ML20214H472

Engineering Assurance Oversight Review Rept,Design Baseline & Verification Program

ML20214H472
Person / Time
Site:	Sequoyah
Issue date:	04/27/1987
From:	Capozzi A, Kazanas N, Weinstein J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20214H443	List: ML20214H442 ML20214H472
References
EA-OR-001, EA-OR-1, NUDOCS 8705270395
Download: ML20214H472 (502)

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Report issue Date: April 29,1987 ENGINEERING ASSURANCE OVERSIGHT REVIEW REPORT SEQUOYAH NUCLEAR PLANT - UNIT 2 DESIGN BASEllNE AND VERIFICATION PROGRAM EA-OR-001 May 14, 1986 through March 31,1987 l

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e > Osf.- J- 29 f 9

,hn W. von Weisenstein / Date Team Leader 2 hb $

Anthony P 4 apozzi ' /) F Date Manager of Engineering Assurance te$alu (

Nicholas C. Kazanas, Dir ww 4 - 7 7 'i~)

Date or Division of Nuclear Qual Assurance

' B705270395 870515 '

PDR ADOCK 05000327 P PDR _

EXECUilVF SupMARY This report represents the results of the Engineering Assurance (EA) Independent Oversight Team's rsview of the Sequoyah pluclear Plant (5Q11) Unit 2 Phase i Design Baseline and Verification Program (084VP) .- The fluclear Performance Plan Volume 2 describes the 004VP and the required independent review cnd oversight of this program.

This program was undertaken as a result of TVA's determination, based on a ntaber of internal and external audits and evaluations, that SQlt lacked a comprehensive and integrated program required for control of design changes during the plant operations phase. Therefore, TVA concluded that a new program for controlling the design modification process was required as well as identifying and correcting problems caused by an inadequate design control process. Theobjectivesof.thisnewprogram were to be achieved in two integrated phases. The first phase concentrated on SQld restart; whereas, the second phase will be devoted to conpleting the other remaining safety-related systems and also correcting the remaining nonrestart findings from Phase 1.

The DB&VP was developed to reconcile this design control issue. The scope of phase I of this program was to provide the required level of confidence that plant systems required to mitigate FSAR Chapter 15 Svents will operate as designed and in conformance with SQIl licensing conmitments. The objectives of this program were as follows:

o Verifying and establishing it.a plant configuration, e Reconstructing the design basis, o Reviewing and evaluating modifications since operating license (OL) issuance against the design basis, o Performing the required tests or modifications developed from this review and evaluation, o Establishing an effective design control process.

To provide added assurance that these activities were adequately performed and documented, EA conducted j an independent oversight review on a sample basis concurrently with the performance of work by the L DB&VPproject. This review was conducted by EA with IdRC participation through inspections. The purpose of this review was to verify that the SQIl DB&VP program has been fully and effectively inplemented and to assess the functional and technical adequacy of modifications made to the systems since OL.

f Theobjectivesofthisindependent,inprocessreviewwereto:

o . Confirm and validate that engineering activities are being conducted in accordance with the overall approved program plan, in accordance with the approved procedures established for the DB8VP, and by personnel trained for the specific activity being confirmed / validated.

e Confirm the functional and technical adequacy of the system evaluations and the completeness / correctness of the supporting doctanentation.

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o Verify that the corrective actions (C/A) resulting from the evaluations have been implemented and doctmented.

o Verify the adequacy and effectiveness of the transitional design change control methodologies and procedures.

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To accoglish the objectives of this review, a team of senior experienced technical personnel was

. selected to conduct progranaatic and detailed technical reviews during the course of the project iglementing this program. The team functioned under the direction of the TVA EA organization. An Advisor with experience in performing 101, IDVP, SSFI, and EA type audits / reviews was assigned by the EA manager to assist the team leader in implementing the EA Oversight Review Process. The team was cogosedofstaffpersonnelfromthemejordisciplinesoftheDivisionofNuclearEngineering(DNE),

Division of Nuclear Quality Assurance (DNQA), and Division of Nuclear Construction (DNC). In addition, other personnel to support the team were provided by engineering services contractors. A nueer of team meters had participated in similar type of audits / reviews as the Advisor.

A program plan was developed to control the oversight review process. In addition, each discipline prepared a detailed plan of action describing their respective discipline involvement in each phase of the oversight review. The team performed an inprocess review, on a sample basis, of every aspect of the prerestart phase of the D88VP as the project cogleted its document preparation, document revisions, and/or reviews of the work products.

The EA Team prepared action items which defined concerns identified by the team during this in-process rsview. The action items were processed through the DB4VP project. The project evaluated the concerns and provided responses which included the cause, extent, corrective action, action to prevent recurrence, and significance. The EA reviewer evaluated the project's responses and documented acceptability,includingverificationforclosure,orreasonforrejectingtheresponse. Any apparent trendswhichmighthaveledtogenericconcernswereaddressedseparatelywiththeprojectfor appropriate action.

The 084VP was a cogrehensive program iglemented by TVA for the first time at Sequoyah unit 2. Three hundred and fif ty-seven action items were issued by the EA Team during their reviews identifying problems and concerns. The types of problems and concerns that resulted from the EA review were neither unusual nor unexpected during a first of a kind program like the DB&VP. In most instances problems identified were corrected or are in the process of being corrected. Except for the drawing comparison activity which resulted in no action items, implementation of project corrective action was necessary before the overall adequacy of work products could be established. For those problems that have been resolved, any similar condition which existed elsewhere, found through project investigation, was also addressed. Where appropriate, the D88VP project iglemented action to prevent recurrence of a condition. The 088VP project is required to provide a similar evaluation of root cause, extent, and corrective and preventive actions to adequately address the remaining unresolved action items identified by the EA Team.

Significant corrective and preventive actions by the project were necessary to prevent recurrence of f several adverse trends recognized as a result of EA Team action items. Preventive actions were also required in response to progrannatic deficiencies identified in individual EA action items. Some of

~ the more significant corrective and preventive actions taken were:

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o A stopwork order in the electrical discipline was issued by the Chief Electrical Engineer in g response to an adverse trend with change document evaluations. All electrical checklists were l subsequently reevaluated and personnel retrained. Fourteen problem identificatior, reports and 150 punchlist items resulted from this effort.

o The scope of electrical and l&C walkdowns was increased,

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o DB&VP personnel were formally retrained to SQEP-il and SQEP-12 with an eghasis on EA concerns.

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e An enhanced civil engineering review group was established.

e AmemorandumfromtheSequoyahProjectEngineertoWestinghousewasissuedtoprovideguidanceon the level of justification and doctanentation necessary to support SQEP-12 checklist evaluations.

o A memorandum was issued from the Program Manager describing the actions to be taken in response to an adverse trend with identification of commitments / requirements (C/Rs) and incorporation of C/Rs into design criteria.

e A separate management review team was established to re-review significant decisions for Problem Identification Reports.

o A Project Directive was issued with instructions defining the depth of engineering evaluations required, o AProjectDirectivewasissuedrequiringinterdisciplinereviewofSYSTERreports, e AProjectDirectivewasissuedrequiringreconciliationofrestartdecisionswithSYSTERsand concurrence review by the system engineer with corrective action determinations, e A reevaluation of the project's technical decisions on restart and the rationale to support these decisions resulted in changes from postrestart to prerestart action, e SQEP-57, " Processing of Test and Retest Requirements identified During the Design Baseline and Verification Program," was issued.

An assessment of the causes which resulted in the concerns expressed in the EA Team action items was performed to provide additional understanding of problems in implementing the DMVP. Two of the most significant causes of these concerns were:

e Misunderstanding of the level of doctsnentation of engineering judgment necessary to conform to DNE Policy Memorandum PM86-04, Engineering Judgnent, e Misinterpretation of requirements for depth of engineering evaluations.

As a result of the FA oversight review and the project's implementation of C/A addressing the EA concerns, the EA Team developed the following overall conclusions:

1. The inplementation of the DMVP procedures was generally conplete and adequate to meet the f objectives of the program, and the activities conducted by the DMVP were generally correct, adequate, and in accordance with program procedures.

2. Subject to adequate inplementation of appropriate C/A, the DMVP project demonstrated the functional and technical adequacy of modifications by providing and/or identifying supporting documentation and justification to establish that nodifications comply with the reestablished f restart design basis requirements. In addition, the existence and technical adequacy of calculations will be established through the DNE calculation program, and the results will be verified by EA.

3. Ntsnerous technical issues have been identified by the DMVP evaluaticns, and an adequate identification process nas been demonstrated. However, the C/A process for these issues has not l progressed suf ficiently to develop a final conclusion on its adequacy. Review of C/A and l verification of acceptable implementation of C/A, when conpleted, are required by the EA Team.

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4. A transitional change control program has been established for the SQN site. However, EA review of this program indicated the iglementation of the new process is only occurring in a small percentage of the engineering changes being made. To ascertain if problems in the process exist in its iglementation and to ensure that effective iglementation has occurred, further review of this process is required by the EA Team.

There are no apparent progranmatic weaknesses remaining to be resolved with the program as a result of the EA Team findings and project action to address these findings. Only a few concerns that address potential weaknesses in the iglementation of some program elements remain to be resolved with the project. Except for these unresolved concerns, the extent of problems has been determined and bounded God the problems have been corrected or are being corrected. However, verification of a nunter of projectactionsbytheEATeamremains.

Based upon verification of adequate C/A for the observations noted in this report including C/A on the DB&VP findings and further iglementation of the transitional design control system, the prerestart phase of the DB&VP has been fully and effectively igtemented.

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TABLE OF CONTENTS P_a_g!t 1.0 INTR 000Cil0N . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.1 Background ....................... 1-1 1.2 Report Content ..................... 1-2 2.0 PURPOSE AND SCOPE ...................... 2-1 2.1 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.2 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 3.0 REVIEW PROCESS . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3.1 Independent Review ................... 3-1 3.2 EA Oversight Review Program Plan ............ 3-1 3.3. Tracking of Action items ................ 3-2 3.4 Approach ........................ 3-2 3.5 Organization of the EA Team . . . . . . . . . . . . . . . 3-3 3.6 Conduct of EA Review .................. 3-4 4.0 SUMARY ........................... 4-1 4.1 General . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.2 Review Results ..................... 4-3 4.2.1 System Boundaries Determination . . . . . . . . . . . . 4-3 4.2.2 Walkdowns . . . . . . . . . . . . . . . . . . . . . . . 4-3 4.2.3 Conparison of As-Designed Drawings Walkdown Results . . 4-4 4.2.4 Electrical Test Results Evaluations . . . . . . . . . . 4-4 4.2.5 Change Document Evaluations . . . . . . . . . . . . . . 4-4 4.2.6 Design Criteria . . . . . . . . . . . . . . . . . . . . 4-5 4.2.7 System Evaluations including C/A ........... 4-6 4.2.8 Transitional Change Control . . . . . . . . . . . . . . 4-7 4.2.9 DB&VP Phase i Report (Preliminary) .......... 4-7 4.3 Conclusions . . . . . . . . . . . . . . . . . . . . . . . 4-8 5.0 OBSERVATIONS AND CAQRs . . . . . . . . . . . . . . . . . . . . 5-l 6.0 SUMARY BY DISCIPLINE .................... 6-1 APPROVALS BY EA TEAM REVIEWERS . . . . . . . . . . . . . . . . 6-2 6.1 Nuclear . . . . . . . . . . . . . . . . . . . . . . . . . 6.1-1 6.2 Electrical ....................... 6.2-1 6.3 instrumentation and Controls .............. 6.3-1 6.4 Mechanical ....................... 6.4-1

6. 5 C i v i l . . . . . . . . . . . . . . . . . . . . . . . . . . 6.5-1 6.6 Operations Engineering ................. 6.6-1 6.7 Quality Assurance . . . . . . . . . . . . . . . . . . . . 6.7-l 6.8 Construction. . . . . . . . . . . . . . . . . . . . . . . 6.8-1 i

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TABLE OF CONTENTS (Continued)

Pag!t 7.0 DETAILED RESULTS BY ACTIVliY ANO BY DISCIPLINE . . . . . . . . 7-1 7.1 System Boundaries Determination . . . . . . . . . . . . . 7.l-1 7.1.1 huclear . . . . . . . . . . . . . . . . . . . . . . . . 7.1.1-1 7.2 System Walkdown . . . . . . . . . . . . . . . . . . . . . 7.2-1 7.2.1 Nuclear . . . . . . . . . . . . . . . . . . . . . . . . 7.2.1-1 7.2.2 Electrical ...................... 7.2.2-1 7.2.3 Instrumentation and controls ............. 7.2.5-1 7.2.4 Mechanical ...................... 7.2.4-1 7.2.5 Civil . . . . . . . . . . . . . . . . . . . . . . . . . 7.2.5-1 7.2.6 Operations Engineering ................ 7.2.6-1 7.2.7 Quality Assurance . . . . . . . . . . . . . . . . . . . 7.2.7-1 7.3 Comparison of As-Designed Drawings with Walkdown Results. 7.3-1 7.3.1 Operations Engineering ................ 7.3.5-1 7.4 Electrical Test Results Evaluations . . . . . . . . . . . 7.4-1 7.4.1 Electrical ...................... 7.4.1-1 7.4.2 Instrumentation and Controls ............. 7.4.2-1 7.4.3 Operations Engineering ................ 7.4.5-1 7.4.4 Quality Assurance . . . . . . . . . . . . . . . . . . . 7.4.4-1 7.5 Change Document Evaluation ............... 7.5-1 7.5.1 Nuclear . . . . . . . . . . . . . . . . . . . . . . . . 7.5.l-1 7.5.2 Electrical ...................... 7.5.2-1 7.5.3 Instrumentation and controls ............. 7.5.3-1 7.5.4 Mechanical ...................... 7.5.4-1 7.5.5 civil . . . . . . . . . . . . . . . . . . . . . . . . . 7.5.5-1 7.5.6 Quality Assurance . . . . . . . . . . . . . . . . . . . 7.5.6-1 7.5.7 Construction ..................... 7.5.7-l 7.6 Design Criteria . . . . . . . . . . . . . . . . . . . . . 7.6-1 7.6.1 Nuclear . . . . . . . . . . . . . . . . . . . . . . . . 7.6.1-1 7.6.2 Electrical ...................... 7.6.2-1 7.6.3 Instrisnentation and Controls ............. 7.6.3-1 7.6.4 Mechanical ...................... 7.6.4-1 7.6.5 civil . . . . . . . . . . . . . . . . . . . . . . . . . 7.6.5-1 7.7 System Evaluation . . . . . . . . . . . . . . . . . . . . 7.7-1 7.7.1 Nuclear . . . . . . . . . . . . . . . . . . . . . . . . 7.7.1-1 7.7.2 Electrical ...................... 7.7.2-1 7.7.3 Instrumentation and Controls ............. 7.7.3-1 7.7.4 Mechanical ...................... 7.7.4-l 7.7.5 Civil . . . . . . . . . . . . . . . . . . . . . . . . . 7.7.5-1 7.7.6 Operations Engineering ................ 7.7.6-1 7.7.7 Quality Assurance . . . . . . . . . . . . . . . . . . . 7.7.7-1 li

TABLE OF CONTENTS (Continued)

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7.8 Transitional Change Control . . . . . . . . . . . . . . . 7.8-l 7.8.1 Operations Engineering ................ 7.8.1-1 7.8.2 Quality Assurance . . . . . . . . . . . . . . . . . . . 7.8.2-I 7.8.3 Construction ..................... 7.8.3-1 7.9 Phase i D88VP Report (Preliminary) ........... 7.9-1 7.9.1 Nuclear . . . . . . . . . . . . . . . . . . . . . . . . 7.9.1-1 7.9.2 Electrical ...................... 7.9.2-1 7.9.3 Instrumentation and Controls ............. 7.9.3-1 7.9.4 Mechanical. . . . . . . . . . . . . . . . . . . . . . . 7.9.4-1 7.9.5 civil . . . . . . . . . . . . . . . . . . . . . . . . . 7.9.5-1 7.9.6 Qua l i t y Assura nce . . . . . . . . . . . . . . . . . . . 7.9.6-1 8.0 TREND ANALYSIS OF EA TEAM FINDINGS ........... 8-1 0.1 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . 8-l 8.2 Purpose of the Trend Analysis of EA Action items .... 8-2 8.3 Approach ........................ 8-3 8.4 Sumnary Analysis of EA Team Action items ........ 8-5 8.5 Selection of Action items for In-Depth Evaluation . . . . 8-13 8.6 Process for in-Depth Evaluation of Selected Action items ........................ 8-13 8.7 in-Depth Evaluation . . . . . . . . . . . . . . . . . . . 8-14 Table 3.2-1 EA Team Scope of Review by Discipline (Review Plan Nunber)

Table 3.6-1 NRC Observations and Corresponding EA Team Action items Table 4.1-1 Open EA Action items that Require Disposition During Phase i Table 8.4-1 Action items Generated by the EA Team (Prt.sented by Activity)

Table 8.4-2 No Corrective or Preventive Action Table 8.4-3 Postrestart Action items Table 8.4-4 Prerestart Action items Table 8.4-5 Invalid Findings Table 8.4-6 Action items Requiring Corrective and/or Preventive Action (Presented by Activity)

Table 8.4-7 Category Codes for Trending EA Oversight Review Concerns Design Baseline and Verification Program - Sequoyah Nuclear Plant Figure 8.4-1 Total Action items for Each Activity Phase of the EA Oversight Review Figure 8.4-2 Finding Type Categories - All Action items Figure 8.4-3 Finding Type Subcategories - All Action items Figure 8.4-4 Affected Document Types Figure 8.4-5 Discipline Responsibility for Corrective Action Figure 8.4-6 Corrective Actions Figure 8.4-7 Preventive Actions Figure 8.4-8 Cause Assessment for Action item Findings Figure 8.4-9 Assessment of Extent of Action item Findings lii

TA8LE OF CONTENTS (Continued)

Figure 8.4-10 Assessment of Significance for Action item Findings Figure 8.4-11 Number of Action items Resulting in the issuance of a CAQ Document.(PIR/SCR)

Figure 8.4-12 Activity Type Codes - Comparison of System 72 (Contalmnent Spray System) Findings by Activity to Remainder of Action items Figure 8.4-13 Finding _ Type Subcategories - Comparison of System 72

. (Containment Spray System) to Remainder of Findings Figure 8.4-14 Preventive Actions - Comparison of System 72 (Containment Spray System) to Remainder of Preventive Actions Figure 8.4-15 Cause Assessment - Comparison of System 72 (Containment Spray System) to Remainder of Causes Figure 8.7-1 Finding Type Subcategories - Conparison of Closed Action items to Open Action items Figure 8.7-2 Finding Type Subcategories - All Evaluated Action items Figure 8.7-3 Comparison of Resolved and Closed Action item Findings - Corrective Actions Figure 8.7-4 Comparison of Resolved and Closed Action item Findings - Preventive Actions Figure 8.7-5 Comparison of Resolved and Closed Action item Findings - Cause Assessment Figure 8.7-6 Comparison of Resolved and Closed Action item Findings - Assessment of Extent Figure 8.7-7 Affected Document Types for Evaluated Action item Findings Figure 8.7-8 Evaluated Action item Findings - Discipline Responsibility Figure 8.7-9 Evaluated Action item Findings Ranked by Responsible Discipline Design Deficiencies Figure 8.7-10 Evaluated Action item Findings Ranked by Responsible Discipline Design Process / Methods inadequate Figure 8.7-1l Evaluated Action item Findings Ranked by Responsible Discipline inadequate Interface Control Figure 8.7-12 Evaluated Action item Findings Ranked by Responsible Discipline Design Criteria Deficiencies Figure 8.7-15 Evaluated Action item Findings Ranked by Responsible Discipline Design Corrective / Preventive Action inadequate Figure 8.7-14 Evaluated Action item Findings Ranked by Responsible Discipline USQD Deficiencies Figure 8.7-15 Evaluated Action item Findings Ranked by Responsible Discipline Test Requirements / Test inplementation Deficient Figure 8.7-16 Evaluated Action item Findings Ranked by Responsible Discipline Records-Retention inadequate Figure 8.7-17 Evaluated Action item Findings Ranked by Responsible Discipline Miscellaneous Deficiencies Figure 8.7-18 Cause Assessment for Evaluated Action items Findings Figure 8.7-19 Preventive Actions for Evaluated Action item Findings Figure 8.7-2D Assessment of Extent of Evaluated Action item Findings Figure 8.7-21 Assessment of Significance for Evaluated Action item Findings iv i

TABLE OF CONTENTS (Continued)

Appendix A Meeting Attendees Appendix B Procedure for Evaluation of Technical Audit Results Memo Appendix C Listing of Finding Type Categories and Subcategories Appendix D ListingofAllActionitems Appendix E Listing of All Evaluated Action items Appendix F Evaluated Findings - Basis for Design Not Documented - Finding Type Subcategory Appendix G Evaluated Findings - Required Design Factor Not Analyzed -

Finding Type Subcategory Appendix H Evaluated findings - No Basis for Design input / Assumption -

Finding Type Subcategory Appendix I Evaluated Findings - Incorrect Design input /Assug tion - Finding Type Subcategory Appendix J Evaluated Findings - Iglementation of Adnin Guidance Deficient - Finding Type Subcategory Appendix K Evaluated Findings - Design Documents Conflict - Finding Type Subcategory Appendix L Evaluated Findings - Miscellaneous Drawing Deficiencies - Finding Type Subcategory Appendix M Evaluated Findings - Iglementation of Technical Guidance Deficient - Finding Type Subcategory Appendix N Evaluated Findings - Miscellaneous Design Document Defic (Exc Dwg and Calc) - Finding Type Subcategory Appendix 0 Evaluated Findings - Missing / inadequate Design Process Procedures - Finding Type Subcategory Appendix P Evaluated Findings - Technical Guidance inadequate - Finding Type Subcategory Appendix Q Evaluated Findings - Internal Discipline Interface Deficient - Finding Type Category Appendix R Evaluated Findings - Missing Requiranents in Design Criteria - Finding Type Subcategory Appendix S Evaluated Findings - Inadequate / Incog lete Requirements in Design Criteria - Finding Type Subcategory Appendix T Evaluated Findings - Potentially Generic Design Problem Not Addressed -

Finding Type Subcategory Appendix U Evaluated Findings - Corrective Action inadequate - Finding Type Subcategory Appendix V Evaluated Findings - Inca glete Evaluation of USQDs - Finding Type Subcategory Appendix W Evaluated Findings - Test Results inadequate - Finding Type Subcategory Appendix X Evaluated Findings - Operations and Maintenance Related - Finding Type Subcategory Appendix Y Other Findings (Not Evaluated in Depth)

Appendix Z Evaluated Findings - Adninistrative Findings Not Affecting the Design Process Appendix AA Listing of All Action items Resulting in a PIR/SCR v

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ABBREVIATIONS AND ACRONYMS ANSI American National Standards Institute AC Alternating Current ACA Auxiliary Control Air

'ACR Auxiliary Control Room Al Adninistrative Instruction A01 Abnormal Operating Instruction AP SYS Auxiliary Power System BIT Boron Injection Tank BlSI Bypassed and inoperable Status indication B/M Bill of Material C/A Corrective Action C/R Connitment/ Requirement

.CAQ Condition Adverse to Quality CAQR Condition Adverse to Quality Report CBI Chicago Bridge and Iron CCB Change Control Board CCD Configuration Control Drawing CCP Centrifugal Charging Pung CCS Conponent Cooling System CCW Conponent Cooling Water CDA Conmitment Document Assignment CDES Change Document Evaluation Sheet CGCS Cont >ustible Gas Control System CEB Civil Engineering Branch CLE Civil Lead Engineer CRAD Control Room As-constructed Drawings CSS Containment Spray System CVCS Chemical and Volume Control System DB8VP Design Baseline and Verification Program DBA Design Basis Accident DC Direct Current DES Discipline Evaluation Supervisor DG Diesel Generator 01 Discipline Instruction DNS8L Division of Nuclear Safety and Licensing DIM Design input Memo DNC Division of Nuclear Construction DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DR Discrepancy Report DRC Design Review Checklist DCR Design Change Request vi

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EA Engineering Assurance ECB Engineering and Conputer Methods Branch ECN Engineering Change Notice EEB Electrical Engineering Branch EGTS Emergency Gas Treatment System ElR Engineering Installation Requirement EPT Ethylene Propylene Terpolymer ER Engineering Report ERCW Essential Raw Cooling Water ER/SD Evaluation Review / Study Drawing ESTS Engineering and Technical Services ESF Emergency Safety Feature EQ Environmental Qualification EPVF Electrical Panel Vent Fans FCN Field Change Notice FCR Field Change Request FCV Flow Control Valve FSAR Final Safety Analysis Report FT Functional Tests ff/lb Foot / Pound GSPS Generating Station Protective System GDC General Design Criteria hp Horsepower HMS Hydrogen Mitigation System HVAC Heating, Ventilating, and Air-Conditioning HX Heat Exchanger IRC Instrumentation and Controls ICSB instrumentation and Control Systems Branch IMI instrument daintenance Instruction IMPL Implemented L-DCR Local Design Change Request LC Loss of Charger LER Licensee Event Report LOCA Loss-of-Coolant Accident MAAl Modifications and Additions Instruction MCR Main Control Room MEB Mechanical Engineering Branch MFIV Main Feedwater Isolation Valves MOV Motor-operated Valves MR Maintenance Request MSS Main Steam System vii i

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NCR' Nonconformance Report NEB Nuclear Engineering Branch NEP Nuclear Engineering Procedure NLE Nuclear Lead Engineer NPSH Net Positive Suction Head NRC Nuclear Regulatory Conmission NRR Nuclear Reactor Regulation NSD-TB Nuclear Service Division - Technical Bulletin (Westinghouse)

NSSS Nuclear Steam Supply System NUC PR Formerly the Division of Nuclear Power OBE Operating Basis Earthquake OEP Office of Engineering Procedure OES Operations Engineering Services ole Office of Inspection and Enforcement OL Operating License 08MO Operations and Maintenance ONP Office of Nuclear Power OWil Outstanding Work item List PAM Postaccident Monitoring PGCE Potential Generic Condition Evaluation PIR Problem Identification Report PLS Precautions, limitations, and Setpoints PM Policy Memorandum FMI Postmodification Test PRO Potential Reportable Ocurrences PS ProjectStaff QA Quality Assurance QC Quality Control QMOS Qualification Maintenance Data Sheet RAP Responsible Action Party RCS Reactor Coolant System R000 Restart Design Basis Docisnent RG Regulatory Guide ,

RHR Residual Heat Removal RIMS Records and Information Management System RPS Reactor Protection System RWST Refueling Water Storage Tank

'Also may indicate Nonconforming Condition Report.

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SCR Signlficant Condition Report SCV Steel Containment Vessel SDE Senior Discipline Engineer SE System Engineer SER Safety Evaluation Report SG Steam Generator l SGB Steam Generator Blowdown SHDN BD Shutdown Board St Surveillance Instruction SIS SafetyinjectionSystem SMI Special Maintenance Instruction S01 System Operating Instruction .

SOR Static-O-Ring SQEP' Sequoyah Engineering Project SQN Sequoyah Nuclear Plant STA Shift Technical Advisor SSE Safe Shutdown Earthquake STEP System Test Evaluation Package SWBID System Walkdown Boundary identification Drawing SYSTER System Evaluation Report j TACF Tenporary Alterations Control Form TCV Temperature Control Valve TDAFP Turbine-Driven Auxiliary Feedwater Punps il Technical Instruction TROI Tracking and Reporting of Open items TVA Tennessee Valley Authority UHI UpperHeadinjection USQO Unreviewed Safety Question Determination VP SYS Vital Control Power System WBN Watts Bar Nuclear Plant WDS Waste Disposal System WDP Walkdown Package WOG Westinghouse Owner's Group WP Workplan WR Work Request WCLD (Westinghouse Unique No. on Calculati W

'Also used to mean Sequoyah Engineering Procedure, ix l

l.0 INTR 00VCT10N l.1 Background As a result of an evaluation of the Sequoyah Nuclear Plant (SQN) problems, the DNE staff concluded that the primary cause of these problems was related to the lack of a comprehensive and integrated program for the control of design during plant operation (memorandum from W. C. Drotleff to S. A. White dated March 31,1986, entitled Sequoyah Nuclear Plant - Design Control Verification). Based on this, DNE management initiated action to develop a design verification of selected safety systems prior to restarting the units. The purpose of this i system verification was to provide the required level of confidence that the plant safety systems essential for mitigation of FSAR Chapter 15 events will operate as designed and in conformance with SQN licensing connitments. Tosupplementtheseobjectives,DNEmanagement also recognized the need to iniplement an Engineering Assurance independent oversight review process during the implementation of this design verification effort.

in support of this action, TVA conmitted to the implementation of a Design Baseline and Verification Program (D88VP) for Sequoyah Nuclear Plant (SQN) unit 2 in Volune 2 of the Sequoyah Nuclear Performance Plan. The DB&VP was designed to address the following control issues:

e Verifying and establishing the plant configuration, o Reconstructing the design basis.

e Reviewing and evaluating modifications since OL issuance against the design basis, o Performing the required tests or modifications developed from this review and evaluation.

o Establishing an effective design control process. i i

TVA comnitted to perform an independent progranmatic and technical inprocess review by DNE's Engineering Assurance (EA) of the DB&VP to provide added assurance that the engineering activities associated with the program are conducted in a technically adequate manner and in accordance with program procedures. This inprocess review was to be performed during the course of the project implementation of the DB&VP. To meet this independent review conmitment, an Engineering Assurance Oversight Team of senior experienced technical personnel was organized (hereafter referred to as the EA Team).

The DB&VP was inplemented in two phases. Phase 1, prestart phase, carried out the program for the systems required to mitigate FSAR Chapter 15 events. Phase 11, postrestart phase, was intended to continue the engineering activities to conplete engineering documentation f describing the as-constructed configuration and extend the program to other safety-related systems.

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1.2 Report Content This report presents the results of the EA Team review of the Phase I effort of the DB&VP.

Section 1.0, Introduction, provides the background which resulted in this effort and the repori logic.

Section 2.0, Purpose and Scope, includes the objective tasks and the extent of the reviews.

Section 3.0, Review Process, includes a description of the oversight review process, the organization of the EA Team, the EA Program Plan and Review Plan, and the NRC involvement in the review process.

Section 4.0, Sunmary, includes a sunmary of the results of the review process, the findings, andtheconclusionsastotheextentthattheDB&VPProgramandEATeamobjectivesweremet.

Section 5.0, Observations and CAQRs, includes a description of each finding that was not fully addressed by the project and verified by the EA Team during the review.

Section 6.0, Surrmary by Discipline, includes a brief description of the activities each EA Team ment >er reviewed, the associated observations, and an overall conclusion on the work performed by the respective DB&VP discipline.

Section 7.0, Detailed Results by Activity and by Discipline, includes the details of the review activities, the attributes used to assess the adequacy of the work, the ntrnber of products reviewed, and results and conclusions by activity.

Section 8.0, Trend Analysis of EA Team findings, includes an analysis of the findings identified by the EA Team and the NRC during the reviews.

Appendixes have been included to provide detailed supporting information relating to the program, such as the attendees at the entrance and exit neetings and supporting information for the trend analysis of the EA Team findings.

t

[

l I

L I-2

2.0 PURPOSE AND SCOPt 2.1 Purpose The objective of the Engineering Assurance Oversight was to perform an independent oversight l

review of the DB&VP. This review was to provide added assurance that the engineering activities associated with the program were conducted in a technically adequate nenner and in accordance with the written procedures prepared specifically for this effort.

The Engineering Assurance Oversight team monitored, on a sagle basis, the DS&VP as the project I

completed its document preparation, document revisions, and evaluations. This review was intended to:

o Confirm and validate that engineering activities were being conducted in accordance with the approved program plan and procedures established for the DB&VP.

e Confirm functional and technical adequacy of system evaluations and completeness / correctness of supporting documentation.

e Verify the corrective actions resulting from these evaluations had been documented and inplemented.

in addition, SQN is required to have the Transitional Design Change Control Program in place prior to restarting the SQN Plant Unit 2. Accordingly, the EA Team reviewed the adequacy of this program to assess its effectiveness in controlling the design change process for continued use at SQN.

In addition to reviewing the DB&VP activities, the EA Team performed a separate programnatic and technical audit of the DNE calculation program. The results of the calculation audit are presented in a separate EA audit report 87-09(T). However, a brief sumnary of the results and status are included in this report for completeness in Section 6.0.

2.2 Scope The EA Team performed an independent and inprocess review of the activities associated with the DB&VP. These activities included the following:

e System boundaries determination e System walkdowns e Conparison of as-designed drawings with walkdown results e Electrical test results evaluations e Change document evaluations e Design criteria (including C/R data base generation) e System evaluations including corrective actions e Transitional design change control process e DB&VP phase I report To achieve the objectives of this ef fort, the EA Team review was both technical and programnatic in nature. Material for review was sampled while the activities were being conducted. The sanple size varied depending upon the activity, type of findings raised, and the magnitude of the DB&VP ef fort. In general, at least a 5 percent sample size was used. General criteria for selecting samples were provided by the team leader. The EA Team disciplines prescribed specific criteria unique to their areas of concern.

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l 5.0 REVIEW PROCESS 3.1 Independent Review l

l l

To meet the IVA objective of independence in Voltane 2 of the Nuclear Performance Plan, the EA l Team ment >ers were selected from personnel not af filiated with the work performed by the DB&VP. In this manner, the EA Team could perform an independent review and assessment of the technical adequacy of the work.

5.2 EA Oversicht Review Proaram Plan The EA Team prepared a program plan which defined the objectives and general approach on how the review process was to proceed. This program plan governed the general conduct of the EA Team including the manner in which the Team was to interface with the project and the means by which the EA Team conveyed concerns to the DB&VP resulting from the reviews. The pro 2 ram plan for the EA Team was submitted to the Nuclear Regulatory Centnission (NRC) Office of Inspection and Enforcement (IE) on June 27, 1986.

Discipline-specific review plans were prepared for each EA Team discipline that was actively involved in each review. The plans were prepared to establish a detailed scope of the review; to ensure a consistent, integrated approach by team ment >ers; and to provide a consistent format for recording review activities.

Review plans were discipline specific and included general information pertaining to the specific activities that were to be reviewed. A detailed breakdown by activity was included in each review plan, as well as the plan of action to acconplish the activity, the sample size selected, the specific criteria used for selecting the documents to be reviewed, and the attributes used to evaluate the adequacy of the document being reviewed. Space was provided on the attribute sheets to record the results. Table 5.2-1 simnarizes the specific activities that each discipline reviewed.

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3.5 Trackina of Action items During the EA Team review, potential concerns, questions, and requests for information were directed to the project through action item forms. Theprojectevaluatedandrespondedto each action item. The adequacy of the project's responses was evaluated for acceptance by the EA Team menters before verification and closeout. Where problems were determined to exist, the project evaluated the cause, extent, action to be taken to correct and prevent the problems, and significance, as appropriate.

The EA Team prepared action items whenever one of the following conditions arose during the review process:

o A technical concern was apparent.

e A potential concern was apparent and no information was readily available to substantiate or alleviate the concern, o A program aspect or practice was observed that was, or appeared to be, incorrect or inadequate, e it was deemed necessary for the project to investigate the cause and extent of problems.

e it was deemed appropriate to evaluate the project's proposed actions to correct problems and prevent recurrence.

The appropriate team members and team leader evaluated the responses to all action items for acceptability, validity, and potential inpact on subsequent project work activities.

The EA Team maintained a status report of action items which included: separate listings by discipline of each action item with a description of the action item, the EA reviewer / project responseassignee,thesubmittaldatetoproject,andtheresolution/closuredates. The status report was updated on a frequent basis and provided to project nunagement personnel, Division of Nuclear Engineering (DNE) management, and team menters, i

Several meetings were conducted during the review with the DBaVP Program Manager and other l project personnel whenever key issues arose that could potentially inpact the project work.

3.4 Approach The approach taken by the EA Team in reviewing activities was to perform an inprocess review of selected products, on a discipline basis, as they were conpleted by the project. Products were selected from each location at which work was being performed (SQN Site, TVA-Knoxville, Westinghouse, and inpell).

To complement these discipline reviews, the EA Team selected one system for an interdiscipline review.

The system selected for the interdiscipline review, the Containment Spray System (CSS), was selected based on the following criteria:

e The najor portion of the system is needed to mitigate FSAR Chapter 15 events ,

e The system has had several modifications since operating license (OL)

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e The system includes multidiscipline engineering aspects e The system includes Nuclear Steam Supply System (NSSS) interface t

e The system was not reviewed in previous audits For this chosen system, each discipline reviewed sanples of work the project produced, up to and including the system evaluation and corrective action determination. This nultidiscipline, cannon system review emphasized interdiscipline interfaces and provided a means of identifying potential interface problems that were not apparent when reviewing sanple products from each program activity, in addition to the document reviews, the EA Team perforned selected walkdowns in order to verifytheadequacyoftheproject'swalkdownresults. This verification was accomplished by conparing the results of the EA Team walkdowns with those of the project. Differences were identified to the project in action items.

5.5 Oroanization of the EA Team The team was organized by the TVA Engineering Assurance organization and included TVA and contractor personnel. The Team consisted of senior-level personnel under the direction of the Team Leader, J. W. von Weisenstein. To assist the Team Leader an Advisor, M. P. Berardi, was assigned by the EA Manager to provide advice and guidance in implementing the oversight review. The advisor, as well as a nunber of other team mesters had experience in performing 101, IDVP, SSFl and EA type audits / reviews. This experience was useful in performing the EA oversight process in accordance with current nuclear industry practices. TVA team menbers were off-project personnel representing their respective branches / divisions / staffs. When requested, additional assistance was provided to the Team by TVA branches / divisions / staffs.

The Team consisted of the following personnel:

Discipline Team Menber Title Engineering Assurance J. W. von Acting Supervisor, Weisenstein Technical Audit Staff (Team Leader)

'M. P. Berardi Advisor "F. E. Denny Quality Assurance Engineer R. J. Floyd Quality Assurance Engineer Nuclear D. G. Renfro Lead Nuclear Engineer l

C. Carey Nuclear Engineer

! Electrical B. M. Gore Lead Electrical Engineer K. F. Liao Electrical Engineer J. W. Semore Electrical Engineer

( Instrumentation and 'R. J. Faubert Lead l&C Engineer Controls "C. E. Gross Electrical Engineer E. E. McBee instrument Engineer

'D. S. Vassallo Senior Control Systems Engineer 1

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.. ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ . s

Mechanical 'S A. Shunen Lead Mechanical Engineer

'D. R. Barnaby Mechanical Engineer R. Tucker Mechanical Engineer Operations Engineering 'T. G. Carson Lead Operations Engineer Civil *R. P. Svarney lead Civil Engineer H. G. Bird Civil Engineer "C. K. Buck Civil Engineer A. B. Savery Civil Engineer r

Quality Assurance P. R. Bevil Lead Quality Assurance Engineer T. E. Spink PerformanceAssessmentProjectEngineer Construction F. E. Gilbert Lead Construction Engineer

' Indicates contract personnel

" Reassigned during the course of EA Team reviews. Their duties and responsibilities were assumed by other team menbers in their respective disciplines.

Preparation for the EA Team review began in March 1906 with the organization of a team.

l Af ter the team menters were assigned, the reviewers were indoctrinated and oriented through part of April and May; this included:

e Familiarization with the D8&VP plan e Familiarization with the EA Oversight Review Program Plan e Familiarizationwithexistingprojectdocuments e Review of audit reports pertaining to the problems which led to the decision that initiated the DB&VP The review began with an entrance meeting at SQN on May 14,1906. The purpose, scope, and approach of the EA Team review were presented at this meeting. (See Appendix A, exhibit I for attendees.)

3.6 Conduct of EA Review Theprojectperformeda100percentreevaluationofdesignchangeswithinthesystemboundary scope of the DB&VP. The EA Team reviewed samples of products resulting from each activity.

Thereviewproceededinparallelwiththeprojectactivitieswhereverfeasibleinorderthat concernsraisedfromthereviewcouldbefedbacktotheprojectasactionitemsinatimely menner. This allowed time for the project to respond and take appropriate action to correct EA reviewer findings, and to implement measures to correct generic problems in the evaluation process before the specific activity was completed and subsequent related activities were initiated.

The NRC-lE inspections of the DB&VP and evaluation of the EA Team results were performed during June 10-20, 1986; July 21-24, 1906; November 3-7, 17-21, Decenter I-4,1986 (3-week inspection); and March 2-13,1907.

Concerns raised by the NRC during their first three inspections were processed through the project by use of the EA action item system. Project responses to the concerns issued as action items were transmitted to the EA Team for review and approval. The EA Team coordinated the responses to NRC-initiated concerns with the NRC team. The concerns raised 3-4

- - _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _~

1 during the March 2-15 inspection were handled by the project directly with the NRC through the SQN Licensing Section. A sunnary of the NRC observations from the first three inspection reports and the corresponding EA Team action items is presented in Table 3.6.l. The status j of the observation as of the time of this report is also included.

1 A fornal notification was issued on March 2, 1981 (805 870302 007), informingtheproject that March 22, 1987 wasthelastdatetheEATeamwouldactonprojectresponsestoaction items for consideration in this report. However,theprojectwasadvisedtocontinuetheir effort in responding to action items even after this date, because they were obligated to address all concerns so the concerns could be closed. The project was notified that any action item not closed at the time of the final report would be converted to an observation or CAQR if applicable.

A postreview conference was held at SQN on March 31, 1987, to sum mrize the results of the EA Team reviews. (See Appendix A, exhibit 2 for attendees.) This report presents results of the reviews completed as of March }l, l%7. In addition, April 15,1%7, was the last date at which the EA Team conpleted the evaluation of project action item responses. These are reflected in the detail results presented in Section 7.0. For purposes of trending (Section 8.0), the cut-off date for action items was March 31, 1987.

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TABLE 3.6-1 NRC OBSERVAil0NS AND CORRESPONDING EA TEAM ACTION ITEMS NRC Repop NRC Observation" EA Action item 50-327/86-38 1.1 (open) 0-16 and 1.2 (open) 0-09, 0-15 50-328/86-38 1.3 (open) M-10 Septenter 15, 1986 1.4 (closed) 0-06, 0-21 2.1 (closed) 0-07 2.2 (closed) 0-21 3.1 (closed) 0-07 3.2 (closed) C-07 '

3.3 (closed) C-07 f 4.1 (closed) N-09 L 4.2 (open) N-Il 4.3 (closed) 0-10 5.I (open) 1-03 5.2 (closed) E-17' 5.3 (closed) E-33',E-70' --

5.4 (open) E-14, N-13 6.1 (closed) 1-09 6.2 (open) N-10 6.3 (open) 1-08, 0-07 6.4 (closed) 0-06 7.1 (closed) 0-14 50-321/86-45 2.3 (open) M-22 and 3.4 (open) C-16 50-328/86-45 4.4 (open) N-22 October 31, l%6 4.5 (closed) N-21 .

4.6 (closed) N-20 l

5.5 (open) E-29 5.6 (closed) E-30 l

6.5 (open) 1-13 6.6 (closed) 1-13 6.7 (open) 1-13 6.8 (closed) 1-14 7.2 (open) C-17 7.3 (open) C-17 8.1 (closed) C-46 s 8.2 (closed) N-19 8.3 (closed) C-46 8.4 (closed) C-46

' Action item initiated by EA before NRC review.

NRC requires the project to submit written responses to the observations that are open. The response will be submitted through nornal SQN Licensing process.

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4.0 SUP9tARY 4.1 General The DB&VP was a conprehensive C/A program that was implemented by IVA for the first time at Sequoyah unit 2. There were several concerns identifled as a result of the I A Team aeview that required corrective and preventive actions by the project. Thisresultedinmajor rework of activities, revisions, and issuance of new procedures and retraining of personnel.

These types of problems and corresponding corrective and preventive actions were neither unusual nor unexpected during a first of a kind program like the DB&VP.

There were a total of 357 action items prepared as a result of the EA Team review. At the conclusion of the April 15,1%7 date at which time the EA Team completed the evaluation of project action item responses the status of action items was as follows:

Nunter of action items 357 Nunter of action items closed 239 Nunter of open action items (C/A has Si been EA verified for Phase I and C/A has been agreed to for Phase ll with EA verification required)

Nunter of open action items (C/A has been agreed to, but require eitherprojectC/AorEAverification (7 of these require both Phase 1 of C/A - Resolved) 47 and Phase 11 C/A)

Nmter of open action items (project C/A has not been agreed to by EA - Unresolved) 20 Ofthe239closedactionitems,209requiredspecificcorrectiveand/orpreventiveproject actions that were verified by the EA Team. Them were 30 action items that required neither corrective nor preventive actions by the project based on the following reasons: (a) the finding was an information request which was adequately clarified, (b) the finding was based on the review of a draf t or interim document and was adequately captured in the issued document, (c) both EA and the DB&VP agreed that the finding was minor and did not require further actions, (d) the finding was outside the scope of the DB&VP but was indicated to be capturedinaprojectprogramoractivity,(e)theDB&VPfurnishedadditionalinformationor doctrnentation, which was verified by the EA Team, that adequately resolved the concern, and (f) the finding was found to be invalid.

There are 58 open action items that contain C/A that the EA Team agreed could be implemented postrestart (Phase 11). An observation (see observation EAl in section 5.0) has been prepared to provide a vehicle to track these corrective actions for EA Team verification. In addition, 20openactionitemsrequireagreementonC/AbetweentheprojectandtheEATeamand47 require project inplementation of C/A or EA verification of C/A. (See Table 4.1-l.) These action items require disposition in Phase I and are the subject of observations and CAQRs in Section 5.0.

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The problems addressed in the EA Team action items were, in some cases, generic and C/As reflected significant rework in the activity. For exanple, the design criteria activity required a major re-review before the results were acceptable. In other cases, the problems were extensive in a discipline, and innlementation of C/As included an extensive rework of the activity required within that discipline. For exanple, in the Electrical discipline, some ECN change docunent evaluations were required to be conpletely reevaluated by the projectbeforetheywereacceptablebyEA. In some instances the EA Team findings resulted in procedure revisions and/or issuance of program directives to correct or clarify a condition. Training of personnel was determined to be acceptable but, in a few cases, the EA Team findings resulted in the retraining of personnel with subsequent rework to correct a condition.

Problemswerealsoraisedwhichweredeterminedbyprojectinvestigationstobesingle

! occurrences and were appropriately corrected. in other cases, the extent of the problems was evaluated by the project and verified by EA to be random or isolated, in addition, the EA Team required the appropriate project disciplines to document the rationale that was used to bound the problems. EA verified the adequacy of this documentation and was satisfied that the EA identified problems were satisfactorily bounded.

in nest instances, problems identified were resolved and corrected or are in the process of being corrected. For these resolved problems, any similar conditions which existed elsewhere, which were found through project investigation were also corrected. Where appropriate, the D8&VP project also determined the cause and inplemented action to prevent recurrence of a condition. The DB&VP project was required to provide an evaluation of cause, extent, and corrective and preventive actions to adequately address the remaining unresolved problems. An analysis of findings for conmonality of cause was performed by the project at the conclusion of each review activity.

A detailed discussion of the concerns presented in the action items and the project action taken to correct identified concerns is presented in section 7.0 of this report. in addition, these action items were evaluated and trended in detail. The results of this trending analysis are presented in section 8.0.

An assessment of the causes which resulted in the concerns expressed in the EA Team action items was performed to provide additional understanding of problems in inplementing the DB&VP. As noted above, extensive reevaluation and rework were required in some portions of the DB&VP before the EA Team could agree that satisfactory products were obtained. Two of the most significant causes of these concerns were:

e Misunderstanding of the level of documentation of engineering judgment r.ecessary to conform to DNE Policy Memorandum PM06-04, Engineering Judgment.

e Misinterpretation of requirements for depth of engineering evaluations.

The nature of these causes indicates that project nanagement involvement at all levels continues to be necessary to ensure that appropriate doctrnentation is produced.

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TheEATeamfindingsresultedintheprojectissuing38CAQsoverandabovethosethatthe projectidentifiedindependently, in addition, the findings that have not been verified to closure have been evaluated by the EA Team against the CAQR criteria. If the condition met this criteria, a CAQR was prepared by EA. These findings have been converted to observations or CAQRs and are included in section 5.0 of this report. A total of 41 observatii>ns and 4 CAQRs were generated by the EA Team upon conclusion of this review.

The EA review plan utilized to select sanples for review was found to be adequate to bound DB&VP implementation problems. This was demonstrated by the results of the EA Team system review of the Containment Spray System (System 72) which did not detect any problem types that were different from those identified during other EA reviews. This is described in Section 8.0, where a conparison has been nude of the findings resulting from the system 72 review and the renuining reviews.

4.2 Review Results The following is a brief discussion of the review results including the types of EA concerns raised and project actions taken to correct / prevent the concerns for each review activity.

Details are presented in Section 7.0.

4.2.1 System Boundaries Determination The EA Team reviewed for adequacy the system boundary determination for those systems required to mitigate FSAR Chapter 15 events as defined in DNE calculation SQN-OSG7-048.

This review principally identified technical concerns related to a lack of documentation to support system boundary determination that all Chapter 15 events were considered. As a result of EA concerns, the project took appropriate action to enhance the documentation to support the boundary determinations. This action resulted in two revisions to the calculation. The EA Team concluded that the revised calculation was adequate.

4.2.2 Walkdowns The EA Team reviewed the project's walkdown activities. The review enconpassed the project's preparation of walkdown packages and documentation of walkdown results, in addition to these reviews, independent walkdowns were performed by the EA Team to compare EA's results with those obtained by the project.

The EA Team identified concerns which included:

e The original walkdown scope was not considered adequate to support the functional analysis evaluations of modifications to Electrical and ISC equipment and systems, e incorrect and inconsistent doctmentation of walkdown results, e Conflicting requirements in walkdown procedures SQEP-08 and SMI-0-317-}0 relating to required infornation to be reported in walkdown results.

e Boundary definition on the walkdown drawings conflicted with the system boundary definitions reported in the calculation SQN-0SG7-048.

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l To resolve these concerns the following actions were taken: (1) the DBaVP project developed a walkdown scope for verifying the adequacy of sensing lines. A sanple of safety-related sensing lines performing safety-related and pressure boundary retention functions were included in this expanded walkdown scope and (2) walkdown procedures were revised and the project re-reviewod walkdown package results to correct and verify the adequacy of documentation. This resulted in additional revisions to walkdown packages and system engineers requesting additional information missed during initial walkdowns which was obtained in supplemental walkdowns.

4.2.5 Convarlson of As-Desioned Drawinas Walkdown Results The EA Team reviewed the project's jus'tification for recorded dif ferences, for accuracy and ccrnpleteness, between the marked up control room as-designed drawings and the engineering as-designed drawings. There were no EA concerns identified as a result of this review.

The EA Team considered this activity acceptable with no additional action required.

4.2.4 Electrical Test Results Evituations The EA Team reviewed the electrical test evaluations results for procedural compliance and technical adequacy. Several concerns were raised with regards to this review. Some of these concerns included:

einadequatejustificationdocumentedtosupportconclusionsreportedintheOBaVP evaluation stenary, o Responsibilities for handling, reviewing, and accepting the test / retest results between the DBaVP and the plant System Engineering Sections were not defined.

These concerns were satisfactorily addressed by reviewing and revising, as appropriate, the evaluation sunmary sheets to include adequate justifications, in addition to preventing any confusion or inadvertent errors in the test / retest process, the project issued SQEP-57 which defines the level of approval required for test / retests and to address the conmunication responsibilities between the DBaVP and the plant System Engineering Section for test / retest considerations.

4.2.5 Change Document Evaluations The EA Team reviewed the project's ef fort in the assembling and reviewing of change documents. The change documents consist of ECNs, TACFs, SCRs/NCRs, l-DCRs, and ONP-Generated Drawing Olscrepancies. The object of EA review was to ensure correct categorization of change docunents, and to ensure that systems within the scope of calculation SQN-0SG7-048 were correctly identified on the change document identification forms, in addition, the project's evaluation of ECNs was reviewed by the EA Team for conpliance with SQEP-12 and for technical adequacy and conpleteness. This was acconplished eitherbyreviewingtheproject'sresultsorbyperformingseparatetechnicalevaluations of ECNs and conparing these results with those from the project's checklist.

To supplement the ECN reviews, the EA Team performed a technical and progranmitic audit of the DNE calculation program which establishes the analyses for the base design of the plant and nudifications to the base design which ties this latter aspect of the calculation program to the DB&VP. A number of deficiencies were identified with calculations which are I

in the process of being corrected by the technical disciplines within DNE. The details of the EA findings are identified in EA Audit 87-09(T).

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( _ _ _____ ... . -

h

{.

The EA Team reviewed change documents to determine the adequacy of modification constructibility of ECN and modification workplan packages, associated doc uents and drawings, and redlined CRADs. The review covered the process from initiation, approval, i and issue of an ECN package by DIlE, through the inplementation of the modification with the Olet workplan package,-to the coupleted redlined CRAOS.

l .

Over 63 percent of the EA findings concerned " Design Review Deficiencies," most of which occurred in this activity. The EA Team review of ECNs resulted in over 26 percent of the total EA action items. ,.

EA concerns and project actions taken include:

i 3 e Concerns regarding lack of documentation and inconsistent documentation of engineering

.. decisions on the ECN checksheets which resulted in the 084VP subsequently issuing

1. detailed technical guidance to clarify the level and extent of doc eentation required for J these evaluations. Inaddition,theD84VPprojectrequiredaseparatesunneryevaluation i I

sheet for each ECN to further clarify the results and conclusions of the ECN evaluations. .

i e Concerns relating to incomplete and incorrect ECN checksheets in the Electrical

j. discipline, which resulted in the D84VP Electrical discipline inplementing C/A and i preventive action programs that included retraining personnel and reevaluating all ECNs.

j Fourteen PIRs and 150 punchlist items were issued as a result of the reevaluations.

u

e Concerns regarding the lack of technical review of ECNs for civil scope which resulted in 1 theD84VPprojectorganizingacivilengineeringreviewgroup. This group developed a i civil checksheet, reviewed all appropriate ECNs, and was directly involved with j interdiscipline reviews of SYSTERs to ensure that system engineers properly utilized the i civil results.

1

These project actions were verified as satisfactory by the EA Team.

4.2.6 Desian Criteria The EA Team reviewed (1) the process for generating the comnitments and requirements (C/R) i data base used as input for the development of design criteria and (2) the D84VP restart j designcriteria. The EA Team identified many concerns relating to inappropriate i requirementsbeingprovidedbytheprojectforaccomplishingthework(i.e.,projectissued I instructions which were not considered mandatory by D84VP personnel), inconplete reviews of i source documents by the project resulting in the elimination of C/Rs from the data base, and i incomplete / inadequate requirements in the design criteria.

J l The project's evaluation of these concerns resulted in individual actions to correct the i- identified problems and in addition, a conprehensive corrective action program was j established that the EA Team considered adequate to resolve the generic problems associated I with these EA concerns on this activity. The C/A program included consideration for j reviewing documents for inclusion in the C/R data base, reviewing source documents that were l originally not considered for incorporation into the C/R data base, and a re-review of 4

designcriteria, in addition to the project addressing the individual EA Team concerns and inplementing this C/A program, the project procedures were revised to add requirements which were previously issued as project instructions in order to mandate certain actions to be 1 performed by the D64VP personnel.

t i

! 4-s 1

Theseprojectactionsresultedinthefollowing: Additional C/Rs were entered into the data base; categorization infornetion of C/Rs was revised to include a more conglete identification of the C/R source in the data base to allow for more accurate retrieval; and revisions / DIMS to the design criteria were issued.

4.2.7 System Evaluations includina C/A The EA Team reviewed the SYSTERs to verify that they were prepared in accordance with SQEP-16 and the conclusions obtained in the SYSTERs were technically adequate.

The results of each system evaluation are documented in a SYSTER. However,SQEP-45 established a project punchlist to track 00&VP open items and provide a documentation basis forprerestartC/Aorjustificationforapostrestartdetermination. Therefore, this activity also included a review of the project's punchlist items for adequacy of the defined C/A. TheEATeamreviewedtheproject'srestartdecisionagainsttheSQNrestartcriteria.

EA Team also reviewed the punchlist items to verify that they were correctly categorized against the CAQ (riteria.

EA concerns and project actions taken in this review activity included:

e EA identified deficiencies in the governing procedures SQEP-16 and SQEP-45. SQEP-16 did not contain provisions for revision of SYSTERs. Inresponse,theprojectissuedR5of SQEP-16 (and revised related procedures) to allow for SYSTERs to be revised for changes, additions, and deletions in addenda to the original SYSTERs.

e SQEP-16 did not define " exception" or " unacceptable item." As a result, exceptions and unacceptable items were not properly or consistently incorporated in SYSTERs. In response,theprojectstatedthatresolutionstoexceptionswouldberesolvedonthe punchlist. it.e project issued a directive to address this concern. EA recognized that SYSTERs were an intermediate product in the overall process and were used principally for identification of those items requiring further attention. The technical decisionmaking associatedwithestablishingandperformingC/Aanddeterminingandjustifyingrestart categorization for each item was acknowledged by EA to be associated with the punchlist.

e EA identified concerns regarding inconsistencies between the decisions reported in the SYSTERs and those on the punchlist. TheDB&VPprojectissuedadirectiverequiring system engineers to reconcile final restart decisions and defined C/As from the punchlist with those reported in the SYSTERs.

e EA identified concerns regarding the lack of system engineer concurrence or decisions made by the line organization on restart and C/As for punchlist items. This was an initial requirement by the DB&VP project, but was subsequently changed. As a result of the EA concerns the project revised the procedure to reinstate this requirement and correct any discrepancies during the reconciliation process, e EA identified concerns regarding the DB&VP project's incorrect technical decisions made for restart on ECNs and other related project activities, theprojectrespondedby reevaluating the bases for their decisions and in some cases changed from postrestart to prerestart action, e EAidentifiedaconcernregardingthe084VPproject'sevaluationsofwhichpunchlist items should be designated as CAQs. Theprojecthasidentifiedcorrectiveactionto resolve this concern, but it was not yet conplete or EA verified. A project assessment of preventive action is still pending.

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Subsequent to these procedural revisions and issuance of project directives to clarify the required content of the SYSTERs, the SYSTERs provided adequate rationale and documentation to support their technical justifications and conclusions. However, a good portion of the evaluation necessary to conclusively determine and reconcile system restart status was deferred in the system evaluations to the punchlist.

The disposition of punchlist items was insufficiently conplete to reflect the adequacy of that effort.

4.2.8 Transitional Chance Control i

The EA Tear.: reviewed the transitional design change control program to verify that the program was procedurally controlled, adequately implemented, and no anticipated progranmatic difficulties were encountered. The EA Team also reviewed this program to determine if the interfaces had been adequately established between DNE, Site QA, DNC, and the Plant Staff and if previously identified design change control weaknesses had been corrected.

SQEP-15 was developed and issued to conply with a SQN conmitment in the Nuclear Performance Plan Volume 2 that a transitional design change control system be implemented before restart to improve the existing design control process and provide an effective transition to the permanent system.

EA identified the following concerns:

e SQEP-l) contains a waiver clause which allows the SQN Project Engineer to grant waivers to this transitional design change control process. This waiver allows modification design work to be performed under SQEP-Al-II, the old design change control process.

Most recent ECNs were processed under this waiver.

e The 8 ECNs processed through the new transitional design change control process involved very minor modifications and few required any drawing changes. Also very little field work had been acconplished at the time of the review and none of the 8 ECNs were closed.

SQEP-13 is technically adequate and appears to be workable. However, because of the limited use of the new process and the nature and status of these ECNs, the EA Team was unable to make a conclusive assessment of the inplementation adequacy of the transitional design change control program at this time. This area will be followed up by EA in order to ensure SQEP-13 is fully inplemented by the project.

4.2.9 DB&VP Phase 1 Report (PreIiminary)

The EA Team reviewed the 084VP project Phase i Report to assess whether it accurately portrayed the DB&VP and its objectives, accomplishments, and conclusions.

EA identified the following concerns:

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e Cutof f dates for DB&VP evaluations for ECNs, FCRs, and open CAQs were not discussed.

e The report incorrectly stated the inplementation status of the transitional design change control program, o The report stated that NCRs/SCRs were included in the program scope, but did not explain that some were excluded from the DB&VP and did not provide the rationale for their exclusion.

e Trending for root cause analysis in the report was based on sorting punchlist items to the disciplines by originator, not by the RAP. This led to a nunter of CEB and EEB items included in NEB's statistics, thus making the NEB portion of the root cause analysis misleading, in response, the project conmitted to revising the report to resolve these concerns. The report revision was not yet available for EA verification.

4.5 Conclusions Based on the results of the EA Team reviews and the C/As taken by the DB&VP project to resolve the EA concerns (details presented in sections 6.0 and 7.0 of this report), the following general conclusions were reached:

e The implementation of the DB&VP procedures was generally conplete and adequate to meet the cojectives of the program and the activities conducted by the DB&VP project were generally correct, adequate, and in accordance with program procedures.

e The DB&VP project denonstrated the functional and technical adequacy of modifications by providingand/oridentifyingsupportingdocumentationandjustificationstoestablishthat modificationscomplywiththereestablishedrestartdesignbasisrequirements,subjectto adequate implementation of appropriate C/A and EA verification for the identified observations and CAQRs.

The above conclusions were based on the following:

e The boundaries of those systems required to mitigate Chapter 15 events were accurately defined in the boundary calculation. ,

e The restart design basis document (RDGD) was adequately re-established and incorporated the licensing and technical requirements comnitted for SQN plant, unit 2. EA verification of acceptable inplementation of project C/A is required.

e The baseline configuration of the applicable safety systems of SQN unit 2 has been established with verification of acceptable inplementation of project C/A. This was demonstrated by the adequate implementation of the walkdown process and completeness of the drawing comparison process, which defined the differences between the as-designed configurations and walkdown results.

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e Electrical and ISO modifications have been tested to demonstrate functional adequacy and compliance with the requirements of tM RDBD, with EA verification required to confirm that acceptable project C/A has been iglemented.

e Engineering judgments have been substantiated and documented based on the adequacy of the change document evaluation and the system evaluation processes with unresolved observationsrequiringprojectactionwithEAverificationofacceptableimplementation of C/As.

e Engineering analyses to support the modifications have been defined based on the l

coglete identification of calculations in the ECN evaluation and system evaluation processes, with EA verification of adequate Iglementation of C/As, In addition, the implementation of C/A and EA verification of the findings identified in the EA Team audit of the DNE calculation program, establishes the technical adequacy of calculations to support the nodifications.

The EA Team reviewed the restart decisions and C/As identified for the DB&VP punchlist items.

Several concerns were identified and are being addressed by the project, the C/A process had not progressed sufficiently for EA to con 1plete its review. Because of the unresolved status of the EA concerns and the additional reviews required by EA, conclusions on the adequacy of this process could not be determined.

The EA Team reviewed the implementation of the transitional change control program. The restricted use of the new design control process limited the FA Team's review of change documents handled by this process. Concerns were raised by the EA Team from this limited reviewandarebeingaddressedbytheproject. The EA Team could not derive a conclusion on the adequacy of the implementation of the transitional change control process until further use is made by the project and additional reviews performed by the EA Team.

There are no apparent programmatic weaknesses remaining to be resolved as a result of the EATeamfindingsandprojectactiontoaddressthesefindings. Only a few concerns remain to be resolved with the project to address potential weaknesses in the Iglementation of some program elements. Except for these unresolved concerns, the extent of deficiencies has been determined, the deficiencies have been corrected or are in the process of being corrected and appropriate preventive action has been identified. However, verification of a nunter of project actions by the EA Team remains.

Based upon EA verification of root cause determination by the project and adequate C/A implementation of the observations noted in this report including C/A on the DB&VP findings and further iglementation of the transitional design control system, the prerestart phase of the DB&VP has been fully and effectively implemented.

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TABLE 4.1-1 OPEN EA ACTION ITEMS THAT REQUIRE DISPOSITION DURING PHASE I Resolved- Unresolved C-05 l- 18 E-10 C-10 1-54 E-25

• C-15 E-26 C-21 'M-30 E-50 C-27 M-55 E-74 C-28 M-45 E-90 C-57 'M-46 E-91 C-40 C-41 N-16 l-55 C-44 N-Si l-56 C-47 N-55 l-57 C-55 N-56 1-59 C-54 N-58 l-60 C-55 C-56 Q-07 M-47

'C-57 Q-09 M-48

', Q-10 M-51 E-14 M-52

'E-51

• E-SI Q-il

'E-55 0-12 E-55 0-15 E-57 E-64 T-01 E-45 E-69 E-72 E-75 E-77 E-80 E-85 E-85 E-87 E-88

'These action items require both Phase I and Phase il corrective action.

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5.0 OBSERVATIONS AND CAQRs The EA Oversight review developed 357 action items. Of these items 239 were closed as of April 15, 1987. Fif ty-eight open action items will require project implementation of C/A and EA verification as part of Phase 11. Sixty-seven open action items (47 resolved and 20 unresolved) require additional project or EA action as part of Phase 1,_ including 7 with both Phase I and Phase ll actions. The 20 unresolved open action items have been evaluated by the EA Team against the CAQ criteria. CAQRs were prepared for 4 unresolved action items which met the criteria.

The remaining 114 open action items were grouped where desirable and converted into 41 observations for continued EA follow-up through closure. These observations and the 4 CAQRs are presented in this section. The observations are grouped by discipline and further categorized as follows:

e Unresolved--Observations resulting from action items generated during the review for which theprojecthadnotmadearesponse,ortheresponsewasjudgednottobeadequateby Engineering Assurance.

e Resolved--Observations resulting from action items generated during the review for which comr.itted project actions have been agreed to by the EA Team but have not boon completed and/or have not been verified. .

To meet the Phase I objectives of the D84VP program, the project is required to conglete the corrective and preventive actions as previously identified to EA on resolved action items. In addition,theprojectmustresolvewithEAtheunresolvedactionitemsincludingthefourCAQs.

This resolution must include an assessment of cause, extent, and significance with a schedule for conpletion of all corrective actions.

A list of the four CAQs written follows the descriptions of the observations.

Descriptions of Observations ObservationNo.Cl(Resolved]

Action item C-21 identified an ECN that was initially thought to be outside the SW810 boundary (unit 1) as actually falling within the boundary (unit 2). The project responded with the issuance of PIRSQlMEB0659 (B44 860910 006), but the C/A of this PIR has not been established.

The Civil discipline of EA must verify that the C/A results in the adequate capture of all ECNs inpacting the unit 2 084VP for incorporation into the appropriate System Evaluations, even though applicable ECNs may be designated unit I only.

Observation No. C2 [ Resolved]

Action item C-10 identified that the project needs a criteria invoking the requirements of Regulatory Guide 1.29 for the protection of Category I components from failure of non-category I conponents. The project resolved this action item by the generation of PlRSQNCEB0670 addressing the above deficiency; how3ver, C/A has not been established. The EA Civil discipline needs to verify the adequacy of C/A upon disposition of this PIR.

Observation No. C3 [ Resolved]

Action items C-15 and C-27 identified that the rigorous pipe stress analysis criteria did not adequately capture applicable restart C/Rs included in the project data base. These deficiencies 5-1

AL, havebeenidentifiedonPIRsSQNCEB8670andSQNCEB8669,andtheprojecthascommittedtorevising the rigorous pipe stress criteria. These action items are resolved by PIR issue, but the C/A must be verified to ensure adequacy of the RD80.

Observation No. C4 (Resolved].

Action item C-56 cited that a sufficient nuntier of significant punchlist items have not been completed to conclude that the C/A for punchlist dispositions is adequate, and action item C-41 stated that partially inplemented ECNs have not been evaluated by the 088vP civils using current field status. These items have been resolved based on adequate inclusion in the D88VP punchlist. However, the adequacy of punchlist dispositions and incorporation into applicable SYSTERS must be verified by EA due to significant inpact upon system evaluation conclusions.

Observation No. CS (Resolved]

Action items C-0) and C-44 were written to address the technical adequacy of change documents.

The technical adequacy of the civil 084VP effort was to have been established by an independent CEB calculation verification program. Technical reviews of change doctments revealed general findings of drawing discrepancies and incorrect FCR evaluations, which were not clearly addressed in the calculation program. These concerns are resolved but cannot be closed until EA verifles the adequate incorporation of these issues into the calculation program, and adequate conpletion of the program.

Observation No. C6 (Resolved]

Action items C-28, C-57, C-40, C-47, C-55, C-54, C-55, and C-57 were written citing several areas of deficiency in the civil D88VP program. These action items are resolved and EA has accepted the C/A, but the C/A inplementation requires EA verification prior to closure.

Observation No. El (Resolved]

The EA Electrical's verification walkdown of portions of Systems 82, VP, and AP resulted in two action items (E-87 and E-88) which were resolved but require verification of project C/A conpletion. The Electrical discipline of the EA team must verify the adequacy of the conpleted C/As as noted below:

1. Reference section 7.2.2.1-6., item c (Action item E-87)

a. Verify that the SYSTER 82 addendum addresses the walkdown drawing discrepancies identified for CRAD 45N727 R L and punchlist item 9132.

b. Verify satisfactory conpletion of C/A for punchlist item 9132 to correct drawing 45N727.

2. Reference sections 7.2.2.1-5., and -6., items d and e; and 7.7.2.1-3., item a, and (Action Item E-88)

• Verify the adequacy of the project's determination of the extent, significance, C/A, and action to prevent recurrence to address the errors involving the recording of incorrect walkdowe data on the AP supplemental walkdown and the missed identification of breaker setting discrepancies.

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b. Verify that additional breaker setting discrepancies have been identified, punchlisted, and 1 properly corrected.

e l

c. Verify that these breaker setting discrepancies have been properly addressed in the AP SYSTER addend e.

p ,

Observation llo. E2 [ Resolved]

lieference section 7.4 l.1-15 (Action item E-57)-The EA Electrical *s review of electrical ,

testing for ECN 2945 and Proop test TVA 22 (unit 2) resulted in an action item (E-57) which led i to the generation of SCR$QNEEH8729.

The Electrical discipline of the EA must verify the adequacy of the cogleted C/A for

,- SCRSQllEEHB729.

r Olnervation Ilo. E3 [ Resolved]

i-EA Electrical's review of De&VP change documents resulted in several action items (E-51, E-53, i E-55, E 49 E-64, E-65, E-72, and E-75). These action items were satisfactorily resolved.

However, the project's C/A was not verified to have adequately corrected the identified -

deficiencies. The Electrical discipline of the EA Team must verify that the project adequately completes the following C/As:

1. Reference section 7.5.2.1-2., items n and b (Action items E-51 and E-53)-The design review checklist for EClis L6712 and L6676 did not adequately address cable thermal requirements.

Verificationoftheproject'sC/AforSCRSQNEE88793isrequired.

2. Reference section 7.5.2.1-2., item e (Action item E-55)--Proper sizing of design criteria j motor overload heaters for EC81 2945 was not checked. Verificationoftheproject'sC/Ato  ;

properly size the direct current overload heaters is required.

4 >

i 3. Reference section 7.5.2.1-2., item I (Action item E-69)--Minor drawing discrepancies were noted by the EA Electrical discipline during the review of ECN L6573. Verification of the project'sC/Atorevisedrawingsisrequired.

, 4. Reference section 7.5.2.1-2., item j (Action item E-64)--Voltage range discrepency involving  !

the ratings of voltage relays for ECN L5449 was not resolved. Verificationoftheproject's

! C/A for PIR$4 NEE 986144 is required, i

5. Reference section 7.5.2.1-2., item h (Action items E-65 and E-72)-ECN L5363 involved adding i load shedding relay contacts in series with the 6.9kV emergency feeder breaker close circult so that the loads will be shed before the emergency feeder breaker closes. The intent of

] this ECN was not met by the final design that was iglemented by the ECN and did not i

consider the potential occurrence of load brooker failures. Verification of the C/A on .

SCRSQNEE806206 is required.

j 6. lieference section 7.5.2.1-2., item q (Action item E-75)-The design checklist question 8.3.C i (SQEP-12) concerning failure modes does not adequately document that a cogrehensive failure analysis has been done. A PIR$QNEE006171 was written to address the problem of imposed voltage. The significance of the problem of Igosed voltages cannot be determined until the

] project satisfactorily provides a resolution of the imposed voltages problem in the PIR.

i i

I 5-3  :

I

l Observation No. E4 [ Unresolved]

Reference section 7.5.2.1 (Action item E-10)--The Electrical discipline of the EA Team raised a concern in action item E-10 involving the scope of procedure SQEP-il, which did not address technical evaluations of potential generic condition evaluations (PGCEs) in the D84VP. The general concern related to the possibility that PGCEs (typically other plant's CAQs that were determined to not exist at SQN) ney not have received adequate reviews by engineers to ensure the documentation coupleteness and technical adequacy of the PGCE conclusions. Theproject responded that the PGCE evaluations were not considered to be part of the modification process and were not intended to be in the scope of SQEP-il. However, no other review program was identified that assessed the adequacy of the PGCE evaluations. The EA Team will review a sangle of past PGCEs to verify the technical acceptability of the dispositioning of these documents.

f Observation No. E5 [ Resolved]

J. F. Cox's memo to SQEP files dated Decentier 3,1986 (B25 86120) 019) contains ll items addressing many team items concerning the C/R data base and appropriate capture of C/Rs in design criteria. Due to the many action items involved (35 action items), E-14 was chosen to be used as a tracking mechanism to consolidate all items relative to the above memo to ensure that all were appropriately addressed. Each EA discipline was still responsible for responding to theiractionitemsandforverificationofprojectC/A.

Of the ll Items contained in the memo, 5 still require EA Team verification. Two memo items required verification under this observation, and the 3 remaining memo items are listed below to conglete the tracking function originally intended for action item E-14.

1. Reference section 7.6.2.1 (Action item E-14)-40emo items to be verified under this observation by Electrical discipline of the EA Team are items 4 and I as noted below:

a. Item 4 concerns C/Rs not included in the original system sorts. EEB identified one C/R l (SQNEE8P8N1228) which must be incorporated into the RPS design criteria, SQN-DC-V-27.9.

EA Electrical must verify the inclusion of the C/R into the design criteria.

b. Item I concerned C/Rs requiring revision or deconmitment with NRC. EEB has identified 15 C/Rs (memo 825 870325 106) which require FSAR text revisions. EA Electrical must verify these revisions.

The following three memo items will be verified under their individual discipline observations:

1. Item 7 concerns the generic problem of the requirement for referencing other criteria docwents within the design criterla. Action items C-15 and C-28 require verification resulting in EA Civil discipline observations C) and C6.

2. Itan 5 concerns the requirement for design criteria preparers to clearly indicate whether ilsts of C/Rs within design criteria contain design requirements or are considered to be for background information. Action item E-31 requires verification, resulting in EA Electrical discipline observation E8.

3. Item ) concerned C/R data sheet system Identification, in particular, the Identification of system nisters greater than 99. Action item M-46 requires verification resulting in EA Mechanical observation M).

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Observation No. E6 (Unresovled]

fhe review of design criteria SQN-DC-V-II.8 R0, "DG and Auxiliary Systems," noted that an excessive number of electrical design requirements were not captured in this mechanical criteria. This resulted in EA action item E-25, which was unresolved and requires additional infornation on C/A.

The Electrical discipline of the EA Team must verify satisfactory establishment of C/As and subsequent conpletions of those C/As for action item E-25 as noted below: ,

l. Reference section 7.6.2.1-2 (E-25)--Additional information must be provided to resolve the generic aspects of an apparent lack of design criteria interface review. Specifically provide:

a. the CAQR nurber written by project for correcting the identified problems with criteria SQN-DC-V-10.5 RI,

b. schedule to complete additional ECN reviews that are required because of the criteria revisions. The D88VP must provide the results of this review to the EA Team, and

c. establish C/As for SCRSQNEE88794 and the CAQR in (a) above.

Observation No. E7 (Unresolved)

Reference Section 7.6.2.1-3, (Action item E-26)--The review of design criteria SQN-DC-V-II.6 R3 "120V Vital Power instrument Power System," resulted in EA action item E-26 which was unresolved andrequiresaprojectresponseonthegenericaspectsofomittingtestingrequirementsfrom design criteria. The Electrical discipline of the EA Team must verify satisfactory establishment of C/A and subsequent conpletions of the C/A for addressing the missing testing requirements from design criteria.

ObservationNo.E8(Resolved)

The review of design criteria SQN-DC-V-27.5 (preliminary 7/18/86), " Containment Spray System,"

resulted in action item E-)I which was resolved but requires verification of completion of projectaction.

The Electrical discipline of the EA Team must verify stafisactory completion of C/A as follows:

Reference section 7.6.2.1-5 (Action item E-31)--The inclusion of reference to the following items in SQN-DC-V-27.5:

a. The 125V DC VP system criteria, and

b. The 480V AC power requirement for the CSS valve operators.

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Observation No. E9 [ Unresolved]

Reference section 7.6.2.1 (Action item E-74)-In a discussion with the NRC, a concern was cited that IE cables for the RPS which were routed through the turbine building (nonseismic structure) were not being labeled IE, Generating Station Protective System (GSPS). A verification check of the RPS by EA Electrical found several discrepancies involving missing and mislabeled cable ID tags. This resulted in EA action item E-74. Theprojectverballyagreedtocorrectthesetags and issue WRs to perform the work. However, the project must comnit to this or other appropriate C/A in writing and proceed to implement any agreement upon C/A. The Electrical discipline of the EA Team must review the formal C/A for this problem when proposed by the project and must verify its satisfactory completion.

Observation No. E10 (Resolved]

Reference section 7.7.2.1-4., item c (Action item E-77)-The review of project directive -

08VP-D-86-019Rl,"SCR/NCRReviewsforSYSTERjustificationofopenCAQstobeincludedwith 084VP," resulted in action item E-77 which was resolved but requires verification of project's C/A. This directive eliminated the open CAQs from the DB&VP review scope. Theproject responded that the open SCRs/NCRs would be evaluated by non-084VP personnel in accordance with NEP-9.l. The EA Team must review and verify the adequacy of the process for these open SCRs/NCRs. ,

(

Observation No. Ell [ Resolved]

Reference section 7.7.2.1-l., item a (Action item E-80)--The EA Electrical's review of the VP SYSTER resulted in an action item (E-80) which identified a concern that change documents were omitted from the applicable SYSTER evaluations. Inresponse,theprojectproposedtosurveythe SEs to determine the extent, significance, and action to prevent recurrence. In addition, the specific change documents identified as omitted from the SYSTERs would be included in the SYSTER addenduns. The Electrical discipline of the EA Team must verify the adequacy of the following projectC/A:

1. Verify that the results of the survey of the SEs is conplete and adequately addresses the extent, significance, and action to present recurrence of the concern.

2. Verify that the omitted change documents have been included in the SYSTER 82 addendum.

ObservationNo,El2(Resolved]

Reference Section 7.7.2.1-l., items d, f, -2.b, and 3.b (Action items E-8) and E-85)-A review of the VP SYSTER punchlist items resulted in the issue of two EA action items, E-8) and E-85, which were resolved but require verification of conpletion of project action. The Electrical discipline of the EA Team must verify satisfactory conpletion of C/A as follows:

1. Verify resolution of conflicts between punchlist items in the SYSTER and SQEP-45 punchlist status in regard to restart decision and C/A.

2. Verify that omitted SQEP-45 punchlist items have been included in the applicable SYSTER addenduns.

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c . _ _

3) r f

i I

Observation No. El3 [ Unresolved]

Reference section 7.7.2.1.5., item c (Action item E-90) -The FA Flectrical's review of the AP SYSTER resulted in a concern that uniglemented ECNs L5668 and 2656 were incorrectly evaluated as not required for restart. This incorrect restart decision also raised a general concern that appropriate restart criteria, especially as it pertains to the tech spec conditions, were not lused in making the restart decisions for unimplemented and partially irnplemented ECNs. In addition, the applicable as-constructed drawings for the ECNs incorrectly indicated the uninglemented'ECNs as field installed.

The following actions are required for resolution:

I. The project must provide evidence that proper restart criteria was used in making the restart decisions of un)g lemented and partially implemented ECNs and must address the extent, C/A, significar.ce and action to prevent recurrence.

, 2. The EA Electrical discipline must verify the adequacy of the following specific C/A:

a. The AP addendum addresses ECNs L5668 and 26% for inplementation prior to restart,

b. The C/A of CAQR SQP870186 and punchlist item 9497 has been aclequately conpleted to address the deficiencies of ECN 26% and the as-constructed drawings.

Observation No. El4 [ Unresolved]

i.

Reference section 7.7.2.1-4., item a (Action item E-91)-In a review of the C/A for punchlist item 6399 of System 249 (VP), it was noted that the punchlist item did not have a restart categorization assigned and did not have adequate C/A scope defined. As a result, the conpleted C/A was found to be inadequate. The scope of the C/A was inadequate in that only the drawing deviation %001598 was noted. Nothing was stated about the possibility that the installed fuses might be incorrect, even though the shif t walkdown stenary sheet item VP-l-31 noted this possibility. ThisactionitemwasunresolvedandrequiresaC/Asubmittalfromtheproject.

The Electrical discipline of the EA Team nost verify satisfactory establishment of C/A and

,g subsequent completion of that C/A as noted below:

l. Project's reevaluation of C/A for this punchlist item.

2. Project's actions in the process of SE concurrence with the restart /postrestart categorizations and C/A definition for punchlist items to ensure that all possible aspects of C/A are considered.

Observation No. Il [ Resolved]

Tne review of SYSTER 81, Primary Water System, resulted in two action items (1-48 and I-54) which

's were resolved. However, evidence of completed C/A was not provided by the project.

t 5-7

. . - - - - _ _ ~ - - . . _ .-. _ - . .. - . - - - - - - - - - _ .

The14CdisciplineoftheEATeammustverifythattheprojectsatisfictorilycmpletesthe following C/A:

1. 1-48-The ER/SD included in Addendum I to SYSTER 81:

a. should contain either a reference to flow diagram 47W819-1 or a marked-up copy of it as the ER/SD.

b. clearly indicate that ECNs L5457 and L65% affect the accessories to control valve 2-FCV-81-12.

2. 1-54-The system closeout statement for SYSTER 81 required by ;>rogram directive 00VP-0-87-002 is cogleted to determine that proper restart categorization and final C/A of punchlist items affecting System 81 are accurate and adequate. Any changes in restart categoritationsincetheSYSTERwasissuedarefullyjustifiedintheclosurestatement.

Observation No. I2 (Unresolved]

The review of punchlist items pertaining to Systems 81 and 3A resulted in action items I-59 and .

1-60. The project did not respond to these concerns.

The l&C discipline of the EA Team must review and concur with the project's responses and verify that C/A, if any, is iglemented satisfactorily.

Action item I-59 concerned the closure of punchlist item 4613 without referencing documentation that the item had been satisfied. The item concerned the qualification of IE cable. The document referenced on the punchlist closure fort.1 concerned a CE8 SCR engineering report. This is an inappropriate doctsnent for closure of the punchlist item.

Action iten 1-60 concerned punchlist item 3588, which was closed based on WCAP-Il239 providing sufficient documentation of accuracy requirements for steam generator level transmitters LT-3-55, -93, -94, and -Il0. However, 3-level transmitters (LT-3-55, -93, and -110) have been replaced under ECN L5995. No documentation was referenced to verify ihat the accuracy of the three new transmitters met the accuracy required by WCAP-Il239.

Observation No. 13 [ Unresolved)

The review of SYSTER 72 resulted in two action items (1-55 and 1-57). The review of SYSTER 68 resulted in action item I-56. The project did not respond to these concerns.

Thel &CdisciplineoftheEATeammustreviewandconcurwiththeproject'sresponseandverify that the C/A, if any, is implemented satisfactorily.

Action item I-55 concerned modification of existing power supplies to match the requirements of transmitters replaced under ECN LS884. The modification was performed under an FCN, but the sunnery of ECN L5884 in SYSTER 72 does not identify the FCN, nor does it address the power supply modification.

Action item I-56 concerned a modification to control switch HS-68-341A performed under ECN L5591. A diode was used in the modification. However, the sunmary of ECN L5591 included in SYSTER 60 does not address the qualification of the added diode.

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i x

Action item I-57 concerned insufficient justification to inplement ECN L6674 postrestart. The ECN authorized the replacement of annuber flow elements FE-72 11 4nd -34 when and if they become inaccurate. The sunmery of ECN L6674 included in SYSTER 72 states that.one unit I annubar has been replaced. Based on this premise, the justification to inplement ECN L6674 postrestart is not adequate.

Observation No. MI [ Unresolved]

Actinn item M-Si identifies a concern related to the adequacy of the informstlon which was included in the auxiliary feedwater system DIM-SQN-DC-V-13.9.8.5 for valve stroke times.

The extent of this concern has not been addressed. A follow-up review will be performed to verify that the extent of the concern has been adequately investigated and acceptable C/A is assigned.

Observation No. M2 [ Resolved]

During review of the draf t containment spray system, several concerns were identified as discussed in action item M-33. Those remaining to be conpleted and verified by EA include:

1. In many cases C/A stsunaries for exceptions and unacceptable items provided in the SYSTERs did not state whether the C/A needed to be conpleted before or af ter restart as required by SQEP-16. Aprogramobjectivewasthatthepre/postrestartdeterminationforC/Awastobe made within the context of the various issues (open and closed) for that system as brought together by the SE in the SYSTERs. Project connitted to issuing instructions which would ensure a thorough " buy in" by the SE a x! discipline evaluation supervisor on C/A categorization and require a closure statement by SE's providing concurrence of C/A definition and categorization for items which affect their system.

2. An SCR referenced was found to involve the incorrect use of cable lengths in certain electrical calculations. Project conmitted to issue an EEB policy memorandum on how cable

!engths are to be used in electrical calculations, and to revise the affected electrical calculations.

Observation No. M5 [ Resolved]

The EA Mechanical review of the project's C/Rs and design criteria preparation resulted in three items which require C/A followed by EA verification.

I. Action item M-30 concerns an interface conflict between design criteria. The residual heat removal & sign criteria SQN-DC-V-27.6 R0 does not provide miscellaneous cooling water interface requirements for the RHR pump. Similar other support system interfaces may also not be adequately covered. Projecthasstatedthat,byissueofPlRSQNCEB0672,theywill review design criteria for this concern.

2. Action item M-45 concerns the fact that although the CCS design criteria, SQN-DC-13.9.9, describes the surge tank baffle as providing safeguards train separation, no evidence could be found for ASME XI pressure boundary tests having been performed on the baffle. Project has conmitted to prepare a test procedure and perform a prerestart leakage test and periodic leak tests to verify pressure boundary integrity, h

5-9

. -.,,,.y,. ,,m--.,---

3. Action item M-46 concerns the fact that C/R data sheets applicable to systems nuntered higher than 99 were not made available to the design criterla preparers. The project revised this concern and found six design criteria that were affected. in accordance with project memo (845 870227 257), DIMS will be issued for these design criteria.

A follow-up review will be performed by EA af ter conpletion of the above project actions.

Observation No. M4 [ Unresolved)

Action item M-52 identified a concern that in some cases punchlist items have been inplemented and closed before the C/A was assigned on the initiating PIR (CAQ). That was the case for PIRSQNEEB86174 and punchlist item 5931.

The C/A for this concern as assigned by the project was to complete the closure process for the PIR and issue a directive and/or procedure revision to ensure that CAQs listed in the punchlist have been properly handled per NEP-9.1 prior to closure on the punchlist (SQEP-45).

This C/A is acceptable but is not considered to be conplete. The review for the extent of the concern focused on one discipline only and was not felt to be adequate in extent.

Observation No. NI [ Resolved]

In a follow-up to action itan N-16, a concern was directed to the project about the correct determination of the actual inplementation status for all FCNs in the scope of the DB&VP. The project responded to this concern by requesting SQN Modifications to supply verified inglementation statuses and completion dates for those FCNs listed in the memo (B25 870220 035).

The Nuclear discipline of the EA Team must verify that the project satisfactorily conpletes the following C/A:

1. Determination of actual icplementation status of all FCNs (by supplemental walkdowns if necessary),

2. Distribution of the actual implementation status to each system engineer,

3. Evaluation of additional FCNs and previously evaluated FCNs with a revised status, and

4. Incorporation of necessary changes into SYSTER addenda.

Observation No. N2 [ Resolved]

Program directive DBVP-D-86-005 eliminated FCRs approved by DNE af ter Septenter 29, 1986, from evaluation within the DB&VP. The concern was directed to the project in action item N-56 that these changes, some of which were field complete, would not be evaluated in conjunction with the other change documents by the system engineer and documented in the SYSTER. Theprojectrespondedby stating that these open FCRs were being handled outside the DB&VP under the transitional design change control process governed by SQEP-13. A related concern developed during resolution was that theprojectnucleardisciplineevaluationsupervisorinterpretedthedirectivetoallowthe elimination of FCRs from the DB&VP based on their not being closed by Septenter 29, 1986. Since these FCRs could have been verbally approved and inplemented before the SQEP-l3 process took effect, they should have been evaluated in the DB&VP per the directive.

5-10

EachengineeringdisciplineontheEATeammustverifythatSQNEngineeringProjectsatisfactorily inplements the requirements of SQEP-15 to achieve technical resolution and incorporation of open FCRs, particularly those FCRs eliminated from the DB&VP by the project nuclear discipline evaluation supervisor.

Observation No. N3 [ Resolved]

In action item C-28, the concern was directed to the project about design criteria documents not including references to all of the other related design criteria doctanents. The project responded to this concern by issuing PIRSQNCEB0672 and routing it to each engineering discipline for their response via a potential generic condition evaluation memo. This C/A was outlined in item 7 of J. F. Cox's memo to files (B25 060911 012). NEB responded to the potential generic condition evaluation memo by conmitting that the NEB system design criteria documents would be reviewed during the revision then in progress to ensure that references to other design criteria documents were adequate.

The Nuclear discipline of the EA Team must verify that the NEB system design criteria documents adequately reference all other related design criteria doctsnents.

Observation No. N4 [ Resolved]

The SYSTERs issued by the DB&VP identify items requiring further attention to resolve. The punchlist developed by the DB&VP tracks these items and documents the C/A and restart category per the requirements of SQEP-45. The EA Team's concern about the proper inplementation of SQEP-45 for the punchlist were expressed in action itan E-83. The project responded to these concerns by conmitting to:

1. " Review 100 percent of the punchlist items that have been closed or restart classifications changed to ensure the system engineer was properly involved and that appropriate documentation of this process exists," and

2. Have the system engineer prepare a " system closure statement" to document his concurrence with the C/A and restart categorization for punchlist items associated with his SYSTER.

The Nuclear discipline of the EA Team nust verify that the project satisfactorily conpletes the C/A described in items I and 2 above. In addition, because no punchlist items assigned to the Nuclear Lead Engineer (NLE) involving significant technical decisions or C/A were closed during the EA review,additionalEANuclearverificationisrequiredtodeterminethattheprojectsatisfactorily completes the original process of determining C/A and restart category for items assigned to the NLE.

Ooservation No. N5 [ Resolved]

TheconcernwasdirectedtotheprojectinactionitemN-55,thatSYSTER61,"IceCondenser,"

contained several deficiencies such as missing forms, missing and incorrect PIR and punchlist items, incorrect valve number references, and failure to address sequence of inplementation of a group of related ECNs. The project responded to these concerns by conmitting to address the deficiencies in an addendum to SYSTER 61.

5-11

The Nuclear discipline of the EA Team must verify that an addendum to SYSTER 61 is issued that addresses the deficiencies described above.

Observation No.116 [ Resolved]

SQEP-16, section 3.3.8, required that the cumulative ef fect of the changes and exceptions made to the system be evaluated in the SYSTER. In Attachment I, section 3.0-R,' SQEP-16 specified an evaluation that will consider the resulting cumulative effect of the iglemented and uniglemented changes to the expected plant. configuration at restart. However, as implied by D8VP-D-86-0023, SYSTERs only addressed the cumulative effects of the modifications physically iglemented by restart. The concern that unimplemented changes (potentially C/A resulting from CAQs) had not been evaluated cumulatively was expressed in action item N-51. Theprojectrespondedbystatingthatthe cumulative evaluation of each uniglemented and partially implemented change would be documented on SQA-183,-Attachment 3 per SQEP-IS.

The Nuclear discipline of the EA Team must verify that the SQA-183, Attachment 3, forms cogleted by the project satisfactorily document the evaluation of the cumulative effects of the uninglemented portions of unimplemented and partially implemented modifications on each other.

Observation No. N7 [ Resolved]

The concern was directed to the project in action item N-58, that the D84VP Phase 1 Preliminary

. Report contained inaccuracies about program scope and SYSTER conclusions, inconsistencies in finding categories for CAQs, inconsistencies in discussion of SCRs in Appendix H-4, and improper trending of punchlistitemsbyoriginatingdiscipline,notresponsiblediscipline..Theprojectrespondedby comnitting to revise the report to address each of these deficiencies.

The Nuclear discipline of the EA Team must verify that the 084VP phase I final report is issued and addresses the deficiencies described above.

Observation 11o. 01 [ Resolved]

Action item Q-07 raised a concern with an ECN designated by a system engineer as a restart item but was removed from the SQN restart list via a restart schedule change Attachment 4 form. This removal from the restart list was not coordinated with the SE.

J.'F. Cox's February 25, 1987 memorandum to Matt Berardi listed several C/A measures which must be verified by the EA Team. These measures include specific and general C/As and also action to prevent recurrences.

Observation No. 02 [ Unresolved]

Action item Q-12 was issued to transfer responsibility for verification of C/A for CAR-86-03-012 to the EA Team. Prior to unit restart, EA must verify the adequacy of C/A for parts A and 8 of the CAR.

5-12

Observation No. Q3 (Resolved]

Action item Q-09 pertains to several EA-reconmended improvements to the SQEP-15 process. The project responded to lhls action item on March 50,1981, and conmillod to iglementing the igrovements by May 8, 1987. The EA Team needs to verify the adequacy of C/A implementation when cogleted.

Observation No. Q4 (Unresolved]

Action item Q-il identified the need to fully inplement SQEP-15 as conmitted to in the Nuclear Performance Plan, Volume 2. A waiver bypassing the SQEP-15 process was predominantly used at the time of the EA review. Aprojectresponsetothisitemhasbeenreceivedandispresentlybeing reviewed by EA.

The EA Team needs to conplete the evaluation of the project response and, upon acceptance of this or a future response, verify the adequacy of C/A inplementation.

Observation No. 05 [ Resolved]

Action item Q-10 pertains to recomnended changes to draf t versions of the D88VP final report. The EA Team needs to verify that these reconnendations are incorporated in the DB&VP final report.

Observation No. Tl (Unresolved]

Action item T-01 concerns control room as-constructed drawings (CRADs) which were revised by the plant modifications organization as field modifications work was congleted. This is acconplished through a " red-lining" process as described in plant procedures.

In interviews with DNE personnel, it was identified that this red-lined information is sometimes found to be incorrect. The action item stated that this process should be better controlled.

Since the time the action item was written, a response to a potential condition adverse to quality relatedtothissamesubjectwasissued(referenceJ.E.LawmemorandumtoL.E.Martindated April 14, 1987, Ll6 870414 800). In the memorandtsn, it is recommended that "a peer review of the transferred (red-lined) Information to be instituted to ensure that the approved change information is correctly transferred to the affected drawings to ensure there is no question about the correctness of the information transfer."

The EA Team needs to follow up on this recomnendation to ensure that this C/A or similar C/A measures are established.

Observation No. EAl (Resolved]

Action items for which the corrective and/or preventive actions can be taken after restart are discussed in section 8.4.2 and listed in Table 8.4-3. Fifty-eight of the EA Team action items involve postrestart corrective / preventive actions. The EA Team must verify these actions during Phase ll of the D88VP for the action items shown below:

C-15 C-53 E-28 E-SI 1-25 l-58 M-22 M-46 N-26 N-47 C-16 C-57 E-29 E-55 l-24 M-07 M-29 M-50 N-27 0-17

, C-17 E-12 E-31 E-84 l-37 M-Il M-50 N-19 N-28 0-18 C-18 E-15 E-39 E-06 l-38 M-13 M-32 N-20 N-29 0-19 C-26 E-22 E-40 1-09 l-45 M-15 M-36 N-23 N-57 C-30 E-27 E-49 l-14 l-47 M-17 M-45 N-24 N-42 5-13

Descriptions of Conditions Adverse to Quality in addition to the obsersations resulting from the review, several items identified Conditions Adverse to Quality (CAQ) and are being processed in accordance with NEP-9.1 R2. The preparation of the CAQR will place these items in the CAQ system for DNE and will only be referenced in this section by a CAQR nunter and a brief description.

CAQR No. Description SQE870R01001 Calculation MEB810406267 contained an unverified assimption. (M-48)

SQE870R01002 Applicable DB&VP punchlist items are not being formally recorded as CAQs. (Q-13)

SQE870R01005 Comparison of Containment Spray System documents indicate inconsistencies in the design temperature for the system piping within containment.

(M-47)

SQE870R01004 The diesel generator and electrical panel ventilation fans are required to start under some conditions to maintain the inlet air to the diesel generator at a design tenperature of 1200F or less. There is no indication in the main control room to verify these fans are operating.

(E-50) 5-14

6.0 SUPMARY BY DISCIPLINE This section covers the scope, approach, and results of the EA Team review. The information is sunnerized by discipline for the following activities which the Team reviewed:

o System boundaries determination e System walkdowns e Conparison of as-designed drawings with walkdown results e Electrical test results evaluations e Change document evaluations e Design criteria e System evaluations e Transitional change control EA Team approvals for this section and for section 7.0 (which represents detailed discussions of the EA Team's technical evaluation of these activities) are listed on the following page. The duties and responsibilities for the l&C, civil, and quality assurance personnel that were reassigned (see section 5.5) during the course of the EA Team reviews were assumed by other team menters in their respective disciplines.

l 6-1

APPROVALS BY EA TEAM REVIEWERS NUCLEAR........... 6.1, 7.1.1, 7.2.1, 7.5.1, CIVIL......... 6.5, 7.2.5, 7.5.5, 7.6.5, 7.6.I, 7.7.I, 7.9.I 7.7.5, 7.9.5 YYb D'. G. Renfro, Senio 'If7le7 QMm+fnIm

' R'.

~

) . Svarney, Gnior " ..

Nuclear Engineer Mechanical Engineer -

A MLk 'lltrier //,) , N A A 4/lyg)

C.darey,Nullear H. G. Bird,'

Engineer Civi Engineer ELECTRICAL........ 6.2, 7.2.2, 7.4.1, 7.5.2, 7.6.2, 7.7.2, 7.9.2 a$ d A. B. Sagery,

&/U' Civil Engineer Wn8 &Ml/7f87 I}/M. Gore, OPERATIONS Engine (ring Specialist ENGINEERING... 6.6, 7.2.6, 7.3.1, 7.4.3,

/[ S

[ElectricalEngineer e

T. G. Carson, Senior 9fhff7 Mechanical Engineer K. F. Liao, QUALITY Electrical Engineer ASSURANCE..... 6.7, 7.2.7, 7.4.4, 7.5.6, 7.7.7, 7.8.2, 7.9.6 MECHANICAL........ 6.4, 7.2.4, 7.5.4, 7.6.4, g 7.7.4, 7.9.4 M (j r k bM f/l7/87 P. R. Bevil, Quality JNJ 'ubtA FIA d.A Assurance Specialist S. A. Shuman, Senior k fl'ilQ Power Engineer ,

CONSTRUCTl0N.. 6.8, 7.5.7, 7.8.3 Ac \ -M-O Md G-/2- 77 R. Tucker. /.E. Gilbert, Ass'istant Mech ,1 cal En ineer Nuclear Project Manager M

ND.' R. %rnaby,$

Mechanical Engineef INSTRUMENTATION AND CONTROLS. . . . . . 6.3, 7.2.3, 7.4.2, 7.5.3, 7.6.3, 7.7p. 7.9.3

'ttuN) 4-rl17

[.J.Faubert, Engineer

f. f.E.m  % e-n-or E. McBee, instrument Engineer 0 W Wad 6- 4'41/87 D. S. Vassallo, Senior

)N -

Control Systems Engineer

~~.W.vonWeisensteinyyv.g J

Team Leader 6-2

6.1 Nuclear 6.1.1_Oversicht the Nuclear discipline of the EA Team reviewed the following DIMVP activitios:

determinalion of system bounderles, walkdowns, assently and ovaluation of change documents, identification of C/Rs and issuance of design criteria documents, issuance of SYSTERs and determination of C/A and restart categorization for punchlist items, and issuance of Phase i Preliminary Report.

EA Nuclear discipline also participated in a technical calculation audit to address the NEB i Calculation Review Effort and evaluate the technical adequacy of the essential nuclear calculations for SQN. This calculation review effort was to establish the adequacy of the NEB calculations through a sagle review of essential calculations and addresses both SQN base design calculations as well as DB&VP calculations identified through the change review process. The results of the EA Nuclear audit participation are described in EA audit B7-09(T) report. Only one area of concern was identified in NEB and was adequately addressed in the audit response. Verification by EA was conducted and the area of concern resolved.

EA Nuclear conpleted the review of the DB&VP with observations associated with the following activities:

1. Assently of change documents (observations NI and N2),

2. Issuance of design criteria documents (observation N3),

5. Issuance of SYSTERs (observations N5 and N6) and determination of C/A and restart categorization for punchlist items (observation N4), and

4. Issuance of Phase i Preliminary Report (observation N7).

6.l.2 Conclusions Based on the review of these DB&VP activities, EA Nuclear formed conclusions on the following:

1. Procedures-In general, the project nuclear discipline's work was accomplished in accordance with the program plan and procedures. As might be expected in a first of a kind program such as the DB&VP, the plan evolved and procedures were revised throughout the effort, sometimes reducing the scope or magnitude of DB&VP work. Some of the items that were eliminated from the DB&VP require EA Team review and were noted as observations.

2. Documentation-Ingeneral,thesupportingdocumentationprovidedbytheprojectnuclear discipline was considered to be correct, although sometimes lacking completeness. In particular, the methodology and engineering judgment were not well docunented in the NEB calculation that established the DB&VP system boundaries, although the bottom line boundary drawings were considered to correctly establish the portions of systems required to mitigate FSAR Chapter 15 events. The design criteria documents issued by NEB were considered to be thorough and well written although one observation was noted. The adequacy of supporting documentation for the ECN/FCN evaluations inproved during the program and their conclusions were considered to be technically adequate.

6.1-1

3. Technical Adequacy-in general, the SYSTERs prepared by the project nuclear discipline were judged to be technically adequate. As the program progressed, the SYSTER's function evolved to:

a. Assenble input data including previously performed individual evaluations of change doctsnents,

b. Doctsnent limited overall evaluations,

c. Identify items needing further attention, and

d. Conclude that the modifications since OL did not degrade the system's ability to mitigate Chapter 15 events.

EANuclearconcludedthattheprojectnucleardisciplineSYSTERsadequatelyperformed these functions although two observations were noted.

In general, EA Nuclear concluded that the programmtic and project nuclear discipline aspects of the DB&VP Phase 1 Preliminary Report were technically adequate with the exception of one noted observation.

4. Corrective Action-The determination and performance of C/A and the determination of restart category for all items assigned to NEB on the punchlist were the responsibility of the Nuclear Lead Engineer, outside the D84VP, with the concurrence of the DB&VP SEs. Due to the generally inconplete status of this effort at the close of the EA review, EA Nuclear could draw no conclusions about the technical adequacy of NEB's punchlist restart categories or C/A and noted this in an observation.

To sunmarize, EA Nuclear concluded that the project nuclear discipline adequately complied with procedures, provided generally correct supporting documentation, and issued technically acceptable SYSTERs. However, due to the inconplete status of the significant punchlist items, EA Nuclear could not reach a conclusion about the technical adequacy of the restart category or C/A for items assigned to NEB and noted this in an observation.

6.1-2

_ __ _ __ .. _ , _ _ . _ - ._. _ m . . .

6.2 Electrical 6.2.1 Oversloht The EA Electrical discipline of the EA Team reviewed the D88vP which included the areas of

, system walkdowns, electrical test evaluation reviews, evaluation of change documents, design criteria, and system evaluations. This review resulted in'the generation of 14 observations and one CAQR. One observation, El, was written in the walkdown area and another observation, E2, in the area of electrical test evaluations.

8-Two observations, E3 and E4, were prepared on change documents and a total of five were written in the design criteria area, observations E5 through E9.

Five observations, E10 through El4, were prepared as a result of reviews of the system evaluations.

CAQR SQE870R01004 was written as a result of C/A review of the system evaluation.

In addition to the review activities performed on the DB&VP, EA Electrical participated in a

, technical calculation audit to address the electrical calculation program which establishes the base design for the plant and ties this base design to the D8tVP by incorporation of

, changes made since OL to the calculations. The concerns and deficiencies found in the EA audit 87-09(T) have been adequately addressed by EE8 and are in the process of being corrected. Verification of this effort by EA will be performed as C/A is completed.

6.2.2 Conclusions

1. The review conducted by the Electrical discipline of the EA Team confirmed that the engineering activities performed by the D84VP electrical discipline were in accordance with approved procedures and were performed by personnel trained for the specific

activity. However, modification of procedures, particularly in the area of change i document evaluation, the issuing of program directives to clarify procedures, and t

retraining of D84VP electrical discipline personnel were necessary to meet the program objective.

2. Docunentation assembled to support the engineering conclusions reached by the D88VP electrical discipline was complete and correct with the exception of missing electrical requirements in some design criteria. it should be noted that multiple revisions involving significant electrical re-review efforts were required to achieve the final acceptable version of the ECN checksheets. In addition, SYSTER addenda and re-reviews of-punchlist items were needed to supplement the initial system evaluations and punchlist efforts.

l t

6.2-1 t

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3. The system evaluations were technically adequate for identifying system discrepancies and for confirming that, upon the cogletion of all prerestart discrepancies, the system's ability to perform its safety functions for the events described in Chapter 15 of the FSAR was not degraded by the changes made since OL. Additional verification is needed to verify that the SYSTERs have ' addressed all change documents and that the correct restart decisions were made for uniglemented and partit.1 implemented ECNs.

4. Few examples of C/A were available for review in the electrical area. Of those reviewed, two were determined to contain inadequate C/A. Additional verification of thir orogram area by EA will be necessary.

6.2-2

6.5 Instrumentation and Controls 6.5.1 oversight The ISC discipline of the EA Team (EA ISC) performed reviews on the 084VP walkdown, design criteria development, change document evaluation, system test evaluation, and the system evaluation activities, in addition, EA l&C participated in an EA audit of the DHE calculations program. The results of this audit are reported in EA Audit Report 87-09(T). Only one deficiency was identified in the l&C area during the audit. This deficisocy concerned the use of a Westinghouse i documt.nt in calculations with no TVA approval for its use. C/A was presented by EEB and EA verified the adequacy of the reponse. This deficiency was rasolved.

EA ISC completed its review of the DB&VP with some concerns remaining unresolved and/or withouthavingverifiedthatprojectC/Ahadbeensatisfactorilyfulfilled. Those concerns are defined in observations II, 12, and 15. All of the observations regard system evaluations including the associated 084VP punchlist.

6.5.2 Conclusions The EA l&C review concluded that all of the final program products were technically satisfactory and were prepared in accordance with their respective procedures. During the course of the program, the scope of the walkdown activity and the degree to which change documents were evaluated and documented required significant redefinition and rework in order to satisfactorily determine the design basis effects of plant modifications.

The deficiency in the walkdown scope was program related. The walkdown activity itself was well executed and documented in accordance with its governing procedures. The deficiencies identified in the change document evaluations were a result of inadequate definition in the change doctanent evaluation procedure and a lack of reviewer training. These deficiencies wereaddressedandsatisfactorilyreconciledbytheprojectduringthecourseoftheprogram.

Procedure inplementation, training, and documentation were found to be satisfactory in all other program activities.

The EA ISC review of the 084VP was supplemented with a review of EEB essential calculations (EA audit 87-09(T)] in order to assess the technical adequacy of the calculations, both on the basis of their supporting role in the DB&VP and the overall design basis of the plant.

The calculations were found to be current, conplete, and well prepared.

6.3-1

. - , , = - - , , - - - - - . - - -,

l 6.4 Mechanical 6.4.1 Oversloht The Mechanical discipline of the EA Team review of the DBIVP included the areas of system walkdowns, evaluation of change documents, evaluation of design criteria, and review of SYSTERs, including restart categorization of punchlist items.

One CAQR (SQE870R01005) and one observation (M)) were written on design criteria preparation. One CAQR (SQE870R01001) and three observations (MI, M2, and M4) were written in the areas of SYSTER preparation and punchlist item closeout.

In addition to the activities performed on the 084VP, a technical audit was performed on the mechanical calculation program which formed a portion of the base plant design. The MFB calculation review effort was based on a sample review of the MEB essential calculations for SQN to establish the technical adequacy of MEB calculations. EA Mechanical reviewed calculations from within the sagte and also outside the MEB sample.

Several concerns and deficiencies were identified during the audit and are covered in detail in EA audit report 87-09(T). These concerns and deficiencies have been addressed by MEB and are in the process of being corrected. Verification of this effort by EA will be performed as C/A is cogleted.

6.4.2 Conclusions Based on the review of these activities, EA Mechanical formed the following conclusions:

1. The mechanical portion of the DB8VP effort was performed in accordance with the program plan and procedures. The scope of certain portions of the program changed as the work progressed, as reflected in revised procedures and program directives.

2. The completeness and correctness of the supporting documentation igroved substantially as each part of the program progressed. The documentation is adequate pending cogletion of reruining issues such as punchlist items, open SCRs, and identified observations.

3. The system evaluations likewise igroved considerably, and, in conjunction with the design review checklists prepared for ECNs, provide substantial and adequate technical justificationforthechangesmadetotheplantsince01.,andthefactthatthose changes will not decrease the ability of the systems to respond to Chapter 15 events.

It is noted that the scope of the SYSTERs with respect to C/A identification and scheduling has changed, as noch of this effort has been deferred to the punchlist.

4. A limited nunter of C/As including restart decisions were available for evaluation. Of those reviewed, one inadequate item was identified against the process. As much of this effort had not been completed at the conclusion of the EA review period, the adequacy of the C/A process could not be fully determined.

6.4-1

• u 6.5 Civil 6.5.1 oversloht TheEACivildisciplinereviewoftheDB&VPincludedtheprojectiglementationofsystem walkdowns, change document evaluations, design criteria preparation, and system evaluations and C/A. The review was conducted from a civil engineering viewpoint to ensure that changes with potential i gact to the design qualification of systems within DB&VP scope were adequately evaluated and documented. The EA review consisted of a technical evaluation of cogleted project products, and included a progranmatic review for civil 00&YP procedural '

cogliance. The adequacy of interface with other disciplines was also evaluated as part of the EA Team effort. Theobjectiveofthereviewwastoprovideaddedassurancethat applicable changes would not degrade the ability of the safety systems to mitigate FSAR Chapter 15 events, in addition, EA Civil participated in the technical audit conducted on the civil calculation effort; however, at the time of the audit the civil effort was in its early stages of iglementation and very few products were available for review. Adequacy of the program was evaluated and determined that if properly iglemented would address the calculation concerns. Several specific areas of concern were identified in EA audit 87-09(T) report.

,~

These areas of concern address both program establishment and technical adequacy. As the CEB effort is implemented, EA verification of the areas being addressed will be conducted.

The EA Civil effort concluded with six observations. Two observations (Cl and C5) were related to the change document evaluations; two observations (C2 and C3) were related to the design criteria; one observation (C4) was related to the SYSTER; and one observation (C6) requiresEATeamverificationofprojectcorrectiveaction.

6.5.2 Conclusions The civil DB&VP effort was adequately cogleted per the approved engineering procedures.

The personnel were found to have been trained as required, f

Dochnentation assenbled by the DB&VP to support the engineering conclusions for the civil scope was adequate. The D84VP documented the walkdown effort, the development of the general design criteria, the change document evaluations, and the system evaluations, and adequately recorded discrepancies on the design baseline punchlist.

The system evaluations adequately incorporated the civil inputs. The actual evaluation of acceptability of open civil-related discrepancies and the effect on system adequacy were delayed until punchlist dispositions could be cogleted.

The C/A program could not be verified because an insufficient nunter of final punchlist dispositions for C/A and restart determination have been completed to allow an EA determination of technical adequacy for civil considerations.

l 6.5-1

6.6 Operations Enaineerina

-6.6.1 Oversicht The Operations Engineering discipline of the EA Team participated in the review of system walkdowns, ccuparison of as-designed drawings with walkdown results, electrical test results evaluations, review of modifications to control room drawings, review of SYSTERs, and transitional change control. Review of the above areas of the DB&VP was performed from an Operations Engineering viewpoint to ensure that items which could af fect plant procedures and operation of the plant were being accurately addressed, documented, and made available to Plant Operations.

The project's satisfactory resolution of all action items raised by EA Operations

. Engineering resulted in no observations being issued in the Operations area.

6.6.2 Conclusions

1. All project activities reviewed by EA Operations Engineering were performed in

-accordance with approved procedures by personnel properly trained in those procedures.

2. Project documentation reviewed was thorough and complete for activities reviewed by EA Operations Engineering.

3. AllprojectactivitiesreviewedbyEAOperationsEngineeringweretechnicallyadequate.

4. The conpleted C/As reviewed in the punchlist were adequate.

6.6-1 c - - - - + - - - ,-m ,

l

)

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6.7 Quality Assurance l

6.7.1 The Quality Assurance discipline's involvement in the EA review of the 088VP consisted of reviews of progrannetic elements of the following areas: system walkdowns, electrical test results evaluations, change document evaluations, system evaluations, transitional design change control, and the project report.

This review resulted in the generation of five observations and one CAQR: one observation (Ql) was prepared in change documents; one observation (Q2) was prepared in the system evaluation of C/A for punchlist items; two observations (Q3 and Q4) were prepared on the transitional change control program; and one observation (QS) was prepared on the project report. The CAQR (SQE870R01002) was prepared on the system evaluation of punchlist items.

6.7.2 Conclusions The adninistrative controls within the SQEP-14 test program in conjunction with the plant / project interface controls in the new SQEP-57 procedure are adequate, effective, and well inplemented.

Upon acceptable closure of observation Ql, the CCB program is judged to be adequate to provide overall control of all plant modifications. This control should facilitate adequate transition to the new change control system.

The D88VP project's evaluations of punchlist items to determine which should be designated as CAQs have been inadequate. Subject to satisfactory resolution of observation Q2 and CAQR SQE870R01002, this portion of the punchlist program is considered adequate.

The EA Team reviewed the inplementation of the transitional change control program. The restricted use of the new design control process limited the EA Team's review of change documents handled by this process. Concerns were raised by the EA Team from this limited review andarebeingaddressedbytheproject. The EA Team could not derive a conclusion on the inplementation objectives of the transitional change control process until further use is made bytheprojectandadditionalreviewsperformedbytheEATeam.

EA QA concluded that the DB&VP Phase i Preliminary Report generally reflected an adequate and accurate accounting of the DB&VP Phase i effort subject to closure of observation Q).

6.7-1

6.8 Construction 6.8.1 Oversicht The Construction discipline of the EA Team reviewed and evaluated change docurnants, transitional change control, and modifications to control room drawings. Review of the above areas was performed from a construction viewpoint to ensure constructibility of engineering change and construction modification packages and compliance with the governing procedures and approved change control program.

The approach taken to establish adequacy of the D88VP from a construction viewpoint included:

1. Review of ECNs issued since OL for completeness, clarity of scope of work definition, and conpliance with SQEP Al-ll.

2. Review of construction implementing modification packages (workplans) for accuracy in reflecting the engineering change, conpleteness of implementing instructions, and compliance with SQN Al-19 (part IV).

3. Review of CRADS for conpleteness and accuracy in reflecting the inplemented or partially inplemented modification.

4. Review of the transitional design change program for conpleteness of engineering change packages, clarity of scope of work definition, completeness and accuracy of inplementing instructions to accurately reflect the design change, and conpliance with SQEP-13.

6.8.2 Conclusions i

The Construction discipline of the EA Team concluded that the engineering-approved and issued change packages and the Construction-approved and issued implementing modification packages accurately reflected the required change, were complete and adequately defined the scope of the change, and other than CRADs were processed and implemented in accordance with governing procedures and the approved program (see observation TI).

This conclusion was based on the following results:

1. ECN packages were prepared, reviewed, approved, and issued in accordance with SQEP Al-Il or SQEP-13. They adequately defined the scope of the change and provided sufficient infornation to ensure a detailed workplan.

2. Workplan packages were prepared, reviewed, and issued for implementation in accordance with SQN Al-19 (part IV). They were complete, accurately reflected the ECN modification, and provided conplete implen. anting instructions.

3. The control room as-constructed drawings accurately reflected the "as-constructed" condition of ieptemented or partially implemented modifications as redlined by the Modifications Cognizant Engineer. These drawings as redlined had not been validated (see observation TI).

6.8-1

s 7.0 DETAILED RESULTS BY ACTIVITY AND BY DISCIPLINE This section provides detailed information regarding the discipline review results by activities.

A brief general description of the project activity and the EA review and participation is

-included for each of the following activities:

e System boundaries determination e . System walkdown e- Conparison of as-designed drawings with walkdown e Electrical test results evaluations e Change document evaluation e_ Design criteria e System evaluation e Transitional change control e Phase i DB&VP Report (Preliminary) 7-1 3

7.1 System Boundaries Determination The DB&VP addressed those systems or portions of systems that are required to mitigate Final Safety Analysis Report (FSAR) Chapter 15 design basis events. The events, systems, and boundariesofthosesystemsweredocumentedinDNEcalculationSQN-OSG7-048bytheproject nuclear discipline.

EA Team reviewed this calculation to determine the extent to which Chapter 15 design basis accidents were considered and docunented in the calculation, the adequacy of the determination of the a!sociated system boundaries, and compliance with Of fice of Engineering Procedure (OEP)-07.

Since the calculation was prepared by the project nuclear discipline with no involvement from other disciplines, only EA Nuclear performed the review for the EA Team.

The results of the EA Nuclear review are presented in section 7.l.l.

p 7.l-1

}

7.1.1 Nuclear EA Nuclear reviewed the system boundary calculation SQN-OSG7-048 (reference 1). The review was to determine the adequacy of the system boundaries and the supporting documentation.

This was acconiplished by considering the following technical attributes:

conpleteness/ correctness, documentation / justification, clarity, and consistency. The review for procedural conpliance included attributes for content, cover sheet completeness, revision log, and approvals.

7.l.l.1 Details EA Nuclear reviewed the list of events, the list of systems, and the system requirements for each event and approxinately half of the system boundary drawings.

In reviewing the calculation for conipleteness/ correctness, several concerns were identified. These included the following:

a. The calculation omitted several types of containment penetrations (e.g., those not associated with a fluid system, nornelly open ones that remain open af ter an accident, and those with blind flanges). The noted omissions were submitted to the projectinactionitemN-03. Theprojectrespondedbyrevisingthecalculation (revision 3) to create boundary drawings for the Containment Isolation System (88) including these and other penetrations.

b. Minor errors in the calculation cover sheet and text were noted. A few required control room indicators were excluded from the RCS boundary drawings. In addition, more conponents than required were included in the boundary drawings for the Vital Control Power System (249/250). AlthoughEANuclearjudgedthattheseerrors, omissions, and inclusion of extra corrponents were minor and that the calculation adequatelyfulfilleditspurpose,theseconcernsweresubmittedtotheprojectin action items N-06 and E-06, respectively, so that the project could consider improving the quality of the calculation package. The project responded by revising the calculation (revision 3) to correct the errors, add the omissions, and delete the extra conponents.

c. The NRC questioned whether NUREG-0737 (Three Mile Island) items were included in the scope of the DB&VP (reference 2). In response to this question expressed in action item N-12, the project stated that all systems and portions of systems, whether included in NUREG-0737 or not, required to mitigate FSAR Chapter 15 events were within the scope of the DB&VP. EA Nuclear concluded that this explanation conplied with the DB&VP plan and satisfactorily addressed the question.

7.1.I-I J

. -. .. . - . .~ - -.- -. - - .- -

. Inreviewingthecalculationfordocumentation/justificationadequacy,severalconcerns

, were raised by EA Nuclear and the NitC. These concerns related to the lack of documentation of. engineering judgment or lack of technical justification in the calculation and included the followin0:

a. The calculation did not address all FSAR Chapter 15 events. This concern was submittedtotheprojectinactionitemN-01. The same concern was also expressed by theNilCandsubmittedtotheprojectinactionitemN-09. Theprojectadequately responded to this concern by revising the calculation (revision 2) to include an explicit justification for the selection of sixteen Chapter 15 events whose mitigating systems encompass all of those required for all of the omitted Chapter 15 events.

b. Safety functions were not identified systematically in the calculation for each event. ThisconcernwasaddressedtotheprojectinactionitemN-02. EA Nuclear

' reconmended in the action item that the reasoning process that had been used _to e

address _each safety function be documented in a tabulation of safety functions for each event and the systems required to provide those functions. Theproject responded by revising the calculation (revision 2) to include a single matrix of safety functions versus systems for all events. Although this composite matrix did j not provide the detailed documentation of safety function and system for'each event as desired, the abbreviated documentation format was considered adequate. This acceptance by EA Nuclear _ was based on the fact that the results of the calculation, system boundary drawings, were considered to be technically adequate.

c. Justification was not provided for those major portions of systems included or omitted from the boundaries, as applicable. This condition was presented to the project in action item N-04. Theprojectprovidedarationalefornotincludingthis justificationinthattherewasnoevidenceofmisinterpretationoftheboundary drawings because of this information not being included. Although EA Nuclear

believesthatprovidingwrittenjustificationisgoodengineeringpracticein general, in this instance, EA Nuclear accepted the project's position without

. requiring further action.

d. No boundary drawings were included in the calculation for the Combustible Gas Control 4 (85), Containment isolation (88), Neutron Monitoring (92), and Reactor Protection (99) Systems. This lack of documentation was addressed to the project in action items N-06 and N-II. TheprojectrespondedbystatingthatnoTVAdrawingswere .

readily available for these systems to use as a basis for boundary drawings.  :

AlthoughEANuclearinitiallyacceptedthisrationale,theprojectlateracknowledged the need and developed boundary drawings for these systems and revised the l calculation (revision 2) to include them.

e. Modifications to plant features internal to certain vendor-supplied components, such as the reactor vessel (e.g., rod cluster control assemblies, fuel assent >lles, and vessel internals, which are all required to maintain the fuel in a subcritical, coolable geometry), were not addressed. This concern was directed to the project in action item N-32. The project responded that components inside the reactor vessel j were considered to be within Westinghouse's scope so that modifications to those

- conponents were engineered under Westinghouse *s QA program and inplemented at the

! direction, with the concurrence, or with the participation of Westinghouse.

k 7.1.1-2

The project stated that this situation applied to other vendors of engineered conponents as well. The determining factor for scope of responsibility was whether TVA or the vendor maintained the associated drawings. Despite their contention that such internal conponents were not within the scope of the program, the project requested that Westinghouse review existing Westinghouse and TVA documents (FCNs, ECNs, and SCRs) associated with design modifications for the unit 2 reactor vessel and internals. The Westinghouse raview concluded that those plant features were acceptable for restart. Based on the results of the Westinghouse review and the project'sexplanationsofvendorscopeofresponsibility,EANuclearacceptedthe project's response to this concern.

In sunmary, several concerns over the lack of adequate documentation and justification in the calculation were identified in items a through e above. The project made revisions to the calculation to address some of these concerns but decided not to expeld the resources to further inprove the quality of documentation for this tenporary calculation. Such doctmentation is generally required by good engineering practice and is recognized by OEP-07 (reference 3) and DNE policy memo (reference 4). Although the calculation still lacks an orderly, well-documented record of the links between each event,safetyfunction,andmitigatingsystem,andjustificationforthespecific portions of those systems included within the boundaries, EA Nuclear concluded that the results were adequate and the amount of documentation included was acceptable.

Acceptance was based on the fact that the results of the system boundary identification were adequate.

In reviewing the calculation for level of clarity and inconsistencies, several concerns were identified:

a. Potentially confusing aspects of the calculation such as terminology and boundary nurkings were evident. This condition was directed to the project in action items N-01 and N-05. This lack of clarity was corrected by revising the calculation (revision 2) to eliminate a " support" category of systems and to make boundary narkings clearer.

b. Two concerns about minor inconsistencies in the calculation were also noted, namely, discrepancies between boundaries on related flow and logic diagrams and between the system-safety function matrix provided in response to action item N-02 and the text.

These inconsistencies were directed to the project in action items N-06 and N-30.

The project responded by revising the calculation drawings and matrix (revisions 2 and 3) to eliminate a sufficient nunt>er of discrepancies to clarify the calculation results.

The calculation was also reviewed to ensure conpliance with OEP-07 (reference 3). The general content, cover sheet completeness, revision log, and approval signatures were adequately completed and documented. Based on these observations, EA Nuclear concluded that the OEP-07 requirements were met.

7.1.1-3 J

j in addition to the calculation adequacy and procedural reviews, EA Nuclear had a generic concern relating to the adequacy of disseminating and applying revised boundary drawings to previously congleted and ongoing project activities. This concern was directed to the projectinactionitemN-31. Theprojectrespondedthatmostoftheboundaryrevisions were made at the request of the affected SEs and that all revisions were conmunicated to the SEs. EA Nuclear confirmed this through discussions with several SEs and concluded that this was an acceptable practice, in conjunction with their review of calculation SQN-0SG7-048, the NRC noted that the Neutron Monitoring System (92) detectors were classified as Environmental Qualification (EQ) category "C" (not required to function and not capable of preventing the performance of a safety function) in calculation SQN-OSG7-0034 (reference 5). However, they also noted that Westinghouse had recently provided TVA with documentation to indicate that use of the "C" designation was incorrect because of a previously unanalyzed control and protection system interaction following a small steam line break inside containment.

Although not in the scope of the DB&VP (because it was EQ-related), this concern was raised in action item N-IO. Inresponse,theprojectissuedSCRSQNNEB0609(reference 6).

EA Nuclear closed action item N-10 because the issue was formally documented by this SCR in TVA's CAQ program and was not within the scope of the DB&VP. However, the NRC continued to monitor TVA's handling of the SCR. During their Noventer 1986 inspection, theNRCrequestedadditionaljustificationfromTVAtosupporttheconclusionsreached in the safety evaluation of this issue performed by Westinghouse (SECL No.86-451). As a result, action item N-10 was reopened January 12, 1987, to track the NRC's concern. EA Nucleardidnotreceivearesponsetothereopenedactionitemfromtheprojectduring the EA review. However, because the NRC formalized their request in a February 3,1%7, letter from J. M. Taylor to S. A. White (reference 7), TVA will be required to address this issue in writing through official licensing channels. For this reason, and because the concern is outside the scope of the D64VP and was captured in an issued SCR, EA Nuclear concluded that no additional EA verification was necessary for this NRC concern.

7.1.1.2 Conclusions The purpose of calculation SQN-OSG7-048 was to identify the boundaries for those systems (or portions) required to mitigate FSAR Chapter 15 events. EA Nuclear concluded that:

(a) revision 3 of the calculation acconplished this purpose with boundary drawings that were considered to be conplete, correct, clear, and consistent; and (b) althcugh the internal doctanentation and justification of the calculation could have been enhanced, the product of the calculation (boundary drawings) was determined to be technically adequate, and the development of the calculation met appropriate procedural requirements. Since the calculation is not required to be updated postrestart, EA Nuclear concluded that the overall calculation was adequate in acconplishing its purpose, that is, identifying systemboundarieswithinwhichtheprojectwastoevaluatemodifications.

7.l.l-4 f

7. l . l .3 References issue Reference Docunent Revision Date Title l SQN-OSG7-048 I 5/22/06 Identification of Systems Required for 2 8/6/06 Sequoyah Resfart 5 1/6/87 2 N/A 0 5/1/86 Design Baseline and Verification Program -

Sequoyah Nuclear Plant 3 OEP-07 0 4/26/85 Calculations 4 820 860424 001 -

4/25/86 Policy Memorandum PM86-04 (DNE) Engineering Judgment 5 SQN-OSG7-0034 3 II/27/85 Neutron Monitoring System (92) NUREG-0588 Category and Operating Times 6 SCRSQNNEBB609 0 6/25/86 CAQ 7 - -

2/3/87 NRC Letter from J. M. Taylor to S. A. White I

7.1.1-5 i

7.2 System Walkdown The project's walkdown activity included functional walkdowns using specific drawing types to determine the actual configuration that currently exists in the plant for the systems within the scope of the DB&VP. The initial walkdown packages were prepared by DB&VP personnel in accordance with SQEP-08 and were coordinated through a DNE walkdown coordinator. The actual walkdowns were performed by a team from Plant Operations, Site QA, and DB&VP project personnel in accordance with SMI-0-}l7-30. These activities were coordinated through the walkdown manager. Supplementary walkdowns were also performed in the same manner to obtain additional information and data, and/or to test functional performance of certain components or portions of systems.

EA discipline reviews were conducted in two distinct areas. First, walkdown packages as they were developed were reviewed for inclusion of the technical attributes necessary to demonstrate the functional ability of the plant systems. Second, walkdown results were reviewed af ter the completion of the walkdown and a review of walkdown-identified discrepancies was performed.

In addition, the EA Team performed independent walkdowns to verify the correctness of the project's results by conparing the EA walkdown results with the project results.

The results from Nuclear, Electrical, l&C, Mechanical, Civil, Operations Engineering, and QA which reviewed the functional and supplemental walkdowns are presented in sections 7.2.1, 7.2.2, 7.2.3, 7.2.4, 7.2.5, 7.2.6, and 7.2.7, respectively.

7.2-1

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L t 7.2.1 Nuclear EA Nuclear reviewed functional walkdown and supplemental walkdown packages for completeness, e

technical adequacy, and cogliance with SQEP-08 (reference 1). The walkdown packages were reviewed to determine if:

a. The walkdown covered all portions of the system identified in calculation SQN45G7-048 (reference 2).

b. All conponents in the walkdown package boundaries were adequately identified or described on data sheets, drawings, and sketches.

c. All discrepancies discovered dering the walkdown were clearly noted and indicated on sumnary sheets, drawings, and sketches.

d. All requested supplemental data was provided by the walkdown package.

e. The w3) Mown package indicated through initials, signatures, dates, and other markings the extent of the system walkdown each day,

f. The walkdown package contained signatures and/or initials as required from its preparers, checkers, reviewers, and disciplines and contained supporting reference documents,

g. Personnel received proper training in SQEP-08.

h. The walkdown package document was handled as a QA document.

l 7.2.1.1 Details The Ice Condenser System functional walkdown package (reference 5) was randomly chosen for reviewfromthosesystemswithinthescopeoftheprojectnucleardiscipline. The Upper Head injectior (UHI) System supplemental walkdown package (reference 4) was chosen for review because this system had been modified extensively since 01.. In addition, EA Nuclear

' reviewed other documents (references 5 and 6) which were accepted by the project in lieu of a walkdown package for the Auxiliary Control Air (ACA) System to determine its conpleteness with respect to item a. above.

r

a. Ice Condenser System 61-The Ice Condenser System walkdown package (reference 3) was found to be technically adequate and in compliance with SQEP-08.

b. UHI System 87--The UHI System supplemental walkdown package (reference 4) was found to be technica!ly adequate and in conpliance with SQEP-08.

c. ACA Systen 32-The ACA System was chosen for review by EA Nuclear because a formal walkdown under the requirements of SQEP-08 was not performed by the project. Instead, the project accepted for its use (see reference 5) the report of a comprehensive review of the ACA System (reference 6) performed during November and December of 1%5. Since the ICA report was not prepared in accordance with SQEP-08, it was only reviewed by EA Nuclear for boundary congleteness. Review of the report revealed that a conglete ACA f

7.2.1-1 j

System walkdown was performed which conpared the as-built drawings with the actual plant configuration. The entire ACA System was walked down and documented in the referenced report. Therefore, all portions of the system in the boundary as defined in SQN-OSG7-048 were included. The ACA System reporI was determined to adequately meet the scope of this review.

7.2.1.2 Conclusions EA Nuclear concluded that the system walkdowns were technically adequate and conplied with SQEP-08. The ACA System walkdown was conplete and technically adequate for use by the project.

7.2.1.5. References issue Reference Document Revision Date Title l SQEP-08 4 12/9/% Packaging and Controlling of Walkdown/ Test Documentation 2 SQN-0SG7-048 5 1/6/87 Identification of Systems Required for Sequoyah Restart 5 WDP-61 0 lce Condenser System Walkdown Package 4 WDD-87-Si 0 UpperHeadinjectionSystemSupplemental Walkdown Package 5 S08 860514 825 - 5/14/86 Memo from W. E. Andrews to D. W. Wilson, "Sequoyah Nuclear Plant - Review of Auxiliary Control Air" 6 LO4 860224 945 0 2/11/86 Review of Auxiliary Control Air System 7.2.1-2

7.2.2 Electrical TheElectricaldisciplineoftheEATeam(FAElectrical)reviewedtheproject'seffort in assertling, performing, and documenting the functional and supplemental walkdowns developed in accordance with procedures SQEP-00 (reference 1) and Special Maintenance Instruction (SMI)-0-317-30 (reference 2). The functional walkdown packages did not cover detailed electrical aspects whereas the supplemental walkdown packages did. The walkdown packages were reviewed for procedural conpliance and addressed the following aspects:

e Verifying that the walkdown scope covers all areas defined in the SWRIDs of calculation SQN-OSG7-048 (reference 3).

e Verifying that the walkdown information, the results, and the discrepancies were adequateIy documenied.

e Verifying that the STA properly documented the review of the walkdown discrepancies discovered.

e Verifying that the walkdown package is properly signed by the necessary parties.

In addition to the procedural review, the supplemental walkdowns were reviewed for technical adequacy. Technical adequacy was determined by reviewing the thoroughness of the system walkdown, the acceptability and adequ.'cv of the walkdown data, and the adequacy of identifying discrepancies.

EA Electrical discipline participated in two EA Team verification walkdowns to further confirm that the walkdown methodology and the electrical system walkdown scope were acceptable and that the system walkdown discrepancies were properly identified. This was acconplished by comparing the EA Team walkdown results with the project's results.

Infornation obtained from the verification walkdowns was also utilized to assist in the SYSTER reviews and is discussed in section 7.7.2. EA Electrical participation and the results of the verification walkdowns are also discussed in the Operations Engineering discipline walkdown results section (7.2.6).

The specific walkdown packages selected for review were chosen primarily on the basis that the system would offer representative types of various electrical loads, be representative of the type of walkdowns conducted, and/or specifically involve the electric power systems identified in calculation SQN-OSG7-048, 7.2.2.1 Details The type of system walkdown, the systems involved, and the specific walkdown packages that were reviewed by the EA Electrical discipline are listed below, along with the verification walkdowns in which the EA Electrical participated.

7.2.2-1

)

Walkdown Type System Walkdown Package Functional 67 WDP-67RI (Unit 2) (reference 4) )

63 WOP-63R0 (Unit 2) (reference 5) 46 WDP-46RI (Unit 2) (reference 6)  ;

30 WDP-30ERO (Unit 2) (reference 7)  :

Supplemental AP WDP-AP-SI (Units I and 2) (reference 8)

VP WDP-VP-DC-SI (Units I and 2) (reference 9)

EA Verification (functional) 82 EA initiated (supplemental) 82, AP, VP EA initiated A review of walkdown package WDP-46 RI indicated that the results reported were acceptable and in accordance with the governing procedures. In general, the remaining walkdown packages reviewed were acceptable except for some minor discrepancies associated with a lack of clear definitions of walkdown boundary scope WDP-67 RI, WDP-63 RO, WDP-30E R0, and WDP-VP-DC-SI R0. In one instance WDP-AP-Si li0, the review of deviations for operability by the STA was not apparent, and one instance WDP-AP-Si the 480V shutdown board (SHDN BD) breaker setting discrepancies were not recognized. The details of these concerns are presented in the following paragraphs:

1. WDP-67RI - Essential Raw Coolina Water (ERCW) System 67-This walkdown package included the applicable mechanical control and flow diagrams for System 67. No electrical walkdown data was required to be gathered in this initial walkdown. The EA Team's review noted the following walkdown package problems:

a. Certain walkdown CRADs were found to have additional markings and engineering decisions made by the SE that reduced the scope of the system walkdown boundary.

SQEP-08 R0 did not permit system walkdown boundary reductions by using engineering judgnents. Thisconcernwasidentifiedtotheprojectinaction item E-01.

b. Certain walkdown CRADs showed " cross-hatched" markings that appeared to represent equipment areas outside the scope of the system. However, as defined by calculation SQN-OSG7-048, these areas should be indicated by " heavy-dash" lines.

The use of and lack of definition for the cross-hatched areas could cause confusion during the walkdown and could result in omissions. EA Electrical believes that clarification of the meaning of such markings could alleviate potential problems. ThiswasidentifiedtotheprojectinactionitemE-2.

The project responded to the above concerns by revising walkdown procedure SQEP-08 and including requirements in the system evaluation procedure SQEP-16 (reference 10) to allow the SE to provide technical justification for not walking down portions of the system in the SYSTER. Theprojectalsostatedthatanyconfusionresultingfrom use of cross-hatched areas would only lead to inclusion of additional walkdown information that is not specifically required and is actually outside the scope of the system boundary defined by calculation SQN-OSG7-048. Theprojectactionsand stated position were acceptable to the EA Electrical. Revision 2 of SQEP-08 and SQEP-16RO were reviewed by the EA Electrical and were found to adequately address the projectactions.

7.2.2-2

2. -WDP-63R0 - Safety injection System (SIS)' 63-This walkdown package included applicable mechanical control and flow diagrams for System 65. leo electrical

~

walkdown data was required to be gathered as part of this' initial walkdown. The EA Electrical noted that the System 63 boundary as established by calculation

. SQll45G7-048 was omitted from the walkdown flow diagram and that a portion of the

-system,theboroninjectiontank(81T)bypassline,wasomittedfromthewalkdown.

TheseomissionswereidentifiedtotheprojectbyactionitemE-04. Theproject responded by: -(a) revising SQEP-08 to permit the SE to deviate from the system boundaries of calculation SQli-OSG7-048, provided that -technical justification is included in the SYSTER in accordance with SQEP-16, and (b) including the Bli bypass line in a supplemental walkdown. -This action was verified by the EA Electrical review of Revision 2 of SQEP-08 and the results of the supplemental walkdown package WDP-63-SIRO which included the Bli bypass line.

3. WDP-30ERO - Ventilation. ERCW Pumpina Station - System (30)-This walkdown package included the walkdown results for the applicable heating, ventilating, and air-conditioning (HVAC) physical drawings pertaining to the ERCW puging station.

Dio electrical walkdown data was required to be gathered for this initial walkdown.

EA Electrical noted that the cogleteness of the walkdown results could not be verified from the walkdown CRADs. This inability to verify bour.dary completeness resulted from the fact that system boundaries were not defined by applicable SWBID in the SQll-0SG7-048 calculation package. Therefore, there were no defined boundaries applied to the walkdown CRADs. Thiswasidentifiedtotheprojectbyactionitem E-03. The project responded by revising calculation SQll-OSG7-048 (Revision 2)-to include the ERCW pu ging station ventilation physical drawings. The EA Electrical confirmed the project's action and found it to be acceptable.

4. WDP-VP-DC-SI - Vital Control Power System (VP SYS)-This supplemental walkdown package included the results for the 125V Vital Direct Current _(DC) Power System.

The EA Electrical review included the confirmation of load assignments, branch circuit connections, and protective devices of the 125V Vital DC Battery Boards.

EA Electrical noted that several portions of the 125V Vital DC Power System (such as the vital batte' ries and battery chargers) were not included in the system walkdown.

ThiswasidentifiedtotheprojectbyactionitemE-81. Theprojectrespondedby providingtechnicaijustification,fornotincludingtheseareasinthewalkdown,in an addendum to the VP SYS SYSTER. EA Electrical's review of W VP SYS SYSTER Addendum, Rev i (reference 11) found this to be acceptable.

5. WDP-AP-SI - Auxiliary Power System (AP SYS)--This supplemental walkdown package included the results for the Class IE AP SYS. The EA Electrical's review included the confirmation of the electrical load assignments and protective device settings of the AP SYS boards. The EA Electrical noted that the AP SYS walkdown package only recorded electrical nameplate data and that no walkdown CRADs were included for this package. The project subsequently compared this nameplate data with the appropriate CRADs and recorded the differences. These differences were not reviewed by an STA for effects upon system operability as required by SMI-0-317-30. This was identified totheprojectinactionitem0-22. Theprojectadequatelyaddressedthisconcernb'y re-reviewing the AP walkdown data, cogaring it with the appropriate CRAD single-line drawings, and documenting the differences using Adninistrative Instruction (Al)-25 (reference 12) for evaluation by a STA. This was acceptable.

7.2.2-3 s

I l

l l

l The results of the EA Electrical's verification walkdown of a portion of the AP SYS also found that in~a comparison with this walkdown package a circuit breaker nameplate data sheet had recorded incorrect walkdown data. Thiswasidentifiedtotheproject by action item E-88. - The project's C/A for this concern was not conplete at the time ,

ofreviewandverificationoftheproject'sactionremainstobeperformed.

'(Observation EI)

~6. EA Verification Walkdown--Portions of System 82, VP SYS, and AP SYS were walked down by the EA Electrical. The EA walkdown also included portions of the VP SYS that the project had excluded from their walkdown to further establish the acceptability of i excluding portions of the system from walkdown. The EA Team recorded their walkdown results on applicable as-constructed drawings and data sheets. These results were then compared with both the applicable project walkdown results and the SYSTERs to verify that the results were similar and that walkdown discrepancies were properly i lentified. The comparison indicated that:

a. A VP SYS CRAD was not identified as having a missing cable ID suffix. This was identifiedtotheprojectinactionitemE-86. Theprojectrespondedbyincluding-this discrepancy in the punchlist to ensure the drawing is corrected and by providingtechnicaljustificationforexcludingthisportionoftheVPSYSfrom the walkdown in the VP SYS SYSTER addendum. The EA Electrical's review of the VP SYS SYSTER addendum, Revision I, found this project action to be acceptable.

b. The vital inverter nameplate data appeared to conflict with-the VP SYS SYSTER's ECil evaluation. This was identified to the project in action item E-86. The projectrespondedbyprovidingadiscussionoftheinverterratingdifferencesin

~the VP SYS SYSTER addendum. EA Electrical's review of the VP SYS SYSTER addendum, Revision I, found this action to be acceptable.

c. A System 82 CRAD drawing discrepancy was not identified from the project's supplemental walkdown data as incorrectly showing two spare breakers and not showing the breaker trip setting for the battery supply breaker. This was identified to the project in action item E-87. Theprojectrespondedbyincluding this discrepancy in the punchlist to ensure the CRAD is corrected and proposed to address this concern in the SYSTER 82 addendum. Theproject'sC/Aswerenot conplete for EA verification at the time of review and this action remains to be verified. (Observation El)

d. An AP SYS CRAD drawing was not identified from the project's supplemental electrical walkdown data as having a breaker setting discrepancy. This was identified to the project by action item E-88. Theprojectrespondedby initiating a drawing deviation form to ensure the CRAD is corrected and proposed to address this concern in the AP SYS SYSTER addendum. The project also proposed to re-review other breaker setting walkdown data against the CRADs to determine the extent of this problem. TheprojectC/AswerenotcompleteforEA verification at the time of review and this action remains to be verified.

(Observation EI)

e. A 480V SHON 80 circuit breaker nameplate data sheet from the WDP-AP-SI package had incorrect data recorded. ThiswasidentifiedtotheprojectbyactionitemE-80 and was discussed previously in the AP SYS walkdown review. Refer to section 5 above.

7.2.2-4 J

7.2.2.2 Conclusions The EA Electrical concluded that the project's of forts in assenbling, performing, and doctsnenting the system walkdowns were performed in accordance with the governing procedures and wore acceptable.

Because of EA concerns generated during the review of walkdowns, the project clarified procedures, initiated supplemental walkdowns to verify breaker settings, and performed additional rework of the AP SYS CRAD single-lines with STA involvement to identify potential drawing deviations previously overlooked. Subsequent to the completions of the remaining various project C/As and EA Electrical verification of their adequacy, the programobjectivesforwalkdownscanbeverifiedtohavebeenmet. (Observation EI) 7.2.2.3 References issue Reference Doctanent Revision Date Title i SQEP-08 4 12/9/86 Packaging and Controlling Walkcown/ Test Documentation 2 SMi-0-317-30 2 8/II/86 Special Maintenance Instruction Systems Walkdown 3 SQN45G7-048 2 8/6/86 Identification of Systems Required for Sequoyah Restari 4 WDP-67 (Unit 2) 1 6/9/86 Essential Raw Cooling Water (ERCW)

System 67 5 WOP-65 (Unit 2) 0 5/30/06 SafetyinjectionSystem63 6 WDP-46 (Unit 2) 1 5/21/86 Feedwater Control System 46 7 WDP-30E (Unit 2) 0 5/20/8C Ventilation - ERCW Pumping Station System 30 8 WDP-AP-Si 0 8/29/86 Auxiliary Power System AP (Units I and 2) 9 WDP-VP-DC-SI O 8/13/86 Vital Control Power System VP (Units I and 2) 10 SQEP-16 3 1/29/87 Procedure for System Evaluation and Development of System Evaluation Report 11 System Evaluation 1 3/16/87 Vital Control Power System Report, Addendtsn 12 Al-25 14 5/8/86 Adninistrative Instruction - Drawing Control After Unit Licensing 7.2.2-5

)

7.2.3 instrumentation and Controls System functional walkdown packages were reviewed by the IRC discipline of the EA Team (EA l&C) for technical adequacy, completeness, accuracy, and conformance to system walkdown procedures. Three system walkdown packages were selected as being representative of systems containing significant engineered safety features, a significant quantity of safety-related 18C components, and a mixture of fluid system control and electrical control features. Those walk (own packages were reviewed for:

a. Conformance to walkdown procedures SQEP-08 (reference 1) and SMi-0-517-30 (reference 2).

b. Completion of all portions of the systems as defined on the System Walkdown Boundary identification Drawings (SWBIDs).

c. Clarity and accuracy of recorded walkdown data,

d. Accurate identification and cross-referencing of supplemental sketches.

e. Adequacy of the walkdown scope in supporting the project objective.

7.2.3.1 Details Three walkdown packages were reviewed by EA l&C: the turbine-driven auxiliary feedwater pump (TDAFP) controls, WDP-46; Postaccident Sampling, WDP-43; and Component Cooling System, WDP-70 (references 3 through 5), in addition, EA I&C reviewed the scope of the walkdowns with regard to the electrical and l&C design features. Also, the NRC performed reviews of drawings used for walkdowns and participated in their own walkdowns to independently assess the adequacy of the project's results. The following presents the results of these reviews and NRC involvement:

1. Turbine-Driven Auxiliary Feedwater Puno (TDAFP) Controls The review of the TDAFP walkdown package WDP-46 (reference 5) resulted in the generation of four concerns:

a. Walkdown package drawing 797492 (reference 6) required a sketch of tbt physical mounting arrangement for component 2-51-46-568. The sketch included in the completed walkdown package incorrectly identified the component as 2-SI-46-548.

TheidentificationdisparitywasforwardedtotheprojectinactionitemI-01. The discrepancy was attributed to a recording error in transposing field walkdown data from the field working copy to the master sketch included in the walkdown package.

The concern was alleviated with the correction of the walkdown package master sketch. The revised master sketch was included with the project's written response and was found to be accurately revised.

7.2.5-1

b. Walkdown package drawing 47W610-46-1 (reference 7) included three hand switches and one transfer switch within the required walkdown boundary. The conpleted walkdown drawing did not indicate that the devices had been verified during the walkdown.

Action item l-03 was generated to address the concern. In addressing the concern, the project stated that it was not the intent of the walkdown plan to verify ISC conponents for which specific panel locations were not defined on the 47W610 series drawings since the location could not be verified if undefined, and the function of the components would be verified in the Electrical Test Results Evaluation portion of the program. EA ISC noted that the project's definition of walkdown scope, as it applied to such components, was not clearly defined in walkdown instruction SMI-0-517-30 (reference 2). The concern was resolved by providing appropriate requirements in procedure SQEP-14 (reference 8), the Electrical Test Results Evaluation. An EA ISC review of these requirements indicated that such devices would receive functional verification by evaluation of postmodification test results and surveillance test results. That approach was determined to be acceptable.

c. A review of the walkdown package indicated that some of the data recorded had been edited after the walkdown package had been issued. That practice appeared to be contrary to quality assurance drawing control requirements. The concern was issued in action item I-05. Thatconcernwasalleviatedwhentheprojectestablishedthat the data had been changed on a working copy revision to the walkdown package, before it became a QA record,

d. A review of the detail sketch for panel 2-L-381 Indicated that it was not referenced on the shift walkdown sunmary sheet, as required by procedure SMI-0-317-30 (reference 2). That concern was issued in action item I-06. The apparentproceduralviolationwasalleviatedwhentheprojectestablishedthatthe sketch in question was not required to be referenced in the shif t walkdown sunmary sheet since it was not a difference observed during the walkdown, but was supplemental information requested by the System Engineer. As such, EA l&C concurred that the sketch was not procedurally required to be referenced on the sunmary sheets.

e. A review of the field working copy of drawing 47W610-46-1 R8 (reference 7),

indicated that conponent XI-46-548 was observed as " missing 1.D. tag" during the walkdown. A review of the master copy of the same walkdown drawing indicated that the notation had not been transposed from the field working copy. The concern was forwarded to the project as action item I-02. Theprojectcorrectedthemaster drawing to include the omission and determined that it was a htsnan error in transposition.

2. Postaccident Samplina The Postaccident Sampling walkdown package WDP-45 (reference 4) was reviewed and was determinedtobetechnicallyadequateandincompliancewithprojectprocedures.

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3.' Consonent Coolina System The Component Cooling System walkdown package WDP-70 (reference 5) was reviewed and was determined to be technically adequate and in conpliance with project procedures.

4. Drawing Correlation As a result of reviewing the walkdown effort, the NRC initiated a concern regarding the lack of correlation between SQN mechanical control drawings and SQN piping drawings.

The control drawings depict instrument loops but do not identify each loop's corresponding root valve. The piping drawings identify root valves but do not identify corresponding instrument loops.

The concern was forwarded to the project in action item l-07 and was resolved by virtue of the SQN flow diagrams which identify both loop l.D. and root valve I.D., thereby providing a documented means of correlating the two.

5 Damaoed Equipment While conducting a component walkdown, the NRC observed a damaged conduit connection and missing component cover on panel RK OL 429. The concern was forwarded to the projectinactionitemI-45. It was resolved with the initiation of work requests to repair the equipnent. Since the concern was maintenance related and not design related, no further EA l&C verification was required.

6. Various Systems Areviewoftheproject'swalkdownscopebyEAl&Cindicatedthatitdidnotcontain sufficient attributes to verify the functional adequacy of electrical and l&C, as-constructed, design features. The scope of the walkdown program did not include physical verification of electrical terminations and instrument sensing line continuity. The absence of that verification was deemed to be a significant shortcoming in the walkdown portion of the program. This concern was issued in action item I-08. Afterextensivedeliberationwiththeproject,theconcernwasresolved based upon the following program clarifications and enhancements:

a. The project's electrical test results evaluation, as defined in SQEP-14 (reference 8), provided sufficient assurance that the as-constructed configuration of modified electrical circuits would allow them to perform their safety-related function.

b. The project's review of QA-verified records of terminations to modified plant wiring, and a supplemental walkdown to verify terminations to vital 120 VAC end 125 VDC power distribution boards.

c. The addition of a supplemental walkdown to ensure the continuity of as-constructed instrument sensing lines.

Thesupplementalwalkdownofsensinglineswascompletedbytheproject,andthe results were reviewed by EA l&C. The results provided adequate assurance that tnere was no pervasive as-constructed inadequacy in the plant's safety-related sensing lines.

7.2.5-3

7.2.3.2 Conclusions The project's system walkdown, although limited in its applicability to l&C and electrical plant features, was well executed, thorough, and technically sound. The ISC discipline of the EA Team concerns were minor and predominantly adninistrative in nature. With the clarifications and extension of scope described above, the walkdown effort met its objective of documenting the as-constructed configuration of plant systems.

7.2.3.5 References issue Reference Document Revision Date Title i SQEP-08 I 5/13/86 Packaging and Controlling of Walkdown/ Test Documentation 2 SMI-0-317-30 0 4/29/86 Systems Walkdown - Units 0, I, 2 3 WDP-46 1 5/3/86 Walkdown Package Feedwater Controls 4 WDP-43 0 5/3/06 Walkdown Package Postaccident Sampling 5 WDP-70 0 5/9/06 Walkdown Package Component Cooling System 6 797492 8 6/26/76 Control Instrumentation Enclosure 7 47W610-46-l 8 12/8/80 Mechanical Control Diagram Feedwater Control System 8 SQEP-14 0 5/15/06 Assembly and Evaluation of Electrical Test Results 7.2.3-4

7.2.4 Mechanical System walkdown packages developed in accordance with SQEP-08 (reference 1) were reviewed to verify the configuration of the process flow for mechanical fluid systems. Preparation of the walkdown package and thoroughness of the walkdown were evaluated for technical adequacy and conformance to program instructions. Specifically the walkdown packages were reviewed to determine if:

e the package boundaries included all arer of the system required to be walked down as defined in the SWBIDs (calculation SQN-OSG7-048).

e All supplementary information required by the SE was clearly defined.

e All information requested was obtained or identified to be unavailable, e Dif ferences found were clearly and thoroughly discussed, with supplementary infonnation provided on attached sketches where necessary, o The requiret reviews, including the STA review of differences found, were provided as documented ty the initials of the reviewers.

Functional wal<down packages were chosen from systems having central roles in the safe shutdown of fle plant and which have experienced changes since OL. Two of the earlier systems walke.1 down were selected so that problems found during their review could have a positive ir,sact on the walkdowns which followed. in addition, the Steam Generator Blowdown System (%B) was selected as being representative of a system for which portions must function to achieve containment isolation.

Supplemental walkdown packages were reviewed to the same technical and progran1matic attributes as the functional walkdown packages. The:e reviews focused on whether the additional information requested by SEs af ter their review of walkdown package results and ECNs was obtained and clearly described.

7.2.4.1 Details Four functional walkdown packages were reviewed: CSS, RHR, UHl, and SGB (references 2 through 5). The results of these reviews follow:

1. CSS System 72--Walkdown package WDP-72 R0 (reference 2) was reviewed. Preparation of the walkdown package was generally in accordance with SQEP-08 (reference 1).

Differences existed between the walkdown package boundaries and the boundaries as defined in the SWBID of calculation SQN-OSG7-048 (reference 6). For exanple, the walkdown package excluded the containment spray recirculation and air test lines which were within the system boundary on the corresponding SWBID. The concern that justificationhadnotbeenprovidedforexcludingthispipingfromwithinthewalkdown package scope was discussed in action item M-04. The project adequately addressed this concern by revising SQEP-16 (reference 7) to require SEs to provide justification in the SYSTERs of any dif ferences between the defined system boundaries and the SWBIDs. Later,theprojectremovedtheportionsofpipinginquestionfromtheSWBID to agree with the system boundary as defined in the walkdown package. This change in the SWBID boundary was documented in the boundary calculation (reference 6).

7.2.4-1

The inforation required by the walkdown package was documented as required except for two items: (a) that an attachment sheet to a shifI walkdown sunmary sheet did not reference the sunmary sheet to which li applied, and (b) the master copy drawing 47W812-1 Ril indicated that valve 2-12-544 had a cap installed, while shif t walkdown sunmary sheet 72-1 Indicated that the valve did not have a cap. These concerns were presentedtotheprojectinactionitemM-05. The project adequately addressed these dif ferences by issuing QA record change forms to reflect the correct configuration. in addition, walkdown team personnel were reminded of the need to ensure the accuracy of the information recorded in walkdown packages.

2. RHR System 74-44alkdown package WOP-74 R0 (reference 3) was reviewed. As in the CSS, differences existed tutween the walkdown package and the SW8lD. For example, walkdown package drawing 47W810-1 RI) (reference 8) did not include the refueling water return line which is included in the SW81D (reference 6). Theproject'sresolutionofthis concern, as discussed in action item M-05, was to expand the scope of the walkdown package in a supplemental walkdown to include the refueling water lines.

In addition, a difference was found outside the scope of the walkdown package which was not reported on the master copy of the drawing. Field copy drawing 47W810-1 RI) (reference 5, sheet 83) indicated that PT-68-64 as shown on the control room as-constructed drawing was tagged PT-68-66. The master copy of the drawing (reference 3, sheet 13) did not indicate a difference. There was also no shift walkdown sunmary sheet discussing the dif ference. This concern was presented to the projectinactionitemM-01. Discussionswithprojectpersonnelindicatedthatthe dif ference was not reported on the master copy of the drawing since PT-68-64 was within the scope of the RCS and outside the scope of the RHR package. The action item stated the concern that all differences found during walkdowns, regardless of whether they are inside or outside the walkdown boundaries, should be reported either in the walkdown package or by some other means to ensure that all differences found are evaluated.

This dif ference was also not reported in the RCS walkdown' package (reference 9). This was presented to the project in action item M-08.

Inresponsetotheseactionitems,theprojectinspectedtheinstrumentduring supplemental walkdown WDP-74-SI R0 (reference 8) and reported the differences found on shif t walkdown sunmary sheet 74-SI-17. In addition, SMI-0-317-30 R2 (reference 10) was revised to add the requirement that walkdown personnel identify all differences found during walkdowns whether or not they are within the scope of that walkdown package.

This adequately resolved these concerns.

Finally, it was noted that in certain cases information required to be verified as part of the " scope" section of a walkdown package was verified only by annotating the

" scope" section without the signatures of the parties that obtained the information (in this case, the orientation of flow elements FE-74-12 and FE-74-14). This concern was l presentedtotheprojectinactionitemM-02. Theprojectperformedareviewof walkdown packages previously prepared to identify attributes that had been documented in a similar nenner. Memos were written to engineering personnel informing them of the

) missing data so that they could request verification of the information in supplemental walkdown packages if they felt necessary, in addition, to pre /ent a similar problem fromoccurringinthesupplementalwalkdowns,theprojectrevisedSit-1(reference 11) to instruct all walkdown team leaders to identify the specific method to be used to verify each attribute requested in the package. Finally, the supplemental walkdown package verified the correct orientation of the flow elements FE-74-12 and FE-74-14 (reference 8, sheet 19). This adequately resolved this action item.

7.2.4-2

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3. UH1 System 87--Walkdown package WDP-87 R2 (reference 4) was prepared in accordance with SQEP-08 (reference 1) and the documentation of results was correct and conglete. The two revisions to the walkdown package deleted IAC and mechanical data sheets which were determined not to be desired for the initial walkdown.

4. SG8 System 15--Walkdown package WDP-15 R0 (reference 5) included the portion of the system within containment up to and including the outboard containment isolation valves. It was prepared in accordance with SQEP-08 (reference 1). The data requested (primary valve orientation and penetration nunt>ers) was properly taken and recorded.

No differences were noted from the drawings.

A general condition found during the review of these and other walkdown packages was that the applicable unit, i.e., SQN unit i or unit 2, was not specified. This concern was presented to the project in action item M-03. Theprojectadequatelyresolvedthis concern by revising SQEP-08 (reference 1) to require that unit I walkdown packages be labeled as unit 1, and unit 2 walkdown packages be given no unit designation.

Three supplemental walkdown packages were reviewed: WDP-38-SI, Auxiliary Feedwater System 38; WDP-32-S2, Control Air, System 32; and WDP-82-SI, Diesel Generator Starting Air and Auxiliaries, System 82 (references 12 through 14). Preparation of the packages was acceptable. Information requested was generally obtained with the necessary verification. Differences found were correctly identified on shift walkdown sunmary sheets. In the relatively few cases where it was not possible to obtain the requested information, that fact was clearly stated for evaluation by the SEs. The supplemental walkdown packages were found to be substantially improved over those of the original walkdowns.

7.2.4.2 Conclusions The mechanical review of the system walkdowns concluded that the project walkdown personnel performed a thorough and technically adequate walkdown of the systems.

7.2.4.3 References Issue Reference Document Revision Date Title i SQEP-08 2 5/29/86 Packaging and Controlling of Walkdown 4 12/9/% Test Documentation 2 WDP-72 0 5/18/86 Containment Spray System 3 WDP-74 0 5/22/06 Residual Heat Removal System 4 WDP-87 2 5/22/86 Upper Head injection System 5 WDP-15 0 5/3/06 Steam Generator 81owdcwn System f- SQN-0SG7-048 1 5/5/86 Identification of Systems Required for 2 8/6/86 Sequoyah Restart 3 1/6/87 7.2.4-3

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Issue Reference Document Revision Date Title 7 SQEP-16 3 1/29/87 System Evaluation and Development of System Evaluation Repor1 8 WDP-74-Si 0 7/29/86 Residual Heat Removal System (Supplemental) 9 WDP-68 0 5/7/86 Reactor Coolant System 10 SMI-0-517-30 2 6/4/06 Special Maintenance Instruction, System Walkdowns Units 0, I, and 2 ll Sit-l I 7/8/86 Section instruction letter 12 WDP-38-Si 0 8/8/96 Auxiliary Feedwater System (Supplemental) 13 WDP-32-S2 0 8/l/86 Control Air System (Supplemental) 14 WOP 42-Si 2 8/16/06 Diesel Generator Starting Air and Auxiliaries System (Supplemental) t 7.2.4-4

7.2.5 Civil System functional walkdowns were conducted to: (a) provide actual plant configuration of the process flow in order to establish the functional design acceptability of the system and (b) provide supplemental physical data, as required, for input to engineering ovaluations of modifications. Walkdown packages were developed by the project in accordance with SQEP-08 (reference 1). The performance of the walkdowns were executed in accordance with SMI-0-517-30 (reference 2).

The scope of the system walkdown was to provide information to verify the functional adequacy of the system. The walkdowns were generally not required to provide dimensional physical configuration data used for civil qualification analysis, unless specifically requested on a case-by-base basis for input to evaluate specific items.

Based on this scope, the EA Team's review of the civil scope included a progranmatic evaluation of compliance of the walkdown activities to the applicable procedures, and verification that the walkdown data which could impact the stress qualification of the system was properly addressed for adequate civil evaluation during the SYSTER review. The EA Team review of the walkdown process included system functional and supplemental walkdowns, verification walkdowns, and transposition of walkdown data from the shift walkdown sheets to the mester Walkdown drawings:

a. System Functional and Supalemental Walkdowns-System functional and supplemental walkdown packages were reviewed to verify that package preparation was in accordance with SQEP-08, and walkdown results were in accordance with SMI-0-517-30. Attributes of the review for package preparation included conpleteness and adequate definition of walkdown data requested, and proper civil approval / acceptance of the package. The walkdown evaluation included completeness and adequate documentation of gathered data requested in the package, verification of data by an independent QA organization, clear identification of walkdown dif ferences on a walkdown sunmary sheet with review by a STA for significance, and adequacy of training for walkdown personnel. The review concentrated on walkdown results which could have an effect on the stress qualification of the system. The selection of a functional walkdown package consisted of a representative cross-section of systems with a significant portion within the program boundaries.

The selection of the supplemental walkdown package was based on choosing one of the more significant systems from the functional walkdown packages reviewed.

b. Verification Walkdown-The EA Civil participated in an independent walkdown with the EA Team on the CCS for the purpose of verifying adequacy and conpleteness of the project results. This was acconplished by directly comparing EA walkdown results with the corresponding project walkdown results. The results of this walkdown are documented in section 7.2.6 of this report.

c. Transposition of Data to Master Drawinos-The EA Civil participated in a review of the accuracy and conpleteness of the project's ef fort to transpose the walkdown results from the shift walkdown data sheets to the master walkdown drawings.

1 7.2.5-I

7.2.5.1 Details The functional walkdown packages reviewed by EA Civil included SGB System (reference 3),

RHR System (reference 4), and the HVAC System (reference 5) conprising a mechanical, nuclear, and ventilation system, respectively. The supplemental walkdown package included the RHR System (reference 6).

The results of the walkdown evaluation by the EA Civil are provided below:

a. SGB System 15-The EA Civil conducted a review of the project walkdown of the SGB System (reference 5) and found it to be acceptable. The preparation of walkdown package WOP-15 was in accordance with SQEP-08 (reference 1) and adequately reviewed and approved by the Project Lead Civil Engineer. All documentation of the walkdown execution was properly signed and verified by QA/QC. No deviations were found and results were recorded in the package in an adequate manner.

b. RHR System 74-The EA Civil conducted a review of the project walkdown of the RHR System (reference 4) and found it acceptable. The preparation of package WDP-74 was verified to be in accordance with SQEP-08 and was adequately reviewed and approved bytheProjectLeadCivilEngineer. Documentation of the walkdown execution was properly signed off and independently verified by QA/QC. Discrepancies found were adequately described on the shif t walkdown simnary sheets and correctly color coded when detailed on the flow diagrams. Those discrepancies affecting the civil area of concern were clearly reported in the walkdown results for subsequent evaluation.

c. Ventilation System 508--The EA Civil conducted a review of project walkdown package WDP-300 (reference 5) for the portion connecting the emergency safety feature (ESF) coolers and found it acceptable. The preparation of the package was verified to be in accordance with SQEP-08. Applicable walkdown documentation was properly signed.

The walkdown data was independently verified by QA/QC and properly documented. The discrepancies found were properly documented on the shif t walkdown suninary sheets and applicable drawings. The data gathered was complete and addressed all the information requested in the package. The only data required for subsequent civil evaluation was the relocation of flow switches to assure that conponent qualification was maintained,

d. Supplemental Package for RHR System 74-Due to the civil scope of change document evaluation, supplemental walkdowns were not found to be reqJired for gathering dimensional data. Thepurposeofthecivilprojectreviewofwalkdowndatawasto identify areas of potential inpact on the stress qualifict. tion of the system.

The EA Team conducted a review of supplemental walkdown package WDP-74-SI (reference 6) for RHR and found it acceptable. The package was properly prepared in accordance with SQEP-08 and clearly described the additional information required by engineering. All data requested was adequately gathered and recorded on standard data sheets and shift walkdown sketch sheets. All documentation was properly signed and verified by QA/QC. All discrepancies were adequately described on the shif t walkdown sunnary sheets and detailed on applicable drawings, The data in the supplemental package requiring subsequent civil consideration was adequately detailed and included the following:

7.2.5-2

e Existing gaps were observed between pipe saddle legs and the pipe, and were evaluated as acceptable for the type of saddle used, e A piping reducer shown on a piping drawing was not found in the field, thus identifyingapotentialproblemwithactualpipesizesanalyzed.

e Additional high-point instrument vents were identified.

e Actual configuration of instrument sensing lines for FE-74-12 was provided, o The mounting location of two flow control valves was found to be different than originally expected.

The civil DB&VP involvement in tho walkdown ef fort was prinerily identification of discrepancies which could inpact the system stress qualification. Dimensional data was not required by the civil DB&VP group due to their reliance on a separate Civil Engineering Branch (CEB) Evaluation Program for establishing technical adequacy as detailed in section 7.5.5.

During the initial phase of the walkdown effort, the EA Civil also selected four separate walkdown packages--Main Steam System (WDP-01), High Pressure Fire Protection System (WDP-26), Postaccident Sangling System (WDP-43), and Waste Disposal System (WDP-77) (references 7 through 10)-to determine whether the data was accurately transposed from the shift walkdown data sheets to the master walkdown drawings.

Transcription discrepancies were cited in three of the packages (references 7, 8, and 9). Two discrepancy conments were not transferred from the nester package to the SE's copy, and one penetration nunter was miscopied. These discrepancies were presented to the project in action item C-01. Theprojectadequatelycorrectedthesediscrepancies by revising the packages and performed additional reviews to assure similar errors were adequately addressed. Therewerenootherdiscrepanciesfoundbytheproject.

A conflict was found between SQEP-08 and SMI-0-317-30. SQEP-08 identified that the walkdown verification for interconnecting piping was to continue to the first isolation valve. SMI-0-517-30 only required the walkdown personnel to verify up to the first component in the interconnecting run, thus not necessarily verifying the first isolation valve. This conflict was presented to the project in action item C-04. Theproject inplemented adequate C/A by directing the Discipline Evaluation Supervisors (DES) to perform supplemental walkdowns as necessary to assure the first isolation valve was verified, and revised SMI-0-517-30 to be consistent with the requirements of SQEP-08.

EA verified the adequate inplementation of the C/A.

7.2.5.2 Conclusions TheEATeamconciudedthattheprojectwalkdowneffortwasperformedinaccordancewith SQEP-00 and SMI-0-317-30. Walkdown data was complete and adequately recorded for subsequent identification of potential impacts for system qualification.

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7.2.5.3 References issue Reference Document Revision Date Title i SQEP-08 3- 6/27/06 Packaging and Controlling of Walkd a n/ Test Documentation 2 SMI-0-317-30 1 6/4/06 System Walkdowns - Units 0, I, and 2 3 WDP-15 0 5/20/06 Walkdown Package for Steam Generator Blowdown - System 15 4 WDP-74 0 5/22/06 Walkdown Package for Residual Heat Removal - System 74 5 WDP-300 0 5/20/86 Ventilation (ESF Coolers) - System 308 6 WDP-74-SI O 7/29/86 Supplemental W ikdown Package for Residual Heat Removal - System 74 7 WDP-01 0 5/23/06 Walkdown Package for Main Steam - System 01 8 WOP-26 0 5/20/06 Walkdown Package for High Pressure Fire Protection - System 26 9 WOP-43 0 5/3/86 Walkdown Package for Postaccident Sanpling

- System 43 10 WOP-77 0 5/7/% Walkdown Package for Waste Disposal -

System 77 7.2.5-4

7.2.6 Operations Enaineerina The Operations Engineering discipline of the EA Team participated in the system walkdowns 4

in two capacities: reviewing project functional and supplemental walkdown packages and performing an independent EA walkdown. The review of project walkdown packages incitded review for technical adequacy and conformance with SQEP-08 (reference 1), thoroughness of walkdown of the systems, and proper handling of discrepancies noted during walkdowns. The following project walkdown activities were reviewed:

a. The STA review of all shift walkdown sumery sheet line items for a PRO and impact on plant operations and industrial safety.

b. Initiation of a drawing deviation form (Attachment D to Administrative Instruction (AI)-25 (reference 2)] for instances where drawings do not reflect as-built conditions.

c. Routing of all drawing deviations to the Surveillance Instruction Review Group for review of drawing deviation inpact on affected sis and S0ls,

d. Initiation of various WRs/MRs to investigate or resolve discrepancies,

e. Initiation of SCRs where appropriate.

F. Rewalkdown of portions of walkdown packages to resolve discrepancies noted in data collection.

g. Inprovement in data-gathering requirements for supplemental walkdowns.

h. Re-review of auxiliary power single-line drawings to ensure that drawing deviations are reviewed by an STA for inpact on system operability.

The EA Team walkdown was performed to gather data independently and conpare these results withtheproject'sinthesameportionsofthesystem'swalkdown.

The NRC questioned the criteria used to select systems for EA walkdown. Action item 0-10 was initiated to document this concern. The EA Team responded by docisnenting the specific criteria that was used for the system selections. This criteria was incorporated in revision I of the EA Oversight Program Plan.

The following criteria were used in selecting systems for EA review of the walkdown packages:

a. System is included in the DB&VP boundaries,

b. Theentiresystemoramajorportionofthesystemisrequiredforsafeshutdown(not just " portion of the system required for containment isolation").

c. System contains a wide range of different conponents (piping, valves, valve operators, pwys, notors, instruments, hangers, and snubbers),

d. System is large and likely to contain a large nunter of discrepancies to be identified and recorded by the walkdown program.

7.2.6-1

e. System has been the subject of numerous IE bulletins, operating experience reports, etc.

f. System has had several modifications since OL.

The use of "as-designed" drawings in walkdown packages was questioned by the NRC and brought to the project's attention through action item 0-08. Theprojectsatisfactorily resolved action item 0-08 by responding that "as-designed" drawings were for information only or for walkdown when CRADs did not exist.

The NRC questioned whether S01s and emergency operating instructions had been considered when establishing system walkdown boundaries. Action item 0-13 was issued to raise the questionwiththeproject. Theprojectsatisfactorilyresolvedtheactionitembystating that ONP personnel familiar with system and emergency operating instructions were used to establish walkdown boundaries. A review by EA was made of the emergency operating instructions which confirmed instrumentation and valves used in the procedures were included in the system walkdown boundaries.

7.2.6.1 Details Two functional walkdown packages were reviewed by the EA Team: High-Pressure Fire Protection (reference 3) and Primary Water (reference 4) Systems. The results of these reviews follow:

1. Hich-Pressure Fire Protection System 26--Walkdown package WOP-26-U2 was reviewed and found in conformance with SQEP-08 (reference 1). All documentation of the walkdown was satisfactory and was properly signed of f by the preparers and QA/QC.

Discrepancies found were properly documented on shif t walkdown sumnary sheets and reviewed by the STA. No PR0s or revisions to Sis /S0ls were required as a result of discrepancies noted.

2. Primary Water System (81)--Walkdown package WDP-81-U2 was reviewed and found in conforrasnce with SQEP-08 (reference 1). All doctsnentation of the walkdown was satisfactory and was properly signed off by the preparers and QA/QC. Discrepancies were minimal, and no equipment was found to be different from that indicated on the flow diagram. A threaded nipple was found on test connection valve 2-81-529 and was clearly described on the shift walkdown sumnary sheet for resolution by issuance of a WR. No PR0s or revisions to Sis /S0ls were required as a result of discrepancies noted.

Three supplemental walkdown packages were reviewed: RHR System, CVCS, and SIS (references 5, 6, and 7, respectively). The results of these reviews follow:

1. RHR System 74--Supplemental walkdown package WDP-74-Si was reviewed and all data requested was correctly gathered, recorded on data sheets and shif t walkdown sketch sheets, and appropriately verified by a second party and QA/QC. High-point instrinnent vents were identified and added to drawing 47W600-93 (reference 8). A piping reducer shown between valves FCV-74-35 and HCV-74-34 on drawing 47WBl0-1 (reference 9) was not found and was marked in green on drawing 47W810-1 to indicate it did not exist. No PR0s were required as a result of discrepancies noted.

7.2.6-2

2. CVCS 62--Supplemental walkdown package WOP-62-SI-U2 was reviewed. It was noted that portions of the system that were not walked down during the functional walkdown were later walked down to gather specific data for flow elements, instrument sensing lines, flow control valve (FCV) status monitoring lights, and containment penetrations. All data requested was correctly gathered, appropriately verifled by a second party, and signed by QA/QC. There were 14 valves not shown on the flow diagram, and valve nameplate data sheets were filled out for these valves. No PR0s were required as a result of the discrepancies noted.

3. SIS 63-Supplemental walkdown package WDP-63-SI-U2 was reviewed. Several areas not walked down as part of the functional walkdown were later walked down to gather flow element, valve nameplate, and containment penetration data. All data requested was correctly gathered except for setpoint data for relief valve 2-RV-65-511. The resetting of 2-RV-65-Sil and replacement of pressure gauges to raise the system design pressure are being acconplished under ECN L6570, and it is unnecessary to verify the present setting of 2-RV-63-Ril. Check valve 2-65-553 had flow in the downward direction, which has been addressed by the SE in the SYSTER. All data gathered was appropriately verified by a second party and signed by QA/QC. No PR0s were required as a result of discrepancies noted.

Seven portions of systems were walked down by the EA Team to independently collect data to conpare directly with the results gathered by the project. The systems for which EA Team walkdowns were conducted included: Auxiliary Feedwater, Component Cooling, Contaltunent Spray, mechanical and electrical portions of Diesel Starting Air, Vital DC Power and 480 Volt Auxiliary Power (references 10 through 15, respectively). The results of these comparisons follow:

1. Auxiliary Feedwater System 0)8-The EA Team walked oown a portion of the unit 2 Auxiliary Feedwater System for comparison with project walkdown resulls; the portion walked down included 2A-A and 28-B motor-driven auxiliary feedwater pumps, the 2A-S TDAFP, and unit 2 auxiliary feedwater piping from the ERCW supply connections through to the containment penetrations on SG loops 3 and 4. The NRC questioned the EA Team's use of an "as-designed" drawing for the EA walkdown for system 038. Action item 0-12 was initiated and answered by EA to document the fact that the poor quality of the "as-constructed" issue of the drawing led the EA Team to use the "as-designed" issue of the drawing for the walkdown. A comparison of the two drawings showed no difference in the areas used for the walkdown. All piping and equipment were walked down in accordance with SQEP-08 (reference 1) and SMI-0-317-50 (reference 16). In general, there was an agreement between EA Team results and the project results, except for isolated instances, in each of these instances, the dif ferences were minor and did not lead to a conclusion that would discredit the project results. The following differences were noted:

a. The EA Team results noted that various pressure switches, transmitters, and local indicators were configured differently than shown on flow diagram 47WB03-2 (reference 17) downstream of the Instrument line first root valve. Ilowever, throughdiscussionswithprojectpersonnel,itbecameevidentthatTVAflow diagrams show instrunent lines accurately only up to the first instrument line root valve. Mechanical control drawings are used to depict instrunent configuration downstream of the instrument line root valve. The auxiliary feedwater mechanical control drawings were reviewed and found to accurately reflect the instrument configuration in question. The noted discrepancies were therefore outside the scope of the flow diagram and were not valid.

7.2.6-3

b. The EA Team noted that instrument root valve labels for 2-PT-3-145 and 2-PT-3-168 (valves 5-325A and 5-334A, respectively) were apparently interchanged.

Investigation by Plant Operations determined that the instrument sensing lines were routed to the wrong pressure transmitter (i.e., SG loop 3 auxiliary feedwater pressure was being sensed by 2-PT-3-168, and SG loop 4 auxiliary feedwater pressure was being sensed by 2-PT-5-145). The EA Team was concerned with the potential significance of incorrectly routed instrisnent tubing and initiated action item 0-05 to track the problem and its resolution. Project investigation of the problem was initiated as a result of walkdown package WDP-058-U2, item 3-33. ProjectinvestigationviaworkrequestWRl22978 determined that 2-PT-3-145 and 2-PT-3-168 had the correct electrical hookup (i.e., 2-PT-)-145 was sending a signal to loop 5 readout on the trend log, and 2-Pf-5-168 was reading out on loop 4 on the trend log). Maintenance request MR8122918 was used to correct the tube routing problem by retubing the sensing lines to the correct pressure transmitters. Al-25 drawing deviation 8600412 was issued to document the tubing error. STA review of the discrepancy did not result in a PRO, as 2-PT-3-145 and 2-PT-3-168 have no control function and are not used for operator information. These instruments are used solely to record pressure on the event recorder trend log. The discrepancy was satisfactorily corrected.

Walkdown package WOP-058-U2 contained several "information only" drawings which had confusing boundary markings. Thiswasbroughttotheproject'sattention through action item 0-04. Satisfactory resolution of action item 0-04 included review of the system 50 SYSTER to confirm the boundaries of the system evaluation agreed with SWBID boundaries.

The EA Team also reviewed the project supplemental walkdown of the Auxiliary Feedwater System. Discrepancies noted on the original walkdown of the Auxiliary Feedwater System, such as nameplate data and sanple line configuration, were adequately addressed by the supplemental walkdown.

2. CCS 70--The EA Team walked down a portion of the CCS for conparison with project walkdown results; the portion walked down included the IA, IB, C 2A, and 28 CCW pumps; CCW heat exchanger B; and piping from heat exchanger B to waste gas compressor heat exchanger B and back to the CCW pungs.

[ Refer to flow diagram 47WB59-1 (reference 18).] Results of the EA CCS walkdown were conpared with the results of the project walkdown and were, in general, found to be in agreement except for the following minor dif ferences, which required further investigationbytheEATeamorresultedinprojectactiontocorrect:

a. A sanple chiller package was added to the CCS and was reflected in revision 6 to flow diagram 47W859-5 (reference 19). A temperature control valve (TCV) on the outlet line of the sanple chiller is not shown on 47W859-3. The TCV was noted duringtheprojectwalkdown;however,nonameplatedatafortheTCVwasrecorded (refer to WOP-70, item 70-26). Thisdiscrepancywaspresentedtotheprojectin action item 0-01. To resolve this discrepancy, the Project 'bikdown Manager sent a nura to the CCW SE requesting the nameplate data be gathered in a supplemental walkdown of the CCW if deemed significant by the SF. The TCV is included in the sanple chiller " package" and is, therefore, not required to be show, on the CCW System flow diagram.

7.2.6-4

b. An inconsistency in filling out breaker position data sheets during project walkdown of CCW was noted. Thisinconsistencywasdirectedtotheprojectin action item 0-02. The problem was due to one walkdown crew misinterpreting the walkdown package instructions on " caution label" terminology. A recheck of the breakers by another crew resulted in corrected data sheets being issued. To prevent recurrence of the problem, additional directions were given verbally to all walkdown crews regarding interpretation of walkdown package instructions.

c. Containment penetration data sheets did not have signoffs noted and documented forindividualpenetrations;thisdiscrepancywaspresentedtotheprojectin action item 0-05. Projectwalkdownpersonnelrevisedthedatasheets(tobe consistent with mechanical, electrical, and l&C data sheets) to include one signature blank for the walkdown team menter and one signature blank for QA/QC for the entire data sheet.

5. CSS 72--The EA Team walked down a major portion of the unit 2 CSS for conparison with projectwalkdownresults;theportionwalkeddown,shownondrawing47WB12-1 (reference 20), included trains A and B from FCV-72-22 and FCV-72-21 to containment penetrations, 2-inch air test line, 0-inch crosstie and recirculation line back to the refueling water storage tank (RWST) and CSS pung 2-inch mininun flow recirculation lines. The EA Team walkdown results of the CSS were conpared with project walkdown results and in general were in agreement, except in the following areas, which required further investigation by the EA Team or resulted in project action to correct:

a. Locking devices on CSS pung discharge valves 72-555 and 72-554 were present but not in use. This discrepancy was not noted during the project CSS walkdown.

Plant operations personnel indicated that alignment of valves will be acconplished during the required prestartup valve position verification; the project action was considered acceptable to resolve this discrepancy.

b. During walkdown of the CSS system, the EA Team noted that the monorail hoist in the 28-8 CSS pung cubicle was parked directly over the CSS pung coupling.

Although not part of the walkdown package scope, this was an unsatisfactory condition as the monorail cranes are nonseismic and should be parked and restrained away from safety-related equipment when not in use. This discrepancy wasnotnotedduringtheprojectwalkdownandwasdirectedtotheprojectin action item 0-20. SCR$QNMEB0675 was issued to relocate nonseismic equipment issued by the project to resolve the problem. As a result of the issuance of SCRSQNME80675, calculation SQEP-C2-62 was performed by CEB to seismically qualify the hoists and trolleys located over safety-related equipment. Theproject action to resolve this discrepancy was considered acceptable.

l c. The flexible shaf ts on the CSS pmp remote-operated vent valves appeared to

! have a bend radius less than the 15-inch radius allowed by drawing 47W457-6 l (reference 21). Thisconditionwasnotnotedduringtheprojectwalkdown.This l discrepancy was directed to the project in action item 0-19. Work requests WRl07920 and WRl07921 were appropriately issued to check and correct the problem.

l 1.2.6-5 l

4. Diesel Startina Air System 82-The EA Team walked dowa a portion of the Diesel Starting Air System. The portion of the system walked da n was on DC-IA-A engine and conpressor lA2 with a spot check of some of the identifiod concerns on the other seven diesels (refer to drawings 4MH39-1 (reference 22) and 4M610-02-1 (reference 23)]. There were no differences noted in a conparison of the EA Team results with theproject'sresults.

5. Vital DC power 400-Volt Auxillary power. Diesel Startina Air Systems 249, 201, and 82-The EA Team walked down a portion of the Vital DC Power, 480-Volt Auxiliary Power, and Diesel Starting Air Systems (referencer 14, 15, and 13, respectively).

The EA Team walkdown was limited to a sampling or the electrical boards and conpartments which were identified in the project's supplemental walkdowns as potentially having discrepancies. The EA Team walkdown also included vital power CRADs 45N70)-2 (reference 24) and 45N709-4 (reference 25) which had been intentionallyexcludedfromtheprojectwalkdown. Four discrepancies were found by the EA Team that had not been noted by the project. These included the following:

1

a. CRAD 45N709-2 (reference 24) did not reflect a cable ID suf fix "S". Vital inverter neoplate data appears to conflict with the VP SYSTERs evaluation of ECNs L5118 and L2662. This discrepancy was directed to the project in action item E-86. Theproject'sresponseandtheEATeam'sdispositionarediscussedin section 7.2.2.2.

b. CRAD 45N727 (reference 26) did not reflect actual configuration. This discrepancy was presented to the project in action item E-87. Theproject's response and the EA Team's disposition are discussed in section 7.2.2.2.

c. CRAD 45N749-2 (reference 27), 400-Volt SHDN board 2A2-a canpartments SD and 90, did not reflect the actual circuit breaker long-delay trip settings. The discrepancy was presented to the project in action item E-88. Theproject's response and the EA Team's disposition are discussed in section 7.2.2.2.

The NRC raised several issues related to system walkdowns in general which were brought to the project's attention through action items. Action item 0-14 raised the question of how much detail is shown in "out-of-function" areas of drawings. This issue was also addressed and satisfactorily responded to in NRC Observation 7.1. The projectissuedapolicymemorandum(RIMSB25870130014) concerning out-of-function infornation on drawings which satisfactorily closed action item 0-I4 and NRC Observation 7.1.

l Action item 0-15 was issued to document NRC concern over differences between unit l and unit 2 walkdown boundaries. Theprojectsatisfactorilyresolvedthisactionitem by issuing a supplemental walkdown package for the unit 2 RHR System and adding a clarifying statement to the auxiliary feedwater walkdown package.

t Action item 0-16 was issued to document NRC concern regarding Plant Operations review of walkdown data for potential inpact on operating instructions and surveillance Instructinns. The project satisfactorily responded to action item 0-16 by noting the STA review of all walkdown discrepancies, in addition, all drawing deviations which resulted from the system walkdowns are reviewed for inpact on surveillance instructions and operating instructions by the Surveillance Instruction Review Group.

7.2.6-6

7.2.6.2 Conclusions The project system walkdown results as found were thorough, technically adequate, adequately documented, and in compliance with SQEP-08 (reference 1) and SMI-0-517-30 (reference 16).

7.2.6.5 References issue Reference Document Revision Date Title i SQEP-08 5 6/27/06 Pack 3ging and Controlling of Walkdown/ Test Documentation 2 Al-25 14 5/8/86 Administrative instruction - Drawing Control After Unit Licensing 3 WDP-26-U2 -- -

High-Pressure Fire Protection System 26 Walkdown Package 4 WDP-81-U2 -- --

Primary Water System 81 Walkdown Package 5 WDP-74-SI-U2 -- -- Residual Heat Removal System 74 Walkdown Package 6 WDP-62-SI-U2 -- -

Chemical and Volume Control System 62 Walkdown Package 7 WDP-63-SI-U2 - --

SafetyinjectionSystemWalkdownPackage 8 47W600-95 11 7/22/86 Mechanical Instruments and controls 9 47W810-1 15 6/II/83 Flow Diagram Residual Heat Removal System 10 WDP-03B-U2 -- --

Auxiliary Feedwater System 038 Walkdown Package 11 WDP-70-U2 -- --

Conponent Cooling System 70 Walkdown Package 12 WDP-72-02 -- -- Containment Spray System 72 Walkdown Package I) WDP-82-02 -- --

Diesel Starting Air System 82 Walkdown Package 14 WDP-249-SI-02 -- -

Vital DC Power System 249 Walkdown Package 15 WDP-201-U2 -- - Auxiliary Power 480V System 201 Walkdown Package 16 SMI-0-317-30 1 6/4/06 Systems Walkdown - Units 0, I, 2 17 47W803-2 26 7/31/85 Flow Diagram Auxillary Feedwater 7.2.6-7

issue Reference Document Revision Date Title 18 47W859-1 14 AC-R 4/29/06 Mechanical Flw Diagram Component Cooling System 19 47W859-3 18 7/27/82 Mechanical Flw Diagram Cormonent Cooling System 20 47WB12-1 11 AC-S 4/26/86 Flow Diagram Containment Spray System

?! 47W437-6 l}AC-C 7/19/81 Mechanical Containment Spray System Piping 22 47W859-l 8 3/30/84 Flow Diagram Diesel Starting Air System 23 47W610-82-1 6 11/5/84 Mechanical Control Diagram Diesel Starting Air System 24 45N709-2 5 6/12/84 Wiring Diagrams, Chargers, inverters, and Miscellaneous Equipment Connection Diagrams -

Sheet 2 25 45N709-4 4 7/27/84 Wiring Diagrams Chargers inverters and Miscellaneous Equipment Connection Diagrams -

Sheet 4 26 45N727 8 3/9/81 Wiring Diagram 6900V Diesel Generators Single Line 27 45N749-2 23 12/30/83 Wiring Diagrams 480 V Shutdown Board IA2-A Single Line l

I l

I l

7.2.6-8

7.2.7 Quality Assurance The QA discipline of the EA Team reviewed the adequacy of implementation and controls of the D84VP system walkdown program. This enconpassed verifying the following walkdown program attributes: adequate progranmatic instructions, appropriately trained and quallfled walkdown personnel, adequate controls of required reviews and approvals of walkdown documents, and proper doctanentation and evaluation of identified walkdown deficiencies.

This review was acconplished in conjunction with the site QA organization through review of recent QA surveillances of the walkdown program. These surveillances ef fectively addressed the progranmatic aspects of the walkdown program.

7.2.7.1 Details EA QA participated in the review of walkdown activities on a surveillance basis, and a review of functional and supplemental walkdown packages.

EA reviewed completed walkdown packages (WDPs) for Systems 62 and 63 (references I and 2) for conpliance with SQEP-08 and SMI-0-517-50 (references 5 and 4). Also, walkdown activities performed on walkdown package WDP-70, unit 2 (reference 5), were observed.

During performance of the EA QA surveillances (references 6 and 7), several concerns were noted pertaining to inadequate reviews and approvals, missing or incorrect documentation, drawing / plant configuration inconsistencies, and inadequate verifications. Discrepancy reports (DRs) (references 8, 9, and 10) were generated and submitted to the project in action items Q-01, 0-02, and Q-04. All these problems have been subsequently corrected (by correcting doctsnents, by providing additional training, etc.) and verified, and the action items were therefore closed by EA. The details of this review and observations of the walkdown process are presented in QA Surveillance Reports 21-86-S-014 and 21-86-S-020 (references 6 and 7).

EA QA also participated in a supplemental walkdown review with the Electrical discipline. The detalls and findings of this joint activity are presented in subsection 7.2.2.

7.2.7.2 Conclusions Based upon the results of the EA Team's reviews, QA surveillances, and observations, the walkdown program was considered to be adequate, ef fective, and well-inplemented.

7.2.7.) References issue Reference Document Revision Date Title I WDP-62 0 - Unit 2 - Walkdown Package for System 62, Chemical and Volume Control 2 WDP-63 0 5/30/86 Unit 2 - Walkdown Package for System 6),

Safetyinjection 7.2.7-1

1 e

f

, Issue Refarence Document Revision Date Title 3 SQEP-08 l~ 5/13/86 Packaging and Controlling Walkdown/ Test Documentation 4 SMI-0-317-30 1 6/4/06 Special Maintenance Instruction, System

. Walkdowns - Units 0, I, and 2 5' WDP-70 0 5/9/06 Unit 2 - Walkdown Package for System 70, Conponent Cooling 6 2f-06-S-014 0 - QA Surveillance Report 7 21-06-S-020 0 -

QA Surveillance Report 8 SQ-DR-86-06-135R 0 7/1/06 QA Discrepancy Report 9 SQ-DR-86-07-140R 0 7/24/06 QA Discrepancy Report 10 SQ-DR-86-154R 0 8/25/86 QA Discrepancy Report t

l 7.2.7-2

7.) Ccuparison of As-Designed Drawines with lisikdown Results The D64VP SEs reviewed the CRADs that were marked up as a result of the system walkdowns (SMI-0-317-30). The CRADs were compared to the as-designed drawings and the results evaluated to determine if additional information was to be obtained in a supplemental walkdown. Dif ferences were identified and recorded on the Drawing Comparison Results/Dif ferences Form in accordance with SQEP-19. This comparison information was used later by the SE for system evaluations.

The EA Team reviewed the recorded differences for accuracy and conpleteness. The team review was performed by the Operations Engineering discipline, and the results are presented in section 7.3.1.

7.3-1

7.3.1 Operations Engineering EA Operations Engineering reviewed: (a)projectcomocrisonsof"as-designed" drawings with CRADs in accordance with SQEP-19; (b) documentation of project conparisons, in the form of attachments to SQEP-19 conpleted by the reviewer, for thoroughness and proper identification of drawing differences; and (c) the need for supplemental walkdown information, when applicable.

7.3.1.1 Deialis Four drawing comparison packages were reviewed for the following: Auxiliary Feedwater System, CVCS, RHR System, and CSS. The results of the FA Operations Engineering review follow:

1. Auxiliary Feedwater System 38-There were 24 differences noted and documented on the appropriate attachment to SQEP-19 (reference 1). EA reviewed each dif ference and agreed that all were identified and adequately documented with appropriate explanations. All differences were identified on the drawings, and a " description of difference" was clearly noted on the comparison results/dif ferences form. The additional information requirements consisted of 12 items to be resolved by supplemental walkdown. Drawing discrepancies were resolved through the Al-25 (reference 2) process. Doc eents were properly signed and personnel acequately trained.

2. CVCS 62--There were 66 dif ferences noted and documented on the appropriate attachment to SQEP-19 (reference 1). EA review revealed that note 17 on drawing 47W809-1 (reference 3) had been deleted by the " preparer." Note 17 concerns reducers found installed during system walkdown but not shown on the "as-designed" drawing. The

" preparer" could not recall why note 17 was deleted and subsequently reinstated note 17 on drawing 47W809-1 (reference 3). There were 6 items identified for additional information to be gathered during a supplemental walkdown. The dif ferences identified were adequately documented with appropriate explanations.

Documents were properly signed and personnel adequately trained.

3. RHR 74--There were 31 dif ferences noted and documented on the appropriate attachment to SQEP-19 (reference 1). All differences noted were miner and were resolved through the drawing revision process. EA reviewed each difference and agreed that each was identified and adequately doctsnented with appropriate explanations. Themajorityof drawing dif fereaces were either valve stem leakoff lines not shown (14 instances) or pressure indicators located in a different place from that shown on the drawing (6 instances). No additional information was required. Documents were properly signed and personnel adequately trained.

4. CSS 72-There were 19 dif ferences noted and documented on the appropriate attachment to SQEP-19 (reference 1). Dif ferences noted were mainly test connections and test connection valves not shown on the CRAD. EA reviewed each difference and agreed that each was identified and adequately documented with appropriate explanation. Drawing revisions will be used to resolve the discrepancies. No additional informailon fran a supplemental walkdown was required. Documents were properly signed and personnel adequately trained.

7.3.1-1

7.3.1.2 Conclusions The project drawing conparison was adequate in that all dif forences were identified and accurately documented on drawings, and was acconplished in accordance with SQEP-19 (reference 1).

7.5.l.5 References issue Reference Doctanent Revision Date Title i SQEP-19 0 5/25/86 Conparison of Control Room As-Constructed Drawings to As-Designed Drawings 2 An-25 14 5/8/86 Administrative Instruction - Drawing Control After Unit Licensing 3 47W809-1 24AC-AA I/21/85 Flow Diagram Chemical and Volisne Control System 7.3.1-2

7.4 Electrical Test Results Evaluations As required by SQEP-14, "Assenbly and Evaluation of Electrical Test Results," ECN modifications and FCN modifications within the boundary of the DB&VP were evaluated to ensure that adequate test dacumentation existed that provided evidence that the safety-related systems and cogonents can perform their safety function 3. Test documentation included postmodification testing, functional testing, and surveillance instruction results. The preoperational test " test results" established the " functional" baseline for safety-related systems and cogonents at the time of issuance of the OL. These tests results were utilized, as required, to substantitte the " functional" basis of the modifications. Reviews were performed on iglemented, partially iglemented, and uniglemented modifications required for restart. Where appropriate, scoping documents for conducting additional tests were prepared in cases where the available test results could not support a modification.

The EA Team reviewed the results from this evaluation to ascertain the technical adequacy of the project's decision for justifying test results supporting modifications and/or developnent of appropriate scoping docunents for additional testing. The results from Electrica!, IRC, Operations Engineering, and QA, which reviewed the electrical test evaluations, are presented in sections 7.4.I, 7.4.2, 7.4.3, and 7.4.4, respectively.

7.4-1

t 7.4.1 Electrical TheElectricaldisciplineoftheEATeam(EAElectrical)reviewedtheproject'seffortsin assentling and evaluating the electrical and ISC portions of ECN modifications within the boundary of calculation SQN-OSG7-048 (reference 1). The project's assently and evaluation of electrical test results were performed in accordance with SQEP-14 (reference 2) and SQEP-57 (reference 3). The EA review was performed to assess the project's work under SQEP-14 and SQEP-57 and their rationale for decisions made on the technical adequacy of tests, and to ensure that adequate test documentation was identified to support the conclusion that the safety-related components within the system boundaries of calculation SQN-OSG7-040 can perform their safety functions. Theproject'stestevaluationsweredone on an ECN basis and were to provide justification for the functional adequacy of the electrical /l&C nodifications of previously performed tests and test results.

Theelectricalreviewenconpassedtheresultsoftheproject'selectricaltestevaluation effort in the following areas:

e Assently of appropriate tests and other support information for test evaluation.

e inclusion of applicable portions of the ECN and workplans in the test evaluation package needed to support the conclusion reached, o Review of test evaluation results to ensure that the safety systems / components can perform their safety function.

e Technical adequacy of retest scoping docunents.

e Projected testing for unimplemented/ partially implemented ECNs.

e Red-line process of marking up and conparing preop schematic drawings with appropriate as-constructed schematics.

The ECN documents chosen for the electrical test review and evaluation were selectively screened from those available to the electrical test review SEs. The following criteria l

were used as a guide in screening the various ECN documents:

l l e The ECN document content was nontrivial in nature and was within the electrical discipline scope of review.

e The ECN document had 1he potential for having significant electrical equipment modifications or system inpact.

e Several ECN doctanents with the potential for requiring different types of electrical testswerechosentoconfirmthethoroughnessoftheproject'sprocess.

e One ECN was chosen from the CSS as part of the sample of 15 for the test evaluations.

e Six drawings covering five systems were randomly chosen to verify the red-line process of marking up and comparing preop schematic drawings with appropriate as-constructed schematics.

q 7.4.1-1

7.4.1.1 Details EA Electrical reviewed 15 ECNs and 6 red-line drawings to determine the adequacy of the project'selectricaltestevaluations. The review of the progranmatic aspects of the assently and evaluation of electrical test results in general verified that the procedure in SQEP-14 was adequate to perform this task. However, there were two concerns raised regarding a question of who was responsible for reviewing and accepting the test / retest results and a question regarding the handling of test and retest results between the 00&VP and the plant System Engineering Section. These concerns were directed to the project in action items E-67 and E-70. The project satisfactorily addressed these questions by issuing SQEP-57. This procedure provided the additional definition and guidance needed to address the interface between the project and the plant System Engineering Section and defined the levels of approval required for tests / retests. EA Electrical verified the answers to the questions in action items E-67 and E-70 in a further review of both SQEP-14 and SQEP-57.

Results of the review are sunmarized below:

1. ECN LS872 (Reference 4) - Diesel Generator (DG) Buildina Ventilation System 300GB-The scope of this modification consisted of adding a fan and associated ductwork in each DG room to provide cooling for each DG and its electrical control cabinet. Parts of workplans 10506, 10516, and 10541, including postmodification test FMT-33, were included in the test evaluation package to describe the electrical .

Installation and testing. The project's evaluation concluded that PMT-33 adequately demonstrated operability of the fans and when conpleted, af ter final installation of local handswitches, PMT-33 will provide satisfactory proof of operability. Although this evaluation supported the majority of the scope of the ECN, the test results did not verify fan operability from the main control room (MCR), inasmuch as there was no annunciation signal verifying fan operation in the MCR. This lack of indication of adequate fan operability in the MCR could potentially result in a DG failure.

This concern was noted in EA action item E-50. TheprojectinitiatedPIRSQNEEB0694 (reference 5) which was upgraded to SCRSQNEEB8728 (reference 6) to address this concern. The disposition and corrective action for this SCR are discussed in section 7.7.2.1

2. ECN 2774 (Reference 7) - Auxiliary Feedwater System 38--The scope of ECN 2774 was to replace the existing motors on motor-operated valves (MOVs) 2-FCV-16 and 2-FCV-18 with 25 foot-pound (f t-lb) 1.6-horsepower (hp) motors per Nonconforming Condition Report (NCR) 2518 (SQN 810106 006). Workplan 9329, including the test results of (a) stroke testing per Sls 166.1 and 166.3, (b) motor meggar checks, and (c) motor rotation, was included in the system test evaluation package (STEP) to describe the electrical installation and testing. The project's evaluation results adequately document that the testing performed on the MOVs following the installation of the new motors had sufficiently verified that these MOVs are capable of performing their intended safety function. No further testing was required to ensure the operability of the replacement motors installed under ECN 2774.

7.4.1-2

3. ECN L5591 (Reference 8) - SIS 63-ECN L5591 involved rewiring the internal circuits of the Westinghouse type W-2 control switches mounted on unit control board 2-M-6 to monitor switch contact continuity in the spring return to "A-AUT0" position.

This modification was required in order to fulfill a TVA conmitment to NRC in IE 8ulletin 80-20 (NEB 820405 266) (reference 9). Workplan 10114 contained in the STEP provided in<,tructions for rewiring and testing of the control switches.

Theproject'sevaluationofthetestresultsindicatedthatthebenchtesting acconplished under workplan 10114 was insufficient to prove that the modified switches have not degraded the capability of the system to perform its intended safety function. As such, an additional test was required to functionally test each modified switch at its reinstalled position to ensure circuit continuity through the mated connector; this was acceptable. The scoping docunent for the proposed additional testing included in the STEP was reviewed by EA Electrical and was found to be technically adequate. However, it was noted that the test evaluation reviewer also appeared to be the technical supervisor, which is in violation of Nuclear Engineering Procedure (NEP)-5.2. This concern was adequately addressed by the l projectandisdiscussedfurtherinitem10. The results of the retest as proposed l above were reviewed and found to be acceptable.

l

4. ECN L5158 (Reference 10) - Standby DG System 82--The purpose of ECN L5158 is to replace the existing 125-V DC DG batteries, Exide 3KXHS-9 and associated battery racks, with the new CSD 30CU-9 batteries and 2-step battery racks. Part of workplan 9119, revision I, including the test results from SI-238.2 was included in the STEP. Theprojectevaluationindicatedthatthenewbatterymetthedesign criteria and that no additional testing was required to verify the acceptance of the new batteries and battery racks; this was acceptable. However, the evaluation failed to address whether the new battery system could~ perform its intended safety function. In reviewing applicable workplan instructions, it was noted that tae new DG battery system had been functionally tested to verify that the associated diesel starts after the appropriate battery charger had been turned off for 30 minutes. EA Electrical concluded from this test result that the new battery system installed under ECN L5158 would successfully perform its safety function.

5. ECN L5298 (Reference 11) - ERCW System 67-This ECN involved rerouting Train "B" ERCW pung motor power cables and ERCW pumping station transformer power cables.

Part of workplan 8757, revision I, including functional tests (Fis) was included in the STEP. The testing conducted on the pump motors af ter the installation of the powercableshadbeenevaluatedbytheprojectandfoundacceptableasdocumentedin the SQEP-14 evaluation. The project's evaluation of the testing performed on punging station transformers concluded that additional testing was required to verify that these transformers can supply lE power on correct phases. An EA Electrical review of the scoping document for the reconmended additional testing found that SNI-2A (Relay Current Measurement for Overcurrent Relay) was incorrectly referenced in the test sunnery. This SMI is not adequate to verify that the proper i phase connections were made in accordance with the workplan. Action item E-78 was I issued to bring the error to the attention of the project. In responding to this action item, the project generated a test review change form which deletes the wrong SMI from the scoping docunent and redefines minimum testing requirements for the transformers in question. These testing requirements were reviewed by EA Electrical and were considered to be technically adequate.

7.4.1-3 l .. .

6. ECN L6295 (Reference 12) - Reactor Protection System (RPS) 99-ECN L6295 covered the inplementation of Westinghouse Owner's Group (WOG) generic design modifications to provide automatic actuation of the breaker shunt trip attachments to increase the RPS reliability. PMT-74wasevaluatedbytheprojectandfoundtobeacceptable.

However,theproject'sevaluationresultsdidnotaddresswhetherthepodified system could perform its safety function as called for in SQEP-14. In reviewing the results of PMT-74, it was noted that the testing did verify that:

e An automatic reactor trip signal generated from the Solid-State Protection System was capable of initiating a reactor shunt trip through the breaker automatic shunt trip attachments, e The breaker shunt trip and undervoltage trip could be tested independently.

These test results adequately proved the capability of the modified RPS to perform its intended safety function. No further testing was required to demonstrate the acceptance of the changes performed under ECN L6295

7. ECN L6544 (Reference 15) - CSS 72--The scope of ECN L6544 consisted of deleting "jumpered out" limit switches, removing valve heaters per SCRSQNEQP8551, revision I (B70 851127 012), replacing the existing wires in the limit switch conpartments with Class IE type SIS wires (TVA Mark No. WJG-6), and correcting drawing discrepancies.

Parts of workplan 11855, including functional testing, were contained in the STEP and provided the instructions for the electrical modifications and testing. The project's evaluation adequately doctmented that the modifications performed under ECN L6544 have not degraded the capability of the system to perform its safety function. No further testing under ECN L6544 was required, as the functional testing performed was adequate to verify the safety function of the modified system. However, it was noted that the reviewer of the test evaluation also appeared to be the technical supervisor, which is in violation of NEP-5.2 for independent reviews. This concern was adequately addressed by the project and is discussed further in item 10.

8. ECN L5599 (Reference 14) - 125-V DC Sth Vital Battery System VP/256-ECN L5599 involved the addition of the 5th vital Battery System to the existing Vital Battery System in order to inprove the system maintenance and operability. This new system is intended to serve as a temporary substitute for any one of the four primary 125-V DC vital batteries.

Workplans 11188, ll260, 11288, 11296, and 11400, including PMT-51 contained in the STEP, provide step-by-step instructions for installation, modification, and electrical testing. The project's evaluation of PMT-51 results concluded that tNs modified primary battery system was not tested in accordance with workplan 11296, inasmuch as the electrical isolation was not checked (breaker 107 was never opened during PMT-51 testing), and this isolation testing is required to be conpleted before unit 2 restart. This evaluation was found to be acceptable. Theproject's review of PMT-51 results also found the following deficiencies:

e The slide bar interlock for normal charger breaker to each vital battery board was not tested.

e The 5th Vital Battery System was not tested with all 60 cells in place.

e The loss of charger (LC) relay for the 5th vital battery charger was not tested.

7.4.1-4

Theprojectconcludedbystatingthatthesethreedeficienciesneedtoberesolved but are not required for unit 2 startup. Notechnicaljustificationwasprovidedas to why the resolution of these deficiencies was not a prerequisite to unit 2 startup. In addition, the 501 nunber for the electrical isolation testing that was referenced in the STEP was in error. These two concerns were addressed in action item E-60. Theproject'sresponsewastheinitiationofthetestreviewchangeform dated October 23, 1906. This change form has been reviewed by the FA flectrical and was technically acceptable.

9. ECN 2633 (Reference 15) - Main Steam System (MSS) 1-This ECN was initiated to replace certain Foxboro pressure transmitters with environmentally qualified replacements. Portions of workplans 70523 and 9199 that enconpassed the functional testswereincludedintheSTEPandevaluatedbytheproject. The functional tests for this ECN involved calibration checks, response time tests, and functional wire checks. Theproject'sevaluationindicatedthattestingwasacceptabletoensure the component functions and that no retest was necessary. SQEP-14 requires the evaluation conclusion to address that the system and components can adequately perform their intended safety function, not simply that no retest was required, it was also noted during the EA Team review that the test evaluation was being done on an ECN and schematic drawing basis instead of a preop test, postmodification test, or surveillance test basis as inplied by SQEP-14 R0. The test evaluation on an ECN/ drawing basis is seen as an improvement over that identified by SQEP-14 R0, and should provide the SE with information that is more easily addressed in the S?'s SYSTER evaluation. However, SQEP-14 R0 does not specifically require this practice. Both of these concerns were addressed to the project in action items E-37 and E-33, respectively.

In responding to these action items, the project revised SQEP-14 and reinstructed their test review engineers to provide a more thorough written evaluation and conclusion for documenting their results. SQEP-14 RI was reviewed and found to be acceptable. It was also noted that the test evaluation reviewer appeared to be the technical supervisor, which is in violation of NEP-5.2. This concern was acequately addressed by the project and is discussed in item 10.

10. ECN L5114 (Reference 16) - SIS 63-This ECN was initiated to correct a deficiency from peop test W6.l.D which indicated that there was no accurate supply breaker status indication in the MCR when a breaker trip signal was present and a start signal from a local handswitch was also applied. This ECN modified the supply breaker control circuit on the 6.9-kV SHDN BD. Workplan WP9822, which included the functional test for this modification, was included in the STEP and evaluated as acceptable. However, the EA Team's review identified the following proble:ns with the project's evaluation:

a. The reviewer of the evaluation appeared to also be the technical supervisor, which is in violation of NEP-5.2 for independent reviews. This was identified to the project on action item E-34.

b. Thewrittenjustificationoftheevaluationonlyaddressedthatnoretestwas required, and failed to note that the modification did not degrade the system's safety functions. This was identified to the project as action item E-37.

i 7.4.1-5 I

c. The STEP contained insufficient testing information to support: (l) the conclusion as acceptable and (2) testing of this modification as adequate. This wasidentifiedtotheprojectasactionitemE-38.

In responding to these action items, the project revised their test evaluation to require a retest to verify proper breaker status indication in the MCR, reinstructed their test review engineers to provide more thorough written evaluations, and re-reviewed 77 test evaluations originally reviewed by the supervisor to ensure the independent review requirements of NEP-5.2 were met. The revised test evaluation was reviewed by the EA Team and was found to be adequate. The retest, as proposed above, was also reviewed and was acceptable to prove (a) proper breaker status was received in the MCR, (b) the safety system function was not degraded by the modification, and (c) the system will perform its safety function as designed.

11. ECN L5017 (Reference 17) - AP SYS 201/202-This ECN added a motor operator and associated controls to an existing manual valve 0-67-546A. Portions of workplans 8653 RO through R6 and 8653 R8 were included in the STEP and evaluated. The project evaluation determined that this modification and the associated functional tests are more appropriately addressed by the System 67 (ERCW) test evaluation of this ECN since the ECN also involves that system. This evaluation was found to be acceptable by the EA Team, since the auxiliary power involvement was minimal.

It was noted that the reviewer of the test evaluation also appeared to be the technical supervisor, which is in violation of NEP-5.2 for independent reviews.

Thisconcernwasadequatelyaddressedbytheproject. The details are provided in item 10 above.

12. ECN L5451 (Reference 18) - Standby DG System 82-This ECN added a redundant AC lube oil pop and a DC lobe oil pung to the DG lube oil system. Portions of workplans WP9994,10118,11424,11425,11426, l1427, and 11703 that enconpassed the functional testing associated with the installation of this ECN were evaluated. In addition, calibration records from Sis-170.I, -170.2, -170.3, and -170.4 were included to verify the oil pressure switch calibration. Theproject'sevaluationindicatedthat the functional testing performed (such as motor rotation check, cable continuity check, and pressure switch calibration) was not adequate to ensure that the DG System had not been degraded and that the conponents and system can perform their safety function. Additional testing was reconmended to verify: (a) the operability of the AC and DC lube oil punps as an integral part of the DG lube oil system, (b) breaker trip settings and switch settings, and (c) that the breaker can operate the pumps with the pressure switches properly starting and stopping the pumps. The EA Team's review found this evaluation to be acceptable. This additional testing was performed in workplan 12336 and upon review was determined to be acceptable.

13. ECN L6573 (Reference 19) - AP SYS 201/202-This ECN removed the circuitry of 1he auto-transfer to the alternate 6.9-kV SHDN BD source and reduced the tripping time of the normal feeder breaker. PMT-86RI and the functional tests that were included inworkplan12068wereevaluatedbytheproject. Testing required by this ECN had not been completed at the time of EA review. However, the tests as written were adequate to address the requirements of the test scoping doctment and were acceptable to verify the adequacy of this change and its effects upon the AP SYS.

The project results showed that, if the test is completed as written with no open deficiencies, the system's safety fenction will not be degraded. The EA Team's review found this evaluation to be acceptable.

7.4.1-6

14. ECN L5363 (Reference 20) - AP SYS-This ECN added circuitry to interlock the emergency feeder breaker close circuit to ensure that load shedding occurs before the emergency feeder breaker closes. Workplan 8967, which contained functional testing of the ECN, was evaluated by the project as adequate. However, the EA Team recognized that, although a continuity check was performed on all boards, the relay operation (contact closing) and actual load shedding was only tested on one 6.9-kV SHON BO. In add _ition, only two loads were shed from the board before the emergency

' feeder breaker was verified closed.' This test deficiency was identified to the projectbyactionitemE-79. Theprojectrespondedbyrevisingtheirtest evaluation to include surveillance testing (Sis-26.lA, -26.1B, -26.2A, and -26.28) which verified load shedding and emergency feeder breaker closure. This revised test evaluation was reviewed and found to be acceptable. No retest was determined to be necessary.

15. ECN 2945 (Reference 21) - HVAC System 30/31-This ECN replaced the I/3-hp DC TDAFP room exhaust vent fan with a 1/2-hp fan and modified the air inlet area to increase ventilation and reduce the room air tenperature rise from 20.38'F to 10*F to resolve preop test TVA-22 test deficiency. The project used workplan 9333, included in the test evaluation package, to conclude that functional testing for fan operation, rotation, and speed was inadequate and that additional retesting was required. A portion of preop test TVA-22 (unit 2) was included and evaluated to prove that the vent fan control circuitry was demonstrated to be adequate. The EA Team found this evaluation to be acceptable. However, in the EA Team's review of preop test TVA-22 it was noted that this ECN had been initiated based on a test deficiency on unit 1, whereas the same deficiency for unit 2 was accepted and approved with no justification provided as to the acceptance of the unit 2 deficiency. This was identified to the project by action item E-57. Theprojectrespondedbyinitiating PlRSQNEER0695 (reference 22), which was later upgraded to SCRSQNEEB8729 (reference

23) . C/A for this SCR had not been identified at the time of the EA Team's review.

(Observation E2)

16. Red-line Process - Schematic Drawing Comparison For the red-line process, the project identified the appropriate preop testing for each system. The schematic drawings that were identified as part of the test record drawings for the preop test were then compared with the latest available, as-constructed drawing to determine if all system changes had been identified for a test evaluation. From this conparison, the project determined that all schematic drawing differences had been identified for review under the SQEP-14 (reference 2) test evaluation process. The EA Team's review of the drawings lished below found this comparison process to be acceptable to ensure changes were correctly included in the test evaluation process with one exception. The High Pressure Fire Protection System 26 drawing package correctly used preop test nunter TVA-41, and designated the dif ferences between the preop schematic and the as-constructed schematic as being attributed to ECNs L6544 (reference 13) and L5880 (reference 24). It also correctly used drawing 45N779-37R5 as the preop schematic. However, the schematic initially used was "as designed" 45N779-37Ril, which was not correct.

ihis was identified to the project in action item E-56. The project's C/A included a re-review of all the drawings before the date of the action item to ensure correct drawings had been used for the entire red-line process. This included the use of drawing 45N779-37 Ril/P for System 26, which was the correct as-constructed t schematic. The electrical test review supervisor issued guidelines to the engineers performing the red-line process to ensure that correct drawings were used and that those drawings were properly marked. This C/A was verified in subsequent EA review of red-line packages.

7.4.1-7

Test Record As-Cxistructed Drawing y

S stem Preop Test Drawing Drawina Concarison Difference 65 W.6.l.D 45N765-14R6 45N765-14Rll/J ECNs l%51, L5000 (reference 25) L6515 26 TVA-41 45N779-57R5 45N779-57Ril/P ECNs L6544, L5880 (reference 26) 32 TVA-27 45N632R8 45N652R10/L ECN 2480 (reference 27) 74 W.6.l.E 45N779-9Ril 45N779-9Rl9/W ECNs 2828, L5036 (reference 28) (unit 1)

W.2.2 (reference 29) 74 W.6.l.E 45N657-8R6 45N657-8R9/J ECN 2875 W.2.2 92 Wil.1 45N657-I4RS 45N657-14R5/H ECN L5880 (reference 30) 7.4.1.2 Conclusions The Electrical discipline of the EA Team review confirmed that the project's efforts in assenbling and verifying the electrical and itC portions of those ECN modifications for electrical test evaluations within the Mundary of calculation SQN-OSG7-048 were acceptable pending the EA Team's urification of corrective actions defined in section 7.4.1.1. (Observation E2) 7.4.1.3 References issue Reference Document Revision Date Title I SQN-0SG7-048 R5 1/6/87 Identification of Systems Required for Sequoyah Restart 2 SQEP-14 R0 5/15/86 Assently and Evaluation of Electrical Test RI 9/19/86 Results 3 SQEP-57 R0 2/11/87 Processing of Test and Retest Requirements identified During the Design Baseline and Verification Program 4 ECN L5872 R0 6/I4/85 Add DG Building Vent Cooling (FWP 830614 500) 5 PIRSQNEEB8694 R0 1/50/87 DG Electrical Panel Vent Fan Indication in MCR (B25 870150 049) t 7.4.l-8

Issue Reference Document Revision Date Title 6 SCRSQNEEB8728 R0 1/30/87 DG Elect. Panel Vent Fan Indication in MCR (B25 870130 047) 7 ECN 2774 R0 3/13/81 Replace Motors on Motor Operators (SWP 810313 504) 8 ECN L5591 R2 5/9/06 W-2 Switch Modification (SWP 820600 519) 9 IE Bulletin RO 7/31/80 Failure of Westinghouse Type W-2 Spring 80-20 Tyne W-2 Spring Return to Neutral Control Switches (NEB 820405 266) 10 ECN L5158 RO 7/17/81 Replace Diesel Generator Battery (SWP 810717 500) ll ECN L5298 R1 8/28/80 ERCW Cables, Reroute (SWP 800828 507) 12 ECN L6293 R2 4/30/06 RPS Shunt Trip Breaker (B25 860430 503) 13 ECN L6544 R2 1/18/% Jumper Out Limit Switch (B25 860l18 553) 14 ECN L5599 R2 5/9/86 Add Fifth Vital Battery (SWP 820616 502) 15 ECN 2633 R0 10/17/79 Replace instrumentation (SWP 791017 511) 16 ECN L5114 RI 2/23/81 Remove IX Relay Contact (SWP 810223 502) 17 ECN L5017 R2 3/14/81 Add Motor Operator to Manual Valve (SWP 810314 503) 18 ECN L5451 R2 1/14/86 Modify Diesel Lube Oil System (B25 860ll4 513) 19 ECN L6573 R0 2/12/86 Eliminate Slow-Bus Transfer (B25 860212 505) 20 ECN L5363 R0 12/II/80 Interlock Emergency Feeder Breaker (SWP 801211 501) 21 ECN 2945 R0 4/14/81 Replacement DC Power Vent Exhaust Fan (SWP 810414 510) 22 PIRSQNEEB8695 R0 1/28/87 Turbine-Driven Auxiliary Feedwater Pump Room Ventilation Test Deficiency (825 870128 046) 23 SCRS') NEE 88729 R0 1/28/87 Turbine-Driven Auxiliary Feedwater Pump Room Ventilation Test Deficiency (B25 870128 045) 7.4.1-9

Issue Reference Document Revision Date Title 24 tCII L5890 RI ll/26/86 Identify Fuses with UlilD on Single Line (825 861126 506) 25 W.6.1.0 R0 7/19/78 SafetyinjectionSystem-Safetyinjection Pung and Related injection System Performance Test l

26 TVA-41 R0 7/22/80 Preoperational Test Instruction Containment isolation System l 27 TVA-27 R0 6/19/80 Preoperational Test Instruction Control Air System 28 W.6.l.E R0 6/30/78 Safety injection System - Residual Heat RemovablePumpandRelatedinjectionSystem Performance Test 29 W.2.2 R0 6/23/78 Prooperational Test Residual Heat Removal Systehl 30 Wil.1 R0 4/19/77 Prooperational Test Nuclear Instrumentation System 7.4.1-10

7.4.2 Instrunentation and Controls The electrical system test evaluation packages were reviewed by the l&C discipline of the EA Team (EA ISC) to ensure that they contained suf ficient rationale and suf ficient supporting documentation to verify that modified ISC circuits and/or component repl3 cements had not conpromised any engineered safety features. Six evaluation packages were selected for EA ISC review, as representative of modifications to plant safety-related control features.

Modifications to ISC conponents, logic, setpoints, and ESF design were focused upon.

The electrical test evaluation packages were reviewed to determine if:

a. Acceptable rationale was included within the packages to justify the project's accept / test / retest conclusions.

b. Sufficient test docunentation was included by reference, or within the packages, to supporttheproject'sconclusions,

c. The referenced test documentation (workplans, surveillance test results, etc.) was pertinent to the modification evaluated.

d. Testing or retesting, where prescribed by the project's evaluation, would adequately confirm satisfactory safety function.

e. The requirements of procedure SQEP-14 (reference 1) were complied with.

7.4.2.1 Details Six system test evaluation packages were reviewed: ECN L6359/SYS 87, ECN L5791/SYS 3A, ECN L5884/SYS 72 ECN L6175/SYS 32, ECN L6124/SYS 3B and ECN L6254/SYS 38 (references 2 through 6). The NRC reviewed additional packages as well. The review of these packages indicated that all aspects were adequately addressed except for the following three concerns:

One concern, relating to surveillance testing, evolved into a significant, generic concern over limitations in the plant's surveillance testing program. The two other concerns were of minor significance. All concerns were subsequently resolved. The details are presented below:

1. ECN L6175, Pressure Switch Setpoints-ECN L6175 (reference 5) facilitated a change to a pressure switch setpoint in the Essential Control Air System. Theprojectevaluation concluded that the test results, recorded in maintenance requests (references 7 and 8) for the recalibration of pressure switches 0-PS-32-62 and 0-PS-32-88, confirmed acceptable function. However, the method of recalibration was not docunented in the project evaluation. The concern was directed to the project in action item 1-32. The concern was alleviated when the project provided evidence that instrument maintenance instruction IMI-134 (reference 9) had been used in the recalibration. A review of IMI-134 confirmed that it was applicable to the switches in question, and had been recorded in the workplan.

7.4.2-1

2. ECN L6551,'Te m erature Switch Setpoints--While. reviewing workplan 11916 (reference 10) for ECN L6551, the NitC noted data omissions within the co g leted workplan. The workplan had not recorded the "as-found" settings on 4 tagersture switches, whereas the "as-found" settings on 9 other temperature switches had been recorded.

Additionally, the workplan required 15'F tolerance for "Itequired values" (now settings) without any design basis reference which permitted that tolerance. The concerns were forwarded to the project in action item I-44. EA l E concurred with theproject'sassessmentoftheunrecorded,"as-found"switchsettingsasaone-time omission, inasmuch as the switches had been recalibrated via the workplan, the omission was insignificant. The concern over the lack of a design basis reference in the workplan for the 1 5'F tolerance was alleviated when EA I K reviewed the governing setpoint calculations 845 860005 910 and 845 860005 911 (references 11 and 12) and confirmed that the tolerances were valid.

3. Surveillance Testina of Time-Delav fielavs--While reviewing electrical test evaluation packages and associated test data documentation, the NRC noted that certain time-delay relays in the CCS, ERCW System, Auxiliary Feedwater System, and Charging System were not included in the plant's surveillance testing program as required to meet IEEE 558-1977 (reference 15). TheconcernwasforwardedtotheprojectinactionitemI-46.

The project response indicated that the deficiency had been previously identified by the Noclear Quality Audit and Evaluation Branch in Deviation Report QSQ-A-86-0007-001 (reference 14). In response to that report, the plant had connitted to identify, test, ;

and prepare periodic testing procedures for all such devices by August I, 1987. EA lE '

concurred with that C/A, and since the deficiency was being tracked by the Nuclear Quality Audit and Evaluation Branch, no further EA IE verification was required.

7.4.2.2 Conclusions The I E discipline of the EA Team found that the evaluation of electrical test results

'was thorough, well-documented, and technically sound. Except for a few omissions in referencing documents, all test doceentation necessary to ensure proper function was well-recorded and sufficiently evaluated. Additionally,therationaleusedbytheproject for selecting and evaluating various testing records was well-defined in the evaluation packages.

7.4.2.5 References issue Reference Document Revision Date Title i

i SQEP-14 1 9/19/06 Assembly and Evaluation of Electrical Test l Results 2 ECN L6559 0 8/21/86 System Test Evaluation Package System 87 5 ECN L5791 0 8/2/86 System Test Evaluation Package System 5A l 4 ECN L5884 0 8/5/86 System Test Evaluation Package System 72 I

7.4.2-2 6 ..

issue Reference Dociment Revision Date Title 5 ECN L6175 0 8/26/86 System Test Evaluation Package System 32 6 ECN L6124/ 0 8/II/06 System Test Evaluation Package System 38 ECN L6254 7 A-233384 -

9/25/84 Maintenance Request 0-PS-32-88 8 A-Il8790 -

11/15/84 Maintenance Request 0-PS-32-62 9 INI-134 2 3/19/84 Configuration Control of instrument Maintenance Activities 10 WPil916 -

9/18/06 Workplan to implement ECN L6551 (workplan (Tenperature Switch Setpoint Changes) complete) 11 843 860805 910 1 8/6/86 Instrtment Accuracy calculation I-TS-I-17A 12 843 860805 911 1 8/5/86 Instrument Accuracy Calculation 0-TS-12-9lA 13 IEEE 338-1977 -

1977 Standard criteria for the Periodic Testing of Nuclear Power Generating Station Safety Systems 14 QSQ-A-86-0007-001 -

7/11/86 Nuclear Quality Audit and Evaluation Branch Audit Report 7.4.2-3

7.4.3 Operations Engineering theOperationsEngineeringdisciplineoftheEATeamreviewedtheresultsoftheproject evaluation of postmodification and surveillance testing for technical adequacy. The evaluation by the project was to verify functional acceptability of electrical and instrumentation modifications made after OL. Projectevaluationofelectricaltestresults was performed in accordance with SQEP-14 (reference 1). Projectdocumentationofelectrical test evaluations was reviewed for thoroughness and identification of the need for additional testing where available test results could not assure functional acceptance of an electrical or instrument modification.

7.4.3.1 Details The EA Operations Engineering review of four ECNs that required electrical postmodificationtestingwasperformedtoestablishtechnicaladequacyoftheproject review. ECNs reviewed include: ECN L6404 (System 74), ECN L6549 (System 74), ECN L6359 (System 87), and ECN L5970 (System 72) (references 2 through 5).

The results of these reviews are sunnarized below:

1. ECN L6404 (Reference 2) - RHR System 74--Workplan WPil600, included in ECN L6404, contains testing to verify that limit switches function properly after being replaced with environmentally qualified switches. The testing of the limit switches in workplan WPil600 verifies proper switch function at the limits of valve travel by verifyingelectricalsignalsatappropriatejunctionboxes. Limit switch testing under WPil600 did not, however, stroke test the motor-operated valve on which the limit switch was mounted. Technical Instruction (TI)-69 (reference 6) requires stroke testing motor-operated valves per SI-166.6 (reference 7) if any maintenance is done involving valve limit switches. This apparent discrepancy was brought to the attention of the project in action item 0-23. Theprojectrespondedthatthelimit switch replaced was a stem-mounted limit switch which provided an interlock permissive only-no operator information (such as open or closed indication) or control function for the valve on which it is mounted.

For this reason, stroke testing the valve on which the limit switch is mounted would serve no purpose, as stroke timing uses the open/ closed indicator lights activated by the valve operator's internal gearbox limit switch, which was not disturbed during the work performed under ECN L6404.

This was considered an acceptable reason for not stroke testing the motor-operated valve in question. O further testing is required to ensure the operability of the limit switches replaced under ECN L6404.

2. ECN L6549 (Reference 3) - RHR System 74--Workplan WPil901, included in ECN L6549, contains steps to test hand switches to ensure that they are disconnected. The test review summary adequately documents the acceptability of the testing performed on the hand switches following their modification. No further testing is required to demonstrate the acceptance of the electrical modifications performed under ECN L6549.

7.4.3-1

3. ECN L6359 (Reference 4) - UHI System 87-Workplan WPil907, included in ECN L6359, provides instructions for installation and calibration of "SOR" level switches which are being used to replace the original level switches. Testing acconplished in WPil907hasbeenevaluatedbytheprojectandfoundacceptableasdocumentedinthe SQEP-14 evaluation. The level switches are being removed and sent to the manufacturer to correct a static shift problem (reference 8). Retesting of the level switches will be accomplished by the same method specified in workplan WPil907 for the original installation of the replacement switcnes. Since the testing performed af ter the original installation was acceptable, the retesting has been evaluated as acceptable.

4. ECM L5970 (Reference 5) - CSS 72- Workplan WPill00, included in ECN L5970, provides instructions for testing motor-operated valves which were replaced. Testing included performance of S1-166.6 (reference 7), which tests valve stroke time and verifies function of remote valve position indication. Testing specified in workplan WPill00 was found acceptable by the project as documented in the SQEP-14 evaluation. No further testing under ECN L5970 is required, as the testing performed is sufficient to

! demonstrate system fur,' tion.

7.4.5.2 Conclusions ProjectevaluationofelectricaltestresultsunderSQEP-14wasthoroughandtechnically adequate. All electrical test evaluations documented in accordance with SQEP-I4 were conducted by personnel trained to SQEP-14, and were signed by the preparer and reviewer.

7.4.3.3 References issue Reference Doctsnent Revision Date Title i SQEP-14 1 9/19/% Assent >ly and Evaluation of Electrical Test Results 2 FCN L6404 2 10/24/86 Replace Stem Mounted Limit Switches 3 ECN L6549 0 12/5/85 Junction Box nood Level Analysis 4 ECN L6359 0 4/15/85 UHI Water Tank Level Switches 5 ECN L5970 0 lI/3/83 Replace Valve Operators for NUREG 0588 Qualification 6 TI-69 10 3/5/86 Sunmary of Pre- and Postmaintenance Valve Tests for ASME Section XI and 10CFR50 Appendix J 7 SI-166.6 21 3/20/06 Post Maintenance Testing of Category "A" and j "B" Valves i

8 IE Bulletin NA 7/I8/06 Static O-Ring Differential Pressure Switches 86-02 7.4.5-2

7.4.4 Quality Assurance The QA discipline of the EA Team performed a review of electrical test results to verify the adequacy of interface controls between the plant and DNE. The test results program was developed to ensure that adequate test documentation existed to substantiate that the safety-related systems and components can perform their safety function. This verification was acconplished by ensuring that adequate instructions were in place and by tracking a selection of required electrical tests from initial identification by the SQEP-14 process (reference l} through completion and final evaluation of test results.

7.4.4.1 Details Five electrical tests were selected at random from the SQEP-14 review group files for this review. These tests supported the adequacy of ECN 2945 (reference 2), ECN L5872 (reference 3), ECN L5591 (reference 4), ECN L5114 (reference 5), and ECN L6202 (reference 6). The detailed results of these reviews are provided below.

I. ECN 2945 (Reference 2) - Alr-Conditionino System 31-The test scope defined by the SQEP-14 review group was to retest the turbine-driven auxiliary feed punproom ventilation fan. This retest request was received by the plant Systems Engineering Section, and the scheduled test start date was March 27, l%7. Two separate punchlist items which encompass this reisst requirement, 3979 and 7454, were appropriately identified by DNE. Both were open at the time of the review and were appropriately classified as restart items.

2. ECN L5872 (Re'erence 3) - Ventilation System 30-A SQEP-14 review determir'ed that ECN L5872 was partially implemented. Operability of a fan control circuit was not demonstrated because control circuits had not yet been installed. Theproject determined that a portion of the unconpleted workplan PMT adequately addressed the scope of the needed functional test. The plant Systems Engineering Section acknowledged receipt of the test request and coordineted conpletion of the applicable portions of the workplan PMT and submittal of the test results to DNE. DNE, in turn, appropriately submitted a notification of acceptability of test results back to plant management.

3. ECN L5591 (Reference 4) - SIS 63--SQEP-14 reviewers determined that functional testing of several Westinghouse W-2 switches was not performed after reinstallation of the modified switches. This problem was also identified in 12 other systems. Workplan 12268 was issued by the plant to perform all of these required tests. The workplan was incomplete at the time of the EA review. However, the System 63 portion (switches 2-HS43-10A and -15A) was completed, and copies of this segment of the workplan were submitted to DNE. DNE appropriately confirmed acceptability of the results.

4. ECN L5tl4 (Reference 5) - RHR System 74-This ECN required a retest of revised logic for breaker position indication on the RHR System. Workplan 12263 was subsequently issued by the plant and adequately addressed the scope of the retest requirements.

The Plant Systems Engineering Section submitted the retest results through plant management to DNE, and DNE appropriately responded with a notice of acceptability of the retest.

7.4.4-1

I l

l

5. ECN L6202 (Reference 6) - CCW System 70-This involved an extensive retest requirement for the CCW System. The retest request has been received by the Plant Systems Engineering Section but has not been worked to date. Three related open punchlist items were appropriately identified-3816, 5363, and 8146--and all are correctly classified as restart items.

l This review determined that all SQEP-14 identified tests sagled were considered to be l adequately scoped and appropriately submitted to the plant for resolution. The plant l Systems Engineering Section received and reviewed the test requests and determined l the best method to either perform the test (e.g., workplan, SI) or to use existing information which would demonstrate adequate functional testing. The Systems Engineering Section then effectively coordinated performance and cogletion of the test and submitted the cogleted test results through plant management to DNE for evaluation and acceptance of results. All three of the completed test results of the five tests sagled by EA are doctanented as QA records under the workplan process.

The QA discipline reviewer determined that, at the time of the review, only two procedures / instructions governed the activities of the electrical test results program, SQEP-14 and ID-CAP-2.4 (references I and 7). These procedures / instructions were determined to only meet the minimum requirements for interface control of the electrical test results program; however, because they had already recognized this situation, the projectissuedSQEP-57(reference 8).

SQEP-57 defines the specific test-related interfacing responsibilities for all affected SQN site organizations. The procedure includes requirements that ensure that all SQEP-14 tests are properly documented as QA records and also ensures these tests are readily traceable to past related tests. SQEP-57 complements the other existing instructions and results in a well-controlled program.

7.4.4.2 Conclusions This review demonstrated that the controls within the SQEP-14 test program in conjunction with the plant / project interface controls in the new SQEP-57 procedure are adequate, effective, and well-implemented.

l 7.4.4.3 References

! Issue i Reference Doctanent Revision Date Title i SQEP-14 I 9/19/87 Assentity and Evaluation of Electrical Test Results 2 ECN 2945_ 0 - Air-Conditioning System 31 3 ECN L5872 0 - Ventilation System 30 4 ECN L5591 0 - SafetyinjectionSystem63 5 ECN L5tl4 0 - Residual Heat Removal System 74 7.4.4-2

issue lieference Document Ilevision Date Title 6 ECidL6202 0 - Component Cooling Water Systen 70 7 ID-QAP-2.4 I II/21/86 Control of flodifications 8 SQEP-57 0 2/II/87 Processing of Test and Retest Requirements-Identified During the Design Baseline and Verification Program i

1 7.4.4-3

7.5 Chance Doctsnent Evaluation Change documents [ including ECNs, FCNs, FCRs, SCRs/NCRs, tenporary alteration control forms (TACFs), local-design change requests (L-DCRs), and ONP-generated drawing discrepancies] were evaluated by the project as required by SQEP-II, " Procedure for identifying and Assent > ling Change Doctsnentation," to determine the extent to which modifications fell within the system boundaries of the 084VP. Change doctanents (ECN, FCR, and FCN) were then evaluated as required by SQEP-12, " Procedure for Evaluating Engineering Change Notice and Field Change Notice Documents," to determine the extent to which the modification affected the restart decision and the technical adequacy of those changes that were within the system boundaries.

The project decisions were then documented in various forms (attachments to SQEP-il and SQEP-12) and sent to the SE for his use in developing the SYSTER.

The EA Team reviewed the adequacy of the project's decisions as to the effect of changes that fell within the system boundary scope and the technical adequacy of the ECN/FCN evaluations.

The results from Nuclear, Electrical, ISC, Mechanical, Civil, QA, and Construction, which performed reviews of the change doctsnents, are presented in sections 7.5.1, 7.5.2, 7.5.3, 7.5.4, 7.5.5, 7.5.6, and 7.5.7, respectively.

7.5-1

7.5.1 Nuclear in general, EA Nuclear reviewed each of the types of change document identification forms for conpleteness, technical adequacy, and compliance with SQEP-II (reference 1). In addition, the change document identification forms were reviewed to determine if the personnel completing these forms had been trained in SQEP-il.

Specifically, the ECN and FCN Identification Forms (Attachments I and 5. respectively, of SQEP-il) were reviewed to determine if:

a. All of them were captured in the identification process, and

b. They were properly categorized as affecting or not affecting a system with the boundaries identified in DNE calculation SQN-OSG7-048 (reference 2).

The FCR Identification Forms (Attachment 38 of SQEP-ll) were reviewed to determine if:

a. They were properly identified (FCR nunter given),

b. All ECNs associated with the FCR were identified and listed on an ECN Identification Form, and

c. All systems affected by the FCR were listed.

The L-DCR Identification Forms (Attachment 2B of SQEP-II) were reviewed to determine if:

a. All L-DCRs, including those issued before OL (listed on the CWIL), were captured, and

b. The correct inplementation status was recorded.

The TACF Identification Forms (Attachment 4 of SQEP-il) were reviewed to determine if:

a. The TACFs were properly determined as being within the boundaries of the systems identified in SQN-OSG7-048, and

b. The correct implementation status of the change at restart was indicated.

The ONP-Generated Drawing Discrepancy identification Forms (Attachment 7 of SQEP-II) were reviewed to determine if:

a. All affected systems were properly identified in part I of the form,

b. The item was correctly marked for exclusion from further DB&VP review, or

c. The listed change document was correctly identified for items marked for further review and tied to an ECN, DCR, etc.

The SCR/NCR Identification Forms (Attachment 6 of SQEP-ll) were reviewed to determine if:

a. SCRs/NCRs were properly excluded from further consideration by the DB&VP (correctly categorized as not affecting any systems or portions of systems inside the boundaries);

7.5.I-I

~

b. The SCR/NCR was categorized as affecting systems or portions of systems inside the boundaries, and its C/A was properly categorized (inglemented, open, or responsibility transferred to ONP Operations); and

c. AllSCRs/NCRscategorizedinbabovehavewrittenjustificationensuringadequateC/A or, if this C/A was considered inadequate, that a new SCR was issued.

EA Nuclear's review of ECNs and FCNs consisted of two parts. The first part involved a review of the ECN and FCN packages to determine if they:

a. Were technically adequate and consistent with design basis doctanents and the RD80 (reference 3),

b. Had an adequale and correct USQD, and

c. Had received proper and sufficient interdiscipline input.

In the second part of EA Nuclear's review, the DB&VP Change Document Evaluation Sheets (CDESs) and the Design Review Checklists (Attachments I and 2, respectively, of SQEP-12) were reviewed for conpleteness, proper justification, documentation, and conpliance with SQEP-12 (reference 4). Specifically, the CDESs were reviewed to determine if:

a. The ECN was adequately identified and described,

b. The rationale fcr the change category and priority selected (see Attachment I of SQEP-12 for categories) was correct and stated adequately,

c. Tho extent that the ECN was reviewed was discussed, and

d. The evaluation sheet contained the proper signatures.

The Design Review Checklists were reviewed to determine if:

a. Adequate engineering explanations /ev61uations were provided on the checklists (e.g.,

references to the FSAR, calculations, specifications, and drawings) to document and support the checklist conclusions,

b. The checklist contained sufficient interdiscipline support,

c. A CAQ was issued when adequate doctanentation did not exist to answer the questions on the checklist, and

d. The checklist contained all the required signatures.

As part of this review of ECN/FCN evaluations, any project nuclear discipline calculations that were used to support the change (either referenced by the ECN package or the checklist) were examined to determine if the calculation:

a. Addressed the ECN/FCN and its results were incorporated into the ECN/FCN, and

b. Employed an acceptable methodology.

7.5.1-2

EA Nuclear also participated in EA Audit 87-09 of the DNE SQN calculations program. Our conclusions from the audit were presented in the February 10, 1987, audit report (reference 5). Since then, EA Nuclear reviewed NEB's proposed C/A and found it to be satisfactory.

EA verification of this C/A has been acconiplished.

The change document identification forms reviewed by EA Nuclear were for the most part chosen at random from various sources (e.g., ECN/FCN hardcopy files, Records and Information Nanagement System (RINS), and draft or final SYSTERs). The ECN/FCN evaluations reviewed by EA Nuclear were selected from systems for which the project nuclear discipline had responsibility. To saniple a broad spectrum, the review included both TVA and Westinghouse systems and liquid process (62, 63, 72, and 87), HVAC process (65), and electronic (90 and 99) systems.

7.5.1.1 Details This section presents a detailed discussion of EA Nuclear's review of change documents.

First, the evaluation of the project's assently and categorization of change documents under SQEP-ll is discussed. Second, the review of the project's evaluation of ECNs/FCNs under SQEP-12 is discussed.

I. Identifying and Assentlino Chance Documents

a. ECN Identification Forms--Fifteen ECN Identification Forms (references 6 through

20) were reviewed in which all the ECNs had been categorized as not affecting the systems of SQN-OSG7-048. This selection was made in an ef fort to identify any systematic errors that may have resulted in ECNs being incorrectly excluded from furtherconsiderationbytheproject. Two of the ECNs reviewed (references 19 and 20) added structures over or around systems identified in SQN-OSG7-048 and raised a concern that modifications to systems not in SQN 4SG7-048 could adversely affect the systems of SQN-OSG7-048 if not properly implemented. This concern was directed to the project in action item N-14. The project pointed out that the scope of the DB&VP as defined in the DB&VP plan (reference 21) was to examine changes to systems (or portions of systems) defined in SQN-OSG7-048 only. EA Nuclear agreed with this response and concluded that all the ECNs reviewed were correctly categorized as not affecting the systems of SQN-OSG7-048.

In addition, two ECNs which were categorized as affecting systems of SQN-OSG7-048 (references 22 and 23) were randomly selected from the (Wil. ECN Identification Forms for these ECNs were reviewed and it was verified that the ECNs had been properly categorized.

EA Nuclear concluded that all ECNs were adequately captured and categorized, and the ECN Identification Forms were completed in conpliance with SQEP-il.

b. FCN Identification Forms-Six FCN Identification Forms (references 24 through 29) were reviewed and EA Nuclear verified that the FCNs had been correctly identified

as being within the boundaries of SQN-OSG7-048. A concern raised during the

( review was that the Westinghouse engineers, who reviewed five of the i

identification forms h eferences 25 through 29), could not be identified as having been trained in SQEP-ll.

7.5.1-3

ThisconcernwasdirectedtotheprojectinactionitemN-36. The project responded by providin0 trainin0 records for these individuals which indicated they had been trained in SQEP-il before cogleting the identification forms. EA Iluclear verified these records.

In addition, EA Iluclear examined the DG4VP FCN assentily process by selecting ten FCNs at random from RINS, the Nuclear Engineering Branch (NEB) hard copy files of FCNs, and the NEB FCN Log.' Eight of the corresponding FCN Identification Forms (references 30 through 37) were reviewed; they correctly categorized the FCNs and were adequately completed. No FCN Identification Forms were prepared by the project for two of the FCNs (references 38 and 39). Subsequent discussions with the Nuclear Lead Engineer (NLE) revealed that FCN Identification Forms were not generated for the FCNs that did not affect the portions of the systems inside the boundaries of SQ1N)SG7-048. Although this conflicted with the letter requirements of SQEP-il, it was considered to meet the intent of the program.

Further discussions with the NLE raised the concern that all FCNs that could have been iglemented after OL or had been approved but not yet implemented, may not havebeenidentifiedby'theprojectduetoSQEP-ilbeingpoorlywordedor misinterpreted. This could have led to some post-OL modifications not being evaluated in the D84VP. This concern was directed to the project in action item N-16. The project responded by undertaking C/A which doctanented additional FCNs on identification Forms for evaluation, documented in SCRSQNNEB8622 (reference

40) several FCNs which might have been iglemented without DNE approval, and revised SQEP-il (reference 41) to describe correctly the identification process for FCNs' included in the 084VP. EA Nuclear considered that this C/A adequately resolved their original concerns.

However, a new concern was raised about FCN iglementation status because discrepancies were encountered by the project in identifying the implementation status of the FCNs listed in SCRSQNNEB8622. Also,theProjectStaff(PS)was unable to provide the latest revision of the FCN Identification Forms to the NLE for updating which raised concerns about PS change document identification form distribution and processing in general. These new concerns were directed to the project in a follow-up to action item N-16. ,

TheprojectrespondedtothesenewconcernsbyrequestingSQNNodificationsto supply the project with the present implementation status of all FCNs (reference 42). The determination of actual iglementation status of all FCNs (by supplemental walkdowns if necessary), distribution of the actual status to affected SEs, evaluation of additional FCNs and previously evaluated FChs with a revised status, and incorporation of necessary changes into SYSTER addenda were not completed by the project during the EA Team review period. EA Nuclear verification is required (observation NI).

The project also pointed out in its response that FCNs are unique documents in that they are Westinghouse documents and are not tracked by TVA in the same manner as other internal TVA change documents. Theprojectstatedthatthiswas the probable cause for apparent deficiencies in the distribution and processing of the FCN Identification Forms. EA Nuclear considers this explanation to adequately address our concern about PS change document identification form distribution and processing in general.

7.5.1-4

c. FCR Identification Forms-Four FCR Identifica, tion Forms (references 45 through

46) were reviewed and found to have been cor:setly conpleted and to conply with g SQEP-ll.

In the course of EA Nuclear's review of SYSTERs, it was noted that several FCRs were omitted from SYSTER 83, CGCS. Thisconcernwasdirectedtotheprojectin action item N-54 (see section 7.7.1.1). Inresponse,theprojectstatedthat these FCRs were not in the scope of the DB&VP, per D8VP-D-86-005 (reference 47),

which stated that FCRs approved by DNE af ter Septent)er 29, 1986, would not be evaluated within the DB&VP.

The project's response to action item N-54 raised the concern that these changes would not be evaluated in conjunction with the other change documents by the SE and documented in the SYSTER. This concern was directed to the project in action item N-%. Inresponse,theprojectstatedthattheseFCRswerebeinghandled outside the 088VP under the transitional design change control process governed by SQEP-13 (reference 48). EANuclearjudgedthatthisprocesswa:adequateto address their original concern, but it was not conpleted by the project during the EA review. Verification by each affected engineering discipline on the EA Team of proper technical resolution of FCRs under SQEP-13 is required (observation N2).

A related concern, developed from the project response to action item N-54 and from conversations with project personnel, was that the project nuclear discipline evaluation supervisor interpreted D8VP-D-86-0056 to allow the u

s elimination of FCRs from the DB&VP based on their not being closed by Septent>er 29, 1986. Since these FCRs could have been verbally approved and inplemented before the SQEP-13 process took effect, they should have been evaluated in the DB&VP per 08VP-D-86-005. This concern was expressed in a followup to action item N-56. Verification by EA Nuclear of proper technical resolution of FCRs eliminated from the DB&VP by the nuclear discipline evaluation supervisor either in SYSTER addenda or under SQEP-13 is required (obsarvation N2).

d. TACF Identification Forms-Three TACF Identification Forms (references 49 through

51) were reviewed and found to have been adequately completed and to comply with SQEP-il.

e. L-DCR Identification Forms-Five L-DCR Identification Forms (references 52 through 56) were reviewed and found to have been adequately conpleted and to conply with SQEP-il,

f. ONP-Generated Drawino Discrepancy identification Forms-Five ONP-Generated Drawing Discrepancy identification Forms (references 57 through 61) were reviewed and found to have been adequately completed and to conply with SQEP-il.

g. SCR/NCR Identification Forms-Ten SCR/NCR Identification Forms (references 62 through 71) were reviewed and found to have been adequately conpleted and to conpiy with SQEP-il with one exception. The review of SCR/NCR Identification Form for NCRSQNPWP8308 (reference 65) raised the concern that SQEP-ll had not been followed by the senior discipline engineer (SDE), who determined that the C/A for this NCR was inadequate, but did not write a new SCR to identify and 7.5.l-5

track the problem. This concern was directed to the project in action item N-15. The project evaluated the reviews nede by this SDE and determined this to be an isolated incident. Theproject reinstructed this SDE in SQFP-Il and conmitted to re-review NCRSQNI'WP8308 and generale a now SCR if the C/A was again determined to be' inadequate. When FA Nuclear allempted to verify that the NCR had been re-reviewed, it was discovered thet the NCR had been excluded from further consideration (along with other open NCRs/SCRs) by the D64VP per directive D8VP-D-86-Ol9 (reference 72). Consr'uently, the concern raised in action item N-15 was eliminated from the D64VP. A concern about this directive wasexpressedtotheprojectinactionitemE-77andassociatedobservationEIO (see section 7.6.2). Verification by each engineering discipline on the EA Team of proper determination of C/A and significance for open SLRs eliminated from the 084VP and handled under NEP-9.1 (reference 73) is required (observation EIO).

2. ECN and FCN Evaluations-The details of the ECN/FCN evaluations will be discussed.

Ten ECNs and one FCN that made changes to systems ir. the project nuclear discipline's scope were chosen for review. The ECN/FCN packages were reviewed along with their CDESs, Design Review Checklists, and supporting calculations. Each ECN/FCN reviewed by EA Nuclear is listed and discussed below. In addition, the NRC expressed concerns over three ECNs which are also discussed below.

a. ECN L5970 (references 74 and 75)-ECN L5970 was written to replace several original valve operators with environmentally qualified ones per NUREG-0588. The ECN package was reviewed and was considered to be technically adequate. There werenoprojectnucleardisciplinecalculationsassociatedwiththisECN. Since this ECN has been fully implemented, no CDES was generated.

The review of the Design Review Checklist for this ECN (and the checklists for other ECNs) revealed that checklist questions 6a and 6c were answered "not addressed," and it was stated a PIR would be written, but no PIR nunber was referenced on the checklist. This raised the generic concern that without a PIR nunter it would not be possible to verify that the deficiency was actually documented and resolved satisfactorily, and there would be no way to track the deficiency among the various parties responsible for its resolution. This concern was directed to the project in action item N-33.

The project responded that SQEP-12 did not require a CAQ (PIR) nmber to be documented in the checklist, and that each exception listed in Section 4 of the SYSTER would be tied to the ECN that identified the exception (i.e., Section 4 of the SYSTER provides the required tie between the SYSTER and the checklist). In addition,theprojectnotedthattheSQEP-45(reference 76)punchlistwould ,

provide for tracking the CAQ between various parties. l Although EA Nuclear was still of the opinion it would be better to docunent any CAQ numbers on the checklists, we considered the generic concern raised in N-33 to have been adequately resolved.

7.5.I-6

Further review of the Design Review Checklist for this ECN raised the concern that many of the questions answered by the electrical support checklist did not have sufficient justification / references to support the conclusion that this ECN involves only direct replacement of components (e.g., electric motor valve operators) for EQ and that it would not affect interface requirements. Also raisedwasthegenericconcernthattheprojectmaynothaveadequatelyjustified or considered interface requirements on other ECNs that involve replacement of components with environmentally qualified components. These concerns were directedtotheprojectinactionitemN-34.

i Theprojectaddressedourspecificconcernbyrevisingtheelectricalsupport checklistforECNL5970toprovidesufficientjustification/ references. To address our generic concerns, the project reviewed a sample of checklists and found that this problem was limited to the electrical AP SYS ECN checklists. The project instructed the checklist preparers to provide adequate justification / references for all answers on the checklist, and the AP SYS checklists were revised. EANuclearconsideredtheprojectactionstohave adequately addressed the concerns and verified that the revised electrical support checklist for ECN L5970 contained sufficient justification / references to support the answers to the interface questions.

b. ECN 2707 (references 77 and 78)--ECN 2707 involved enlarging a spray shield and rerouting conduit as necessary to avoid jet ispingement from potential pipe breaks. Since this ECN has been fully implemented, no CDES was generated. There werenoprojectnucleardisciplinecalculationsassociatedwiththisECN. The l

ECN package was reviewed and found to be deficient because it did not reference i any supporting calculations for the increased loads on the enlarged spray shield (not noted in the checklist), did not consider seismic analysis of the shield, or have any electrical discipline involvement. In addition, fl'e civil support and the SE sunnery checklists should have referenced SQN-DC-V-l.l.Il (reference 79) for general pipe rupture protection requirements. Theprojectwasinformedof these deficiencies in ECN 2707 and its checklist by N-55.

The project initially agreed to revise the checklist to correct the deficiencies. However,itwassubsequentlydiscoveredbytheprojectthatECN 2707 was a unit I only ECN and therefore did not need to be evaluated by the unit 2 088VP. The ECN Identification Form for this ECN was revised to indicate it did not affect the systems of SQN-OSG7-048.

EA Nuclear verified that this ECN affected unit I only and also concluded that this concern had no generic implications,

c. ECN L6549 (references 80 and 81)--ECN L6549 called for analysis of junction boxes housing Class IE conponents located Inside containment below the postulated LOCA flood level and relocation if required. The ECN package was reviewed and found to be technically adequate and conplete. Since this ECN has been fully

implemented, no CDES was generated. The checklist for this ECN was reviewed and l found to have been adequately completed and to conply with SQEP-12. One of the l data sheets of the ECN package referenced a SQN calculation (reference 82). This calculation was reviewed and found to have drawn several important conclusions regarding the time-dependent behavior of the loss-of-coolant accident-<lesign p

7.5.l-7

'l1' ' ' '

basis accident (LOCA-0BA) flood level in containment from a Watts 8ar Nuclear Plant (WBN)-specific calculation (reference 83) without proper consideration of potential differences between the two plants. Theprojectwasinformedofthis apparent inproper use of a WBN calculation to support a SQN calculation in action item N-57.

TheprojectrespondedbyissuinganewSQN-specificcalculationforthetransient LOCA-DBA flood level in containment (reference 84).

EA Nuclear reviewed the new calculation and considered it to be technically adequate and informed the project that they should revise the SQN calculation (reference 82) to reference this new calculation (instead of the W8N calculation). All of EA Nuclear's concerns were adequately addressed by the project.

d. ECN L5779 (references 85 throuch 87)-ECN L5779 was written to add a bypass line with a differential pressure gauge around UHI hydraulic isolation valve FCV-87-22. This ECN was partially implemented and its CDES was reviewed and found to have justified the priority category for this change as "postrestart" because this change was to improve plant availability. However, the purpose of the CDES was to evaluate the restart configuration of the change from a safety standpoint and not the underlying reason for the change. The partially implemented status of this change should have been evaluated on the CDES in order to ensure that the safety of the system was not degraded. The review of the ECN package revealed that requirements in the USQO were not conpletely incorporated into plant surveillance instructions, that the seismic qualification of the modification had not been assured, and that design conditions had not been accurately captured on engineering drawingo There were no project nuclear discipline calculations associated with this ECN.

The review of the checklist revealed several errors and inconsistan;:les. For checklist questions 2c, 6g, and 6h, the SE sunnary checklist referenced the supporting civil or electrical checklists; however, these supporting checklists did not address these questions. The SE sumnary checklist did not contain adequatejustification/referencesforitsresponsestoquestions6Jand7,and the supporting electrical checklist did not contain an adequate reference for its response to question C. Several of the checklist questions apparently had the correct response but incorrect justification: 10a, 10b, and 10c on the SE checklist and 10e,10h,10f, and 10g on the supporting electrical calculation.

Theprojectwasinformedofthedeficienciesdiscoveredduringthereviewofthe CDES, ECN package, and ECN checklist in action item N-38.

The project responded by revising the CDES to recomnend that the ECN be properly conpleted before restart, referencing PIRSQNCE88665 (reference 88) to address inadequate docunentation of seismic qualification, and issuing PIRSQNNE88632 (reference 89) to address conflicting design pressure and tenperature conditions for the modification. Theprojectalsorevisedthechecklisttocorrectits deficiencies. In addition, the project sent a letter to Westinghouse (reference

90) to clarify how checklists were to be filled out and verbally advised the SE that the CDES must evaluate the restart configuration of the change.

7.5.1-8

EA Nuclear considered the above corrective actions to adequately address the deficiencies found during the review of ECN L5779. A new concern was raised during EA Nuclear verification of the above corrective action. The Civil Lead Engineer was shown on the SQEP-45 punchlist (punchlist item 5730) as responsible for determining the restart status of several sapport variances that affect this ECN, but no restart status had been entered on the punchlist for this item.

However, the SE had already stated in the CDES that this ECN should be' fully

. iglemented. EA Nuclear's new concern was about the potential conflict-in restart iglementation status determined by the different parties.' Theproject was informed of this concern in a follow-up to action item N-38. Theproject responded by submitting a SQA-185 Attachment } form to the Change Control Board (CCB) recomending implementation by restart. EA Nuclear verified that the CCB approved the recomendation. This corrective action adequately addressed EA Nuclear's follow-up concern.

e. ECN L5600 (references 91 and 92)--ECN L5600 was written to move four containment su g level sensor bellows from inside the crane wall to outside the crane well to allow sensor maintenance at power. Since this ECN has been fully implemented, no CDES was generated. There were no project nuclear discipline calculations associated With this ECN. The review of the ECN package revealed that adequate structural and seismic analyses had not been performed, and that no data sheets.

had been included in the package for the civil discipline. The checklist was reviewed and found to have inadequate justification in answering question 10g (18C response characteristics) as " addressed" and found to have an unclear response to item C. TheprojectwasinformedofthedeficienciesintheECN packa0e and ECN checklist in action item N-40.

The'projectrespondedbyreferencingPlRSQNCE88637,PIRSQNCE88639,and PIRSQNCE88656 (references 95 through 95) to address the structural and seismic

. inadequacies and revising the electrical checklist to adequately answer question 10g and item C.

EA Nuclear considered the project's C/A to have adequately addressed the deficiencies found during the review of ECN L5600. EA Nuclear reviewed the punchlist (for the above listed PIRs) and the revised checklists to verify that the C/A was performed. All of EA Nuclear's concerns were adequately addressed by theproject.

f. FCN TEIM-10676-This FCN was reviewed in conjunction with the associated ECN L%32 (see references % and 97). ECN L5632 was written to modify the Solid State Protection System so that a feedwater isolation trip would result in a trip of the main feedwater pugs, hotwell pugs, and main steam turbine. Since this ECN has been fully iglemented, no CDES was generated. Therewerenoproject nuclear discipline calculations associated with this ECN. The review of the ECN package revealed one discrepancy. The USQD and ECN cover sheet indicated that the FSAR (reference 98) was to be updated. The text of the FSAR was apparently updated but Figure 7.2.1-1 of the FSAR was not revised to reflect this change.

The checklist was reviewed and found to have insufficient references / justification for the answers to questions in sections 3, 5, and 10.

The project was informed of these deficiencies in the FSAR and ECN checklist in action item N-41, 7.5.1-9

1 l

l The project responded by connitting to submit the revised FSAR figure to NEB Licensing for inclusion in the next FSAR update and revising the checklist to providesufficientreferencesorjustificationfortheanswerstoquestionsin sections 3, 5, and 10.

EA Nuclear considered the project C/A to have adequately addressed the deficiencies found during the review of FCN TE W l0676. EA Nuclear reviewed the revisedchecklistandverifiedthatadequatejustificationandreferenceshad been provided for the questions in sections 3, 5, and 10. All of EA Nuclear's concernswereadequatelyaddressedbytheproject.

g. ECN L5371 (References 99 and 100)-ECN L5371 was written to replace 10 isolation dampers in the Emergency Gas Treatment System (EGTS) with butterfly valves to meet low leakage requirements. Since this ECN has been fully inplemented, there was no CDES generated. Therewerenoprojectnucleardisciplinecalculations associated with this ECN. The review of the ECN package revealed two discrepancies. The ECN cover sheet correctly indicated that the FSAR needed to be updated. However, a review of the FSAR revealed that while the text had been updated, a schematic of the EGTS had not been revised to show butterfly valves instead of danpers. Also, one support variance received preliminary, but not final, engineering approval.

The SE sunnary checklist was reviewed and found to have several deficiencies.

The SE responded to all parts of checklist question 8 on the hydraulic design criteria with "N/A," noting that the EGTS does not interface with any hydraulic systems. Hewever, because the EGTS is a fluid system itself, the damper / valve changes should have been addressed at least for item 8b (loss coefficients for the replacement valves).

The supporting electrical checklist did not adequately support / justify the respcnses to questions on materials conpatibility, operability, and response times (questions 2b, 7, and 10f). The supporting civil checklist did not supply adequatejustificationforthe"N/A"responsestotheeffectsthechangehadon structural design criteria (question 6).

TheprojectwasinformedofthedeficienciesfoundintheECNpackage,FSAR,and ECN checklist in action item N-42. TheprojectrespondedthattheFSARwouldbe updated and that punchlist items 7473 and 7268 referenced PIRSQNCEB8639 (reference 95) and PlRSQNCEB0659 (reference 101) to address the missing -

calculations and inadequate technical evaluation of the FCR. Theprojectalso revised the ECN L5371 checklist. In addition, it was determined that the failure to address checklist question 8, hydraulic design criteria, was generic to all nuclear HVAC Systems (65, 30A, 31A), and affected checkilsts from each of these systems were revised accordingly.

EA Nuclear considered the project C/A to have addressed the specific and gerieric deficiencies found in the review of ECN L5371. EA Nuclear reviewed issued SYSTERs for systems 65, 30A, and 3lA and verified that the C/A was acconplished.

All of EA Nuclear's concerns were adequately addressed by the project.

7.5.1-10

h. ECN L5323 (references 102 through 104)--ECN L5323 called for replacing charcoal test canisters in various filters in several air cleaning systems with test tray assentlies. The ECN package was reviewed and found to be technically adequate and complete and to have received sufficient interdiscipline support. The CDES was reviewed and found to have correctly and adequately identified, categorized, and prioritized the change. The checklist was reviewed and found to have insuf ficient justification / references for questions 2b and 4e. In addition, the SE summary checklist did not address the questions under hydraulic design criteria (question 8 of the checklist). One calculation (reference 105),

referenced by the supporting civil checklist, was reviewed and found to adequately address the seismic considerations. Theprojectwasinformedofthe deficiencies in the ECN checklist in action item N-44.

Theprojectrespondedthatthechecklistwouldberevisedtoaddsufficient justification /referencesforquestions2 band 4e. In addition, as described above for ECN L5371, the checklist for this and other ECNs that affect HVAC systems would be reviewed and revised to adequately address the questions under section 8.

EA Nuclear considered the project response to have adequately addressed the deficiencies found during the review of ECN L5323. The revised checklist in the issued SYSTER 65 was reviewed and found to have adequately answered questions 2b, ,

4e, and 8. All of EA Nuclear's concerns were adequately addressed by the project.

l. ECN L6258 (references 106 and 107)-ECN L6258 was written to renove power from various conponents to satisfy 10CFR50 Appendix R requirements. This ECN has been fully implemented so there was no CDES to review. The ECN package was reviewed and found to conflict with the CVCS design criteria (reference 108). Further investigation revealed that the design criteria document was in error, incorrectly referencing a superseded conmitment. The project was informed of the deficiencies in the design criteria document and C/R data base in action item N-39. Adescriptionoftheproject'sC/AassociatedwithactionitemN-39and subsequent EA verification is provided in section 7.6.l.l. Two associated calculations were reviewed (references 109 and 110) which supported the change and referenced this ECN.

The checklist was reviewed and found to have been adequately prepared and sufficientjustification/referencesgivenforallanswerswiththeexceptionof question I (compliance with design criteria). As discussed above, the change conflicted with the current design criteria which should have been noted by the SE. However, subsequent discussion with the SE indicated that he was aware that the change did not conflict with TVA's latest NRC conmitment. The project's C/A of revising the design criteria document adequately addressed EA Nuclear's concern as described in section 7.6.1.1.

J. ECN 2779 (references lit throuch Il3)-ECN 2779 was written to provide the capability to isolate pump and sump lines through the containment upon the detection of a high radiation level in the lines. The ECN package was reviewed and found to be technically adequate and conplete. The CDES was reviewed and found to have correctly and adequately identified, categorized, and prioritized the change. There were no project nuclear discipline calculations associated 7.5.1-1l

\

with this ECN. The review of the checklist revealed that the checklist questions that were answered "not addressed" did not reference a PIR nunber (see discussion of N-33 under ECN L5970). Otherwise, the checklist was adequately conpleted.

k. ECN L5966 (references 114 and ll5)-ECN L5966 was written to change the isolation signal for several valves in System 90 from containment ventilation isolation to Phase B isolation. The CDES was reviewed and found to have correctly and adequately identified, categorized, and prioritized the change. Since this ECN has been cancelled, the ECN package was not reviewed and no checklist was generated. Therewerenoprojectnucleardisciplinecalculationsassociatedwith this ECN. EA Nuclear considered this ECN to have been correctly and adequately evaluated by the project.

1. ECN L6673 (reference ll6)-The NRC reviewed calculation SQN-63-0053 (reference l17) in connection with its review o' this ECN. The review revealed that insufficienttechnicaljustificationhadbeenprovidedfortheRHRpumprunout flow rate used in calculation SQN-63-0053. Theprojectwasinformedofthe calculation deficiency in action item N-46.

The project responded by revising the calculation to provide justification for the value of runout flow rate used. EA Nuclear reviewed the revised calculation andfoundadequatetechnicaljustificationforthevalueofrunoutflowrate used. This concern was adequately addressed by the project.

m. FCN L6784 (reference ll8)-The NRC reviewed Waste Disposal System physical piping drawing 47W560-5 (which was outside the scope of the DB&VP) in connection with its review of ECN L6784. The review revealed several inconsistencies between drawing sections and the plan view. Theprojectwasinformedofthedrawing discrepancies in action item N-47.

TheprojectacknowledgedthattheWasteDisposalSystem(WDS)drawingshada large nunter of errors and issued PlRSQlMEB8718 (reference 119) to identify drawing discrepancies on this setem. The drawing errors are to be corrected during the development of the configuration control drawings. Theprojectalso responded that the portions of the WDS within the DB&VP scope were verified by the walkdown which noted no instances of incorrect piping.

EA Nuclear verified that PIRSQlMEB8718 was issued and determined not to be significant. EA Nuclear considered the project C/A to have adequately addressed this finding,

n. ECN L6076 (reference 120)-ECN L6076 was written to change the pressure switch (0-PS-62-I47) connection from opening on increasing pressure to opening on decreasing pressure at the same setpoint. The switch serves to trip the CVCS holdup tank recirculation ptap on low pressure. The NRC reviewed this ECN which was outside the scope of the DB&VP. The review raised the concern that a safety-related function of overpressure or overfill protection on the CVCS holdup tanks may have been deleted by the change, that this deletion was not considered in the USQ0, and that the instrument was not being handled as safety-related.

The project was informed of these concerns in the ECN package in action item N-48.

7.5.1-12

TheprojectrespondedthatECNL6076restoredtheswitchtoitsintendeddesign function of tripping the non-safety-related pump on low pressure for its own protection, which is not a safety function. Theprojectalsostatedthatthe CVCS holdup tanks are protected from vacuum by a vacuum breaker and from overpressure / overfill by a relief valve and a local high pressure alarm. The project explained that PS-42-147 was not on the SQN Critical Systems, Structures, and Components List because it does not perform a safety-related function or form

.part of the tank pressure boundary. EA Nuclear concurred that this explanation adequately addressed all of the concerns.

o. In addition to the drawing discrepancies identified in their review of ECN L6784 discussed above, the NRC found three sets of apparent discrepancies in the design conditions shown on flow diagrams: 47N812-1 (reference 121) and 47NBl0-1 (reference 122). Theprojectwasinformedofthesedrawingdiscrepanciesin action item N-45.

The project responded by issuing CAQR SQP870194R0 (reference 123) to document the results of their review of the mechanical flow diagrams for over 20 systems. A detailed listing of discrepancies was doctsnented with several conponents being identified as potentially deficient. The proposed C/A for the CAQR was to revise the drawings as required. The CAQR also stated that additional CAQRs would be issued to address individual canponent deficiencies. EA Nuclear concluded that the capture of this concern in an issued CAQR with its proposed C/A adequately addressed the concern and required no further EA Nuclear verification.

7.5.1.2 Conclusions Following the perfornance of C/A, EA Nuclear concluded that the project's process of assentling and categorizing change documents was adequately inglemented, with the exception of remaining verification associated with:

a. Assembling FCNs and determining their inplementation status, and

b. Handling open SCRs/NCRs and open FCRs outside the DB&VP scope.

The project's C/A addressing EA Nuclear's concerns about FCNs requires EA Nuclear verification (observation NI). The concern about handling of open SCRs/NCRs outside the DB&VP scope requires EA Team verification (observation E10). The concern about handling of open FCRs outside the DB&VP scope requires EA Team verification (observation N2).

Following the performance of C/A, EA Nuclear also concluded that the project's ECN/FCN technical evaluation process was adequate.

7.5.1.3 References issue Reference Document Revision Date Title i SQEP-il I 5/31/86 Procedure for Identifying and Assentling Change 2 6/16/06 Documentation 4 8/18/06 7.5.1-13

Issue Reference Doctment Revision Date Title 2 SQN-OSG7-048 3 1/6/87 Identification of Systems Required for Sequoyah Restart 3 BMI 861210 006 0 12/4/86 Restart Design Basis Document 4 SQEP-12 2 7/31/06 Procedure for Evaluating Engineering Change Notice and Field Change Notice Documents 5 805 870210 001 -

2/10/87 EA Audit Report 87-09 6 ECN L6395 0 -

ECN Identification Form (Attachment I of SQEP-il) 7 ECN L6397 0 -

ECN Identification Form (Attachment I of SQEP-il) 8 ECN L6399 0 -

ECN Identification Form (Attachment I of SQEP-il) 9 ECN L5854 0 -

ECN Identification Form (Attachment I of SQEP-il) 10 ECN L5855 0 -

ECN Identification Form (Attachment I of SQEP-II)

II ECN LS858 0 --

ECN Identification Form (Attachment I of SQEP-il) 12 ECN L5272 0 --

ECN Identification Form (Atiachment I of SQEP-l1) 13 ECN L5273 0 --

ECN Identification Form (Attachment I c? SQEP-il) 14 ECN L5806 0 --

ECN Identification Form (Attachment I of SQEP-il) 15 ECN L5808 0 -

ECN Identification Form (Attachment i of SQEP-II) 16 ECN LS890 0 -

ECN Identification Form (Attachment I of SQEP-l!)

17 ECN L5854 0 -

ECN Identification Form (Attachment i of SQEP-il) 18 ECN L5659 0 --

ECN Identification Form (Attachment I of SQEP-il) 19 ECN L5887 0 -

ECN Identification Form (Attachment I of SQEP-ll) 20 ECN L5889 0 --

ECN Identification Form (Attachment I of SQEP-il) 21 -

0 5/1/06 DB&VP - SQN (B25 870212 041) i I/87 22 ECN 2278 0 -

ECN Identification Form (Atiachment I of SQEP-1l) 23 ECN 2151 0 -

ECN Identification Form (Attachment I of SQEP-ll) 24 TENO-40503 0 -

FCN Identification Form (Attachment 5 of SQEP-l1) 7.5.1-14

w. - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ . _ _ _ . _ - _ . . ..- __ __

Issue Reference Document Revision Date Title 25 TEM-10644 0 -

FCN Identification Form (Attachment 5 of SQEP-ll) 26 tem-10659 0 -

FCN Identification Form (Attachment 5 of SQEP-ll) 27 TEW-10677 0 -

FCN Identification Form (Attachment 5 of SQEP-II) 28 TENO-40523 0 -

FCN Identification Form (Attachment 5 of SQEP-II) 29 TENO-40539 0 -

FCN Identification Form (Attachment 5 of SQEP-II) 50 TEM-106478 0 -

FCN Identification Form (Attachment 5 of SQEP-il) 31 TEM-10678 0 -

FCN Identification Form (Attachment 5 of SQEP-il) 52 TEM-40536 0 -

FCN Identification Form (Attachment 5 of SQEP-ll) 53 TElel-10675 0 -

FCN Identification Form (Attachment 5 of SQEP-il) 34 IEM-10662 0 -

FCN Identification Form (Attachment 5 of SQEP-il) 55 TEl94-40542 0 -

FCN Identification Form (Attachment 5 of SQEP-il) 56 TEM-10679A 0 -

FCN Identification Form (Attachment 5 of SQEP-ll) 37 TEM-10651 0 -

FCN Identification Form (Attachment 5 of SQEP-il) 58 tem-40504 0 -

FCN 59 TENM-40505 0 -

FCN 40 SCRSQNNEB8622 0 9/4/86 CAQ 41 SQEP-il 6 3/25/87 Procedure for identifying and Assentling Change Docunentation 42 825 870220 035 --

2/20/87 Memo from 08&VP to SQN Modifications 43 FCR 4ll3 0 -

FCR Identification Form (Attachment 58 of SQEP-ll) 44 FCR 4184 0 -

FCR Identification Form (Attachment 38 of SQEP-il) 45 FCR 4058 0 -

FCR Identification Form (Attachment 38 of SQEP-ll) 46 FCR 4097 1 -

FCR Identification Form (Attachment 38 of SQEP-II) 47 DBVP-D-06-005 0 9/29/86 FCR Review 48 SQEP-15 1 8/25/86 Procedure for Transitional Design Change Control 7.5.1-15

issue Reference Document Revision Date Title 44 84-122-90 0 -

TACF Identification Form (Attachment 4 of SQEP-ll) 50 82-2077-90 0 -

TACF Identification Form (Attachment 4 of SQEP-II) 51 80-557-90 0 -

TACF Identification Form (Attachment 4 of SQEP-il) 52 0933 0 -

L-DCR Identification Form (Attachment 28 of SQEP-il) 53 1675 0 --

L-DCR Identification Form (Attachment 28 of SQEP-il) 54 1746 0 -

L-DCR Identification Form (Attachment 28 of SQEP-il) 55 1813 0 -

L-DCR Identification Form (Attachment 28 of SQEP-il) 56 0441 0 -

L-DCR Identification Form (Attachment 28 of SQEP-ll) 57 AC-393 0 -- ONP-Generated DWG Discrepancy Form (Attachment 7 of SQEP-ll) 58 86-00-404 0 -- ONP-Generated DWG Discrepancy form (Attachment 7 of SQEP-II) 59 AC-187 0 -- ONP-Generated OWG Discrepancy form (Attachment 7 of SQEP-II) 60 AC-385 0 - ONP-Generated OWG Discrepancy Form (Attachment 7 of SQEP-ll) 61 86-00-169 0 - ONP-Generated DWG Discrepancy Form (Attachment 7 of SQEP-il) 62 NCRSQNEE88402 0 -

NCR/SCR Identification Form (Attachment 6 of SQEP-il) 63 Vendor #833845-1 0 --

NCR/SCR Identification Form (Attachment 6 NCR-l of SQEP-il) 64 SCRSQNA88601 0 -- NCR/SCR Identification Form (Attachment 6 c' SQEP-II) 65 NCR$QNPWP8300 0 --

NCR/SCR Identification Form (Attachment 6 of SQEP-il) 66 NCRSQNNEB8503 0 -

NCR/SCR Identification Form (Attachment 6 of SQEP-il) 67 NCRSQNNEB8507 0 -

NCR/SCR Identification Form (Attachment 6 of SQEP-II) 7.5.1-16

lssue Reference Document Revision Date Title 68 NCRSQNPWP8401 0 -

NCR/SCR Identification Form (Attaciunent 6 of SQEP-il) 69 NCRSQNNE88202 0 --

NCR/SCR Identification Form (Attachment 6 of SQEP-il) 70 NCRSQNSNP8116 0 --

NCR/SCR Identification Form (Attachment 6 of SQEP-II) 71 NCRSQNNEB8306 0 --

NCR/SCR Identification Form (Attachment 6 of SQEP-II) 72 DBVP-D-86-019 0 11/20/86 SCR/NCR Reviews for SYSTER Justification of Open CAQs to be included within DB&VP 75 NEP-9.1 0 7/1/86 Corrective Action 74 ECN L5970 - -

ECN Package 75 ECN L5970 0 9/9/06 ECN Checklist (Attachment 2 of SQEP-12) 76 SQEP-45 0 10/24/06 Control of D64VP Action items 77 ECN 2707 -- --

ECN Package 78 ECN 2707 0 9/23/86 ECN Checklist (Attactonent 2 of SQEP-12) 79 SQN-DC-V-l.l.Il 4 9/12/84 Evaluating the Effects of a Pipe Failure Outside Containment 80 ECN L6549 - - ECN Package 81 ECN L6549 0 9/17/06 ECN Checklist (Attachment 2 of SQEP-12) 82 B25 860611 001 0 6/11/% OE Calculation

8) NEB 811125 267 0 11/25/81 EN DES Calculation 84 B25 861217 802 0 12/17/06 DNE Calculation 85 ECN L5779 -- -

ECN Package 86 ECN L5779 0 7/11/86 ECN CDES (Attachment I of SQEP-12)

I 87 ECN L5779 0 9/19/% ECN Checklist (Attachment 2 of SQEP-12) 88 PlRSQNCEB8665 - -

CAQ 7.5.1-17 t . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - - _ _ _ - - - _ _ - - _ - - _ _ _ _ - - _ _ _ _ - . _ - _ _

Issue Reference Document Revision Date Title 89 - PlRSQISIE88632 --- -

CAQ i 90 825 860903 001 -

9/2/86 TVA Letter to Westinghouse 91 ECN L5600 -- - ECN Package 92 ECN L5600 0 9/29/96 ECN Checklist (Attachment 2 of SQEP-12) 93 PlRSQNCE88639 - -

CAQ 94 PIRSQllCE88637 0 CAQ 95 PIR$QNCE88656 0 CAQ

% ECN L5632 -- -- ECN Package 97 ECN L%32 0 7/9/06 ECN Checklist (Attachment 2 of SQEP-12) 98 -- - - Sequoyah Nuclear Plant Final Safety Analysis Report 99 ECN L5371 -- -- ECN Package 100 ECN L5371 0 9/7/86 ECN Checklist (Attachment 2 of SQEP-12) 101 PlRSQNCE88659 -

CAQ 102 ECN L5323 - - ECN Package 103 ECN L5323 0 9/12/06 ECN CDES (Attachment i of SQEP-12) 104 ECN L5323 0 9/7/06 ECN Checklist (Attachment 2 of SQEP-12) 105 B41 860728 001 1 7/29/86 OE Calculation 106 ECN L6258 - - ECN Package 107 ECN L6258 0 9/17/86 ECN Checklist (Attachment 2 of SQEP-12) 100 SQN-0C-V-27.2 0 7/25/06 Chemical and Vollne Control System 109 Enclosure 2 of - 12/21/84 SQN Fire Shutdown Logic L44 841221 804 Diagram and Associated Keys l10 845 85ll28 219 3 11/27/85 Category and operating Times lil ECN 2779 - - ECN Package 112 ECN 2779 0 10/3/% ECN CDES (Attachment i of SQEP-12) 7.5.1-18

l Issue Reference Doctmjen Revision Date Title

11) FCN 21M 0 8/29/06 FCN Checklist (Allachment 2 of SQCP-12) l14 ECN L5966 -- -- ECN Package l15 ECN L5966 0 9/6/86 ECN CDES (Attachment I of SQEP-12) 116 ECN L667) -- -

ECN Package l17 SQN-63-0053 0 5/27/86 OE Calculation 118 ECN L6784 - -

ECN Package 119 PIRSQlMEB8718 0 2/2/87 CAQ 120 ECN L6076 - - ECN Package 121 47W812-1 - -

CS Mechanical flow Diagram 122 4?NBl0-1 -- - RHR Mechanical Flow Diagram

12) , CAQRSQP870194 0 CAQ 7.5.l-19

7.5.2 Electrical The Electrical discipline of the EA Team (EA Electrical) reviewed the project's effort in the assembling of the change documents for those changes not field couplete at the time the

- OL was received, as well as all t,ubsequent changes which have been initiated since the receipt of the OL. The change doc uents consist of ECNs, TACFs, SCRs/IICRs, L-0CRs, and CNP-Generated Drawing Discrepancies. EA Electrical's review was performed to assess the project'sworkunderSQEP-il(reference 1)toensurecorrectcategorizationofchange  ;>

docuents, and to ensure that systems within the scope of calculation SQll-CSG7-048 (reference 2) were correctly identified on the change doc e ent identification forms. In addition, the project's evaluation of ECNs was reviewed for coupliance with SQEP-12 (reference 3) and for technical adequacy and completeness. This ECN review was performed to confirm that sound engineering explanations were provided to support the checklist conclusions and that the changes, including supporting calculations, were technically adequate and couplete. ~ Specific change doc uent selection was primarily based on the significance of the electrical equipment modification or electrical system impact. Some l ECNs were selected to evaluate the project's consistency of ECN reviews when multiple systems were involved by these ECils, in addition to the review activities performed on the i D88VP, EA Electrical participated in a technical calculation audit to address the electrical calculation program which establishes the base design for the plant and ties this base design to the D88VP by incorporation of changes mode to the calculations since

' receipt of the OL. The electrical essential calculations list was checked for completeness and technical adequacy. Concerns and deficiencies noted included lack of clearly identifying all essential calculations; on one list an ECN was not evaluated for effect on some calculations; a missing essential calculation that had never been prepared and some calculations had incesplete or inadequate assumptions and werifled computer programs. The concerns and deficiencies found in the audit have been adequately addressed by the Electrical Engineering Branch and are in the process of being corrected. Verification of this effort will be performed at a later date by EA.

7.5.2.1 Details

1. Assen611no of Chance Documents EA Electrical reviewed 20 EClis (references 4 through 22). These included:

L5449, L5970 L5872 L5451, 2768, 2777, L5085, L6652, L5359, L5328, L5864, L5867, L5877, L5880,1849 L5153, L5156 (System 31A), L51% - System VP, L5158, L6455 (references 4 through 22). All but 5 of the ECNs (1849, L5864, L5867, L5449, and l L5800) were found to be technically acceptable and processed in accordance with I

procedure SQEP-Il for ECN boundary determination and for system applicability.

However, the following concerns were noted for those ECNs:

a. Prelicense ECN 1849 was found listed on the ECN identification form but did not appear on the outstanding work items list (CWil). This concern was presented to the project in action item E-05. In responding to this concern, the project confirmed that ECN 1849 was indeed closed, was correctly not listed on the CWIL, and since it was completed before receipt of the OL, was outside the 088VP scope. Furthermore,theprojectindicatedthatonlytwoECNs(1849and1989) were found to be pre-OL and inadvertently sent to the SDEs. These two ECNs were recalled on June 4, 1986, from the SDEs to prevent unnecessary work. This action was found to be acceptable.

J 7.5.2-1

b. Incorrect system categorization of ECNs L5864, L5867, and L5800. This was identified to the project in action item E-06. Theprojectredesignatedthe ECNs and sent them to the SEs for evaluation in accordance with the procedures.

This action was found to be acceptable.

c. ECN L5449 was not identified as involving the VP SYS. Action item E-62 identified this concern. TheprojectgeneratedasupplementalECN .

identification form (reference 4) for ECN L5449 which correctly indicated that I the ECN affects the VP SYS, This was reviewed and found to be acceptable.

In addition to the above concerns which are directly related to the ECN review, the EA Electrical discipline raised a concern regarding the scope of procedure SQEP-II.

The concern was that potential generic condition evaluation (PGCE) documents were not being included in the D88VP. The concern related to the possibility that PGCEs (i.e., those previously determined to not exist at SQN) may not have received an adequate evaluation by SEs to assure documentation consistency and technical adequacy of the resultin0 conclusions. This concern was identified to the project in action item E-10. In response to this concern, the project indicated that PGCE evaluations were not considered part of the modification work process and thus not intended to be within the scope of the D88VP. However, no other program was identifled to the EA Team that does evaluate these FCCEs. Although the lack of including these doctsnents within the scope of the 084VP had no direct bearing on the performance of work to implement the 00&VP procedure, the EA Team will review some of the past PGCEs to verify the technical acceptability of the dispositions of these documents. (See Observation E4)

The EA Electrical discipline reviewed the following three TACFs: 2-84-115-3, 2-85-2007-30, and 0-85-0004-317 (references 23, 24, and 25). Reference 24 involved replacing and rerouting cable, since the original cable electrically shorted and its associated ccadult was too full to accept another cable. Both 2-85-2007-30 and 0-85-0004-317 have been determined to be outside the SW8tD boundary. Theproject's review, evaluation, and categorization of these TACFs were technically acceptable.

The EA Electrical reviewed 15 SCRs/NCRs (references 26 through 40) for proper system identification, categorization, and evaluation.

NCRSQNFWP8401 (reference 26)

NCRSQNEE88612 (reference 27)

NCRSQNEEB8306 (reference 28)

SCRSQNNE88510 (reference 29)

SCRSQNEEB8517 (reference 30)

NCRSQNEEB8100 (reference 31)

NCRSQNEEB8111 (reference 32)

NCRSQNEEB8113Rl (reference 33)

NCR$QNNEB8105 (reference 34)

NCRSQNEEB79-15RI (reference 35)

NCRSQNEEB8310 (reference 36)

NCR$QNEEB8502 (reference 37)

SCR$QNEE88529 (reference 38)

NCRSQNEEB8509 (reference 39)

SCRSQNEEB8602 (reference 40) l 7.5.2-2

in general, the SCR/NCR evaluations were found to be technically acceptable with the exception of some lack of technical justification provided for categorizing the documents and inappropriate signatures on the identification evaluation forms.

The details of these concerns follow:

a. There was lack of wr1tten justification to assure adequate C/A for all "OllP" and "lMPL" categorized SCRs/NCRs. This concern was identified to the project in action item E-09. In responding to this concern, the project re-reviewed al "0NP"and"lMPL"SCRs/NCRstoensurethatadequatejustificationswereprovided.

This process was verified by the FA Electrical and was acceptable.

b. The EA review of the "lMPL" categorized NCRSQhEEB8tl) R1 (reference 55) indicated thatinsufficientdocumentationexistedintheproject'sfilestoshowthatthe C/As established under this NCR had been fully inplemented by ONP. This concern wasdirectedtotheprojectinactionitemE-18. In responding to this concern, theprojecthasre-reviewedthisNCRandasaresultNCRSQNEEB8113RIwas reclassified as "011P". This was acceptable.

Additionally, the project has re-reviewed all "lMPL" NCRs/SCRs for correct categorization. (See item a above for details.)

c. ONP categorized SCR/NCR identification forms were signed by SDEs before evaluationofONPdocumentationbytheproject. This concern was of minor significance to the technical adequacy of the process. Action item E-15 identified this concern to the project. Theproject'sresponseindicatedthat although the identification forms were signed by SDEs, they were still sent to ONP for disposition, and the fact that the forms were signed had no effect on the disposition of this paperwork. This was acceptable.

The EA Electrical reviewed three L-DCRs (references 41 through 4)). These L-DCRs were correctly determined to be outside the SWBID boundary for the AP SYS and VP SYS. The L-DCR identification forms were found to be technically acceptable.

The EA Electrical reviewed the following six items concerning ONP generated drawing discrepancies: 86-00-201, AC-236, AC-277, AC-289, 86-D0-35), and 86-00-352 (references 44 through 49). Theproject'sreviewandevaluationofthese ONP-generated drawing discrepancies were technically acceptable and correctly documented on the identification forms for all items except for item 86-D0-352. This item involved the drawing discrepancy for drawing 45N767-5 (reference 50). This ,

drawing involved the DG remote control bus relay scheme and is associated with System

82. It incorrectly showed a connection to the 125-VDC vital battery board I, panel 4, circuit D19, rather than to the current circuit C42. However, the identification form identified only the VP SYS and neglected to include System 82. This concern was reportedtotheprojectinactionitemE-80. In responding to this concern, the projectproposedtoissueanaddendumtotheSYSTERforSystem82toincludean evaluation of this document. This action item was not conplete and remains to be verifled. (See Observation Ell.)

7.5.2-3

2. Evaluation of Encineerina Chance Notices (ECNs)

Seventeen ECNs (L5449, L5970, L5872--System AP, L5872--System 30, L5451, L6544, L6676, 2774, L6015, 2945, L5114--System 38, L5114---Systems 62, 63, 74, L5365, L6575, L6667, L6712, L6386 (references 4 through 7 and 51 through 61) were reviewed. The results of this review are presented below:

a. ECN L6544 (Reference SI) - RHR System 74-This ECN involved (1) removal of jtsupered out limit and torque switches, (2) deletion of 40-watt motor heaters per SCRSQNEQP8531 R1 (reference 62), (5) replacement of the existing wires in the limit switch conpartments with Class IE wire, and (4) correction of drawing discrepancies. These changes were performed in order to facilitate future field maintenance and testing of MOVs as well as to comply with 10CFR50.49 requirements. Adequate engineering explanations / evaluations were provided for all applicable checklist items except the following:

(l) No references to the FSAR, technical specifications, and design criteria were provided for each applicable item.

(2) " RIMS" was inappropriately used as a coordination / reference source.

(5) Checklist item B.3.c (failure modes) was not addressed.

(4) No accession nunter was given to doctsnent the QMDS referenced in the coordinating / reference colunm.

(5) The answer "N/A" provided by the SE to checklist item B.S.a concerning voltage drop analysis was not appropriate. Since removal of a large ntseer of motor heaters would af fect voltage drop on the electrical circuits, the ef fect of this change on voltage drop analysis must be evaluated.

(6) No documentation existed in the congleted checklist package to determine if an Appendix R shutdown logic calculation, identified in the ECN package, was '

reviewed or was affected by this ECN.

Concerns (I) through (5) were directed to the project in action item E-27 and concern (6) in action item E-35. InresponsetotheconcerninE-27,theproject re-reviewed the ECN and a revised design checklist was generated. This design checklist was reviewed by the EA Electrical and found to be technically acceptable.

InresponsetotheconcerninactionitemE-55,theprojectindicatedthat 10CFR50 Appendix R conpliance is required to prevent and/or mitigate the of fects of a fire and since fire is not an FSAR Chapter 15 event, any documentation related to Appendix R conpliance is not required to be reviewed under the D84VP.

This was acceptable.

b. ECN L6676 (Reference 52) - Main Feedwater System 3A--ECN L6676 involved routing separate cables from 400-Volt Reactor MOV Boards to the motor brake coils of the main feedwater isolation valves (MFlVs), 2-FCV-33-3), -47, -87, and -100. These 7.5.2-4 J

motor brake coils require a minimum of 90 percent of the rated voltage to operate while the calculated degraded voltage for these valves ranges from 65.2 to 78.2 percent (see SCRSQNEQP9606, reference 63).

The applicable checklist items were technically adequate with the following exceptions:

(l) Checklist item B.3.b. (Conpatibility With Existing Electrical Insulation and Wiring)--This item was evaluated as " Addressed" by this ECN using Attachment A, sheet 2, as a reference. This sheet relies solely on the Master 8/M as the basis for justifying material compatibility of electrical cable and wiring. The Master B/M alone without the specific identification of cable by mark nunter is not sufficient. This concern was identified to the projectinactionitemE-45. The project revised the checklist response to address this concern by taking credit for the 10CFR50.49 EQ program reviews of cables in harsh environments and by referencing the appropriate EQ binder containing the qualification of the cable. Cables not covered by the EQ program were reviewed against the list of acceptable cables of Design Criteria SQN-DC-V-II.) RS (reference 64) using ECN workplans and cable mark nebers, while the use of splices detailed in the workplans was reviewed against the applicable standard drawing for splices. Since the use of the B/M was determined by the project to be a generic problem, the project re-reviewed all electrical ECN checklists to assure proper response to checklist item B.3.b. This action item was satisfactory.

(2) Checklist item 8.5.e (Compilance with Electrical Cable Thermal Requirements)--This item was evaluated as " Addressed" and referenced Note la, Attachment A, which stated "the addition of new cable will inprove the thermal capability." This explanation was not sufficient to address the specific cable thermal requirements of this ECN since the new cable is covered by the CACTAT program. A more appropriate reference for this item should be either " Note 3, Attachment A," or the item should be marked "not addressed" and a PIR issued with the specific identification nunter given in the design review checklist for tracking. This was identified to the project in action item E-53. TheprojectinitiatedPIRSQNEER0671 (reference 6i) to address the lack of cable thermal analysis for cables to the motor brake coils of the main feedwater isolation valves 2-FCV-3-33,

-87, -47, and -100. This was acceptable. However, during verification of thePIR,theEAElectricaldisagreedwiththeproject'sdecisionto designate this PIR as "not significant" and designate action as postrestart. A response to this later concern was not available for EA to review. (See observation E3.)

(3) Checklist item B.6 a and b. (Seismic Qualification)--This item was not addressed by the project electrical discipline. This concern was directed totheprojectinactionitemE-41. Theprojectindicatedthattheseismic qualification of electrical equipment, although not addressed by the EA Electrical, was being addressed by the civil discipline and the appropriate SEs. This method of handling the seismic qualification of electrical equipment was verified and found to be acceptable.

7.5.2-5 l _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Furthermore, during the review of the ECNs and associated drawings, it was found that the schenstic diagram 45N779-24 R20 (reference 66) shows the motor brake coils of the MFIVs 2-FCV-3-33, -87, -47, and -100 were fed from the prim ry side of the full-voltage reversing starters located on the 400-V reactor MOV boards. While on the corresponding connection diagrass-45N2749-il Rio (reference 67) and 45N2750-1 Ril (reference 68), the same brake coils are shown to be supplied from the secondary side of the starters. The design as shown in the connection diagrams is correct for this application. -This drawing discrepancy was brought to the attention of theprojectinactionitemE-53. Theprojectaddeditem4681tothe g

punchlist to correct the erroneous schematic diagram and designated action for postrostart.. This was acceptable.

c. ECN 2774 (fleforence 53) - AP SYS-This ECN involved the replacement of the existing 1.0-hp motors on MDvs 2-FCV-16 and 2-FCV-18 with 25-ft-Ib I.6-hp motors. The applicable checklist items were found to be technically acceptable except for the following:

(l) Checklist item B.I (Design Criteria)--Design Criteria SQN-DC-V-II.4.1 (reference 69) was correctly identified as the design basis document.

However, the revision level was not given.

(2) Checklist item B.3.b (Compatibility with Existing Electrical Insulation and Wiring)-See item 2b.(l), ECN L6676, for a discussion of this checklist item and adequate resolution of the EA Electrical's concern.

(3) Checklist items B.3.d (Compatibility with Service Board Capacity), B.3.g (Minimen Vital Bus), B.S.a (Voltage Drop Analysis), B.S b (Emergency Diesel Loading), B.S.c (Protective Relaying and Circuit Protection Requirements),

and B.5.e (Electrical Cable Thermal Requirements)--These items were adequately evaluated as "Not Addressed," but no PIRs were written to ensure that calculations will be performed for the new l.6-hp motor which has already been installed on valve 2-FCV-IBB.

(4) No interdiscipline input was obtained from the electrical discipline even though involvement by the project electrical group was identified on the ECN cover sheet.

(5) The motor hp rating shown on the "as-designed" drawings 45N751-4 Rl9 (reference 70) and 45N751-8 Rl8 (reference 71) had not been changed to "l.6" from "I.0" to reflect the modifications required under this ECN.

Concern (1) was directed to the project in action item E-59. Concerns (3),

(4), and (5) were directed to the project in action item E-66. In response totheconcerninactionitemE-59,theprojectrevisedthedesignreview checklist to correctly reference the auxiliary power design criteria as SQN-DC-II .4.1 R2 with DIMS SQN-DC-V-II.4.1-1, -2, and -3. This was acceptable.

7.5.2-6

InresponsetotheconcernsinactionitemE-66,theprojectrevisedthe design review checklist and added punchlist items 7952, 7953, 79%, ano 7957 to *he punchlist for tracking and designated action as prerestart. The action was acceptable,

d. ECN L6015 (Reference 54) - Auxiliary Buildina Chiller System 31--ECN L6015 involved changing oil heaters from 600-watt to 285-watt for the compressors of the air conditioners to avoid overheating of oil. The compressors provide air to service auxiliary building general ventilatior, chillers which are nonsafety-related equipnent which were outside the scope of the 084VP. This change was performed in accordance with the manufacturer's request. It was noted that sheet I of USQO incorrectly indicated that this ECN involved the replacement of the existing 600-watt oil heaters with 285-watt heaters for the conpressors which service the safety-related shutdown board room chillers. This error was ~

identified in action item E-58. TheprojectissuedrevisionioftheUSQOto correct this error and revised the ECN identification form to remove ECN L6015, System 31, from further evaluation in the DBAVP. This was verified by EA Electrical and was acceptable. Additionally, the similar error was noted on the ECN Identification Form for ECN L6015-System AP. This error was identified to theprojectinactionitemE-32. Theprojectrespondedbyrevisingthisformto reflect the fact that this ECN does not affect portions of AP SYS within the boundaries of SW8lD. This was acceptable.

e. ECN 2945 (Reference 55) - VP SYS - HVAC System 31-This ECN involved replacing the two TDAFP room vent fan inpellers to increase the air flow in the room. This change also necessitated the replacement of the DC vent fan motor for a larger HP motor. Adequate evaluations were provided for the design review checklist items except for the following:

(1) An improper reference to a superseded design criteria was used.

(2) The 8/M wa1 improperly referenced to address the basis of acceptat,le cable insulationcompatibility.

(3) A wrong calculation was referenced to address the voltage drop considerations.

(4) Proper sizing of the DC fan motor overloads was not addressed.

(5) The applicable calculation for this ECN did not properly identify the use of unverified load data.

(6) The evaluation of instrumentation adequacy for this ECN referenced the wrong drawing and handswitches.

The above deficiencies were identified to the project in action itans E-54 and 7

E-55. In response to these deficiencies, the project re-reviewed this ECN and i

revised the design review checklist evaluations. Revision I of this ECN design review checklist was reviewed and found to adequately address the problems 7.5.2-7 o . .

.. I

identified exc yt for item (4). Theprojectneedstoprovidean explanation /justificationtosupportthepropersizingofthemotoroverloads.EA requires verification of this action. (See Observation E3)

f. ECN L5ll4 (Reference 56) - CVCS 62, SIS 63, and RHR System 74--This ECN involved removing the IX relay contact used to seal in a local breaker close signal in the 6.9-kV SHDN BD breaker control circuitry. EA Electrical's review found that adequate evaluations were provided and were consistent between the involved systems except for the following items:

(a) The wrong design criteria was used to evaluate the design change.

(b) The seismic analysis was not marked as being evaluated.

TheaboveproblemswereidentifiedtotheprojectinactionitemE-42. In responsetotheseconcerns,theprojectre-reviewedtheECNandrevisedthe design review checklist to correct the identified problems. This C/A was verified and found to be acceptable by EA Electrical,

g. ECN t$114 (Reference %) - Auxiliary Feedwater System 38-This ECN involved removing the IX relay contact used to seal in a local breaker close signal in the 6.9-kV SHON B0 breaker control circuitry. This ECN also involved systems 62, 63, and 74 and was chosen to evaluate the project's consistency of ECN reviews when more than one system was involved. The design review checklist evaluation was found to be adequate r.nd consistent with the involved systems except for the following items:

(1) AreferencetotheB/Mwasincorrectlyusedasthebasisofjustifying acceptable wiring and insulation conpatibility.

(2) Seismic analysis was not marked as being evaluated.

(5) A drawing was incorrectly referenced for the evaluation of automatic / manual operation.

The above problems were identified to the project in action item E-41. In response to these concerns, the project re-reviewed the ECN and revised the design review checklist to correct the identified problems. This C/A was verified and found to be acceptable by EA Electrical.

h. ECN L536) (Reference 57) - AP SYS-This ECN involved adding load shedding relay contacts in series with the 6.9-kV emergency feeder breaker close circuit so that the loads will be shed before the emergency feeder breaker closes. This ECN was initiated to resolve NCRSQNSWP8026 (reference 72) which identified possible damage to the DG if the DG were running at rated speed and voltage for testing and an accident signal was given such that the emergency feeder breaker closed and connected the DG to a fully loaded 6.9-kV SHDN BD. The EA Team's review of the checklist evaluation for th!s ECN found that adequate evaluations were provided except for the following items:

7.5.2-8

(l) An improper reference to an Appendix R calculation was given to address the circuit protection aspects of this ECN.

(2) The effects of the response time of this change upon the DG were not adequately evaluated.

(5) Theproject'sextentofreviewofthisECNincludedanONP-generateddrawing discrepancy; however, no specific document number was identified to permit verification.

(4) The intent of the ECN was not met by the final design that was implemented and did not consider the potential occurrence of load breaker failures.

The above deficiencies were identified to the project in action items E-65 and E-72. Theprojectrespondedtothesedeficienciesbyre-reviewingtheECNand t revising the design review checklist evaluation, in addition, SCRSQNEEB86206 (reference 73) was initiated to resolve the implementation problem with the ECN.

Revision 2 of the design review checklist for this ECN was reviewed by the EA Team and found to adequately address the problems identified above. C/A identification for SCRSQNEEB86206 was not completed for EA review to assess the acceptability. (See observation E3.)

1. ECN L657) (Reference 58) - AP SYS--This ECN involved removing the auto-transfer from the normal feeder breaker to the alternate breaker tripping the normal feeder breaker and reducing this tripping time. The EA Electrical review of the project's SQEP-12 design review checklist for this ECN found that adequate evaluations were provided for the applicable checklist items except for the following:

(1) An improper reference to a penetration calculation was given to address the circuit protection aspects of the ECN.

(2) An inadequate evaluation was provided to address the response time aspects.

(5) Drawing discrepancies involving 45N765-1 R16 (reference 74), 45N765-18 R2 (reference 75), and this ECN were identifled.

(4) The USQO for this ECN appeared to be inadequate since the relaying changes and offects were not addressed.

Deficiencies (1), (2), and (3) were identified to the project in action item E-69. Deficiency (4)wasdirectedtotheprojectinactionitemE-68, in response to the deficiencies presented in these action items, the project re-reviewed the ECN and revised the ECN design revlow checklist calculation and the USQO.

Revision 2 of the design review checklist for ECN L657) and revision 2 of the USQO were reviewed and found to adequately address the above deficiencies. In response to deficiency (3) presented in action item E-69, the project's action to correct the drawing discrepancies is not conplete and requires EA verification.

(See observation E5.)

7.5.2-9

j. ECN L5449 (Reference 4) - AP SYS--This ECN involved modifying the existing degraded voltage relaying scheme to comply with NRC requirement. This was accomplished by replacing the existing undervoltage relays with more sensitive pickup relays, adding timing relays, and revising the relaying and tripping relay logic scheme. The design review checklist for this ECN was found to be adequate with the exception of the following deficiencies:

(1) An inproper reference to an Appendix R calculation was given to address the circuit protection aspects of the ECN.

(2) A reference to the 8/M was inproperly used as the basis of electrical cable insulation compatibility.

l (3) The seismic qualification of the devices added by this ECN was not addressed.

(4) Inadequate justification was given for the instrumentation evaluations.

(5) The degraded voltage relays were apparently procured with an incorrect control voltage range as evidenced by the B/M for the relays.

(6) In evaluating the response time setting of the relays, there was an apparent discrepancy with the FSAR.

(7) Drawing discrepancies involving 45N724-3 Rl6 (reference 76), 45N724-4 Rl6 (reference 77), and 45N765-18 R2 (reference 75) were also identified as needing correction.

(8) The USQO did not address the loss of voltage relay logic added by the ECN.

Deficiency (2)wasidentifiedtotheprojectinactionitemE-45. Deficiencies (1) and (3) through (7) were documented in action item E-64, and deficiency (8) was directed to the project in action item E-63. In response to these deficiencies,theprojectre-reviewedtheECNandrevisedthedesignreview checklist evaluation and the USQO. Revision 2 of the design review checklist for ECN L5449 and revision I of the USQ0 were reviewed and found to adequately address the above deficiencies.

However, action item E-64 remains open to verify the C/A of PIRSQNEEB86144 (reference 78) which will address the apparent voltage range discrepancy discovered in this ECN review. (See observation E).)

k. ECN L5872 (Reference 6) - Ventilation System 30 and AP SYS--This ECN covered the addition of fans and associated ductwork to each DG room to provide cooling for the DG and its electrical control cabinets. This ECN was chosen to evaluate the l project's consistency of ECN review when nere than one system was involved. EA l Electrical's review indicated that the project's design review checklists were I technically adequate and consistent for the two systems except for the following:

(1) FSAR text was not revised to reflect the change.

(2) The fan logic diagram was incomplete.

7.5.2-10

(3) The fan flow diagram was incorrect.

(4) The instrLanent tabulation for the handswitches was incorrect.

(5) No instrumentation had been provided to specify starting of the additional fans, even though it is required to operate to protect the DG and its associated electrical panels.

(6) Inadequate evaluation was given to the material conpatibility question.

(7) The B/M was inproperly referenced to address the basis of acceptable cable insulation compatibility.

(8) Cable thermal requirements were evaluated as "not applicable," but no CAQ was written.

(9) Seismic qualifications were not addressed for the components.

(10) The ISCs were not adequately described.

(ll) Redundance, diversity, ar6 separation requiraents were not adequately described.

(12) An incorrect calculation was used to reference circuit protection.

The above concerns were documented in action items E-49 -50, 45, -46, -41, and -59. Theprojectresponsetotheseactionitemsincluded:

(1) Issued punchlist item 467) isystem 50) to correct items (1) through (4) and identified action for phase ll; this was satisfactory.

(2) Issued revision 2 of the design review checksheet to cover item (6) which was reviewed and found to be acceptable by the team.

(3) Corrected items (7) through (12) which were covered by action items E-45,

-46, -41. -52, and -59 by revised checksheets. This was acceptable to the electrical review team.

(4) Initiated a PIR for the fifth deficiency documented in action item E-50 which was subsequently upgraded to SCRSQNEEB8728 (reference 79). This SCR, which was written in response to the lack of control room indication and of fan operability, contained inadequate C/A. This is discussed in section 7.7.2.1-4 (item b). (See CAQR SQE870R01004.)

1. ECN L6667 (Reference 59) - CSS 72--ECN L6667 modifled the open and close control circuits in four MOVs in the CSS. The modifications removed the torque and type ao limit switches in the open mode and changed the ao limit switches to a type ac limit switch in the close mode. The design review checklist evaluation for the ECN indicated that adequate evaluations were provided except for the following:

I 7.5.2-11

. (l) The checklist did not show that the ECN workplan took IE notice 86-29 into account as required by the USQO.

(2) There was an apparent conflict between the USQO and the workplan in that the workplan called out the need to perform a valve stroking time test but the USQO indicated that the ECN changes would not affect the valve stroke time.

(3) Reference to standard drawings for cable splice was incorrectly used.

(4) No coordination was indicated with the Civil Engineering Branch for seismic evaluations.

(5) No indication was given on the checklist that follow-up action would be coupleted on a functional test which was still needed.

TheabovedeficiencieswereaddressedtotheprojectinactionitemE-61. The project responded to these deficiencies by revising the design review checklist evaluations and by adequately explaining why a conflict existed between the workplan and the USQO in this area. The checklist revisions were verified by the EA Electrical. This was acceptable,

m. ECN L5970 (Reference 5) - CSS 72-This ECN replaced eight valves in the CSS in czpliance with NUREG-0588 to provide environmentally qualified equipment. The design review checklist evaluation for this ECN Indicated that adequate evaluations were provided except for the following:

(1) Insufficient documentation was available to show valve operators installed by the change were exact replacements for the existing valve operators.

This concern was addressed to the project in action item N-34, which covered the generic problem of using the EQ program in lieu of required doctanents.

in response to this concern, the project revised the design review checklist evaluation to properly an w er the concern. Item B.2.a was verified by EA Nuclear and found to be acceptable.

(2) The B/M was inproperly referenced to address the basis of acceptable cable insulation compatibility. This concern was addressed by action item E-45 which generically covered the B/M problw In responding to this concern, the project revised the design review caeck!ist evaluation to properly answer the concern. Item B.2.b was verified by EA Electrical and found to be acceptable,

n. ECN L6712 (Reference 60) - Auxiliary Feedwater Control System 46-This ECN '

involved replacing the normel feeder cables to the TDAFP contioIs and the TDAFP room DC vent fan. The design review checklist evaluation of this ECN was found to be adequate except for the following:

(1) A reference to the B/M was inproperly used as tre basis of cable insulation and wiring conpatibility.

(2) The ventilation loading was inproperly evaluated as being increased.

(3) An incorrect calculation was referenced as applicable to this ECN.

7.5.2-12 s .. .

1 f

(4) Problems were identified in the applicable voltage drop calculation.

(5) No CAQ was identified for evaluating the cable thermal requirements.

(6) No evaluation was provided for the seismic analysis determination.

(7) Recently issued FCRs that were applicable to the ECN review were not listed as being used in the evaluation.

The above deficiencies were identified to the project in action item E-SI. In responsetothesedeficiencies,theprojectre-reviewedtheECNandrevisedthe design review checklist evaluation and issued SCRSQNEEB8793 (reference 80).

Revision 2 of the design review checklist for this ECN and the SCR problem description were reviewed by the EA Team and found to adequately address the problems identified above. However, C/A of SCRSQNEEB879) was not evallable for EA verification. (See observation E3.)

o. ECN L5451 (Reference 7) - DG Startina Air System 82-This ECN involved modifying the DG lube oil system by adding a redundant AC lube oil pinp and a DC lube oil pump to ensure a consistent oil supply is circulated through the engine. The design review checklist evaluation of this ECN was found to be adequate except for the following items:

(1) The USQO of this ECN did not cover the full scope of changes inplemented by this ECN.

(2) A reference to the B/M was inproperly used as the basis of cable insulation and wiring conpatibility.

(3) Inappropriate calculations were referenced to address the board capacity, voltage studies, voltage drop, and battery loading.

(4) An inadequate evaluation was provided to address the circuit protection aspects.

(5) Seismic qualification of electrical devices was not addressed.

(6) A supplemental walkdown was not identified to verify the as-constructed electrical aspects of the ECN.

(7) No calculations existed to address the loading of the 125-DC DG battery.

TheabovedeficiencieswereidentifiedtotheprojectinactionitemsE-47,E-45, E-46, and E-48. In response to these deficiencies, the project initiated the following corrective actions:

(1) The ECN was re-reviewed and the design review checklist evaluation and the USQO were revised [ deficiencies (1), (5), (4), (5), and (7)).

(2) A supplemental walkdown of the 125V DG battery system was performed

[ deficiency (6)).

7.5.2-1) i

i (3) The meth'od used for addressing the electrical cable insulation and wiring compatibilliy was changed to appropriately reference the EQ binder for-cables in a harsh environment, and for cables not in a harsh environment, the design criteria for cables and the design standard drawing for cable splices were used as the basis of review acceptance. The above C/As by the

, project were reviewed by EA Electrical and found to be acceptable

' [ deficiency (2)].

As a result of the large number of EA Electrical action items on various SQEP-12 electrical support design review checklists, the project re-reviewed all checklists prepared by the electrical support section to determine the extent of discrepancies in the checklists. [See memorande from J. E. Staub to J. F. Cox dated 12/11/86 (reference 81)]. The results of the re-review were documented in 7 a memorand e from J. F.'Cox to J.' W. von Weisenstein dated 2/II/87 (reference 82). The re-review covered approximately 600 checklists with 500 checklists being revised. During the re-review, approximately 150 punchlist items were written which included 14 PIRs. The problems identified in the re-review of these checklists were incorporated into the system evaluation reports. The revised checksheets (ECN L5451 RS-System 82, ECN L6712-System *6, ECN 2945 Rl-VP SYS, ECN 2945 Rl-System 30, ECN L6544 R2-Systems 62, 63, and 74, EUI L5599 R0-VP SYS) were sampled by EA Electrical and verified as having incorporated the needed corrections.

p. ECN L6386 (Reference 61) - WP SYS-The purpose of this ECN was to replace the rod.

insertion recorder, ZR-65-5070, Westronics Model Mll8, with a state-of-the-art recorder Westronic Model MllE. This new recorder provides more reliability and maintenance free operation than the old model recorder. The ECN and the e project's ECN review checklist were reviewed and found to be technically adequate,

q. In addition to the above concerns raised, the following concerns regarding SQEP-12 RC and RI in action items E-7, E-17, E-75, and E-76:

(1) SQEP-12 R0, design review checklist, Attachment 2, item 5.b, did not cover t ,

120V AC inverter loading (action item E-7).

,. (2) SQEP-12 R1 (reference 83) deleted the entire set of evaluation questions contained in "C" of SQEP-12 R0 (reference 84) (action item E-17).

'=  ?

(3) The ccamonly used answer, "The change will not cause a simultaneous short

' 5 which would cause a loss of the board," to SQEP-12 checklist question

^

B.3.C. "The changes create an electrical problem in any of its failure modest" does not adequately document that a comprehensive' failure analysis has been done (action item E-75).

t (4) During the EA Electrical review of SQEP-12 R2 checklist for ECN1, L5944 (reference 85) and L6459 (reference 86) It was noted that the control rod drive mechanism cooler fan motors and lower conpartment cooling fan motors were removed from lE qualification as they do not perform safety functions.

Calculation SQN-OSG7-058 was performed to cover non-class lE loads fed from Class lE power sources. However, neither ECN L5944 nor L6459 were addressed

> by the calculation or its revision (action item E-76).

i

, 7.5.2-14 1

in response to these deficiencies, the project:

(1) Revised SQEP-12 R2 to add the inverter loading to question 5.b of the Attaclunent 2 checklist.

(2) Explained that the pertinent questions in Section C of SQEP-12 R0 checklist were covered by specific questions in Section B of the checklist. These questions were to tie the questions in Section B together to perform a system evaluation and identify deficient areas.

(3) Issued Directive No. D8VP-086-27 (reference 87) to address checklist item B.3.C and initiated PlRSQNEE88617 (reference 88) to cover the inposed voltage problem.

(4) Incorporated ECNs L5944 and L6459 into revision I of calculation 10CFR50.49(2)-l dated February 25, 1987 (reference 89).

Items (1), (2), and (4) above were acceptable. However, for item (3) (action item E-75), the project had not provided a resolution of the inposed voltage problem for all af facted systems in the DB&VP. (See observation E3.)

7.5.2.2 Conclusions EA Electrical concluded that upon completion of appropriate C/As, the project's ef forts in assembling, evaluating, and documenting change documents were performed in accordance ,

with the governing procedures and were technically acceptable. iA Electrical concerns resulted in an extensive project C/A program to re-review ECNs and establish appropriate C/A for any identified deficiencies. This program identified approxinetely 150 punchlist items including 14 PIRs-12 for problems with design criteria and two for lack of calculations. These problems were incorporated into the SYSTERs resulting in an enhanced change document evaluation. The only remaining activity is the EA verification of projectC/As. (See Observations E3 and E4, and CAQR SQE870R01004.)

7.5.2.3 References issue Reference Document Revision Date Title i SQEP-il 4 8/18/06 Procedure for identifying and Assembling 4 Change Documentation 2 SQN-OSG7-048 2 8/6/86 Identification of Systems Required for Sequoyah Restart 3 SQEP-12 2 7/23/86 Procedure for Evaluating Engineering Change Notice and Field Change Notice Documents (SWP 820513 540) 4 ECN L5449 0 5/13/82 Modify Degraded Voltage Relaying to Congly with NRC Requirements on Degraded Grid Voltage 7.5.2-15

5 ECN L5970 1 1/6/06 Replace Valve Operator to Add Qualification per NUREG 0588 6 ECN L5872 1 5/5/84 Add Fan and Associated Ductwork to Each Diesel Generator Room (PWP 840517 504) 7 ECN L5451 3 10/23/86 Modify tube Oil System to Prevent Damage (825 861023 502) 8 ECN 2768 2 t/18/86 Add Reactor Level Instrumentation (825 860ll8 513) 9 ECN 2777 0 5/14/80 Add Reactor Head Venting Systems (SWP 80514 516) 10 ECN L5085 0 8/19/80 Replace Diesel Generator Battery Rack in Battery Board Room (SWP 800819 500) ll ECN L6652 0 3/28/06 Drill Weep Holes in the Bottom of L-Panel Junction Boxes (825 860328 507) 12 ECN L5339 0 10/27/80 Change Solenoid Valves (SWP 801027 504) 13 ECN L5320 0 10/9/80 Change AC Feeder to the Flow Control Instrument Loop on the Auxillary Feedwater Pts @ Turbine (SWP 801009 591) 14 ECN L5864 0 3/28/83 Remove Space Heaters from Drawings (IMP 830518 511) 15 ECN L5867 0 4/8/83 Modify Fuel Transfer System by Westinghouse (PWP 830518 523) 16 ECN L5817 0 6/3/83 Modify Containment Curbs (PWP 850711518) 17 ECN L5880 2 2/18/86 Identify All Fuses With A Unique identifier (B25 860218 503)

J 18 ECN 1849 1 3/7/79 Waste Disposal System (SWP 820103 500) 19 ECN L5153 0 12/19/79 Changes to the Main Control Boards (SWP 791219 517) I 20 ECN L5156 0 3/7/80 Change Set Points on Pressure Switches (SWP 800307 500) 21 ECN L5158 0 7/17/81 Replace 125-V DC Diesel Batteries (SWP 810717 500) l 7.5.2-16

22 ECN L6455 0 8/27/85 Replace 6-V Batteries and Modify A5-24 Board (825 061126 506) 23 TACF 2-84-115-3 0 6/19/86 Cable Routing Changed for 2FM4481 24 TACF 2-85-2007-30 0 12/15/06 Install a Nonqualified Motor or Reactor Lower Compartment Cooler Fan 2A-A 25 TACF 0-85-0004-317 0 12/19/06 Remove a 70-A Breaker to 480-V Auxiliary Building Connon Board MCCA Conpartment 8C2 to be Used to Send the 5th Vital Battery Charger 26 NCRSQNPWP8401 0 2/21/84 Target Rock Nuclear Grade Process Solenoid Valves (PWP 840221 002) 27 NCRSQNEE88612 0 1/31/86 Compatibility of Supplemental Equipment (843 8602ll 934) 28 NCRSQNEE88306 0 3/29/83 Environmental Qualification-ASCO Solenoid Valves (EE8 830330 932) 29 SCRSQNNEB8510 0 7/29/85 Environmental Qualification-Barton Transmitters (B45 850730 851) 30 SCRSQNEE88517 0 8/16/85 Environmental Qualification Instrument Accuracies (B43 850819 903) 31 NCRSQNEE88108 0 12/16/82 Primary Containment Air Lock Electric Penetrations are not Documented to be Environmentally Qualified (EEB 821216 936) 32 NCRSQNEE88lIl 0 2/6/81 440-V Motors Were Powered from 400-V Power System (EE8 810417 907) 33 NCRSQNEE88113 1 10/28/82 120-V AC Vital Inverters (EE8 821029 917) 34 NCRSQNMEB8105 0 6/26/81 Defective Governor Droop Lever Spring (ME8 8ll110 026) 35 NCRSQNEE879-15 I 9/28/79 Improper coordination of Maxinun Available Fault Current, Current Transformer Rating and Total Circuit Burden (EEB 830406 937) 7.5.2-17

I 36 NCRSQNEEB8510 0 3/31/85 Environmental Qualification NAMCO Limit Switches (EEB 830406 957) 57 NCRSQNEEB8502 0 2/20/85 Environmental Qualification - Terminal Blocks (EEB 85022 %I) 58 SCRSQNEEB8529 0 12/6/85 WBN Conduits Containing 400MCM Cables That Exceeded the Conduit Fill (B45 851220 904) 39 NCRSQNEEB0509 0 4/24/85 The 5the Vital Battery and Battery Rack (B45 850502 927) 40 SCRSQNEEB8602 0 1/6/06 Conputer-routed Cable Lengths are inadequate for OE Calculations (B45 060123 902) 41 L-DCR L-1306 0 12/19/ % Field to Determine Settings on Instrument Transformer 42 L-DCR L-1478 0 12/19/86 Install a Spigot in the Water Line to Each Vital Battery Room

4) L-DCR L-1501 0 11/8/06 Provide Separate Control Power to the Flow Switches and Level Switch 44 86-DD-201 0 5/25/86 ONP4enerated Drawing Discrepancy (B28 861206123) 45 AC-236 0 11/26/86 ONP-Generated Drawing Discrepancy (B28 861204 213) 46 AC-277 0 5/23/86 ONP-Generated Drawing Discrepancy (828 861206 123) 47 AC-289 0 12/16/ % ONP-Generated Drawing Discrepancy (B28 861218 008) 48 86-D0-35) 0 12/2/86 ONP-Generated Drawing Discrepancy 49 86-00 " 2 0 12/2/06 ONP-Generated Drawing Discrepancy 50 45N767-5 16 8/8/86 Wiring Diagram 6900-V Diesel Generators 51 ECN L6544 2 1/18/86 Change Drawings to Delete Jumpered Out Limit Switches, Simplify Schematics, Correct Drawing Discrepancies and Remove Valve Heaters (B25 860ll8 553) 7.5.2-18

52 ECN L6676 0 06/2/06 Insufficient Operating Voltage to Operate the Motor Brakes on the Main Feedwater Isolation Valves (R25 860603 501)

- 53 ECW 2774 0 3/13/81 Replace Motors on MOVs 2-FCV-l-16-A and 2-FCV-l-18-13 with 25 ft-lb Motors (810416504) 54 ECN L6015 0 11/30/83 Change oil Heaters from 600 Watt to 285 Watt for Auxiliary Building Chiller Packages (PWP 831220 501) 55 ECN 2945 1 4/14/81 Replace DC Power Vent Exhaust Fan and Fan Wheels on Both Fans (SWP 810414 510) 56 ECN L5114 1 2/23/81 Remove IX Relay Contact Used to Seal in Close Signal on 6.9-kV Shutdown Board areaker Control Circuits 57 ECN L5363 0 Ol2/II/80 Interlock the Emergency Feeder Breaker -

Automatic Close Circuit to Ensure That Load Shedding Has Occurred (SWP 80!211 501) 58 ECN L6573 0 1/23/86 To Eliminate Necessity for OE Analysis of the Slow-bus Transfer Scheme (825 860212 505) 59 ECN L6667 1 6/11/86 Remove Torque and 8ypass Limit Switches from the Control Circuit on MOVs (825 860611 503) 60 ECN L6712 0 6/19/06 Replace the Normal Feeder Cable for the Turbine Driven Auxiliary Feedwater Pump (TDAFP) Control Circuit and Recable the TDAFP Room OC Vent fan Motor Starter Circuit (825 860619 522) 61 ECN L6386 2 1/14/86 Replace Rod Insertion Limit Recorder (825 060114 508) 62 SCRSQNEQP8531 1 II/26/85 Environmental Qualification of IE Equipment for Postulated Accidents (870 851127 012) 7.5.2-19

63 SCRSQNEQP8606 0 1/10/86 The Main Feedwater isolation Valves Must Operate at 75% of Rated Voltage While Calculated Degraded Voltage for These Valves Range From 65.2% to 78.6%

(870 86011 002) 64 SQN-DC-V-II.3 5 9/30/85 Power, Control and Signal 65 PIRSQNEE88671 0 2/13/87 Cable Thermal Analysis Was Not Made (825 870223 048) 66 45N779-24 20 7/16/86 Wiring Diagram 480-V Shutdown Auxiliary Power 67 45N2749-il 10 7/16/86 Wiring Diagram 400-V Reactor MOV BD 242-A 68 45N2750-1 11 7/2/00 Wiring Diagram 400-V Reactor MOV B0 281-8 69 SQN-DC-V-1I.4.I 2 7/22/06 NormaI and Emergency AC Auxiiiary Power Systems 70 45N751-4 19 12/10/85 Wiring Diagram 480-V Reactor MOV B0 lA2-A 71 45N751-8 18 12/10/85 Wiring Diagram 480-V Reactor MOV B0182-8 72 NCRSQNSWP8026 12/8/80 Interlocks on Emergency Feeder Breaker to the 6.9-kV Shutdown Boards to Ensure That Loading Shedding has Occurred Before the Breaker is Closed 1/23/87 ECN L5363 was Prematurely Closed and 73 SCRSQNEEB86206 Interlock on the Emergency Breaker to the Shutdown Boards (825 870209 005) 74 45N765-1 16 8/l/86 Wiring Diagram 6900-V Shutdown Auxiliary Power 75 45N765-18 2 6/3/83 Wiring Diagram 6900-V Shutdown Auxiliary Power Train A & B 76 45N724-3 16 7/7/82 Wiring Diagram 6900-V Shutdown Board 2A-A 77 45N724-4 16 /7/83 Wiring Diagram 6900-V Shutdown 80 28-8 78 PIRSQNEEB86144 0 11/14/86 Discrepancies in Degraded Voltage (B25 870150 038) 79 SCRSQNEEB8728 0 1/20/87 Diesel Generator and Electric Panel Ventilation fans Are Required to Start to Maintain inlet Air to 120* or Less (825 870130 048) 7.5.2-20

80 SCRSQNEE88795 0 2/13/87 Cable Thernel Analysis Was Not Made (825 870225 048) 81 825 861211 002 -

12/11/86 Memorandum J. E. Staub to J. F. Cox l

82 825 870211 034 -

2/11/87 Memorandtsn J. F. Cox to l J. W. von Weisenstein l 83 SQEP-12 1 6/12/06 Replace Rod insertion Limit Recorder (825 860114 500) 84 SQEP-12 0 5/15/86 Procedure for Evaluating Engineering Change Notice and Field Change Doctanents 85 ECN L5944 4 2/3/84 Ventilation System and Chemical and Voltane Containment System (PWP 840203 516)

% ECN L6459 0 9/17/85 System 50, Class IE Classification Not Needed for Low Conpartment Fan Motors (825 850917 005) 87 D8VP-006-27 0 -

SCR/NCR Reviews for SYSTER Justification of Open CAQs to be included in DB&VP (825 861289 056) 88 PIRSQNEE88617 -

1/29/87 The Inposed Voltage Problem on Checklist Question 8.5.C 89 10CFR50.49(2)-l i 2/25/87 Nonsafety-Related Equipment inportant to Safety 7.5.2-21

7.5.3 Instrumentation and Controls The project's evaluations of design change documents were reviewed to ensure that the assessments of those documents accurately and sufficiently verified that the plant modifications iglemented or proposed by those documents did not degrade any engineered safety features.

The EA review of the project's evaluations was cogleted in two segments. In order to ensure that all change documents pertaining to the DB&VP project had been identified and accurately categorized by the project, ECN identification forms were reviewed. The review was cogrised of assessing the project's evaluation of each ECN in terms of its system applicability and DB&VP applicability and assessing the project's compliance with procedure SQEP-II (reference 1).

In order to ensure that the project's evaluations of design change documents were technicallysound,projectECNevaluationswerereviewed. The ECNs selected for review were representative of ISC cogonent modifications and replacements, changes to ISC cogonent setpoinh, and modifications to ESF design.

The following aspects of the project's evaluation of ECNs were reviewed:

a. Conclusions on prerestart or postrestart iglementation of modifications.

b. Evidence that appropriate design basis requirements had been recognized in evaluating modifications,

c. Evidence that all applicable design aspects of the modifications were adequately evaluated and deficiencies were recorded for future resolution.

d. Sufficient documentation and/or rationale was included and/or referenced to support conclusions on design adequacy,

e. Cogliance with the requirements of procedure SQEP-12 (reference 2).

7.5.3.1 Details The following 9 ECNs were reviewed for accurate system and boundary determinations:

L6667, L5527, E2641, L6359, L5734, L55l4, L6389, 2873, and L5275 (references 3 through II).

The EA review of the above ECNs concluded that, in general, the project accurately determined system and DB&VP boundary applicability except in one case.

ECN 2873 (reference 10) should have been categorized as affecting Reactor Protection System 99 and RHR System 74. EA l&C notified the project of the inaccuracy, and the projectaddedthosesystemstoitsbcundarydeterminationsheetwithouttheneedofan action item. EA l&C verified that the system applicability of the ECN had been accurately corrected.

7.5.3-1

The project technical evaluations for the following 10 ECNs were reviewed by EA l&C for technical adequacy: L6559 System 87, L5791 System 5A, L6404 System 65, L5884 System 72 L6175 System 52, L6254 System 38, L5600 System 65 L6124 System 38, L5275 System 65 (references 12 through 20), and L5754 System 75 (referenco 22). Additionally, EA l&C performed a progranmatic review of an early draft ECN evaluation, L5055 System 74 (reference 21).

The EA review of the above ECN evaluations concluded that ECN L6175 was totally adequate and all of the remaining evaluations were adequate only in a few areas. Several concerns resulted from this review, including some by the NRC, and are presented below:

a. ECN L6559 System 87-ECN L6559 System 87 (reference 6) facilitated the substitution of UHI tank-level switches. The ECN design review checklist (reference 12), item 6A, categorized the component seismic qualification of the substituted level switches to be "not addressed," and referred to a PIR "to be issued." Procedure SQEP-12 (reference 2) required that a CAQ report be issued in such cases. A specific CAQ was not referenced in the project's review checklist. The concern was forwarded to the projectinactionitemI-21. The concern was alleviated with the establishment of a project punchlist that addressed the lack of seismic qualification documentation.

(Foradditionaldiscussionontheprojectpunchlist,refertosection7.5.1.1.)

Checklist item 10E recognized the lack of range and accuracy documentation for the new level switches, but did not provide any assurance that proper range and accuracy would be confirmed. Additionally, checklist item 10H defined switch setpoint considerations as r.ot applicable. Whereas setpoints are largely governed by instrument accuracy, and instrisnent accuracy is in turn affected by instrument range, the project checklist conclusions were contradictory. ActionitemI-22wasissuedtotheprojectto reconcils the concern. The project revised the checklist and establisted punchlist item 2042, System 87, to ensure the development of an appropriate calculation. .

b. ECN L5791 System 5A-The project checklist (reference 15), item I, referred to Design Criteria SQN-DC-V-4.2 (reference 25) as a design basis reference for modifying the SG low low-level setpoints. A review of the design criteria revealed that it did not establish a design basis for those setpoints. The ECN review checklist item 10H referred to the ECN workplan as the design basis reference for the SG-level setpoints. Whereas the workplan is a support doctsnent of the ECN, the workplan did not constitute the design basis of the ECN. These concerns were forwarded to the project in action items 1-25 and I-24. Theprojectestablishedthatthedesignbasis was included in the Westinghouse Precautions, Limitations, and Setpoints (PLS) document; the project issued PIRSQNEEB86126 (reference 24) to add Westinghouse PLS (reference 25) design requirements into Design Criteria SQN-DC-V-4.2 (reference 25) and to review the potential omission of Westinghouse PLS setpoint data in all SQN design criteria.

c. ECN L6404 System 65-The project's ECN review checklist (reference 14) for ECN L6404 System 65 recognized the lack of component seismic qualification documentation for replacement limit switches. AsinotherprojectECNevaluations,itdidnotrefer to a tracking system to ensure resolution of the missing seismic qualification docisnentation. Additionally, the checklist indicated that limit switches were not attached to a seismically qualified component. The limit switches were in fact 7.5.5-2

directly attached to a safety-related valve (FCV-65-72). Those concerns were forwarded to the project in action item I-27. The project established punchlist item 0907 and initiated PIRSQNCEB8657 (reference 26) to ensure adequate tracking of these documentation deficiencies.

d. .ECW L5884 System 72-The project's, review checklist (reference 15) for ECN L5884 System 72 referred to a purchase requisition as docunentation for the seismic qualification of replacement flow transmitters. Inasmuch as purchase requisitions define design requirements, they do not constitute conclusive documentation of the as-delivered and installed seismic condition. The cor.cern was issued to the project in action item I-25. The project forwarded seismic qualification memorandtsu (CEB 840507 255), reference 27. The memorandum attests to the installed seismic condition of new transmitters. The documentary deficiency cited in this action itemwastypicalofseveralotherprojectECNreviews. The generic concern over the lack of conponent seismic qualification was alleviated by project directive D8VP-D-0-86-010 (reference 28). For additional discussion on the generic C/A, refer to section 7.5.5.1.

The project's design review checklist (reference 15) for ECN L5884 System 72 was also inadequate with regard to instrument range and accuracy verification. The concern was issuedtotheprojectinactionitemI-26. The project established punchlist item 1984 to adequately track its resolution.

e. ECN L6254 System 38--A review of the project's ECN review checklist (reference 17) for ECN L6254 revealed deficiencies which were typical of most l&C sections of ECN '

checklists, i.e., the lack of supporting setpoint dacumentation and/or the lack of any assurance that unidentified calculations would be developed. The concerns were issued in action items 1-28, 1-29, and 1-30. Theprojecteitherprovidedspecificreferences to existing calculations or initiated a PIR and/or a punchlist item entry to ensure adequate resolution of the lacking documentation.

f. ECN L5600 System 65-ECN L5600 System 65 facilitated the routing of instrument sensing lines through a reactor building crane wall penetration. The ECN required the drilling of new crane wall penetrations. A review of the ECN cover sheet did not indicate any endorsement by the civil discipline. Theproject'sECNreviewchecklist (reference 18) did not reconcile that deficiency. The concern was issued to the project in action item I-51. The project issued PlRSQNCEB8659 (reference 29) which required the civil engineering discipline to review ECN L5600 in the disposition of this PIR.

g. ECN L6124 System 38-A review of ECN L6124 indicated that it was also representative of synptomatic project deficiencies in establishing calculation doctanentation. The concernswereissuedtotheprojectinactionitems1-35andI-54. In addition, the project'sECNchecklist(reference 19)indicatedthattheprojecthadnotreferredto drawings 45N779-10 (reference 30) and 45N779-25 (reference 51) which defined time delays inconsistent with those recorded in the ECN. The concern was issued to the projectinactionitemI-55. The project issued PIRSQNEE886159 (reference 32), which provided adequate assurance that the time delay relay settings as recorded on drawings 45N657-5 (reference 55) and 45N779-25 (reference 51) would be corrected in the normal dispositioning of the PIR through the CAQ process.

7.5.5-3

1

h. ECN L5275 System 63--A review of tte project's ECN review checklist (reference 20) I forECNL5275 System 63indicatedthattheproject'spostrestartconclusionwas )

unfounded. The ECN facilitated the replacement of a rotometer type flow switch with

'a differential pressure type flow switch. The project's change document evaluation  !

sheet indicated that the existing flow switch need not be replaced before SQN unit 2 restart. That position conflicted with the text of the ECN, which indicated that

)

the existing low-flow alarm signal on the BIT recirculation line performed unsatisfactorily. The ECN attributed the problem to an inappropriately wide reset band inherent to the existing switch. Theproject'sCDESbaseditspostrestart decision on the existence of adequate adninistrative procedures that ensured proper operator action following a low-flow indication. The referenced administrative procedurewasnotspecificallyidentifiedbytheproject. Based on the lack of a specific reference to the adninistrative procadure, action item 1-36 was issued to the project. The project identified S01-55-2M6-XA-55-60 (reference 34) as the applicable adninistrative procedure. The EA Team reviewed the Sol and concluded that it included proper administrative procedures.

A multitude of undocumented conclusions within the project's ECN evaluation checklist with regard to fluid system operating conditions were noted, such as item 2f corrosion characteristics, item Bf effect on fluid temperature, and item 10H setpoint effects.

The concerns were directed to the project in action items 1-37 and 1-38. However, with the resolution of action item 1-36 (i.e., the flow switch replacement need not be implemented before plant restart), action items 1-37 and 1-38 became irrelevant and furtheractionbytheprojectbeforerestartwasnotrequiredtoresolvetheconcerns.

1. ECN L5734 System 63--ECN L5734 (reference 7) regarded a drawing revision which had been omitted from the drawing ravision scope of previotis ECN 2873 (reference 10). The projecthadinadvertentlyperformedatechnicalevaluationofECNL5734intermsof the design chanos inposec by ECN 2873. AnEAreviewoftheproject'sevaluation noted numerous inconclusive determinations concerns idich were forwarded to the project in acti Q i.tems 1-39, 1-40, 1-41, 1-42, and I-43. The project established that ECN L5734 only constituted a drawing revision which resulted from design changes facilitated by ECS.'2873. Inasmuch as ECN 2873 was a preoperational design change, a technical evaluation was not in the scope of the D88VP. Theproject'sevaluationof ECN L5734 was subsequently revised to reflect its " documentation change only" status.

J. ECN L6374 System 70-ECN L6374 (reference 35) regarded the substitution of pressure switches. Duringareviewoftheproject'sECNevaluation,theNRCnotedthatthe project evaluation had not included doctanentary verification that the substitute switches conplied with the reset requirements prescribed in the ECN. The concern was forwardedtotheprojectinactionitemI-47. The project requested reset perfornance data from the switch supplier. A review of the data by EA confirmed that the switch complied with the ECN design requirements.

k. ECN L5033 System 74-A review of an early draf t project ECN evaluation on ECN L5033 (reference 21) indicated that the project was deferring an adequate human factors evaluation on ECNs by virtue of a separate human factors review program.. SQEP-12 (reference 2) required an evaluation within the DB&VP, thus creating an antpiguity between the D88VP scope and the Htsnan Factors Evaluation Program. The concern was i

forwardedtotheprojectinactionitemI-04. The ant >iguity was resolved when the projectrevisedSQEP-12toappropriatelyeliminatehumanfactorsevaluationsfromthe scope of the D84VP. A review of the revised procedure (reference 2) by EA verified L

that the procedure had been revised satisfactorily.

7.5.3-4

As a consequence of the many defit:lencies noted and forwarded to the project, the project recognized that the omissions were symptomatic and issued memorandtsn (825 061211 002) (reference 30) which directed a generic rework of all ECN checklists.

Subsequent to the rework, six ECNS were randomly selected for review to ensure that the rework was satisfactory: L6359 (reference 12), L5971 (reference 13), L5884 (reference 15), L6124 (reference 19), L5995 (reference 37), and L5882 (reference 38),

in all cases, the revised checklists adequately addressed specific calculation references, and/or added punchlist tracking references, for their instrument range, accuracy, and setpoint conclusions. EA consequently found the rework ef fort to be satisfactory.

As a consequence of pervasive deficiencies in the initial change document evaluations, with respect to calculations, EA 18C participated in an audit of EEB calculations, which related to both the D84VP, and the design basis of the plant. As a result of that audit, the ISC related calculations were determined to be technically sound and essentially conplete.

7.5.3.2 Conclusions With the inprovements made to evaluation methods and criteria during the evaluation program, the resulting evaluations were accurate, sufficiently documented, and conglete.

7.5.3.3 References issue Reference Document Revision Date Title i SQEP-Il 4 8/19/% Identifying and Assembling Change Documentation 2 SQEP-12 0 5/15/06 Evaluating Engineering Change Notice and 2 7/23/86 Field Change Notice Documents 3 ECN L6667 1 6/5/86 Various Systems - Remove Torque and Bypass Limit Switches From MOV Circuits 4 ECN L5527 0 4/28/82 containment Spray System 72 - Add Alarms to Indicate FCVs Not Fully Closed 5 ECN E2641 0 10/24/79 Reactor Coolant System 68 - Minimize Probability for Reactor Overpressurization 6 ECN L6359 0 ll/6/85 Upper-HeadinjectionSystem87- Replace Level Switches 7 ECN L5734 0 9/26/83 Residual Heat Removal System 74 - ESF Reset Controls 7.5.3-5

issue Reference Document Revision Date Title 8 ECN L5514 0 9/18/81 Reactor Coolant System 68 - Revise Contract Nwbers on Relay to RCP Overload Annunciatlon 9 ECN L6389 0 5/2/06 Prinery Water System 81 - Lower Setpoint to Eliminate Tank Overflow 10 ECN 2873 0 10/27/80 Various Systems - Implement IE Notice 80-06 ll ECN L5275 0 3/29/84 SafetyinjectionSystem63-Replace Rotometer Type F1 with Differential Pressure Type 12 ECN L6359 0 9/l7/% Design Review Checklist i 11/22/06 Design Review Checklist 13 ECN L5791 0 8/l4/86 Design Review Checklist i 10/24/86 Design Review Checklist 14 ECN L6404 0 9/19/06 Design Review Checklist 15 ECN L5884 0 9/9/86 Design Review Checklist 2 11/28/06 Design Review Checklist 16 ECN L6175 0 8/19/06 Design Review Checklist 17 ECN L6254 0 8/17/06 Design Review Checklist 18 ECN L5600 0 8/12/05 Design Review Checklist 19 ECN L6124 0 8/l7/86 Design Review Checklist i 12/2/86 Design Review Checklist 20 ECN L5275 0 9/23/06 Design Review Checklist 21 ECN L5033 0 8/19/86 Design Review Checklist 22 ECN L5734 0 8/10/86 Design Review Checklist 23 SQN-DC-V-4.2 1 7/11/86 Design Criteria For Main Feedwater System 7.5.3-6

.h

Issue Reference Document Revision Date Title 24 PIRSQNEE886126 0 10/28/06 Westinghouse PLS Design Setpoint Data Not Referenced in Design Criteria SQN-DC-V-4.2 25 PLS 9 5/81 Westinghouse Document Precautions, Limitations, and Setpoints for NSSS 26 PlRSQNCE88657 0 7/21/86 Seismic Documentation Does Not Exist 27 CEB 840507 255 -

5/17/84 Memo J. W. Rivers to CEB Files (Seismic Qualification) 28 DBVP-0-0-86-010 0 10/15/06 SYSTER Discipline Interface Review 29 PlRSQNCEB8659 0 7/21/06 Missing CEB Seismic Calculations 50 45N779-10 17 II/50/85 Wiring Diagram 480V Shutdown Auxiliary Power 51 45N779-25 24 8/8/06 Wiring Diagram 480V Shutdown Auxiliary Power 52 PlRSQNEE886159 0 11/6/06 Time-Delay Relay Settings 55 45N657-5 12 5/14/86 Wiring Diagram Separation and Miscellaneous Auxiliary Relays 54 Sol-55-2M6- 5 5/17/85 Annunciator Response XA-55-60 55 ECN L6574 0 6/27/85 Replace Dual Snap Model 604 Pressure Switch with U.E. Model 164 56 825 861211 002 --

12/11/86 Memo J. E. Staub to J. F. Cox.(EA Action items on Electrical Discipline Support to SQEP-12) 37 ECN L5995 1 8/19/06 Design Review Checklist 58 ECN L5882 1 12/5/% Design Review Checklist 7.5.5-7

7.5.4 Mechanical i The change documents evaluated included ECNs, FCNs, FCRs, TACFs, SCRs/NCRs, and L-DCRs and ONP-generated drawing discrepancies. The project review of these documents was evaluated against the requirements of SQEP-II (reference 1) and SQEP-12 (reference 2).

Change document identification forms were reviewed against the requirements of SQEP-il to determine if the forms had been cogleted properly and signed by appropriate personnel.

SQEP-ll is primarily a procedure to classify change docunents as to whether they are within the bounds of the DBtVP, and to provide their iglementation status.

For ECNs and FCNs, the EA review considered whether:

a. Pre-OL ECNs on the CWil were adequately identified on an ECN identification form,

b. The systems within the scope of calculation SQN-OSG7-048 (reference 3) that were affected by the changes were correctly identified on the ECN identification form.

c. The changes noted on the cogleted ECN identification form were correctly identified as beino within the bounds defined by calculation SQN 4SG7-048.

For Category D FCRs, the evaluation considw ed whether:

a. FCR and associated ECN nusers were correctly identified on the FCR identification forms.

b. The system assignments for the FCR correctly identified the FCR identification form (including consideration for hazards, interactions, and other system interfaces).

For TACFs, the evaluation considered whether:

a. The TACF adequately noted applicability to those portions of systems identified in the SWRIDs.

b. The iglementation category was correctly specified on the TACF identification form.

For SCRs/NCRs, the evaluation considered whether:

a. The assignment of the SCR/NCR as being within the SWBID boundary was correct,

b. The status category of the SCR/NCR noted on the SCR/NCR identification form was correct.

c. All "0NP" and "lMPL" categorized SCRs/NCRs have a written justification ensuring adequate corrective action, or, where required, new SCRs were issued.

For L-DCRs, the evaluation consider whether:

a. The L-DCR identification form 6dequately identified whether the L-DCR was listed on the i Ollt.

b. The iglementation status of the L-DCR was adequately recorded on the L-DCR identification form.

7.5.4-1

For ONP-generated drawing discrepancies, the evaluation considered whether the ONP-generated drawing discrepancy identification form was correctly conpleted.

Change document evaluation sheets were reviewed in accordance with SQEP-12 (reference 2) for requiredsignaturesandtodeterminewhetheradequatejustificationhadbeenprovidedto support category conclusions (prerestart or postrestart).

The design review checklists prepared for each ECN and FCN in accordance with SQEP-12 were reviewed to determine whether:

a. The change was technically adequate and consistent with design basis documents such as USQDs and design criteria.

b. Adequate explanations and evaluations had been provided to support checklist conclusions.

c. Calculations required to support the change were technically adequate and conglete and addressed the ECN.

d. A CAQ was issued when documentation did not exist or was not adequate.

7.5.4.1 Details

i. SQEP-il Reviews Twenty-eight ECN identification forms (references 4 through 31) were reviewed. All ECN identification forms were correctly conpleted except for ECNs L5415 and L5681.

The ECN identification form for ECN L5415 (reference 11) was not properly signed. This concernwaspresentedtotheprojectinactionitemM-35. Theproject'sresponse indicated that the form reviewed by the EA Team was preliminary and the final issued form was adequately signed. EA verified the adequacy of the signatures.

ECN identification form for ECN L5681 (reference 15) listed only System 32 as being applicable. The ECN was also applicable to System 67 (ERCW System). This concern was presentedtotheprojectinactionitemM-37. In response to the deficiency, the SE on the System 67 reviewed ECN L5681 and determined that the applicable change had no direct impact on the ERCW System 67.

The inplemented change to System 32 was required to satisfy the design requirements of System 67. An evaluation of this ECN for System 32 would have satisfied the requirements of System 67. Therefore, the identification of System 32 only was considered acceptable.

Sixteen SCR/NCR identification forms (references 32 through 47) were reviewed by EA.

All were correctly conpleted except for NCRSQNNEB8117 (reference 35), NCRSQNNEB8138 (reference 37), and SCRSQNNEB8520 (reference 47).

7.5.4-2

Two NCRs (references 35 and 37) did not have sufficient information on the identification form to determine the adequacy of the C/A. This concern was directed to the project in action item E-09. The project's response provided revised identifica-tion forms which contain sufficient information to determine that the C/A was adequate.

SCRSQNNER8520 (reference 47) was incorrectly classified "Open" when it should have been "0NP" (C/A to be determined by ONP). This concern was directed to the project in action item M-09. The project corrected the identification form and determined this to be a one-time occurrence. This action was considered acceptable by EA to adequately resolve this concern.

Fiva Category D FCRs (references 48 through 52), four L-DCRs (references 53 through 56), five ONP-generated drawing discrepancies (references 57 through 61), and four TACF identification forms (references 62 through 65) were reviewed by EA. EA found all of the above to be technically correct.

2. SQEP-12 Reviews Twenty ECNs were revieued (references 66 through 85) to determine if the design review checklists and change doctsnent evaluation sheets were correctly completed and the justificationswereadequ3tetothediscussionsforeachattributeconsideredonthe evaluation form. The following are the results of this review:

a. ECN 2945 System 31-This ECN (reference 66) which replaced fans and f an wheels on certain TDAFP Room HVAC Ventilation System equipment was one of the earlier ECN evaluations reviewed by EA. The evaluation form was coupleted but was not yet formallyissuedbytheproject. Three concerns were raised as a result of the EA review. Certain of the checklist questions in section's 2, 4, 6, and 8 of the checklist htd no answer of any sort. Thisconcernwaspresentedtotheprojectin action iten M-19. The project subsequently revised and issued the checklist to add the req 1 ired evaluations not previously included, except on section 8, " Hydraulic Design Criteria." In this section of this ECN evaluation as well as other HVAC ECN evaluations, the project response was "N/A - No piping systems are involved." The projecthadinterpretedthisquestiontoonlyapplytopipedwatersystems. In a follow-up reply to action item M-19, EA expressed the concern that this section is the only place in the design review checklist where fluid considerations such as pressure drop, fluid tenperatures, velocity, and throttling requirements would be addressed. For exagle, in this ECN a fan was replaced in order to achieve a required maximum air tenperature rise of 10*F within the TDAFP room. Replies to some of the questions in section 8 would have doctsnented the adequacy of the new fan. However, since this section was not used, that conclusion couldn't be reached from the available documentation, in addition, a draf t of the ECN sumnery paragraph to be included in the SYSTER was available for review. It was found to not address postm elfication testing which had verified that the required flows were achieved, and how it was concluded that the required maximum temperature rise was achieved with that flow. EA presented this concern to the project in a revision to action item M-19.

7.5.4-3

In respnnse to this concern, the project conmitted to revise all airside HVAC ECN design review checklists and SYSTER evaluation summery sheets in Systems 30, 30A, 31, and 3lA to more completely address the fluid-related questions in section 8 of the checklists. EA reviewed a sanple of revised design review chet.klists with section 8 conpleted to verify the project action. This adequately resolved the concerns. Ancther concern identitled during the review of this ECN was that certain items on.the checklist identified missing documontation, but did not indicate that PIRs had been written for these items as required by SQEP-12. This concernwasdirectedtotheprojectinactionitemM-20. Theprojectrepliedthat the issued design review checklist would reference PIR nunt>ers where required.

This adequa'ely resolved this concern,

b. ECN L5064 Systen No. 70--This ECN (reference 67) involved replarament of two containment isolation valves which previously had hard seats wi.h valves having soft seats. One of the valves (3-inch 2-70-79) has not been installed; the other (1/2-inch 2-70-698) was installed. All of the attributes evaluated for this ECN were found to be adequate except for two concerns. Checklist attribute B.2.b was checked acceptable and referenced bills of material (B/Ms) (reference 86). The B/Ms identified the valve body material but not the valve seat material. The B/Ms list other documents, such as valve data sheets (reference 87), which state that the design accident radiation dose is 108 rads. Valve vendor drawing TVSW-30604GS-(2) (reference 88) identified the valve seat material as ethylene propylene terpolymer (EPT), and referenced test reports (reference 89) which indicated that EPT has a threshold of I x 107 rads above which property changes occur. It was not clear either from the project checklist nor from review'of referenced documentation that conpatibility of valve seat material to the existing installation was considered. The second concern related to a deficiency in the signing of the document evaluation sheet and ECN checklist. Both forms were signed in the SE block by an engineer in the CCS group rather than the SE as required by SQEP-12. These concerns were presented to the project in action item M-32, in response, the project stated that an evaluation of the valve seat noterial had been considered for other applications in environments of this type, and had been qualified in the Watts Bar Mechanical EQ Program. This was discussed in the evaluation sunmary for ECN L5064 provided in the SYSTER. The mechanical EQ program for SQN will qualify this and other materials formally when the program is performed after restart. The project also conmitted to review other ECN evaluation performed on this system to ensure that similar material conpatibility issues have been addressed.

Finally, the project issued program directive DBVP-D-86-006 (reference 90) which allowed SEs to delegate their signoff authority to others for the preparation of design review checklist while requiring the SE to sign the SYSTER. This adequately resolved this concern.

c. ECN L5095 System 62--The ECN (reference 68) modified test vent and drain connections for containment isolation valve testing. This was one of the earlier ECNsevaluatedbytheproject. There were several concerns raised from the review of this ECN. In many cases, the rationale and/or references to support the conclusions in the ECN checklist were not provided. This concern was presented to 7.5.4-4

the project by action item M-25. As a result of this and similar action items, meetings were held between the EA Team and project personnel to further explain the nature of EA concerns. The project developed guidelines to describe the additional information needed to upgrade the ECN evaluations. The guidelines were issued to both Westinghouse (825 860903 001, reference 91) and TVA SEs (B25 860821 005, reference 92). In addition to the above concern, EA also noted that from the reply to checklist item 6h that there were no dynamic or potentially dynamic loads considered in the analysis of the system, and it was not clear whether there was l documentation available to support this conclusion. The USQO that formed a part of the ECN indicated that no effect on existing seismic analysis was anticipated. it was not clear whether an effort had been made to determine if an evaluation or piping analysis was available to support the checklist conclusion. A copy of the CEB support input checklist for the ECN was reviewed, and it was again not clear whether documentation was available to support the checklist conclusion. These deficiencies were directed to the project in action item M-25. Theproject addressed these deficiencies by taking the following action: CEB revised its ECN docunentation to state that there was an undetermined effect on the alternate piping analysis for the system involved that nust be evaluated. Theproject determined that in some cases modifications which were performed outside the containment isolation boundary to portions of systems which were inside the SWBID boundary needed to be evaluated for civil (stress) effects on the system. A project memorandum was issued to all SEs (B25 861209 014, reference 93), which instructed SEs to perform additional SQEP-12 evaluations for the valves added by this ECN to all of the systems affected (67 containment penetrations in all).It was not clear how the above statement in the USQD (that no effect on existing seismic analysis was anticipated) was substantiated, particularly in view of the civil input for the ECN evaluation that the impact to seismic analysis needed to be checked. Also in certain ECN evaluations, the USQOs alone were used as an explanation as to why an item had been adequately addressed. These concerns were presented to the project by action item M-54.

For the project response regarding adequacy of USQOs, see the discussion for action item M-38 in section f. InresponsetotheuseofUSQOsasjustificationof adequacyofachecklistitem,theprojectrevisedthechecklistsinvolvedand issued a memorandum to all system engineers reminding them to purge any references to USQOs from ECN checklists. This adequately resolved these concerns,

d. ECN L5415 System 30-This ECN (reference 69) was conpleted adequately except that it was signed by an engineer ott.or than the SE. This was resolved as discussed in actionitemM-32forECNL-5064byprojectdirective08VP-D-86-006(reference 90).

e. ECN L5451 System 82-This ECN (reference 70) added an AC and DC lube oil pung to each of the emergency DGs. Theprojectevaluationsincludedadiscussionofthe seismic qualification of the oil piping, but did not discuss the seismic qualification of the conduit which was modified. This concern was presented to the project in action item M-40. The project reply was that the typical conduit support drawings (drawing series 47A056) were used without modifications for this change and therefore did not have to be reviewed by the DB&VP group. EA reviewed the conduit design and found it was adequate. This concern was adequately resolved.

7.5.4-5

f. ECN L5681 System 32-This ECN (reference 71) involved a change nede to resolve a deficiency found during testing relating to insufficient ERCW flow to the auxiliary containment air cogressor af tercoolers. Material (filler bars) was removed from within the heat exchangers to allow increased ERCW flow. The USQD contained two statements which were not supported by documentation within either the ECN or the LCN evaluation: (1) that the function of the auxiliary containment _ air co gressor would not be dagraded by the change,~ and (2) that the euxiliary containment air cogrewor seismic qualification would not be adversely if facted. The ECN referenced a memorandum which stated that the change was a vendor-recomended fix for the problem. However, the referenced memorandum s1ated that the vendor representative came to SQN to investigste the problem, could not find one, and therefore reconmended that further testing be done. The USQD also stated that seismic qualification would not be affected since the ECN cover sheet required that seismic analysis be evaluated. No reference to seismic analysis could be found.

In addition, the CE8 review of the ECN indicated that no analysis was required or performed. These concerns were directed to the project by action item 4 38.

t Theprojectreplyforthefirstitemwasthatasubsequentdiscussionwiththe vendor indicated his agreement with removal of the filler bars to permit greater flow rates, as documented on internal memorandtsn 79110880400. Theprojectreplied for the second item that the procedures in place at the time the USQD was prepared for this ECN required that the USQO be cogleted before the implementation of design work associated with the ECN. In effect, the USQO preparer relied on the branch's comitments to follow up on the appropriate actions identified in the USQO and to correct any adverse findings. Because of concerns raised about the adequacy of this USQD and others (also see action item 5 34), the project is performing a USQO cog leteness verification for all currently open ECNs in accordance with SQEP-Al-ll (reference 94) which is outside the scope of the D84VP. ECNs and USQOs which are being prepared now and for issue in the future will be processed in accordance with SQEP-13 (reference 95) which includes requirements to issue a USQD at the beginning of the ECN process as well as verification that the iglemented change fully agrees with the desigr.. Finally, for work being performed on USQOs for post-OL ECNs that are already closed, the SQEP-12 (reference 2) change evaluation process did address the adequacy of these changes. The USQO for ECN 5681 was subsequently revised to state that seismic analysis was not affected in accordance with the evaluation done by CES as a part of the design baseline program review of the ECN. This adequately resolved this concern.

An additional concern was that certain items were lacking in the ECN evaluation, including operability testing and hydraulic design adequacy. Performance of the modified auxiliary contairvaent air cogressor and the maintenance of required exit air tagerature limits had not been verified. This concern was presented to the project in action item 4 39. Projectreviewofthisitemresultedin PIRSQWlE886lIl (reference %) and punchlist item 6722 to retolve and track this item. This adequately resolved this concern.

(

1 7.5.4-6

_._ _ _ _ _ - . _ _ _ _ _ _ - . _ _ .._____J

A g. ECN L5714 System I-This ECN (reference 72) modified the main stssa check valve balance arms. EA found no record that one of the persons who signed the form had been trained to SQEP-12. Thisconcernwaspresentedtotheprojectbyactionitem M-44. As a result, the individual was trained to referenced procedure. All documents reviewed by the individual to that procedure were re-reviewed for adequacy. A sanple of the ECNs evaluation affected were reviewed by EA and found to be adequate. Finally,aprojectmemorandum(reference 97)fromJohnF.Coxto all lead discipline engineers and SEs dated October 31,1986, reen1phasized the need for all personnel involved in the DB&VP program to be properly trained. This adequately resolved this concern,

h. ECN L5769 Systems 5A and 58-This ECN (reference 75) involved the elimination of chemical feed lines from each of the main feedwater pipes feeding the steam generators. The remaining connections on the feedwater pipes were retained. Upon EA review of the ECN evaluation, concerns were noted regarding project responses to questions on certain checklists. Question P.I regarding whether the change met all the design basis requirements was answered "not applicable" while, in fact, the reason for the change was a requirement of GDC-57 as discussed in the Main Feedwater System Design Criteria. The response for checklist question B.2.C regarding whether the change involves an ASME Code Section 3 conponent was also checked as "not applicable." However, this disagrees with the classification as defined in the Main Feedwater System Design Criteria SQN-DC-V-4.2 (reference %)

which states that the piping is TVA Class B, and that for procurements such as this af ter April 2,1975, ASME Section 3 Class 2 is applicable for this TVA piping class. TheseconcernswerepresentedtotheprojectinactionitemM-36. The project's initial reply was that the applicable code is ANSI B51.1 in accordance with NEB memorandwn (845 860926 254, reference 99) and FSAR tables 3.2.2-1 and 5.2.2-2. These allow procurements after April 2, 1973, for systems in which the design and procurement had already been initiated as of April 2,1973, to be designed to ANSI B31.1. Upon further consideration, it was realized that this r.onflicted with the Main Feedwater Design Criteria and a ntder of other design criteria. As a result, the project conmitted to issue DIMS to revise nine design criteria to reference the previously discussed code tables and to clarify procurement requiremente. Theprojectissuedpunchlistitems774dthrough1756to resolve and track conpletion of this item for each of the nine affected systems.

This concern was adequately resolved.

i. ECN L5842 System 58-The purpose of this ECN (reference 74) was to add cavitating venturies to the Auxiliary Feedwater System to provide runout protection for the auxiliary feedwater pumps. The ECN evaluation was found to be very thorough. The ECN itself included two USQOs, one for the design and one for the poshnodification testing. SQEP-14 (reference 100) provided confirmation that postmodification testing acceptance criteria were met with one exception relating to deficient minimunt delivered flow. This item was evaluated under PRO.-I-86-005 (reference 101) which indicated that it had been acceptably addressed.

j. ECN L6105 System I--This change (reference 75) involved the replacement of the 3/4-incl' valve in a bypass line around the main steam isolation valve. The ECN checklist aadressed only the seismic qualification of the valve and not the piping that supports the valve. The USQO stated that the new valve installation (which would include both the piping and valves) required seismic qualification. This concern was presented to the project in action item M-41.

7.5.4-7 L - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

The civil ECN checklist was revised to reflect this deficiency, PlRSQNCEB0637 (reference 102) was issued to resolve the discrepancy, and punchlist items 6116 and 6131 were written. This concern is adequately resolved.

k. ECN L6501 System 32-This change (reference 76) involved removing isolation valves, revising line sizes, and rerouting pipes in the Control Air System. The ECN evaluation was acceptable except for a concern about a calculation referenced in the ECN checklist which did not appear to address the piping change involved in the ECN. The calculation, MEB44 860827 002 (reference 103), could have enveloped the changes in the ECN, but there was nothing either in the checklist or in the calculation itself which indicated that it did. This concern was presented to the projectinactionitemM-42. The project revised the ECN checklist to clarify the fact that the calculation was done based on the most limiting pressure drop in the system, and that evaluations which were not included in the calculation had shown that the line in question was, in fact, enveloped. EA confirmed the adequacy of the calculation to support the nodification. This concern was adequately resolved.

1. ECN L6541 System 67-This change (reference 77) was initiated to replace the valve body of valve 67-551A with a new body due to activation-induced erosion in the existing valve.

The ECW evaluation was acceptable except for three attributes in the checklist.

Two of these related to concerns similar to those reported in action items M-25 and M-36 which were discussed in sections c and h above.

ThethirdconcernwaspresentedtotheprojectinactionitemM-27. It related to the need to perform additional work-in this case, modeling the change in rigorous piping analysis, with no discussion of tho PIR being issued to track conpletion of the work. Theprojectsubsequentlyissuedguidelinesdiscussingtheneedto adequately address concerns raised during ECN evaluations as discussed in action item M-25 under item c_ above which adequately resolved this concern.

m. ECN L-6665 System 62-This ECN (reference 78) changed Limitorque operators from non-EO-qualified to full EQ-qualified operators. The ECN checklist, one of the earlier ones prepared, did not provide discussion or clarification as to how the conclusions were reached that are provided in the checklist. In addition, two versions of the design review checklist were found, each signed and appearing to be issued, but disagreeing with each other in certain ways and only partially conglete. These concerns were presented to the project in action items M-21 and M-23. Asaresult,theprojectissuedguidelinesonhowchecklistsshouldbe preparedtobothWestinghouseandtheSEsontheproject(alsoseethediscussion in action item M-25 in section c above). In addition, the project added detailed evaluations of ECNs in the SYSTERs. Finally,theprojectrevisedandreissuedthe ECN checklist for L-6665 to correct the deficiencies (B28 870116197, reference 104). This concern is adequately resolved.

7.5.4-8

n. A neber of other ECN evaluations were reviewed. Inthese,theprojectevaluations were found to be adequate, the discussion needed to justify the conclusions reached were provided, and additional work needed to couplete the required technical evaluation was identified. In the latter cases, PIRs were issued in accordance with the procedures. These ECNs were L5183, L5417, L5422, L6024, L6112, L6238, and ,

L6697 (references 79 through 85). '

l An additional concern raised which was not related to a specific ECN covered the extent of review planned to verify that the changes being reviewed and the program were adequately addressed on design documents (drawings, calculations, etc.).

Discussions with project personnel indicated plans to check those doctsments that addressed the changes, but not to go further to ensure that they were addressed correctly as reflected in appropriate changes to inputs, asseptions, and resulting effects on other documents. This concern was~ addressed to the project in action item M-06. The project did subsequently issue a memorandum dated Septenter 29, 1986, as modified in a memorandum dated Novenber 6,1986, that SQEP-12 reviewers for documents such as drawings and calculations would include the review for appropriate design considerations, inputs, results, including resulting effects on other systems and conponents. This concern is adequately resolved.

An additional effort outside the scope of the DB4VP program which EA Mechanical participated in was an audit of a number of the mechanical calculations which supported the Sequoyah unit 2 base plant design. The audit focused on the inplementation of the ME8 calculation program as defined in 844 861217 017 (reference 105) as well as a review of selected calculations outside of that program. Two deficiencies and two concerns were identified in technical areas during the audit as discussed in the audit report (805 870210 001, reference 106).

At the time of this report, calculations are being revised and the scope of the MEB program was being increased to address the areas of concern identified.

7.5.4.2 Conclusions The Mechanical discipline of the EA Team reviewed 62 project evaluations of change documents to the requirements of SQEP-Il and 21 ECNs and FCNs to the requirements of SQEP-I2. A total of 19 action items were written and resolved. At this item, project C/A is required to resolve PIRSQlelEB86lIl (refe ,nce %) for auxiliary containment air congressor performance testing, punchlist items 7748 through 77% to issue DIMS to revise design criteria to show appropriate code requirements, and PlRSQNCEB8637 (reference 102) to provide required seismic qualifications. With conpletion of these items, it is concluded that the project's efforts were generally performed in accordance with the governing procedure.

7.5.4-9

7.5.4.3 References issue Reference Doctsnent Revision Date Title

,~ I SQEP-il I 5/15/86 Procedure for Identifying and Assembling 2 6/16/85 Change Documentation 2 SQEP-12 1 6/12/86 Procedure for Evaluating Engineering Change 2 7/23/86 Notice and Field Change Notice Documents 3 SQN-OSG7-048 1 5/22/06 Identification of Systems Required for 2 1/6/87 Sequoyah Restart ECN Identification Forms (SQEP-II, Attachment 1) 4 ECN 3032 -

6/2/06 825 060824 034 5 ECN 5183 -

II/18/86 828 861121 006 6 ECN 5353 - -

B28 860920 095 7 ECN 5371 -

6/2/86 B25 861116 743 8 ECW 5373 - -

828 8702ll 033 9 ECN 5386 - -

825 860914 218 10 ECN 5397 - -

B25 861102 098 ll ECN 5415 - --

825 860920 097 System 70 12 ECN 5415 -

6/4/06 B25 861116 268 System 30 13 ECN 5420 - 6/2/86 825 860824 049 14 ECN 5422 -

6/4/06 B25 861116 456 15 ECN 5681 -

6/19/86 825 860824 058 16 ECN 5714 -

6/5/86 825 860912 088 l

17 ECN 5769 - -

825 860914 051 18 ECN 5995 -- -

B25 860824 063 19 ECN 6103 -

6/5/86 B25 860913 002 I

7.5.4-10 t

lssue Reference Document Revision Date Title 20 ECN 6112 -

6/6/06 825 870205 009 21 ECN 6195 - -

825 861011 064 22 ECN 6238 - -

B25 860825 025 25 ECN 6291 -- -

B25 860915 240 24 ECN 6515 - -

825 060920 224 25 ECN 6586 - -

828 861205 055 26 ECN 6405 - -

B28 870215 048 l

27 ECN 6419 - -

825 060915 224 28 ECN 6421 -- -

B25 060915 229 29 ECN 6501 --

6/2/06 825 860824 015 50 ECN 6541 - -

825 860825 051 51 ECN 6697 -- -

825 861026 265 SCR/NCR Identification Fonns (SQEP-II, Attachment 6) 32 NCRSQNMEB800lR0 - -

828 870214 119 55 NCRSQWEB806RI - -

828 861206 086 54 NCRSQNSWP8107 -

6/25/86 828 861205 046 55 NCRSQNNEB8117 - -

828 861211 075 56 NCRSQNNEB8121 -- -

828 870116 445 57 NCRSQNNEB8158 -- -

828 861204 065 38 NCRSQlMEB8204 -- -

828 861205 094 39 NCRSQNSWP8212 - -

828 % I204 055 40 NCRGEMEB8502RI -- -

B28 861202 017 41 NCRGENMEB8402 - -

B28 861205 244 i

7.5.4-11

lssue Reference Document Revision Dite Title 42 NCRGENMEB8403 -- -

B28 861203 245 43 NCRGEIMEB8404 0 -

828 861203 246 44 NCRSQNMEB8411 - -

B28 861203 097 45 NCRSQNNEB8506 -- -

828 861202 093 46 SCRSQNNEB8513 -- -

B28 870115 091 47 SCRSQNNEB8520 - -

828 861202 095 CAT D FCR Identification Forms (SQEP-ll, Attachment 3A) 48 Cat D FCR - -

828 870109 054 4067 ,

49 Cat "D" FCR - -

828 861105 031 4236 50 Cat "D" FCR -- -

828 870109 053 4391 51 Cat "0" FCR -- -

B28 861121 100 4482 52 Cat "D" FCR -- -

828 861121 099 4503 L-DCR Identification Forms (SQEP-II, Attachment 2A)

,3 l 53 L-DCR 1884 -- -

825 861016 221 l

! 54 L-DCR 1937 - -

B25 861016 222

! SS L-DCR 2045 - -

B25 861016 223 56 L-DCR 2076 - -

825 661016 225 7.5.4-12 L. .

Issue -

Revision Date Title Reference Document

\

ONP-Cenerated Drawino Discrepar.cy identification Forms SQEP-il, Attachment 7) 57 ONP 86-00-425 - 8/16/86 B28 861203 159 .' . .

58 ONP AC-185 -- -

828 861203 165 p,

v. , ; ,

59 ONP AC-360 ----

6/10/86 828 861203 175 ,', "

in; : (

60 ONP 86-00-426 - 8/16/86 828 861203 158 ,

61 ONP 86-00-447 - 8/16/06 B28 861211 082 TACF Identification Forms (SQEP-il, Attactynent 4) 62 TACF l-81-241-67 -

7/12/86 B28 870108256 ,

65 TACF l-82-25847 - -

B28 870108 253 l

64 TACF 2-83-2001 7/12/86 -

4 65 TACF 05-064 -- -

Dosion Review Checklist Forms (SQEP-12, Attachment 2) 66 ECN 2945 -- - -

67 ECN L5064 --- --

828 860926 202 68 ECN L5095 -- -

B25 060926 027 69 ECN L5415 - -

828 870319 052 (System 50) 70 ECN L5451 - -

825 861004 229 71 ECN L5681 - -

825 861004 229 (System 32) 72 ECN L5714 - -

828 861212 078 75 ECN L5769 - -

B28 861250 265 74 ECN L5842 - -

B28 861250 264 75 ECN L6105 - -

828 861212 081 I

7.5.4-15

/ .

Issus Reference Document Revision Oate Title 76 ECN L6501 -- -

828 870122 192 17 ECN L6541 -- -

825 861004 259 78 ECN L6665 - -

C23 870219 005 79 ECN L5185 - -

828 870319 049 80 ECN L5417 - -

B28 861204 539 al ECN L5422 - -

828 870319 053 22 ECN L6024 - -

825 861025 070 85 ECN L6112 - -

823 861203 519 84 ECN L6238 -- -

828 870108 402 85 ECN L6697 -- -

825 661101 262 86 478M464015 0 -- -

47BM464-16 0 -- -

87 47VD464-15 1 - -

47VD464-16 1 - -

88 IVSW-30604GS-(2) 2 -

89 Test Report - -- -

90 08VP-D-86-008 - 10/15/86 System Engineer Signoff Authority (825 861015 013) s 91 B25 860905 001 9/2/86 TVA letter from D. W. Wilson to Westinghouse -

Guidance on Open items 92 825 860827 005 - 8/27/86 Memo from M. T. Tormey, SQEP-12 Checklist Preparation Guidance 93 825 861209 014 -- 12/9/% Memo from J. F. Cox, Evaluation of ECN L5095 by System 88 Review l 94 SQEP-Al-ll 2 2/20/86 B25 860220 006 95 SQEP-13 2 12/19/86 825 861224 002

% PIRSQNME8861 t l - 12/9/86 CAQ on Missing Postmodification Test / Calculation for ECN L5681 ,

7.5.4-14

issue Reference Doctment Revision Date Title 97 10/51/86 Meno from J. F. Cox 98 SQN-DC-V-4.2 - -

805 860721 504 99 B45 860926 254 -- 9/26/% NE8 memo, Clarification of Materials Related to Questions Raised During ECW Review 100 SQEP-14 I 9/19/86 S53 861211 % 3 101 PROL-l-86-006 1/15/86 USQD for ECN L5842 (AFW Cavitating Venturi) 102 PlRSQNCE88657 8/18/86 CAQ on Missing Congonent Analysis documentation (825 860819 019) 105 MEB44 860827 002 8/26/06 At.r.iliary Control Air System Pressure Drop Calculation 44 ECN L6665 12/8/86 Design Review Checklist (828 870116 197) 105 844 861217 017 12/17/06 ME8 Calculation Program 106 805 870210 001 2/10/87 Calculation Audit Report 7.5.4-15

7.5.5 Civil ECNs and other system changes were evalu.ited by the DB8VP project. SQEP-il (reference 1) was the project procedure for assentling change docinents which were evaluated, including ECNs, FCNs, FCRs, TACFs, SCRs/NCRs, L-DCRs, and ONP drawing discrepancies. SQFP-12 (reference 2) was the procedure used to technically evaluate ECNs and FCNs. The balance of the doctanents was evaluated during the system evaluation.

The Civil discipline of the EA Team evaluated the adequacy of the project's inplementation of assentling and classifying the change documents by reviewing document identification forms (Attachments I through 7 of SQEP-II) for conpliance to SQEP-il. The EA Civil assessed the adequate capture of all civil-related changes which were not field conplete at the time of the OL, as well as all subsequent changes af ter OL, that are within the boundary of calculation SQN-OSG7-048 (reference 3). Review of conpleted change identification forms for accuracy and conpleteness included the following attributes.

e Identification of af fected systems for the change document, e Identification of change being within the bounds defined by calculation SQN-OSG7-0A8 (reference 3).

o Categorization status of the change.

e Proper signing of identification form by appropriate personnel with adequate training, e Assignment of FCR and L-DCR to appropriate ECN.

e AdequatewrittenjustificationprovidedforSCR/NCRtoensurecorrectiveactionadequately corrects the problem described.

e Technical adequacy of TACFs written on permanent plant components.

Selection of documents by the EA Team was primarily based on inclusion of civil-related consideration, and included doctanents identified out of bounds to ensure required subsequent evaluations were not excluded by SQEP-il products.

A sunmary of the selection for the change documents is provided below:

Chango Document identification Type Form Selection Size Description ECNs Attachment i 26 Random selection verifying adequate identification of SQEP-Il form FCRs Attachments 3A 4 FCRs with civil scope and 3B of SQEP-Il FCNs Attachment 5 of 5 FCN included those with civil scope SQEP-Il 7.5.5-1

TACFs Attachment 4 of 6 TACFs with civil scope SQEP-Il SCRs/NCRs Attachment 6 of 15 SCR/NCR with civil scope SQEP-Il 1-DCRs - Attachment 2A and 8 L-LCRs with civil scope 28 of SQEP-il ONP Attachment 7 of 5 ONP with civil scope SQEP-il in addition, the EA Team performed a technical review of the project's evaluation of ECNs and FCNs inplemented in accordance with SQEP-12. The review evaluated the technical adequacy of the I change and consistency with the RDBD (reference 4) in addition to the adequacy of the project evaluation documented on the Change Docunent Evaluation Sheet (Attachment I of SQEP-12) and the design review checklist (Attachment 2 of SQEP-12). TheprojectissuedaSQEP-12 Attachment 2 guideline (reference 5) which was found to be a useful guide for utilization of the civil input for incorporation into the conpleted formal ECN design checklist.

The approach of the EA review was first to determine the technical adequacy and completeness of l the conpleted civil DB&VP checklist which is submitted to the SE for incorporation into the design review checklist. This review assessed the adequacy of engineering explanations on civil-related considerations and evaluations to dccument rational used for supporting the checklist conclusions, including appropriate references to design standards, drawings, and calculations. The adequacy of identifying CAQ nunt>ers on the checklist was also reviewed by EA. The change document evaluation sheet was reviewed for technical adequacy of current change status for those ECNs which were not fully inplemented.

EA Civil also performed an independent technical evaluation of the ECN and conpared these resultswiththosefromtheproject'scivilchecklist. Applicable calculations were reviewed to evaluate their technical adequacy for supporting the ECN change, verifying acceptability of the methodology, assure proper inputs was used, and check if calculation results were incorporated in the design. Accuracy of resulting design drawings was reviewed to address the adequacy of inplementing the design change.

The EA Team also reviewed a group of system design review checklists which included civil

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considerations to assess the adcquacy of the SE incorporating the results of the civil checklist.

The basis of the ECN review was to select an ECN document containing civil scope which was then reviewed for a specific system. The ECN selection encompassed a broad base assessment of specific civil activities required to assure technical adequacy of the related DB&VP scope. The areas covered to obtain this cross-section included:

e Rigorous Piping Analysis e Pipe Support Design e Alternate Analysis 7.5.5-2

e Congonent Seismic Qualification e General Structural Considerations e Pipe Rupture Considerations e Review for Vibrational Effects on Systems ECNs were also selected based on significance of the change and importance of the affected sVstem. Some ECNs affecting a conson system reviewed by other EA disciplines were included in the selection to ensure adequate interface review. The selection resulted with 20 ECNs (references 6 through 25) which contained the civil considerations described above.

As part of the EA review effort to address technical adequacy, three ECNs were also selected to evaluate the adequacy of the project's review conducted in accordance with SQEP-51 (reference 26). ECNs with a potential for adversely affecting operational piping vibration were screened andthenreviewedbytheprojecttoassesstheneedforadd.itionalvibrationaltesting. The EA evaluation assessed the adequacy of the engineering explanation and evaluations provided to document the rational for supporting the checklist conclusions.

The selection of FCNs was sinply based on those including civil or seismic considerations, however, very few FCNs were found with any civil involvement within DB&VP scope. Only four FCNs were selected for the technical review of the project's evaluation due to the minor civil-related scope. The approach of the FCN review was a detail evaluation of the design review checklist and change document evaluation sheet prepared by the project to determine the technical adequacy of the civil-related changes.

7.5.5.1 Details Assenblina Chance Documents There were 26 ECN identification forms (references 27 through 52) reviewed by EA Civil. These forms were properly prepared and signed by the Civil SDE. They correctly identified the affected systems within the scope of SQN-OSG7-048 (reference 3). One prc,cedural deviation was noted in which the SDE designated an ECN (reference SI) out of bounds in lieu of identifying the affected system number, as required by SQEP-il. His determination was correct; however, it was the responsibility of the SE to make the determination. The concern was reported to the project on action f emt C-02 and adequately resolved by ensuring that the SE still verified the decision by signiag all ECN identification forms. EA verified the adequacy of the SE's determination and signature of ECN identification forms within the scope of the DB&VP.

A general concern resulted from the review of ine ECN identification forms. The Team determined that an insufficient capture of ECNs concerning the steel containment vessel (SCV) resulted from the project effort. Although ECNs affecting the SCV configuration was unlikely, ECNs were generated which affected attachment load changes on the SCV shell which could impact the significant SCV function for mitigating a Chapter 15 event. This concern was presented to the project in action item C-29. The project identified applicable ECNs, SCRs, and calculations which were technically evaluated by SQEP-12 under DB&VP. EA reviewed the pad i attachment calculations referenced in the identified ECN evaluations and concluded that these changes would not degrade the safety function of the SCV.

7.5.5-3

Additional reviews of adequate ECN capture were performed by the EA Team during the selection of the 20 ECNs (references 6 through 25) for technical evaluation. The review of ECN applicability identified two ECNs which were incorrectly excluded from DB&VP. The first ECN (reference 24) was excluded from DB&yP since it indicated unit i only on the cover sheet; however, the affected piping analysis drawings added a seismic restraint to the containment spray test line for both SQN units I and 2.

The EA Civil physically verified the addition of this support to unit 2 via field walkdown.

This concern was presented to the project in action item C-21. Theprojectcorrectlyadded this ECN to the DB&VP scope and generated PIRSQWEBB659 (reference $3) to address the generic concern. TheprojecthasnotestablishedadequateC/AforthisPIR. Subsequent EA verification is required upon adequate project disposition to ensure all applicable DB&VP ECNs have been captured. See observation Cl.

The second ECN (reference 17) af fected cable tray and conduit supports which were conmon to both units; however, the project initially identified the ECN incorrectly as out of bounds for unit 2. This concern was reported to the project in action item C-23. Theprojectdirected the Civil DB&VP to review all ECNs declared inbounds for either unit on conmon systems to ensure changes were adequately addressed for unit 2. EA verified that the Civil DB&VP technical evaluations adequately reviewed unit i ECNs on conmon systems for its effect on unit 2 ECNs.

The EA Civil reviewed four FCR identification forms. Two inprocess FCRs (references 54 and

55) were reviewed to verify proper association with an ECN with Attachment 30 of SQEP-Il for subsequentprojectevaluationinSQEP-12. Two Category D type FCRs (references 56 and 57) werereviewedtoverifyproperprocessingwithAttachment3AofSQEP-ilforsubsequentproject evaluation in SQEP-16 (reference 58).

The inprocess FCR forms were verified to be propurly conpleted and signed. The associated ECN for FCR 4312 was properly identified and determination of system boundary was adequately documented. The identification form for FCR 4093 (reference 55) identified only System 70 as affected; however, the FCR changed general drawing notes effecting pipe supports of all systems. The review of the associated ECN form (reference 59) listed System 70 as the only affected system. This concern was presented to the project in action item C-45.

The project adequately corrected the specific identification forms and established appropriate C/A by organizing a group of senior-level discipline engineers ("A-Team") to review ECNs originally determined out of bounds for capturing any additional ECNs. Theprojectactionwas determined adequate by EA to resolve this concern.

Only two Category D FCR identification forms (references % and 57) were selected because of the limited civil involvement. The review of the records found that the capture of Category D FCRs was adequately completed and thorough. The Attachment 3A forms of SQEP-il were properly prepared and conpleted by the SE. These two FCRs were properly determined out of bounds.

The EA Civil reviewed five FCN identification forms (references 60 through 64), but found very few FCNs with any civil considerations. The conpleted forms were verified to be properly congleted and signed by appropriate personnel. Project decisions for inbounds determination were acceptable.

7.5.5-4 l l

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_ _ _ _ _ _ _ _ . _ _ _ . .J

The EA Civil evaluated six TACFs (references 65 through 70), even though very few were found with any civil considerations. TACF 2-84-115-3 and 0-86-007-317 (references 65 and 66) included minor physical changes which did not impact the civil qualification of the item.

TACF 0-85-040-62 (reference 67) only addressed replacement of original bolts but was properly determined outside the SWBID boundary. The other TACFs (references 68, 69, and 70) involved specific structural changes to unit I components. The associated TACF identification forms were reviewed and found to be properly prepared and evaluated for inbounds /out-of-bounds determination. The project activity for addressing TACF forms in accordance with SQEP-Il was found acceptable.

The EA Civil evaluated 15 SCRs/NCRs (references 71 through 85). The earlier conpleted SCR/NCR identification forms were found to contain docunentation errors. The incorrect system designation was assigned to SQNCE88115 (reference 71) and the implemented classification was incorrectly identified for SQNCEB8404 (reference 72). Inadequatetechnicaljustificationwas also found on the identification form for SQNCE88115 (reference 71). These concerns were addressed to the project in action items C-08, C-09, and E-09, respectively. The project took appropriate action to address the generic concern by recalling all implemented SCR/NCR identification forms for re-review and made appropriate corrections as required. The EA Civil reviewed several revised data on the identification forms and were determined to be adequate exceptforsixexamplesinwhichtechnicaljustificationswerestillunacceptable(SQNCE88115, SQhCE88303, SQNNE88107, SQNCE88302, GENCEB8402, and SQNCE88512). This deficiency was re-presentedtotheprojectinarevisiontoactionitemE-09. Theprojectperformedanother technical review of the docunented justification of all civil-related implemented SCR/NCRs, which resulted in 30 corrected identification forms. Upon project completion, EA reviewed six additioral forms (references 86 through 91) and found the technical justifications adequate.

In conclusion, the project's responses and C/A enabled EA to close action items C-00, C-09, and E-09 concerning inadequate technical justifications of SCR/NCRs on SQEP-il identification forms, including the specific exanples listed above.

An inadequate technical justification was also found on an open NCR, SQNCE88404 (reference 72). This deficiency was presented to the project in action item C-38. Partway through the program,DNEeliminatedtheevaluationofopenSCR/NCRsfromthebaselineprogrambyproject directive (reference 92). The justification was that the engineering line organization would evaluate them in accordance with NEP-9.l. Action item C-38 was no longer applicable based on this program change. The EA Team considered the removal of open SCR/NCR from DB&VP potentially inappropriate due to the fact that pertinent information contained within the DB&VP was not readily available to the line organization to perform an adequate evaluation.

This concern was presented to the project in action item E-77. The details of resolving this action item are in section 7.7.2 (Electrical). The Civil 084VP took appropriate C/A by adding these open SCR/NCRs to the D88VP punchlist which ensures DB&VP consideration by inplementation ofprojectdirectiveD8VP-D-87-002(reference 93).

EA Civil evaluated eight L-CCRs (references 94 through 101); however, few L-DCRs were available with civil considerations within the scope of DB&VP. L-DCRs were generally found to be either out of bounds or cancelled, consistent with project procedure Al-19 (reference 102) which only allows L-DCR to be written on nonsafety-related changes. The forms were found to have been properly prepared and dispositinned as out of bounds.

The EA Civil evaluated five ONP drawing discrepancy forms (references 103 through 107) with civil-related scope. The identification forms were adequately conpleted and signed of f. A review performed on the project's records found the implementation adequately conplete and thorough.

7.5.5-5

Technical Evaluation of ECNs and FCNs The EA Civil technically evaluated 20 ECNs (references 6 thrtsugh 25) and 4 FCNs (references 108 through 111) for compliance with SQEP-12. Details of the review are provided below.

An early review of preliminary SQEP-12 design checklists prepared by Westinghouse was conductedinordertoassesstheinitialprojectproductsoftheevaluation. Three preliminary checklists were reviewed for ECNs t-6540, L-5691, and L-5832 (references 112 through 114). Theprojectreviewwasappropriateforgeneralsystemengineering considerations, but not conplete for civil considerations. Another concern was the use of informalprojectinstructionswhichwouldnotresultinasufficientdesignreviewto establish technical adequacy. Theseconcernswerepresentedtotheprojectinactionitem C-05. The project subsequently established a Civil DB&VP group onsite which developed an in-depth civil checklist which captured the applicable civil considerations for adequate system qualification. This revised format was to be presented to the SE for conpleting the formal SQEP-12 Attachment 2 design checklist for each civil-related ECN. This effort was a significant civil enhancement for the technical evaluation of change documents as a result of this EA identified concern. The Civil DB&VP was verifying the existence of change qualification doctsnentation for the ECNs; however, upon initial review of conpided civil checklist, it was identified that an in-depth calculation and drawing review to establish technical adequacy was not being performed. Thisconcernwasagainpresentedtotheproject by revision to C-05. The project advised that technical adequacy was being established by an independent CEB calculation program (reference 115).

The FA Civil reviewed the civil calculation program to verify that the scope encompassed the problems and concerns raised by the DB&VP project during the course of performing their evaluations. The DB&VP was to take credit for the results of the civil calculation efforts to technicallyjustifythecivilECNc'alculationanalysis. A separate EA audit was conducted on the DNE calculation program with participation from EA Civil. The results of this audit is presented in reference II6. EA Civil identified several concerns during this audit that still require C/A identification and inplamentation for the DNE Civil Engineering Branch. EA Civil requires verification of adequate inplementation of the C/A for the calculation progrun to determine technical adequacy of the DB&VP ECN evaluation process. See observation C5.

The EA Civil reviewed 20 ECNs (references 6 through 25) for programnatic compliance and technical adequacy, in addition, three ECNs were reviewed to determine the adequacy of the project'sevaluationofoperationalvibrationeffects(references 16,18,andl17). The details of the EA Civil reviews are provided below.

l. ECN 2166 (Reference 6) - Ventilation Systen>--This ECN designad approximately 70 seismic HVAC duct supports to address NCR SWP-78-S-5 (reference 118).

The Civil DB&VP checklist (reference 119) provided an adequate evaluation with appropriate explanations of the ECN. The affected calculations and HVAC drawings were properly referenced. The checklist attachments made reference to a Watts Bar Design Criteria, WB-DC-40-5l.9, (reference 120) which was verified to be incorporated in the SQN criteria SQN-DC-V-24.I (reference 121).

The 47W920 mechanicel drawing series (reference 122) was reviewed and the new hangers were found to be properly added and relocated. The mechanical drawings properly referred to the 47A055 drawing series (reference 125 tlrough 126) for identification of the hanger mark numbers.

7.5.5-6 l

The support calculations (reference 127) and variance calculations (reference 128) adequately qualified the affected supports shown on the applicable drawings (references 125 through 126). These calculations were found to be technically adequate, in compliance with applicable design criteria in RD80, and consistent with the HVAC support drawings.

A minor documentation error was noted, but was not significant enough to affect the' technical adequacy.

2. ECN 2944 (Reference 7) NSS Ol-The ECN reanalyred and revised main steam and feedwater i piping drawings due to NCRSQNCE88041 (reference 129) which identified an additional axial load on the piping due to a pressure buildup resulting from a LOCA.

The civil D88VP checklist (reference 130) correctly identified the documents associated with the piping analysis, and noted the applicable analysis as not being docismented in the calculations for-the supports. These items were included under PIRSQNCE88638 (reference 131); however, the pipe support calculations were not identified in the checklist. Also, identified was the lack of alternate analysis which was identified under PIRSQNCE88665 (reference 132).

The piping analysis calculations (references 13! and 134) analyzed the condition described by the NCR. The affected isometric drawing (reference 135) noted that the piping had been analyzed for the described LOCA condition.

Review of the Basic Engineers support drawings (references 136 and 137) shows that revisions have been properly made per this ECN. The pipe support calculation identified on the form to support this ECN could not be located.

EA Civil determined that the checklist should have stated that no calculation could be located instead of not being referenced. Thisconcernwaspresentedtotheprojectin action item C-37. The project corrected the checklist by changing the applicable reference from PlRSQNCE88638 to PIRSQNCE88639 (reference 138). EAverifiedtheproject correctly revised their checklist and concluded and that the problem would have been addressedduringprojectevaluationhaditremainedunderPIRSQNCE88638. The punchlist items was not dispositioned at the time of this report and requires EA verification of C/A. See observation C6.

3. ECN L5227 (Reference 8) - DG Startina Air System 82-This ECN implemented revisions to pipe supports for all systems resulting from NCR SWP-80-S-3 (reference 139) which required replacing missing calculations and revising existing calculations to ensure that complete calculations were provided for all hanger and support drawings. This ECN selection was reviewed for only Systou 82.

The Civil D88VP checklist (reference 140) was found properly evaluated and conveted.

The EA review found that the changes of the ECN was technically adequate and in accordance with the applicable design criteria. The calculations (references 141 through 144) for applicable support drawings (references 145 through 148) were found to be technically adequate. The changes only required documentation changes with no field modifications required. The drawings agreed with the results of the calculations, but it was noted that no references were made in the calculations to the design criteria governing maximum deflection limits and that the seismic design loads referenced a Watts Bar design criteria (reference 120), which has been incorporated in the SQN criteria (reference 121). These 7.5.5-7

concerns of the referenced deflection limit were resolved when EA verified the calculations were within the limits established by applicable SQN criteria. The Civil DB&VP evaluation of this ECN was determined to be acceptable.

4. ECN L5779 (Reference 9) - UHI System 87-This was a partially inplenented ECN which added a bypass line around an isolation valve to prevent a pressure differential which could fall a rupture disk. ECN data sheet 3 (reference 149) shows that no civil-related documents are af fected, but does state that a rigorous analysis will be performed to facilitate installation. Workplan l1613 includes supports for the bypass line which ties into the 12-inch pipe, recognizing that FCR approval on support variances is required to finish the work.

The civil DB&VP checklist (reference 150) properly identifies that rigorous analysis was not required and correctly included this ECN under PIRSQNCEB8665 (reference 132) as no alternate analysis supportjng documentation was available.

A review of reference 151 and the civil DB&VP checklist indicated that the actual field status of the change detailed in the workplan was not adequately evaluated. The civil DB&VP review assumed the ECN was implemented without considering data from the workplan to technically assess the current physical configuration. Further review of the checklist prepared by the SE was performed to evaluate the adequacy of incorporating the civil checklist. Inconsistencies were found concerning the involvement of rigorous analysis, the existence of FCR 3636 relocating the tie-in of the bypass line, and that no recognition of the support variance was incorporated. These concerns were noted to the project in action items C-41 and C-43, respectively. Theprojectrevisedbothtocorrect the specific checklist inconsistencies identified and properly determined on the change docunent evaluation sheet that this ECN would be fully implemented before restart.

The civil DB&VP also punchlisted all partially implemented and unimplemented ECNs within the SWBID to ensure the project Civil organization determines the acceptability of the current field status of the changes evaluated under SQEP-12. These actions were found adequate to capture the general concern of C-41; however, they also indicate the inadequate DB&VP evaluation of all partially implenented civil-related ECNs. Subsequent EAverificationwillberequiredtoaddresstheadequacyofthependingprojectC/A. See observation C4.

5. ECN L6004 (Reference 10) - SIS 63-This ECN modified two ent>cdded plates for unit 2 due to overloaded pipe supports. The design change was found technically adequate by EA and consistent with the design basis documents. The required civil drawings (references 152 and 153) were revised to agree with the calculations (reference 154).

The civil DB&VP checklist (reference 155) evaluation was acceptable with the two following exceptions:

a. Nine various systems were noted as being affected by this ECN when in fact, only one system, System 63, was affected.

b. An incorrect RIMS accession number (B25 851021 306) was referenced instead of the correct accession nunt>er (B25 851028 309) for the calculations which involved the plate analysis.

7.5.5-8

I

-These concerns were presented to the project in action item C-25. To correct these concerns, Civil D88VP prepared separate attachments for each system to avoid confusion. Since the RIMS accession numbers were not required on their evaluations before July 14,'1986, the project re-reviewed all attachments for correct RIMS

, accession number references generated before this date.- EA verified the adequacy of

- the C/A by reviewing the specific corrected checklist and reviewing multiple system

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checklists for readamly selected ECN L5881 (reference 1%) and ECN L6207 (reference 157) to determine acceptability.

(6. ECN L6300 (lieference 11) - High Pressure Fire Protection System 26-The civil portion of

this ECN included the addition of draf t stops at stair penetrations at elevations 690.0' V and 714.0','and concrete curb for drainage control as a result of the added sprinkler systems shown initially on civil drawings (references 158 and 159) and architectural drawings (references 160 and 161).

The civil 088VP checklist (reference 162) was determined to be caplete and included adequate explanations and evaluations.

For the EA review, the draft stop design (reference 163) was found seismically qualified in accordance with the applicable design criteria. The concrete curb was a nonstructural-item for drainage control; therefore, no calculations were required. The architectural drawings, however, did not agree with the civil drawing curb locations and did not reference the civil drawings.

ThesedrawingdiscrepancieswerenotedtotheprojectinactionitemC-19. The project responded that the architectural drawings were' issued prometerely and that new curb locations would be required. Also,theprojectstatedthattheproblemresultedfromno formal docunentation requirements being provided in the ECN package. EA verified that the carb locations were properly revised on the civil drawings which was the controlling drawing.

7. ECN L6439 (Reference 12) - RCS 60--This partially iglemented ECN relocated transmitters to the outside of the crane wall and ran sense lines through the wall to the' transmitters. The civil involvement required alternate analysis, support design, seismic qualification of a panel, and cutting of reber.

The civil D64VP checklist (reference 164) contained acceptable evaluations, and adequately identified missing calculations on appropriate PIRs for alternate analysis, pipe rupture concerns, and open FCRs. This partially implemented ECN was also punchlisted to assure the civil line organization evaluates the actual field status.

EA reviewed the seismic qualification of the electrical panels (reference 165) and found it acceptable. A preliminary copy of the alternate analysis problem (reference 166) was found to be technically adequate and in accordance with RD0D. Support variances calculations (references 167 through 171) and a calculation concerning reber cutting (reference 172) were also determined to be technically accurate.

l

.During this review, it was noted that another required calculation addressing reber cuts (reference 173) was not included in the civil 084VP checklist. This concern was reported to the project in action item C-59. The project advised the EA Team that this analysis was generated for anticipated additional cuts which were not made. EA verified this -

condition which resolved the concern.

7.5.5-9

8. ECN L5451 (Reference 13) - DG Startino Air (System 82)-The ECN modified the oil piping on the emergency DG engine and added a second AC lube oil ptsnp.

1 1

The civil DR&VP checklist (reference 174) contained adequate explanations for its l attributes, and properly identified the applicable PIRs for missing calculations and the ,

open FCRs except for one case. TheprojectlistedCEB 831202 250 (reference 175) as documenting the conponent qualification of the additional pung, however, this memo only addressed MEB 831215 950 (reference 176) which only qualified the piping portion and miscellaneous conponents of the change. The additional punp was actually qualified by MEB 820402 901 (reference 177). Thisconcernwasdocumentedtotheprojectinactionitem C-30. The project corrected their checklist and noted that PIRSQNCEB8637 (reference 178) addressed the lack of CE8 approval Lof this report. This action was verified to be adequate by EA.

1 In addition to the above review, EA performed a technical evaluation and found that the I modification analysis (reference 176) and support variance calculations (references 179 and 180) were adequate and in compliance to applicable criteria in the RD80. Support

, drawings (references 181 and 182) adequately incorporated calculation results. The pump qualification (reference 177) was found to be adoquate; however, it appeared to be based on acceleration spectra from another plant which did not envelope the SQN spectra. This concern was noted to the project in action item C-31. The project was able to adequately demonstrate that the acceleration profiles used to qualify the pump were attached in a later section of the report which did envelop the SQN acceleration spectrum curves.

9 ECN L6710 (Reference 14) - SIS 63-This ECN addressed the required reanalysis of piping to qualify overlap areas and ensure seismic integrity for chemical and volume control, safety injection, and standby DG systems. Revision to support load tables and support analysis, and resulting physical modifications were reviewed for System 63. This ECN resulted from C/A for NCRSQNCEB8303 (reference 183) which identified that lapping techniques as described in SQN-RAH-206 (reference 184) were not used.

The Civil DB&VP checklist (reference 185) provided adequate explanations and evaluations for this ECN. PlRSQNCE88657 (reference 186) was correctly identified as being affected by open FCRs. The piping analysis portion of the checklist correctly identified applicable overlapping considerations, and also correct!y identified the affected pipe support drawings.

EA evaluated the support calculations (references 187 through 192), pipe support drawings (references 193 through 200), and piping analysis (reference 201) for System 63.

The stress calculation adequately addressed the overlapping considerations of problems N2-63-IA, -2A (reference 202) and N2-65-72.74-IA, -2A (reference 203). The methodology of the support calculations was acceptable and the drawings properly incorporated the results of the support analysis. The EA review, however, determined that these supports did not adequately incorporate the enveloping loads from these two stress problems. Support load I tables (references 204 and 205) showed larger loads than those used in the support calculations and revealed general discreparcies between the load magnitude and conditions. Further review by the EA Team indicates that one support (reference 190) could overstress the wall attachment plate with the correct higher load. These concerns wereprovidedtotheprojectinactionitemC-53. Theprojectreviewedthesupportsand wall attachnent plate and found the items would rennin structurally adequate and generated i

7.5.5-10

PIRSQNCEB8709 R1 (reference 206) to address the generic implications of this item in conjunction with the results of the calculation program (reference 115). EA verification of technical adequacy is required for project C/A. See observation C6.

10. ECN 2548 (Reference 15) - CSS 72--This ECN involved the reanalysis of the piping attached to the SCV to include inertial loadings and dynamic movements due to DBA analysis. The ECN also resulted in the modification of several snubber supports. The civil DB&VP checklist (reference 207),was found to provide adequate evaluations and documentation.

The project properly referenced PIRSQNCEB8639 (reference 138) for missing pipe support calculations. The EA Team reviewed TVA support calculations (reference 208) requalifying CBI supports and found them acceptable. Pipe stress calculations (references 209 through 212) were also found technically adequate and consistent with the EDS Nuclear incorporated (now Inpell) piping isometrics (references 213 through 216). This ECN evaluation was determined acceptable.

11. ECN 2971 (Reference 16) - CS!h-This ECN addressed the reconciliation of the piping analysis and pipe support designs to field as-built condition as a result of inplementing SQN program for conpliance with IE Bulletin 79-14. The civil DB&VP checklist (reference 217) was found conplete for System 72 4 1 the adequately docunented the rational supporting checklist conclusions. Drawings and calculations were properly referenced, and missing pipe support calculations were correctly documented by PIRSQNCEB8639 (reference i38). Documentation discrepancies were properly referenced to PIRSQNCEB0638 (reference 131). The EA Team evaluated the available analysis for selected piping isonotrics (references 218 through 223). The associated pipe stress analysis (references 224 through 229) were reviewed and inund technically adequate and comply with applicable criteria in the RDBD.

The EA Team also reviewed the design review checklist, Attachment 2 of SQEP-12 (reference 250) prepared by the SE to evaluate the adequacy of his incorporation of civil checklist conclusions. The civil checklist was referenced as an attachment; however, the following discrepancies were found:

o The design review checklist did not recognize the existence of the PIRs from the civil i.hecklist .

o The SE revised the civil checklist without CEB concurrence, disregarding deficiencies initially identified for pipe support by stating supports are seismically qualified by definition.

These concerns were presented to the project in action item C-36. The project corrected thespecificdesignreviewchecklist,andgeneratedprojectdirectiveDBVP-0-06-010 (reference 231) specifying that Civil DB&VP WoJld perform a discipline review of all draft SYSTERs to ensure their input was properly incorporated into design review checklist by the SE. EA verified the adequacy of the revised design review checklist for this ECN in the SYSTER for System 72. The adequacy of this C/A to address the general concern is detailed later in item 22 for " Design Review Checklists." l

12. ECN L5298 (Reference 17) - ERCW System 67--ECN L5298 rcrouted conmon ERCW train B pump power cables to meet separation requirements. EA technically evaluated the civit scope which involved the layout and design of cable tray and conduit supports. The trays and ,

supports were added according to drawings 48N!)23Pl4 and 48N1326R6 (references 232 and 7.5.5-11

233), respectively, and this part of the change was adequately doctanented. The calculation (reference 234) was found technically adequate and complied with the requirements of SQN-DC-V-l.).4 (reference 255). Typical conduit supports were selected and installed by the field using typical support details drawings 47A056 (reference 236) and Modifications and Additions Instruction (M&Al)-II (reference 237). Variances to the standard conduit supports were requested by the field when required to deviate from standard application.

The EA Team reviewed the qualification adequacy of the standard designs (reference 236) used for this change which were referenced on conduit drawing 45N832-1 (reference 238) with the method of field application implemented by M&Al-ll (reference 237). The specified allowable conduit spans, welding details, and installation instructions were technically adequate and in conpliance with design criteria SQN-DC-V-13.10 (reference 239). Deviations to the standards were properly doctsnented by variance request doctsnented by a FCR for engineering approval.

Initially the civil DB&VP checklist was not available for EA review due to the concern doctsnents in action item C-23 detailed earlier in the assembling change document section.

During an NRC inspection, the subsequent civil checklist was reviewed and found that two support variances on FCRs 455 and 565 (references 240 and 24I) were evaluated as acceptablewithoutprovidingsufficientjustification. This concern was noted to the project in action item C-47. The project reviewed this evaluation and found that variance calculations were actually unavailable, and revised their checklist to properly reference PIRSQNCE80639 (reference 138). The project also reviewed additional checklists to capture and correct similar discrepancies fcund. EA verified the adequacy of the revised checklist for this ECN and concurred with the adequacy of the C/A conmitted to reso!ve the l

extent of the concern. This item requires subsequent EA verification of adequate inplementation of the C/A. See observation C6.

13. ECN 15724 (Reference 18) RHR System 74--This ECN replaced a failed snubber with a rigid support and a lateral rigid support at the same location on the pipe. The snubber had failed as a result of an unknown operational transient. The civil DB&VP checklist (reference 242) was reviewed and found to have adequate engineering evaluations and explanations which document the rational used for supporting checklist conclusions.

The EA Team reviewed drawing 47K432-56 (reference 243) and the corresponding pipa analysis (reference 244). The piping with the revised sepport scheme was properly modeled and reanalyzed; however, the operational transient input was not evident in the analysis, the '

support load failing the snubber was properly estimated and the revised support (reference 245) was adequately designed. This estimted load, however, was not properly recorded in the calculation log as an unverified assumption requiring subsequent verification. These concernswerereportedtotheprojectinactionitemC-13. Theprojectrevisedthe calculation (reference 244) to correct the deficiencies cited, and established PMf-32 (reference 246) for establishing the root cause of the transient and verifying adequacy of the design change. EA verified the adequacy of the revised calculation and the test procedure to address the concern.

During an NRC inspection, the unit I isometric for the same piping was incorrectly designated as high energy piping. This concern was presented to the project in action i tem C-52. Theprojectreviewedthesystemparameterstoensurethislinewaslowenergy piping and revised the isometric correctly. EA concurred with the low energy designation and the isometric revision to resolve the concern.

7.5.5-12 a

14. ECN L5750 (Reference 19) Containment Isolation System 88 This ECN added two containment multiple penetrations consisting of a large pipe sleeve with inner and outer head plates t supporting the smaller process test pipes.

EA reviewed the design details and verified that containment isolation requirements were achieved by inboard and outboard isolation valves. The qualification for the process pipe (reference 247) and penetration assently (reference 248) were considered technically adequate. The component qualification for the isolation valves (reference 249) did not =

adequately address the DBA load; however, due to the small valve size, the containment isolation function would be maintained. Theprojecthadpreviouslyidentifiedthis concern on PIRSQNCEa8655 (reference 250).

The Civil D8&VP checklist (reference 251) was reviewed and found to adequately document the rational supporting checklist conclusions. The concern of inadequate seismic qualification documentation for the isolation valves was properly captured by referencing PIRSQNCEB8657 (reference 178).

During an NRC inspection, a concern was found that an unconservative assumption was used for the qualification of the process pipes. This concern was documented in action item C-48. The project revised the calculation which demonstrated the adequacy of the piping configuration. EA concurred that the C/A adequately addressed the NRC concern.

15. ECN 15775 (Reference 20) - RCS 68--This ECN changed air- operated relief valves to solenoid motor operated power relief valves. This change was reviewed by EA for pipe whip considerations to ensure the added cables were not vulnerable to impingement by postulated pipe breaks. The USQD was incorrectly checked for pipe whip considerations as N/A. The civil 084VP checklist (reference 252) properly doctsnented this deficiency on PIRSQNCEB8666 (reference 255). The EA Team concurred with Civil DB&'.P evaluation based on the Team's independent evaluation of the ECN.

16. ECN 15824 (Reference 21) ERCW System 70--This ECN replaced motorized valve operators with environmentally qualified notorized valve operators. The EA Team reviewed the operator data and determined the weight differential was insignificant to affect the stress qualification. The piping analysis (reference 254) was reviewed and found technically adequate and complying with applicable criteria in the RDBD. The piping isometric (references 255 and 256) were reviewed and found adequate and were revised to incorporate the weight difference. The seismic qualification of the motor operators could not be retrieved from RIMS for performing a technical evaluation.

The Civil DB&VP checklist (reference 257) was reviewed and found to be acceptable. The checklist properly referenced the piping calculation and isometrics and recognized the missing conponent qualification. This deficiency was properly doctsrented on PIRSQNCEB0657 (reference 258). The evaluation was found acceptable.

17. ECN l6202 (Reference 22) - CCS 70--This ECN changed pressure sensor switches designed to detect a loss of pressure in the CCS due to a pipe break with switches designed to detect a low level in the CCS surge tanks. Ibe original pressure sensor switches were not sensitive enough to detect pressure changes which would occur with a pipe break in one of the CSS lines. EA reviewed this change to determine the adequacy of pipe rupture mitigation considerations.

7.5.5-15

The civil DB&VP checklist (reference 259) was reviewed and adequately concluded that pipe rupture evaluation for this ECN was addressed, referencing the applicable calculation (reference 260).

This pipe rupture calculation was reviewed and determined to be technically adequate. The analysis consisted of an evaluation of the effect on System 70 of a postulated break in the line to the waste evaporator building, and the ability of the new sensors to detect the low level, af fect the isolation of the line, and thereby protect this system from a loss of coolant. This evaluation was determined to be acceptable.

18. ECN L6263 (Reference 23) - Feedwater System 5-This ECN redesigned two feedwater pipe supports which experienced concrete cracking near the edge of the crane wall. The supports carry tne 16-inch diameter feedwater line to the SGs.

The civil DB&VP checklist (reference 261) was reviewed and found to adoquately reference applicable drawings and calculation documenting the change; however, insufficient explanations were provided to enable a SE to interpret the civil checklist for incorporation into his design review checklist. This concern was reported to the project in action item C-42. The project adequately resolved this concern by designated civil DB&VP individuals to serve as contact points for specific systems to aid the SEs in providing clarification of checklist entries. Additionally, written ECN evaluations which

were strictly civil in nature were prepared by civil DB&VP for input to the SE. EA i verified the adequate implementation of these C/As.

EA reviewed the support drawings (references 261 and 262) and the related calculation (reference 263). The revised design and analysis were determined technically adequate except for two concerns.

e The length of support brace was significantly less conservative in the calculation as conpared to the drawing, e inconsistency existed between design input loads used for the two supports.

l 1 These concerns were reported to the project in action item C-44.

l The project resolved the documentation inconsistency and revised the drawing to correct the discrepancy. TheprojectalsoincludedthisconcernonPIRSQNCEB8659(reference 264). EA verified the adequacy of these C/As for this ECN; however, the generic question of drawing accuracy has not been addressed by formal C/A for i sis PIR. This item remains open requiring subsequent EA verification of C/A. See observation C5.

19. ECN $268 (Reference 24) - CSS 72-This ECN implemented C/A change to resolve NCRSQNCE88007. The containment spray test line was reanalyzed because the original analysis incorrectly used properties for 3-inch pipe instead of that for the actual 2-inch pipe. As a result of the analysis, extra lateral supports were added for both units. The EA Team performed a technical review on the piping analysis (reference 265), the associated Isometric drawing (rolerence 266) and the mechanical piping drawing (reference 267). The analysis was done assuming that the piping layouts were the same, but opposite hand, for units I and 2. The unit 2 layout, however, was shown with an additional dogleg in the piping configuration. This concern was noted to the project in action item C-22.

The project dtwnonstrated that the additional dogleg was found as the result of the 7.5.5-14

)

subsequent 79-14 walkdown and was detailed and analyzed separately at a later date EA reviewed the subsequent calculatios.s and found them technically (reference 268).

adequate.

A civil DB&VP checklist was not initially available for review due to the concern cited in action item C-21 discussed earlier in the section for assentling ECNs. The subsequent generated civil checklist was reviewed and found adequate.

20. ECN L61% (Reference 25) - RCS 68-The loop seal piping was insulated to reduce water slug forces to practical limits. The civil involvement included piping analysis and pipe supporis.

The civil DB&VP checklist (reference 269) properly determined that adequate documentation did not exist for a support variance and included this under PlRSQNCE88639 (reference 138). The project also identified severel FCRs that had not been closed under The review of the ECN data sheets found applicable pipe PlRSQNCEB8657 (reference 186).

support drawings af fected by the change; however, they were not addressed in the civil checklist. This concern was reported to the project in action item C-32. Theproject corrected the specific checklist and reviewed additional checklists to assure this concern was an isolated case. EA verified the adequacy of the revised checklist and the sample reviewperformedbytheproject.

The EA Team technically reviewed the piping analysis (reference 270) and found it to be technically adequate for-qualifying this ECN. Three pipe support drawings (references 271 through 273) and the associated calculations (references 274 through 276) were reviewed for adequately incorporating the results of the stress analysis. The support designs were found technically adequate except that FCR 5963 (reference 277) was not addressed in the applicable calculations (reference 275 and 276). This concern was documented to the project in action item C-33. The project c'rrected their checklist and documented the discrepancy on the SQEP-45 punchlist. EA verified the adequacy of the project C/A.

21. Additional ECN Technical Reviews Additional reviews of ECNs were performed by the NRC which identified specific concerns, similar to those found by EA.

a. ECN L6556 (reference 278) was reviewed and found that the seismic qualification of a limit switch bracket shown on TVA drawings (references 279 and 280) was not performed, and applicable bolting sizes and naterial specifications were not detailed (reference 280). These concerns were reported to the project in action item C-49. Theproject generated a calculation (reference 281) which demonstrated the qualification of the bracket, and the bolting material and sizes were documented on FCR 4289 (reference 282). EA concurred that the C/A was adequate to ensure the seismic qualification of this ECN.

b. ECN L6499 (reference 283) was reviewed concerning alternate analyzed piping. The piping layout on the analysis isometric for problem N2-70-A-30l A (reference 284) did not agree with the physical drawings (reference 285) for unit 2. These concerns were reportedtotheprojectinactionitemC-50. The project corrected the isometric drawing and performed a thernal evaluation confirming the acceptability of the initial qualification. EA concurred with the adequacy of the drawing and thernal evaluation to resolve this concern.

7.5.5-15

?

c. ECN [6487'(reference 286) was reviewed and found the following discrepancies:

o Piping isometric (reference 287) showed the pipe opposite hand from installed -

configuration.

~

e _ Valve 2-FCV-77-20 was not supported in accordance with alternate analysis criteria, o Clag qualification did not consider additional weight of condulet.

o Qualification of. 5/8-inch copper tubing was not retrievable.

e FSAR did not address use of copper tubing.

These concerns were noted to the project in action item C-51. The project implemented adequate C/A by revising the isometric drawing, demonstrating adequacy of the screening process (reference 288), generating qualification calculations (references 289 and 290), and initiating a licensing change for clarification. EA concurred with the adequacy of the C/A to resolve the concern.

As a result of the technical reviews of the 20 ECNs selected by EA and those reviewed by the NRC, a number of deficiencies were identified revealing a trend regarding inadequate FCR evaluations and drawing discrepancies. These concerns were presented

- to the project in revisions to action items C-05 and C-44. Theprojectresponse recognized that _ the specific exagles were captured by PIRs requiring subsequent engineering evaluation; however, the extent was not clearly addressed for assuring an adequate 084VP review. The calculation program which is the basis of establishing technical adequacy for the civil D88VP ef fort did not adequately address .the extent of these concerns. See observation C5.

22. Design Review Checklist Evaluation EA had reviewed the civil D64VP checklists for the adequacy of civil considerations. The EA Civil performed a review of six design review checklists (references 250, 291 through 295) prepared by the SE to evaluate the adequacy of incorporating the civil data.

The checklist for ECN L5497 for System 70 (reference 295) was evaluated for the addition of unions to relief ~ lines on the spent fuel pit heat exchangers. This checklist adequately incorporated the civil D84VP checklisi as Appendix 2C of the design review checklist (DHC).

The checklist for ECN 2120 for System 62 (reference 292) was reviewed for the redesign of the steam leakof f piping for valve VLV-68-580. This checklist did not make any reference to any civil D64VP checklist, and incorrectly determined the seismic adequacy of the change by sigly referencing the USQO. Thisconcernwaspresentedtotheprojectin action item C-55. TheprojectestablishedaC/AprograminProjectDirective DRVP-0-86-010 (reference 251) for Civil 084VP to review all SYSTER generated in accordance with SQEP-16 (reference 58) to ensure their input was properly incorporated in the design

. review checklist attached to the SYSTER, and concur on the conclusions of the system evaluation. The project adequately revised the Design Review Checklist for 2120.

'The checklist for ECN L6706 for System 68 (reference 291) was reviewed for its evaluation of design adequacy of pipe supports from the as-constructed data gathered from field 7.5.5-16

walkdowns. This checklist incorporated the wrong civil checklist. The design checklist referenced the civil checklist for L6701 (reference 296) which resulted in inadequate checklist conclusion. This concern was reported to the project in action item C-40. The project C/A was the same as C-35 which was determined by EA to be adequate. Theproject adequately revised the Desigr. Review Checklist for L6706 except for specific response to question B-l. EA verification of adequate revision to the checklist for clarification is required. See observation C6.

A general concern found earlier from the reviews of these design checklists was the The inadequate response to question B-l of all conpleted checklists prepared by the SE.

response was marked " addressed," referencing a CEB memo (reference 297), despite deficiencies cited in the applicable civil DB&VP checklist. This concern was noted to the project in action item C-54. The project clarified that the CEB memo documented the basis for identifying additional attributes in the civil DB&VP checklist which needed to be evaluated consistent with item 10 of the generic guideline (reference 5). The generation of SQN-DC-V-l.0 (reference 298) validated the project contention that these additional attributes adequately enconpassed the required considerations for conpliance with RD80.

The generic C/A inplemented by 08VP-D-86-010 would ensure consistency of responses to question 8-l. EA determined the C/A for this action item was adequate and review of checklists included in the SYSTERs found that the C/A was generally implemented adequately. Specific exanples requiring additional EA verification are detailed in section 7.7.5 The Design Review Checklist (reference 294) for ECN L5773 prepared by the SE was reviewed by EA. This checklist did not incorporate the latest civil DB&VP checklist (reference 299) and did not address pipe rupture considerations. The design checklist did not address question B-1 concerning compliance to the RD80 based on the finding concerning PIRSQNCEB8666 (reference 253). These concerns were previously captured in action items C-40 and C-34 in which the C/A program was found to be adequate, and the specific DRC was verified to be adequately revised.

The EA Team also evaluated the Design Keview Checklist tm tCN L5779 (reference 295) and 2971 (reference 250) which were detailed earlier in this section during the technical evaluation.

In sunm3ry, five cf the six Design Review Checklists initially did not adequately incorporate the civil ingr . The project established appropriate C/A by inplanenting DBVP-D-86-010 (reference 231). EA performed a subsequent review of these five checklists upon the issue of the applicable SYSTER, and found that all five were revised to adequately incorporate the civil data to resolve the concern. The checklist for L6/06 requiresverificationofprojectC/Aforconsistencyofresponse. See observation C6.

23. ECN Reviews for Vibrational Ef fects EA reviewed three ECNs (references 300 through 302) to evaluate the adequacy of the

' project review for operational vibrational ef fects. The EA evaluation of ECN 2419 (reference 117) concurred with the project's determination (reference 301) that since the change reanalyzed ERCW piping for the accident transient DBA load, this ECN could not increase the likelihood of an operational vibration. The project checklist (reference 302) recognized ECN 2971 (reference 16) and changed several systems to correct discrepancies found during the 79-14 ef fort. EA concurred with the evaluation of the projectchecklist. ECN L5724 (reference 18) involved the replacement of a failed snubber 7.5.5-17 j

with two rigid restraints. The project checklist (reference 503) identified the snubber had failed as a resialt of an operational transient vibration. This problem is being properly handled for resolution by at PMT-32 (referoce 246). This testing document was reviewed and found to adequately address the data required to establish operational transient.

24. FCN Evaluation The EA Team evaluated the technical adequacy of four FCN DRC (references 108 through 111);

however, FCNs in general were found to have very little civil involvement. The attribute sheets contained adequate explanations and evaluations to document the rational used for supporting checklist conclusions.

7.5.5.2. Conclusions The assent >ly and class fi;ation of chcnge documents were determined to be acceptable and in compliance with SQEP-Il with one exception. The total nunt>er of ECNs nay not be fully l Identifled and requires adequ.te C/A for PIRSQNMEB8659 to be established and subsequent CA verification. See observation Cf.

i The project adequately implemented the SQEP-12 evaluation process and identified applicable l

discrepancies on the D84VP punchlist. Technical adequacy and acceptable restart decisions l

have not been established due to the following, which requires additional EA verification.

See observation C5.

e The scope of the independent calculation program does not clearly address drawing l

discrepancies or adequacy of FCR evaluations. The program has not been fully implemented, and EA has not yet conpleted verification of C/A for technical abservation from EA Audit f

87-09.

l e An insufficient nuntier of punchlist dispositions are conpleted or inplemented to determine acceptability of ECNs.

e Partially inplemented ECNs have not been adequately evaluated based on field status.

7.5.5.5 References l

l Reference Document Revision Date Title i SQEP-Il 4 8/18/86 Procedure for Identifying and Assentiling Change Documentation 2 7/23/86 Procedure for Evaluating Engineering Change 2 SQEP-12 Notice and Flead Change Notice Documents SQN 4SG.'-048 2 8/6/86 Identification of Systems Required for Sequoyah 3

Restart (825 860806 805) 4 828 861210 006 0 12/4/06 Restart Design Basis Document 5 825 860827 005 N/A 8/27/% SQEP-12 Atf achment 2 Guideline 7.5.5-18 1

Reference Doctsnent Revision Date Title N/A 12/27/78 Engineering Change Notice 2166 (SWP 781229 063) 6 ECW 2166 N/A 4/2/81 Engineering Change Notice 2944 (SWP 810402 50/)

7 ECN 2944 N/A }/10/80 Engineering Change Notice L5227 (SWP 800510 500) 8 ECN L5227 N/A 11/9/82 Engineering Change Notice L5774 (825 851101502) 9 ECN L5779 N/A 9/30/85 Engineering Change Notice L6004 (825 860ll4 525) 10 ECN L6004 N/A l/5/85 Engineering Change Notice L6300 (825 860505 508) ll ECN L6500 N/A 6/19/85 Engineering Change Notice L6739 (825 060117 507) 12 ECN L6439 N/A 2/22/82 Engineering Change Notice L5451 (B25 860114 515) 13 ECN L5451 N/A 7/11/86 Engineering Change Notice L6710 (825 860716 502) 14 ECN L6710 N/A 9/6/79 Engineering Change Notice 2548 15 ECN 2548 N/A I/l)/81 Engineering Change Notice 2971 16 ECN 2971 N/A 8/6/80 Engineering Change Notice L5298 17 ECN L5298 N/A 9/28/82 Engineering Change Notice L5724 18 ECN L5724 N/A 10n/82 Engineering Change Notice L5750 19 ECN L5750 N/A 2/8/83 Engineeririg Change Notice L577) 20 ECN L5773 N/A 11/8/85 Engineering Change Notice LS824 21 ECN L5824 ECN L6202 N/A 8/20/84 Engineering Change Notice L6202 22 N/A 11/13/84 Engineering Change Notice L6263

2) ECN L6265 ECN L5268 N/A 4/22/80 Engineering Change Notice L5268 24 ECN L61% N/A 7/29/84 Engineering Change Notice L6t% (825 8604I4 509) 25 0 12/9/06 Procedure for Evaluation of Changes for Ef fect 26 SQEP-51 on Piping Vibrations and Testing Requirements 27 Attachment i N/A ECN Identification Form of SQEP-ll for ECN L6184 28 Attachment i N/A ECN Identification Form of SQEP-ll for ECN-L6183 7.5.5-19

- _ - - - _ ____________-_____-___-_____-_-__-______________J

Reference Document Revision Date Title 29 Attachment i N/A ECN Identification Form of SQEP-il for ECN-L6182 ,

30 Attachment i N/A ECN ldentification Form of SQEP-ll for ECN-L6181 31 Attachment i N/A ECN Identification Form of SQcP-il for ECN-L6180 32 Attachment i N/A ECN Identification Form of SQEP-ll for ECN-L6119

3) Attachment i N/A ECN Idectification Form of SQEP-ll for ECN-L6176 34 Attachment i N/A ECN Identification form of SQEP-il for ECN-L6175 35 Attactnnent i N/A ECN Identification Form of SQF.P-il for ECN-L6174 36 Attachment i N/A ECN Identification Form of SQEP-il for ECN-L6175 57 Attactvnent i N/A ECN Identification Form of SQEP-il for ECN-l6027 58 Attachment i N/A ECN Identification Form of SQEP-il for ECN-L5902 39 Attachment i N/A ECN Identification Form of SQEP-il for ECN-L54}4 40 Attachment i N/A ECN Identification form of SQEP-il for ECN L292) 41 Atlachment i N/A ECN Identification form of SQEP-il for ECN L2945 7.5.5-20 J

Reference Document Revision Date Title 42 Attacionent i N/A ECN Identification Form of SQEP-il for ECN L2693 43 AtIachment i N/A ECN Ideniification Form of SQEP-ll for ECN L5647 44 Attactrwnt i N/A ECN Identification Form of SQEP-ll for ECN L5649 45 Attactnent i N/A ECN Identification Form of SQEP-ll for ECN L%50 46 Attachment i N/A ECN Identification Form of SQEP-il for ECN L%51 47 Attachment i N/A ECN Identification Form of SQEP-ll for ECN L%52 48 Attachment i N/A ECN Identification Form of SQEP-li for ECN L%53 49 Atlachment i N/A ECN Identification Form of SQEP-il for ECN L%%

50 Attachment i N/A ECN Identification Form of SQEP-il for ECN L5657 51 Attachment i N/A ECN Identification Form of SQEP-il l

for ECN L5654 52 Attachment 1 N/A ECN Identification Form of SQEP-il for ECN L5655 0 Problem Identification Repori for SQ WEB 8659 l 5) PIRSQNME80659 Attachment 3-B N/A Inprocess FCR Identification Form 54 of SQEP-fi for FCR 4}l2 7.5.5-21

.. I

Reference . Document _ Revision Date Title 55 Attachment 58 N/A inprocess FCR Identification Form of SQEP-il for FCR 4095 N/A N/A FCR Identification Form - Category D FCRs 56 Attachment 5-A of SQEP-Il for FCR 5505 N/A N/A FCR Identification Form - Category D FCRs 57 Attactment 5A of SQEP-Il for FCR 4557 2 10/17/06 Procedure for System Evaluation and Development 58 SQEP-16 of System Evaluation Report 59 Attachment i N/A ECN Identification Form of SQEP-il for ECN 6604 60 Attactnent 5 N/A FCN Identification Form of SQEP-Il for IEND-40562 61 Attachmen1 5 N/A FCN Identificaiion Form of SQEP-li for TENO-40514 62 Attachment 5 N/A FCN Identification Form of SQEP-li for TEM-10651 f 65 Attachment 5 N/A FCN Identification Form of SQEP-il for TEM-10649 64 Attachment 5 N/A FCN IdentifIcaiion Form of SQEP-il for IENM-10645 65 Attachment 4 N/A N/A TACF Identification Form of SQEP-il for TACF 2-84-115-5 66 Attachment 4 N/A N/A TACF Identification Form l

of SQEP-Il for TACF 0-86-007-517 7.5.5-22

___________J

l-l l-Revision Date_ Title Reference Document Attactwnent 4 N/A N/A TACF Identification Form (B25 861025 203) l 67 I of SQEP-il for 1ACF 0-85-040-62 Attachment 4 N/A N/A TACF Identification Form 68 of SQEP-il for TACF l-85-0092-26 Attactunent 4 N/A N/A TACF Identification Form 69 of SQEP-Il for TACF l-82-301-78

-Attachment 4 N/A N/A TACF Identification form 70 l

of SQEP-il for TACF l-85-085-317 N/A SCR/NCR Condition Adverse to Quality 71 Attachment 6 of SQEP-il Identification Form for SQNCE00ll5 i

SCR/NCR Condition Adverse to Quality 72 Attachment 6 of SQEP-il Identification Form for SQ1CE08404 RI SCR/NCR Condition Adverse to Quality 73 Attactunent 6 N/A of SQEP-il Identification Form lor CEB 79-19 4

N/A SCR/NCR Condition Adverse to Quality 74 Attachment 6 of SQEP-il identification form for GENCEB8402 N/A SCR/NCR Condition Adverse to Quality 15 Attachment 6 of SQEP-il Identification Form of SQNSWP8222 N/A SCR/NCR Condition Adverse to Quality 76 Attachment 6 of SQEP-il identificalion Form of SQNCEB8303 N/A SCR/NCR Condition Adverse to Quality 77 Attachnent 6 of SQEP-il Identification Form of SQNCER8302 7.5.5-23 2

Reference Docwent Revision Date Title N/A SCR/NCR Condition Adverse to Quality 78 Attachment 6 of SQEP-il Identification Form of SQNEEB8627 N/A SCR/NCR Condition Adverse to Quality 79 Attachment 6 of SQEP-il Identification Form of SQNNE88107 N/A SCR/NCR Condition Adverse to Quality 80 Attachment 6 of SQEP ll Identification Form for SQNCE88412 N/A SCR/NCR Condition Adverse to Quality 81 Attachment 6 of SQEP ll Identification Form for SQNCEB8414 i SCR/NCR Condition Adverse to Quality 82 Attachment 6 of SQEP ll Identification Form for SQNCE88101 i SCR/NCR Condition Adverse to Quality 83 Attachment 6 of SQEP 11 Identification Form for SQNCE88508 i SCR/NCR Condition Adverse to Quality 84 Attachment 6 of SQEP ll Identification Form for SQNCE884%

N/A SCR/NCR Condition Adverse to Quality 85 Attachment 6 of SQEP-il identification Form for SQNCEB8403 0 NCR - Pipe Break Documentation Error 86 Attachment 6 of SQEP-Il SQNCE88010 Attachment 6 0 NCR - Pipe Support Error 87 of SQEP-il SQNCE88032 88 Atlachment 6 0 NCR - TPIPE Error of SQEP-il SQNCE88402 SCR/NCR Condition Adverse to Quality 89 Attacivnent 6 --

of SQEP-il Identification Form for SQNCE88041 7.5.5-24 J

I

(

Revision _ 'Date Title Reference Document _

SCR/NCR Condition Adverse to Quality 90 Attachment 6 --

of SQEP-il Identification Form for CEB 78-5 SCR/NCR Condition Adverse to Quality 91 Attachment 6 --

of SQEP-il identification Form for SQNSWP8025 D8VP-D-06-Ol9 0 ProjectDirective 92 DRVP-D-87-002 0 -- ProjectDirective 95 N/A local Design Change Request identification 94 Attachment 2A of SQEP-Il form for L-DCR 0588 N/A Local Design Change Request identification 95 Attachment 2A Form of SQEP-il for L-DCR 1212 N/A local Design Change Request identification

% Attactsnent 2A Form of SQEP-il for L-DCR 1425 N/A local Design Change Request identification 97 Attachment 2A Form of SQEP-il for L-DCR 1450 N/A local Design Change Request identification 98 Attachment 2A Form of SQEP-il for L-DCR 1549 N/A local Design Change Request identification 99 Attachmtent 2A Form of SQEP-il for L-0CR 1594 N/A local Design Change Request 100 Attachment 28 of SQEP-Il for L-DCR 1847 N/A Local Design Change Request 101 Attachment 2B of SQEP-ll for L-DCR 1855 Al-19 ProjectProcedure 102 N/A Office of Nuclear Power Generated Drawing 105 Attachment 7 Discrepancy of SQEP-Il for ONP-AC-105 i

7.5.5-25 J

Reference Document Revision Date Title 104 Attachment 7 N/A Office of Nuclear Power Generated Drawing of SQEP-ll Discrepancy for ONP-AC-135 Attachment 7 N/A Office of Nuclear Power Generated Drawing 105 of SQEP-Il Discrepancy for ONP-AC-412 106 Attachment 7 N/A Office of Nuclear Power Generated Drawing of SQEP-il Discrepancy for ONP-AC-504 107 Attachment 7 N/A Office of Nuclear Power Generated Drawing of SQEP-il Discrepancy (B25 861114 937) for ONP-AC-590 108 Attachment 2 N/A Design Review Checklist for System 68 of SQEP-12 for TENO-40562 109 Attachment 2 N/A Design Review Checklist for System 99 of SQEP-12 for TENO-40556 110 Attachment 2 N/A Design Review Checklist for System 99 of SQEP-12 for IENM-10645 Ill Attachment 2 N/A Design Review Checklist for System 99 of SQEP-12 for IENM-10651A l12 Attachment 2 N/A Preliminary Checklists of SQEP-12 for ECN L6540 l13 Attachment 2 N/A Preliminary Checklists of SQEP-12 for ECN L5691 114 Attachment 2 N/A Preliminary Checklists of SQEP-12 for ECN L5832 115 B4186%I6 011 CE8 Calculation Program Civil Policy Memo FM86-02 116 805 870210 001 N/A 2/10/87 EA Audit 87-09 Ili ECN 2419 N/A 6/25/79 Engineering Change Notice SWP 790625 500 7.5.5-26

.s

Reference Doctanent_ Revision Date Title N/A 12/27/78 Nonconformance Repori SWP-78-S-3

! -118 NCR SWP-78-S-5 119 Civil 08&VP N/A 7/15/06 Civil D8&VP Checklist Checklist for ECN 2166 for System 30 6 2/10/06 Location and Design of Pipe Supports 120 W8-0C-40-31.9 0 6/23/06 SQN Pipe Support Criteria 121 SQN-DC-V-24.1 N/A 47W920 Drawing Series 122 47W920 (Varies) N/A 0 12/19/78 Mechanical HVAC Typical Support No. 233 123 47A055-235 0 12/28/78 Mechanical HVAC Typical Support No. 234 124 47A055-234 0 12/27/78 Mechanical HVAC Typical Support No. 235 125 47A055-235 0 12/29/78 Mechanical HVAC Typical Support No. 236 126 47A055-236 SWP 810702 070 0 6/30/8l Pipe Support Calculations 47A055-232 through 401 127 0 8/31/81 SNP-Support Variance Calculations Book No. 21 128 SWP 820125 014 N/A 12/18/80 Nonconformance Report for SQNCE88041 129 NCRSQNCE88041 .

130 Civil 08&VP 1 9/17/86 Civil D8&VP Checklist Checklist for ECN 2944 for System 01 0 7/16/86 Problem Identification Report for SQNCEB8638 131 PlRSQNCEB8638 0 9/16/06 Problem Identification Report for SQNCEB8665 132 PlRSQNCEB8665 CE8 810729 039 9 7/23/81 Fummry of Piping Analysis 0600l04-06-03 133 Sequoyah Nuclear Plant Main Steam System CE8 810729 038 9 7/23/81 Sunmary of Piping Analysis 0600104-06-04, 134 Sequoyah Nuclear Plant Main Steam System 912 3/8/06 EDS Nuclear Main Steam Piping (Steam Generator 135 0600102-06-02 2) 2-HI-316 1 4/28/81 Basic Engineers, Sheet 2-Hi-316 136 2-HI -349 2 4/28/81 Basic Engineers, Sheet 2-Hi-349, Sheet I of 2 137 and Sheet 2 of 2 7.5.5-27

Reference Docunent Revision Date Title PIRSQNCEB8659 0 7/17/86 Problem identification Report for SQNCf88659 158 NCR SWP-80-S-5 N/A 2/15/80 Nonconformance Report (SWP 800215 054) 159 140 Civil 08&VP l 7/10/06 Civil DB&VP Checklist Checklist for L5227 for System 82 141 SWP 820502 008 2 2/22/82 2" O Less Class i Type Support Calculations 142 SWP 820502 009 2 2/22/82 2" O Less Class i Type Support Calculations SWP 800518 085 1 3/18/80 2" O Less Class i Type Support Calculations 145 144 SWP 820502 016 2 2/22/82 2" O Less Class i Type Support Calculations 47A055-172 1 3/10/80 Mechanical Seismic Support Process Pipe 2" 0 or 145 less 146 47A053-1728 1 3/10/80 Mechanical Seismic Support Process Pipe 2" 0 or less 147 47A055-151 1 3/10/80 Mechanical Seismic Support Process Pipe 2" 0 or Less 148 47A055-419 1 3/10/80 Mechanical Seismic Support Process Pipe 2" 0 or less 149 SWP 850204 817 1 2/4/85 Engineering Change Notice L5779, Data Sheet 5 150 Civil DB&VP 1 9/16/06 Civil DB&VP Checklist Checklist for L5719 for System 87 151 Attachment i N/A 7/ll/86 Change Document Evaluation Sheet for L5779 for of SQEP-12 System 87 for ECN L5779 19 11/12/85 Miscellaneous Steel, Crane Wall Errt>edded Parts, 152 48N914 Sheet 2 48N916 15 11/12/85 Miscellaneous Steel, Crane Wall Ent>edded Paris, 155 Sheet 4 154 NCRSQNSWP8501 1 10/28/85 Ent>edded Plate (825 851028 509) 7.5.5-28

(

Reference Document Revision Date Title i

155 Civil 088VP 0 7/10/06 Civil 088VP Checklist Checklist for L6004 for System 65 156 Attachnent 2 N/A 10/19/86 Structural Design Criteria for Design Review of SQEP-12 Checklist for ECN L5881 157 Attachment 2 N/A 10/4/% Structural Design Checklist for Design Review of SQEP-12 Checklist for ECN L6207 158 4tN321-1 15 8/21/85 Concrete, elf 54.0, floor Outline 159 4tN321-2 15 8/21/85 Concrete, EL7}4.0, Floor Outline 160 46W405-5 7 4/12/85 Architectural Reinforced Masonry Walls, Plans and Details i

161 46W405-6 7 4/12/85 Architectural Reinforced Masonry Walls, Plans

! and Details I62' Civil 00&VP N/A 7/8/86 Civil DB&VP Checklist l

Checklist for L6500 for System 26 l

i 165 825 8606}0 80) 0 6/}0/06 Fire Protection Draff Stops l

164 Civil 084VP 2 9/24/86 Civil D88VP Checklist Checklist for L6439 for System 68 165 B25 060524 812 0 5/21/86 Seismic Qualification (ll) of Panels I and 2-L-454 and I-t-472 Due to ECN L6459 166 N2-68 -A-)l 4R N/A Prel Piping Analysis of Preblem N2-68 A-314R 167 B25 860515 101 0 1/4/86 Pipe Suppori and instrument Tubing 47A051-19-A160 168 825 86051) $02 0 1/4/86 Pipe Support and Instrument Tubing 47A051-19-Al61 169 825 060513 305 0 1/7/86 Pipe Support Variance 47A051-38 A55 7.5.5-29

Reference Docurm:nt Revision Date Title B25 860515 506 0 1/4/86 Pipe Support Variance 47A051-58-A56 170 0 N/A Condui1 Suppori 47A056-1066-A84 I 11 B25 8608l4 302 0 7/14/86 Rebar Cuts for Sleeves in Reactor Building 172 825 860714 801 Crane Wall 0 11/25/85 Reactor Building Concrete Rebar Cuts ll) 025 85Il25 500 114 Civil DB&VP 1 8/25/86 Civil DBaVP Checklist Checklist for L5451 for System 82 N/A 12/2/83 Menorandum to Civil Engineering Support Branch 115 CEB 831202 250 files from J. T. Huie, Mechanical Engineer (Engineering Mechanic Group), Civil Engineering Support Branch, W) Dl95 C-K MEB 851215 950 0 11/3/85 Qualification of tube Oil System Modification, 176 Sequoyah Nuclear Plant 0 5/2/82 Seismic Qualification Report on Soakback Punp -

' 117 MEB 820402 981 Lube Oil Modificalion 0 7/16/86 Problem identification Report 178 PIR$QNCEB8657 (825 860819 019) l pWP 830511 018 0 5/II/8) Support Variance Calculation 179 FMP 840606 805 0 6/6/84 Typical Instrunentation Support Variances 180 Calculation 2/14/80 Mechanical Seismic Support 181 47A051 -19 1 Instrunent Sensing (ines 7/l5/84 Mechanical Seismic Support instrument Sensing 182 47A051-15 5 Lines N/A 9/l}/8) Nonconfornunce Report (CER 850921 015)

' 185 NCRSQNCEB8305 j

CEB 850825 008 0 8/25/85 Rigorous Analysis Handbook Class 2 and 5 184 Analysis, Section SQN-RAll-2%, Termination of Analysis Problems 185 Civil DB&VP 1 11/12/86 Civil DB4VP Checklist Checklist for L6710 for System 6) 1.5.5-30

Reference Document Revision Date Title 0 8/18/86 Problem Identificalion Repori 186 PlRSQNCE88657 825 860824 301 1 8/24/86 Pipe Suppori H20-435 187 6/5/86 Pipe Support H20-437 188 B25 860605 552 0 0 6/5/86 Pipe Suppori H20-440 189 825 860605 347 0 6/5/06 Pipe Support H20-441 190 B25 860605 331 6/5/86 Pipe Suppori H20-445 191 825 860605 528 0 825 860824 500 1 8/24/86 Pipe Support H20-444 192 905 8/15/86 Basic Engineers Sheet H20-435

19) H20-455 f

904 8/15/86 Basic Engineers sheet H20-435A 194 H20-435A 901 7/20/86 Basic Engineers Sheet H20-437 195 H20-437 901 7/20/86 Basic Engineers Sheet H20-440 1% H20-440 90 7/20/86 Basic Engineers Sheet H20-441 197 H20-441 901 7/20/06 Basic Engineers sheet H20-443 198 H20-44) 902 8/15/86 Basic Engineers Sheet H20-444 199 H20-444 902 8/15/86 Basic Engineers Sheet H20-444A 200 H20-444A 9/15/86 Review of Piping Analysis for Adequate 201 841 860915 264 1 Termination - OSR-5048 7/16/80 Sumury of Analysis N2-65-1 A, -2A 202 825 860717 815 2 4 9/15/86 Sunmary of Analysis N2-65-72-74-lA, -2A 203 825 860916 810 478435-76 4 7/19/06 System N2-6)-2A Support Loads-Safety injection 204 System-SIS Pwp Suction 4 7/19/86 System N2-65-2A Support loads-Safety injection 205 478435-77 System-SIS Pwp Suction i N/A Problem Identification Report 206 PIRSQNCEB8709 207 Civil DB&VP 0 7/23/86 Civil DB&VP Checklist f Checklist for t

l 2548 for l

System 72 l

1.5.5-31

-- - - - - _=_ , .

h Reference Document _ Revision Date Title L

B41 860411 005 1 4/11/06 Steel Contairunent Vessel Miscellaneous Steel 200 Support Calculation 8 5/20/80 12" Containment Spray Dynamic Analysis l

209 0600104-01-01 8 5/20/80 12" Containment Spray Dynamic Analysis 210 0600104-01-02 7 5/20/80 12" Containment Spray Dynamic Analysis l 211 0600104-01-05 7 5/20/80 12" Containment spray Dynamic Analysis 212 0600104-01-04 9/7/198 12" Containment Spray isometric 215 0600102-01-01 7 7 9/11/79 12" Containment Spray isometric 214 0600102-01-02 6 9/5/79 12" Containment Spray isometric 215 0600102-01-0) 6 9/5/79 12" Containment Spray isometric 216 0600102-01-04 217 Civil D64VP 0 7/25/86 Civil 084VP Checklist Checklist for 2971 for System 72 4 6/23/31 Containment Spray Pipe isometric 218 47K437-50 l

5 4/22/81 Containment Spray Pipe isometric i 219 47K457-51 4/10/81 Containment Spray Test Line isometric 220 47K457-52 3 4/29/81 Containment Spray Test Line isometric 221 47K427-55 3 2 7/29/81 Containment Spray Test Line isometric 222 47K457-54 I 5/21/01 Containment spray Test Line isometric 225 47K457-55 2 6/15/81 Containment Spray Pipe Calculations 224 N2-72-I A 2 6/15/81 Containment Spray Pipe Calculations 225 N2-72-2A I I/15/87 Containment Spray Pipe Calculations 226 N2-72-3A I 3/2/81 Containment Spray Pipe Calculations 227 N2-72-4A I 5/18/81 Containment Spray Pipe Calculations 228 N2-72-5A 0 2/23/81 Containment Spray Pipe Calculations 229 N2-72 6A 7.5.5 52

l Reference Document _ Revision Date Title 250 Design Review 0 7/23/86 Design Review Checklist I

-Checklist for l FCN 2971 for System 72 2 31 08VP-D-86-010 0 10/15/86 ProjectDirective 48N1525 14 4/10/81 Miscellaneous Steel Cable fray Support 232 6 4/10/81 Miscellaneous Steel Cable fray Suppori

25) 48NI)26 2 4/7/81 Miscellaneous Steel Cable Tray Support 234 825 861027 802

(

Calculatlons 2)$ SQN-DC-V-l . ). 4 0 8/20/75 Design Criterla - Category i Cable fray Support System 2 56 47A056 5 3/50/81 Category I and 1(L) Conduit Supports typical Drawings 257 M4Al-ll 12 }/14/06 Modifications and Additions Instruction 45N832-1 24 7/4/85 Conduit and Grounding Drawing 2 50 2 59 SQN-0C-V-15.10 2 11/20/85 Design Criteria - Seismically Qualifying Conduit Supports 240 FCR 455 N/A I/2/81 Field Change Request (SWP 810106 018) 241 FCR $65 N/A 5/22/81 Field Change Request (SWP 810528 033) 242 Civil DaavP 0 6/25/86 Civil 084VP Checklist Checklist for L5724 for System 14

) 12/25/82 Residual Heat Removal Pipe Analysis Isometric i 24) 47K432-56 Cf8 821117 000 l 11/16/82 Residual Heat Renoval Pipa Analysis Calculation 244 902 1/26/82 Residual Heat Removal Pipe Support 245 H65-569 246 PMT-32 N/A 10/29/85 Postmodification Test (825 85l029 014)

CtB 821028 012 0 10/21/82 Containment Penetration Analysis 247 Ctil 840904 006 0 9/4/84 Containment Penetration Analysis 248 T.5.5-35

r~

l

' Date fitte Reference Documen_t Revision 249 CI A 849817 256 0 9/l7/84 Qualification of 5/4-inch Globe Valves 9 / 50/06 Problem identificalion Repori for SQNCf 88655 250 PlRSONCE8%55 0 (825 861002 055)

(

Civil 084VP 0 8/7/tn Civil 084VP Checklist 251 Checklist for ECN L5750 for System 88 Civil 084VP 0 9/18/06 Civil 084VP Checklist 252 Checklist for ECN L5775 for System 68 0 2/20/87 Problem Ideniification Report (825 870505 006) 255 PIRSQNCE88666 2 6/15/84 Coniponent Cooling System Piping Analysis 254 IWP 840628 000 Calculation 8 7/5/84 Conponent Cooling System Piping Isometric 255 47K464-60 11 7/1/84 Congonent Cooling System Piping isolation 256 47K464-74 Civil 084VP l 8/28/06 Civil 084VP Checklist 257 Checkilst for L5824 for System 70 Civil 084VP 0 9/5/86 Civil 084VP Checklist 258 Checklist for L6202 0 9/5/86 Pipe Rupture Evaluation 259 841 860905 024 Civil 084VP 0 7/10/06 Civil 084VP Checklist 260 Checklist for L6265 for System 5 905 5/20/85 feedwater Pipe Support Details 261 2 H4-282 905 5/20/85 Feedwater Pipe Suppori Details 262 2 -H4-522 2 5/21/85 Pipe Support Calculation 265 025 850521 807 0 8/25/06 Problem IdentifIcatlon Repori 264 PIR$QNCt88659 I 5/18/81 Containment Spray Test Line Piping Analysis 265 N2-72-5A I 4/22/80 Isonetric Drawing 266 47K457-55 1.5.5-54

Reference Docwent Revision Date Title 14 4/22/80 Mechanical Piping Drawing 267 47457-5 0 4/10/80 Containment Spray Test Line Piping Analysis 768 N?-72-5A 269 Civil 084VP 2 10/28/86 Civil 084VP Checklist Checklist for ECN L61% for System 68 I I?/19/84 Piping Analysis Documentalion Problem 210 SQP 841220 005 0600154-13-05 907 10/15/84 Basic Engineers, Sheet 2-H %-72 271 2-H %-72 2-H%-105 907 6/10/06 Basic Erigineers, Sheet 2-H%-105 772 2-H%-127 906 3/20/85 Basic Engineers, Sheet 2-H%-127 273 0 3/11/85 Reactor Coolant System, 7-H%-72 274 825 850312 500 0 2/26/85 Reactor Coolant, 7-H%-105 275 SQP 850226 800 3/8/85 Reactor Coolant, 2-H%-127 216 825 850300 304 1 N/A l/29/06 Field Change Report 5%)

717 SQNP Al-19 Part IV Attachment 8 for Revision 12 for FCR 5%)

ECN 165% N/A 12/10/85 Engineering Change Notice B25 860117 509 2 18 12/5/84 lone Switch Mounting Details 2 79 47A)48 260 1 0 6/12/86 fone Switch Mounting Details 780 47A348-287 281 825 861202 801 0 I?/l/06 Seismic Qualification Calculation FCR 4289 0 3/10/06 Field Change Request 4289

?H2 (6449 N/A 7/24/85 ingineering Change Notice l6449 28) 784 N2 70 A 50lA I I?/10/86 Piping Analysis Calculaflons (825 061??? 819) 785 4 M464-8  ?? 1/?0/06 Physical Piping Drawing (CN 16407 N/A 9/17/05 Ingineering Change Notice 825 860114 SOS 286 787 0 WD-?l5 1 5/12/80 Hanger Localion IsmetrIc 7.5.5-)$

I~

l l

l I

Revision Date Title i

Reference Document _

l 7/4/86 Alternate Analysis Review Program Evaluation of SQN-AA-006 0 288 l Plans for Phase i Issues 0 7/18/06 Solenoid Seismic Qualification Calculation 289 B25 860718 800 0 t/19/87 Solenoid Seismic Qualification Calculation I 290 825 870l?0 807 0 9/24/86 Design Review Checklist for System 68 291 OCR for (825 861101 258)

ECN L6706 0 9/17/86 Design Review Checklist for System 62 292 OCR for (825 861025 05))

[CN 2120 0 9/20/06 Design Review Checklist for System 70

29) DCR for (825 860926 093)

ECN L5497 0 9/18/86 Design Review Checklist (B25 861101 226) 294 OCR for ECN L5fl5 0 9/19/86 Design Review Checklist (825 061101 284) 295 DCR for ECN L5719 0 8/6/06 Civil 084VP Checklist 296 Civil 084VP for System 68 Checklist for L6701 8/25/86 SQlP-12 (R2), Attachment 2, Page 2 of 7, 297 ftsmo f rom J. Rupert to Question 8.1 fach Systwn Engineer 0 12/5/86 Design Crlieria i 298 SQN DC-V-l.0 l

0 7/16/06 Civil 084VP Checklist 299 Civil 084VP Checklist for L5ll)

N/A 12/12/06 Vibration checklist 100 SQlP-51 Attachment A for ICN 2419 N/A 12/10/06 Vibration checklist 301 SQtP-51 Attactvmint A for ECN 2911 N/A 12/11/06 Vibration checklist 302 SQE P-51 Attactment A for ECN 5124 7.5.5 36

7.5.6 guality Assurance lhe QA discipline of the [A foam review of change document evaluation consisted of a progranmitic review of the activities of the Change Control Board (CCB) program.

The CCB has the task of providing overall nunagement control of modifications during '

l the transition period from the existing modification control process to the new control process. The EA review verified the adequacy of this prograrmillc control for [CNs designated as prerestart by the 004VP project, i

ihls activity was acconiplished by verifying conpliance with SQN instructions SQA-18) and

! SQtP-15 (references I and 2). Program inglementation was specifically checked for ade ,uacy in two phases. The first phase involved ensuring that selected [CN's which were identified ,

as restart items by 004VP were approved by the CCB and that the required work, including I any drawings or instruction revisions, was either already conpleted or scheduled to be i completed prior to restart. The second phase was to review all past CCR meeting minutes, list all modifications which were cancelled or deferred by the CCB, determine if any of these nodifications were identified by 004VP as required restart items, and then ensure that these CCB decisions were appropriately documented with copies distributed to DNE.

7.5.6.1 Details the first phase of checking for adequate programmtic implementation involved selecting a total of three representative prerestart [CNs at random from SYSilRs 18 and 61 (references ) and 4). The (CNs selected were L6791, L6690, and L6759 (references 5 through i), it was then verified that these three [CNs were approved by the CCB as ,

prerestart items, ihls CCB approval was acconplished by approving generic OCR 7259 i

(reference B). Ihis DCR which encompasses all three ICNs reviewed was written specifically to inplement C/A identified in the resolution to problems associated with NCRs, SCR$, and tRs. ,

l EA QA also verifled if DNC and the plant modifications organisation had developed ICN inplementation schedutos along with cmpleting any required as-constructed /(onfiguration I control drawings or instruction revisions.

I iwo of the three (CNs, L6690 and L6759, were found to be in various stages of conpletion as follows:

l KN_t6690 @eference 6)--[CN L6690 is being perforned using two workplans,12006 and 12 (references 9 and 10). Workplan 12006 was field-cmplete and workplan-conplete and was filed as a QA record in the plant records vault. In reviewing this file, no drawings were '

A ilsted in the workplan as requiring revision and none were judged by IA to be required.

plant work instruction MAAl-9 (reference 11) was, however, shown in the workplan as requiring a change. Further review verifled that this instruction was appropriately r revised. e lHA, I Workplan 121$$ has not been conpleted to date, and af fected drawings 41A0$0 li. -10, and 41A0$61 (references 12 through l$) were in the process of being revised (or inillalty l developed) and issued. All renuining work is scheduled to be conpleted before restart. .

l 1.5.6 1

1 I

[CN 16139 (Reference,1))--ECW L6759 is being performed using two workplans 12205 and 12204 (references 16 and 11).. As of the time of the EA review and this writing, neither is coglele. It is to be noted that sections do exist in all workplan packages for addressing any needed drawing or instruction change.

lhe third ECN reviewed, L6791 (reference $), was found to have been previously listed on P/2 as a prerestart item but had been rescheduled postrestart. At the time of this review, the ECN was not iglemented and no copy of applicable workplan 12211 (reference 18) for this ECN could be located. The removal from P/2 problem was determined l

! to have been caused by a lack of a tie between two site instructions, SQA 185 and SQA-190

! (references i and 19). This problem was presented to the project in action item Q-Oi.

The project has subsequently identified specific and generic C/As along with actions to prevent recurrence. These actions include revising existing instructions and correcting the appropriate records. EA Team verification of C/A is required (see observation Ql).

The second phase of verif ying adequate progranmitic iglementation of SQA-18) and SQ(P-15 involved searching for cancelled or deferred nodifications and determining if those CCB -

decisions were properly documented and copies were distributed. In reviewing CC8 meeting I minutes, only four cancelled or deferred nodifications were found: OCRs 679, 1714, 652, and 914 (references 20 through 25). All of the ECNs associated with these OCRs were evaluated for applicability to the 084VP and several were unit 2 restart items. OCR 954 was cancelled since it was determined that no actual modification was involved. DCRs 619 and 1714 were deferred in the October 19, 1986, CCB meeting and DCR 652 was cancelled in the October 17, 1986, meeting. No cogleted SQA-185 Attactement 4 form could be located t

formally documenting any of these deferrals or cancellations, nor was this document sent to DNE. This lack of documentation / distribution concern was directed to the project in action item Q-08. For corrective action, CCB documented the three cancellation / deferrals and sent copies to DNE, and the action itom was subsequent 1y closed.

Another action item 0 05, was identified in the early iglementing stage of the CCB program during review of SQA-105 and was presented to the project. This concern pertained to SQA 185 failing to recognize a DNE appeal process for CC8 decisions to cancel I

nodif ications. the action item resulted in Site personnel revising SQA-185 to recognite this appeal process, this revision corrected the concern and the item was closed, n 1.5.6.2 Conclusions Upon acceptable closure of observation Ql, the CC8 program is judged to be adequately providing overall control of all plant modifications. This control should facilitate adequate transition to the new change control system.

1.5.6.5 References issue Roference Doctant Revision Date iltle 1 SQA.185 ) -- Change Control Board l

0 -- Procedure for DN( interface with Change Control [

2 SQlP.l> '

Ibard (CCB) l.$.6 2

Issue Ref er ence Docment Revision Date iltle SYSilR 18 0 -- Systun Evaluation Repor1 - Systen 18 f uel Oil

)

SYSilR 61 0 -- System Evaluation Report - System 61 Ice 4

Condenser ECN L6791 -- -- Engineering Change Notice 5

6 ECN LW)0 -- -- Engineering Change Notice 1 ECN L6739 - -- Engineering Change Notice U DCR 2259 - -- Design Change Request WP 12006 -. -- Workplan 9

WP 1215) -- -- Workplan 10 f

) Modifications and Additions instruction, il M4Al-9 --

"fightening, inspection, and Documnf ation of Bolted ConnecIlons" l

Orawing 0 -- Selsnic Class 1 Structures - Mechanical Hanger i

I?

41A050 Il Drawing - General Notes Drawing 0 -- Se19nic Class i Structures - Hechanical Hanger 1)

Orawing - General Notes l

4 7A050-18 l

14 Orawing (proposed) --

47A050 IBA Orawing 15 -- Seismic Class i Structures - Seismic Supports 15 41A056 1 Conduii 16 WP 1220) . - Workplan il WP 12?04 - - Workplan 10 WP 12211 . - Workplan 19 SQA 190 0 -- Sequoyah Activities list Restart lion Olsposition 20 DCR 610 - - Design ChJnge Request 21 DCR llii -- Design Ct.ange Roquest

?? DCR 652 - - Dosign Change Request 23 DCR 914

-- Design Change Requerst 1.5.h-)

7.5.1 Construction the Construction discipline of the EA Team reviewed change docunwnts to determine the adequacy of nodification constructability for ICN and nodification workplan packagos, associated docunwnts and drawings, and redlined CRADs. The review covered the process fran inillation, approval, and issue of an LCN package by DNE through the Inglenentation of the nodification with the DNC workplan package to the conpleted redlined CRADs. To determine the adequacy of the process, the following attributes were considered: conpleteness of the

[CN package, clarity of scope-of-work definition in the ICN, accuracy of the CRA05 to reflect the ICN nodification, coupleteness of the workplan to accurately reflect the ICN modification, and completeness of inplementing instructions.

7.5.7.1 Details Seven LCNs, L5H00, L6616, L6649, L6146, L6749, (6191, (6829 (ref erences I through 1),

were reviewed along with their associated workplans WP 12020, WP 12011, WP 11969, WP 12225, WP/12152, WP 12265, and WP 125}2 (references 8 through 14) and CRADs 4 NH66-2, 4MH66 ll, 45N630-10, 45N65014, 45N105-7, 45N706-4, 4$N106-5 (references 15 through 21). All of the (CNs were processed in accordance with SQtP Al-ll (reference 22). Two of them, ICh 16797 and L6829, (references 6 and 7) were initially Intended to be processed in accordance with SQEP 15 (reference 23), but recolved walvers from the DNF project engineer to be processed in accordance with SQ(P Al-ll, which is permitted by SQlP-l). All seven of the workplan packages were processed in accordance with SQN Al-19 (Part IV) (references 24 anJ 2$). All of the CRA05 reviewed had been redlined "as-constructed" by Modification ingineers. There were no Indications that these drawings as redlined had been reviewed and validated as required in the Nuclear Performance Plan. This concern was presented to the project in action item T-01 (sco observallon it),

the results of the [A construction discipline reviews of the seven (CNs, seven workplans, and seven CRADs are presented below:

1. (CN L5Hb0 (Reference l) - AP SYS and VP SYS.-The scope of this change package involves the identification and labeling of fuse protection devices in various auxillary power systems. It was Inillally issued on niy 21,1963, and later revised on Decenter lu,1985, and February lo,1906, it was 1. sued to inplwunt DCR 1811.

The (CN package as revised on February 10, 1906, had been acceptably reviewed, evaluated, approved, and processed in accordance with governing procedures and cogni tnwnt s, the package contained the required cover sheet, llS00, nodification coppilance review, FCR, [Q review checklist, and drawing data sheets. It was cmplete, defined the scope of work, and provided suf ficient informellon to ensure detalled workplans, ef fective Installation, and QC Inspections. Thir ty-one workplans were issued by rmdification to Inplewnt the entire scope of this ICN.

fleid work was in process at the finn of this evaluation.

1.5.11

1 ,

i

2. [CN MI6 (Reference 2) - System 50- The scope of this change package involves ,

replacement of fire danpor fusible links in the HVAC duct between the letdown Heat l

l

[xchanger Room and pipe chase of the Auxiliary Building with higher tenperature i fusible links.

I it also involved the permanent renovat of 2 feet of HVAC duct from the danper to the I pipe chase. This ECN was issued to inplement the C/A for SCR$QNN(H852).

lhe ECN package had been acceptably reviewed, evaluated, approved, and processed in i

l accordance with governing procedures and connitments. The package contained the ,

! required cover sheet, USQ0, modification conpliance review, modification criteria, )

i

[Q inpact review, SCR, and drawing data sheets, it was conplete, adequately defined the scope of work, and provided sufficient information to ensure detailed workplans, elfective installation, and QC inspections. One workplan,12071, ws needed by Modifications to inglenent the entire scope of this ICN. Field work was conpleted

- for this modification on July /22,/1906. The workplan and drawings were "as-constructed" by the Modifications Cognirant ingineer and are under the control of the DNE Orawing Control Unit.

3. [CN (6649 (Reference 3) - Systems }0 and 43--The scope of this change package  ;

involves the replacement of existing wiring with quallfled higher tenperature wiring  ;

i inside specified Target Rock and Valcor solenoid valves throughout the plait

! requiring additional junction boxes and conduit changes to remove sharp bend radius l conditions, ihls IC'l was issued to inplement the C/A for SCRSQNNfH8540.  ;

the (CN package had been acceptably reviewed, evaluated, approved, and processed in j accordance with governing procedures and connitnents. The package contained the required cover sheet, USQ0, nodification conpliance review, modification critoria, 10 Impact review, SCR, DCR, FCR, and drawing data sheets. it was conplete, adequately defined the scope of work, and provided suf ficient infornution to ensure detailed workplans, ef fective installation, and QC inspections. One workplan, ll%9, was needed by Modifications to inclement the entire scope of this ICN. Fleid .

l work was cowpleted for this modification on August 20, 1996. The workplan and drawings were "as-constructed" by the Modifications Cognliant Ingineer and are under  :

l  !

the control of the ONE Orawing Control Unit.

4. (CN (6746 (Reference 4) - System ?ll, -The scope of this change packago involves the isolation of class l[ power supplies to non class if transformers by Installing l pcinary isolation fuses between the 400V AC vital power transfer switches and their l corresponding prinary fused disconnect switches. Ihls (CN was issued to inplant i the corrective action of NCRSQNSWlH?06. [

lhe (CN package had been acceptably reviewed, evaluated, approved, and processed in accordance with governing procedures and conmitmnnts. The package conf alned the required cover sheet, USQO, podification conpliance review, nodification criteria, j (Q inpact revlew, NCR, OCR, and drawing data sheets, it was conpfete, cdequately 1.5.l-2  ?

defined the scope of work, and provided suf ficient informflon to ensure detailed workplans, ef fective installation, and QC Inspections. One workplan, I???5, was needed by Modifications to Iglement the entire scopo of this (CN. Fleid work was in process at the time of this evaluation.

5. [CN 16149 (Reference 5) - Svstem 250 --the scope of this change package involves the replacement of all Sussman type 1(Al circuit protective actuator devices Ihis (CN was presently used throughout the plant with Rusvun MIS-5 typo fuses.

issued to inplement the C/A of SCR$QNtf R0644 and DCR 2259.

The ECN package had been acceptably reviewed, evaluated, approved, and processed In accordance with governing procedures and conmitments, the package contained the required Cover Sheet, USQ0, Modification Ccmpliance Review, Modification Criteria, f 0 Impact Review, SCR, and Drawing Data Sheets. It ws conplete, adequately defined the scope of work, and provided suf ficient informstlon to ensure detalled workplans, effective installation, and QC Inspections. One workplan, 12152, was needed by Modifications to inglement the entire scope of this (CN. Field work was in process at the time of thlt evaluation.

6. [CN l6797 JReference 6) _VP SLS -The scope of this change package involves the installation of two 4-polnl et.dironmentally quallfled terminal blocks to replace cable spilces required by ECN L6126 issued to replace an 8 point terminal block thJt had corroded. Two 4-point terminal blocks had to be used as there were no envirorenentally quellfled 8 point terminal blocks available in the industry that were quellfled for 10CFR$0.49 application. Ihls (CN ws issued to inglement DCR 9 12.

It received a walver to be processed in accordance with SQfP-Al-ll instead of SQtP-1).

The (CN package had been acceptably reviewed, evaluated, approved, and processed in accordance with governing procedures and C(egnlinwnts. The package confalned the required cnver shoot, USQO, nodification conpliance review, nudification criteria, IQ inpact review, OCR, and drawing data sheets. It was conglete, adequately defined the scope of work, and provided suf ficient informflon to ensure detallect workplans, oflective Installation, and QC Inspections. One workplan,12265, ws needed by Modifications to inplarent the entire scope of this (CN. fleid work ws congloted for this modification on Novenber 17, 1906. Drawings and the workplan were as constructed by the Modifications Cognisant Engineer and are under the control of the ONE Orawing Control Unit.

7. [CN_lfN9 (Reference 1) - Svjtam jlf -the scopu of this change package requires that fire danpers in the Control Bullding HVAC be ps<hJnlCally bloChed open and their elech Ital cable terminations renoved. Ihis ICN was issued to Inplenent the C/A of SCR$QN(ifW6tl5. It received a walvor to be processed in accordance with SQtP Al ll

. Instead of SQ(P l),

the (CN package hait been acceptably reviewed, evaluated, approved, and processed in 1.5.1-)

accordance with governing procedures and comitnwnts. The package contained the required cover sheet, U500, nodification cogliance review, nodification criteria.

[Q igact review, SCR, and drowirg data shoots. it was coglete, adequately defined the scope of work, and provided suf ficient information to ensure detalled wrkplans, ef fective installation, and QC inspections. One workplan,12552, was needed by Modifications to Iglenent the entire scope of this (CN. Field work had not started at the time of this evaluation.

8, W)rkp_lan I?0?O _(Reference _8) - AP SYS _and VP SYS -Ihis workplan was I of 51 workplans written and issued by Modifications to inglenent DNC (CN L5890 which authorized the identification and labeling of aunillary power system fuses.

The package had been acceptably reviewed, evaluated, approved, and processed in accordance with SQN Al-19 (part IV) Rl7, and other governing procedures and comnitnents, it contained the required data, docunwnts, and drawings including the workplan specification with detailed written instructions, inspection requirements and hoIdpolnt5. The conpleied package adequateIy defIred the wrk requlrenents and contained suf ficient detall to ensure correct installation, inspections, and docupentation for the portlon of the change covered by this workplan. Nospecial requirements or pustnudification tests were required. Field work had not been conpleted at the tirne of this evaluation.

9, Egkplan 12011 (Reference 3) - System 30 -This workplan was written and issued by Modifications to inplement DNE (CN LMI6 which authorlied the replacenent of fusible links in fire dangers of HVAC system with higher tavgerature fusible links and removal of portions of the HVAC duct. It was the only workplan needed to inglenunt this (CN.

The package had been acceptably reviewed, evaluated, approved, and processed in accordance with SQN Al-19 (Part IV) Ri7, and other governing procedures and cmenitnwnts, it contained the required data, docunwnts, and drawings including the wrkplan specification with detailed written instructions, inspection requirenwnts, and holdpoints. The cogleted package adequately defined the wrk requirenents and contained suf ficient detall to ensure correct installation, Inspections, and docwwnf ation. No special requirements or post m4lfication tests were required.

Field wrk was cmpleted for this axilfication on July 77, 1986. Ihlt wrkplan and drawings were as constructed by the Modification Cognllant [ngineer and are under the control of the DNE Drawing Control Unit.

10. Sydplin_l,lyLLReprwe_10) - Sylt_am110_a_nd_4}-lhls wrkplan was written and issued by nonfications to inglenent ONC LCN t%49 which authorlied the replaconent of existing wiring with quallflod higher tangerature wiring inside specifled farget Rock and Valcor solenold valves throughout the plant requiring additional junction boxes and conduit changes to recoved sharp tend radius conditions, it was ths only workplan needed to inplenunt this (CN.

the package had been acceptably reviewed, evaluated, approved, and processed in accordance with SQN Al.19 (Pari IV) Ril, and other governing procedures and comitnwnts, it contained the required data, docwents, and drawings, including the 1.5.1 4

workplan specification with detalled written instructions, inspection requirements, and holdpoints. The conpleted package adequately defined the work requirements and contained suf ficient detail to ensure correct installation, inspections, and docunentation. No special requirements or postmodification tests were required.

Field work was cogleted for this nodification on August 20, 1906. This workplan and drawings were as constructed by the Modification Cognilant Ingineer and are under the control of the DNC Drawing Control Unit.

II. Workplan 12225 (Reference 11) - System 201,-The workplan was written and issued by nodifications to Iglenwnt DNE [CN L6746 which authorlied the isolation of class IE power supplies to non-class IE transforners by installing primary isolation fuses between the 480V AC vital power transfer switches and their corresponding prinury fused disconnect switches. It was the only workplan needed to Iglenent this (CN.  ;

Ihe package had been acceptably reviewed, evaluated, approved, and processed in f accordance Hlth SQN Al-19 (part IV) Rif, and other governing procedures and conalinents. It conialned 1he requited data, docwients, and drawings Including ihe workplan specification with detalled written instructions, inspection requirements, and holdpoints. The conpleted package adequately defined the work requirenants and p contained suf flcient detall to ensure correct installation, inspections, and L docunentation. No special requirenwnts or postnudification tests were required.

Fleid work was still in process at tine of this evaluation.

17. Workplan 17152 (Reference 12) - Systems 0001nd ?$0--this workplan was written and ,

issued by Modifications to inglenunt DNt LCN L6749 which authorlied the replacement of all Bussmen type KAl circuit protective actuator devices presently used throughout the plan with Busviun MIS 5 type fuses, it was the only workpton needed r

to Inviteent this (CN. The package had been acceptably reviewed, evaluated, approved, and processed in accordance with $QN Al-19 (part IV) Alf, and other governing procedures and comnitnwnts. it contained the required data, documnts, and drawings including the workplan specification with detailed written instructions, inspection requirements, and holdpoints. The conpleted package adequately defined the work requirements and contained suf ficient detall to ensure correct installation, inspections, and documentation. All special requirements and postnixtlfication tests are adequately identified and defined. Fleid work was still in process at the line of this evaluation.

13. Mkplan 17?65 (Reference 13) - VP__$Yl--Thlt workplan was written and issued by Modifications to inplement DN( (CN L6197 which authorlied the Installation of two '

4 folnt environmentally quallfled terminal blocks to replace cable splices required by (CN (6??fs issued to replace an 0 point terminal block that had corroded. Two {

j 4 point terminal talocks had to be used as there wore no environmentally quallfled 8 point terminal blocks available in the Industry that were quallfled for 10CfR$0.49 application, it was the only workplan needed by Modifications to laplement this (CN. l lhe package had twen acceptably reviewed, evaluated, approved, and processed in aCcordJnce with $QN Al-19 (part IV) Ril, and other governing procedures and cuveni tnwnts, it contained the required data, documnts, and drawings including the l

1.$.1-5

(

i workplan specification with detailed written instructions, inspection requirements, and holdpointS. The conple1ed package adequateIy def1ned 1he work requiremenis and contained sufficient detall to ensure correct installation, inspections, and i documenta t iois. All special requirements and postadification tests were adequately identified and defined. Field work was congleted for this modification on 11-17-86, ihls workplan and drawings were "as-constructed" by the Modification Cognizant Engineer and are under the control of the ONE Drawing Control Unit.

14. Workplan I?)}? (Reference 14) - System llA-lhls workplan was written and issued by '

Modifications to implenent DNE [CN L6829 which authorlied the fire danpers in the Control Building HVAC be mechanically blocked open and their electrical cable  ;

terminations removed. it was the only workplan needed by Modifications to inplement ,

thisECN.

The package had been acceptably reviewed, evaluated, approved, and processed in l

accordance with SQN Al-19 (part IV) Rl7 and other governing procedures and I

commitments. It contained the required data, documents, and drawings including the j l I

workplan specification with detalled written instructions, inspection requirements, l and holdpoints. The cunpleted package adequately defined the work requirements and contained suf ficient detall to ensure correct Installation, inspections, and docunentation. No special requirements or post modification tests were required.

Field work had not started on this mdification at the fine of this evaluation.

i l$. (RADS 4 Aelf4-?R)0 and 47WRf4-il R?l (References l$ and 16) - System 30 -These two drawings are mechanical flow diagrams for part of the Auxillary Building HVAC revised and issued by DNE on [CN L6616. They were redlined "as-constructed" in the control roum drawing file by the Modifications engineer af ter ccepletion of the applicable field work on workplan 12011. They were reviewed for cunpleteness and accuracy of the Nrkings to reflect the "as-constructed" condition of the modification as described in the (CN and workplan packages. Drawings as u rked had not been reviewed and validated at the line of this evaluation.

16. (RAQs 47N6}0-10R2G. 41N6)014R$K. 45N10}-7Rll (References 17 through 19) - System D0,--These three drawings are electrical schematic and wiring diagrams for part of the various ventilation systes and 125V Vital Battery Board til revised and issued ,

f by DN( on (CNS 16749 and L5000. They were partially redlined "as constructed" In the control roun drawing file by the Modifications engineer af ter coupletion of the applicable field work on workplan 12157. They were reviewed for conpleteness and ,

accuracy of the mrking to reflect the "as-constructed" condition of the l c

m dification as described in the (CN and workplan packages. These drawings as nurked had not been reviewed and validated at the line of this evaluation.

17. CRA09 4$N706 4RI) and 4SN106-)Rl9 (References 20 and il) - AP Sy$--These two t

drawings are electrical wiring diagrams for 120V AC Vital Instrunent power Boards I-111, 2-111, I IV, and 2 IV revised and issued by DNf on (CN L5800, they were partially redlined "as-constructed" in the control roun drawing file by the i Modifications engineer af ter empletion of the applicable field work on workplan f

1 1

1 l . $ .14

12020. They were reviewed for coglehness and accuracy of the merkings to reflect the "as-constructed" condition of the modification as described in the ECN and workplan packages. These drawings as marked had not been reviewed and validated at the time of this evaluation.

7.5.7.2 Conclusions The Construction discipline of the EA team concluded that the engineering-approved and issued ECN packages and the Construction-approved and issued iglementing workplan packages were coglete and adequately defined the required change and were processed in accordance with governing procedures. There was an action item T-01 (see observation il) that the CRADs, as redlined by Modifications, had not been validated.

7.5.7.3 References

! Issue Reference Document Revision Date Title I [CN L5800 2 2-18-86 Engineering Change Notice ECN L%I6 0 4-7-86 Engineering Change 2

Notice (CN L6649 0 4-18-86 Engineering Change 5

Notice 4 ECN L6746 0 8 4-% Engineering Change Notice ECN L6749 0 1-21-86 Engineering Change 5

Notice 6 (CN L6797 0 9-22-86 Engineering Change Notice 1 ECN L6829 0 1-15-87 Engineering Change Notice WP 12020 0 8-25-86 Workplan 8

0 7-8-86 Workplan 9 WP 12071 1

10 WP 18969 0 7-11-86 Workplan ll WP 12225 0 ll-10-86 Workplan l

I 12 WP 12152 0 9-9-86 Workplan l

i 7.9.1-1 l

i 15 WP 12265 0 11-10-86 Workplan 14 WP 12552 0 2-20-87 Workplan 15 CRAD 4 M866-2 50 Mechanical Flow Diagra 16 CRAD 47W866-il 21 Mechanical Flow Diagra 17 CRAD 45N650-10 2G Electrical Schematic 18 CRAD 45N650-14 $K Electrical Schematic 19 CRAD 45N705-7 11 Electrical Wiring ,

l

! Diagra 20 CRAD 45N706-4 15 Electrical Wiring Diagra 21 CRAD 45N706-5 19 Electrial Wiring Diagra 22 SQEP-Al-ll 2 2-6-86 Handling of ECNs 25 SQEP-15 2 12-19-86 Transitional Design Change Control 24 SQN Al-19 (Part IV) 17 6-5-86 Plant l

Modifications:

l After Licensing 12-50-86 Plaqt 25 SQN Al-19 (Pari IV) 19 Modifications:

After Licensing 7.5.7-8

7.6 Desion Criteria A major DOSVP activity was the revision or issuance of design criteria documents necessary to establish the design basis for the systems within the 00&VP scope. In order to enhance

! the design criteria preparer's efforts to capture pertinent requirements, an orderly, top < lown process was conducted to identify all docisnented licensing consnitments and design This process requirements (C/Rs) and provide them to the af fected design criteria preparers.

consisted of the following steps:

l

a. Issuing procedures / conducting training (TVA, Impell, and Westinghouse).

l

b. Selecting C/R source documents (TVA and Westinghouse).

c. Subdividing source documents / distributing to responsible DNE/ Engineering and Technical Services (ESTS) branches (Inpell).

d. Identifying C/Rs/ preparing C/R data sheets (DNE/ EATS branches (impell for NEB) and l

Westinghouse].

e. Evaluating C/Rs for FSAR revision (box 5 on C/R data shee't) (DNE/E&TS branches).

f. Entering C/Rs in database / distributing analysis reports by topic [DNE/ Engineering and Conputer Methods Branch (ECB)).

g. Preparing design criteria (DNE/ESTS branches and Westinghouse).

Step a. was generic to the C/R and design criteria process whereas steps b. and f. were governed by SQEP-18, " Procedure for Identifying Consnitments and Requirements as Source Information for Sequoyah Design Criteria Development," and inpell Project instruction 0060-571-Pl-1, while step g. was governed by SQEP-29, " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant."

The EA Team reviewed the adequacy of the C/R data base process and the revised or issued design criteria doctsnents necessary to establish the design basis for the D64VP systems.

The results from Nuclear, Electrical, l&C, Mechanical, and Civil which reviewed the C/Rs and design criteria are presented in sections 7.6.1, 7.6.2, 7.6.5, 7.6.4, and 7.6.5, respectively.

l

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i I

7.6-l 1

1 4._ _ _ . - - _ . _ . ~ . . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ . . . , _ _ _ _ - _

7.6.1 Nuclear _

The Nuclear discipline of the EA Team reviewed the design criteria preparation activity to verify by examining sanples of project work products that each of the steps in the process outlined in section 7.6 was perforned in a technically adequate manner and in accordance with SQEP-18 (reference 1) and SQEP-29 (reference 2). The review attributes and sanple selection criteria are discussed in section 7.6.l.1 individually for each step in the process.

The EA Team had a significant nuntper of concerns related to the C/R and design criteria activity. The project responded to several of these with a comprehensive, coordinated C/A program (references 3 and 4). The specific areas of C/A outlined in reference 3 will be addressed as applicable to EA Nuclear's review and verification individually for each of the steps outlined in section 7.6.

7.6.l.1 Details

1. Issuino Procedures /Conductina Trainina--The project issued governing procedures for the C/R and DC activity and trained performing personnel. EA Nuclear concluded that the issuance of procedures was adequate with the following exceptions.

Early work in the C/R activity was not governed by a format, issued TVA procedure.

As a This progranmatic concern was directed to the project in action item N-07.

l result, the project issued SQEP-18 (reference 1) which included a " handbook" that ha1 previously served to provide informal guidance to TVA personnel performing C/R activities. In addition, the project stated that the inpell C/R activities had been governed by an inpell project instruction (reference 5) issued April 14, 1986. EA Nuclear concluded that the formal issuance of SQEP-l8 incorporating the previous informal guidelines and the existence of the inpell instruction adequately addressed our concern.

The NRC inspection team expressed a progrannetic concern that the Impell C/R work was not independently verified to ensure that they accounted for all potential C/Rs.

This concern was directed to the project in action item N-13. However, since the concerns expressed in action item E-14 enconpassed the NRC's concern, EA Nuclear judgedthatactionitemN-l)hadbeenissuedunnecessarily. The project addressed the concern in their response to action item E-14. See section 7.6.2 for discussion.

A mat >er of project work products randomly selected for evaluation by EA Nuclear in the C/R and desl0n criteria activity were reviewed for proper training of their preparers and checkers. Those work products included 15 TVA C/R source document subdivisions reviewed for C/R identification by DNE/E&iS branches (references 6 through 20), 6 Westinghouse C/R source documents reviewed for C/R identification by l Westinghouse (references 21 through 26),11 TVA C/R source documents reviewed for j

subdivision / distribution by Impell (references 27 through 57), and 5 C/R data sheets j

' prepared by Impell for NE8 (references }8 through 42). EA Nuclear concluded that training was adequate with the following exceptions.

l The EA Team expressed progranmatic concerns over inadequate training of DNE/E&ls personnel and lack of identification of performing Impell personnel on TVA source documents being subdivided and distributed. These concerns were directed to the project in action items E-Il and E-36. See section 7.6.2 for discussion.

7.6.1-1 L

2. Selectino C/R Source Documents--The mjor C/R source documents were identified by the project in Section V and Attachments I and 2 of SQEP-16. The identification of additional internal C/R sources was stated in SQEP-lB to be the responsibility of each DNE/E&TS Branch Chief. EA Nuclear reviewed the SQEP-10 list of nejor doctanents for completeness as part of our evaluation of a TVA C/R source document subdivision reviewed for C/R identification by a ONE/ESTS branch (reference 6). EA Nuclear concluded that the selection of C/R source documents was adequate with the following exceptions.

The NRC inspection team questioned whether the technical specifications (reference

43) were used as C/R source documents and, if not, whether potentially applicable C/Rs could have been overlooked. This progranmatic concern was directed to the project in action item N-8. The project responded that any changes to the technical specifications would have been included in the licensing correspondence provided to inpell as C/R source doctanents. Theprojectalsodescribedthereviewfor operational interfaces (including technical specifications) of draf t design criteria documents by the Operations SEs (references 44 and 45). In addition to these responses, the EA Team performed a topical review of all revisions to the U2 technical specifications since OL and discovered no instances where the technical specification revisions would have resulted in a change to the RD80. As a result, EA Nuclearjudgedthatthetechnicalspecificationsdidnotneedtobeexplicitly identified as C/R source documents.

SQEP-IB instructed the DNE/E&TS Branch Chiefs to identify C/R source documents for review such as internal contract files and design files in addition to those C/R f source documents provided to Impell. Contrary to this requirement, NEB failed to review any of these additional, internal sources for C/Rs. The technical concern was that potentially applicable C/Rs could have been overlooked. This concern was directed to the project ir. action item N-l8. In response, NEB performed an internal review as described in reference 46. NEB's C/A corresponds to item 8 described in i reference 3. This review did not identify any additional C/Rs. EA Nuclear verified NEB's review by randanly sanpling several internal NEB notebooks and determining that they did not contain any additional C/Rs.

EA Nuclear's review of proprietary Westinghouse C/R source documents revealed that neither system descriptions nor "E-specs" had been explicitly identified as C/R source doctsnents even though they were referenced in design criteria documents.

Although EA Nuclear judged that the nejor features of the reviewed systems appeared to be included in the design criteria documents, the technical concern was that potentially applicable C/Rs could have been overlooked. This concern was dirdcted to the project in action item N-26. The project responded that the documents in question were upper-tier doctsnents composed of requirements collected from other sources which were identified as C/R source doctsnents. The project also conmitted to have Westinghouse review their "WCAPs" (which include system descriptions) and "E-specs" during phase ll to confirm that all applicable C/Rs have been identified.

EA Nuclear judged that this explanation and proposed C/A were adequate to address our concern.

7.6.1-2

}. SubdividingandDistributinaC/RSourceDocuments--TheprojectprovidedthenujorC/R source documents identified in SQEP-18 to tropell. As directed in reference 5, l@ ell subdivided them as necessary into manageable " single-topic" portions and distributed those with potential design C/Rs to the responsible DNE/E&TS branches for further processing. Impell categorized those documents with potential operating C/Rs as "NUC PR" and those with no potential C/Rs as "N/A." Neither of these latter two categorieswereprocessedfurtherbytheproject.

EA Nuclear reviewed a random sangle of five documents categorized by Impell as "N/A" (references 27 through 31) and a random sanple of six documents categorized as "NUC PR" (references 32 through 37) to determine if they contained any potential design C/Rs. All of the documents except two (references 36 and 57) were judged by EA Nuclear to have been properly categorized.

Reference 56 described a Westinghouse nuin steam line break analysis and specified a nist>er of design C/RS which were judged by EA Nuclear to probably be contained in FSAR Section 6.2 which was assigned to NEB by Impell. Reference 37 responded to a deficiency report by comnitting to store the nonseismic spent fuel pool cask loading l

area gate in a safe position rather than to redesign the gate to seismic standards.

l Both of these documents were categorized as "NUC PR" even though they contained l

potential design C/Rs. This technical concern was expressed in action item N-25.

The project responded that any potential C/Rs in reference 36 were included in an FSAR section assigned to NEB and that reference 37 was a duplicate of one that had been assigned to CEB. EA Nuclear verified these responses. Both of our concerns wereadequatelyaddressedbytheproject.

However, in response to this and other similar EA Team concerns, the project comnitted to review all of the documents categorized as "N/A" by impell as required I in item 2 of reference 5. As reported in reference 47, the re-review identified nine -

I new C/Rs, only one of which merited incorporation in a design criteria document during phase 1. Based on the relatively small nunt>er of new C/Rs identified and even smaller ntst>er of new C/Rs identified with design criteria inpact during phase 1, EA Nuclear concluded that the inpell categorization of documents as "NUC PR" and "N/A" was adequate.

EA Nuclear randomly selected five doctsnents (references 48 through 52) assigned to NEB by inpell on conmitment document assignment (CDA) sheets (described in reference

5) end reviewed them to determine if the DNE/ESTS branch assignment was appropriate.

' lear concluded that this aspect of the Impell distribution process was adequate.

EA Nuclear concluded that the overall Impell process of subdividing and distributing potential C/R source doctsnents was adequate.

4. Identifyino C/Rs/preparino C/R Data Sheets--Upon receipt of the CDA sheets and associated documents fran inpell, each DNE/ESTS branch was directed by SQtP-18 (reference 1) to identify single-topic C/Rs and prepare a data sheet (included in 5(tP-10) for each one. Inpell performed this activity for NEB.

7.6.l-3

A nunter of project work products randomly selected for evaluation by EA Nuclear in the C/R and design criteria activity were reviewed for proper identification and l documentation of C/Rs on data sheets. Those work products included 15 TVA C/R source document subdivisions reviewed for C/R identification by DNE/ESTS branches (references 6 through 20), 6 Westinghouse C/R source documents reviewed for C/R identification by Westinghouse (references 21 through 26), and 5 C/R data sheets prepared by inpell for NEB (references 38 through 42). EA Nuclear concluded that both the identification of C/Rs and their documentation on C/R data sheets were adequate.

5. Evaluatino C/Rs for FSAR Revision--SQEP-18 (reference 1) required the DNE/ESTS Branch Chiefs to identify any C/Rs that required FSAR revision and to initiate the change.

Box 5 on the C/R data sheet (described in SQEP-IB) was used for this purpose.

Based on discussions with project personnel, it appeared to EA Nuc! ear that this change evaluation process might have been misused leading to applicable C/Rs being omitted from DC documents. Thistechnicalconcernwasdirectedtotheprojectin action item N-22. The project responded with a comnitment in item I of reference 3 that each DNE/E&TS branch would review all C/Rs marked for change to ensure that necessary FSAR revisions were nede. NEB's performnce of this C/A was reported in references 5) and 54. NEB determined that most of the C/Rs marked for change could be deleted from the C/R data base, that some should be retained, that a few required FSAR revisions, but that none required incorporation into restart design criteria documents. EA Nuclear independently verified NEB's review by randomly sampling some of the deleted C/Rs (references 55 through 66), some of the retained C/Rs (references l

! 67 through 69), and all of the C/Rs determined to require FSAR revision (references j

70 through 81) to determine if we concurred with NEB's disposition.

EANuclearjudgedthatNEB'sreviewadequatelyaddressedourconcern. EA Nuclear concluded that, with the performance of this C/A, NEB adequately evaluated all C/Rs marked for FSAR revision.

6. Enterino C/Rs into Data Base /Distributino Analysis Reports by Topic--Upon receipt of the C/R data sheets from the DNE/E&TS branches, ECB entered them into a data base and provided various analysis reports (sorts by topic) as required by SQEP-18.

A nunter of project work products randomly selected for evaluation by EA Nuclear in the C/R and design criteria activity were reviewed to determine if C/Rs had been included in the data base and in applicable analysis reports. Those work products included 15 TVA C/R scurce document subdivisions reviewed for C/R identification by DNE/ESTS branches (references 6 through 20) and six Westinghouse C/R source documents reviewed for C/R identification by Westinghouse (references 21 through 26). EA Nuclear concluded that the entry of C/Rs into the data base and the distribution of analysis reports were adequate with the following exception.

The initial approved analysis report was only issued to Lead Engineers and not SEs as well as required by SQEP-18. This EA Team programmtic concern was directed to the projectinactionitemE-19. See section 7.6.2 for discussion.

7.6.1-4

7. Preparina Desian Criteria Documents--SQEP-29 (reference 2) guverned It the preparation and issuance of design criteria docunents by the DNE/ESTS Branch Chiefs.

instructed the preparers to revise existing design criteria documents or write new ones as required to capture the applicable C/Rs and any additional required information. The preparer was to record on a C/R data base tracking The sheet (SQEP-29, design Attachment 2) the nunber of any C/R addressed in the design criteria.

criteria documents were to be prepared in accordance with NEP-3.2, Design input (reference 82), and checked using the SQEP-29, Attachment 4 checklist as a guideline.

EA Nuclear randomly selected five C/Rs (references 83 through 87) from those appearing on the UHI System Analysis Report but not appearing on the C/R data base tracking sheet for SQN-DC-V-27.7 (reference 88), and reviewed them toEAdetermine whether they should have been incorporated in the design criteria document.

Nuclear also reviewed all 23 of the C/Rs (references 89 through lit) app,aring on the Canbustible Gas Control System (CGCS) analysis report but not appearing on the C/R data base tracking sheet for SQN-DC-V-26.1 (reference 112); reviewed all four of the C/Rs (references 115 through 116) appearing on the auxiliary control subject analysis report but not appearing on the C/R data base tracking sheet for SQN-DC-V-2.17, (reference 117); and reviewed all four of the C/Rs (references 118 through 121) appearing on the CSS analysis report but not appearing on the C/R data base track sheet for SQN-DC-V-27.5 (reference 122). Based on our review of references through 122. EA Nuclear concluded that all of the applicable C/Rs in the system and subject sorts were included on the C/R data base tracking sheets for the respective design criteria documents.

In addition, several C/Rs that did not, in EA Nuclear's opinion, represent applicable Most.of these conmitments were also included on the SQN-DC-V-26.1 tracking sheet.

C/Rs were segregated into a " background" section of the design criteria document while the more applicable C/Rs had been categorized as " design input."

it should be noted that several EA Nuclear and NRC inspection team concerns with the conplete incorporation of applicable C/Rs into various design criteria documents l

developed during the course of other reviews of DB&VP design criteria

! docunent-related activities will be discussed later in this section.

EA Nuclear randomly selected five C/Rs (references 125 through 127) from those appearing on the C/R data base tracking sheet for SQN-DC-V-27.7 (reference 88) and reviewed them to determine whether they were actually incorporated into the text of the design criteria document. In additioc, EA Nuclear reviewed 14 of the 15 " design input" C/Rs (references 128 through 141) and four of the nine " background" C/Rs (references 142 through 145) appearing on the SQN-DC-V-26.1 C/R data base tracking sheet, all 12 of the C/Rs (references 146 through 157) appearing on the SQN-DC-V-2.

C/R data base tracking sheet, and five "NE8" and four proprietary Westinghouse C/Rs (references 158 through 166) randomly selected from the SQN-DC-V-27.5 C/R data base tracking sheet to determine whether they were actually incorporated into the text of the respective design criteria documents. EA Nuclear concluded that all of the C/Rs on the C/R data base tracking sheets were actually incorporated into the text of the respective design criteria documents with the following exceptions.

7.6.l-5

None of the five C/Rs (references 123 through 127) sampled from the SQN-DC-V-27.7 C/R data base tracking sheet were completely and correctly contained in the text of the design criteria document. This technical concern was directed to the project in action item N-27. In response, the project conmitted to revise SQN-DC-V-27.7 during phase ll to incorporate three of the C/Rs (references 124 through 126) and stated that the remaining two C/Rs (references 123 and 127), which had conflicted with the text of SQN-DC-V-27.7, were incorrect and would be deleted from the data base during phase 11. EA Nuclear concurred that with these design criteria document revisions and data base deletions during phase 11, our concerns will be adequately addressed.

One of the 14 reviewed " design input" C/Rs (reference 131) and all of the four reviewed " background" C/Rs (references 142 through 145) from the SQN-DC-V-26.1 C/R l

data base tracking sheet were missing from the text of the design criteria document.

However, it was EA Nuclear's opinion that none of these C/Rs needed to be incorporated into the design criteria document text and that they could have been omittM from the tracking sheet. These technical concerns were directed to the project in action ite N-17. Inresponse,theprojectrevisedSQN-DC-V-26.1to incorporate reference 131 and explained that " background

• references (including C/Rs) l may be listed in a design criteria document for infora tion only without needing to be incorporated into the document since this meets the intent of NEP-3.2 (reference 82). EA Nuclear verified that SQN-DC-V-26.1 RI was issued containing reference 131 and concurred with the DB&VP explanation of " background" references.

Two of the 12 C/Rs (references 149 and 152) listed on the SQN-DC-V-2,17 C/R data base l

l tracking sheet were not explicitly included in the text of the design criteria document. Reference 149 was an FSAR statement that the operator is responsible for transfer of control to the auxiliary control room. No mention was made in the design criteria document of manual transfer of control. Reference 152 was an FSAR statement that the CSS will be actuated either nenually from the control room or auxiliary control room. The note following section 4.4 of the design criteria stated that other systems ney be added to the remote shutdown panels, such as Containment Spray.

These technical concerns were directed to the project in action item N-23. In response to the first of these concerns, the project stated that the transfer requirements were not design requirmnents and were addressed in operating instructions. EA Nuclear concurred with this explanation. In response to the second concern,theprojectexplainedthatthecontrolofsystemsrequiredtomitigateFSAR Chapter 15 events (such as Containnent Spray) was not required in the Auxiliary Control Room (ACR), but was included at the designer's option. EA Nuclear concurred with this explanation.

Only one of the nine C/Rs (references 158 through 166) san 1 pled from the SQN-DC-V-27.5 C/R data base tracking sheet was completely and correctly contained in the text of the DC document. However, EA Nuclear judged that 5 of the unincorporated C/Rs (references 158, 160, 164, 165, and 166) were extraneous or duplicated by other l C/Rs. Another C/R (reference 163) appeared to contain a value for CSS heat exchanger duty that conflicted with the text of the design criteria document. Two C/Rs (references 161 and 162) contained references to several RGs and GDC which were not included in the design criteria doctanent. These technical concerns were directed to the project in action item N-28. In response the project conmitted to delete reference 158 from the tracking sheet during phase 11 and stated that Westinghouse 7.6.1-6

would delete references 164 through 166 from the tracking sheet as necessary during EA phase 11. The project also stated that reference 160 was an applicable C/R.

Nuclear. concurred with these responses. TheprojectstatedthattheCSSheat EA-exchanger duty was correct as provided in the design criteria document text.

Nuclear judged that the discrepancy between the text and reference 16) was not significant enough to require deletion of the C/R. The project stated that reference 161 would be deleted from the C/R data base during phase 11. Regarding reference 162, the project stated that applicable GDCs were invoked by reference in SQN-DC-V-27.5 to the 10CFR50, Appendix A, 1970 draft, that RG l.26 was invoked by reference in SQN-DC-V-27.5 to SQN-DC-V-3.0, and that RG l.82 was not a TVA conniiment for SQN. EA Nuclear concurred with these responses. With the performance of these C/A during phase 11 EA Nuclear judged that our concerns will be adequately addressed.

The NRC inspection team stated that an essential C/R (nunter unknown) was not included in SQN-DC-V-26.1 (reference 112). The C/R stated that enlarged spray shields would be installed over some of the igniter assemblies in the Hydrogen Mitigation Systan (HMS). It was pointed out to the NRC inspection team by the project, and EA Nuclear agreed, that this C/R did not af fect the boundaries of the CGCS required for restart. This technical concern was directed to the project in action item N-22. In response, the project comnitted to revise SQN-DC-V-26.1 to l

l include _the C/R. EA Nuclear verified that SQN-DC-V-26.1 RI contained the

' requirements of the C/R.

In the course of reviewing several system design crieria documents, EA Nuclear noted that they did not appear to include all of the requirements associated with nuterials contained, for example, in FSAR Section 5.2.5. This concern was directed to the In a follow-up to this concern, EA Nuclear l

project in technical action item N-24.

requested an explanation of how " materials" C/Rs were being applied to the ECN f In response to this latter request, the l

evaluation checklist (see section 7.5.1).

l project referenced a Septenter 26, 1986 memo from J. A. Raulston (reference 167) that was used to provide guidance in the proper consideration of materials requirements when conpleting ECN checklists. EA Nuclear judged that this memo would provide adequate guidance. In response to the original concern in action item N-24, NE8 reviewed (reference 168) all of the " materials" C/Rs that had not already been l

incorporated into design criteria documents, identified seven for further review, and l'

' finally determined that only one additional C/R (reference 169) needed to be added to a design criteria document. EA Nuclear independently verified the results of the NEB review by randomly sampling C/Rs from the C/R " materials" analysis report to determine whether they were included in design criteria documents (if so indicated on l In addition, I the report) or whether they should be included (if not so indicated).

EA Nuclear evaluated each of the seven C/Rs identified for further review by the projectandverifiedthatonlyreference169neededtobeaddedtoadesigncriteria document and that it may be added during phase 11. Basedontheproject'sreviewof all " materials" C/Rs, the guidance provided in reference 167, and our verification of the review, EA Nuclear concluded that naterials requirements were adequately addressed in system design criteria documents.

7.6.l-7

As noted in section 7.5.1.1, during EA Nuclear's review of ECN 6258, a superseded C/R was found to have been incorporated into SQN-DC-V-27.2, " Chemical and Volume Control System" (reference 170). The superseded C/R (reference 171) stated that two miniflow control valves (FSV-2-90 and 99), associated with the centrifugal charging ptsgs, would be nanipulated postaccident. However, a later C/R (reference 172) stated that these valves only needed to remain open postaccident. The discrepancy was gernene to the evaluation of ECN L6258 because it was vo remove motive power from these valves to satisfy Appendix R requirements. These technical concerns were directed to the project in action item N-39. Inresponse,theprojectdeletedreference171from SQN-DC-V-27.2 and the C/R data base and incorporated reference 171 in SQN-DC-V-27.2.

EA Nuclear verified that SQN-DC-V-27.2 RI was issued with appropriate revisions.

The NRC inspection team noted that although two C/Rs (references 175 and 174) stated that the RHR System isolation valve high pressure interlocks would be diverse as well as redundant, SQN-DC-V-27.6, "RHR System" (reference 175), only included the redundancy requirement. This technical concern was directed to the project in action item N-43. In response, the project revised the design criteria document to include the diversity requirement. EA Nuclear verified that SQN-DC-V-27.6 RI was issued and included the missing requirement.

In response to the concerns presented in action item M-07, the project conmitted to review C/Rs not previously reviewed in accordance with SQEP-29 to determine if they should be incorporated into design criteria documents. This review was required by item 4 of reference 5. In support of this effort, NEB reviewed 12 new C/Rs supplied by the project and concluded that none of them required incorporation into any NEB design criteria documents as stated in reference 176. EA Nuclear independently verified the NEB review and concurred that no design criteria document revisions were necessary. Also in support of this effort, Westinghouse reviewed a number of new C/RssuppliedbytheprojectandconcludedthatsevenC/Rsneededtobeincorporated into particular Westinghouse system design criteria doctanents as stated in reference 177. EA Nuclear independently verified a sample of those new C/Rs determined by Westinghouse not to require incorporation into design criteria documents and concurred that none of them would require design criteria document revisions, in addition, EA Nuclear reviewed final draft versions of the revised system DC documents and verified that six of the seven new C/Rs had been satisfactorily incorporated.

The DB&VP verbally conmitted to incorporate the other C/R and issue all of these design criteria documents during phase 1. Thus, EA Nuclear verified that both NEB and Westinghouse have properly reviewed the new C/Rs supplied to them and incorporated the applicable ones into the appropriate design criteria documents.

However, among the concerns presented in action item M-07, the EA Team also addressed the lack of a DB&VP procedure establishing a long-term mechanism to ensure that new C/Rs will be identified and incorporated into design criteria documents as necessary. This issue is discussed with action item M-07 in section 7.6.4.

Based on our reviews and the corresponding prcject C/A, EA Nuclear concluded that, in general, applicable C/Rs had been adequately incorporated into design criteria doctsnents.

7.6.1-8

in addition to the previously described reviews and concerns strictly related to the proper incorp) ration of applicable C/Rs into design criteria documents, EA Nuclear reviewed three design criteria documents in detail for more general attributes such as whether ite following were included:

e codes, standards, and regulatory requirements; e performanco criteria, design parameters, environmental conditions, naterial and chemical requirements, and quality group classifications; e interface requirements; e justificationofdeviations; l' e definition of design basis events; e separation, redundancy, cnd diversity requirements; and e test and inspection requirenents.

The three design criteria documents reviewed in detail were SQN-DC-V-26.1 (reference 112), SQN-DC-V-2.17.(reference 117), and SQN-0C-V-27.5 (reference 122). They were selected to represent design criteria documents prepared by the project nuclear in addition to discipline in the central staf f, at SQN site, and at Westinghouse, these detailed reviews, EA Nuclear and the NRC inspection team performed a limited review of other design criteria doctsnents including SQN-0C-V-27.2 (reference 170),

SQN-DC-V-2.15 (reference 178), SQN-0C-V-27.8 (reference 179), and SQN-0C-V-27.4 (reference 180). Based on this contination of detaifed and limited reviews, EA Nuclear concluded that, in general, the preparation of design criteria documents was adequate with the following exceptions.

EA Nuclear noted that the statement in SQN-DC-V-26.1 that the HMS performed neither a primary nor a secondary safety function appeared to conflict with its Seismic Category l(L) requirements explicitly stated elsewhere _in the design criteria document. In addition, EA Nuclear noted tMt the design criteria document failed to These technical specify isolators between the Class IE power supply and the HMS.

concerns were directed to the project in action item N-17. Theprojectrespondedby

-1 revising the design criteria doctrnent accordingly. EA Nuclear verified that SQN-DC-V-26.1 was issued containing the appropriate revisions.

The NRC inspection team stated that the requirements for EQ in several system design criteria documents (e.g., SQN-0C-V-26.1 (reference l12)] were unclear or inconsistent. Although EA Nuclear did not agree that the example design criteria documentwasunclear,theNRCtechnicalconcernwasdirectedtotheprojectinaction item N-21. In response, the project revised SQN-DC-V-26.1 accordingly. EA Nuclear verified that SQN-0C-V-26.1 RI was issued containing appropriate clarification.

7.6.l-9

EA Nuclear noted the following technical concerns about SQN-DC-V-2.17 (reference 117): it should have provided EQ requirements for the ACR equipment itself, its single-failure requirement was too restrictive, and it contained conditional statements that did not fully convey criteria to the designer. These technical concerns were directed to the project in action item N-25. Theprojectrespondedby stating that the EQ requirements for the ACR equipnent are provided for each conponent in its associated system design criteria document, that the restrictive single-failure requirement was inposed at TVA's discretion, and that the particular conditional statements were necessary to convey requirements that vary with design basis event. EA huclear concurred that these explanations adequately addressed our concerns.

EA Nuclear noted a few minor errors and reference omissions in SQN-DC-V-27.5 (reference 122). Thistechnicalconcernwasdirectedtotheprojectinactionitem N-28. The project responded by to revising the design criteria document accordingly. EA Nuclear verified that SQN-DC-V-27.5 RI was issued containing appropriate changes.

EA Nuclear expressed the technical concern that motive power had been removed from several conponents by ECN L6258 to disable them to meet Appendix R requirements while no such mention was nede in the corresponding system design criteria documents (e.g.,,miniflow control valves around the CVCS centrifugal charging pumps -

SQN-DC-V-27.2 (reference 170)]. This technical concern was directed to the projectinactionitemN-59. Theprojectrespondedbyrevisingaffecteddesign criteria documents to list those disabled components. EA Nuclear verified that DIM-SQN-DC-V-7.4-2, "ERCW System," and DIM-SQN-DC-V-15.9.9-5, "CCS," were issued and contained those lists. Ourconcernwasadequatelyaddressedbytheproject.

The NRC-Nuclear Reactor Regulation (NRR) insgection team stated that the containment isolation provisions for SQN should meet GDC 54-57 (reference 181) and that SQN-DC-V-2 I5 (reference 178) did not adequately state these requirements. This technical concern was directed to the project in action item N-19. Theproject responded by stating that the design criteria document contained TVA's current position on this ongoing issue which was being addressed with the NRC-NRR through normal TVA licensing channels outside the DB&VP. EA Nuclear verified that this issue was being addressed outside the DB&VP (reference 182) and did not require further FA verification.

The NRC inspection team stated that SQN-DC-V-27.8 (reference 179) did not require that indication of the source range flux be provided outside the MCR nor that special electrical penetrations must conform to IEEE-517. EA Nuclear discovered that those requirements were expressed in C/Rs that were incorporated into SQN-DC-V-2.17 and SQN-DC-V-2.15 respectively. NRC's technical concern was directed to the project in getionitemN-20withareconmendationbyEANuclearthattheprojectshouldrevise

,QN-DC-V-27.8 to include these requirements directly or by reference, in response, the project conmitled to revise the design criteria document to do so during phase

11. EA Nuclear concurred that phase 11 implementation acceptably addressed the concern since the requirements were included in the controlling design criteria documents.

7.6.1-10

l The project addressed the issue of adequate referencing within design criteria l

documents of related design criteria docunents presented in action item N-20 and similarly in action item C-28 by issuing PIRSQNCEB8672 (reference 183) and routing it to each discipline for their response via a generic condition evaluation memo NEB responded (reference 184). This C/A was outlined in item 7 of reference 5. (

(reference 185) by conmitting that the NE8 system design criteria documents would be l

reviewed during the revision cycle then in progress, to ensure that references to other design criteria documents were adequate. This effort was not completed during the EA review and requires EA Nuclear verification (observation N3).

EA Nuclear noted that SQN-DC-V-27.4 (reference 180) stated that a reactor is not designed for critical operation with less than two-loop operation and will not be ,

operated with these conditions although this appeared to conflict with the statement l

in SQN Technical Specification Limiting Condition for Operation 3.4.1.1 (reference l

43) that all reactor coolant loops shall be in operation for startup and power operation. This technical concern was directed to the project in action item N-29.

In response, the DB&VP ccmnitted to revise the design criteria document during phase EA il to state that the technical specifications currently require 4-loop operation.

Nuclear concurred that this proposed C/A and its implementation in phase il .

)

adequately addressed our concern.

7.6.l.2 Conclusions The Nuclear discipline of the EA Team reviewed all steps of the process used by the Our conclusions are discussed below by projecttoproducedesigncriteriadocuments.

activity.

Following the perforance of project C/A which consisted of the incorporation into a procedure of requiremnts that were previously provided as informi guidance, EA Nuclear concluded that the procedures and training for the C/R and design criteria activity were adequate.

Following the performnce of project C/A which consisted of a review of NEB internal files for C/Rs (in which no new C/Rs were identified), EA Nuclear concluded that the selection of C/R source docunents by the project was adequate.

Following the performnce of project C/A which consisted of a review of a group of l

l potential C/Rs that had been eliminated by Impell (in which only a few new C/Rs were identified), EA Nuclear concluded that the subdivision and distribution of C/R source docunents by impell were adequate.

EA Nuclear concluded that the identification of C/Rs and the preparation of C/R data '

sheets by TVA, Inpell, and Westinghouse were adequate.

following the performnce of project C/A which consisted of a review of C/Rs for FSAR revisions (from which several FSAR revisions were initiated), EA Nuclear concluded that the evaluation of C/Rs for FSAR revision was adequate.

EA Nuclear concluded that the entry of C/Rs into the data base and the distribution of analysis reports were adequate.

7.6.l-11 i

Following the performmce of project C/A which consisted of making a nunt)er of mostly minor design criteria document and C/R data base revisions or conmitting to do so during phase ll, EA Nuclear concluded that the preparation of design criteria documents was adequate with the following exception. Adequate referencing within NEB's design criteria documents of related design criteria docunents (item 7 of reference 5) requires EA Nuclear verification (observation N)).

In sunmary, with the exception of this observation which requires EA verification and determination of adequate inplementation of C/A, EA Nuclear concluded that the overall D8&VP process of identifying C/Rs and issuing design criteria documents was adequate.

This conclusion is based on the results of our reviews of each step in the process and our verification of successful inplementation of extensive project C/A.

7.6.l.) References issue Reference Document _ Revision Date Title 0 6/14/86 Procedure for Identifying Conmitments and i SQEP-18 Requirements as Source Information for SQN I 7/9/66 Design Criteria Development 0 6/21/86 Procedure for Preparing the Design Basis 2 SQEP-29 '

I 7/18/86 Document for SQN

) B25 060911 012 - 9/11/% TVA memo from Cox to SQEP Files 4 825 861203 019 -

12/3/06 TVA memo from Cox to SQEP Files 5 0060-571-PI-I O 4/14/26 inpell's Project instruction for Design Criteria identification and Documentation 6 - - - - - ---- SQN FSAR 10.4.7.2.1 7 --- - --- SQN FSAR 10.4.7.2.2 8 --- - - - -

SQN FSAR 10.4.7.2.3 9 - - - - -

SQN FSAR 10.4.7.2.4 10 -- ---

SQN FSAR 10.4.7.2.5 ll --- - ---- SQN FSAR 7.4.1.3.2 12 - .--- - --- SQN FSAR 3.2.2.2; 3.2.2.5 A27 820}01 032 -

5/1/82 TVA Final Report to NRC on Generic Letter 81-14 15 14 - - - - -

3/79 NRC Safety Evaluation Report A27 800512 018 - 5/12/80 Final 50.55(e) Repori on NCRSQNNEB8009 15 7.6.1-12

Issue Reference Document _ Revision Date Title 16 NCR SQNEf88021 - 10/6/80 CAQ 17 NCR ME879-41A -

5/27/80 CAQ 18 NCRSQIMEB8405

- 6/1/84 CAQ 5/79 TVA Nuclear Program Review (" Blue Book")

l 19 20 NCRSQNEEB0021

-- 10/6/80 CAQ ,

l 21 FSO/SS-IVA-482 - 2/17/85 Calculation 22 FSD/SS-TVA-560 -

6/5/82 Calculation 25 FSO/SS-UHl-3'2 -

5/26/d2 Calculation ,

24 FSD/SS-TVA-186 - l/8/81 Calculation 25 N4SA-N-97 - 8/1/77 Calculation 26 PDC-FSA-TVA-3251 - 12/l/76 Calculation 27 A27 850509 015 - 5/9/85 TVA letter from Kamer to Adensam (NRC) 28 A27 850511 015 - 5/11/85 TVA letter from Mills to 0'Reilly (NRC) 29 A27 850427 016 - 4/27/85 TVA letter from Mills to O'Reilly (NRC) 30 NEB 850512 617 - 5/10/85 TVA letter from Mills to O'Reilly (NRC) f 31 A27 850509 017 - 5/9/85 TVA letter from Kanmer to Adensam (NPC) 32 - - - - - - - 5/10/78 TVA letter from Gilleland to O'Reilly (NRC) f 55 - - - - - - 10/15/72 TVA letter from Gilleland to Davis (NRC) 34 A27 810925 028 - 9/25/81 TVA letter fram ilills to O'Reilly (NRC) 35 A27 810814 020 - 8/l4/81 TVA letter from Mills to Denton (NRC)

- - - - - - - - - 11/14/78 TVA letter from Gilleland to Varga (NRC) l 36 l

l A27 800702 001 - 7/2/80 TVA letter from Mills to O'Reilly (NRC) 57 58 SQN NEBFAKil66

- C/R 59 SQN NE8FAKil67 . - - - - - - C/R 40 SQN NEBFAKil68

- - - - - - - C/R 41 SQN NEBFAKil69

- - - - - C/R 7.6.1-I5

lssue.

' Reference Document devision Date Title 42 SQN NEBFAKil)0 - - - - - - - C/R 45 - - - - - - - - - - 36 7/28/86 SQN Technical Specificalions 44 B23 860623 201 -

6/23/06 TVA memo from Cox to Those listed 45 B25 860630 101 -

6/30/86 TVA memo from Wilson to Abercront>ie 46 B45 861002 252 - 10/2/86 TVA memo from Raulston to Cox 47 B25 861022 100 -

10/22/86 TVA menn from Gilbert to files 48 --- - - ---- NEB CDA sheet containing SQN FSAR 9.1 49 -- - - -- - -- NFB CDA sheet containing SQN FSAR ll.1 50 - - - - -- -------- NEB CDA sheet containing SQN FSAR 12.1.1 51 -- - - - - NEB CDA sheet containing SQN FSAR 15.0 52 - --- - NEB CDA sheet containing SQN FSAR 9.5.10 55 B45 861011 251 -

10/17/86 TVA memo from Weir to Cox l

! 54 B45 861208 266 - 12/8/86 TVA memo from Weir to Cox l

l 55 B45 860509 021 --

---

C/R 56 B45 860515 %2 -

---

C/R 57 B45 860517 017 - - - - - - C/R -

58 B45 860508 054 -

C/R i

! 59 B45 860515 719 - ---- C/R i

! 60 845 060516 069 C/R 61 B45 060516 906 --- C/R 62 845 860516 153 ----- C/R 63 B45 860509 015 - -

C/R 64 845 860515 786 ----- C/R 65 B45 860516 977 - - - - - - C/R i

66 845 860507 Oli ----- C/R 7.6.1-14

issue Reference Document _ Revision Date__ Title 67 B45 860515 054 - ----- C/R 68 845 860516 065 - - - - - C/R 69 845 860516 192 - ----- C/R 70 B45 860515 698 - ---- C/R 71 B45 860512 000 - --- C/R 72 845 860514 017 - - - - C/R 15 845 8605I4 057 - --- C/R 74 B45 860516 025 - --- C/R 75 845 860516 026 - --- C/R i

76 B45 850516 027 - ----- C/R 71 B45 860516 028 ----- C/R 78 B45 860516 029 - ----- C/R

.79 B45 860516 050 - = C/R 80 B45 860516 031 - ----- C/R 81 B45 860516 052 - - C/R j

82 NEP-3.2 0 7/1/86 Design input I

83 SQNWESitil094

- - C/R 84 SQWESft(1090

- - C/R 85 SQNWESRJFil06

- - C/R l

86 SQNWESWil55

- - C/R 87 SQNWESRJFl209

- - C/R 88 SQN-0C V-27.7 0 7/23/06 Upper Head injection Systern 89 SQNEERMJSl002

- C/R 90 SQNEEBPBNil20

- - C/R 91 SQNNEBOLH1005

- C/R l

7.6.1-15

issue Reference Document Revision Date Title 92 SQNNEBOLH1023

- - C/R 93 SQNNEBOLH1029

- - C/R 94 SQNNEB0tHl035

- - C/R 95 SQNNEBOLHl078

- - C/R

% SQNNEBOLH3tl4

- - C/R 91 $QNNEB0tH3219

- - C/R 90 SQNNEBFAKl095

- - C/R 99 SQNNERFAK1218

- - C/R 100 SQNNEBFAK1280

- - C/R 101 SQNNEBFAKl292

- - C/R 102 SQNNEBFAK3015

- - C/R 105 SQNNEBFAK5058

- - C/R 104 SQNNEBFAK5146

- - C/R 105 SQNNERFAK)l50

- - C/R 106 SQNNEBHEMil05

- - C/R 107 SQNNEBlHC3029

- - C/R 100 SQNNEBRSM3129

- - C/R 109 SQNWESBJ81055

- - C/R 110 SQNWESPPfl006

- - C/R lli SQWESRJFl423

- - C/R 112 SQN-DC-V-26.1 0 07/11/86 Cont >ustible Gas Control System 115 SQlMEBJLF1209

- - C/R 114 SQeMEBJLFl275 - - C/R 115 SQNNERHtM1030

- - C/R l16 SQNWESRJFil68 - - C/R 1.6.1-16

lssue Reference Document Revision D_ ate Title l17 SQN -DC -V -2.17 0 7/l4/06 Remote Shutdown Criteria from tocations Outside the Main Control Room 118 SQNEEBP8NI224

- - C/R (19 ' SQIMEBRTWl015

- - C/R 120 SQNNERFAKl201

- - C/R 121 SQNNE8FAKl222

- - C/R 122 SQN-DC-V-27.5

- 7/30/06 Containment Spray System 125 SQlWESRJFl200

- - C/R 124 SQlWESRJF1071

- - C/R l

125 SQfMESRJFl072

- - C/R 126

- - C/R SQlWESRJFl075 127 SQlWESRJFl379

- - C/R 128 SQNEEBP9 Nil 59

- - C/R 129 SQNNEBDLHl009

- - C/R 130 SQNNEBFAKl060

- - C/R 131 SQfMESPPfl026

- - C/R f - - C/R 132 SQNNEBOLH1035 l

C/R l)) SQNNEB0lHl034 154 SQNNEBOLH10ll

- - C/R SQNNEBOLHl059

- - C/R 135

- - C/R 136 SQNNEBHEM1026 157 SQNNEBFAK5125

- - C/R l

l C/R l l)8 SQNNEBF AKil%

SQNNEBFAKil)7

- - C/R 139 j

I - - C/R

' 140 SQNNEBFAKl221 r

7.6.l-17

issue Document _ Revision Date_

Title Reference

- - C/R 141 SQNNEBFAKl2))

- - C/R 142 SQNNEBFAK3095

-- - C/R

14) SQNNEBHEMIDI)

- - C/R 144 SQNNEBHEMl06)

- - C/R 145 SQNWESJTCl012

- - C/R 146 SQNEEAMJS1067

- - C/R 147 SQNEEBPBNil02

- - C/R 148 SQNNEBFAKl018

. - C/R 149 SQNNEBFAK1019

- - C/R 150 SQNNEBFAKl021

- - C/R l 151 SQNNEBHEM107)

- - C/R 152 SQNNEBRSM3204

- - C/R

15) SQNNEBFAKil95

. . C/R 154 SQNEEBPBN1026

- - C/R 155 SQNMEBRTWl001

- - C/R l 156 SQNMEBRTW1003

! - - C/R I 157 SQWEBRTWl004

- - C/R 158 SQNNEBHEM1004

- - C/R 159 SQNNEBFAKIl4)

-- -- C/R 160 SQNNEBFAK)l2)

-- -- C/R 161 SQNNEBHEMil41

-- -- C/R 162 SQNNEBFAKil)5

-- -- C/R

16) SQNWESRJFl210

-- -- C/R 164 SQWESRJFl001

-- -- C/R 165 SQNWESRJFI)76 7.6.l-18

l Issue Reference Document Revision Date Title 166 SQINESRJFl 577

- - C/R 167 845 060926 254 - 9/26/06 TVA Humo from Raulston to Wilson 168 845 86till 254 - II/l)/86 TVA Meno from Weir to Cox 169 SQlMESRfetill0 - - C/R ,

l 0 7/25/86 Chemical and Volume Control System 170 SQN-0C-V-27.2 171 SQNNE8RSM3078

- - C/R 172 SQNNE8RSM5012

- - C/R l7) SQNNE8RSM3252

- - C/R 174

- - C/R SQNNf8RSM)264 0 7/21/06 Residual Heat Removal System ll5 SQNK-V-27.6 176 B45 861015 251 - 10/15/06 TVA Memo from Rautston to Cox 177 845 861027 255 - 10/27/86 TVA Meno from Weir to Cox 178 SQN -0C-V-2.15 0 6/16/06 Containment isolation System 179 SQN-DC-V-27.8 0 7/24/86 Neutron Monitoring System 100 SQN-DC-V-27.4 0 7/25/06 Reactor Coolant System l

10CFR50, -- -- Code of Federal Regulation, Part 50,

! 181 Appendix A Appendix A 182 A02 860820 011 - 8/15/86 NRC letter from Holonich to TVA 185 PIRSQNCE88672 0 10/6/86 CAQ 184 B25 861006 010 - 10/8/86 TVA Memo from Wilson to Those listed 185 825 870l14 002 - 1/14/87 TVA Memo from Jones to Wilson 7.6.l-19 l

7.6.2 E l_ectrical The Electrical discipline of the EA Team (EA Electrical) performed a technical review of the DB&VP process of identifying licensing comnitments and design requirements per SQEP-18 (reference 1) and the preparation of design criteria per SQEP-29 (reference 2). This review assessed: (c) the adequacy of the C/R data base process performed by TVA and inpell/ Westinghouse for IVA; (b) the technical adequacy of selected design criteria prepared by TVA and Westinghouse for safety systems; and (c) the adequacy of the resulting R000.

EA Electrical reviewed the adequacy of the identification of sources to ensure all sources needed to capture the C/Rs were identified by SQEP-18. C/Rs from the licensing doc eent sources identified in Attachment I of SQEP-18 and other C/R sources, such as vendor letters, correspondence files, and system design files, were selected and checked against the relational data base to verify C/Rs data sheets had been prepared and the C/R captured in the data base. The C/R sheets were also reviewed for conpleteness of the key word descriptive fields. In addition, training of the senior people was checked. Finally, C/Rs which were candidates for a licensing comnitment change were reviewed to ensure the correct determinations were nude by the branch.

Specific source documents were selected for review to verify the various inpell C/R processes. These processes included identifying and assigning C/Rs to the appropriate branches, preparing nultiple C/R sheets for source documents with possible multiple C/Rs, checking the accuracy and completeness of the descriptive fields of the C/R data base sheets I and the ilning of inpell personnel to Project Instruction 0060-571-PI-l reference 3), in addition a random check of source doctsnents designated as "not applicable" C/Rs by inpell was l

nude to ensure no C/Rs were incorrectly designated and thus eliminated as candidates from the C/R data base.

Source documents used by Westinghouse in identifying C/Rs for their part of the SQEP-18 l

effort were randomly selected to assess Westinghouse's efforts in identifying C/Rs. This review also included checking the accuracy and conpleteness of the descriptive fields of the C/R data sheets and the training of Westinghouse personnel to SQEP-18.

A review of selected design criteria, prspared by TVA and by Westinghouse per SQEP-29, was performed to ensure that all appropriate licensing comnitments and design requirements were includedandthatthedocumenttechnicallyaddressesitssubject.

Restart design basis documents were also reviewed for conpleteness to verify that all necessary specific and GDC, design input drawings, and other additional design input documents as appropriate were referenced.

7.6.2.1 Details There wete 21 C/Rs (references 4 through 24) randomly identified for evaluation of IVA's of forts in the C/R area from 60 discipline-specific source documents, in additlon, 40 discipline-specific source documents were reviewed from which 10 C/Rs (5 inpell and 5 Westinghouse) (references 25 through 29 and 30 through 34, respectively) were randomly identified to evaluate their respective efforts in the program. The review of the Impell effort also included a check of 70 electrical discipline source documents designated as "not applicable" C/Rs from which 5 (references 35 through 39) were chosen for detailed review.

l 7.6.2-1

The selected C/Rs which were candidates for a licensing change consisted of ) exanples (references 40 through 42) of the 25 marked for potential change.

Westinghouse design criteria for the CSS (references 45) and the RCS (reference 44) were reviewed to ensure that Westinghouse proprietary C/Rs were captured in the tracking sheets and in the design criteria.

A total of 5 design criteria with significant electrical involvement was chosen to review the SQEP-29 ef fort of the project and Westinghouse. These criteria were Auxiliary Power (reference 45), DG (Reference 46), Vital AC (Reference 47), Vital DC (Reference 48), and CSS (Reference 49).

Three systems of the RD80 (reference 50)--AP SYS, VP SYS, and CSS--were selected for review.

Results of EA Electrical's review of the C/R process, design criteria and RDBD preparations for the project's and Westinghouse /Inpell support efforts are sunmarized below:

Progranmatic issues for the C/R and Desian Criteria Processes The procedures contained in SQEP-18 and SQEP-29 were deemed acceptable to inplement the C/R and design criteria preparation process. However, various concerns, as discussed below, were raised by EA Electrical.

l LackoftrainingtotheSQEP-18,HandbookforSeniorPeople,andtoInpellProject Instruction 0060-571-PI-l RO was identified. These deficiencies were directed to the project in action items E-Il and E-36, respectively. The project provided documents not initially available to the EA, to prove proper instructions had been given to those personnel performing the work, or that personnel had performed their work in accordance with the required procedures. This was verified by the EA Electrical and was acceptable.

l SQEP-10 neglected to include Federal, state, and local permits in its Attachment I as a necessary source for C/Rs. Thisdeficiencywasdirectedtotheprojectinactionitem E-l). The project agreed to have all sponsors of nensafety-related permits submit C/Rs.

This was deemed a phase il type work since no safety systems were affected. This was acceptable.

The C/R data base sorts were sent to the SEs instead of the design criteria preparer as required by SQEP-18. ThisdeficiencywaspresentedtotheprojectinactionitemE-19.

The project responded that both the SE and the design criteria preparers, via the lead Engineers, received the C/R data base sorts. This was verified and accepted by EA Electrical.

During one of the NRC inspections, an initial concern was raised over the verification of inpell's ef forts in the C/R process. The concern was later expanded to address the entire C/R and design criteria ef fort as performed by TVA, Inpell, and Westinghouse. These concernsweredirectedtotheprojectinactionitemE-14. The response provided by the project for the Inpell ef fort initial concern included records of transmittals between inpell and TVA for all C/Rs and source documents handled, and explanation of the Inpell processdoneviaitsprojectinstruction 0060-571-PI-l R0. This effort was independently verified by the EA Team. However, the broader scope of the concern was not addressed by the project at this time (see observation E5).

7.6.2-2

tack of training of design criteria preparers was identified by action itan E-45. In its response, the project conmitted to training all untrained personnel and to a reexamination of the work done to ensure it was in compliance with the procedures. The response was reviewed, verified, and approved by EA Electrical, in its identification of those design criteria required to support the Sequoyah restart, the project failed to identify two electrical design criteria SQN-DC-V-II.5 and SQN-DC-V-12.2 (references 51 and 52). Thiswasaddressedtotheprojectinactionitem E-16. Theprojectrespondedbyaddingthetwocriteriatothedesignbaselineeffort.

This was acceptable to EA Electrical.

Another concern on the design criteria preparation involved the proper referencing and inclusion of C/Rs in the design criteria. Thisdeficiencywasdirectedtotheprojectin action item E-20. The project required that all involved design criteria preparers review their design criterla and issue a DIM where clarification of the C/R lists was necessary.

The issue of required DIMS was verified by the EA Team. This was acceptable. (See memorandum 825 86120) 019 - reference 53).

Technical issues for C/Rs and Desian Criteria Ofthe31C/Rs(references 4through34)reviewedfortheC/Rprocess,themajorityhadC/R data sheets properly prepared and included in the relational data base. The C/R forms generally addressed the key word descriptive fields adequately and to the extent needed to ensure retrieval of the C/Rs from the data base. Action items E-12 and E-44 both addressed thefailureoftheprojecttogenerateC/Rsandtoincludetheminthedatabase (references I through 4 and 32). Theproject'sresponseadequatelyaddressedthisconcern both specifically, by issuing C/R data sheets for those applicable C/Rs identified in the action item, which was subsequently verified by EA, and generically by readdressing the source doctrnents for omission of C/Rs. This is being tracked by punchlist item 7653. The lack of proper key word identification (references 8,14,16, 24, and 28, through 35) on the C/R sheets was addressed to the project by action item M-14. Theprojectinitlateda C/A program to include a reevaluation of the sanple program to reassess the problem discipline-wide. The sample program results were submitted to FA and were verified and approved.

The five C/Rs (references 55 through 59) selected to assess Impell's ef forts in the C/R process were reviewed per the previously mentioned attributes and were acceptable with no deficiencies noted.

Three C/Rs (references 40 through 42) which had block 5 of the C/R sheet checked indicating a change was required, were reviewed to ensure that they had been correctly evaluated as candidates for change. AllthreeC/Rswerecorrectlyevaluatedbytheproject.

Review of the CSS (72) and the RCS (68) design criteria against Westinghouse proprietary C/Rs indicated that all three C/Rs for the CSS (references 54, 55, and 56) were captured in the tracking sheets and the design criteria. There were nine C/Rs reviewed for the RCS (references 57 through 65). Four of the five C/Rs (references 57 through 60) checked for inclusion in the design criteria tracking sheets for the RCS and two of the four C/Rs (references 64 and 65) checked for inclusion in the design criteria of RCS were satisfactory. One C/R for the RCS (reference 61), which addressed control and indication i

7.6.2-3

features on certain critical valve functions was omitted from the RCS tracking sheet. This deficiencywasdirectedtotheprojectinactionitemE-40. The project noted that this C/R had been determined to be not applicable for the RCS and had been superseded by another C/R for the RHR System. It will be included in the RHR design criteria in phase 11 since the af fected valves are not required to perform a safety function. This was acceptable.

Two C/Rs for the RCS (references 62 and 65) which involved calculations used to determine surge line volume, maximum surge, minimum area of surge line, etc., were omitled from the RCS design criteria. In addition these Westinghouse C/Rs could not be determined to be the most recent information since no revision nunbers were assigned to the document.

Theseconcernsweredirectedtotheprojectinactioniteml-18. Theprojectaddedthe identified C/Rs of the most recent issue to the design criteria and checked all other C/Rs to ensure the latest revision was included in the design criteria. This was acceptable and was verified by the FA Team by review of the design criteria.

The FA Electrical reviewed five design criteria: Auxiliary Power, DG, Vital Power (AC),

Vital Power (DC), and Containment Spray (references 45 through 49). The results of these reviews are presented below,

l. SQN-DC-V-II.4.1 (Reference 45) - Normal and Emergency Auxiliary AC Power Systems--This criteria adequately addressed the applicable codes, standards, and regulatory requirements, and included system and conponent requirements. Other technical aspacts, such as requirements for separations, redundancy, and diversity; the application and coordination of protective devices; and the effects of electrical events such as faults, loss of voltage, etc., were also acceptably included. The criteria failed to l include several C/Rs in the data base tracking sheet and the design criteria text, did not address electric cabling requirements, omitted a portion of the testing required in the FSAR, and did not adequately address the DG System capability requirements. These deficiencies were directed to the project in action items E-28 and E-29. Theproject 5dded the C/Rs to the data base tracking sheet. A DIM was issued to include these added C/Rs and the additional testing requirements. This was verified by the EA Electrical. In addition the project agreed to include those C/Rs not appropriate for the design criteria but needed for design in other design guide documents in phase ll.

This is acceptable.

During an NRC visit to review C/Rs and design criteria, an NRC concern (NRC observation 5.6) was raised that the AP design criteria did not adequately address power cable ratin2s for untripped continuous motor overloads. This concern was directed to the project in action item E-50. It was later expanded to include the general concern that the design aspects of cable sizing for safety-related loads, as addressed by the design criteria, might not consider all the various required criteria such as degraded voltage, short circuit, overloads, etc. The project respond by Indicating that a cable anpacity program had been underway for some time to address the general problem of cable sizing, in addition, DIMS to the desi0 n criteria were written to add reference to the ampacity standards, references to TVA and industry standards on various cable applications, and environmental design criteria and drawings. These Dims were reviewed and verified by EA Electrical and were acceptable to resolve the concern.

l I r i i l

7.6.2-4 ,

2. SgbDC-V-II.8 (Reference 46) - OG and Auxiliary Systems--The operating descriptions, safety function, and corresponding requirements for response to the ISAR Chapter 15 event, along with separation, redundancy, and diversity requirements, were provided in the criteria. The criteria did not include several C/Rs in the data base tracking sheets and the design criteria text; did not address all required electrical standards and regulatory requirements; did not discuss the design parameters for the DG battery terminal voltage at the design minimum discharge state, nor reference electrical cabling and separations requirements; failed to address OG battery system testing; did not consider DG starting on degraded voltage, and protective devices for the DG battery and battery board; and did not include voltage requirements for the redundant motor-driven fuel punps. Theseomissionsweredocumentedtotheprojectinactionitem E-25. TheprojectissuedaDIMtothecriteriatoincludetheaboverequirements. The OlM was reviewed and was acceptable.

I However, as part of the concern the generic aspx4 of an apparent lack of interface review had been identified. This was noted because of the excessive nunter of electrical design requirements not captured in this mechanical criteria. Theproject

( has not yet adequately addressed this concern. (See observation E6) l 3. SQN-DC-V-II.6 (Reference 47) - GT for 120V Vital Instrument Power Systems (AC) -The criteria included system and conponent requirements; provided interface requiromonts including system functional and conponent/ structural physical requirements and adequately addressed the operating description, safety functions, and corresponding requirements for response to the FSAR Chapter 15 event. The criteria also appropriately included separation, redundancy, and diversity requirements; considered the effects of electrical events; and addressed the application and coordination of protective devices for electrical equipment. All applicable C/Rs from SQEP-29, Attachment 2, were included in the design criteria; however, in some cases the C/Rs were only referenced indirectly in the text or under the design input section

" References" and were not adequately described. Also some C/Rs were missed in the design criteria and on the data base tracking sheet. The interface requirements were adequately addressed with the exceptions of the maintenance source with regard to allowable voltage range input. Testing requirements were included but omitted the inverters, distribution boards, instrumentation, protection devices, and the maintenance sources. The application and coordination of protective devices were adequate with the exception of alarm contacts needed on the distribution boards.

Power, voltage, raceway, electrical insulation, and motor requirements were adequately addressed with the exception of cable and maintenance source voltage requirements. The criteria failed to address some applicable codes, standards, and regulatory requirements, in that it omitted IEEE Standards 32) and6, NEMA SG-), and AB-1, and RGs 1.29, l.}2, and 1.6, and Regulatory Requirement 10CFR50 Appendix 8. The above concerns were identified to the project in action items E-20, E-21, E-22, and E-26. Except in one instance all of the concerns were appropriately addressed by the l projec t. Memorandums were issued which added missing C/Rs to the data tracking sheets and DIMS were issued to add missing C/Rs and to include the technical inforsation mentioned above in the design criteria. C/As for E-20, E-21, and E-22 were verified and were acceptable, in the one instance where the project did not respond to a concern (action item E-26), the project needs to address the generic aspects of omitting testing requirements from design criteria (see observation E7). 7.6.2-5

4. SQN-DC-V-II.2 (Reference 48) - 125V Vital Battery System.-A detailed technical review of this criteria, enconpassing all the attributes described for the three previously discussed criteria, revealed that it was technically adequate in all areas but two.

(1) Some C/Rs had been omitted from the data tracking sheets and the design criteria. These deficiencies were directed to the project in action items E-21 and E-22. As discussed under the previous section on SQN-DC-V-II.6 design criteria, the project adequately responded to these by generating nwmos and OlMs to address the concerns. These menos and DIMS were verified and approved by the EA Electrical. (2) Cable requirements had not been addressed in the design criteria and the vital battery terminal voltage at the design discharged state was not specified. These deficiencies were directed to the project in action items E-23 and E-24, respectively. Theproject response for E-23 referenced the fact that the evaluation of the cable requirements was addressed by reference to the cable design criteria contained in Attachment I to SQEP-29. This was acceptable. As an added enhancement, the project has agreed to add references to the GOC in each of the specific criteria as part of phase 11. Tracking of this agreement is by punchlist item 7938 for System 67. (Also see action item E-14.) A OlM was added to the criteria by the project to address the omission of the minimum battery voltage in response to action itan E-24. This was acceptable and was verified by the EA Electrical.

5. SQN-0C-V-27.5 (Reference 49) - CSS (Preliminary)--The technical review of this preliminary design criteria addressed all the various attributes mentioned for the previously discussed design criteria. In general, the design criteria was acceptable except in the omissions of IEEE Standards $23, 344, 334, 279 and FSAR section 7.3-1 requirements. These omissions were identified to the project in action items E-31 and E-39. The final issued version af this design criteria resolved all of the issues of action item E-39 and several of the issues covered by the action item E-31. There were two renaining issues. The first was the inclusion of references to the 125V DC VP SYS criteria and the 480V AC power r Nulrements for the CSS valve operators, which were to be added to the design criteria in phase ll since they were not required for restart.

l C/As by the project on this issuo was inconplete and requires verification by EA. (Observation E8) The second issue was the apparent lack of a thorough interface review to ensure all appropriate discipline requirements were included. (See section 7.6.2.l(2) for a discussion of tils generic concern). In addition to a review of the design criteria, three systems of the RDB0 (reference 50) were reviewed to evaluate their cortpleteness. The RDBD for VP SYS, AP SYS, CSS, included all the appropriate references to GDC and drawings as required by SQEP-29. In a discussion with the NRC, other concerns were cited in two additional design criteria. These included the use of outdated environmental data in design criteria SQN-DC-V-II.) and a concern that IE cables for the RPS which were routed through the turbine building (non-seismic structure) were not being labeled as being IE, Generating Station Protective System (GSPS). This later concern resulted from a review of design criteria SQN-DC-V-12.2. It was noted that exception EX-SQN-DC-V-12.2-5 taken to section 4.4.4 of the criteria was not consistent with Branch Technical Positions ICSB 26, NUREG-0800, which require that all reactor trips incorporated in the RPS should be designed to meet the requirements of IEEE Standard 279 (reference 66). IEFF Standard 279 requires such components to be distinctively 7.6.24

identified as being in the protective systems. Theseconcernsweredirectedtotheproject in action items E-71 and E-74, respectively, in response to the concern raised in action item E-71, the project issued a DIM to the criteria to refer the user to the Environmental Design Criteria SQN-DC-V-21.0 and the 47E235 Series Environmental Data Drawings for the appropriate environments. Environmental parameter values presently in SQN-DC-V-II.5 were deleted. This was acceptable. Theprojectalsodidasamplereviewofninedesign criteria within the DB&VP--two from EEB, four from r.EB, and three from NER--to determine if proper reference to envirorcental design documents was made. The sampled criteria adequately referenced SQN-DC-V-21.0 and the 47E235 series drawings. This was verified and accepted by the EA Electrical. In response to the concern raised in action item E-74, the project clarified the DIM by explaining that the exception covered the Turbine Building valve circuits listed in ER (501 860122 %)) (reference 67) not the RPS circuits. EA Electrical performed a verification check of the labeling of the RPS circuits and found several discrepancies involving missing and mislabeled cable 10 tags. It

• laroject verbally agreed to Correct these tags and issue WRs to perform the work. The project has not yet formally responded to these deficiencies. (See observation E9)

As a result of a significant number of concerns raised, the project instituted a C/A program for C/R and design criteria preparation (see references 55 and 68 for a detailed program description and results). The EA Electrical reviewed the project's C/As program and its results for items 2, 5, 5, 7, and 11 of reference 55. Items 2, 5 and 11 have been verified by EA Electrical. Item 2, the concern over inpell's sort of N/A conmitments, was covered by action item E-15 and has been previously discussed in the section above, item 11 was addressed by action item E-25 and docunented the project's conmittnent for efforts in phase ll design criteria enhancement. Action item E-12 covered item 3 and expressed a concern that C/R data sheet fields had not been properly filled out. Theproject'sC/A consisted of a review of tha electrical C/R sheets, which resulted in four additional minor revisions to C/R sheets. The EA Team verified the adequacy of the results, item 5 concerned capturing C/Rs in the design criteria and was documented in action item E-20. Theconcernaddressedinthisactionitemwasadequatelyaddressedbytheproject(see previous discussion for Progranmatic issues for the C/R and Design Criteria Process). l Item 7 discussed the lack of referencing other appropriate criteria documents within the design criteria. This was presented to the project in action items E-23 and E-31. The l project stated that the problem was minor and could be corrected in phase il enhancement, i Tracking is via PIR SQNCEB8672 (punchlist item 7938 for System 67 only). EA Electrical I agreed with this assessment. Theprojecthasnotyetaddressedthegenericaspectofthis concern which was presented to the project in action item E-14. EA requires verification of C/A (see observation ES). I 1.6.2-1

I 7.6.2.2 Conclusions TheElectricaldisciplineoftheEATeamreviewedtheprojectactivitiesindevelopinga C/R data base, preparing restart design criteria, and generating a RD80. The extensive ef fort conducted to establish and maintain C/R data base, coupled with the ef forts of the design criteria preparer and supplemented by a broad base C/A program, led to the development of technically adequate design criteria and RDBD. With the exception of EA verification of portions of the C/R and design criteria C/A program and with project establishment of C/A for: (1) portions of the C/R and design criteria program, (2) the RPS labeling concern, (3) design criteria interfacing requirement concern, and (4) addressing electrical testing requirements in design criteria, the program objective was verified to have been met. (See observations E5 through E9). 7.6.2.3 References issue Reference Docunent Revision Date Title 7/9/06 Procedure for identifying Comnitments and i SQEP-18 1 Requirements 1 7/18/86 Procedure for Preparing the Design Basis 2 SQEP-29 Document for Sequoyah Nuclear Plant 3 0060-571 -PI-I O 4/14/86 Design Criteria identification and Documentation 4 SER 3/79 Safety Evaluation Report Section 8.4.4 - Electric Per.etrations Meet Regulatory Guide 1.63 5 SER 3/79 Safety Evaluation Report Section 8.4.4 Circuit Breakers Protecting Containment Must be Tested 6 S01 8605C6 943 -- 5/7/86 Response to IE Bulletin 85-43 MOV Switch Settings Verification and Testing 7

                                            --      --            SQN Final Safety Analysis Report Section SQN FSAR 8.3.1.1,120V AC Vital Instrument l'ower Board Branch Circuit Breaker Alarm Contacts 8    A27 810109 006              1/9/81        Interlocks to Emergency Feeder Breakers
                                                 -   --           SQN FSAR Section 8.3.2.1.1, Vital Battery Board 9    SQN FSAR Breaker Trip Alarm Contracts 10
                                              --      --           SQN FSAR Section 8.1.4.(8), Onsite Power DC SQN FSAR System
                                              --          -        SQN FSAR Section 8.l.5.3, IEEE Standard 344-1971 11    SQN FSAR 12                         --      --           SQN FSAR Section 8.l.4(4), Onsite Power System SQN FSAR AC and DC 7.6.24

Issue Reference Document Revision Date Title 15 SQN FSAR -- -- SQN FSAR Section 8.5.11, Sustained Overvoltage Protection for 6.9-Kv Shutdown Buses 14 A27 810125 001 -- 1/23/86 ERCW Puno Motor Relays Change out IS L53 840010 874 -- 8/10/84 Add Time Delay to RAD Monitor 16 10CFR50.55(e) -- 11/5/80 Provide control power supply to AFW Final Report turbine-driven pung (SQNEEBElll206) 17 EEB 800200 020 -- 2/6/80 Change Transformer Neutra! Ground Relating Scheme (SQNEEBEllE1200) 18 MEB 840521 500 - 5/1/84 ERCW Screen Wash Ptrip Maxinun and Mininun Operating Volts 19 SWP 820225 007 -- 2/25/82 DCR-SQ-DCR-934 Add DC Oil Ptsrp for Diesel Generator 20 NCRSQNEEB8115 -- 4/9/81 Replace Class IE motors with nutors capable of starting at 80 percent of rated voltage 21 L44 841101 809 -- 11/1/84 Separation Requirements for 125V DC Sth Vital Battery per FSAR Section 8.5.1.4 22 Ll6 810305 802 -- 3/20/84 Electrodyne Valve Operators 25 TVA Blue Book -- 5/79 Radiation Monitors and Sampling 24 SER -- 3/79 Safety Evaluation Report Fire Retardant Coating for Cables in Spreading Room 25 SQNEEBORWl015 -- 5/6/86 FSAR Section 8.1.4, Design Basis Onsite (Standby) Power Systems (3) Category i Structures 26 SQNEEBORWl014 -- 5/6/86 FSAR Section 8.1.4, Onsite Power Systems (4) 27 SQNEEBORWl015 -- 5/6/86 FSAR Section 8.1.4, Onsite Power Systems (5) 28 SQNEEBElll024 -- 5/6/86 FSAR Section 8.3.1.4.1, Cable Derating and Cable Tray Fill, IPCEA Standard Flame Test 29 SQNEEBElll058 -- 5/7/86 FSAR Section 8.3.1.4.1, Minimum Conductor Site 2/0 AWG for 600V Cable 30 SQNWESftfl094 -- 5/15/86 Preliminary Layout Guidelines for Reactor Vessel Vent RCS (68) 7.6.2-9

issue Reference Document Revision Date Title 31 SQWESRJFl019

                                 --        5/8/86      SafetyinjectionSystem(63) Actuation 5/15/86     FSAR Pump Curves System (63) 32       SQNWESRJFl215 5/8/86       Pump Auto Start Time Containment Spray (72) 33       SQNWESRJFl021 5/8/86       Parameters for Containment Analysis Safety 34      SQWESRJFl001 injectionSystem(63) 35       NEB 850122 622         --       I/8/85      TVA Letter to NRC on Diesel Generator Batteries 36       NER 850214 804         -       2/13/85      TVA Letter to NRC on LER SQRO-50-328/85001 37      NEB 821109 650 00               II/2/82     TVA Letter to NRC on LER SQR0-50-327/82121 6/9/82       TVA Letter to NRC and TVA Radiological Emergency 38      NEB 820610 608         --

Plan 39 NEB 860701 219 - 6/25/82 Internal NRC Memo Sent to TVA for information 40 SQNEEBDRWl034 5/6/86 Revision Dates to ANSI and NEMA Standards 5/13/86 Justification for Continued Operation for 41 SQNEEBPBNil30 Equipment Not Environmentally Qualified

                                      --     5/5/86      Abnormal events which could cause physical 42      SQNEEBP8N1015 damage to the Reactor Trip System Conponents 43     SQN-DC-V-27.5            0       7/30/% Containment spray System (72) 44                              0       7/23/86     Reactor Coolant System (68)

SQN-DC-V-27. 4 45 SQN-DC-V-I I . 4.1 2 3/28/86 Nornal and Emergency AC Auxiliary Power System 0 7/10/86 Diesel Generator and Auxiliary Systems 46 SQN-DC-V-I I .8 3 7/ll/86 120V AC Vital Instrument Power Systems 47 SQN-DC-V-I I .6 48 3 7/11/86 125V DC Vital Battery System SQN-DC-V-I I .2 49 SQN-DC-V-27.5 0 7/18/86 (Preliminary) Containment Spray System 826 861210 006 0 12/4/86 Restari Design Basis Document, Sequoyah Nuclear 50 Plant Unit 2 SQN -DC-V-I I . 3 5 9/30/85 Power, Control, and Signal Cables for Use in 51 Category I Structures 7.6.2-10

Issue Reference Document Revision Date Title 52 SQN-0C-y-12.2 6 9/30/85 Separation of Electric Equipment and Wiring 55 B25 861203 019 -- 12/5/% Menorandum, Sequoyah Nuclear Plant - Design Baseline and Verification Program to Support Restart 54 SQWESW1067 - 12/20/71 Seismic Considerations for Protection Grade Equipment 55 SQWESRJFl017 -- 8/24/70 TVA Revised Emergency Loading Requirements 56 SQWESWil69 -- 7/28/71 Review of TVA Logic Diagram 57 SQNWESRJF1209 - 1/9/75 Data for FSAR Analysis (B45 860515 098) 58 SQNWESWl031 -- 6/18/73 RCS Pung Motor Data Sheets (B45 860515 923) l 59 SQNWESRJF1212 -- 11/9/74 FSAR Data (845 860515 221) l l 60 SQWESWl058 -- 5/6/81 PORY Identification Nunt>ers (845 860515 % 7) 61 SQWESWl083 -- 10/20/72 Critical Function Motor-Operated Valves (845 860515 917) 62 SQNWESmil04 -- 6/3/71 Pressurized Surge Line Parameters (B45 860515 934) 63 SQWESW1090 -- 8/13/75 TVA/ TEN Reactor Vessel E-Spec Addendum 678666 R3 (845 860515 929) 64 SQWESW1029 -- 11/13/72 TVA/ TEN Reactor Coolant Punp E-Spec 677355 RI l 65 SQNWESW1061 -- 5/28/81 Reactor Vessel Head Vent System (856 860515 972) 66 IEEE Standard 279 -- 71 Criteria for Protection Systems for Nuclear Power Generating Stations 67 Sol 860122 %) 0 12/27/85 Engineering Report for SCR SQNEER8530 RO 68 B25 860911 012 -- 9/11/06 Sequoyah Nuclear Plant Design Baseline and Verification Program (DB&VP) to Support Restart 7.6.2-1l

o 7.6.3 Instrumentation and Controls The ItC discipline of the EA Team review of project desip criteria consisted of two activities:

1. A review of potential licensing conmitments and design requirements (C/Rs) from plant files to ensure that all applicable C/Rs had been recorded in the plant C/R relational data base.

2. A review of the plant system design criteria to ensure that all applicable design requirements, licensing conmitments, and other governing inputs were incorporated.

TVA source documents, Westinghouse source documents, and inpell conmitment document assignment (CDA) sheets were reviewed. Their selection included a variety of source document types and focused on the less visible C/Rs such as letters and nemorandtsus. Design criteria were selected which have significant interdiscipline content, safety relationship, and control system performance requirements. I. TVA source documents were reviewed to ensure:

a. A C/R data sheet had been prepared for the licensing conmitment or design requirement,

b. The relational data base included the C/R.

c. Senior Engineers / Managers were properly trained in the review activity.

l

2. Westinghouse source documents were reviewed to ensure:

t

a. A C/R data sheet had been prepared for the licensing conmitment.

b. The relational data base included the C/R.

c. Westinghouse senior people had been trained in the review activity. .

5. Inpell conmitment document assignment sheets were reviewed to ensure:

a. Appropriate assignment for the C/R to a TVA branch or Nuclear Power.

b. Impell project team personnel had been trained in the use of project procedure 0060-57l-PI-I.

4. Design criteria were reviewed to ensure that all applicable licensing conmitments, codes, standards, and requirenents (such as regulatory, system and conponent, interface, separa1 ion, and postmodifica1 ion iesting) have been included.

7.6.5.1 Details Eight (VA source documents and 11 Westinghouse source documents were reviewed. Five source documents (references I through 5) were found to be unrecorded in the C/R relational data base. Those concerns are discussed below, in addition to two concerns regarding programmtic aspects of the C/R data base preparation. 7.6.5-l L 2

Conmitments and Requirements TVA letter to NRC dated 5/12/86 (reference 1), contained conmitments to investigate, test, and maintain specific MOVs and MOV switch settings. Those conmitments were not recorded in the C/R data base. Action item I-10 was directed to the project to address the concerns. The project conmitted to add the conpitments to General Construction Specification G-50 (reference 6). EA recognized that the conmitment was not design related and had no inpact on the DB&VP objectives, but were maintenance related, and consequently closed the action item. NUREG 0011 SER, Supplement 5 dated 6/01 (reference 2) contained a conmitment to provide a backup display for incore temperature. A C/R data input sheet was not prepared for the document. Action item I-il was directed to the project to address the concern. In response, the project established that the requirement was included in design criteria SQN-0C-V-19.0 (reference 7) Appendix A. Additionally, the project conmitted to preparing a C/R data sheet for this conmitment. An unrecorded conmitment (reference 3) related to Rosemount dif ferential pressure transmitter zero shif t, described in IE Notice 85-100. Action item I-12 was directed to theprojecttoaddresstheconcern. Inresponse,theprojectnotedthatthisphenomena had been recognized and had been accounted for in Sequoyah setpoint and accuracy calculations. EA l&C reviewed typical calculations and concurred. References to C/Rs recorded in Westinghouse proprietary files were not recorded in the C/R database. - Action item I-15 was directed to the project to address the concern. The project provided a letter from Westinghouse dated July 16,1986 (reference 8), which attested that all proprietary documents which contained conmitments and requirements (such as system descriptions, drawings, specifications, etc.) had been forwarded to fVA in a non-proprietary form. EA l&C concurred that the coordination of proprietary documents was satisfactory. ! Westinghouse document TVA-2698 dated May 11, 1972 (reference 4) was not documenled in the C/R data base. Action item I-16 was directed to the project to address the concern. The l project response established that the doctrnent did not constitute a conmitment or design requirement. It was intended to be applied as a guide for maintenance and calibration of instrumentation components within the RPS. In addition, EA l&C datermined that the RPS design criteria SQN-DC-V-27.9 (reference 9) did contain accuracy and tolerance requirements for RPS components. Documentation of source doctrnent revision level in preparing the C/R data sheet appeared to be inadequate. Action item l-18 was directed to the project to address the concern. The project established that the documents referenced had been superseded by a later revision to Westinghouse document RFS-TVA-10646 (reference 10). EA l&C verified that the requirements contained in the doctrnent were included in design criteria SQN-DC-V-27.6 (reference 11). A Westinghouse letter to TVA (TVA-878 dated July 7,1970, reference 5) contained 17 sections, of which only 9 were reviewed and C/R data sheets prepared. Action item I-19 was directed to the project to address the concern. The project conmitted to having the Westinghouse SE review these criteria and if the criteria were not identified for another source as C/Rs, they would be added to the C/R data base. E 7.6. 3-2

Due to the nunt>er of action items concerning unrecorded conmitments, project comnitted to a re-review of C/Rs which had been omitted from the C/R data base [ memo from J. f. Cox to Sequoyah Project Files dated 9/11/% (reference 12)]. For further discussion and verification of this ef fort, refer to section 7.6.2.1. IngeiI Sortin2 The inpell prepared assignment sheets were all determined to be appropriate. Fourteen ISC related source documents reviewed by impell personnel which had been categorized "N/A" (document contained no licensing conmitment or design requirement) were reviewed by EA ISC. The documents were typically licensee event reports (LERs) which addressed individual component failures which were not generic in nature and for which licensing and/or redesign conmitments were not established. One source docunent, a letter from TVA to NRC dated 8/5/80 (reference 15) conmitted to upgrade features of the meterological nonitoring system. As such, it was incorrectly categorized as "N/A". Action item I-17 was written to address this deficiency. The project concurred that the document was misassigned and should have been assigned to Nuclear Power. Project conmitted to reviewing all source docunents assigned "N/A" by inpell for possible misassignment. Desian Criteria Design criteria for the SGB System (IS), postaccident monitoring system (PM) (45), and CSS (72) (references 14, 7, and 15) were reviewed. All aspects of the design criteria were found to be satisfactory. Two additional design criteria were reviewed by the NRC. The review of design criteria SQN-DC-V-2.16 (referexe 16) and SQN-DC-V-52.0 (reference 17) resulted in three action items as follows:

1. Desian Criteria SQN-DC-V-2.16--As a result of the review of the design criteria, five concerns were identified by the NRC:

a. Section 4.6 "nondetectable failures for electrical systems" relied on test as the primary course of action. IEEE 579-1977 requires redesign as the preferred course of action.

b. The definitions of " train" and " independence" were not consistent with accepted industry usage as reflected in IEEE standards.

c. Section 5.5 "long-term period with active / passive failure" confused mechanical and electrical terminology,

d. Loss of offsite power was not addressed as a possible event.

e. PM system electrical criteria were not included.

The concerns were presented to the project in action item I-14. For concern b, the project response indicated that the definitions used were technically correct and would not have resulted in misapplication of criteria even though they are rot as clear as they could be. The project conmitted to providing clarifications to the 7.6. 5-5

i definitions as an inprovement under the phase il portion of DB&VP. For concern e, the project established that specific separation criteria for PAM instrumentation would be defined in the PAM design criteria SQN-DC-V-19.0 (reference 7) instead of being added to the generic criteria. Concernsa,c,andd,theprojectindicated

  - that revisions to the design criteria would be inplemented prior to restart.

Revision I to design criteria SQN-DC-V-2.16 (reference 16) was issued January 21, 1987, and changes reviewed by the EA team. All revisions were acceptable and action item I-14 was closed.

2. Desian Criteria SQN-DC-V-52.0--As a result of the review of the design criteria, five concerns were identified by the NRC:

a. Section 5.3.1.f of the design criteria identified IEEE 525-1971 as the applicable issue to be used for replacement parts and equipment rather than IEEE-525-1974.

b. C/R nunter SQNMEBLWBl208 "setpoint requirements" was applicable to system 52 but was not included in the design criteria.

c. Section 5.4.5 of the design criteria discussed the need to protect portions of the ACA system from the effects of postulated ruptures of surrounding piping where those interactions have a potential for jeopardizing safe plant shutdown.

However, it did not discuss any specific interaction that would qualify, such as the overpressure transient discussed in C/R SQl#IEBLWBl060.

d. A requirement for " oil free" conpressed air was identified in a Westinghouse (W)

Nuclear Service Division Technical Bulletin (NSD-TB) No. 81-3 (reference 18). This requirement was recorded in the C/R data base (SQWESRPMillo, reference 19); it was not addressed in the design criteria.

e. C/R nunter SQNNEBFAK1229 (reference 20) " upgrade of air supply to containment radiation monitor isolation valves" was applicable to System 52 but was not included in design criteria SQN-0C-V-52.0., revision 0. The C/R conmitted to upgrade the air supply to valves I-FCV-90-108, -109, -Ilo, -114, -115, and -116.

These valves are not included in Table I, " Vital Equipment Served by the ACA," of the design criteria. The concerns were presented to the project in action item l-15. For concern a, the issue was resolved by design input menorandum (DIM) to the design criteria (reference

21) to correct section 3.5.l.f to refer to IEEE 325-1974.

Due to the complexity of action item I-15 and the volume of reference documentation included in the project's response to five concerns, it was decided to reissue concern b as a new action item l-20. Theprojectresponseto1-20 indicated that a design criteria document is an upper-tier design input document which does not necessarily have to include all instrument setpoints. Engineeringjudgmentmustbe exercised to determine the need for incorporating certain setpoints values into design criteria documents. The specific setpoint concern expressed in the actico itun did not qualify as required data in the ACA design criteria. EA l&C concurred withtheproject'sresponsewhichclarifiedtheproject'srecognitionandtreatment or setpoints in the DB&VP. 7.6.5-4

l For concern c, the project response indicated that the C/R applied to ACA headers in inside containment and those headers did not perform a primary safety function, addition, the project comnitted to clarify protection of this family of air lines in design criteria SQN-DC-V-10.5 (reference 22). EA ISC and EA Mechanical concurred with the project position and verified that the clarification was issued in a DIM (reference 21). For concern d, although the design criteria specified the ACA conpressors to be non-lubricated, an acceptance criteria, or definition of " oil free" air was not included. The project comnitted to issue a DIM (reference 21) to the design criteria to prohibit use of oil-based thread lubricants and add words " oil free" to design criteria with a definition of " oil free." EA reviewed the DIM and concurred that the revisions were acceptable. For concern e, although the source document (reference 23) for C/R SQNNEBFAKl229 (reference 20) comnitted to upgrading the air supply to the radiation monitors isolation valves, no formal change documentation, per established procedures, was issued by the engineer's cognizant of the requirements for radiation monitors, justifyingandauthorizingtheuseofessentialair. Theprojectresponseincluded SCRSQNNE88615 (reference 24), which was issued to document and track this discrepancy. EA l&C concurred with the use of the SCR tracking and resolution methods as a satisfactory means of resolving the concern. As a result of the NRC's request for a definition of Sequoyah's comnitments on Regulatory Guide 1.97, scheduled for inplementation in 1%7, related to the design basis and verification program, one additional action. item (1-09) was issued. The project response established that TVA was comnitted to implementing the requirements j of Regulatory Guide 1.97 until October 1%7. This action item was a request for j definition and clarification only. No corrective action or follow-up verification i was required. 1.6. 3. 2 Conclusions The design criteria provide a sufficient design basis for the fluid systems. Although numerous concerns arose regarding omissions in the C/R relational data base, the omissions did not compromise the adequacy of the design criteria. 7.6.3.3 References issue Reference Document Revision Date Title i L44 860512 803 -- 5/12/86 TVA Letter to NRC (IE8 8503) NVREG Oil SER -- 6/8I Safety Evaluation Report Related to the 2 Supplement 5 operation of Sequoyah Nuclear Plant Units I and 2 g

                                                -  2/6/86     Memo from D. E. McCloud to J. N. McGriff, IE 3    L)) 860206 802 Notice 85-100 Rosemouni Transmiiter lero Shiff 7.6.5-5

issue Referenc,e Document Revision Date Title 4 TVA-2698 -- 5/ll/72 Westinghouse Letter to IVA (RPS Channel Accuracles and Setpoint Tolerances) 5 TVA-878 -- 7/7/70 Westinghouse Letter to TVA (Reactor Control and Protection System Functional Requirements) 6 G-50 2 3/14/84 Torque and Limit Switch Setting for Motor-Operated Valves 7 SQN-DC-V-19.0 0 7/17/85 Design criteria Postaccident Monitoring Systan (45) 8 TVA-860609 -- 7/16/06 Westinghouse letter to TVA (C/R Review) 9 SQN-DC-V-27.9 0 7/24/86 Design Criteria Reactor Protection System 10 RFS-TVA-10646 -- 11/16/72 Westinghouse document i ll SQN-DC-V-27.6 0 7/21/86 Design Criteria Residual Heat Removal 12 825 0609 1 012 -- 9/11/86 J. F. Cox's Memo to SQEP Files (DB&VP to Support Restart) 13 A27 800005 027 - 8/5/80 TVA Letter to NRC 14 SQN-DC-V-3.1.1 2 7/11/86 Design Criteria Steam Generator Blowdown System (15)

                                                        ~

15 SQN-DC-V-27.5 0 7/30/06 Design Criteria Containment Spray System (72) 16 SQN-DC-V-2.16 1 1/21/87 Design Criteria Single Failure Criteria for Fluid and Electrical Safety-Related Systems l 17 SQN-DC-V-52.0 0 7/11/% Design Criteria Auxiliary Control Air System j (52) i 18 NSD-T8 81-3 - 2/10/81 Westinghouse Nuclear Service Division f Technical Bulletin IE Notice 80-11 5/23/06 C/R Data Sheet Control Air Contamination by Oil 19 SQNWESRMillo 20 SQNNEBFAK1229 5/16/% C/R Data Sheet Upgraded Radiation Monitor Air Supply 21 OlM SQN-DC-V-52.0-1 - 1/29/87 Design input Menorandum Auxiliary Control Air System (32) 22 SQN DC-V-10.5 1 8/24/84 Design Criteria separation of Instrument Sensing Lines and Instrtunent Air Lines 7.6.3-6

Issue Docunent Revision Date Title Reference 0 10/22/80 Containment Radiation Monitors inoperable 25 LSI 801020 921 SCR$QNNEB86tS 0 8/7/86 Significant Condition Report Failure to 24 Upgrade Air Supply to Radiation Monifors inside Containment l i 7.6. )-7

7.6.4 Mechanical The 084VP identified and cataloged C/Rs in accordance with SQEP-18 (reference 1). Design criteria were then prepared or revised to incorporate the applicable C/Rs in accordance with SQEP-29 (reference 2). The design criteria appropriate design input drawings, and upper-tier licensing documents have been cataloged in a R000 (reference 5). The Mechanical discipline of the EA Team performed a review of the process for producing the documents (C/Rs, design criteria, and R000) and reviewed a sanple of each type of product for conforance to procedural requirements and for technical adequacy. The C/Rs were reviewed to determine if: e Source docesnents were identified. o C/R data sheet reviewers were trained, e Licensing coninitments and design requirements on C/R data sheets were captured in the C/R data base. e Licensing comnitments which are candidates for change are adequate. Design criteria were reviewed to determine if: o C/Rs were incorporated into the design criteria text and C/R tracking list, e industry codes and regulatory requirements were correctly assigned, e Performance criteria, design parameters, environmental conditions, neterial requirements, QA requirements, and related technical information were adequately explained, o Sound technical justifications were provided for deviations to requirements. e Separation, redundancy, and diversity requirements were thoroughly provided. e Test and inspection requirements were adequately assigned. e Hydraulic requirements such as net positive suction head (NPSH), pressure drop, and fluid velocities were specified. o Notation was made of any special layout or physical arrangement requirenents. C/Rs were prepared by TVA, Westinghouse, and inpell, in addition, Inpell was involved in the initial sorting of C/R source documents for review by the various disciplines (Civil, Electrical, Mechanical, and Nuclear). Because of the particular locations where work was performed ar,d the proprietary nature of some of the Westinghouse C/R source docisnents, reviews of the process for selection and preparation of C/Rs and technical review of the adequacy of the C/Rs themselves were performed at all three locations. 1.6. 4 -l

The sanple for review and evaluation of C/Rs was taken from readily available documents [i.e., FSAR,10CFR50.55(e) Final Reports, IMI green book, IMI blue book, responses to NRC IE Bulletins, Violations / Deviation / infractions, and searches of in-house QA record files (RIMS) of memos, letters, procurement documents, etc). For the TVA review, approxinefely 60 discipline-specific source documents were polled and 20 C/Rs were randomly identified for evaluation. For the Westinghouse review, approxinately 40 discipline-specific source documents were polled and 15 C/Rs were identified for evaluation. For the inpell review of C/Rs, approximately 40 discipline-specific source documents were polled, 4 C/Rs were identified for evaluation, and 9 non-C/Rs were reviewed to confirm non{/R classification. The Impell review work was done according to inpell's Project instruction 0060-571-Pl-l (reference 4). For each C/R reviewed, the related source document was also reviewed to verify the adequacy of C/R data sheets and to ensure correct understanding of the C/R. Note that due to the multiple reviews that were performed for candidates for C/Rs and C/Rs occasionally different, evaluation sheets were filled out for the same C/R. Three design criteria with significant mechanical involvement (i.e., fluid / hydraulic in addition, two design systems) were selected for conprehensive detailed evaluation, criteria were given a partial review with emphasis on the mechanical aspects of that design criteria. The selection of design criteria for review was also based on those which were deemed to have central roles in the safe shutdown of the plant as described in Chapter 15 of the FSAR. The design criteria selected were:

a. Auxiliary feedwater System (reference 5) System 3B.

b. ERCW System (reference 6) System 67.

c. CCW System (reference 7) System 10.

d. Containment isolation System (partial review) (reference 8) System 88.

e. Containment Spray System (partial review) (reference 9) System 72.

7.6.4.1 Details

1. Inoell C/R Review and Evaluation The inpell review focused on verif ying the process of assigning C/Rs to the appropriate branches, preparing multiple C/Rs for source documents with possible nultiple C/Rs, checking the accuracy and completeness of the descriptive fields of theC/Rdatabasesheets,andthetrainingofImpellpersonneltoProjectinstruction 0060-571-pl-l (reference 4). In addition, a random check of source documents desi0nated as "N/A" C/Rs (no C/R required) by inpell was made to ensure no C/Rs were incorrectly designated and thus overlooked. For this review, Mechanical discipline-specific source docurents were selected for review. A sunmary of the results of that review is presented in the paragraphs which follow.

Five of the documents (references 10 through 14) classified by Impell as "N/A" (no C/Rs required) were reviewed and evaluated by EA to determine if these were classified correctly. References 10 through l) were found to have been correctly classified as "N/A" (no C/Rs were required). One of the documents (reference 14) was classified incorrectly and was found to require a C/R. The results of this review are discussed below. l

7. 6. 4 -?

a. TVA's letter to the NRC dated June I,1905 (reference 10), discussed an LER on the low-level limit of the RWST being exceeded. This was related to a mechanical failure. No C/R was required.

b. TVA's nuno from F. W. Chandler to files dated June 9,1915 (reference 11), was related to an NRC exil meeting. Miscellaneous topics were discussed. No C/R was required.

c. TVA's letter to the NRC dated October 20,1982 (reference 12), discussed an LER that was issued to docisnent the failure of a valve to open. The cause was assigned to a breaker in the wrong position (incorrect operation); no C/R was required,

d. TVA's letter to the NRC dated Septent>er 21, 1983 (reference 13), discussed failure of the SIS pung 2A and two centrifugal charging ptsnps (CCPs) to meet minimum head curve requirements. Further review of documentation on this issue (follow-up letter to the NRC dated August 26,1985 (reference 15)) indicates that on review of subsequent test data by TVA and Westinghouse, the condition was found to be acceptable af ter accounting to changes in the system configuration during the test. No C/R was required.

l l

e. TVA's letters to the NRC dated Septerrt>er 2,1901 (reference 14), and followup j

dated August 26, l%S (reference 15), were found to require a C/R (i.e., were L incorrectly assigned "No C/R" status). Reference 14 described an investigation which found that the design of the ERCW supply to the CCS "C" heat exchanger l discharge valve, 0-FCV-67-152, allowed it to go to 100 percent open upon receipt l i of an safety injection signal. As a result, insufficient flow under worst case conditions to other required equipment such as the CSS heat exchangers and l charging pump room air and oil coolers could have resulted. The letter stated that to prevent this from occurring, the valve must go only 35 percent open under these conditions. As this is a design requirement, a C/R should have been written (none was). Also, no reference to this design requirement could be found in the ERCW design criteria (reference 6) although it does contain reference to the required component flows (ERCW design criteria sections 0.1.19 and 8.1.20). Discussion of the requirement vould have conveniently fit into ERCW design criteria section 3.9.ll (corrponent cooling heat exchanger valve logic), or as a minimum could have been included in Appendix C of the design criteria if a C/R had been written. Follow-up investigation found that the ERCW system Operating ' instruction 501-67-1, Appendix A, page I (reference 16) states that the valve goes to 55 percent open upon receipt of a safety injection signal. SI-566 (reference 17) data sheet 13.1, page i of 4, requires that the valve be reset to the 35 percent setting af ter conpletion of surveillance tests. ERCW Mechanical Logic Diagram 47W611-67-5, Rl2 (reference 18), was reviewed, and it was found that the logic will retain the valve at the at 35 percent open position upon receipt of a safety injection signal under the present system logic. Thus, alihough a C/R was not written, the requirement was designed into the plant. This concern about lack of a C/R was presented to the project by action item M-29. Upon conpletion of the review cycle for this concern, the project agreed to prepare a C/R for the requirement for 35 percent valve position for 0-FCV-67-152 and agreed to incorporate the valve position requirement into the ERCW design criteria test as a phase ll activity as corrective action for the specific concern. The general C/A and action to prevent recurrence of similar 7.6.4-3

events related to tire concern that C/Rs oe prepared and included in the design criteria are identified in Attachment I, item 2, of the Septenter il,1906 nmo from J. F. Cox to the SQEP Files (reference 19). This memo and its response which discusses coppletion of C/A (referenca 20) are discussed in detail in the section 5, TVA C/R Review and Evaluation. Five additional documents with mechanical discipline-related content which were assigned C/R status were also reviewed for acceptability including acceptable assigrwent of responsible discipline and correct assignment of key work / topic fields. All five of the items checked (references 21 through 25) were acceptable,

a. SQNMEBLWBl021 (reference 21) C/R for FSAR Section 10.5.5.5 deals with feedwater chemistry control. This is a design requirement and was correctly assigned to the Mechanical discipline.

b. SQNMEBLWBIO% (reference 22) C/R for FSAR section 10.4.8.2, paragraph 5, deals with a requirement for an additional SGB path, c SQIMEBLW81144 (reference 25) C/R for Section 5.5.1 of the Saf fey Evaluation Report (SER) supplement I deals witn a design requirement to provide runout protection for the SGB punps.

d. SQNMEBLWBil94 (reference 24) C/R for a muno from C. A, Chandley to R. W. Cantrell dealswiththesamesubjectsasreference22.

( l l e SQNMEBLWB1298 (reference 25) C/R for a memo from C. A. Chandlef to R. M. Pierce deals with SG8 pwp protection setpoint changes. l I One of the C/R review concerns applicable to all documents reviewed was training. This concern about the need for adequate evidence for the use of proper ly trained j inpell personnel to perform the sort of potential C/R documents was presented to the ! project by action item E-%. This action item is addressed in the Electrical review l of C/Rs.

2. Westinghouse C/R Review and Evaluation The Westinghouse review focused on source documents used by Westinghouse in identifying C/Rs for their part of the SQEP-18 (reference l} ef fort. These were reviewed and several were randomly selected to assess Westinghouse's efforts in identifying C/Rs. The review included (1) verifying the accuracy and conpleteness of the descriptive fields of the C/R data sheets (2) the training of Westinghouse personnel to SQEP-18, and (5) correct assignment of C/Rs to the affected design criteria (SQEP-29, (reference 2)).

Six C/R$ (references 26 through 51) were selected for review from the Westinghouse RHR (74) analysis report on the basis that they were excluded from the RHR (74) data base tracking sheet (SQEP-29, (reference 2) revision I, Attactonent 2], i.e., Westinghouse did not consider that these C/Rs were applicable to the RHR (74) design criteria (reference 32). Each C/R and its data sheet were reviewed. A conparison was nude between the C/R subject material and the topic list of the RHR (74) data base tracking sheet to see if the topic was duplicated. This provided guidance as to whether Westinghouse considered the topic inportant to the design criteria, the RHR i 7.6.4-4 l

design criteria (reference 32) was reviewed using NEP-3.2 revision 0, Attachment 2 (reference 33) to determine if the inforation was appropriate for inclusion in the design criteria, or covered in the design criteria. The f SAR and other reference documents were consulted as appropriate to verify that the selected C/Rs were properly assigned as not applicabit, to the design criteria. Five of the items reviewed (references 26 through 30) were acceptable for this attribute. One of the items which was reviewd (reference 31), das incit.,ded in the data base tracking sheet, but was found to be inadequately incorporated 'In the affected design criteria. This concern will be discuesed in section 3 (below), Design Criteria Review and Evaluatlon. Additionally, a concern raised by an NRC inspection tee. nenter, regarding confirmation that all Westinghouse " proprietary" C/Rs have been adequately incorporated in the SQN design criteria, was presented to the project by action item M-22. At the time the concern as written, there was no way to verify that the IVA l based design criteria preparers had fully considered the Westinghouse C/Rs. The project's corrective action was to obtain a statement from Westinghouse that all information included in the prop-letary C/Rs has also been reflected in l nonproprietary docur:ents. In addition, the project comnitted to replace references i to proprietary infora tion with nonproprietary references during phase 11. This rssolved the concern as it relates to phase I (prerestart) of the 084VP. An NRC l follow-up Inspecilon will review the status of this concern during phase il of the DB&VP (postrestart). ! a. C/R SQWESWl088 (reference 26) is an internal Westinghouse memo which discusses l procurement of thermi sleeves for two of the four RCS loops for the RHR/RCS interface connections. Review of this C/R included use of the RHR design criteria (reference 32), the RCS design criteria (reference 34), Westinghouse RCS flow diagram (reference 35), Westinghouse RHR flow diagram (reference 36), and the Westinghouse SIS flow diagram (reference 37) to determine adequate capture of the C/R for the RHR system design criteria (reference 32).

b. C/R SQNWESRJFl055 (reference 27) is a Westinghouse letter to TVA which transmits a listing of revisions to drawi%s. Although a C/R data sheet was prepared, it was not needed.

c. C/R SQWESRJF1015 (reference 28) deals with the addition of flow elenents l (orifices) for flow balancing of the centrifugal charging punp lines, safety l injection ptrrp cold leg, and safety injection pung hot leg injection lines (total I of 12 flow elements). The C/R was adequately captured in the af fected design criteria . Review of this C/R required the use of the SIS design criteria (reference 38) and the RHR design criteria (reference 32),

d. C/R SQWESRJF1086 (reference 29) deals with safety injection eximum resistances for flow paths (FL/01. The C/R was adequately captured in the SIS design criteria (reference 38).

e. C/R SQWESRJFil02 (reference 30) discusses the RHR flow for one of the RilR operation configurations. The RHR design criteria (reference 32) and the SIS design criteria (reference 38) adequately address this interface requirement.

7.6.4 5

f. C/R SQNWESPWil51 (reference 31) discusses " service water" requirements (fRCW and CCS systems) for the auxiliary heat exchanges of the RHR, centrifugal charging, SIS, and CCS punps. One item was applicable directly to the RHR system. This dealt with design pressure and tonperature for the " service water" side of RHR pump lube oil coolers. The concern that the RHR and related design criteria do not adequately address this topic was presented to the project by action item M - }0. This concern was arrived at af ter reviewing the way the support system (cooling water) interface was handled in the following documents: RHR design criteria (reference 32), or CCW design criteria (reference 7), and CCS flow diagram (reference 39).

The project's C/A for the concern expressed by action item M-30 was a conmitment to clarify the SIS design criteria text for this topic and resolve PlRSQNCEB8672 (reference 40 and punchlist item 7938) so that it addresses design criteria interfaces in a general way. Part B, Corrective Action, has not been assigned for this PIR. The concern has been addressed but is not closed for this reason, Refer to observation M) for additional discussion of this concern. A second major issue of the concern presented in action item M-30 is that interfaces between systems are adequately defined and addressed in the design criteria, in order to prevent future occurrences of this problem, the project conmitled to review the design criteria to see that adequate references of other design criteria is nede. This conmitment is noted in item 7 of the attachment to reference 20 and PIRSQNCEB8672 (reference 40) which is listed as punchlist item 7938. The C/A for this PIR is a phase 11, postrestart concern and has not yet been assigned. Follow-up verification review is required and is discussed in observation M). Four C/Rs (references 41 through 44) were selected for review from the Westinghouse RHR (74) analysis report on the basis that they were included in the RHR data base tracking sheet [SOEP-29 revision I, Attachment 2 (reference 2)] and have been incorporated in the RHR design criteria (reference }2). Each C/R and its data sheet were reviewed. A conparison was nude between the C/R subject material, the design criteria text, and design criteria appendices to confirm that the C/R was included in the design criteria text. SQEP-29 revision I (reference 2) and NEP-).2 revision 0, Attachment 2 (reference 35) were used as guidelines to determine where this infornution should be located in the design criteria, in addition design criteria were reviewed if referenced on the C/R data sheets for selected C/Rs to ensure adequate C/R capture. All four of the C/Rs selected (references 41 through 44) for the attribute "B" review performed for the Westinghouse C/R data base are adequately captured in the RHR design criteria (reference 32) and the RHR SYSIER, j

a. C/R SQNWESMWl001 (reference 41) suggests that dual range pressure transducers be provided for the RHR punps due to the narrow allowable range of pressures for the punp and seals. Since the letter was a suggestion and not a definite requirement and was not acted on or noted in the RHR design criteria (reference 32) text, it was determined that this C/R did not need to be applied to the RHR system.

b. C/R SQNWISRJFil48 (reference 42) discusses 100 percent radiography of the RHR punp pressure boundary and RHR minimtsn punp suction pressure (evaluation head or NPSH). The NPSit requirements were adequately addressed in the RHR design criteria (reference $2). The C/R was captured in the design criteria.

7.6.4 6

l

c. C/R SQlWESRJF1064 (reference 43) deals with transmittal of an SQN valve inventory sheet. The cross-reference of TVA and Westinghouse valve identification nunters was included in the RHR design criteria (reference 32). The C/R was captured in the design criteria.

d. C/R SQWESRJWl014 (reference 44) deals with the RPS l&C channel assignments for RCS, CVCS, RHR, SIS, and other systems. The information was included in Appendix C of the RHR design criteria (reference $2).

Approximately 30 Westinghouse C/R source documents were screened for potential C/R candidates. Five C/R source docunents (references 45 through 49) were randomly selected from this field of 30 Westinghouse proprietary C/R source documents. Each of the five selected source documents was reviewed to determine specific potential C/R contents / topics. These source documents and topics were conpared with the C/R analysis reports (conputer lists of C/Rs for the systems affected by the potential C/R) to determine if both the topic and docunent were captured in the C/R data base (SQEP-18 (reference 1)] and to confirm that the C/R data sheets were adequately filled out. Four of the documents selected (references 45 through 48) were captured in the C/R data base. One docunent was not captured (reference 49). The concern about omission of this C/R source docunent frun the C/R data base was presented to theprojectinactionitemM-28. The five C/Rs and concern are discussed below. l

a. C/R SQlWESRJFil)2 (reference 45) on RHR heat exchanger parametric data was captured adequately in the C/R data base,

b. C/R SQlWESRJFil61 (reference 46) on RHR mininun flow instrunentation was captured adequately in the C/R data base.

l

c. C/R SQlWESRJFil0) (reference 47) on SIS test acceptance criteria was captured l

adequately in the C/R data base. I

d. C/R SQNWESRFJ1066 (reference 48) on [Q requirements for existing plants was captured adequately in the C/R data base,

e. SD/SA-TV-468 (reference 49), Westinghouse (proprietary) source docunent internal meno, deals with hydraulic design requirements for the SIS cold leg accunula tors, ihls C/R source document was not captured in the C/R Data Base.

The concern about capture of this potential C/R was presented to the project in actlon item M-28. Af ter discussion of this C/R concern with Westinghouse, a C/R data sheet was prepared for the Westinghouse docunwnt (reference 49). Additional progranmatic C/A was comnitted to by the project in J. F. Cox's mmos to the SQlP Files dated Septenter ll,1986 (reference 19) and Decenter 3,1986 (reference 20). the latter memo represents the project's overall corrective action to deficiencies in the C/R and design criteria ef fort that was covered by a large nunter of EA action items, this meno is suf ficiently extensive to be covered in section ), IVA C/R Review and Evaluation (below). 7.6.4-1

r An additional selection of C/Rs with Mechanical involvement was made to v:rif y Three C/R (references 30, 50, correct assignment in the C/R data base system soris. and 51) fran the System 999 (applies to all systems) C/R sor1 were selected. Additionally five C/Rs (references 47 and 52 through 55) were selected for s.milar verification of system assignment to several of the mechanical systems. Seien of tho l eight C/Rs (references 50, 47, and 50 through 55) were verified as meeting the SQEP-18 (reference 1) requirements. One C/R data sheet (reference 47) was not adequately prepared with regard to the assignment of the data fields and topic fields This concern was presented to the project by action item on the C/R data sheet. l M-)l. Upon review of this concern with the other disciplines and further review of mechanical-related C/R data sheets, several additional inadequately filled out C/Rs l were noted (references 46, 51, and 5$ through 60). A similar concern was also i presented by action item M-14. Action item M-14 is discussed in section 5, ivA C/R ! Review and Evaluation (below).

a. C/R SQlWESRJFI)Si (reference 50) is a Westinghouse interof fice memo which provides the SQN active valve list with valves noted by their Westinghouse identifications only. Several of the valves were confirmed to be properly identified in their respective design criteria. The capture of the C/R is considered acceptable against all systems (C/R data sheet system field code 999).

b. C/R SQlhESRJFl575 (reference $1) deals with the Westinghouse standardized technical specifications and included a tabulation of references for support of I

data in the SQN technical specifications. The capture of the C/R is considered acceptable against all systems (999).

c. C/R SQlMESRJFil02 (reference 30) deals on operating configuration of the RHR system for one RHR pop supplying two CCPs and two safety injection pugs simultaneously during the recirculation phase of containment recovery. The C/R is adequately identified in the RHR design criteria (reference 32) and the CSS design criteria (reference 9).

d. C/R SQlNESRJFl)92 (reference 52) discussed design studies for the location of the RHR branch from the RCS to a new location. The C/R was captured and properly assigned in the data base,

e. C/R SQIMESRJFI)95 (reference $3) includes technical data on SIS pug NPSH from the RWSi, additional CSS norries, Boron injection delay times, and a general review of the ESF systems layout. The capture of the C/R was acceptable, j f. C/R SQlWESPPfl004 (reference 54) discussed the stress analysis of J-norries for i

the feeding in the steam generators. The C/R was captured and properf y assigned l in the data base.

g. C/R SQlWESBJBil% (reference $$) deals with the Westinghouse feedwater line cracking final report. The C/R was captured in the C/R data base. There were several deficiencies in the assigrment of data fields on the C/R data sheet, this concern was presented to the project by action item M 51. Olscussion of that follow in the section on reviewed IVA C/Rs.

h. C/R SQlMESRJFil0) (reference 47) deals with $15 test acceptance criteria. The C/R was captured in the C/R data base f rom the source document. Several of the C/R data fields were not properly assigned on the C/R data sheets. The concern presented by action item M-51 is discussed in the section on IVA C/R review which follows.

7.6.4 0

). TVA C/R Review and Evaluation the TVA review focused on verifying the adequacy of the identification of sources to ensure all sources needed to capture the C/Rs were identified by SQEP-18 (reference 1). C/Rs from the licensing docunent sources identified in Attachment I of SQEP-18 and other C/R sources, such as vendor letters, correspondence files, and system design files, were selected and checked against C/R data base to verify C/R data sheets had been prepared and captured. The C/R sheets were reviewed for cogleteness of the key word descriptive fields. In addition, training of the senior people was checked. Finally, C/Rs which were candidates for a licensing conmitment change were reviewed to ensure the correct determinations were nude by the branch. Approximately 60 TVA C/R source documents were screened for potential C/R candidates. Twenty-two C/R source docunents (references 54, 55, and 61 through 80) were randomly selected from this field of 60 TVA C/R source documents. Each of the 22 selected source documents was reviewed to determine specific potential C/R contents / topics. These source documents and potential topics were conpared with the C/R analysis reporis (computer lists of C/Rs) for the systems affected by the potential C/Rs to determine if either or both the topic and document were captured in the C/R data base [SQEP-18 (reference 1)] and to determine whether the C/R data sheets were adequately filled out, in the process of reviewing these C/Rs, concerns were raised about the adequacy of the C/R process and specific concerns about the technical content of some of the C/Rs. One of the 22 C/R source docunents reviewed was not captured (reference 80). The concern about the failure to capture this C/R source docuent in the C/R data base was presented to the project by action item M-14. The programnatic concern that the SQEP-18 (reference 1) procedure did not address ongoing identification of C/Rs andtheadditionofthesetotheC/Rdatabasewaspresentedtotheprojectbyaction item M-l. Specific technical problems with C/Rs that were determined to be captured but not adequately addressed in the C/R data base were presented to the project by action items M-ll. -12, and -15. A concern regarding adequacy of the training of personnel preparing the C/R$ to the procedure for doing this work was presented to the project by action item E-II. Following is a brief summry of the C/Rs reviewed:

a. C/R SQNMEfWAl)$6 (reference 64) deals with the minimum required ERCW flow to the CCS HX concurrent with the nuximum ERCW tenperature in the C/R data base.

However, the data tields for the C/R data sheet were not adequately assessed, ihls concern was presented by action item M-14.

b. C/R ScalWESPPfl004 (reference 54) deals with the steam generator feeding "J" nottle stress analysis and was acceptably captured in the C/R data base,

c. C/R SQNWE50JBil56 (reference $$) deals with the Westinghouse feedwater line cracking final report and was acceptably captured in the C/R data base,

d. C/R SQNM(RRGMl021 (reference 65) deals with Class 1(E) electrical requirements for the IRCW traveling screens and was acceptably captured in the C/R data base.

e. C/R SQNNEBHfMl048 (reference 66) deals with the addition of a fine delay requirement for radiation nonitors. The C/R was acceptably captured.

7.6.4-9

f. C/R SQNEEBP9 Nil 47 (reference 67) deals with the steam line break tageratures for qualification of essential equipnent in the steam valve vaults and auxiliary feedwater pwp turbine rooms. The C/R was acceptably captured,

g. C/R SQNMEinMAll22 (reference 68) discusses Class IE requirements as they apply to the ERCW screen wash system. The C/R was acceptably captured.

h. C/R SQNNEARSM)001 (reference 62) discussed nodification of the chemical feed lin connections to the feedwater system to meet contaironent isolation requirements.

The C/R was captured in the C/R data base; however, the C/R data shoot fields were not adequately assigned. This concern was presented to the project by action M-14 and is discussed in detail below.

l. C/R SQNNEBRSM3220 (reference 69) discussed an SIS Train B flow deficiency noted in an NCR. The C/R was acceptably captured in the C/R data base.

J. C/R SQNME8bMAlll5 (reference 70) identifies heat tracing requirements for the ERCW punping station. The C/R was acceptably captured.

k. C/R SQfetEBJLFl244 (reference 61) defines a requirement that only pressure fire retardant treated wood can be used in safety-related areas of the plant. The C/R was acceptably captured.

l. C/R SQNNEBFAKl026 (reference 71) notes that radiation monitoring of the ERCW effluent is required. The C/R was acceptably captured.

m. C/R SQletEHbMAIO98 (reference 72) notes the discussion of the conmitment to meet the G0Cs 2, 44, 45, and 46 for SQN. The C/R was acceptably captured,

n. C/R SQIMEinMAl099 (reference 73) was written to note ERCW operational requirenents during adverse conditions, the C/R was acceptably captured.

o. C/R SQNMEinWAlll0 (reference 14) discusses the mechanical conponent codes and IVA safety classifications of safety systems conponents such as piping and valves.

The C/R was acceptably captured.

p. C/R SQNMEleMA1096 (reference 63) discusses the requirement for an adequate water level at the (RCW punping station intake structure during adverse conditions.

The C/R was acceptably captured,

q. C/R SQNMEBRGMl018 (reference 75) discusses the requirement to monitor the flows through the ERCW strainers for excessive pressure drop. The C/R was captured acceptably,

r. C/R SQNMEftMAll08 (reference 76) discusses the results of a study of the ef fects of raw water on carbon steel piping and reconmend upgrading to stainless steel piping wherever possible. The C/R was acceptably captured.

s. C/R SQNCER-CGil41 (reference 77) discusses the requirement to analyte the ERCW Intake punging station for danuge due to a postulated barge impact. The C/R was

- acceptably captured. 7.6.4-10

t. C/R SQlMEBJtFl}00 (reference 78) discusses power cable separation requirements for the ERCW puping station. The C/R was acceptably captured,

u. C/R SQNMf 8tW81206 (reference 79) discusses the need to control the min steam valve vault environmental tenperature to 80*F to 120'F in order to minimite nuin steam safety relief valve setpoint drif t. The C/R was acceptably captured.

v. DES 840109 006 C/R source document (reference 80 discusses a design study related to the requirement to mitigate / minimize cavitation of ERCW throttling valves.

The C/R was not captured in the C/R data base. The concern about failure to capture this C/R in the C/R data base was presented to the project by action item M-l). Theprojectrespondedtothisconcernbynotingthatoneoftheeffectsof the ERCW study (reference 80) was to cause a revision in the design guide for raw water piping systs calculations (reference 81) to require that the potenflat for cavitation be checked in future design calculations. The project concluded that no C/R was required since there are documented requirements for consideration of cavitation in the design guide. Additionally,theprojectnotedthatadesign change request (DCR 2170) has been initiated to correct cavitation erosion problems in the ERCW system. The inmediate concerns about cavitation / erosion danuge in the ERCW System are considered by the project to be a nuintenance probitm. The EA Mechanical reviewer considered the inclusion of the cavitation requirement in the design guide as acceptable to address the captare of the design requirement. Since a design guide included the requircrnent, no C/R was considered needed. This concern was adequately resolved. The concern that the C/R data sheet topic fields be correctly assigned for each C/R was presented to the project by action items M-14 and M-)l. Nine C/Rs were identified in M-)I (references 46, 51, and 55 through 60 and 82) and six additional C/Rs from other disciplines were identified in action item M 14 (references 61 through 6) and 8) through 85). In the opinion of the reviewer, each of these had inadequately filled out data sheets. As noted in SQEP-18 (reference 1) and SQEP-29 (reference 2), the C/Rs and the resultant C/R data base were to be sorted for use by the design criteria preparers. Proper sorting of the C/Rs included in the data base depends on the conpleteness and adequacy of the date that is coded on the C/R data sheets. The project provided C/A for three action items in both a direct and indirect way. On the direct action C/A, the following referenced C/R data sheets were revised: References 30, 34, 44, 46, % through 61, 6), 68, and 84 through 86. It was agreed that references 59, 83, and 84 did not require revision. The indirect progranstic C/A was ccrnnitted in the September menn frcrn J. F. Cox inemo (reference 19). Item ) of the nuxno notes that a sanple review of the C/R data sheets would be nude to verify their adequacy. The response to this memo (reference 20) will be discussed in a separate item below. An EA verification review of project's progranutic C/A (reference 20) was nude and documented in the closure of the concern that was presented by action item M-14. Basically, the key word field assignments were found to be in need of further review and revision, but this is a largely subjective evaluation since there is no level of independent review in the issue of C/R data sheets. Also, no evidence was noted of failure to incorporate C/Rs into the affected design criteria due to the lack of the fully adequate key word fields. The basisforclosureoftheconcernsthatwerepresentedtotheprojectbyactionitems M 14 and M.)l 15 related to adequacy of C/R data sheet key word fields and adequacy of the design criteria which were subject to separate EA verification review and evaluallon. 7.6.4-11

The concern that the C/R procedure, SQEP-18 (reference I) does not address ongoing identification and utilization of new C/Rs which are generated af ter the initial C/R effortwaspresentedtotheprojectbyactionitemM-7. Theproject'sC/Aforthis concern is addressed in the following two areas:

a. The project coninitted to systenutically review all of the C/Rs not included in the original C/R data base sorts. This is recorded in item 4 of the attactsnentAn to reference 19. The results of this review are docunented in reference 20.

EA verification review of the project's C/A was nudo and is described in detail in the closure of the action item. The EA verification review sanple consisted of seven of the project's 76 C/Rs involved. The conclusion of the review is that the new C/Rs are being added to the data base and distributed for review for possible inpact to the design criteria in an acceptable way.

b. The project conmitted to revise SQEP-18 (reference 1) and SQEP-29 (reference 2) to include provisions for issuing new C/Rs and nuking sure that they are properly reviewed for incorporation into the design criteria. This conmitment is recorded in D. W. Wilson's January 12, 1987 none to R. C. Denney (refert.nce 87). As noted in the memo, this is not a restart requirement. Verification of this C/A will be done as a part of the phase il efforts. Based on the project's phase ll (postrestart) cmmitment to bring up to date the C/R data base and the defined C/A for a SQEP-18 procedure revision, this concern was adequately resolved..

The concern about omission of a potential C/R from the C/R data base and inadequate incorporation of the C/R into the af f ected design criteria was presented to the project by action item M-II. Specifically references 88 through 94 were reviewed to determine whether a C/R was needed to address the thernal load range (minimum and For C/A, nuxinun tenperatures) in the design of Auxiliary Feedwater System piping. the project to coninitted revising the auxiliary feedwater design criteria by issuing a DIM to explain or docunent the dif ference between the auxiliary feedwater minimum design tenverature of 40* and the ERCW backup water supply minimum design tenperature of 35'F. The project did not agree to issue a C/R for thernal load range, but did by issue of a DIM (reference 5) which incorporated adequate infornution. A concern that a C/R which was not prepared for dealing with the station blackout (total loss of AC power) as it af fects the Auxiliary Feedwater System (reference 95) The project responded to this was presented to the project by action item M-12. concernbyprovidingsufficientjustificationstoshowthattheblackout considsration was only considered so that alternate nntive power would be provided for the auxiliary feedwater pmps (i.e., AC power and design criteria control / steam power), EA review confirned that the auxiliary feedwater design criteria (reference 5) did include provisions for this design requirement which resolved this concern. While performing a verification review of the project's C/R C/A ef fort (documented in reference 20) an unaddressed concern listed in a supporting menn (reference %) was j identified, this concern is that C/R data sheets for systems nuntered higher than System 99 (i.e., in the system assigruent or af fected system's listing on the C/R data sheet) nuy not be captured in the design criteria. There was no infornution available to indicate that this concern had been addressed by the project in its C/R program suntrary nono (reference 20). This concern was presented to the project by action item M-46. Theprojectsresponsetothisconcernwastorequestinputfrom I 7.6.4-12 s - - - - - - - - - - - - _ _ _ _ _

the branches who prepared the C/R data sheets on how they addressed the system assigrunents on review of C/Rs for design criteria preparation (reference 97). The project collected responses to this concern from each of the involved disciplines as input to its C/A (references 98 through 101). C/A for this concern required the parts as follows:

a. For unit 2, six design criteria were identified as needing revision of DIMS to add the applicable C/Rs to the affected design criteria. This was considered to be a phase I (prerestart) item. Verification of this item is discussed in observation M).

b. For unit I and to prevent reoccurrence of this concern, the project has comitted to revise SQEP-18 and SQEP-29 (references I and 2) to provide clear direction on handling PIRs on the punchlist. This comitment is being tracked as punchlist item 9421.

This C/A was acceptable to resolve the concern but follow-up verification is needed for both parts of the C/A. This concern has been included in otnervation M).

5. TVA Desian Criteria Review and Evaluation A review of selected design criteria prepared by TVA and by Westinghouse per SQEP-29 was performed to ensure that all appropriate licensing conmitments and design requirements were included and that the document technically addresses its subject.

This review also focused on basic technical adequacy in areas such as hydraulic design requirements, application of industry codes and standards, agreement with licensing documents such as the FSAR and SER and adequate consideration of separation redundancy and diversity requirements as they apply to mechanical systems. The design criteria which were reviewed and the concerns associated with each of them are discussed below. Auxiliary Feedwater System Deslan Criteria (Reference $) The following concerns were noted during the review of the design criteria.

1. Inadequacies in the use of the C/R data base tracking sheets and inclusion of C/Rs in the design criteria.

2. Inadequate consideration of interfaces in the design criteria text. Exangles include: ERCW/AfW design tenperatures are different and interface / operability of local AFW flow control valve during station blackout (supply of auxiliary air).

5. Testing requirements for major conponents such as flow control valves.

4. Fluid /hydraulle design requirements such as NPSH.

5. Thernal design requirements related to piping daign.

A general sunmary of these concerns was presented to the project by action item M 17. 7.6.4 15

n the concern about C/R data base tracking sheet inadequacies was addressed from two view points. First, several of the items listed on the C/R data base tracking sheet were considered by the reviewers inportant enough to have been discussed in the design criteria text. This concern was presented to the project as part A of action item M-17. The project's response to this concern was to present an acceptable justification for not including sane of the items listed. Follow-up action for those items related to system interfaces was assigned for consideration in phase 11 of the DMVP (postrestart) and are to be handled as a pari of the C/A to PIRSQNCfB8677 (reference 40) punchlist item 7918. This PIR is discussed in the project's C/R design basis C/A memo from John Cox dated Decwter ),1906 (reference 20), this concern was adequately resolved. Follow-up verification for this itan is noted in observation M). Secondly, concern about the interpretation of and application of appendices to the design criteria which included exhaustive listings of C/Rs was presented to the project in action item M-24. The project's C/A for this concern was to issue Dims to l the af fected design criteria (references 102,10), and 104) to clarif y the use and i interpretation of the C/R listing for potential users of the design criteria. These DIMS were reviewed by EA and the project's C/A was determined to be acceptable, i f The concern about inadequate consideration of interfaces in the design criteria text waspresentedtotheprojectinpart8ofactionitemM-17. this concern was related to several specific technical areas which had specific action items related to them. The auxiliary feedwater/ERCH minimum interface tenperature was presented to the project in action item M-II. The concern was addressed by the issue of a DIM for the auxiliary feedwater design criteria (reference 102). The DIM was reviewed and EA found that the concern had been adequately addressed. This concern was resolved by the issue of the OlM. i The concerns about requirements for control of auxiliary feedwter flow during a station blackout and cool down and were presented to the project in action item M-12. The project's justification that the current design is acceptable is incluced in its response to action item M-12. On further review by EA, it was determined that the project's response was technically acceptable but not required to be incorporated in the design criteria text. The project's ccanitnent to review design criteria references [itan 7 of attachment I (reference 20) and PIRSQNClB8672 (reference 40) punchlist ltom 7938). Follow-up verification of C/A for this PIR is noted in observation M). The concern that testing requirements of auxiliary feedwter corrponents (other than pmps and drives) was not adequately discussed in the design criteria text was presentedtotheprojectinactionitemM-17,partC. The project responded to this concern by providing a technical justification for deviating from the guidelines provided in the project procedures. Basically, since this concerned design criteria which were being prepared af ter conpletion of the design, the equipnunt procurennnt specifications (which normily follow the design criteria in normt design process) were considered adequate to contain this type of inform tion. Therefore, it was not

 ~

felt necessary to duplicate that inforation in the design criteria text. Ihis i response was adequate to resolve this concern. The concern that fluid hydraulic design requirenents were not adequately discussed in the design criteria test was presented to the project in action itom M-10. The project's C/A was to issue a OlM (reference 102) to add appropriate language to the design criteria text. This was acceptable action to resolve the concern. 7.6.4-14

Ihe concern that thermal design requirements (thermal load range mininese and maximum espected operating tenperatures) were not adequately discussed in the design criteria text was presented to the project in action item M-15. Theproject'sC/Aforthis concern was to comnit to issuing a DIM for the design criteria to add insulation requirements and operational podes analysis references. This C/A is scheduled as a phase 11 postrestart activity. This C/A was adequate to resolve the concern. Containment Sprav System Deslan Criterla (Reference 9) The containment spray system design criteria (reference 9) was reviewed. A concern relating to inconsistencies between the design criteria and the flow diagram (reference 105) and other design documents for the design tenperature of the portion of piping inside containment. The concern presented to the project in action item M-47 noted that while the design criteria and flow diagram indicate a design tenperature of Il5 F, 0 the operating modes calculation (reference 106) and FSAR Figure 6.2.1-22 (reference 107) Indicate that tenperature considerably higher, up to 1600 F nuy be possible during certain modes of operation. This concern is also discussed in CAQR SQEB70R01005. Cr=aanent Coolina Water System Desian Criteria (Reference 7) The following concerns were identified during the review of the design criteria:

1. Fluid / hydraulic requirements such as NPSH.

2. Westinghouse proprietary C/Rs.

5. Applicable codes and standards such as ASME ANSI.

The concern about the omission of fluid / hydraulic requirements was presented to the project by actic,n item M-18. The project response was to add required requirements to the design criteria by C. A. Chandley's meno (reference 100). This concern was adequately resolved. l The concern about Westinghouse proprietary C/Rs was presented to the project by f action item M-22. See section 2, Evaluation of Westinghouse C/Rs, for a discussion I of this concern. This concern was adequately resolved. The concern about the omission of codes and standards was presented to the project by I action item M-26. The project response stated the codes and standards arn referenced in the procurement specifications of the major equipnent. Since the procurements specifications are referenced in the design criteria, this design criteria meets the requirements of SQEP-29. this concern was adequately resolved. An additional concern, outside the scope of the 084VP, identified by the NRC, related to the conponent cooling surge tank baf fle. As discussed in action item M-45, although the CCW design criteria (reference 7) described this feature as providing safeguards train separation and as required for NPSH of the conponent cooling ptmps, no evidence of preservice or inservice ASME XI testing could be found. Project performed calculations (references 109 and 110) which indicate that the baf fle is not required for WPSH but is necessary to ensure an adequate supply of makeup water for each train. Project comnitted to performing a prerestart leakage test as well as periodic inservice tests (at least once every ten years) as well as revising the CCS design criteria appropriately. Preparation of the test procedures and revision of the design criteria have not yet been conpleted as discussed in observation M5. 7.6.4-15

i During the review of the CCS design criteria SQN-0C-V-l).9.9 (reference 7) and FSAR section 9.2 (reference lil), a concern was identified. The concern is that heat loads listed in the CCS design criteria are dif ferent than the heat loads listed in the FSAR. This concern was presented to the project in actic,n item M-45. ihe project has agreed to revise the FSAR as a postrestart activity. This concern was adequately resolved and is discussed in observation M5. Essential Raw Water Coolina System Desian Criteria (Reference 6) The following concerns were identified during the review of the design criteria:

1. Onission of stress input information.

2. Onission of C/Rs from the design criteria.

5. Use of the phase "specified exceptions" without specifying the exceptions.

The first concern was presented to the project by action item M-15. Theproject agreed to issue a DIM to add the stress input inforation to the design criteria during phase ll of the prograns. This concern was adequately resolved. The second and third concerns were presented to the project by action item M-16. The project agreed to add the omitted C/Rs which related to Appendix R conpliance and not to Chapter 15 events to the design criteria during phase 11. Theprojectdeletedthe phase "specified exceptions" frcrn the design criteria. This concern was adequately resolved.

Containment isolation System Deslan Criteria (Reference 8)

Containment Isolation Systan design criteria (reference 8) was reviewed. No exceptions are listed in section 8 " Exceptions" but exceptions to leakage testing provisions are discussed in section 7. This concern was presented to the project by action item 0-17 which is discussed in the Operations reviews. Prograrmatic issues for C/R and Desian Criteria Processes A suf ficiently large nmber of concerns were idontified in the course of review of C/Rs and design criteria that the project agreed to group these concerns and provide a uniform project-wide C/A program. This C/A program is sumerized in reference 19. The results of that program were presented by the project in reference 20. The project's actions listed in the nwo were reviewed against the concerns in individual actioa itoms. The collection of the results of these reviews was sunarized in section 7.6.2. In the process of performing this review, it was noted that the project could have done a better job docunenting the work that was done for this C/A. In particular, such of what was done to support the project's conclusion is available only in infornal documents and working files. In general, it is expected that the supporting mterials would be CA records (i.e., in RIMS, but not necessarily QA (multisignature) documents) that would be available for review at any time. 7.6.4-16

l l 1.6.4.2 Conclusions The Mechanical discipline of the EA Team performed a thorough technical review and evaluation of the licensing comitment/ design requirement and design criteria docisnentation process. TheresultsoftheEAreviewcoupledwiththeproject'sC/Asand l responses to observation M) and CAQR SQE870R01005 support the conclusion that the C/Rs and design criteria are technically adequate to support the SQN unit 2 restart. 7.6.4.5 References , issue f Revision Date Title Reference Document j 0,1 7/9/86 Procedure for Identifying Conmitmen15 and i SQEP-18 Requirements 0,1,2,5 2/l}/87 Procedure for Preparing the Design Basis for 2 SQEP-29 SQN (825 070216 016) RD80 -- 12/4/86 Restari Design Basis Document (826 861210 006) 5 0060-571-PI-I O 4/14/86 inpell Project Instruction for Design Criteria ! 4 identification and Documentation 7/11/86 Auxillary Feedwater System (58) Design Criteria 5 SQN-0C-V-15.9.8 0 including DIMS I, 2, and 5. (844 870227 016, 844 870125 004, 844 860905 001, and 805 860721 518) 2 7/II/86 Essential Raw Cooling Water System (67) Design j 6 SQN-0C-V-7.4 Criteria l 7/11/86 Conponent Cooling Water System (70) Design 7 SQN DC-V-15.9.9 0 Criteria including DIMS I, 2, and 5 0 6/16/% contaltunent isolation System (88) Design 8 SQN-DC-V-2.15 l ' Criteria 9 SQN-0C-V-27.5 0 7/}0/06 Contalrunent spray System Design Criteria System (72) NA 6/1/8) IVA Letter from Green to O'Reilly 10 L51 830526 822 1 ll No RIMS Natier NA 6/9/75 TVA Memo from Chandler to Files - NRC Exit Assigned Meeting 12 L5I d21020 896 NA 10/20/82 IVA Letter from Green to O'Reilly - LER

                           --                 --     9/21/8)     TVA Letter from Green to O'Reilly -

15 Surveillance fest 14 L51 810902 890 -- 9/2/81 TVA Letter to NRC NA 8/26/85 IVA lotter to NRC- Follow-up on Reference 14 15 SS) 850823 919 7.6.4-ti

lssue Reference Document Revision Date Title 16 501-67-l 27 II/14/06 ERCW System 0perating Instruction Appendix A, Page i 17 SI-566 15 9/}/% ERCW Surveillance Operating instruction Data Sheet I).1 18 47W6tl-67-5 12 4/2/85 ERCW Mechanical Logic Diagram t 19 B25 860911 012 NA 9/11/86 Meno from J. F. Cox to SQEP Files 20 B25 86120) 019 NA 12/3/06 Meno from J. F. Cox to SQEP Files 21 SQNME8tW81021 1 5/5/80 C/R for FSAR Section 10.).5.), Feedwater ! Secondary Chemistry (844 860619 042) 22 SQNME8tW81056 0 -- FSAR Section 10.4.8.2 Paragraph 5, Steam Generator 8 lowdown Flow Path (844 860508 019) ! 25 SQWE8LW81144 0 -- SER Supplement i Section 5.).I - SG8 Pep Runout Protection (844 860509 067) 24 SQWE8tWBil94 0 -- Addition of SG8 Pwp Runout Protection (844 860512 017) 25 SQNME8tW81298 0 -- Pep Modification and Setpoint Changes (844 86051) 016) 26 SQNWESWl088 0 5/6/06 Thermal Sleeves for RHR/ SIS Norrie in load Logs 27 SQWESRJF1035 0 4/28/86 RHRs Process Flow Olagram l 28 SQWESRJF1015 0 4/25/86 SIS Flows and Tenperature Sensors 29 SQWESRJFl006 0 5/5/06 ECCS Piping Resistance Criteria 30 SQNWESRJFil02 0 5/3/86 Mininun RHR Containment Spray Flows l I 31 SQWESWil51 0 5/15/86 Service Water System Design (Mechanical) I Condition 32 SQN -DC-V-27.6 0 7/21/86 RHR Design Criteria System (74) i

                                                   ))    NE P-3.2             0     7/1/86      Design input 34    SQN-0C-V-27. 4       0     7/2)/86     Reactor Coolant System 0esign Critoria
                                                   $5     ll0E324,           10     --          Westinghouse Reactor Coolant System Flow Olegram Sheet I l

l 7.6.4-18 l l

issue Reference Doctanent Revision Oste Title , 56 Il0E552 9 -- Westinghouse Residual Heat Removal System flow Diagram 57 Il0E 558, -- -- WestinghouseSafetyinjectionSystemFlow Sheet i Diagram 50 SQN-DC-V-27.5 0 7/24/06 Safety injection System Design criterla 47WB59 7 -- CCS Flow Olagram 39 40 -- -- Punchlist item 7958 for Design Criterla PIRSQNCE88672 Interfaces (825 861008 008) 0 5/8/06 RHR Wide Range Pressure Measurement 41 SQWESWl081 ! 0 5/5/86 RHR Ptsp - NPSH 42 SQWESRJFII48 l 45 SQWESRJFl064 0 5/5/06 Sequoyah Valve List 44 SQWESRJFl014 0 4/25/86 14C Channel List 45 SQWESRJFil52 0 5/5/06 RHR Hx Parametric Data 46 SQWESRJFII61 0 5/5/86 RHR System 0rifice l l 47 SQWESRJFil05 0 5/5/86 SIS Test Acceptance Criteria 48 SQWESRJFl066 0 $/5/86 Quality of Stem Mounted Limit Switch 49 $0/SA-TV-468 N/A 9/8/87 Westinghouse Proprietary Memo file TVA 200 0/1 on TVA Safety injection System Cold leg Paraneters

                                                                 $0      SQWESRJFl551                                           0       5/15/06    Active Valves 0       5/15/86     Standard Technical Specification valves -
                                                                  $1      SQWESRJFl575 Calculation 0       5/12/06     RHR Ptsp Spray Connect 100 Poinis 52      SQWESRJFl592 55      SQWESRJFl595                                           0      5/12/06 Safeguards Systems Performance 0       4/29/06    J Nonle Stress Analysis 54     SQWESPPfl004 0       5/16/86    Final fee 4 eater Line Cracking Report 55      SQWES8JBil%

56 SQWESRJFl019 0 5/2/86 SafetyinjectionSystemActuation 0 5/2/06 Contaltenant Spray Ptsp Start Time 51 SQWESRJF1021 7.6.4-19

issue Reference Docunent Revision Date Title 0 5/6/06 Reactor Vessel Vent System Layout Guidelines 58 SQNWESMWl094 and Interface Criteria 59 SQNMEBLW81289 0 5/12/06 Feedwater Tenperature and Pressures for Operation (844 860515 052) 60 SQNEEBElll058 0 5/6/86 Mininsn Size for Power Cables Above 600V is #2/0A (825 861205 100) 61 SQIf(8JLF1244 0 5/14/86 Determine Action to be Taken for Containment Isolation Valves (844 860515 056) 62 SQNNE8R$M)001 0 5/12/06 Modification of the Chemical Feedline Which Connect to the Auxiliary Feedwater and Main Feedwater System for Containment Isolation (845 860515 991) 65 SQNME8WA1096 0 5/10/86 ERCW Review of System to Acconmodate Flood Levels and Downstream Dam Failure ! (844 860512 279) 64 SQISEBWAI)% 0 6/9/86 System Heat Load and Flow Requirenent (844 860902 786) ! 65 SQNMl8RGMl021 0 5/15/86 ERCW Traveling Screen Classification I (844 860515 000) 66 SQNNE8HEMl048 0 5/9/06 Modifications of Radiation Monitors Due to Spurious Contaironent Ventilation Isolation (845 860509 218) i 67 SQNLEBP8 Nil 47 0 5/10/06 Replace Steam Generator Pressure fransmitter and Disposition other Devices which are not Qualified for Valve Room (845 860512 816) 68 SQNMEBWAll22 0 5/10/06 ERCW System - Seismic Qualification of Screen Wash Punps, Piping, and Associated Equipent i l (344 860512 276) 69 SQNNE8R$M5220 0 5/16/06 SafetyinjectionSystemforDeficiency Corrected by RHR Heat Exchanger Valve Position (844 860516 659) 70 SQlWHWAlll5 0 5/10/86 ERCW System Heat trace and Freeze Protection Requirement (844 860512 265) 7.6.4-20

lssue Reference Document Revision Date Title 0 5/12/% Comnitment to Evaluate Moving the ERCW 71 S@NEBFAKl026 Radioactive Liquid Effluent Monitor (845 860512 893) 0 5/10/06 ERCW Acceptance of ERCW System to Requirement 72 SQNMEllWA1098 of GDC 2, 44, 45, and 46 (B44 860625 000) 0 5/10/86 ERCW System Operation Accident (B44 860512 248)

1) S@MEBWAl099 0 5/10/86 ERCW System Design Codes and Standards 74 SQNMEBWAlll0 0 5/l}/06 ERCW System Auto Backwash Strainer Pressure 75 S@MEBRGMl018 Orop (844 86051) 076) 0 5/10/06 ERCW System Corrosion and Organic Fouling 76 SQNME8 Wall 08 Requirements (B44 860625 009) 0 5/11/86 Barge Collision into intake Pumping Station:

77 $@CEB-CGil41 ERCW PS and Explosion Hazards i' 78 SQNMEBJLFI)00 0 5/8/06 Fire Protection Modification and Schedule for Unit i Train A and B Cable Roroute (844 860512 146) 0 5/12/06 Main Steam Valve Room Environmental Tenperature 79 SQNMEBLWBl206 Requirements (844 860512 029) l -- TVA Memo 80 DES 840109 006 1 6/3/06 Mechanical Design Guide for Raw Water Piping 81 OG -M6. 3. ) System Calculations 5/6/06 IPCEA P-46-426 Power Cable Mpacities, Volume I 82 SQNEEBElll024 0 f

                                                           - Copper Conductors (825 06l205101) 0       6/4/%        Provide Control Power Supply to the Auxiliary

8) SQNEE8Elll206 feedwater Turbine-Orive Pop Independent to that of Motor-Driven Punp (B4) 860606 939) 0 5/l8/06 ERCW System Corrosion (B44 86051) 015) 84 SQNMEBRGMl011 0 5/11/86 ERCW Pe p Motor Relay Change Range 85 SQNEEBDRWl079 '

(84) 860512 852) 0 $/16/06 Neutral Ground Relay Scheme on Unit Station 06 SQNEEBElll200 Service, Reserve Station Service and Cumnon Station Service Transformers (84) 860516 852) 7.6.4 21

issue bwision Date 7itte Reference. Document _ 1/12/87 Memo from D. W. Wilson to R. C. Denney on 87 825 870ll3 027 - SQN-Engloyee Concerns Task (Group ECTG) Element Reports - Report 215.03 SQN-Review and Corrective Action Plan Revision i

                                         --        --            On Auxiliary Feedwater Piping 88       NCSQNCE8812) 89                             --        --            On Safety injection Piping NCRSQNCE98305 DES 84070) 019       --        6/29/84       J. P. Darling Memo to R. W. Cantrell 90
                                          --        5/3/84       R. W. Cantrell Memo to J. A. Coffey 91       PWP 840508 001 f/II/04      R. W. Cantrell Meno to J. A. Cof fey 92       NEB 8401ll 260        --
                                        --          7/II/86      Draf t Design Criteria for the ERCW System 67 93        --

I -- 7/11/86 Draft Design Criteria for the Auxiliary i 94 -- feedwater System 30 95 NSR 800510 052 - 5/10/80 Memo from H. N. Culver to R. H. Dunham on SQN - Turbine-Drive Auxiliary Feedwater Pung Levol Control Valves Air Supply i

             %        B45 061015 251         -        10/15/85 Memo from J. A. Raulston to J. F. Cox on SQN C/R Data Sheet Review l

97 825 870217 Oli - 2/17/87 Memo to those listed from J. F. Cox SQN-C/R Data Base System Assignments (M-46) i >:emo to D. W. Wilson f rom R. O. Barnett SQN-C/R 98 B41 870226 002 -- 2/26/87 Data Base System Assignments (Civil) 2/20/87 Meno to J. F. Cox from A. F. Pagano SQN C/R 99 B4) 870220 925 -- Data Base Assignments (Electrical) 100 B45 070227 257 -- 2/27/87 Memo from R. C. Weir to J. F. Cox SQN-C/R Data Base Systems Assignments (Nuclear) l B44 870225 000 -- 2/25/07 Memo fran L. W. Boyd to J. F. Cox SQN-C/R Data 101 Base Assignments (Mechanical) 102 DIM-SQN-DC-V-l) 9.8-5 2/27/87 844 870227 016 105 DIM-SQN-DC-V-13.9.9-3 3/2/87 844 87030? 007 104 DIM-SQN-DC-V-7.4.2 3/5/87 844 870305 018 7.6.4-22 L

Issue Reference Document Revision Date Title Flow Diagram for Containment Spray System [~ 105 47W812-1 11 12/23/06 CSS operating Modes calculation 106 825 861223 300 - 107 FSAR Figure - Tenperature Transient of Active Sune and 6.2.1-22 Inactive Supp 108 OlM-SQN-0C-V-13.9.9-2 l/16/87 B44 870116 008 0 12/8/06 CCS Surge Tank Makeup Calculation 109 B44 861200 019 110 B44 861200 017 0 12/8/86 CCS Surge Tank Level lli FSAR Section 9.2 "-3 Setpoint Calculation 0. L ,, , 7.6.4-23

7.6.5 Civil The EA Civil discipline participated in reviewing the adequacy of the DB&VP identification of licensing comnitments and design requirements in accordance with SQEP-18 (reference 1), and the preparation of design criteria for the RDBD in accordance with SQEP-29 (reference 2). This ef fort included the review of the C/R data base and incorporation of all restart C/Rs into the restart design criteria. For the C/R identification ef fort, the review evaluated the conpleteness of the data base, accuracy of C/R input data to the actual C/R, and adequacy of the selection process for determining the hard copy C/R docunents for input to the data base. The EA Team searched the licensing document sources identified in Attachment i of SQEP-18, including a RIMS search of memorandums and letters, for selecting C/Rs to verify that they were captured in the C/R data base with appropriate C/R data forms prepared. These C/R forms were reviewed for conpleteness of the key word descriptive fields, and verification that civil C/Rs with The initial general criteria subjects were assigned to the "All Safety System," System 999. C/R selection process was evaluated by reviewing inpell's assigned N/A documents which were not forwarded to the branches for C/R evaluation to assure that potential C/Rs were not missed. The EA Team's review included verification of adequate training of personnel to appropriate procedures, and also adequacy of the deterinination by the branches of C/Rs that were candidates for a licensing change. A review of CEB GDC was performed to evaluate the technical adequacy and inclusion of all appropriate C/Rs. The criteria were selected fran civil CDCs listed in Attachment I of SQEP-29 to include general subjects most related to the qualification of items included in the DB&VP, such as pipe stress, pipe supports, conponent qualification, and cable tray support systems. Included in the evaluation were the three restart interim design criteria which utilized relaxed acceptance criteria for restart consideration only. The RD80 was also reviewed to verify the adequacy of capturing the civil GDC required for restart. The technical review included assurance that the applicable codes, standards, and regulatory requirements were properly incorporated. Loading continations and allowable stress limits were verified for conpliance to SQN licensing conmitments. Technical interface considerations were evaluated to ensure conponent and structural requirements were adequately incorporated for overall system qualification. The review to ensure the incorporation of all appropriate licensing C/Rs was based on conpliance to sections 5.6.4 and 5.6.5 of SQEP-29 (reference 2). This directs the CEB Branch Chief to review the civil GDCs referenced in system criteria for enconpassing those C/Rs in the "ALL SAFETY-RELATED SYSTEMS" (999 sort). EA Civil evaluated whether the project assessment was adequately documented to show each applicable C/R required for restart was contained in the GDC, or whether a subsequent revision was implemented for incorporation of the C/Rs. 7.6.5-1

7.6.5.1 Details Incorporation and Capture of Licensino C/Rs Approximately 100 civil-related documents were reviewed from licensing document sources to cbtain 25 representative civil C/Rs. The selection included 13 items frce the FSAR, 9 comnitments made in formal TVA letters to the NRC, and 3 C/Rs from the SERs. The selection of these C/Rs concentrated on the FSAR and consideration of generic civil nuclear industry concerns. There were 21 (references 3 through 23) of the 25 C/R forms properly found in the TVA C/R data base. The remaining four C/R documents were not captured in the C/R data base. The documents included a TVA letter concerning the auxiliary feedwater system (reference 24), ca;pliance to RG l.29 (reference 25),10CFR50.55e final report on NCRSQNCEB8210 (reference 26), and FSAR Table 3.2.1-1 (reference 27). These deficiencies were reported to the project in action items C-06, C-10, C-12, and C-24, respectively. Theprojectprepareda C/R form (reference 28) for the subject letter (reference 24) for resolving C-06, which adequately captured the comnitment. Theprojectidentifiedthatthesubstanceof NCRSQNCEB8210 (reference 26) was captured by another C/R form (reference 29) previously written to address a similar requirement, which EA verified adequately enconpassed the missed comnitment concern of C-12. TheprojectreportedthattheFSARtable(reference 27)ofC-24wasincludedinC/R SQNNEBHEM1012 (reference 30) which generically captured FSAR Section 3.2. This C/R was not origirally found in the 999 "All System" data base, however, the project added it to the 999 sort by correctly revising the C/R form. EA verified the adequacy of the C/A for C-24 for capturing the comnitment. The problem of not including appropriate C/Rs in the data base was generic in nature. The project inplemented a C/A program (reference 31) to address the general concern of missing conmitments from the C/R data base which is discussed later in this section. The project identif nd th6t their conmitment of full conpliance to RG l.29 was also captured by SQNNEBHEM1012 (reference 30) and SQNCEBJOHl026 (reference 32). The first C/R generally references the conplete FSAR Section 3.2 in which the RG is identified. The addition of this C/R to the 999 sort assured adequate inclusion for civil criteria conmitments. The second C/R captures FSAR Section 3.7.3.13 which requires that category I piping analysis criteria is c.ontinued to the first restraint beyond the Category I isolation valve. The substance of compliance to RG l.29 was also contained in SQNNEBHEM304l (reference 33) which captured SER Section 3.2.I and was included on the 999 system sort. EA verified the adequate C/A for capturing the comnitment in the data base, but also identified a generic concern that an adequate criteria or program has not been established at SQN for protecting Category I conponents from the failure of Category 11 components which could fall and damage safety equipment. Theproject'sevaluationofC-10 also recognized that there is no current criteria distinction between Category I (L)a safety-related pressure retention and safety-related position retention piping (Category I (L)b). Classification corresponding to class designat!on is normally made by MEB and transmitted to the analyst by a flow diagram. TheprojectgeneratedPIRSQNCEB8670 , (reference 34) to address the concern of conpliance to RG l.29. The C/A for this CAQ was not available for EA Team verification at this time (see observation C2). 7.6.5-2

i i I l l !g in general, the 21 C/R forms (reference 3 through 23) that were initially in the data base L were found coglete and accurate, and had assigned the general civil comnitments properly to the 999 all system code. . However, three concerns were raised by the EA Team relating to the C/R forms (references 14,16, and 22) involving inadequate selection of GDC subjects. The first of these concerns included the proper subject, Missles, not being marked on

       .SQNCEBOC1017 (reference 16). This concern was doctmented to the project in action item

_C-05. ' Another concern was that the proper subject, Electrical Raceways, was not marked on . SQNCEBNFl010 (reference 14), and the last concern was that all applicable subjects were not identified on SQNCEBJOHl059 (reference 22). These latter two concerns were documented to [ the project on action item C-II. TheprojectrevisedthethreeapplicableC/Rforms,and EA verified the adequacy of the revisions to resolve the concerns. These problems were determined to be generic in nature by the project, and the project iglemented a general C/A program (reference 31) to address the extent which is detailed later in this section. in addition to the review of 25 C/Rs, 5 representative. civil-related items and i electrical item was selected for EA review from approximately 70 documents for which Igell designated as N/A, that is, outside the scopes of the DB&VP activities and the plant operations responsibilities. All 5 civil items (references 35 through 39) were correctly exeg ted from further considerations'of incorporation into the C/R data base. The electrical-item was a TVA letter (mference 40) connitting to' limit the use of terminal blocks for Class IE-circuits inside primary containment unless they were housed in conduit boxes sealed to withstand primary containment design pressure. This comnitment should have been included F- in the C/R data base since it was within the scope of the 084VP program. Action item C-20 was generated to document the incorrect judgment by Igell resulting in a missed C/R. The project entered this comnitment into the data base and established a C/A program (reference

31) to address this concern which is described below.

Due to the l'arge nuntper of concerns evaluated by the project from the entire EA Team, the [ projectestablishedaC/Aprogramwhichaddressedseveralgenericconcernsassociatedwith l: the C/R data base development (reference 31). The program included a rereview of the N/A }. category comnitments and NEB files to capture potential C/Rs addressing the concern of C-06,;C-20, and C-24. The C/A program also included a rereview of 140 C/R data sheets to ensure adequate C/R form preparation, addressing the concern of C-05 and C-II. The results of the project C/As were doctanented in a TVA memo (reference 41). The EA Team verified that the project adequately iglemented their C/As to ensure adequacy of incorporation and capture of licensing C/Rs into the C/R data base. The Team also verified that specific incorrect C/R forms were properly revised, and new forms were generated for any missed comnitments. Adequate implementation of generic C/A of the rereview of the igell N/A file of reference 31 was verified and ensured that no significant civil C/Rs remain in their N/A category files. The Team also concurred with the results of the C/R data sheet system identification rereview by verifying that minor errors in the C/R forms would not have af fected the adequacy of capturing the C/Rs in the applicable civil design criteria as required by SQEP-29 (reference 2). Preparation of Desian Criteria The EA Team reviewed four civil design criteria (references 42 through 44 and 58), the DIMS which address restart interim design criteria (references 45 through 47), one system criteria (reference 48), and the civil GDC (reference 49). The civil GDC was generated as C/A in response to EA Civil action items. The results of the review are sumnarized below. 7.6.5-3 L-

l. SgN-DC-V-I}.) (Reference 44) - Detailed Analysis of Category l Pipina System--This criteria provides the general requirements for rigorous pipe stress analysis for Category I piping systems. The criteria adequately invoked the applicable conmitted codes, ASME lit and ANSI B31.7. The various computer programs were adequately described and the required usage for which they were qualified were appropriately identified.

The criteria incorporated the required piping classifications, load containations, and stress allowables as conmitted in the FSAR; however, a more thorough definition of terms, such as " sustained and occasional loads," along with conmitments from the C/R data base could only be found in the Rigorous Analysis Handbook, which was not referenced. This document reference along with the following specific requirements were not addressed in this stress criteria:

a. Overlap design considerations, such as rigorous analysis interface with alternate analysis or dead weight hung piping,

b. Interface procedures to control and identify the system / piping design input required by the pipe stress analyst to inglement this criteria.

c. Interface criteria between TVA stress analysis scope and the Class i NSSS analysis performed by Westinghouse.

Applicability or limitation of tubing analysis to this criteria. d.

e. Method or classification scope for analyzing nonsafety- related piping for protection from potential damage to safety-related piping /equipnent within the DB&VP.

These concerns were directed to the project in action item C-15. The project inpleme.. ed a general C/A program (reference }l) which addressed the concerns of C-15 by the generation of SQN-DC-V-l.0 (reference 49). EA evaluation which is detailed later in this section in the review of the civil GDC cannot be completed at this time. See observation C5. Another concern that resulted from EA's review of SQN-DC-V-15.3 was inconsistency with the RCS system criteria, SQN-DC-V-27.4 (reference 50). The RCS criteria references SQN-DC-V-15.5 for RCS pipe stress qualification; however, SQN-DC-V-13.5 exenpts the reactor coolant loops from its scope. This concern was documented by action item C-27, and subsequently resolved by the project's generation of PIR SQNCE88669 and addition of this PIR on the DB&VP punchlist (reference 51). C/A for EA Team review has not been established to ensure adequate resolution. See observation C3. 7.6.5-4

2. SQN-DC-V-1).5-3 (Reference 45) - Acceptance Criteria for Restart for SQN-DC-V-15.3 --

This DIM provided specific relaxations /exeniptions to the requirements of SQN-0C-V-15.3 for the restart of SQN. This interim acceptance criteria was used as justification to enable restart for short-term deviations to the base criteria conmitments until the design qualification was backfitted to the original licensing conmitment. The relaxation to slightly higher allowables appeared appropriate based on later editions of ASME codes. . The interim criteria approach concentrated on qualification for the faulted condition, with prime relaxation of the upset condition, which also appeared appropriate based on the theme of restart to mitigate FSAR Chapter 15 events. During an NRC. Inspection, the NRC reviewer indicated that NRC acceptance was required for these reduced design margins to FSAR licensing contnitments before restart. In addition, it was noted that there was an apparent lack of established controls to track those items requiring requalification. These concerns were documented in action item C-07. TheprojecttookthefollowingC/A: e Fcrmal presentation of interim acceptance criteria to the NRC (references 52 and 53). e Established an interim policy (reference 54) to control specific application of interim criteria as an unverified calculation assumtion, and limited general application to alternate analyzed piping and cable tray supports, o Established a project procedure for formal documented control (reference 55). EA verified the adequacy of the project implementation of the C/A.

3. SQN-0C-V-l.3.4 (Reference 42) - Cable Tray Support System Criteria-The criteria adequately invoked the required codes and standards necessary for the user to neet the applicable licensing C/Rs. It contained the necessary design parameters, load conbinations, stress allowables, and material properties. The EA review verified that the applicable restart cable tray C/Rs in the 999 sort were adequately captured in this criteria.

One concern resulted in which the criteria did not provide considerations for the concentratedweightofoverhungcablebundlesexitingthetraytofeedadjacent equipment. This concern was documented to the project in action item C-14. The project identified that previously issued SCRSQNCEB0622 (reference 56) had established C/A which enconipassed this issue. EA reviewed the resulting report by Wylie Laboratories resulting from the inplementation of this C/A (reference 57) and verified that it adequately qualified the configuration. I' 7h.5-5

4. SQN-0C-V-l.5.4-5 (Reference 46) - Acceptance Criteria for Restart of SQN for SQN-DC-V-l.5.4-This OlM provides specific relaxations /examptions to SQN-0C-V-l.5.4 to be usad as justification for short-term deviations to licensing conmitments to enable restart until the design qualification was backfitted to the original criteria. This DIM was found adequate based on the acceptability of the attributes reviewed. The testing previously performed justified the increased dan 1 ping values, and the concentration on qualification for the faulted condition is consistent with the theme to mitigate FSAR Chapter 15 events. The NRC concern relating to their acceptance of these interim criteria were also applicable for this interim criteria. Adequate resolution was provided (see discussion under SQN-DC-V-15.5-5).

5. 59N-DC-V-24.1 (Reference 58)-Location and Desian of Pipina Supports and Supplemented Steel in Category I Structures--The base pipe support design criteria, SQN-0C-V-24.I, was generated for SQN based on the Watts Bar Pipe Support Criteria, WB-0C-40.51.9 (reference 59). The load conibinations, stress allowables, support classifications, and design approach were found to be adequate and in conpliance with the applicable codes comnitted in the FSAR. The following specific concerns resulted from this review:

e T!.e criteria does not cover supports designed by the NSSS supplier, Westinghouse; however, this limitation is not documented in the applicable system criteria such as SQN-0C-V-27.4 (reference 50). This concern was included in the extent of action item C-27. The project conmitted to include the NSSS in SQN-0C-V-24.l; however, this remains an open item as C/A has not been inplemented and could not be verified. See observation C5. o CEB did not review the C/Rs in the 999 sort against this criteria to ensure adequate incorporations of applicable licensing conmitments as required by SQEP-29. This concern was included in action item C-16. TheprojectC/Aresultedinthe generation of a new GDC, SQN-DC-V-l .0. (';ee item 9 for details.). e During an NRC inspection conparing SQN criteria with WB-0C-40.51.9, it was noted that two design requirements were not incorporated in the SQN criteria. These two requirements were consideration of pipe stress induced by the use of stiff pipe clanps and the method of confirr ing that floor and wall sleeves subjected to piping axial leads are qualified for these loads. These concerns were reported to the project in action item C-16. Theywererasolvedwhentheprojectprovidedevidence subsequently verified by the EA Team that use of stiff pipe clamps is prohibited by SQN General Construction Specification G-45 (reference 60), and that the design of axial loaded sleeves are addressed in a mechanical design standard (reference 61). e During an NRC inspection, a review of the C/Rs relating to drilled-in-anchors was made, it was noted that these c m mitments were not required for restart, yet these requirements are critical for assuring adequate pipe support attachments to concrete walls. The review also revealed that the C/R requiring the use of through-bolts for anchorage on masonry walls was required for restart; however, this design criteria was not revised to capture the C/R. Theseconcernsweredocumentedtotheproject in action item C-17. The project established a C/A program (reference 51) resulting in the generation of SQN-DC-V-l.0. EA verification of the adequacy of this C/A is detailed in itan 9. 7.6.5-6

l

6. SQN-DC-V-24.1-1 (Reference 47) - Acceptance Criteria for Restart for SQN-DC-V-24.1 --

This DIM to the pipe support criteria provided limited relief to licensing C/Rs for use asjustificationforshort-termdeviationsforrestart. The pipe support design would be backfitted to the original requirements during a specified period. The DIM was found adequate based on the acceptability of the attributes reviewed. The relaxation to slightly higher allowables was considered appropriate based on later editions of the ASME 111 Code and RG l.124. The interim criteria approach concentrated on qualification for the upset condition also was considered appropriate based on the theme for restart to mitigate FSAR Chapter 15 events. Anchorage deviations for expansion anchors were consistent for an interim period allowed by the original conpliance to IE Bulletin 79.02. The project was required to obtain NRC approval for all these licensing deviations and established controls for tracking application of this OlM (see alscussion for action item C-07 under SQN-DC-15.3-5).

7. Appendix F (Reference 42) - Desian Criteria for Qualification of Seismic Classes I and

_Il Mechanical and Electrical Equipment--Appendix F establishes an adequate basis for analytical qualification and enpirical testing qualification for all the various classifications of mechanical and electrical components. The criteria does not clearly invoke the applicable design codes or stress allowables. It adequately covers seismic load conbirations, but fails to clearly consider other dynamic load considerations, such as DBA load contribution. Throughdiscussionswithprojectpersonnel,itwas found that elements of the WBN component qualificalion criteria (reference 62) were used for SQN conponent qualification. Comparison with the Watts Bar component qualification criteria (reference 62) found the WBN criteria more conplete, clearly addressed the design methodology for the applicable codes, and contained thorough functional assurance test criteria. in comparison, Appendix F appeared only to be a general guide for qualifying components. These technical concerns were reported to the project in action item C-IB. It was resolved bcsed on the following project clarifications; e Appendix F serves as a guide by designated cognizant engineering personnel specially trained by CEB for sdsmically qualifying equipment using technical references supplemented, e At SQN, equipment specifications and procurement documents establish applicable codes, loading standards, pressures, tenperatures, and other vital design requirements, e Review and approval of the procurement documents and modification to all safety-related conponents are accomplished and controlled by CEB-DI 121.03 (reference 65). e Project conmitted to a C/A program (reference 31) to address the required interface of Appendix F with other controlled civil design documents. EA verified that the C/Rs in the 999 sort were reviewed against Appendix F, however, found that the criteria failed to fully capture DBA load considerations identified in C/R SQNCEBFHCl01) (reference 64). This deficiency was documented in action item C-26. The project's C/A pogram (reference 31) adequately enconpassed the resolution to this concern. 7.6.5-7

1 The EA verification of the adequacy of this C/A program for resolving C-18 and C-26 is detailed later in this section in the review of item 9

    . 8. SGi-0C-V-27.5 (Reference 48) - CSS Criteria-This system criteria was reviewed to evaluate the proper incorporation of civil GOCs and capture of system unique C/Rs with civil scope. The civil C/Rs assigned to this system were comitments to reenalyze specific problems identified in 10CFR50.55(e) reports to ensure compliance to existing civil G0C. They did not include new criteria comitments, thus did not require specific incorporation into system criteria. The civil GDCs were incorporated by reference under the external events sections under descriptions of the design basis,L such as Flood, Missiles, and Ability to Withstand the Safe Shutdown Earthquake (SSE) and Operating Basis Earthquate (08E) Without the loss of Function. Many discrepancies were found demonstrating the inadequate incorporation of civil GOC and indicated that the preparer did not adequately coordinate the effort with CEB. Specific findings included the following:

e' Failure to incorporate applicable pipe support GDCs listed in SQEP-29, Attachment 1. e leproper reference to duct qualification criteria. e Failure to incorporate cable tray support criteria, e No reference of CEB interim criteria for restart. l

l. e References were made to civil design guides in lieu of applicable design criteria as

!- required in SQEP-7). l l These concerns were presented to the project in action item C-28. , Asaresultoftheseconcerns,theprojectgeneratedPIRSQNCER0672(reference 66)to-l address the inadequacy of system criteria incorporating GOCs. TheprojectsC/Aprogram (reference 41) documented its implementation by issuing a new General Civil Design Criteria, SQN-DC-V-l.0 (reference 49). In addition, the project comitted to issue Dims for system criteria to incorpo: ate this new GDC for addressing the civil scope

  -         basis required for the R000 (reference 65) for resolving action item C-28, which remains open pending EA verification of C/A to the PIR (see observation C6)..

L I 9. ; SQN-0C-V-l.0 (Reference 49) - General Civil Desion Criteria-This criteria was comprehensive and established the basis for identifying the specific civil design criteria required for restart and included the 999 sort civil C/Rs required for restart. Inaddition,theprojectidentifiedwhatcivildocumentincorporatedthe specific C/R. This GDC consolidated the civil criteria documentation required to perform the stress qualification for demonstrating system adequacy to mitigate FSAR Chapter 15 events. The approach taken in the development of the criteria was deemed acceptable as it provided the doctsnentation to demonstrate full compliance to SQEP-29. It provided a consolidated document for reference in the R000 which assenties all specific civil design criteria and other controlled civil design documents that capture C/Rs required to perform system qualification. The listing of civil-related C/Rs also provides a handy reference of applicable C/Rs from the C/R data base in a single criteria document. 7.6.5-8

This criteria was found adequate based on the acceptability of the attributes reviewed. The listing of civil design criteria was found complete. The RD80 (reference 65) was reviewed and found to adequately incorporate SQN-DC-V-l.0 to establish a sound civil design criteria basis for restart. -7.6.5.2 Conclusions The final civil GDC product was found to be in conpliance with SQEP-18 and SQEP-29 except for rigorous pipe stress analysis, as noted in observation C3. The issued RDBD adequately incorporates the civil GDC. EA verification of adequate project C/A is required upon project disposition of PIRSQNCE88670 and PlRSQNCEB8672, documented in observation C2 and C6 respectively. 7.6.5.3 References issue Reference Document Revision Date iltle i SQEP-18 1 7/9/86 Procedure for identifying Comnitments and Requirements 2 SQEP-29 1 7/18/86 Preparing Design Basis Document for Sequoyah Nuclear Plant 3 SQNCE8KA81004 N/A 5/14/86 C/R form for IVA Position on IE Bulletin 79-14 (A27 800506 016) 4 SQNCE8CPB1012 N/A 5/13/06 C/R Form for Jet inpingement Considerations (FSAR 3.6.4) 5 SQNCE8CGil58 N/A 5/14/86 C/R Form for Wind and Tornado loadings (FSAR 3.3) 6 SQNCE8JDHl026 N/A 5/ll/86 C/R Form for Terminating Category i Boundary at First Restraint Beyond Isolation Valve (FSAR 3.7.3.13) 7 WNCEBJDHl015 N/A 5/11/86 C/R Form for Pipe Stress Danping Valves to be Used (FSAR 5.7.1.3) 8 SQNCE8CG1002 N/A 5/13/86 C/R Form for 10CFR50.55(e) Final Report SQN(e)CE88030, (A27 810120 014) 9 SQNCEBCGl019 N/A 5/14/06 C/R Form for Applicable Codes and Standard for Design of Category 1 Structures (FSAR 3.8.1.2) 10 SQNCE8CGil67 N/A 5/15/% C/R Form for Design of Anchorage to Concrete (SER 5.9.2) ll SQNCE8NES1013 N/A 5/12/86 C/R Form for Equations Used to Produce an Average Seismic Response (FEAR 3.7.1.1) 12 SQNCE8JDill002 N/A 5/14/86 C/R Form for Snubber inspection Procedure (Final Report for Infraction 328/78-18-02) 7.6.5-9

Issue Reference Document Revision Date Title SQNCEHNFl001 N/A 5/14/86 C/R Form for Pressure Retaining Capacity of 15 Steel Containment Vessel (SER 2.4.2) N/A 5/14/86 C/R Form for 10CFR50.55(e) Report on NCR 14 SQNCEBNFl010 CEB79-19. N/A 5/14/06 C/R Form for Dynamic Pressure Transfer Analysis IS SQNCEBNF1022 of the Steel Containment (FSAR 5.8.2.4.2) 16 SQNCEBOC1017 N/A 5/II/86 C/R Form for Missile Protection of 480-Volt Transformer in Auxiliary Building. Incorrect C/R Form, C-5 Generated (SER Supplement 5) 17 SQNCEBOCl0ll N/A 5/11/86 C/R Form for Category i Structural Criteria for Toranado Generated Missiles (FSAR Table 5.5.5-2) 18 N/A 5/14/86 C/R Form for 10CFR50.55(e) Report for SQNCEB8012 SQNCEBCPBl005 to Mitigate Pipe Rupture in Mainsteam Lines (A27 801050 006) 19 SQNCEBNFl020 N/A 5/14/06 C/R Form for Applicable Regulatory Guides for Steel Containment Vessel (FSAR 5.8.2.2.5) 20 SQNCEBCP01004 N/A 5/15/06 Pipe Break Criteria for Westinghouse Prim 3ry Coolant Loop (FSAR 5.6.2.1) 21 SQNCEBJDH1025 N/A 5/11/86 C/R Form for Limitations for Using Alternate Analysis (FSAR 5.7.5.9) N/A 5/8/86 C/R Form for 10CFR50.55(c) Report on GENCEB8215 22 SQNCERJDHl059 25 SQNCEBKABl029 N/A 5/15/86 C/R Form for NCRSQNCEB8106 24 A27 820501 152 N/A 5/1/82 TVA Letter providing Piping Criteria for Auxiliary Feedwater System 25 RG l.29 5 9/78 Regulatory Guide 1.29 N/A - 10CFR50.55(e) Final Report for NCRSQNCEB8210 26 10CFR50.55(e) Final Report 27 FSAR N/A N/A Category i Structure Table 3.2.1-1 28 SQItiEBLWBl572 N/A 7/2/86 C/R Form for TVA Letter A27 820501 152 29 SQNCEBNFIO21 N/A 5/11/86 C/R form for B41 860514 26l 30 SQNNEBHEM1012 N/A 5/12/86 C/R Form for FSAR Section 5.2 7.6.5-10

i Issue Reference Document Revision Date Title 31 B25 860911 012 N/A 9/ll/06 J. F. Cox's Memo Providing Corrective Action Program for SQEP-18 and SQEP-29 Due to EA Action Items 32 SQNCEBJDH1026 N/A 5/5/86 C/R Form for FSAR Section 3.7,3.13 33 SQNNEBHEM3041 N/A 5/16/06 C/R Form 34 PIRSQNCE88670 N/A 9/25/06 Problem identification Report 55 L5I 810708 906 N/A 7/8/81 Letter Providing Details of Missing Hanger on Unit l l 36 (No nunter) N/A 6/9/75 Description of unresolved erection item described l l Memo from Chandler for NRC Exit Meeting l N/A 8/25/81 Letter Discussing Unit i ERCW Field Problem ( 57 L45 810825 812 i (Letter to NRC) l 38 (No nunber) N/A 6/14/77 Documenting Corrective Action for Inproper Letter from Storage of Main Steam Pipe Supports Gilleland to NRC 39 A27 810430 018 N/A 4/50/81 Documenting Qualification Adequacy of Unit 2 l l Cables in the EGTS Filter Rooms 40 A27 790712 Oil N/A 7/12/79 Limit use of Terminal Blocks for Class IE Circuits only when Sealed to Withstand Prinary Containment Pressure N/A 12/3/06 J. F. Cox's Memo Sunmarizing Completion of 41 825 061205 019 Corrective Action Program for SQEP-18 and SQEP-29 42 SQN-DC-V-1.3.4 1 12/22/86 Category l Cable fray Support Systems l 45 Appendix F 2 12/24/73 Design Criteria for Qualification of Seismic Classes I and il Mechanical and Electrical Equipment 44 SQN-DC-V-15.5 5 8/15/84 Detailed Analysis of Category l Piping System 45 DIM SQN-DC-V-13.5-5 N/A 6/10/86 Detailed Analysis of Category l Piping System, Acceptance Criteria for Restart of SQN (841 860610 006) 46 DIM SQN-DC-V-l.).4-) N/A 6/13/86 Design input Memo for SQN-DC-V-l.3.4 RO 7.6.5-11

l l l issue Reference Docunent Revision Date Title l I DIM 3QN-DC-V-24.1-1 N/A 7/21/86 Location and D) sign of Piping Supports and ! 47 ' Supplemental Steel in Category i Structures Acceptance Criteria for Restart of SQN 48 SQN-DC-V-27.5 0 7/30/06 Containment spray System 49 SQN-DC-V-1.0 0 12/5/86 General Civil Design Criteria l SQN-DC-V-27.4 0 7/25/86 Reactor Coolant System 50 2 1/29/86 Control of Design Baseline and verification 51 SQEP-45 Program Action items 52 S10 860725 802 N/A 7/25/86 TVA Letter to NRC 55 510 860725 805 N/A 7/25/86 TVA Letter to NRC B41 850724 001 N/A 7/21/86 CEB Policy Memo PM86-12 54 0 8/21/86 SQN Postrestart Activity Tracking 55 SQEP-35 l i N/A 5/10/06 SCR on Cable Tray Support Design Criterla Errors ! 56 SQNCEB8622 57 CEB-8N-1010 0 8/5/86 Report by Wylie Laborator es SQN-0C-V-24.1 0 6/25/86 Location and Design of Piping Supports and 58 Supplemental Steel in Category i Structures WB-DC-40.51.9 6 2/10/% Location and Design of Piping Supports and 59 Supplemental Steel in Category i Structures 60 G-45 9 8/l4/86 Support and Installation of Piping System in Category I Structures 61 DS-MS.2.6 0 10/25/85 Mechanical Design Standard, Sleeve-Siring, Sealing, and Anchoring 62 WB-DC-40-312 2 7/51/84 Wetis Bar Component Qualification Crlieria 65 CEB-Di 121.05 1 5/16/86 Seismic Design and Review 64 SQNCEBFHC1015 N/A 5/10/% C/R for Seismic and DBA Test Procedures, FSAR Section 5.9.l.2 826 % I210 006 -- 12/4/86 Restart Design Basis Document 65 66 PIRSQNCEB0672 N/A 10/6/06 Problem idenfification Report 7.6.5-12

7.7 System Evaluation The culmination of the 084VP was the issuance of SYSTERs for each system in the program and a punchlist that tracked all of the items identified during the program that required action. The SYSTER preparation and issue process was governed by SQEP-16, " Procedure for System Evaluation and Development of System Evaluation Report." The SE preparer accumulated all of the required inputs associated with modifications since OL (e.g., ECN evaluations from SQEP-12, L-DCRs, SCRs, and ONP-generated drawing discrepancies). These documents were then evaluated, individually and collectively, to determine their acceptability based on compliance with the RD00. The intent was to verify that the ability of tho systems or portions of systems identified in the DB&VP to mitigate FSAR Chapter 15 08Es, and to acconplish a safe shutdown have not been reduced as a result of the modifications and that these modifications have not violated licensing conmitments. The system evaluation process also included evaluation review / study drawing (ER/SD) to document the system's configuration through restart. All items identified in the SYSTERs or elsewhere in the DB&VP that required action were input to a punchlist for tracking. This process was governed by SQEP-45, " Control of DB&VP Action items." Each punchlist item must have a description, C/A, restart categorization (pre- or post-), and justification if postrestart. A responsible action party (RAP) was assigned to perform a C/A to close the punchlist item. The RAP determined the required C/A and restart categorization and coordinated these with the cognizant SE(s). ProjectDirective D0VP-D-87-002 required the SE to issue a punchlist closeout statement verifying his concurrence with the C/A and restart categorization for all items af fecting his system. The punchlist closeout statement also discusses any restart categorization differences with the SYSTER. The EA review was to verify that the SYSTERs were prepared in accordance with SQEP-16 and the conclusions obtalnu! in the SYSTERs were technically adequate. All of the team discipline reviewers, except for Construction, performed these reviews. The results from the discipline review are presented in sections 7.7.1, 7.7.2, 7.7.3, 7.7.4, 7.7.5, 7.7.6, and 7.7.7. 7.7-1

7.7.1 Nuclear The Nuclear discipline of the EA Team reviewed SYSTERs to determine their technical EA adequacy and conpliance with SQEP-16 (reference 1) and associated program directives. Nuclear also reviewed punchlist items to determine the technical adequacy of their C/A and restart category and conpliance with SQEP-45 (reference 2) and associated program directives. The SYSTERs were reviewed by EA Nuclear for the following attributes: e Did the ER/SD capture the changes? e Did the list of inputs include all types? e Did TACFs have the correct disposition and action? e Were ECNs evaluated acceptably? e Were category D FCRs evaluated acceptably? e Was adequate documentation provided for SCRs that the C/A was conplete? e Were SCRs evaluated acceptably? e Were L-DCRs evaluated acceptably? e Were ONP-generated dr w ing discrepancies, walkdowns, and test results evaluated acceptably? e Was adequate justification provided for any system portions not walked down? e Were cumulative effects evaluated acceptably? e Were unacceptable items documented? e Were all system punchlist items includes? e Was the statement of conclusions adequate? Punchlist items were reviewed by EA Nuclear to verify that the SE's concurrence had been properly obtained or for the following attributes: e Was the restart categorization (and justification if postrestart) acceptable? e Was the C/A technically adequate? e Was the C/A cospleted acceptably? SYSTERs were selected for review based on early availability from those prepared by the project nuclear discipline in NEB and at Westinghouse. Punchlist items were selected for review from those associated with the reviewed SYSTERs, randomly from those which had been closed, or randomly from those which had been assigned to the NLE as the RAP and which had either been closed or deferred until after restart. 7.7.l-l

7.7.1.1 Details EA Nuclear reviewed SYSIER 85, "CGCS," (reference 5) and SYSTER 61, " Ice Condenser System," (reference 4). In addition, EA Nuclear reviewed all of the punchlist items associated with SYSTER 85 through the January 7,1987 update (references 5 through 85) and SYSTER 61 through the January 14,1987 update (references 86 through 199). EA Nuclear also randomly selected three independent punchlist items (references 200 through 202) which had been closed, in addition, six other independent punchlist items (references 205 through 200), which had either been closed or deferred until af ter restart, were selected by EA Nuclear for review from those assigned to the NLE as the RAP. EA Nuclear concluded that the preparation and issuance of SYSTERs 85 and 61 were adequate with several exceptions. These exceptions and concerns developed during our review of punchlist items are grouped in the fellowing discussion by type of concern and observatlon.

l. Procrammatic Concerns

a. EA Nuclear identified deficiencies in the governing procedures SQEP-16 and SQEP-45 (references I and 2). SQEP-16 R2 did not contain provisions for revision of SYSTERs. As a result, there was no guidance on correcting errors or including evaluations of additional inp'.ts. This progranmatic concern was directed to the projectinactionitemN-49. In response, the project issued R5 of SQEP-16 (and revised related procedures) to allow for SYSTERs to be revised for changes, additions, and deletions in addenda to the original SYSTERs. EA Nuclear concluded that these procedure revisions adequately addressed our progranmatic concern.

b. SQEP-16 did not define " exception" or " unacceptable item." As a result, exceptions and unacceptable items were not properly or consistently incorporated in SYSTER sections 5 and 4 and appendices containing SQEP-16, Attachment 2A and 28 forms. This progrannatic concern was directed to the project in action items N-50, N-54, and N-55. In response, the project invoked Section 4.0 of Attachnent I of SQEP-16 which stated that resolutions to exceptions would be resolved on the punchlist. EA Nuclear judged that our project response did not adequately address our concern about the internal consistency and uniformity of the SYSTERs as standalone documents. However, during the evolution of the SYSTER/punchlist relationship in the latter stages of the D88VP, EA Nuclear recognized that SYSTERs were an intermediate step in the overall process responsible only for identification of those items requiring further attention. EA Nuclear judged that the SYSTERs performed the problem identification function adequately even though they contained these inconsistencies. The technical decisionanaking associatedwithestablishingandperformingC/Aanddeterminingandjustifying restart categorization for each item was acknowledged by EA Nuclear to be associated with the punchlist, not the SYSTERs. The EA Team's concerns about the implementation of SQEP-45 for the punchlist were expressed in action item E-85 (see section 7.7.2). Since the technical importance of the punchlist superseded that of the SYSTERs, EA Nuclear judged that the Team's concerns about the punchlist superseded ours about the SYSTERs.

7.7.1-2

in response to the concerns expressed in action item E-83, the project issued D8VP-D-87-002 (reference 209) requiring the SE to issue a punchlist closeout statement verifying his concurrence with the C/A and restart categorization for all items affecting his system and reconciling any restart categorization differences from the SYSTER. Verification by EA Nuclear of proper determination of C/A and restart category of punchlist items and technically adequate reconciliation of punchlist/SYSTER dif ferences in the punchlist closeout statement is required (observation N4.)

c. EA Nuclear expressed prograntnatic concerns over several sections of SQEP-45RI related to the exclusion of the SE from the process of revising and closing punchlist items. Theseconcernsweredirectedtotheprojectinactionitem N-52. The project responded by issuing R2 of SQEP-45 to require SE concurrence in the C/A, restart categorization, and justification. EA Nuclear concluded that this C/A was adequate to resolve the concern and verified that SQEP-45R2 was issued containing these requirements.

d. EA Nuclear noted a conflict between SQEPs-16 and -45. SQEP-45, section 3.4.5, required the SE to review the punchlist to ensure all items had been included in the SYSTER if the items were required for restart. This inconpletely fulfilled the requirement in SQEP-16, section 3.3.7, that the SYSTER's explanation of each unacceptable item would include the C/A and whether the action was required for restart or postrestart. This prograrmatic concern was directed to the project it, action item N-52. In response, the project invoked Section 4.0 of Attachment I of SQEP-16 referring to the punchlist. EA Nuclear judged that the project response did not adequately address the concern.

However, as discussed previously for another concern about SYSTER inconsistencies (see section 7.7.1.1-l(b)), since the technical inportance of the punchlist supersededthatoftheSYSTERs,EANuclearjudgedthattheEATeam'sconcerns about the punchlist (expressed in action item E-83) superseded ours about the i SYSTERs and that the punchlist closeout statement was adequate C/A. Verification by EA Nuclear of proper determination of C/A and restart category of punchlist items and technically adequate reconciliation of punchlist/SYSTER differences in the punchlist closeout statement is required (observation N4).

2. Missino SYSTER Inputs

a. EA Nuclear noted that SYSTERs 83 and 61 did not list any FCRs in section 2.0 or include SQEP-II (reference 210) Attachments 3A and 38 forms in the appendices.

These technical concerns were directed to the project in action items N-54 and N-55, respectively. Inresponsetobothconcerns,theprojectstated that SQEP-16 did not require FCRs to be listed in section 2.0. EA Nuclear acknowledged that although all other SQEP-ll change documents were required to be listed, SQEP-16 had no such specific requirement for FCRs. EA Nuclear judged that this was acceptable because FCRs were evaluated only in conjunction with their related ECNs. In response to the concern presented in action item N-55, the project also stated that the SQEP-il forms were included in SYSTER 61. EA Nuclear acknowledged our oversight. However, in response to our concern about 7.7.1-3

missingFCRs,theprojectreferredtoprograndirectiveD8VP-D-86-005which removed these FCRs from the DB&VP- Since EA Aclear had expressed general concerns about DBVP-0-86-005 in action item H-56 (see section 7.5.1.1-l(c)), we elected to allow our specific concern about SYSTER 61 to be addressed by the projectalongwithourgeneralconcern. Verification by the EA Team of proper resolution of FCRs is required (observation N2).

b. Several SCRs were mentioned in SYSTERs 83 and 6' but were not listed in section 2.0 or individually evaluated in section 3.0. These technical concerns were directed to the project in action items N-54 and N-55, respectively, in response to the concerns, the project referred to program directive D8VP-0-06-019 which eliminated open SCRs from the DB&VP. Since the EA Team had expressed general concerns about DBVP-D46-Ol9 in action item E-77 (see section 7.7.2), EA Nuclear elected to allow our specific concerns about SYSTERs 83 and 61 to be addressed by the project along with the Team's general concern. Verification by the EA Team of proper determination of C/A and significance of open SCRs is required (observation EIO, see sections 7.7.2 and 7.5.1.1-l(g)).

c. SQEP-19 (reference 2il) Attachment I forms were not included in SYSTER 61. This technical concern was directed to the project in action item N-55. In response, the project conmitted to add these forms to SYSTER 61. EA Nuclear concluded that this C/A was adequate to resolve the concern but was unable to verify this C/A because the SYSTER 61 addenda was not available during the EA review. EA Nuclear verification is required (observation NS).

3. SYSTER Walkdown Boundary Differences EA Nuclear noted that SYSTER 83 did not definitively state what portions of the hydrogen reconbination subsystem of the CGCS were walked down or tested. This technical concern was directed to the project in action item N-54. In response, the project explained that two walkdowns were performed for the only two change documents directly af fecting the subsystem and that the surveillance tests applied to the entire subsystem. EA Nuclear concurred that this explanation was adequate.

l l 4. SYSTER ECN Evaluations

a. In SYSTER 6l, ECN L6713 replaced check valve 2-61-745 located inside containment on a glycol expansion bypass loop. The ECN checklist referred to the ECN modification criteria for testing requirements which only said " functional test" although the valve is required to be tested per SI 158.1 since it is a containment isolation valve. This technical concern over proper testing was directed to the project in action item N-55. Inresponse,theprojectstated that the SI was required to be performed before restart per normal SI procedures and therefore, did not have to be punchlisted. EA Nuclear concurred that this explanation was adequate.

b. In SYSTER 61, the evaluation for ECN 2548 included penetration Xil4 and Xil5 in a reanalysis of piping rigidly attached to the steel containment vessel but omitted similar penetrations X47A and B. This technical concern was directed to the project in action item N-55. In response, the project noted that X47A and B were both bellows-type penetrations which were not rigidly attached. EA Nuclear verified this and concluded that the piping reanalysis was adequate.

7.7.1-4 l

c. The evaluation of ECN L6752 in SYSTER 61 did not specifically address its impact on the ice condenser system. This technical concern was directed to the project in action item N-55 In response, the project noted that the ECN checklists had been conpleted specifically for the effect of that ECN on the ice condenser, even though that was not reflected in the evaluation text. EA Nuclear concurred that this explanation was adequate.

d. In the description of the evaluation of ECN L6645 in SYSTER 61, EA Nuclear noted that valve 2-FCV-61-193 was identified instead of valve 2-FCV-61-192. This technical concern was directed to the project in action item N-55. In response, the project coninitted to revise the error in the addendum to SYSTER 61. However, the addendtsn was not available during the EA review. Verification by EA Nuclear of appropriate revision in the addendum to SYSTER 61 is required (observation NS).

e. EA Nuclear noted that the description of the evaluation of ECN L6754 in SYSTER 83 appeared to conflict between the first and second paragraphs about techriical conclusions and what punchlist items remained to be addressed. This technical concernwasdirectedtotheprojectinactionitemN-54. In response, the project explained the description of the evaluation and confirmed that all associated punchlist items were on the January 30, l%7 punchlist with a prerestart status. EA Nuclear concurred in the explanation of the description and the status of the punchlist items. However, since the EA Team expressed general concerns about the punchlist in action item E-83 (see section 7.7.2),

EA Neclear elected to allow our specific concern about SYSTER 83 to be addressed bytheprojectalongwiththeTeam'sgeneralconcern. Verification by EA Nuclear of proper determination of C/A and restart category of punchlist items and technically adequate reconciliation of punchlist/SYSfER differences in the punchlist closeout statement is required (observation N4).

5. SYSTER Cumulative Effects Evaluation

a. SYSTERs 83 and 61 only addressed the cumulative effects of trodifications that were inplemented or were scheduled to be implemented by restart. Although this approach met the requirements implied by program directive 08VP-D-86-023 (reference 212), no consideration was given in the evaluations to the uninplanented portions of uninglemented or partially inplemented ECNs as explic3+iy required by SQEP-16. EANuclearjudgedthatthecumulative e m uation of unimplemented portions of ECNs as required by SQEP-16 was necessary because it may be just as important, if not more so, to address those changes that may not be inclemented by restart because they may be C/A modifications to restore systems to full conpliance with design requirements. Otherwise, isolated evaluations of inconplete trodifications may result in the deferral of the implementation of modifications that individually would not need to be inplemented by restart but which collectively could prevent systems from being in compliance. (This would be particularly true for ECNs resulting from the C/A for open SCRs which were eliminated from the DB&VP by 08VP-D-86-019. See section 7.6.2 for a discussion of EA Team concerns and observation E10 about this directive.) EANuclear'stechnicalconcernwasdirectedtotheprojectinaction item N-51. Af ter a series of exchanges, the project responded that uninplemented and partially inplemented changes would be evaluated against the as-built configuration per SQA-18) and SQEP-IS (references 215 and 214). The project indicated that conpletion of the SQA-183 Attachment 3 checklist would provide a review of all previously approved modifications which would be uninplemented at 7.7.l-5

               -.                     - _-. - .                           -                   -   - - - - - - - - - .                                                 - ~ . . . ~~- -_

l f restart along with the sequential effects on previously approved changes and vice l versa.- Based on this project comitment, EA Nuclear concluded that the C/A was adequate to resolve our concern. Verification by EA Nuclear is required inat the uniglemented and partially iglemented ECNs are adequately evaluated using _ S04-185, Attachment 3 including the cumulative effects of uniglemented portions on each other (observation N6).

b. EA Nuclear raised a generic concern based on the exeg tion of documentation only_

changes from the evaluation of cumslative effects. This concern was directed to theprojectinactionitemN-54. In response, the project comitted to address , this " doc eentation only ECll" concern along with our.other concern about the l l evaluation of caulative ef fects discussed above [see section 7.7.1.l-5(a)). However; the ultimate resolution of the other concern discussed above did not i

'                                                 address "docunentation caly ECNs" explicitly. In retrospect, EA Nuclear judged                                                         l 1

that any cumulative ef fects of docaentation only ECNs would have been l insignificant, would have been handled adequately under the normal design control process, and thus, did not need evaluation within the 084VP. EA Nuclear i concluded _that our concern did not require C/A. 3 3 c. ECN L5729 was evaluated in SYSTER 83 as a documentation only change since drawings were being revised to show an as-constructed penetration location.

                                                 'However, it appeared that consideration should have been given to the possibility j

that several subsequent engineering evaluations could have been performed using 4 the previous incorrect location. This technical concern over caulative effects

                                                  'wasdirectedtotheprojectinactionitemN-54. Inresponse,theprojectnoted that the drawing being revised was electrical and that the corresponding civil drawing had shown the correct location. EANuclearjudgedthatevaluationsor analysesintheprojectnucleardisciplinewouldprobablyhaveusedthecivil drawing and thus would have been unaffected by ECN L5729. EA Nuclear concluded

' that this explanation adequately addressed our concern.

d. EA Nuclear judged that the evaluation of cumulative effects and sequence of

;                                                     iglementation documented in SYSTER 61 for several valve-related ECNs (L5457,                                                       '

L58BI,'L5895, L6207, and L6643) was inadequate. This concern was directed to the

                                                                                                                                                                                       .i project in action item N-55. -In response, the project comnitted to address the sequence of implementation of the valve-related ECNs in the addenda to SYSTER

61. EA Nuclear concluded that this C/A would resolve this concern but was unable 10 verify the adequacy of the C/A because the SYSTER 61 addendun was not l

1 available during the EA review. Verification by EA Nuclear of appropriate revision in the addende to SYSTER 61 is required (observation NS). l ! 6. SYSTER and Punchlist Discrepancies I a. In SYSTER 85, the supporting electrical checklist for ECN L6552 referenced a PIR as requiring resolution. However, the PIR did not appear on the punchlist. This technical concern was directed to the project in action item N-54. In response, theprojectstatedthatthePIRhadbeencancelled. EA Nuclear concurred that ihe cancellation was appropriate and that this explanation adequately addressed 1 our concern, i 4 i 7.7.l-6

b. Section 5.0 of SYSTER 85 stated that with the closure of all punchlist items contained in section 5.0, the system would be acceptable. Since this did not distinguish between pre- and postrestart items, it inplied that all punchlist items must be closed before the system would be acceptable. This progrannatic concernwasdirectedtotheprojectinactionitemN-54. In response, the EA project invoked the punchlist as controlling the restart categoritation.

Nuclear concurred that this explanation adequately addressed our concern.

c. In SYSTER 61, the evaluation for ECN L6752 did not reference a punchlist or PIR nunt>er to provide a means of tracking a conclusion that calculation packages were in the process of being issued. This technical concern was directed to the project in action item N-55. Inresponse,theprojectstatedthatall calculations had been issued and that no punchlist reference was required. EA Nuclear verified this and concluded that this explanation adequately addressed our concern.

d. In SYSTER 61, SCRGENQAB8205 was evaluated as being conplete yet continued to appear on the punchlist as requiring a technical adequacy review. This technical concernwasdirectedtotheprojectinactionitemN-55. In response, the project stated that the punchlist item would be closed. EA Nuclear concurred thatthisC/Aadequatelyaddressedourconcernandjudgedthatitwasnot significant enough to require verification.

e. EA Nuclear noted the following four d acrepancies in SYSTER 61. The supporting mechanical checklist for ECN L6759 answered two questions with "not addressed" yet provided no punchlist or PIR nunt>ers. The reference to punchlist 5667 in several ECN evaluations was incorrect because this item had been transferred on the punchlist to punchlist $869. In Appendix 11 of SYSTER 61, ECN 2971 was identified as requiring a review of an FCR to be acceptable but the evaluation in section 5 and the conclusions in section 4 did not address this deficiency and no punchlist nunt>er was referenced. In section 5 ECN L6756 was evaluated as requiring resolution of a PIR but was not listed accordingly in secticn 4. These technical concerns were directed to the project in action item N-55. In response to these four concerns, the project comnitted to isste an addendum to SYSTER 61 incorporating proper punchlist references, deleting ECN 2971 from Appendix it, and listing ECN L6756 in section 4. EA Nuclear concluded that this C/A adequately resolved the concerns but was unable to verify it because the SYSTER 61 addendum was not available during the EA review. Verification by EA Nuclear of the C/A described above is required (observation NS).

f. In the evaluations in SYSTER 85 of SCRs SQNEEB8652 and 8654, inadequate justification was provided for postrestart categorization. Two SCRs were on i the punchlist for System 61 but were not included in SYSTER 61. These technical concerns were directed to the project in action items N-54 and N-55, respectively, inresponse,theprojectstatedthattheseSCRswereopenand thus eliminated from the 08&VP by D8VP-0-86-019. EA Nuclear also expressed a concern that SQEP-45 should be revised to require the punchlist to include all items resulting from the DBdVP even if they were being tracked independently (e.g.,SCRs). In response to our concern about SQEP-45, the project stated that although open SCRs were eliminated from the DB&VP, SEs have the option of punchlisting such items. Since the EA Team had expressed general concerns about 7.7.1-7 f

D8VP-D-86-019 in action item E-77 (see section 7.6.2), EA Nuclear elected to allow our specific concerns about SYSTERs 85 and 61 and SQEP-45 to be addressed by the project along with the Team's general concern. Verification by the EA Team of proper determination of C/A and significance of open SCRs is required [ observation E10; see sections 7.6.2 and 7.5.1.1-l(g)].

g. EA Nuclear noted the following discrepancies related to punchlist items. EA Nuclear found at least 21 punchlist items associated with System 85 that were not included in $YSTER 83. Also in SYSTER 83, the evaluation of ECN L6751 referenced EA Nuclear punchlist5359butgavenorestartcategorizationorjustification.

found at least 10 punchlist items associated with System 85 on the January 7, 1%7 punchlist with no restart categorization or justification, even though SYSTER 85 was issued Decent >er 10,1986. No restart categorization was provided for punchlists 729 and 5105 in either SYSTER 61 or the punchlist. In SYSTER 83, the evaluation of ECN L5729 stated that puachlist 5847 was crerestart but the punchlist showed postrestart. In SYSTER 61, the ovaluations of ECNs L6651 and L671) stated that punchlists 3714 and 4811 were to be "dispositioned" prerestart but the punchlist showed postrestart. EA Nuclear also noted an instance where two pairs of punchlist items were duplicated except that the restart categorizations conflicted. These technical concerns here directed to the projectinactionitemsN-53,-54,and-55. In response to these concerns, the project stated that SQEP-45 R2 trevised in response to EA Nuclear concerns discussed in section 7.7.1.1-l(c)J required tne SE to concur with the C/A and restart categorization of punchlist items affecting his system. However, EA Nuclearhadexpressedconcernsabouttheproject'spracticeofobtainingSE concurrence by telephone and from individuals other than the SE who had not been properly designated. Theseconcernsveredirectedtotheprojectinactionitem N-57. In response to the concerns expressed in this action item and in action item E-8), the project issued DSVP-0-87-002 requiring the SE to issue a punchlist closeout statement reconciling differences in restart categorization between the punchlist and the SYSTER [see section 7.I.I.1-l(b)]. EANuclearjudgedthat inis general C/A adequately addressed our specific concerns described above. Verification by E4 Nuclear of proper determination of C/A and restart category of punchlist items and technicilly adequate reconciliation of punchlist/SYSTER differences in the punchlist closeout statement required (observation N4).

h. Six independent punchlist itens (references 203 throu'h 200) wh8ch had either been closed or deferred until af ter restart were selected by EA Nuclear for review fran those assigned to the NLE as the RAP. EA Nuclear found that all six l

! items were acceptable. However, these items did not involve any technical decisions or substantial C/A. El Nuclear mada an exhaustive search of al! 150 items on the March 5, 1987 punchlist assigned to the NLE and determined th7t no itens that involved significant technical decisions or C/A had been closed during the EA review. In addition, no punchlist closeoat statements had been issued during the EA review by SEs to reconcile their SYSTER and the punchlist as required by DBVP-D-87-002. Therefore, EA Nuclear could not conclude that the punchlist or punchlist/SYSTER reconciliation process was being adequately conducted. Verification by EA Nuclear of proper determination of C/A and restart category of punchlist items and tect'aically adequate reconciliation of punchlist/SYSTER dif ferences in the punchlist closecut statement is required (observation $l4). 1.7.1-8

7. Training Based on inconsistencies observed in various work products and on discussions with project personnel, it appeared to EA Nuclear that adequate training in SQEP-45 had notbeenprovidedtoprojectpersonnel. This technical concern was directed to the project in action item N-52. In response, the project provided representative training records. Although several individuals were indicated on those records as having been trained after the issuance of their SYSTERs, EA Nuclear concluded that this C/A was adequate to resolve the concern because the trained personnel were still actively involved in the current punchlist closeout process. EA Nuclear concluded that this C/A was adequate to address our concern.

7.7.1.2 Conclusions The Nuclear discipline of the EA Team had two observations related to SYSTERs. The concern was expressed that the SYSTERs did not evaluate the cumulative effects of the uninplemented portions of uninglemented and partially inplemented ECNs as required by SQEP-16. The project conmitted to document an equivalent evaluation on the SQA-183, Attachment ) checklists for all these ECNs instead. Since the agreed-upon C/A vas not conpleted during the EA review, EA Nuclear verification is required (observation N6). A nuntier of concerns were expressed about the progranaatic and technical adequacy of SYSTER 61. The project conmitted to nake several changes and additions in the SYSTER 61 addendum to resolve these concerns. Since the agreed-upon C/A was not completed during the EA review, EA Nuclear verification is required (observation NS). With the exception of the concerns expressed in these two observations which require EA verification and determination of adequate innlementation of C/As, EA Nuclear concluded that the DB&VP SYSTERs were technically adequate as vehicles to assentile input data, evaluate them, and identify items needing further attention. The punchlist evolved to take on the very significant technical role of determination and doctsnentation of C/A and restart categorization for items identified in the SYSTERs. EA

            'Huclear had one observation related to the punchlist. Concerns were expressed that the punchlist was not well controlled initially and that the SE was excluded from continued involvement. Theprojectrevisedprocedures,conductedtraining,andinvolvedtheSEsin concurring with punchlist items via a punchlist closeout statement. The concept of a punchlist closeout statement addressed EA Nuclear concerns about discrepancies between SYSTERs and the punchlist. EA Nuclear concluded that this C/A would be adequate. Since this C/A was not completed during the EA review, EA Nuclear verification is required (observation N4).

In addition, since an insuf ficient ntstt>er of technically significant punchlist items assigned to the NLE were closed during the review, further EA Nuclear verification of the punchlist process itself is required to determine adequacy (observation N4). i 7.7.I-9

7.7.1.5 References issue Reference Document Revision Date Title / Subject i SQEP-16 l' 9/ll/86 Procedure for System Evaluation and Developnent 2 10/17/06 of Systems Evaluation Report l 5 1/29/87 2 SQEP-45 1 12/5/86 Controf of DB&VP Action Items 2 1/29/87 5 2/12/87 5 828 861217 081 0 12/10/86 System Evaluation Report - Conbustible Gas Control System (83) 4 828 870103 001 0 1/2/87 System Evaluation Report - Ice Condenser l System (61) 5 0068 -- 12/16/ % Punchlist item 6 0099 - 12/16/06 Punchlist item i 7 0150 - 12/16/06 Punchlist item B 0149' -- 12/16/86 Punchlist item 9 0190 -- 12/16/06 Punchlist item 10 0247 -- 12/16/86 Punchlist item ll 0290 -- 12/16/86 Punchlist item 12 0514 -- 12/I6/E6 Punchlist item 15 0564 -- 12/16/86 Punchlist item 14 0606 -- 12/16/06 Punchlist item 15 0621 -- 12/16/06 Punchlist item 16 0651 - 12/16/86 Punchlist item 17 0695 -- 12/16/86 Punchlist Itan 18 0717 -- 12/16/86 Punchlist item 19 0836 -- 12/16/86 Punchlist item 20 0994 -- 12/16/86 Punchlist item 7.7.1-10

issue Revision Date iltle/ Subject Reference Document 1027

                               --            12/16/86      Pu'nchlist item 21 1049'
                               -             12/16/86      Punchlist item 22

2) l100 ~ 12/16/86 Punchlist item 1835

                                -            12/l6/86      Punchlist item 24 1855
                                 --      - 12/16/06        Punchlist item 25 1250
                                 --           12/16/86      Punchlist item 26 1276
                                  -           12/16/06      Punchlist item 27 1500
                                   --          12/16/06     Punchlist item 28
                !)))              --           12/16/86     Punchlist item 29 1%4
                                   --          12/16/36      Punchlist item 50 1418
                                    --         12/16/06      Punchlist item 31 1472
                                    --          12/16/86     Punchlist item 32 1531
                                    --          12/l6/06     Punchlist item 33
                                     --         12/16/86      Punchlist item 34       1568 1581
                                     --         12/16/06      Punchlist item 35 1624
                                    ~~           12/16/06     Punchlist item 37       1635
                                       ~         12/16/06 Punchlist item 1668
                                       --        12/16/86      Punchlist item 38 1676
                                       --        12/16/06      Punchlist item 39 40        170}
                                        --        12/16/06 Punchlist item Al       1765
                                        --        12/16/86     Punchlist item 42        1805
                                        --        12/16/06 Punchlist item
                                         --       12/16/06      Punchlist item

4) 1858 44 1866

                                           -      12/16/06 Punchlist item

! 45 1900

                                          --      12/16/86 Punchlist item 7.7.1-11

lssue Revision Date iltle/ Subject Reference Document 46 2017

                                                                -              12/16/06       Punchlist item 41        5I27             --              12/16/86      Punchlist Item 48        5359
                                                                 -              12/16/86      Punchlist item 49        5444
                                                                 --             12/16/06      Punchlist item l

5728

                                                                   --           12/16/06      Punchlist item 50 51        5729
                                                                   --            12/16/06      Punchlist item l                                       52        5731
                                                                   -              12/16/06     Punchlist item

5) 573)

                                                                    --            12/16/06     Punchlist item I

5845

                                                                    --            12/16/86     Punchlist item 54 55        5846
                                                                     --           12/16/06      Punchlist item f

56 4439

                                                                      --           12/16/86     Punchlist item 57        4712               --            12/l6/86     Punchlist item i

58 5847

                                                                      --           12/16/86      Punchlist item
 '                                       59        3008
                                                                       --          12/16/06 Punchlist item 60         3876
                                                                       --           12/16/06     Punchlist item 61        4598
                                                                        --          12/16/06 Punchlist item e

62 5680

                                                                        --          12/16/86      Punchlist item l

63 5732

                                                                          -         12/16/ %      Punchlist item 64        5761
                                                                         --          12/16/86     Punchlist item 65        5798
                                                                          --         12/I6/06 Punchlist item 66        5846
                                                                           --        12/16/86      Punchlist item 67        5919
                                                                           --        12/16/86      Punchlist item 68        6781                    -       12/16/06 Punchlist item 69        6818                  --        12/16/86     Punchlist item 70        3828
                                                                             --       12/16/86     Punchlist item 7.7.l-12

                 -        ~ . - .       .                              -              . _--

Issue Reference Document Revision Date Title / Subject 71 5866 -- 12/16/06 Punchlist item 72 6087 -- 12/16/06 Purichlist item 75 6148 -- 1/7/87 Punchlist item 74 6264 -- t/7/87 Punchlist item 75 6268 -- 1/7/87 Punchlist item 76 6269 -- 1/7/87 Punchlist item ( 77 645) - l/7/87 Punchlist item 78 6888 -- 1/7/87 Punchlist item 79 7006 -- l/7/87 Punchlist item j ! B0 7054 -- 1/7/87 Punchlist item 81 7091 -- 1/7/87 Punchlist Itan 82 7125 -- 1/7/87 Punchlist item 85 7218 - 1/7/87 Punchlist item 84 7256 -- 1/7/87 Punchlist item 85 7275 -- 1/7/87 Punchlist item 86 0070 -- 1/14/87 Punchlist item 87 0101 -- t/14/87 Punchlist item 88 0132 - 1/14/87 Punchlist item 89 0147 -- 1/14/87 Punchlist item 90 0188 -- 1/14/87 Punchlist item l 91 0245 - 1/14/87 Punchlist item 92 0288 -- 1/14/87 Punchlist item I i 95 0 38 ) -- 1/14/87 Punchlist item 94 0404 -- 1/14/87 Punchlist item l l l 7.7.1-13 l l

lisue Reference Document Revision Date Title / Subject 95 0551 -- 1/14/87 Punchlist item

        %        0566              --

1/14/87 Punchlist item 97 0604 - t/14/87 Punchlist item 98 0619 - 1/14/87 Punchlist item 99 0649 -- 1/14/87 Punchlist item 100 069) - 1/14/87 Punchlist item 101 0715 -- 1/14/87 Punchlist item f- 102 0729 - - - 1/14/87 Punchlist item 105 - 0992 -- 1/14/87 Punchlist item j 104 1025 - 1/14/87 Punchlist li m 105 1051 -- l/14/87 Punchlist item l 106 ll02 -- 1/14/87 Punchlist item 107 1855 -- 1/14/87 Punchlist item 108 1248 - 1/14/87 Punchlist item 109 1278 -- t/14/87 Punchlist item 110 1298 - - - 1/14/87 Punchlist item lli 1529 -- 1/14/87 Punchlist item 112 1562 t/14/87 Punchlist item l15 1416 -- 1/14/87 Punchlist item 114 1470 - 1/14/87 Punchlist item 115 1529 --- t/14/87 Punchlist item 116 1565 -- 1/14/87 Punchlist item 117 1579 -- t/14/87 Punchlist item 118 1622 -- 1/l4/87 Punchlist item 1 7.7.1-14

Issue Reference Document ' Revision Date Title / Subject il9 1633 -- 1/14/87 Punchlist item 120 1666 -- 1/14/87 Punchlist item 121 1678 -- 1/14/87 Punchlist item 122 1740 -- l/14/87 Punchlist item l 123 1767 -- 1/14/87 Punchlist item 124 1803 - 1/14/87 Punchlist item 125 1831 -- 1/14/87 Punchlist Item 126 '1856 -- l/14/87 Punchlist item 127 1868 -- I/14/87 Punchiist Item 128 2706 - 1/14/87 Punchlist item 129 3548 -- 1/14/87 Punchlist item 130 3349 -- 1/14/87 Punchlist item 131 3350 -- 1/14/87 Punchlist item 132 3351 -- 1/14/87 Punchlist item 135 3352 -- l/14/87 Punchlist item 134 3353 - t/14/87 Punchlist item 135 3354 -- t/14/87 Punchlist item 136 3355 -- l/14/87 Punchlist item 137 3356 -- t/14/87 Punchlist item 138 3357 -- '/14/87 Punchlist item 139 3714 -- 1/14/87 Punchlist item 140 3778 -- t/I4/87 Punchlist item 141 4427 -- 1/14/87 Punchlist item 142 4503 -- 1/14/87 Punchlist item 143 4515 -- 1/14/87 Punchlist item 7.7.l-15

issue Reference Document Revision Date title /Sub.iect 144 4542

                              -               1/14/87        Punchlist liam 145         4589              -              t/14/87         Punchlist item 146        4694             --              1/14/87         Punchlist item 147         4703             -              1/14/87         Punchlist item 148 -       4760              --             l/14/87        Punchlist item 149        4765              -              l/14/87         Punchlist item 150         4778              --             1/14/87        Punchlist item ISI         4791
                                  --            1/14/87        Punchlist item 152        4811
                                  --            1/14/87        Punchlist item 153        4865               --            t/14/87         Punchlist item 154         4876               --            1/14/87        Punchlist item 155        4916               --            1/14/87        Punchlist item 156        4928                -            1/14/87        Punchlist item 157         4937
                                     --          t/14/87         Punchlist item 158        4945
                                     -            1/14/87        Punchlist item 4908                --           l/14/87        Punchlist item 159 160         4996                --          t/14/87        Punchlist item 161        5022
                                      --           1/14/87        Punchlist item 162        5061
                                        --         t/14/87        Punchlist item 163         5063
                                       --          1/14/87        Punchlist item 164        5070
                                        --          t/14/87       Punchlist item 165        5073
                                         --         1/14/87        Punchlist item 166         5100
                                         --         1/14/87        Punchlist item 167        5105
                                          --         t/14/87       Punchlist item 168        5164
                                           --        l/l4/87       Punchlist item 7.7.l-16

) Issue Reference Docunent Revision Data Tit le/Sub.iect 169 5667 -- .l/14/87 Punchlist item 170 5748 -- 1/l4/87 Punchlist item 171 5785

                                           -            1/14/87           Punchlist item 172          5823               .---             l/14/87           Punchlist item 175           5869
                                         -              1/14/87           Punchlist item 174          5906
                                         --              l/f4/87         . Punchlist item 175          6082                 --

t/14/87 Punchlist item I I 176 6085 -- 1/14/87 Punchlist item 177 6084 -- l/14/87 Punchlist item f-178 6085 -- 1/14/87 Punchlist item l 179 6158

                                            --             1/14/87         Punchlist item i

180 6186 -- t/14/87 Punchlist item 181 6191 -- l/l4/87 Punchlist item 182 6214 -- l/14/87 Punchlist item 183 6422 -- l/14/87 Punchlist item i ! 184 6768 - 1/14/87 Punchlist item 185 6805 - t/14/87 Punchlist item l 186 6836 -- l/l4/87 Punchlist item 187 6857 -- 1/14/87 Punchlist item 188 6860 -- l/14/87 Punchlist item 189 6875 - 1/14/87 Punchlist item l 190 6%5 -- l/l4/87 Punchlist Itan I 191 6993 -- l/14/87 Punchlist item 192 7041 -- 1/14/87 Punchlist item

19) 7078 -- 1/l4/87 Punchlist item 7.7.l-17

issue Title / Subject Reference Document ' Revision _ Date 7110

                                               --         1/14/87      Punchlist item 194 7127
                                                --        1/14/87      Punchlist item 195 7205
                                                --        1/14/87      Punchlist item 1%

197 7243

                                                --        1/14/87       Punchlist item 198               7288
                                                 --       1/14/87       Punchlist item 734)
                                                 --        l/14/07      Punchlist item 199 200               6805 1/9/87       Punchlist item 201               6813                 --        t/8/87      Punchlist item 202               6818                  --       1/9/87      Punchlist item 8185                 --       2/3/87      Punchlist item 203 204               5417 12/15/86    Punchlist item 3828
                                                    --       12/15/86    Punchlist item 205 206               7651
                                                     --      1/14/87      Punchlist item 207                5332
                                                     --      2/16/87      Punchlist item 200               7812
                                                      --     2/6/87       Punchlist item 0       3/13/07      084VP System Engineer Concurrence with 209               D8VP-D-87-002 Closeout of Punchlist items 5       1/29/87      Procedure for Identifying and Assentling 210               SQEP-il Change Documenta1 ion 0      5/23/86      Comparison of Control Room As-Constructed 211               SQEP-19
                                                                         ' Drawings to As-Designed Drawings 08VP-D-87-023          0      12/2/86      Synergistic Evaluation of Modifications 212 3

12/11/86 Change Control Board (CC8) 213 SQA-183 0 8/1/86 Procedure for DNE Interface with Change 214 SQEP-15 ' Control Board (CC8) { ( i 7.7.1-18

7.7.2 Electrical TheElectricaldisciplineoftheEATeam(EAElectrical)reviewedtheproject'sSYSTERsand punchlist restart decisions and C/As for technical adequacy and for conpliance with SQEP-16 and SQEP-45 (references I and 2) and those procedures which assentled the SYSTER data, i.e., SQEP-il. -12, -14, -19, and -29 (references 3 through 7). SYSTERs selected for review include those which provide essential electric power to safety systems and/or contained various types of electric loads. (Information collected from the EA verification walkdown, which was previously discussed in section 7.2.2, was also utilized to assist in the SYSTER reviews.) This review also included a review of the project's punchlist items and completed C/As. Electrical-related punchlist items were selected for review as representativeofthetypesofC/Asrequiredbytheproject(e.g.,drawingrevisions, re-tests, calculations, WRs, and CAQs). The EA Electrical review was performed to ensure: e The ER/50s captured all additional changes since the initial markup of the SW810. e All change documents associated with the system have been evaluated for impact or. safety function of the system and were correctly dispositioned. e Theproject'sevaluationofengineered/nonengineeredandsystemconfigurationchanges was technically adequate, e The contined ef fect of modifications on the systen has been adequately addressed. e Punchlist items af fecting the SYSTER had been included and adequately addressed. e Restart categorization for punchlist items was acceptable. e C/A was technically adequate, o The conclusion of the SYSTER was technically adequate. 7.7.2.1 Details ihree SYSTERs were reviewed by EA Electrical. The Vital Control Power System and Auxiliary Power System SYSTERs (references B and 9) were evaluated in detail since they provide essential electric power to the plant safety systems. Additionally, the electrical portions of the CSS SYSTER for System 72 (reference 10), which contains various types of electrical loads, were reviewed. In general, the SYSTERs were found to be prepared in accordance with the governing procedures and were adequate except for the following areas: some change documents l ' omitted from the evaluations, it could not be determined if the proper restart criteria was used for some ECNs, circuit breaker setting discrepancies were not adequately evaluated, and some project C/As could not be verified at this time. Details of the reviews including concerns raised are presented below: 7.7.2-1

Vital Control Power System SYSTER (Reference 8) VP SYS-This SYSTER includes the 1. identified change documents and configurational changes that af fect the conponents within the SW81D for the VP SYS of calculation SQN-OSG7-048 (reference 11). The VP SYS provides the source of power for the Class IE plant control systems during normal and emergency conditions. In general, the EA Electrical's review of this SYSTER found it to be technically acceptable with rational engineering explanations given not only for changes that directly af fected the system, but also for changes that had no effect upon the system. However, the EA Team did note in their review the following deficiencies:

a. .Three change doctsnents were listed which had no ef fect upon the VP SYS but did involve System 82 (DG Starting Air System). The SYSTER for System 82 (reference

12) was checked to verify that the change documents had been properly evaluated for that system, but were not included. This deficiency was identified to the projectinactionitemE-80. The project responded by agreeing to address these missing change documents in an addendum to the 82 SYSTER. In addition, the project surveyed the other SEs to determine the extent of other missing change

doctanents from other SYSTERs. Thisprojectactionwasnotavailableforreview, and additional EA verification of this C/A is required (observation Ell).

b. Technical justification for portions of the VP SYS that were not covered by the system walkdown was not included. This was identified to the project in action items E41 and E-86. The project responded by providing the necessary technical justification in the VP SYS SYSTER Addendum, revision I (reference 15). This was reviewed by EA Electrical and found to be acceptable,

c. ECN L6746 (reference 14) was identified as within the VP SYS SW8ID boundary, but was not evaluated in the VP SYS SYSTER. Thiswasidentifiedtotheprojectin action item E-82. The project responded by including the evaluation of this ECN in the VP SYS SYSTER Addendum, revision 1. The VP SYS Addendum, revision I, was reviewed by EA Electrical and found to adequately address ECW L6746. This was acceptable.

l

d. Punchlist items 5586 and 6501 evaluated in the VP SYS SYSTER and identified as required for rastart conflicted with the SQEP-45 punchlist items 5586 and 650t (references 15 and 16), which indicated a postrestart categorization. This confiletwasidentifiedtotheprojectinactionitemE-85. Theproject responded by issuing a program directive, DBVP-D-87-002 (reference 17), to require the SE to concur with punchlist changes and perform a reconciliation of punchlist items (restart decisions and C/A identified) with the SYSTER. EA Electrical reviewed the directive and found it to be acceptable. However, the reconciliation ef fort was not complete at the time of review and additional EA verification of this is required (observation El2).

e. Two items identified by the SQfP-14 test review for ECN L5599 (reference 18) involving the mechanical interlock of the battery charger input circuit breakers and the LC relay were not included in the VP SYS SYSTER evaluation. This was identified to the project in action item E-84.

The project responded be explaining that the LC relay involves the fif th vital battery charger which is outside the SWBID boundary, while the circuit breaker mechanical interlock testing is addressed in the VP SYS SYSTER, addendum as punchlist item 9581. The EA Team found this explanation to be acceptable. The VP SYS SYSTER Addendum, revision I, was reviewed and found to adequately cover testing of the circuit breaker mechanical interlocks. 1.1.2-2

f. Several SQEP-45 punchlist items (e.g., 6406,6350,6215,7492,6514, reference 19 through 23) were omitted from the VP SYS SYSTER and conflicted with the restart categorization in the SYSTER. Thiswasidentifiedtotheprojectinactionitem E-85. Theprojectrespondedbyexplainingthatthesepunchlistitemomissions will be addressed in the VP SYS SYSTER Addendum and restart decision conflicts will be corrected in the reconciliation effort of punchlist items by the SE. EA Electrical's verification of the project C/A for this item is required (observation E12).

g. EA Electrical's varification walkdown of the VP SYS (which was discussed in section 7.2.2) identified vital inverter nameplate ratings that appeared to conflict with that in the VP SYS SYSTER. Ihiswasidentifiedtotheproject in action item E-E,6. The project responded by including a discussion of the inverter rating dif ferences in the addendum to the VP SYS SYSTER. VP SYS SYSTER Addendtrn, revision I, was rsviewed by the EA Team and thi:; discussion was acceptable.

2. CSS SYSTER (Reference 10) - System 72--The CSS in conjunction with other safety systems provides the removal of postaccident containment heat. This SYSTER captured all the identifieo type of engineered /nonen{ineered changes obtained from the thange documentation since the issue of the unit 2 operating license and within the system SWBID for the CSS calculation SQti-OSG7-048.

Generally, the review of the SYSTER by EA Electrical indica *ed that documentation and explanations for the changes af fecting the system, was technically adequate, and arrived at acceptable conclusions with reference to efforts of the various changes on The the system's ability to perform its safety functions for Chapter 15 events. following deficiencies were noted:

a. SCR SQNEEB8602 (reference 24) which dealt with the inappropriate use of conputer routed cele lengths required to support electrical design calculations had acceptabie C/A assigned. However, the SYSTER noted that no documentation existed to verify that designers were instructed on which cable lengths to use. PIR SQWEEB8654 (reference 25) and punchlist item 5755 for System 72 (reference 26) wore written to identify this concern. It was also noted that the SCR was evaluated as being acceptable if the PIR was confl eted before restart. However, a check of the renchlist printout dated February 4, 1987, for punchlist item 5755 showed this item was designated postrestart. This was unacceptable since it did not accomplish completion of corrective actions before restart. This generic concern was directed to the project in action item M-)). The project responded that all Sequoyah calculations required for restart will be revised as necessary to correct any deficiencies in cable leng'hs before restart. This was acceptable. However, the project has not corpleted this C/A for EA verificaticn (observation M)).

b. Several punchlist items were missing from the SfS1ER, e.g., 2056, 3958, 7144 (references 27, 28, and 29) while some were in the SYSTER, e.g., 7341, 5320, 5304,6875, but not on the punchlist, in addition, several punchlist items did J not have a restart decision shNn even though the SYSTER noted they would be done before restart, e.g., 0764, 0485, 3670 (references 30, ll, and 32). These concerns were addressed to the oroject in action item E-89. Theproject responded to the specific punchlist item problems by noting that some items were typographical errors which were addressed correctly in other areas of the repor t and some items which appeared to be in contradiction between various SYSif R 7.7.2-3

sections were not, since one area of the report covered the disposition of the punchlist item and another its required restart status. This response was acceptable and several specific punchlist items (e.g.,134l, 7391, 5309, 6875, 5320) were verified and approved by EA Electrical. Theproject'sresponsealso addressed the remaining generic aspects of the punchlist problems by referring to the C/A reconciliation ef fort which included a re-review of 100 percent of the (See punchlist items and correction of the SYSTER and punchlist conflicts. action item E-83.) This reconciliation effort was not coglete at the time of review and additional EA verification is required (observation El2).

3. Auxiliary Power System SYSTER (Reference 9) - AP SYS--The AP SYS provides the essential electrical power to the plant Class IE equipment during the normal and emer0ency conditions. Generally, EA Electrical *s review of this SYSTER found that I the project's preparation and documentation of the AP SYS SYSTER under SQEP-16 was adequate. However, during the EA Team's review, the following deficiencies were noted:

a. A comparison of SYSTER documents, WDP-AP-SI data sheets 485 and 488 (reference i

           }}) and Walkdown CRAD 45N749-5R21 (reference 34), showed that the breaker trip setting were not in agreement. This deficiency is similar to the problem previously identified by the EA verification walkdown and discussed in section 7.2.2. These breaker trip setting disagreements were also not identified or adequately evaluated in the SYSTER. This concern was reported to the project in action item E-88. TheprojectrespondedbystatingthattheWalkdownManager will take a sample of the 480V SHON 80 breaker settings and check these breaker settings with those from the AP SYS supplemental walkdown.         The results of this sagte will determine the extent of the problem and the need for further C/A.

l This project action was not complete at the time of review and EA verification is l required (observation EI). f b. Punchlist itans 8078 and 8079 (references 35 and 56) which are listed on the February 4, l%7 printout and identified as being part of the AP SYS were missing from the AP SYS SYSTER. Also punchlist item 4553 was included in the AP SYS SYSTER but was not listed in the February 4, 1987 printout. These types of deficiencieswerepresentedtotheprojectinactionitemsE-89,E-85,andE-85. In response to these deficiencies, the project indicated that they would handle the generic aspects of the punchlist problems by reconciling the punchlist with t the SYSTERs. This involves a re-review of 100 percent of the punchlist items and correction of punchlist problems (see action item E-83). This was acceptable. l However,theprojecthasnotcompletedthisC/AatthetimeoftheEAreviewand EA verification is required (observation El?).

c. Uniglemented ECN L5668 (reference 57) and ECN 26% (reference 38) WMe not adequately evaluated in the AP SYS SYSTER to identify that the o.9-kV SHDN BDs were not protected for bus f aults and that the bus differential relays may operate igroperly for faults such that equipment do.ege and technical specification conditions could results. Thus ECN L5668 was incorrectly evaluated as not required before restart, while ECN 2656 was incorrectly assumed to have been iglemented before OL. In addition, the applicable as<onstructed drawings incorrectly showed replacement dif ferential relays as being field installed for the above uniglemented ECNS. The incorrect restart decision on these ECNs also raised a general concern that proper restart criteria, especially as it pertains to Technical Specification Conditions, was not used in making the restart These decisions (Pre / Post) on the unimplemented and partially implemented ECNs.

7.7.2-4

concernswereaddressedtotheprojectinactionitemE-90. Theproject responded io the specific ECNs identifled by stating that ECN L5668 and 2656 would be addressed in the AP SYS SYSTER addendum. CAQR SQP870186 (reference 39) and punchlist item 9497 were also written to address the deficiencies of ECN 2656. EA verification of this specific C/A is required. In addition, the project's response to the general concern involving restart criteria was not cogleted at the time of review (observation El3).

4. C/A Verification Results--Sixteen punchlist items (references 40 through 55) were reviewed. All punchlist items except two (6399 and 6520), were determined to have acceptable restart categoritations, were technically adequate in scope and definition for the C/A, and had acceptable conpletion of C/A. The C/A exceptions are discussed below:

a. Punchlist item 6399, System 249 (VP SYS) (reference 40), did not have adequate scope defined for the corrective action and had no restart categorization assigned. The completed C/A was also found to be inadequate since the fuse size discrepancy identified by the punchlist item was not corrected or addressed by the drawing deviation that closed the punchlist item. These concerns were directed to the project in action item E-91. Theprojectresponsetothe concerns noted for punchlist item 6399 was not available for EA review (observation El4).

b. Punchlist item 6520, System 30 (reference 41), was written for PIRSQNEER0694 (reference 56). This PIR was upgraded to SCRSQNEE88728 (reference 57). The punchlist item which addressed the PIR not the SCR, was incorrectly designated as postrestart. Thistypeofdeficiencywasidentifiedtotheprojectinaction item E-83 with the project's response previously discussed in item Id.

In addition, the Part B C/A for CAQ SCR SQNEE88728 (reference 58), which was written in response to action item E-50 and discussed in section 7.5.2, was I reviewed and found to be inadequate. Theprojectstatesinpart8oftheSCR that no C/A was required since a CAQ was determined not to exist based on using Abnormal Operation Instruction (A01)-35 (reference 59) to dispatch an operator to verify the DG and Electrical Panel Vent Fans (EPVF) operability. However, a review of A01-35 found it to be inadequate to ensure the operator verifies fan operability. Thisconcernwasreportedtotheprojectinaction l ~ item E-50. The project has not established appropriate C/A for this concern (CAQR SQE870R01004).

c. In addition to the two punchlist item discrepancies, EA Electrical noted that project directive DBVP-D-86-Ol9 (reference 60) eliminated all open CAQs from the Da&VP review scope. The EA Team expressed the concern that the non-DB&VP personnel performing tha review would not have the necessary infornation readily available (i.e., SYSTERs, narked-up CRADs) and would not be as familiar with the system as the D88VP personnel. This concern was conveyed to the project in action item E-17. The project responded that the open SCRs/NCRs would be evaluated by non-DB&VP personnel in accordance with NEP-9.1 (reference 61). The EA Team concurred with this action item but considers it important enough to review and verify the adequacy of this process for these open SCRs/NCRs (observation E10).

7.7.2-5

7.7.2.2 Conclusions The Electrical discipline of the EA Team concluded that the SYSTERs were prepared in accordance with the governing procedures and were acceptable for identifying system discrepancies and for confirming that, upon completion of all prerestart discrepancies, the system's ability to perform its safety functions for the events described in Chapter 15 of the FSAR was not degraded. Subsequent to the conpletion of the SYSTER addendum programandcompletionofacceptableC/Aprograms,theSYSTERswerejudgedtobe technically adequate except for observation Ell which involves omitted chango document evaluations, observation EI) which involves inappropriate restart decisions of unimplemented ECNs that did not utilize proper restart criteria, and' observation El4 which involves inappropriate C/As performed on a punchlist item and a CAQ. The punchlist C/As reviewed, with the two exceptions identified above, were technically adequate. However, because of insufficient C/A results available for review the C/A

                                                     . program could not be verified to have met the overall program objectives. Additional EA verification is required in the areas of open CAQs and punchlist item C/As (observations EIO and El2).

7.7.2.) References issue Reference Document Revision Date Title i SQEP-16 } l/29/87 Procedure for System Evaluation and Development of System Evaluation Reports 2 SQEP-45 3 2/12/87 Control of Design Baseline and Verification Program Action items

                                                              }    SQEP-Il                                           4    8/18/86       Procedure for Identifying and Assmbling change Documentation 4    SQEP-12                                           2     7/31/86      Procedure for Evaluating ECN and FCN Documents 5    SQEP-14                                            I   9/19/86       Assently and Evaluation of Electrical Test Results 6    SQEP-19                                           0    5/23/86      Comparison of Control Room As-Constructed Drawings to As-Designed Drawings
                                                               ?    SQEP-29                                            1   7/18/06 Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant 8    System Evaluation 0                                                 VCPS, Vital Control Power System Report - VP SYS                                                      (825 870115 001) 9    System Evaluation 0                                    2/17/87       Auxiliary Power (AP) System Evaluation Report - AP SYS                                                      Report (828 870219 006) 10     System Evaluation 0                                    2/9/87       System Evaluation Report Containment Spray Report - System 12                                                  System - 72 (828 870211 119)

7. 7. 2--6

h i Issue Reference Document Revision Date Title 11 SQN-OSG7-048 2- 8/16/06 Identification of Systems Required for Sequoyah Restart 12 System Evaluation 0 12/12/82 System Evaluation Report, Standby Diesel l Report - System 82 Generator System - 82 (828 861251 160) 15 System Evaluation 1 3/16/87 VCPS, Vital Control Power System Report, Addendum - (828 870326 052) VP SYS 14 ECN L6746 0 8/4/86 Provide Isolation for Class IE Power Supply to Non-lE Tranformers 15 Punchlist 3506 -- 1/16/87 SQEP-45, Attachment 2 - System 82 16 Punchlist 6301 - t/15/87 SQEP-45, Attachment 2 - System 249 17 08vP-D-87-002 0 5/13/87 08VP Directive - SE Concurrence with Closeout of Punchlist items (825 870315 045) 18 ECN L5599 2 5/9/86 Add FifIh Vital 8atiery (825 860509 504) 19 Punchlist 6406 -- 2/4/87 Punchlist Printout - System 249 20 Punchlist 63}0 -- 2/4/87 Punchlist Printout - System 249 21 Punchlist 627) -- 2/4/87 Punchlist Printout - System 249 22 Punchlist 7492 -- 2/4/87 Punchlist Printout - System 249 23 Punchlist 6314 -- 2/4/87 Punchlist Printout - System 249 24 SCRSQNEE88602 0 2/4/06 Significant Condition Report Computer Routed Cable lengths are inadequate for Calculations (843 860207 933) 25 PlRSQNEE88654 0 7/16/86 Problem Identification Report, Inadequate f i- Corrective Action for SCRSQNEE88602 (845 860718 907) 26 Punchlist 5755 -- 5/3/87 Punchlist Printout - System 72 27 Punchlist 2056 -- 2/4/87 Punchlist Printout - System 72 28 Punchlist 1938 -- 2/4/87 Punchlist Printout - System 12 Punchlist 7744 2/4/81 Punchlist Printout - System 72 ( 29 -- 30 Punchlist 0764 -- 2/4/87 Punchlist Printout - System 12 31 Punchlist 0485 -- 2/4/81 Punchlist Printout - System 72 l 7.7.2-7

Issue Reference Document Revision Date Title Punchlist 3670 -- 2/4/87 Punchlist Printout - System 72 32 WOP-AP-Si 0 8/29/86 Auxiliary Power System - 33 AP SYS Supplemental Walkdown (Units I and 2) 21 2/26/86 Wiring Diagram, 400V Shutdown 181-3, Single ! 34 45N749-3 2/4/87 Line Punchlist Printout - System 201 35 Punchlist 8078 -- 2/4/87 Punchlist Printout - System 201 36 Punchlist 8079 - ECN L5668 0 1/15/82 Replace CO-2 Dif ferential Current Relays - 37 Unit I (SWP 820715 515) ECN 2656 0 10/19/79 Replace Existing CO-2 Relays - Unit 2 38 (SWP 791019 500) (Closed by SWP 8003 % 607) 0 3/12/87 Condition Adverse to Quality Report - 39 CAQR SQP870186 Auxiliary Power Bus Differential Relays on 480V SHDN BOS (SI) 870312 842) 1/18/87 SQEP-45, Attachments I and 2 - System 249 40 Punchlist 6399 -- l 1/15/87 SQEP-45, Attachments I and 2 - System 30 41 Punchlist 6520 -- Punchlist 4564 -- 1/23/87 SQEP-45, Attachments I and 2 - System 201 42 l/15/87 SQEP-45, Attachments I and 2 - System 82 l 43 Punchlist 6440 -- Punchlist 7872 -- - SQEP-45, Attachments I and 2 - System 202 44 2/6/87 SQEP-45, Attachments I and 2 - System 30 45 Punchlist 7123 -- Punchlist 6359 -- 1/22/87 SQEP-45, Attachments I and 2 - System 201 46 Punchlist 4194 - 12/23/86 SQEP-45, Attachnents I and 2 - System 201 47 Punchlist 6631 -- 1/21/87 SQEP-45, Attachments I and 2 - System 201 48 i Punchlist $300 -- -- SQEP-45, Attachments I and 2 - System 249 l 49 Punchlist 4430 -- -- SQEP-45, Attachments I and 2 - Sysfun 31 50 2/20/87 SQEP-45, Attachments I and 2 - Systan 202 51 Punchlist 4566 -- Punchlist 6559 -- -- SQEP-45, Attachments I and 2 - System 201 52 , Punchlist 6573 -- 1/4/87 SQEP-45, Attachments I and 2 - System 201

                                           $3 Punchlist 8514           --         --         SQEP-45, Attachments I and 2 - System 201 54 7.7.2-8 1

l l Issue Reference Doctsment_ Revision Date Title 2/6/87 SQEP-45, Attachments I and 2 - System 201 55 Punchlist 8036 -- 0 l/30/87 Problem identification report DG Electrical - 56 PIRSQNEF88694 Panel Vent fan Indication in NCR (825 870130 049) j 0 1/30/87 Significant Condition Report - Failure to

                           $7      SCRSQNEE88728 Establish Proper Design input - Part A (825 870130 047)

SCRSQNEE88728 0 3/24/87 Significant Condition Report - Failure to 58 Establish Proper Deisgn input - Part B (Part 8) (825 870324 023) 7 10/22/86 Abnormal Operating instruction, Loss of . 59 A01-35 Offsite Power l 60 D8vP-D-86-Ol9 0 11/20/06 084VP Directive - SCR/NCR Reviews for SYSifR Justification of Open CAQs included in 084VP NEP-9,1 1 2/20/87 Nuclear Engineering Procedure, Corrective 61 Action (805 870220 503) l I 7.7.2-9

7.7.5 instrumentation and Controls the 18C discipline of the EA Team reviewed SYSTERs for rationale, cogleteness, accuracy, technical adequacy, and conformance to procedures. In addition, the SYSTERs and punchlist items were compared with regard to C/A and restart decisions. The review considered the following: o Conformance to procedure SQEP-16 (reference 1). e Adequacy of modification evaluation. e Cogleteness of justifications with regard to sequential and contined effects. e Adequacy of restart decisions and corrective actions, i e Cagleteness of inputs. i Accuracy and cogleteness of documentation supporting the existing plant configuration s at restart, e Adequacy of justification with regard to uniglemented or partially iglemented design changes. i 1.7.3.1 Details SYSTERs for the CSS, Primary Water Systems and Waste Disposal System were reviewed. EA l&C concluded that all aspects of the SYSTERs were satisfactory, except as described below:

1. CSS (SYSTER 72)--The review of SYSTER 72 (reference 2) resulted in three concerns regarding ECN evaluation summaries and one concern regarding a NCR evaluation sunnary.

The subject of one concern pertained to the absence of a SYSTER input related to transmitter power supply modifications. Inadequatetechnicaljustificationfornot iglementing an ECN was the subject of another ECN-related concern. The subject of the third ECN related concern pertained to the inco g lete ECN evaluation description with regard to an added electronic cogonent. The concern regarding the NCR pertainedtoaninadequatejustificationtodemonstratethattheNCRwasnota nonconforming condition,

a. ECN LS884 (reference 3) replaced existing transmitters with new qualified transmitters. The ECN evaluation sunmery made note that the existing transmitter l

power supplies had been modified to provide the proper voltage range required by the new transmitter. The power supply modification documentation was not included as an input to the SYSTER. This concern was presented to the project in action item I-55. Projectresponsewasnotavailableatthetimeofthisreport (see observation 13). 7.7.3-1

b. ECN L6674 (reference 4) is an unimplemented ECN which authorizes the replacement of annubar flow elements when they become defective. The ECN evaluation sunmary makes note that the corresponding unit I annubars have become defective.

However, the evaluation concludes that the unit 2 annubars do not require replacement prior to restart. This conclusion was based on inadequate technical justification. This concern was presented to the project in action item l-57. Project response was not available at the time of this report (see observation 13).

c. NCRSQNNEB8405 (reference 5) addresses the lack of control room automatic continuous indication to alert the operator that protection channels were being bypassed for testing as required by lEEE 279-1971, paragraph 4.13 (reference 6).

This NCR was determined by project not to be a nonconforming condition because ONP has adninistrative controls to ensure tags are placed on the main control board to alert the operator, and therefore, meets IEEE 279-1971, paragraph 4.15. l The intent of paragraph 4.13 is automatic continuous indication as required by RG l.47 (reference 1). This concern was presented to the project in action item l-58. TheprojectprovidedadequatedocumentationdemonstratingthatSQNPhad conmitted to the inplementation of the bypassed and inoperable status l'ndication (BISI) monitoring system designed to conform to RG l.47. BlSI is to be operable before the congletion of each unit's cycle four refueling outage. The SQN organization had been addressing the subject concern through the licensing group in response to NRC questions outside the DB&VP Program; therefore, follow-up ! verification by EA l&C is not required.

d. Review of ECN L5591 (reference 8) in SYSTER 72 led to a concern pertaining to the modification of a control switch in System 68. Modification to the control switches in Systems 68 and 72 is identical. The modification of HS-68-341A uses a diode; however, the sunmary of ECN L5591 in SYSTER 68 does not address the qualification of the diode. The concern was presented to the project in action item I-%. Projectresponsewasnotavailableatthetimeofthisreport(see observation 13).

2. Weste Disposal System (SYSTER 77)--The review of SYSTER 77 (reference 9) resulted in two concerns on ECN evaluation sunmaries and one concern on a NCR evaluation sunmary.

Thesubjectofoneconcernpertainedtotheincorrectremovalofexistingvalvesin the ER/SD and lack of discussions pertaining to a related postrestart ECN. Inadequate technical justifications for not inplenenting an ECN was the subject of the other ECN-related concern. The concern on the NCR pertained to the lack of discussion on an instrument which could potentially be the cause of a flow restriction in a relief valve discharge line, i t 7.7.3-2

a. ECN L5765 (reference 10) provides for logic circuit nodifications affecting two valves which were to be removed postrestart by ECN L5851 (reference 11). The intent to remove the valves was not contained in the SYSTER, but the ER/SO shows the valves removed. This concern was presented to the project in action item I-49. Project comitted to expand the ECN L5765 description by addendum to reference the postrestart removal of the valves and to correct the ER/SO to reflect the valves and logic configuration in the restart condition. Theproject subsequently provided an acceptable revised ECN description in addendum i to SYSTER 77. EA l&C verified that the addendum was accurate and coglete,

b. ECN L5851 (reference ll) was an uniglemented ECN which authorizes the installation of a new gas analyzer, postrestart. Justification not to iglement the ECN prerestart conflicted with the related DCR and USQO, which indicated that the existing gas analyzer was not operating accurately. The concern was presented to the project in action item I-50. Projectsubmittedadequate documentation to demonstrate that a revised method of operating the existing analyzer provides accurate readings. The project comnitted to expand the justification in the SYSTER (addendtsn 1) to reference the modified operational procedures to igrove accuracy. Theprojectsubsequentlyprovidedanacceptable revised ECN description in addendum I to SYSTER 77. EA l&C verified that the addendtsn was accurate and coglete.

c. NCRSQNSWP8202 RI (reference 12) addressed potential restrictions in the pressure relief valve discharge piping from the waste gas decay tanks. Thejustification addressed the technical acceptability of isolation valves in the relief path, but did not address radiation monitor RE-90-Il8 which is described as "in-line" and could also be a relief path restriction. The concern was presented to the projectinactioniteml-52. Projectprovidedadequatedocumentationwhich demonstrated that the radiation monitor could not adversely affect the relief path from the decay tanks.

5. Primary Water Systems (SYSTER Bl)--The review of SYSTER 81 (reference 13) resulted in two concerns on incorrect references: one concern on an incorrect walkdown package procedural instructions and one concern on inconsistencies between SYSTER and punchlist.

The subject of one concern pertained to incorrect references in the SYSTER ER/SD. One concern pertained to incorrect references in an ECN evaluation sunary and one l concern pertained to incorrect procedural instruction in the walkdown package I relative to the requirement to co g lete mechanical data sheets. inconsistencies between SYSTER and punchlist with regard to C/As and restart categories was the subjectofthefourthconcern,

a. The ER/SO for this SYSTER is a sketch generated for use in the SYSTER. The TVA drawing reference (47W819-1 R21) (reference 14) was not included and the references nude to ECN L5457 and ECN L6556 (reference 15) were not clear with regard to cogonents modified by each ECN. These concerns were presented to the project in action item I-48. The project comnitted to correct the ER/SD in f addendum I of the SYSTER. TheprojectproposedC/Awasadequateandrequires verification by EA ISC (see observation ll).

1.7.5-5

b. The description of ECN L5457 (reference 16) identified incorrect NCRs and also did not include all applicable NCRs as inputs to the SYSTER. This concern was presentedtotheprojectinactioniteml-51. The project conmitted to correct the NCR references in addendum I of the SYSTER and identified the NCRs as out of scope since they were EQ related. Project'sresponsetoth'sconcernwasadequate and the administrative action to remove the NCR references from the SYSTER does not require EA l&C verification,

c. Mechanical conponent nameplate data sheets in walkdown package (WDP-81) were not completed for the mechanical portion of the walkdown as required by the scope of the walkdown. The concern was presented to the project in action item I-55. The project advised that this was no longer required, and addendum I of the SYSTER will include a note in the walkdown package to that effect. Project'sresponse to this concern is adequate and the administrative action to revise the scope of the walkdown package does not require EA l&C verification,

d. Review of the punchlist for items related to ECN L5457, L5063, and L5095 (references 16, 17, and 18) revealed inconsistencies between the SYSTER and the punchlist with regard to C/As and restart categories. The concern was presented totheprojectinactioniteml-54. The project advised that any item with C/A and restart category changes from the SYSTER will be reviewed, reconciled, and l

documented in a final closure statement. TheprojectproposedC/Aisadequate and requires verifications by the EA 18C (see observation 11).

4. Verification of Corrective Actions and Restart Categories--Twenty punchlist items l

(references 19 thru 38) were reviewed to obtain a measure of assurance that punchlist l closeout activities were being satisfactorily identified and fulfilled with regard to restart status and C/As. Where punchlist entries were closed out, supporting documentation of conpleted punchlist activities were reviewed for acceptability. The punchlist items were satisf actorily identified, and conpleted activities were properly documented except for two items described below:

a. One concern pertained to C/A which required accuracy calculations to docunent the effects of replacement transmitters. Theprojecthaddeterminedthat Westinghouse calculation WCAP-il239 enveloped the ef fects of the three new transmitters and closed this punchlist item (reference 22) without demonstrating that the accuracy parameter of the new transmitters f all within the WCAP-il239 acceptable allowances. Theconcernwaspresentedtotheprojectinactionitem I-60. Projectresponsewasnotavailableattheatthetimeofthisreport(see observation 12),

f 7.7.)-4

b. TheotherconcernpertainedtoC/Awhichrequiredtheprojecttoprovide documentation verifying that cables have been evaluated for environmental suitability. Theprojectclosedtheirpunchlistitem(reference 26)with reference made to a memo; however,theproject'srecordsdidnotinclude The concern adequate evidence that the memoranden satisfied the required C/A.

was presented to the project in action item I-59. Projectresponsewasnot available at the time of this report (see obserwation 12). 7.7.3.2' Conclusions The system evaluations provided adequate rationale and documentation to support their technicaljustificationsandconclusions. However, a good portion of the evaluation necessary to conclusively determine and reconcile system restart status was deferred in the system evaluations to the design baseline punchlist. In turn, the disposition of punchlist items was insuf ficiently conplete to reflect the adequacy of that effort. 7.7.3.3 References issue Document Revision Date Title Reference 3 1/29/87 Procedure for System Evaluation and i SQEP-16 Development of System Evaluation Report 0 2/9/87 SYSTER 72 Containment Spray System 2 828 8702ll 119 ECN L5884 0 6/30/83 Replace Existing Transmitters with 3 Qualified Transmitters 0 6/2/86 Replace Original Flow Elements (I and 4 ECN L6674 2-FE-72-13 and 34) with Annubar Type ANR-16 l 1/7/85 Bypassed and inoperable Status Indication 5 NCRSQNNEB8405 for Solid State Protection System

                                                                   --   1971 Criteria for Protection Systems for Nuclear 6        IEEE 279-1971 Power Generating Stations Regulatory Guide                              5/73       Bypassed and inoperable Status Indication 7

for Nuclear Power Plant Safety Systems 1.47 0 6/7/82 Modification of Westinghouse W-2 Control 8 ECN L5591 Switches 0 1/15/87 SYSTER 77 Waste Disposal System 9 828 870117 472 0 12/23/03 Delete Full Open Limit Switches 10 ECN L5765 7.7.3-5

Issue Document Revision Date Title Reference ECN L5831 1 10/29/85 Add 02 Analyzer to Waste Gas Conpressors 11 Design, Headers 1 7/30/84 isolation Valves Added to Waste Gas Decay 12 flCRSQNSWP8202 Tank Violate ANSI 831.1 for Pressure Relief Valve Discharge Piping 0 1/29/87 SYSTER 81 Primary Water System 13 825 870130 005 21 9/16/82 Flow Diagram Primary Water 14 47WB19-1 1 12/10/85 Replace existing Namco Limit Switches with 15 ECN L6556 Envirorventally Qualified Switches 2 11/6/06 Replace Existing Solenoid Valves with 16 ECN L5457 Qualifled ASCO NP-l Series 1 7/30/06 Replace Containment isolation Check Valves 17 ECN L5063 with Soft Seat Check Valves 2 10/8/86 Modify Test Drain and vent Connections for 18 ECN L5095 Inproved Operability 3/3/87 Punchlist Printout System 72 19 1984 3/3/87 Punchlist Printout System 63 20 3029 3/3/87 Punchlist Printout System 63 21 3052

                                                                      -        3/3/87       Punchlist Printout System 3A 22        3588 3/3/07       Punchlist Printout System 72 23       3671 3/3/87       Punchlist Printout System 72 24       3682
                                                                        -       3/3/07       Punchlist Printout System M 25        3922
                                                                         -      3/3/87       Punchlist Printout System 81 26        4613
                                                                         -       3/3/87      Punchlist Printout System 38 27       4626
                                                                         -       3/3/87      Punchlist Printout System 3B 28       4636 3/3/87       Punchlist Printout System M 29       5271 3/3/87       Punchlist Printout System 38 30       5291
                                                                           -     3/3/87       Punchlist Printout System 3B 31       5309                                                                                                            ,

7.7.5-6

Issue Document Revision Date Title Reference I

                        -     3/3/87        Punchlist Printout System 38 32     5316 l
                        -      3/3/87       Punchlist Printout System 72    <

33 6078 3/3/87 Punchlist Printout System 61 34 6086 _3/3/87 Punchlist Printout System 72 35 7391 3/3/87 Punchlist Printout System 72 36 7649 - 3/3/87 Punchlist Printout System 38 37 7654 3/3/87 Punchlist Printout System 32 38 7794 7.7.3-7

                                                                                                         \

7.7.4 Mechanical The Mechanical discipline of tae EA team reviewed SYSTERs for cogliance with SQEP-16 and SQEP-45 (references I and 2). Three SYSTERs were chosen for reviews for reviews based both on availability and their performing a central role in the safe shutdowt. of the plant. The containment spray SYSTER was reviewed twir.e, initially as a draf t (reference 3) at project's request to provide early feedback to help inprove the quality of the SYSTER preparation effort, und later, when formally issued (reference 4). In addition, the Auxiliary Feedwater System (reference 5) and Standby Diesel Generator System (reference 6) were reviewed. The EA Mechanical review considered whether: e The ER/SD captured all required changes. e All applicable changes documents were evaluated for impact on the system. e Adequate technical justification had been provided for ECNs/FCNs, including uninglemented and partially implemented ECNs/FCNs not requiring further work, e AdequatetechnicaljustificationwasprovidedforSCRs/fJCRs. e ONP-generated drawing discrepancies were evaluated. e The ctsnulative ef fects of all system change documents were considered. in addition, a sangle of punchlist items from each system were evaluated for pre- and postrestart decisions and assigned C/A. 7.7.4.1 Details Following are the results of the SYSTER reviews:

a. CSS (System 72)--As discussed earlier, the CSS SYSTER was reviewed twice, once as a draft SYSTER when it was initially available for review in October 1986, and then as a final issued SYSTER in February 1987.

As a result of the review of the draf t SYSTER, five areas of concern were directed to the project in action item M-53. Each of these is discussed below with the corresponding resolutlon: o C/A for many of the SCRs/NCRs which affected the system were not included in the system evaluation. The requirement for establishing C/A for open SCRs/NCRs had previously been transferred out of the SYSTERs to SQEP-il (reference 7). The concern was that with this change, resolution of SCRs/NCRs, particularly the pre /postrestart decision and C/A would not be reviewed within the context of the other changes which had been made to the system. Projectsubsequentlyissued program directive DBVP-D-86-Ol9 which substituted assessment of these items either in the SYSTERs or SQEP-ll with processing and resolution in accordance with DNE procedure NEP-9.1 (reference 8) and tracking in the Tracking and Reporting of Open items (TROI) list. 7.7.4-1

Project comnitted to determining whether the C/A is required before restart for all open SCRs/NCRs. TheEArevieweragreedtotheprojectrequesttofollow this item through action item E-77. e in some cases, evaluation provided in the SYSTER was not clear or consistent. Cases were foured where an SCR was found to be acceptable in section 5 of the SYSTER, while the C/A sumery provided in section 4 was that further review was required, in response to this concern, the project issued program directive 00VP-D-86-Oll, which provided guidance on the amount of justification required and the need to develop consistent conclusions. Substantial i g rovement was noted in this area in later SYSTERs. This adequately resolved this item. e C/A sunneries for exceptions and unacceptable items in section 4 of the SYSTER i did not always state whether the C/A needed to be completed before or after l restart, as required by SQEP-16. For some items, this was being transferred to the SQEP-45 process. For some items, this was being transferred to the SQEP-45 process. EA felt that an i g ortant program objective was that the pre /postrestart determination for corrective action needed to be made within the context of the I various technical issues, both resolved and unresolved, which had been identified l for the system. It was felt that the eventual status of all such items would ultimately need to be collected either in a revision to the SYSTER or another ! system level docunent in order to meet program objectives rather than solely through the SQEP-45 process. Projectrepliedthataprogramdirectivewouldbo l issued to ensure a " buy-in" by the SE and DES on C/A categorization and to require l i a closure statement by all SEs providing concurrence for C/A definition and categorization of all such items which affect their SYSTERs. Further EA l verification is required upon issue of the program directive and solected products (observation M2). e There was no discussion of how the contained or synergistic effects were evaluated and found to meet the system basis. There was a statement that the evaluation had been performed, but it did not discuss what specific changes were evaluated and why they were found to be acceptable. Project issued directive DBVP-D-86-025 which outlined a specific method to be used for evaluating synergistic effects. This adequately addressed this item, o Finally, SCRSQNEEB0602 was found which had another SCR$QNEEB8654 written against it, which closed the former SCR. No evaluation of the SCR could be found in the SYSTER. This item was found to involve the incorrect use of cable lengths in certain electrical calculations and is discussed in detail in section 7.7.2. The formal issue of the CSS system evaluation report (reference 4) was substantially igroved over the draf t. The appropriate change docunents were discussed. Justification of uniglemented ECNs not required for restart, as well as the discussion for iglemented SCRs/NCRs, L-0CRs, TACFS, ONP-generated drawing discrepancies, etc., was adequate. Four punchlist items from the system (reference 9 through 12) were evaluated and are discussed below: 7.7.4-2

Punchlist item 3669 was found to be closed acceptably. Punchlist item 8081 specified cog letion of a calculation to substantiate containment spray flow orifices sizing which was the appropriate corrective action. As this calculation had not yet been performed, corrective action cogletion and punchlist closure could not be performed. Punchlist item 6070 correctly specified the required corrective action, that of SI-!66.6 functional tests which in turn require empletion of Sl-166.3 and Sl-166.4 tests. References 13 and 14 indicated that only $1-166.4 tests had been performed at the conipletion of the audit period, and it could not be verified whether further testingwasplannedbytheproject. Punchlist iten 3670 required physical replacement of certain drain connection fittings downstream of valve 2-72-541 and corresponding changes to drawing 47W812-1 (reference 15). Review of the documentation indicated that the item was closed i before the cogletion of work review by QA and closure of the work request. This concern was directed to the project in action item M-49. It was found that SQEP-45 requires only SE concur once prior to punchlist. As this was provided, this item was acceptable.

b. Auxiliary Feedwater (System 38)--The auxiliary feedwater SYSTER (reference 5) was l

I reviewed. This SYSTER was found to be adequate except for the concerns noted below: e There is no distinction provided in Table 2-1 for ECNs between the *0NP scheduled implementation status at restart" and the actual present status of ECN iglementation. There is the potential for ONP to reschedule the status of an ECN l without concurrence of the SE. Action item 0-7 addresses the need to reco the ONP ECN iglementation scheduled changes with the pre /postrestart schedule requirements for the changes. e No reconmendations are provided as to what C/As are reconmended in the SYSTER, other than a listing of the punchlist items that will track the C/As through the SQEP-45 process (see observation M2). Six of the punchlist items written against the system were reviewed for pre /postrestart decision and C/A (references 16 through 21). These were found to be acceptable except for punchlist items 5931 and 8075. Punchlist item 5931 involved a discrepancy between the system design criteria text C/A for (reference 22) and the actual plant pug suction low pressure switches. the punchlist item was iglemented through OlM-SQN-DC-V-13.9.8-3 (reference 23) to the auxiliary feedwater design criteria. However, it was found that C/A has not yet been assigned to the initiating PIR (reference 24) even though the punchlist item was closed. This concern was identified in action item M-52. The C/A assigned by the project to date is to correct the specific PIR and punchlist item noted by the action item and issue a directive to project personnel on the correct handling of punchlist items related to PIRs. The C/A for this action item is not ' complete because the review to date for the extent of the problem focused on only one of the four disciplines involved. The remaining action is to clearly define the extent of the concern and revise the proposed C/A. Because the review for Follow-up extent was inadequate, the action item has not been resolved on closed. verification for this concern is noted in observation M4. l Punchlist item 8075 related to the fact that the auxiliary feedwater design criteria (reference 22) does not adequately include valve stroke times. The item l l 7.7.4-3 L

is correctly classified as prerestart since the information is necessary to determine whether the valves are capable of performing their required safety functions. The proposed C/A was to revise th'e design criteria to include the missing information. The C/A was inplemented by issue of DIM-SQN-0C-V-3.9.8-3. Section 7 of the DIM addressed this item but did not discuss the significance of the listed valve time stroke limlis as they relate to the function of the Auxiliary feedwater System, not the source of the stroke times. - This concern was directedtotheprojectinactionitemM-51. (See observation Ml.) e While performing the review of the SYSTER, a deficiency in the document control original (RIMS) copy was noted. The text pages for section 4.0, " Exceptions and Reconmendations," and section 5.0, "Sunnery and conclusions," (pages 233 to 244 of 245 pages) were missing. The concern was that due to the large nunter of pages and attachments in the SYSTERs, there may be other omissions in the controlled copies / originals of the documents that had not yet been discovered. This concern wasdirectedtotheprojectinactionitemM-50. Projectreplywasthatthisand one other known case of this would be corrected, and that for SYSTERs issued in the future, the table of contents would include the nunter of pages in each section as well as the total nunter of pages, so that a completeness review could be performed by those responsible for entering the SYSTERs into RIMS. This ! adequately resolved the concern. e Finally, several drafting errors were noted on the ER/SDs for correction by the preparer of the drawings. They appeared to be the type of changes that would be required to be made to resolve ONp or walkdown package drawing discrepancies; I however, the initiating source of the changes were not referenced. it was found that SQEP-16 does not specify requirements for marking the drawings in this l regard, such as by referencing the applicable walkdown package item nunter, ECN

neber, etc. Since there is no requirement for this, an action item was not written; however, it is not felt to be good engineering practice. It is reconmended that in future ef forts of this type that procedural requirements be added to allow verification of the ER/SDs.

c. Standby OG System (System 82)--This system evaluation (reference 6) was reviewed and

found to be adequate with the exception of the items discussed below

e SCRSQNNEB8107 was reviewed to determine whether adequate technical justification was provided for inplemented SCRs. The SCR was written because the Watts Bar FSAR required blowout panels for the carbon dioxide storage tank room in the DG Building and the Sequoyah carbon dioxide storage room did not have blowout panels. The SCR/NRC identification form (reference 25) found the SCR resolution (no blowout panels required) as acceptable based on the fact that analysis showed l ' that the doors would blow out and serve the same purpose as blowout panels. The identification form did not reference a calculation nunter, which provided that analysis. This concern was presented for the project in action item M-48 was written and the project provided the analysis (calculation) (reference 26). The calculation was found to be based on certain assunptions about the pressures that the referenced doors would open at which could not be substantiated (CAQR SQE870R01001), e Section 4, " Corrective Action," does not address the pre- and postrestart status of the punchlist items identified during the various evaluations for this system. 7.7.4-4 l I

This concern was previously discussed earlier in this section in the action item M-33 discussion for the CSS (System 72). e In addition, several concerns were identified relatir,g to the evaluation of changes of the interfaces between systems. SQEP-12, revision I (reference 27) eliminated section C of the design review checklist, which specifically addressed the evaluation of system interfaces. SQEP-16 does not mention the need to evaluate interfaces as a part of the SYSTERs. The concern was that the interface evaluation and control process is one of the more difficult design processes to perform, and with the program enphasis on system boundaries, the engineers may not understand their responsibilities for this essential design activity. An i additional concern regarding interfaces between systems expressed by an NRC reviewer related to the updating of information which is shown on more than one drawing as a result of walkdowns. Specifically, the question of how and when the piping on any drawing which has not been walked down (generally the out-of-function piping) will be updated to reflect the actual plant configuration was requested. These concerns were presented to the project in action item M-10. e in response, the project issued program directive D8VP-D-86-003 emphasizing the need for engineers to identify changes on their system which could affect others and to notify those responsible for the systems of the potential effects. In addition, a project memorandum from D. W. Wilson dated January 30, 1987 (825 870130 014) (reference 28) was issued which clarified project policy concerning i out-of-function information on drawings. It also required that as drawings are ! revised, excessive out-of-function information was to be removed and that out-of-function information should not be used for design, operation, or maintenance of the plant. 7.7.4.2 Conclusions The Mechanical discipline of the EA Team reviewed one draf t and three final issue SYSTERs. In general, it was found that the issued SYSTERs were substantially inproved over the draft issue. Concerns which remain are CAQR SQE870R01001 and observations MI, M2, and M4. It is noted observations M1 and M4 were issued against a relatively small nuntier of punchlist items which were reviewed. In addition, some of those reviewed did not yet have C/A assigned. As a result, further project C/A definition followed by EA review is necessary before the punchlist item closeout process can be deemed adequate. ObservationM2requiresconfirmationofaprojectmethodofensuringadequateresolution and closure of corrective action for items which affect the SYSTER. Finally,CAQR SQEB70R01001 involves a specific technical issue growing out of the EA evaluation of a SYSTER which has not yet been resolved. With resolution of these items along with acceptable ovaluation of further project C/A and punchlist item closure, it is concluded that the projects ef forts were generally performed in accordance with the governing procedures. 7.7.4-5

7.7.4.3 References Issue Reference Document Revision Date Title i SQEP-16 5 1/29/07 Procedure for System Evaluation and Develognent of System Evaluation Report 2 SQEP-45 3 2/12/87 Control of D84VP Action items 5 SYSTER 72 Draft 10/1/96 Containment Spray System 4 SYSTER 72 0 2/9/87 Containment Spray System 5 SYSTER 38 0 - Auxiliary Feedwater System l 6 SYSTER 82 0 -- Standby Diesel Generator System 7 SQEP-il 5 1/29/87 Procedure for Identifying and Assenbling

     -                                                                            Change Documentation 8     NEP-9.1                     1             2/29/87       Corrective Action l

l l Punchlist 8081 0 1/28/87 ECN E2941 Resizes Containment Spray Flow l 9 Restrictor$

                   'O      Punchlist 3669 I                          l/25/07       Drain valve have a Cap instead of a Blind Flange 11     Punchlist 6079 0                          12/15/86      ECN L6697, Remove Clutch Tripper Fingers -

( Perform 51-166.6 12 Punchlist 3670 2 2/25/87 2-72-541 has Chicago Fitting Instead of Blind Flange 825 870)ll 034 -- 3/11/87 Memo from L. M. Nobles to D. W. Wilson, 13 SQEP-14 Retest Review l

                                                              --      3/5/87       Memo f rom L. M. Nobles to D. W. Wilson, 14     553 870305 851 Resolution of SQEP-14 Retest Package -

ECN L6697 47W812-1 11 - Confaltunent Spray Flow Diagram 15 16 Punchlist 59}l I 3/9/87 Revise Auxillary Feedwater Design Criteria to Match Plant 7.7.4-6 c - - - _ _ . _ _ _ _ . . - -

lssue Document. Revision _ Date_ Title Reference 2/12/87 Add Valve Stroke Times to Auxiliary Feedwater 17 Punchlist 8075 2 Design Criteria Flowdrawingdoesnotreflectinstailed 18 Punchlist }l24 -- configuration at 2-3-825

                                 --            -              AFW System Design SQN-DC-V-l).98 currently 19     Punchlist 5418                                   does not state the setpoints of the systems pressure switches.
                                                -              Original item 058-36 did not show the level 20     Punchlist 7515     --

of detail necessary to resolve drawing deviation incorporate PIR QA record change form 2-QA-038-2 Level indicating controllers UC-3-172-175-174 21 Punchlist 7657 -- and 175 provide signal to the turbine-driven pump level control valve - one motor-driven pung level control valve 7/11/86 Auxiliary Feedwater Design Criteria 22 SQN-0C-V-13.9.8 0 DIM to Auxiliary Feedwater Design Criteria 25 OlM-SQN-0C-V-l).9.8-5 PlRSQNEE886174

                                     --            12/8/86       SQN-0C-V-l).9.8 to Remove Redundant'   Pressure 24 1

Switches 1 6/25/86 SCR/NCR Identification Form (828 870116 445) 25 SCRSQNNE88107 NE8 810406 267 Calculation 26 Procedure for Esaluating ECN and FCN Documents 27 SQEP-12 4 2/12/97

                                       --            1/50/87      Meno from D. W. Wilson 28    825 870I50 014 7.7.4-7

7.7.5 Civil , The Civil discipline of the EA Team (EA Civil) participated in reviewing the adequacy of the DB&VP system evaluations performed in accordance with SQEP-16 (reference 1) and doctsnenting restart decisions and C/A for identified open items in accordance with SQEP-45 (reference 2). A system evaluation consisted of an engineering evaluation of all modifications which were individually evaluated by other DB&VP procedures to verify that changes did not degrade the system ability to mitigate FSAR Chapter 15 design basis events or violate licensing commitments. SQEP-16 provides for the accumulation of data on changes since OL, and the identification and justification of open items that will be completed i after restart. The results of each system evaluation are doctsnented in a SYSTER. SQEP-45 established a project punchlist to track DB&VP open items and provide a doctsnentation basis forprerestartC/Aorjustificationforapostrestartdetermination. EA Civil reviewed the technical adequacy of incorporating civil considerations for SYSTER evaluations, overall conclusions, and completeness of the previous change evaluations and data-gathering activities of the SYSTER. The depth of the EA Civil review included the following considerations:

1. The listing of inputs and the ER/SDs were reviewed to ensure capture of all types of changes within the scope for DB&VP (reference 3).

2. The technical adequacy of project evaluation and disposition of applicable change documents was evaluated, including TACFs, Category D FCRs, L-DCRs, inplemented SCR/NCRs, and ONP drawing discrepancies.

5. Walkdown discrepancies which could inpact the seismic qualification of systems were evaluated to ensure adequate resolution by the project.

   ',              4.      The overall assessment of the technical justification for acceptability of ECNs, FCNs, and inplemented SCR/NCRs.

5. The adequa:y of establishing all physical work required to be implemented before restart.

6. The interrelationship and cumulative ef fect of the applicable change documents and discrepancies included in the SYSTER.

7. The adequacy of the project evaluation of identified unacceptable items, including all punchlist items.

8. The adequacy of C/A inplementation for civil DB&VP SYSTER reviews to assure proper incorporation of required civil input of conpleted system evaluations.

SYSTERs were selected for review based on the following criteria: , e One of the cirlier SYSTERs issued e Mininun of one mechanical and one nuclear system o A system which had been selected for EA Civil evaluation of walkdown packages 7.7.5-l G

e Systems containing significant civil-related changes EA Civil also evaluated the adequacy of project dispositions of civil-related punchlist items in accordance with SQEP-45 (reference 2). The technical adequacy of the scope and definition of C/A was evaluated by EA Civil. The acceptability of the restart categorization,includingthejustificationforpostrestartclassificationwasalso reviewed. The review also evaluated the adequacy of intemented punchlist closure dispositions. Punchlist items were selected which covered exagles of each type of standard entries including open SCR/NCRs, partially iglemented ECNs, and the generic PIRs generated from civil DB&VP ECN evaluations (references 4 through 10). 7.7.5.1 Details The SYSTERs were reviewed by EA Civil included those for System 26, System 72, and System 74 (references Il through 15). The results of these reviews are presented below. l. SYSTER 26 (Reference ll) High Pressure Fire Protection--This SYSTER was one of the initial

              " fast track" mechanical system evaluations and covers the containment isolation portion of the High Pressure Fire Protection System. The system evaluation was found adequate and cogliance with the current revision of SQEP-16 (reference 1) except for two concerns, one relating to inadequate seismic qualification evaluation and the other to inadequate etpulative effects evaluation. The SYSTER properly addressed the civil input for ECN The conclusions prcperly evaluations and technical acceptance of iglemented SCR/NCRs.

referenced the need to disposition applicable open punchlist items. The punchlist was found to adequately capture civil 084VP unacceptable items, including the need to evaluate partially iglemented ECNs and open SCR/NCRs; however, an insufficient nunter were dispositioned for EA evaluation. The first concern found was the inadequate evaluation for ensuring the seismic This qualification of a TACF (reference 14) modifying a permanent plant cogonent. concernwasreportedtotheprojectinactionitemC-54. Theprojectprovidedan adequate justification for the acceptability of the TACF and conmitted to revise the SY$iER by addendum to include this justification. This item requires subsequent EA review of SYSTER addendums for incorporation of the justification. See observation C6. The second concern was that the cumulative ef fects evaluation was found to be inadequate. The matrix did not include FCNs, TACFs, or L-DCRs, and details of Theseconcernswerereportedtotheprojectin synergistic effects were not provided. action item C-55. The project conmitted to correct the cumulative ef fects evaluation as part of the planned addendum to this SYSTER. The addendum was not available for EA review and will require verification. See cbservation C6.

2. SYStER 72 (Reference 12) - CSS-The CSS evaluation was determined to be acceptable and in compliance with SQEP-16. Adequate technical evaluations were provided for the ECNs, and Very items requiring additional evaluation were appropriately entered into the punchlist.

few punchlist items had been dispositioned, thus, the EA Team could not fully verify However, a few punchlist items evaluated by the adequacy of restart decisions and C/A. project (references 15 through 21) were found to be adequately dispositioned. 7.7.5-2

One concern was identified which related to the sanple program for evaluating enbedment adequacy to justify NCRCENCEB8205 (reference 22) which did not adequately encompass the nonconformity problem description. Thisitemwasnotedtotheprojectinactionitem C-58. The project demonstrated the adequacy of sanple selection basis, recognizing the editorial error in the SYSTER. EA verified the technical adequacy of the calculation (reference 23) to establish that this deficiency was editorial in nature, and the SYSTER conclusion of acceptability was determined to be adequate.

3. SYSTER 74 (Reference 13) - RHR-The EA Team review of the system resulted in several concerns which are presented below. Unless noted as a concern, the EA review indicated that the remaining attributes were adequately addressed.

a. ECNs determined to be unacceptable were not included in the ECN exceptions.

b. The civil DB&VP did not adequately doctsnent their evaluation of walkdown discrepancies for impact to seismic qualification.

c. The SYSTER conclusions were inconsistent with punchlist dispositions.

d. Punchlist dispositions, restart decisions, and C/A were not always found to be adequate,

e. Partially inplemented ECN L6690 (reference 24) was not adequately evaluated to determine acceptability of current field status.

f. The design review checklist for ECN L5095 (reference 25) did not adequately incorporate the civil input.

g. The walkdown results were not adequately included in the ER/SDs.

TheconcernswerereportedtotheprojectinactionitemC-57. The project conmitted to make specific corrections to the SYSTFR by an Addendum issue. Walkdown discrepancies were reviewed by civil DB&VP as part of the SYSTER discipline, however, any civil involvement for resolution would be done in eccordance to SQEP-13 (reference 26) as drawing discrepancies. EA did find walkdown discrepancies were included on the punchlist. Subsequent EA verification will be required for addressing the adequacy project inplementation of C/A. See observation C6. Punchlist adequacy is discussed later in this section for C/A. The RHR SYSTER conclusions of adequacy were properly made contingent on punchlist resolution; however, an insuf ficient nunber of punchlist items were congleted to establish overall system adequacy based on civil considerations, in sistmary, these three system evaluations were found to be in accordance with the current revision of SQEP-16. The open civil items were adequately captured in the project punchlist; however, suf ficient ntstber of dispositions were not conpleted to determine overall adequacy. During the review of these three SYSfERs, it was noted that adequacy of open SCR/NCR was not included, consistent with project directive DBVP-D-86-019 (reference 27). Concern of excluding these documents is detailed in action item E-77 in section 7.7.2 of this report. EA did verify that civil DB&VP i 7.7.5-3

added these open SCRs/NCRs to the system punchlist which should incorporate this consideration into the final system evaluation if conpliance to current SQEP-45 requirements is maintained Corrective Action Thirty-five punchlist items (references 15 through 21 and 28 through 55) were reviewed during the three SYSTER evaluations. Few punchlist items contained the restart decisions, C/As identification, inplementation of C/A schedules, and required signatures. Punchlist items for other systems were also searched for obtaining a reasonable sangle of technical dispositions. Only a small nunt)er of the punchlist items reviewed could be found with any technical significance. The review of these items resulted with the following concerns: e insufficientjustificationforpostrestartdetermination e incorrect closure of open SCRs/NCRs e incorrect disposition of civil line organization which conflicts with previous civil DB&VP determinations e lack of any mechanism to incorporate punchlist dispositions into the system evaluation e A system which enables multiple disposition by different groups for different reasons without established revision basis These concerns were presented to the project in action item C-56. Theproject established proper C/A by conmitting to re-evaluate all previous punchlist dispositions to require concurrence from the SE and applicable DES. This procedure was established by the project via directive DBVP-D-87-002 (reference 56) to docanent required concurrence for punchlist items and acceptability of punchlist dispositions for system evaluations. EA Civil needs to verify the adequacy of project inplementation of this directive. (See observation C4.) EA performed an additional review of latter punchlist dispositions. The selection of punchlist items was based on obtaining exangles of each of the seven generic civil PIRs (references 4 through 10) resulting from the ECN evaluation, partially inplemented ECNs, and open SCRs/NCRs. A thorough search found very few conpleted in accordance with directive DBVP-D-87-002 which contained significant civil considerations. Fifteen items (references 57 through 71) were reviewed by EA which had, as a minimum, the civil DES concurrence with the civil line organization. The C/As were found to be appropriate, and the restart classification were generally found to be adequate. These items were primarily closed based on availability of the applicable qualifying documents. Punchlist items representing partially inplemented ECNs had not yet been dispositioned to enable EA evaluation. During this review, EA Civil identified preliminary copies of Attachment 2 of SQEP-45 in which the project was considering block closure of punchlist items involving a conmon identified problem by listing them on the same punchlist form. The seven involved civil PIRs (references 4-10) and included appropriate C/A and correct restart classification; however, in some cases, the basis for C/A was not clearly established. Therefore, further review by EA upon formal project innlementation is required to determine overall l adequacy of these generic dispositions. (See observation C4.) 7.7.5-4

7.7.5.2 conclusions The system evaluations were performed in accordance with SQEP-16, and punchlist dispositions wre addressed in accordance with SQEP-45. The required civil input was properly incorporated and well documented in the SYSTERs and system evaluation conclusions. A suf ficient ntsser of punchlist dispositions have not been completed to enable EA determination of technical adequacy for C/A and restart categorization. Subsequent EA review will be required upon project conpletion to assess the adequacy of this activity. See observation C4. 7.7.5.3 References issue Reference Document Revision Date Title 3 1/29/87 Procedure for System Evaluation i SQEP-16 2 SQEP-45 2 1/29/87 Control of D8&VP Action items 2 8/6/86 Identification of Systems Required for 3 SQN-OSG7-048 Sequoyah Nuclear Plant (B25 860006 805) Problem Identification Report B25 860819 019 4 PIRSQNCE88637 Problem Identification Report B25 060730 006 5 PIRSQNCEB8638 6 Problem identification Report B25,860819 018 PlRSQNCEB8639 Problem Identification Report 825 861211 020 7 PIRSQNCEB8657 Problem Identification Report 825 870324 017 8 PlRSQNCE88659 Problem Identification Report B25 861126 036 9 PIRSQNCEB8665 Problem Identification Report B25 870303 006 10 PIRSQNCEB8666 11 SYSTER for System 26 System Evaluation for High Pressure Fire Protection 12 SYSTER for System 72 System Evaluation for Containment Spray System 13 SYSTER for System 74 System Evaluation for Residual Heat Removal 14 TACF 1-85-092-26 Temporary Alterations Control Form Attachment 2 Punchlist item for System 72 15 of SQEP-45 I for item 5886 Attachment 2 Punchlist item for System 72 16 ) of SQEP-45 l for item 0153 l 7.7.5-5

Issue Reference Doctanent Revision Date Title 17 Attachnent 2 Punchlist item for System 72 of SQEP-45 for item 4981 18 Attachment 2 Punchlist item for System 72 of SQEP-45 for item 4509 19 Attachment 2 Punchlist item for System 72 of SQEP-45 for item 1476 20 Attachment 2 Punchlist item for System 72 of SQEP-45 for item 1744 21 Attachment 2 Punchlist item for System 72 of SQEP-45 for item 6065 22 NCRGENCEB8205 NCR 25 841 850705 006 0 7/5/85 CE8 Calculation Enbedded Plates with Multiple Attachments 24 L6690 Engineering Change Notice 25 L5095 ' Engineering Change Notice 26 SQEP-15 2 12/19/86 Procedure for Transitional Design Change Control 27 08VP-D-86-019 N/A ProhetDirective 28 Attachment 2 Punchlist item for System 26 of SQEP-45 for item 0572 29 Attachment 2 Punchlist item for System 26 of SQEP-45 for item 1920 50 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 4911 7.7.5-6 ._ _. . _~ ._, ._ _ _ . _ - _ . ..-.-, __ . _ _ .

issue Reference Doctsment Revision Date Title 51 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 5122 32 Attachment 2 , Punchlist item for System 74 of SQEP-45 for item 5192

5) Attachment 2 Punchlist item for System 74 of SQEP-45 for item 5098 34 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 0513 55 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 5159 36 Attactanent 2 Punchlist item for System 74 of SQEP-45 for item 0059 37 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 5180 38 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 0947 39 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 2749 l 40 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 755I 41 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 6122 42 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 4995 t

7.7.5-7

issue Reference Docuent Revision Date Title 45 Attactnent 2 Punchlist item for System 74 of SQEP-45 for item 4820 44 Attactnent 2 Punchlist item for System 74 of SQEP-45 for item 4854 45 Attactment 2 Punchlist item for System 74 of SQEP-45 for item 5968 46 Attachment 2 Punchlist item for System 74 of SQEP-45 for item 0415 47 Attachment 2 Punchlist item for System 82 of SQEP-45 for item 1227 48 Attachment 2 Punchlist item for System 82 of SQEP-45 for item 6655 49 Attachment 2 Punchlist item for System 82 of SQEP-45 for item 6242 50 Attachment 2 Punchlist item for System 82 of SQEP-45 for item 6I22 51 Attachment 2 Punchlist item for System 54 of SQEP-45 for item 7575 52 Attachment 2 Punchlist item for System 59 of SQEP-45 for item 5046 55 Attactnent 2 Punchlist item for System 81 of SQEP-45 for item 5047 54 Attachment 2 Punchlist item for System 50 of SQEP-45 for item 5078 7.7.5-8

issue Reference Document Revision Date Title 55 Attactumnt 2 Punchlist itern for System 67 of SQEP-45 for item 4520 56 00VP-D-87-002 N/A 5/15/87 ProjectDirective 57 Attachment 2 Punchlist item for System 87

            -of SQEP-45 for item 5721 58       Attachment 2                         Punchlist item for System 01 of SQEP-45 for item 905 59       Attachment 2                          Punchlist item for System 81 of SQEP-45 for item 5047 60       Attachment 2                         Punchlist item for System 74 of SQEP-45 for item 0859 61        Attachment 2                        Punchlist item for System 30 of SQEP-45 for item 5876 62        Attachment 2                       Punchlist item for System 38 of SQEP-45 for item 5776 65        Attachment 2                        Punchlist item for System 68 of SQEP-45 for item 4540 64        Attachment 2                       Punchlist item for System 62 of SQEP-45 for item 4969 Attachment 2                       Punchlist item for System 67 65 of SQEP-45 for item 944 66        Attachment 2                      Punchlist item for System 77 of SQEP-45 for item 5422 67        Attachment 2                       Punchlist item for System 30A of SQEP-45 for item 5415 7.7.5-9

Issue Reference Doceent_ Revision _ Oate _ Tltie Punchlist item for System 45 68 Attactment 2 of SQEP-45 for item 5575 Punchlist item for System 70 69 Attachment 2 of SQEP-45 for item 5602 Punchlist item for Open SCR/NCR SQNCE88622 70 1445 Open SCR/NCR 8622 Punchlist item for Open SCN/NCR 8607 71 1704 72 SCRSQNCE88714 825 870207 014 7.7.5-10

7.7.6 Operations Enaineerina The Operations Engineering discipline of the EA Team reviewed SYSTERs to confirm technical adequacy by verifying that configuration changes identified during system walkdowns were addressed in sections 3.0 and 4.0 of the SYSTER. Project evaluation and resolution of configuration changes were reviewed, and punchlist entries for each configuration change were reviewed for appropriate restart status and corrective action. CRADs were reviewed against configuration changes listed in the respective SYSTER and punchlist items to verify proper drawing revision. 7.7.6.1 Details Two SYSTERs were reviewed in detail: CSS (SYSTER 72) and CVCS (SYSTER 62) (references I and 2). In addition, two other SYSTERs were spot checked for uniformity in handling configuration changes: Auxiliary Feedwater System (SYSTER 38) and SIS (SYSTER 63) (references 3 and 4). Details of the review of the SYSTERs for operations considerations I are provided below: l. CSS - SYSTER 72 (Reference I)--Sections 3.B.1 and 4.8.1 summarize the project evaluations performed on the discrepancies noted in the system walkdown. Resolution l of the discrepancies and their acceptability were also documented, along with a reference to the punchlist item nurter used for tracking conmitment closure. Drawing den ations written to correct drawings were adequately referenced. From an operations viewpoint, the Containment Spray SYSTER provides adequate documentation of configuration changes and resolution of those changes. Ten punchlist items for the CSS configuration changes were reviewed (references 5

 -                   through 14). All items reviewed were acceptable with regard to restart.

categorization, description, and C/A specified. Congletion of corrective action was verified for three punchlist items that were closed. The inplemented C/As were adequate.

2. CVCS - SYSTER 62 (Reference 2)--Sections 3.B and 4.B sumnarize the project evaluations performed on the discrepancies noted on the original system walkdown and supplemental system walkdown. Resolution of the discrepancy was documented. Section 4.B lists the walkdown discrepancies that were categorized prerestart and the action that must be conpleted before restart. From an operations viewpoint, the CVCS SYSTER provides adequate documentation of configuration changes and resolution of those changes.

Ten punchlist items for the CVCS configuration changes were reviewed (references 15 through 24). All items reviewed were acceptable with regard to restart categorization, description, and corrective action specified. Adequate completion of corrective action was verified for six closed punchlist items.

3. Auxiliary Feedwater System - SYSTER 3B (Reference 3)-A spot check of the Auxiliary Feedwater SYSTER was performed to confirm all walkdown discrepancies were addressed in the SYSTER. The Auxiliary Feedwater SYSTER references the punchlist as the method of resolving the discrepancies. This method of dealing with configuration changes, although not as effective as addressing each change in the SYSTER itself, was considered acceptable by the EA Team.

7.7.6-1

A review of the Auxiliary feedwater System punchlist itons was performed to verify that all walkdown configuration changes were appropriately listed in the punchlist. Open punchlist items 2l06 and 2664 dealing with configuration changes had no " restart" determination indicated on the punchlist. Several closed punchlist items do not have

  " restart" determination listed; however, since these items have been dispositioned, the notation of restart was not considered significant in these cases. While all configuration changes noted during the system walkdowns were listed in the punchlist, the above omissions indicated that the punchlist alone is not a reliable source of items required for restart in the Auxiliary Feedwater System. The SYSTER relies on the punchlist to identify those. items required for restart. Punchikt item 2112 states that "2-LCV-3-111 has been removed for maintenance" and is obviously required for restart, yet the " restart" colunn for this item is blank and the item closed in the punchlist. This indicates punchlist items are being closed out without proper resolution. The project is working to improve the resolution of punchlist items.

Project inprovement in this area will be the subject of additional EA review at a later date.

4. SIS - SYSTER 65 (Reference 4)--A spot check of the Safety injection SYS1ER was All performed to confirm all walkdown discrepancies were addressed in the SYSTER.

walkdown discrepancies were listed in section 3.B.1 along with a discussion of the resolution and whether the resolution is pre- or postrestart. Areviewofthesafetyinjectionpunchlistitemswasperformedtoconfirmallwalkdown configuration changes were listed. All configuration changes were listed in the The punchlist although " restart" designation was not indicated for all items. In this case, punchlist was consistent with the SYSTER except for one instance. walkdown item 63-14 (punchlist item 5571) resolution calls for a WR to be issued to provide an identification tag for the 0.140-inch orifice. Punchlist item 3571 This for this discrepancy has been closed out without providing an identification tag. discrepancywasdirectedtotheprojectinactionitem0-24. Theprojectadequately addressed this concern by revising SYSTER 63 to exclude the requirement for tagging the orifice, since it is not a flow element orifice and not required to be tagged. EA Operations Engineering reviewed four CRAOS to verify that configuration changes noted during system walkdown are reflected in the revised CRADs. The latest available issues of drawings 47W809-l R24EE (reference 25), 47W6l0-62-2 Rl9R (reference 26), 47WB12-1 RilU (reference 21), and 47W610-72-1 RIOl (reference 28) were reviewed against configuration changes listed in the respective SYSTER and punchlist items. The drawings reviewed had been revised to incorporate some, but not all, configuration changes identifled during ihe system walkdowns. The reason for partial incorporation of the configuration changes is that some of the drawing deviations issued to address the configuration changes have not yet been processed as part of a workplan or ECN The drawing revision closeout and thus the affected drawing has not yet been revised. process is on-going at this time and some prerestart drawing deviations have yet to be incorporated. The drawing deviations that have been incorporated in the CRADs have been done accurately to reflect system configuration as found during system walkdown. 7.7.6-2

7.7.6.2 Conclusions The two SYSTERs reviewed in detail, SYSTERs 72 and 62, provide a thorough surmary of all configuration changes found during system walkdown and resolution of the changes. The Auxiliary Feedwater SYSTER (58) did not provide as thorough a suimary, but instead referred the reader to the punchlist for configuration change idontification and resolution status. All SYSTERs reviewed were technically adequate and prepared in conformance with SQEP-16 (reference 29). In addition, the EA Team concluded that all configuration changes are, in general, being ef fectively listed on the punchlist. Closeout of punchlist items will be revisited by EA at a later date. Revision of CRADs to date to incorporate drawing deviations resulting from system walkdowns has been done accurately. 7.7.6.5 References issue Reference Document _ Revision Date Title i SYSTER 72 0 2/9/87 System Evaluation Report for Containment Spray 2 SYSTER 62 0 2/17/87 System Evaluation Report for Chemical and Volune Control 3 SYSTER 38 0 2/15/87 System Evaluation Report for Auxiliary Feedwater 4 SYSTER 65 0 2/18/87 SystemEvaluationReportforSafetyinjection 5 System 72 0 5/3/87 Punchlist Item Nurser 03669 Punchlist 6 System 72 0 3/5/87 Punchlist item Nunter 0%70 Punchlist 7 System 72 0 5/3/87 Punchlist item Nurser 0%72 Punchlist 8 System 72 0 5/5/87 Punchlist Item Nunter 0%76 Punchlist 9 System 72 0 3/3/87 Punchlist item Nunter 0%79 Punchlist 10 System 72 0 }/3/87 Punchlist item Numer 0%80 Punchlist ll System 72 0 3/3/87 Punchlist item Number 03684 Punchlist 12 System 72 0 3/3/87 Punchlist item Nuter 0%85 Punchlist 7.7.6-3

issue Reference Document Revision Date Title System 72 0 3/5/87 Punchlist item Nunter 03687 13 Punchlist 14 System 72 0 3/3/87 Punchlist item Nunter 07743 Punchlist System 62 0 3/3/87 Punchlist Item Nunter 03060 15 Punchlist 16 System 62 0 3/3/87 Punchlist item Nunter 03078 Punchlist 17 System 62 0 3/3/87 Punchlist item Nunter 03079 Punchlist 18 System 62 0 3/3/87 Punchlist Item Nunter 0%30 Punchlist 19 System 62 0 3/3/87 Punchlist Item Ktster 0%33 Punchlist 20 System 62 0 3/3/87 Punchlist Item Nunter 0%38 Punchlist 21 System 62 0 3/3/87 Punchlist item Nunter 0%45 Punchlist 22 System 62 0 3/3/87 Punchlist Item Number 0%54 Punchlist 23 System 62 0 3/3/07 Punchlist item Nunter 0%55 Punchlist 24 System 62 0 3/3/87 Punchlist item Number 0%59 Punchlist 47W809-l 24EE 2/27/87 Flow Diagram, Chemical, and Volume Control 25 System 1/17/87 Mechanical Control Diagram, Chemical and 26 47W610-62-2 19R Volume Control System 47W812-1 11U 2/27/87 Flow Diagram, Containment Spray System 27 101 1/27/87 Mechanical Control Diagram, Containment 28 47W610-72-l Spray System 4 3/25/87 Procedure for System Evaluation and 29 SQEP-16 Development of System Evaluation Report 7.7.6-4

7.7.1 Quality Assurance The QA discipline of the EA Team review of system evaluations consisted of verifying that the non-CAQ status of the punchlist items were correctly categorized as not within the CAQR program. 7.7.7.1 Details Forty randomly selected punchlist items (references I through 40), which were designated Each item was evaluated to as open non-CAQ restart items, were sangled for this review. determine if it was appropriately classified as a non-CAQ. This review determined that 22 of the 40 items (designated with an asterisk in section 7.7.7.3) appeared to be candidates for CAQs based on the limited punchlist item description. However, CAQs were not prepared. Thiswasidentifiedtotheprojeciin action item Q-13. Noresponsewasreceivedfromtheproject,andtheitemreminsopen (see CAQR SQE870R01001). In addition, the NRC identified two observations (58 and 39) on one of their D88VP inspections which relate to system evaluations. These items were tracked by the EA Team as action items Q-05 and 0-06. 0-05 is an NRC concern with the C/R data base, and Q-06 pertains to Plant Operation Review Comnittee and periodic review of mintenance procedures. Both concerns have been adequately addressed and corrected by site personnel and were subsequently closed by EA. EA also issued action item Q-12 to track to completion a site QA condition adverse to reference 41) which concerned design baseline and calculation quality (CAR-86-05-012, problems. This item is presently open and unresolved (see observation Q2). 7.7.7.2 Conclusions The DB&VP project's evaluations of punchlist items to determine which should be designated as CAQs have been inadequate. Subjecttosatisfactoryresolutionof observation QO2 and CAQR SQE870R01002, this portion of the punchlist program is considered adequate. 7.7.7.3 References issue Reference Docunent Revision Date Title I 6102' -- -- Punchlist item i l 2 6740 -- - Punchlist item 3 7459 -- -- Punchlist item 4 7672' -- -- Punchlist item f 5 1979 -- -- Punchlist item 6 1980

                                                                                      -          --          Punchlist item 7      5262'                                                  -           -          Punchlist item 8       3583'                                           --                 --         Punchlist item 9      5634'                                            -                 --          Punchlist item 7.7.7-l

issue Reference Document Revision Date Title 10 62678 -- -- Punchlist item 11 7744 - -- Punchlist item 12 7747' -- - Punchlist item 15 7810 -- - Punchlist item 14 7814' -- - Punchlist item 15 7825 -- - Punchlist item 16 7875' -- -- Punchlist item 17 7950' - -- Punchlist item 18 8085* -- - Punchlist item 19 8102' - -- Punchlist item 20 8158 - - Punchlist item 21 1891 -- - Punchlist item 22 5574' - - Punchlist item 25 5595 - - Punchlist item 24 5821 -- - Punchlist item 25 5906' -- - Punchlist item 26 5979 -- -- Punchlist item 27 4552 - - Punchlist item 28 4570 -- - Punchlist item 29 4659' -- - Punchlist item 50 5255 - - Punchlist item 31 5292* - -- Punchlist item 52 5501' - -- Punchlist item 55 5380' - -- Punchlist item 34 5845' -- -- Punchlist item 35 6055 -- - Punchlist item 36 6107' - -- Punchlist item 37 6589' -- -- Punchlist item 38 6692 -- -- Punchlist item 39 7145 -- -- Punchlist item 40 7664' -- - Punchlist item di CAR-86-05-012 -- -- Corrective Action Report 7.7.7-2

7.8 Transitional Chance Control The 084VP program required that the SQN project have in place a change control process prior to restart. Tomeetthisrequirement,theSQNprojectpreparedandissuedSQEP-l),

      " Transitional Change Control." This procedure addresses requirements for the initiation, processing, controlling, and closing of engineering change documents, including interface requirements between DNE, Modifications, and Operations. The inplementation of SQEP-13 was essential to ensure that the intended process, in fact, achieved the desired results for reviewing those design control problems that lead to the 08&VP.

The EA Team reviewed the SQEP-13 process to verify that the process provided instructions to achieve the desired results and adequate interface controls were provided and associated procedures in place for DNE, Modifications and Operations to ensure that required interfaces were consistent and conglete to achieve the objectives of SQEP-13. The results of the Operations Engineering, QA, and Construction reviews are presented in sections 7.8.1, 7.8.2, and 7.8.3, respectively. 7.8-1

.        ..                                    _-        .    -      --                                                   _. -      .  .                                           ~ .-
         .7.8.1                       Oserations Engineering The Operations Engineering discipline of the EA Team involvement in the SQEP-15 transitional change control process (reference l} was to determine that adequate interfaces were in place between Plant Operations and other involved organizations and that the process could be offectively laplemented.

7.8.8.1 Details EA Operations Engineering reviewed SQEP-15 (reference 1) to determine Plant Operations 1 involvement in the transitional design change process. Since a very limited nunter of ECNs were processed ty the SQEP-15 program to date and they required little or no involvement from Plant Operations, it was not possible to review the implemented work to make an assessment of the ef fectiveness of the transitional design change process with regard to Plant Operations. Therefore, EA Operations Engineering reviewed SQEP-15 to determine if Plant Operations interfaces were appropriately addrest.ed. The results of the review are as follows:

a. SQEP-15 R2 contains Plant Operations interface in steps 4.1.2,4.1.5,4.1.15,4.1.17, 4.1.18, and 4.4.2.

b. DNE's Operations Engineering Services (CES) is also involved at step 4.1.15 for input on inservice inspection and system operabilityAnsintainability/ reliability. A review of OES input by Plant Operations would enhance this step.

c. In step 4.1.18, a " verification" that design is conglete and data sheets list all affected documents is required from all disciplines without specifying the form (e.g., ~

memo, form) on which this " verification" is to be provided. I J d. Step 4.1.25 should contain a dedicated signoff block for Plant Operations in section D of the ECN cover sheet. i

e. Step 4.l.26 should include Plant Operations in ECN distribution, i

f. Step 4.l.55 should include notification of Plant Operations to revise SI/SOI procedures.

j 7.8.l.2 Conclusions Procedure SQEP-15 is technically adequate and appears to be workable in its present form. Af ter more experience is gained using the SQEP-15 process, the procedure could be further enhanced by adding dedicated signoff blocks for Plant Operations in sections B and D of the ECN cover sheet. Plant Operations should also review OES input at step 4.1.15. 7.8.l.3 References ! Issue

;                                                    Reference Document         Revision                      Date                        Title I        SQEP-l3         2                         12/19/86          Procedure for Transitional Design Change Control i

1~ 1 [ 7.8.l-l 1

7.8.2 Quality Assurance The QA discipline of the EA Team reviewed the transitional design change control program to verify that the program was procedurally controlled, adequately implemented, and no anticipated progranmatic dif ficulties were encountered. The EP Team also reviewed this program to determine if the interfaces had been adequately established between DNE, Site QA, DNC, and the Plant Staf f and determined if previously identified design change control weaknesses had been corrected. This review was performed by verifying that the processing of a selected sample of ECNs by the transitional design change control procedure complied with the procedure requirements. SQEP-l) (reference I) was developed and issued to comply with a SQN conmitment made in the Nuclear Performance Plan Volume 11 (reference 2). This conmitment required that a transitional design change control system be inglemented before restart to inprove the existing design control process and provide an effective transition to the permanent system. SQEP-13, however, contains a waiver clause which allows the SQN Project Engineer to grant waivers to this transitional design change control process. This waiver allows modification design wcrk to be performed under SQEP-Al-ll (reference 3), the old design change control process. 7.8.2.1 Details During the EA review of the SQEP-15 program, ECNs which were processed via a waiver to SQEP-13 (i.e., SQEP-Al-II) were found to be the rule rather than the exception. Out of 87 ECNs checked by EA, only 8 had been processed through SQEP-13. SQN had conmitted to the NRC to having an " implemented" transitional design change control program prior to restart. This lack of utilization of the new transitional change control process was presentedtotheprojectinactionitemQ-il. At the time of this writing, no response to this action item had been received by the EA Team (see observation Q04). All of the 8 ECNs processed through the new transitional design change control process involved very minor modifications and few required any drawing changes. Also very little field work had been acconplished at the time of the review and none of the 8 ECNs were closed. Because of the nature and status of these ECNs, the EA Team was therefore unable to make a conclusive adequacy assessment of the inplementation of the transitional design change control program at this time. However, a preliminary review was performed to determine any obvious problems to date in the transitional design change control process. Six of the eight total SQEP-13 ECNs were selected for this review, namely ECNs L7000, L7061, L7012, L7083, L7078, and L7015 (references 4 through 9). These were checked for compliance with the basic requirements of SQEP-13. In general, several program concerns were identified by the review team during this review. These included requesting additional signoffs in the ECN review process and need for identification and/or clarification of certain important items, such as who approves ECNs and initialing section 8 of the ECN cover sheet even if no involvement is indicated. Theseprogramconcernswerepresentedtotheprojectinaction item Q-09. No response to this action item has been received. (See observation Q3). 7.8.2-1

in addition, ECNs L6828 and L6829 (references 10 and (1), which were processed via SQEP-Al-ll, were also reviewed to verify that waivers to SQEP-13 were appropriately docisnented. The following presents the results of these ECN reviews:

1. ECN L7000 (Reference Authorizations, 4)--ECN preparation,L7000 was theand review, approvals, first ECN toofbe written distribution SQEP-13 process.

this ECN were reviewed and found to be acceptable. Portions of section 8 of the ECN cover sheet were not appropriately initiated, however. Also, the ECN package index These deficiencies were did not accurately reflect the ECN package contents.No response to this action item ha presentedtotheprojectinactionitemQ-09. been received. (See observation Q3).

2. ECN L7061 (Reference 5)--This ECN was developed to address corrective action for an SCR.

The ECN was reviewed for proper authorization, preparation, review, approval, All areas were found acceptable except the ECN package index was and distribution. No not accurate. ThisdeficiencywaspresentedtotheprojectinactionitemQ-09. response to this action item has been received. (See observation Q3). 3. ECN L7012 (Reference 6)--This ECN was found to be processed in accordance with SQEP-13 requirements. It contained the required authorization, preparation, reviews, and approvals. No problem areas were identified in this review.

4. ECN L7085 (Reference 7)-This ECN contained all appropriate authorization, Approval was granted to this ECN to use preparation, reviews, and approvals.

as-designed drawings in lieu of configuration control drawings (CCDs) on February 10, 1987,bytheProjectEngineer. This exception was given in order to expedite the No A CCD will be originated prior to completion of field work. start of field work. concerns were identified in the review.

5. ECN L7078 (Reference 8) and ECN L701) (Reference 9)--All reviews and approvals were found acceptable except in section B of the ECN cover sheet; all boxes checked "no" were not initiated. Also, Operatic'ts Engineering Services did not sign for review and approval in the modification criteria section nor in section D of the ECN cover sheet as required by SQEP-13 Thisdeficiencywaspresentedtotheprojectinaction item Q-09. No response to this action item has been received. (See observation Q3).

6. ECN L6828 (Reference 10)-A waiver to SQEP-15 was granted by the Project Engineer to The allow ECN L7027 to be worked per SQEP-Al-ll under another new ECN (L6828).

reason given for requiring the waiver was to accelerate design completion to support restart. The waiver was issued December 3, 1986. No concerns were identified in this review.

7. ECN L6829 (Reference ll)--On Novent)er 28, 1986, a waiver was granted by the Project The reason given for the waiver was Engineer to process this ECN per SQEP-Al-II.

that DNE could not support a January target date fer completion if SQEP-13 was used. No concerns were identified in this review. 7.8.2-2

7.8.2.2 Conclusions The adequacy of the inplementation of the transitional design change control program could not be assessed by the QA discipline of the EA Team because of the infrequent use of the new process at the time of this report writing. However, all waivers to the SQEP-15 process which were reviewed were properly documented. 7.8.2.3 References issue Date Title Reference Document _ Revision 2 -- Procedure for Transitional Design Change i SQEP-13 Control 2' - -- -- Nuclear Perfornence Plan - Volume ll 2 -- Engineering Change Notice 3 SQEP-Al-Il

                                   --        --           Engineering Change Notice 4      ECN L7000 ECN L7061     --         --          Engineering Change Notice 5
                                    --        --          Engineering Change Notice 6      ECN L7012
                                    -          --         Engineering Change Notice 7      ECN L7083 ECN L7078       --         --         Engineering Change Notice 8

ECN L7013 - -- Engineering Change Notice 9

                                      --         --        Engineering Change Notice 10     ECN L6828 Engineering Change Notice ll                     --        --

ECN 16829 7.8.2-3

7.8.3 Construction. The Construction discipline of the EA Team reviewed the transitional change control program to

     - determine the adequacy of modification constructability for the new ECNs (L7000 series) and modification workplan packages, associated documents, and drawings. The review covered the process from initiation, approval, and issue of an L7000 series ECN       package by DNE through the To determine adequacy of the implementation of the modification with the DNE workplan package.

process the following attributes were considered: cogleteness of the ECN package, clarity of scope-of-work definition in the ECN, accuracy of the CRADs, completeness of the workplan to accurately reflect the ECN modification, and completeness of implementing instructions. 7.8.3.1 Details

         - Two ECNs (L7012-System 364 and L7083-System 82) (references I and 2) were reviewed along with There their associated workplans (12269-System 364 and 12374-System 82) (references 3 and 4).

were a limited nueer of ECNs processed through the new SQEP-l3 (reference 5) transitional The change control program at the time of this review (i.e., 8 of 87 potential ECNs). remaining ECNs received waivers and were processed in accordance with SQEP-Al-li (reference 6)

         -which is permitted by SQEP-13 The results of the EA Construction reviews of the two ECNs and two workplans are presented below:

1. ECN L7012-System 364 (Reference I) - The scope of this change involves the replacement of the existing protective coating on the steam generator and pressurizer elevated slabs, elevation 781, unit 2, with a technologically advanced co d ination coating system. It was issued to implement FCR 4735 The ECN package had been acceptably evaluated, documented, and processed in accordance with governing procedures and comnitments. A DNE Task Engineer had been assigned and the package contained the required cover sheet, USQD, index, appendix R review, modification criteria, FCR, EQ review checklist, CCB review, drawing data sheets, and other required reviews and approvals. It provided sufficient information to ensure a detailed workplan, effective installation, QC inspections, and final documentation. Workplan 12269 was written by Modifications to iglement the entire scope of this ECN. Field work was in process at the time of this evaluation.

2. ECN L7083-System 82 (Reference 2) - The scope of this change involves the installation of oil baffle plates to the crank case pressure detectors on each standby diesel generator to prevent a false high pressure trip which may occur during engine acceleration following a cold start caused by engine lube oil surges into the cavity of the crank case pressure detector. It was issued to implement FCR 5053.

The ECN package had been acceptably evaluated, doctanented, and processed in accordance with governing procedures and conmitments. A DNE Task Engineer had been assigned and the package contained the required cover sheet, USQO, index, appendix R review, modification criteria, FCR, EQ review checklist, CCB review, seismic qualification, vendor information, TACF, drawing data sheets, and required reviews and approvals, it provided sufficient information to ensure a detailed workplan, effective installation, QC inspections, and final documentation. Workplan 12374 was written by Modifications to implement the entire-scope of the ECN. Field work was in process at the time of this evaluation. 7.8.3-1

5. Workplan 12269-System 564 (Reference 5) - This workplan was written by Modifications to implement DNE ECN L7012 which authorized the replacement of the protective coating on the It was the only steam generator and pressurizer elevated slabs, elevation 781, unit 2.

workplan needed to inplement this ECN. The workplan package had been acceptably evaluated, documented, and processed in accordance with SQN Al-19 (Part IV) Rl7 (reference 7) and other governing procedures and comnitments, it contained the required table of contents, workplan request review cover sheet, engineering installation requirement (EIR) identification form, workplan control form, workplan specification with detailed written instructions, inspection holdpoints, inspection requirements, ECN package, drawings, and other required reviews and approvals. The conpleted package adequately defined the work requirements and prerequisites / permits and contained sufficient detail to ensure correct installation, inspections, and documentation. No special requirements or post modification tests were included since none were required by DNE. Field work was in process at the time of this evaluation.

4. Workplan 12574-System 82 (Reference 4) - This workplan was written by Modifications to inplement DNE ECN L7085 which authorized the installation of oil baffle plates to the crankcase pressure detectors on the standby diesel generators to prevent a false high pressure trip during engine acceleration after a cold start caused by tube oil surges into the cavity of the pressure detector. It was the only workplan needed to inplement this ECN.

The workplan package had been adequately evaluated, documented, and processed in accordance with SQN Al-19 (Part IV) Rl9 (reference 8) and other governing procedures and comnitments. it contained the required table of contents, workplan request, review cover sheet, ElR identification form, workplan control form, workplan specification with detailed written instructions, QC holdpoints, inspection requirements, prerequisites / permits, ECN package, drawings, and other required reviews and approvals. The completed package adequately defined the work requirements and contained sufficient detail to ensure correct installation, inspections, and documentation. Postmodification tests were identified and defined. Field work was in process at the time of this evaluation. 7.8.5.2 Conclusions The Construction discipline of the EA Team concluded that the two engineering-approved and issued ECN packages and the two Construction-approved and issued inplementing workplan packages accurately reflected the required change, were conplete, adequately defined the scope of the change, and were processed and implemented in accordance with the transitional change control procedure. There was a concern that an insufficient number of ECNs had been evaluated under the new process and was presented to the project in action item Q-il. Section 7.8.2.l presents the details of this action item. 7.8.3-2

7.8.5.5 References References Document Revision issue Date Title i ECN L7012 0 12-4-86 Engineering Change Notice System 564 2 ECN L1085 0 2-11-87 Engineering Change Notice System 82 5 WP 12269 0 12-5-86 Workplan - System 564 4 WP 12574 0 2-27-87 Workplan - System 82 5 SQEP-15 2 12-19-86 Procedure for Transitional Design Change Control-6 SQEP-Al-ll 2 2-6-86 Handling of ECNs 7 SQN Al-19 17 6-5-86 Plant Modifications: (Part IV) After Licensing 8 SQN Al-19 19 12-50-86 Plant Modifications: (Part IV) After Licensing r 1.8.5-5

a e 7.9 Phase 1084VP Report (Preliminary) Tofulfilltheprogramrequirements,theprojectissuedaPhaseiPreliminaryReportto describe the scope, objectives, methodology of conduct, findings, conclusions, and reconmendations of the program. EA reviewed the report to assess whether it accurately portrayed the DB&VP and its objectives, acconplishments, and conclusions. The Nuclear, Electrical, 14C, Mechanical, Civil, and QA reviewed the report from their discipline perspective. The results of the discipline reviews are presented in sections 7.9.1, 7.9.2, 7.9.3, 7.9.4, 7.9.5, and 7.9.6, respectively. 7.9-1

7.9.1 Nuclear EA Nuclear reviewed the entire DB&VP Phase l Preliminary Report (reference 1) except for Appendices H-l through H-3 (discipline findings sunmary reports for CEB, EEB, and MEB). 7.9.l.1 Details EA Nuclear concluded that the report was adequate with the following exceptions:

a. The report stated that NCRs/SCRs were included in the program scope without explaining that some were excluded frcen the DB&VP and providing the rationale for their exclusion,

b. The report stated that each SYSTER documented the system's acceptability for restart when in fact, the SYSTERs only concluded that the post-OL modifications met the RDBD and did not degrade the system's ability to mitigate FSAR Chapter 15 events.

c. The report listed " inadequate corrective action" as a category for characterizing findings which was inconsistent with the DB&VP practice of reopening SCRs determined to have inadequate C/A and thereby excluding them from further consideration by the DB&VP. In addition, this category called " inadequate corrective action" was not ef fectively or consistently applied and appeared to overlap with another category, "0 PEN SCRs."

d. In Appendix H-4, the report contained several unjustified statenents and inconsistencies in its discussion of SCRs.

e. Trending for root cause analysis in the report was based on sorting punchlist items to the disciplines by originator, not by the RAP. In the Nuclear discipline, this led to a nunter of CEB and EER items such as seismic analysis and fusing being included in NEB's statistics, thus making the NEB portion of the root cause analysis in Appendix J of the report misleading.

These concerns were presented to the project in action item N-58. In response, the project conmitted to a report revision. Since the revised report was not issued during the EA review, EA Nuclear verification is required (observation N7). 7.9.l.2 Conclusions EA Nuclear concluded that the DB&VP Phase l Preliminary Report accurately described the DB&VP and its objectives, accomplishments, and conclusions except for the concerns noted in the previous section related to NCR/SCR exclusion, SYSfER conclusions about acceptability for restart, use of the " inadequate corrective action" finding category, SCR discussion inconsistencies in Appendix H-4, and improper trending of punchlist i tans. The project conmitted to revise the report to address these concerns. EA Nuclear verification is required (observation N7). 7.9.l.3 References issue Reference Document Revision Date Title 1 825 810305 052 0 3/5/87 DB&VP Phase i Preliminary Repor! 7.9.1-1

1 7.9.2 Electrical The project issued a DB&VP Phase 1 Preliminary Report for unit 2 (reference 1) addressing the scope, objectives, program descriptions, findings, and conclusions of the DB&VP program. fhe Electrical discipline of the EA team (EA Electrical) reviewed this report to ensure that electrical results were accurately incorporated. The review concentrated on Appendix H-2 and AppendixH-5whichprovidedtheprojectelectricaldisciplineresultsandelectricalwalkdown results; however the general text of the report was also evaluated. Formal attribute sheets were not used as comnents are provided below. 7.9.2.1 Details The EA Electrical reviewed the DB&VP Phase 1 Preliminary Report for unit 2 and found it to adequatelyaddresstheprojectelectricaldisciplinefindingsfromtheprogram. Appendix H-2 which concentrated on electrical findings from the ECN evaluations, test evaluations, drawing conparisons, and SYSTER evaluations and Appendix H-5 which concentrated on the walkdownfindingsbothadequatelyaccountedfortheprojectelectricaldisciplineresults. The general text satisfactorily portrayed the DB&VP objectives, acconplishments, and conclusions, 7.9.2.2 Conclusions The project's DB&VP preliminary report provided a technically acceptable presentation of theDB&VPphaseIprogramfortheprojectelectricaldiscipline. 7.9.2.) References issue Reference Doctsnent Revision Date Title i B25 B70305 052 0 3/5/87 Sequoyah Unit 2. DB&VP Phase i Preliminary Report 7.9.2-I

1 7.9.5 Instrumentation and Controls The 18C discipline of the EA Team (FA l&C) reviewed the IAC related portions of the DB8VP Phase i Preliminary Report (reference 1). The review focused upon Appendix H-2 (Electrical). 7.9.5.1 Details EA l&C found the report to be ccnplete, accurate, and thorough, and did not create any EA l&C concerns. 7.9.5.2 Conclusions The IAC related portions of the report accurately documented the program results and their significance. 7.9.5.5 References issue Reference Document Revision Date Title 5/5/87 DB&VP Phase i PreIiminary Repori 1 825 870505 052 0 4 f 7.9.5-l

s - i' 7.9.4 Mechanical The project issued the Sequoyah unit 2 Preliminary Phase I report (reference 1) which addresses the scope, objective, findings, and conclusions of the 00&VP program. The MechanicaldisciplineoftheEATeamreviewedthereporttoensurethatprojecteffortsin the nochanical area were accurately depicted. 7.9.4.1 Details The EA Mechanical review focused on Appendix H-3 which detailed the mechanical ress.Its. The EA review found this section to adequately describe the major findings, necessu v corrective actions, and remaining work necessary to conplete the phase i portion of the program. 7.9.4.2 conclusions EA Mechanical concluded that the DB&VP preliminary report provided a technically acceptable description of the results at this stage of phase I of the 00&VP program. 7.9.4.3 References issue Reference Document Revision Date Title 1 825 870505 052 - 3/5/87 Sequoyah Unit 2 Phase i DB&VP Report 1 (Preliminary) s

              \

4 7.9.4-1

r 7.9.5 Civil The project issued a preliminary report (reference 1) addressing the scope, objectives, The Civil discipline of the program descriptions, findings, and conclusions of the program. EA Team reviewed this report to ensure civil results were accurately incorporated. Although the review corcentrated on Appendix H-1 of reference I which provided the EA Civil results, > the general text was also reviewed. The results of this review are provided below. 7.9.5.1. Details I This AppendixH-lprovidedanadequatefactualaccountofthe'Civilprojectresults. section concentrated on civil 084VP findings from ECN evaluations, SCR/NCR evaluations, and resolutions to EA action items. The details were accurate and the assessment of This section implied fl'at PIRSQNCE88659 project-generated PIRs was approoriate. i (reference 2) could te considereo act significant because of the small ntaber of technical problems which were found from the ECN evaluations; however, the project did not, in general, perform the type of in-depth review of the ECWs necessary to find technical errors. (See discussion in section 7.5.5.1 for concern presented in action item C-05.) The project did properly clarify that the technical adequacy of calculations is being fully addressed by the calculation program and that each item of this PlR would be

'                           evaluated individually (page Hi-8 of reference 1).

The general findings reported by the Civil project were appropriate, especially the Even concludlag statement that confidence will result upon closure of punchlist items. though the Civil D84VP was not required to address civil-related findings reported by the other disciplines, such as the pipe support weld discrepancies reported in Appendix H-4

'                             (reference I), these items were appropriately punchlisted for subsequent resolution.

i The general text, sections 1.0 through 6.0, adequately inco porated'the civil. findings. These sections accurately described the basis of the DB&VP program, and reported punchlist - data resulting from program products. Section 6.3 properly identified that C/A had to be implemented for prerestart punchlist items. Section 6.5 also recognized that the results

                        <      of this progratalong with the successful coupletion of other programs were required for restart; however, the interrelationship of the DB&VP with associated programs, such as the calculation program, was not provided.

7.9.5.2 Conclusic*ns TheprojectreportprovidedanadequatestatusoftheDB4YPPhaseiProgramforcivil considerations, recognizing the need for punchlist reNon and conpletion of certain aspects of other related programs before restart. N fi si report should address the results of punchlist dispositions and the inte W 4 (ov' ; between DB&VP and associated restart programs required to establish the teca.i A t b 4 acy of the design baseline. - 7.9.5.5 Referexes ! Issue Reference Document Revision Date Title 0 5/5/87 DB&VP Phase l Preliminary Report , 1 825 870505 052 5/24/87 Problem identification Report (B25 870524 017) 2 PIRSQNCEB8659= N/A 7.9.5-l 2 6

7.9.6 Quality Assurance The project issued the SQN unit 2 Phase l Preliminary Report (reference 1) which addressed thescope, objectives, findings,andconclusionsoftheDB&VPprogram. The QA discipline of the EA Team reviewed the report to ensure that the general presentation and content reflected good quality assurance practices and were consistent. 7.9.6.1 Details EA QA reviewed a preliminary version of the DB&VP final report for adequacy. The following concerns were subsequently identified: ECNs, FCRs, and open CAQs which were not evaluated by DB&VP af ter certain dates were not discussed; definition of EA responsibilities as pertaining to the oversight review needed revising; the report incorrectly stated that the transitional design change control program was inplemented; and an explanation was needed to justify certain statements made. These concerns were directedtotheprojectinactionitemQ-IO. In response, the project comnitted to revising the report to incorporate the subject of each of these concerns. The report revision was not available for EA verification (see observation Q5). 7.9.6.2 Conclusions EA QA concluded that the DB&VP Phase i Preliminary Report generally reflected an adequate and accurate accounting of the DB&VP phase i effort subject to closure of observation Q). 7.9.6.5 References issue Reference Document Revision Date Title l B25 870505 052 0 5/5/87 DB&VP Phase 1 Preliminary Report l l 7.9.6-1

8.0 TREND ANALYSIS OF EA TEM FINDINGS This section covers the scope, purpose, approach, and results of the sumery analysis and trend analysis of the EA Team findings. e Scope o Purpose o Approach e Sumery analysis of EA Team action items e Selection of action items for in-depth evaluations e Process for in-depth evaluation e in-depth evaluation of findings 8.1 Scope This section presents results of both a sumary level-analysis of all of the EA Team findings and of an in-depth evaluation of selected findings of the Phase i effort on the D88VP. NRC concerns / observations from the first three inspections were reflected in EA action items and have been included in the population analyzed. All of the EA action items have been systematically categorized to allow for stamery analysis and for trend analyses to be performed. Trending of the findings (action items) enabled the EA Team i to further support their conclusions on the adequacy of the D88VP results. I i l 8-1

                                                                                                         )

8.2 Purpose of the Trend Analysis of EA Action items The purpose of this analysis was to form, based on conposite results of the EA Team reviews and the first three lillC inspections on the 084VP, valid conclusions with respect to the EA review programobjectives: o Confirm and validate that the activities on the D8tVP were conducted in accordance with the overall approved program plan, in accordance with the approved project procedures, and by personnel trained for the specific activity being confirmed / validated. e Confirm that the doctanentation supporting the DB&VP conclusions, i.e., that the functional-adequacy of the systems has not been conpromised as a result of modifications made since OL, is conglete and that technically adequate engineering justifications have been provided, e Determine if the C/A resulting from the DB&VP evaluations have been appropriately inplemented and doctsnented. 4 8-2

8.5 Approach Review findings from the EA Team and the first three NRC inspections were itemized, categorized, and coded according to DNE EA instructions referexed in Appendix 8, Procedure for Evaluation of Technical Audit Results. Individual findings have been assigned identification ntseers and categorized. Categorization consists of assigning codes used to define the specific attributes of each finding. These attributes consist of; activity type, status, finding type, docisnent type, responsible discipline, corrective action, preventive action, cause, extent, significance, and CAQ generated. Coding inforation applicable to each finding was then doctsnented on a coding sheet (Table 8.2-1). Each coding sheet was subsequently reviewed to ensure clarity and consistency of the information. The information in the coding sheets was input to a conputerized data base for use in composite analysis of the data. The results presented in the followino sections are based on the status of the items in the database as of March 31. 1987. The action items are designated by an alphantsneric code which indicates the discipline of the reviewer and the numerical sequence of the action item. The action item designation key is shown below: ACil0N ITEM IDENilFICATION NUMBER = AYYY with A = Discipline / Area of the Reviewer e.g., C = Civil Discipline E = Electrical Discipline I = Instrisnentation and Controls Discipline M = Mechanical Discipline N = Nuclear Discipline 0 = Operations Engineering Q = Quality Assurance T = Construction and YYY = Numerical sequence identifier starting with 01 in each discipline / area and increasing. Data base infora tion was sorted according to finding type subcategory. Each subcategory was thoroughly reviewed for comnonalities and significance of occurrences, and special emphasis was placed on findings that could affect review adequacy - product development. The subcategories having a smil ntster of findings randomly spread anung responsible disciplines were excluded from the in-depth evaluation and were evaluated as a general group. This exclusion process is discussed further in section 8.7. Coninon criteria were used in analyzing the data and neking a determination of the significance of deficiencies. Those include: e What are the most prevalent types of problems? e What findings would have the greatest inpact on plant design and design process? e What is the known cause and extent of these problems? 8-3

l l Definitions Findino-A line item on an observation or action iten, or a line item listed in the report that requires a response, llormally, this would consist of an individual item nister in an observation, report, or enforcement action ~ (NilC inspection). Observation--Document'd e items observed in the review / inspection process which require corrective and/or preventive action and represent the tracking device for follow-up until closure. Action item--Item written to request additional information from the project when the information - was not readily available and for identifying potential concerns and deficiencies to the project for resolution. CJ-Action taken to correct an identified deficiency, including that required for correction of similar conditions. Preventive Action--Action taken to prevent recurrence of an identified deficiency. Open Iten--An observation, action item, or finding which remains open pending further action by either the project, EA Teen, or Nilt inspectioa Team. Unresolved item--An open observation, action item, or finding generated during the review for whichtheprojecthadnotmadearesponse,ortheresponsewasjudgednottobeadequatebytheEA Team. Resolved item-An open observation, action item, or finding generated during the review for which comnitted project actions have been agreed to by the EA Team but have not been conpleted and/or have not been verified. Closed item--An observation, action item, or finding for which the project's corrective / preventive actions have been reviewed, accepted, and verified by the EA Team. For trending purposes an action item for which all Phase I actions were completed and any Phase ll actions were accepted by the EA Team was considered closed. 8-4

8.4 Stsmery Analysis of EA Team Action Itans The results of the EA Team reviews are presented by a sunnary discussion of all of the action items generated during the review process. An in-depth evaluation of selected findings is contained in Section 8.7. Table 8.4-1 lists all of the action items generated during the review as a function of the 08&VP activity for which the action items were generated. Figure 8.4-1 graphically displays the distribution of action items as a function of the activity reviewed. Eleven attribute codes were used to categorize the action items. Detailed subcategory codes were also used to provide an additional level of detail. This section discusses a sismery of action items for each of the 11 attribute codes. The 4ction items are further correlated to dif ferentiate between those that were invalid findings (Table 8.4-5); those that required no corrective or preventive action (Table 8.4-2); those that can be closed after restart (Table 8.4-5); and those that require closure before restart (Table 8.4-4). Action items that were initi6ted as a result of concerns raised by the NRC during their first three inspections of the DB&VP are included in these tables. For purposes of this sismery section, all of the EA action items (including those initiated as a result of the first three NRC inspections) have been included in the stamery analysis of findings. 8.4.1 Action items Not Requirina Project Action The action items shown in Table 8.4-2 are those which did not require either corrective or preventive action by the DB&VP. The reasons that no DB&VP actions were required include: (a) the finding is an information request which was adequately clarified, (b) the finding was based on the review of a draf t or interim doctanent and was adequately captured in the issued doctsnent, (c) both EA and the DB&VP agreed that the finding was minor and did not require further action, (d) the finding is outside the scope of the 088VP and requires no project action, (e) the DB&VP furnished additional information or documentation, which was verified by the EA Team, that adequately resolved the concern, and (f) the finding is not valid. Action itans involving concerns outside the scope of the DB&VP but which required 084VP action to ensure their capture in another project program or activity are not included in this grouping. Such action items are considered to require corrective action and are so categorized as requiring 08&VP corrective action. 8.4.2 Postrestart Action items Action items for which the corrective and/or preventive actions can be taken af ter restart are presented in Table 8.4-3. Many action itans discussed multiple concerns for which individual and/or collective corrective / preventive actions were proposed. Therefore, the resolution of such action items could involve both prerestart and postrestart actions. The inclusion in the postrestart grouping indicates that either all or a portion of the corrective and/or preventive actions will be acconplished af ter restart. Fif ty-eight of the EA Team action items involve postrestart corrective actions. For fifty-one of the 58 any associated Phase I corrective / preventive actions have been ve,rified by the EA Team and Phase 11 actions have been agreed to. Seven of the action items involve corrective / preventive actions which have been agreed to but project inplementation of the actions or EA verification of the actions has not been cmpleted. The irrplementation of these postrestart actions will be verified by the EA Team during Phase 11 of the 08&VP (see observation EAl). 8-5

I I 8.4.) Prerestart Action items The prerestart action items shown in Table 8.4-4 are those for which all of the corrective and/orpreventiveactionsaretobeisplementedbytheprojectandverifiedbytheEATeam prior to restart. As of the trending cutoff date of March 31, 1987, there were 276 closed and resolved action items in this category. In addition, 25 unresolved action items could not be assigned a restart status as C/A has not been agreed upon. The resolved and unresolved action items will be tracked by the observations presented in Section 5.0. 8.4.4 Action items Requirino Corrective and/or Prevertive Action Action items requiring corrective and/or preventive action by the project are grouped in Table 8.4-6 by the same specific key activities pertinent to the 084VP as was used in Table 8.4-l. The listing of action items in Table 8.4-6 does not include those which are invalid or for which corrective and preventive actions were not necessary. 8.4.5 invalid Action items The 7 action items shown in Table 8.4-5 are not considered to be valid findings. The reasons that the action items are considered invalid include: (1) the reviewer was misinformedorincorrectinthejudpents/decisionswhichprecipitatedthefindingand (2) additional infornation/ explanation / documentation was provided which indicated the concern was not valid. Nunerous action items involved concerns which arose during the review of an interim or draf t docunent. The project response to such concerns would acknowledge the validity of the concern but indicated that the finalized document was already issued and incorporated the concern. Those action items were not considered to be invalid since the reviewer's concern arose from a valid review activity. Therefore, such action items were included in the group of valid action items for which no corrective and preventive actions were required (see subsection 8.4.2). 8.4.6 Types of Action item Findines The action items generated by the EA Team during the review of the 084VP were classified according to type of finding. The findings are classified into one of 55 subcategories which together comprise 9' major categorical topics. Discussions of finding type categories and subcategories are presented below. 8-6

8.4.6.1 Findina Type Categories Nine categories were used to classify the action items for finding type and were selected to represent the complete range of D64VP activities which were to be reviewed. The nine categories are discussed in detail in Section 8.7 and Appendix B, which contains a reference glossary of category definitions. Table 8.4-7 displays the trending codes used to categorire the action items. Trend code til shows the categories and subcategories used. The nine finding type categories are: 1.00 Design Review Deficiencies 2.00 t,esign Review Process / Methods inadequate 3.00 Inadequate Interface Control 4.00 Design Criteria Deficiencies 5.00 Corrective / Preventive Action inadequate 6.00 USQO Deficiencies 7.00 Test Requirements / Test inplementation Deficient 8.00 Records Retention inadequate 9.00 Miscellaneous Deficiencies-Figure 8.4-2 displays graphically the finding type categories represented by the EA Team action items. The findings, to the mexinun extent possible, were coded into a specific design review deficiency category. As an exanple of the coding decision process, 4 consider the design criteria preparation activity of the D88VP. This activity consisted of two distinct phases. First, applicable comitments/ requirements (C/Rs) were identified and included in a C/R data base. Secondly, design criteria were prepared which were to include the appropriate C/Rs. Findings that involved a failure to capture a C/R were coded into a design review deficiency category, if possible. Findings which concerned a failure to capture a properly identified C/R into an appropriate design criteria were coded into Category 4.00, Design Criteria Deficiencies. Figure 8.4-2 reveals that the largest category of findings involves design review deficiencies, i.e., failure to adequately address specific technical concerns. The ranking of finding types is given below: e Design Review Deficiencies - 227 (or 63.5%) action items e Design Criteria Deficiencies - 52 (or 14.5%) action items e Review Process / Methods inadequate - 25 (or 7%) action items i e Corrective / Preventive Action inadequate - 21 (or 6%) action items e All other categories - 32 (or 95) action items 8.4.6.2 Findina ivpe Subcateaories As discussed above, the nine finding type categories are subdivided into 55 subcategories to allow a nore meaningful categorization process. The subcategories are shown under trend code til, finding type code, in Table 8.4-7. A sumury of the finding type subcategories for all of the EA Team action items is presented graphically in Figure 8.4-3 The most significant, i.e., prevalent, findings are presented below: 8-7

e ' Basis for design review not documented - 60 (or 16.8%) e Required design factor not analyzed - 58 (or 16.2%) e No basis for design input /assumtion - 34 (or 9.5%) e inadequate / incomplete requirements in design criteria - 25 (or M) e Missing requirements in design criteria - 25 (or 71)

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e Missing / inadequate DB4VP process procedure - 20 (or 5.6%) e incorrect design input / assumption - 19 (or 5.3%) e Potentially generic design problem not addressed - 12 (or 3.4%) e Inplementation of Technical Guidance Deficient - 12 (or 3.4%) e Inplementation of Adninistrative Guidance Deficient - ll (or 3.1%) e Miscellaneous Drawing Deficiencies - II (or 3.11) e Design Document Conflict - 10 (or 2.8%) e All other subcategories - 60 (or 16.8%) 8.4.7 Types of Docunents Affected by the Action Items The action items are also categorized in terms of the docunents affected, i.e., the document in which the concern which generated the action item was found. The docunent types are shown in Figure 8.4-4. Included with the docunent type are any associated 084VP review / identification forms, such as the C/R data sheets for design criteria preparation or the design review checklist used for the review of ECNs. As shown in Figure 8.4-4, ECNs and design criteria (including associated docunents for each) together account for 180 (or 52.M) of the affected docunents. Individually, each type accounts for approxinutely 26% of the af fected documents. The most significant types of docunents (including associated documents) af fected are: o ECNs - % (or 26.9%) e Design Criteria - 92 (or 25.8%) e SYSTERs - 47 (or 13.2%) e Walkdown Packages - 33 (or 9.2%) e Calculations - 21 (or 5.9%) e Technical Procedures - 19 (or 5.3%) 8-8

8.4.8 Responsible Oroanization for the Action items The action items are categorized to indicate the discipline (s) within the DB&VP which are responsible for investigation and resolution of the findings and for the innlementation of any corrective and/or preventive actions. The discipline codes are shown as code IV, Responsible Discipline Codes, in Table 8.4-7. A nultidiscipline designation is also used for findings which cross discipline boundaries. The distribution of responsibility for action items within the DB&VP is presented in Figure 8.4-5. Eighty (or 25% of the 342 items coded) represent action items with nultidiscipline inpact. 8.4.9 Corrective Actions Required to Resolve the Action items Corrective actions are actions taken to resolve the innediate concern of a finding without necessarily identifying the root cause of the concern and actions required to prevent recurrence. The types of corrective actions required to resolve the EA Team action items are shown as code VI, Corrective Action Codes, in Table 8.4-7. The distribution of required corrective actions is shown in Figure 0.4-6. The most significant corrective actions include the revisions of change doctanent evaluation forms (21.1%) and the revision of design criteria docments (19.3%). Various identification and evaluation forms were used in the change document (ECNs, FCNs, PIRs, SCRs, etc.) evaluation activity of the 084VP. Therefore, it must be recognized that the revision of a change document evaluation form will frequently result in additional associated corrective actions, such as the preparation of calculations or analyses and the issuance of PIRs/SCRs. Corrective actions which involve the generation of a C/R data sheet to capture a C/R in the data base would be categorized as a revision of a criteria doctanent. Adninistrative actions, which represent 12.8% of the corrective actions, include connunications between disciplines, sections within disciplines, SEs, the DB&VP, and the Project. Two significant corrective action programs were required to resolve extensive concerns of 1he EA Team. e A review of all change doctsnent evaluation checklists conpleted by the electrical discipline to address concerns related to inconplete and incorrect checklists, e A program to resolve numerous concerns related to identification and capture of C/Rs and the preparation of restart design criteria. 8.4.10 Preventive Actions Required to Resolve the Action items Preventive actions are actions which result from the 08VP establishing the root cause of a finding and fornulating actions which will prevent the recurrence of the finding. The types > of preventive actions taken by the DB&VP are indicated by code Vil, Preventive Action Codes, in Table 8.4-7. The distribution of required preventive actions is displayed in Figure 0.4-7. The preventive actions were instituted to prevent recurrence of problems associated with the design review process, i. Fornet training (and re-training) accounted for 24 (or 7.I%) of the DB&VP preventive actions. Formal training includes training provided to 084VP and supporting contract personnel on engineering procedures (SQEPs) and for which training records are required. Supervisory actions constituted 97 (or 28.9%) of the preventive actions. These actions include infornel correspondence, discussions and meetings with subordinates, increased supervisory attention / involvement, and correspondence below the Assistant Project Engineer level. An additional 94 (or 28%) of the preventive actions involved the revision or issuance of procedures, policy directives, or Project and Assistant Project Engineer instructions, it should be noted that ntsnerous project responses to EA Team action items 8-9

rT=-- +N-invoked: (1) the same procedure revision / issue, or (2) the same policy directive, and (3) the same project level correspondence. Therefore, the number of action items in this category is greater than the actual ntaber of procedures revised / issued by the D64VP in response to the action items (likewise for policy directives and Project Engineer and Assistant Project Engineer level correspondence / instructions). Significant preventive actions were necessary to prevent recurrence of several adverse trends recognized as a result of EA action items (see section 8.7 for specific details). Significant preventive actions were also required in response to programnstaic deficiencies identified in individual EA action items. Some of the more significant preventive actions taken were: e A tenporary stop work order in the Electrical discipline was issued by the Chief Electrical Engineer (memorandum from W. S. Raughley to J. F. Cox dated October 31, 1986) in response to an adverse trend with change document evaluations. All electrical , checklists. were subsequently reviewed. e Formal retraining of DBtVP personnel to SQEP-il and SQEP-12 with an emphasis on EA concerns. e Revision of SQEP-12, " Procedure for Evaluating Engineering Change Notice and Field Change Notice Documents" e Menorandtsn from the Sequoyah Project Engineer to Westinghouse (memo from D. W. Wilson to Westinghouse dated Septenter 2,1986) to provide guidance on the level of justification and docisnentation necessary to support SQEP-12 checklist evaluations, o ProjectDirective08vP-0-86-09toensureadequatedepthofengineeringevaluations, o ProjectDirectiveD8vP-D-86-010toensureinterdisciplinereviewofSYSTERreports. e issuance of SQEP-57, " Processing of Test and Retest Requirements identified During the Design Baseline and Verification Program." 8.4 ll Causes of the Concerns in the Action item Findinas A categorization of the action items for the underlying cause of the concern (s) expressed in the finding (s) was performed to permit a more conplete understanding of the fundamental deficiencies in DBaVP activities. The cause codes utilized are presented in Table 8.4-7 under code Vill, Cause Codes. The causes established in the analysis of the action itens are a contination of the DB&VP assessments of cause and the EA Team's assessments / knowledge of the underlying cause. ThecausesofthefindingsaredisplayedinFigure8.4-6. An analysis of the causes r'eveals five types of deficiencies which occurred in all disciplines and most activity phases of the DBaVP and represent the cause for 74.1% of the findings. Thesefivemajor cause categories are presented below: e Doctsnentation of Evaluation inadequate /Inconplete - 69 (or 20.4%) e Engineering Evaluation inadequate /Inconplete - 49 (or 14.7%) e inadequate (or no) Procedures - 48 (or 14.21) e Failure to conply with Procedure -45 (or 13.2%) 8-10

e Identification of Design input / Design Basis inadequate /Inconplete - 39 (or 11.6%) The cause category, "Docunentation of Evaluation inadequate / locomplete," includes those action items in which the justification and/or docunentation for a technical judgnent/ decision / assumption was not adequate. The large nueer of action items in this cause category indicates a need for continued management attention to SQEP adherence to DNE Policy Menorandun PIW6-4)4, Engineering Judgnent. The nunter of items in the other categories indicate that continued nenagement attention is required to: 1) enphasize the need for accuracy in engineering investigations and evaluations, 2) enphasize that work must be done in accordance with SQEP and 084VP procedures, and 3) ensure that procedures governing DB&VP work are thorough and adequate. 8.4.12 Extent of the Findinos in this section, a sumery of the extent of the finding (s) in each action item is presented. An assessment of extent is performed which considers the finding (s) in each action item, the DB&VP response (s), and the reviewer's follow-up comnents. The assessment of extent is hanpered somewhat because many action items involved multiple findings of a ! diverse nature. The extent of those findings was usually based on the most significant, l or prevalent, type of finding. The extent categories are represented by code IX, Extent of Conditions Codes, in Table 8.4-7. A sumery of the extent assessment is shown in l l Figure 8.4-7. Note that 105 (or 31%) of the findings involve concerns that were extensive l within one or more disciplines. An additional 100 action items were of limited extent l while 117 (or 34.8%) represented isolated unique findings. Eleven of the findings ! involved concerns which were random. 8.4.13 Sionificance of the Findinos A categorization of the action items to assess the significance categories has also been l ' performed. The significance categories established are shown under code X, Significance, l in Table 8.4-7. The assessment of significance considered the finding (s), the DB&VP ! response (s), and the reviewer's follow-up connents. Flexibility was exercised in l assigning a significance code, e.g., some findings which required design docunent changes I were assessed as " minor technical" because of the minor nature of the concern. The significance assessment is presented graphically in Figure 8.4-10. Of particular inportance is that only three action items involved concerns for which hardware changes (nodifications) were required. This parallels the small percentage of DB&VP findings which required hardware changes. Also noteworthy is the fact that 187 (or 58%) of the findings resulted in significant design docunent changes. 8.4.14 CAQs Generated as a Result of Action items Figure 8.4-11 and appendix AA show the EA action items which resulted in one or more CAQ ! docunents (PIR/SCR) as a function of the EA review activity. An evaluation of each CAQ, including significance and restart status, is being performed by the DB&VP during Phase

1. However, based on the SQN restart criteria, the ipplementation of corrective actions for some CAQs was deferred to Phase 11 of the DB&VP. The EA Team will verify the adequacy of the present corrective actions and inplementation of those corrective actions (see observation EAI). Of the 58 CAQs, 29 were generated as a result of the various change document review activities.

I 8-11 l

8.4.15 System Review of the DBayP for System 72 (Contaiment Spray System) The surrmaries and discussions of previous report sections are based ca a review, by discipline when appropriate, of each activity phase of the DB&VP. The EA Team used System 72, Containment Spray System, to perform a system review of the CB&VP activities. This type of review allows the EA Team to track findings for the selected system which cut across all activity phases and disciplines of the DB&VP. System 72 was chosen for the reasons given below: e Major portion of the system is needed for FSAR Chapter 15 accident mitigation e System has had several nodifications since OL e System includes multidiscipline engineering aspects e System includes NSSS interface e System was not reviewed in previous audits Figures 8.4-12, -13, -14, and -15 show the distribution of findings for system 72. Figures 8.4-12 presents a carparison of the findings for systen 72 by DB&VP activity against the population of all other findings. A comparison of finding type subcategories is displayed in Figure 8.4-13. The distribution of preventive action and finding cause for the system 72 review is conpared to those for all other findings in Figures 8.4-14 and 8.4-15, respectively. An analysis of the system review indicates that the findings for systen 72 closely mirror those for the DB&VP activities as a whole, thereby enhancing the degree of assurance that the EA Team reviews of the DB&VP are conplete and adequate.

                                           '8-12

8.5 Selection of Action items for in-Depth Evaluation The assessment of action items to be included in the in-depth evaluation is based on the status of all action items as of March 31,1987. Open action items were coded insofar as the D84VP repsonse (if any) and reviewer follow-up (if any) would permit. The trend codes assigned to resolved action items reflect D84VP intent for corrective / preventive actions rather than inplemented actions. Unresolved items were trended, as a mininnan, for activity, finding type, and affected doctsnent type. Therefore, resolved and unresolved items should be considered to be partially trended for purposes of establishing the findings to be evaluated in-depth. This is not a reflection on the D8&VP comnitment to properly inplanent the corrective / preventive actions, since the EA Team is comnitted to verify the inplementation during Phase 11. Observations have been issued for all open action items. The evaluation of the results of the action items consisted of categorizing the findings by finding types having similar characteristics and performing an in-depth evaluation of each category for concerns and patterns which would lead to conclusions about the effectiveness of the design review process. The action item findings within each finding type category were evaluated for the ntster of occurrences, distribution among disciplines, extent of conditions, and significance of the finding. They were also analyzed to determine the likelihood that the reported condition would have been corrected during the ongoing design process, existing as-constructed confirmation programs, or test programs. Causes of the findings and corrective and preventive actions taken by the DBavP were also evaluated. The results of these in-depth evaluations are stamarized for each finding type category in sections 8.7.1 through 8.7.16 utilizing Appendixes C through AA. The finding type categories and subcategories are listed in Appendix C. l l A listing of action items to be evaluated in depth was established from the action iten data base (Appendix D). The list of evaluated action item findings included all findings except for those l which were open or invalid. Figure 8.7-1 shows the ntseer of closed and open action items as a l function of the finding type subcategories. Unresolved itend are excluded from the in-depth evaluation because of a lack of resolution between the DB&VP and EA for corrective and preventive actions. Resolved items are excluded because, even though proposed corrective and preventive actions have been accepted by the review team, the actions have not been Inglemented by the DB&VP l or verified by EA. Therefore, the actual inpfemented D64VP actions are subject to change / revision from those agreed to at the resolution. This uncertainty as to actual vs. proposed corrective and preventive actions has a potential to skew the in-depth evaluation if they were included. For those reasons, the in-depth evaluation is limited to closed action items, i.e., those for which I D64VP actions have been inplemented and verified. Minor editorial or adninistrative findings that i have no ef fect on the design and design review process are included as part of the evaluated findings. Findings which are excluded from the in-depth evaluation are addressed separately in section 8.7.9. Appendix E is a listing of action item findings used for in-depth evaluation. 8.6 Process for in-Depth Evaluation of Selected Action items The action item findings to be evaluated were grouped by finding type subcategories, which were then ranked by the total ntster of occurrences within each subcategory (Figure 8.7-2). Those subcategories containing the majority of the findings were evaluated in-depth. However, additional conservatism was applied to the in-depth evaluation in that the finding type subcategories representing approxirmtely 94 percent of the evaluated audit findings were evaluated i n -dept h. To achieve this level of conservatism, all finding type subcategories 8-13

l l with nere than three occurrences were selected for in-depth evaluation. Ninety-four percent of the findings represented approxinutely 54 percent or 19 of the 35 finding type subcategories. The remaining 6 percent of the evaluated findings represented finding type subcategories with 3 or less findings. These were evaluated as a group as discussed in section 8.7.9. Each finding type subcategory was evaluated in-depth with regard to distribution across disciplines and extent of conditions. Editorial and/or administrative findings having no.effect on the process were also taken into consideration. Findings that are more significant and/or occur frequently were evaluated for their combined significance on the adequacy of design and the review process. The findings were also evaluated for cause and corrective and preventive actions in order to draw conclusions on the effectiveness of the overall design and review process. Findings reneining open at the time of issue of this report were evaluated to the extent that suf ficient infornation was available for.an in-depth evaluation. The potential significance of the unclosed findings on conclusions reached in the in-depth evaluation is discussed in section 8.7.11. 8.7 in-Depth Evaluation The results of the in-depth evaluation of the findings within each subcategory are suninarized in the order of finding type categories shown in Appendix C. The subcategories within each category are discussed starting with those having the most findings and concluding with those having the least. All the findings evaluated in-depth (i.e., 94 percent) occurred within eight of the nine categories as shown in Appendix C. Although the nuin evaluation was based on finding type subcategories, additional analyses were performed in order to develop supplenwntal information to support the overall conclusions. Additional analyses included evaluations of responsible disciplines, af fected documents, causes, and preventive actions. The DB&VP is a corrplex process and the first of its kind within TVA. Problems were, therefore, expected to be found in both its inpimentation and execution. Since this is a first-time program, it was not possible to set an acceptable error rate for the finding types as there is no previous experience on which to base such a judgnent. Accordingly, each finding type subcategory was analyzed for coninon groupings of problans,.whether these groupings were recognized, and the apparent adequacy of DB&VP action taken. Contronalities between finding type subcategories for these problan groupings were also analyzed. 8-14

8.7.1 Deslan Review Deficiencies 8.7.1.1 Basis for Desian Not Documented Findings of a technical nature within this subcategory (Figure 8.7-2, Appendix F) refer to a lack of docunentation to support the basis for a design, such as no calculation or preidentified testing to support or verify the design basis. Exagles for the review process include the failure to reference supporting calculations /doctanentation or Design Review Checklists (ORCS) and the failure to cogletely capture a C/R in the C/R data l base. Discipline-specific findings of this type were observed in all of the review disciplines except Construction. The Electrical (24, including 15 I&C), Mechanical (10), and Civil (8) disciplines accounted for 86 percent (42 of 49 findings). Twelve findings involved 2 or nere disciplines and were consequently classified as nultidiscipline. The Nuclear (#), Operations (2), and QA (1) reviews accounted for the remainder of these findings. There were 49 findings in this subcategory, none of which l resulted in hardware changes. Thirty-four of the findings resulted in design doctsnent l changes. l ! Thirty-seven of the 49 findings were generated as a result of the change doctsnent evaluation activity. The rensinder of the findings resulted from the System Boundary (I), Walkdown (4), Electrical Test Review (I), Design Criteria Preparation (3), and System Evaluation Report (3) activities. Eleven of the 12 findings involving i multidiscipline responsibilities resulted fran the change doctsnent review activity, in addition, 5 findings (E46,123, and 124) resulted in the DB&VP issuing one or more CAQ (PIR or SCR) documents. PIRSQNEEB8671 was initiated for action item E46 to document the lack of a voltage drop calculation for the 125V DC lube oil ptsms. Action item 12) resulted in P RSQNEE886126 to doctsnent lack of design criteria requirements for setpoints on steam generator level switches. Action item 124 refers to Igroper use of an ECN workplan as the basis for addressing setpoints for the steam generator level switches and references PlRSQNEEB86126 as providing C/A for 124 and 123. The 37 findings related to the change doctsnent evaluation activity were analyzed further to determine the presence of trends and for indications of DB&VP recognition and response to any observed trends. The additional analyses indicate that almost all of j the findings related to properly identifying, reviewing, and evaluating the various change doctsnents, particularly ECNs, are included within the scope of the 08&VP. Change l doctsnent identification forms were used to correlate the doctanents and affected systems to ensure subsequent capture and analysis. Change doctsnent evaluation forms (such as the DRC used for ECNs) were used to record the detailed evaluation of the docunent and included references to supporting calculations /doctsnents where required. The Civil (6), j Electrical (19, including 13 l&C), Mechanical (10), and Nuclear (3) disciplines l experienced problems in preparing identification and evaluation forms for change doctanents. Eleven items, as noted previously, involved 2 or more disciplines. This adverse trend was recognized by the DB&VP management and corrective actions were iglemented. Preventive actions included formst retraining with an e@hasis on quality i standards and revision of governing SQEPs. Additional guidance was provided on the level of justification and doctrentation necessary in a memorandtsn from the Assistant Project Engineer to Westinghouse and distributed to DB&VP personnel (memorandtsn from D. W. Wilson to Westinghouse dated Septenter 2,1986). 8-15

In addition, the Chief Electrical Engineer issued a tenporary stop work order in the Electrical and l&C disciplines (memorandun from W. S. Raughley to J. F. Cox dated October 31, 1986). Additional senior-level management personnel were assigned to the change docunent review effort in those disciplines and some organizational restructuring was effected. The Electrical and l&C disciplines also performed a 100 percent review of completed change document identification / evaluation forms. Approximately 600 checklists were re-reviewed (see memo fran John Cox to John von Weisenstein dated February ll,1987 (B25 870211 054)] with 500 being revised. During the re-review of the checklists, approximately 150 corrective actions were identified and entered on the punchlist for tracking. Fourteen of these punchlist items were PIRs (12 for problems with design criteria and 2 for lack of calculations). After the institution of these corrective / preventive actions, the quality of change docunent evaluations inproved markedly. The in-depth evaluation indicates that the DB&VP actions were sufficient in all disciplines to address the concerns of the evaluated findings. Subsequent change docunent evaluations were adequate. The in-depth evaluation of this subcategory indicates that the adverse trend related to change docunent evaluation forms has been adequatelp addreased by the 084YP through the inplementation of appropriate corrective / preventive actions. No other adverse trends exist for this finding type subcategory, 8.7.l.2 Required Desian Factor Not Analyted Findings in this subcategory (Figure 8.7-2 and Appendix G) within the DB&VP include not addressing a relevant factor on the change docunent evaluation form and failure to recognize a C/R and to capture it in the C/R data base for later consideration in appropriate design criteria. There were 38 finding types in this subcategory. None of the findings resulted in hardware changes, but 21 required changes to design docunents. Findings of this type were observed in all review disciplines except Operations, Quality Assurance, and Construction. Ten action items involved findings of a nultidiscipline nature. The findings were distributed anong the Civil (9), Electrical (16, including 10 l&C), Mechanical (7), and Nuclear (5) disciplines. Three action iterns (151, M41, and NIO) resulted in CAQs. One finding was identified in the system boundary activity, 15 in the change document review activity,19 in the design criteria preparation activity, and 5 in the system evaluation report activity. One finding (N12) involved an information request as to whether IMI scope items were included in the System and Boundary determinations for the 084YP. TMl scope items are included to the extent necessary to mitigate Chapter 15 events. Thirteen action items (CO2, Coe, C09, C29, C45 El8, E35, E73, E76,125,131, M41, and N14) involved failure to address relevant concerns in the inplementation of SQEP-ll (identification and Assent > ling of Change Docunentation) and SQEP-12 (Procedure for evaluating Engineering Change Notice and Field Change Notice docunents). These two procedures require the use of Identification and Evaluations checirlists through which appropriate change docunent attrib'utes are to be addressed, it should be noted that these checklists serve as a means to distinguish between design changes for which adequate evaluations /docunentation/ justification is available and those which require additional 084YP action. Therefore, the failure to consider a relevant checklist attribute is appropriately considered a design-related deficiency. The causes of the findings include ) instances of failure to follow procedures, 2 of inadequate /inconplete docunentation of the evaluation, } in which the engineering evaluation was inadequate or incapplete, 2 of inadvertent error, I of an inconplete docuvent review cycle, I in which the review performed was inadequate or inconplete, and I due to inadequate procedures. 8-16

All 6 findings in the Electrical discipline (which includes l&C) were part of the adverse trend in adequately completing SQEP-12 Design Review Checklists previously discussed in section 8.7.l.l. Preventive actions taken by the 084VP included the formalretrainingofelectricalpersonneltoSQEP-12,theissueofProjectDirective D8vP-0-86-09toensureadequatedepthofengineeringevaluations,theissueofProject Directive 08VP-D-86-010 to ensure interdiscipline review of SYSTER reports, the issue of SQEP-15 to ensure that USQDs are prepared af ter a design package is complete. Corrective actions include the couplete review of all electrical checklists af ter the tenporary stop work order issued by the Chief Electrical Ergineer. The stop work order and the results of that review are discussed in section 8.7.l.I. All of the civil findings (5) concern failure to address relevant factors on the SQEP-il change document identification forms, which capture change documents for subsequent review under SQEP-12. Problems with proper conpletion of the identification forms by Civil personnel were recognized by the project in response to EA concern. A re-review of civil identification forms was performed and increased management attention was , focused on this problem. The actions discussed above have adequately resolved the adverse trend in conpletion of change doctsnent identification and evaluation forms. Subsequent forms were conpleted in a satisfactory manner. Of the 19 findings in the design criteria preparation activity,18 (action items COS, Cll, Cl2, C24, El2,110, li t,112,116,119, M07, Mll, Ml2, Ml4, M29, M51, N18, and N25) involved an adverse trend concerning the failure to capture a C/R in the C/R data base. ! These concerns related to the adequate capture of C/Rs for subsequent consideration and incorporation into appropriate design criteria. The principal causes of these findings were failure to follow procedures, inconplete or inadequate review efforts, inadequate or inconplete identification of the design basis, and inadequate procedures. The predominant corrective action (15) was to revise the C/R data base to include the missing concern or to revise the appropriate design criteria to incorporate the missing concern (s). A corrective action program was begun as described in a memorandtsn from J. F. Cox to Sequoyah Engineering Project Files dated 9/11/86 concerning "D64VP to support restart," to address project actions necessary to resolve ntsnerous concerns related to the C/R data base and the preparation of restart design criteria. These project actions have adequately resolved the adverse trend for concerns related to restart C/Rs and design criteria. EA will verify the postrestart aspects of this resolution during Phase 11 of the 08VP. Five findings (action items EB4,151,152,158, and N54) concern problems with the content of SYSTER reports. Even through 4 of the 5 concern the Electrical and lac disciplines, the findings are random and unrelated, with only N54 having a notti-discipline involvement. There is no adverse trend in this subcategory of evaluated findings involving SYSTER reports. However, many of the open findings concern SYSTER reports. Section 8.7.16 discusses the potential impact of open findings. 8-17 l l

_ ~ . - -

8. 7.1. 5 ho Basis for Desion input /Assuetion i

Action item findings in this subcategory (Figure 8.7-2 and Appendix H) reflect concerns j where the basis for inputs /asstaptions/ technical concerns used in a design analysis or evaluation is not supported by documentation, or no justification is provided within an analysis or an evaluation package. Findings of this nature include calculations where engineering judpents have not been docunented adequately, and also lack of adequate justification for judgments made in addressing attributes of the change documents identification and evaluation forms. There were 29 findings in this category, none of which required hardware changes. Twenty of the findings resulted in significant design docuent changes. The remaining 9 findings were all considered to be minor technical concerns. Findings were observed in the Nuclear (9), Electrical (8, including 6 14C), Mechanical (2), Civil (4), and Operations (5) disciplines. Three of the findings involved nmitiple disciplifies. No findings were observed for which @ and Construction were the responsible organizations (one finding from a @ reviewer was assigned to the Mechanical discipline). The most significant trend for this finding subcategory is that 17 of the 29 findings (alnest 59 percent) occurred in the change docuent evaluation activity. The findings involved are for action items Cl), C25, C30, C42, E45, E54,104,130,155,154,147, M54, M39, N41, N42, N44, and N46. Most concern inadequate or inconplete doceentation orjustificationfortheevaluationofECNsthroughtheSQEP-12designreview checklist. As such, this trend reflects problems and misunderstandings associated with inplementation of DNE Policy Memorandun PM86-04, Engineering Judpent, which gives direction for the degree of documentation and/or justification required to docunent engineeringjudpent. Four of the action items (C50, E45, M39, and N42) resulted in ore or more CAQ doc eents being issued. The preventive action for this group of findings included formal retraining of personnel to SQEP-12 with an enphasis on EA concerns related to accuracy, ccepleteness, ar4 adequate justification and documentation of the evaluations. Increased supervisory attention was also inplemented as a preventive action. The OB&VP also developed an ECN sunnery sheet which is conpleted by the SE and included in the appropriate SYSTER report. As corrective action, all of the SQEP-12 checklists prepared by Westinghouse for the 084VP were reviewed for adequate and , consistenttechnicaljustification. TVA SEs reviewed and concurred on all subsequent Westinghouse submitted checklists. The Mechanical discipline is'ued guidelines for evaluating specific checklist items and re-reviewed conpleted checklists. SQEP-12 was also revised to renove certain nonrelevant checklist items from the scope of the 08&VP. The preventive actions cited above were satisfactory as evidenced by the lack of findings for subsequent chat.ge document evaluations. Five findings (action items N01, NO2, N004, N09, and N)2) in the Nuclear discipline related to a lack of sufficient justification for judpents concerning the system boundary calculation, SQN-OSG7-048, in each finding, the relevant technical concerns were adequately evaluated by the 084VP personnel but were insufficiently documented. Increased supervisory attention was used as a preventive action to ensure compliance with Policy Menorandun PM86-04, Engineering Judpent. Three of the findings were of limitedextent,onewasanisolatedoccurrence,andthefifth(lackofjustificationfor boundary selection in the system boundary calculation) applied only to the system boundary calculation. No CAQ docunents were issued as a result of these action items. 1 i 8-18 i

3 Four findings were observed in the Operations (5) and QA (I) reviews for walkdown activities. No ccrmonality exists between walkdown findings other than the lack of adequatetechnicaljustification. The most significant findings are: (1) action item 015, which involves the inclusion of unit i features within the walkdown boundaries for unit 2 without justification being provided in the walkdown data package and (2) Q01, which expresses concerns that walkdowns are not always performed per the instructions of SMI-0-17-030. SQEP-08 was revised to cover packaging and controlling of walkdown/ test doctanentation. The concern of finding QOl is being handled as part of the CAQ process governed by NEP-9.1, Corrective Action. The two remaining findings (017 and 018) in this subcategory involve random design criteria problems for which design criteria doctsnents were revised to provide additional justification. Both involved a failure on the part of the design criteria preparers to follow procedures. Increased supervisory attention was implemented as a preventive action. The adverse trend involving change document evaluation findings has been adequately corrected by the 084VP. EA will conduct additional verification during the Phase 11 oversight review of design criteria preparation. There is no indication of additional trends in this subcategory. 8.7.1.4 incorrect Design input /Asstmetion Findings in this subcategory (Figure 8.7-2 and Appendix I) include deficiencies in which input or asstmptions used in design analysis or evaluation were incorrect. There were a total of 12 findings of this type. Findings were observed in the Civil (3), Electrical (7, including i l&C), Mechanical (1), and Operations (I) reviews for a total of 12 findings. None of the findings resulted in the generation of a CAQ document or in hardware changes. Six resulted in the revision of design doctsnents. . Seven of these findings (action items C22, C48. E49, ES2, E59,136, and M09) are part of the previously Identified adverse trend concerning change document identification and evaluation l I forms. Corrective actions included administrative action and revisions of change doctanent evaluation forms. Programnatic preventive and corrective actions have been l j discussed previously and will not be repeated here. ! The remaining five findings include one ea'.h from the system boundary, walkdown, electrical test review, design criteria preparation, and SYSTER activities. There is no indication of an adverse trend for these findings. 8.7.1.5 Inglementation of Administrative Guidance Deficient Findings in this subcategory (Figure 8.7-2 and Appendix J) reflect concerns in which engineering or design work performed does not conform to established adninistrative guidelines, procedures, and instructions. There were 10 findings of this type observed and distributed as follows: Electrical (6, including 3 l&C), Nuclear (3), and QA (1). One finding, E43, concerned the discovery that Westinghouse design criteria preparers had not been trained to SQEP-29. The DB&VP found upon investigation that some Westinghouse design criteria preparers were not aware of the C/R data base. Corrective action was taken to review and revise design criteria as necessary. Preventive action included fornal training to SQEP-29 and nunagement action to confirm that sutaitted design criteria are prepared by trained personnel. A review of renuining findings shows that four resulted from the review of SYSTER$. However, there is no conmonality between the four that would indicate an adverse trend. 8-19

8. 7. l .6 Desian Documents Conflict This finding type subcategory (Figure 8.7-2 and Appendix K) refers to inconsistencies between design doc w ents including design criteria, diagrams, drawings, specifications, and calculations. There were 9 findings of this type. Design doctsnent conflicts occurred in the Civil (2), Electrical (4, including 318C), and Mechanical (3) discipline reviews. No hardware modifications were necessary as a result of these findings. Action itens C)9 a,nd 129 resulted in the issuance of CAQs documents. Seven of the findings led to changes in design docisnents. Four findings (Cl9, C39, 129, and M21) are concerns which involve design review checklists for ECN evaluations. These are part of the adverse trend involving the change docisment evaluation process of SQEP-12.

Preventive and programnatic corrective actions for that adverse trend have been discussed previously. The remaining findings (5) were identified during the review of walkdown activities. They involve various concerns and are not indicative of an adverse trend. 8.7.1.7 Miscellaneous Drawino Deficiencies Findings in this subcategory (Figure 8.7-2 and Appendix L) refer to drawing or draf ting inconsistencies, such as missing, inaccurate, or inappropriate information or references. Nine findings of this type were recorded. Findings were observed in the Civil (2), Electrical (2 in 18C), Mechanical (1), Nuclear (2), and Operations (2) reviews. Three of the findings (action items 135, N45, and N47) resulted in the issuance of CAQ docisnents. Five revisions to design docisnents resulted from these findings. There is no adverso trend in this subcategory. 8.7.l.8 inclementation of Technical Guidance Deficient Findings in this subcategory (Figure 8.7-2 and Appendix M) reflect cases of design doctanents not conforming with established division or corporate design methods or requirements. There were 9 findings of this type, from Electrical (6, including i 18C), Mechanical (1). Nuclear (1), and Operations (1) reviews. None of the findings resulted in a CAQ docisnent. Seven of the 9 findings wre considered to be isolated occurrences and 6 of those were minor editorial or administrative problems which had no effect on the design process or on operations. There were no CAQs issued as a result of these findings. There are no adverse trends in this subcategory. 8.7.1.9 Miscellaneous Desian Doctanent Deficiencies (except Drawinos and Calculations Findings in this subcategory (Figure 8.7-2 and Appendix N) reflect concerns where there are errors in doctsnents other than drawings and calculations. There wre 5 findings in this subcategory. Findings were observed in Civil (2), Electrical (l), and Nuclear (2) reviews. No CAQ docisnents resulted fran these findings. Four of these 5 are concerns with adequate evaluation of change doctanents (in this case, ECNs) and are therefore part of that previously discussed adverse trend. Adequate corrective and preventive actions have been inplemented by the 084VP.

8. 7. 2 Deslan Review Process / Methods inadequate Deficiencies that relate to inadequacies within the design review process ard/or design review process nothods are included in this category.

8-20

8.7.2.1 Missina/l e nte Desian Review Process Procedures The 16 findings in this subcategory (Figure 8.7-2 and Appendix 0) reflect concerns in which procedures / instructions for the control of the design review process are missing, inconsistent, or inadequate. Findings of this type were observed in the Civil (2), Electrical (5, including i 14C), Mechanical (2), Nuclear (4), Operations (2), and QA (1) reviews. One action itera, E67, resulted from a review of SQEP-14 Electrical Test Evaluation and noted there was insufficient guidance given as to the responsibilities for specifying test and retest acceptance criteria and for acceptance of test results. A new procedure, SQEP-57, " Processing of Test and Retest Requirements identified During the Design Baseline and Verification Program" was issued to provide the necessary guidance. 8.7.2.2 Technical Guidance inadequate Findings in this subcategory (Figure 8.7-2 and Appendix P) include those in which the technical guidance provided to 084VP personnel through. technical procedures, standards, and guidelines are not adequate to satisfactorily control the design and evaluation process. The EA Team observed four findings in this subcategory. One finding each resulted from the Civil, Electrical, Mechanical and Operations reviews. As discussed in previous sections, the findings were coded against design related deficiency categories whenever possible. Therefore the discussions of other finding type subcategories has discussed corrective and preventive actions for identified trends in terms of actions which strengthen the technical guidance provided to 084VP personnel. 8.7.5 Inadequate Interface Control , Internal Olscipline Interface Deficient Findings in this subcategory (Figure 8.7-2 and Appendix Q) express concerns that the flow of design information between disciplines or groups with the 084VP is deficient. Also included are instances in which the internal (i.e., within ONP) interface between the 084VP and supporting organizations is not adequate. Four findings exist for this subcategory. Findings were observed in the Civil (I), Mechenical (2), and Operations (1) reviews. There are no indications of an adverse trend in this subcatecory. 8.7.4 Deslan Criteria Deficiencies The findings in this category concern instances in which relevant design requirenants were not adequately or ccepletely incorporated into design criteria. Missing requirements, inconsistent requirements, or conflicting requirements are also included. 8.7.4.1 Missino Requirements in Desian Criteria Findings in the subcategory (Figure 8.7-2 and Appendix R) are those for which the requirements for relevant design parameters have been omitted from appIIcable design criteria. For the 004VP, an additional convention was established in that these findings include those for which applicable C/Rs were captured in the C/R data base but were not incorporated into appropriate design criteria. l 1 8-21

I There are 20 findings in this subcategory. Findings were observed in the Civil (2), Electrical (9 including 5 for I&C), Mechanical (5), and Nuclear (4) disciplines. Two action items (E25 and 113) resulted in the generation of CAQ docunents. None of the findings resulted in hardware changes but 14 did require changes to design documents. Sixteen findings cited revisions / issuance of design criteria docunents as a corrective action, in several instances dif ferent action items refer to the same criteria revision or DIM (design input memorandun) as C/A. Consequently, the nunt)er of action items which cite criteria revision or issue does not equate to a discrete nuttier of such DB&VP actions due to multiple-counting. Of the two civil findings, the first action item C06 concerned a missed conmitment to the NRC for piping design criteria for the auxiliary feedwater (AFW) system. The C/R was forwarded to the AFW SE for inclusion in the AFW design criteria. The concern of missed licensing comnitments in design criteria was judged to be extensive in several disciplines. Accordingly, a corrective action program was begun as described in items 2 and 8 of John Cox's mano of Septent>er ll, 1986 (825 060911 012). The Inpell files of N/A ccranitments was reviewed by a senior TVA engineer for missed C/R sources. The NEB files of licensing conmitments were also sanpled to ensure that applicable C/Rs were not omitted frcrn design criteria. The second civil finding, Cl4, concerned the lack of a requirement in SQN-0C-V-l.5.4 to provide for the consideration of the ef fect on the seismic analysis of cable trays of the added mess of cables at exit points of the trays. A test report from Wyle Laboratory (CEB-8N-1010) qualified typical Sequoyah tray configurations. The programnatic issue of overloads and additional attactrnents to cable trays are addressed in the resolution of SCRSQNCEB8622, which was identified independently of this action item and is being processed in accordance with the corrective action process of NEP-9.l. ThreeoftheElectricaldisciplinefindings(actionitemsEI5,E21,and[23)werejudged to af fect nultiple disciplines and have extensive inplications. The concern of action item EI), the inclusion of Federal / State / Local permits in the C/R data base, even though extensive, has no significance or effect on restart since such C/Rs are nonsafety-related. The project engineer has requested all discipline branch chiefs to sutait C/R sheets for all nonsafety-related permits. Findings for action item E21 involved the cnission of C/Rs from the design criteria for the DG System, the Auxiliary Power System, the 120 Vac Vital Power System, and the 125V Vital Batter System. The finding for action item E23 concerned the failure to address electrical cable requirements in design criteria, in both cases, the DB&YP issued DIMS to capture the C/Rs in appropriate design criteria. Additional corrective actions included a review to identify C/Rs not identified in the original system sorts used for design criteria preparation, the identification of enhancements to be made to the design criteria during Phase 11 of the DB&VP, and the issue of PIR$QNCEDB672 to resolve the concern of proper reference of governing general design criteria in system design criteria. The remaining six of the Electrical discipline findings (E24, E29, E40,11),117, and 120) were discipline specific. The finding for action item E24 concerns the omission for SQN-DC-V-II.2 if requirenents for the vital battery minimun terminal voltage at the design discharge state. Action item E29 involved the failure to capture nuverous C/Rs in the auxiliary power design criteria SQN-Oc-V-II.4.1. The finding for E50 involves certain control and indication features for notor-operated valves in the RHR and RCS systems being omitted from their design criteria. For 115 the requirements of IEEE 325-1974 for replacement Mrts and equipment were not captured in SQN-DC-V-32.0 for the EA systern. Design requirements for instrunent setpoints and other design requirements were also (nitted frcrn the EA system criteria. Finding l17 concerns a review by Inpoll 8-22

which assigned a C/ft for TVA to provide seteorological sanitoring syste features and additional emergency response organization staffing to be II/A when in fact the C/R l should have been assigned to the Division of gluclear Power. Finding 120 is an esponsion l on one of the concerns for ll) for the ACA syste design criteria in which a requirement I to replace 20-200 second range relays with a 5 second range relays. There is no componality between these findings to indicate a trend in that different systees and different types of C/Rs are involved. C/As for each (eacept 120) included a review by the 00$VP of the missed C/Ils and the revision of design critoria to include valid C/Its. l l For120the00tVPprovidedtechnicaljustificationfornotincludingsetpoint requirements in the ACA design criteria and clarified the broader issue of recognition and treatment of setpoint issues by indicating that it will be handled by a seperate program outside the OttVP. The C/A for E40 to include noncontrol and indication features in the RIE System design critoria is to be accoppilshed af ter restart. The finding for E29 was judged to be extensive throughout the Electrical discipline in that it acknowledge the outent of problems associated with incorporating C/Rs into design criteria. - The reunining findings were isolated (E24, E40, and 120) or limited (II) and 117) in extent. Significant corrective actions included the ccamitment to review the issue of missing C/Ils for inclusion in appropriate design doctsusnts during Phase il of the DetVP (finding E29). In addition, a policy memorande was written in response to ll) which provides guidelines on the types of setpoints and/or limits which should be specified in machenical design criteria. The OttVP investigation of action item 11) which contained nultiple findings, resulted in the generation of SCitsgelEM615 concerning the nood to supply essential control air to sample isolation valves and radiation monitors in the radiation nonitoring system. The requirement to supply essential air had been identified as a C/R from a review of LERL60$000527 but was not included in the ACA system design criteria. This concern could have gone undetected had it not been discovered during this review. The Mechanical discipline review resulted in five action items (MI), Mi$, Ml8, M24, and M28). The finding for Ml) involved a isolated concern in that a requirement for minimizing cavitation of EllCW throttle valves was not presented in the EllOf system design criteria. Design Guide OG-n6.5.3 was revised to provide guldence to check for cavitation. A study of the need for EllOf system modifications will be completed af ter restart. The finding for Mi$ 13 that )he EllOf system design criteria did not address temperature and pressure stresses for support design and stress analysis. Further investigation revealed the omission to be entensive throughout the discipline. C/A is to revise applicable design criteria after restart to reference design guide M$.l.1 for determining insulation and Operating Modes requirement to be considered in piping analysis, increased nonegement attention will constitute preventive action to ensure that system design criteria reference relevant documents. l The finding for M18 is that the CCS design criteria did not reference IIPSH valves for thermal barrier booster pa ys. C/A was taken to revise the subject criteria. 10 0 preventive action was considered necessary. The finding for M2A involved a concern which was found to have sultidiscipline ispect. A review of the EllOf system design criteria noted three appendices which listed C/fts but none of the requirements were incorporated into the tout of the design criterla. The design criteria for the EllOf, CCS, and AFW systens were revised to provide guldence on the use of the C/Rs lists attached to the criteria, increased supervisory attention should prevent a recurrence of this concern. 8 25

I The finding for action item M28 is a concern that some parameters for the design of SIS , cold log accumslators were not captured. The 084VP C/A was to prepare a C/R data sheet I to add the requirement to the C/R data base. Additional corrective action for this concern to address the broeder issue of the C/R data base adequacy will be accomplished through the review program described in John Cox's memo to SQEP files dated 12/3/86 (825 861205 Ol9). Three of the five mechanical action items (MI), MIS, and M24) wre written as a result of the review of the ERCW system design criteria. This is not considered an indication , of a trend since the concerns were generated by different reviewers. A concentrated review of any design criteria would likely discover similar concerns. The D84VP corrective and preventive actions have included an assessment of extent and significance have adequately addressed the presence of similar conditions in other criteria. Action items N19, N22,'N24, and N27 were issued during the Nuclear discipline review of design criteria preparation. Action item N19 was an information request to clarify the 084VP position with respect to contairment isolation conpliance with CDC 54-57. Action items N22 and N27 concerned failures to incorporate C/Rs into appropriate design criteria.. Corrective actions were acconplished for both through the review of the CR data base and design criteria as discussed in John Cox's meno dated Septenber 11,1986, to the SQEP files. Action item N24 was for a progranmatic deficiency for the proper specification of materials and associated requirements into design criteria. NEB performed a conplete review of 267 materials-related C/Rs to determine if any should have been incorporated into system design criteria. (See nuno from R. C. Weir to J. F. ( Cox dated Noventer I),1986, B45 861115 254). A total of 141 of the items were found to I have been previously incorporated into system design criteria. Of the remaining 226 l C/Rs, one was found that should be incorporated into the Auxiliary Control Air System criteria after restart. The conmonality among many of the action items in this subcategory is the issue of incorporating C/Rs which were included in the C/R data base into appropriate criteria. This adverse trend was addressed by a corrective action program addressed in menoranda from John Cox (Assistant Project Engineer) to the Sequoyah files dated Septenter ll, 1986 (snd discussed in section 7.6.l.2) and Decenber ),1986. The corrective action program includes additional reviews to identify missed C/Rs and incorporate them into the C/R lists attached to the criteria. The corrective action program is adequate to resolve this averse trend. 8.7.4.2 Inadequate /Inconclete Requirements in Deslan criteria Findings in this sub category (Figure 8.7-2 and Appendix S) express concerns in which relevant design requirements are contained in the appropriate design criteria but are not adequately or conpletely addressed. This finding subcategory contains 18 findings. Findings were observed in the Civil (4), Electrical (7, including i lac), Mechanical (2), and Nuclear (5) disciplines. Ten of the 18 findings in this subcategory have C/A which are to be inplemented after l restart. None resulted in a CM) docuneet being issued or in hardware changes. The corrective action for 16 of the 18 is to revise or issue a design criteria document I (usually by issuance of a design input memorandue (DIM). Ten of the findings involved l isolated or randan concerns. Significantly, no preventive action was considered necessary for 11 of the findings which is an indication of the isolated nature of many of these findings. Preventive actions utillred to prevent recurrence for this l l 8-24 l

subcategory include increased supervisory attention. These findings will also be af fected by the corrective action program for the C/R review and subsequent criteria revision as discussed in John Cox's manorandum to the SQEP files of,Septenter 11, 1986 (825 860911 012). Considering the scope of the design criteria preparation activity for the OgWP and the ' isolated nature of many of these findings an adverse trend for inadequate / incomplete requirements in design criteria is not indicated. The corrective and preventive actions taken should adequately address the progrannetic aspects of design criteria preparation. 8.1.5 Correcti w/Preventi n Actions inadeouste 8.7.5.1 potentially Generic Desion Problem Ilot Addressed Findings in this subcategory (Figure 8.7-2 and Appendix i) reflect concerns where potentially generic design or design review problems were not adequately investigated for possible effect and need for corrective action. There are 7 findings of this type, including Electrical (5, including 2 lac), iluclear (1), and Operations (1) review itens. Ito CAQ documents were issued as a result of these action itens. l The five electrical discipline findings include two for design criteria' preparation, one for change document evaluation, and two related to walkdown activities. 8.7.5.2 Correctiw Action inadeouste The four findings in this subcategory (Figure 8.7-2 and Appendix U) include instances in which corrective actions for previously recognized design or design review problems are found to have been inadequately identified and/or implemented. Findings wre observed in the Civil (I), Itechanical (I), and Operations (2) reviews. 8.7.6 USQD Deficiencies t 8.7.6.1 Incomplete Evaluation i i Findings in this subcategory (Figure 8.7-2 and Appendix V) represent instances in which a USQD did not adequately or completely identify or evaluate all relevant factors of an l issue. Four such findings resulted from the EA team reviews of the Electrical (3) and fischanical (l) discipiires. 8.7.7 Test Requirement / Test inelementation Deficient 8.7.7.1 Test Results inadequate ' t l The four findings of this subcategory ((Figure 8.7-2 and Appendix id)) involve concerns in which test requirenents and procedures are adequately identified and inglemented but the results of the test are deficient due to failure to adequately perform the test, the , equipment failed to meet acceptance criteria, or the test record forns and drawings are l not acceptable. Findings were observed in the Electrical (), including on 14C) and

• I Operations reviews, t

8-25

r

             -(

8.7.8 Miscellaneous Deficiencies

8. 7.8.1 Operations and Maintenance llelated The 8 findings in this subcategory (Figure 8.7-2 and Appendix X) reflect concerns of an operational or neintenance nature and, as such, would not be categorized against design and engineering deficiencies, methods, or processes. Findings were observed in 18C (2),

Operations (5), and QA (1). 0.7.9 other Findinos The finding types which have not been previously discussed are those which had three or less occurrences per finding type and thus constitute the least occurring findings. These findings are spread over 16 of the 35 subcategories yet represent only 6 percent of the , findings (Figure 8.7-2 and Appendix Y). Within each of the sixteen finding type I subcategories there were three cases with three findings, one case with 2 findings, and 5 I cases with one finding. Therefore, no findings were observed in seven of the finding type 1 - subcategories. An inspection of these categories shows the findings to be distributed among numerous disciplines. No casmonalities or trends are indicated in these subcategorles. 8.7.10 Adninistrative Findinos not affectino the Desion Process The findings identified in Appendix Z were considered adninistrative and/or editorial in nature because they were determined to have no effect on the design or engineering process. These findings have been included within the database for analy1lis since they are valid concerns. As shown in Figure 8.7-21 findings of this type accounted for 8.4% percent of the evaluated findings. These findings were analyzed for trends or conmonalities among findings to ensure they would have no affect on the design process. There is no evidence of any adverse trend or commonality among these findings and, hence, no indication of an unrecognized affect on the design process. 8.7.ll Af fected Documents Evaluation A graph of Evaluated Findings by affected doctsnents is given in Figure 8.7-7. The identification of affected doctment types was used in the evaluation of Finding Type ! Categories in section 8.7 and in developing the sisensry level information of section 8.4. The various change categories refer to both problems with the actual change doctanent or with the corresponding identification and evaluation forms. Likewise, the design criteria documents include problems with design criteria and with identification of C/Rs. l 8.7.12 llesponsible Discipline Evaluation The evaluated findings were also evaluated on the basis of the discipline responsible for the deficiency (and, hence, the C/A and P/A) which caused the finding. This evaluation by discipline was performed to support the evaluation by finding type and to provide additional information fran a discipline point of view to support the development of overall conclusions. Discipline involvement has been adequately reflected in the previous discussions of Finding Type Subcategories. Figures 8.7-8 through 8.7-17 show the responsible organization (including multidiscipline involvement) as a function of all evaluated findings and by finding type categories, respectively. 4 8-26

8.7.15 Cause Assessnent Evaluation The evaluated findings were also analyzed on the basis of root cause of the condition which resulted in the finding. This analysis of cause was performed to aid in highlighting potential root cause trends which may not be readily apparent from the finding type evaluations. The determination of root cause is normally nere subjective in nature than other parameters avaluated and is based on the total " content" of an action item, i.e., the reviewer's original concern, the 088VP response, the reviewer's followup evaluation, and the experience / knowledge of the EA evaluation team. Root causes for the evaluated findings are shown graphically in Figure 8.7-18. Five cause categories are seen to have dominated the cause rankings. These are: e Doctmentation of evaluation inadequate /inconglete (%) e Fall to comply with procedures (48) l e Identification of design input / design basis inadequate / inconplete (35) e Engineering evaluation inadequate / incomplete (52) e inadequate procedures (29) Three of these categories represent deficiencies in performance or doctanentation evaluations or decisions made by 088VP personnel. These categories have to do with adequacy of identification of design input / design basis, the engineering evaluation process, and doctmentation of evaluations mode. These root cause trends indicate a need for continued managenent emphasis and attention to adequate training of D81VP personnel, on thorough and conplete identification and evaluation of technical requirements, and on conglete docismentation and justification of evaluations. Continued emphasis on proper procedural requirements and adherence to procedures is also indicated. 8.7.14 Preventive Actions Evaluation This section discusses the findings by the preventive action taken for the finding. The l three basic categories of preventive action are procedure issue / revision, formal training, and supervisory application. The distribution of each type of preventive action utilized by t% DB&VP is shown in Figura 8.719. It must be ramenbered that several action items might refer to the see preventive action. Therefore, the nuneer of actions shown in Figure 8.7-19 will not correspond quantitively to the nunber of discrete actions taken by the DB&VP. The preventive actions have been factored into the discussion of tre,nds by finding type, it is therefore believed that any trends related to preventive actions have been adequately discussed. Tte most prevalent preventive action was increased supervisory attention or involvenent. hatt in frequency of occurrence was the revision of procedures andtheprovisionofadditionalguidancethroughprojectdirectives. For 102 of the actionitems,nopreventiveactionswerejudgedtobenecessary. 8-27

N A l i 8.7.15 Sucolemental Evaluations - Extent, Sionificance. and CAO Documents issued 2 . l Additional groupings of evaluated findings are presented in this section. Figure 8.7-20 displays the extent of conditions assessment of the findings. An evaluation of  ! significance is shown in Figure 8.7-21. Appendix AA presents a listing of the cvaluated ' findings which resulted in CAQ documents. It is felt that the full impact of these

assessments have been adequately evaluated for trends through their incorporation into the  !

, discussions previous sections. Therefore,' these groupings are presented in this section for summary purposes for the evaluated findings rather than for purposes of indicating adverse trends. l 8.7.16 Open Items and Catenorv Chanees s ' In order to categorize and input EA Team findings and perform the various data sorts needed for the in-depth evaluatics a cut-off date of March 31, 1987 was established. M-r--t to cut-of f additional information on some items was obtained. These findings are considered and discussed in the evaluations where deemed appropriate, generally based on significance. Therefore, some appendices may not agree exactly with the corresponding discussion on a quantitative basis. Even though the open action item findings were excluded from the in-depth evaluation, comparisons of the finding type subcategories, corrective actions, preventive actions, cause assessment, and extent assessment have been made to ensure that trends or

cosmonalities with a potential significant ispect on the design review process have not ,

been overlooked. The couperison for corrective action, preventive action, cause, and extent is based on evaluated (closed) findings and resolved findings as these items have not been definitively established for unresolved items. This comparison is sunnerized graphically in Figures 8.7-l, 3, 4, 5, and 6. The couperison of finding type subcategories in Figure 8.7-1 shows that, in general, the same distribution of findings is present in the closed and open findings. The only

emceptions are for subcategories N (NSSS Interface Deficient), 0 (Corrective Actions j inadequate), and U (Processing of Records Deficient). The comparison of subcategory H r Involves one evaluated (closed) item in the Nuclear discipline concerning the omission of j source documents from the Westinghouse C/R search for design criteria preparation. The j resolved finding is a civil concern for the lack of coordination of design criteria for Reactor Coolant Piping pipe stress criteria between TVA and Westinghouse. PIRS@CE88669 i has been written to correct the design criteria reference. leille both action items concern interfaces between TVA and Westinghouse they are not considered indicative of an adverse trend. The interfaces between TVA and Westinghouse are numerous. Both_the civil and nuclear findings were determined to be specific to their disciplines. Accordingly, it j

is concluded that these findings do not represent an unacceptable rate of interface deficiencies. The corrective and preventive actions in each case should be adequate to resolve the concerns of these findings. A review of the concerns associated with the Corrective Action and Processing of Records subcategories have been examined. The five findings for the Corrective Action subcategory include four items that are, unresolved and one resolved. There is no commonality or trend

• indicated by these findings. The two items in the Processing of Records subcategory involve two findings; one in which a change was made to leP-46 without using the QA record form to document the change. The other is a concern that the document control center is releasing SYSTERs with missing sections.

v 5 ON

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       .,---__,----.__,_.m._                            . . . _ . _ - - . _ _ - - _ _    - ,    .         ..          - - - - - - - .
                                                                                                                                      ---.._.--,_-,m.--

The comparison of corrective actions in Figure 8.7-3 shows the only difference in distribution of types of corrective actions to be in category 7, which involves revision or issuance of SYSTER reports. The resolved action items contain neerous findings for which the corrective actions are to be handled in the appropriate SYSTER reports.so the level of activity in this corrective action category is not surprising nor indicative of an adverse trend. The review of preventive actions, cause assessment, and assessment of extent, as shown in Figures 8.7-4, 5, and 6, do not indicate any significant differences. The review and conparison of finding types for open and evaluated (closed) findings does not indicate any trends beyond those previously identified and addressed in this in-depth evaluation. However,'neny of the open findings represent concerns for which the full extent and significance have not been established. Since each open item will become an observation and will be dispositioned before restart it is not anticipated that these items will affect the results from the evaluated findings. The EA team will verify the C/A and P/A established for the open findings.

TABLE 8.4-1

                            . ACTION ITEMS GENERATED BY THE EA TEAM (PRESENTED BY ACTIVITY                   Transitional 0).

System Design Change Change Electrical Design Criteria Control System Preparation Evaluation Report Boundary Walkdown Documents Test Evaluation C54 M50 Q09 E33 C05 E43 N07

 'E08   COI 002     CO2 E07 104 M36                                      C06 E44 N08         CSS- MS2             Q11 C03 E09 121 M37                        E34                                                    Tol N01   C04 003                                                          C07 E71 N10         C56 N49 C08 E10 I22 M38                        E36 NO2   E01 004                                                          C10 E74 N13         C57 N50 C09 EIS I23 M39                        E37 NO3   E02 005                                                          C11 109 N17         C58 N51 C13 E17 124 M40                        E38 N04   E03 006                                            E56           C12 Il0 N18         E77 N52 N05   E04 007      C19 E18 I25 M41                                     C14 Ill N19         E80 N53        DB&VP Phase I-C21 E27 126 M42                       E57                                            Preliminary Report N06   101 008                                            E60            CIS 112 N20        E81 N54 N09   102 009      C22 E32 127 M44                                      C16 113 N21        E82 NSS C23 E35 128 M51                       E67                                                     N58 N11   103 010                                            E70            C17 I14 N22        E83 N56 N12   105 012      C25 E41 I29 N14                                      C18 IIS N23        E84 N57               Q10 -

C29 E42 I30 N15 E78 N30 IO6 013 E79 C20 I16 N24 E85 024 N31 107 014 C30 E45 131 N16 C24 I17 N25 E86 Q07 IO8 015 C31 E46 133 N33 I32 N32 I46 C26 I18 N26 E87 Q13 I45 016 C32 E47 134 N34 C27 I19 N27 E88 M01 019 C33 E48 I35 N35 C28 I20 N28 E89 M02 020 C34 E49 I36 N36 C46 M07 N29 E90 M03 021 C35 E50 I37 N37 E11 Mll N39 E91 M04 022 C36 E51 138 N38 E12 M12 N43 I48 MOS QO1 C37 ES2 139 N40 E13 M13 017 149 M08 QO2 C38 E53 I40 N41 E14 M14 018 ISO 001 Q04 C39 E54 I41 N42 E16 MIS Q05 151 Q06 C40 E55 I42 N44 E19 M16 Q12 152 C41 ES8 I43 N45 E20 M17 153 C42 E59 I44 N46 E21 M16 154 C43 E61 I47 N47 E22 M22 155 C44 E62 M06 N48 156 C45 E63 M09 011 E23 M24 E24 M26 157 C47 E64 M19 023 158 C48 E65 M20 QO3 C49 E66 M21 Q08 E25 M28 E26 M29 I59 I60 [h" m ra C50 E68 M23 E28 M30 - E29 M31 M10

• CSI E69 M25 M33 o-C52 E72 M27 E30 M43 'I E31 M45 M47 C53 E73 M32 M48 E05 E75 M34 E39 M46 E40 M49 E06 E76 M35 GThere were no action items for the drawing comparison activity.

NO CORRECTIVE OR PREVENTIVE ACTION ACTION ITEA NO. DESCRIPTION C22 U2 ANAL OF CONT SPRAY TEST LINE FOR ECN L5268 JUSTIFIED AS OPPOSITE HAND OF U1 BUT ROUTING CONFIG C29 INSUFFICIENT CAPTURE OF ECNs CONCERNING STEEL CONTAINMENT VP.SSEL AND OTHER PRESSGRE BOUNDARY COMP C31 VENDOR CA:.CULATIONS FOR ECN L5451 SEISMIC RESPONSE CURVES DO NOT ENVELOPE TVAs RESPONSE SPECTRA C58 JUSTIFICATION IN SYSTER 72 FOR NCRCEB8205 DOES NOT ADDRESS THE FULL EXTENT OF CEB REVIEW OF CL E83 CRAD USED FOR WD COULD NOT BE REFERENCED TO A SWBID IN SYS EOUNDARY CALC PKG E17 ECN CHECKLIST DUESTIONS WERE DELETED FROM SECT C OF SCEP-12 REVISION 1 (obs. 5.2) E19 C/R ANAL REPORTS WERE NOT DISTRIBUTED TO SE's FOR USE IN DSCN DOCUMENT DEVELOPMENT WHICH VIOLATES SOE E35 APPENDIX R SHUTDOWN LOGIC CALCS ARE NOT DOCUMENTED IN ECN L6544 CHECKLIST AS BEING REVIEWED OR E44 SOEP-18R1 REGMNT THAT C/R DATA SREETS BE PREPARED FOR LICENSING COMMITMENTS WAS VIOLATED FOR 278 SOEPs 14 & 26 DO NOT PROVILE METHOD TO DOCUMENT THE

• FUNCTIONAL" BASIS IVR SAFETY SYS IN ENG DOC 185 CHANGE MADE TO WDP-46 WITHCUT USING OA RECORD CHANGE FORM TO DOCUMENT CHANGE WHICH VIOLATES AI-7 106 DETAIL SKETCH OF PANEL 2-L-381 IS NOT REF ON WDP-46 SUN SHEET & DNE AGREEMENT NOT PROVIDED WHICH V 116 C/R INVOLVING PROCESS CONT SYS. CHAN ACCURACY & SETPOINT TOLERANCE IS NOT DOCUMENTED IN C/R DB I32 ECN L6175 PRESSURE SWITCH RECALIBRATION TEST RESULTS LACK REFERENCE TO METHODOLOGY M20 ECN 2945 DRC HAS MISSING DOCUMENTATION & PIRs HAVE NOT BEEN ISSUED FOR TRACKING PURPOSES WHICH VIOLATES M26 SON-DC-V-13.9.9 MAY NOT LIST ALL APPLICABLE INDUSTRY CODES AND STANDARDS M35 ECN 5415 SOEP-11 ATTACHMENT 1 NOT PROPERLY SIGNED SY SYSTEN ENGINEER N48 ECN 5451 DID NOT REQUIRE THE SEISMIC REVIEW OF THE CONDUIT INSTALLATION FOR THE ENERG DG AC & DC LUBE DIL M49 PUNCHLIST ITEMS ARE BEING CLOSED BEFORE DA COMPLETES REVIEW OF FIELD WORK N12 TNI COMNITNENTS NOT PROPERLY SCOPED FOR SYSTEM BOUNDARY DETERMINATIONS AND DESIGN BASELINE VERIFICA N19 SON-DC-V-2.15 ATTACHMENT A NOTES ARE NOT ACCEPTABLE FOR CVCS INJECTION LINES TO MEET GDC 54-57 (NRC-24. obo. 8.2)

N31 PREVIOUS WALKDOWM EVALUATIONS MUST BE VERIFIED TO MEET REVISED ENLARCED SYSTEM BOUNDARIES IN CALC PKG SO N48 IMPROFER DELETION OF SAFETY-RELATED FUNCTION BY ECM L6876 (NRC 58). 008 CONCERNS AS TO EXTENT, USE AND REASON FOR AS-DESIGNED DRAWINGS IN WDPs (NRC-4) 012 EA TEAM USED *AS-DESIGNED

• DRAWINGS INSTEAD OF *AS-C0FSTRUCTED* DRAWINGS FOR INDEPENDENT WALKDOWN (MRC-5) 013 OPERATIONS INPUT TO DB&V PROGRAM SCOPE MAY NOT FULLY CAPTURE THE REOUIREMENTS OF EDIs AND S01s (obs. 4.1) 014 WASTE DISPOSAL SYS CONTAINMENT BOUNDARY PENETRATION 1-46 IS NOT SHOWN ON DRAWING FOR WDP-77 (NRC-16. obs. 7.1) 016 NO PROCEDURES TO REDUIRE REVIEW OF WALKDOWN DATA FOR ASSESSMENT OF POTENTIAL IMPACT ON OPERATIONS (NRC-14. ob 021 GUIDELINES NOT EST FOR CONSISTANCY IN THE COLLECTION OF NP DATA FOR EQUIP MOD OR REPLD SINCE OL (NRC-34. obs. 1.4 023 POST-MAINTENANCE TESTING OF FLOW CONTROL VALVES PER SI-166 & TI-69 IS NOT BEING PERFORNED I

E

                                                                                                                      ~.e Om a

t . .

1 POSTRESTART ACTION ITEMS ACTICH ITEM NO. DESCRIPTION CI5* C16 SON-DC-V-13.5 IS DEPENDENT ON SON RIGOROUS ANALYSIS H C17 C18 GDC EXCLUDES C/R FOR DRILLED ANCHORS & FAILED TO C C26 C30 C33 C/R PARTIALLY CAPTURED IN APPENDIX F DESIGN CRITERIA F CALCULATIONS FOR SUPPORTS 2-H36-72 & 2-H36-105 HAVE NOT BEEN REVISED TC INCORPORATE FCR 39 C57* NUNEROUS ECW AND PUNCHLIST DISCREPANCIES FOUND IN SYSTER 74 REVIEW FOR RHR SYSTEM E12 C/R DATA SHEETS HAVE NOT BEEN PREPARED FOR LICENSING COMMITMENTS WHIC& VIOLATES SEOP-18 E13 SOEP-18 ATTACHMENT 1 DOES NOT LIST FEDERAL. STATE AND LOCAL PERMITS E22 C/Ra FOR DG & AUX SYS. 125 VITAL BATT SYS & 120 AC VP SYS WERE OMITTED FROM ATTACH 2 C E27 ECN L6544 CHECKLIST DOES NOT REFER TO FSAR. TECH SPECS & DESIGN CRITERIA FOR APPLICABLE ITEM E28 ELEC DESICX C/Rs WERE OMITTED FROM DESIGN (NRC-25. CRITERIA & C/R DB TRACKING SHEET FOR AUX PO obs. S.5) E29 AUX. POWER CRITERIA SON-DC-V-11.4.I DID NOT CAPTURE ALL APPLICABLE C/Rs E31

• FSAR REOMNTS. INST CALLING & SEP REOMNTS. ELEC PWR REOMNTS. & 125V VITAL BATT &

E39 IEEE 279 & FSAR C/R FOR CONT SPRAY SYS HAVE NOT BEEN ADEOUATELY ADDRESSED IN SYS D E40 C/R FOR MOV CONTROL & INDICATION FEATURES REF ON PRINTOUTS FOR RER & RCS SYS BUT NOT IN ECN L5872 DRC CONTAINS TECHNICAL ERRORS INVOLVING ECW COVER SHEET. FSAR, LOGIC DIAG. FLOW DIAG & I-TABS E19 E51

• ECN L6712 DRC CONTAINS MINOR ERRORS. CALC ERRORS. AND DOES NOT FROVIDE JUSTIFICATION E53*

E84 E86 ECN L6676 DRC CONTAINS IMPROPER EVALUATION RESPONSE FO CRAD 45N709-2 RL HAS CABLE IDENTIFICATION PROBLEM & VITAL INVFRTER NAMEPLATE DATA IS I 109 THE EFFECT OF RG 1.97 ON THE DBVP HAS NOT BEEN IDENTIFIED (NRC-15.obs. 6.1) 114 123 SINCLE FAILURE CRITERIA TERMINOLOGY IN DESIGN CRITERI A SON-D ECM L5791 DRC REFERS TO ECN WORKPLAN AS BASIS FOR ADDR SETPOINTS BUT WORKPLAN IS CE 124 I 37 ECN 05275 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 2f. 3f & leh 138 ECM L5275 DRC DOES NOT PROVIDE JUSTIFIED CONCLUSION FOR CATECORIZING ITEMS 1. 2a, 2b. 6c. 7a. 8b. 84 & 18b AS *NOT I45 FC-30-149 HAD MISSING COVER AND DAMACED FLEX COND BUT WAS NOT TACCED TO INDICATE CO I47 PERFORMANCE OF PRESS SW REPLACED BY ECN L6374 CANNOT BE VERIFIED SINCE SOURCE D 150 NCR NEB 8405 EVAL DOES NOT CONTAIN JUSTIF FOR LACK OF AUTO CONT INDICATION IN MCR DUR M07 SOEP-18R0 DOES NOT ADDRESS HANDLING OF C/Rs IDENTIFIED AFTER C/R DATA BASE CLOSURE Mll THERMAL LOAD RANGE C/R FOR PIPING DSGN & ANAL. ERCW INTERFACE REO. & MIN TEMP REO NOT M %*J C/R FOR MINIMIZING CAVITATION OF ERCW THROTTLE VALVES NOT CAPTURED IN C/R DATA BASE OR DESIGN C MIS DESIGN CRITE2IA DOES NOT ADDRESS TEMPERATURE & PRESSURE STRESSES FOR SUPPORT DESIGN & STRESS AFW DEFICIENCIES RELATED TO SYS INTERFACE. MISSING C/Ps. SHOP TEST REDUIREMENT, & DESIGN REOUIREMENT FOR ATWP NPSH M17 M22 C/R FOR WESTINGHOUSE PROPRIETARY INFORMATION MAY NOT BE INCORPORATED INTO DESIGN CRITERIA (NRC-27, obs. 2.3) M29 C/R FOR ERCW COMPONENT COOLING SYS "C' HEAD EXCHANCER DISCHARGE VALVE 6-FCV-67-152 NOT M30

• SON-DC-V-27.6 DOES NOT ADDR DSGN REOMNTS FOR RHR PMP COOLING WATER JACKETS & AUX OIL S N32 ECN L5064 DRC ITEM B.2.b WAS INCORRECTLY REVIEWED RESULTING IN INVALID CONCLUSIONS & EVAL M% ECM 5769 DRC DOES NOT REF MFW 3A DC SON-DC-V-4.2 IN RESPONSE TO OUEST B.1 & DOES NOT REF A M45 FSAR DOES NOT REFLECT CCS DESIGN CRITERIA (NRC 37. obs. 2.4)

M46

• C/R DATA SHEETS FOR SYSTEMS NUMBERED HIGHER THAN 99 MAY NOT BE CAPTURED IN THE DESIGN CRITERIA M58 ENTIRE TEXT PAGES FOR SECTS 4.0 & 5.0 IN THE SYSTER ORIGINAL DOCUMENT CONTROL COPY WERE MISSING N19 SON-DC-V-2.15 ATTACHMENT A NOTES ARE NOT ACCEPTABLE FOR CVCS INJECTION LINES TO MEET CDC 54-57 ., g (NR N20 C/Ra REO IND OF SR FLUX OUTSIDE MCR & THAT ELEC 7EN MUST CONFORM TO IEEE 317 OMITTED IN SON-DC-V mg N23 INALEOUATE INCORPORATION OF C/Ka IN SON-DC-V-2.17 I,p N24 PROCH.MMATIC DEFICIENCY EXISTS CONCERNING THE PROPER SPECIFICATION OF MATERIALS & THEIR ASSOCI g(

N26 SOURCE DOCUMENTS OMITTED FROM WESTINGHOUSE C/R SEARCH N27 C/R IDENTIFIED ON TRACKING SHEETS NOT INCORPORATED INTO SON-DC-V-27.7 a

                                                                                                                                                -i POSTRESTART ACTION ITEMS                                               +     *
 ' ACTION.

ITEM NO. ~ DESCRIPTION N28 FAILURE TO INCORPORATE C/Rs INTO SON-DC-V-27.5 TEXT AND TO FULLT SPECIFY DESIGN REQUIRENENTS N29 DISCREPANCIES EXISTS BETWEEN TECH SPEC LCD 3.4.1.1 AND SON-DC-V-2'/.4 FOR RCS 2 LOOP NIN OPERATION CONDITION (obe. 2.5) - N37 SUPPORTING CALC FOR ECN 6549 USED WBN SPECIFIC CALC TO CONCLUDE THAT CNTNT LOCA-DBA FLOOD LEVEL WILL NOT SUBMERGE JBs N42 EVAL OF ECM L5371 OVERLOOKED NEED FOR FSAR REVISION & LACE OF FINAL APPROVAL OF FCR Sol & HAS NUNNNOUS CHECKLIST DISCREP M47. PIPING ELEVATION IN SECT J5-J5 05 47W568-5 DOES NOT AGREE WITH PLAN VIEW & MAT NOT REP AS-BUILT CONF (NCR 57. obs. 2.7) 017 RATIONAL FOR DESIGN CRITERIA 05 RER SUMP LINE ISO VALVES & POST ACCIDENT ISO VALVES NOT UNIFORNLY CAPTURED 018- SON-DC-V-2.15 DOES NOT CONTAIN REFERENCES TO NUREC-1.63. SON-DC-V-11.3 AND SON-DC-V-12.2 FOR CONTENT ELEC FENETRATIONS 019 ARMOURED CABLES ON CSS PUNP REMOTE OPERATED VENT OPERATOR SUSTAIN EXCESSIVE BENDING AND DO NOT OPERATE FREELY

• The action items contain Phase'I and Phase II corrective / preventive actions which have been agreed to by the EA Team but the implementation and/or verification of the Phase I actions has not been accomplished.

                                                                                                                                         ~.

P4 >

                                                                                                                                         ~ a.

PRERESTART ACTIC ITDIS ACTION ITEM NO. DESCRIPTION Cs1 INCOMPLETE TRANSFER OF INF0PMATION FROM NASTER WALEDOWN DRAWING TO COPY IN WDPs FOR NS,HPFP, & PAM CO2 INAPPROPRIATE SEOUENCE FOR ELIMINATING AN ECW FROM FURTHER REVIEW BY MARKING NO INSTEAD O C83 CLARIFICATION OF DEGREE OF CALC REVIEWS REQUIRED TO ESTABLISH TECHNICAL ADE00ACY MR PIPE STR C04 ATTRIBUTES M & N OF ATTACHMENT 5 0F SOEP-98 NOT INCLUDED IN SMI-e-317-30 C05 AUX BUILDING 400V TRANSFORMER ROOM TORNADO HISSILE PROTECTION NOT CAPTURED IN C/R TRACKING S TO NRC FOR AFW PIPING DESIGN CRITERIA WAS NOT CAPTURED IN THE C/R DATA BASE C06 COMNITTNENT IN LETTER A27820381832 C87 REDUCTION OF MARGINS IN FSAR NEEDS LICENSING ACTION & C/R TRACKING NEEDS TO BE ADDRESSED (NRC-21, obs. 3.2 & 3.3) Cs8 ECN 2971 WAS NOT IDENTIFIED ON NCR/SCR IDENTIFICATION FORM BY SDE FOR ANALYSIS BY SYS ENGR . C89 SCR/NCR IDENTIFICATION FORM INCORRECTLY SHOWS SCRCEB8484 AS CLOSD AND IMPLEMENTD Cle REG. GUIDE 1.29 C/R I102 PROTECTION OF CATEGORY I COMPONENTS FROM FAILUBE OF CATEGORY II COMPOW C11 DESIGN CRITERIA ON ELEC RACEWAYS WAS NOT CHECKED ON C/R FORM & ALL APPLICABLE SUBJECTS WERE NOT ID C12 NCRCEB8219 FOR DESIGN OF MISC STEEL ATTACHMENTS WAS NOT CAPTURED IN C/R DATA BASE C13

SUMMARY

PIPING ANALYSIS CALC PEG FOR EVAL OF ECN L-5724 CONTAINS URVERIFID ASSUMPTION FOR OPER C14 EFFECT OF ADDED WEIGHT OF CABLES IN TRAYS AT EXIT POINTS ON SEISMIC ANALYSIS NOT CONSIDERED I C19 CIVIL AND ARCH DWCS IN ECN L6306 SHOW CONFLICTING REQUIREMENTS FOR CONC CURBS UNDER ARCH DOO C29 C/R REDUIRING SEALED OR ENCLOSED TERMINAL BLOCKS INSIDE CONTAINMENT WAS MISSED IN IMPELL REVIEW OF C21 ECN L5268 INCORRECTLY SCOPED AS AFFECTING UNIT 1 ONLY C22 U2 ANAL OF CONT SPRAY TEST LINE FOR ECM LS268 JUSTIFIED AS OPPOSITE HAND OF U1 BUT ROUTING CONFIGUEA C23 ECN LS293 INCORRECTLY EXCLUDED FROM SOEP-12 TECHNICAL REVIEW C24 C/R FOR FSAW TABLE 3.2.1-1 NOT CAPTURED & PROJECT DISCIPLINE INTERFACES INADEOUATE TO CAPTURE GENERIC C/E C25 JUSTIFICATION FOR CALCULATION MODIFICATION NOT PROPERLY DOCUMENTED THROUGH USE OF A RIMS NUMBER C27 IMPROPER REFERENCE TO SOM-DC-V-13.3 BY RCS DESIGN CRITERIA C28 INCORRECT REFERENCES TO CEB GENERIC DESIGN CRITERIA IN SON-DC-V-27.5 C29 INSUFFICIENT CAPTURE OF ECNe CONCERNING STEEL CONTAINNENT VESSEL AND OTHER PRESSURE BOUNDARY COMPONENTS C31 VENDOR CALCULATIONS FOR ECN L5451 SEISMIC RESPONSE CURVES DO NOT ENVELOPE TVAs RESPONSE SPECTRA C32 ADDITIONAL SUPPORT DRAWINGS FOR ECM L61% ARE NOT LISTED WITH REFERENCED CALCULATIONS ON CIVIL CHECKLIST C34 SOEP-12 CHECKLIST PREPARATION GUIDANCE REVIEW INADEOUATE MR ECNs 2548 AND 5978 DUE TO UNCLEAR REQUIR C35 CEB CHECKLIST NOT PREPARED FOR ECW 2120 AND GENERIC IMPLICATIONS NOT IDENTIFIED AND ADDRESSED C36 ECN EVALUATION DID NOT CONSIDER PIR, SE MODIFIED CIVIL CHECKLIST WITHOUT SDE OK, AND CHECKLIST WAS NOT READABLE C37 ECN 2944 DRC ITEM 6.3 ATTACH 2B-2 REFERENCES PIPE SUPPORT DWGS BUT DOES NOT REFERENCE CALCULATION DOCUMENTS C30 NCR CEB8484R1 IDENT FORM DOES NOT DOCUMENT TECHNICAL JUSTIFICATION FOR CORRECTIVE ACTION WHICH VIOLATES SOEP C39 ECM L6439 DATA SHEET DOES NOT ADDRESS ALL APPLICABLE DRAWINGS THAT CALCULATIONS WERE PERFORMED ON FOR CUT R C48 IMPROPER INPUT OF CIVIL INTO INTO COMPLETED ECM REVIEW C41 ECW L5719 DRC REVIEWED CIVIL DESIGN REQUIREMENTS BUT DID NOT EVALUATE FIELD INPLEMENTD WORK C42 TECHNICAL JUSTIFICATION AND EVALUATION NOT PROVIDD FOR ECW L6263 AS WELL AS CHECKLIST ITEM 6.4L C43 ECM L5779 SOEP-12 REVIEW IDENTIFIED DESCREPANCIES WITH SOEP-12 CHECKLIST, CIVIL CHECKLIST AND ECN DATA SHEET C44 ECW L6263 CALC CONT DISC BETW LENGTH OF BRACE ON DWG & LENGTH USED IN STRUCT COMPTR MODEL AND USED INVALID SUP C45 SDE REVIEW OF ECN L6694 FOR CATEGORY D FCR 4993 DID NOT RECOGNIZE POTENTIAL IMPLICATIONS ON ALL RESTART SYSTEMS C46 ANCHOR PT MOVEMENT NOT ADDR IN DSGN CRIT & CABLE TRAY SUPPORT DSGN DOES NOT ADDR PT LOADS (NRC 44, obs. 8.1, 8.3, & 8.4) C47 ECN L5298 DRC ATTACH 2B DOES WOT PROVIDE JUSTIF FOR STATEMENT THAT CALCS ARE NOT REDUIRED FOR FCE 455 (HRC 45, obs. 7.4) C48 CNTNT PENETRATION LEAK TEST ANAL DOES NOT ADDR BOUNDING CASE OF PIPE CANTILEVERED MAX DIS FROM READ PL (NRC 48, OBS.3.6) C49 ECN L6556 DOES NOT PROVIDE BOLT SIZES & MAT SPECS FOR LIMIT SWITCH MOUNTING PLATE OR SEIS 00AL FOR BRACKETS & BOLTS C50 NRC AUDIT OF ECN L6479 IDENT DISCREPANCIES BETW PIPING LAYOUT SHOWN ON ISOMETRIC & PHYSICAL PIPING DWG (NBC 58, obs.3.5) C51 TECHNICAL REVIEW OF ECM L6487 DID NOT ADDRESS PIPING CALCULATION & FSAR DISCREPANCIES NRC AUDIT OF ECN L5274 IDENTIFIED DISCREPANCIES BETWEEN RHR PIPING SHOWN ON ISOMETRIC & PHYSICAL DWG (NRC 52, obs. 3.9) I2h C52 C53 TABLE OF SUPPORT CALCS & LOADS REFERENCED IN ECM L6719 CONTAINS DISCREPANCIES IN LOAD MAGNITUDES & CALC LOAD CONDITION ra C54 INADE00 ATE JUSTIFICATION IN SYSTER 26 FOR SEISMIC OUALIFICATION OF TACF 1-86-092-826 FOR TACK WELDED VALVE BONNET - INCOMPLETE IVALUATION OF CUMULATIVE EFFECTS IN MATRIX FOR SYSTER 26 DUE TO EXCLUSION OF FCus, LCDRs & TACFs C55 o? C58 JUSTIFICATION IN SYSTER 72 FOR NCRCEE8295 DOES NOT ADDRESS THE FULL EXTENT OF CEB REVIEW OF CLOSELY SPACED ANCHORS E81 LACK OF DOCUMENTATION FOR REDUCING WALEDOWN BOUNDARY ON CRADe FROM SWIBDs (WDP-67R1) e1-

PRERESTART ACTION ITEMS ' (CONTINUED) ACTION ITEM 30. DESCRIPTION ES2 CALC PKG DOES NOT ADDRESS MEANING OF CROSS-HATCHED AREAS OF SYS BOUNDARY ON SWBIDs AND CRADs ES3 CRAD USED FOR WD COULD NOT BE REFERENCED TO A SWBID IN SYS BOUNDARY CALC PKG E04 OVERALL SYS BOUNDARY AND BORIC INJECTION BYPASS LINE WAS OMITTED FROM CRAD ON WDP-63 WHICH VIOLATES SOEP-88 E85 PRE-OL ECN LISTED 05 ECM IDENTIFICATION FORM BUT NOT ON THE OWIL WHICH VIOLATES SEOP-11 E86 ECES L5864, L5867, L5888 ARE IDENT AS AFFECTING SYS 291/292 INSTEAD OF VP & AP SYS WHICH VIOLATES SOEP-11 ES7 GUIDELINES INADED IN SOEP-12 TO ENSURE THAT ALL NEEDED ELEC DIST SYS ARE ADDR IN REVIEW OF ECM CHECK LIST ITEM Sb E88 12 EVAC PREF & 250VDC PWR SYS, RAD MON, SMPL & FP PWR DIST SYS WERE INCORRLY LISTED IN SYS BOUND CAi.C PKG AS VP SYS Ee9 WRITTEN JUSTIFICATION NOT PROVIDED BY SDE's FOR *IMPL* CATEGORY SCR/NCRs WHICH VIOLATES SOEP-11 E11 TRAINING OF SENIOR PEOPLE TO SOEP-18 WAS DONE TO C/R HANDBOOK BEFORE PROCEDURE ISSUANCE E14 PROJ'S METHOD TO VERIFY THAT IMPELL IS ASSIGNING DOCS TO CORR BR NOT COVERED IN SOEP-18R9 & INPELL INST (NRC-18,obs.S.4) EIS E16 SDE's SUBMITTED SCP/NCR IDENT FORMS TO REVIEWER BEFORE RECEIVING ALL *ONP' DOCUMENTATION WHICH VIOLATES SOEP-11 E17 SON DESIGN CRITERIA SON-DC-V-11.3 & SON-DC-V-12.2 WERE NOT INCLUDED IN LIST OF RESTART ELEC CRITERIA ECE CHECKLIST OUESTIONS WERE DELETED FROM SECT C OF SOEP-12 REVISION 1 (obs. 5.2) E18 INSUFFICIENT DOCUMENTATION WAS PROVIDED TO ENSURE THAT CORRECTIVE ACTIONS FOR SONLEB811321 WERE *IMPL' BY ONP E19 E29 C/R ANAL REPORTS WERE NOT DISTWIBUTED TO SE's FOR USE IN DSGN DOCUMENT DEVELOPMENT WHICH VIOLATES SOEP-18 LACK OF CLARITY IN SOEP-290s INVOLVING USE OF NEP-3.2 FOR PREPARATION OF DESIGN CRITERIA E21 C/Rs WERE OMITTED FROM DG & AUX SYS,125V VITAL BAT,7 SYS & 120V AC VP SYS DESIGN CRITERIA E23 CABLE REOMNTS NOT ADDR & CABLE DSCN CRIT NOT REF IN DC CONT PWR SYS, FIFTH VITAL BATT SYS & DG & AUX SYS DSGN CRIT E24 E39 VITAL BATTERY MININUM TERMINAL VOLTAGE AT DESIGN DISCHARGE STATE WAS NOT SPECIFIED IN SON-DC-V-11.2 SON-DC-V-11.4.1 DOES NOT ADDR CABLE CAP FOR CONT OVERLOADS LESS THAN MOTOR BKR PROT RELAY TRIP SETTINGS (NRC-26,obs.S.6) E32 E33 DOCUMENTATION DOES NOT EXIST IN ECH L6615 PKG TO ANS 00EST Sa & 5e & CAO NOT ISSUED FOR TRACKING PUR (VIOLATES SOEP-12) PROCEDURE USED BY ESES TO ASSEM, EVAL & DOCUMENT TEST DATA DOES NOT AGREE WITH SOEP-14 REQUIREMENTS (obs. 5.3) E34 E35 INDEPENDENT REVIEW OF ELEC TEST EVALUATION FOR ECN L5017 PEG WAS NOT PERFORNED WHICH VIOLATES NEP-5.2 & SOEP-14 E36 APPENDIX R SHUTDOWN LOGIC CALCS ARE NOT DOCUMENTED IN ECW L6544 CHECKLIST AS BEING REVIEWED OR AFFECTED BY THE ECN E37 VERIF NOT PROVIDED THAT TRAINED IMPELL PERS ASSIGNED *N/A' CAT OR APPROP ENG BR/NU PWR RESP TO SOURCE DOCUMENTS E38 SUPPORTING ENG JUSTIFICATION FOR ECNs 2633 & L5114 TEST REVIEW PKG DO NOT ADDRESS PURPOSE OF TEST EVALUATION E41 ECN L5114 TEST REVIEW PKG CONTAINED INSUFFICIENT SUPPORT INFO TO JUSTIFY THE EVALUATION CONCLUSION E42 ECM L5114 ELEC DRC CONTAINS MINOR EREORS & DOES NOT ADDRESS SEISMIC OUAL OF ELEC COMPONENTS E43 ECM L5114 DRC CONTAINS OMISSIONS & WAS EVALUATED USING THE WRONG DESIGN CRITERIA - LACK OF TRAINING OF WESTINGHOUSE DESIGN CRITERIA PREPARERS TO SOEP-29 E44 E45 SOEP-18R1 RE0MNT THAT C/R DATA SHEETS BE PREPARED FOR LICENSING COMMITMENTS WAS VIOLATED FOR SYS 62 & 74 PMP CURVE E46 ECN L5451 DRC ITEM B.3.6 EVALUATION WAS BASED ON MB 0F MATERIAL WHICH DOES NOT VERIFY DESIGN CRITERIA REONNT E47 ECN L5451 DRC ITEMS B.3.d&g & B.S.a&b REF WRONG CALC PKG, ITEM B.5.c CONT INADEO RESP, & ITEM B.S.e DID NOT SPECIFY PIR E48 USOD FOR ECN L5451 REDUCES THE SCOPE OF THE ECM AND DOES NOT ADDRESS THE 125VDC LUBE OIL PMP THAT WAS ADDED BY E58 ECN L5451 DRC WAS INCORRECTLY EVALUATED SINCE CHANGES TO 125V DC DG DIST BD WERE NOT INCLUDED IN FIELD WALKDOWN E52 ECN L5872 REVIEW INDICATED THAT INST HAS NOT BEEN PROVIDED TG GIVE MCR INDICATION OF STATUS OF DC E:'HAUST VENT FAN E54 ECM L5872 DRC CONTAINS TECH ERRORS INVOLVING SYS MON CIRCUITS, REF FLOW DIAG INSTEAD OF SCH, & REF WRONG HAND SWITCHES E55 ECE 2945 DRC REF WRONG DSGN CRIT REV,-EVAL TO SYS 31 CHECKLIST, REF CALCS THAT USED UNVERIFIED ASSUM & OTHER MINOR DISC E56 ECN 2945 DRC ITEM B.1 INCORRLY REF SON-DC-V-3.2, B.3.d & B.S.c WERE INCORRLY EVAL AS N/A, AND B.3.d HAD WRONG CONCLUSION E57 SOEP-14R1 SECT 3.6 REONNT WAS VIOLATED IN RED-LINE PKG SINCE AS-DSGN DWG WAS USED FOR AS-CONST DWG TO COMP E58 ECN 2945 TEST EVALUATION DIS NOT DOCUMENT THAT ASSOCIATED PREOP TEST DEFICIENCY HAD BEEN RESOLVED E59 USOD FOR ECN L6815 MISIDENTIFIED ELEC EQUIP BEING MODIFIED t!NDER ECN AS SAFETY RELATED E65 ECM L5872 DRC DID NOT REF DESIGN CRITERIA REV, REF WRONG CALC PKG, & DID NOT REF REDUND, DIVERSITY & SEP REOMNTS E61 ECM L5599 TRP LACKS JUSTIF TO SUPPORT CONC THAT RESOLUTION TO OPEN ITEMS IS NOT REO POR RESTART & SCO E62 ECN L6667 DEC INAPPROP REF BM & STD DWGS, DOES NOT REF EXISTING CALCS, CONTAINS DISC IN ITEM 7 & REVIEWERS NAME ILLEGBLE E63 SOEP-11 ATTACH 1 FOR ECM 5449 INCORRECTLY STATED ECM ONLY INVOLVES AP SYS BUT ECM ALSO INVOLVES VP SYS7d E64 USOD 11)R ECW L5449 DOES NOT ADDR LOSS OF VOLT RELAYING LOGIC & INDICATES OVERVOLT LOGIC 2 0F 23 INSTEAD ECN L5449 DRC CONTAINS ERRORS & DOES NOT ADDRESS DESIGN DISCREPANCIES E65 N E66 ECN L5363 DRC ITEM B.S.c REF WRONG CALC PKG & ITEMS B.19.f & D WERE INCORRECTLY EVAL RESULTING IN I C'INVALID ECE 2774 DRC CONT OMISSIONS THAT COULD PREVENT CALCS FROM BEING MADE TO ADDR ITEMS B.3.d,B.3.g,B.S.a,B.5.b,B.S.c & B.5.e

                                                                                                                                                     *i on

PRERESTART ACTION ITEMS (CONTINUED) ACTION ITEM NO. DESCRIPTION S E67 E68 SEOP-14 DOES NOT IDENT WHO APPROVES

• RETEST
• TEST RESULTS, W E69 ECN L6573 DRC CONTAINS MINOR ERRORS THAT COULD CAUSE THE EVALUATION NOT TO B E79 SOEPs 14 & 26CONTAINS SON-DC-V-11.3R5 DO NOTENVIR PROVIDECOND METHOD TO DOCUMENT THAT ARE DUTDATED & DO NOTTHEAGREE
• FUNCTIONAL WITH ENVIR COND
• BA ISS E71 E73 ECN L6533 DRC DOES NOT SUBSTANTIATE THAT CHANGES HAVE BEEN ADDR IN PROGRAMS OUTSIDE THE DBVP E74 RPS SOEP-12 1E CHECKLIST CABLES ROUTED DUESTIONTHROUGH B.3.c DOES NOT THE TURBINE ADEO BUILDING DOC THAT ARE NOTFAILURE A COMPREHENSIVE BEING ANAL LABELED HAS B E75 E76 E77 CALC PKG OSG7-938 DID NOT ADDR ECNs L5944 & L6459 (NRC 55, obs. 6.11)DBVP-D-86-919 REM E78 E79 ECM L5298 TEST REVIEW PACKAGE RETEST SCOPING DOCUMENT ALL APPLICABLE CHANCES & MODIFICATIONS MAY NOT BE CAPTURED AND INCLUDED IN SYSTER 82 E E89 E81 TECHNICAL JUSTIFICATION NOT PROVIDED FOR SWBID AREAS NOT WALKED DOWN & AS CO E82 ECN L6746 NOT CAPTURED IN SOEP-12 REVIEW OR IN THE SYSTER EVALUATION WHICH CO E83 PUNCHLIST DWG DEFICIENCIES, ITEMS LISTED PUNCHLIST AS &POST-RESTART ITEMS, W/0 SUFF PUNCHLIST ITEM CONFLICTS ARE TECH JUSTIF IN NOT ADDRESSED & VP SYSTER EVAL OF SYSTER EVALUATION E85 E87 CRAD 45N727 DOES NOT REFLECT PLANT CONFIGURATION FOR DIESEL 125V DC DISTRIBUTI E88 489V SHDN BD BREAKER SETTING DISCREPANCIES NOT IDENTIFIED ON PUNCHLIST OR ADDRESSED IN AP E89 PUNCHLIST AND SYSTER NOT RECONCILED RESULTING IN ITEMS REQUIRING ACTION BEING E99 UNIMPLEMENTED ECNs NOT ADEOUATELY ADDRESSED IN AP SYSTER & INCORRECTLY SHOW 191 IDENTIFICATION OF COMPONENT 2-SI-46-56B WAS NOT ACCURATELY TRANSFERRED TO MASTER IN If2 WDP FIELD DWG MARKED COMPONENT WITH MISSING ID TAG AS
• ITEM 1* & MASTER COPY WAS NOT SIM 193 WALKDOWN PERSONNEL DID NOT INCLUDE VERIFICATION OF HANDSWITCHES IN COMPLETED WDP IS4 ECM L5938 DRC STATES THAT ITEMS 19h & ISc ARE APPLICABLE & TECH ADEOUATE & OUALIFIES ISS 196 CHANGE MADE TO WDP-46 WITHOUT USING 04 RECORD CHANGE FOR LACK OF ROOT VALVE NUMBERING AND PIPING INTERFACE NOTATION OR FUCTIONAL CONTROL DRA91NGS (N 197 188 METHOD DOES NOT EXIST FOR EVAL RED ELEC & I & C SYS INFORMATION THAT IS NOT OBTAINED FROM WALKDOWN (N Ile TVA RESPONSE TO NRC IEB 85-93 CONTAINS C/Es TO INVESTIGATE, TEST, & MAINTAIN MOV SETTINGS BUT WAS NOT C Ill C/R IN NUREG 911 SER, SUPPLEMENT 5 ITEM II.F.2, REOUIRING BACKUP DISPLAY FOR INCORE TEMP WAS NOT CAPTURED IN C I12 RESPONSE FOR TVA MEMO CONCERWs NRC IE INF NOTICE 85-199, ROSMOUNT DIFF PRESS TRANS ZERO PT SHIFT, IS NOT COMP 113 SON-DC-V-32.9 REF IEEE 323-1971 INSTEAD OF 323-1974 & DOES NOT ADDR SYS SETPOINT REDMNTS (NRC-32, obs. 6.5, 6.6 I15 C/R DEFINING THE ABILITY OF FLOW INSTRUMENTS TO INDICATE SYS FAILURES IS NOT DOCUMENTED IN C/R DB 116 C/R INVOLVING PROCESS CONT SYS, CHAN ACCURACY & SETPOINT TOLERANCE IS NOT DOCUMENTED IN C/R DB 117 TVA LETTER ON METEORLOGICAL MONITORING SYS FEATURES & ADD EMER RESPONSE ORG STAFFING I18 C/Rs INVOLVING IEC CHANNEL LIST HAVE MISSING ATTACHMENTS AND MAY NOT BE IN C/R DB 119 WESTINGHOUSE LETTER TVA-898 DID NOT IDENTIFY ALL APPLICABLE REACTOR CONT & PROT SYS FUNCTI I29 C/R REQUIRING REPLACENENT OF 29-293 SEC RANCE RELAY WITH 3 SEC RANGE RELAY IS NOT IDENTIFIED IN I21 ECN L6359 DRC DOES NOT PROVIDE ADEDUATE ASSURANCE THAT SEISMIC OUALIFICATION OF LEVEL SWITCHES 122 ECM L6359 DRC CONTAINS CONFLICTING & INCOMP ASSESSMENTS OF SETPOINT ACC & SETPOINT MARG 125 ECM L5884 DRC ITEM 6a IS MARKED AS *ADDR* BUT DOES NOT PROVIDE ASSURANCE THAT COMPONENTS 126 ECN L5884 DRC CONTAINS TWO ITEMS WHICH ARE *NOT ADDR* BUT CAO WAS NOT ISSUED TO RESOLVE OR TR 127 ECN L6494 RECOGNIZES LACK OF SEISMIC 00AL FOR REPLMNT SW ON FCV-63-72 BUT DOES NOT REF *l8TO g CA 128 ECN L6254 DRC DOES NOT REFERENCE REOUIRED SETPOINT CALCULATIONS.

129 ECM L6254 DRC DOES NOT CONTAIN ADEOUATE ASSESSMENT OF TECHNICAL REQUIREMENT OF SON-DC-V-13.9.8 TE I36 ECM L6254 DOES NOT CONTAIN ADEOUATE ASSESSMENTS OF SETPOINT ACCURACY & MARGINS FOR PRESSURE w "' o' I31 ECM L5699 COVER SHEET IND WO INVOLVEMENT BY CIVIL DISC BUT USOD IND THAT FIELD MOD WAS REVIEWED o I32 ECN L6175 PRESSURE SWITCH RECALIBRATION TEST RESULTS LACK REFERENCE TO METHODOLOGY os b . 133 ECM L6124 DRC DOES NOT CONTAIR ADE0UATE ASSESSMENT OF TIME DELAY SETPOINTS FOR SWITCHES DESCRIBED IN E

PRERESTART ACTION ITEMS (CONTINUED) ACTION ITEM NO. DESCRIPTION 134 ECW L6124 TIME DELAY SETPOINT CALCULATIONS NOT REFERENCED IN ECN PACKAGE I35 ECN L6124 DATA SHEET DID NOT REFLECT ALL NECESSARY DRAWING CHANGES FOR MODIFICATION I36 ECN L5275 DEC DOES NOT PROVIDE JUSTIFIED CONCLUSION THAT BIT RECIRC ROTOMETER IS NOT REQUIRED FOR RESTART I39 ECE L5734 DEC EVALUATION PROVIDES IECORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS lea & ISb I48 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 6a & 6b I41 ECM L5734 DRC EVALUATION PROVIDES INCO2 RECT & UNJUSTIFIED CONCLUSION FOR ITEM 7a I42 ECN L5734 DEC DID NOT REFERENCE THE PRIMARY SYSTEM DESIGN CRITERIA AS JUSTIFICATION FOR ITEM 1 CONCLUSION I43 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 19e & 19d 144 WP 11916 LISTS TEMP SWITCH 'REO VALUES

• WITH +/-5 DEG F TOL W/0 REF TO DSGN BASIS FOR JUSTIFICATION (NRC 35,obs. 6.19)

I46 FAILURE TO PERIODICALLY TEST TINE DELAY RELAYS PER IEEE 338-1977 REQUIREMENTS (NRC 47, obs. 6.15) 148 I49 SYSTER 81 USES AN UNNUMBERED SKETCH FOR ER/SD & ADDRESSES CONTROL VALVE LIMIT SWITCHES NOT SHOWN ON SUBID OR ER/SD DISCREPANCY BETWEEN COMMITTMENT FOR LOGIC DIAGRAM CHANGE PER ECN L5765 & CORRESPONDING PL ITEM 150 151 ECM L5831 WAS LISTED AS POST RESTART BASED ON ADEO OF EXISTING EQUIP BUT EXISTING EQUIP IS NOT ADED FOR SAFETY FUNCTION NCRs/SCRs AFFECTING PRIMARY WATER SYSTEM HAVE NOT BEEN IDENTIFIED OR EVALUATED PER SOEP-16 152 153 JUSTIF FOR NCRSONSWP8292R1 ADDR THE TECH ACCEPT OF RELIEF PATH-ISOLATION VALVE BUT DOES NOT ADDR RAD NON RE-99-118 154 WDP-81 DOES NOT INCLUDE NAMEPLATE DATA FOR MECHANICAL COMPONENTS AS REQUIRED BY WALEDOWN SCOPE M01 UNCOORDINATED CHANGES TO PUNCHLIST CREATED CONFLICT BETWEEN PL C/A & RESTART STATUS AND STATEMENTS IN SYSTER 81 M92 AS-BUILT DRAWING DISCREPANCIES NOT TRANSFERRED TO MASTER WALKDOWN COPY &

SUMMARY

SHEET NOT PROVIDED M93 OC SIGNOFF AND VERIFICATION WAS ACCOMPLISHED ONLY BY HIGHLITE & RED LINES & PROCEDURES DID NOT INDICATE A OA DOCUMENT M94 WDP-15 INDIVIDUAL 8 1/2 X 11 SHEETS NOT DESIGNATED UNIT 2 AS APPOSED TO UNIT 1 DUE TO PROCEDURAL DEFICIENCY DBVP HAS NOT DOCUMENTED RATIONALE FOR THE INCLUSION OF ALL' PROGRAM SCOPED ITEMS M95 M86 WDP-72

SUMMARY

SHEET ATTACHMENT DOES NOT REFERENCE

SUMMARY

SHEET & WDP MASTER DWG NOTE CONFLICTS WITH

SUMMARY

SHEET M98 PROCEDURES DO NOT ADDRESS ECM REVIEW FOR TECHNICAL ADE00ACY OF DRAWINGS & CALCULATIONS WHICH VIOLATES SOEP-12 M99 RHR WDP DISCREPANCY CONCERNING RCS EQUIP MOT REPORTED TO WDP-72 PERSONNEL FOR PROPER INTERFACE ON MASTER DWG (NRC-22) M18 SCR NEB 8529 WAS INCORRECTLY CLASSIFIED AS *0 PEN

• INSTEAD OF "0RP* IN ACCORDANCE WITH SOEP-11 SOEP-16 DOES NOT ADDRESS SYSTEM INTERFACE & REVIEW RESPONSIBILITIES (obs. 1.3)

M12 M14 AFW & AUX AIR C/R FOR LOSS OF AC POWER NOT ADDRESSED ADEOUATELY IN DESIGN CRITERIA FOR CRITICAL TIME REQUIREMENTS M16 C/R DATA SHEETS ARE INCOMPLETE & IMPROPERLY FILLED OUT CAUSING INCOMPLETE CAPTURE OF DSGN REOMETS IN DSGN CRIT ( M18 DSGN CRIT DOES NOT STATE REG GUIDE 1.29 EXCEPTIONS, SOEP-11 LICENSING COMMITMENTS NOT CAPTURED, & HPFP C/R NOT CAPTURED M19 DESIGN CRITERIA DID NOT REFERENCE NPSH VALVES FOR THERMAL BARRIER BOOSTER PUMPS M29 DRC FOR ECN 2945 DOES NOT ADDRESS ITEMS FOR WDP & HYDRAULIC, STRUCTURAL, AND MECHANICAL DESIGN CRITERIA M21 ECM 2945 DRC HAS MISSING DOCUMENTATION & PIRs HAVE NOT BEEN ISSUED FOR TRACKING PURPOSES WHICH VIOLATES SOEP-12 M23 ECW L6665 DRC HAS TWO SEPARATE AND POSSIBLY CONFLICTING VERSIONS M24 ECH L6665 DRC DOES NOT PROVIDE REFERENCE FOR ITEM 3.6 & 6.a AND VENDOR INFORMATION NOT RETRIEVABLE M25 SON-DC-V-7.4 CONTAINS THREE APPENDIXES LISTING DOCS THAT CONTAIN COMMITMENTS & REOMNTS NOT INC INTO TEX M26 ECN L5995 DRC JUSTIFICATION AND ASSOCIATE REFERENCES NOT CAPTURED FOR SYSTEM DESIGN TEMPERATURE AND PRESSURE M27 SON-DC-V-13.9.9 MAY NOT LIST ALL APPLICABLE INDUSTRY CODES AND STANDARDS M28 ECN L5995 DRC DOES NOT REF PIR WRITTEN FOR JUSTIFICATION OF CHANGE TO PIPING RIGOROUS ANH.YSIS WHICH VIOL M31 C/R FOR SIS COLD LEC PARAMETERS FOR DESIGN OF COLD LEG ACCUMULATORS WAS NOT CAPTURED (obs 5.4) M33 SOURCE DOCUMENTS NOT INCORPORATED ON C/R DATA SHEETS & IN DESIGN CRITERIA FOR SIS & RHR SYSTEMS (obs. S.4) N34 DRAFT CONTAINMENT SPRAY SYSTER DOES NOT EVALUATE C/A FOR OPEN SCE/NCRs OR JUSTIFY EVALUATION OF SYNER M35 INCORRECT USE OF USOD FOR ECN L5995 TO JUSTIFY SEIS OUAL OF REPLACEMENT OF BLIND FLANGE WITH SECOND VALVE, NIPPLE, & CAP M37 ECN 5415 SOEP-11 ATTACHMENT 1 NOT PROPERLY SIGNED BY SYSTEM ENGINEER M38 SOEP-11 ECN ID FORM DOES NOT ASSIGN ECN L5681 TO SYS 67 POR EVAL OF THE EFFECT OF ACA AIR COMPRESSOR M39 USOD FOR ECN L5681 DOES NOT DOCUMENT VENDOR RECOMMENDATIONS & SEISMIC ANALYSIS WAS NOT PERFORMED OR ECN L5681 DRC DOES NOT APPROPRIATELY ADDRESS SEISMIC ANALYSIS, OPERABILITY & HYDRAULIC DESIGN M48 ** M41 ECN 5451 DID NOT REQUIRE THE SEISMIC REVIEW OF THE CONDUIT INSTALLATION FOR THE ENERG DG AC & SDC $ LUBE O

                                                                                                                                     '4 M42       ECN L6103 CIVIL CHECKLIST DOES NOT ADDRESS TUBE OUALIFICATION FOR PORV ISOLATION VALVES                                  *E M43       ECB L6581 CHECKLIST DOES NOT ADDRESS ECM JUSTIFICATION FOR REFERENCED CALCULATIONS                                      I cm ASME XI SEC 9.1 REQUIRING PERIODIC TESTING OF PRESS RETAINING CMPNT IS NOT CAPTURED IN SON-DC-V-13.99 (NRC 46, obs.6.12) Eh OO

PRERESTART ACTION ITEMS (CONTINUED) ACTION ITEM NO. DESCRIPTION M44 ECNs 5714 & 6193 NOT REVIEWED BY ENGINEER TRAINED TO SOEP-Il M49 PUNCHLIST ITEMS ARE BEING CLOSED BEFORE DA COMPLETES REVIEW OF FIELD WORK Nel JUSTIFICATION INADEO IN CALCS FOR ABSENCE OF FSAR CHAPT 15 DBAs & EVAL FOR OFFSITE RADIATION NOT DOCUMENTED (obs. Ne2 SAFETY FUNCTION IDENTIFICATION NOT SYSTENATICALLY IDENTIFIED IN CALCULATION PACKAGE SON-OSG7-048 N83 CONTAINMENT PENETRATIONS AND ASSOCIATED ISOLATION VALVES OMITTED FROM BOUNDARY DRAWINGS IN CALCULATION FK Na4 LACK OF JUSTIFICATION FOR BOUNDARY SELECTION IN CALCULATION PACKAGE SON-OSG7-048 N85 SYSTEM BOUNDARY DWG IN CALC PEG SON-OSG7-648 HAS INCONSISTANT BOUNDARY NARKINGS AND REO VS NOT RED AREA DES N96 MISCELLANEOUS ERRORS, OMISSIONS, AND INCONSISTENCIES IN CALCULATION PACKAGE SON-OSG7-948 NN7 LACK OF TVA PROCEDURE FOR LICENSING COMNITMENTS REVIEW ACTIVITY 888 NRC OUESTIONS WHETHER TECHNICAL SPECIFICATIONS ARE BEINC CONSIDERED FOR INPUT TO LICENSING COMMITMENT LIST (NRC N#9 JUSTIFICATION NOT PROVIDED FOR INCLUSION / EXCLUSION OF ALL SYSTEMS FOR CHAPTER 15 ACCIDENTS IN CALCS (NRC-8,obs. 4.1) Nie DUALIFICATION OF THE EXCORE NUCLEAR INSTRUNENTATION FOR ROD EJECTION ACCIDENT IS IN OUESTION (NRC-19, obs 6.2) N11 SCOPE DEFINITIONS FROM RPS AND NMS NOT CONSISTENT WITH OTHER SYSTEM BOUNDARIES (NRC-28, obs. 4.2) N12 TMI CONNITNENTS NOT PROPERLY SCOPED FOR SYSTEM BOUNDARY DETERMINATIONS AND DESIGN BASELINE VERIFICATION PROGRAM ( N13 IMPILL LICENSING REVIEW OF DSCN CRIT DEVELOPMENT WAS NOT INDEPENDENTLY VERIFIED FOR CAPTURE OF ALL C/Rs (NRC-17,obs.5.4) N14 POTENTIAL INTERACTIONS NOT CONSIDERED IN ROUTING OF ECNs PER SOEP-11 NIS SCR/NCR PWP8388 CORRECTIVE ACTION WAS FOUND INADED & A NEW CAO WAS NOT ISSUED TO READDRESS FINDINGS BY SDE PER SOEP-11 516 SON-OSG2-##1 DID NOT CONSIDER FCNs APPROVED BY OTHERS & THOSE THAT WERE NOT APPROVID REGARDLESS OF IMPLEMENTA N17 FAILURE TO INCORPORATE C/Es INTG DESIGN CRITERIA TEXT AND TO SPECIFY ALL INTERFACE REQUIREMENTS PER SOEP-29 N18 FAILURE TO REVIEW ALL INTERNAL DOCUMENTS FOR C/R IDENTIFICATION PER SOEP-18 N21 INADEDUATE AND INCONSISTANT EO REQUIREMENTS IN SON-DC-V-26.1 FOR EXISTING IMPLACE EQUIPMENT (NRC-29, obs. 4.5) N22 C/R RED THAT ENLARGED SPRAY SHIELDS BE INST OVER IGNITER ASSEMB IN HMS WAS OMITTED FROM SON-DC-V-26.1 (NRC-38, obs. 4.4) N25 IMPROPER ASSIGNMENT OF POTENTIAL C/R SOURCE DOCUMENTS BY IMPELL TO NUC POWER INSTEAD OF NEB N38 INCONSISTENCIES EXIST BETWEEN TABLE 1 *SYS WHICH SUPPORT SAFE Sir" 0F CALC PKG SON-OSG7-848 R2 & OTHER PARTS OF CALC PKG N31 PREVIOUS WALKDOWN EVALUATIONS MUST BE VERIFIED TO MEET REVISED ENLARGED SYSTEM BOUNDARIES IN CALC PKG SON-OSG7-648R2 N32 FAILURE TO ADDRESS FUEL GEOMETRY REQUIREMENTS IN CALC. SON-OSG7-648 N33 ECN DRCs CONTAINED *NOT ADDRESSED

• RESPONSES BUT PIR NUMBER WAS NOT PROVIDED WHICH VIOLATES SOEP-12 N34 ELECTRICAL CHECKLIST DOES NOT PROVIDE ADEOUATE REPLACEMENT COMPONENT INFORMATION FOR ELECTRICAL EQUIPMENT CHANGEOUTS N35 ECN 2787 COVER SHEET DID NOT INDICATE SEISMIC ANALYSIS OR ELEC INVOLVEMENT & CHECKLIST DID NOT MEET SOEP-12 REOMNTS N36 INADEOUATE DOCUMENTATION BY SE PREPARER & REVIEWER ON FCN FORM AND TRAINING OF PERSONNEL NEEDS VERIFICATION N38 ECN 5779 DRC CONTAINED POTENTIAL INADEDUACIES, WITH THE EVALUATION & REVIEW OF UHI DWGS TO DEPICT THE SYSTEM BOUNDARIES N39 IMPROPER INCORPORATION OF SUPERCEDED COMMITMENTS IN SON-DC-V-27.2 N48 INADEOUATE ECN 5688 PACKAGE & SOEP-12 CHECKLIST FOR MOVING SUMP LEVEL SENSOR BELLOWS FROM INSIDE TO OUTSIDE CRTMNT WALL N41 FAILURE TO REVISE FSAR DWG UPON FCN IMPLEMENTATION N43 FAILURE TO INCORPORATE C/R FOR DIVERSE HI PRESSURE INTERLOCKS IN SON-DC-V-27.6.

N44 UNIMPLEMENTED STATUS OF ECN L5323 FOR CHARCOAL CANISTER REPLACEMENT NOT ADEOUATELY ADDRESSED IN SOEP-12 CHECKLIST N45 LOCATION OF DESIGN PRESSURE & TEMP BREAKS INCORRECTLY MARKED ON FLOW DIAGRAM (NRC 54, obs. 2.7) N46 LACK OF JUSTIFICATION IN PRESSURE DROP CALC. EPH-SMJ-822886 USED TO SUPPORT ECN L6673 (NRC 56, obs. 2.6) N48 IMPROPER DELETION OF SAFETY-RELATED FUNCTION BY ECN L6876 (NRC 58). N49 SOEP-16 HAS NO PROVISIONS FOR ALLOWING CHANGES AND MODIFICATIONS TO ISSUED SYSTERs N58

• EXCEPTIONS
• ARE NOT BEING PROPERLY OR CONSISTANTLY INCORPORATED INTO SYSTERs 551 IMPROPER REVIEW OF CUMULATIVE EFFECTS OF UNIMPLEMENTED CHANGES IN SYSTERs N52 NO ROLE IN SOEP-45 R1 FOR SE TO APPROVE RESOLUTION & STATUS OF PUNCHLIST ITEMS AGAINST HIS/HER SYSTER N53 RESTART INDICATIONS ARE INCORRECT FOR PUNCHLIST ITEMS FOR SYSTER 82 & SYSTER DID NOT ADDRESS RELATED PUNCHLIST ITEMS N54 VARIOUS & NUMEROUS DEFICIENCIES IN SYSTER 83 FOR THE COMBUSTIBLE GAS CONTROL SYSTEM NSS SYSTER 61 FOR ICE COND SYS INADE0UATELY ADDRESSES NUMEROUS FCRs/ECNs/SCRs & IS INCONSISTENT WITH PUNCHLIST 7d aE N56 OPEN FCRs ARE BEING EXCLUDED FROM SYSTERs PER DBVP-D-86-905 *5 M57 PUNCHLIST CHANGES NOT COORDINATED WITH APPLICABLE SE AND ITEMS NOT PROCESSED FOR COMPLETENESS / TIMELINESS o' Del MECHANICAL COMPONENT DATA SHEET NOT INCLUDED IN WDP-78 TO RECORD VALVE NAMEPLATE DATA NEEDED DURING SYSTEM EVALUATION 082 INCONSISTENCY IN FILLING OUT MECH COMP DATA SHEET FOR WDP-78 FOR THE PRESENCE OF A YELLOW CAUTION TAG ON MOV BREAKERS ((

PRECESTART ACTION ETEMS (CONTINUED) ACTION ITEN 50. DESCRIPTION-003 WDP-7N CONTAINNENT PENETRATION DATA SHEETS DO NOT CONTAIN INITIALS & DATES FOR EACH PENETRATION-004 'INFORNATION ONLY' AND WALEDOWN DRAWINGS IN WDD-38 WERE NOT SIGND BY TNE PREPARER AND/OR CHECEER 005 AFW PRESSURE TRANSNITTERS LABELS ARE REVERSED & DOC OF TRANSNITTER/ LOOP ALIGNNENT & FUNCTION IS NOT PROVIDED (obs 1.1) 006 WDP DID NOT IDENTIFY AS-BUILT DWG DISCREP FOR PIPE SIZE & TEAN DID MOT DOC ALL DIFFERENCES OBSERVD (NBC-2,obs. 1.4,6.4)  ; Os7 WDPs CONTAIN INCONSISTENT PNL LOCATIONS, INCORRECT SKETCHES & NO RECORD FOR STEAM LEAKOFF LINES (NRC-3,obs. 2.1,3.1,6.3). 000 CONCERNS AS TO EXTENT, USE, AND REASON FOR AS-DESIGNED DRAWINGS IN WDPs (NBC-4) 009 DIFFERENCES BETWEEN SYSTER AND WALEDOWN BOUNDARIES WERE NOT DOCUMENTED & JUSTIFIED (NRC-7,obs.1.2) - 010 CRITERIA FOR SELECTING EA TEAN WALEDOWNS WAS NOT DOCUMENTED IN OPERATIONS DISCIPLINE REVIEW PLAN (NRC-9,obs. 4.3) 011 ASSESSNENT OF THE ADEQUACY OF SCOPE & DIRECTION FOR DB&V PROGRAN IS HAMPERED BY DELAY IN ISSUING SOEPs (NRC-11) 012 , EA TEAN USED.*AS-DESIGNED

• DRAWINGS INSTEAD OF 'AS-CONSTRUCTED
• DRAWINGS FOR INDEPENDENT WALEDOWN (NBC-5) 013 OPERATIONS INPUT TO DB&V PROGRAN SCOPE NAY NOT FULLY CAPTURE THE REQUIRENENTS OF E01s AND S0la (obs. 4.1) '

014 WASTE DISPOSAL SYS CONTAINNENT BOUNDAltY PENETRATION X-46 IS NOT SHOWN ON DRAWING FOR WDP-77 (NRC-16, obs. 7.1) 015 DIFFERENCES EXIST BETWEEN THE U1 & U2 WD BOUNDARIES WITH JUSTIFICATION NOT PROVIDED IN THE WDP (NRC-13, obs. 1.2) 016 NO PROCEDURES TO REQUIRE REVIEW OF WALIDOWN DATA FOR ASSESSMENT OF POTENTIAL INPACT ON OPERATIONS (NRC-14, obs.1.1) 029 NONORAIL CRANES & HOISTS SHOULD NOT BE PARKED OVER SAFETY EQUIPMENT,e.g., MONORAIL HOIST PAREED OVER 23-B PUNP CDUPLING 021 GUIDELINES NOT EST FOR CONSISTANCY IN THE COLLECTION OF NP DATA FOR EOUIP MOD OR REPLD SINCE OL (NBC-34, obs.1.4 & 2.2) - 022 023 PROJECT NEEDS TO VERIFY THAT SINGLE LINE CRADs ARE BEING RFVIEWED BY A STA FOR DRAWING DEVIATIONS PER SNI-6-317-36 POST-MAINTENANCE TESTING OF FLOW CONTROL VALVES PER SI-166 & TI-69 IS NOT BEING PERFORNED 061 SYSTEN WALIDOWN PACKAGE N0. 50-DR-86-06-135R 50' PERFORNED AND DOCUMENTED PER SNI-0-317-838 De2 DEFIC 67-138 IN WDP-67 FOR ERCW IDENTIFIES DIAP;iRAGM VALVE AS GATE VALVE (DISCREPANCY REPORT NO. S0-DR-86-07-146R) 083 084 SOA-183 DESCRIBES A CCB DECISION CLASSIFICATION FOR MOD AS ' CANCELLED

• BUT DOES NOT RECOGNIZE A DNE APPEAL PROCESS 005 WR/NR NOT REFERENCED IN WDP FOR NISSING/ INCORRECT ID TAGS mR AFW & ERCW SYSTEMS (DISCREPANCY REPORT NO. S0-DR-86-154R)

LACK OF ASSURANCE TNAT ALL C/Rs, INCLUDING NSSS/ VENDOR RECUIREXENTS, ARE CAPTURED IN THE C/R DATA BASE (NRC 38) Os6 008 SONE MAINTENANCE PROCEDURES ARE NOT SUBJECTED TO PORC REVIEW & SONE ARE NOT REVIEWED & UPDATED AS REQUIRED (NRC 39) ' Ole CHANGE CONTROL BOARD IS NOT DOCUMENTING MODIFICATION CANELLATIONS OR DEFERRALS OF DCRs AS REQUIRED BY SOA183 DRAFT SON U2 DBVP PN I REPORT DOES NOT ADDR C/As RED TO MEET DBVP OBJECTIVES & DOES NOT ADDR ALL ECBs, FCRs & NCRs/SCRs

                                                                                                                                                  %?
                                                                                                                                                  .O .

ot

INVALID FINDINGS

  ' ACTION          -

ITFM NO. DESCRIPTION

                                                                                          ~

C31 VENDOR CALCULATIONS FOR ECM L5451 SEISNIC RESPONSE CURVES DO NOT ENVELOPE TVAs RESPONSE SPECTRA E83' CRAD USED FOR WD COULD NOT BE REFERENCED TO A SWBID IN SYS BOUNDARY CALC PEG E19 C/R ANAL REPORTS WERE NOT DISTRIBUTED TO SE's FOR USE IN DSGN DOCUMENT DEVELOPMENT WHICH VIOLA E44 SOEP-18R1 REONNT THAT C/R DATA SHEETS BE PREPARED FOR LICENSING CONNITNENTS WAS VIOLATED 185 CHANGE MADE TO WDP-46 WITHOUT USING 04 RECORD CHANGE TORM TO DOCUMENT CHANGE WHICH VIOLATES AI H35 ECM 5415 SOEP-11 ATTACHNENT 1 NOT PROPERLY SIGNED BY SYSTEN ENGINEER . M48 ECN 5451 DID NOT REQUIRE THE SEISNIC REVIEW OF THE CONDUIT INSTALLATION FOR THE ENERG DG AC & D e

                                                                                                                                              %e" o.

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TABLE 8.4-6 ACTION ITEMS REQUIRING CORRECTIVE and/or PREVENTIVE ACTION (PRESENTEDTransitional BY ACTIVITY *) Design Criteria System Design Change System Change Electrical Evaluation Report Control Test Evaluation Preparation Biundary Walkdown Documents C05 E71 N18 C54 N49 Q09 E08 C01 001 CO2 E10 I23 M42 E33 CSS N50 Q11 N01 C04 002 C03 EIS I24 M44 E34 C06 E74 N20 C07 109 N21 C56 NSI T01 NO2 E01 003 C08 E18 I25 M51 E36 C57 N52 E02 004 C09 E27 I26 N14 E37 CIO' Il0 N22 NO3 E77 N53 E04 005 C13 E32 I27 N15 E38 C11 Ill N23 N04 E80 N54 N05 101 006 C19 E41 I28 N16 E56 C12 I12 N24 E57 C14 I13 N25 E81 N55 DB&VP Phase I N06 102 007 C21 E42 I29 N33 Preliminary Report C23 E45 I30 N34 E60 CIS I14 N26 E82 N56 N09 103 009 E83 N57 N11 107 010 C25 E46 I31 N35 E67 C16 IIS N27 C17 I17 N28 E84 024 N58 N30 IO8 015 C30 E47 I33 N36 E78 Q10 I45 019 C32 E48 I34 N37 E79 C18 I18 N29 E85 Q07 N32 M01 020 C33 E49 135 N38 I46 C20 I19 N43 E86 Q13 C24 I20 017 E87 M02 022 C34 ESO I36 N40 E88 M03 Q01 C35 E51 I37 Nel C26 M07 Q18 C27 Mll QOS E89 M04 QO2 C36 ES2 138 N42 C28 M12 Q12 E90 MOS Q04 C37 E53 139 N44 C46 M13 E91 M08 Q06 C38 E54 I40 N45 C39 ESS I41 N46 E11 M14 - I48 C40 E58 I42 N47 E12 MIS I49 C41 E59 I43 011 E13 M16 150 C42 E61 I44 QO3 E14 M17 ISI C43 E62 I47 Q08 E16 M18 I52 C44 E63 M06 E20 M22 I53 C45 E64 M09 E21 M24 154 C47 E65 M19 E22 M28 ISS C48 E66 M21 E23 M29 156 C49 E68 M23 E24 M30 157 C50 E69 M25 E25 M31 I58 CSI E72 M27 E26 M43 159 CS2 E73 M32 E28 M45 I60 C53 E75 M34 E29 M46 M10 EOS E76 M36 E30 N07 M33 8Y E06 104 M37 E31 N08 M47 5$* e E07 I21 M38 E39 N10 M48 " E40 N13 M50 o-E09 122 M39 M41 E43 N17 M52 ((

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_ U. PROCl5514G Of RtCORDS Dtf!C Lal 'B. V. RF OUIRf D RECORDS 401 MAltf A NED ~ C. RE - TE s t _ LQQ fil$fFi t Ahf OU$JL{j(if hf f f 5 ~ D 4EW IE51 W. C0451kull10h klLAl[D E. 404E RE00lRED _ X. OP61t Allots A40 MA141[ HANCE Rf L Al[D Z F...OrNEa fivlSE CHAh61 DOCuntti tvAtuAllO4 FORM Y. SY5itM BoutDARY SCOPE thAD(00Ali./14COMPLLIC _ G. PRtPAR[D BY: ,.y q I REVl[WLD BY:

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C-C'1 e W O

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e-= -4

TOTAL ACTION ITEMS FOR EACH ACTIVITY PHASE 1 OF THE EA OVERSIGHT REVIEW l l CHANGE DOC (QTY 188)

                                                       /        38.6%
                                              '                                  ~

DSGN CRIT PREP (QTY 94) - f. % 26.3 % /

                                                ; Q' ,i ,,         ~

N \'< Nx e \ SYS BOUNDARY (QTY 13) e' 'N'g ' 3.6%

                                                   ..sqx +, xs ELEC TEST EVAL (QTY 14)

SYSTEM EVAL RPT (QTY 52) f 14.6 % s WALKDOWN (QTY 43) 12.0 % 5 e N

                                                                                                                                                       ?

i'

FINDING TYPE CATEGORIES ALL ACTION ITEMS 240 - 227 220 - 'Es,, ..?,'f n,

                                  , rw.
                                     ~,.

200 - i:M:i: 7ijinii: NOTE: FINDING CATECORIES ARE DEFINED IN APPENDIX C 180- M.. wp., , .G9'@il: to 3 ^;;j$wss:N

                                  ' d!!fkk::

us 160 - #8.2!!@!8

       >-                       s             ..:

3,yx$$ 5%

                               *8p^!   n.p; jim.::!.

140 - .w; :"^' ' 5: O $$b@:i@i!Es Os:1 sp, 4 120 - i g $Ef'R'h

WJMi::;4 v 7'$35' a- 100 - EM$'$$N  :$ii ~

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                               ':$0
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3 80- .'s s.

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3 5%%!&;6i8.s; 2 .a: . 60-  !. 'gjo:'@

                                      . : M.:.:

52 85! pi Ss. 42 > :' 3!.: i:M:~ wx .;;$i.i8,n p: 40- .i

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                                 +
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                                                                 ' n, s.. .

1,, ( -- 8:9 <:: 5 25 20 - $ ' .M../. n.;,  !.- i.f::!." .;...;....... S.9c hWXS. . 9. .p

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uSp " ?jj $' :::':;;

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                                                                                                                                                                               ~1 ,

1.00 4.00 2.00 5.00 9.00 3.00 7.00 6.00 8.00 FINDING CATEGORIES m M O m Co

                                                                                                                                                                                             #~

0 -

FINDING TYPE SUBCATEGORIES ALL ACTION ITEMS 70 - 60 - se NOTE: FINDING SUBCATECORIES ARE DEFINED IN APPENDIX C 50 - e 2 .

 ! a-           1 xi 30-25 25 y

2 ** ' d 20 - to 12 12 10 - h :f l:)flibgji illb 0 1 e;;;;;e+;e 6 eeeeeee;;et 6$6 d@. eoeee.+oeee$ aissea$ v FINDING SUBCATEGORIES h

                                                                                         .=

l W

AFFECTED DOCUMENT TYPES AWING (QTY 10) ' VENDOR DOC (NON-N888) (QTY 1) O.3% 4 TECH PROC (QTY 19) - 5.3% M PROC (QTY 5) , 3% 7 g' j;/ . j_ CRIT (QTY 92)

                                                                               /            #

l KDOWN PKG PROC (QTY 33) ~ p pk I CALC 6.9% (QTY 21) N'

                                                                            /j'
                                                                                              ,l

• l SAR (QTY 1) j / 0.3%

TEST 2.8% PROC (QTY 10) - \ NONE (QTY 1) 0.3% USQD (QTY 6)

                                                                                                                %                                      1.7%

e \ ECN (QTY 96) /. k k SYSTER (QTY 47) 28.9% FCR (QTY 2) , 0.6% l l SCR/NCR (QTY 9) l I 2.5%

                                                                                                          . FCN (QTY 3)                                              ?

0.8% 0

DISCIPLINE RESPONSIBILITY FOR CORRECTIVE ACTION ELECTRICAL (QTY 64) ( 19.0 % i & C (QTY 42) 12.0 % NUCLEAR (QTY 43)

                                                                           ,,'   13.0 %
                         '.. ((>, ,                                          h MECHANICAL (QTY 33)                    ' ' -

10.0 % . j ,,f , , ,

                                            ~ ,,
                                                  "      ,y,,,
                                                      '. , ,,,f' i;l' ./. '
                                           '\'N m.
                                          'h                                   MULTI-DISC (QTY 80)

CIVIL (OTY 48) _ / ', 23.0 % 14.0 % . OPER & MAINT (QTY 28) / 4 QUALITY ASSURANCE (QTY 4) 8.0% 1.0 % 5 8

                                                                                                   ?l c~

CORRECTIVE ACTIONS REV 21.1 % CHG DOC EVAL FORM (QTY 71) \ REV/ PREP CALC (QTY 19) 5.6 % NEW TEST (QTY 3) 0.9 % . REV/PERF ANAL (QTY 6) E DSGN CRIT DOC (QTY 65) 1.8%

                                           M NEW 0.3% MOD COMP (QTY 1) No -                                                  REV SAR (QTY 1) 3;t4;.4 p v    .                       7 ' O.3%

REV/ PREP TECH JUST FICATION (QTY 14) / 4.2% ' s L f/

                                                                        /'      \\ OTHER (QTY 7)
                                                  /                . s              2.1%
                                                               '~~

REWORK MOD (QTY 1) 0.3% / [ ' REV SYSTER RPT (QTY 27) 8.0% REV/ PREP PROC (OTY 14) f 4.2% REV WALKDOWN PKG (QTY 12) l 3.6% RE-TEST (QTY 2) 0.6% REVIISS DWG (QTY 12) 3.6% NONE REQUIRED (QTY 38) 11.3% ADM ACTION (QTY 43) 12.8 % y E

                                                                                                               !s m
                                                             - - _                                             ?

PREVENTIVE ACTIONS RVISION. APPt ETC,(QTY 97) f fa,

                                  //
                                    //f-/

24)

   "s.VQ33 o     PROC.. INS'TRUC (QTY 94)      a. ,

e q, 1 / . .y

                                             -  x \y y,07g REQUIRED (QTY 121) i                                                                                                S ai
                                                                                                  .=
                                                                                                  ~

CAUSE ASSESSMENT FOR ACTION ITEM FINDINGS Doc or eval INADeor NCour toTV so) 4-INADEQ 1.es DSeel OUTPUT DETAIL (OTY 8) 7 10 OF DES INP/ DES BAS INADEQ/INCOMP (OTY 39) _ x e ** 4 11.8% b f%

                                                        "'i'-

1

                                                                       ..                                              4

_ OT R (OTY 14) y , i FAIL TO COMP WITH PROC (QTY 45) s ' 4 a UNKNOWN (QTY S) i g 4 ,\ ' 1.s% W.. INADEC (OR NO) PROC (OTY 48) / g "88S/YEftOOR ERROR (OTY 2) 14.2 % 8% REV INCOedP/INADEQ (OTY 14) 4.ou l j UNCLEAR OSGN REQUIRERAENTS (OTY 11) 3.9% ! INCoedP DOC CYCLE (QTY 1) e.3% NOT VAUD FIND 4004 (OTY 7) 2.1% INADVERTENT ERROR (OTY 19) 5.7% INCOMP TR AIN (QTY 7) 2.o% L._ INVAUD REVIEW (OTY 2) m o.eu g l

                                                                                                                                                                         !ii m
                                                                                                                                                                         ,2  i k
                           .                                                     _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .                                        a

ASSESSMENT OF EXTENT OF ACTION ITEM FINDINGS ISOLATED / UNIQUE (QTY 117)

                                  , .<,.g
                                                           /              34.8 %
                             .{                                .

l

                         //                 ' .: .

j d! LIMITED (QTY 100) UNKNOWN (QTY 3)

                                                                              ~~ 0.9%

29.7% ,9

                                      .              'g'               ,

f NDOM (QTY 11) e\/ EXTENSIVE DISC (QTY 45) 13.4 % EXTENSIVE GEN (QTY 60) f 1 17.9 % N S l  ?

                                                                                                                                      !=

ASSESSMENT OF SIGNIFICANCE FOR ACTION ITEM FINDINGS  ! MINOR EDITORIAL /ADM PROB (QTY 23) MINOR TECH PROB (QTY 98) 7.1% \ ,r 30.1%

                                                               ./
                                            / " :zi1.ti t IItttiitrti
                                                     +w n +msn z:b.
                                                       . d      .i

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                                                                        ~

UNKNOWN (QTY 6) 1.9%

                                      , , :, V, ;<ffg','g'i;9'Y
                                                                   ~  . \
                                       ' 3[:',ji}yf'          ';V
                                                                          \ NONE (INVALID FINDING)(QTY 7) y' g ; I                   2.2%

w~

                                           /      '

DSGN DOCUMENT CHANGE (QTY 187) 57.8 % HARDWARE CHANGE (QTY 3) 0.9% l e n

                                                                                                            =

NUMBER OF ACTION ITEMS RESULTING IN THE ISSUANCE OF A CAO DOCUMENT (PIR/SCR) 30 - ,, 6!l. q::'.  : 4 33!l

                                                                                              . . g:
                                ~

Mllllll Ull. co 20 - ACTMTY TYKC00E noms l P ' = te r s,s vio a v a r  :::=::- 8** l I'.EE$5E*oSc"E" s k 15- 3. sous em oocouswTs avotvmo

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, g "="a11"#".?!? "' f:!,? % :" e T e ='".!'a n s co m oi.

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ACTIVITY TYPE e T

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s. ACTIVITY TYPE CODES COMPARISON OF SYSTEM 72

                          ~(CONTAINMENT SPRAY SYSTEM)

FINDINGS BY ACTIVITY TO REMAINDER OF ACTION ITEMS 160 - Q Remainder of Findings 12e E system 72 Findings 126 - acnvrry in coot EEESoE e liafe"l#JOis 3 g ,oo _ i N, mm5NS.EO*"o. .c em g .7 8

 <  75-b e

N 50-2 4, S ss 25-13 12 18 0 , ,

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ACTIVITY TYPE CODE @ N T

FINDING TYPE SUBCATEGORIES COMPARISON OF SYSTEM 72 (CONTAINMENT SPRAY SYSTEM) TO REMAINDER-OF FINDINGS 65-60-55 - 2 c3 ruuAinoEn oF FINDelGS M SYSTEhi 72 FINDINGS

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NOTE: FINDING SUBCATECORIES ARE DEFINED IN APPENDIX C 45-a g 40-z iE 35 - . , 8 30-a. E 2

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PREVENTIVE ACTIONS I COMPARISON OF SYSTEM 72 I (CONTAINMENT SPRAY SYSTEM) TO REMAINDER OF PREVENTIVE ACTIONS 125-

                                                                           '   O REMAINDER OF FINDINGS enymuvucnortcoms O. FORMAL TRAMING 100 -  j.j"f"" gTc. Luc                              a SYSTEM 72 FINDINGS

4. cmen 92 _

d) t3 ' Z g 75 - c b e , E 50 - l Z 25- ,, O i 0 1 2 3 4 3 PREVENTIVE ACTION CODES S R

                                                                                                       .=

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CAUSE ASSESSNENT COMPARISON OF SYSTEM 72 (CONTAINMENT SPRAY SYSTEM) TO REMAINDER OF CAUSES 75-70-84 O REMAINDER OF FINDINGS gggg 65-A [o"o*c'5YvIiE*S"JE'ou, 60- j,"^o%, 8,8,",f7g[g"T,%g,,, E SYSTEM 72 FINDINGS

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RNDING TYPE SUBCATEGORES COMPARISON OF CLOSED ACTION ITEMS

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! 60 - 50 - _ [O CLOSED ACTIONITEMS and OPEN ACTIONITEMS NOTE : CO FD4 DING SUBCATEGORIES ARE DEFINED M APPENDIX C 2 j g 40 -  : 5 F o 4: 30 -- a l 8 x W e

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        ~l9        i l        I NOTE: FINDING SUBCATECORIES ARE DEFINED IN APPENDIX C l
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COMPARISON OF RESOLVED AND CLOSED ACTION ITEM FINDINGS CORRECTIVE ACTIONS 70 - O CLOSED ACTION ITEM FINDINGS 60 _ Im enn om E RES0WED ACION ITEM FINDINGS c

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COMPARISON OF RESOLVED AND CLOSED ACTION ITEM FINDINGS PREVENTIVE ACTIONS 110 - 102 f 100 - rnEYEnnecnnota O CLOSED ACTION ITEM FINDINGS 1 !l EpYe dYAS no. E RESOLVED ACTION ITEM FINDINGS l 90 - g ngaegocmornoc c0 4.onen 3 80 - ** i 6 70-A O j < 60-b at 50- , g 40-Z 30-i ) 20 - jy I

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COMPARISON OF RESOLVED AND CLOSED ACTION ITEM FINDINGS CAUSE ASSESSMENT 70-CAMBLCODES

e. ENS EVAL INADEOANCOMP i "

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!                                         CAUSE CODES                                                                                                 5
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COMPARISON OF RESOLVED AND CLOSED ACTION ITEM RNDINGS ASSESSMENT OF EXTENT 110 - l 100 - EXImmT or comarnoMa_ coats

'                                          ss

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O CLOSED ACTION ITEM FINDINGS l 6 p 70 - o E RESOLVED ACTION ITEM FINDINGS i

                      <      60-6 g      50-                                                                                         50 g      40 -                                             =

z l 30-1 20- jy l 10-11

-:-:s:- + +

11 $$ [3 8 l - l ici;5:ti5foi a em l 0 1 6 4 1 4 e :f2 EXTENT CODE 8 h i E m 03 y

AFFECTED DOCUMENT TYPES FOR EVALUATED ACTION ITEM FINDINGS 100 - 90- NOTE: DOCUMENT TYPE CODES ARE GIVEN IN TABLE 8.4-7 80 - 72 , 70-5 60-c g 50-m 40-m .. <

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i j I EVALUATED ACTION ITEM FINDNGS { DISCIPLibE RESPONSIBILITY j 70 - 3 RESPONelALE N CODES i o. wuctaan i i 60 - 1. ELecmcAs. i:3i:i:-3i:ii 2.1&C !' 3. WCHANICAI.

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Wg - EVALUATED ACTION ITEM FINDINGS ! RANKED BY RESPONSIBLE DISCIPUNE i DESIGN PROCESS / METHODS INADEQUATE j 15 - l 14 - tuntonetsameGM.tMLGODEG

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Appendix A Pese I of I MEETilE ATTEleEES Exhibit Meetino 1 EA Oversight Team Entrance Meeting, Sequoyah leuclear Plant (May 14,1906), List of Attendees 2 EA Oversight Team Exit Meeting, Sequoyah leuclect Plant (March }i,1987), List of Attendees

APPE31X A Exhibit i Page I of I EA OVER$1GHT TEMI ENTRANCE MEETING SEQUOYAH NUCLEAR PLANT (MAY I4, 1986) LIST OF ATTENDEES Oroanization Title Name DNQA/SQN Site QA Manager W. E. Andrews NRC-lE Team Leader R. E. Architzel DNE/EA EA Team Leader M. P. Berardi Conpliance Engineer TVA/SQN Compliance R. C. Birchell Civil Technical Supervisor C. K. Buck DNE/EA A. P. Capozzi DNE/EA Consultant for 'A DNE/EA Senior Me..hanital Engineer T. G. Carson NRC Region il inspector

8. i. Dees QA Engineer F. E. Denny DNE/EA DNE/EA Mechanical Engineer R. J. Faubert Electrical Section Supervisor

8. M. Gore DNE/EA DNE/EA Electrical Engineer C. E. Grass DNQA/SQN QA QA Inspector T. L. Howard NRC-lE Section Chief E. V. Int >ro NRC-SQN NRC Resident K. M. Jenison Civil lead Engineer C. M. Jc5nson DNE/SQEP DNE/SQEP Program Manager H. L. Jones EA Engineer J. W. Kelly DNE/EA DNE/00 Consultant A. W. Latti Walkdown Manager S. S. Long TVA/SQEP DNE/SQEP Administrative Assistant R. H. O'Donnell Nuclear Section Supervisor D. G. Renfro DNE/EA EA Engineer A. H. Ritter DNE/EA Civil Technical Supervisor A. 8. Savery DNE/EA DNE/EA Electrical Engineer J. W. Samore DNE/EA Senior Power Engineer S. A. Shuman Performance Assessment Project T. E. Spink DNQA/EA Engineer Senior Mechanical Engineer R. P. Svarney DNE/EA J. C. Thanpson DNQA/SQN QA Consultant M. T. lormey DNE/00 Restart Task Force DNE/EA Mechanical Engineer R. Tucker DNE/EA Acting Section Superd sor J. W. von Weisenstein AssistantProjectEngineer C. Y. Wang DNE/SQEP DNE/EA Manager of EA J. F. Weinhold DNE/SQEP ProjectEngineer D. W. Wilson

APPENDIX A Exhibit 2 Page I of I EA OVER$1GHT TEAM EXIT MEETING SEQUOYAH NUCLEAR PLANT (March 31, 1987) LIST OF ATTENDEES Name Oroanitation Title 1 R. E. Archittel NRC-lE Senior Inspector Specialist D. R. Barnaby DNE/EA Mechanical Engineer M. P. Berardi DNE/EA Advisor P. R. 8 evil DNQA QA Specialist H. C. Bird DNE/EA Civil Engineer C. F. Botanon DNE/WBN Group Head . A. P. Caporti DNE/EA Manager of EA T. G. Carson DNE/EA Operations Engineer J. F. Cox DNE/SQEP AssistantProjectEngineer F. E. Denny DNE/EA Senior Lead Auditor R. J. Faubert DNE/EA Reviewer T. A. Flippo Site QA Quality Surveillance Supervisor R. J. Floyd DNE/EA QA Engineer F. Gilbert BLN PM0 (DNE/EA) Assistant Nuclear Project Manager B. M. Gore DNE/EA Principal Engineer B. L. Hall CNP/ Licensing Engineer T. L. Howard Site QA/SQN QA Manager H. L. Jones ONE/ NEB 08&VP N. C. Karanas DNQA Director of DNQA J. A. Kirkebo DNE/00 Director of Nuc kar Engineering D. L. Kitchel DNE/ NEB DB&VP Unit i Engineering Manager A. W. Latti DNE Consultant D84VP K. F. Liao , DNE/EA Electrical Engineer W.M.Matejek DNE Retest Program Manager E. E. McBee DNE/EA Instrument Engineer A. M. Qualls ONP/SQN Plant Manager D. G. Renfro DNE/ NEB (EA) Lead Nuclear Reviewer A. H. Ritter DNE/EA EA Engineer A. B. Savery DNE/EA Civil Engineer J. W. Semore DNE/EA EA Electrical Engineer S. A. Shuman DNE/EA lead Mechanical Engineer R. P. Svarney DNE/EA Senior Mechanical Engineer M. T. Tormey DNE/DB&VP Advisor R. Tucker DNE/EA Mechanical EA Reviwer D. Vassallo DNE/EA Senior Contrni Systems Engineer J. W. von Weisenstein DNE/EA Team Leader

TYif r Apprndix B vva . its44n Pigs 1 of 1 ITED STATES GOVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY To  : Engineering Assurance Files FROM  : I' 0. Ents, Acting Supervisor of Trend Analysis Section, W12 D103 C-K DATE  : APR 211987

SUBJECT:

PROCEDUhE FOR EVALUATION OF TECHNICAL AUDIT RESULTS The attached procedure has been utilized as the basis for trending the action item findings generated by the SQN Engineering Assurance Independent Oversight Review Team for the Design Baseline and Verification Program. The trending was performed to aid in the identification of adverse trends in the findings and to permit an orderly and systematic presentation of data in the final report of the EA Team. 4 R. (f. Enis ' ROE:JCP . Attachment cc (Attachment): RIMS, SL 26 C-K d,' A. P. Capozzi, W12 B34 C-K DNE1 - 0030E EA - 4/21/87

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M Bur (*.S. Savinus Bonds Revulariv nn 11,< Parrnit enr in.., plan .

APPENDIX C Page 1 of 1 LISTING OF FINDING TYPE CATEGORIES AND SUBCATEGORIES III. FINDIN3 'YPE CODES 1.00 D ES li d REVIEW DFFICIENCIES

0. INADEQUATE FUNCTIONAL DESIGN

1. BASIS FOR DESIGN NOT DOCUMENTED

2. REQUIRED DESIGN FACTOR NOT ANALYZED

3. INCORRECT DESIGN INPUT / ASSUMPTION

4. NO BASIS FOR DESIGN INPUT / ASSUMPTION

5. MISCELLANE0US CALCULATION DEFICIENCIES

6. DESIGN DOCUMENTS CONFLICT

7. MISCELLANE0US DRAWING DEFICIENCIES

8. MISCELLANEOUS DESIGN DOCUMENT DEFIC (EXC DWG& CALC)

9. IMPLEMENTATION OF TECHNICAL GUIDANCE DEFICIENT A. IMPLEMENTATION OF ADMIN GUIDANCE DEFICIENT B. REVIEW / APPROVAL DEFICIENCIES C. CALCULATION INPUT SOURCE NOT IDENTIFIED D. CALCULATION CONCLUSION NOT CONSISTENT WITH RESULTS E. INCOMPLETE PROCUREMENT DOCUMENTS 2.00 DESIGN REVIEW PROCESS / METHODS INADEQUATE F. TECHNICAL GUIDANCE INADEQUATE G. MISSING / INADEQUATE DESIGN REVIEW PROCESS PROCEDURES 3.00 INADEOUATE INTERFACE CONTROL H. NSSS INTERFACE DEflCIENT I. SUPPLIER INTERFACE DEFICIENT J. INTERNAL DISCIPLINE INTERFACE DEFICIENT 4.00 DESIGM_CRIJFRI A DEFICIENCIES K. INCONSISTENCY WITHIN DESIGN CRITERIA L. INADEQUATE / INCOMPLETE REQUIREMENTS IN DESIGN CRITERIA M. MISSING REQUIREMENTS IN DESIGN CRITERIA 5.00 CORRECTIVE /PRFVENTIVE ACTION INADEQUATE

. N. POTENTIALLY GENERIC DESIGN PROBLEM NOT ADDRESSED

0. CORRECTIVE ACTION INADEQUATE 6.00 USOD DEFICIENCIES P. INADEQUATE EVALUATION

0. INCOMPLETE EVALUATION 7.00 TEST REQUIREMENTS / TEST IMPLEMENTATION DEFICIENT R. TEST REQUIREMENTS DEFICIENT S. TEST PROCEDURE (S) DEFICIENT T. TEST RESULTS INADEQUATE 8.00 RECORDS RETENTION INADEOUATE U. PROCESSING OF RECORDS DEFICIENT V. REQUIRED RECORDS NOT MAINTAINED 9.00 MISCEll ANE0US DEFICIENCIES W. CONSTRUCTION RELATED X. OPERATIONS AND MAINTENANCE RELATED Y. SYSTEM B0UNDARY SCOPE INADEQUATE / INCOMPLETE

CIVIL /STNUCTURAL (5100) LISTING OF ALL ACTION ITEMS ACTION ITEM TREND NO. CODES DESCRIPTION C01 108B5B18101 INCOMPLETE TRANSFER OF INFORMATION FROM NASTER WALKDOWN DRAWING TO COPY IN WDPs FOR NS,HPFP, & PAN - CO2 302E7B14401 INAPPROPRIATE SE00ENCE FOR ELININATING AN ECW FRON FURTNER REVIEW BY NARKING NO INSTEAD OF SYS 61 ON ECM ID FORN C03 30F74G25420 CLARIFICATION OF DEGREE OF CALC REVIEWS REQUIRED TO ESTABLISH TECHNICAL ADEQUACY FOR PIPE STRESS / SEISMIC OUALIFICATI C04 10FB5B25021 ATTRIBUTES N & N OF ATTACHNENT 5 0F SOEP-08 NOT INCLUDED IN SMI-0-317-30 C05 50214124201 AUX BUILDING 480V TRANSFORMER ROON TORNADO MISSILE PROTECTION NOT CAPTURED IN C/R TRACKING SYSTEN II)R MISSILES C06 50N17123421 CONNITTNENT IN LETTER A27820301032 TO NRC FOR Alli PIPING DESIGN CRITERIA WAS NOT CAPTURED IN THE C/R DATA BASE C07 50G14B25221 REDUCTION OF NARGINS IN FSAR NEEDS LICENSING ACTION & C/R TRACKING NEEDS TO BE ADDRESSED (NRC-21, obs. 3.2 & 3.3) C08 302G4G18021 ECW 2971 WAS NOT IDENTIFIED ON NCE/SCR IDENTIFICATION FORM BY SDE FOR ANALYSIS BY SYS ENGR C09 302G4G18001 SCR/NCE IDfMTIFICATION FORN INCORRECTLY SHOWS SCRCEB8404 AS CLOSED AND INPLEMENTED C10 50N14130220 REG. GUIDE 1.29 C/R FOR PROTECTION OF CATEGORY I COMPONENTS FRON FAILURE OF CATEGORY II CORPONENTS WAS NOT CAPTURD C11 50214138121 DESIGN CRITERIA ON ELEC RACEWAYS WAS NOT CHECKED ON C/R FORM & ALL APPLICABLE SUBJECTS WERE WOT IDENTIFIED C12 50214E20001 NCRCEB8210 FOR DESIGN OF MISC STEEL ATTACHMENTS WAS NOT CAPTURED IN C/R DATA BASE C13 304C4231021 SUNKARY PIPING ANALYSIS CALC PKG FOR EVAL OF ECE L-5724 CONTAINS UNVERIFIED ASSUNPTION FDR OPERATIONAL VIBRATION LOADS C14 50N14333221 EFFECT OF ADDED WEIGHT OF CABLES IN TRAYS AT EXIT POINTS ON SEISMIC ANALYSIS NOT CONSIDER G IN SON-DC-V-1.3.4 (ebe. 8.3) CIS 51N14121221 SON-DC-V-13.5 IS DEPENDENT ON SON RIGOROUS ANALYSIS HANDBOOK TOR PIPING ANALYSIS BUT DOES NOT REFERENCE HANDBOOK C16 51L14113321 PIPE STRESS CONSIDERATIONS FOR STIFF CLAMPS & PIPE SLEEVE LUG RESTRAINTS NOT ADDRESSED IN SON-DC-V-24.1 (NaC-23,ebs 3.4) C17 51L14124321 GDC EXCLUDES C/R FOR DRILLED ANCHORS & FAILED TO CAPTURE C/R FOR THRU-WALL BOLTS IN NSNRY WAL%S (NRC-31, obs. 7.2 & 7.3) C18 51L14114321 DB DOC DOES NOT CAPTURE ALL SDEP-29 REONTS & AFP F OF THE DA MANUAL FOR SEISMIC 00AL OF MECH & ELEC COMP /EDUIP IS INADED C19 306E451B021 CIVIL AND ARCH DWGS IN ECN L6300 SHOW CONFLICTING REQUIRENENTS FOR CONC CURBS UNDER ARCH DOORS & ARE NOT I-REFERENCED C20 50317120421 C/R REQUIRING SEALED OR ENCLOSED TERNINAL BLOCKS INSIDE CONTAINNENT WAS NISSED IN IMPELL REVIEW OF NCREEB79-7 C21 303E731C220 ECN L5268 INCORRECTLY SCOPED AS AFFECTING UNIT 1 ONLY C22 303C4E30001 U2 ANAL OF CONT SPRAY TEST LINE FOR ECW L5268 JUSTIFIED AS OPPOSITE HAND OF U1 BUT ROUTING CONFIGURATIONS DIFFER C23 30GE732C450 ECN L5298 INCORRECTLY EXCLUDED FROM SOEP-12 TECHNICAL REVIEW C24 50217128401 C/R FOR FSAR TABLE 3.2.1-1 NOT CAPTURED & PROJECT DISCIPLINE INTERFACES INADEOUATE TO CAPTURE GENERIC C/Rs C25 304E4G11321 JUSTIFICATION FOR CALCULATION N0DIFICATION NOT PROPERLY DOCUMENTED THROUGH USE OF A RINS NUMBER C26 51114124321 C/R PARTIALLY CAPTURED IN APPENDIX F DESIGN CRITERIA FOR SEISMIC AND DBA LOADS ON ELECTRICAL AND NECHANICAL COMPONENTS C27 50H14124220 IMPROPER REFERENCE TO SON-DC-V-13.3 BY RCS DESIGN CRITERIA C28 50L17120420 INCORRECT REFERENCES TO CEB GENERIC DESIGN CRITERIA IN SON-DC-V-27.5 C29 302E4E31201 INSUFFICIENT CAPTURE OF ECNs CONCERNING STEEL CONTAINNENT VESSEL AND OTHER PRESSURE BOUNDARY COMPONENTS C30 314E4G38020 ECM L5451 DRC ITEM 6.1 ATTACH 2A REFERENCES COMPONENT DUAL NENO BUT ITEM 6.2 STATES THAT PIPING ANALYSIS IS NOT REQUIRED C31 30354E39041 VEND 02 CALCULATIONS FOR ECN L5451 SEISMIC RESPONSE CURVES DO NOT ENVELOPE TVAs RESPONSE SPECTRA C32 308E4G1E001 ADDITIONAL SUPPORT DRAWINGS FOR ECM L61% ARE NOT LISTD WITH REFERENCED CALCULATIONS ON CIVIL CNECKLIST C33 311J4211001 CALCULATIONS FOR SUPPORTS 2-H36-72 & 2-H36-105 HAVE NOT BEEN REVISED TO INCORPORATE FCR 3963 C34 30174B35411 SOEP-12 CHECKLIST PREPARATION GUIDANCE REVIEW INADE00 ATE FOR ECNs 2548 AND 5970 DUE TO UNCLEAR REQUIREMENTS C35 300E7C04421 CEB CHECKLIST NOT PREPARED FOR ECN 2120 AND GENERIC INPLICATIONS NOT IDENTIFID AND ADDRESSED C36 301E7G04421 ECM EVALUATION DID NOT CONSIDER PIR, SE PODITIED CIVIL CHECKLIST WITHOUT SDE OK, AND CHECKLIST WAS NOT READABLE C37 301E4G34021 ECM 2944 DRC ITEM 6.3 ATTACH 2B-2 REFERENCES PIPE SUPPORT DWGS BUT DOES N0' REFERENCE CALCULATION DOCUMENTS C38 301G7E21411 NCR CEB8404R1 IDENT FORM DOES NOT DOCUMENT TECHNICAL JUSTIFICATION FOR CORRECTIVE ACTION WHICH VIOLATES SOEP-11 C39 306E4G30220 ECN L6439 DATA SHEET DOES NOT ADDRESS ALL APPLICABLE DRAWINGS THAT CALCULATIONS WERE PERFORNED ON FOR CUT REBAR C40 30JE7G00421 IMPROPER INPUT OF CIVIL INFO INTO CONPLETED ECM REVIEW C41 30JE7710021 ECN L5779 DEC REVIEWED CIVIL DESIGN REQUIREMENTS BUT DID NOT EVALUATE FIELD IMPLEMENTED WORK C42 304E4B11301 TECHNICAL JUSTIFICATION AND EVALUATION NOT PROVIDD FOR ECE L6263 AS WELL AS CHECKLIST ITEN 6.4L C43 30JE4G34121 ECN L5779 SOEP-12 REVIEW IDENTIFIED DESCREPARCIES WITH SOEP-12 CHECKLIST, CIVIL CHECKLIST AND ECN DATA SHEET C44 3074453C220 ECN L6263 CALC CONT DISC BETW LENGTH OF BRACE ON DWG & LENGTH US:"D IN STRUCT COMPTR NODEL AND USED INVALID SUPP LOADS C45 302J4G14221 SDE REVIEW OF ECW L6604 FOR CATEGORY D FCR 4093 DID NOT RECOGNIZE POTENTIAL IMPLICATIONS ON ALL RESTART SYSTEMS ., C46 50L14B3F251 ANCHOR PT MOVEMENT NOT ADDR IN DSGN CRIT & CABLE TRAY SUPPORT DSGN DOES NOT ADDR PT LOADS (NRC 44, obs. 8.1, 8.3, & 8.4) gh C47 301E4G11220 ECN L5298 DRC ATTACH 2B DOES NOT PROVIDE JUSTIF FOR STATENENT THAT CALCS ARE NOT REQUIRED FOR FCR 455 (NBC 45, obs. 7.4) CNTNT PENETRATION LEAK TEST ANAL DOES NOT ADDR BOUNDING CASE OF PIPE CANTILEVERED NAX DIS FRON HEAD PL (NRC 48, OBS.3.6)

                                                                                                                                           ~g C48    303C4221021                                                                                                                             ,

C49 301E4520021 ECN L6556 DOES NOT PROVIDE BOLT SIZES & NAT SPECS FOR LIMIT SWITCH NOUNTING PLATE OR SEIS DUAL FOR BRACKETS & NOLTS &M* W

CIVIL / STRUCTURAL (5100) ACTION ITEN TREND NO. CODES DESCRIPTION C50 307C4512221 NEC AUDIT OF ECM L6479 IDENT DISCREPANCIES BETW PIPING LAYOUT SHOWN ON ISONETRIC & PHYSICAL PIPING DWG (NRC 50, obe.3.5) C51 301E4220221 TECHNICAL REVIEW OF ECN L6487 DID NOT ADDRESS PIPING CALCULATION & FSAR DISCPEPARCIES CS2 3074451C021 NRC AUDIT OF ECM L5274 IDENTIFIED DISCREPANCIES BETWEEN RHR PIPING SHOWN ON ISOMETRIC & PEYSICAL DWG (NRC 52, obs. 3.9) C53 303C4210220 TABLE OF SUPPORT CALCS & LOADS REFERENCED IN ECW L6710 CONTAINS DISCREPARCIES IN LOAD NACNITUDES & CALC LOAD Q)NDITION C54 601L4411001 INADEOUATE JUSTIFICATION IN SYSTER 26 FOR SEISNIC OUALIFICATION OF TACF 1-86-092-026 TOR TACK WELDED VALVE BONNET CSS 602L4725021 INCOMPLETE EVALUATION OF CUNULATIVE EFFECTS IN NATRIZ FOR SYSTER 26 DUE TO EXCLUSION OF FCNs, LCDRs & TACFm C56 6 GL4 PUNCHLIST ITEMS WERE IDENT WITH IMPROPER RESOLUTION WHICH COULD AFFECT THEIR INCORPORATION INTO THE SYSTER DOCUMENT C57 611L4714201 EUXEROUS ECN AND PURCHLIST DISCRIPANCIES FOUND IN SYSTER 74 REVIEW 1132 R3R SYSTEN C58 601L4E31011 JUSTIFICATION IN SYSTER 72 FOR NCRCEB8205 DOES NOT ADDRESS THE FULL EXTENT OF CEB REVIEW OF CLOSELY SPACED ANCHORS 7%

                                                                                                                                           %s
                                                                                                                                           ** 5 OM C

U

ELECTRICAL (2100) ACTION ITEM TREND NO. CODES DESCRIPTION E01 106B7824421 LACK OF DOCUMENTATION FOR REDUCING WALKDOWN BOUNDARY ON CRADs FROM SWIBDs (WDP-67R1) E02 10NB7232021 CALC PKG DOES NOT ADDRESS NEANING OF CRKS-HATCHED AREAS OF SYS BOUNDARY ON SWBIDs AND CR&Ds E03 10N87E39041 CRAD USED FOR WD COULD NOT BE REFERENCED TO A SWBID IN SYS BOUNDARY CALC PEG E04 10NB7824421 DVERALL SYS BOUNDARY AND BORIC INJECTION BYPLSS LINE D S OMITTED FROM CRAD ON WDP-63 WHICH VIOLATES SOEP-08 EOS 309E7814201 PRE-OL ECM LISTED ON ECN IDENTIFICATION FOR4 3UT NOT GW THE OWIL WHICH VIOLATES SEOP-11 E06 30NE7B20221 ECNS L5864, L5867, L5880 ARE IDENT AS AFFECTING SYS 201/202 INSTEAD OF VP & AP SYS WHICH VIOLATES SOEP-11 E07 30F71815221 GUIDELINES INADEO IN SOEP-12 TO ENSURE THAT ALL NEEDED ELEC DIST SYS ARE ADDR IN REVIEW OF ECN CHECK LIST ITEM S E08 003C023E001 120VAC PREF & 250VDC PWR SYS, RAD MON, SNPL & FP PWR DIST SYS WERE INCORRLY LISTED IN SYS BOUND CALC PKG AS YP SYS E09 301G7G14421 WRITTEN JUSTIFICATION NOT PROVIDED BY SDE's FOR *INPL' CATEGORY SCE/NCRs WHICH VIOLATES SOEP-11 E10 3 OG7 SOEP-11 DOES NOT ADDR PGCE DOCS RESUI. TING IN CONCERN THAT PROBS IDENT AT OTHER PLANTS MAY NOT BE ADD E11 50A87B34011 TRAINING OF SENIOR PEOPLE TO SOFP-18 WAS DONE TO C/R HANDBOOK BEFORE PROCEDURE ISSUANCE E12 5121111C221 C/R DATA SHEETS HAVE NOT BEFN PREPARED FOR LICENSING COMNITMENTS WHICH VIOLATES SEOP-18 E13 51M17B33401 SOEP-18 ATTACHMENT 1 DOES NOT LIST FEDERAL, STATE AND LOCAL PERMITS E14 50N17B25421 PROJ'S NETHOD TO VERITY THAT INPELL IS ASSIGNING DOCS TO CORR BR NOT COVERED IN SOEP-18R0 & IMPELL INST (NRC-18,ebs.5.4) E15 30AG7914401 SDE's SUBMITTED SCR/NCR IDENT FORMS TO REVIEWER BEFORE RECEIVING ALL *0RP* DOCUMENTATION WHICH VIOLATES SOEP-11 E16 50111133221 SON DESIGN CRITERIA SON-DC-V-11.3 & SON-DC-V-12.2 WERE NOT INCLUDED IN LIST OF RESTART ELEC CRITERIA E17 30G77E31401 ECN CHECKLIST OUESTIONS WERE DELETED FROM SECT C OF SOEP-12 REVISION 1 (obs. 5.2) E18 302G1G34021 INSUFFICIENT DOCUMENTATION WAS PROVIDED TO ENSURE THAT CORRECTIVE ACTIONS FOR SONEEB8113R1 WERE *IMPL' BT ONP E19 50977E39241 C/R ANAL REPORTS WERE NOT DISTRIBUTED TO SE's FOR USE IN DSGN DOCUMENT DEVELOPMENT WHICH VIOLATES SOEP-18 E20 50L17125421 LACK OF CLARITY IN SOEP-29RO I4VOLVING USE OF REP-3.2 FOR PREPARATION OF DESIGN CRITERIA E21 50N17123421 C/Rs WERE OMITTED FROM DG & AUX SYS, 125V VITAL BATT SYS & 120V AC VP SYS DESIGN CRITERIA E22 51L17114101 C/Rs FOR DG & AUX SYS, 125 VITAL BATT SYS & 120 AC VP SYS WERE OMITTED FROM ATTACH 2 C/R DB TRACKING SHEETS E23 50M17123420 CABLE REOMNTS NOT ADDR & CABLE DSGN CRIT NOT REF IN DC CONT PWR SYS, FIFTH VITAL BATT SYS & DG & AUX SYS DSGN CRIT E24 50N11130021 VITAL BATTERY HININUM TERMINAL VOLTAGE AT DESIGN DISCHARGE STATE WAS NOT SPECIFIED IN SON-DC-V-11.2 E25 5 L1 ELECTRICAL DESIGN REQUIREMENTS NOT ADE00ATELY ADDRESSED IN DESIGN CRITERIA SON-DC-V-11.8R0 E26 51L11121221 SON-DC-V-11.623 DOES NOT ADEDUATELY CAPTURE ALL APPLICABLE C/Rs FOR THE 120V VITAL INSTRUMENT POWER SYSTEM E27 311E1G10321 ECN L6544 CHECKLIST DOES NOT REFER TO FSAR, TECH SPECS & DESIGN CRITERIA FOR APPLICABLE ITEMS E28 51L11121221 ELEC DESIGN C/Es WERE OMITTED FROM DESIGN CRITERIA & C/R DB TRACKING SHEET FOR AUX POWER DC SON-DC-V-11.4.1 E29 51N11123321 AUX. POWER CRITERIA SON-DC-V-11.4.1 DID NOT CAPTURE ALL APPLICADLE C/Rs (NRC-25, obs. 5.5) E30 50L11131021 SON-DC-V-11.4.1 DOES NOT ADDR CABLE CAP FOR CONT OVERLOADS LESS THAN NOTOR BKR PROT RELAY TRIP SETTINGS (NRC-26,ebs.5.6) E31 51511121221 FSAR REOMNTS, INST CABLING & SEP REONETS, ELEC PWR REOMNTS, & 125V VITAL BATT & INST RE0XNTS OMITTED FROM CSS DSGN CRIT E32 309E1G25001 DOCUMENTATION DOES NOT EXIST IN ECH L6015 PEG TO ANS OUEST Sa & 5e & CAO NOT ISSUED FOR TRACKING PUR (VIOLATES SOEP-12) E33 40G71815321 PROCEDURE USED BY ESES TO ASSEM, EVAL & DOCU ENT TEST DATA DOES NOT AGREE WITH SOEP-14 REOUIREMENTS (obs. 5.3) E34 40B71B14211 INDEPENDENT REVIEW OF ELEC TEST EVALUATI0il FOR ECM L5017 PEG WAS NOT PERFO2MED WHICH VIOLATES NEP-5.2 & SOEP-14 E35 302E1E3C001 APPENDIX R SHUTDOWN LOGIC CALCS ARE NOT DOCUNENTED IN ECH L6544 CHECKLIST AS BEING REVIEWED OR AFFECTED BY THE ECN E36 409E1B21321 VERIF NOT PROVIDED THAT TRAINED IMPELL PERS ASSICNED *N/A* CAT OR APP 20P ENG BR/NU PWR RESP TO SOURCE DOCUMENTS E37 40TD1B21221 SUPPORTING ENG JUSTIFICATION F02 ECNs 2633 & L5114 TEST REVIE.1 PMG DO NOT ADDRESS PURPOSE OF TEST EVALUATION E30 40RDIC20001 ECM L5114 TEST REVIEW PKG CONTAINED INSUFFICIENT SUIFORT INFO TO JUSTIFY THE EVALUATION CONCLUSION E39 51L11133001 IEEE 279 & FSAR C/R FOR CONT SPEAY SYS HAVE NOT BEEN ADEOUATELT ADDRESSED IN SYS DESIGN CRITERIA SON-DC-V-27.5R0 E40 51M11134001 C/R FOR KOV CONTROL & INDICATION FEATURES REF ON PRINTOUTS FOR RHR & RCS SYS BUT NOT IN SON-DC-V-27.6 & 27.4 E41 308E1G11011 ECN L5114 ELEC DEC CONTAINS MINOR ERRORS & DOES NOT ADDRESS SEISMIC OUAL OF ELEC COMPONENTS E42 301E7G10421 ECB L5114 DRC CONTAINS OMISSION 3 & WAS EVALUATED USING THE WRONG DESIGN CRITERIA E43 50A17B04221 LACK OF TRAINING OF WESTINGHOUSE DESIGN CRITERIA PREPARERS TO SOEP-29 E44 50110E39041 SOEP-18R1 RE0MNT THAT C/R DATA SHEETS BE PREPARED FOR LICENSING COMMITMENTS WAS VIOLATED FOR SYS 62 & 74 PMP CURVES E45 304E1G03320 ECN LS451 DRC ITEM B.3.6 EVALUATION WAS BASED ON MB 0F MATERIAL WHICH DOES NOT VERIFY DESIGN CRITERIA REOMNT e jg 301E1G10320 ECN L5451 DRC ITEMS B.3.d&g & B.S.a&b REF WRONG CALC PKG, ITEM B.S.c CONT INADEO RESP, & ITEM B.S.e DID NOT SPECIFY PIR Sm E46 E47 300M043C001 USOD FOR ECN L5451 REDUCES THE SCOPE OF THE ECM AKD DOES NOT ADDRESS THE 125VDC LUBE DIL PMP THAT WAS ADDED BY ECW - "Q E48 301EIG10001 ECN L5451 DRC WAS INCORRECTLY EVALUATED SINCE CHANGES TO 125V DC DG DIST BD WERE NOT INCLUDED IN FIELD WALEDOWN E E49 313ElB11011 ECN LS872 DRC CONTAINS TECHNICAL ERRORS INVOLVING ECN COVER SHEET, FSAR, LOGIC DIAG, FLOW DIAG & I-TABS C

ELECTRICAL (2100) ACTION ITEM TREND-NO. CODES DESCRIPTION E50 302E1F!3020 ECN L5872 REVIEW INDICATED THAT INST HAS NOT BEEN PROVIDD TO GIVE MCR INDICATION OF STATUS OF DG EXHAUST VENT FAN E51 313E1G00321 ECM L6712 DRC CONTAINS MINOR ERRORS, CALC ERRORS, AND DOES NOT PROVIDE JUSTIFICATION FOR ADEQUACY OF CONCLUSIONS E52 303EIG11021 ECN LS872 DRC CONTAINS TECH ERRORS INVOLVING SYS MON CIRCUITS, REF FLOW DIAG INSTEAD OF SCH, & REF WRONG HAND SWITCHES E53 313EIG10050 ECM L6676 DEC CONTAINS IMPROPER EVALUATION RESPONSE FOR ITEM B.5.s & TECH INCONSISTENCY BETWEEN SCH DIAG & CONE DIAG E54 304EIC00301 ECM 2945 DRC RET WRONG DSGN CRIT REV, EVAL TO SYS 31 CHECKLIST, REF CALCS THAT USED UEVERIFIED ASSUN & OTHER MINOR DISC ESS 302EIG10221 ECN 2945 DEC ITEM B.1 INCORRLY REF SON-DC-V-3.2, B.3.d & B.S.c WERE INCORELY EVAL AS N/A, AND B.3.d RAD WRONG CONCLUSION E56 403D1314251 E57 50EP-1421 SECT 3.6 REDMNT WAS VIOLATED IN RED-LINE PKG SINCE AS-DSGN DWG WAS USED FOR AS-CONST DWG TO COMPARE PREOP DWG 404D1730020 ECM 2945 TEST EVALUATION DID NOT DOCUMENT THAT ASSOCIATED PREOP TEST DEFICIENCY HAD BEEN RESOLVED E58 30PMIF30011 USOD FOR ECN L6015 MISIDENTIFIED ELEC EQUIP BEIEC KODIFIED UNDER ECN AS SAFETY RELATED ES9 303ElG01321 ECM L5072 DRC DID NOT REF DESIGN CRITERIA REV, REF WRONG CALC PKG, & DID NOT REF REDUD, DIVERSITY & SEP RE0MITS E60 40TDIC21001 E61 ECN L5599 TRP LACKS JUSTIF TO SUPPORT CONC TIIAT RESOLUTION TO OPEN ITEMS IS NOT REO FOR RESTART & SCOP DOC REF WRO?G SOI 301EIG00321 ECM L6667 DRC IMAPPROP REF BM & STD DWGS, DOES NOT REF EXISTING CALCS, CONTAINS DISC IN ITEN 7 & REVIEWERS NAME ILLEGBLE E62 309EIG24021 SOEP-11 ATTACH 1 FOR ECN 5449 INCORRECTLY STATED ECN ONLY INVOLVES AP SYS BUT ECM ALSO IEVOLVES VP SYS E63 300N1F31001 E64 USDD FOR ECN L5449 DOES NOT ADDR LOSS OF VOLT RELAYING LOGIC & INDICATES OVERVOLT LOGIC 2 0F 3 INSTEAD OF 10F 3 SGEME 303E1G00320 ECN L5449 DEC CONTAINS ERRORS & DOES EDT ADDRESS DESIGN DISCREPANCIES E65 301EIC00320 E66 ECE L5363 DRC ITEM B.5.c REF WRONG CALC PKG & ITEMS B.10.f & D WERE INCORRECTLY EVAL RESULTING IN INVALID CONCLUSIONS 301E1G07320 ECE 2774 DRC CONT OMISSIONS THAT COULD PREVENT CALCS FROM BEING MADE TO ADDR ITEMS B.3.d,B.3.g,B.5.a,B.5.b,B.S.c & B.S.e E67 40G71825221 SEOP-14 DOES NOT IDENT WHO APPROVES

• RETEST
• TEST RESULTS, WHO EST
• RETEST
• ACCEPT CRIT & RHO PERF & PART IN RETEST E68 300M1F30001 E69 301EIC00221 USOD FOR ECN L6573 DOES NOT ADDR DECR TRIPPING TIME OF NOR FDR BKR FOR 6900V SHDN BDS & DOES NOT ADDR SPECIAL REOMN E70 ECM L6573 DRC CONTAINS MINOR ERRORS THAT COULD CAUSE THE EVALUATION NOT TO BE COMPLETE & ACCURATE 40GD7E33401 E71 50L1111CO21 SOEPs 14 & 26 DO NOT PROVIDE METI10D TO DOCUMENT THE
• FUNCTIONAL
• BASIS FOR SAFETY SYS IN ENG DOCS OR FUT MODS (obs. 5.3)

SON-DC-V-11.3R5 CONTAINS ENVIR COND THAT ARE OUTDATED & DO NOT AGREE WITH ENVIR COND ISSUED BT SON E0P (NRC 40,obe. 6.9) E72 3 2E ECN L5363 DOES NOT ADDR THE EFFECTS OF FAILURE TO SHED LOAD (S) DUE TO LOAD BREAKER FAILURE (ERC 41, obs. 5.7) E73 302ElG00321 ECM L6533 DRC DOES NOT SUBSTANTIATE THAT ClfANGES HAVE BEEN ADIR IN PROGRAMS OUTSIDE THE DBVP (NRC 42, obs. 5.0) E74 50L11E3F001 E75 302E1G20320 RPS 1E CABLES ROUTED THROUGH THE TURBINE BUILDING ARE NOT BEING LABELED AS GSPS PER EXCEP NO EX-SON-DC-V12.2-5 (NRC 43) SOEP-12 CHECKLIST DUESTION B.3.c DOES NOT ADEO DOC THAT A COMPRElIENSIVE FAILU2E ANAL HAS BEEN DONE (NRC 59, obs. 6.14) E76 302E123A221 CALC PKG OSG7-038 DID NOT ADDR ECNs L5944 & L6459 (BRC 55, obs. 6.11) E77 60977815421 E78 40RD1410021 DBVP-D-06-019 REMOVES TEE REONNTS OF EVAL OPEN SCRs & THE OPEN NCR/SCRs FROM DB&VP WHICH VIOLATES SOEP-16R1 & SOEP-E79 ECN LS298 TEST REVIEW PACKAGE RETEST SCOPING DOCUMENT INCORRECTLY REFERENCED SMI-2A IN TEST

SUMMARY

401E1410021 E80 602L1713021 ECN L5363 ELEC TEST REVIEW PKG FUNCT TEST RESULTS DO NOT ADEO DOCUMENT THAT MODIFIED SAFETY FURCT WILL PERPDRM ALL APPLICABLE CHANGES & NODIFICATIONS MAY NOT BE CAPTURED AND INCLUDID IN SYSTER 82 EVALUATION E81 601L1714221 E82 609L1731001 TECHNICAL JUSTIFICATION NOT PROVIDED FOR SWBID AREAS NOT WALKED DOWN & AS CONSTRUCTED INFO NOT EVALUATED IN SYSTER E83 604L7724421 ECN L6746 NOT CAPTURED IN SOEP-12 REVIEW OR IN THE SYSTER EVALUATION WHICH CONFLICTS WITH SECT 3.1A 0F THE SYSTER E84 612L1738001 PUNCHLIST ITEMS LISTED AS POST-RESTART W/0 SUFF TECH JUSTIF & SYSTER EVAL OF OPEN ITEMS CONFLICTS WITH PUNCHLIST ITE E85 602L1710221 INTERLOCK FOR NORMAL CHARGER FEEDERBREAKERS TO VITAL BATTERY BDS & LC RELAT FOR STH VITAL BATTERY HAVE NOT BEE DWG DEFICIENCIES, PUNCHLIST ITEMS, & PUNCHLIST ITEM CONFLICTS ARE NOT ADDRESSED IN VP SYSTER EVALUATION E86 613L1731121 E87 602L1531001 CRAD 45N709-2 RL HAS CABLE IDENTIFICATION PROBLEM & VITAL INVERTER NAMEPLATE DATA IS IN CONFLICT WITH VITAL POWER S E88 602L1708551 CRAD 45N727 DOES NOT REFLECT PLANT CONFIGURATION FOR DIESEL 125V DC DISTRIBUTION PANEL & IS NOT ADDRESSED IN SYSTE E09 480V SHDN BD BREAKER SETTING DISCREPANCIES NOT IDENTIFIED ON PUNCHLIST OR ADDRESSED IN AP SYSTER 609L1724321 E90 600L1730030 PUNCHLIST AND SYSTER NOT RECONCILED RESULTING IN ITEMS REQUIRING ACTION BEING NISSED OR IMPROPERLY EVALUATED IN E91 6 2L UNIMPLEMENTED ECNs NOT ADE00ATELY ADDRESSED IN AP SYSTER & INCORRECTLY SHOWN AS FIELD INSTALLED IN AS-CONST DWGS RESTART CATEGORIZATIONS WERE NOT ASSIGNED & THE SCOPE OF CCREECTIVE ACTIONS WERE INADEDUATE IN PUNCHLIST ITEN 6 2% ill ?! s 2*" l

INSTRUNENTATION AND CONTROL (3100) ACTION ITEM TREND NO. CODES DESCRIPTION 101 - 107B5618001 IDENTIFICATION OF COMPONENT 2-SI-46-56B WAS NOT ACCURATELY TRANSFERRED TO NASTER IN COMPLETED WD PACKAGE 102 106B5618001 WDP FIELD DWG MARKED COMPONENT WITH MISSING ID TAG AS

• ITEM l' & NASTER COPY WAS NOT SIMILARLY MAREED 103 10GB2835321 WALKDOWN PERSONNEL DID NOT INCLUDE VERIFICATION OF HARDSWITCHES IN COMPLETED WDP 104 304E2G25021 ECN L5038 DRC STATES THAT ITEMS 10b & 10e ARE APPLICABLE & TECH ADEDUATE & OUALIFIES THIS BY A FUTURE HUNAN FACTORS 105 100B2E39041 CHANGE MADE TO WDP-46 WITHOUT USING OA RECORD CHANGE FORM 70 DOCUMENT CHANGE WHICH VIOLATES AI-7 106 109BSE3F001 DETAIL SEETCH OF PANEL 2-L-381 IS NOT REF ON WDP-46 SUM SHEET & DNE AGREEMENT NOT PROVIDED WHICH VIOLATES SNI-0-317-30 107 10647B3B201 LACK OF ROOT VALVE NUMBERING AND PIPING INTERFACE NOTATION ON FUCTIONAL CONTROL DRAWINGS (NRC-6) 108 101B2623321 METHOD DOES NOT EXIST FOR EVAL RED ELEC & I & C SYS INFORMATION THAT IS NOT OBTAINED FROM WALKDOWN (NRC-10, obs.5.166.3) 109 5151743B401 THE EFFECT OF RG 1.97 ON THE DBVP HAS NOT BEEN IDENTIFIED (NRC-15,obs. 6.1) 110 50212F28001 TVA RESPONSE TO NRC IEB 85-03 CONTAINS C/Rs TO INVESTIGATE, TEST, & MAINTAIN MOV SETTINGS BUT WAS NOT CAPTURED IN C/R DN l

Ill 50212123021 C/R IN NUREC 011 SER, SUPPLEMENT 5 ITEM II.F.2, REQUIRING BACKUP DISPLAY FOR INCORE TEMP WAS NOT CAPTURED IN C/R DB i 112 50212B23321 RESPONSE FOR TVA MEMO CONCERNS NRC IE INF NOTICE 85-100, ROSMOUNT DIFF PRESS TRANS ZERO PT SHIFT, IS NOT COMPLETE l SON-DC-V-32.0 REF IEEE 323-1971 INSTEAD OF 323-1974 & DOES NOT ADDR SYS SETPOINT RE0MNTS (NBC-32, obs. 6.5, 6.6, & 6.7) l 113 50M12123220 114 51L12133221 SINGLE FAILURE CRITERIA TERMINOLOGY IN DESIGN CRITERIA SON-DC-V-2.16 NEEDS CLARIFICATION (NRC-33,obs. 6.8) IIS 50N17431201 c/R DEFINING THE ABILITY OF FLOW INSTRUMENTS TO INDICATE SYS FAILURES IS NOT DOCUMENTED IN C/R DB I16 50212E3F001 C/R INVOLVING PROCESS CONT SYS, CHAN ACCURACY & SETPOINT TOLERANCE IS NOT DOCUMENTED IN C/R DB I17 50H12133201 TVA LETTER ON METEORLOGICAL MONITORING SYS FEATURES & ADD EMER RESPONSE ORG STAFFING COMMITMENT CAT AS *N/A* BY IMP 118 50A12114301 C/Rs INVOLVING IGC CHANNEL LIST HAVE MISSING ATTACHMENTS AND MAT NOT BE IN C/R DB I19 50217123221 WESTINGHOUSE LETTER TVA-890 DID NOT IDENTIFY ALL APPLICABLE REACTOR CONT & PROT SYS FUNCTIONAL REQUIREMENTS AS C/Rs 120 50M12431001 C/R REQUIRING REPLACEMENT OF 20-200 SEC RANGE RELAY WITH 3 SEC RANGE RELAY IS NOT IDENTIFIED IN DESIGN CRITERIA 121 30AE7B35411 ECM L6359 DRC DOES NOT PROVIDE ADE00 ATE ASSURANCE THAT SEISMIC 00ALIFICATION OF LEVEL SWITCHES WILL BE EVALUATED I22 301E2G01321 ECN L6359 DRC CONTAINS CONFLICTING & INCOMP ASSFSSMENTS OF SETPOINT ACC & SETPOINT MARG FOR REPLACEMENT LEVEL SWI 123 311E2G10320 ECN L5791 DEC REF TO SON-DC-V-4.2 AS BASIS FOR *ADDR* CAT BUT LEVEL SETPOINT MOD BY ECN IS NOT ADDR NOR REF BY DSGN C I24 311E2G10320 ECW L5791 DRC REFERS TO ECN WOREPLAN AS BASIS FOR ADDR SETPOINTS BUT WOREPLAN IS GERMANE TO ECW WHICH VIOLATES 125 302E7320401 ECN L5084 DRC ITEM 6a IS MARKED AS *ADDR* BUT DOES NOT PROVIDE ASSURANCE THAT COMPONENTS WILL BE SEISMICALLY EVAL 126 301E7G2C421 ECM L5084 DRC CONTAINS TWO ITEMS WHICH ARE *NOT ADDR* BUT CAO WAS NOT ISSUED TO RESOLVE OR TRACK THESE ITEMS 127 301E2G21221 ECN L6404 RECOGNIZES LACK OF SEISMIC OUAL FOR REPLNNT SW ON FCV-63-72 BUT DOES NOT REF TO CAO FOR RESOLUTION & TRA I28 301E2G00321 ECN L6254 DRC DOES NOT REFERENCE REQUIRED SETPOINT CALCULATIONS I29 306E2G00320 ECN L6254 DRC DOES NOT CONTAIN ADEQUATE ASSESSMENT OF TECHNICAL REQUIREMENT OF SON-DC-V-13.9.8 130 304E2G04221 ECM L6254 DOES NOT CONTAIN ADEDUATE ASSESSMENTS OF SETPOINT ACCURACY & MARGINS FOR PRESSURE SWITCHES DESCRIBED IN I31 302E7C25420 ECM L5600 COVER SHEET IND 50 INVOLVEMENT BY CIVIL DISC BUT USOD IND THAT FIELD NOD WAS REVIEWED AND APP BY CIVIL DISC I32 40TD2E31201 ECN L6175 PRESSURE SWITCH RECALIBRATION TEST RESULTS LACK REFERENCE TO METHODOLOGY I33 304E2G07321 ECM L6124 DEC DOES NOT CONTAIN ADEDUATE ASSESSMENT OF TIME DELAY SETPOINTS FOR SWITCHES DESCRIBED IN ECN I34 304E2G07321 ECN L6124 TIME DEL?.Y SETPOINT CALCULATIONS NOT REFERENCED IN ECN PACKAGE 135 3074251C020 ECM L6124 DATA SHEET DID !!OT REFLECT ALL NECESSARY DRAWING CHANCES FOR MODIFICATION 136 303E2G21221 ECN L5275 DRC DOES NOT PROVIDE JUSTIFIED CONCLUSION THAT BIT RECIRC ROTOMETER IS NOT REQUIRED FOR RESTART I37 311E7G2B401 ECN L5275 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 2f, 3f & 10h I38 311E2E21411 ECN L5275 DRC DOES NOT PROVIDE JUSTIFIED CONCLUSION FOR CATEGORIZING ITEMS 1, 2a, 2b, 6c, 7a, 8b, 84 & 10h AS *NOT ADDR* I39 301E2G31221 ECN L5734 DEC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 10a & 10b I40 301E2G31221 ECE L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 6a & 6b l I41 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEM 7a 142 301E2G31221 ECN L5734 DRC DID NOT REFERENCE THE PRIMARY SYSTEM DESIGN CRITERIA AS JUSTIFICATION FOR ITEM 1 CONCLUSION 143 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSIDH FOR ITEMS 10c & lod I44 30XESE18001 WP 11916 LISTS TEMP SWITCH ' RED VALUES

• WITH +/-5 DEG F TOL W/0 REF TO DSGN BASIS FOR JUSTIFICATION (NRC 35,obs. 6.10)

I45 11XN591E031 FC-30-149 HAD MISSING COVER AND DAMAGED FLEX COND BUT WAS NOT TAGGED TO INDICATE CONDITION HAD BEEN g DOCUMENTED I46 40RDSD23221 FAILURE TO PERIODICALLY TEST TIME DELAY RELAYS PER IEEE 338-1977 REQUIREMENTS (NRC 47, obs. 6.15) I47 314E2B38001 PERFORMANCE OF PRESS SW EEPLACED BY ECN L6374 CANNOT BE VERIFIED SINCE SOURCE DOCUMENTATION IS INCOMPL (NRC 53,obs.6.13)ag I48 601L2714021 SYSTER 81 USES AN UNNUMBERED SKETCH FOR ER/SD & ADDRESSES CONTROL VALVE LIMIT SWITCHES NOT SHOWN ON SWBID OR E , 149 601L2738011 DISCREPANCY BETWEEN COMMITTMENT FOR LOGIC DIAGRAM CHANGE PER ECN LS765 & CORRESPONDING PL ITEN 4 l I

INSTRUNINTATION AND CONTROL (3100) ACTION ITEM TREND N0. CODES DESCRIPTION 150 604L2731021 151 602L2714021 ECN LS831 WAS LISTED AS POST RESTART BASED ON ADEO OF EXISTING EQUIP BUT EXISTING EQUIP IS NOT ADED FOR SAFETY FUNC 152 602L2730021 NCRs/SCRs AFFECTING PRIMARY WATER SYSTEM HAVE NOT BEEN IDENTIFIED OR EVALUATED PER SOEP-16 153 60AL3718221 JUSTIF FOR NCRSONSWP8202R1 ADDR THE TECH ACCEPT OF RELIEF PATH ISOLATION VALVE BUT DOES NOT ADDR RAD MON RE-90-118 154 WDP-81 DOES NOT INCLUDE NAMEPLATE DATA FOR NECHANICAL COMPONENTS AS REQUIRED BY WALKDOWN SCOPE 60GL2725321 155 6 2L2 1 UNCOORDINATED CHANGES TO PUNCHLIST CREATED CONFLICT BETWEEN PL C/A & RESTART STATUS AED STATEMENTS IN SYSTER 81 156 6 2L 7 3 FCN USED TO MODIFY 10-50sa POWER SUPPLY IS NOT IDENTIFIED AS INPUT TO SYSTER

SUMMARY

FOR ECM L5884 157 6 4L2 THE DUALIFICATION OF DIODE USED IN MODIFICATION OF CONTROL SWITCH HS-68-341A WAS NOT ADDR IN SYSTER

SUMMARY

ISO 617L2B24211 JUSTIFICATION FOR NOT IMPL ECE L6674 REQUIRING THE REPLACEMENT OF ANNUBAR ELEMENTS 72-13 & 72-34 IS IRADEOUATE 159 6 11 NCR NEB 8405 EVAL DOES NOT CONTAIN JUSTIF FOR LACK OF AUTO CONT INDICATION IN MCP DURING PARTIAL BYPASS OF I60 6 2L NEKO CLOSING PUNCHLIST ITEM DOES NOT PROVIDE ADEDUATE CLOSURE JUSTIFICATION AND CONTAINS WRONG RIMS NUMBER PUNCHLIST 3588 WAS CLOSED WITHOUT VERIFICATION OF TRANSMITTER PARMETER ACCURACY CONTAINED IN CALC PEG WCAP-112 t" B C$

                                                                                                                                                           "' o

MECHANICAL (4100) ACTION ITEM TREND NO. CODES DESCRIPTION M01 106B5625221 AS-BUILT DRAWING DISCREPANCIES NOT TRANSFERRED TO MASTER WALKDOWN COPY &

SUMMARY

SHEET NOT PROVIDED N02 10BB5625221 OC SIGNOFF AND VERIFICATION WAS ACCOMPLISHED ONLY BY HIGHLITE & RED LINES & PROCEDURES DID NOT INDIC M03 10GB7E25411 WDP-15 INDIVIDUAL 81/2 X 11 SHEETS NOT DESIGNATED UNIT 2 AS APPOSED TO UNIT 1 DUE TO PROCEDURAL DEFICIENCY M04 101B3223221 DBVP HAS NOT DOCUMENTED RATIONALE FOR THE INCLUSION OF ALL PROGRAM SCOPED ITEMS MOS 10745514101 WDP-72 SUMNARY SHEET ATTACHMENT DOES NOT REFERENCE

SUMMARY

SHEET & WDP MASTER DWC NOTE CONFLICTS WITH SU M06 30F77B25421 PROCEDURES DO NOT ADDRESS ECN REVIEW FOR TECHNICAL ADEDUACY OF DRAWINGS & CALCULATIONS WHICH VIOLATES SOEP-M07 51213125421 SOEP-18R0 DOES NOT ADDRESS HANDLING OF C/Rs IDENTIFIED AFTER C/R DATA BASE CLOSURE N08 106B3635021 RHR WDP DISCREPANCY CONCERNING RCS EQUIP NOT REPORTED TO WDP-72 PERSONNEL FOR PROPER INTERFACE ON MASTER DWG M09 303G3G38011 SCR NEB 8520 WAS INCORRECTLY CLASSIFIED AS "0 PEN" INSTEAD OF *0NP" IN ACCORDANCE WITH SOEP-11 M10 60JL7B25401 SOEP-16 DOES NOT ADDRESS SYSTEM INTERFACE & REVIEW RESPONSIBILITIES (obs. 1.3) 51213123221 THERMAL LOAD RANGE C/R FOR PIPING DSGN & ANAL, ERCW INTERFACE REO, & MIN TEMP REO NOT ADEOUATELY CAPTURED IN AFW DC M11 M12 50213133221 AFW & AUX AIR C/R FOR LOSS OF AC POWER NOT ADDRESSED ADEOUATELY IN DESIGN CRITERIA FOR CRITICAL TIME REQUIREMENT M13 51M1313B001 C/R FOR MINIMIZING CAVITATION OF ERCW THROTTLE VALVES NOT CAPTURED IN C/R DATA BASE 02 DESIGN CRITERIA M14 50217124421 C/R DATA SHEETS ARE INCOMPLETE & IMPROPERLY FILLED OUT CAUSING INCOMPLETE CAPTURE OF DSGN REDMNTS IN DSGI C MIS 51M13113321 DESIGN CRITERIA DOES NOT ADDRESS TEMPERATURE & PRESSURE STRESSES FOR SUPPORT DESICN & STRESS ANALYSIS M16 50L1313B021 DSGN CRIT DOES NOT STATE REG CUIDE 1.29 EXCEPTIONS, SOEP-11 LICENSING COMMITMENTS NOT CAPTURED, & HPFP C/R NOT CAPTURED M17 51J1312E121 AFW DEFICIENCIES RELATED TO SYS INTERFACE, MISSING C/Rs, SHOP TEST REQUIREMENT, & DESIGN REQUIREMENT FOR A NP NPSH M18 50M1313B221 DESIGN CRITERIA DID NOT REFERENCE NPSH VALVES FOR THERMAL BARRIER BOOSTER PUMPS M19 301E7G13221 DRC FOR ECN 2945 DOES NOT ADDRESS ITEMS FOR WDP & HYDRAULIC, STRUCTURAL, AND MECHANICAL DESIGN CRITERIA M20 301E3331011 ECN 2945 DRC HAS MISSING DOCUMENTATION & PIRs HAVE NOT BEEN ISSUED FOR TRACKING PURITISES WHICH VIOLATES SOEP-12 M21 306E7G25221 ECN L6665 DRC HAS TWO SEPARATE AND POSSIBLY CONFLICTING VERSIONS M22 51510B3D211 C/R FOR WESTINGHOUSE PROPRIETARY INFORMATION MAY NOT BE INCORPORATED INTO DESIGN CRITERIA (NBC-27, obs. 2.3) M23 301E7C25421 ECN L6665 DRC DOES NOT PROVIDE REFERENCE FOR ITEM 3.6 & 6.a AND VEMDOR INFORMATION NOT RETRIEVABLE M24 50M17113421 SON-DC-V-7.4 CONTAINS THREE APPENDIXES LISTING DOCS THAT CONTAIN COMMITMENTS & REONITS NOT INC INTO TEXT OF DS M25 301E7G25421 ECN L5095 DRC JUSTIFICATION AND ASSOCIATE REFERENCES NOT CAPTURED FOR SYSTEM DESIGN TEMPERATURE AND PRESSURE M26 50L13E33001 SON-DC-V-13.9.9 MAY NOT LIST ALL APPLICADLE INDUSTRY CODES AND STANDARDS M27 301E7B21421 ECM L5095 DRC DOES NOT REF PIR WRITTEN FOR JUSTIFICATION OF CHANGE TO PIPING RIGOROUS ANALYSIS WHICH VIOLATES SOEP-12 M20 50M13113021 C/R FOR SIS COLD LEC PARAMETERS FOR DESIGN OF COLD LEG ACCUMULATORS WAS NOT CAPTURED (obs. S.4) M29 51213123221 C/R FOR ERCW COMPONENT COOLING SYS *C' HEAD EXCHANGER DISCHARGE VALVE 0-FCV-67-152 NOT INCORPORATED IN C/R DB BY IMPELL M30 51L13111021 SON-DC-V-27.6 DOES NOT ADER D3GN REOMETS FOR RI!R PHP COOLING WATER JACKETS & AUX OIL SEAL COOLERS FOR DSGN PRESS M31 50217124221 SOURCE DOCUH G TS NOT INCORPORATED ON C/R DATA SHEETS & IN DESIGN CRITERIA FOR SIS & RHR SYSTEMS (obs. 5.4) M32 311E3427221 ECN L5064 DRC ITEM B.2.b WAS INCORRECTLY REVIEWED RESULTING IN INVALID CONCLUSIONS & EVAL WAS NOT PROPERLY SIGNED BY S M33 602L7720421 DRAFT CONTAINMENT SPRAY SYSTER DOES NOT EVALUATE C/A FOR OPEN SCR/NCRs 02 JUSTIFY EVALUATION OF SYNERGISTIC EFFECTS M34 304M3B25201 INCORRECT USE OF USOD F02 ECN L5095 TO JUSTIFY SEIS DUAL OF REPLACEMENT OF BLIED FLANGE WITH SECOND VALVE, NIPPLE, & CAP N35 30AE3E39041 ECN 5415 SOEP-11 ATTACHMENT 1 NOT FROPERLY SIGNED BY SYSTEM ENGINEER M36 31113123221 ECN 5769 DEC DOES NOT REF M N 3A DC SON-DC-V-4.2 IN RESPONSE TO OUEST B.1 & DOES NOT REF ASME CODE REOMNTS IN ITEN B2.C M37 301E343C001 SOEP-11 ECN ID FORM DOES NOT ASSIGN ECM L5601 TO SYS 67 FOR EVAL OF THE EFFECT OF ACA AIR COMPRESSOR CHANGE ON ERCW SYS M30 300M0F23320 USOD FOR ECN L5681 DOES NOT DOCUMENT VENDOR RECOMMENDATIONS & SEISMIC ANALYSIS WAS NOT PERII)RMED OR DOCUMENTED M39 304E3G26020 ECN L5681 DRC DOES NOT APPROPRIATELY ADDRESS SEISMIC ANALYSIS, OPERABILITY & HYDRAULIC DESIGN M40 302E4E39041 ECN 5451 DID NOT REQUIRE THE SEISMIC REVIEW OF THE CONDUIT INSTALLATION FOR THE EMERG DG AC & DC LUBE DIL PUNPS M41 302E4G30000 ECN L6103 CIVIL CHECNLIST DOES NOT ADDRESS TUBE OUALIFICATION FOR PORV ISOLATIGN VALVES M42 301E3G31021 ECN L6501 CHECKLIST DOES NOT ADDRESS ECH JUSTIFICATION FOR REFERENCED CALCULATIONS M43 50M13D33021 ASME XI SEC 9.1 REQUIRING PERIODIC TESTING OF PRESS RETAINING CMPNT IS NOT CAPTURED IN SON-DC-V-13.99 (NRC 46, obs.6.12) M44 309E3D07001 ECNs 5714 & 6103 NOT REVIEWED BY ENGINEER TRAINED TO SOEP-11 FSAR DOES NOT REFLECT CCS DESIGN CRITERIA (NRC 37, obs. 2.4) y M45 51003036001 M46 51M17125421 C/R DATA SHEETS FOR SYSTEMS NUMBERED HIGHER THAN 99 MAY NOT BE CAPTURED IN THE DESIGN CRITERIA Ak M47 6 2L3 1 CSS SYSTER DOES NOT ADDRESS CONFLICTING DESIGN TEMPERATURES IN FLOW DIAGRAM, DESIGN CRITERIA, & FSAR *Q M48 6 4L4 10 RATIONALE FOR NO BLOWOUT PANELS IN CO2 STORAGE ROOM OF THE DGB IS NOT ADEOUATELY ADDRESSED IN STSTER 82 "S M49 60GL3E3F001 PUNCHLIST ITEMS ARE BEING CLOSED BEFORE OA COMPLETES REVIEW OF FIELD WORK &M" w

 ~       ._ _         .                                                .  ..                         . .            __   _
                                                                                                                               .         2     ..

NECNANICAI (4100) ACTION ITEN TREND NO. CODES DESCRIPTION M50 -61UL3815001 ENTIRE TEXT PAGES FOR SECTS 4.0 & 5.0 IN THE SYSTER ORIGINAL DOCUMERi' CONTROL COPY WERE MISSING M51 3 01 DIN-SON-DC-V-13.9 DOES NOT ADED IDENT THI: AFFECTED VLVE FUNCT, IMPORTANCE TO SAFETT, & TWE S009CE OF STREE TINES LISTED M52 6 07 ' PURCHLIST 5931 WAS CLOSED BEFORE CORRECTIVE ACTION WAS ASSIGNED TO THE ASSOCIATED PIR SON-EEB-86174 - , 4 k t i e 4 1

                                                                                                                                                                  , .T'8 OM
                                                                                                                                                                    'a U

NUCLEAR (1100) ACTION , ITEM M ND NO. 3 copes DESCRIPTION N01 004CO211221 JUSTIFICATION INADEO IN CALCS FOR ABSENCE OF FSAR CHAPT 15 DBAs & EVAL FOR OFFSITE RADIATION NOT DOCUMENTED (obs.4.1) NO2 004C0231221 SAFETY FUNCTION IDENTIFICATION BOT SYSTENATICALLY IDENTIFIED IN CALCULATION PACKAGE SON-OS(T1-048 NO3 00DCO210201 CONTAINMENT PENETRATIONS AND ASSOCIATED ISOLATION VALVES OMITTED FROM BOUNDARY DRAWINGS IN CALCULATION PKG SON-OS N04 004C0411301 LACK OF JUSTIFICATION FOR BOUNDARY SELECTION IN CALCULATION PACKAGE SON-OSC7-048 N05 005C023E221 SYSTEM BOUNDARY DWG IN CALC PKG SON-OSG7-048 HAS INCONSISTANT BOUNDARY MARKINGS AND REO VS NOT REO AREA DESIGNATIONS N06 Gh CO211221 MISCELLANEOUS ERRORS, OMISSIONS, AND INCONSISTENCIES IN CALCULATION PACKAGE SON-OSG7-048 N07 50G77835421 LACK OF TVA PROCEDURE FOR LICENSING COMMITMENTS REVIEW ACTIVITY N08 50N10B31201 NRC OUESTIONS WHETHER TECHNICAL SPECIFICATIONS ARE BEING CONSIDERED FOR INPUT TO LICENSING COMMITMENT LIST (NRC-1) N09 004CO211221 JUSTIFICATION NOT PROVIDED FOR INCLUSION / EXCLUSION OF ALL SYSTEMS FOR CHAPTER 15 ACCIDENTS IN CALCS (NRC-8,obs. 4.1) N10 50210330020 OUALIFICATION OF THE EXCORE NUCLEAR INSTRUMENTATION FOR ROD EJECTION ACCIDENT IS IN DUESTION (NRC-19, obs. 6.2) N11 00DC023B221 SCOPE DEFINITIONS FROM RPS AND NMS NOT CONSISTENT WITH OTHER SYSTEM BOUNDARIES (NRC-20, obs. 4.2)

                 #12    002COE3F001    TMI COMMITNENTS NOT PROPERLY SCOPED FOR SYSTEM BOUNDARY DETERMINATIONS AND DESIGN BASELINE VERIFICATION PROGRAM (

N13 50G77835421. IMPELL LICENSING REVIEW OF DSGN CRIT DEVELOPMENT WAS NOT INDEPENDENTLY VERIFIED FOR CAPTURE OF ALL C/Rs (NRC-17,obs.5.4) N14 302E7B31201 POTENTIAL INTERACTIONS NOT CONSIDERED IN ROUTING OF ECNs PER SOEP-11 NIS 309G4B14001 SCR/NCR PHP8308 CORRECTIVE ACTION WAS FOUND INADED & A NEW CAO WAS NOT ISSUED TO READDRESS FINDINGS BY SDE PER SOEP-11 N16 302F0G3C220 SON-OSG2-001 DID NOT CONSIDER FCNs APPROVED BY OTHERS & THOSE THAT WERE NOT APPROVED REGARDLESS OF IMPLEMENTATI N17 50L10133121 FAILURE TO INCORPORATE C/Rs INTO DESIGN CRITERIA TEXT AND TO SPECIFY ALL INTERFACE REQUIREMENTS PER SOEP-29 N18 50210434301 FAILURE TO REVIEW ALL INTERNAL DOCUMENTS FOR C/R IDENTIFICATION PF5 JOEP-lb N19 51M10E3F201 SON-DC-V-2.15 ATTACHMENT A NOTES ARE NOT ACTEPTABLE FOR CVCS INJECTION LINES TO MEET GDC 54-57 (NRC-24, obs. 8.2) N20 51L10131001 C/Rs REO IND OF SR FLUX OUTSIDE MCR & THAT ELEC PEN NUST CONFORM TO IEEE 317 OMITTED IN SON-DC-V-27.8 (NRC-28, obs. 4.6) N21 50L1013B021 INADEQUATE AND INCONSISTANT EO REQUIREMENTS IN SON-DC-V-26.1 FOR EXISTING IMPLACE EQUIPMENT (NRC-29, obs. 4.5) N22 50M10113021 C/R RED THAT ENLARGED SPRAY SHIELDS BE INST OVER IGNITER ASSEMB IN HMS WAS OMITTED FROM SON-DC-V-26.1 (NRC-30, obs. 4.4) N23 51L10131001 INADEDUATE INCORPORATION OF C/Rs IN SON-DC-V-2.17 524 51M17110221 PROGRAMMATIC DEFICIENCY EXISTS CONCERNING THE PROPER SPECIFICATION OF MATERIALS & THEIR ASSOCIATED REDMNTS IN DC DOCS N25 5021713C421 IMPROPER ASSIGNMENT OF POTENTIAL C/R SOURCE DOCUMENTS BY IMPELL TO NUC POWER INSTEAD OF NEB N26 51H10133321 SOURCE DOCUMENTS OMITTED FROM WESTINGHOUSE C/R SEARCH N27 51M10120221 C/R IDENTIFIED ON TRACKING SHEETS NOT INCORPORATED INTO SON-DC-V-27.7 N28 51K1013B221 FAILURE TO INCORPORATE C/Rs INTO SON-DC-V-27.5 TEXT AND TO FULLY SPECIFY DESIGN REQUIREMENTS N29 51L10131001 DISCREPANCIES EXISTS BETWEEi1 TECH SPEC LCO 3.4.1.1 AND SOR-DC-V-27.4 FOR RCS 2 LOOP MIN OPERATION CONDITION fobs. 2.5) N30 00DC0211221 INCONSISTENCIES EXIST BETWEEN TABLE 1 *SYS WHICH SUPPORT SAFE SD* OF CALC PKG SON-OSG7-048 R2 & OTHER PARTS OF CALC PKG N31 001COE3F001 PREVIOUS WALKDOWN EVALUATIOPS MUST BE VERIFIED TO MEET REVISED ENLARGED SYSTEM BOUNDARIES IN CALC PKG SON-OSG7-040R2 N32 004C0411001 FAILURE TO ADDRESS FUEL GEOMETRY REQUIREMENTS IN CALC. SOK-OS(T1-048 N33 301E7B25401 ECM DRCs CONTAINED *NOT ADDRESSED

• RESPONSES BUT PIR NUMBER WAS NOT PROVIDED WHICH VIOLATES SOEP-12 N34 308E1G11001 ELECTRICAL CHECKLIST DOES NOT PROVIDE ADE00 ATE REPLACEMENT COMPONENT INFORMATION FOR ELECTRICAL EDUIPMENT CHANGEDUTS N35 308EOG30001 ECN 2707 COVER SHEET DID NOT INDICATE SEISMIC ANALYSIS OR ELEC INVOLVEMENT & CHECKLIST DID NOT MEET SOEP-12 REDMNTS N36 30VF083D011 INADEDUATE DOCUMENTATION BY SE PREPARER & REVIEWER 05 FCN FORM AND TRAINING OF PERSONNEL NEEDS VERIFICATION N37 311C0211021 SUPPORTING CALC FOR ECM 6549 USED WBN SPECIFIC CALC TO CONCLUDE THAT CNTNT LOCA-DBA FLOOD LEVEL WILL NOT SUBMERGE JBs N38 302E7G20220 ECN 5779 DRC CONTAIEED FOTENTIAL INADEDUACIES, WITH THE EVALUATION & REVIEW OF UHI DWGS TO DEPICT THE SYSTEM BOUNDARIES N39 50L17123221 IMPROPER INCORPORATION OF SUPERCEDED COMMITMENTS IN SON-DC-V-27.2 N40 301EOG30201 INADE00 ATE ECM 5600 PACKAGE & SOEP-12 CHECKLIST FOR MOVING SUMP LEVEL SENSOR BELLOWS FROM INSIDE TO OUTSIDE CNTNNT WALL N41 304F0421201 FAILURE TO REVISE FSAR DWG UPON FCN IMPLEMENTATION N42 314E7G07220 EVAL OF ECN L5371 DVERLOOKED NEED TOR FSAR REVISION & LACK OF FINAL APPROVAL OF FCR 501 & HAS MUNEROUS CHECKLIST DISCREP M43 50L10123221 FAllURE TO INCORPORATE C/R FOR DIVERSE HI PRESSURE INTERLOCKS IN SON-DC-V-27.6.

N44 304E0C07221 UNIMPLEMENTED STATUS OF ECN L5323 FOR CHARCOAL CANISTER REPLACEMENT NOT ADEDUATELY ADDRESSED IN SOEP-12 CHECKLIST N45 30743535320 LOCATION OF DESIGN FRESSURE & TEMP BREAKS INCORRECTLY NARKED ON FLOW DIAGRAM (NRC 54, obs. 2.7) > N46 304C0231021 LACK OF JUSTIFICATION IN PRESSURE DROP CALC. EPM-SMJ-022886 USED TO SUPPORT ECM L6673 (NRC 56, obs. 2.6) aq N47 31740532220 PIPING ELEVATION IN SECT JS-J5 ON 47W560-5 DOES NOT AGREE WITH PLAN VIEW & MAY NOT REP AS-BUILT CONF (NCR 57, obs. 2.7) N48 303E0E3F001 IMPROPER DELETION OF SAFETY-RELATED FUNCTION BY ECN L6076 (NRC 58). 'o !' N49 60G77815421 SOEP-16 HAS NO PROVISIONS FOR ALLOWING CHANGES AND MODIFICATIONS TO ISSUED SYSTERs  ?,y w

NUCLEAR (1100) ACTION ITEN TREND

50. CODFS DESCRIPTION M50 60AL7714421

• EXCEPTIONS
• ARE NOT BEING PROPERLY OR CONSISTANTLY INCORFORATED INTO SYSTERe N51 60NL7B15401 INPROPER REVIEW OF CUNULATIVE EFFECTS OF UNINPLEMENTED CHANCES IN SYSTERe M52 60G17725421 NO ROLE IN SOEP-45 R1 FOR SE TO APPROVE RESOLUTION & STATUS OF PUNCHLIST ITEMS AGAINST HIS/NER SYSTER 553 60AL7725421 RESTART INDICATIONS ARE INCORRECT FOR PUNCHLIST ITEMS FOR SYSTER 02 & SYSTER DID NOT ADDRESS RELATD PUNCMLIST ITDIS '

M54 602L7B15401 VARIOUS & NUNEROUS DEFICIENCIES IN SYSTER 83 FOR THE. COMBUSTIBLE GAS CONTROL STSTEN N55 602L3711221 SYSTER 61 FDR ICE COND STS INADEDUATELT ADDRESSES NUNEROUS FCRs/ECNe/SCRs & IS INCONSISTENT WITH PUNCIN.IST M56 602L7E30401 OPEN FCRs ARE BEING EXCLUDED FROM SYSTERe PER DBVP-D-06-005 - N57 60ALOB15511 PUNCHLIST CHANCES NOT COORDINATED WITH APPLICABLE SE AND ITFNS NOT FROCESSED FOR COMPLETENESS /TINELINESS M58 6 NL DEFICIENCIES EXIST IN SON UNIT 2 PHASE I DBVP REPORT _B A

2. e

_ =--

OPERATIONS (6100) ACTION ITEM TREND NO. CODES DESCRIPTION 001 101B5618001 NECHANICAL COMPONENT DATA SHEET NOT INCLUDED IN WDP-70 TO RECORD VALVE NAMEPLATE DAT 002 109B5615001 INCONSISTENCY IN FILLING OUT NECH CONP DATA SHEET FOR WDP-70 FOR THE PRESENCE OF A YELLO 003 10BBSE11011 WDP-70 CONTAINNENT PENETRATION DATA SHEETS DO NOT CONTAIN INITIALS & DATES FOR EACH PENETRATION 004 107B3B14001 *INFORMATION ONLY" AND WALKDOWN LRAWINGS IN WDP-3B WERE NOT SIGNED BY THE PREPARER AND/OR CHEC 005 10X42A3E031 AFW PRESSURE TRANSNITTERS LABELS A2E REVERSED & DOC OF TRANSMITTER / LOOP1.4,6.4) ALIGNMENT & F 104B5B11301 WDP DID NOT IDENTIFY AS-BUILT DWG DISCREP FOR PIPE SIZE & TEAN EID NOT DOC ALL DIFFERENCES OBSERVED (NRC-2,obs. 006 WDPs CONTAIN INC0dSISTENT PNL LOCATIONS, INCORRECT SKETCHES & NO RECORD FOR STEAM LEAK 0FF LINES (NRC-3,obs. 2.1,3.1 007 10XB7615421 (NRC-4) 10FB7E3F201 CONCERNS AS TO EXTENT, USE, AND REASON FOR AS-DESIGNED DRAWINGS IN WDPs 008 DIFFERENCES BETWEEN SYSTEN AND WALKDOWN sOUNDARIES WERE NOT DOCUMENTED & JUSTIFIED (NRC-7,obs. 1.2) 009 104B7B11401 10175035621 CRITERIA POR SFLECTING EA TEAN WALKIOWNS WAS NOT DOCUMENTED IN OPERATIONS DISCIPLINE REVIEW PLAN (NRC-9,obs. 4.3) (NRC-11) 010 011 30G77825421 ASSESSMENT OF THE ADE00ACY OF SCOPE & DIRECTION FOR DBSV PROGRAN IS HAMPERED BY DELAY IN ISSUING SO 012 103BSE32001 EA TEAN USED *AS-DESIGNED

• DRAWINGS INSTEAD OF *AS4%)NSTRUCTED* DRAWINGS FOR INDEPENDENT WALKD 013 10XCSE3F301 OPERATIO2S INPUT TO DBSV PROGRAN SCOPE NAY NOT FULLY CAPTURE THE REOUIREMENTS OF E0Is AND SOIs (obs WASTE DISPOSAL SYS CONTAINXENT BOUNDARY PENETR4 TION X-46 IS NOT SHOWS ON DRAWING FOR WDP-77 (NRC-16, obs. 7.1) 014 10745E3F001 1.2)

DIFFERENCES EXIST DETWEEN THE Ut & U2 WD BOUNDARIES WITH JUSTIFICATION NOT PROVIDED IN THE WDP (NRC-13, obs. 015 104B5625021 10XBSE3F301 NO PROCEDDCES TO REDUIRE REVIEW OF WIU'DOWN DATA FOR ASSESSXENT OF POTENTI AL INFACT ON OPERATIONS 42C-14, obs.1.1 016 017 51410114121 RATIONAL FOR DESICE CRITERIA ON EllR SUNP LINE ISO VALVES & POST ACCIDENT ISO VALVES NOT UNIFORELY 51417114121 SON-DC-V-2.15 DOES NOT CONTAIN REFERENCES TO NUREG-1.63, SON-DC-V-11.3 AND SON-DC-V-12.2 FOR CONTNNT ELEC PENETRAT 018 019 11NBSD25401 ARHOURED CABLES ON CSS PUXP RENGTE OPERFED VFNT OPERATOR SUSTAIN EXCESSIVE BENDING AND DO NOT OPE 10X85B34550 NONORAIL CRANES & HOISTS SHOULD NOT BE 2ARKED OVER SAFETY EQUIPHENT,e.g.,NONORAIL HOIST PARKED DVER 2B-B PUNP CDUPL 020 GUIDELINES NOT EST FOR CONSISTANCY IN THE COLLECTION OF NP DATA FOR EQUIP HOD OR REPLD SINCE OL (NRC-34, obs. 1.4 & 2.2) 021 10GBSE3F211 022 10JB1614201 PROJECT NEEDS TO VERIFY THAT SINGLE LINE CR7Ds ARE BEING REVIEWED BY A STA FOR DRAWING DEVIATION 023 30TDSE31201 POST-NAINTENANCE TESTING OF FLOW CONTROL VALVES PER SI-166 & TI-69 IS NOT BEING PERFORNED 024 6 4L PUNCHLIST CLOSED WITHOUT COMPLETING CORRECTIVE ACTION SPECIFIED IK SYSTER EN 4 ;:l U

QUALITT LSSURANCE (7100)  ! ACTION ITEM TREND NO. CODES DESCRIPTION 001 104B5624321 SYSTEM WALKDOWN PACKAGE NO. S0-DR-86-06-135R NOT PERFORMED AND DOCUMENTED PER SMI-0-317-030 002 1D(186512220 003 30G86825211 DEFIC 67-138 IN WDP-67 FOR ERCW IDENTIFIES DIAPHRAGM VALVE AS CATE VALVE (DISCREPANCY REPORT NO. 50-DR-WO7-140R) 004 100B6512121 SOA-103 DESCRIBES A CCB DECISION CLASSIFICATION FOR MOD AS " CANCELLED

• BUT DOES NOT RECOGNIZE A DNE APPEAL PROCESS 005 50117413401 WR/MR NOT REFERENCED IN WDP FOR HISSING / INCORRECT ID TAGS IT19 AFW & ERC" S7 STEMS (DISCREPARCY REPORT NO. S0-DR-LACI 0F ASSURANCE THAT ALL C/Rs, INCLUDING NSSS/ VENDOR REQUIREMENTS, ARE CAPTURED IN.THE C/R DATA BASE (NRC 38) 006 10A75815311 007 6 6L6 SOME MAINTENANCE PROCEDURES ARE NOT SUBJECTED TO PORC REVIEW & SOME ARE YOT REVIEWED & UPDATED AS REQUIRED (NRC 008 30X85B18211 DISACREEMENT EXIST BETWN SYSTER DOCS & ATTACH 4 0F SON RESTART SCHEDULE CHANGE DOC RECARDING RESTART STATUS O 009 3 G7 CHANGE CONTROL BOARD IS NOT DOCUMENTING MODIFICATION CANELLATIONS OR DEFERRALS OF DCRs AS REOUIRED BY SO4183 ADDITIONAL CLARIFICATION SHOULD BE INCORPORATED IN THE NEXT REVISION TO SOEP-13 010 60!L7F31221 DRAFT SON U2 DBVP PH I REPORT DOES NOT ADDR C/As RED TO MEET DBVP OBJECTIVES & DOES NOT ADDR ALL ECNs, FCRs & NCRs/SCRs 011 3 C9 '

012 5 01 SOEP-13 NEEDS EXISTING WAIVER CLAUSE REMOVED & PROJECT NEIDS A TARGET DATE FOR FULL IMPLEMENTATION DCN CRIT, CALCS, & FSAR ON SAFETY RELATED STS NOT BEING MAINT PER REOMbTS OF TVA TOPICAL REPORT, SEC 17.1 & 10CTR 50.71 013 6 NL PUNCHLIST ITEMS ARE BEING IDENTIFIED WITHOUT PERSONNEL ISSUINC CAOS WHEN APPROPRIATE

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                         . APPENDIX D-Paga 13 of 13 '

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CIVIL /STRUCTUSAL (5100) LISTING OF ALL EVALUATED ACTION ITEMS ACTION ITEM TREND NO. CCDES DESCRIPTICN 10355518101 INCCMPLETE TRAN3FER 0F INFORMATION FROM MASTER WALKDOWN DRAWING TO COPY IN WDPs FOR MS,HPFP, & FAP C01 CO2 302E7314401 INAPPROPRIATE SEQUENCE FOR ELIMINATING AN ECN FROM FURTHER REVIEW BY MARKING NO INSTEAD OF SYS C04 10FB5B2502) ATTRIBUTES M & N 0F ATTACHMENT 5 0F SOEE-08 NOT INCLUDED IN SMI-0-317-30 C05 50214124201 AUX SUILDING 4607 TRANSFORMER ROOM TORNADO MISSILE PROTICTION NCT CAPTURED IN C/R TRACKING SYST C06 50117123421 CCKMITTMENT IN LETTER A27820301032 TO NRC FOR AFW PIPING LESIGN CRITERIA WAS NOT CAFTLRED IN THE 3.2 C/R&LATA 3.3) BASE REDUCTION OF MARGINS IN FSAR NEEDS LICENSING ACTION S C/R TRACKING NEEDS TO BE ADDRESSED (NRC-21, obs. C07 53114B25221 C06 ?O1G4G16021 ECN 2971 WAS NOT IDENTIFIED ON NCR/SCR IDENTIFICATION FORM Si SDE FOR ANALYSIS SY SYS ENGR C09 302G4G18001 SCR/NCR IDFNTIFICATION FORM INCORRECTLY SHOWS SCRCEB8404 AS CLOSED AND IMPLEMENTED C11 50214138121 DESIGN CRITERIA CN ELEC RACEWAYS WAS NOT CHECKED ON C/R FORM & ALL APPLICABLE SUBJECTS WERE NOT IDE C12 50214E2C001 NCRCEB8210 FOR DESIGN OF MISC STEEL ATTACHMENTS WAS NOT CAPTURED IN C/R DATA BASE C13 304C423:021

SUMMARY

PIPING ANALYSIS CALC FKG FOR EVAL OF ECN L-5724 CONTAINS UNVERIFIED ASSUMPTION FOR OPERATI febs. E.33 C14 50M14333221 EFFFCT OF ADDED WEIGHT OF CASLES IN TRAYS AT EXIT POINTS ON SEISMIC ANALYSIS NOT CONSIDERED IN SON-DC-V-1.3.4 (NRC-23,obs 3.41 Cle 51L14113321 PIFE STRESS CONSIDERATIONS FOR STIFF CLAMFS & PIPE SLEEVE LUG RESTRAINTS NOT ADDRESSED IN SON-DC-V-24.1 51L14124321 GDC EXCLULES C/R FOR DRILLED ANCHORS & FAILED TO CAPTURE C/R FOR THRU-WALL BOLTS IN MSNRY WALLS (NRC-31, obs. 7.2 & 7.3) C17 C16 51L14114 32! DB DOC DOES NOT CA?TURE ALL S2E?-29 REOMTS & APP F 0F THE 0A MANUAL FOR SEISMIC OUAL OF MECH & ELEC COMP C19 306E4513021 CIVIL AND ARCH DWGS IN ECN L6300 SHOW CONFLICTING REQUIREMENTS FOR CONC CURBS UNDER ARCH DGORS & AR C20 50317120421 C/R RE0VIRING SEALED OR ENCLOSED TERMINAL BLOCKS INSIDE CONTAINMENT WAS MISSED IN IMPELL REVIEW OF NCREEB C22 303C4E30001 U2 ANAL OF CONT SPRAY TEST LINE FOR ECN L5268 JUSTIFIED AS OPPOSITE HAND OF UI BUT ROUTING CONFIGURATIONS DI C23 30GE732C450 ECN L5298 INCORRECTLY EXCLUDED FROM SOEP-12 TECHNICAL REVIEW C24 50217128401 C/R FOR FSAR TABLE 3.2.1-1 NOT CAPTURED & PP0 JECT DISCIPLINE INTERFACES INADE0UATE TO CAPTURE GENERIC C/Rs C25 304E4G11321 JUSTIFICATION FOR CALCULATION MODIFICATION NOT PROPERLY DOCUMENTED THROUGH USE OF A RIMS NUMBER C2e 51114124321 C/R PARTIALLY CAPTURED IN APPENDIX F DESIGN CR!TERIA FOR SEISMIC AND DBA LOADS ON ELECTRICAL AND MECHANI C29 302E4E31201 INSUFFICIENT CAPTURE OF ECNs CONCERNING STEEL CO.1TAINMENT VESSEL AND OTHER PRESSURE BOUNLARY COMPONENTS C30 314E4G38020 ECN L5451 DRC ITEM 6.1 ATTACH 2A REFERENCES COMPONENT OUAL MEMO BUT ITEM 6.2 STATES THAT PIPING ANALYSIS C32 30SE4G1E001 ADDITIONAL SUPPORT DRAWINGS FOR ECN L6196 ARE NOT LISTED WITH REFERENCED CALCULATIONS ON CIVIL CHECKLIST C33 311J4212001 CALCULATIONS FOR SUPPOPTS 2-H36-72 & 2-H36-105 HAVE NOT BEEN REVISED TO INCORPORATE FCR 3963 C34 30174B35411 SOEP-12 CHECKLIST PREPARATION GUIDANCE REVIEW INADEQUATE FOR ECNs 2548 AND 5970 DUE TO UNCLEAR REQUIREMENTS C35 300E7G04421 CEB CHECKLIST NOT PREPARED FOR ECN 2120 AND GENERIC IMPLICATIONS NOT TDENTIFIED AND ADDRESSED C3A 201E7G04421 ECN EVALUATION DID NOT CONSIDER FIR, SE MODIFIED CIVIL CHECKLIST WITHOUT SDE GK, AND CHECKLIST WAS NOT READASLE C38 301G7:21411 NCR CEB8404R1 IDENT FORM DOES NOT DOCUMENT TECHNICAL .TUSTIFICATION FOR CORRECTIVE ACTION WHICH VIOLATES SOEP-11 C39 306E4G30220 ECN L6439 DATA SHEET DOES NOT ADDRESS ALL APPLICABLE DRAWINGS THAT CALCULATIONS WERE PERFORMED ON FOR CUT RES C42 304E4911301 TECHNICAL JUSTIFICATION AND EVALUATION NOT PROVIDED FOR ECN L6263 AS WELL AS CHECKLIST ITEM 6.4L C43 303E4G34121 ECN L5779 SOEP-12 REVIEW IDENTIFIED DESCREPANCIES WITH SOEP-12 CHECKLIST, CIVIL CHECKLIST AND ECN DATA SHEET C45 302J4G14221 SDE REVIEW OF ECN L6604 FOR CATEGORY D FcR 4093 DID NOT RECOGNIZE POTENTIAL IMPLICATIONS ON ALL RESTART SYSTEMS C46 50L14B3F251 ANCHOR PT MOVEMENT NOT ADDR IN DSGN CRIT & CABLE IkAY SUPPORT DSGN DOES NOT ADDR PT LOADS (NRC 44, obe. 8.1, 8.3, & 8.4) C43 30304221021 CNTMT PENETRATION LEA'K TEST ANAL DOES NOT ADDR BOUNDING CASE OF PIPE CANTILEVERED MAX DIS FROM HEAD PL (NRC 48, OBS.3.6) C49 301E4520021 ECN L6556 DOES NOT PROVIDE BOLT SIZES & MAT SPECS FOR LIMIT SWITCH MOUNTING PLATE OR SEIS OUAL FOR BRACKETS & BOLTS C50 32704512221 NRC AUDIT OF ECN L6479 IDENT DISCREPANCIES BETW PIPING LAYOUT SHOWN ON ISOMETRIC & PHYSICAL PIPING DWG (NRC 50, obs.3.5) C51 301E4220221 TECHNICAL REVIEW OF ECN L6487 DID NOT ADDRESS PIPING CALCULATION & FSAR DISCREPANCIES CS2 30744510021 NRC AUDIT OF ECN LS274 IDENTIFIED DISCREPANCIES BETWEEN RHR PIPING SHOWN ON ISOMETRIC & PHYSICAL DWG (NRC 52, obo. 3.9) C58 601L4E3:011 JUSTIFICATION IN SYSTER 72 FOR NCRCEB820S DOES NOT ADLRESS THE FULL EXTENT OF CEB REVIEW OF CLOSELY SPACED ANCHORS 2%

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ELECTRICAL (2100) j ACTION ITEM TREND NO. CODES DESCRIPTION Eel 196B7824421 LACK OF DOCUMENTATION FOR REDUCING WALIDOWN BOUNDARY ON CRADs TROM SWIBDs' (WDP-67R1)

E02 10NB7232021 CALC PKG DOES NOT ADDRESS MEANING OF CROSS-HATCHED AREAS OF SYS BOUNDARY ON SWBIDs AND CRADs E04 10NB7824421 OVERALL SYS BOUNDARY AND BORIC INJECTION BYPASS LINE WAS OMITTED FROM CRAD 08 WDP-63 WHICH VIOLATES SOEP-08 EOS 309E7B14201 FRE-OL ECN LISTED ON ECN IDENTIFICATION FORM BUT NOT OS M E OWIL WHICH VIOLATES SEOP-11 E06 30NE7B20221 ECNS L5864, LS867, L5880 ARE IDENT AS AFFECTING SYS 201/202 INSTEAD OF VP & AP SYS WHICH VIOLATES SOEP-114 E07 30F71815221 GUIDELINES INADEO IN SOEP-12 TO ENSURE THAT ALL NEEDED ELEC DIST SYS ARE ADDR IN REVIEW OF ECN CHECK LIST ITEN Sb E08 003C023E001 120VAC PREF & 250VDC PWR SYS, RAD MON, SMPL & FP TWR DIST SYS WERE INCORRLY LISTED IN SYS B0UND CALC PKG AS VP SYS E09 301G7G14421 WRITTEN JUSTIFICATION NOT PROVIDED BY SDE's FOR "IMPL" CATEGORY SCR/NCRs WHICH VIOLATES SOEP-11 E11 50A87334011 TRAINING OF SENIOR PEOPLE TO SOEP-18 WAS DONE TO C/R HANDBOOK BEFORE PROCEDURE ISSUANCE E12 5121111C221 C/R DATA SHEETS HAVE NOT BEE 1 PREPARED FOR LICENSING COMMITMENTS WHICH VIOLATES SEOP-18 E13 51M17B33401 . SOEP-18 ATTACHMENT I DOES NOT' LIST TEDERAL, STATE AND LOCAL PERMITS EIS 30AG7B14401 SDE's SUBMITTED SCR/NCR IDENT FORMS TO REVIEWER BEFORE RECEIVING ALL TNP" DOCUMENTATION WHICH VIOLATES SOEP-11 E16 50111133221 SON DESIGN CRITERIA SON-DC-V-11.3 & SON-DC-V-12.2 WERE Nui INCLUDED IN LIST OF RESTART ELEC CRITERIA E17 30G77E31401 ECN CHECKLIST 00ESTIONS WERE DELETED FROM SECT C OF SOEP-12 REVISION 1 (obs. 5.2i . E18 302G1G34021 INSUFFICIENT DOCUMENTATION WAS PROVIDED TO ENSURE THAT CORRECTIVE ACTIONS FOR SONEEB811321 WERE "IMPL* BY ONP E20 SeL17125421 LACK OF CLARITY IN SOEP-29R0 INVOLVING USE OF NEP-3.2 FOR PREPARATION OF DESIGN CRITERIA E21 50M17123421 C/Rs WERE OMITTED FROM DG & AUX SYS, 125V VITAL BATT SYS 6 120V AC VP SYS EESIGN CRITERIA E22 51L17114101 C/Rs FOR DG & AUX SYS, 125 VITAL BATT SYS & 120 AC VP SYS WERE OMITTED FROM ATTACH 2 C/R D3 TRACKING SHEETS E23 50M17123420 CABLE REOMNTS NOT ADDR & CABLE DSGN CRIT NOT REF IN DC CONT PWR SYS, FIFTH VITAL BATT SYS 6 DG & AUX SYS DSGN CRIT E24 50M11130021 VITAL BATTERY MINIMUM TERMINAL VOLTAGE AT DESIGN DISCHARGE STATE WAS NOT SPECIFIED IN SON-DC-V-II .2 E27 311E1G10321 ECN L6544 CHECKLIST DOES NOT REFER TO FSAR, TECH SPECS & DESIGN CRITERIA FOR APPLICABLE ITEMS E28 51L11121221 ELEC DESIGN C/Rs WERE OMITTED FROM DESIGN CRITERIA & C/R DB TRACKING SHEET FOR AUX POWER DC SON-DC-V-11.4.1 E29 51M11123321 AUX. POWER CRITERIA SON-DC-V-11.4.1 DID NOT CAPTURE ALL APPLICABLE C/Rs (NRC-25, obs. 5.5) E30 50L11131021 SON-DC-V-11.4.1 DOES NOT ADDR CABLE CAP FOR CONT OVERLOADS LESS THAN MOTOR BKR PROT RELAY TRIP SETTINGS (NRC-26,cbs.5.63 E32 309E1C25001 E33 DOCUMENTATION DOES NOT EXIST IN ECN L6015 FKG TO ANS OUEST Sa & Se & CAO NOT ISSUED FOR TRACKING FUR (VIOLATES SOEP-12) 40G71815321 PROCEDURE USED BY ESES TO ASSEM, EVAL & DOCUMENT TEST DATA DOES NOT AGREE WITH SOEP-14 REQUIREMENTS (obs. 5.3) E34 40B71B14211 INDEPENDENT REVIEW OF ELEC TEST EVALUATION FOR ECN L5017 PKG WAS NOT PERFORMED WHICH VIOLATES NEP-5.2 & SOEP-14 E35 302E1E3C001 APPENDIX R SHUTDOWN LOGIC CALC'S ARE NOT DOCUMENTED IN ECN L6544 CHECKLIST AS BEING REVIEWED OR AFFECTED BY THE ECN E36 409ElB21321 VERIF NOT PROVIDED THAT TRAINED IMPELL PERS ASSIGNED 'N/A* CAT OR APPROP ENG BR/NU PWR RESP TO SOURCE DOC"MENTS E37 40TD1921221 SUPPORTING ENG JUSTIFICATION FOR ECNs 2633 & L5114 TEST REVIEW PKG DO NOT ADDRESS PURPOSE OF TEST EVALUATION E38 40RDIC20001 ECN L5114 TEST REVIEW PKG CONTAINED INSUFFICIENT SUPPORT INFO TO JUSTIFY THE EVALUATION CONCLUSION E39 51L11133001 E40 IEEE 279 & FSAR C/R FOR CONT SPRAY SYS HAVE NOT BEEN ADEOUATELY ADDRESSED IN SYS DESIGN CRITERIA SON-DC-V-27.5R0 51M11134001 C/R FOR MOV CONTROL & INDICATION FEATURES REF ON PRINTOUTS F0F RHR & RCS SYS BUT NOT IN SON-DC-V-27.6 6 27.4 E41 308EIG11011 ECN L5114 ELEC DRC CONTAINS MINOR ERRORS & DOES NOT ADDRESS SEISMIC OLAL OF ELEC COMPONENTS E42 301E7G10421 ECN L5114 DRC CONTAINS OMISSIONS & WAS EVALUATED USING THE WRONG DESIGN CRITERIA E43 50A17B04221 LACK OF TRAINING OF WESTINGHOUSE DESIGN CRITERIA PREPARERS TO SOEP-24 E45 304EIG03320 ECN L5451 DRC ITEM B.3.6 EVALUATION WAS BASED ON MB 0F MATERIAL WHICH DOES NOT VERIFY DESIGN CRITERIA RE;MNT E46 301EIG10320 ECN L5451 DRC ITEMS B.3.d&g & B.S.a&b REF WRONG CALC PKG, ' ITEM B.5.c CONT INADEO RESP, & ITEM B.S.e DID SOT SPECIFY PIR E47 300M043Ce01 , USOD FOR ECN L5451 REDUCES.THE SCOPE OF THE ECN AND DOES NOT ADDRESS THE 125VDC LUBE OIL IMP THAT WAS A;DED BY ECE E48 301ElG10001 E49 313ElB11011 ECN L5451 DRC WAS INCORRECTLY EVALUATED SINCE CHANGES TO 125V DC DG DIST PD WERE NOT INCLUDED IN FIELD WALKDOWN ECN L5872 DRC CONTAINS TECHNICAL ERRORS INVOLVING ECN COVER SHEET, FSAR, LOGIC IIAG, FLOW DI AG & I-TABS E52 303ElG11021 ECN L5872 DRC CONTAINS TECH ERRORS INVOLVING SYS MON CIRCUITS, REF FLOW DIAG INSTEAD OF SCH, & REF WRONG PAND SWITCHES E54 304E1G00301 ECN 2945 DRC REF WRONG LSGN CRIT REV, EVAL TO SYS 31 CHECKLIST, REF CALCS THAT USED UNVERIFIED ASSUF & CNEA MIN 3? DISC E56 403D1314251' E58 30PMIF30011 SOEP-1421 SECT 3.6 RE0MNT WAS VIOLATED IN RED-LINE FKG SINCE AS-DSGN DWG WAS USED FOR AS-CONST DWG TO CCMH PE PRE USOD FOR ECN L6015 MISIDENTIFIED ELEC 10 VIP BEING MODIFIED U$ DER ICN AS SAFETY EELATED .og ES9 303E1G01321 ECN LS872 DEC DID NOT REF DESIGN CRITERIA REV, REF WRONG CALC PKG, & DID NOT REF REDUND, DIVERSITY & SEP RECMsis S E60 40TDIC21001 E61 301EIG00321 ECN L5599 TRP LACKS JUSTIF TO SUPPORT CONC THAT RESOLUTION TO UPEN ITEMS IS NOT REO FOR RESTART & SCOP LOC RET W ECN L6667 DRC INAPPROP REF BM & STD DWGS, DOES NOT REF EXISTING CALCS, CONTAINS DISC IN ITEM 7 & REVIEWERS NAME ILLEGBLE *h E62 309EIG24021 50EP-11 ATTACH 1 FOR ECN 5449 INCORRECTLY STATED ECE ONLY INVOLVES AP SYS SUT ECN ALSO INVOLVES VP SYS N* E

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ELECTRICAL Gles) ACTION ITEM TREND NO. CODES DESCRIPTION E63 ?00M1F31001 US0D FOR ECN L5449 DOES NOT ADDR LOSS OF VOLT RELAYING LOGIC & INDICATES OVERVOLT SEOP-14 DOES NOT IDENT WHO AFPROVES

• RETEST
• TEST RESULTS, WHO EST " RETEST
• ACCEPT CRIT & WHO PERF & PA Et ? J 0C71825221 E68 M1F30001 US0D FOR ECN L6S73 DOES NOT ADDR DECR TRIPPING TIME OF NOR FDR SKR FOR 6900V SHDN B E70 . SOEPs 14 & 26 DO NOT PROVIDE METHOD TO DOCUMENT THE
• FUNCTIONAL" BASIS FOR SAF

        . cN'JGD7E3B401 SON-DC-V-11.3R5 CONTAINS ENVIR COND THAT ARE OUTDATED & DO NOT AGREE WITH INVIR COND ISSUED BY SON E0P (

E71 50L1111C021 302E1G00321 ECN L6533 DRC DOES NOT SUBSTANTIATE THAT CHANGES HAVE BEEN ADDR IN PROGRAMS OUTSIDE THE DBVP (NRC 42, obs. 5.8) E73 302E123A221 CALC PKG OSG7-038 DID NOT ADDR ECNs L5944 & L6459 (NRC SS, obs. 6.11) E76 E7 40RD1410021 ECN L5298 TEST REVIEW PACKAGE RETEST SCCPING DOCUMENT INCORRECTLY REFERENCED SMI-2A IN TEST C^ 401E1410021 ECN L5363 ELEC TEST REVIEW PKG TUNCT TEST RESULTS DO NOT ADEO DOCUMENT THAT MODIFIE 'EB1 601L1714221 TECHNICAL JUSTIFICATION NOT PROVIDED FOR SWBID AREAS NOT WALKED DOWN & AS CONSTRUCTE E62 609L1731001 ECN L6746 NOT CAPTURED IN SOEP-12 REVIEW OR IN THE SYSTER EVALUATION WHICH CONFLICTS WITH S E84 612L1738001 INTERLOCK FOR NORMAL CHARGER FEEDERBREAKERS TO VITAL BATTERY BDS & LC RELAY FOR STH E86 613L1731121 CRAD 45N709-2 RL HAS CABLE IDENTIFICATION IROBLEM & VITAL INVERTER NAMEPLATE DATA IS IN CO E5 w0 0Y e

INSTRUMENTATION AND CONTROL (3100) ACTION ITEM TREND NO. CODES DESCRIPTION 101 107B5618001 IDENTIFICATION OF COMPONENT 2-SI-46-56B WAS NOT ACCURATELY TRANSFERRED TO MASTER IN COMPLETED WD FACKAGE IO2 196B5618001 WDP FIELD DWG MARKED COMPCNENT WITH MISSING ID TAG AS

• ITEM l' & MASTER COPY WAS NOT SIMILARLY MARKED 103 10GB2835321 WALKDOWN PERSONNEL DID NOT INCLUDE VERIFICATION CF HANDSWITCHES IN CCMPLETED WDP Ist 304E2C25021 ECN L5038 LRC STATES THAT ITEMS leb & 10e ARE APPLICABLE & TECH ADEOUATE & OUALIFIES THIS BY A FUTURE HUMAN FACTORS PROG 106 10935E3F001 DETAIL SKETCH OF PANEL 2-L-381 IS NOT REF ON WDP-46 SUM SHEET & DNE AGREEMENT NOT PROVIDED WHICH VIOLATES SMI-0-317-30 107 10647B3B001 LACK OF R~ VALVE NUMBERING AND PIPING INTERFACE NOTATION ON FUCTIONAL CONTROL DRAWINGS (NRC-6) 188 101B2623321 METHOD DC ' NOT EXIST FOR EVAL RE0 ELEC & I & C SYS INFORMATION THAT IS NOT OBTAINED FROM WALKDOWN (NRC-10, obs.5.1&6.3) 109 51N1743B401 THE EFFECT OF RG 1.97 ON THE DBVP HAS NOT BEEN IDENTIFIED (NRC-15,obe. 6.1) 110 50212F28001 TVA RESPONSE TO NRC IEB 65-03 CONTAINS C/Rs TO INVESTIGATE, TEST, & MAINTAIN MOV SETTINGS SUT WAS NOT CAPTURED IN C/R DB Ill 50212123021 C/R IN NUREG 011 SER, SUPPLEMENT 5 ITEM II.F.2, REQUIRING BACKUP EISPLAY FOR INCORE TEMP WAS NOT CAPTURED IN C/R DB I12 50212B23321 RESPONSE FOR TVA MEMO CONCERNS NRC IE INF NOTICE 65-100, ROSMOUNT DIFF IRESS TRANS ZERO PT SHIFT, IS NOT COMPLETE 113 50M12123220 SON-DC-V-32.0 REF IEEE 323-1971 INSTEAD OF 323-1974 & DOES NOT ADIR SYS SETPOINT RE0MNTS (NRC-32, obs 6.5, 6.6, & 6.7) 114 51L12133221 SINGLE FAILURE CRITERIA TERMINOLOGY IN DESIGN CRITERIA SON-DC-V-2.16 NEEDS CLARIFICATION (NRC-33,obs. 6.8) 115 50N17431201 C/R DEFINING THE ABILITY OF FLOW INSTRUMENTS TO INDICATE SYS FAILURES IS NOT DOCUMENTED IN C/R DB I16 50212E3F001 C/R INVOLVING PROCESS CONT SYS, CHAN ACCURACY & SETPOINT TOLERANCE IS NOT DOCUMENTED IN C/R DB 117 50M12133201 TVA LETTER ON METEORLOGICAL MONITORING SYS FEATURES & ADD EMER RESPONSE ORG STAFFING COMMITMENT CAT AS "N/A" BY IMPILL 118 50A12114301 C/Rs INVOLVING ISC CHANNEL LIST HAVE MISSING ATTACHMENTS AND MAY NOT BE IN C/R DB I19 50217123221 WESTINGHOUSE LETTER TVA-898 DID NOT IDENTIFY ALL APPLICABLE REACTOR CONT & PROT SYS FUNCTIONAL REQUIREMENTS AS C/Rs I20 50M12431001 C/R RE0VIRING REPLACEMENT OF 20-200 SEC RANGE RELAY WITH 3 SEC RANCE RELAY IS NOT IDENTIFIED IN DESIGN CRITERIA l 121 30AE7B35411 ECN L6359 DRC DOES NOT PROVIDE ADE00 ATE ASSURANCE THAT SEISMIC OUALIFICATION OF LEVEL SWITCHES WILL BE EVALUATED l 122 301E2G01321 ECN L6359 DRC CONTAINS CONFLICTING & INCOMP ASSESSMFNTS OF SETPOINT ACC & SETPOINT MARG FOR REPLACEMENT LEVEL SWITCHES 123 311E2G10320 ECN L5791 DRC REF TO SON-DC-V-4.2 AS BASIS FOR "ADDR* CAT BUT LEVEL SETPOINT MOD BY ECN IS NOT ADDR NOR REF BY DSGN CRIT I24 311E2G10320 ECN L5791 DRC REFERS TO ECN WORKPLAN AS BASIS FOR ADDR SETPOINTS BUT WORKPLAN IS GERMANE TO ECN WHICH VIOLATES SOEP-12 125 302E7320401 ECN L5884 DRC ITEM 6a IS MARKED AS *ADDR* BUT DOES NGT PROVIDE ASSURANCE THAT COMPONENTS WILL BE SEISMICALLY EVALUATED I26 301E7C2C421 ECN L5884 DRC CONTAINS TWO ITEMS WHICH ARE *NOT ADDR* BUT CAO WAS NOT ISSUED TO RESOLVE OR TRACK THESE ITEMS I27 301E2G21221 ECN L6404 RECOGNIZES LACK OF SEISMIC OUAL FOR REPLMNT SW ON FCV-63-72 BUT DOES NOT REF TO CAO FOR RESOLUTION & TRACKING 128 301E2G00321 ECN L6254 DRC DOES NOT REFERENCE REQUIRED SETPOINT CALCULATIONS 129 306E2G00320 ECN L6254 DRC DOES NOT CONTAIN ADEOUATE ASSESSMENT OF TECHNICAL REQUIREMENT OF SON-DC-V-13.9.8 130 304E2G04221 ECN L6254 DOES NOT CONTAIN ADEOUATE ASSESSMENTS OF SETPOINT ACCURACY & MARGINS FOR FRESSURE SWITCHES DESCRISED IN ECW I31 302E7G25420 ECN L5600 COVER SHEET IND NO INVOLVEMENT BY CIVIL DISC BUT USOD IND THAT FIELD MOD WA' REVIEWED AND AFP BY CIVIL DISC I32 40TD2E31201 ECN L6175 PRESSURE SWITCH RECALIBRATION TEST RESULTS LACK REFERENCE TO METHODOLOGY I33 304E2G07321 ECN L6124 DRC DOES NOT CONTAIN ADEOUATE ASSESSMENT OF TIME DELAY SETPOINTS FOR SWITCHES DESCRIBED IN ECN I34 304E2G07321 ECN L6124 TIME DELAY SETPOINT CALCULATIONS NOT REFERENCED IN ECN FACKAGE 135 3074251C020 ECN L6124 DATA SHEET DID NOT REFLECT ALL NECESSARY DRAWING CHANGES FOR MODIFICATION I36 303E2G21221 ECN L5275 DRC DOES NOT PROVIDE JUSTIFIED CONCLUSION THAT BIT RECIRC ROTOMETER 15 NOT REOUIRED FOR RESTART I37 311E7G2B401 ECN L5275 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 2f, 3f 5 leh 138 311E2E21411 ECN L5275 DRC DOES NOT PROVIDE JUSTIFIED CONCLUSION FOR CATEGORIZING ITEMS 1, 2a, 2b, Oc, 7a, 8b, Bd.& 10b AS *NOT ADDR*

139 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 10a & 10b I40 301E2G31221 ECN L5734 DRC EVALUATION FROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 64 & 6b I41 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEM 7a 142 301E2G31221 ECN L5734 DRC DID NOT REFERENCE THE PRIMARY di3 TEM DESICS CRITERIA AS JUSTIFICATION FOR ITEM 1 CONCLU5 ION I43 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 10e 6 lad I44 30XE5E16001 WP 11916 LISTS TEMP SWITCH "REO VALUES" WITH */-5 DEG F TOL W/0 REF TO DSGN BASIS FOR JUSTIFICATION (NRC 35,obs. 6.10s I45 1:XN591E031 FC-30-149 HAD MISSING COVER AND DAMAGED FLEX CCND BUT WAS NOT TACCED TO INDICATE CONDITION HAD BEEN DOCUMENTED (NRC 36) I46 40RD5D23221 FAILURE TO PERIODICALLY TEST TIME EELAY RELAYS PER IEEE 338-1977 REQUIREMENTS (NRC 47, obs. 6.15) , 147 314E2B38001 PERFORMANCE OF PRESS SW REPLACED BY ECN L6374 CANNOT BE VERIFIED SINCE SOURCE DOCUMENTATION IS INCOMPL (NRC 53,obs.6.13) jl; h I49 601L2738011 DISCREPANCY BETWEEN COMMITTMENT FOR LOGIC DIAGRAM CHANGE PER ECN L5765 & CORRESFONDING FL ITEM *g ISO 604L2731021 ECN L5831 WAS LISTED AS POST RESTART BASED 03 ADEO OF EXISTING EQUIP BUT EXISTING EQUIP IS NOT ADEO FOR SAFETY FUNCTION *T 151 602L2714021 NCRs/SCRs AFFECTING PRIMARY WATER SYSTEM HAVE NOT EEEN IDENTIFIED OR EVALUATED PER SOEP-16 o, ]

INSTRUMENTATION AND CONTROL (3100) ACTION ITEM TREND No. CODES LESCRIPTION I52 602L273te22 JU37IF FOR NCRSONSW?b202R1 ADLR THE TECH ACCEPT OF RELIEF FATH ISOLATION VALVE SUT IOES NOT ALDR RAD MON RE-90-118 IS3 60AL3718221 WDP-81 DOES NOT INCLUDE NAMEPLATE DATA FOR MECHANICAL COMPONENTS AS REQUIRED BY WALKDOWN SCOPE 158 612L232421. NCi< MEB840S EVAL DOES NOT CONTAIN JUSTIF FOR LACK OF AUTO CONT INDICATION IN MCR DURING F ARTI AL BYPASS OF SAFETY SYSTEMS l l l l l

)'

O m

MECHANICAL (41N) ACTION ITEM TREND No. CODES DESCRIPTION Mai 106B5625221 AS-BUILT DRAWING DISCREPANCIES NOT TRANSFERRED TO MASIER WALKDOWN COPY &

SUMMARY

SHEET NOT PROVIDED M22 10Bb5625221 OC SIGNOFF AND VERIFICATION WAS ACCOMPLISHED ONLY BY HIGHLITE & RED LINES & PROCEDURES DID NOT INDICATE A CA DOCUMENT M03 10GB7E25411 WDP-15 INDIVIDUAL 6 1/2 X 11 SHEETS NOT DESIGNATED 4 NIT 2 AS APPOSED TO UNIT 1 DUE TO PROCEDURAL DEFICIENCY MO4 101B3223221 DBVP HAS NOT DOCUMENTED RATIONALE FOR THE INCLUSION OF ALL PROGRAM SCOPED ITEMS MO5 19745514101 WDP-72

SUMMARY

SHEET ATTACHMENT DOES NOT REFERENCE

SUMMARY

SHEET & WDP JASTER DWG N0h. CONFLICTS WITH

SUMMARY

SHEET M06 30F77B25421 PROCEDURES DO NOT ADDRESS ECN REVIEW FOR TECHNICAL ADEQUACY OF DRAWINGS & CALCULATIONS WHICH VIOLATES SOEP-12 M07 51213125421 SOEP-16RO DOES NOT ADDRESS HANDLING OF C/Rs IDENTIFIED AFTER C/R DATA BASE CLOSURE M08 106B3635021 RHR WDP DISCREPANCY CONCERNING RCS EQUIP NOT REPORTED TO WDP-72 PERSONNEL FOR PROPER INTERFACE ON MASTER DWG (NRC-22) M09 303G3G38011 SCR NEB 8520 WAS INCORRECTLY CLASSTFIED AS *0 PEN

• INSTEAD OF "0NP* IN ACCORDANCE WITH SOEP-11 M10 60JL7B25401 SOEP-16 DOES NOT ADDRESS SYSTEM INTERFACE & REVIEW RESPONSIBILITIES fobs. 1.3)

, M11 51213123221 THERMAL LOAD RANGE C/R FOR PIPING DSGN & ANAL, ERCW INTERFALE REO, 6 MIN TEMP REO NOT ADEQUATELY CAPTURED IN AFW DC M12 50213133221 ATW & AUX AIR C/R FCR LOSS OF AC POWER NOT ADDRESSED ADE00ATEL4 IN DESIGN CRITERIA FOR CRITICAL TIME REQUIREMENTS M13 51M1313B001 C/R FOR MINIMIZING CAVITATION OF ERCW THROTTLE VALVES NOT CAPTURED IN C/R DATA BASE OR DESIGN CRITERIA M14 50217124421 C/R DATA SHEETS ARE INCOMPLETE & IMPROPERLY FILLED OUT CAUSING INCOMPLETE CAPTURE OF DSGN RE0MNTS IN DSGN CRIT (obs.5.4) MIS 51M13113321 DESIGN CRITERIA DOES NOT ADDRESS TEMPERATURE & PRESSURE STRESSES FOR SUPPORT DESIGN & STRESS ANALYSIS M16 50L1313B021 DSGN CRIT DOES NOT STATE REG GUIDE 1.29 EXCEPTIONS, SOEP-11 LICENSING COMMITMENTS NOT CAPTURED, & HPFP C/R NOT CAFTURED l AFW DEFICIENCIES RELATED TO SYS INTERFACE, MISSING C/Rs, SHOP TEST REQUIREMENT, & DESIGN REQUIREMENT FOR AFWP NPSH l M17 51J1312E121 M18 50M1313B221 DESIGN CRITERIA DID NOT REFERENCE NPSH VALVES FOR THERMAL BARRIER BOOSTER PUMPS M19 301E7G13221 DRC FOR ECN 2945 DOES NOT ADDRESS ITEMS FOR WDP & HYDRAULIC, STRUCTURAL, AND MECHANICAL DESIGN CRITERIA M20 301E3E31011 ECN 2445 DRC HAS MISSING DOCUMENTATION & PIRs HAVE NOT BEEN ISSUED FOR TPACKING PURPOSES WHICH VIOLATES SOEP-12 M21 306E7G25221 ECN L6665 DRC HAS TWO SEPARATE AND POSSIBLY CONFLICTING VERSIONS M22 51K10B3D211 C/R FOR WESTINGHOUSE PROPRIETARY INFORMATION MAY NOT BE INCORPORATED INTO DESIGN CRITERIA (NRC-27, obe. 2 1) l M23 301E7G25421 ECN L6665 DRC DOES NOT PROVIDE REFERENCE FOR ITEM 3.6 & 6.a AND VENDOR INFO 2MATION NOT RETRIEVABLE M24 50H17113421 SON-DC-V-7.4 CONTAINS THREE APPENDIXEC LISTING DOCS THAT CONTAIN COMMITMENTS & REOMNTS NOT INC INTO TEXT OF DSGN CRIT  ; I M25 301E7G25421 ECN L5095 DRC JUSTIFICATION AND ASSOCIATE REFERENCES NOT CAPTURED FOR SYSTEM DESIGN TEMPERATURE AND PRESSUPE M26 50L13E33001 SON-DC-V-13.9.9 MAY NOT LIST ALL APPLICABLE INDUSTRY CODES AND STANDARDS M27 301E7B21421 ECN L5095 DPC DOES NOT REF PIR WRITTEN FOR JUSTIFICATION OF CHANGE TO PIPING RIGOROUS ANALYSIS WHICH VIOLATES SOEP-12 M28 50M13113021 C/R FOR SIS COLD LEG PARAMETERS FOR DESIGN OF COLD LEG ACCUMULATORS WAS NOT CAPTURED fobe. 5.4) M29 51213123221 C/R FOR ERCW COMPONENT COOLING SYS *C" HEAD EXCHANGER DISCHARGE VALVE 0-TCV-b7-152 NOT INCORFORATED IN C/R DB BY IMPELL M31 50217124221 SOURCE DOCUMENTS NOT INCORPORATED 08 C/R DATA SHEETS & IN DESIGN CRITERIA FOR SIS & RHR SYSTEMS (obs. 5.4) H 32 311E3427221 ECN L5064 DRC ITEM B.2.b WAS INCORRECTLY REVIEWED RESULTING IN INVALID CCN?LUSIONS & EVAL WAS NOT IROPERLY SIGNED SY SEs M34 304M3B25201 INCORRECT USE OF USOD FOR ECN L5095 TO JUSTIFY SEIS OUAL OF REPLACEMENT OF BLIND FLANGE WITH SECOND VALVE,NIFPLE, & CAP M36 31113123221 ECN 5769 DRC DOES NOT REF MFW 3A DC SON-LC-V-4.2 IN RESPONSE TO QUEST 3.1 & LOES NOT REF ASME CODE REOMNTS IN ITEM E2.C M37 301E343C001 SOEP-11 ECN ID FORM DOES NOT ASSIGN ECN L5681 TO SYS 67 FOR EVAL OF THE EFFECT OF ACA AIR COMPRESSUR CHANGE ON ERCW SYS M38 300M0F23320 USOD FOR Eck L5681 DOES NOT DOCUMENT VENDOR RECOMMENDATIONS 6 SEISMIC ANALYSIS WAS NOT PlaF0FMED OR DOCbMENTED M39 304E3G26020 ECN L5681 DRC DOES NOT APPROPRI ATELY ADDRESS SEISMIC ANALYSIS, OPERABILITY & HYDR AULIC IESIGN M41 302E4G30000 ECN L6103 CIVIL CHECKLIST DOES NOT ADDRESS TUEE OUALIFICATION FOR PORV ISCLATION VALVES M42 301E3G31021 ECN L6501 CHECKLIST DOES NOT ADDRESS ECN JUSTIFICATION FOR REFERENCED CALCULATIONS M44 309E3507001 ECNs 5714 & 6103 NOT REVIEWED BY ENGINEER TRAINED TO SOEP-11 M45 51003036001 FSAR DOES NOT REFLECT CCS DESIGN CRITERIA (NRC 37, obs. 2.41 M48 6 4L4 10 RATIONALE FOR NO BLOWCUT PANELS IN CO2 STORAGE ROOM OF THE DGB IS NOT ADEOUATELY ADDRESSED IN SYSTER 82 M49 60GL3E3F001 PUNCHLIST ITEMS ARE PEING CLOSED BEFORE DA COMPLETES REVIEW OF FIELD WORK 1 2%

                                                                                                                                             %?
                                                                                                                                             *N OM M

c - . NUCLEAR (1100) ACTION ITEM TREND NO. COLES DFSCRIPTION N01 004CO211221 JUSTIFICATION INADED IN CALCS FOR ABSENCE OF FSAR CHAPT 15 IBAs & EVAL FOR OFFSITE RADIATION NOT DOCUMENTED (obs.4.1) NO2 004C0231221 SAFETY FUNCTICN IDENTIFICATION WOT SYSTEMATICALLY IDENTIFIED IN CALCULATION PACKAGE SON-OSG7-048 NO3 00DC0210201 CONTAINMENT PENETRATIONS AND ASSOCIATED ISOLATION VALVES CMITTED FROM BOU CARY DRAWINGS IN CALCULATION PKG SON-OSG7-e48 N04 004C0411301 LACK CF JUSTIFICATION FOR BOUNDARY SELECTION IN CALCULATION PACKAGE SON-OSG7-048 N05 005C023E221 SYSTEM BOUNDARY DWG IN CALC PKG SON-OSG7-048 HAS INCONSISTANT BOUNDARY MARKINGS AND REO VS NOT REO AREA DESIGNATIONS N06 00YC0211221 MISCELLANEOUS ERRORS, OMISSIONS, AND INCONSISTENCIES IN CALCULATION PACKAGE SON-OSG7-048 N07 50G77835421 LACK OF TVA PROCEDURE FOR LICENSING COMMITMENTS REVIEW ACTIVITY N08 50N10931201 NRC OUESTIONS WHETHER TECHNICAL SPECIFICATIONS ARE BEING CONSIDERED FOR INPUT TO LICENSING COMMITMENT LIST (NRC-1) N09 004C0211221 JUSTIFICATION NOT PROVIDED FOR INCLUSION / EXCLUSION OF ALL SYSTEMS FOR CHAPTER 15 ACCIDENTS IN CALCS (NRC-8,obs. 4.11 N10 50210330020 OUALIFICATION OF THE EXCORE NUCLEAR INSTRUMENTATION FOR ROD EJECTION ACCIDENT IS IN OUESTION (NRC-19, obs. 6.2) N11 00DC023B221 SCOPE DEFINITIONS FROM RPS AND NMS NOT CONSISTENT WITH OTHER SYSTEM BOUNDARIES (NRC-20, obs. 4.2) N12 e02COE3i001 TMI COMMITMENTS NOT FROPERLY SCOPED FOR SYSTEM BOUNDARY DETERMINATIONS AND DESIGN BASELINE VERIFICATION PROGRAM (NRC-12) N13 50G77835421. IMPELL LICENSING REVIEW CF DSGN CRIT DEVELOPMENT WAS NOT INDEPENDENTLY VERIFIED FOR CAPTURE OF ALL C/Rs (NRC-17,obs.5.4) N14 302E7B31201 POTENTIAL INTERACTIONS NOT CONSIDERED IN ROUTING OF ECNs PER SOEP-11 l N15 309G4B14/01 SCR/NCR PWP8303 CORRECTIVE ACTION WAS FOUND INADEO & A NEW CAO WAS NOT ISSUED TO READDRESS FINDINGS BY SDE PER SOEP-11 N17 50L10133121 FAILURE TO INCORPORATE C/Rs INTO DESIGN CRITERIA TEXT AND TO SPECIFY ALL INTERFACE REQUIREMENTS PER SOEP-29 l l N18 50210434301 FAILURE TO REVIEW ALL INTERNAL DOCUMENTS FOR C/R IDENTIFICATION PER SOEP-18

,     N19    51M10E3F201  SON-DC-V-2.15 ATTACHMENT A NOTES ARE NOT ACCEPTABLE FOR CVCS INJECTION LINES TO MEET GDC 54-57 (NRC-24, obs. 8.2)

N20 51L10131001 C/Rs REO IND OF SR FLUX OUTSIDE MCR & THAT ELEC PEN MUST CONFORM TO IEEE 317 OMITTED IN SON-DC-V-27.8 (NRC-28, obs. 4.6) l N21 50L10133021 INADEOUATE AND INCONSISTANT EO REQUIREMENTS IN SON-DC-V-26.1 FOR EXISTING INPLACE EQUIPMENT (NRC-29, obs. 4.5) N22 50M10113021 C/R RE0 THAT ENLARGED SPRAY SHIELDS EE INST OVER IGNITER ASSEMB IN HMS WAS CMITTED FROM SON-DC-V-26.1 (NRC-30, obs. 4.4) N23 51L10131001 IN ADEOUATE INC0FPC2ATION OF C/Rs IN SON-DC-V-2.17 N24 51M17110221 PROGRAMMATIC DEFICIENCY EXISTS CONCERNING THE PROPER SPECIFICATION OF MATERIALS & THEIR ASSOCIATED REOMNTS IN DC DOCS N25 5021713C421 IMPROPER ASSIGNMENT OF POTENTIAL C/R SOURCE DOCUMENTS BY IMEELL TO NUC POWER INSTEAD OF NEB N26 51H10133321 SOURCE DOCUMENTS OMITTED FROM WESTINGHOUSE C/R SEARCH N27 51M10120221 C/R IDENTIFIED ON TRACKING SHEETS NOT INCORPORATED INTO SON-DC-V-27.7 N28 51K10133221 FAILURE TO INCORPORATE C/Rs INTO SON-DC-V-27.5 TEXT AND TO FULLY SPECIFY DESIGN REQUIREMENTS N29 51L10131001 DISCREPANCIES EXISTS BETWEEN TECH SPEC LCO 3.4.1.1 AND SON-DC-V-27.4 FOR RCS 2 LOOP MIN OPERATION CONDITION (obs. 2.5) N30 00DC0211221 INCONSISTENCIES EXIST BETWEEN TABLE 1 "SYS WHICH SUPPORT SAFE SD* OF CALC PKG SON-OSG7-048 R2 & OTHER PARTS OF CALC PKG N31 001COE3F001 FREVIOUS WALKDOWN EVALUATIONS MUST BE VERIFIED TO MEET REVISED ENLARGED SYSTEM BOUNDARIES IN CALC PKG SON-OSG7-048R2 N32 004C0411001 FAILURE TO ADLRESS FUEL GEOMETRY REQUIREMENTS IN CALC. SON-OSG7-046 N33 301E7B25401 ECN DRCs CONTAINED "NOT ADDRESSED" RESPONSES BUT PIR NUMBER WAS NOT PROVIDED WHICH VIOLATES SOEP-12 N34 308EIG11001 ELECTRICAL CHECKLIST DOES NOT PROVIDE ADEOUATE REFLACEMENT COMPONENT INFORMATION FOR ELECTRICAL EQUIFMENT CHANGE 00TS N35 308EOG30001 ECN 2707 COVER SHEET DID NOT INDICATE SEISMIC ANALYSIS OR ELEC INVOLVEMENT & CHECKLIST DID NOT MEET SOEP-12 REDMNTS N36 30VF0B3?011 INADEOUATE DOCUMENTATION BY SE PREPARER & REVIEWER ON FCN FORM AND TRAIhING OF PERSONNEL NEEDS VERIFICATION N37 311C0211021 SUPPORTING CALC FOR ECN 6549 USED WBN SPECIFIC CALC TO CONCLUDE THAT CNTMT LOCA-DBA FLOOD LEVEL WILL NOT SUBMERGE JBs N40 301E0G30201 INADE00 ATE ECN 5600 PACKAGE & SOEP-12 CHECKLIST FOR MOVING SUMP LEVEL SENSOR BELLOWS FROM INSIDE TO OUTSIDE CNTMNT WALL N41 304F0421201 FAILURE TO REVISE FSAR DWG UPON FCN IMPLEMENTATION N42 314E7G07220 EVAL OF ECN L5371 OVERLOOKED NEED FOR FSAR REVISION 6 LACK OF FINAL APPROVAL OF FCR 501 & HAS NUMEROUS CHECKLIST DISCREP N44 304E0G07221 UNIMPLEMENTED STATUS OF ECN L5323 (OR CHARCOAL CANISTER REPLACEMENT NOT ADEOUATELY ADDRESSED IN SOEP-12 CHECKLIST N45 30743535320 LOCATION OF DESIGN PRESSURE & TEMP BREAKS INCORRECTLY MARKED ON FLOW DIAGRAM (NRC 54, obs. 2.7) N46 304CO231021 LACK OF JUSTIFICATION IN PRESSURE DROP CALC. EPM-SMJ-022386 USED TO SUPPORT ECN L6673 (NRC 56, obs. 2.6) N47 31740532220 PIFING ELEVATION IN SECT J5-J5 ON 47W560-5 DOES NOT AGREE WITH PLAN VIEW & MAY NOT REP AS-BUILT CONF (NCR 57, obs. 2.7) N49 60G77815421 SUEP-16 HAS NO PROVISIONS FOR ALLOWING CHANGES AND MODIFICATIONS TO ISSUED SYSTERs N50 60AL771442t " EXCEPTIONS" ARE NGT BEING PROPERLY OR CONSISTANTLY INCORPORATED INTO SYSTERs y 2l; N52 60G77725421 NO RJLE IN S0!P-45 R1 FOR SE TO AFPROVE RESOLUTION & STATUS OF PUNCHLIST ITEMS AGAINST HIS/HER SYSTER qg N53 60AL7725421 RESTART INDICATIONS ARE INCORRECT FOR PUNCHLIST ITEMS FOR SYSTER 82 & SYSTER DID NOT ADDRESS RELATED PUNCHLIST ITEMS yg N54 602L7B15401 VARIOUS & NUMEROUS DEFICIENCIES IN SYSTER 83 FOR THE COMBUSTIBLE GAS CONTROL SYSTEM ep a N57 60ALOB15511 PUNCHLIST CHANGES NOT COORDINATED WITH APPLICABLE SE AND ITEMS NOT PROCESSED FOR COMPLETENESS / TIMELINESS m o

OPERATIONS (6100) ACTION ITEM TREND No. CODES TESCRIPTION 001 10lb5616001 MECHANICAL COMPUNENT DATA SHEET NOT INCLUDED IN WDP-70 TO RECORD VALVE NAMEPLATE DATA NEEDED DURING SYSTEN EVALUATION 002 109B5615001 INCONSISTENCY IN FILLING OUT MECH COMP DATA SHEET FOR WDP-70 FOR TH', FRESENCE OF A YELLOW CAUTION TAG ON MCV BREAKERS 003 19335E11011 WDP-70 CONTAINMENT PENETRATION DATA SHEETS DO NOT CONTAIN INITIALS & DATE3 FOR EACH FENETRATION 004 107h3314001 *INFORMATION ONLY" AND WALKDOWN DRAWINGS IN WDP-33 WERE NOT SIGNED BY THE PREPARER AND/OR CHECIER 005 10X42A3E031 AFW FRESSURE TRANSMITTERS LABELS ARE REVERSED & DOC OF TRANSMITTER / LOOP ALIGNMENT & FUNCTION IS NOT PROVIDED (obs 1.1) 006 10435b11301 WDP DID NOT IDENTIFY AS-BUILT DWG DISCREP FOR FIPE S12E & TEAM DID NOT DOC ALL DIFTERENCES OBSERVED (NRC-2,obs. 1.4,6.4) 007 10XB7615421 WDPs CONTAIN INCONSISTENT PNL LOCATIONS, INCORRECT SKETGES & NO RECORD FOR STEAM LEAKOFF LINES (NRC-3,cbr. 2.1,3.1,6.3) 008 10FB7EiF201 CONCERh5 AS TO EXTENT, USE, AND REASON FOR AS-DESIGNED DRAWINGS IN WDPs (NkC-4) 009 104B7311401 DIFFERENCES BETWEEN SYSTEM AND WALKDOWN BOUNDARIES WERE NOT DOCUMENTED & JUSTIFIED (NRC-7,obs. 1.2) 010 10175P35021 CRITERIA FOR SELECTING EA TEAM WALKDGWNS WAS NOT DOCUMENTED IN GPERATIONS DISCIPLINE REVIEW PLAN (NRC-9,cbs. 4.3) 011 30G77625421 ASSESSMENT OF THE ADEC'J ACY CF SCOPE & DIRECTION FOR DB4V FadRAM IS HAMPEAED BY DELAY IN ISSUING SCEPs (NRC-11) l 012 103B5E30001 EA TEAM USED *AS-DESIGNED

• DRAWINGS INSTEAD OF PAS-CONSTRUCTED
• DRAWINGS FGR INDETENDENT WALKT0WN (NRC-5) 013 10XCSE3F301 OPERATION 3 INPUT TO DB6V FROGRAM SC0FE MAY NOT FULLY CAPTURE THE REOUIREMENTS OF LOIs AND S0Is (obs. 4.1) 014 10745E3F001 WASTE DISPOSAL SYS CONTAINMENT BOUNDARY PENETRATION X-46 IS NOT SHOWN ON LRAWING FOR WIP-77 (NRC-16, obs. 7.1) 015 104B5625021 DIFFERENCES EXIST BETWEEN THE U1 & U2 WD BOUNDARIES WITH JUSTIFICATION NOT PROVIDED IN THE WDP (NRC-13, obs. 1.2) l 016 10XB5E3F301 NO PROCEDURES TO REQUIRE REVIEW OF WALKDOWN DATA FOR ASSESSMENT OF POTENTI AL IMPACT ON OPERATIONS (NRC-14, obs.1.1) 1 017 51410114121 RATIONAL FOR DESIGN CRITERIA CN RHR SUMP LINE ISO VALVES & FOST ACCIDENT ISO VALVES NOT UNIFORMLY CAPTURED 018 51417114121 SON-DC-V-2.15 DOES NOT CONTAIN REFERENCES TO NUREG-1.63, SON-DC-V-11.3 AND SON-DC-V-12.2 FOR CONTMNT ELEC FINETRATIONS 019 11NB5D25401 ARMOURED CABLES CN CSS IUPP REMOTE OPERATED VENT OPERATOR SUSTAIN EXCESSIVE PENDING AND I0 NOT OPERATE FREELY 020 10XB5B34550 MONORAIL CRANES &. HOISTS SHOULD NOT PE PARKED OVER SAFETY EQUIPMENT,e.g., MONORAIL HOIST FARKED OVER 2B-B PUMP COUPLING 021 10GB5E3F211 GUIDELINES NOT EST FOR CON 3ISTANCY IN THE COLLECTION OF NP DATA FOR EQUIP MOD OR REPLD SINCE OL (NRC-34, obs. 1.4 & 2.2) 022 103B1614201 PROJECT NEEDS TO VERIFY THAT SINGLE LINE CRADs ARE BEING REVIEWED BY A STA FOR DRAWING DEVIATIONS PER SNI-0-317-30 023 30TD5E31201 POST-MAINTENANCE TESTING OF FLOW CONTROL VALVES FER SI-166 & TI-69 IS NOT LEING PERFORMED 2%

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QUALITY ASSURADCE (7100)

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ACTION ITEM TEEND NO, CODE 3 DESCRIPTICN 001 10435624321 SYSTEM WALKDOWN IACKAGE NO. $0-DR-86-f6-135R NOT PERFORMED AND DOCUMENTED FER SMI-0-317-03J 002 20036512223 DEFIC 67-138 IN WDP-67 FOR ERCW IDENTIFIES DIAPHRAGM VALVE AS GATE VALVE (DISCREPANCY REFORT NO. S0-DR-86 003 30G86825211 SOA-183 DESCRI5ES A CCS DECISICP CLASSIFICATION FOR MOD AS " CANCELLED" BUT DOES NOT RECOGNIZZ A DNE APPEA 004 20036512121 WR/MR NOT REFERENCED ININCLUDING WDP FOR MISSING / INCORRECT ID TAGS FOR AFW & ERCW SYSTEMS (DISCREPANCY REPO NSSS/ VENDOR REGUIREMENTS, ARE CAPTCRED IN THE C/R DATA BASE (NRC 38) 005 501274134J1 LACK OF ASSURANCE THAT ALL C/Rs, 006 10A75815311 SOME MAINTENANCE PROCEDURES ARE NOT SUBJECTED TO PORC REVIEW & SOME ARE NOT PEVIEWED & UPvATED AS REQ 003 3JX85318211 CHANGE CONTPCL E0ARD IS NOT DOCUMENTING MODIFICATION CANELLATIONS CR DEFERRALS OF DCRs AS REQUIRED BY SOA183 l l l 5k

                                                                                                                                          ,oM OY M

1 1

EVALUATED FINDINGS BASIS FOR DESIGN NOT DOCUMENTED FINDING TYPE SUBCATEGORY a ACTION ITEM TREND NO. CODES DESCRIPTION C26 51114124321 C/R FARTIALLY CAPTURED IN APPENDIX F DESIGN CRITERIA FOR SEISMIC AND DBA LOADS ON ELECTRICAL AND C33 311J4211001 CALCULATIONS FOR SUPPORTS 2-H36-72 & 2-H36-105 HAVE NOT BEEN REVISED TO INCORPORATE FCR 3963 C34 30174335411 SOEP-12 CHECKLIST PREPARATION GUIDANCE REVIEW INADE00 ATE FOR ECNs 2548 AND 5970 DUE TO UNCLEAR REQ 301E7'104421 ECN EVALUATION DID NOT CONSIDER FIR, SE MODIFIED CIVIL CHECKLIST WITHOUT SDE OK, AND CHECKLIST WAS NOT READABLE C36 C38 301G7E21411 NCR CE58404R1 IDENT FORM DOES NOT DOCUMENT TECHNICAL JUSTIFICATION FOR CORRECTIVE ACTION WHICH C49 301E4520021 ECN 06556 DCES NOT PROVICE BOLT SIZES & MAT SPECS FOR LIMIT SWITCH MOUNTING PLATE OR SEIS OUAL FOR C51 301E4220221 TECHNICAL REVIEW OF ECN L6487 DID NOT ADDRESS PIPING CALCULATION & FSAR DISCREPANCIES C58 601L4E31011 JUSTIFICATION IN SYSTER 72 TOR NCRCEB8205 DOES NOT ADDRESS THE FULL EXTENT OF CEB REVIEW OF CLOSELY S E09 301G7G14421 WRITTEN JUSTIFICATION NOT PROVIDED BY SDE's FOR "IMPL" CATEGORY SCR/NCRs WHICH VIOLATES SCEP-11 E16 S0111133221 SON DESIGN CRITERIA SON-DC-V-11.3 & SON-DC-V-12.2 WERE NOT INCLUDLD IN LIST OF RESTART ELEC CRITERIA 311E1G10321 ECN L6544 CHECKLIST DOES NOT REFER TO FSAR, TECH SPECS & DESIGN CRITERIA FOR APPLICABLE ITEMS E27 E42 301E7G10421 ECN LS114 ERC CONTAINS OMISSIONS & WAS EVALUATED USING THE WRONG DESIGN CRITERIA 301EIC10320 ECS L5451 DRC ITEMS B.3.d&g & B.5.a&b REF WRONG CALC PKG, ITEM B.S.c CONT INADEO RESP, & ITEM B.S.e DID NOT SPECIFY PIR E46 E48 301EIG10301 ECN L5451 DRC WAS INCORRECTLY EVALUATED SINCE CHANGES TO 125V DC DG DIST BD WERE NOT INCLUDED IN FI 301EIG00321 ECN L6667 DRC INAPPROP REF PM & STD DWCS, DOES NOT REF EXISTING CALCS, CONTAINS DISC IN ITEM 7 & REVIEWERS NAME ILLEGB E61 E79 401E1410021 ECN L5363 ELEC TEST REVIEW PKG FUNCT TEST RESULTS DO NOT ADEO DOCUMENT THAT MODIFIED SAFETY F i E81 601L1714221 TECHNICAL JUSTIFICATION NOT PROVIDED FOR SWBI" AREAS NOT WALKED DOWN & AS CONSTRUCTED INFO l NOT 101B2623321 METHOD DOES NOT EXIST FOR EVAL REO ELEC & I & C SYS INFORMATION THAT IS NOT OBTAINED FROM WALKDOWN (NRC-10, obs.5.1&6.3 108 I22 301E2G01321 ECN L6359 LRC CONTAINS CONFLICTING & INCOMP ASSESSMENTS OF SETPOINT ACC & SETPOINT MARG F 123 311E2G10320 ECN L5791 DRC REF TO SON-DC-V-4.2 AS BASIS FOR "ADDR" (AT BUT LEVEL SETFOINT NOD BY ECN IS NOT ADD 124 311E2G10320 ECN L5791 DRC REFERS TO ECN WORKPLAN AS BASIS FOR ADDR SETPOINTS BUT WORKPLAN IS GERMANE TO 126 301E7G2C421 ECN L5884 DRC CONTAINS TWO ITEMS WHICH ARE *NOT ADDR" BUT CAO WAS NOT ISSUED TO RESOLVE OR TRACK I27 301E2C21221 ECN L6404 RECOGNIZES LACK OF SEISMIC OUAL FOR REPLMNT SW ON FCV-63-72 BUT DOES NOT REF TO C I28 301E2G00321 ICN L6254 DRC DOES NOT REFERENCE REQUIRED SETPOINT CALCULATIONS ECN L5275 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 2f, 3f & 10h I37 311E7G2B401 ECN L5275 DRC DOES NOT PROVIDE JUSTIFIED CONCLUSION FOR CATEGORIZING ITEMS 1, 2a, 2b, 6c, 7a, 8b, 84 & 10b AS *NOT ADDR' I38 311E2E21411 I39 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 10a & 10b I40 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 6a & 6b I41 301E2G31221 ECN L5734 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEM 7a I42 301E2G31221 ECN L5734 DRC DID NOT REFERENCE THE PRIMARY SYSTEM DESIGN CRITERIA AS JUSTIFICATION FOR ITEM 1 CONCL I43 301E2G31221 ECN L5714 DRC EVALUATION PROVIDES INCORRECT & UNJUSTIFIED CONCLUSION FOR ITEMS 10e & 10d I49 601L2738011 DISCREPANCY BETWEEN COMMITTMENT FOR LOGIC DIAGRAM CHANGE PER ECN L576S & CORRESPONDING PL ITEM M04 101B3223221 DBVP HAS NOT DOCUMENTED RATIONALE FOR THE INCLUSION OF ALL PROGRAM SCOPED ITEMS DRC FOR ECW 2945 DOES NOT ADDRESS ITEMS FOR WDP & HYDRAULIC, STRUCTURAL, AND MECHANICAL DESIGN CRITERIA M19 301E7G13221 M20 301E3E31011 ECN 2945 DRC HAS MISSING DOCUMENTATION & PIRs HAVE NOT BEEN ISSUED FOR TRACKING PURPOSES WHICH M23 301E7G25421 ECN L6665 DRC DOES NOT PROVIDE REFERENCE FOR ITEM 3.6 & 6.a AND VENDOR INFORMATION NOT RETRIEVABLE M25 301E7G25421 ECN L5095 DRC JUSTIFICATION AND ASSOCIATE REFERENCES NOT CAPTURED FOR SYSTEM DESIGN TEMPERATURE M27 301E7B21421 ECN L5095 DRC DOES NOT REF PIR WRITTEN FOR JUSTIFICATION OF CHANGE TO PIPING RIGOROUS ANALYSIS M32 311E3427221 ECN L5064 DRC ITEM B.2.b WAS INCORRECTLY REVIEWED RESULTING IN INVALID CONCLUSIONS & EVAL W M36 31113123221 ECM 5769 DRC DOES NOT REF MFW 3A DC SON-DC-V-4.2 IN RESPONSE TO QUEST B.1 & DOES NOT REF ASME M37 301E343C001 SOEP-11 ECW ID FORM DCES NOT ASSIGN ECN L5681 TO SYS 67 FOR EVAL OF THE EFFECT OF ACA AIR COM M42 301E3G31021 ECN L6501 CHECKLIST DOES NOT ADDRESS ECN JUSTIFICATION FOR REFERENCED CALCULATIONS N31 001COE3F001 PREVIOUS WALKDOWN EVALUATIONS MUST BE VERIFIED TO MEET REVISED ENLARGED SYSTEM BOUNDA N33 301E7B25401 ECN DRCs CONTAINED *NOT ADDRESSED

• RESPONSES BUT PIR NUMBER WAS NOT PROVIDED WHICH VIOLATES m> SOEP-12 N37 311CO211021 SUPPORTING CAT C FOR ECN 6549 USED WBN SPECIFIC CALC TO CONCLUDE THAT CNTMT LOCA-DBA $%FLOOD LEVE N40 301EOG30201 INADEOUATE ECN 5600 PACKAGE & SOEP-12 CHECKLIST FOR MOVING SUMP LEVEL SENSOR BELLOWS *g FRO 001 101B5618001 MECHANICAL COMPMENT DATA SHEET NOT INCLUDED IN WDP-70 TO RECORD VALVE NAMEPLATE ~. DATA NEEDE CRITERI A FOR SMCTING EA TEAM WALKDOWNS WAS NOT DOCUMENTED IN OPERATIONS DISCIPLINE REVIEW PLAN (NRC-9,obs. 3 4.3) 010 10175835021 50117413401 LACK OF ASSURA3Ct. NAT ALL C/Re, INCLUDING NSSS/ VENDOR REQUIREMENTS, ARE CAPTURED IN THE C/R DATA BASE (NRC 38) 005

EVALUATED FINDINGS REQUIRED DESIGN FACTOR NOT ANALYIED , FINDING TYPE SUBCATEGORY ACTION ITEM TREND NO. COLES DESCRIPTION CO2 302E7P14401 INAPPROPRIATE SEQUENCE FOR ELIMINATING AN ECN FROM FURTHER REVIEW BY MARKING NO INSTEAD OF SYS 61 ON ECN ID FORM C05 50214124201 AUX BUILDING 480V TRANSFORMER ROOM TORNADO MISSILE PROTECTION NOT CAPTURED IN C/R TRACKING SYSTEM FOR MISSILES C08 302G4G18021 ECN 2971 WAS NOT IDENTIFIED ON NCR/SCR IDENTIFICATION FORM BY SDE FOR ANALYSIS BY SYS ENGR C09 302G4G18001 SCR/NCR IDENTIFICATION FORM INCORRECTLY SHOWS SCRCEB8404 AS CLOSED AND IMPLEMENTED C11 50214138121 DESICN CRITERIA ON ELEC RACEWAYS WAS NOT CHECKED CN C/R FORM & ALL APPLICABLE SUBJECTS WERE NOT IDENTIFIED C12 50214E20001 NCRCEB8210 FOR DESIGN OF MISC STEEL ATTACHMENTS WAS NOT CAPTURED IN C/R DATA BASE C24 50217128401 C/R FOR FSAR TABLE 3.2.1-1 NOT CAPTURED & PROJECT DISCIPLINE INTERFACES INADEOUATE TO CAPTURE GENERIC C/Rs C29 302E4E31201 INSUFFICIENT CAPTURE OF ECNs CONCERNING STEEL CONTAIFMENT VESSEL AND OTHER PRESSURE BOUNDARY COMPONENTS C45 302J4G14221 SDE REVIEW OF ECN L6604 FOR CATEGORY D FCR 4093 DID NOT RECOGNIZE POTENTIAL IMPLICATIONS ON ALL RESTART SYSTEMS E12 5121111C221 C/R DATA SHEETS HAVE NOT BEEN PREPARED FOR LICENSING COMMITMENTS WHICH VIOLATES SEOP-18 E18 302C1G34021 INSUFFICIENT DOCUMENTATION WAS PROVIDED TO ENSURE THAT CORRECTIVE ACTIONS FOR SONEEB8113R1 WERE *IMPL' BY ONP E35 302E1E3C001 APPENDIX R SHUTDOWN LOGIC CALCS ARE NOT DOCUMENTED IN ECN L6544 CHECKLIST AS BEING REVIEWED OR AFFECTED BY THE ECN l E73 302E1G00321 ECN L6533 DRC DOES NOT SUBSTANTIATE THAT CHANGES HAVE BEEN ADDR IN PROGRAMS OUTSIDE THE DBVP (NRC 42, obs. 5.8) E76 302E123A221 CALC PEG DSG7-038 DID NOT ADDR ECNs L5944 & L6459 (NRC 55, obs. 6.11) E84 612L1738001 INTERLOCK FOR NORMAL CHARGER FEEDERBREAKERS TO VITAL BATTERY BDS & LC RELAY FOR STH VITAL BATTERY HAVE NOT BEEN TESTED Il0 50212F20001 TVA RESPONSE TO NRC IEB 85-03 CONTAINS C/Rs TO INVESTIGATE, TEST, & MAINTAIN MOV SETTINGS BUT WAS NOT CAPTURED IN C/R DB Ill 50212123021 C/R IN NUREG 011 SER, SUPPLEMENT 5 ITEM II.F.2, REQUIRING BACKUP DISPLAY FOR INCORE TEMP WAS NOT CAPTURED IN C/R DB 112 50212B23321 RESPONSE FOR TVA MEMO CONCERNS NRC IE INF NOTICE 85-100, ROSMOUNT DIFF PRESS TRANS ZERO PT SHIFT, IS NOT COMPLETE I16 50212E3F001 C/R INVOLVING IROCESS CONT SYS, CHAN ACCURACY & SETPOINT TOLERANCE IS NOT DOCUMENTED IN C/R DB I19 50217123221 WESTINGHOUSE LETTER TVA-898 DID NOT IDENTIFY ALL APPLICABLE REACTOR CONT & PROT SYS FUNCTIONAL REQUIREMENTS AS C/Rs I25 302E7320401 ECN L5884 DRC ITEM 6a IS MARKED AS *ADDR* BUT DOES NOT PROVIDE ASSURANCE THAT COMPCNENTS WILL BE SEISMICALLY EVALUATED 131 302E7G25420 ECN L5600 COVER SHEET IND NO INVOLVEMENT BY CIVIL DISC BUT USOD IND THAT FIELD MOD WAS REVIEWED AND APP BY CIVIL DISC I51 602L2714021 NCRa/SCRs AFFECTING PRIMARY WATER SYSTEM HAVE NOT BEEN IDENTIFIED CR EVALUATED PER SOEP-16 I52 602L2730021 JUSTIF FOR NCRSONSWP8202R1 ADDR THE TECH ACCEPT OF RELIEF PATH ISOLATION VALVE BUT DOES NOT ADDR RAD MON RE-90-118 I58 612L2B24211 NCR MEB8405 EVAL DOES NOT CONTAIN JUSTIF FOR LACK OF AUTO CONT INDICATION IN MCR DURING FARTIAL BYPASS OF SAFETY SYSTEMS M07 51213125421 SOEP-18R0 DOES NOT ADDRESS HANDLING OF C/Rs IDENTIFIED AFTER C/R DATA BASE CLOSURE M11 51213123221 THERMAL LOAD RANGE C/R FOR PIPING DSCN & ANAL, ERCW INTERFACE REO, & MIN TEMP REO NOT ADEOUATELY CAPTURED IN AFW DC M12 50213133221 AFW & AUX AIR C/R FOR LOSS OF AC POWER NOT ADDRESSED ADEOUATELY IN DESIGN CRITERIA FOR CRITICAL TIME REQUIREMENTS M14 50217124421 C/R DATA SHEETS ARE INCOMPLETE & IMPROPERLY FILLED OUT CAUSING INCOMPLETE CAPTURE OF DSGN REOMNTS IN DSGN CRIT (obs.5.4) M29 51213123221 C/R FOR ERCW COMPONENT COOLING SYS *C' HEAD EXCHANGER DISCHARGE VALVE 0-FCV-67-152 NOT INCORPORATED IN C/R DB BY IMPELL M31 50217124221 SOURCE DOCUMENTS NOT INCORPORATED ON C/R DATA SHEETS & IN DESIGN CRITERIA FOR SIS & RHR SYSTEMS (obs. 5.4) M41 302E4G30000 ECN L6103 CIVIL CHECKLIST DOES NOT ADDRESS TUBE QUALIFICATION FOR PORV ISOLATION VALVES NIO 50210330020 OUALIFICATION OF THE EXCORE NUCLEAR INSTRUMENTATION FOR ROD EJECTION ACCIDENT IS IN 00ESTION (NRC-19, obs. 6.2) N12 002COE3F001 TMI COMMITMENTS NOT FROPERLY SCOPED FCR SYSTEM BOUNDARY DETERMINATIONS AND DESIGN BASELINE VERIFICATION PROCRAM (NRC-12) N14 302E7B31201 POTENTIAL INTERACTIONS NOT CONSIDERED IN ROUTING OF ECNs FER SOEP-11  ; N18 50210434301 FAILURE TO REVIEW ALL INTERNAL DOCUMENTS FOR C/R IDENTIFICATION PER SOEP-18 I l N25 5021713C421 IMPROPER ASSIGNMENT OF POTENTIAL C/R SOURCE DOCUMENTS BY IMPELL TO NUC POWER INSTEAD OF NEB N54 602L7B15401 VARIOUS & NUMEROUS DEFICIENCIES IN SYSTER 83 FOR THE COMBUSTIBLE GAS CONTROL SYSTEM o> Y

                                                                                                                                               '2 1

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EVALUATED FINDINGS NO BASIS FOR DESIGN INPUT /ASSLYPTION FINDING TYPE SUBCATEGORY ACTION ITEM TREND NO. CO ES DESCRIPTION Cl3 .'.04231021 SLMMARY PIPING ANALYSIS CALC PKG FOR EVAL OF ECN L-5724 CONTAINS UNVERIFIED ASSUMPTION FOR OPERATIONAL VIBRATION LOADS CI*; AE4G11321 JUSTIFICATION FOR CALCULATION MODIFICATION NOT PROPERLY DOCUMENTED THROUGH USE OF A RIMS NUMBER C30 3'4E4G38020 ECN L5451 DRC ITEM 6.1 ATTACH 2A REFERENCES COMPONENT GUAL MEM0 BUT ITEM 6.2 STATES THAT PIPING ANALYSIS IS NOT REQUIRED C42 30 Td311301 TECHNICAL JUSTIFICATION AND EVALUATION NOT PROVIDED FOR ECN L6263 AS WELL AS CHECKLIST ITEM 6.4L E45 30" 4G03320 ECK L5451 DRC ITEM B.3.6 EVALUATION WAS BASED ON MB 0F MATERIAL WHICH DOES NOT VERIFY DESIGN CRITERIA REOMNT E54 304EIG00301 ECN 2945 DEC REF WRONG DSGN CRIT REV, EVAL TO SYS 31 CHECKLIST, REF CALCS THAT USED UNVERIFIED ASSUM & OTHER MINOR DISC i l 104 304E2025021 ECN L5038 DRC STATES THAT ITEMS 10b & 10c ARE APPLICABLE & TECH ADECUATE & OUALIFIES THIS BY A FUTURE HUMAN FACTORS PROG i I30 304E2G04221 ECN L6254 DOES NOT CONTAIN ADEDUATE ASSESSMENTS OF SETPOINT ACCURACY & MARGINS FCR PRES % SWITCHES DESCRIBED IN ECN ' I33 304E7G0'321 ECN L6124 DRC DOES NOT CONTAIN ADEOUATE ASSESSMENT OF TIME DELAY SETPOINTS FOR SWITCHES DESCRIBED IN ECN I34 304E0007321 ECN L6124 TIME DELAY SETPOINT CALCULATIONS NOT REFERENCED IN ECN PACKAGE PERF0FMANCE OF PRESS SW REPLACED BY ECN L6374 CANNOT BE VERIFIED SINCE SOURCE DOCUMENTATION IS INCOMPL (NRC 53,obs.6.13) I47 314E2B38001 153 604L2731021 ECN L5031 WAS LISTED AS POST RESTART BASED ON ADEO OF EXISTING EQUIP BUT EXISTING EQUIP IS NOT ADEO FOR SAFETY FUNCTION M34 304M3925201 INCORRECT USE OF USOD FOR ECN L5095 TO JUSTIFY SEIS OUAL OF REFLACEMENT OF BLIND FLANGE WITH SECOND VALVE, NIPPLE, & CAP M39 304E3C20020 ECN L5681 DRC DOES NOT APPROPRIATELY ADDRESS SEISMIC ANALYSIS, OPERABILITY & HYDRAULIC DESIGN M48 6 4L4 10 RATIONALE FOR NO BLOWOUT PANELS IN CO2 STORAGE ROOM OF THE DGB IS NOT ADEOUATELY ADDRESSED IN SYSTER 82 N01 004CO211221 JUSTIFICATION INADEO IN CALCS FOR ABSENCE OF FSAR CHAPT 15 DBAs & EVAL FOR OFFSITE RADIATION NOT DOCUMENTED (obs.4.1) NO2 004C0231221 SAFETY FUNCTION IDENTIFICATION NOT SYSTEMATICALLY IDENTIFIED IN CALCULATION PACK:.GE SON-OSG7-048 N04 004C0411301 LACK OF JUSTIFICATION FOR BOUNDARY SELECTION IN CALCULATION PACKAGE SON-OSG7-048 N09 00400211221 JUSTIFICATION NOT PROVIDED FOR INCLUSION / EXCLUSION OF ALL SYSTEMS FOR CHAPTER 15 ACCIDENTS IN CALCS (NRC-8,obs. 4.1) N32 004C0411001 FAILURE TO ADDRESS FUEL GEOMETRY REQUIREMENTS IN CALC. SON-0SG7-048 N41 304F0421201 FAILURE TO REVISE FSAR DWG UPON FCN IMPLEMENTATION N42 314E7G07220 EVAL OF ECN L5371 OVERLOOKED NEED FOR FSAR REVISION & LACK OF FINAL APPROVAL OF FCR 501 & HAS NUMEROUS CHECKLIST DISCREP N44 304E0G07221 UNIMPLEMENTED STATUS OF ECN L5323 FOR CHARC0AL CANISTER REPLACEMENT NOT ADEOUATELY ADDEESSED IN SOEP-12 CHECKLIST N46 304C0231021 LACK OF JUSTIFICATION IN PRESSURE DROP CALC. EPM-SMJ-022886 USED TO SUPPORT ECN L6673 (NRC 56, obs. 2.6) 006 104BSB11301 WDP DID NOT IDENTIFY AS-BUILT DWG DISCREP FOR PIPE SIZE & TEAM DID NOT DOC ALL DIFFERENCES OBSERVED (NRC-2,obs. 1.4,6.4) 009 104B7B11401 DIFFERENCES BETWEEN SYSTEM AND WALKDOWN BOUNDARIES WERE NOT DOCUMENTED & JUSTIFIED (NRC-7,obs. 1.2) 015 104B5625021 DIFFERENCES EXIST BETWEEN THE U1 & U2 WD BOUNDARIES WITH JUSTIFICATION NOT PROVIDED IN THE WDP (NRC-13, obs. 1.2) i 017 51410114121 RATIONAL FOR DESIGN CRITERIA ON RHR SUMP LINE ISO VALVES & POST ACCIDENT ISO VALVES NOT UNIFORMLY CAPTURED 018 51417114121 SON-DC-V-2.15 DOES NOT CONTAIN REFERENCES TO NUREG-1.63, 50N-DC-V-11.3 AND SON-DC-V-12.2 FOR CONTMNT ELEC PENETRATIONS 001 104B5624321 SYSTEM WALKDOWN PACKAGE NO. S0-DR-86-06-135R NOT PERFORMED AND DOCUMENTED PER SMI-0-317-030 55 2 *" 5 0$ e2

EVALUATED FINDINGS INCORRECT DESIGN INPUT / ASSUMPTION FINDING TYPE SUBCATECORY ACTION ITEM TREND NO. CODES DESCRIPTION C20 50317120421 C/R REQUIRING SEALED OR ENCLOSED TERMINAL BLOCKS INSIDE CONTAINMENT WAS MISSED IN IMPELL REVIEW OF NCREEB79-7 C22 303C4E30001 U2 ANAL OF CONT SPRAY TEST LINE FOR ECN L5268 JUSTIFIED AS OPPOSITE HAND OF U1 BUT ROUTING CONFIGURATIONS DIFFER C48 303C4221021 CNTMT PENETRATION LEAK TEST ANAL DOES NOT ADDR BOUNDING CASE OF PIPE CANTILEVERED MAX DIS FROM HEAD PL (NRC 48, CBS.3.6) E08 003CO23E001 120VAC PREF & 250VDC PWR SYS, RAD MON, SMPL & FP PWR DIST SYS WERE INCORRLY LISTED IN SYS BOUND CALC FKG AS VP SYS E49 313ElB11011 ECN L5872 DRC CONTAINS TECHNICAL ERRORS INVOLVING ECN COVER SHEET, FSAR, LOGIC DIAG, FLOW DIAG & I-TABS ES2 303E1G11021 ECN L5872 DRC CONTAINS TECH ERRORS INVOLVING SYS MON CIRCUITS, REF FLOW DIAG INSTEAD OF SCH, & REF WRONG HAND SWITCHES E56 403D1314251 SOEP-14R1 SECT 3.6 REOMNT WAS VIOLATED IN RED-LINE PKG SINCE AS-DSGN DWG WAS USED FOR AS-CONST DWG TO COMPARE PRE 0? DWG E59 303ElG01321 ECN LS872 DRC DID NOT REF DESIGN CRITERIA REV, REF WRONG CALC PKG, & DID NOT REF REDUND, DIVERSITY & SEP REOMNTS E86 613L1731121 CRAD 45N709-2 RL HAS CABLE IDENTIFICATION PROBLEM & VITAL INVERTER NAMEPLATE DATA IS IN CONFLICT WITH VITAL POWER SYSTER I36 303E2C21221 ECN L5275 DRC DOES NOT PROVIDE JUSTIFIED CONCLUSION THAT BIT RECIRC ROT 0 METER IS NOT REQUIRED FOR RESTART M09 303G3C38011 SCR NEB 8520 WAS INCORRECTLY CLASSIFIED AS *OPEN* INSTEAD OF *0NP' IN ACCORDANCE WITH SOEP-11 012 103B5E32001 E4 TEAM USED *AS-DESIGNED

• DRAWINGS INSTEAD OF *AS-CONSTRUCTED
• DRAWINGS FOR INDEPENDENT WALKDOWN (NRC-5)

                                                                                                                                                                         ~8 ON N

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EVALUATED FINDINGS IMPLEMENTATION OF ADMIN CUIDANCE DEFICIENT FINDING TYPE SUBCATECORT ACTION ~ ITEM TREND NO. CODES DESCRIPTION E11 50A87B34011 TRAINING OF SENIOR FEOPLE TO SOEP-18 WAS DONE TO C/R HANDBOOK BEFORE PROCEDURE ISSUANCE EIS 30AG7314401 SDE's SUBMITTED SCR/NCR IDENT FORMS TO REVIEWER BEFORE RECEIVING ALL *0NP" DOCUMENTATION WHICH VIOLATES E43 50A17B04221 LACK OF TRAINING OF WESTINGS 00SE DESIGN CRITERIA PREPARERS TO SOEP-29 I18 50A12114301 C/Rs INVOLVING IGC CHANKEL LIST HAVE MISSING ATTACHMENTS AND MAY NOT BE IN C/R DB 121 30AE7B35411 ICN L6359 LRC DOES NOT PROVIDE ADE0UAT ASSURANCE THAT SFISMIC OUATIFICATION OF LEVEL SWITCHES WILL 1 153 6 CAL 3718221 WDP-81 DOES NOT INCLUDE NAMEPLATE DATA FOR MECHANICAL COMP 0KENTS AS REQUIR D BY WALKDOWN SCOPE l N50 60AL7714421 " EXCEPTIONS" ARE NOT BEING PROPERLY OR CONSISTANTLY INCORPORATED INTO SYSTERs ! N5? 60AL7725421 RESTART INDICATIONS ARE INCORRECT FOR PUNCHLIST ITEMS FOR SYSTER 82 & SYSTER DID NOT ADDRESS RELAT N57 60ALOB15511 PUNCHLIST CHANGES NOT COGFDINATED WITH APPLICABLE SE AND ITEMS NOT PROCESSED FOR COMPLETENECS/TINEL l 006 10A75815311 SOME MAINTENANCE PROCEDURES ARE NOT SUBJECTED TO 00RC REVIEW & SOME ARE NOT REVIEWED & UPDATE h OY s e.=

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                                                                      ;g y-g, .-      "-'e EVALUATED FINDINGS T Qi}.?                 ,                                                  ,

DESXGN DOCUMENTS CONFLICT:. ' FINDING TYPE SUBCATECORT' 7 7 p , u ,- ACTION

                                                                                                                                                             '~.,

ITEM  : TREND . 2' NO. . CODES- DESCRIPTION. '

                                                                                                           ~

C19 306E4518021

                                                                                                                                                                  ~

CIVIL AND ARCH DWGS IN ECN L6300 SHOW CONFLICTING REQUIREMENTS FOR CONC" CURBS' UNDER ARCH DOORS & ARE NOT X-REFERENCED C39 306E4G30220 ECN L6439 EATA SHF5T DOES NOT ADDRESS ALL APPLICABLE DRAWINGS THAT CALCULATIONS WERE PERFORNED 05 FOR CUT REBAR1

     -E01      106B7824421  LACK OF DOCUMENTATION FOR REDUCING WALKD0bH BOUNDARY ON_CRADe FROM'SWIBDe (WDP-67RI)
                                                                                                                                                                                        ~                                   ~

102 .106B5618001 WDP FIELD DWG MARKED COMPONENT WITH MISSING ID TAG AS

• ITEM 1* & MASTER COPY WAS NOT SIMILARLY MAREEDE

      .I07'    10647B3B201 . LACK OF' ROOT VALVE NUMBERING AND PIPING INTERFACE NOTATION DN FUCTIONAL CONTROL DEAWINGS (NRC-6)-                                                             e                     ~.

s I29 306E2G00320 ECN L6254 DRC DOES NOT CONTAIN ADE00 ATE ASSESSMENT OF TECHNICAL REOUIREMENT OF SON-DC-V-13,9.8 .. M01 106B5625221 AS-BUILT DRAWING DISCREPANCIES NOT TRANSFERRED TO MASTER WALKDOWN COPY &

SUMMARY

SHEET NOT PROVIDED: .. M08 106B3635021 RHR WDP DISCREPANCY CONCERNING RCS EQUIP NOT REPORTED TO WDP-72 PERSONNEL FOR PROPER INTERFACE ON NASTER DWG-(3RC-22).  %-- 306E7G25221 M21 ECN L6665 DRC HAS TWO SEPARATE AND POSSIBLY CONFLICTING VERSIONS s' C7-',: a= ~ a ' 5- .g 6-  % i 2 R; W; i

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~ EVALUATED FINDINGS

                                                      .-MISCELLANEOUS DRAWING DEFICIENCIES FINDING TYPE SUBCATEGORY..

ACTION ITEM TREND' NO. f CODES. DESCRIPTION 307C4512221-NRC AUDIT OF ECN L6479 IDENT DISCREPANCIES BETW PIPING LAYOUT SHOWN ON ISOMETRIC-& PHYSICAL PIPING DWG (NRC 50, obs.3.5)- C50 C52 3074451C021 NRC AUDIT OF ECN L5274 IDENTIFIED DISCREPANCIES BETWEEN RHR PIPING SHOWN ON ISOMETRIC & PHYSICAL.DWG (NRC 52, obe. 3.9) 101 107B5618001 IDENTIFICATION OF COMPONENT 2-SI-46-56B WAS NOT ACCURATELY TRANSFERRED TO MASTER IN COMPLETED WD P

 'I35     ~30742510020     ECM L6124 DATA SHEET DID NOT. REFLECT ALL NECESSARY DRAWING CHANGES FOR MODIFICATION MOS      10745514101-    WDP-72 

SUMMARY

SHEET ATTACHMENT DOES NOT REFERENCE

SUMMARY

. SHEET & WDP MASTER DWG NOTE CONFLI N45 30743535320 ' LOCATION OF DESIGN PRESSURE & TEMP 3REAKS INCORRECTLY MARKED ON FLOW DIAGRAM (NRC 54, obe. 2.7)- 7 )' 31740532220 . PIPING ELEVATION IN SECT J5-J5 DN 47W560-5 DOES NOT AGREE WITH FLAN VIEW & MAY NOT REP AS-BUILT CONF (NCR 57,- obs. 2. N47 004 107B3B14001 *INFORMATION ONLY" AND WALKDOWN DRAWINGS IN WDP-3B WERE NOT SIGNED BY THE PREPARER AND/OR CHECKER. 10745E3F001

                        - WASTE DISPOSAL SYS CONTAINMENT BOUNDARY PENETRATION X-46 IS NOT SHOWN ON DRAWING FOR WDP-77 (NRC-16, obs.'7.1) 014
                                                                                                                                                 .;B ON

EVALUATED FINDINGS 7 IMPLEMENTATION OF TECUNICAL GUIDANCE DEFICIENT , FINDING TYPE SUBCATEGORY ACTION ITEM TREND NO. CODES DESCRIPTION E05 309E7B14201 PRE-OL ECN LISTED CN ECW IDENTIFICATION FORM BUT NOT ON THE OWIL WHICH VIOLATES S20P-11 E32 339E!G25001 DOCUMENTATION DOES NOT EXIST IN ECN L6015 PKG TO ANS OUEST Sa & 5e & CAO NOT ISSUED FOR TRACKING PUR (VIOLATES SOEP-121 E36 409E1B21321 VERIF NOT PROVIDED THAT TRAINED IMPELL PERS ASSIGNED *N/A" CAT OR APPROP ENG BR/NU PWR RESP TO SOURCE DOCUMENTS l i E62 309EIG24021 SOEP-11 ATTACH I FOR ECN 5449 INCORRECTLY STATED ECN ONLY INVOLVES AP SYS BUT ECN ALSO INVOLVES VP SYS E82 609L1731001 ECN L6746 NOT CAPTURED IN SOEP-12 REVIEW OR IN THE SYSTER EVALUATION WHICH CONFLICTS WITH SECT 3.1A 0F THE SYSTER 106 109B5E3F001 DETAIL SKETCH OF PA!EL 2-L-381 IS NOT REF ON WDP-46 SUM SHEET & DNE AGREEMENT NOT PROVIDED WHICH VIOLATES SMI-0-317-30 M44 309E3B07001 ECNs 5714 & 6103 NOT REVIEWED BY ENGINEER TRAINED TO SOEP-11 N15 309G4B14001 SCR/NCR FWP8308 COERECTIVE ACTION WAS FOUND INADEO & A NEW CAO WAS NOT ISSUED TO READDRESS FINDINGS BY SDE PER SOEP-11 002 109B5615001 INCONSISTENCY IN FILLING OUT MECH COMP DATA SHEET FOR WDP-70 FOR THE PRESENCE OF A YELLOW CAUTION TAG ON MOV BREAKERS

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EVALUATED FINDINGS ,

                                        . MISCELLANEOUS DESIGN DOCUMENT DEFIC (EXC DWG & CALC)

FINDING UFl SUBCATEGOEY' ACTION. ITEM TREND NO. ' CODES . DESCRIPTION 108B5B18101' INCOMPLETE TRANSFER OF INFORMATION FROM MASTER WALKDOWN DRAWING TO COPY IN WDPs FOR MS,HPFP,'& PAM C01 C32 308E4GIE001 ADDITIONAL SUPPORT DRAWINGS FOR ECN L61% ARE NOT LISTED WITH REFERENCED CALCULATIONS OR CIVIL CNECKLIST E41 308EIG11011 ECN L5114 ELEC DRC CONTAINS MINOR ERRORS & DOES NOT ADDRESS SEISMIC OUAL OF ELEC COMPONENTS N34 308EIG11001 ELECTRICAL CHECKLIST DOES NOT PROVIDE ADEDUATE REPLACEMENT COMPONENT INFORMATION FOR ELECTRICAL EQUIPMENT C N35 308E0G30001 ECH 2707 CCVER SHEET DID NOT INDICATE SEISMIC ANALYSIS OR ELEC INVOLVEMENT & CHECKLIST DID NOT MEET SOEP-12 RE0M A4

                                                                                                                          ;8 OY 25

EVALUATED FINDICOS MISSING / INADEQUATE DESIGN PROCESS PROCEDURES FINDING TYPE SUBCATEGORY ACTION ITEM TREND NO. CODES DESCRIPTION C07 50G14R25221 REDUCTION OF MARGINS IN FSAR NEEDS LICENSING ACTION & C/R TRACKING NEEDS TO BE ADDRESSED (NRC-21, obs. 3.2 & 3.3) C23 30GE732C450 ECN L5298 INCORRECTLY EXCLUDED FROM SOEP-12 TECHNICAL REVIEW E17 30G77E31401 ECN CHECKLIST OUESTIONS WERE DELETED FROM SECT C OF SOEP-12 REVISION 1 (obs. S.2) E33 40G71815321 PROCEDURE USED BY ESES TO ASSEM, EVAL & DOCUMENT TEST DATA DOES NOT AGREE WITH SOEP-14 REOUIREMENTS (obs. S.3) E67 40G71825221 SEOP-14 DOES NOT IDENT WHO APPROVES " RETEST

• TEST RESULTS, WHO EST " RETEST" ACCEPT CRIT & WHO PERF & PART IN RETEST E70 40GD7E3B401 SOEPs 14 & 26 DO NOT PROVIDE METHOD TO DOCUMENT THE
• FUNCTIONAL' BASIS FOR SAFETY SYS IN ENG DOCS ON FUT MODS (obs. 5.3) 103 10GB2835321 WALKDOWN PERSONNEL DID NOT INCLUDE VERIFICATION OF HANDSWITCHES IN COMPLETED WDP M03 IDGB7E25411 WDP-15 INDIVIDUAL 8 1/2 X 11 SHEETS NOT DESIGNATED UNIT 2 AS APPOSED TO UNIT 1 DUE TO PROCEDURAL DEFICIENCY M49 60GL3E3F001 PUNCHLIST ITEMS ARE BEING CLOSED BEFORE 0A COMPLETES REVIEW OF FIELD WORK N07 50G77835421 LACE OF TVA PROCEDURE FOR LICENSING COMMITMENTS REVIEW ACTIVITY N13 50G77835421. IMPELL LICENSING REVIEW OF DSGN CRIT DEVELOPMENT WAS NOT INDEPENDENTLY VERIFIED FOR CAPTURE OF ALL C/Rs (NRC-17,obs.5.4)

N49 60G77815421 SOEP-16 HAS NO PROVISIONS FOR ALLOWING CHANGES AND MODIFICATIONS TO ISSUED SYSTERs N52 60G77725421 NO ROLE IN SOEP-45 R1 FOR SE TO APPROVE RESOLUTION & STATUS OF PUNCHLIST ITEMS AGAINST HIS/HER SYSTER 011 30G77825421 ASSESSMENT OF THE ADEDUACY OF SCOPE & DIRECTION FOR DB&V PROGRAM IS HAMPERED BY DELAY IN ISSUING SOEPs (NBC-11) 021 10GBSE3F211 GUIDELINES NOT EST FOR CONSISTANCY IN THE COLLECTION OF NP DATA FOR EQUIP MOD OR REPLD SINCE OL (NRC-34, obs.1.4 & 2.2) 003 30G86825211 S04-183 DESCRIBES A CCB DECISION CLASSIFICATION FOR MOD AS

• CANCELLED" BUT DOES NOT RECOGNIZE A DNE APPEAL PROCESS

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EVALUATED FINDINGS TECHNICAL CUIDANCE INADEQUATE FINDIO TYPE SUBCATECC3Y ACTICN ITEM TREND NO. CODES DESCRIPTION C04 10FB5B25021 ATTRIBUTES M & N OF ATTACHMENT 5 0F SOEP-08 NOT INCLUDED IN SMI-0-317-30 E07 30F71815221 GUIDELINES INADEO IN SOEP-12 TO ENSURE THAT ALL NEEDED ELEC DIST SYS ARE ADDR IN REVIEW OF ECN CHECK LIST ITEM Sb M06 30F77B25421 PROCEDURES DO NOT ADDRESS ECN REVIEW FOR TECHNICAL ADEOUACY OF DRAWINGS & CALCULATIONS WHICH VIOLATES SOEP-12 008 10FB7E3F201 CONCERNS AS TO EXTENT, USE, AND REASON FOR AS-DESIGNED DRAWINGS IN WDPs (NRC-4) l l

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EVALUATED FINDENCS INTERNAL DISCl?LINE INTERFACE DEFICIENT FINDING TYPt CATEGORY ACTION ITEM TREND

50. CODES DESCRIPTION C43 30JE4G34121 ECN L5779 SOEP-12 REVIEW IDENTIFIED DESCREPANCIES WITH SOEP-12 CHECKLIST, CIVIL CHECKLIST AND ECN DATA SHEET M10 60JL7B25401 SOEP-16 DOES NOT ADDRESS SYSTEM INTERFACE & REVIEW RESPONSIBILITIES (obe 1.3)

M17 51J1312E121 AFW DEFICIENCIES RELATED TO SYS INTERFACE, NISSING C/Re, SHOP TEST REQUIREMENT, & DESIGN REQUIREMENT FOR AFWP NPSH 022 103B1614201 PROJECT NEEDS TO VERIFY THAT SINGLE LINE CRADe ARE BEING REVIEWED BY A STA FOR DRAWING DEVIATIONS PER SMI-0-317-30.

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EVA1.UATED FINDINGS MISSING REQUIREMENTS IN DESIGN CRITERIA. FINDIG TYPE SUBCATECOR) ACTICN ITEM TREND NO. CODES DESCRIPTION 50M17123421 COMMITTMENT IN LETTER A27820301032 TO NRC FOR AFW PIPING DESIGN CRITERIA WAS NOT CAPTURED IN THE C/R DATA BAS Cc6 CI4 50M14333221 EFFECT OF ADDED WEIGHT OF CABLES IN TRAYS AT EXIT POINTS ON SEISMIC ANALYSIS N SOEP-18 ATTACHMENT 1 DOES NOT LIST FEDERAL, STATE AND LOCAL PERMITS E13 51M17B33401 C/Rs WERE OMITTED FROM DG & AUX SYS, 125V VITAL BATT SYS & 120V AC VP SYS DESIGN CRITERIA' E21 50M17123421 50M17123420 CABLE RE0MNTS NOT ADDR & CABLE bSGN CRIT NOT REF IN DC CONT FWR SYS, FIFTH VITAL BATT SYS & DG & AUX SY SON-DC-V-11.2 E23 E24 50M11130021 VITAL BATTERY MINIMUM TERMINAL VOLTAGE AT DESIGN DISCHARGE (NRC-25, obs.STATE 5.5) WAS NOT SPECIFIED IN E29 51M11123321 AUX. POWER CRITERI A SON-DC-V-11.4.1 DID NOT CAPTURE ALL APPLICABLE C/Rs E40 51M11134001 C/R FOR MOV CONTROL & INDICATION FEATURES REF ON PRINTOUTS FOR RHR & RCS SYS BUT NOT SCN-DC-V-32.0 REF IEEE 323-1971 INSTEAD OF 323-1974 & DOES NOT ADDR SYS SETPOINT RE0MSTS (NRC-32, obs. 6.5, 113 50M12123220 I17 50M12133201 TVA LETTER CN METEORLOGICAL MONITORING SYS FEATURES & ADD EMER RESPONSE ORG 120 50M12431001 C/R REQUIRING REPLACEMENT OF 20-200 SEC RANGE RELAY WITH 3 SEC RANGE RELAY IS NOT IDEN M13 51M1313B001 C/R FOR MINIMIZING CAVITATION OF ERCW THROTTLE VALVES NOT CAPTURED IN C/R DATA BASE OR DE MIS 51M13113321 DESIGN CRITERIA DOES NOT ADDRESS TEMPERATURE & PRESSURE STRESSES FOR SUPPORT DESIGN & S M18 50M13133221 DESIGN CRITERIA DID NOT REFERENCE NPSH VALVES FOR THERMAL BARRIER BOOSTER PUMPS M24 50M17113421 SON-DC-V-7.4 CONTAINS THREE APPENDIXES LISTING DOCS THAT CONTAIN COMMITMENTS & R M28 50M13113321 C/R FOR SIS COLD LEG PARAMETERS FOR DESIGN OF COLD LEG ACCUMULATORS WAS NOT CAPTURED (obs. 5. 51M10E3F201 SON.?C-3-2.15 ATTACHMENT A NOTES ARE NOT ACCEPTABLE FOR CVCS INJECTION LINES TO MEET GDC 54-57 (NRC-24, obs. 8.2) N19 50M10113021 C/P RED THAT ENL ARGED SPRAY SHIELDS BE INST OVER IGNITER ASSEMB IN HMS WAS OMITTED FROM SON-DC-V-26.1 (NR N22 N24 52M17110221 PROGRAMMATIC DEFICIENCY EXISTS CONCERNING THE PROPER SPECIFICATION OF MATERIALS & TH N27 51M10120221 C/R IDENTIFIED ON TRACKING SHEETS NOT INCORPORATED INTO SON-DC-V-27.7 2% In.U, e .

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EVALUATED FINDINCS INADEQUATE / INCOMPLETE REQUIREMENTS IN DESIGN CRITERIA q FINDING TYPE SUBCATECORY ACTION ITEM TREND NO. CODES DESCRIPTION C16 51L14113321 PIPE STRESS CONSIDERATIONS FOR STIFF CLAMPS & PIPE SLEEVE LUG RESTRAINTS NOT ADDRESSED IN SON-DC-V-24.1 (NRC-23,obs 3.4) C17 51L14124321 GDC EXCLUDES C/R FOR DRILLED ANCHORS & FAILED TO CAPTURE C/R FOR THRU-WALL BOLTS IN MSNRY WALLS (NRC-31, obs. 7.2 & 7.3) C18 51L14114321 DB DOC DOES NOT CAPTURE ALL SOEP-29 RE0MTS & APP F OF THE 04 MANUAL FOR SEISMIC QUAL OF MECH & ELEC COMP / EQUIP IS INADEO C46 5CL1433F251 ANCHOR PT MOVEMENT NOT ADDR IN DSGN CRIT & CABLE TRAY SUPPORT DSGN DOES NOT ADDR PT LOADS (NRC 44, obs. 8.1, 8.3, & 8.4) E20 50L17125421 LACK OF CLARITY IN SOEP-29RO INVOLVING USE OF NEP-3.2 FOR PREPARATION OF DESIGN CRITERIA E22 51L17114101 C/Re FOR DG & AUX SYS,125 VITAL BATT SYS & 120 AC VP SYS WERE OMITTED FROM ATTACH 2 C/R DB TRACKING SHEETS E28 51L11121221 ELEC DESIGN C/Rs WERE OMITTED FROM DESIGN CRITERIA & C/R DB TRACKING SHEET FOR AUX POWER DC SON-DC-V-11.4.1 E30 50L11131021 SON-DC-V-11.4.1 DOES NOT ADDR CABLE CAP FOR CONT OVERLOADS LESS THAN MOTOR BKR PROT RELAY TRIP SETTINGS (NRC-26,obs.S.6) E39 51L11133001 IEEE 279 & FSAR C/R FOR CONT SPRAY SYS HAVE NOT BEEN ADE00ATELY ADDRESSED IR SYS DESIGN CRITERIA SON-DC-V-27.5R0 E71 50L1111CO21 SON-DC-V-11.3RS CONTAINS ENVIR COND THAT ARE OUTDATED & DO NOT AGREE WITH ENVIR COND ISSUED BY SON EDP (NRC 40,obs. 6.9) 114 51L12133221 SINGLE FAILURE CRITERI A TERMINOLOGY IN DESIGN CRITERI A SON-DC-V-2.16 NEEDS CLARIFICATION (NRC-33,obs. 6.8) M16 50L1313B021 DSGN CRIT DOES NOT STATE REG GUIDE 1.29 EXCEPTIONS, SOEP-11 LICENSING COMMITMENTS NOT CAPTURED, & HPFP C/R NOT CAPTURED M26 50L13E33001 SON-DC-V-13.9.9 MAY NOT LIST ALL APPLICABLE INDUSTRY CODES AND STANDARDS N17 50L10133121 N20 FAILURE TO INCORPORATE C/Rs INTO DESIGN CRITERIA TEXT AND TO SPECIFY ALL INTERFACE REOUIREMENTS PER SOEP-29 51L10131001 C/Rs REO IND OF SR FL' OUTSIDE MCR & THAT ELEC PEN MUST CONFORM TO IEEE 317 OMITTED IN SON-DC-V-27.8 (NRC-28, obs. 4.6) N21 50L1013B021 INADLOUATE AND INCONSISTANT EO REQUIREMENTS IN SON-DC-V-26.1 TOR EXISTING INPLACE EQUITNENT (NRC-29, obs. 4.S) N23 51L10131001 INADEQUATE INCORPORATION OF C/Rs IN SON-DC-V-2.17 829 S1L10131001 DISCREPANCIES EXISTS BETWEEN TECH SPEC LCO 3.4.1.1 AND SON-DC-V-27.4 FOR RCS 2 LOOP MIN OPERATION CONDITICN (obs. 2.S) 7%

                                                                                                                                             -E y

EVALUATED FINDINGS POTENTIALLY GENERIC DESIGN PROBLEM NOT ADDRESSED FINDING TYPE SUBCATECC3Y ACTION ITEM TREND NO. CODES DESCRIPTION E02 10NB7232021 CALC FKG DOES NOT ADDRESS MEANING OF CROSS-HATCHED AREAS OF SYS BOUNDARY ON SWBIDs AND CRADs E04 10NB7824421 OVERALL SYS BOUNDARY AND BORIC INJECTION BYPASS LINE WAS OMITTED FROM CRAD ON WDP-63 WHICH VIOLATES SOEP-E06 30NE7B20221 ECNS L5864, LS867, L5880 ARE IDENT AS AFFECTING SYS 201/202 INSTEAD OF VP & AP SYS WHICH VIOLATES SOEP-11 109 51N1743B401 THE EFFECT OF RC 1.97 ON THE DBVP HAS NOT BEEN IDENTIFIED (NRC-15,obs. 6.1) I15 50N17431201 C/R DEFINING THE ABILITY OF FLOW INSTRUMENTS TO INDICATE SYS FAILURES IS NOT DOCUMENTED IN C/R DB NOS SON 10B31201 NRC 00ESTIONS WHETHER TECHNICAL SPECIFICATIONS ARE BEING CONSIDERED FOR INPUT TO LICENSING COMMITMENT LIST (N 019 11NBSD25401 ARMOURED CABLES ON CSS PUMP REMOTE OPERATED VENT OPERATOR SUSTAIN EXCESSIVE BENDING AND DO NOT OPERATE FREELY 2% b

EUALUATED FIh"JINGS CCORECTIUE ACTION INADEQUATE - 4' FINDING TYPE SUBCATECORY ACTION ITEM TREND

50. CODE- DESCRIPTION C35 300E7G04421 CEB CHECKLIST NOT PREFARED FOR ECN 2120 AND GENERIC IMPLICATIONS NOT IDENTIFIED A!iD ADDRESSED M45 S1003036001 FSAR DOES NOT REFLECT C N DESIGN CRITERIA (NRC 37, obe. 2.4) 002 100B6512220 DEFIC 67-138 IN WDP-67 FOR ERCW IDENTIFIES DIAPHRAGM VALVE AS GATE VALVE (DISCREPANCY REPORT NO. S0-DR-86-07-140R) 004 100B6512121 WR/MR NOT REFERENCED IN WDP FOR MISSING / INCORRECT ID TAGS FOR AFW & ERCW SYSTEMS (DISCREPANCY REPORT NO. S0-DR-86-154R) i 1

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EVALUATED FINDINGS INCOMPLETE EVALUATICJ OF USQDS FINDING TYPE SUBCATEGGY ACTION ITEM TEEND No. CCtES DESCRIPTION E47 300M043C001 USCD FCR ECN L5451 REDUCES THE SCOPE OF THE ECN AND DOES NOT ADDRESS THE 125VD E63 300MIF31C01 USOD FOR ECN LS449 DOES NOT ADDR LOSS OF VOLT RELAYING LOGIC & INDICATES OVERVOLT E68 300M1F30001 USOD FOR ECN L6573 DOES NOT ADDR DECR TRIPPING TIME OT NOR FDR SKR FOR 6900V SHD N38 300M0F23320 USOD FOR ECN L5681 DOES NOT DOCUMENT VENDOR RECOMMENDATIONS & SEISMIC ANALYSIS WAS s

                                                                                               %A 5

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EVALUATED FINDINGS TEST RESULTS INADEQUATE FINDING TYPE SUBCATEGORY ACTION ITEM TEEND No. CODES DESCRIPTION E37 40TD1B21221 SUPPORTING ENG JUSTIFICATION FOR ECNs 2633 & L5114 TEST REVIEW PKG DO NOT ADDRESS PURPOSE OF TEST EVALUATION E60 40TD1C21001 ECN L5599 TRP LACKS JUSTIF TO SUPPORT CONC THAT RESOLUTION TO OPEN ITEMS IS NOT REO FOR RESTART & SCOP DOC RET WRONG SGI I32 40TD2E31201 ECN L61TS PRESSURE SWITCH RECALIBRATION TEST RESULTS LACK EEFEREhCE TO METHODOLOGY 023 30TD5E31201 POST-MAINTENANCE TESTING OF FLOW CONTROL VALVES PER SI-166 & TI-69 IS NOT BEING PERFORMED l I ! i l l l l l l 5% 23 0 P, E l c l

                                                                  -EVALUATED FINDINGS OPERATIONS AND MAINTENANCE REIATED
                                                             - FINDING TYPE SuscATECORY ACTION ITEM     TREND

50. CODES DESCRIPTION WP 11916 LISTS TERP SWITCH ' RED VALUES

• WITH +/-5 DEG F TOL W/0 RET TO DSGN BASIS FOR JUSTIFICATION '(NRC 35,obs I44 30XESE18001 I45 11XN591E031~ FC-30-149 HAD MISSING COVER AND DAMAGED FLEX COND SUT WAS NOT TAGGED TO INDICATE CO 005 10X42A3E031 ATW FRESStiRE TRANSNITTERS LABILS ARE REVERSID & DOC OF TRANSNITTER/ LOOP ALIGNMENT & F WDPs CONTAIN INCONSISTINT PNL LOCATIONS, INCORRICT SKETCHES & NO RECORD FOR STEAM LEAKOFF LINES (NRC-3,obs. 2.

C07 10XB7615421 013 10XCSE3F301 OPERATIONS INPUT TO DB&V PROGRAN SCOPE MAY NOT FULLY CAPTURE THE REQUIREMENTS OF EDIs AND S 10XBSE3F3CI NO PROCEDURES TO REQUIRE REVIEW OF WALKDOWN DATA FOR ASSESSMENT OF POTENTIAL INPACT ON OPERATIONS (NBC-14, ob 016 NONCEAIL CRANES & HOISTS SHOULD NOT BE PARKED OVER SAFETY EQUIPMENT,e.g., MONORAIL HOIST PARKED OVER 2B-B FU 020 10X85B34550 008 30X85B18211 CHANGE CONTROL BOARD IS NOT DOCUMENTING MODIFICATION CANELLATIONS OR DEFERRALS OF DCRs AS REQ 2' % 2' 8 OM e-*

                                                                                                             .  = .                                    I

i CTHER FINDINGS (NOT EVALUATED IN DEPTH) ACTION ITEN TREND NO. CODES DESCRIPTION N05 005C023E221 SYSTEM BOUNDART DUG IN CALC PKG SQN-OSG7-048 HAS INCONSISTENT BOUNDARY MARKINGS AND REQ VS NOT REQ AREA DESIGNATIONS E34 40871814211 INDEPENDENT REVIEW OF ELEC TEST EVALUATION FOR ECN L5017 PKG WAS NOT PERFORMED WHICH VIOLATES NEP-5.2 & SQEP-14 M02 10885625221 QC SICNOFF AND VERIFICATION WAS ACCOMPLISHED ONLY BY HICHLITE & RED LINES & PROCEDURES DID NOT INDICATE A QA DOCUMENT 003 10EB5E11011 WDP-70 CONTAINMENT PENETRATION DATA SHEETS DO NOT CONTAIN INITIALS & DATES FOR EACH PENETRATION NO3 00DC0210201 N11 CONTAINMENT PENETRATIONS AND ASSOCIATED ISOLATION VALVES OMITTED FROM BOUNDARY DRAVINGS IN CALCULATION PKG SQM-OSG7-048 00DC0238221 SCOPE DEFINITIONS FROM RPS AND NMS NOT CONSISTENT WITH OTHER SYSTEM BOUNDARIES (NRC-20. obs. 4.2) N30 00DC0211221 INCONSISTENCIES EXIST BETWEEN TABLE 1 "SYS WHICH SUPPORT SAFE SD" 0F CALC PEG SQN-OSG7-048 R2 & OTHER PARTS OF CALC PKG N26 51H10133321 SOURCE DOCUMENTS OMITTED FROM WESTINCHOUSE C/R SEARCH M22 51K10B3D211 N28 C/R FOR WESTINCHOUSE PROPRIETARY INFORMATION MAY NOT BE INCORPORATED INTO DESIGN CRITERIA (NRC-27. obs. 2.3) 51E10138221 E58 FAILURE TO INCORPORATE C/Es INTO SQN-DC-V-27.5 TEXT AND TO FULLY SPECIFY D8tSIGN REQUIREMENTS 30PMIF38011 USQD FOR ECN L6C15 MISIDENTIFIED ELEC EQUIP BEING MODIFIED UNDER ECN AS SAFETY RELATED E38 40RDIC20001 ECM L5114 TEST REVIEW PKG CONTAINED INSUFFICIENT SUPPORT INFO TO JUSTIFY THE EVALUATION CONCLUSION E78 40RD1410021 I46 ECN L5298 TEST REVIEW PACKAGE RETEST SCOPING DOCUMENT INCORRECTLY REFERENCED SMI-2A IN TEST

SUMMARY

40RD5D23221 FAILURE TO PERIODICALLY TEST TIME DELAY RELAYS PER IEEE 338-1977 REQUIREMENTS (NRC 47, obs. 6.15) N36 30VF083D011 N06 00YC0211221 INADEQUATE DOCUMENTATION BY SE PREPARER & REVIEVER ON FCN FORM AND TRAINING OF PERSONNEL NEEDS VERIFICATION MISCELLANEOUS EREORS OMISSIONS. AND INCONSISTENCIES IN CALCULATION PACKAGE SQN-OSG7-048

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EVALUATED FINDINGS ADMINISTRATIVE FINDINGS NOT AFFECTIE3 THE DESIGN PROCESS ACTIO4 4. ITEM NO. DESCRIPTIUh- t C34 C38 50iP-12 CHECKLIST PREPARATICN GUIDANCE RELIT". INADEQUATE FO JUSTIFICATION IN SYSTER 72 FOR NCPCEB8205 DOES NOT ADDRESS THE FULL EXTENT OF CE3 REVIE C58 Ell TRAINING OF SENIOR PEOPLE TO SOEP-I8 WAS DONE TO C/R NANDBOOK BEFORE PROCEDURE ISSUANCE E34 INDEFENDr.hT GEVIEW OF ELFC TEST EVALUATION FOR ECN LSe17 ?KG WAS NOT PERFORNED WHICH V E41 ECM L5114 ELEC DRC CGMTAINS MINOR ERRORS & DOE 3 NCT ADDRESS SEISMIC DUAL OF ELEC COMPOWENTS E49 ECM L5872 DRC CONTAldS TECHNICAL ERRORS INVGLVING ECN COVER SHEET, FSAR, LOGIC DIAG, FLOW DIAG & I-TABS E58 USOD FOR F.CN L6415 NISIDENTIFIED ELEC E0 DIP BEING NODIFIED UNDL2 ECM AS SAFETY RELATED 121 ECW L6359 ECM L5275 DRCDRC DOES DOES NOT PROVIDE NOT PROVIDE JUSTIFIED ADE00 ATE ASSURAitCE CDNCLUSION THAT SEISMIC FOR CATEGORIZING ITEMS I, 2a,OUALIFICATION OF AS 2b, 6e, 7a, 8b, Bd & 10b LEVEL

                                                                                                                                                                                        *NOT S A 138                                                                        4 I49     DISCREPANCY BETWEEN COMMITTNENT                                              FOR LOGIC DIACRA. CHANCE PER ECN LS765 & CORRESPONDING PL ITEN 158     NCR ND8485 EVAL DOES NOT CONTAIN JUSTIF FDP LACK OF AUTO CONT INDICATION IN NCR DURING P M83      WDP-15 INDIVIDUAL 8 1/2 X 11 SHEETS NOT DESICNATED UNIT 2 AS APPOSED TO UNIT 1 DUE TO PROCEDURAL N09      SCR NEB 8529 WAS INCORRECTLY CLASSIFIED AS *0 PEN" INSTEAD OF *0NP* IN ACCORDANCE WITH SOEP-11 N29      FCN 2945 ERC HAS MISSINC DOCUNESTATIO.1 & PIPS HAVE NOT EEEN ISSUED FOR TRACKING PURPOSES C/R FOR WESTINGHOUSE PROPRIETARY INFORMATION NAY WOT BE INCD2PORATED INTO DESIGN CRITERIA (NRC-27, obs. 2.3)

N22 N36 IRADEOUATE DOCUMENTATION BY SE PREPARER & REVIEWER ON FCN FORN AND TRAINING OF PERSONNEL N57 PUNCKLIST CHANGES NOT C00RDINATED WITH APPLICABLE SE AND ITEMS NOT PROCESSED FOR COMPLETENES 083 WDP-79 CONTAINMENT PENETRATION DATA SHEETS DO NOT CONTAIN INITIALS & DATES FOR EACH I.4 & PENETRATION 2.2) 021 CUIDELINES NOT EST FOR CONSISTANCY IN THE f'OLLECTION OF WP DATA FOR EDUIP MOD OR REPLD SINCE OL (NRC-34, obs. 0a3 SOA-183 DESCRISES A CCB DECISION CLASSIFICATION FOR NOD AS

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