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Insp Repts 50-327/87-52 & 50-328/87-52 on 870803-14 & 19. Violations Noted.Major Areas inspected:as-built Verification of ERCW Sys in Conjunction W/Integrated Design Insp, Including Review of Mechanical & Electrical Disciplines
	ML20235K542
Person / Time
Site:	Sequoyah
Issue date:	09/23/1987
From:	Mccoy F, Zech G; NRC OFFICE OF SPECIAL PROJECTS
To:	;
Shared Package
ML20235K462	List: IR 05000327/1987052; ML20235K459; ML20235K504;
References
	50-327-87-52, 50-328-87-52, NUDOCS 8710050138
	Download: ML20235K542 (54)
	v • d • e

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Report'Nos.: .50-327/87-52 and 50-328/87-52 1: - Licensee: Tennessee Valley Authority L 6N38 A Lookout Plac Market Street Chattanooga, TN .37402-2801 E Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah I and 2 l l

 ' Inspection Conducted: Ayust3-14and9 198 LTeam Leader:
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F. R. McCoy, Section Chief -L M quoyah Inspection Programs, Division of TVA Project Office of Special Projects

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n Team Members: J. Brady J. Kelly n W. K. Poertner M. Poston-8rown G. Walton H. Kerch i J. York R. Harris G. Hunegs J. Peters , M. Thomas D. Riska ! W. Bearden D. Ford, Parameter, In C. Vanderneit M. Goode, Parameter, Inc.

L Approved by: 5 /4 , ~ e g3h7 G. G. Zech,4ssistant Director, Inspeccion7rograms Signed Division of TVA Projects , Office of Special Projects SUMMARY t Scope: This special, announced inspection was conducted in the area of as built verification of the essential raw cooling watet; (ERCW) system in conj;nction with the integrated design inspection (IDI) of that system. The inspection consisted of in plant review in the mechanical, electrical, civil, structural, and instrumentation and control disciplines in order to verify that the ERCW system, as currently constructed and installed, is in accordance with

 ' applicable drawings and system design specification Conclusions:- Although deficiencies associated with the ERCW system were observed by the inspection team, the team concluded that, in general and subject to the resolution of those deficiencies, the ERCW  s,, stem is satisfactorily installed and constructed in accordance with design specifications. The identified deficiencies included some in the areas of electrical distribution and cable conduit routing (paragraph 2), uncontrolled l

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_ L L 2 ' modifications (paragraphr 1 and 3), disablement of system safety features without appropriate analysis or control (paragraph 6), and inadequate control of some in line valves to ERCW components and instruments (paragraph 6) which require resolution and which have potential generic implicatio Violations identified during this inspection include:

' Violation 327, 328/87-52-01 is a violation of 10 CFR 50 Appendix B Criterion III for failure to establish measures to assure that applicable regulatory requirements and the design basis for the ERCW system are correctly translated into specifications, drawings, procedures, and instructions and for failure to assure specific design changes were subject to design control measures commensurate with those applied to the original design and approved by the organization that performed the original design. Examples include:
(1) failure to specify some in line valves to components cooled by ERCW i and high point vent valves within ERCW instrument lines in drawings or procedures. This precluded formal alignment of these valves and resulted in 'non compliance with Technical Specification surveillance requirement 4.7.4.a for 31 day valve lineup verifications for ERCW operability since initial plant operation (see paragraphs 1 and 6).

(2) providing cllowance for routing of safety-related cables through undesignated cable trays under certain conditions without apparent technical justification (see paragraph 2).

(3) changing the ERCW screen wash pump purchase specifications to delete the ASME code class III requirement without concurrently updating the design document (see paragraph 1).

(4) specifying metal flexible hose for the ERCW inlet and outlet piping to the diesel generator lube oil coolers with a design rating of 100 psi intead of ERCW system design pressure of 150 psi (see paragraph 1).

(5) disconnecting the 2A screen level differential transmitter from its level detectors and removing the inlet level detector without design control measures commensurate with the original design and without formal engineering approval (see paragraph 3).

(6) installation of a cross connect pipe and valve assembly between the train A and train 8 pump and pump room cooler headers without design control measures commensurate with the original design and without formal engineering approval (see paragraph 1).

Violation 327, 328/87-52-02 is a violation of 10 CFR 50 Appendix B Criterion V for failure to prescribe and/or accomplish documented instructions, procedures, or drawings for activities af fecting qualit Examples include: J

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 (1) prescription of . conflicting requirements and failure to accomplish requirements associated with packing and sealing of pump house instrument line sleeves (see paragraph 3).

(2) failure to heat trace a portion of the ERCW system contrary to 3 drawing requirements (see paragraph 3).

(3) failure to include specific safety-related instruments on the critical systems, structures, and components (CSSC) list pursuant to SQA-13 (4) failure to provide any instructions for alignment of valves located in instrument lines downstream of primary root valve (5) failure to properly route handswitch wiring sheathed in Beldon Braid within portions of the main control panel contrary to SQN-DC-V-1 (6) failure to properly route specific safety related cables pursuant to cable pull cards or cable schedules contrary to general construction specification G-3 Violation 327,328/87-52-03 is a violation of 10 CFR 50 Appendix B Criterion VI for failure of document control measures to assure that drawing changes were properly reviewed for adequacy. One example was i noted where review of drawing changes did not identify and correct error Unresolved items identified during this inspection include: l l 327,328/87-52-04, Concerns with disabling safety related equipment without l proper review or control over compensatory measures (see paragraph 6)

327,328/87-52-05, Concern over observed flow conditions for diesel generator coolers and upper containment coolers (see paragraph 6).

,These items have enforcement implication which requires further NRC evaluatio Weaknesses identified during this inspection include: A weakness in conduct of operations with regard to disabling safety-related functions without appropriate review and analysis and without appropriate compensatory actions (see paragraph 6 and Unresolved Item 327,328/87-52-04).

L A weakness in past practices associated with labeling of valves, instruments and conduits (see paragraphs 1, 2, and 3).

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I Weaknesses in preventative maintenance programs and in maintenance practices i associated with restoration of equi,pment to operational status af ter mainte-nance activities and with the site s apparent inability to relate to the need to repair and correct damaged equipment (see paragraphs 1, 2, and 3).

The inspection scope and findings were summarized on August 19, 1987, with those individuals delineated in Appendix l L--_-____

S i INSPECTION' DETAILS 1. Mechanical Inspection The inspectors . conducted a comparison between the licensee's as constructed drawings and.the actual in place ERCW system. This comparison was conducted by performing a- hand over hand walkdown of the ERCW system

in . the ERCW pumphouse, emergency diesel generator building. auxiliar building, the - annulus, and inside containment. Valves,- piping, ' and mechanical _ components were compared to flow diagram 47W845 sheets 1 through 5',. piping > isometrics, design documents, and vendor data package The walkdown in the auxiliary: building did 'not include Unit 1: auxi11ary equipment as shown on flow diagram 47W845 sheet' Conformance of ERCW System With The As-Constructed Drawing The relative ' order of all- branches and components was' inspected to verify installation in accordance with the flow diagrams. . Several sets of in line valves located on the skids for the safety injection a pumps and centrifugal charging pumps were not shown on the flow diagrams and were not labeled. These valves are in the lines'to the oil and bearing coolers and appear to have been supplied by the vendor with the skid mounted motor and pump. These valves, i closed, would not allow cooling water flow to these pieces of safety equipmen This is considered a violation of 10 CFR 50 Appendix B

,  Criterion III for failue to assure applicable regulatory requirements and the design' basis are correctly translated into specifications, drawings, procedures, and instructions, and is designated as Vi11ation 327, 328/87-52-0 In evaluating this deficiency the inspectors observed other opera-tional concerns associated with these valves that are discussed in paragraph Other lesser signific:nt drawing discrepancies were also identified during the mechanical inspectio *

The 738 and 747 series relief valves shown on the flow diagram down stream of the ERCW strainer discharge were not found during the walkdow The licensee subsequently produced ECN 2860 dated-1980 which had deleted these valves from the system prior to plant licensing. These valves (1 each series per strainer) were , still shown on flow diagram 47W845-5 for three of the four strainers (not shown for strainer A1A-A) Although the drawing

was updated for the AIA-A strainer, this drawing change was inadequate in that it did not update the drawing for the other three strainers. This is considered to be a violation of 10 CFR 50 Appendix B Criterion VI for failure of document control measures to assure that drawing changes were properly reviewed for adequacy and is identified as Violation

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327,328/87-52-0 The licensee deleted these valves from the ' flow diagrams after the discrepancy was pointed out. Th ~ strainer and isolation valve assemblies in the supply ifnes to the ERCW pump motor cooling coils were not located during the walkdow TVA produced ECN 6014 which removed the strainer and valve in addition to resizing the lin The work for this ECN had been recently completed. The licensee updated the flow diagram after the discrepancy wac pointed ou Several sets of 3/4 inch vent and drain connections were'not located in the position shown on the flow diagram. These included the 3/4 inch vent valves upstream of the series 573 relief valves on the combined return lines from the lower containment, and the 3/4 inch 581 series vent valves and 3/4 ; inch drain valves 765 and 769 on the supply lines to the upper I containment vent coolers. The inspectors determined that the slightly different location of the vent and drain valves had no effect on their ability to perform their functio , Several thermowells were located in slightly different positions from that shown on the flow drawings. These thermowells were numbers 408 and 410 on the supply pipe for the 66S foot eleva-tion 2A and 28 pipe chase coolers. The inspectors determined that the different location would have no effect on the function of these thermowell l t In conducting the walkdown, the inspectors noted a section of

pipe that did not agree in size with the flow diagram or , The supply and return piping from both the 2A and

isometric B penetration room coolers located on the 690 foot elevation were 1-1/2 inches in diameter instead of 2 inches in diameter as called for on the flow diagram and isometrics. In comparing the Unit 2 installation to the Unit 1 installation, the inspectors ] noted that the Unit 1 installation was 2 inches in diameter as i called for in the drawings. Both Unit 1 and Unit 2 had stain- ' less steel pipe in this area indicating it was not original installatio The licensee produced ECN L6725 written in July 1986 to change the design drawings for this section of pipe to agree with the as constructed configuration and to resolve interference encountered during inspection. The licensee was unable to explain why the flow drawings had not yet been update The licensee updated the drawings after this discrepancy was pointed out by the inspector The inspectors verified that two separate independent trains of mechanical components existed within the plant. One exception was found which was located on the boric acid transfer pump and AFW pump space cooler return lines. An unidentified piping and valve assembly had been installed such that it connected the two drain plugs located downstream of the 674A and 6748 valves. This piping would allow cross connecting of the train A and train B return header This

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short section of 3/4 inch pipe did not appear on the drawing The licensee was unable to produce any documents showing when this header cross connect had been installe The licensee has since initiated action to remove this section of pipe. The licensee had identified this section 'of pipe as a drawing discrepancy on a previous design baseline program walkdown, however, the walkdown did not identify this section of pipe as a train cross connect nor as an uncontrolled modification and inappropriately noted the item as not a nuclear , safety operability concern. The inspectors consider that modification of . safety related systems without proper control and review is a significant deficiency with generic implication and in this case one that involves cross connecting independent trains of equipmen This item is considered to be another example of violation 327, 328/87-52-01 for failure to subject adequate design control measures and approvals for this cross connect installation, b. Containment Penetrations The inspectors verified that all ERCW containment penetrations for l the upper and lower containment coolers were properly identified and ' configured, that check valves were properly oriented for the flow direction, and that proper valve orientation existed for selected valve c. Component Tagging The inspectors inspected to verify that valve and equipment tag numbers were in accordance with the as constructed drawings. Relief valve 582A on the supply line to the upper containment vent cooler was improperly labeled as 581 Also the insaectors noted examples of missing tags, In lower containment, the " nspectors noted that valve and equipment tags were in poor condition. Many were broken and should be considered for replacement. Tags were not found on about 25% of the thermowells located in the lines to the room cooler The inspectors noted that the licensee has implemented a tagging program to resolve these types of deficiencies and the inspectors consider that this program would have captured these deficiencie d. Material History The inspectors verified name plate data for all ERCW pumps, screen wash pumps, traveling screens, and strainers against vendor data packages and design documents. The only exception was the four ERCW screen wash pumps which were not ASME code stamped as required by the i design documents. The licensee's contract and bid specifications had been amended during the bid process to eliminate A5ME code requirements due to a lack of bidders. These pumps were bid three different times before the existing pumps were purchased. The licensee stated that they intended to eliminate the code requirement in the design documents because of the prob;em in finding bidders to

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3 , , bid on 'ASME code. stamped pumps of this type for the nuclear industr This observation is being further reviewed by the integrated' design inspection team for technical adequacy. This is considered to be an a additional example. of Violatinn 327,328/87 62-01 for- failure to ' assure applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.

l ' The inspectors verified by sanple of the NB ERCW pump, the CB' screen wash pump, the ' X74 and X57 containment penetration assemblies, the 28-1 emergency diesel generator heat exchanger, and the C component cooling system heat exchanger that adequate material traceability i existed. The inspectors verified that selected portions of piping l (including valves,. flanges, and fasteners) located on the NB ERCW pump discharge., the 2B-8 ERCW strainer discharge, the ERCW inlet to

, the 28-1 emergency diesel generator heat exchanger, the ERCW suction

to the- 2B auxiliary feedwater pump, the ERCW inlet to the 28 l

containment spray heat exchanger, and the CRCW inlet to the C l component cooling system heat exchanger,: met the required size, ' material, and rating requirements, and that material traceability existed. The inspectors identified two exceptions. The studs that hold flow control- valve, 2-FCV-67-67 between two flanges (located upstream of the inlet to the diesel generator heat exchanger) were found to be shorter than called for on the bill of materials. This valve was replaced in 1985 with a new valve. The licensee'was unable to produce either a work order showing the studs had been shortened or a new bill of material showing where new studs were ordered. In evaluating this condition the licensee concluded that proper thread engagement existed and that proper material was installe Consequently, the shorter studs did not appear to present any safety concerns. The inspectors considered that the licensees material l history should. document this condition. The licensee stated that this action has been completed.

L The inspectors identified that the metal flexible isolation hoses located on the inlet and outlet of the emergency diesel generator l, heat exchangers were ordered for a design pressure of 100 psi rather , than the 150 psi pressure rating of the ERCW system. The licensee stated that a typographical error had occurred in the 1973 bid and ' order process which identified the working pressure and temperature as 100 psi and 150 degrees instead of the intended 150 psi and 100 degrees. Fortunately, the vendor had in fact supplied a part capable of operating at a higher pressure rating. During this inspection the licensee went back to the vendor for resolution of this concern and the vendor has now rerated the metal hose for operation at ERCW l- system design pressure. This is considered to be an additional i example of Violation 3.27,328/87-52-01 for failure to assuro applica-ble regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and j instructions.

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j- ! 5 System Maintenance The inspectors observed that a section of pipe on the supply to RHR pump room cooler 28 had a significant amount of corrosion on it. The licensee ultrasonically tested the pipe and performed :n analysis of the necessary wall thickness for continued operation. The pipe was determined acceptable for operation and a work requent was generated to clean and paint the pip The inspectors observed a bent valve stem on valve 6938 with% the annulu This is on the return line of the 28 lower contah.ent l cooler.

l The inspectors _ observed excessive water leakage from strainer 28-B

, during system operatio Additional maintenance and housekeeping deficiencefes were identified during electrical, instrumentation, and housekeeping walkdowns as j delineated in paragraphs 2 and 3 of this repor . Electrical Inspection The examination of electrical components and cables which comprise portions of the ERCW system was accomplished, using a sampling basis, by comparing the TVA as-constructed drawings with actual installations. The comparison was conducted by performing a walkdown of ERCW system components in the ERCW pumphouse, auxiliary building, emergency diesel generator building, control building, and containment. The components selected for examination were essential to the initiation and control of ERCW system functions and provided an adequate basis for determination of system design, compliance, and performanc Electrical Components Inspection -

(1.) Pumps and Motors The examination of four ERCW pumps and associated motors verified that these components were of the type, size and   i performance characteristics specified by the applicable design document Physical location, mounting, and installed configuration were as specified, and name slate data accurately reflected the purchase specification requ rements. The pumps examined were manufactured by Johnston Pump Company and maintain an in-service rating of 11,000 gallons per minut The associated 700HP pump motors were manufactured by General Electric and qualified Class IE for continuous duty servic The following ERCW pumps and associated motors were examined during the inspection:

ERCW Pump QA ERCW Pump RA

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. 6 ERCW Pump NB ERCW Pump P While the installation of the ERCW pumps and: motors was generally determined to be acceptable, several deficiencies were observed with regard to associated electrical components. The examination 'of conduits which house. RTD cabling for ERCW pump motor "PB" upper motor temperature elements disclosed .that several- flex connections had been damaged or broke Additionally,. it appears that inadequate seismic supports had been provided for the vertical runs of several conduits containing RTD cables near ERCW pump motors "RA" and "PB". In this area the inspectors identified several conduits whose installed configuration would provide less that adequate assurance of component function during a seismic event. The inspectors did note that these temperature elements and conduits were not safety related. In response to these observations the licensee issued Work Requests 8243719 and B243721 to repair the broken conduits in this area. Additionally, calculations were performed by the licensee to determine the adequacy of seismic supports for the conduits in question which concluded that the existing installations would perform their intended functio (2) Valve Motor Operators The inspectors examined eleven ERCW system valve operators during the inspectio Field installations were reviewed and compared with approved design documents. in order to determine conformance with design requirements such as material type and qualification, wiring configuration, system interface and general quality of workmanship. The following system valves were examined during the inspection:

2-FCV-67-295 Upper Containment Cooler Containment Isolation Valve 2-FCV-67-296 Upper Containment Cooler Containment Isolation Valve 2-FCV-67-297 Upper Containment Cooler Containment Isolation Valve 2-FCV-67-298 Upper Containment Cooler Containment Isolation Valve 2-FCV-67-066 Emergency Diesel Generator Cooler Isolation Valve 2-FCV-67-067 Emergency Diesel Generator Cooler Isolation Valve 2-FCV-67-123 Containment Spray Heat Exchanger Isolation Valve 2-FCV-67-124 Containment Spray Heat Exchanger Isolation Valve 2-FCV-67-125 Containment Spray Heat Exchanger Isolation Valve _ _ _ - _ _ _ _ _

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2-FCV-67-126 Containment Spray Heat Exchanger Isolation Valve 2-FCV-67-152 Component Cooling Water Heat Exchanger Isolation Valve In ' general, the examination of motorized valve operators 'I associated with the ERCW system indicates that they have been installed in accordance with approved oesign document Applicable wiring diagrams and schematics were compared with field installations and indicated that Class 1E cable installations had been properly terminated at each of the valves examined, and that qualified materials had been specified and _l used during cable termination activitie During the inspection the inspectors also observed several minor deficiencies within the valve motor housings. These included items such as: damaged wires, miscellaneous debris in the limit l switch housing, improper repair of damaged motor leads, I excessive bending of conductors, safety related conduits which ) were not labeled, and missing lock washers on valve operator l mounts. While the nature of these deficiencies was generally considered to be minor and not critical to valve function and operation they do indicate a lack of attention to detail in the conduct of maintenance on safety related component During the period of the inspection, electrical maintenance work requests were written on all motor operated valve discrepancies. Prior to the end of the inspection, all discrepancies were corrected, 3 all work requests were completed and reviewed, and the results ) were presented to NRC inspectors for review. Table I delineates I specific deficiencies for each valv (3) Control Boards ,

An examination of ERCW system related control boards was i accomplished to determine whether system circuits, relays, l breakers, fuses, and switches were properly installed, and were i of the type and performance characteristics specified by approved design document The following control boards were examined during the inspection: j 6900V Shutdown Board 2A-A l 6900V Shutdown Board 28-B 1 Main Control Board 0-M-027 .i 480V Reactor MOV Board 2A2-A l 480V Reactor MOV Board 2B2-8 ! Auxiliary Control Panel 2-L-10 l In general, the examination indicates that ERCW system related 4 components have been installed in accordance with requirement i The condition of items such as the 6.9KV shutdown boards and the 480V reactor MOV boards indicates that the plant staff has been ;

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effective in assuring that vital system components are properly I maintained. Material characteristics were also found to be in accordance with requirements. Breakers, relays, fuses and wiring materials were of the type and size specified for system l performance. Panel wiring was specified by the appropriate TVA and vendor wiring diagrams. With regard to materials, the inspectors noted that several brands of 14 gauge SIS wire, including wire manufactured by "Pirelli" and " Continental," had been installed in the control compartments of the shutdown board These materials are not in accordance with the requirements of the vendors connection diagram 33-47035-D475 Rev. 2, which specifies the exclusive use of #14 type GE-SIS-Vulkene wire for this application. Subsequent discussions with ; licensee engineering personnel indicate that the requirement for use of GE-Vulkene was stipulated by the vendor for use in

manufacturing of the equipment. . Modifications performed on site have allowed for the use of alternate materials, such as Perilli and Continental wire, which maintain the level of qualification and performance characteristics specified in Design Criteria SQN-DC-V-11.3, entitled " Power, Control, and Signal Cables for , use in Category I Structures." ]

The examination of components in Main Control Board 0-M-027, l disclosed several installation deficiencies. This panel houses ~ the ERCW system transfer and hand switches required for manually operating system components. Due to proximity of these devices, redundant divisional cables have been routed into the same panel and installed in barriers such as "Belden Braid" in order to diminish the effects of a locally generated fire. The installa-tion of circuits in enclosures containing more than one division of redundent Class IE wiring is controlled by section 4.4.6.1 of Sequoyah Design Input Memorandum on Separation of Electrical Equipment and Wiring Design Criteria SQN-DC-V-12.2, which states:

  "The minimum separation distance between redundant Class 1E circuits internal to Control Boards, Panels, Relay Racks, etc., shall be six inches of free air space. Wherever this separation distance is not maintained, barriers shall be provided between redundant Class 1E wiring. Within the Westinghouse supplied main and auxiliary control room panels, braided sheath material, such as Belden Braid, is an acceptable barrier for reducing the redundant Class 1E separation to less than six inche The braid shall be used only over wire with teflon or other approad insula-tion. Braid covered wiring for redundant Class IE circuits shall be restrained such that their braids do n;t touch nor shall they be able to migrate with time to touch.'

The requirement reflects the TVA response to NRC question 7.31 of the FSAR which prohibits the use of Belden Braid as a barrier

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material in lieu of the ~ required six ' inch separation. In response;to this question the licensee's FSAR provides the

follow coraitment.. " Wiring for.each train is routed from the

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field to separate -vertical risers, separated horizontally in enclosed horizontal wireways and then routed from the wiring to the enclosed switch module using metallic cover cables. Maximum air space between cables of different trains has been maintaine and in no case does cable from a different train touch or can y migrate with time to touch." Contrary to this requirement the ' inspectors ~ identified ~ numerous examples of redundant wiring

whose braids were in physical contact within panel 0-M-27. Most of the deficiencies noted occurred between risers located in the panel, and were the result of inadequate training of cabling to ; their respective hand and transfer switches. This condition was' ! also identified in some sections of the auxiliary control panel, ; and was in evidence in other portions of the main control ' board In response to this issue the licensee presented CAQR SQP-87-1325IDI, written July 30, 1987. This document identifies the existing deficiencies in panel 0-M-27 and aroposes corrective actions which would require the retrain ng of cables to assure .conformance with the separation requirement How- i ever, the CAQR does not address the existence of similar deficiencies in other portions of the main and auxiliary control

  ' board Consequently, additional work will be required to assure that redundant panel wiring is in accordance with  i separation requirements. The inspectors consider that this deficiency may be generic to all portions of the main and j

auxiliary control panel. This item is considered to be a violation of 10 CFR 50 Appendix B Criterion V for failure to - , accomplish activities affecting quality in accordance with l documented instructions and is designated as Violation 327, 328/87-52-0 During the examination of the auxiliary control panel 2-L-10 the inspectors noted that ERCW flow indicator 2-FI-67-62C was inadequately mounte This is a panel mounted instrument which is held in place by tensioned set screws and a mounting bracke The examination disclosed that the lower mounting bracket'of the instrument was broken allowing movement of the instrument within the panel. In response to this observation the licensee has issued work request B-290012 to replace the lower mounting 4 bracket and has completed this corrective actio l l

  (4) Penetrations The inspectors examined the outboard side of electrical penetrations #30 and #47 which house control circuits for system i
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67 containment isolation discharge valves 2-FCV-67-295, 296, 297, and 298. Field cable to penetration connections were verified and compared with approved design documents which l

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indicate that ERCW system cables 2V3090A, 2V3100A, 2V31108, and 2V3124B, have been installed as specifie I Cable Tracing The examination of selected Class 1E circuits associated with the ERCW system was accomplished'by physical inspection of the actual field routing. Cables were traced by applying a modulated RF signal of 100Hz to selected conductors of each cable. The signal was then monitored from it's initiation source through the length of the cable routing in order to verify that the installed configuration of the cable accurately reflected the approved design routing. The cables selected for examination initiate vital control and power functions within the ERCW system, and represent both electrical divisions. The following cables and associated system devices were examined: Cable # Device Services Service 2PP686A ERCW Fump RA Power 2PP687A ERCW Pump M Power 2PP693A SI Control - Pump RA Control 2PP 694 Aux Control - Pump RA Control IPP7128 ERCW -Pump NB Power 1PP718B SI Control - Pump N8 Control IPP719B Aux Control - Pump NB Control E3020A 2-FCV-67-130 Power 2V2021A 2-FCV-67-130 Control 2V3051B 2-FCV-67-138 Power 2V3052B 2-FCV-67-138 Control The inspectors noted the following conditions: Signal tracing was initiated on cable #1PP7128, which is the motor power feed for ERCW pump N This circuit initiates from the Unit 1 6.9KV shutdown board IB-B and is routed through the plant raceway system and duct banks to the ERCW pumphouse where the motors are located. An RF signal was applied to the phase "A" and "B" bus stabs at the shutdown board and monitored from that point to determine whether the cable had been routed as shown on the computer generated cable pull card. During the examination the inspectors observed that cable 1PP7128 had been routed into tray segment AW-8, which was located between junction box JB-3933 and four inch conduit IPP7.t2 This tray segment is not shown on the cable pull card or in the licensee s computerized cable routing system (CCRS) which provides directions for installation of cable throughout the plan Consequently, the routing of this cable is not in accordance with applicable design document The examination of cable IPP7188 also disclosed deviations from the routing specified on the pull card and in the CCRS. This cable provides ERCW system SI control for pump NB, and is routed from the - _ - _ _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

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J l 6.9KV shutdown board 18-8 to panel 1-R-51 in the control roo ] Design information specifies that the cable should route from tray NF-B to conduit 1PP13408 as it enters the 6.9KV panel. However, physical inspection indicates that the cable also routes through tray ; NK-8, and terminates in the panel via conduit IPP1335B instead of the l conduit specified by desig j

The identified routing deficiencies were discussed with licensee ! engineering personnel in order to determine their root cause. The l discussions indicate that similar problems had been previously I identified by Employee Concern 238.01 and one of these problems, the I routing of cable 1PP7188 through tray NK-8, may have been the result of a 1975 project memorandum on the subject of cable routing which j states. .. ' For computer cable routing the' node point in the cable i tray network nearest the cable entry is chosen as the starting point j for the run. On occasion, a cable will enter the network near an ! intersection. Since some tray designations change at intersections, the computer routing may be such that the short segment of entry tray will not appear on the routing card. When this situation occurs, 1 route the cable in this tray to the conduit even though the tray j designation does not appear on the routing card, providing the ' voltage level of the cable and the tray correspond and the length of the cable from entry point to the intersection is not more than 10 feet." This memorandum was later incorporated into the requirements i of licensee maintenance and alteration instruction (M&AI)-4 via revision 7 to that document and implemented during plant modifica-tions. This allowance was later removed from M&AI-4 by revision and , is not in the current version of that documen Consequently, i numerous cable installations may be router.' through raceway segments which are not shown on approved design document Although the routing of cable IPP7188 into tray segment NK-B may have been the result of implementing the requirements of this memorandum, the deficiencies identified in the routing of cable 1PP7128, however, can not be attributed to this document in that, the length of cable IPP7128 routed in unscheduled tray segment AW-B is longer than 10 feet, and is not at a point of entry or exit from the raceway networ Additionally, the routing of cable IPP7188 into conduit 1PP13358 instead of IPP13408 is clearly outside the scope of M&AI- I In response to these observations the licensee has initiated a j technical evaluation of the identified deficiencies to determine ; whether important quality attributes such as thermal loading, voltage

segregation, and electrical separation have been compromised. While formal response has not been received, the preliminary evaluation indicates the existing installation is technically acceptabl However, of more generic concern are the implications associated with . wide spread use of the previously mentioned project memorandum and i the quantity of routing deficiencies identified in the team's ) relatively small inspection sample. The licensee has indicated in a ! response to employee concern 238.01 that an evaluation of the I l _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _

_ - - _ _ _ - _ _

4 practices and procedures utilized in routing and installing cables at Sequoyah will be initiated and will include a review of relevant , installation and inspection records stored on site. This review will ! be. utilized in establishing the accuracy of the CCRS and determining i the adequacy of cable installations -at Sequoyah. This review is currently programmed to be implemented as a post restart long range - progra The inspectors have concern that the licensee's programs which were I implemented to resolve electrical concerns, such as the ampacity review program, depend on the unverified assumption that cables are routed pursuant to cable pull cards and computerized cable routing system. As evidenced by this inspection finding, this assumption may ' not be valid, The inspectors consider that additional action will be required to be taken by the licensee to properly bound the scope of this concern as either isolated or generic and to ap3ropriately resolve the concern. In pursing this resolution the 1"censee should also provide technical justification for allowing 10 foot cable sections to enter _ cable trays not identified on the routing card This justification should include the elements of separation, : segregation, volumetric tray loading, and thermal loadin General Construction Specification G-38, " Installing Insulated Cables Rated Up to 15, 000 Volts," requires in paragraph 3.1:

"Among other things, cable pull cards or cable schedules specify the route a cable is required to take between points of terminatio Measures shall be taken to ensure that this route is followed in installing the cable. If instances occur where cables cannot be installed exactly as indicated on the cable pull card or cable schedule (see section 3.2.1.8.2.b for one example), the engineering project shall be notified for dispositio Alternate routes shall not be selected by OC/NUC PR without the approval of OE."

As stated above cables IPP718B and 1PP7128 were not routed in accordance with cable pull cards or cable schedules. With the exception of the routing of cable 1PP7188 into tray segment NK-B j there is no documentation or indication that alternate routing was I appropriately allowed and approved by engineering. This failure to I comply with cable installation instructions is considered to be an additional example of violation 327, 328/87-52-0 In the case of routing of cable IPP718B into tray segment NK-B, the inspectors have been unable to ascertain that adequate technical I justification existed for the previous M&AI-4 allowance for routing l cable sections less than ten feet through unspecified tray segments j if the cable enters the network at an intersection poin This is ; considered to be an additional example of violation 327,328/87-52-01 ' for failure to correctly translate applicable regulatory requirements

i

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and the design basis into specifications, drawings, procedures, and instruction Technical Specification Compliance System valves were also reviewed to ascertain compliance with applicable plant Technical Specifications. Valve stroking, stroke timing, overcurrent trips, fuse inspection, breaker inspection, and thermal overloads were evaluated for specified system valves and determined to be in accordance with requirements. The reviews conducted are listed in Table I . Instrumentation and Control Inspection The inspectors examined the instrumentation associated with the 47 ERCW instrumented functions delineated in Table III. This examination was conducted to verify conformance with design specifications and instrument calibration and functionabilit Instrumentation Functionability Inspection The B28-B strainer pressure differential gage 2-PDIS-67-490 E/F was observed to be pegged high at greater than 6 psid and yet the automatic backwash function of the strainer was not operating as designed. The licensee confirmed the gage to be within calibration and cleared the high differential pressure reading by manually initiating strainer backwash. In evaluating this condition the inspectors observed other operational concerns associated with this instrumentation which are discussed in paragraph The 2A traveling screen level differential transmitter, 0-LDT-67-487 was observed to be disconnected from both the inlet and outlet screen level detectors and the inlet detector had been removed from its well. There were no provisions for preventing debris from entering the impulse line ports on the transmitter and there was no indication that the work was being controlled through either the licensee's modification program or maintenance / work request program. This level j transmitter is safety related and is designed to activate the ERCW screen wash pumps, upon high level differential between the screen inlet and outlet. This in turn is designed to activate the traveling j screens upon attaining normal pump operating pressure. This automatic function prevents clogging of the screen and assures proper j suction pressure for the ERCW pump. Again, the inspectors consider ' that modification of safety related systems without proper control and review is a significant deficiency with generic implication .

This item is considered to be an additional example of violation ! 328/87-52-01 for failure to subject adequate design control measures ; and approval to the work which disconnected this level transmitte I i The inspectors noted that while the screen level differential i transmitters were safety related, the level detectors, which are ! i

i

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,.

designed'to input level-signals to the transmitters', were not. This'

; appeared to be inconsistent. ' Additionally, the inspectors noted'that neither the safety related leve1~ transmitters nor-the level detectors-are- listed ' on the ' licensee's Critical Structures, Systems, : and !
     '
-Components (CSSC) list, SQA-134. These concerns are identified as an additional 1 example- of violation 327, 328/87-52-02 for failure to accomplish activities affecting quality in accordance with documented instruction .
~ In -evaluating this condition the inspectors observed other opera-tional concerns associated with this instrumentation which are discussed in paragraph During the. inspection of ERCW instrumentation ~in the. auxiliary building, flow transmitter,' 0-FT-67-206, which monitors ERCW flow to the station air compressors, was found to have its electrical ,

transmitter removed from _the fluid portion of the instrument. - Two ! work requests (WR-8220452 and WR-8226246) were found on the trans- I mitter, however, after reviewing the WR tags the inspectors were unable to Ldetermine' if either tag covered the current condition of the transmitter. The licensee provided copies of the two active WRs to .the inspector and WR-8226246 stated that the transmitter was broken and needed to be replace The licensee ~ further provided a design change request requesting a replacement transmitter be acquired because the current. type of transmitter is no' longer available. This item has been identified by the licensee as an item t to be completed prior to Unit 2 restart.' The inspectors observed that this instrument is safety related and is designed to provid alarm capability to the control room operators so that the non-safety related piping to the station ~ air compressors can be isolated by operator action on a high flow condition indicative of a pipe brea This instrument as well as its other train counterpart are not listed . in the licensee's CSSC list, SQA-134. Again, this is considered to I be an additional example of violation 327,'328/87-52-02 for failure i to accomplish activities affecting quality in accordance with i documented instruction During the walkdown of the ERCW system instrumentation in the ERCW l pumping station, the inspectors o?a rved the following condition with ) the installed instrumentation on tw 18-8 ERCW straine . ,J GAGE READING NAME 1-PI-67-490A 168 PSIG strainer 1B-B inlet pressure 1-PI-67-490B 0 PSIG strainer 1B-B outlet pressure 1-PDIS-67-490E/F 0.6 PSID strainer 18-B differential pressure l 1-PI-67-490A was reading in excess of normal system operating pressure and the reading on 1-PDIS-67-490E/F was inconsistent with 3 the readings of the inlet and outlet pressure gages. The licensee ; evaluated the instrumentation and determined that the inlet and ' i

l I i

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V L

l outlet pressure gages were out of tolerance and neede'd calibratio Upon completion of the calibration the differential pressure gage was checked and found to be reading correctly. The licensee stated that because the inlet and outlet pressure gages were not considered safety-related they were only calibrated on an as. requested basi The inspectors had no.further concern with this observatio During the walkdown of. the ERCW system instrumentation in the emergency diesel generator building the inspectors observed the following conditions with the installed instrumentation for the emergency _ diesel generator heat exchanger i

GAGE READING NAME 1-FI-67-280 >750 GPM EDG 182 ERCW supply 2-FI-67-280 >750 GPM EDG 282 ERCW supply 2-FI-67-74 >750 GPM EDG 181 ERCW supply , l All three of the above gages have scales of 0-750 GPM and two of the gages were found pegged high. The licensee informed the inspectors 1 that these gages were in calibration and that they were functioning properl Additionally, during the walkdown of the ERCW system instrumentation in the auxiliary building the inspectors observed the following conditions with the installed instrumentation for the upper i containment cooler GAGE READING NAME j l 1-FI-67-269 >25 GPM upper containment cooler 'l 20 discharge 1-FI-67-335 upper containment cooler

  >25 GPM 20 supply    )

Both gages have 0-25 PSID scales and were found pegged hig Again these gages were determined to be in calibration and functioning properl Paragraph 6 addresses the additional operational aspects of these observation The ERCW temperature indicators located on the ERCW discharge lines from each emergency diesel generator (EDG) are impossible to read from the floor or the EDG platforms due to their location and the ; angle at which they are installed. The following instruments are ; involved: ) 1-TW-67-71 1-TW-67-76 l l _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _

     - _ _ _ _ _ _ - _ _

16 j 1-TW-67-276 1-TW-67-279 2-TW-67-71 2-TW-67-76 1 2-TW-67-276 2-TW-67-279 RE-90-134 on radiation monitor RM-90-134 was not operating properly because of a cocked plug in the rotometer. During the course of this inspection, the licensee corrected this proble ; b. Valve Functionability Inspection l The inspectors observed the performance of the following instrumented' valves under loss of power / air: ; 2-FCV-67-186 containment spray pump room cooler 8 supply I 2-TCV-67-129 upper containment vent cooler A supply ! 2-TCV-67-132 upper containment vent cooler C supply 2-TCV-67-140 upper containment. vent cooler D supply The inspectors verified that the valves actuated satisfactorily to their fail-safe position on a loss of power and a loss of air i pressure to the valv c. Inspection of Environmental Protection of Instrument Components ! The inspectors noted problems with the sleeves used to route instrument sense lines from the ERCW pumps in the upper level of the ERCW pump house to the next lower level where the affected I transmitters and instruments were located. Specifically ERCW j instrumentation drawings 17W600-2 and 17W600-3 require vertical ) sleeves for the ERCW instruments to be sealed and filled in accordance with the following note: ) l

 " Field to seal sleeves by filling them to a thickness of  l 12" i 1" with DOW Corning's 3-654B Silicone RTV foam and using  l Johns Manville Cerablanket or Cerafiber as the damming   l material."      l Drawing 37W206-3, however, requires vertical sleeves for the ERCW instruments to be sealed and filled in accordance with the following note:

I

 " Pack all sleeves with DOW Corning 3-6548 Silicone RTV foam or equal to the thickness of the wall or floor using" Johns Manville Cerabianket or Cerafiber as the damming materia The above two notes provide conflicting instructions on the actual installation of damming material within the vertical sleeves. These conflicting instructions are further complicated by a note on detail

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 . - _
.

w . , Q '.

.
   -17 g
.u-P sketch A-6' and D-6. of drawing 37W206-6 which directs the water-tight .-
- caulking of both ends of the sleeve The; licensee stated that this damming 5 material was to' prevent'

flooding from the upper level' to the.next lower level whereL safety related electrical . transformers, motor control-. centers, and instruments were located.-

,
'The inspectors. visually examined several vertical' sleeves -(listed,-

below) and noted the:following:

 -
 :All sleeves examined were sealed on the top onl *

l All sleeves extended approximately 6 inches up from the floor instead of 2 inches as shown on drawing 37W206-6i !

      -i All sleeves- appeared to be dammed with black,= sheet foam insulation, not the material specified in either drawing not '
 *

The amount of damming material in the verticalisleeves appeared to ~ be insu ~ fficient. ' The distance from the bottom of .the sleeve to the bottom of-the damming. material- on several of the sleeves, was as listed below: i INSTRUMENT DISTANCE FROM OTHER BOTTOM REMARK

  .0-PT-67-433 26 inches   j 0-PT-67-437 30 inches 0-PT-67-441 31 inches 0-PT-67-445 31 inches 0-PT-67-457 31 inches 0-PT-67-465  seal was broken and air was leaking 0-PT-67-468 28 inches 0-PT-67-480 28 inches These measurements reflected substantially less damming material was installed than required by either of the licensee's  ]

drawing !

An inspector observed the licensee's removal of sealant and insulation from the vertical sleeve for the 0-PI-67-468 instrument line. During the removal the inspectors were able to i confirm some of the above listed items. The material used as the damming material was black foam pipe wrap insulation instead of the specified material and the sleeve was only packed to a depth of approximately 2.5 inches. After the completion of the inspection of the vertical sleeve the licensee filled the sleeve with the correct material and to the correct depth. Because of I

I l

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this finding it appears that' all vertical sleeves in the ERCW pumping station first level will need to be repacked and sealed to the specification of the design document ~ The licensee had initiated a work request to perform the repacking and-resealing of these sleeves to the design specification l These deficiencies are considered to be additional examples ,of-Violation 327, 328/87-52-02 for failure to prescribe and accomplish activities affecting quality in accordance with the specified j drawings, i i The inspectors examined instrument line slope and heat tracing within ! the ERCW pumping statio ERCW instrument lines that are exposed.to ! atmosphere are required to be sloped to allow self-draining to l prevent the accumulation and possible freezing of stagnant water in 'j accordance with SQN-DC-V- The inspectors traced all ERCW l instrument lines in the ERCW pumping station that could possibly be exposed to freezing conditions. The licensee stated that this condition was applicable only to the upper . level of the ERCW pump l hous The inspectors considered this licensee assessment was ! correct. The inspectors determined that all of these lines appeared ! to be correctly sloped to allow the self-draining of any wate l These instrument lines are also required to be heat traced in-accordance with system design and drawings. The inspectors identified that the RA ERCW pump discharge pressure instrument line ! did not have heat tracing as required by drawings 17W600-2 and l 17W600- Some of the other ERCW pumps did have the required heat tracing, however, it was not clearly evident that all instrument i lines shown to have heat tracing in fact do because of the lagging on i the lines. The failure to install heat tracing on the RA ERCW pump discharge pressure instrument line pursuant to drawings, 17W600-2 and-3 is considered to be an additional example of violation 327, ; 328/87-52-02 for failure to adequately accomplish activities affecting quality in accordance with specified drawing d. Instrument Valve Tagging Inspection The inspectors walked down the ERCW instrumentation lines in the ERCW pump stations using plant drawings (17W600-2, 3,13, and 47W845-5) and observed the following discrepancies; The following high point vent valves were not found on drawing 17W600-13: 1-67-1022A, 2-67-1024A, 2-67-1023 The following isolation valves are not labeled on the afore- ; mentioned drawings 0-67-1006A, 0-67-1005A, 0-67-1006B, 1 2-67-1023A, 2-67-10.'3E, 2-67-1024C, 0-67-1015A, 2-67-10238, 2-67-1024 I .. _____._..-_-__._.._m__. _ _ _ . _ - _ .--

__- -_

i The following instrumentation contained both orange (division A) ' and white (nondivisional) or brown (division B) and white labels from the instrument line tap to the terminal instrument: 0-PI-67-4618, 0-PI-67-480, 2-PI-67-4908, 0-PI-67-468, 2-PI-67-490 The inspectors walked down .the ERCW instrumentation lines in EDG

building and the auxiliary building using plant drawings (17W600-2, 3,13, and 47W845-5 and observed the following discrepancie The following high point vent valves were not found on drawing 47W845-1 through 47W845-6: 1-67-8328, 1-67-916B , 1-67-915B , 1-67-8318, 1-67-9148, 2-67-8328, 2-67-833B, 1-67-8338, 2-67-915B, 2-67-916 * The following valves were not labeled: 1-67-911B , 1-67-8278, 2-67-9118, 2-67-8278, 2-67-911C, 2-67-8270, 2-67-912B, 2-67-8268, 2-67-912C, 2-67-826 The following instrumentation contained both orange and white or brown and white labels from the instrument line tap to the terminal instrument: 1-FI-67-69, 2-FI-67-69,.1-FI-67-74, 2-FI-67-74, 1-FI-67-277, 2-FI-67-277,1-FI-67-280, 2-FI-67-28 As noted in paragraph 1, the licensee has implemented a tagging program to resolve the in plant tagging discrepancies such as those referred to herein and it appears that this would accomplish the 1 proper tagging of all valves associated with the ERCW instrumentation once fully implemente With respect to the fact that valves critical to instrument function-ability are not specified on plant drawings, the licensee was able to demonstrate that the specified instrument isolation valves were shcwn I without labeling on instrument series drawings which are working level J drawings for instrument technicians. The inspectors were unable, ! however, to identify the specified high point vents on any drawing This is considered to be an additional example of Violation 327, , 328/87-52-01, for failure to assure applicable regulatory require- j ments and the design basis are correctly translated into specifica- 1 tions, drawings, procedures and instruction ) , Maintenance and Housekeeping Inspection The inspectors noted the following maintenance and housekeeping i ' discrepancies during their walkdown of the ERCW system instrumentatio A 24 inch pipe wrench was found in the EAM-A cable tray on the !

middle level of the QA and RA section of the ERCW pump statio The wrench was removed from the cable tray.

( _ - _ _ _ _ _ _ - _ _ _ _ _ _ .__ >

_ _ _ _ - .

Many of the instrumentation stands were badly rusted where the support came in' contact with the floor. The inspectors had no technical concern with this condition affecting thrt support of the stands and note it as a preservation issue onl Several of the armored cables associated with the heat tracing on the screen wash pumps and associated piping were badly damage Action was initiated by the licensee to correct this item during the inspectio The conduit for the D-A screen wash pump was missing a cover and , had water inside the conduit. Action was initiated by the i licensee to correct this item during the inspectio The following components were identified as having rust accumulation during a walkdown of the auxiliary building. The 4 inspectors had no technical operability concern with this i condition and note it as a preservation issue onl TW-67-402 1-TW-67-403 1-TW-67-404 1-TW-67-407 2-TW-67-402 2-TW-67-403 2-TW-67-404 2-TW-67-405 2-FE-67-191 2-FCV-67-186 1-FE-67-187

All ERCW strainers either had water leaks or showed signs of previous water leakage and some, particularly strainer 28-8, were exhibiting excessive rust that appeared to be potentially detrimental to the support. The licensee examined this ccndition and analyzed it as acceptable for use. The inspectors concurred with the licensee's analysis and results and this condition is noted as a preservation issu . Structural Support Inspection The inspectors walked down the ERCW system and preselected a sample of mechanical snubbers, fixed pipe supports, ba!,e and support plates, which appeared questionable, for detailed review. The review was to ascertain technical adequacy of the structural support and mounting associated with ERCW mechanical and electrical components, Snubber Inspection The inspectors selected nine pipe snubbers associated with the ERCW system and performed visual inspections, with the aid of mirrors, measuring gauges, and levels, to assess compliance with the i as-installed configuration. The criteria used for inspection was based on the appropriate as-constructed drawings and vendor manual i __. o !

l .The below listed attributes were used:

Match drawing for position, orientation and typ Examine support plates, bolts, and fasteners.

' i Examine for deterioration and leak . Ensure moving parts are free. Verify current acceptable testing - and preventive maintenance for each snubbe '

Inspections were performed on the following nine snubbers:

Snubber 1-67-1-ERCWH-58E

Snubber 47A450-25-357-RRY '

Snubber 47A450-25-356-DSSZ

Snubber 47A450-25-340-DSY ;

Snubber 47A450-25-340-0SZ

Snubber 47A450-25-441

Snubber 47A450-25-442

Snubber 47A450-25-384

Snubber 47A450-25-442-DSSZ During the inspection, numerous grease fittings were observed on snubbers and strut brackets which were painted and no grease was apparent on the connection. The licensee advised the inspectors that an employee concern identified in April 1986, discussed the problem with grease fittings and strut connections not moving freely. Based on that concern, the licensee had taken the following actions to ensure that spherical bearings on snubbers were maintained in an . operable condition. SI-162.1 " Snubber Visual Inspection (hydraulic l and mechanical)" implements Technical Specification 3/4.7.9 which requires visual inspections be performed on all safety related snubbers every 18 month Part of the acceptance criteria provided by SI 162.1 is to rotate the snubbers by hand in both directions on the spherical bearing The snubber should rotate freely which is verification that the spherical bearings are operating properl Corrective maintenance is required to those snubbers resisting rotatio The licensee performed calculations (identifier 2147) on January 26, 1987 which assessed the impact on snubber performance when periodic lubrication was not performed. The conclusion stated i in the calculations was that any adverse impact on snubber

performance is considered minor. Additionally, the licensee committed that a preventative maintenance program for snubber lubrication would be implemented by March 1988. Based on the licensee's corrective action program and performance of calculations to assess impact, the inspectors had no further questions on this matte All snubbers inspected were found acceptable and in compliance with I drawing requirements.

l b. Fixed Pipe Support Inspection

The inspectors selected ten fixed pipe supports (including spring hangers, support brackets and hanger rods of different ratings) on .

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     -

l

i l l u the. ERCW system and performed visual inspections, with the aid of i-mirrors, measuring gauges and levels to assess compliance with j as-installed configuration. The criteria used for the inspection was j based on the appropriate as-constructed drawings, i The below listed attributes were used:

       , Match drawings for position, orientation and typ . Ensure moving components are free and lubricate Inspection was performed for the following. pipe supports:
       ,
      '
 -

Hanger Rod 1-ERCWH-232

Hanger Rod 1-ERCWH-234 ]

       )
 -

Spring Can Support 2AFDH243

Strut 2AFDH244

Spring Can Support 2AFDH245 3

Spring Can Support 2AFDH246 l

Hanger Rod 1-HGR-67-ERCW-208-6

Hanger Rod 1-HGR-67-ERCW-207-3

Hanger Rod 1-ERCWH-233B

With the exception of Hanger Rod 1-ERCWH-233B, no problems were , identified with the fixed supports inspecte ' The following discrepancies were identified with strut assembly i 1-ERCWH-2338 relative to the requirements specified on the as-built ' drawing, sheets HERCW-330C and HERCW-330 The pin-.to pin dimension specified on the drawing is 39 inche The measure dimension is 42 inches; 3 inches longer than ' specified in the drawin L

The drawing depicts the rear bracket pin to be installed ! vertically. The rear pin is actually installed horizontall The drawing requires a locknut installed end tightened against the strut to prevent loosening. The locknut on the shaft was loos The drawing specifies a dimension of 5 inches for left hand thread engagement and 6 inches for right hand thread engagement for the strut assembly. The actual measured lengths are 7 inches on the left side and 3 inches on the right sid The records were reviewed which certified the strut assembly was inspected and accepted per drawing requirements on March 15, 197 Support Modification Request Number 67-735 issued January 24, 1979, ! identified the tolerance differences and was accepted by engineerin ' - ____- _______

_ _ _ _ _ _ _ _ - _ _ _ - - - _ _ __

  .       ,
.
' ~

w , 2 , .However, . the : drawing wasi not revised to reflect the as-built dimension 's The licensee reviewed the' deficiencies ' described above' and on-

 : August 11, 1987,.. provided the technical justification for the observed conditions and took corrective action. by. tightening the locknut, Further, the licensee provided'the inspector with'a copy.ofL a program presently in progress on Unit 2, titled " Functional Verification of Supports for Rigorously Analyzed Category 1 Piping".    '

The program is controlled by an engineering instruction CEB-0121.83 which requires field . verification (usually walkdown inspections) of

 ' all . pipe supports on rigorously analyzed Category 1 piping. The instructions require an -inspection checklist, with inspection attributes. defined in the program. Attachment 3 to. CEB-0121.83 specifies attributes for strut and snubber assembly inspections which should identify pipin deficiencies
  . This program on all should rigorously ensure analyzed that the Catego,ry 1
     "as-insta11ed'

configuration' is- consistent with' existing design data. Conditions-found in the verification program such as the items discussed above will be analyzed in accordance with an engineering instruction CEB-C1 21.80. titled " Program Plan for Calculations Regeneration of- Pipe

Supports on Rigorously Analyzed Category 1 Piping-Sequoyah 2". The

program. discussed above is scheduled for completion prior to restart of Unit '2 Jand the inspectors consider that the attributes of that-program inspection would have identified the deficiencies noted b 'the inspectors once strut assembly 1-ERCW-233B was . inspected by that progra Based on the licensee's program in progress for inspecting andsreanalyzing Category 1 pipe supports, and based on the analysis and corrective actions taken on this particular ' support, the inspectors have no additional concern in this are Support and Base Plate Inspection The inspectors selected 10 base and/or support plates on the ERCW system and performed visual inspections to assess the comp ~11ance with as-installed configuration. The criteria used for inspection was based on the appropriate as-constructed drawings and vendor's manual The below attributes were used: 1 Ensure position, orientation and type are in accordance with design drawing . Examine bolts and fasteners for distortion, cracks and other !

nonconformances.

l L Inspection was performed on the following supports plate Support 2067HPPE37W206-1-06 _ _ _ _ _ _ - - _ - _ _ _

- _ _ _ _

l '24 i

Support 2067HPPE37W206-1-07

Support 2-ERCW-276-01

Support 2067HPPE37W206-3-04

 -~ Spring Can Support 2-AFDG-243
 -

Hanger Rod 1-HGR-67-ERCW-208-6

Hanger Rod 1-HGR-67-ERCW-207-6 ,

      '
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Support HGR-67-ERCW-207-4

Support HGR-67-ERCW-208-4

Support HGR-67-ERCW-207-2

No problems were identified during inspection of the support plate l To verify the seismic adequacy of the as-installed mounting, the inspector selected two floor mounted 300KVA transformers and one ERCW i model A strainer for revie The equipment was all located in the ; ERCW pump hous l The 300KVA transformers were seismically qualified by Wyle Laboratories and connected to the test table using thirteen bolt Field inspection found the equipment was connected to an embedment i plate by welding, different than the method used to seismically l qualify the equipment. The licensee provided the inspector with a copy of engineering calculations which justified a welded mounting ' arrangement in lieu of bolting. The calculations required a fillet weld, 14' inches long on 12 inch centers. The drawing also described a fillet weld of the same dimensions. Measurements on the weld found the minimum weld requirements were met. Therefore, the mounting of the transformers was found to be acceptabl The ERCW motorized backwash strainer was qualified by calculations i performed by PX engineering on June 2,1976. The calculations ) assumed a connection to a sliding base using 24 bolts. Drawing 38N336, Rev. O " Miscellaneous Steel ERCW Pumping Station Embeded Steel" show the sliding base connection made using eight 1 inch j; diameter bolts. On October 9,1980, a Field Change Request (FCR) M3027 was approved and changed the specified eight bolts to five bolts. The inspector questioned the adequacy of the installed condition and requested a copy of the calculations showing the five bolt connection. The licensee was initially urable to produce the 3 l original calculations. On August 7,1987, the licensee performed calculations justifying the five bolt connection. Review of these calculations by the NRC IDI team reflected that the five bolt arrangement was acceptable for mounting the strainer to the sliding l bas Additional review of the entire strainer baseplate is now I being accomplished by the NRC IDI tea Subsequent to performance of this calculation the licensee was able to retreive the original calculations justifying the reduced bolting arrangement for mounting the strainer to the sliding plate. The inspectors had no further concern in this are _ _ _ - _ _ _ _ _ _

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l

1 Independent Measurements and Weld Record Review The inspectors performed independent measurements and non destructive examinations of selected portions of the ERCW system in order to ascertain as constructed adequacy. Emphasis was placed on welding and quality control activities during this inspectio Appendix A of this report further delineates the details and results of these inspection ERCW Piping Independent Measurements Nine pipe welds were magnetic particle tested and visually examined satisfactorily. One additional pipe weld was also visually examined and found acceptabl Twenty pipe / component sections were ultrasonically tested for wall thickness and found acceptabl ERCW Structural Component Independent Measurements Sixty-six structural anchor bolts were ultrasonically tested for embedment depth and found acceptabl Approximately 150 individual structural welds associated with 38 supports and hangers were visually examined with the following noted deviations from drawing requirements: Support 1-ERCW H-501 one weld n;issing Hanger Rod 1-ERCW H-232A one weld missing Hanger Rod 1-ERCW H-234 one weld missing Spring Can 2AFDH-246 one weld was 6 inches in lieu of 8 inches specified on the design drawing Support 1-HGR-67-ERCW-208-4 one weld had slag which was rejectable by visual weld acceptance criteria (VWAC) Support 1-ERCW H-222 two welds missing l The specific deficiencies were analyzed by the licensee and determined to be technically acceptable without repai ; These findings are identical to the type of findings which were self identified by the licensee in the welding reinspection program. In the inspection sample associated with that program the licensee identified deviations from drawing requirements which were also all analyzed as acceptable without repair. The inspectors consider that although deviations from design requirements exist with the , structural welds, there is no indication from either the licensee's I weld reinspection program or from this inspection that physically deficient or unserviceable cupport welds exist in the plan .

Consequently the inspectors consider that the licensee's commitment to analyze structural weld deviations, as they are identified, for serviceability is appropriate corrective actio _ - _

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t 2 ConcreteCompressiveStrengthfndependentMeasurementsL h Concrete' compressive strength of the- ERCW pump' house and intake structure and containment. crane wall was examined by four windsor probe testing sauples with satisfactory results, d .- Pipe Weld Record. Review The inspector 1 selected- seven pipe welds on the ERCW ' system and performed a review of.the weld records for compliance in the area o welder qualification, weld procedure qualification and nondestructive- 1 examination results.

, The following data was examined for seven pipe welds: i

Weld No. -0ER 14077 (Pipe to Flange weld, 1/78) Class'of Weld-TVA Class (CL)C (ANSI B31.7) Detailed Welding Procedure-GTSM-11-0-3-B Welder-6HBB (Stensil No.)

Weld Metal-E7053 and E7018 Nondestructive Examination (NDE)-Fitup, Visual and Magnetic. Particle Pipe Dimensions-Diameter 24", thickness 0.375"

Weld No.-0ER 1500 (Pipe to Flange weld, 11/78).

Class of Weld-TVA (CL)C (ANSI B31.7) Detailed Weld Procedure-SM-11-B-3 Welder-6FAA Weld Metal-E7018 NDE-Visual and Magnetic Particia Pipe Dimensions-Diameter 6", thickness 0.280"

Weld No.-0ER 9477 (Reducer to Pipe weld, 9/77) Class of Weld-TVA (CL)C . Detailed Weld Procedure-SM-11-B-3 ! Welder-6BBB Weld Metal-E7018 . NDE-Fitup, Visual, and Magnetic Particle Pipe Dimensions-Diameter 6", thickness-0.280"

Weld No.-0ER 13409A (pipe to Coupling weld, 5/80) . i Class of Weld-TVA (CL)B Detailed Weld Proceduro-GT-11-0-1-A J Welder-6BGL Weld Metal-E7053 I NDE-Fitup, Visual, and Magnetic Particle Pipe Dimensions-Diameter 2", thickness 0.154" l

Weld No.-0ER 040M2 (Pipe to Sweepolet weld, 8/77) Class of Weld-TVi (CL)C s _ _ - _ _ _ _ - - _ _ _ _ _

. , -

L l 27'

Detailed Welding Procedure-GT-11-0-1-A Welder-60AB l' Weld Metal-E7053 I' NDE-Fitup, Visual, and Magnetic Particle f

l' Pipe Dimensions-Diameter 4", thickness 0.237"

Weld No.-0ER 2154 (Pipe to Pipe weld 4/74) Class of Weld-TVA (CLC)C Detailed Welding Procedure-SM-11-B-3 Welder-6 WAG Weld Metal-E7018 NDE-Visual and Magnetic Particle Pipe Dimensions-Diameter 24", thickness 0.375"

Weld No.-0ER 2173 (Elbow to Flange weld, 10/73) Class of Weld-TVA (CLC)C Detailed Weld Procedure GTSM-11-0-3-8 Welder Metal-E7053 and E7018 NDE-Visual and Magnetic Particle l Fitting Dimensions-Diameter 18", thickness 0.375" The licensee used only qualified weld metal and therefore was not , required to record the weld metal heat number. The type of weld metal used was adequate for the welds. Welder qualification and thickness requirements were acceptable. Welder continuity records were available for welds made after October 1974. Starting in November 1984, the licensee revised continuity record forms and these later forms were available in records. Four out of the seven welds were covered under this later period. Three of the welds were made in the earlier period and therefore continuity records were not available, but other types of records show no revocation of welder qualifications during that time period. There was no requirement to maintain these records past two years of operation and consequently Sequoyah Unit 2 is outside of the scope of record retention require-ments for those earlier continuity records as delineated in quality assurance procedure ID-QAP-17.2, dated June 8,198 The inspectors reviewed the nondestructive examination acceptance records for all seven pipe welds. Some welds had fitup inspections and all had visual and magnetic particle or liquid penetrant inspections. The performance qualification tests and the retest records for the nondestructive examination personnel performing these tests were examined and found to be acceptabl e. Structual Weld Record Review fourteen structural weld records were examined by the inspectors for compliance in the areas of non destructive examinatio The j structural welds were welded to AWSD 1.1. The welder, weld metal < type, and exact detailed welding procedure used were not recorded and

are not required to be by the applicable cod The hanger and structural welds were examined only by visual inspection as require '

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__ - -. , __ _ _ - - . .. f 28: The .. licensee inspection personnel were from the mechanical ~ grou The applicable" codes did not require maintenance of training and qualification records for inspectors performing. visual inspections until 1981. Therefore, no. training records were available for the inspectors ' associated with the sampled welds. The following;14 hanger. structural weld records were reviewed for an acc'eptable weld inspection records,- the date .of inspection, and the revision 'of the inspection instruction No. 75 that was-in place at the time that the hanger was inspecte Hanger No. 2067HPPE37W206-1-07 .

     .
     .
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An acceptable visual inspection was performed October 1980 to~ inspection instruction 75 (II 75) revision Hanger No. 2067HPPE37W206-1-06 . An acceptable visual inspection was. performed October 1980 to II 75 revision Hanger No. 206HPPE37W206-3-04 An acceptable visual inspection was performed September 1979 to II 75 revision Hanger.No. 1067HPABERCWH-232 An acceptable visual inspection was performed October 1977 to II 75 revision Hanger No. 1067HPABERCWH-233 An acceptable visual inspection was performed September 1977.to II 75 revision Hanger No. 1067HPABERCW-502 An acceptable visual inspection was performed October 1977 to II 75 revision Hanger No. 1067HPABERCWH-501 An acceptable visual inspection was performed October 1977 to II 75 revision Hanger No. 1067HPDERCWH-208 An acceptable visual inspection was performed July 1977 to II 75 revision 1.

'

Hanger No. 1067HPABERCWH-207 An acceptable visual inspection was performed March 1979 to II 75 revision 2 l

Hanger No. 2067HPR246450-25-356 l An acceptable visual inspection was performed November 1980 to l II 75 revision 4.

L--____-________-________--_-_ __ _ _ _ _ .. ______ _ _ _ - _ _ _ - _ _ _ _ - _ _ _

Hanger No. 2067HPR247450-25-340 An acceptable visual inspection was performed February 1981 to II 75 revision Hanger No. 2067HPR247450-346 An acceptable visual inspection was performed September 1980 to II 75 revision Hanger No. 2067HPR247420-25-350 An acceptable visual inspection was performed September 1980 to II 75 revision Hanger No. 2067HPR247450-25-351 An acceptable visual inspection was performed July 1980 to II 75 revision All areas reviewed were found acceptabl . Operational Issues Several operational issues were identified during this inspection as a result of further evaluation of specific concerns associated with the mechanical and instrumentation and control inspections delineated in paragraphs 1 and These issues are discussed below: Uncontrolled Valves l l The inspectors noted that the sets of oil cooler and bearing cooling in line valves located on the skids for the safety injection pumps and centrifugal charging pump, which were not labeled nor identified on drawings, were also not properly controlled. Specifically these valves were not required to be aligned in the system operating instructions for ERCW, safety injection or centrifugal charging systems nor were they included in the Technical Specification sur-veillance instructions associated with monthly valve lineup verifi-calions for those systems. Additionally the valves were not locked, sealed, or otherwise secured in position. The inspectors are concerned that these valves, if mispositioned could prevent cooling water flow to the safety injection and centrifugal charging pumps thus disabling those pumps if they had been called upon in an accident. Although there was no apparent control over the posi-tioning of these valves, the inspectors could find no direct evidence that the valves were ever positioned in a manner such that the affected pumps were not adequately cooled. This condition is considered to be a result of violation 327, 328/87-52-01 since these valves were not formally identified on drawings. Additionally this is considered to have resulted in a condition of non compliance with Technical Specification surveillance requirement 4. 7.4. a, from initial plant start up to shutdown in August 1985, in that these valves were not verified to be in the correct position every 31 days to demonstrate both ERCW loops operable. The inspectors are _

n

concerned that had this deficiency not been identified during this inspection, this condition would have remained uncorrected at unit

.startu The inspectors questioned the licensee with respect to how in ifne instrument and vent valves between primary root valves and the instruments were controlled. The licensee informed the inspectors that control was maintained through skill of the craf The inspectors consider that skill of the craft in itself is not an adequate control for assuring that instrument valves are properly aligned and periodically verified to be aligned. This is c'onsidered to be an additional example of violation 327, 328/87-52-02 for failure to establish and implement written procedures for activities affecting qualit Disabling Of Safety Functions Without Proper Review Or Control Over Compensatory Actions During a review of the instrumentation associated with the ERCW strainers, as discussed in paragraph 3, it was determined that the automstic functions associated with those instruments had been defeate6 cM that those functions were now being manually performe Through discussions with the licensee it was determined that these instruments are safety-related and that the automatic functions are addressed in the licensee's FSAR. During preoperational testing in 1980, standard operating differential pressures across the strainers were found to be higher than the setpoint of 2 PSID for strainer backwash actuation. The preoperational tests also identified a problem with the operation of the backwash valve which caused the valve to continually cycle. The licensee issued a test deviation report and requested that the setpoint of the strainer differential pressure be raised to 6 PSID and that the high differential pressure switch for the backwash valve be removed from service. These actions appear to have been properly implemented and the strainers continued to perform their automatic functio A licensee information or temporary instruction for the operations group (night order) dated May 16, 1986, required the removal of power from the ERCW strainers due to the use of continuous sodium hypochlorination for micro-biological induced corrosion (MIC) control. It also required operators to closely monitor ERCW strainer differential pressure indicators ensuring that the strainers were maintained below the differential pressure setpoint (6 PSID) through manual backwash operations. This action appears to have been taken without a safety evaluation being performed pursuant to 10 CFR 50.59. A condition adverse to quality report (CAQR SQP871282) was issued in July 1987, !

regarding the removal of power to the ERCW strainers. This CAQR stated that a safety evaluation had not been completed prior to the { j issuance of the night order. This safety evaluation relating to the 4 removal of power from the ERCW strainers was completed only after the issue had been brought up during this inspection. The inspectors are _. __ I

L 1 1,

l i concerned that : this evaluation does not adequately address system operation in an accident mod During a walkdown of the ERCW instrumentation' the inspectors noted

that the aressure and pressure differential gauges associated with 28-8 stra'ner were reading as follows: GAUGE READING -NAME

2-PI-67490A 124 PSIG , Strainer 28-8. inlet ; pressure 2-PI-67-4908 100 PSIG Strainer 28-B outlet pressur PDIS-67-490E/F >6 PSID Strainer 28-B-

     . differential pressure The 2-PDIS-67-490E/F reading of greater than. 6 PSID meant that the . J indicator was pegged high and the automatic backwash function of the !

o ' strainer was not operating.as designed. The licensee was informed of I the gauge readings' and the strainer was backwashed which reduced the i L abnormal reading into the normal range. The inspectors reviewed L attachment C (outside routing . log sheets) for operations sectio , letter administrative (OSLA) 99 which indicated that.the differential t pressure across the 28-B strainer had exceeded the maximum value of 6 j , PSID on August 1,1987, on the 7 a.m. - 3 p.m. shift. The pressure j !- was also noted to be in excess of 6 PSID on the August 2,1987, through August 5,1987. The inspectors also reviewed copies of i 0$LA-99 for the month of July 1987, and found the following ' times ' that the differential pressure across an ERtw strainer exceeded 6 PSI DATE STRAINER DATE STRAINE A-A 7-14-87 1A-A 7-13-87 28-B 7-12-87 28-8 7-12-87 IB-B 7-11-87 28-8 7-11-87 IB-B 7-10-87 2B-B 7-10-87 IB-B According to ' the OSLA, any abnormalities were to be noted in the remarks sectio The OSLA also listed a minimum, normal, and maximum value, however, the excessive differential pressures were never noted in the remarks section. During a conversation with an assistant unit operator (AV0) an inspector was told that the AU0 is to note any abnormal reading on the OSLA and that the OSLA is reviewed by the i responsible assistant shift engineer (ASE). The AVO stated that the ! review of the OSLA constituted the relaying of information regarding ' abnormalities and that sometimes there was no verbal exchange of information beyond that which was covered in the OSLA. The AVO 1 further stated that work requests (WR) were generated by the AVO l finding the abnormality if the AVO felt the abnormality was severe enough. The AVO stated that the determination of the severity of the

l

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- _ - - _ - _ _ _ _ __ _ _ ._ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _

        - _ _ _ _ _ ,

abnormality was left to the AVO depending on how far the reading was out of specificatio During a follow-up conversation with an ASE and another AU0, an inspector was told that Technical Specification related data which is recorded on the OSLA is also used by operations personnel in the control room for inclucion -in the appropriate surveillance' instructions. This was conf f rmed by operations personnel in a further conversation with the inspector The inspectors also noted examples where readings were not recorded in the OSLA due to other work taking precedenc The use of the OSLA-99 to record safety-related plant readings, especially when these readings are expectea to prompt compensatory actions for defeated automatic safety functions, is considered inappropriate in that this is not a PORC approved and reviewed ; procedure. The OSLA is also not retained for plant records which i makes verification of past operations impossibl l i During a review of the instrumentation associated with the ERCW .; traveling screens, as discussed'in paragraph 3, it was determined that the automatic functions associated with the screen level detectors and level differential transmitters had been defeated and that those functions were now being manually performe The screen level differential transmitters, on sensing a high level differential, are designed to start the screen wash pump The screen wash pumps are designed to activate the traveling screens upon attaining operating pressure. These functions assure adequate suction pressure for the ERCW pumps by cleaning the screens if they should become blocked. Through discussions with the licensee it was determined that these instruments are safety-related and that their automatic functions are addressed in the licensee's FSA The ERCW traveling screens were tested during preoperational testing in 1980 and the level detectors were found to be defective which ' required the screen wash pumps and the traveling screens to be manually placed in a continuous run mode. As a result of the failed preoperational test, a test deviation report was issued requesting a changeout of the defective level detectors and that continuous manual operation of the screen wash system be initiated. The requested Engineering Change Notice, ECN-5758 for resolution of this problem was not issued until 198 Due to maintenance and operations concerns for the screens and screen wash pumps and because work associated with ECN-L-5758 had yet to be completed, a Temporary Alteration Control Form (TACF-82-258-67) was written in 1982. The TACF called for the lifting of leads from the control circuitry, thereby, preventing an automatic start of the screen wash system on a loss of signal or high level differentia The screen wash pumps and the screens were removed from continuous operation and screen washing was to be accomplished through use of a timer every 60 hours and intermittent manual operatio An i

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i s !

Jinadequate safety. evaluation for . this change to safety-related

 -
= equipment appeared .to have been completed because it stated that the equipment was'not mentioned.in the FSAR. A licensee information or
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temporary. instruction for the operations group(night order)-dated May 16, 1986, required the removal of: power from the ERCW screen wash pumps, again due to-the use of continuous sodium hypochlorinatio It also required operators to closely monitor ERCW traveling screen differential 1evel indicators (local and control room)' ensuring that the ' screens were maintained below the differential. level setpoint ~( ir.ches of water) .through manual screen wash operations. No safety evaluation. appears to have been aerformed with respect to these t actions. In April 1987, an Unrev'ewed: Safety Question Determination (USQD-"-31 R1) was written which identified specia1 ' requirements whirb sst be. met for, continued operation of the ERCW screen wash sy" .; i n its present ' configuration. The USQD stated that the . automatic timers. were never successfully tested during the i preoperational test and that the differential level annunciator associated with the traveling screens in the control room was unavailabl Special instructions of the USQD required the comple-tion of procedures regarding. the daily manual operation of the 4 traveling screens .and screen wash pumps to be completed prior to Unit 2 restarti This safety evaluation did not address the fact that l-power had been removed from the screen wash pump as a result of the aforementioned night order. A condition' adverse to quality report (CAQR.SQP871282) was issued in July 1987, regarding the removal of _ power to the ERCW screen wash pumps. This CAQR stated that a safety

. evaluation had not been completed prior to the issuance of the night order. The CAQR also stated that the differential level indicators for the traveling screens should be eliminated from the right order because these detectors were ino3erabl At the present time the replacement of the level detect'on elements has still not been accomplished and procedures governing the manual operation of the screen wash system are still being developed. Also, a 50.59 review relating to the removal of power from the ERCW screen wash pumps was completed only after this issue was brought up during the. last week of the inspection and again did -not adequately address system operation in an accident mod The inspectors have concern that as currently configured the ERCW system may not be able to fulfill its safety function should the .

screens or strainers be clogged during an event. There is no reliable indication in the control room that would indicate that clogging of either screens or strainers had occurred and there are no provisions for assuring maintenance of clear screens or strainers during an event. Additionally there is no indication that this prob 1.em would have been satisfactorily resolved by the licensee prior to Unit 2 startup without this inspection findin With regard to these two problems the inspectors consider that weaknesses may exist in the engineering-operations interface which contributed to an apparent lack of appropriate engineering input to

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l

l 34 temporary resolution and . compensatory measures implementation and also which prevented timely permanent resolution of the proble The inspectors note that this observed practice of disabling safety-related equipment and invoking compensatory measures without proper evaluation and control . may have generic implications and consider that the licensee should identify all safety-related l functions which are disabled, ' acknowledge completion of adequate safety evaluations and to establish adequate control measures over requisite compensatory actions. This area will be reviewed during the NRC restart readiness revie i These concerns are considered to have enforcement implications which ; are currently under evaluatio Pending completion of that ' evaluation this item is identified as unresolved item 327, 328/87-52-0 During the review of OSLA 99 the inspectors discovered that the readings for lake temperature are also recorded therein and ha exceeded the maximum value of the OSL No notes were made in the remarks sectio DATE READING 08-01-87 85.31 07-28-87 8 Since the unit is currently in Mode 5 this does not constitute an operability . issue. The inspectors reviewed surveillance instruction SI-3 log sheets from August 1,1985, to August 21, 1985 and found no entries recorded where lake temperature exceeded the limit' of 83 degrees which is the maximum temperature allowed by Technical Specifications for Mode 1-4 operation. The inspectors also requested copies of OSLA-99 to review for that same time period but were informed by the licensee that the OSLA-99 logs were not retained as plant record c. Observation of Abnormal Flow Conditions As previously indicated in paragraph 3, during the walkdown of the ERCW system instrumentation in the emergency diesel generator building the inspectors observed the following conditions with the installed instrumentation for the emergency diesel generator heat exchanger GAUGE READING NAME i 1-FI-67-280 >750 GPM EDG 182 ERCW supply 2-FI-67-280 >750 GPM EDG 2B2 ERCW supply 2-FI-67-74 >750 GPM EDG 181 ERCW supply

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All three of the above gauges have scales of 0-750.GPM and two of the gauges were found pegged high. The licensee informed the inspectors that these gauges were in calibration and that they were functioning properly. The inspectors questioned the apparent practice of using undersized gauges to monitor ERCW flow and the licensee informed the inspectors that the increased flow was due to the unusual ERCW lineup currently being used at tho facility. The inspectors requested information concerning the reason for the unusual flow through the

EDG coolers, however, the licensee was unable to supply this information prior to completion of the inspectio Also during the walkdown of the ERCW system instrumentation in the auxiliary building the inspectors observed the following condition with the installed instrumentation for the upper containment cooler ! GAUGE READING NAME 1-FI-67-269 >25 GPM upper containment cooler 2D discharge 1-FI-67-335 >25 GPM upper containment cooler 2D supply Both gauges have 0-25 GPM scales and were found pegged hig The licensee again stated that these gauges were in calibration and informed the inspectors that the increased flow was due to. the unusual ERCW Ifneup currently being used at the facility. The inspectors requested information concerning the reason for the unusual flow through the coolers, however, the licensee was unable to supply this information by the end of this inspectio The inspectors are concerned with the potential configuration control and equipment degradation aspects of this observation for both the EDG heat exchangers and upper containment coolers and this item is identified as Unresolved Item 327, 328/87-52-05 pending completion of licensee action to determine how and why these conditions existe l l

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TABLE I-

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  > DEFICIENCIES IDENTIFIED IN MOTORIZED VALVE OPERATORS 2-FCV-67-295 Minor crackir.g on spare limit switch rotor at! the roll' pi '
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Minor cracking on the close' limit switch rotor at the roll pi Two loose ~ terminal' screws, cutoff tiewraps.in-limit switch are '

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 -

Lock washers' missing on two' valve operator l mounting bolt FCV-67-296

T3 motor bend' radius was less than minimum permitte lTwo valve operator mounting bolts missing lock washer Oil film in limit switch are Cutoff tiewraps left in limit. switch area. . 2-FCV-67-297 i

 '~
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Loose flexible conduit elbow on control wire conduit.

L - Lock washer missing on two motor operator mounting bolt Debris left in limit switch area.

! - Five control wire leads had the inner insulation cu One lead was cut to bare conducto . 2-FCV-67-298

The T2 motor lead bend radius was less than the minimum permitted.

L 2-FCV-67-152 1 ,

Oil film in the limit' switch are The motor conduit was not labele Debris was left loose in the limit switch are ;

2-FCV-67-123

Green conductor of the control cable had minor charring on the outer insulatio ' 2-FCV-67-124 L

Debris left in the limit switch area.

4 2-FCV-67-125

The white and orange control wires had minor cuts in the outer insulatio The red and green control wires had abrasion damage to the outer insulatio _ _ ________- __ - - _ _ - _ -

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The T1 motor lead has been repaired using taping material Conduit 2V2200A and conduit 2V2202A were not labele Debris in the limit switch are FCV-67-126 1

No deficiencies note FCV-67-66

Two flat washers were loose on spare terminal studs with no terminal ! nuts to prevent the washers from falling onto wired termination The ground wire from the operator casing to the terminal housing was not installed. The valve operator. technical manual details the ground wire installatio .-FCV-67-67

The limit switch housing was loos The ovound wire from the operator casing to the terminal housing was not installed. The valve operator technical manual details the ground wire installatio i l l l l l ______________

_ _ _ _ _ _ _ _ _ _ 3.- l TABLE II ! E . l TECHNICAL t- * SPECIFICATION- 4.6. .6.3.3 4.8.3.1.a.2 4.8.3.1.a.3 4.8.3.1.6 4.8. PROCEDURE- SI166.66 SI16 SI25 ST27 SI26 SI251 FUNCTION STROKING TIMING OVERCURRENT BREAKER FUSES-OVERLOADS INSPECTION 2-FCV-67-66 * * * * * SAT 2-FCV-67-67 * * * * * SAT 2-FCV-67-123 * * * * * SAT 2-FCV-67-124 *' * * * * SAT 2-FCV-67-125 * * * * * SAT 2-FCV-67-126 * * * * * SAT

2-FCV-67-152 * * * * * SAT 2-FCV-67-295 SAT SAT SAT SAT SAT SAT 2-FCV-67-296 SAT SAT SAT SAT SAT SAT : 2-FCV-67-297 SAT SAT SAT SAT SAT SAT 2-FCV-67-298 SAT SAT SAT SAT SAT SAT

  * Not applicable since valves are not containment isolation valves, i
         <
         .I l
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_ __ TABLE III LISTING OF INSTRUMENTATION WHICH WAS WALKED DOWN AND REVIEWED FLOW' ELEMENT TRANSMITTER / INDICATOR- NAME 1-FE-67-69* 1-FI-67-69* EDG 1A1 Discharge ~1ow

2-FE-67-69* 2-FI-67-69* EDG 2Al. Discharge Flow 1-FE-67-74* 1-FI-67-74* EDG 181 Discharge Flow

.2-FE-67-74*  2-FI-67-74*  EDG 281 Discharge Flow 1-FE-67-277* 1-FI-67-277*  EDG 1A2 Discharge Flow 2-FE-67-277* 2-FI-67-277*  'EDG 2A2 Discharge Flow 1-FE-67-280* 1-FI-67-280*  EDG 182 Discharge Flow 2-FE-67-280* 2-FI-67-280*  EDG 282 Discharge Flow 1-FI-67-122*  Containment Spray HX 18 Supply Flow 1-FI-67-136*  Containment Spray HX 1A Supply Flow 2-FI-67-122*  Containment Spray'HX 28 Supply Flow-2-FI-67-136*  Containirant Spray HX 2A Supply f;ow 0-FE-67-206* 0-FT-67-206*  Station Air Compressor {

Header 1A Supply Flow 0-FE-67-209* 0-FT-67-209* Station Air Compressor Header 18 Supply Flow < 2-FE-67-226* 2-FI-67-226* CCW HX 2C Supply Flow 1-FE-67-267* 1-FI-67-267* Upper Containment Cooler , 18 Discharge Flow j 1-FE-67-269* 1-FI-67-269* Upper Containment Cooler ID Discharge Flow 1-FE-67-276* 1-FI-67-276* EDG 1A2 Supply Flow 2-FE-67-276* 2-FI-67-276* EDG 2A2 Supply Flow 1-FE-67-280* 1-FI-67-280* EDG 182 Supply Flow ; 2-FE-67-280* 2-FI-67-280* EDG 282 Supply Flow i 1-FE-67-332* 1-FI-67-332* Upper Containment Cooler 1A Supply Flow 1-FE-67-333* 1-FI-67-333* Upper Containment Cooler , 10 Supply Flow ! 1-FE-67-334* 1-FI-67-334* Upper Containment Cooler IB Supply Flow 2-FE-67-335* 2-FI-67-335* Upper Containment Cooler i 20 Supply Flow

. PRESSURE INDICATOR TRANSMITTER SWITCH NAME 0-PI-67-433*    ERCW Pump JA Discharge Pressure

_______________-___ _

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 ,,,  ,
  /

1 , -

Table 1III 2

PRESSURE INDICATOR TRANSMITTER SWITCH .NAME -

-(cont'd)
.0-PI-67-437*           ERCW Pump KA Discharge Pressure 10-PI-67-441*-           ERCW Pump LB

< .

  .
            .DischargeLPressure:
.0-PI-67-445*           ERCW Pump'MB Discharge Pressure 0-PI-67-457*           ERCW Pump PB Discharge Pressure-
'0-PI-67-461*-           ERCW Pump QA Discharge Pressure-0-PI-67-465*           ERCW Pump.RA Discharge Pressure-
-0-PI-67-468*           Screen Wash Pump.CB Discharge' Pressure 0-PI-67-480*     0-PS-67-480*      Screen Wash Pump CB Discharge Pressure 1-PI-67-490A*     1-PdIS-67-490E/F*      Strainer B18-8
.             Inlet Pressure 1-PI-67-490B*           . Strainer B18-8 Outlet Pressure 2-PI-67-490A*-    2-PdIS-67-490E/F*      Strainer B28-B~

Inlet Pressure 2-PI-67-490B* Strainer B28-8

   ,         Outlet Pressure-LEVEL ELEMENT  INDICATOR   TRANSMITTER      NAME 0-LE-67-470A* 0-LDI-67-470B*   0-LDT-67-470*      Screen AA Out7et Level 0-LE-67-470B*           Screen-AA Inlet Level TEMPERATURE ELEMENT  CNTLR/INDIC   VALVE       NAME 1-TW-67-71*          EDG 1A1 Outlet Temperature
.2-TW-67-71*          EDG 2A1 Outlet Temperature 1-TW-67-76*          EDG 181 Outlet Temperature   i 2-TW-67-76*          EDG 281 Outlet  !

Temperature

m __._.._ __ __ _ _ - _ _ - _ _ _ . _ _ _ _ _ .____._u__ _ . . _ _ _ . . . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ __ m

Table III ,

'-

TEMPERATURE ' ELEMENT- CNTLR/INDIC VALVE NAME 1-TW-67-276* EDG 1A2 Outlet Temperature 2-TW-67-276* EDG 2A2.0utlet Temperature 1-TW-67-279* EDG 182 Outlet 1

    . Temperature 2-TW-67-279*    EDG 282 Outlet Temperature RADIATION MONITOR   NAME RM-90-133*   Discharge Header Radiation Monitor RM-90-134*   Discharge Header Radiation Monitor
* Instruments that have been walked dow >

l { [_ _ __ _ . _ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ - - - _ _ _ _

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..

APPENDIX A NRC.- NDE Mobile Van Inspection Activities-Introduction During ' the' period of' August 3 thru 14,1987, a NRC special. projects' team inspection was conducted at TVA's Sequoyah sit The NRC mobile Nondestructive

- Examination -(NDE) laboratory assisted -in this' inspection. Selected safety related piping, ' structural and support weldments in the essential raw cooling water system were inspecte The purpose of the. NRC mobile laboratory was to perform independent-
- measurements and non-destructive examinations in . order to verify the adequacy
-

of the Sequoyah welding quality control program. This was accomplished by reperforming. selected examinations required of the licensee.by the regulations and codes and evaluating the results. . In addition to verification .of the required examination ~, several other confirmatory examinations designed to verify. confarmance with material specifications were performed and compared to site quali yt assurance record Magnetsc Particle Examination of Pipe Weldments Magnetic Particle Examination (MT) was performed on Essential Raw Cooling Water System (ERCW) piping welds. Nine (9)' weldments' and adjacent base material (% inch on either side.of weld) were examined per NRC procedure NDE-6,.Rev. See attachment No.1 for the specific items examined and the results of the examinatio Results: No violations were identifie Visual Examination of Piping Weldments Ten (10) pipe weldments and adjacent base material-were visually examined per NRC procedure. NDE-10, Rev. O, Appendix The examination was performed using visual aids such as lights, mirrors . and gauge These examinations were performed to determine the general condition of the pipe weldments and adjacent base material,. specifically checking for cracks, misalignment or other visual discontinuities. See Attachment No. I for the specific items examined and the results of the examinatio .Results: No violations were identified.

l Thickness Measurement of Piping Wall l Ten (10) weldments and adjacent pipe material at three locations were examined per NRC procedure NDE-11, Rev. 0 using a Nortec NDT thickness gauge. Minimum wall thickness was determined by using an ASTM standard pipe size and nominal wall thickness chart. See Attachment No. 1 for specific items examined and the results of the examinatio Results: No violations were identifie Appendix A 2 Windsor Probe During the inspection samples of concrete compressive strength were taken using the Windsor Probe on two walls of the 28 intake structure at elevation 699, one en an original Another sample was taken at elevation 720' pour area on the and floor one ontwo between a repair ERCW are pumps in the 28 area. A fourth test sample was taken inside unit 2 containment on the crane wall in the same proximity as a Windsor Probe test performed by the licensee.

A comparison of test results with concrete pour data, compression test data and design requirements were made between the NRC tests and the licensee's result From these tests it was concluded that the concrete examined met the design strength requirements.

During the Windsor Probe sampling, the inspector visually examined concrete surfaces in the immediate area for spalling and deterioration, no spalling or apparent deterioration was present. See attachment no. 3 for specific items examined and the results of the examination.

Results: No violations were identified.

Visual Examination (Hanger / Supports) Included in this inspection were hangers, support components and attachments selected from the Essential Raw Cooling Water System (ERCW) and the ERCW supply to the Auxiliary Feedwater System (AFW). Those hanger and supports selected for inspection were examined for specific attributes as outlined in Nuclear Construction Issues Group (NCIG-01), Visual Weld Acceptance Criteria (VWAC-02) Rev. 2, site drawings, isometrics and visual examination data reports. Some components were inspected with protective coatings applied, therefore, cracks and fusion type discontinuities could not be evaluated. Those attributes looked for on components with protective coatings were fillet weld and flare bevel size, location, leg and throat size, length of weld, gross unaercut, large porosity and overall workmanshi Those components with the protective coating remcved were inspected to the specific attributes outlined in the Visual Weld Acceptance Criteria (VWAC) Rev. 2.

Several deficiencies such as missing or undersized welds were identified during this inspection. These types of deficiencies were previously identified as a generic issue with regard to plant hangers and supports and TVA, as part of their welding reinspection program, is analyzing and dispositioning such deficiencie The specific deficiencies identified by NRC were analyzed and dispositioned by the licensee as acceptable for use without repair. See Attachment No. 2 for specific items examined and the results of the examination.

Results: No violations were identifie ._ _ ' 6 Appendix'A- 3 Anchor' Bolt Examination-

,
.Includedlin this inspection was 'an. ultrasonic examination (UT) of ' sixty-six
'
(66) anchor bolts of.various-lengths and diameters. Samples.were taken from structural components : on. the. Essential . Raw Cooling Water System (ERCW). ' The examination was performed using TVA General Construction Specification No. G-32 and . associated drawings. See Attachment No. 2 for. specific items examined and
'
'the results of the examinatio Results: No violations were identifie . Summary'and Conclusions InLsummary, 9 ERCW pipe welds were . examined by magnetic particle,'10 ERCW pipe -
. welds were examined visually and ultrasonically,- 38 hangers and component
      '

supports;in the ERCW and AFW systems were visually inspected, 66 anchor bolts were ultrasonically examined >for length, and concrete compressive strength was measured in 4 locations.using a Windsor Prob The quality of piping welds inspected was generally good. -The inspection of

' hangers and ' supports. identified discrepancies such as missing or undersized welds. Similar types of hanger and support deficiencies were previously
. identified by the-licensee and the licensee's welding reinspection program has-addressed the disposition of such deficiencies. The specific- deficiencies identified by the NRC have been acceptably dispositioned. Measurements of concrete compressive : strength confirmed that minimum specified compressive strengths were exceeded and in the one case compared, agreed well with the licensee's measuremen The 'NRC independent measurement and non-destructive examination activities identified no unacceptable conditions or violation Attachments:

Attachment No. 1 is a tabulation of specific pipe weldments examined and result Attachment No. 2 is a tabulation of specific hanger / support components examined

~and result Attachment No. 3 is a tabulation of specific Windsor Probe-Concrete compression i

' tests and result l L l

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l ( ) L TABULATION OF PIPE WELDS EXAMINED AND j RESULTS OF INDEPENDENT MEASUREMENT PROGRAM ) l i APPENDIX A !

-ATTACHMENT NO. 1~     Page 1 of 1 )

l l l l l V. IPIPE IPIPE DRAW l REMARKS l SYSTEM / WELD l CLASS l M. l VISUAL l WALL THICK lDI l THICK l i ERCW 14077 3 acceptable . acceptable acceptable l 24" .375 lERCW - 129 l l l l l l l ERCW 1500 3 acceptable acceptable acceptable 6" .280 lERCW - 5 l l [ l l l l l

ERCW 9477 3 acceptable lacceptable acceptable 6" .280 reducer

ERCW - 9 l 1 l l l l l 1ERCW9476 3 acceptable acceptable acceptable 8" .322 reducer lERCE - 9 l l l l l l l ERCW Pentration 68 2 acceptable acceptable acceptable 2" .552 pene- ' lTVA - 48N406 l l l l l l ltration I ERCW 13409A l 2 acceptable acceptable acceptable 2" .154 , lERCW - 122 l l l l l l l ERCW 4073 3 . acceptable acceptable acceptable 4" .237 lFRCW - 22 l ! l l l l l ERCW 2154 3 acceptable acceptable . acceptable 24" .375 IERCW - 9 l l l l l l ERCW 2173 3 acceptable acceptable acceptable 18" .375 lERCW - 9 l l j l l l l ERCW 2FLV-67-146 . 3 N/A : acceptable . acceptable , 24" .375 lERCW 47K450-65 l l l l l l l l l l l l l l l

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Appendix A i Attachment No. 2 INDEPENDENT MEASUREMENT PROGRAM Support And Hanger Inspection VT VWAC Date: August 3 - 14, 1987 Page 1 of 3 Site: Sequoyah ITEM IDENTIFICATION DWG./ ISO ACCEPT / REJECT REMARKS 1 2067HPPE37W206-1-06 37W206 Acceptable Support (1) 2 2ERCW-276-01 47A053-120 " Support / Anchor 2ERCW-276-01 Bolt 3 2067HPPE37W206-1-07 37W206 " Support

l ' 4 MK12 38N337-2R5 Support Cable Tray

" "

5 MK13 Support Cable Tray

6 MK4 & MK5 38N337-1R4 Support l Cable T:ay

7 2067HPPE37W206-3-04 37W206 Support 8 IBB ERCW MCC XFMR As Built " Base Mount 300 76-87230 KVA. Dry Type Transformer 9 28B ERCW MCC XFMR As Built Base Mount 300

76-87230 KVA. Dry Type Transformer

         "
    *10   1-ERCW H-501 48N1216-R5  Support
         "

11 1-ERCW H-502 48N1216-R5 Support

12 1-ERCW H-232 47W450-4R8 Hanger Rod

    *13   1-ERCW H-232A 47W450-4-R14 "

Hanger Rod

14 1-ERCW H-2338 48N1374-R6 Hanger Rod

    *15   1-ERCW H-234 4W450-4R8 "

Hanger Rod

16 1-67-1-ERCW H-58E 47W450-4R8 Snubber

17 2AFDH-243 47W427-1R3 Support Spring Can

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. _ . __ - - Page 2 of 3 Appendix A Attachment 2 Date: August 3 - 14, 1987 Site: Sequoyah ITEM IDENTIFICATIO DWG./ ISO ACCEPT / REJECT REMARKS

^
'18 - 2AF0H-244 47W427-1R3 Acceptable Strut
    "

19 2AFDH-245 47W427-1R3 Spring Can

    "
*20 2AFDH-246 47W427-1R3  Spring Can
    "

21 1-HGR-67-ERCW-208-6 47W450-2 Hanger Rod

" "

22 1-HGR-67-ERCW-207-6 Hanger Rod

   " "
#23 1-HGR-67-ERCW-207-3   Support !
   " "

24 1-HGR-67-ERCW-208-3 Support

" "

25 1-HGR-67-ERCW-207-4 Support

   " "
*26 1-HGR-67-ERCW-208-4   Support
   "
'27 1-HGR-67-ERCW-207-5  "

Support

" "

28 1-HGR-67-ERCW-208-6 Support

    "
(1)*29 1-ERCW H-22 47W450-3R8-  Support / Anchor Bolt
    "

30 47A450-25-356 RR(Y) 4YA450-28-356 Support

31 47A450-25-356-DS(SZ) 47A450-23-3 Support

32 47A450-25-340-DS(Y) 47A450-25-340 Support

23 47A450-25-340-DS(Z) 47A450-25-346 Support !

34 47A450-25-346 47A450-25-340 Support

35 47A450-25-350 47A450-25-350 Support

36 47A450-25-351 47A450-25-351 Support

"    "

57A450-25-348 47A450-25-348 Support

      ]
"    "

47A450-25-349 47A450-25-349 Support

* Denotes supports that this inspection identified as having discrepancie l However, TVA s welding reinspection program had previously identified the same type of discrepancies and committed to analyzing for suitability for service

_ l -. Page 3 of 3 Appendix A Attachment 2 all discrepant supports foun All asterisk supports have been analyzed and accepted by calculation #. Support was located 8 inches from a pipe elbow rather than 32 inches specified on the drawing. The condition had been previously analyzed as acceptable in the licensee's alternate analysis progra (1) Ultrasonic examination of anchor bolt

J J

1

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   .-_

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I I Appendix A Attachment 3

WINDSOR PROBE SAMPLES ; ,

      'l Area Required PSI NRC(PSI) TVA(PSI) Reference / Location 1 3000 28 day 7200 N/A ERCW pumping station El. 692 west wall closure poured 0-I-1CPPEERCW-1-06 Ref. Dw >

31W211-1 Gen. Const. Spec. G-2 j and Inspection Instruction 95

 '2 3000 28 day 7725 N/A ERCW pumping station E1. 682 wall ERCW-1-31 0-I-1CPPEERCW-1-31 Gen. Cons Spec. G-2 and Inspection Instruction 95 3 3000 28 day 6675 N/A ERCW pumping station E1. 705 floor slab 0-I-1CPPEERCW-01 Re Dwg. 31W211-4 Gen. Const. Spe G-2 and Inspection Instruction

4 >6750 PSI 7725 8000 Ultimate design strength in

  *2.175 *2.12 excess of 6750 PSI Reactor Bld Crane wall between E1. 773.42 and 73.75 RB-2-16A East 2-R2CPR2RB2-16A Gen. Cons Spec. G2 * Avg. probe extension

_ - - _ - _

-.

I APPENDIX B August 19, 1987 Exit Interview Attendees Licensee Employees

*S. White, Manager, Office of Nuclear Power
*C. Fox, Deputy Manager, Office of Nuclear Power
*C. Mason, Deputy Manager, Office of Nuclear Power i- *R. Gridley, Director, Nuclear Safety and Licensing
*J. Kirkebo, Director,. Nuclear Engineering
*J. LaPoint, Deputy Site Director
*R. Charlson, Advisor, Office of Nuclear Power
*R. Bass, Office of Nuclear Power
*G. Rogers, Office of Nuclear Power
*R. Buckholz, Site Representative, Office of Nuclear Power
*L. Nobles, Plant Manager !
*M. Ray, Deputy Director, Nuclear Safety and Licensing
*T.. Chiles, Manager - Material
*S. Smith, Office of Nuclear Power
*J. Hosmer,' Site Project Engineer
*B. Alsup, Corporate Licensing Manager
*D. McCloud, Manager - Generic Licensing
*W. Andrews, Assistant Division Director, Nuclear Quality Assurance
*G. Minton, Nuclear Quality Assurance
*D. Wilson, Chief Nuclear Engineer
*M. Harding, Site Licensing Manager
*L. Martin, Site Quality Manager
*T. Ippolito, TVA Licensing
* Tormey, Engineering Assurance i
*S. Johnson, Administrative Department
*S. Fisher, Director, Nuclear Business Management
*T. Shea, Nuclear Engineering l
*B. Pennell, Nuclear Engineering
*J. Staub, Nuclear Engineering i
*W. Raughley, Nuclear Engineering i
*G. Kirk, Site Compliance Licensing Manager '
*M. Cooper, Plant Operations Review Staff
*T. Chapman, Browns Ferry Nuclear Plant
*M. Milad, Sergeant and Lundy
*M. Bowideriri, Sergeant and Lundy
*E. Rothong, United Engineers NRC Management
*J. Keppler, Director, Office of Special Projects i
* Ebneter, Director, Division of TVA Projects
*G. Zech, Assistant Director for Inspection Programs
*J. Zwolinski, Assistant Director for Projects
* Pierson, Chief, Plant System Branch
;

I

    ._-___-_-_ _ _-_a

_ _ _ _ _ - . . _ - _ _ . - _ _ _ _ _ - _ - - _ _ _ . _ _ _ _ _ _ _ Appendix B 2

*A. Marino, Chief, Reactor Operations Branch
*J. Donohew, OSP Projects Branch Chief
*B. Grimes, Deputy Director, Division of Reactor Inspections and Safeguards
*E. Imbro, Section Chief, Division of Reactor Inspections and Safeguards
*J. Clifford,. Technical Assistant to Director, Division of TVA Projects NRC Resident Inspectors      5
*K. Jenison
*M. Branch
*P. Harmon
 .

_ _ _ _ _ _ _ _ . . }}

IR 05000327/1987052

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