ML20236D444

Informs Commission of Status of Issues Requiring Resolution Before Restart.Staff Intends to Meet W/Commission Again to Obtain Approval Authorizing Facility to Go Critical.Facility May Be Ready to Achieve Criticality in Nov 1987

ML20236D444
Person / Time
Site:	Sequoyah
Issue date:	07/16/1987
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
TASK-PII, TASK-SE SECY-87-173, NUDOCS 8707300451
Download: ML20236D444 (44)

Text

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July 16, 1987 POLICY ISSUE -

g g SECY-87-173 For: The ' Commissioners From: Victor Stello, Jr.

Executive Director for Operations

Subject:

STATUS OF STAFF ACTIONS REQUIRED BEFORE RESTART OF I SEQUOYAH 2

Purpose:

To provide the Comission with a summary report on the status of issues requiring resolution before the restart of Sequoyah Unit 2.

Backcround: The Sequoyah Nuclear Plant consists of two units, each rated at approximately 1150 MWe. These units were shut down by TVA in August 1985 because of questions about the environmental qualification of electrical eauipment. On September 17, 1985, the NRC requested, pursuant to 10 CFR 50.S4(f), that TVA submit information regarding its plans for correcting problems in the overall management of its nuclear program and, among other things, its plans for correcting problems at Sequoyah. Later i in 1985, the Comission established the NRC Senior Management Team, supported by the TVA Project staff within NRR, to oversee the activities required for restart of the TVA operating reactors and the licensing of Watts Bar and Bellefonte. The NRR j

staff identified a number of major TVA issues requiring reso-  :

lution prior to the restart of any of the TVA reactors and '

provided periodic status reports to the Comission, the most recent of which was issued December 9, 1986 (SECY-86-1F).

On February 9,1987, the Commission established the Office of Special Projects (0SP) to, among other things, efficiently and i aggressively (1) identify and resolve the problems causing the '

shutdown of TVA's Sequoyah and Browns Ferry facilities and prevent their recurrence and (2) evaluate TVA's Watts Bar facility to identify, assess and resolve the problems that prevent the licensing of this facility and to ensure that the facility is in compliance with the Commission's regulatory requirements. On April 15, 1987, OSP briefed the~ Comission on its activities and its initial impressions of TVA's activities for the restart of Sequoyah. In that meeting, OSP informed the

~ Commission that it would plan at least two additional Commissicn meetinas prior to recommending restart of Sequoyah Unit 2 (SON 2). Thir paper forms the basis for the first meeting.

Contact:

S~. Richardson, OSP x?9044 e7o739hi PDR s 870716 87-173 PDR

a The Commissioners Discussion: Since April 15, 1987, the staff and TVA have made substantial progress on the resolution of key issues affecting Sequoyah.

During the April 15, 1987 Ccmmission briefing, the staff pre-vided the Commission with a slide that categorized the status of key issues in one of three categories: A) NRC and TVA are in agreement re handling of problem; NRC review schedule con-sistent with licensee schedule; B) NRC and TVA are in agreement re handling of problem; licensee schedule overly optimistic or NRC review is behind schedule; C) Questions exist re handling of problem. This slide (Enclosure 1) has been updated to inclade all of the major technical issues that have been or are being resolved. A summary of each issue is provided in Enclosure 2.

In the discussion which follows, the staff discusses five major issues in which the Commission has expressed interest: the schedule for SQN 2 restart, the Integrated Design Inspection (IDI) effort, harassment and intimidation issues (H&I), manage-ment, and environmental qualification of electrical equipment (EQ). The staff also discusses the significant issues which appear at this time to have the greatest potential to affect SQN 2 restart: the adequacy of cable installation, TVA regeneration of civil engineering design calculations, the restart test program, the fuse replacement program, and the readiness of the plant staff to resume operations. As indicated .

previously, the remaining major technical issues are summarized in Enclosure 2. {'

(a) Schedule for SCN 2 Restart i The staff has approved the restart criteria used by TVA to identify issues that must be resolved prior to Sequoyah and Browns Ferry restart. A copy of the criteria is provided in Enclosure 3. The staff's appro' al was documented in a June 9, 1

1987 letter to TVA. In its let:er, the staff concluded that the criteria were sufficiently c,onst.rvative and were, therefore, acceptable. The staff documented its understanding that the words "significant probability" and "high probability" in the criteria would be interpreted conservatively. In addition,  ;

the staff documented that Criterion 3 of the restart criteria was not intended to exclude deviations from the FSAR not previously reviewed in accordance with 10 CFR 50.59.

Having approved the restart criteria, OSP identified the NRC staff activities necessary before the restart of Sequoyah Unit 2. These were identified in the OSP Sequoyah Activities Schedule sent to the Commission on June 23,1987(SECY87-153).

The staff has now revised the schedule to take into account the Integrated Design Inspection (IDI) and to update recent changes in other activities. Revision 1 of the schedule (Enclosure 4) contains a target date for non-nuclear heatup of SCN 2 of August 27,1987,'anc criticality nc earlier than '

November 6, 1987. A Commission decision on criticality will

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not be requested until after the satisfactory completion of the l IDI. If major- prohiins are identified as 'a result of the IDI, '

the scheduled dateffer criticality wculd likely be celayed.

(b) The Inteorated Desion Inspection o l The staff has been closely monitoring TVA's efforts to identify I and resolve the many issues that need to be addressed prior to Sequoyah restart. Although the efforts have been quite extensive, c the identification of issues has been an evolving process and somewhat fragmented. Issues had been raised regarding the similarity between Sequoyah and Watts Bar and, therefore, the potential for problems at Watts Bar to have occurred at Sequoyah.

Allegations persist regarding Sequoyah's compliance with comit- 1 ments made in its Final Safety Analysis Report (FSAR) and former Commissioner Asselstine questioned how the staff knew-  !

whether Sequoyah's original design was adequate. In examining these;i!; sues, the staff observed that TVA's engineering and design review afforts to date have concentrated en separate programs looking horizontally across the safety systems at Sequoyah and focused on the specific concerns raised. TVA's efforts hava;not included a vertical review through one or more' safety systems that would provide additional assurence i that 611 major design and construction problems have been identified and resolved prior to SON 2 restart.

Accordingly, the staff decided that an independent design / con-struction verification of at least one safety-related system  !

should be undertaken. 'The staff notified TVA of its decision in l a letter dated June 2, 1987 and indicated that the " vertical slice" verification should include significant aspects of the interactions l add interfaces throughout design , engineering and '

construction. !t should focus "on areas not directly s.;vered by TVA's efforts and should minimize redoing work already performed by TVA. During a ineeting on June 8,1987, TVA proposed to have its Engineering Assurance (EA) organization conduct the verifi-cation. Although the staff has?a high regard for the EA organi-zation, the staff concluded that because EA had been involved in much of the work already done by TVA, it did not provide any real degree of independence. Furtnsrmore, EA did not believe any additional review was necessary. The staff gave TVA the choice of hiring an independent cont'ractor or having the NRC do the work.

s TVA stated that an independent contractor would take at least nine months to complete the effort, unreasonably delaying Sequoyah restart, and it could not commit to such a program at that time.

~ Therefore, the NRC staff elected to perform the review itself.

'The staff has chosen the Es$ential Raw Cooling Water System (ERCWS) for the " vertical sli e" review. The entrance meeting fer this effort was held on July 8, 1987 and the report docu-menting the inspection review i!! expected tc be completed by p< November 6, 1987. Although this effort is likely to identify j '. '

race problems, the staff expects this review to provide the ioded confidence that no major problems have been overlooked, y - ,

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G I o The Commissioners The activity is fee recoverable and, therefore, the ccst of j the inspection will be borne by the license 2. 1 l

(c) Harassment and Intimidation Issues 4 In early 1985, the number of TVA employees reporting safety ,

concerns about Watts Bar to the NRC rather than TVA sharply increased. The employees expressed concerns regarding fear  ;

of reprisals by TVA management if they had reported the concerns to TVA. NRC made TVA aware that it was receiving large numbers of concerns and as a result, TVA hired a private contractor (QTC) to interview all employees at the Watts Bar site to attempt to determine the scope of the employee concerns. These interviews resulted in approximately 5000 Employee Concerns. About 100 concerns were related to harassment and intimidation (H&I). Some of the H&I concerns were investigated by QTC.

Some were referred to the TVA Office of the General' Counsel for i investigation. QTC subsequently was dismissed by TVA and, with I the creation of the Office of the Inspector General in February 1986, the Inspector General (IG) ersumed responsibility for investigating concerns related to H&I.

l The H&I concerns that had been made to the NRC were referred to NRC's Office of Investigations (01) for investigation. OI issued an investigation report in April 1986 which found several incidents of discrimination for reporting safety concerns had l occurred from 1981 through 1985. The staff issued a civil penalty enforcement action for these incidents which TVA paid in August 1986. Subsequently, it was determined that concerns related to H&I that may have occurred prior to the hiring of Mr. White (Manager of the Office of Nuclear Power) and the restructuring of TVA's corporate organization should be referred '

to the TVA IG for resolution. Allegations of H&I that occurred after the niring of Mr. White were and continue to be referred to 01.

The staff is currently planning an in-depth review of the H&I area. This will include a review of (1) the results of the ,

IG's investigation reports and actions taken by TVA in those i cases in which the allegations were substantiated, and (2) the ,

TVA actions to programmatically eliminate those factors that  !

contributed to the H&I environment. '

(d)ManacementIssues l In its 10 CFR 50.54(f) letter, the staff identified that manage-I ment deficiencies were part of the underlying cause of the problems with TVA's nuclear activities. TVA was directed to address these deficiencies in its response to the letter. The TVA Board of Directors' response to the staff's 10 CFR 50.54(f) letter was to hire the current Manager of the Office of Nuclear Pcwer and provide him with the resources, authority, and responsibility for the total, management, control, and super-vision of the TVA nuclear power program. The Office of Nuclear 4

.. The' Commissioners Power generated the Corporate Nuclear Performance Plan (CNPP) describing the actions taken by TVA to strengthen management, to improve the or nuclear program,toganization responsible improve employee for implementing confidence the and to imple-raent virious new programs and activities. The staff safety  !

evaluation report (NUREG-1232) on the Corporate Nuclear Perfor- I mance Plan is expected to be issued by the end of July 1987. j 1

The staff concluded from its review of the CNPP that the organi- l zation and staffing of the Office of Nuclear Power and the  ;

programmatic improvements in place or under way are sufficient, if properly implemented, to resolve the concerns at the cor-porate level that led to issuance of the staff's 10 CFR 50.54(f) letter and to support continuing TVA nuclear activities, including plant operations. The TVA Board of Directors will be requested to notify the NRC at least 30 days prior to any  ;

permanent change in this organization, or permanent replacement of senior managers, including the Site Directors. Because the TVA corporate plan is programmatic, its effectiveness depends on its implementation and the NRC staff plans to closely monitor this implementation. i l

The staff is also reviewing the Sequoyah Nuclear Performance Plan, which identifies the root causes of problems specifically related to Sequoyah, describes plans for correcting these problems, and responds to the Sequoyah plant-specific issues i raised in the NRC 50.54(f) letter. This Plan describes the 1

26 special programs under way at TVA, many of which are covered 1 in the summaries in Enclosure 2. The staff's SER on this Plan will be issued before Sequoyah is permitted to go critical.  !

The NRC staff also plans to closely monitor the Plan's implementation.

(e) Environmental Qualification of Electrical Eouipment The main issue which precipitated the shutdown of the Sequoyah units in 1985 was the environmental qualification of electrical equipment (EO). The NRC staff has completed a comprehensive review of the Sequoyah E0 program including a number of inspections of its implementation and concluded that, after satisfactory completion of identified plant modifications, i the program will be in compliance with the requirements of 10 CFR 50.49. These modifications will be completed and completion will have been certified by TVA prior to restart.

The staff now considers Sequoyah's E0 program to be one of the better programs in the nuclear power industry.

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. The Commis'sioners (f) Other Significant Issues Additional significant technical and operational issues which have the greatest potential to affect SQN 2 restart are discussed below.

(1) Adecuacy of' Cable Installation

' Concerns were raised by TVA employees regarding cable installation. The concerns were that integrity of the insulation of the cables had been degraded in three instal-lation situations: cable pullbys, cable jamming, and long vertical cable runs supported at the top. To resolve these concerns, a testing program was developed by TVA after consultation with the staff. In-situ nondestructive tests (D.C. high potential) of representative worst-case cables were planned. In May 1987, during the initial tests of cables IEEE-383in long)

(1974vertical cablefour standards, runs of in 16accordance with cables in one conduit failed the tests. TVA then began a reevaluation of the cable testing program and has recently provided the outline of a revised test nrogram to the staff. TVA intends to submit a revised program in August 1987 which is expected

' to propose changes to several test parameters previously agreed to by NRC including testing the cables at lower voltages. The staff will review this revised program. If replacement of cables is required, this could become the pacing item for SQN 2 restart, i (2) Desian Calculations Review l TVA instituted a review of essential design calculations to verify that the calculations existed and were adequate to support the design of Sequoyah. TVA completed an initial review of a sample of engineering calculations in the electrical, nuclear, mecnanical and civil areas. Although i nc significant problems were identified in the the nuclear and mechanical engineering calculations, significant problems were identified in the electrical and civil areas. In the electrical area, 100% of the calculat1ons were reviewed and  !

a number of issues concerning circuit breaker sizing and i cable sizing were identified. The calculations were revised as necessary and equipment modifications were made.

Furthermore, TVA reported by letter dated June 12, 1987, that all electrical calculations may be subject to further  !

revision prior to restart for the following reasons: l a) verification of all previously unverified assumptions, j b) deletion of non-conservative or unverified design cable '

lengths, c) correction of deficiencies identified by DBVP, and c) incorporation of configuration control (6s-constructed) craMrgs and applicable DEW walkdewn data. It is not known what impact this will have on restart.

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i In the civil area, about 5000 pipe support calculations I were missing. The staff has required TVA to regenerate I the missing civil calculations, to the extent practicable, prior to restart. The staff will inspect the regeneration ,

of the calculations. (

i (3) Restart Test Prooram i

In response to all of the programs under way since the j shutdown of the Sequoyah plant, a comprehensive restart test program is required to ensure that the plant safety 1 systems are functional before restart of Sequoyah. A start-up testing program is being developed which includes integrated system testing, as well as heat-up, criticality, j and power escalation testing. This program will incorporate .j the results of the post modification review and other Sequoyah surveillance and test programs to produce a compre-hensive set of test requirements. A summary description of the program and a listing and schedule of required testing i identified by this program were submitted on May 26 ano Jily 6, 1987, respectively. However, TVA has not completed a 1 the detailed test procedures. These must be completed prior to commencement of the testing program. Inspections I have been conducted on this program and the staff is in general agreement with the TVA program. An additional inspection is scheduled for late July 1987.

(4) Fuse Replacement There was widespread use of Bussman XAZ fases as primary protection for safety-related circuits at Sequoyah. These fuses lacked certified fuse curves that indicated the fuse l would clear a fault between 5 and 15 amperes and the vendor stated the actuators may ignite and burn instead of opening at 5 to 15 amperes. The fuses were initially replaced by TVA with Bussman MIS-5 fuses. Subsequently, when there were problems with these new fuses they were replaced with Littelfuse FLAS-5 fuses. Recently, it was discovered that 42 of the new Littelfuse fuses had failed at Sequoyah.

This matter is under review by TVA'and the staff.

(5) Operational Readines_s_

In addition to completion of other ongoing technical programs, actions are required to assure that the Sequoyah plant and its management are ready for plant restart. TVA must

1) establish and implement final verification programs to assure all actions required for restart are implemented, and

2) verify that all commitments and regulations are satisfied.

TVA has established general guidance for operational readiness verification and has conducted an interim operational readiness review. Actions to estchlish site implementing accuments for operational readiness reviews must still be finalized.

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.- Tha Commissioners The NRC will independently assess TVA's readiness in these areas.

Over the past several months, TVA management and NRC attention has been concentrated on the review and root cause evaluation of several personnel errors associated with recent operational and testing events. This evalua-tion identified several examples of failure to follow -

procedures,-inadequate procedures and an overall. lack of control over testing evolutions including system and equipment status. These problems are currently being-considered for escalated enforcement and TVA's corrective actions for this. issue are currently being evaluated by the staff.

Conclusion:

Substantial progress has been made both by TVA and the NRC staff in resolving the issues for Sequoyah restart.

However, a number of issues still need to be resolved and key programs completed before the staff will be ready to recommend restart.

The staff intends to meet with theLCommission again to obtain approval to authorize Sequoyah Unit 2' to go - ,

critical. The staff's current schedule indicates that Sequoyah may be ready to achieve criticality in November 1987.

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f V,ctor Stello J r. V f i Executive Director for Operations

Enclosures:

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1. Status of Issues Regarding .

Sequoyah Unit 2

2. Technical Issues Summary Sheets

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3. TVA Restart Criteria

4. OSP Sequoyah Restart Activities Schedule (Rev. 1) (Commissioners,  !

SECY, OGC only). I DISTRIBUTION:

Commissioners OGC (H Street)

OI OIA GPA ACRS EDO SECY s .

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l ENCLOSURE 1 STATUS OF ISSL'ES REGARDING SEQUOYAH, UNIT 2 ISSUE A B C CORPORATE PLAN X SITE MANAGEMENT- X QUALITY ASSURANCE X INTEGRATED DESIGN INSPECTION X DESIGN BASIS VERIFICATION PROGRAM X

' DESIGN CALCULATIONS REVIEW X ALTERNATELY ANALYZED PIPING X HEAT CODE TRACEABILITY X

. CABLE INSTALLATION X FUSE REPLACEMENTS X AMPACITY X

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FIRE PROTECTION X ENVIRONMENTAL QUALIFICATION X WELDING X

~ TECHNICAL SPECIFICATIONS X NUBEG-1150 .

X HYLROGEN ANALYZER OPERABILITY X PROCUREMENT CONCERNS X i MAINTENANCE X POST MODIFICATION TESTING X RESTART TEST PROGRAM X SURVEILLANCE INSTRUCTIONS X CONTROL ROOM DESIGN REVIEW X -

OPERATIONAL READINESS X  !

EMPLOYEE CONCERNS / ALLEGATIONS X  ;

i A, NRC AND TVA IN AGREEMENT RE HANDLING OF PROBLEM, NRC REVIEW SCHEDULE CONSISTENT WITH LICENSEE SCHEDULE, B. NRC AND TVA IN AGREEMENT RE HANDLING OF PROBLEM, LICENSEE SCHEDULE OVERLY OPTIMISTIC OR NRC REVIEW IS BEHIND SCHEDULE, C. QUESTIONS EXIST RE HANDLING 0F PROBLEM, I

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ENCLOSURE 2 l

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1 TECHNICAL ISSUES

SUMMARY

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TABLE OF CONTENTS PAGE I. MANAGEMENT A. CORPORATE PLAN ................................... 1 B. SEQUOYAH SITE MANAGEMENT ......................... 2 C.- QUALITY ASSUPANCE ............................... 3 II. ADEQUACY OF SEQUOYAH DESIGN A. INTEGRATED DESIGN INSPECTION ................... 4 1 B. DESIGN BASIS VERIFICATION PROGRAM ................ 5 )

C. DESIGN CALCULATIONS REVIEW ....................... 6 j D. ALTERNATELY ANALYZED PIPING ...................... 7 f

E. HEAT CODE TRACEABILITY ........................... 8 III. ELECTRICAL ISSUES i

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A. CABLE INSTALLATION ................................ 9 B. FUSE REPLACEMENTS ............................... 10 C. AMPACITY ......................................... 11 IV.. OTHER TECHNICAL i A. FIRE PROTE'CTION ................................. 12-B. ENVIRONMENTAL QUALIFICATION ..................... 13 C. WELDING .......................................... 14 D. TECHNICAL SPECIFICATIONS ........................ 15 E. NUREG-1150 ...................................... 16 F. HYDROGEN ANALYZER OPERABILITY ................... 17 G. PROCUREMENT CONCERNS ............................ 18 H. MAINTENANCE ..................................... 19 V. RESTART READINESS A. POST MODIFICATION TESTING ....................... 20 i B. RESTART TEST PROGRAM ............................ 21 j C. SURVEILLANCE INSTRUCTIONS ....................... 22 D. DETAILED CCNTROL PCOM DESIGN REVIEW ............. 23 E. OPERATIONAL READINESS ............................ 24 VI.EMPLOYEECONCERNS/ ALLEGATIONS........................25-26

ISSUE: CORPORATE PLAN PROBLEM: THE NRC'S 50.5h(F) LETTER OF SEPTEMBER 17, 1985, REQUESTED SPECIFIC INFORMATION REGAPDING ACTIONS TAKEN OP PLANNED BY TVA TO IMPROVE CORPORATE OVERSIGHT, DIRECTION, AND SUPPORT OF NUCLEAR POWER I ACTIVITIES. I TVA ACTION: IN RESPONSE TO THE NRC 50.54(F) LETTER, TVA SUBMITTED ITS NUCLEAR PERFORMANCE PLAN (NPP) - i CORPORATE (REVISED) , VOLUME 1 0F THE NPP). THIS PLAN DESCRIBES ACTIONS TVA HAS TAKEN TO IMPROVE ITS I OVERALL MANAGEMENT OF ITS NUCLEAR PROGRAM. THESE )

ACTIONS INCLUDE: HIRING, TRAINING, DEVELOPING AND PROVIDING FOR THE RETENTION OF EXPERIENCED NUCLEAR MANAGERS; RESTRUCTURING THE TVA ORGANIZATION TO l CONCENTRATE AUTHORITY FOR NUCLEAR OPERATIONS UNDER l' THE MANAGER OF NUCLEAR POWER AND TO REMOVE ALL NON-NUCLEAR ACTIVITIES FROM HIS PURVIEW; CONSOLIDATING THE CA/QC FUNCTIONS; ESTABLISHING CLEAR LINES OF RESPONSIBILITY FOR ENGINEERING ACTIVITIES; REORGANIZING THE TRAINING PROGRAM; AND CENTRALIZING LICENSING ACTIVITIES. IN ADDITION, TVA HAS TAKEN STEPS TO IMPROVE EMPLOYEE CONFIDENCE i IN TVA'S NUCLEAR MANAGEMENT. SOME LONGER-TERM i PROGRAMMATIC IMPROVEMENTS ARE STILL UNDER WAY AND l WILL BE COMPLETED AFTER RESTART. l 1

NRC RESPONSE: THE STAFF HAS CONCLUDED THAT, FROM A PROGRAMMATIC I STANDPOINT, TVA HAS ACCEPTABLY ADDRESSED THE l CORPORATE-LEVEL CONCERNS RAISED BY THE STAFF IN THE l 10 CFR 50.54(F) LETTER. SINCE THE TVA CORPORATE l PLAN IS PROGRAMMATIC, ITS EFFECTIVENESS DEPENDS  !

UPON ITS IMPLEMENTATION WHICH THE STAFF WILL )

CLOSELY MONITOR. HOWEVER, STAFF OBSERVATIONS TO l DATE ARE GENERALLY FAVORABLE. THE STAFF'S ACCEP- l TANCE OF THE.CORPCPATE PLAN IS BASED UPON THE l CURPENT MANAGER OF THE OFFICE OF NUCLEAR POWER, THE OTHER SENIOR MANAGERS CHOSEN BY HIM, AND THE NEW ORGANIZATIONAL STRUCTURE. THEREFORE, THE STAFF WILL FORMALLY REQUEST THAT TVA NOTIFY THE STAFF AT I LEAST 30 DAYS PRIOR TO ANY PERMANENT CHANGE TO THE I CORPORATE ORGANIZATION OR PERMANENT REPLACEMENT OF SENIOR MANAGERS.

STATUS: PROGRAM REVIEW COMPLETE. IMPLEMENTATION CURRENTLY BEING MONITORED. THE STAFF SER IS EXPECTED TO BE ISSUED IN JULY 1987.

POTENTIAL SHORTCOMING: NONE EXPECTED.

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I ISSUE: SEQUDYAH SITE MANAGEMENT

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PROBLEP: THE NRC'S 50.54(F) LETTER OF SEPTEMEFR 17, 1985, REQUESTED SPECIFIC INFORMATICM P.EGARLu1G ACTIONS TAKEN CP PLANNED BY TVA TO IMPRCVE MANAGEMENT OVERSIGHT, DIRECTION, AND SUPPORT OF SEQUOYAH SITE ACTIVITIES.

TVA ACTIONS: IN RESPONSE TO THE 50.54(F) LETTER, TVA SUBMITTED THE SEQUOYAH NUCLEAR PERF0FMANCE PLAN (VOLUME 2 0F q THE NPP). IN THIS PLAN, TVA DESCRIBED CORRECTIVE '

ACTIONS TO 1) RESTRUCTURE THE SEQUOYAH SITE ORGANIZATION TO BE COMPATIBLE WITH THE RECENT j CHANGES TO THE CORPORATE STRUCTURE, 2) PREPARE POSITION DESCRIPTIONS WHICH DELINEATE AREAS OF RESPONSIBILITY AND AUTHORITY FOR SITE MANAGEMENT, '

INCLUDING REPORTING CHANNELS AND INTERFACES, 3)

DEFINE TRAINING ACTIVITIES, SUCH AS SHIFT TECHNICAL ADVISOR TRAINING OR SENIOR REACTOR OPERATOR LICENSE TRAINING FOR MANAGERS, AND 4) ESTABLISH SPECIFIC j SITE IMPROVEMENTS SUCH AS, FOR EXAMPLE, A SITE '

LICENSING GROUP.

NRC RESPONSE: THE STAFF HAS CONCLUDED THAT TVA HAS ACCEPTABLY  !

ADDRESSED, FROM A PROGRAMMATIC STANDPOINT, THE SITE l l LEVEL MANAGEMENT CONCERNS RAISED IN THE 50.54(F) l l LETTER. HOWEVER, THE STAFF WILL CLOSELY MONITOR IMPLEMENTATION OF THIS PROGRAM.

1 STATUS: PROGRAM REVIEW COMPLETE. IMPLEMENTATION CURRENTLY BETNG MONITORED. THE STAFF SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUED IN SEPTEMBER 1987. ,

POTENTIAL SHORTCOMING: NOME EXPECTED 2-s

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. i ISSUE: QUALITY ASSURANCE  !

FROBLEM: THE NRC'S 50,54(F) LETTER REFERRED TO A NUMBER OF i INSTANCES OF POOR PERFORMANCE IN THE QUALITY ASSURANCE AREA INCLUDIt!G THREE SUCCESSIVE SALP PEFICDS WITF RATIl!GS OF 3 IN CUALITY ASSURANCE AT BOTH SECUOYAH AND BROWNS FERRY.

TVA ACTIONS: IN RESPONSE TO THE 50.54(F) LETTER, TVA HAS REVISED ITS QUALITY ASSURANCE TOPICAL REPORT TO INCLUDE A fiUMBER OF CHANGES INCLUDING: 1) RESTRUC-TURING THE NUCLEAR QUALITY ASSURANCE ORGANIZATION i TO INCLUDE A SITE REPRESEtlTATIVE AT EACH SITE REPORTING TO THE NEW DIRECTOR OF NUCLEAR QUALITY ASSURANCE, 2) CONSOLIDATING ALL NUCLEAR QUALITY ASSURANCE AND QUALITY CONTROL FUNCTIONS UNDER THE  :

DIRECTOR OF NUCLEAR QUALITY ASSURANCE, 3) ADDING AN ENGINEERING ASSURANCE ORGANIZATION FOR AUDITING TVA ,

PROGRAMS, AND 4) INCREASING EMPHASIS ON CORRECTIVE ACTION AND ROOT CAUSE ANALYSIS PROGRAMS. A TVA QA MEMORANDUM DATED JUNE 16, 1987, ON QA'S REVIEW CF THE SEQUOYAH CONDITIONS ADVERSE TO QUALITY (CAQ).

REVIEW PROCESS IDENTIFIED SEVERAL DEFICIENCIES INCLUDING A LACK OF LINE MANAGEMENT INVOLVEMENT AND SUPPORT AND A LACK OF EFFECTIVE SITE QA INVOLVEMENT.

NRC RESPONSE: NRC APPROVED THE REVISED QA PROGRAM AND QA ORGANIZATION DESCRIBED IN THE REVISED QA TOPICAL REPORT IN JANUARY 1987. NRC NOTED THAT INSPECTIONS 1 WOULD BE PERFORMED TO VERIF'f PROGRAM IMPLEMENTA- i TI.CN. THE STAFF IS REVIEWING THE QA REVIEW FINDINGS AND THE TVA RECOMMENDATIONS FOR CORRECTIVE ,

ACTIONS, AND THESE WILL BE INCLUDED IN THE SCOPE OF '

THE AUGUST 1987 INSPECTION.

STATUS: PROGRAM REVIEW ONGOING. WRC INSPECTION PLANNED FOR AUGUST 10-14, 1987.

POTENTIAL SHORTCOMINGS: NONE IDENTIFIED AT THIS TIME.

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I ISSUE: INTEGRATED DESIGN INSPECTION I PROBLEM: THE STAFF HAS BEEN CLOSELY MONITORING TVA'S EFFORTS TO IDENTIFY AND PESOLVE THE MANY ISSUES THAT NEED TO BE RESOLVED PR!CR TC SEQUOYAH PESTART. ALTHOUGH THE EFFORTS HAVE BEEN QUITE EXTENSIVE, THE IDENTI-FICATION OF IGSUES HAS BEEN AN EVOLVING PROCESS AND l SOMEWHAT FRAGMENTED. ISSU'ES HAVE BEEN PAISED l REGARDING THE SIMILARITY BETWEEN SEQUOYAH AND WATTS BAR AND, THEREFORE, THE POTENTIAL FOR PROBLEMS.AT WATTS BAR TO HAVE OCCURRED AT SEQUOYAH. ALLEGA- ,

TIONS HAVE BEEN RECEIVED REGARDING SEQUOYAH'S  !

COMPLIANCE WITH ITS FINAL SAFETY ANALYSIS REPORT AND FORMER COMMISSIONER ASSELSTINE QUESTIONED HOW  !

THE STAFF KNEW WHETHER SEQUOYAH'S ORIGINAL DESIGN WAS ADEQUATE. IN EXAMINING THESE ISSUES, THE STAFF OBSERVED THAT TVA'S ENGINEERING AND DESIGN REVIEW EFFORTS TO DATE HAVE CONCENTRATED ON SEPARATE PROGRAMS LOOKING HORIZONTALLY ACROSS THE SAFETY SYSTEMS AT SEQUOYAH AND FOCUSED ON THE SPECIFIC CONCERNS RAISED. TVA'S EFFORTS HAVE NOT INCLUDED A VERTICAL REVIEW THROUGH ONE OR MORE SAFETY SYSTEMS THAT WOULD PROVIDE ADDITIONAL ASSURANCE THAT ALL MAJOR DESIGN AND CONSTRUCTION PROBLEMS HAVE BEEN i IDENTIFIED AND RESOLVED PRIOR TO SQN 2 RESTART. l TVA ACTION: TVA PROPOSED THAT ITS ENGINEERING ASSURANCE ORGANIZATION COULD CONDUCT THE DESIGN REVIEW EFFORT.

NRC RESPONSE: SINCE THE NRC STAFF CONCLUDED THAT THE TVA ENGINEERING ASSURANCE ORGANIZATION WOULD NOT l

PROVIDE ANY REAL INDEPENDENCE, THE NRC WILL CONDUCT l

A VERTICAL SLICE ON THE ESSENTI'AL RAW COOLING WATER (ERChD SYSTEM. THIS VERTICAL INSPECTION THROUGH THE ERCW WILL ADDRESS SIGNIFICANT ASPECTS OF THE INTERACTIONS.AND INTERFACES THROUGHOUT DESIGN, ENGINEERING AND CONSTRUCTION TO PROVIDE ADDITIONAL ASSURANCE THAT ALL MAJOR CHANGES AND CONSTRUCTION PROBLEMS HAVE BEEN IDENTIFIED AND RESOLVED.

STATUS: 0 KICK-OFF MEETING WITH TVA - JULY 8, 1987.

O BEGIN ONSITE ACTIVITY - JULY 27, 1987.

O EXIT MEETING - SEPTEMBER 11, 1987.

O ISSUE LETTER IDENTIFYING RESTART ISSUES -

OCTOBER 9, 1987.

O ISSUE INSPECTION REPORT - NOVEMBER 6, 1987.

POTENTIAL IF MAJOR DESIGN PROBLEMS ARE IDENTIFIED, RESTART OF SHORTCOMINGS: SEQUOYAH WOULD LIKELY BE DELAYED.

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ISSUE: DESIGN BASELINE VERIFICATION PROGRAM (DBVP) l PROBLEM: QUESTIONS WERE RAISED DURING A REVIEW C0f1 DUCTED FOR TVA BY GILBERT COMMONWEALTH IN 1985 REGARDING THE ACEQUACY CF THE EXISTING TVA DESIGN CONTROL PROCESS.

TVA ACTIONS: TVA DEVELOPED THE DESIGN EASELINE VERIFICATION PROGRAM TO REESTABLISH THE DESIGN BASELIrlE FOR THE SEQUOYAH FACILITY AS CF THE DATE OF THE OPERATING LICEfiSE. THIS PROGRAM INCLUDED: 1) ESTABLISHING THE PLANT CONFIGURATION, 2) RECONSTRUCTIt!G THE DESIGN BASIS, 3) REVIEWING AND EVALUATING MODIFI-CATIONS SINCE ISSUANCE OF THE OL, AND 4) PERFORMING REQUIRED TESTS OR MODIFICATIONS DEVELOPED FROM THIS REVIEW AND EVALUATION. THIS PROGRAM HAS INCLUDED A REVIEW 0F MODIFICATIONS MADE TO 37 SAFETY SYSTEMS AND HAS RESULTED IN APPROXIMATELY 3900 RESTART '

ITEMS THAT NEED TO BE RESOLVED. EXAMPLES OF ITEMS INCLUDE MISSING CALCULATIONS, INCOMPLETE DESIGft DOCUMENTATION, Af!D FAILURE TO UPDATE AS-EUILT 4 DRAWINGS TC REFLECT PLANT CONFIGURATION.

NRC RESPONSE: THE NRC HAS CONDUCTED A NUMBER OF INSPECTIONS OF THE DBVP PROGRAM AND HAS CONCLUDED THAT THE PROGRAM HAS ACCOMPLISHED ITS INTENDED PURPOSE.

OPEN ISSUES FROM THESE INSPECTIONS ARE CURREf!TLY BEING RESOLVED BY TVA. THE STAFF WILL PERFORM THE FINAL INSPECTION OF RESTART ACTIVITIES If! THIS PROGRAM AND ISSUE THE STAFF EVALUATION. ADDITIONAL INSPECTIONS WILL BE PERFORMED OF POST-RESTART ACTIVITIES.

! STATUS: PROGRAM ONGOING. THE STAFF SE WILL BE INCLUDED IN L THE SER ON VOLUME 2, EXPECTED TO BE ISSUED IN l SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: NONE EXPECTED i

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ISSUE: DESIGN CALCULATIONS REVIEW PP0BLEM: TVA INSTITUTED A REVIEW 0F ESSENTIAL DESIGN i CALCULATIONS TO VERIFY THAT THE CALCULATIONS  !

EXISTED AND WEPE ADECUATE TO SUPPCPT THE i DESIGN OF SEQUOYAH. AS A PESULT OF THE CALCULATION i REVIEWS, TVA DETERMINED THAT THOUSANDS OF CALCULATIONS l WERE NOT RETRIEVABLE.

TVA ACTIONS: TVA CcMPLETED AN INITIAL REVIEW 0F A SAMPLE OF i ENGINEERING CALCULATIONS IN THE ELECTRICAL, 5 NUCLEAR, MECHANICAL AND CIVIL AREAS. I ALTHOUGH NC SIGNIFICANT FROBLEMS WEPE IDENTIFIED IN THE THE NUCLEAR AND MECHANICAL ENGINEERING CALCULATIONS, 4 SIGNIFICANT PROBLEMS WERE IDENTIFIED IN THE ELECTRICAL D CIVIL AREAS. IN THE ELECTRICAL AREA, 100% OF idE CALCULATIONS WERE REVIEWED AND A NUMBER OF ISSUES CONCERNING CIRCUIT BREAKER SIZING AND CABLE SIZING WERE IDENTIFIED. THE RESOLUTION OF THESE ISSUES IS COVERED ON THE

SUMMARY

SHEETS ON ELECTRICAL ISSUES.

IN THE CIVIL AREA, ABOUT 5000 PIPE SUPPORT CALCULATIONS WERE MISSING. THE STAFF HAS REQUIRED TVA TO REGENEPATE THE MISSING CIVIL CALCULATIONS, TO THE EXTENT PRACTICABLE PRIOR TO RESTART.

l NRC RESPONSE: NRC IS REVIEWING TVA'S CALCULATIONS PROGFAM AND WILL INSPECT THE REGENERATION OF THE CALCULATIONS.

STATUS: TVA HAS PEPORTED BY LETTER DATED JUNE 12, 1987, THAT ALL ELECTRICAL CALCULATIONS MAY BE SUBJECT TO FURTHER REVISION PRIOR TO RESTART FOR THE FOLLOWING REASONS:

A) VERIFICATION OF ALL PREVIOUSLY UNVERIFIED ASSUMPTIONS, B) DELETION OF NON-CONSERVATIVE OR UNVERIFIED DESIGN CABLE LENGTHS, C) CORRECTION OF DEFICIENCIES IDENTIFIED BY DEVP, AND D) INCORPORATION  !

0F CONFIGURATION CONTROL (AS-CONSTRUCTED) DRAWINGS l l

AND APPLICABLE DBVP WALKDOWN DATA. NRC IS l AWAITING FURTHER INFORMATION FROM TVA. TVA HAS l BEGUN REGENERATION OF THE MISSING CIVIL i CALCULATIONS. I POTENTIAL l SHORTCOMINGS: 1. ELECTRICAL CALCULATIONS: STATUS UNCERTAIN PENDING THE RESOLUTION OF THE JUNE 12TH LETTER.

2. CIVIL CALCULATIONS: TVA MUST REGENERATE THE CIVIL CALCULATIONS, TO THE EXTENT PRACTICAL, BEFORE RESTART -- AN EFFORT ESTIMATED TO TAKE ABOUT FOUR MONTHS.

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ISSUE: ALTERNATELY ANALYZED PIPING / SUPPORTS

-1 PROBLEM: DEFICIENCIES WERE IDENTIFIED FCP PIPING AFD PIPING l l I EUPPORTS THAT HAD BEEN DESIGNED USING METHCDS BACED OM GUIDELINES AND CRITERIA RATHEP THAN USING A RIGOROUS ANALYSIS. j TVA ACTIONS: TVA ESTABLISHED A PIPING SUPPCRT REVIEW EFFORT l

THAT IDENTIFIED MODIFICATIONS PEQUIRED FOR RESTART. THE MODIFICATIONS HAVE BEEN CotiPLETED AND A LONG TERM REVIEW THAT WILL ASSESS GENERIC .

IMPLICATIONS FOR OTHER PIPING IS IN PROGRESS.

NRC RESPONSE: THE STAFF CONCLUDED THAT THE RESTART REVIEW CONDUCTED BY TVA WAS ACCEPTABLE. THE STAFF.IS i CURRENTLY REVIEWING THE LONG-TERM PROGRAM.

STATUS: THE EFFORT IS COMPLETE FOR RESTART. THE STAFF SE WILL BE INCLUDED IN THE SER GN VOLUME 2, EXPECTED )

TO BE ISSUED IN SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: NONE EXPECTED l

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1 ISSUE: HEAT CODE MATERIAL TRACEABILITY PROBLEM: A SPECIFIC EMPLOYEE CONCERN NOTED THAT TVA DID NOT HAVE ADEQUATE CONTROLS TO ENSURE PROPER MATERIAL l TPACEAEILITY. SPECIFICALLY, THE CONCERN STATED '

TVA INSPECTORS WERE NOT REGUIRED TO CHECK THE l MATERIAL CODE CLASSIFICATION PRIOR TO INSTALLA- l TION. AS A RESULT, SEVERAL INSTANCES WEFE i REPORTED IN WHICH CLASS C PIPE MATERIALS WERE l INSTALLED IN CLASS A APPLICATIONS. ]

TVA ACTIONS: TVA HAS PERFORMED A COMPREHENSIVE REVIEW OF THIS PROBLEM AND WILL ASSESS ALL SAFETY-RELATED 1 PIPING PRIOR TO RESTART AND DEMONSTRATE ITS ACCEPT- 2 ABILITY FOR SERVICE IN ACCORDANCE WITH ESTABLISHED l PROCEDURES OR REPLACE THE PIPING.

NRC RESPONSE: THE NRC STAFF IS MONITORING TVA'S EFFORT. AN NRC INSPECTION TO ASSESS THE SCOPE AND THE RAMIFICATIONS OF THIS ISSUE WAS CONDUCTED ON JUNE 23 THROUGH 26, 1987 AND ANOTHER INSPECTION IS SCHEDULED FCR JULY 20 THROUGH 24, 1987.

STATUS: PROGRAM REVIEW IS ONGOING. IMPLEMENTATION IS CURRENTLY BEING MONITORED. THE STAFF SE WILL BE I INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO DE l ISSUED IN SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: STAFF REVIEW 0F TVA'S APPLICATION OF ACCEPTANCE CRITERIA IS NOT COMPLETED.

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ISSUE: CABLE INSTALLATION PROELEM: A NUMBER OF EMPLOYEE CONCERNS INDICATED THAT CABLE PULLING PF.ACTICES AT SEQUOYAH VIOLATED PROCEDURES AND/0R PROCEDURES WERE NOT ADEQUATE TO ASSUPE  !

CABLE INTEGRITY FOLLOWIt!G INSTALL ATION. CABLE INSULATION DAMAGE MAY HAVE OCCURRED FROM OVER TEfJSIONING OF CABLE PULLING THROUGH CONDUIT /

PACEWAYS, CABLE PULLING THROUGH CONDUITS WITH EXISTING CABLE (PULLBYS), CABLE JAMMING AND SHORT BENDING OF THE CABLE.

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TVA ACTION: TO ENSURE THAT CABLES WERE PROPERLY INSTALLED AT  !

THE SEQUOYAH PLANT, TVA HAS UNDERTAKEN A CABLE  !

TESTING PROGRAM TO VERIFY THE INTEGRITY OF THE

• I CABLES. TVA SUBMITTED ITS CABLE TESTING PROGRAM FOR STAFF. REVIEW IN EARLY APRIL 1987 AND PROCEEDED WITH TESTING AFTER STAFF CONSULTATION. THE TESTS

' WERE IN-SITU NONDESTRUCTIVE TESTS (D.C. HIGH

' POTENTIAL) 0F REPRESENTATIVE WORST-CASE CABLES. I IN MAY, 1987, DURING THE INITIAL TESTS OF CABLES IN l

LONG VERTICAL CABLE RUNS IN ACCORDANCE WITH t IEEE-383 (1974) STANDARDS, FOUR OF 16 CABLES IN ONE CONDUIT FAILED THE TESTS. TVA THEN BEGAN A REEVALU-ATION OF THE CABLE TESTING PROGRAM AND HAS RECENTLY PROVIDED'THE OUTLINE OF A REVISED TEST PROGRAM-TO l

THE STAFF IN A MEETING HELD WITH THE STAFF ON JULY 13, 1987. TVA INTENDS TO SUBMIT A PEVISED TEST PRCGRAM IN AUGUST 1987. THIS PROGRAM IS 4 EXPECTED TO PROPOSE CHANGES.TO SEVERAL TEST PARAMETERS PREVIOUSLY AGREED TO BY NRC INCLUDING j TESTING THE CABLES AT LOWER VOLTAGES. j i

NRC RESPONSE: THE STAFF WILL REVIEW TVA'S PROPOSED TESTING I REVISIONS WHEN SUBMITTED.

STATUS: TVA SUBMITTAL EXPECTED BY AUGUST 7, 1987. STAFF l EVALUATION WILL BE COMPLETED BY SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: IF REPLACEMENT OF CABLE IS REQUIRED, THIS ISSUE COULD BECOME THE PACING ITEM FOR SEQUOYAH 2 RESTART.

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4-ISSUE: FUSE REPLACEMENT PROBLEM: THEPE WAS WIDESPREAD USE OF BUSSMAN KAZ FUSES AS PRIMARY PROTECTION FOR SAFETY-RELATED CIRCUITS AT SEQUOYAH. THIS FUSE' LACKS DOCUMENTATION THAT SHCWS IT WOULD CLEAR A FAULT BETWEEN 5 AND 15 AMPERES.

TVA ACTION: ALL FUSES WERE REPLACED BY CERTIFIED FUSES.

HOWEVER, SINCE THIS REPLACEMENT, 42 RANDOM FAILURES HAVE OCCURRED IN THE REPLACEMENT FUSES. TVA IS EVALUATING THE CAUSE OF FAILURES.

NRC RESPONSE: THE STAFF IS AWAITING TVA'S REPORT ON THE FUSE FAILURES TO ASSESS THE-ADEQUACY OF THE REPLACED FUSES.

STATUS: AWAITING TVA SUBMITTAL. THIS SUBMITTAL IS EXPECTED BY JULY 24, 1987.

POTENTIAL SHORTCOMING: THE STAFF HAS NOT REVIEWED TVA'S REPORT ON THE FUSE FAILURES. THIS ISSUE MAY AFFECT PLANT RESTART.

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i ISSUE: AMPACITY J PROBLEM: AN INPO FINDING ON THE BELLEFONTE PLANT IDENTIFIED THE LACK OF DESIGN CALCULATIONS TO SUPPORT THE ADEQUACY OF At1PACITY FATINGS OF CABLES. THIS FINDING WAS FOUND TO BE APPLICABLE TO SEOUOYAH. >

TVA REDID THE CALCULATIONS, LOWERED THE RATED 'l TVA ACTION: I CAPACITY OF SOME CABLES AND PEPLACED SOME CABLES, 1 THE DESIGN TABLES HAVE BEEN REVISED TO REFLECT THE l CORRECT, MORE CONSERVATIVE, VALUES FOR AMPACITY. l NRC ACTION: STAFF AGREED WITH THE NEW AMPACITY VALUES AND THE HARDWARE CHANGES.

STATUS: REVIEW COMPLETED. THE STAFF'S SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUED IN SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: NONE EXPECTED.

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ISSUE: FIRE PROTECTION PROBLEM: BOTH NRC AND TVA REVIEWS IDENTIFIED SIGNIFICANT VIOLATIONS OF 10 CFR 50, APPENDIX R.

TVA ACTION:~ THIPTY-NINE SIGNIFICANT. MODIFICATIONS'HAVE BEEN IMPLEMENTED. MINOR MODIFICATIONS REMAIN.AND WILL BE IMPLEMENTED ON A SCHEDULE APPROVED BY THE NRC STAFF. TWENTY-TWO EXEMPTIONS FROM. APPENDIX R REQUIREMENTS WERE REQUESTED BY TVA,-AND 20 WERE APPROVED BY NRC. THE REMAINING 2 EXEMPTION REQUESTS WERE' WITHDRAWN. INSTALLATION 0F'AN AUTOMATICALLY ACTUATING SPRAY SYSTEM IN THE THE 480 VOLT SHUTDOWN BOARD. ROOMS IS THE ONLY RESTART MODIFICATION ITEM NOT. COMPLETE AS OF JUNE 22-26, 1987. HOWEVER, MANUAL ACTUATION 0F THE SPRAY SYSTEM IS POSSIBLE, AND A FIRE WATCH IS'BEING MAINTAINED. SEQUOYAH, COMPARED.WITH OTHER PLANTS, NOW HAS AN ABOVE AVERAGE PROGRAM.

NRC RESPONSE: NRC INSPECTIONS SHOW THAT THE TVA CORRECTION OF APPENDIX R DEFICIENCIES IS ACCEPTABLE.

STATUS: THIS ITEM IS ESSENTIALLY COMPLETE FOR RESTART.

IMPLEMENTATION CURRENTLY BEING MONITORED. THE; STAFF SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUE,D IN SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: NONE EXPECTED i

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ISSUE:. . ENVIRONMENTAL QUALIFICATION (EQ)

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PROBLEM: THE SEQUOYAH PLANT WAS SHUT DOWN IN AUGUST 1985' BECAUSE INSUFFICIENT COCUMENTATICN EXISTED TO DEMONSTRATE-THAT ELECTRICAL EQUIPMENT AT THE FLANT.

WAS ENVIRONMENTALLY CUALIFIED AS-F.EQUIRED BY 10 CFR 50.49.

TVA ACTION:. TVA DEVELOPED AN EC PROGRAM TO IDENTIFY EQUIPMENT, i SPECIFY ENVIRONMENTS, VERIFY EQUIPMENT IN THE-FIELD, DOCUMENT QUALIFICATION, SPECIFY MAINTENANCE REQUIREMENTS, MAINTAIN EQ BINDERS, AND REPLACE UNQUALIFIED EQUIPMENT IF NECESSARY. THE DOCUMEN-TATION-DEMONSTRATING COMPLIANCE IS COMPLETE AND ANY REQUIRED MODIFICATIONS WILL BE COMPLETED BEFORE RESTART.

NRC RESPONSE: THE STAFF HAS BEEN REVIEWING'TVA'S EQ EFFORT FOR THE PAST YEAR. INSPECTIONS ENTAILING OVER 1300 MAN HOURS OF EFFORT AT THE SEQUCYAH SITE HAVE BEEN COMPLETED TO DATE AND HAVE INCLUDED A 100% LOOK AT THE EQ BINDERS AT SEQUOYAH. PR0 GRAMMATICALLY THE STAFF HAS FOUND THAT THE EQ PROGRAM AT SEQUOYAH IS NOW ONE OF THE BETTER PROGRAMS IN THE NUCLEAR POWER INDUSTRY.

STATUS: LICENSEE EFFORT COMPLETE. ONE ADDITIONAL FOLLOW-ON INSPECTION-IS SCHEDULED TO BE COMPLETED IN EARLY-AUGUST. THIS SHOULD COMPLETE ALL' STAFF EFFORTS ON THIS ISSUE. IHE STAFF SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUED'IN SEPTEMBER 1987. -

POTENTIAL SHORTCOMINGS: NONE EXPECTED.

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ISSUE: WELDING- l PROBLEM: CONCERNS WERE RAISED AT THE WATTS BAR SITE REGARDING TVA's INSPECTION PRACTICE AND WELDING i FCD CONTROL PRCGPAM. THESE CONCERNC IMPLICATED I THE QUALITY OF WELDMENTS AND THE ABILITY OF THE

'r' ELDS' TO PERF0PM THEIR FUNCTION.

TVA ACTION: TVA CONDUCTED A REASSESSMENT PROGRAM WHICH CONSISTED OF TWO PARTS: (1) PROGRAMMATIC REVIEW I 0F COMMITMENTS AND PROCEDURES FOR IMPLEMENTING THE COMMITMENTS, AND (2) PHYSICAL REINSPECTION OF SAMPLE WELDS.

NRC RESPONSE: THE NRC STAFF APP' ROVED THE REASSESSMENT PROGRAM AND CONDUCTED SEVERAL INDEPENDENT INSPECTIONS TO ASSURE THE ADEQUACY OF TVA'S CORRECTIVE ACTIONS IN TERMS OF BOTH THE WELDING PROGRAM AND THE SITE HARDWAPE.

STATUS: THE STAFF IS PREPARING AN SE INCLUDING TVA'S COMMITMENTS IN THE WELDING AREA. IT IS COMPLETING ITS REVIEW OF TVA'S FINAL EMPLOYEE CONCERN PROGRAM ELEMENT REPORTS ON SEQUOYAH WELDING CONCERNS AND PREPARING SES ON THESE REPORTS. THE STAFF SE ON WELDING WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUED IN SEPTEMBER 1987.  ;

POTENTIAL SHORTCOMINGS: NONE EXPECTED l

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ISSUE: TECHNICAL SPECIFICATIONS PROBLEM: TVA HAS IDENTIFIED 4 TECHNICAL SPECIFICATION (TS)

CHANGES REQUIPING APPPOVAL BY THE NRC SEFORE SEQUCYAH CAN ENTER MODES 4, 3 OP 2. ThESE CHANGES l INVOLVE SURVEILLANCE FEGUIREMENTS FOP STEAM ,

GENERATOR BLCWDOWN AND THE CONDENSATE DEMINERALIZED, i REFERENCES TO MOTOR OPEPATED VALVES, PLANT STAFF ORGANIZATION, AND CONTAINMENT SPRAY RESPONSE TIMES.

TVA ACTIONS: TVA HAS SUBMITTED ALL FOUR TECHNICAL SPECIFICATION CHANGES TO THE STAFF.

NRC RESPONSE: THE FOUR RESTART TECHNICAL SPECIFICATION AMEND-MENTS ARE UNDER STAFF REVIEW. ADDITIONAL CLARIFYING INFORMATION MAY BE REQUIRED. ALL i FOUR AMENDMENTS HAVE BEEN NOTICED IN THE FEDERAL I REGISTER. ]

STATUS: REVIEW EFFORT IN PROGRESS. THE STAFF EXPECTS TO ISSUE THE FOUP RESTART TECHNICAL SPECIFICATION CHANGES IN AUGUST 1987.

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e ISSUE: NUREG-1150 PROBLEM: IN THE DPAFT OF NUREG-1150, REACTOR RISK REFERENCE DOCUMENT, WHICH WAS ISSUED FOR PUBLIC COMMENT IN FEBRUARY 1987, SECUOYAH WAS SHOWN TO BE AM CUTLIER IN TERMS OF RISK WHEN COMPARED WITH OTHER PLANTS.

TVA ACTION: TVA HIRED WESTINGHOUSE TO PERFORM AN INDIVIDUAL y PLANT EVALUATION (IPE) FOR SEQUOYAH WHICH )

CONCLUDED THAT THE RESULTING PISK IS LOWER THAN THAT SHOWN IN NUREG-1150 BY A FACTOR OF 2 TO 3.

THE IPE WAS BASED ON A NUMBER OF DIFFERENT ASSUMPTIONS THAN THOSE USED IN NUREG-1150.

NRC RESPONSE: THE OFFICE OF RESEARCH IS SPONSORING ADDITIONAL I ANALYSES OF NUREG-1150 AND THE IPE ALONG WITH DATA ON OTHER PLANTS COVERED IN NUREG-1150. PUBLIC COMMENTS HAVE BEEN SOLICITED ON THE DRAFT NUREG-1150 AND ARE DUE BY THE END OF AUGUST 1987.

STATUS: OFFICE OF RESEARCH WILL CCMPLETE ITS REVIEWS OF COMMENTS AND ADDITIONAL ANALYSES ON NUREG-1150 BY JULY.1988.

RES WILL PROVIDE AN ANALYSIS OF THE SON IPE BY JULY 31, 1987.

POTENTIAL SHORTCOMINGS: DEPENDING ON NRC'S DECISION ON THE USE OF THE SEQUOYAH IPE, TVA MAY HAVE TO DO ADDITIONAL WORK.

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ISSUE: HYDROGEN ANALYZER OPERABILITY PROBLEM: A RECENT INSPECTION IDENTIFIED THAT THE ANALYZER  !

PIPING MAY HAVE BEEN INSTALLED INCORRECTLY. THE i SYSTEM IS NOT CONSIDERED GPEFABLE AND IS NEEDED FOR CRITICALITY (MODE 2).

TVA ACTION:- TVA MUST SUBMIT ANALYSES OF THE HYDROGEN ANALYZER PIPING INSTALLATION, NRC. RESPONSE: THE STAFF IS REVIEWING THE DESIGN AND INSTALLATION OF'THIS SYSTEM AND WILL REVIEW TVA'S ANALYSES WHEN 4 THEY ARE SUBMITTED. .'y ( )

STATUS: AWAITING ANALYSIS FROM TVA, POTENTIAL 1 SHORTCOMINGS: COMPLETION OF STAFF SE ON THE HYDROGEN ANALYZER MAY REQUIRE A NEW APPROACH BY TVA. THIS MAY AFFECT THE SCHEDULE FOR HEATUP BECAUSE IF'A MODIFICATION-TO l THE SYSTEM IS REQUIRED, IT COULD AFFECT CONTAINMENT INTEGRITY REQUIRED.FOR MODE 4.

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TVA ACTION: TVA HAS UNDERTAKEN AN EXTENSIVE PROGPAM TO REVIEW AND EVALUATE PAST AND PRESENT PROCUREMENT OF REPLACEMENT ITEMS TO IDENTIFY THOSE REPLACEMENTS THAT REQUIRE ADDITIONAL QUALIFICATION FOR USE IN SAFETY-RELATED APPLICATIONS. TVA'S REPLACEMENT PARTS PROGRAM, INCLUDING DETAILED IMPLEMENTING PROCEDURES, HAS BEEN SUBMITTED FOR STAFF REVIEW.

TVA IS ESTABLISHING QUALIFICATION OF ITEMS OR '

REPLACING ITEMS ON EQUIPMENT REQUIRED FOR RESTART ON A PRIORITY BASIS.

NRC RESPONSE: TVA PROGRAMMATIC APPROACH IS ACCEPTABLE TO THE STAFF. DETAILED IMPLEMENTIf!G PROCEDURES APE I PRESENTLY UNDER STAFF REVIEW. INSPECTION OF THE I PROGRAM'S IMPLEMENTATION IS SCHEDULED FOR JULY 1987. )

i STATUS: PROGRAM REVIEW IN PROGRESS. THE ST/5F SE -W!LL SE i INCLUDED IN THE SER ON VOLUME 2,xEXPdCTED TO BE ISSUED IN SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: NONE EXPECTED 3

• l ISSUE: MAINTENANCE PROBLEM: PROGRAMMATIC PROBLEMS Ill SITE MAINTErlANCE WERE PREVIOUSLY IDENTIFIED IN SALP AND INSPECTION  ;

REPORTS, THESE FFCBLEMS WEFE ATTRIBUTED TO l

1) MANAGEMENT PROBLEMS I!! THE DEVELOPMENT AND ADMINISTRATION OF CONTROLS ON MAINTENAIJCE ACTIVITIES AND 2) THE FAILURE TO IMPLEMEfT EFFECTIVE AND T*MELY CORRECTIVE ACTIONS WHEN PROBLEMS WERE IDENTIFIED.

TVA ACTION: TVA IS IMPLEMENTING CORRECTIVE ACTIONS DESCRIBED IN ITS CORPORATE AtJD SEQUOYAH NUCLEAR PERFORMANCE PLANS INCLUDING 1) ESTABLISHING A CORPORATE NUCLEAR MAINTENANCE MANAGER, 2) IMPROVING COMMUNICATIONS BETWEEN CRAFT PERSONNEL AND MANAGEMENT, 3) ESTAB-  !

LISHING JOB ACCOUNTABILITY AT THE CRAFT AND MANAGER l LEVELS, 4) ESTABLISHING A NEW MAINTENANCE REQUEST  !

SYSTEM, 5) INCREASING STAFFING OF MAINTENANCE  ;

PLANNERS AND ADDING AN SRO TO COORDINATE ACTIVI- I TIES, 6) DEVELOPING A LONG TERM PROGRAM TO IMPPOVE MAINTENANCE PROCFDURES, 7) IfiPROVING THE PPEVENTIVE

MAINTENANCE PROGFAM, AND 8) It'PLEMENTING TRACKING AND TRENDING FOR FUTURE COMPONENT FAILURES AND OUT-OF-CALIBRATION CONDITIONS.

NRC RESPONSE: THE NRC HAS INSPECTED THE MAINTENANCE PROGRAM IMPROVEMENTS BElflG IMPLEMENTED BY TVA AND HAS 1 CONCLUDED THAT THE MAINTENANCE PROGRAM IS ACCEPTABLE, i NRC WILL CONTINUE TO MONITOR IMPLEMENTATION OF THIS i PROGRAM.

STATUS: PROGRAM ONGOING. IMPLEMENTATION IS CURRENTLY BEING i MONITORED. THE STAFF SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUED IN SEPTEMBER I 1987.

POTENTIAL SHORTCOMIMCS: NONE EXPECTED, l

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ISSUE: POST MODIFICATION TESTING  !

PROBLEM: INSPECTIONS CONDUCTED IN 1986 DETERMINED THAT I TVA HAS COMPLETED NUMEROUS MODIFICATIONS AT I SEQUOYAH SINCE THE PLANT WAS LICENSED AND, IN I MANY CASES, THIS WORK WAS NOT ADEQUATELY TESTED.

I TVA ACTION: TVA HAS COMPLETED A REVIEW OF ALL POST-LICENSE l MODIFICATION TESTS ASSOCIATED WITH THE 37 SYSTEMS IN DBVP PHASE I AND IDENTIFIED APPROXIMATELY I 100 TESTS REQUIRING RE-PERFORMANCE. TVA IS IN THE  !

) PROCESS OF RE-PERFORMING THESE TESTS. TVA HAS I INITIATED ACTION TO ENSURE THAT THE SYSTEM  !

ENGINEERING GROUP CONCURS WITH ALL SPECIFIED TESTS J TO ASSURE ADEQUATE TEST PROCEDURES ARE USED.

NRC RESPONSE: THE STAFF IS REVIEWING TVA'S TEST REVIEW RESULTS. j INITIAL OBSERVATIONS INDICATE THAT TVA PERFORMED j AN ADEQUATE REVIEW IN DETERMINING TEST  !

REQUIREMENTS. HOWEVER, OBSERVATION OF SELECTED i TESTS INDICATES PROBLEMS WITH PROCEDURE j COMPLIANCE AND WITH THE ADEQUACY OF THE TEST PROCEDURES AND INSTRUCTIONS. THE STAFF HAS A CONCERN THAT THIS MAY BE INDICATIVE OF INADEGUATE OVERALL TEST. CONTROL, TEST PERFORMANCE OVERSIGHT, 1

'AND TRAINING. THIS WAS DISCUSSED IN AN ENFORCEMENT  !

l CONFERENCE WITH IVA AND LICENSEE CORRECTIVE ACTIONS ARE BEING MONITORED BY THE STAFF.

STATUS: PROGRAM' REVIEW IS ONGOING. IMPLEMENTATION IS 1 CURRENTLY"BEING MONITORED. THE STAFF SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE I ISSUED IN SEPTEMBER'1987. ,

l POTENTIAL CORRECTIVE ACTIONS MAY NEED TO BE AUGMENTED AFTER SHORTCOMINGS: FURTHER STAFF REVIEW AND OBSERVATION OF TVA ,

PERFORMANCE.

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ISSUE: RESTART TEST PROGRAM i PROBLEMS: IN RESPONSE TO ALL OF THE PROGRAMS UNDER WAY'SINCE THE SHUTDOWN OF THE SECUOYAH PLANT, A COMPREHEf!S VE RESTART TEST PP0 GRAM IS FEGUIRED TO ENSURE THAT THE PLANT SAFETY SYSTEMS ARE FUNCTIONAL BEFCRE PESTART OF SEQUOYAH, TVA ACTION: A START-UP TESTING PROGRAM IS BEING DEVELOPED WHICH INCLUDES INTEGRATED SYSTEM TESTING, AS WELL AS HEAT-UP, CRITICALITY, AND POWER ESCALATION TESTING.

THIS PROGRAM WILL INCORPORATE THE RESULTS OF THE POST MODIFICATION REVIEW AND OTHER SEQUOYAH SURVEILLANCE AND TEST. PROGRAMS TO PRODUCE A COMPPE-HENSIVE SET OF TEST. REQUIREMENTS. A

SUMMARY

DESCRIPTION OF THE PROGRAM AND A LISTING AND SCHEDlLE OF REQUIRED TESTING IDENTIFIED BY THIS PROGRAM WERE SUBMITTED ON MAY 26 AND JULY 6, 1987, RESPECTIVELY. '

NRC RESPONSE: INSPECTIONS HAVE BEE!4 CONDUCTED ON THIS PROGPAM.

THE STAFF IS IN GENERAL AGREEMENT WITH THE TVA PROGRAM. AN ADDITIONAL INSPECTION IS SCHEDULE" FOR LATE JULY 1987.

STATUS: PRCSRAM REVIEW ONGOING AND TVA HAS NOT COMPLETED ALL THE DETAILED TEST PROCEDURES. .THE SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUED IN SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: THE STAFF'S REVIEW NEEDS TO BE COMPLETED PRIOR TO START OF TESTING CURRENTLY SCHEDULED FOR AUGUST 1987. J i

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.7

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. 1 ISSUE: SURVEILLANCE INSTRUCTIONS (SIS)

PROBLEM: AN NRC INSPECTION DETERMINED THAT A NUMBER OF SURVEILLANCE INSTRUCTIONS WERE INADEQUATE.

TVA ACTION: TVA IMPLEMENTED A SPECIAL SI REVIEW AFD REVISION PROGRAM TC ENSURE THAT TECHNICAL SPECIFICATION (TS) SURVEILLANCE REQUIREMENTS ARE i SEING MET, AND THAT SIS CAN BE PERFORMED AS l

WRITTEN. THIS PROGRAM INCLUDED A REVIEW OF EACH SURVEILLANCE INSTRUCTION FOR TECHNICAL CONTENT, ,

SCOPE, AND VERIFICATION THAT THE INSTRUCTION CAN BE  !

PROPERLY FOLLOWED.

NRC RESPONSE: THE NRC STAFF HAS EVALUATED TVA'S SI REVIEW AND  ;

REVISION PROGRAM AND-CONCLUDED THAT THE PROGRAM IS  ;

ACCEPTABLE. INSPECTIONS OF PROGRAM IMPLEMENTATION NERE COMPLETED IM JUNE AND JULY 1987. THE RESULTS  ;

0F THE INSPECTIONS WERE ACCEPTABLE.

]

STATUS: COMPLETE. IMPLEMENTATION CURRENTLY BEING MONITORED. THE STAFF SE WILL BE INCLUDED IN THE SER ON VOLUME 2, EXPECTED TO BE ISSUED IN SEPTEMBER 1987.

POTENTIAL SHORTCOMINGS: NONE EXPECTED.

I

ISSUE: DETAILED CONTROL ROOM DESIGN REVIEW (DCRDR)

PROBLEM: AS PART OF GENERIC CONTROL ROOM PEVIEW, EVALUATE WHETHER CONTROL ROOM DESIGN REQUIREMENTS IN SUPPLEMENT 1 TO NUREG-0737 HAVE BEEN SATISFIED.

TVA ACTIONS: TVA HAS IMPLEMENTED A CONTROL ROOM REVIEW PROGRAM AT SEQUOYAH IN RESPONSE TO THE REQUIREMENTS OF NUREG-0737. NO REMAINING PLANT MODIFICATIONS NEED TO BE MADE BEFORE RESTART. HOWEVER, TWO DOCUMEPTS ON CONTROL ROOM DESIGN NEED TO BE SUBMITTED BY TVA (1) A LETTER PRIOR TO RESTART DETAILING ACTIVITIES ON HUMAN ENGINEERING DEFICIENCY (HED) 0220 AND (2) A SUPPLEMENT TO THE

SUMMARY

REPORT FOR SEQUOYAH UNITS 1 AND 2 INCLUDING A SCHEDULE FOR COMPLETING THE REMAINING SEQUOYAH HEDS AFTER RESTART.

NRC RESPONSE: IF THE TVA RESTART SUBMITTAL IS SATISFACTORY, THE STAFF CAN CONCLUDE THAT TVA'S CONTPOL ROOM DESIGN REVIEW PROGRAM IS ACCEPTABLE.

STATUS: AWAITING RESTART SUBMITTAL FROM TVA. THE NRC WILL ISSUE THE SE WITH CONFIRMATORY ITEMS CONCERNING THE SCHEDULE FOR THE REMAINING HEDS IN AUGUST 1987. 1 POTENTIAL SHORTCOMING: NOME EXPECTED, '

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I ISSUE: OPERATIONAL READINESS )

PROBLEM ACTIONS ARE RECUIRED TO ASSURE THAT THE SEQUOYAH I PLANT PERSONNEL ARE READY FOR PLANT RESTART. IN l CONNECTION WITH TPIS, TVA AND NRC MANAGEMENT ATTENTION HAVE BEEN CONCENTRATED ON SEVERAL PERSONNEL ERRORS ASSOCIATED WITH RECENT OPERATIONAL AND TESTING EVENTS.

TVA ACTION: TVA HAS ESTABLISHED GENERAL GUIDANCE FOR i OPERATIONAL READINESS VERIFICATION AND HAS CON-DUCTED AN INTERIM OPERATIONAL REVIEW. ADMIRAL WHITE HAS COMMENCED A SERIES OF MEETINGS WITH PLANT PERSONNEL AIMED AT DETERMINING THE ROOT CAUSE OF PERSONNEL ERRORS.

NRC RESPONSE: NRC WILL INDEPENDENTLY ASSESS TVA'S READINESS FOR RESTART. WITH FESPECT TO RECENT EVENTS, NRC HAS i IDENTIFIED SEVERAL EXAMPLES OF FAILURE TO FOLLOW ,

PROCEDURES, INADEQUATE PROCEDURES, AND AN OVERALL l

LACK' 0F CONTROL OVER TESTING EVOLUTIONS INCLUDI!!G SYSTEM AND EQUIPMENT STATUS. AN ENFORCEMENT CONFERENCE WAS HELD WITH TVA MANAGEMENT ON JUNE 18, 1987. THE NEED FOR ESCALATED ENFORCEMENT ACTION AND TVA'S CORRECTIVE MEASURES ARE CURRENTLY UNDER STAFF REVIEW. l STATUS: EFFORTS ONGOING POTENTIAL ,

^

SHORTCOMINGS: CONTINUED PERSONNEL ERRORS COULD IMPACT ON TVA'e  !

I

' AND/OR NRC'S DECISICN REGARDING READINESS FOR I RESTART.

A u___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ - _ - - .

'l ISSUE: EMPLOYEE CONCERNS (EC) PROGRAM PROBLEM: UNDER THE EMPLOYEE CONCEPNS PROGRAMS INITIATED AT WATTS BAR IN 1985 MORE THAN 5000 EMPLOYEE CONCERNS WERE IDENTIFIED, APPROXIMATELY 1100 SAFETY AND NON-SAFETY CONCERNS IDENTIFIED IN THE ORIGINAL EMPLOYEE CONCERN PRCGRAM WERE APPLICABLE TO SEQUOYAH BY DIRECT REFERENCE OP GENERIC APPLICABILITY.

TVA RESPONSE: TVA HAS DIVIDED THE CONCERNS INTO 9 CATEGORIES:

CONSTRUCTION, ENGINEERING, OPERATIONS, MATERIALS I CONTROL, WELDING, QUALITY ASSURANCE, INDUSTRIAL I SAFETY, MANAGEMENT AND PERSONNEL, AND HARASSMENT )

AND INTIMIDATION (H&I). TVA HAS SUBMITTED 317 '

ELEMENT REPORTS DOCUMENTING Ils INVESTIGATIONS AND '

CORRECTIVE ACTIONS FOP SEQUOYAH FOR 6 0F THE CATEGORIES. NO SAFETY-RELATED CONCERNS WERE IDENTIFIED IN THE INDUSTRIAL SAFETY.AND MANAGEMENT AND PERSONNEL CATEGORIES. Hal CONCERNS ARE BEING ADDRESSED SEPARATELY BY THE TVA INSFECTOP GENERAL.

OF 317 REPORTS 56 REQUIRE COMPLETION OF COPRECTIVE ACTIONS BEFORE PLANT RESTART.

CONCERNS IDENTIFIED IN THE NEW EMPLOYEE CONCERN PF0 GRAM WHICH WAS INITIATED ON FEBRUARY 1, 1986 HAVE BEEN i

INVESTIGATED AND RESOLVED SEPARATELY.

NRC RESPONSE: THE STAFF HAS REVIEWED THE ORIGINAL EMPLOYEE CONCERNS I PROGRAM AND HAS CONCLUDED THAT THE PROGRAM IS ACCEPTABLE, '

l THE ELEMENT REPORTS ARE CURRENTLY BEING REVIEWED BY

! THE STAFF. APPROXIMATELY 15% OF THE ELEMENT REPORT  ;

REVIEWS ARE COMPLETE. OF THE 317 ELEMENT REPORTS, l 251 REPORTS ARE REQUIRED TO BE REVIEWED FOR RESTART. I i THE NEW EMPLOYEE CONCERNS PROGRAM IS STILL UNDER I REVIEW, STATUS: ALL THE RESTART ELEMENT REPORT EVALUATIONS ARE EXPECTED TO BE COMPLETED BY THE END OF AUGUST 1987.

STAFF REVIEW 0F THE NEW PROGRAM SHOULD BE COMPLETED l BY THE END OF JULY.

l P0TENTIAL SHORTCOMINGS: RESOLUTION OF THE RESTART ELEMENT REPORTS MAY REQUIPE TVA TO DO ADDITIONAL WORK PRIOR TO RESTART.

d l l 4

. I ISSUE: ALLEGATIONS I

PROBLEM: A MUMBER OF ALLEGATIONS OF SAFETY PROBLEMS AT TVA HAVE BEEN MADE-DIRECTLY TO THE' STAFF IN LIEU OF BEING PROVIDED TO TVA UNDEP THE EMPLOYEE C0tlCERtiS '

PP0 GRAM 155 SEQUOYAH AND TVA GENERIC ALLEGATIONS ARE UNDER REVIEW BY THE STAFF. THE STAFF HAS REVIEWED 107 0F THESE ALLEGATIONS AND HAS DETERtdINED THAT 102 NEED TO BE RESOLVED BEFORE SEQUOYAH RESTART. ,

TVA ACTION: It! A NUMBER OF INSTANCES, THE TECHNICAL CONTENT OF THE ALLEGATION HAS BEEN PROVIDED TO TVA FOR ITS l REVIEW AND RESPONSE ~TO THE NRC. TVA HAS THEN .I ENTERED THE ALLEGATION INTO ITS EMPLOYEE CONCERN PROGRAM.-

NRC RESPONSE: THE STAFF WILL REVIEW THE REMAINING 48 SEQUOYAH AtlD TVA GENERIC ALLEGATIONS TO DETERMINE THEIR-

) '

SEQUOYAH RESTART STATUS AND WILL ASSIGN THE RESTAPT ALLEGATI0flS TO THE APPROPRIATE TECHNICAL REVIEWERS AND DEVELOP SCHEDULES FOR THEIR RESOLUTION.. THE-NRC STAFF WILL REQUIRE THAT ALL POTENTIALLY SAFETY SIGNIFICANT SEQUOYAH-RELATED ALLEGATIONS BE RESOLVED j BEFORE THE RESTART OF SEQUOYAH. q l

STATUS: THE STAFF REVIEW IS ONGOING. THE STAFF WILL I COMPLETE ITS EVALUATI0ft OF THE SEQUOYAH RESTART ALLEGATIONS BY OCTOBER 1987.

POTENTIAL l SHORTCOMINGS: RESOLUTION OF THE RESTART ALLEGATIONS MAY REQUIRE I TVA TO DO ADDITIONAL WORK PRIOR TO RESTART.

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+ ENCLOSURE 3

- Revision 1 l

RESTART REQUIREMENT CRITERIA l The following criteria shall be used in evaluating whether a particular item must be resolved prior to restart of unit 2 at Sequoyah.

1. The item identifies a specific deficiency which has significant probability of leading to the inoperability of a system required for restart or operation by the appropriate technical specifications.

2. The item identifies a programmatic deficiency which has a high probability of causing or has caused a specific deficiency which meets No. I above.

NOTE: To assist in the determination of required for restart  !

relative to technical specifications as in criteria No. I and No. 2 above, an affirmative answer to any of the following questions requires consideration of the item for restart based on technical specification requirements.

a. Does the item directly and adversely affect  ;

safety-related equipment function, performance. l I reliability, or response time) i

b. Does the item indirectly and adversely affect safety-related equipment power supply, air supply, cooling, lubrication. or ventilation?

]

c. Does the item adversely affect primary containment l Integrity?

d. Does the item adversely affect secondary containment integrity?

e. Does the item adversely affect ccintrol room-habitability?

f. Does the item adversely affect systems used to process radioactive waste?

g. Does the item adversely affect fire protection or fire loads?

h. Does the item adversely affect the ability of a system l

or component to meet its safety function during a l design basis event by impacting the seismic analysis, I

single failure criteria, separation criteria, high l energy line break assumptions, or equipment qualification?

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Ravision 1

1. 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 affected?

j. If not corrected prior to restart, could it lead to an uncontrolled release or spread of radioactive  ;

contamination beyond the regulated area?

3. The item identifies a specific deficiency that results in a j failure to comply with NRC regulations'and no variance has j been approved by the NRC.

4. TVA has committed to the NRC to complete the item prior to restart. -

5. The item identifies a specific deficiency which has a significant probability of leading to a personal injury during plant operation.

6. The item identifies a specific condition which has a forced outage risk (probability X outage length) during the next cycle in excess of the critical path time to correct the condition prior to restart. .

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, IV-5

c.am. . 4

, O3P'c SEO.UOYAH RESTART ACTIVITIES SCHEDULE

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