ML20236M661

Forwards Summary of 870924 Mgt Meeting W/Util to Discuss Concerns Re Utils Handling of Equipment Operability Problems & Scope of Corrective Programs in Response to Violations Noted in Insp Repts 50-327/87-50 & 50-328/87-50

ML20236M661
Person / Time
Site:	Sequoyah
Issue date:	10/30/1987
From:	Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	White S TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8711130231
Download: ML20236M661 (7)

See also: IR 05000327/1987050

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6N:38A Lookout Place

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1101 Market. Street

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Chattanooga, TN'. 37402-2801

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Gentlemen:'

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SUBJECT: ' MEETING SUMMARY

.SEQUOVAH,' DOCKET ~NOS. 50-327 ' AND 50-328 -

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This. refers to the management meeting conducted,'. -at our request, at the'.

Sequoyah site'on September 24,.1987. :The meeting was: held to discuss. concerns

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related to:

TVA's handling of current matters involvi

problems; and the scope -of TVA's : corrective programs ng equipment operability

for_ past'and current.

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operational events.

A summary of the meeting topics is provided in Enclosure.

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A list of attendees at the meeting is shown in Enclosure'2.

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It is our opinion that' this' meeting was' benefic'ial' in that'.we feel it provided .

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both the NRC and TVA a better. understanding of;the issues.

As discussed in the'-

meeting, specifics on' the recent NRC review of. TVA's responses ~to violations

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associated with' the 1984 thimble tube ejection event .have been issued with:

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Inspection Report 50-327,326/87-50.

Additionally, TVA commitments ' regarding L

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the containment spray system are provided in Enclosure 1.

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In accordance with -Section' 2.790 ' of NRC's " Rules Lof.. Practice," .Part 2,LTitle

10,. Code of Federal Regulations, a copy of this lettercand. its. enclohures will.

be placed in the NRC Public Document Room.

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Should you have any . questions concerning' these matters,,we will be pleased to'

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discuss them.

Sincerely' . ORIGINAL SIGNED BY

q GARY G. ZECH

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Gary G. Zech, Assistant Diredtori

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for Inspection Programs

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TVA Projects Division .

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Office'ofSpecial' Projects

Enclosures:

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Meeting Summary

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2.

Meeting Attendees

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(See page 2)

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., , / Manager .' . . . . ' d WVA Representative,iBethesda- W Office 1 m - ? eAccw/encis- i ' ' !- -V J. G. Keppler 0SP ) , [ . /S. . D. Ebneter,EOSPs 1 , /J..A. Zwolinski, OSP' s - ' /8. D. Liaw, OSP s

, y S. D. Richardson, OSP K. P. Barr, OSP/RII 1 F. McCoy, OSP/RII:. " R. Carroll, 0SP/RII 1 . Brady,'OSP/RII. vfuh, Resident. Inspector - 1 I .c. ' ' NRC Document Control. Desk '; State of' Tennessee- ~ , , , /1'Rutberg,0GC o < 1 , ,, \\; ! O I II ^ RCarroll:er: 'FM KB r- ~.10//f/87 10 87 '. M10/p87 g-. . . [ ,1 _l : 't. i \\J ' <i l = i , , ,

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OCT 3 01987 ENCLOSURE 1 On September 24, 1987, representatives of Tennessee Valley Authority (TVA) met with the Office of Special Projects-NRC, at NRC's request, at the Sequoyah site. The purpose of the meeting was to discuss concerns related to: TVA's handling of current matters involving equipment operability problems; and the , scope of TVA's corrective programs for past and current operational events. ' NRC opened the meeting by telling TVA that their handling of current equipment operability problems had raised concerns by the staff. The specific matters prompting these concerns were then briefly summarized as follows: (1) Auxiliary Feedwater (AFW) Pump 2A-A; Fc11owing installation of the cavi- tating venturi in 1984, the pump could not deliver 440 GPM (bases for Technical Specification (TS) D/P value). Subsequently, TVA analysis identified that a flow of 400 gpm, would provide adequate cooling capacity, and Unit 2 was returned to power operations without disposition of the TS test value. The NRC staff considered that TVA did not implement 10 CFR 50.59 adequately in that a Technical Specification change was required and not requested and commission approval for the modification and degraded flow condition was not obtained. The NRC was concerned that without recent NRC intervention, this condition would not have been adequately resolved prior to restart. (2) Hydrogen Analyzers; Both Unit 2 trains appear to be inoperable due to ' initial design and construction deficiencies. After being made aware of NRC concerns, TVA determined the system to be adequate without proper , walkdown and evaluation. If not for NRC involvement since November 1986, the deficiencies would have gone undetected and uncorrected. (3) Essential Raw Cooling Water (ECRW) Screen Wash System and Strainer Backwash System; Screen differential level detectors have been defective since 1980. Power was removed from screen wash and strainer backwash pumps on May 16, 1986, such that automatic operation was defeated. The system was used in intermittent manual operation only. There was no safety evaluation performed or formalized procedure for system control in this state. Night orders were used to control it. Furthermore, there were no established provisions for assuring maintenance of screens and strainers during an event. (4) ERCW Skid Valves; ERCW supply to safety injection and coolant charging pumps passes through unlabeled and uncontrolled in-line valves located on the pump skids. This condition has existed since initial startup and has remained uncorrected until NRC identification in August 1987 despite Design Baseline Verification Program (DBVP) and associated surveillance instruction (SI) system walkdowns performed by TVA. (5) Containment Spray (CS) System; During preoperational testing, pump head inadequacies were discovered and flow orifices were installed in both units to increase pump D/P without addressing or verifying the affect on system flow. The inappropriate orifice installation and the resultant reduction in CS flow, was identified through TVA's special Nuclear Per- formance Plan (NPP) programs for DBVP and restart testing. The NRC feels

.. , . , ,, , Oct 3 01987 j ' , 1

Enclosure 1 2 j q . . . +! that the identified hardware problem would have be'en / corrected by TVA 1 prior to heatup However, the Condition. Adverse to Quality Report (CAQR) ] identifying this problem was marked.with " deportability" indeterminate. 9 It was not until three? months later that- the CAQR was revised to.be - l reportable. Consequently,- the NRC is concerned on: how timely:TVA will' ( be 'on determinations involving equipment operability and event.reporta- 1 bility when.the units are operating. ~ ' In response to the individual matters ' addressed labove, the followingl comments were made: .] (1) AFW Pump 2A-A; TVA stated that when;the flow rate dropped.in 1984 1 after irotalling the cavitating venturi, they had Westinghouse- perform an analysis. The; analysis supported a flow rate of 400 GPM: - and the ' related surveillance instruction was changed accordingly. . TVA stated that this matter was informally discussed with the NRC- staff and based on this discussion, TVA felt the subsequent. restart l in 1985 was okay. However, TVA indicated .that they had always - H intended to restore the flow rate back to 440 GPM as evidenced by the- fact that they replaced the flow venturi during this current outage. Additionally, they said the pump's. impeller was just recently replaced when it became evident to them that the NRC had related concerns. NRC pointed out to TVA that when the. flew rate .of 440 'GPM could not ~ ' be obtained, the modification made to AFW pump 2A-A no longer met the requirements of 10 CFR 50.59. Consequently, a TS change was required 1 prior to Unit 2 restart in 1985. TVA acknowledged this and indicated ' that they have~ taken corrective actions to assure such occurrences are prevented' in the future. Stated corrective actions . include an 1 independent review of the engineering safety' evaluation ~ by licensing personnel prior to the performance.of related work; as well as a licensing review of the work plan after the work' is comp 1ete' to assure no changes, test deficiencies, etc. have occurred. 1 (2) Hydrogen Analyzer; The licensee indicated that this system had been plagued with installation problems (ie. , piping, power supplies,- reagent air supplies etc.). TVA's determination that the system was adequate without doing a proper walkdown or evaluation, was attri- buted by TVA to be an attitude problem of both the lower and middle management involved. In part, this situation was considered to be an. - engineering / operations interface problem.' Accordingly, TVA indicated i plans to acclimate and train their. design engineering staff on TSs and their importance to the plant. Additionally, TVA suggested- , that SI repeatability problems may have led TVA to correct some of the system s deficiencies prior to restart. (3) ERCW Screen Wash S agreement with NRC'ystem and Strainer Backwash System; TVA was in s dissertation of. the problem. .They expressed a new policy of no longer accepting such conditions. To assure that similar situations don't exist, TVA indicated that night orders, hold orders and temporary alteration control forms were presently being reviewed, and an enhanced staff interview arocess.was in progress to identify similar type problems. At the t me of the meeting, there - . _ _ . _ _ _

.j . 007 3 o jggy Enclosure 1 3 l I ! had been no similar problems found. However, a large majority of night orders were found to provide instructions on the use and j manipulation of safety-related equipment. These night orders were in

the process of being eliminated and appropriate procedural instruc- l tions were being written in their place. The existing night order ' instruction (USLA-30) was also being changed to provide better guidance in this area. Additionally, some long standing tagouts (hold orders) were found to be in effect, providing isolation .of i, nonessential or partially eliminated equipment. 'An unresolved safety l question determination (USQ9) was made for each of these items, and j the hold order procedure (AI-3) was being changed to ensure an USQD is performed for such long term tagouts during the yearly review / rewrite of existing hold orders . in effect. The licenses;also indicated that enhancements made to the procedural change process through the new PORC operation, as well as recent stream lining of .i the design change process, have helped eliminate these contributing ! factors to the problem. j (4) ERCW Skid Valves; TVA pointed out that the DBVP walkdowns would not have identified the existence of the skid valves; however, the i walkdown associated with the related SI review should have. The i fact that it didn't was attributed to personnel error. At the time. ] of the meeting, TVA was in the process of looking at other skid

mounted equipment, and had yet to find any similar type control - problems. The licensee stated that prior to restart, related pro- ! cedures would be changed accordingly to ensure control of the skid j valves. Additionally, TVA indicated that all valves 'in the 37 i systems reviewed during the DBVF will have tags and label plates ! before restarting. ' (5) CS System; TVA indicated that the related deficiency was identified ) as a heatup item, and that the CAQR was marked indeterminate because ! more informatio, was requested to support an. engineering evaluation. Since CS is not required in mode 5, TVA saw no immediate urgency attached to the engineering evaluation. TVA assured the NRC that s when an apparent problem like the CS issue :is identified while l operating, the appropriate TS action is taken immediately, and the engineering evaluation is performed in parallel.

When questioned as to who was aware of the " indeterminate" CAQRs, j the licensee indicated it was the C < 3 Operational Review Staff

(PORS) supervisor; and it was he .o iforned the plant if the

identified problem is a TS operab), / .ssue. The NRC told TVA that l they should consider keeping the y a tions management (i.e., Plant I Manager, Site Director, Assistant Site Director, etc.) informed of all " indeterminate" CAQRs and not rely solely on the PORS ! supervisor's discretion. TVA ackn71 edged the concern and said they ! would pursue an amenable solution. To help bridge the gap between l operations and engineering, TVA said they planned to put design j engineers in the system engineering group to allow them first hand , knowledge of system test results and equipment problems. l ! l, m_______. . _ _ _ _ _ _ _ _ _ _ _ _ ]

. m ' - , , .. . . < LOCT 3 0 1987 - ' ' Enclosure 1 41. f . '

q 2:n , , . 17 oy ' Additionally,discussionspecifi4allycreiatsdtotheCSsystem'ledtoi j the following licensee commitmhis R Q ' (a) . Perform .an engineering evaluation lof Lthe". test, results for' CS pump 2A. and verify that test data' is 'not indicative of: possible pump' failure, ys , (b) Look into scaling -control ' room ' indication thing' test; results from. previous tests.' (c) Review the .lo' cation off the ANUBAR flowfinstruments L and evaluate , the possibility, of any' r,eeded. modifications ~.' (d) Verify heat' exchanger D/P during.each SI?or ASME .section XI-. testing of-the pump and add an acceptable fouling ~ factor. j l Having completed the discussion of current operatio'al matters,,tho'. n

meeting focused in on the recent NRC review of the 1984 thimble . tube l ejection event. Specifically, NRC expressed the . concern that TVAf s, i ! responses of two of 'the related violations (50-327,328/84-24-011and' ] l 02) indicated an inadequate root cause a'nalysis, Lresulting in cor . rective actions that may. not- be appropriate to preclude recurrence.. q l 1 i TVA was told that the specifics of the' NRC review would be. issued in' Inspection Report ' 87-50. At that . time TVA would b'e requested 'in- writing to evaluate NRC concerns in this area, and; identify whether corrective actions. associated with recent operational- events, such: ! es the reactor coolant 's encompass these concerns. pill events of February and April-1987,, Additionally, TVA was l told . that ithey -

o l should identify what actions .they consider 'necessary to assure that , problems are adequately analyzed for root cause in order that appro- l priate corrective actions -are identified. - TVA.-indicated that they [ understood, and would proceed with their own review. , , '

The meeting was brought to..a clo'se with the. general understanding . that the current equip /.ent operability matters discussed .in :this meeting were still under NRC evaluation'for' potential enforcement action. i _ _ . _ _ _ _ _ _ _ _ _ _ _ . - _ _

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00T 3 01987

ENCLOSURE 2

-1 Heeting Attendees. d j l U. S. Nuclear Regulatory Commission

S. D. Ebneter,'. Director, Division of TVA Projects (TVAPD),.0SP G. G. -Zech, Assistant Director for Inspection Programs, TVAPO, OSP K. P. Barr, Deputy. Assistant Director for Inspection Programs, TVAPD, OSP. . F. R. McCoy, Section Chief, Sequoyah 1 R. E. Carroll, Jr., Project Engineer, Sequoyah y K. M..Jenison, Senior Resident Inspector, Sequoyah. j P. M. : Harmon, Resident Inspector, .Sequoyah; ' W. K. Poertner, Resident Inspector,.Sequoyah , M. W.' Branch, Startup Coordinator, Sequoyah- iq Tennessee Valley Authority 1 ! C. C. Mason, Deputy Manager, Office of Nuclear Power i H. L. Abercrombie, Site Director, Sequoyah Nuclear. Plant 4 J. LaPoint, Assistant Site Director 1 L. M. Nobles, Plant Manager l R. Lewis, Assistant to the Plant Manager J M. R. Harding, Engineering Group Manager R. H. Buchholz,-Sequoyah Site Representative

, L. E. Martin, Manager,' Site Quality . ) J. H. Sullivan, Supervisor, Plant Operational Review Staff. J. Hosmer, Division of Nuclear Engineering R. H. Scheide, Licensing Engineer ] ! 4 i 1 - _ _ _ _ - _ _ _ . _ _ - - }}