ML20147F110

Forwards Updated Issues Sheet for Outstanding Technical Issues Re Unit 2,per Request.Sheet Identifies Which Organization Has Action to Complete Unresolved Issues. Response to Employee Response Team Preliminary Rept Encl

ML20147F110
Person / Time
Site:	05000000, Sequoyah
Issue date:	10/28/1987
From:	Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Harold Denton NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
Shared Package
ML082310326	List: IR 05000327/1987027 ML20147F052 ML20147F110 ML20149B937 ML20149C482
References
FOIA-87-726 NUDOCS 8803070239
Download: ML20147F110 (125)

Text

{{#Wiki_filter:I gk2 EICO _M 'o UNITED STATES J4 8 ~,t NUCLEAR REGULATORY COMMISSION j7 l c ey WASHINGTON, D. C. 20655 "%,..../ 0CT 2 81951. MEMORANDUM FOR: Harold R. Denton, Director Office of Governmental and Public Affairs FROM: Thomas A. Rehm Assistant for Operations Office of the Executive Director for Operations

SUBJECT:

UPDATED SEQUOYAH ISSUES SHEET Enclosed is an updated issues sheet for the outstanding technical issues related to Seouoyah Unit 2. The issues sheet is provided per your request in preparation for the hearings with Congressman Dingell's subcomittee. Please note that the sheet now identifies which organizatior. (NRC or TVA) has the action to complete unresolved issues, y y / / / oma s% 'sch"1 Assit1.rt for Oaerocior.t i Offher i f Executive Director for Operations

Enclosure:

Sequoyah Unit 2 issues sheet cc: J. Bradburne #~C

Contact:

J. Clifford, OSP 49-29045 i 880307c239 0803o2 lb hSNNB PDR 76 7 )

( 1 l STATUS OF ISSUES REGARDING SEQUOTjH, UNIT 2 Category Issue A B1 B2 C Corporate Plan X Site Management X Quality Assurance X Integrated Design Inspection X Design Basis Verification Program X Design Calculations Review Civil X Electrical X Alternately Analyzed Piping X Heat Code Traceability X Cable Installation X Fuse Replacements X Ampacity X Fire Protection X Environmental Qualification X Welding X Technical Specifications X g NUREG-1150 X Hydrogen Analyzer Operability X Procurement Concerns X Mainter.ance X Post Modification Testing X Restart Test Program X Surveillance Instructions X Detailed Control Room Design Review X Operational Readiness X Employee Concerns X Allegations X Exemptions X NRC and TVA are in agreement regarding how Category A the issue is being handled and NRC's review schedule is consistent with the licensee's schedule for resolution of the issue. Category B1 NRC and TVA are in agreement regarding how the issue is being handled and the licensee is preparing submittals. Category B2 NRC and TVA are in agreement regarding how the issue is being handled and NRC has under review. Questions still exist regarding how the issue Category C will be resolved.

~. -. .3 sy, 14-8 '? r g%r : RESPONSE TO ERT PRELIMINARY REPORT NS-85-001-001 TABLE OF CONTENTS h I. Pu'RPOSE AND SCOPE ~ 4 II. EXECUTIVE

SUMMARY

AND. CONCLUSIONS i III.-APPRAISAL OF ISSUE RESOLUTION PROCESS IV. DETAILS A. Issue Development and Closure Process Reconstruction B. Response to NS-85-001-001 Conclusions C. Response to NS-85-001-001 Attachment C Questions 1 t i o . p 4 d 3 a 6 ( i p[ t J

f t# M~ I. PURPOSE AND SCOPE s The Employee Response Team (ERT) of the TVA employee concern program investigated a concern that TVA had prematurely closed the issue of visual inspection of structural welds through carbo zine primer at the Watts Bar Nuclear Plant (WBN). This memorandum provides the Nuclear Safety Review Staff (NSRS) response to the ERT investigative report NS-85-001-001 questions and an assessment of the closure process. The memorandum is written in a report format to facilitate presentation and provide a reference basis for any further correspondence. The scope of this activity was to assess the' existence and applica-bility of documentation which constituted the basis of the NSRS clo-sure of the issue in question. II. EXECUTIVE

SUMMARY

AND CONCLUSIONS The NSRS evaluated the ERT investigative report NS-85-001-001 which concluded that TVA had closed prematurely and without adequate justifi-cation the NSRS identified findings related to visual inspection of structural welds through carbo zine primer at the WBN. The closure process was evaluated and is discussed in this memorandum The NSRS responses to the detailed questions contained in NS-85-001-001 are provided in subsequent paragraphs of this memorandum. The responses are based upon correspondence that existed at the time of closure of the issue in early 1984. The NSRS principal conclusion is that closure of the issue was not premature and that a satisfactory justification existed to support the closure. A second substantial conclusion is that, as concluded by the ERT investigators, the treatment and resolution of the issue was untimely and unresponsive; however, the final closure resulted from an-exhaustive and thorough consideraton of the issue and its related facets. III. APPRAISAL OF ISSUE RESOLlTIION PROCESS The practice followed in developing (initial identification and substan-tiation) the issues by NSRS'and subsequent reporting to the appropri-ate line organization management for resolution was the same for the carbo zine issue as for any other NSPS issues. The issue was devel-oped as part of the R-82-02-WBN management review (although it was not a subject of the exit meeting identification'of substantial findings) and was further the subject of a special review, R-82-0 M 1N. The basic issues initially identified by NSRS in mid 1982 wete: 1) that inspections through carbo zine primer had been performed without 3 proper procedures, 2) that documentation to support the qualification of the validity of the inspections was deficient and 3) that devia-tions from the AWS D1.1 code had not been justified nor had NRC appro-val been sought or received. The NSRS statements of the concerns were reasonable and lear; however, the supporting detail confused the I

+ issue somewhat. Just what inspections through primer-(initial accept-ance or reinspection) were the source of the NSRS conce w was not clearly presented in.the NSRS reports. The OEDC initial response to the findings was to deny the alledged problems and set about justifying the technical acceptability of the inspections to NSRS. Clearly from our current perspective the procedures and documentation-were insufficient to support the adequacy of the inspections, techni-cal justification did exist and NRC-NRR had not been informed. How-ever, NRC Region II was informed'through the 10CFR50.55(e) reporting of nonconforming conditions. The divergence of'the responses from the issues after the initial exchange served only to. confuse the issues for both parties. Resolution of the issue was not timely and the failure of the' respond-ents to converge on the issue of documentation and reporting to NRC was the major factor in not maintaining timeliness. In fairness to the line organization, although'NSRS continued to maintain its posi-tion on the issues, no particular urgency toward closure was indicated and the transfer of follow-up and closure responsibility to 0QA in,the winter of 1983 probably delayed the resolution. In several instances, OQA acted to close the issues with 0EDC and was challenged by NSRS-regarding the appropriateness of those actions. A greater degree of coordination between the two offices could have helped avoid this confusion. Starting in the early fall of 1983, the NSRS/0QA coordi-nation was achieved and the resolution followed in a reasonable fash-ion. A complicating side issue contributed considerably to the extended resolution time for this issue. The NSRS had a position and continues to maintain it that when a licensing commitment is not being met or - has been modified by TVA, a specific justification for not meeting the commitment should be provided to the NRC for specific review and approval. The line organization has not agreed with this position and continues to disagree. In the case of conformance to the WBN FSAR commitment to meeting AWS D1.1-1972 in the codes and standards sec-tion, Amendment 47, TVA inserted after AWS D1.1-72, "as modified by TVA General Construction Specification G-29C." The line organization con-cluded that the exceptions were within the latitude provided by AWS D1.1 for the engineer and thus TVA was in compliance with the FSAR commitment. The NSRS position was that specific exqeptions to AWS D1.1 should be justified to NRC in detail and approval requested for the exceptions to avoid misunderstandings in the licensing process. This difference of views needs to be resolved by TVA management to avoid such conflicts in the future. The degree or level of required communication with NRC needs *o be clearly understood at all levels. ~ IV. DETAILS A. Issue Development and Closure process Reconstruction 2 w-- u

i ', ( 's The following is a reconstruction of events describing activities leading to recognition of visual inspection of structural welds t through carbo zine primer as an issue and activities after recog-nition of the issue leading to closure of the concern. Some parts of the reconstruction are deductively concluded from correspon-dence at the various times and simple logic of what any reason-able person could have done under similar circumstances. It is fully recognized that,this reconstruction is not totally rigorous and is done to establish some perspective on the issue. It is not intended that an exhaustive list of all documentation be discussed - only that sufficient to establish the thesis. In December 1979 and January 1980 deficiencies were noted in structural welds of supports at WBN relating for the most part to veld configuration. The corrective action defined at that time was to improve the inspection procedures, review previous docu-mented acceptances and reinspect previously accepted supports with the new procedure. In June 1980, a major nonconforming condition report (NCR 2375R) was generated based upon a sampling of cable tray supports, conduit supports, and miscellaneous steel. Substantial fractions of the sampled supports were initially rejectable against G-29 (AWS DI.1) accep*.ance criteria. The corrective action proposed was to identify each nonconforming weld and repair them to meet the drawing requirements or provide details to engineering for evalu-ation. A series of memoranda ensued dealing with relaxation of the G-29C acceptance criteria for dimensional considerations or veld configuration with very specific criteria relaxation being granted. In November 1980 a second major NCR (2654R) was generated based upon a random inspection of 245 duct supports of which 22 percent had unacceptable velds. The defects were principally configura-tional except porosity was noted. The welds in question had been installed and accepted from January 1976 to March 1980. The corrective action proposed was to reinspect all duct support velds in the auxiliary building made prior to March 1980 and repair them to meet G-29C. im These two NCR's will serve to illustrate the procer s that occur-red and to assess the attendent activities. The NCR's were properly judged significant and were properly reported under 10CER50.55(e). Further, the NSRS concludes thaf the disposition actions of reinspection and requests for and granting of specific criteria modifications were properly achieved. As late as November 1983 NRC took closure action on NCR 2375R for WBN unit 1 but stated the item remained open for unit 2. From 1980 through 1983 an intricate set of OEDC documentation exists which is not all directly referenced to any given NCR; however, it appears that the activity was all aimed at an opti-mal resolution of the deficiencies identified in various NCR's, including 2375R and 2654R. In the midst of all this 3

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activity, NSRS conducted the major management review of WBN (R-82-02-WBN) and a special review (R-82-07-WBN)..These reviews had three findings associated with inspection'through carbo zine primer, R-82-02-WBN-24, R-82-07-WBN-02, and R-82-07-WBN-06. A similar set of documentation to the OEDC set resulted from cor-respondence dealing with~the NSRS findings. The NSRS reviewers determined, by interviewing inspectors, that visual inspections of welds through carbo zine primer had been perfo rmed. It is not clear that sufficient questions were asked to define whether the welds being inspected through primer were for initial weld acceptance or part of the NCR resolution sampl-ing programs. The NSRS report does not differentiate. It is consistent to all documented responses that the welds'being discussed by the inspectors were part of the sampling programs. The NSRS concerns were received at a time when TVA was striving to fully justify the technical adequacy of a very large popu-lation of structural velds throughout WBN. The responses to the NSRS findings basically defended the CONST and EN DES programs and disagreed that the programs were deficient in the areas alledged by NSRS. Records of two sets of sampling program support weld visual inspections have been reviewed by NSRS. These records were provided to NSRS in late 1983 and support a conclusion that the welds inspected through carbo zine primer were reinspections for configuraton only as part of an OEDC sampling program. The ~ records were an essential pr.rt of the OQA and NSRS closure of the issue in early 1984. One set of the records are dated July 1981 and recorded inspections fer configuration of duct supports and contsin notes that the welds were painted in some instances. The second set of records are dated June 1982 and recorded full quality and configuration data for miscellaneous structural steel velds. None of the welds were noted to be painted even though the surface condition was noted in most instances. The NSRS concludes that the July 1981 records were part of the disposition of NCR 2654R and the June 1982 records were part of the disposi-tion of NCR 2375R. It can reasonably be concluded that visual inspections of struc-tural welds through carbo zine primer were performed as part of the initial sampling activities for NCRs as early as January 1980. Since the welds had been inspected and accepted prior to the NCR activity, there is no reason to suspect the acceptance was based on inspections of primed welds. Clearly in July 1981 inspections for configuration through primer were performed and ) recorded. In all probability, in the fall of 1981 someone(s) recalled the prohibition of inspection through paint in G-290. This led to the request for relief of the requirement which in turn led to the November 1981 and January 1982 EN DES memoranda granting the limited approval. With the possible exception that. an NCR or some kind of deviation describing document concerning the inspections through primer which'had not been authorized 4

4 3 I could have been needed, the above set of events is reasonable and acceptable-practice. It is a fact that the records necessary to totally establish a traceable set of events cannot be resurrected now. The basis of the NSRS recommendations in 1982 was a perceived need for better documentation in procedures and in records. The line organi-zation responded as discussed above and chose to continue to -technically justify the acceptability of the practice. This divergence of direction led to the extended correspondence neces-sary to finelly resolve the issue. An additional observation to help put the carbo zine issue in perspective is that many relaxations of the geometrical aspects .of-the weldments were granted by EN DES as part of the NCRs dispostions. The geometrical acceptance criteria are contained in G-29C and as well as AWS D1-1. Although the potential impacts of the relaxations of actual weld geometry c.re far greater.than the impact of some small defect which might be overlooked as a result of examining a painted weld, these relaxations were not challenged because the traceability was more clearly maintained and the justifications were more clearly stated. -Therefore one can reasonably conclude, in hindsight, that the issue of inspec-tion through carbo zine primer might not have been raised had the documentation been more clearly maintained. Conclusions to be reached from this reconstruction are: 1. Structural welds at WBN were inspected and accepted in accor-dance with appropriate procedures before they were primed. In no documented case were welds initially inspected and accepted after the primer was applied. 2. A need arose to reinspect some welds for configurativa aspects. 3. The primer was not removed from some of the welds being reinspected for configuration - an apparent or alledged violation of existing procedures. 4. CONST requested of EN DES and was granted permission to reinspect for configuration through carbo zinc primer. 5. SomeveldswerereinspectedforconfiguraEonthroughcarbo zine primer both before and after permission was granted. 6. No authorization was ever given b; EN DES to reinspect for i quality through carbo zine primer. Any inspections made or initial acceptance or reinspections for quality through' primer were made without proper authorization or procedures. 1 7. Sample programs where reinspections, with the primer removed, for quality were conducted to resolve NCRs. Some 36,000 l 5

, t linear inches of welds with the primer removed were reinspec-ted with tero rejectable defects when reviewed by EN DES. This served as the basis for closure of the item by NSRS. The fac'. that no rejectable defects were found during reinspec-tion of the 36,000 linear inches of clean welds gave suf-ficient confidence that the remaining welds were structurally adequate regardless of whether or not they had been reinspec-ted through carbo. zine primer and with or without good procedures. B. Response to NS-85-001-001 Conclusions 1. ERT

Conclusion:

The concern is substantiated. TVA closed the carbo zine issue prematurely, and without adequate and documented technical justification and cor-rective action. From 1981 to late 1983, TVA's handling of the' carbo zine issue was utimely and unresponsive. Then in January and February 1984, TVA questionably dismissed the issue. NSRS RESPONSE: The NSRS does not agree that the issue of structural veld inspection through carbo'zine primer was prematurely closed by TVA nor was the issue questionably dismissed by TVA in January and February 1984. Further, the NSRS finds the technical justification was adequate and remains so and the justification is documented principally in the references of the August 13, 1985, Investigative Report NS-85-001-001 which is the subject of this response. The essential par-ties to the evolution of the carbo zine issue still work for TVA and still relate facts consistent with that sumarized in the January 30, 1984,.0QA to NSRS memorandum which cap-tured the major details of the resolution-of the_ issue. The January 30, 1984, OQA memorandum is an acceptable overall summary of the actions and decisions leading to TVA closure of the issue of structural veld inspecton through carbo zinc. primer. The NS-85-001-001 report conclusion regard'ing timeliness and responsiveness of the parties from 1981 through 1933 is correct to a great degree. The NSRS review and resulttant concerns as expressed in R-82-02-WBN-24, R-82-07-WBN-02, and -06 could have been more clearly or precisely stated. In i turn, the OEDC responses could have requested clarification; instead, the line responses set about justifying the techni-cal acceptability of some inspections through the primer and substantially ignored the documentation issue after the initial response. Once the divergent paths were estab-lished, achieving full communication and convergence was l 6

i .f very' difficult - the parties simply were'not working on the same issue. The NSRS concerns were principally related to documentation of results'and controlling'proceduces; the EN-DES and CONST responses principally related to.the technical acceptablility of the inspections. Convergence-was attained in late 1983 and early 1984 through a series of meetings involving OQA and NSRS. The NS-85-001-001' Attachment C, questions are answered in Section IV.C of this report. The ten "Conclusion" questions are answered in the following paragraphs. 2. NS-85-001-001 - Conclusion Question 1 Does TVA consider inspection of welds through' carbo 'zine primer a deviation or "contrast" to AWS D1.1-727 If not, why? If so:

RESPONSE

Inspection of welds through carbo zinc primer is a deviation from AWS D1.1-1972 paragraph 3.10.1 which states "Welded joints shall not be painted until after the work has been completed and accepted." Reinspection of painted welds that ^ ~ were completed and accepted in an unpainted condition is not addressed by AWS D1.1. It should be kept in mind that. inherent in the application of all codes, standards, Regulatory Guides, etc., the ulti-mate selection and specification of requirements is the responsibility of the engineer or designer to accomplish any design / construct / operate task. In.every case, the engineer /- designer specification must be technically justified. In this context, AWS D1.1 is no different than any of hundreds of standards and guides at hand to help the designer; none of the standards or guides'are generally 100 percent appli-cable to a given specification. The G-29C specification is an engineering specification which relied in part upon AWS D1.1 for a set of technically acceptable requirements. In the same manner that the engi-neer selected, for ease of specification, AWS DI.1 require-ments for G-29C to accomplish specific goals, the engineer can relax or strengthen the requirements consistent with'any particular new or different condition so long as technical justification exists. In the case of the inspection through primer, the construction forces properly asked for and were properly granted engineering approval to deviate from G-29C and in turn AWS DI.1 for purposes of reinspecting welds to resolve nonconformances. This process is fully acceptable as an engineering practice. 7

3. NS-85-001-001 - Cenclusion Question 2 Does TVA have a documented technical justification for the above deviation or "contrast"? If not, why? If so, where is it documented, and:

RESPONSE

A documented technical justification exists for performing inspections of structural weld for configuration through properly applied carbo zinc primer. That justification is contained in the December 17, 1981, memorandum from Schrandt to QAB Files (QAS 811217 010) and in the January 14, 1982, memorandum from Cantrell to Wilkins (NEB 820114 253) which superceded the November 2, 1981, memorandum from Cantrell to Wilkins (SWP 811102 056). The documentation may be subject to criticism for its lack of specific traceability regarding the qualification process; however, the need for traceabil-ity is highly subjective in nature. Recognizing that AWS D1.1 is not very specific regarding records in general, it is not surprising that traceability which is a subset require-ment of records might be subject to dispute. 4. NS-85-001-001 - Conclusions Question 3 Did TVA present and/or discuss the above deviation and/or technical justification to/with the US NRC Region II at the Janua ry 12, 1984 meeting in Atlanta? If not, why? If so:

RESPONSE

The issue of weld inspection through carbo zine primer was specifically discussed with NRC-I&E Region II at the January 12, 1984 meeting in Atlanta. The meeting is documented in Janua ry 16, 1984, memorandum from Lyons to SEB files (OQA 840116 401). 5. NS-85-001-001 - Conclusions Question 4 Did the US NRC Region II, at or as a result of the above meeting, indicate to TVA whether or not the above deviation and/or justification would be acceptable? If not, why? If so, what was the indication and was the indication documen-ted?

RESPONSE

There is no direct indication that Region II either accepted or questioned the inspections in question. However, attach-ment 2 of OQA 840116 401 documents a set of Region II ques-tions from the meeting which TVA agreed to pursue and evalu-ate the need for program improvements; the issue of inspection through carbo zine primer is not addressed in the list of 8

o, t' questions which indicates Region II did not question the TVA practice. 6. NS-85-001-001 - Conclusions Question 5 Did TVA delete the references to such_ inspection from specifi-cation G-29C on January 23, 1984 as a result of the above meeting and a~ negative response from US NRC Region II? If not, why_the deletion?. If so: RESPONSE _ Since there was no indication that Region II was questioning the weld inspection through carbo zine primer, the January 23, 1984 deletion did not result from a negative NRC response. The parties to the issue - NSRS, OQA and EN DES agreed, at the time,'in the interest of removing all residual or linger-ing questions of misapplication of the engineering granted limited authority to inspect welds through primer, the authority was removed from G-29C. It should be noted that the NCRs resolving sample programs which relied upon the approval had been completed and no longer needed the appro-val. The deletion in 1984 in no way should be construed to imply the restricted practice in 1981 and 1982 was an invalid exercise of engineering authority. 7. NS-85-001-001 - conclusions Question 6 At the January 18, 1984 meeting with the TVA Board of Direc-tors, it was decided that specific exceptions to'AWS DI.1-72 and associated justifications would be disclosed to the US NRC-NRR; at this meeting,- did TVA present and/or discuss the inspection of welds through primer as one of the specific exceptions? If not, why? If so:

RESPONSE

The issue of weld inspection through carbo zine primer and the related qualification program were specifically discus- 'm sed in the Board of Directors briefing of January 18, 1984. The summary of the brief is documented in the February 13, 1984, memorandum from GM (Willis) to General Manager's File ~ (EDC 840213 003). 8. NS-85-001-001 - Conclusions Question 7 At the above meeting, was the forthcoming change to specifi-cation G-29C (to delete references to such inspection) and/or the reasons for the change, presented or discussed? If not, why? If so: 9

1 c 't

RESPONSE

Deletion of the G-29C allowed practice of restricted weld inspection through carbo zinc primer was not discussed at the January 18, 1984 Board briefing. Since the deletion was not a key issue and OQA had not requeated the deletica at that time, there was no forcing function to provide such a discussion, 9. NS-85-001-001 - Conclusions Question 8 At the February 12, 1984 meeting with the US NRC-NRR in Bethesda, did TVA disclose the above deviation and/or justifi-cation? If not, why? If so:

RESPONSE

The subject of weld inspection through carbo zine primer was not discussed at the February 12, 1984 meeting of TVA and the NRC-NRR in Bethesda. The issue of the veld inspections through primer was felt to be resolved and acceptable based upon data from sampling programs which demonstrated that the weld inspections through primer had been performed for the purposes of disposition of NCRs related to veld configur-ation. The number of welds which might have been inspected improperly, for weld quality through primer, was estimated to be 100 - 150. Since the NCR disposition results from the extensive sampling had showed no rejectable quality defects, the 100 - 150 welds were felt to be acceptable. 10. NS-85-001-001 - Conclusions Question 9 Did the US NRC-NRR, at the above meeting or otherwise, indicate to TVA whether or not the above deviation and/or justification is acceptable? If not, why? If so, what was the indication?

RESPONSE

The subject of weld inspection through carbo zine primer was not discussed at the meeting with NRC-NRR. Thus NRC-NRR gave no indication whether or not the practice was accep-table. 11. NS-85-001-001 - Conclusions Question 10 Does TVA consider the "sampling program" re-inspections as inspections subject to specification G-29C and code AVS D1.1-72? If not, why? If so, refer to question 1, above.

RESPONSE

The sampling program reinspections were subject to the G-29C and AWS D1.1-72 requirements to the extent specified by the 10

t engineering designers. The response to question 1 above more fully addresses the engineering specification inter-relationship with codes and standards. C. Response to NS-85-001-001 Attachment C Questions 1. QID A STATEMENT The purpose of this memorandum is to document final resolu-tion and closure of NSRS concerns with the AWS Welding Program at the Watts Bar Nuclear Plant. QUESTION Since the "purpose of this memorandum is Eto document final resolution and closure of NSRS concerns," is it intented that this memorandum address all of the following NSRS findings regarding the carbo zine issue: (a) NSRS item R-82-02-WBN-24? (b) NSRS item R-82-07-WBN-02? (c) NSRS item R-82-07-WBN-067.

RESPONSE

The intent of the memorandum was to document resolution of the three concerns addressed in attachments 1, 2, and 3. These were: (1) That the WBN welding program did not provide filler material records necessary to satisfy AWS D1.1-1972. (2) That the k3N welding program did not provide inprocess inspection records to satisfy AWS D1.1-1972. (3) NSRS review of WBN weld program indicated that inspec-tions had been performed through carbo zine primer. These three statements had been agreed to by OQA and NSRS in meetings on October 28, 1983 (OQA 831118 425) and December 21, 1983 as adequately defining and scoping the remaining or unresolved NSRS concerns associated with R-82-02-WBN-24, R-82-07-WBN-02, and R-82-07-WBN-06. Note that the purpose of the December 21, 1983 meeting was stated in the informal memorandum from J. R. Lyons II to H. N. Culver dated December 20, 1983, WBN - AVS Weld Program (no RIMS number) to be: "At the Wednesday meeting we intend to discuss each evaluation and determine the areas in which OQA and l II

e l , t NSRS agree or disagree. It is-intended that this effort-provide a basis for determining any corrective actions or for closing'NSRS items R-82-07-WBN-02 and -06, and R-82-02-WBN-24." 2. QID B l STATEMENT The following is a sumary of the key events that led to the eventual resolution of the NSRS. concerns: . QUESTION l Although not listed in the'"summary of key events," did the following events also "lead to the eventual resolution of-the NSRS concerns" regarding the carbo zine issue?: (a) January 12, 1984 meeting with USNRC Region II in Atlanta l to. discuss the specification G-29C program?' l (b) -January 23, 1984 revision to specification G-29C (P.S.3.- C.S.4) to delete references to inspection through carbo zine primer? (c) February 10, 1984 (scheduled) meeting with USNRC-NRR in Bethesda to present G-29C exceptions to the AWS D1.1-72 l structural welding code?

RESPONSE

(a) The January 12, 1984 meeting with USNRC Region II was held to provide additional support to the OQA and NSRS positions regarding weld filler material control and l inprocess weld inspection records which were to be presented to the TVA Board. l (b) The OQA recommendation to OEDC that G-29C be revised to delete provisions for reinspection through carbo zine was made to preclude any future concerns in this area, but was not a basis for closure of the inspection through carbo zine issue. ~ (c) The meeting with USNRC-NRR in Bethesda was in response to the January 18, 1984 Board meeting to ensure that NRR understood and accepted the TVA exceptions to AWS j D1.1-1972 as defined in G-29C. These exceptions were not related to the inspection through carbo zine issue. 3. QID C l 12 i i

\\ t Statement In your memorandum to me dated August 10, 1983 (GNS 830811 050), you identified three concerns your organization had with respect to the AWS Welding Program at Watts Bar Nuclear-Plant. They were filler material records, inspection records, and inspection through carbo zinc. QUESTION The NSRS memorandum dated August 10, 1983 identifies a conflict between the procedure and acceptance criteria of G-29C process specifications for inspection of welds through primer: (a) Was this conflict specifically addressed and resolved? (b) If not, why? (c) If so, was the resolution documented and was a response transmitted to NSRS?

RESPONSE

(a) The alledged conflict involving inspection of welds through carbo zine primer was specifically addressed and resolved. (b) Not applicable (c) The resolution was documented and transmitted to NSRS. Numerous discussions led to final documented acceptance that the issue was resolved. The summary presentation of the agreement that the issue of visual inspection through carbo zine primer was acceptably addressed was based on two sets of documentation. The first set is summarized in attachment 3 to the January 30, 1984 memorandum (OQA 840130 002) from Anderson, OQA to Culver, NSRS. The "Sample Program Results" on page I summarized inspections of 35,000 linear inches of welds for configuration and 23,600 linear inches of welds for quality; (configuration denotcy weld length, size, overlap, convexity and concistty and quality denotes cracks, porosity, are strikes and craters). For these sample, weld quality was 100% acceptable and the weld configuration was 100% acceptable for cable tray sup-ports, duct hangers and conduit supports. However, 667 i linear inches (3.63%) of miscellaneous structural steel welds were unacceptable for configuration only. The sample program inspections for quality were conducted with the primer removed. The second set of documen-tation was actual weld inspection results from July 1981 and from June 1982 which were reviewod by NSRS. 1 13

The July, 1981 inspections were for configuration only 0 and were noted that in some instances the welds were painted. The June, 1982 inspections were for configur-ation and quality; surface conditions noted were "suit-able for MT," poor, rough, etc. In no case was a painted or primed surface noted. 4. QID D STATEMENT We attempted to respond to your concerns in my memorandum to you dated October 20, 1983 (OQA 831020 002). QUESTION The OQA memorandum dated October 20, 1983 states that "the issue of inspection of welds through carbo zine primer has been resolved by the closure of NSRS item R-82-07-WBN-06; the subject of this memorandum is NSRS item R-82-02-WBN-24. (a) Since item R-82-07-WBN-06 was closed by OQA on 8-24-83, how was closure of this item the basis for OQA closure of item R-82-02WBN-24 on 5-6-837 (b) Since item R-82-02-WBN-24 identifies the inspection of welds through primer as a contrast to AWS D1.1-72, why doesn't the memorandum address the issue as related to the structural welding code?

RESPONSE

(a) R-82-02-WBN-24 (AWS Deviations) was closed by the OQA Design Quality Assurance Branch on May 6, 1983 (0QA 830506 002) based on their review of the technical justifications provided by OEDC to NSRS (EDC 821215 004). The memorandum from NSRS dated August 10, 1983 - subject R-82-02-WBN-24 -to OQA (GNS 830811 050) ques-tioned the OQA action and identified three issues for further consideration. These were the same three issues discussed in QID-A above. R-82-07-WBN-06 (Qualification of Welding Procedures for Inspection thru Carbo Zine) was closed by OQA on August 24, 1983 (0QA 830824 002) based on qualification tests performed by OEDC (EDC 830621 004). The closure of R-82-07-WBN-06 in August 1983 was not the basis for closure of R-82-02-WBN-24 in May, 1983. (b) The contrast between G-29C and AWS as it related to the carbo-zine issue was addressed in the resolution of R-82-07-WBN-06 and not as a part of R-82-02-WBN-24. 14

4 I This was due to the fact that weld acceptance inspec-tion for quality through carbo zine was never intended; therefore it was never addressed as a deviation frem the AWS code. Note that the OQA memorandum of October 20, 1983 was in response to the NSRS memorandum of August 10 1983 and thus had the same subject heading which was related to closure of R-82-02-WBN-24. However, the OQA comments related to inspection through carbo zine were stated in item 1 to be related to R-82-07-WBN-06. 5. QID E STATEMENT Your concerns were not resolved and on October 28, 1983, we met with you to attempt to reach a resolution. The meeting was documented by a memorandum to the Systems Engineering Branch Files dated November 18, 1983 (0QA 831118 425). A plan of action was agreed to in the meeting, and OQA proce-eded to implement the plan. QUESTION The OQA memorandum dated November 18, 1983, for "Actions to be Taken" regarding "Inspection through carbo zine," states that OQA will "develop a factual history of all actions taken" and will "evaluate if the actions taken provide an adequate basis for closure of the problem." (a) Was a "factual history" developed by OQA prior to November 18, 19837 (b) Was an evaluation of the "Letions taken" to "provide an adequate basis for closure" performed by OQA prior to November 18, 19837 (c) Was the "plan of action" completed and documented? s n.

RESPONSE

(a) A factual history had not been prepared in a consoli-dated form which included all related OEDC, NSRS and OQA correspondence and documents. The lack of a single chronology of related events had contributed to communi-cation difficulties between the three organizations. s (b) The purpose of the October 28, 1983 meeting was to discuss the NSRS concern stated in their August 10, 1983 memorandum (GNS 830811 050) that OQA had acted prematurely in closing R-82-02-WBN-24. The action item in question was that OQA would "(re) evaluate if the 15 -n -J

.~ .,.~

s..

4i l ictions (previously) taken (by OEDC and OQA) provide (d). 'an adcquate basis for (the)' closure of the problem '(R-82-02-WBN-24) (by OQA)." Portions in parentheses provided for clarification. i (c) Yes. The memo'from J.:W. Anderson to H. N. Culver dated January 30, 1984 (0QA 840130'002) documented- -closure'of the NSRS concern and completed the plan of 7 action. i 6. . ID F Q { STATEMEg [ Num.erous informal meetings were conducted between our organi-2ations to attempt to clarify the concerns and their resolu- [ tions. Attachment 1 of this memorandum is the final resolu-tion on filler materia}-records and supporting information which was used to draw OQA conclusions. Attachment 2 of this memorandum is the final resolution on inspection records and. i supporting information which was ured to draw OQA conclu-siens. Attachment 3'of this memorandum is'che final resolue ~ tion on inspection through carbo zine and supporting infor-mation which was'used to draw OQA conclusions. i QUESTION [ 1 l (a) Regarding the "numerous informal meetings," were any of 4 these meetings documented (i.e. notes of meeting issued)' to reflect information presented and discussed, and agreements and disagreements? f (b) Note: Questions regarding "Attachment-3" are presented l J separately (below). l

RESPONSE

[ j (a) The fuformal meetings and discussions were not docu-t mented. (b) No response required. 7. QID G i 3 i ] STATEMENT j On January 18, 1984 NSRS and OQA set with the TVA. Board of Directors. In that meeting you concluded that all of your concerns were resolved and that you agreed with OQA's con-elusions. l 6 I 16 r s, r -.,>+v -p-e

t QUESTION (a) Was the January 18, 1984 meeting with the TVA Board the point at which NSRS concluded that all of their concerns were resolved? If not, when? (b) How did this one meeting succeed, since numerous meet-ings in the past had apparently failed, in resolving all the NSRS concerns? (c) Was information, other than that contained in the Janua ry 30, 1984 memorandum, presented or discussed at the TVA Board meeting?

RESPONSE

(a) The January 18, 1984 meeting with the TVA Board was not "the point" when NSRS concluded their concerns were resolved - there was no "the point" rathe a series of points which are best summarized in the January 30, 1984 OQA to NSRS memorandum. It should be recognized that the January 30, 1984 memorandum was not intended to capture every meeting, telephone discussion, etc. However the memorandum does contain sufficient documen-tation to support an affirmative decision to close the carbo-zine issue in a summary sense. (b) This question presumes an affirmative answer to G.(a) which is not the case in a simplistic view. (c) The memorandum from W. F. Willis to General Manager's File (EDC 840213 003) summarizes the Board briefing of Janua ry 18, 1984. No information other than that stated in these minutes was presented or discussed. The January 30, 1984 OQA memorandum to NSRS relates the essential discussions at the Board briefing dealing with the inspection through carbo-zinc, and is con-tained in attachment 3 to the OQA memorandum. 8. QID H STATEMENT We believe that all of your concerns have been satisfactor-il:' resolved and we no longer consider your AWS Welding Program concerns to be an open issue. Record Note: This memorandum was coordinated with H. N. Culver on 1/30/84. He is in full agreement with the content and he acknowledges that the data presented resolves all NSRS con-cerns. 17

X. ~ + Q _\\ i.- 1 QUESTION Does this mean that the NSRs staff reviewed and accepted the "content".and "data" for accuracy and completeness?

RESPONSE

The record note is explicit in stating coordination of the memorandum with H. N. Culver and his agreement and acknow+ ledgement. The dialogue regarding weld inspection through 4 carbo zine primer was lengthy both in words and in time. Many different people were involved in the< dialogue at different times including various NSRS staff. -It can be concluded from the record note that after the lengthy dia-logue, Mr. Culver spoke for NSRS as the Director of NSRS and its staff. Accuracy and completeness are subtle issues not explicitly stated in the record note and either may'or may not have been part of Mr. Culver's-coordination, egreement and acknowledgement. "Full agreement with the content" could be presumed to endorse accuracy; acknowledgement of resolution could b_e presumed to endorse sufficient complete-ness to resolve the concerns _as is explicitly stated. 9. QID 1A STATEMENT y CONCERN NSRS review of WBN weld program indicated that inspections had been performed through carbo zine i primer. QUESTION (a) Was the performance of such inspections the only aspect of the "concern"? (b) What about the lack.of approved procedures? (NSRS iter R-8207-WBN-02) (c) What about the lack of a documented "qualification" program to justify the ability of inspectors to detect defects through primer? (NSRS item R-82-07-WBN-06) (d) What about the aspect of deviation fr"om the AWS D1.1-72 l code and FJAR commitment? (NSRS R-82-02-VBN-24)

RESPONSE

(a)-(d) The statement is an adequate summary descrip; ion of the concern, items (b), (c), and (d) are valid "aspects" of the concern but by no means the only "aspects". It would be very difficult to state all the aspects of the concern at this time with-out reinvolving all the parties to the concern 18

w Y. '. iS* 'n' Lf n w x. A pj., g. It'is deemed sufficient-that _ (t : 'from the beginning. the'. extensive-dialogue leading-to the January 30, 1984 summary memorandum convinced the NSRS Direc-tor'that closing the concern of weld inspection through carbo zine primer was warranted. To ^ attempt to state all the aspects of the concern. would presume to' speak for all parties to.the. dialogue. 3 It should be note'd thatLthe June 23,.1982 memoran- . dun from Culver, NSRS to Kimmons, OEDC transmit- _ ting'the R-82-07-WBN states ".. this review was 'not concerned with' the technical aspects of inspec-ting welds through carbo zine primer., Rather, .this review was concerned with whether or not such-inspections were in accordance with approved site procedures and that justification for such inspec s tion procedures:was adequately documented..." The' long continuing dialogue interjected a. number of ? .? aspects of the inspection concern that were related to R-82-07-WBN findings but not necessarily converg-a ing on the final resolution. r 1 10. QID IB i y . 1 STATEMENT a CONST requested approval from EN DES to. inspect through 'I carbo zine primer as a part of a series'of. sample programs in which welds were being reinspected to determine their I adequacy and the adequacy of previous inspections.' j QUESTION ,..m If the purpose was "to inspect through carbo zine as,a part of a series of sample programs," did the approval'for such inspection clearly.init the practice to the "sample pro-grams?" ~ s

RESPONSE

sj CONST managerant regnested approval to visually inspect f welds as part'of toepling programs for veld configuration without retroving tGe' primer. Although it ii not clear tcl an outside observer, it is felt. that the engineering'and con-struction people understood the nature of the approval granted by the November 2, 1981 Cantrell to Wilkins memoran-3 dum. Authorized anspection of welds in question at that 'i 3 time was based upon a full visual inspection' prior to apply-ing;ths primer, and the November 2, 1981 memorandum did not grant specific authority to accept welds based upon an l init tal visual examination through primer after November 2, 1981. Therefore, it is concluded that any initial acceptance j 19 s h

g. 5 ' l t. 'of welds with primer applied was limited. This position is supported by Reference N to the NSRS R-82-07-WBN report.: Reference N is-a Schrandt,' QA Engineer to QAB Files,.QAS 811217 010, memorandum which states "...EN DES concluded welds requiring only visual examination could be inspected with primer applied under conditions. stated in the uemoran-dum. Inasmuch asjthese welds were inside the building they had previously been subject to the Watts Bar quality control program prior to the EN DES requirement for a sampling program with respect to weld quality." The November 2, 1931 memorandum does not explicitly and-clearly state the approval the way the Schrandt memorandum states the case. However from an indepth review of the j related correspondence of that general time, an outsider can conclude with reasonable certainty the intent of the par- ~ ties. The considerable degree of misunderstanding regarding just what was authorized could h ve been avoided if the I construction request and the Engineering authorization had been more clearly documented at the outse. e 11. QID IC STATEMENT Inspection through carbo zine authorized for: Welds made prior to November 2, 1981 Inspections made after November 2, 1981 Carbo zinc 5 mils and sprayed in accordance with the applicable specification. QUESTION (a) Are the "inspections made after November 2, 1981" part of the "sampling program," or does this statement apply to any-inspections? i (b) How do the inspectors determine if a specific weld was made prior to, or after, November 2, 19817

RESPONSE

(a) The EN DES approval applied to reinspection of welds { for configuration only through a maximum of 5 mils carbo zine primer which was responding to a specific CONST request. j i (b) There was no effective way for an inspector to deter-mine the date a weld was made. According to the weld j inspection supervisors, this difficulty was a major reason the inspectors did not exercise the lattitude provided by engineering and the procedures. 20 +s

c, -1 12. QID ID STATEMENT All welds inspected for._ veld quality (porosity, lack-of-fusion, cracks,.etc.). as a part of an EN DES directed sam-pling program-to be. cleaned. ~ QUESTION -(a) If this statement is intend.ed'to be a quotation from the Process Specification 3.C.S.4, why was the "unless. exempted by EN DES" provision not included in this statement? (b) Does this statement masn tnas welds inspected for quality, and not part of the EN DES directed sampling. program, need not be cleaned?

RESPONSE

(a) The statement was not intended to be a direct quotation rather as a. bounding statement expressing a summary allowable action. (b) The EN DES requirement was that welds not be painted until examined and accepted. Subsequent reinspections "not par: of the EN DES directed sampling program" were not addressed. No approval was ever given by any organization to inspect for weld quality through carbo zine primer.-

13. QID 1E STATEMENT Acceptance criterfe for weld defects'to_be in accordance with G-29C.

QUESTION 'l (a) Is there'"acceptance criteria for weld defects," other than in G-29C, that would apply? (b) Is there "acceptance criteria," other'than for "weld defects," that apply? -l

RESPONSE

(a) Within.the scope of the November 2, 1981 memorandum, there were no acceptance criteria for weld defects other than G-29C. There were numerous other acceptence criteria for weld defects which were not covered by the 1 i 21

'v e 9 November 2,1981 memorandum such as criteria for sur-face (not visual) or volumetric examination. (b) There are no acceptance criteria, ether than for weld defects, that apply to the concern about reinspection of welds through carbo-zine_ primer. The visual exami-nation weld acceptance criteria were contained,in'G-29C-and included;both weld quality and weld configuration defect limits. Reinspection for weld quality defects through carbo zine primer was never allowed by G-29C.

14. QID 1F STATEMENT' SAMPLE PROGRAM RESULTS:

Scope Sample Results Cable tray 8,000 linear inches (configur 100% acceptable supports ation) 3,500 linear inches (quality) (note 1) Duct hangers. 5,000 linear inches (configur-100% seceptable ation) 2,100 linear inches (quality) Misc. strue. 18,000 linear inches (both) 100% acceptable stecel for quality 667 inches unac-ceptable for configuration (3.63%) Conduit 4,000 linear inches (configur-100% acceptable supports ation) (note 2) QUESTION (a) How do the "Sample Program Results" relate to each of the aspects (see Question IA, above) of the carbo zine concern? (b) Where are the sample-program results for "instrument-supports" and structural steel (other than "misc. stru. steel")? i 4

RESPONSE

(a) The sample program results were associated with the resolution of several NCRs, and were conducted to address issues independent of the carbo zine concern. 22 j

.v A portion of the welds included in-these samples were reinspected through carbo zinc. This was the_ basis for the initial CONST request to EN DES to' allow reinspec - tion.through carbo-zine for^these samples. EN DES authorized reinspection of welds made prior to November 2, 1981 through carbo-zine for weld configuration characteristics (size, location, undercut, overlap and' weld splatte.r), but required that,e-inspection for weld quality (cracks,. porosity and inck of fusion) have the. primer removed.. The sample program results provided a basis for evalua-ting the adequacy of a large. body of welde independent of the carbo zine issue. The results provide confi-dence that even if welds-had been inspected through carbo zine primer, there is a very. low probability of a weld defect. (b) There.were no previous sample programs for instrument supports. All the sampling programs being discussed in the carbo zine issue were for structural steel' welds - the scope descriptions were for specific support appli-cations. ~ 15. QID 1G STATEMENT NOTE 1: All sample program inspections upon which the determination of acceptability of weld quality were based were conducted with primer removed. QUESTION (a) Does the "Note 1" apply to all of the "Scope" items, or just to the "cable tray supports" item, for weld qual-ity? ~ (b) Why is the "cable tray supports" item the only "Scope" item that has the "(note 5)" reference?

RESPONSE

w (a) Note 1 applies to all of the scope items. l (b) This was an error on the chart. Note 1 should have ) been included as a general note. { e 16. QID 1H STATEMENT NOTE 2: Weld quality accepted based on cable tray support sample program. 23 4 ,v.

3 Based on these sample programs, the primary area of uncer-' tainity with respect to weld acceptability is.related.to weld configuration-(i.e.: overlap, undercut, size,etc.). QUESTION (a) If "weld configuration" is the "primary" area of uncer-tainty, what.other (i.e., secondary ~ tertiary, etc.) area (s).of uncertainty is applicable? (b) Is the "uncertainty"... "b.ased on these sample pro- . gra as"? If so, how was the "uncertainty" resolved?.'If- .not, what is the "uncertainty" based on?

RESPONSE

(a) There were no areas of uncertainty with respect to weld acceptability other than weld configuration. Deletica of the word "primary" would not affect the intent of this sentence. (b) No. The uncertainty was based on the NCRs being eva.lu-ated. The results of the sample programs limited the area of uncertainty to weld configuration (and not weld quality), and provided a basis for acceptance of the welds within the scope of the NCRs. 17. QID 2A STATEMENT Inspection through carbo zine acceptable for: weld configuration (overlap, undercut, size, location) large cracks coarse porosity. Inspection through carbo zine unacceptable for: small cracks fine porosity. Based on this qualification program, the area of concern for any inspection conducted through carbo zine is limited to small~ cracks and fine porosity. QUESTION (a) Does this mean that welds can be inspected for weld quality (cracks, poresity,.etc.) through carbo zinc? (b) Does this mean that "small. cracks" and "fine porosity" ~ are acceptable if not detected through carbo zinc?' 24 .m

o-(c) 'What are the' definitions for.."small" versus "large,"

~ ~ and."fine" versus "coarse," as: applicable toLeracks and; ~ ' ' porosity? I (d) Are these statements consistent with th'e OEDC results and conclusions of the OEDC "qualification. program"?L

RESPONSE

(a)-(d) The November 2, 1981 memorandum authorized inspec-tion through carbo zinc primer for weld configur-ation as part of a sampling ~ program from pre-viously accepted welds. -The qualification program- -demonstrated that.from a technical-acceptability ~ . point of view large cracks'and porosity.can be' ' detected-through the carbo zinc primer if 5-mils or less in thickness. Further,'although visual inspection was generally enhanced by the primer, detection of fine-cracks and porosity. ~ could be limited. Rather than assess structural acceptability of any cracks and porosity beyond

• G-29C limits, sampling inspections'for weld qual-ity was not permitted through carbo zinc primer.

Therefore definitions of large versus small and coarse versus fine are not a consideration at ' issue and the program is totally consistent.

18. QID 2B STATEMENT Welds at Watts Bar were. inspected through carbo zine as a-part of the weld sample program.

QUESTION Does this mean that welds, other than "as part of the weld sample program," were not inspected through carbo zinc? r

RESPONSE

-see The NSRS Report R-82-07-WBN provided in the details for R-82-07-WBN-02 (paragraph IV.B), "...four. admitted to having. inspected carbo zine primed welds. While such inspections had been made, the practice apparently had not been exten-Based on these interviews, it appeared that only 100-sive. This to 150 welds may have been inspected in thiz manner.' could not be substantiated by a review of the records', however, nor was it possible to specifically determine which-welds were inspected in this manner." 25 p a e,, ~

1.. 4 19. QID 2C STATEMENT ~ Inspection through carbo-zine was not authorized by EN DES for determination of acceptability ofl veld quality (poros-ity, lack-of-fusion, cracks, etc.). QUESTION Refer to Question ID, above. (a) Why does this statement not include: ...as a part of an EN DES directed sampling program...unless exempted by EN DES"? a (b) What is the basis for this statement? (c) Refer to Question 6B(a); is there a contradiction in these statements?

RESPONSE

(a)-(b) The OQA statement in question is a summary state-ment of fact and applies whether part of a samp-ling program or not; EN DES.always has an option of providing specific evaluations at.d exemptions if technically justified. The docunentatioa dealing with the carbo-zine' primer issue contains no EN DES authorization to inspect et reinspect for weld quality through carbo zine primer. (c) By chosing to use "limit" in the vording.a simple reading could lead to a perception of a contradiction. However, taken in view of all the documentation prior to August 24, 1983'when.the G-29C Addendum 2 was issued, no contradiction exists. The G-29C speci-fication was and continued to be a "limiting" document. A better choice of wording might have been to "clarify" rather than "limit." 20. QID 2D STATEMENT Results of sample programs indicate weld quality was not an area of uncertainty for samples. QUESTION (a) If "weld quality was not an area of uncertainty," then why were weld quality inspections performed? 26

y ,. ;.y .p E g1 a \\ 0'} h; '(b) j Is the. "area :of certainty": applicable 'only. '.'for ; sam-: i ples"? TIf so, whatLabout; the total population that the - ,-l - samples" represent ?

RESPONSE

^ 'l (a)~ The weld.samplesf.were conducted as-a part of the10EDC.. actions to evaluate and resolve-several.NCRs' involving .the NBN weld program.'For;those NCRs, the~in.tegrity and' acceptabilicy of.the welds'were indeterminate from;both. 'l ~ ,a: veld quality and. weld configuration ~ perspective. :The .j .' samples.provided a basis for;. determining that both weld .x

quality-(no' quality defects identified).and weld con.

figuration--(3.63% of sample: included-deviations deter.- c mined by EN DES to be~ acceptable as'is) were accep-- _j table.~' ' ~ ~ (b) ~No. The weld sample results: established the uacer-: l tainty limits and provided :a. statistical basis ' for. deter-mining that the total population of weld were accep-table subject to-the uncertainty limits of the: sample. 21. QID 2E -l STATEMENT Results of' weld qualification program indicates that weld quality can be determined through carbo-zinc, with the = . exception of small cracks and; fine porosity. i QUESTION ~ ~ Refer to Question 2A, above;-the~same questions apply tof I this statement. Also'see Question 6A. _ .l 5' < RESPONSE-The statement identified is a' summary statement concerningl j the results of the qualification program. The answer-to 2A and 6A, apply equally to.this. question. 'i

22. QID 2F l.:

w STATEMENT I Available data, including NSRS evaluation' notes, indicates ~that the extent to which inspection through carbo zine may [ have been conducted outside the sample program was rela-tively small. [ .I QUESTION -l l (a) Are the "available data" and "evaluation notes" avail-able for review? [ 1 .e 27 l cl I .~.J ._._._._._._.w..._~.,

-. ~.-.,...- s =t ' p- ? a (b).Do.the "data".and."notes" define the "extent to which j inspection'through carbo zine may have been' conducted J outside the sample program"?. lbi [(c);Howmuch..(quaatitatively)is."relatively'small"?: ? RESPONSE (a) The-evaluatibn notes'are available fdr review. !The l' other< available -data was informal and ~there are no = -records available. (b) The' data and NSRS-notes indicate that there'may have' -: +-

been 100

to 150 welds inspected through carbo: zinc.

The sample' data associated with HVAC duct. hanger sam-1 t ples' identifies those reinspected through primer. ~ However, whether the'100 t' 150. welds:were within.the-o sample programs cannot be determined because no spe-cific welds were identified to NSRS. -(c) Relatively small'is 100 to 150. welds. ~ J 4

23. QID 2G STATEMENT OQA CONCLUSION Based on the information provided above-regarding the area.

l' of uncertainty from the weld sample _progransf(weld:configur-ation), the area of. concern for any' inspections through-carbo zine primer (weld quality), and.the extent to which~ inspections may have been conducted through carbo zinc, the integrity of the welds at Watts Bar Nuclear Plant are not-in question. QUESTION Is "the integrity of the welds...not in question" be'cause of ~ the "area _of uncertainty," the "area of concern" and the "extent to which inspections may have bee'n conducted"? t

RESPONSE

2 Yes. The NSRS and OQA evaluations indicated that a small-but indeterminate number of welds may have been-inspected 4. through carbo zinc outside the authorized sample programs. Since the OEDC test program'(EDC.830621 004) had indicated F that the determination of weld quality through primer was E not an' acceptable practice, the integrity of any welds that 3 may have been so inspected was in question. t The sample program results had.not identified any weld quality defects, and thus provided a basis for concluding, ~ t 28 _ t ...-m.- - -.. ~. - - -.

.c with a high degree of confidence,1that any welds actually inspected thru primer did not include weld quality defects, and were thus adequate. The composite results of the weld samples provided the basis for concluding'that the integrity of the welds at Watts Bar Nuclear Plant (i.e.' their'techni-cal adequacy) were not in question. 24. QID 2H STATEMENT 'NSRS POSITION NSRS agrees with the OQA' conclusions regarding the adequacy of the OEDC program. QUESTION (a) Does NSRS agree that each of the NSRS findings regard-ing carbo zine (R-82-02-WEN-24, R-82-07-WBN-02 and R-82-07-WBN-06) have been adequately addressed and-resolved? (b) If so, why was this OQA memorandum and "Attachment 3" issued?

RESPONSE

(a) NSRS agreed that the findings regarding weld inspection through carbo zine primer _were adequately addressed and resolved. (b) The purpose of the January 30, 1984 OQA memorandum was stated in the opening paragraph of the memorandum as "to document final resolution and closure of NSRS concerns with the AWS Welding Program at the Watts Bar Nuclear Plant." The resolution process for the find-ings had been lengthy and somewhat confusing. It'was deemed appropriate that the OQA memorandum be issued to supercede and/or augment any prior documentation. 25. QID 3A STATEMEh'T CONST verbally requested that EN DES evaluate the accepta-bility of visual examinaiton of welds in accordance with G-29C after coating with carbo zine. Note: Involved OEDC personnel have stated that the purpose of this request was to facilitate the performance of a. series of weld sample programs underway at WBN to verify the acceptability of 29

E t welds. These sample programs were to evaluate-both weld configuration (location, size, undercut, and overlap) and weld quality (porosity,: cracks, lack-of-fusion, etc.) for welds which had been previously inspected and accepted. QUESTION If the "purpose" was for the "sample program"-only, why didn't OEDC clearly state this in their memorandum-and-process specification?

RESPONSE

The response to this question is the same as the response to 'IB above.

26. QID 3B STATEHENT November 2,1981 - SWP 811102 056 authorized. visual exami,-

nation of welds in accordance with G-29C after coating with carbo zinc, provided (quote): 1. Carbo zine thickness is 5 mils maximum. 2. All work after this date is exam-ined prior to priming with carbo ~ zinc. 3. Welds inspected for weld quality as part of an EN DES directed sampling program are to be cleaned. QUESTION 1 (a) Does this memorandum apply to only "sample program" inspections? (b) If so, why does the effective date (11-2-81) cover periods not within the scope of the "sample program"?

RESPONSE

(a) The CONST aanagement had requested approval to inspect previously accepted welds which had subsequently been primed with carbo zine to facilitate the sample inspec-tions for weld configuration. The November 2, 1981 memorandum was intended to respond to the CONST request. Although the original request was made t.o facilitate 30

..m 9 . sampling program inspections, there are no obvious ' technical reasons the authority could not be justified for other-inspections.for weld configuration. (b) There was not a single "sample, program." A number of nonconforming conditions were technically resolved by instituting sampling programs - some prior to November. 2, 1981, some. after November 2,-1981. 27. QID 3C STATEMENT-December 1, 1981(A). CONST provided. verbal authorization to inspectors. Note: This authorization may have been limited to one. inspection unit. QUESTION (a) What is the basis for. stating that this "verbal authori- + zation may have been limited to one inspection unit"? (b) Which inspection unit? (c) Was the December 1, 1981."verbal authorization" based' on the November 2, 1981 (30 days prior) memorandum? (d) Is "verbal authorization" an accepted practice for activities affecting quality?

RESPONSE

(a) The basis for the statement that this verbal authori-zation may have been limited to one-inspection unit was personal interviews conducted by OQA of each of the inspection unit -supervisors at the time. (b).The'one inspection unit was the. electrical inspection unit. snv (c) The verbal authorization was based on the' earlier issued memorandum. (d) Verbal authorization without supporting follow-up written authorization is not an accepted practice for activities affecting quality. To reemphasize this point the inspection units were instructed on December, 15, 1981 that initial inspection through carbo zine was not allowed by the procedures (see QID 3E).

28. QID 3D STATEMENT 31

s s. . December 2, 1981(A) NSRS, during conduct of mini-management review, expressed concern with issue of inspection through carbo' zinc.

RESPONSE

There was a QID with no' ques. ion for this statement,

29. QID 3E STATEMENT December-15, 1981 -

CONST verbally informed' inspectors not to inspect through carbo zinc. QUESTION Why didn't CONST inform,.in writing, the inspectors not to inspect through carbo zinc; if not-in 1981, why not in 1982 or 19837

RESPONSE

Acceptability of inspecting through carbo zine did not become an issue until the November 2, 1981, memorandum from Cantrell to Wilkins was written. Copies of this memorandum were issued to units but no permission to inspect through carbo zine was included in-site procedures'. Therefore, it was not deemed necessary to give inspectors written instruc-tions not to inspect through carbo zine since no procedure- . change permitting this' inspection had been issued at this time. The use of a memorandum in lieu of procedures was not allowed, and management believed that this fact had been emphasized enough to inspectors and others. The only writ-ten instructions to inspectors on the carbo zine issue was through procedure revisions.

30. QID 3r STATEMENT January 14, 1982 - NEB 820114 253 clarified condition under which inspections through carbo zine is authorized (superseded SWP 811102 056)

(quote): 1. The acceptance criteria for weld defects is in accordance with G-29C 2. The carbo zine was sprayed in accordance with the applicable coating application specification. 32

_i I QUESTION (a) Other than providing background information, and coat-ing thickness and. application restrictions, how is this memorandum different from the previous authorization for inspection through the primer? (b).Was this memo'randum issued in response to the'NSRS expressed concern? If not, why was it issued? (c) Was the reference to "sprayed" coating based on the recognition that carbo zinc may also be applied by the brush method?

RESPONSE

(a) 'Other than providing background information and c',ating thickness and application restrictions,the' Janu;ry -14, 1982 memorandum is the same as the November 2, 1981 memorandum. (b) The memorandum was issuedLto satisfy the LN DES QA concern at that time. It provided information regard-ing the bases for allowing the limited inspection through carbo zine primer. (c) It was recognized before the memorandum that carbo zine primer could be brushed on as well as sprayed; Appli-cation by spraying was specified in the memorandum to reflect the EN' DES requirement. 31. QID 4A STATEMENT The carbo zine thickness is not greater than 5 mils as documented in coating inspection records and/or log books or as measured adjacent to the weld. Coating thickness measure-ment techniques shall be in accordance with the specifi-cation for coating application. All work performed after this date shall be examined before it is primed. QUESTION Refer to Question 2C, above.

RESPONSE

The 5 mils thickness is specified in the painting standard and is measured using a paint thickness gage which operates on magnetic principles. During the plant walkdovn discussed in the January 14, 1982 memorandum, painting inspectors, using the thickness gage, me$sured the thicknesses as part 33 s v ~e-7c g

v ..). ~ of th'e inspection qualification sampling. The laboratory prepared samples were similarly tested for primer thickness.

32. QID 4B STATEMENT January 25,-1982 - PS 3.C.4.5(a) issued. Authorizes inspec-tion through carbo zine with same restrie -

tions as NEB 820114 253 for welds made prior to November 2, 1981. -QUESTION The P.S.3.C.5.4(a) is dated 1-25-82, but when was it'act-ually issued to CONST7 ' RESPONSE The specification was transmitted to CONST February 12, 1982.

33. QID 4C QUESTION On June 3,1982, NSRS Report No. R-82-02-WBN was issued, and contains a finding (R-82-02-WBN-24) regarding c.rbo zine; why is this report not listed as a key event?

RESPONSE

Reference to this report was unintentionally omitted from the chronclogy. Note that the chronology was not developed to be a comprehensive lising of all correspondence and events related to the issue.

34. QID 4D STATEMENT June 23, 1982, NSRS Special Investigation R-82-07-WBN (GNS 820623 050) issued. Review conducted March 29 through April 2, 1982. Results included:

R-82-07-WBN-02, Improper Inspection of Structural Sup-port Welds Based on interviews with QC inspectors, it was' concluded that 100 to 150 structural support welds had been inspected through carbo zine primer without approved. procedures. 1 34 j

?'I, .t. Recommendations Due to the uncertainity'of the outcome on the question of the. site-approved procedures for inspecting velds through1 carbo zine primer, the NSRS proposes'two recommendations: 1. If this type of inspect. ion is acceptable through im'ple-mentation of the EN DES-approved process. specification, then the welds should be used "as is." 2. If this type of inspection is unacceptable, then the-welds should be reinspected in accordance with existing site approved procedures. QUESTION (a) Were these "100 to 150 structural support welds" part. of the sampling program"? (b) Did the inspectors indicate that they noted the pre-' sence of coating on the inspection record for each weld?

RESPONSE

- (a) Review of the R-82-07-WBN report and its supporting background and subsequent correspondence and related documentation does not provide an indisputable answer to the question of whether the 100 to 150 welds were part of a_ sampling program 'or part of the ongoing construction weld acceptance inspection program. How-ever, a reasonable scenario is that the QC inspectors. ~ rnd their supervisors were following written instruc-- tions - that G-29C or written procedures or the November 2, 1981 EN DES, Cantrell to Wilkins (SWP 811002 056) memor-andum was the basis for acceptance inspection. If the 100 to 150 were other than part of a sampling program, inspection through primer was not authorized and the inspections so performed would have been in violation of authorized procedures. R-82-07-WBN states in paragraph IV. B that )f the 24 inspec-tors interviewed, 9 believed inspection of-carbo zine primed welds was permitted by the memorandum" (11/2/81 EN DES). "Of the nine inspectors, four admitted to having inspected carbo zine primed welds...This could not be substantitated j by a review of the records." Since the 11/2/81 memorandum was stated as the authorizing. document, one can conclude: 1. No inspection welds which had carbo zine primer applied would have been permitted prior to the 11/2/81 authoriz-iag memorandum. 35

.c 'i ~. 2. Work after 11/2/81 was required by the item 2 of the EN-DES memorandum to be examined prior to applying the-primer. 3. Item 3 of'the EN DES memorandum would allow by_ omission of direction carbo zine primed welds _ directed as part of a sampling program be inspected for features other than quality, (b) Paragraph IV.B of R-82-07-WBN states that inspection of welds through carbo zine primer.could not be substantiated by a review of the records. This,would indicate that the ~ _ presence _ of coating was not' noted for any of the welds in the record reviewed by NSRS in support of R-82-07-WBN.

35. QID 4E STATEMENT R-82-07-WBN-06, Documentation of Weld Sampling Program Insufficient documentation exists to substantiate the weld'

~ sampling program conducted to verify-that visual weld inspec-tion could be makd through carbo zine primer. QUESTION Does this mean the "weld sampling program", or does it mean the "qualification program"?

RESPONSE

Paragraph IV.F of the R-82-07-WBN report discusses the insufficient documentation as related to 25 welds at WBN which were randomly selected for inspection along with two t specially prepared weld samples. The results of the inspec-tion of these welds were the basis for concluding that it was acceptable to visually inspect carbo zinc: coated welds. This paragraph would indicate the insufficient documentation referred to the "qualification program" welds.

36. QID 5A STATEMENT July 22, 1982 EDC 820722 006 - Initial OEDC response to-R-82-07-WBN includes (in part) (quote):

Inspection records from the Record Storage ~ Vault signed by inspectors who stated to NSRS that they made inspections through carbo zine have been examined. There is no entry on the record that the inspections were made through 36

carbo zinc. All records examined identified f ^ ~' the applicable approved procedure'(WBN-QCP-4.13) as the inspection document. Therefore, as previously stated, we conclude that the- ,'l inspections were made using an approved procedure. QUESTION (a).Did the inspectors indicate'whether'or not'they had made an "entry on the record," regarding the presence of such a coating? (b) Were they' instructed to make such an entry? ~ (c) Do the ~ record forms and procedure provide.for such an entry?

RESPONSE

(a) It cannot be determined whether the inspectors made any entries "on the record" regarding carbo zinc. The permanent weld inspection records do not contain such entries. However, the data sheets used for the weld sample programs had a space for recording "surface condition." A large percentage of the data sheets for the HVAC duct support weld sample sheets indicated that the surface condition was "painted." (b)-(c) Procedures allow for use of remarks to indicate conditions of interest to the inspectors which are not necessarily covered by the procedures. The record forms provide a space for remarks. Since inspection through carbo zine primer was author-ized only for sampling programs for weld configur-ation, it would not be expected that an inspector would remark that an unauthorized inspection was perfo rmed. Further, if the inspection was for an authorized condition, that authorized' condition would not be noted normally..This could explain ~ see why the sampling program inspections of July 1981 had a surface condition noted as "painted."

37. QID SB STATEKENT It has been determined that the reported inspections of structural welds involved were confined to the work of one engineering unit. As stated in the response to Item 01, CONST cannot find any record of inspections which were performed without an approval procedure.

37

e e l ,a QUESTION (a) How.was it "determined that the reported inspec-tions...were confined to...one engineering unit"? (b) Where the "sampling program" inspections performed to an "approved procedure" which defines the "record of inspection"?' If so, was this "record of inspection" checked for hotations of inspection through coatings?

RESPONSE

(a).The determination of possible inspections through carbo zine primer was made by discussions or interviews with the responsible unit superivsors. e (b) The sampling program inspections were performed to the corrective action specified in the appropriate'noncon-forming condition report. The inspection of record was that required by the engineer to document the correc-tive action on the NCR. The answer to QID SA(a) above. explains the data sheets for sampling programs as related to surface conditions. 38. QID SC QUESTION On May 6, 1983, OQA issued a memorandum to close NSLS item l R-82-02-WBN-24; why is this key event excluded? ' RESPONSE See response to QID 4C,

39. QID 6A STATEMENT June 21, 1983 -

EDC 830621 004 OEDC follow-up response to R-82-07-WBN-06 provided the following results of the 0EDC qualification program designed to ascertain the acceptability. i of inspection through carbo zine (quote): ~ 1. The qualification tests did substan-j tiate the ability to perform visumi j inspection of welds through primer for size, location, undercut, and overlap as permitted in G-29C. (OEDC has not interpreted G-29C as permitting acceptance of weld quality based on an inspection through primer.) H 38

4 9 i - p' - ^ -- i. '.c,', h s The qualification tests did not '. 2. - substantiate a practical.methodiofL visual-inspection-of weld quality; - through primer.in'a~ construction 9 - environment'. l- ~

.s QUESTION.

4 '(a) -What! action bas:takeninresponsetoth'eJfailuretof'the. . "qualification tests"Lto "substantiate _a'practi'cali method of: visual inspection,of weld:qualityfthrough_. z 1 primer"?J ~(b) 'If none', why? ' RESPONSE (a)-(b) No-furthe'r action.was deemed necessary since - inspection for weld quality through carbo.zine 1. -primer was -not authorized. 40. QID 6B STATEMENT. August 24, 1983 -.PS 3.C.S.4(a), Addendum 2, issued-to' limit scope of visual inspection through carbo zine to weld configuration as follows (quote): Revise paragraph 5.2.1 to read as fol-lows: 5.2.1 - Welds made'priur;to November-2, 1981, which are coated with carbo zine primer may be. visually examined for weld' size, undercut, overlap,.and arc strikes - in.accordance with this process'.specifi-cation.without removing the primer ~ 32 provided: (a).The carbo zine was sprayed in accordancefwith the applicable coating application specification. 4 (b) 'The carbo zine thickness is'not . greater than.5 mils as documented. in coating inspection records 4 and/or log books or as measured adjacent to thejweld. ' Coating.-in accordance with the specification. for coating application. e 39 f 'r-w e er* p D. W T-r 4-y -= tT+-)T--gze3-- 'N--(*'PTN-=y k e4.gY y FwsypW$ j1%her y, e7--p,

QUESTION (a) Why was the process specification revised "to limit scope of visual' inspection through carbo zine to weld configuration?" (b) Does this mean that.the previous version did not limit the scope to' just configuration? (c) Refer to Question 2C(c); is there a contradiction in these statements? RESPONSE-(a) The process. specification was revised at the request of the OQA to provide further-clarification of.the limits ~ of permissibility of visual inspection through carbo zine primer. (b) There was no change in the intended scope or appli-cation of the process specification. Since no process specification, memoranda, or. procedures in existance ~ prior to November 2, 1981, permitted the inspection of welds with any type of applied coating, it was con-cluded that all welds which had primer applied had received a visual inspection prior to their being coated. A sample program of welds which had been primed were stripped of primer and examined for veld quality showed that cracks and porosity were not a concern - in that there were none with rejectable levels of cracks or porosity. (c) There is no contradiction in that they are mutually. exclusive. The statement of QID 2C is that inspection through carbo zine primer for weld quality was not authorized, while the statement of QID 6B authorizes weld characteristics which are configurational in nature to be inspected through the carbo zinc primer if the welds were made prior to November 2, 1981. 41. QID 6C STATEMENT August 24, 1983 - OQA responded to OEDC that OQA had conduc-ted necessary follow-up actions associated.with R-82 WBN-06 and that the item was closed (0QA 830824 002). j a QUESTION (a) For OQA's closure of item R-82-07-WBN-06, what consider-ation was given to.the failure of the "qualification tests" (see Question 6A, above) and the revision "to 40 1 *.

is limit scope" of the specification (see Question 6B, above)? If none, why? (b) Whatieffect did the'above events have on inspections performed prior to the date of the events?

RESPONSE

(a) There was no consideration to be given in closure;of-R-82-07-WBN-06 to the failure of the qualification. tests to substantiate a method of visual inspection for weld quality through carbo zine primer. No inspection through carbo zine primer for veld quality was permit-ted. (b) The question is non sequitur in that events occurring after the inspections could have no effect on the inspections. Since inspections for weld quality through carbo zine primer were never authorized, fail-ure of the qualification tests to qualify such inspec-tions was of no consequence. 42. QID 6D ~ STATEMENT October 18, 1983 - WBN QCP-4.13 revised to delete pro-visions for inspection through carbo zinc. QUESTION (a) On October 28, 1983, did the procedure (WBN-QCP-4.13-VTC) "delete," or just revise, the provisions?

RESPONSE

The addendum to WBN QCP-4.13 RO dated October 28, 1983 accomplished the same clarification as the G-29C revision _of August 24, 1983 (see response to 6B.for intent). The dele-' tion of all references to inspecting through-carbo zine occured in revision 1 of WBN-QCP 4.13-VTC dated March 26, 1984.

43. QID 7A STATEMENT a

October 28, 1983 NSRS met with OQA and requested that OQA reconsider our actions to close R-82-02-WBN-02. The NSRS provided the following statements (quote): 1A. We disagree that this is closed for the following reasons: 41

g - .s '3 c 1. Inspectors within the electrical, instrumentation,. and civil welding groups stated they did inspec-tions. 2. OQA closure is based upon'only the electrical group. ~ 3. OQA hasl documentation that only three welds, inspected by the electrical group, had primer on them and those three have not been inspected yet. No other welds were identified by OQA; therefore, the statement in 1A, second section is incorrect. 4. Six of; twenty inspection personnel interviewed by NSRS stated they inspected through primer but could not remember which welds. OQA obtained at a .later date a list of welds inspected or not inspec-ted through primer from three inspectors. IB. 1. The inprocess. specifications G-29C, P.S.3.C.5.4(a), dated March 9, 1983, which allows inspection through primer has not'been revised. An andendum to G-29C dated August 12, 1983, which provides the revision has not been issued. 2. WBN denied in a memorandum from Kimmons to Cu!.ver dated July 22, 1982, that personnel were told to inspect through primer using only a memorandum. In a memorandum from the electrical supervisor to an OQA employee received by NSRS on October 25, 1983, states that he told his inspectors to inspect through primer. QUESTION (a) Was the meeting between OQA and NSRS for closure of "R-82-02WBN-02", or for closure of R-82-02-WBN-247 (b) If the later number is correct, and since this "Attach-ment 3" does not otherwise refer to NSRS item R-82 WBN-24, was this key event included in error? (c) If so, does it still apply to the carbo zine issue

RESPONSE

(a) The meeting was for neither R-82-02-WBN-02 nor R-82 o WBN-24..The January 30, 1984 OQA memorandum obviously ~ had a typographical error in its statement of the reason for the October 28, 1983 meeting. The NSRS finding R-82-02-WBN-02 was related to untimely audit reponses and had nothing directly to do with welding program findings. 42 ~ =

l' a, Finding R-82-02-WBN-24 was a broader base finding that the structural welding at WBN had not been accomplished in accordance with all the requirements of the AWS-DI.1-1972 structural welding code. The October 28, 1983 statements IA and IB, which were attributed to NSRS, address the issue of weld inspection through carbo zine primer. The carbo zine primer issue was one of eight subset issues given as examples of less stringent: implerentation of the AWSD1.1-1972 requirements. The NSRS finding R-82-07-WB,N-02 relates specifically to the issues presented on October 28, 1983 items IA and. IB, Thus, in all probability, the closure issue should- .have been R-82-07-WBN-02 not R-82-02-WBN-02 nor R-82 WBN-24.' (b) Answered in 7.A(a) (c) Finding R-82-02-WBN-24 is applicable to the carbo zine issue. The issue of weld insp.ction through carbo zine primer was introduced by NSRS as one example of eight alledged problems in finding R-82-02-WBN-24. The issue was subsequently expanded in.a special report on structural welding practices as findings R-82-07WBN-02 and R-82-07-WBN-06. Upon resolution of the R-82 WBN-02 and R82-07-WBN-06 findings, one example of eight examples of alledged problems cited in R-82-02-WBN-24 was resolved. 44. QID 8A STATEMENT Data Relative to Bounding Area of Concern The following information and data is provided to define: to the extent possible, the area of concern with respect to inspection of welds through carbo zine at WBN. 1. Types of welds - Structural welds governed by G-29C PS.3.C.S.4(a), including pipe hangers, cable tray supports, conduit supports, miscellaneous structural steel, duct hangers and instrument supports. 2. Date of welds - PS.3.C.S.4(a)' authorized CONST to inspect welds made before November 2, 1981, through carbo zinc. Separate from that specification, a number of sampling programs at.WBN have verified the accept-ability of the seven-types of welds idencified in (a) above up to the effective dates of the sampling pro-grams. The combination of the data is provided on Figure I to characterize the timeframe within which welds could have been made and subsequently inspected 43

] V '. ' ' i*, '., through carbo zine. Note that this does not imply that ~ these welds were actually inspected through carbo zinc'. - t '3. -Date of Weld Inspections - Inspection through carbo zine was initially authorized by EN DES on November:2, 1981 (SWP 811102 056). CONST verbally authorized the WBN inspectors to-inspect through carbo zine approximately December 1, 1981. This verbal authori- .zation was-rescinded on approximately December 15, 1981. PS.3.C.5.4(a) authorized' inspection through carbo zine from January 25, 1982,'to August 12,.1983. WBN QCP-4.13 authorized the inspection through' carbo zine from September 13, 1982, to October 28, 1983. 4. Location of welds - There is no data available which would bound the location of welds which may have been inspected through carbo zinc. 5. Inspection Units Involved - The NSRS review notes indicate that inspectors within the electrical, instru-mentation, and civil welding groups had stated that they had performed inspections through carbo' zinc. QUESTION (a) Does this "Bounding... information and data" apply to the "sampling plan" inspections? (b) If so, how does each of the items (2 thru 5) relate to the "sampling program"? (c) If not, how does the item 3 relate to the inspection? ~

RESPONSE

~ (a) No. The bounding information was developed to more , clearly define potential areas which fall within the This has nothing to do with-the bounds-of the concern. sample programs. (b) No answer required. (c) Item 3 identifies the dates varicus documents autho-rized (with restirictions as previously noted) inspec-tions through carbo zinc.

45. QID 8B 4

STATEMENT General - a. The NSRS report indicated: 44 e

i> 3 (1) _that of 24 inspectors interviewed, 9 believed inspec-tion through carbo zine had been permitted and 4_indi-- cated they had actually performed inspection through carbo zinc, (2) it appeared that 100 to 150. structural support welds had been inspected through carbo zinc primer without-approval procedures, and (3) that this could not be substantiated by a review of the records nor was it possible, to.specifically determine which welds were inspected in this manner. Note: The OEDC response to R-82-07-WBN-02 verified that the inspection records did not indicate that the inspections had been made through carbo zinc. QUESTION Refer to Question 5A, above.

RESPONSE

The response to this question is contained in the response to SA above with the following added information. An unasked question exists relating to the NSRS interviews of the 24 inspectors. Were the 100 to 150 structural support welds inspected through carbo zine primer without approved pro-cedures being inspected for initial acceptance of weld quality and weld configuration or as part of a sampling program for an NCR corrective action? Since the question was not asked and cannot be unequivocably answered one must rely upon the results of the sampling program for confidence that the welds which may have been improperly' inspected are acceptable.

46. QID 9A STATEMENT In March 1983, CONST questioned their inspectors to deter-mine if they could identify any welds which had been inspec-ted through carbo zine. Three (3) conduit supports were identified and were' documented under an IRN. These supports were later cleaned and reinspected and were found to be acceptable.

QUESTION (a) Why did it take 15 months (December 1981 to March 1983) for CONST to act upon this matter? (B) How were the three conduit supports identified? Records? l 45

f.,

i

RESPONSE

(a) During the 15. month time' frame, CONST was working with-information from anonymous' sources and no specific welds were identified. When an inspector admitted.he-had inspected through carbo zinc, all' inspection records signed by that inspector during the timeframe were pulled, the. welds cleaned and reinspected. There was not a 15 month time lag. (b). The three conduit supports.were the'only items specifi-cally identified as being inspected through carbo zinc. The inspector prepared an IRN which identified them. This'was IRN-E-BHP-144. 47. QID 10A t STATEMENT .1979 .1980 .1981 .1982 .1983 2 2. Cable Tray Supports 3 3. Conduit Sup-port 3 4. Miscellaneous structural steel 3 5. Duct Hangers 4, 6. Instruments Supports 1 QUESTION 1 (a) Where is the data for "Instrument Supports"? (b) Where is the data for structural steel (other than "miscellaneous")? 46 O

.: (-... La. y M 3 g.....-

I-

RESPONSE, (a) ' No.. sample program was performed on: instrument'sup-ports (b) Allethe sample' programs were for' structural steel-welds'. -Miccell.oeous structural steel'is one cate--

gory of structural steel. 5 0 1 i 1 f l% d I i 1 i h J n l 47 i

~48.'QID 11A

'-[..

.;..; y,. F, ), d i,* STATEMENT 1 A';CEPTANCE CRITERIA COMPARISON P.S.3.C'.3.2 P.S.3.C.5.4 l I'.S.3.C.5.4 -CRITIRIA AWS Dl.1-72 I; PRIOR TO 2/13/81 I AFTER 2/13/81 1 convexity .15 in. +.03 in. .15 in. +.06,1n. .lS in.'+.06 in, j Undercut .01 in. deep transverse Pipe hangers - 1/32 in. 1/32 in. deep on l to stress deep on stressed members stressed members. Undercut on non-1/32 in, deep _ parallel other components - -stressed me=bers 4 to stress 1/32 in. deep on c; tall not -be ~ cause stressed members except for rejection. l an additional-1/32 in.- 1 deep and 1/4 in. length-l not to exceed 10% of the i_ run. Undercut in non- -stressed members is not I cause for rejection. l l i Undersize 1/16 in. underrun for Cable tray supports - 1/16 in, underrun i 10% of length ICM 2688 showed for 10:: of length [ minimum size. j r Duct supports - 3/16 in. is etnimum size. 1/16 in. I underrun for "entire e j length on welds larger thaa 3/16 in. J l f 3 Arc strikes No are strikes or veld Random arc strikes and No are strikes ' par:er allowed weld s p tter are accept-allowed.. N,o. weld ~f and s weld spatter able if cleaned by wire f -- spatter allowed, brushing except nonexcessive t veld spatter is -G acceptable on carbon i i stesi surfaces not' ( being painted. L f ._is for Chanees ,chnies) 9 ) Mn v it: . Allowed by AWS D1.1-1980. No Code addressed non-stressed members, new tolerances allowed by ASME III, t NAVSHIPS 0900-005-9010 and NAVSHIPS 0900-000-1000. EN DES calcul4tions support the changes (SVP 821022013 and SWP 820127042). r .t a. - Not normally considered defects. Brittle and fatigue failure frequently } ..; d initiate from are strikes. These components are not subject to'nor designei ! Wald a,e u.- for fatigue failure. These mae tials would not fail from brit,tle: fracture f but from ductile fracture. l i 47A l 1 .f , ~.. _. ~ _. _

i

s. 7 e -.

a =- .t i k I @ c +'sg e ,a. QUESTION (a) What-does this "Acceptance Criteria Comparison" have to-do with the-carbo zine issue?- . (b) Where is the AWS DI.1-72' comparison for inspection-through primer?

RESPONSE

f - (a).7he acceptance criteria comparison shows that'there is -no difference.between AVS and G-29C for the carbo zinc issue. (b).There'4s no comparison because the inspection through.. . I ~ prie :r w t for sample programs and not' for.new insp ections l 4 4 k ? 48 ,c, u_

(CL h ~ ~ 4 TENNCCIEE VALLEY AUTHORITY 'O 4 ,, ~ KNOXVILLE. TENNESSEE 379o2 i OCT 211985 Mr. Harold R. Denton, Director 3 Office of Nuclear Reactor Regulation U.S. Ncelear Regulatory Conunission Washington, D.C. 20555

Dear Mr. Denton:

Your letter to me dated September 26, 1985, requested copies of investigation reports and related documents dealing with potentially safety-related employee concerns on TVA's nuclear plants. My letter to you on October 7, 1985, transmitted the information requested which our Nuclear Safety Review Staff (NSRS) had received as of September 30, 1985. In compiling the requested documents, NSRS inadvertently failed to include a response to an investigation report by Quality Technology Company (QTC). That response, dr.ted September 27, 1985, is provided as enclosure 1. A memorandum providing correction of certain information in the original response,' dated October 1, 1985, is included as enclosure 2. These responses relate to QTC investigation report number NS-85-001-001, "Visual Inspection of Structural Welds Through Carbo Zine Primer," which was provided to you in our October 7, 1985 submittal. This oversight was due to the fact that this was a unique report, with the I response directed to me instead of the NSRS. l If you have questions concerning the contents of this letter or the enclosures, please contact M. S. Kidd at FTS No. 856-2289. Sincerely, l [ I

• t:a -

. F. illis General Manager { l Enclosures cc (Enclosures): Mr. James Taylor Director Mr. J. Nelson Grace Office of Inspection and Enforcement Regional Administrator [ U.S. Nuclear Regulatory Comirsion U.S. Nuclear Regulatory Comission, i Washington, D.C. 20555 Region 'I { 101 Marietta Street, Suite 3100 Atlanta, Georgia 30323 -{] p h[ An Equal Opportunity Employer (( t

. tvaea es.o.een U,NITED STATES GOVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY 001 '85 1001 051 W. F. Willis, General Manager, E12B16 C-K To K. W. Whitti Director of Nuclear Safety Review Staff, E3A8 C-K FROM October 1, 1985 DATE t NSRS RESPONSES TO QTC INVESTIGATION REPORT, PRELIMINARY REPORT NO. SUBJEcr: NS-85-001-001 - RELATING TO VISUAL INSPECTION OF STRUCTURAL WELDS THROUGH CARBO ZINC PRIMER

Reference:

My memorandum,to yo6 dated September 27, 1985 (QO1 850'927 051) The reference memorandum contained two numerical errors in conclusion 7, pages 5 and 6 of the attachment. Please note that the number "36,000" should read 23,600 in both instances in conclusion 7. GD12hl K. W. Wlfitt Jni:WCS cc: RIMS. SL26 C-K H. G. Parris, MR6N011 B-C -KEEP 7:C .. ~.. Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan L~'- .; a...w...: ~..

T af A 4 5 !*695 i 9IT7lD' STATES GOVERN 31ENT a # M., cd107dM d M771 TENNESSEE VALLEY AUTHORITY J U01 '850927 051 W. F. Willis, General Manager, E12B16 C-K TO-K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K FRO)! ScPtember 27, 1985 DATE St BJECT: NSRS RESPONSES TO QTC INVESTIGATION REPORT, PRELIMINARY REPORT NO. NS-85-001-001 RELATING TO VISUAL INSPECTION OF STRUCTURAL kILDS THROUGH CARBO ZINC PRIMER

Reference:

Your memorandum to me dated August 28, 1985 (Q01 850827 051) The response to your request in the reference is provided in the attachment to this memorandum. The response involved input from and coordination of a large number of people from OE and OC as well as the NSRS.. The help from these people was fully cooperative in nature and in the tone of "let's put this issue to rest once and for all." In concert with preparation of this memorandum, we have been fully involved in the response to the companion memorandum you sent H. G. Parris requesting a samplisg program to reevaluate the quality of the welds at WBN. We are particularly impressed with the positive atti-tude of all the parties to the responses. We beliese the responses to questions raised in NS-85-001-001 con-tained in this meuorandum resolve any concern of premature closure and inadequate justification for closure of the issue of visual inrpection of structural welds through carbo zine primer. The sam-pling plan being provided by separate correspondence will resolve any reasonable questions concerning the quality of the structural welds at WBN. We are available to respond to any further questions you may have l concerning this memorandum. 1/cd& K. W.'Whitt' (/ JFM:WCS i Attachment ec: RIMS, SL26 C-K H. G. Parris, MR6N011 B-C KEEP 7:C e

Acer F,.y %,yu p+] .. r; Fridy wa, 0, ;;gy i( sj 97 i:s07 I want to thank If there are no other questions, Mur' 1 you for a nice, concise presentation and for finishing 2 y We will see you on the 6th of within our time limit. 3 February in the subcommittee. i 4 MR. MC CRACKENs Okay. f 5 11:00 Let's break and return at MR. WARD: 6 7 o' clock. (Recess.) Our next topic for discussion is a MR. WARD: 9 from the staff and then for the substantial ~ l 10 l briefing, first a briefing on the program of 2 i 11 part representatives from TVA, f reorganization of the nuclear activities at TVA. 12 l This first I First, a word to the subcommittee. 13 g. hour of presen:ation is incended to inform us, bring us up 14 ! to the current level on the status of the program at TVA and 15, u 16 the activities. After hearing that, following lunch, we have 17 j for committee allotted another 45 minutes or so just 18 discussion, taking what we have heard in this morning's 19 briefing after lunch to spend some time so than the 20 it believes it should committee can decide whether or not f l 21 play a more substantial role in reviewing the TVA program 22 if so, how the committee should than it has in the past and, 23 24 go about it. l If you would keep that in mind, if we have some 25 N ACE.FEDER/u., SEPORTERS, INC. 8043366v4 Nationwide Coverage 202 347 3700 e ++%

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s' j 38 08 time after lunch, we would like to discuss that. 3Gur 'l I will introduce Hugh Thompson, of To start out, 2 whom Mr. Denton described this morning 3 the NRC staff, NRR, as playing a leading role for the NRC in monitoring this 4 5 reorganization effort. i 6 Mr. Thompson. 7 MR. THOMPSON: Thanks, Mr. Ward. We certainly appreciate the opportunity to address the ACRS today on an 4 8 issue which the staff identified as one of the four major 9 items and areas in its 50.54(f) letter to TVA, along with 10 11 the specifics on the various sites. Corporate was one which we felt was extremely 12 l that we are reviewing prior to 13 important and a key element g 14 restart. recently TVA announced a significant 15 Ar you know, the staff, change in their corporate structure, which we, 16 l briefed the Commission on earlier this week and TVA in fact 17 briefed the Commission on yesterday. 18 l Part of the Commission's view of this step was 19 l that it was certainly an important step that indicated 20 aggressive action was being taken by TVA on this matter and 21 that our review of the submittals that have been before us f 22 l is kind of being held in abeyance, giving the new manager at f 23 l TVA and Mr. White &n opportunity for him to look at the 24 activiti3s that have been planned, those that are ongoing, 25 r ACE FEDERAL REPORTERS, INC. 322 347 3700 Nationwide Coserage 80 M 36 6 86 ~---e j

4 4 99 f :3 09 and then report back to the committee. Y.wr 1' this time the Commission's viec of the 2 So at corporate matters are pretty much being held in abeyance 3 I would pending TVA reaf firming their previous submittal. 4 think it would be appropriate for TVA to describe the f 5 details of these corporate changes that have been made. 6 7 They are here today to do that. So without me getting into further telling what 8 I think Jim Hufham and Chuck Mason of TVA are here 9 TVA did, to provide some specific details, and at the end of their 10 presentation if there are any particular questions, either 1 11 of the staff or to TVA, we would be pleased to respond. i 12 13 l MR. WARD: Thank you. l f 14i Mr. Hufham. MR. HUFHAM: Thank you, Hugh. 15 f We do want to thank the committee today for 16 17 j asking us to come back. We were here in October, where I 1 and we described as many changes to our 18 - talked to you, i l 19 I organization as we could at that time. f At that meeting I announced that we would have l 20 several significant changes coming, one of which would be i 21 Chuck Mason would be returning to aceume the position in i 22 23 charge of our nuclear operations. Since that time he has \\ is fulfilling that job. He is also our Deputy 24 returned. He t jff 25 Manager in the Office of Nuclear Power. ACE. FEDERAL REPORTERS. INL. 3 2 147 3700 Nationwkie Coverage M3%4646

100 .3 10 Chuck will be going into more detail today than I , c,tu r ' 1 was able to go into in October. The agenda is before you, 2 and we have handouts of the slides Mr. Mason will be using. 3 I would like to introduce So with that comment, 4 Chuck, who will make our presentation on the 5 6 reorganization. I mm Chuck Mason, Deputy Manager of 7 MR. HASON: the Office of Nuclear Power at TVA. 8 9 Also, as Jim indicated, I have a second title and a second hat as Manager of Nuclear Operations, directly 10 responsible for the three operating sites of the Nuclear 11 12 Services Division. 13 (Slide.) g As shown by the agenda, my presentation co'nsists 14 of a management overview and an update on the issues at each l 15 16 site. I O Because of time constraints we can't possibly 17 So I invite your questions at 18 f address each item in detail. I hope to allow time for questions at the end, so 19 any time. i that we can assure that we actually cover what you i 20 21 specifically wanted to hear. As the TVA Board told the NRC Commissioners 1 22 yesterday, the TVA nuclear program is in great difficulty. 23 The TVA Board is committed to restoring the confidence of 24 the Tennessee Valley Region, and the nation in TVA's 25

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I I B 101

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ability to safely and efficiently operate its plants. TVA 2 has taken aggressive steps toward that goal. 3 I would like to preface my presentation this 4 morning by confirming and explaining an item that Hugh 5 mentioned and that you have heard about here in the past 6 week. 7 Last Friday, the TVA Board announced that the TVA 8 was bringing a new top manager to the agency for the entire 9 nuclear program, retired Admiral Steve White. He starts 10 next Monday, January 13th. 11 Mr. White served in the Navy for 33 years and 12 retired after serving as a four-star admiral in charge of 13 j the Navy's Materiel Command. This command consisted of i l 14 1 250,000 people and was responuible, among other things, for i 1 15 procuring the Navy's ships, including their nuclear ships, 16 their aircraft, the electronic systems, shore facilities and l l 17 f other Navy supplies. i 18 He is a product of the nuclear Navy, and his 19 experience in the nuclear Navy ranged from serving aboard 20 the Navy's first nuclear submarine to serving as an i 21 assistant to Admiral Rickover, and at one time he was 22 commander of ninety nuclear powered submarines. 23 Mr. White comes to TVA for two years on an 24 employca loan through a contract with Stone & Webster 25 Engineering Corporation. lfy 4 ACE. FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800 3 4 4646 m .m f

102 S 12 4: The We have clearly defined Mr. White's role. r;sur ' 1 a written TVA Board entered into a written agreement, 2 memorandum of understanding, between him and the TVA Board 3 of Directors that establishes the objective of providing TVA 4 with the management capability so that at tha end of two 5 years the TVA nuclear program will be approved and TVA will 6 have enhanced capability to manage the program with 7 8 permanent TVA personnel. is the basic charge the Board has given. 9 That The essence of the memorandum of understanding is that 10 Mr. White has the responsibility and authority to manage our 11 12 total TVA nuclear program. Some of the highlights of this memorandum of 13 L 14 understanding are: Mr. White will have direct authority and I 15 control, and supervision 16 responsibility for the management, 17 l of TVA's entire nuclear program, including but not limited to the design, construction, maintenance, and operation of 18 all existing and planned TVA f acilities. This includes the 19 1 authority to establish management and operating policios, 20 including 21 procedures related to TVA's nuclear power program, training, and 22 any aspect of personnel management, 23 communications. He has direct access -- 24 I sort of rate success in nuclear lf i 25 MR. PEEDt ACE FEDERAL REPORTERS. INC. 202 147-3700 Nationmide Coverage M 3% e646

i !! 103 g Sg 13, 3,tur 1 activities in three components: people, equipment, and 2 design. the Did you say that Mr. White would really have 3 t 4 ability to control all three? i j 5 MR. MASON: Yes, sir, he definitely does have t f 6 that authority. 7 8 9 I 10 11 i 12 l 1 13 a 14 l l 15 16 f I 17 \\ 18 i 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. I %C 147 3700 Nationwide Coverage 8CO3)MM6

T ?..o ,,5 104 3 01 4 ggs 1 DR. MOELLER: To whom does he report? 2 MR. MASON: He reports directly to the general 3 manager and the board of directors. The general manager is 4 -- I don' t know how to describe it. He's the right arm of 5 the board of directors. 6 MR. EBERSOLE:. What happened to the dominant position that personnel used to have in operations? You 7 8 know, you got your people sent to you from a rather distant ) rather and certainly not very cognizant personnel department 9 than getting them through the more intimate path of 10 11 assessing their ability and getting them that way. 12 MR. MASON: I think I can address that better on 13 a later slide. g 14 MR. EBERSOLEs. All right; fine. I didn't see 15 it. 16 MR. MASON: Subject to certain reservations of e 17[ authority that have been invested in the board by the TVA Mr. White is authorized to hire, remove and assign TVA 18 j

Act, contract personnel as he deems necessary and to redirect or 19 restructure the activities and functions of TVA offices, 20 insofar as nuclear power activities are involved.

He has 21 22 direct responsibility for providing nuclear power budget and financial information and developing and directing budgets 23 24 for approval. The internal TVA activities and functions necessary for the successful operation of the nuclear lI7 25 4 ACE FEDERAL REPORTERS, INC. 202 347 3700 Nuionwide Coverage 800 33M646

105 g:t02 including the Nuclear Safety Review Staff, shall c 1

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2 report to Mr. White. He is authorized and directed by the board to cooperate fully with the United States Nuclear 3 Regulatory Commission and any other agency or entity, 4 governmental or otherwise with jurisdiction over or 5 to assure the safe, 6 interest in TVA's nuclear power program, reliable and efficient design, construction and operation of 7 8 TVA's facilities. He'll be responsible for all aspects of TVA's 9 relations with NRC and other agencies or entities. 10 White's first effort will be in analyzing, 11 Mr. 30 days, details of TVA's most serious 12 over the next At the technical, management and communications problems. 13 i end of that time, he will report his evaluations of th's 14 situation and his plans for corrective action to both the i 15 ' 16 boaJd and the NRC. I'm sure that you recognize the significant 17 18 j recent announcement that the authority which the board has given Mr. White and the comments I make today regarding the 19 20 organizational and plans, are subject to change. Mr. White 21 will be on board one day of next week. As I said, he'll be evaluating our situation and developing his own plan of 22 23 action. I personally don't anticipate sweeping changes, 24 that there I recognize and ask that you also recognize 25 but ACE FEDERAL REPORTERS, INC, %!2-347 3700 Nationside Comage 800 3364646

V 106 3 o3 ,,3v ' 1 will be some changes. Until specific changes are identified, we're 2 proceeding in accordance with our docketed, performance 3 4 improvement plan. 5 MR. MICHELSON: Question. You haven't showed us the slides in the handout of the organization of this Offico 6 7 of Nuclear Power. I do have it here in front of me, and and it lists a whole lot of names, but very few vacancies. 8 l Was this already agreed to by Mr. White? This l 9 l 10 organization. Or is this the one subject to change? 11 MR. MASON: This is the one that's subject to l 5 12 e.tnge. 23 MR. MICHELSON: This was prior to his coming 1 g i 14 aboard. 15 MR. MASON: This is the one in effect as of i 16 g today. I 17 l MR. MICHELSON: So this is part of what you see 18 j that we might see changed? 19 MR. MASON: There'll be some refinements. As I 20 say, I don' t anticipate sweeping changes. 21 MR. EBERSOLE:. Fine. One other question while 22 I've interrupted you. Is it anticipated that Mr. White be 23 in Chattanooga? 24 MR. MASON: He will be in Chattanooga. l I Ill%) 25 I MR. EBERSOLE:. Thank you. ACE FEDERAL REPORTERS, INC. XC 147 3700 Natiomnde Coverage 800 3 4 6646 - ~ _ _ - .c

"44f 107 9:1 04 ,y 1 MR. REED: One other point. Mr. White comes to 2 you from the Navy. The Navy, for many, many years, in the nuclear Navy has used aptitude screening and testing for its 3 4 nuclear Navy personnel. 5 Do you anticipate you might impose that? 6 MR. HASON: The management supervisory people we'-n 7 do not currently use an aptitude test battery of the same 8 nature as the Navy does. For our operators and craft I don' t think 9 people, we do use general aptitude battery. 10 he'll change that. He may want to go to something 11 l particularly in our body end training input to use in 12 aptitude test battery for engineers. I don't know that he 1 13 would, though, but that's a good possibility. gg l 14 MR. MICHELSON: One more question, as long as 15 you're interrupted. 16 l There has been in the press media talk about a i i 17 l nuclear consultant to the board. Is that still valid, or is this gentlemen now 18 j 19 going to take that function? 20 MR. HASON: This gentleman, because of his 21 experience and background, and the board feels like they no 22 longer have to have a separate nuclear consultant. 1 23 MR. MICHELSON: Thank you. 24 MR. HASON: I feel like we've made significant lf$ 25 progress in the last few months, and we have a solid course 1 ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage SCO3M4646

v 108 39 05 9 gw ' 1 of action laid out. As I indicated, I don' t enticipate sweeping changes but there will be refinements. 2 Could I ask a question of the old 3 MR. EBERSOLE. I don't see any reference to that. 4 office of Power? Jesse, do you thiink that'll come up as MR. WARD: 5 i We haven' t given him a chance to get of f.' 6 I he moves along? The old Office of Power no longer has 7 MR. MASON: as of three months anything to do with the nuclear program, I 8 9 ago or six months ago. 10 MR. EBERSOLE:. All right. That eliminates 11 that. Of course, we still coordinate with 12 MR. MASON: the operation people on dispatching power. 13 g Do they still order what plants 14 MR. EBERSOLEs. 15 they need? We have a Power Supply Planning Group MR. MASON: 16 l facility needs; yes. 17j that looks at long-range I 18 l (Slide.) I'll put this "a begin discussing where we are, 19 This is slide back up which we showed to you in October. 20 ' 21 the organization that was put in place in July 1985. One of the things it did was to bring all the key players in the 22 nuclear program under one single manager, Hugh Parris, 23 reporting directly to Bill Willis. 24 h 25 MR. EBERSOLE:. It looks like Mr. Parris has got ACE FEDERAL REPORTERS, INC. 800 33MM6 202-}47 3700 Nationmide Covercse

V 109 06 9 :: 1 a big ear. , -s ( 2 MR. MICHELSON: Is this still valid? Is Mr. White coming aboard? 3 This is the old organization 4 MR. WARD: 5 MR. MASON: I pointed out this was presented to 6 you in October. This was the first time that TVA had all the nuclear people under a single manager reporting to the 7 the ear board and general manager, where he can really get 8 This of the board of directors on nuclear problems. 9 The included the key of fices and group s which are involved. 10 11 l principal offices, I won't say the key, because there wsa a 12l couple of others that the board of directors and the general the Nuclear Safety manager a this level above Hugh Parris, g 13 14 Review Staff and several consultants. 15 MR. EBERSOLE. Could you comment on the nuclear 16 background of Mr. Willis and Mr. Parris. MR. MASON: Mr. Willis has no direct nuclear 17 { 18 3 experience. He came up through our construction l I don't believe he was involved in the 19 organization. Is constructiors of any of our nuclear facilities, directly. 20 there anybody who can amplify that? i 21 Mr. Parris has no direct nuclear operating 22 He's been involved in the 23 experience or design experience. 24 nuclear program since day one at TVA, as a part, originally, of the Power Supply Planning Group that evaludted 25 ACE FEDERAL REPORTERS. INC. 20."-147 3700 Nationwide Comge 8043)M646

V' 110 3 01 . c,tv ' I alternative power supplies. And after that, in the early days of Browns Ferry and the evaluation of different types 2 for the last few years has been 3 of plants. He, I guess, senior manager involved in the nuclear program with no 4 direct nuclear operation and construction experience. 5 6 MR. EBERSOLE:. So I giless critical decisions which are nuclear-related will start with White and proceed 7 8 to you? Is this correct? 9 MR. HASON: Put the next slide up, and I'll 10 discuss that a little bit. 11 (Slide.) We now draw this organization chart a little bit 12 13 differently. It's still basically the same. Everybody's g 14 under one single manager, but we draw the chart 15 differently. We want to show the chart that reflects our present areas of emphasis and future areas of emphasis. 16 the support of the operations phase of our 17 f Consequently, rather than the design and construction 18 nuclear program, 19 phase. For years and years, we've been a design and 20 construct agency, and that's where the principal effort has 21 22 been in building new plants. The operations people took 23 over the plants and operated them, I guess, as best we 24 could. I guess that's one way to put it. We didn' t have good coordination and teamwork between the design, the lf") 25 ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800 3)HM6

N 111 39 08 9 organization and the operating organizacion, because they gdw 1 had one charge to design and build plants, and we had a 2 3 charge to operate them. I think-the organization we've got now brings all that together and focuses on the fact that 4 we're not longer in the construct mode or the design mode, 5 It's 6 even though we' re finishing a couple of projects. primarily support of the operating organizations. 7 8 MR. MICHELSON: Excuse me.. Does this chart now mean that Mr. Parris has nothing to do with the nuclear 9 10 generation? MR. MASON: That's correct. As of last Friday, 11 fj Parris no longer has anything to do with the nuclear 12 l Mr. 13 program. 14 i MR. MICHELSON: This block at the top replaces 15 the one called "Parris" in the previous slide? i i 16 { MR. HASON: That's correct. Mr. White is the 1 7 1, Manager of the Office of Nuclear Power. He reports directly 18 s to Mr. Willis and the board of directors. You can put s Mr. Willis and the board of directors in one block, because 19 20 they function as an entity. I'm shown under Mr. White as Deputy Manager of 21 the Office of Nuclear Power, and my second hat still shows 22 for me as Manager of Nuclear Operations directly responsible 23 24 what we call the three operating sites -- Browns Ferry, have Sequoyah and Watts Bar, even though Watts Bar does not ll") 25 ACE FEDERAL REPORTERS, INC. M.347 3700 Nationwide Coverage W 3M4646 _...g.__

112 ,09 09 Tibw I an operating license, it's close enough that it's operated 2 and managed in the same fashion. 3 DR. OKRENT: Question. The engineering and 4 construction people that are shown in the blocks on the are they people who are devoted 100 percent of the 5 r ight, time to nuclear power programs or they part of some larger 6 7 block of construction? 8 MR. HASON: The manager in engineering, I have in back of the room, and I'm going to have him address part of 9 10 that, if I can' t adequately state it, or if he disagrees 11 with the way I state it. I His primary emphasis is, of course, nuclear. 12 guess probably 99 percent of his time is dedicated to the 13 g He has an engineering staf f that's 14 nuclear program. 15 available for other TVA agencies to call on, if they have an l 16 engineering problem. If a fossil plant has an engineering 17 ) problem, they write a contract to get services from Mr 18 f Cantrell's organization. The incumbent is not involved in 19 that, other than as a far removed supervisor. He's got 20 lower level people that actually handle that. So I would say this time it's probably 99 plus percent of the time 21 22 ' dedicated to nucler. 23 MR. WARD: But this is the only engineering and 24 design of fice in TVA. 25 MR. HASON: No, I won't say that. Within the lf"] ACE FEDERAL REPORTERS, INC. 202-147 3700 Nationwide Coverage 800 336 66 4

113 , :) 10 Of fice of Power, as Mr. Ebersole mentioned a while ago, we . c,w 1 have a group of designer people who des'ign transmission 2 3 facilities, substations, and transmission lines, and the communications networks associated with those transmission 4 5 facilities. 6 MR. WYLIE: This is the only pr plant, though. This is the only power plant design 7 MR. HASON: 8 organization. 9 MR. CANTRELL: I'm Bob Cantrell, the Manager of 10 Engineering at TVA. Since Chuck has come back, he's not aware that I 11 l now also have the transmission system engineering 12 13 capability < The Office of Engineering and Construction, all gg of the engineering design and construction efforts, report 14 i 15 i in the nuclear program, because that's where the 16 a . predominance of our business is, except for the ferti.lizer i 17 ) people. 18 i MR. EBERSOLE. So this includes the fossils and b 19 ' the hydros, the works. 20 MR. CANTRELL: We have those people. It's a 21 small portion of our work, but we feel we can share some 22 expertise, but they are generally dedicated small groups, to 23 both the fossil and hydro program. 24 MR. WARD: Can you give us a fraction there? fraction of your office's effort will be devoted to lf"j 25 What ACE-FEDERAL REPORTERS, INC. 202-147 1700 Naionwide Coverage 800 336 6646

114 69 11 4 zy$w 1 nuclear? Greater *:han 80 percent. MR.-CANTRELL: 2 MR. MICHELSON: At some point, are you also going 3 is divided between site to clarify how the engineering 4 engineering and central engineering, since they're under 5 They have dif ferent supervision, as I understand it? 6 differnt responsibilities. 7? MR. MASON: I'll get into that in just a minute. 8 I would like to go through this basic 9 organization chart and point out that some of the people 10 maybe that are different now than who are on board six 11 As I months ago or held these positions six months ago. 12 is indicated, one of the significant moves with Mr. White, 13 g that the Nuclear Safety Review Staff now reports to the line 14 That will be effective next 15 organization and Mr. White. 16 Monday. Kermit Whitt is the supervisor. He's had that job l and has been affiliated with that organization since it was 17 18 l born, I guess. That's a downgrading of the MR. MICHELSON: 19 reporting responsibility of that organization, which used to i l 20 it's to the office l be to the general manager and now 21 22 manager. MR. MASON: That's correct. 23 So the board now longer gets MR. MICh'ELSON: 24 indirect reports. direct reports from Mr. Whitt but rather, 25 ACE FEDERAL REPORTERS. INC. M3364646 Nationwide Coverage 202 347 3700

115 .a 22 MR. MASON: That's correc t. 1 I.: I see a degree of isolation from .V MR. EBERSOLE. 2 the buck falls on the board and the general manager, in that i 3 4 your table now. this is a big part of our MR. MASON:

Well, 5

~ is accountability. emphasis in our new organization, 6 l Mr. White is not only accountable for production, he's .7 He's accountable for communictions accountable for quality. 8 He's accountable for employee morale. 9 Who's accountable for independent MR. MICHELSON: 10 review of safety, since he's responsible for direct? 11 We also Our quality assurance group. i MR. MASON: 12 l have nuclear safety review staff, a nuclear safety review 13 g board that's neutral of all utilities, who provide t hat i 14 l 15 independence. MR. EBERSOLEs. Chuck, in the course of your 16 a 17 l presentation, are you going to be able to take, let's say, hypothetical job that originates by an order from Power a I 18 q It goes to is issued to Design to produce and is produced. 19 i Construction and it goes to Operation, and close the circu t 20 from the to be sure that the Design organization receives 21 ultimate usor confirmation that it has been built a 22 being run according to the integral concept. J 23 That was one of the deadly things that never 24 I think everybody would be much interested in lf""( 25 happened. ACE FEDERAL REPORTERS, INC. 800 33 4 646 Nuionside Coverage 202 347-3700 I

116 g 913 g I can't visually see it up rt$ 1 how you closed that circle. 2 there. Maybe you can check it through. It's not accurately reflected on 3 MR. KASOM: either of these organization charts, but if you look at a 4 later one -- I'll put it up -- I think you'll be able to see 5 6 it. 7 MR. EBERSOLE. Okay. 8 9 10 11 12 14 15 16 17 i 18 19 20 21 22 23 24 25 ACE. FEDERAL REPORTERS, INC. E.347 370) Nationwide Coverage 2 336 4646

l 117 ) ,10 01 By the way, did Mr. Whitt check out

8bc 1

DR. OKRENT: a large fraction of the difficulties that TVA has found 2 3 i self in? Certainly, their reviews had 4 MR. MASON: indicated that we had symptoms of the situations we'd gotten 5 ourselves into, not only his but reports from INPO on the 6 NRC ctaff and our quality assurance organization said there 7 found ourselves were syuptoms before we got to the place we 8 9 in. Those symptoms obviously were not acted upon 10 11 properly. DR. OKRENT: Were his comments very strong so I 12 [ face? 13 they would hit you in the g 14 ' MR. MASON: A lot of them were, I can assure you 6 15 l of that. Kermitt, would you like to comment on that? 16 j 17 l MR. WHITT: I'm Kermitt Whitt, Director of the Nuclear Safety Review Staff. 18 t We some of the statements were very strong. 19,

Yes, 1

There were no wrote our statements as we saw them. 20 in the Had we been extremely smart l 21 constraints of any type. management control systim and the management practices, NSRS 22 should have seen what was coming and should have done 23 whatever necessary to tell the line organization that this 24 is what was ahead of them and to take corrective action. ih 25 ACE FEDERAL REPORTERS, INC, 800-336 4646 202 147 3700 Nationwide Cowrage ~-__r=_-~a--.~...-

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y 118 , p 02 We had whatever clout was needed to do that. I cl/bc 1 2 can' t speak for everybody in NSRS. I guess I wasn't smart 3 onough to put all this together and show it in advance. 4 MR. MICHELSON: At what point in time are you 5 responsible for this function? 6 MR. WHITT: What period of time? Since October 7 of 1977. I'm sorry, 1979. 8 MR. MICHELSON: For this function, you were in 9 charge of the Safety Review Staf f in '79? 10 MR. WHITT: I was Director of the Nuclear Safety 11 Review Staff starting January 3, 1985. 12 MR. MICHELSON: So it's very recently that you're 13 responsible for it. gg 14 MR. WHITT: The total organization, yes, sir. 15 But, since '79, I've been responsible for the operations 16 part. 17 I MR. EBERSOLE: Kermitt, did you actually probe 18 J into design issues and make resolutions of them? I'm just 19 probing into a dark corner just to see to what degree you 20 could go down in the corners and dig up the dust. 21 MR. WHITT: We could and can probe wherever we 22 think needs to be probed. .BERSOLE: Then you've got the wherewithal to 23 MR. 24 interate where you think you should probe. I'll take a case 25 in point. The old 10-inch main steamlines which feed the lf"$ ACE. FEDERAL REPORTERS, INC. 202 147 3700 Nationwide Coverage 800 336 4 46

O ,10 03 119 1 y//bc 1 HPCI pumps has been a design issue for years. That's a 2 potential for disaster if they blow. 3 Are you acquainted with that? 4 MR. WHITT: Not personally. I'm not personally 5 accuainted to talk about it, but I am aware 6f it. 6 MR. EBERSOLE: That's all I wanted to know, 7 whether you've judged that it's all right. O MR. WARD: One more question. Go ahead, Max. 9 DR. CARBON: Wha t vere your responsibilities, 10 since..1980 or some thing? Prior to January 1985. 11 MR. WHITT: I was, for a couple of years prior to 12l that, I was Assistant Director, and prior to that -- 13 DR. CARBON: Of what? 4 14 MR. WHITT: Nuclear Safety Review Staff. Prior 15 to that, I was head of the Operations Review. 16 DR. CARBON: Thank you. 17, MR. WARD: Chuck, if we continue at this pace, i 18j will you be able to get through all your presentation in 30 19 minutes? Or do we need to let you go? 20 MR. HASON: We need to speed it up. 21 MR. WARD: Why don' t we hold questions and 22 comments for a while. Go ahead. 23 MR. MASON: We certainly recognize that 24 organization charts don' t make things happen. In our 25 refirament of the organization, we picked the people who ACE FEDERAL REPORTERS, INC. N2-347 3700 Nationwide Coverage SOCK 3%4646

i l 120 ,10 04 w/bc 1 were best-qualified for the positions, that we could fill 2 with TVA people. We sup; '.emented the TVA people with new hires 3 from outside TVA and we've used contractors to fill line 4 positions where we do not have adequately experienced 5 personnel and we've been unable to recruit them. 6 7 That's something that's new for TVA; it's never The basic criteria that we used in 8 been done before. 9 selecting people are the proven track records in the areas 10 that we feel are most important. And that's an attitude of 11 quality first, good communicators, motivators, sense of responsibility and accountability, team players as opposed 12 g 13 ! to turf-builders. 14 We feel like our key managers set the example. 15 Good communications teamwork. Frequent discussions so we i 16 can speak with one voice as an agency. 17 (Slide.) 18 l I'd like to review with you some of the key 19 people that have been brought in to make our organization 20 more effective. In addition to Mr. White', we've brought in Dica 21 22 Denise, who is the assistant to me. Mr. Denise comes to TVA 23 with more than 20 years experience in nuclear power and he's 24 a well-respected name in the industry. He served most 25 recently as the Director of the Division of Reactor Safety i ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 80CL3364646 ____n____-___.- - n_ _ _ ' ' ' ~ ~ ' '

121 ,10 05 J/bc l' with NRC Region IV. In his position with TVA, he'll be 1 spearheading special projects in design. 2 3 Primarily, right now, he's involved with Watts He had early nuclear experience with Babcock and 4 Bar. 5 Wilcox and the nuclear ship, Savannah. After that, he was deputy manager of DOE's Sava'nnah River operatiors. 6 Another man that we brought in is Lagrence 7 He has over 25 years experience in the nuclear Martin. 8l 9l power industry, most recently as section chief in Region IV He came out of the Nuclear Navy, worked for Duke 10 with NRC. Power Company in the engineering part of their organization 11 l during the Oconee startup; and with McGuire before he went 12 13 to NRC. 14 L Assistant to the Manager of Nuclear Operations, has I don't know how many years of 15 16 experience in nuclear power. He started out with the 17 l initial crew at Farley, went to NRC in Atlanta. He's been l 18 ' with INPO essentially since day one of its existence, and he has served as supervisor of the Radiological and Chemistry 19 20 Division of INPO. Bill Bibb, who is our site director at Brown's 21 Ferry, came to TVA under a contract with the Management 22 23 Analysis Company. Bill has over 30 years experience in the 24 nuclear power field in plant operation and project 25 management. He's had an SRO license at several facilities. l) ACE-FEDERAL REPORTERS, INC, 2 347 3700 Nationwide Coserage 800 336 6646

v i 122 ,10 06, i?/bc 1 He participated as a GE startup supervisor and engineer at a 2 number of plants, foreign and domestic. He was project 3 manager of the WPPS II project when it first got licensed a 4 yaar and a half or two years ago. He's got some good 5 experience and he's proven to be a valuable asset to Brown's 6 Ferry. 7 Some of the key TVA people that we've moved 8 around, Willie Brown, we've moved to Watts Bar as project 9 manager because he's got a proven track record as a shaker 10 and a mover and a good communicator. He's made 'significant 11 improvements in the construction operation at Watts Bar. 12 Bill Caudill, who was one of Mr. Parris' three ll 13 assistants on the previous slide, we've now moved him back 14 to Watts Bar as site director. 15 Part of your questions, Mr. Ebersole, on 16 personnel, we have moved down from our corporate personnel 17 staff the head of that staff, who is now working directly ( 18 l for Mr. White and myself, and has been in that organization ) 19 for about the last four months to help us developing some 20 employee development plans and better communications 21 ability; and also the ability in helping us trying to 22 recruit and bring on more new people. 23 Another one of the assistants, the comparison j 24 staff on the previous slide, is Jim Darling, who is now the 25 project manager. ACE FEDERAL REPORTERS, INC. T? 147 3700 N<M_W_ _ 800 3364 646

123 ,10 07 '7/bc 1 MR. EBERSOLE: Do Whitt and Ziminski stand 2 parallel, eye to eye? 3 MR. MASON: I've not seen yet. Mr. Whitt will 4 likely report here on Monday when Mr. White comes aboard. 5 As of today, he still reports to Mr. Willis. 6 MR. MICHELSON: Where ic the responsibility for 7 Bellefonte? 8 MR. MASON: We have a project management team. 9 Mr. Darling is responsible as project manager for both the 10 design and construction of Bellefonte. That same situation 11 l exists on Watts Bar Unit II, whereas, Watts Bar Unit One, we i 12 j consider as an operating facility. 13 DR. REMICK: Chuck, where is the training center? g 14 l MR. MASON: The training center is under me in i 15 l this organization. I 16 DR. MOELLER: Maybe you said this earlier, but is 17 l Mr. White happy with this organizational scheme? 18 f MR. MASON: I have not talked to Mr. White in 19 ! detail about this. Mr. White came into TVA back in November 20 and spent about three weeks with a team of people. I know, 21 in his comments as we're looking, he did not see any basic 22 holes in the way we were organized. 23 DR. MOELLER: At least he's happy to begin this 24 way. f 25 MR. MASON: Yes. Like I indicated, I'm sure he ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationside Coverage 800 336-6646

124 ) 08 7 We have a vacancy that I'm will have some refinements. .t/bc 1 trying to recruit for, and I'm also trying to work with an 2 architect-engineer to assign me a contractor to fill that 3 position for some period of time, until I can recruit or 4 train one of my own people. 5 That's a position that I'm holding open until 6 is in basic Mr. White actually gets on board, to see if he f 7 8 agreement with that program. And you've worked or know Mr. White DR. MOELLER: 9 well enough to know that you can work with him? 10 I've I'm sure I can work with him. MR. MASON: 11 l including admirals before. worked with a lot of people, 12 (Laughter.) 13 22 years in the navy in the MR. MASON: I spent 14 I've had a lot of interaction at a lower 1 15 naval reserve. that time. And I survived it. 16 ~ level with an admiral during (Laughter.) 17 ' t (Slide.) 18 ' This is a backup slide. I don' t know if it's in j 19 I'll try to address Mr. Ebersole's 20 your package or not. I'd first like question on how do we handle design changes. 21 to point out that I read through the transcript of the last 22 23 meeting. It seemed to me that some people felt like all we had done with the site director is change the name of the 24 And that's plant manager and put a lot more bodies in it. f 25 ACE FEDERAL REPORTERS, INC, 800 33M646 202 347-3700 Nationwide Coverage L!

C 125 10 09 4 g/bc. 1' not the case at all. What we've done with our site organization is 2 3 that the plant manager is still there, still has basically 4 the same responsibility he's always had, that is, operations i 5 and maintenance of the plant. What we've tried to do with this site 6 organization is relieve him of a lot of the burdens of j 7 8 worrying about procurement of material for design changes, warehousing, budgets, plant roads around the perimeter, a 9, 10 l lot of peripheral stuff that his attention will get diverted 11 i on before he'll provide the support for it. j 12 Now, so he'll concentrate on the operatio,and f 13 ! maintenance of the plant. One way of lorking at this, if \\ in 14 you want to compare it with a private utility, we have, 15 essence -- we don' t have vice presidents, but we have 16 essentially a vice president in charge of that facility. 17 If it was a single unit utility, I think you 18 could relate very well with what we're trying to do here. 4 l 19 We put the appropriate people to support that facility on a 1 20 single unit utility. This would be practically the whole i 21 corporate organization on a single unit utility. He has the authority and responsibility to see 22 23 that that facility is operated and maintained safely and 24 properly. One way of looking at the design organization 25 that we have at the site with the private utility, private i ) ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800 33M666

126 ,10 10 i utility has a design organization at the site. Generally, r//bc

• 1 i

they'll call on an architect-engineer for the resources to 2 do modifications that are still funneled back through this 3 4 design entity at the site. 5 We look at our Knoxville office. Mr. Campbell's organization in Knoxville is our architect-engineer. 6 7 MR. MICHELSON: Does that mean Design Services 8 reports to him? 9 MR. tiASON: Design services? Let me tell you, When this is one of the areas that we're going to refine. 10 11 l we set this organization up, you're familiar, Carl, with 12 some of the past practices of TVA, of turfbuilding and g 13 l arguing over whose responsible for what. When we set this organization up, the site organization went out and hired us 14 15 a design guy. The design people from Mr. Campbell's organization that were sent down there still reported to 16 17 < him. 18 He, not their MAS. And that's really where their I 19 loyalty was. So we had an extra layer of people in here. 20 Our own design guy reported to this fellow, and was 21 evaluated by this fellow and was charged with keeping an eye 22 on those guys from Knoxville that were sent down. We're going to eliminate that layer, responsible 23 24 directly to the site director. This guy will make out lf"' 25 project manager's appraisal forms. ACE FEDERAL REPORTERS, INC. 202 147 3700 Nationwide Cosetage 800 33M646 LI

127 ,10 11 ^

1. A3c 1

MR. MICHELSON: Where are the design decisions 2 made that directly influence the safety of the plant? 3 MR. MASON: They'll be made right here. 4 MR. MICHELSON: Those will not be cleared back 5 through Knoxville? He'll report to the site director? 6 MR. MASON: He will have the responsibility for 7 the design director. That's the design we're working on 8 now. 9 MR. MICHELSON: And you'll have there the 10 adequate expertise to cover all the disciplines involved? 11 MR. MASON. That's correct. And if we need 12 additional resources on a particular area of expertise, 13 we'll call on our tech engineer. He'll submit to this man J e l 1 14 whatever technical expertise he needs. 15 MR. MICHELSON: The problem I have is why do you f 16 need to have an engineering organization in Knoxville if 17 I this is where t.he design decisions are made? 18 ; MR. MASON: One reason we have a design 19 organization ira Knoxville is that we can't have all the 20 technical ability at the site. 21 MR. MICHELSON: They act as consultants, I 22 gather. 23 MR. MASON: They act as an architect-engineer in 24 home office in Gaithersburg or San Francisco. They also lf" 25 develop design criteria and design procedures that are used ACE. FEDERAL REPORTERS, INC. %C-347 3700 Nationwide Coverage 600 3364646

128 4 10 12 They set the standard that the actual technical 3 W/bc. l' on site. decisions and responsibility for those technical decisions 2 will answer to that man on site. 3 Who is in charge of the safety at DR. OKRENT: 4 5 the site? Our quality assurance organization MR. HASON: 6 l and our nuclear safety review board. 7 Which are not on that chart. DR. OKRENT: 8 We have a quality assurance staff MR. MASON: 9i here, but quality assurance is centralized in our 10 11 organization. But your nuclear safety is MR. MICHELSON: 12 The boe.rd i's in the operating -- 13 there. g The nuclear safety review board is MR. MASON: 14 for Nuclear, again under the executive vice president 15 Steve White. correlated to a private utility. 16 Everybody goes to Steve White l MR. MICHELSON: 17 l 18 eventually, yes. Where on that chart do people go with DR. HARK: 19 ' their complaints, or worries? 20 it's shown on MR. MASON: It's not shown on here, 21 We have an Employee Concerns, long-term 22 the previous chart. We have one manager who reports 23 employee concerns program. He has at each site at least directly tv ins and Mr. Whita. 24 l one individual whose sole responsibility is to be a f "") 25 ) ACE FEDERAL REPORTERS, INC. 800 3364M6 202 347 3700 Nationwide Coverage .- ~. : . ; : :.: p _.,.. _- y,=., : - ~,-..,.. ;....,3__

v - ~' ; 129 ,10 13 J i listening post for employee complaints. l/bc DR. MARK: All right, they don't have to go to 2 3 Knoxville then. We have a man on each site, 4 MR. MASON: No. including Knoxville-Chattanooga, by the way. 5 6 7 8 9 10 11 12 13 g 14 15 16 17 < l 18 19 20 21 22 23 24 f 25 ACE. FEDERAL REPORTERS, INC. 8 @ 3366646 202-347 3700 Nationwide Coverage i ,., ~.

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l 130 11 01 the bottom there you have got ivbdr 1 MR. EBERSOLE: At 2 three managers, right? 3 MR. MASON: These are site directors. Those are the site directors? 4 MR. EBERSOLE: 5 Okay, I understand. Those are the site directors. those are little islands that are complete 6

Now, 7

in themselves, aren't they? 8 MR. MASON: No, they are not complete in They have the responsibility and authority. At 9 themselves. the operating end is a thread of continuity to assure they 10 don' t develop any totally independent islands. 11 l For example, in this organization we have 12 chemistry people, health physics people that go from plant l 13 to plant to certify that our policies are being carried 1 14 We are developing policies and directives that are 15 out. issued in this office to ensure that we have a common goal 16 17 j at each of the plants. I they are self-supporting? MR. EBERSOLE: But 18 l I am not clear about that. 19 20 (Slide.) Chuck, could I ask you a question 21 MR. WARD: about that because I think it is related? 22 Your design Do your design services go there? 23 24 services group. Is that strictly liaison for the Knoxville 25 design office? Can they use smaller projects? ACE FEDERAL REPORTERS, INC. M336 6646 %12 347 3700 Nationwide Coverage .- -. ;, _ a.-_. - aa

131 l ,11 02 l' abur 1 3R. MASON: They do saything that chey have *.he 2, capability to do without additional resources. Browns Ferry we have probably 200 people. At 3 At 4' Sequoyah we have about 150. At Watts Bar we are built up to 5 about 150. 6 MR. WARD: But projects over some magnitude go to b 7 Knoxville? 8 MR. MASON: He still has the responsibility for He may take the project and go to an outside 9 them. 10 architect engineer. MR. WARD: All right. What about the 11 f 12 f modifications block? What does that mean? 13 MR. MASON: On an operating site -- now, this is 14 Browns Ferry. The effect of Mr. Ebersole's question, he 15 does what on a design modification? If the plant manager sees a need for a design 16 l k 17 i modification, he writes a design change request, and basically -- I will ekip a lot of details -- he goes to the i' 18 I design organization for scoping the solution for his t 10 t 20 problem. If he agrees with the proposed solution, he okays l 21 it and goes back for a detailed design. l l Once his design modifications group, which is 22 1 comparable to what you might consider in construction -- 23 24 they are the implementers of the modification that the 25 design generates. They provide field engineers and craft ACE-FEDERAL REPORTERS, INC. M.347 3700 Nationwide Coserage 800 33H656 .a _.. ~

i l 132 g li 03 1 personnel to implement the modification. They do the (Sybur planning, make sure the material is there, make sure that 2 the work plan is developed in the proper degree of detail. 3 They go out and do the work when it shows up on schedule. 4 When it is finished and we are ready to test it 5 6 and verify that it meets the test criteria, Design Services, 7 when they design it, they will specify what When they get post-modification tests have to be done. 8 through implementing it, we have got some test engineers who 9 it meets the go out and do the actual testing to verify that 10 11 design requirements. 12 MR. WARD: We seem to have some burning i 13 questions. Max, Paul, and then Dave. 14 DR. CARBON: The design modifications done by the for the safety 15 Design Services Grnop, who reviews those 16 aspects? g The Plant Operations Review Committee 17 MR. MASON: u the design organization does unreviewed safety 18 i does it -- 19, questions and determinations. Then the Plant Operations 20 Review Committee does it. i 21 DR. CARBON: Does the Plant Operations Review Committee have all the expertise to handle the systems 22 23 interactions? 24 MR. MASON: Not necessarily. That is why the i design services organization -- when they do the der,ign, a 25 ACE FEDERAL REPORTERS, INC. 202 147 3700 Nationwide Cosetage 80433MW6

w i;9 " i f 133 ,11 04 , cur

• 1 they introduce the unreviewed safety questions.-

~ 2 DR. CARBON: And they will have a full complement 3 of safety people? 4 MR. HASON: Yes. If they don't have it, they 5 will get it from the architect engineer or from our 6 Knoxville facility. 7 DR. CARBON: Then Mr. Whitt's group simply looks 8 over some of them? 9 MR. HASON: Mr. Whitt's organization is not 10 necessarily in the modification. The Nuclear Safety Review 11 Board reviews and assures that the safety evaluations are 12 ; done properly on modification. Then Whitt can pick and 13 choose what he looks at. l 14 DR. CARBON: What does the nuclear safety staff 15 do? 16 MR. HASON: That is the Nuclear Safety Review 17 Board now. They are the staff for the Nuclear Safety Review 18 Board, the full-time staff for the three Nuclear Safety 19 Review Boards. Each plant being of a different manufacturer i 20 and different vintage, has a different Nuclear Safety Review 21 Board. It is a part-time job. They meet at least once a ) 22 quarter, or more frequently as necessary. It is a typical l 23 Nuclear Safety Review Board. That is the permanent staff of 24 the board. l 25 DR. CARBON: Are they under the plant manager? ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 2 336-6646 \\

7) 134 g 11 05 wbur 1 MR. MASON: No. They are under myself and 2 Mr.' White. That is this group right here. 3 DR. CARBON: I see it there. That is what I am 4 asking. 5 I guess I don' t really understand yet what they 6 do. 7 MR. MICHELSON: They are their ACRS. 8 MR. WARD: Sir, I guess this is all very 9 interesting, but I would like to know when you expect to get to the problems which you felt led to the closing down of 10 11 the plants and what is going to be done to fix that so they 12 can be started up again. 13 Will you get there if we give you a chance? l 14 MR. MASON: Not in the time remaining, but I will 15 try to address that. I guess I feel like the basic problem were a lot 16 l 17 of technical reasons why the plants are shut down and why t 18 ! Watts Bar has not started up. The reason for those 1 19 technical problems are lack of management attention or 20, management -- they are management in nature. That is why we 21 are concentrating on how to rebuild our management structure 22 to get the appropriate people in there to resolve the 23 technical issues and get the plants back to running so we 24 won't run into the same situation in the futura. The basic reason the plants are in the situation lf") 25 ACE FEDERAL REPORTERS, INC. 202 147 3700 Nationwide Coverage im33&M46

maggp=------- -- 135 gli 06 3Vbur 1 they are in now is management in nature. That is the basic b The organization and structure of the 2 root cause. lack of accountability. 3 management control system, There is something here that talks 4 DR. SHEWMON: about accountability, communication, performance 5 measurements, and training. 6 7 MR. MASON: Put that slide up. 8 (31ide.) These are what we think rebuilding the management 9 for so that we don't get back structure is going to provide 10 It is timely focused and i 11f in the situation we are in now. We are using project management, 12 j stresses accountability. 13 which is a new concept at TVA. gg We have, for example, a project manag'er in charge 14 l 15! of environmental qualification and support of the equipment He has access to draw any TVA organization, 16 i up there. l 17 ; whatever resources he needs. They work for him in solving He is responsible for solving that problem. 18 f that problem. He is i The same thing goes for the site director. 19 20 responsible for that site. He is The same thing goes for Mr. White. 21 22 accountable. You build that into day-to-day activities. 23 We haven't 24 Again, I say that is new to TVA. 25 really stressed that in the past. lf") ACE FEDERAL REPORTERS, INC. 8043)WA6 202-147 3700 Nationwide Covetage .;:.~ =

N ,)Al 07 136 %Vbur 1 Teamwork and communication, ccmmunication with 2 our employees and communication back and forth between the 3 various groups, the operation and the design group and the 4 modification. 5 We are going to set goals, primarily in the areas 6 of regulatory performance and the INPO performance 7 indicators. We are going to measure our performance in 8 regard to those. It is a very key part of our effort. 9 Training and retention of key managers. We are 10 doing some other things in TVA that we have been negligent 11 ' in in the past. We have got a college program for SROs, who 12 have been operators for years and years and do not have the g 13 benefit of a college education. 14 We have got 21 people right now, I believe, 15 enrolled in a degree program, takon totally off the shift. l 1 16 We have sent them to the University of Tennessee to pursue a 17 degree. We pay their tuiaion and their salaries for that 18 j time. If they maintain their SRO qualification during the j 19 Thanksgiving break and Christmas break and various holidays, 20 they do not do their retraining during those periods. 21 We have had the first five graduates of that 22 class in December. We bring them back into the plant and 23 use them in some of our key managerial positions. We feel 24 like they have got valuable experience and they have [ 25 demonstrated management capability to assume shift ACE FEDERAL REPORTERS, INC. 202 147 3700 Nationwide Coverase 800 336 6646

l 137 .,)11 08 Sybur 'l supervisor roles, and we want to take maximum advantage of 3 2 their experience. 3 Another thing we are doing in this regard that we 4 haven' t done in the past is put engineers and managers into 5 license training. TVA has not done that as a practice in i 6; the past. 7 We have got, I think, 38 people total enrolled in 8 the SRO training and licensing program for engineers and 9! managers. When they get their license, we are going to put 10 ' them on shift as assistant shift supervisors and let them 11 get some hands-on operating experience so that in the future 12 we can better develop plant managers and key managers in 13 othgr areas of our organization. 14 We are taking, for example, some design 15 engineers. To show you how we have changed, we are taking 16 de. sign engineers, construction engineers, and putting them f I 17 in that licensed plant rather than just the operations 18 l folks. 19 A couple of you are familiar with scme of the 20 past practices in that regard. We feel like we have made 21 significant improvements in our ability to go across 22 organizational lines and work together. 23 DR. MOELLER: The opportunity co enter the 24 college program is highly competitive, I presume, or is f 25 selective? ACE, FEDERAL REPORTERS, INC. M12 347 3700 Nation *Me Coserage 800 336-6666 ..,u._- .y _- m _....

118 d 11 09 2,Vbur '1 MR. MASON: The operators initially had a little l 2 apprehension about it, but the people have now graduated and 3 they have put other people in. I think almost universally 4 the operations people want to get involved in that program. 5 We can' t take everybody at once, but it is a program I am 6 dedicated to and that I am going to pursue as long as I am 7 in a position where I can see that that program is carried 8 on. 9 HR. WARD: Gentlemen, I think we are going to 10 have to cut off questions. 11 MR. REED: May I make one statement that is very 12 pertinent? 13 MR. WARD: I think not, Glenn. gg 14 Let's give Mr. Mason 10 minutes to wrap up, and 15 then we can have a couple of questions. 16 (Slide.) 17 MR. MASON: I want to update you on the status of 18 each one of the sites with regard to the technical issues. 19 I won't have time, I guess, to go into a lot of detail, but 20 the basic reason that Sequoyah shut down, that we 21 voluntarily shut it down, is because we had serious concerns 22 that our environmental qualification program for that 23 facility was not adequate. 24 This was brought out -- I don't know how we got fh 25 into that, but it was pointed out at some of our quality ACE FEDERAL REPCRTERS, INC. 202 347 37W) Na:ionwide Covetage 80433M646 I e .n- ....,-~ f ______a

139 ,11 10 assurance audits questions kept coming up that we weren't cur 1 real sure that our environmental qualification program was 2 3 adequate. SRS had some comments on it. We had some 4 In order to answer 5 violations associated with the program. those questions, we hired Westech Corporation, which is an 6 in and independently look at our 7 architect engineer, to come 8 environmental qualification progrem. As a result of their look, we felt that we were 9 in bad enough shape in environmental qualification to 10 11 justify shutting down the plant. It was a good decision. We did it. We found a 12 lot of problems associated with environmental qualification, 13 { 14l and it was not all just in paperwork. We actually had some We have had to hardware that did not meet the requirements. 15 We had to change out and reroute the cables, the conduits. 16 j change out some wiring and motor operated valves and limit 17 1 switches, junction boxes, and that sort of thing. 18, So when we get through, we feel like we are going 19 to have the best documented and the most defensible 20 industry. If not environmental qualification program in the 21 i 22 the best, it will be very near the best. We will really f But attack that problem with a great degree of attention. 23 24 we are getting close. For Sequoyah we will give you a ballpark figure. 25 ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nuionwide Coverage 800 336-6646 l

1 l ,811 11 140 SVbur- 'l If we think we can finAsh up all of our identified work 2 activities that we know about now, in late January, early 3 February. That is an optimistic schedule. It only 4 considers the items that we know for sure we have got to 5 do. There may be some additional environmental 6 qualifications, cable rerouting for example. That comes out 7 in the next two or three weeks. 8 We think after that time there will be some 9 period of time to put together a final report on the 10 activities that allows NRC to evaluate and question us on 11 what we have done. 12 The startup date. There is not a projected 13 l startup date. The startup date is sometime in the future. g 14 I don't want to put a date on it. 15 The other aspects that we have got to address at 16 Sequoyah before restart, major aspects, are the ones out of 17 l our 50.54(f) letter that we got in September, operational I 18 ' readiness plans. That is well underway. The cable tray 19 support analysis is closed out. The design control surveys 20 that was highlighted in our 50.54(f) letter. We have that 21 adequately under control, and we have got an outside 22 consultant working with us on that. 23 The employee concern program has the potential of 24 developing new work activities, but we can't predict what lf 25 might come out of the employee concern program. ACE. FEDERAL REPORTERS, INC, E)47 3700 Nationwide Coverage 800 336 6646 t

~ ,y ,a .0 11 12 141 DAVb u r * ~ i (Slide.) t 2 At Watts Bar probably the biggest unknown up 3 there and the thing that is going to take the most time is 4 the employee concerns or allegations. 5 so we have a major program of interviewing 6 people, asking for any safety concerns. 7 We have over 5000 people. We had over 4000 8 concerns. About a little less than 2000 of those concerns 9 are possibly safety related. 10 The others are related to promotions, pay, 11 veterans benefits, and that sort of thing, a little less 12 than 2000 safety-related concerns. 13 i We are investigating each and every one of them. 14 We are finding a lot of them substantiated, probably about 15 50 percent. 16 Substantiated doesn't necessarily mean that we 17l have to take corrective action. It means that there is 18 I validity to that concern. 19 One of the major concern is associated with 20 welding. 21 There's maybe 200 individual concerns related to 22 the welding program. We are looking at the welding program, 23 and the big picture is to make sure we include all the 24 concerns. 25 There has been a major effort going on in the ACE FEDERAL REPORTERS, INC, 202 347 3700 Nationwide Coscrase 80133H646 ~

10 11 13 142 DAVbur' 'l welding program in the investigation thus far. 2 We are using the contract with the Department of 3 Energy -- through them -- and EG&G Idaho and other national 4 labs participate as necessary to verify that they are 5 satisfied. 6 7 8 9 ( 10 11 12 { 13 14 15 16 17 18 19 20 21 22 23 24 25 ACE FEDERAL P.EPORTERS, INC. 202 347 3700 Nation *kie Coserage 800 336-6M6 .M k f

l l10 'iE 0'l 143 DAV/bq, ,1 Brown's Ferry has several more items than the 2 other two plantse We've got a lot more work to do at 3 Drown's Fe rry. Environmental Qualification is going to be a 4 major ef fort at Brown's Ferry. It's an old plant. We have 5 not had good design control and configuration management for 6 Brown 's Ferry. The re 's a lo t o f e f f or t in revisiting that 7 scene to get that back on track. 8 Appendix R, we still have some modifications to 9 do. This is Brown's Ferry Unit Two, which is our first 10 Brown's Ferry Unit to start up. We're not projecting a 11 startup date for Brown's Ferry, although we do hope to have 12 by the middle of February a detailed schedule of the 13 activities, integrated activities at Brown's Fe rry. 14 It will be I think at the earliest fall or 15 winter, at the earliest, when we start up Brown's Ferry 16 Two. Brown's Ferry III and Brown's Ferry I are further into 17 the future because we have committed before we start those 18 l two units up to make sure that all the post-TMI backfits are 19 installed. 20 They still have a significant amount of post-21 TMI modifications to do. 22 MR. WARD: Thank you very much, Mr. Mason. We 23 can take two questions. Short questions. Ye s. 24 MR. REED: What I think I'm hearing is that the re 25 probably is a turnabout from 1980. When I happened to be on ACE FEDERAL REPORTERS, INC. %C 347 3700 Nationwide Coserage 800 33M646

o y O ** w li10 12 02 144 DAV/bc ' I the INPO team, a turnabout from the feedstock material type ll 2 of thinking. In other words, you have a big people 3 problem. And, in 1980, it seemed to me that there was a 4 feeling that you could take any unselected warm body and 5 through your systems train this person to be anything, l 6 without any selection. 7 I think you've told me you' ro turning that 8 around. 9 HASON: I'm not going to confirm that that 10 was our is y position. ( 11 ( Lauc h te r. ) 12 MR. MASON: Rut, cet a ' nly, we ' re no t doing tha t 13 now. That's directly opposite w' . we intend to do. 14 MR. REED: I have the quotes written down. 15 I would li<e to make a comment in regard to 16 that. We've got a lot of people problems, but they' re not 17 people problems across the board, they' re managemen t type 18 problems. We ' ve got a vas t amoun'. of re sources, good people 19 at the intermediate level and the working level. 20 They need to be drawn together and function as a 21 team and I think that's the direction we're headed. And I'm 22 confident that we 'll ge t this program back on track. 23 MR. WARD: The second and last question. 24 DR. MARK: You spoke of the kind of things which { 25 you're working through at Sequoyah be fore you' re ready to ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage 800 336-66 4 l l J g

7 11011 03 145 DAV[,bG 1 start. Is the NRC staf f keeping pace with you and saying, 2 yes, that one is now qualified, and stuff? or is that only 3 to be done af ter you've finished? 4 MR. MASON: NRC staff, as a result of the 5 activities back in early December, I guess, where the senior 6 management team got real active and Mr. Thompson was 7 designated as the senior executive for TVA, we've worked 8 very well with the NRC staff. I don' t know tha t they've 9 told us on anything yet, That's okay, you can mark it of f 10 your list. 11 I don' t know if there 's daily contact but, 12 certainly, we ' re talking weekly. We've got this massive 13 effort at Watts Bar. We' re working with the NRC to identify ll . the approach we're going to use with that program. 14 15 And before we put it all on the docke t and say ' hat's it, we are getting some feedback and comments from 16 t 17 the NRC staff. Instead of going 'all the way down the road 18 and having to back up to square one. 19 MR. WARD: Thank you. 20 Mr. Thompson, ia there anything you'd like to 21 say? 22 MR. THOMPSON: I guess I'll second that point, 23 that we are trying to keep clearly abreast and integrate our 24 scheduling and our views at an early stage in tha 25 programmatic aspect as well as monitoring the impleme n ta tion {, ACE. FEDERAL REPORTERS, INC. l$2 347 3700 Nationwide Coverage 800 336-6666 i Mk..

• 4 :

10'li'04 146 DAV/bc,,,1 of those. And, secondly, the Commission has indicated, as 2 requested by TVA, an agreement to allow at least a 30-day 3 period for the new manager of Nuclear Power to come on board 4 and evaluate the issues and come back and brief the 5 Commission on some of the things you were asking about -- 6 the root causes of their previous p;oblems and why the. 7 corrective actions are addressed. 8 I think, with that, we ' re optimistic. We ' re 9 movir, forward. We think things are moving in the right 10 direc tion, and we wan t to maintain our new schedule and pace 1] with the TVA ef forts. 12 DR. KERR: Are you convinced that the TVA problem 13 is soluable in the foreseeable future? {i 14 MR. THOMPSON: We believe that the foundations 15 have been put in place, the building blocks to have that 16 solution. We don' t see any specific item right now that's 17 in su rmoun ta ble. Obviously, the specifics on the Brown's 18 Fe rry, the further away you look at a particular plant, we 19 have less information than I think TVA has, less 20 information, and we have not reviewed some of that 21 in fo rma tion. In the detail, we've looked at Sequoyah or 22 some of the others. Watts Bar. 4 23 MR. WARD: Okay. Thank you very much. Le t ' s 24 break for lunch, come back at 1:10. 4 (Whereupon, at 12:10 p.m., the mee ting recessed, 25 26 to reconvene in unrecorded session at 1:10 p.m., this same 27 day.) q y ACE-FEDERAL REPORTERS, INC. 202 4 47 3700 Nationwide Coverage 800 336-6666 A

8

• "' 4 4

8 k UNITED STATES '[ NUCLEAR REGULATORY COMMISSION @[ j + WASHINGTON, D. C. 20655 D M ~OY January 3, 1986 Docket Nos: 50-390/391 Mr. H. G. Parris ManagerofPower& Engineering (Nuclear) Tennessee Valley Authority 6N011B Missionary Ridge Place 1101 Market Street Chattanooga, Tennessee 37402-2801

Dear Mr. Parris:

During a Comissioner's recent visit to TVA facilities on December 19, 1985 TVA personnel presented the enclosed infonnation on the Employee Concern Program. The conclusion on the last page titled, "NSRS Perceptions of Watts i Bar Status," was that 10 CFR 50, Appendix B, requirements are not being met at the Watts Bar facility. It was noted during the meeting by TVA's manage-ment that this was not necessarily TVA's corporate position. In order to assist the NRC in determining whether or not TVA is in violation of the Comission's Rules and Regulations, and your Construction Pennit, you are requested to furnish under oath or affinnation. TVA's corporate position with respect to whether or not 10 CFR Part 50, Appendix B requirements are being met at the Watts Bar facility. This position should be provided in writing no later than January 9, 1986. Within 30 days. TVA shall provide infonnation on an item-by-item basis that i supports the TVA corporate position. If any corrective actions are associated with the items that information should also be provided. Sincerely. . De on, recbor Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page !i _Cl 4. l fh 0 ff A!d. //* &j _/ J f f u wwV i y-

(. = Mr. H. G. Parris Bellefonte Nuclear Plant Tennessee Valley Authority Browns Ferry Nuclear Plant Sequoyah Nuclear Plant Watts Bar Nuclear Plant j cc: Herbert S. Sanger, Jr., Esq. Mr. Charles R. Christopher General Counsel Chairman, Limestone County Comission Tennessee Valley Authority P.O. Box 188 400 West Sumit Hill Dr., E11B33 Athens, Alabama 35611 Knoxville, Tennessee 37902 Ira L. Meyers, M.D. Mr. Kermit Whitt State Health Officer Tennessee Valley Authority State Department of Public Health j 400 West Sumit Hill Dr., E3A8 State Office Building Knoxville, Tennessee 37902 Montgomery, Alabama 36130 Mr. R. A. Wallin Mr. Steven Roessler Babcock & Wilcox Company U.S. Nuclear Regulatory Comission i P.O. Box 1260 Reactor Training Center l Lynchburg, Virginia 24505 Osborne Office Center, Suite 200 Chattanooga, Tennessee 37411 Mr. Robert B. Borsum Babcock & Wilcox Company James A. Coffey Suite 220 Site Director, BFNP 7910 Woodmont Avenue Tennessee Valley Authority Bethesda, Maryland 20814 P.O. Box 2000 Decatur, Alabama 35602 Mr. Donald L. Williams, Jr. Tennessee Valley Authority Resident Inspector 400 West Sumit Hill Drive, W10B85 U.S. Nuclear Regulatory Commission y Knoxville, Tennessee 37902 Route 2, Box 311 Athens, Alabama 35611 Resident Inspector, Bellefonte NPS c/o U. S. Nuclear Regulatory Comission Robert L. Lewis, Manager, BFNP P.O. Box 477 Tennessee Valley Authority Hollywood, Alabama 35752 P.O. Box 2000 Decatur, Alabama 35602 Regional Administrator Region II U.S. Nuclear Regulatory Comission Mr. Bob Faas 101 Marietta Street, NW, Suite 2900 Westinghouse Electric Corp. Atlanta, Georgia 30323 P.O. Box 355 Pittsburgh, Pennsylvania 15230 t Mr. Ron Rogets lennessee Valley Authority Mr. Jerry Wills i 400 Chestnut Street, Tower II Tennessee Valley Authority Chattanooga, Tennessee 37401 400 Chestnut Street, Tower II Chattanooga, Tennessee 37401 O c f

t, 1 : Mr. H. G. Parris Bellefonte Nuclear Plant Tennessee Valley Authority Brovcis Ferry Nuclear Plant Sequoyah Nuclear Plant t Watts Bar Nuclear Plant cc: Resident Inspector /Sequoyah NPS Mr. Mark J. Burzynski c/o U.S. Nuclear Regulatory Comission Tennessee Valley Authority 2600 Igou Ferry Road Watts Bar NP Soddy Daisy, Tennessee 37379 P.O. Box 800 Spring City Tennessee 37381 Tennessee Department of Pablic Health ATTN: Director, Bureau of Environmental Health Services Cordell Hull Building Nashville, Tennessee 37219 Mr. Michael H. Mobley, Director Division of Radiological Health T.E.R.R.A. Building 150 9th Avenue North Nashville, Tennessee 37203 County Judge Hamilton County Courthouse Chattanooga, Tennessee 37402 Mr. L. Tomasic Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Ralph Shell Tennessee Valley Authority 400 Chestnut Street, Tower II Chattanooga, Tennessee 37401 Resident Inspector / Watts Bar NPS c/o U.S. Nuclear Regulatory Comission Rt. 2 - Box 300 Spring City. Tennessee 37381 Mr. Ken Parr Tennessee Valley Authority 400 Chestnut Street Tower II Chattanooga, Tennessee 37401 l

l EMPLOYEE CONCERN PROGRAM APPROACH STATUS OF QTC CONTRACT DESCRIPTION OF INVESTIGATION PROCESS EMPLOYEE FEEDBACK PROCESS a STATUS OF ECP AND ANY DIFFICULTIES NSRS PERCEPTION OF WATTS BAR STATUS i l p. e 5 .--.--.__m,___

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1 l 1 STATUS OF QTC CONTRACT l l 10, 1985 (ORIGINALLY d, h 3 l MILLION' DOLLARS) 0 CONTRACT AWARDED To QTC MAY l i hMI l 0 CONTRACT DUE TO EXPIRE FC.u m itr*1986 (COST AT THAT TIME WILL BE 5.6 MILLION DOLLARS) lly, f { f/f A: 0 -C^"T"'CT TO.: CAT t0:" T^ 25, isoo, AT A C0si vr 2.7 MILLION f DOI.LARS (TOTAL COST)MfL BE 8.3 MILLION DOLLARS AS ADMINISTERED BY 44[ NSRS) V A SECOND CONTRACT IS BEING FORMULATED WITH P&E (NUCLEAR)--DETAILS STILL IN DRAFT PHASE. CONTRACT WILL BE ADMINISTERED BY P&E (NUCLEAR) i FOR TRAINING OF EMPLOYEE CONCERN SITE REPRESENTATIVES l 0 l ( 1 W __,....-.....,.__._v_..,_,...,.-. -_,.,,,,___,,,,__,.......,_,c . _,..._,,_.,._ m, ..-,----...n,_-,.,,,.,y_

DESCRIPTION OF IFVESTIGATIVE PROCESS l \\ j How GROUP Ass 1GNED i l POTENTIALLY AFFECTS NUCLEAR SAFETY OF VITAL EQUIPMEN NSRS - NOT CONFIDENTIAL AFFECTS TECHNICAL SPECIFICATION REQUIREMENTS / LIMITS OR O LICENSING SUBMITTALS I&H TECHNICAL SAFETY-RELATED ASPECTS NONCOMPLIANCE TO NRC REQUIREMENTS ERI - POTENTIALLY AFFECTS NUCLEAR SAFETY WHERE ADDITIONAL INFORMATION IS NOT AVAILABLE DUE To EMPLOYEE CONFIDENTIALIT DOES NOT AFFECT NUCLEAR SAFETY BUT EMPLOYEE REQUESTS CONFIDENTIALITY I&H AND MISCONDUCT ISSUES (ASSIGNED BY OGC) ISSUES ON NSRS (ASSIGNED BY OGC) DEC - MISCONDUCT (NORMALLY ASSIGNED TO ERT) I&H (NORMALLY ASSIGNED To ERT) ALL OTHER NONSAFETY PERSONNEL, CORPORATE POLICY, GRIEVANCE OR DER REQUIREMENTS ISSUES _ ~ - - -. -.. -. - - ,,.., -, - - -,., -,... - = _, -, -. - -.,. -... -.. -. .--.,._-,-,_,..-.n

MILESTONE REVIEW COMMITTEE (MRC) TO EVALUATE / ASSESS EACH EXPRESSED POTENTIALLY NUCLEAR j MRC FUNCTION SAFETY-RELATED CONCERN IN A CURSORY MANNER WITHOUT ANY ATTEMPT BY THE MRC TO INVESTIGATE OR VALIDATE ANY OF THE CONCERNS AND To PRIORITIZE THE POTENTIAL IMPACT.'0F THE INVALIDATED EMPLOYEE CONCERN ON WATTS BAR MAJOR INITIAL STARTUP MILESTONES 1. FUEL LOADING MILESTONES 2. INITIAL CRITICALITY 3. POWER OPERATION ABOVE 5 PERCENT 4. POWER ASCENSION TESTING 5. Pl. ANT OPERATIONS AT 100 PERCENT POWER 6. OTHER PERIODIC--APPROXIMATELY EVERY 2 WEEKS MEETINGS NORMALLY 5 REPRESENTATIVES MEMBERS 0 3 FROM WATTS BAR 0 2 FROM NSRS H^ l ~.

emf 4ovre FEEtEAed 'Ptoegsg t. EMPLOYEE CONCERN DISPOSITION REPORT CONCERN NO. XX-45-013-OO1 DATE OF PREPARATION: 9-9-85 i CONCERN: 309 WELD ROD WAS USED TO WELD 316 STAINLESS PIPE AT SEQUOYAH UNIT 1. ~ INVESTIGATION PERFORNED BY: ERT FINDING (S): SOTH E308 AND E309 FILLER MATERIAL MAY BE USED FOR WELDING $16 BASE MATERIAL. WELDING WITH E309 FILLER MATERIALS IS ALLOWED PER APPLICABLE WE! D PROCEDURE SPECIFICATION / PROCEDURE / PERFORMANCE GUALIFICATION RECORD. l CORRECTIVE ACTION (S) NOME REQUIRED CLOSURE STATENENT: THE CONCERN AS STATED NAY BE TRUE, HOWEVER, USE OF E309 FILLER MATERIAL IS ACCEPTABLE AND HAS NO INPACT ON QUALITY. ERT Form G ._,__.___.____..?,,__._,,

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DIFFICULTIES WITH EMPLOYEE CONCERN PROGRAM 0 LACK OF/ SLOW LINE RESPONSE O LACK OF IMPLEMENTATION OF CORRECTIVE ACTION PROMISED BY LINE To THOSE INVE3TIGATION REPORTS THEY DID RESPOND To O LACK OF INFORMATION ON THE K-FORM O INORDINATE AMOUNT OF TIME INVOLVED IN AQUIRING FOLLOWUP INFORMATION FROM QTC O e M*

i.c NSRS PERCEPTIONS OF WATTS BAR STATUS l MAJOR ISSUES 0 AS-CONSTRUCTED WELDING PROGRAM IS INDETERMINATE D ELECTRICAL CABLE PRESENT QUALIFICATION CONDITION IS INDETERMINATE O INSTRUMENT LINE INADEQUACIES SLOPE FITTINGS BENDING INDUCED STRESSES ON CONDUIT HYDROSTATIC TESTING O CONSTRUCTION PROCESSES, IN GENERAL, ARE LOOSELY CONTROLLED 0 RECORDS ARE OF POOR QUALITY 0 LACKOFINDEPENDENCEOFQAIQCPERSONNEL(CONST) 0 0 LIST NOT IN GOOD SHAPE AND IS INCONSISTENT WITH CSSC LIST O MATERIAL TRACEABILITY VERY POOR, ESPECIALLY SEISMIC CAT 1 (PIPING, HVAC, CONDUIT, TRAYS, INSTRUMENTATION, ETC.) 0 FIELD CONFIGURATION OF CABLES, SUPPORTS HAS LOST ACCUMULATED LOADING CONTROLS ON EMBEDDED PLATES' 'O NONCONFORMANCE REPORTING DOES NOT ADDRESS CORRECTIVE ACTION ASPECTS APPROPRIATELY EDTTOM LINE D DESIGN CONTROL IS NOT INITIALLY SPECIFIED UP FRONT NOR_IS FINAL CONFIGURATION FEEDBACK GIVEN BACK TO DESIGN--MARGINS OF SAFETY ARE INDEIERMINATE D 10 CFR 50, APPENDIX B, REQUIREMENTS ARE NOT BEING MET

l"h e u ![asun q j$ UNITED STATES 6 NUCLEAR REGULATORY COMMISSION g g, t, W ASHING TON, D. C. 20555 3 y \\, / FH a G36 Docket Nos.: 50-327 and 50-328 Mr. S. A. White Manager of Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

Dear Mr. White:

Subject:

Special Inspection of January 24, 1986 on' Welding Concerns - Sequoyah Nuclear Power Plant On January 21 to 24,1986, NRC staff conducted part of a special inspection to examine Bechtel's Audit program and TVA's weld reinspection program at Sequoyah. The staff identified several concerns which were discussed with your personnel at the exit interview. This letter documents those concerns. Those concerns were as follows: 1. Because of parallel efforts in perfoming reinspections while still providing submittals to NRC, reinspections were not being performed exactly in accordance with written commitments. Inspection procedures which were being used for PT and MT were written to ASME Section XI. The January 17, 1986, submittal ?o NRC specified reinspections were to be to ANSI B31.1 and 831.7. 2. In the "Program Description" submitted to NRC dated January 17, 1986, the tems "adequate for service" and "meet all commit-ments and requirements" appear to be used interchangeably. These terms are not the same. NRC considers that the audit and reinspection program should first determine if commitments and requirements are met. The next step would be to determine "adequacy for service." 3. The person in a supervisory / coordination position over the reinspection program was the same person supervising inspection personnel during original construction. Af ter questions were raised by NRC, that person was relieved of the responsibility. By* w os n.., a n? in. O W V J ((J / Wf& l V

FEB 2 6-1986 '- 4i '.Mr. S. A. White 2-4 For the audit, Bechtel does not require double' checking of the audit activities. 5. The MT procedure being used'did not contain details for calibration. of the MT yoke. This -letter does not require a response. A fannal! inspection report will be issued in the near future. Sincerely,/ fctf B. J.jYo gblood Director PWR Pro' ct Dir torate #4 Divisio of PWR Licensing-A,~ NRR cc: See next page e n , y4,-

M r'. S. A. tihite Tennessee Valley Authority Sequoyah Nuclear Plant cc: Herbert S. Sanger, Jr., Esq. Tennessee Department of Public General Counsel Health Tennessee Valley Authority ATTN: Director, Bureau of 400 West Summit Hill Drive, E 118 33 Environmental Health Services Knoxville, Tennessee 37902 Cordell Hull Building Nashville, Tennessee 3/219 Mr. K. W. Whitt Mr. Michael H. Mobley, Director Tennessee Valley Authority Division of Radiological Health 400 West Summit Hill Drive, E3A8 T.E.R.R.A. Building Knoxville, Tennessee 37902 150 9th Avenue North Nashville, Tennessee 37203 Mr. Bob Faas Westinghouse Electric Corp. County Judge P.O. Box 355 Hamilten County Courthouse Pittsburgh, Pennsylvania 15230 Chattanooga, Tennessee 37402 Mr. Jerry Wills Tennessee Valley Authority SN 133 Lookout Place Chattanooga, Tennessee 37402-2801 Mr. Donald L. Williams, Jr. Tennessee Valley Authority 400 West Summit Hill Drive, W10885 Knoxville, Tennessee 37902 Resident Inspector /Sequoyah NPS c/o U.S. Nuclear Regulatory Comission 2600 Igou Ferry Road Soddy Daisy,. Tennessee 37379 Regional Administrator, Region II U.S. Nuclear Regulatory Comission, 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 Mr. Everett Whitaker Tennessee Valley Authority SN 1288 Lookout Place Chattanooga, Tennessee 37402-2801

A02 871002 005 i i TENNESSEE VALLEY AUTHORITY cHATTANCQQA TENNss$aa 374ot ^ 6N 38A Lookout Place October 2, 1987 Mr. James G. Keppler, Director Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East-West Highway EW 322 Bethesda, Maryland 20814

Dear Mr. Keppler:

In the Estter of ) Docket Nos. 50-327 i Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) LOW-VOLTAGE CABLE TESTING At our meeting in Knoxville on September 10, 1987, with you and your staff, the subject of testing low-voltage cable at SQN was discussed in some detail. During that meeting, certain statements were made by one of the NRC consultants that were inaccurate and misleading. The Purpose of this letter is to provide you and your staff with accurate information j and to correct the record so that any pronouncements you may make on tne i matter will not be based on f allacious coments by one of your consultants. At that meeting, your consultants stated that the high-potential testing of low-voltago cablas af ter installation was not uncomon. In response to questioning he indicated that high-potential testing of low-voltage cables was required at the nuclear plants operated by Florida Power & i Light Company (FP&L). As you may recall, I pointed out that TVA had j performed a survey of a large number of utilities with operational { nuclear plants and had found none that used high-potential testing of I installed low-voltage cables. The TVA survey had included St. Lucie of FP&L. Subsequent to the matting, I had my people check with FP&L to obtain confitsation of our previous understanding. As a result, FP&L provided a copy of their nuclear plant cable installation procedures and the procedures of their original constructor (Ebasco). I The following excecyt from the FP&L procedure applies to testing of low-voltage cable after installations cable insulation shall be teste.d as indicated below af ter the cables are pulled and before they are connected. A record shall be kept of all such tests. All 600-volt class power cables shall be tested with a 500-volt magger. The minimum acceptable insulation resistance is 25 magohms. An Equat Coportunity Employer f l" i Q (/ } '9 $ // A 1 .t lj3)2 (/ b _i 1- " W L 7 :-)

.o ' 0 October 2, 1987 Mr. James G. Keppler The FP&L procedure goes on to state the high-potential test requirement (0:' high-voltage cable as Collows: Five kV cables shall be tasted with a 2,500-volt m*gger, with 100 mogohms Each cable shall then be hi-potted by TP&L an acesptable minimum. personnel. Another TP&L procedure provides for high-potential testing of 600-volt pcwer Howevee, TP&L cables when the 500 'olt negger reading is unacceptable. advised they have never used this procedure at a nuclear installation.. This was confirmed by their central staff, plant, and construction engineers. A further check of the Ebasco installation procedure for low-voltage' cables indicates similar test requirecents with the exception that the Ebasco magger voltaga is 1,000 volts in lieu of the 500 volts specified by FP&L. tes6 Thus, TVA maintains its position that, to our knowledge, no other operating nuclear plant in the U.S. subjects its low-voltage cable to high-potential We continue to believe such testing is unnecessary tests after installation. and can only result in spucious indications. Very truly yours. TENNESSEE VALLEY AUTHORITY S*A Wh j Hanager of Nuclear Power \\ Mr. C. G. Zech, Assistant Director l ect for Inepection Programs { Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta street, NW, Suite 2900 Atlanta, Caorgia 30323 Mr. J. A. 2wolinski, AsJistant Director for Projects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East-West Highway EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Isou Ferry Road 37379 Soddy-Daisy, Tennessee

• l October 2, 1987 i

m Me. James C. Kappier DLW RTH!AW Enclosure cc (Enclosure): RIMS, HR 4M 72A-C H. L. Abercrombie. ONP. Sequoyah C. E. Ayers, LP 6N 250-C W. R. Brown ECTG, OKP, Watts Bar E. S. Christenbury, E11 B33 C-K J. P. Darling, ONP, Bellefonte S. B. Fisher, LP 3M 168D-C C. H. Fox, Jr., LP 6N 38A-C i R. L. Cridley, LP 5N 1575-C \\ ~ W. H. Hannum, BR IN ? ?B-C W. C. Kazanas, LP AN ASA-C J. A. Kirkebo. W12 A12 C-K O. C. Mason, LP 6N 38A-C G. R. Mullee, BR SS 168A-C D. R. Nichols, BR SS 100A-C R. A. Pedde, 101 PMO Bids. Watts Bae R. A. Pedde, 11-129 SB-K M. P. Pomrehn, Browns Ferry S. J. Smith, LP 6N 38A-C G. Toto, ONP, Watts Bae 1 3 4 1 1 ) t 8 e ,}}