ML20214Q686
| ML20214Q686 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/18/1987 |
| From: | Hutzler C TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214Q673 | List: |
| References | |
| MC-40705-SQN, MC-40705-SQN-R03, MC-40705-SQN-R3, NUDOCS 8706050115 | |
| Download: ML20214Q686 (17) | |
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- TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM t
REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 3 lR3 (Final Report - Reopened)
TITLE: Quality Receiving Unit PAGE 1 0F 16 lR3 REASON FOR REVISION:
To incorporate Technical Assistance Staff and Senior Review Revision 1 Panel comments.
To incorporate additional information and reflect comments by the Revision 2 Nuclear Regulatory Conunission. Report status changed from
" Final" to " Reopened".
To incorporate Senior Review Panel comments Revision 3 PREPARATION PREPARED BY:
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- SRP secretary's signature denotes SRP concurrences are in files.
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TVA EMPIAYEE CONCERNS REPORT NUMBER: -MC-40705-SQN
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SPECIAL PROGRAM
'zg REVISION NUMBER: 3 lR3 PAGE 2 0F 16 lR3 I. INTRODUCTION e
This evaluation was performed as a result of a Sequoyah Nuclear Plant (SQN) specific employee concern, number XX-85-027-X02.
J II.
SUMMARY
OF PERCEIVED PROBLEM The pe'rceived problem as stated in concern number XX-85-027-X02 is:
" Material inspectors were not allowed to validate heat numbers of structural steel received on site as required by procedure [;] heat No. 7438383 is an example."
i This is in error based upon additional information obtained from the i
Nuclear Safety Review Staff (NSRS) unexpurgated files (see Section IV.C of this report).
Based upon this additional information the perceived problem is as stated
- e. in NSRS Report No. I-84-34-SQN:
" Heat numbers for QA [ Quality Assurance] material (steel)
! may be entered into the ' log book' [ Heat Number Sort I' Printout (HNSP)] without Certified Material Test Reports (CNTRs) being.in the record vault. Heat No. 7438383.
was provided as an example."
III. EVALUATION METHODOLOGY A. Reviewed expurgated files to obtain additional information.
B. Reviewed Employee Concerns Task Group (ECTG) working files to obtain additional information.
1 C. Reviewed NSRS unexpurgated files to obtain additional information.
D. Reviewed Site Procedures to determine the requirements for i validation of heat numbers.
! E. Conducted interviews to determine if any instances of material inspectors not being allowed to validate heat numbers for material
- received on site were known (This step was performed for the original perceived problem as stated in concern number
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XX-85-027-X02).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 3 0F 16 lR3 IV.
SUMMARY
OF FINDINGS A. A review of the expurgated files revealed the number of an NSRS report, which was, "(NSRS) Report Number XX-85-027-X02."
B. A review of the ECTG working file revealed an Employee Response Team (ERT) Investigation Report number XX-85-027-X02 and associated correspondence. This correspondence indicates that NSRS Report number XX-85-027-X02, referenced in Section IV.A. of this report (MC-40705-SQN), is in fact the ERT Investigation Report number XX-85-027-X02.
ERT Investigation Report number XX-85-027-X02 was written to address the perceived problem as stated in concern number XX-85-027-X02 and it contained the following conclusion:
"This concern is not substantiated. Tais conclusion is based on the following:
(1) Interviews of the other material inspectors provided no evidence to support an impedance of inspectors to validate heat numbers as directed in the approved procedures.
(2) Material heat numbers randomly extracted from the H.N.S. [ Heat Number Sort) satisfactorily proved themselves to be adequate in that proper certified material test reports were readily available for all numbers picked.
The discrepancy noted in the observation section of this report requires further evaluation by TVA."
This conclusion, "This concern is not substantiated", is concurred with. Basis number (1) is agreed with, see Section IV.E. of this ECTG report (MC-40705-SQN). Basis number (2) is not agreed with due to the results of the heat code evaluation performed at SQN in ECTG Report MC-40703-SQN and the following inquiries.
, TVA EMPLOYEE CONCERNS REPORT NUMBER 8 MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 4 OF 16 lR3 A Certified Material Test Report (CMTR) for each of the eleven heat numbers (7439599, 7438383, 31B246, 3457, 4464622, 52795, 56434, 59139, 59569, K6024, and M2026), including the example heat number 7438383 given by the Concerned Individual (CI), referenced in the ERT report was requested from the Document Control Unit (DCU). Only four (7439599, 7438383, 4464622, and 52795) of the eleven requested CMTRs were obtained from the DCU, one of these four was the example heat number 7438383 given by the CI. However, one heat number (3457) referenced in the ERT report is not listed in the HNSP.
These DCU personnel were again requested to conduct a thorough search for CMTRs for these eleven heat numbers and to ascertain whether or not they could be considered to be "readily available".
This search revealed the following:
CMTRs were found for only the following eight heat numbers: 7439599, 7438383, 31B246, 4464622, 52795, 59569, K6024, and M2026.
DCU personnel did not consider any of the CMTRs to be "readily available", and they stated, "it was a very difficult and time consuming process to locate these CMTRs."
CMTRs for the following three heat numbers, 3457, 56484, and 59139, could not be found.
NOTE: The above inquiries were employed to determine whether or not a CMTR could be found for the subject heat numbers. ECTG report MC-40703-SQN programmatically addresses the methods l employed to establish and maintain material traceability to the CMTR and the results of the lack of this
( traceability.
The discrepancy noted in the observation section of the ERT Report l is:
there is nothing adequately describing the use, methods of maintenance or controlled distribution of the HNSP, as required by 10 CFR 50, Appendix B, Criterion V.
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i <- TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM
- j. REVISION NUMBER: 3 lR3 PAGE 5 OF 16 lR3 i
This discrepancy became an NSRS recommendation (Q-85-027-X02-01) to SQN. SQN's response, which is contained in the ECTG working files, was as follows:
. . . generation of a new procedure to control a-document no longer in use at SQN is not justified."
SQN's " Corrective Action Response Evaluation", was " accepted" by NSRS and ERT report XX-85-027-X02 closed. The NSRS acceptance transmittal is maintained in the ECTG working files.
SQN's response to, and NSRS's closure of..this discrepancy is not concurred with because it did not address SQN's violation of 10 CFR 50 Appendix B, Criterion V, which states:
" Activities affecting quality shall be prescribed i by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactory accomplished."
4 The HNSP was used during a portion of the construction' activities, at SQN, as the primary method of material verification, at installation, and also during the review for acceptability of the weld record documents. The HNSP remains available for use and, in fact, is used today as an aid in locating CNTRs for heat numbers (e.g., the HNSP was used by DCU personnel in locating the CNTRs referenced in Section IV.B of this report). The resultslof a i lack of procedure governing the HNSP and its use are addressed
- - in ECTG report NC-40703-SQN.
NOTE: Although no specific timeframe can be established for this concern, it was determined to l
be construction related due to ERT report references to Construction Procedures and the concurrence of the CI with the results of the subject investigation, as stated in the i
report ". . . The CI was contacted to discuss results of i the subject investigation and '
does not have any further j questions in the area."
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4 TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-00705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 6 0F 16 lR3 C. A review of the NSRS unexpurgated file revealed that several investigations into concerns raised by this CI had been performed; the results of which failed to satisfy the CI. Consequently, as stated in NSRS Report No. I-84-34-SQN (QO1 850315 052) a team of NSRS investigators met with the CI, in December 1984:
"The NSRS objectives were to (1) obtain a precise and complete definition of the employee's concerns, whether it was the restatement of previously evaluated concerns or identification of new concerns, and (2) to evaluate, indepth, all items of concern as identified in (1) above, regardless of whether or not it had been previously evaluated, to determine the validity of the concerns and, if valid, the safety significance of the concern."
The concerns were documented and concurred with, by the CI, as follows:
" Concern No. 1 Individual 'A' has not been following QA procedures since 1977, and also, individual
'B' (the concerned employee) has not been allowed to follow QA procedures during the same time period. The following three examples were provided to support this allegation.
Example A - Cable reels were not meggered upon rereeling for the reels documented on Data Sheet 6 of Inspection Instruction (II)-32, ' Inspection of Material in Storage and Housekeeping Conditions,' for
' report Nos. MIG-828. -827, 710, -755 -756, and -757.
Individual B stated that the ' Data Sheet 6s' of II-32 for these MIG reports were not in the Material Inspection Group trailer and he did not know whether they were in the Quality Control Records Unit or not.
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- TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 7 0F 16 lR3 Example B - Cable identliication information may not have been transferred properly when cables were rereeled. In some cases cable catalog numbers were used on the II-32 Data Sheet 6s instead of cable reel numbers (SNP numbers) as required by the procedures.
The concerned employee stated that this violation occurred during the 1981 through July 1982 timeframe.
Example C - A reel of cable with TVA mark No.
'WDU' was transferred to SQN from Watts Bar Nuclear Plant (WBN). TVA mark No. WDU is class 1E cable at SQN, where as it is non-class IE at WBN. Individual B was concerned that this reel of cable may have been used in a class 1E system. Individual B provided a form TVA 45D dated January 13, 1983, to the investigation team on this subject.
Concern No. 2 Quality assurance training was not always received as documented on the SQN Report of Training or Instruction form. He alleged that these records were altered by the instructors or clerks after the training sessions were completed and forms signed by the alleger. The alleged alteration dealt with addition / expansion of the description of instruction or training given. He provided documents dated July 18, 1983, and June 27, 1983, to illustrate this allegation.
Concern No. 3 Heat numbers for QA material (steel) may be j
entered into the ' log book' without Certified Material Test Reports (CMTRs) being in the record vault. Heat No. 7438383 was provided as an example. He stated that he had not been able to locate CMTRs for three other heat numbers in the past but that he did not remember those numbers."
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. i TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 8 OF 16 lR3 These concerns and their related conclusions and recommendations l identified as a result of the NSRS investigative actions (referred I to as NSRS " classical" investigations) are required to be evaluated lR3 and closed by the ECTG "Other Site" Category Evaluation Group in l accordance with: l
" TENNESSEE VALLEY AUTHORITY l EMPLOYEE CONCERNS TASK GROUP l PROCEDURE ECIG M.2 i PROGRAM PLAN lR3 FOR l SWEC AND NSRS ISSUES", l Revision 0, dated 08/28/86. l However, concern No. 3 is directly related to concern number IR3 XX-85-027-X02 and therefore it is evaluated in this report. 1 It is apparent that the concern as stated by QTC in concern number XX-85-027-X02 was derived by combining statements in the CI's concern Nos. 1 and 3. Concern No. 1 deals with incidents of impediment in following QA procedures:
". . . individual 'B' (the concerned employee) has not been allowed to follow QA procedures. . . "
while concern No. 3 deals with program inadequacies:
" Heat numbers for QA material (steel) may be entered into the ' log book' without Certified Material Test Reports (CMTRs) being in the record vault . . ..
Having requested and obtained a CMIR for heat number 7438383, NSRS stated they could not substantiate the specific allegation of concern No. 3. However, in order to have a higher level of confidence in the HNSP they requested CMTRs for five additional l
randomly selected heat numbers (428990, 434221, 19047, 2-TV-67-426,
' and 1815533). CMTRs were obtained for all of these except 2-TV-67-426. As a result of the review of these and "other documents" in conjunction with their interviews, NSRS complied a historical synopsis of the Heat Number Sort program used and reached the following conclusion:
"The specific allegation was not substantiated; however, there appear to be inconsistencies in the implementation of the compilation of required materials certification as well as ambiguity in the program established to control it . . ."
, TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 9 0F 16 lR3 The portion of the conclusion dealing with the nonsubstantiation of the " specific allegation" is not concurred with because the allegation that heat numbers may be entered into the " log book" without CMTRs being in the record vault is valid (see Section IV.B of this ECTG report). However, the balance of the conclusion is agreed with.
The NSRS report (I-84-34-SQN) also contained the following recommendation:
"As a result, the investigators could not confidently determine (1) the purpose (s) for which the Heat Number Sort was generated, (2) the specific administrative controls designed and practiced to maintain the integrity and adequacy of the program, and (3) the complete scope of application and utilization of the printout.
Therefore, it is NSRS's recommendation that a search of documents / files / procedures be made so that a history of the Heat Number Sort can be reconstructed to include the following:
(1) The purpose / reason the Heat Number Sort was generated.
(2) Those management controls designed and implemented to administer the program.
(3) The function the program was designed l to serve and the function it has been serving, if different.
(4) The confidence OC [0ffice of Construction]
management has with the available information in the program (Heat Number Sort printout).
i NSRS further recommends that appropriate actions be taken to obtain CMTRs for items
( listed for example 4 [2-TW-67-4261."
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.. TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM J REVISION NUMBER: 3 lR3 PAGE 10 0F 16 lR3 This recommendation is concurred with; however, it has yet to be adequately addressed as shown by the following correspondence:
A memorandum dated March 15, 1985, from the Director of NSRS to the Manager of Construction and the Manager of Engineering (Q01 850315 051) requested OC:
. . . to provide NSRS with the actions taken or planned to resolve these issues within 30 days of the date of this memorandum."
A memorandum dated April 16, 1985, from the Manager of Construction to the Director of NSRS (C01 Ep0416 007) requested a 30-day extension to permit a more thorough investigation of the issues, includin- the recommendation, raised by the NSRS report. -
A memorandum dated May'15, 1985, froni the Manager of Construction to the Director of NSR3 (C01 850515 005) requested an additional ten work!.36 days to complete their response to the recommendation. A postscript dated May 16, 1985, (Col 850516 005) directed the SQN OC that:
"A response to I-84-34-SQN.03 [the NSRS recommendation) is to be drafted and reviewed by OC QAB [ Quality Assurance Branch) by the end of business on May 28. I will not request another extension for this item."
A memorandum dated May 20, 1985, from the Director of NSRS to the General Manager (Q01 850520 050) supplied the status of the recommendation response as:
. . . Awaiting OC's completion of research".
A memorandum dated May 21, 1985, from the Project Manager, SQN OC to the Assistant to the Manager of Construction (C23 850521 008) stated:
"I can understand your desire not to request an additional extension.
The reason for both previously requested extensions was that we have informally coordinated drafts with NSRS.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3.
PAGE 11 OF 16 lR3 We have not thus far been able to provide words satisfactory to them.
SQN grew through the maturation of 10CFR50. What was acceptable no longer is. The heat code printout was in fact used as a quality assuring mechanism but in fact never had any formal controls applied to it. This was considered acceptable at that point in time and the mechanism was in fact an improvement over what had been done before. The challenge is to gain understanding of that condition without exerting a massive record review program."
A memorandum dated May 28, 1985, from the Manager of Construction to the Director of NSRS (C01 850529 007) contained the following response to the recommendation:
"We have studied the subject NSRS investigation and herein provide the following responses:
Recommendation I-84-34-SON-03 Availability of the Material Certification and Requirements for Heat Number Sort Printout Entries A search of documents / files / procedures has been made as well as discussions with personnel who were involved with the Heat Number Sort Program. The following information is supplied in answer to the four areas mentioned in the NSRS report.
- 1) The purpose / reason the Heat Number Sort was generated.
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- TVA EMPLOYEE CONCERNS REPORT NUMBERg MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 12 OF 16 lR3 The HNSP was developed to provide a quick reference for document reviewers to verify heat numbers recorded on QA inspection records.
For example, before weld data sheets were filed in the records storage vault a record reviewer would verify by way of the HNSP that the material used was appropriate.
If a record was received bearing a number which was not in the HNSP the record was rejected and researched.
- 2) Those management controls designed and implemented to administer the program.
There were no formal management controls placed on the HNSP.
A Sequoyah Heat Number User's Guide was published and used for providing basic instructions on how to enter data into the program.
- 3) The function the program was designed to serve and the function it has been serving, if different.
Same as 1.
- 4) The confidence OC management has l with the available information in the program.
OC management is confident that the information in the program was/is sufficiently accurate to statistically support a reasonable assurance that the plant was constructed in accordance with applicable codes and standards.
. TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 (R3 PAGE 13 0F 16 lR3 It must be remembered that the SQN QA program grew and matured with the 10CFR50 QA program. It is understood and accepted that the SQN QA program would not meet todays standards but it did meet the standards of the time.
Weed Instrument Company was contacted on March 28, 1985 and appropriate documentation was received for the items listed in example 4 of your basic report."
A memorandum dated July 8, 1985, from the Director of NSRS to the General Manager (QO1 850709 055) supplied the SQN OC response to the recommendation (C01 850529 007) along with the following comment:
"We do not find the response satisfactory and plan to investigate this issue ourselves in the near future."
A memorandum dated July 8, 1985, from the Director of NSRS to the Manager of Construction (QO1 850709 054) contained the following:
"We have reviewed your response to NSRS recommendation I-84-34-SQN-03, Availability of the Material Certification and Recuirements for Heat Number Sort Printout Fe.cles, and do not find it satisfactory.
We plan to investigate this matter further ourselves in the near future.
Please provide us with copies of all SQN procedures since the inception of the Heat Number Sort Printout that controlled or referenced this program for any and all i
applications. These procedures should ine* te all that could have been in effect sin: then as well as those deleted or inactivated. Our intent is to determine the historical background of the program as well as its potential / perceived /
actual application. We appreciate your cooperation on this matter and expect the results of the historical review by August 1, 1985."
- TVA EMPLOYEE CONCERNS REPORT NUMBER; MC-00705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 14 0F 16 lR3 A postscript dated July 16, 1985, (C01 850716 001) directed an addressee to:
". . . assemble the requested information (what is available) and prepare response for . . . (The Manager of Construction's]
. . . signature ASAP."
A memorandum dated July 23, 1985, from the Manager of Construction to the Director of NSRS (C01 850723 004) contained the following:
"We have performed a review of SQN's i Quality Program to identify any procedures referring to or controlling the Heat Number Sort Printout and were unable to identify any such interfacing quality program procedures. We have attached a Program User's Guide to assist you. Please be advised that this guide and the HNSP are not and never were a part of the Quality Program at Sequoyah."
No further correspondence concerning this recommendation was found; thus leaving the matter unresolved.
D. Site Procedures governing the validation of heat numbers, consisted of the following:
SNP Inspection Instruction No. 30, " Receipt Inspection" (II-30), Revision 0, dated 05/04/77 through Revision 7, dated 09/20/82.
SNP Construction Procedure No. P-34, " Heat Number Validation" (P-34), Revision 0, dated 06/13/77 and Revision 1, dated 12/13/78.
SNP Inspection Instruction No. II-39, " Heat Codu Transfer and ASTM 1 Designator Transfer" lR3 (II-33), Revision 0, dated 05/04/77 through Revision 2, dated 12/11/78.
SNP Construction Procedure No. P-31,
" Identification and Marking of Permanent Material" (P-31), Revision 0, dated 05/04/77 through Revision 2, dated 12/17/79.
1American Society for Testing and Materials lR3 l
1 . TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 15 0F 16 lR3 These procedures require that heat numbers be validated; either at receipt of material into the warehouse (II-30 and II-39) or upo.1 division of the material into two or more pieces, after issue froO the warehouse (P-34). A valid heat number is defined in II-39 as follows:
"The heat number or heat code shall be considered valid if the number or code marked or stamped on the material agrees with that on the applicable material certification or if the heat number or heat code has been j previously validated."
These procedures provide methods to permanently mark the material with a validation confirmation mark; but, they do not require a permanent mark.
Markings of a nonpermanent nature would probably, with the passage of time, become partially or totally obliterated; thus giving the illusion of its having never been validated, when the item is viewed in the field.
NOTE: No site procedure could be found governing the accuracy of the-information or the use of the HNSP, only a User's Guide 2 was lR3 found describing how information should be encoded.
E. Interviews conducted with eight materials inspection personnel, active during the construction phase of SQN revealed no known instances of material inspectors being prevented from validating heat numbers / codes of material received on site, as required by the i
procedures.
NOTE: Any potential intimidation or harassment of this CI is being handled by the Inspector General's Office by concern number HI-85-005-001.
2 UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT. lR3 l
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o TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN e' SPECIAL PROGRAM REVISION NUMBER: 3 lR3 PAGE 16 0F 16 lR3 Conclusions The perceived problem as originally evaluated (i.e., incidents of impediment in following QA procedures) was in error; however, the perceived problem as presently stated (i.e., programmatic inadequacies) was determined to be valid based upon the findings contained in this report. Contrary to the requirements of 10 CFR 50, Appendix B, Criterion V, the Heat Number Validation process and HNSP used for heat number documentation accountability /retrievability, lR3 were/are not sufficiently controlled by QA procedures, i The results of the lack of procedural control to ensure that -
l properly certified materials were used during and subsequent lR3 construction activities at SQN, is addressed in ECTG report numoer l MC-40703-SQN, " Heat Code as Related to Material Control". l V. ROOT CAUSE Management's failure to initiate and m?intain adequate administrative lR3 controls (site procedures) to implement regulatory and code requirements. l VI. CORRECTIVE ACTION To be provided by line organization.
Reference:
CATD No. 40705-SQN-01, Revision 0 VII. GENERIC. APPLICABILITY Determined to be generically applicable to Bellefonte Nuclear Plant (BLN) and WBN due to the necessity to provide adequate administrative controls (site procedures) to implement regulatory and code requirements.
VIII. ATTACHMENTS Attachment A - Concerns Printout (Identifies relationship to Nuclear Safety and Generic Applicability)
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM RENRT NUMBER: MC-40705-SQN REVISION NUMBER: 5 IR)
PAGE I of I Sequoyah Nuclear Plant - Element Quality Receiving Unit ATTACIMENT A LIST OF CONCERNS INDICATING SAFETY RELATIONSHIP AND GENERIC APPLICABILITY CATEGORY: MC SU0 CATEGORY: 40700 PROCEDURAL CONTROL GENERIC APPL QiC/NSRS P' REFERENCE SECil0N #
CONCERN SUB PLT BBSW INVESilGAil0N S CONCERN CATEGORY - MC NUMBER CAT CAT LOC FLQB REPORT R DESCRIPil0N SUBCATEGORY - 40700 XX-85-027-X02 MC 40700 SQN NYNY ERT No. SS Material inspectors were not 150078 XX-85-027-X02 allowed to validate heat nunbers of structural steel received on NSRS No. site as required by procedure I-84-34-SQN heat No. 743838) is an exangle.
Sequoyah.
"PSR Codes:
SR-Nuclear Safety-Related SS-Nuclear Safety Significant NO--Not Nuclear Safety-Related 40 % i