ML20235V239

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Forwards Response to Action Items Resulting from 870521 Meeting W/Nrc & 870903 Discussion W/J Zwolinski.Action Items Requiring Further Clarification Agreed Upon & Listed in Encl.Items Resulting from Meeting Considered Closed
ML20235V239
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 10/06/1987
From: Gridley R
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8710150059
Download: ML20235V239 (23)


Text

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i TENNESSEE VALLEY AUTHORITY j

CH ATTANOOGA. TENNESSEE 37401 SN 1578 Lookout Place 00T 061987 1

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, D.C.

20555 Gentlemen:

In the Matter of the

) Docket Nos.

50-327 Tennessee Valley Authority

)

50-328 SEQUOYAH NUCLEAR PLANT - TVA-NRC MEETING OF MAY 21, 1987 - RESPONSE TO ACTION ITEMS This submittal is in response to a discussion on September 3, 1987, with John Zwolinski of your staff concerning the action items from the May 21, 1987 meeting.

In the course of the subject meeting several requests for information were asked of TVA by the NRC staff. After the May 21, 1987 meeting, in a discussion between J. A. Zwolinski, of NRC, and M. B. Whitaker, Jr., of TVA, those items requiring further clarification were agreed upon.

The enclosure addresses each of those items.

Some of the information has already been submitted since the May 21, 1987 meeting. Although there are discussions and submittals ongoing between the staff and TVA on these issues, we consider all the action items resulting from the May 21, 1987 meeting closed.

If you have any questions, please telephone R. F. Campbell at (615) 751-4892.

l Very truly yours, TENNESSEE V LLEY AUTHORITY R. L. Gr diey, Director Nuclear Licen ng and Regulatory ffairs Enclosure cc: (See page 2) 0 A710150059 871006 F gi PDR ADOCK 05000327

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P PDR An Equal Opportunity Employer J

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.g U.S. Nuclear Regulatory Commission ~'

00T 00987 cc (Enclosure)':

Sequoyah Resident Inspector i

sequoyah Nuclear Plant 2600 Igou Ferry Road

. Soddy. Daisy, Tennessee 37379 Mr. G.'.'G. Zech, Assistant Director

. Regional.. Inspections Division of TVA Projects office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia-30323 Mr. J. A. Zwolinski, Assistant Director for Projects office of Special' Projects U.S. Nuclear Regulatory Commission 4350 East West Highwry.

EW 322 -

Bethesda, Maryland' 20018 i

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,}s ENCLOSURE ACTION ITEMS RESULTING FROM MAY 21, 1987 TVA/NRC MEETING 1.

provide NRC with a list of outside contractors associated with the Volume 2 special programs and their periods of performance. In the development of this list, include the name of an expert, if there was one, that participated with or oversaw the special program.

TVA Response: The list of outside contractors is given in Attachment 1.

2.

Verify that TVA made submittal on cable Ampacity and provide date of submittal to NRC.

l TVA Response: The submittal was dated February 27, 1987, from R. L. Gridley to B. J. Youngblood.

3.

Kequest information from WESTEC regarding comparicon of the scope of their work for TVA with the scope of their work for other plants.

l TVA Response: Attachment 2, a letter dated June 5, 1987, from C. J. Crane, of WESTEC, to W. L. Elliott, the TVA EQp Manager, summarizes WESTEC's scope of Environmental Qualification work for Sequoyah Nuclear plant (SQN) and provides a comparison of the work for SQN with the scope of work for other l

plants.

1 4.

provide NRC with cable test results.

TVA Response: The SQN revised cable test program was submitted July 31, 1987, from R. Gridley to NRC.

This submittal committed to forwarding the test results as they are completed.

5.

provide NRC with copies of C. H. Fox's backup viewgraphs and a short explanation of conversion factors for second viewgraph.

TVA Response: See Attachment 3 for the two backup viewgraphs. The second part of the action item concerned the explanation of conversion factors for the second viewgraph. The question was stated as follows:

If the Windsor probe extensions are directly translatable to concrete compressive strength, why weren't those conversions made (i.e., a probe extension of 2.03 inches was shown on the slide instead of the corresponding compressive strength)?

Response

The purpose of the Windsor probe tests at SQN was to supplement the evaluation of the concrete tests which were made during the construction period. The Windsor probe tests were intended to determine if significant differences existed between concrete placed during " low strength" time periods with concrete placed during " control" periods when the specification requirements for strength were met. No attempt was made to convert the Windsor probe extensions to compressive strength because the correlations to core strengths were not necessary. Additional testing, such as coring, would have been considered if the comparison for the " low strength" and " control" periods showed a significant difference in strength.

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I For information purposes, an approximate range for the compressive strength can be estimated from the Windsor probe extension of 2.03 inches mentioned in the above question.

The plot of the Windsor probe data in the SQN report indicates an average 90-day strength between 6,300 and 7,800 psi for a probe extension of 2.03 inches.

However, the strength data that was used for the plot does not account for strength increases in age after 90 days and does not account for the curing conditions of the concrete member.

6.

Provide detailed information regarding requirements to environmentally qualify valve 74-1.

TVA Response:

Evaluation of the requirements to environmentally qualify valve 74-1 at SQN has been completed.

A report providing information is included as attachment 4.

7.

Provide NRC with schedule and scope of calculation program.

(DNE) l TVA Response: This was submitted July 31, 1987, R. L. Gridley to U.S.

Nuclear. Regulatory Commission, Attention:

Document Control Desk.

8.

Document Management Review Group review of Dallas Hicks's allegations and provide to NRC for information.

TVA Response:

This response was submitted June 23, 1987, R. L. Gridley to U.S. Nuclear Regulatory Commission, Attention:

Document Control Desk.

9.

Provide response to Commissioner Asselstine's letter to NRC by June 3, 1987.

TVA Response:

This response was submitted June 10, 1987, S. A. White to James G. Keppler.

10. Provide man-hour estimates to review 100 percent of calculations by technical branch.

TVA Response:

The preliminary estimate for the review of Sequoyah calculations is 32,350 man-hours.

This preliminary estimate is subject to change as the scope of the review is further defined.

The Civil Engineering Branch estimate is for a review sampling of the civil / structural calculations only, and does not include any man-hours for the engineering mechanics function.

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l ATTACHMENT 1

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ACTION ITEM 1 DESCRIPTION.

PERFORMER REMARKS 1.0' Environmental Qualification Westec Services C. J. Crane I

-(Westec Services)

. August 1985-cont.

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2.0 Design'and Configuration TVA John Cox/

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Control, Henry Jones

,,3.0

. Cable; Tray Support Analysis TVA Alec Rather 4.0 Design Calculations Review.

a.)

Electrical TVA Jim Hutson (Knoxville)

- b. ) Mechanical TVA C. A. Chandley (Knoxville) c.)

Nuclear TVA F. A. Koontz d.)

Civil 1)~

Bechtel Pipe support 5/87 - ongoing 2)

Stone & Webster Hanger Support 5/87 - ongoing 3)

Gilbert Common -

Five Rigorous Wealth Analysis-Technical'-

Review, 2/87 to-4/87 4)

Robert Cloude

. Technical Review 5/87 to 6/87 Long-term calculation Program procedures.

Technical Instructions Sargent & Lundy Nov 86 - ongoing-(18 months)

Paul Shaffer (S&L)

Jim Hudson (S&L)

DEO2;TL7163.05 SQEP June'22,-198'l L___._______

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DESCRi?] ION PERFORMER REMARKS 5.0 Alternately Analyzed 1)

Impell Majority employees Piping and Supports.

2)

R. L. Cloud & Assoc.

are Impe11 con-tractors (90%)

Dave Wilson - TVA 6.0 Main Stream Temperature Westinghouse.

Nick Liparulo (W)

R. H. Bryan (TVA)

Jim Pilgram (TVA) 7.0 Fire Protection'- 10 TVA Jim Pearse/

CFR'50 Appx R Bob Edlund 8.0 Plant Welding Program Bechtel 1/13/86.to 1/31/86.

Principal engi-neer M. J. Dutta CWI'- G. R. Hoffman 9.0 Sense Line Issues TVA Jim Staub /

Pranab Guita 10.0 Wall Thinning Assessment TVA Jim Pilgram Program (Pipe Erosion /

Corrosion) 11.0 Restart Test Program Stone & Webster April 87 to Bechtel February 88.

Westinghouse Advisor:

0. J. Mavro (Stone & Webster) 12.0

' Component and Piece TVA Jim Murdock/

Part Qualification Tom Spink 13.0 Electrical Issues.

13.1 Cable Ampacity

.TVA Rick Collins /

13.2 Cable Pulling Issues TVA Tim Shen 13.3 Fuses TVA Kent Brown /

Tim Shen Jerry Webb (Knox)

DE02;TL7163.05 SQEP June 22, 1987 l

3 x

g DESCRIPTION PERFORMER REMARKS 14.0 Containment Isolation TVA Bob Bryan Design Review (Knox) 15.0 Miscellaneous Programs 15.1 Miscellaneous TVA A. Rather

-Civil Engineer Issues 3.5. 2 Moderate Energy Sargent &'

May 1986 to Line Break Flooding Lundy May 1987. TVA Supervisor:

Harry O' Brian 15.3 containment Coatings Imperial Co.

TVA - Dave Briggs S.G. Penney.

(contractor)

March 1986 to present Westinghouse TVA - Bill Mangiante October 1986 to March 1987 15.4 ECCS Water Loss TVA V. A. Bianco Outside Crane Hall 15.5 Platform Thermal TVA A. Rather crowth 15.6 Heat Code Traceability TVA TVA -

David Briggs DE02;TL7163.05 SQEP June 22, 1987 1737b 8/24/87 GJT.

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I ATTACHMENT 2 i

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\\. WESTEC Services, Inc.

2260 Butler Pike Phmouth Meetma PA 194621412 (215)834497o June 5,1987 P36045.001 Serial No.87-121 Mr. Walter L. Elliott, EQP Manager Tennessee Valley Authority Sequoyah Nuclear Power Plant DSC-D-35 Soddy Daisy, TN 37379 P.O. Box 2000 I

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Ref.1:

Telecon between W. L. Elliott (TVA) and C. J. Crane (WESTEC) on J 1987.

Subject:

NRC request for information regarding WESTEC scop Environmental Qualification work at Sequoyah.

Subject:

WESTEC Scope of Work Regarding Environmental Qualification at TVA's Sequoyah Nuclear Plant.

Dear Mr. Elliott:

This letter and its attachment summarizes WESTEC's scope of Environ cation (EQ) work for Sequoyah Nuclear Plant and provides a compariso Sequoyah with the scope of work for other plants. This letter is subm to your recent request regarding this information (Reference 1).

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WESTEC engineers are registered professional engineers who posses 1

experience in the nuclear industry. These individuals have experience in c and naval nuclear power plant operations, architect-engineering firms, co nuclear plant design and licensing activities. WESTEC environmental qua experiences includes:

Program technical reviews and audits o

Program development -

o Preparation o

Preparation of qualification documentation o

of procedures Development of test plans o

Solving complex qualification problems o

Regulatory and licensing support o

Development of maintenance programs for equipment o

i Expert technical consulting o

Supervision of qualification testing o

Development of 10CFR50.49 equipment lists o

Training o

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l Mr. Walter L. Elliott, EQP Manager Page 2 June 5,1987 WESTEC has performed the following EQ work for Sequoyah:

A combined team of TVA and WESTEC personnel performed a programmatic o

and technical review of the environmental qualification activities and documentation for Sequo3 5, Watts Bar and Browns Ferry (July-August, (Mr. C. J. Crane).1985). The team leader of this technical review was a WESTE Assisted TVA in the development of the Sequoyah EQ program and the o

project manual. The manual provides guidance on EQ technical issues and provides detailed instructions and procedures for preparation and maintenance of EQ documentation.

o Assisted TVA in development of a Qualification Maintenance program for

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EQ equipment.

Provided EQ training to TVA and contractor personnel.

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Performed a technical audit of the Sequoyah Plant EQ program and

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procedures.

Provided technical expertise to TVA for resolution of various technical -

o issues.

Performed independent management reviews of,a11 EQ binders. This review o

was a 100% technical review of the EQ file to ensure that the product was technically correct. ' A WESTEC engineer supervised the management review group (Mr. C. J. Crane). The group consisted of 4 to 5 senior engineers (2 WESTEC engineers,1 TVA engineer and 1 engineer from Digital Engineering).

Assisted TVA in the evaluation and resolution of the main steam valve vault o

hot spot issues regarding equipment and cabling. A WESTEC engineer was the team. leader for this effort (Mr. C. J. Crane).

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performed by WESTEC for other nuclear utility clients. Attachm summary of the WESTEC EQ as_signments at other plants.

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e for the NRC (I was previously employed as a contractor EQ Program is an excellent program and is certainly one of the finest in the coun This judgment considers program elements such as the l of the plant walkdowns, the implementation of the EQ program at the site, and the program procedures.

Sincerely, C. j. Q Cyril J. Cranc, P.E.

Manager of Engineering Projects Power Engineering Division Enclosure CJC/ fess

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ENVIRONMENTAL QUALIFICATION AT OTHER PLANTS c_

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WESTEC EQUII'd ENT QUALIFICATION ENGINEERDIG EXPERIENC i

. The following matrix shows the in-depth EQ experience that WESTEC Services l has to offer the nuclear industry.

1 M nintenance &

Plant EQ Program EQ Program l

Surveillance Plan Engineering Services Third Party Review Dresden Unit 2

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'X-Dresden Unit 3 '

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X Quad Cities Unit i X

X X

-Quad Cities Unit 2 X

'X La Salle Unit 1 X'

La Salle Unit 2 X

Zion Unit 1 I

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X Ninc M11e Pt. Unit 1 X

X Susquchanna Unit 1

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Susquehanna Unit 2 M

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Duane Arnold X

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X Davis Desse

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Sequoyah Unit 1 X

Sequoyah Unit 2 X

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Cooper Station X

l Drowns Ferry Unit i X

X Drowns Ferry Unit 2 X

X Drowns Ferry Unit 3 -

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Watts Dar Unit t X

1 X

Watts Bar Unit'2 X

Kcwaunce X

X X

X Calvert Cliffs X

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In light of recent NRC EQ program inspections, WESTEC has developed and conducted the following 3-phase audit program at 12 nuclear power plants:

Phase 1:

evaluation of the approaches used to demonstrate, evaluate and document equipment qualification Phase 2:

evaluation of the technical adequacy and completeness of these a

evaluations Phase 3:

evaluation of the completeness and format of technical documentation, files and records.

Equipment qualification programs for the following plants have been audited by WESTEC EQ cngineers:

Nebraska Public Power District (Cooper Station - 1985) o Wisconsin Public Service (Kewaunee,1985-Present) o

~- r-Tennessee Valley Authority (Sequoyah Units 1 & 2, 1985-1986)

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o Tennessee Valley Authority (Browns Ferry Units 1,2&3,1985-Present)

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Tennessee Valley Authority (Watts Bar Units 1 & 2,1985-Present) o

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Commonwealth Edison Company (Dresden Units o

2 & 3, 1984-1985) 3o Commonwealth Edison Company (Quad Cities Units 1 & 2, 1984-1985)

Commonwealth Edison Company (Dyron Units 1 & 2, 1985) o Commonwealth Edison Company (LaSalle Units o

1 & 2, 1985)

Commonwealth Edison Company (7. ion Units 1 & 2, 1985) o Niagara M ohawk Power Company (Nine Mile Point Unit 1,1983) o IQwa Electric Company (Duane Arnold,1985-Present) o Experience in Representing Utility Clients During NRC Audits In addition to independent evaluation of equipment qualification documentation WESTEC enginects have supported the utility's equipment qualification positions following plants:

TVA, Sequoyah Units 1 & 2 (1985 present) o Niagara M ohawk Power Company, Nine M ile Point Unit 1 (1983) o Commonwealth Edison Company, Dresden Units 2 & 3 (1986 present),

o 7, ion Units 1 & 2 (1985)

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Wisconsin Public Service, Kewaunce (1985-1986) o

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Baltimore Gas & Electric, Calvert Cliffs (at present) i

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COMMONWEALTH EDISON COMPANY

Title:

-Equipment Environmental Qualification Summary

..of Work:._.WESTEC engineers have provided the following technical services

~ associated with the equipment environmental qualification (EEQ) programe at various CECO nuclear stations:

Technical Audits of EEQ programs at Zion, Dresden, Quad Citics, LaSalle, and Byron 1 to determine compliance with the requirements of 10CFR50.49.

Preparation of maintenance and surveillance engineering procedures to ensure on-going equipment qualification for Zion, Dresden and Quad Cities Stations.

Miscellaneous site support in the equipment qualification requirements for the Dresden and Quad Citic Stations.

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Qualification by analysis of electromatic actuators of BWR relief valves located inside containment for Decsden and Quad Cities Stations.

Duration: February 1983 to present Client:

NIAGARA MOHAWK POWER CORPORATION Titic:

Equipment Environmental Qualification Summary of Work:

.WESTEC engineers provided the following technical services relative

. to the equipment environmental qualification program at Nine Mile

...s Point, Unit 1:

Review and modify, as necessary, the list of safety-related equipment subject to environmental qualification. requirements of IE Dulletin 70-010.

Review documentation of equipment qualification for safety-related equipment subject to the requirements of IE Bulletin 79-01B and NUREG-0588.

Assist in upgrading equipment qualification documentation to meet DOR Guidelines, IE Bulletin 79-01D and NUREG-0588.

j Duration: April 1983 - June 1984

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Client:

IOWA ELECTRIC LIbHT & POWER COMPANY

Title:

Maintenance and Surveillance Procedures Summary 7-~

of Work:

WESTEC extracted the maintenance and surveillance requirement L

from the qualification documentation for the environmentally

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' qualified equipment at the Duane Arnold Energy Center (DAEC)

WESTEC wrote maintenance and surveillance procedures to ensure the on-going environmental qualification of previously qualified equipment...WESTEC engineers also reviewed Correction Maintenanc'e Action Requests (CMAR' ) since 1982 for DAEC to s

de' termine if maintenan'ce performed on environmentally qualified '

equipment. voided the qualification status of the equipment in any "W'..a::...::.,

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Duration: Octob'er - Dec' ember 1985

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WESTEC is presently providing engineering services rela'ted to environmental qualification,. maintenance and ' surveillance documentation and procedures in accordance with 10CFR50.49 and y,

providing engineering support to the Iowa Electric Q-team effort at --

D,uane Arnold Energy Center.

Duration: January 1986 to present

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NEBRASKA P'UBLIC POWER DISTRICT

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Title:

Review of Equipment Environmental Qualification Summary of Work:

WESTEC Services provided a review of the documentation which demonstrates environmental qualification of equipment important to safety in a harsh environment for the Cooper Nuclear Station. The

.t objective of this review was to evaluate the adequacy of the environmental qualification files in establishing and documenting equipment qualification.,,,

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urse of the review, genera 1 requirements of Nebraska Public n

Power were considered and EEQ audit forms were developed, tailo to specific equipment types, identifying unique equipment qualification aspects for all components. A final report was submitted which identified significant results and problem areas and included a summary audit finding, audit deficiency forms and EQ audit forms.

Duration: April-August 1985 l

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TOLEDO EDISON COhi!PANY

Title:

Equipment Environmental Qualification Summary of Work:

WESTEC engineers provided engineering and technical services to complete the. following environmental qualification tasks:

h epa' red'a'idission level' procedure for control activities related

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to EQ of nuclear-related equipment.

. Prepared a station p.rocedure'to provide administrative control of EQ equipment, with the technical content reflecting the' requirements established by 10CFR50.49,and, Reg. Guide 1.89.

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. d su r, v..eillance procedures...

Prepared station maintenance an..

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to implement a program which provides continuing EQ of equipment.

Ensured industry wide technical issues regarding specific components which have been, or are being, addressed by Toledo Edison.

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Duration: October 1985 - January 1986.

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Client:

TENNESSEE VALLEY AUTIIORITY

Title:

Equipment Environmental Qualification

Summary of Work:

WESTEC engineers performed a programmatic review of environ-mental qualification activities and documentation at Browns Ferry,

.Sequoyah and Watts Bar Stations for Tennessee Valley Authority.

The objectives of the review were as follows:

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Determine the degree of compliance as appro.priate to

.10CFR50.49, NUREG-0588 and DOR Guidelines.

Identify elements that' fully comply with the final rule, both in program and implementation.

Identify deficiencies or weakne$ses in the program or implementation thereof.

Provide recommendations to resolve deficiencies and weaknesses identified.

Provide recommendations for improvement to the environmental I

qualification program.

Subsequent to the programmatic review, WESTEC performed a 1

detailed management review of the environmental qualification program documentation files for Sequoyah. An evaluation was made as to auditability, compliance to qualification criteria, and the technical correctness of the documentation. Engineering analyses and resolutions were provided for the deficiencies identified in the review. Similar work is now in progress for Watts Bar.

Duration: July 1985 to present

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~NIICOliSIN PUBLIC SERVICE CORPORATION Client:

eview o' Equipment Environmental Qualification

Title:

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Summary,,

of Work:n,WESTEC Services provided a technieni review of the documentation scope of 10CFR50.49 for the Kewaunee Station. 'Ihe object of the technial review was to evaluate and fully document the adequacy of the environmental qualification files in establishing and documenting equipment qualification in compliance with 10CFR50.49. In order to accomplish this objective, WESTEC examined and evaluated:

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Approaches used to demonstrate, evaluate and document

,c 3 equipment qualification.

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. Technical adequacy of.these evaluations.

... Application of qualification criteria such as industry standards,

n. DOR Guidelines and NUREG-0588. - ir..

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Completeness and auditability of technical documentation files and records.

Duration: November 1985 - January 1986 l

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WESTEC is p'roviding additional engineering assistance for work related to the independent technical review performed on WPSC i.

Environmental Qualification files for the Kewaunee Nuclear Power Plant. This work consists of the following:

' Resolution o'f open items identified in the prior review.

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Development of a verification plan (with supporting checklists)

,. for verification of nameplate information, special instruments, etc.

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Review of correspondence and other related documentation to ensure all commitments to the NRC have been met.

Duration: January 1.986 to present Client:

ARKANSAS POWER & LIGIIT COMPANY

Title:

Preventive Maintenance Engineering Evaluations Summary

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of Work:

WESTEC engineers are currently developing Preventive Maintenance Engineering Evaluations (PMEE) for safety-related equipment for Arkansas Nuclear One, Unit 1. These PMEE's serve a dual purpose of identifying essential mai t I

n enance requirements, and when

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activities are recommended based on engineering judgment and review of documentation pertaining to the equipment. The PMEE's L

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Consequences of failure and consideration of th'e criticality and:

Mdsage of the equipment.

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. Conditioning monitoring parameters to aid in detecting degrading material or performance.

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. Identification of special maintenance requirements specified by the vendor.

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identification of the frequency for maintenance and conditioning

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- basis for the recommended actions and frequencies together with.

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references required to support conclusions.

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Duration: November 1985 to present e

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Client:

PENNSYLVANIA POWER & LIGIIT COMPANY

Title:

Qualification of 600V Cable Summary

. of Work:

WESTEC engineers analyzed the qualification testing information

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conccening'600 Volt power and control cable manufactured by Amedcan Insulated Wire (AIW) Company for use at Pennsylvania Power & Light's (PP&L's) Susquehanna Steam Electric Station (SSES),

Units 1 and 2..,, J..,..,,.,, m

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The purpose of the work was to qualify the cable by analysis and i

provide supporting documentation demonstrating qualification of the cable in order to achieve qualification in accordance with NUREG-0538 Category II criteria and applicable IEEE standards.

j Duration: June 1983 - July 1985 4 s 4

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6-ATTACHMENT 3 r

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t NOTE:

SUBMITTED TO NRC 4/8/87, R. L. GRIDLEY TO S. EBNETER

-AS PART OF SQN CONCRETE EVALUATION.

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CBS MtX

' DAY 20 DAY 90 ESS PE RN POUR FEATURE 1 30004 3000 1.66 34 0-A2CPA'iA915D WALL 2 30004 3890 6613 3000 2.13 42 0-A2CPAVAB09-OiA WALL l

3 3000A 3165 -5580 2600 2.17 49 0-A2CPABAsiv-17H SLAS l

4 3000A 3390 4990 30001.83 39 0-A2CPABAB22-02A SLAS 5 3000A 4960.-7075 2600 2.01 51 0-A2CPABAB24-13 -WALL 6 3000A 3470 5130 2700 2.05 40 0-A2CPABPT-9-14C W

, ALL 7 3000A 3000 2.09 44 0-C2CPCBCB1-45E WALL-8 3000A 4290 3000 2.19 56 0-C2CPCBC91-12A SLAB 9 3000A 3570 5240 3000 1.90 39 050-CPDADGB 4-3E WALL 10 3090A 3550 3000 2.11 51 1-R2CCR1RB1-3-100 SLAB 11 3000A 4045 6190 3000 2 12 44 2-R2CPR2RB2-3-100 SLAB 12 30008 2670 3890 3000 1.96 43 0< '2CPABAB200 WALL j

13 30008 2370 3575 3000 2.18 49 0-A2CPABAB21 A WALL 14 4000A 4000 1.99 41 '. -A2CPABAB1BA WALL 15 4000A 5000 8490 4000 1.99 51 0-A2CPABAB24-13 WALL 16 4000A 4910 6580 3300 2.23 '~ 0-A2CPt* AB24-14 SLAB i

i 17 4000A 4840 7470 4000 2.15 52 0-A2CPABAB24-16WALL 18 4000A 4960 7215 3300 2.24 57 0-A2CPABAB24-le WALL 19 50004 4906 2.22 53 0-A2CPABA825-01P WALL 20 5000A 6795 4595 4000 2.09 52 0-A2CPABAB25-1U WALL 21 5000A 4800 2.25 55 0-A2CPABAB25-1Y WALL 22 5000A.5465 7520 50001.93 55 1-R2CFR1RB1-1"A WALL

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7 ATTACHMENT 4 Flow control valve (FCV) 74-1 is one of two valves in series that isolate the reactor coolant system (RCS) from the suction side of the residual heat removal (RHR) system.

FCV 74-1.is a motor operated valve located inside the crane wall-in the primary containment.

It is the valve closest to the reactor.

The valve is normally closed with the power removed.

The breaker is q

padlocked open and the breaker cabinet is also padlocked to prevent the valve

-from being inadvertently energized.

The valve is only opened when the plant is being placed on RHR in preparation for continuing a cooldown to cold shutdown conditions.

The valve has. interlocks that prevent it from opening if the RCS pressure is too high and the valve will automatically close if the RCS pressure rises.above normal RHR conditions.

FCV 74-1 does not close automatically on an SI signal nor any other accident signal because it would be closed when these. signals would be expected to be' generated.

From an equipment qualification standpoint,.this valve is qualified to function for 15 minutes after a break in the RHR line outboard (away from the RCS) of both RHR valves.

This is an event that occurs when the reactor is at a low pressure and the valve is open. Operability is needed to allow the break to be isolated. An engineering evaluation was performed that established that the valve will not reopen once it is closed.

For all other events including steam line breaks inside containment and LOCA's, the valve is closed.

The need for qualification of the valve was reviewed and it was determined that the valve would not inadvertently open as a consequence of any event including events that resulted in the valve being submerged.

Because of this and the fact that-Sequoyah is a hot standby plant and not a cold shutdown plant, no additional qualification of the valve is needed to assure pubile safety.

o FCV 74-1 would be flooded after an event that would result in actuation of the containment spray system or the melting of a major portion of the ice bed.

As noted in the previous paragraph, the fact that the valve is flooded does not represent a hazard to the health and safety of the public.

However, having l

FCV 74-1 available for the operators to use long term is an asset. As such, l

we are evaluating raising the operator on this valve above the maximum i

post-accident water level inside of the containment.

This change is not required for plant restart and as such may be made in a future outage.

j t.

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