ML20215M960
| 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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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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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
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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
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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.
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Should you have any questions concerning this letter, please contact me or
Mr. Gene Imbro at 301-49'c-9671.
Sincerely,
gC[$0$ $NO
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G
a s
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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
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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
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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.
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Enclosure
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.Sequoyah Inspection Items Requiring Additional Information (cont'd)
5.
ELECTRIC POWER
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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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From TVA's response for this item, it was not clear that TVA's operating
experience with the current setting of overloads (between 15-30 seconds of
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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
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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-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.
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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
conditions, and section 8.4 requires that test data be provided to support this
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proof of performance.
IEEE Std. 323-1974, Section 4.3 requires that
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qualification demonstrate that the equipment was capable of meeting its
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performance specifications under the service conditions. The absence of a
hydrostatic test requirement after seismic qualification testing requires TVA
to make an assumption that seismic qualification testing did no damage to the
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instrument pressure boundary.
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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
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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
during a follow-up inspection.
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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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Distribution:
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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
Regional Administrator, II
CRStahle, NRR
TMNovak, NRR
ELD
CGC
WECline, RII
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