ML20207P468
| ML20207P468 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/20/1986 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P454 | List: |
| References | |
| 203.3(B), 203.3(B)-R, 203.3(B)-R00, NUDOCS 8701160165 | |
| Download: ML20207P468 (27) | |
Text
e A
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM
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REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 0 TITLE:
EXPERIENCE FEEDBACK Tracking System for Comitment Inadequate PAGE 1 0F 23 REASON FOR REVISION:
4 PREPARATION
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SIGNATURE
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REVIEWS REVIEW COMMITTEE-Y =-A
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"M DATE g ATURE TAS:
y SIGNATURE DATE CONCURRENCES CEG-H:b NWd 12-70 3 SRP:
SIGNATURE DATE SIGNATURE DATE APPROVED BY:
ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
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8701160165 870109
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 h
PAGE 2 0F 23 1.
CHARACTERIZATION OF ISSUES:
Concern:
Issues:
WI-85-100-034 a.
There is no formal system to track
" Engineering (ENDES) inadequately and assign commitments for problems addresses and considers opera-identified by INP0.
tion, maintenance, testing and construction requirements b.
There is poor tracking of NRC and general industry practices experience information.
in the design process. There are not forced interactions c.
There are no forced interactions with other utilities, no formal with other utilities for system to track and assign information exchange.
- commitment for problems identified to INP0, and poor d.
Feedback to engineering of tracking of NRC experience.
corrections for problems identified information. CI has no further is not adequate.
information. Anonymous concern via letter."
-Q NOTE: The following issues from this concern are addressed in Sequoyah Element Report 203.2.
Engineering inadequately addresses operation requirements in design process.
Engineering inadequately addresses e
maintenance raquirements in design process.
Engineering inadequately addresses construction requirements in design process.
Engineering inadequately addresses testing requirements in design process.
Engineering inadequately addresses general industry practices in design process.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(8)
SPECIAL PROGRAM REVISION NUMBERi 0 b
PAGE 3 0F 23 2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Documentation Identifiers:
o Identified by Nuclear Safety Staff Date May 1985 l
NSSS Report 85-02, " Deficiency in Implementation of the L
Nuclear Experience Review Program"
- o Identified by Employee Concerns Task Group: Operations Date 6/5/86 Report 307.09, Element: " Experience Review Program" a
3.
DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
I. k None i
4.
INTERVIEW FILES REVIEWED:
Expurgated file for WI-85-100 was examined, and no additional
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unreviewed information was found.
i 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
I 6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER
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APPLY OR CONTROL IN THIS AREA?
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See Appendix A.
!l 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
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TVA. EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0
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PAGE 4 0F 23
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8.
EVALUATION PROCESS:
a.
Reviewed baseline documents to determine policy and procedures for experience feedback program for operations and engineering at SQN.
b.
Determined the existence and details of the following types of programs at SQN:
o Formal experience feedback program o Review and followup on INP0, NRC, industry experience infonnation c.
Determined programs and methods used to address feedback from 8.b for SQN Unit 1 and Unit 2:
o Organization o Communication methods
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d.
Reviewed the implementation of the existing programs for incorporating experience information into plant design and operation.
9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
10/80:
NUREG-0737, Task Action Plan I.C.5 issued by NRC to y
require preparation of procedures for ferd5ack of i
operating experience to plant staff 12/23/80:
TVA responds to NUREG-0737 stating its program is adequate 07/28/81:
TVA Division of Nuclear Power issues Procedure No. DPM N72A39, " Review, Reporting, and Feedback of Operating j
Experience Items," to implement Office of Nuclear Power j
Program to meet the specific requirements of NUREG-0737, I.C.5.
11/30/81:
TVA Office of Power Quality Assurance Audit No.
j CH-81-SP-04 addresses Feedback of Operating Experience to Plant Staff and identifies deviation 09/82:
NSSS 82A2 Section Instruction letter for Regulatory Engineering Support Section issued to address disposition of experience review material b
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0
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PAGE 5 0F 23 11/22/82:
TVA SQN Standard Practice SQA 26 issued to implement TVA program for' review of operating experience reports at'SQN 06/d4:
TVA commits to review all NRC Inspection Notices and Circulars issued between 1979-1983 05/85:
Nuclear Safety Staff Report 85-02 provides results of investigation of the nuclear experience review program at BFN
- 06/04/85:
Procedure DPM N72A39 revised to become procedure-0601.01 in order to reflect TVA reorganization.
11/01/85:
TVA receives concern WI-85-100-034 11/22/85:
Licensing Support Group (LSG) Instruction Letter, LSG
.85Al, issued to delineate the procedure to be followed
-in describing the elements of coordination of experience review material within the LSG.
b 11/27/85:
NRC receives employee letter regarding concerns about TVA's nuclear program 02/18/86:
NRC letter forwards copy of concerned Employee's letter to TVA for review and response 02/21/86 NRC investigative interview.with concerned individual
~03/10/86:
In its Corporate Nuclear Performance Plan (NPP) TVA
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commits to implement an operating experience review o
program 06/05/86:
Report 307.09, TVA WBN Employee Concerns Task Group Operations CEG on Subcategory: Nuclear Power / Site Programs / Procedure, Element: Experience Review Program 06/23/86 NRC forwards transcript of interview with concerned individual to TVA 1981-1985: QA audits of all TVA plants note deficiencies in TVA s
Operating Experience Review (0ER) Program 1981-1986:
INP0 evaluations note deficiencies in TVA OER program l
1984-1986: NRC inspections note deficiencies in TVA OER program
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l 12/86:
Program Management Procedure 0601.01, pre-release copy of Revision 0 procedure completely revised to establish new Nuclear Experience Review (NER) program as committed to in the NPP L
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TVA EMPLOYEE CONCERNS REPORT NUMBER: '203.3(B)
SPECIAL PROGRAM
-REVISION NUMBER: 0
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PAGE 6 0F 23 Discussion:
9.1 BACKGROUND
AND PROCEDURES:
All of the issues identified in this concern relate to the acquisition, distribution, and tracking of nuclear power industry experience. The typical sources of this information are identified in the concern and are:
(1) Institute of Nuclear Power Operations (INPO), (2) the Nuclear Regulatory Commission (NRC), and (3) other nuclear utilities. All of the issues can be grouped under the single heading of Operating Experience Review (0ER) and may be addressed together.
Note that at TVA this activity has generally been called the OER program.
However, it was sometimes referred to as the Nuclear Operating Experience Review Program (NOERP) 4 or the Nuclear Experience Review (NER) program. With the
. most recent revision of the controlling procedures TVA is now officially calling this the NER program. This report will adopt the term OER when discussing this program prior to the
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most recent changes and will use NER when referring to the
.new TVA program.
In October 1980, the NRC issued NUREG-0737, " Clarification of TMI Action Plan Requirements."
In Task Action Plan I.C.5, which only addresses feedback of operating experience to operators, the the NRC states the requirement that:
"Each applicant for an operating license shall prepare procedures to assure that operating information pertinent to plant safety originating both within and outside i
the utility organization is continually supplied to operators and other personnel and is incorporated into training and retraining programs."
TVA responded to this NRC requirement on 12/23/80 indicating
,j' that their program is adequate (App. A, 5.rr). On 07/28/81
]
TVA issued area procedure DPM N72A39 for the review, j
reporting, and feedback of operating experience items (App.
j A,5.ss).
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l' TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM i
REVISION NUMBER: 0 I
G PAGE 7 0F 23 '
At the Sequoyah site the procedure governing the OER program is Standard Practice SQA 26, " Review, Reporting, and Feedback of Operating Experience Items" (App. A, 5.cc). The date shown on this procedure for Revision 0 is 11/22/82 and the present version, Revision 7, is dated 11/20/85. Although SQA 26 is first dated 11/22/82 it must have been in use earlier because a QA audit performed in November 1981 identified deviations in both SQA 26 and DPM N72A39.
The essence of these deviations is that DPM N72A39 did not sufficiently address all the requirements of NUREG-0737. This procedure did not provide for TVA experience at one TVA plant to be reviewed for applicability at other TVA plants, nor did it assure that important information is handled with dispatch.
The Sequoyah procedure SQA 26 was also faulted because it merely duplicated N72A39 and did not contain any specific instructions for plant personnel. The present version (R7) of SQA 26 now includes a list of specific responsibilities for the Sequoyah Regulatory Engineering Section (RES).
In addition to review and dissemination of experience information, the RES is required to ensure that any action
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resulting from the review item is completed.
When a modification or other action results from the review of an experience review item the OER procedures require that the OER staff ensures that the appropriate organization is assigned responsibility. The OER staff then maintains a record of the item until the responsible organization reports it as closed. For the tracking of the actions necessary to implement a correction a computerized tracking system is used.
In September 1982, the Regulatory Engineering Support Section (RESS) of the Reactor Engineering Branch (REB) issued Section Instruction Letter (SIL) NSSS82A2 ( App. A, 5.h).
The scope of this SIL provided directions for the handling and reviewing of experience review material within RESS and expanded on the Division Procedure N72A39.
This SIL was the corporate equivalent of site procedure SQA 26 and was the
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governing document for the RESS during the period when the OER program was administered as a centralized program.
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F TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 8 0F 23 In. June 1985, each TVA site and division was given responsibility for its own OER. Area Procedure 0601.01,
" Review, Reporting,)and Feedback of Operating Experience Items" ( App. A, 5.u issued on 06/04/85, described the new responsibilities resulting from this reorganization and replaced the'former procedure DPM N72A39. This new procedure identifies the experience information sources which are to be reviewed and delineates the requirements and responsibilities in the divisions / branches for performing their reviews. This procedure requires the plant site to establish procedures to ensure that recommendations resulting from the reviews are
' addressed and that proper action is taken.
This reorganization introduced difficulties in the OER program. The mechanics of the OER program after January 1, j-1985 were changed to transfer the OER responsibilities to the
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plants. The RESS became only an OER items clearinghouse with no review or filtration function (App. A, 5.0).
The site RE section became the initial point of. review. Also, procedure 0601.01 specifies that the Nuclear Licensing Branch (NLB) will maintain a file for all 0ER material received prior to grz January 1,1985, and the sites shall maintain a file for OER material received after January 1, 1985. To further fragment the program, Office of Engineering (OE) discontinued routine coordination of the investigations of NRC Bulletins, Circulars, and ins for operating license (0L) plants.
The OE continued, however, to coordinate and initiate OE investigations into these items for construction permit (CP) plants (App.A,5.q).
The Licensing Support Group Instruction Letter (GIL) LSG 85A1 (App. A, 5.ee) was originally issued on November 22, 1985 and addresses t N disposition of experience review material.
This GIL expands the Office of Nuclear Power (ONP) procedure 0601.01 but is limited to the activities of the Licensing Support Group.
It reflects the decentralized operation of the OER program and specifies that the Regulatory Engineering Section at each site is responsible for the accuracy and completeness of experience review material.
It does, however, provide for distribution of internal review material and for a generic experience review in addition to the review of externally generated experience information, b
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)'
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 9 0F 23 Documentation was examined (e.g., App. A, 5.ccc) to determine extent of TVA involvement with others in the-industry. There was ample evidence of TVA participation in professional societies (e.g., ASME, IEEE) and Owners Group activities for SQN.
Participation was at chairperson and other committee levels. TVA has participated in NSSS Owners Group Activities since the mid-1970s, becoming more active following issuance of NUREG 0737 in 1980.
Participation with other Utilities (e.g., Duke Power) and other industry groups (e.g., EPRI) was also noted. This involvement is presented in more detail in Sequoyah Element Report 201.1.
9.2 OTHER INVESTIGATIONS:
From 1981 into 1986 the TVA OER program has been evaluated numerous times by the NRC and INP0 and audited by TVA QA (see App. A, INPO, NRC, and QA references).
Each time the program was examined, findings or deviations were identified and improvements were recommended. Most of the findings were related to the dissemination of in-house experience information between the many TVA divisions and sites.
fr6 Additionally, the program was described as fragmented, and the procedures were criticized for not sufficiently delineating responsibility and directing performance. These evaluations also identified a lack of management support for the OER program and a lack of staffing to perform the necessary reviews in an efficient and timely manner.
A review of the transcript of the NRC interview with the concerned individual (CI) reveals only a minor clarification of the issues in that he felt the experience information was made available to only a limited number of individuals.
He felt that the engineers who were implementing the design were doing so with hearsay information rather than with their own personal direct knowledge of.the experience of other plants as identified by NRC or INP0.
The QA, NRC, and INP0 reviews that the evaluation team examined generally focused their comments and findings on the activities of licensing personnel and management. The only comments found relating to this specific point to which the CI referred were in an NRC internal memo in December 1985 (App. A, 5 99).
The NRC staff was concerned that operator training programs at SQN may not include appropriate " lessons learned." This point was resolved, however, when the NRC inspector sampled the processing of several operating experience reports and verified that the information was j
b provided to the operators ( App. A, 5.aaa). This point is now specifically addressed in SQA 26.
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SPECIAL PROGRAM REVISION NUMBER: 0 Qe PAGE 10 0F 23
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In 1984 TVA identified a design deficiency at Browns Ferry Nuclear Plant (BFN). Subsequent investigation by TVA revealed that this item had previously been identified in NRC Information Notice (IN) 79-32 but had not been adequately evaluated by TVA at the time because the NRC had not required a response to IN 79-32. As a result, TVA committed to the NRC to review all ins and circulars issued between 1979 and 1983 inclusive. The results of this review were summarized in February 1985 ( App. A, 5.r) and eight items were identified as being the responsibility of the Office of Engineering (0E).
The performance of the TVA OER Program was examined by the TVA Nuclear Safety Staff (NSS) in 1985 (Ap'p. A, 5.s) and by the Operations Category of the Employee Concerns Task Group in 1986 (App. A, 5.tt). The NSS review was mainly concerned wi t h f,omo specifics at Browns Ferry but identified several areas of weakness in the dissemination of TVA's own -
experience throughout TVA.
p In responding to'a deviation in QA Audit QBF-A-85-0016, the
%D Director of Nuclear Services stated his opinion that the root cause was that "TVA has at least seven different experience review programs. These seven programs are one for each site (four), the Nuclear Central Office (NCO), the Power Operations Training Center (P0TC), and the Office of Engineering (0E)."
In a January 1986 memo ( App. A, 5.jj),
when discussing the same deviation, the Manager of Licensing restated that the OER program is in need of total revamping.
He went on to say that until guidance is received from upper-level management, (e.g. the ONP policy, directive, and standard) the licensing group instruction letter LSG 85A1-will be used to administer the OER progrom.
Operations Category Report 307.09 contains a summary of the reviews and findings by INPO, NRC, and TVA QA.
The report summarizes the findings that the TVA OER program is not as effective as it should be, that it does not receive adequate management attention and concern, and the procedures do not j
support the requirements nor their intent.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(8)
SPECIAL PROGRAM REVISION NUMBER:
0 PAGE 11 0F 23 The report identifies the following specific deficiencies:
"o Failure to follow procedures as written.
"o Lack of upper-level control and responsiveness to written identification of problem areas and request for guidance.
"o Insufficient performance standards.
"o Written policies and actions contrary to procedures that contributed to fragmentation of responsibilities and authority and corporate distrust.
"o Lack of clearly defined procedures that outlines [ sic] what documents will be formally added to the OER data base and by whom.
"o Corporateperturbations(i.e.,
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decentralization) used as excuse for substandard performance for an excessive timeframe.
"o Repetitive disregard to suggestions for improvement."
l The evaluation team has examined the documents listed in Appendix A and concurs with the findings expressed in Operations Report 307.09.
9.3 NEW TVA PROGRAMS:
TVA management is aware of the continuing problems with the OER program (App. A, 5.hh, 5.kk).
Consequently, in the Corporate Nuclear Performance Plan (CNPP) (App. A, 5.uu, 5.vv) TVA described a Nuclear Experience Review (NER) program 3
where:
" Licensing personnel, under the direction of the Director of Nuclear Safety and Licensing, will be responsible for managing the TVA Nuclear Operating Experience Review program system for internally and externally 0618D (12/19/86)
d TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
T I
SPECIAL PROGRAM REVISION NUMBER: 0 G
PAGE 12 0F 23 identified problems or events. Under this system, significant problems or events identified at other nuclear plants by the C
NRC, INP0, NSSS vendors, and others, and significant problems (events) identified at TVA's nuclear plants will be made the subject of experience review reports."
l The Sequoyah site responsibilities for the NER program are 3
further described-in the Nuclear Performance Plan, Volume II, j
Sequoyah ( App. A, 5.ww) as follows:
2 f
"The Site Nuclear Operating Experience Review T
Program (N0ERP) has been established as part of the TVA Corporate Program managed by Nuclear Safety and Licensing. The site l
licensing organization will establish j
procedures to implement and interface with
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the corporate N0ERP to:
"o Receive information into the site N0ERP
- f k,.
and disseminate that information to the appropriate departments responsible for e
operations, training, engineering, and 1
other plant activities.
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"o Ensure that recommendations from external l
site organizations are factored into the
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appropriate department programs.
i "o
Ensure Inspection and Enforcement (IE)
Bulletins and Generic Letters are reviewed from both a regulatory and an d
experience review point because of their dual role.
"o Implement an in-house experience review
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t
. 3, program to communicate significant site j
operational events, maintenance and design problems to other TVA plants and W
the industry through corporate N0ERP."
b t
06180 (12/19/86) l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAME REVISION NUMBER: 0 PAGE 13 0F 23 In Revision 1 of the CNPP, this Program is listed as commitment item No. 21 with completion required before restart of the Sequoyah plant.
This commitment is also shown in the Corporate Commitment Tracking System (CCTS) as commitment No. NC0 860156109 ( App. A, 5.qq) and as a restart item.
In conjunction with this NER program, the CNPP also commits to establishing a corporate nuclear operation experience database that will provide a management tool and TVA-wide access to all experience review items. This commitment is listed as commitment item No. 22 but the due date is shown as a
long term.
The CCTS control number for this commitment is NC0 860156 063 (App. A, 5.pp).
To govern the functions of the Office of Nuclear Power (ONP),
a hierarchy of Nuclear Procedures System was issued on 07/10/86 (App. A, 5.zz).
This hierarchy shows five levels of documents which are required for any given program. For the NER program, only two of the required procedures have been issued. For the Sequoyah site, Standard Practice SQA 26 is e
available and the corporate licensing group has the GIL o
LSG 85A1 although both of these procedures will require revision to properly reflect the recentralization of the NER program. The required directives manual must be prepared, along with the necessary instruction manual for the site licensing section and the procedure manual for the corporate licensing division. The ONP policy has not been issued as of this date but exists in draft form (App. A, 5.bbb).
For the corporate star dards manual, Area Plan Procedure 0601.01 has been completely rewritten and is now known as the Program Management Procedure (PMP) 0601.01 ( App. A, 5.yy).
This procedure is part of the ONP interim procedures system and specifies that the Manager of Nuclear Safety has the overall responsibility for the performance of the NER program.
The sites and divisions are responsible for providing internal experience information to the central office and for implementing corrective actions as applicable. The general requirements of this procedure state that:
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i 06180(12/19/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:.203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 5'
PAGE 14 0F 23 "The experience review function is a process by which industry and internal experience is screened, an assessment performed, and lessons learned are factored into TVA's sites and divisions.... TVA is also responsible for ensuring that the nuclear industry is aware of items that could affect the safety of nuclear plants."
In addition to reviewing and disseminating nuclear experience materials, procedure PMP 0601.01 requires:
"The Manager,- NER, or designee shall ensure all significant plant events are reported on the i
Nuclear Network System. The Director of Nuclear Services or designee shall ensure that equipment failures are reported on the NPRDS [ Nuclear Plant Reliability Data System] system.
"The Manager, NER, shall develop an NER status report on a monthly basis which shall contain:
y o
A list of all open NER packages o
A list of NER items added or closed during the month o
An evaluation of the use of effectiveness of the NER program including an assessment of problem areas "The purpose of the status report is to inform TVA management of any areas of good or exceptional performance and areas requiring management attention within the ONP."
The Manager, NER, is also required to track corrective action resulting from an experience review item until implemented, and to update the Tracking and Reporting of Open Itcms (TROI) computer system and NER data base accordingly. NER action items shall not be closed until all corrective actions are completely implemented and documented.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 15 0F 23 Findings:
The evaluation team review of the operating experience review program at TVA shows that in 1981 TVA implemented an OER program as required by NUREG-0737. This program has, however, been inadequate as exemplified by the continual occurrence of deviations and findings when examined by NRC, INPO, and TVA QA. The program has been fragmented with no central coordination for the multitude.of individual and separate programs.
TVA has recognized these inadequacies and has so stated in the Nuclear Performance Plan. TVA is attempting to remedy this situation by implementing a centrally directed system for operating experience review and for internal and industry-wide dissemination of TVA experience. TVA has the core procedure (PMP 0601.01) of the new NER program prepared but has yet to issue it, the necessary upper-tier governing documents, and the lowest level implementing procedures. This commitment is presented in the NPP and is included in the CCTS data base as NCO 860156109.
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PAGE'16 0F 23
==
Conclusions:==
The issues expressed by this employee concern are valid in that the OER program as practiced by TVA has been inadequate in general.
The specific tracking of INP0 items has frequently been poor, and the feedback of TVA experience to the INP0 data systems has been all but neglected. Tracking of NRC information has, for the most part, not suffered as much, but the dissemination among the sites of TVA's own in-house experience has repeatedly been criticized.by reviewers.
The procedures for the OER program have been available since 1981 but have been both lacking in detail and not followed by personnel. The existence of the procedures demonstrates management's awareness of the need for an OER program, and the procedures essentially reflect the regulatory requirements.
However, there is a gap between the procedures and their implementation.
TVA management has recently placed more emphasis on the NER program and has committed in the CNPP to implement an effective program prior to the restart of the Sequoyah Plant. Although the complete
' s hierarchy of required procedures is not yet prepared, the core procedure (PMP 0601.01) has been prepared and is presently under review for the necessary approvals. When complete and adequate procedures are prepared and the program is properly and effectively implemented, the NER program should be sufficient to resolve these issues.
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SPECIAL PROGRAM REVISION NUMBER: 0 b
PAGE 17 0F 23 ADDENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a,
'INP0 Report of Sequoyah Nuclear Plant, 11/81 Evaluation b.
Foremost Safety and Reliability Issues, Identified through INP0 Plant Evaluation and the Significant Events Evaluation and Information Network Program (SEE IN), (12/81) c.
Recurring Findings and Recommendations and Good Practices, INPO, (01/82) d.
Letter from E. P. Wilkinson, INPO, to H. G. Parris, TVA, concerning recommendations and good practices identified during INP0's assistance visit to WBN during week of 01/18/82,(02/10/82) e.
TVA memo from H. J. Green to A. W. Crevasse, " Quality Program Audit Report No. OPQAA-CH-81SP-04 ( A24 820112 001),"
d (Ll6 820219 893), (02/25/82)
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v
[
^
f.
TVA Office of Power, Quality Program Audit Report from A. W.
y Crevasse to H. J. Green, et al, Audit No. CH-8200-10,
)'
" Operating Experience and Feedback Control," (A24 821006 i
005),(10/04/82) 9 TVA memo from H. J. Green to G. W. Killian, " Quality Program Audit Report No. CH-8200-10 (A24 821006 005)," (Ll6 821118 812), (11/19/82) 8 h.
TVA Division of Nuclear Power, Reactor Engineering Branch
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(REB), Section Instruction Letter, from J. Hutton to NSSS Engineering and Analysis Group, " Disposition of Experience I
Review Material - REB No. NSSS82A2," (11/03/83) 1.
INP0 Report of Sequoyah Nuclear Plant TVA, 02/84 Evaluation j.
TVA memo from J. P. Darling to R. W. Cantrell, " Institute of Nuclear Power Operations (INP0) - INP0 Publications," (L33 840413 802), (05/17/84) 6 Li k.
INP0 Report, " Recurring Recommendations and Good Practices from NTOL Assistance Visits," (05/84) 1.
INP0 Report, " Browns Ferry Nuclear Plant," (10/84) 3
)
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g TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(8)
SPECIAL PROGRAM REVISION NUMBER: 0
'h PAGE 18 0F 23 APPENDIX A (Cont'd) m.
TVA memo from G. W. Killian to H. L. Abercrombie, " Division of Quality Assurance Audit Report No. CH-8400 Operating Experience and Feedback," (Ll7 841016 804), (10/16/84) n.
TVA memo from D. E. McCloud to M. J. Burzynski, " Review of Significant Operating Experience Reports (SOER) for. Watts Bar Nuclear Plant (WBN)," (11/19/84)'
o.
TVA memo from J. P. Mulkey to J. E. Gibbs, " Operating Experience Review Trip Report," (T15 841213 848) (12/06/84)
_p.
Letter from D. M. Verelli, NRC, to H. G. Parris, TVA, " Report Nos. 50-390/84-82 and 50-391/84-56," (A02 841217 015),
(12/12/84) q.
TVA memo from J. A. Raulston to J. W. Hufham, " Handling of NRC Bulletins, Circulars, and Information Notices for Plants with an Operating License (0L)," (NEB 850220 251), 02/20/85) h r.
TVA memo from J. A. Raulston to Those Listed (R. O. Barnett, et al), "Bellefonte, Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants - Review of NRC-01E Circulars and Information Notices Issued between 1979 and 1983 (Inclusive)," (NEB 850228290),(02/28/85) s.
TVA Nuclear Safety Staff Report 85-02, " Deficiency in Implementation of the Nuclear Experience Review Program Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants,"
(L42 850517 801), (05/85) l t.
TVA memo from H. B. Rankin to J. P. Vineyard, "Sequoyah Nuclear Plant (SQN) - Handling of Operating Experience Review (0ER) Information for SQN," (06/04/85) u.
TVA Division of Nuclear Power, Procedure No. 0601.01 1
(formerly OPM No. N72A39), " Review, Reporting, and Feedback j
of Operating Experience Items," (06/04/85) k TVA memo from R. W. Cantrell to J. P. Darling, " Institute of v.
Nuclear Power Operations (INP0) - INP0 Publications," (B4585 0606 261), (06/06/85)
OE Draft input to WBN INP0 Evaluation, " Disposition of SOERs w.
within the Office of Engineering (OE)," (06/07/85), TTB #059
[
(06/24/86) 06180(12/19/86) i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 19 0F 23 APPENDIX A (Cont'd) x.
Letter from D. M. Verelli, NRC, to H. G. Parris, TVA, " Report Nos. 50-390/85-36 and 50-391/85-36" (A02 850621 006),
(06/19/85) y.
INP0 Report, " Evaluation of Sequoyah Nuclear Plant," Second Draft,(07/02/85) z.
I;4P0 Report, " Evaluation of Watts Bar Nuclear Plant," Second Draft,(09/03/85) aa.
TVA memo from J. Hutton to F. A. Szczepanski, " Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants - Nuclear Experience Review Program," (L44 850919 812), (09/23/85) bb.
TVA memo from G. W. Killian to H. L. Abercrombie,
" Transmittal of QAB Audit Report No. QSQ-A-85-0012," (Ll7 851101 801), (11/01/85) cc.
SQN Standard Practice, SQA 26, " Review, Reporting, and
(;
Feedback of Operating Experience Items," R7, (11/20/85) dd.
TVA memo from J. Hutton to G. W. Killian, " Response to QAB Audit Report No. QBF-A-85-0016," (L44 851120 802), (11/20/85) ee.
TVA ONP Nuclear Licensing Branch, Group Instruction Letter, from D. E. McCloud to Licensing Support Group, " Disposition of Experience Review Material - LSG No. 85Al, Revision 3,"
(08/04/86) ff.
Letter B. J. Youngblood, NRC, to S. A. White, TVA, "TVA Employee Concern Program," (L44 860224 774), (02/13/86) flemorandum from G. M. Holahan, NRC, to B. J. Youngblood, NRC, l
gg.
" Staff Review of TVA's Response to 50.54 (f) Letter,"
(12/30/85) f hh.
TVA memo from A. R. Meller to Files, " Nuclear Safety Monthly l
Top Management (NSMTM) Meeting Held January 3,1986,"
l (L42 860228 804), (01/03/86) ii.
TVA memo from G. W. Killian to R. L. Gridley, " Evaluation of Corrective Action Response - Audit Report No. QBF-A-85-0016 -
Deviations D02 and 003," (Ll7 860128 801), (01/28/86) b.
06180(12/19/86)
TVA EMPLOYEE' CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 h
PAGE 20 0F 23 APPENDIX A (Cont'd) jj.
TVA memo from R. L. Gridley to G. W. killian, " Response to QAB Audit Report No. QBF-A-85-0016," (L44 860129 810),
(01/29/86) kk.
TVA memo from A. R. Meller to Files, " Nuclear Safety Monthly Top Management (NSMTM) Meeting Held January 24, 1986," (L42 860228 803), (01/30/86) 11.
Letter from D. R. Hicks to NRC, Committee on Energy and Commerce, Committee on Interior and Insular Affairs.
" Concerns Regarding the TVA Nuclear Program," (11/27/85) mm.
TVA memo from R. L. Gridley to R. B. Kelley, " Actions to Close Outstanding QA Audit Deviations - Nuclear Licensing Branch (NLB)," (L44 860221805), (02/21/86) nn.
Letter from NRC to S. A. White, TVA,
Subject:
Transcript of Interview of Dallas R. Hicks," (06/23/86) oo.
NRC NUREG-0737, " Clarification of TMI Action Plan Requirements, Item I.C.5," (11/80) pp.
Corporate Commitment Tracking System Commitment Update Report, Operating Experience Review, Control Number:
NC0-86-0156-063 qq.
Corporate Commitment Tracking System Commitment Update Report, Operating Experience Review Program, Control Number:
NC0-86-0156-109 rr.
Letter from L. M. Mills, TVA, to H. R. Denton, NRC, " Response to D.G. Eisenhut's Letter dated October 31, 1980, Post TMI Requirements, Browns Ferry Nuclear Plant, Docket Nos. 50-259, 50-260, 50-296," (A27 801223019), (12/23/80) ss.
DPM N72A39, " Review, Reporting, and Feedback of Operating Experience Items," (04/05/83) tt.
TVA WBN ECTG Operations CEG, Subcategory: Nuclear Power / Site Program / Procedure, Element Review Program Report No. 307.09, (06/05/86)
Corporate Nuclear Performance Plan, Volume I, R0, (03/86) uu.
b i
0618D(12/19/86) s
-__.v-
-4.._
,,e-,
,_.~,yyy-e. -,
E TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 (Gf PAGE 21 0F 23 APPENDIX A (Cont'd) vv.-
Corporate Nuclear Performance Plan, Volume I, R1, (07/22/86) ww.
Sequoyah Nuclear Performance Plan, Volume II, R1, Final Concurrence Transmitted July 14,1986, (L44 860714 800) xx.
Tennessee Valley Authority, Nuclear Quality Assurance Manual, (NQAM),(11/14/85) yy.
PMP 0601.01, " Nuclear Experience Review," prerelease copy, (undated) zz.
TVA memo from S. A. White to Those Listed, (LO2860709839),
" Policy Establishing the Nuclear Procedures System,"
-(07/10/86) aaa. TVA Memo from J. Hutton to F. A. Szczepanski, " Browns Ferry, Sequoyah, and Water Bar Nuclear Plants, Nuclear Experience Review Program," (L44 860919812), (09/28/85) b bbb. Office of Nuclear Power Policy 6.1, " Nuclear Safety," draf t (12/06/86) ccc. TVA memo from S. A. Shipman to Those Listed, (R. O. Barnett, et al), " Professional Society Committees and Industry Activities,"(B02860903001),(08/25/86) 6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
a.
NUREG-0737, " Clarification of TMI Action Plan Requirements,"
Task Action Plan I.C.5," Procedures for Feedback of Operating Experience to Plant Staff" b.
TVA Nuclear Performance Plan, Volume I, Corporate R0, R1, R2 c.
TVA Nuclear Performance Plan, Volume II, Sequoyah d.
Commitments NC0 860156 063 and NCO 860156109 on the Corporate Commitment Tracking System to implement an operating experience review program and an experience database e.
Standard Practice SQA 26, " Review Reporting, and Feedback of Operating Experience Items" b
06180(12/19/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 22 0F 23 APPENDIX A (Cont'd) f.
Section Instruction Letter NSSS82A2, " Disposition of Experience Review Material" g.
Area Procedure 0601.01, " Review, Reporting, and Feedback of Operating Experience Items" h.
Program Management Procedure PMP0601.01, " Nuclear Experience Review" i.
Group Instruction Letter LSG 85Al " Disposition of Experience Review Material" 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT:
Telecon from W. E. Purcell, Bechtel, to D. T. Clift, TVA, (IOM-449)
(12/02/86) b Telecon from D. Zwicky, E. Purcell, Bechtel, with D. T. Clif t and W. Ludwig, TVA, (IOM-450) (12/09/86)
RFISQN-754(12/12/86) 06180 (12/19/86)
TVA EMPLOYEE CONCERNS REPORT NtMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 b
PAGE 23 0F 23 CATD LIST The following CATO forms are included as part of this report:
203.03 SQN 01 203.03 SQN 02 203.03 SQN 03 203.03 SQN 04 t
i 9
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ECTG C.3 Attachment A
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CATD No. c705 3 JQ Al-0 3 a.
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VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE IITLE DATE
ECTG C.3 Attactunent A Pass 1 of 1 Ravision 2 - A ECSP CORRECTIVE Action Tracting Docume Q (CATD)
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1 SIGNATURE TITLE DATE l
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