ML20237K769
| ML20237K769 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, 05000000 |
| Issue date: | 08/06/1987 |
| From: | Cossett D, Hunt G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18032A532 | List: |
| References | |
| BFN-NSRS-1, BFN-NSRS-1-R03, BFN-NSRS-1-R3, NUDOCS 8709080014 | |
| Download: ML20237K769 (24) | |
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, 1 REPORT NUMBER: BFN-NSRS-1 TVA EMPLOYEE CONCERN SPECIAL PROGRAM REVISION NUMBER: 3 REPORT TYPE:
Browns Ferry Nuclear Plant Element TITLE : Review of Nuclear Safety Review' Staff Restart l I_ tams at Browns Ferry l
REASON FOR REVISION: Revised to show current status (June 1957) of the NSRS items at Browns Ferry,
SUMMARY
GTATEMENT:
The 24 items in this report wlre identified by the Nuclear Safety Review Staff (NSRS) and were assigned to the Employee Concerns Task 0-Group (ECTG) for verification and closure. The verification activities are described in this report.
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.5 hi PREPARATION PREPARED BY: -
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SIGNATURE REVIEWS N
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SIGNATURE" DATE .
SIGNATURE DATE i.
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j N/A DATE UE MANAGER OF NUCLEAR POWER
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EtSPMANA'GER- Q) D CONCURRENCE (FINAL REPORT ONLY) t
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TENNESSEE V LLEY AUTHORITY
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BROWNS FERRY NOOLEAR PLANT EMPLOYEE CONCERNS TASK GROUP j OTHER SITES l: CEG p
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-Browns Ferry Nuclear Plant .NSRS Classical Items-E-
Subcategory:
Element: Review of Nuclear safety Review Staff Restart Items At Browns Ferry f
R Report Number: BFN-NSRS-1 1
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Reviewed By -
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4 m' 7 * ! paview;of Nuclear' Safety Review Staff (NSRS) Open Items Requiring' Resolution at Browns Ferry Nuclear Plant (BFN) prior to Unit 2 Restart, i
.I; Introduction NSRS conducted ~ reviews of. activities at Browns Ferry Nuclear PlantNSRS (BFN) items during itsispan of:o'verview responsibility from 1979 to 1986.
cremaining open in.,1987 have been exam ne i d by the Employee Concerns Task Group (ECTG). 1 j
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 ofl109 issues were considered applicable.to,BFN including 24 requiring resolution prior.to j 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 be
' addressed ~in a subsequent report,.BFN-NSRS-2.
The status of.the 24 NSRS restart issues for BFN is as follows: l I~
{ .y i R-80-05-SQN-4B Configuration Control Closed R-82-08-NPS-10A Management Attention Required.for Closed Resolution (BFN Regulatory Guide 4.15
[f Program and Laboratory Quality' Program)
R-82-08-NPS-10B Management Attention Required (Possible I5 Closed High Radiation Exposure.Following f- Accidental Break of the Main Steam Line) ,.
R-82-08-NPS-10C Issuing of Directives Contrary to TVA
. Closed Commitments (Chemistry Program)
I-83-28-BFN-02 A Change in Radwaste System Operations Closed is Necessary for. Disposal of Spent
% Radioactive Resins I-84-16-BFN-05 Transient Analysis on. System Piping for Closed High Pressure Coolant Injection (HPCI)
R-84-17-NPS-5 Cable Assemblies at BFN with Assigned QA
( Open Level I Fabricated by TVA from QA Level II
/ ~ Parts and No Mechanism to Upgrade QA y l
Classification l
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R-04-17-NPS-lO Commercial Grade Items with QA Levels I and Open II Designations Quality Verification for Commercial Grade Open R-84-17-NPS-ll Items Receipt Inspection of QA Level I and II Closed R-84-17-NPS-12 Items by Field Quality Engineers Clear Identification of Purposes and Uses Optn R-84-19-WBN-01 of All Controlled Documents Instantaneous Trip Settings of the Breakers C1) sed R-84-19-W8N-06 for Motor-Operated Valves Development of Criteria for Cable Tray Fill Open R-84-19-W8N-07 Level and QC Inspection Investigation of Piping and Supports Open I-84-33-BFN-01 l
I-84-34-SQN-03 Availability of the Material Certifi-Open cation and Requirements for Heat Numbers The Adequacy of Dispositions for Identified Open I 06-WBN-01 i Cable Bend Radius Problems s The Adequacy of the Program for Cable Open I-85-06-WBN-02 N Pulling Activities s
1 Voltage Drop & Short Circuit Current I Open I-85-06-WBN-03 Determination & Verification f Inadequate OE Environmental Qualification
- Open R-85-08-OE/NUC PR-1 Procedure for Equipment Qualification by h Similarity (s
a Inadequate OE and NUC PR Procedures for Closed R-85-08-OE/NUC PR-2 Initiating and Processing NCR-FE/ERs
- s Lack of Priority on SQN NCR Initiation O Closed R-85-08-0E/NUC PR-3 Lack of Engineer Awareness of NCR-FE/ER Closed R-85-08-OE/NUC PR-4 CAQR Procedure Lack of Timeliness in Initiating and Closed R-85-08-OE/NUC PR-5 Processing NCR-FE/ERs Failure of Management to Correct Problems Closed R-85-08-OE/NUC PR-6 pi with Timeliness and Responsiveness
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II, Verification _ of NSRS Restart Iteina (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 l
Verify through walkdown of several CSSC systems that physical i configuration agrees with CSSC configuration control drawings !
Correct any deficiencies, and walkdown additional systems if significant problems have been found The original report details were reviewed, as was the Browns Ferry j 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 ;
i- Management Plan (May 27, 1986), BFN Electrical Baseline Drawing List l and Schedule (August 6, 1986), Progress Report - Drawing Discrepancy
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f 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
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y ' personnel concerning numerous aspects of the Unit 2 P2 schedule for baseline activities, and the configuration control program progress y
2 and status, ECTG confirmed that the Configuration Control program is adequately h staffed and scheduled to verify the correction of drawing The following discrepancies required to support. Unit 2 restart.
configuration control activities were verified:
Procedures established for review of ECNs processed since J operating license issuance to ensure systems functional ability E
in accordance with the FSAR q
Procedures established for evaluation of unimplemented and j h partially implemented ECNs !
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Establishment of baseline design (in progress)
M i Review of walkdown/ test data (in progress) ;
Procedures established for performance of DNE Review Board safety evaluations Resolution of identified discrepancies (in progress) kb a
>~ Establishment of a change control process (in progress) i I
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F 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 restart have been! walked down
" 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 L
EQ field. verifications. essentially complete (exceptions include cable bend radius / sidewall pressures and vertical conduits) l J
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 oflthe BFN configuration control effort was verified by' 3
ECTG to go.beyond that recommended by the NSRS R-80-05-SQN-4B L:
report, Based on the verified adequacy of . staffing and schedules to (
implement the BFN configuration control' commitments,-this-~ item is i
- j. Closed, l
(Closed) R-82-08-NPS-10A, Manaqement Attention Required f (BFN Regulatory Guide 4.15 Program i
-and Laboratorv Quality Program).
In the original review, MSRS concluded'that the BFN Regulatory
[ Guide 4.15 Chemistry Quality Assurance program was deficient in its N-procedures, problems.
scope, and responsiveness in correcting'iden ECTG report 30711 an increased level of management attention; reviewed the current status of corrective action to the R-82-08-NP report, and CATD 30711-NPS-2 was issued concerning the NSRSIn identified deficiencies.
plan (March'17, 1987) stated the following:
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Tha goal for the approach presently being pursusd is to davelop 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 l
i was established at the corporate level with the responsibility and authority to develop, implement, and maintain a This program is state-of-the-art chemistry program at TVA.
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 f audit report. l f
ECTG reviewed on June 9, 1987 the chemistry Work Plan Program Plan, Directive, Schedule, and Model plant Chemistry Program Development Additionally, discussions were held with Plan and Schedule. Based on these )
personnel of the Chemistry Program Manager's office. j verification activities, ECTG determined that suitable management '
attention is being given to the program. This item is closed.
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(Closed) R-82-08-NPS-108, Management Attention Required (possible )
Hiqh 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)
NSRS I-131
- act'ivity levels will not exceed 3.2 microcuries/ gram.
recommended that the Technical Specifications be rewritten, or proper >
justification for existing specifications be provided.
to NSRS the TVA's manager of nuclear power provided (L29 840725 891) 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 h,$
during normal operation would restrict the acceptable dose T 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 Given theconsiderations expected type than the primary coolant DEI-131 level.
gi 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.
J Based on the review of technical specification requirements and the J justification for existing specifications, this item is closed.
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, of Directiveg Contrary to TVA !
(Closed) R-82-08-F3PS-10C, IssuinqCommitments (Chemistry program)
')i During the triginal' review, NSRS concluded that procedural contro absent for the~centralt NSRS recommended that nuclear power management analytical procedures. .
direct their attention to this procedure development; ECTG report 30711 reviewed the current status of corrective action to the-R-82-08-NPS report,.In and CATD 30711-NPS-2 was issued concerning response, identified deficiencies.described an overall chemistry program' for TVA (See of March 17., 1987,'
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 D and. Schedule. ' Based on these verification: ffice Chemistry Program Manager s office'.
activities, ECTG determined that the development of TVA central o policy, goals, and objectives for chemistry This itemactivities is closed,is being accomplished in a controlled manner.
(Closed) I-83-28-BFN--02, A Change in Radwaste System Operations is Necessary
[ Resins.
j During a 1983 investigation of resin liners containing excess water, NSRS concluded that BFN's handling of wet solid radioactive waste was not inNS accordance with BFN's FSAR Section 9.3,4.1.
p- the'FSAR description of the solid radioactive waste system, a system ,NSRS d.: change was made which connected the bead and powder resin systems, d not 3- stated that an unreviewed safety question determinationThe (USQD)
Nuclearha D.
been performed for mixing together the two resin types. Re failure to perform a timely USQD in accordance with 10 CFR 50.59.
BFN' corrective actions included performance of a 10CFR 50.59 evaluation, and procedural changes and process controls to prevent recurrence.I h.
excess water in the resin liners. dated October 2, 1984. The NRC closure' Report 50-259, 260,.296/84-37 that the
' included acceptance of the BFN explanation (A27 840817 006) g+ mixing of resin types was not outside the scope of the FSAR description.
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Based on review of the applicable documentation and discussions with the plant personnel, ECTG concluded that the NSRS issue has been F
satis
- addressed. This item is closed, e,
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IorHiqh (Clooed) I-84-16-BFM-05,. Transient Analysis on System Pi9inq Pressure Coolant Iniection (HFCIl NSRS reported that the High Pressure Coolant Injection (HPC had numerous failures. NSRS recommended that, after implementingda of piping and supports.special test 82-11, a Based transient analysis of the sys on the to determine maximum loads from the fluid flow.
supports should be redesigned as required.
analysis, ECTG reviewed the HPCI Abnormal Transient Analysis As' a Report (B45 851202 257) and discussed the issue with BFN personnel, (B45'851008 252),
' result of the BFN analysis and evaluations, Engineering Changewas issued 2015-84)
Notice R23.
(ECN) P5366 (Work PlanHPCI main check valve, FCV 73-45, whi require an inordinately high differential pressure to force open, Thewas replaced for testing reasons not associated with the analysis. d to northernmost strut on support R24, which was damaged, was replace ensure lead capacity.
l Based on the above review activities and BFN actions, ECTG This item is verified that the NSRS recommendations had been implemented.
f': closed.
B (Open) I-84-17-NPS-5, Cable Assemblies at BFN with Assigne parts and No Mechanism to Uparade QA g
Classification NSRS reported that selected cable assemblies at BFN were improperly from The assemblies were manufactured d classified QA level I items.
) parts with a lesser QA level II designation, and no amechanism NSRS recommended program of existe to upgrade the level II designation. procedural development, inspections, and n
identification, replacement,
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. training to assure that cable assemblies in stock, in us assurance specifications, s
h In response to identified problems of the type cited by NSRS, TVA has >
['j established an on-going program for rssuring that commercia items satisfy requirements.
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 CommercialAn Grade Material, overall reportParts, on theor Components for CSSC Application". During this
%q dedication program was issued by ECTG as Report 801.04.
followup review, ECTG reviewed schedules and implementing documents,
(. and discussed present status of the dedication program with cognizant 3;.
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Contractor work on this issue is in process under contracts TV-56071A '
(Wyle) and TV-65375A (Bechtel). A TVA/ contractor. team (tha items-evaluation; group) is committed ~
These activities are
.to have completedl ,
items, and corrective actions as needed. J scheduled on-the DFN P2 Schedule - 7024, " Materials Mana ImprovementLProject. acceptable closure of ECTG CATD 80104-NPS-1 w (0 pen) R-84-17-NPS-10, Commercial Grade Items with OA Levels I an II Desicinatig,ris In the origina1' 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 That practice was contradictory to the purpose of Level I and II.
having QA Level I and II items with considerable QA documentation
' attesting to the items suitability for fulfilling an intended L NSRS-recommended that items purchased with no QA function.
requirements.or no requirements for material certification (COC,
'- . programs should not be purchased with a QA Level I an for use in nuclear power.
f In response to identified problems of the type cited by NSRS, TVA has b established an on-going program for assuring proper control over purchased material and items. items purchased with no QA requirem
, material certification, or from vendors or manufacturers without y
TVA-approved QA programs is described in NQAM, Part I, i Section 2.7.2,
-"Dedication of Commercial Grade Items," and in Browns Ferry S te Director's Standard Practice, BF'SDSP-6.1-02, Revision 1, " Dedication k Program for Commercial Grade Material, Parts, or Components for CSSC Application."
An overall report on the background problems leading up to theDuring this 4 dedication program was issued by FCTG as report 801.04.
E followup review on the NSRS item, ECTG reviewed schedules and A. implementing documents, and' discussed present status of the Id dedication program with Browns Ferry site personnel.
Contractor work on this issue is in process under contracts TV-56071A A TVA/ contractor team (the items (Wyle) and TV-65375A (Bechtel). t t the 3
evaluation group) is committed to have completed prio These activities are items, and corrective actions as needed. " Materials Management scheduled on the BFN P2 ScheduIe - 7024, Implementation of the dedica Improvement Project."
g'^ acceptable closure of ECTG CATD 80104 - NPS-1 will close this item.
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(Open)'R-84-17-WPS-ll, Quality Verification for Cemmercial Grade In'the original report NSRS stated that the use of commercial grade-the items:will function as intended'under all cond 5
for time of th
]Y i
receipt inspection program or audit of the' vendor's-QA programNSR
"- ' commercial grade items.
7 receipt inspc.ction program which includes listing or comparable verification of' i
' ' mechanisms, such as audit of vendor's QA program,etc., for replacement comm certificate of conforma,ce, items that will be' dedicated as basic components
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'In response to iderSified problems of the type cited by NSRS, TVA has h' established an on-going program for assuring that received item satisfy requirements.
p NQAM Part I Section 2.7.2, Revision'1, " Dedication.of Commercial Grade Items", Browns Ferry Sitm Director's Standard Parts,' or Components for C.SSC Application", and Quality Control Revision 1, " Receipt Inspection".
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Inst *"uct' ion-QCI 1;1-04,inci.ude receipt inspection by a-qualified QC
} Requirements nodinspectori, auditing of_ vendors' QA programs, and' ver
- 9. ECTG interviews indicated that:
k' ol certif'icate of conformance.inspr.ctions are'now performed by a QC insp 0- a '3L>. s 7
e 7 'l ' " 4' levdlyl'I, II,-III, h
6 Contrast.or work on this issue is in process under contracts TV-56071A i( (Wylel M ai TV-65375A (Bechtel).'
A TVA/ contractor team (the items
/ evaluatio& group) is committed to have completed prior. to restart the
, g BFN evaluation of $$dalled and; warehoused commercial grade item
'and corrective actbn"as needed.
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/'(' the BFN P2 Schedu k/7024, " Materials Management Impro Project".
k'f s' ECTG as Report 301.'04 3 Implementation'of the dedication program and P-
'acceptablecledeofECiGC6TD80(10"4-NPS-1willclosethisitem.
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(Closed)R-84-17-NPs-12,ReceiptinhoctionofQALevelIandIIi Items by Fjield Quality Enoineers j
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The NSRS report found that TVA did not require use of qualified b inspectors for receipt inspections concerning commercial NSRSgrade items j to be dedicated as basic components in quality equipment.
recomme.nded that receipt. inspections be performed by Field Quality
,g* ' Engineers or othe* inspectors cualified to ANSI N45.2.6.
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TVA i s requirements for qualified inspectors are now provided:in t e Revision 1,
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' Nuclear Quality Assurance Manual, Part III, Section 2.2, t 'j
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" Receipt / Inspection, Handling, and Storage2.6.
'and Spare Parts i d of Materials, items'are qualified to TVA procedures consistent with ANSI N45.
QAM requirements and
.ECTG reviewed the original NSRS report, the NRevision 1, " Receipt Quality Inspection".
Control Instruction QCI 1.1-04, Requirements d now include re qualified QC inspector, auditing of' vendors' ECTGQAinterviews programs, an f
' verification of certificate of conformance. indicated that insp
-100 percent of QA levels I. II, III.
td Based on this review activity, ECTG determined l satisfactorily at.BFN. This issue is closed.
d Uses of
'(Open) R-84-19-WBN-Ol, Clear Identification of Purposes an All Controlled Documents _
In the original report, NSRS identified instances at WBN d where logi and control drawings did not agree with electrical drawings i a termination' lists.
v NSRS item was' assigned by ECTG to all sites for review and correct o E as needed. '
h ECTG's verification activities at BFN included discussio engineering design personnel and revi.ew of Conditions Adverse to i Quality Reports (CAQRs) concerning technical content of BFN c and logic diagrams.
'BFN personnel assigned to the DNE Baseline Project :The BFN stated CAQs that an upgrade to the logic / control drawings is'in process.have The CAQs include NCR BFNEEB 8203, NCR BFNEEB 8411l i I. ;' SCR BFNEEB 8652. "...overall management deficiency identifies root cause as follows:
h '.
1 in design control may have existed at the time of occurrenceCo ,
' .(September, 1974)."
l (B22 070420 019): '
h 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, au defined in Nuclear D-d' Engineering Procedure (NEP)-6.1,3.5, which shall co -
corrective action. . all involved D*~ plant does not agree with the requirements .
drawings shall be revised under an ECN and issued per NEP-6.1.
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- Ths ECTG verification for BFN's .' configuration f Unit 2 con to restart.
implement configuration control commitments Completion in suppo ,
Pending j will close the.NSRS item on logic and control drawings. 1 of the SCR actions is tracked by ECTG CATD R-84-19-WBN-0 . l l
this completion, the NSRS item remaini open.
l (Closed) R-84-19-WBN-06, Instantaneous for Motor-Operated Trip Settings of the Bre Valves (MOVsl instantaneous trip .
, -The original NSRS report for WBN stated thatsettings for i with Engineering Design (EN DES) criteria'and vendorNSCS rec recommendations.
be-set in agreement with the National Electric ECTG'sCode generic(NEC), review and that-WBN documentation reflect the proper values. l tion. DNE L
of the NSRS item assigned the item to all sites for eva ua personnel at Browns Ferry found the item did not apply to BFN.
Circuit breakers with adjustable instantaneous trips are notThe MOVs brea installed on the BFN motor-operated valves.
thermo-magnetic trips and cannot be adjusted.
Based on the BFN review, this NSRS item is closed.
) (0 pen) R-84-19-WBN-07, Development of Criteria for Cable Tra Level and QC Inspection' f
d be.
d L ~In the original review at WBN, NSRS ECTG's conclude ll to provide a basis for Quality Control (QC) inspec 3r ;' sites' including BFN.
ECTG Report CO-10900 " Cable" examined the cable tray fill issu
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At BFNs the issue is extensively Af assigned CATO 10900-NPS-5. documented in SCR BFN EEB 8602 M'
follows:
b Descriptfort Cable weights and outside diameters are not available from a QA Non-QA The origin of the present values is unknown.
h source.
values were used for the calculation of conduit and cableble traytray
- seismic loadings-and for the c.alculation of conduit and ca 2 cross sectional area fill. Qa values are required for these calcul.ations.
Corrective Action:
y A search of the TVA contract files shall be performed to find i
a 1.
%: any available data on cable weights and outside diameters fo all cables which have been installed at BFNP.
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- 2. All cables which cannot have their w2ights and outsido diameters determined by a contract search shall ba walked down to determine this data.
- 3. All data which is gathered in either task I 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 At this time the issue remains open.
NSRS item R-84-19-WBN-07.
Analysis and Supports (Open) I-84-33-BFN-01, Invertiqation of Pipinq Design The original NSRS' report stated that isometric and load supportNSRS drawings are required to accompany each complete analysis.
found many instances at BFN where the drawings w Drawings were not issued for the not cover as-built conditions.
essential equipment cooling water (EECW) and reactor drain and vent systems.
NSRS recommended that all isemetric and support drawings for the EECW and reactor drain and vent systems bc prepared, checked, and issued in conjunction with the completed analysis summary book.
Complete documentation suitable for audit was to be available.
' ECTG verification activities for this item included a re cognizant DNE personnel at BFN.
{
g BFN personnel stated that they thought the required work w complete:
p It was agreed that DNE would verify completion and not available. >
provide closure documentation. ECTG issued CATD R-84-33-BFN-Ol j
y dated June 10, 1907. This item remains open.
d S of the Material Certification and
- (Open) I-84-34-SQN-03, AvailabilityRequirements for Heat Number Sort Printout ,
Entries b
h The original report by NSRS stated that there appear and some ambiguity in the program established to control it.
- s Specifically, NSRS could not conclude with certainty that the SQN Heat Number Sort Printout included only material with acceptable NSRS recommended that a history of the Heat Number certification.
Sort be reconstructed to establish the program's purposes, controls, Following ;
<3 designed functions, actual functions, and data quality. r
" assigned to BFN. !
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The ECTG Report MC-40703, " Material Control, Procedural Control, Haat 26, 1986 examined the SQN status of this Code issue,
" dated SeptemberThe issue status at Browns Ferry The will be at evaluation reported in EC subcategory report MC-40700, " Procedural Control".
BFN is not complete at this time.
Completion of the ECTG 40700 evaluation and subsequent correctiveAt t action if necessary will close this item.
remains open.
of the Dispositions for (Open) I-85-06-WBN-01, The AdequacyIdentified Cable Bond Radius problems In tne 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 ofThe available i RTmin values for multiconductor cables.
as well as the acceptance criteria for sampling used-to justify the The report as-installed conditions, lacked engineering support. l to ,
stated that OC was permitted by OE to bend the cables permanent be any !
a radius of one-half of values which in 1981 were recognized to industry standard for minimum values to which a cable can b permanently bent.the installed condition of these cables at WBN based on "0 f developed" valut_s, NSRS questioned the validity of these values.
Following review for generic applicability, ECTG also initiated f review of this issue at BFN.
b At BFN, the cable bend radius issue 1986.
is the subject ofThis BFN SCR identifies r SCR BFN EEB 8634, dated June 27, cause and planned corrective action as follows:
h j General Construction Specification G-4 did not provide guidance l J A on minimum bend radius because cable bend radius was apparent y
$ not a concern during the time frame of the original construction of the plant.
f[s h A walkdown of the plant shall be performed All triax, to i have been installed through condulets or pull boxes.
h coax, and twinax cables which are installed fo
- conduits that could have a standard bend Those radius identified d.
less tha minimum bend radius of the cable involved.
will be walked down to determine if minimum bend is exce l All triax, coax and twinax cables shall alsoQA belevel walked down to l identify any installations through condulets.
q documentation shall be issued to documer.t any cables which violate the minimum bend radius specified by G-38, h ,
f f
Page 13 of 19 l
l
{ _ __- ___________________ m
ECTG's evaluation of the cable bend radius problem is reported inECTG find construction category report 10900.CATD 10900-NPS-1 was issued to correct identifie the NSRS report.
problems.
Acceptable closures of ECTG At thisCATD ti.no the10900-NPS-1 issue remains and open.SCR BFN EEG 8634 will close the NSRS issue.
of the Program for Cable Pulling (Open) I-85-06-WBN-02, The Adequacy Activities In the July 1985 report, NSRS concluded that OE and OC's td cable pulling programs were inadequate The and in violation report of the accep e stated that industry standards and practices.
Construction Specification G-38 had not defined the method forit had f calculating maximum allowable tensfore for multicable pu Also, the industry considered the side wall pressure Failure to ensureas break link.
a limiting factor for cable pulling activities.that i l for maximum allowa exceeded in any cable pulling operation increased the potent a cable damage (inculation degradation) which is not nec6:sarilyECTG's gener detected visibly or through testing.
f issue found it potentially applicable to BFN.
At Browns Ferry the cable pulling 1986.
issue is the subject ofThis BFN SCR particularly SCR BFN EEB 8631, dated June 27, f addresses sidewall pressure, as follows:
4 Cable sidewall pressure (SWP) calculations were not required in 8 TVA construction specifications G-3 and G-4, electrical design
, standards, or drawings prior to cable installation.
5 The existing cable installations will be evaluated by comparing
'i calculated SWPs of a worst case sample with allowable SWPsIf allowable SWPs d established by SWP tests (E13 860604 001).
@ have been exceeded, they will be corrected by replacing the a cables in accordance with TVA construction Specification G-38 and G-40.
2 ECTG's evaluation of cable pulling activities is reported inThe ECTG finding
[j~
construction category report 10900.CATD 10900-NPS-1 was issue.1 to correct of the NSRS report.
^
identified problems.
Acceptable closures of ECTG At thisCATD 10900-NPS-1 time the issue remainsand open. SCR BFN EEB 8631 will close the NSRS it-aue.
Page 14 of 19
~~- _ _ _ _ _ ~ ~ ~ - - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ '-- - - - - - - _ __
7
,71 ,
. L; i T h 3
'j (Open) I-85-06-WBM-03, Voltaae Drop and Short Circuit Current
.t - Determination _n In NSRS report number I-85-06-WBN-3, the,NSRS recommended that O fperform short circuit'and voltage drop calculations for the d Level 3 power circuits to ensure the adequacy of_the size of-the installeECT !
cable to perform its intended functions.
the open issue found it potentially applicable to BFN. !
ECTG completed a major review of-' Design Calculations
) "Controllof Design at Browns Ferry
,and reported results in ECTG report 205.1'(C Calculations". Key findings include the following:
J TVA established an electrical calculations, program in 1985 to correct and resolve deficiencies found in electrical calculations'at the four nuclear plants. -
l l tions to be
.TVA identified a minimum set of electrical ca cu acom adequate.
The~ performance of the calculations required for BFN Unit restart is.in process.
i, 3'will be prepared prior to restart of each unit.
[ TVA has committed to a long-term calculation program to complete all' calculations required to document the design basis.
ECTG found Nuclear Engineering procedures adequate to' cover d .
g requirements for preparing, CATDsmaintaining,-and were issued tocontrolling (1) track completion the-c electrical calculations. 20501-BFN-1),
g ~
of the essential. calculation program (CATO (3)', address" !
3 (2) supplement ~ scope of the program (CATD 20501-BFN-2), )
}. quality records aspects 1of the program (CATDs An additional CATD.
calculation program (CATD'20501-BFN-5).
(205.05 NPS 04) concerned issuance / implementation of instruc f'Q the' long-term electrical calculation program.
I
(
'I BFN work on the calculations. program is the subject ofAcce 1
[j ' CATDs and SCR BFN EEB 8529 will close this NSRS item at Browns Fer
,c
- n I si l i
Q.
@k W-hf
.4
'0A , I I
Page 15 of 19 i h
A. .
7 i
1
(Open) R-85-08-OE/NUC PR-01, Inadequate OE Environment Qualific Similarity NSRS stated that the OE procedure for environmental qualification but of "ceent allowed qualification by " similarity" "
SQN el- trical e. . ._ e critoria defining what constituted a "simi lar contained no-item, NSRS recommended that these criteria be established and incorporated into the TVA procedures governing environmental be used qualification of electrical equipment, and that the criter previously qualified by similarity, it generically applicable to DFN.
The verification n.i ivities included interviews with cognizant personnel of th.> office of Engineering and Browns Ferry site i t environmental qualification project as well as a review of equ pmen 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 QualificationOffice of E j of Electrical Equipment in Harsh Environment "
3
, EQ personnel indicated that qualification by similarity wa implemented at a site when desired.
3 Q BFN site EQ personnel stated that the NEB-DI-125.01 procedure Thewas issued after the DFN EQ program documentation was prepared.
j procedure was reviewed, and BFN determined that The requirements site EQ managerwere j adequately implemented by the site EQ program. stated that BFN requ
?
qualification by similarity, and that, therefore, the similarity At this time criteria were not needed in the BFN progr am procedures.
N the criteria for qualification by similarity are not included, y ECTG recommends that the issue in of site qualification by similarity procedures by either at BFN be addressed, rather than omitted, j including the criteria for possible use if needed or byCATD stating that 9
.,3 qualification by similarity is not acceptable at BFN.R-85-08-0E p June 9, 1987.
k...
b ei
$1 ,
Page 16 of 19
- ' ' ~ ~ - - - - - ~ - - - - - - - - _ _ _ _ _ _ . _ _ _, _ . _ _ ' - " ' - - - - - - - _ _ _ _ _ , _ _ _ _ _
1 l
A 9 R-85-08-OE/NUC PR-2, Inadequate OE end NUC pR Procedures for '
(Clossd) Initiating and Processinq NCR-FE/ERs NSRS concluded that the OE and ONP procedures fo and engineering reports (ERs) were inadequate for assuring theirNSR timely initiation and processing.
of TVA's program and possible changes to provide for effective j interface between participating TVA organizations, este.t'ishment of y centralized tracking, and significant reduction in the tine 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, Programs." They include a thorough review of the various nuclear programs to ensure that they contain adequate provisions for timely A new Conditions resolution of conditions adverse to quality.
a Adverse to Quality (CAQ) program with centralized tracking and y specific time requirements was to be implemented at all sites by E
March 30, 1987.
.. ECTG verified that the CAQ program is established in the Nuclear y Quality Assurance Manual (NQAM), Part I, Section 2.16, Revision 2.
~
At BFN, CAQ procedcres are in p1 ace and overall site training has 5* been completed. There is a commitment to timeliness The Tracking in the CAQ and Reporting of Open report initiation and processing.
g Items (TROI) computer system has been selected as the single M- corporate system for tracking CAQs. The CAQ timeliness will be N tracked by TROI and overdue items tagged for ma 6 at the time of the ECTG verification activities because of theBased lo
{Q j program's recent implementation. including commitments, docum f I
reporting / auditing provisions, the NSRS item is closed. i f,(
on SQN NCR Initiation l (Closed) R-85-08-0E/NUC pR-03, Lack of priority
(;j NSRS stated that a time period of approximately two months elapsed ,
between the time the assignment was made to evaluate the adequacy of l the SQN containment pressure differential transmitters (CPDTs) until !
the NCR was issued. It was recommended that OE defino and document a l policy to assure that operating plants are afforded the proper {
priority regarding work activities related to safety and quality. (
- .c4 The policy should be effectively communicated to all levels of OE ;
bh 1 management and employees, and reemphasized periodically. I
- t. !
r_
b .
! 4 1
Page 17 of 19 l
E_______________________ _ _ _ _ _ _ _ __J
ECTG reviewed ~the NSRS report, current commitments in ths Nucle:r Performance. Plan concerning the correctivo action process, i NQAM requirements, and the Division of Nuclear Engineering implement ng procedure.
ECTG review of the DNE procedure NEP i k 9.1 " Cor operating plants are af forded the proper priority regard ng worInitial trainin activities related to safety and quality.
CAQ process, including the priority for operating plants, has been Based on the TVA commitments, implementing procedure completed.
provisions, and CAQ training, this NSRS item is closed.
Lack of Engineering Awareness of the_
(Closed) R-85-08-OE/NUC PR-4, NCR-FE/ER process _
NSRS concluded that some OE engineers were unfamiliarNCRs, with the process as a whole and the allowable timeframes for processing FEs, and ERs. NSRS recommended establishment ofi a formal d and effective training program on the OE procedure for initiat ng an processing NCR-FE/ERs.
) CAQ program training requirements, as identified in the NQAM,
)
5 Section 21.0 " Implementation Requirements," prov f
than March 30, 1937.
> Based on the verified completion of training, this NSRS item is closed, g-(Closed) R-85-08-0E/NUC PR-5, NCR-FE/ERs_
Processing Lack of Timeliness in Initiatinq a g
NSRS stated that NCR SQNNEB8501 was not processed Additionally, NSRS by OE within h i Ej! timeframes specified by established procedures. stated f requirements for processing NCR-FE/ERs.
~
necessity of compliance with NCR-FE/ER initiating and processing y requirements be emphasized to all involved OE employees.
a TVA's commitments to timely and effective corrective actions I, are 1
1
@ outlined in the N clear performance Plan, Volume I,Section V l Revision 4, and are documented in the NQAM, part I, Section 2.16. l The NQAM section establishes timeliness requirements and describes a j
process of escalation for failure to comply.
be tracked by TROI, and overdue items wi.ll be tagged for management Auditing data concerning the now program's adequacy is attention. Based on the CAQ not yet available because of the program's recency.
g program ir.itiation including commitments, documentation, training,
- ' ' ' tracking, and reporting / auditing provisions, the NSRS item is closed.
i Page 18 of 19 l
l l
e=
- i -
L' '
.]
L or .
(Clos'ad)'R-85-08-OE/NUC.pR-6,. Failure of Manacement to Correct Problems with Timeliness and j
l' 'r , Responsiveness Involving the NCR-FE/ER_ .
.j Process _
J-In.the, August _.1985 report, NSRS concluded,that problems with timeliness and responsiveness'in identifying, documenting, and j correcting' nonconforming ; conditions adverse to quality had been ]
identified by audit organizations and recognized by TVA management. NSRS as 1 a problem as,far back as 1980 but were yet to be correc the audit activities be' intensified in the areas of NCR-FE/ER.
^
procedural. compliance.
The TVA Nuclear Performance Plan, Volume I,Section VI.0, commits TVA to several steps'to improve its corrective action program and These steps include implementation of the L management new CAQ program,in this area. implementation of a single corporate system for l'
tracking CAQs,. problem flagging to provide for increased management attention and involvement, and a single program for trending of I
CAQs.
'The plan also commits TVA to the necessary reviews ECTG and audits-to provide' measures of the effectiveness of the program. ver audit module and schedule of audits Based 'tx> include on thesethe areas of.
corrective 6
corrective action'prc:edural compliance.
Il actions, the NSRS item is closed.
Attachment _
BFN CATDs: R-84-19-WBN-01 I-84-33-BFN-01
- y. R-85-08-0E/NUC PR-01 5 .
4 y.
8 N
49:
M
- p I
i Page 19 of 19
- _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ _m.___
T2 5- 87 0610 889-l i
h . ,
ECTG C,3 Attachment A 1 Page 3 o'T 1 Revision 4 v'
ECTG Corrective I Action Tractinr, Document 4 (CATD) i INITIATION Applicable ECTC Report No.: N A/SE.3-2
- 1. .Immediate Corrective Action Required:. D Tes F No
- 2. Stop Work, { recommended: O Yes [ No
- 3. . CATD No. C84-/9-L/6# o/ 4 INITIATION DATE - d B 7
- 5. RESPONSIBLE ORGANIZATION: U/x/ 5//c .OJed, 1 I 6. PROBLEM DESCRIPTION: 8 1R O NQR Come4 6 gef4m3 A/ car #a/ /n !
L St.RBFWEEBoc@t. Carno/eh*m o fel,,*e sex witt curcer' \
b- /oca c6seros>uerei nk.,1i17d' m & c 'SYe.n , lo: DJfere.,Mk / hessurc #
'~
sif,d 7'o 4 e * &c.7 AYa sia4M 5,. JI~4 cvi/.
, O ATTACHMENTS
- 7. PREPARED BY: NAME b c" rV f DATE: 69M gJ " B. CONCURRENCE: CEG-H
'(Lef-.4 r 4/- DATE:- 6/ro/P7
'. 9. APPROVAL: ECTG PROGRAM MGR. (I E /J A b DATE: /1bd/ A .
f r(~/
' CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN: -
n.
~
( -
O ATTACHMENTS l rc
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-B: DATE:
E.ww PROGRAM MANAGER DATE:
VERIFICATION AND CLOSE0UT "
i,3 -
- i, r .. 1".l . Approved corrective actions have been verified as'satisf actorily p; implemented.
- ,3 SIGNATURE TITLE DATE r ~
l: 48697 P
E_-____-___=----___ - - - . .
T4O DVUU1V .vd v 1.
i . -
ECTG C.3 Attachment A Page 1 of 1 Revision 4 _ ;
i
_ECTG Corrective Action Track Documents ;
(CATD) 1 ' f e
Applicable ECTG Report No.: BFN-NSRS-1 h.. INITIATION _
1 Immediate Corrective Action. Required: _ Yes r No
- 2. Stop Work Recommended: _ Yes x No 9
- 4. INITIATION DATE 6/10/87
- 3. CATD No. I-84-33-BFN-01 4 5. -RESPONSIBLE ORGANIZATION: r QR _ NQR BFN Site Director Prepare and check the isometric and
'6. PROBLEM DESCRIPTION: )
support load drawinr.s for EECW and rea: tor drain and vent systems.
(- Perform an evaluation of problem N1-110-1R.
Issue these drawints. (discussed with Provide verification documentation suitable for audit tric Frevold).
ATTACHMENTS 4 6/10/87
[
'r-- DATE:
7 '.
PREPARED BY: NAME ,hl u /d/ 76/ L DATE: 6/10/87 d4 0 h.,
- 8. CONCURRENCE: CEG-H DATE: 6 /Alin i ECTG PROGRAM MGR. (1 T04151% \
- s e 5 9. APPROVAL: 3 f CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
d.
w k l
~
ATTACHMENTS
?$ DATE:
- 11. PROPOSED BY: DIRECTOR /MGE: DATE: f 4.' 12. CONCURRENCE: CEG-H: DATE:
ECTG PROGRAM MANAGER
.7,.
VERIFIC5 TION AND CLOSEOUT Y 13. Approved corrective actions have been verified as satisfactorily j implemented k
s 1 l l DATE SIGNATURE TITLE p ,
4 e
l 1
s ~ ,
1 C___.
1 7
T25 870610 6s8 ECTG C.3 Attachment A ,
Pat,e 1 of 1 !
Revision 4 j I
ECTG Cot rective Action Track Documents I (CATD)
~ \
INITIATION Applicable ECTG Report No.: BFN-NSRS-1 l l
>- 1 Inunediate Corrective Action Required: _ Yes x No 2, Stop Work Reconvoended: Yes x No CATD No. R-85-08-0E/NUC PR-01 4. INITIATION DATE 4[9[67 4
3.
- 5. RESPONSIBLE ORGANIZATION: JFNSiteDirector PROBLEM DESCRIPTION: g QR g NQR DNE criteria defining environmental
- 6. 4
- h. qualification by similarity are to be incorporated into BFN procedure. l or procedure is to state that E0 by similarity cannot be used. (Note:
,' the similarity criteria appear in the E0 Manual in use at SON and WBN.)
o _.
ss _
_,_ ATTACHMENTS d 7. PREPARED BY: NAME .b J % / 8 F Nit h -- DATE: 6/09/87
- 8. CONCURRENCE: CEG-H /fA & A./h s ~
DATE: 6/09/87
- 9. APPROVAL: ECTG PROGRAM MGR, if BllW']0 V k DATE: J /,m/ M
@ t~'
Q\ t j CORRECTIVE ACTION y 10. PROPOSED CORRECTIVE ACTION PLAN:
d a -
II 4 it i r ._ l ATTACHMENTS DATE:
- 11. PROPOSED BY: DIRECTOR /MGR:
CEG-H: DATE:
- 12. CONCURRENCE: ;
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSEOUT
- 13. Approved corrective actions have been verified as satisf actorily g ,
implemented SIGNATURE TITLE DATE i , i
. 't
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _