ML20236C425
| ML20236C425 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/16/1987 |
| From: | Hubbard G NRC OFFICE OF SPECIAL PROJECTS |
| To: | Ebneter S NRC OFFICE OF SPECIAL PROJECTS |
| References | |
| NUDOCS 8707300059 | |
| Download: ML20236C425 (11) | |
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JUL 101987 DISTRIBUTION:
dECentral FileM MEMORANDUM FOR:
Stewart D. Ebneter OSP:TVA R/F TVA Projects Division JKeppler/JAxelrad Office of Special Projects SRichardson
.GHubbard THRU:
B. D. Liaw, Assistant Director CJamerson for Technical Programs RPierson TVA Projects Division BDLiaw Office of Special Projects Sconnelly Robert Pierson, Chief Plant Systems Branch Division of TVA Projects Office of Special Projects FROM:
George Hubbard Plant Systems Branch TVA Projects Division Office of Special Projects
SUBJECT:
COMMENTS ON OIA REVIEW 0F NRC'S EQ INSPECTIONS AT SEQUOYAH NUCLEAR PLANT 1.
Page 2, Paragraph 3, Sentence 4:
Office of Special Projects (0SP) Staff is not sure the March 1985 date is accurate. Unless 0IA has specific information regarding the March date, Spring 1985 would be considered more appropriate.
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Page 7, Paragraph 3, Sentence 2:
The actual number of inspections conducted at Sequoyah is five and not four as stated.- (January 6 17, February 10 14, June 23-27, and December 8 12, 1986 and April 6 10, 1987).
3.
Page 8, Paragraph 3, Sentence 2:
The reference to the "rar cooling water system" should be changed to the
" essential raw cooling water system" since this is TVA's official terminology for the system being reviewed.
George Hubbard Plant Systems Branch e7073000598707%7 TVA Projects Division ADOCK 0500 Office of Special Projects PDR PDR G
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1 OIA REVIEW 0F NRC'S REVIEW 0F THE ENVIRONMENTAL
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h QUALIFICATION PROGRAM AT THE SEQUOYAH NUCLEAR PLANT l
INTRODUCTION.
The Office of Inspector and Auditor (01A) has reviewed the Nuclear Regulatory Comission's (NRC) assessment of the Tennessee' Valley Authority's (TVA)
Environmental Qualification (EQ) Program at the Sequoyah Nuclear Power Plant.
The purpose of our review was to look at the program developed by NRC to evaluate Sequoyah's EQ program, and to determine NRC's ability to ensure Sequoyah's compliance with 10 CFR 50.49. Our review was initiated as part of an oterall 01A review of NRC's -regulatory activities involving TVA's nuclear power facilities.
BACKGROUND Environmental qualification is required to assure that safety-related equipment will perform as required during accident situations. The requirements for environmental qualification of electric equipment important to safety for nuclear power plants are found in 10 CFR 50.49.
For purposes of this section, equipment important to safety is that equipment relied upon to remain functional during and following a design basis event to ensure (i) the integrity of the reactor's core, (ii) the capability of the utility to shut down the reactor and maintain the reactor in a safe shutdown condition, and (iii) the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures of radiation. According to 10 CFR 50.49, all holders of operating licenses issued prior to February 22, 1983,
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.were to, by May 20, 1983, identify a list of all electric equipment important to safety for purposes of Section 50.49 already qualified and submit a schedule for either the qualification or replacement of the remaining electric equipment. This schedule was' to set a goal for final qualification of electric equipment no later than March 31, 1985. Under certain circumstances, the Director, Office.of Nuclear Reactor Regulation (NRR), could grant extensions of this deadline to a date no later than November 30, 1985, for specific pieces of equipment. The regulation also gave the Commission the authority in exceptional cases to consider and grant an extension beyond
' November 30, 1985, for completion of environmental qualification.
On February 25,.1985, TVA's Manager of Licensing and Regulations notified NRC that "Sequoyah has-in place and is implementing an electrical equipment environmental qualification (EQ) program to satisfy the requirements of 10 CFR 50.49."
TVA further stated that the documentation maintained in its EQ files was in compliance with 10 CFR 50.49 and that it provided assurance of continued compliance through the EQ program.
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In a letter dated July 24, 1985, to the Director, NRR, the Chief of the Nuclear Licensing Branch of TVA stated that, for Sequoyah, TVA had " completed replacement or qualification of all electrical equipment previously identified to NRC as being unqualified." The letter continued, however, that TVA was evaluating the environmental qualification status of two categories of components: cables and terminal blocks. TVA considered these components to be operable despite the indeterminate status of their 50.49 qualification.
While this was their official position in July 1985, earlier, in March 1985, TVA began feeling they had generic problems in the area of EQ. TVA,
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therefore, decided to contract with'a consultant to independent 1y' review the EQ-programs for their' plants..
l On July l29, 1985, a team composed of WESTEC Services, Inc. and TVA personnel, began a programmatic and' technical review of TVA's environmental qualification activities and documentation'to determine the degree of compliance with 10 CFR 50.49. The review was conducted at TVA's Office of Engineering in. Knoxville and at the Browns Ferry site, and its scope included TVA's entire EQ program for the Browns Ferry, Watts Bar, and Sequoyah Nuclear Plants. As part of its Knoxville review, the team inspected programmatic aspects (e.g., procedures, list of equipment requiring qualification, design basis accidents, environments, and systems required to mitigate those accidents) of the program and conducted a-100% technical review of 30 EQ binders. These binders are the documents generated by TVA which.contain evaluations to demonstrate qualification'for.the different categories of 50.49 equipment. As part of the site review at Browns Ferry, the team inspected programmatic aspects of the Browns Ferry program and conducted field verification inspections. The. team was also to have performed site reviews at the Sequoyah and Watts Bar facilities, but decided to postpone those reviews based on the results of their work at TVA Headquarters and Browns Ferry.
On August 21, 1985, TVA voluntarily began a shutdown of its Sequoyah facility based on concerns identified by the TVA/WESTEC team that the EQ program at Sequoyah might be inadequate to demonstrate full compliance with 10 CFR 50.49.
The TVA/WESTEC team issued its report on September 25, 1985.
In it, they identified certain unsatisfactory aspects of TVA's EQ program which led them to conclude that documented qualification had not been established for a large i
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i majority of equipment reviewed. The team concluded that, in general, the EQ files.were unauditable, and."where technical information could be found, the majority of it was scattered and not easily retrievable." The team also felt
' that'the types of deficiencies identified were generic to all of TVA's utilities, and not limited to Browns Ferry alone.
1 The report did, however, note several areas of strength, one being the completeness of the list of equipment requiring qualification under 10 CFR 50.49.. Finally, the team recommended that TVA place the highest priority on expeditiously resolving the issues identified in their report.
SEQU0YAH'S ENVIRONMENTAL QUALIFICATION PROGRAM Subsequent to its voluntary shutdown of Sequoyah in August 1985. TVA formed the Environmental Qualification Project (EQP) to develop and implement an EQ documentation program for Sequoyah, to serve as.a prototype for its other nuclear facilities. The EQP was comprised of personnel from TVA's Nuclear Services (P&ENuclear),theplantsites,andTVA'sOfficeofEngineering.
In addition, the Site Director for fequoyah was given the overall responsibility and authority for developing and implementing that plant's EQ program.
In order to accomplish this task, he appointed a Project Manager of the EQP, to work within OE.
While the EQP was designed to function within OE, TVA developed Project Manual j
EQP-01 to define and describe the EQP and its responsibilities, and the EQP-specific instructions and activities that must be followed to meet the responsibilities.
In addition, Sequoyah Practice SQA 173 was developed to describe Sequoyah's overall program for maintaining compliance with 10 CFR 50.49.
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5 EQP-01 prescribes that EQ evaluations are to be performed to demonstrate that electrical equipment is capable of performing its safety function in the ~;ent 1
-of an accident situation. These evaluations are to be documented in EQ binders, which are to be prepared from input' documents including:
--Sequoyah's 50.49 equipment list;
--A detailed checklist governing the preparation of the binder; and
--Field verification data.
l EQP-01 also states that the binderware to be reviewed in the field, and by management, in cases where such a review is requested by the project manager.
Sequoyah issued 97 binders; 96 equipment binders and a general binder documenting general problem areas and broad areas pertinent to the plant's EQ program.
The general. binder also included an overall description of the program and. addressed program-related NRC information notices, circulars, and bulletins. The binders were subjected to field review and a management review, and a quality engineering review was performed on selected binders by I
Sequoyah's Quality Assurance (QA) personnel.
METHODOLOGY FOR NRC'S REVIEW 0F SEQUOYAH'S EQ PROGRAM In a December 2, 1985, memorandum to the Director, NRR, the Director, Office of Inspection and Enforcement (IE), defined the scope of the inspection to be performed by IE at Sequoyah to review TVA's implementation of their EQ program, as required by 10 CFR 50.49. The inspection was to include:
q A detailed review of a majority of Sequoyah's EQ binders to determine l
l that they contain adequate documentation to demonstrate that the
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equipment meets the requirements of 10 CFR 50.49;
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A physical: inspection' of selected equipment to verify that the EQ
' documentation is applicable to the.as-installed equipment;
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.A review of Sequoyah's implementation of a 10 CFR 50.49 program;-
j A review of Sequoyah's implementation of a program to maintain the
-qualification of equipment during the life of-the plant; A review of Sequoyah's implementation of. Technical Evaluation
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' Report / Safety Evaluation Report EQ corrective action commitments; and 1
A review of. corrective actions resulting from the.TVA/WESTEC EQ inspection.
The Director. IE, estimated that at least ten people would be needed to i
accomplish the inspection, utilizing staf_f from NRR, IE, and Region.II, and
. consultants from the Sandia and Idaho National Laboratories.
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.4 TemporaryInstruction:(TI) 2515/76 of the IE Manual, " Evaluation of Licensee's j
Program for Qualification of Electrical Equipment Located in Harsh.
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.. Environments," was the guidance'to be used to review the adequacy of Sequoyah_'s EQ program. This TI was issued March 27, 1986, for the purpose of t
providing guidance for the inspection of licensee environmental qualification programs and for determining that licensee commitments for resolution of outstanding EQ issues are being properly implemented.
j SCOPE j
t We conducted our review in accordance with generally accepted Government j
1 auditing standards between June 1986 and March 1987. Our review included j
interviews with the IE Inspection Team Leader at NRC Headquarters, and an I
extensive review of correspondence between NRC and TVA on the subject of EQ.
In addition, we reviewed inspection reports prepared by the IE Inspection
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Team, transcripts of public Connission meetings, Commission papers, agency procedures and other documents pertinent to EQ. Our review included a look at j
Sequoyah's EQ program, the program established by NRC to review Sequoyah's f
effort, and an evaluation of how well NRC carried out its review of Sequoyah's EQ program.
FINDINGS i
j Our review di.sclosed that NRC has done a good job of establishing and implementing a program for evaluating the EQ program at Scquoyah.
In December 1985, the Director, IE, established a set of criteria for the review to follow, and the inspections were performed in accordance with that criteria.
l NRC formed a 13 member inspection team, comprised of 10 staff members from IE, NRR, Regions II and IV, and 3 individuals from the Sandia National Laboratory.
l The team conducted four inspections of Sequoyah's EQ program at TVA's corporate Headquarters in Knoxville, Tennessee, and at the plant itself between January 1986 and April MP.7.
Based on discussions with the inspection team's leader, we found that the team used the guidance provided in TI 2515/76 and evaluated Sequoyah's program by:
reviewing the procedures for j
controlling the licensee's EQ efforts; examining the licensee's qualification documentation files; verifying the adequacy and accuracy of the licensee's 50.49 equipment list; examining the licensee's program for maintaining the qualified status of the covered electrical equipment; evaluating the licensee's corrective action on the findings of the TVA/WESTEC management review; conducting a physical inspection of the plant; and reviewing cmployee concerns.
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1 During their inspections, the NRC inspection team' identified several J
c unresolved items; however, by the end of their April 1987 inspection, only one remained unresolved. During their April 1987 inspection, the NRC inspection team determined that TVA had yet to complete several items of fieldwork 1
identified during NRC's inspections. The inspectors also determined that TVA l
has a tracking system to assure completion of the work prior to restart. This i
item is being tracked as a confirmatory item in the final EQ Safety Evaluation Report (SER),whichwasissuedonApril 30, 1987. When TVA submits its j
corrections for the completion of all fieldwork, the inspection team will i
i review a sample of the items to verify completion prior to restart.
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Also, during the course of some routine testing, TVA found that some areas within Sequoyah's containment reached higher temperatures than had previously been anticipated. Accordingly, affected equipment in these areas must be requalified at these higher temperatures to ensure compliance with 10 CFR 50.49. TVA is_ currently working on a plan to correct the situation; then it must implement the changes. As this item was not identified through NRC's EQ review, it is not being tracked in the EQ SER. Rather it is being tracked as an inspection item, which will remain open until such time as TVA implements
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all necessary changes. The inspection team will verify completion of this item prior to Sequoyah's restart.
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Until recently, TVA officials were planning a July 1987 restart for Sequoyah.
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However, on June 8,1987, NRC made a decision to rev4ew-the-de';4gr Ord rep r
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.:crk pcr4-d on St.quoyah's raw cooling water system prior to the plant's b
restart. Acccrding_tn the airector. Office-of-Special' Projects, his review O 60..t f c..r should take onl-y'thrce cr.d a half months, and upon completion of the review, NRC should be in a position to recommend restart of Sequoyah Unit 2.
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During their inspections, the NRC inspection team identified several unresolved items; however, by the end of their April 1987 inspection, only one remained unresolved.
During their April 1987 inspection, the NRC inspection team determined that TVA had yet to complete several items of fieldwork identified during NRC's inspections. The inspectors also determined that TVA l
has a tracking system to assure completion of the work prior to restart. This j
item is being tracked as a confirmatory item in the final EQ Safety Evaluation l
Report (SER),whichwasissued April 30, 1987. When TVA submits its corrections for the completion of all fieldwork, the inspection team will l
review a sample of the items to verify completion prior to restart.
Also, during the course of some routine testing, TVA found that some areas i
within Sequoyah's containment' reached higher temperatures than had previously been anticipated. Accordingly, affected equipment in these areas must be requalified at these higher temperatures to ensure compliance with 10 CFR TVA is currently working on a plan to correct the situation;.then it 50.49.
As this item was not identified through NRC's EQ must implement the changes.
review, it is not being tracked in the EQ SER. Rather it is being tracked as an inspection item, which will remain open until such time.as TVA implements i
The inspection team will verify completion of this item all necessary changes.
prior to Sequoyah's restart.
Until recently, TVA officials were planning a July 1987 restart for Sequoyah.
However, on June 8,1987, NRC made a decision to conduct an integrated design /
construction inspection on Sequoyah's essential raw cooling water system prior This review should take about four months, and upon to the plant's restart.
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completion of the review, NRC should be in a position to recomend restart of Sequoyah Unit 2.
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s.- e CONCLUSION f.6 Based on our review, it appears that NRC has performed a review of Sequoyah's.
l EQ program sufficient to ensure their qualification under 10 CFR 50.49.
H We also feel that _NRC's inspections have been well planned, conducted in accordance with the established criteria, and performed both professionally and timely. All this has been evidenced in the inspection reports, which were all well organized and clearly written.
AGENCY COMMENTS
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To be provided.
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