ML20195K095

Provides Status of Issues Required to Be Resolved Prior to Restart of Sequoyah Unit 2.Related Documentation Encl

ML20195K095
Person / Time
Site:	Sequoyah
Issue date:	01/13/1988
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
TASK-PICM, TASK-SE SECY-88-011, SECY-88-11, NUDOCS 8801290160
Download: ML20195K095 (43)

Text

_ _ _ _ _ _

t>R MGo l

h l

yi.

/;

January 13, 1988 3.g 1

SECY-88-11

/

os, A oj POLICY ISSUE l

(Commission Meeting)

For:

The Comissioners l

From:

Victor Stello, Jr.

Executive Director for Operations

Subject:

UPDATED STATUS OF STAFF ACTIONS FOR TENNESSEE VALLEY AUTHORITY SEQUOYAH UNIT 2 RESTART

Purpose:

To provide the status of issues required to be resolved prior to the restart of Sequoyah Unit 2.

1 Discussion:

The staff briefed the Comission on July 23, 1987. The Comission Paper was SECY-87-173, "Status of Staff Actions Required Before Restart of Sequoyah 2", dated July 16, 1987. The staff and TVA have completed a number of actions since SECY-87-173 was sent to the Comission. provides the status of key issues which must be resolved prior to the restart of Sequoyah Unit 2 in one of the following categories:

(A) NRC and TVA are in agreement regarding the handling of probiem; NRC review schedule consistent with lice'nsee schedule; (B) HRC and TVA are in agreement regarding the handling of the problem; however, potential schedule impact exists (for subcategory B1, the licensee is preparing submittals or still implementing significant actions and for B2 the NPC has the issue under review); and (C) questions exist regarding the handling of the issue.

The Category B definitions have been modified since SECY-87-173 to more clearly define the impact of each issue on restart. includes the separate summary sheets on each issue which provide details of the issue, TVA and NRC actions, and l

current status.

ng

" a.

5 Of the 28 key issues, the. review of 17 of the issues are considered g

resolved. On these 17 issues, TVA may still have some work at Sequoyah to complete before restart, NRC confirmatory inspections S>.

may still have to be done, or the staff may have not documented gy its safety evaluation yet. However, these 17 issues are not I

ovn expected to delay restart.

5,5 Oea Remaining Issues To Be Resolved sThere are 11 issues in either Category B1 or B2, The staff expects to complete its review of all the Category B2 issues in February 1988.

In its letter to TVA of December 31, 1987, the staff identified

Contact:

G. Zech, OSP'

,17 submittals needed from TVA for.the staff to complete its 492-3310 restart evaluations of the issues listed in Enclosure 1.

4 The Comissioners -

The significant issues related to restart are briefly dircussed below.

Cable Installation During testing conducted by TVA to determine whether control and power cables had sustained insulation damage as a result of allegedly inadequate installation practices, TVA identified potential insulation deficiencies with silicone rubber insulated cables supplied by three vendors: American Insulated Wire (AIW),

Anaconda, and Rockbestos.

Some silicone rubber insulated cables have failed in-situ high potential (hi pot) tests and some uninstalled, new, but drop-weight impacted cables have failed laboratory testing which was conducted to ascertain the potential for cable damage from normal stresses expected during shipping, handling and installation.

TVA provided a report on these failures pursuant to 10 CFR Part 21 because it believed the findings could affect other plants.

There are about 960 silicone rubber insulated single conductor cables inside containment, totaling about 60,000 feet.

In a letter dated November 13, 1987, the staff informed TVA that based on the information developed up to that time.by TVA, all the silicone rubber insulated cables at Sequoyah were considered suspect. Although the generic concerns associated with the use of this material in other plants are under review by NRR, it is the staff's position that this issue must be resolved for Sequoyah prior to restart. TVA was told that if TVA elects not to replace these cables, then TVA will have to demonstrate prior to restart that these cables will perform their intended safety functions in a harsh environment.

On November 24, 1987, in a meeting between NRC and TVA, TVA presented results from tests conducted at Wyle Laboratcry.

The results demonstrate that a significantly lower than originally anticipated insulation thickness may be recuired for. installed cables to perform their intended function x!uring and after a LOCA.

In a letter dated December 28, 1987, TVA documented its basis for concluding that the silicone rubber insulated cables installed at Sequoyah are adequate to perform their intended function.

TVA also informed the staff that, as a result of a decision made before the Wyle Laboratory test results were known, all the ATW cables in safety-related harsh environment applications and the associated Anaconda and Rockbestos cables mixed in the AIW cable conduits in Unit 2 containment have been replaced. These cables were replaced with cables acceptable to the staff.

The staff has reviewed the TVA test data and concluded that the remaining installed Silicon rubber cables - Anaconda and Rockbestos - are acceptable for service. The Wyle laboratory tests represent partial qualification of the silicon rubber

' cables for a period of ten years which provides sufficient margin for startup. Therefore, the. staff will require'TVA, as a condition of restart, tocfully qualify the silicon rubber cable for the expected life of Sequoyah before return to operation from the first refueling outage after restart.

w w

9 WMEttE MO q'ft M -* W -

• =e-~

w

i, t

0

' The Commissioners -

Inteorated Desian Inspection The NRC staff conducted an Integrated Design Inspection (IDI) of one safety related system, the Essential Raw Cooling Water (ERCW) system, at Sequoyah to obtain assurance that engineering interfaces and systems aspects of design were not overlooked in the TVA restart programs, and that all major changes and construction problems were identified and resolved by TVA. The IDI consisted of a design verification review and a comparison of the as-built configuration to the design.

The IDI was conducted over a seven week period, and one additional followup inspection has been completed. A final inspection will be conducted prior to restart to verify implementation of corrective actions.

The IDI results indicate that the quality of work for Sequoyah is typical for reactors of the same vintage for all fur.ctional areas except for the civil / structural area. The staff requested that TVA 1

conduct some specific reviews of seismic analyses and designs for structures related to the ERCW system. Of the 64 inspection findings identified to TVA, the NRC has agreed with the majority of TVA's proposed corrective actions. There are several items that i;eed to.be resolved prior to restart-and the staff is working with TVA to reach closure on these items.

Restart Technical Specifications

' TVA has recently identified an additional Technical Specification (TS) change which needs to be addressed before Sequoyah may enter Mode 4 This involves the surveillance recuirements on the control room emergency ventilation system and the measured control room pressure.

TVA has determined that it may need to increase the

. control room ventilation inflow above the TS limit to meet the required control room positive pressure.

The staff is working with TVA on an expedited basis to resolve this issue. Other Technical Specification changes may be identified prior to heatup or restart.

Operational Readiness Sequoyah Unit 2 has not been operated for over 2 years; therefore, particular attention must be paid to the readiness of the plant personnel and systems for restart. NRC has identified, in the past, examples of personnel errors and a lack of procedure adherence and control of testing evolutions. Additionally, weaknesses in TVA's problem identification and resolution process which affect equipment operability were identified.

s 9

5 e

av.

me d w.<<w u _

4-..

- - - w g n-

-m

The Comissioners,

Recent NRC inspections have shown that the problems related to-the examples of failure to follow procedures, inadequate procedures and an overall lack of control over testing evolutions have been resolved. TVA has also implemented measures to address identified weaknesses in its problem identification / resolution process. These measures will be assessed by the staff during plant heatup prior to criticality.

TVA has worked to correct these problems ar.d has had INP0 conduct an audit of the site's readiness for restart. There is also a TVA cor9 orate team at the site performing an independent review.

TVA sutmitted the results of these reviews in a letter dated January 5, 1988.

Overall, the staff believes that TVA has made significant progress to Support heatup.

NRC's evaluation of TVA's corrective actions is ongoing and will continue through plant restart. The review of these actions must include observations during heatup (Modes e and 3) when plant systems are required to be operable.

Employee Concerns and Allegations A number of major TVA programs described in the Sequoyah and Corporate Nuclear Performance Plans arose from employee concerns.

The staff has completed evaluations of about 75% of the employee concerns identified in the TVA Employee Concerns Special Program which are considered restart items by the staff. The remaining evaluations are expected to be completed in February 1988. TVA, however, still needs to provide information for the staff to complete its evaluation of a number of the restart employee concerns.

The staff's evaluation will be issued as Part 2 of the Safety Evaluation Report on Volume 2 c,f TVA's Nuclear Performance Plan.

Allegations are also being reviewed by the staff. The staff will ccmplete its review of the restart allegations in February 1988.

Any new allegations received before restart will be evaluated against the staff approved restart criteria to determine if they must be resolved before plant restart.

Intimidation and Harassment The staff conducted an inspection during August 1987 related to intimidation and harassment issues at TVA.

The inspection was conducted at the TVA Inspector General's office, TVA Corporate offices and the Sequoyah site.

All intimidation and harassment cases for either the Sequoyah site or corporate headquarters were reviewed by the inspection team as well as programatic measures adopted by TVA to address intimidation and harassment within TVA.

The inspection team found the TVA programmatic improvements acceptable and the staff is monitoring implementation of these improvements.

--+ -

• w e **e w

-= yae rw,==re.e 9 7, g-a-e.w

..e.

e 5-The Commission'ers Management The staff has reviewed TVA's Corporate and Sequoyah Nuclear Performance Plans. These plans describe the actions TVA has-taken to improve its management of its nuclear power plants including significant management changes at Sequoyah.

The staff's safety evaluation of corporate management was issued as Volume 1 of NUREG-1232 an July 28, 1987.

The evaluation of Sequoyah site-specific management will be issued in January 1988 as part of the staff's evaluation of Volume 2 of the TVA Nuclear Performance Plan.

The staff conducted an inspection on the effectiveness of corporate and Sequoyah site management in August and September 1987.

The staff's observations, including the inspection, are favorable.

The staff concluded in its evaluation that TVA has acceptably addressed the corporate-level concerns raised in the staff's 50.54(f) letter. The inspection did not find any significant weaknesses in the corporate and Secuoyah site management. The staff will continue to observe TVA management effectiveness as the plant progresses from Mode 5 to Mode 2 during plant heatup.

Conclusion The resolution of these issues and other remaining work could support a date of February 23, 1988 for Secuoyah Unit 2 restart.

This includes the six week pre-restart heatup discussed below.

The staff plans to brief the Commission again just before the plant is ready to go critical and, at that briefing, the staff will present its recommendation related to criticality (restart) for the Commission's consideration.

Pre-Restart Heatup The staff and TVA are discussing entry into Modes 4 and 3, Hot Shutdown and Hot Standby, respectively, to allow a heatup before restart (criticality). Although there is fuel in the core, this would be a non-nuclear heatup using reactor coolant pump heat.

This would allow TVA plant operators to operate plant systems in a normal operating mode while the reactor remains subcritical.

Unit 2 would remain in heatup for about 6 weeks. The exact duration of the heatup period will depend on the nature of any hardware problems encountered and the time needed for operators to refamiliarize themselves to an operating environment.

If it is e

0 6

4

-www_

a was.rw==

. - e

w. p

,pm ew. -.

8 m

l

-l The Comissioners '

necessary for TVA to complete restart work before Mode 2. Unit 2 could return to Mode 5 (Cold Shutdown) before restart. TVA has stated that it intends to complete all the remaining outage required restart work before beginning this heatup. This would allow the plant to continue into Mode 2 (criticality) after staff and Commission approval without the plant cooling down.

/

J

\\

r A

2 dictor Stelro, Jr./,

Executive Director /

for Operations

Enclosures:

1.

Status of Issues 2.

Technical Issues Sumary Sheets This paper is tentatively scheduled for discussion at an Open Meeting on Wednesday, January 20, 1988.

DISTRIBUTION:

Coramissioners OGC (H Street)

OI OIA GPA REGIONAL OFFICES o

EDO OGC (UF)

ACRS ASLBP ASLAP

)

SECY i

l ENCLOSURE 1

~

STATUS OF KEY TSSUES REGARDING SEOUOYAH, UNIT 2 Category issue A

81 82 C

Corporate Plan X-Sequoyah Site Management X

Quality Assurance X

Integrated Design Inspection X

Design Baseline Verification Program X

Design Calculations Review Civil X

Electrical X

Alternately Analyzed Piping / Supports X

Heat Code Traceability X

Cable Installation X

Fuse Replacements X

Ampacity X

Fire Protection X

Environmental Qualification X

Welding X

. Technical Specifications X

NUREG-1150 X

Hydrogen Analyzer Operability X

Procurement Concerns X

Maintenance X

Exemptions X

Post Modification Testing X

Restart Test Program X

Surveillance Instructions X

Detailed Control Room Design Review X

Operational Readiness X

Employee Concerns X

Allegations X

Category A NRC and TVA are in agreement regarding how the issue is being handled and NRC's. review schedule is consistent with the licensee's schedule for resolution of the issue.

Issue has potential to impact restart schedule.

Category B Category 81 NRC and TVA are in agreement regarding how the issue is being handled and potential slippage of restart could exist based on licensee activity.

Category B2 NRC and TVA are in agreement regarding how the issue is being handled and potential slippage of res, tart could exist based on NRC staff activity.

Category C Questions still exist regarding how the issue will be resolved.

z

A 4

s+4_em m

S 1

i

\\

ENC [0SURE2

\\

TECHNICAL ISSUES

SUMMARY

SHEETS J

1 i

e e

+

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

---

e2-,

4 P

I TABLE OF CONTENTS PAGE I.

MANAGEMENT A.

Corporate Plan...................

1 B.

Sequoyah Si te Management..............

2 C.

Qutlity Assurance..................

3 T1. ADEQUACY OF SEQUOYAH DESIGN A.

Integrated Design Inspection............

4-6 i

B.

Design Baseline Verification Program........

7-8 C.

Design Calculations Review.............

9 D.

Alternately Analyzed Piping / Supports........

10 E.

Heat Code Traceability...............

11 III. ELECTRICAL ISSUES A.

Cable Installation.................

12-13 B.

Fuse Replacement 14 C.

Ampacity......................

15 VI. OTHER TECHNICAL A.

Fire Protection 16 B.

Environmental Qualification.............

17 18 C.

Welding D.

Technical Specifications..............

19 E.

NUREG-1150.....................

20 F.

Hydrogen Analyzer Operability............

21 G.

Procurement Concerns................

22 H.

Maintenance.....................

23 1.

Exemptions.....................

24 V.

RESTART READINESS A.

Po'st Modification Testing..............

25 B.

Restart Test Program................

26 C.

Surveillance Instructions..............

27 D.

Detailed Control Room Design Review.........

28 E.

Operational Readiness................

29-30 VI.

EMPLOYEE CCNCERNS/ ALLEGATIONS 31-32 8

4 5

4

ISSUE:

CORPORATE PLAN PROBLEM:

TheNRd's50.54(f)letterofSeptonber.17,1985, requested specific information regarding actions taken or planned by TVA to improve corporate oversight, direction, and support of nuclear power activities.

TVA ACTION:

In response to the NRC 50.54(f) letter, TVA submitted its Nuclear Performance Plan (NPP) - Corporate (Revised)

(Volume 1 of the NPP).

This Plan describes actions TVA has taken to improve its overall management of its nuclear program. These actions include:

hiring, training, developing and providing for the retention of experienced nuclear managers; restructuring the TVA organization to concentrate authority for nuclear operations under the Manager of Nuclear Power and to remove all non-nuclear activities from his purview; consolidating the OA/0C functions; establishing clear lines of responsibility for engineering activities; reorganizing the training program; and centralizing licensing activities.

In addition, TVA has taken steps to improve employee confidence in TVA's nuclear management. Scme longer-term programmatic improvements are still under way and will be completed after restart.

NRC RESPONSE:

The staff has concluded that, from a progracreatic standpoint, TVA has acceptably addressed the corporate-level concerns raised by the staff in the 10 CFR 50.54(f) letter.

Since the TVA Corporate Plan is progrannatic, its effectiveness depends upon its implementation which the staff will closely monitor. However, staff observations to date are generally favorable.

TVA has been successful in attracting a substantial number of experienced managers to fill major positions in the new organization previously teld by contractor managers. Also, in a management effectiveness inspection, it was noted that a management training program has been initiated and several hundred nanagers have completed at least a portion of this training program.

NRC management regularly attends corporate management staff meetings. The staff's acceptance of the Corporate Plan is based upon the current manager of the Office of Nuclear Power, the other senior managers chosen by him, and the new organizational structure. Therefore, the staff requested that TVA notify the staff at least 30 days prior to any permanent change to the corporate organization or permanent replacement of senior managers.

STATUS:

Program review complete. The staff SER, NUREG-1232, Volume 1, was issued on July 28, 1987.

Implementation of programs is currently being monitored.

P0TENTIAL None exhected SHORTCOMINGS:

~

e '

7~+-

w.

---..~-,w,

~~-

e-

~ ~ -

ISSUE:

SEQUOYAH SITE MANAGEMENT PROBLEM:

The NRC's 50.54(f) letter of September 17, 1985, requested specific information regarding actions taken or planned by TVA to improve management oversight, direction, and support of Sequoyah site activities.

TVA ACTION:

In response to the 50.54(f) letter, TVA submitted the Sequoyah Nuclear Performance Plan (Volume 2 of the NPP).

In this plan, TVA described corrective actions to 1) restructure the Sequoyah site organization to be compatible with the recent changes to the corporate structure, 2) prepare position descriptions which delineate areas of responsibility and authority for site management, including reporting channels and interfaces, 3) define training activities, such as shift technical advisor training or senior reactor operator license training for managers, and (4) establish specific site improvements such as a site licensing group.

Over the last few months, TVA has assigned a new Assistant to the Manager of Nuclear Power full time to the Sequoyah site, added a Deputy Site Director and appointed a new Plant Manager. All of these managers were hired from outside the TVA organization.

NRC RESPONSE:

The staff has concluded that TVA has acceptably addressed, from a programatic standpoint, the site level management concerns raised in the 50.54(f) letter. The staff conducted a 2-week on-site management inspection to ascertain the effectiveness of TVA's management and organizational structure.

The inspection noted significant improvements to site support from site engineering resulting from the movement of the engineers to the site. Also, organization, planning, communications and management control activities were found to be generally effective. The final inspection report will be issued in January 1988.

STATUS:

Program review complete.

Implementation currently being monitored. The staff SE will be included in the SER on Volume 2, to be issued in January 1988.

P0TENTIAL None SHORTCOMINGS:

4 e

I

__,_e-

---*-=

• g----

_sm -"

e*

e,-.

ape-~*

,QUALITYASSURANCE ISSUE:

i PROBLEM:

The NRC's 50.54(f) letter referred to a number of instances of poor performance in the quality assurance area that received three successive SALP period ratings of 3 at both Sequoyah and Browns Ferry.

TVA ACTION:

In response to the 50.54(f) letter, TVA has reviseo its quality assurance topical report to include a number of changes including:

1) restructuring the Nuclear Quality Assurance organization to include a site representative at each site reporting to the new Director of Nuclear Quality Assurance, 2) consolidating all nuclear quality assurance and quality control functions under the Director of Nuclear Quality Assurance, 3) adding an engineering assurance organization for auditing TVA engineering design programs, and 4) increasing emphasis on corrective action and root cause analysis programs.

TVA initiated in Februar at Sequoyah the Condition Adverse to cuality (CAQ)y 1986 Program 1

which consolidated the reporting of ncnconformances to one i

standard form as opposed to several. This CAQ process established measures for icentifying and initiating corrective actions in a more timely manner.

In addition, the CAQ program absorbed the ongoing program to complete thuse backlog corrective action packages identified as restart safety issues.

The Sequoyah site management is focusing high level attention to the CAQ progran to ensure i

its effectiveness in resolving outstanding CAQ issues.

NRC RESPONSE:

NRC approved the revised QA program and 0A organization described in the revised QA Topical Report in January 1987. The staff has continued to assess the effectiveness j

of the corrective actions and 0A/0C improvements TVA committed to in its revised 0A Topical and Nuclear Performance Plan.

These NRC actions involved the technical review and inspections of the design, construction, installation, testing and operations activities of the Sequoyah 2 facility.

Particular QA attention was focased on the Design Baseline and Verification Program, the Environmental Qualification Program, the Corrective Action Program, the Replacement Items Program, and the resolution of Employee Concerns including TVA management attitude and involvement in restoring confidence, quality and safety at the Sequoyah facility. The NRC staff feels that, in general, TVA's QA program is effective. Recent inspections of TVA's corrective action process indicate some problems still exist with timeliness of deficiency resolution; nowever, with increased management attention currently being directed, the corrective action process should support restart.

Final inspection of process implementation will be made during heatup prior to Mode 2.

STATUS:

Program review and inspections are ongoing consistent with operational readiness inspections.

POTENTIAL None SHORTCOMINGS:

,3 -

1..

. -..,,. ~ :

-y..

-.,. =

a

6 ISSUE:

INTEGRATED DESIGN INSPECTION PROBLEM (S):

Significant concerns related to the TVA design process and the Sequoyah design adequacy.were identified in the review of technical concerns at Sequoyah. These included Identification of issues at Sequoyah had been an evolving process and somewhat fragmer,ted.

Issues raised regarding the potential that problems at Watts Bar may have also occurred at Sequoyah.

Allegations regarding Sequoyah's compliance with FSAR commitments.

TVA ACTION:

TVA has conducted a number of programs to provide assurance that FSAR commitments and the TVA designs implementing the com.itments are adequate. These programs include the Design Baseline Verification Program, alternate analysis, regeneration of essential calculations in several disciplines, and an cperability "look-back" review. However, all of the efforts have been focused on individual engineering disciplines and at the component level. Thus, the engineering interfaces and systems aspects of design were not evaluated. TVA proposed that its Engineering Assurance (EA) organization could conduct the design review effort equivalent to an Independent Design Verification Progran (IDVP).

NRC RESPONSE:

The staff rejected the TVA proposal to use TVA EA staff to conduct an IDVP based primarily on lack of independence of the EA organization.

The NRC therefore undertook a "vertical slice" review of the Essential Raw Cooling Water (ERCW)

System.

The inspection of the ERCW system consisted of:

(1) an integrated design inspection (IDI) te verify the i

adecuacy of the design, and (2) an as-built system walkdown to verify implementation. This inspection addressed significant aspects of the interactions and interfaces throughout design, engineering and construction to provide additional assurance that all. major changes and construction problems have been identified and resolved. A public meeting was held with TVA on July 8,1987 and onsite activity began on July 27, 1987. The as-built verification inspection exit meeting was held on August 19, 1987, and the IDI inspection exit meeting was held on September 11, 1987 TVA was notified by letter dated October 9, 1987 of those items that needed resolution prior to restart. The final inspection report was issued on November 6, 1987, listing 3 additional report items.

0

. eguwpr] A rw.

e*

W..

yy

• e+*----_*~*-*

TVA addressed the restart items in its letter of October'29, 1987. The information TVA provided at that time was examined during a followup inspection by the IDI team which was completed on November 19, 1987.

The associated inspection report should be issued in January 1988. TVA addressed all the inspection findings in its letter dated December 29, 1987.

The IDI inspection indicated the work quality in most functional areas was typical of what would be found at reactors of similar vintage. However, the nature and number of problems found in the civil / structural area were greater than expected. As a result, TVA was requested to conduct a broader review of this J

area at Sequoyah.

The followup inspection revealed, however, that the civil / structural problems did not have the generic implications originally identified and that the previously

{

requested broader review of civil / structural work was not i

necessary. The -IDI te.am did request TVA (I) to conduct expanded reviews of structural issues related to wall shear calculations, eauipment supports, reinforcing steel in concrete walls; (2) to verify the vertical seismic leading against available plant specific vertical response spectra; (3) to regenerate missing calculations for seismic Category I masonry block walls.

Of the 64 IDI restart items,13 were closed during the followup inspection. The IDI team also reviewed TVA's proposed corrective actions for.48 of the remaining 51 restart items i

and substantially agrees that the actions will resolve the issues. These items will be closed upon formal submittal of the agreed upon resolutions by TVA and confirmation by the staff that the corrective actions have been completed.

The restart items that remain to be reviewed are the seismic l

design of the ERCW access cells, the rock-filled dike, and the ERCW pumphouse roof.

TVA plans to submit information to resolv'e these issues in January 1988. The information will be evaluated against the staff approved restart criteria, and all restart issues will be resolved prior to restart.

As stated previously, the staff also conducted an as built verification inspection of the ERCW system. The staff concluded that in general the ERCW system is installed and constructed in accordance with design specifications, Some specific deficiencies were identified with potential generic implications, including (1) electrical distribution and cable conduit routing, (2) uncontrolled modifications, (3) disabicment of safety system features withcut appropriate analysis or control, and (4) inadequate control of some in-line valves to ERCW components and instruments.

The staff has reviewed TVA's proposed corrective actions with regard to these deficiencies and with minor exceptions, is in general agreement with those actions. An inspection to verify implementation of those actions is scheduled prior to heatup.

5-e

= -.. em

-=-e.

g,==s,e g--==--,

• . - + - - +

e--

.=,y

+, - -

--e-an==.==--

..e

+.

A final'IDI followup inspection is schedule'd for early February 1988 to confirm corrective actions for all restart i

activities identified in the IDI.

STATUS:

The staff is reviewing TVA's letter dated December 29, 1987.

Inspections have been, or are being, scheduled to verify the corrective actions being taken by TVA.

POTENTIAL Based on the licensee's submittals and the IDI inspection SHORTCOMINGS:

conducted in November 1987, none are expected.

e l

l J

*"71**'-**e

• • w

ISSUE:

DESIGN BASELINE VERIFICATION PROGRAM (DBVP)'

PROBLEM:

Questions were raised during a review conducted for TVA by Gilbert Comonwealth in 1985 regarding the adequacy of the existing TVA design control process.

TVA ACTION:

TVA developed the Design Baseline Verification Program to reestablish the design baseline for the Sequoyah facility as of the date of the Operating License. This program included:

1) establishing the plant configuration, 2) reconstructing the design basis, 3) reviewing and evaluating modifications since issuance of the OL, and 4) performing required tests or modifications developed from

)

this review and evaluation. This program has included review of modifications made to 37 Safety Systems and has resulted in approximately 5900 restart items that need to be resolved.

Examples of items include missing calculations, incomplete design documentation, and failure to update as-built drawings to reflect plant configuration.

Of the original 5900 restart items, approximately 750-300 remain for resolution. Post of these are in the pipe s

support calculation area and involve primarily documentation and'30me testing during the heatup phase.

An independent oversight review by the Engineering Assurance j

(EA) Group of TVA's Division of Nuclear Engineering is an integral portion of the DBVP, and is staffed on a full-time basis through the pre-restart phase by a tcam of senior experienced technical personnel. The objectives of this review were, (1) to confinn and validate that engineering activities were being conducted in accordance

'with the overall approved program plan, (2) confirm the -

functional and technical adequacy of the system evaluations, (3) verify that the corrective actions resulting from the evaluations have ceen implemented and documented, ano (4) verify the adequacy and effectiveness i

of the transitional design change control methodologies and procedures.

A supplemental EA oversight review report was issued September 29, 1987 and was forwarded to the NRC in a letter dated October 23, 1987. The EA team concluded that i

implementation of the DBVP for restart is satisfactory and that the objectives of the DBVP have been met.

NRC RESPONSE:

The NRC has conducted a number of inspections of the DBVP program and has concluded that the pre-restart phase of the program has accomplished its intended purpose.

NRC review and inspection of the EA oversight has revealed an effective and thorough effort resulting in both programatic improvements and identification of technical shortcomings in various aspects of the DBVP implementation. TVA has taken action to correct these issues and the EA team has adequately monitored the corrective. actions.

The NRC staff considers that EA oversight

. ~

..,.;, w,.

m c - -....

=. -

j has provided additional assurance regarding the overall adequacy of the DBVP. Ten open issues from these inspections are currently being resolved by.TVA. The NRC concludes that the DBVP was generally conducted in accordance with the TVA program plan and implementation by both DBVP personnel and the EA oversight group have been adequate. Additional inspections will be performed as post-restart activities to close out the deficiencies and/or observations identified during the staff inspections.

STATUS:

Program ongoing. The staff SE will be included in the SER on Volume 2. to be issued in January 1988.

P0TENTIAL None SHORTCOMINGS:

i I

e I

9.,. L =._.. cnn -

-=_

I--

1SSUE:

DESIGN CALCULATIONS' REVIEW PROBLEM:

TVA instituted a review of essential design calculations to verify that the calculations existed and were adequate to support the design of Sequoyah. As a result of engineering calculation reviews conducted by TVA, it was determined that thousands of engineering calculations were not retrievable.

Further questions existed regarding the adequacy of other calculations.

1 TVA ACTION:

TVA completed a 100% check of essential calculations in the Nuclear, Pechanical and Electrical areas. As a result, l

some modifications were required, such as replacement of 125 cables for ampacity concerns.

In the civil engineering area, only a sample of calculations '

were reviewed by TVA.

However, as a result of this review, TVA had to regenerate thousands of missing calculations for i

pipe supports. TVA proposed restart criteria for pire suppcrts with subsequent reevaluation to meet FSAR criteria.

NRC RESPONSE:

NRC staff has reviewed TVA's calculations program and inspected its implementation in the Mechanical, Electrical and Nuclear areas and found 1:s efforts acceptable. The staff has accepted the restart criteria for pipe stupports and will inspect

)

the regeneration of the missing pipe support calculations as well as TVA's review of other calculations in the Civil area.

The staff finds the long-term (FSAR) criteria generally acceptable but will require additional justification regarding the criteria for standard component supports.

The IDI revealad that those calculational areas that TVA i

had reviewed internally and corrected, were generally acceptable.

In the civil engineering area which had not received complete internal TVA review, the staff fcund significant problems during the IDI.

STATUS:

TVA needs to make a final submittal concerning unverified assumptions used in electrical calculations.

TVA is scheduled to complete by the end of January 1988 all restart modifications to pipe supports. The staff is inspecting TVA's actions regarding items identified in previous inspections on calculations and 101.

POTENTIAL None SHORTCOMINGS:

l 9

-e%.

,_%pg,,,p sw*--,e

q_e,

=

~,, -

5 ISSUE:

ALTEPHATELYANklYZEDPIPING/ SUPPORTS PROBLEM:

Deficiencies were identified for piping and piping supports that had been designed using methods based on guidelines and criteria rather than using a rigorous analysis.

TVA ACTION:

TVA developed a two-part program to resolve this concern.

For restart, TVA proposed interim acceptance criteria in selected areas; for long-te.r?, conformance with FSAR connitments will be restored. Support modifications needed for restart have been implemented.

NRC RESPONSE:

NRC reviewed the interim criteria and found them acceptable.

The staff also conducted an audit which included review of program procedures, sample calculations and field inspection of some piping runs. The staff is currently reviewing the long-term program.

STATUS:

The effort is ccaplete for restart. The staff SE will be included in the SER on Volume 2, to be issued in January 1988.

P0TENTIAL None SHORTCOMINGS:

t 10 -

• "~7w+_=,

---ene

-s==4%

w=

.._q,.

-e

l l

ISSUE:

' HEAT CODE TRACEABILITY PROBLEM:

A specific employee concern noted that TVA did not have adequate contrcls to ensure proper material traceability.

Specifically, the concern stated TVA inspectors were not required to check the material Class classification prior to installation. As a result, several instances were identified in which Class B and C pipe materials were installed in Class A applications.

TVA ACTION:

TVA has performed a comprehensive review of this problem and has assessed all safety-related piping in order to demonstrate l

its acceptability for service.

NRC RESPONSE:

The NRC staff conducted inspections to assess the scope and the ramifications of this issue during the weeks of June 23 and July 20, 1987.

In general, the staff concluded that TVA has adequately addressed the issues raised by this j

employee concern. However, the NRC staff considered the proposed corrective actions in the small-bore piping materials area to be inadequate. Three inadecuacies were identifieo.

STATUS:

TVA has satisfactorily addressed two of the inadecuacies identified by the NRC sta'ff by rereviewing the piping analysis and upgrading the material for one pipe fitting which did not have evidence that the required non-destructive examinations (NCE) had been performed. The third item is under NRC review.

The st-3ff expects to include its safety evaluation in the SER for Volume 2, to be issued in January 1988.

POTENTIAL None SHORTCOMINGS:

I j

4 e -

0

~+--y 6 9 %+r:m--

emm -

_a se gr e**

,_ 6 _

,,A_,

=

i ISSUE:

CABLE INSTALLATION PROBLEM:

A number of employee concerns indicated that cable pull'ing practices at Sequoyah violated procedures and/or procedures were not adequate to assure cable integrity following installation. Cable insulation damage may have occurred from overtensioning of cables pulled through conduits with existing cables (pullbys), cable jamming, cable in long vertical drops, and cable pulled through a short bend radius.

TVA ACTION:

To ensure that cables were properly installed at Sequoyah, TVA developed a cable test program to verify cable integrity and submitted this program on April 8, 1987 for staff review.

The program proposed in-situ nondestructive (D.C. high potential) tests on a representative worst-case conduit configuration. There are no standards specifically applicable for in-situ testing of installed cable.

Therefore, the cable qualification standard IEEE-383 (1974) was used as a basis for acceptability of the cable installation at Sequoyah.

On April 22, 1987, during the initial tests of cables in long vertical cable runs, four of 16 silicone rubber insulated cables failed the test and TVA, in consulation with the staff, revised its test program.

TVA provided its revised test program to the staff on July 31, 1987.

The revised test program proposed a reduction in test voltages to be applied to cables under test. TVA conducted additional tests in August and all cables not having' silicone rubber insulation passed the test.

However, six more failures occurred out of 75 silicone rubber insulated cables tested at the reduced test voltage.

On September 10, 1987, in a meeting on the cable testing j

issue, TVA and NRC discussed failures of silicone rubber insulated cables at the reduced test voltages.

The failures were identified during in-situ testing and from laboratory testing of uninstalled cables.

These failures demonstrated to TVA that silicone rubber insulated cables manufactured by Arterican Insulated Wire (AIW), Anaconda, and Rockbestos have the potential to be seriously damaged by normal stresses expected during shipping, handling and installation.

TVA provided a report on these failures pursuant to 10 CFR Part 21 because it believed the findings could affect other plants.

There are about 960 silicone rubber insulated single conductor cables inside containment, totaling about 60,000 feet.

NRC RESPONSE:

In a letter dat ' November 13, 1987, the staff informed TVA that based on the information developed up to that time by TVA, all the silicone rubber insulated cables at Sequoyah were considered suspect.

Althcugh the generic concerns associated with the use of this material in other plants are under review by NRR, it was the staff's position that this issue must be resolved for Sequoyah prior to restart.

TVA was told that 1.f TVA elects not to replace these cables, then TVA will have to demonstrate to the staff's satisfaction prior to restart that these cables will perform their intended safety functions in a harsh' environment.

• e-oee ee n

,w w=w oom.w m m e

+

-e.

l

~

On November 24', 1987, in a meeting between NRC and TVA, TVA presented the status of its ongoing efforts to resolve the silicone rubber insulated cable issue. TVA presented results from Wyle Laboratory ' tests that demonstrate a significantly lower insulation thickness may be required, than originally anticipated, for installed cables to cerform their intended function during and after a LOCA.

TVA also identified industry standards that could qualitatively explain the discrepancies between the results of in situ tests performed at Sequoyah and those results from the Wyle Laboratory tests. The in-situ and Wyle Laboratory tests demonstrated that the cable breakdown voltage per mil thickness decreases as the thickness of the cable increases. On this basis, TVA asserted that failures at relatively low hi-pot voltages do not mean that the installed silicone rubber insulated cables have insufficient insulation thickness to perform their intended function during and after a LOCA.

In a letter dated December 28, 1987. TVA documented its basis for concluding the silicone rubber insulated cable was adecuate to perform its intended function. TVA also documented that all the AIW cable in safety-related harsh environment applications and the associated Anaconda and Rockbestos cables mixed in the AIW cable conduits in Unit 2 containment hav'e been replaced.

This was a result of a decision made before the Wyle Laboratory test results were known. These cables were replaced with cables acceptable to the staff.

TVA has completed its testing of cables to assess the three principal concerns raised by TVA's Employee Conce'rns Special Program. The results of this effort are' documented in a transmittal to the staff dated November 20, 1987.

Based on a review of the results (which involves the testing of 925 single conductor cables), the staff concludes that TVA has adequately demonstrated the integrity of cables in the Sequoyah plant that do not utilize silicone rubber insulation.

The staff has reviewed the TVA test data and concluded that the remaining installed Silicon rubber cables - Anaconda and Rockbestos - are acceptable for service. The Wyle Laboratory tests represent partial qualification of the. silicon rubber cables for a period of ten years which provides suf ficient I

margin for startup. Therefore, the staff will require TVA, as a condition of restart, to fully qualify the silicon j

rubber cable for the expected life of Sequoyah before return i

to operation from the first refueling outage after restart.

j STATUS:

No restart impact.

The staff will require that the silicon rubber cable be qualified for the life of the plant prior to return to operation after the first refueling outage.

POTENTIAL None SHORTCOMINGS:

,a

i ISSUE:

FUSE REPLACEMENT PROBLEM:

There was widespread use of Bussman KAZ fuses as primary protection for safety related circuits at Sequoyah.

These fuses lacked documentation that demonstrated their ability to clear a fault between 5 and 15 amperes.

TVA ACTION:

TVA replaced these fuses with the MIS-5 fuses manufactured by Bussman which also experienced numerous failures.

On October 29, 1986, TVA submitted a Part 21 notification on the MIS-5 fuse failures.

All fuses were subsequently replaced with fuses manufactured by the Littlefuse Co.

(FLAS-5). However, since this replacement, there have been 69 FLAS-5 fuse failures.

TVA again submitted a Part 21 notification on the FLAS-5 failures and issued an LER on July 20, 1987.

TVA has further determined the cause of failures to be solder material creep and has committed to replace all defective fuses with fuses of proper solder material before Mode 4.

TVA has submitted a report on FLAS-5 fuse testing performed to identify the root cause of failures and to demonstrate the improved reliability of the new fuses.

NRC RESPONSE:

The staff has completed review of TVA's fuse replacenent program and concluded that fuses with the new solder material are acceptakle for their intended service.

STATUS:

Complete pending TVA's : placement of all defective fuses.

P0TENTIAL None SHORTCOMINGS:

i '

,~

~ "'

.r____'__

__.=.__._____._T.-- - _ - - - - _ _. : :_ ~::L"'_~ ? ? ~_ ' -. - - -

• ^

• ISSUE:

AMPACITY PROBLEM:

An INPO finding on the Bellefonte Plant identified the lack of design calculations to support the adequacy of ampacity ratings of cables. These findings were found to be applicable to Sequoyah.

TVA ACTION:

TVA recalculated allowable ampacity tables for various types of raceways, voltage classes and types of flame-retardent treatments. The revised tables will be applied to all TVA plants and ampacity calculations verified using these revised ampacities. TVA, using a sampling program approved by the staff, re-examined the Sequoyah raceway designs.

This program demonstrated the adequacy of all centrol and instrument raceways but identified a number of potential inadequacies in power cable ampacities. A 100% review of power cable aapacities was undertaken and identified 457 potentially unacceptable cables.

Detailed analysis 01 individual raceways, modificatiens to tray covers and i

identification of permanently de-energized cables reduced j

the number of unacceptable cables to 125.

TVA's rerouting or replacement of the 125 cables will be completed prior to restart.

NRC RESPONSE:

The staff has approved the new ampacity tables, power cable analysis, raceway modification and replacement programs.

STATUS:

NRC review complete pending (1) TVA certification of ccmpletion of replacement and modification and (?) TVA

)

confirmation of unverified assuroption on maximum flame-retardant coating thickness.

These will be reviewed as part of the staff's review of employee concerns. The staff's SE expects to be included as part of the SER cn Volume 2 to be issued in January 1988.

1 POTENTIAL None SHORTCOMINGS:

15 -

-w-Pe._

_ $cyw.r _

es**y ese e

-,e 4+m.*

____.e==

. -== =p e-eye w ee -

+m a. e--

e.--.%,e.as..

ISSUE:

FIRE PROTECTION PROBLEM:

An NRC inspection at Watts Bar in. July 1984 identified significant deficiencies with respect to fire protection under 10 CFR Part 50, Appendix R.

Subsequent inspection activities at Sequoyah resulted in escalated enforcement. NRC issued a Confirmation of Action letter to TVA identifying actions needed for complete review of the Appendix R program at Sequoyah.

TVA ACTION:

TVA reevaluated its fire shutdown logic and associated circuit interactions.

Thirty-nine significant rrodifications have been implemented. Minor modifications remain and will be implemented on a schedule approved by the NRC staff.

NRC RESPONSE:

Twenty deviatior, requests from Appendix R requirements were approved by the staff.

NRC inspections have been conducted on the TVA correction of past Appendix R deficiencies.

The staff finds that Sequoyah now has an acceptable fire protection program and is in compliance with Appendix R.

The staff has found the few compensatory measures in place to be acceptable.

STATUS:

Restart modifications are complete. The staff SE will be included in the SER on Volume 2, to be issued in January 1988.

POTENTIAL None SHORTCOMINGS:

4 4

16 -

> V)N%99 5V -

7

~v+"

• ~

~_w-

~R

ISSUE:

ENVIRONMENTAL QUALIFICATION (EQ)

PROBLEM:

The Sequoyah plant was shut down by TVA in August 1985 because insufficient documentation existed to demonstrate that electrical equipment at the plant was environmentally qualified as required by 10 CFR 50.49.

This was identified by TVA and their contractor, WESTEC Services Inc.

TVA ACTION:

TVA developed an EQ program to identify equipment, specify environments, verify equipaent in the field, document qualification, specify maintenance requirements, maintain EQ binders, and replace unqualified equipment if necessary.

The documentation demonstrating compliance is complete and any required modifications will be completed before restart.

NRC RESPONSE:

The staff has been reviewing TVA's EQ effort for the past year.

Inspections entailing over 1300 man hours of effort at the Sequoyah site have been completed to date and have included a 100% look at the EQ binders at Sequoyah. Tile staff hos found that the EQ program at Sequoyah is now one of the better programs in the nuclear power industry, in terms of both documentation and hardware.

STATUS:

Licensee effort complete.

NRC inspecuans complete.

No furtner staff efforts planned on this issue. The staff SE will be included in the SER on Volume 2, to be issued in January 1988.

j POTENTIAL None SHORTCOMINGS:

l I

l 1

i 1

- 1.' -

--,-m_

s ey._a

• • ' M tRt_ A m

- *19 26, t Me uA s# -

~~-

~

m l

e ISSUE:

WELDING PROBLEM:

Concerns were raised at the Watts Bar site regarding TVA's inspection practice and welding rod control program. These concerns were potentially applicable to Sequoyan and thus implicated the quality of weldments and the abilit/ of the welds at Sequoyah to perform their function; TVA ACTION:

TVA conducted a reassessment program which consisted of two parts:

(1) programmatic review of commitments 6nd procedures for implemer. ting the commitments, and (2) physical reinspection of sample welds.

NRC RESPONSE:

The NRC staff approved the reassessment program and conducted several independent team inspections in 1986 to ensure the adequacy of TVA's corrective acticns in terms of both the welding program and the site hardware. The staff conducted independent non-destructive examinations, using the NRC independent measurements van, of some welds at Sequoyah.

In addition, reviews were performed by Brookhaven National Laboratory and an expert consultant team.

STATUS:

The staff has completed its SE in the welding area.

It 11 completing its review of TVA's final employee ccncern program element reports on Sequoyah welding concerns and preparing SEs on these reports.

The staff SC will oe included in the SER on Volume 2, to be issued in January 1988.

P0TENTIAL None SHORTCOMINGS:

l b

a a

• w-

w. w e,~ m we-wm,v-=.ame=-e.-

y==

.t ISSUE:

TECHNICAL SPECIFICATIONS PROBLEM:

TVA has identified a number of Technical Specifications (TS) changes recuiring approval by the NRC before Sequoyah can enter Modes 4, 3 or 2.

These chaages include surveillance requirements for steam generator blowdown and the condensate demineralizer, references to motor operated valves, plant staff organization, containment spray response times and the curveillance requirements for the control room emergency ventilatioa system.

Many other TS changes (e.g., administrative changes) have been submitted to the staff as a result of new TVA programs, however, approval of these requests are not required for restart. These non-restart change requests i

total over 40 separate submittals.

TVA ACTION:

TVA has submitted four of the restart TS change requests to the staff.

At least one submittal, on the control room emergency ventilation system and the measured control room pressure (control room habitability), was recently identified by TVA as being needed and will be submitted in January 1988.

NRC RESPONSE:

Four of the restart TS amendments have been issued.

STATUS:

NRC staff is awaiting the submittal of the fifth amendment request.

NRC staff understands that additional TS change requests are being considered by TVA.

P0TENTIAL Expedited Public Noticing and staff review may be required in e

SHORTCOMINGSt order to avoid heatup/ restart delays.

4 e

e e

e 4

19 -

m ew!. m v

• nw*

w"=m e e e.

ma q wp

4 ISSUE:

NUREG-1150 PROBLEM:

In the draft of NUREG-1150, Reactor Risk Reference Document, which was issued for public ccmment in February 1987, Sequoyah was shown to be an outlier in terms of risk when compared with other plants.

TVA ACTION:

TVA hired Westinghouse to perform an individual plant evaluation (IPE) for Sequoyah which concluded that the resulting risk is lower than that shown in NUREG-1150 by a factor of 2 to 3.

The IPE was based on a number of different assumptions from those used in NUREG-1150 analysis.

l NRC RESPONSE:

The Office of Regulatory Research (RES) is sponsoring additional analyses to finalize NUREG-1150 and will factor in the information provided by TVA both in the IPE and in their comments. RES is developing a revised assessment of core melt frequency for Sequoyah based on revised assumptions concerning the component cooling water system.

STATUS:

A Peer review group that is reviewing the NUREG-1150 results Let with the staff ouring early January,1908.

The prel,iminary Sequoyah core malt results indicate that Sequoyah is not an outlier.

POTENTIAL None SHORTCOMINGS:

e

-tm ' ^- '

m" a

w-e

ISSUE:

HYDR 0 GEN ANALYZER OPERABILITY PROBLEM:

NRC inspections identified that the H analyzer oiping was 2

installed incorrectly.

The svstem is not considered operable and is needed for criticality (Mode 2).

The problems identified are the following:

1.

vendor recommendation not implemented for line slope and line insulation, 2.

excessive water traps existed in sensing lines, 3.

H analyzers would not automatically load on the EDG 7during loss of offsite power, but the analyzcrs are on an essential bus, 4.

dA" train analyzer did not sample upper containment, 5.

sensing line plugged with foreign material, 6.

caps and valves missing from test connections contrary to dosign requirements, and 7.

noncenservative changes to FSAR instrumentation accuracy values without supporting 50.59 evaluations.

TVA ACTION:

TVA has modified piping to correct slope, sample location water trap and configuration problems.

TVA has proposed resolution of instrumentation accuracy problems.

Resolution of electrical deficiencies are ongoing.

NRC RESPONSE:

The staff is reviewing the licensee's actions to resolve this issue.

STATUS:

This issue will be resolvea prior to restart.

POTENTIAL hone SHORTCOMINGS:

e 5

1 4

g e-owe s* w-e -

ISSllE:

PROCUREMENT CONCE'RNS PROBLEM:

From TVA NSRS Reports between 1983 and 1985 and during an inspection in November 1986, NRC determined that TVA had procured replacement parts for safety-related equipment without appropriate procurement controls to ensure that replacement' items were tested or qualified for their safety-related applications.

TVA ACTION:

TVA has undertaken an extensive program to review End evaluate past and present procurements of replacement itenis to identify those replacements that require additional qualification for use in safety-related applications.

TVA's Replacement Parts Program, including detailed implementing procedures, has been submitted for staff review. TVA is establishing qualification of items or replacing items on equipment required for restart.

NRC RESPONSE:

TVA's programmatic approach is acceptable to the staff.

July 1987 inspection identified staff concerns with regard to the seismic qualificaticn of replacement parts and TVA's dedication process for new procurement.

STATUS:

Licensee efforts are in progress.

Staff has issued a position letter on seismic qualification which will resolve tnis issue for restart. TVA needs to submit their program plan to address the long-term resolution and the dedication process.

Inspection scheduled for late January /

early February,1988.

The staff SE will be included in the SER on Volume 2, to be issued in January 1988.

POTENTIAL None SHORTCOMINGS:

._.i _.. _

ISSUE:

MAINTENANCE PROBLEM:

Programmatic problems in site maintenance were previously identified in SALP and inspection reports. These problems were attributed to (1) managerrent problems in the development and administration of controls on maintenance activities and (2) the failure to implement effective and timely corrective actions when problems were identified.

TVA ACTION:

TVA has implemented corrective actions described in its Corporate and Sequoyah Nuclear Performance Plans, including (1) establishing a corporate Nuclear Maintenance manager, (2) establishing job accountability at the craft and manager levels, (3) establishing a new maintenance request (MR) system, (4) increasing staffing of maintenance planners and adoing an SR0 to coordinate activities, (5) developing a long tor.n program to improve maintenance procedures, (6) improving the preventive maintenance program, (7) implementing tracking and trending for future component failures and out-of-calibration conoitions, (8) attaining INP0 accreditation cf all maintenance craft training programs (received 5/7/87).

NRC RESPONSE:

The NRC has inspected the maintenance program improvements implerr.ented by TVA and has concluded that the maintenance program is acceptable for restart.

STATUS:

TVA has successfully identified corrective and preventive maintenance items needed to support unit restart in the form i

of the daily work item list and other plant scheduling activities.

Midd.a and upper level management involvement has increased in the resolution of maintenance scheduling and execution.

Sequoyah is significar.tly reducing the maintenance backlog.

Inspection findings have determined maintenance practices and adherence J

to present maintenance procedures are adequate. The staff SE will be included in the SER on Volume 2, to be issued in January 1988.

POTENTIAL None SHORTCOMINGS:

0 9

4 g

e 8

23 -

" " ~

J w * = ~

en-n ~

,.,,,,ew_

ISSUE:

EXEMPTIONS PROBLEM:

Subsequent to the development of the TMI Action Plan, NRC staff policy has been established that closed systems outside containment are not generally acceptable as an isolation barrier for lines covered by GDC 55 ad 56. As a result of an NRC inspection at Sequoyah in March 1986, issues regarding TVA reliance on closed systems to meet GDC requirements were identified. This led to a general reassessment of the Sequoyah containment isolation design.

Subsequent to discussions with the NRC, TVA redesignated certain existing system line isolation valves as containment isolation valve:.

For those cases where the GDC requirements could not be met by merely redesignating the valve as a containment isolation valve, TVA has requested an exemption from specific aspects of the GDC requirements.

In addition to the fact that some of the redesignated valves dic not meet the GDC, there were three cases in which certain containment isolation valves could not be Type C tested in accordance with Appendix J in their current configuration.

TVA ACTION:

TVA has submitted requests for three exemptions to GDC 55 or 56 and three exenptions to Appendix J Type C leak rate testing.

NRC RESPONSE:

NRC has reviewed the requests and has completed evaluations to grant the exemptions.

The evaluations are in accordance with NRR positions.

STATUS:

The GDC exemptions have been issued. The Appendix J exemptiens are in concurrence and are expected to be issueo in January 1988.

P0TENTIAL None SHORTCOMINGS:

e.

4

__.-4L-e-

POST MODIF; CATION TESTING (PMT)

ISSUE:

PROBLEM:

Inspections cenducted in 1986 determined that TVA had completed numerous modifications at Sequoyah since the plant was licensed and,.in many cases, this work was not adequately tested.

TVA ACTION:

TVA has completed a review of all post-license modification tests associated with the 37 systems in the design basis verification program (DBVP) Phase I and identified approximately 109 tests requiring re-performance.

TVA is in the process of re-performing these tests. TVA has initiated action to ensure that the system engineering group and the Division of Nuclear Engineering review and approve all PMT associated with design changes and temporary alterations.

In addition, TVA has initiated a conduct of testing procedure in order to ensure the adequate implementation of approved PMT.

Finally, improvements in test deficiency resolution have been af fected.

NRC RESPONSE:

The NRC reviewed TVA's PMT review results and determined that TVA performed an adequate review to establish test reperformance requirements.

Selected tests were observed by the NRC and found, with minor exceptions, to be acceptable.

STATUS:

Program review is complete.

Implementation of remaining tests has been factored into the restart test activities and is being reviewed as part of the NRC restart test inspection effort.

The staff SE will be included in the SER on Volume 2, to be issued in January 1988.

FOTENTIAL None SHORTCOMINGS:

e 0

e s

-== ~ ~~w*

'w..,.

ISSUE:

RESTART TEST PROGRAM PROBLEM:

.In response to the programs under way since the shutdown of the Sequoyah plant, a comprehensive restart test program is required to ensure that the plant safety systems are functional before restart of Sequoyah.

TVA ACTION:

A restart test program has been developed by TVA,which identifies the testing required prior to and during startup and power ascension of Sequoyah Unit 2.

This program identified approximately 6000 safety and operational functions required for the components associated with the 37 design baseline verification program (DBVP) systems as well as the rod control and flood mode boration systems.

TVA evaluated the preoperational, post tredification and surveillance testing perfonned on these systems in orcer to determine if each of the identified safety and operational functions had been adequately tested.

The results of the TVA surveillance instruction review program were factored into this evaluation.

From this overall evaluation, TVA detemined that approximately 15 Special Tests were required.

Additionally TVA determined that approximately 125 surveil-lances needed to be reperformed prior to and during startup.

i This testing was necessary to validate the functionality of approximately 500 of 6000 identified functirns. Of these 500 functions, le.ss than 25 were determined to have never been adequately tested in the past. To date approximately 12 Special Tests ano 85 surveillances have been accomplished to validate the 500 functions.

This testing has identified problems with emergency diesel generator (EDG) voltage regulators, Control Room Ventilation, conteinment spray flow orifices. Safety Related Room Coolers and Main feed Pump Control Circuitry.

TVA has satisfactorily corrected problems with EDG voltage regulators and containment spray flow orifices, and is pursuing resolution of Control Rocm Ventilation, Safety Related Rcom Coolers and kain Feed Pump Control Circuitry problems.

NRC RESPONSE:

The SER is currently being drafted for program acceptance.

NRC inspection of program implementation reflects that TVA has satisfied their nuclear performance plan (NPP) conmitments and TVA is adequately implementing this program.

STATUS:

TVA will perform approximately 40 surveillances and 3 Special Tests prior to startup. Approximately half of these must be done prior to heatup. NRC inspection of test program implementation has been substantial to date ano will continue through heatup and startup.

POTENTIAL Shortcomings in TVA's schedule adherence for testing could SHORTCOMINGS:

impact scheduled heatup and startup activities.

Equipment and system deficiencies identified from these tests could impact adversely en scheduled heatup and startup.

O ~

ISSUE:

SURVEILLANCE INSTRUCTI,0NS (sis)

PROBLEM:

NRC inspections determined that a number of sis were inadequate, i

TVA ACTION:

TVA implemented a special SI review and revision program to ensure that Technical Specification (TS) surveillance requirements are being met, and that sis can be performed as written. This program included a review of technical content, scope, and clarity for each SI determined to be required for startup, operation and safe shutdown.

NRC RESPONSE:

The NRC staff has evaluated TVA's SI review and revision program and concluded that the program is acceptable.

Inspections of program implementation were completed in June and July 1987.

The results of the inspections were acceptable.

STATUS:

Phase ! ccmplete.

Phase II, the administrative enhancer.ent portion, is long term and is currently being monitored.

The staff safety evaluation will be included in the SER on Volume 2, to be issued in January 1968.

POTENTIAL' None SHORTCOMINGS:

e 9

e

~

' 27 -

~ _...

_m__..

ISSUE:

DETAILED CONTROL ROOM DESIGN REVIEW (DCRDR)

PROBLEM:

As part of a generic control room review, evaluate whether control room design requirements in Supplement 1 to NUREG-0737 have been satisfied.

1 TVA ACTION:

TVA implemented a control room review program at.Sequoyah in response to the requirements of NUREG-0737 No remaining plant modifications need to be made before restart.

TVA has submitted (1) a letter detailing activities on Human Engineering Deficiency (HED) 0220 and (2) a supplement to the Summary Report for Sequoyah Units 1 and 2 including a.

schedule for con.pleting the remaining Sequoyah HEDs after restart.

NRC RESPONSE:

The staff conducted an audit of the TVA program and has concluded that TVA's Control Room Design Review Program is acceptable.

STATUS:

Program review complete.

The staff Safety Evaluation was issueo on August 27, 1987.

P0TENTIAL None i

SHORTCOMINGS:

l l

l

)

4 1

28 -

l 1

-*m 2

~ r-z..- - ~ ~ - -. - ' -

I

e ISSUE:

0PERATIONAL READINESS PROBLEM:

Sequoyah Unit 2 has not been operated for over 2 years; therefore, particular attention must be paid to the readiness of plant personnel and systems for restart.

NRC has identified, in the past, examples of personnel errors and weaknesses in TVA's problem identification arid resolution process which affect equipment operability.

Both the NRC and TVA need to assure that Sequoyah Plant systems and personnel are ready for restart. The review should concentrate on programatic improvements and implementation of those improvements to assure that past problems have been corrected.

TVA ACTION:

TVA has established general guidance for operational readiness verification and has conducted an interim operational readiness review.

INP0 has also conducted an assessnent of operational readiness. Additionally upper managerrent observations of operatioral activities have been implemented. Additional licensee operational readiness assessments including quality assurance audits are to be concucted prior to startup.

TVA's manager of Nuclear Power has commenced meetings with plant personnel in order to determine the root cause of personnel errors. Corrective actions for identified equipment operability problems are in progress.

NRC RESPONSE:

NRC is independently assessing TVA's readiness for restart by conducting operaticnal readiness reviews prior to each hold-point release.

These inspections concentrate on plant material condition and deficiency resolution, as well as control of evolutions. Additionally NRC has conducted extensive shift turnover and centrol room observations and considers turnovers to be adequate and control room decoru'm to be excellent.

With respect to recent issues:

(1)

NRC identified several examples of failure to follow procedures, inadeouate procedures, and an overall lack of control over testing evolutions, including system and equipment status. Recent inspections indicate adequate resolution of testing control and procedure utilizatien problems by TVA.

(2)

Several instances were identified where Unit 2 could have been restarted with inoperable equipment due to apparent weaknesses in TVA's problem identification /

resolution process.

The systems involved included containment spray, auxiliary feedwater, essential raw cooling water, and hydrogen analyzers.

TVA has initiated corrective actions to resolve these specific concerns.

NRC will confirm operability of these systems prior to their required mode.

Final NRC inspection of TVA actions with respect to deficiency' resolution will be accomplished during h'eatup'in conjunction with closure of Order EA 85-49 for Sequoyah.

29 -

mx,

_kr As

?

b~

" ~

• ~#'

' ' ~ ~ ~

' ~ " " *

(3) Weaknesses have recently been identified.in TVA's process for reviewing plant changes pursuant' to 10 CFR 50.59 which could impact operability determinations.

l TVA resolution of these weaknesses are under current NRC inspection with final NRC disposition pending escalated enforcerrent action.

1 (4),Many examples have been noted where temporary compensatory measures were implemented long term to resolve system and design deficiencies due to apparent weaknesses in TVA's problem identification / resolution process.

TVA's resolution of this concern is under current NRC inspection.

(5) Weaknesses were noted in TVA's system alignment and configuration control processes.

TVA's resoluti.on of this concern is under current NRC inspection.

STATUS:

The staff considers that TVA has made sionificant progress in its preparations to enter heatup.

TV4's corrective l

rteasures are currently underway.

Control room and shift turnover observation by NRC are ongoing. Hold point #1 (Mode 5-4) release inspection is currently ongoing.

Additional inspections are planned prior to each hold-point release (5 in all).

POTEriTIAl.

NRC needs to establish more confidence in TVA's operational SHORTCOMINGS:

capabilities under operating conditions prior to the plant entering Mode 2.

This will be evaluated during heatup prior to Mode 2.

1 l

l i

1 l

l w

• e k

->w a*__ m p e mrm-

--e.

ISSUE:-

EMPLOYEE CONCERNS (EC) PROGRAM PROBLEM:

Under the Employee Concerns Programs initiated at Watts Bar in 1985 more than 5000 employee concerns were identified.

Approximately 1100 safety and non-safety concerns identified in the original Employee Concern Program were applicable to Sequoyah by direct reference or generic appin.cbility.

TVA ACTION:

TVA has divided the concerns identified in the original Employee Concern Program into 9 categories: construction, engineering, operations, materials control, welding, quality assurance, industrial safety, managament and personnel, and harassment and intimidation (H&l).

TVA has submitted 317 element reports documenting its investigations and corrective actions for Sequoyah for the first 6 of these categories.

No safety-related concerns were identified in the industrial safety category.

The H&I concerns are being aadressed by the TVA Inspector General's Office separately from the employee concern prcgram. Of the 317 element reports submitted by TVA, 56 require completion of corrective actions before plant restart.

TVA developed the new Employee Concern program to investigate and resolve those employee concerns received after February 1, 1986.

NRC RESPONSE:

The staff has reviewed the original Employee Concerns program and has concluded that the program is acceptabi'e.

The staff's Cecember 14, 1987 SER on the Management and Perscnnel Category concluded that the employee concerns in this catecory were adequately addressed by TVA. The element reports are currently being reviewed by the staff. Of the 317 element reports, 251

' reports are required to be reviewed for restart.

The findings of an NRC inspection on intimidation and harassment are that these cases are being acceptably addressed by TVA.

The new Employee Ccncerns program has been revieweo and approved by the staff for those employee concerns that were substantiated.

the restart corrective actions are being monitored by the staff.

J STATUS:

TVA still needs to provide information for a number of restart i

eierent reports in order for the staff.to complete its evaluations. The staff has completed its review of 75% of the restart element reports. All.the remaining restart element report evaluatiens will ha completed in February 1988.

The staff's SE will be included in Part 2 of the SER on Volume 2.

P0TENTIAL None SHORTCOMINGS:

~

K h A J WmM M. __

,WPWI WW N'

s w-

^

ISSUE:

ALLEGATIONS PROBLEM:

A number of allegations of safety problems at TVA have been made directly to the staff in lieu of being provided i

to TVA under the Employee Concerns program. Currently there are about 300 TVA allegations related to TVA being tracked by the staff.

The staff has determined that about 170 need to be resolved before Sequoyah restart.

TVA ACTION:

In a number of instances, the technical content of the allegation has been provided to TVA for its review and response to the NRC.

TVA has then entered the allegation into its Employee Concern program.

NRC RESPONSE:

The staff is in tne process of reviewing the Sequoyah restart allegations.

The NRC staff will resolve all potentially safety significant Sequoyah-related allegationc before the restart of Sequoyah.

Any new allegations received before restart will be evaluated against the staff approved restart criteria to determine if they must be resolved before plant restart.

STATUS:

The staff review is ongoing.

The staff will complete its i

evaluations of the Sequoyah re' start allegations in February 1988.

POTENTIAL Resolution of the restart allegations may require TVA to SHORTCOMINGS:

co additicral work prior to r,estart.

l e

32 -

i

'"~

M*

maes%,

,