ML20236E273
| ML20236E273 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/29/1987 |
| From: | Walters R, Zwisky D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20236E191 | List: |
| References | |
| 201.6(B), 201.6(B)-R01, 201.6(B)-R1, NUDOCS 8710290149 | |
| Download: ML20236E273 (30) | |
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.TVA EMPLOYEE' CONCERNS. REPORT NUMBER: 201.6(B). I SPECIALLPROGRAM-
' REPORT-TYPE: SEQUOYAH. ELEMENT . REVISION NUMBER: 1
.i TITLE: . INCORPORATION OF REQUIREMENTS'AND-COMMITMENTS IN'0ESIGN.
Traceability of Design Requirements PAGE 1 0F 28 i
REASON FOR REVISION:
.1 . Revised to add Section 10, Corrective Action," and delete CATO 201.6~ 1 I
SQN 01.
l PREPARATION
-PREPARED BY:
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( SIGNATURE /DATF/.
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4EEN REVIEW COMMITTEE:
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SIGNATURE DATE CONCURRENCES ,
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p PDR SRP:
DATE SIGNATURE
- DATE SIGNATURE APPROVED BY:
p.
DATE MANAGER OF NUCLEAR POWER DATE
. ECSP MANAGER CONCURRENCE (FINAL REPORT ONLY) l
- SRP Secretary's signature denotes SRP concurrences are in files.
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e e
'TVA EMPLOYEE CONCERNS -REPORT NUMBER: :201.6(B)
SPECIAL PROGRAM.
REVISION NUMBER: ~l i
'~ PAGE 2 0F.28
- 1. CHARACTERIZATION OF ISSUES:
Cnncerns: Issues:
1-85-128-NPS .
- a. There is a lack of traceability of:
design requirements.
"An individual from BFN wrote.
NSRS expressing his concern that.the control and quality b. Inadequate control of design calcula-of OE's design effort is tions impacts traceability of design inadequate. The CI sent requirements.
several roughly written pages detailing and sum- c. Basic design input is not available.
marizing his evaluation and
. conclusion of three msjor d. Design requirements and the basis of areas: determination of design requirements are not readily available.
(1) Design Calculations, (2) NCR's, and.
(3) Management Policies."
Note: The following issues from.
Issues c.-and d.. stated. these concerns are addressed in Sequoyah
. Note:
here were developed from _a review Element Reports 204.11, 205.1, 205.2, by an evaluation team member 205.3, and 206.1, as indicated.
of the expurgated interview Issues indicated with an asterisk (*) .
file for employee concern were developed from notes generated by' I-85-128-NPS.
the evaluation team when the expurgated file for I-85-128-NPS was reviewed. 1 WI-85-100-037
" Lack of traceability of design Scope of engineering required for requirements. The standard modifications is not identified and answer is, 'it's TVA practice.' no attempt is made to identify CI has no further information, activities for modifications.
Anonymous concern via letter." (204.6)*
WI-85-100-043 Basic design calculations are not "There are problems in design prepared and not documented, calculations, in that some are (205.1 )*
never prepared, some are in.
adequate in scope and quality, There are no procedures to control and some are not stored as and maintain calculations current, quality records. There is (205.2)* l inadequate interface and control of design calculations, Configuration control does not which impacts traceability of exist. (206.1 )
- design requirements. CI has no further information. Some design calculations are never Anonymous concern via letter." prepared, or are inadequate in scope and quality. (205.1) 09540-3 (05/?o/87)
a
.. u TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B)
SPECIAL PROGRAM REVISION NUMBER: 1 I PAGE 3 0F-28 Issues: (continued)
There is inadequate control of
> design. calculations and inadequate interface coordination with design calculations-(e.g., Branch / project).
(205.2)
Some design calculations are not stored as-quality records. (205.3) l
-NO X
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES Identified by Not Applicable )
i Date Not Aeplicable l Document Identifier: Not Applicable
- 3. DOCUMENT N05., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
No specific identifications. l i
'4 -INTERVIEW FILES REVIEWED:
- a. Expurgated file for WI-85-100 was reviewed, and no additional ,
unreviewed information was found.
- b. Expurgated file for I-85-128-NPS was reviewed, and notes were developed by the evaluation team. ,
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
.6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER y
APPLY OR CONTROL IN THIS AREA? 1 I
See Appendix A.
055nD-3 (05/29/R7)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B)
SPECIAL PROGRAM- '
REVISION NUMBER: 1 I PAGE 4 0F 28 i
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT. l See Appendix A.
- 8. EVALUATION PROCESS:
- a. Reviewed management procedures establishing hierarchy of i documents,
- b. Reviewed established Sequoyah program commitments through I FSAR and other hierarchy of documents that define design requirements that govern the design of systems, structures, and components,
to determine policy and procedures for development and I control of design calculations. l 1
- d. Reviewed engineering procedures defining preparation of design input, including those for:
o Calculations o Modifications
- e. Checked engineering procedures for incorporation of traceability requirements.
- f. Reviewed Engineering Department and Project procedures that implement the identified calculation polices for development and control of design calculations. Reviewed the adequacy of !
the procedures,
- g. Reviewed results of audits (e.g., EA, INPO, NRC) to determine if design input is available to support existing design.
- h. Reviewed available transcripts of NRC investigative interviews to gain additional information regarding the concerns,
- i. Compared engineering documents with the program requirements to evaluate traceability of design requirements.
- j. Reviewed the Design Basis Program and the Design Baseline and Verification Program for Sequoyah Plant to determine if the programs adequately address the issues.
)
0554D-3 (05/?9/87)
.. l TVA EMPLOYEE CONCERNS' REPORT NUMBER: 201.6(B) '
SPECIAL PROGRAM REVISION NUMBER: 1 i b PAGE 5 0F 28
- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
01/70 - SQN-QA Manual, through R12, constitutes engineering ~
12/73: design procedures in effect j 09/73 - Division of Engineering Design (EN DES) Engineering 06/85: Procedures (EPs), are in effect 09/17/74: ANSI N45.2.9 on QA records implemented in DE0-EP 1.14, !
R0, (changed to EN DES-EP 1.14, R2, 12/13/76) 06/76: TVA commits to Regulatory Guide 1.64 which endorses ANSI N45.2.ll-1974 1
09/27/80: Operating License (0L) issued for SQN Unit I f 09/15/81: OL issued for'SQN Unit 2 3 04/09/85: TVA Topical Report TVA-TR75-1 A, R8, issued 06/85 - Office of Engineering Procedures (0EPs) are in 06/86: effect; supersede EN DES-EPs ,
08/85: TVA voluntarily shut down SQN Units 1 and 2 because of questions about the environmental qualification of electrical equipment 09/85 to Sequoyah Project Manual (SQEPs) is in effect Present:
09/17/85: NRC requests that TVA submit plans for correcting SQN problems 11/01/85: TVA presents its draft Corporate Nuclear Performance Plan (CNPP) and draft Sequoyah Nuclear Performance Plan (draft) to NRC 12/07/85: TVA receives employee concern WI-85-100-037 12/07/85: TVA receives employee concern WI-85-100-043 i
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I 0559D-3 (05/?9/87) 1
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l i . . . - i TVA EMPLOYEE CONCERNS' REPORT NUMBER: 201.6(B);
'SPECIAL PROGRAM REVISION NUMBER: 1
(( PAGE 6 0F 28
! .i TVA receives employee concern I-85-128-NPS !
02/18/86:
03/10/86: TVA Corporate Nuclear Performance Plan, Volume I, R0, submitted to NRC ,
04/08/86: Design Basis Program for.TVA Plants accepted and ,
adopted (formal design basis document to be captured and maintained) 05/01/86: Formal Design Baseline and Verification Program (DBVP) for Sequoyah, R0, issued l 07/86 to Nuclear Engineering Procedures (NEPs) are in effect; Present: supersede OEPs 07/14/86: Sequoyah Nuclear Performance Plan (SQN-NPP), Volume II revised and issued as R1 07/22/86: TVA CNPP, Volume 1, revised (Rl) 08/13/86: TVA CNPP, Volume 1, revised (R2)
Discussion: I j
9.1 BACKGROUND
i The Sequoyah plant design was begun in the late 1960s when !
compliance witn regulatory requirements was not required to be well documented. The majority of the SQN licensing commitments were made in the late 1960s and early 1970s, and some of the present day regulatory documents are not Sequoyah requirements. It is not necessary to update the Sequoyah l i
plant to include all of the new guidance published by NRC, unless there are specific requirements or commitments to do so.
The issues identified in this element allude to a programmatic deficiency, relative to availability of design requirements and consequently design input, which results in '
a lack of traceability of same. The indication is that the ;
TVA design process is lacking a degree of control over '
engineering records.
I 05500-3 (05/24/87)
6 TVA~ EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B)
SPECIAL PROGRAM-
<' REVISION NUMBER: 1 i 'PAGE 7 0F 28 The f act that documentation rather than hardware is addressed in this element provides some latitude in determining that any necessary corrective measures could be completed during the post-restart activities. There are " checks and balances," such as inspection and testing, which can ensure that necessary safety aspects are evaluated and corrected, as required, on a-case-by-case basis.
9.2 TVA ENGINEERING PROCEDURES The documents that contain procedures to control engineering
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at SQN and their applicable time frames are identified below:
o SQU Quality Assurance Manual through R12 (01/70-12/73) o EN DES Engineering Procedures (Red Book) (09/73-06/85) o Office of Engineering Procedures (0EPs) (06/85-06/86) l o SQN Engineering Project Manual (SQEPs) (09/85 to present) _l o . Nuclear Engineering _ Procedures (NEPs) (07/86 to present) 9.3 DESIGN PROCESS Issues relevant to this element involve the preliminary design phase, the design development phase, production, construction, and operation phases of the design process.
The preliminary design phase provides much of the design input including structures, system interfaces, design criteria, and layout design. At the design development phase, detailed design proceeds on a structure-by-structure basis and system-by-system basis. Design input includes ,
regulations, industry codes and standards, design bases, interface requirements, design criteria, many calculations, design standards, design guides, standard drawings, typical drawings, and standard specifications referenced by design documents.
At the production phase, the design input is used to generate the final' design output documents, such as drawings, specifications, bills of material, and system descriptions, by which the project is built. Design review is conducted during this phase to ensure that the design which was finalized in the design development (or design input) phase is accurately translated into design output documents.
l 05590-3 (05/?9/87)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B) 1 SPECIAL PROGRAM !
REVISION NUMBER: 1 l l PAGE 8 0F 28 At the construction phase, the design output documents are i utilized to construct the final product. Design at this phase involves field observation for conformance to the intent of drawings and specifications, resolution of problems arising during construction and testing, any necessary interpreting of design documents for the constructors, resolving field change requests, and reviewing vendor documents to be provided to operations.
TVA Development of Design Basis The design basis for a TVA nuclear plant is generally developed during the preliminary and the design development ,
phases. :
As indicated by a TVA memorandum (04/08/86) relative to the Design Basis Program (App. A, 5.kk),
"The design basis is a necessary part of the design documentation required for an ;
i operating nuclear plant. Although a design basis for all of the TVA nuclear plants exist [s], it.is not always readily retrievable in a verified form. A need exists for a verified, controlled design basis document (DBD) to be maintained throughout the plant life."
i The design basis establishes design input which is governed by procedures identified in Appendix A.
Records Control Design records, such as the following, have been addressed in many TVA procedures and are defined in Appendix A.
o SQN-QAP-III-1.3, " Preparation and Review of Records Computation" o EN DES-EP 1.14, " Engineering Records - Retention and Storage" o OEP-16, " Design Records Control" o NEP-1.3, " Records Control" L
l l 05590-3 (05/P9/87)
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TVA EMPLOYEE CONCERNS. REPORT NUMBER: 201.6(B)
SPECIAL PROGRAM REVISION NUMBER: 1
..I PAGE 9 0F 28 i
4 SQN'QAP-III-1.2, R1, " Control of Design Documents"'
(12/21/71), while discussing design input documents, such as design criteria'and calculations, did not require them to be part of the permanent records file. The only documents required to be permanent records were design drawings.
TVA policy on records retention in procedure EN.0ES-EP.l.14 requires that records that are essential to determine cause of failures that may be catastrophic or result in high economic loss are considered vital and must be retained.
Attachment No. I to EN DES-EP 1.14, "EN DES Records i Satisfying ANSI N45.2.9 Alternate Remote Duplication Requirements," added at R1 (ll/10/75),-addresses the requirement for certain design input documents-(as well as some design output documents) to be retained as EN DES records which were intended to satisfy the ANSI N45.2.9 alternate remote duplication requirement. Safety Analysis Reports, calculations, and design criteria are among the design input documents to be retained.
9.4 TRACEABILITY (Issue "a") i l '
ANSI /ASME NQA-1-1983 (App. A, 5.k) defines traceability as the ability to trace the history, application, or location of an item and.like items or activities by means of recorded identification.
For purposes of discussing the issues, " traceability" will also be taken to mean maintaining records of engineering documents and revisions from basic design through installation (i.e., maintain design input and design output records).
ANSI N45.2.11 mandates relating final design output back to the source of design input and requires traceability documentation. The records requirements of ANSI N45.2.ll and of ANSI N45.2.9 also apply.
TVA Requirements OEP-16 ( App. A, 5.s) included correspondence, design input, design output, calculations, TVA and OE forms, photographs, and data stored in electronic media as design records with responsibility given to the employees nf OE for proper ;
handling. Design records were referred to as " Office of l Engineering (0E) master file." j l 05590-3 (05/P9/87) !
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TVA EMPLOYEE CONCERNS. REPORT NUMBER: ~201.6(B) 1 I SPECIAL PROGRAM REVISION NUMBER: 1 i
C PAGE 10 0F 28- l The current procedure NEP-1.3 (App. A, 5.x), which supersedes OEP-16, contains similar information.
According to OEP-8'and NEP-5.1, design output documents used to communicate design requirements to organizations.outside :
of Engineering are: q
\
- a. Drawings and Design Change Supplements
- b. Instrument Tabulations
- c. Quality Assurance Lists (Q-Lists) i
- d. Construction Specifications
- e. Requisitions !
- g. S em Dest p ns
- h. Certified Design Specifications
- i. Test Scoping Documents ;
- j. Approved Vendor Documents
- k. Procurement Specifications
- 1. Construction Requirements Manuals !
The evaluation team was able to retrieve previous drawing revisions for use in other Sequoyah Element Reports.
Availability of revised design output documents' through the TVA records system provides evidence that design requirements are traceable through the TVA record system.
Regulations, industry codes and standards, etc., are traceable through application in design input documents, such as the design criteria documents (App. A, S.aa). These regulations, etc., are used in most of various design criteria in the various design criteria volumes. The 1 Construction Specifications (App. A, 5.t) also identify i regulations, etc.
OEP-08 ( App. A, 5.w) identifies a design output document as one that implements the design criteria and specifies the design requirements of systems, their structures, and components. The design output documents are prepared by the Office of Engineering (0E) and issued for the use of .l organizations outside OE. OEP-08 states: "The design basis of these output documents will be traceable to their design inputs." l l
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TVA EMPLOYEE' CONCERNS REPORT NUMBER: 201.6(B)
SPECIAL PROGRAM REVISION NUMBER: 1 1 PAGE 11 0F.28 i
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i Per OEP-06 (App. A, 5.w), " Design input includes laws, regulations, industry codes and standards, design bases, interface requirements, design criterir; and.TVA design standards, design guides, standard dravings, typical l drawings, and standard specifications wuich are referenced by design documents." Procedure OEP-08 scates TVA policy as: !
" Drawings and design change supplements" are a standard means i' of communicating design requirements to organizations outside OE. So, by their very purpose, drawings. include design requirements and represent those design requirements specific to their applications.
OEP-06 states the policy as: " Design criteria documents will I be prepared for all designs and will identify the effective revision of all design inputs and the portions of each design input that are applicable to each desigt."
OEP-08 and NEP-5.1 require the preparer of drawings to include on each drawing or drawing series, a3 appropriate, a i note referencing all design input documents (design criteria, i etc.), calculations,-and construction specifications used in developing the drawing or drawing series. Also, drawings are required to be reviewed by a checker as part of the drawing -
approval cycle. Part of the specific purpose of the checker '
is to ensure correct application of all standard documents which are reproduced or directly referenced on a drawing. ,
-This ensures that the standard drawings are.not misused.
~
In the absence of specifics, engineering procedures adequately address controls necessary to ensure proper representation of design requirements on design / installation drawings. This subject is discussed further in Sequoyah Element Report 204.4 (App. A, 5.xx).
Sequoyah Element Report 201.1 (App. A, 5.ww) addresses l application of regulatory requirements. ;
(
With the design basis input unavailability, even though the information is retrievable from various SQN engineering locations, it appears from the CNPP and SQN NPP that design requirements traceability is fragmented. This is evident by the need for the development of the 080 and from the j objectives of the Design Baseline and Verification Program (DBVP) (App. A, 5.mm). The DBVP states:
05500-3 (05/29/37) 1
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B)'
SPECIAL PROGRAM REVISION NUMBER: 11
'b PAGE 12 0F'28 "The objectives of this program are:
"o To verify the adequacy of the plant modifications made since operating license (OL) to systems, or portions thereof, required to mitigate FSAR, Chapter 15, design basis events 'and 'to provide for safe shutdown of the plant.
"o To provide confidence that these modifications are supported oy engineering analysis and documentation."
"o To provide confidence that these modifications are made in conformance with licensing commitments.
"The essential elements of the overall program are as follows:
"o Verifying and establishing the actual plant configuration.
"o Reconstructing the Design Basis.
(
"o Reviewing and evaluating modifications since OL issuance against the design basis.
"o Performing the required tests or' modifications i developed from this review and evaluation.
"o Issuing revised control room drawings essential for operations."
"These program objectives will be met in two phases. The pre-restart phase of this program will be devoted to compiling data from tests and walkdowns, performing system evaluations, implementing and testing required restart modifications. The post-restart phase will include implementation of the modifications not required for restart, completion of other safety systems evaluations not required for restart, and implemention of corrective actions to the '
other safety systems, as required, and formal revision of control room drawings (i.e., configuration control drawings)."
It should be noted that Subsection 6.2 of ANSI N45.2.9 requires that records storage systems shall accurately retrieve information without undue delay.
l s
05590-3 (05/29/87) l
g' TVA. EMPLOYEE CONCERNS REPORT NUMBER: 201 '.6(B)
SPECIAL PROGRAM-REVISION NUMBER: 1 I PAGE 13 0F 28 The evaluation team believes that full and proper implementation of the DBVP and development of the 0B0 should mitigate lack of traceability of design requirements.
The evaluation team also believes that with the advent of a controlled DBD, the concern advanced in the transcript of NRC investigative inicrview (App. A, 5.bb) pages 168 and 169 regarding the traceability of design requirements should be ;
alleviated.
Summary Even though TVA engineering procedures (e.g., OEP-06 and OEP-16) generally covered this issue, lack of consistent implementation resulted in a lack of traceability of design i requirements, and some design requirements are not readily :
available. However, design requirements and the basis of !
determination of design requirements should be readily available upon successful completion of the DBVP and the -j development of the 080. i 9.5 CONTROL OF DESIGN CALCULATIONS (Issue "b")
Adequacy of design calculations is questioned in Sequoyah j i
Element Reports 205.1 (App. A, 5.zz) and 205.2 (App. A, 5.aaa). The latter concludes:
"The issues of inadequate interface coordination and control of design calculations, in particular those that preceded the SQN operating license, are valid and are supported by the reports, documents, and calculations reviewed by the evaluation team."
It is obvious that design requirements traceability is affected by inadequate calculations. The lack of adequate coordination between branch and project for electrical design changes resulting in inadequately prepared and controlled electrical load calculations, as per finding b of Sequoyah Element Report 205.2, certainly impacts design requirements traceability by not ensuring that all input is included in the calculations. Section III of the Sargent and Lundy Report on SQN Electrical program assessment (App. A, 5.pp) 1 I
identifies some calculations which reflect this condition.
l 0554D-3 (05/29/87) ,
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TVA EMPLOYEE CONCERNS . REPORT NUMBER: 201.6(B) -i SPECIAL PROGRAM REVISION NUMBER: -1 L
N PAGE 14 0F 28
~
Even though TVA engineering procedures (e.g., OEP-07 and OEP-16)' generally covered this issue, lack of. consistent j implementation resulted in inadequate control of design calculations, which impacted traceability of. design requirements. However, the impact on design requirements traceability can be mitigated by implementing measures addressed in Sequoyah Element Report 205.2.
t 9.6 DESIGN BASIS AVAILABILITY (Issue "c") l l
The point of the discussion in Subsection 9.3 regarding the design process is encapsulated in a TVA memorandum 04/08/86 (App. A, 5.kk):
"The design documentation requirements for a nuclear.
operating facility, as required by NRC and ANSI standards, consist of those engineering documents. ;
necessary to properly operate, modify, avaluate safety ,
questions, set and evaluate limiting conditions of operation (LCO), and evaluate any abnornal event in the plant. The design basis is a necessary.part of this l design documentation, and along with det ailed engineering, drawings, specifications, and related documents, is required and must be controlled to ensure all licensing and power generation commitments are maintained." 4 l
The development of the design basis and supporting documentation such as calculations is a generic issue which j must be addressed. This is recognized by TVA in the above referenced memorandum, and the implication is that some basic design input is not readily available.
Further substantiation is discussed in Sequoyah Element Report 213.3 ( App. A,- 5.ddd), in that design criteria documents for communications, overall plant security, instrumentation and controls, and lighting could not be found. Additionally, some design criteria were identified by TVA in the design criteria index for Sequoyah, but were never issued.
i 05590-3 (05/?9/87)
TVA EMPLOYEE CONCERUS- REPORT NUMBER: 201.6(B).
SPECIAL PROGRAM'.
REVISION NUMBER: 1 I PAGE 15 0F 28' Through the CNPP ( App. A, 5.r) and the SQN NPP (App. A, 5.s),
.TVA has recognized the need to generate the necessary design '
basis documents (DBD) discussed in the above TVA memorandum
( App. A, 5.kk) and to establish the DBVP ( App. A, 5.mn).
i The TVA memorandum 04/08/86 (App. A, 5.kk) provides additional description of the DBD program: '
"The concept recommended herein is a top-down
-)
approach in which commitments made to generic upper tier design input documents, commitments nade in licensing documents, design requirements needed to satisfy the' plant safety analysis, and TVA policies and existing design criteria must be ;
captured in either plant-specific design criteria [
or other design input docunents. These design criteria must include, as a minimum, those general design criteria for site, plant, structures, and systems which when adopted by the project manager constitute the DBD for that plant." ;
SQN Engineering Procedure SQEP-29 dated 07/18/86 ( App. A, 5.y), establishes the requirements for a systematic approach 'l to developing a DBD for Sequoyah. It states that the DBD j shall define, establish, and maintain the upper-tier design documentation requirements. The DBD and its subsequent ;
revisions shall be subject to review for approval by the discipline branch chiefs and shall be controlled and maintained.throughout the life of the plant. The scope of ;
this procedure includes both safety-related and t nonsafety-related systems, structures, and components. Only those safety-related systems or portions of systems ;
i identified by SQN-0367-048, " Calculations for SWBIDs," are required to be included in the Restart Design Basis Document, j Section III, Subsection 2.2.3 of the SQN NPP ( App. A, 5.s) l provides a degree of assurance that the DBVP will be controlled so as to ensure achievement of the program objectives:
1 05590-3 (05/29/87) 1
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B)-
t.
SPECIAL PROGRAM '
REVISION NUMBER: _1 I PAGE'16 0F 28
" Independent Review-
"DNE's Engineering Assurance [EA3 will perform an independent oversight review of the Design Baseline and ,
Verification Program. This review will provide added !
assurance that the engineering activities associated with the program are conducted in a technically adequate manner and in accordance with the written procedures prepared specifically for this effort.
" An independent tean of experienced technical 3 personnel will monitor, on a sample basis, the Design Baseline and Verification Program as the project completes its document preparation, document revisions, .
l and/or review. This review will:
o Confirm and validate that engineering activities-are being conducted in accordance with the approved program plan and procedures established for the Design Baseline and Verification Program.
o Confirm functional and technical adequacy of '
g system evaluations and completeness / correctness of supporting documentation.
o Verify that corrective actions resulting from these evaluations have been documented and implemented." !
l '
' This comprehensive program is designed to correct problems caused by the past design and modifications control system.
It reestablishes the plant design basis and establishes a l configuration control system to facilitate appropriate )
engineering input for modifications. (Note: This same l information is contained in the SQN NPP [ App. A, 5.s, Section 2.0].)
To demonstrate effectiveness of EA, the EA Independent Oversight Review Team has moni'ored the DBVP and has ferreted I out certain inadequacies in the design criteria reconciliation as evidenced by an Action Items tabulation j l I originated by the EA Independent Oversight Review Team (App. A, 5.uu). Items noted by EA are tracked to corrective j action completion.
l 05590-3 (05/29/87)
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TVA EMPLOYEE CONCERNS REPORTLNUMBER:' 201.6(B)
FJ . .SPECIAL' PROGRAM REVISION NUMBER: .1-b .PAGE170F28l n
~l f
The NRC conduct' e d special inspections of the DBVP. (App.'A, 5.dd and 5.ee),. including the TVA EA Independent Oversight.
Team activities. From its inspection"( App..: A, 5.ee) .the NRC:
team; concluded'that the' preparations and approach for the.
- program were, in"most cases, in accordance with the program
/ plan,~ subject to some. general comments.. .
Summary Even though TVA engineering procedures (e.g., OEP-06 and OEP-16) generally covered this issue, lack of. consistent.
implementation.resulted in some basic design input not being available. Basic design input should be provided upon successful completion- of the DBVP and the development of the DBD. Attentive maintenance.of the DBD and the design' basis.. .
should ensure continuing availability of accurate' basic. 6 design' input, j 9 . 7- DESIGN. REQUIREMENTS AND THEIR BASES-(Issue "d")
The lack of readily available' design requirements and the
( basis of design requirements is substantiated by the CNPP and-SQN-NPP (App. A, 5.rr and App. A, 5.s)..
As' discussed'in Subsection 9.3, regarding the design process,
.the' evolution of TVA procedures from plant inception to' the present'has exhibited a growing concern for the need to preserve TVA plant design basis documents. The procedures have continually been expanded to develop and enhance.the basis of design requirements.
Improvements to the development of the SQN plant design basis f are noted in the Design Baseline program. j Even though TVA engineering procedures (e.g., OEP-06 and OEP-16) generally covered this issue, lack of consistent implementation resulted in some design requirements and the basis of determination of some design requirements not being readily available. Traceability of design requirements should be provided upon the successful completion of the DBVP, and the DBD is intended to provide, among other things, traceability of design requirements.
J 05590-3 (05/29/87)
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'VA. EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B)-
'~ '
SPECIAL PROGRAM:
< . REVISION NUMBER: .1
.. a
'PAGE 18 0F:28'.
' Findings:
~
^ 'a. - There is 'a;1ack ofl traceability of.some' design requirements.
.. b .1 Inadequate control:of design calculations impacts
" traceability of design requirements. Sequoyah Element Report.
205.2 addresses -measures to mitigate this condition.-
'c.. -Some basic design input is not always readily retrievable.
d.. Some design requirements and the basis of determination of -
-design requirements are not-readily available.
Conclusions:
All issues -identified in the employee concerns are ' valid. However,
- upon. successful completion of the DBVP and DBD, basic design' input and design-requirements should. provide required traceability.
The issue of design requirements traceability can also-be mitigated-L(? Jby implementing. measures addressed in~the~ corrective action plan, TCAB-030 -for Sequoyah ' Element Report 205.2 ( App.' A, 5.aaa) relative to the TVALEssential Calculation Program.
- 10. CO'RRECTIVE ACTION:
TVA' corrective action plan TCAB-039 provided for CATD 201 01 SQN 0.1 )
7
. states the following:-
"The C/R Database program (SQEP 18 R2), Design Basis Program and Design Baseline and Verification Program shall be i comleted as applicable to neet the restart requirements for i eac1 unit at Sequoyah. The post-restart phases for these 1 programs will be completed as schedules are established."
The evaluation team concurs with the TVA corrective action plan.
Completion 'of the post-restart phases of the corrective action for CATD 201.01 SQN 01 (12/16/86) will provide adequate corrective action for findings "a," "c," and "d" included in Section 9 of this report,
-05590-3 (05/29/87)
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- ._ 1 TVA EWLOYEE-CONCERNS REPORT-NUMBER
- .201.6(B) d j
y SPECIAL PROGRAM: . .
, . REVISION NUMBER:- 1 q
$ PAGE 19 0F'28 i
. APPENDIX A
, 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
.a. Title l10 of the Code of. Federal Regulations, Part 50
.(10CFR50), Chapter 1,L Appendix B,'" Quality: Assurance Criteria For Nuclear Powe Plants and Fuel Reprocessing Plants"~
- b. Regulatory Guide 1.29, " Quality Assurance Program Requirements (Design and Construction) " R0, -(06/07/72)
- c. Regulatory Guide 1.33, " Quality Assurance Program :
Requirements (Operations)," R2, (02/78) l d'. Regulatory Guide 1.64,:" Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76) ;
e.- Regulatory Guide .l.88, " Requirements for Collection, Storage,- .!
and' Maintenance of Quality Arsurance Records for Nuclear. ' -)
Power Plants," R2, (10/76) ]
( f. ANSI. N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants"
- g. ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance. of Quality Assurance Records for Nuclear ~ Power-Plant s" i i
- h. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- i. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear' Power Plants" t
- j. ANSI N18.7-1976, '" Administrative Control and Quality Assurances for the Operational Phase of Nuclear Power Plants" I
- k. ANSI /ASME NQA-1-1983 Edition, " Quality Assurance Program l Requirements for Nuclear Facilities" ;
- 1. Seouoyah Preliminary Safety Analysis Report, (PSAR)
- m. Sequoyah Final Safety Analysis Report (FSAR) Updated, through l' Amendment 3 (04/86)
- n. TVA, TR 75-1A, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," R8, (04/09/85) ,
, i 05590-3 (05/29/87)
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SPECIAL PROGRAM
' REVISION NUMBER: -
1
~
.PAGE 20.OF 2'8 w
q
' APPENDIX A (Cont'd)
- o. 'TVA, Nucle'ar Quality Assurance Manual, (NQAM), (11/14/85)
]
p.- Sequoyah Nuclear'. Plant Quality Assurance _ Manual' (SQN .QAM) -
Quality Assurance Procedures -(QAPs) employed in the review of- ,
this element are from Revision ll of the SQN QAM-(and prior).-
and include:
SQN-QAP-III-1.1, R2, " Preparation and Review of Design Criteria for Sequoyah Nuclear Plant," (04/07/71) l SQN-QAP-III-1.3, (No. Rev.) " Preparation, Review and Records of Design Computations," (no date). (Note: Rev. 1 of this' .
l
. procedure is superseded by DED-EP-3.03) ]
c, . . -TVA Office of Engineering Design and Construction'n-(OEDC)
-Quality Assurance Manual, (09/12/75)- l
- r. TVA Corporate Nuclear Performance Plan, Volume I, R2, I (08/13/86)
- s. Sequoyah Nuclear Performance Plan, Volume II, R1, '(07/17/86)-
t
- t. General Construction Specifications Manual. (Index - 12/18/85)
- u. TVA Records Disposition Handbook, Part I, Page I-1, -(1985) j i
- v. ~TVA Division of Engineering Design (EN DES) Engineering Procedures Manual. This evaluation refers to the following:
4 Volume 1, Section 1.0, Category: General Volume 2, Section 3.0, Category: Engineering Volume 3, Section 4.0, Category: Design Volume 4, Section 5.0, Category: Procurement .[
EP 1.14, R0 and " Engineering Records - Retention and EP 1.14, R10 Storage," (05/13/83)
EP 1.28. R7 " Control of Documents Affecting Quality,"
(07/23/84) t i
.05590-3 (05/29/87)
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P SPECIAL' PROGRAM ..
R REVISION NUMBER: 1 L
s
)5 PAGE 21 0F 28.
APPENDIX A=(Cont'd) i
-EP~3.01, R6 " Design Criteria Documents ,- Preparation, 1
- s. '
Review, and Approval," (05/22/84) j l
1 EP ~3.04, R13 "EN DES Construction Specifications -- l Preparation, Review, and Approval," 1 (02/l_4/84) ' ,
g EP 3.09, R3 ' " Design Criteria Diagrams for Fluid Systems- 1
- Preparation, Review, and Approval"- ' :3 (12/14/81) l
[
' EP 3.3 7,' R3 " Codes, Standards, and Other Non-TVA~ i Documents - Filing and Referencing,"'
i l (08/11/83) j
-EP 3.38, R0 " System Description Documents _-
Preparation, Review, and Approval,"
(02/16/83)
T( EP 4.01, R10 " Signatures / Initials for Preparation, Review, and Approval-of EN DES Drawings,"
'(04/25/85). _
EP 4.02, R16 " Engineering Change Notices (ECNs) Before R Licensing - Handling," (07/23/84)-
]
EP 4.11, R1 " Combined-Design Drawings and Project Standard Drawings - Preparation and Use,"'
(07/11/78)
EP 4.12, R5 "EN DES Design Guides and Design Standards
- Preparation, Review, Approval, Distribution, and Revision," (04/15/82) ]
EP 4.14, R3 "EN DES Typical Drawings and Standard )
- Drawings - Preparation, Review, Approval, j
-Distribution, and Revision," (08/10/81) l EP 4.16, R5 " Configuration Control by use of Drawings and Drawing Lists," (11/10/82)
EP 4.18, R4 " Design Change Requests (DCRs) -
Processing, Reviewing, and Approving,"
(05/22/84) 4 l
[
l
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( PAGE 22 0F 28 i
.i
' APPENDIX A (Cont'd) !
EP 4.21, R3 " Revising and Voiding EN DES Engineering Drawings," (10/18/83)
EP 4.39, R3 " Routine Distributing of Prints and Microfilm Aperture Cards for Drawings Under TVA Control," (10/18/83) ,
i EP 5.01, R17 '" Purchase Requisitions - Evaluation of Bids ,
and Recommendation / Rejection of Contract i Award - Revisions to Contracts," (05/23/85)
EP 5.20, R7 " Processing Procurement Requests,"
(11/05/84)
EP _5.30, R6 Standard Format for the Preparation of Procurement Specifications," (07/29/83) !
EP 5.32, R3 " Preparation of Procurement Specifications !
for Civil Items," (05/13/83)
( " Procurement Quality Assurance," (10/26/84) j EP 5.33, R8
- w. TVA Office of Engineering (OE) Procedures Manual, (04/26/85) l OEP-06, R0 " Design Input," (04/26/85) ,
OEP-07, R0 " Calculations," (04/26/85) 0EP-08, R0 " Design Output," (04/26/85) 0EP-09, R0 " Procurement," (04/26/85) 1 OEP-10, R0 " Review," (04/26/85)
OEP-16, R0 " Design Records Control," (04/26/85)
- x. TVA Division of Nuclear Engineering (DNE) Procedures Manual, NEP-1,3, R0 " Records Control," (07/01/86)
NEP-3.2, R0 " Design Input," (07/01/86)
NEP-4.1, R0 "*rocurement," (07/01/86) 1 05590-3 (05/29/87) 1 l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B) l SPECIAL PROGRAM .
REVISION NUMBER: 1
( PAGE 23 0F 28 APPENDIX A (Cont'd)
NEP-5.1, R0 " Design Output," (07/01/86) ;
NEP-5.2, R0 " Review," (07/01/86) !
- y. Sequoyah Engineering Project (SQEP) Project Manual 1 l
SQEP-13, R0 " Procedure for Transitional Design Change Control," (07/25/86) i SQEP-18, R1 " Procedure for Identifying Commitments and Requirements as Source Information for !
Sequoyah Design Criteria Development," j (07/09/86) ,
SQEP-18, R2 " Procedure for Identifying Commitments and Requirements as Source information for Sequoyah Design Criteria Development,
"( Draf t)"
( SQEP-29, R1 " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant,"
(07/18/86)
- z. Sequoyah Nuclear Plant Design Criteria Manual (6 Volumes),
(06/26/86) aa. Sequoyah Nuclear Plant Design Criteria, Volume 1 through Volume 7, Index - R3, (01/30/86) bb. Letter from B. J. Youngblood, NRC, to S. A. White, TVA (B45 860714 832), with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN (06/23/86) l cc. Letter from NRC to S. A. White, TVA, " Report Nos. 50-327/86-27 {
and 50-328/86-27," (L44 860506 542), (A02 860502 002), (04/22/86) !
1 l dd. Letter from NRC to S. A. White, TVA, " Report Nos. 50-327/86-38 l and 50-328/86-38," (09/15/86) l l
ee. Letter from NRC to C. C. Mason, TVA, " Report Nos. 50-327/86-45 l and 50-328/86-45" (10/31/86) i l
05590-3 (05/29/87)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B)
SPECIAL PROGRAM REVISION NUMBER: 1
( PAGE 24 07 28- '
1 APPENDIX A (Cont'd) ff. Letter from Impell to TVA (Attention: Mr. Henry Jones),.
" Design Control Program External Audit Finding Evaluation," ,
(Impell/TVA-86-162), (06/19/86) (TTB 150) l gg. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-180), (06/30/86)- (TTB 150) hh, Letter from Impell to TVA ' Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-197), (07/10/86) (TTB 150) ii. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation," ;
(Impell/TVA-86-233), (07/23/86) (TTB 150) jj. TVA Report: " Assessment of Engineering Design Control for the Browns Ferry Nuclear Plant," by Myer Bender, F. E.
Laurent, E. H. Cole, and R. D. Sabin, (09/85) (TTB 142) ,
( TVA memo from W. C. Drotleff, Jr., to Those Listed, kk. i (R. G. Domer, et al.), " Design Basis Program for TVA Nuclear Plants," (844 860402 007), (04/08/86)
- 11. TVA memo from W. C. Drotleff, to Those Listed (H. L.
f Abercrombie, et al.), " Transition to Division of Nuclear Engineering Procedures," (B05 860410 008), (04/14/86) mm.
TVA memo from D. W. Wilson to Those Listed, (G. Aklu, et al.), "Sequoyah Nuclear Plant - Design Baseline and l
' Verification Program," (B25 860506 020), (05/06/86) i nn. TVA memo from L. L. Jackson to Those Listed (H. L. Abercrombie, et al.), " Institute of Nuclear Power Operations (INPO) Corporate Evaluation Responses,"
(A02 860.13 012), (08/14/86) 8 oo. INP0 Report of Sequoyah Nuclear Plant TVA, February 1984 Evaluation (TTB 156) pp. Sargent and Lundy Final Report, "Sequoyah Nuclear Plant, Nuclear Plant Electrical Calculation Program Assessment,"
(04/08/86) (TTB 101) k 05590-3 (05/29/87)
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l TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6(B) 's SPECIAL PROGRAM REVISION NUMBER: 1 j (1 PAGE 25 0F 28 l APPENDIX A (Cont'd)-
qq. Gilbert / Commonwealth, Inc. Report- No. 2600, " Assessment of Design Control Program for the Sequoyah Nuclear Plant, l Prepared for the Tennessee Valley Authority," (10/85) #
(RFI 538) l i
rr. Gilbert / Commonwealth, Inc. Report No. 2614, "Sequoyah Nuclear !
Plant Modification for Tennessee Valley Authority," (
1 (03/03/86) (RFI 538) )
ss. TVA memo from R. L. Gridley to Those Listed 1 (H. L. Abercrombie, et al.), "Sequoyah Nuclear Performance {
Plan - Volume II - Final Concurrence," (L44 860714 800), j (07/14/86) i tt. TVA memo from J. F. Cox to M. T. Tormay, "Sequoyah Design Basis Program to Support Restart," (B25 860811 100),
(08/11/86) uu. Action Items Originated by the Engineering Assurance 1
-( Independent Oversight Review Team for the Sequoyah Nuclear l Plant Design Baseline and Verification Program - Summary (i Report, prepared by John'Non Weisenstein, (10/22/86) (RFI 714) j vv. Sequoyah Nuclear Plant Standard Practice, SQA0134 " Critical J
Structure}
(01/27/86 Systems,andComponents(CSSC) List,"R8, !
ww. Sequoysh Element Report 201.1, R1, (01/15/87) i xx. Segi.oyah Element Report 204.4, (Prelim), (11/09/86)
I 4
yy. Sequoyah Element Report 204.11, (not issued as of 01/16/87) zz. Sequoyah Element Report 205.1, R3, (12/23/86) aaa. Sequoyah Element Report 205.2,'R2, '
(12/22/86) 1 l
bbb. Sequoyah Element Repcrt 205.3, (not issued as of 01/16/87) l
' l Sequoyah Element Report 206.1, R0, (10/31/86) l ccc. ,
ddd. Enquoyah Element Report 213.,3, R0, (11/18/86)
A 3
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SPECIAL PROGRAM REVISION NUMBER: 1
( PAGE 26 0F 28 !
APPENDIX A_(Cont'd)
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER
. APPLY OR CONTROL IN THIS AREA?
- a. 10CFR50, Appendix B, " Quality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants" _
- b. Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction)," RO, (06/07/72)
- c. Regulatory Guide 1.33," Quality Assurance Program i< requirements (Operations)," R2, (02/78)
- d. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- e. Regulatory Guide 1.88, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," R2, (10/76)
ANSI N45.2-1971, " Quality Assurance Program Requirements for
(_ f. ,
i Nuclear Power Plants"
- g. ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants"
- h. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- i. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
- j. ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"
- k. Sequoyah Final Safety Analysis Report (FSAR) updated through Amendment 3 (04/86)
- 1. TVA Division of Nuclear Engineering, Nuclear Engineering Procedures (NEPs):
NEP-3.2, R0 " Design Input," (07/01/86) j NEP-5.2, R0 " Review," (07/01/86) i '
( Engineering Project (SQEP), Project Manual 1
05590-3 (05/29/87)
}
?
nQ ( '
- [fl ,
I ,
- TVA EMPLOYEE CONCERNS REPORT- NUMBER:-: 201.6(B)
.[\V V. S.'
L 1 SPECIAL' PROGRAM h-- g ! {'I!.
,h b REVISION NUMBER: 1-
\- i4 ,f 43 ;;h, - PAGE 27 0F 28 jpg(11 5
g,d ,.
i) .-
-c !z y g'- APPENDIX A (Cont'd)'
A- ;
'7. LIST itEQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS,'AND OTHER- i
_DFDL3SIONS RELATED TO ELEMENT.
,) e
- a. RFI 502,2 . 08/13/86) t .
- b. Teleco'n, D. Usicky Bechtel, to T. Clift, TVA, . IOM '422,.
, (11/25/86) j b
- c. RFI 749, (J2/03/86)
.,. d. RFI 750, di/04/86) e, TTB,095, (08/20/86), (Response to RFI 502)
.,- oj- '
' TTB 097, (08/19/86), (Response to RFI'502)
T' d. .,
- f.
q .
. h. TTB 156, (l?/b5.(86), (Response to RFI 749)
IN h. TTB 168, (12/09/86), (Response to RFI 750) s
+ f~ ,
.,. i f > 1. RFI 714, (11/11/86)
'r.
t.
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TVA EMPLOYEE CONCERNS . REPORT NUMBER:J 201.6(B)
SPECIAL PROGRAM REVISION NUMBER:. 1 b PAGE 28 0F 28 CATD LIST
.The following CATD identifies and provides corrective action for findings "a," "c," and "d" of this report:
1201.01 SQN 01 - (Issues "a," "c," and ."d";'.12/16/86) '
A copy of the above CATD is included for tracking purposes.
~ The CATD noted below has been deleted from this report.
201 06 SQN 01, deleted 05/29/87
(
l 05590-3 (05/29/87)
\
a .. A . ., ; , ,,
j ,
. 'ECTG C.3'
-Attachment A-
.s. . .,
I -
Page 1 or l.
s\ Revis_lon 2 --A.
, 3 CORRECTIVE o(Tracting Document s
- 4
, INITIATION ,
- j. Corrective Action Required: '
g Yes .O . No ct, Recoassended: 0 Yes
. No..E8/.o/ 34N-e/
4 No '
INITIATION DATE //*%1"% '
'8 PONSIBLE ORGANIZATION: A>A/6 AM4
(.
'6. PROBLEM DESCRIPTION:
' 7M'" 6 MM *ssJ/
QR O NQR
- ' W A'#9tm62nMS MAVC net YST gggy COMR.,6 TWub Pgst. 2dgoe yAN.
(A.) $96P /f,R2 ' 6/A - 449~48.e&d== Ate 4M 3
.'. (L) 09stbH dAKIC PAasm i (c) bes/GN 8456UW6 6 /Ed/MC47?e</ s*d*W u.
i /1/ O ATTACHMENTS
. 7. PREPARED BY: NAME /27.4/M (/7K / DATE: #-r.2 -f(.
- 8. CONCURRENCE: CEG-H ho V Nt t1xMV DATE: / 2. &~- P'4 i' 9. APPROVAL: ECTG PROGRAM MGR.0 B 2/d-dre d. e4 DATE: @eS-//t,
$' s CORRECTIVE ACTION
- 10. ' PROPOSED CORRECTIVE ACTION PLAN:
CI'c W T# 6 bA dfA N 9 W I[d D
-p' $ . - EV /3/G"MD/2 4 A/DVA/I B M 17612 i G O $i l' *
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4 1 l
-t , O ATTACHMENTS 9 11. PROPOSED BY: DIRECTOR /MGR: 4-(8 B A /A, DATE: /J -/S-N-I 12. CONCURREN,CE: CEM-H: DATE:
., 3RP: DATE:
l* ECTG PROGRAM MGR: DATE:
1 !
. VERIFICATION AND CLOSEOUT
- 13. Approved corrective actions have been verified es satisfactorily implemented. I l
-: Xhin. ..
g :
..' . SIGNATURE 7 7' IITLE, i)',"' l
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St:ndard Practica Piga 8
'1 SQA166
,1 Revision 8 Attachment'A ,
)
i ,
Page 1 of 2 -'
i
- ^4Qdigft ave Action Plan of Employee Concern Investigation Tracking Checklist j ,
Number 2Ol 0[ *iCPA/fCMY 2. 0 1. 0 1 % 9 A O l ion Responsible for Corrective Action Plan EX/ Gr I te /2-9-76 CO VE' ACTION. PLAN (CAP)
- 1. Does this report require corrective action? , .
Yes ! ' No
. (If yes, describe corrective action to be taken, if no, provide justification) fff C/f hvAAMM AfM/Am ($MA /W A5 \ hctKd AM/s A'M/An*
sab bwsd Asmut J ym/wrod AVddsn swsu se r:uadixs A4' JAGAcAAtx 19 sMxxr 7Nd 4rrAM fxatretMAfff 4 Anw MW'/*
Ar M4441 YAW. 7;t/s Act AswA' A/" A*'Arts' hw 7Nfff AWifAef JtM l* AM - 423*'A'-tMb A9 kWouldC AFA /cnsws/f#D.
- 2. Identify any lar item / instances and corrective , action taken.
- 3. Will corrective action preclude recurrence of findings? Yes V No V. .4. Dona this report contain findings that are conditions adverse to cualitv (CAQ)
. \,. as defined by AI-12 or NEP 9.1? YES No / ,"
AfDAld
- 6. Which site seytion/ organization is responsible for corrective action?
WS/Ofi/A # .104/ f. Cox
- 7. Is corrective action required for restart? Yes V No (This determinate ~on is to be made using Attachment C of SQA166.)
- 8. P2 zone number for restart corrective action? Zone 9/7/
- 9. Estimate completion date for correction action. ,
Completed By 7/ _k As ' Date /z. -//" #6 ,
Approved By T)E d N '
Date /Z.-/G - @
ECTG Concurrence // Date
. M -
g pt.,,n bV .
( ,
0206S/mit -
m______ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ . _ ... J