ML20147H929

Safety Evaluation Supporting Nuclear Safety Review Staff Recommendations Requiring Resolution Before Restart of Facility

ML20147H929
Person / Time
Site:	Sequoyah
Issue date:	03/02/1988
From:	NRC OFFICE OF SPECIAL PROJECTS
To:
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ML20147H911	List: ML20147H907 ML20147H929
References
NUDOCS 8803090115
Download: ML20147H929 (11)

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g UNITED STATES y p, NUCLEAR REGULATORY COMMISSION ie 5 -l WASHINGTON, D. C. 2u555 SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS l RESTART NUCLEAR SAFETY AND REVIEW STAFF RECOMMENDATIONS i

l TENNESSEE VALLEY AUTHORITY -

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2

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! DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

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The Nuclear Safety Review Sta'f (NSRS) of the Tennessee Valley Authority (TVA)

I issued safety reports between October 1979 and February 1986 when it was disbanded. These reports described the results of internal TVA evaluations of

, the performance of TVA organizations in the TVA nuclear program. Of these reports, 63 reports were either related to the Sequoyah units or to organizations

which controlled activities at the units.

I l These NSRS reports contained recomendations to the TVA line organizations i for actions to be taken to address NSRS identified safety problems. Those NSRS

} recommendations which were not addressed by TVA and closed out by NSRS before

) it was disbanded were addressed by TVA through its Nuclear Management Review i

Group (NMRG) or its Employee Concern Task Group (ECTG). These are the open l NSRS recomendations being addressed for Sequoyah in this evaluation.

2.0 BACKGROUND

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! As stated in TVA's letters dated October 27, 1986 and June 16, 1987, there are

158 open NSRS recomendations which were not closed out at the time the NSRS

! was disbanded. Of these, 97 werd determined to be related directly or

, generically to Sequoyah. The other open NSRS recomendations are related to l TVA nuclear plants other than Sequoyah. For the 97 open NSRS recommendations related to Sequoyah, 27 are considered restart items needed to be resolved before the restart of Sequoyah Unit 2 and 70 are considered non-restart items I that may be resolved after the restart of Unit 2. This evaluation a<tdresses the 27 restart NSRS recomendations and the acceptability of the 70 non-restart j NSRS recomendations being classified as non-restart. The evaluation of the 70 )

non-restart NSRS recomendations will be the subject of a separate letter.  ;

a TVA issued three reports which addressed the 27 open NSRS recommendations  !

that TVA considered restart items for Sequoyah. These reports are NMRG No. R-86-02-NPS, ECTG-NSRS-01 Revision 2, and ECTG-NSRS-02, Revision 1, which ,

were submitted in letters dated December 17, 1986 and January 30 and January  !

16, 1987, respectively. The NMRG report addressed two open restart "SRS recomendations and the ECTG reports addressed the remaining 25 open restart NSRS recomendations. The latter ECTG report also identified 69 (of the 70) open non-restart NSRS recommendations which may be resolved after the restart l of Sequoyah, i l

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I' I The staff evaluated the above two ECTG reports and issued its evaluation in its

!* letter dated August 27, 198 . The criteria used to determine if an NSRS recom-mendation was a restart iten was that approved in the staff's letter dated

! June 9, 1987. The staff ccncluded that (1) the NSRS recomendations considered t to be non-restart items for Sequoyah were acceptable and (2) the corrective

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actions described by TVA 11 the two reports (ECTG-NSRS-01 and ECTG-NSRS-02)

I were adequate to address tie 25 open restart NSRS recorsnendations. In the ,

staff's letter, TVA was requested to submit the details of the corrective

!. actions taken. This was to allow the staff to review thase details before the

! restart of Sequoyah.

t f In response to the staff's letter of August 27, 1987, TVA provided the details

of its cocreutive actions for the 25 open restart NSRS recommendations from the two ECTG reports. TVA provided the details in its reports SQN-NSRS-1, Revision 3, and SON-NSRS-2, Revision 2. These were submitted by letter dated October 5, 1987. In this letter, TVA also provided the report SQN-NSRS-3 which

, addressed 70 non-restart NSRS recorvnendations. This latter report included the remaining one (of the 70) non-restart NSRS recorrnendation which had not I been provided to the staff in report ECTG-NSRS-02 Revision 2.

t i This evaluation addresses the detailed corrective actions provided by TVA in j its letters dated December 17, 1986 and October 5, 1987 on the 27 open restart '

NSRS recomendations. It also evaluates the conclusion by TVA that the additional non-restart open NSRS recomendation listed in report SQN-NSRS-3 j is non-restart.

3.0 EVALUATION

! The enclosed table lists the 27 open restart NSRS recomendations for Sequoyah. l l The table provides TVA's resolution for Sequoyah, the status of this resolution '

and the staff's evaluation of this resolution. The TVA resolution for Sequoyah

! is one of the following: (1) a TVA progran discusssed in the Sequoyah Nuclear l Perfornance Plan, such as the Design Baseline Verification Program, (2) an ECTG element report generated by the TVA Special Employee Concern Pr.ogram, (3) a Sequoyah or TVA corporate procedure or instructions which was generated,

! reviewed or revised, or (4) modifications which were done at Sequoyah. The staff evaluated each resolution to determine if it acceptably addresses the i recomenda tion.

Based on its review, the staff concludes that the TVA resolutions are accept-  !

able as a means to address the restart NSRS recomendations. Where the staff has verified that the NSRS recomendation is being acceptably addressed in the specific TVA resolution for Sequoyah, the staff has concluded in the enclosed table that the TVA resolution is acceptable and verified. Where the staff concludes the TVA resolution is acceptable but has not been able to review the specific procedure, instruction or modification, the staff has only concluded in the enclosed table that the TVA resolution is acceptable but not verified.

The review of the specific procedure, instruction or modification will be the

, subject of a separate evaluation. The staff has concluded the inspections to verify the procedure, instruction or modification may be conducted after the l restart of Sequoyah Unit 2.

The "acceptable and verified" finding for a TVA program or ECTG element reports means the NSRS recomendation is being acceptably addressed in the program or i n . _ _ - . - _ - _ _ _ _ _

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j f element report and the staff's safety evaluation of that program or element report will also be the evaluation of the acceptability of the TVA resolution of the NSRS recommendation. Verified may also mean that the issue, such as i NSRS recomendation R-86-01-SQN-01 on improvements in overall as low as reasonably achievable, has been addressed in the staff's evaluation of the TVA

Sequoyah Nuclear Performance Plan (SNPP). The staff's Safety Evaluation on the SNPP was issued on January 21, 1988.

TVA has concluded that all the restart NSRS recommendations are closed because the ECTG has completed its review of the work on the resolution of these recom-mend 3tions. In some cases, there may be some work remaining to be done by TVA.

For gxample, NRC is still reviewing ECTG elenent reports referenced in the

- enclosed table and there are non-restart electrical calculations which may be j completed after the restart of Sequoyah. Because TVA is tracking on these j activities through at least the Sequoyah Activities List (SAL) TVA does not

- want to track these activities also as an open restart NSRS recommendation for i Sequoyah. Therefore, TVA has concluded that all the restart NSRS recomenda-tions for Sequoyah are closed. This is acceptable to the staff.

For NSRS recomendations where TVA may have additional work to do, the staff is tracking 'nis work through its review of a TVA program or ECTG elenent report and the raff will be issuing a separate evaluation on its review of that program or element report.

For Recommendation R-84-19-WBN-07, Development of Criteria for Cable Tray Fill Level and QC Inspections, the staff reviewed TVA procedure SQEP-06, Revision 3, December 1987. Although TVA referred to SQEP-06, Revision 2. June 18, 1976 in its submittal dated October 5,1987, the procedure had been revised since then.

Section 4.5 of the procedure specifies the cable tray loading criteria. The staff concludes that this procedure provides acceptable criteria for cable tray fill levels and quality control inspections.

The NSRS recomendations which are not considered verified are addressed below:

3.1 Recommendation R-84-19-WBN-01 I The NSRS identified that controlled documents are not clearly identified for j all plants and the purposes and uses for ea:h docurent have not been delineated. i The NSRS referenced an instance at Watts Bar where logic and control drawings I in the control room did not agree with electrical drawings and temination j lists. This recommendation was considered by TVA to be generic to Sequoyah. 1 The ECTG's investigation at Sequoyah determined that the electrical prints are i controlled; however, the logic drawings are not controlled documents and have been removed from the control room. TVA also stated by phone on January 25, 1988 that control documents at Sequoyah are identified and the purposes of the i documents are delineated.  !

The staff concludes that TVA's actions are acceptable to close out the NSRS .

recomendation. This will be verified in an inspection. Based on the Plant l Modification and Design Control and Design Baseline and Verification Programs i being conducted by TVA and reviewed by the staff, the staff concludes that the '

verification may be done after restart. These TVA programs are evaluated in the  ;

staff's Safety Evaluation Report on the SNPP, dated January 21, 1988 '

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1 i 3.2 Recomendation R-85-2-SQN/WBN-2 The NSRS identified the following as remaining to be done to close the issue on d U gh-pressure seals: (1) issue procedure MI-1.11. (2) issue revised procedure l: SMI-0-94-3,(3)reviseprocedureSMI-0-94-3and(4)reviseappropriate i instructions to preclude pressurizing the primary systems with the thimble tubes disconnected from the overhead path transfer system (OPTS) or preclude

', work on the seals with the primary system pressurized above atmospheric p pressure and the thimble tubes disconnected from the OP15. TVA stated that the special maintenance instructions were reviewed for adequacy, compared to the i recomendations and found acceptable. Interviews were also held to verify that j the level of understanding the lessons learned was acceptable.

] The staff concludes that TVA actions to close the NSRS recomendation are j acceptable. The instructions will be verified in an inspection. Based on the

< staff's review of TVA naintenance program and its maintenance instruction

' enhancement program as described in TVA's Sequoyah Nuclear Perfortnance Plan

, (SNPP), the inspection may be conducted after restart of Sequoyah Unit 2. The staff's evaluation of TVA's maintenance progran is in its Safety Evaluation Report of the SNPP, dated January 21, 1988.

! 3.3 Recomendation 1-85-06-WBN-05 i The NSRS recomended that the TVA Division of Quality Assurance identify the L required controls applicable to systems identified with limited quality L'

assurance (QA) in the TVA Nuclear Quality Assurance Manual (NQAM). TVA stated that the NQAF contains a revised description of the limited QA program and specified the requirements that are imposed on the 13 features and programs to which a limited QA applied. At Sequoyah, TVA stated that these requirements are implemented in procedure Standard Practice SQA-189.

This is acceptable to the staff to close out the NSRS recommendation. An inspection will be conducted to verify that procedure SQA-189 properly imple-nerts the NSRS recomendation. Based on the staff's review of TVA's quality assurance program as described in the SNPP, the inspection may be conducted l after the restart of Sequoyah Unit 2. The staff's evaluation of the site i

quality assurance program is in its Safety Evaluation Report of the SNPP, dated January 21, 1988.

3.4 Recomendation R-80-05-SQN-10 l

The NSRS recomended that the design of the Sequoyah containment and other l l areas be reviewed to determine if they are adequate to withstand the effects of i

tornados. The additional analyses by TVA to verify the adequacy of the i structures at Sequoyah to withstand tornados were reviewed and approved by NSRS except i for one issue.

l For NSRS recomendation R-80-05-SQN-10, there is an apparent inconsistency between the TVA report ECTG-NSRS-02, Revision 1, and SQN-NSRS-2. The former report was submitted by letter dated January 16, 1987 and was addressed in the staff's Safety Evaluation dated August 27, 1987. The former report stated that

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. -S-i the NSRS had concluded that its remaining concern was the temperature moni-toring system which was to be installed in the 480-Y shutdown transformer

1 rooms. The latter report was in the TVA submittal dated October 5,1987, and 1 stated that the only remaining concern was vertical missile strikes down the l exhaust vent of the containment. On November 2, 1987, TVA (R. Gagne, ECTG

? program) stated that the two concerns were in fact the Lame concern, u

TVA stated that a missile plate has been installed beneath the opening of the

exhaust vent to provide protection installed directly under the opening. This is acceptable to the staff to close out the NSRS recomendation. This will be

verified in an inspection; however, based on the staff's review of the Design i Baseline ano Verification Program being conducted by TVA, the inspection may be conducted after restart of Sequoyah Unit 2. This program was evaluated in the j .

staff's Safety Evaluation Report on the TVA SNPP, dated January 18, 1988.

l 3.5 Recomendation R-82-08-NPS-01 a

f The NSRS determined that water quality analytical procedures were inadequately 4 controlled and documented and inconsistencies were found between the Nuclear i Steam Supply Systen vendor procedures and ASTM standards. The NSRS report l

stated that there were no procedural control: established for the central office

preparation, qualification and issuance of analytical procedures. TVA stated j that procedural controls for qualifying and issuing analytical procedures are required by the NQAM and implemented for Sequoyah through procedure SQE 22. In I addition, major modifications have been made to upgrade the water chemistry program.

4 The staff concludes that TVA's actions are acceptable to close out the NSRS recomendation. This will be verified in an inspection. Based on the staff's review of TVA's quality assurance program as described in the SNPP, the inspection may be conducted after the restart of Sequoyah Unit 2. The staff's Safety Evaluation Report on the SNPP was issued on January 21, 1988.

3.6 Recorrendation R-84-17-NpS-12 ,

The NSRS determined that the receipt inspection between Field Quality Engineering and Power Stores for QA levels I and II material and comercial grade itens was inadequate. It recomended that such items be receipt inspected by individuals qualified to ANSI N45.2.6. TVA stated that receipt inspection of these items are done by individuals qualified to that ANSI standard.

The staff concludes that TVA's actions are acceptable to close out the NSRS recomendation. An inspection will be conducted to verify the implementation of TVA's actions. Because the staff has addressed TVA's piece part qualifi-cation program in its evaluation of TVA's SNPP at 1 found it acceptable, this.

inspection may be conducten after the restart of Sequoyah Unit 2. The staff's Safety Evaluation Report on the SNPP was issued on January 21, 1988.

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! 3.7 Recomendation I-86-101-SQN

- The NSRS determined that the Conax connectors in the containment did not always

! meet vendor wire bend radius requirements and that deficiant connectot

installations were accepted by Sequoyah quality control. TVA stated that work i requests were initiated in 1986 to correct problems found during its verifica-i tion activities. These work requests have been completed. TVA has addressed its quality assurance program in the SNPP.

( The staff concludes that TVA's actions are acceptable to close out the NSRS

recomendation. The staff evaluated TVA's quality assurance program in its Safety Evaluation Reports on TVA's Corporate and Sequoyah Nuclear Performance f- Plan, dated July 28, 1987 and January 21, 1988. The program was found

! acceptable by the staff. The staff has also examined this specific issue as

{ part of its evaluation of TVA Inspection Performance in its Safety Evaluation

- Report dated October 22, 1987 and found it acceptable. Therefore, an inspection

! to verify the work requests may be conducted after the restart of Sequoyah j Unit 2.

4.0 CONCLUSION

Based on its review of the TVA submittal dated October 5, 1987, on restart NSRS recomendations, the staff concludes that (1) all the restart NSRS recommendations are closed and (2) all the TVA resolutions at Sequoyah for the

, restart NSRS recomendations are acceptable as a means to address the recomenda tion.

In some cases, the staff has been able to verify that the TVA resolution, a o program or an element report, is acceptably addressing the NSRS recomendation.

In these cases, the staff has concluded that the TVA resolution is acceptable and verified. The separate staff safety evaluation on the program or element report will address the acceptability of that program and eierent report.

Where the staff has not concluded a resolution is verified, the staff will, in a future letter, address the specific procedure, instruction or, plant modification.

In its submittal dated October 5,1987, TVA also provided its resolution for 70 non-restart open NSRS recomendations. The staff's review of these TVA resolutions at Sequoyah will be the subject of a separate evaluation. The TVA submittal dated October 5, 1987, provided an additional non-restart NSRS recomendation which had not been evaluated by the staff in its Safety Evalua-tion dated August 27, 1987. This additional recomendation is 79-10-03-3, concern for reliability, in TVA report SQN-NSRS-3. This recomendation report stated that programatic aspects of reliability activities did not exist at TVA in 1979. The staff concludes that, in accordance with the restart criteria approved in its letter dated June 9,1987, this is not a restart item. The ECTG has concluded in its report that this recomendation has been satisfac-torily addressed and TVA has an active reliability program.

An inspection will be conducted to verify implementation of TVA corrective actions for those NSRS recomendations that the staff concluded in the Table were acceptable but not verified. The staff has concluded that this inspection does not have to be conducted prior to the restart of Sequoyah Unit 2.

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5.0 REFERENCES

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1. Letter, R. L. Gridley (TVA) to H. Denton (NRC). Nuclear Manager's Review J

i Group Report, R-86-02-NPS, dated December 17, 1986.

t 6 2. Letters, J. A. M2cDonald (TVA) to H. Denton (NRC), Employee Concern Task i Group Report ECTG-NSRC-01, Revision 2, and ECTG-NSRS-02, Revision 1,.

dated, respectively, January 30 and 16, 1987.

s i 3. Letter, J. A. Zwolinski (NRC) to S. A. White (TVA), Evaluation of Nuclear

Safety Review Staff Concerns Requiring Resolution Before Restart, dated August 27, 1987.

l f 4. Letter, R. Gridley (TVA) to NRC, Sequoyah Nuclear Safety Review Staff i (NSRS) Reports, dated October 5,1987.

[ 5. Letter, S. D. Ebnater (NRC) to S. A. White (TVA), Safety Evaluation Report l on the TVA Sequoyah Nuclear Performance Plan, dated January 21, 1988, t

Prircipal Contributor: Jack Donohew I February Dated: 1988 I

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[ SAFE Y EVALUATION OF RESTART NSRS l

T OMMENDATIONS FOR SEQUOYAH i

f TVA Resolution j NSRS Recommendation at Sequoyah TVA Status Evaluation

[ SQN-NSRS-1 Report

.I R-80-05-SQN-04B, Design Baseline Continuing, Acceptable and ,

) Configura: ion Control Verification SAL Number 101 Verified

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' Program R-84-19-WBN-01, Clear The identifica- Completed Acceptable but  ;

Identification of tion and purpose not verified l Purpose and Use of All for the electrical

! Controlled Documents at logic and control i All Plants, drawin s has been accomp ished.

j R-84-19-WBN-07, SQEP-06 Completed Acceptable and i Development of Criteria (Revision 3, VeriffW*. NRC l for Cable Tray Fill Level December,1987). is reviewing the I and QC Inspections procedure within l its review of 1 tiement I

Report 23803.

R-85-2-SQN/WBN-2, Instructions Completed Acceptable but

( Maintenance, Operating SMI-0-94-3, not verified l and Test Instruction Mi-1.9, MI-1.10  !

and MI-1.11. l I-85-06-WBN-01, ECTG Element NRC reviewing Acceptable and l

, Adequacy of Dispositions Report 10900 element report verified

• l I for Identified Cable Bend l Radius Program I I-85-06-WPN-02, ECTG Element NRC reviewing Acceptable and Adequacy of Progran for Report 10900 element report verified

• 1 Cable Pulling Activities I-85-06-WBN-05, Standard Completed Acceptable but Development of Established Practice not verified and Documented Limited QA SQA-189 Program and Failure to Incorporate the Established Limited QA Program into NOAM ,

o The staff has verified that the NSRS recomendation is being addressed in the

• TVA Resolution at Sequoyah." The staff's evaluation of the ECTG elenent report or TVA program will also be the evaluation of TVA's resolution of the NSRS recomendation, i

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{ TVA Resolution j NSRS Recommendation at Sequoyah TVA Status Evaluation

! R-86-01-SQN-01, Evaluated in Completed Acceptable and i Improvements in Overall staff's Verified *. As l Low As Reasonably August 27, 1987 Issue addressed

Achievable Safety Evaluation. in staff's SERF on Sequoyah Nuclear

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Performance Plan

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{ SON-NSRS-2-Report R-80-05-SQN-10, Missile plate Completed Acceptable but Adequacy of Containment installed beneath not verified to Withstand Tornado exhaust vent to Damage protect equipment l R-82-07-WBN-06, ECTG Element NRC reviewing Acceptable and Visual Inspection of Report WP-02-SON element report Verified *

[ Welds Through Primer

R-82-08-NPS-01, SQE-22 Completed Acceptable but j Issuing Directives not verified Contrary to TVA Comitments I R-84-07-WBN-1, ECTG Element NRC reviewing Acceptable and j Pipe Support Report 20501 element report Verified

• Calculations Destroyed R-84-17-NPS-10, SQA-45 Completed Acceptable for R-84-17-NPS-11 (Section 27), all three and QMI710'.2(Rev.0), Verified

• for R-84-17-NPS-12,

for Connercial Grade Items QMI 710.3 (Rev. 0) R-84-17-NPS-10 l With QA Level I and II and AI-11 and 11. 1 Designation, Receipt

Inspections P-84-19-WBN-6, Trip settings are NRC reviewing Acceptable and Trip Settings of pre-set by the element report Yerified*

Breakers for MOV vendor and Motor-0perated are not adjustable.

Valves (MOV) and ECTG Element Report 23702.#

• The staff has verified that the NSRS recocinendation is being addressed in the "TVA Resolution at Sequoyah." The staff's evaluation of the ECTG element report l or TVA >>rogram will also be the evaluation of TVA's resolution of the NSRS l recorrnendation. I i PhoneconferenceonFebruary2,1987withR.Gagne(TVA,ECTG).

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'l j I-84-34-SQN-03, ECTG Element NRC reviewing Acceptable and i Availability of Material Report 40703 element Verified

• j Certification and report g R;quirements for Heat i Number Sort Printout .

( Entries I-85-06-WBN-3, SQEP-09, Continuing, Acceptable and Voltage Drop and Short Design completed Verified *.

Circuit Current Calculations restart Issue addressed Determination Review Program electrical in staff's SERF calculations on Sequoyah

, Nuclear r Performance Plan (Section2.3.3).

R-85-08-0E/NUC PR-01, SQN EQ Program, Completed Acceptable and Inadequate Environrental NEB-DI-125.01, Verified

• Qualification (EQ) SQN EQ

,- Procedure for Equipment Project Manual f Qualification by Similarity R-85-08-0E/NUC PR-02, Conditions Completed Acceptable and R-85-08-0E/NUC PR-03, Adverse and Verified

• R-85-08-0E/NUC PR-04, Ouality(CAQ)

R-85-08-0E/NUC PR-05, Program, TROI R-85-08-0E/NUC PR-06, System Timely Initiating and i Processing of NCR, FE .

and ER**

I-86-101-SON, Work to correct Completed Acceptable but Wire Bend Radius In problem completed but Ouality not verified l Installation Using Engineering

! Conax Connectors has not inspected the work l

• The staff has verified that the NSRS recor:rendation is being acceptably addressed.

The staff's evaluation of the SNPP ECTG element report or TVA program will also be i the evaluation of TVA's resolution of the NSRS recomendation.

! ccNCR = non-conformance reports. FE = failure evaluations, ER = engineering reports.

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NSRS Recomendation at Sequoyah TVA Status Evaluation r

R-86-02-NPS Report i

R-85-03-NPS-07, M4SL-A46, Completed Acceptable and i Connon Mode Failure Evaluated in Verified *,

staff's Issue addressed l- August 27, 1987 in Staff's SERsf

Safety Evaluation on Corporate and i Sequoyah Nuclear i Performance Plan

• i (Sections 6.4.2 i and 4.8 respectively).

l R-85-03-NPS-08, Findings 0-1, Completed Acceptable and

Quality Assurance 2, 3 in NMRG Verified.* Issue f

. Surveillance of Report addressed in l Maintenance Program R-86-02-NPS staff's SERF on ,

l dated TVA's Corporate i December 17, and Sequoyah 1986 Nuclear i Performance Plans (Sections 6.4.2

, and 4.8 respectively). .

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• The staff has verified that the NSRS recommendation is being acceptably addressed.

The staff's evaluation of the SNPP ECTG element report or TVA program will also be the evaluation of TVA's resolution of the NSRS reconnendation.

1. SERs (NUREG-1232, Volume 1 and 2) dated July 28, 1987 and January 22, 1988 respectively.

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