ML20207K540
| ML20207K540 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/16/1986 |
| From: | Gass K, Knightly J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K525 | List: |
| References | |
| ECTG-NSRS-02, ECTG-NSRS-02-R01, ECTG-NSRS-2, ECTG-NSRS-2-R1, NUDOCS 8701090444 | |
| Download: ML20207K540 (46) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
ECTG-NSRS-02 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER:
1 TITLE: R9 view of Nuclear Safety Review Staff Open Items Requiring Closure or Tracking at Sequoyah REASON FOR REVISION: To incorporate TAS, SRP, and internal review comments SWEC
SUMMARY
STATEMENT: The 17 items in this report were identified by the Nuclear Safety Review Staff (NSRS) and were asssigned to the Employee Concerns Task Group (ECTG) for verification and closure. The verification activities are in progress, with present status described in this report.
PREPARATION PREPARED BY:
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- DATE APPROVED BY:
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ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) l
- SRP Secretary's signature denotes SRP concurrences are in files.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Subcategory: Sequoyah-NSRS Classical Items I
Element: Review of Nuclear Safety Review Staff Open Items l
Requiring Closure or Tracking At Sequoyah Report Number:
ECTG-NSRS-02 Evalustor:
N L<213h IL 16[N J. J. Knightly ~
l Date Reviewed By:
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Tracking at Sequoyah Nuclear PlantRoulew of Nuclear Safety Review St (SQN) ems Requiring Closure or I.
INTRODUCTION NSRS conducted reviews of activities at SQN during it were 42 open items requiring follow-up review for closurr s span of overview 86 there February 1986, NSRS conducted its final review of NSRS In early e.
and closed 38 in report R-86-01-SQN (reference 27) open items at SQN Office of Engineering (OE)a Design Quality Assurance Branch surveillanc within the had responsibility for corrective action or responseS ty to SQN where OE items must be resolved before restart.
, to determine which (reference 28) identified the five items which were required to beSurveillance resolved before startup and these were transmitted to the P Manager, SQN Engineering Project on February 14 roject
, 1986.
A subsequent memorandum dated May 1, 1986 (referenc Nuclear Licensing identified eight open items affDirector o e 29), from the to the Manager of The eight included the five items identified by LEecting SQN restart.
identified in NSRS report R-86-01-SQN.
and additional items was reviewed in report ECTG-NSRS-01.
The status of these eight items report a review of all NSRS open items was undertaken by SQFollowing p In addition to the 8 items in report ECTG-NSRS 01 N and ECTG.
were identified as requiring closure verification by ECT, 17 additional items startup.
but did not appear to require closure before startAn additional G before cable to SQN up.
The 17 items are as follows:
R-80-05-SQN-10 Adequacy of Containment to Withstand Tornado Damage R-82-07-WBN-06 Visual Inspection of Welds Through Primer (Reopened by NRC)
R-82-08-NPS-10C Issuing of Directives Contrary to TVA Commitments R-84-07-WBN-1 Pipe Support Calculations Destroyed R-84-17-NPS-10 Commercial Grade Items With QA Level I l
and II Designations l
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R-84-17-NPS-ll Quality Verification for Commercial I
Grade Items
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R-84-17-NPS-12 j
Receipt Inspection of QA Level I and II Items by Field Quality Engineers i
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Page 1 of 44
r Rsview of Nuclear Safety Review Staff (NSRS) Opsn Items Rsquiring Closure or Tracking at Sequoyah Nuclear Plant (SQN)
I.
INTRODUCTION NSRS conducted reviews of activities at.SQN during its span of overview responsibility from 1979 to 1986, and at the commencement of 1986 there were 42 open items requiring follow-up review for closure.
In early February 1986, NSRS conducted its final review of NSRS open items at SQN and closed 38 in report R-86-01-SQN (reference 27).
At this same time, a Design Quality Assurance Branch surveillance was conducted within the Office of Engineering (OE) to review all NSRS open items applicable to SQN, and for those items which had generic applicability to SQN where OE had responsibility for corrective action or response, to determine which items must be resolved before restart. Surveillance Report S86-10 (reference 28) identified the five items which were required to be resolved before startup and these were transmitted to the Project Manager, SQN Engineering Project on February 14, 1986.
A subsequent memorandum dated May 1, 1986 (reference 29), from the Director of the Nuclear Managers Review Group (NMRG) to the Manager of Nuclear Licensing identified eight open items affecting SQN restart.
The eight included the five items identified by OE and additional items identified in NSRS report R-86-01-SQN.
The status of these eight items was reviewed in report ECTG-NSRS-01. Following preparation of that report a review of all NSRS open items was undertaken by SQN and ECTG.
In addition to the 8 items in report ECTG-NSRS-01, 17 additional items were identified as requiring closure verification by ECTG before startup. An additional 69 items were considered to be applicable to SQN but did not appear to require closure before startup.
The 17 items are as follows:
R-80-05-SQN-10 Adequacy of Containment to Withstand Tornado Damage R-82-07-WBN-06 Visual Inspection of Welds Through Primer (Reopened by NRC)
R-82-08-NPS-10C Issuing of Directives Contrary to TVA Commitments R-84-07-WBN-1 Pipe Support Calculations Destroyed R-84-17-NPS-10 Commercial Grade Items With QA Level I and II Designations R-84-17-NPS-11 Quality Verification for Commercial Grade Items R-84-17-NPS-12 Receipt Inspection of QA Level I and II Items by Field Quality Engineers i
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Page 1 of 44
L R-84-19-WBN-6 Instantsnsous Trip Sattings cf the Breakers for Motor-Operated Valves I-84-34-SQN-3 Availability of the Material Certification and Requirements for Heat Number Sort Printout Entries I-85-06-WBN-3 Voltage Drop and Short Circuit Current Determination and Verification I-86-101-SQN Wire Bend Radius in Installations Using Conax Connectors R-85-08-0E/NUC PR-1 Inadequate OE Environmental Qualification Procedure for Equipment Qualification by Similarity R-85-08-0E/NUC PR-2 Inadequate OE and NUC PR Procedures for Initiating and Processing NCR-FE/ERs R-85-08-0E/NUC PR-3 Lack of Priority on SQN NCR Initiation R-85-08-0E/NUC PR-4 Lack of Engineer Awareness of NCR-FE/ER R-85-08-0E/NUC PR-5 Lack of Timeliness in Initiating and Processing NCR-FE/ERs
'R-85-08-0E/NUC PR-6 Failure of Management to Correct Problems with Timeliness and Responsiveness Involving the NCR-FE/ER Process The review detailed in this report examined all 17 items. The status of l
the additional 69 items was not determined in this review. The j
identification of these items and the issues raised by them are listed in Appendix A.
l In June 1986, the Watts Bar Nuclear Plant's (WBN) special Employee l
Concerns Task Group (ECTG) assumed responsibility for tracking and verification of corrective action on all NSRS classical report open Ig/
items. This was in addition to the open items resulting from the NSRS/ Quality Technology Company Employee Concern Program._ No Corrective I
Action Tracking Documents (CATD's) will be issued for the classical open l
items. Several ECTG reports include classical report details. CATDs
(
have been written, or are in the process of being written, for many areas sin 11er to those identified in the classical reports. Also, SQN I
has plans in place for resolution of most of these items. ECTG plans to l
work with SQN to resolve these items. Since the classical open items L
are restart issues, this report will be revised periodically before l
restart to show the status of each item.
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Page 2 of 44
5 II. ' VERIFICATION OF NSRS OPEN ITEMS A.
(0 pen) R-80-05-SQN-10, Adequacy of Containment to Withstand Tornado Damage
===1.
Background===
i The NSRS report recommended that the design of the SQN containment be reviewed to determine if it is adequate to withstand the effect of depressurization and missiles caused by 4
tornados.
Specific problem areas identified by the NSRS which appeared to lack adequate tornado depressurization and missile protection were the diesel generator exhaust stacks, and penetrations through the roof, Diesel Generator Building, refueling water storage tank, primary water storage tank, condensate storage tanks, and the 480-volt shutdown transformer j
rooms on elevation 749 of the auxiliary building.
2.
Corrective Action Taken I
TVAs Office of Engineering Design performed additional analysis j
to document the adequacy of containment to withstand tornado damage. The initial study report was transmitted May 13, 1980, l
(reference 22), supplemented August 8, 1980, (reference 23), and finalized Decemoer 22, 1981, (reference 24). The NSRS August, 1981 review of the report stated (reference 25):
1 The NSRS has reviewed the subject report concerning tornado protection criteria for SQN. With one exception, we find
]
the report acceptable and the resolutions of the concerns j
within the report acceptable.
In order to ensure a thoroughly documented study, the NSRS believes section 3.1.3.g should include information on the jl temperature monitoring system which was to be installed in j
the 480-Y shutdown transformer rooms. We request that you i
send us the revised report incorporating this change.
)
The requested information on the temperature monitoring system was included in the finalized SQN report (reference 24).
i 3.
Specific Verification Methodology
[
l NSRS Report Number R-80-05-SQN "Sequoyah Nuclear Plant -
I l
unit 1 - Routine Review" dated June 26, 1980, was reviewed, as
{ fI were the response memoranda and evaluations from Office of g
Engineering (reference 22, 23, 24, 26). Additionally, ECTG l
discussed the adequacy of tornado protection with DNE and site I
engineering personnel cognizant in this subject area.
I i
Page 3 of 44 l
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4.
Verification Analysis DNE's consultant on tornado misslie protection reviewed for ECTG !
the development of Engineering's report, "Sequoyah Nuclear l
Plant - Assessment of the Tornado Protection Criteria (reference 23)."
The report's focus was on airborne missiles I
and reviewed possible direct and indirect effects on j
safety-related equipment or systems which might. result from such I
missile damage. The report was revised several times based on Office of Engineering's discussions with the NSRS staff at that l
time (1980-1981). He expressed the view that the report was complete, and that each NSRS issue was addressed. ECTG verified that NSRS documented their acceptance of the assessment, with l
/TI the one exception concerning temperature monitoring equipment information, and that this information was subsequently provided l (reference 24).
5.
Completion Status The documentation review and-initial interviews concerning this l
issue indicate that TVA has adequately addressed tornado l RJ protection at SQN. However, pending completion of additional g
verification interviews, this item remains open.
B.
(Open) R-82-07-WBN-06, Visual Inspection of Welds Through Primer
===1.
Background===
j u
The NSRS report stated that insufficient documentation existed to substantiate the weld sampling program conducted to verify that visual weld _ inspections could be made through Carbo zine primer. The NSRS recommended that TVA prepare a report describing the weld sampling program and providing the technical justification for inspection through primer. This item was closed February 3, 1984 (references 30 and 31). The TVA general manager received a letter from a former NSRS member dated November 7, 1985, which questioned the validity of closing the item. SQN has identified this item for further review. The questions raised in the November 7 letter and the technical issues are to be addressed.
2.
Corrective Action Taken i
i l 8/
In 1982 NSRS report R-82-07-WBN " Inspection Practices of Structural Steel Welds-Special Report" stated that visual inspection of welds had been performed after being painted with Carbo Zine Primer. This report was subsequently closed by NSRS February 3, 1984 (reference 31).
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Quality Tschnology Corpany (QTC) in 1985 raidsntified ths j
prcblem of visual inspection of welds after being painted with primer.
NSRS in September 1985 stated that their response (reference 41) to the QTC report would answer concerns of l
premature closure of the issue. This NSRS September 1985 g
response resulted in a letter to the TVA General Manager from a y
former NSRS member (reference 40) stating that the 1985 NSRS response had attempted to discredit the original 1982 report.
1 I
Although the original NSRS review was conducted at WBN, it was potentially applicable to SQN. This issue has been identified l
by SQN as an area to be resolved before restart.
3.
Specific Verification Methodology I
I The corrective action undertaken by TVA was examined, which I
included the numerous investigation reports, responses, reports I
of analysis, employee concern reports, safety evaluation by the t
Office of Nuclear Reactor Regulation related to assessment of I
TVAs welding program SQN units 1 and 2, and the national laboratory technical evaluation report related to the welding I
concern program at TVA's SQN units 1 and 2 (references 35-45).
1 4.
Verification Analysis j
RCTG welding project evaluation report number WP-02-SQN-R2 l NI (reference 36) stated:
l Review of the OC procedures used at SQN during construction I
specifically prohibited the practice of inspection of Welds l
l alter painting.
(See section 4.C to SNP Inspection l
l Instruction Number II-75, " Visual Raamination of Weld Joints.")
l l
The Process Specification which allows this practice was initiated in 1982, one year after construction was completed. This specification was not applicable nor was it l
implomented at SQN.
g I
The conclusion drawn by WP-02-SQN is that no initial acceptance inspections were performed on coated welds at SQN.
I 5.
Completion Status i
The results of this analysis indicate that the correct program elements for the control of this issue were addressed and l
implemented at SQN by.both OC and NUC PR.
Pending further confirmation by personal interviews, this NSRS item will remain open.
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C.
(0 pin) R-82-08-NPS-10C Issuing of Directivas Centrery to TVA Commitments
===1.
Background===
The Nuclear Quality Assurance Manual (NQAM), part III, Tiection 1.1, paragraph 4.0, describes the ONP Quality Assurance Program to implement the power QA program. This paragraph requires that activities which affect nuclear safety shall be prescribed in i
documented procedures and instructions. The requirements of such procedures and instructions are mandatory and shall be k
compiled with by responsible organizations and individuals.
In order to ensure as much uniformity in the control of nuclear i
plant water quality as practical, the central office prescribed j
in the Divisional Program Manual (DPM) N79E2, section II, analytical procedures to be used to satisfy licensing, i
regulatory, code, and TVA requirements. The procedures were i
developed from industry standards, e.g., ASTM or Standard Method i
Procedures.
I Nuclear Steam Supply System (NSSS) vendor or chemical vendor procedures were referenced only when no industry standard procedures were available. The procedures were intended to be explicit enough that they could be used as written, or the plant may incorporate the procedures into any site instructions necessary to implement use at the plant provided the technical content was not altered.
During the 1982 review, NSRS concluded (reference 16) that:
There were no procedural controls established for the central office preparations, qualification, and issuance of analytical procedures.
No documented qualification of analytical procedures was found before issuance from Nuclear Central Office (NCO) for plant use. ANSI N18.7-1976, paragraph 5.2.15 requires those organizations which are receiving documents for implementation or change to have access to pertinent background information upon which to base its approval and to have an adequate understanding of requirements and intent of the original document.
NSRS review of the section II of DPN N79E2 analytical procedures found inconsistencies existed between what was denoted in NSSS vendor and ASTM procedures, including simple stoichiometry.
These inconsistencies involved missing critical variable maintenance precautions, technically incorrect chemical equation balsucing, and inadequate analysis technique. No formal record documents had been prepared to establish the fact that the l
procedures had been tested and qualified before their issuance I
for implementation. Had this been accomplished, the i
inaccuracies could have been prevented.
Page 6 of 44
2.
Corrective Action Taken I
In a phone conversation December 10, 1986 with Mr. J. L. Bates at SQN, Mr. Bates stated to ECTG that he was hired from the Institute of Nuclear Power Operations (INPO) to come to TVA and I
r set up a chemistry program for the nuclear plants. Mr. Bates stated that the corporate (central) office does not have a chemistry program at this time. The sites are responsible for l
the chemistry. The central office will come in and review the sites only when asked by the site, and then only advise.
Mr.
Bates is at SQN working on an interim program for startup with a representative from each site who will return to their i
respective site and implement the new program.
In response to an INPO inspection (reference 46) TVA stated:
TVA is developing a new system of Office of Nuclear Power I
(ONP) policies, directives, standards, procedures, and Instructions to govern its nuclear activities, including I
chemistry activities at its nuclear plants. The l
establishment of this proc c re system ensures ONP centralized control, technical uniformity, and continuity for I
the manner in which all corporate and site departments j
interface. The ONP policies, directives, and standards are upper-tier documents which establish ONP management positions jb and interface responsibilities, authorities, and uniform methods for implementing requirements. The lower-tier l
procedures and instructions will represent a detailed extension of the upper-tier documents by delineating the l
responsibilities, authorities, requirements and actions to be l
accomplished in the area of chemistry at the user level.
The ONP headquarters organizations will have personnel with l
expertise in chemistry. These personnel will assist management with the development of TVA policy, goals, and l
objectives for chemistry activities. They will also monitor g
implementation of policy beginning in Ipril 1987 through onsite assessments of plant programs and observation of work l
activities, and assessing site performance through review of performance data. Underlying causes of problems identified I
i during site assessments will be identified and necessary l
I corrective acticn will be implemented.
l An expanded corporate nuclear performance reporting system is j
being developed. This system will provide for the collection l
l of key performance indicators for trending and analysis by the appropriate nuclear herdquarters technical staff. This I
i reporting system will be fully implemented by February 1987.
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Page 7 of 44 k
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l 3.
Spreific Varification Msthodology g
A discussion was held with a former NSRS investigator of this l
issue and phone conversations with a former Central Chemical Engineering Section engineer and with J. L. Bates as stated above. Pertinent documents were reviewed for this issue, t
4.
Verification Analysis I
The new manager for the nuclear power chemistry program stated l g; to ECTG that an interim program, including necessary policies j
and procedures, will be in place before the startup of SQN.
I 5.
Completion Status y
ECTG will review the interim program as it is put in place.
I This includes organizational controls and implementation of I
directives. Pending the development of the program and its l
review, this item remains open.
l D.
(Open) R-84-07-WBN-1, Pipe Sup' port Calculations Destroyed
- 1. - Background This April 6, 1984 NSRS special review of NCR WBN SWP 8303 concerned missing pipe support calculations at Watts Bar Nuclear Plant. NSRS stated that safety-related pipe support calculations performed by Energy Data Systems (EDS) Nuclear.
Incorporated had been destroyed and that no quality records existed to documsnt the adequacy of the pipo supports. NSRS i
recommended that the calculations be recreated and maintained as TVA quality records. The records status of calculations for T.DS-designed suppc+ts at SQN needed to be determined, 1
7.
Corrective Action laten The initial corrective action response (reference 4) stated that documentary evidence of the quality of the calculations was available as follows:
Verification that the information contained on the pipe l
support drawings conforms to that specified by the design computations is provided by the initialing of the drawing originals by the checker. The design calculations were available to the checker, and his initials are verification that the member sizes and support configurations are those as specified in the design calculations.
In March 1985, following subsequent meetings with NSRS and Nuclear Regulatory Commission (NRC) representatives, the Managar of Engineering stated (reference 5) that-TVA had committed to develop calculations before the first refueling outage of unit 1 for all the EDS designed supports in which the calculations were destroyed.
Page 8 of 44
3.
Sptcific V*rifiention Mathedelegr NSRS report R-84-07-WBN, " Watts Bar Nuclear Plant - units l
1 and 2 - Special Review of NCR WBN SWP 8303 Related to Missing Pipe Support Calculations," dated April 5, 1984 was reviewed, as I
were the corrective action responses (references 4 and 5).
The l
Sequoyah Civil Discipline calculation policy (reference 33) and action plan (reference 34) were reviewed, and discussions were l
conducted with DNE and SQN site personnel responsible for implementation of the plan, j
4.
Verification Analysis l
The categories and listings of required calculations and the schedules for their identification and revision or regeneration l
are identifiel in the Sequoyah Civil Discipline Calculation l
Action Plan (reference 34). The civil discipline pipe support calculations such as those performed by EDS, are included in I
the plan. Engineers responsible for implementation of the ikl calculation action plan stated to ECTG that they visited the EDS l
offices (now called IMPEL corporation offices) in Atlanta g
October 4, 1986. Using the SQN plant systems listings, an extensive sampling of the EDS pipe support calculations identified 100 percent of either (1) original calculations, or j
(2) structural verification calculations. Additionally, it was confirmed that an EDS index to all calculations was in place to I
aid in retrieval. It was stated to ECTG that the EDS l
calculations for SQN appear to be fully identifiable and l
retrievable. A DNE memorandum attesting to this is in preparatiot.
l S.
ConDietion Status The p G verification activities indicated that this NSRS issue I
for SQN can be closed soon based on the availability of the EDS calculations for SQN. The issue remains open for now pending I
documentation by DNE of the calculations' availability.
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E.
(Open) R-84-17-NPS-10, Commercial Grade Items With OA Levels I And II Designations
===1.
Background===
The NRC regulations and TVA procedures recognize that basic i
components can have varying degrees of quality placed upon their i
importance to safety. The Nuclear Quality Assurance Manual (NQAM) establishes four QA levels (levels I, II, III and IV) to j
which items or services for CSSC may be assigned. The guidelines in assigning levels are identical to those listed in ANSI N45.2-1971. TVA has equated the following terms:
(1) Basic Component.
- (2)* Critical Systems, Structures and Components (CSSC).
Page 9 of 44
(3) Structurss, Systems cnd Componsnts Irportant To Safety.
(4) Safety-Related Structures. Systems and Components.
NSRS R-84-17-NPS-10 (reference 12) stated:
If TVA procured a commercial grade item for use as a basic component, it must either assure quality during the manufacturing or through receipt inspection, testing, or other means.
For a true commercial grade item that is purchased off the shelf by part number with no documented quality, the only avenue available to TVA to assure quality is through receipt inspection and testing.
TVA was found to have purchased commercial grade items from vendors lacking a QA program and to have assigned the equipment a quality rating.
In order for TVA to assign a quality rating, the equipment should have been upgraded through testing or receipt inspection, but this was not always done. These items may then have been used in a safety-related function. TVA should ensure that all equipment rated as QA level I or II has been either purchased from a vendor with appropriate QA program or upgraded by TVA through receipt inspection or testing.
2.
Corrective Action Taken The Office of Nuclear Power (ONP) response to NSRS (reference 13) stated:
A telecon between C. R. McWharter and R. D. Smith on June 27, 1985, revealed an NSRS misunderstanding concerning DNP's plans for the procurement of commercial grade basic components. Only commercial grade basic components would be procured as QA level II under the revised system of QA levels. Appendix F. " Determination of Basic Component Status, Commercial Grade, and 10 CFR 21 Applicability," was issued on August 16, 1985.
ONP stated that the implementation of these actions would adequately resolve the NSRS concerns.
I l
The Second Quarterly Status Update to NSRS report R-84-17-NPS 1
I (reference 14) stated:
I The revision to the Nuclear Quality Assurance Manual (NQAN),
I part III, section 2.1 redefining the QA level designation
[(I system to be issued by December 31, 1985, will resolve this
- /
recommendation.
I 3.
Specific Verification Nothodology i
l The NSRS files and the TVA employee concerns report pertinent to l
j this issue were reviewed. Discussions were held with the
.i procurement CgG head. The NQAM was reviewed.
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Page 10 of 44 i
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4.
Veri'fication Analysis The current NQAM (dated June 20, 1986) part III, section 2,1, j
4.3.2.4, " Assignment of QA Levels, does define the QA level designation system.
I 5.
Completion Status l
l The latest update for this issue was found in the fourth update to NSRS report R-84-17-NPS which (reference 15) stated that a i
- Araft corporate level procedure detailing program requirements U
for a " dedication" program was to be issued for review and I
comments on July 25, 1986. The procedure was to be issued upon l
disposition of received comments with a target date of October 15, 1986. The corporate level procedure had not been j
lasued as of December 12, 1986.
I Pending implementation verification of revised plant procedures reflecting NQAM requirements, this issue R-84-17-NPS-10 remains open.
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L F.
(Open) R-84-17-NPS-11, Quality Verification for Commercial Crade Items
===1.
Background===
In the original review (reference 12), NSRS concluded that the use of commercial grade items as basic components placed solely upon TVA the responsibility for assuring that the item would function as intended under all conditions. The QA program within TVA was not capable of providing that assurance because it did not include a receipt inspection program which included testing of the item or comparable mechanisms such as an audit of the vendor's QA program for commercial grade items.
NSRS reconssended that ONP should establish a receipt inspection program which included testing (or comparable mechanisms such as audit of vendor's QA program, verification of certification of conformance, etc.) for replacement commercial grade items that would be dedicated as basic components or parts. This would provide documented assurance that the iteins would function as intended - including accident conditions.
2.
Corrective Action Taken ONPs response January 6, 1986, was given in the second quarterly status update to NSRS report R-84-17-NPS (reference 14):
The resolution of the issue of " dedication" of commercial grade items for basic component use was being actively pursued by TVA and the rest of the nuclear utility industry.
The issue was complex and not easily resolved. Power and Engineering (P & E) (Nuclear) personnel attended an industry seminar dealing with this problem and were in contact with other utilities who are striving for resolution.
By March 1, 1986 ONP expected to have a proposed solution for management review.
Page 11 of 44 L
t Tha. latest updata for this issus was found in (roferance 15) fourth update to NSRS report R-84-17-NPS which states:
A draft corporate level procedure detailing program requirements for a " dedication" program was to be issued for review and comments on July 25, 1986. The procedure was to be issued upon disposition of received conunents with a target date of October 15, 1986.
I 3.
Specific Verification Methodology 1
The NQAM proce'ure was reviewed. Discussions were held with the d
TVA Employee Concerns Special Program (procurement) Supervisor I
and staff regarding this issue. A phone conversation was l
conducted with a central office NQA supervisor regarding the I
status of the corporate level procedure detailing program l
requirements for the" dedication" program.
I-4.
Verification Analysis 1
ECTG reviewed NSRS files and the TVA Employee Concerns Report pertinent to this issue. Phone conversation with the central I
office NQA staff revealed that a corporate level procedure detailing program requirements for a " dedication" program was
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issued in draft form. The procedure will be issued upon disposition of received cossments.
I DNE will provide a detailed implementing procedure for the above g
mentioned program procedure (reference 52).
I The current NQAM, part III,'section 2.1 is dated June 20, 1986.
l Revision 0, part III, section 2.1, paragraph 4.3.2.5,
" Assignment of QA Levels," does define the QA level designation I
system.
g S.
Completion Status l
l The corporate level procedure had not been issued as of December 12, 1986. Pending this being issued and implementation I
verification of corrective action this item will remain open.
l G.
(Open) R-84-17-NPS-12, Receipt Inspection of OA Levels I and II Items by Field Quality Engineers (FOE)
===1.
Background===
From the NSRS review of procurement practices an'd procedures for operating nuclear power plants (reference 12) NSRS concluded the following:
Considering the changes recommended by NSRS in this report with regard to the procurement of QA levels I and II. material and commercial grade items to be dedicated as basic-components, the division of receipt inspections between Field Quality Engineering (FQE) and Power Stores, in effect during this review, would be inadequate.
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Page 12 of 44 e
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NSRS reccnunsndsd that all itsms procured as QA Level I and II and conumercial grade items to be dedicated as basic components should be receipt inspected by Field Quality Engineers or others qualified to ANSI N45.2.6.
t 2.
Corrective Action Taken i
I l
ONP's response January 6, 1986, to the conclusion by NSRS
[
(reference 14) was:
A revision to the NQAN, part III, section 2.2 to be issued shortly, would require that all basic components, including l
those procured as conumercial grade, be receipt inspected by certified QC inspectors. This would resolve this recommendation, t
3.
Specific Verification Nothodology i
l The NSRS files and the TVA Employee Concerns reports pertinent to this issue were reviewe'd. Discussions were held with I
4 procurement personnel of the material control category l
[
evaluation group staff with regards to this issue. The current i
i g
revision of the NQAM was reviewed.
g
{
i
\\
i 4.
Verification Analysis i
l RI The NQAN, part III, section 2.2 is dated June 20, 1986, revision O.
Part III, section 2.2, 5.2.4 does require item I
inspection and explains how the receipt inspection is to be i
l performed.
l 5.
Completion Status I
i Pending implementation verification of revised plant procedures I
reflecting NQAM requirements, this item will remain open.
l 4
i H.
(Open) R-84-19-WBN-6, Instantaneous Trio Settings Of The Breakers For Motor-Operated Valves 1.
Bactrground The NSRS report stated that the instantaneous trip settings of j
the breakers for motor-operated valves were' set too high at WBN. If the breakers are set too high, the circuit that the breaker is protecting may be damaged. SQN needed to ensure that the instantaneous teip settings at SQN were in agreement with I
the National Electrical Code (NEC) as required by TVA design standard E.9.2.1 or other appropriate standard.
i In 1984, the NSRS performed a review and analysis of the results t
of the Black and Yeatch (B&V) Independent Design Review of the WBN unit 1 Auxiliary Feedwater (AFW) System and the TVA 4
activities in response to the B&V findings. The NSRS review covered the B&V initial and supplemental reports, the activities of the TVA program team and the cognizant line organizations, l
the activities of the TVA management policy consalttee, and the activities of the task force of the policy connaittee.
Page 13 of 44 L-
~
From this review and analysis of the rssults of the B&V review (reference 19), one of the NSRS recommendations was:
{
The instantaneous trip breakers should be verified to be set in agreement with the intent of the NEC. The documentation for the design as well as for the testing and operations of equipment should. reflect the proper values. The program should be implemented TVA wide.
I Memorandum (reference 20) and NSRS routine review report R-84-26-WBN (reference 18) provide the NSRS evaluation of Power's response to the NSRS recommendations resulting from the B&V review as follows:
Concern: Fifty-nine breakers were in noncompilance with the intent of the NEC, with no documented justification; and a i
nonmandatory design guide now superceded the previous mandatory design standard.
Response: DNE agreed that the planned corrective action for l
the 59 breakers had not been implemented.
2.
Corrective Actions Taken l
l The Employee Concerns Special Program (ECSP) issued a report on g
this issue (reference 47) dated November 26, 1986. The g
discussion section of this report states:
g At SQN, nonadjustable time limit (thermal magnetic) circuit l
breakers were used in the combination starter, differing from Watts Bar. Thermal magnetic circuit breakers are factory-set l
and cannot be adjusted in the field. In its evaluation for l
Sequoyah, the TVA Task Force for Review of Black and Veatch Findings determined that tho' concern does not apply to l
Sequoyah because the circuit breakers do not use adjustable l
instantaneous trips. However, for this report the concern is 1 gj considered to cover a potential generic problem: the proper 1
selection and application of molded case circuit breakers for short circuit protection in 480-volt combination motor l
starters. This evaluation addresses the issue that selection l
of trip ratings for a large number of thermal magnetic l
I circuit breakers may have been inappropriate... Whether or not calculations formed part of the selection process is not I
j clear.
In any case, documentation of the original selection l
cannot be found and TVA is preparing new calculations to verify the existing trio ratings. Although the new I
l calculations have not been completed, initial assessment by l
TVA predicts that only a small number of trip ratings will be found unsatisfactory. Circuit breakers with unsatisfactory I
trip ratings will be replaced before restart of SQN. Until l
final calculations are completed and can be evaluated, the magnitude of the problem remains undetermined.
l i
i t
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Page 14 of 44
I 3.
Sp2cific Verification Methodology l
Discussions were held with DNE at Watts Bar. TVA Employee g
Concerns Special Program, Sequoyah Element Report numbers 237.1 (B) and 237.2 (B) were reviewed.
I l
4.
Verification Ana'ysis I
Completion of the calculations, clarification of the design-l g/
criteria, and replacement of the circuit breakers found to be deficient (if any) should clear this item.
l 1
5.
Completion Status l
TVA is preparing new calculations to verify the existing trip l
ratings. Circuit breakers with trip ratings found to be unacceptable will be replaced prior to SQN restart. Pending this and further review this item will remain open.
l I.
(Open) I-84-34-SQN-03, Availability Of The Material Certification And Requirements For Heat Number Sort Printout Entries
===1.
Background===
This March 15, 1985, NSRS report stated that there appeared to be inconsistencies in the compilation of required material certification and some ambiguity in the program established to control it.
Specifically, NSRS could not conclude with certainty that the SQN Heat Number Sort Printout included only material with acceptable certification. NSRS recommended that a history of the Heat Number Sort be reconstructed to establish the program's purposes, controls, designed functions, actual functions, and data quality.
2.
Corrective Action Taken The Office of Construction responded (reference 6) with the information requested by NSRS. The response stated:
The Heat Number Sort Program (HMSP) was developed to provide a quick reference for document reviewers to verify heat numbers recorded on QA inspection records. For example, before weld data sheets were filed in the records storage vault a record reviewer would verify by way of HNSP that the material used was appropriate.
If a record was received bearing a number which was not in the HNSP the record was rejected and researched.
There were no formal management controls placed on the HNSP.
A SQN Heat Number User's Guide was published and used for providing basic instructions on how to enter data into the
- program, t
Page 15 of 44
OC mtnagamsnt is confidsnt that the information in the program was/is sufficiently accurate to statistically support a reasonable assurance that the plant was constructed in
)
accordance with applicable codes and standards.
F It must be remembered that the SQN QA program grew and l
matured with the 10 CFR 50 QA program.
It is understood and accepted that the SQN QA program would not meet today's standards but it did meet the standards of the time.
i NSRS did not find the response satisfactory (reference 7), and requested any SQN procedures which may have controlled or referenced the HNSP.
SQN responded (reference 8) that a review of SQN's QA program had not identified any procedures referring to or controlling the HNSP.
SQN provided a HNSP Ptagram Users Guide as the only historical document referencing the HNSP.
SQN also stated that the users guide and the HNSP are not, and never were a part of the site quality program.
3.
Specific Verification Methodology l
l NSRS Report I-85-34-SQN, "SQN - Employee Concern Regarding Alleged Violation of QA Procedures at SQN," dated March 15, 1985 l
l was reviewed, as were corrective action response memoranda l
1
-(references 6, 8).
The ECTG Report NC-40703, "Naterial Control, 3
Procedural Control Heat Code," dated September 26, 1986 was l
4 reviewed along with corrective action recommendations j
(40703-SQN-01) and the SQN Engineering Project response j
(reference 32) to these recommendations. In addition.
}
discussions were conducted with personnel cognizant of the l
}
pertinent material traceability issues.
1 1
4.
Verification Analysis SQN Engineering Project personnel stated (reference 32) that a l
?
Heat Code Traceability Task Group (HCTTG) had been formed to I
l research, evaluate, and resolve the material traceability issues l [/
of CATD Number 40703-SQN-01. Several actions were proposed j
including review of commitments, verification that written programs reflected conusitments, assemblage of quality-indicating documentation, review of documentation and issuance of a finL1 l
j adequacy report.
4 ECTG Naterial Control personnel have been meeting periodically with the cognizant codes, SQN, and ONP personnel concerning the j
,HCTTG activities to establish suitability for service of the
{
material used at SQN.
ECTG personnel stated that all parties l
l are in agreement that the material control documentation on hand i
is not fully adequate, and that additional I
demonstration / documentation of suitability for service will have l
to be accomplished.
Certain differences, including lack of agreement concerning the applicable code of record during SQN l-construction, still need to be worked out prior to ECTG l
acceptance of SQN's corrective action plan (CAP).
ECTG material control personnel stated that the NSRS concern will be fully I
addressed in the. accepted CAP, and that SQN will demonstrate I
that any material used is, in fact, suitable for service.
l 4
Page 16 of 44 I -
5.
Comp 1stion Status I
This NSRS item remains open pending ECTG acceptance of the I
corrective action plan for ECTG Material Control CATD 40703-SQN-01.
Following acceptance of that plan, which is i jji to address the NSRS concern, this NSRS concern will be closed with tracking of corrective action to continue under ECTG CATD 40703-SQN-01.
l J.
(0 pen) I-85-06-WBN-3, Voltage Drop and Short Circuit Current Determination
===1.
Background===
The description of deficiency as stated in SCR WBN EEB 8571 was stated es:
The Watts Bar Nuclear Plant (WBN) INPO review and TVA's Office of Quality Assurance audit identified specific electrical design calculations that had not been evaluated and documented. Because of these findings / deviations, problem identification reports (PIRs) WBN EEB 8527 and WBN EEB 8528 were initiated to correct the problems. In pursuing the corrective actions to resolve the PIRs, it was discovered that other calculations were missing. Significant condition report (SCR) was written to address the fact that for WBN, TVA had failed to' identify the minimum set of electrical calculations (calculations on safety-related systems required to shut down the plant), to revise existing calculations to incorporate subsequent design changes, and had issued design documents and drawings without preparing or before completing supporting calculations. These calculations are necessary to ensure the technical adequacy and compliance with the plant design basis. Affected systems include:
auxiliary and control power distribution, communications, instrument and control, lighting, raceway, switchyard and transformers.
This condition resulted primarily from inadequately defined requirements to document supporting design calculations and studies. Those calculations that were formalized were not updated to support document and drawing revisions.
In NSRS report number I-85-06-WBN-3, the NSRS recommended that OE should perform short circuit and voltage drop calculations for the Level 3 power circuits to ensure the adequacy of the size of the installed cable to perform its intended functions.
NSRS stated that this rocommandation was applicable to SQN and was identified by SCR number SQN EEb 8527.
Page 17 of 44
l 1
2.
Corrective Action Taken Corrective action for the deficiency was stated (reference 11) as:
A preliminary minimum set of calculations necessary to ensure the technical design adequacy and compliance with the plant i
design basis has been identitled and compared to existing-l calculations. Th,is resulted in the identification of-additional calculations that need to be performed, and existing calculations that need to be revised before fuel Ioading. TVA is proceeding to perform these calculations based on this preliminary set.
l Sargeant and Lundy was contracted to provide an independent assessment to ensure that the calculations for the
)
Electrical, Instrumentation, and Control System necessary to support the design basis had been identified and that all the necessary calculations existed, and were current and j
retrievable. This effort has been completed.
As a result of the Sargeant and Lundy review, TVA's Electrical Engineering Branch (EEB) has issued a branch Policy Memorandum (PN) 86-02 regarding the performance of electrical calculations. This policy memorandum identifies
.all EEB-controlled electrical calculations necessary to fully document the design basis of a standardized TVA nuclear plant. In addition, it identifies the set of calculations I
which must be completed in order to support fuel loading and the set of calculations which can be performed after fuel j
loading.
i PM 86-15 was also issued regarding documentation of the calculation's status. This policy requires that a checklist be prepared for each calculation listed in PN 86-02 and any additional plant-specific calculations identified according l
to the requirements of PN 86-02.
The preparation of the l
checklist will identify the current status of each calculation and will provide a method for monitoring the l
resolution of all identified deficiencies and the completion i
of all required calculations. Any required new i
calculation (s) or deficiency resolutions identified by the
{
above exercise to assure that safety-related' equipment can i
perform its intended designed functions under design basis i
conditions will be completed prior to fuel load of the respective units (internal tracking data for unit 1: May 31, 1987; for unit 2 August 31, 1988). The balance of the plant j
(BOP) calculations will be completed after fuel loading j
(internal tracking date: December 31, 1988). The performance of the calculations will establish the adequacy 4
of the existing design documents and drawings and will also 4
baseline the calculations for future revisions. Any l
deficiencies identified by the performance of these calculations will be handled separately and evaluated per the Nuclear Engineering Procedure (NEP) 9.1 " Corrective Action."
Page 18 of 44
,.., _ _,.. _ -. - - - - - _ _ - -.. ~ - -
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In ord2r to provant rscurranco, PMs 86-02 and 86-15 will ba
{
incorporated into the Watts Bar Engineering Project Manual as
(
a revision to the requirements of Engineering Procedure
/
(EP) 43.09, " Procedure for Identifying the Calculations j
Required to Support Electrical Design." Once PM 86-15 has been implemented, an assignment of responsibility for each l
identified calculation will be made to WBEP principal electrical engineers by fuel load of unit 1 (internal tracking date for assignment: Apell 30, 1987). This assignment of responsibility involves an acknowledgment of i
the calculations required to support the electrical system designs and ensures that the calculations are maintained in accordance with NEP 3.1, " Calculations" and NEP 6.1 " Change Control." In addition, PM 86-24 has been issued to detail and clarify the existing design process at the working level.
3.
Specific Verification Methodology NSRS Report Number I-85-06-WBN, " Investigation of an Employee Concern Regarding Cable Routing, Installation and Inspection at Watts Bar Nuclear Plant" (reference 9) dated July 8, 1985, was reviewed, as were the response memoranda from the Office of i
Engineering (references 10 and 11).
4.
Verification Analysis Discussions with the DNE project leaders for both WBN and SQN indicated that the set of calculations which must be completed in order to support fuel loading for SQN were one to two weeks from completion at the time of this ECTG verification.
5.
Completion Status While actions appear to be making pengress, it seems there is much left to be done regarding documentation of the calculations (projected date December 31, 1988).
Pending completion and necessary review, this item remains open.
I K.
(Open) I-86-101-SQN, Wire Bend Radius In Installations Using Conax Connectors
===1.
Background===
The issues concerning Conax connectors were derived from Employee Conce' ens generated as a result of the Watts Bar ECSP.
The issues were determined to be site specific to the SQN and were investigated and evaluated on that basis. These issues were:
Conax connectors in the containment did not always meet vendor wire bend radius requirements; connector installations with deficiencies were inspected and accepted by SQN QC; no action was taken by SQN QC management to investigate or i
document the deficiencies.
l Page 19 of 44
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.o 5
The NSRS investigated thasa issuss and issued report number I-86-101-SQN dated February 1386. A Corrective Action j
Report dated February 1986 was also issued. Two valves were i
found to have connectors where wire bend radii were below-l minimum requirements and workplans were found to have been written where work was performed and inspected; however, the plans did not provide reference to the vendor manual for 1
installation of the connectors.
Lack of QC management action i
could not be verified since ECTG could find no evidence to determine if the concerned individual brought this issua to QC i
management before the NSRS investigation.
The issue of the connectors not meeting the wire bend radius requirements and connectors installed and accepted with deficiencies is valid. A reinspection was initiated by TVA management. Specific corrective actions and the results
}
achieved are given in report 80203-SQN.
2.
Corrective Action Taken I
1 A review and verification for adequacy of the corrective action i
to this item included examination of the details in the TVA I
I Employee Concerns report (reference 48), corrective action i
report (reference 50) and memorandums (reference 49 and 51).
I ECTG conducted on-site discussions with the supervisor and engineer in the Modifications Section that were responsible for l
the inspection and rework of the Conax connectors. They j
verified the 100-percent inspection of Conar connectors Installed at the time of the inspection. This conversation also revealed that the work request and the special maintenance instruction (SMI) data packages associated with the inspection 4
and rework were sent to Quality Assurance (QA) for past work j
review, but were rejected for lack of Nuclear Performance i
Reliability Data System (NPRDS) reporting. The data packages l
are being held by Modifications because they do 'not have a data i
entry clerk. Verification for SQ-CAR-86-02-005 files was i
performed by Mike Stitt, QA representative on August 7, 1986 g/
(attached note to SQ-CAR-86-02-005).
- 3.
Specific Verification Methodology i
The original NSRS report (I-86-101-SQN) details as well as TVA l
ECSP report number 80203-SQN, Corrective Action Report (CAR)
SQ-CAR-86-02-005 and correspondence relating to this concern l
were reviewed. Principals involved in this activity were contacted to determine the status for SQN.
l I
i 4.
Verification Analysis l
ECTG verification activities indicated that all field terminations of Conax connectors were inspected and those found out of compliance with the vendor manual reworked. Work Requests B122261 and B106248 initiated the inspections. Twenty nonseparate work requests were initiated for rework of the q
connectors determined to be unacceptable.
Page 20 of 44 l
5.
Corplaticn Status l
The inspection and rework for all Conax connectors at SQN has been completed with the exception of the functional test for I gf 2-FSV-43-251 and 2-75-61-122.
SQ-DR-86-160R has been initiated I
to track completion of the functional test. When the work l
requests and SMI data packages are reviewed and approved by QE this NSRS issue will be ready for closure.
I L.
(Open) R-85-08-0E/NUC PR-01, Inadequate OE Environmental Qualification Procedure for Equipment j
Oualification by Similarity
(
===1.
Background===
NSRS stated that the OE procedure for environmental I
qualification of SQN electrical equipment allowed qualification by " similarity" but contained no definite criteria defining what l
constituted a "similar" item. NSRS recommended that these i
criteria be established and incorporated into the TVA procedures governing environmental qualification of electrical equipment, and that the criteria be used to re-evaluate the qualification status of electrical equipment previously qualified by similarity.
J 2.
Corrective Action Taken The Manager of Power and Engineering (PEE) responded August 8, 1985 (reference 1) that the IEEE 323-1971 and 1974 standards allowed for qualification by similarity (i.e.,
qualification by extrapolation of test data or operating
{
experience data) when supported by analysis / documentation. The response stated:
l j
Qualification by similarity is subjective by nature and involves a significant degree of engineering ' judgement.
Although detailed criteria cannot be developed for this method, OE will specifically include the requirement that qualifications by similarity be accompanied by supporting
)
analysis in the next revision of the discipline interface document which will be controlling future OE EQ activities.
This revision was to be in effect by October 30, 1985.
1 l
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Page 21 of 44
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=
Tha responsa also noted the spscial audit of the EQ program had begun July 20 1985, and committed to correct any deficiencies found in this independent evaluation of the TVA EQ program.
3.
Specific Verification Nethodology I
l 1
l NSRS Report R-85-08-0E NUC PR, dated June 5, 1985 was reviewed, j
y as were corrective action response memorandum (reference 1
i 1, 2, 3), TVA's EQ commitments in the Nuclear Performance Plan, Volume 2 (dated July 17, 1986), and the Equipment Qualification l
j Project (EQP) implementing documentation. Additionally, ECTG J
j discussed this topic with cognizant personnel of the Office of l
Engineering and Sequoyah site environmental qualification g
j project.
q l
s j
4.
Verification Analysis I
I TVA's environmental qualification commitments are described in l
the SQN Nuclear Performance Plan (July 17, 1986, section III.
j 1.0).
Standard Practice SQA 173, "Sequoyah Nuclear Plant 10 CFR 8
50.49 Environmental Qualification Program" establishes program l
policy for implementing and maintaining equipment i
j qualification. Office of Engineering Procedure NEP 5.1 provides I
guidance for preparation of EQ documentation and SQN-EQP-01, j
)
l g/
" Equipment Qualification Project Manual" contains the working level procedures for preparing the qualification file (EQ binders) that provides the auditable record demonstrating l
qualification for each item of equipment requiring I
qualification. The EQ Project Manual at each site provides the l
1 guidance and analytical approach for qualifying by similiarity.
This guidance and the resulting documentation in the EQ binders l
1s regarded as fully adequate, according to ECTG interviews with the Office of Engineering and Sequoyah equipment qualification l
project managers. Additionally, NRC's reviews of the EQ program l
have identified no programmatic problems with the approach for qualifying by similarity, according to these managers.
It was l
noted that, for the future, the EQ requirements, including those for qualifying by similarity, will be included additionally in a l
j new office of engineering interface document NE8 - DI - 125.01
" Program Requirements for Environmental Qualification of I
Electrical Equipment in Harsh E*tvironments".
l S.
Completion Status I
l ECTG's preliminary reviews of EQ program documentation and l
Interviews with EQ program personnel indicate that the NSRS concern with qualification by similarity has now been fully I
addressed. ECTG is conducting additional review of the guidance l
documented in the EQ Project Manual. Pending completion of this review, the NSRS item R-85-08-0E/NUC PR-01 remains open.
l Page 22 of 44
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i N.
(0psn) R-85-08-0E/NUC PR-02, Intd*oucte OE and NUC PR Prociduras fer Initiating and Processing NCR-FE/ERs 1,
Background
NSRS concluded that the OE and ONP procedures for processing
)
nonconforming conditions reports (NCRs), failure evaluations (FEs), and engineering reports (EEs) were inadequate for assuring their timely initiation and processing. NSRS reconunended in-depth review of TVAs program and possible changes to provide f>r effective interface between participating TVA organizations, establishment of centralized tracking, and significant reduction in the time required for processing and disposit'.oning.
2.
Corrective Action Taken The P&E response (reference 1) dated August 8, 1985 stated that an OE/0NP Management Task Force had been established April 1985 to assess TVA's program for handling conditions adverse to quality (CAQ). The task force assessment resulted in a complete ravamping of TVA's procedures controlling the handling of CAQs.
The response memorandum detailed the procedural and mar.agesent control changes which had been made to assure timely and responsive processing of CAQs, and the quality assurance verification activities to monitor ONP and OE compliance with the procedure requirements.
3.
Specific Verification Methodology
[
NSRS Report Number R-85-08-0E/NUC PR "Spw Ial Review of Office of Engineering and Office of Nuclear Pows Activities Associated l
wit Sequoyah Nuclear Plant Containment Pressure Instrumentation," dated June 5, 1985, was reviewed, as were l
corrective action response memoranda (references 1, 2, 3) and l
SQN's connaitments in the Nuclear Performance Plan (July 17, 1986). In addition, ECTG reviewed the OE and site CAQ
! OI procedures in order to verify adequate provisions for the l
initiating and processing of CAQs.
I
- 4.
Verification Analysis l
TVA's consnitment to providing effective and timely corrective l
action for a CAQ, including action involving multiple l
organizations, is described in the SQN Nuclear Performance Plan (July 17, 1986), section II.2.5.
l 1
Page 23 of 44 b
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ECTG varifisd that rsvissd procsdurss'for tha handling of CAQs have been issued as follows:
.l c
I SQN site procedure SQA118 " Handling of Nonconformance Reports l
L or Conditions Adverse to Quality Received from Office of Engineering" (Revision 8, dated October 20, 1986) l Division of Nuclear Engineering Procedure NEP 9.1,
" Corrective Action" (Revision 0, July 1, 1986) l The procedures include provisions for the issues addressed in l
this NSRS item, as follows:
I Prompt preliminary evaluation to make assessment of potential l
e
{
safety significance I R/
I Priority for identification and processing of operating plant j
CAQs l.
Timely coordination between DNE and the site organizations l
i l
Prompt notification of either the Site Director or Plant
}
}
Nanager f.s an initial step toward resolution of CAQs that I
present an immediate threat to health and safety l
S.
Completion Status i
Preliminary review of the engineering and site procedures indicates that adequate procedures are in place for the C&Q l
process.
Pending additional ECTG review of the current
{
timeliness of processing and adequacy of centralized tracking, I
this item remains open.
I N.
(Closed) R-85-08-0E/NUC PR-03, Lack of Priority on SON NCR Initiation l
l
===1.
Background===
NSRS stated that a time period of approximately two months j
elapsed between the time the assignment was made to evaluate the adequacy of accuracles of the SQN containment pressure differential transmitters (CPDTs) until the NCR was issued. It j
was recommended that OE define and document a policy to assure l
that operating plants are afforded the proper priority regarding i
work activities related to safety and quality. The policy should be effectively communicated to all levels of OE l
management and employees, and reemphasized periodically, i
i 1
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l Page 24 of 44 1j
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i 2.
Cerrsctive Action Taksn The P&E response (reference 1) dated August 8, 1985, outilned I
the complete revamping of TVAs procedures controlling the handling of CAQs. Priority handling of CAQ's was described as follows:
i i
All CAQs identified by CE employees are now immediately documented and reported to management. Specific timeframes 4
I are now established for issuance of the CAQ report and for prompt evaluation and documentation of generic implications.
The P&E response included a training plan and schedule which
~
i provided for completion of training for affected Office of Engineering, BFN and SQN site personnel by November 27, 1985, j
and training completion for affected WBN personnel before 4
licensing of unit 1.
3.
Specific Verification Methodology j
l l
NSRS report number R-85-08-05/NUC PR, dated June 5, 1985, was l
~
j reviewed, as were corrective action response memoranda j
(references 1, 2, 3) and SQN's comunitments in ths Nuclear l
Performance Plan (July 17, 1986).
..In addition, ECTG reviewed l
j the engineering CAQ procedure to verify its definition of a policy to assure that operating plants are afforded the proper l
priority regarding work activities related to safety and quality. }
4.
Verification Analysis l
1
}
The Division of Nuclear Engineering procedure NEP 9.1 provides that operating plant CAQs identified by DNE are assigned l
priority.
l I
5.
Completion Status I
ECTG review of the DNE procedure NEP 9.1 indicates that DNE has l
defined and documentad a policy to assure that operating plants are afforded the proper priority regarding work activities related to safety and quality. Communication of the policy to l
all levels of OE will be evaluated as part of the NSRS item R-85-08-0E/NUC PR-04 concerning lack of engineer awareness of the CAQ process. This NSRS item I-85-08-0E/NUC PR-03 is closed.
l 1
0.
(0 pen) R-85-08-0E/NUC PR-04, Lack of Engineer Awareness of the NCR-FE/ER Process
]
===1.
Background===
i i
NSRS concluded that some OE engineers were unfamiliar with the process as a whole and the allowable timeframes for processing NCRs, FEs, and Ets. NSRS recommended establishment of a formal and effective training program on the OE procedures for initiating and processing NCR-FE/ERs.
[
Page 25 of 44 l
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2.
Ccreactiva Action Taksn The P&E response (reference 1) stated that a comprehensive OE training program was being established.to provide detailed and effective training in the initiation, documentation, tracking, and processing of the entire CAQ-ER process. The response stated that all OE employees involved in nuclear plant CAQ-ER processing would receive the enhanced training before the end of October 1985.
It was noted that the TVA Task Force for responding to the NRC order modifying the BFN and SQN licenses may make further recommendations regarding overall TVA training. Subsequently, on September 27, 1985 TVA transmitted (reference 2) to the NRC TVA's commitments and training plans for assuring that operating plant CAQs identified by OE are assigned priority to ensure that safe operation of the operating plant is not compromised.
Upon issuance of a CAQ report by OE personnel, OE is required to lausediately notify and forward a written description of the C&Q to the operating plant management. For any CAQ identified by OE that represents an immediate threat to health and safety at any operating nuclear plant, OE isusediately notifies the effected site director at the time of identification by OE mansgement.
3.
Specific Verification Nethodology l
l NSRS report number R-85-08-0E/NUC PR, dated June 5, 1985, was reviewed, as were corrective action response memoranda l
(references 1, 2, 3) and SQN's cosusitments in the Nuclear Performance Plan (July 17, 1986).
In addition, BCTG began a l
review of training documentation for the C&Q process for both l
DNE and Sequoyah site personnel.
i 4.
Verification Analysis l
l k/
TVA's cosusitment for training DNE and SQN site personnel in the CAQ process is identified in the SQN Nuclear Performance Plan (July 17, 1986), section II.2.5.
The plan states that SQN site personnel involved in implementing the revised CAQ procedures g
have completed training.
ECTG verification on this item is l
continuing.
l 5.
Completion Status l
ECTG's review of training documentation for the CAQ process for g
both DNE and SQN site personnel is in process. Pending results I
of the review, this item R-85-08-0E/NUC PR-04 remains open.
g P.
(Open) R-85-08-0E/NUC PR-05, Lack of Timeliness in Initiatint and Processinz NCR-FE/ERs Page 26 of 44 i
1.
Bcckground NSRS stated that NCR SQNNEB8501 was not processed by OE within the timeframes specified by established procedures.
Additionally, stated NSRS, it was evident that OE frequently exceeded the specified time requirements for processing NCR-FE/ERs.
It was recommended that the necessity of compliance with NCR-FE/ER initiating and processing requirements be emphasized to all involved OE employees.
2.
Corrective Action Taken The P&E response (reference 1) stated:
a.
That timeliness and responsiveness were emphasized to OE employees in training completed June 28,.1985.
b.
That this was being clearly identified in the comprehensive training program identified in the response to item four above (R-85-08-05/NUC PR-04).
3.
Specific Verification Nothodology NSRS Report. R-85-08-05/NUC PR, dated June 5, 1985, was reviewed. I as were corrective action response memoranda (references 1, 2, 3) g and SQN's commitments in the SQN Nuclear Performance Plan (July 17, 1986). In addition, ECTG began a review of training l
documentation for the CAQ process for both DNE and SQN site l
personnel to verify that the necessity of compliance with CAQ g
requirements was emphasized to all involved employees, gf 4.
Verification Analysis l
This verification analysis is in process.
l 5.
Completion Status g
ECTG's review of training documentation for the CAQ process for l
both DNE and SQN site personnel is in process. Pending results of the review, this item R-85-08-0E/NUC PR-05 remains open.
l Q.
(Open) R-85-08-0E/NUC PR-06, Failure of Manaaement to Correct Problems with Timeliness and Responsiveness Involving the NCR-FE/ER Process
===1.
Background===
In the August 1985 report, NSRS concluded that problems with timeliness and responsiveness in identifying, documenting, and 3
correcting nonconforming conditions adverse to quality had been identified by audit organizations and recognized by TVA management as a problem as far back as 1980 but were yet to be corrected.
NSRS recommended that improved management controls be established and that the audit activities be intensified in the areas of NCR-FE/ER procedural compliance.
Page 27 of 44
2.
Corrective Action Taken The P&E response (reference 1) detailed the procedural and management control changes made as a result of the OE/NUC PR Management Task Force evaluations, as described in the response to item 2 above (R-85-08-0E/NUC PR-02).
Actions to increase both the depth and frequency of verification activity involving all aspects of the CAQ process were outlined in a Division of Quality Assurance memorandum (reference 3).
This memorandum included as an attachment the schedule for CAQ audits commencing during the first quarter of fiscal year 1986 and a description of the expanded scope of these audits.
l 3.
Specific Verification Methodology I
I NSRS Report R-85-08-0E/NUC PR, dated June 5, 1985, was reviewed.
I as were corrective action response mcmoranda (references 1, 2, 3) and SQN's commitments in the SQN Nuclear Performance Plan (July I
17, 1986).
In addition, for this item, ECTG reviewed the j
vorification activities for the CAQ process.
l 4.
Verification Analysis g
SQN's commitments for intensifying verification activity to lNl ensure compliance with CAQ procedural controls are identified in the SQN Nuclear Performance Plan (July 17, 1986),Section II.2.5.
I The ECTG verification analysis is in process.
5.
Completion Status l
ECTG's review of CAQ verification activities is in process.
Ponding results of the review, this item R-85-08-0E/NUC PR-06 I
remains open.
l Page 28 of 44
)
i l
APPENDIX A (ECTG-NSRS-02) i.
i The following 69 NSRS open items are considered applicable to SQN by ECTG but i
closure before startup does not appear essential.
I j
79-09-01-1 Employee Concern Over Escessive Wire Lifting Practices to Facilitate Testing i
i l
IN 1978 Division of Power Systems Operations (PS0) personnel found that i
i testing Watts Bar Nuclear Plant (WBN) 6900-volt and 480-volt shutdown j
boards and diesel generator load logic and control boards required a large number of wire lifts, test lead installations.and wire 1
l determinations. This was contrary to TVA position in WBN Final Safety l
Analysis Report (FSAR) question 040.10. WBN Design Change Request l
(DCRs) for test blocks to facilitate testing was turned down by the 4
Division of Engineering Design (EN Das) on the basis that the two-year j
testing interval was too infrequent to justify installation of test blocks. NSRS recosusended that Office of Power resubmit DCRs and define i
where test blocks were needed.
)
79-09-01-2 Employee Concern Over Escessive W!re j
L1fting Practices to Facilitate Testing 4
l IN 1978 P50 personnel found that testing WBN 6900-volt and 480-vol shutdown boards and diesel generator logic and control boards required a 4
j large number of wire lifts, test lead installations, and wire roterminations. EN DES must make provisions to facilitate testing, j
troubleshooting, and maintenance of the relays, indicating instruments.
l transducers, and timers on these boards.
9 I
79-09-01-3 Employee Concern Over Escessive Wire L1fting Practices To Facilitate Testing i
The Division of Nuclear Power should review maintenance'end surveillance l
instructions at all nuclear plants to ensure that TVA policy of minimizing the number of jumpers and/or wire lif ts required to facilitate testing or maintenance is being implemented. DCRs should describe where and why test blocks are needed.
I
{
R-80-10-BFN-01 Unreviewed Safety Question Determination l
l On July 9, 1980, at the request of BFN, and because of extended hot i
weather, ONP authorised wire lifts to defeat the automatic tripping function of the cooling tower lift pumps when cold water discharge j
temperature reaches 95'F.
This waiver was estended to July 21 and again j
to July 28.
In addition, the 95'F temperature trip requirement in the cold water discharge channel was raised to 97'F.
An NSRS review revealed that an unresolved safety question determination had not been j
conducted for this temporary safety-related alteration of an FSAR requirement as required by 10 CFR 50.59 paragraph VI.A.
i Page 29 of 44 1
)
u_.,_,.~.__________,,_..-________.
_ _ _ ~.. _.
f1 APPENDIX A (ECTG-NSRS-02) (continu,d) i l
R-80-10-BFN-IV A Expansion of DPM N73011 j
DPM N73011 section 7.3 should be expanded to ensure that proposed nitorations that make changes to systems or procedures described in the j
SAR are reviewed to determine if an unreviewed safety question is j
involved.
R-81-02-BFN Develop a TVA Policy Regarding Loss of Safety Function i
j Improve procedures handling evonts involving loss of or potential loss of safety functions not covered by technical specifications.
R-81-04-YCN/NPS-01 Level of Safety Review of Yellow Cresk Nuclear Plant (YCN) i NSRS concludes that YCN is not receiving an adequate level of safety J
review by NSA as required by TVA Topical Report TR-75-1A R4 Section l
17.1A.1.2.3 (4). There were no procedures in place governing the safety i
review, there was no written program to ensure adequate scope of review.
I and no in-depth studies had been issued to supplement the decreased 1
level of squadcheck reviews. NSRS has determined that this issue is appilcable to all nuclear plants under construction.
l R-81-04-YCN/NPS-02 Inadequacies of RP 4.02 i
j NSRS concluded that RP 4.02 "Ragineering Change Notices Handling" l-vloisted criterion III of Appendix 5 to 10 CFR 50 in that no guidance for determining which organizations are required to approve an RCN is
]
given. NSRS has determined that this issue is applicable to all nuclear j
plants under construction.
R-81-08-BFN-20 Quality Assurance and Quality Control of Operational Activities 1
ONP should increase the scope of the OPQA&A audit program to provide the MSRS reasonable assurance that the nuclear facility will be operated within the technical specifications and conditions of the 11eense.
R-81-08-BFN-41 QA&A Staff i
ONP should evaluate the QA audit program to determine whether or not a
l additional personnel resources are needed to effectively implement the 4
program. Action should be taken as appropriate to support the results j
of the evaluation.
1 J
I 4
i j
Page 30 of 44
)
APPENDIX A (ECTG-NSRS-02) (continued)
R-81-14-0EDC(BLN)-32 Inadequate Storage of Audit Support Records Storage of audit support records was not in accordance with ANSI N45.2.12 and N45.2.9 requirements in that they were stored in non-fire-rated cabinets.
R-81-14-0EDC(BLN)-41 QAB Auditor Training A written approval program for the training of QA auditors had not been
- established. Develop an administrative procedure delineating QA auditor training requirements and management approval of training programs.
R-82-08-NPS-01 Requirements /Needs/ Activities Matrix Lack of comprehensive chemical and radiochemical program manual has led to Chemistry Section personnel not being fully familiar with requirements and commitments that have been made on behalf of water gus11ty control with the exception of chemistry requirements associated with technical specifications.
R-82-08-NPS-02 Quality Assurance Program for Chemistry Activities The ONP Quality Assurance Program which provides QA program requirements for all of its facilities if they perform quality-related activities for its nuclear power plants, was found by NSES devoid of controls required to be placed over safety-related chemistry activities. This issue was primarily written against the ONP QA Manual and not against any technical activity which might be accomplished by the Central Laboratory Service (CLS) or any other non-nuclear power facility, as well as the power plants themselves.
R-82-08-NPS-03 Chemistry Program Organization and l
Responsibility Review ONP's functionally decentralized organization has bred autonomy among J
its organizational units so that responsibility of one unit with respect l
to the activities of another unit is not well defined, thus causing
[
duplication of effort among other things.
e L
l i,
i I
t h
b II J
Page 31 of 44 o
L
. _-~
~_
APPENDIX A (ECTG-NSRS-02) (continued)
R-82-08-NPS-04 Procedural Controls for conducting Safety / Quality Affecting Activities Within the Chemical Engineering Group 1
i (CEG) d j
No procedural controls had been formulated to accomplish the safety / quality affecting activities being performed by CEG. Certain actions taken by the group circumvented normal administrative controls I
for assuring safety / quality objectives were maintained.
)
R-82-08-NPS-05 Program Improvement j
At the time of this review, the ONP central office CgG was found to be more in a reaction mode which addressed problems as they were raised q
rather than being forward-thinking.
j i
R-82-08-NPS-06 Internal Review and Feedback Process No internal review mechanism was established with the CEG to assess the effectiveness of its activities, to verify the sites were implementing its directives (division procedures), to periodically advise management of overall chemistry program effectiveness and to make recommendations j
for corrective action.
R-82-08-NPS-07 Verification of Onsite Radiochemical I
Laboratory Analyst (RLA) Training The nuclear central office training branch does not monitor the effectiveness of onsite training programs. An extension of their j
responsibility is to direct training programs when continued for certification and/or qualification at the site level as, for example, l
RLA training.
1 R-82-08-NPS-09 Intergraded Calibration and Chemical
}
Program Development CLS has not established formal program controls to accomplish its j
chemistry and other chemical support function activities and to i
accomplish its QA responsibilities to ONP.
i j
R-83-08-BLN-2 Development of Cleaning / Flushing l
Program Control Procedures 1
EN DES's generated documents G-39 and N4N-981 did not include all the l
requirements of ANSI N45.2.1-1973 and past TVA commitments necessary for the development of an adequate flushing / cleaning program.
I 1
Page 32 of 44
APPENDIX A (ECTG-NSRS-02) (continued)
R-83-08-BLN-5 Approval of The 1/8-Inch Variance For Acceptable Purge Dam Residual Particle Size Specification Revision Notice SRN-N4M-891-2 states in part, paper and glue particles up to 1/8-inch in any direction appearing on the strainer during proof flushing are acceptable. The relaxation of particle size from 1/32-inch to 1/8-inch granted by EN DES had not been approved by either the ANSI coussittee or NRC.
I-83-13-NPS-1.s Quality Engineering Branch Records There is no overall OEDC effort to provide ONP a complete QA file integrating both construction and QEB records la a usable form. Develop an integrated records system for QA records that will satisfy the needs of ONP and the Office of Engineering Deslan and Construction (ORDC).
I-83-13-NPS-1.b Quality Engineering Branch Records TVA would meet the requirements of NRC regulations and ANSI standards if the current requirements and intent of documented procedures were followed. Correct implementation deficiencies identified in the estating QA record system.
I-83-13-NPS-1.d Quality Engineering Branch Records There is no coordinated TVA effort to ensure the adequacy of identification, collection, collation, indesing, and distribution of vendor QA records. Clarify organizational responsibilities for storage and retrieval of vendor documents and manuals.
I-83-13-NPS-2 Quality Ir.gineering Branch Records A task force reporting to assistant GM should esamine NSRS findings relative to vendor QA records and take steps to correct the inadequacies.
Report back to Office of General Manager (OGM) on the planned actions and schedule for completion of the integrated records system.
R-83-18-NPS-01 Management of The Reorganisation of the TVA Radiation Protection And Radiological Emergency Planning Program The responsibilities for conducting TVAs radiation and radiological protection program were not well defined.
Upper management in ONP should take action to assure that the final decision is promptly made regard!ng the assignment of responsibilities and update all TVA corporate documents accordingly.
i Page 33 of 44 l
1
APPEND X A (ECTG-NSRS-02) (continued)
R-83-18-NPS-02 Office of Nuclear Power Program and Licensing Documents The ONP program and licensing documents for radiation protection and radiological emergency planning had not been issued or were out of date. Resources should be directed toward preparation, updating, and issuing area plant manuals, OQAMs. SQN and BFN Technical Specifications and PSARs, and plant standards practices.
R-83-18-NPS-03 Organizational Emphasis of ONP Radia*.lon Protection and Radiological Emerhancy Preparedness Programs.
The radiation protection and emergency preparedness programs had been organizational 1y doemphasized within ONP. ONP should place more organizational emphasis on these programs, increase staff size, and add the technical expertise necessary to develop and maintain their respective programs.
R-83-18-NPS-04 Organizational Placement of Health Physics at Nuclear Plants The reporting chain for Inplant Health Physics Section was described as being to the Assistant Superintendent for maintenance which is not in compliance with NRC RG 8.8 and NUREG-0731. ONP should formalize a reporting change for the inplant health physics section from Assistant Superintendent for Naintenance to the Plant Superintendent or establish a new position for that purpose.
R-83-18-NPS-05 Health Physics Technical Staff Onsite The Health Physics Section at SQN does not have sufficient technical expertise in Health Physi M to identify unique and new health physics problems as they occur. Establish a technical services position in the plant Health Physics Soction.
R-83-18-NPS-06 Radiological Health Staff (RHS)
Technical Support RHS is not providing the technical support or long range planning support to the plants commensurate with their abilities. ONP and RHS should establish a mechanism to provide more presence of the RHS personnel in the operating plant whereby RHS technical level personnel can work fulltime on plant technical programs.
Page 34 of 44
1 APPENDIX A (ECTG-NSRS-02) (continued)
R-84-05-WBN-14 Inspector Certification Records No QC inspector certification records were kept at the site. A monthly printout was sent from POTC listing inspector certifications which sometimes were in error or indicated partial certifications without specifying the area.
R-84-17-NPS-01A The Procurement System is too Cumbersome and Not Well Known by the Users The ONP procurement program is wasteful, cumbersome, and overloaded with redundant reviews. Eliminate all unnecessary steps in the procurement cycle with the goal of placing very few, if any, steps between the requisitioner and the purchasing agent.
R-84-17-NPS-018 The Procurement System is too Cumbersome and Not Well Know by the Users No one in OhP knew the procurement process much beyond their sphere of involvement. A formalized documented training program covering the' entire procurement process should be developed and required for all personnel within the procurement cycle from the requisitioner to the purchasing agent.
R-84-17-NPS-01C The procurement System is too Cumbersome and Not Well Known by the Users The lack of awareness of the procurement process delays resulted in urrealistic espectations being placed upon the system with regard to delivery time. A realistic timeframe should be established for routine non-special order procurements. A mechanism should be included in the procurement system to periodically evaluate and adjust that timeframe, as uell as communicate the timeframes to involved personnel.
l
- R-84-17-NPS-01D The Procurement System is too Cumbersome and Not Well Known by the Users In the planning of plant modifications, engineers could not rely on the procurement process to produce materials in tlue to meet schedules.
Material availability and procurement timeframes should be included in all maintenance and modification planning activities.
i Page 35 of 44
l j
1 APPENDIX A (ECTG-NSRS-02) (continued)
R-84-17-NPS-03 Excessive Review of Request for Deliveries (RDs) On Indefinite Quantity Term (IQT) contracts ONP was reviewing and approving RDs with the same rigor as the initial IQT contract. ONP should streamline its procedure for the review and approval of RDs to be in line with the requirements of the TVA procurement manual.
R-84-17-NPS-04 Insufficient Documantation for Transferred Material Sites requesting material to be transferred to them by another TVA organization or location did not specifically identify documentation requirements or regulee a copy of the original contract the material was~
purchased under.
R-84-17-NPS-06 BFN Power Stores Receipt Inspectors Not Trained to Inspect Material Power Stores Receipt Inspectors are not trained to receive materials with Certificates of Compliance (COC), Certified Mill Test Reports l
(CNTR) or other QC documentation. On at least two separate occasions, BFN Power Stores Personnel receipt inspected and accepted material with
[
CNTRs.
R-84-17-NPS-07 Natorial With Limited Shelf Life Not i
Reordered in a Timely Manner l
t i
Neither 8FN nor SQN were reordering material with sufficient lead time l
to have new material on hand before esisting material's shelf life l
l espires. ONP should revise the OQAN to establish programs to inspect I
and reorder limited shelf life material. The current three month
)
reorder lead time specified in DPN N7742 should be re-evaluated and adjusted as necessary.
j
(
- R-84-17-NPS-08 Materials Management System (MANS)
Under-utill ed
?
The MANS system was being under-ut111:ed in that its capability to track
(
inventory items usage and to reorder items automatically was not being i
used. ONP Power Stores and Natorials Management Services Section should
}
jointly increase efforts to ut111:e NAMS in the most effective manner possible.
t F
c Page 36 of 44 l
APPENDIX A__(ECTG-NSRS-02) (Continued)
R-84-17-NPS-09 10 CFR Part 21 Requirements Incorrectly Linked to Nuclear Power QA Requirements Nanufacturing quality and receipt inspections were automatically reduced when 10 CFR 50 part 21 requirements were determined not applicable.
Remove the influences of 10 CFR 21 applicability upon the determination of required quality levels for items or services.
Revise OQAM part III, section 2.1, appendix F accordingly.
I-84-31-BFN-01 Investigation of Potential Significant Events A number of technical specifications were violated during a full power shutdown margin test. ONP should establish an ongoing program to provide internal investigations of potential significant events at TVA nuclear plants.
I-84-31-BFN-02 Interpretation of Regulatory Requirements The technical specifications violated during a full power shutdown nr.rgin test were perceived to be of the gray area type that could be interpreted differently with justification. ONP management should identify those areas of regulatory requiconents, including technical specifications, that are considered ta represent interpretation problems.
1 I-84-31-BFN-03 Interpretation of Regulatory 4
.equire nts A number of technical specification interpretations by line personnel were incorrect during a full power shutdown margin test. ONP should establish a policy and procedures for the interpretation of regulations l
for plant operation under temporary technical specification modificatica, waivers, or exceptions.
I-84-31-3FN-04 Commitment to Procedural Controls l
After a number of procedure violations during a full pewer shutdown r
margin test, line personnel made little effort to show N8R3 that procedural controls were of paramount importance. ONP management should establish a written policy to ensure the necessary commitment is made to procedural controls and ensure strict adherence to procedures by all personnel.,
t l
1 t
Page 37 of 44
APPENDIX A (ECTG-NSRS-02) (Ctatinu d)
R-84-32-NPS-01 Inadequate TVA Quality Program Action was incomplete on developing and implementing an integrated quality program that will account for the identification and control of attributes such as: activities affecting quality; quality program I industry standards; and vendor components, systems, structures, etc.
data I-84-33-BFN-07 Piping Analysis OEDC failed to review all other piping analysis sections after a 1982 WBN independent review team identified basic root counes for nonconforming conditions in WBN piping.
I-84-33-BFN-08 Failure of QA to perform audits and surveillances of identified problem areas within Piping Analysis Sections No audits or surveillances have been conducted or are scheduled to be performed by QA organizations of the BFN Piping Analysis Section. No audits /survalliances were performed to verify the implementation and effectiveness of the WBN piping analysis section procedures.
I-84-34-SQN-01 Failure to follow QA procedures by an individual at SQN The alleged failure to follow QA procedures by individual "A" for the two examples cited by individual "B" were substantiated. Conduct a survey of individual "A's" activities to determine other areas where he could have potentially failed to follow QA procedures and their safety implications.
I-84-34-SQN-02 Completion of TVA Mark Letter Description on the Transfer Requisition Documents The potential of non-Class IE cable being installed in a Class IE system appears to be greater when cables are transferred from one site to another site where the TVA cable mark letters do not define the same cable at both sites.
Page 38 of 44
]
1 l
APPENDIX A (ECTG-NSRS-02) (Continued)
I-85-06-WBN-4 Timely and Responsive Corrective Actions for Resolution of Identified Problems Evaluate the NSRS, INPO, and other reports applicable to WBN unit 1 to determine if these findings individually or collectively are violations of WBN licensing requirements.
R-85-07-NPS-01 Manager of Power and Engineering Appointment of a Records Manager The Manager of Power and Engineering should appoint a manager to ensure that records associated with the procurement and installation of QEB source inspected equipment and materials are indexed and stored. The scope should include all past and future QRB source inspected procurement records for SQN, WBN and BLN and establish a schedule of completion for past records indexing and storage.
SAFEGUARDS R-82-01-PSS-01, " Authorities and Responsibilities Not Clearly Defined in Writing" R-82-01-PSS-02, " Procedure for Functioning of Branch Staff Not Defined in Writing" R-82-01-PSS-03, "Rapectations of PSS Management not Defined in Writing" R-82-01-PSS-04.B.1, " Lack of Guidance and Support to Fleid Staffs" R-82-01-PSS-04.5.2, " Lack of Guidance and Support to Field Staffs" R-82-01-PSS-04.C.1, " Lack of Guidance and Support to Field Staffs" R-82-01-PSS-05, " Internal and External Interfaces Not Well Defined" R-82-01-PSS-11,." Lack of Document Control" R-82-01-PSS-12. "T&Q Implementing Instruction R-82-01-PSs-13, "Natorial Revisions" - Material Review and Approval R-82-01-PSS-15 " Site Security Organization - Administration Responsibilities and Authority Not Clearly Defined" I
\\
i d
Page 39 of 44
R-82-01-PSS-24, "Bellefonte Security Facilities Tracking System" R-83-16-NPS-01, " Revision of the Safeguards Information" R-84-06-NPS-01, " Revision of the Safeguards Information" The issues addressed by NSRS individually and collectively indicated that the nuclear security responsibilities of the Public Safety Service (PSS)
Nuclear Security Program were not clearly defined by policies, procedures, or directives necessary for the administration of the program, nor adequately implemented when delineated in physical security, j
safeguard contingency, and training and qualification plans.
References j
1.
Memorandum from H. G. Parris to K. W. Whitt dated August 8, 1985,
" Nuclear Safety Review Staff (NSES) Special Review of the Office of Engineering (OR) and Office of Nuclear Power (NUC PR) Activities Associated with Sequoyah Nuclear Plant (SQN) Containment Pressure i
Instrumentation - NSRS Report No. R-85-08-OR/NUC PR" (L44 850808 800) l 2.
Memorandum from H. G. Parris to J. N. Grace, of NRC, dated September 27, 1985 " Sequoyah Nuclear Plant Units 1 and 2 Browns Ferry Nuclear Plant Units 1, 2, and 3 (RA-85-49)" (L44 850927810) i
)
3.
Memorandum from R. J. Nullin to Those listed dated November 13, 1985,
{
" Division of Quality Assurance (DQA) Verification Plan for Conditions Adverse to Quality (CAQs)" (L17851106801) l 4.
Nemorandum from H. G. Parris to H. N. Culver dated July 25, 1984, " Watts Bar Nuclear Plant Units 1 and 2 - Nuclear Safety Review Staff Report R-84-07-WBN" (DRS 840726 001) l 5.
Memorandum from R. W. Centre 11 to K. W. Whitt dated March 15, 1985,
" Watts Bar Nuclear Plant Units 1 and 2 - NCR WBN CRB 8418 - Destroyed j
RDS Calculations" (541 850304 004) i 6.
Nemorandum from C. Bonine to K. W. Whitt dated May 28, 1985, "Sequoyah l
Nuclear Plant OC Response to Nuclear Safety Staff Report No.
I-84-34-SQN" (Col 850529 007) 7.
Memorandum from K. W. Whitt to C. Bonine dated July 8, 1985, "NSRS Report No. I-84-34-SQN-Investigation of Alleged Violations of QA Procedures at Sequoyah Nuclear Plant" (QO1 850709054) 8.
Memorandum from C. Bonine to K. W. Whitt dated July 13, 1985, "Sequoyah i
j Nuclear Plant OC Response to Nuclear Saf0ty Staff Report No.
I-84-34-SQN" (Col 850723004) 4 i
j j
l
{
l Page 40 of 44 1
9.
NSRS R2 pert Numbsr I-85-06-WBN, " Watts Bar Nuc1scr Plant (WBN) -
Investigation of an Employee Concern Regarding Cable Routing, Installation, And Inspection - Nuclear Safety Review Staff Report No.
I-85-06-WBN," dated July 9, 1985 (RIMS 001 850709050) 10.
Memorandum from W. S. Raughley to J. A. Raulston dated September 25, 1986, " Watts Bar Nuclear Plants Units 1 and 2
- 10CFR 50.55(E) - Final Report SCR WBN EEB8571" 11.
Memorandum from J. R. Lyons to J. A. Mcdonald dated October 20, 1986,
" Watts Bar Nuclear Plant - Units 1 and 2 - Lack of Adequate Calculations to Document Electrical System Design Basis 10 CFR 50.55(e) Report No. 3 (Final) - NCR SCRWBNEEB 8571" 12.
Nuclear Safety Review Staff Report Number R-84-17-NPS " Review of Procurement Practices and Procedures for Operating Nuclear Power Plants" dated June 11, 1984 - December 5, 1984, (QOI-85-0312-051) 13.
Memorandum (draft), H. G. Parris to K. W. Whitt, dated August 22, 1985 Nuclear Safety Review Staff (NSRS) - Report R-84-17-NPS
" Review of Procurement Practices and Procedures for Operating Nuclear Power Plants" 14.
Memorandum, H. G. Parris to K. W. Whitt dated January 6, 1986, Nuclear Safety Review Staff (NSES) - Report R-84-17-NPS
" Review of Procurement Practices and Procedures for Operating Nuclear Plants" 15.
Memorandum, Erik Kvaren to W. R. Brown dated September 4, 1986, Nuclear Safety Review Staff (NSRS) - Report R-84-17-NPS
" Review of Procurement Practices and Procedures for Operating Nuclear Power Plants" (L 67 86 0829 888).
16.
NSRS Report Number R-82-08-NPS "Special Program Management Review" dated February 18, 1983 (GNS 83 0225 051) 17.
Memorandum H. N. Culver to H. G. Parris, dated February 9, 1984, Follow-up Review of the Nuclear Safety Review Staff Special Program, Review of the Office of Power Water Quality Program - Nuclear Safety Review Staff Report Number R-83-26-NPS 18.
NSRS Report R-84-26-WBN, "NSRS Routine Review of the Response to NSRS Recommendations Identified in NSRS Report Number R-84-19-WBN" dated September 5, 1984 19.
NSRS Report R-84-19-WBN, NSRS Assessment of the Results of the Black and Veatch Independent Design Review of the Watts Bar Nuclear Plant Auxiliary Feedwater System, dated June 15, 1984 i
l Page 41 of 44 1
_ _ _, _ _ _ _ - ~ -
- 20. 'Nimorendum, H. N. Culvar to W. F. Willis, dated Stpterbar 5, 1984, Response to Board Comment - Watts Bar Nuclear Nuclear Plant - Response to Board Question on Power Response to NSRS Report Number R-84-19-WBN, Assessment of the B&V Independent Design Review of the WBN Auxiliary Feedwater System (GNS 84 0906 100) l 21.
Memorandum, G. R. Owens to NSRS Flies, dated August 21, 1985 " Watts Bar
~
Nuclear Plant - Status and Disposition of NSRS Concerns R-84-19-WBN-06 and -07 Results From Independent Assessment of the B&V Review" 22.
Memorandum, from M. N. Sprouse to H. N. Culver dated May 13, 1980,
" Assessment of the Tornado Missile Protection at Sequoyah Nuclear Plant" (CEB 800513040) 23.
Memorandum, from N. N. Sprouse to H. N. Culver, dated August 8, 1980, "Sequo)ah Nuclear Plant - Tornado Missile Protection " (CRB 800808 007) 24.
Memorandum, M. N. Sprouse to H. N. Culver dated December 22, 1981, "Sequoyah Nuclear Plant - Assessment of the Tornado Protection Criteria"'
(CEB 81 1222 015) 25.
Memorandum, H. N. Culver to M. N. Sprouse dated August 17, 1981, "Sequoyah Nuclear Plant - Assessment of the Tornado Protection Criteria" (GNS 810817 054) 26.
Nemorandum, M. N. Sprouse to M. N. Culver dated Nay 12, 1982, " Watts Bar Nuclear Plar.t - Assessment of the Tornado Protection Criteria - Civil Engineering Branch Report CR8-82-10" (CRB 820512 021) 27.
NSRS Report Number R-86-01-SQN, "SQN-NSES Follow-up Review of Open Items from Previous NSRS Reviews and Investigations," dated March 21, 1986 (Q01 860321 051) 28.
Memorandum R. Gray Beasley to J. P. Vineyard, dated February 14, 1986, "Sequoyah Nuclear Plant - QA Review of Operational Readiness - NSRS Open Items - Surveillance Report Number S86-10" (505 860214 001) 29.
Memorandum R. K. Seiberling to R. L. Gridley, dated May 1, 1986,
" Schedule of TVA/NRC Activities before Sequoyah (SQN) Restart" (QO1 860501 223) 30.
Memorandum J. W. Anderson to G. H. Kimmons, dated August 24, 1983, "NSRS Report Number R-82-07-WBN" (0QA 830824 002) 31.
Nemorandun H. N. Culver to J. W. Anderson, dated February 3, 1984,
" Watts Bar Nuclear Plant - Closure of NSRS Item R-82-02-WBN-24" (GNS 840203 054)
Pa8e 42 of 44
l 32.
McCorandum, H. L. Absrcrorbio to W. R. Brown, dated Octobsr 29, 1986, "Sequoyah Nuclear Plant (SQN) - Employee Concerns Task Group (ECTG)
Element Report 407.03 SQN - Material Control Category - Corrective Action Plan (CAP). (503 861024 805).
33.
Memorandum, C. N. Johnson to R. O. Barnett, dated November 13, 1986, "Sequoyah Nuclear Plant - Policy Memorandum PM 86-02 (CEB) - Civil Discipline Policy for Design Calculations (B25 861113 342).
34.
Memorandum, C. N. Johnson to R. O. Hernandez, dated November 13, 1986, "Segyoyah Nuclear Plant - Implementation of Segouyah Civil Discipline Calculation Action Plan (B25 861117 304).
35.
Memorandum, W. R. Brown to H. L. Abercrombie dated October 28, 1986 "Sequoyah Nuclear Plant (SQN) - Weld Project Investigation / Evaluation Reports" 36.
Welding Project Generic Employee Concern Rvaluation Report (WP-02-SQN-R2) dated August 26, 1986 37.
Safety evaluation by the Office of Nuclear Reactor Regulation Related to Assessment of TVA's welding Program.
Sequoyah units 1 and 2 docket numbers 50-327/328 October 30, 1986 38.
Overview of welding program including procedural compliance assessment preliminary August 21, 1986 (Preliminary) 39.
Technical Rvaluation Report (TER) related to the Welding Concern Program at TVAs Segouyah units 1 and 2, dated August 1986 by Carl J. Cazjkowski and Milford H. Schuster of the Department of Nuclear Rnergy, Brookhaven National Laboratory, Upton, New York 11973 40.
Letter to W. F. Willis, General Manager, TVA from Claude M. Key, Jr.
dated' November 7, 1985 41.
Memorandum K. W. Whitt to W. F. Willis dated September 27, 1985, "NSRS response to QTC Investigation Report, Preliminary Report Number N5-85-001-001 relating to Visual Inspection of Structural Welds Through Carbo Zine Primer" (QO1 350927 051) 42.
Memorandum J. W. Anderaon to H. N. Culver dated January 30, 1984, " Watts Bar Nuclear Plant - AWS Weld Program" (0QA 840130 002) 43.
Memorandum J. W. Anderson to G. H. Kimmons dated August 24, 1983, "NSRS Report Number R-82-07-WBN" (0QA 83-0824-002) 44.
Memorandum G. H. Kimmons to H. N. Culver dated July 23, 1982, " Watts Bar Nuclear Plant - Inspection Practices of Structural Stell Welds - Special Report - Nuclear Safety Review Staff Report Number R-82-07-WBN" Page 43 of 44
e 45.
M corendum G. H. Kimmons to J. W. Andsrson dated June 21, 1983 "Wstts Bar Nuclear Plant - Resolution of NSRS Recommendation Number R-82-07-WBN-06" 46.
Institute of Nuclear Power Operations (INPO) Corporate Evaluation of Sequoyah Nuclear Plant, December 1985.
47.
The Employee Concerns Special Program Report Number 237.2 (B) (Sequoyah Element) Revision 1, dated November 26, 1986, " Electrical Protection Design 400 to 500 Breakers Unacceptably Set."
National electrical code and good engineering practices violated, Limitorque valve operators inadequately fused.
48.
TVA Employee Concerns Special Program Report Number 80203-SQN, Revision 1 49.
Memorandum R. W. Olson to D. C Craven dated March 6, 1986 "Sequoyah Nuclear Plant - Corrective Action Report (CAR) SQ-CAR-86-02-005" 50.
Corrective Action Report SQ-CAR-86-02-005 dated February 10, 1985 51.
Memorandum R. W. Olson to D. C. Craven dated March 26, 1986 SQN proposed corrective action for corrective action report (CAR) SQ-CAR-86-02-005 52.
Memorandum Reik Kvaven to W. R. Brown dated September 4, 1986 " Nuclear Safety Review Staff (NSRS) - Report R-84-17-NPS-Review of procurement practices and procedures for operating Nuclear Power Plants" L67 860829 883 4
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