ML20215M960

Forwards Description of Items to Be Inspected for Determination of Acceptability of 861030 Response to Insp Repts 50-327/86-27 & 50-328/86-27.Encl Info Should Be Made Available by 861117

ML20215M960
Person / Time
Site:	Sequoyah
Issue date:	10/30/1986
From:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Mason C TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8611040050
Download: ML20215M960 (7)

See also: IR 05000327/1986027

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NUCLEAR REGULATORY COMMISSION

- WASHINGTON, D. C. 20555

i o o ***# OCT 'l 01986

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Docket Nos. 50-327

and 50-328

Mr. C. C. Mason

Acting Manager of Nuclear Power

Tennessee Valley Authority

6N, 38A Lookout Place

1101 Market Street

Chattanooga, Tennessee 37402-2801

Gentlemen:

SUBJECT: INSPECTION REPORT 50-327/86-27 AND 50-328/86-27

5 This refers'to your letter dated July 28, 1986, in response to our letter dated

April 22,1986, which forwarded the report of a special inspection to examine

.

design control practices for the Sequoyah Nuclear Power. Plant conducted by the

NRC's Office of Inspection and Enforcement (IE). IE has evaluated the

corrective and preventive actions documented in your letter.

Certain of the items require additional information and review to assess their

acceptability. The enclosure to this letter describes these items, including

specific concerns regarding individual responses.

Resolution and follow-up inspection for the items in the report will be handled

by IE and/or Region II. The enclosure to this letter describes areas that will

be inspected by the team. However, the team will not necessarily be limited to

the items in the enclosure; the team may also inspect other inspection items

before drawing final conclusions regarding the adequacy of your response to the

subject inspection report.

Please have the information described in the enclosure to this letter available

by Noven;ber 17, 1986, which coincides with the second phase of the upcoming NRC

design control inspection. No reply to this letter is requested.

In accordance with 10 CFR 2.790 (a), a copy of this letter, the enclosure, and

your response letter dated July'28, 1986, will be placed in the NRC's Public

Document Room. '

Should you have any questions concerning this letter, please contact me or

Mr. Gene Imbro at 301-49'c-9671.

Sincerely,

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gC[$0$ $NO

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a s .T r, Director

Of ice of spection and Enforcement

Enclosure: Sequoyah Inspection Ite

Requiring Additional Information

cc w/ encl: See Page 2

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.

. -Mr. C. C. Mason -2-

cc w/ enc 1:

Tennessee Department of Public Regional Administrator, Region II

Health - U.S. Nuclear Regulatory Commission.

ATTN: Director, Bureau of. 101 Marietta Street, N.W., Suite 2900'

Environmental Health Services Atlanta, Georgia 30323

Cordell Hull Building

Nashville, Tennessee 37219

J. A. Kirkebo

ATTN: D.'L. Williams Mr. Michael H. Mobley, Director

. Tennessee Valley Authority Division of Radiological Health

400 West Summit Hill Drive, W12 A12- T.E.R.R.A. Building

,

Knoxville, Tennessee 37902 150 9th Avenue North

& Nashville, Tennessee 37203

.

Mr. Bob Faas

Westinghouse Electric. Corp. County Judge

P.O. Box-355 Hamilton County Courthouse

Pittsburgh, Pennsylvania ~15230 Chattanooga, Tennessee 37402 .

R. L. Gridley

Tennessee Valley Authority

SN 157B Lookcut Place.

Chattanooga, Tennessee 37402-2801

M. R. Harding .

Tennessee Valley Authority.

Sequoyah Nuclear Plant

P.O. Box 2000

Soddy Daisy, Tennessee 37379

Resident Inspector /Sequoyah NPS

c/o U.S. Nuclear Regulatory Commission

2600 Igou Ferry Road

Soddy Daisy, Tennessee ~37379

H. L. Abercrombie

Tennessee Valley Authority

Sequoyah Nuclear Plant

P.O. Box 2000

Soddy Daisy, Tennessee 37379

.

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1. BACKGROUND

The TV'A response (Reference 1) to the NRC Special Design Control Inspection

report (Reference 2) has' been evaluated by the Office of. Inspection and

Enforcement. Certain items are consicered open based on a need for additional

information, confirmatory inspection, clarification of the response, or an

inadequate response. In addition, the corrective actions relating to these

items and other items identified in Reference 2 are subject to confirmatory

inspection. The references are listed in Section 7 of this enclosure. The

section numbering in this enclosure is consistent with that used in the

original report.

2. MECHANICAL SYSTEMS

No additional information is needed in this area.

3. MECHANICAL COMPONENTS

e

Deficiency D3.3-5, Pump Fundamental Frequency

TVA's response to Deficiency D3.3-5 is inadequate. TVA designed and installed

pumps and associate piping at Sec;uoyah based on a pump fundamental frequency

criterion of 33 Hz, a criterion that TVA did not meet for the pump and

associated piping identified in this deficiency, or for other pump / piping

subsystems, since TVA indicates that the " extent of this condition has not been

established at this time." TVA considers that the design of the pump and

associated piping identified in this deficiency "is a representative situation

for existing floor-mounted safety-related equipment with rigid attached

piping." The team believes that reanalysis of this configuration with a pump

spring-mass model derived from the pump dynamic analysis is necessary to

substantiate the adequacy of this subsystem. The deficiency remains open.

The generic implications of this item should also be assessed.

4. CIVIL / STRUCTURAL

Deficiency 04.3-1, Evaluation of Structures for Reinforcing Bar Cuts

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This item concerned TVA's lack of analysis and evaluation of the impact on

structural integrity in cases where steel reinforcing bars were cut during

modifications. An example was steel bars cut during installation of a new

penetration in the pressurizer compartment.

The team considers that the response by TVA is not adequate. TVA has not

performed any analytical work to resolve this issue. TVA stated that the

reinforcing bar cuts were approved, reviewed, and verified by engineering

judgment. The team is concerned that this engineering judgment was not

adequately documented, at least to the extent of identifying whether the

reinforcing bars cut were in the low stress zones. TVA should evaluate, at

least on a sample basis, the effects of cutting reinforcing bars at the

Sequoyah site.

1

Enclosure

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v w w m m L w :. w w w m n m

.Sequoyah Inspection Items Requiring Additional Information (cont'd)

.- 5. ELECTRIC POWER

Deficiency D5.3-1, Temporary Alterations Using Temporary Alteration Control

Forms (TACFs)

This item concerned the use of TACFs for permanent changes to the plant, and a

lack of independent verification of drawing changes associated with TACFs. TVA

stated that a procedure, to be issued by September 1, 1986, will address

Division of Nuclear Engineering safety evaluation of open TACFs.

However, the TVA response did not address team concerns regarding procedural

controls for TACFs, including requirements for independent verification of the

as-built drawings, review of TACFs and the associated follow-up documents by a

responsible design organization, and restriction of use of TACFs to temporary

changes in the plant. TVA should address requirements for these activities to

allow resolution of this item.

Unresolved Item US.3-3, Motor Operated Valve Thermal Overload Trip Setting

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I From TVA's response for this item, it was not clear that TVA's operating

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experience with the current setting of overloads (between 15-30 seconds of

locked rotor current) adequately reflects design basis situations (For example,

operation during degraded voltage conditions considering that the travel time

for several motor operated valves exceeds 30 seconds.) Similarly, relative to

testing, it is not clear that the testing was conducted by simulating degraded

voltage conditions. It appears that TVA has not demonstrated that the thermal

overload settings of safety-related motor operated valves will not cause a

spurious trip during travel when operating under worst case degraded voltage

conditions where duration of the travel can be more than 30 seconds.

This item will remain open pending determination of testing and/or analysis by

TVA which demonstrates that the existing settings will not cause a spurious

trip during travel while operating under worst case design conditions.

Unresolved Item US.3-5, Loss of Control Power Annunciation

This item concerned the lack of annunciation of loss of control power to the

auxiliary feedwater pump. In their response, TVA noted that this was a generic

condition, and that this function had been previously implemented by a status

monitoring systen which was removed during a modification. TVA plans to

restore annunciation for loss of control power as originally committed to when

the licensee proposed transfer of this annunciation to a technical support

center system. The licensee stated that NRR will review the final design

concept and the interim measures for implementation of requirements of

Regulatory Guide 1.47. This item is closed for the purpose of this inspection

as this constitutes an open licensing issue to be resolved between TVA and NRR.

6. INSTRUMENTATION AND CONTROL

Deficiency D6.1-1, AFW Pump Discharge Pressure Switch Ratings

AFW pump discharge pressure switches 1-PS-3-148, -156, -164, and -171 that

provide a safety-related interlock to position AFW bypass control valves were

replaced on two separate occasions with equipment from different manufacturers.

For each of these replacements, the team found no evidence that apparent

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di

-Sequoyah Inspection Items Requiring Additional Information (cont'd)

• pressure integrity before and after the seismic qualification test, a second

vendor that supplied instruments connected to the reactor coolant system had

not.

_

TVA response states that the requirements for seismic qualification and

hydrostatic pressure test are totally independent of one another. The team

disagrees with this position on the basis that a hydrostatic test after seismic

qualification testing is the only effective means to demonstrate that the

pressure boundary safety function of the instrument has not deteriorated. For

example, IEEE Std. 344-1975, Section 8.1 requires that equipment performance

requirements be demonstrated when the equipment was subjected to seismic test

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conditions, and section 8.4 requires that test data be provided to support this

, proof of performance. IEEE Std. 323-1974, Section 4.3 requires that

i qualification demonstrate that the equipment was capable of meeting its

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performance specifications under the service conditions. The absence of a

l- hydrostatic test requirement after seismic qualification testing requires TVA

to make an assumption that seismic qualification testing did no damage to the

instrument pressure boundary.

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I To validate this assumption for the Static-0-Ring (SOR) NX-JJTTX6 differential

pressure indicating switch, TVA committed to an onsite pneumatic pressure test

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to 2982 psig for the onsite instruments and a pressure test to 3000 psig by the

hN __- instrument supplier or Action Laboratories for the particular unit used during

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the seismic qualification. The team intends to review these test results

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during a follow-up inspection.

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l The TVA response did not indicate whether this condition was limited only to

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the 50R instrument procurement identified by the team. The response also did

not provide a commitment that future safety-related pressure boundary

instrument procurement activities would require a post-seismic hydrostatic

pressure test. Additional information is required from TVA on these topics.

7. REFERENCES

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(1) Letter and enclosure, R. Gridley, TVA, to Dr. Grace, USNRC Region II

regarding Inspection Report 50-327/86-27 and 50-328/86-27, " Response to

Deficiencies and Unresolved Items," dated July 28, 1986.

(2) Inspection Report 50-327/86-27 and 50-328/86-27, forwarded by J. Taylor

letter dated April 2E, 1986.

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Mr. S. A. White

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Distribution:

DCS ,

PDR

LPDR

DQAVT Reading

QAB Reading

RArchitzel, IE

RLSpessard, IE

EVImbro, IE

HMiller, IE

BKGrimes, IE

JMTaylor, IE

RStarostecki, IE

HRDenton, NRR

GZech, RII

BBHayes, 01

KPBarr, RII

BDebbs, RII

SRConnelly, OIA

ELJordan, IE

JYoungblood, NRR

HThompson, NRR

DMuller, NRR

Inspection Team (8)

ABelisle, RII

JHolonich, NRR

Resident Inspector

NSIC

Regional Administrator, II

CRStahle, NRR

TMNovak, NRR

NTIS

ELD

CGC

WECline, RII

IE:DQAVT:QAB IE:DQAVT:QAB IE:0QAVT:DD

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REArch}tzel EVImbro H'JM,i l ler esi RLSpessard RS tecki

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