IR 05000327/1987040
| ML20236W815 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/29/1987 |
| From: | Baker E, Gilray J, Hooks K, Hubbard G, Leu K, Napuda G, Pierson R NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20236W802 | List: |
| References | |
| 50-327-87-40, 50-328-87-40, NUDOCS 8712080248 | |
| Download: ML20236W815 (43) | |
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< UNITED STATES NUCLEAR' REGULATORY COMMISSION ' ' ' ,
OFFICE 0F SPECIAL. PROJECTS
:TVA PROJECTS DIVISION '
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'lI i R'eport Nos.:~ 50-327/87-40 and_50-328/87-40'
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, Docket Nos.: '
50-327 and 50-328
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iLicensee'Nos.: DPR-77 and DPR-79-Licensee:- -Tennessee Valley Authority 6 North 38A Lookout Plac Market Street-
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Chattanooga,. Tennessee 37402-2801 ,j
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Inspection Conducted: --July 13-24, 1987 .{
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ilnspectors: . -
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G. T. Hubbard, Inspection Team Leader Date 51gned- J o
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BhdSBdn E.. T. Baker, Senior Reactor. Engineer
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.:W. Gilr , Quality Ars Jrance Engineer Dath Signed f ( MW // L1
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K. C. Leu, Reactor Engineer Wln M/8.V/?7 D6te 51gned .
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s fit & ')0 2 5f$'l' K~ R. Hooks, Reac$4r Operations Engineer lDate Signed
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Consultants: . D. L. Harris, W. Hansen, M. H. Juister, 5 B. E. Scanja, D. H. Schultz y, . Approved By: 4/ , 1A //)? 8[' J[- ' R. C. Pierson, Chief./ Date Signed l
* PlantLSystems Branch I
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8712080248 871130 W PDR ADOCK 05000327 j .. . G_ ' PDR l
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' INSPECT,10N SUMMARY Inspection on July 13-24,~1987 (Inspection Report Nos.: 50-327/87-40 and 50-328/87-40)- Areas Inspected: Announced follow-up inspection to review the licensee's corrective actions relative to findings identified during NRC Inspection Nos.: 60-327,328/86-61 (Piece Parts Procurement) and 50-327,328/86-68 (Safety Systems Outage Modifications (Installation)). The inspection also reviewed Sequoyah's Critical Structures, Systems, and Components (CSSC) List, two Open Items from NRC Inspection Report 50-327,328/86-11 Quality Assurance Program, and Conditions Advserse to Quality Report (CAQR) Progra Results: The inspection determined that TVA/SOM is taking corrective action with regard to procurement deficiencies identified in Inspection Report 50-327,328/86-61 through the implementation of the Replacement Items Program (RIP) and changes in the TVA and Office of Nuclear Power organizations and procedures. However, the inspection identified concerns relative to corrective action in the areas of seismic evaluations of replacement parts for seismically qualified eauipment, dedication package preparation for purchase parts, inspection instructions for receiving inspectors on purchased parts, and TVA's resolution for approximately 3000 missing I maintenance requests (MRs) identified by RI The inspection also determined that TVA/SQN is taking corrective action on the violations in the Safety the TVA admitted Systems deficiencies Outage Modification supporting (SSOMI), Inspection Report Inspection 50-327,328/86-68. TVA denied 51 deficiency examples supporting the report violations. Nine of the denials were accepted. Thirty-eight of the denials were not accepted; however, since documentation was now available to resolve the deficiency examples, the inspectors closed the thirty-eight denials. TVA's denials of four other deficiency examples were not accepted and they remain ope The inspection identified no deficiencies in SON's CSSC List, Quality Assurance Program, and CAQR Program; however, the NRC did make { recommendations for improvements to the CSSC List and the CAQR Progra ; Details of the recommendations are provided in the inspection repor i
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Items Remainina Open from Previous Inspection Reports I Inspection Report 50-327,328/86-61 !
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Potential Enforcement Findings: Failure to Take Adequate Corrective Action 50-327/86-61-01; j in Procurement of Safety-Related Equipment 50-328/86-61-01 and Storage and Retrieval of QA records l Procurement Implementation items: l Normal Feed Breaker to Reactor Vent Board Paragraph 6.b.3* 2B-B (2-BDC-201-J0-P)
* Note: Refers to paragraphs of 86-61 report.
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' m ~3 ; 2:- ' AuhiliaryRelayin6.9KVShutdownLogic l- Paragraph 6.b.4 ^ Relay. Cabinet 2A-A (2-PNLB-202-SC-A) 4
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3; ' Diesel Generator Air Start Motors ,
. Paragraph 6. . . : Shutdown Boa'rd 2A-A Logic. Relay Panel , Pa,ragraph 6 ~(2-BDA-202-CO-A)
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s ~ Inspection Report 60-327,328/86-68 ,, Violations: ,
> ' Failure to Include ASME Requirement's'in Purchase 50-327/86-68-01; Requirements for SR Equipment ,
50-328/86-68-01
. ' Issuance and-Installation of Nonconformin /86-68-02;-
Material ' > 50-328/86-68-02 Failure to Maintain Records for Equipment 50-327/86-68-03; Identification 50-328/86-68-03 Failure to Install'or' Modify. Equipment- 50-327/86-68-05; per Requirements 50-328/86-68-05
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5.: Receipt-Inspection of Equipment .Not 50-327/86-68-06;. Meeting, Purchase Requirements 50-328/86-68-06 Inadequate Implementation of Document Control 50-327/86-68-07; Procedures 50-328/86-68-07.- Deficiency:
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Installation Different from Flow Diagram D-2.3-5
~ Unresolved Items:- Potential Installation of Non-EQ Valves U-2.1-1 Possible Improper Upgrading of Bou'rn's Trimpot U-2.1-2 Resistors Non-qualified Valves Installed In Seismic U-2.1-4 Locations 4. . . Missing Snubber Test and Procurement Documentatio U-2.1-5 6 HVAC Duct Installation in Fifth.125Y Battery Room U-2.2-1 s ( '6.- Failure to Include Vendor Instructions in Work U-2.3-1 l Procedures .j 7. . Possibly Reworked Pipe Support Welds with No U-2.4-1 Documentation i .
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- 4 -- ' , o! . , :n b s 8hs ' Unknown- ThiNkness of' Flamemastic on- Power 'U-2.4-2 Cables and:Its.Effect on Ampacities J '
U : Unknown'EffectonBearingPressureon'C1hssiIE- LU-2.4-3 1 Cables'in Unsupported Vertical Bundlesi i >-
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'10$ Question on Concrete Expansion' Anchor Sizes U-2.4-4 11b -Effect of Loose' Control Room Electrical Panel U-2.5-1 Doors on Seismic' Qualification
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'I Open Items:
" ' Lack of Controls.to Properly Identify and 0-2.1-1 Segregate Material Storage Areas 2.- Root Cause 'of Valve Damage Not Identified - 0-2.5-1 No Evaluation of Maintenance Deficiency 0-2.5-2
: Vendor Instructions Not Included in Site 0-2.5-3 Work: Procedures l-
' Root Causes of Hardware Failures No .5-4
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{ QA/QC. Coverage of Modification Work 0-2.6-1 .Two-party Verification of Maintenance' 0-2.6-2 inactivities New Items:
Unresolved Item: 50-327/87-40-01;
~ Adequacy'of. Seismic Evaluations of Replacement. Parts for Seismically 50-328/87-40-02 Qualified Equipment Inspection' Follow-up-Item: Verification of Seismic Tasks Completion 50-328/87-40-01 . : Dedication Package Preparation, 50-327/87-40-02; Inspection Instructions for Receiving 50-328/87-40-03 Inspectors,'and Missing MRs j
3, Walkdown Inspection Observations In Fifth 50-327/87-40-03;. Vital. Battery. Room 50-328/87-40-04
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,. .- DETAILS 1.- ATTENDEES AT EXIT MEETING ;1.1 . Tennessee Valley Authority (TVA)~
H. L. Abercrombie, Sequoyah Site' Director
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J. T. LaPoint, Deputy Site. Director n T. Chiles, Assistant to Director, Planning.and Financial Staff-R. Hansen, Nuclear Engineer
.C. McWherter, Chief, Materials and Procurement. Services (MPS)
N. C. Kazanas, Director Nuclear Qu'ality Assurance R. Cook,-Licensing Enginee T. J.'Arney, Quality Assurance . . G. C. Wilkerson, Manager Sequoyah (SON) Purchasing J. D. Beavers, Watts Bar (WBN) Materials
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V. L. Bradford, MPS Secretcry D.~Michlink, lead Procurement Manager A. P. Capozzi,. Engineering Assurance T. 'E. Spinks, Project Manager, SQN. Replacement Items Program A. H. Ritter, Engineering Assurance 1 Engineer-G. B.' Kirk . Compliance Licensing Manager R. C. Parker, Quality. Assurance C. R. Brimer, Assistant Project Engineer I. V. Holt, Browns Ferry (BFN) MPS T. J. McGrath, Assistant Site _ Representative - Office of Nuclear
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Power (ONP)- L'. E. Martin, SQN Site Quality Manager L..J. Wheeler, SQN Materials Manager W.. Horn, Modifications
. A..M.'Qualls,~ Assistant to Plant Manager .R. H. Buchholz. . Site Representative .0NP L. M. Nobles, Plant Manager ,
D. Scheide, Licensing Engineer 1.2 Consultant J.-M. Abeles, Vice President Operations, DiBenedetto Associates 1.3 NRC K. M. Jennison, Senior Resident Inspector R. Carroll, Region II Inspector
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R. C. Pierson, Chief, Plant Systems 0.anch
-6-2,0 Procurement Inspection Follow-up 2.1 ' Background In September 1986 an inspection of Sequoyah's procurement activities was performed and documented in Inspection Report 50-327,328/86-61-(hereafter known as'86-61). The inspection was conducted to review corrective actions taken to resolve findings-noted in TVA Nuclear Safety Review Staff (NSRS) reports R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS. The NRC inspection verified the findings noted in the NSRS reports, e.g., using commercial grade items in safety related applications without determining whether the item was suitable for its intended application; inability to retrieve documentation in a timely manner; and inadequate instructions for performing receipt inspection. The inspectors also determined that TVA had failed to take corrective action-concerning the NSRS finding In response to the NRC's inspection TVA developed the Replacement Items Program, created the Materials Management organization, reinserted engineering into the procurement cycle by forming the Contract Engineering Group, established a corporate level Maintenance Maneger, and initiated major revisions to the ,
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procedures governing procurement, receipt inspection, and - engineering. evaluation of replacement item .2 Scope This inspection was conducted to ascertain the extent and_ adequacy of TVA's corrective action taken in response to Inspection Report 86-61. This inspection included a review of the Replacement Items Program, the ability of Sequoyah's new procurement organization and implementing procedures to supply the plant with the correct replacement parts after restart, the relationship between TVA's l Office of-Nuclear Power (ONP) and Purchasing, and TVA's actions to close out findings noted in Inspection Report 86-6 .3 Findings j-2. replacement Items Program ] The Replacement Items Program (RIP) was established to review all maintenance requests (MRs) generated since the start of plant power ! operations to determine which pieces of equipment, if any, were ) degraded by the installation of commercial grade items. Three 1 methods of installing replacement parts were identified; MRs, work requests (WRs), and trouble reports. RIP identified apprcximetely 192,000 MRs and WRs (hereafter referred to as MRs) and approximately 5,000 trouble report I
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The MRs were entered into a ccmputer data base to facilitate tracking and sorting. MR categories were established and lists compiled for analysis and action on replaced item The MR categories included: cancelled; non-plant systems; no historic value; non-safety-related system; non-design basis verification system; non-Unit 2 systems; no parts replacement involved; non-safety-related equipment; non-10 CFR 50.49 equipment; and parts installed in non-safety-related ! application Trouble Reports (TRs) were each reviewed manually by RIP personnel to sort out those that did not involve Critical Structures, Systems, and Components (CSSC) and did not involve work on Unit 2. Because a different system of categorization and identification was used when TRs were in use, the NRC inspectors identified several errors that were made by the personnel performing the sorting. The l categorization of TRs was reviewed again by RIP personnel and the error was corrected. Those TRs involving replacements in CSSC systems were entered into the computer data base for further evaluatio Samples of MRs were selected for NRC review in each categor The NRC review corroborated correct segregation and appropriate analysis in each category. One isolated mis-tabulation was noted and attributed to an error in number transposition. A tabulation of MR category totals, sample numbers, and results is shown in Table TABLE A q Tabulation of TVA Work Requests by Category:
Category of Maintenance Approximate Number of l Work Requests Work Requests NRC Sample Size Cancelled 11,000 12 Non-Plant 8,000 10 ; No Historical value 49,000 10 l Non-CSSC System 42,000 50 i Non-Design Basis & 15,000 50 ;
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Verification Non-Unit //2 30,000 50 Non-Parts Replacement 19,000 25 ' Non-CSSC Equipment 12,800 25 Non-10 CFR 50.49 12,000 25 Remaining: (10 CFR 50.49, with parts in safety-related application) 1,095
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In performing the component level sort between CSSC and non-CSSC components, problems in 2.of the 25 MRs reviewed were noted. Sequoyah Administrative Procedure SQA-134. " Critical Structures,. Systems and Components (CSSC) List" was used as the basis for determining whether a component was properly classified. As indicated by the two examples below, the-guidance in SQA-134 is not sufficient, by itself ' to properly classify a component and is sometimes contradictor MR A095259 resulted in the replacement of boric acid evapo-ration and gas stripper package "B" concentrate pump 2 on i February 10, 1984. This MR was classified as non-CSSC by the RIP. team. However, SQA 134 page 10 of 16, item 18.3 indicates that " Pumps.(Except Primary Water Makeup Pumps and Monitor Pumps)-(Caustic Pumps)" in the Chemical and Volume Control System-(System 62) are CSSC Components. Iten 18.15 in SQA 134 (same page) states that " Boric Acid Evaporators are not CSSC."
It continues to describe a non-CSSC package boundary which the licensee has interpreted as including the concentrate pumps because the entire package was provided as a skid mounted unit. However, the piping associated with the pumps is class
"D" piping which is normally used in CSSC system MR 8112558 concerns the replacement of a defective power supply and defective point cards in the control room annunciator system on Panel M-21. These components were determined to be non-CSSC. However, note 1., Electrical sub-paragraph c., states that indication and alarm circuits in the control room or auxiliary control room e~e CSSC. The licensee states that the system is CSSC up to the components in question, i.e., the readout and readout drivers in the control room. The reason that they are non-CSSC is because they were not procured as safety equipment at the time of plant constructio While the equipment in both cases was determined to be properly classified as non-CSSC, SQA-134 by itself was inadequate and in certain cases contradictory :n providing guidance on classification at the component level. For further discussion of the CSSC list and SQA-134 see paragraph The overall result of the review verified that the search for installed parts which had the potential for not meeting environmental qualification requirements was made conscientiously and thoroughly by TV For those MRs which replaced items which could effe.:t seismic ;
or environmental qualification, the RIP group performed data searches and analyses to establish whether items previously procured could be ascertained as either not requiring qualification or, if required, were in fact properly qualified. These reviews were given the name " Previous i f I - a
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u ,~ . . ProcurementLSubstantiation Packages" (PPSPs). -Forty-two?
. > - PPSPs k representing.114' MRs were. reviewed .by- the NRCi tea 'PPSPs: consisted'of three types: ,those. involving items . determined by analysis to not- have safety-related functions,.
those established as involving items actually supplied:a l meeting qualification requirements although!not ordered. that , . way,:and those involving items.which TVA could dedicate by:
. performing certain inspections . tests .or analyses. In the-course of performing the NRC review, RIP engineers who prepared the packages.and QA engineers who. reviewed them were interviewe " > Thel inspectors found that many of..the procured items.were shown to be procured from suppliers who fabricated.them as qualified-items, even.when TVA' procurement contracts did not:
so require. uThe NRC review determined that Technical
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Instruction, TI-104, " Installed Items Verification for' Critical: Structures,. Systems and Components Equipment," and
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the 42 PPSPs reviewed were satisfactory' . In.additioncto.the.MRs' discussed above, TVA identifie approximately 3,000 MRs which could not be located fo evaluation. At'the time of the inspection TVA had not
- determined how they. would address these missing MRs. .The
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4 NRC will review TVA's action concerning these MRs as part of
. the new procurement ' inspection follow-up item described in , paragraph .3. Effect on Seismic Qualification 4 All:MRs which were. identified as' replacing ' items in CSSC - equipment were also reviewed for their effect on seismic qualification. Sequoyah' document.CEB-87-09, Revision 1, dated June 12, 1987,- titled."A. Report of the Seismic Review ' Activities'," developed by the Sequoyah RIP contained.the results obtained.by the seismic group of. RIP.' The RIP activities conducted invclved a' seismic review of past maintenance replacement items that had been purchased as commercial grade without documentation of their qualification or adequate dedicatio The RIP seismic group utilized an earthquake experience data-base as the primary criterion for performing the seismic review of maintenance activities involving the replacement'of parts. TVA's Technical Instruction,-TI-108, " Instruction.for Assessing the Seismic Sensitivity of Maintenance Activities Involving Replacement Parts," was prepared by TVA's Civil EngineeringBranch(CEB)'anditsconsultant, Earthquake !
Engineering, Inc. (EQE) to implement the use of the experience data base. It contained procedures and criteria for classification screening, seismic sensitivity screening and engineering evaluation of maintenance activitie SQN seismic review activities involved a total population of : approximately 36,000 past MRs. About 28,000 MRs were found to involve replacement parts and 11,000 of those MRs involved CSSC component f h--m_ _ __ _ . _ . _ . _ .
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The, RIP review indicated that 5595 MRs were disposi-
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tioned " acceptable" by.the classification screen; 4912 MRs were dispositioned " acceptable" by the seismic screen using the experience' data base; 520 MRs were dispositioned
" acceptable" by further information evaluations by CEB; and 13 MRs required field inspections. No replacements were determined to~ adversely effect seismic qualificatio .2.1. MR Sample Review The inspector randomly selected 50 of the 11,000 MRs.for review to determine whether the replacement activities performed by the liceasee degraded the seismic qualification of the equipmen Seven MRs selected were not available, because they were still being reviewed. Seismic screening guidelines contained in TI-108 were used as a reference to determine the seismic sensitivity of maintenance activities and replacement items for the remaining 43 MRs. MRs that vere determined to be potentially seismic sensitive were subjected to further engineering evaluations by the inspecto Review of 39 of the MRs indicated that the maintenance activities were primarily related to items such as: flange insulation repair, painting, pump oil change, conduit seal, valve bolt replacement, dissemble / reassemble of valve, etc.,
and therefore were seismically non-sensitive and would not have affected or degraded the equipment qualification The following four MRs were determined by TVA to be not seismically sensitive. TVA's basis for eaching this conclusion was that in reviewing the earthquake experience data base, these replacement parts "did not affect any aspect of the equipment related to sources of damage in past earthquakes." MR number A-299-409, dated February 19, 1985, involved the replacement of a GE panel meter in the diesel generator (D/G) distribution panel, ,1978, replaced defective TR number excitation 01563 surge dated January (CR1 through CR12 on suppressors 45N767-1) in D/G 18-B and 28-B and a bracket in D/G 28- MR number 20690, dated July 27, 1979, invc1ved replacement of an output relay to a temperature swk 2 on an instrumentation control panel, i
, MR number A-5-29910, dated July 17, 1985 removed and )
installed an air receiver tank drain valve (piping component) in D/G room 1 : ______ J
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- 11 - ,. .' This one sentence justification was not considered adequate documentation that the item would function during or after a seismic event. The justification is; based on inspections of equipment which experienced a seismic event and was found to .be undamaged and capable of functioning. The NRC inspectors (
were concerned as to whether the replacement items would function properly during a seismic event and not prevent safety related equipment from performing its intended- -l function. This concern was discussed with the licensee and 1 his consultants. However, neither party appeared to 1 understand the concern because the response the NRC inspectors received was always the same; "the equipment was not related to sources of damage observed from past earthquakes." q
In a' letter from TVA, dated August 14, 1987, which supplied j additionel information concerning use of the seismic y i screening criteria, TVA referenced and enclosed a copy of a ! portion of a paper prepared by EQE, titled, " Summary of the- l Seismic Adequacy of Twenty Classes of Equipment Required for ' ' j the Safe Shutdown of Nuclear Plants," dated February 198 ' On page 5 of the enclosure an example appears which confirms the NRC inspectors' concern that the earthquake experience data base was being interpreted incorrectly when applied to a 1 component's effect on a system when subjected to a seismic { event. A quote from the enclosure follows: ; a
" INSTANCES OF SEISMIC EFFECTS AND DAMAGE 'j
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The experience data base contains one instance of seismic effects to instruments. There are no cases of *
seismic damage to instruments, the racks themselves, or to attached tubing or wirin ) At Steam Plant Number 3 on Adak Naval Station, affected i
by the 1986 Adak Earthquake, two' pressure switches were tripped (Figure 23-14). During the earthquake, l vibration of the internal push rod caused the actuation i of diaphragm-type sudden pressure switches on two of the j boilers. These sudden pressure switches are on a
"%ir-trigger" and are easily actuated by vibration '
The actuation of the pressure switches tripped an auxiliary relay, which in turn tripped the MCC controlling the boiler fan motor. There was no damage .; to any of the equipment in this syste No instances of seismically-induced damage to instruments, racks, or attached tubing and wiring were found in an extensive literature search and telephone survey." -
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. 12 . ; , ' -Here isLa clear example of a seismically sensitive item', th ' pressure switches, causing.significant-system perturbations ,being dismissed because there was no damage to equipmen There was no apparent consideration of the effect on the i equipment of the unavailabili.ty of the. boiler fan motor'ifL the equipment would have been. called on'to operate.during or 2-' after the earthquake. It is this: failure of the earthquake -
experience; data base to address operationalitransients that- :
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'As indicated.th CEB-87-09, Revision 1, dated June 12, 1987,- H
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13 MRs were unable'to be dispositioned by further engineering ( evaluation by CEB. As a result, field walkdown inspections-were conducted to address the item's effect.on seismic- ., qualification. Nine MRs from the 13 were picked.by'the NRC ! inspector to field. verify the installed conditions. .The 1 inspector was' accompanied by an engineer from E0E.
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' ' MR number 48482, dated April 17, 1979, was initiated t . fabricate and install a pipe hanger on a waste disposal system line within the Auxiliary Building. The-
, piping is class G-according to " General Design Criteria ' for the classification of piping, pumps, valves, and vessels," Revisioa 1,.cated December 12, 1975; The
. supports for "G". piping.were to TVA drawing 47A058'
series;. The, inspector inspe_cted the piping condition as ', well as the ; support plate' and anchor bolts. and found-them satisfactor The pipe hanger was installed because of too much movement'of the piping, according to the' description of work requested. The inspector therefore requested to see the original piping design drawings to.. verify , whether a support was originally installed at the '
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location. of the new support. The licensee was not able to locate the drawings, but stated that this system was part of the design reconciliation effort which would resolve this issue prior to restart. This item will be followed-up during a future inspection, MR number A-112166, dated October 27, 1983, UHI Room: Fire pump starter switch and its associated conduit were relocated... The NRC inspector observed adequate panel anchoring. However finger clamps were missing from the conduit resulting in a 13. foot unsupported vertical span. The missing clamps should be reinstalle Note: Verification of a. and b. above is identified as inspection follow-up item 50-328/87-40-0 MRs 64808, 080272, A-043245, A-108323, 112696, A-119664, and A-238002 were also reviewed and found to be correctly classified as non-sensitiv ; - _ _ - _ _ _ _ - _ .
- 13 - , . Because the issue of the appropriateness of using the earthquake experience data base is still not resolved, all seismic issues involving seismically sensitive equipment are consideredanunresolveditem(50-327/87-40-01;50-328/87-40-02).
2.3.2 New Procurement Proaram As part of the corrective action taken in response to 86-61, TVA established a new procurement organization and is
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revising procedures covering procurement and associated inspection .3. Organization Within the Office of Nuclear Power {0NP), TVA has established a Materials Management organization consisting of warehousing, engineering, quality engineering, expediting, and contracts ' personnel. The warehousing personnel are responsible for determining what material is needed, when to purchase it, and preparing the purchase requisition. Engineering personnel are responsible for reviewing all purchase requisitions and assuring that all required technical requirements'are included, deter-mining at what quality level the item should be procured, and determining receipt inspection requirements. If an item is being procured commercial grade, for a safety related j application, engineering personnel determine what the dedication actions must be. Quality engineering reviews the f technical and qudity requirements established by engineering.
' Contracting personnel then prepare the procurement request and obtain authorization to purchase the item. The request, including all technical and quality. requirements, is then forwarded to the central purchasing organization to actually solicit bids and award the contract. However, purchasing has-no authority to modify the technical or quality requirements and must place the order with an approved supplier. With this reorganization, TVA has reinserted engineering into the procurement process and consolidated control of technical and quality requirements contained in procurement documents within DN .3. Procedures At the time of the inspection, TVA had not completed the i revision of all the procedures covering procurement and l associated inspections. The sections of the Nuclear Quality Assurance Manual (NQAM) covering procurement; Part I, Section 3.4 and Part III, Section 2.1 had been revised. These sections were reviewed by the inspectors and appeared to be acceptable as general guidance normally found in upper tier documents. However, the implementing procedures; SQA-45,
" Quality Control of Material and Parts and Services;" AI-11 " Receipt Inspection, Nonconforming Items, QA Level / Description Changes and Substitutions;" AI-20. "QC l l
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- _ _ - _ - - - - _ - _ _ _ - 14 - . . Inspection Program;" and the TVA SQN Inspection Plan were not considered acceptable at the time of the' inspection. The inspectors' review of these procedures determined that ..
sufficient guidance concerning what characteristics should be inspected and what the acceptance criteria were, was not being provided to the TVA. receipt inspectors. The lack of guidance was a result of inadequt te procedures. Examples to support this conclusion appear below in the discussion of dedication
' Group (CEG) and packages reviewed byprepared by the Contract the NRC inspectors. It should Engineering be noted that, TVA was already preparing revisions to these procedures at the time of the ' inspection; however, the revisions had not been' completed. These revised procedures will be. reviewed during a follow-up inspection to determine tne effectiveness of the procedure .3. Review of Dedication Packages Prepared by CEG From a total of 322 purchase requisitions and 94 dedication packages (DPs) prepared by CEG, the NRC inspectors selected a sample of 17 purchase requisitions and 18 dedication packages to review. A single dedication package prepared by the Inventory. Evaluation Section (IES) was also reviewed. No problems were found with the 9 QA Level I and the single 0A Level III purchase requisitions reviewed. However, problems with 5 of the 7 QA Level II purchase requisitions were identified. All five requisitions 0706106, 0720120, 0616116, 0506125, and 0429105 had the same basic problem, inadequate instructions to the inspector on how to accept the items for use in safety-related application Of the 18 dedication packages reviewed, 4 were excellent, 3 were acceptable, I had been cancelled and 10 were unacceptable. A summary of the packages follows:
DP5027, Socket Head Cap Screws; DP5116, Bolts, Cap Screws, Studs; DP5127, Machine Screw Nuts; DP5098, Valve Adapter Bushin All four of these packages were excellent. The critical characteristics called out truly represented attributes which were critical to the items performing their function and the inspection requirements provided instructions to the inspector on how to verify the critical characteristics and how often. However, due to poor general administrative instructions and a lack'of training in using the dedication packages, the receipt QC inspector did not perform the proper
- inspections on the valve adapter bushing even though dedication package 5098 was correc DP5082, Fuse Block; DP5118 Brazing Rods; DP5050, Capacitor These three dedication packages were found acceptabl !
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DP1001, Graphite Tape; DP5012, Compression Connector; DP5016, Bolting; DP5023, Resistors; DP5037, Fuses; DP5053. Pulsation Dampner; DP5067, Pressure ~ Transmitter; DP5093, Damper;- DP5101, Fuses; DP5128, Terminal Lug .These ten packages were found unacceptable. DP5053 was found
. . inadequate because the critical characteristics-did no include a check of functionality. DP5067 was found unaccept-able because the. item was classified as QA Level II yet the item was being ordered under a N45.2 quality assurance program. DP5093 was found unacceptable because the drawings ~
furnished to the inspector did not have tolerances on the dimensions and the written instructions.did not provide , acceptance criteria. The remaining packages were found ! unacceptable because either the inspection criteria. called out did not match the critical characteristics listed or the things listed as critical characteristics.were in fact only l an item descriptio .J i The fact that'in 4 cases the dedication packages prepared were considered excellent shows that the system can work; however, better procedures and better training are needed to . ensure that the dedication is performed correctly all the ; tim ;
The revised procedures and an additional sample of: dedication ] packages will, be reviewed during a future inspection to j
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verify adequate; implementation of the progra '2. Potential Enforcement Finding from 86-61 86-61-01-(0 pen):'1TVA's corrective actions relative to l this potential enforcement finding in the areas of j procurement and receipt inspection of safety-related equipment are discussed in paragraphs 2.1 and 2.3. The NRC's evaluation of TVA's corrective actions-are discussed j in paragraph 2.3. TVA's corrective action with regard to ! the area of the finding concerning storage and retrieval of quality assurance records is discussed in paragraph I While the NRC's evaluations have determined that corrective action is being taken, except as stated, TVA is still subject to possible enforcement relative to this findin This' finding remains open pending a decision regarding enforcement.
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2 3.4; . Specific Procurement' Implementation Findings from 86-61 Listed below is the status of the examples cited in paragraph 6.b. of 86-6 . Steam Generator Level Solencid Valve (2-LSV-003-174)
(Closed)
Planned reviews of all issue. slips by IES prior' to - issuance should prevent QA Level 11 material from being used in maintenance on EQ equipmen . Roactor Trip Bypass Breaker (2-BKRC-099-KH/319-G)
(Closed)
TVA was able to supply ' documentation that the undervoltage
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trip attachn.ont was qualifie . Normal Feed Breakers to Reactor Vent Board 28-B (2-BDC-201-JQ-B)(0 pen) The licensee's response'to the issue.was contained in a document CEBRIP-SON 2-113. Revision 0,' dated May 12, 1987, which stated that the primary activity.of the MR involved the replacement of a breaker in the Motor Co'ntrol. Center (MCC)'and did not affect any aspect of the equipment related to the sources of damage in past earthquakes. The replacement part was evaluated by the licensee in accordance with TVA.Sequoyah'TI-108 and was found to be not seismically sensitive. Since the licensee'did not provide any documented evidence of qualification for the trip unit other than using the seismic experience data base for seismic qualification of the part and the previously stated concern over system perturbations, this: item remains ope .- Auxiliary Relay in 6.9KV Shutdown Logic Relay Cabinet , 2A-A (2-PNLB-202-SC-A) (0 pen) -] Additional information has been received concerning the i
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qualification of the MG-6 relays. This information will be reviewed and covered during a followup inspectio ! l BoricAcidTransfer(BAT)PumpMotor(2-MTRB-62-230-A) j (Closed) This issue involved a replacement BAT pump motor- ) i
. installed on January 13, 1983, with no documentation to -)
' support qualification of the pump moter. SQN document 1 SQEP-12-12 " Class 1E Seismic Qualification Westinghouse j Motor Frame 254T," Revision 0, dated December 1986, attached to a Westinghouse Letter TVA-86-747, dated , December 1986, addresses the seismic qualification of l i
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, , - .. the Westinghouse motor.for the. BAT: pump.. The. letter contained a' BAT pump.seismicianalysis: summary which-
,7 , j -L ' providedlthe stress; calculation-at' various locations'on ,. the motorf and the frame? ' locations such asiwater pump' i* j > ,
"- Ltie2down bolts, anchor bolt,[ shaf t, frame, nozzle. flange. -
' motor / pump bearing etc...were included and the ,
! calculated stresses at these locations 1were'below the:
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specified allowable ' stresses.s In addition ;the!1etter also indicated thatLthe BAT; pump'had,been seismicall ,
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._ analyzed to13.0g and 2.0g-for;the; horizontal and-verticalsdirections whereas:the required seismic leve '
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"at; the equipment' level!(EL.690 Auxiliary Building),was- '
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approximately 1.1g.in.the;E-W direction.
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'The licensee further stated;thatl the: replacement motor-
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supplied under the NSSS contract with Westinghouse.- fThe engineeringJanalysis and calculations'by ..
! Westinghouse.provided documented evidence that the: l m ,
' replacement BAT: pump motor _ (2 MTRB-62-230A): had not-
, degraded the; seismic qualification.- This item is , " < , considered resolve w 6.- 'Diese1L Generator- Air Starter Motors (0 pen) T'he' licensee responded that the'.seismicLexperience data
- base and a broad range of. industry experience indicated -
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L < that-the motors are very rugged- pieces of equipment 1 ' which are not seismically sensitive. The licensee also L' '
' stated that functional! tests performed on the mcl.or and l the. periodic diesel surveillanceJtesting ensure'the
,1 functional and: seismic qualification'of the motor since the normal' vibrations. encountered bylthe air starter-motors during the starting of. the diesels.is-more Lsevere -
-than theiseismic qualifications would dictate, i'
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Early in.the' inspection the' licensee stated ~that a start test was scheduled and the NRC inspectors requested.to' observe thettesting to witness the. severity of the- j
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, b vibration. However, the schedule for.the test. slipped j andlthe NRC-inspectors were not able to witness the- Q tes ;j o < K~ ,s In the written response to the 86-61 finding, th * licensee used experience data as a basis:for claiming j L seismic qualification of diesel generator air starter :! E
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motors. This. item remains.open since no documentation ! l:E . W y of qualification was presente j
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F u - l Shutdown' Board 2A-A Logic Relay Panel (2-BDA-202-CO-A)
(0 pen)
Additional ~informationhasbeenprovidedontheAgastat relays in. question. This information will be reviewed and covered during a followup inspectio . Containment Isolation Yalve (2-FCV-32-103) (Closed) ; i Changes made to clarify the . requirements for shelf life ! items and preparation and review of procurement i requisitions should provide adequate corrective actio J Control Valve (2-FSV-32-1031) (Closed) J Based on available documentation, TVA was'able to show .j this valve was qualified. Changes being made to the - procurement program should prevent QA Level II equipment ~ J from being used in EQ application's without adequate dedicatio q
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2.4 Summary Based on the reviews and evaluations perfomed in the areas of procure- { ment by the inspectors, the NRC determined that TVA and SQN are taking i corrective actions to ensure that past and. future-procurement 1 activities do not adversely affect safety-related equipment and the safe 1 operation of?the plant. While the RIP corrective actions for environ - j mentally qualified equipment were found to be acceptable, the corrective 4 actions being taken for seismically qualified equipment were-considered i
. inadequate for ensuring qualification to SQN seismic requirements of l'
IEEE-344. Resolution of seismic concerns is identified as an unresolved item-(reference paragraph 2.3.1.2). 1 The NRC determined that positive changes.are being made in the l procurement process at TVA and SQN through organization and procedural i changes. 'dased on the inspectors reviews and evaluations, the NRC considered that the new procedures and controls governing the relationship between ONP and TVA Purchasing were adequate to ensure
.that nuclear material and equipment (including replacement parts) met i appropriate nuclear requirements. While changes were in process, the-NRC inspection identified concerns in the areas of procurement dedication package preparation and inspection instructions for receiving; inspector !
Resolution of concerns in these areas of the new procurement program,
' 'as well as.TVA's resolution for the approximately 3000 missing MRs (see paragraph 2.3.1.1) is considered an inspection follow-up item 50-327/87-40-02;'50-328/87-40-03.
! The inspectors reviewed TVA's corrective action relative to Potential l Enforcement Finding 86-61-01; however, it remains open pending possible , enforcement action (see discussion.in: paragraph 2.3.3). The inspectors
^
reviewed nine items identified as procurement implementation problems i ,
.in NRC Inspection Report 86-61.and were able to'close five of the nine H items. The other four items remain open pending resolutio , - - - - - - - - - . _ - _ _ _ , . _ _ _ _ _ - . _ - - ._m_.-________m__________,__.,_,_,____m,.,,___m
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3.0 Safety Systems Outage Modification (Installation) Inspection Follow-up 3.1 Background The NRC conducted a modified Safety Systems Outage Modification Inspection (SSOMI) December 1-12, 1986 and January 12-23, 1987 at Sequoyah. The results of this inspection were documented in NRC Inspection Report Nos. 50-327,328/86-68 (hereafter known as 86-68),datedApril 24, 1987. This report identified seven violations of criteria in Appendix B to 10 CFR 50. ' Additionally, the report documented a number of other inspection findings which were identified as unresolved items or open item On July 9 and 16, 1987, TVA responded to the violations identified in the report. In the response, TVA addressed 90 specific ; deficiencies oc subparts thereto which were identified in the inspection report as suporting the seven violations. TVA admitted 39 of the 90 deficiencies and denied the remaining 51. This inspection was a follow-up to the modified SSOMI inspection to review the actions SQN'has taken to address the issues identified in the inspection repor .2 Scope The initial focus of this inspection consisted of a review of the 51 deficiencies denied in the TVA response to the inspection repor This included a review of TVA's basis for denying the deficiencies and making a determination by the NRC inspectors as to whether TVA had a valid basis for denying each deficiency. Following review of the denied deficiencies, the inspectors reviewed the deficiencies which were admitted by TVA to determine if adequate corrective action had been taken or was planned. During the inspection, the inspectors did not review any of the items identified in the inspection report as being unresolved or open items. Review of the deficiency admissions not closed during this inspection and the unresolved and open items will be performed during a future NRC inspectio .3 Findings 3. Violation No. 1: (0 pen) Failure to assure that applicable ASME Code requirements were included in the procurement of specific safety-related code class equipmen Example a.: Isokinetic probes, which are used to collect post-accident air samples, and which should have been purchased to ASME Code Class 2, were in fact purchased to non-code requirements, thereby eliminating requirements for certified material test reports (CMTRs) and other quality verification (Deficiency D-2.1-3).
, um-m ___ _ _ _ _ _ _ . _ _ _ _ _ _ _ __ _ _ _ _ _
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- 20 - . .- While TVA responded that the procurement of these components as non-TVA Class B and the subsequent field change request (FCR)
approval did not result in a violation, TVA admitted that the violation that did occur was that documentation could not be located to establish seismic qualification of the probe uni Based on the NRC ins Work Packages (WPs) 10615pectors' review and 10616, of TVA " Closure and discussions with the Package" and cognizant engineer for the WPs, the NRC accepts TVA's statement that the isokinetic probes are not required to be TVA Code Class B (although the WPs did require it).
While TVA was unable to provide the inspectors with documented objective evidence that TVA originally planned to have the seismic qualification of the probe components verified and documented by TVA's Civil Engineering Branch as opposed to vendor certification, i
.the NRC determined that TVA's corrective action for resolving the admitted violation was acceptable. Verification of corrective action completion will be performed during a future NRC inspectio Example b.: A cavitating venturi, which is located at the discharge of Auxiliary feedwater Pump 2A-A, and which is required by the purchase specification to have an ASME Code N stamp, in !
fact does not have an ASME Code N stamp and has no documentation indicating that it was purchased to ASME Code requirements (Deficiency D-2.1-2).
The NRC inspectors reviewed TVA records which demonstrated that tne ASME Code N stamp was not required from the vendor since the welds questioned were performed by TVA onsite. These records were not presented to NRC inspectors during the course of the SSOMI inspection. In fact, TVA personnel told the original SS0MI ,
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inspectors that the welds were vendor welds because TVA could not locate any TVA weld records. Based upon review of the records, this violation example is close Example c.: A stainless steel spiral threaded insert, which is installed in the primary side head of a Unit 2 steam generator, which should have been purchased to ASME Code Class 1 requirements, was in fact purchased to'non-code requirements, with no safety review or other quality verification (Deficiency D-2.1-1).
Based on the NRC inspectors' review of documentation concerning the deficiency and discussions with TVA personnel, the NRC agrees that the TVA procurement of the threaded insert was adequat Therefore, the NRC accepts the denial of this violation exampl The NRC still has some questions concerning the TVA use of the insert and will investigate these questions when unresolved item, U-2.3-1 (failure to follow vendors procedures for installing the insert), is resolved during a future NRC inspection.
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c n ' f , i [ ? "N # L 3:3.2 b'iolation No12: [(0 pen)l Issuance and' installation of-
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* l Example a~.-: Of:1451 diesel; generator fobndation-anchor bolts? .
reviewed by the inspection team,D144 had'no material; .
> Certifications as. required byLthe; applicable safety. classification +
-andL the materia 1 Specification, w' 1
' /f LExample b.: D The majority of the nutsiand bolts used as' fasteners R
7' ' Efor the: battery rackslin Battery roomsi1, 2L an~d 5 did ~not-have c 9' L vendor markings'.or, grade classifications, and' were' not traceable - '
:to material l identifications.-
Example. b. : TRequi red l material i traceabil i tyl documentation coul d h' .' . i not' bexfound for a large number of other' installed items, which
: are' listed in Table IV,;and which include safety iiijection. pump.
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~ ' " ~ , : casing bolts,lanLauxiliary feedwater.. pump; discharge flange,
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battery room, anchor.. boltsi Steam Generator 44. anchor bolts. , ' l valves, snubbers,1 test flangesi and variousFbolting' material ' E <
- Note: The'above' examples areLdescribed under report deficiencies, W ,
~D-2.1 7.and.D-2.1- TVA. admitted;the1violationasrelatedtosamhles 17-1,'44-1,45-l A f "and 46-1 of deficiency D-2.1-7. and samples l 45-2, 20-3, and 21-1 of: . .
: deficiency.0-2;1-8. . The NRC' inspectors reviewed the corrective
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action;for the-above. items and was.able;to close.sampleL21-1 as
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being adequate and complete; The inspectors reviewed the- . corrective action for sample.20-3: and were' ableL to verify that the
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- bolt thread engagement problem was corrected,.but the material grade ' problem had not been corrected.- The inspectors' review of the planned corrective action.for thelmateHa1. grade problem of sample 20-3 identified no concerns; however,- this item remains
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open pendingzverification of corrective' action completion during a future inspection.
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.The inspectors reviewed the planned corrective action for samples-17-1, 44-1, 45-1,L 46-1, and 45-2 and identified no problems. This-items.will remain open pending verification of corrective action completion-during a future inspectio TVA denied the. violation as related to samples 1-2, 3-1, 3'-3, 5-2, 6-2,-7-1, 10-3, 11-5, 12-1, 13-1, 13-3 19-1 19.-3, 19-5, 40-1 of D-2.1-7.and D-2.1-8. The inspectors reviewed specifications, letters cf compliance, material certifications, and'other
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documentation (which was not'provided the inspectors during the .e gw 3:. original. inspection or prior to issuance of 86-68)' relative to m.# these violation samples. Based on the reviews of the new data and ,
* detailed evaluation of the findings, all samples are closed except , ' ,
for sample 1- i y fh
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- , Sample 1-2 pertained to TVA's' failure 'to locate material' '
certifications.for 1-1/8" studs and nuts used in bolting the Auxiliary Feedwater . Pump 2A-A discharge flange to NAVC0 spool piece 2AFD-13.' In the denial, TVA stated that ANSI B31.7C, paragraph 1.732.1.3d did not' require bolts and nuts to have material markings on them once a bolted joint is assembled. 'The inspectors agreed with this; however,.to verify that the appropriate bolts and nuts.were used, the inspectors asked for the bolt records (II-2 Forms) which would verify that indeed the
. connection was' properly assembled. TVA was unable to. produce i: these records during' this inspection; therefore, the TVA denial is . denied and remains ope Example d.: For one case, based on.a limited sample, the internal wiring in a Limitorque valve operator was found to be not qualified to Class 1E requirements.(Deficiency D-2.4-10).
The NRC inspectors reviewed documentation which included purchase requirements,- . vendor certifications for the valve, and maintenance records"to' insure TVA had not changed the wire. Based on the reviews, the TVA discussion in the report response, and discussions with TVA personnel, this item'is close . Violation No. 3: (0 pen) Failure to maintain identification of. items by heat number, part number, serial number, or other appropriate mean Example a.: Since May 1986, 308 and 308L weld rods could not b distinguished from each other in the weld rod ovens at Unit 2 >
(Deficiency D-2.1-9). lJ I
The'NRC inspector ' reviewed the " Closure Package" for this example and discussed the TVA. review with TVA personnel involved in the i review. Based on the inspector's review and discussions, the NRC j considers TVA's corrective action to.be adequate and.this example i
.is close Example b.: A number of weld records did not provide adequate j traceability of the weld metal to CMTRs; specific examples are listed in Section 2.1.4.2 and Table IV (Deficiency D-2.1-10).
TVA denied the examples for this ' violation in their response to the report. - TVA supported the denial with documentation ( i 575's, purchase orders, receipt inspections) which was not available during the original inspection or prior to issuance of ! 86-68. -The NRC inspectors' review of the above documention ! determined that TVA's weld filler material controls are adequate, ! if TVA only purchases qualified weld rods-and the welds are documented by " Weld Data Sheets" which verify the weld rod type ! , used for a given weld. The inspectors identified no problems in ! I these areas (weld rod purchasing and data sheets); therefore, l these violation examples are close :_-
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f" , Chicago; Fluid Power; solenoid materiali andl Target RockLsolenoidL m '
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Rock solenoid valve material. l Based'ontthe inspectors review ofA
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correctivetactionito;befadequate and these. samples lare closed.c F4 ? ,
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1TVAidenied the?samplesfof .the violation dealing with(the; Limitorque. '
- gj:j g Vi gear. clutches.. The: inspectors' determined thatcTVA:had:an ? '
< appropriate Certificate. of,Com'p 11ance available for ~reviewifor ~
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, TsampleL W8'1,The . ~ inspector also. determined from1 review of. , '
r . procurement documentation; that item 01lwas thelpart in question ,
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;for; sample W9 andlit was cordered to QA' Level.0; requirements lfor?
- f %J , - & >G T < LSystem Code 27L CondensertCirculating Water Systemi;The inspector- $ v
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further determined that the.part was being: held:as ta , bin spare parti iand;was' marked as a,.non _ quality part.,LBased on the above inspectors' i> ,
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m '4 Lactivities,Tsamples W8 and W9 are closed;
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I3.3'.4' " Violation : No. : 4:1(Closed)Elssuanceof.materialsiwhich'do<, i
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1not havejthe required certifications:(Deficiency.D-2.1-4)L
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, 2 LTV51deniedthisviolationonthegroundsithatTVAsaspursuinga; scourse of: action lat the; time of the SSOMI-inspection; for:
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tresolutioniof.the piece parts concernsLidentifiediin NRC ' e Inspection' Report Nos. 86-61'.J TVA~ contended that,since they were D '
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K . pursuing a course of "actioniwith' input from theLNRC,fthere wasLno ' y~ , .basisiforlthe, violation; ,,
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LAs'part'of this SSOMIJfollow-up inspection, the NRC,als~o conducted E
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'a? follow-up inspection to the 86-61< Procurement Inspection;to;
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Treview TVA's corrective action. relative to,the,, findings;of that; ; /, ' inspection. In conjunction with this'reviewfthe'NRCl inspectors
^ reviewed TVA's -denial"ofl this violation. ,
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evaluation'of.how TVA controls the"issueJand tracking of- ,.,W . materials from Power Stores- for materials; that ,do' not have.
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< : required certifications ~, and review of the (information provided y in the; report response; the NRC accepts.the' violation' denial and'
@ ', ' ' the violation is' withdraw + a . !
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'As notedjin paragraph 2.3.3, a Potential Enforcement Finding was n .& identified in the 86-61 report for failure.to take adequate;
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corrective action in' procurement and TVA is subject _to possible-W . enforcement relative to that finding, m ', .
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3. Violation No. 5: (0 pen) Instances in which safety-related equipment was not installed in accordance with the instructions,. procedures, or drawing Example a.: Installation of the fifth 125V Vital Battery did not meet the specification and drawing requirements: cable separation-violations involving A and B train cables were identified in Battery Board 5; insta11ed' lights in Battery Room 5 were found to be standard fixtures rather than the required vapor / explosion proof fixtures; intercell connection cables which link Vital Battery Cells 52 and 53 were found to have bend radii less than , required by site specifications (Deficiencies D-2,4-12, -14, -11, l and -13 respectively). I TVA admitted deficiency D-2.4-12 with regard to the vital battery and the NRC inspector's review of the planned corrective action found it to be satisfactory. Verification of correctie action , completion will be performed during a future inspectio { TVA denied deficiencies D-2.4-14 and -11 with regard to cable separation and light fixtures. Based on the NRC inspectors' '
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review of the report response and other documentation available during this inspection, these two items are close . TVA denied deficiency 0-2.4-13 with regard to the cable bend radius based on its belief that the original installation met the bend radius requirement, that the violation was written against the original installation because of the words ". . . was not i installed in accordance with . . .", and that the existing bend - J radius is acceptable based on evaluation. The NRC disgrees with this position. The violation was written against-the equipment j condition which existed when the SSONI inspectors identified the j problem and this was made known to TVA during the SS0MI { inspection; therefore, the NRC considers the narrow interpretation j of the words " installed" to be unacceptable. Additionally, the l NRC disagrees with the disposition of CAQR SQP 870898 (see { paragraph 5.3.2 for further discussion) which evaluates the i acceptability of the cables as they exist in the plant. The ; inspectors examined the questioned cables in the plant during this inspection and found the cited cables, as observed, in the fifth vital battery room did not meet the minimum bend radius of TVA's electrical design procedure E-12.5.1, Revision 2, " Minimum Radius for Field-Installed Insulated Cables Rated 15,000 Volts and Less." 1 Based on the. inspectors' observations, the inspectors felt that if . the insulation was damaaed and the conductors were to come in contact, i the cables could possibly contact cables of a different polarit This is contrary to TVA's evaluation that if the conductors were to come in contact, the bundled cables are tied to the same terminal; therefore, no corrective action was deemed necessary. Additionally, the inspectors could see no reason why the cables should be stressed beyond the minimum bend radius. Based on the above, TVA's denial of this violation example is not accepted and the NRC considers the ; violation example vali : a @sy4 M M W ,_.W~~'v> - a m s e w> > > '
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? a .; ' Panel ~1A1;has: threelconduits withc15Lto 20' cables entering?
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wyp$(. gj : , Lgj,fAIrip: pan!inthe.sameroomwassupportsdjby[bailingwirec {& < '
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'y that wasisupported inadequately.1LThe main concern is that?
the pan can. fall and-damagelsafety'-related devices oni
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' electrical equipment.JThis isan examp!le ;of poor quality 3 icontroi.:
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Ed .' . Cable, notcproperly supported (behind:the '6.9KVL switchgear. ,
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;Theicable ,is; partially. run in aLnon-safety-related. tray,:then .
gq s ..*s, , V in a safety-related tray, and then;back in thet kj ;
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:, .non-safety-rel,ated tray. ;During these transitions the cabl ey > ,
e lacksiany supportu This cable routing is considered an-example:of poor qualit ~
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% @ , . pp A & : The same occurNnce of unsupported" cable was also observed a i
,' 'a for' tray."NFA."- ,
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" ' : Cables ro'uted in_ cable: trays have. in most cases, been ..
6 treated with fire retardant.: In'one case, a safety related g *y
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; trays" PEA " had a roll of bathroom tissue lying on the fire
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retardant. This was considered an' example of poor 4 housekeeping and a fire safety concern.-
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,em x W g[ , !The above it' ems need to be addressedLby' TVA and are considered an f inspebtion. follow-up item (50-327/87-40-03;- 50-328/87-40-04) which 7 will be reviewed'during s future'. inspectio > '
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f- s u > Exampleib.: ~ Pipe restraint on ERCW pump inlet line was assembled Jsuch that. it acted in only-two directions rather than the three as
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x,~ t P Tdesigned; structural:: filet welds for two' pumps were stitch welded h ' ' :rather than continuously welded;as specified on'the support !
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g$d1 , Jdrawing; accomplishment of work activities (cutting of a pump y y" idischarge line, disassembly.of pipe hangers, and. removal of a part i
' internal"to'al pump housing) without procedural requirements or' /
d. .bsf
"' ' proper documentatic_n .(Deficiencies D-2.4-1 and -2).
%' TVA admitted deficien'cy;D-2.4-1 with regard to the pipe constraint i 3 , : working in only two directions rather than three. NRC review of f the: planned corrective action found it to be satisfactory; . & ' however, verification of corrective action completion will be y, , , * .- , performed duringLa future inspectio s , '
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TVA denied deficiency D-2.4-1 concerning the stitch weld versus j
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continuous weld on the basis that.the stitch weld was in accordance with the original design and the discrepancy was du .to an error, following installation, when the support drawing was changed from.a typical drawing to an Engineered Support drawin TVA. stated that the weld symbol for the stitch weld was incorrectly. transferred. Therefore, TVA denies that the weld was not in agreement with requirements; however., they agree that the drawing should reflect the actual installation and they are j correcting the discrepancy. The NRC inspectors reviewed d i documentation related to the weld installation and held discussions with TVA personnel. Based on the inspectors' evaluation, the NRC agrees that the support was installed as designed and it was a documentation error. Therefore,:TVA's denial of this violation example is accepte TVA denied deficiency D-2.4-2 concerning work activities not i meeting procedural requirements. TVA's response is based on its belief that the cited activities 'were necessary and that.the nonconformances were subsequently restored and documented in accordance with procedural requirements. The inspectors' evaluation of this deficiency concluded that TVA had not clearly addressed the actual deficiency, that equipment had been disassembled without authorizing documentation. During this inspection, TVA was unable to provide the NRC with any i documentation that authorized the disassembles which were -i performed. Additionally, TVA failed to respond to the third part of this deficiency (paragraph 2.4.1.3 of the report) concerning the removal in PMT-97 of a brass nipple from the pump P-B cooling coil as documented in the test engineer's daily journal. Based on , the fact that TVA was unable to support their position with i documented objective evidence, this violation example is considered valid and the denial it denied. TVA also needs to address the' issue regarding the removal of the brass nippl Example e.': Electrical installation discrepancies including loose L-B condu't boxes and loose or broken flexible conduit; transmitter installations,with assembly discrepancies; loose debris and mold on terminal blocks; rust on seating surfaces; * i improperly mounted resistors; deficient Raychem splices; and missing side protective covers on devices in Auxiliary Control , Room panels (Deficiencies D-2.4-3 thru'-7, D-2.4-9, and D-2.5-1). l
TVA admitted the violation examples for deficiencies D-2.4-3 thru l
' -7, D-2.4.9, and D-2.5.1 except for a few specific examples for deficiencies D-2.4-4 thru -6. The inspectors reviewed the planned corrective action for the admitted deficiencies and identified no problem Verification of corrective action for the admittals !
will be accomplished during a future inspection, except for i verification of the tightening of the conduit connections on
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transmitter 2-PDT-44 (D-2.4-3) and the correction of identiifed Raychem splice deficiencies (D-2.4-9). These two corrective actions were verified by the inspector during this inspectio l =_ :_-
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- 27 - . - TVA denied the following specific violation examples: (1) torque values on transmitter caps for transmitters 2-PT-30-42 and -43, D-2.4-4; (2) rotor.. terminal block markings on 2-FCV-1-18, D-2.4-5; and' (3) loose conduit on valve 2-FSV-40-14, D-2.4- The: inspectors reviewed the TVA position that the Qualification Maintenance Data Sheets (QMDSs) are the controlling documents for specifying. installation / maintenance torque values and that the WP '
11912 was consistent with the QMDS for the transmitter. After reviewing-related documentation, the NRC agrees with TVA's position and accepts the denial for transmitters 2-PT-30-42 and-4 The inspectors agreed with the deficiency statement that the information in WP 11979 was not sufficiently detailed to "... , positively identify the correct terminals...". However, the
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inspectors also agreed with TVA that there was no requirement that rotor terminal blocks be marked. Since the inspectors found the information provided in thc WP to be consistent with industry practice and the detail provided was considered to be within the ; skill of the craft, the NRC accepts the violation example denial i for rotor terminal block marking TVA's denied the loose conduit on valve 2-FCV-40-14 on the grounds that there is no such valve in the plant. Careful review of information by the NRC inspectors' along with input from the original SSOMI inspectors determined that the valve of original concern was probably valve 2-FSV-30-14. This valve was found in the plant location described by the original NRC inspectors and it had a-loose conduit connection. Since the inspection report did not J identify the correct valve with the loose conduit and there was no i
plant valve as identified in the report, the denial is accepte Inspections by NRC resident inspectors, since this follow-up inspection, have verified that the loose conduit on valve , 2-FSV-30-14 has been tightene The inspectors noted that TVA failed to respond to a instrument line support hanger which was missing on transmitter 2-PT-30-42 (part of D-2.4-4) in the report response. The inspectors discussed this with TVA personnel and they provided-the following position on this item. TVA stated that the maximum support ! spacing was exceeded on the transmitter installation; therefore, the support was "omitted," not missing as stated in the deficiency. TVA stated that the support has been installed and the inspectors verified that an instrument line support was recently installed at transmitter 2-PT-30-42. Since corrective action has been taken, this item is close Example d.: Mechanical installation discrepancies including missing or inadequate concrete anchor bolt pull test records; l locations,' configurations and welding details on hangers, braces and support plates which were not in accordance with drawing requirements; a failure to hydrotest newly installed power operated relief valves; an incorrect component listed on weld l record; and installation of a larger coupling and an extra reducer ' not shown on the drawings on Diesel Generator 1A-2 (Deficiency D-2.4-15 thru -19, D-2.3-9, and D-2.4-8).
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i TVA admitted the violation. examples for deficiencies'D-2.4-16 thru D-2.4-19 and the second example under D-2.4-15 (gaps between the ears of valve operator clamps for valve 1-FCV-63-165). The inspectors reviewed the planned corrective action for the admitted deficiencies and found them to be acceptable. Verification of i corrective action completion will be accomplished during a future inspectio ' TVA denied the violation examples for deficiencies D-2.3-9, ,
.D-2.4-8, and the first example under D-2,4-15 (no anchor bolt pull i test records - valve 1-FCV-63-165). The inspectors reviewed TVA's f denial of deficiency D-2.3-9 concerning failure to hydrostatic l ' testing of new Power Operated Relief Valves (PORV) 2-FCV-8-334 and !
2-PCV-8-340A.- The inspe: tor also reviewed WP 10478 which related to , PORV installation including piping and support modifications to , accommodate the new valves. The inspectors verified that~ the e hydrostatic test was run without the PORV valves being installe . as stated.in the deficiency; however, the inspectors were unable to 1 identify any requirements to hydrostatic test valve / bolted flange l connections. Therefore the NRC accepts the TVA denial of this 3 deficienc { j TVA's denial of deficiency D-2.4-8 stated that the cited lack of ' installation of a 2-inch weld-o-let to an existing 16 inch by 18 inch reducer in accordance with WP 10961-is in error. TVA stated that the weld-o-let is installed on Unit 2, loop 3, upstream of ; valve 2-FCV-3-508. The NRC inspectors reviewed-the deficiency and l TVA's response and determined that the deficiency as described in 1 the inspection report was probably referencing the weld-o-let f
. downstream of the valve. This weld-o-let is installed and there i is no reducer downstream of the valve. .Since the follow-up I'
inspectors found the stated deficiency somewhat unclear in the report with regard to whether the weld-o-let in question was upstream or downstream of valve 2-FCV-3-508, TVA only addressed i' the weld-o-let upstream of the valve in the report response, and the fact that TVA was able to demonstrated to the inspectors satisfaction that both weld-o-lets (upstream and downstream) were installed according to design requirements, the NRC accepts TVA denial of this deficienc TVA's denial of the first example of deficiency D-2.4-15 concerning anchor bolt pull test records stated that the bolt pull i test records were located in WP 8739, the WP that was used to l install the restraint. rather than being in WP 8800 as stated in the inspection report. Based on the NRC inspectors discussions with TVA, the inspectors determined that the denial was based on the
" belief" that WP 8739 and WP 8800 used the same base plate. TVA was unable to provide the inspectors with any documented objective evidence to support this " belief." In fact the inspectors review of the WPs indicates that the base plates could not be the same unless the location in the WPs is incorrect; therefore, the NRC disagrees with TVA's position and considers the violation example to be valid. Based on the above, TVA's denial is denie !
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3. Violation No. 6: (0 pen) Instances in which items that did not meet the purchaTe order specifications had been signed-off as acceptable during receipt inspectio Example a.: Certified Material Test Reports (CMTRs) involving specific types of weld electrodes furnished by ARCOS failed to include mechanical test data as required (Deficiency D-2.1-6 i samples W-15 and W-18). ! Example b.: A normally closed solenoid valve operating at 1 watts was ordered; the valve accepted was normally open and l operated at 10.5 watts (Deficiency D-2.1-6 sample W-12).
Example c.: Required impact tests were not included for an accepted five inch stainless steel bar, hardness values required ! by the specification were not contained in the CMTR for another accepted stainless steel bar, and required bend test results were not included in the.CMTR for a one inch carbon steel plate (Deficieucy D-2.1-6 samples W-21, W-22, and 42-1).
Example d.: Physically different gaskets for a three inch Masoneilan valve were accepted under the same part number (Deficiency D-2.1-6 sample W-10).
TVA admitted the following examples of deficiency D-2.1-6: samples W-10, W-15, W-21, and W-2 While TVA did not formally respond to sample W-18 in the inspection response, discussion between TVA and the NRC inspectors established that TVA's position regarding sample W-18 was the same as for W-15, which also pertained to ARCOS weld electrodes. The NRC inspectors'. evaluation of corrective action for the admitted violation examples, including sample W-18, determined that the action was adequate. Verification of completion of the corrective action for all examples will be performed during a future NRC inspectio TVA denied that samples W-12 and 42-1 were examples of deficiency j D-2.1-6 and supported the violation. The NRC inspectors reviewed f documentation on sample W-12 that demonstrated that the 10.4 watt ' normally opened valve was the valve required and that the contract had been revised to reflect the required valve. Additionally, the ,
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inspectors determined that upon receipt inspection, SQN completed an evaluation and documented the contract revision as an "Al-19, Attachment 9" and the valve was accepted. TVA was able to ! demonstrate to the inspectors' satisfaction that the valves ; actually receipt inspected were in accordance with the revised ; contract; however, discussions with the original inspectors subsequent to this inspection identified that document 6 tion at the time of the original inspection documented that the TVA l receipt inspector had accepted the valve as being a normally ;
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closed solenoid valve operating at 15.4 watts when in fact it was a normally open valve operating at 10.4 watts. In view of this ; information this violation example is valid; however, since the i valve actually receipt inspected (normally open operating at 1 I watts) is the valve required and documentation is now correct, l this example is closed.
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- 30 - , , , -> - The TVA denial of example 42-1 concerning failure of the CMTR for ' 1" thick steel plate hanger 1-RCH-88, WP 10615, to list the fresultsLof. bend tests as required by the purchase specificatio was based on the fact that appropriate documentation is in place for ,the , bend test results. The NRC inspectors ~ reviewed the ' documentation for the bend test results and determined that it was appropriate for documenting the test results. Therefore, the NR accepts _TVA's denial of this example of the violatio .
3. 3. 7 -~ Violation- ho. 7: _
(0 pen)Inadequateimplementationof document control procedure Example a.: A number of drawings contained inaccurate information and,' although some of the errors'were found during installation, the drawings were not changed by the appropriate change documen-E tation-(field change requests or design change requests). .i Example b.: . A number of modification packages reviewed either did not identify the drawings to be changed, or did not' identify or include the applicable drawings .for use by construction organizations. LIn some cases, procedural changes signed-off as I I
complete had not been issue TVA admitted to. deficiencies D-2.3-1, -2, -4, -6, -7, -10, and parts of the deficiencies identified in D-2.3-8 as being examples of the violation. The inspectors reviewed the corrective actions for the' admitted deficiencies and closed deficiency D-2.3-7 and the deficiencies relative .to WPs 11580 and 11915 under deficiency D-2.3-8. While the planned corrective action for the other admitted: deficiencies were reviewed and found to be adequate by the inspectors, they did not verify completion-of. corrective action on them. ~ Verification of corrective action completion will be done during a future inspectio TVA denied the deficiency D-2.3-3 and some of the deficiencies identified _in D-2.3-8. Even though problems identified in section 2.3.12 of the report relative to WPs 11100, 11154, 11174, and 11912 were not specifically connected to this violation, TVA's response denied that the problems were discrepancies with following Procedure AI-1 The inspectors reviewed the response documentation related to the denied deficiencies, the specific WPs, drawings, and other documentation cited in the deficiencies in order to understand the concerns of the original ' inspection team. Additionally the inspectors talked'to various members of the origina'l team and determined that the major team concern under this violation was TVA's lack of attention to detail in the completion of WPs, drawings, and related documentation. Based on the inspectors' reviews of WPs, drawings, and other documentation, they determined that the identified deficiencies which were denied were minor and not of safety significance; therefore, having TVA go back and correct'them would serve no useful purpose. Based on the above, = _ - _ - -
F i [- l - 31 - p
.- * the NRC's major. concern was whether WPs, drawings, and associated documentation are now being processed according to procedural requirements. Based on discussions with TVA and direct NRC i
observations of WPs, drawings, and associated documentation E processed prior to 1986 and those processed during 1986 and later, the inspectors determined a significant improvement in the control of WPs, drawings,'and associated documentation processed during 1986 and late Based on the followino: (1) the minor safety significance of the denied deficiencies; (2) the observed significant improvements in documentation over the last year and a half. (3) the generic-aspects of TVA's corrective action on the admitted deficiencies of this violation, (4) the program improvements described and committed to in the SQN Nuclear Performance Plan such as the Civil Design Calculation Program, the Electrical Design Calculation Program, and the Design Configuration and Control Program, and (5) the original inspectors' major concern under this violation, these deficiencies under this violation are close . Deficiency D-2.3-5: Installation different from flow diagra While this deficiency was not used to support a violation, it was identified in Section 2.3.5 of the report as a deficiency, as well as in Table I of the report. Since it was an identified deficiency in the report, TVA should formally respond to it. This deficiency concerned WP 10748 (ECN5773) which installed PORV The flow diagram 47W813-1 improperly showed two concentric reducers downstream of the PORVs. while the actual installation used one concentric reducer and one 6" x 3" reducing tee. The report states thst TVA initiated a Potential Drawing Deviation N .to correct this discrepancy. This deficiency should be forraally addressed by TV . Unresolved and Open Items: As discussed in pa ngraph 3.2 of this report, the inspectors did not review items identified as unresolved or open in the SSOMI inspection report. These will be reviewed during a future NRC inspectio .4 S_ummary Based on the reviews and evaluations performed to follow-up the i SSOMI findings, the NRC determined that TVA is taking corrective j action on the violation examples which TVA admitted to as being ; violations. During the inspection eight admitted violation i examples were closed by the inspectors, since adequate corrective j action had been taken by TVA. Corrective action on other admitted d violation examples was scheduled for completion followino the ' inspectio , l _ _ _ _ _ _ _ _ _ - _ _ _ - - _ _ _ <
' - 32 - .. . During the inspection exit meeting on July 24, 1987, the NRC stated that it would accept TVA's denials for 47 of the 51 . . violation examples denied. .The four remaining denials were net accepted during the exit meeting.: However, since the exit meeting, the follow-up inspectors have held discussions with members of the original SSOMI inspectors. Based on these discussions, thel staff has re-evaluated its position and is now > unable. to accept 38 of the 47. denials previously stated as being acceptable. The staff is able to accept 9 of the 47. denial With regard to the 38 denials not accepted, the staff position is that since the documentation was unavailable during the SSOMI ' inspection. .the violation examples are valid. The staff feels that since the SS0MI extended over a period of eight weeks, sufficient time was provided TVA-for supplying the required documentation, but for some reason it was not supplie In a few cases the SSOMI inspectors, stated that TVA personnel even admitted that the documentation did not exist; however, TVA somehow now has the documentation. The fact that TVA now has the documentation does not change the fact that during the SS0MI the violation examples were valid. Since this inspection determined that appropriate documentation was.now'available to resolve the violation examples. the examples have been closed in the enclosed inspection report. Since the examples are now closed, no response to these violation examples ~ is require The above discussion concerning documentation of the 38 violation examples is an excellent example of the 'significant problems with TVA's storage and retrieval of records. The.NRC acknowledges that TVA is addressing the issue of records storage and retrieval as part of their Employee Concern Program (reference Element Reports 80503 and 80504) and the resolution of these concerns is expected to improve TVA's ability to make records available in a timely manner. The reason for stressing this issue is to ensure that TVA fully, recognizes the problems in the records area and utilizes appropriate' resources in the resolution of this issue in .a timely manner. Since resolution of this records issue is already being followed by NRC staff, no follow-up of this issue is planned as a result of this' inspectio With regard to. the four violation example denials not accepted at l the exit meeting, three were rejected since TVA could not provide !
the inspectors with documentation substantiating the TVA position. The other denial was based on the fact that the NRC found the TVA evaluation of the fifth vital battery room cable bend radius evaluation to be unacceptabl Additionally, the NRC determined that SSOMI deficiency D-2.3-5 needed to be addressed by TVA along with a few other minor deficiency examples in the report (see details in paragraph 3.3). Eleven SSOMI report unresolved items and seven open items remain open following this inspectio W l
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4.0 Critical Structures, Systems, and Components (CSSC) List 4.1 Backoround Paragraph 7.d of NRC inspection report 50-327,328/86-11 discussed that SQN has a Q-List but it is not being implemented. Instead, SQN is using the CSSC list to classify work documents such as work requests and work plans. During the 86-11 inspection, responsible TVA personnel comitted to implementing a new Q-list three months after Unit 1 and Unit 2 returned to operation. In a letter to D J. Nelson Grace, Region II Administrator, dated June 27, 1986, from R. Gridley, Director, Nuclear Safety and Licensing, TVA revised the commitment to state that three months after Unit 1 and Unit 2 are returned to operation, a senedule or plan would be developed to implement a Q-list. This revised commitment was accepted in a letter from G. Zech to S. A. White dated October 9, 1986. Since the October letter, one inspection (50-327,328/87-16) and several additional letters have discussed and addressed the adequacy of the existing SQN system of using the CSSC list in place of 'a 0-list and the implementation date for a new Q-list. In addition to the above, two employee concerns raised questions concerning the use and/or adequacy of the CSSC list at SQN. Based j on the above inspections, correspondence, and employee concern evaluations by the NRC, the implementation and use of the CSSC list I at SQN were evaluated during this inspection, j j 4.2 Scope
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The inspection involved the review and use of the CSSC list, including the controlling procedures and documents pertaining to this lis Interviews and discussions took place with key TVA ! personnel from the Divisions of Nuclear Engineering, Quality i Assurance (QA) and Operations responsible for developing, controlling i and using this list and with the Employee Concern Task Group and members of the Independent Senior Review Panel responsible for I i investigating and evaluating employee concerns relating to the CSSC lis i
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4.3 Findinos 4. CSSC List Procedures The NRC inspectors determined that Sequoyah's Nuclear Plant Standard Practice document SQA-134, "CSSC List" and 6 referenced l source documents are the primary source documents used at Sequoyah for establishing CSSC classifications. The central authority for determining CSSC classification is the CSSC Review Connittee consisting of qualified individuals in engineering and technical l fields. Representatives from the QA organization and the Division } of Nuclear Engineering (DNE) are members of this congnittee, j- however, the attendance of the representative from DNE is not mandatory at committee meeting . g __
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Administration Instruction AI-39, " Critical Structures, Systems and Components" describes the responsibility and authority of the ; CSSC Committee and Standard Practice procedures SQM2, " Maintenance 1 Managenent System" and SQA45, " Quality Control of Material and , Parts and Services" further describe controls and guidelines for' i ,
.CSSC classification and the use of SQA-134 and the six referenced j source documents relative to CSSC classification. Questions or i requests for interpretation regarding CSSC classification are j L required to be submitted to the CSSC Review Committee for action !
in accordance with procedure AI-39. At the time of the- 1 inspection 'there'was a backlog of CSSC requests for { interpretation awaiting CSSC Review Committee action. However, j those actions with potential impact on restart were receiving
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priority action by the Committee in order to close them out prior to restar I In discussions and interviews with the electrical, mechanical and l instrumentation engineers responsible for preparing maintenance work requests and for determining whether the work is safety : related, the inspectors confirmed that they adequately understood l the use of SQA-134 and the six referenced source documents -{ described in SQM 2 for determining CSSC classification. While the ' TVA personnel felt that these documents provided an acceptable means for determining CSSC classification, they considered the overall review process cumbersome and difficult as opposed to using a one source document which identifies all CSSC ite The inspectors evaluated reports identifying problems with the CSSC list, however, the inspectors attributed these to the misconception that the SQA-134 was an exclusive document identifying all CSSC items. As described above SQA-134 in conjunction with the six referenced source documents represents the Sequoyah CSSC lis In general the inspectors found the procedures adequate in describing responsibilities and the criteria for determining CSSC classification. The inspectors found the criteria to be - consistent with regulatory requirements and FSAR commitments. The inspectors however identified the following weaknesses in procedure AI-39 which merit consideration. Procedure Al-39 lacked controls for documenting technical decisions, which would provide a record of the basis for reaching technical decisions, and lacked a mandatory attendance requirement for the DNE representative on the CSSC Review Committee, The lack of documenting the technical basis for removing the boric acid evaporators from the CSSC list (CSSC Tracking No. 60) is an example of technical decisions not being documente . Employee Concerns In addition to the above reviews, the inspectors evaluated the results of the Employee Concerns Task Group (ECTG) investigation relative to Employee Concerns Element Report Nos. 209.1(b) and 209.2(b) which address the possible existence and use of two CSSC
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, * listings'at Sequoyah! -Meetings and' discussions took place.with x ' the Chairman of the CSSC Review Committee, .che ECTG, and member ' 'of.the independent Senior. Review; Panel in order to understand' 'their assessment of.the adequacy of the CSSC list and the extent c' '
Lthat it was being maintained and used. There was general Lagreement that Sequoyah'had in use only.one list consisting of
.SQA-134 and the six reference documents. In' addition,'it was , a agreed that this. approach was adequate in classifying CSSC's, ' '
however, it was pointed out that while' the overall process was adequate it'was-found to be cumbersome and somewhat. difficult to-use. The above concern (the,use of two CSSC lists) was. attributed to'a proposed Sequoyah Q-List which was developed but rejected for use due-to numerous deficiencie ECTG suggested that it would be prudent' for TVA to perform an
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accuracy and completeness review of;the .CSSC list since TVA ha procedurally committed to do such. A corrective abtion plan associated with the above Employee. Concern Element . Report commits TVA to perform such a completeness.and accuracy review but not prior to restar In discussions with TVA it was revealed that TVA was initiating action. to delete the commitment to_ review the . accuracy and completeness of the CSSC list from'the corrective
> - action plan since they.have sufficient conf _idence in its accurac and that a detailed Q-List would be developed ~sometime'after restart of Units ,1 and ? which would supersede the present classification syste As a result ofjthis inspection, the NRC suggested to TVA that in order to gain further confidence in the accuracy.and completeness of the CSSC' list that the TVA Engineering Assurance organization . should conduct a technical audit in this. area. The inspectors understand that Engineering Assurance in conjunction with'the ' Quality Assurance-organization has recently conducted such an audit of the CSSC list and concluded that the: list and the overall process for CSSC classification is acceptable recognizing the difficulties, when using the source documents'with SQA-134. Th TVA audit group also recognized and recommended the need to develop a detailed Q~ list which would supersede SQA-134 and the referenced source document .4 Summary Based on the inspectors' reviews and evaluations of the development, control and use of Sequoyah's classification of j
, , CSSCs, the inspectors determined that while the overall CSS j process is somewhat cumbersome and difficult to implement it is acceptable and meets regulstory and FSAR requirements; however, the following observations should be considered when changes are made in the CSSC process.
L Procedure AI-39 lacks controls for documenting technical decisions, which in turn would provide a record of the technical basis for reaching technical decision )
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- Procedure AI-39 does not require mandatory attendance from the Division of Nuclear Engineerin . The process for determining if an item is CSSC is cumbersome and difficul In conclusion, the inspectors found there is reasonable assurance
.that there are no major problems in determining CSSC classification at Sequoyah. The inspectors found the present classification system acceptable for use on a short term basis; however, since the process is cumbersome and difficult, a Q-lis should be developed to consolidate the existing CSSC. list and all supporting parts. While no major problems were identified in CSSC classification and control, TVA/SQN should consider the identified weaknesses when CSSC procedures are revised. Additionally, it is recommended that development and implementation of a Q-list, as committed to by TVA, be accomplished as soon as possible. No items are identified for NRC follow-up as a result of this CSSC list evaluatio .0 Additional Inspection Activities 5.1 Sequoyah QA Proaram The inspectors made several observations regarding the QA organi-zatinn and QA program-implementation during this inspectio Generally, the inspectors found the overall QA program implemen-
'tation at Sequoyah to be improving and working in an acceptable manner. Auditors assigned to the corporate office are being reassigned to specific sites in order to enable them'to be more knowledgeable of ongoing activities and more effective in performing audits. Onsite surveillance functions are being
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restructured to permit improved flexibility in monitoring the l important ongoing work in a more timely manner; therefore, ) allowing quicker reporting of findings and corrective action s
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The QA organization is actively developing a Quality Improvement { Program in compliance with the Nuclear Performance Plan and the ; QA Topical Report TVA-TR 75-1A. The basic objective of this ! program is to improve quality and plant performance by focusing j the accountability for quality from the QA organization to each i employee of TVA. Through the use of performance standards and indicators the company employees will work with management in terms of " Quality Circles" to identify and resolve problems and recommend improvements. Evidence from other companies who have j implemented similar programs has shown remarkable results in the ! attitude change of employees in regard to new pride and respect i for the quality of their work. The inspectors believe this j t Quality Improvement Program to be a significant ingredient in l contributing to TVA's objective of achieving higher quality j standards and performance at its nuclear facilitie '
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* The Condition Adverse to Quality (CAQ) Program was recently audited by the TVA QA organization which resulted in findings that it was not being adequately implemented at Sequoyah and lacked adequate management involvennt. In reviewing this issue we found that top management including Mr. S. A. White, Manager of Nuclear Power, has placed top priority in identifying and implementing an action plan to correct the CAQ program problems. It was apparent that each proposed action was either closed out or actively being worked on. (See additional coments on CAQRs in paragraph 5.3.)
The inspectors determined that the Engineering Assurance activity at Sequoyah appeared to lack sufficient staffing to effectively
"arry out technical audits and reviews on a day-to-day basi However, TVA pointed out that it was trying to add four additional Engineering Assurance personnel to the site staff which would bring the total to si In conclusion, the inspectors determined that the QA program at ;
Sequoyah appeared to be improving consistent and in accordance with the commitments of the Nuclear Performance Plan and the QA Topical. The QA organization is actively involved in participating and assisting in identifying and resolving technical and quality r assurance issues. Also an improved awareness and support by the plant staff towards meeting quality objectives was observe l Continued ongoing improvements and progress in ths QA area are ! expected and will be assessed through future meetings and inspection .2 Inspection Report 50-327,328/86-11 Open Items 5. . 86-11-02 (0 pen): TVA has agreed to develop an improved Q-list for use at the Sequoyah facility. The form and content of the list has not yet been fully decided on at this time. However, requests for bids have been submitted by TVA to outside contracting firms to develop a Q-list. Since the list is.not developed and in use the previous 86-11-02 inspection item remains ope (See paragraph 4.0 for further discussion on CSSC list.)
5. (Closed): The inspectors reviewed TVA's methods for revising the CSSC list. The CSSC Review Committee has established a formalized tracking system for changing the CSSC list content. This system was inspected and acceptably verifie Therefore, the previously open item 86-11-03 is now close .3= Conditions Adverse to Quality Reports (CAQR) 5. Backaround In the process of reviewing RIP, SS0MI, and the QA Program, the inspectors identified concerns with the CAQR system. As discussed in paragraph 5.1, the inspectors determined that TVA had identified problems with the SQN implementation of the system and Mr. S. A. White had placed top priority on the resolution of these problems. In view of the fact that TVA was in the process of resolving program problems, the discussion provided below is to ; identify .NRC inspector concerns so that TVA can consider them when l resolving TVA identified problem area l
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5. R_IP'CAQR Concerns In the process of reviewing the activities of RIP, the NRC inspectors ' identified 19 CAQRs which were issued by RIP personnel. In following up on-the CAQRs issued the' inspectors also reviewed the following procedures AI-12, Revision 0 and 1. Part I & II, " Administrative Instruction-Corrective Action;" NEP-9.1, Revision 2 " Corrective-Action;" and SQEP-61, Revision 0, " Handling of Condition Adverse to Quality Reports (CAQR) and Problem Identification Reports (PIR)."
Of the 19 CAQRs, 5 violated the 30 day limit on remedial corrective i
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action, 7 appeared .to have incorrectly indicated that there was no
" Potential Effect on Operability," 3 appeared to have incorrectly indicated that the'CAQR was.not significant, and 2. contained .
Remedial Corrective Actions.which were not acceptable. The following i' detafis the problems with each CAQ CAQR #SQP870936 Description: Several Systems were affected with the installation i of electrical components'used in Category I application, without seismic qualificatio Origination Date: 5/21/87 CAQ Coordinator Date Received: 5/22/87 Remedial Corrective Action Date: Past Due Specific Problems: l
- The CAQR was past due for the 30-day Remedial Corrective i Action.-
CAQR #SQP871060 Description: Spent' Fuel Pi Non-QA material used in applicatio Origination Date: 6/12/87 CAQ Coordinator Receive Date: 6/15/87 Remedial Corrective Action Date: Past Due Specific Problems:
- The CAQR was past due for the 30-day Remedial Corrective Actio CAQR #SQP870899 !'
Description: Containment Sump Level. Used nonconformance inspection material without a releas Origination Date: 5/15/87 CAQ Coordinator Receive Date: 5/18/87 Remedial Corrective Action Date: 6/25/87 Specific Problems:
- The CAQR was past due for the 30-day Remedial Corrective !
i Actio Part B1 was checked "No" by a group other than PORS. This is a procedural erro : l
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Description: Containment Sum Qualified equipment degraded by . a"
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: installing components without proper certificatio .
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- 5/4/87 . j LCAQ Coordinator Receive Date: 5/7/8 l Remedial Corrective Action Date: 6/17/8 '
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- The CAQR was past due for.the 30-day Remedial Corrective .~ Acti on . - The; Potential Operability issue. is marked incorrectly as j , " No '. " q 1
CAQR #SQP871064 .
Description: ECN indicates work is QA and seismic analysis is required.
0 . Origination,Date: 6/12/87 .
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, .CAQ Coordinator Receive Date: 6/15/87 (
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Remedial Corrective Action Date: Non The.CAQR.was. closed by SQP87093 CAQR #SQP871061 Description:- ECN indicates' work is QA and seismic analysis is require . m , H-Origination:Date: 6/12/87 CAQ Coordinator Receive Date: -6/15/87: " Remedial Corrective Action-Date: Non The CAQR.wasl closed'by SQP87093 CAQR #SQP87106 Description:1-Non-QA' hardware used on Seal Sleeve Penetratio ~
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L 0pigination Date: 6/12/87 L
. .-CAQ Coordinator Receive Date: 6/15/87 j l
Remedial Corrective Action Date: Past Due q u Special Problems: j
- The CAQR was past due for the 30-day Remedial Corrective i Actio The Potential Operability issue is marked incorrectly as - "No." l l.
L CAQR #SQP870776 .) L Description: Incorrect Connector Assembly Installe Origination Date: 4/28/87 .
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i CAQ Coordinator Receive Date: 4/30/87 Remedial Corrective Action Date: 5/28/87 ! l Specific Problem-
- The Potential Operability issue was marked incorrectly as ;
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-- . Description: : Replaced Boot on'Namco limit switch without using the Lrequired . lubrication kit. . 1 Origination Date: 6/28/87 CAQ Coordinator _ Receive Date: 7/1/87 iRemedial Corrective' Action Date: 7/3/87 Specific' Problems:
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-:The Potential, Operability issue was marked incorrectly 'as
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"No."
--Reference QMDS required maintenance. Remedial Corrective Action does not comply with QMDS requirement ~ i '
'CAQP, .#SQP871171- 1 Description: Incorrect limit switch installed on Limitorqu l operator-SMB-000.- 1
' Origination Date:: 6/29/87' . -
.CAQ Coordinator Receive Date: . 7/2/87 Remedial Corrective Action Date: N/A Specific: Problem: - I
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j ,The Potential Operability issue was marked incorrectly as-
, - t' No . " - The~ switch' installed was for a model'SMB- ' ! -CAQR iSQP871131 Description:' All IE and Seismic Category I-item ' Origination' Date: - -
6/25/87J CAQ Coordinator, Receive Date: 6/30/87 iRemedial Corrective Action'Date:' N/A Specific Problems:
- The original initiation date of 6/4/87 violates the time frame in AI-12 and NEP The Potential Operability-. issue was marked incorrectly as "No."
- This CAQR is'SIGNIFICANT, but page 2 was not available for revie CAQR #SQP871119 Description: Shelf life on various items are not recorde Origination Date: 6/25/87 CAQ Coordinator Receive Date: 6/26/87 Remedial Corrective Action Date: N/A 4
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" * Specific Problems: I
- The Potential Operability. issue was marked incorrectly as 3
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N The original initiation date of 5/28/87 violates the time frame in AI-12 and NEP Someone other than PORS checked the boxes in Part This is a procedure erro The description of this CAQR is considered "SIGNIFICANT" by the wide spread application of nonrecorded use of item with shelf life requirements. The block for significance was marked incorrectly as "No."
CAQR #SQP871197 Description: Use of RTV-180 after its shelf life is exceeded would affect the qualification of flow switche Origination Date: 7/7/87 CAQ Coordinator Receive Date: 7/9/87 Remedial Corrective Action. Date: N/A Specific Problem: ,
- The Potential Operability issue was marked incorrectly as ' "No."
CAQR #SQP871206 Description:- Various system and components are not in compliance with 10 CFR 50.4 Origination Date: 7/8/87 CAQ Coordinator Receive Date: 7/10/87 Remedial Corrective Action Date: N/A Specific. Problems:
- The Potential Operability issue was marked incorrectly as "No."
- The description of this CAQR is considered SIGNIFICANT by the widespread application of non 10 CFR 50.49 use items, but'the block was checked "No."
- This CAQR addresses Generic Problems. Part B response is past du ! CAQR #SQP871172 Description: Incorrect part used in 17 transmitter I
^rigination Date: 7/1/87 !
CAQ Coordinator Receive Date: 7/2/87 Remedial Corrective Action Date: N/A <
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Specific Problems:
- The Potential Operability issue was marked incorrectly as N _The description of this CAQR is considered SIGNIFICANT by the widespread number of 17 transmitters spread to four systems, but the block was checked "No."
CAQR #SQP870898 Description: Incorrect minimum radius bend on vital batteries.
, Origination Date: 5/15/87 CAQ. Coordinator Receive Date: 5/15/87 . Remedial Corrective Action Date: 5/22/87 Specific Problem:
- Remedial Corrective Action was not acceptabl Electrical design procedure E 12.5.1, Rev. 2 " MINIMUM RADIUS FOR FIELD-INSTALLED INSULATED CABLES RATED 15,000 VOLTS AND LESS," shows how to calculate minimum radius bend. Any deviation from this design is considered unacceptable for installation of cable in a nuclear facilit Note: See discussion in paragraph 3. CAQR #SQP870950 Descr_iption: Non-Qualified heaters were installed in various systems on six valve Origination Date: 5/23/87 CAQ Coordinator. Receive Date: 5/26/87 Remedial Corrective Action Date: 6/26/87 Specific Problem: NON This CAQR was closed correctl CAQR #SQP870949 Description: Non-Qualified beaters were installed in various ,
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Origination Date: 5/23/87 CAQ Coordinator Receive Date: 5/26/87 Remedial Corrective Action Date: N/A, Part B not attache Specific Problem:
- Review not complet Part B was not available for revie CAQR #SQP871150 Description: Replace Agastat Relays with an assembled 120vac coil and a 125vdc fram Origination Date: 6/29/87 .
CAQ Coordinator Receive Date: 6/30/87 l Remedial Corrective Action Date: N/A Specific Problem: NONE. This CAQR was progressing favorably, j
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, 5. .SSONI CA0R Concerns)
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, Duri_ng:the review of SSOMI items; the inspectors were concerned-a
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Jthat even'though.TVA admitted to a-number of. examples.of the cited > L violations, TVA did not, document;each ofithe' deficiencies on a
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# CAQR even though procedure AI-12 re' quired it. xThe:inspectorsL .
discussed;the.. concerns'with-TVA Licensing and-QA: personnel.and 4"',, 4 l found that'there were differences:injinterpretation;ofLAI-12m m
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between Licensing and'QA.c The main differences being-as toihow; i deficiencies. identified prior to AI-12 implementation were- ,
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CAQR! problem areas, the' inspectors decided to let TVA.-resolve this t Lconcern as part of the overall CAQR problem ' resolutio "' 5. = Summary-
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While no specific items were . identified for.hRC _ inspection'
: follow-up, TVA~should= consider these: concernproblems in the .CAQR progra '
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