ML20213A451
| ML20213A451 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/23/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20213A334 | List: |
| References | |
| 201.5(B), 201.5(B)-R01, 201.5(B)-R1, NUDOCS 8702030284 | |
| Download: ML20213A451 (28) | |
Text
.;
TVA EMPLOYEE CONCERNS REPORT NUMBER:
201.5(B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NtNBER: 1 TITLE:
INCORPORATION of REQUIREMENTS AND COMITMENTS IN DESIGN Tracking of Cossnitments and Design Changes PAGE 1 0F 27 Dissemination System REASON FOR REVISION:
1.
Revised to incorporate conunents by TAS and SRP; and to add Section 10, Corrective Action.
PREPARATION PREPARED BY:
/l/V $7 7 SIGNATURE
/
A) ATE
~"
REVIEWS
.-+ctn:
REVIEW COM ITTE -
'/Y/ W.
W
'l
~~ SIGNATURE DATE l
A tan f
7 1/A1?
/'
S::GNATURE DATE CONCURRENCE 5 fY lSfSl
/
/- /6-fr7 CEG-H:
A SRP: Q
- k. W /-23-87 l
SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
M0/SKl ns-r1
~in ECSP WARAGER DATEI MANAGER' 0F NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files.
l ER" R88 M E8a8827 P
TVA EMPLOYEE CONCERNS REPORT NL9tBER: 201.5(B)
SPECIAL PROGRAM REVISION Nl#EER: 1 PAGE 2 0F 27 1.
CHARACTERIZATION OF ISSUE (S):
Concerns:
Issues:
WI-85-100-041 a.
There is a lack of adequate tracking
" Lack of adequate tracking for for EN DES, (TVA), commitments.
ENDES comitments and design changes.
CI has no further b.
There is a lack of adequate tracking infomation. Anonymous concern for EN DES, (TVA), design changes.
via letter."
Note:
Issue b is addressed in T.Tsiiient Report 204.6.
c.
TVA adds diesel generators without updating licensing documents.
WI-85-100-002 Note: Other references to diesel I-85-132-SQN-01 gerierators (e.g., margins) are XX-85-122-006, 007 discussed in Element Report 243.0 "Sequoyah: Diesel generator margins are inadequate. TVA d.
TVA does not keep licensing has added DGs to Browns Ferry, documents (i.e., FSAR) current.
Sequoyah and Watts Bar.
Each time a question is raised, TVA must conduct another study.
TVA adds diesel generators without upgrading licensing documents.
CI has no further information. Anonymous concern via letter."
- 2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by NRC, TVA/WBN Date 1980-1984, 1985, 1986 l
Documentation Identifiers:
Nonconfomance Report (NCR) WBN NEB 8419, (12/84)
NRC Inspection Reports SD-390/84-35, 84-77, and 85-38 NRC Investigation Report 2-84-010, and violation 50-390/85-38-01 NSRS Investigation Report I-85-132-SQN for Employee Concern XX-85-122-006, (03/03/86) 0070D - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.5(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 27 Report 307.10, Subcategory: Nuclear Power / Site Program /Prccedure Element: Corporate / Site Support Functions Category: Operations, ECTG, CEG, (05/02/86)
Report No. 710, " Productivity as Related to Management and Personnel" TVA Employee Concerns Special Program 08/29/86 NRC Inspection of SQN Closecut and FSAR Updates ( App. A, 5.fff)
Corrective Action Report SQ-CAR-86-04-021 3.
DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STAlto IN ELD 4ENT:
Element pertains to commitments in general.
Addition of diesel generator refers to the fifth DG 4.
INTERVIEW FILES REVIEWED:
The expurgated files were reviewed for the following concerns and no additional information was obtained:
EC WI-85-100-041 EC XX-85-122-006 ED XX-85-122-007 EC WI-85-100-002 I-85-132-SQN-01 l
5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
1 See Appendix A.
l 6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
7.
LIST RE00ESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
0070D - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 4 0F 27 8.
EVALUATION PROCESS:
a.
Examined Corporate Comitment Tracking System (CCTS).
b.
Examined Tracking and Reporting of Open Items System (TROI) for this purpose.
c.
Examined other tracking systems (CATS).
d.
Reviewed other investigations of this issue (e.g., NRC, QA) e.
Reviewed available transcripts of NRC investigative interviews f.
Examined relationship between dates of FSAR update and initiation of addition of fifth diesel generator (If 5th DG has been included in FSAR).
g.
Detennined means and date of TVA's notification to NRC of the addition of the fifth diesel generator.
h.
Coordinated response with Electrical Group, particularly Element Report 243.0(B).
i.
Determined if TVA is annually updating FSAR as required; examine TVA procedure (s) for updating FSAR.
9.
DISCUSSION, FINDINGS, AND CONCLUSIONS Chronology:
Late 1981:
Comitment Action Tracking System (CATS) system initiated at SON l
12/82:
SQN 135 and CS-SIL-5 issued to govern comitment j
tracking activities 1984:
NRC identifies comitments improperly tracked at Watts Bar 12/84:
TVA submits Non-Conformance Report (NCR) WBNNEB8419 to NRC dealing with improperly tracked comitments at WBN l
00700 - 01 /14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NLSEER: 1 PAGE 5 0F 27 09/85:
H. G. Parris issues policy statement that CCTS is to be used TVA-wide for NRC comitment tracking 11/14/85:
Employee concerns WI-85-100-002, WI-85-100-041, XX-85-122-006, and XX-85-122-007 received by TVA 02/24/86:
Procedure SQA 135 revised to incorporate use of CCTS per H. G. Parris policy 03/03/86:
NSRS Investigation Report NSRS I-85-132-SQN issued for employee concern XX-85-122-006 regarding addition of fifth diesel generator 05/02/86:
ECTG Operations Category issues Report 307.10 which addresses comitment tracking 06/20/86:
ECTG Management and Personnel Category issues draft report for Element 12 which addresses the comitment tracking system 09/22/86:
Concern I-85-132-SQN-01 received by TVA Discussion:
a.
Source of Issue The employee concern expressing inadequate tracking of comitments was originally for WBN but has been included for SQN because of the possibility of generic application.
During an NRC human factors audit of the Watts Bar control room in October 1980, numerous items were identified that required correction by TVA.
These items, along with the corrective action, were subsequently incorporated into the WBN SER as Appendix D.
Over a period of about 6 months in 1984, the resident NRC inspector reviewed these Appendix D items to ensure closure.
In several instances, TVA had reported items as closed that the inspector found to be incomplete. Subsequent reviews by TVA also revealed similar items. These items were originally reported under 10CFR50.55(e) to the NRC-01E Inspector on December 14, 1984, as NCR WBNNEB 8419.
No similar situations have occurred at Sequoyah.
00700 - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NIMBER: 201.5(B)
SPECIAL PROGRAM REVISION NL4eER: 1 PAGE 6 0F 27 b.
Definition of Comitments:
In the process of licensing and operating a nuclear power plant, numerous comitments are made to various organizations or agencies.
TVA presently has two separate sets of data that are referred to as comitments.
The first of these is the commitment / requirement (C/R) data base which has been prepared specifically as part of the Sequoyah restart effort and is made up principally of items in the FSAR and SER.
These C/Rs will be handled as part of the Design Baseline and Verification Program (DBVP) and will be discussed in other element reports.
The second set of comitments is defined in the policy memos by H. G. Parris ( App. A, 5.aa) and by W. T. Cottle ( App. A, 5.z) as "a written and docketed statement of TVA actions taken or to be taken by some future date (milestone or calendar date)." These comitments have been specifically identified for inclusion in the Corporate Comitment Tracking System (CCTS) and are to be tracked as unique requirements.
Typically, these comitments are made in specific written responses by TVA to NRC Office of Investigation and Enforcement (0IE) violations or Bulletins, NRC Generic Letters, meetings with the NRC, etc., although there are other sources.
A review of the transcript of the NRC interview of the concerned individual (CI) reveals that although the CI was referring to any and all comitments, he specifically emphasized comitments to the NRC such as in the FSAR, the Environmental Report (ER), or in response to questions.
l Because the DBVP and other element reports are addressing the comitments in the FSAR, etc., this review will address the specific type of comitments defined by H. G. Parris and W. T. Cottle.
l c.
Evaluation Team Investigation Within TVA in the past there have been several systems l
utilized by the various organizations for tracking of the many and varied types of comitments to internal organizations as well as to the NRC and other external organizations. These systems included the Comitment Control System (CCS) which was used by the Quality Engineering Branch for the Office of Nuclear Power; the Verification and Improvement Administrative System (VIAS) which was used by the former Office of Quality Assurance to track items related 00700 - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NIMBER: 1 PAGE 7 0F 27 to QA audits and deviations, etc.; and the Tracking and Reporting of Open Items (TROI) system which was a generalized tracking system used by the former Office of Engineering Design and Construction (0EDC) to track and monitor a variety of comitments that may be made in response to NRC, INPO, QA, or other sources.
General engineering design changes that occurred throughout the nonnal design process were not included in TROI but were scheduled and monitored as routine engineering work.
The CCS and the VIAS were essentially limited to QA/QE related items instead of commitments to the NRC and will not be investigated further here.
The TROI system included NRC commitments among the many items it was used to follow.
I However, it was not intended to replace existing organizations specific systems which were used to track and close individual items (App. A, 5.s, 5.ccc).
The specific practice at Sequoyah for tracking commitments was initiated sometime late in 1981.
At the request of the then Site Director, C. C. Mason, the Sequoyah Compliance Section set up the Commitment Action Tracking System (CATS).
The implementation of this system was completed in the latter part of 1982 and is used for tracking commitments resulting from Licensee Event Reports (LERs), responses to the NRC inspection reports, NSRS and QA audits, and Institute of l
Nuclear Power Operations (INP0) reviews.
The procedures for l
maintaining this system are covered in Compliance Staff Instruction Letter CS-SIL-5, "Comitment and Corrective Action Tracking" (App. A, 5.b) and Standard Practice SOA135, "Comitment Tracking" ( App. A, 5.c).
These procedur; were initially placed in service on July 8,1982, and December 3, 1982, respectively.
Since the implementation of CATS, the SQN compliance section has distributed reports of all open commitments to each of the responsible section supervisors, the group managers, and the plant superintendent approximately every 2 weeks.
Using the reports, these personnel met regularly and the comitments were followed to completion.
In addition to these reports, the compliance section supervisor presented a summary of late commitments at weekly management staff meetings.
These reports were not, however, transmitted to corporate headquarters in Chattanooga.
l l
00700 - 01/14/87
~
TVA EMPLOYEE CONCERNS REPORT NLSEER: 201.5(B)
SPECIAL PROGRAM REVISION NLSEER: 1 PAGE 8 0F 27 During an interview with the evaluator ( App. A, 7.a), the supervisor of the compliance section stated that any comitment made for SQN and approved / transmitted by the plant manager's office was passed through the compliance section and was placed in CATS.
He could not make such a statement for commitments that did not go through the plant manager's office, such as any made by OE (DNE).
However, he was not aware of any such comitments that were not on CATS.
Beginning in September 1985, all TVA organizations were directed (App. A, 5.aa) to use the CCTS as the official system for tracking comitments made to the NRC. Following this directive, all open comitments on CATS were placed on CCTS, and Sequoyah Standard Practice SQN 135 was revised to require the use of the CCTS as the official NRC comitment tracking system for SQN.
The TVA hierarchy for the Nuclear Procedures System ( App. A, 5.uu) identifies five levels of documents to control the functions of the Office of Nuclear Power (ONP).
Only three of the five required procedures for the Corporate Comitment Tracking System (CCTS) have been prepared.
Neither the ONP Directive nor the ONP Standard has been issued for the CCTS.
Preparation of the ONP standard is in progress, and a draft is presently under TVA review. Because this draft is still subject to revision, a copy was not made available to the evaluation team for review ( App. A, 7 q).
The policy for use of CCTS was originally issued by H. G.
Parris on September 26,1985 ( App. A, 5.aa).
This policy was clarified and a few specific actions were identified by W. T.
Cottle on October 2,1985 ( App. A, 5.z).
Lacking the directive and the standard, the corporate office l
and the sites are operating CCTS based solely on the TVA policy statement and their own site procedures and instructions.
The corporate licensing section is also providing periodic reports to t:1e Manager of Nuclear Power showing the status of open comitments and some trending information ( App. A, 7.t).
The SQN procedure SQA 135 ( App. A, 5.c) incorporates the definition of the Parris and Cottle policy statements and specifies responsibilities and procedures for comitment tracking. Beginning with Revision 3 in December 1985, the SQN compliance staff was directed to use the corporate mainframe tracking system CCTS.
00700 - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NUMBER:
201.5(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 9 0F 27 This procedure calls for cormitment due dates to be presented and for late items to be identified.
It also states that only the Site Director can establish or modify the content or the due date of a connitment, and that he is to be notified immediately if either cannot be met.
The lowest level document controlling commitment tracking is the SQN Compliance Staff Instruction Letter CS-SIL-5
" Commitment and Corrective Action Tracking" ( App. A, 5.b).
This instruction does not specifically mention CCTS, although it does refer to the Nuclear Corporate Office commitment tracking system for NRC commitments.
This instruction requires the applicable supervisor and plant management to be furnished a listing of commitments every 2 weeks, or more often if requested.
The specific tool for tracking is not stated although CATS appears to be specified based on the reference to a CAT form (commitment or Corrective Action Tracking Report) and a plant tracking system. When the SQN site compliance staff was reorganized into two groups in June 1986 this SIL ceased to be appropriate and is no longer in use. A new procedure to take its place will be required when TVA implements the five levels of procedures that are required to govern the CCTS and the tracking of commitments.
However, this instruction is not required prior to Sequoyah restart.
The procedures described above control TVA corporate and site operations groups' activities for commitment tracking.
For controlling engineering activities, the Nuclear Engineering Procedures (NEPs) are the governing documents. NEP-2.1 ( App.
A, 5.e), " Licensing Support," specifically addresses me commitment tracking.
This procedure is dated July 1,1986, but it appears to have been prepared without awareness of the corporate commitment tracking policy and CCTS. Specifically, this procedure fails to point out that only the Director of Nuclear Safety and Licensing can make a commitment to the NRC.
It also provides an exception that DNE is not required to track a commitment if the commitment is being followed by an equivalent tracking system in another TVA organization.
With the implementation of CCTS there is no " equivalent tracking system." Furthermore, NEP-2.1 specifies the TROI l
system to be used for tracking commitments to closure instead of CCTS.
I l
1 00700 - 01 /14/87 l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.5(B)
SPECIAL PROGRAM REVISION NIMBER: 1 PAGE 10 0F 27 Procedure NEP-2.1 lacks definitions for " closure,"
" completion," and the " responsible organization." Also, this procedure does not direct that existing ECNs, or other changes in progress be checked when identifying a comitment and its related activities.
Note that after reviewing the preliminary version of this report the TVA Engineering Assurance Organization has revised NEP 2.1 to correct the concerns expressed above (App. A, 5.eee, 5.111).
d.
Other Investigations Comitment tracking at SON can be sumarized by examining the results of reviews performed by other organizations, both within and without TVA.
In particular, the NRC Systematic Assessment of Licensee Performance (SALP) Board reviews, the NRC site inspector's reports, and the TVA QA organization reports contain information concerning the comitment tracking practices at SQN back to 1980.
Some of the documents reviewed did not examine the tracking of comitments specifically.
However, because comitment tracking is often involved in other activities, coments concerning other activities that may include comitments and their tracking are also discussed here for completeness.
The NRC SALP Board has performed five evaluations of the performance of the Sequoyah plant.
The first SALP report
( August 1982, App. A, 5.m) reviewed did not specifically address the tracking of comitments.
The SALP Board identified apparent weaknesses such as failure to comply with regulatory requirements for auditing, and failure to take corrective actions in response to audit findings.
In the next SALP Board evaluation ( April 1983, App. A, 5.1),
the Board commented that the licensee met the time requirements in responding to violations and was quick to i
take corrective action whe violations were identified by NRC.
The SALP Board report for the period from January 1,1983 through February 29,1984 ( App. A, 5.k) did not present any l
coments or assessments that could be related to comitment l
tracking activity.
i 00700 - 01/14/87 l
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 110F 27 The final SALP Board report (September 1985, App. A, 5.j) assessed the TVA headquarters functions. The SALP Board comented:
"... the Board believes that licensee headquarters lacked an integrated tracking system for insuring that NRC comitments are met.
This finding is based on the existence of separate tracking systems for the various licensee headquarters offices (Construction, Engineering and Nuclear Power)."
In the specific assessment of SQN licensing activities, the report comented, "Overall, the licensee has made good efforts to meet established comitments."
NRC inspection report No. 50-327,328/85-46 (January 1986, App. A, 5.dd) specifically reviewed the comitment tracking system.
The following coments are excerpted from that report:
o "The CCTS was not fully implemented at the time of the review."
o "CCTS is not sufficiently detailed to identify multiple facets within the same comitment."
o "Neither CATS nor CCTS addresses written comitments that I
are completed based on exit interview infomation and prior to the date of issuance of an NRC violation response.
This means a record of the comitment and its completion is not preserved."
o "The licensee comitted in SQN NPP, Volume 2, to review i
past NRC comitments back to January 1,1981, in the areas of past violation responses, IE Bulletin responses, licensee event reports, and NUREG-0737 items.
These items will be reviewed by TVA prior to unit startup."
l l
The NRC coments generally identified that a new comitment tracking system was under development but did not indicate that there was a problem with the actual tracking of l
comitments at SQN.
0070D - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NISSER: 201.5(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 12 0F 27 In NRC inspection report 50-327,328/86-06 ( App. A, 5.ee) the inspector noted that TVA was reviewing all open and closed NRC comitments as discussed in the SQN-NPP. Followup on comitment dates in responses and review of licensee's comitment tracking review were identified as Inspector Followup Item 327,328/86-06-01.
In the most recent NRC inspection report 50-327,328/86-31 (August 1986, App. A, 5.y), the CCTS was reviewed for its viability, extent, and implementation.
The inspector verified that CCTS was implemented and that data entry into CCTS appeared to be adequate.
The inspector also noted that the data entered into the CCTS are independently verified for each NRC comitment.
The inspector stated that QA involvement in comitment tracking appears to meet the minimum requirements and appears to be adequate, but QA_ involvement could be strengthened to include routine audits of the CCTS.
Regarding comitments that were closed prior to the issuance of the NRC inspection report which were not on CCTS (as noted in an earlier NRC inspection report) the inspector noted that the CCTS can now load "open, closed, and hold" issues.
The present CCTS thus maintains the status of both open and closed comitments.
Finally, the inspector again noted that TVA had comitted in the SQN-NPP to review past violation responses, IE Bulletin responses, Licensee Event Reports, and NUREG-0737 items back to January 1,1981.
This action was still in progress; however, it appeared to be proceeding at an acceptable rate and has been identified as an item that must be completed prior to unit startup.
The TVA Operations Quality Assurance Branch (00AB) has reviewed comitment tracking procedures on several occasions.
In 00AB report 50-8400-02 ( App. A, 5.m) the QA reviewer noted that CATS was being adequately utilized for proper tracking of open items and corrective actions.
QA audit report QSQ-A-85-0009 ( App. A, 5.00) specifically discusses CATS.
The report noted that the CATS program requires that comitment status reports be sent to the 00700 - 01 /14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NLSEER: 1 PAGE 13 0F 27 applicable plant sections and managers.
The procedure also requires late items to be identified as such; the actual reports do this and indicate the number of days late as well.
l Repeet QSQ-A-85-0009 also pointed out that CATS was not accunitely tracking comitments made in response to DQA audit deviations.
The compliance supervisor agreed with the QA reviewer and agreed to include these commitments in CATS.
In the QA review, a sample of two NRC comitments was selected for verification of status. One of these comitments was still open, but both were found to be accurately tracked on CATS.
QA audit report QSQ-A-86-0002 (February 1986, App. A, 5.11) noted that NRC comitments are tracked on the new CCTS while all other comitments are still handled by CATS. This is in accordance with the new TVA commitment tracking policy.
CCTS was specifically reviewed in the most recent QA audit performed for all sites as well as for the Knoxville and Chattanooga offices. This review was reported in QA Report QSS-A-86-0016 ( App. A, 5.g9) on July 25, 1986.
At each site, the audit team reviewed 50 to 60 examples of TVA comitments that had been transmitted to the NRC for various reasons.
All comitments that originated at the sites were found listed in the CCTS data base.
However, one comitment contained in a letter to the NRC from Chairman Dean was not entered.
The QA reviewer attributed this omission to the lack of a higher-tier QA procedure in ONP for controlling the CCTS program.
Another comitment not on the CCTS was found in a letter from S. A. White to the NRC.
This comitment was not on the CCTS because of the TVA practice of not considering items as comitments when the corrective action is already complete at the time of the TVA response to the NRC.
Consequently, the audit report identified one deviation from requirements caused by the lack of an upper tier QA procedure to control the CCTS program, and one due to failure to enter into the CCTS those comitments to NRC violations which were completed prior to issuance of the TVA response as required I
by the TVA policy statements presented in the memos from H.
l G. Parris ( App. A, 5.aa) and W. T. Cottle ( App. A, 5.z).
00700 - 01 /14/87
TVA EMPLOYEE CONCERNS REPORT NUISER: 201.5(B)
SPECIAL PROGRAM REVISION NtMBER: 1 PAGE 14 0F 27 The audit team found no instances at SQN where committed corrective actions were designated as complete but in fact were not.
The team also verified that most of the audited organizations periodically (1 to 2 weeks) distribute computer printouts of all NRC open/TVA incomplete commitments.
Trending, as far as late TVA commitment items to the NRC are concerned, is accomplished through periodic reports to the Manager of the Office of Nuclear Power ( App. A, 5 99, 7.t).
However, due to the lack of a corporate standard f or CCTS j
this activity is not procedurally controlled.
e.
Discussion of Additional Diesel Generator Issue:
The employee concerns about addition of the fifth diesel generator are discussed in Element 243.0.
Issue "e" concerning the updating of licensing documents is valid in that a fifth diesel generator is being installed at SQN and its existence is not reflected in the FSAR.
- However,
\\
regulation 10 CFR 50.71(e) ( App. A, 6.b) only requires that the Updated Final Safety Analysis Report (UFSAR) be revised to include changes made in the plant.
Tne incorporation of the fifth DG has not been completed ( App. A, 7.k); thus, no revision of the UFSAR is required.
Notification of the NRC, however, appears to be slow in that components and accessories for the fifth DG were delivered to SQN as early as April 1,1981 ( App. A, 5.f).
The NRC was first infomed of the fifth DG in the annual report for 1983
( App. A, 5.v). This infomation only incidentally referred to the fifth DG in Engineering Change Notices (ECNs) for conduit and cabling, etc., to connect to the fifth DG building.
Further details and a more specific notification were provided in the request for a technical specification revision ta incorporate the fifth DG on February 1,1985
( App. A, 5.w).
However, this request for a revision very clearly indicated that the change was to become effective upon completion of the modification and associated post-modification testing.
It is for this same reason --
that the work is not complete -- that the FSAR has not been updated.
It is the Site Director's policy not to incorporate changes into the FSAR until the actual installation and all associated work and verification are complete ( App. A, 5.u).
TVA personnel have advised that there will be no attempt to license the fifth DG prior to restart of unit 2 ( App. A, 7.v).
00700 - 01/14/87
I TVA EMPLOYEE CONCERNS REPORT Nt#SER: 201.5(B)
SPECIAL PROGRAM REVISION NLSBER: 1 PAGE 15 0F 27 This policy conforms with 10 CFR 50.71(e) which requires an annual update of the FSAR to be submitted which "... shall bring the FSAR up to date as of a maximum of 6 months prior to the date of filing the revision." This regulation requires that the FSAR be updated to include the effects of all changes made in the facility, and that the FSAR be updated 2 years after the operating license is granted and every year thereafter.
This has been done for SQN unit 2
( App. A, 5.ww, 5.xx, 5.yy, 5.zz).
In addition to the fifth diesel generator, a more general issue is raised about TVA's updating'its licensing
^
documents.
In this review the evaluation team did not attempt to detennine if all the modifications made at the SQN site have been accurately represented in the FSAR.
- Instead, it was observed that the potential for this problem has already been recognized within TVA as evidenced by R. L.
I Gridley's memo of February 18,1986 ( App. A, 5.u).
In preparing for the 1986 update of the FSAR, Gridley pointed out that all modifications made before 1984 may not be accurately reflected in the FSAR, and that a program to evaluate ECNs and their inclusion in the FSAR should be initiated.
As part of the DBVP, design requirements and commitments will be identified and included in the necessary design criteria documents. Where discrepancies exist between the commitment and the implementation it may be appropriate to change the commitment. Specifically, Attachment 2 to SQEP-18 ( App. A, 5.vv) directs that identified changes shall be tracked until they are incorporated ink the licensing document.
Procedure SQEP-18 specifies that this shall be accomplished in accordance with OEP-14, although NEP-2.1 will now be used because it is the superseding procedure.
Procedure NEP-2.1 l
controls how changes in the plant are to be coordinated with NSL for possible incorporation into the FSAR. Besides covering FSAR changes resulting from design changes, NEP-2.1 also directs the lead nuclear engineer to determine annually the need for UFSAR revisions to reflect installed plant modifications.
Findings:
l a.
A computerized comitment tracking system (CATS), was implemented at the Sequoyah site in 1982. Since that time commitments have been tracked on this system in accordance with the directions in Procedures SQA-135 and CS-SIL-5.
In 1986, the site-developed CATS was replaced by the corporate 00700 - 01 /14/87 j
l
1 TVA EMPLOYEE CONCERNS REPORT NlmBER: 201.5(B)
SPECIAL PROGRAM REVISION NLM ER: 1 PAGE 16 0F 27 mainframe system (CCTS) for tracking NRC comitments.
Procedure SQA-135 was revised to reflect this change.
Although the latest revision of CS-SIL-5 in hovember 1985 does not specifically name the CCTS, this instruction ceased to be appropriate when the site compliance section was reorganized in June 1986.
Consequently, this instruction is no longer used.
The corporate standard for controlling the use of the CCTS has not yet been issued. Meanwhile, personnel at the Sequoyah site are utilizing SQA-135, the H. G. Parris policy l
directive, and their own knowledge and expertise to maintain the tracking status of NRC comitments.
TVA has comitted to the NRC to completely implement the CCTS, including the necessary procedures, prior to restart of the Sequoyah Plant.
However, the complete set of five procedures has been comitted to be completed in the long term, and all five are not required before restart, b.
Issue "b" is addressed in Element Report 204.6(B).
c.
A fifth diesel generator has been added at SQN, but updating of the licensing document (FSAR) is not yet required because the incorporation of the DG is not yet complete.
d.
The wider question of updating licensing documents in general is currently being addressed (see Gridley memo of 02/18/86; App. A, 5.w), and the DBVP includes procedures to coordinate design basis comitments and requirements with the FSAR.
The response to the NRC request ( App. A, 5.fff) for TVA's plans to address ECN closure and FSAR updating will also provide corrective actions for this issue.
==
Conclusion:==
a.
Issue "a," as it applies to SQN, is not substantiated by this evaluation.
The reports reviewed demonstrate that commitments have been adequately tracked at the Sequoyah site since 1982 when the CATS was developed.
The few discrepancies found are more related to deficiencies of TVA's implementation of corrective actions than to comitment tracking.
Also, in those instances where weaknesses were identified in the comitment tracking activities or in CCTS, the corporate deficiencies, and not the SQN site, were apparently responsible.
00700 - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NLSWER: 1 PAGE 17 0F 27 1
The Corporate Comitment Tracking System (CCTS) has been established for TVA-wide tracking of NRC comitments. The SON site has procedures in place and the system appears to be functioning well.
All open NRC comitments are on CCTS, and TVA has committed to the NRC in the NPP that CCTS will be implemented, the data base will be updated with all comitments, and CCTS policy-implementing procedures will be issued. This comitment is identified on the CCTS data base by comitment number NC0 860156098 ( App. A, 5.rr) and NC0 860156102 ( App. A, 5.ss) and must be completed prior to restart of Unit 2.
In addition to the implementation of CCTS, TVA has comitted in the NPP to conduct a review back to January 1,1981 of LERs, NRC Bulletins, and NRC inspection reports to identify any comitments that belong in the CCTS data base.
This comitment appears in the CCTS data base as No. NCO 850491012 (App. A, 5.tt).
The evaluation team has found evidence to demonstrate that comitments have been adequately tracked at SQN. TVA's comitments to implement and verify an adequate tracking system prior to startup assures that past, present, and future comitments are properly tracked to completion.
b.
Issue "b" is addressed in Element Report 204.6(B).
c.
For issue "c" the concern is valid, but adequate procedures are in place and are being followed.
I d.
Issue "d" is valid.
The DBVP and other actions to be discussed with the NRC will provide adequate procedures to assure that the FSAR will accurately reflect the design changes made since the operating license was issued.
l 00700 - 01 /14/87
~
TVA EMPLOYEE CONCERNS REPORT NLSEER: 201.5(B)
SPECIAL PROGRAM REVISION NUMBER: 1 l
PAGE 18 0F 27 l
10.
CORRECTIVE ACTION TVA has submitted a Corrective Action Plan (CAP) for each of the four CATDs associated with this report ( App. A, 5.hhh).
For CATD 201.05 SQN-01 the CAP indicates that two procedures to govern the CCTS will be prepared before restart.
This action is being tracked on the CCTS by NCO 860156098 and NCO 860156102. This CAP is acceptable to the evaluation team.
For CATD 201.05 SQN-02 the CAP states that Regulatory Licensing will review past violation responses, bulletin responses, licensee event reports, and NUREG-0737 items back to January 1,1981. TVA has committed to complete this action before restart and is tracking it on the CCTS as NCO 850491012.
This CAP is acceptable to the evaluation team.
For CATD 201.05 SQN-03 the CAP states that open and completed NRC comitments back to January 1,1986 will be identified and input to the CCTS verified. This action is not considered a restart item; however, it is scheduled to be completed before restart.
This CAP is acceptable to the evaluation team.
For CATD 201.05 SQN-04 the revised CAP ( App. A, 5.qqq) describes a program of reviewing ECNs and verifying the accuracy of the FSAR.
The NRC has also noticed the lack of closure of ECNs and the discrepancies with the FSAR. The NRC has requested ( App. A, 5.fff)
TVA to provide by January 31, 1987 a program and schedule for correcting this situation.
Consequently, this CAP is a preliminary description of the program TVA intends to submit to the NRC. TVA has indicated in this CAP that this is not a restart item.
However, because of the specific involvement of the NRC in this issue, this CAP is acceptable to the evaluation team.
l I
I l
00700 - 01 /14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NLM ER: 1 PAGE 19 0F 27
)
APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
SNP FSAR, Amendment 3,1986 b.
Sequoyah Nuclear Plant Compliance Staff Instruction Letter CS-SIL-5, " Commitment and Corrective Action Tracking," Rev.
2, (11/27/85) c.
Sequoyah Nuclear Plant Standard Practice, SQA 135,
" Commitment Tracking," Rev. 4, (02/24/86) d.
TVA Nuclear Engineering Procedure, NEP-6.1 (fomerly OEP-ll),
" Change Control", Rev. O, (07/01/86) e.
TVA Nuclear Engineering Procedure, NEP-2.1 (fomerly OEP-14),
" Licensing Support," Rev. 0, (07/01/86) f.
NSRS Investigation Report No. I-85-132-SQN, for Employee Concern No. XX-85-122-006, TVA Nuclear Safety Review Staff, (03/03/86) g.
Draft Report for Element 12, " Commitment Tracking System,"
Employee Concerns Category - Management and Personnel, (06/20/86) h.
TVA Watts Bar Nuclear Plant Employee Concerns Task Group -
Operations - CEG, " Subcategory:
Nuclear Power / Site Program / Procedure, Element: Corporate / Site Support Functions, Report No. 307.10," (05/02/86) 1.
TVA memo from Jackson to Those Listed, ( A02 860813 012),
Institute of Nuclear Power Operations (INP0) Corporate i
Evaluation Responses, (08/l4/86) j.
Letter from Dircks, NRC, to TVA, (B45 850919 826), SALP Board Reports, (09/17/85) k.
Letter from Lewis, NRC, to TVA, (NEB 840614 612), SALP Board Reports, (06/12/84) 1.
Letter from Lewis, NRC, to TVA, ( A02 830415 001), SALP Board Reports, (04/13/83) m.
Letter from Lewis, NRC, to TVA, ( A02 820823 010), SALP Board Report, (08/20/82) 0070D - 01/14/87 i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.5(B)
SPECIAL PROGRAM REVISION Nt#EER: 1 PAGE 20 0F 27 APPENDIX A (cont'd) n.
Transcript of the July 10, 1986 TVA Meeting with the Advisory Comittee on Reactor Safeguards ( ACRS) Full Comittee o.
TVA Nuclear Perfomance Plan, Vol. I Corporate, and Vol. II Sequoyah p.
TVA memo from Mullin to Gridley, (119 860725 903),
" Transmittal of Nuclear Quality Audit and Evaluation Branch Audit Report," QSS-A-86-0016, (07/25/86) q.
TVA memo from Mason to Those Listed, (L16 860304 884), "Use of Tracking and Reporting of Open Items (TROI) System for Office of Nuclear Power (ONP) Tracking and Trending Analysis," (03/12/86)
Two-part TVA memo between Raulston and Beasley, "Comitment r.
Endorsement No. WBN-E 487," (NEB 850207 301) (02/07/85) and (805 850418 003) (04/18/85) s.
TVA memo from Mason to Those Listed, (L44 851227 801),
" Policy Regarding Control Over Making Comitments to the NRC, Tracking Comitments Through Implementation, and Maintaining Comitments Throughout P1 ant Life," (01/02/86) t.
Letter from Domer, TVA, to Adensam, NRC, (L44 850201 806),
" Amendment to operating license for SQN," (02/01/85) u.
TVA memo from Cridley to Abercrombie, (L44 860218 811),
"Sequoyah Nuclear Plant Unit 1 and 2 Annual FSAR Update,"
(02/18/86) v.
Letter from Mills, TVA, to O'Reilly, NRC, (A27 840314 041),
" Annual Report 1-1-83 to 12-31 SQN Unit 1 and 2,"
(03/14/84) w.
Letter from Do;ner, TVA, to Adensam, NRC, (851211001),
" Proposed Change to Technical Specifications to Allow Use of a Fifth Standby Generator,"(L44 850201806), (02/01/85) i x.
Letter from Shell, TVA, to Adensam, NRC, (L44850418 806),
" Additional Infomation for Technical Specification Revision to Allow Use of a Fifth D/G," (04/18/85) l 0070D - 01/14/87 l
l
1 TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 210F 27 APPENDIX A, (cont'd) y.
SQN NRC letter from G. G. 7ech, NRC, to S. A. White, TVA, (A02 860818 019), " Notice of Violation, (Inspection Report Nos. 50-327/86-31 and 50-328/86-31)," (08/12/86) z.
TVA-SQN memo from W. T. Cottle to Those Listed, (L44 850927 801), " Policy regarding control over making commitments to the NRC," (10/02/85) aa.
TVA-SQN memo from H. G. Parris to Those Listed, (L44 850919 805), " Policy regarding control over making comitments to the NRC," (09/26/85) bb.
Letter from J. P. O'Reilly, NRC, to H. G. Parris, TVA, Report Nos. 50-327/83-31 and 50-328/83-31, (02/14/84) cc.
Letter from D. M. Verre111, NRC, to H. G. Parris, TVA, Report Nos. 50-327/85-23 and 50-328/85-23, (08/02/85) dd.
Letter from J. A. 01shinski, NRC, to S. A. White, TVA, Report Nos. 50-327/85-46 and 50-328/85-46, (01/29/86) ee.
Letter from J. A. Olshinski, NRC, to S. A. White, TVA, Report Nos. 50-327/86-06 and 50-328/86-06, (03/05/86) ff.
TVA-SQN memo from R. J. Mullin to Those Listed, (L19 860611 900), " Audit No. QSS-A-86-0016 Corporate Comitment Tracking System," (06/11/86) gg.
TVA-SON memo from R. J. Mullin to R. L. Gridley, (L19 860725 903), " Transmittal of Nuclear Quality Audit and Evaluation Branch Audit Report QSS-A-86-0016," (07/25/86) hh.
TVA-SQN memo from R. L. Gridley to J. E. Hutton, (L44 860822 807), " Response to Audit Report QSS-A-66-0016,"
(08/22/86) ii.
TVA-SQN memo from G. W. Killian to H. L. Abercrombie and R.
W. Cantrell, (Ll7 860211808), " Transmittal of QAB Audit Report No. QSQ-A-86-0002," (02/11/86) jj.
TVA-SQN memo from H. L. Abercrombie to G. W. Killian, (S53 860310 956), " Corrective Action and Correction of Deficiencies on QAB Audit Report No. QSQ-A-86-0002,"
(03/12/86) 00700 - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NL9WER: 201.5(B)
SPECIAL PROGRAM REVISION NLNSER: 1 PAGE 22 0F 27 APPENDIX A, (cont'd) kk.
TVA-SQN memo from R. L. Lumpkin Jr. to H. J. Green, (0QA 830817 704), "OQA Audit Report SQ-83TS-09," (08/17/83) 11.
TVA-SQN memo from H. J. Green to R. L. Lumpkin Jr.,
(L16 830920 855), " Response to 0QA Audit Report SQ-83TS-09,"
(09/22/83) m.
TVA-SQN memo from R. L. Lumpkin Jr. to J. A. Coffey, (0QA 840123 700), "OQA Audit Report No. SQ-8400-02,"
(01/23/83) nn.
TVA-SQN memo from J. A. Coffey to G. W. Killian, (L16 840216 874), " Response to 00A Audit Report No.
S0-8400-02," (02/21/84) oo.
TVA-SQN memo from G. W. Killian to H. L. Abercrombie and J.
Hutton, (L17 850717 806), " Transmittal of QAB Audit Report No. QSQ-A-85-0009," (07/17/85) qq.
TVA-SQN memo from H. L. Abercrombie to G. W. Killian, (S53 850809 884), " Response to QAB Audit Report No.
QSQ-A-85-0009," (08/14/85) rr.
CCTS Comitment Update Report, Comitment No. NC0 860156098 ss.
CCTS Comitment Update Report, Commitment No. NC0 860156102 tt.
CCTS Comitment Update Report, Comitment No. NC0 850491012 uu.
TVA c".no from S. A. White to Taose Listed, (L02860709839),
" Policy Establishing the Nuclear Procedures System,"
(07/10/86)
I vv.
Sequoyah Engineering Procedure SQEP-18, " Procedure for Identifying Comitments and Requirements as Source Information for Sequoyah Design Criteria Development," Rev.
l 1, (07/09/86) l w.
Letter from L. M. Mills, TVA, to E. Adensam, NRC, (AQ7 830414 007), " Transmittal of Updated FSAR," (04/14/83) xx.
Letter from D. S. Kamer, TVA, to E. Adensam, NRC,
( A27 840416 013), " Transmittal of Anendment 1 to the Updated FSAR," (04/16/84) 00700 - 01/14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NtBEER: 1 PAGE 23 0F 27 APPENDIX A, (cont'd) yy.
Letter from J. W. HJfham, TVA, to E. Adensam, NRC, (L44 850411 809), " Transmittal of Amendment 2 to the Updated FSAR," (04/11/85) zz.
Letter from M. B. Whitaker, TVA, to B. Youngblood, NRC, (L44 860411 812), " Transmittal of Anendment 3 to the Updated FSAR," (04/11/86) aaa.
Letter from B. J. Youngblood, NRC, to S. A. White, TVA, (A02 860224020), " Concerns Regarding the TVA Nuclear Program," (02/18/86) bbb.
Letter from B. J. Youngblood, NRC, to S. A. White, TVA (06/25/86), with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN ccc. TVA memo from G. H. Kimmons to N. N. Sprouse and H. H. Mull, "All Nuclear Plants - Implementation Of Tracking and Reporting)of Open Items System (TROI)," (EDC 820615 001),
(06/15/82 ddd. Report No. 710, " Productivity as Related to Management and Personnel," TVA Employee Concerns Special Program, (08/28/86) eee. TVA 45D, P. L. Duncan to D. T. Clift, a consnitment to revise NEP 2.1, (11/03/86) fff. Letter from G. G. Zech, NRC, to S. A. White, TVA, "Sequoyah ECN Closecut and FSAR Updates," (L44 861224113), (12/18/86) ggg. SQ-CAR-86-04-021, Corrective Action Report Regarding FSAR Updates, (No RIMS f), (04/18/86) hhh.
Letter from G. R. McNutt, TVA, to G. L. Parkinson, Bechtel,
" Employee Concern Evaluation Program - Corrective Action Plan," TCAB-037, (12/19/86) 111.
Procedure Change Notice, NEP 2.1, (805 861212 502), (12/31/86) jjj. Employee Concerns Task Group, Other Sites, Element:. '. ping Design Analysis, Report Number SWEC-SQN-06, (09/15/86) kkk.
Employee Concerns Task Group, Other Sites, Element: NRC Notification Inadequate, Report Number SQEC-SQN-23, (10/07/86) 00700 - 01 /14/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.5(B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 24 0F 27 APPENDIX A, (cont'd) 111. Employee Concerns Task Group, Other Sites, Element:
Non-Confomance Reporting, Report Number SWEC-SQN-31, (09/09/86) mm. Employee Concerns Task Group, Other Sites, Element: TVA Comparison to Industry Medians, Report Number SWEC-SQN-12 R1, (01/05/87)
{
nnn. Employee Concerns Task Group, Other Sites, Element: High Failure Rate for Auxiliary Feedwater ( AFW) System, Report Number SWEC-SQN-43 R0, (11/15/86) ooo. Employee Concerns Task Group, Other Sites, Element:
SQN Operational Readiness Review, Report Number SWEC-SQN-48 R1, (01/05/87) ppp. TVA memo from W. R. Brown to H. L. Abercrombie, " Watts Bar Nuclear Plant Employee Concerns Task Group (ECTG) - Element Report SWEC-SQN-40, (T25 861009 925), (10/09/86) qqq. TVA memo from H. L. Abercrombie to W. R. Brown, "Sequoyah Nuclear Plant (SQN) - Employee Concerns Task Group (ECTG)
Element Report 201.05 SQN - Engineering Category - Corrective Action P1an (CAP)," (S03 870114 850), (01/14/87) 6.
WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
a.
SNP FSAR as updated March 1986 b.
10CFR50.71, " Maintenance of Records, Making of Reports" c.
10CFR50, Appendix B, Criterion III, " Design Control,"
Criterion V, " Instruction, Procedures, and Drawings,"
Criterion XVI, " Corrective Action," and Criterion XVIII,
" Audits" d.
Nuclear Quality Assurance Manual, Part III, Section 1.1,
" Document Control" e.
Nuclear Engineering Procedure, NEP 2.1, " Licensing Support,"
Rev. O, (07/01/86) f.
Nuclear Engineering Procedure, NEP 6.1, " Change Control,"
Rev. O, (07/01/86) 00700 - 01 /14/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.5(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 25 0F 27 l
APPENDIX A, (cont'd)
Rev. O, (07/01/86)g Procedure, NEP 9.1, " Corrective Action,"
Nuclear Engineerin j
g.
j h.
Licensing Commitment No. NCO 850467007 to " Implement Corporate Commitment Tracking System which will include updating the CCTS data base and implementing CCTS policy in procedures," to be completed prior to restart
(
i.
Licensing Ommnitment No. NCO 850491012 to " Review back to January 1,1981, all LERs, ERC Bulletins, and NRC inspection reports to identify any commitments which should be included in the CCTS data base"
~
j.
Licensing Commitment No. NC0 860156 098, " Corporate Commitment Tracking System" k.
Licensing Commitment No. NC0 860156102, " Corporate Connitment Tracking System" 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELAltu TO ELEMENT.
a.
Personal visit to Knoxville, TN, (08/27,28/86), BLT-043 (09/16/86) b.
Personal visit to Chattanooga, TN, (08/28/86), BLT-043 (09/16/86) c.
Personal visit to SQN site, (08/29/86), BLT-043 (09/16/86) d.
RFI # SON-533, (09/05/86) e.
RFI #SQN-548, (09/04/86) f.
RFI #SQN-552, (09/10/86) g.
RFI #SQN-573, (09/15/86) h.
RFI #SQN-599, (09/29/86) 1.
Telecon, W. E. Purcell, Bechtel, to D. T. Clift, TVA, IOM 255 (09/10/86) j.
Telecon, W. E. Purcell, Bechtel, to D. T. Clift, TVA, IOM 257 (09/15/86) 00700 - 01 /14/87
TVA EMPLOYEE CONCERNS REPORT NtmBER: 201.5(B)
SPECIAL PROGRAP REVISION Wl#EER: 1 PAGE 26 0F 27 APPENDIX A, (cont'd) j.
Telecon, W. E. Purcell, Bechtel, to D. T. Clift, TVA, IOM 257 (09/15/86) k.
Telecon, W. E. Purcell, Bechtel, to 0. T. Clift, TVA, IOM 262 (09/22/86) 1.
Telecon, W. E. Purcell, Bechtel, to D. T. Clif t, TVA, IOM 266 (09/23/86) m.
Telecon, W. E. Purcell, Bechtel, to D. T. Clift, TVA,10M 265 (09/24/86) n.
Telecon, D. T. Clif t, TVA, to W. E. Purcell, Bechtel, IOM 279 (09/26/86) o.
Telecon, W. E. Purcell, Bechtel, to D. T. Clift, TVA, IOM 280 (09/29/86) p.
Telecon, W. E. Purcell, Bechtel, to D. T. Clift and Roy Holliday, TVA, IOM 291 (10/01/86) q.
Telecon, D. T. Clift, TVA, to W. E. Purcell, Bechtel, IOM 292 (10/02/86) r.
RFI, #SQN-585, (09/22/86) s.
RFI, #SQN-587, (09/23/86) t.
TTB,122 Section 5, (10/02/86) u.
RFI, #SQN-603, (09/29/86) v.
Meeting in Knoxville between Nesbitt and Hutson, TVA, Don-Doncow, Bechtel, IOM 530 (08/21/86) 0070D - 01/14/87
r TVA EMPLOYEE 00NCERNS REPORT NUMBER: 201.5(B)
F SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 27 0F 27 CATD LIST The following CATDs identify and provide corrective action for the findings included in this report:
201.05(B) SQN-01 (12/19/86) 201.05(B) SQN-02 (12/19/86) 201.05(B) SQN-03 (12/19/86) 201.05(B) SQN-04 (12/19/86) (CAP Revised 01 /14/87) l l
l l
l 00700 - 01 /14/87
t i
til s
REFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 46 FREQUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:57:19 OflP - 1555 - RWM EMPLOYEE C0f4CERN PROGRAF 1 SYSTEM (ECPS)
RUN DATE - 12/02/86 LIST OF Et1PLOYEE C0f4CERN IllFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20105 TRACKING OF COMMITMENTS AND DESIGN CHANGES S
GENERIC KEYHORD A H
APPL QTC/NSRS P
KEYHORD B C0tiCERt1 SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD C NUMBER CAT CAT D LOC FL QB REPORT R
DESCRIPTION KEYHORD D HI 100-002 EN 20105 S HBN YYYY SR DIESEL GENERATOR MARGINS ARE INADEQU NONCONFORMANCE T50211 EN 24300 K-FORM ATE.
TVA HAS ADDED DGS TO BROWNS FE CORRECTIVE ACTION
~
RRY, SEQUOYAH AND HATTS BAR.
EACH T GENERAL IME A QUESTION IS RAISED, TVA MUST C EQUIPMENT ONDUCT ANOTHER STUDY. TVA ADDS DIES EL GENERATORS HITHOUT UPGRADING LICE HSING DOCUMENTS. CI HAS NO FURTHER INFORMATION. ANONYMOUS CONCERN VIA LETTER.
HI 100-041 EN 20105 S HBN YYYY SR LACK OF ADEQUATE TRACKING FOR ENDES DESIGN CHANGES
}
T50213 EN 20406 REPORT COMMITMENTS AND DESIGN CHANGES. CI AUDIT HAS NO FURTHER INFORMATION. ANONYM 0 ENGINEERING US CONCERN VIA LETTER.
GENERAL ggg XX 122-006 EN 20105 S SQN YYYY - I SS 17 5 S;; 'L SEQUOYAH DIESEL GENERATOR MARGINS A NONCONFORMANCE T50214 EN 24300 REPORT RE INADEQUATE. TVA HAS ADDED DGS TO CORRECTIVE ACTION BROWNS FERRY, SEQUOYAH AND HATTS BA GENERAL R.
EACH TIME A QUESTION IS RAISED, EQUIPMENT J
TVA MUST CONDUCT ANOTHER STUDY. TVA ADDS DIESEL GENERATORS HITHOUT UPGR ADING LICENSING DOCUMENTS. CI HAS N O FURTHER INFORMATION. ANONYMOUS CO 4
)
HCERN VIA LETTER.
XX 122-007 EN 20105 S BFN YYYY I-85-147-BFN SR BROHN'S FERRY: DIESEL GENERATOR MARG NONCONFORMANCE T50214 EN 24300 REPORT INS ARE INADEQUATE. TVA HAS ADDED DG CORRECTIVE ACTION J
S TO BROWNS FERRY, SEQUDYAH AND HATT GENERAL S BAR.
EACH TIME A QUESTION IS RAIS EQUIPMENT ED, TVA MUST CONDUCT ANOTHER STUDY.
TVA ADDS DIESEL GENERATORS HITHOUT UPGRADING LICENSING DOCUMENTS. CI H AS NO FURTHER INFORMATION. ANONYM 0U S CONCERN VIA LETTER.
I-85-132-SQN EN 24300 N SQN YNYY SR DIESEL GENERATOR MARGINS ARE INADEQU EN 2Ol65 K-FORM ATE. TVA HAS ADDED DG'S TO BROWN'S F ERRY, SEQUOYAH AND HATTS BAR. EACH T INE A QUESTION IS RAISED, TVA MUST C ONDUCT ANOTHER STUDY. TVA ADDS DIESE L GENERATORS HITHOUT UPGRADING LICEN SltlG DOCUMENTS. CI HAS NO FURTHER IN FORMATION. ANONYMOUS CONCERN VIA LET TER.
l 5