ML20235T195
| ML20235T195 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/17/1987 |
| From: | Carfagno A, Triolo S CALSPAN CORP. |
| To: | Singh B NRC |
| Shared Package | |
| ML20235T197 | List: |
| References | |
| CON-NRC-03-81-130, CON-NRC-3-81-130 TER-C5506-623, NUDOCS 8707220064 | |
| Download: ML20235T195 (42) | |
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{{#Wiki_filter:.- ______- _ D a TECHNICAL EVALUATION REPORT y NRC DOCKET NO. 50-327, 50-328 FRC PROJECT C5506 NRCTAC NO. -- FRC ASSIGNMENT 37 s N RC CONTRACT N O. NRC-03-81 130 FRC TASK 623
. EVALUATION OF NUCLEAR SAFETY REVIEW STAFF CONCERNS KEQUIRING RESOLUTION BEFORE AND AFTER RESTART TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 -
I TER-C5506-623 Prepared for l Nuclear Regulatory Commission FRC Grou? Leader: G. J. Toman 1 Washington, D.C. 20555 NRC Lead Engineer: B. K. Singh w July 17, 1987 This report was prepared as an account of work sponsored by an agency of the United States i Government. Neither the United States Government nor any agency thereof, or any of their ) employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, appa-ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights. Prepared by: Reviewed . Approved by: l #1
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TER-C5506-623 CONTENTS Section Title Pace 1 INTRODUCTION . . . . . . . . . . . . . I 2 '
SUMMARY
AND EVALUATION OF SEQUOYAH RESTART ISSUES AND PRCPOSED TVA VERIFICATION AND CLOSURE ACTIONS . . . . 3
~2.1 . Issues Addressed in TVA Report R-86-02-NPS (2 Items) . . 3 2.2 Issues Addressed In TVA Report ECTG-NSRS-01 (8 Items) . . 4 2.3 . Issues Addressed in TVA Report ECTG-NSRS-02-(17 Items). . 11 3 EVALUATION OF' NON-RESTART ITEMS. . . . . . .. . . 25 4 CONCLUSIONS. . . . . . . . . . . . . . 37 4.1 Restart Issues. . . . . . . . . . . . 37
'4. 2 Non-Restart Issues. . . . . . .. . . . . 37 5 REFERENCES . . . . . . . . . . . . . . 39 iii 4
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' FOREWORD l1 This Technical Evaluation Report was prepared by Franklin Research Center (FRC)'under a contract with the U.S. Nuclear Regulatory Commission (Office of'
'i_ . Nuclear Reactor Regulation) for technical assistance in support of NRC
-l;l operating reactor licensing actions. The technical evaluation was conducted
.in accordance with criteria established by the NRC.
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- 1. INTRODUCTION The Nuclear Safety Review Staff (NSRS) of the Tennessee Valley Authority (TVA) issued 151 reports between October 1979 and August 1985. These reports are now ref erred to as " classical" NSRS reports. The reports described the results of internal TVA audits of the performance of various TVA organizations with respect to activities affecting the TVA nuclear program. Of the 151 reports, 63 reports were either directly related to the Sequoyah plant or to TVA organizations which controlled engineering, construction, procurement, quality assurance, training, operations, and maintenance of the Sequoyah plant.
In a letter from W. F. Willis (TVA) to H. R. Denton (NRC) dated September 6, 1985, TVA listed, by identification number and topic, all of the " classical" NSRS reports which had been issued and also identified 43 reports as having findings which had not been resolved (open items) as of August 31, 1985. Twenty-two of the reports having open items were either directly or indirectly associated with the Sequoyah plant. In a letter from R. L. Gridley (TVA) to B. J. Youngblood (NRC) dated April 4, 1986, TVA provided NSRS Report R-86-01-SQN that described "close-out" actions for open items contained in previous " classical" NSRS reports and identified five remaining open items specific to the Sequoyah plant. TVA closed two additional items relevant to the Sequoyah restart in its Nuclear Managers' Review Group (NMRG) Report R-86-02-NPS [1]. TVA report ECTG-NSRS-01, Rev. 2* [2), dated January 30, 1987, which was issued by the Employee Concerns Task Group (UTCG), subsequently addressed 8 items affecting the Sequoyah restart, including the 5 previously identified in the April 4, 1986 letter and additional items identified in NSRS report R-86-01-SQN. Another 17 items were identified in TVA report ECTG-NSRS-02 [3] dated January 16, 1987, as requiring closure before the Sequoyah restart. ECTG-NSRS-02 also identified 69 open NSRS recommendations that require resolution following restart. TVA has prepared a Sequoyah Activities List (SAL), hted March 27, 1987, which lists the activities to be completed at the Sequoyah plaat. This list
- Revision 1 was issued on December 23, 1986.
4 TER-C5506-623 , contains all the items to be completed before the restart of Sequoyah Unit 2. Items listed in the ECTG-NSRS-01 and -02 reports as requiring completion prior f to restart should also be listed as restart items in the SAL.
'The purpose of this report is to:
o Identify the " classical" NSRS issues requiring corrective action before the restart of the Sequoyah plant and those that may be resolved following restart. o Document a programmatic review of the corrective actions by TVA to resolve the NSRS issue (inspection of corrective actions to be performed by NRC). o Verify that TVAs classification of " classical" NSRS items as restart and non-restart is acceptable. 1 o Evaluate the status (open or closed) and corrective action of each
' item as described by TVA reports DCTG-NSRS-01 and -02 and NMRG report ,
R-86-02-NPS. o Determine if the actions for closure of restart issues were or will be acceptable. j I
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- 2.
SUMMARY
AND EIALUATION OF SEQUOYAH RESTART ISSUES AND PROPOSED TVA VERIFICATION AND CLOSURE ACTIONS Two items related to the restart of the Sequoyah plant were addressed in TVA's NMRG report R-86-02-NPS. The TVA report ECTG-NSRS-01 identified 8 items as needing corrective action before restart of the Sequoyah plant. Report-
- ECTG-NSRS-02 identified an additional 17 restart items. TVA corrective action has resulted in the closure of 5 items; the remaining 22 are still open, pending completion of TVA action. Table 1 indicates the current status of all restart items. Each restart item is summarized below. The item numbers with the alphanumeric codes SQN, WBN, NPS, and OE/NUC PR indicate the site or TVA entity to which the issue origina11v applied, i.e., Sequoyah, Watts Bar, Nuclear Procedures Staff, and Office of Engineering / Division of Nuclear Power, l respectively.
2.1 ISSUES ADDRESSED IN TVA REPORT R-86-02-NPS (2 ITEMS) R-85-03-NPS-07, Common Mode Failure f I NSRS recommended that a program be developed which would provide a method of avoidinc common mode failure. The Office of Nuclear Power responded that a f program in accordance with the Nuclear Quality Assurance Manual (NQAM) would be. implemented. In a follow-up review, NSRS ascertained that Mechanical l Maintenance Section Instruction Letter MMSL-A36 adequately addressed the I problem of maintenance-initiated common mode failures with two exceptions. f' 1. NSRS recommended that common mode failure caused by the use of the same calibrated tool on redundant pieces of equipment be addressed in MMSL-A36. l l 2. NS25 did not agree that using two qualified craftsmen constitutes redundancy of people. NSRS recommended that the phase "... or two qualified craftsmen should be assigned to the work," be deleted from l MMSL-A36. f A subsequent NSRS Sequoyah review identified that the two changes to 1 MMSL-A36 have been made. It also verified that foremen were being trained to MMSL-A36. Therefore, this item was closed for Sequoyah. TVA's corrective action is adequate; closure of this item is justified. 1 i s _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-_a
TER-C5506-623 R-85-03-NPS-08, Surveillance of Maintenance Program This item is with the USNRC Office of Special Projects to verify closure. 2.2 ISSUES ADDRESSED IN TVA REPORT ECTG-NSRS-01 (8 ITEMS) The Nuclear Safety Review Staff (NSRS) reviewed activities at the Sequoyah Nuclear Plant from 1979 to 1986 and had recognized 42 open items requiring follow-up review for closure. NSRS conducted its final review of open items in February 1986 and closed 38 in report R-86-01-SQN. The Design Quality Assurance Branch, within the Division of Nuclear Energy (DNE), then conducted a review of all open items applicable to Sequoyah to identify those items that must be resolved before Sequoyah restart. As a result, five items were identified in surveillance report S-86-10 as needing resolution before startup. These were transmitted to the Sequoyah Engineering Project Manager on February 14, 1986. Subsequently, the Nuclear Manager's Review Group (NMRG) identified eight open restart items, including the five provided by DNE and additional items addressed in NSRS report R-86-01-SQN. These eight items are reviewed below. R-80-05-SON-04B, Configuration Control The NSRS recommended a revision to the configuration control program because discrepancies were noted between the "as-constructed" drawings and the actual plant configuration of critical systems, structures, and components (CSSC). Accordingly, a number of actions were taken by TVA, including: independent review of the drawing control program, performance of plant walk-downs, and review of engineering changes to ensure that they are incorporated in the drawings. A Sequoyah Design Baseline Verification Program was established to address the design control issues. This item remains open by TVA until completion of the Design Baseline Verification Program by TVA. TVA's corrective action, implementation, and verification methodologies are adequate to resolve this issue. This item was not identified in the ECTG-NSRS-01 report as a SAL restart item. TER-C5506-623 '
.i R-84-19-WBN-01, Clear Identification of Purpose and Use of All Controlled Documents at All Plants The NSRS review of an independent vendor report noted findings where logic / control drawings did not agree with the electrical drawings and recommended that all controlled documents should be clearly identified for all plants. It also recommended that the purposes and uses for each document be i specified and that superfluous information should be deleted and discrepancies 'in documents be corrected. An as-built drawing control system should also be given a high priority. In a follow-up review, NSRS stated that the recommen-dation had not been fully complied with since it referred to all TVA plants and the response addressed only the Watts Bar plant.
TVA stated in its ETCG report that the status of this restart issue needs to be examined at the Sequoyah plant. It further stated that it should be , verified that planned actions will ensure that the information errors on , control and logie diagrams are corrected, and that until this verification is made, the item will remain open for TVA. In 1.6 ETCG report, TVA identified this resolution of the NSRS recommenda-tions as a restart item (No. 140) on the SAL. Implementation of the recommend-ed corrective action is adequate to resolve this issue R-84-19-WBN-07, Development of Criteria for Cable Tray Fill Level and OC Inspections s The NSRS in its original review at Watts Bar was concerned about the cable routing system when they observed that cabling in many areas exceeded the height of the side rails of the cable trays, even though the tray seemed to have sufficient area to lay cable below the side rails. TVA used a computerized system to route cables and to limit the fill in the cable trays. Although this system was used to assist and to document what was actually accomplished in the field, the computer system could not be used as a final acceptance vehicle without some verification of what existed in the field. Therefore, NSRS recommended development of criteria for field use to control actual tray fill levels and to provide a basis for QC inspection. This was applied to Sequoyah.
d TER-C5506-623 In the E'ICG report, TVA identified this recommendation as being on the SAL as restart-item No. 0172. Implementation of the NSRS recommendations is adequate to resolve this issue. [ \ l R-85-02-SON /WBN-02,' Maintenance, Operating, and Test Instructions { l i l :The NSRS recommended several changes to maintenance, operating, and test i instructions for high-pressure seals so that sufficient precautions and.other measures can be taken to preclude degradation of these high-pressure seals. Accordingly, TVA made changes to its instructions and training to ensure that work on high-pressure seals will not be done while the system is pressurized. The NSRS in report R-86-01-SQN identified the following specific actions as remaining to be done to close this issue:
- 1. Issuance of the proposed MI-1.11, " Thimble Tube Installation" which will replace Special Maintenance Instruction (SMI)-1-94-5.
- 2. Issuance of the proposed revision to SMI-0-94-3 that requires the use of an appropriate thread lubricant and cautions against allowing fitting bodies to turn.
- 3. Further revision of SMI-0-94-3 to include a precaution against working on the high pressure seals when the primary system is pressurized above atmospheric pressure.
- 4. -Revision of appropriate instructions to preclude pressurizing the primary system with the thimble tubes disconnee.ted from the overhead '
path transfer system or preclude any work on the seals with the ,; primary system pressurized above atmospheric pressure and the thimble tubes disconnected from the overhead path transfer system, l According to a memorandum dated April 18, 1986, Sequoyah has issued i MI-1.11, and SMI-0-94-3 would be revised by May 1, 1986. Also, MI-1.9 and 1[ MI-1.10 with MI-1.11 and the revision to SMI-0-94-3 would assure item 4 above. The ECTG verification analysis indicated that SMI-0-94-3, Revision 2 was issued on June 27, 1986. The work instructions include the use of thread lubricant. MI-1.9, revision 7 was issued on September 9, 1985. It was revised to incorporate changes in response to NSRS Report R-85-02-SQN/WBN. It provides for QC hold points, inspection of threads of high pressure fittings, and application of lubricant to threads. MI-1.10, revis2on 3 was issued on I 1 l
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' September 9, 1985. It was revised to include changes in response to NSRS report R-85-02-SQN/WBN. The instruction precludes maintenance on the high pressure fittings while the primary system is pressurized above atmospheric or head pressure from the guide tube. MI-1.11 was issued on July 10, 1986, replacing SMI-1-94-5. The work instructions are clear, and provisions for verification by the cognizant engineer and QC inspector are included.
No further action is needed by Sequoyah, and hence the item is closed. TVA's corrective action and methodology were adequate to close out this issue. I-85-06-WBN-01, Adequacy of the Dispositions for Identified Cable Bend Radius Problems In its original review at. Watts Bar, NSRS could not find sufficient . justification or engineering basis for bending cables to less than the industry standard valuea,. Bending to a radius less than minimum could cause premature failure of the insulation because of overstressing in the area of the bend, potentially invalidating the environmental qualification certification of the cable. NSRS recommended that the Office of Engineering (OE) establish minimum bend radius values that are fully supported by a manufacturer's test data. Accordingly, TVA took corrective action which includes stress calculations and an independent laboratory test of cable samples for environmental qualification. The results of these efforts were also applied to Sequoyah. TVA has taken actions to justify the reduced bending radius for some cables and is correcting the bend radius on certain 5-kV cables; howevt.r, the ETCG report concludes that the engineering tests, reviews, and analyses are fragmented and do not resolve concerns for irreversible damage to spiral wound shiel'ds on cables and the effect of excessive bending on the cable's qualifi-cation. The NRC staff has been actively pursuing bend radii and cable pulling concerns with TVA. Information concerning cable bend radii at the Sequoyah plant was requested of IVA by letter dated August 4, 1986. A Technical Evaluation Report issued on February 19, 1987 discusses unresolved issues relating to the bend radii issues. _7
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TER-C5506-623 L This item is considered open by TVA pending review of the Technical Evaluation Report and resolution of NRC concerns.
.TVA'has not identified a means to resolve .e ETCG concerns and has not responded to cable bend radii issues raised in Lne February 19, 1987 Technical Evaluation Report. Therefore, there is no b: sis for stating that actions by TVA will provide adequate resolution of the concerns. The ETCG report did not j identify the item as a restart issue on the SAL.
The cable bend radii assue is in the Sequoyah Nuclear Performance Plan' ) and is being reviewed by the NRC. I-85-06-WBN-02, Adequacy of the Program for Cable Pulling Activities NSRS found that control of the cable pulling program was inadequate ; J
.. and inconsistent with the accepted industry standards and practices. NSRS recommended that OE management revise relevant documents and procedures and establish a program for evaluation of the condition of the installed cable.
Accordingly, TVA performed calculations and lab tests which show that cable has not been damaged. TVA has taken actions to justify its cable pulling practices. The NRC requested-information regarding cable pulling at Sequoyah in its letter dated
, August 29, 1986. The NRC attended a meeting on cable issues at Sequoyah on s .
. September 23 and 24, 1986.
a The ETCG considers the issues open because TVA has not concluded that an in-service inspection program i: not needed or that the tests performed are adequate to justify the as-installed condition of the cable. In the ETCG report, TVA has not identified the means to resolve this issue. Insufficient information is available to conclude that TVA's approach to resolution will resolve the cable pulling concerns. The issue was not identified in the ETCG report as a restart item on the SAL. Cable pulling is an issue in the Sequoyah Nuclear Performance Plan, which is being reviewed by the NRC.
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'I-85-06-WBN-05, Underdevelopment'of Established and D)cumented Limited QA Program and Failure to Incorporate the Established Limited QA Program into NOAM In its original review at Watts Bar, NSRS noted that the. limited Quality
' Assurance (QA) program as established in the Office of Engineering Design and Construction (OEDC) . instruction was inadequate. NSRS recommended that the Division of Quality Assurance (DQA) identify the required "special controls" applicable to systems previously identified as " limited QA" in the Nuclear Quality Assurance Manual (NQAM). This recommendation was applied to Sequoyah.
'TVA's corrective action for the Sequoyah plant was to issue plant proce-
<ures describing the limited QA program requirements. As of the Licensee's submittal, the plant procedures were still under review;.therefore, this item remains open by TVA.
TVA's corrective action and implementation methodologies are adequate to resolve this issue. This review is not identified.in the ETCG report as a restart item on the SAL. R-86-01-SON-01, Improvements in Overall As Low As Reasonably Achievable (ALARA) Program NSRS recommended that additional specific actions should be taken to. strengthen the ALARA program at Sequoyah. These were:
- 1. Determine the appropriate Health Physics (HP) technician staffing level required to perform ALARA duties effectively during normal and off-normal working hours. A job-task analysis could be used to-determine an effective staffing level.
- 2. Establish an ALARA review committee composed of members from the major functional areas with the responsibility for overall coordination of the ALARA program.
- 3. Increase employee participation in the ALARA employee suggestion l program.
- 4. ALARA coordinators should be assigned to all functional organiza- '
- tions, e.g., modifications, operations, maintenance, test, design, and site services to provida these groups with the expertise necessary to support all aspects of the ALARA program.
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- 5. An ALARA program should be prepared and given to those individuals direc1y. responsible for the ALARA plant efforts, e.g., ALARA :
Committee members, department coordinators, plus those individual . responsible for preparation of ALARA pre-plans and post-plans. The training program should incorporate as basic elements: the physics , of radiation; fundamentals of radiation attenuation; types of i' radiation sources; review of industry experience; and methods to reduce exposure. Sequoyah responded to the above recommendations'in a memorandum dated April 18, 1986. These responses were:
- 1. The Health Physics section will be reorganized. Stafhng levels and job functions are a major part of this reorganization.
- 2. SQN site management does not endorse the need for a formal ALARA committee at this time. Each manager, supervisor, and site worker is charged with the responsibility of implementing ALARA practices and philosophy in his daily activities. The site ALARA goals are achieved through the efforts of all site personnel.
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- 3. The site HP section will do more to promote the ALARA suggestion j program. Increased communication and feedback on man-rem savings should be made available to all site employees. A form of reward is ;
imdav consideration by the HP supervisor at this time. {
- 4. The HP section has made a shift supervisor available to the maintenance planners; however, refer to item 2 for management !
direction on separate committees and coordinators.
- 5. An ALARA training program that was previously developed is to be revised and presented in a manner that will complement items 2, 3 and 4, above.
Although Sequoyah did not endorse a formal ALARA committee, TVA verified I that the plant was responsive to an HP reorganization, training need, and HP shift supervisor availability to maintenance planners. TVA also verified that corporate changes identified in the Nuclear Performance Plan, Volume II have
' improved the ALARA program with respect to minimizing employee exposure and improving regulatory performance.
TVA's actions are adequate to close out this issue. No further action as needed by Sequoyah. This item is closed.
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2.3 ISSUES ADDRESSED IN TVA REPORT ECTG-NSRS-02 (17 ITEbE) l Following preparation of-report ECTG-NSRS-01, which addressed the 8 items
. reviewed in Section 2.2 of this report, Sequoyah and ECTG reviewed all NSRS open items. Seventeen additional items were identified by ECTG as requiring
. closure before startup. Sixty-nine additional items were considered applicable to Sequoyah, but were not considered startup items. The 17 startup items are t reviewed below.
R-80-05-SON-10, Adequacy of Containment to Withstand Tornado Damage
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The NSRS recommended that the design of the Sequoyah containment be
$- reviewed to determine-if it is adequate to withstand the effects of depres-surization and missiles caused by tornados. Other specific problem areas identified were the diesel generator exhaust stacks and roof penetrations,
- dieselgeneratorbuilding,refuelingwaterstoragetank,primarywaterstoragk tank, condensate storage. tanks, and the 480-volt shutdown transformer rooms on elevation 749 of the auxiliary building. TVA's Office of Engineering Design
. performed additional analyses to verify the tornado adequacy of the structures
[ I at Sequoyah and issued reports to NSRS on May 13 and August 8, 1980. These j analyses were reviewed and approved by NSRS except for the omission of tornado i protection criteria for the temperature monitoring system. This was addressed on the final report dated December 22, 1981. 1 i i TVA has addressedstornado protection at Sequoyah. TVA's corrective approach is adequate; however, this issue remains open for TVA until verification interviews by TVA as described in the ETCG report are completed. i This verification is not identified in the ETCG report as being on the l l SAL as a restart item. l R-82-07-WBN-06, Visual Inspection of Welds Through Primer This is a Watts Bar issue applied to Sequoyah. The NSRS concern was that l the weld sampling program conducted to justify the visual inspection of welds !
- j. through carbo-zine primer was not adequately documented. The NSRS recommended that TVA prepare a report describing this program and providing technical 1
t A TER-C5506-623 justification. This was an employee concern identified by QTC. This issue I~ was identified as an item to be resolved at Sequoyah before plant restart. A review of QC welding procedures at the Sequoyah plant incicated that inspec-tion of welds after painting was prohibited. The TVA review concluded that no inspections were performed through primer at Sequoyah. Confirmation interviews are being performed by TVA. This issue remains l \ , open for TVA until confirmation by personal interviews by TVA is completed, l TVA's corrective action and verification methodologies are adequate to resolve this issue. This is employee concern element report WP-02-SQN, which is under review by NRC. The resolution of the NSRS issue is not identified in l the ETCG report as a restart issue on the SAL. l I R-82-08-NPS-10C, Iscuing of Directives Contrary to TVA Commitments An NSRS review found that issuance of water quality analytical procedures a was inadequately controlled and documented. Inconsistencies were found between Nuclear Steam Supply System vendor procedures and ASTM standards. TVA is developing a new system of Office of Nuclear Power policies, directives, stan-dards, procedures, and instructions to govern its nuclear activities. An interim chemistry program is being developed at Sequoyah with policies and procedures to correct these inconsistencies. Representatives from each TVA site involved will return to their respective sites and implement the new program. This will be in place before Sequoyah restart. This issue remains open by TVA pending implementation of the chemistry I l program. TVA's corrective action and implementation methodologies are satisfac-to ry. TVA did not identify resolution of this issue as being on the SAL. 4 R-84-07-WBN-1, Pipe Support Calculations Destroyed An NSRS review of pipe support calculations at the Watts Bar plant indicated that calculations performed by Energy Data Systems (EDS) had been l destroyed and no quality records existed to verify the adequacy of the pipe supports. NSRS recommended that the calculations be recreated and maintained
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.as TVA quality. records. As a result, it was necessary to determine the status of EDS-designed calculations at the Sequoyah plant.
Engineers visited the EDS offices and, using the Sequoyah plant systema
. listing, extensively sampled the EDS pipe support calculations. They identified 100 percent of either the original calculations or structural
. verification calculations. It was concluded that no pipe support calculations
. were destroyed for Sequoyah. The Department of Nuclear Engineering is in.the process of documenting the availability of these calculations.
This item remains open by TVA until documentation by TVA of the status of Sequoysh pipe support calculations is finished. TVA's approach to corrective action is satisfactory. This is an issue in Volume II of the TVA Nuclear performance Plan being reviewed by NRC. This was not identified by the ETCG report as a restart item on the SAL. i l R-84-17-NPS-10, Commercial Grade Items with QA Level I and II Designations TVA purchased commercial grade items from vendors not having a QA program, and assigned the equipment a quality rating. NSRS recommended that TVA ensure that all equipment rated as QA level I or II has either been purchased from a vendor with a proper QA program or upgraded by TVA through testing or receipt inspection. To resolve this concern, TVA made revisions to f the corporate level Nuclear Quality Assurance Manual (NQAM), detailing } requirements of a " dedicated" program of commercial grade items for basic component use. Plant procedures will be modified to reflect the revised NQAM requirements. This item remains open by TVA until the implementation by TVA of revised I procedures is verified. TVA's approach to corrective action is satisfactory; however, components installed prior to change of procedure should be evaluated for proper QA designation. The ETCG report did not indicate that this issue is a restart item on the SAL. R-84-17-NPS-11, Quality Verification for Commercial Grade Item _s r NSRS concluded that the QA program at TVA was not capable of providing ) [ 1 assurance that commercial grade components used in safety-related applications L ____ _________________________________.________.U
I I II TER-C5506-623 l would function as intended under all conditions. NSRS recommended that a 1 receipt inspection program, including testing or a comparable effort, be i established for replacement commercial grade items that would be dedicated as basic components or parts. This would provide assurance that the item would 'j l function as intended. ) A corporate level procedure containing program requirements for a {
" dedication" program of commercial grade items for basic component use was to have been issued by October 15, 1986. The procedure had not been issued as of l
December 12, 1986. This item remains open for TVA until the procedure is issued and implementation verified. TVA's approach to resolving this issue is I adequate; however, components installed prior to change of procedure should be i evaluated for proper QA designation. TVA has not identified this issue in the ETCG report as a restart item on the SAL. R-84-17-NPS-12, Receipt Inspection of QA Level I and II Items by Field Quality Engineers NSRS found that, regarding the procurement of QA levels I and II material and commercial grade items to be dedicated as basic components, receipt inspection between Field Quality Engineering (FQE) and Power Stores was , inadequate. NSRS recommended that all such items be receipt inspected by , Field Quality Engineers or others qualified to ANSI N45.2.6. As a corrective i action, the Nuclear Quality Assurance Manual (NQAM) was to be revised to
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require receipt inspection by qualified QC inspectors. Part III, Section 2.2, 5.2.4 of the NQAM dated June 20, 1986 would require item inspection and explain how receipt inspection should be performed. This item remains open for TVA until revised plant procedures reflecting j NQAM requirements are implemented and verified by TVA. TVA's approach to i corrective action is adequate; however, components installed prior to change in procedure should be evaluated for proper QA designation. This issue was not identified in the ETCG report as being on the SAL as a restart item. R-84-19-WBN-6, Instantaneous Trip Settings of the Breakers for Motor-Operated Valves The NSRS report stated that the instantaneous trip settings for motor-operated valve breakers were set too high at the Watts Bar plant. If the
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J TER-C5506-623 4 1 . l ' breakers are set too high,'the circuit that the breaker is protecting may be - L damaged under overload conditions and the plant margin of safety reduced. This - issue was applied to Sequoyah. NSRS stated that TVA should ensure that the I 1 instantaneous trip settings at Sequoyah are in agreement with the National Electrical Code (NEC) or another comparable standard. NSRS also recommended : that the instantaneous trip breakers should be verified to be set in' agreement . with the intent of the NEC. The documentation for the. design as well as for the testing and operation of the. equipment should reflect the proper trip setting values. NSRS recommended that the program be implemented throughout TVA. i Documentation of the original selection of trip settings cannot be j found. TVA is preparing new calculations to verify existing trip ratings. Breakers with unacceptable trip settings will be replaced. 1 This item remains open for TVA until acceptable trip settings are verified for all'the valve operator breakers at the Sequoyah plant. , TVA's corrective approach and verification procedure are adequate to resolve this issue. The ECTG report does not state that this item is a restart item on the SAL. This item is also related to Employee Concern element reports, Engineering 237.1 and 237.2, which are being reviewed by NRC.
'I I-84-34-SQN-03, Availability of Material Certification I
NSRS found inadequacies in the compilation and control of required ! mate! rial certification. In particular, it was uncertain whether the Sequoyah Heat Number Sort printout included only material with acceptable certifica-tion. NSRS recommended that a history of the Sequoyah Heat Number Sort be reconstructed to establish the program's purposes, controls, functions, and data quality. Sequoyah has set up a Heat Code Traceability Task Group (HCTTG) to resolve all material traceability issues. This item remains open for TVA pending ECTG acceptance of the HCTTG
'I corrective action plan by T*,'A. TVA's approach to resolving this issue is adequate. This is Employee Concern element report, Material Control 40703, which is being reviewed by NRC. The ETCG report did not state that this issue was on the SAL as a restart item.
.I TER-C5506-623 I-85-06-WBN-3, Voltage Drop and Short Circuit Current Determination and Verification For Watts Bar and Sequoyah, the NSRS recommended that voltage drop and short circuit current calculations for level 3 power circuits be done. If the j voltage drop is excessive, the equipment being supplied may not have sufficient starting voltage in all cases. Excessive short circuit current could result in cable damage beforn 'he protective devices trip. TVA is.
performing electrical calculations to resolve this concern for the Sequoyah plant. To prevent recurrence, engineering procedures are being revised to , ensure proper documentation of electrical design. This item remains open for TVA pending completion and necessary review. ; TVA's approach to resolving this issue is satisfactory. This item is not identified in the ETCG report as being on the SAL as a restart item. This is ; an issue in Volume II of the Sequoyah Nuclear Performance Plan, which the NRC is reviewing. I-86-101-SQN, Wire Bend Radius in Installations Using Conax Connectors The NSRS concern was that the Conax connectors in the containment did not always meet vendor wire bend radius requirements and that connector installations with deficiencies were inspected and accepted by Sequoyah quality control. This concern was determined to be valid by an NSRS investigation. Wire bent at too small a radius may cause insulation damage. Inspection and rework of all Conax connectors at Sequoyah has been completed. Work requests and special maintenance inspection (SMI) data must still be reviewed. This item is open for TVA, pending approval by TVA of work requests and SMI data package by Quality Assurance. 7Ve carrective action and verification methodologies are adequate to resolve this issue. This is Employee Concern element report, Quality Assurance 80203, which is being reviewed by NRC. This item was not identified in the ETCG report as a restart l issue on the SAL. a 3 1 i
TER-C5506-623 P-85-08-0E/NUC PR-01, Inadequate Procedure for Equipment Qualification by Similarity The NSRS. determined that the environmental qualification (EQ) procedure for electrical equipment at Sequoyah allowed qualification by " similarity," but provided no criteria defining a "similar" item. NSRS recommended that these criteria be established and incorporated into TVA procedures on qualifying electrical equipment and be used to re-evaluate the qualification of electrical equipment that was qualified by similarity. TVA is addressing > EQ in the Sequoyah Nuclear Performance plan. Existing TVA procedures in the EQ Project Manual provide the guidance and analytical approach for qualifica-
! tion by similarity. TVA considers this guidance and the documentation in the i
EQ binders as adequate. It was noted that EQ requirements, including quali-
} fication by similarity will be included in a new Office of Engineering ,
interface document, NEG-DI-125.01. Preliminary reviews of EQ documentation and interviews with EQ personnel by the ECTG indicate that qualification by
$ similarity has been adequately addressed. Additional review of the guidance documented in the EQ project manual is being conducted by the ECTG.
This item remains open by TVA until the DCTG reviews are complete. TVA's approach to rccc1ving this concern is adequate. NRC is reviewing EQ in its ij review of the Sequoyah Nuclear Performance Plan. It is recommended that EQ documents using the similarity method be reviewed by an outsidewexpert before closure of this issue. This issue is not identified in the ETCG report as a restart item on the SAL. R-85-08-CE/NUC PR-02. Inadequate Procedures for Initiating and Processing
, NCR-FE/ERs NSRS concluded that procedures for processing nonconformance reports i (NCRs), failure evaluations (TEs), and engineering reports (ERs) were I inadequate to assure timely initiation and processing.
NSRS recommended in-depth review of TVA's program and possible changes to provide for effective interface between participating TVA organizations, establishment of centralized tracking, and significant reduction in the time required for processing dispositioning. A Management Task Force was established in April 1985 to assess TVA's procedures for handling conditions I i . _ _ _ _ _ _ _ _ _ _ - -
o TER-C5506-623 adverse to quality (CAQ). This assessment resulted in the revision of TVA l procedures controlling CAQs. A preliminary review has indicated that adequate procedures are now in place for the CAQ process. A TVA commitment to provide effective and timely corrective action for a CAQ is in the Sequoyah Nuclear Performance Plan, which is being reviewed by the NRC. The ECTG is still reviewing the timeliness of processing and adequacy of centralized tracking under the current system. Until this review is completed, this item remains open for TVA. TVA's approach to resolving this issue is satisfactory. This issue is not identified in the ETCG report as a restart issue on the SAL. R-85-08-0E/NUC PR-03, Lack of Priority on NCR Initiation NSRS found that NCRs on Sequoyah containment pressure differential transmitters were not initiated in a timely manner. It was recommended that a Office of Engineering (OE) policy be defined and documented regarding the priority of operating plant activities related to safety and quality. In response, TVA revised its procedures controlling the priority treatment of CAQs. All CAQs are immediately documented, reported to management, and assigned specific periods for issuance of the report. In addition, an employee training plan was initiated, to be completed in the OE and at the ; Sequoyah site by 1985. ECTG review indicated that employee training and adequate procedure I changes regarding the priority of work activities have been completed. This item was closed by TVA. I TVA's corrective action is adequate; closure of this item is justified. j l R-85-08-0E/NUC PR-04, Lack of Engineer Awareness of NCR-FE/ER The NSRS concluded that some engineers were unfamiliar with procedures and time frames for handling NCRs, FEs, and ERs. The NSRS recommended estab-1 lishment of a formal training program on the OE procedures for initiating and ; processing NCR-FE/ERs. A comprehensive OE training program was established to . 1 Employee training has been completed, but ECTG is correct this situation.
*e .
TER-C5506-623 still' reviewing thr. training documents. TVA commitment for training DNE and Sequoyah site personnel in the CAQ process is in the Sequoyah Nuclear Performance Plan, which is being reviewed by NRC. The Plan states that site personnel involved in implementing the revised CAQ procedures have completed training. This item is open for TVA, pending completion oi the ECTG review. TVA's corrective approach is adequate. This review is not identified in
! the ETCG report as a restart item on the SAL.
t
.j.. R-85-08-0E/NUC PR-05, Lack of Timeliness in Initiating and Processing .i NCR-FE/ERs s
The NSRS found evidence that the OE frequently exceeded the specified
-i
- time requirements for processing NCRs, FEs, and ERs. It was recommended that.,
the necessity for compliance with NCR, TE, and ER initiating and processing 9
~} requirements be emphasized to all involved OE employees. 7ecordingly, TVA completed employee training regarding this issue.
Training documents for DNE and the SQN site are being reviewed by ECTG. Pending results of the review, this item remains open for TVA. J TVA's corrective approach and verification methodology are adequate to resolve this issue. The ECTG review is not identified in the ETCG report as a i restart item on the SA(, R-b3-08-0E/NUC PR-06, Failure of Management to Correct Problems with Timeliness f and Responsiveness Involving the NCR-FE/ER Process The NSRS was concerned that there were problems with timeliness and responsiveness in identifying, (.ocumenting, and correcting nonconforming conditions adverse to quality. Therefore, NSRS rec.ommended that improved i manag'ement controls be established and that the audit activities be intensified in the areas of NCR, FE, and ER procedural compliance. Accord-ingly, TVA changed procedural and management control systems and also took actions to increase both the depth and frequency of verification activity involving all aspects of the CAQ process. r u - _ _ _ - _ _ _ - _ _ -
TER-C5506-623 The ECTG review.of CAQ verification activities is in process. Pending. results of the review, this item remains open for TVA. TVA's approach to resolving this issue is'sa'tisfactory. The review by ECTG was not identified in the'ETCG report as a restart item on the SAL.
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,gpend,hA .yto TVA Report ECTANSR$-02 identiflu 69 of ten items from:
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t m., oLc 1 i N h .3 p, j ! O 'i. ", F.u stad.t Requirement Cr(t[ri'a ' ,, jfl P$ t , m p' The. f $11owing criteria shall be used in evaluating whether a particular i ' ,i tw itNnr3uct be,k A 4 resolved priop to restart of unit 2 at Sequoyah. m( '
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1c' ' The item ide;'.tsfies a specific deficiency which has significant
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y- a o gy 3 . 4j 0* 2. t Theitemidentidiesaprogrammaticdeficiencywhichharlahigh ,\ f'"a s probability 90 causing or has causes a specific deficiency .which l,
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ineets No, O Abovid 1 ' 'd- i * (%f M i1 ' Mob: To a2aist in tne determination of re3uired for restart relatave to technical t,pecificatice, W it/ criteria No. I and a i s v ...Y s No,' 3 abobe, an affirmative answer to any of the following i i, ~' (' quectN w/irequi.rss snsiderat{on of the item"for restart based as1 -
. on' technical specification requirurA:nts., r s
- a. Does 'the item directly and adversely affect safety-related e ,
equipment fun.: tion, performance, reliability, or respor.se , time? a e sr
' -Does the item indirectly and adversely affect safety-related t- ' 'N'b. equipment power supply, air supply, cooling, lubrication, or x ventilation? s
- c. Does the item adversely effect primary containesnt integrity? j
~
, 3
- d. Does the item adversely affee' secondary containment i
( integrity? 3 t 7f .
,W ,
y ,, , it r; e. . Does the itera adversely affect,. control room habitability? y[' g f . 'Voty the item adverse 2r af.tect systems used to procesr-i 4 ' racicactive waste? ' i+1 \ ,
Defs the item adversely affect fire protection or. fire loads?
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- ,I TER-C5506-623
.bljk( , ' h, c-h4 h .' Does the' item adversely affect the ability of a system or f$ evmponent to meet'its' safety function during a design basis Ry event by. impacting the seismic analysis, single failure z
[
- M criteria,' separation criteria, high energy line break assumptions, or, equipment qualification?
((. , .. .
- i. Are the programs such'as Radiological Health, Security, Radiological Emergency Preparedness, or Quality Assurance
'which are necessary for safe conduct of operation of the plant adversely.affacted?-
- j. 'If not corrected prior to restart, could it lead to an uncontrolled release or spread of ' radioactive contamination ;
m x; 'beyond the regulated trea?- '
- 3. The item identifies'a specific deficiency that results in a failure p to comply with NRC regulations and no variance has been approved by I the NRC.
i
; 4. .TVA has committed to the NRC to complete the item prior to restart, l
- 5. The item identifies a specific deficiency which has a significant 4 probability of leading to a personal injury during plant operation. l
- 6. The item identified a specific condition which has a. forced outage risk (probability X outage length) during~the next cycle in excess of f the' critical. path time to correct the condition prior to restart."
s Table'2 contains the list of 69 items identified in ECTG-NSRS-02 by TVA as non-restart' issues. These items have been reviewed according to the above criteria and their status as non-restart items has been confirmed. An' l C, evaluation of the "non-restart" classification is provided for each item.
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a . y, TER-C5506-623 -{
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Table 2. Listing of 69 " Classical" NSRS Recommendations. j c Requiring Resolution'Following Restart of Sequoyah !
- a. and Evaluation of Classification by TVA- j I
i 1 Item and Description Evaluation of Non-Rectart Classification ]
'79-09-01-l'- Watts.Bar Item. No specific correla-tion to Sequoyah issues. May have.
Employe'e Concern Over Excessive Wire occurred during construction. Not Lifting Practices to Facilitate- considered to be a Sequoyah restart -) Testing item..
-* - 79-09-01-2 Watts Bar Item. No specific correla-tion to Sequoyah issues. May have p Employee Concern Over Excessive Wire occurred during construction. Not 4- Lifting Practices:to Facilitate considered to be a Sequoyah restart
- Test 2ng item..
4 g 79-09-01-3 Watts Bar' Item. No specific correla-tion to Sequoyah issues. May have
'. Employee Concern Over Excessive Wire occurred during construction. Not
' Lifting-Practices to Facilitate considered to be a Sequoyah restart
'- Testing item.
- I. R-80-10-BFN-01' ' Browns Ferry Item. No specific cor-i . relation to Sequoyah. Not considered Unreviewed Safety Question Determina- to be a Sequoyah restart item.
tion for Waiver on Water Temperature
' Limit R-80-10-BFN-IV A Browns Ferry Item. No specific cor-relation to Sequoyah. Not considered Verification that Revision to Browns. to be a Sequoyah ~ restart item.
Ierry Procedure DPM N73-011 Does Not j Contain an Unreviewed Safety Question R-B1-02-BFN Browns Ferry Item. Not considered e to be a Sequoyah restart item. Develop a TVA Policy Regarding Loss of Safety Function j R-81-04-YCN/NPS-01 Yellow Creek (Cancelled Plant) Item. 5 No specific correlation to Sequoyah. Level of Safety Review of Yellow Not considered to be a Sequoyah
? Creek Nuclear Plant (YCN) restart item. .l l'<
t q ll TER-C5506-623 I Table 2. (Cont.) Item and Description Evaluation of Non-Restart Classification R-81-04-YCN/NPS-02 Yellow Creek (Cancelled Plant) Item. No specific correlation to Sequoyah. Inadequacies of EP 4.02 " Engineering Not considered to be a Sequoyah i Change Notice Handling" for Yellow restart item. 'I*i Creek R-81-08-BFN-20 Browns Ferry Item. No specific cor-- relation to Sequoyah. Not considered ! Quality Assurance and Quality Control to be a Sequoyah restart item.
- of Operational Activities ;
I R-81-08-BPN-41 Quality Assurance personnel staffing level item raised in 1981. No cor-QA&A Staff, Adequacy of Staffing relation to recent QA issues. Not Levels considered to be a Sequoyah restart item. R-81-14-OEDC(BLN)-32 Bellefonte Item. Issue involved lack of fire rated storage for auditor Inadequate Storage of Audit Support working papers. No correlation to Records Sequoyah. Not considered applicable to Sequoyah. R-81-14-Oi:DC(bLN)-41 Bellefonte Item. Correlation to l Sequoyah QA training issue which i Quality Assurance Branch Auditor was closed. Training, No Written Training Program 1 R-82-08-NPS-01 General issue. Correlates to Office of Nuclear Power (ONP) item , Requirements /Needs/ Activities Matrix R-82-08-NPS-10C. This item is { for Chemistry Section addressed by Report ECTG-NSRS-02. ; Refer to Section 2 of this report. l R-82-08-NPS-02 General issue. Correlates to ONP item R-82-08-NPS-10C. This item is Quality Assurance Program for Che:nistry addressed by Report ECTG-NSRS-02. Activities Refer to Section 2 of this report. R-82-08-NPS-03 General issue. Correlates to ONP item R-82-08-NPS-10C. This item is Chemistry Program Organization addressed by Report ECTG-NSRS-02, and Responsibility Review Refer to Ssetion 2 of this report. R-82-08-NPS-04 General issue. Correlates to ONP item R-82-08-NPS-10C. This item is Procedural Controls for Conducting addressed by Report ECTG-NSRS-02. Safety-Quality Affecting Activities Refer to Section 2 of this report. Within the Chemical Engineering Group .(CEG)
j TER-C5506-623 s= Table 2. (Cont.) ,
- Item and Deceription Evaluation of Non-Restart Classification R-82-08-NPS General issue. Correlates to ONP item R-82-08-NPS-10C. This item is Program Improvement for Chemical addressed by Report ECTG-NSRS-02. 1 Engineering. Group Refer to Section 2 of this report.
R-82-08-NPS-06 General issue. Correlates to ONP item R-82-08-NPS-10C. This item is Internal Review and Feedback Process addressed by Report ECTG-NSRS-02. for Chemical Engineering Group Refer to Section 2 of this report. R-82-08-NPS-07 General issue. Correlates to ONP item R-82-08-NPS-10C. This item is Verification of Onsite Radiochemical addressed by Report ECTG-NSRS-02. Laboratory Analyst (RLA) Training Refer to Section 2 of this report.* R-82-08-NPS-09 General issue. Correlates to O'NP item R-82-08-NPS-10C. This item is Integrated Calibration and Chemical addressed by Report ECTG-NSRS-02. Program Development Refer to Section 2 of this report. R-83-08-BLN-2 Bellefonte construction item. No specific correlation to Sequoyah. Development of Cleaning / Flushing Not considered to be a Sequoyah Program Control Procedures ~ restart item. R-83-08-BLN-5 Bellefonte construction item. No l specific correlation to Sequoyah. Approval of the 1/8-Insh Variance Not considered to be a Sequoyah for Acceptance Purge Dam Residual restart item. I Particle Size l I-63-13-NPS-1.a Records management issue. Not con-sidered to be a Sequoyah restart i
' Quality Engineering Branch Records, item.
Records System Not Integrated ) I-83-13-NPS-1.b Records management issue. Not con-L sidered to be a Sequoyah restart Quality Engineering Branch Records, item.
' Record Keeping Procedures Not Properly Implemented I-83-13-NPS-1.d Records management issue. Not con-sidered to be a Sequoyah restart Quality Engineering Branch Records, item.
Vendor Records Not Adequately Reviewed and Controlled
.(
'2ER-C5506-623 Table 2. (Cont.)
Item and Description Evaluation of Non-Restart Classification I-83-13-NPS-2 I Records management issue. Not con- i sidered to be a Sequoyah restart
. Quality Engineering Branch Records, item.
Recommendation for Resolution of Vendor QA Records Problems R-83-18-NPS-01 Issues applicable to organizational structure of the ONP. ONP has been Management of the Reorganization of restructured. Not specifically TVA Radiation Protection and Radio- applicable to Sequoyah. Not consi- , logical Emergency Planning Program dered be a Sequoyah restart item. i R-83-18-NPS-02 Issues applicable to organizational structure of the ONP. ONP has been Office of Nuclear Power Program restructured. Not specifically and Licensing Documents applicable to Sequoyah. Not consi-l dered to be a Sequoyah restart item. R-83-18-NPS-03 Issues applicable to organizational l structure of the ONP. ONP has been Organizational Emphasis of ONP restructured. Not specifically
~ Radiation Protection and Radiological appl.icable to Sequoyah. Not consi-Emergency Preparedness. Program dered to be a Sequoyah restart item.
H R-83-18-NPS-04 Issues applicable to organizational structure of the ONP. ONP has been I Organizational Placement of Health restructured. Not specifically l Physics at Nuclear Plants applicable to Sequoyah. Not consi-dered to be a Sequoyah restart item. t ', R-83-18-NPS-05 Issues applicable to organizational l structure of the ONP. ONP has been l] Health Physics Technical Staff restructured. Not specifically ) l Onsite applicable to Sequoyah. Not consi- ;)
- dered to be a Sequoyah restart item.
R-83-NPS-06 Issur a related to TVA organiza-tion. G specific correlation to f Radiological Health Staff (RHS) Sequoych. Not considered to be a
]
Technical Support Sequoyah restart item. 1 R-84-05-WBN-14 Watts Bar item. Correlates with an en; ioyee concern for Sequoyah. In-Inspector Certification Records vestigation determined not applicable to Sequoyah. Not considered to be a Sequoyah restart item. l 4 [ - _ - - _ _ _ _ - _ _ _ . _ _ _ _ _ \
fL T - fy ,y ( 4 J .J. j, P4 'IER-C5506-623 fL H. la: , l Table 2. (Cont.) Item and Description Evaluation of Non-Restart Classification R-84-17-NPS-01A Item concerns ONP procurement system. Not specifically applicable !. The Procurement System Is Too to Sequoyah. Not cons:idered to be a L Cumbersome and Not Well Known by the Sequoyah restart item.
' Users
)3 R-84-17-NPS-01B Item concerns training in procure- ,, ment system. Applicable to all ). The Procurement System Is Too plants. Not considered to be a L ?.- Cumbersome and Not Well Known by the Sequoyah restart item. I{ Users R-84-17-NPS-01C Scheduling issue for procurement. Applicable to all plants. Not conr sidered to'be a Sequoyah restart l- The Procurement System Is Too . Cumbersome and Not Well Known by item. ' s l. C the Users i R-84-17-NPS-01D Scheduling issue applicable to all plants and ONP. .Not considered a The Procurement System Is Too Sequoyah restart item. Cumbersome and Not Well Known by the Users R-84-17-NPS-03 Concern applicable to ONP. No specific plant applicability. Not 1 Excessive Review of Request for consider d a Sequoyah restart item. 4 Deliveries (RDs) on In(efinite Quantity Term (IQT) Contracts R-84-17-NPS-04 Conceras systems for transfer of material among TVA sites. Possibly Insufficient Documentation for applicable to Sequoyah. Not con-
} Transferred Material sidered a restart item.
R-84-17-NPS-06 Concerns performance of inspections not required by procedure at Browns
.J j BPN Power Stores Receipt Inspectors Ferry. No specific correlation to Sequoyah. Not considered a restart Not Trained to Inspect Material item.
I R-84-17-NPS-07 Concerns system for timely ordering of spare parts for items with limited , Material with Limited. Shelf Life shelf life. Not considered to be a Not Reordered in a Timely Manner restart item. l I m .. hi l .b TER-C5506-623 Table 2. (Cont.) w Item and Description Evaluation of'Non-Restart Classification R-84-17-NPS-08 Concerns lack of use of computerized systera for ordering spare parts. Not Materials Management System (NAMS) considered a restart item. ; Underutilized i 4 R-84-17-NPS-09 When 10CFR21 was not applicable, QA requirements were waived inappro- -;
.10CFR Part 21 Requirements Incorrectly priately. Issue applicable to QA.
Linked to Nuclear Power QA Require- manual. No specific correlation to ments. Sequoyah. Not considered a restart item. I-84-31-BFN-01 Issue was for Browns Ferry. Possible correlation to Sequoyah thimble tube Investigation of Potential Signifi- ejection issue. However, the thimble cant Events tube concern.has been closed for Sequoyah. Not considered a restart item. I-84-31-BFN-02 Issue was for Browns Ferry. No I specific correlation to Sequoyah. t Interpretation of Regulatory Not considered a restart item. Requirements I-84-31-BFN-03 Issue was for Browns Ferry. No s specific correlation to Sequoyah.
, Inter'pretation of Regulatory Not considered a restart item.
Requirements l I-84-31-BFN-04 Issue was for Browns Ferry. No q specific correlation to Sequoyah. j Commitment to Procedure Controls Not considered a restart item. ,j R-84-32-NPS-01 Issue is related to the organization of the overall TVA quality assurance ] i Inadequate TVA Quality Program program. TVA quality assurance ! program and organization has been I revised. No specific correlation to Sequoyah. Not considered a restart item. I I-84-33-BEW-07 Report is an investigation of an ) employee concern for Watts Bar. No I Piping Analysis specific correlation to Sequoyah issues. Not considered a restart item. l
.________.__________j
l < j TER-C5506-623 Table 2. (Cont.) ! l Item and Description Evaluation of Non-Restart Classification f I I-84-33-BFN-08 Report is an investigation of an employee concern for Browns Ferry. Failure of QA to Perform Audits No specific correlation to Sequoyah I and Surveillance of Identified issues. Not considered a restart Problem Areas within Piping Analysis item. Sections I-84-34-SQN-01 Report is an investigation of an employee concern for Sequoyah. Failure to follow QA Procedures by Issue concerned activities of a an Individual at Sequoyah specific employee. Activities affecting quality perforned by that employee are being surveyed. I-84-34-SQN-02 Report is an investigation of an employee concern for Seqcoyah. Issue Completion of TVA Mark Letter was for transfer of non-safety-Description on the Transfer Requisi- related cables from Sequoyah to Watts tion Documents Bar for potential use in safety systems. Concern did not relate to cables being transferred to Sequoyah. Not considered a restart item. I-85-06-WBN-4 Report is an investigation of employee concern for Watts Bar. No Timely and Responsive Corrective specific correlation to Sequoyah. Actions for Resolution of Identified Not considered to be a Sequoyah Problems restart item. R-85-07-NPS-01 Staffing issue. Not specifically applicable to Sequoyah. Not con-Manager of Power and Engineering sidered to be a Sequoyah restart Appointment of a Records Manager item. R-82-01-PSS-01 Item concerns procedures and documen-tation associated with physical Authorities and Responsibilities security of TVA facilities. Gener-Not Clearly Defined in Writing ally applicable to Sequoyah but not identified as a safety-related issue. Not considered to be a Sequoyah restart item. R-82-01-PSS-02 Item concerns procedures and documen-tation associated with physical Procedure for Functioning of security of TVA facilities. Gener-Branch Staff Not Defined in Writing ally applicable to Sequoyah but not identified as a safety-related issue. Not considered to be a Sequoyah restart item. 7_ - =_ [ TER-C5506-623 J Table 2. (Cont.) b Item and Description Evaluation of Non-Restart' Classification
'R-82-01-PSS-03. . Item concerns procedures and documen-tation associated with physical Expectations of Public Safety Services security of TVA facilities. Gener- j (PSS) Management Not Defined'in Writing ~
. ally applicable to Sequoyah but not <
identified as a safety-related issue. Not considered to be a Sequoyah 1 restart item.
)
R-82-01-PSS-04.B.1 Item concerns procedures and documen-tation associated with physical Lack ~of Guidance and Support to security of TVA facilities. Gener-Field Staffs ally appliable to Sequoyah but not identified as a safety-related issue. Not considered to be a Sequoyah restart item. R-82-01-PSS-04.B.2 Item concerns procedures and documen-tation associated with physical Lack of Guidance and Support to security of TVA fac21stles. Gener-Field Staffs ally appliable to Sequoyah but not identified as a safety-related issue. Not considered to be a Sequoyah restart item. R-82-01-PSS-04.C.1 Item concerns procedures and documen-tation associated with physical Lack of Guidance and Support to security of TVA facilities. Gener-Field Staffs ally applicable to Sequoyah but not identified as a safety-related issue. Not considered to be a Sequoyah restart item. R-82-01-PSS-05 Item concerns procedures and documen-tation associated with physical Internal and External Interfaces Not security of TVA' facilities. Gener-Well Defined ally applicable to Sequoyah but not identified as a safety-related issue. Not considered to be a Sequoyah restart item. R-82-01-PSS-11 Item concerns procedures and documen-tation associated with physical Lack of Document Control security of TVA facilities. Gener-ally applicable to Sequoyah but not identifed as a safety-related issue. Not considered to be a Sequoyah restart item.
4
'EER-C5506-623 Table 2. (Cont.)
Item and Description Evaluation of Non-Restart Classification R-82-bl-PSS-12 -
. Item concerns procedures and documen-tation associated with physical T&Q (Training and Qualification) security of TVA facilities. Gener-Implementating Instruction ally applicable to Sequoyah but not identified as a safety-related issue.
Not considered to be a Sequoyah d restart item. R-82-01-PSS-13 Item concerns procedures and documen-
, tation associated with physical i
Material Revisions - Material security of TVA facilities. Gener-Review and Approval ally applicable to Sequoyah but not identifed as a safety-related issue. Not considered to be a Sequoyah , 6 restart item. . s R-82-01-pSS-15 Item concerns procedures and.documen-tation associated with physical Site Security Organization - security of TVA facilities. Gener-
- p. Administration Responsibilities ally appliable to Sequoyah but not f and Authority Not Clearly Defined identified as a safety-related issue.
Not considered to be a Sequoyah restart item. I I .R-82-01-PSS-24 Item concerns procedures and documen-tation associated with physical t- Bellefonte Security Facilities security of TVA facilities. Gener-l Tracking System y ally applicable to Sequoyah but not identified as a safety-related issue. Not considered to be a Sequoyah j restart item. j i R-83-16-NPS-01 Item concerns procedures and documen-a tation associated with physical Revision of the Safeguards security of TVA facilities. Gener- ; Information ally applicable to Sequoyah but not ] identifie.d as a safety-related issue. ! i Not considered to be a Sequoyah f restart item. i R-84-06-NPS-01 Item concerns procedures and documen- 3 I tation associated with physical j Revision of the Safeguards security of TVA facilities. Gener- ) Information ally applicable to Sequoyah but not identifed as a safety-related issue. 4 Not considered to be a Sequoyah ) restart item.
TER-C5506-623 Table 2. (Cont.) Item and Description Evaluation of Non-Restart Classification R-81-08-BFN-08' Item concerns Browns Ferry Plant-Operations Review Committee (PORC). Scope of Staff Audit Program for .No specific correlation to Sequoyah. .i Follow-up on Corrective Action Not considered to be a Sequoyah ' restart item. (l r l 3
l TER-C5506-623 l
-' fi
- 4. CONCLUSIONS )
i a 4.1 RESTART ISSUES The 8 restart items in~ report ECTG-NSRS-01 and 17 restart items in report ECTG-NSRS-02 identified by the Nuclear Safety Review Staff (NSRS) were i assigned to the Employee Concerns Task Group (ECTG) for verification and closure. In addition. TVA closed out two open " classical" NSRS items in a report identified as Nuclear Managers' Review Group (NMRG) Report
)
R-86-02-NPS. ECTG examined the corrective action undertaken by TVA and the specific verification methodology and verification analysis for each item, including procedure and documentation review, documentation control, personal inter-views, testing, inspections, and analyses. ECTG closed two items in report , ECTG-NSRS-01 and one item in report ECTG-NSRS-02 and concluded that no further action is need for these itemt by TVA. These conclusions have been found to be acceptable. The resolution of Item R-85-03-NPS-07, addressed by NMRG, was reviewed and found adequate. The other item closed by NMRG, R-85-03-NPS-08, has been < turned over to NRC Region II to verify closure. The remaining 22 items contained in the two ECTG reports are being reviewed by ECTG. TVA considers these items as open, pending verification of corrective actions by TVA. The ECTG's findings were found to be acceptable, provided the following recommendations are incorporated: l o With respect to Items R-84-17-NPS-10, 11, and 12, TVA must ensure i j that commercial grade equipment and spare parts that were installed !
' or stored for later use prior to revision of plant procedures have j been verified as being acceptable for use in QA applications. 1
\
l o With respect to Item R-85-08-0E/NUC PR-01, environmental l qualification documents that use the similarity method should be evaluated by an independent reviewer. 4.2 NON-RESTART ISSUES The list of 69 non-restart issues listed in report ECTG-NSRS-02 was reviewed according to the " Restart Requirements Criteria" in Section 3. TVA's 1 l } l 1 lP i , l 1
, i
t: p I', '
*f j.0 TER-C5506-623 ._v k' '
b classification of these'." classical" NSRS recommendations as non-restart issues was reviewed against TVA's restart requirement classification criteria contained in Section~3 of:this report and was found to be acceptable, d 1
e-
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~
O TER-C5506-623 o
- 5. REFERENCES
- 1. Rl L. Gridley.(TVA) I
. Letter with Attachment to H. Denton (NRC)
Attachment:
Nuclear Managers' Review Group Report R-86-02-NPS
' December 17,.-1986
- 2. J. A. Mcdonald (TVA)
Letter with Attachment to H. Denton (NRC)
Attachment:
Tennessee Valley Authority, Sequoyah' Nuclear Plant Employee Concerns Task Group, Report ECTG-NSRS-01, Revision 2, January 30, 1987
- 3. J..A. Mcdonald (TVA)
. Letter with Attachment to H. Denton (NRC)
Attachment:
Tennessee' Valley Authority, Sequoyah Nuclear Plant Employee Concerns Task Group, Report ECTG-NSRS-02, Revision 1, January 16. 1987
- 4. Sequoyah Nuclear' Performance Plan, Revision 1, Tennessee Valley Authority, March 1987 l
i I r ) _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ . . . _ _ _ _ _}}