ML20214K477
| ML20214K477 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/11/1986 |
| From: | Hubbard G, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20214K471 | List: |
| References | |
| 50-327-86-01, 50-327-86-1, 50-328-86-01, 50-328-86-1, NUDOCS 8608210117 | |
| Download: ML20214K477 (30) | |
See also: IR 05000327/1986001
Text
~
. .'
.
.
,.-
.
.
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Report Nos: 50-327/86-01; 50-328/86-01
Docket Nos: 50-327/328
Licensee: Tennessee Valley Authority
' 831 Power Building
Chattanooga, Tennessee 37401
Facility Name: Sequoyah Nuclear Plant, Units 1 and 2
Inspection At: Knoxville and Chattanooga, Tennessee
Inspection Conducted: January 6-17, February 10-14, and June 23-27, 1986
Inspector: . 7- Date
G. T. Hubbard, Equipment Qualification & Test
Engineer
Also participating in the inspection and contributing to the report were:
U. Potapovs, Chief, Equipment Qualification Inspection Section, IE
S. D. Alexander, Engineer, IE
R. N. Moist, Inspector,.IE
A. R. Johnson, Engineer, IE
P. Shemanski, Engineer, NRR
A. S. Masciantonio, Engineer, NRR
R. O. Karsch, Engineer, NRR
A. B. Ruff, Reactor Engineer, RII
L. F. Foster, Reactor Inspector, RII
L. D. Bustard, Member of Technical Staff, Sandia National Laboratories (SNL)
V. J. Dandini, Member of Technical Staff, SNL
J. W. Grossman, Member of Tec Staff, SNL
f
Approved by: Lk h d / 2.-zV2- - O d'IN
U. Potapovs, Chief, Equi; ment Qualification Date
Inspection Section, IE i
8608210117 860815
PDR ADOCK 05000327
G POR
_ _ _ ___ _.- __ . . . _ - , _ _ _ , , . _ . _ . - _ _ _ . _ _ . _ _ _ , _ . _ _ _ . - . . _
.
. .- ,
.
,
. .
,
INSPECTION SUMMARY
Inspection on January 6-17, February 10-14,and June 23-27, 1986 (Inspection
Report Nos.50-327/86-01; 50-328/86-01)
Areas Inspected: Announced inspection to review the licensee's implementation
of a program per the requirements of 10 CFR 50.49 for establishing and maintaining
the qualification of electric equipment within the scope of 10 CFR 50.49.
Results: The inspection determined that the licensee has implemented a program
to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed
below. At the completion of this inspection, the licensee was in the process
of finishing activities to establish qualification of equipment within the scope
of 10 CFR 50.49; therefore, a follow-up NRC EQ inspection will be performed prior
to plant restart.
Report
Name
Paragraph Item Number
l
Potential Enforcement / Unresolved Items:
4.D.(1)(a) 50-327/86-01-06;
1. Masoneilan 8012 Level Control Valve
50-328/86-01-06
Westinghouse Modular Electrical 4.0.(1)(b) 50-327/86-01-07;-
2.
1
Penetration' Assembly 50-328/86-01-07
4.D.(1)(c) 50-327/86-01-08;
3. Essex Power and Control Cable
50-328/86-01-08
ASCO Solenoid Valve, Model 206-381 4.0.(1)(d) 50-327/86-01-09;
4.
<
50-328/86-01-09
'
Nutherm 32KW Air Duct Heater 4.D.(1)(e) 50-327/86-01-10;
5.
50-328/86-01-10
GA Technologies RD-23 Radiation 4.0.(1)(f) 50-327/86-01-11;
6.
Detector / Brand-Rex Coaxial Cable 50-328/86-01-11
Eaton Multiconductor Signal Cable 4.D.(1)(g) 50-327/86-01-12;
7.
50-328/86-01-12
Limitorque Motor Valve Operators 4.D.(1)(h) 50-327/86-01-13;
8.
50-328/86-01-13
Cyprus (Rome) Power and Control 4.D.(1)(1) 50-327/86-01-14;
9.
Cable 50-328/86-01-14
10. Barton Transmitter, Lot 7-764 4.D.(2) 50-328/86-01-15
11. Raychem Splices / Breakouts 4.F.(1) 50-327/86-01-15;
50-328/86-01-16
>
i
. _ , _ . _ . _ . _ . , _ _ , _ _ _ _ . , - - - . . _ _ _ _ _ . _ _ _ . _ _ _ , - _ . _ _ _ , _ _ _ _ _ . - . . ~ , , , . . . _ _ , _ - = , _ _ _ -
.
- - .
.
,
,
.
Open Items:
12. Completion of EQ Training 4.A(4) 50-327/86-01-01;
50-328/86-01-01
13. Completion of Audit Corrective Actions 4.A(6) 50-327/86-01-02;
50-328/86-01-02-
4.B. 50-327/86-01-03;
14. Revision to Maintenance Procedure
SQM 62
50-328/86-01-03
15. Completion of Maintenance Program 4.B. 50-327/86-01-04;
50-328/86-01-04
16. Equipment Maintenance History 4.8 50-327/86-01-05;
Effects on Qualification 50-328/86-01-05
4
&
L
4
, n ., , - ., -- -- - - - , - , , - , - , ,a- e---. -,.1 , - --- , - ,
.
<
.- ,
.
,
.
DETAILS
1. PERSONS CONTACTED:
1.1 Tennessee Valley Authority (TVA)
'
H. L. Abercrombie, Sequoyah Site Director
R. A. Sessoms, EQ Project Manager
C. E. Cantrell, Assistant to EQ Project Manager
D. W. Wilson, Project Engineer
D. L. Williams, Supervisor, Nuclear Licensing Staff
E. Daugherty, Commodity Group Leader (CGL)
J. E. Wills, Nuclear Licensing Engineer
W. L. Elliot, Commodity Group Manager
J. A. Teague, Site Support Coordination Manager
T. E. Spinks, Technical Advisor - QC Programs and Procedures
D. L. Reed, CGL
R. W.McIntosh,
L. N. Cantrell, Manager
Technical-Staff
Office
EQ ofProject
Engineering)
(EQP
J. F. Wagner, CGL
D. L. Kitchel,.WBN EQP
F. W. Tanner, Management Review Team Member
R. J. Pratt, FQ Evaluator
K. W. Brown, CGL
R. A. Brown, EQ Evaluator
D. B. Arp, EQ Evaluator
A. W. Thomas, EQ Evaluator
D.- F. Ackerly, EQ Evaluator
J. K. Greene, EQ Evaluator
N. A. Pike, EQ Evaluator
A. W. Lewis, EQ Evaluator
.
D. D. Dayton, E0 Evaluator
E. E. McBee, EQ Evaluator
D. L. Kirby, Sytems Engineer
T. R. Witmer, Aging Analyst
P. Johnson, Aging / Management Review Staff
W. C. Graham, EQ Evaluator
L. P. Woodley, EQ Evaluator
T. S. Orr, EQ Evaluator
B. E. Reagan, EQ Evaluator
R. D. McKnight, EQ Evaluator
C. D. Helton, EQ Evaluator
R. C. Foust, EQ Evaluator
0. H. Seals, Systems Engineer
F. Denny, Quality Management Staff
R. L. Mills, Engineer
D. Rom.ine, Engineer
R. Poole, Engineering Assistant
R. J. Griffin, Nuclear Safety Review Staff (NSRS) Site Representative
G. T. Hall, Engineer
.
W. S. Wilburn, Technical Services Manager
C. R. Brimer, Manager - Site Services
B. S. Schofield, Engineer
D. E. Crawley, Health Physics Supervisor
. . - . - -- . _ _ . . . . ._ - . - - - _ - _ _ _ . - _ - .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.. .
.
.
. .
,
G. B. Kirk, Compliance Supervisor i
J. T. Crittenden, Chief Public Safety
H. D. Elkins, Jr., Group Supervisor
M. J. Edwards, Health Physics
C. W. LaFever, Instrumentation Engineering Supervisor
D. H. Tullis, Mechanical Maintenance Supervisor
R. N. Butler, QA Evaluator "
'
C. M. Lowe II, QA Engineel-
R. L. Bruce. Program & Standard Section Supervisor
H. B. Rankin, Design Services, Manager
R. C. Denney, Design Services, Staff
B. M. Patterson, Maintenance Superintendent
P. R. Wallace, Plant Manager
L. M. Nobles, Superintendent D8E
R. C. Birchell, Mechanical Engineer ,
J. M. Blankenship, Information Officer
R. W. Olson, Modification Manager
D. L. Jeralds, Instrumentation Craf t Supervisor
M. R. Sedlacik, Electrical Modifications Supervisor
J. P. Vineyard, OE Project Manager
M. A. Skarzinski, Electrical Maintenance Supervisor
B. W. Hooper, Electrical Maintenance
J. M. Anthony, Operations Group Supervisor
L. S. Bryant, Mechanical Maintenance Engineering Supervisor
M. R. Harding, Engineering Group Manager
R. E. Alsup, Licensing Project Manager
S. W. Littrell, EQ Coordinator
R. Gladney, Instrument Maintenance Engineering Supervisor
W. E. Andrews, Site Quality Manager
F. C. Mashburn, Nuclear Engineer
T. M. Galbreth, Site Representative
J. W. Kelly, E.A. Engineer
T. Kontovich, Electrical Maintenance Engineering Supervisor
F. D. Cuzzort, Electrical Engineer
R. L. Collins, Electrical Project Staff Engineer
R. H. O'Donnell, OE Staff Engineer
C. E. Chmielewski, Nuclear Engineer
R. M. Mooney, Supervisor Systems Engineer Section
J. L. Hamilton, QE/QC Supervisor
A. E. Ives, Program Administration
R. W. Fortenberry, Engineering Section Supervisor
R. C. Manley, Planning and Scheduling Supervisor
R. Sauer, Employee Concerns
T. Galbreth, Employee Concers
J. S. Nieri, SQN Employee Concerns
1.2 Consultants
,
C. J. Crane, Westec Services, Inc.
K. E. Weise, Westec Services, Inc.
l
1.3 Observer
R. K. Ho, Consultant to Nuclear Utility Group on EQ
- - - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- - - -
.. .
'
-
. .
.
a
1.4 NRC
R. H. Wessman, Senior Managenent Team Staff -
L. J. Watson, Resident Inspector
D. P. Loveless, Resident Inspector
T. E. Conlon, Chief, PSS
G. G. Zech, Chief, Vendor Program Branch
6
5
0
J
- -,
. - - . . _
..
,
. .~
. .
2. PURPOSE
1
The purpose of this inspection was to review the licensee's implementa-
i
tion _of a program.to meet the requirements of 10 CFR 50.49 for Sequoyah
Nuclear Plant (SQN), Units 1 and 2.
3. BACKGROUND-
The NRC held a meeting with TVA on May 10, 1984 to discuss TVA's proposed
r
methods to resolve the equipment qualification (EQ) deficiencies _ identified'
in the Safety Evaluation Report (SER) dated April 26, 1983 for Units 1 and
2 and in the Franklin Research Center (FRC) Technical. Evaluation Reports
(TERs) dated March 31, 1983 for both units. Discussions also included TVA's
general metho' d ology for compliance with 10 CFR 50.49 and Justification for
i Continued Operation (JCO) for those items for which environmental qualifi-
'
cation was not complete. Based on TVA letters dated November 14, 1983, and
March 23 and April 3,1984 the NRC granted TVA a scheduler extension to -
10 CFR 50.49(g) requirements until November 30, 1985 for Unit 1. Addi-
tionally, based on TVA letters dated November 7 and 21,1984, the NRC
granted a similar scheduler extension for Unit 2 until November 30, 1985.
In both cases, JC0s were submitted for equipment which had not been quali-
,
>
fied in time to meet rule deadline requirements of Spring 1984 for Unit 1
and Fall 1984 for Unit 2.
'
On August 21-22, 1985 TVA shutdown both units of SQN due to concerns that
documentation at TVA nuclear sites might be inadequate for environmental
qualification of electrical equipment within the scope of 10 CFR 50.49.
'
This decision was based on the results of a TVA management review of the
environmental qualification activities for compliance with 10 CFR 50.49
at TVA nuclear sites. This review was conducted by TVA staff and Westec
Services, Inc. Based on this decision and the results of the review, TVA
initiated an indepth program to ensure that environmental qualification of
,
.
all electrical equipment within the scope of 10 CFR 50.49 was established
at SQN and all other TVA nuclear sites.
4. FINDINGS
' The NRC inspectors examined the licensee's program for establishing the
qualification of electric equipment within the scope of 10 CFR 50.49.
The program was evaluated by examination of the licensee's qualification
!
documentation files, review of procedures for controlling the licensee's
EQ efforts, verification of the adequacy and accuracy of the licensee's
i 10 CFR 50.49 equipment list, examination of the licensee's program for
maintaining the qualified status of the covered electric equipment, and
evaluation of the licensee's corrective action on the findings of the
l
TVA/Westec management review.
The NRC inspectors determined that TVA had developed and had implemented
a new EQ program which is defined in the program plans of the " Environ-
mental Qualification Project Manual." The licensee had established quali-
fication of the equipment within the scope of 10 CFR 50.49 and had docu-
mented the qualification in E0 binders. These binders also established the
i
installation and maintenance criteria for the equipment. In cases where
i
2
-._. ._. _ _ .-
_ _ . - - - - . . - -. . .
'
?
.-
,
, .
additional activities were necessary to ensure qualification, open items
were identified in the front of the binders and a means of assuring com-
pletion of these activities was established. In addition. ,the plant was
required to verify and to document that all maintenance requirements had
l
been met.
The licensee's EQ Project _(E0P) had generated over 60 Significant Conditions
Report (SCRs) that.affected EQ. The EQP also. identified approximately 30
SCRs that were EQ related but were generated by _other licensee organizations.
These items were being tracked and a method of assuring completion of both
groups of SCRs prior to restart was established. Approximately 12 other
outstanding technical issues, including the effect of mainsteam line break l
(MSLB) superheat in the valve vault, have been resolved or are being followed
to assure adequate resolution, including field modifications if necessary.
The issue concerning MSLB superheat in the valve vault was not addressed
in the preparation of the binders since final environmental conditions
for the vault had not been established when the binders were prepared.
The licensee stated that the binders would be revised to establish quali-
fication of equipment for any changes in environmental conditions once this
issue was resolved.
Based on the inspection findings, which are discussed in more detail below,
the inspection team determined that TVA has implemented a program to meet
the requirements of 10 CFR 50.49. Although some deficiencies have been
identified, qualification of electric equipment within the scope of the
rule will be established prior to SQN restart.
A. E0 Program Procedures
The inspectors reviewed the licensee's program to determine whether
10 CFR 50.49 requirements concerning environmental qualification of.
electrical equipment important to safety had been factored into in-
structions and procedures. The licensee had established a project
within the Office of Engineering (0E) to develop an equipment
qualification program. This project initiated the program, established
the basic requirements and guidelines, developed the_10 CFR 50.49
List, and prepared the EQ binders, that reflect the installed status
of EQ equipment for Sequoyah. The activities and applicable
procedures reviewed durir.g this inspection are detailed below:
(1) Office of Engineering Procedures
Environmental Qualification Project Manual, (EQP-01), issued by
OE, described the methods and format used to document equipment
evaluations required to demonstrate compliance with 10 CFR 50.49.
This manual provided instructions for performing environmental
qualification (EQ) evaluations and for completing auditable EQ
files. The documents for the files were placed in uniquely iden-
tified EQ binders (EQBs). Each binder addressed a generic piece of
equipment that was used in various applications in the plant. All
plant quipment included in each binder was uniquely identified
and traceable to its generic counterpart. Each EQB consisted
of the following sections:
3
__ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
. - - .. -. - .- - .. . - -. .. ..
'
. .
.
4
... .
,
!
(a) Title page referring to the vendor and equipment types
- (b Revision log
'
(c Table of Contents . .
(d Open item and qualification deficiency listing
(e TAB A - Identification of equipment comprising the equipment
'
typ .
(f) TAB B - Checklist for evaluation of environmental qualifica-
tion including summary and conclusion
. (g) TAB C - Analyses and justification
(h) TAB D - Qualification documents
(1) TAB E - Miscellaneous. documents and correspondence
(j) TAB F - Field verification' data
(k) TAB G - Qualification maintenance data sheets
(1) TAB H - Vendor instruction manual
(m) TAB I'- Vendor drawing for equipment.
(n) TAB J - Evaluation of IE circulars, bulletins, and vendor
bulletins
One of the major parts of the EQB was Tab B which was a check-
- list that was used by the binder preparers. By filling out
the checklist properly, the preparer (evaluator) ensured, that
i' equipment.was qualified or corrective ' action was initiated to
bring equipment into qualification. The checklist was compre-
hensive and listed items under each of its major headings that-
the preparer used to aid him in determining qualification. The
'
evaluator's (preparer's) comments for each item on the checklist'
were supported by material in other sections-(TABS) of the EQB.
- This support material was referenced specifically by TAB No. and page
and paragraph number. This detailed checklist allowed the auditor
to quickly find the supporting ' documentation and/or analysis for the
i particular piece of equipment. The checklist consisted of the
following major headings:
2
"
i (a) Documentation
(b) Conclusion of Review
(c) Qualification Criteria
- (d) Qualification Methodology
=
e) Equipment Description
[ f) Installation Interfaces
- g) Test Sequence
h) Aging
i) Material Analysis
'
j) Equipment Electrical Characteristics
i k) Required Operating Environment
j 1) Comparison of Test Conditions to Specified Conditions
- m) Operability Test Results
n) Maintenance and Surveillance
- o) Summary of Review
Another major part of the EQB was TAB G which provided qualifica-
tion maintenance data sheets (QMDS) for each piece of plant
'
equipment that was covered by the tinder. Discussion of QPDS
sheets and how they were used is provided in section 4.B. on
- maintenance.
.
4
!
_ .-_. _ . ,_._._ _ _ _ _ _ _ _ __.-.._ _ _._ _ _ . _ , _ _ - _ _ . - . . . . . _ _ _ . , _ . .
-_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
.
,.
.
.. .
,
Training on the above documents and other Office of Engineering
procedures was required for preparers and approvers of the EQB,
The training records of personnel were audited on a sampling
' basis and were found to be satisfactory.
i
(2) Sequoyah Office of Engineering On-Site Project Documents
TVA had established an on-site Office of Engineering Project
which developed Administrative Instructions specifically
for the 10 CFR 50.49 EQ program. This OE project also acts as
the architect engineer for the site. The following procedures
were reviewed:
(a) Sequoyah Engineering Project (SQEP) Administrative Instruc-
tion, (AI-08A), " Equipment Qualification Program Documenta-
tion." AI-08A specified' how EQBs are maintained and, if
necessary, how new EQBs'will be prepared if this action
' falls within OE responsibility. This document parallels
the requirements specified in EQP-01 which was discussed'
above. AI-08A commits the Office of Engineering to act-
as the architect / engineer for various technical and docu-
ment control activities with regard to the 10 CFR 50.49
program as it affects Sequoyah.
(b) SQEP-AI-11B, " Document Control for EQ Binders and 10 CFR
50.49 List." This instruction provided measures for the
control and distribution of Sequoyah's 10 CFR 50.49 do-
cuments. It discussed how equipment qualification change
notices and Quality-Information Releases (QIRs) are
controlled and how they control changes to EQ binders and
the 10 CFR 50.49 List.
(c) Other Sequoyah Office of Engineering Project Procedures !
'
which had been revised to incorporate changes required by l
10 CFR 50.49 were also reviewed. These procedures were:
(a) SQEP-AI-11, "ECN Handling." This described the methods
to be utilized to handle engineering change notices
(ECNs) and ensure that equipment qualification is
evaluated during the preparation and review of ECNs.
(b) SQEP-AI-11A, "FCR Handling." This described the methods
to control the preparation, review, and approval of
Field Change Requests (FCRs) to ensure that EQ parameters
are considered in FCRs.
(3) Sequoyah Nuclear Plant (Site Power Operations Department)
Documents
Approximately 20 site procedures and instructions were reviewed.
About 1/3 of these procedures / instructions were new and were
specifically written for the 10 CFR 50.49 program. The remaining
2/3 were changed or revised to incorporate 10 CFR 50.49 require-
ments. The procedures provided detailed information and
5
. . . . . .
- . . -- _, . . _ - -.
. ..
,.. .
instructions for the control of 10'CFR 50.49 ' activities and
the implementation of 10 CFR 50.49 requirements at Sequoyah.
Discussions of some procedures and instructions reviewed are
detailed below:
(a) Sequoyah Admin'istrative Standard Practice, (SQA-173),
"Sequoyah Nuclear Plant- 10 CFR 50.49 Environmental-
Qualification Program." This was the site's standard
practice procedure for maintaining compliance to -
10 CFR 50.49 requirements after the issuance and turn-
-
over of the Office of Engineering EQBs and 10 CFR 50.49
-
List. SQA 173 defined responsibilities, interfaces,
and control of both onsite and offsite 10 CFR 50.49
programs that affect the Sequoyah site. This document
'
listed the various implementing documents as they applied
to the 10 CFR 50.49 site program. Some of the responsi-
bilities specified in SQA 173 are assigned to the EQ
Coordinator who was the central figure in the 10 CFR 50.49
,
site program. The Plant Maintenance Superintendent, who
'
was responsible for maintaining the qualification of EQ'
equipment, had identified the Electrical and Instrumentation -
Supervisors as the responsible _ individuals for all EQ main-
tenance activities, even if the maintenance was outside their
discipline. The plant quality assurance staff performed
1
quality control inspections and surveillance of the site's
EQ program.
f
(b) SQt. 174, "10 CFR 50.49 List and E08 Control." This proce-
,
dure was written specifically to control the on-site distri-
bution and revisions to the EQBs and the 10 CFR 50.49 List.
The.QIR was used as the notification vehicle of on-site
initiated changes to these documents. Af ter a modification,-
'
,
which affected 10 CFR 50.49, equipment item was completed, ~
a QIR was used to notify appropriate personnel. OE used
the environmental qualification change notice as the vehicle
to alert users of EQ changes that were accomplished by ECNs.
,
Changes that affect Design Base Events (DBE) require a Design
'
Change Request.
!
(c) SQA 175, " Equipment Information System (EQIS)." The EQIS
was a computer system which was the data base for component
data. Procedure SOA 175 described the controls and require-
!-
ments placed upon the use of the EQIS to ensure an accurate
data base for safety-related (S/R) (especially 10 CFR 50.49)
equipment. Controls were accomplished with software security,
' audits, and administrative controls of data input. EQIS
was utilized as a machinery history record for the " required"
maintenance items on the QMDS for 10 CFR 50.49 equipment.
(d) SQA 161, " Procurement of 10 CFR 50.49 Equipment." This
procedure established the plant requirements for ensuring
that unique technical requirements are met during the
procurement of electrical equipment included under 10 CFR
!
'
6
'a._-
.- ,
- . . - . _ _ - .. . . - - - - - - - - - --- -- . -. -
~~
. . .
. .
,
50.49. This applied to all materials,1 components, and
.
spare parts used dur.ing replacement and maintenance of
equipment. This procedure assigned particular respon-
sibilities and -functions to certain organizations to help
ensure that proper materials and parts are specified,
procured, fabricated, tested, received. . identified, and -
stored to meet and maintain. the technical and environmental
requirements of 10 CFR 50.49 equipment.
(e) Other procedures.and instructions had been revised to
implement the requirements-of the Sequoyah 10 CFR 50.49
program. These documents were reviewed to. determine if '
they included provisions to ensure adequate control of
procurement, maintenance, receipt inspection, storage,
modification, vendor technical information, nonconfor-
mances, and documentation activities associated with
10 CFR 50.49 equipment. Pertinent comments were dis-
cussed and resolved with licensee personnel.- Sequoyah
Nuclear Plant' documents reviewed are listed below:
! SQM 1, " Maintenance Program"
4
SQM 2, " Maintenance Management System"
SQM 57, " Preventive Maintenance Program"
i SQM 50, " Maintenance History and Trending"
AI-4, " Document Control"
AI-11, " Receipt Inspection, Nonconforming Items, QA
Level / Description Changes and Substitutions"
AI-19, " Plant Modifications Af ter Licensing"
AI-23, " Vendor Manual Control"
- AI-36, " Storage, Handling, and Shipping of QA Material"
AI-39, " Critical Structures, Systems and Components
(CSSC)" .
i- ,
SQA26, " Review, Reporting, and Feedback of Operating '
.
- _
Experience Items"
SQA45, " Quality Control of Material and Parts and
! Services"
p SQA125, " Controlled Documents"
SQA134, " Critical Structures, Systems, and Components
(CSSC) List"
(f) Several items of improvement / clarification were discussed
with licensee personnel and are being considered for
inclusion-in future changes to procedures. Improvements
being considered are listed below:
(1) An abbreviation and definition section should be added
to each procedure. This section should follow the
scoping and reference sections such that it precedes
,
the main body of the procedure.
(2) A change should be made to forms (TVA 575 etc.) so
!
that the preparer has to consider and indicate certain
instructions on the form such as:
,
,
i 7
,
1
- - , - ,
e e-- w , r- nn----,_----,,.-m-,-n- - +_ men-- -,------,,--r-.- ----n-.,,,--,------,,n, . .-n-a--- - , ,
'
...
.
10 CFR 50.49 material: Yes No
1)
CSSC: Yes No
2)
At the time of the inspections, this information was
being put on the forms by a rubber stamp.
(3) Deletion of a note and caution note in SQA 45 that is
confusing and not needed in light of requirement that
precedes these notes. That is, delete reference to
the write in phrase, "For General Plant Use" on TVA
Form 575, (See b above).
(4) Correction of several typos identified to the licensee.
These improvement / clarification items discussed with
licensee personnel are not considered significant
relative to meeting program requirements; therefore,
no follow-up during future NRC inspections will be
performed concerning these items.
(4) Training - A training session on the general aspects of EQ was
monitored. The presentation of this training was considered
professional and informative with regard to EQ. The presen-
tation described the history of EQ and discussed the impact of
items such as General Design Criteria, Union of Concerned
Scientists (UCS), IE Information Notices, IE Bulletins, IE
Circulars, Commission Orders, Generic Letters and finally, the
resulting 10 CFR 50.49 Rule (Law). The training session relayed
to the participants the importance of Environmental Qualification
of electrical equipment in potential harsh environments and how
the successful implementation of the program depended upon each
employee.
At the time of the February inspection, approximately 500 licensee
perscnnel had attended this general EQ Training. It was estimated
that approximately 200 more employees were to attend the training.
Training also was required for selected employees on various
Sequoyah 10 CFR 50.49 procedures and instructions. This training
consists of an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Seminar / Training Session. At the time of
i
the February inspection, approximately 75 licensee personnel had
- attended this training course. The licensee stated that approxi-
mately 150 more employees were to attend this training. At the
time of the February inspections, attendance records, for both
these training programs were reviewed to confirm class attendance.
Completion of the above training is considered an Open Item
(50-327/86-01-01; 50-328/86-01-01) which will be reviewed during
the follow-up inspection prior to restart.
I
(5) Nuclear Power Stores Tour
The inspectors performed a walkthrough inspection of the Nuclear
Power Stores. This walkthrough revealed the following:
(a) 10 CFR 50.49 equipment / parts are uniquely identified.
8
.
- _ _ _ . -- . . . _ . . - . -. - _ - - . - . ._-
- _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
,..
.
(b) 10 CFR Part 50.49 equipment and parts appeared to be
' adequately stored.
(c) Some individual parts were separately bagged for
protection and control.
(d) Storeroom areas were being well maintained.
(e) Shelf life items were identified as such and items
examined were within their allotted shelf life.
(f) The control and use of commercial spray can products
(waxes, oils, pest control, etc.) contain detrimental
chemicals was discussed.
(g) Items were easily located and were stacked for easy
access.
(h) Temperature and humidity was being controlled.
A discussion with stores personnel also indicated that no
equipment / parts were being released on TVA Form 575 unless
10 CFR 50.49 or Non 10 CFR 50.49 was designated on the form.
(6) Review of TVA's Internal Audits of the EQ Program
TVA has conducted several audits of the EQ program since it
was established following the shutdown of SQN in August 1985.
These audits have included a management audit in November 1985,
a QA audit in December 1985, an'd an engineering assurance audit in
April-May 1986. These audits included review of the EQP activi-
ties in both Knoxville and Chattangoca, the site's OE project,
,
and the Office of Nuclear Power. The NRC inspectors reviewed the
two issued audit reports and preliminary finding notices from the
engineering assurance audit (the report had not been issued).
The inspectors also held discussions with audit team members.
The reviews of the reports and the discussions with audit team
members indicated that the audits identified some findings re-
quiring corrective action; as well as, some recommendations to
l
clarify or improve certain aspects of the EQ program. Corrective
'
action was being taken by the licensee; however, it had not been
completed. Completion of audit corrective actions is considered
an Open Item. (50-327/86-01-02; 50-328/86-01-02.) which will be
reivewed in the follow-up inspection.
Based on the inspectors' review of procedures, discussions with
licensee personnel, and review of documentation, the inspection team
determined that 10 CFR 50.49 requirements concerning environmental
qualification of electrical equipment important to safety were
factored into the licensee's instructions and procedures and the
licensee had implemented them.
9
- _ - - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
..
..
. .
.
B. E0 Maintenance Program
The NRC inspectors reviewed the licensee's provisions for preserving
the qualified status of equipment qualified to 10 CFR 50.49. Tab G
of the EQ binders provided QMDSs for each piece of plant equipment
that is covered by the binder. The QMDS sheets specified the required
maintenance to ensure continued qualification and listed the recommended
maintenance and/or surveillance activities. The recommendations fcr
maintenance and surveillance activities aid in detecting material or
equipment performance degradation and provide aid in maintaining the
equipment in a qualified state for potential harsh environments.
The NRC inspectors reviewed maintenance procedures SQM 62 ("10 CFR
50.49 Program, Qualification Maintenance Data Sheets Implementation"),
SQM 1, SQM 2, SQM 57, and SQM 58. Procedure SQM 62 addressed the
utilization of QMDS documentation and was written'specifically for
implementation of the documentation. The QMDS documentation is
used by schedulers and maintenance personnel to ensure mairtenance
documents are prepared, maintenance activities are scheduled, and
maintenance work is performed. During the inspectors review of this
procedure and discussions with SQN personnel, the inspectors recom-
mended that the procedure should have the change evaluation, described
' in SQM 57, incorporated in this procedure. The inspectors also re-
commended that the QMDSs " Storage Requirement" should be addressed
in this procedure. SQN personnel stated that these recommendations
would be incorporated in the next revision to the procedure. Incor-
poration of the above revision is considered an open item (50-327/
86-01-03; 50-328/86-01-03) which will be reviewed during a future
NRC inspection.
Appendix C of SQM 62 was used to ensure that all QMDS requirements
and recommendations were accounted for in the maintenance and
surveillance programs. A typical Appendix C form included the
unique equipment identification number, EQ binder number, type of
requirement, frequency of activity, implementation procedure number,
and the responsible site group. The inspectors reviewed six
Appendix C forms which had been completed for 10 CFR 50.49 items.
The inspectors also reviewed records in the instrumentation and
electrical maintenance areas for several EQ Binder QMDS items. This
review included a brief walk / talk through of several QMDS items on
the EQIS and Preventive Maintenance (PM) computer system. This re-
.
view revealed that implementation of the program in this area was
'
being accomplished. The inspectors were advised that all " essential"
,
QMDS items were not complete. These QMDSs are being tracked to en-
sure all are being worked. During the June inspection, the inspectors
reviewed the QMDS status which showed completions ranging from 86% to
96% for Units 1 & 2 in the electrical and instrument areas.
10
.- - - - . . - . . . - . - __
'
. .
.
. .
,
The inspectors review of the licensee's procedures and records
determined that the licensee was implementing a program to maintain
the qualified status of 10 CFR 50.49 items; however, the program was
not complete at the time of the inspection. Since the licensee had
.
not completed the implementation of his maintenance program for EQ-
i equipment, completion of this effort is identified as an open item
c
-(50-327/86-01-04; 50-328/86-01-04) which will be reviewed during
the follow-up NRC inspection.
In addition.to the completion of the licensee's OMDS program, the.
.
inspectors were concerned with the depth of the review the li:ensee
> was performing to ensure a valid qualification baseline was esta-
blished. The licensee based the ' qualification of 10 CFR.50.49
equipment on the assumption that equipment-is installed and main-
tained in accordance with standard vendor.reconenended practices /
procedures. If these are not followed or activities are perforled.
on the equipment outside vendor recemmendations, the qualified
status of the equipment may be affected. While it was determined
during the inspection that the licensee is establishing.a quali-
1
fication baseline for all equipment, there is concern that instal-
! lation procedures and subsequent modification or maintenance acti-
vitie.s on qualified equipment may not have been sufficiently re-
. ,
viewed to determine-if the qualified status of equipment was main-
tained. Examples of this concern are as follows:
(1) During a maintenance inspection at Sequoyah in December,
1985, unresolved item 327/85-45-12 related to the lack of
documented torque requirements on screws holding vendor
supplied mounting brackets on four model 8316 ASCO solenoid
4
valves (1-FSV-63-42, -63-42,-68-305, and -77-20). Based
on the inspector's review
workofpackage
engineering) change notice (ECN)
6487 and the associated (WP 11806. the in-
' spector noted that neither the ECN nor the WP denoted any
special requirements for disassembly or reassembly of these
,
valves to allow for installation. In the above cases one
i
' or both of the valve mounting brackets were removed and no- '
l
screw torque requirements could be identified in the in-
.
sta11ation documentation as required in vendor instructions.
! There instructions need to be followed in order to main-
tain qualification. Since -that inspection, the licensee
,
,-
has ensured that the screws have been torqued in the proper
j sequence and to the appropriate levels.
(2) Paragraph 4.F (1) documents examples of Raychem splices /
bn akouts which were not installed according to vendor
recemmended procedures. While it is acknowledged that
a significant condition report (SCR) had been written
to inspect Raychem breakouts for possible installation
i-
problems, this was only after the problem had been
identified at TVA's Watts Bar Nuclear Plant and not as
a result of any planned activities of the Sequoyah EQ
program in the establishment of equipment qualification
baselines. Additionally, the SCR does not address some
.
of the deficiencies that were identified during the NRC
! walkdown.
.
11
l
'
_ __._.._._ _ ___ _. _-_,_. _.._,..___ __ _ _ _ . __.-,-_m___,_______
. _ . . _ . .__- . _
v.
. .
. .
.
(3) Paragraph 4.F (2) documents the fact that the initial
qualification of ASCO solenoid valves was.used on the-
assumption that'no thread sealant was used at interface
connections; however, the NRC walkdown inspection iden-
tified extensive use of thread sealant on most of the
valves inspected.- Although TVA has now determined that
the use of thread sealant is acceptable within defined
'
guidelines', the use of thread sealant was not pennitted
initially by documentation in the qualification binder.
Based on discussions with the licensee both during and following-
the inspection, it was determined that the licensee has performed
an extensive review of past documentation and . activities relative
'
to. installation, maintenance, and modification of qualified equip-
ment in establishino maintenance baselines for qualified equipment;
L however, the NRC will perform further review of the licensee's main-
tenance baseline activities during the follow-up inspection. _ This
i NRC review of the licensee's maintenance baselines is considered
an Open Item (50-327/86-01-05; 50-328/86-01-05).
C. EQ Master List
The licensee is required to maintain an up-to-date list of the
equipment that must be qualified under 10 CFR 50.49. The list at .
SQN was entitled "Sequoyah Nuclear Unit 1 and 210 CFR 50.49 List." '
The basis for this list was established from the "Sequoyah Harsh
Equipment List.(SQEL)," which is now a historical engineering .
document. The SQEL was a snapshot of the Sequoyah Unit 1 and 2 as
of September 1985. Since the TVA/Westec review, the SQEL had been
carefully reviewed and upgraded to ensure all appropriate equipment
' was included. For ease of access and control, this list was part
of a computer controlled environmental qualification data base.
,
- Considered in the preparation of the 50.49 list and the SQEL were
environmental effects resulting from all postulated design-basis
'
accidents (DBAs) documented in the licensee's Final Safety Analysis
Report (FSAR), technical specification limiting conditions for opera-
tion-(LCOs), and emergency operating instructions (E0Is). Also con-
! .
sidered and reviewed in developing the lists were category and opera-
,
ting time documents, definitions of accident assumptions, and category
! definitions.
!
j In order to assure that the licensee's 50.49 list was being main-
'
tained up-to-date, the inspectors performed an indepth evaluation
- of the following: (1) findings identified during the TVA/Westec
l
review; (2) the licensee's control of engineering change notices
and their impact on the 50.49 list; (3) procedures for maintaining
the completeness of the list; (4) the validity of accident assump-
tions; (5) E01s to confirm that during an accident the operators
will only be referred to reliable equipment assumed not to fail;
and (6) the 50.49 list to verify its accuracy.
r
I
12
4
- ,--n,-- , ~,-,,,,=--.-..-+ww, . _ _ , , , . - . - - , , + - - - - - - - --
mmw.----.-,,--.-=,-.,,----,,,v- e -r,, ,,,,.w_-m,--,
-
-,,mer,,,,,,,,m-.,,-
~
.. .
. .
,
The NRC inspectors reviewed the licensee's corrective action on the
following TVA/Westec review findings for SQN which had an effect on
the validity of the 50.49 list:
Observation No.1-SQN: " Completeness of Sequoyah Listing of
Electrical Equipment Located in A Harsh Environment Required to
Satisfy 10 CFR 50.49
Observation No. 2-SQN: " Lack of Documentation for Identification of
10CFR50.49(b)(2) Items-SQN"
Observation No. 3-SON: " Documentation Discrepancies and Technical
Omissions on Environmental Data Drawings"
Observation No. 4-SQN: " Incorrect Operating Times"
Observation No. 6-SQN: " Traceability of Technical Basis for Sequoyah
Class 1E Equipment List for Harsh Environment"
Observation No. 9-SQN: " Error in Emergency Operating Instruction
(E01)"
Observation No.13-SQN: " Lack of Cable Traceability"
Based on the inspectors review of the licensee's corrective action
on the above findings, discussions with licensee personnel, and
review of available documentation; the inspectors determined, during
the January inspection, that the licensee had taken adequate corrective
action on the findings or was pursuing a course of action relative to
the findings that would ensure their adequate resolution prior to SON
restart.
The NRC inspectors reviewed E01s to determine if they only referred
a reactor operator to equipment and systems capable of surviving any
harsh environment resulting from the associated DBA. This was to
ensure the operator would not be confused by misleading readings and
initiate actions which relied on failed equipment. The E0Is in place
during the January inspection at SQN referenced numerous devices and
control systems which would not survive an accident; however, the
licensee stated that they were in the> process of' upgrading procedures
and expected to have them in place in the near future. As an interim
measure operator training emphasized th'at in an emergency, operators <
,
should not rely on any single indication or parameter as a basis for
action, but should confirm readings by tracking independent associated
parameters. Additionally, the operators were trained to give preference
to instruments of known post-accident reliability. At SQN these in- '
struments were identified on the control console as " Post-accident
Monitoring" equipment. Based on reviews of E01 documentation and dis-
cussions with two reactor operators, the inspectors determined that the
licensee's interim measures were adequate to ensure that operators
would not be confused by misleading readings and initiate actions which
relied on failed equipment.
13
. . . -. .- .. -. . . _
. . - . . . -- . . .
, 7; . .
.
. .
,
t
'
'
'
In verifying the validity of the 50.49 list, the inspectors sampled
approximately 700 items of equipment required to be.on the list. In
i addition, certain other items of equipment which performed safety
functions and which might appear to need to be on the list during a
casual review were evaluated for inclusion on the list. To test the
thoroughness of the licensee's list review, the status of selected
< items in this last category were questioned. The licensee provided
satisfactory explanations why these items were not on the list. .The
'
inspectors also determined that," Post-accident Monitoring" equipment
(R.G. 1.97 Program) were in the process of being installed-in the
plant and added to the list. This effort is scheduled to be completed
by September 1987 during'the licensee's cycle four refueling outage.
U that the lists were complete and accurate prior to SQN restart. Since.
the licensee had an adequate program in place for controlling the
lists and no deficiencies were identified during the inspectors
review, no additional, indepth evaluations of the ' licensee's 50.49-
., list is anticipated during the follow-up inspection.
D. Environmental Qualification Files
,
The NRC inspectors examined 93 EQ binders for SQN Units 1 and 2 to ;'
verify the qualification status of equipment within the scope of
10 CFR 50.49. Two binders (SOL-003 and IXT-001) found acceptable
during a. November 1985 NRR audit were not reviewed during this in-
' spection. Of the total of 95 binders, approximately 50 identified
as "open items" required field work to be accomplished at the plant
in order for the as installed 50.49 equipment to comply with quali--
fication requirements established in the binders. For the binders
,
'
with open items the licensee established a system to verify the
completion of the field work in accordance with binder requirements. .
In addition to comparing plant service conditions with qualification
test data and verifying the basis for these conditions, the inspectors
-
s reviewed areas such as required post-accident operating. time compared
- to the duration of time the equipment had been demonstrated to be
"
qualified; similarity of tested equipment to that installed in the
i plant (e.g., insulation class, materials of components of the equip-
. .
,
ment, testo configuration compared to. installed configuration, and
'
documentation of both); evaluation of adequacy of test conditions;
aging calculations for qualified life and replacement interval
determination; effects of decreases in insulation resistance on
equipment performance; adequacy of demonstrated accuracy; evaluation
.
of test anomalies; and applicability of EQ problems reported in IE
ins /Bulletir.s and their resolution.
The intpectors found that the binders reviewed were readily auditable
o and documented qualification of the equipment except for the
deficiencies described in the following paragraphs.
.
(1) The NRC inspectors' review of the EQ binders discussed below
j. identified significant deficiencies in the binders to the ex- *
tent that qualification of the covered equipment was not esta-
blished when the inspectors initially reviewed the binders. In
these instances the licensee was able to establish qualification
14
'
,
Uw - , , - - , . .- ~~Um.b.._...-,.-,,-,,., s,- . .mm - - - , , - - m---,,,,_,.-. ..m.,,---m-...p,--.,.._ .--_,---e.. - .. . . . - _ _ ,
_
. .
. .
of the covered equipment either by additional data and/or new
analysis not originally included in the binders. The additional
data and/or new analysis was incorporated by the licensee into
t,inder revisions by June 27, 1986. The inspectors reviewed the
resisions and found the binders to be acceptable for establishing
qualification of the equipment; therefore, further review of the
affected binders is not planned. Even though the licensee was
able to demonstrate qualification of the covered equipment and
resolve the inspectors' concerns the items below are identified
as potential enforcement / unresolved items since qualification
was considered to be not established when the initial review of
the binders was performed.
(a) ihe inspector's review of binder ILCV-001, Masoneilan 8012
level control valve (electropneumatic valve positioner),
determined that documentation in the binder did not
adequately demonstrate the ability of the valve positioner
to maintain proportional function during a DBA. The main-
tenance of proportional function was defined in the binder
as being the functional performance requirement of the
positioner. Based on discussions with the licensee, he was
able.to demonstrate to the inspectors that proportional
function was not required for the valve positioner in its
inplant application. The licensee revised the binder to
reflect the positioner's true functional performance re-
quirement and was able to establish qualification of the
positioner to the new requirement. Since the binder did
not establish qualification to the initially defined
performance requirement this is identified as a Potential
Enforcement /UnresolvedItem(50-327/86-01-06;
50-328/86-01-06).
(b) The inspectors' review of binder PENE-002, Westinghouse
modular electrical penetration assembly (EPA), identified
concerns with the use of Arrhenius methodology with a six
hour duration test at 350 degrees F to demonstrate
qualification (post-accident operability) of EPR o' rings
in the EPAs for a 100 day, 115 degree F, post-accident
environment. The inspectors specifically questioned the
validity of extrapoling a six hour test to demonstrate a
post-accident operability requirement of 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> (100
days). Based on discussions with the inspectors, the
licensee revised the binder to include additional data
that established qualification of the EPR o' rings for use
in the EPAs at SQN without using the questioned methodology.
This is identified as a Potential Enforcement / Unresolved
Item (50-327/86-01-07; 50-328/86-01-07).
(c) The inspectors' review of binder CABL-022, Essex power and
control cable, determined that qualification documentation
(qualification checklist, TAB B) did not include a descrip-
tion of qualification test equipment, test equipment accu-
racies, and calibration data. Since this data was not avai-
15 j
!
i
- , , - - , - - - - - , - - , - -. . - . - . - _ _ - - - . .- . . - -
_. - . .- -_. . .-. . . . -_.
~
.
.
'
^
lable, the inspectors were concerned with the adequacy of
the test instrumentation to demonstrate performance of the
,
cable during a DBA. The. licensee resolved this concern by
performing and including in the-binder an error analysis
which demonstrated that-the test profile would envelope
actual DBA conditions even if test pressure / temperature
,
values varied by as much as a minus 20%. This is'
identified as a Potential Enforcement / Unresolved Item
'
(50-327/86-01-08); 50-328/86-01-08). (
'
(d) The inspectors' review of binder SOL-007, ASCO solenoid
-
valve model 206-381, determined that six of the valves
were subject to submergence DBA conditions in the plant
and the licensee was basing qualification of the valves on '
test data during which the test valves were not submerged.
l
Qualification was based on Wyle Laboratories test report
l No. 17523-1 for testing of conduit sealing methods. During
these tests one of the test seals failed and water entered.
the coil cavity of the ASCO valve which was connected to-
,
the seal. Documentation in the report indicated that coil
electrical function was maintained for.114.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into
.
the test. Since the valves were not subject to a complete
submergence test during qualification testing, the . inspectors
considered these six valves' to be unqualified for their-
accident environment. After the. inspectors' concerns were
discussed with the licensee the licensee was able to
-
demonstrate that the six valves would perform their respective
functions prior to exposure to submergence conditions during.
-a DBA. Additionally the licensee demonstrated by a failure
mode effects analysis that any failure of the valves after
submergence would not cause a detrimental effect on the plant
dperation and/or mislead the reactor operator during or
following a DBA. The licensee revised the binder to include
the above information and established qualification for the
six valves for their accident environments. This is-identified
as a Potential Enforcement / Unresolved Item (50-327/86-01-09;
I 50-328/86-01-09).
L
l (e) The inspector's review of binder IMIK-001, Nutherm 32KW
' air duct heater and control components, identified deficien-
cies in the documentation such that qualification was
considered to be not established. These deficiencies
included failure-to adequately document similarity between
tested and installed equipment and demonstrate post-accident
operability after DBA testing. In the case of post-accident
operability, the licensee based operability on thermal aging
tests at 200 degrees F and 100% relative humidity conducted
prior to accident testing. This approach did not consider
the effect of the accident environment on the post-accident '
equipment operation. The binder was revised to address
the identified issues and establish qualification of the i
i
heater. This is identified as a Potential Enforcement /
Unresolved Item (50-327/86-01-10; 50-328/86-01-10). j
16
l
t;~_ . , _ . . _ . - , . _ , . . _ _ .
. _ _ ._ _ . _ . _ _ _ _ _ _
,
..-
,
~
. .
.
(f) The inspectors reviewed binders IRE-001, GA Technologies
3
RD-23 radiation detector, and CABL-042, Brand-Rex coaxial
e cable, as a single item of equipment, since they are used
at SQN in the high range radiation monitoring system'(HRRMS)
which is highly sensitive to cable / detector interaction.
~
The inspectors determined that the detectors' functional
performance requirements (capacitance and insulation
resistance) were not clearly defined in conjunction with
the associated Brand-Rex cable. It was further determined
,
that the licensee had not adequately addressed all
possible issues with regard to the mechanical integrity of
the cable jacket and/or moisture intrusion at detector / cable -
connectors. Of particular concern to the inspectors was
the fact that cracking of the Hypalon cable jacket occurred
during qualification testing of the cable. Since cracking.
of the cable jacket could provide a path for moisture
intrusion and the fact that moisture intrusion adversely
l
affects system operation, the effect on qualification of
the equipment is considered significant. The licensee
+
revised both the detector and cable binders and established
> qualification of both items; therefore, establishing quali-
i
fication of the HRRMS. This is identified as a Potential
Enforcement / Unresolved Item (50-327/86-01-11; 50-328/86-01-11).
'
(g) The inspectors' review of binder CABL-017, Eaton.multiconductor
signal cable, identified that analysis of leakage currents
measured during cable qualification tests indicated possible
errors in instruments circuits could range from 4% (low end)
for transmitters to 15% (low end) for acoustic monitors and
RTDs. Since the licensee had not documented any analysis
relative to the acceptability of these possible errors in
i
either the cable binder or the associated instrument binders,
'
the inspectors were concerned with the ' affect of these errors
'
on plant system accuracy and/or functional performance
.l
.
requirements. The licensee' revised the binder to adequately
address leakage currents and established qualification of
l
i the cable. This is identified as a Potential Enforcement /
Unresolved Item (50-327/86-01-12; 50-328/86-01-12).
(h) The inspectors' review of binders M0V-001 thru -005,
Limitorque motor valve operators, identified one concern
!. with regard to documentation in the binders and the esta-
blishment of qualification of the operators. Of concern
l- to the inspectors was whether or not limit / torque switch
j
compartments of the operators needed to have drains to
prevent moisture / water accumulation in the compartment.
,
Since some operators in the plant were observed to have
long vertical conduit runs coming into the switch compart-
j
'
ments from above, the inspectors were concerned that the .
operators might not be qualified for installations of this
j
,
type. The licensee revised the binders to include additional
information and analysis and established qualification of
i
17
!
-. _ . . _ _ . _ _ _ . _ . . . ~ . _ . . - . . . _ _ . - . _ _ _ . _ _ _ . . _ _ , , . . , . - _ _ _ _ _ . . . _ _ _ . _ . _ . - , . _ . . - . . . . .
- . - .
,
. .
, .
,
the motor valve operator. This is identified as a Potential
Enforcement / Unresolved Item (50-327/86-01-13; 50-328/86-01-13).
Other Limitorque operator concerns were identified as open
.
items and are discussed in paragraph 4.D.(3).
(i) The inspectors of binder CABL-016, Cyprus (Rome) power and
control cable, identified that the calculations to demon-
strate cable post-accident. operability did not reflect the
actual cable operating temperature of 67.9 degrees Centi-
grade for cable 2PL4510B*B, which provides power to electric
motor 0-MTR-31A-28. The file was revised to include cal-
- culations using actual cable operating temperature and
demonstrate post-accident operability. This is identified
as a Potential Enforcement / Unresolved Item (50-327/86-01-
14;50-328/86-01-14).
(2) The following paragraph describes one significant deficiency
identified during NRC binder review which was not corrected
prior to the end of this inspection.
The NRC inspectors reviewed the licensee physical verification
sheets in binder XHTR-001 for Barton transmitters, Lot 7-764.
Based on this review, the inspectors questioned the locations
of five steam generator level transmitters, which were within
3 inches of the postulated accident flood level of 694.5 feet
elevation for Unit 2 containment. The inspectors questioned
the accuracy of the locations and whether the transmitters
might indeed be partially submerged during the postulated flood;
therefore, being unqualified for their plant applications.
Based on the inspectors questions, the licensee. performed another
physical verification of the transmitters locations. The licensee
determined that two of the transmitters were located sufficiently
,
above flood level so as not to affect their qualification. The
other three transmitters were determined to also be above flood
level; however, they were connected to conduit fittings that
were below or at flood level. Conduit fittings below flood ,
levels are not allowed by the licensee's qualification criteria.
Since the conduit fittings were at or below flood level the
qualification of these transmitters was affected. The licensee
documented that transmitter 2-LT-3-38 was qualified in its
4
location since it would perform its function prior to exposure
to flooding and that failure af ter exposure to flooding would
not affect accident mitigation or mislead the reactor operator.
Transmitters 2-LT-3-43 and -56 were identified to be relocated
above the flood level to maintain qualification. The licensee
initiated an SCR to relocate the two transmitters. This is
Potential Enforcement / Unresolved Item (50-328/86-01-15).
(3) In addition to the deficiencies discussed above, the inspectors
review of the E0 binders identified other minor concerns that ,
were classified as inspection open items. These items included l
minor file deficiencies or omissions, clarifying data in the
i
.
binders, correcting minor inconsistencies in the documentation, !
'
1
J
18
. . - .. .. -- -. .- - . - . . - - . - . - . - _ . - - . . - . - - . - . - - . . - . _ - . - - -
- -
'
. .
. ,
and verifying that special conditions of qualification have
been completed. The identified open items were corrected by
the licensee prior to the end of the June inspection. For those
items corrected by the licensee and reviewed by the inspectors
for adequacy, no further action will be taken. Binders which
had inspection open items identified against them and now con-
sidered acceptable are as follows:
(a) ILM-001, Masoneilan 8005A Level Modifier
(b) CABL-010, Belden Signal Cable
(c) CABL-043, Okonite Power and Control Cable
(d) SOL-001, Valcor Solenoid Valve
(e) ITS-002, Static-0-Ring Temperature Switch
(f SOL-006, ASCO Solenoid Valve Model NP8316
PENE-004, Westinghouse Canister Penetrations
(g
(h MOV-001 thru -005, Limitorque Motor Valve Operators
(i) XMTR-002, Foxboro E11GM Pressure Transmitter
(j) CABL-003, AIW Power and Control Cable
(k) CABL-001, BIW Multiconductor Signal Cable
(1) ILCV-001, Masoneilan 8012 Level Control Valve-
(m) CABL-012, Brand-Rex Signal Cable
(n) CABL-021, Essex Power and Control Cable
(o) GEN-001, Generic Binder
(p) CABL-036, Rockbestos Power and Control Cable
4
(4) IE ins and Bulletins - The NRC inspectors reviewed and
evaluated the licensee's activities related to the review of-
EQ related IE Information Notices (ins) and Bulletins. The
inspectors' review included examination of procedures and EQ
binders relative to ins / Bulletins. The procedures reviewed
' detera.ined that the licensee has a system for distributing,
reviewing, and evaltating ins / Bulletins relative to equipment
within the scope of 10 CFR 50.49 and that they are addressed in
'
appropriate equipment EQ bincers (Tab J of the Binder). During
the EQ binder reviews, the inspectors evaluated the' licensee's
l
actions with respect to applicable ins / Bulletins. The
inspectors identified no deficiencies during this review.
E. TVA/Westec Review Findings
In addition to the E0 binder reviews discussed above, the NRC
inspectors evaluated the binders relative to the licensee's
corrective actions on the qualification file related findings
identified in the TVA/Westec Management Review Report, dated
September 25, 1985. Since the findings were indicative of overall
programmatic deficiencies in qualification documentation, the
licensee did not specifically address each and every finding of the
report. Instead, he addressed the findings generically by
developing and implementing a new EQ program which is defined in the
program plans of the " Environmental Qualification Project Manual."
This program was designed to correct all the file related findings
generically. The licensee used this new program to completely
re-establish his qualification documentation for SQN. It was his
re-established documentation which was reviewed by the inspectors.
19
-. . - -. . _ . - - - - - -- - - - _ , --.
--_-,,.__l
. . - . - -
'
. .
- ,
.
TVA/Westec findings which are covered by the above approach are:
~
Observation No. 5-SQN: " Lack of Cable Qualification Documentation"
Observation No.- 7-SQN: " Deficiencies in SQN-NEB-XX-62 Westinghouse
Motor Evaluation"
Observation No. 8-SQN: " Deficiencies in MEB-72-025 Westinghouse -
Motor Evaluation for CS Pump Motors"
Observation No. 10-SQN: " Deficiency in EQS SQNEEB-RM-1 General
Atomic Radiation Monitors Qualification Evaluation"
i Observation No.11-SQN: " Deficiencies in SON-NEB-XX-55 Barton 764
,
Transmitters" .
,
!
Observation No. 12-SQN: " Deficiencies in Qualification File
MEB-30-66, 2-FC0-30-109 and 2-ZS-1-181 Namco Limit Switches"
Observation No.14-SON: " Cable Qualification File Deficiencies"
Observation No.15-SQN: " Cable Submergence Qualification Requirements"
c
Note: Discussions of licensee corrective action on other SQN TVA/Westec
findings is provided in paragraph 4.C.
'
Since the licensee took the generic approach regarding the TVA/Westec
- findings, the inspectors were unable to individually trace corrective
action on each and every finding. However, the inspectors had access
-
to the TVA/Westec report and as they reviewed EQ binders of equipment
specifically discussed in the SON portion of the report, they
evaluated the binder relative to the report findings. For example,
l
' Namco limit switch binders, 125-001 thru -004, were reviewed to
~
ensure that findings on Namco limit switches from the TVA/Westec report
i were adequately addressed in the binders. This type of a review was
performed for equipment associated with the observations listed above.
Additionally, the inspectors also reviewed report. findings for SQN
specific cable qualification files for generic application to binders
for cable not reviewed during the TVA/Westec review.
In order to determine whether findings on Browns Ferry Nuclear Plant
and Watts Bar Nuclear Plant were considered in the binder preparations
for SQN, the inspectors reviewed the findings for these plants. These
.
j
findings were considered for equipment specific applicability as
well as generic applicability in reviewing the SQN binders.
The inspectors review of the EQ binders identified only one concern ,
relative to the findings of the TVA/Westec report. This concern i
related to documentation of TVA's definition of functional performance
. requirements for electrical cable. This finding was identified in
1
the report as Observation 12 at Browns Ferry and was considered to
l have generic application to all cable binders. This concern was
20
-
' '
. .
.
discussed with the licensee and he was able to demonstrate that
cable functional performance requirements were considered in the
preparation of the cable binders. Based on the concern, the
licensee included a section to his " Generic" qualification binder to
document how he was considering functional performance requirements
in preparing his cable binders. Even though he had not finalized
his Generic binder, at the time the concern was identified, the
licensee provided a copy of the added section to the inspectors and
they found it adequately addressed the concern.
F. Plant Physical Inspection
The NRC inspectors, with component accessibility input from the
licensee, selected more than 150 items of equipment for physical
inspection during the plant walkdowns. The items selected for.
inspection were chosen based on the inspectors' review of the EQ
binders, knowledge of potential problems with equipment installations
based on previous experience, and equipment located in the most severe
environmental zones (emphasis was placed on inside containment equip-
ment). An equal division of inspection items between Units 1 and 2
was sought and was considered to have been reasonably accomplished.
During the physical inspection, the inspectors examined characteristics
such as mounting configuration, orientation, interfaces, model number,
ambient environment, and physical condition. Only two concerns were
identified as having an effect on equipment qualification; however,
other observations which had no effect on equipment qualification
were documented.
(1) The plant walkdown inspection for Raychem type NMCK, NPKV, and
WCSF-N splices (including motor connector kits and cable break-
outs) ' covered by binders MCK-001, MCK-002, and SPLC-001 identified
instances of improper splice installations. Splices were obser-
ved to be bent too sharply and sleeves over Raychem breakouts were
observed to be too short. Equipment where -improperly installed
or questionable splices were observed were:
- Limitorque motor valve operators 1-FCV-3-47, 2-FCV-3-47,
1-FCV-1-15, and 2-FCV-3-136B
- Conduits 2V3035A and 2V30438 located in the Unit 2 annulus
- Pump motor 1-PMP-070-046
- Unit 1669 pipe chase cooler air handler blower motor
- Unit 1201A pipe chase cooler blower motor
- Motor 2-AHU-030-157
21
_ _ .
.._ . _ . . -. - __ _ ._ - _ -_ _ _ _ _
- .-
, ,
.
An SCR had been written, prior to the June inspection, requiring i
inspection of approximately 850 Raychem breakouts; however, the l
plant walkdown indicated that all splices should be inspected i
'
to determine if they have been properly installed. This is a
Potential Enforcement / Unresolved Item ,(50-327/86-01-15;-
50-328/86-01-16).
(2) During the walkdown inspection of solenoid valves, in particular
'
- ASCO solenoid valves covered by binder 50L-006, the inspectors
observed extensive use of thread sealant on most all valves
inspected. Since the valve qualification binder stated that
thread sealant should not be used on the valves, the inspectors
raised questions about the use of thread sealant in the plant.
The licensee was able to demonstrate to the inspectors that the
use of thread sealant was acceptable and he revised the solenoid
binders to reflect the use of thread sealant within defined
guidelines. This concern was treated as an open item which was
corrected during the inspection and is considered resolved as
'
identified in paragraph 4.D.(2).
!
(3) While the observations documented below do not directly effect
equipment qualification, they are considered significant with _
regard to plant cleanliness and/or overall equipment maintenance.
4
'
(a) In general, housekeeping in the plant was not considered good,
especially in the valve vault and inside containment. The
inspectors recognize that work was going on in the plant, but a
housekeeping cleanup is necessary prior to plant startup.
(b) Mirror insulation on line near valve 2-FSV-63-172 had fallen
several feet below line.
i
(c) In RHR pump room 1A-A, flex conduit was rubbing against remote
'
manual operated valve, 1-74-5240. Work request WR 108311 has
been written. Also conduit bracket on conduit to motor
,
1-MTR-30-175 was pulled off the wall. Work request WR 108313
has been written. (Both work requests were written during the
I inspection.)
I
i (d) Corrosion, rust, loose solenoids, packing leaks, and/or other
miscellaneous observations were pointed out to TVA personnel by
the NRC inspectors on the following valves:
,
I 1-FSV-30-17,-58,-69
! 1-FSV-87-8
'
1-FCV-62-74
t- 2-FSV-62-72,-73,-74
2-FSV-77-9,-18
i
,
(e) On large 10-12" pipe near 2-FSV-30-15 and -50, RHR system MOV
i (Limitorque), packing leak was observed with crystallization
,
and corrosion on valve bonnet.
,
22
l
. _ _ . . _ - . _ . _ . _ . . _ _ _ _ . _ _ _ .
..=
'
.
.
.
_
(f) On valve 2-63-598 SIS Test #2 connection - packing leak was
observed along with evidence of seat leakage. Crystallization
was observed at valve tailpiece which was open to atmosphere.
(g) Valve 2-FCV-63-71 SIS Line, was unsupported except for its
piping (potential seismic concern). Packing leak was observed
along with evidence of body to bonnet leakage. Valve 2-FCV-63-70
was also unsupported.
(h) Two screws were missing or not installed properly on Masonelian
valve 1-LVC-3-174 and one screw was missing on 2-LVC-3-175.
(1) Corrosion was observed on screw holding Cutler-Hammer terminal
block in junction box 2-JB0X-991-1505.
(j) Plant ID Tags were missing on both Unit I hydrogen analyzers.
(k) Westinghouse pressure transmitters, 1 and 2-PT-30-0310A and
,
-0311B, were marked with a safe working pressure of 12 psig;
however, TVA claims a safe working pressure of 120 psig.
Nameplate should reflect proper pressure.
(1) Some cable, plcnt ID Tags were observed to be missing and/or
broken during walkdown.
-
(m) Mirror insulation was observed to be dented and crushed in
several places. Concern was expressed as to whether or not the
insulation was damaged sufficiently to be detrimental to the
insulation's thermal properties.
>
(n) Terminal blocks in Limitorque operator for valve 2-FCV-3-136B
were very dusty. Terminal blocks in Limitorque operator for
valve 2-FCV-3-15 were dirty and grimy. Drops of oil were obser-
ved in the bottom of the limit / torque switch compartment for valve
.
2-FCV-3-15.
(o) The flex conduit for position indicating limit switch on valve
2-FCV-77-18 was broken. Work request B132944 was issued.
Since the above observations were considered to be maintenince
,
oriented and they do not directly effect equipment qualification,
they have been referred to Region II for consideration in their
operational readiness review prior to SQN restart.
G. Employee Concerns
' The NRC inspectors reviewed lists of concerns from the TVA Employee Concerns
program to identify those that were considered to have potential effects
on the SON EQ Program. These identified concerns were then reviewed to
3
- determine if they affected the EQ Program. If it was determined that they
did affect the program, they were reviewed to determine if they had ade-
quately been resolved in the current SON EQ program. The following concerns
were reviewed by the inspectors.
23
.
~,
r ,,,n, , - - , - - - - , . . - - - , , - - - , , , - - -+ . , . . . . , , .
-
..w-~e.r,-n-~,,-.,.,-,,,,--.y--,,--ww e-,-,.,-----v.,m..,e-
. .- . - - . . ..--- - -
'
.
.
,.
(1) XX-85-122-014: Environmental Qualification of Electrical and I&C -
equipment and components is inadequate. This concern is being
addressed by the current program and will be corrected when TVA
completes their current program and the NRC issues a SER accepting
(2) XX-85-094-013: . It is the quality problems regarding environmental
< qualification of components per NUREG 0588 that made the Sequoyah
plant shutdown. The comments of (1) above apply to this concern.
'
'
(3) IN-85-463-007: Relocation of equipment. This concern dealt with the
possibility that equipment purchased for one application might be used
in another application'for which it was not suited and this would not
be known because appropriate equipment documentation might not be kept
>
with the equipment. Of particular concern was the transfer of equip-
ment between different TVA plants. This concern was identified as
4
'
still open on the revised lists; however, the NRC inspectors did not
identify any instances of EQ equipment being used in inappropriate
applications during their EQ program review. Equipment reviewed had
'. documentation to support its use in its plant application and provided
traceability to its manufacturer. No further review of this concern
- is planned at this time by this NRC' team.
(4) In-85-964-003: Material / equipment is ordered dedicated to a specific
.
system, unit, etc., but is frequently installed /used elsewhere and it
is unknown if documentation is revised to reflect this cannibalization.
This concern was still open on the reviewed lists. The comments.
,'
regarding NRC review of conern (3) above apply to this concern.
(5) XX-85-027-X03: TVA informed NRC tha~t cable had been removed from site
--Refer-
in 1981. The cable was still being removed from site in 1984.
ence NRC SQN EEB 8019R1 --Closed. The inspectors reviewed this concern
and determined that the cables in question, cable types PJJ and PNJ,
,
were used in EQ applications at SQN and their qualification was
>
covered by the current EQ program. The qualification of these cables
was documented in binders CABL-001, -015, -020, and -034.
These binders were reviewed by the NRC inspectors and found to
support qualification of these cables. Since qualification was
,
i-
established for these cables, no further review of this concern is
- planned.
I
(6) MAS-85-002 and MRS-35-005: Raychem on 2-FCV-43-77 --Closed. TVA
did not verify this problem and the NRC inspectors did not look
at this specific splice. However, the inspectors did examine other
.
1
' Raychem splices at SQN and identified a Potential Enforcement /
Unresolved Item (see paragraph F.(1)) which must be corrected prior
-
to restart.
i
l
!
,
' 24
.
~ +r n,v,,-- ,.,m ,,v-..y w,,, v,.,.,wm,m-,e.e,ngr w ,-e.ww --o n - a, nw- m nng n n -,- a m -. , . , - . - , ,-,,me.---..,.,wgnn,n, - , , - - -- , . - , - e,,...,.
.
. .
(7) MAS-85-003: Cable splice on CCS pump motor --Closed. TVA determined.
that cable 1PL4735 was the cable in question for this concern and the
splice was performed per 11-10, Rev._11, which required Raychem heat-
shrink. The inspectors did not look at this specific splice, but
the findings discussed in (6) above are applicable to this concern.
The NRC inspectors have identified other concerns that have the potential
for effecting EQ equipment. These will be reviewed during the NRC follow-
up inspection prior to SQN restart.
.
>
>
25