ML20214F979
| ML20214F979 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/18/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8705260368 | |
| Download: ML20214F979 (16) | |
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' TENNESSEE VALLEY-AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place 3
MAY 181987
.U.S.'. Nuclear Regulatory Commiss!cn ATTN: ' Document Control Desk-Washington.D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327
. Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - SEQUOYAH ACTIVITIES LIST (SAL)
This letter provides TVA's response to an NRC request for additional J
information rega: ding the development of the SAL..
The need for
-additional information was conveyed by NRC staff in a meeting held with
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TVA on April 2, 1987, in Bethesda, Maryland.
TVA's response is provided in enclosure 1 and is in the form of'a revised and expanded section IV.of the Sequoyah Nuclear Performance Plan (SNPP) which now sununarizes the processes that have been in place and used at SQN since March 1986 to identify, evaluate, schedule, track,'and complete corrective actions required to resolve issues and conditions important to the restart of SQN.
A formal revision of the SNPP will follow this letter in approximately'.
two weeks,
Very truly yours, TENNESSEE VALLEY AUTHORITY R. Gridley, D ector Nuclear Safety and Licensing Enclosures cc:
see page 2 2
Y 8705260368 870518
'i PDR ADOCK 05000327 g gg PDR w.
p t-4 An Equal Opportunity Employer
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-. U.S. Nuclear Regulatory Commission hf {h hf cc (Enclosures):
Mr. G. G. Zech, Assistant Director for Inspection Prograns Office of Special Projects U.S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia '30323 Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
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ENCLOSURE 1 REVISION TO SECTION IV 0F THE REVISED SEQUOYAH NUCLEAR PERFORMANCE PLAN (SNPP) x-1 IV.
SUMMARY
OF SEOUOYAH ACTIVITIES
1.0 DESCRIPTION
OF SEOUOYAH ACTI'iITIES LIST The Sequoyah Activities List (SAL) is a list of all actions (including TVA commitments) applicable to SQN unit 2 that are considered important to the restart of SQN unit 2 or to the implementation of programmatic issues identified in the SNPP which are not required to be completed before the restart of SQN unit 2.
The SAL is not a detailed punchlist and it does not include all actions to be completed after restart of SQN unit 2.
Therefore, updating of the SAL will be discontinued when all the identified issues on it are closed.
The corrective actions for each restart SAL item provide the appropriate details for ensuring that the full scope of the SAL item is properly addressed.
Each SAL item is classified as restart or noncestart. The SAL reports the status of those items which have been closed and is further defined and tabulated in section IV.3.0.
The SAL represents a snapshot in time and therefore will change as time progresses. As a result, the SAL is maintained separately from the controlled version of the SNPP, and updates of the restart items are periodically provided to NRC.
SAL restart items and associated commitments, other than TVA Corporate Nuclear Performance Plan (CNPP) commitments, are grouped into major program areas.
These program areas are as follows:
Environmental Qualification o
Design and Configuration Control o
Cable Tray Support Analysis o
Design Calculations Review o
Alternately Analyzed Piping and Supports o
Main Steam Temperature o
Fire Protection, 10 CFR 50 Appendix R o
o Welding Program Review o
Sense Line Issues Wall Thinning Assessment Program o
o Restart Test Program Component Piece Part Qualification o
o Electrical Issues Containment Isolation Design Review o
Miscellaneous Programs o
Employee Concerns Program o
o Maintenance Quality Assurance Identified o
Additional NRC Requirements o
Miscellaneous SAL Items o
J TVA comunitments which correspond to SAL items are ' denoted by'a commitment number. Conunitments are tracked by TVA on its corporate c
-comunitment tracking system (CCTS). SAL items with no commitment
. number are activities which TVA management considers necessary.to implement the changes and improvements' described in the SNPP.
Restart' SAL items and the associated plans and goals listed'or stated in'the revised SNPP,'which are not classified as commitments.
may be changed by TVA as appropriate to reflect experience gained through the improvement programs. Any such changes would be part of
.the updates to the SAL Which TVA periodically provides to NRC.
Included in section IV.3.0 is the. list of CNPP connaitments pertaining to SQN. This listing correlates the CNPP commitment to i-the appropriate CNPP page number and identifies each action as to status relative to SQN:
ongoing, complete, restart, or long term..
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2.0 METHODOLOGY USED TO IDENTIFY RESTART ITEMS A special sequoyah Restart Task Force was established by i
S.- A. White, TVA Manager of Nuclear Power, on March 19, 1986, to verify the identification of problems and initiate action for resolution, where necessary, before restart of SQN. This task force was composed of high-level management from TVA and outside i
consultants with extensive nuclear experience in' operations, quality
' assurance, design, construction, and project management. The task l
force examined SQN issues to ensure that the actions to be taken at SQN would suitably address the root cause of identified problems.
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This section describes the methodology by which issues were identified for inclusion on the original SAL and sets forth the criteria used to evaluate each issue to determine which items would I
be required to be resolved before the restart of SQN. This section also contains a description of the processes and controls used to revise the SAL and to ensure closure of each SAL item consistent l
with its intent.
A.
Development of the SAL The CNPP (Volume 1) established the direction and the objectives for the SNPP. The task force used that evaluation and others to focus attention on issues and programmatic problems requiring resolution before restart. Under the guidance of the task force, the line organization began development of a list of all issues or conditions which would need to be resolved or corrected before the restart of either SQN unit. To establish a baseline, the restart and potential j.
restart items from the following sources were placed on the Sequoyah Restart List (SRL):
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-1) Nuclear Engineebing Restart'L'ist - Items were' identified by the Division of Nuclear Engineering (DNE) from a review of all open significant condition reports (SCRs),
nonconformance reports (NCRs) -engineering change notices; (ECNs),'NRC and internal inspection reports, NRC p
' commitments..and action items on the Tracking and -
Reporting of Open Items system (TROI).
Those items that t'
were considered to be significant were listed and then-each item was evaluated for its importance to restart.
l 11)' Division of Nuclear Quality Assurance.(DNQA) - DNQA provided a list of items from a Quality Assurance (QA)
L report on operational readiness Which addressed-DNQA audits, 'the corporate Institute of Nuclear Power
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Operations-(INPO) evaluation report, all open corrective action reports (CARS), all open discrepancy reports (DRs),
all open Nuclear Safety Review Staff (NSRS) issues, and the findings from studies performed by outside engineering.
- firms such as Gilbert Commonwealth, Black and Veach, and Stone and Webster.
iii) Project 2 (P/2) Outage Schedule -~ Key-activities were included'from the then current P/2 scheduled outage work which was scheduled to be completed before restart.
iv) Corporate Commitment Tracking System (CCTS) - This j.
included NRC commitments required to be completed before-t-
restart or by the end of the current outage as planned at that time.
f-v) Employee Concerns - All issues identified by the Employee Concern Program as applicable to SQN were evaluated to determine the safety significance and were included if.
judged to be important to restart.
3 vi) The NRC "Stello" Plan - This was reviewed, and the activities required to support NRC's review were identified to ensure consistency'and completeness.
vii) NRC OIE inspection reports - Items from the Systematic j
Assessment of Licensee Performance (CALP) report and other inspection reports issued between September 17, 1985, and l.
April 1986 that were restart issues were included.
After this process, a baseline was established which identified approximately 560 potential restart items. The task force reviewed 4
the list and interrogated the responsible line managers and lead engineers to ensure that:
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i) all potential restart issues were identified; 4
- 11) the methodology used to evaluate restart items was sound and addressed the full issue; r+.+..
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- lli) the resolution of fissues integrated input from _all appropriate disciplines and had Quality Assurance (QA) participation and input; and iv) control systems were established to appropriately track and close each issue or item.
As the list evolved, the task force developed a set'of restart-t
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screening criteria to provide written guidance for the line' i
organization to use in identifying restart issues. These criteria, j
as presented in the-SNPP, were structured to identify programmatic deficiencies having a high probability of causing a specific deficiency which, in turn, would be a restart issue and to provide a; sound method for evaluating specific deficiencies to identify safety-
' significant conditions. Additional criteria were provided to ensure that personnel health and safety, radiological controls, and 4
regulatory requirements were also considered in establishing the SRL.
In.an April'1986 memorandum, the Site Director required all responsible supervisors to use the restart screening criteria to
. verify the SRL.- In addition, he also directed them to review new and unresolved items in their area of-responsibility and to present 3,
l these items for review by the task force. The development of the i
SRL was being performed concurrently with a complete rewrite;of the-SNPP;-and, during this time, it was decided to expand the SRL to include' activities and issues from the revised SNPP and other-sources and thereby expand the list beyond " restart items" to-include issues considered important to the implementation of the SNPP.
This new list was called the SAL and classified items as restart or nonrestart.
The task force provided the guidance and the responsible line organizations within the Office of Nuclear Power (ONP) identified additional issues'and activities. As issues were identified, I
responsible supervisors used the restart criteria to determine which items should be' completed before restart. Their recommendations were presented to the task force for review, and the SAL was revised accordingly. The following are examples of some of the actions to L
ensure that the SAL was comprehensive:
i) CCTS entries opened af ter September 17, 1985, were reviewed by responsible organizations and added to the list as appropriate.
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- 11) The NRC correspondence, including the September 17, 1985 10 CFR 50.54(f) letter, was reviewed to ensure that NRC j
concerns had been identified and an appropriate SAL action item existed or who added.
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iii) Commitments and major issues from the text of the revised i
SNPP were added, and the SAL was organized into program areas based on the special programs of the revised SNPP, section III.
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. iv) Newly identified issues from further review of the' Watts
-Bar Employee Concern.Special Program or from the newly established ONP Employee Concern Program were evalcated 3
.and added to the list.
As a result of these actions, a draft SAL was published and circulated to all divisions and sites for review and comment. The comments were incorporated and a revised draf t was then reviewed, item by item, during a meeting of all responsible organizations with.
Mr. White. This process produced the SAL that was submitted to the NRC in July 1986las part of the revised SNPP.
That list was comprised of 702 restart and noncestart_ items applicable to SQN units 1 and 2.
Based on the number and scope of the areas evaluated for potential SAL items, the numerous ~ requests by the task force and TVA y:
1 management for potential SAL items, and the expertise of the task force, TVA is confident that the SAL submitted with the SNPP in July 1986 encompassed all the restart issues applicable to SQN unit 2 and known to TVA at that time.
B.
Process for Revision of the SAL
_ Shortly after the SNPP was submitted, SQN management established a process for controlling revisions to the SAL and for scheduling and tracking actions required to resolve each issue on the SAL. -These processes were described in a memorandum from the Site Director to those managers responsible for ensuring that particular SAL ltems were resolved and corrective actions completed. The Planning and Scheduling staff was assigned the responsibility for~ control of revisions to the SAL and the use of the P/2 scheduling program to track completion progress.
The emphasis at SQN shifted from problem identification to j
implementation of the SNPP, evaluation and' resolution of appropriate corrective actions for the problems identified on the SAL, and the preparation and conduct of the special programs described in the SNPP section III. As these efforts proceeded, additional technical issues were identified and brought to the attention of the Site Director and the task force. The Site Director's weekly review meetings and progress reports to the task force served as another 7
forum to identify additional issues requiring resolution before p
restart of SQN unit 2.
These meetings continue to be held by the Site Director along with the progress reporting to the Manager of i
Nuclear Power.
As the action plans and implementation schedules for resolution of SAL items or execution of the programs described in the SNPP were developed, they were submitted to the Planning and Scheduling staff and entered into P/2 in conjunction with the applicable SAL item.
The task force evaluated action plans, program changes, and the restart determination proposed by line management to address the basic issues that had been identified in the SNPP.
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- A set of written SAL policies evolved in August 1986 requiring tha changes to the restart list be submitted to the Planning and Scheduling staff which' ensured that the change was reviewed by the Site Director or the restart director and the task force. It is 1
important to note that ONP managers were directed and encouraged to identify new potential restart activities and that the Site Director or task force continued to review restart determinations made by the line managers.
The SAL is periodically updated for all changes and provided to the responsible managers-to ensure it is regularly reviewed for accuracy. The first_such update was accompanied by a transmittal-memorandum which also provided written SAL policies for making changes to the SAL. The importance of maintaining the list using approved policies was also reemphasized in a.later meeting of nearly 100. managers and senior engineers. This frequent emphasis on-accuracy of the SAL and the formalized policies provided. assurance that new issues were identified, evaluated, brought to the attention of TVA management, and added to the TAL with a restart or noncestart designation.
The common criteria used to guide the line organizations in raising issues and making recommendations to management ~and the task force have been the restart requirement criteria set forth_in table 7 of L
section IV of the SNPP. These criteria were initially established f
by the task force and were subsequently refined to reflect input from the Browns Ferry Nuclear Plant tank force and adopt a consistent format.
In December, a memorandum from the Site Director to principal managers at SQN was issued to formalize these criteria. This was not a relaxation of the criteria, and no SAL item was removed from the listing. Effective March 10, 1987, these 1
criteria were made applicable as the unified restart requirement criteria for all TVA sites. Table 7 (page 13) provides the full i
text of these criteria. Line management has been instructed to use these criteria to determine which' issues or corrective actions j,
require resolution or completion'before restart of SQN unit 1 or 2.
The restart criteria in table 7 are applicable to hardware items.
However, the principles embodied in the restart criteria can readily be applied to other activities, such as maintenance programs, j
training programs, and the procedure upgrade efforts to determine what is necessary to be completed before restart. Judgement is used when reviewing restart requirements for non hardware-related attivities. Where ju'dgements have been made not to complete f
programmatic activities before restart, those judgements are
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reviewed by the Manager of Nuclear Power in the context of issuing the SNPP and any subsequent revisions to it.
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~On' March 5, 1987; the Sequoyah' Restart Task Force was disastabli'hed s
by Mr. White:after having completed its assigned responsibilities.
The methodology for identifying restart-items after disestablishing e.
the task. force remains essentially as discussed,in the preceding paragraphs except that the task force review of restart determinations made by the line managers has been assumed'by the Site Director and his designees.
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All potential SAL ltems are identified either through engineering review program recommendations or through the new condition Adverse
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to Quality Report (CAQR) process. =Each potential SAL item or CAQR is evaluated using the unified restart requirement criteria to determine whether associated corrective action is required to be completed before restart of SQN unit 2.
Those items determined through these evaluations to be restart-issues are presented to the Site Director's staff for approval.
The Site Director is responsible for approval of particular items that must be resolved before restart and for ensuring that each SAL item is' properly dispositioned. The Site Director has designated either the Restart Director or Assistant to the Site Director to evaluate proposed _new activities and ascertain that these activities meet the restart criteria.
C.
Coordination of Sequoyah Restart Activities Following approval of a SAL item, responsibility is assigned to appropriate line managers for definition and implementation of
-corrective action. All SAL items are dispositioned in accordance with a SQN site procedure.
Only the Manager of Nuclear Power can delete items from ths activities list that have been designated as restart items.
As noted in paragraph B, the Site Director has identified a Restart Director who is responsible for coordinating management of the restart effort. The Restart Director reports directly to the Site Director and has responsibility and authority to establish specific l
schedule priorities, ensure that line managers are coordinating their activities to complete all restart actions, establish site goals as appropriate to achieve a safe and timely restart, call and conduct restart schedule status meetings, and ensure performance of the individual groups and intege'ated work activities. These efforts l
by the Restart Director have been established in order to ensure that all restart requirements are properly completed in an integrated fashion and on a timely basis. Through the activities of l
the Restart Director, the site Director is provided with an early signal of potential problem areas and is able to take prompt action.
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2 _D.
' SAL Item Closure Process
- In November _1986,' the SQN Site Director initiated action to i
.. establish a standard practice to govern the review and closure of restart SAL items. :A procedure was developed, piloted, revised, and
' issued in December-1986. This procedure-(SQA190) became effective on-January 6, 1987. While.the initial" intent of SQA190 was to isovern the closure process ;it has.also been useful'in identifying issues and directing management attention to actions that are.
required to resolve' issues and complete corrective' action plans as set forth in the.SNPP and related SAL items.
The procedure.
specifies that closure of each restart. SAL' item is accomplished 4
through an independent review by the Division of Nuclear Safety'and.
Licensing (DNSL). This review encompasses the documentation that
. initiated the corrective action and the records that provide objective evidence that the corrective actions were completed or-that the-issue was resolved.
As noted, the initial issue of SQA190 specified the process for review and closure of SAL items; it also included a paragraph to ensure that potential restart SAL items would be evaluated using the restart criteria. The detailed administrative controls were set forth in the SAL policies described in paragraph B of this enclosure. Controls were established through SQA190 to ensure that.
none of the restart SAL items were deleted or reclassified without proper review and approval.-
The process established at SQN for identification and closure of activities and corrective actions required to be completed before restart of SQN unit 2 has produced the following results:
Issues requiring resolution are identified and clearly classified as restart or noncestart using a single uniformly applied criteria.
The SAL is organized by major program area in order to facilitate closure reviews of each program and each class of issue with NRC.
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The closure process requires corrective actions to be i
established, approved, and communicated to those who'are i
responsible for the implementation.
The procedure also causes l
corrective actions to be classified as restart or nonrestart
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using the restart criteria.
The procedure requires that individuals who are responsible for each step of the process from issue identification, through j
implementation, to clos,ure be identified.
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The review of closure documentation has identified problems early enough to permit TVA management to take appropriate
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The individual closure packages are prepared and prochecked to facilitate an effective review process with TVA management.
-.These packages also identify those SAL items for which
-postrestart corrective actions have been specified.
At restart TVA management will be able to'have a precise and highly reliable assessment of the status of each activity on the SAL.
Significant progress has been made with the completion and' closure
.of SAL ltems. The status as of May 10, 1987, was:
Total number of Restart-SAL items 486 i:
Restart SAL items with restart corrective actions complete 325 Restart SAL items reviewed and signed by DNSL 296
. E.'
Improvements to the SAL Revision and Closure Process In February 1987, TVA implemented its new corrective action procedure, Nuclear Quality Assurance Manual (NQAM) Part I, section 2.16, at SQN through the issuance of SQN procedure AI-12.
This procedure has benefitt*d the process for identifying potential new SAL ltems by consolidating, into one process, the various methods that had previously existed at SQN and elsewhere in ONP for identifying, evaluating, and determining corrective actions for Conditions Adverse to Quality (CAQs). Additionally, the responsibility for maintaining the list of identified CAQs and for
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tracking the evaluation and corrective actions has been centralized within,DNQA. Thus, TVA has three basic methods of identifying potential new SAL items:
engineering and management recommendations arising from the various programs ~that TVA is implementing, licensing commitments, and CAQRs.
Each CAQR issued under the new procedure and the associated corrective actions will be evaluated as a potential restart issue utilizing the restart criteria set forth in the SNPP. This review will be retroactive for all open CAQRs issued under the new procedure (AI-12). A revision to the SQN procedure SQA190 is being made to enhance the closure process and impec.ve the controls over the process by which potential SAL items are identified and evaluated using the restart criteria.
The most important changes are:
Addition of a form to document the restart /nonrestart determination for engineering recommendations and CAQRs that have been evaluated using the restart criteria and to ensure adequate management review and approval.
i o' Proceduralizing the requirement for approval by the '
-Manager of Nuclear Power to remove a restart SAL item.
Addition of guidance for managing the completion and closure of SAL items that are large in scope or are programmatic and involve many subtasks or issues,.each of which requires evaluation, resolution, and potential corrective action (tracking SAL items)..
Addition of guidance and requirements that are intended to facilitate the closure of those ECNs associated with restart SAL items.
As an added measure, the SQN Site Director initiated a review of the processos that have been in use at SQN over the past eight months to identify and evaluate potential SAL items.
This review will provide an independent assessment for the Site Director of whether the restart criteria have been appropriately applied to the screening of potential restart SAL ltems and associated corrective actions.
This review was conducted by QA on a sample basis and the findings are now being evaluated.
These actions and changes to the procedure will: ensure that issues continue to be reviewed and added to the SAL, if appropriate; improve TVA's accountability over the work required to implement the SNPP; and make more manageable the completion and closure process--thus helping to ensure that the overall objectives of the SNPP will be achieved.
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. 3.0 SEQUOYAH ACTIVITIES LIST (SAL).
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.The SAL contains the following information for each entry:
o Unique I.D.' Number.
o Description - paraphrasing.the actual scope statement from the source document o
Restart Classification (Yes or No) o.
Commitment Number from CCTS. If applicable o
Volume 2 Reference, if applicable o
Unit 2 Status The status column contains one of four categories as follows:
Closed - All corrective actions have been accomplished and documented.
Restart Complete - All corrective actions that have been specified to be completed before restart are accomplished and documented. Remaining corrective actions have been identified and are being tracked in CCTS or P/2.
Duplicate - The scope of the SAL item is the same as, or falls within the scope of, another SAL item.
Open -
Corrective action is incomplete.
In assigning a " closed" status to restart items in the SAL, the following definitions were used:
o Review of SCRs/NCRs. CAORs. Technical Evaluations.
Surveys / Audits of Systems and Pronrams. Technical Issues Resolution etc.. Not Directly Covered by Desian Channe Requests (DCRs)/ECNs These iters can be classified as closed on the activities list once the actual review, evaluation, survey, audit, etc., has been completed to the point where the task requires no further corrective action by anyone and the acceptable results of these tasks have been documented. This includes actions identified to prevent recurrence if such actions are required.
o Work Associated with Restart DCRs/ECNs These items can be classified as closed on the activities list once the task defined by the DCR/ECN has been completed to t'he point where the system can be declared operable.
In addition, the following steps are required: drawings in the main control room have been
- e. properly marked, all required plant procedures-have been revised and issued or a temporary change is in place and approved, and the workplans are signed as being complete -
by the cognizant workplan engineer and Operations Section personnel, or a partial modifications completion fona has been initiated and approved.
o Work Associated With Restart DCRs/ECNs Not Requirina Physical Work on Plant Systems These items can be classified as closed in the activities list once the work required for restart.has been completed to the point where the task requires no further corrective actions by anyone and results of the accomplished work have been adequately documented as acceptable.
In general, restart items which were closed before March 1986 do not appear on this list. The purpose of listing closed items is to indicate the progress which has been made on restart items since March 1986.
Activities list items associated with issues identified in the Employee Concerns Program are annotated by an asterisk which follows the item description.
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,e. Table 7 RESTART REOUIREMENT CRITERIA The following criteria shall be used in evaluating whether a particular item must.be resolved before restart of unit'2 at SQN.
1.
.The item identifies a specific deficiency which has significant.
probability of leading to the inoperability of a system required for restart or operation by:the appropriate technical specifications.
2.
The item identifies a programmatic deficiency which has a high probability of causing or has caused a specific deficiency which meets No. 1 above.
NOTE: To assist in the determination of required for restart relative to technical specifications as in criteria No. I and No. 2 above, an affirmative answer to'any of the following questions requires consideration of the item for restart based on technical specification requirements.
a.
Does the item directly and adversely affect safety-related equipment function, performance, reliability, or response time?
b.
Does the item indirectly and adversely affect safety-related equipment power supply, air supply, cooling, lubrication, or ventilation?
c.
Does the item adversely affect secondary containment integrity?
d.
Does the item adversely affect secondary containment integrity?
e.
Does the item adversely affect control room habitability?
f.
Does the item adversely affect systems used to process radioactive waste?
g.
Does the item adversely affect fire protection or fire loads?
h.
Does the item adversely affect the ability of a system or component to meet its safety function during a design basis event by impacting the seismic analysis, single failure criteria, separation criteria, high " energy line break assumptions, or equipment qualification?
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- Table 7 (continued)
- i. Are the programs such as Radiological Health, Security, Radiological Emergency Preparedness, or Quality Assurance which are necessary for safe conduct of operation of the plant adversely affected?
- j. If not corrected before restart, could it-lead to an uncontrolled release or. spread of radioactive contamination beyond the regulated area?
3.
The item identifies a specific deficiency that results in a failure to comply with NRC regulations and no variance has been approved by NRC.
4.
TVA has committed to NRC to complete the item before restart.
5.
The item identifies a specific deficiency which has a significant probability of leading to a personal injury during plant operation.
6.
The item identifies a specific condition which has a forced outage risk (probability X outage length) during the next cycle in excess of the critical path time to correct the condition before restart.
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