ML19341A525
| ML19341A525 | |
| Person / Time | |
|---|---|
| Issue date: | 12/30/1977 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Mondale W SENATE, PRESIDENT OF THE SENATE |
| Shared Package | |
| ML19341A503 | List:
|
| References | |
| FOIA-80-516 NUDOCS 8101260222 | |
| Download: ML19341A525 (2) | |
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LE1TER UHICH TRAf4SMITTED NUREG-0410 TO CONGRESS
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UNITED STATES Q
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OFFICE OF THE NYq CHAIRMAN MN g.p
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The Honorable Walter Mondale President of the Senate Washington, D.C.
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Dear Mr. President:
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In accordance with the reporting requirements of Section 210
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of the Energy Reorganization Act of 1974, as amended by Public Law M
95-209, the Nuclear Regulatory Commission submits the enclosed report, E
entitled "NRC Program for the Resolution of Generic Issues Related N
to Nuclear Power Plants".
M
&W In October 1976, the Commission directed the NRC staff to develop (H
the generic issues program described in the report, and development
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and implementation of the program has proceeded over the past year.
,Nf The NRC program, as developed by the staff, is considerably broader pi7 than the " Unresolved Safety Issues Plan" required by Section 210.
fd It includes plans for the resolution of generic environmental issues,
/"O for the development of improvements in the reactor licensing ~ process, k
and for consideration of less conservative design criteria or operating g,-]
limitations in areas wher'e present requiremants may be unnecessarily restrictive or costly.
The progress repcrte, which are required by i$f Section 210 to be included in future NRC annual reports, may be more W
bli useful to the Congress if they focus on the specific Section 210 safety items.
g The NRC program described in the report provides for the identification of generic issues, the assignment of priorities, the development of detailed Task Action Plans, projections of dollar and manpower h@
costs, continuing high level management oversight of task progress, j
and public dissemination of information related to the tasks as they V
progress.
It should be noted that the safety issues addressed (fd in the NRC program are not " unresolved" in that the NRC staff has 3A~
made a determination for individual operating plants that continued p
operations or licensing actions do not present a significant risk u:g to the public while the longer term generic reviews are underway.
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~ Y, Nc The Honorable Walter Mondale yM The plans described in the report cover all of the most important generic safety issues.
Detailed plans on a number of issues of lesser k
safety significance unresolved on the date of enactment of Section 210 1
will be developed as resources become available and will be described j
in the annual updates required by the statute.
The implementation I
of this program will be reviewed by the Commission.
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PSincerely,f i
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' Joseph M. Hendrie e.y.
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Enclosure:
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80-5I6 Babcock &Wilcox Po..er Generat.cn Group P.O. Box 1260, Lynchburg, Va. 24505 Telephone: (804) 384-5111 May 20, 1980 Mr. Victor Stello, Jr.
Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Re:
Your letter dated April 10, 1980
Dear Mr. Stello:
In accordance with 10 CFR 2.201, I am enclosing the Babcock and Wilcox Reply to the Notice'of Noncompliance which was attached as Appendix A to your letter referenced above, along with a statement of the actions which B&W has taken to address
'the matters raised in the Notice.
B&W denies each of the alleged items of noncompliance contained in the Notice of Noncompliance.
Nevertheless, B&W believes that proceedings under 10 CFR 2.205 would be time-consuming, expensive, and needlessly divert critical personnel and resources.
Accord-ingly, I am enclosing a check, in payment for Items 2 and 3 only, for the total amount indicated in the Notice of Pro-posed Inposition of Civil Penalties.
Very truly yours, hf L*
D.E.
Guilbert Vice President and General Manager Nuclear Power Generation Division DEG/jck Enclosures U
V O
BABCOCK & WILCOX REPLY TO NRC NOTICE OF NONCOMPLIANCE DATED APRIL 10, 1980 In accordance with 10 CFR 2.201 and the instructions contained in the NRC Notice of Noncompliance dated April 10, 1980, Babcock & Wilcox (B&W) hereby files its written statement or explanation in reply to each of the alleged items of non-compliance.
In what follows, B&W will:
- 1) admit or deny each alleged item of noncompliance, and 2) address actions which have been or will be taken which are appropriate to the matters raised in the Notice.
I.
ADMISSION'OR DENIAL B&W denies each of the four alleged items of non-compliance.
II.
ACTIONS The Notice of Noncompliance required that B&W provide (3) the c.orrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further noncompliance, and.(5) the date when full compliance will be achieved.
As noted previously, B&W does not believe that any noncompliance has occurred.
Nevertheless, B&W had previously instituted a series of actions and is continuing to address matters such as those raised by NRC in the Notice of
~~
Noncompliance.
Actions have been and will be taken which are:
- 1) generic, and 2) appropriate to the specific matters raised in the Notice of Noncompliance.
In what follows the generic actions, as well as the specific actions taken which are appropriate to the matters raised in the Notice will be described.
A.
Generic Actions During the summer of 1979, B&W initiated an intensive review of NPG-1707-01, B&W's internal procedure for the processing of safety concerns (PSC) which implements the requirements of 10 CFR Part 21.
This review culminated in the issuance of Revisions 7 and 8 to NPG-1707-01, dated November 20, 1979 and April 1, 1980 respectively, which are designed to improve the over-all effectiveness of this procedure and more sharply define its purpose and applicability.
More specifically, these revisions will provide additional assurance that any safety concerns raised by B&W employees will be reported and processed in accordance with B&W's Part 21 procedures, regardless of the form in which these concerns originally arise.
These revisions, inter alia, specify the contents of any evaluations pursuant to the PSC procedure and contain action-forcing provisions which ensure that appropriate followup actions will be taken with respect to each safety concern which is reported.
Copies of these revisions are enclosed as Attachments 1 and 2.
4 Further, on April 10, 1980, the Managers of all cognizant departments within the B&W Nuclear Power Generation Division (NPGD) issued Management Directive 205 T4 4 assigning priorities for the pr'ocessing of safety concerns within NPGD, establishing evaluation time limits, and insuring appropriate i
notification of customers with respect to safety concerns being processed by B&W.
The issuance of this management directive is a-further step in the continuing commitment by B&W management to monitor the PSC process and insure that evaluations will be con-ducted and action taken in a timely manner.
A copy of this
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management directive is enclosed as Attachment 3.
On December 12 and 14, 1979, the Licensing Section also conducted training sessions.for all NPGD employees to re-emphasize the purpose and scope of the PSC procedure, to explain the availability of this system for implementing safety concerns and to encourage the use of this procedure by all employ'e'es.
These formal training sessions, which included presentations by senior B&W management, will be supplemented from time to time by workshops on specific safety subjects.
Finally; the PSC system has been,.and will continue to be, audited on a regular basis by B&W Quality Assurance and licensing personnel and B&W's utility customers, as well as the NRC, in order to continually monitor the performance of this system,. measure compliance with the requirements of Part 21, and make any additional revisions which may be necessary or appropriate.
B.
Specific Actions Item 1 B&W has undertaken a series of actions designed to improve the capability of operators to manage transients.
Additional guidance designed to preclude operators from in-terrupting high pressure safety injection in the event of a small break LOCA was promulgated by NRC and B&W by April 4, 1979, following the TMI-2 incident.
B&W, in cooperation with NRC, then established special training progams for operators dealing with this phenomenon.
B&W subsequently embarked on an extensive re-analysis of small break LOCA's with emphasis on scenarios related to the TMI-2 sequence of events.
This ef fort enhanced the understanding within the industry and NRC of small break LOCA performance and resulted in the promulgation of a series of additional operating guidelines for small break LOCA's.
The operator response in connection with the Crystal River incident would suggest that these programs have been effective and that the operating guidelines for small break LOCA's have been successfully implemented at operating plants.
The ongoing review of the Crystal River incident resulted in l
NRC Staff recommendations to reassess certain elements of the small break guidelines, an endorsement of B&W efforts to develop l
abnormal transient operating guidelines (ATOG), and a recommen-dation of full utility support for the ATOG program.
These longer-term efforts should further improve the capability of operators to manage transients.
Item 2 This item is applicable only to Davis-Besse.
Analyses for small break LOCA's using an auxiliary feedwater (AFW) level control of 10 feet for the Davis-Besse plant were reviewed in December of 1978.
This review led to the conclusion that such a condition would not result in a significant departure in expected performance from the cases previously itnalyzed with B&W's NRC-approved evaluation model (less than 20*F. peak cladding temperature increase relative to the 32 foot case).
Subsequcni analysis in B&W's May 7, 1979 submittal to NRC confirmed B&W's initial judgment that the 10 foot control level, combined with the high auxiliary feedwater injection point at Davis-Besse, was consistent with the heat transfer assumption preser.ted in the NRC-approved LOCA evaluation model.
Item 3 An analysis of small break LOCA's on B&W plants with reactor coolant pumps running was performed during January of 1979.
These analyses and subsequent analyses confirmed B&W's initial judgment that the pumps running case would not represent a limiting or unacceptable case from the standpoint of peak cladding temperature.
IA should be noted that at t' e time that the alleged h
item arose, the basic assumption throughout the industry and NRC-was that the effects of small break LOCA's would be bounded by the pumps-off case and that the pumps-off case was the appropriate case for analyses of small break LOCA's.
In this regard, it had been assumed that the pumps would either continue running or remain off throughout the LOCA.
During the spring and summer of 1979, B&W's extended analysis of small break LOCA behavior resulted in the identification of system thermal hydraulic conditions which gave rise to a separate concern over interruption of reacter coolant pump operation in a time frame after initiation of a LOCA.
This, in turn, was promptly identified to the NRC and resulted in generic requirements from NRC applicable to all PWR's which are designed to insure that reactor coolant pumps are tripped at the outset of conditions which indicate a small break LOCA.
Item 4 With the completion of the extensive small break LOCA analysis documented in B&W's May 7, 1979 submittal to NRC (see Chapter 6 and the Appendix thereto),
B&W has confirmed its initial judgment that there are no outstanding issues raised in the Michelson Report on small break LOCA's.
e III.
CONCLUSION B&W realizes that the effect!.veness of any procedure designed to identify, evaluate, and resolve safety concerns may be strongly dependent upon management commitments and attitudes regarding such a procedure.
During the past year, B&W has taken a number of significant steps designed to further enhance employee awareness of this procedure.
B&W is committed to improving the use of its procedure and encouraging individual employees to initiate the procedure whencver they feel it is appropriate to do so.
B&W agrees with the Staff that a company cannot ask for un-evaluated suspicions that an item is a safety matter.
In the context of Part 21, a company must, however, rely.upon the judg-ment, awareness, and expertise of the individual engineer to.
initially distinguish the undefined safety question from the substantial safety hazard, and also assure that the quality of evaluations conducted by the company is high,.
The timeliness of evaluations warrants particular effort, and B&W has taken manage-nent action to control and expedite the evaluation process.
As noted previously, B&h has established goals for continuous measure-nent of performance in evaluations. - Moreover, B&W has increased the frequency of internal audits to reinforce the need for timely evaluation and identify appropriate action.
B&W recognizes the importance of the matters addressed in the Notice of Noncompliance.
Needless to say, it has been profoundly influenced by the TMI experience.
From senior manage-ment to the individual engineer, B&W and its employees continue to be committed to improving the safety of its. product and learning the lessons of TMI.
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POLICl ES A!!D f ROCEDURES
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- PG-1707-01 (Rev 7)
,'D s E C T I C'.
SUBJECT t-i s,j C'.T_:' STA';DAT.35 PROCESSIltG OF SAFETY C0!;CERilS I.
APPLICA3ILITY COMPLETE REVISIO!i ALL IPG3 PERSO:;'!EL II.
PURPOSE To provide an orderly and visible process for identifying, evaluating and initiating the resolution of safety concerns related to or affecting f;PGD-
-supplied coaponents, systens and services.
To assure co r.pliance with liRC regulations (e.g.,10CFR21,10CFR50, etc. ).
III.
EFFECTIVITY All safety concerns identified after the issue date of this procedure.
Safety concerns identified prior to the issue date of this procedure may be processed in accordance with this procedure.
ilV.
REFERENCES ItPG-1703 Preparation and Process'ing of Internal Deficiency Report /
.h.
1716-Al Restraint Order / Corrective Action Request Q.),
by 10CFR21 Policy for Reporting of Defects and Noncompliance as Required V.
F0rd'.S PROCESSED (See Forms Section Manual)
Bh*HP-20203 - Preliminary Report of Safety Concerns (PSC)
VI.
GE!!ERAI A.
If guidance in interpretation of the following definition or other aspects of the procedure is needed, consult with Licensing.
B.
The general def'inition of a safety concern as used in this procedure is:
Any itea t;hich has been discovered during design, nnalysis, fabrication, installation, testing, inspection, training, and operations activities of a nu:laar pc.ter plant and which has or may have safety implications.
C.
F:eparting of safety concerns to the customer or the !;RC is not required if 'P3D Licansin; has docu:r.ented evidence that the concern is adequately kno.:n to tha affc:ted I;PGD custcmers in the case of potential significant deficiencies, cr is adequately known to the NRC in the case of potential substar.tial safety hazards.
D.
Fecurrence of a previously rerorted safety concern shall be reported as l l, 3:
a cr.: sarety ccncern.
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VI.
GE*.ERAL (cont'd)
E.
Once a PSC is issued,.the originator may rescind it by documenting the basis in a reco to the !!anager, Licensing, and attaching supporting docu-centation as necessary.
The originator's canager shall indicate concur-rence on the nemo. Appropriate action shall be taken by the Manager, Licensing.
VII.
RESP 0';SIBI' ITIES FOR REPORTIt!G All !!PGD p rsonnel are responsible for originating form BWi!P-20208 when they discover potential safety concerns that are suspected of falling within the definition given in Section VI.B. above.
VIII.
PROCEDURE Refer to flowchart, Exhibit A, for the procedure to process safety concerns.
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EXHIBIT "A" i
P6 v tit, tr e.artte (<J. Try (5It k;ft Is in g-J18C';
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Uten discovering or recetete; a eeoort of a t'stential safety crma a sessrectes sf <atitig.st**n tne eef tettien of SectionT!.8 r
f of tne sr cedere. 6 ese e for. EN. Kith. *Preltsinary Acsort e
HIGNTM of Sa ety toicerns (>tt}*,
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l ee.ie..m and btain reager s sigaet.te on fo Iwic a ti,.g ug.,
accuracy and cc pleteness sf trforretten.
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gg 2 STf 7 24 PLC q
tevle. for adecuacy; if ratesters, reavest afettional trJewa.
ggggg ticfl fron origtr.ater. See f.2te 2.
Assign P*,C r,v:Ter ad its in. Prepare an$ C1strib.te cone' reN and inferriettoi copy I A:etse c.stc*4r of poten.
of ISC ta distribetton Ilstat in **Ste I.
tial strety c>r.cern if g.g, pg 3 % IC*
rt:,t+e: ty cer.tra:t or v.:.It c.*t;+er agrterert. Send As retdred cen=ere e4etteg(s). requestirs atter-cance from (3.*."Is4) ct:y cr lettee to P eager.
the fellowtrg persons:
4 Lt:ststr;. and Secords a Orf 5tnetor of PW Ed'
b Licensing (rgineer atstgned to mandle safety concern c Project Tanate-e91 fwrctlen IIIP IArl= P5(
Others. as necessery, such as Etcensing Section Far.eger.
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( COVit itDO Purpose of the e4ettag:
pit Parager er cestgreen re;relutattie of Plant Ir.tegra.
tioni Quality $$surance.
a) Proxte snierstancing of ccacern b) Determine aspitcablitty of co*.cern to crerating plant and plar.ts in constr6ction STEP 2C [tV34LA1101 c
C4teMne safety syntHceace RUCAT dp (5:stabitsh priority ror e.al ation of cor.cern es 074 evalwatton ad fc11c...p action recetrene ts (seelste 6)
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tecluding assts* ent of restonstbilities aes schedule. Icen.
tify lead organtaatten res:onsible foe follow-up actions.
f) Letcraine f6ading retstrerents sad scarces The Licenstrg Insteeer shall gre;are a sw rary of eeettag e
res61ts and distritste to attencees and incte Itsted in hote 3.
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a Frepare follow-up ACiton i
fian (n.r) (see hote r) as
- ""'th"'"''a-ttA3 ressired by Step 2. Catain Detemtre whether or r.et the res:rted safety concern is I.,w;p a;a oval of tar fror.e-ar. agers reportable oncer feceral res.1stions.
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responstale for actions and f a F.cr.aser, ticetstrg. sna If P5C is not to be evatusted ty Nr:D. forward safety concern to cu
,,,gg,s,t,on.er, as,stribation Itstee in Metecered necessary. sta Pro ett renager function F sject renagerent fun:rton.
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. (Procedure ends testrthte TAP to Lote 3 gg 3,re,3 Cls tribat ton.
Prepare etatuatica report and coter remo. Ctstritrute in teNa'r accorence =tth hate 3.
See s.ste 4 for centent of report.
c t.s for ea16stica report. Decerent t,gress as r.ecessary eitth a feral sistcsttien to titer.str.g (5tep 731 ad c:stritattor. to those 184ted in hate 3.
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- 1 te V;-UG3-CI. f.sv t se l Ltteatte; of action taken, ir E
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- evalwetten retort er.J c:tify the Panayer. Licensieg.
cf a'a wg;tstec ccrrectica:s. at:stions enc ctrer clarificattans.
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POLiClES AND~ PROCEDURES g.,..,
NPG-1707-01
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n EXHIBIT "A" (cont'd)
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u>m CC.l* PC 3,
f 5ft* 71 Ircern ete cmais cc eei.i.e ite origirator. se.ise ym,*
e ali.a tte,,n re;>rt,.,If recatred ard sb,tain cenc.erence 4
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and fr3 teering (see hete 5).
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sewess ese file.
Deterrir-e reporttag strategy, t.e., to ehem, fo *4t. timing.
etc. If the safety coe:ern is teeattfief es a:
- 1. 5.P.ta ntial 12,*. watere e
- te $ peat. I*'te etica cr 8
ca le gpineres to e, sta.st;. ee 4;;snIreiorihte).
Fro 9tei pre.*:e e.a1.e t.se eesort t t*e civis tc* be.d and a;gitcaLIe Project retager.its copy to distettutten Itstei in hate 3.
If writter, ccsf erratian is *n ave Mle nlthen 48 i<oa s from the custorne test t'.e ARC r.es teen I 1 1.tMIT.
nettfied, actify tr.e htC of t'.e safety concern ty tets;' ore.
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- !*;tt T.s s-telegram.
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Nr.tential 5**ete rarere for fcst--e+t la ce atten er 5 ts r
ites felineera te tJSr s't_ 5.h t ier b e:M ier IG1 resartsOe). pre stiy gro.icET.sivaticr. re; ort copy RC d'istettstlen ItsttiI* I Di "':" "'88 *as e alienie emae:t rara;er.ith e es ::. :2t serrte weerM env tr. f.ete 3.
kattfy the hec series rep;rt. la!1cate tire d 44 544ty concem mWn 4 howrs h tMR3r,e. M or telegran mith c:acurrent notification to tre suppiter II
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c er a y
sigaed re,c to Pacager.
Prerere cover ramo and forward with record of pertinent Litensing.
tele;none information or copy of Tht er telegram to tne RTD flee of recet it tiy Dieg.
Gleisten read ar.d distributton listed in hete 3.
t Stoe Feed tr.itiates c4+
$.ts.!t wettten recort within 5 days eltrer firectly to e-ou' re;4rtin9 Detted the h2*. or ela applicable Project Panar,er to custorer ret.tred by 10'fR21.
- ger satsalttel to the hRC. ettb ccpy to distribution Itsted in fiate 3.
2.
Steetf tcent tef tetgent ccser reo andTr are w(10;f R50.55fe) reportable). prepare ith evaivation report to the distributton Itstes in hote 3 and Divisten read.
D11.* fl*J
- 3. Other Beeortable ! tee prer,are cover new and forward PU21 mitt. eva'i.ation re;,crt to the distrttut*en Itsted in hote 3.
Advise custe=1er or htC as requtred.
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kor6-Se;,ortable to9 cert. prepare re o stating disposition.
f attact, evalostion report. end forward to distrthtlon 8 4 8!C' **tD listed in hate 3.
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p f f** tiv N3I"# '">'cs "t: * "" 8'PF .
4tateln P5C file acttre until follo..up ections #re ccrp1sted, II N"-**ELI*'t itsted tr. Ster 11.1.
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Fer 56bstantial Safety Pa:ei Js. trom:tly acttfy the gggg c stWe alth ct:y cf cet***:stton to t'e C6vistan g.,;.y Per s ast reas;ers. C,alsty Isma*:e. tec,ect *. ras;c-ent.
,'.. g g, twing trt'rno*;. Castm Se' vite ars De Weres Ce-ter, biere c.-stcrer has rottf:e: tre ut. : :=tte the Fanager, ttceestas. e sta met tien confir-Jtion t'at tne nr.; tas teta ratHied ty the c steer.
g I.
Ifr all St*er cer:rta!'ie safety c0';c*rs afelse cost.*fr I
gg;g.gp 3g ti letter of flest ceterr.tr.atice ette cc;p to ttreaste; tif fit 10 C.'510*i t y
12 gf Precess ens file, N
a m :. c~.m.e::. ei:c.
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r-pag 4i.Rev7) 11-20-79 1
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P01.lCIES AND PROCEDURES s,.,,g llPG-1707-01
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EXHIBIT "A" (cor.t'd. )
a liOTES:
1.
All correspondence related to safety concerns shall reference file point 205/T4.4 plus the PSC number.
2.
A safety concern that is fou'nd to duplicate the subject material of a previ-ously submitted concern shall be returned to the originator with explanation and copy of the previously submitted safety concern.
3.
DISTRIBUTI0ll:
Originator Records Center l'.anager, Quality Assurance Manager, Licensing Manager, Field Engineering and Services Manager, Generic Projects Manager, Integration Manager, Engineering Manager, Plant Design 14anager, Safety Analysis Affected Project lianager(s)
Other Affected Personnel, as, applicable
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4.
Evaluation Report shall contain, as a minimum, the following:
a.
Description of concern b.
How concern was discovered
- c.
Analysis of si..ety considerations d.
Equipment and plants affected e.
Reportabilityunder10CFR50.55(c)and/or10CTR21 f.
Corrective actions, as applicable, taken or to be taken 5.
QA I anager's concurrence indicates that the applicable llPGD organizations have participated in the evaluation and that an assessnent has been made to determine if changes are needed to the QA Program requirccents (e.g.,
increased number of QC Surveillance inspections, increased number of vendor audits,etc.).
Engineering l'anager's concurrence indicates that the evaluation report has been reviewed for accuracy with respect to:
a.
Components, systems, services and plants affected b.
flature of the defect or failure to comply and evaluation of the safety concern c.
Corrective action
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EXHIBIT "A" (c'ont' a f.0TES:
(cont'd.)
6._ Follow-up action'is defined, for purposes of this procedure, as follows:
a.
To bring deficient items into conformity with requirements b.
To identify causes for deficiency c.
To prevent recurrences of deficiency d.
To raake such other investigations or analyses or take such other follow-up actions as are deemed necessary because of the repeated concern.
7.
The follow-up action plan shall include as applicable:
a.
Actions to be taken b.
Individucls or organizations responsible c.
Schedule for completion including milestones d.
Decision points and alternate actions e.
Funding source
\\-r i
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l G-l D**D D ']k o
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o Page 6 (Rev 7).
11-20-79 w.-n-
. -,. - - -. - - - - -. ~ - - - - - - - -. - - - - - ~ = _ ~ - - - -
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"1 tr.u. t n
.t POLiClES A!!D PROCEDURES
.,.3g l(g -) TECilC1 fiPG-17C7-01 (Rev 8)
S.3 JECT u
CURITY STA!!D'RDS PROCESSII;G OF SAFETY C0iCERiiS Y
Y I.
APPLICABILITY ALL li?GD PERSGNMEL II.
PURPOSE To provide an orderly and visible process for identifying, evaluating and initiatirg the resolution of safety concerns related to or affecting tiPGD-supplied cor.ponents, systems and services.
To assure co:pliance with NRC regulations (e.g.,10CFR21,100FR50, etc.).
III.
EFFECTIVITY All safety concerns identified after the issue date of this procedure.
Safety ccncerns identified prior to the issue date of this procedure may be processed in accordance with this procedure.
I V.
REFEREft ES NPG-1703 Preparation and Processing of Internal Deficiency Report /
Restraint Order / Corrective Action Request a
V.
FOR!!S PROCESSED (See Forms Section Itanual)
BUNP-202C3 - Preliminary Report of Safety Concerns (PSC)
VI.
GErlERAL A.
If guidance in interpretation of the following definition or other aspects of the procedure is needed, consult with Licensing.
B.
The general definition of a safety concern as used in this procedure is:
Any ite :.thich he.s been discovered during design, analysis, fabrication, installation, testing, inspection, training, and operations activities of a nuclear poster plant and which has or may have safety implications.
C.
Reportin; of safety concerns to the customer or the I RC is not required if *iF2C Licer. sinc has decv.ented evidence that the cer.cern is adequately k.c..r. to the affected I;PGD custcmers in the case of pocential significant deficie :cies, or is adequately known to the NRC in the case of potential substantici safety hazards.
D.
Escurrer.ce of a previously reporte.d safety concern stall be reported as
'/
a ne.: sEfety concern.
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. cc jf 5:t-t 1HE t)^RCCE fa LCCK COPA'iY AD'.ti r I sTH AT I VE t.tA.'iUAL POLICIES A!!D PROCEDURES
,y,. g g,
['N f;PG-1707-01
\\/ i VI. - GEf;EF.AL { con 'd)
E.
Once a FSC is issued, the originator may rescind it by docu: enting the basis in a cer.o to the fianager, Licensing, and attaching supporting docu-rentation as necessary.
The originator's manager shall indicate concur-rence on the remo. Appropriate action shall be taken by the l<anager, Licensing.
VII.
RESP 0NSIBILITIES FOR REPORTIliG All !;PGD personnel are responsible for originating form Bk'NP-20208 when they discover potential safety concerns that are suspected of falling within the definition given in Section VI.B. above.
VIII.
PROCED'JRE Refer to flowchart, Exhibit A, for the procedure to process safety concerns.
4
-END-4 I
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f Page 2 (.Rev 7) 6 6E 31-20-79 L
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1.er tat:c:, 5 tea w o..
A M ' ! *.1 $ 7 I Al I '. E * '.' *., Q POLICIES AND PROCEDURES e
'.' ?/ 3 E R N
(
NPG-1707-01 V
EXHIBIT A e
'ensou'.urr' c'<fm (Sti c't 1) e v.
IS' W II'*
I tres t'steeteleg e* recating a etwt c'.e pcteattat se'ety cogeen s.stectes of f alle 3.it
- t e t f t it*:e er Se:ttsevf.s C'8 8 e, t=e ; ecetere. -ere*e fare f.s2.!*1:e *eret *lears esert s
g*.. g ef 1 seats (secerns (f st)*.
I la te,te..tth er.i cuate re ver s ses stee es f u enetrattas ectoracy av: tevleteness e taf t-atter..
- p. !.,
.Att pg A.in.:
! El',.ll iM ii se,te. for ages acys tf ee: esse *,. res.est ersts :ral tr'
-e-stor h 9 erWrater. See h:te 2. Asst C r.m-er! 1el L:CIAS:ta Fre:are ese sistrf t.te t se' cre e 4 te.'a atste c:sy t a.
4 3 As..se c.st.
. se seten.
of pg.e sistriestten Itstet tr 6:te 1.
tiet safety cwter of 578 M sultti ree.tret 6a ccetes:t er sW-B c.st.ree as erset. Seaa 8s reastres, coeve e reette3(s), ree..est**g a ttessaare free '
(tr.:123.3 cars of let.ar te masser, the fe% irs perscas:
Lice sie;. att set: ds a,, Orts,,tas,,tae c,f,Fi,t,,
,,,,,.et ts nae.cle saf ety cancers Can'.ac.
gg,, ;g;,
c1 Preje:t Paaagraat f6actise 5191 Art 6 i Oth,ers,gsg,r,e,ce,ssa,ry, seca as Liceastel Sectism snarager.
as PSC g,g aee; re:restatative of 8 reject g gm
/ I g
[
Eastaterlegi 0.ality Asssweence.
Costa yino Pu ;sse e,f tre setting:
r a) Pre sta e#gerstartteg of cence a t) Ceterstre apolicatt11tf et cencern to caerettet staat and plaats is constewstter./ start a 5 te,c /[ m,m,,,x,'l o teie-iae sa,fes, atf,e,<e.aue i tt e> ist.sitas, terti, si.eee. of u <er.
- e) Score e.e1.ettse and falle...: act e* re.terests (see h:te 6) are.es:cs.tteltt'es saa sc.hesele (0 11.t'0 tac,g81r3. ass.el*ie.
e r t ment c tivy een c;wasste rein sinie es se for faIIc.ai.sp artfv*La ase estatito cart.reet case fsr e
pwtitcatten of Falle p Actica Pian ifAs),
f) Detervlee funetag rusterents an.:, st.rces.
The Liceastag tr3 tater saa11 pre:eee a 64 reer sf seettre resvits an! (1stritate tc attencess est tscse Insted to hate 3.
4 4 Prs:see Fr:1,=-678ctica If erettests) pot ceavenes, the tice-sir 3 t Steaer s' ail e
decreat e*pretriste actt:ss ret. tree te resolve FK. with Plat (SAP) (see Acte 7) a,s, itstrtwttes to these Itstes la ute 3.
ggg; ret. tref ts Stes 2. Ceta enmtt aps,.a1 e* FAP fe mps g[e, j*,
ersvsttle for actiers.e4 06 tate taftreatic'.t frea t%e sess tasticts es me:essary to frce Prager, ttcessing. ens ceTlete the e.a1 etten.
Frrfect re-agesett fo. cts:s.
r l
Ctstrtt te IA7 to hate 3 Detarette 6*wtter er est t*e rep:*tes se'ets coetern is
,g, j d i ste t t.t t sn.
reportable under feastal re;. tat tu.
Prt.tce ta'arratte9 as If PSC is f at to be evalustet by 48 * *;*sers ta'ety ce.cern ratassa*f ts Liceestag fr*
=tts re a to itstributter Itster ta site )'e:t e tager f.nction to custa ve. as deems ee:eveer, esa 8rs s
s srt; east as necessary wits here)
. (Frece:s e safs e.a:.atsc repert. Decire't e
a **r.at e: :estttes ts Liceas'ag '5tes 73) ass Pre:are evalenttom rerrt e=f cc.e. r,=e. ttstettete to e's.rtht'en te 19sse accersence with hate 3.
See kate 4 fae testest et repcrt.
Itstat ta %ste 3.
q-6 r.. e. ett te cete-1re t' U..' > e.~. e-ar tise is e:4:re:
s.t.* :s !
- re-v:. ;3 01. Acesse l ts:s'st*; cf actiea tasen.
t.
t te.te. e.alsette* resort est arrfs t-e r s te*, it:ess **g.
e eggg,73 O a 3 s6; testes correct:ces, at:stu*t e-ct e-ciert*ttattees.
Ct*?'lNIS v
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.e e...i wr rm.ca, 6 m cm oww.y e.m.inenin.w.u.s POLICIES t,ND PROCEDURES w,ew,.n NPG-1707-01 (m
s EXHIBIT A (cont'd')
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OA i t.A.t: Tit.
I E t F *.,7 7 C;7tt FN 1
7 ?Ttt 78 P:ht!!a*
!*:t r: rate curets or reistee with c ts'nator. fe.tse eest.stica report. If recetras. #ed ettate ccecurrence it t
gg.pg3*
(sts atv e en te er ce-e) froa ParJ;e's. C.41 tty Anssrance e
ar-e ts;1r.eerlag (see !. ate 5).
f!!'its frctest er.d file.
+
gg;ge gete-tee repertteg ties. f.e.. te wr.:. f:~at. tt-teg e tc. If the safety ceegern is tienttf ted as 4:
- 1. ?Jttag*tet tegjy *ersef tr' EV e"p.1**cr.etica or ler.tces Meers ti sa U.M.c e.
Wil re;crtatie),
sr:40
.s.sce e.a..etim renet to t*e T,tutstse Past and er tceale Pecje:t rees;er ett% c::p to Ctst'ttatten itstas in hate 3.
f orittes c:r*:estic. is e:t a.alla:1e Ena'.t't ?:04 mitein 43 bc.rs fram tte c str er t*st tte ht* rat tee 9 gjppt ec tt.f,tet. mo,.ttfy the h:C of tr.e safety ce* terr. t/ teltihD'w.
wt it:e e um,m so,1e.15ei sefet~erer, f,. f.re,.
WiIejstil.erec to CTe'y ;.. ::e. i.<--,tten er
.:M t' IIMI rir~C7 tat,it). or. ;Op tec. ice e. i6at te. reoort to t'.e Chistc9 heat and a;;11cette f rgje:t P'a*.a;er with
$GSTA':T AL 5:rrty >A7:Ot My 1r 9
c:ty to distrf tutter Itstes te hete 3.
6:stfy tre AEC Be.les re;ert. Ir:1cete time ef tt-e safety concern mithin if, P Jrs by idle:ncee. Tws er telegre a atth concurrert e:ttf tcatt:n to 19e selter CIVISICM f[,#,'
'h* $$~y'h" ets the p-ocure ent respensitt19ty.
Sigr.e: r:ero 13 Panager.
Prepare cover rem and forward with retorf of Pert 19ent tic ess f e;.
tele; hone infortsattor. cr ccpy cf 70 or telegret to the
~h:1t: Tire of receipt by tht.
Civistoi tees and distettution itsted in hite 3.
sfce kcad tettiates 43-
$ar.it mettten repert etthin $ Cays ettt.ar directly to h~.r regrttegrerted the f.A*. er via arplicable Preject renager to c6ste:M required ty luTR21.
fcr s.t-sttal to the h40, alth co:p te Ctstr1 button listes In h3te 3.
3.
Stef fiort tettete-ey (to:Fass.ssfe) re:eetabte).orecare coser tre ar.4 forward witn ereltattOn re:Cr* te the (1stribatten listes in hote 3 and Elvister Feat.
EVWIIDh 3.
Othe' 8e-:etable Ite9. pregare cc..er re90 and forward MI mith etsivation rencet to the Cist*%tice. Itsted in Ctt.!t DIM hate 3. Adrite cbstorier er het et retwiref.
4.
h:m-te:ertrtle tc cern pre; art tre stattr.g disposition.
- f.,3, g g attaca e.alvatten re;crt. ar.s forware to Ctstributton pq itsted in hate 3.
g g
STEP 78 Matrtain P5C file active entti follew-up acticas are cervleted.
p g.,,.g.
h2ttfp s;; plier with ctpy of
'II"O**I!IIkII nattf tcetic? to cistelbuti:n Itsted in Step 11.1.
I thA(' ei.rA l
titet-C0'.It d':
II f
V 1.
for Sasteattal Safety haracas. o-e :tly r. stfs t%e pg.
r,.
costc e =114 cecy c' r.:tificatt:a to t.e :t.t sten g
yy;
- eef ars twea;ers. t, titty Ass. r :e. r-c;e:t 4 a;c-ent, y,,'.....
Ltce'.ste;. (*;tsce te;,.st: ee 5,.1:e a : tre 'e:or:s
' * *
- l teete*. 6-e e costree t.as *:tt **cs t*e '. :. rec. tee tr.e
- sea;er. Lice-stes..+tg.etttea c:-*te atten test tr e ka; r.46 tetn r. tt'ie: ry tr e c6* tnr.
't* all et*ar re::eter.e str t ct :er t. ervtse caste er s
3.
I r,t.:. a tj letter ef firal cettertretic i.tta c:t, to lite steg.
e
- r. g Ltiitt TO CU5tCa'2 4 f
12 e
f.f f recets ar.0 file.
D.
t: tis 4tt :. Enm.: ;a m.t.
s s.. -
3%O fr?
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Page 4 (Pev 8)
C* JtM*..t T W rid h A etLCOX C0vPtNY Ac'it *. I S T R ATI VE f.*ANUAL POLICIES A!0 PROCEDURES g
gg,,g g g
(
f:P3-1707-01 V) i.Ahlbli k (CCnt'C) fl0TES:
1.
Corresponder.ce related to safety concerns shall reference file point 205/T4.4 plus the PSC nu.ber.
2.
A safety cor.cern that is found to duplicate the subject material of a previously submitted ccncern shall be returned to the originator with explanation and copy of the previcusly submitted safety concern.
3.
DISTRIBUTIO' :
Originator Records Center fianager, Quality Assurance lianager, Licensing I4anager, Field Engineering and Services Manager, Generic Projects
+
!!anager, Project Engir.eering Manager, Engineering
+
11anager, Plant Engineering lianager, Safety Analysis Affected Project Itanager(s)
Other Affected Personnel, as, applicable
/
4.
Content of the evaluation report shall be in accordance with the following:
(a) The requirements of paragraph 21.21(b)(3) of 10CFR21 shall be followed if concern is reportable under Part 21; this format may also be followed.
as applicable, for concerns reportable under 10CFR50.55(e).
(b) For concerns that are not reportable under Part 21 or 50.55(e), the report shall contain the same type of information as under (a), as applicable, and shall also include a discussion of the basis for deter.r.ining non-reportability to I RC.
(c-)
For all reports, include how the concern was discovered.
5.
QA lianager's corcurrence indicates that the applicable IPGD organizations have participated in the evaluation and that an assessment has been made to determine if changes are needed to the QA Program requirenents (e.g.,
increased nu.ber of QC Surveillance inspections, increased number of vendor audits,etc.).
Engir.eering "aiager's concurrence indicates that the evaluation report has
-been revie.ced fcr accuracy with respect to:
a.
Components, systems, services and plants affected.
b.
liature of the defect or failure to comply and evaluation of the safety concern.
c.
Corrective action.
[V
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C; ;fut.1 h t Eat:c A 6
.,.,,, g NP3-1707-01 c.,
)
EDi1 BIT A" (cont'
!NTES:
(cont'd. )
6.
Tcilo.e-up action is defined, for purposes of this procedure, as follows:
a.
To bring deficient items into conformity with requirements b.
To identify causes for deficiency c.
To prever.t recurrences of deficiency d.
To make such other investigations or analyses or take such other follow-up actions as are deemed necessary because of the reported concern.
7.
The follo.i-up action plan shall include as applicable:
a.
Actions to be taken b.
Individuals or organizations responsible c.
Schedule for completion including milestones d.
Oscision points and alternate actions e.
Funding source
+
f.
Specific description of actions or documentation that define closure of follow-up action.
T g.
The corrective actions recomended by the PSC evaluation report.
4 9
h f
Q.)
0 4-1-30 Page 6 (ktv 8) 2 oat
P*
0 D
T l
D THE E E:::b..lLCOX CCMPAl;Y F0(EF.Gh.E:.AT;: S GP.0UP Se 6
d Er.;tr.eering, Customer Service, Project IOnegement s.pV a 3 SElity Assurance Perscnnel Manager, Cepartments of Engineering, Custome* Service, Project Mar.agu ent and Quality Assurance aos ees.s Cust.-
File No. 205 T4.4 All or Ref.
Subj.
Manager. ant Directive - Assignment of PSC Priorities, DateApril 10, 1980 Evaluatica Span Times, and Customer Gotification lw.i....,......................w...,.
b T\\ k C'
ANroved by:
Manager, Engineering Department
-[c g Y!7//h Manager, Customer Service Department Manager, Project Management Department
/./b [4/10 Manager, Quality Assurance Department
-, g2c/m
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/ /
Assientent of PSC Priority and Evaluation Times.
I.
Aaplicabili ty O_
rnis directive applies to the Engineering, Customer Service, Project Management and Quality Assurance Departments.
-I I.
Purpose To provide guidance regarding (1) priority of PSC work, (2) evaluatlon time linits, (3) reports to management, and (4) customer notification requirements for PSC evaluation reports.
III.
Effectivity This instruction shall apply to all PSC's originated subsequent to the issue date of this directive.
Acditionally, follow-up to ensure customer action as described in V-4 shali be effective for all PSC's being evaluated at the time this directive takes effect.
l \\'.
Ins tructions A.
Priorities All PSC's will be assigned a priority by Licensinc folicwinc :Se front end meeting; the priority uill be indicated in tr.e front ens meeting r.inutes and will be reflected in the evaluation schedule acreed c?sn.
l'any factors can affect priorities for PSC wort, but, as a'ceneral guide,
(',
PSC's affecting operating clants should be citen t e hichest criority h
U of any work within SIG3.*..nere conflicts de.cicp bet.-tein FSC's
- n1 following order of precedence will govern:
l
= h t'.e event a Priority 1 SFR gercrates a Priority 1 PSC (cr vice versa),
tr.e re:::nsible manager shali assign the necesscr'y rescurces 10 c r:plete b:th cctivities witnin the prescrited schecule.
a Priority 1 - Operating Plant - High Prcbcbility Event Priority 2 - Operating Plant - Low Probability Event Priority 3 - Plants Under Construction B.. Evaluation Time limits An evaluation co.Tpletion date will be established in the front end reetings 'consis' tent With ' safety significance.
These dates will be shown on the status reports.
A perfomance measurement target has been established to complete 90" of the evaluation reports within the established dates.
Performance will be reported against this target for PSC's filed after the effective date of this directive.
C.
Reports to Manaaement The Licensing Section will maintain status records on all PSC's and will provide a monthly status report to the above Department Managers.
V., Custoner !;otification The following actions will be taken to appropriately inform and involve our customers in the PSC process.
O -
1.
Project Management
- will transmit preliminary PSC evaluation reports of PSC's affecting their plants where it is indicated that the PSC is likely to be reportable.
'2.
As appropriate, Project Management
- will transmit for information final evaluation reports for PSC's affecting their plants, including those that are detemined to be not reportable under federal regulations.
3.
Licensing will recommend to Project Management
- other communications with custorers regarding selected PSC's prior to completing the preliminary evaluation.
This will involve cases where it is clear the issue is potenticily quite significant in terms of evaluation effort, safety im-plications, or possible significant hard. tare changes.
4.
For PSC's where (a) operating plants are affected, (b) a very significant safety issue is involved, and (c) customer action is required, a date will be established, as agreed to between Licensing, Project / Service f.'Inagers, and co5nizant technical personnel, for receipt of a customer com.itment to take the required action.
If such com.iitrent is not re-ceived, the matter will be escalated to fiPGD management for follow-up.
5.
!!ctifications to customers of significant safety issues on operating plants shall be addressed to the utility upper managerent.
O Service Mcnager for Operating Plants
8b4/6 6
el s APR 2 1980 I DIORAflDU!! FOR: John F. Ahearne, Chaiman g
FR0ft:
James J. Cummings, Director b 63 UC
%aen#
4 Office of Inspector and Auditor 3
SUBJECT:
BABC0CK AllD HILC0X (B&!l) IriVESTIGATIO!!S -
REVIEll FOR CRII;IfiALITY During the period Itay 1979 through !!ovember 1979, the Office of Inspection and Enforcement conducted three separate investigations into various aspects of thether Ball had adequately analyzed potential safety problens brought to their attention and whether the natters should have been reported to the llRC pursuant to Part 21,10 CFR.
The first investigation, case number 79-HQ-001, was conducted during the period itay 14-31, 1979, and addressed the narrow issue of whether the artichelson Report", which addressed the inplications of small pipe break LOCAs, was properly handled by B&W. !!ichelson emphasized that the thrust of his concern was not that he was certain that the small pipe break LOCA's that he postulated presented a significant safety hazard, but rather he felt that they had not been sufficiently analyzed. The investigation substantiated that although B&W had received l'ichelson's report, they did not perceive it to be a natter of safety hazard significance, but rather a " valid technical comment."
In sum, the report's significance was not recognized until after its " technical comments" were confimed by the accident at Three I:lle Island (Till).
l The second investigation, case number 79-110-002, was conducted during l
the period July 19-August 17, 1979, and was concerned with how BA1!
handled an internal renorandun written by a Ball engineer in !!ovember 1977.
In the menorandun, the engineer expressed concern that E&t! custoners lacked guidance regarding the necessity for not teminating HPSI during LOCAs and reconaended that such advice be provided.
One recipient of the Demo characterized the natter as a serious concern and suggested that improper operation interruption of HPSI could result in core uncovery and possible fuel damage. Again, this is what happened at TifI.
flevertheless, prior to THI, the BS11 Licensing !!anager felt that the natter raised was not a significant safety item requiring him to inplement BSl! Part 21 procedures. Additionally, another engineer authored a nemo essentially expressing the. view that following the suggested changes could cause ham. Higher officials of BAi! denied 1:nowledge of the nemo prior to Tl1I. They also characterized the issue as being a technical difference of cpinion or dispute.
I....
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l John F. Ahearne,
The third investigation, case nunber 79-110-003, was conducted during the period October 25-flovce 26, 1979, and also was targeted on whether
~
B&W had conducted proper analysis under Part 21 of two natters raised.,
In !!ovember 1977 Toledo Edison Conpany (TECO) requested that they be l
pemitted to lower the steam generator (SG) set point from 10 feet to 3 feet.
In addressing the question P,5W engineers detemined that the original calculations had been at the 32 foot level, but felt that the 10 foot level tus bounded by that analysis.
Other EAW employees subsequently noted that sna11 break 1.0CAs with reactor coolant pumps powered were also unanalyzed. ll hen these ratters were raised, B&U personnel viewed them as not being a safety hazard and, therefore, did not require a Part 21 analysis. B&W detemined not to advise TECO, and flRC that these ratters had not been analyzed. They were concerned that the notice to llRC of the issues night generate an " overreaction" on the part of the flRC. Revised B&tf Part 21 procedures now include " safety implications" (cnphasis added) which presumably would require these natters to be ch~ gj
/
~
reported to the flRC in the future.
Our review of these investigations reveals no evidence of willful cor.Qct or mission by B&W such as to constitute criminality, especially under the regulatory requirments existent at the time.
For example, Part 21 g
nerely required the " evaluation" by the licensee of the existence of a particular deviation which could create a substantial safety hazard and notification to llRC of such a defect if it were found to exist. Thorninre, crininality would be dependent on showing that the licensee, in its evaluation, had determined that one or more of the above stated natters did constitute a safety hazard and then willfully detemined not to report the natter to the fiRC. The discretionary judgment of the licensee is controlling so long as there is any reasonable basis for that judgnent and criminality, should it exist, will still require a showing that the Itcensee willfully did not report a known defect.
It is emphasized that this conclusion is based on the parameters of the three referenced IE investigations, which are still in a "pending status" and, therefore, the substantiation of crininality at a future tire based on "new facts" is not foreclosed. Based on the above, I have detemined that the natters raised, thus far,' do not t.urrant referral to the Department of Justice for their prosecutive consideration, cc: Connissioners (4) l M. J. Dircks, A/EDO L. Bickwit, GC V. Stello, IE H. Shapar, ELD Distribution:
OIA OIA Redding Fortuna RSmith n
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