ML18033A557
| ML18033A557 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/06/1988 |
| From: | Frane J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 20900, 20900-V02-R05, 20900-V2-R5, NUDOCS 8902150057 | |
| Download: ML18033A557 (64) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG
'VOLUPTE'2 ENGINEERING CATEGORY SUBCATEGORY REPORT 20900 0-LIST UPDATED NUCLEAR POWER I
C 8902i 0057 890206 POP.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:
SUBCATEGORY REPORT FOR ENGINEERING TITLE:
Q-LIST REPORT NUMBER'0900 REVISION NUMBER:
5 Page 1 of 26 1.
Revised to incorporate SRP and TAS comments as well as to incorporate corrective actions for BFN and BLN.
2.
Revised to incorporate SRP (References).
S 3.
Revised to incorporate SRP and TAS comments and to add Attachment C
Comments.
4.
Revised to incorporate SRP and TAS comments.
5.
Revised to incorporate SRP and TAS comments.
R ON R
AR BY:
S NA
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'F OA VIEW COMMITTEE:
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/z-ZZ-8p TA SIGNA U NUR N
CEG-H:
f-6-a8 DATE SRP Secretary's signature denotes SRP concurrences are in fi1es.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 REVISION NUMBER' Page ES-1 of 2 EXECUTIVE
SUMMARY
This subcategory report considers employee concerns regardinq Q-Lists.
It addresses the accuracy of the Q-Lists, the effects of using inaccurate Q-Lists, the use of more than one list, and Engineering input to the Q-List.
"Q-List" is a generic term used by the nuclear power industry to describe a
listing of the plant struc'tures,
- systems, and components that are to be covered by the Quality Assurance (QA) progr am requirements of 10 CFR 50, Appendix B.
There is wide variation in the format and detai'1 of the Q-Lists in existence within the nuclear power industry.
Q-Lists range from summary lists containing only systems and components, to extensive lists with subcomponent identification and detailed data.
TVA has generally referred to the list's a critical structures,
- systems, and components (CSSC), list for operations activities.
The accuracy of the Q-List/CSSC List was found to be questionable at the Watts Bar (WBN) and Sequoyah (SQN) nuclear plant sites.
At Watts Bar, the TVA QA organization and the Huclear Safety Review Staff (HSRS) investigated and found significant discrepancies in the Q-Lists, which were reported to the NRC.
Previously committed corrective actions which were overdue had not been completed.
At Sequoyah, a scheduled biennial review had not been performed and known CSSC Review Conmittee action items had been repeatedly deferred.
At Browns Ferry ('BFN), while no specific problems were noted by the evaluation
- team, the CSSC List had not recently been reviewed for accuracy or completeness.
At Bellefonte (BLN), the Q-list was found to be accurate and
- complete, and it appears to be adequately controlled by engineer inq procedures..
Various Q-Lists existed independently and concurrently for a time at WBH and BFN.
- However, the use of multiple lists was limited in time and extent, and was determined not to represent a significant problem.
TVA has committed to correct the list at WBN, create a
new list at
- BFH, and cancel the redundant lists at both plants.
The concerns that the enqineering design qroup was not providinq input to changes to the Q-Lists were found not to be valid for any of the plants.
The cause of the negative findings in this subcateqory is a lack of clearly defined interorganizational responsibility and author ity for directing the development and implementation of the Q-Lists.
TVA's QA organization identified Q-List/CSSC List problems at WBN',and caused the initiation of corrective action.
QA did not identify the findinqs noted in thi.s reoort for
The negative findings applied to more than one plant and more than one organization.
Specific actions to correct the neqative findings have been initiated at the element level in response to element level CATOs.
A review of TVA's Nuclear Performance Plans (NPPs) by the evaluation team revealed that TVA recognized in the Watts Bar NPP a problem of deficient, incomplete, and multiple Q-Lists, and was taking steps to correct the 26460-24
( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER 20905 REVISION NUMBER':
'5 Page ES-2 of 2 problem.
The
- SQH, the. BFN, and Corporate NPPs contain no discussion or specific commitment relative to accuracy or use of a Q-List or CSSC 1'ist. 'L'N has no plant-specific NPP and is covered by the Corpoirate NPP.
The e'valuation team believes, however, that the commitments in the Corporate NPP to consolidate a TVA nuclear infrastructure avid 1(o develop standardi procied0re]s to control interfaces with support organizations~
c'oupled with the correCtive actions to which TVA has coimmitted at the element level, should eliminate
'uture problems regarding accuracy of the Q-List for each plant.
The Nuclear Quality Assurance Manual (NQAM), commits the Oiivision of Nuclear Engineering (ONE) to develop aind maintain a Q-list for each nuclear plant.
The. NQAM, which is. the governing upper-tier ddcuiment, requi~es implem'ent'ation of the WBN and BLN Q-Lists before receipt of an operating license for'he first unit.
It also requires the SQN and BFN Q-Lists to be implemented at a
date mutually agreed to by ONE and the Nuclear Site Oirector (NSO).,
For
- BFN, the time frame has been established in the corrective action plan (CAIP).
For SQN the time frame has not yet, been establi'shed.
TVA has prepared corrective action plans for 'WBN, BFN,,
and BLH, which, when properly implemented,.
should resolve the ne'qativte findin'qs noted in tIhis report.
The sQN corrective action plani provided,justification that the bienni al review of the Sequoyah CSSC List for accuracy and completene. 's, wnich was scheduled for June
- 1987, is not necessary prior to restart.
The NIRC concluded after a
recent inspection at SQN that the SQN CSSC List and its utilization process appeared to be working and were adequate for the short term (unit 2 restart).
The HRC recommendled that the SQN Q-I ist be developed and implemented in an expeditious, manner (Ref.
12O).
]in addition, a Joint Oivision of Nuclear Quality Assurance/Engineering Assurance (OHQA/EA) audit at SQH resulted in a
recommendation thiat Engineeirinq and Operations commiit to the expeditious development and pub'lication of a control'led'SQN Q-List (Ref.
119).
TVA has committed to submit a Q-List implementat'ion plan for SQN to the NRC by March 1, 1988 (Ref.
121).
This commitmeht is beiing tr'ac(ed to completion by TVA as part of the Corporate Commitment Tracking System (CCTS),
as wi'll the Q-List implementation
- plain, when it is provided to the HiRC.
The significance of the negative findings is that the impact of any omissions from the Q-Lists (or equiva'lent documents) cannot be determined until 'the evaluations of Q-list accuracy have been cokplethd.'huS, there is s6me potential for future physical plant changes'.
The causes, significance, and other evaluatiiod results are being reexamined from a wider perspective in the Engineering'ateqory Report.
26460-24
( 12/22/87)
TVA EMPLOYEE CONCERNS SPECZhL PROGRhN REPORT NUMBER:
20900 FRONT NETTER REV:
3 PhGE i OF viii Preface This subcategory, report is one of' series of reports prepared for the Employee Concerns Special Program (ECSP),of the Tennessee Valley huthority (TVh).
The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVh's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986.
Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800. employee concerns.
Each of'he concerns was a
formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the NRC.
and the general public.
The results of these investigations are communicated by four levels of ECSP reports:
- element, subcategory,
- category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the, restart of Sequoyah Nuclear Plant's reactor unit 2.
hn element consists of one or more closely related issues.
hn issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns.
For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself.
Consequently, some elements did include only one issue, but often the ECTG evaluation.found more than one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
- However, the subcategory report does more than collect element level evaluations.
The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore. require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface,.
a glossary of the terminology unique to ECSP reports, and a list of acronyms.
hdditionally, at the end of each subcategory report will be a Subcategory Summary Table that includes the concern numbers; 'identifies other subcategories that share a concern; designates, nucl'ear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
TVh EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: '0900 PRONT l'LETTER REV:
2 PAGE ii OP viii The subcategories are themselves summarized in a series of eigh't category reports.
'Each category report reviews the major findings and c'ollectiv'e significance of the subcategory rkpodts~ in ohe 'of 'the following'reas:
management and personnel relktibns'ndustrial safety construction material control operations quail ty assur ance/qual ity con'trdl wel,ding eng,ineering A separs.te report-on employee conc'erns dealing with specific contentions of'ntimidation, harassment, and, wron'gdoing will be released by the TVh'ffice of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports i.'ntegrate the information assembled in all the subcategory reports within the category, addressing partii'.ul'ar 1'y the underlying causes of those problems that run across more th'an'onle subcategory.
A final report will integrate and as'sess the information collected b'y all of the lower level repo'rts prepared for the
- ECSP, including the Ii>spector General's report.
For more detail on, the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employoe Concerns Task Group-Program Manual.
This Nanual,spells out the program's objectives,
- scope, organization, and responsibilities.
It also specifi.es the procedures that were folio'wed 'in 'thh i'nvestigation, reporting, and closeout of the issue,s raised by einpl'oyhe 'cohce'ms.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 FRONT MATTER REV:
2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS'lassification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A:
Issue cannot be verified as factual Class B:
Issue is factually accurate, but what is described is not a
problem (i.e., not a condition requiring corrective action)
Class C:
Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D:
Issue is factual and presents a problem for which corrective action has
- been, or is being, taken as a result of an evaluation Class E:
A problem, requiring corrective action, which was not identified by an employee
- concern, but was revealed during the.ECTG evaluation, of an issue raised by an employee concern.
collective si nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see "employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.
criterion
( lural:
criteria a basis for defining a performance,
- behavior, or quality which ONP imposes on itself (see also "requirement" ).
element or element re ort an optional level of ECSP report, below the subcategory level, that deals with one or more issues.
em lo ee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form'quivalent to the K-form.
JVh EMPLOYEE CONCERNS SPECIAL PROQiUi8 REPORT NUMBER:
20900 FRONT, ltilTTER REV:
2 PAGE.iv OF viii grouping of employee concerns.
~findin s
includes both statements of fdct 'and the judgments made about. those facts during, the evaluation process; negative findings require-6or&ec'tive action.
issue a potential problems as interpreted by the ECTG during the evaluation
- process, raised in one or more conderns.'-form (see "employee concern")
evaluation judgment or diecision map b4 based.'oot cause the underlying reason for a probl'em.
<<Terms essential to the program but which Heq'ukt'e detailed'efinition have been defined in the ECTG Procedure Nanual (e.g,
- generic, specific, nuclear safety-related, unreviewed safety-signi'fican't qa'uestion]i.
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 FRONT MATTER REV:
2 PhGE v OF viii Acronyms AZ AISC ANS ANSI ASME ASTM Administrative Instruction American Institute of Steel Construction hs Low hs Reasonably Achievable American Nuclear Society American National Standards Institute American Society of Mechanical Engineers American Society for Testing and Materials AMS BFN BLN CAQ CAR CATD CCTS CEG-H CFR CI American Melding Society Browns Ferry Nuclear Plant Beliefonte Nuclear Plant Condition Adverse to Quality Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System Category Evaluation Group Head Code of Federal Regulations Concerned Individual CMTR Certified Material Test Report COC DCR DNC Certificate of Conformance/Compliance Design Change Request Division of Nucleat Construction (see also NU CON)
TVA ENPLOYEE 'CONCERNS SPECIAL PROGK1A REPORT NUMBER:
20900 PRONT NATTER REVr 2
PAGE vi OP viii DNE DNQA DNT DOE DPO Division of Nuclear Eng ineer ing Division of Nuclear Quality Assurance Division of Nuclear Training Department of'necgy Diviision Percsonne~l Officer DR ECN ECP ECP-SR ECSP ECTG EEOC EQ ENRT EN DES ERT FCR FSAR Discrepancy Report or Deviation Report Engi.neering Change Notice Employee Concerns Program Employee Concerns Program-Site Representative Empl,oyee Concerns Special Program Employee Concerns Task Gc'oup Equal Employment Opportunity Commission Environmental Qualificac.ion Emergency Neidical Response Team Eng,ineecing Design Employee
Response
Team oc Emergency.Response Team Field Change Request Final Safety Analysi,s Report FY GET HCI HVAC Piscal Year
- General, Employee Training, Hazard Control Instruction He.ating,, Ventilating Air Conditi,oning; Installation Znstcuction INPO IRN Inst:itute of Nuclear Power Operations Inspection Reje!ction Notice 0
TVA EMPLOYEE CONCERNS SPECIhL PROGRAM REPORT NUMBER:
20900 FRONT MATTER REV:
2 PAGE vii OF viii L/R M&hI MI MSPB NCR NDE NPP NPS.
NQAM NRC NSB NSRS NU'ON NUMARC OSHA Labor Relations Staff Modifications and. Additions Instruction Maintenance Instruction Merit Systems Protection Board Magneti'c Particle Testi'ng Nonconforming Condition, Report Nondestructive Examination Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Manual'uclear Regulatory Commission.
Nuclear Services Branch Nuclear Safety Reviev Staff Divis'ion of Nuclear Construction (obsolete abbreviation, see DNC)
Nuclear Utility Management and Resources Committee Occupational Safety and Health-Administration (or Act)
'QC QCI Office of Nuclear Power Office of Morkers Compensation Program Personal History Record Liquid Penetrant Testing Quality. Assurance Quality Assurance Procedures
.Quality Control Quality Control Instruction
TVh EMPLOYEf? CONCERNS SPECIhL PROGRhN REPORT NlJMBER:
20900 frRONT NhTTER REV,,
2 1?hGE viii OP v'iii QCP QTC RIF RT SQN SI SOP'RP SWEC TAS Quality Control Procedure Qual',ity Technology Company Reduction in Force Radiographiic Testing Sequoyah Nuclear Plant Surveillance Instruction Standard Operating Procedure'enior IRevieir Panel Stone and 'Webster Engineeking C'orporation Technical hssistance Staff',
TSL TUh TUTLC VT Trades and Labor Tennessee Ualley huthority Tennessee Ualley Trades add Labor Council'ltrasonic Testing Visual Testing WBECSP Watts Bar.Employee Concern Special Program Watts Bar Nuclear Plant WP Work Request o'r Work Rules Morkplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 REVISION NUMBER:
5 Page 2 of 26 Section Executi ve Summary Preface ECSP Glossary of Report Terms Acronyms CONTENTS Page ES-1 1
Introduction 2
Summary of Issues/Generic Applicability 3
Evaluation Process 4
Findings 5
Corrective Actions 6
Causes 7
Collective Siqnificance Glossary Supplement for the Enqineerinq Cateqory Attachments 3
17 18 A
Employee Concerns for Subcateqory 20900 B
Summary of Issues,
- Findings, and Corrective Actions for Subcateqory 20900 C
References A-l B-1 C-1 TABLES Table 1
Classification of Findings and Corrective Actions 2
Findings Summary 3
Matrix of Elements, Corrective Actions, an'd Causes Paqe 21 22 23 26460-R24
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g C
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 REVISION NUMBER:
5 Page 3 of 26 l.
INTROOUCTION This subcategory report summarizes and evaluates the results of the Employee Concerns Special Program (ECSP) element evaluations prepared under Engineering Subcategory 20900, Q-List.
"Q-List" is a generic term used by the nuclear power industry to describe a
listing of the plant structures,
- systems, and components that are to be covered by the Quality Assurance (QA) program requirements of 10 CFR 50, Appendix B.
There is wide variation in the format and detail of the Q-Lists in existence within the nuclear power industry.
Q-Lists r ange from summarv lists containing only systems and components to extensive lists with subcomponent identification and detailed data.
TVA has generally referred to the list as a critical structures,
- systems, and components (CSSC) list for operations activities.
The employee concerns that provide the basis for the element evaluations are listed by element number in Attachment A.
The plant location where the concern was originally identified and the concern applicability to other TVA nuclear plants are also shown.
The evaluations are summarized in the balance of this report as follows:
o Section 2 summarizes, by element, the issues stated or implied in the employee concerns and addresses the determination of qeneric app1 icabi 1 ity o
Section 3 -- outlines the process followed for the element and subcategory evaluations and cites documents reviewed o
Section 4 summarizes the findinqs by element, and identifies the negative findings that must be resolved o
Section 5 -- hiqhliqhts the'orrective actions required for resolution of the negative findings cited in Section 4 and relates
. them to each element and to each plant site o
Section 6 identifies causes of the negative findings o
Section 7 assesses the significance of the negative findings o
Attachment A lists, by element, each employee concern evaluated in the subcategory.
The concern number is given along with notation of any other subcategory with which the concern is shared, and the plant sites to which it could be applicable.
The concern is auoted as received by TVA, and is characterized by TVA as safety related (SR), safety significant (SS), or not safety related (NO) 2646D-R24
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TVA EMPLOYEE CONCERNS S,PECIAI.
PROGRAM REPORT NUMBER:
'20900 REVISION NUMBER:;
Page 4 of 26 o
Attachment B contains a sumharly df the element-level
,evaluations.
Each issue is listed, by element number and p'lancet,
~
along with its corresponding findings and corrective actions.
The reader may trace a concern from.Attachrhen't A tb an issue 'in Attachment 8 by using the element nulmbhr and applicable plant.
The reader may relate a corrective action des'cription in Attachment B to causes and signif.icance in Table 3 by using the CATO number which appears in Attachment B in parentheSes at the end of the corre'ctive'ction description.
The term "Peripheral finding" in.the issue column refers to a
finding that occurred during the Course of evaluating a concer~n but~
did not stem directly from an employee~co'ncern'.
These are classified as "E" in Tables 1
and 2 of this report.
o Attachment C lists the refe&enlcesl cite'd in the text 2.
SUMMARY
OF ISSUES/GENERIC APPLICABILITY The employee concerns listed in Attachment A for each element and plant
~have
~
been
- examined, and the potential problems raised by the five related concerns have been divided into two elements and identified as four separate issues.
Elements 209.1 and 209.2 had indiv'idual element evaluations prepared for SQN,'hile they were combined and addressed under element evaluation 209.1 for the other three pl ants.
Thi s, i s ref 1 ec ted in Tao 1 e
~1 of thi s r eport.
I All of the employee. concerns listed were~evaluated for each nf the four plant.;
except Concern IN-86-095-OOI?,
which was evaluated. only for MBN.
This concern was regarding the use of a CSSC Q-List.
Thle CSSC Q-List was not used at either
- SQN, BLN, or BFlli; thus, no evaluation of this concern was required at these three nuclear plant, sites.
All of the other issues were evaluated~ for
~
each plant.
The issues can be summarized a~s fol'lows:
o Element 209. 1 - Q-List Oifferences The documents (Q-Lists or equivaliant) used to ident,i'fy'the applicability of QA program controls are not accurate and complete.
Various Q-Lists, (or equivalents,)
exist at the same time that are different in content.
The engineerinq design qrc)up dcIes not provide input tn the Q-Lists (or equivalents).
26460-R24
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM.
REPORT NUMBER:
20900 REVISION NUMBER:
5 Page 5 of 26 o
Element 209.2 - Impact and Significance of 0-list Differences The use of inadequate g-Lists (or equivalents) could have adversely affected the establishment of appropriate gA program controls on items that are related to plant safety.
By reference to an inadequate g-List, the possibility exists that "non-g" items are installed in a safety-related system.
Each issue reviewed in the element evaluations is stated fully in Attachment B, which also lists corresponding findings (both positive and negative) and corrective actions that are discussed in Sections 4 and 5 of this, report.
3.
EVALUATION PROCESS This subcategory report is based on the information contained in the element evaluations prepared to address the specific employee concerns related to those issues stated in Section 2 above.
The evaluation process consisted of the following steps:
3.1 Element Evaluation Process a ~
b.
C ~
d.
Oefined the issues for each element from the employee concerns.
Reviewed regulatory guides (Refs.
1, 2,
and 3),
TVA criteria documents (Refs.
44 thrqugh 50),
and TVA ornqrams (Refs.
15 through 17, and 82) related to developing procedures (Refs.
30 through 35) and practices (Refs.
36 throuqh 43) to govern 0-Lists (or equivalent documents).
Reviewed applicable FSAR sections (Ref s.
4 through
- 13) to understand scope and basis of NRC review (Refs.
66 through 84), to determine requl atory compliance, and to identify any open issues or TVA comnitments related to g-Lists.
Reviewed applicable
- manuals, standards, and specifications (Refs.
15 through 29) and conducted facility visits (Refs.
116 and 117) to develop 9-List understanding.
e.
Reviewed any other documents applicable to the issues and determined to be needed for the evaluation, such as correspondence (Refs.
63 through 84, 87 through 114), instructions (Refs.
51 through 54),
Corrective Action Reports (CARs) (Ref. 59), Nonconforming Condition Reports (NCRs) (Refs.
55, 56, and 95 through.107),
evaluation and review reports (Refs.
14, 57, 58, 85 through 92,
- 108, and 109), etc.
26460-R24 (12/22/87)
TVA,EMPLOYEE CONCERNS SPECIAL. PROGRAM Rl.:PORT NUMBER:
2ilgOO RI=VISION NUMBER:
i 5
~
Page 6 of 26 I
f.
Made visits to WBN, SQN and BFN plant sites.to further evalluate thh i ssues.
g.
Using the rlesults from steps a throuqh e above, evaluated the issues for the element and documented the fihdings.
h.
Evaluatecl TVA's committed corrective act'ioris.
3.2
~Subcate i>~r Eualuation Process a.
Tabulatecl i.ssues finclings, and corrective actions from the element evaluations in a plant-by-plarht arrangement (see Attachment 8).
b.
Prepared Talbles 'I, 2, arid 3 to permit comparison and identification of common and unique issues, findings!, a'nd'corrective actions'etween the four plants.
c.
Classified the findings and corrective actions from the element evaluations us,ing the ECSP definitions.
d.
e.
On the basis of ECSP cluidelin&s, arialyzed the collective significance aind causes of the findings from the element evaluations.
Evaluated defined corrective actions to determine if addit'ional actions are required as a result~ of causes found in step du Provided addit,ional,judqment and/or information that may not have been apparent at the element evaluation level.
4.
F INO IiVGS The findings from the five element evaluations For this subcategory are listed by element number and by p'lant in Attachment B. 'The findings for eaCh element are summarized, in the following paragraphs.
4.1 Bac~caround The five employee coricerns in the element evaluations associated with this, subcategory report relate to the concurrent exiSte'nce of different Q-Lists.for WBN, the accuracy of the, lists, and the impact of using those lists.
These concerns were investigated as well for SQN, BFN>>
and BLN.
2646D-R24
( 12/22/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT HUMBER:
20900 REVISION NUMBER:
5 Page 7 of 26 "Q-List" is a generic term used oy the nuclear power industry to describe a
listing of the plant structures,
- systems, and components that are to be covered by the Quality Assurance (QA) program requirements of 10 CFR 50 Appendix B.
There is wide variation in the format and detail of the Q-Lists in existence within the nuclear power industry, from summary type l.ists containing only first-level identification, to extensive listings with subcomponent identification and detailed data.
TVA policy documents, including the governing upper-tier Nuclear Quality Assurance Manual (HQAM) (Refs.
18, 19, 20, and 23),
have established the commitment that the Division of Nuclear Engineering (DNE) will develop and maintain a Q-List for each. nuclear plant.
The DNE-developed Q-List will be used by all divisions within a plant to maintain uniformity.
The timinq for implementation of a DNE-developed q-List is a plant-unique situation, as noted
(
in the following paragraph.
The specific portion of the NQAM that addresses Q-List is ID-'QAP-2.7.
ID-QAP-2.7 (Ref.
18), which governs the development,
- control, and application of a Q-List for each nuclear plant, has undergone several revisions affectinq the implementation commitment for the Q-Lists at the various plants.
It now states that "The SQN and BFN Q-.Lists will be put into effect by the NSD at a
date mutual,ly agreed to by ONE and the NSD" and that the "NSDs for WBN and BLH shall implement the Q-List and incorporate its requirements into its plant operating instructions prior to receipt of an operating license for the first unit."
The following is the chronoloqy of the major events concerning TVA Q-Lists/CSSC Lists at the four nuclear plant sites:
04/78:
10/82:
01/83:
01/84:
Nuclear Power (NUC PR) organization issues a Critical Structures,
- Systems, and Components (CSSC) List for each plant for application of the Operational QA proqr am; the list is added to the Nuclear Quality Assurance Manual (NQAM) as Appendix A, and identified as the NQAM CSSC List.
This list was derived from the PSAR/FSAR CSSC Lists The Office of Engineering Design and Construction (OEDC) procedure OEDC-2QPD-5, Rl, assiqns the Office of Enqineerinq Design (EN DES) the responsibility for preparing a detailed CSSC List for BFH EN DES (now ONE) issues the WBN 'Q-List for one year's trial use, intended as a controlled singgge ist of structures,
- systems, and components covered by the TVA QA program EN DES (now DNE) reissues the WBN Q-List for use;
- however, HUC PR continues to utilize the HQAM $ZEC List stating that it is better suited to that organization's needs 2646D-R24
( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBERS:
',20900 REVISION NUMBER:
5 Page 8 of 26 05/84:
10/84:
11/84:
12/84 01/85:
02/85:
06/85:
07/85:
07/85:
08/85:
08/85:
10/85:
11/85:
01/86:
03/86:
03/86:
EN OiES (now DNIE) issues the'N OLS CSCC I ist for BFN EN OES (now ONIE) issues BLN Q-List A sp!ecial sublist.ing of the WBN Q-List is developed by the Office of Engineering
[OIE] (f<)rmerly EN OES, now DNE), sorted by selected design functions identified by'UC PR; this list is called the WBN CSSC~-Li st NQAHI Part V, IO-QAP-2.7, "Q-List" revised; OE (now ONE) identified as having rc!sponsibility for devdloping and maintaining Q-List for each nuclear, plant NUC PR issues WBN-Ai[-7.6, which provides for use of the AB5 Q-List and WBH CSSC Q-List in lieu, of thie NQAM CSSC List; at this point discrepancaes between the NQAM CSSC List and the WBN CSSC Q-Ljst become evident and investigation begins Responsibility for maintaining the CSSC Lists is transferred from corp!orate OHQA in Chattanooga 'to'the NSDs TVA receives Employee Concer'n IH-85-407-001 TVA r.eceives.Emplovee Concern IN-'85'-688-603 CSSC'List deleted from HQAM Appendix A
TVA receives Employee Concerns IH-.85-087-004 and IH-BG-090-001I TVA issues Nonconforming Condit'iOn Neporj:
HCR W-269-P at
':lBN TVA reports NCR W-269-P, Rl to the NRC.in accordance with 10 CFR 50.55(e)
TVA receives Employee Concern 'lN-'86-095-002.
As a partial resolution.of HCR W-269-P, Rl, HUC PR revises
'BN-AI-7.6 to delete the WBN C'SSC Q~Li'st HQAM Part V, IO-QAP-2. 7, "Q-List," revised to. change BLH Q-List implementation to before fuel load TVA issues final report to NRC on NI.R W-269-P, Rl 0
03/10/86:
TVA submits Corporate I'nuclear Perfo~ancd Plan (CNPP),
Volu'me '1,'RO',
to NRC 26460-R24
( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 REVISION NUMBER:
5 Page 9 of 26 06/86:
NQAM Part V, IO-QAP-2.7, "Q-List,." Revision 0 issued to revise Q-List implementation requirements for SQN and BFN 09/86:
TVA issues revised.final report to NRC on NCR W-269-P, Rl 4.2 Element 209.
1 - Q-List Oifferences 4.2.1 Watts Bar Nuclear Pl ant Findings The WBN "Q-Lists" provided a basic reference for the various WBN organizations to identify those structures,
- systems, and components which are subject to the special requirements and activities of the QA program.
Organizational use of the Q-List includes the following:
o As the design organization, EN DES originated the Q-List as a desiqn-output document to provide information (i.e., identification of structures, systems and components in the gA program) to interfacing organizations
- notably the Offices of Construction (OC) and Nuclear Power (NUC PR).
EN OES (now ONE) also had use for the Q-List internally, as a reference for performing activities such as safety evaluations.
o Within OC, the Q-List is designated for use in determining identification of structures,
- systems, and components in the QA Program.
The content nf the workplans developed by OC to control construction and installation activities could be significantly
.impacted by the resultant determination of "Q" status of the related structure,
- system, or component.
o Within NUC PR, the Q-List is used in the control of maintenance and modification activities.
The requirements prescrioed in maintenance requests and workplans, includinq such items as inspection activities and documentation requirements, could be significantly impacted by the "Q" status of the related structure,
- system, or component.
The employee concerns relating to Q-List(s) deficiencies were raised during mid-1985.
This time frame corresponds to the performance by TVA of investigations of problems with the Q-List(s),
and indicates a general awareness within TVA of the issues noted. in these employee concerns.
For this
- reason, the evaluation of these:issues is focused on a review of the TVA systematic investigations and the resulting corrective actions that have occurred or are in process on Q-List(s) problems.
TVA Nonconforming Condition Report NCR W-269-P, Rl (Ref..
56) and its associated corrective action, provide the. most significant evidence that the pertinent issues regarding Q-Lists have been recognized and are being resolved by TVA.
NCR W-269-P, Rl, documents discrepancies, inaccuracies and omissions 2646D-R24'] 2/22/87)
TVA EMPLOYEE CONCERNS
,'SPECIAL PROGRAM REPORT NUMBER:
20'900 REVISION NUMBER:
'age 10 of 26 0
in the Q-List for programmatic areas and certain specific systems.
This condition was determined by TYA to constitute a significant deficiendy that required reporting to the NRC under the 'requi'rements of 10 CFR 50.55(e)'.
'A brief chronology of the activities specific to NCR W-269-P, Rl, and its'elated subject matters is as follows".
01/85:
Q-List review initiated by Plant QA St',aff'o investigate alleged discrepancies 08/85:
Quality Evaluation Report, QE-85-09 '(Ref.
- 91) issued to docllment discreIpancies identified in the rev'iev'~ of Q-List treatment of Systems 62 and 63 08/85:
Corrective Action Report WB-CAR-85-45 issued to require NUC P0 action on certain CSSC Q-List diScrepancies 08/85:
Nonconforming Condi'tion Report NCR W-269 P issued to document both progr amatic and specific Q-List discrepancieS 10/85:
NCR W-',269l-PRl, issued to expand on the'etail of the ident i fied (f-List d i screpanc ies
'0/85:
NSRS Investigation Report No.
I-85-422-WBN issued documentinq'he NSRS review of Employee Concerns relating to Q-List discr'epancies 10/85:
TYA provides initial notification to the NRC of the 10 CFR '50!.55(e) reportability of NCR W-269-,P, 'Rl
'2/85:
TYA Interim.10 CFR.50.55(e)
Rdpo&t issued to the'RC r eqardinq NCR W-269'-PR1 02/86:
CAR WB-CAR-85-45 corrective action documented to be complete and the CAR closed 03/86:
TVA Final 10 CFR 50,.55(e)
Report issued to the! RC regardinq NCR, W-;269-P R 1 09/86 Revised Final 10 CFR 50.'55(e)
Report issued to the NRC regarding
'NCR W-;269'-PRl Relative to the accuracy and completeness of the Q Lists for WBN, the TVA systematic evaluations relating to NCR W-269-P, Rl, identified that discrepancies existed in the Q-Lists, including the following types of deficiencies:
o Omissions of safety-related items from the Q-Lists 0
2646D-R24
( 12/22/87) 0'
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 REVISION NUMBER:
5 Page ll of 26 o
Inconsistency of Q-Lists with NQAM requirements regarding differentiation between safety-related and special feature equipment o
Inaccurate identification of items in the Q-Lists o
Inadequacy of Q-List notices to reflect appropriate QA, program implementation requirements The revised final 10 CFR 50.55(e)
Report (Ref.
- 68) documented a TVA commitment to perform a complete review of the WBN Q-List before fuel load of WBN unit l.
This commitment was a result of a completeness review of the WBN Q-List for six systems.
That-review (Ref.
107) identified errors in the Q-List cover age for these systems which were quantified and classified by TVA as.fol 1 ows:
Classification Component Identification Errors Safety Function Errors Omissions From Q-List Number of Errors 183 41 110 The concern that changes were made to the Q-Lists without Engineerinq input was found not to be valid for any of the four plants.
Element 209.
1 found the
. accuracy of the Q-List (or equivalent document) was questionable fo'r two of the four plants, SQN and WBN.
4.2.2 Sequoyah Nuclear Plant Findings The listing for SQN is identified as the Critical Structures,
- Systems, and Components (CSSC) List (Ref. 36),
and is nf the summary type.
The SQN CSSC List is characterized as a working document, with everyday usage in SQN activities includinq modifications, maintenance, and procurement.
- However, the use of the SQN CSSC List is limited to the Operations organization only (e.g.
for procurement of maintenance materials and for modifications); the list was not used by Construction or Engineering at Sgn, and currently is not used by Engineering.
The SQN CSSC:List identifies safety-related structures, systems,,
and components comnitted in the SQN FSAR (Ref.
- 4) Section 3.2.
The individual system drawings (flow diagrams, control diagrams, etc.)
developed by Engineering identify the safety-related structures,
- systems, and components at SQN.
These design basis drawings',
rather than the SQN CSSC List, were used by the Engineering and Construction organizations as the source documents to determine the items that required QA proqram controls.
26460-R24
( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL 'PROGRiR REPORT NUMBER:,
, 2$ 90O REVISION NUMBER:
5 Page 12 ot 26 Engineering deve'loped design documents t'hat w'erd siibs'eqiiently used bp Construction.
Operations developed the CS!iC IList i rom the same engiriieerin'9 design documents with engineering participation.'ng'ineering iS represented on the CSSC Review Committee which had t'he'respainsability I>f updatina, the ICSSC List.
Engineering continued to use the designee documents from which the CSSC List was created while Operations used t'he'CSCC Li.t.
Since any list wc)uld bie prepared from the engineering documents, coexistence of a list and do'cuments
'oes riot represent de facto use of two lists (at'east not in the same rontext as at WBN where a Q-List and a
CSSC list'et e'eing used concurrently'}.
'onstruction Specification N2G-877 (Ref. 28) provicles guidance to the'onstruction organization for identifying items requiring QA program controls.
Tables were included as part 'of N2G-8?7 (prior to revision 5) which contained generalized convenience listings of safety-related
- items, However, the tables were used only as -guidelines and did not constitute a '"Q-List."
The current revision of N2G-877, Revision 5, allows Construction to use a
"Q-List" (91QL series dr awings) as an alternative to the system drawings for identification of items requiring QA pro)rain donItrols.,
IHowever,. the klQ'L series drawings have not been implemente~i at SQN pendinq the,Q-List development activity noted in the NQAM and out,lined, bqloy.
- Further, thi's alternative method has not been used by (',on'st/uckion.
Control of the SQN CSSC List is established througn, Sequoyah Administrative Instruction AI-39 (Ref. 51) which provides far a
SQN 'CSSC Review Committee, the membership of which includes. engineerinq, to maintain the SQN CSS(', List.
The committee is required to perform a biennial review of the CSSC List to ensure that the list is accurate and complete.
The review of referenced documents identified yarioIis cases of direct or inferred concern regarding the accuracy.
and coiinplett~ness of the CSSC List.
A complete review of the SQN CSSC List has hot been accomplished.
'Minutes of CSSC Review Committee meetinqs (Ref.
62} refleIcted that the committee performed numerous activities respondinq to "Request for Revision to CSSC List" forms, but those activities do not constitute a complete review of 'th>
SQN CSSC List.
NRC Report 50-327/86-11 (Ref. 84) documents NRL inspection activities associated with followup of TVA's response to NRC Generic Letter 83-28 (Ref. 72), which contains requi rements fol lickns'eel, tb c'onfino safety-related identification of reactor trip system common'ents
'antIl to describe their~
pro'grams for ensurinij that all components of other safety-,"related sy'stems are identified-as safety-related.
2646D-R24
( 12/22/87}
TVA EMPLOYEE CONCERNS
,SPECIAL PROGRAM REPORT NUMBER:
20900 REVISION NUMBER:
5 Page 13 of 26 maint n
n Results of this NRC inspection identified that the c e current program for enance of'he CSSC List deviates from the program de b
d b
The NRC inspector also concluded that TVA's seri e
y in the mcsestchoRds for revising the CSSC List lacked a formalized system for tracking eview Committee agenda
- items, and for requesting changes to the CSSC List.
TVA's response (Ref.
- 66) to the NRC inspection report did not dd either of these items.
i no a
ress The NRC inspection also included a limited review (sample of seven) of classif maintenance requests to verify that work activities were b
1
'ed as CSSC or non-CSSC.
In the area of equipment classification, the NRC determined that there were no violations or deviations.
The evaluation team considers the issues relating to the accuracy and tempered b
th completeness of the SQN CSSC List to be valid for SQN Th' r
is conclusion is p
y the positive factor that the on-going activities of the SQN CSSC Review Committee provide a reasonable assurance that th pro ems with the SQN CSSC List.,
However, it is prudent for TVA to.perform a
robl m
ere are no major confirmatory review of the accuracy and completeness of th SQN CSSC ss arious TVA internal references (direct or implied) to the need for such a review.
The review should be performed with input from DNE to determine the degree of completeness appropriate for th 1'
include r r
e is, and should resolution of those agenda items previously deferred by the SQN CSS" Review Comnittee.
The SQN CSSC List was initially developed and issued by NUC PR, and is presently the responsibility of the NSD through the Operations organization.
The CSSC List is maintained by the SQN CSSC Review Committee.
ONE has actively participated in CSSC Review Committee activiti s
ivi ies on an as-needed asis.
e interface with ONE tempers the employee concern related to the issue of lack of engineering design group input/approval of the CSSC List, and indicates a
DNE de facto involvement with the list.
The NRC has stated that the SQN CSSC List and its utilization process appeared to be working,and wer e adequate for the short term (SQN unit 2 restart),
but they recommended that TVA develop and implement the SQN Q-List in an expeditious manner (Ref.
120).
Following the NRC review, DNQA and EA performed a joint audit of SQN, which resulted
.in a recommendation that Engineering and Operations commit to the expeditious development and publication of a controlled SQN Q-List (Ref.
119).
TVA committed in a letter to the NRC (Ref.
121) that they will "provide an implementation plan for the t.SQN] Q-List by March 1, 1988."
This is being tracked by the Corporate Commitment Tracking System (CCTS} item NCO 860194003.
Mhen this plan for the implementation of a SQN-Q-List is provided, the plan will be assigned a
CCTS h
2646D-R24
( 12/22/87)
.TVA EMPl OYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER I
)O9QO REV IS)'ON NUMBI'R I'age 14 of 26 item number and tracked to completion.
This will ensure that TVA tracks the Q-List implementation as a commitment to the, NRC and will enable the NRC to monitor the Q-List impliementation.
lhus a CATD is not required wi.thi this report.
4.2.3 Brownsl Fierry Nuclear Plant Findings At about the same time that the Office of Nuclear Power issued the Appendix A, SSC List to the NQAM (Ref.
19), the BFN Plant Super intendent issued Standard PraCtiCe BF 1.11 (Ref.
39)>>
WhiCh WaS a'iSO deriVed fram the FSAR CSSC LiSt (Ref. 11).
A review of historical documents by the evaluation team showS that tIIe )F,l.]l CSSC List is, and 'has been,,
an integral, part, of, procurement, maintenqnc,,an(I modification activities at BFii.
Tiie HF)( proc edur'es (Reft 39.and
- 60) tliat control these activities typical-ly cite thIn CSSC List as the source documelnt for determining safety-elaited CSSC items and activities.
Site Director Standard. Practice (SDSP) 2'.?,(fpr(tIerly 2.14) has required sinqe 1981, that a review of'he BF 1.11 CSSC List be performed at least ev'erg' years..SDSP
- 2. ill requires that the rgavipw,as(;ertain that the information on, the list is complete and accurate.
A revieiw of the r(avision history,indicates that there.have been eight revisions to the BF 1.1 1 CSSC List since 1981.
All revisions except one add items to the CSSC List that were identified in other documents as belonging in. the CSSC List.
The one revision that indicates "annual review"'roduced only editorial changes.,
The extent of the a.tual review is not i<howe.
Disco.'sion." with TVA perso(me)
(Ref.
117) indic teIl tha) no review record exists that would provide I vi'deI)ce ofiennial review, exceoi; the history-of-revision, page of BF 1.11.
P~ragrI)ph 6.,2 Of SDSP 2.7 cqntains the following statement:
"The qeneral'(Ivision of a orocedure.constitut(as a
review."
Before July 1985, the review could hav(m b'eer> accomp'lished by an item-.for-item comparison to the NQAM, Appendix A.CSSC List which,was -being revie( ed', b SS Review Committee in the corporate QA or~gapiaation in Chattanooga.
Frorp February July 1986 to the present, the BF)N Site Director has been ri spionsib'le for the accuracy and completeness of the BF 1.11 CSSC List.
More than one Q-List (or equivalent) with different content were in use at the same time at BFN.
BFN hacl i.ssued a secon) c)sc L'ist (EN DEs cssc List) while the Operations/NQAM. CSSC List.was in use.
There I<as not sufficient evidence, to indicate that the BF l. 11 CSSC List wag cpmpleI:e and accurate.
A, npw I
Q-List is being developed and wi 1.1 replace the existing CSSC Lists after th new and existing lists are compared and after any discrepancies, that a~'e Found are documented.
2646D-R24
( 12/22/87)
TVA EMPLOYEE CONCERNS.
SPECIAL PROGRAM REPORT 'NUMBER:
20900 REVISION NUMBER:
5 Page 15 of 26 The issue which relates to lack of engineering design group input to the Q-List is not valid for BFN.
The SFH 1.11 CSSC List was originally derived from the FSAR list,. and the revision record describes revisions resulting from engineering input.
4.2.4 Bellefonte Nuclear Plant Findings BLN is now using a single Q-List to satisfy the intent of 10 CFR 50, Appendix B, Criterion II.
In the past,
- however, several different lists were used to determine which pl.ant items required QA program controls.
The lists were as follows:
o From the beginning of the project in 1972 to the present, BLN has used a set of criteria documents to identify the safety-related structures,
- systems, and components.
o The PSAR/FSAR contains a summary listing of structures,
- systems, and components (July 1973 to present).
o From April 1978 through July 1985, Appendix A of the OQAM/NQAM contained a
CSSC List that was derived from the PSAR CSSC List.
In July 1985, the list was deleted from the HQAM, and thus was superseded by the BLN BLGl CSSC. List.
o BLH Standard Practice BLGl included a
CSSC List and was issued in 1982.
On November 20, 1986,.the CSSC List was replaced by the BLN Q-List.
o The BLN Q-List was issued by system from October 1984 through
=February
- 1985, and it listed the items defined by the criteria documents.
The BLN Q-List appears to be adequately controlled by engineering procedures.
For design and construction activities, the listing of safety-related structures,
- systems, and components was provided from 1972 to October 1984 by design criteria documents and diagrams.
In October
- 1984, EN DES (now DHE) began
- issuing, by system groups, the Q-List which became the primary list of safety-related items but was supplemented by the design criteria documents and diagrams.
All systems wer e issued as Revision 0 by February 1985.
To cover the operational activities, TVA issued BLN Standard Practice BLGl in 1982.
BLGl contained a
CSSC List which was maintained equivalent to the OQAM/HQAM.
In November
- 1986, BLGl deleted the CSSC List and incorporated the BLH Q-List, thereby making the BLN Q-List applicable to all project activities.
The BLH Q-List and the controlling and supporting procedures used for BLH that affect safety-related structures,
- systems, and components are all engineering documents.
Thus, the issue relating to lack of engineering input to the Q-List is not valid for BLN.
2646D-R24
( 12/22/87)
TVA EMI>LOYEE, CONCERNS SPECIAL PROGRAM REPORT NUMBER".
20900 REVISION NUMBER:
5, Page 16 of 26 The evaluation team identified one per'ipheral findipg,requiring resoluition at, BLN:
lack of evidence that CSSC open action items reported by the i)ivision of'uclear Quality'ssurance (ONQA) in a memo from R. J. Mullin to Those Listed (Ref.
10B) had been closed out Even though no evidence was found that the NQAM CSSC List open items were
- resolved, the eva'luator found that the BLN Q-List, appeared to be accurate and complete on the basis of the. thorough, formalized procedures used to prepare the Q-List.
The procedures includeci reviewS by all engineering discipliiies, trial use feedback from the construction organization, and independent reviews.
Because the BLN.Q-List (Ref.
122),
as noted
- above, appears to the evaluation team to be accurate and complete, the evaluatiion,team found no evidence of, misclassified safety-related items during fabricytion or installation,.
4.3 Element 209.2 - Impact and Siqnificance Of ()-List Oifferences The full significance of the findings of this Q-List subcategory to the physical plants cannot be evaluated until the corrective action reviews, which have been committed to by WBN, SQN, and BFN, have been completed and the final impact assessed.
If the reviews find that saf'ety-related structures,
- systems, or components, Ihad been manuf actured and instal led as nonsaf ety-r el ated, the consequences could be very signif'icant.
It would mean that certain quality assurance p~ogram activities durinq design, construction, and operation intended to ensure that a structure,
- systems, or component will perform satisfactorily in service may not have been performed,.
4.4
~Summa'f Subtat~eo~r Findi~na A summary of the classif ied findinqs is prqviped, in Table 1.
Class A and 9
findings indicate that, there iis no problem ~and tnat,'orrective action is not required.
Class C, 0, and E f'indinqs require,corrective actions.
The corrective action class, defined in the Glossary Supplement, is identified, in the table by the numeral combined with the, finding, clasS.
For example, the designation 03 in Table 1 ind'icates that the evaluated issue was found to be valid (findinq class 0) and that a corrective action involvinq some t'yp0 olf documentation revision is requi'red (corrective action Class 3).
0 26460-R24 (12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20900 REVISION NUMBER:
5 Page 17 of 26 Findings are summarized by classification in Table 2.
Of the 15 findings identified by a classification in Table 1,
seven require no corrective action.
Of the remaining, two findings had corrective actions initiated before the ECTG evaluation and five required new corrective actions to be taken.
There was one peripheral finding uncovered during the ECTG evaluation which required.new corrective action.
5.
CORRECTIVE ACTIONS As noted in Section 4 of this report, Table 2 identifies eight findings that require corrective action.
The detailed corrective actions are described in Attachment B (listed by element and by plant).
A condensation of this information by element and applicable plant follows.
5.1 Element 209.1 - Q-List Oifferences At WBN, in response to eIement level
- CATOs, TVA has committed to review the
.-L>st and to revise it as required to make it accurate. TVA also will.delete the CSSC Q-List and review activities that took place during the use of the CSSC Q-List to verify that the QA program was adequately implemented. At Sf}N, TVA orovided justification that the biennial review of the CSSC List is not necessary prior to restart. The NRC concluded that the SCN CSSC list and its utilization process appeared to be workinq and were adequate for the short term (SQN unit 2 restart), but recommended the SQN Q-List be developed and implemented in an expeditious manner. TVA has comnitted to submit a Q-List implementation plan to the NRC by March 1; 1988 (Ref. 121). Because this is tracked on CCTS (item number,'<CO 860194003), and the Q-List implementation plan, once it is provided, wi 11 also be tracked on CCTS, there is no CATO required with this report. At BFN, in response to element level
- CATOs, TVA has committed to complete the
~neve opment of and,issue, a new i}-List. then discontinue the EN NES and liUC PR CSSC Lists. TVA also committed to compare the new Q-List with the BF'. 11 CSSC List and EH OES CSSC List and resolve the differences. At BLN, in response to element level
- CATDs, TVA has committed to close out UHg~memo (Ref.. 108) open action items.
5.2 Element 209.2 - Impact and Si nificance of Q-List Oifferences TVA will review the activities that took place du~ing the use of the CSSC Q-List at WBN, and during the use of the questionable CSSC lists at SQN and BFN, to verify that the QA proqram was adequately implemented. 26460-R24 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 2O90fI REVISION NUMBERS: 5 Page 18 of 26 5.3 Summarized iCorrecti ve Actions These corrective actions appear in Table 3,, along with their corresponding finding/corrective action classifications.'he'table indicates the plaint or plants to which a corrective action is applicable by the Corrective Action Tracking Document .(CATO) column where'he applicable plant is identified b' the CATD number. Until corrective action is completed, the potential exists for physical plant changes. The evaluation teami found the corrective action plans submitted for WBN,, SqN,,
- BFN, and BLN to be acceptable to resolve the findings.
6. CAUSES Table 3 identifies causes f'r each neqativ~~ fincling requiring corrective action. Table 3 has 1I7 column headings representing causes af riegative findings (e.g, "l ack of Management Atteniti<)n," "Inadequate Procedures," etc.) For each negative finding, the most irnpo!rtant causIs identified. Whenever direct evidence linked a cause to a negative finding requirinq corrective
- action, such evidence was taken into acc~ount.~
For the eiqht correctiive actions described'in'able 3, nine causes have been identified. These are slhown in the table and tdtaled at the end. o WBN - Omissions and errors in the WBN O-List, nreviously reported by TV%, were causied by "Engineering Error" and were not resolved in a timely manner. The use of the C.'tSC! 9 'List an8 activities result'inq therefrom is the result of " Inadequate Communication" between engineering and maintenance persdnniel. o 'S()N - "Untimel.y Resolution of 'Issues" 'is'th'e c,,auI~e of lack of resolution of 'the S(JN iCSSC Reviel Cbmmittee agenda items which were'epeatedly deferred., o BFN - "Inadequate Communication" 'between enginieering and operations personnel is the cause of the 'ladk of 'adequ'ate review of th'e BFN'SSC and issuance of'he NUC PIR CSSC List. o BLN - The caiuse of the lack of'ina'1 c'loseout of ON(A open-act:ion ztems For BEN is "Untimely Res'olution 'of Issues." II 26460-R24 ,( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION'UMBER: 5 Page 19 of 26 Although "Inadequate Communication" and "Untimely Resolution of Issues" are noted in Table 3 as the causes of the negative findings requiring corrective
- action, the evaluation team believes the negative findings primarily stem from a "Fragmented Organization" wherein the responsibility and authority for preparing and implementing an adequate listing of safety-related structures,
- systems, and components were not clearly delineated and enforced between functional organizations.
7. COLLECTIVE SIGNIFICANCE The five concerns expressed in this subcategory resulted in eight findings requiring corrective actions as a direct result of 'the employee concerns. Corrective actions were in progress for two of the findings at the time of the ECTG evaluation. The eight findings requiring corrective action were judged to be significant. The full significance of the negative findings is that the impact of any omissions from the g-Lists/CSSC Lists is indeterminate because the evaluations of g-List accuracy are not complete. Thus, there is some.potential for future ohysical plant changes. The consequences cannot be determined until the corrective action reviews have been performed. However, the following observations can be made at this time: o The concern that multiple (}-Lists existed independently and concurrently was found to be valid at two plants (WBN and BFN) but under different circumstances. The CSSC (j-List was issued at MBN in 1984 to provide a more workable document than the g-List for NUC PR use in operations, maintenance, and modification activities. UFfi had, or has, sever al lists for the purpose of satisfyinq the intent of 10 CFR 50, Appendix 8, Criterion I.I. Although the concern represents a significant problem, the significance is tempered by the fact that each list was used only by the operations organization and only for a limited time, and that the lists are being compared to resolve potential deficiencies. o Table 3 identifies four cases nf "Inadequate Communication," four cases where the cause is "Untimely Resolution of Issues," and one instance of "Engineering Error." TVA's gA organization identified C-Listicssc List problems at wBN wnicb resulted in initiation of corrective action. Perhaps gA audits should have identified the negative findings in this report at SgN,
- BFN, and BLN.
- However, specific corrective actions for these negative findinqs were initiated at the element level.
Category Report 80000, Rev. 2, guality Assurance,
- states, "Corrective action has been implemented 2646D-R24
( 12/22/87)
TVA EMPI OYEE CONCERNS ,SPE',CIAL PROGRAM REPORT.NUMBER: 25905 REVISION NUMBER: 5 Page 20 of'6 by 1VA to resolve the audit progii ariii p&oblenis,'... A tr'ackin) CATA was issued to verify effectivd iinplem&ntation,." The report did not contain specifics regarding individual items (such as Q-'Li~t)'f'rL overall audit program. The Q-IList is a document that shiould tie-monitored and maint;ailned by line management and periodically audited by QA. Thus,, the QA organizat,ion would have a lesSer rolealnd lohger feedback
- loop, than line management' day to day invcilvement,.
Occas'ional 'prbbl'em'f this sort are to be expected, but the frequency tri nd should become lower with time as errdrs in detail are identified through use., If the trend does not shiow a "time related" frequency reduction, the reasons should be examined. Auditing for this purpose would be appropriate. No broader conclusions can be drawn from these causes. The la'st three colvmns of Table 3 ~how the sign1ficance of the corrective actions, with r'egard to actual or.potential changes in documentation,
- margins, and hardware.
Until the review of Q-Lists/CSSC Lists-has been completed, 'here is a pot:ential that hiardware may have to be changed because it does not: meet QA program requirement,s. TVA has developed a series of Nuclear Perf6rmande Plans (NPPs) to correct programmatic and management, shortcomings that have contributed to the problems experienced in d irectiion and control of TVA' nuclear activities. Volume 1 qif the HPP describes the measuires that TVA ha< taken and currently intends to take to improve the corporate-level management of'ts nuclear activitie< ahd to correct the problems that have occurred in thiiS area. Volumes 2, 3, and address
- SQN, BFN,,
and MBN, respectively.'hei e 'is cvrrently no plant'-spec'ifi'c NPP for BLN. The three plant-specific nuclear plerformarlice plans providk aln account of the actions TVA is.taking to improve its nuclea~ proqram. The Q-List/CSSC List was specifically addressed only in the Watts Bar NPP; The commitments in the Corporate HPP to consolidate the nuclear orqanization, to develop standard procedures, and cont'rol iinte'rfaces with support organizations, a'iong with the specific corr'ective actions at the element'. level to which TVA hias committed in response t'o t',he'fi'ndinas for the individual
- plants, and thie NQAM requirement for a Q-List to be implo.mented at each of th' nuclear plant sites, should e1liminate future problems regarding accvr'acyl oF the 1-ists of.safety-related structvres, sy<te4s, and components.
The results of this subcategory evaluation are combined with the other subcategory-evaluations and reassessed in tthe Enginee'rin'g category report. 26460-R24 (12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page 21 of 26 TABLE 1 CLASSIFICATION OF FINDINGS AND CORRECTIVE ACTIONS Element 209. 1 g-List Differences Issue/ ~Findin ** Finding/Corrective Action Class* S N WBN 8 N LN 03 C3 03 E3 (1) A 06 A A C3 03 A A A A 209.2 Impact and Significance of b g-List Differences (2) (2) (2) (1) (2) Issue is addressed. in element 209.2. Issue is addressed in element 209.1.
- Classification of Findin s
and Corrective Actions A. B. C. 0. E. Issue not valid. No corrective action required. Issue valid but consequences acceptable. No corrective action required. Issue valid. Corrective action initiated before ECTG evaluation. Issue valid. Corrective action taken as a result of ECTG evaluation. Peripheral issue uncovered during ECTG evaluation. Corrective action required.
- 1. Hardware
- 2. Procedure
- 3. Documentation
- 4. Training
- 5. Analysis
- 6. Evaluation
- 7. Other
- Defined in Attachment B.
26460-R24 ( 12/22/87)
TVA EMPLOYEE CONCERNS ,'SPECIAL PROGRAM REPORT NUMBER: 20905 REVISION NUMBERS: 5 Page 22 of 26 TABL'E 2 F INOINGS SUGARY Cl assificatiion of Findiii~ns A. Issue not validl. No corriective action required,. B. Issue valid but, consequences acceptable. No corrective action required. C. Issue val id. Corrective action initiated before ECTG evaluation. 0. Issue val id. Corrective action taken as a result of ECTG evaluation., E. Peripheral issue uncovered durinq ECTG evaluation. Corrective action required. Plant SQN WBN BFN BLN i2>>1 1 3 '0'0' 0 0 2 0 0 '2 0 3 0 0 0 0 1 Tiota 1 0 lotal 2646D-R24 ( 12/22/87)
IATLE 3 HXIRIX Of ftfafNIS ~ CORRECTIVE ACTIONS, AND CAUSES SUBCAlfGORY 209(IO REVISION NUHUERI S PAGE 23 UF 26 CAUSES OF NFGATIVf flNOINGS a \\ Xr/lfNI ffFECIIVENESS DESIGN PROCESS EfffCllYENESS I 2 3 a S 6 I 8 9 10 '1 12 13 I I Q IN ICAL AOf UACY FINDING/ CDRRECTI'VF ACTION FtfH CLASS.a ~ CORRFCTIVf ACTION CAID ilnade-i ifngrg Design ifrag-i ) iProce-ilnade-i Docu-i Not nented H t ilra- / 0 ~ iyroce-)Fol-iwuni- (Res of/of Hgt/Design/quate iRecon-t ion tr dares l~ d cation issues Atten 8a es Calcs cll. Design Detail i<<anted/Inade-/Inadi-id>>res equate tUn- ) )Inade-i (quate i Lack Judgat crit/ )Organ-)quate (quate )Not tCos )tluely)Lack )quate itnade-tAs-btt) of not Comit Insuf. Verlf Sids Oocu-Not nenta-(Toi-t lon lo>>ed fngrg iVendor Error Error 6 igni fI-cance of Corrective ~ACTI 0 H H tn9.1 C3 Perforn corplete revle>> of Q.t 1st ~nd revise accordingly. NSN nl A P 03 Perforw revle>> of active Itens on the SQN CSSC review coavalttee agenda. SQN Al A P C3 Revle>> oalntenance and nodlflcatlon activities during use of redundant CSSC/Q-L 1st to verify that QA progran was adequately Irpleuented. C3 Delete redundant CSSC/Q-L 1st. IISN nl USN nt P P Conpare new 041st <<1th SF I.'ll CSSC list and FN Dfg CSSC List and resolve differences. SFN At P P 03 Coaplete devetopnent and Issue new rj-List, then discontinue the fN OFS and NUC PR CSSC List. F3 Close out open-action Itens. SLN Al
- SIN nl SFN A3 tn9.2 06 If the tng. I SQN Al corrective action discloses Inaccuracies or ontsitons ln the SQN CSSC List, the Itens <<II I be dispositioned In accordance <<Ith established CAQ procedures.
SQN Al P P IOIALS Defined In the Glossary Supp lenent, a ~ Defined In Table I. 76UID-R19 (12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL'ROGRAM. REPORT NUMBER: 26906 REVISION NUMBER: ~ 5 ~ Page 24 of 26 GLOSSARY SUPPLEMENT FOR THE'. ENGINEERING CATEGORY act>on are category zei as 1.ollows: 1. Fragmented o~rianization - Lines of 'authority, responsibility, and accountability were not clearly defined. 2. 3. Inadequate qualit~(g) trainin i-Personnel were not fully trained sn 'the prociedures esta >s e or desIlgn, process control and in the maintenance of design documents, includinq audits. Inadequate procedures - Oesign and imodif'ication control methods and procedures were de icient in est~ablishinq requirements and did not ensure an effective design control'prbgr am in some areas. 4. Procedures not, followesd - Existing Iprocedures controlling.the design process werie not7uT1y adhered to. i 5. Inadequate communicatiIons - Comm~unication, coordination, and cooperat~ion were not tuuTy effective in supplying needed information within p1lants, between plants and organizations (eng., Enqineeriinq, Con;struction, Licensing, and Operations), and between interorganizat,ional diIsciplines and deoartments. 0 6. Untime~lresolution of'ssues - Problems~ were not resolved in a tamely manner,, and tttexr reso'lution was not aqqressivelv oursued; 7. Laclk of management attention - Ther;e i~as, a, lai,-k of management attention -sn ensuring that pr()grams r!aquirE!d For an effective desiqn process were established and implemented. 8. Inadequate des,iqn bases - Oesign bases were lacking, vaqueu or >ncompMete ForM!~sign exiecution and verification and for design chanqe evaluation. 9. Inadequate calculations -. Oesiqn calculations were incomplete, used incorrect input or assumption!s,.or otlierwise Failed to fully demonstrate compliance with design requirements or support desiqn output documents,. 10. Inadequate as-built reconciliation - 'Reconciliation of dlesiqn and T>censrng riocuments wrttto ant as-built. condition was. lacking or incomplete. 11. Laclk of desicCn detail - Oetai'I in dlesian output documents was insufficient to ensure compliance with desiign requirements.. 26460-R24 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page 25 of 26 12. Failure to document en ineerin jud ments - Documentation justifying engsneersng judgments used sn the design process was lacking or incomplete. 13. Desi n criteria/commitments not met - Desiqn criteria or licensing commitments were not met. 14. Insufficient verification documentation - Documentation (Q) was snsu resent to au st the adequacy. o esign and installation. 15. Standards not followed - Code or industry standards and practices were not comp ied with. 16. En ineerin error - There were errors'r oversights in the assumptions, met odology, or judgments used in the design process. 17. Vendor error - Vendor design or supplied items were deficient for the intended purpose. Classification of Corrective Actions - corrective actions are classified as be ongoing to one or more o the o owing groups: 1. Hardware - physical plant chanqes 2. Procedure - changed or generated a procedure 3. Documentation - affected QA records 4. Traininq - required personnel education 5. Analysis - required design calculations, etc., to resolve 6. Evaluation - initial corrective action plan indicated a need to ~eva nate the issue before a definitive olan could be established. Therefore, all hardware, procedure, etc., changes are not yet known 7. Other - items not listed above Peripheral Findin Issue) - A negative finding that does not result directly rom an emp oyee concern but that was uncovered durinq the process of evaluating an employee concern. By definition, peripheral findiogs (issues) require corrective action. 2646D-R24 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROCiRAM REPORT NUMBER 20900 REVISION NUMBER.' Page 26 of 26 Si nificance-of'orrective Actions - The evaluatfion toam's judgment a< to the ssgns icance of the corrective actions listened in Table 3 is indicated'in'he last three columns of the table. Significance iS rated in acdordance with the type or types of changes that may be expdcthd to result from the corrective action. Changes are cIategorized as: o Oocumentat,ion change (O) - This is a change to any desiqn input or output document (e.g., drawirigg s5ecIification, calculation, or procedure) that dbes not result in a sionificant reduction in-desIign mar gin. o Change in design. margin (M) - This is a change in design interpretation (miinimum requirement's actual capability) thati results in a significant (ou'tside noIrmkl 'limiti~ of expected accuracy) change in the designimargiin.i All designs include~margins~ to a'liow-for error and unforeseealble events. Changes in dekigln margins are a normal and accept,ab'le part of the design and construction process as, long as the final design margins satisfy regulatory requirements and applicable codes and standards. o Change of hardware (M) - This is a physical change to an existing plant structure or component that resu'its from a change in the design basis, or that is required to correct an initially inadequate design or design error. If the change result:ing from the corrective action is judged to be significant, either an "A" f'r'ctual or "P'or po'tential is entered into the appropriate co'lumn of lable 3. Actual is distinguished from potentia'I because corrective actions are not complete and,'consequently, the scope of'equired changes may not be known. Corrective actions are judged to be significant if the resultant changes affect the overall quIalityJ performance,, or margin of' safety-related structure,
- system, or comnonent.
4l 26460-R24 ( 12/22/87)
~ I ~ TVA'MPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page A-1 of 3 ATTACHMENT A EMPLOYEE CONCERNS FOR SUBCATEGORY 20900 Attachment A lists,,by element, each employee concern evaluated in the subcategory. The concern's number is given, along with notation of any other subcategory with which the concern is shared and the plant sites to which it could be applicable. The concern is quoted as recei.ved by TVA, and is characterized by TVA as safety related (SR), safety siqnificant (SS), or not safety related (NO). 0107A-R61 ( 12/22/87)
ATTACINEHT A EMPLOYEE CONCERNS FOR SUBCATEGORY 20900 REYISIOH NUMBERf 5 PAGE A-2 OF 3 ELEMENT CONCERN RURRER PLANT Ellallls APPL ICABILITY BLH CONCERN DESCRIPTIOH* 209.1 IN-85-407-001 las or rAA 6 an-oo-ooo vugg IN-86-087-004 IN-86-0g0-00! NBN iiBii. Ilgw X X X CSSC Q-List ls not accurate. Hot all components covered by QA program are listed. QE Department has list that documents the inaccuracies. the CSSC Q-List Is used to deteraflne lf QC inspections are required. Cl has no further'nformation." (SS) Concern over validity of'Critical System, Structures and Components '0 i let inn flotsfla 1noUo ao IITI' a ll ..R ~ a.a. Rs ~ R s a is ~ ~ sv W ~ I ~ ssSSO I IS WllnnC IV lO ma IIILaIII I I conf Ident Ia l itys o (SR) Significant differences exist ln the content of the Nuclear Power 'Q'.ist and the Critical Structures, Systems and Components (CSSC), 'Q' lst. Many Items originally placed on the NUC power '0'ist are not reflected on the CSSC 'Q'ist, which could adversely affect estdbi lshflwEnt nf znnronrIsto oEss I fan ii t I aa ..I.l I. rr I I ~ ~ sJ s ssnss ss ~ s Mn ~ aosls wlllln ol o related to plant safety. Nuclear Power concern. No specifics prov ~ cd Cl has no IVIther information." (SS j "iiUC rwx iiio name/dept. given) Issued a Critical Structures, Systems and Components L'ist (CSSC) that does not include a? I items Identified on the site 'Q'ist (No specifics given). This was done without Office of ENG, ENG Design Group Input/approva) (The originator of the. site 'I)'ist). By referring to the
- CSSC, the possibility exists for
!Astz)jfng Non-Q'- items -lif'-a-Safety%elated System ~ CI has no additional information. NUC Power Concern." (SS) s ~ IN-86-095-002 NBN CI ls concerned that the recent use of the CSSC-!Q'ist rather than the 'Q T.fst Is not correct ~ due to differences ln content between the two documents.(IE Requirements, seismic-requ!rements!. This condition has been documented by an HCR, which has been determined to be reportable, and the NRC bass been fiotlfled HUC Power Dept. concern. Cl has no further. Information." (SR) SR/NO/SS lndlCateS Safety related, nat Safety relatell nl Safety Sinniffl'Snl psr sdOte mf IIO IS I ln al., R'CTG by TYA before evaluations. 27400-RB (12/22/87)
dNENT A EHPLOYEE CONCERNS FOR SUBCATEGORY 20900 CONCERN ELEMENT lllNBER 209.2 IN-85-407-001 IN-86-087-004 IN-86-090-001 PLANT LOCATION MBN NBN APPLICABILITY X X X CONCERN DESCRIPTIONS RE VI S ION HINBER: 5 PAGE A-3 OF 3 t "CSSC Q-List is not accurate. Hot all components covered by QA program are listed. QE Oepartment has list that documents the inaccuracies. The CSSC Q-List is used to determine if QC inspections are required. CI has no further information.'SS) "55gn5ficant d5fferences exist in the content of the Nuclear Power 'Q'ist and the Critical Structures, Systems and Components (CSSC) 'Q'ist. Nany items orlglnally placed on the NUC Power 'Q'ist are not reflected on the CSSC 'Q'ist, which could adversely affect establishment of approprfate quality controls on items which are related to plant safety. Nuclear Power concern. No specifics provided. CI has no further 5nformat5on." (SS) "NUC PNR (No name/dept. given) issued a Critical Structures, Systems and Components List (CSSC) that does not include a I 1 items identified on the site 'Q'ist (Ho specifics given). This was done without Office of EHG, ENG Design Group 5nput/approval (The originator of the site 'Q'ist). By referring to the
- CSSC, the possibility exists for installing 'Hon-Q'tems ln a Safety-Related
- System, Cl has no additional 5nformation.
KUC POMER concern.'SS) SR/NO/SS indicates safety related, not safety related, or safety significant per determination criteria in the ECTG Program manual and applied by TVA before evaluations. 27400-RB (12/22/87)
I - ~
TVA.EMPLOYEE CONCERNS SPECIAL PROGRAM .REPORT NUMBER: 20900 REVISION NUMBER: 5 Page B-1 of 11 ATTACHMENT B
SUMMARY
OF 'ISSUES,
- FINDINGS, AND CORRECTIVE 'ACTIONS, FOR SUBCATEGORY 20900 Attachment B -- contains a summary of the element-level'valuations.
Each issue is listed, by element, number and plant, along with its corresponding findings and corrective actions. The reader may trace a concern from Attachment A to an issue in Attachment 8 by using the element number. and applicable plant. Tne reader may relate a corrective action description in Attachment 8 to causes and significance in Table 3 by using the CATD number which appears in Attachment B in parentheses at the end of the corrective action description. 0107A-R61 ( 12/22/87)
Issues ATTACINENT 8 SUHNARY OF
- ISSUES, FINUINGS, AHD CORRECTIYE ACTIONS FOR SUBCATEGORY 20900 Findings REVISION NIIBER1 5
Page 8-2 of 11 Corrective Actions e { It ~ e AAAAAAAAAAAAAAAAAA Element 209.1 - Q-List Differences AAkAAA*AAA*AAAAAAA a. The documents !Q-Lists or equivalent) used on SQN to identify the appllc-AkllIAV r Eld -o- ~- 4 h ~ I I re vwi <<e<<h vie<<I vl<<4I 4 IIUL accurate and complete. SQ{I a. The SQN CSSC List is the "Q-List type document in use on SQN to Identify items that require QA program controls. Although a revie~ of the 5{IN CSSC List for accuracy and completeness has been codvditted to by TYA. such a review has not.been performed to date. The required biennial reVleW Of the CSSC LiSt IS PreaentIV SCherlulerl foe completion by June 1981. The activities of the SQN CSSC Revle~ Coalaittee are a pos It Ive I 4l tol towards md inta ining the SQN CSSC L fst as a 'living'ocument. 'However, the following shortcomings are evident fn the Review Coedafttee actions: o A TYA review of the SQN CSSC List for accuracy and rrvvovhleepev <<or I o ~ I
- e. <<o her +e<<o<<ee<<<<<<ee<<<<
lev<<v'cell 4l I veeep I IMIeu lo Vale ~ Therefore the baseline. to which the CSSC Review Committee is providing updates for plant modifications etcep Is of undetermined accuracy and completeness. o Ihe practice of deferring numer~classff fcatfon actions to the pending ONE Q-List development I onltrlbiiles to lb<<queo+4onabie status of SQN {55C List accuracy and completeness. N01E: One of the purposes of a recent HRC inspection at SQN was to evaluate the adequacy of the CSSC List. As noted In the TVA prepared minutes !Ref. 118) of the Inspection exit rdeeting on July 24,
- 1987, the HRC
'concluded that the SQH CS'SC List and-its utllfaatfon process appeared to be working and, for the short term, wveere adequ<<tc ~ ~ eoivcvcl I ft-was-recoiKiended by NRC that the Q-List for SQN be developed and Implemented ln an expeditious manner. SQN h 'vd a. The cor ct Ive act@@i codlafts that al I active f emswnothe SON SC Revfew Codlxfttegagneh) wQ~ /viewed to prior:to Peel're j'pu{Iejtev vill looloie tihose Ite<<q Nei<<a~ei~f{pseta aS deferra lS to 0 In addftfon)t the above.<ev ew actlone the correct lve gt n pIa{ffigiiailted by TYA provided addlt nal fnyotlrBtatikn renardfnvie ONE tovolveea{t~ ~tie"EuEIItevlev J'ustff fcatfon(th tq comp/))e fevfew of the GSC List is t {~r ~basal)c.ftrfdF to restart. The evaluatfon e m Qje e the ONE procedure rfor Q L ))e< I ve It to be adequate. ! CATO -209-0)- SQH Ol) IL4Mg e h <<I 4'
- 24) ID-R16 '(12/22/87)
issues AITAClkl SUNHAHY OF
- ISSUES, FIHOINOS, iU CORRI.CIIVf. ACIIOHS FOR SUUCAILOONY 20900 Findings REVISION HUNBER:
Page 8-3 of ll Corrective Actions Element 209. 1 - Q-List Uifferences - SQH c. Various Q-Lists (or equivalents) exist on SQN, which are different in content. d. The engineering design group does not provide input to the Q-Lists (or equivalents) on SQN. b.'he investigation indicated that only a single listing. the SQN CSSC List, was used on Sequoyah. The Engineering organization had developed a "trial use" SQH Q-List, but it was not implemented on the project.
- Thus, the problems associated with the existence of several Q-Lists having different content were not applicable to Sequoyah.
- Further, the IVA coavxitment in the NQNI to implement the forthcoming DNE-developed and maintained Q-List will adhere to the principle that a
single list prescribing QA program applicability will be in existence for SQN. Thus, at some future date, the SQN CSSC List will apparently be superseded by an SQH Q-Lists c.* The SQH CSSC List was initially developed and issued by . NUC PR, and Is presently the responsibility of the HSD through the Operations organization. The CSSC List is maintained by the SQH CSSC Revie~ Coxvalttee. Although direct ONE organization membership on the cosmlttee is not prescribed by the controlling procedure'(Al-39) (Ref. 5)). UNE has actively participated in CSSC Revie~ Cosmittee activities on an as-needed basis. The interface <<ith DNE tempers the employee concern related to the issue of lack of engineering design group input/approval of the CSSC List. and indicates a DNE de facto Involvement with the list. In the past, Q-Lists/CSSC Lists have been prepared and changed by various TVA organizations. Changes have been made at the corporate level to assign specific responsibilities with regard to these lists. As specified in HEP-S.I,, "Q-List," changes to Q-Lists shall be controlled by UNE through the ECH process. b. Hone required: c. Hone required. Finding "b" in SQN Element Report corresponds to issue "c herein. Finding "c" in SQN Element Report corresponds to Issue "d" herein. Issue "b" is found in SQN Element 209.2. 2411U-R I6 (12/22/87)
Issues ATTACIINENT 8 SMIARY OF
- ISSUES, FIHUINGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 20900 Findings REVISION HUNBER1 5
Page $-4 of I I Corrective Actions Element'09.1 - Q-List Differences - MBN NH MBH a. The CSSC Q-List is not accurate and comp)ete, and significant differences exist in the content of that list and the Q-List. a. TYA has identified and investigated problems assocfated <<ith the Q-List documents used on Watts Bar Nuclear Plant (MBH). The most significant of the analysis eechanises include Nuclear Safety Review Staff (NSRS) Investigation Report I-85-422-MBN (Ref.
- 58) and Nonconforming Condition Report (HCN) M-269-P, Rev.
I (Ref. 56). The Q-List problems were determined by IVA to be a signfficant deficiency and were reoorted tn the NRC under 10 CFR'50.55(e). The TYA reports documented that discrepancies existed; whfch Included omissions, inconsistencies, and fnaccuracies in the identification of safety-related items within the Q-lists. The CSS C Q-List was a specia I sort of the Q-List which wds ut 111zeh hv HUC PR fnr onerstInns masfntenance s d modification activities. The CSSC Q-List was intended as a replacement for ihe CSSC Lisi,which haa been deveioped by HUC PR and used since 1978. Although the CSSa..Q-List was issued and used by NUC PR, ft,was developed directly from the OE originated NN Q=Lfst. E~gineer fng was Involved <<ft+ Ch'ilUC PR-- interface in developing the selection criteria for the C558 Q-ust; Thusi tfie-CSSC Qf.fst was derived with OE (UNE) Input and fnvolveeent. a. To address Finding "a, which relates to the issue regarding deficiencies in Q-List(s) content, TVA w'ill Implement the corrective actions coaaaftted to the NRC (L44 860917 812) for Honconformlng Condition Report NGR M-269-P Rl The following corrective actions have been rnssslndnh Lu TVA rOI sl V UJ ~ In o The MoH Q-i.isi general noies and WBH Administrative Instruction Al-7.6 have been revised to clarify the safety classifications of components Ifsted fn the Q-List. o The MBN CSSC Q-List has been canceled ~ d ~ 'l d nl IllI'l~ Inn uj na=l ~ Ms nl ~.VlJ JllOOs o TYA has issued guidance for fdentiFying class )E motors, as an fnterfe measure to revising the MBN I)-List to unfqueiy ident!fy all eotors. o The Nuclear Quality Assurance Manual (HQAM) bus been revised to det ine limited QA programs used at WBH. o Tke MBH QLLst has keenrevised tn provide short-term resolutfon of conte. d-def fcfenc les ident ff'ed I NCR M-269-P, Rl. In addftfon to these actions already completed. TYA has coaniitted to complete the following beFore MBN unit I fuel load: o .Revision of the entire Q-List independently of the existing Q-List, in a coordinated, effort betweerl the desfgn, construction, and operatfons organizations to identify and correct errors, to ensure consistent teraifnology and deFinltlons, and to provide straightforward.and concise inforeatfon. tCATD 20o nl uAN n11 2411U-R16 ( 12/22/87) 0
issues AIFACIAL SUHHARY up
- ISSUES, flHUIHGS, AHU CONNECTIVE ACIIOHS NOR SUUCAIEGORY 20900 Findings REVISION NUHBER:
Page 8-5 of ll Corrective Actions Element 209. I - Q-List Differences - NBH b. The CSSC Q-List was issued without engineering design group input/ approval. c. The use of the CSSC Q-List could have adversely affected the establishment of appropriate quality control on items that are related to plant safety. By referring to the CSSC Q-List, the possibility exists for installing non-Q items in a safety-related system. b. There were three formally issued Q-List documents on HBH, suxvaarized as follows: o CSSC List - Ueveloped and issued in April 1978 by NUC PR for application of the Operational QA Program o Q-List - Ueveloped by the OE and issued in January 1984 after one year's trial use; intended as a controlled single list of the structures,
- systems, and components (SSC) covered by the TVA QA Program o
CSSC Q-List - A special sublisting of the Q-List, issued in November 1984. Intended to provide a more workable document than the Q-List for NUC PR use in operations. maintenance, and modiFication 'activities-and a replacement for the CSSC List. The CSSC Q-List was subsequently canceled. OE developed the CSSC Q-List from selection criteria that were established by NUC PR.
- However, an apparent lack oF coarsen definition and different program emphases between these offices led to incorrect selection criteria for the CSSC Q-List.
In spite of NUC PR's role in establishing selection criteria, there was active involvement between OE and NUC PR in the development and issue of the CSSC Q-List to the extent that the issue regarding lack of engineering design group input/approval of the CSSC Q-List is not considered valid. c. Use of the CSSC Q-List was limited both by timeframe and by organization and has been canceled. Therefore the scope of potential problems from use of the CSSC Q-List should be limited by the time of issue of Administrative instruction AI-7.6 (RO, January 8, 1985) (ReF, 53), which initiated the use of the CSSC Q-List, until AI-7.6 was revised (Rl, January 31, 1986) to delete the CSSC Q-List. In addition, the CSSa Q-List was used only by plant personnel (HUC PR) and not by the design or construction organizations. b. None required c. To address Finding "c, which relates to the effects of using deficient Q-List(s), TVA will implement the corrective actions coavaitted to the NRC (L44 8609ll 812) for Honconforming Condition Report HCR W-269-P, Rl. The TVA corrective action plan provides for the following actfons: o The revised Q-List, resulting from the complete review activity noted for Finding "a, will be compared to the old Q-List. The differences will be documented, tracked as open items, and transmitted for evaluation by the 2411D-R 16 ()2/22/87)
ATTACIOIEHT 8 SINHARY .OF
- ISSUES, FIHDIHGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 20900 REVISION NUHBERI 5
Page 8-6 of 11 Issues Findings Corrective Actions Element 209. I - Q-List Differences - UBN TVA's-10'CFR 50.55(e) report to the NRC on Q-List deficiencies costsitS tO review and establish a complete and accurate Q-List. TVA also cosefts to review maintenance and modification activities for the period from Ol/08/85 to 02/15/86 and to make necessary I'nrrort Ianc rocult fnn from tho roVIe Thea ~ ivl>> ~ are cosIIIitted to be complete prior to fuel load. The results of-the TVA revie~ of the Q-List for accuracy and completeness indicate that additional deficiencies exist ln the Q-List. Unlike the )Imitations-regarding historical,nco nf tho rSSr A I ict ~ tho A I tct. as prepared for'se by all organizations on NH. As such, tho INII>> t ~ r, i o rc i >> n ' ll>> ~>>yI I>>o>> IMno %l ~ llSIUV 0 UUI Ic Icllc it-List are mare encompassing than the potential for impact on only maintenance and modiiications activities. Of particular interest are the ramifications of Q-Liit deffcfencies on the Office. af Construction !OC) actlvltfes. Before the Q-List was fmp)ementef on MBN, 'tiIe OC.dcpendcii on the IdefItfffco't foil of safecy-related-features in the individual system documents and drawings originatedby DE. Hfth fmplementatfon of the Q-List. Construction Specification N3G-881 (Ref. 29) was revised to identify the Q-List as an additfonal source of identifying the SSC subieCt tn tho QA Program. H3r.-881 states that either source (f.e.. Q-Lfst or drawings) may ho ~lcoa r n Id ditto t I t tl CCI' -ai-- ~ o v v>> ~ O>> rden>>fry>>a>> ~ On Or one oS>>i dePend ~ UV On >>Iie needs of the user. Ihese factors indicate that deficiencies in the Q-i.ist could result in incomplete implementation of QA program requirements by Construction. The results of the corrective actions taken by TVA to aifdrosc iloflcfoncfoc In the-Q Ltet must be ascocsod tn determine the impact of identified deficiencies on a <<ide tonga Of QA program requfre@eritS fACiudfAg deSigA ~ procurement,.and construction activities, as approprIate. Division of Nuclear Construction (DHC), the Nuclear Site Director (NSD), and the Division of Nuclear Engineering (DNE) as appropriate, for potential impact on construction, maintenance. procurement, dcslgri, iind other actIvlttes. Conditions Adverse to Quality (CAQs) will be identified before MBN unit 1 fuel load, arid corrective actfons wfll be scheduled and completed by the resnnncihlo nrganfZatfnnc ac announce teton Pl lol to IPPH Illnit 1 iueI loa'd ~ IVA wl I I complete a review of maintenance and modification activitfes during the existence of the CSSC Q-List to verify that these activities were adequately fmplemented. (CATO 209 01 'NBH 02) 2411U-R16 I /22/87) 0 0
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Page 8-7 of II Corrective Actions Element 209. I - I)-List Oifferences - BFN a. The documents (I)-Lists or equivalent) used to identify the applicability of I)A program controls are not accurate and complete. a. BFN Browns Ferry either used, or is now using, several lists for the purpose of satisfying the intent of 10 CFR 50, Appendix 8, Criterion II, as follows: o The FSAR in Appendix 0 contained a CSSC I.ist between 1970 and 1978. o In that same period (1970 through 1978), the CH'AN contained a Critical Structures,
- Features, Systems and Equipment (CSFSE) list ~hich was used by TVA during construction of BFN units I, 2, and 3.
o From 04/78 through 07/85, Appendix A of the OMAH/NOAH contained a CSSC List which was derived from the FSAR CSSC List. In 05/81 the HSRS found the list deficient. As a result of the NSRS revie~, a CSSC Review Coavxlttee was formed in Chattanooga to be responsible for updating the list to reflect plant modifications. In 07/85, the list was deleted from the HI)AH and the responsibility for it was transferred to the site director. The site director did not create a specific CSSC Revie~ Coaeittee to continue the coavaittee review concept. o ln 03/78, the BFN plant superintendent issued Standard Practice BF l.Il, CSSC List (Ref. 39), which is being used by operations personnel to this day. This BF l. Il CSSC List was also derived from the FSAR CSSC List. It was not a continuation of the CSFSE List which was used during construction and no evidence was found that a comparison of the two lists was made and any differences reconciled. Periodic revie~ is required by the BF 1.11 procedure:
- however, no evidence was found that the reviews were for accuracy or completeness and that they incorporated plant modifications.
BFN a. A program is in process to develop and Implement a I)-List which <<ill provide more detailed coeponent level identification and specification and replace the present CSSC list. An experienced contractor and TVA are generating the initial phase of this 0-List in order to meet the Nuclear Regulatory Cooeission's (NRC) generic requirements related to equipment class iflcatlons. This list will use information derived from the Baseline Program, field walkdowns, and licensing coexltments and requirements related to equipment classifications. This initial issue (Phase I) of this list, for safety-related
- systems, is scheduled for late September 1987.
Evaluations of additional systems for which TVA has made coaraitments for application of I)A or limited gA programs (Phase ll) <<ill be completed 6 months following restart of each unit. Uuring the interim period between completion of Phase I and the completion of Phase ll, instructions for the use of the I)-List will direct the users to use the CSSC lists for guidance for items not appearing in the I)-LIst. Upon completion of Phase II in conjunction with an aggressive update and tracking scheme, an active and complete component I)-List <<ill have been developed. (CATO 209 01 BFN 01) o In 05/84 ONE issued a set of drawings titled "Eii OES CSSC List." There is evidence that this list caused some changes ln the BF 1. 11 CSSC List.
- However, no evidence was found that a complete comparison was made and any differences reconciled.
24110-R16 ( 12/22/87)
Issues ATTACHHENT 8 SUHMARY OF
- ISSUES, FIHUIHGS, AHU CORRECflVE ACTIONS FOR SUBCATEGORY 20900 Findings REVISION HUHBER:
5 Page 8-8 of ll Corrective Actions Eieient 209.1 - I)-LIst Differences - BFN b. The use of inadequate I)-LIsts (or equiv-tlttet1 tn )A kt l- ~.. t lisstt J avulse> Iltv'e oueel oc Iy affected the establishment of appro-priaie QA program controls on items that are related to plant safety. By reference to an Inadequate I)-List. the possibilltv exists that "non-0" items are Installed in a safety-related eueeotI J ~ c. Various 1)rLIsts (or equivalents) exist that are different in conieni. o In addition, the evaluation team found that GE Is preparing a I)-list which will be completed later this year (1987).
- b. Standard Practice OF 1. 11 is useJ by the operations organization for procurement, maintenance, and modifications.
Procedures for control of procurement, maintenance, and modification activities establish BF 1. 11 as the base reference for Identifyino safety-related '(CSSC) items or activities. An inaceurato nr Incomoloto RFH cSSI' let. Cou)d result in misclassification of an item or work activity as not being safety-related (CSSC)t resulting In the omission of 1)A program requirements.
- c. There Is more than one I)-List/CSSC List available and In use ai BFN.
o Standard Practice BF 1.11 Issued 03/78 is the primary CSSC List used by operatioas personnel for procurement, maintenance, and modification. The EN OrC reer I ate I oa nr.mg c t bet\\ tttl,v vtlv ~t t t'tt vs ~ ttueU Mlclllknut that could be used for the same activities. It was created with a draft procedure; however, It 1s noi clear who used It. b. If at any time during the preparation of the 11-LIst, discrepancies are discovered ~hich are Conditions Adverse to Quality, CAI)Rs will be Initiated and processed in aCcordanCe With NEP 4 1 LInon It euaneo of the I)-List at the completion of ~ siase ~ Ie o co>%liar Ison Is to made between l It-and the Huclear Power CSSC and the EN OES CSSC )isis noting'the discrepancies. CAI)Rs [to resolve needed hardware changes] will be Issued <<hen diaaoreementS between. the )IStS are a result of the I)-LIst classifying a ~ ANlltbtt t%4eu t1tetA kJtk st 'tv rvss'tilt tv ~ %tJ ~ 't ~ 01% U llo ~ %II tet previously'lassified non-safety related. Other discrepancies will be identified and evaluated via the PIR process. Dlspositfon of those Initiated CAqRs will be performed in accowdance with HEP-9.'I and wi)1 be tracked by the TROI system. (CATO 209 Ol BFN 02) c. The BF I. 11 and EN OES CSSC lists wi'll be dlscontfnued upon completion of the Phase Il 9;List, (Refer to Section 14.1 of BFNPP Volume 3 coanIItment). (CATO 209 01 BFN 03) o The revision history of Standard Practice BF I. 11 shows two revisions that were the result of a difforonce botwoen the EH OfS fSSC List and the BF l.Il CSSC List. This fInding Is the only evidence an the documentS ICV IOWed that the IWO )ISIS Were evel compared;
- however, the. evidence does not indicate whether or not.the comparison was compiete.
Issues ATTACIQIEt SUHHARY OF
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REVIS ION NDHBER. 5 Page 8-9 of 11 Corrective Actions Element=209. I - I)-List Differences - BFN d. The engineering design group does not provide input to the I)-Lists (or equivalents). BLN a. The documents (I)-Lists or equivalent) used to identify the applicability of 1)A program controls are not accurate and complete. d. The reference documents show no requirement for DNE participation in revie~ and/or approval of Standard Practice BF I. Il, CSSC List. This list did, however. originate from the FSAR and the revision record of BF I.ll describes some revisions resulting from engineering input. BLN a. BLN is now using a single I)-List to satisfy the intent of 10 CFR 50; Appendix 8, Crfterio'n II. In the past,
- however, several different lists were used to determine which plant items required'A program controls.
The lists were used as follows: o From the beginning of the project in 1972 to the
- present, BLN has used the plant design criteria documents to identify the safety-related structures.
- systems, and components.-
o The PSAR/FSAR contains a summary 1istlng of structures,
- systems, and components (07/73 to present).
o From 04/78 through 07/85, Appendix A of the OI)AH/NOAH contained a CSSC List that was derived from the PSAR CSSC List. In 07/85, the list was deleted from the H8AH, and thus was superseded by the BLN BLGI CSSC List. o BLN Standard Practice BLGI (Ref. 43) included a CSSC List and was issued in 1982. On ll/20/86, the CSSC List was replaced by the BLN 0-LIst. o The BLH 0-List was issued by system from 10/84 through 02/85, and it listed the items defined by the criteria documents. The BLN I)-List appears to be adequately controlled by engineering procedures. TVA memo from R. J. Nullin to Those Listed, CSSC List and CSSC Revie~ Coavalttee (Ref. IOB) [LI6 84123I 974) ( 12/31/84), transferred responsibility for the CSSC List to the BLN jobsite and included a list of open paperwork items to be resolved. d. Hone required: BLH a. A review of the open items in the memo from R. J. Hullin to Those Listed, dated December 31, 1984 (L16 841231 974) <<ill be performed. Discussion of resolution or proposed resolution will be documented. The revie~ <<ill be completed in time to implement any required changes to the 0-list as a result of the revie~ prior to fuel load of each unit. (CATO 209 01 BLN 01) 24I 10-RI6 ( 12/22/87).
issues ATTACttHEHT U SUMHARY Uf
- ISSUES, FIHUINGS, At(0 CORRECTIVE ACTIONS FOR SUBCATEGORY 20900 Findings REVISION NUHBER:
5 Page 8-10 of II Corrective Actions Element 209. I - Q-List Oifferences - BLN Tk o r u a o ~ s ~ Tile use ol lnodcquate Q Lrsts (or equiv alents) could have adversely affected the establishment of appro-priate QA program controls on Items that are related to plant saFety. By reference to an Inadonuato A-Ifst tho possibility exists that "non-Q" Items afe iriStalleu ln o sofety reloted system. I c. Various Q-Lists (or equivalents) exist that are different ln content. The engineer Ino design group does not provide Input to the Q-Lists (or e qu Ivo 1 en Is ) ~ Even though no evidence was found that the NQAH CSSC list open-items were resolved, the evaluator found-that the BLN Q-List appeared to be accurate and complete based on the thorough, formalized procedures which were subsequently used to prepare the Q-List. The procedures inc lorloil roulouo hu a\\ r o nrlooul a Areal 1 r si. ~ ~ o ~ ~ II v ~ ~ % I ~ ~ IV u ~ ol r ~ illoor llli construction organization through trial use.feedback, and r l ~ oui,yoouool i cV IeÃoo
- b. Because the BLtt Q-List, as noted in Finding a,
appears to be accurate and complete. the evaluator found no evidence of misclassified saFety-related items during fabr'Ication or installation
- c. For design and construction activities, the !1st!ng of safety-related structures.-
- systems, and components was provided from 19?2 to 10/84 by design criteria documents and diagrams.
ln IO/84, EN OES began Issuing. by system groups, the Q-Lrst which became the primary list of safety-related items but.supplemented by the design criteria documents and diagrams. All systems were Issued RO by 02/85. To cover /he ooorar ional act rvr tres 'T<A r u 8 Standard Practice BLGl ln 1982. BLGI contained a CSSC L4$t riihicii was maintained equivalent to the OQAH/NQAH. In 11/86, BLGl deleted the CSSC List and incorporated the BLIi Q=List, thereby making the BLN Q-List applicable to al'I project activities. The BLN QoL!St and the coAtrolliAg aAd suPPortlng procedures used for BLN that affect safety-related structures,
- SysLems, arid compoAenrts are all eAgrneer IA9 documents.
Thus, the issue relating to lack of engineering input to the Q-LIst is not true for BLH. b. Hone required. c. Hor,e required. do itoilc 'requr redo 24110-R16 (12/22/87) ~ 0
Issues ATTACI SUGARY OF
- ISSUES, FIHUIiiGS, AHU CORRECTIVE ACTIONS FOR SUBCATECORY 20900 Findings REVIS IOH NUHBER.
Page B-ll of ll Corrective Actions b.* The use of inadequate 0-Lists (or equi-valents) on SI)N could have adversely affected the establishment of appro-priate OA program controls on items that are related to plant safety. By reference to an inadequate I)-LIst, the possibility exists that "non-lP items are installed in a safety-related system. Si)M b. 'To date, the SON CSSC List has been used only by the Operations organization; the list was not used by Construction or Engineering on SOM. Therefore, the potential effects of using an inaccurate or incomplete Sl)N CSSC List are limited to Operations activities, which include procurement. maintenance, and modification. Si)H procedures that controi procurement, maintenance, and modification activities of the Operations organization establish the SI)N CSSC List as the base reference for identifying safety-related (CSSC) items or activities. Erroneous classification as non-CSSC could result In omission of essential requirements and activities. Ho specific deficiencies in the SOH CSSC List were identified in the review of the case file materials. NOTE: One of the purposes of a recent NRC inspection at Si)N was to evaluate the adequacy of the CSSC List. As noted In the TVA prepared minutes of the inspection exit meeting on July 24, 1987, the HRC concluded that the S)H CSSC List and its utilization process appeared to be working and, for the short term, were adequate.
- However, it was recoxvxended by NRC that the 0-LIst for Si)N be developed and implemented in an expeditious manner.
1 A1 4k 4 IlA 0 kt Ell4 k A e Element 209.2 - impact and Significance of II-Lists DifFerences 1 Ai1 4 A*i1 1 4 Aiai*** A y ~v'. $(A 'hag iyidV Ygor tive act ion plan (TQB-'0 )~Jh Tan ro des that if the corot Af.y)Son or uoy Element 209.1 disc'lok s '%brac(,'uracl gris ons in the SON CSSC is the 'q}).},be dispositio o Pjti kded. h dware changes) (pr> start 'Tf'<prop ate) ln accordance h e~stab1I>he procedures for co+I ons advert %oApa y. (CAID 209 02 S(jH 01 ~cS'BN (See 209.1) BFH (See 209. 1) BLH (See 209.1) HBH (See 209.1) BFH (See 209.1) BLN (See 209.1) HBN (See 209. 1) BFN (See 209.1) BLM (See 209.1) Issues a, c, and d are ln Element 209. l. 24110-R I 6 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page C-1 of 8 ATTACHMENT C REFERENCES 10 CFR 50, Appendix 8, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion II, "Quality Assur ance Program" 2. Regulatory Guide 1.29, Rev. 2, "Seismic Design Classification," (02/76) 3. Regulatory Guide 1.26, Rev. 2, "Quality Group Classifications and Standard for Water-Steam, and Radioactive Waste Containing Components of Nuclear Power Plants," (06/75) SQN FSAR, Section 3.2 (Amendment 3), "Classification of Structures, Systems and Components" SQN FSAR, Section 17 (Amendment 3), "Quality Assurance" 6. WBN FSAR, Section 3.2 (Amendment 55), "Classification of Structures, Systems and Components," .(04/15/85) 7. WBN FSAR, Section 17 (Amendment 55), "Quality Assurance," (04/15/85) 8. BFN UFSAR, Section 1.6.2 (Amendment 4), "Nuclear Systems and Engineered Safeguards" 9. BFN. UFSAR, Section 1.10 (Amendment 4), "Quality Assurance Program" 10. BFN UFSAR, Appendix A (Amendment 4), "Conformance to AEC Proposed General Design Criteria" ll. BFN FSAR, Appendix D, "Quality.Assurance Plan for Browns Ferry Nuclear Plant," ( all amendments as of 05/05/87) 12. BLN FSAR, Section 3.2, "Classification of Structures, Components, and Systems," Amendment 27, (06/20/86) 13. BLN FSAR, Section 17.0, "Quality Assurance," Amendment 27, (06/20/86) 14. TVA Topical Report, TVA-TR75-1A, "Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," Rev. 8, (04/09/85) 15. 2QPD-5, Rev. 1, All Nuclear Plants - The Identification and Specification of Items Covered By the OEDC Quality Assurance Program 3773D-R9 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page C-2 of 8 16. 17. 18.. 19. 20. 21. 22. 23. 24. TVA Corporate Nuclear Performance
- Plan, Volume 1, Rev.
4, (03/26/87) Watts Bar Nuclear Performance Plan (WBNPP), Volume 4, Draft Version, (03/13/87) Nuclear Quality Assurance Manual, Part V, Section 2.7 (IO-QAP-2.7), "Q-List," Rev. 0, (06/18/86) Nuclear Quality Assurance Manual, Appendix A, "CSSC Lists - All Plapts,," (07/29/85) Nuclear Quality Assurance Mahual, Part I, Section 1'.3, "Limited QA Program Requirements," Rev. 1, ( 12/12/86) WBN Administrative Instruction Al-7.6, Rev. O, "Q-List," (01/08/88) Construction Qual,i ty Assurance Manual, Rek. 2, '(01/23/74) Nuclear Quality As.surance Manual, Part I, Section 1.7, "CSSC List,": Rev. 0, (06/18/86) NEP-5. 1, Design Output, Attachment 6, "Q-List," Rev. 0, (07/01/86) 25. OEP-08, "Design Output," Attachment 6, "Q-List," Rev. 0, (04/26/85) 26. Mechanical Design Standard OS-M18.6. 1, "Idlentification of Mechanical Safety-Related Systems and CompOnentk," ReIv.','. (O9/,kl/81) 27. 28. 29. 30. 31. 32. Civil Design Standard OS-C1.2',.2,, "Classification cif Structures, Quality Levels of Struct,ural Materials, and AelIateId guality Assurance Responsibi'ilities of the Design Enqine,er," Rev. 0, ( 12/12/83) Constructibn Specification N2'G-877 (Initial issue thiI ouqh Rev. 5),', "Identification of Structures,
- Systems, and
('.omponents Covered by the Sequoyah Nuclear P'I ant Quality Assuranci Program" Construction,'Specification t43G-881, Rev,. 4, "Identification of StructuresSystems, ancl Components Covered t)y the, WBNP Qual'ity Assurance Proqram," (08/23/85) Construction Procedure P-24, Rev. 6, "Ihspection aind Test Status," (05/07/82) WBN Procedure WBEP-EP 43.15, "Preparaitibn ancl Maintenance of Watts Bar Q-List" (al,so reviewed Rl draft submitted with TTB-250), Rev. 0, .( 10/03/86) TVA Engineerinq Procedure EN OES-EP 1.28, "Control of Documents Affectinq Quality," R,ev,. 7, (07/23/84) 3773D-R9 ( 12/22'/87)
TVA EMPL'OYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page C-3 of 8 33. 34. 35. 36. 37. 38. 39, 40 41. 42. 43. 44. 45. TVA Engineering Procedure EN OES-EP 3.48, "QA List - Preparation and Handling," Rev. 1, (04/24/84) TVA Special Engineering Procedure EN OES-SEP 83-03, "Final Review and Issue of Structures,
- Systems, and Components List Covered by the Quality Assurance Program for Bellefonte Nuclear Plant," Rev.
1, [NEB 830802 851j, (08/15/84) Annunciator
Response
Procedure 9.5 with Form SOSP-1 and Form SOSP-16 (completed) Rev. 0, (03/18/87) Standard Practice
- SQA134, Rev.
8, Critical Structures, Systems and Components (CSSC) List, (01/27/86) SNP Standard Practice
- SQN2, Rev.
20, "Maintenance Management System," (09/11/86) SNP Standard Practice
- SQA45, Rev.
22, "Quality Control of Material and Parts and Service," (09/ll/86) BFN Standard Practice BF l. 11, Revision 0000, "CSSC and Non-CSSC Listing," (01/30/87) BFN Site Director Standard Practice, SOSP 2.7, Rev. 4, "Periodic Two-Year Review of Site Instructions," ( 12/04/86) BFN Site Director Standard
- Practice, SOSP 2.11, Rev.
4, "Review,
- Approval, and Change of Site-Generated Procedures/Instructions,"
(02/19/87) BFN Standard Practice BF 2.14, (superseded), "Review of Plant Instructions," (ll/30/84) BLN Standard Practice BLGl, "Q-List," Rev. 8, (04/03/87) Design Criteria WB-OC-40-36, Rev. 3, "Classification of Pioing,
- Pumps, Valves and Vesse'ls,"
( 11/19/85) Design Criteria WB-OC-40-36.1, Rev. 1, "The Classification of Heatino, Ventilating and Air-Conditioning Systems," (1 1/15/83) 46. Design Criteria BFN-50-739 (Draft A), "Classification of Structures,
- Systems, and Components,"
BFNP-2 47. 48. BLN Design Criteria N4-50-0744, "Identification of Mechanical Safety-Related Systems and Components," Rev. 1,,(09/17/84) BLN Design Criteria N4-50-0754, "Classification of Pipinq,
- Pumps, Valves, and Vessels,"
Rev. 1, (09/17/84) 37730-R9 ( 12/22/87)
T'VA EMPLOYEE: CONCERNS SPECIAL PROGRAM REPORT INUMBER: 20900 REVISION NUMBER: 5 Page C-4 of 8 49. BLN Design Criteria,N4-NJ-0740, Rev. 2, "Secbndary Containment Isolation System," (04/08/86) 50. BLN Desiqn Critei ia N4-VL-0740, Rev. 0, "Control Bui ldinq-. Non-ESF Areas HVAC " (09/23/75) 51. SQN Administrative Inst~ruction AI-39,, Rev., 2, "Criticall Structures, Systems and Component,s - (CSSC)," (01/09/86) 52. SQN Administrative Instruction AI-'19.,', P'art III,'ev.', "Plant Modifications: Modification Request)" (06/03/86),, and Part IV Rev. 18, "Plant Modifications: After Licensing," (07/07/86) '3. 'BN Administrative Instruction Al-'7.6, Re>i. l, '"Q'-Li'st," (01/31/816) 54. Quality Control Instruction QCI-1.40 Rev. 7, '"Rector'ds Accountability Program," (09/04/85) 55. WBN NCR W-269-P, (08/26/85) 56. NCR W-269-P, Rev. 1 ( 10/04/85) 57. SQN Generic Concern Task Force Report, GOR16-16, Rev. 1, for Employe'e Concern Number IN-85-688-003, (06/02/86) 58. NSRS Investigation.Report I-85-.422-WBN, ( 10/04/85) 59. Corrective Actiain Report WB-CAR-85-48, (08/20/85) 60. BFEP-PI-86-(Draft),, "Critical Structures,
- Systems, and Components'(C'SSC)"'1.
Quality Assurance I ist (Q-List) OGP0025-00-Series, ".Q-List:Genera'I Notes," Rev. 0, ( 10/30/84) 62. Minutes of SQIN CSSC Meeting 85-02., Meeting 85-03., Meeting 85-04 Meeting 86-01,, Meeting 86-02 Meeting 86-03 Review Caimmittee Meetings: [S53 8507'30 825], (06/26/85) [S5:) 851101 980], (09'/10/85) [S53 8'51203 903], ( 1'1/14/85) [S53 8602'19 840],'01/14/86) [S53 860423 814], '(04/15/86) [S53 860514 940], (04/24/86) 63. TVA memo from T. G Campbell to W. E. Ahdrews, [L53840807942]; "SQN-CSSC List," (08/09/84) 0 64. TVA memo from J. E., Law to Those Listed< "Q-List Specification," [iL16 851003 854]. (10/03/85) 65. TVA memo, L,aw to Cantrell, CSSC List, [L16'850206, 842], (02/06/85) ll 3773D-R9 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page C-5 of 8 66. 67. 68. 69. 70. 71. 72. 73. 74. 75. 76. 77. 78. 79. 80. 81. Letter from R. Gridley (TVA) to J. N. Grace (NRC), "Response to Inspection Report 50-327/86-11 and 50-328/86-11,".[L44 860627 800], (06/27/86) Letter from Gridley (TVA), to Grace (NRC), "WBN Units 1 and 2 - g-List Conformance to NIZAM Requirements - WBRD-50-390/85-86, WBRD-50-391/85 Final Report," [L44 860303 815], (03/03/86) Letter from R. Gridley to J. N. Grace (NRC)., "Revised Final 10 CFR 50.55(e) Report on,NCR W-269-P Rl," [L44 860917 812], (09/17/86) Letter from Thompson (NRC) to Parris (TVA), "Concerns Regarding TVA Construction Sites," [L44 850528 290], (05/16/85) Letter from Huffman (TVA). to Thompson (NRC), "Response'o Concerns Regarding TVA Construction Sites," [L44 850605 803], (06/15/85) Letter from Huffman (TVA) to Grace (NRC), "WBNP-g-List Conformance to NQAM Requirements - WBRD-50-390/85-56, WBRD-50-391/85 Interim Report," [L44 851209 803], ( 12/09/85) Letter from Mills (TVA) to Adensam (NRC), "TVA Docket No. 50-327 E 50-328, TVA Response to Items 2.1 and 2.2 of NRC Generic Letter 83-28," [A27831107026]% ( 11/07/83) Letter from Mills (TVA)to Denton (NRC), "Response to Generic Letter 83-28," [LOO 831110 701], (11/07/83) Letter from Mills (TVA) to Denton (NRC), "Supplemental
Response
to Generic Letter 83-28," [ROO 840920 734], (09/17/84) Letter from Domer (TVA) to Thompson (NRC), "Supplemental Resoonse to Generic Letter 83-28," [ROO 850604 556], (06/03/85) Letter from Adensam (NRC) to Parris, "Request for Additional Information re Generic L'etter 85-23," [L44 850408 697], (04/02/85) Letter from Vassallo (NRC) to Parris, "Request for Additional Information re Generic Letter 85-23," [L44 850430 678], (04/23/85) Letter from D. S. Kammer (TVA) to E. G. Adensam (NRC), "Response to Generic Letter 83-28," [no RIMS number], (06/26/84) Letter from Adensam (NRC) to Parris, "Request for Additional Information re Generic Letter 85-23," [A02 850328 008], (03/22/85) c. TVA memo from Parker to Mills, "Supplemental
Response
to Generic Letter 83-28, (06/21/84) TVA memo from Hufham to Coffey, "Review of Response to Generic Letter 83-28," (L44 850514 800], (05/14/85) 3773D-R9 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGIRANI \\ REPORT NUMBER:','2090CI REVISION NUMBER: 5 Page C-6 of 8 82. 83. 84. 85. 86. 87. 88. 89. 90. 91. 92. 93. 94. 95. Letter from McNutt to Parkinson, "Employee Concern Eva'iuation Program Sequoyah Restart Program - Corrective Action, P'ian (CAP)," (12/08/86) (TCAB-021 ancl TCAB-022) Letter from L. N. Arms (TVA) to American Nuclear Insurers, "SQN-ANI/MAELU Nuclear Liability Insurance - Sept. 10-13, 1984 Inspection-- Recommendations 84-2,, 84-3, andi 84-4," t.L01 841221 158], .( 12/19/84) Letter from 'I. A. Olshinski (NRC), to Sc As White,(TVA), "Report Nos. 50-327/86-11 and 50-328/86-11," LL44 860429'73], (04/22/86) Specification Review Notice SRN-N4G-889-,01, [NED 830325 259 j, (03/25/83) Nuclear Safety Review. Staff Report, R-84-32-NPS, (Ol/16/85) TVA memo from K. W. Whitt 'to H. G,. Parris', "NSRS Investigation Report I-85-422-WBN" tno RIMS number), (10/11/85), (TTB-18) TVA memo from K. M. Whitt to E. R. Ennis,'Correctiye Action Responise 'valuation (I-85-422-MBN, Item 2)," Lno RIMS number], (01/08/86), (TTB-18) TVA memo from K. M. Whitt to E. R. Ennis,'Corrective Action ResOonise Evaluation (I-85-422-MBN, Items 1, 3, 4)," (no RIMS number],, (01/08/86), 'TTB-18) TVA memo from Howard to Enni's, "Employee Concern Investigation Report Transmittal 'Response," Lno RIMS number), (12/06/85) (TTB-18) TVA memo from Howard to Ennis, "WBNP - Quality Evaluation Reoort QE-85-09 CSSC Q-List," LL04 850826 950], (08/26/85). TVA memo from J. A.. IRaulston to R'., Gridley, "Final '10 CFR 50.55(e),Report on NCR W-269-P Rl" t.B45'60306 260], (03/06/86) TVA memo, Cottle to. Howard, "MBNP-ECIR I-85-422-WBN" [no RIMS number], ( 01/16/86), TVA memo, "OEDC-QPM-3-73, Rev. 1 (06/20/72)" (TTB 326) (04/08/87) TVA memo from Ennis to Wadewitz, "MBNP - Nonconforming Condition Report (NCR)'-269-P,'" t L04 850827 950], (08/27/85), 96. 97. 98. TVA memo, from Heatherly tio Nuc'lear Q-List - NCR W-269-P," [B45 851122 TVA memo from Wilson to Standifer and Corrective Action Report (CAR) ( 11/29/85) TVA memo from Wilson to Standifer, t.T15 851224 968'] '(12/24/85) Engineering Branrh Files,. "WBt)- 257], (11/22/85) '"MBN - Q List - NCR W-269-P, Rev'. MB-CAR-85-4~5,'~ P15 851129 '949], '"WBN ~ Q List - NCR W-269-P, Rev. 1,"I 3773D"R9 ( 12/22/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 20900 REVISION NUMBER: 5 Page C-7 of 8 99. 100. 101. 102. 103. 104. 105. 106. 107. 108. 109. 110. 112. TVA memo from Heatherly to Nuclear Engineering Branch Files, "WBN-Resolution of NCR W-269-P - WBEP Action Item Coordination Meeting," [B45 860109 262], (01/09/86) TVA memo from Heatherly to Nuclear Engineering Branch Files, "WBN-Resolution of NCR W-269-P - Omission of Class 0 Piping in System 63-Safety Injection System," [B45 860109 265], (Ol/30/86) TVA memo from Standifer to Wadewitz, "WBN - NCR W-269-P, Rev. 1," [B45 860205 254], (02/05/86) TVA memo from Standifer to Wilson, "WBN - Q-List - NCR W-269-P, Rev. 1," [B45 860205 256], (02/05/86) TVA memo from Standifer to Wilson, "WBN - Resolution of NCR W-269-P-Preparation of Limited QA Matrix,'" [B45 860210 262], (02/10/86) TVA memo from Standifer to Wilson, "WBN - Resolution of NCR W-269-P-Non-CSSC Equipment and Rewrite of General Note," [B45 860225 257], (02/25/86) TVA memo from Heatherly to Nuclear Engineering Branch Files, "WBN-Resolution of NCR W-269-P - Review of Class IE Equipment Powered Flow Control Valves (FCVs)," [B45 860304 256], (03/04/86) TVA memo from Heatherly to Nuclear Engineering Branch Files, "WBN Q-List," [B45 860602 251], (06/02/86) TVA memo from Heatherly to Nuclear Engineering Branch Files, "WBN-Resolution of NCR W-269-P Results of Complete System Review," [845 860509 261], (05/09/86) TVA memo, Mullen to Abercrombie, Cottle, Coffey, and Quails, "CSSC and CSSC Review Committee," [L16 841231 974], (12/31/84) TVA memo from H. N. Culver to H. G. Parris, "NSRS Report R-81-08-BFN," [GN5 810515 001], (05/15/81) TVA memo from Fortenberry to McNutt, "SQN - Enqineerinq Related Employee Concerns - Subcategory/Element 209. 1(B) and 209.2(B)," [no RIMS number], ( 10/06/86) TVA memo from Abercrombie and Brown, "SQN - ECTG Element Report 209.01 SQN - Engineering Category - Corrective Action Plan (CAP)," [S03 861205 808], ('12/05/86) TVA memo from Abercrombie to Brown, "SQN-ECTG Element Report 209.2.SQN-Engineering Category - Corrective Action Plan (CAP)," [S03 861205 807], (12/05/86) 3773D-R9 ( 12/22/87)
I VA EMPLOYEE CONCERNS SPECIAI. PROGRAM REPORT NUMBER: 20900 Rl.:VISION NUMBERS: 'age C-8 of 8 113. TVA memo f'rom Fortenberry to C'lift, i "SQN i-Employee Concern - Element 209 1 - CSSC List,," [no RIMS number],(12/18/86) 114. TVA memo f:rom Fortenberry to McNutt~ "SQN - Employee Concern Evalua'tion" Report - SQN Element Report 209.1(B)," tS53 870106 942], (01/05/87) 115. TVA 6436, Maintenance Request Form (ONP-2-84) (OP-BFN-6-86) 116 Meeting 03/26/86, Knoxville, Tenn. - Anderson 8 Aronson (Bechtel) w'ith Clift and Bianco (TVA) BILT-006,(04/08/86) 117. Trip report, Visit to BFN plant, Jatt;k Gott, IOM-963', (04/17/87) 118; TVA memo from M. R. Harding to R. La Gridley "iSequoyah Nuclear Plant (SQN) - NRC Procurement Inspection,'Exit Meeting of July 24, 1987,," tS10 870810 804] (08/10/87) 119. TVA memo from Nl. C. Kazanas,to H. La Abercrombie and J. A. Kirkebo, "Sequoyah Nuclear Plant Q-List," t.L20 870930 840], '(09/30/87) 120. Letter from J. G. Keppler, NIRC., to S. A. Wh'ite, TVA, "Items Identif~ied-by the Integrated Design Inspection Requiring Resolution Prior to Restart of Sequoyah Unit 2," t A02 871013 001], '(10/09/87) 121. Letter from R. I.. Grid'ley, TVA, 'to U.S. NRC,, "Sequoyah Nuclear Plant (SQN) - Q-List Program Development Status," t.L44 870828 808], (08/28/87) 122. BLN Quality Assurance.List (Q-List),ev.',' 10/30/84) 123. Nuclear Quality Assurance Manual, Part V, Section
- 2. 7
( IO-QAP-2. 7), "Q-List," Rev. 12/31/84 ,124. Nuclear Quality Assurance Manual, Part V, Section
- 2. 7
( ID-QAP-2. 7), "Q-List," Rev. 03/10/86 125. TCAB-021, 209 02,'SQN O'I, ( 12/08/86) 126. TCAB-022, 209 01,'SQN O'I; ( 12/08/86)i 127. TCAB-249, 209 01 lrlBN O'I, (03/11/87)i 128. TCAB-250, 209 01 MBN 02, (03/ll/87)'~ 129. TCAB-482, 209 Ol BFN 0;I, 02, 03, (08/30/87)i 130. TCAB-608, 209 01 BLN O'I, (07/21/87)i 0 37730<<R9 ( 12/22/87)}}