IR 05000327/1986062

Insp Repts 50-327/86-62 & 50-328/86-62 on 861112-21. Violations Noted:Failure of Design Organization to Evaluate & Properly Disposition Mfgs Requirements Associated W/ Installation of Containment Hydrogen Monitors for Plant

ML20207T913
Person / Time
Site:	Sequoyah
Issue date:	02/09/1987
From:	Bearden W, Branch M, Brooks C, Hopkins P, Mccoy F, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T898	List: IR 05000327/1986062 ML20207T896 ML20207T902 ML20207T913
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-327-86-62, 50-328-86-62, IEB-80-06, IEB-80-6, NUDOCS 8703240418
Preceding documents:	ML20236D471 (27 July 1987)
Download: ML20207T913 (17)

Text

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UNITE'1lll STATES g pm REIg'o, NUCLEAR HEGULATORY COMMISSION

.[ p REGION ll

, , 101 MARIETTA STREET, * * ATLANTA, GEORGI A 30323

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Report Nos.: 50-327/86-52 and 50-328/86-62 Licensee: -Tennessee Valley" Authority 6N11 B Missionary Plac Market Street Chattanooga, TN 37402-2801 ,,

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Docket Nos.: 50-327 and 50-328 License Nos.: DRP-77 and DRP-79 Facility Name: Sequoyah Units 1 and 2 Inspection Conducted: November 12-21, 1986 Inspectors: M M. Branch, Inspectiotr

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am Leader 'Date Signed 24v ,w W. Beafden, esident spector, Bellefonte / Dete Signed A sident Ins ctor, Browns Ferry iA/n

/ Date Signed C. Brodks,}

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.<v P. Hop' kins, Resident f In ector, V. C. Summer Date Signed

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f " / 9 fY'7 J. Tedrow, Resi ent Inspector, Cr s, al River- Date Signed Approved by:

F. McCoy', Section Chief v-

/[ 2 rh D~ ate' Signed Division of TVA Projects SUMMARY Scope: This special. announced inspection was conducted in the areas of

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Engineering Change Notice (ECN) close-out and review of the transitional design change ECN program as described in the Sequoyah Performance Pla In the areas inspected two violations were identified. The first

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Results:

violation, discussed in paragraph 8.1, involved a failure of the Design-Organization to evaluate and properly disposition manufacturer's requirements associated with the installation of the Containment Hydrogen Monitors for both

units. The second violation, discussed in paragraph 9, idertified by the .

l licensee, involved a failure to establish a program required by the Nuclear i Quality Assurance Manual (NQAM) tc ensure long-term commitments implemented

! into procedures /instrtctions are not deleted by subsequent revisions.

l 8703240418 870304 7 PDR ADOCK 050 G

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REPORi DETAILS

- Persons Contacted Licensee Employees P. R. Wallace, Plant Manager B. M. Patterson, Maintenance Superintendent

• N. E. Andrews, Site Quality Manager

• G. B. Kirk, Compliance Licensing Supervisor k. W. Olson, Modifications Branch Manager M. R. Sedlacik, Electrical Section Manager, Modifications Branch l

, R. M. Mooney, Systems Engineering Supervisor

• J. F. Weinhold, Engineering Assurance Manager

• A. H. Ritter, Engineering Assurance Engineer i

• M. P. Berardi, Engineering Assurance Advisor l

• J. W. Kelly, Engineering Assurance Engineer

• D. L. Widner, Modifications Supervisor

• C. R. Winton, Modifications Engineer

• L. Elliott, Engineering EQ Project Manager

• T. Holliday, Division of Nuclear Engineering L *M. A.-Purcell, Compliance Engineer

• M. Cooper, Compliance Engineer Other licensee employees contacted included technicians, operators, l shift engineers and maintenance personnel.

l-l NRC Resident Inspectors Contacted:

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• K. Jenison

• P. E. Harmon D. P. Loveless W. K. Poertner Additional NRC Personnel Contacted:

• V. Imbro, Section Chief, IE

• E. Architzel, Senior Inspection Specialist, IE

• L. Belke, Quality Assurance Engineer, IE

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• Attended exit interview Exit Interview The inspection scope and findings were summarized on November 21, 1986, with those persons indicated by an asterisk in paragraph one above. The follow-ing new items were discussed: Violation (327/86-62-02 and 328/86-62-09), Failure to properly control the design process paragraph '

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2 Licensee Identified Violation (328/86-62-14), Failure to establish programs regarding commitments established by Design Division Procedures paragraph Unresolved Item (328/86-62-07), Radiation Protection review of pene-trations in sh,ield building paragraph 8.1.

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• Unresolved Item (327/86-62-01 and 328/86-62-08), Adequacy of H2 analyzer to meet operability requirements of Technical Specification (TS) 3.6.4.1 paragraph * Unresolved Item (327/86-62-03 and 328/86-62-11), Evaluation of USQD for l change 3 to FSAR on H2 analyzer accuracy paragraph 8.1.

• Inspector Followup Item (328/86-62-01), ECN closeout check list -

paragraph Inspector Followup Item (328/86-62-02), Need to close ECNs prior to restart paragraph Inspector Followup Item (328/86-62-03), Followup of revised calcula-tions for effects of radiation on device qualification paragraph * Inspector Followup Item (328/86-62-04), Review of final revision of Al 19, part IV and ensure time commitments for ECN closecut and drawing update is established paragraph Inspector Followup Item (328/86-62-05), . Correction of FSAR Table 6.3.2-4 paragraph Inspector Followup Item (328/86-62-06), Evaluate the need for TS change to reflect the addition of Main Feed Pump Tri Also the need for written guidance in determining when a TS change is needed, should be evaluated paragraph * Inspector Followup Item (328/86-62-10), Need to establish 30 minute activation requirement for H2 analyzer paragraph Inspector Followup Item (328/86-62-12), Followup of battery room deficiencies paragraph Inspector Followup Item (328/86-62-13), Correction of FSAR irregulari-ties described in Corrective Action Report (CAR) SQ-CAR-86-021 -

paragraph Inspector Followup Item (328/86-62-15), Followup of corrective action for deficiency in long-term commitment maintenance paragraph * Indicates items not discussed in November 21, 1986 Exit, but were discussed with L. Nobles on a phone call December 18, 198 'l

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The licensee acknowledged the inspection findings with no dissenting com-ment The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection period. At no time during the inspection period did the inspectors provide written material to the license . Licensee Action on Previous Enforcement Items (92702)

This area was not inspecte . Unresolved Items Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or devia-tions. Three unresolved items were identified during this inspection (paragraph 8.1). Engineering Change Notice (37700)

ECN Closeout This portion of the inspection was to assess the licensee activities asso-ciated with closeout of ECNs. A brief description of identified problem associated with ECN closecut along with the licensee's new closeout process is provided for clarity. The new Transitional Design Change ECN program is not part of this discussion but is described in detail in paragraph 6 of this repor The ECN is the vehicle used by Ti!A Engineering to evaluate and approve changes to the physical plu Changes to the facility are allowed by 10 CFR part 50.59 provided the written safety evaluation for the proposed modification determines that an unreviewed safety condition will not be created by the modification. Additionally,10 CFR Part 50, Appendix B, Criterion III, Design Control, requires that design changes, including field changes, be subject to design control measures commensurate with those applied to the original design. To implement this design change into a plant modification additional programs and procedures are utilize The modification program, discussed in paragraph 7 of this report, converts the design change into a physical plant modification. However, in the past, procedures necessary to feedback to the design organization actual modifi-cation vs. proposed modifications were ineffective. This resulted in a disconnect between the design and operating organization in the area of design control. An essential part of this operations / design feedback process should be the closure of the ECN which then establishes the design basis for additional modification. Currently only 145 of the 1400 safety i related ECNs have been close In August 1985, TVA established an ECN closeout group consisting of approximately 12 full time personnel. The purpose of this group was to establish closecut criteria and perform close-out reviews of the modification packages. These reviews by the operating

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organization were documented on a closecut form which provided the basis for closeout of the ECN by the Engineering organization. Initially, this closure checklist was established by Modification Group Letter (MODL) A-23; however, it was later integrated into Administrative Instruction (AI) 19 (Part IV),'" Plant Modifications: After Licensing."

The check list currently being used by the task group is more detailed than the one presently in AI 19 (Part IV). The inspector identified to the licensee the need to update the AI-19 checklist so as to have only one inclusive list for ECN closeout. This item is identified as Inspector Followup Item (IFI 328/86-62-01).

The inspector reviewed several ECN closure packages to determine the number and nature of the specific findings. Of the 5 ECN closure packages reviewed, the inspection revealed that most of the problems identified through the closecut project were of the drawing update natur Additionally, the inspector reviewed the closeout criteria established by the closeout form. The closecut criteria included on the form are as follow:

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Review all Work Plans (WP) and Field Change Requests (FCR) necessary to accomplish the EC .

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Verify that the Office of Engineering has listed all affected drawings and FCRs on the final inventory shee Verify ECN revision list matches the list contained in the W Verify that all drawings have been update Problems associated with the ECN process are discussed in Section II.3 and III.2 of the Sequoyah Nuclear Performance Plan; however, no mention of a schedule or a commitment to close ECNs prior to restart could be foun Closure of ECNs appear prudent as the closure review is the vehicle which triggers the FSAR update process as well as ensuring that drawings are revised. TVA's schedule and reasoning for not closing ECNs prior to restart is the subject of a separate letter from Region II to TVA dated December 18, 1986, and will be tracked as Inspector Followup Item (IFI 328/86-62-02). Transitional Design Control System In Section II.3.3 of the Sequoyah Nuclear Performance Plan, TVA committed to implementing a transitional design control system prior to restart. The purpose of the transitional program is to correct some of the root causes of past design control problems at Sequoyah and to facilitate implementation of the permanent upgraded design control progra The performance plan does not contain sufficient detail on this subject, however, the inspector was provided a copy of the TVA Division of Nuclear Engineering Design Change Process Improvement Program, dated July 1986 which describes in detail both the transitional and permanent programs and assigns responsibilities for implementation. This document explains that since the permanent program won't be implemented until sometime after restart, the transitional system

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is necessary to ensure once the Design Baseline and Verification Program (DBVP) has reestablished the plant design basis and configuration control, that it is properly maintaine This.is the criteria to which_the program was judged during this inspection. No evaluation was made as to the effectiveness of the program in easing the transition to the new program or as to how comprehensive it was in correction of root causes.

The Design Change Improvement Program Plan required that each site develop procedures to implement the transitional system. At Sequoyah, this procedure is Sequoyah Engineering Procedure SQEP-13, " Procedure for Transitional Design Change Control," Revision 1. The inspector reviewed the procedure and found that it adequately addressed all of the aspects of the program plan and satisfied the commitments of the Sequoyah performance plan.

Adequate provisions are contained either in SQEP-13 or through . reference to other Nuclear Engineering Procedure (NEPs), Standard Practices or other administrative instructions to assure that the design basis is properly referenced and maintained and that the DBVP efforts are not compromised.

Key elements of the program are discussed below:

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The modification package will be reviewed as a whole to ensure that it is suitable for its intended purpose, represents a complete and high quality engineered modification, can be effectively installed and tested, and that all documentation is traceable to permit updating upon completion, and reflects the actual plant configuration.

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A responsible modification package DNE task engineer will be assigned to ensure the design work is identified and p9: formed, the package is assembled correctly, completed, reviewed, and closed.

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The design modification shall be for a single unit and be of manageable size to permit implementation within the defined period. The review /

approval process will include a . review of the completed modification package, performance of USQD reconciliation to the FSAR and will result in revisions to affected design documents as necessary after installa-tion and testing to represent the final design conditions.

The licensee is currently implementing SQEP-13 on a case-by-case basis (i.e., only on new modifications) until restart, at which time all modifica-tions will be controlled by i About 60 Engineering Change Notices are in various stages of preparation using SQEP-13; however, none have yet been completed through the design stages. Following design completion, the modification will be turned over to plant modifications for physical work.

It will be sometime (possibly after restart) until a modification has gone through the complete cycle to closure. For this reason it was not possible to evaluate implementation of the transitional program.

An indepth look into design inputs was made as a spotcheck on the compre-hensiveness of the transitional program. SQEP-13 references NEP 3.2,

" Design Inputs," for the assimilation cf modification design criteria. NEP 3.2 in turn requires that design inputs for all structures, systems and components be identified, documented, and preserved. These criteria shall

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be incorporated in a Design Basis Document (DBD). The DBD is to be the single source document in which licensing commitments are made and where design documentation is maintained. The DBD does not yet exist (except in partial draft form) but input for the Safe Shutdown Systems will be com-pleted prior to restart since this is an integral step in the DBVP. Design Criteria Documents, however, do exist and are used in lieu of the DBD for new modification The inspector accumulated all of the design criteria for the Control Building Emergency Pressurization (CBEP) Syste This consisted of SQN-DC-V-13.9.6, Control Building Ventilation Design Criteria which referenced other general design criteria as well as specifying the environmental conditions and environmental design criteria. During review of this material, the value for post-accident radiation exposure appeared questionable. An engineer involved in the 10 CFR 50.49 review indicated that the value did not initially include a source from the charcoal loading which would occur throughout the 100-day . cident period but that a revised calculation was in progress. Additionally, ECN-L7000, Addition of required supports to the Main Steam Dump Header, ECN-L7027, Seal electrical conduit penetrations between the Auxiliary Building and Turbine Building, and ECN-L7013, Replacement of Sample Pumps and Motors for the containment yydrogen analyzers, were reviewed. Although these ECNs had not yet com-pleted the full design review and approval process, these ECNs were reviewed to determine how the transitional system was being implemented. The in process ECNs were being implemented per the transitional program requirements. One deficiency was noted with the modifications criteria (Attachment A of NEP 3.2) of ECN-L7013. The regulatory requirement section failed to make reference to NUREG 0737, Clarification of TMI Action Pla No other deficiencies were noted. This was identified to the licensee for correctio Followup of the revised radiation calculations for device qualification if the post-accident radiation environment is increased is identified as Inspector Followup Item (IFI 328/86-62-03). Review of Modification Proces The inspector reviewed the draft revision of procedure (AI 19 part IV,

" Plant Modification After Licensing"). This procedure specifies the control process necessary to convert work specified in the ECN into a completed field modification. The process is described as follows:

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Design Change Request (DCR) written by plant

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Change Control Board reviews DCR

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ECN developed by engineering along with safety review

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ECN received by the plant modification group from engineering

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Work listed on outstanding work list

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Work Plan (WP) written to field implement the ECN (several work plans may be necessary to implement the entire ECN)

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Operations align system as necessary to implement WP

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WP. field completed

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Post-modification or functional test accomplished

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System returned to operations and control room drawing updated

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Review for TS and procedures update by plant staf Also feed back to update the simulator is initiated

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ECN closeout review by modification group which should drive update the of all drawings

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ECN closure recommended by modification to engineering

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Engineering ECN closure drives 10 CFR 50.71 annual FSAR update The problems identified by the inspector during this review include the following:

1) No time limit to review and close the ECN has been established. Since the ECN closure is the review to ensure all drawings -are updated, a time limit to review ECNs after field completion should be establishe ) Since 10 CFR 50.71 required the annual update of the FSAR to be current within 6 months of the modification, a commitment to review and close ECNs in a timely manner after field completion of the modification is neede The above two items are identified as weaknesses in the ECN/ modification process and should be addressed by the final revision of AI 19, Part IV, which will implement the transitional ECN progra These two items as well as the review of the final revision of AI 19, Part IV is identified as Inspector Followup Item (IFI 328/86-62-04). Design, Design Changes, and Modifications (37700)

The inspector reviewed several WPs for technical adequacy, proper review and approval, adequacy of safety evaluation, as well as drawing and procedure update. Field installation was reviewed and verified on several of the ECNs reviewed. Additionally, the inspector reviewed the modifications to ensure

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that the entire ECN scope was implemented by the combination of WP WPs reviewed as well as inspection findings are as follow: Engineered Safety Feature (ESF) Reset Controls The licensee initiated ECN L5734 in response to IE Bulletin 80-0 This Bulletin described circumstances under which resetting certain ESF alone resulted in equipment changing positions from their emergency mode to their normal mod The ECN changed the control circuit for RHR heat exchanger outlet valves 2-FCV-74-16 and -28 so that the valves would remain in their emergency position after the Safety Injection (SI) signal was reset. WP 10600 implemented this ECN which basically consisted of adding a reset switch in the control room such that the valves would remain in their emergency position after SI system reset until the additional component reset was switched. Neither the ECN or WP required that the FSAR be revised to reflect the change in valve control. Table 6.3.2-4 of the FSAR lists the sequence of change-over operation from injection to recirculation for the RHR Syste This sequence described manipulation of FCV-74-16 and 28 in Step 2; however, without resetting the SI actuation signal and the newly installed reset switch, these valves would remain fully open. A licensee representative indicated that the sequence of operation described in FSAR Table 6.3.2-4 was not correct and did not agree with Emergency Instruction E11.2, Revision 2, Transfer to RHR Containment Sum An Inspector Followup Item will be assigned to track correction of the FSAR (IFI 328/86-62-05).

The inspector noted that the ECN closure verification form discussed in paragraph 5 above does not include a check to ensure that the FSAR was changed (if required). There was no assurance that similar examples of failure to update the FSAR would be corrected. A licensee representa-tive indicated that instead of checking this during the ECN closure verification, a separate task force was being developed to correct FSAR deficiencies. This task force is to be assembled as part of the corrective action for CAR 86-04-021 discussed in a separate paragraph of this repor Addition of Main Feed Pump Trip Signal ECN L5632 was initiated in May 1982 to correct an adverse condition on the feedwater system. The condition resulted from pressure surges in the feedwater piping following a feedwater isolation with the Main Feed Pump (MFP) still running. The modification added a trip signal to the MFP circuitry such that upon a reactor trip coincident with low T-avg, the MFP trips (in addition to the already existing feedwater isola-tion).

The ECN coversheet indicated that a potential TS change was involve The Unreviewed Safety Question Determination (USQD) associated with this ECN detailed this concern by stating that "although the FSAR accident analysis does not take credit for feedwater isolation due to

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low T-Avg coincident with a reactor trip, the existence of this isola-

-tion does provide redundancy and diversity in the design for accident mitigation." Since the basis for TS 3/4.3.2 includes instrumentation required to provide for reliability, redundancy and diversity not otherwise taken credit for in the FSAR analysis, the USQD concluded that this instrumentation may need to be added to TS 3/4.3.2, Engi-neered Safety Feature Actuation System Instrumentation. Furthermore, Westinghouse provided a Safety Evaluation on the MFP trip signal and also indicated that a change to the plant TS may be in orde No documentation could be located to show how this recommendation was dispositioned. Although, a sign-off on the WP control form for WP N was completed, indicting that a TS change was received, this trip function was never added to the TS. Licensee representatives indicated that an undocumented evaluation made by the modifications engineer determined that no TS change would be required. Since this is a rather unique situation (evaluating the need to add previously not included functions and equipment operability requirements to the TS), the inspector pursued whether the licensee had developed any criteria with which to make this judgment. Since 10 CFR 50.36 does require that the TS be based upon the FSAR as well as amendments to the FSAR, the regulations did foresee the need to add equipment to the TS as modifi-cations are made to the p~ ant. There is no written guidance at Sequoyah to aid in making this determination. The inspector requested that Sequoyah licensing reevaluate the necessity for adding this function to the TS. This will be tracked as an Inspector Followup Item (328/86-62-06). Control Room Smoke Removal Fan Replacement, Dampers Addition ECN L5140 as implemented by WP 8340 and WP 8573 replaced the belt driven control room smoke removal fan with a direct driven type fa Dampers FCO-31A-105D and FC0-31-106D were added, ducting rerouted and position indicating lights added to control room panel 1-M-9 for the new damper The inspector noted that the damners and associated indicating lights were not part of the present plant configuratio Further investigation and discussions with licensee personnel revealed that dampers FC0-31A-1050 and FC0-31A-106D and associated indicating lights were removed under ECN L5274. No deficiencies were identifie Control Room HVAC Damper Replacement ECN L5274 as implemented by WP 8669, WP 8680, WP 10435 and WP 12205 provided for replacement of dampers FCO-31A-105A, B&D and FC0-31A-106A, B & D with a single pair of motor operated butterfly valve The replacement valves FCV-31-105A and FCV-31-106A we.e intended to provide better isolation during control room HVAC isolatio No deficiencies were identifie Installation of Containment Pressure Indication ECN L5141 as implemented by WP 3521 and WP 3542 provided for installa-tion of two continuous containment pressure indications in the Control

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Roo This 'ECN was a post-TMI modification as required by item 2.1.10 of NUREG-0578 which called for addition of-sensors to monitor contain-ment pressure in the containment using transmitters qualified to IEEE 323-197 Additionally, this system must meet the requirements of Regulatory Guide 1.9 The inspector noted from the review that the ECN did provide containment pressure indication as required but did not provide any mode of continuous recording as required by Regulatory Guide 1.9 Further investigation and discussion with licensee personnel revealed that containment recorders were installed under ECN L519 No deficiencies were note Installation of Containment Pressure Recorders ECN 5196 as implemented by WP 10666 provided for installation of continuous containment pressure recorders in order to complete a portion of post-TMI requirements as discussed in paragraph e abov Under this ECN pressure recorders .1-PR-30-310 and 1-PR-30-311 were to be installed in the control room on panel 1-M-9; however, due to the Unit 1 instruments not being received at site, spare recordere on Unit 2 control panel 2-M-9 are being temporarily utilized until the recorders are received and put in service. The ECN will remain open pending completion of work under a later W Reactor Coolant System Pressure Transmitter Installation ECN L6055, WP 11173, WP 11174, WP 11193 and WP 11226 installed an additional Reactor Coolant System wide range pressure transmitter (PT-68-69) and relocated two others (PT-68-66 and PT-68-59). These transmitters provide inputs to the cold over pressure protection and reactor vessel level instrumentation (RVLIS) systems. The WPs were reviewed to insure that the scope of the ECN was fully implemented and that these modifications complied with regulatory requirements. No deficiencies were note Changing Setpoint of Auxiliary Control Air Compressors ECN L5994 and WP 9390 increased the air pressure start setpoint for the auxiliary control air compressors and removed the internals from the following auxiliary control air system check valves: 32-262,32-268, 32-329, and 32-328. The work plans were reviewed to check that the scope of the ECN was fully implemented and that regulatory requirements were me No deficiencies were note Installation of Capillary Tubing for RVLIS System ECN 2768 and WP 10995 installed capillary instrument tubing for the RVLIS syste The inspector reviewed the WP and partially walked down portions of this modificatio No discrepancies were note .

, Pressure Boundary-Integrity ECN 6050 was initiated to upgrade the high pressure fire protection system (HPFP) in the mechanical equipment room EL732.0, so that the piping will retain pressure boundary integrity retention as required

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during a seismic even No deficiencies were note Purge Air Exhaust Fan 1A and Back Draft Damper Modification ECN 5192 and WP 8474 were inspected for accuracy and to ascertain i the procedural process had been followed and closecut was adequat The preoperational test deficiency report showed that the backdraft dampers on the discharge of the reactor building (RB) exhaust fans were damaged due to excessive DP across the dampe Subsequent evaluations indicated that some of the dampers were not needed, and they were therefore removed. The remaining dampers were replaced with a heavier duty designed dampe A walkdown of the physical installation along with associated drawings, FCNs, _ WPs, FSARs and TS requirements was accomplishe Closeout procedures for the associated documents appeared to be well esta-blished. No deficiencies were identifie . Hydrogen Analyzer Modification ECN L6032 as implemented by WP 11110 and WP 11119 relocated the cali-bration system as well as numerous electrical components on the con-tainment hydrogen (H2 ) analyzer. This relocation was necessitated because components of the H 2 analyzers located in the annulus area between the containment liner and shield building were not environ-mentally qualified for the expected post accident radiation field. The inspector review of this modification which included field verification of installation identified a potential problem regarding the effects of penetrations through the reactor shield building. Specifically, ECN-L6032 involved several penetrations in the shield building through the shield wall. The ECN was silent on die effect of these penetra-tions on the shielding capability of the wall or ALARA. Both the profile and the location of a penetration can have an impac Further review of this item by members of the Design Baseline Verifi-cation Inspection Team resulted in the following discussion:

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The radiation protection section located in Knoxville, indicated that all penetrations in the shield wall need to be reviewed for an effect on ALARA as well as impact on shielding of equipment and

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components from potentially damaging radiatio The review is intended to prevent penetration locations that are in-line of radioactively hot equipment or those that cross a path for per-sonnel access. Evidence was found to suggest that the radiation protection section did review and approve the technical content of the ECN prior to implementation. However, the review of drawings which showed the location, number and size of the penetrations showed no evidence of participation by the radiation protection section in the squad review. A squad review is a discipline interface review by the drawings which depict a modification. The drawings reviewed by the inspector were 47W470-2 and 47W471-1 On these drawings there is a total of four revisions that result from the changes required to implement ECN L6032. The revisions resulting from ECN L6032 on Drawing 47W470-2 are 31 (dtd. 2/3/84),

32 (dtd 10/23/84), and 33 (dtd 12/26/86). Drawing 47W471-15 had a single revision resulting from ECN-L6032 which is 39 (dt /23/84). None of these revisions have any indication that the radiation protection section was involved in the squad review for the modification. The penetrations in question are located at elevation 734 which is the refueling floor and location of the control roo In one location there is a mechanical equipment room inside the shield wall. At another location the emergency gas treatment equipment is located inside the shield wall. The lack of interface review of drawings by the radiation protection section was identified as a problem by INP0 for instances of local electrical control panels being located in areas where personnel would receive inordinately high radiation doses when operating the control TVA was requested to provide the inspector with any additional information to support the adequacy of the radiation protection review of the modifi-

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cation. This item is identified as unresolved item (URI 328/86-62-07)

pending receipt and review of any additional information provided by TV During the review of the modification to the H2 analyzer, the inspector noted problems with the initial installation of the H2 analyzers for both Units 1 and 2. The original H2 analyzers installed in the 1978 time frame were later upgraded to satisfy the requirements of NUREG 0737, "TMI Action Plan."

NUREG 0737, item II.F.1 (6), " Containment Hydrogen Monitor" required the accuracy and placement of the H 2 monitors be provided and justified to be '

adequate for their intended function. TVA in their December 10, 1980 letter (L. M. Mills to A. Schwencer, NRC) on TMI Action Plan item II.F.1 (6)

described the system as follows: "As a result of the analyzer capability and the mixing afforded by the hydrogen collection system which draws from compartments within the containment and the containment dome a true indica-tion will be given of the hydrogen concentration within containment. The analyzers are calibrated to measure hydrogen concentrations between zero and ten percent with an accuracy of plus or minus one-tenth of one percent...."

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The field installation of the H monitors 2 for both Units 1 and 2 did not implement the vendor (Consip Delphi, Inc.) requirement regarding sample line slope and insulation. The failure to properly route and insulate the sample line results in the condensation of moisture for the containment post-accident H z sample in-route to the detector. This installation can create two potential problems: 1) water traps present a torturous path for the H 2 gas to reach the detector although the vendor did indicate, in a phone call, that the pump was capable of pumping any water that reaches the analyzer, 2) a true reading of containment vapor H2 concentration is not possible as long as actual containment moisture is greater than that the detector sees.

The vendor indicated the reading could be higher than actual by as much as a factor of 5 although TVA analysis, performed at the inspector's request, indicates a lesser error. These inaccuracies appear to be in the conserva-tive direction; however, decisions made based on the H g indication are not conservative. Specifically, Sequoyah Function Restoration Guidelines FR-Z1,

" Response To High Containment Pressure," instructs the operator to NOT place H2 recombiners in service and to consult technical support center for containment hydrogen purge instructions if H 2 indication is > 6%. These actions, if based on erroneous high Hz indication, would be noli-conservative and may result in post accident complications.

The installed system does not appear to provide the degree of accuracy originally claimed in TVA's December 10, 1980 letter and on a subsequent change to Section 6.2.5.3 of the Sequoyah FSAR the described accuracy was changed to plus or minus 1.5 percent hydrogen. Region II has requested a review of the present installation by the office of Nuclear Reactor Regula-tion (NRR) in order to determine system adequacy to satisfy the requirement of NUREG 0737 and TS 3.6.4.1.

The adequacy of the installed system to satisfy the operability requirement of TS 3.6.4.1 is identified as Unresolved Item (URI 327/86-62-01, 328/86-62-08) pending NRR review.

To determine root cause of why the designer failed to implement critical vendor installation requirements, the inspector reviewed the design control process inplace during the 1978 time frame. Additionally, the inspector reviewed the requirements of 10 CFR Part 50, Appendix B to determine what design control requirements should have been in place to ensure a quality end produc Criterion III of 10 CFR Part 50, Appendix B requires the design control process to include measures to ensure appropriate quality standards are specified and included in design documents and that deviations from these standards are controlled. TVA's current procedures for control-ling the design process are outlined in the Nuclear Engineering Manual.

Procedures in this manual require design requirements be traceable to the output document which may include ECNs, drawings or procedure This manual further requires the output to be consistent with the associated input documents or appropriately dispositioned.

During the above review, the inspector discussed with the design engineers their basis for not including critical vendor requirements in their design.

No basis or supporting calculations could be produced as to how the vendor

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installation instructions were dispositione Tha inspector realizes that not all vendor recommendations are requiremant This issue is being pursued as part of Generic Letter 83-28 and will not be discussed further in this report. However, when a vendor sells a product which has been qualified for a specific purpose, installation recommendations take on a higher degree of importance and proper disposition of these recommendations / requirements are necessary to ensure a quality installation. The failure to properly control the design of the H 2 analyzer system is a violation of 10 CFR Part 50, Appendix B Criterion III, Design Control (327/86-62-02 and 328/86-62-09).

Several related items associated with the H2 analyzer installation were also identified. These items along with the inspector's concerns are listed below:

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NUREG 0737 item II.F.1 (6) requires the H 2 analyzer be a continuous monitor or be activated within 30 minutes after receiving a SI signa A review of the emergency instruction (EI) E-0, " Reactor Trip or Safety Injection," indicated no reference to activation of the H2 analyzer within 30 minutes of the SI. The inspector discussed this item with the group responsible for emergency procedure The licensee indicated that task analysis has shown that if a true SI occurs, procedure E-0 will drive the operator to other procedures which will instruct the operator to activate the H 2 analyzer equipmen The inspector could find no time criteria established in any procedure review which would ensure the H2 analyzers are functioning within 30 minutes after an S This item is identified as Inspector Followup Item (IFI 328/86-62-10).

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Revision 3 of the Sequoyah FSAR changed the specified accuracy of the H2 Anal

+/- 15%yzer fromfor of scale thethe previous value toThe instrumen +/- inspector 1.5% Hydrogen which requested thatisthe licensee produce a 10 CFR 50.59 safety evaluation which should have been performed prior to changing tne FSA The annual update of the FSAR is to ensure plant modifications made during the year are accurately reflected in the FSAR. It appears that TVA has used the FSAR update process to correct problems identified in the FSAR. It is the NRC position that changes to the facility as described in the FSAR, either physical or documentary, need to be supported by a 10 CFR 50.59 Safety).

(USQD)

Evaluation (TVA Unreviewed TVA was requested Safety to provide Question the USQD Determination for the identified chang This item is identified as Unresolved Item (URI 327/86-62-03 and 328/86-62-11) pending receipt and review of the USQD. Battery Room Thermostat Modifications ECN L5781 was written to raise the 125 VDC vital battery room thermo-stat settings from 60 F to 75 F. This change was necessary since no margin was available from the battery electrolyte temperature limit of l

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TS 4.8.2.3.2.b (3) which was also 60 F. The affected thermostats were TS-313-442, 468, 492 and 518. Actual thermostat settings were found to vary from this setpoint on November 20, 1986, as follows:

THERMOSTAT ACTUAL LOCATION SETTING TEMPERATURE Vital Battery Room 1 78 F 64 F Vital Battery Room 2 82 F 57 F Vital Battery Room 3 75 F 72 F Vital Battery Room 4 85 F 66 F The equipment requirements were satisfied because only 2 of the 4 batteries are required to be operable for the existing plant condition, however, the condition of various components were cause for concer The thermostats had apparently been adjusted to combat deficiencies with room exhaust fans and dampers. Inoperable exhaust fans and dampers allow a direct inlet of outside cold air to enter the rooms and exceed the capacity of the room heaters. The battery room 2 thermostat had two maintenance work request tags hanging on it. MRA-536440 was written on 10/10/85 because room temperature was too low. WR B292818 was written on 10/31/86, again describing a low room temperature problem. On the day of inspection, no temperature control was available since the space heater had been previously removed. Battery room 4 also had a work request tag (B202819) on the thermostat requesting a setpointadjustment. Since insufficient time was available for follow-up of the battery room temperature problems, an Inspector Followup Item (IFI 328/86-62-12) will be opened to track this concer . Independent Review Durinc the course of this inspection the inspectors became aware of a defic;iency associated with the quality of the Sequoyah FSAR. The licensee had identified through his corrective action program that a Significant Adverse Condition existed regarding the current updatad FSAR. This condi-tion was documented by CAR SQ-86-04-021 which was written on April 16, 198 The CAR indicated that there is no assurance that Sequoyah is meeting the requirements of 10CFR 50.71 which recuires the FSAR to accurately reflect the actual plant and be current withi n 6 months of any modification which affects the FSA The conclusion stated on SQ-CAR-86-021 was that there is no assurance that the SQN FSAR is up to date. The root cause was determined to be inadequate procedures to ensure review of changes and documentation of these review Stated corrective action will consist of the establishment of an inter-disciplinary task force to review past material which could have affected the FSAR such as procedures, correspondence, modifications, safety evalua-tions, analyses, design documents, etc. This work has not been scheduled or fully scoped as yet and has not been linked to unit restart. TVA's schedule and reasoning for not resolving the conditions described in l

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SQ-CAR-86-04-021 is the subject of a separate letter from Region II to TVA and will be tracked as Inspector Followup Item (328/86-62-13).

Also during this inspection, the inspectors identified a weakness in the outside or;anizations. Specifically, Section 5.1.3 of the TVA Nuclear Quality Assurance Manual (NQAM) requires that a method be established to ensure long-term commitatnts implemented by procedures / instructions are not deleted by subsequent revisions. This NQAM requirement is implemented, for procedures generated by the plant operating organization, by Administrative Instruction (AI) 4.0, " Plant Instructions - Document Control." This AI requires .that commitments be listed in the reference section of the imple-menting procedure. Additionally, AI 4.0 requires that _ changes to the >

implementing procedures _ not delete implemented commitments unless the commitment is cancele The inspector could not locate a design division program commitment control similar to the program discussed above. It should note that an audit performed by the Quality Systems Branch (Rim L16 861104 895, dated November 5,1986) identified this same deficiency. This item is identified as Licensee Identified Violation (LIV - 328/86-62-14) and no notice will be issued. Followup review of the corrective action for this item is identi-fled as Inspector Followup Item (IFI 328/86-62-15).

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