ML18033A561
| ML18033A561 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/10/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 21300, 21300-V02-R02, 21300-V2-R2, NUDOCS 8902150081 | |
| Download: ML18033A561 (78) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG VOLUIIAE2 ENGINEERING CATEGORY SUBCATEGORY REPORT 21300 ELECTRICALTESTING A2'G) PLANNING UPDATED NUCLEAR POWER
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM
'EPORT TYPE:
SUBCATEGORY REPORT.FOR ENGINEERING TITLE:
ELECTRICAL TESTING AND PLANNING REPORT NUMBER:
21300 REVISION NUMBER:
2 Page 1 of 17 AS N
OR REVISION:
1.
Revised text to incorporate SRP and TAS comments.
Revised Table 3 for corrective actions.
Revised to rearrange findings and to add corrective actions in Attachment B.
2.
Revised to incorporate SRP and TAS comments.
Added Attachment C (References).
PREPARED BY SIGNATURE
]0>tZ 8 DA E
R W
M TAS SIGN URE ATE SIGNATURE CONCURRENCES 0
E NA DA CEG-H:
SRP'IGNATU
~zu -SH DATE APPROVED BY.
P AGER MANAG R 0 NUCL AR POWER DATE 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'1300 REVISION NUMBER' Page ES-1 of 1
EXECUTIVE
SUMMARY
This subcategory report summarizes and evaluates the results of the element evaluations prepared under the Engineering Subcategory 21300, Electrical Testing and Plannina.
The element evaluations document the evaluation of 16 issues related to TVA's four nuclear plants,
- Sequoyah, Watts Bar, Browns
- Ferry, and Bellefonte.
The issues were derived from two employee concerns which cited presumed deficiencies or inadequacies in engineering participation in the preoperational test program of the plant systems.
Negative findings previously identified for Sequoyah were closed before the ECTG evaluation.
Causes for the negative findings relate to engineering procedures.
and site standard oractices, in some instances, not being followed; procedures not beinq fully adequate to cover all requirements; lack of documentation for acceotance of test deficiencies based on engineering judgment (Watts Bar, Browns Ferry, Bellefonte);
some final safety analysis report (FSAR) commitments not reflected in the test documents (Browns Ferry); discrepancies between test documents and the FSAR (Bellefonte);
and lack of documentation in the test and retest results packages for the implementation of the design chanaes made by engineering change notices (Watts Bar).
Also, at Browns Ferry, the initial preoperational test program was not well developed and did not include documented acceptance criteria.
The major corrective actions include development of a restart test program, develooment of new site engineering procedures, revision of licensing documents, documentation of'ngineering judgment for test deficiencies and revision of test documents to correct procedural deficiencies..
On the basis of'he observations
- made, and in spite of the findings identified and of corrective actions mainly in the areas nf procedural inconsistencies and deficiencies, overall engineering oarticipation in the preoperational test oroqram aooears to be adequate for all plants except Browns Ferry.
- However, a
restart test program has been developed for Browns Ferry to resolve the shortcominqs of the preooerational test and retest programs.
Implementation of the corrective actions should resolve all the findings identified during the evaluation for WBN, BFN, and BLN.
A potenti'al for hardware modification does exist as a result of implementation of corrective actions for Watts Bar and Rrowns Ferry.
The TVA-developed Nuclear Performance Plans (NPPs) are expected to improve corporate-level'management of TVA's nuclear activities.
The clarification of responsibility and authority of line management in conjunction with the strengthened role of Quality Assurance (QA) and the establishment of the Enaineerinq Assurance (EA) organization should prevent r'ecur rence of discrepancies identified in this subcatego'ry report.
The causes identified and the other evaluation results will be reexamined from a wider perspective during the Engineering category evaluation.
26800-R15 (10/09/87)
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- Preface, Glossary, and List of Acronyms for. ECTG Subcategory Reports HISTORY OF REVISION REV NUMBER PAGES REVISED REASON FOR CURRENT 'REVISION To clarify that one or more attachments will help the reader find where a particular concern is evaluated
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20400 FRONT MATTER REV:
3 PAGE 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 Authority (TVA).
The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986.
Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns.
Each of 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.
An element consists of one or more closely related issues.
An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more, concerns.
For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself.
Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
- However, the subcategory report does more than collect element lovel evaluations.
The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
Additionally, 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.
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TVA EM]PLOVER CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20a00 FRONT MATTER REV:
2 PAGE ii OF viii The subcategories are themselv<es summariz'ed in'
'series of eight category reports.
Each category report reviews'h'e major findings and collective significance of the sulbcategory reports in one of the fol'lowing areas:
management and personnel relations.
industrial safety construction, material control operations quality assurance/quali.ty control welding engineering A separate
- report, on employee concerns~ de~aling~with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integra'te'he infbrmation collected at the element level, the category reports integrate the information assembled in all the subcategory reports wi'thin the'a'tegory,
'addre."sing particularly the underlying causes of those problemS that run across more than one subcategory.,
0 A final report will integrate and asseSs thd information collected by all of the lower level reports pre]pared for the
- ECSP, including the Inspector General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, con. ult the Tenne'ss6e Valley Authority Employee Concerns Task Group Program Manual.
The Haaluai s'pells'out the program's objectives,
- scope, organization, and resp'onsibilities.
It also specifies the procedures that were followed in the ~inVestig'ati'on,', reporting and closeout of the issues raised by employee cdnc6rns.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20400 FRONT MATTER REV:
2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS=
classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A:
Issue cannot be verified as factual Class B:
Class C:
Issue is factually accurate, but what is described is not a
problem (i.e., not a condition requiring corrective acti'on) 4 Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D:
Issue is factual and presents a problem for which corrective action has
- been, or is being, taken as a result of an evaluation Class E:
A problem, requiring corrective action, which was not identified by an employee
- concern, but was revealed during the ECTG evaluation of an issue raised by, an employee concern.
collective si nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see "employee concern" )
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recur.rence.
criterion
( 'lural:
criteria) a basis for defining a performance,
- behavior, or quality which ONP imposes on itself (see also "requirement").
element or element re ort an optional level of ECSP report, below the subcategory level, that deals with one or more issues.
em lo ee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
TVh ENPLOYEIE CONCERNS SPECIhL PIROGRhN EEPORT NL'IMBER:
20400 E,'ROIfZ ?M'.TER REV:
2 PhGIE iv OF viii evaluator(s) the indi.vidual(s) assigned the responsibility to assess a ape(:if'ic
'rouping of employee concerns.
~tindin s
includes bot:b,statements of fact andi tbe,judsments made about dboke facts during the evaluati.on process; nega,tive findings r'equire corrective~
action.
issue a potential problem, as interpreted by the ECTG'uring the evaluation
- process, raised i.n ione or more concerns.
K-form (see "employee concern'")
evaluation, judgment or decision may be based.
root ca~se the underlying reason for a problem.
<<Terms essential to the program but which require detailed definition have been defined in the IECTG Procedure Manual (e.g.',
g'en&rid, specific, nuclear safety-related, unreviewed safety-significant'. question).'
TVA EMPLOYEE CONCERNS SPECIAL 'PROGRAM REPORT NUMBER:
20400 FRONT MATTER REV:
2 PAGE v OF viii Acronyms AI
,AISC Administrative Instruction American Institute: of Steel Construction ALARA As Low As Reasonably Achievable ANS ANSI ASME
,CAQ CAR CATD CCTS American Nuclear Society American National Standards Institute American Society. of Mechanical.Engineers American Society for Testing and Materials American Welding Society Browns Ferry Nuclear Plant Bellefonte Nuclear Plant Conditi'on Adverse to Quality Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System CEG-H Category.Evaluation Group Head CFR CI Code of Federal Regulations Concerned Individual CMTR COC DCR DNC Certified Material Test Report Certificate of Conformance/Compliance Design Change Request Division of. Nuclear Construction,(see also NU CON)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM
- REPORT, NUMBER:
20400 FRONT MATTER REV:
2 PAGE vi OF viii DNE DNQA DNT DOE DPO Diivision of Nuclear Engineering, Diivision of Nuclear Quality Assurance Diivision of Nuclear Training department of Energy Diiviision Personnel Officer DR ECN ECP ECP-SR ECSP D~iscreIpancy Re1port or Deviat.ion Report Engiineering Change Notice Employee Concerns Program Employee Concerns Program-Si',te Representative Employee Concerns Special Progi.am'CTG EEOC EMRT EN DES ERT FCR FSAR FY GET HCI HVAC Empl.oyee Concerns Task GrouP Equal Employment Opportunity Commisslioa Environmental Qualification Emergency Medical Response Team Engineering Design Employee
Response
Team or Es1erp;ency Re. pohse Team Field Change
- Request, Final Safety Analysis Report, Fiscal Year General Empl,oyee Tra.ining Hazard Control Instruction Heat.ing, Ventilating,, Air Conditioni'ng
'nst;allation Instruction INPO Inst'.itute of Nuclear Power Opet,ations Inspec1 ion Rejection Notice
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
20400 FRONT MATTER REV:
2 PAGE vii OP viii L/R MRAI MI MSPB MT NCR NDE NPP NPS NQAM NRC NSB NSRS NU CON Labor Relations Staff Modifications and Additions Instruction Maintenance Instruction Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Examination 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)
NUMARC Nuclear Utility Management and Resources Committee OSHA ONP OWCP Occupational Safety and Health Administration (or Act)
Office of Nuclear Power Office of Workers Compensation Program PHR Personal History Record PT QA QAP QC QCI Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures Quality Control Quality Control Instruction
TVA E1$PLfOYEE CONCERNS SPECIA'L PROGRAM REPORT NUMBER" 20400 FRONT NATTER REV:
2 PAGE viii OF viii QCP QTC RIF RT SQN SI Quality Control Procedure Quality Technology Company Reduction in Force Rad:iographic Testing Sequoyah Nuclear Plant Surveillance Instruction.
SOP SRP SWEC TEL TVA TVTLC WBECSP WBN Standard Operating Procedure Sen:ior Review Panel Stone andi Webster Engineering Corporation Technical Assistance Staff Trades and Labor Tennessee Valley Authority Tennessee Valley Trades and Labor Council Ultrasoni.c Testing Visual Testing Watts Bar Employee Concern Special Program Watts Bar Nuclear Plant WR World Request or World Rules Workplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER 2
Page 2 of 17 Section Executive Summary Preface ECSP Glossary of Report Terms Acronyms 1
Introduction 2
Summary of Issues 3
Evaluation Process 4
Findings 5
Corrective Actions 6
Causes 7
Collective Significance CONTENTS
~Pa e
ES-1 Glossary Suoplement for the Engineering Category 15 Attachments A
Emnloyee Concerns for Subcategory 21300 8
Summary of Issues,
- Findings, and Corrective Actions for Subcateqory 21300 C
References B-l C-1 TABLES Table 1
Classification of Findings and Corrective Actions 2
Findinqs Summary 3
Matrix of Elements, Corrective Actions, and Causes Paae 12 13 2680D-R15 (10/09/87)
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER 2
Page 3 of 17 1.
INTRODUCTION This subcategory report summarizes and evaluates the results of the ECSP element evaluations prepared under Engineering Subcategory 21300, Electrical Testinq and Planning.
The element evaluations document the evaluation of 16 issues related to TVA's four nuclear plants,
- Sequoyah, Watts Bar, Browns Ferry, and'ellefonte.
The issues were derived from two employee concerns that cited presumed deficiencies or inadequacies in engineering participation in the oreoperational test program of the plant systems.
The two employee concerns provide the basis for the element evaluations and are listed by element number
.in Attachment A.
The plant location where the concern was originally identified and the applicability of the concern to other TVA nuclear plants are also shown.
The two concerns included in this subcategory were identified for Watts Bar.
These concerns were sufficiently broad to apply to all four TVA nuclear plants, as is shown in the applicability column.
The concerns were grouped into four element evaluations, one for each of the four nuclear plants.
The evaluations are summarized in the balance of this report as follows:
o Section 2 summarizes the issues stated or implied in the employee concerns o
Section 3 outlines the process followed for the element and subcategory evaluations and cites documents reviewed o
Section 4 -- summarizes the findings and identifies the negative findings.that must be resolved o
Section 5 -- hiqhliqhts the corrective actions required for resolution of the negative findings cited in Section 4 and relates them 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 each empl'oyee concern evaluated in the subcategory.
The concern number is given,.the plant sites to which it could be aoplicable are noted, the concern is quoted as received by TVA, and is characterized as safety related, not safety related, or safety significant 26800-R15 (10/09/87)
TVA EMf'LOYEE CONCERNS SP'ECIAL PROGRAM REPORT NUMBER';
21300 REVISION NUMBER 2
Page 4 of 17 o
Attachment 8 -- contains a summary of the element-'level evaluations.
Each issue is listed by plant, opposite its corresponding findings and corrective actions.
The reader may trade a concern from Attachment A to an issue in Attachment B by using the element number and applicable plant.
The reader may relate a'orrective action description in Attachment B to causes and significance in Table 3 by using the CATD number which appears in Attachment B in parentheses at the end of the corrective action description.
The term "'Peripheral finding" in the issue column refers to a
finding that occurred during the course of~ev~aluating a concern,but did not stem directly from a employee concern.
These are claSsi'fied
's "E" 'in 'Tables 1
and 2 of thi~ r0po'rt Attac:hment C -- contains the references cited in the text 2.
SUMMARY
OF ISSUIES The employee concerns listed in Attachment A'for each. plant.have been
- examined, and the potential problems raised by She two concerns have been identified as four separ ate issues.
Review of these issues has resulted in four element evaluations.
The issues deal w.ith presumed deficiencies in engineering participation'in'he
'reoperational test program of the plant systems.,
More specifically,'he issues deal with (1) the adequacy of the electr'ical test program and plann'indi (the evaluation team interpreted this issue as inadequacies iin the oreoperational test program),
(2) engineering participation in providing acceptance criteria, (3) engineerinq participation in the conduct of the tests and review of test results, and (4) engineering acceptance of deviation~~ to preooerational test acceptance criteria without justification.
As the following sections.
show, the issueS were'.determined to have some validity at three of the four TVA nuclear 'plants
('Watts Bar, Browns Ferry; and Bellefonte) and to require corrective actions.
Negative findings previOusly identified for Sequoyah were closed before the ECTING evaluation.
Each issue reviewed within tlhe element evaluations is -more comp'letely discussed in Attachment B which also lists corresponding findings and corrective actions tlhat are discussed in Sections
'4 and 5 of this report.
2680D-R15 (10/09/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REYI5 ION 'NUMBER 2
Page 5 of 17 3.
E'!ALUATION PROCESS This subcategory report is based on the information contained in the applicable element -evaluations prepared to address the specific employee concerns related to the issues broadly defined in Section 2 for all four nuclear plants.
From the evaluation process described below, together with the references cited, the reader can determine the steps followed for each of the elements and the subcategory:
a.
Defined issues for each element from the employee concerns.
Attachment A of this report lists the employee concerns addressed herein.
b.
Reviewed regulatory requirements and industry standards (Refs.
36 throuqh 44) applicable to the preoper ational test activity.
c.
Reviewed applicable sections of the FSAR, Safety Evaluation Report (SER) Supplement (Refs.
2 through
- 6) to understand scope and basis of NRC review, to determine the extent of regulatory compliance, and to identify any open issues or TVA commitments related to the design.
d.
Reviewed other documents applicable to the issues and determined to be needed for the evaluation, such as correspondence (Refs.
45 throuqh 61),
INPO report (Ref. 62), Stone 5 Webster report (Ref. 63),
assessment of engineering design control for BFN (Ref. 64), orocedures and site standard practices (Refs.
7 through 22), preooerational test scoping documents and preoperational test result packaqes including test deficiency reports (Refs.
24 thr ough 35), oroblem identification reoort (Ref. 65), engineering change
- notices, NRC insoection reports and TVA responses (Refs.
66 through 47),
and quality assurance audit reports (Refs.
98 through 106) e.
')sing the results from steps a through d above, evaluated the issues and documented the findinas in element evaluations.
f.
Tabulated
- issues, findings, and 'corrective actions from the element evaluations in a plant-by-plant arrangement (see ).
g.
prepared Tables 1,
2, and 3 to permit comparison and identification of issues,
- findings, and corrective actions among the four plants; h.
Classified the findings and corrective actions from the element evaluations using the ECSP definitions.
i.
On the basis of ECSP guidelines, analyzed the collective
'iqnificance and causes of the findings from the element evaluations.
26800-R15 (10/09/87)'
TVA EMPLOYEE CONCERI'IS SIPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NIJMBER 2
Page 6 of 17 K ~
Evaluated defined corrective actions to determiine if additionali actions are required as a result of causes found in step i.
Provided additional, judgment or information that may not be appareint
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at the element level.
4.
FINDINGS Th'e comolete findings From each of the four element evaluations for this subcateqory are cont:ained iri Attachment, B, and are listed by element number i
and olant.
The specific findings, with the applicable plant(s) shown in parentheses, aire summarized as follows;.
'o Negative findings previously identif ied were closed for SequOyah befoire the ECTG e'valuation (Ref~.
1~)
o Engineering procedures and site~ standard practices relating to the preoperational test program are~ not ful~ly adequate to ensure incoir ooration of aill design requirements i~ncluding procedural'equirements for the processing ofi preoperational test documents and, in some instainces, not followed.,
This has resulted in discrepancies.
in test results packiages (BF'N,'BLN, 'IBN).
o There were no documented acceptance criteria in the initial TVA-orefix test scop.ing documents and preoperational test instructions Even Chapter 13.4 of t;hei FSAR Amendment 31 (Ref. 3),
does not clearly def'ine the acceptance cri'teria of each,.
preoperational test; it merely provides~
a "Test Summary" (BFN).
o Test results oackaqes were found to have minor procedural inconsistencies and/or deficiencies
In addition, enaineerina review of test resu'Its'as not adequate because some test result oackaqes were approvedi withi open exceotions and no documentation was available to iidentify'th'e closure of same (BFN).
o There were several instances of no documentation for engineering justification of the acceptance'f'reoperati'onal test def icienc:ies (NBN,, BFN, BLN).
In addition, the following peripheral findinigs iwere identified:'
In some instances, FSAR commitments are not ful1ly reflected in the acceptance criteria of the test doicurAents (BFN)>>
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21300 REVISION NUMBER 2
Page 7 of 17 o
In isolated
- cases, there are discrepancies in the acceptance criteria between the FSAR and test documents (BLN).
o Oocumentation was not available for two test and retest results packages (TVA-13B and TVA-13BRT: Ref.
A summary of the classified findings is provided in Table 1.
Class A and 8
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'ombined with the finding class.
Classification of findings are tabulated in Table 2.
Where more than one corrective action is identified in Table 1 for a single finding (e.g.;
Element 213.2, Finding c), Table 2 counts only a single classification.
- Thus, Table 2 identifies one finding for each issue evaluated.
Of the 19 findings identified by classification in Table 1, eight require no corrective action.
Of the remaininq, eight required new corrective actions to be identified, and three resulted from peripheral findings uncovered during the ECTG evaluation and also required corrective actions.
From Table 2, it can be seen that for Watts Bar, where all of the issues originated, two of the four original issues were found to be valid and require corrective action;
- however, one peripheral issue was identified that also required corrective action.
I 5.
CORRECTIVE ACTIONS Althouah the findings for Sequoyah shown in Attachment B remained ooen ror several years after completion of oreooerational
- tests, they were closed and an adeauate system was in place at the time of the evaluation.
Browns Ferry has developed an extensive and coordinated proqr am to re-verify plant design.
As a result, a major restart test program has been developed to resolve emoloyee concerns regarding the quality of testinq/review performed during the initial oreoperational test and retest orograms.
The original test results oackaqes will not be reopened or revised.
The Bellefonte preoperational test nroaram has been placed on hold and all completed tests will be redone when the orooram is reactivated.
At that time, new site engineering orocedures will be develooed to prevent recurrence of discrepancies identified.
',watts 3ar will develop new ngineering project procedures.
411 deficiencies and inconsistencies found in. the test results packages will be reviewed and corrected.
26800-R15 (10/09/87)
1VA,EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
2'I300 REVISION NUMBER 2
Page 8 of 17 The detailed corrective action descriptions 'are contained in Attachment B,.
A summary of this information, with the applicab'le plant identified in parentheses, follows:
o Develop enqineerinq procedures to prevent:
- 1) recurrence of procedural deficiencies and/or evaluation inconsistencies in test, results
- packages, and
- 2) lack of diocumentation for justifying engineering, judgment in the acceptance of test deficiencies, when the test program is reactivated (BLN).
o Review test packages for procedural defici'encies and/or inconsistencies arid revise test results packages as required.
- Also, deve'iop new engineering projecti priocedures to prevent recurrence of the above shortcomings (WBN).'
Document technical justification tio support engineering judgment in the acceptance of 'preoperationail test deficiencies (WBN).
o Train personnel in new and revised engineering procediures to prkveht
'ecurrence of procedural and documentatiio'n deficiencies (WBN, BLN).
o Oeve'lop a restart test program and resolve the shortcomings. df the'reoperational test and retest programs (BFN).
o Review andi revise existing sitei diirector standard practices to include procedural control of'ngiineering activities and to require enqineering approval for correctioins iofi Cesiqn-related test deficiencies In addition, the followinq corrective actions were identified for the oerioheral findinqs:
o Review the FSAR commitments.
Corriect FSAR and/or input to the restart test orogram as necessary (BFN)<
o Revise Chaipter 14 of the FSAR and iresolve.other discrepancies with test documents on reactivation of the pi'eoperational test program (BLN).
o Review
- and, docuiment previously completed test and retest results packages (TVA-13B and TVA-13BRT; Ref, 26) for the implementation of desiqn changes made by ECNs (WBN).
These corrective actions also appear in Table 3, along with their corresoondinq findinq/corrective action classifications.
The table indicates the plant or plants to which a corrective action is applicable by the Corrective Action Tracking Document (CATO') column "where the applicable plaint is identified by the CATD number.
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21300 REVISION NUMBER 2
Page 9 of 17 From the Finding/Corrective Action Classification column of Table 3, it can be seen that of the ten corrective actions identified, one involves development of restart test prooram, one requires training, five require evaluation and document fix, two involve development of procedures to prevent recurrence of identified problems, and the remaining one requires evaluation to validate the test.
A ootential for hardware modifications does exist as a result of imolementation of corrective actions for Watts Bar and Browns. Ferry.
- Further, it should be noted that for the employee concerns examined no corrective actions were required for Sequoyah, but corrective action is required for the other three olants, Watts Bar, Broivns Ferry, and Bellefonte.
The evaluation team finds the corrective action plans acceptable to resolve the findings.
6.
CAUSES Table 3 identifies one or more causes for each. problem requiring corrective action.
For each corrective action, the most important cause is identified;
- however, in some instances, it was felt that the problem was the result of a combination of causes, each of which should be identified.
In those
- cases, more than one cause is identified for some of the corrective actions.
Totals are shown at the end of the table.
The two most frequent causes are (1) procedures not fully adequate in establishing requirements and (2) procedures, in some instances, not followed.
This indicates that improvements in the quality of preoperational o.nqineer'ing procedures and site practices, and training, are warranted.
When viewed from a larqer perspective, management effectiveness becomes the most frequent cause qroup, with all ten corrective actions falling into this aroup.
Manaqement did not ensure that adequate engineering procedures and site practices were established, that personnel were trained in the use of procedures, and that orocedures were followed.
Two causes are attributed to design orocess effectiveness.
Instances were found where lack of design bases contributed to the incompleteness of Browns Ferry preoperational test program.
Moreover, there was a lack of documentation justifvinq engineering judgment used in the acceptance of preoperational test deficiencies for all plants except Sequoyah.
7.
COLLECTIVE SIGNIFICANCE The neqative findinqs for all plants exceot Sequoyah center around lack of documentation ana lack of fully adequate engineering procedures and site oractices in establishing design, requirements.
FSAR commitments were not, in some instances, fully reflected in the acceptance criteria of the test documents.
In several instances, engineering judgments in the acceptance of test deficiencies were not documented.
Also, there was a lack of 2680D-R15 (10/09/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGIRAM REPORT NUMBER:
2130O REVISION NUMBIER'2,'age 10 of 17
.documentation in tHe test and retest resuilts packages for the implementation of desinn changes made bv engineering change notices.
The Browns Ferry initial nreo6erational test oroqram was not well developed, and it did not include documented acceotance criteria in test scoping documents and preoperational test instruct,ions.
Browns Ferry has novi developed a restart:
test oroqram.
On the basis oF 'the observations
- made, and in spite of thie negative findings identified and of corr'ective actions mainily iinithe areas of procedural inconsistencies and deficiencies, overall. engineerinig participation in the oreooerational test program appears to be adequate for all plants excePt Rrowns Ferry.
However,,
a restart test progi'am'has been developed for.Browns Ferry to resolve -the shortcomings of the preoperational test and retest proarams.
Implementation of the corrective iactions should resolve all the findinqs identified during the evaluation far MBN, BFN and BLN.
A potential For hardware modifications does exist as a result of implementation of corrective actions f'r Watts Bar and Browns iFerry.
The TVA-developed Nuclear Performance Plains i(NPPsi, Reft 23) is expected to imorove corporate-level manaaement of TVA's nuclear activities.
The clarification of responsibility and'uthority of line management in conjunction with the strengthened role of'uIality'ssurance (QA) and the establishment of the Engineering Assurance (EA) organization are a positive step toward permitting TVA to monitor. Engineering's iperformance in the oreoperational test oroqram.
In addition, EA and QA should provide additional assurance that engineering procedures and site practices are adequate and are beinq followed, that FSAR commitments
- .re ~et, and that o.nqineerinu judaments in the acceptance of'est deficiences are documented.
Furthermore, closei coordination and communicati on bet:ieen EA and
')A -o line nanaqements to orovide feedbaick on engineering perfotmance through technical audits should orevent recur rence of the di sc repanci es ident ifi ed above.
.~
The results of this subcategory evaluation are being combined witli the other s>>bcateaory evaluatiions and reassessed in the Enqineeriing category evaluation.
26800-R15 (10/Og/Si~)
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER 2
Page ll of 17 TABLE 1
CLASSIFICATION OF FINDINGS AND CORRECTIVE ACTIONS Element Issue/
Findinas**
Finding/Corrective Action Class*
WN BN BLN 213.2 Inadequate Electrical
- Testing, Planning, and Enaineering Participation; Deviations to Preopera-tional Test Acceptance Criteria C3 A
03 04 06 02 A
06 02 A
,06 02 '2 04 06 D6 D3 06 E3 E6 02 02 06 06 04 E3 E3 E6 E6 E2
- Classification of Findinas and Corrective Actions A.
B.
C.
E.
Issue not valid.
No corrective action required.
Issue valid but consequences acceptable.
No corrective action required.
Issue valid.
Corrective action initiated before ECTG evaluation.
Issue valid.
Corrective action taken as a result of ECTG evaluation.
Perioheral issue uncovered during ECTG evaluation.
Corrective action required.
- l. hardware
- 2. Procedure
- 3. Documentation
- 4. Training
- 5. Analysis
- 6. Evaluation
- 7. Other
- Defined for each plant in Attachment B.
26800-R15 (10/09/87)
T'VA EMPLOYEE CONCI:RNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER 2
Page 12 of 17 TABI E 2
F INOINGS
SUMMARY
Plant Classification of Finclinqs A.
Issue not valid.
No corrective.
action required.
3,2,,0 2
Total B.
Issue valid but consequences acceptable.
0 0
0 0
No corrective action required.
0 C.
Issue valid.
Corrective action initiated before ECTG evaluation,.
D.
Issue valid.
Corrective action taken as a result of'CTG evaluation.
E.
~eripheral issue uncovered during ECTG evaluation.
Corrective action required.
1 0
0 0
0 2
4 2
0 1
1 1
Total
,'4,,5,,5 5
19 0
g ~
26800-R15 (10/09/87)
Cl:
TABLE 3 Haik II UF EtfHEN IS ~ CUkkECIIVf ACIIONSi ANO ChUMS SUBCATEGORY 21300 REVISION NNNIER: 2 PAGE 13 Of lf CAUMS Of NEGAIIVE FINDINGS a I
I TEOIN ICAL I
HANAGEHENI ffffC I I YEN E SS DESIGN PROCESS ffFECIIVENESS ADE ACY I
I 2
3 a
s 6
7 8
9 10 II 12 13 It 15 16 IT I
fINUTNG/
CORREC IlVE ACTION fLOi CLASS.a ~
CUkkLCIIVL ACT IUN CAfU (frag-I I
(Proce-Ilnade-I Ilnade-I (fngrg (Design(lnsuf.(
(nvnted(inade-(Inade-(dures (quate Iun-(
Ilnade-(
(quate I Lack (Judgat(Crit/ IVerlf (Stds (Organ-(quate (quate (Not (Con-Itinely(Lack (quate Ilnade-IAs-bit(
of I not (Ccaaalt(Docu-(Not Iiaa-I tl-IProce-(fol-Inunl- (Res of(of Hgt(Design(quate (Recon-(Design(Docu-I Not (nenta-Ifol-(fngrg tion trn dures loved cation Issues Atten Bases Calcs cll.
Detail nented Het tlon loved Error
(
Signific-( ancee of I Corrective(
(Vendor(
Actions'rror 0
H H I 213.2 02, 06 Develop a restart test progran (RIP) and resolve the shortconlngs of the preoperatlonal test and retest pfograns ~
Bfk 02 I
I I
I X
(A(P(P(
oa Train personnel In neu and revised engineering proCedureS to prevent recurrence of procedural and docunentat Ion det lc lane les.
kbk UI btk Ul BLN 02 E3, f6 E2 Revleu the TSAR coasaltuents, COrreCt the FSAR and/ur nudity NTP as necessary.
BFN UI A
P E3, f6 Revise Chapter Iq of the fSAk for discrepancies.
kesolve other discrepancies upon reaCtlvatlOn Ot the preoperatlonal test progran.
NLN UJ IAI-
- 02. 06 02'6 Develop eng lneer lng procedures to prevent recurrence ot procedural def lc lane les and/or evaluat lon Inconsistencies in preoperatlonal test prugraa uhen reactivated.
Develop engineering procedures to prevent Tact uf docunentatlon for justilylng engineering 3udgnvnt In Lne acceptance of preoperational test deflciences a vn the test progran is react>vated.
BLN Ol NLN Ut IAI-I I
IAI-Defined in Lhe Glossary Supplenent.
~'efined In Table I.
26810-k I3 (10/Ug/BfI
TABLE 3 HAIRIX Of ELEHENIS, CORRECTIVE ACTIONS% ANO CAUSES SUBCAIEMRV 21300 REVISION HWBERL 2 PAGE la Of ly F INOING/
CORRECTIVE ACfION fLOI CLASS. ~ h CORRfCTLVE ACIION CAID CAUSES OF NEGA'flVE fINDINGS h I
TfCNNICAL I
HLNAGEHENI EffECIIVENESS Ilnade-I If ngrg (Design(lnsuf. I (quate I Lack (Judgnt(Crit/ IVerlf IStds (frag-I I
Iproce-Ilnade-I (rented(lnade-(Inade-(uvres (quate (Un-I S ignifl-I cence of I Corrective Vendor(
Actions'nade-(Organ-(quate (quate (hot (Con-Itlnely tack quate Inade-(As-bit(
of
( not (Couelt(Docu-I isa-I LI-Iproce-Ifol-Iuunl- (Res of(of Hgt(Design(quate (Recon-(Design(Docu-I Not Iuenta-t Ion trn dures loved cation Issues Atten Bases Calcs cll.
Detail rented Het tlon Not Fol-(Engrg loved Error Error 0
IL H
DESIGN PROCESS EffECTIVENESS ADE V
I 2
3 4
5 6
7 8
9 IO I
12 I3 ld IS 16 ly I
% ~ %
C IJ%C hv hv vJ% vu Revleu Lest results packages for procedural deficiencies and/or evaluation Inconsistencies and correct as necessary.
Also, develop procedures.
NBN Ui I
I I A I
I I<
E3, E6 Revleu and docunent previously conpleted Lest and retest results packaoes for the lnplenentatlon of design tllhhhht hhhv hv rruh A
P P
,OJ 06 Oocunvnl tcchnical Justification Lo support engineering Judgnent In the acceptance of preoperatlonal test def Ic lane les.
Revieu and revise ealstlng
~ ~ ~
Jl
~
~
J h
~ %%
% ~
prqct lees for procedural control of engineering activities and to require engineering approval for correction of deslon-related test deflclencles.
~
Bfh Ua htv nc
~
h
~l r
I
[
I A,
(
?
iOiALS Defined In the Glossary Supplement%
~'efined in Tahie i.,
26$ I0-RI~ ( I0/Og/Bf) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER 2
Page 15 of 17 GLOSSARY SUPPLEMENT
.FOR THE ENGINEERING CATEGORY Causes of iVeaative Findinqs - 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 aualit (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 procedures
- 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 u
y adhered to.
5.
Inadequate communications - Communication, coordination, and cooperation were not u
y effective in supplying needed information within plants, between plants and organizations (e.g.,
Engineering, Construction, Licensing, and Operations),
and between interorqanizational disciplines and departments.
6.
Untimel resolution of issues
- Problems were not resolved in a
timely manner, and their resolution was not aggressively pursued.
7.
Lack of management attention - There was a lack of management attention in ensurinq that programs required for an effective design orocess were established and implemented.
8.
Inadequate design bases
- Design bases were lacking, vague, or incomp ete or design execution and verification and for design chanqe 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.
Inadequate as-built reconciliation - Reconciliation of design and icensing documents with plant as-built.condition was lacking or
.incomnlete.
ll.
Lack of desiqn detail - Detail in design output documents was insufficient to ensure compliance with design requirements.
2680D-R15
( 10/09/87)
~
8 '
TVA EMPLOYEE: CONCIERNS
'SPECIAL PROGRAM REPORT NUMBER';
21300 REVISION NOMBER 2
Page
'16 of 17 enqineering judgments used in the design process was lacking or incomplete.
13.
Desiqn cr'.teria/commitments not met - Design criteria or licensing commi,tments wel e not met; 14.
Insufficient verification documentation - Documentation (g) was
~Vi 15.
Standards.not followed Code or industry standards and practices were not complied wit,h.
16.
Enaineerina.err'or - There were errors or oversights in the assumptions, methodology, or judgments used in the design process.
17.
Vendor
~error - 'Vendor design or supplied items were deficient for the intiended purpose.
Classification of Corrective Actions - corrective actions are classified as belonging to,one or mor'e of the folTowing groups:
1.
Hardware - physical plant changes 2.
Procedure- - changed or generated a procedure 3.
Documentatior> - affected OA records 4.
Trainina - required personnel education 5.
Analysis - required design calculations, etc., to resolve 6.
Evaluation - initial corrective action plan indicated a need to daevauate the issue before a definitive plan could. be establishecl.
Therefore, alll hardware, procedure, etc!, changes are not.yet known 7.
Other - items not listed above Peripheral Finding~Is.ue)
- A negative finding that does not result directly evaluatinq an. employee concern.,
By definition, peripheral findings (issues) require corrective action.
Significance oF Corrective Act'ions - The evaluation team's judgment as to, the siqnificance o)F the corrective actions listed in Table 3 is indicated in the last three columns of. the table.
Significance is rated, in accordance with the tvne or types of chanaes that may be expected to result from the corrective action.
Changes are categorized as:
0 0
26800-R15 (10/09/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER 2
Page 17 of 17 o
Oocumentation change (D) - This is a change to any design input or outout 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 par t 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 olant 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 siqnificant, either an "A" for actual or "P" for potential is entered into the aopr opriate column of Table 3.
Actual is distinguished from potential because corrective actions are not complete and, consequently, the scope of required changes may not be known.
Corrective actions are judged to be significant if the resultant changes affect the overall quality, performance, or margin of a
safety-related structure,
- system, or component.
26800-R15 (10/09/87)
V ~
"I C
i
~O 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER: 2 Page, A-1 of 2 ATTACHMENT A EMPLOYEE CONCERNS FOR SUBCATEGORY 21300 Attachment A lists each employee concern evaluated in the subcategory.
The concern number is given, the plant sites to which it could be applicable are
- noted, the concern is quoted as received by TVA, and is characterized as safety
- related, not safety rel'ated, or safety significant.
,0107A-R37
( 10/02/87)
LUNCLKN LltHLNI IIUWltk PLANI LUCAI IUN Al IALI!NLNIA LMPLUrLL LUNLLHNS FUK SUUCAILUUkr ?I3UU APPI ILnbllIlr S
NN<<Uh dFN NLN CUNCLHN UE SCH I P I I UN'EVISIUN NUNILH: ?
PAUE A-? UF ?
? I3.2
<<I-US-IUU-ulu IN.-Nb-U?I-OUI
<<uh
<<NN X
X X
X X
X I.II.'I.trical lest inq anu planninq I's Inadequate.
Enqlneerlnq,either dues nut address testlnq or does so Inadequately.
Acceplance criteria fur tesllnq is lnauequate tu non-existent ISH)
U<<viall<<n( i(~
~ >re ne>
tasci
~rr~nt i~r i ~.
~
r r
wpswll4 I, ~
~ LTI ~ 4 <<cl u 4lggpgeu uy Lug)
<<ltnuut <<rltten yustlflcations.
It cannot be ueteroined by the du% unental lun lii the lest pachaqe <<iietiier or nut a detal led evaluation of lhe devlatlun <<as perfureed by ENUES.
This cuncern applies to all pre-up tests.
Iunit Ij Uelails kno<< to IIIC, <<lthheld uue to conf luentlallty.
ci has no further Inforiiiation, NUc PUNEH concern "
t Sk)
IiiulcJLus s J Idly rel Jluu ~ llut Safely I'I'IJleii ~ iii 'safely siqlil~pi.'i'!i.lurnlillallull CriluriJ Ill tiic LLIU Iruqravi inanual anu app>>i.u
TVA EMPLOYEE CONCERNS SPECIAI PROGRAM REPORT NUMBER:
21300 REVISION NUMBER:
2 Page B-l of 29 ATTACHMENT B
SUMMARY
OF
- ISSUES, FINDINGS, AND CORRECTIVE ACTIONS FOR SUBCATEGORY 21300 Attachment B -- contains a summary of the element-level evaluations.
Each issue is listed by plant, opposite its corresponding findings and corrective actions.
The reader may tr ace 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.
The term "Peripheral finding" in the issue column refers to a finding that occurred during the course of evaluating a concern but did not stem directly from an employee concern.
These are classified as "E" in Tables 1
and 2 of this report.
0107A-R28 (09/22/87)
Issues AIIACjjHLNI U SUHH<jNY TAULE UF SUUCAIEtjUNY ELLHENIS SUIICAIEGURY 2ISOO F lndings Corrective Actions REVISION NUHUER: 2 Page 8-2 of 2g 111111111111111111 Ele<<<ent 213.2
- Inadequate Electrical Yesting and Planning 1 *11*1 1 1 1*11 1 1 11 1 1 St)N a.
(he electrical. test prugra<<<
d l
~.
. ~
i
~.s.... ~..
assu
<ssassss
~ ssu as a sssauas<uaau
~
b.
Engineering participatiun in the progra<<i in providinu dcceptdiice criteria is inadequate.
c.
Engineering participation regarding the conduct of the tests aod review of the test results is ioadevvdte,
- a. Logioeeriog participation io ttie overall preoperational soid post<<<udification test prugra<<<s 'was found to be adequate based uo evaluation of test scoping doculentS and Lest results packages (Hef. 24).
b.
Un Lhe baS<S ut tjlis LVSL pdCkay<<S reVieWed (jjef. 24),
Eiivlnrssrjslss ssdr< lalssdt isus in thss ssrssssrwsa fnr nrnuls<lnn accepLance criteria is adequate.
Pfjs, PHfls, and accejit siiice cfiterld wer e piiijie<rly < evleÃed a<<d
~ vo< v<<<eotev by IYA Engineering.
c.
Ihe tulluwiiisj pruble<<<s revardiov Engineering participation io ttie revi<<w ui test resulLs were identified:
u togineeriiig was not pruperly advised in a ti<<<'ely
<ssa\\ioer ut a rai lestuiie chidoye fur the co<<<pletioo of t<<st defici<<ncies ur uf co<<pjetiun aod closure of certain Lest d<<ficienci<<s.
a.
None required.
b.
None required.
c.
None reavired u
A sugyest<<d
<<<udit icatiuo was assigned a deficiency
<i<+<it<or ba
<Illvtdk<d u'stgiiieiiriiig i i's uouuvS ty yuve
< iilI sljiji<vval for 4 LCSt r<<sulLs package wito sol uuLstandiog deficiency.
u A defici<oicy tur d Lest results packaye was not closed uut, alttiuugo resulutiuo ut the deficiency was Subdijttesl LO kiiuins ssr jiig u
s
~ su
~ ~ suu ~
~ ssu
~ \\ ua
~ a au a
~ \\ as
~ 'a au s aa'sal ssas<a erroneously indicating a<i upen deficiency that had already been resulved.
Altouvyn tiie above it<<<<<S re<<<dined op<<n fur several years after co<<pletiuo ot the preoperatiorial LesLs, they are
<iuW CluSed snid an adequate SySte<<<
WaS In plaCe at the L j<<<V Qf tiiiS evs< Iuat luis Lsd aaSuru
< jsss resaulsst iun ansi closure of siinilar ite<<<s.
223UU-2ij'U<<)
issues Al TACNNENT 8 SU%SHY TAULL UF SUBCATEUUNY ELENENTS SUBCATEGUkY 2I300 Findings Corrective AcLions REVISIUN NUHBEN: 2 Page 8-3 of 29 Element 2)3.2 - SIIN (Continued) d.
Ueviatiuns to preoperatiunal test acceptance criteria were accepted by Engineering withouL justification (Cl indicates written 3ustification is necessary.)
Uocux~ntation of the Engineering evaluation of preupera-tional test deviations (deficiencies) was Inadequate.
Ki(N a.
The electrical test program and planning are inadequate; b.
Engineering participation in the program providing acceptance criteria is inadequate.
c.
Engineering participation regarding the conduct of the tests and review of the test results is inadequate.
- d. Ueviations (deficiencies) from preoperational test acceptance criteria were accepted by EN UES in accordance wiLN TVA procedural requirements contained in EN UES-EP 6.01.
Supporting docwxentatlun uf EN DES acceptance of preuperaLiunal test deficiencies was adequate to determine the extent of the Engineering evaluation performed
- a. Lngineering participation in the overall preoperational test program was found to be adequate based on the evaluation of test scoplng documents and test results packages (Nef. 26).
Initial test identification is the responsibility of Engi<<eeririg with revie~ inputs received from the site teSt Cuurdinator.
The responsibility for scheduling and planning resides with the site test coordinator with review inputs from Engineering.
ln recognition of the fact that must of the engineering functions are unscheduled support activities, the evaluation team found no evidence that staffing was inadequate to provide reasonable test activity support.
- b. Un the basis of the l3 test packages reviewed (Ref. 26),
Engineering participation in the establislvnent of acceptance criteria was found to be adequate.
c.
The evaluatiun Lean reviewed IJ test results packages that were prepared fur nine systems.
These packages reviewed included Scoping Uucuvmnts and Preoperational lest Instructions (PTls).
Engineering parLicipated during the testing on an as-needed basis for observaLion anil guidance.
Test results
- packages, Including Plls and acceptance criteria, were reviewed and documented by Lnyineering.
UA Invulvevmnt was nut required by procedure;
- however, IIA cuv<<rage was provided through periodic audits of the progran.
d.
None required.
KBN a.
Nunc required b.
None required.
c.
TVA coxeits So review the procedural deficiencies and inconsistenc>es within the nine Bechtel-reviewed results packages and cenplete any required corrective action prior to unit I fuel load.
A CAI) report will be prepared if a condition advirse to quality is identified as a result of this review.
ln addition, test representatives will be trained on revised Procedure IIEB-Ul-126.U3 and new KBEP Procedures 8.0Z, 8.03, and 8.04.
(CATO 201 03 KBN 03)
ZZJUO-Z Ug/87)
Ai[ACIIIILN! 99 bULLssikf iAOLE OF bUUCAiELlOKY ELEIICNfS s Ilsil'Alrnslssv J I 'lsul J ss s s ~
s
~ 4 ss ss HFVISION NONUER; 2 Page 8-4 of 29 I ccssssc
~ Jcs s
cr iiiuiiigs CorrecCive Actions Element 213 '
- 18N (Cuntinuedj liie procedural deficie99CieS or in~wnSfSte9Cies are 99ut significant aiid do not invalidate Liie Overall adequacy uf Llie eiigineei'sisg part k ipat. iuii iil tbe preuperat iunal LeSL program.
Several examples of the types of procedural deficiencies ur 19icunsisteiicies observed by tiie evaluation teain are c lied helusi t u
hQI9ie hc~s9P1999 Uucums.'nts d d not siiclude -a cha99ge sheet
~
ur an explanation fur Lhe revlslun as required by EP W.U7, 9Lb, asection 4.2.
I o
hcuping'uucimientS were iiut referenced in Appendix A of su99ie P fls.
!Iie-9. aia99iwn hy whkh scope-docu99ient c99aiiges -<<ave Liue99 incorporated into Che Pfls was not evident.
u buiiie Piis did nut reference tne applicable FSN sectiun numbers in Appendb A.
o 1:lusure ui eiigiiieeriiig cuiiiiients un some Plis'ild 9'ssasss'ss sai ssssssssrai csssssscsssic
~ ss ~
cssisw
~ ssct
~ s c 1 ~ c iluL ev ldeilt ~
u Preyperat luiial les L IN-4.1.
Uef ic lency UN139 (ii'22oj w'as clused by pi lib, Nl, Supplement 1,
and Pi 224, Kl, Supple999uiit 1.
ln addltiOn, Pl 22b WaS Lied to Pi 224 and 1'f Llb in Appendix 8 (test def icieucies aiid eiices9tiuusl in LI!9 cnlissis99 fnr
~
"Ulspusitiun u1 UeiicieiiCy," out there waS nO mention
~sf pl VssI 9 ~ s 9 ~ s, 9
~ ss,cs r e js9 IA.
9.
~ I c
f
\\ e
~ ace ss\\ Pu\\
s
~ ussss c
s issccl s
~ iss
~ ssss sss final resulutiun ut deficiencies, exceptions, or open iteus j.
Notes:
l.
UN is a test det iCienCy found during tiie test.
Pf is a LeSt deficieiicy requiring design
<<igineering resulutiun.
Every Pl will have a currespoiiding UN:
2238U-22
( 1U/Ug/8/)
issues ATTACINEHT 8 SUMHAKY TAULt UF SU8CATEGUkY flfktNTS SUUCATEOUkY 213UU FindingS Corrective Actions kfVISION HUHUER: 2 Page 8-5 of 29 Element 213.2 - K8N (Continued) u Preuperational lest YTVA-138.
HCK (nu number) dated Nay 11, 1981 (page 23 p.
1 Of the teSt reSultS package) was tied to Trouble Report (TK) 38llo and Ueficiency UN21.
This deficie<<cy was not mentioned in the Test Sumaary kepurt but dispositioned in Appendix 8 as closed by Tk 3811U.
This HCR (PN8C box relay failed to operate) was not approved either by Engineering or by tne Office of Nuclear Po~er (NUC PK).
Even though Deficiency ON-22 was not mentioned in the TeSt Su~nnary KePOr t, thiS WaS diSPOSitlOned aS closed in Appendix 8 and Engineering conmented that no further action was needed by HUC Pk.
Uata sneet 5.2.1 did not include all tne information required by Scope Uocbment No. TVA-13, paragraph 8.7.c
( 1 tnrougn 5).
o Preoperatlonal Test ITVA-138KT.
Test Record Form f4 was neither submitted nor mentioned in the test results package transmittal form for Oeficiencles UN53, ON54, and EX 33.
- However, these were diSPOSitiOned as closed in Appen'dix 8.
There was no clear evidence to identify that Engineering had approved Ueficlencies UN53, UN54; or EX 33.
EX 32 was approved by Engineering even though the acceptance criteria were not met.
o Preoperational Test ITVA-l.
Even though Ueficiency Ukb iS an open item per Appendix 8 and the Test Sumnary Keport, fngineering approved tne test results package as a complete package witnout resolving the item.
o Preuperatiunal Test iTVA-lb. Ueficiency UNTI (PT42) was approved by Engineering witn a comment, "Control power key diagram to be revised to snow tne sync signal circuit breaker on tne distribution panel as normally open, Ho".
No evidence was found to identify that tne key diagram haS been revlseu.
the scope document nas been revised to clear the Ueficiency Okll but no change notice was issued for PTl.
The scope doc<<me<<t also stipulated, "Also the removal of sync signal to tne inverter section of the UPS must not deform the output wavelorm magnitude by any more than 2x".
lest results were tound to be deficient in this requiranent.
2238D-2 Ug/8))
ATTACIIHLNT U bUHHAKY TAULE UF SUttCAILUUIIY'EttKENTS KIKICatFI IVIV Vl.hiii KEYIUIUtl tlUKHEKI 2 Page 8-6 of 29 I SsueS c I.<t-..~
~
~ ~lb ~ llg8 Corrective Actions Element 213.2 - K8N (Co'ntitiued)
Lngine<<rinu dPPruved the test result's as a complete pdckdgl wittivut dppruving tne Ueficlency 0K14 (PT bg?).
Test Kecora Form f4 !ncludea PT 53? taut not Ull14.
App<<ndix U also dispuSitiOned this deficiency ds clusedo u
Vreup<<rdl,iundl lest fTYA-lbA.
tlCk i!2bk was issued on Ug/Ig/// prior Lu testinu.
Inere is no evlaence in tne result package that.ttie corrective action (breaker repidCeitkitK,?
WdS Cig4tls Led nriur tn test lnn lest Rervrd FOAII f4 Is Irut In Ltie file for tlic closiire uf EX 1, !, b, dnd?
by teSL KIU.IU.
Even In Prevperdtionai Test a KIU.iu, it is aifficuit.to ideiiLity ttie clusure ut these exceptions 'If one does nut knuw the exact dtinuticiatur window numbers.
Jbtwever Lngjneerjiig a~luvdI uf tile test results was iiut depetident un the satistdctury cotr4tletiun.of vrevpeidtivndl Test IfKIU 10 vreuperdtlundl feiL fTYA-IUU. Kurk un test reslrdlnL VKJUb wdS Completed during ttie system testing.
lluwever, Lhis VK did nut list dll ECNs 'required for Ine codtpletioit ut testinu, ketestlnu uf most of the affect<<d valves relating Lu exception EX2 hdd been
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'T pustdluditicdtiun test.
Lngineering gave final dppl Uvd I Lu lhe test result's ds a I vlxplcte pal kdge In spite ut the Cvtituettt, "lne pust modification testing sliuuld verity tlidt Lne vdlv<<S open dtid close In li0 secunds vr less ds dn dccetttdtlce criteria."
ttrnnIIne l I ~ a Isl I
< ~ (illn Ikr tintln Innnu Ilttl tlnc nnt
'I J
been dispusitivned in Appendix U.
Lnglneering gave t indi dpPrvvdl to Lhe teSt reSulLs as d Cud4tlete package eVen ttiuugii neW exCePtions EX 29 tnrouglt !b, Jd through 41, dnd iiew Ueficiencies UN 2b tliruugli 4b IidVe nut Ue<<n dpPruved.
tleltlier Test Kecord Fvrtd f4>>ur Lne traiismlttdl letter for ttie test results package meiitiuned th<< above exceptions dnd def ic i<<iicies.
these were d ispus itivned as closed in Appeiidlx U.
22!UU-23 (TU/Ug/0/>
AIIACIPLLNI U SUNNIIRY )AUL). UF SUUCAILUUkY LLLMEN)S SUUCAIEUURY 2) JOO REVISION NUHUER: ?
Page U-l uf 29 Issues F lndlngs CorrecLive Actions f)emenC 213.2 - NUN (ConLlnued) d.
Uevlations to preuperatiuna) test acceptance criteria were accepted by Enqlneerlnq witnuut 3ustlflcatlun.
(CI Indicates wrILten Justification ls necessary.)
Oucumentatlun of the Engineering eva)uatlon of preupera-tlona) test deviations (uuflc)encles) eras Inadequate.
- 1. Acceptance baSed on enqlneerlng Judqment
- 2. Fire/smoke damper prob)ems addressed ln Subcategury Report 23000, E)ement 230. I
)Ul
- 3. Acceptance based on ECN, vendor dra~ing changes, satisfactory retest, procedural
- changes, or field correction of prob)em 26
- 4. Instruction error or deficiency outside of tile Lest scvpe
- b. C)censing issues reso)ved by lech Spec/FSAR chmrge or NRC acceptance b
- b. Reca)cu)at)on to cunflrm adequacy of result 4
iota) 2))
Fire/smoke danper prob)ems have been addressed In SubCategury kepurt 23000, f)etrtent 23U. I and are not adureSSed further In this e)ement, except to note that Lne resolution of the problem was we)1 documented un the VI furtrfs.
Acceptab)e deficiencies placed In categories 3
Lhruugh 6 were reSO)Ved Or COrreCted by Clearly uucumenLed metnudS.
The remaining deficiency reports were given an acceptab)e disposition on the basis uf eng)neer lng
- d. Iu uva)uate Issue "u," the eva)uatiun Leam reviewed 43U preupurationa) test ueflclency repurts processed from UZ/U4 Lhruugh UZ/Ul.
Ueflciency reports were dispositioned on a printed form Identified with a Sequentla) nuxeer preCeded by PT, I.ceo PT-00) thrOugh PT-)4).
Oeficlency reports numbered Pl-30) throuqh P)-/41 were revleweu.
wlthlh this group, Zl) Pls were found tu have an "acceptab)e deficiency" disposition.
)Ire basIs fur acceptance of these deficiencies was provided ln a)) cases.
lhe eva)uatlun team grouped the accepLance basis Into six categories:
Pruv )de technical Just) f)cat)on documentation for nutrterous NUN P) deficiencies to support how they were dispositioned.
This <<11'I be accomp))shed In three phaSeS defined ln the fO))Owing paraqraphs.
Uurlnq each
- phase, a
teChnlCal adequaCy reVlew Of the Identified PT-item wl) 1 be conducted by either the deslqn test representat)ve or by a technlca))y qualified engineer.
The review will consist of examlnlnq the def lclency, reviewing the reso)ut )un, deterrnlnlnq the appropriateness of the reso) uLion, and deve) oping a wr It ten technlca) rationa)e to support.
Lhe resolution, as needed.
Uocumentation supporting Pi reso)utlon wl)1 be lnc)uded In the site 0A test results
- package, and a copy wl)) be retained <<Ith the.
englneerlnq design test fl)es.
A CA))
report <<l)1 be prepared If a CAI) is identified during the imp)ementation of this CA)U.
Addltlona) procedures wl)l be developed as ouL)lned ln the comnitted action to issue c.
Phase I <<ill review the 33 deficiencies Tddent 7ted hy the Bechtel enhloyee concern evaluation team.
This review will be completed In accordanCe with the above discussion prlur to unit 1 fuel load.
yltese ll lit revle>> tne reeel ~ led l tens of the 441 revle ed by Bechtel to determine lf further ducumentat)orr ls
- required,
)his rev lew <>st!fioat ion renuiied to SupPurL a deCisiun based upon engineering Judg!ix.'nt.
lo evaluate this Issue, the evaluation teaxi looked to ANSi N45.2.li which states, in part, that design aCtiVltieS ue preSCribed In "... written fOre, whiCh provides adequate control and permits reviewing,
- CheCklnu, Or Verlfylna tne results nf tie act IVity by personnel who are experienced ln the subject activity.
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! vl technical 3ustificatlon of, engineering judgeent iS also adurussed In a supplex!ent to NEP-3.2.
iiie suppieeent to NiP-3.2 requireS that the written baSIS fOr an engineering 3udgntent be '... sufficiently clear to peruilt another engineer versed in the particular diSClpllne tu understand the preparer's thought process."
Un the basis provided by ANSI N45.2. 11 and the Suppieeent tu NLP 3 2 tl!e evaluation .tean!
founu tiiat a signif icant nu!nber of the deficiencies given an acceptable diSpusition had Insufficiently docuoented technical iust ificat lun fur acceptance.
Phase III <<Ill review the PfS not
~v.e..ea b," ".! Le! !P!-Du! lunarb PI-300) to detereine lf their resoiut! Gris arc adequately supported, Phases ii and iii snaii oe coepleted before unit 1 fuel load.
(CAiU 201 03 wBN 02) 273HU-10 (UUy13/0/)
AIIALINLNI8 SU<PV<HV TAULI. UF, SUUCATLOUHY LLLHLNIS SUUCAIEOUky 213UU REVISION NUHUEH: 2 Page 8-9 of 29 issues f'inu logs CorrecCIve AcLions Element 213.2 - w8N (Continued) e.
Peripheral finding.
e.
Tne evaluation tean found one significant deficiency which is characterized below.
fwO tnglneering Change NOCICeS (ECNS) 2/86 and 2199 Were found fur pr<<uperaLlonal test fVA-138, "Unslte Ac Uistribution System."
P f1 paraqrapn 2.3.3 stated that theSe ECNs will "... substantially impact and Invalidate portions uf the test."
The test was completed anu the results approved by engineering even thuuuh the test ulrector did nut sign paragraph 2.2.3.1 to.signify LhaL Lhe ECNs listed In paragraph 2.3.3 did not Invalidate the test results.
The evaluation team found no evidence that retesting was undertaken following Implementation uf the ECNs.
e.
fhe TVA correccive action plan Is to have the design test representative responsible for tests lvA-138 and TYA-138 Retest (RT), complete a documentation and a technical adequacy revie~,
and prepare documentation of these reviews.
This documentation will be included within the two test results packages.
This review will enCail thorouqhly reviewing ECNs
?/86 and 2199 for technical content and then reviewinq TVA-138 (HT) results package to ensure that all aspects of the tecluiical content of the subject ECNs wer'e adequately retested and that acceptance criteria were met.
If a condition adverse to quality (CAII) is identified during the Implementation of this CATO, a CAf) report will be prepared.
This revie~ and the associated uocumentation will be completed before unit 1 fuel load.
(CATO 20? 03 w8N Ol) 8FN The electrical test program and plannlnq are inadequate.
a.
T<<e Initial preuperational test program was nut well developed.
SubSequent teSt programS have impruveu over the years.
fvA will test most of the syste<<P-I2.1.
'fhis program was evaluated and found to include steps to make ic an auequate test proqra<n.
There Is nu restart test prugram currently In place for units 1
anu 3.
No applicable proceuures were found that directly controlled engineering actIvities associateu with HTP.
UFN En lneerln Activities Associated with kfp SUSP 12-1, "Restart Test Proqram,"
Hev.
I (Section 7.0 and form SUSP-9/)
anu NEP 10.4, Rev. 0 (Section 3.0) identify engineering activities associated with the Kestart fest Program.
Uence no furLher corrective action is required for this Iten.
7?JUU-IU
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with regard Lo plannlnq, initial test Identification was Lne responsibility uf L<igin<<ering with review data from the preoperatlunal test cuurdinatur/s Ite test director.
The reSPunSibility fqr scheduling anu planning resided witn tnis Inuiviuual, with revi<<w data fru<n Engin<<ering.
In recugnitlun of the fact that must uf the engineering funcLluns ar<<uns< l<udulid suppurL activities, the evaluation Leam fvunu nu evidence 'tf<at staffing was inauequate tu pruVide reaSOnablu L
CCIVILy SuppurL.
Restart Test Pro ram for Units 1
and 3 The intent Is to implement a units 1 and 3 restart progra<n similar to tf<at furmulated for uniL 2.
Restart test programs fur units 1 and 3 will be audresseu In a timely <<<armer subsequent tu restart uf unit ?.
(CAIU 213 u2 UPN Uq)
-i)sues AIIAL!1!!INl 3UHHRKY IABLL UF 3UBCAfE!IUKY LLEHENIS 3UBCAIEL'IUKY 21 JUU Findings Corrective Actions Nf.viSiUN NUMBER ~ 2 Page S-IO of 29 Element 2l3.2 - BFN (Continued)
Vnqrr nnrinn pnriLiCI"OO" 'n L'rogram in providing acceptance crlter la ls indaequdte.
b.
Usi ihu udsls uf Irrfurirrdtrun reviewed, enqlneerl>>g pJrt lcipal ion I>> tnu pruqram fur pruvldinu acceptance crllerld wds iiul ddequdte during the Inlt(dl stage.
After t!!e ALL audit I>> Ul//2,.t>>t evdludtlui! team notea
,Impruveieerrt I>> the slipuldllo>> uf acceptance criteria by Eall!Oa er'!nsl
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1/I eupt ~ QL IUO4I ftie)t pro]r4 !is, a>>d pustirxrdlfical lu>> Lest program s.
I!ie evaluttlori Learn.reviewed iiie UUE pruqram !n Lhe furm uf tne test scoplng documents provided by UNL fur a couple of. restal't Systems dlli! nuted thdt adequate aCCepldnCe crlter la ar'e provided.
lrie KlP test instruction) arl bdSed on UBL arid Systtlrr teSt speClflcatluns,,and many b.
See corrective actions for issue c.
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I ca!as villar t!ie tests and revle<<uf t!ie te)t results is inaaequaie.
c, Englineerlng review uf i!Ie Lest results wds IIUL diltqudle tu the exte>>l t>>at:
u Fur fest fVA-2UI unit 2. "3ecu>>dary CO!ital>>merit Leak Kale fest," It ls staLed In t!ie dlspusitiun of EXCent run 2 tt dt ihe <<urk remaining ur the rOuf
<<lll not affect the test results, and this exception II~ ~ I bt \\ Ie4i tU 4l 4 Idler daiea NO<<ever, the -iest packdqe did not Include the documentation for the closure of this exception.
fhe exception disposition also states that "the std>>dby uds treatment swltchuver luqlc has nut been ln)tailed because uf lack of materia! 'isnraafnre
!i <<1 1! nnt UQ Inc iud sant 1 1 cn ha later date."
fhe test package did nut Include any ducumentJLiun to iuentify t!ie cerlpietiun of Installation Jnd testing uf trit circuitry.
Furtrrerinure, It. Is statelr "I>> pdrdqrJPI! 6.5.4 thai the
)ecuiiddi'v coiildliimeiii llieilndl a x>>dn)IIJn !Ict <>u hut fuiiCtiunJI testing."
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Lv I!le!ILIfy llldt tile Le)L Ildi! bee!I perfurcled, c.
fVA has develuped an extensive and cuurdinated program to re-verify plant deslgnc lhls resulted In a maioi rec!alt program.
lhls program Includes the fu!fowl!!g:
I) A Uesign Bdsei inc anu Verification Proqram (UBYVP), coordinated by UNE to verify system design/conf lguraLlon
- 2) Necessary test requirements generated by UNE to verify syctemc decfnn functions required for safe shutdown 4
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aac i/ ~ QIIL ij Several systems which provide direct support to plant operations but >>ot required for safe shutdown will be t ac!assi ibv cue!em
!sac ~ cn sr !frrui Inssc (SIS).
- 4) f!!use syslems nut lepurtdrrt to safi!ty
<<lll be aadre)sed by a system checklist.
- 5) All identified )ystems will uti lite a system c!!eckllst tu record the system stdtUs dl!d documentdt luil ds d result uf review of. system prucedures,
!iuld
- orders, temporary al terat lu>>s, e>>glneerlng change notices, slqnifleant open maintenance
- requeStS, a>>d system walkduwns.
77 brrr IU I!IB/la/0/)
AI IACIpILNI U SUtuQHY IAULE UF SUUCATEI'UHY ELLIILNTS SUUCATEGUHY 213UO HEVISIUtt NUIIUEH: 2 Page U-ll uf 29 Issues F Iud ings CorrecLive Actions Element 213.2 - UFN (Continued) u Fur Test I'L-b, unit 1, "HeSidual tteat Kexoval (HIIH)
System," acceptable deficiencies for Chanqe Sheet 9
stipulated "verify Lttat 1UA-K3UA and U did energize at this puint in ttte test."
Tlte test result package did nuL Include any ducumentatiun to vel ify tltat this tesL tlad been Implemented.
Also, In paragraph 6.2.4 of the preuperatlunal test instruction, lt Is stated that SIIULduwll COO ling mode operation cannot ue verified unti1 the Po~er Test Program when the reactor vessel can be Iteated up."
tlo documenLation or reference was Included In tne tesL results package to Identify that tlte test has been Implemented.
o For Test GE-31-2A, unit 1, "Standby Oiesel Generator A," GE letter GE-198, dated 06/13//3, reterred tu Lxceptlons 30, 33, 35, and 37 whereas Lite exceptions in the test result package were llsLed as 1, 2, 3, 4.
Lxceptlons 1, 2, 3, 4 weie properly dlspoSll,luned and approved by Engineering.
The test package did nut correlate these exceptions with Exceptluns JU, 33, 35, and 37.
o Fur Test GE-32, unit 2, "Ul.'uwer System," altltougtt Lite test result package did not include Engineering approval uf supplemental disposition of Exceptions 4
and 5, the evaluatiun team determined that these exCeptiuitS haVe been SatISfaCLOrily diSpOSitiOned by ttte preuperat Iona I tesL engineer.
Ihe above destrlbed activities are project ctxnnltments and proqrams which have been coordinated with IVA mttnagement and the NHC.
Completiun of these activities will yield a quality product and should resolve any employee concern for quality of testing/review.performed during the Initial preoperational test program.
For Lhe above reasons, the original test results packages will nut be reopened or reviewed.
with the exception of the following two concerns, ttte RTP progrmn will resolve the listed concerns.
- 1) There Is no requlrenent for "the secondary containment thermal expansion test In Lite hut functional testing."
The "secondary leak rate test" utilizes existinq surveillance Instruction Sl 4./.C to verify system operation/inteqrity.
No restart test program test will be performed.
- 2) Incorporation of temporary cttanqvs Into Sls Is now addressed by SUSP 2.11, Section 6.3.
Sls have been successfully utilized for several years and any required temporary changes have been Incorporated or deleted.
Ilence no further corrective action Is required.
The corrective action will be completed prior to each unit restart.
(CATO 213 02 UFN 02)
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issues A'-iAC<Q'Lhfi U bUHHHKY 1AULl. UF bUUCAfLUUKT LLLKLN15 N<<CAICGUKy ZlJUU lindiiigs Corrective Actions REVISlOH KUKUEKL 2 Page B-12 of 29
~ ~
flement 213,2 KFli fCufltloud di u lur ket'est kl-J/, units 1 and i', "kaff Cooling <fater System,"
Lhe VUKC reVlew CheCXl lit identified Lxceptlun/Uef lcienc les J and b tu be placed on an aol luff 1 iel inui<X<<ent fur i<i Sn eX epf innc pl~ced on nold, and t<ie dlspusltlun uf the exceptions stated tiiai tlile did llut af feet tile test l<<e test package did.nut include any uucumentation'to identify the removal of the hold orderS.
o Fur Retest KU-JU, unit 1, "Primary Cunlalnment ISulat'Iuf< chvStem
+ the P(ikf'eVis cf rheokiicl identified (xCeptlun l.-l tu be placed on the pre;fuel 1
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V ~ XPOS IiIun ul lhe uxl ept Iuub stipulated that this exceptlun did nut. affect t<le 4Cceptaf lee Criieria uf ihe test.
ihe teSL Package did not Include any documentation relating tu the closure uf this exception.
Also listed l<i the checklisi ls Excepilun L-b.
fhe d ls poS I L 0
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S ipulated iiiat ill1 S ixl I 1 be C leared by performl<ig tne test under kU-?J, unit l."
the test package uiu nut incluue any documentation Lo verify t<tat thiS exCeptlun had been closed.
22JUU-1U (UU/lJ/U/1 1
AlIALINLtt I 8 SUtutkKY 1AULL OF SOUCAIEGOKf tttMtttIS SuttCAIL UKY 213UU REVISIOtt ttIN8ERL ?
Page 8-13 of 29 Issues F indlngs Corrective Actions Element 213.2 - 8FN (Continuea) u For Kelest KG-31-3, unit I, "Al tmerqency Po~er Systee Operation; ECC> lusting on Boreal Auxiliary Power and Uiesel Generator Po~er," the PURC review checklist ld<<ntlfled txCePLions/Ueflclencles t2, Eb, Eb, 84, U5, and Ug to be included on Lhe pre-fuel loading cttecklist.
Itte test result package did not Include any ducumenlatlun for Lite Closure of theSe exceptions/def iclenc les.
Lqulpment Itens covered by tttese deficiencies/exceptions
<<ere not available for releSL b<<cause of eaint<<nance ur because they were under hold.
Uurlng ttte tesL, availability of vollage at the breaker terminals was ctteckeu Lo ensure lnat on reeoval uf ttte huld ttte equIpn~nt would operate as required.
lllls did nut, Ituwever, prove tile funcLlonallty of the equipment In question.
For ttte disposition of a fe>> ottter deficiencies/exceptluns, the sane pttliosophy had been usea.
o For ReLesL RG-31-3, unit i', "AC Eeergency Power Systen Uperatlon, ECCS lesllng on Rormal Auxiliary Po~er and Ulesel G<<neiator Power," clusure of EXCeptlOnS/UeflClenCleS E2, E3, t6, E7, and Ub waS required before the fuel loading a'nd knglneerlng nad appruved the exceptluns/deficiencies without ascertalnlng the closure of theSe ltees.
The test result package did not include the pre-fuel loaalng cneckllst, nor the documentation for the Closure of these exceptions/deficiencies.
As ment lonea for Retest RG-31-3, unit 1, tests were performed to ensure the availability uf tne power supply so that on renoval of the hula, the equitxnent would operate as required.
Also, for disposition of txceptions/Ueficiencies, such as El, U8, U2U, and U33, changes were cade without proper docueentatlon.
Ueflclencles Ul and 038 for retest of unit 1 ana unit 2, respectively, were placea on ttte PURC action item log in accordance wlttt the PORC review checklist.
Ihe test results packages did not include any documentation to identify ttte closure of titese def iclencles.
ltte evaluation team detereined that tttese deficiencies were closed by alsconnecLlng the affected equipment from lhe diesel generator battery and Supplying the same froe tne 250 V dc supply panel 8 by ECH L-l/94 anu ttork Plan 5841.
/8/)
Issues AI)ACHHENI U SULKY lABLE UF SUBCA)EGURY ELEHENIS SUUCAIEGUkY 213UU F lnd lngs fcolleI.LIVL-Actions REVISION NUHBER: 2 Page 8-14 of 29 Element 213.2 - BFN (Cont)hued)
O NeteSt NG-J2-2I unitS I and 2, ")2b V dC Power Systeo," identified, during tne discharge test under SurVell)anre IOStrurtlon lSl 1 4 g,a ~ 2 r lho termlnol voltage fur the 60 cells of diesel generator battery A os appl ox Illlall ly, IUS V ~
Indi v Idud I \\ e I I vo I Lage readings were taken and two cells were found to have terminal voltdges below I.B V.
Ihls lmplles that these two cells may be defective.
- Ilowever, Engineering did.not question tnese readings.
A I'ew temporary changes were made to Sl 4.9.A.2.c I pi
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o Envirolxxental conditions for the tests were not St Ipuldted.
O the mechanism by which the tempordry ChdngeS tO the survo)1)anre Insttrurt tons (Sist havo boch Inro%.oi atrd into the original documents was not evident.
o Preoperationdl test, preoperatlonal
- retest, and postmodification instructlonS did not reference tne FSAR and scoping documents.
n Pronnordt lnnal toStS With 4 TVA nrof iX dnd 411
~ otodt results packageS did not include. evaluations of the ef IL'\\ ts Of any OOLSLdnulnlj ECNS On Lhe LCSLS ~
o lest Gt-), unit I, 'Feedwater Control System,"
contained four exceptions witn one exception accepted
~
<<itnout engineering justification.
u IesL GE-Z, uniL I, "Reactor Mater C)eanup System,"
contained db except IOOS wlLN ~ rLSQIOLION Ol l4 excepLiunS deferred. until maintenance was perfomned or tne Installation was coa4tleted.
No evidence was found Lnat these exceptions were properly resolved.
o -test
)VA-OU, unit I, "Prilaary Containment Atmosphere Cuntrol," contained ll exceptions, one of wnich was aCCepted by Engineering witnOut juStif)Cat)On.
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Issues AlIACINt.RI U SQVSkY IAULL UF SUUCAIEUUHY LLLHtIIIS SUUCAIEUOHY 2IJUU fInd ingS CorrecLlve AcLlons REVISION HlNIIEH: 2 Page 8-Ib of 29 Element 213.2 - SFII (Cuntinued) o lust Ut-b, unit 2, "Kesiuua) lleat Removal System,"
contained nine acceptable def ic ienc les.
Ihe uefiCiency relating Lo achievement of required flow rate In the torus cuolinq loop was accepted by ULU with minimal justificaLiun even while acknowledging that the globe valve ln each luop was undersized.
o Retest RG-6, unit I, "Keactur Core Isolation Cooling System," Identified une Instance of an on-the-Spot replacement of a hand Switch without an evaluation of the CauSe fur Switrh COntaCt failure.
o Retest HU-22C, unit I, "Average Power Range lhnltorinq System" disclosed a faulty electrical penetration.
A spare electrical connection was used to repair the deteCted fault, b'ut there Is no evidence that this Informat lun was used to revise the applicable drawings.
o Retest HU-32-2, units 1 and 2, "l25 Vdc Power System,"
noted several alarms that <<ere resolved by chanqlnq the alarm setpolnts.
Ho engineering JustIficatlon was provided for acceptance of this change.
o HetesL RI-I3, units I and 2, "Fire ProtectIon System,"
identified t<<fo circuits that did not function properly because the ~rong hands<<Itches were. Installed.
No Information was found to Indicate that the affected dOCumentatlOn had been reVISed tO refleCt the SwltCh ChangeS.
Ihese chanqeS also raIse the possibility that these cIrcuits did not function properly durlnq tne original preuperational test or during plant operation.
223RI)-18 ul )
issues IIIIALUrtttlI u Sutttbtkf IAULI; UF SUUCAILIsukf LLLMI.NI6 SUUCAIL'buky 213uu I intlit tgs Currectlve AcLiuns kCvisluN NUIIULk: 2 P~e 8 ib uf 2a f.ietrcAL 213 i = Ufsg (COALInuea) d.
Uevldtiuns to preoperaliundl Lest acceptdnCe Criteria were dC<eutea by Engineering wltnout justification.
lndlcateS Writ tun IVSI tf!e.alton Is necessary,)
Uocument'atlvn of tne EregsAecriAg eviltuat Ivn of PI evperd tiondi test deviations (def ic leuc les) was inadequate.
d.
Ine prevperdllundl lesl results pdCkdgi Cviilalntd-d IIVXSI<r uf ueflcletieleS thai lucre dcscesttsea "ds-Is" Wlltiousi engineerinq duSL Iflcdtlun.
Itic evaluation teen did nut find-ttte number uf deflCseIICIUS dCceplea Wiitiaut engineering justlfication tu be excessive, particularly wiieA viewed against the stanuaras ana reguiatory requirements ltl place wllell Lhese lesLs wel'e lie'IA4 cunaucted.
Itic reteSL prugrdvt aiiOw<<d un-ttie-Spot ChdngeS tO COrreCt
~fIcierecies ltlls @clhvv dlv not di lvw.d deliberate englnteerlng evaluation.
Engineering jusllfication for accepCdnbe uf test deficiencies was Inadequately documented and.
on numerous occaslonsi docuxtentation of Justification wias nonexistent.
itic early PIII pr'ogidtn waS under ttie prOcedural cuntroi of tlte dPPli ICdl'ie Portloi'I Of itiC Pearit i&deflCaLIoil Instruction, UF-8.3, Ihe applicable porLlons of UF-8.3 were subsequentiy deieted ana a new lttore effective prugrdxt WdS defined ln procedure, SUSP-1112.
Ine evaluation team looked at several PIII results packages dad found that enaIneerlna evaluation nf ts St aeflr,lencles was evlaent.
itic restart test. progrdxl procedure SUSP-12.
1 for unit 2 wds evdiudtea ana founa to inciuae pioceaurai contruis for the hdn'aling uf test aeflcleilcies, but the expedience uf un-tne-sput currecLlons of aeflclencles still exists.
Inaepenaent audits could be vs<<a effectIvelv ta verlfv tndt vn-ttie-spot corrections du not affect design.
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CUSP 12.1 "k<<sldrl fest Prvqrdstl," kev. I, (Section b b and SUSP 1/?
'Post Hudificdtlon lest Progrdxt" provide meiuis vf docuxtentlng deficiencies.
Lngineering will be involved ln any design changes resulting from tnese prograxts since sotte fore of desivn ctianae aoriweents ieiist Issued to physically change plant etac I, n dian
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SUttCATLGUHY ELLttLNTS SUUCATEGUHY 2)300 HEV)SION NUMUEHL 2 Page 8-17 uf 29 issues F inuings Corrective Actions E)eeenL 213.2 - UFN (Cuntinued) e.
Periphera) findfitg.
e.
ftte evaluation Leam found discrepancies bet<<een Ltte FsAH, suction 13.4 (LesL suottary),
anu Lite Lest resu)L packages describeu belo<<.
o Test GE-3)-2A, unit 1; Retest HG-31-3, unit 1; attd Ketest k0-3)-3, uniL 2 - FSAH Section 0.5 stfpu)ates that fVA eeeL the diese) generator capacity requirement of AEC Safety Guide 9.
Section 8.5.4.2 anu Figure 8.5-19 of the FSAH indicate that computer studies have been conducted to represent the cost severe loading that the pumps and eotors (and therefore the uiese) generator) can encounter.
The cost severe voltage drop occurs on starting the 2,UUU hp HtlH pump motor, plus eiscel)aneous 480 V
loaus.
Ttte calcu)ated resu)ts show that the vo)tage initially dips to approximately 47 percent motor voltage anu recovers to 80 percent voltage in
).4 seconds.
The RHR pump eotor coees to full speed at 3.5 seconds, whereas tn actual tests, the RllR pump eotor accelerated at 3.5 seconds <<ithout the elsce'llaneous 480 V loads.
lhe FSAR also states that the eotors invo)ved have been checked with the manufacturer to verify tnat tttey <<f 11 reach fu)1 speed under loau for tne condition stated above.
)n none of the'bove tests and retests were 480 V loads autumaLica)ly sequenced per the established loading sequencing of the plant.
TVA also did not eeasure tne frequency uip during ttte loau sequencing of diesel enerators.
Even though Safety Guide 9 was not eet iterally, the ft'ttent appeared to have been eet, but no justification was provided for not sequencing ttte 480 V loads.
e.
A revie<<of the "FSAH Ctxnnltment" <<il) be performed by Urowns Ferry Nuclear Project.
FSAH corrections anu/or Rfp modifications
<<ill be made aS required by the resu)ts of that revie<<.
CAt)R UFF870088 corrective action defineu an extensive program for updating and correcting FSAR inaccuracies.
1he corrective action w)1) be comp)eted before unit 2 restart.
(CAfU 213 02 UFN 01) ftte test suenary under "Standby AC Pu<<ur System tesL GE-31," of Section 13.4 of ttte FSAR, contains coinnftmett(s to (1) check automatic redistribution of 1oau after failure of one diesel, anu (2) perform an integrateu tesL to uenonstrate uperatiun uf al) plant safety systems subsequent to a )oss of offsite po~er.
)tte evaluation team interpreted this second requirement tu mean loss of offsite po~er to all tttree Units ~
i'23UU-)U
(
87)
issues nI ~ IILI<<1LIt~
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~
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SUIKAKY fAULt. UF SUUCAILGUKY llfttLNIS SUUCAiftiUKT 213UO F Inufngs Corrective Actions kfVISIUN NUKULK: 2 Pnon K ttt nf 9Q fleIIIent 213.2 - UFN (Continued )
fne test result packages reviewed by the evaluation lI am dlu nut contain any tI etc to tneet tiIe rr<<n Ita'~nt (1) above.
For connitaettt (2),
IVA has conducted loss=of Offiiti-pnwel LestS On 4 UOIL b4SIS Only.
Uiesel generator loading, Including the aeqree of coatnitlnent tu Aic safety Uuide 9, Is discussed in Subcatequry Report 246UO, flement 243.0.
o ftIe tact cu<<nnar'v Ionuer
<<4 lfi kit I lertr1cal Svc tern Normal Auxiliary,.Power Systeal
( IVA-9)," of
'Seftlont 4.4 of iile FSARI silpulaies to (1) denunstrate loading and vultaqe requlation design ob3ectlves under design criteria loading (I.e., under the aost degraded conditions) anu (21 verify-short-circuit and Inverse-tice protection of all 4 kV c!I'cul't ilt'eaket's supplying pow r to class 1 bo rds ~
ltle LLS L resuI t paek4gL'S fOr lent 7VA-9 4nd Reies t kf-9 did not Incluae any tests to eeet the above StlpulatlOnS.
It IS nut feaSible tO Verify by teSt thi: loadinq and voltage. regulation under the InOSt degraaeu voltage condition.
However, Section 8.4 of tile'FSAR ctatec lnat iVA hac nerfnr@nu Vnltane Itrnn analyses to verify tilat ttle AC auxiliary po~er systeal'S I,ap4ble Of Supplyln'g Svl I ICICOL Volt49C Lo successfully start anu run all safety motors without tranSfer.to unSite Iuiesel) po~er for.
noralally'xpected systcwn lo4alnq.
Uechtel Norttl Aeerican Power corporatiun (UNAPc) nas performed a load flow stuay for toe aueuoacv uf the Al'uxi 1 iarv nnweI S<<Stem ln ttle study, UNAPC tlas Iauntifieu the requireeents of
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223UU-IU (UU/13/Ul)
Issues AIIAL'INLET B Sueekf IABLI. UF SUBCATLbukr LLM.HIS SUBCA IEUUkY 213UU F Iud lngs Corrective Actions kEVISIUII klNBEk: 2 Page 0-19 of 29 E)ement 213.2 - BFII (Continued)
<<Itn reference Lo FSAk stipu)ation (2), lt ls a)so not feasible to verify the short circuit rating of the breakers ln Lhe p)ant.
The short-circuit capability of the breakers Is tested ln the manufaCturer'S plant and certified.
Ihe TVA L.)ictrical Engineering Branch determines tne rating of Lhe breaeers required for the p)ant frum short-circuit studies.
Inverse-time overcurrent relay cuordlnat lun study are prepared by the 1VA Protection Analysis gvuup, and the UPSO engineering group ca) lbrates the relays un a routine bas'IS ~
o The test sumnary under Emergency Equipment Cooling water System (IVA-4)," uf Sectlun 13.4 of the FSAk, stipulates to verify the capability of the SyStem tu automatlca) ly supply raw river ~ater tu the assigned receivers upon Initiation by an accldenL signal or by signa) from the assigned receivers.
fest IYA-4 did nut Include any test to verify the above stipulation.
iiowever, the emergency equipment cooling water system (ELC<<) nas been tested for automatic initiation by an accident signal during the preuperatlonal testing of the dlese) generators.
A)so, In accordance
<<Ith 51-4.2.8-6l, the EEC<< system Is tested once every b months fur automatic Inltlatlun on raw cooling water system dlstrlbutlun system (assigned receivers) lu<<
pressure.
While reviewing tne test results fur kO-J)-3, unit 2, the evaluaLlon team noted that Lest steady-SLate voltages for diesel generators A, B, C, anu U were hlgii.
Ihe voltage fur diesel generator A was particular)y high, 5250 V, when compared <<1th a num)na) vo)tage of 416U V (kef. Uata Sheets 5.5.U, 5.6.A, and 5.1.A).
Such a high voltage cuuld StreSS the wlnulng of the generatorS and CauSe damage tu the lnsulatlun unless Lhe prob)em ls rectified expeditious)y.
Engineering did nuL quest ion high test steady state vu)tage fur diesel generators.
There remains some uncertainty whether Lhe high voltage actual)y existed or operator error occurred when reading the Instrumentatlon.
Subsequent performance of monthly survel))ance instruction Sl 4.9.A.) resulted ln proper steady state voltage for the affected dlese) generators.
Even though no further corrective actions are required, IVA Intends to Inc)ude the voltage to)eragce ln their restart test procedures for a)1 diesel generators.
Any case of vu)tage exceeding the to\\erance <<l)1 be recorded and evaluated.
Ibis <<Ill be comp)eted befure unit 2 restart.
(CATO ?)3 OZ BFN U3)
??3BU-)B f)
Issuoc ATTACIWUT U SUN44kY TAULE OF SUUCATEGOkY ELMNTS SUUCATEGUHY 21300 F insiinssc Corrective Actions kEV I S IiiU tkvlUEn ~ 2 Page 8-20 of 29 Element 213.2 - ULM a.
The electrical test program and
, planning are inadequate.
ULN
- a. Lngiueerinu participation in tlte uveral! preoperational test program was found to be adequate based on evaluation of t sc t crupinn sdlocumeontc ar t ceres seesuls ts paeika ee (Kefs. 33 and 34).
tilth regard to planning, initial test identification is the responsibility of Engineering <<ith review information received froi,the site test coordinator.
The responsibility for scheduling and planning resides with ttso cits ts ct rnnrdinatnr.witis roview lnfnrscat inn received frou Engineering.
ln recognition of the fact lllat umsi UI the cnglsleel III'JJ IUIIctlons ale UnsclledUIcd support activities, the evaluation team found no evidence titat staffing was inadequate to provide reasonabie test activity support.
UL11 Uone req>> lreli, b.
Enoineerinu narticipation in tiie program ln providing acceptaiice cl lierla ls Inladequate
~
b.
Un ths! basis of tlie cotvtleted ts st nackalses and Pile ruvi<<wud (kefs.
33 and 34), Engineering participation in the UStabllslimeni Of aCCCpldiiCC Ci iterla tiaS fnunii 'tO ue adequate.
b Mnno ronssired
~
( lO/Ug/U7)
AIIACINLNI 0 SUNRAY TABLE UF SUUCAILUUHY tLENLNIS SUUCAIEQIRY 21300 HEVISIUN NUNUEH: 2 Page U-?I of 29 issues F lndlngs Corrective Actions Element 213.2 - BLN (Continued) c.
Engineering participation regal ding the COnduCL Of the tests and the revie~ of the test results ls inadequate.
- c. Ihe packages reviewed included scoplng documents and Pils.
Engineering participated during testing on an ds needed basis for observation and guidance.
fest results
- packages, including Pils and acceptance criteria, were reviewed and documented by Engineering.
The evaluaLlon team also found a number of procedural deficiencies or evaluation Inconsistencies.
Ihe procedural deficiencies or evaluation Inconsistencies ObServed by the evaluation team are not significant and do not Invalidate the overa11 adequacy of the Engineering participatlun ln the preoperatlonal test program.
Several examples of the types of procedural deficiencies or evaluation Inconsistencies observed by the evaluation team are cited below:
o Fur IesL PT-EU-Ul, unit 1
"IvAUffslte (Preferred)
Puwer System (Unit Uuards),"
a change was made without pruper documentation for the disposition of Oeflclency UN-4.
Ueflclency ON-9 was encounLered at test steps 5.3.2.U and 5.3.2.14.
Change number CN-14 <<as issued to disposition UN-9 but this contained only step 5.3.2.8.
Also, test instructions for step 5.3.2.14 did not reference CN-14.
Engineering coaeent I on page 2 of the approval form is still open.
Scoplng document step 1.2(g) states, "when that feeder voltage has been restored to 90 percent of nominal, ACU 52N-151 will automatically reclose."
Sections 5.5 and 5.6 of the test results package did not include any steps to verify Lhe voltage.
c.
Ihe preoperatlonal test program has been suspended and all conpleted tests will be redone when the test program ls reactivated.
with this preface, the emphasis of the corrective action <<ill be to improve the existing program to mlnimlae procedural deficiencies and inconsistencies within the Bellefonte preoperational test program.
Though the identified findings of this report >>111 certainly be retained and specifically applied to each Individual
- test, where appropriate, the existing documentation will not be corrected since It wl11 be completely redone.
Ihe following steps will be accomplished to improve the overall test prugram:
- 1) within ONE, a) ULN-spec(f Sc engineering procedures will be developed to ensure all aspects of preoperatlonal
- testing, Including documentation, Is ha'ndled ln a quality manner (this will include ensuring that design criteria in the FSAR and test documents are consistent.)
b)
UNE test representatives will be trained In the use of the procedures.
Per NEP 10.4, the scoping documents are now ConSidered a desIgn output document requiring verification of technical content and are to be maintained current.
This wl I 1 be Implemented upon reactivation of Lhe pieoperatlonal test program 223UU-IU
/U/)
ns snC<W.N<
0 MEANT TABLE UF SUUCATEGORY LLLH<.NIS SUHCATEGURV 213UU REVISION NOHBER:
?
Paso k
O'J C
'Jw
'J%
I
~ L M ~
CJ Issues F Indlngs Corrective Actions E!~nt 2I3.2 - BLH (Cunt!nueu)
Fur fest PI-TL-UIA, unit I, "Solid State Contrui System (Ulesei Generator Loading Logic)," no environmental condition was stipulated, although the
.scoping document required -that area environ-mr<taI COnditlOnS muSt be maintained within the tOieranCeS specified In FSAR Table 3.i1.1-2 for normai conditions throughuut the test period.
In Section 3.0 of the SCuPfng dOCument, It waS Stated that TeSt PT-EJ-OI, I?U V Vital AL Puwer System," should have been completed to provide the required power.supplies to ghm soi id s tgt~ controlr system+SKS)e Test PT EJ 01 has not yet been completed.
To clear Ueflclency Oil-3,
<he scqueiue controller card was wephced without pruper dOCumentatlOn.
The methOd by whlCh general Englneerfng coenents are resolved is not evident.
o For Test PT-IL-OIB, unit', "Solid-State Control SM<<em (Alarm Ve~<fication' gppendlx A re'e"e"c-d Test Scoplng Uocument PT-IL-01.
Tt<ls document did not address alarm ver ification; it dealt only with Test Pl-IL-OIA.
For disposition of Ueflclencies UN-6, UN-IO, and UN-II, changes were made without proper documentation.
2)
All preoperational testing is'ciledu led to bc accomplished/reevaluated.
3)
<<1th HUC PR, admlnlStratlVe prOCedure BLA-?.4 will be revised to ensure procedural deficienoies and Inconsistencies are,minimized.
4)
A special Independent evaluation team will be assembled by i<SO stafc to verify that program requirements are impiemented.
the above actions should minimize the procedural deficiencies as noted
<n I
Ihe corrective actions will.be completed prior to fuel load.
(CATU 213 02 ULN Ui)
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Ti<e root valve'o 1<'CV-IPI-010 was placed on hold "Exception."
In the disposition of Lxceptlon EN-?, It was stated tl<at this unresolved
. Item did not affect the test.
The test package did hl I <
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of the hold order.
For the disposition of Ueflciuncles UN-l, Uii-13, and Uii-i5, changes were maoe withuut Proper documentation.
There eras no evidence ti<at Engineering general connents on the test results package were resolved.
After the issuance of the test scoplng document for Test PT-GC-OIB, a few change sheets
<<ere Issued.fur Pi-i'c-01, even though these are related to PT-GC-OIB.
Engineering dispositioned Test Ueflclency report PT-22 (UN-15) as unacceptable.
Ueficlency UH-15 haS been closed by installing resized nuzz les, but Test Ueficlency Report PT-22 has not been closed.
?? IHH-IH i<hi/13/0/I
AI IACltttLNI 0 SUtt>tAHY TAttLL UF SUKATtUOHY ELLttENTS SUKATEGOHY 2I300 REVISIUN NUttttEKL 2 Page 8-23 uf 29 Issues Flnaings Corrective Actions Ele>>ent 213.2 - BLN (Continued) u For fest PT-YP-Ul, units 1
ana 2, "Intake Pu>t>ping Station Heating anu ventilating System," the fan >>otor HPtt nas not been recoruea as required by paragraph 5.8 of tt>e tesL scoplng uocu>>ent.
Paragraph 5.8 has been Indicated as part of "prerequlsites."
In actuality, tttls paragraph.should be part of the test.
The test results package did not aaaress the environmental condltiuns ln accordance with tile test scoplng docuoents.
Ueficlency UN-2 should be referenced to step 5.1.4 at>a not to step 5. 1.5.
Paragraph 4.2 of the teSt scoping aucu>t>ent required an alarm in the main control ruom for high 11>>IL ther>>ostats In each essential raw cooling water (EHCw) pu>t>p room.
lhe test results package did not Include any step to verify this.
o fur lest PI-VG-Ul, unit 1, "Uiesel Uenerator Ouildlng Lnvirunmuntal Control System," >>ethod by <<hlctt general engineerIng cu>nt>ents were resolved is not evident.
Step b.11 of tne a'cceptancu criteria st>auld reaa, "tt>e set points were correct to within i3'F" instead of "t3x "
u fur lest PI-NF-OIC1, unit 2, "Fuel Handling Equip>t>ent (SpenL fuel Rick Urag lest," paragraph 3.1, under "PreCauLiunS," lt waS Stated, "AVOid eXCeSSIVe actuation uf grapple>>echanlsm wnlle dry.
A limit of (10) cycles of the fuel grapple ln one hour ls recon>>ended before Ltte grapple>>ust be I>nt>ersed ln, or sprayed with water fur lubrication."
Test scoping aocu>t>ent Pl-NF-Ul ipecifieu a
11>nit of 10U cycles, but uld nut stipulate any Interval tl>>e, No appendix has been adueu to the test, results package for "Test Hecord Urawi'ngs."
o for IesL PI-NF-OIA, unit I, "Fuel Handling Equip>t>ent, Fuel Storage ttanullng oriugu, ana ttew Fuel Elevator,"
aisposition of Ueflclencles UN-9 at>a UN-15 was made without proper uucu>>entat ion.
The >t>ethud by which general Engineering co>n>>ents were resolved Is nut evident.
ls'Suds AfIAObttttf It SutVUikY TAULL UF. SUUCATLUUkY LLLttEkf>
SUUCATLQURY 21300 F ind fngs Correctl ve Act fons REVISIUtt hUttUER' Page 0-24 of 29 E1ement 213.2'-
BLtt (Contlnuedl fur fest Pf-RF-UIA, uniii. 2 ~,
Fuel tianul ing Fquipment Fuel Storage ttanallng Uriuge, anu,kew-Fuel Elevator,"
actuators fur fimlt switches LS-3Z anu LS-33 were not installed but necessary stuns tu pelfore the tests were aaueu.
Ihe,test reSults package uld not include snv sl t lian ttnis lie t fnr
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5lel lar ly, no action,l tee;1 1st was lnicluaeu.fur iiie lnsiallaiion of PFU relavs.
Appendix E (lest kecord Drawings) did not include Stearns Rogeis Urawlngs L22355, 'Sheet 96,.as referenced ln Ueflclency keport TUR-4.; For tne aisposltlon of, UeflclencyiU-11, changeS were cade wfthout.proper dllcltmentat tun Fur TeCt PF'F Olk iinlt
'l ctnnc 5.4.21 to 5.4.36 have beett changed to accotttodate the dlBINiy ' ue I asscmv Iy be ifig lol a ted ifi tile fUe I clur4ge racks.
Fur unit 2, similar ctianges were not cade.
0 For lest Pf;EU-OIAI Rl, unit lt "125V Class 1E;UC Vital Po~er System (System fest);" Appendix A of ttie P fl chnula 'refninncn Tnct Scolplnii tiocuimeni Pr EtJ OTA not Pf-EU-UT.
FSAR Section-14.2 should also be referenCeu ln Apperia 1 x 'A; Section 4.0.of the test scuplng uocument stated, "Hefure start.lna ttie test',
ttie battery initial conditions..., requirements uf'paragraph 5; I of ma innrn l ll 4 It ct n
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Also, the test scoplng document stated itic inermumeier accuracy as a I-F, wnereas ine Pfl,Stated the aCCuraCy tO be i 2'F.
SerVICe teStS Should reflect ttie baLtery's ability to satisfy the deslan requirements (battery duty cycle) of the dc system.
o For fest PT-EJ-UI, KU, unit 1,, "12UV Vital AC Power
- System, the'est scoplng uoctXPent t'eferred to fest
,TYA-16 undir Section 4, ".Prerequlsltes."
.The correct refereitce shuula be fest Pf-EU-01A.ana 8.
Also, this documenL aid not reference ttie FSAk.
In addition, the PTI did iiot reference ttie lest scoplng document or the F SAR.
77 JUt)-10
'(UU/1J/UI )
Issues AlIACINL<<I 0 SUHHAHT TAULL UF SUKATLUUHY LLLHLllfS SUKAfEUUkY 2)300 F lnuings Corrective Actions HEVISIU<<<<UHUEH: 2 Page 0-25 of 29 E)e<nent 213.2 - BLM (Continuea) o Fur lest PT-IV-U), Uraft I, units I anu 2, "Lnviruns Had)ation Huniturlng System,"
Appendix A did nut reference the test scoplng document or the FsAH.
The aucument Itself did not reference the FSAR.
o For lesL PT-<<U-UIA, Uraft 4, "Uecay Heat kemoval System (compo<rent checkout),"
the decoy heat remova) system >>as divided Into three separate tests:
Vf-<<0-0)A; Pf-<<U-UIU, "Uecay Heat Re<naval System (Fuel Puul Support fest)"; and PT-<<U-U)C, "Uecay Heat kemuva)
(Hut Functional)."
)<<<>>ever, there >>as only one lest Scuping Uuc<nnent, Pf-HU-01.
the docu<nent aid not indicate the portions applicable to each Individual test.
The docunent needed a revision to reflect all the re<)u)rements of FSAR Section 14.2.
Valve nu<nbering In the scoplng document did not agree
>>Itn the Pfl.
Ihe PTI dia not reference this document or the FSAH.
o For fest Pf-KL-UIA, HU, "Essential Ra>> Cooling eater (Ekc>>) system (FuncLlonal Pkg 1)," the Eckll system >>as aivideu Into three separate tests:
pf-KE-UIA; PT-KE-018, "I.ssentlal Ra>> Cuo)lng Hater System (Functional Pkg 2)" and PI-KE-OIC, "Essentia)
Ra>>
Coo) Ing eater System (Flu>> Ua)ance)."
There >>ere three tests even though there >>as only one Test Scuplng Uocument, PT-KL-Ul.
The scoplng document uid not Indicate the portions applicab)e to each Individual Lust.
Steps snuu)a be added to the Pfl for Test Pf-KE-UIA fur auto<nat)c s<<utuo>>n of all operating
. EHC>> p<nnps ana subsequent startup of all EHCw pumps un a simulateu loss uf offslte pu<<er to agree >>1th the scuping docu<nent.
Sect)un
- 5. I, "Unit I Test (under Unit 2 ConstrucLlun)" of the teSL SCOping document shuula be aauea under "precautions" of the pTI.
fhe scuplng document uiu nut address the environmental conditions, F5AH Section 14.2 <<as nut referenced In Appendix A of the Pfl.
v'I <' <<
I <<
<anil
issues Alldl'IPIINI 4 SUHHART fAULt UF SUUCAlttiURT LLLtIL'NIS SUUCAitIIUNY 2 IJUQ F lndlngs Corrective Actions REVISION NUMEN: 2 Page LI-ph rlf pg flement pl \\,p BLN (I'ontlnuadl o
Fur lest'PI-IL-UlC, Uraft Z, "L'ssentlal Raw Cuollrig water Systeln (Flow Ualance),"
surde
! tees of the data shiets for ttie 1'l Flow Requirements Uata did not agree with tile teCL Codplnn rdICICCrCrient tal laS "Alignment for Flow Ualance Test.
o ln many instances, a preoperatlonal test for a systeln was dlvlded into multiple preuperatlonal
- tests, but tnere waS Only One teSt SCOplnu dOCument fOr the SyStedi.
lhe document did not lndlc'ate portions Anni tndhlsI tn aden lnrttrrtrrrrcl tact c.. nfl
>I
~
c
...~
4 Jurlru I ~ lb VIV IIVC
~ uICI CIICu )CVPIng QOCumenLS WILn revlslons ln Appendlr A.
None of the Plls referenced environmental conditions.
Some of the scoplng documents also did not reference environmental condl tlons.
u lhe methud by which scope document changes have been
~ ncu porati d into tiie Pl ls or vlcc versa was noL evident.
o Some Pals did nut reference the applicable FSAR SeCtiOn In Appendld A.
Unly one Pll referenced FSAR Snot inn id u ln Annanrllc A, Srrrrra nf tha cCOnlnn documints did not reference the applicable FSAR Se C L I0 II ~
PP NNI-lN fUN/1S/U/I
Issues AlIACttttLNI 0 SUIVInkY fAULt. UF SUUCAIEGONY ELEttENTS SUUCAIEGUkY 21300 Findings Corrective Actions REVISION ttUttUEH: 2 Page 8-2) of 29 Ele<nent 213.2 - SLH (Continued]
d Ueviatlons to preoperatlonal tesL aCCeptanCe Cr lter la were, aCCepted by Engineering
<<I thout gust Ification.
(Cl indicates written justlfIcation ls necessary.)
Uocumentat ion of the Engineering evaluation uf pieoperatfonal test devi atluns (def ICienCleS) waS inadequate.
<t. Iu evaluate Issue "d," the evaluation team reviewed all d.
pr<<operational test deficiency reporls processed to date.
Uuficlency reports were dlsposllluned on a printed furm identified with a sequential number preceded by PT, I.e.,
Pf-Ul thruugn PI-UU.
ttitttfn this group, 35 Pfs were tound to have an "accepLable deficiency" disposition.
Ihe baSIS fur aCCeptanCe Of theSe deflCienCleS waS provided In all cases.
Ihe evaluation team grouped the arceptance basis Into four categories:
I. Acceptance based on engineering judgment
- 2. Acceptance based on satisfactory retest
- 3. Acceptance b~sed on ECH
- 4. Instruction error total As noted ln the corrective action to issue c, the preoperatlonal tests for Uellefonte are scheduled to be reaccomplished.
Therefore, these identified deficiencies will be voided and no action will be taken to resolve the specific deficiencies.
- However, the lessons learned will be factored into the procedures and training program as outlined ln the corrective action to Issue c.
Furthermore, supple<nent to NEP 3.2 requires engineering judgment to be documented by providing technical justification for the acceptance uf test deficiencies.
The corrective action will be completed before uttlt I fuel load.
(CATU 213 02 SLN 02)
Acceptable deficiencies placed In categories 2 tt<rougtt 4
<<er>> resolved or corrected by clearly documented mett<uds.
Ihe remaining deficiency reports were given an acceptable disposition on the basis of engineering judgment.
Ine evaluation tea<n found nO requirement ln ttie applicable procedures tt<at defined or addressed tt<e extent uf written tecttnlcal justification required to Suppart a decision based upon engineering judgnent.
Io evaluate this issue, the evaluation team reviewed ANSI N4b.2.11 which states, ln part, tt<aL design activities be pr'eSCrlbed In "... written fOr<n, whfCh pruVideS adequate cunt<'ul and permits reviewing, ct<ecklng, or verifying tt<e results of tne activity by personnel wtlo are expertenced ln the subject aCtlvlty."
fhe Issue uf adequate tect<nical support level fur technical 3ustiflcatiun of euqlneerlnq 3uugnent ls also addressed In a supplement to NLP-3.2 ~
ft<e supplement to ttEP-3.2 requires that Ltte written basis for an engineering Ju<t<t<nunt be... sufficiently clear to permit anott<ur engineer vers<:d in tt<u parLIcular discipline to understand Lhe preparer's thuughl process."
/0/)
0
Issues AiIAuviLNI U buiuotNY IABLL UF SUBCAftOOHY LLLHLNIS SUOCAfEOOk Y 21 JuO Flntl)nits Currectlve Actions BLVh,)UN NONBLk: ?
Page B-?U of ?9 Element 213.2 - BLN (Cont)nued) e.
rPer ipnera i finn 1ng.
Un the liaSIS nruV)ded by ANSI N45 2 11 and the SurpP)~ rt tu NLP-J.2, the evaluation team found that a signlflcalit no~acr
<<'f the dl.f)C)eric)es g)VCii atri aCCCPtab)C dispusit )un llad Insufficiently duCumented teclinlcai just)f )cat)un for acceptance.
e.
)lie evaluatiun teen found discrepancies in the acceptance cf)tel'Ia aionng test scnplnn duct>monte pf Ic and the Fspk fur lusts P)-EU-OlA, Pf-LJ-U), and Pf-KE-U)C.
In a<<dd ~ t ~unt tlict e iias no statcirertt III 'tile al.l.cptance criteria of the test results package for lest Pf-VP-Ol to demonstrate eiectricai independence as stated
)ri FSAN Sect)on 14.2.
e.
1VA recogn)zes that FSAN Cliapter 14 is n,
~ ra n
~
<<u ~ << ~
<<aalu fne corrective action plan Is as follows:
I)
Incorporate the proposed major reV)SIOn tn Clianter 14 Of thn FSAk 91 CnV ~
~nn vntrl h.
~
~
~
. C
<<rr<< r<<l<< ~ It lry tc~l CEII II Ul llle
)dent)fled findings ln the BLN Preop fest Beculils Nanagement Fiies (maintained by UHE-NEB Preop Section) to-be reSOlved upon reactlvat)on of test program.
31 Encllvn thrnnnh rtn<<<<innocent lvn.,lv I ~
of.procedures and tra)ning as proposed ln corrective action to
)ssue c that the requirements/objectives/metliods, etc.t for the various preoperationai tests are un)formal)y and accurately vn-n t n l it tC t
n n
~
~ <<lr<<I tell tll 0 ~
~ al
~ cl lc<<<<<<l,url'cnl hr
)lie corrective action w)ii oe comflleted before unit I fuel load.
(CAID 213 02 BLN.03) 2?JBU IU (UB/13/U/)
issues AlTALIINLNT 0 SUHtQHY TABLE UF SUBCATLGUkY LLLMLNTS SUBCATEGUkY 21300 F Iud iuqs Corrective Actiuns kEVISIUN NUNUEk: 2 Paqe B-79 uf 29 Element 213.2 - BLN (Continued)
Ine evaluatiun team considered the starting of standby exhaust
- fans, In the event of CU2 simulation for completed lest PI-YG-01, to be a design error.
The steps as written for the preoperatlonal test instruction PT-VG-Ul allows the startinq of standby fan and then stoppinq the fan by simulated C02 Initiation.
The C02 logic Including the stopping of both normal and standby fans simultaneously was tested in Test PT-GC-018 - Fire Protection System (OG Building).
The corrective action plan is as follows:
The appropriate steps In Test PT-VG-Ol will be clarified to indicate its intent of stopping the runninq fan and to record the starting time of the standby fan.
A statement will also be added that this step and the test are not to verify the COP systen logic.
A further statement will be added to Indicate that COP loqic and equipnent
( I e PE-2 relay)
<<Ill be tested ln test PT-GC-01B.
The corrective action <<Ill be completed prior to unit 1 fuel load.
(CATO 213 02 ULN 04)
S
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER:
2 Page C-1 of ll ATTACHMENT C REFERENCES 1.
Sequoyah Element Report 213.2, "Inadequate Electrical Testing,
- Planning, and Electrical Participation; Deviations to Preoperational Test Acceotance Criteria," Rev.
2 (05/07/87) 2.
Watts Bar Final Safety Analysis Report (FSAR), Chapters 8 and 14, updated through Amendment 55 (04/15/85) 3.
Browns Ferry Final Safety Analysis Report (FSAR), Chapters 8 and 13, Amendment 31 4.
Bellefonte Final Safety Analysis Report (FSAR), Chapters 8 and 14, updated through Amendment 27 (06/20/86) 5.
Sequoyah Final Safety Analysis Report (FSAR), Chapters 8 and 14, updated through Amendment 3 (04/86) 6.
NRC memo from Schwencer to Watson (TVA) attaching "Supplement tl to Safety Evaluation Accepting Proposed Preoperational Retest Program for Units 1
and 2," (06/18/76)
(BFN) 7.
EN DES-EP
- 6. Ol, Preoperational Testing Documents - Processing, Rev.
1 (07/24/77);
Rev.
2 (10/05/78);
Rev.
3 (05/25/79);
Rev.
4 (10/28/80);
Rev.
5 (01/12/83) 8.
NEB-DI-125-03, Preoperational Testing Documents - Processing, Rev.
0 (07/01/85) 9.
NEP-3.2, "Design Input," Rev.
0 (07/01/86) 10.
AI-6.2, "Watts Sar Nuclear Plant - Administrative Instruction-Preooerational Test Program,"
Rev.
0 (08/10/82) ll.
TVA memo from Cantrell to Those Listed, "ONE Interim Order - Supplement to NEP-3.2,"
[B05 861222 502],
( 12/22/86)
-12.
Preoperation and Review of Preoper ational Test BF-87, Part 1, ll and ill, 12/09/70, 09/07/72 and 01/07/74, respectively, (canceled after the commercial operation of the units) 3726D-R5 (10/09/87)
T'VA EMIPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 RE'I/ISION NllNBER:
i!
Page C-2 of ll 13.
Procedure for P'erformance of Preoperhtionil Tes't BF-100, Rev, 0
(ll/17/71), Rev.
!I (10/11/72),
Rev.
2 (03/13/73),
Rev.
3 (05/24/76),
canceled I>n,ll/30/76 14.
Preoperational Retest Program BFA-70,.Rev.
0 (08/27/75),
canceled on 03'/16/77 15.
-Plant Modifications, Standard Practice,BF+8.3, Rev.
0 (08/80) 16.
Handling of Test Deficiencies BF-10. 9, Rev.
0, (06/28/83) 17.
Postmodification Test Program, SD SP~17,.2, Rev; 0, (ll/06/86)
(BFN) 18.
Restart Test Program, SDSP-12.1, Rev.
0 (01/21/87)
(BFN) 19.
BLA 7.4, "Bellefonte Nuclear Plant, Standard Practice
- Preoperational Test Program,"
Rev.
10
( 12/1',2/85) 20.
TVA Tooical Replort, TR 75-1A, "Quality Assurance Program Description for the Desiqn, Construction, and Operation of'VA Nuclear Power Plants,'"
Rev.
8, (04/09/85) 21.
TVA Nuclear Quality Assurance Manual((NQAth) (06/20/86) Part II, Section 4,.1, "Preoperational Program" 22.
TVA Interdivisional Quality Assurance Procedures Manual for Nuclear Power Plants (IPM):
In-QAP-11,.1 "Preoperat ional Testing" (10/20/86) 23.
TVA Nuclear Performance Plans:
Revised Corporate Nuclear Performance
- Plan, Volume 1 (03/86)
Revised Sequoyah Nuclear Performances Plian<
Volume '2 (03/87)
Browns Ferry Nuclear Performance
- Plan, Volume '3 (08/86)
Matts Bar Nuclear Performance
- Plan, Vol!'umph 4! (03/87) 24.
Samole of preoperational test resul.tS package rleviewed (SQN).,
TVA-15 andi 15RT "Vital 120-V AC'o'wed System" TVA-'l6 Vital 125-V AC Power SyStelm" l
TVA-41 Containment
!Lsolation System'"
A-Z.Z "Residual Heat Removal System" TVA-13Bl "Onsite AC Distribution System" TVA-I "Emergency Glas Treatment',System".
TVA-'18A "Essential Raw Cooling Nater Sydteln"
'VA-30 Condenser Vent System" TVA-33 "Radiation Monitoring System" 3726D-R5 (10/09/87) il:
TVA EMPL'OYEE CONCERNS
'SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER:
2 Page C-3 of ll 25.
Deficiency Reports PT-001 through PT-800 (SgN) 26.
Samole of preoperational test results packages reviewed (WBN):
TVA-1 "Shield Building Inleakage Rate Test - EGTS Functional" TVA-13B "Onsite AC Distribution System (Diesel Generator TYA-13BRT Loading Logic)"
TVA-15 "Vital 120-V AC Power System" TVA-16A "Vital 125-V DC Power System" TVA-16B "Battery Load Verification" TVA-18A "Essential Raw Cooling Water System" TVA-188 "Essential Raw Cooling Water. System - Flow Balance" TVA-18C "Essential Raw Cooling Water System - Flow Balance" TVA-30 "Condenser Vent Systems" TVA-33 "Environs Monitoring System" TVA-41 "Containment Isolation System" W-4.1
".Residual Heat Removal System" 27.
Preoperational Test Deficiency Report No.
PT-301 through PT-574 (02/84 throuqh 08/84, MBN) 2R.
Preoperational Test Deficiency Report No. PT-576 through PT-651 (08/84 through 12/84, WBN) 29.
Preoperational Test Deficiency Report No.
PT-653 through PT-741 (01/85 through 02/87, WBN) 30.
Samoles of preoperational test results packages reviewed (BFN):
TVA-4 TVA-6B TVA-g and 9A "Emergency Equipment Cooling Mater System," unit 1
"Primary Containment Atmosphere Control," unit.1 (Reviewed by evaluation team only for issue "d" of the element)
"4. 16 kV Electrical System - Normal," unit 3
b TVA-20 "Secondary Containment Leak Rate Test," unit 2
3726D-R6 (10/09/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21l300 REVISION NUMBER:
2 Page C-4 of ll TVA-23
'"Environs Monitoring," units 1,
2, and 3
TVA-32
'"Raw Cooling Water System," unit 2
- GE-1 "Feedwater Control System," unit 1
- GE-2 "Reactor Water Cleanup System," unit 1
GE-5
'Residual Heat Removal System," unit 1
GE-30 "Primary Containment Isolation System Test," unit 1
GE-31-2A
'"Standby Diesel Generator A" unit ll GE-32 "DC Power. System," unit 2 GE-32-2
'"DC Power System," unit 3
GE-33 "Unit Prefeir red Power System
( 120 V ac)," unit 1
31.
Samples of preoperational retest resu~lts, packages reviewed (BFN):
'"4. 16 kV Electrical System.(Normal)" unit 1
'"Fire Protection System (Water and-C02)," units 1
and 2
'"Raw Water Cooling System," units 1
and 2
- RG-6 "RX Core Isolation Cooling System," unit 1
- RG-22C "Average Power Range Monitoring System," unit 1
RG-30 "Primary Containment Isolation System," unit 1
RG-31-3 "AC Emergency Power System Operation, ECCS Testing on Normal Aiixiliary Power and Diesel Generator Power," unit 1
RG-31-3 "AC Emergency Power System Operat'ion, ECCS Testing on Normal Aiixiliary Power and Diesel Generator Power," iunit 2 RG 32-1 "DC Power System (250 V)," units 1
and 2
RG 32-2 "DC Power System (125 V)," units 1
and 2
32.
Samples of postmodification test result packages reviewed (BFN):
PMT-08A "500 kV SWYID System as One Offsite Power System," units l~
2, and 3
Reviewed only for issue "d" of the element.
0 3726D-R6 (10/09/87).
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER:
2 Page C-5 of ll PMT-109 "RHR Return Line Orifice," units 1,
2, and 3
PMT-118 "DG Paralleling Circuit Test," units 1,
2, 3
33.
Samples of completed preoperational test results packages. reviewed (BLN):
PT-EB-01 "TVA Offsite (Preferred)
Power System (Unit Boards),"
units 1
and 2
PT-GC-01B "C02 Fire Protection System (DG Building)," unit 1
PT-IL-01A "Solid State Control System (Diesel Generator Loading Logic)," unit 1
PT-IL-018 "Solid State Control System (Alarm Verification)," unit 1
PT-NF-01A "Fuel Handling Equipment - Fuel Storage Handling Bridge and New Fuel Elevator," unit 1
PT-NF-01A "Fuel Handling Equipment. - Fuel Storage Handling Bridge and New Fuel Elevator," unit 2
PT-NF-018 "Fuel Handling Equipment (New. Fuel Storage Racks Draft test and New Fuel Handling Tool," units 1
and 2
PT-NF-01C "Fuel Handling Equipment (Spent Fuel Racks Drag Test and Fuel Handling Tools," unit 1
PT-NF-01Cl "Fuel Handling Equipment (Part 1 Spent Fuel Racks Drag and Index Test)," unit 2
PT-VG-01 "Diesel Generator Building Environmental Control System," unit 1
PT-VP-01 "Intake Pumpinq Station Heating 5 Ventilating System,"
units 1
and 2, common PT-XE-01A "500kV Switchyard System as One Offsite Power System (Switchyard)," unit 1
PT-XE-01B "500kV Switchyard System as One Offsite Power System (Transformers)," unit 1
PT-XE-01B "500kV Switchyard System as One Offsite Power System (Transformers)," unit 1
34.
Samples of preoperational test instructions and test scoping documents reviewed (BLN):
PT-EJ-01 "120V Vital AC Power System," unit 1
3726D-R7 (10/09/87)
T'VA EMPLOYEE CONCI=RNS SPECIAL PROGRAM
,'REP'ORT NUMBER:
1300
'REVISION NUMBER:
2 Page C-6 of ll PT-EU-01A 125V Class lE DC Vital Power System," unit 1
,PT-IV-01 "Environs Monitoring Sys'em,"
un'its 1
and 2
PT-KE-01A "Essential Raw Cooling Water System (Functional Pkg 1),"
unit 1
PT-KE-O'IB "Essential Raw Cooling Mater System (Functional Pkg 2),'l unit 1
PT-KE-01C "Essential
.Raw Cooling Mater System (Flow Balance)>" unit 1
PT-ND-01A "Decay IHeat Removal System (Ciomponent, Checkout),"
~ 6nit 1
35.
Preoperational
'Test Deficiency Report No.
PT~01 through PT-88, (05/79 through 07/85, IBLN')
36.
10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," C'riteria 17 and 18 (07/71 and 01/01/73) 37.
10 CFR 50, Appendix 8, "'Oualiity Assurance Criteria fair Nuclear Power Plants andi Fuel Reprocessing Plants,'"
(as amended 01/75) 38.
"'Quality Assurance Requirements f'r the Design of Nuclear Plant:s,"
(06/76) 39.
Regulatory Guide 1.68, "Initial Test Program for Water-Cooled Nuclear Power Plants" (ll/73, 01/77,,
and 08/78) 40.
AEC Guide for Planning iaf Preoperational Testing
- Programs, (12/07/70)'1.
AEC Safety Guidie 9', '"Selection. of Diese'I Gienerator Set Capacity for Standby Power Siupp lies,"'03/07/71) 42.
NRC Branchi Technical Position PSB-l, Adequacy of'tation, Electric Distribution System Voltage, Rev. 0, '(07/8'1)
'3.
44.
45.
Regulatory Guide 1.108, "Periodic Testing of Diesel Generator Units Used As Onsite Electric Power Syst;ems at Nuclear Power Plants,"
Rev.
1, (08/77)
I ANSI H45.2.11l-1974,
'"Quality Assurance Requirements for the Design'of'uclear Power P'lants,"
(06/06/74)
I Letter from B. J.
Younablood,
[845 860714 832], (06/25/86)
I 3726D-R6 (10/Oi9/87)
~.
TVA EMPLOYEE CONCERNS SPECIAL.PROGRAM REPORT NUMBER:
21300 REVISION NUMBER:
2 Page C-7 of 11 46, 47 ~
48.
49.
50.,
51.
52.
53.
54.
55.
56.
57.
59.
60.
TVA memo from Green to Sprouse, "Preoperational Testing Program Phaseout,"
[L41 820317 818], (03/23/82)
(SQN)
TVA memo from Sprouse to Green, "Preoperational and NCS (Noncritica',
System)
Testing Programs Phaseout,"
[NEB 820512 274], (05/12/82),
(SQN)
TVA memo from Raulston to Campbell, "Preoperational Test Program Phaseout,"
[NEB 820728 261], (07/28/82),
(SQN)
TVA memo from Cottle to Parris, "Operational Readiness Review,"
[A02 851113 016], (11/14/85)
(SQN)
TVA memo from Pierce to Ballentine, "EN DES Certification for Fuel Loading,"
DENEB 800227 209], (02/27/80),
(SQN)
TVA memo from Dunham to Fox, "EN DES Certification for Fuel Loading,"
DENEB 800229 273]
(02/29/80)
(SQN)
TVA memo from Cantrell to Ballentine and Stack, "EN DES Certification for Fuel Loading,"
[SWP 810616 001], (06/12/81),
(SQN)
TVA memo from Sprouse to Green, "EN DES Certification for Fuel Loading,"
[NEB 810701 272], (07/01/81),
(SQN)
TVA memo from D. R. Patterson to Those Listed, "Electrical Engineering Branch Review of Electrical and Instrumentation in Control Systems Preooerational Test," (09/19/75),
(SQN)
TVA memo from D. R. Patterson to Those Listed, "Preoperational Testing Prooram -
lectrical Engineering Branch Review,"
I.NEB 790302 361],
(03/01/79),
-(SON),
TVA memo from J.
A. Raulston to Those Listed, "Preoperational Testing Program - Electrical Engineering Branch Review,".
[NEB 810210 251],
(02/09/81),
(SQN)
TVA memorandum from Raughley to Those Listed, "Sequoyah Nuclear Plant (SQN) - Potential Generic Condition Evaluation,"
f825 870207 036],
(02/07/87),
[B26 870226 457], (02/26/87)
TVA memo from Durham to Those Listed, "Designation of DED Test Representatives for Preoperational Retesting of Units 1
and 2 after March 22,
- 1975, Cable Tray Fire - Test Program and Documentati.on,"
(05/20/75)
(BFN)
TVA memo from Weaver to Mechani'cal Design Branch Preop Test Representatives and Results Reviewers and Their Supervisors, "Preoperational Test Program,"
(03/06/73)
(BFN)
TVA memo from Parrish to Kellegham, "Browns Ferry Nuclear Plant Preoperational Test Program,"
(10/30/70) 3726D-R6 (10/09/87)
TVA EINIPLOYEE CONCERNS SPECIAL PROIGRAM REPORT NUMBER:
21300 REVISION NUMBER,:,2, Page C-8 of 11 61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
TVA memo frcm Durham t,o Benkus (GE), "Preoperationa'1 Testing NIM-1, NIM-300 I
BFN-63" (08/02/71)
(BFN)
INPO Report, Eva iuati on of Tennessee Val 1 eye Authori ty (TVA), Watt,s Sar'uclear Plant (06/85)
Review. oF Desiqn and Con~Figuration Control.on Watts Bar by Stone It Webster I=ngineering Corporation,
.(02/86 Graft)'ssessment of Engineering Design Control for Browns Ferry Nuclear P'lant by Bender, Cole, Laurent, Sabin, (09/85)
TVA Problem Identificatio~ Report by E.
C. Mathews relatinq to test',ino, 'of, diesel generators,
[821 870306 019], (03/06/87),
and corrective ection
[B21 870519 013], (05/19/87)
(BLN)
Letter from R.,
C. Lewis, NRC, to H.
G. Parris, TVA, with attached Inspection Report Nos5'0-390/83-51 and 50-391/83-40,
[NEB 840118 220],
( 01/12/84)
Letter from 0,.
M. Verrelli, NRC, to H.,
G. Parris, TVA, with attached Inspection Report Nos.,
50-390/84-Sli and 50-391/84-55,
[L44 841119-641],
(11/13/84)
(WBN)
Letter from 0,.
M. Verrelli, NRC, to H.,
G. Parris, TVA, with attached Inspection Report Nos,.
50/390/84/87I aod 50~391/84-59,
['L44 S41227 526],
( 12/24/84)
(WBN)
Letter from 0,.
M. Verrelli, NRC, to H,;
G. Parris, TVA, with attached Inspection Report Nos.
50-390/85-10 and 50-391/85-10, (L44 850313 163],
,( 03/1 1/85)
( WBN)
Letter from J.
N. Grace, NR'C, to H.',, ParrisTVA, with attached
- SALP, Board Report
- 50-390/85-05
[L44 850401i00i7 ],i (03/26/85)
(WBN)
Letter frcm D. M. Verrelli, NRC, to H,'.
G. Parris, TVA with attached, Inspection Report Nos.
50-,390/85-19 and 50-39I/85-1?
('L44 850404 460],
(04/03/85)
(WIBN)
Letter from D. M. Verrelli, NRC, to H,'.
G. Parris, TVA, with attached Inspection Report Nos.
50-390/85-42 and 50-39'I/85-33,
[L44 850625 075],
(06/11/85)
(WBN)
Letter from R.
C. Lewis,
- NRC, To H.
G, Parris,,
TVA, with attached Inspection Report 50-390'/82-35 and 50-391/82-32,
[NEB 821110 218 ],
(ll/02/82)
(WBN) 3726D-R5
( 10/09/87)
~
~
~
s TVA 'EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER:
2 Page C-9 of 11 74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
Letter fr om R. 0. Walker, NRC, to H.
G. Parris, TVA, with attached Inspection Report 50-390/85-40 and 50-391/85-31,
[845 850729 830],
(07/19/85)
(WBN)
Letters frcm D. M. Verrelli, NRC, to H.
G. Parris, TVA, with attached Inspection Reports 50-390/84-13 and 50-391/84-11,
[A02 840314 008],
(03/13/84);
50-390/84-28 and 50-391/84-23,
[A02 840515 001], (05/ll/84);
50-390/85-08 and 50-391-85-08
[A02 850402 003], (03/29/85);
50-390/85-33 and 50-391/85-28
[A02 850510 006], (07/05/85)
(WBN)
Letter from L. M. Mills, TVA, to J.P. O'Reilly, NRC, "Watts Bar Nuclear Plant Units 1
and 2 -
NRC OIE Region II Inspection Reports 50-390/83-51 and 50-391/83-40,
Response
to Violations," [A27 840214 019], (02/14/84)
TVA memorandum from Raulston to Those Listed, "Watts Bar Nuclear Plant-Preoperational Testing -
NRC Violation," [NEB 840215 251], (02/15/84)
Letter frcm L. M. Mills, TVA, to J.
P. O'Reilly, NRC, "Watts Bar Nuclear Plant Units 1
and 2 - NRC OIE Region II Inspection Reports 50-390/83-51 and 50-391/83 Revised
Response
to Violation," [A27 840409 012],
(04/09/84)
TVA memorandum from Standifer to Wadewitz, "Watts Bar Nuclear Plant -
NRC Violation," [NEB 840813 276], (08/13/84)
TVA memorandum from Standifer to Those Listed, "Watts Bar Nuclear Plant-Preoperat i onal Testing -
NRC Viol at i on - Test Representat i ve and Supervisor Meeting,"
[NEB 850219 260], (02/19/85)
TVA memorandum from Standifer to Wadewitz, "Watts Bar Nuclear Plant - OE Follow-Up to Preoperational Testinq Violation 50-390/83-51-02 and 50-391/83-46-02 and Inspector Followup Item 390/84-81-01 and 391/84-55-01,"
[845 850314 254], (03/14/85)
TVA, memorandum from Reed to Electrical Engineer ing Files, "Watts Bar Nuclear Plant - Class lE Batteries - Technical Specifications (TS) and Surveillance Instructions (SI)," [B43 850701 936], (06/28/84)
Letter frcm Varrelli, NRC, to Parris, TVA, "Report Nos.
50-390/85-10 and 50-391/85-10,"
[L44 850313 163], (03/11/85)
(SON)
Letter frcm Varrelli, NRC, to Parris, TVA, "Report Nos.
50-390/85-19 and 50-391/85-17,"
(L44 850404 460], (04/03/85)
(SON)
AEC memo from Davis to Watson (TVA), "03/72 Audit Findinqs on Preoperational Test Proqram,"
(05/04/72)
(BFN)
C 3726D-R5
( 10/09/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21305 REVISION NUMBER:
2 Page C-10 of 11 91.
TVA memo fr cm Weber, Browns Ferr'y Qualit:y 92.
TVA memo free Weber, Browns. Ferry Quality
"'Meetin'g with AEC Compliance of May 4, 1972 on As'surance Program" '(05/16/72)
(BFN)
"Meetinq with AEC Compl.iance of May 4, 1972 on Assurance Pr ogram" '(05/16/72) 93.
NRC memo fr'om C. Lewis to H.
G. Parris,
'TVA, ~with attached Inspection Reports 50-438/83-31 and 50-439/83~31.'(AOZ 'S4()105 005], (01/04/84)
(BLV) 94.
NRC memo fran J.
A. Olshenski to S. AWhite,. TVA, with attached Inspection Reports 50-438/86-02 and 50-.439/86-'02'AOZ 860424 004,j, (04/21/86)
(BLN) 95.
TVA memo from A. M. Quals to L. S.
Cox, attachinq "Corrective Action Report BLN-CAR-84-CIZ," [CZO 850301 005],,(02/27/85)
(BLN) 96.
TVA memo fran R.
M. Hodqes to L. S.
Cox, attachinq NRC letter of ll/02/82 (NEB SZ1110 2lS],
and Reports 50-390/82-,35 and 50-391/82-32 related to motor-to-pump misaliqnment
[MEB 821Z27 031'],
(12/27/SZ)
(BLN) 97.
TVA memo from L. S.
Cox, R. MHodges,, related to "Motor to Pump flisaliqnment,"
[BLN 830128 069], (Ol/PS/83)
(BLN) 98.
TVA memo from J.
R. Parr'ish to Those Listed,
'"Browns Fer! y Nuclear Plant
- Quality Assurance flanual," (06/20/72)
(BLN) 99.
TVA memo fr'om Price to Hathcot:e - Browns Ferry QA Audit Ccmpliance Audit 74 Preoperative Testinq; (CI7/22/74)
(BLN) 86.
TVA memo from Patterson to Mechanical Design Files, "Preoperat:ional
- Testing, AEC Concerns - Notes of Mc!eting ir> Knoxville on May ll, 1972" (05/15/7'2)
(BI=N) 87.
TVA memo frcm Weaver to Sprouse and Lacy, '"Preoperational Test'inq AEC Concerns,"
(05/25/72)
(BFN) 88.
TVA memo fran Parrish to Thomas and Kelleqham, "Proposed Modifications to Preoperational Test Program,"
(06/07/72)
(BFN) 89.
TVA memo frcm Patterson to Calhoun, "Preoperational Retesting - 'Revision of Retest Scoping Documents to Agree with RO Preoperational Retest Instructions,"'09/08/75)
(BFN) 90.
TVA memo frcm Russell to Hathcote, "Unit 3 Review of Approval Cyi:le f6r Preoperational Test:
Pr ocedure Documents,"
(11/21/75)
(BFN)
I I
4 1
e il 3726D-R5 (10/09/87)
~
~..
~"
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21300 REVISION NUMBER:
2 Page C-ll of 11 100.
TVA memo from Price to Hathcote Browns Ferry QA Audit Ccmpliance Audit 75 Preoperati onal Test,
( 12/03/75)
(BLN) 101.
TVA memo free R. A. Costner to M. N. Sprouse - Office of Quality Assurance Audit Report 020-A-84-002,
[OQA 840104 513], (01/04/84)
(BLN) 102. Joint Quality Assurance Audit Report JA-8000-02,
[QAM 800222 003],
(01/14-15/80)
( BLN) 103. Joint Quality Assurance Audit Report JA-8000-11, (QAM 801231 003],
( 11/24-26/80)
( BLN) 104. Joint Quality Assurance Audit Report JA-8100-05,
[QAM 811008 001],
(08-09/81)
(BLN) 105.
TVA memo frcm G.
W. Killian to A. M. Quails, Transmittal of QAB Audit Report QBL-A-85-004, (L1750822 800], (08/22/85)
(BLN) 106.
Memo frcm Sprouse to Knight, "OEDC Audit MB0-4," f'QTS 800606 800]
(06/06/80)
(SQN) 3726D-R5
( 10/09/87)
'h b
.]l~
0 Il