ML20235U374
| ML20235U374 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Browns Ferry |
| Issue date: | 07/23/1987 |
| From: | Cassett D, Hunt G, Knightly J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML110830549 | List: |
| References | |
| BFN-NSRS-1, NUDOCS 8710140062 | |
| Download: ML20235U374 (23) | |
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1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLAAfT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Subcategory: Browns Ferry Nuclear Plant - NSRS Classical Items Element:
Review of Nuclear Safety Review Staff Restart Items At Browns Ferry Report Number: BFN-NSRS-l' Prepared By N
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'Dat'e 8710140062 871007 PDR ADOCK 05000259 P
Review of Nuclear Safety Review Staff (NSRS) Open Items Requiring Resolution at Browns Ferry Nuclear Plant (BFN) prior to Unit 2 Restart.
I.
Introduction NSRS conducted reviews of activities at Browns Ferry Nuclear Plant (BFN) during its span of overview responsibility from 1979 to 1986. - NSRS items remaining open in 1987 have been examined by the Employee Concerns Task Group (ECTG).
ECTG examined the status of open NSRS issues including those identified specifically for BFN as well as other sites' issues which could have generic applicability at BFN.
In all, a total of 109 issues were considered applicable to BFN including 24 requiring resolution prior to Unit 2 restart. The status of these restart issues is the subject of this BFN-NSRS-1 report, with the status of the 85 non-restart issues to b2 addressed in a subsequent report, BFN-NSRS-2.
The status of the 24 NSRS restart issues for BFN is as follows:
Closed R-80-05-SQN-4B Configuration Control Closed R-82-08-NPS-10A Management Attention Required for Resolution (BFN Regulatory Guide 4.15 Program and Laboratory Quality Program)
Closed R-82-08-NPS-10B Management Attention Required (Possible High Radiation Exposure Following Accidental Break of the Main Steam Line)
Closed R-82-08-NPS-10C Issuing of Directives Contrary to TVA Commitments (Chemistry Program)
Closed I-83-28-BFN-02 A Change in Radwaste System Operations is Necessary for Disposal of Spent Radioactive Resins Closed I-84-16-BFN-05 Transient Analysis on System Piping for High Pressure Coolant Injection (HPCI) j Open R-84-17-NPS-5 Cable Assemblies at BFN with Assigned QA Level I Fabricated by TVA from QA Level II Parts and No Mechanism to Upgrade QA Classification Page 1 of 19
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Op2n R-84-17-NPS-lO Commercial Gr:ds Items with QA Lavals I cnd II Designations Open R-84-17-NPS-ll Quality Verification for Commercial Grade Items Closed R-84-17-NPS-12 Receipt Inspection of QA Level I and II Items by Field Quality Engineers Open R-84-19-WBM-01 Clear Identification of Purposes and Uses of All Controlled Documents Closed R-84-19-WBN-06 Instantaneous Trip Settings of the Breakers for Motor-Operated Valves Open R-84-19-WBN-07 Development of Criteria for Cable Tray Fill Level and QC Inspection Open I-84-33-BFN-01 Investigation of Piping and Supports Open I-84-34-SQN-03 Availability of the Material Certifi-cation and Requirements for Heat Numbers Open I-85-06-MBN-01 The Adequacy of Dispositions for Identified Cable Bend Radius Problems Open I-85-06-WBN-02 The Adequacy of the Program for Cable Pulling Activities Open I-85-06-WBN-03 Voltage Drop & Short Circuit Current Determination & Verification Open R-85-08-0E/NUC PR-1 Inadequate OE Environmental Qualification 1
Procedure for Equipment Qualification by Similarity j
Closed R-85-08-0E/NUC PR-2 Inadequate OE and NUC PR Procedures for Initiating and Processing NCR-FE/ERs Closed R-85-08-0E/NUC PR-3 Lack of Priority on SQN NCR Initiation Closed R-85-08-0E/NUC PR-4 Lack of Engineer Awareness of NCR-FE/ER CAQR Procedure Closed R-85-08-0E/NUC PR-5 Lack of Timeliness in Initiating and Processing NCR-FE/ERs Closed R-85-08-0E/NUC PR-6 Failure of Management to Correct Problems with Timeliness and Responsiveness Page 2 of 19
II.
V*;rific~tinn of NSRS R*st rt It*ms (Closed) R-80-05-SQN-04B, Configuration Control In the original review dated June 1980, NSRS concluded from electrical deficiencies it found that configuration control was inadequate and made the following recommendations:
Establish CSSC configuration control verify through walkdown of several CSSC systems that physical configuration agrees with CSSC configuration control drawings Correct any deficiencies, and walkdown auditional systems if significant problems have been found The original report details were reviewed, as was the Browns Ferry Nuclear Performance Plan commitments concerning configuration control.
ECTG reviewed the Design Baseline and Verification Program plan for Browns Ferry (July 14, 1986), the BFN Configuration Management Plan (May 27, 1986), BFN Electrical Baseline Drawing List and Schedule ( August 6, 1986), Progress Report - Drawing Discrepancy Program (May 29, 1986), and overall BFN procedures used to identify and correct drawing discrepancies and to prevent recurrence of the configuration problem. Discussions were also held with cognizant personnel concerning numerous aspects of the Unit 2 P2 schedule for l
baseline activities, and the configuration control program progress l
and status.
ECTG confirmed that the Configuration Control program is adequately staffed and scheduled to verify the correction of drawing discrepancies required to support Unit 2 restart. The following configuration control activities were verified:
Procedures established for review of ECNs processed since operating license issuance to ensure systems functional ability in accordance with the FSAR l
Procedures established for evaluation of unimplemented and partially implemented ECNs Establishment of baseline design (in progress)
Review of walkdown/ test data (in progress) l Procedures established for performance of DNE Review Board l
safety evaluations Resolution of identified discrepancies (in progress) i Establishment of a change control process (in progress) l Page 3 of 19 l
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Establishment of a transitional design control system Field verification of all installed EQ equipment Specific progress concerning correction of electrical deficiencies includes the following:
Electrical single-line drawings required to support Unit 2 i
restart have been walked down I
Program being formulated for verification of all electrical schematic drawings 250 electrical schematic drawings identified for verification in support of EQ instrumentation and control system calculations EQ field verifications essentially complete (exceptions include cable bend radius / sidewall pressures and vertical conduits)
Appendix R walkdowns for cables complete Drawing discrepancies tracked and corrections in process Program implementing procedures and recurrence control procedures in place except for electrical schematics procedure BFEP-pI-87-44 The scope of the BFN. configuration control effort was verified by ECTG to go beyond that recommended by the NSRS R-80-05-SQN-4B report. Based on the verified adequacy of staffing and schedules to implement the BFN configuration control commitments, this item is closed.
(Closed) R-82-08-NPS-10A, Management Attention Required j
(BFN Regulatory Guide 4.15 Program j
and Laboratorv Quality p rogram).
j In the original review, NSRS concluded that the BFN Regulatory Guide 4.15 Chemistry Quality Assurance program was deficient in its procedures, scope, and responsiveness in correcting identified problems. The NSRS recommendation for item R-82-08-NPS-10A was for an increased level of management attention.
ECTG report 30711 reviewed the current status of corrective action to the R-82-08-NPS report, and CATD 30711-NPS-2 was issued concerning the NSRS identified deficiencies. In response the proposed corrective action plan (March 17, 1987) stated the following:
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Tha gon1 for th3 cpprorch prasantly being pursu:d is to davslop an exceptional program that exceeds in quality all requirements, commitments, and industry standards.
As a result of the problems identified in this audit and other audits by NRC, INPO, Quality Assurance, etc.,'a Chemistry Program Manager's position was established at the corporate level with the responsibility and authority to develop, implement, and maintain a state-of-the-art chemistry program at TVA.
This program is presently under development and schedules have been submitted for its implementation. When implemented, this program will address the concerns, both stated and implied, in the subject audit report.
ECTG reviewed on June 9, 1987 the chemistry Work Plan Program Plan, Directive, Schedule, and Model Plant Chemistry Program Development Plan and Schedule.
Additionally, discussions were held with personnel of the Chemistry Program Manager's office.
Based on these verification activities, ECTG determined that suitable management attention is being given to the program.
This item is closed.
(Closed) R-82-08-NPS-LOB, Management Attention Required (possible High Radiation Exposure Following Accidental Break of the Main Steam Line).
In the original report, NSRS stated that the BFN Technical Specifications as written did not appear to provide the technical basis for assuring that reactor coolant dose equivalent (DE) I-131 act'ivity levels will not exceed 3.2 microcuries/ gram. NSRS recommended that the Technical Specifications be rewritten, or proper justification for existing specifications be provided.
TVA's manager of nuclear power provided (L29 840725 891) to NSRS the results of an outside review of the Technical Specification adequacy.
The consultant's report stated (LOl 840625 106):
It was concluded that limits on ventilation activity releases during normal operation would restrict the acceptable dose equivalent I-131 level to a value below the present Technical Specification limit.
Furthermore, the offgas release rate and noble gas nuclide distribution are more important considerations than the primary coolant DEI-131 level. Given the expected type of fuel failures producing high DEI-131 levels, the present Technical Specification limit does not constitute an undue hazard.
From a safety standpoint there is no justification for requiring DEI-131 measurements following power level changes.
Based on the review of technical specification requirements and the justification for existing specifications, this item is closed, j
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(Closad) R-82-08-NPS-iOC, Issuing of Directives Contr&ry to TVA Commitments (Chemistry Program)
During the original review, NSRS concluded that procedural controls were absent for the central office preparation, qualification, and issuance of analytical procedures, NSRS recommended that nuclear power management direct their attention to this procedure development.
ECTG report 30711 reviewed the current status of corrective action to the.
R-82-08-NPS report, and CATD 30711-NPS-2 was issued concerning the NSRS identified deficiencies. In response, the proposed Corrective Action Plan of March 17, 1987, described an overall chemistry program for TVA (See R-82-08-NPS-10A for description).
ECTG reviewed in June 1987 the Chemistry Work Plan Program Plan, Directive, Schedule, and Model Plant Chemistry Program Development Plan and Schedule.
Additionally, discussions were held with personnel of the Chemistry Program Manager's office.
Based on these verification activities, ECTG determined that the development of TVA central office policy, goals, and objectives for chemistry activities is being accomplished in a controlled manner..This item is closed.
(Closed) I-83-28-BFN-02, A Change in Radwaste System Operations is Necessary for Disposal of Spent Radioactive Resins.
During a 1983 investigation of resin liners containing excess water, NSRS concluded that BFN's handling of wet solid radioactive waste was not in accordance with BFN's FSAR Section 9.3.4.1.
NSRS stated that, contrary to the'FSAR description of the solid radioactive waste system, a system change was made which connected the bead and powder resin systems.
NSRS stated that an unreviewed safety question determination (USQD) had not been performed for mixing together the two resin types. The Ruclear Regulatory Commission (NRC) also assigned a violatien to-TVA fo' this failure to perform a timely USQD in accordance with 10 CFR 50.5c.
BFN corrective actions included performance of a 10CFR 50.59 evaluation, and procedural changes and process controls to prevent recurrence of excess water in the resin liners. The NRC violation was closed in NRC Report 50-259, 260, 296/84-37 dated October 2,1984. The NRC closure included acceptance of the BFN explanation (A27 840817 006) that the mixing of resin types was not outside the scope of the FSAR description.
l Based on review of the applicable documentation and discussions with the i
plant personnel, ECTG concluded that the NSRS issue has been satisfactorily addressed. This item is closed.
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4 (Clostd) I-84-16LBFN-05, Trrnsient An91ysis on System Pipinq for High Pressure Coolant Injection (HPCI) i i
NSRS reported that the High Pressure Coolant Injection (HPCI) System had numerous failures.
Concern was also expressed about degradation of piping and supports. NSRS recommended that, after implementing a j
special test 82-11, a transient analysis of the system be performed j
to determine maximum loads from the fluid flow.
Based on the analysis, supports should be redesigned as required.
I ECTG reviewed the HPCI Abnormal Transient Analysis Report (B45 851202 257) and HPCI Discharge Piping Support Evaluation (845 851008 252), and discussed the issue with BFN personnel.
As a result of the BFN analysis and evaluations, Engineering Change Notice (ECN) P5366 (Work Plan 2015-84) was issued to modify support R23.
HPCI main check valve, FCV 73-45, which was suspected to require an inordinately high differential pressure to force open, was replaced for testing reasons not associated with the analysis. The northernmost strut on support R24, which was damaged, was replaced to ensure load capacity.
Based on the above review activities and BFN actions, ECTG verified that the NSRS recommendations had been implemented.
This item is closed.
(0 pen) I-84-17-NPS-5, Cable Assemblies at BFN with Assigned QA Level I Fabricated by TVA from QA Level II Parts and No Mechanism to Upgrade QA Classification j
NSRS reported that selected cable assembl.ies at BFN were improperly classified QA level I items. The assemblies were manufactured from parts with a lesser QA level II designation, and no mechanism existed to upgrade the level II designation. NSRS recommended a program of identification, replacement, procedural development, inspections, and training to assure that cable assemblies in stock, in use, or fabricated in the future satisfy the required technical and quality assurance specifications.
In response to identified problems of the type cited by NSRS, TVA has established an on-going program for assuring that commercial grade items satisfy requirements. The program is specified in NQAM part I, Section 2.7.2 " Dedication of Commercial Grade Items" and Browns Ferry Site Director's Standard Practice (BF SDSP) 16.1-02, Revision 1,
" Dedication Program for Commercial Grade Material, Parts, or Components for CSSC Application".
An overall report on the q
l dedication program was issued by ECTG as Report 801.04.
During this i
followup review, ECTG reviewed schedules and implementing documents,
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and discussed present status of the dedication program with cognizant BFN personnel.
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Contrcctor work on this issus is in process undsr contracts TV-56071A (Wyle) and TV-65375A (Bechtel).
A TVA/ contractor team (the items evaluation group) is committed to have completed prior to restart the site-specific evaluation of installed and warehoused commercial grade items, and corrective actions as needed. These activities are scheduled on the DFN P2 Schedule - 7024, " Materials Management Improvement Proj ect.
Implementation of the dedication program and act.2ptable closure of ECTG CATD 80104-NPS-1 will close this item.
(Open) R-84-17-NPS-10, Commercial Grade Items with QA Levels I and II Designations In the original report NSRS found that commercial grade items were being purchased with little or no QA requirements or from vendors or manufacturers without TVA approved QA programs and classified as QA Level I and II.
That practice was contradictory to the purpose of having QA Level I and II items with considerable QA documentation attesting to the items suitability for fulfilling an intended function. NSRS recommended that items purchased with no QA requirements or no requirements for material certification (COC, CMTR, etc.,) or from vendors or manufacturers without TVA-approved QA programs should not be purchased with a QA Level I and II designation for use in nuclear power.
In response to identified problems of the type cited by NSRS, TVA has established an on-going program for assuring proper control over purchased material and items. The specific program for evaluating items purchased with no QA requirements or no requirements for material certification, or from vendors or manufacturers without TVA-approved QA programs is described in NQAM, Part I, Section 2.7.2,
" Dedication of Commercial Grade Items," and in Browns Ferry Site Director's Standard Practice, BF SDSP-6.1-02, Revision 1, " Dedication Program for Commercial Grade Material, Parts, or Components for CSSC Application."
An overall report on the background problems leading up to the dedication program was issued by ECTG as report 801.04.
During this followup review on the NSRS item, ECTG reviewed schedules and implementing documents, and discussed presen't ' status of the dedication program with Browns Ferry site personnel.
Contractor work on this issue is in process under contracts TV-56071A (Wyle) and TV-65375A (Bechtel).
A TVA/ contractor team (the items evaluation group) is committed to have completed prior to restart the Browns Ferry evaluation of installed and warehoused commercial grade items, and corrective actions as needed. These activities are scheduled on the BFN P2 Schedule - 7024, " Materials Management Improvement Project." Implementation of the dedication program and acceptable closure of ECTG CATD 80104 - NPS-1 will close this item.
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(Open) R-84-17-NPS-11, Qu'lity Varifiention for Commerciel Gr-d4 Items In the original report NSRS stated that the use of commercial grade items as basic components places the responsibility for assuring that the items will function as intended under all conditions solely upon j
TVA.
The QA program within TVA at the time of the NSRS review was not capable of providing that assurance because it did not include a receipt inspection program or audit of the vendor's QA program for commercial grade items. NSRS recommended that NUC PR establish a receipt inspection program which includes listing or comparable mechanisms, such as audit of vendor's QA program, verification of certificate of conformance, etc., for replacement commercial grade items that will be dedicated as basic components or parts thereof, that would provide documented assurance that the items will function as intended.
1 In response to identified problems of the type cited by NSRS, TVA has j
established an on-going program for assuring that received items 1
satisfy requirements. The receipt inspection program is described in NQRM Part I Section 2.7.2, Revision 1, " Dedication of Commercial Grade Items", Browns Ferry Site Director's Standard Practice BF SDSP-16.1-02, " Dedication Program for Commercial Grade Material, Parts, or Components for CSSC Application", and Quality Control Instruction QCI 1.'-04, Revision 1, " Receipt Inspection".
Requirements now include receipt inspection by a qualified QC inspector, auditing of vendors' QA programs, and verification of certificate of conformance.
ECTG interviews indicated that i
inspections are now performed by a QC inspector for 100 percent of QA I
levels I, II, III.
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Contractor work on this issue is in process under contract's TV-56071A (Wyle) and TV-65375A (Bechte'l).
A TVA/ contractor team (the items evaluation group) is committed to have completed prior to restart the BFN evaluation of installed and warehoused commercial grade items, l
and corrective action as needed. These activities are scheduled on l
the BFN P2 Schedule-7024, " Materials Management Improvement Project".
An overall report on the dedication program was issued by ECTG as Report 801.04.
Implementation of the dedication program and acceptable closure of ECTG CATD 80104-NPS-1 will close this item.
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(Closed) R-84-17-NPS-12, Receipt Insoection of QA Level I and II Items by Field Quality Engineers The NSRS report found that TVA did not require use of qualified inspectors for receipt inspections concerning commercial grade items to be dedicated as basic components in quality equipment.
NSRS recommended that receipt inspections be performed by Field Quality Engineers or other inspectors qualified to ANSI N45.2.6.
1Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. l
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TVA's r:quiramsnts for qualified inspectors cra now provided in tha Nuclear Quality Assurance Manual, Part III, Section 2.2, Revision 1,
" Receipt, Inspection, Handling, and Storage of Materials, Components, and Spare parts".
QC inspectors for parts for Quality Level I and II items are qualified to TVA procedures consistent with ANSI N45.2.6.
ECTG reviewed the original NSRS report, the NQAM requirements, and Quality Control Instruction QCI 1.1-04, Revision 1, " Receipt Inspection".
Requirements now include receipt inspection by a-qualified QC inspector, auditing of vendors' QA programs, and verification of certificate of conformance.
ECTG interviews indicated that inspections are now performed by a QC inspector for 100 percent of QA levels I, II, III.
Based on this review activity, ECTG determined that the NSRS recommendations for use of qualified inspectors are being implemented satisfactorily at BFN.
This issue is closed.
l (Open) R-04-19-WBN-Ol, Clear Identification of Purposes and Uses of All Controlled Documents In the original report, NSRS identified instances at WBN where logic and control drawings did not agree with electrical drawings and termination lists.
Following review for generic applicability, this NSRS item was assigned by ECTG to all sites for review and correction as needed.
ECTG's verification activities at BFN included discussions with BFN engineering design personnel and review of Conditions Adverse to Quality Reports (CAQRs) concerning technical content of BFN control and logic diagrams.
BFN personnel assigned to the DNE Baseline Project stated that an upgrade to the logic / control drawings is in process. The BFN CAQs j
have documented several instances of disagreement in these drawings.
The CAQs include NCR BFNEEB 8203, NCR BFNEEB 8411, and SCR BFNEEB 8652. The SCR BFNEEB 8652 R1, dated March 1, 1987, identifies root cause as follows:
"...overall management deficiency
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in design control may have existed at the time of occurrence (September, 1974)." Corrective Action is assigned as follows (B22 870420 019):
A walkdown shall be performed to determine the as-constructed configuration of the plant.
If the as-constructed configuration of the plant agrees with the requirements.
. all involved drawings shall be revised and issued under exception change control, as defined in Nuclear Engineering Procedure (NEP)-6.1.3.5, which shall complete this corrective action. If the as-constructed configuration of the plant does not agree with the requirements.
. all involved drawings shall be revised under an ECN and issued per NEP-6.1.
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Th3 ECTG varificition for BFN's configuration control progrca (R-80-05-SQN-48) concluded that staffing and schedules wers cdcqunts to implement configuration control commitments in support of Unit 2 restart. Completion of the actions identified in SCRBFN EEB 8652 R1 will close the NSRS item on logic and control drawings. Completion of the SCR actions is tracked by ECTG CATD R-84-19-WBN-01.
Pending i
this completion, the NSRS item remains open.
(Closed) R-84-19-WBN-06, Instantaneous Trio Settings of the Breakers for Motor-Operated Valves (MOVs)
The original NSRS report for WBN stated that instantaneous trip settings for motor-operated valve breakers were not in accordance with Engineering Design (EN DES) criteria and vendor recommendations. NSRS recommended that instantaneous trip breakers be set in agreement with the National Electric Code (NEC), and that j
WBN documentation reflect the proper values.
ECTG's generic review
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of the NSRS item assigned the item to all sites for evaluation.
DNE personnel at Browns Ferry found the item did not apply to BFN.
Circuit breakers with adjustable instantaneous trips are not installed on the BFN motor-operated valves. The MOVs breakers have thermo-magnetic trips and cannot be adjusted.
Based on the BFN review, this NSRS item is closed.
l (Open) R-84-19-WBN-07, Development of Criteria for Cable Tray Fill Level and QC Inspection l
In the original review at WBN, NSRS concluded that criteria should be
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developed for field use to control actual cable tray fill levels and l
to provide a basis for Quality Control (QC) inspection.
ECTG's I
generic review of the item found it potentially applicable to all sites including BFN.
ECTG Report CO-10900 " Cable" examined the cable tray fill issue and assigned CATD 10900-NPS-5.
At BFN, the issue is extensively documented in SCR BFN EEB 8602 R1 applicable to all three units, as follows:
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Description:==
Cable weights and outside diameters are not available from a QA source. The origin of the present values is unknown.
Non-QA values were used for the calculation of conduit and cable tray seismic loadings and for the calculation of conduit and cable tray cross sectional area fill. QA values are required for these calculations.
Corrective Action:
1.
A search of the TVA contract files shall be performed to find any available data on cable weights and outside diameters for all cables which have been installed at BFNP.
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2.
All ctblas which etnnot havs thsir waights cnd outsids diameters determined by a contract search shall be walked down to determine this data.
3.
All data which is gathered in either task 1 or 2 above shall be used to determine the correct conduit and tray fill, and seismic loadings. These fill and loading values shall be documented by QA level documents.
Closure of the ECTG Report 10900 and SCR BFN EEB 8602 R1 will close NSRS item R-84-19-WBN-07.
At this time the issue remains open.
(0 pen) I-84-33-BFN-01, Investigation of Piping Analysis and Supports Design The original NSRS report stated that isometric and load support drawings are required to accompany each complete analysis.
NSRS found many instances at BFN where the drawings were not provided.
There were also instances where the analysis was not complete or did not cover as-built conditions.
Drawings were not issued for the essential equipment cooling water (EECW) and reactor drain and vont systems. NSRS recommended that all isometric and support drawings for the EECW and reactor drain and vent systems be prepared, checked, and issued in conjunction with the completed analysis summary book.
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Completa documentation suitable for audit was to be available.
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I ECTG verification activities for this item included a review of documentation related to the original report, and discussions with cognizant DNE personnel at BFN.
BFN personnel stated that they thought the required work was complete; however, a closed ECN or other closure documentation was not available.
It was agreed that DNE would verify completion and provide closure documentation.
ECTG issued CATD R-84-33-BFN-Ol
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dated June 10, 1987. This item remains open.
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(Open) I-84-34-SQN-03, Availability of the Material Certification and I
Requirements for Heat Number Sort Printout Entries The original report by NSRS stated that there appeared to be inconsistencies in the compilation of required material certification and some ambiguity in the program established to control it.
Specifically, NSRS could not conclude with certainty that the SQN Heat Number Sort Printout included only material with acceptable certification.
NSRS recommended that a history of the Heat Number Sort be reconstructed to establish the program's purposes, controls, designed functions, actual functions, and data quality.
Following review by ECTG for generic applicability, this NSRS item was also assigned to BFN.
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Ths ECTG R: port MC-40703, "Matsrial Control, Procsdural Control, Hazt Coda," dated September 26, 1986 excmin d ths SQN status of this issue. The issue status at Browns Ferry will be reported in ECTG subcategory report MC-40700, " Procedural Control". The evaluation at BFN is not complete at this time.
I Completion of the ECTG 40700 evaluation and subsequent corrective action if necessary will close this item.
At this time, the issue remains open.
(Open) I-85-06-WBN-01, The Adecuacy of the Dispositions for Identified Cable Bend Radius Problems In the original review at Watts Bar, NSRS investigators determined that there was not sufficient manufacturers' documentation /
justification / test data nor OE engineering basis to substantiate the final dispositions documented for NCRs or establishment of RTminvalues for multiconductor cables. The available information, as well as the acceptance criteria for sampling used to justify the as-installed conditions, lacked engineering support.
The report stated that OC was permitted by OE to bend the cables permanently to i
a radius of one-half of values which in 1981 were recognized to be an I
industry standard for minimum values to which a cable can be permanently bent.
Although OE and OC's final disposition accepted the installed condition of these cables at WBN based on "0E/OC developed" values, NSRS questioned the validity of these values.
Following review for generic applicability, ECTG also initiated review of this issue at BFN.
1 At BFN, the cable bend radius issue is the subject of SCR BFN EEB 8634, dated June 27, 1986. This BFN SCR identifies root cause and planned corrective action as follows:
1 General Construction Specification G-4 did not provide guidance on minimum bend radius because cable bend radius was apparently not a concern during the time frame of the original construction of the plant.
A walkdown of the plant shall be performed to identify all conduits contairing class lE Medium Voltage Power cables which have been installed through condulets or pull boxes. All triax, I
coax, and twinax cables which are installed for 1E applications l
shall be reviewed to identify any cables which are installed in conduits that could have a standard bend radius less than the minimum bend radius of the cable involved. Those identified l
will be walked down to determine if minimum bend is exceeded.
j All triax, coax and twinax cables shall also be walked down to identify any installations through condulets. QA level documentation shall be issued to document any cables which violate the minimum bend radius specified by G-38.
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l ECTG's ovaluation of th3 ctble bsnd ridius problem is reportsd in l.
construction category report 10900.
ECTG findings included those of the NSRS report. CATD 10900-NPS-1 was issued to correct identified problems.
Acceptable closures of ECTG CATD 10900-NPS-1 and SCR BFN EEG 8634 will close the NSRS issue.
At this time the issue remains open.
(Open) I-85-06-WBN-02, The Adequacy of the program for Cable Pulling Activities In the July 1985 report, NSRS concluded that OE and OC's cable pulling programs were inadequate and in violation of the accepted industry standards and practices. The report stated that Construction Specification G-38 had not defined the method for calculating maximum allowable tension for multicable pulls nor had it finally established the method of pulling multicables utilizing a break link.
Also, the industry considered the side wall pressure as a limiting factor for cable pulling activities.
Failure to ensure that maximum allowable tension, as well as sidewall pressure, was not exceeded in any cable pulling operation increased the potential for
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cable damage (insulation degradation) which is not necessarily j
detected visibly or through testing.
ECTG's generic review of the
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issue found it potentially applicable to BFN.
At Browns Ferry the cable pulling issue is the subject of l
SCR BFN EEB 8631, dated June 27, 1986.
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addresses sidewall pressure, as follows:
l Cable sidewall pressure (SWP) calculations were not required in TVA construction specifications G-3 and G-4, electrical design standards, or drawings prior to cable installation.
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The existing cable installations will be evaluated by comparing calculated SWPs of a worst case sample with allowable SWPs
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established by SWP tests (E13 860604 001).
If allowable SWPs j
have been exceeded, they will be corrected by replacin3 the cables in accordance with TVA construction Specification G-38 and G-40.
ECTG's evaluation of cable pulling activities is reported in construction category report 10900. The ECTG findings included those of the NSRS report.
CATD 10900-NPS-1 was issued to correct identified problems.
Acceptable closures of ECTG CATD 10900-NPS-1 and SCR BFN EEB 8631 will close the NSRS issue.
At this time the issue remains open.
Page 14 of 19
(Open) I-85-06-WBN-03, Volt qw Drop rnd short Circuit Curr*nt Determination In NSRS report number I-85-06-WBN-3, the NSRS recommended that OE perform short circuit and voltage drop calculations for the Level 3 power circuits to ensure the adequacy of the size of the installed cable to perform its intended functions.
ECTG's generic review of the open issue found it potentially applicable to BFN.
ECTG completed a major review of Design Calculations at Browns Ferry and reported results in ECTG report 205.1 (C) " Control of Design Calculations".
Key findings include the following:
TVA established an electrical calculations program in 1985 to correct and resolve deficiencies found in electrical calculations at the four nuclear plants.
TVA identified a minimum set of electrical calculations to be completed before restart and ECTG's evaluation found the listing adequate.
The performance of the calculations required for BFN Unit 2 restart is in process.
Electrical calculations for Units 1 and
'j 3 will be prepared prior to restart of each unit.
TVA has committed to a long-term calculation program to complete j
all calculations required to document the design basis, j
ECTG found Nuclear Engineering procedures adequate to cover requirements for preparing, maintaining, and controlling the 1
electrical calculations.
CATDs were issued to (1) track completion j
of the essential calculation program (CATD 20501-BFN-1),
(2) supplement scope of the program (CATD 20501-BFN-2), (3) add ress quality records aspects of the program (CATDs 20501-BFN-3 and -4),
and (4) request issuance of a BFN procedure concerning the interim calculation program (CATD 20501-BFN-5l An additional CATD (205.05 NPS 04) concerned issuance / implementation of instructions for the long-term electrical calculation program.
BFN work on the calculations program is the subject of SCR BFN EEB 8529.
Acceptable closure of the ECTG Report 205.1 (C)
CATDs and SCR BFN EEB 8529 will close this NSRS item at Browns Ferry.
P Page 15 of 19
(Opin) R-85-08-OE/NUC PR-01, In-dequeto OE Environment Qur.lifiertion i
Procedura for Equipment Qualifiention by Similarity NSRS stated that the OE procedure for environmental qualification of SQN electrical equipment allowed qualification by " similarity" but contained no definite criteria defining what constituted a "similar" itam.
NSRS recommended that these criteria be established and incorporated into the TVA procedures governing environmental qualification of electrical equipment, and that the criteria be used i
to re-evaluate the qualification status of electrical equipment previously qualified by similarity. ECTG's review of this item found
]
it generically applicable to BFN.
j i
i The verification activities includer, interviews with cognizant personnel of the office of Engineering and Browns Ferry site environmental qualification project as well as a review of' equipment qualification project implementing documentation.
EQ requirements, including those for qualifying by similarity, are included in Office of Engineering discipline interface document NEB-DI-125.01 " Program Requirements for Environmental Qualification of Electrical Equipment in Harsh Environment." Office of Engineering EQ personnel indicated that qualification by similarity was not a requirement but was addressed in the interface document and could be implemented at a site when desired.
BFN site EQ personnel stated that the NEB-DI-125.01 procedure was issued after the BFN EQ program documentation was prepared. The procedure was reviewed, and BFN determined that requirements were adequately implemented by the site EQ program. The site EQ manager stated that BFN requires full qualification of equipment rather than qualification by similarity, and that, therefore, the similarity criteria were not needed in the BFN program procedures.
At this time the criteria for qualification by similarity are not included.
J ECTG recommends that the issue of qualification by similarity at BFN be addressed, rather than omitted, in site procedures by either including the criteria for possible use if needed or by stating that qualification by similarity is not acceptable at BFN. CATD R-85-08-0E/NUC PR-01 concerning this open item was issued to BFN June 9, 1987.
page 16 of 19
4 (Clostd) R-85-08-OE/NUC PR-2, Inadnau*te OE and NUC PR Procedures for Initiating and Processing NCR-FE/ERs -
NSRS concluded that the OE and ONP procedures-for processing.
nonconforming conditions reports (NCRs), failure evaluations.(FEs),
and engineering reports (ERs) were inadequate lfor assuring their timely initiation and processing. 'NSRS recommended in-depth review of TVA's program and possible changes to provide for, effective interface between participating TVA organizations, establishment of centralized tracking, and significant reduction in the time required for processing and dispositioning.
ECTG reviewed the NSRS report, current commitments in the Nuclear Performance Plan, NQAM requirements, and the corrective action program implementation at the BFN site.
Nuclear Performance Plan commitments concerning the nuclear-corrective action program are outlined in Volume I, (Revision 4),
Section VI.D.1 " Improvements in TVA's Nuclear Management Systems and P rog rams. " They include a thorough review of.the various nuclear programs to ensure that they contain adequate provisions for timely resolution Of conditions adverse to quality.
A new Conditions Adverse to Quality (CAQ) program with centralized tracking and specific time re;wirements was to be implemented at all sites by March 30, 1987.
ECTG verified that the CAQ program is established in the Nuclear Quality Assurance Manual (NQAM), Part I, Section 2.16, Revision 2.
At BFN, CAQ procedures are in place and overall site training has been completed. There is a commitment to timeliness.in t'he CAQ report initiation and processing.. The Tracking and Reporting of-Open Items (TROI) computer system has been selected as.the single corporate system for. tracking CAQs. The C4Q timeliness will be tracked by TROI and overdue items ' tagged for management attention.
Auditing data concerning the new program's adequacy was not available at the time of the ECTG verification activities because of the program's recent implementation.
Based on the CAQ program initiation i
including commitments, documentation, training, tracking, and I
reporting / auditing provisions, the' NSRS item is closed.
(Closed) R-85-08-OE/NUC PR-03, Lack of Priority on SON NCR Initiation NSRS stated that a. time period of approximately two months elapsed.
between the time the assignment was made to evaluate'the adequacy of the SQN containment pressure differential transmitters (CPDTs) until
~
the NCR was issued. It was recommended that OE define and document a policy to assure that operating plants are afforded the proper priority regarding work activities related to safety and quality.
The policy should be effectively communicated to all levels of OE management and employees, and reemphasized periodically.
Page.17 of 19
ECTG reviewed thi NSRS raport, currsnt commitments in tha Nuclear Performance Plan concerning tha correctivo action process, NQAM requirements, and the Division of Nuclear Engineering implementing procedure.
ECTG review of the DNE procedure NEP 9.1 " Corrective Action" indicates that DNE has defined and documented a policy to assure that l
operating plants are afforded the proper priority regarding work activities related to safety and quality.
Initial training on the
)
l CAQ process, including the priority for operating plants, has been completed.
Based on the TVA commitments, implementing procedure provisions, and CAQ training, this NSRS item is closed.
j l
(Closed) R-85-08-0E/NUC PR-4, Lack of Engineering Awareness of the i
NCR-FE/ER Process NSRS concluded that some OE engineers were unfamiliar with'the process as a whole and the allowable timeframes for processing NCRs, FEs, and ERs.
NSRS recommended establishment of a formal and effective training program on the OE procedure for initiating and processing NCR-FE/ERs.
CAQ program training requirements, as identified in the NQAM, Section 21.0 " Implementation Requirements," provide for CAQ program training at all sites and for offsite support organizations no later than March 30, 1987.
Based on the verified completion of training, this NSRS item is closed.
(Closed) R-85-08-OE/NUC PR-5, Lack of Timeliness in Initiating and Processing NCR-FE/ERs NSRS stated that NCR SQNNEB8501 was not processed by OE within the timeframes specified by established procedures.
Additionally, NSRS stated it was evident that OE frequently exceeded the specified time requirements for processing NCR-FE/ERs.
It was recommended that the j
necessity of compliance with NCR-FE/ER initiating and processing requirements be emphasized to all involved OE employees.
TVA's commitments to timely and effective corrective actions are outlined in the Nuclear Performance' Plan, Volume I,Section VI, Revision 4, and are documented in the NQAM, Part I, Section 2.16.
The NQAM section establishes timeliness requirements and describes a process of escalation for failure to comply. The CAQ timeliness will be tracked by TROI, and overdue items will be tagged for management attention.
Auditing data concerning the new program's adequacy is not yet available because of the program's recency.
Based on the CAQ program initiation including commitments, documentation, training, tracking, and reporting / auditing provisions, the NSRS item is closed.
Page 18 of 19
l (Closed) R-85-08aOE/NUC PR-6, Failurs of Management to Correct Problems with Timeliness and Responsiveness Involving the NCR-FE/ER Process In the August 1985 report, NSRS concluded that problems with J
timeliness and responsiveness in identifying, documenting, and correcting nonconforming conditions adverse to quality had been identified by audit organizations and recognized by TVA management as a problem as far back as 1980 but were yet to be corrected.
NSRS
{
recommended that improved management controls be established and that the audit activities: be intensified in the areas of NCR-FE/ER procedural compliance.
The TVA Nuclear Performance Plan, Volume I,Section VI.D, commits TVA to several steps to improve its corrective action program and management in this area. These steps include implementation of the new CAQ program, implementation of a single corporate system for tracking CAQs, problem flagging to provide for increased management attention and involvement, and a single program for trending of CAQs. The plan also commits TVA to the necessary reviews and audits to provide measures of the effectiveness of the program.
ECTG verified that Division of Nuclear Quality Assurance has in place the audit module and schedule of audits to include the areas of corrective action procedural compliance.
Based on these corrective
]
actions, the NSRS item is closed.
Attachment J
BFN CATDs:
R-84-19-WBN-01 l
I-84-33-BFN-01
{
R-85-08-OE/NUC PR-01 I
l l
I
')
1 I
I l
l l
l l
l 3
Page 19 of 19 l
T25 870610
- 883 ECTG C.3 Attachment A Page 1 oT 1 Revision 4 V
ECTG Corrective i
Action Tracting Document (CATD)
INITIATION Applicable ECTG Report No.:
NVV8./-
1.
Inunediate Corrective Action Required:. O Yes E -No 2.
Stop WorQeconunended: 0 Yes
[ No 3.
CATD No. C8f-/9-h/5# o/
4.
INITIATION DATE -d987 5.
RESPONSIBLE ORGANIZATION:
U N SeYe h ech 6.
PROBLEM DESCRIPTION: (irQR O NQR _ Come4,6 defrims Afee,reFA/ /4 SCABFWEf886Sb"$/ (gmo/efm eM,*r SCX wi// terreef
/ con WhernserreT io'r,,fi/?ul m & e ^3 fee, lok a Os Yferenfik/ A eJrorc ',
si%J fo 4 5
- M*c7 A.A.Yso% Ly./ *:,:-cu;f.
j 1
j O ATTACHMENTS 7.
PREPARED BY: NAME b dC/J DATE:
G-9 M l
B.
CONCURRENCE: CEG-H
'(L2L,-A h DATE:
6 /ro/ f 7 9.
APPROVAL: ECTG PROGRAM MGR.
I 1 S1/Rh DATE:
/l/d/ A
.l v
'c\\~j CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSEOUT 23.
Approved corrective actions have been verified as~ satisfactorily implemented.
i SIGNATURE IITLE DATE 48697
~
p 6
T Td, 5 6't U 0 1 o oc o ECTG C.3 Attachment A Page 1 of 1 Revision 4 E_ CTG Corrective Action Tract Documents (CATD)
INITIATION Applicable ECTG Report No.-
BFN-NSRS-1 1
Immediate Corrective Action Required:
,,Yes x No 2.
Stop Work Recommended:
Yes x No 3.
CATD No.
I-84-33-BFN-01 4.
INITIATION DATE 6/10/87 5.
RESPONSIBLE ORGANIZATION:
BFN Site Director 6.
PROBLEM DESCRIPTION:
r_ QR _ NQR Prepare and check the isometric and l
support load drawings for EECW and reactor drain and vent systems.
Issue these drawings.
Perform an evaluation of problem N1-110-IR.
J Provide verification documentation suitable for audit (discussed with j
l Eric Frevold).
l 1
ATTACHMENTS
~
7.
PREPARED BY: NAME J-A d d 76t h DATE:
6/10/87 8.
CONCURRENCE:
CEG-H LA 4 AA.,
DATE: 6/10/87 9.
APPROVAL:
ECTG PROGRAM MGR.
( 1 T04ttlh \\
DATE:
&, //J t A Q) j CORRECTIVE ACTION' l
10.
PROPGSED CORRECIIVE ACTION PLAN:
l l
I ATTACHMENTS l
11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER VERIFIC TION AND CLOSE0UT Approved corrective actions have been verified as satisfactorily 13.
implemented SIGNATURE TITLE DATE O
E
T25 870610
- 688 l
ECTG C.3 Attachment A' Page 1 of 1 Revision 4 4
ECTG Corrective Action Track Documents (CATD)
INITIATION Applicable ECTG Report No.:
BFN-NSRS-1 1
Immediate Corrective Action Required: _ Yes x No 2.
Stop Work Recommended:
Yes x No 3.
CATD No.
R-85-08-0E/NUC PR-01 4.
INITIATION DATE 4[9[T7
~
~
5.
RESPONSIBLE ORGANIZATION:
EFN Site Director PROBLEM DESCRIPTION:
XQRt]?NQR DNE criteria defining environmental 6.
qualification by similarity are to be incorporated into BFN procedure, (Note:
or procedure is to state that E0 by similari'ty cannot be used.
the similarity criteria appear in the E.0 Manual in use at SON and WBN.)
ATTACHMENTS s
~
7.
PREPARED BY: NAME.k-M E N, # w DATE:
6/09/87 8.
CONCURRENCE:
CEG-H
//ab & h DATE:
6/09/87
~
9.
APPROVAL:
ECTG PROGRAM MGR.
l # 70]XWp V h DATE:
L/,m/ M t
l~'
G\\
CORRECTIVE ACTION _
10.
PROPOSED COR2ECTIVE ACTION PLAN:
ATTACHMENTS j
~~
11.
PROPOSED BY:
DIRECTOR /MGR:
DATE-DATE:
12.
CONCURRENCE:
CEG-H:
DATE:
ECTG PROGRAM MANAGER VERIFICATION AND CLOSEOUT Approved corrective actions have been verified as satisfactorily 13.
implemented SIGNATURE TITLE DATE l
e