ML18033A559
| ML18033A559 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/05/1987 |
| From: | Damon D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 21000, 21000-V02-R03, 21000-V2-R3, NUDOCS 8902150064 | |
| Download: ML18033A559 (58) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG VOLMrKE2 ENGINEERING CATEGORY SUBCATEGORY REPORT 21000 ENVIROMLENTALQUALIFICATION UPDATED TVA NUCLEAR POWER
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:
SUBCATEGORY REPORT FOR ENGINEERING TITLE:
ENVIRONMENTAL QUALIFICATION REPORT NUMBER: 21000 REVISION NUMBER:
3 Page 1 of 25 2.
3.
ASON FOR REVISION:
I Revised to incorporate SRP and TAS coments.
Revised to incorporate SRP coments on their concurrences.
Revised to incorporate additional TAS comments; added Attachment C
(References).
PR ARA ION REVIEWS TS'(~
8 N
N SIGNATURE DA CEG-H:
SRP.
~
cu SIGNAT
~zd~S DATE APPROVED 8 CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page ES-1 of 1
EXECUTIVE
SUMMARY
This subcategory report details evaluations and draws conclusions for concerns raised under Engineering Subcategory 21000, Environmental gualification, in the Employee Concerns Special Program.
The evaluations covered five issues related to TVA's four nuclear plants:
- Sequoyah, Watts Bar, Browns Ferry, and Bellefonte.
The issues were derived from a total of eight employee concerns that cited presumed deficiencies or inadequacies in the TVA environmental qualification program.
One issue relates to the location of sensitive instrumentation in a harsh environment and was investigated at both Sequoyah and Watts Bar.
The evaluation determined that the condition was known and that the equipmhnt in this=area was qualified for the environment in question.
No corrective action was required'.
The remaining four issues relate to the adequacy of the environmental qualification program.
These issues are generic to all four nuclear plants, and their evaluation resulted in essentially the same findings and corrective actions for each plant.,
The evaluation found that the issues were valid but that'he problems had been independently identified by TVA management reviews and that significant corrective action was in progress at each plant except Bellefonte.
The environmental qualification program at Bellefonte is on hold pending rescheduling of construction and engineering activities.
TVA management's review of the environmental qualification program determined that existing procedures did not provide the level of documentation or detail required for compliance with 10 CFR 50.49.
The root causes for the failure to comply were identified by TVA as a fragmented organization and a lack of management attention.
While these problems existed in the TVA environmental qualification program at the time the employee concerns were'filed, the proqram has since undergone a major overhaul.
The corrective actions taken to upgrade the environmental 'qualification program at each plant to comply with 10 CFR 50.49 are broad and comprehensive.
The upgrade program includes the preparation and revision of numerous procedures, preparation of a new 10 CFR 50.49 equipment list, and preparation of new environmental qualification packages (binders) for 10 CFR 50.49 equipment.
The program at Sequoyah is the most advanced and is the model for the other plants.
Full implementation of the upgraded
- program, as outlined in the nuclear performance plans for all plants, should be sufficient to resolve the issues and concerns raised.
This grouped evaluation at the subcategory level did not find any new or broader issues requiring attention.
The causes identified and other evaluation results are being examined from a wider perspective during the Engineering category evaluation.
2632D-R13 (10/07/87)
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- Preface, Glossary, and List of Acronyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUNBER PAGES REVISED REASON FOR CURRENT REVISION
'3 To clarify that one or more attachments will help the reader find where a particular concern is evaluated
I i
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TVh ENPLOYEE CONCERNS SPECIAL PROGBLN REPORT NUMBER:
21000 FRONT NETTER REV:
3 PdGE i OF viii Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley huthority (TVA).
The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVk.'s Nanager 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 5BDD employee concerns.
Each of the 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.
dn 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 ZCTG 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 eztent to which problems overlap more than one element and'ill 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 nuclear 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.
TV'NPLIOTEE CONCERNS SPECIAL, PROGRAM REPORT RAtBER:
21000 FRONT maZER aZV:
PhGE ii OF viii emselves reports.
Each category report reviews the major findings and col'lective significance of 'the subcategory.reports in one of'he following areas:
management and personnel relet~ion's industrial safety construction material control operations quality assurance/quality contxol welding engineering h separate report on employee coerce>.-ns'ealing with specific content'iona of intimidation, harassment, and wrdngdoidg will be 'released by the '1'ffice of the Inspector General.
Just as the subcax,egory reports integrate the information collected at th~.
element level, the category reports integrate the information assembled il~:
all the :ubcategory reports withi'n the'a'tegory, addressing partirular)y the under lying causes of those problems that run across more titan one subcategory.
h final report will integrate 'and assess the, information collected by all of *the lower level reports pxepared for the
- ECSP, includiing the Inspector General's report.
For more detail on the methods by which ECTG employee concerns weHe evalua'ted and reported, consult the Tennessee Valley'uthority Employee Concerns Task Group Program Nanual.
The Manual spells oux. the pxogram's objectives,
- scope, organisation,
'and resp'onsibilities; It, alsd sgec~ifi'es the procedures that were followed i6 the 'investigation reporting, ahd closeout of the issues raised by 'employee concerns.
4I
~~
~ ~
TVh EHPLOTEE CONCERNS SPECTRAL.PROGRhN REPORT NUMBER:
21OOO FRONT KLTTER REV:
2 PhGE iii OF viii ECSP GLOSSARY OF REPORT TERMS~
classification of evaluated issues the evaluation of an issue leads to one oi the following determinations:
Class A:
Issue cannot be verified as factual Class B:
Essue 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:
h 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 fiz 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 f'ormal, written description of a circumstance or circumstances that an employee thinks unsafe, un]ust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-!orm.
TVd ENPLOXEE CONCERNS SPECLbL PROGRJlN REPORT NUK)ER:
21OOP FRONT KLTTER 'REV:
2 PAGE iv OF viii evaluator(s) the individual(s) assigned the responsibility to assess'
'specific grouping of employee concerns.
~findin s includea both st:atements of fact and tha judtments made about those facts during the evaluation process; negative,finds.ngs require corrective action.
issue a potential problem,, as interpreted by the ECTG during the evaluation
- process, raised in one or more concernsa K-form (see memployee concern")
~re uirameat a standard of performante.
bdhatiobb or quality.on uhioh an evaluation judgment 'or decision'ma'y be based.
root cause the underlying reason for a problem.
~Terms essen'Cial to the program but which require detailed definition'ave'been defined in the ECTG Procedure
'tlanual (le.g'.,'generic, specific, nutle'ar
'afety-related, unreviewed safety-significaht que'sti'on).
4l s H I
s As 1~~ e err secern~me
TVh EMPLOYEE CONCERNS SPECIhL PROGRhM REPORT NtJMBER:
21000 FRONT MhTTER REV:
2 PhGE v OF viii hcronyms hI hdministrative Instruction hISC hmerican Institute of Steel Construction hLhRh hs Low hs. Reasonably hchievable hNS hmerican Nuclear Society hNSI hmerican National Standards Institute hSME hmerican Society of Mechanical Engineers hSTM hmerican Society for Testing and Materials hWS hmerican Welding Society BFN Browns Ferry Nuclear Plant BLN Bellefonte Nuclear Plant ChQ Condition hdverse to Quality ChR Corrective hction Report ChTD Corrective hction Tracking Document CCTS Corporate Commitment Tracking, System CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual.
CMTR Certified-Material Test Report COC Certificate of Conformance/Compliance DCR DNC Design Change Request Division of Nuclear Construction (see also NU CON)
TVA EBPPTAYEE CONCERNS SPE!CIA PRGGEULN REPORT NUMBER 21600 FRONT MATTE!R REV:
2 PAGE vi OP vi.ii DNE DNQA DNT DPO Division of Nuclear Engineering Division of Nuclear Quality Assurance Division of'uclear Training Department of'nergy Division Personnel Officer DR ECN ECP ECP-SR ECSP ECTG
'EEOC EQ EMRT EN DES FCR PSAR HCT Discrepancy Report or Deviation Report.
Engineering Change Not;ice Employee Concerns Program Employee Concerns Program-S~ite Representative Employee Concerns Special Program Employee Concerns Task Group Equal Employment Opportunity Commission Environmental Qualif'icat.lion lEmergency Medical Response Team lEngineer:i,ng Design Employee
Response
Team or Emergency
Response
Te'am Field Change Request I?inal Safety Analysis Report Fiscal, Year General P~ployee Training Haiard Control Instruction 0
HVhC Heating Ventilating, hit Conditioning Xnstallat;ion Instruction INFO IRN I:nstitute of Nucl.ear Power Operat;iona Inspection Rejection Not3.ce
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 FRONT MATTER REV:
2 PA6E vii OF viii L/R MALI Labor Relations Staff Modifications and Additions Instruction MI
'aintenance Instruction MSPB Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Ezamination NPP NPS NQAM NRC NSRS NU CON NVKARC OSHA ONP OMCP Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Manual Nuclear Regulatory Commission Nuclear Services Branch Nuclear Safety Review Staff Division of Nuclear Construction (obsolete abbreviation, see DNC)
Nuclear Utility Management and Resources Committee Occupational Safety and Health Administration (or Act)
Office of Nuclear Poorer Office of 'Qorkers Compensation Program PHR PT QAP QCI Personal History Record Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures Quality Control Quality Control Instruction
TVh ElPLOTEE CONCERNS SPECIhL PROGRhH REPOFT NUMBER 2l0Pp FRONT.KLTTER REV:
2
)
PhGE viii OF viii QCP QTC RIF RT SQN SI SOP SMEC ThS T6L TVTLC UT VBECS P VBN Quality Control'rocedure Quality Technology Company Reduction in Force Radiographic Testing Sequoyab Nuclear Plant Surveillance Instruction Standard Operating Procedure Senior, Review Panel Stone and 1febster. Engineering Corporation Techn;ical hssistance Stai'f Trades and Labor Tennessee Valley huthority Tennessee Valley Trades and Labor Council Ultrasonic Testing Visual Testing watts Bar Employee Co&cern 'Spe'cial Program 1'watts Bar Nuclear Plan,t 0
1Jork Request or Mork Rules
'lkorkplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 2 of 25 Section Executi ve Summary Preface ECSP Glossary of Report Terms Acronyms CONTENTS
~Pa e
ES-1 1
Introduction 2
Summary of Issues/Generic Applicability 3
Evaluation Process 4
Findings 5
Corrective Actions 6
Causes 7
Collective Significance Glossary Supplement for the Engineering Category Attachments A
Employee Concerns for Subcategory 21000 8
Summary of Issues,
- Findings, and Corrective Actions for Subcategory 21000 '
References TABLES Table 1
Classification of Findings and Corrective Actions 2
Findings Summary 3
Matrix of Elements, Corrective Actions, and Causes 5
16 17 18 23 A-1 C-1
~Pa e
20 21 22 2632D-R13 (10/07/87)
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TVA EMPLOYEE CONCERNS
. SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 3 of 25 1.
INTRODUCTION This subcategory report details evaluations and draws conclusions for concerns raised under Engineering Subcategory
- 21000, Environmental Qualification.
r The employee concerns, are listed by element number in Attachment A.
The plant location where the concern was originally identified and the applicability of the concern to the other TVA plants are also identified.
The top-level requirements for environmental qualification (EQ) are set forth in 10 CFR 50.49.
This regulation requires that all plant equipment that is important to safety and is located in a harsh environment be qualified for that environment.
Furthermore, documentation demonstrating equipment qualification must be maintained in an auditable file.
The evaluations are discussed 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 determiniation of generic applicability o
Section 3 outlines the process followed for the subcategory evaluation o
Section 4 details evaluations of the issues by element and presents ihe findings o
Section. 5 highlights the corrective actions required for resolution of the negative findings cited in Section 4 and relates them to element and to 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, alonq with notation of any other element or category with which the concern is shared; the plant sites to which it could be applicable are noted; and the concern is quoted as received by TVA, and is characterized as safety related, not safety related,. or safety significant o
Attachment 8 contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and corrective actions.
The 2632D-R13 (10/07/87)
TVA EMPLOYEE.
CONC'ERN,'S SPECIAL PROGRAM REPORT NUMBER."
'1'000
'REUISION NUMBFR: 3 Page 4 of 25 reader inay trace a concern from, Attachment, A,to an issue in Attachment B by using-'the element nu~iber and applicable plant.
The reader may relate a corrective action description in Attachment,B to causes and significance in Table 3 by using the CA'TD number which appears in Attachment B in parenth~eses at the end of the corrective action description o
Attachment C list.; the references, cited, in the text 2.
SUMMARY
OF. ISSUES/GENERIC 'APPLICABILITY The eight employee concerns listed'n Attachment A (by element) were filed between November 1985 and.January 1986
'These eight concerns have baleen examined andi the ipotential negative findings raisied by them have been
~
identified as issues,.
Only five separate, issues were identified in this subcategory.
An NRC interview of a concerned individual, conducted on
'ebruary 21,
- 1986, also explored these issues.
This inter,.view added certain details to the more broadly stated concerns.
These details, however~ did not alter the basic issues to be evaluated and, in and of themselves, did not~
initiate additional corrective actionsl All concerns discuss,ed herein apply. to the EQ program in effect before the shutdown of SOlli.
The five issues evaluated under this subcategory are stated fully, in Attachment B, which also 1'ists the cori.espoqdirig findirigs and corrective actions that are discussed in Sections 4
andi 5 of thiis report.
The issues, grouped by element, are summarized below.
- 2. 1 Sensitive Instruments/Harsh Environment - Element 210.
1 0
This issue states that certain sensitive instruments and equipment are located in a harsh environment near the bottom of the reactor vessel.
The issue was identified at Watts Bar but was investligated at both Watts Bar and Sequoyah because the Reactor Building arrangements are nearly the same.
The i'ssue was not specifically addressed at Browns Ferry and,Bellefonte because their reactor systems and building arrangements have littl'e in common with Watt.;
Bar.
However, the specific subject matter of this concern is really encapsulated in the more broadly, expressed concerns of element 210.2 and is thereby addressed bv inference for Browns Ferry and Be'llefonte as well.
26320-R13 (10/Oi'/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER:
3 Page 5 of 25 2.2 Inadequate Environmental Qualification Proqram - Element 210.2 These four issues state that the EQ program is inadequate and that not all required equipment is qualified.
In many cases, qualification records do not exist or are inadequate.
Also, the current (i.e., preshutdown for SQN) upgrade program for EQ needs scrutiny.
These issues were identified as being
- generic, and were investigated at all four TVA'uclear plants.
3.
EVALUATION PROCESS The evaluation process for the subcategory consisted of the following steps (element evaluation methodology is described in Subsection 4.4):
~ a.
Defined issues for each element from the employee concerns.
b.
Reviewed applicable regulatory requirements, industry standards, and TVA criteria documents related to the issues to develop an understanding of the design basis.
c.
Reviewed applicable design documents to develop design understanding and to verify implementation status.
d.
Reviewed applicable
and SER Supplements to understand scope and basis of NRC review, determine regulatory compliance, and to identify any open i'ssues or TVA commitments related to the design.
e.
Reviewed any other documents applicable to the issues and determined to be needed for the evaluation such as correspondence, transcripts of interviews, procedures, audit reports, audit plans, etc.
f.
Using the results from steps a through e above, evaluated the issues for each element.
g.
Tabulated
- issues, findings, and -corrective actions for each element in a plant-by-plant arrangement (see Attachment 8).
h.
Prepared other tables, as needed, to permit comparison and identification of common and unique issues,
- findings, and corrective actions among the four plants.
Classified the findings and corrective actions for each element using the ECSP definitions.
j.
On the basis of ECSP guidelines, analyzed the collective significance and causes of the findings for each element.
2632D-R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 6 of 2'.i k.
I=valuated defined corrective actions to determine if additibna'1 actions are required as a r~esult~ of causes found in step j.
1.
Provided addi tional judgment Or information that may,not be apparent at the element level.
FINDII'IGS The findings for each issue in this subcategory are summarized in Attachment In the attachment, the findings are listed by element number and by plant.
- 4. 1 Sensitive Equipment/Harsh Environment - Element 210.
1 The issue was valid in that sensitive instrumentation is locatedl in the areas described.
HIowever, thiis fact was known, and appropriate measures had been taken under the EQ program in existence at the time SQN was shut down to ensure operability of this equipment in spite.of the environmental. conditions noted.
The present EQ program is adequate to cover safety-related eqUipmeht located in the areas identified by the concern (SQN, WBN).
4.2 Inadequate EQ Program - Element 210.2 All four issues raised by these concerns were raised and found valid for the EQ program in existence wh!en SQN was shut down.
That.overall EQ program had ~
been determined inadequate by TVA management reviews independent of, and
- before, the filing of the concerns.
The present EQ programs at all TVA units,,
except Belief onte, have been, or are beinq, upqraded to comply with 10 CFR 50.49.
Under the upgrade program, ail equipment required t6 bi qualified is being identified and the documentation is being vpqraded as required.
The new program and its dccumentation are being audited'intiti'ally as part of TVA's QA program as well as by 'the NRC.
This program must be completed bef'ore fuel load for each unit.
A long-term EQ program is being established to continue this activity in support of replacements and modifications after startup (SQN,
The present EQ program at Sequovah is being used as a mode'I for the other TYA plants.
This program has received thorough scrutiny frcxn the NRC and, TVA manaqement.
The NRC draft SER for the Sequoyah EQ progr'am is favorable.
At Browns Ferry, the planned NRC inspections and regular audits by TVA management should provic!le the sc:rutiny required to verify compliance with 10 CFR 50.49.
Canparable TVA audits, and NRC inspections performed at Watts Bar and Bellefonte (when appropriate) should provide the scrutiny. required'(SQN,'BN, BFN, BLN).
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26320-R13
( 10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'1000 REVISION NUMBER: 3 Page 7 of 25 Because of plant rescheduling and manpower limitations, the EQ program at Bellefonte is on hold and most major systems have been placed under layup conditions.
4.3 Summar of Subcateqor Findin s
Employee Concern OE-QMS-4 is not addressed in the above discussion because a
telecon in the interview file indicated that the concern was "basically resolved and may be considered closed."
In addition, it was found that the concern relates to the installation. of radio equipment which did not require environmental qualification.
This concern was assigned to element 210.2 because the words "equipment qualification" were used in the concern description.
No issue has been established to correspond to thi's concern.
The concern is being resolved through a'significant condition report which was written for Sequoyah and Watts Bar.
The classified findings are summarized in Table 1.
Class A and B findings indicate there is no problem and that corrective action is not required.
Class C,
0,, and E findings 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 C3 in Table 1'ndicates that the evaluated issue was found to be valid (finding Class C) and that a corrective action involving some type of documentation is required (corrective action Class 3).
For element 210.1, while the issue is considered valid, no specific deficiency could be identified and no corrective action was specified.
As a result, the findinq is classified. as 8 in Table l.
For element 210.2, as mentioned
- above, the EQ program had been determined inadequate by TVA independent of, and before, the filing of these concerns.
Furthermore, the corrective actions noted above had been initiated before this ECTG evaluation.
As a result, in Table 1 the finding for element 210.2 is classified as. C.
A singular finding is shown since the deficiency is in the overall EQ program and the division of the concerns into four issues is somewhat artificial.
With respect to the corrective actions for element 21'0.2, the deficiencies appear primarily in EQ documentation (corrective action Class. 3), but correction of the deficiencies requires significant revision of EQ program procedures (corrective action Class 2),
as well.
Some modification or replacement of hardware, retraining of personnel, and reanalysis of environmental conditions were also involved for SQN'nd will likely be required for WBN, BFN, and BLN.
Table 2 summarizes the findings by classification.
Where more than one corrective action is identified in Table 1 for a. single finding (e.g.,
element 210.2),
Table 2 counts only a single classification.
Thus Table 2
2632D-R13 (10/07/87)'
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 8 of 25 4l identifies one finding for each issue evaluated.
Based on the classification of findings described
- above, two out of six findings require no corrective action.
- One fiinding per plant requires c6rrdctive'ction.
These corrective
- actions, as identified in Table 1
and Attachment B, are essentially the same for each of the plants.
4.4 Element Evaluat'ions This section details the evaluations of: the issues, under elements 210. 1 and
'210.2 applicable to each of the four TVA nuclear plants.
Supporting rationale and references are. provided f'r the findings,'hich are summarized in Attachment B,.
4.4.1 Element '210. 1 The issue described
'in 'Section-2 for element,219.
1 was identified at WBN and was specificall,y evaluated for both WBN and SQN because SQN has a similar Reactor Building arrangement.,
The issue raised in element 210. 1 was not 'specific'ally evaluated for BFN and BLN because their plant arrangements are significantly different from, those of WBN and SON.
However, this issue was inherently addressed in the evaluation of element 210.2, which addresses the adeq'uady of 'the ehtire EQ program.
What constitutes a "harsh environment" lis not(
a0 e'xplicitly defined;. rather, it is presumed to be one that would be sig'nificantly more severe at some point in time as compared to norma'I plant operations including anticipated occurrences.
In addressing this soecific concern, the <~valuation team applied this meaninq to the concerned individual's (CI'0) use of the words "harsh environment."
It should be noted that none of the appiliaable regulatory requirements prohibit equipment,
'includinq "sensitive instrumentation,"
from being placed in harsh environments.
The requirements only stipulate that when safety-related electrical equipment is pla'ced'n such environments, it must be aopropriately qualif'ied.
The area at WBN and SQN specifically refer'red to in the concern ("the bottom of the reactor and part way up 'the building" ) contains flow, pressure, and level transmitters, motor operated flow~ cont&ollvalves, position switches, temperature elementsand the assbci.ates wire a~id cable.,
All of this equipment that is important to safety either~ha4 b'eerii or is in the process of being qualif ied as described in the evaluation of element 210.2.
The evaluation team could niot identify any special or "sensitive" instrumentat.ion in these areas that was not being so,addre'ssed.'.
2632D-R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 9 of 25 The areas in question can.be considered "harsh."
Drawings 47E235 sheets 42 and 45 for WBN (Ref.
2) and 47E235 sheets 44 to 48 for SQN (Ref.
- 3) identify the areas in question.
The concerned individual's reference to "sensitive equipment" is taken to be "electrical equipment important to.safety" as defined in 10 CFR 50.49 (Ref. 4).
Documents "10- CFR 50.49 Equipment Located in the Reactor Building" for WBN (Ref.
- 5) and "List of Devices Inside Containment and Lower Compartment" for SQN (Ref.
- 6) identify the electrical equipment important to safety in the areas in question.
Therefore, even though the equipment may be considered "sensitive," successful qualification under the WBN and SQN EQ programs will demonstrate that it can perform its safety functions under the "harsh" environmental conditions stipulated.
4.4.2 Element 210.2 Backoround.
It is apparent from documentation associated with ihe TVA EQ
~program Refs.
7, 8,
and 9) that substantial activity and corrective actions
~ere in progress before the employee concerns were filed.
To place these concerns in proper context to the present TVA EQ program, an historical perspective of the overall TVA EQ program and how it evolved into the present SQN program is helpful.
The most cogent synopsis the.evaluation team found was in Section 1.A.2 of the SQN Environmental Qualification Package SQNEQ-GEN-001 (Ref. 10).
This is quoted below for the readers'onvenience:
"A.2 TVA EO History "In early 1980, with NRC's issuance, of IE Bulletin 79-01B and NUREG-0588, TVA reacted with an effort directed at satisfying the licensing issues associated with EQ and relatively little attention was directed toward developing an overall programmatic direction that would satisfy the operational maintenance, inspections, test and engineering documentation requirements over the life of the plant.
TVA developed a qualification plan and beoan to obtain quali.fied equipment.
However, the focus of TVA's efforts was to produce a licensing document, the Electrical Equipment Environmental Qualification Report (EEEQR) rather than to develop a sound engineering basis from which the licensing, documents could be derived.
There was no indication that operational requirements were considered as an integral part of the program.
"Throughout the early 1980s, there were several attempts to recognize the overall programmatic requirements associated with EQ, but progress suffered due to a general lack of under standing of the full implications of EQ.
Also, the program was fragmented with no one in overall charge.
"Audits in both Engineering and Power cited programmatic deficiencies.
These audits concluded that TVA's EQ efforts lacked. programmatic direction and definition of interdivisional interfaces resulting in a fragmented program with poor overall coordination and communication.
2632D-R13 (10/07/87)
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21000 REVISION NUMBER:i 3 i
Page 10 of 25 "Subsequently, in the late 1983 to 1984 timeframe, substantial lprogrhss'as achieved as management began to realize TVA had some problems.i EQ coordinator ipositions were established, first in NUC SVCS, then't'he olant sites andi in OE to provide a focal point for EQ.
An effort was initiated. to develop Qualification Maintenance Data Sheets to provide engineering requirements for the maintenance of the qualif'ied status of equipment..
However, progress i'n the'e'velopment of an overa1ll integrated program was slow arid there was still no single entity with overall responsib'ility for the program.
Also, it was questionable whether'VA'8 equipment qualification, files were 'rea'dily auditable'ince the files i
were in several locations and filed under differing schemes.
"There was a recognition that an upgrade and consolidation of'he qualification files was needed, and proposed method was put forth for'pproval to iproceed.
Sequoyah Nuclear Plant had decided to proCeed with the proposal in phases just prioritoi thee Management Review that was begun on July 19, 1985.
"The Management Review produced several observations on tlie-EQ activities for Brown.; Ferry,
- Sequoyah, and Watts Bar Nuclear Plants.
These observations are delineated in [Ref. 11]."
Reference 11 transmitted
'the report, "Management Review of Environmentail Oualification Activities And Documentation For iConformance with 10 CFR 50)49'-
September 25, 11985."
This report was prepared by a te'am of WesTec Services, Incorporated; and TVA personnelI who performed an overall review of TVA ~EQ i
activities and document ation to establishi TVA' generic compliance to 10 CFR 50.49 and NUREG-0588.
e On Auaust 21 and 22,
"as a result of the l'lanagement Review of T'VA's Environmental Qualification Program, the Environmental QualificatiOn Projeot was established
.and charged with the objective of developing an Environmental Qualification Documentation Program to verify that all plant equiptnent covered under 10 CFR 50.49 is qualified.for,its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must'perform'its safety function uip to the end of'ts qualified life."
(Ref.
10)
In January
- 1986, after initial issue of the SQN EQ b'inders was completed, emphasis was directed toward comp'letion of a similar program for WBNI, utilizing essentially the same EQ project that had developed the program for SQN '{Ref. 12).
The BFN units have remained shut down since March 1985 as a
result'f a variety of TVA'nd NRC concerns,'ncluding the environmental 2632D-R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REYISION NUMBER: 3 Page ll of 25 qualification of equipment.
In January
- 1986, an environmental qualification Droject was established for BFN.
This program was modeled after the one being implemented at SQN.
No upgrade of the BLN EQ program has been scheduled to date because of an indeterminate plant restart schedule and manpower limitations.,
The employee concerns addressed herein were not filed until Oecember
- 1985, 4
,months after the SQN shutdown.
The employee concerns address the conditions that led to the shutdown and do not challenge the TVA EQ program that was put in place to correct the situation.
Nevertheless, the evaluation team reviewed the TVA EQ program activities independently to ensure that the. concerns raised were really addressed in the TVA EQ program.
NRC Investiqative Interview.
On February 21, 1986, the NRC staff conducted an investigative interview o TVA personnel.
Portions of this interview covered subject matter relative to these concerns.
The interview transcript was forwarded-to TYA on June 23, 1986, with a request that the concerns discussed therein be evaluated (Ref. 13).
This transcript was reviewed by the evaluation team.
The issue of equipment qualification is discussed on pages 89 through 99 of the NRC interview transcript.
Salient portions of this transcript, which expand on the concerns under element 210.2, are extracted and quoted below:
From page 91 "TYA has bought a lot of equipment knowing full well that it needs to be qualified, but have made the judgment that they will qualify later and they never do.
They would take the responsibility for qualifying it..
In some cases they bought and stored it and drew out of those stored inventories, making an assumption that it was okay to use it whether it was qualified or not.
In some cases they have attached paperwork.to it after the fact, without doing any analyses or testing."
From pages 93 and 94 "Some of the stuff that I looked at physically sitting out at Phipps Bend subsequently was moved to other sites.
Boxes of equipment sitting there for years that never had receipt inspection done on the quality of the equipment or whether it was even specific. equipment ordered or the right equipment and it was never maintained during that period for any long-term storage requirements.
Some of it was not even verified as qualified.
. It was just oftentime coupled with unqualified untraceable stuff and they mixed inventories and used it at will..
In many cases the qualification was done to one environment and then used at another environment."
2632D-R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER,'i 21000 REVISION NUMBER: 3 e,.
Page 12 of 25 From paqe 98 "A standard way of'oing business with TVA is to accept stuff and
- not, necessarilly look to see if what they'ot was acceptable.
If the vendor told them it,was qualified, it was good'nough for them.
. this WesTec report which you probably have read concerning the TVA qualification, I had run into practically',everything they said there'ncluding looking at equipment across the aboard.
I have seen it a'll'and a lot more than what they stated in there~
I agree with it."
The statements from page 98 of the NRC,transcript, indicate that the NesTed report, which initiatecl EQ activities resulting in the 'present
- program, was sufficiently'horough.to gain the interviewee's agreement and acceptance.
The statements from oage 91 miarely add more spec'ifi'c detail as to practices that are already covered by the more general scop'e of the concerns under 01ement 210.2.
'The statements from pages 93 and 94,
- however, suggest two entirely new concerns:
improper storage ancl misapplicati'on 'of'equipment that is Otherwisb properly qualified.
Although site storage is outside the scope of an engineering
- concern, the evaluation team felt that, since it came up in this investigation. and since it could be covered within the scope of the element 210.2 issues, investigation and disposition under this element would not be unreasonable.
Improper storaqe of environmentally qualified equipment from cancelled sites (e.g.,
Hartsville, Phipps
- Bend, and Yellow Creek) that, may have been used oii ooerational unnits is addressed in Quality Assurance Oeviation Report PPS-A-86-001 (Ref. 14).
This resulted in corrective actions in response to Sianificant Condition Report (SCR)
GENIRP'86'01, which is applicable to 'llBN,
15).
Review's clerk cbnducted't the HartsVille, Phipps
- Bend, and Yellow Creek distribution centers for equipment and materials transferred to MBN,
- SQN, BFN, or BLN with the result that "the equipment and materials were determined to be acceptable. or not affected by the SCR and, in all cases, it was determined not to be reportable to the NRC" (Ref. 16).
Closure of SCR GENIRP 860'I was completed on February.2, 1987 (Ref. 17).
This issue was resolved in accordance with TVA QA procedures.
The testimony also suggests that equipment qual'ified for one application ltray have been used in anotl'ier where its qualification parameters were inappropriate.
In such.cases, the qual'ification paperwork will appear to be~
in place and in complianc'e with program requirements but the equipment could actually be unqualified because it was transtferred for use in a different portion of the plant or to a different ~plant entirely.
This is an engineering matter within the scope of the element 219.2 is'sues,'n'd is treated accordingly under this element evaluation as an additional concern.
2632D-R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER:
3 Page 13 of 25 Evaluation Results.
The specific concerns under element 210.2 were addressed and va sdated in the March 12,
- 1986, NSRS Report I-85-225-SQN, (Ref. 18), which relied heavily on the report "Management Review of Environmental Qualification (EO) Activities and Documentation for Compliance with 10 CFR 50.49," dated September 25, 1985.
The conclusions of this Management
- Review, as paraphrased in the NSRS Investigation Report I-85-225-SQN responding to these employee
- concerns, are:
"Based on its review of the TVA EQ program at Knoxville and BFN, the team concluded that qualification has not been established for many equipment items.
In general, the EQ fi.les were found to be incomplete and not readily auditable; where technical information could be found the majority of it was scattered and not easily retrievable.
The team
~ believed that this situation was due to the fragmented nature of the program and the lack of overall cohesive direction of the effort.
This fragmentation was evidenced by the team's observations of inconsistent approaches to qualification by various organizations, lack of detailed
- review, and. poor documentation.
The team.believed that the identified deficiencies were significant, systematic, and pervasive, in. that the same type of deficiencies could be expected to be found in other EQ files.
The team recommended that TVA place the highest priority on the expeditious resolution of these issues."
The issues outlined above caused TVA to shut down the Sequoyah Nuclear Plant and to develop a comprehensive EQ program.
This EQ program effort is outlined in the
(Refs.
1, 19, and 20).
Review of the documentation associated with the EQ program activities shows that the issues raised by these employee concerns were known and in the process of being resolved well before the concerns themselves were initially filed in December 1985 (Refs.
7, '8, 9,
and 10).
Since these issues were identified independently of the ECTG Program and corrective actions were instituted to address the concerns, as pointed'ut in the quoted statement
- above, the evaluation team concluded that NSRS Report I-85-225-SQN constituted a comolete response to these employee concerns.
While the NSRS and TVA/WesTec reports did not specifically address BLN, the observed deficiencies were identified as "systergatic and pervasive."
Therefore,,the same deficiencies are assumed to exist at BLN as at
TVA's.success in implementing corrective actions at SQN, which serves as the model for WBN, BFN, and Bl N, is substantiated by the NRC as a result of EQ program inspections which began in January 1986 (Ref. 21) and conti.nued into 26320-R13 (10/07/87)
TVA EMPLOYE'E'ONCERINS SPECIAL PIROGiRAM REPORT -NUMBER: '1000 REVISION NUMBER].
3I Page 14 of 25 Avaust 1986 (Refs.
22, 23, and 24).
Ih its EQ in'spection report, the NRC addressed these employee concerns as well'S the TVA/WesTec report and found that:
"In additionI to the above inspection
- sCope, your corrective aetio!I!s ItakIen With regard tO the findingS Of the TVA/WeSie'C RepOrt Were reVieWede The inspection determined that, the EQ Program which you are implementing is adequatel,y addressing the findings of the report.
"The inspection also reviewed a sample,'of, 'employee concerns relative to your EQ program tio evaluate whether the concerns had been resolved from the technical staIndpoint.
N'o deflicien!tieS were identified during thie inspection relative to thie concerns reviewed."
The program for enviroinmental Iqualificlatilon of elIectrical/IEC equipment; and components was reviewed to establish its adequacy in response to the NRC interview transcript and the gieneral cOntext of the employee concerns.
The evaluation team independentlly reviewed SQN EQ Binder's SQNEQ-IFT-001, SQNEQ-MOT-003, and SQNIEQ-MOV-005 (Refs.
7, 8, and 25) against.the requirements of IEEE STD 323-1974.
Sufficiient compliance within the framework of the SQN regulatory requirements was established to conclude that the present EQ program activities are resollving the issues raised vnder element 210.2.,
The orincipal means of upgrading the EQ program at each plant has been the EQ
~
Project.
The original EQI Project was formed in September 1985 to develop and restrvcture thie SQN EQ program.
In, January,1986,,
after initial issue of the SQN EQ binders was completed, similar programs were established for WBN and BFN.,
The WBN program utilized personnel from the SQN EQ project while at BFN contract personnel predominated.
The EQ programs at WBN and BFN are n'ot as advanced as that at SQN, but they are being modeled after the SQN program.
The
! eview of EQ.proCedures and documentation.
at WBN (Refs.
26, 27, 28,',
2'9, 'and 30) and BFN (Refs.
31, 32e 33, and. 34) indicates that the essential elements Of the SQN EQ program are contained in tlhe WBN and BFN EQ programs.
The WBN-and BFIN projects are committed to ciompliance with 10 CFR 50e49 before fvel load.
(Refs.
19 and 20).
In Jully 1985, TVA terminated ongoing EQ wor'k at BLN being done by an outside cont;ractor (Ref. 35).
Engineering and construction at BLN have, been essentially on hold since about mid-1985.
A significant condition:report (SCA BLII EEBB543) sian issued against thd BLII EB program on December 9,
1985 (Ref. 36).
The subject condition is stalted a4 follows:
2632D-R13 (10/07/87)
TVA EMPL'OYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER:
3 Page 15 of 25 "There is no methodology document which defines the requirements for environmental qualification of electrical equipment in harsh environments and outlines a program for achieving and maintaining compliance with 10 CFR 50.49 for Bellefonte Nuclear Plant."
The engineering report (Ref. 37) associated with this SCR makes the following statement with respect to the status of the program:
"TVA has notified the NRC of our intent to meet the requirements of 10 CFR 50.49 for BLN (re:
L44 850225 801).
Also, the list of BLN commitments to NRC maintained by the Nuclear Licensing Branch (Chattanooga) contains and follows the commitment to provide EQ documentation before fuel loading.
Since neither TVA nor 10 CFR 50.49
. established a schedule by which plants under construction are to comply with 10 CFR 50.49, TVA has not missed a commitment to the NRC, nor are we in noncompliance with 10 CFR 50.49.
"TVA has not established an EQ program for BLN to date because of manpower limitations.
Since the plant schedule has been stretched
- out, there will be adequate time in the.future to establish an EQ program that will not impact OL schedule.
Additionally, the BLN program will be.able to take advantage of the SQN, and WBN program experience."
The SCR corrective actions are stated as follows:
o "OE-DETS-NEB will ensure that procedural requirements are issued to estab 1 i sh an EQ program for BLN that fulfi 1 1 s the requirements of 10 CFR 50.49 by fuel load.
o "OE-DETS-NEB will ensure that the issued EQ program procedures for BLN described
. above are maintained so that the requirements of 10 CFR 50.49. continue to be fulfilled."
Implementing these actions, with. a program similar to that at SQN, would reso'lve the issues under element 210.2 at BLN.
The issue of potential misapplication of environmentally qualified equipment acquired from, cancelled sites, as raised in the NRC interview transcript, is also known and has been resolved as part of the comprehensive EQ program effort for WBN,
Part of the review for suitability of application in an operating unit is a cross comparison of the environmental qualifications for the equipment and conditions calculated for the plant.
Review of the WBN, SQN, and BFN EQ binders (Refs.
7, 8, 25, 27, 28; 29, 30, 31, and 32) indicates that this evaluation is performed as a routine activity irrespective of the acquisition source.
It is expected that the same program will eventually be applied at BLN.
2632D-R13 (10/07/87)
TVA EMPLOYEE: CONCERNS SPECIAL PROGRAM REPOR'T NUMBER:
2100l)
REVISION NUMBFR:
3 Page 16 of 25 The facts that the entire TVA EQ program actiivity has been conducted and implemented under close NRC inspection (Refs.
21, 22,.and 24) and that the sampled review conducted by the eval'uation team detected no significant'iscrepancies, support the general conclusion of adequacy and regulatory conformance exists throughout the entire the EQ program.
Further substantiation of this conclusion is found in the NRC draft SQN EQ program Safety Evaluation Report (Ref.
- 38) which contaiins the following statements; "On the basis of the above evaluation, the, staff has reached the following conclusions with ri gard. toi the qua'lification of electric equipment important to saf'ety within the scope of 10 CFR 50.49:
"(1) The Sequoyah electrical equipment environmental qualification proaram complies with the requirements of 10 CFR 50.49.
~O
, I
"(2) TVA's proposed iresola>tions for each of the environmental qualification deficie~ncies identifiied in the staff's SER ahd th6 FRC
'ER are acceptable.
"The staff's findings regard'ing compiiiance with 10 CFR 50.49 rely on certain modifications/replacements that must be completed for the affected equipment to be qualified.
In all das'es,'VA is aware of what modifications or replacements are irequired.
iHoweveras a confirmatory action, prior to restart, TVA will be required to certify that the....
issues t noted herein] have, been completed or resolved."
For ONE activities at
9, 39, and 40).
The position of EQ coordinator for plant activi'ties has been establ-ished with reporting responsibi 1'ities to tile plant maintenance superintendent.,
-'The EQ coordinator is responsible for implementation of the site Et} program and for ensuring compliance with 10 CFR 50.49 is maintained.
The program will be in place and functioning before SQN startup.
The SON-soecific ONE procedure (Ref. 40) is based on.the ON'E procedure (Ref. 41) applicable to all TVA units for long-termiEQi program requirements.
This broader ONE procedure (Ref. 41) will be used~ t'o establish long-term EQ proqr ams at WBN, BFN, and BLN" before slartupE The uSe 'of a common ONE-leVel'rocedure should result in long-term EQ programs at WBN, BFN, and BLN that are similar to the one at SQN.
In addition, the EQ program for each plant Hill
.continue to be scrutinized by. internaliTVA qualiity assurance organizhtions (i.e.,
QA as supported by EA) and the NRC..
5.
CORRECTI VE ACTIONS 0
Table 1 identifies a tota'1 of eight corrective actions for element 210.2 but none fo'r element 210.1.
The corrective actions,. along with their findinq/corrective action classifications are summarized in Table 3;
',The 26320 R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 17 of 25 corrective action descriptions in the table are a condensation of the more detailed corrective action information provided in Attachment B.
The plants to which the corrective actions are applicable are identified by the Corrective Action Tracking Document (CATO) column where the applicable plant is identified by the CATD number.
As noted earlier, TVA had initiated corrective action on its environmental qualification program before the beginning of this ECTG evaluation.
TVA's upqrade oroqram for Eg is outlined in the Sequoyah Nuclear Performance Plan (Ref. 3).
The upgrade program is essentially the same for each of the TVA plants.
TVA's corrective action for the ECTG findings of the referenced element reports is to complete the implementation of the upgrade program at each plant.
For the purposes of this subcategory evaluation, TVA's corrective action has been broken into its two main components:
(1) upgrading program procedures, and (2) upgrading program documentation.
As a result, a total of eight corrective actions are identified in Table 1 for element 210.2.
A special E0 program was established at each plant (except Bellefonte) to review all activities affecting Eg, including procurement,
- storage, and maintenance procedures; environmental drawings and calculations; 10 CFR 50.49 equioment list; and Eg documentation; and to revise or restructure these, as aoprooriate.
A key feature of the upgrade program is the collection of Eg documentation into controlled binders to provide a central auditable file to demonstrate qualification as'equired by 10 CFR 50.49.
The evaluation team findings regarding the completion status of the SgN corrective action plan (CAP) for SON Element Report 210.2 (Ref. 42) are documented in the "ECTG Verification Closeout Checklist" (Ref. 43).
This reoort states:
"The evaluation team concluded that the Eg program that was established and the procedures that control its continuing activities adequately resolve the emoloyee concerns discussed in SgN Element Report 210.2
- and, subject to completion'f the remaining open items, satisfy the CAP commitments as outlined in revision 1 of the NPP."
6.
CAUSES Table 3 identifies the causes for each finding. requiring corrective action.
An attempt was made to i'dentify only the most direct precedent condition that led to each finding; however, in this instance it appeared that the problem resulted from a combination of causes, so each is identified.
In all cases, the experience of the evaluation team was used to establish the cause.
2 632D-R13 (10/07/87)
TVA EMPLOYEE.CONCI=RNS SPECIAL PROGRAM REPORT N'UMBER 21000 REVISION NUMB.R:
3 Page 18 of 25 The causes identified in lable 3 relate to the conditions that existkd at the time the employee concerns were filed.
A. noted
- a. TVA management review independent of and
- before, these concerns were filed A brief summary of the conditionS in that time frame is found in the Sequoyah Nuclear IPerformance Plan (Ref. 1).
This is quoted below for the reader's convenience:
"The cause for the failure,to comply in a timely fashion with 10 CFR 50.49. requirements was>>
a lack 'of management attention to the environmenta'I qualifIication program.i As a resu'lt, responsibility
- and, authority [werel not clearly defined and thus the level of docurnentat.ion and attent,ion to detail required for compliance was not recognized.
Additionally, there was a failure to stay informed of'he perfonnance, of
~the remainder of the nuclear utility industry in this program area.
These factors were further compounded by an organizational structure which made communication and cooperation between design and operational personnel difficult."
This summary identifies the root causes for.the failure of. the TVA EQ program to comply with 10 CFIR 50.49.
The TVA management review mentioned abOve had identified a number of deficiencies in,the program, including inconsistent approaches to qualification by various organizations, lack of detailed review, and poor documentation.
EQ files were found, in general, to be incomplete and not readily auditable.
As a result, qualificatiori had not been established for many equipment items.
The root causes for these problems are identified by TVA as a "Lack of Management, Attention" and "Fragmented Organization."
The evaluation team's indepen<ient review in response to these employee concerns confirms the validity of TVA's prior finding.
Again,,these observations do not reflect the current. status of the EQ program at TVA, because, subsequent to the management review in 1985, the program has undergone a major revision.
7.
COLLECTIVE SI GNIF I CAI4CE The issues raised by the employee concerns in tliis subcategory were identified and validated by TVA manatjement reviews independent of, and before, the concerns were filed.
Subsequently, TVA has conducted a major revision or upqrade of its EQ program,.
The upgrade program for environmental qualification is addressed specifically im Sectiion III,, Special
- Programs, of the Nuclear Performance Plan for each plant.'he brOader issues of a "Fragmented Organization" and
'"Lack of ~Management'Attention,"
which were largely responsib'le for the programmatic deficiencies of the old environmental qualification program, are addressed part'ly tin,Section III and,
- more, generally, in the balance of this nuclear performance plan.
The upgraded program is currently being implemented, with some minor variations, at
'632D-R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 19 of 25
- Sequovah, Watts Bar, and Browns Ferry.
Additionally, TVA has committed to imolementing an equivalent program at Bellefonte after engineering resumes there.
The current plan at each plant is to implement the program on a
unit-by-unit basis rather than for the entire plant. at once.
The Eg program at Sequoyah has progressed the farthest and, in fact, is nearly complete.
The Sequoyah program has been subjected to thorough scrutiny by TVA management and the NRC.
The NRC review has led to a favorable draft SER on that Eg program, subject to the TVA completion of a number of open items.
Full implementation of this program at each of the TVA plants should be sufficient to resolve the issues and concerns raised.
The evaluation team's conclusion as to the significance of the findings and associated corrective actions is indicated in Table 3 in the last three columns.
Significance is rated in accordance with the type of changes that resulted from the corrective actions.
The Eg upgrade program has resulted in extensive changes to Eg-related documentation including:
the preparation or revision of numerous procedures",
preparation of a new 10 CFR 50.49 equipment list; the collection of qualification records into auditable Eg documentation packages (binders);
and the reevaluation of these records to establish equipment qualification in the current plant configuration.
As a result of the reevaluation, some equipment modification or replacement has been required at SgN and is likely at WBN, BFN, and BLN.
These hardware changes are reflected in the open items sections of the Eg binders.
The EQ upgrade program is a large effort that has required roughly one hundred engineering man-years per plant and is still ongoing. 'he effort to date has been focused on the first unit at each plant to be started.
The upgrade effort required before startup of subsequent units should be substantially
- less, but still significant.
The staffing level required to maintain equioment qualification in the long term will be significantly higher under the new proqram than under the old one.
Currently, the Eg effort is focused on Seauoyah unit 2 and Browns Ferry unit 2.
Eg program implementations at Watts Bar 'and Bellefonte are presently lower priority items and awaiting successful conclucions of the Sequoyah and Browns Ferry programs so that
.experienced manpower can be used at these follow on plants.
Nearly half the individuals currently involved are contract personnel (roughly 90 percent at Browns Ferry and somewhat less at Sequoyah).
Thus,, there is significant potential for a loss of experience and continuity,in this area, particularly at Browns Ferry.
The impact or this situation, or the manner in which it is accommodated, remains to be seen.
s, 2632D-R13 (10/07/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGIRAMi REPORT-NUMBER:
21005 REVISION.NUMB)R:I 3 Page 20 of 25 TABLE '1 CLASSIFICATION OF'INDINGS AND CORRECTIVE ACTIONS E 1 eir)ent 210. 1 Sensitive'nstruments/
Harsh Environments Finding/Corrective Issue/
Action:Class~
~Finllin **
SON WBN.
BFNl r BL!K
!B B
210.2 Inadequate Env"'ironmental Qual ificatioIn Progra.m 4**C2'3'2 C2
~
'C2 C3 C3 C3
- Classification of Finclinqs ancl Correct,ive Actions A.
Issue not va1 id.
No corrective action -required
-B.
Issue. valid but consequences accept,ab'le.
No corrective action required,i C.
Issue -valicl.
Corrective action initiated before-ECTG evaluation.
D.
Issue valicl.
Corrective action taken as a result of. I=CTG'valuation.
E.
Peripheral'ssue uncovered during ECTG evaluation..
Corrective act.ion required.~
- 1. -Har dware
- 2. Procedure
- 3. Documentation O'. Train'ing
- 5. Analysis 6; Evaluation
- 7. Other
- Defined for each plant in Attachment
'B.'**
Issues a,.b, c, and d,,
as listed in Attachment B, are essentially the, same and are, therefore, treatedl as a single issue.,
2632D-R13 (10/07/87)
~
P
~
~
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 21 of 25 TABLE 2 F INOINGS
SUMMARY
Classification of Findin s A.
Issue not valid.
No corrective action required.
" Plant SQN
0 0
0 B.
Issue valid but consequences acceptable.
No corrective action required.
C.
Issue valid.
Corrective action initiated before ECTG.evaluation.
D.
Issue valid.
Corrective action taken as a result of ECTG evaluation.
K.
Peripheral issue uncovered during ECTG evaluation.
Corrective action required.
1 1'
1 0
0 0
0
'0.
0 1
1 0
0 0
0 0
Total 2
2 1
1 6
2632D-R13 (10/07/87)
IAOLE 3 HAIRIX UF ELEHENfs ~ CDRNECIIVE ACIIUNS, N<U CAUSES SUUCAIEGORT ZION REVISION NUHDER: 3 PAGE ZZ OF ZS HANAGEHENI EFFECIIVENESS CAUSES Of NEGAIIVE F INDINGS
~
I IEOLIICAL DESIGN PRXESS EffECIIVENESS AUE CV F INDING/
CORRECf IVE ACEION ELOI CLASS.ii CORNECVIVE ACf<UN raIU
/frag- /
/
/Ploce-/In<de-/
/
/
/
Jlnade-/
/Engrg /Deslgnflnsuf.)
Jaunted/In<de-tlnade-/dures (quate
/Un-
/
/Inade-/
(quate
/ Lack /Judgnt/crit/ (verlf /stds IUrgan-(quate Iquate
)Not ICon-Itlnelylt<<k lquate llnade-IAs-bttl of I not IConaltlDocu-'Not Jita-
/
U-
/Proce-/Fol-
/nunl- (Res of/of Hgt/Ueslgn/quate
/Recon-/Destgn/Docu-
/ Not
/nenta-/Fol-
/Engrg I
I I
(Vendor/
I ~ Ion n
~
~ ~ I
~ il n
~
cca
~ ~ m <<ev ncc I'
I
~ ~
I
~..
a ~ ~
I ~ ~
I 1- -
In----
\\ ~ On Inwell clrnr CI tlat C I
I z
3 a
5 6
7 8
g Io 11 Iz 13 Id ls 16 If I
3 Igni fI-cance of CnrreetIVI I Act lons' H
nln n
~
~ C rn IA vpgrade cO prngran prOCedureS
~
C NON Ol 8FN OI 8LN Ol C3 Uporade eoulpnent EU docln<entatton.
SUN Ul NUN Ol urn nl 8LN Ul IUIAL6
~
Defined In the Glossary Supplenent.
~ n ner <nod In faute I, Z63SD-R8
( IU/Uf/83)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'1000 REVISION NUMBER:
3 Page 23 of 25 GLOSSARY SUPPLEMENT FOR THE ENGINEERING CATEGORY Causes of Neqative Findin s - the causes for findings that require corrective action are categorized as follows:
1.
Fragmented or anization - Lines of authority, responsibility, and accountabi ity were not clearly defined:
2.
Inadequate qualit (0) trainin Personnel were not fully trained in the procedures established for design process control and in the maintenance of design documents, including audits.
3.
Inadequate rocedures Design and modification control methods and procedures were deficient in establishing requirements and did not ensure an effective design control program in some areas.
4.
Procedures not followed - Existing procedures controlling the design process were not fully adhered to.
5.
Inadequate communications Communication, coordination, and cooperation were not fully effective in supplying needed information within plants, between plants and organizations (e.g.,
Engineering, Construction, Licensing, and Operations),
and between interorganizational disciplines and departments.
6.
Untimel resolution of issues Problems were not resolved in a
time y manner, and their resolution was not aggressively pursued.
7.
Lack of manaqement attention - There was a lack of management attention in ensuring that programs required for an effective design process were established and implemented.
8.
Inade uate desi n bases
- Design bases were lacking, vague, or incomplete for design execution and verification and for design change evaluation.
9.
Inadequate calculations - Design calculations were incomplete, used incorrect input or assumptions, or otherwise failed to fully demonstrate compliance with design requirements or support design output documents.
10.
Inade uate as-built reconciliation - Reconciliation of design and licensing documents with plant as-built condition was lacking or incomplete.
2632D-R13 (10/07/87)
TVA EMPLOYEE CONCI=RNS SPECIAL PROGRAM iREP'ORT NUMBER!
21000 REVISION NUMBER: 3 Page 24 of 25 ll.
Lack of desiqn detail - Detail in t9esign output documents was insufficient to ensure compliance ivith design requ'irements'2.
Failure to document enqineerin
'ud ments - Documeptation jjustifying enigineering judgments used in the design process was lacking Or incomplete.
13.
Oesiqn criteria/cotnmitments not met - Desicjn criteria or licensing commitments were not met.
14.
Insufficient verification doc~umentation '- Documentation (g) was
'nsufficient to audit the adequacy~of~ desiqn and installationi 15.
Standards not followed - Code or industry standards and practice's were not comp
>ed >orth.
16.
Eni~ineerinq error - There were errqrs or oversights in the
'ssumptions, methodology, Or,judgm&ntS Used in the design pirokess.
17.
Vendor error - Vendor design or su>pitied items were deficient for the intended purpose.
Classification of Corrective Actions - corrective actions are classified a'
belonqinq to one or more of the following groups:
1..
Hardware - physical plant chan'ges 2.
Procedure
- clhanged or generated a procedure 3.
Documentation - affected gA records 4.
Traini~n
- required personnel educaiti0n 5.
Ana~lsis - required design calculatiolss, etc., to resolve 6.
Evaluation - initial correctike,acij,ioh p'lani ihdicated a need to evaTuate the issue before a definitive plan could be established,.
Therefore, all hardware, procedure, etc.,
changes are not, yet known 7.
Other - items not listed above Peripheral Fiindi~n~lssu~e
- A negative finding that does not result directly evaluating an employee concern.
By dlef'inition, peripheral findings (issues) require corrective action.
2632D-R13 (10/O7/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page 25 of 25 Significance of Corrective Actions - The evaluation team's judgment as to the si,anificance of the corrective actions listed in Table 3 is indicated in the last three columns of the table.
Significance is. rated in accordance with the tyoe or types of changes that may be expected to result from the corrective action.
Changes are categorized as:
o Documentation change (D) - This is a change to any design input or output document (e.g.,
drawing, specification, calculation, or procedure) that does not result in a significant reduction in design margin.
o Change in design margin (M) - This is a change in design interpretation (minimum requirement vs actual capability) that results in a significant (outside normal limits of expected accuracy) change in the design margin.
All designs include margins to allow for error and unforeseeable events.
Changes in design margins are a normal and acceptable 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 (H) - This is a physical change to an existing plant structure or component that results from a change in the design basis, or that is required to correct an initially inadequate design or design error.
If the change resulting from the corrective action is judged to be sianificant, either an "A" for actual or "P" for potential is entered into the aooropriate column of Table 3.
Actual is distinguished from potential because corrective actions are not complete and, consequently, the scope of required chanaes may not be known.
Corrective actions are judged to be significant if the resultant chanoes affect the overall quality, performance, or margin of a safety-related structure,
- system, or component.
2632D-R13 (10/07/87)
'I il
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page A-1 of 3 ATTACHMENT A EMPLOYEE CONCERNS FOR SUBCATEGORY 21000 Attachment A lists, by element, each employee concern evaluated in the subcategory.
The concern number is given, along with,notation of any other element or category with which the concern is shared; the plant sites to which it could be applicable are noted; and the concern is quoted as received by TVA and characterized as safety. related, not safety related, or safety significant.
0107A-R37 (10/02/87)
ELE55ENT COHCERN IIUMUIR ATTACIIHLHT A LttPLUYL'E CUHLLPtiS fU~UBCATLGURY ? IUOO PLANT APPLICABILITY CONCERN DESCRIPTION'E VI5IUH HUtiBERT 3
PAGE A-7 Oi'
?10.1 IN-85-068-002 tiBN See See "Sensitive equipment, I.e., instruments and.instrument panels are
?10.?
?10.?
located ln a harsh environment.
CI stated that tile location of this equipment ls In the bottom of the reactor and part way up the bul 1dlnq.
Unlt not speclf led."
(SS) 210.2 tt1-85-100-005 iiBN "Envfrorurental qua)If lcat5on of electrical and I&C equipment dnd ron nnnontc lc inaslonuato lissailfll'atlnn Wae nfton nnt slnno nr if It was done, records do not exist ln many cases, which results ln ICI UI
~
o..
o
. t ITVVI I IL4LIVII Vl I Ytllos Ysl'YIIU~
I ul I YIIL uyvl OUY tsl vstl 4IF I VI environmental qualifications needs scrutiny.
CI has no further Information.
Anonymous concern via letter."
(SR)
XX-85-122-0)4 XX-85-122-015 XX-85-)22-(16 HI-85-07?-N13 55IH BLN BFN IlBN "Env5ronmental qua15flcatlon of electrical and I&C equfpment and Csssisnnnent S
1 S 1 nassonssato lissai 1flI at inn Wae nfton nnt slnno nr if 5 t was done, records do not exist ln many cases, which results ln muul1 1cdLUQn ulLP 14LYsi'YOL~
I ul I YIIL Visual auY tsl vsil oss' vs environmental qual lflcatlons needs scrutiny.
CI has,no furtiier Information.
Anonymous concern via letter.=
(SS)
"Environmental qualification of electrical and I&C equipment and COmponentS 5S--fnadegsuate ps~1!ffCatfon yac nfton nnt dnno nr lf lt waS dOne, reCOrdS dO nOt. eXISt, ln many CaSeS, whlCh reSultS ln modffIcation or replacementi Curl'ent iipqrdde proqrdus fol environmental qualifications needs scrutiny.
Cl has no furtiier Informat fon.
Anonymous concern via letter.
(SR)
"Envfronliental qualification of electrical and ILC equipment and Compunontc fS fnadenuateM
'Qsual iffCatinn yac nfton nnt dnnl nr lf was done, records do not exist ln many cases, which results ln modff-Ical'on o" rep'acemen Current up"rade proqr-m.or environmental qualifications needs scrutiny.
CI has no further information.
Anonymous concern via Teiier."
(SR)
"HRC Identified the followlnq concern from review of the i)TC file:
'Inadequate environmental qualification/documentatlons.'"
(SR)
SR/HO/SS indicates safety related, not safety related, or safety Slqnlf leant per VA before evaluations.
21~(10/Ol /81) determination criteria In the ECTO Proqram nanual and dPPlled
AlTACIIMENT A I.MPLUYI.t; CUNCEPNS FUR SUBCAlEGUPY ?IOUU CONCERN ELEMENT NUMBER PLANT LOCATION APPL I CABILI TY BLN CONCERN UESCRIPTION'EVISION NUMBER:
3 PAGE A-3 UF 3
?10.7 XX-85-094-013 (Cont'd)
OE-I)MS-4
?10.3 SIIN HBN X
X X
X X
X UI.LLTLU "Sequoyah:
lt Is the quality problees reqardinq enviroivrentai qualification of conponents per NU REG 0588 that cade the Sequoyah plant shut down.
CI has no specifics or hardware details."
(NO)
"Individual Nad Inforu'ation that mlqht be helpful ln the equlpvent qua I Ification effort."
(SS)
I 5R/NO/55 indicates safety related, not safety related, or safety slqnlf leant per determination criteria In the ECTO Proqrae o'anual and applied by TVA before evaluations.
? 141D-4 (10/Ul/87)
l Cl I
0
~
V~ *i TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 3 Page B-1 of 7 ATTACHMENT. B
SUMMARY
OF ISSUES, FINDINGS, AND CORRECTIVE ACTIONS FOR SUBCATEGORY 21000 contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and corrective actions.
The reader may trace a concern from Attachment A to an issue in Attachment B by using the element number and applicable plant.
The reader may relate a corrective action description in Attachment B to causes and significance in Table 3 by using the CATO number which appears, in Attachment B, in parentheses at the end of the corrective action description.
0107A-R37 (10/02/87)
ATTACIPtENT U SUNDRY UF
- ISSULS, FINUINOS, ANU CORRECTIVE ACTIONS I'Ok SUUCATEbtVRY 71000 PEVI SION NUMBER:
3 Paqe B-? of 7
Issues Findinqs Corrective Actions 1*111*1111111111**
Element 210.1
- SenSitiVe Equipment LOCated in.iiarSh EnVirOrvrentS 11111*1*1111111111 SIIN SIIH SQH Certain sensitive enuinnv nt such as instrerents and instrument
%&&le tr )&&%ton I i
~
~
Vos o
~ os
~ o
~v\\ oacu
~ ~ ~ o
~ sos Jss environment near the lower portion of the reactor.
a The concel II ds)s s ns)t sns'c ifica I lv i%lent if v anv safety-related equiprent of a unique or "sensitive" t ~ it I
~ t I
~ i.s s.& In. r su&russ ln t)so cs)N DIID
~ so s us c
~ %so
~
~ o
~ 0%
o
~ ~ Cssuy u%
~ Iq 'iu \\
\\
u I'
Tne areas in question can be ConSidered "harSh."
Therefore, safety-reiated instrumentatilin) iii tiiese areas must be apprupriat'sly qualified.
Tne sIIN EgP presently in place adequately covers tiie equipment located In the areas referred to i)y the Cl and as more accurately Identified by Siieuts 44 tu 40 uf S)IH Urawinq 41E?35,
<<a' a
I ss
~ a r
. I I
~Ii tn o i n oc&nssnuah a
s ~ V s ~ usa s chaos uoao
~
anV as ul s) s a
~ sos is ~ ~
us u uaquug
~
Nuclear Plant - Units 1 and 7, Equipment kequirinq iiualificatiun unuer lUCFN50.49 List."-
Ti)use conclusions are supported in the evaluation of element 710.7 for SON.
a.
None reuuiredi MBH r
~'i ~ & conc'Ittu&
&ss
~ Insss&nt 0 ~
\\ c ~
~ o ~ ~ ~ ocss7
~ i ~ ac c%)u
~ I& %,%
~ ~
such as Instruments and Instrument
- panels, is locateli in a harsh environment near the lower portion of the reactor.
Ttso as oac ln nssoct inn ran bu rnnc i%lorn)i hare))"
ac ident ifled by MBN Urawinqs 4/L?35-47 and 4?E?35-45.
The concerned indiviuualss reference to osen)sitive equipment,"
which he later-defines as "instruments and Instrument panels,"
ls taten to be "electrical equipment important to safety" as defined in 10CI'RSU.49.
Tiierefore, drawinq tliese referenCes toqetlier neanS that cif'u i.uiito s lsict ~ as&soot t Ines ln to&co sruoc mssct ho Ju i /
~ %u%uu apprOpriately qualified.
Tiie TVA'nVlrOnsrental
)iual lf)Cat)un I ruqram (Eqr) presssntly isns plaCC Is baSCu on compliance with 10cfkb0.49.
keview of the document,
."10cFP50.49 Equipment Located in the Reactor Uuiidinq-watts Uar Nuclear Plant," (0?/17/Ul), st)o<<s the inclusion of tne electrical equipment Impurtant to safety in the areas identified.
Tiierefuret even thouuh tiie equipment may be considered "sensitive," successful qualification
~sndei ti)e ws)N Ls)P )vill sgestssnstrate that it I'an perfurm itS Safety funrt iuns unsjer tiie "t)arSii" enVIrun<tental COI)dl tiuns
'St lpuls)test ~
Ndnt required
0 Issues ATTACHE'NT 8 St@HART UF
- ISSUES, FINUINGS, ANU CORRECTIVE ACTIONS FUP.
SUBCATEGURY ?1000 I inuings REVISION NUHUER:
3 Paqe 8-3 of 7 Correct Ive Actions Ele<rent 710.1 - BFH (Co<<bined with 210.2)
BLM (Combined with 210.2)
(Co<<bi>>ed wit>> ?10.?)
ULN (Co<rbi>>ed with ?IU.?)
BFH (Combined with 710;?)
BLN (Combined with?10.7) i<<i*<<<<AAAAN*1***<<<<
E)e<rent 2'10.?
- Inadequate Environ<<ental qualif icatio>> Prugra<r
<<0<<1>111<<&<<<<iA<<i*<<
SqN a.
The environ<<ental qualification (Eq) proqra<< at Sequoyah is Inadequate.
54N All ti<e issues raised by these ru>>cer>>s were valid for the old Eq proqra<<
ln effect In August 1985, but were also adequately addressi.d In Invustigativn Report 1-85-??s-sqN, tnv iro<vrental qual ifi cation/Electrical/16C Equipment/Co<<ponents,"
(03/17/Bb).
a.
T<<e old SIIH Eti program had beu>> deter<< Ined inadequate by TVA manaqement reviews indepe>>de>>t of and prior to the filing of these concerns.
SqN a.
Correct e
n I<
Uucu<rent (CATV) 210 0?
S I
S d d to TVA on 09/30/86.
A u> ed cu<rpiet ion uf an enviro e
u a iun program as outlined I t e <tqN clear erfur<<<ance Plan prior to S
start.~
On Il/U5/86, a
tact u>> Plan reSpondinq to tl CATO~re dive<i by the ECTG.
Tl<e co e
act'fdR, t lined therein and th a)LM+c, ed to It de<<<onstrate tha regtiv~ti >>s initiated under h
+T EqiP~r r
are sufficient to re 1 c ji<es<nheo e
concerns.
No add t nkI cojF<<sgiv actions are necessary.
Tl s gtgfyn~
satisfactory to th e 'AQUAItin"
73780-6
( 10/01/87)
issues ATTACIV~EHT U bUtu'WY Ui'MUt.S, FIHUIHOb, ANU CUKRECTlVt ACT)OHS FUK SUBCAIEOUKY 71000 Findinqs kE VISION HUHBER:
3 Page 8-4 uf /
Correct1ve Actions E)ement 210.2 - bi)H (Continued) b.
Not all required equ)pment was qualified.
c.
Ttualif)cation.records do not exist or are inadequate in many cases.
d Curierit upgrade proqram.for Ei) needs scrutiny.
TTBH
- b. All equipment required to be qualified ln accordance with
)UCI VbU,49 is presently under review.wh1ch must be completed prior to BUti restart.
A long-term Ei) proqram has been estabiisheii to continue this activity in support of replacement anil modifications after restart.
- c. Recoras,and re)dtud documentation files domonstaattn ti.
adequacy oi tiie SUN El) Program are being developed and A<<rlttorl nu Tlld w
t
~ A bl IIII~ '
t t ~
t ~
~
~
g
~ u ups
~ CI ~ L Pll l Limni Ilh% ~
~ Ilubu I I Ius wl I I be completed prior to restart and maintained by the loniqer term Ei) Pruqram.
d.
The bi)H Et) Proqrair is inspected regularly by the NRC and audited bv TVA management.
wUH b.
Same as "a" above.
c ~
J arne as a
above ~
d.
Same as "a" above.
Ti.e envirow ntal qua) if)cation proqram at tfatts Bar is Inadequate a ~ As loci 1 ified iin bequoyah
- t. 1ement Report 7iU.O? ~ the oid TVA environmental qua)if ication (ET)) proqram had deficienciis that required corrective action.
S)nce many of these corrective actions were equally aermane to ttattS Uar, the concerns as stated were. valid.,An ET) corrective action proqram equiva!ent -tu-the moqram et-ST)H is now being put,into effect at wBH.
However, at present, the
-"".", t-program has-a-suustantfal Hst of open 1tems to be closed and a nuitber of UHUA anil UNE-EA surveillance issues to be resolved.
a.
CA10 710 02 wBH Ol states that an ET) program that reflects the Si!H EU Vroqram has not been fully implemented at watts Bar TVA s corrective action r lan (TCAB-29/, 03/16/8/) outl1nes the plan aind applicable procedures for compietinq inplementatlon of the'ET) proqram before fuel load for each unit at watts Bar.
These actions are satisfactory to tiie evaluation team.
Issues ATTACIWENT 8
SUMMARY
UF
- ISSUES, I INUINUS, ANU CORRECT'IVE ACTIONS FUR SUBCATEUURY ?1000 F Indinqs REVISION NUMBER:
3 Paqe 8-S of 7
Corrective Act Ions Element 2TO.? - wBN (Continued) b.
Not all required equipment was qual Ifled.
- b. Much uf the equipment qualified under the s4N E4 proqram Is the same as the equitant used at watts Bar.
The s4N environmental qualif ication uf thiS equipment,
<<hich <<as conducted under close Inspection by the NRC and TVA manaqenent, has been appl1ed tu the <<BN equipment as appliCable.
WBN equipment ur CundltiOnS that are different from S4N are buinq appropriately qualified under the wBN E4 pruqram.
AII equipment qualifications necessary for compliance Mith IUCFRS0.49 <<III be completed tu thu Satisfactlun uf the NRC prior tu wBN fuel load.
b.
Same as "a" above.
c.
Itualification records do not exist or are Inadequate In nany cases.
- c. The wuN UNt and <<atts Bar E>>qineerinq Prodect
(<<BEP) have procedures requirinq development and retention of auditable files suppurt lnq tne qualification of equipment under the jurisdiction of IUCFRb0.49.
TVA management
<<111 conduct audits of these flies to ensure tnat these procedures are Implemented properly.
TVA UN4A's 1987 audit SChedule Identifies Audit Module 36 to cover Construction's and Operation's tq of safety-related equipment.
Included In this annual audit are the requirements that:
o "All applicable N equips~.nt has been Identified,"
o Equipment documentation dmwnstrates qualification of equipment to expected seismic and environmental condl t Tons," and o
"An adequate Interface but<<e<<n tne Uivision of Nuclear Enqineerinq (UNE) and the Uffice of Nuclear Power (UNP) has been defined In 4A procedures."
c.
Same as "a" above.
?3?BD-6 (TO/0)/87)
Issues ATTACtl/tENT 8 SU/uQRT UF
- ISSUES, FINUItt85, AttU CORRECTIVE ACTIONS FOR SUBCATEGORY ?1000 F indings RI.VIS IOtt ttU/tBER:
3 Paqe Bu6 of 7
Corrective Actions Element 2IO.? - 1/BN (Continued) d.
The current upgrade program for Eti needs scrutiny.
BFN a.
The environmental qualification (EtI) program at Bro<<ns Ferry ls inadequate.
- d. Audits and other verification activities by TVA management and t)A, sllnllar to those c'onducted on St)N, will provide tne scrutiny required to assure successful completion of the wBN Et) program.
In a 03/10/87 teleconference lt was established inat a corrntete and iniearated audit schedule
,for the wBN UttE, wOEP, Operations, and Construction
~ u/cia! ~
c
~
I'l
~ IIUIIII !c Uu/caaa
!aaua!auauaa
/aaal an ua gua ~ auu1 auni uy a.n ua 4 uaaw
~ u uc
~ ~ v
~ aracaca
~ ccu uu assure the level of scrutiny required to neet 1UCFP50.49.
BFN All four issues raised by these concerns were valid for the old E!I Proqram, but were also adequately ad!tressed by tt!e TVA'NSRS tnVUSt inat ivaa Ra Pert I Bh ??5 SIIN "Envlrun/ceantal Uual 1f 1 cat ion/t I!.ctrIcal/IttC Equipment/Components,"
/ ~ ~ 11 ~ 'I ~ale\\
u 1 ~..
~IrU U..
- 1. ~
D
/
ol
$I/J/ I//oU/ ~
allnaa/
1 lie Ill I~ IIUI ~ eul I cl
~ ol aa uaacc
~ Iuaa ~
a.
The utd UFN tt) program t!alt been determined inadequate by TVA managerent reviews Independent. of and before these concerns were filed.
d.
Same as "a above.
BFN a.
CATit 210 02 BFN 01 siaies tt!ai no audltable Et) documentation ls currently available and that compliance with 10 CFR 50.49 must be established by approp! late review before Bi N restart.
TVA's i/!
11
/TPAR d4/
ul
~ 'cl 1 lvc u\\ 'a
~ ua uaua I w u I
07/?1/87) outlines the plan and appt>cao!e proceuures
/or ur!ng!ng o/n into compliance with 10 CFP, 50.49, including the preparation of auditable tj doculrentation.
Furthermore, the CAP
.commits TVA to full Implementation of t/a!c nadiram fur earh alnit Ibefure reetart of that unit.
This CAP is acceptable tu ihe evaluation tean.
b.
Not all required equipment was
~
q all/iud c.
ttualificatlon records do not exist nl pro tni/t!Inuate in naanv cases.
- b. All equlprrent required to be qualified is belnq ldentlf!ed and the Ijocumeutation ls being upgraded In accordance wit>> 10 CFR 50.49.
This program must be
'completed before-81'N restart.
- long-term Et,'rogra.
<<111 be established to continue this activity in support of t'epldCemeniS and modifications aftei restart.
C. IteCOrdS and related dOCulren'iatiOn fileS demunStrating it!e adequacy of the BFtt Eil proqram are belnq deve'loped; Tt!ese records are being audited by TVA management and tne NRC Atso these files will be cnrrpleted before restart and maintained, by tne lonqer term Eti proqram.
b.
Same as "a" above.
c.
Same as "au aoove.
uulai ~la1/f.
J/Q!I, Iu/ UI
Issues ATIActl>>Ettl 0 SOt<<+LRY Ot ISSULS, I'INUltIUS, Attl) CORkECTIVE ACTIONS I UR SUUCATEUOkf 71000 f Indinqs RE VISIUH ttUHBER:
3 Paqe U-l of I Corrective Actions t lement ZIO.<! - HBN (Continued) d.
The current upgrade proqram for EII needs scrutiny.
BLN d.
The Ut tt Eq prOqra<r IS <ruueled after the Stttt EII prOqram which received tt<orouqu scrutiny from tne NKC and TYA mdnaqement.
Planned ttkt. Inspect io>>s dnd regular dudits by TVA na>>aqvment st<uuld pruvi<tu the scrutiny required to meet 10 CCR 50.49 at UI'N.
BLtt d.
Same as "a" above.
a.
The environmental qualification (L<I) program at Bellefonte Is Inadequate.
All four Issues raise<I by it<use cunrerns
<<ere valid for the old EQ program.
Ilu<<ever',
tt<uy t<4<t been identified previously by thu IVA NSPS l>>vestiqative kepurt I-U5-775-5<IN, "tnvironmenta1 I)ua I lt irat ivn/E lectrical/16C tquipment/Co<rponents,"
(OJ/17/86).
- a. Alonq wit>> St)tt, wUN, and BIN, the old BLN EU Proqram had been determined Inauequate by TVA <rdnaqem<.>>t reVlewS Independent of, and prior to, tt<e filing of these concerns.
Nowevet, unlike ttie situation at other TYA unIts. there Is no current effort to upgrade the EII program at ULH.
- Instead, the EII program Is on >>old and most najor systems have been placed under layup conditions.
Equipnent layup ls performed under a
controlled proqram witt< TYA manage<rent reviews and audits.
a.
CATU 710 07 BLtt 01 states ttiat an Et) program c<xrpardble to the one at SIIH has not been I<rplemented at BLtt.
TVA's CAP (TCAU-604, 01/70/81) co<<mits TVA to I<tplementation of an upgraded Et) program at BLN for each unit before tt<at unit Toads fuel.
The 54H Et) program will be use<i as a <rodel, alonq with any lessons learned at SIIN, wBN, and Bf'N.
Although little Is currently being none on the EII proqram for ULN, joint ONIIA/tA au<tits will be perfor<red on a periodic basis to monitor the status of the program.
Ibis CAP Is acceptable to tt<e evaluation team.
b.
Not all required equipment was qualifled.
c.
Itualificatlon records do not exist or are inadequate ln nany cases.
d.
Ihe current upgrade progran for EI) needs scrutiny.
- b. All equltxrent required to be qualified by 10 CfR 50.49 wil I be Identif led and qualified before fuel load.
.However, as a result of plant rescheduling and nanpo<<er limitations, tt<is activity is currently on hold.
- c. kecords and related
<tocu<runtatlun files demonstratinq the adequacy of tl<e ULN Et) proqra<n will be developed as required by lo CIR 50.49.
Tttese records wIII be au<lited by TYA nanaqeme>>t
<>><d tt<e Hkc, as appropriate.
- Itowever, as a result of plant rescttedulinq and <nanpowet limitations, this docume>>tdtlon activity Is also on hold, d.
There Is no upgrade program for EII at BLH at It<is tine.
TVA Is co<>><<Itted to upgradi>>q tt<e EII program when resources pernit, bulldinq un tt<e experience gained at st)N, wUH, and UIN.
Audits by TYA manaqere>>t and IIPc Inspectiuns cu<rparable to tt<ose provided at slIN and UFN will provide the scrutl>>y required.
b.
Sane as "a" above.
c S~
ds d
dbove.
d.
Same as "a". above.
73<<80-7 (10/Ol/8/)
1 0
0 0
.TVA EMPLOYEE CONCERNS SPECIAI PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 0 Page C-1 of 4 ATTACHMENT C REFERENCES 1.
Sequoyah Nuclear Performance Plan,Section III, "Special Programs,"
(07/14/86) 2.
TVA Watts Bar Drawing 47E235, Sheets 42 and 45, "Environmental Data, Environment-Harsh" 3.
TVA Sequoyah Drawing 47E233, Sheets 44 through 48, "Environmental
- Data, Environment-Harsh" 4.
10 CFR 50.49, "Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants" 5.
Watts Bar Nuclear Plant, "10 CFR 50.49 Equipment Located in the Reactor Auildinq,'" (02/12/87) 6.
Sequoyah Nuclear Plant, "List of Devices Inside Containment and Lower Compartment," (09/ll/86) 7.
Sequoyah Nuclear Plant Environmental Qualification Package, SONEQ-IFT-001, "Gould Flow Transmitters,"
(12/11/85) 8.
Sequoyah Nuclear Plant Environmental Qualification Package, SQNEQ-MOT-003, "Joy Fan/Reliance Electric-Induction Motor, Type RN Insulation - Inside Containment,"
(12/08/85) 9.
Seauoyah Nuclear Plant Standard Procedure SQA 173, "Sequoyah Nuclear Plant 10CFR50.49 Environmental Program,"
Rev.
1,,
( ll/18/85) 10.
Sequoyah Nuclear Plant Environmental Qualification Package, SONEO-GEN-001, (03/02/86) ll.
TVA memo from J.
W. Hutton to Darling. and Abercrombie, "Management Review of Environmental Qualification (EQ) Activities and Documentation for Compliance with 10 CFR 50.49,"
[B70 85092 007], (09/26/85) 12.
TVA memo from M. L.-Rayfield to R.
G. Domer, "Watts Bar Environmental Qualification Project (EQP) Transition Plan,"
[B26 0623 0353, (06/23/86) 13.
Letter from B. J. Youngblood, NRC, to S. A. White, TVA, with the attached transcript of the investigative interview conducted'y the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN,
[B45 860714 8323, (06/25/86) 3799D-Rll (10/08/87)
T'VA EMPLOYEE 'CONCI:RNS SPECIAL PROGRAM REPORT NUMBER s'i 21 00()
REVISION NUMBER: 0 Page C-2 of 4 14.
15.
16.
Duality Assurance Deviation Report PRS-A-86-000'I, Rev. 0,
[L19 86053'0 900]
(07/1'5/86)
TVA memo from L. Tummel to D.
W. Wilson, "Hartsville, Phipps
- Bend, and Yellow Creek Storage Facilities - Significant Condition Report (SCR)
'No.'ENIRP 8601," [B24 860911 003], (09/11/i96)
TVA memo from L. Tummel to E, R. McWherter, "Significant Condition Report (SCR)
G'ENIRP. 8601 Rl," [B24 861120 002],, (ll/20/86) 17.
TVA memio from C. A. Chandley to Those Listed, "Browns Ferry,
- SequoVah, Watts Bar, Bellefonte Nuclear Plants, and Hartsville and Phipps Bend Distribution Centers - Significant Condition Report (SCR)
No.
GENIRP 8601
~ Rl," [844 870202 012J, (02/02/87) 18.
19.
20.
21.
'2.
23.
'24.
25.
26.
27.
NSRS Investigative Report I-85-225i-SQN,i"Environmental Qual ificat ios/E'i ectri cal /IE C Equi pment/Components,"
(03/12/86)
Watts Bar Nuclear Performance Plan (Draft),Section III"Specidl Programs,"
(05/06/87)
Browns Ferry Nuclear Plant Performiance
- Plan,Section III, "'Special Programs,"
(revised 09/02/86)
Letter 'From Tay'lor, NRC, to TVA, "'Equipment Qualification for SQN,!'A02 860214 009], (02/1'I/86)
Letter;From Taylor, NRC, to TVA,, "Eauioment Qualification (EQ) Iinspecitidn of SON,"'A02 860303 005], (02/25/86)
Letter
~From Zech, NRC, to TVA, "Equipment Qualification Inspectiioni-i SQN," [A02 860620 005], (06/13/86)
Letter
<From Heishman, NRC, to TVA, " I'nspection Nos.
50-327/86-01; 50-3289/86-01,",[A02 860821 010], '(08/1$ /86)
Seauoyah Nuclear Plant Environmental Qualification Package SONEQ-MOV-005, Vols. I and II, "Liimit'ore'iue'Actuatoirs Outside Containment with Brakes,"
(02/25/86)
Watts Bar Environmential QualifiCatFion Pdojtct -'Project Manual, i
WBN-'EQP-01, Rev,.
1
[B71 860725 500], ~(07/25/86)
Watts Bar Nuclear Plaint Unit 1 EQ Documentation
- Package, WBNEQ-GEN-001',
Rev.
0 [871, 860930 57'2] (i09/30/86$
'labA A an'd B and Open Items only) 3799D-Rl 1 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21000 REVISION NUMBER: 0 Page C-3 of 4 28.
29.
30.
31.
32.
33.
34 35.
36.
37.
38.
39.
Watts Bar Nuclear Plant, Unit 1, EQ Documentation
- Package, WBNEQ-lPT-001, "Westinghouse Pressure Transmitters,"
Rev. 0,
[B71 860930 573],
(09/30/86, Tabs A and B and Open Items only)
Watts Bar Nuclear Plant, Unit 1, EQ Documentation
- Package, WBNEQ-MOV-003, "Limitorque Motorized Valve Actuators," Rev.
0,
[B71 860930 590],
(09/30/86, Tabs A and B and Open Items only)
Watts Bar Nuclear Plant, Unit 1, EQ Documentation
- Package, WBNEQ-MOT-002, "Joy Fan/Reliance Electric Induction Motor, Type RN Insulation, Inside Containment,"
Rev.. 0,
[B71 860930 533], (09/30/86, Tabs A and 8 and Open Items only)
Browns Ferry -EQ Documentation
- Package, BFN2EQ-MOT-001, "GE RHR and Core Spray Pump Motors," Draft Rev. 0, (03/09/87, Tabs A and B and Open Items only)
Browns Ferry EQ Documentation
- Package, BFN2EQ-XMTR-005, "Rosemont Pressure Transmitters," Draft Rev.
0, (03/09/87, Tabs A and B and Open Items only)
Browns Ferry Engineering Project Procedures, BFEP-PI-87-01 through 23 and 28 for environmental qualification, Rev.
0, (issued 03/18/87)
'Browns Ferry Environmental Qualification Project - Project Manual, BFN-EQP-01, Rev.
0, (09/23/86),
(superseded by BFEP-PPI-87-01, etc.)
Letter from J. 0. Vantrease, Impell, to J.
- Cox, TVA, "Bellefonte Nuclear
- Plant, NSSS Environmental Qualification Program, Project Status - July 31, 1985," [B45 851114 953], (09/31/85)
Siqnificant Condition Report, BLN EEB 8543, Bellefonte Nuclear Plant, Units 1
and 2, "There is no methodology document
. for Environmental Qualification
.." [B43 851212 903], (12/09/85)
TVA memo from J.
A. Raulston to D. T. Clift, "Bellefonte Nuclear Plant-En'qineerinq Report (ER) for Significant Condition Report (SCR)
BLN EEB 8543,"
[B45 860128 256], (01/28/86)
Letter from B. J.
Youngblood, NRC, to S. A. White, TVA, "Transmittal of Draft Safety Evaluation on Equipment Qualification for Sequoyah, Units 1
and 2," (12/05/86)
TVA memo from J.
A. Kirkebo (Eng.
and Tech. Services) to R.
G.
Domer (Proj. Eng.), "Organization for Maintaining. the Environmental Qualification Program for Electrical Equipment under 10 CFR 50.49," [845 860329 251], (09/04/86) 3799D-Rl 1 (10/08/87),
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORl'UMBER:
21000 REVISION NUMBER:,0, Page C-4 of 4 40.
Sequoyah Engineering Administrative Instruction SQEP-AI.-OSA, "10 CFR 50.49 Program Requirements'dr Env'ironmental Qualificatiioni ofi Electrical Equipment," Rev.
2, (05/27/87) 41.
TVA memo from R,.
C. Weir to Those Listed, "Bellefonte, Brogans Ferry,
- Sequoyah, and Watts Bar Nuclear Plants - Issuance of Nuclear Engineering Branch's (NEB) l)iscipline Interface Procedure (DI) 125.01 Rl, Pr'ogham'equirements for Environmental Qualif ication of Electrical Equipment in Harsh Environments,"
[845 870317 263),
(03/17/87) 42.
Sequoyah Element Report 210.2, "Inadequate Environmental Qualification Program,"
Rev.
2, (01/27/86) 43.
Letter from G.
I' Parkinson (Bechtel) to G.
R. McNutt (lVA), CATO 210 02 SQN 01 ECTG Verification Closeout Checklist, BLT-497, (09/23/87) 3799D-R 1 l
('il0/08/87) 0: