ML20237K798
| ML20237K798 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, 05000000 |
| Issue date: | 07/28/1987 |
| From: | Cossett D, Hunt G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18032A532 | List: |
| References | |
| BFN-NSRS-2, BFN-NSRS-2-R01, BFN-NSRS-2-R1, NUDOCS 8709080028 | |
| Download: ML20237K798 (66) | |
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'~gf-TVA EMPLOYEE CONCERNS' REPORT NUMBER: BFM-NSRS-2 SPECIAL PROGRAM l
" ' REPORT. TYPE: Browns Ferry Nuclear' Plant Element REVISION NUMBER: 1 ;
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. TITLE: Review of Nu'elear Safety Review Staff PAGE 1 OF 56 Non-Restart. Items at Browns Ferry )
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- REASON FOR REVISION
- To incorporate TAS and SRP comments.
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SUMMARY
STATEMENT: The 85 non-restart items in this report were identified by the l Nuclear Safety Review Staff (NSRS) and were assigned to the Employee Concerns Task Group (ECTG) for verification and closure. The verification activities are I
described in this report.
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PREPARATION
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SIGNATURE DATE SIGNATURE" DATE i APPROVED BY: l l.
N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) l "SRO Secretary's signature denotes SRP concurrences are in files. ]
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Subcategory: Browns Ferry Nuclear Plant - NSRS Classical Items 1.
Element: Review of Nuclear Safety Review Staff I Non-Restart Items At' Browns.Forry
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' Report Number: BFN-NSRS-2 3
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REPORT NUMBER: BFN-NSRS-2
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- TVA EMPLOYEE CONCERNS SPECIAL PROGRAM
) REVISION NUMBER: 1 l
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1 Raview of Nuclear Safety Review Staff (NSRS) Non-Restart Items Requiring Resolution at Browns Ferry Nuclear Plant (BFN).
I. Introduction NSRS conducted reviews of activities at Browns Ferry Nuclear Plant (BFN)
NSRS items during its' span of overview responsibility from 1979 to 1986, remaining open in 1987 have been examined by the Employee Concerns Task Group (ECTG).
ECTG examined the status of open NSRS issues including those identified issues which could have specifically for DFN as well asInotherall, asites' total of 109 issues were generic applicability at BFN, considered applicable to BFN including 24 requiring res Unit 2 restart. The status of those restart issues was the subject of a previous report, BFN-NSRS-1, with the status of 85 non-restart issues addressed in this report, BFN-NSRS-2.
The status of the 85 NSRS non-restart issues for GFN is as follows:
Excessive Wire Lifting Practices to Closed 79-09-01-1 Facilitate Testing Excessive Wire Lifting Practices to Closed 79-09-01-2 Facilitate Testing 79-09-01-3 Excessive Wire Lifting Practices to Closed Facilitate Testing Reliability Closed 79-10-03-1 R-80-06-BFN-C Inspection of BFN Reactor Scrams Closed Unreviewed Safety Question Determination Closed R-80-10-BFN-01 Expansion of DPM N73011 Closed R-80-10-BFN-IV A Special Provision for Performing USQDs by Closed R-CJ-10-BFN-IV C EN DES i
R-80-10-BFN-IV E Provide additional Information on Temporary Closed ,
Alteration Control Form l Develop a TVA Policy Regarding Loss of l l Open R-81-02-BFN-01 Safety Function Level of Safety Review of Yellow Creek Open R-81-04-YCN/NPS-Ol l
' Nuclear Plant (YCN)
Inadequacies of EP 4.02 Closed R-81-04-YCN/NPS-02
TVA EMPLO'!EE CONCERNS REPORT NUMBER: BFN-NSRS-2 SPECIAL PROGRAM 0
- REVISION NUMBER: 1 PAGE 3 OF 52
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Closed R-81-08-BFN-08 Increased Scope of OPQA&A Staff Audit' Program Closed R-81-08-BFN-20 Quality Assurance and Quality Control of Operation Activities Closed R-81-08-BFN-41 QA&A Staff Closed R-81-08-BFN-45 Modify and Enforce Special Work Permit (SWP) Procedures-Closed R-81-14-0EDC(BLN)-32 Inadequate Storage of Audit Support Records-Open R-81-14-OEDC(BLN)-41 QAB Auditor Training Closed R-81-31-BFN-01 Inadequate Procedural Control of Operator Training Closed R-81-31-BFN-03 Operator Training Program Inadequacies Open R-82-08-NPS-01 Requirements /Needs/ Activities Matrix
~ 0 pen R-82-08-NPS-02 Quality Assurance Program For Chemistry Activities Open R-82-08-NPS-03 Chemistry Program Organization and Responsibility Review Open R-82-08-NPS-07 Verification of Onsite Radiological Laboratory Analyst (RLA) Training Open R-82-08-NPS-09 Integrated Calibration and Chemical Program Development Closed R-83-08-BLN-2 Development of Cleaning / Flushing Program Control Procedures
. Closed R-83-08-BLN-5 Approval of the 1/8-inch Variance for Acceptable Purge Dam Residual Particle Size Closed I-83-13-NPS-1.a Quality Engineering Branch (QEB) Records Closed I-83-13-NPS-1.b Quality Engineering Branch Records Closed I-83-13-NPS-1.d Quality Engineering Branch Records l
Closed I-83-13-NPS-2 Quality Engineering Branch Records f
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REPORT NUMBER: BFN-MSRS-2
' ' TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 52 Closed R-83-18-NPS-01 Management of the Reorganization of TVA Radiation Protection and Radiological Emergency Planning Program Open R-83-10-NPS-02 Office of Nuclear Power and Licensing Documents Closed R-83-18-NPS-03 Organizational Emphasis of ONP Radiation Protection and Radiological Emergency Preparedness Programs Closed R-83-18-NPS-04 Organizational Placement of Health Physics at Nuclear Plants Closed R-83-10-NPS-05 Health Physics Technical Staff Onsite Closed R-83-10-NPS-06 Radiological Health Staff (RHS) Technical Support Closed I-83-28-BFN-01 Testing of Water Retaining Characteristics of Resin Closed R-84-05-WBN-14 Inspector Certification Records Closed I-84-16-BFN-01 Recognition of the HPCI System as Necessary
' to Maintain the Plant in a Safe Condition NDE Examination of HPCI System Welds in Closed I-84-16-BFN-02
- Piping and Restraints 3
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" Closed I-84-16-DFN-03 Implementation of Special Test 82-11 for Units 1, 2, and 3 h
Closed I-84-16-DFN-04 Implementation of Design Change Roquest BF-DCR-P2040 g
R-84-17-NPS-01A The Procurement System is too Cumbersome Open and Not Well Known by the Users R-84-17-NPS-01B The Procurement System is too Cumbersome Open and Not Well Known by the Users 5 ~
R-84-17-NPS-01C The Procurement System is too Cumbersome Open
- and Not Well Known by the Users R-84-17-NPS-01D The Procurement System is too Cumbersome Open and Not Well Known by the Users l
Closed R-84-17-NPS-04 Insufficient Documentation for Transferred Material l
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+ ,: t i REPORT NUMBER: BFM-NSRS-2i
- - 'C' TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 1-f PAGE 5 OF 52 l
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Closed' R-84-17-NPS-06 BFN Power Stores Clerks Not Trained to j Inspect Material ~
l Open R-84-17-NPS-07 Material With Limited' Shelf. Life Not: .f Reordered in a Timely Manner J i
,R-84-17-NPS-08 Materials Management System (MAMS)
.Open
'ii Under-Utilized R-84-17-NPS-09 10 CFR Part 21 Requirements Incorrectly .
Open Linked to Nuclear Power QA Requirements -
closed I-84-31-BFN-01 Investigation of Potential Significant f Events 1 Closed. I-84-31-BFN-02 Interpretation of Regulatory. Requirements 1 '
Closed I-84-31-BFN-03 Interpretation of Regulatory. Requirements'
' ClosedI-84-31-BFN-04 Commitment to Procedural Controls hl Open .R-84-32-NPS-01 Inadequate TVA. Quality Program p
Open I-84-33-BFN-02 ' Acceptance of Pipe Stresses and/or Support 5,
. Stresses in Excess of Defined Allowable Stresses 4
M Open I-84-33-BFN-03A Written Guidance and Training for <
Performing Piping Analysis g?
- l Written Guidance and Training for !
Open I-84-33-BFN-03B f Performing Piping Analysis _
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I-84-33-BFN-04 Calculations Checked by Non-Independent
[j' Open Inexperienced Personnel Closed I-84-33-BFN-05A Failure to Implement Discrepancy Status
' Tracking System as Defined in Special Engineering Procedure (SEP) 81-02 e Closed I-84-33-BFN-05B Failure to Control Progress of 79-14 Through Accurate Scheduling q q
Failure to Revise SEP 81-02 to Adequately Closed I-84-33-BFN-06 Define 79-14 Program Closed I-84-33-BFN-07 Piping Analysis 1 1
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REPORT NUMBER: BFN-NSRS-2 5 O TVA. EMPLOYEE CONCERNS SPECIAL PROGRAM' REVISION NUMBER: 1 PAGE 6 OF.52 Closed -I-84-33-DFN Failure of QA to Perform Audits and Surveillance of Identified Problem Areas within Piping Analysis Sections
' Completion of TVA Mark Letter Description Closed I-84-34-SQN-02 on the Transfer Requisition Documents q
. Closed I 06-WBN-04 Timely and Responsive Corrective Actions '
for Resolution of Identified Problems-I-85-06-WBN-05 Underdevelopment of Established and Open Documented Limited ~QA Program and' Failure to Incorporate the Established Limited QA Program into NQAM.
Closed R-85-07-NPS-01 Manager of Power and Engineering Appointment'of a Records Manager ,
Lack of Procedu'res for Handling Employee r
b Closed I-85-10-BFN-01 Concerns / Allegations l
. Fourteen Safequards Items Authorities and Responsibilities Not Closed R-82-01-PSS-01 Clearly Defined in Writing' f'~- .
Procedure for' Functioning of Branch Staff 4
Closed R-82-01-PSS-02 Not Defined in Writing Expectations of PSS Management Not Defined' b Closed' R-82-01-PSS-03 i in Writing k
R-82-01-E38-04.B.1 Lack of Guidance and Support to Field Staffs Closed d
E' R-82-01-PSS-04.B.2 Lack of Guidance and Support to Field Staffs Closed !
i R-82-01-PSS-04.C.1 Lack of Guidance and Support'to Field Staffs zi Closed Closed R-82-01-PSS-05 Internal and External Interfaces Not Well
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. Defined k Closed R-82-01-PSS-011 Lack of Document Control p:
p f Closed R-82-01-PSS-12 T&Q Implementing Instruction i
Closed R-82-01-PSS-13 Material Revisions - Material Review and Approval i
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REPORT fBUMBER: DFN-NSRS-2
' TVA EMPLOYEE CONCERNS
,t SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 7 OF 52 R-82-01-PSS-15 Site Security Organization - Administration Closed Responsibilities and Authority Not Clearly Defined R-82-01-PSS-24 Bellefonte Security Facilities Tracking Closed System R-83-16-NPS-01 Revision of the Safeguards Information Closed R-84-06-NPS-01 Revision of the Safeguards Information Closed II. Verification of NSRS Non-Restart Items (Closed) 79-09-01-1, Excessive Wire Liftinq Practices to Facilitate I
Testing In 1978, Division of Power Systems Operations (DPS0) personnel found that testing The Watts Bar Nuclear Plant (WBN) 6900 volt and 480 volt shutdown boards and diesel generator load logic and control boards required a
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large number of wire lifts, test lead installations, and wire determinations. This was contrary to the TVA position in the WBN Final ,
A WBN Design Change l
} Safety Analysis Report (FSAR) question 040.10.
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Request (DCR) to install test blocks to facilitate testing was turned down by the Division of Engineering Design (EN DES) on the basis that the two year testing interval was too infrequent to justify installation of
- NSRS recommended that the Office of Power resubmit The DCR test blocks.
and define where test blocks were needed.
5 I The Division of Power Systems Operations Engineering supervisor at BFN stated that performing tests on the above referenced equipment does not require leads to be lifted in order to provide adequate and accurate test data. He further stated that test equipment used is " state of the art" j
and test procedures can be accomplished without lifting leads. Tests on the devices in question are completed through a series of DPSO System Maintenance Instructions (SMIs) that provide step by step directions for e testing.
Based on review of the applicable procedures and interviews with plant personnel, ECTG concludes that this NSRS issue has been satisfactorily q
addressed. This item is closed.
M (Closed) 79-09-01-2, Excessive Wire Liftinq Practices to Facilitato Testing
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l REPORT NUMBER: BFW-NSRS-2 )
,e TVA EMPLOYEE CONCERNS
.' . SPECIAL PROGRAM REVISION NUMBER: 1 j l
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In 1978 DPSO personnel found that testing WBN 6900 volt and 480 volt shutdown boards and diesel generator logic and control boards required a !
j large number of wire lifts, test lead installations, and wire 1 determinations. The NSRS report stated that EN DES should make provisions to facilitate testing, troubleshooting, and maintenance of the l relays, indicating instruments, transducers, and timers on these boards.
The Division of Power Systems Operations engineering supervisor at BFN stated that performing tests on the above referenced equipment does not '
require leads to be lifted in order to provide adequate and accurate test data. He further stated that test equipment used is " state of the art" and test piocedur,,,s can be accomplished without lifting leads. Tests on i
the devices in question are completed through a series of DPSO System ,
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Maintenance Instructions (SMIs) that provide step by step directions for testing, therefore the NSRS recommendation above does not apply.
Based on review of the applicable procedures and interviews with plant-s
)- personnel, ECTG concludes that this NSRS issue has been satisfactorily I addressed. This item is closed. i k
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(Closed) 79-09-01-3, Excessive Wire liftinq Practices to Facilitate Testing 3' .
The NSRS report concluded that the Division of Nuclear power should review maintenance and surveillance instructions at all nuclear plants to h ensure that TVA policy of minimizing the number of jumpers and/or wire
?, lifts required to facilitate testing or maintenance is being impleme W d. DCRs should describe where and why test blocks are needed. ;
- The Division of power Systems Operations (DPSO) engineering supervisor at j BFN stated that performing tests on the above referenced equipment does not require leads to be lifted in order to provide adequate and accurate test data. He further stated that test equipment used is " state of the Q
art" and test procedures can be accomplished without lifting leads, g Tests on the devices in question are completed through a series of DPSO System Maintenance Instructions (SMIs) that provide step by step
^ directions for testing and do not require 1,> ads to be lifted.
Based on review of the applicable procedures and interviews with plant l
personnel, ECTG concludes that this NSRS issue has been satisfactorily l
y addressed. This item is closed.
k (Closed) 79-10-03-01, Concern for Reliability NSRS stated there were no programmatic aspects of current reliability activities existing. One-time tests did little to establish the ability l of items to perform satisfactorily over their expected service lives.There l
Reliability requirements were not being specified in requisitions. )
was a lack of reliability engineering expertise in TVA.
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TVA EMPLOVEE CONCERWS REPORT NUMBER: BFN-MSRS-2 f
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 9 0F 52 The ECTG investigation indicated that for the past several years, TVA has l had an active reliability program; Division of Nuclear Engineering (DNE) and the former TVA Power Production (P PROD) have had both a steering committee and a working level task force. Both of those groups have been 1 I
actively working. These two divisional efforts have worked closely with qualified reliability persons from organizations such as Electric Power Research Institute (EPRI), Department of Energy (DOE), Electric Energy
. institute (EEI), Nuclear Energy Research Center (NERC), Nuclear Plant Reliability Data System (NPRDS) and with private organizations such as ;
FAMAN and Mechanics Research. In addition, there have been detailed exchanges with other utilities organizations. There have been joint ,
programs with several of these organizations on collecting data and i investigating various systems. Also, TVA has been an associate member of l the United Kingdom Atomic Energy Authority (UKAEA) Systems Reliability l Service for over two years and has access to the Statistical Reporting j
Service (SRS) data bank and counsel with SRS reliability engineers, :
i In addition, industry trending is being accomplished through the {
Institute of Nuclear Power Operations (INPO) by the Nuclear Plant i Reliability Data System (NPRD3). !
The Proventive Maintenance Supervisor at BFN stated that Preventive l Maintenance Instruction (PMI) 6.4 defines a formal written and approved guideline for implementing the Preventive Maintenance Failure Trending 1 l
Program.
l Based on review of the applicable procedures and interviews with plant i personnel, ECTG concludes that this NERS issue has been satisfactorily l addressed. This item is closed.
(Closed) R-80-10-BFN-01, Unreviewed Safety Question Determination On July 9, 1980, at the request of BFN, and because of extended hot t weather, Office of Nuclear Power (ONP) authorized wire lifts to defeat ,
O the automatic tripping function of the cooling tower lift pumps when cold !
water discharge temperature reaches 95oF. This waiver was extended to !
July 21 and again to July 28. In addition, the 95oF temperature trip The ;
requirement in the cold water discharge channel was raised to 97oF. l NSRS evaluation revealed that an unresolved safety question determination l (USQD) had not been conducted for this temporary safety-related alteration of a Final Safety Analysis Report (FSAR) requirement as j
required by 10CFR50.59 paragraph VI.A.
i The NSRS recommended that Division Procedure Manual (DPM) procedure N73011 should be expandec to include a provision to ensure USQDs for {
j proposed alterations that make changes to systems or procedures described I in the FSAR. NSRS further recommended that a copy of the USQD should (
then be forwarded to DNE and Nuclear Safety Review Board (NSRB).
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TVA EMPLOVEE CONCERNS REPORT NUMBER: BFN-NSRS-2 0 I .'"
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 10 0F 52 The ECTG investigation of the issue found that DPM N73011 has been cancelled and replaced' by Preventive Maintenance Instruction (PMI) 8.1.
An Unreviewed-Safety Question Determination (USQD) for temporary
~ alterations made by a Temporary Alteration Control Form (TACF) is required by PMI 8.1 Para. 5.2.3A. In addition, BF 17.18 (USQD) Para' 5.2.6 requires a USQD for changes to any Plant Operational Review Committee (PORC) reviewed instruction that changes a procedural detail l described in the Final Safety Analysis Report (FSAR), Technical i Specification, or any- safety analysis that supports a licensing amendment.
Additionally, Site Director Standard Practice (SDSP) 2.11, Form SOSP-15, f- addresses the USQD requirement for procedura revision. A copy of each USQD is not sent directly to design: however, design is required to review existing TACF's before startup for design impact. A copy.is'not sent to NSRB but one is sent to the plant Nuclear Safety Staff (NSS).
Based on reviews of current applicable procedures, ECTG concludes that
$ this NSRS issue has been satisfactorily addressed. The NSRS item is closed.
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(Closed).R-80-10-BFN-IV A, Expansion of Division Procedure Manual (DPM) N73001 A review'at BFN in 1980 by NSRS noted that DPM N73011, section 7.3, (revision dated Feb aary 14, 1980) did not contain provisions to ensure
.that proposed alterations changing systems'or procedures in the Safety
, Analysis Report (SAR) are reviewed for' safety questions, whether in written chapter material or drawings.
.The' NSRS recommended that DPM N73011 be expanded to include a provision to ensure USQDs for proposed alterations that make. changes to systems or j j'
procedures described in the FSAR. NSRS further recommended that a copy of the USQD should then be forwarded to Division of Engineering Design 3( (EN DES) and NSRB. ,
k An ECTG investigation of the issue revealed that DPM N73011 has been cancelled and replaced by PMI 8.1. A USQD for temporary alterations made by a Temporary Alteration Control Form (TACF) is required by PMI 8.1 Para. 5 2.3A. In addition, BF 17.18 (USQD) Para 5.2.6 requires a USQD for: changes to any Plant Operational Review Committee (PORC) reviewed instruction that changes a procedural detail described in the FSAR, Technical Specification, or any safety analysis that supports a licensing 7'
amendment. Also, procedure SDSP 2.11, Form SOSP-15, addresses the USQD requirement for procedure revision. .,
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A -copy of the USQD is not sent directly to design; however, design is ,
required to review existing TACF's before startup for design impact. A copy is not sent to NSRB but one is sent to the plant NSS.
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4 TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 l- #
SPECIAL PROGRAM REVISION NUMBER: 1.
PAGE 11 OF 52 Based on reviews of current applicable procedures, ECTG concludes that this NSRS issue has been satisfactorily addressed. This NSRS issue is i
closed.
- 1 (Closed) R-80-10-BFN-IVC, Special Provisions for Performing Unreviewed Safety Questions (USQDs) by Division of Enqineerinq Design (EN DES)
In July 1980, the cooling towers at BFN began tripping out at the automatic trip level of 95'F due to high atmospheric temperatures.
A Division of Nuclear Power (NUC PR) authorized' raising of the cooling tower lift pump and switchyard trips to 97'F. This constituted an y unreviewed safety question.
( NSRS recommended that EN DES be responsible for performing an unreviewed g safety question determination (USQD). EN DES should accept verbal p requests from an affected station's Plant Operations Review Committee or
- c. - Office of Nuclear Power (ONP). The verbal request would require e follow--up with a written communication within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, f However it'has been determined that current procedures adequately control the USQD process without EN DES preparing all USQDs.
'An investigation of the issue revealed that Division Procedure Manual g
(DPM) N73011 has been cancelled and replaced by Preventive Maintenance Instruction (PMI) 8.1. A USQD for temporary alterations made by a Temporary Alteration Control Form (TACF) is required by PMI 8.1 Para.
5.2.3A. In addition, Browns Ferry procedure'BF 17.18 (USQD) para 5.2.6 requires a USQD for changes to any Plant Operational Review Committee (PORC) reviewed instruction that changes a procedural detail described in the Final Safety Analysis Report (FSAR), Technical Specification, or any
- safety analysis that supports a licensing amendment.
5 Also, Site Director Standard Practice (SDSP) 2.11, Form SOSP-15, j addresses the USQD requirement for procedure revision, h' A copy of the USQD is not sent directly to design; however, design is y' required to review existing TACF's before startup for design impact. A copy is not sent to NSRB but one is sent to the plant Nuclear Safety Staff (NSS),
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Based on reviews of current applicable procedures, ECTG concludes that d this NSRS issue has been satisfactorily addressed. This NSRS issue is y Closed.
(Closed) R-80-10-BFN-IVE, Provide Additional Information on Temporary Alteration Control Form In July 1980, the cooling towers at BFN began tripping out at the NUC automatic trip level of 95'F due to high atmospheric temperatures.
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b 3, 7 , .TVA EMPLOYEE ~ CONCERNS REPORT NUMBER: BFN-NSRS-2' N SPECIAL PROGRAM REVISION NUMBER: , 1 .j PAGE 12 0F 52 g--
PR authorized ' raising the cooling tower lift pump and switchyard trips to P 97'F. This constituted an unreviewed safety question.
The NSRS recommended that temporary Alteration Control Forms be modified to provide additional.information, including reference connection diagrams used to determine the location points for' jumper installation or.
wire lifts'and add an " operability test required" block.
Investigation of the issue and a review of' current' procedures have s
revealed ~the.following.
- 1. Preventive Maintenance Instruction.(PMI)'B.1,; Para 5.2.3d requires L
that a detailed description of the alteration be put on the Temporary i Alteration Control Form (TACF). It further requires-that all jumpers ,
and wire lifts be. identified by panel number, terminal block, f .-
terminal number,' wire number, device- (i.e. Relay or Switch), and i
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- , - unique identifier.
- 2. . Paragraph 5.2.31 requires.-that two (2) sets of drawing be marked-up' '
< to reflect the temporary alteration-c It also requires that the i
i drawings affected be listed on form PMI-12..
H h~' .3 ,P.aragraph 5.2.3H and Form PMI-12 require listing the tests required to prove operability after the temporary alteration has been installed and after it is removed.
Based on the examination of current procedures, ECTG concludes that this This item is closed.
NSRS issue has been satisfactorily addressed. 'j 4
(Open) R-81-02-DFN-01,' Develop a TVA Policy Regarding Loss of Safety Functions j l
l l' The above referenced NSRS report was initiated at BFN in 1981. The I y, concern stated that improper installation of piping supports in the I
$ Residual Heat Removal (RHR) and Emergency Equipment Cooling Water (EECW) pipe tunnels at BFN resulted in the potential for degradation of safety
?' systems capabilities during earthquake loading. The report further stated that conditions allowed by BFN Technical Specification 3.5.C are-in error.
. The NSRS corrective action recommendation for BFN stated that Division of 7 Nuclear Power (NUC PR) should revise and modify Technical Specification 4
3.5.C whereby a minimum of three (3) EECW pumps will be used instead of u, two (2).
An. investigation of this issue has been conducted by ECTG and the P following information provided.
A lead civil engineer in charge of the 79-14 program has provided t.he l' following information regarding supports in the pipe tunnel. Tha support J
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2
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. SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 13 OF 52 p
inadequacies in the pipe tunnel are being addressed by the 79-14 l
program. Completion of 79-14 is scheduled for cycle six outage, the first outage after restart. Engineering Change Notice (ECN) PO 268, a f' 79-02 working document, has been used to upgrade deficient conditions in the pipe tunnel sufficient to ensure that safety system capabilities are not degraded.
An engineer from Civil Engineering Branch (CED), Division of Nuclear Engineering (DNE), stated that Engineering Change Notice (ECN) PO 260 installed base plates and supports to correct deficient conditions in the
- pipe tunnel. 'He further stated that during cycle six, the pipe tunnel would be reworked under ECN PO 289, a working document of 79-14. Old
', supports will be removed and new supports will be installed during this
)- time.
j In regards to Technical Specification errors involving Residual Heat 3
Removal (RHR) pumps, an Emergency Equipment Cooling Water (EECW) system
- design engineer from the Knoxville Office provided the following 3' information. Operating Instruction EECW OI-67 requires 9000 GPM for RHR system operation for a three (3) unit plant. In addition, design l h critoria for RHR systems, BFN-50-7023, requires 9000 GPM for a three (3) unit plant. DFN's commitment requirement, Nuclear Engineering Branch j (NED) RAC 1057 also requires 9800 GPM for 3 units. Technical Specification 3.5.C, table 3.5-1 requires two (2) pumps for operation of g BFN. However, with each pump having a capacity of only 4500 GPM, the
- Technical Specification appears to be in conflict with operation instructions, design criteria, and NEB commitment requirements.
This issue will remain open and be tracked by CATD R-81-02-BFN-01.
(0 pen) R-81-04-YCN/NPS-01, Level of Safety Review of Yellow Creek Nuclear Plant (YCN)
This NSRS concern was initiated at YCN in 1981, and has been determined l to be generic to BFN. The concern states that no minimum safety review requirements had been established by the Nuclear Engineering Branch
- . (NED). The concern further stated that it had been a policy of NEB to curtail safety reviews when manpower was in short supply or more pressing needs existed.
i The NS9S corrective action recommendation stated that NED should f
establish a written program to ensure that adequate safety reviews, g including all safety-related features, were performed at YCN. It further i ttated that procedures be initiated to provide guidance in performing ;
[ safety reviews. This issue is considered applicable at all sites. J L
' CCTG's investigation shows that ONE Nuclear Engineering Procedures (NEP) 2.1 and 6.1 concerning controls of the ECN Process address the issue of safety reviews at a corporate level; however, procedure NEP 6.6, which l' has not been issued as of this date, will add - Qis issue at the site level.
7 i .1 3
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TVA EMPLOYEE CONCERNS kEPORT NUMBER: BFN-NSRS-2 l
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SFECIAL PROGRAM j
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l PAGE 14 0F 52 i 1 3
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U.
! )
e d.ihisissuewillremainopenuntdlprocedureNEP6.6isimplementedand .
i=
will be tracked by CATD R-81-04-s'CN/NPS-01.
l .
(Closed)R-81-04-YCN/NPSM2,InadequaciesofEP4.02
- 0. f .f The above referenced NSRS report stated that Engineerir.g Design procedure f
EP4.02 concarning the ECN process did not contain sufficient guidance for )
i/ determining which organization needs to approve ECNs. !
,4 l 2:
The corrective action recommended by NSRS was to revise ~P4.02 to include
[
guidance for determining-which organizations are, required to approve 3 ECNs. Further recommendations stated that the. branches should
periodically review all approved ECNs to ensure that proper approvals were obtained,
- j. Procedure EP4.02 was revised and redesignated as OEP-11. OEP-11 wt.s p revised and redesignated as NEP-6.1. NEP-6.1, referenced in engineering !
- l. element report 204.6 (A), addresses ECN responsibilities at a corporate f level, while Browns Ferry engineering procedures BF EP-PI 96.03 addresses y ECN responsibilities for Browns Ferry.
h L o 'Jased on ECTG's investigation of the issue and a review of applicable l . procedures, it is concluded that this issue has been properly addressed, f This NSRS item is closed.
1, (Closed) R-81-08-DFN-08,' Increased Scope of OPQA&A Staff Audit Program L
f'
> ~ Audits required by BF SP 10.1, " Corrective Action Policy" dated February
, J' 1980, were not adequately scoped to give management the assurance that
- the corrective action system was working effectively. The audits did not include the LER Program, for example, which handled the identification, 4 evaluation, correction, and reporting of items identified in the NQAM as 3 significant conditions adverse to quality, f The NSRS corrective action recommendation stated that the Office of Nuclcar Power should increase its scope of OPQA&A Staff Audit Program to lr provide reasonable assurance that corrective action programs are u ,
effective.
l This re:omanendation was acted upon by ONP who developed an Audit Module 23 " Corrective Action" to provide verification of implementation and '
i effectiveness of the CAQ program.
ECTG reviewed the audit module and samples of audit reports concerning corrective action implementation and ef festiveness and found them satisfactory. Based on a review of the program and samples taken, ECTG concludes that this issue has been satisfactorily addressed. The issue is closed. ,
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s TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-WSRS-2
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PAGE 15 OF 52 (Closed) R ' 08-BFN-20,- Quality Assurance and Quality Control of Operational Activities h
L
$' :The NSRS stated that the scope of ONP's' audit program was inadequate and I
' could not ensure conformance to Technical Specifications.
I Thk NSRS Corrective Action Recommendation stated that ONP should increase the scope of the OPQA&A audit program to provide the NSRS reasonable
- assurance that the nuclear facility will be operated within the technical specifications and conditions of the license.
4
- ' ONP's cor rective action response stated that' QAB had developed an audit 4' , ,
plan matrix including scoping documents, and made them an integral part of the quality assurance audit program by either direct inclusion or reference in.a division-level instruction. In addition, QAB included examples of the Audit Plan Matrix and the scoping documents, b: Based on interviews with cognizant personnel and a review of DQA instruction 322 (R2, March 1986) " Standard Audit Module Scoping Document" which indicate that the audit program is adequately scoped, ECTG h
M) .
concludes-that this issue has been satisfactorily addressed. The issue is closed.
.. (Closed) R-81-08-BFN-41, QA & A Staff
}: The NSRS report concluded there were inadequate resources (manpower) on the Audit Program Staff to perform necessary audits or implement the e audit program.
$ The NSRS Corrective Action Recommendation stated that ONP should evaluate l'
the QA audit program to determine whether or not additional personnel resources are needed to effectively implement the program. Action should' 4'" be taken as appropriate to support the result of the evaluation, j 4! During ECTG interviews with cognizant personnel, it was determined that r
the staff of DQA had tripled since this NSRS issue was initiated in
, 1981. In addition, new auditors are being acquired and trained on a continuing-need basis providing adequate resources for DQA.
Based on interviews with DQA supervisors, ECTG concluded that thJ 5 issue s
has been satisfactorily addressed. This NSRS item is closed.
}l (Closed) R-81-08-BFN-45, Modify and Enforce Special Work Permit Procedure 4-NSRS stated that Special Work Permits (SWP) in radiation protection i
\ programs lacked satisfactory implementation. Also, the time sheets for SWPs are not completed properly, nor is data on the time sheets evaluated or used. !
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, TVA EMPLOYEE CONCERNS REPORT NUMBER: BFW-NSRS-2 ;
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REVISION NUMBER: 1 PAGE 16 0F 52 f i
The NSRS Corrective Action recommendation stated the follewing.
- 1. Provide accountability for completed SWPs. '
- 2. Re-evaluate the need for timesheets.
- 3. Modify Browns Ferry Radiological Control Instruction, BFN RCI-9, l
" Radiation Work Permits (RWPs)." {
.I 4 Provide an indoctrination class for personnel using SWP routines i f
- 5. Reinstruct personnel in the requirements for passageway around the unit #1 scram discharge header.
An investigation of the issue showed that items nos. 1, 3, and a part of J
2 were closed by NSRS follow-up review report R-81-29-BFN. Item no. 5
) was closed by NSRS report R-82-06-NPS.
I The remaining part of item no. 2 is covered by BFN RCI-14, " Radiological Incident Determination and Reporting." The purpose of RCI-14 is to ensure that failure to comply w'.th radiological requirements is identified, documented, and promptly reported to management. This
) procedure provides enforcement for failure to comply with RCI-9. The Special Work Permits (SWP) routines have been replaced by RWPs and are covered by RCI-9.
- Item No. 4 is no longer valid since Special Work Permit routines are not used at BFN and all training requirements on SWP routines have been deleted from RCI-9.
The ECTG evaluation has concluded that this NSRS issue has been k satisfactorily addressed. The item is closed.
3 (Closed) R-81-14-0EDC (BLN)-32, Inadequate Storage of Audit Support h Records
- In September 1981, the NSRS investigation found that the storage of audit support records was not in accordance with the requirements of ANSI N45.2.12 and ANSI N45.2.9. Some records were being stored in non fire rated cabinets.
4 The NSRS recommended that a verification of Audit Support Records be h performed to ensure that records kave been transmitted to the MEDs/ ARMS system, currently entitled RIMS.
ECTG's investigation of the issue indicates that Part 3, Section 5.1 Paragraph 4.22 of the NQAM gives direction for retaining records from a corporate level. Tha Site Director Standard Practice BF SDSP 2.5 addresses the issue of record retention at BFN.
}
, j TVA EMPLOYEE CONCERNS REPORT NUMBER: BFW-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 17 OF 52 Additionally, a sampling of the RIMS file was performed to verify that applicable procedures were being effectively implemented.
Based on the satisfactory results achieved from the sampling effort and j nositive interviews with cognizant personnel from the Document Control Section, ECTG concludes the NSRS issue has been properly addressed. This ;
item is closed.
(Open) R-81-14-OEDC (BLN)-41, QAB Auditor Training The above referenced NSRS concern was initiated in 1981 at BLN and was also determined to be generic at BFN. It stated'that EN DES failed to establish a written approved program for training auditors.
The Engineering Assurance (EA) organization within DNE does not have a formal procedure that g;ves direction for training personnel as auditors. However, new auditors within EA are being given auditor training at POTC.
POTC is currently conducting auditor training and at the same' time developing a training standards manual. The manual is scheduled to be issued on 11-29-87 and will' include, in part, the following training courses presently used in POTC training,
- a. QAT 008 - Introduction to Auditing
- b. QAT 002 - Observation Training for QA Audit Personnel
- c. QAT 007 - Codes and Standards
- d. QAT 010 - Advanced Auditing Techniques The NSRS Corrective Action Recommendation suggested that QAB develop an administrative procedure delineating QA training requirements and provisions for management approval of QA auditor training programs.
ECTG recommends that DNE develop a procedure that provides guidance for auditor training, either by using the established POTC training program, or developing a new program unique to DNE auditing requirements.
This issue will remain open until an adequate resolution has been i initiated and implemented. This issue will be tracked by CATD R-81-14-OEDC(BLN)-41 i
f (Closed) R-81-31-BFN-01, Inadequate procedural Control of Operator Traininq l
In 1981, the NSRS conducted an investigation of the above referenced
. concern. The followi g deficiencies were noted.
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- 1. .DFN' standard practice BFA 75 concerning operator training'did not.
implement NRC: requirements in accordance with NRC Letters.
- 2. Plant ~ instructions had not been updated for reactor operators, t- 3. Daily' lesson plans were not' applied.
- 4. Pl' ant Operations Review Committee did not review the adequacy of the operator training program.
i' The'NSRS recommended that daily lesson plans should be applied and the Plant Operations Review Committee should' review the adequacy of the b operator training.
To correct the deficiencies of this issue, operatc- training is being accredited .through the Institute of Nuclear Power (INPO).
In addition.to INPO Accreditation, the BFN Nuclear Performance Plan
[
Volume III has also addressed Operator Training and provides the following program,
- 1. Operator roqualification training has been upgraded significantly in g
- c. response to weaknesses identified by recent NRC requalification examinations.
!- 2. -A comprehensive one-time training program to upgrade all licensed s operators has been initiated.
- 3. ' Training effectiveness is being evaluated by. monitoring individual 4
training performance'through. comprehensive weekly examinations.
followed by a comprehensive final examination.
- 4. All licensed operators will receive a 16-week upgrade training course
before performing license related duties on an operating unit.
h Beginning in 1987, annual requalification training for licensed 4 ' operators was increased from four to at least six weeks to maintain operator knowledge. TVA is currently planning for eight weeks of requalification training.
- 5. To resolve communications problems, increased emphasis is being 4- placed on communications and teamwork in the control room during i h simulator training.
ECTG has concluded that the attention given this issue, which includes a 4
new training facility, certification of instructors, INPO's accreditation I program, and DFN's NPP Vol III, shows that this issue has been
' satisfactorily addressed. This NSRS item is closed. f l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 4 t-
. SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 19 OF 52 (Closed) R-81-31-BFN-03, Operator Training Program Inadequacies
)
The above referenced.NSRS issue was investigated in 1981 and at that time l the following deficiencies were noted.
! 1. The plant standard practice BFA 75 concerning operator training was inadequate.
- 2. The method used to store operator training (. documentation and records was inadequate, k
~
- 3. There was an insufficient number of operator training staff members, a
- 4. The training facility was inadequate.
The NSRS corrective action recommendation stated the following.
l
- 1. Revise BFA75 and keep it up to date
- 2. Review the detailed findings and make corrections as recommended l
- 3. Increase the operator training staff, h'
- 4. Insure Training facilities are adequate.
To correct the deficiencies of this issue, operator training is being accredited through the Institute of Nuclear Power (INPO).
I In addition to INPO accreditation the BFN Nuclear Performance Plan Volume III has also addressed operator training and provides the following program.
$ Operator requalification training has been upgraded significantly in ,
- 1. !
4 response to weaknesses identified by recent NRC requalification b examinations.
- 2. A comprehensive one-time training program to upgrade all licensed operators has been initiated.
Training effectiveness is being evaluated by monitoring individual 3.
l training performance through comprehensive weekly examinations
% followed by a comprehensive final examination. l u
- 4. All licensed operators will receive a 16-week upgrade training course l j
before performing license related duties on an operating unit.
l i
Beginning in 1987, annual requalification training for licensed E operators was increased from four to at least six weeks to maintain l operator knowledge. TVA is currently planning for eight weeks of requalification training. l
TVA EMPLOYEE' CONCERNS REPORT NUMBER: BFN-NSRS-2 4
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REVISION NUMBER: 1 4 I
PAGE 20 OF 52 I l
/5,. To resolve communications problems,' increased emphasis is being f I
placed on communications and teamwork-in the control room during-simulator training.
ECTG has concluded that'the' attention.given this issue, which includes a new training facility, certification of instructors, INPO's accreditation program, .and BFN's NPP Vol III, is adequate. This issue has been satisfactorily addressed and is closed.
(Open) R-82-08-N; 1-01, Requirements /Needs/ Activity Matrix This NSRS issue tates that the.N-OQAM is not self sufficient and relies-
>' on division directives for supplemental detailed requirements. ONP personnel are not comprehensively aware of what commitments and requirements had.been made on behalf of. water quality control or how they I. had'been incorporated into directives and procedures except.for the .
!' requirements of the specific plant technical specifications.
)
-The recommendation supplied by the NSRS stated that a requirements /needs/ activities matrix should be developed to identify and l tabulate all requirements, TVA commitments, and program needs. The g
requirement.should be indexed to the source control documents for P.
tracking and-verification of implementation.
In respoine to this issue, CATD 30711-NPS-02 was initiated to provide h corrective action for deficient conditions. This CATD requested that all
- items in the R-82-08-NPS series reporte (1 thru 10) be reviewed and a method of resolution for deficiencies be provided.
f-b A Corrective Action Plan (CAP) was developed to implement a new program as described in the text of the following cap.
h - In response to the subject NSRS audit report and discussions with 4 persons involved in the audit, it was determined that addressing the
- 10 recommendations, after such a long lapse in time, i t, not practical nor would it address all of todays problems. Instead, a much broader e- approach will be'taken that includes the stated scope and intent of this audit. The goal for the approach presently being pursued is to develop an exceptional program that exceeds in quality all y.
requirements commitments, and industry standards. As a result of the a problems identified in this audit and other audits by NRC, INPO, 2 Quality Assurance, etc. , a Chemistry Program Manager's position was K established at the corporate level with the responsibility and K authority to develop, implement, and maintain a state-of-the-art chemistrv program at TVA. This program is presently under L development and schedules have been submitted for its M.
implementation. When implemented, this program will address the I concerns, both stated and implied, in the subject audit report, s
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REPORT NUMBER: BFM-MSRS-2
- 3 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 21 0F 52 ECTG obtained a copy of the p@jposed program schedule, and further
-investigations ravaaled that a portion of the program had been implemented and the remainder was reasonably following the prescribed schedule. The intent of the newly developed program is to establish and implement a model program at the Sequoyah Nuclear Plant that is " State of the Art" and with its successful completion, to adopt and implement it at l WBN, BFN, and BLN. !
This issue will remain open until CATD 30711-NPS-02 has been completed and the model program at SQN installed at all other TVA Nuclear sites.
(Open) R-82-08-NPS-02, Quality Assurance Prociram for Chemistry Activities lho NSRS investigation in 1982 concluded that the ONP Quality Assurance Program, which provides QA program requirements for all of its facilities performing quality-related activities, was devoid of controls required f for safety-related Chemistry activities. Chemical and radiochemical i program controls were not established to the degree warranted.
The corrective action recommendation made by the NSRS stated that the ONP l Quality Assurance Program should include all safety related chemistry p activities.
s In response to this issue, CATD 30711-NPS-02 was initiated to provide This CATO requested that all 0 corrective action for deficient conditions.
items in the R-82-08-NPS series reports (1 thru 10) be reviewed and a method of resolution for deficiencies be provided.
A Corrective Action Plan (CAP) was developed to implement a new program
- 4. as described in the text of the following CAP. l l
In response to the subject NSRS audit report and discussions with k persons involved in the audit, it was determined that addressing the i
10 recommendations, after such a long lapse in time, is not practical g' nor would it address all of todays problems. Instead, a much broader l
.j approach will be taken that includes the stated scope and intent of '
this audit. The goal for the approach presently being pursued is to develop 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, I Quality Assurance, etc. , a Chemistry Program Manager's position was
- established at the corporate level with the responsibility and l authority to develop, implement, and maintain a state-of-the-art l a l chemistry program at TVA, This program is presently under L
development and schedules have been submitted for its b implementation. When implemented, this program will address the concerns, both stated and implied, in the subject audit report, I
TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-MSRS-2 a
,a SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 22 OF 52 ECTG obtained a copy of the purposed program schedule and further investigations revealed that a portion of the program had been implemented and the remainder was reasonably following the prescribed schedule. .The intent of the newly developed program is to establish and
' implement a model program at the Sequoyah Nuclear Plant that is " state of the art" and with its successful culmination, to adopt and implement it at WBN, BFN, and BLN.
This issue will remain open until CATO 30711-NPS-02 has been completed and the model program at SQN installed at all other TVA Nuclear sites.
L (0 pen) R-82-08-NPS-03, Chemistry Program Organization and Responsibility Review l
e The NSRS issue referenced above indicated that ONP's functional 3 decentralized organization has bred autonomy among its organizational units. Each of the six (6) project control staffs for chemical and f radiochemical control within ONP has duplicated the efforts of the other b
causing confusion as to the responsibility relationship of the CEG with
$ the plants and POTC, p
g TF. Corrective Action Recommendation offered by the NSRS states that ONP P
should reexamine the assignment of authority and responsibility for Chemical and Radiochemical Control to ensure that authority, accountability, and responsibility is specifically defined and delegated.
f In response to this issue, CATD 30711-NPS-02 was initiated to provide corrective action for deficient conditions. This CATD requested that all f
items in the R-82-08-NPS series reports (1 thru 10) be reviewed and a b- method of resolution for deficiencies be provided, A Corrective Action Plan (CAP) was developed to implement a new program h as described in the text of the following CAP.
In response to the subject NSRS audit report and discussions with persons involved in the audit, it was determined that addressing the 10 recommendations, after such a long lapse in time, is not practical nor would it address all of todays problems. Instead, a much broader
+ approach will be taken that includes the stated scope and intent of this audit. The goal for the approach presently being pursued is to a develop an exceptional program that exceeds in quality all U requirements commitments, and industry standards. As a result of the W problems identified in this audit and other audits by NRC, INPO, Quality Assurance, etc., a Chemistry Program Manager's position was established at the corporate level with the responsibility and j
authority to develop, implement, and maintain a state-of-the-art chemistry program at TVA. This program is presently under development and schedules have been submitted for its l
implementation. When implemented, this program will address the concerns, both stated and implied, in the subject audit report.
TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2
. t
- SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 23 OF 52 ECTG obtained a copy of the porbosed program schedule, and further
= investigations r .ealed that a portion of the program had been implemented and L.. remainder was reasonably following the prescribed schedule. The intent of the newly developed program is to establish and implement a model program at the Sequoyah Nuclear Plant that is " state of the art" and with its successful culmination, to adopt and implement it at WBN, BFN, and BLN.
This issue will remain open until CATD 30711-NPS-02 has been completed and the model program at SQN installed at all other TVA Nuclear sites.
J (Open) R-82-08-NPS-07, Verification of Onsite Radiochemical Igboratory i Analyst (RLA) Training This NSRS issue states that no onsite involvement or program i effectiveness appraisals are being accomplished in the area of RLA 4 training by the Nuclear Central Office Training Branch. There is some 1
indication that the training program breaks down at the plant level.
d The NSRS corrective action recommendation suggested that the NCO training
) branch should assess en site RLA training activities at periodic intervals. ,
l 3
In response to this issue, CATD 30711-NPS-02 was initiated to provide S corrective action for deficient conditions. This CATO requested that all items in the R-82-08-NPS series reports (1 thru 10) be reviewed and a method of resolution for deficiencies be provided.
4 3
i A Corrective Action Plan (CAP) was developed to implement a new program o as described in the text of the following CAP.
7 In response to the subject NSRS audit report and discussions with persons involved in the audit, it was determined that addressing the
- 10 recommendations, after such a long lapse in time, is not practical 7 nor would it address all of todays problems. Instead, a much broader approach will be taken that includes the stated scope and intent of this audit. The goal for the approach presently being pursued is to develop an exceptional program that exceeds in quality all requirements commitments, and industry standards. As a result of the problems identified in this audit and other audits by NRC, INPO, Quality Assurance, etc. , a Chemistry Program Manager's position was established at the corporate level with the responsibility and authority to develop, implement, and maintain a state-of-the-art w
chemistry program at TVA. This program is presently under development and schedules have been submitted for its implementation. When implemented, this program will address the concerns, both stated and implied, in the subject audit report.
8 TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 24 OF 52. q ECTG obtainedla: copy of the purposed program schedule,'and further investigations revealed that:a portion of'the program had been implemented and the. remainder was reasonably following the prescribed 1 3
schedule. The intent of the. newly developed program is to establish and-
' implement a'model; program at the Sequoyah Nuclear, Plant that is " state of ,
the art" and with its successful culmination,.to adopt and. implement it-at WBN, BFN, and'DLN.
This issue will remain open until CATD 30711-NPS-02 has been completed.
and the' model program at SQN installed at all' other TVA Nuclear. sites.
-(Open)-R-82-08-NPS-09, Inteqrated Calibration and Chemical Program Development
'This issue was investigated in 1982 by NSRS. The report concluded that even though CLS has established controls for its M&TE calibration program,' formal controls for the safety-related chemical support functions have not been established. .
l.
The NSRS corrective action recommendation stated that CLS should expand l: the formal controls to cover the chemistry and.other quality-affecting activities to define the laboratory's QA responsibilities'to ONP.
l In response to this issue, CATD 30711-NPS-02 was initiated to provide corrective action for deficient conditions. -This CATD requested that all' l
items in the R-82-08-NPS series reports (1 thru 10) be reviewed and a method of resolution for deficiencies be provided.
.4 s' A Corrective Action Plan (CAP) was developed to implement a new program I as described in the text of the following CAP.
j- In response to the subject NSRS. audit report and discussions with persons involved in the audit, it was determined that addressing the 10 recommendations, after such a long lapse in time, is'not practical
[ Instead, a much broader
- nor would it address all of todays problems. .
approach will be taken that includes the stated scope and intent of' C this audit. The goal for the approach presently being pursued is to develop an exceptional program that exceeds i'n quality all d requirements commitments, and industry standards. As a result.of the
'- problems identified in this audit and other audits by NRC, INPO,
- Quality Assurance, etc., a Chemistry program Manager's position was t established at the corporate level with the responsibility and
( authority to develop, implement, and maintain a state-of-the-art i chemistry program at TVA. This program is presently under i development and schedules have been submitted for its
- l. implementation. When implemented, this program will address the concerns, both stated and implied, in the subject audit report.
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PAGE 25 OF 52 i
ECTG obtained a copy of the purposed program schedule, and further l investigations revealed that a portion of the program had been implemented and the remainder was reasonably following the prescribed ;
schedule. The intent of the newly developed program is to establish and i implement a model program at the Sequoyah Nuclear Plant that is " state of i the art" and with its successful culmination, to adopt and implement it l at WBN, DFN, and DLN. j This issue will remain open until CATD 30711-NPS-02 has been completed and the model program at SQN installed at all other TVA Nuclear sites.
t
- 1 (Closed) R-83-08-BLN-2, Development of Cleaninq/ Flushing program Control j Procedures The cleaning / flushing program for safety-related systems at the BLN site is governed by the requirements of NRC Regulatory Guide (RG) 1.37 which endorses ANSI N45.2.1 1973, " Cleaning of Fluid Systems and Associated
) Components During Construction Phase of Nuclear Power Plants." The requirements specified in these documents were to be incorporated in OE-generated documents G-39 " Cleaning During Fabrication of Fluid
} Handling Ccmponents" and NAM-891 " Chemical Cleaning Instructions for a
. Piping Systems for Bellefonte Nuclear Plant." Not all of the h' requirements of the RG and ANSI standard had been incorporated into G-39 and NAM-891 and the documents were very general in nature. As a rs.sult, j the site-generated procedure, BNP-CTp-6.1, "C19aning and Flushing of Systems" and the construction test packages did not meet all the requirements of RG 1.37 and ANSI N45.2.1-1973 and did not contain sufficient detsil to provide adequate guidance for inexperienced personnel to allow development of an acceptable flushing program.
W .
NSRS recommended that OE review RG 1.37, ANSI N45.2.1-1973, other documents containing TVA commitments, and the details of the NSRS reports l and incorporate the programmatic requirements and applicable g recommendations into G-39 and N4M-891 to ensure that responsibilities, 4 technical requirements, documentation and records, training, and adequate program test controls were defined. NSRS also recommended that the site 2 review the site-generated procedures, OC test packages, and the flushing program to ensure conformance to the OE-generated documents with specific emphasis on acceptance criteria and adequate details in each system test package for controlling the accomplishment of the activity and documenting the results.
h The corrective action for this NSRS finding was completed in early 1984
. and a response provided to ECTG by the DNE office in Knoxville on June 4, 1987. The response stated that General Construction Specification C-39 was revised (Revision No. 6 effective 2-15-84) to
address the NSRS finding that TVA's Cleaning / Flushing procedures did not contain all the requirements of ANSI 2.1-1973. The principal construction test procedures which implement G-39 are reviewed by DNE each time they are revised for compliance with G-39 requirements.
l
( '[ TVA EMPLOYEE CONCERNS REPORT NUMBE'R: .BFN-MSRS-2 h: ; i SPECIAL PROGRAM i REVISIOiJ NUMBER: 1 o PAGE 26 OF 52 Additionally,. cognizant personnel have' stated 1 that this'. issue applied only.to BLN and is not applicable to other sites.
Based.on interviews with cognizant personnel'and a. review of MIE-provided documents, ECTG concludes that this NSRS issue has been satisfactorily addressed. ~This issue is closed.
l 1
'# (Closed) R-83-08-BLN-5, Approval of the 1/8-inch Variance for' Acceptable purge Dam Residual Particle Size.
l NSRS conducted ~a review at Bellefonte Nuclear plant (BLN) concerning piping system flushing activities covered by. requirements of~ ANSI-
- j. N45.2.1-1973. This standard permits the allowable size of purge dam material to be no greater than 1/32 inch. The implementing document for these. activities is General Construction Specification G-39. This issue.
was considered generic to Browns Ferry Nuclear Plant (BFN).
NSRS'noted that a' variance had been granted by EN DES to relax the allowable size from 1/32' inch to 1/8 inch. This.is contrary to G-39 Specification and ANSI Standard N45.2.1-1973.
b.
NSRS recommended that if the variance was not approved, EN DES must evaluate the flushing program and determine'the adequacy of.the program
[. for.further flushing and the acceptability of systems previously flushed to the 1/8 inch acceptance criteria.
{'
If the variance is approved by the NRC, an instruction should be prepared' and ' implemented -for classifying and measuring particulate materials and documenting the results.to ensure that the 1/8 inch acceptance criteria is applied only.-to properly' identified and measured purge dam materials.
Since BFN is also committed to ANSI N45.2.1-1973 and uses G-39'
- Specification this issue was considered to have generic implications.
( Discussions with cognizant personnel indicates that this issue applies h only to BLN and is not applicable to BFN.
In~ addition, Knoxville DNE drafted'a letter.on June 4, 1987 stating that Construction Specification C-39 'was revised to address the NSRS issues concerning cleaning / flushing procedures.
L
- Based on interviews with cognizant personnel and the memo from DNE, ECTG b concludes that this NSRS issue has been satisfactorily addressed. This-issue is closed.
F (Closed) I- 83-13-NPS-la, Quality Enqineerinq Branch (QEB) Records b Vendor-supplied QA records obtained by QEB for SQN have not been completely turned over to NUC PR and there does not appear to be any. plan to do so in the near future. This places TVA in violation of 10CFR50, 15
- TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2
} SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 27 0F 52 Appendix 0, Criterion VII, and Topical Report requirements. Although this report examined the flow of records for SQN, there is no basis to believe that this conclusion would not also apply to other TVA nuclear facilities.
The NSRS recommended t!.at an interdivisional task force reporting to the Assistant General Manager be formed to correct the problems identified and to establish an effective records system.
A follow-up report, R-85-07-NPS, was initiated in May 1985 that addressed ,
I the same issue as I-83-13-NPS-la. It stated that the NSRS had confirmed I in the follow-up report that in response to the corrective action recommendation contained in I-83-13-NPS, a task force was established and functionally active between December 1983 and April of 1984. 1 Additionally, the repo-t of May 1985, documented the results of the j I
follow-up corrective action review by NSRS of the findings and recommendations associated with the NSRS report I-83-13-NPS. This follow -up review covered activities of the Office of Engineering, Office l j
of Construction, and NUC PR regarding the accumulation, storage, l
transferring, and retrievability of vendor and construction records connected with procurement requiring QEB source inspection, f- To ensure the satisfactory completion of this issue, CATD R-85-07-NPS-01 was initiated at WBN. Based on the NSRS follow-up investigation in h May 1985, the corporate nature of the problem, and its tracking by a CATD issued for Watts Bar, this NSRS issue at BFN is closed.
a I (closed) I-83-13-NPS -1b, Quality Enqineerinq Branch (QEB) Record s
' The NSRS report concluded there was no overall OEDC effort to provide NUC PR a complete QA file integrating both construction and QEB records in a usable form. This was in violation of TVA Quality Assurance Procedure l
I The NSRS recommer.Jed that an interdivisional task force reporting to the i Assistant General Manager be formed to correct the prchlems identified and to establish an effective records system. f A follow-up report, R-85-07-NPS, was initiated in May 1985 that addressed ,
the same issue as I-83-13-NPS-1b. It stated that the NSRS had confirmed in the follow-up report that in response to the corrective action a recommendation contained in I-83-13-NPS, a task force was established and ,
l functionally active between December 1983 and April of 1984. J Additionally, the report of May 1985 documented the results of the I. follow-up corrective action review by NSRS of the findings and L
recommendations associated with NSRS report I-83-13-NPS. This review covered the activities of the Office of Engineering, Office of Construction, and NUC PR regarding the accumulation, storage, l
transferring, and retrievability of vendor and construction records connected with procurement requiring QEB source inspection.
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-.' .t: TVA EMPLOYEE CONCERNS . REPORT NUMBER: BFfM SRS-2 4 SPECIAL. PROGRAM REVISION NUMBER: 1 PAGE 28 OF 52 To ensure the satisfactory completion of this issue, CATD R-85-07-NPS-01
..was initiated at WBN. . Based on-the follow-up investigation in May 1985, the corporate; nature of the problem, and its tracking _by a CATD. issued for Watts Bar, this NSRS issue at BFN is closed.
-(Closed) I-83-13-NPS-1d, Quality Enqineerinq Branch (CEB) Records The retrieval'of.information from vendor QA records at SQN by NUC PR'was considered to be inadequate due to poor organization, lack of
. completeness, low level of indexing, and lack of editing. Retrieval depended'upon use of individuals located away from the site.
There was no coordinated TVA effort to ensure.the adequacy of identification, collection, collation, indexing, and. distribution of
- s. Vendor QA records.
The NSRS recommended that an interdivisional task force reporting to the L Assistant General Manager be formed to correct the problems identified and to establish an effective records system.
r A' follow-up report, R-85-07-NPS, was initiated in May 1985 that' addressed
'the same icsue as I-83-13-NPS-ic. It stated that the NSRS had confirmed in the follow-up report that in response to the corrective action recommendation contained in I-83-13-NPS, a task force was established and 3
[
functionally active between December 1983 and April of-1984.
Additionally, the report of May 1985 documented the results of the
', _ follow-up corrective action review by NSRS of the findings and recommendations associated with the NSRS report I-83-13-NPS, This p' follow-up review covered the activities of the Office.of Engineering,-
$' Office of Construction, and NUC PR regarding the accumulation, storage, transferring, and retrievability of vendor and construction records connected with procurement requiring QEB source inspection.
[
E To ensure the satisfactory completion of this issue, CATD R-85-07-NPS-01 was initiated at WBN, Based on the follow-up investigation in May 1985, the. corporate nature of the problem, and its tracking by a CATD issued for Watts Bar, this NSRS issue at BFN is closed.
(Closed) I-83-13-NPS--2, Quality Enqineerinq Branch (QEB) Records
.This issue, as investigated by NSRS in 1983, stated that no schedule was provided that established when vendor records themselves would be p verified as complete or indexed for retrievability, OEB had not l2 established a schedule to verify or index records at SQN & WBN.
This issue was investigated at SQN & WBN and, as a result of the investigation, NSRS recommended that the responsibility of vendor records
- be assigned to a manager who would be organizationally capable of coordinating the efforts of OE, OC, & ONP regarding vendor records. 1 L i 1
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TVA EMPLOVEE CONCERNS REPORT NUMBER: BFiB-NSR S-2
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REVISION NUMBER: 1 PAGE 29 OF 52 During interviews,' cognizant QEB personnel stated that in the timeframe of this issue, all vendor records pertaining to BFN had been shipped to the site and had already been filed in record storage.
Further investigations by ECTG have shown that QMI-446 (which superceded OEB-EP-24,58)-titled Supplier Document Review and QMI-450 (which superceded QEB-EP-24.37) titled Contract Records Index and Filing address the issue of vendor records.
Based on interviews with QEB personnel and review of appropriate l
' documentation, ECTG concludes that this issue has been adequately addressed. This NSRS item is closed.
(Closed) R-83-18-NPS-01, Manaqement of the Reorganization of TVA Radiation Protection and Radiological Emerqency Planning Program j
The NSRS evaluation of this issue stated that the responsibilities for conducting TVA's radiation protection and radiological protection program were not well defined and disagreements as to the final disposition of I some of its functions had not been resolved. TVA Organization Bulletins, Codes, and Instructions had not been issued a year after the h reorganization and this had led to interface and communications barriers.
The NSRS recommended that upper management.should take actions to assure l that final decisions are promptly made regarding the assignment of
~. responsibilities and all necessary TVA corporate documents (codes, bulletins, instructions) are updated to reflect the final decisions.
Upper-management involvement should be maintained until the program has been implemented in accordance with the approved documentation.
ECTG's evaluation of the issue showed that the Radiation Protection Plan i (RPP) Section A, Rev. 3 dated July 15, 1986 details ONP's requirements ,
j e
and management controls for the radiation and radiological protection
$ programs. It applies to all aspects of radiation protection associated .I with TVA nuclear power plants and supporting functions and services.
k Based on the review of the RPP, ECTG concludes that this NSRS issue has been satisfactorily addressed. This NSRS item is closed.
(Open) R-83-18-NPS-02, Office of Nuclear Power program and Licensin_q 3 Documents j This NSRS issue concerned Office of Nuclear Power program and licensing documents for radiation protection and radiological emergency planning s which had not been issued or were out-of-date. NSRS recommended additional resources be directed toward preparing, updating, and issuing the Area Program Manual, Operations Quality Assurance Manual (OQAM),
Technical Specifications, Final Safety Analysis Report, and plant standard practices in the areas of radiation protection and radiological emergency planning.
.~ t TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2
- SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 30 OF 52 V
Foll'owing review of the applicable documentation, ECTG determined that
.this issue is still'open. The FSAR and Technical Specifications do not 0
j; reflect' current organizational structures and need to be updated.
The'OQAM, as mentioned in the initial report, no longer exists. It was
[ replaced by: the NQAM. .Later, the NQAM section concerning radiation protection was removed and placed in the Radiation Protection Plan. =The g
Area Program Manual was replaced by the BFN Radiological Emergency Plan f which now' reflects the current organizational structure. Notification to the NRC concerning the current organization was initiated by TVA' December 10, 1986 and,. following NRC approval, the current organizational F,.
structure will be ready for incorporation into the Technical
- h. Specifications. The completion of the updates to the Technical
- Specifications and FSAR will be tracked with ECTG CATD R-83-10-NPS-02.
Until completion of the updates, this item remains open.
(Closed) R-83-10-NPS-03, Organizational Emphasis of Radiation Protection and Radiological Emerqency Preparedness Proqrams j.
In the original report, NSRS stated that the radiation protection and emergency preparedness programs had been organizationally deemphasized.
3 NSRS recommended that more emphasis be placed on these programs and that f staffing should be developed to the level and with the technical expertise necessary to develop and maintain their respective programs.
' ECTG determined that .the radiation protection and emergency preparedness
~ programs are now receiving more emphasis. At BFN, the Radiological Control section has been reorganized and several new positions have been 6 created. Personnel assigned to the new positions have strong academic F backgrounds and related work experience. BFN has establi; Sed the emergency preparedness program at the branch level, the r.mergency j- Preparedness Branch, with three sections as follows:
- 1. Emergency Preparedness Programs State and Local
- 2. Emergency Preparedness Program Planning.and Implementation 3, Emergency Preparedness Exercises and Emergency Facilities.
- Based on the increased emphasis on the radiation protection and emergency L preparedness programs, this NSRS item is closed.
4- (Closed) R-83-18-NPS-04, Organizational Placement of Health Physics at
- Nuclear Plants
" The NSRS report stated that the reporting chain for the inplant health physics section, described as being to the Assistant Superintendent for Maintenance, was not documented nor in compliance with regulatory requirements. NSRS recommended formalization of the reporting chain directly to the plant superintendent
. i, TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-MSRS-2 >
SPECIAL PROGRAM ~ f REVISION NUMBER: 1 ]
1 PAGE 31 OF 52 i
ECTG verified that organizational placement of health physics at the b Browns Ferry site now satisfies.the NSRS recommendation. The BFN site 5-Radiological Control Supervisor reports directly to the Plant Manager.
f Based on the satisfactory organizational placement, the NSRS issue is closed.
(Closed) R-83-18-NPS-05, Health physics Technical Staff Onsite This NSRS' issue concerned a lack of technical expertise in health physics y to identify unique and new health physics problems as they occurred at each site. There was a need for expertise to identify problem areas E requiring further technical analysis by offsite personnel and to provide
) on-the-spot technical guidance, NSRS recommended that there be established at each plant the position of assistant to the Health Physics Supervisor or similar position staffed with a highly qualified, degreed health physicist, h
ECTG verified that, since the issue of the NSRS report, the BFN Health Physics Section was reorganized and changed to the site Radiological l Control Section. The new section has been strengthened by additional e positions of Radiological Health Supervisor, Radiological Protection 6 Supervisor, Technical Supervisor, and an AI. ARA engineer. BFN filled these positions with personnel having strong academic backgrounds and related work experience. Based on the strengthening of the onsite health !
f physics technical staff, this NSRS issue is closed, r
(Closed) R-83-18-NPS-06, Radiological Health Staff (RHS) Technical Support 5 The NSRS report concluded that the Radiological Health Staff were spending to much time in the office and not enough time in the field
$; where the problems were. NSRS recommended a mechanism be established to provide more presence of RHS personnel in the operating plants.
- ECTG verified the increased presence of radiological control personnel at the BfN site. As stated above for item R-83-18-NPS-05, the Site Radiological Control Section has been strengthened by additional positions to provide the site with the necessary technical experience.
The section currently has one PHD in Health Physics, two staff welders with M.S. degrees in Nuclear Engineering, and one with an MS degree in Health Physics to assist the section supervisor.
Based on the increased RHS technical support, this NSRS issue is closed.
7' i I (Closed) I-83-28-BFN-01, Testing of Water Retaininq Characteristics of i l
Resin h
l
['
The NSRS report stated that a TVA shipment of spent resin from BFN to Barnwell, South Carolina was sampled and foundThe to have water in the shipment contained a container in excess of the minimum standards.
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- 1 TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 1 I PAGE 32 OF 52 s i i
mixture of bead type and powdered type resin, each with different water retaining characteristics. The radwaste program instituted by ONP adequately addressed dewatering bead and powdered resin individually, but '
did not take into consideration dowatering a ecmbination of the two types which is common to the BFN site. ;
i '
NSRS recommended that the water-retaining characteristics of a mixture of bead and powder should be determined by test for various mixture percentages. Based upon the test results, plant procedures should bo ;
changed as applicable to ensure that resin liners are adequately q
) dewatered.
s Subsequent to the NSRS report, the NRC closed out a related violation (Violation 50-259/260/296/84-12-01, Excess Water in Radioactive Resin l Shipping Liners), The clcse-out report by NRC (Report Nos. _
j 50-259/260/296/85-11 dated March 21, 1985) found acceptable "the results f of tests to demonstrate the adequacy of dewatering procedures."
h Based on review of the applicable documentation and discussions with the g plant personnel, ECTG concluded that the NSRS issue has been p satisfactorily addressed. This item is closed, h (Closed) R-84-05-WBN-14, Inspector Certification Records The NSRS report, dated June 1984, concluded that printouts (at Watts Bar) l describing inspector certifications sometimes indicate that the t inspectors are only " partially" certified and do not always identify the areas in which they are certified. In some cases the printouts contained errors in certification data. NSRS recommended that any areas of y " partial" certification be identified.
Subsequent to the NSRS report, the Nuclear Quality Assurance Manual l (NQAM), Part II, Section 5.6.3 (dated July 1, 1987) established g requirements for an up-to-date list of certified inspection personnel, 3 with distribution to each nuclear plant. Specifications are provided concerning identification of certification areas for partially certified
- inspectors. In addition to the clarification of requirements, improvements in the interactive computer system have improved the certification documentation process. Areas of partial certification are now identified, b Based on the improvements in the certification process, this NSRS item is s closed. ,
l l
(Closed) NSRS I-84-16-BFN-01, Recognition of the HPCI System as Necessary l l
u to Maintain the Plant in a Safe Condition 4 The NSRS report stated that the high-pressure coolant injection (HpCI) j system had incurred many failures and had been very unreliable from the startup of BFN unit 1 in 1973. Failures had occurred in the components, j the control mechanisms, and in structural supports, q i
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1 o i n< ' 'O 'TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 y o
4 SPECIAL PROGRAM REVISION NUMBER: 1 -]
PAGE 33 OF 52 NSRS recommended that, because of the importance of this system, a complete fix to,the' system must be pursued immediately-so that it would t
perform its required safety function. Also,-the system must be~ raised on
.the priority list and be. recognized for its'importance to public safety.
ECTG's review of this issue indicated"that.the plant has completed the recommendations of I-84-16-BFN 02, 03, 04 and 05 for unit 2. In addition the plant established a'HPCI Task Force to study and make recommendations-for system improvement. The last Task Force Meeting was held in January-1987. In summary, the following actions have been taken:
-1. NDE was performed on areas of the system which analysis showed to have been subjected.to.high stresses.during operation.
.2. An analysis was performed for normal and abnormal conditions. The K
results indicated that Unit 2 support R-23 should be modified. This
! work'has been done per'ECN PS366-Work Plan 2015-84.
I:
- 3. Valve 73-45 which:was suspected of leaking and sticking has been
[ ireplaced on Unit <2 by ECN P0651, workplan 2053-84. The ECN covers l" unit 1 & 3 also,
- 4. .Special Test 82-11 was performed on Unit 2. The modification.
~ associated-with the test has been physically completed on Unit 2 s
o (ECN P0766). The ECN covers all three units.
- 5. As part of the Environmental Qualification Program, a contract has been awarded for performance of control system modifications to all three units to environmentally qualify the system. A specific
[
aspect of this work is the relocation of the governor control panel to a suitable' environment.
I
- 6. Mechanical Maintenance Instruction MMI-23 has been revised to include a monthly inspection of the HPCI system. This corresponds
}-
l' to the monthly operability test SI 4.5.16.
i k' 7. SI 4.6G has been revised as an NRC commitment to include a visual inspection of HPCI piping and supports after an injection (scram).
3 SI 4.6G para 19.14.
F 3
Dased.on the above actions, ECTG has concluded that the HPCI system k received the priority and-level of importance by the plant that the NSRS I was seeking. This NSRS item is closed.
(Closed) I-84-16-BFN-02, NDE Examination of HPCI System Welds in Pipinq and Restraints The NSRS report stated that several restraint failures have occurred during operational testing of the High Pressure Coolant InjectionBent system. In one case, a base plate was pulled out of the wall.
or i broken restraint members were more common because of periodic overloads.
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t I TVA EMPLOVEE CONCERISS REPORT NUMBER: BFN-WSRS-2 l 1
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PAGE 34 0F 52
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l NSRS recommended that non-destructive examinations (NDE) of the welds, the piping in the vicinity of the restraint lugs, and the restraints f themselves, be conducted to ensure that the system is still qualified to meet its; safety function.
ECTG reviewed the original NSRS report and applicable correspondence. In addition, discussions were conducted with cognizant personnel at BFN. It was determined that Browns Ferry performed NDE on areas agreed to at a November 28, 1984 meeting with NSRS. (The NDE was specified in memorandum B22 85 0304 025 and reported in Rio 85 0423 964).
Based on performance of the recommended NDE, the NSRS item is closed.
)
(Closed) NSRS I-84-10-BFN-03, Implementation of HPCI Special Test 82-11 for Units 1, 2&3 l The NSRS report stated that special test 82-11, conducted at Vermont Yankee Nuclear Plant in early 1984, had demonstrated a control modification on the HPCI turbine which improved (lessened) the_ system quick start transient. NSRS recommended that BFN implement the operations change specified in and tested by the 82-11 test. All Units should be tested by the Test 82-11. In addition, the piping and supports should be inspected before and after each operational test to allow for the evaluation of the cause of problems should any failures occur.
ECTG's review of this issue indicated that special test 82-11 was performed at BFN and the modification implemented by ECN P0766. The physical work is complece on Unit 2 only. Units 1 and 3 are also covered by the ECN. Mechanical Maintenance Instruction MMI-23 is performed monthly to inspect the HPCI system after testing. Additionally, Surveillance Instruction SI 4.6G provides for inspection after injection.
Based on implementation of special test 82-11, this NSRS item is closed.
(Closed) I-84-16-BFN-04, Implementation of Design Change Request BF-DCR-P2040 for the HPCI System The NSRS report stated that, because of a corrosion problem in the governor control box, Design Change Request BF-DCR-P2040 was initiated to relocate the control box to a more favorable environment. However, the DCR was cancelled February 1984 as "not necessary," Implementation of the DCR was made a NSRS recommendation in the June 1984, I-84-16-BFN report.
ECTG verified that the governor control box is being replaced and relocated on all three units per ECNs P3183, P3184, and P3185. The physical completion of work is to be accomplished under contract 87NLF-839241 awarded to General Electric for environmental qualification of the HPCI turbine. The contract states an installation completion date of August 24, 1987.
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- BFN-RSRS-2 a
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PAGE 35 OF 52 Based on the' contract award and work. scheduling, the NSRS item is closed.
V- .
.' (Open) R-84-17-NPS-01A The procurement System is Too Cumbersome and Not t- Well Known bv'the' Users NSRS stated' that the, biggest problem found. with the procurement system used by NUC PR was its wasteful and cumbersome nature. . Procurement were overloaded with redundant reviews producing little value added'in most cases.and causing unnecessary. time delays up to months. Virtually anyone-could initiate a procurement action with little or no training.
h No one was found in the procurement process that' knew the process much 3
beyond theirLsphere of involvement. That resulted'in unrealistic T' expectations being placed upon the system by the originator with regard to delivery time, and in perpetuation by others in the process who did a s not correct the problems or expectations. One of the more cumbersome and 3s redundant review processes occurred within the Nuclear Central Office.
- NSRS stated that the removal of that review process on October 1, 1984, 9 with the transfer of people to the sites, would halp streamline the g, process provided'the Central Office problems were mot'also transferred to a the sites.
i Thelfirst of'four NSRS recommendations to correct the problems was as follows:
~
The Procurement Problem Task Force recommendation to eliminate all-unnecessary steps in the procurement cycle with the goal of placing s, very few, if.any, Steps between the requisitioner and the purchasing agent should be given the highest priority.
f The procurement process at Browns Ferry was being reviewed at the time of g this report by ECTG with results to be reported in ECTG report 80104-BFN.
The scope of.the 80104 review includes all NSRS items from the R-84-17-NPS report.
4 Acceptable closure of the ECTG report 80104-BFN and resolution of findings will close NSRS item R-84-17-NPS-01A.
(Open) R-84-17-NPS-010, The procurement System is too Cumbersome and Not Well Known by the Users NSRS identified problems with'the procurement system used by NUC PR (see j R-84-17-NPS-01A for problem description). The second of four NSRS recommendations to correct the problems was as follows:
A formalized, documented training program covering the entire procurement process should be developed and required for all personnel within the procurement cycle from the originator (requisitioner) through the purchasing agent.
p
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). TVA EMPLOYEE CONCERNS.. ' REPORT NUMBER: BFPJ-NSRS-1 '
..SPECIAL PROGRAM ;
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- s. PAGE 36 OF.52 J,
An'.ECTG' review of the'overall BFN procurement process was in process at' .
p the time of this report and will be reported in ECTG: report 80104-BFN. f
.. - The scope of.the.80104 review includes all NSRS items from the f, R-84-17-NPS' report. ,
i Acceptable closure of the ECTG repor!t 80104-BFN and resolution of 1
. findings will close NSRS item R-84-17-NPS-010.
(1 (Open): R-84-17-NPS-01C, The procurement System Is Too Cumbersome and Not Well Known By the Users W
lNSRS. identified problems'with the procurement system used by NUC PR (see
~
l R-17-NPS-01A for problem description). The third of four NSRS
. recommendations to correct the problems was as follows:
f e.
.A realistic timeframe(s).should be established for routine non-special order procurement, based upon past experience, to cover
- j. the time required from: procurement origination through receipt of
'the material onsite. A mechanism'should be included in the 61 procurement system to periodically' evaluate and. adjust that 3- timeframe as necessary, as well as communicate the timeframe to involved personnel (planners, procurers, etc.).
". An ECTG' review of.the overall BFN procurement process was in process at the time of this. report and will be reported in ECTG report 80104-BFN.
[ *
~The scope of the 80104 review includes all NSRS items from the
.; R-84-1*-NPS report.
a-4 3 Acceptable closure of the ECTG report 80104-BFN and resolution of 0 findings will close NSRS item R-84-17-NPS-01C.
- g. (Open) R-84-17-NPS-01D, The procurement System Is Too Cumbersome and Not Well Known By The Users N' NSRS identified problems with the procurement system used by NUC PR (See R-84-17-NPS-01A for problem description). The fourth NSRS recommendation to correct the. problems was as follows:
Material availability and procurement timeframes should be included in'all maintenance and modification planning activities. (NOTE:
This recommendation is predicated upon information that NUC PR is developing a maintenance and modification planning and scheduling function at each site.)
l- An ECTG review of the overall BFN procurement process was in process at the time of this report and will be reported in ECTG report 801'04-BFN.
The scope of the 80104 review includes all NSRS items from the R-84-17-NPS report.
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TVA. EMPLOYEE CONCERNS REPORT NOMBER: BFN-NSRS-2
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' Acceptable closure of the'ECTG report 80104-DFN and resolution of W findings will close NSRS item R-84-17-NPS-010. ,
$. (Closed)'.R-84-17-NPS-04, Insufficient Documentation for Transmitted j
~
': Material
]
r The NSRS report concluded that sites requesting material to be .
transferred to them by another TVA organization or location did not j specifically identify documentation requirements or require a copy of the j original contract the material was purchased under. Therefore, the ;
[ receiving site had a limited basis for accepting material during the :{
receipt inspection. process. The site ass'umed that all applicable !
p documentation had been sent by the transferring organization without ;
knowing exactly what.the original specifications (technical /QA) were. l i
j NSRS recommended that NUC PR implement requirements regarding~ transferred' d material. A copy.of the original contract should be'in the possession of L- and used by the receiving site during receipt inspection, and QC k documentation required with the transfer should be specifically.-
identified.
, The original report details were reviewed to determine all of the
$> specific recommendations and compared with the current Browns Ferry Quality Control Inspection Program and dedication program for commercial grade material, parts, or components for CSSC application.
l
- . Discussions were also held with the Items Evaluation Group Manager, a !
g knowledgeable quality. control inspector, and the power stores site manager ]
3 to determine the current program implementation status and the relative M. understanding by site personnel. These discussions indicated that ;
Quality Control Instruction, QCI 1.1, Revision 1, " Receipt Inspection" l now requires a quality control inspector to verify the documentation package on transferred material. The inspector also requires a copy of the contract as part of the documentation package. The Items Evaluation l h' Group reviews the transfer package in accordance with Site Director Standard practice (SDSP) 16.1-02, Revision 1 " Dedication Program for ,
-Commercial Grade Material, Parts, or Components for CSSC Application "
];
Reviews are performed by trained engineering personnel and a formal
.. dedication is required before the transferred material can be used as a {
" basic component" in a CSSC system. l 1
9' Based upon the above findings, this NSRS issue is closed.
Is
. (Closed) R-84-17-NPG-06, BFN Power Stores Receipt Inspection Clerks Not Trained to Inspect Material
/ In the original review, NSRS concluded that power stores clerks were not trained to receive materials with Certificates of Conformance (COC),
Certified Mill Test Reports (CMTRj, or other similar QC documentation.
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L L C l t. TVA EMPLOYEE CONCERNS REPORT NUMBER: DFM-NSRS-2 L' '
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 30 OF 52 l-I j, .
1 The NSRS report identified instances where pers'onnel performed receipt W; inspection and acceptance of material ~ incorrectly. NSRS recommended 'that L5 , the Division of Nuclear Power revise the Operations Quality Assurance Manual (OQAM) to prohibit receipt inspection except by qualified QC inspectors of material with QC documentation.
s, f 1
The original report details were reviewed to determine all of the t specific recommendations and compared with the' current Browns Ferry I
quality control program for receipt inspection. ' Discussions were also.
held'with cognizant personnel to determine program implementation, k status, and . relative understanding by site personnel. These discussions
. indicated the following:
NQAM Part I,.Section 2.7.2, Revision 1, " Dedication of Commercial Grade Items" and Quality Control Instruction, QCI 1.1, Revision 1, " Receipt Inspection" require receipt inspection of QA level I,.II, and III (certificate of conformance) by-a responsible QC inspector. Discussion j;
with a QC inspector to determine program implementation indicated that L' receipt inspection was for'all QA level I, II, and III items.
5'
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Based upon verification of receipt. inspection by trained inspectors, this
!. NSRS issue is closed, i l: (Open)- R-84-17-NPS-07, Material With Limited Shelf Life Not Reordered In A Timelv Manner e
In the original review, NSRS concluded that Browns Ferry was not' ordering
. material with sufficient lead time to have new material'on hand before 2 existing material shelf life. expired. The NSRS recommended the following d program changes:
[ (1) Revise the OQAM to establish programs to inspect and reorder limited shelf life material; (2) The then-current three month reorder lead time should be re-evaluated and adjusted as necessary.
The original report details were reviewed to determine all of the specific recommendations and compared with the current Browns Ferry Materials Managements Improvement Project Program. Discussions were also ,
g held with cognizant personnel to determine program status, i P ECTG found the following actions necessary to close the issue- i
)
Drowns Ferry Materials Management Improvement Project (P-2 schedule, Item l
7024).must complete task D14 of the project manager's report dated April L 13, 1987 and described as follows:
D14. Develop comprehensive shelf life program 1
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.I f I TVA EMPLOYEE CONCERNS. REPORT NUMBER: BFiB-iBSRS-2 ,
SPECIAL PROGRAM ~ l r.
PAGE 39 OF 52.
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14'.1 Identify all. inventory, staged direct charge, and ECN support materials requiring shelf' life' control by commodity code 14.1.1- Establish shelf life for items identified in 14.11 14.2' Implement' shelf L life control via PM .sof tware progran.
14.3 Load all data from current Prime Tracking Program 14.4 Load new d'ata from 14.1 l
- 14.5L Establish shelf life extension program (guidelines) 14.6' Write new ' procedure and/or revise existing procedure 14.7 -. Train personnel f
The above task is currently scheduled on the site P-2 schedule under
> : Materials Management-Improvement Project number 7024. Verification of..
completion of this task will close the NSRS item. This item remains open-b:
h with tracking by.ECTG CATD R-84-17-NPS-07.
-(Open) R-84-17-NPS-08, Materials Management System (MAMS) Under Utilized h- ..
In the original review, NSRS concluded that the MAMS System was being ,
6 under utilized. in that its capability to track inventory items usage and to. reorder items automatically was not being used. Additionally, the. .
MAMS program. lacked any quality assurance controls to prevent I l
l, unauthorized changes to specifications or other information. NSRS recommended the~following program changes:
ONP power stcres and materials management services should jointly increase efforts to utilize MAMS in the most effective manner possible, The original report details were reviewed to determine all of the s specific recommendations and compared with the current Browns Ferry -
Materials Management Improvement Project program. Discussions were also held with cognizant personnel to determino program status:
s: ECTG found the following actions necessary to close the issue:
p f Browns Ferry Materials Management Improvement Project (P-2 schedule, a item 7024) must complete task F1 of the prnject manager's report dated l' April 13, 1987 and described as follows:
y F1. Enhance the MAMS inventory analysis program b 1.1 Develop a system design for routine inventory analysis
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'l 1 1.1.1 Perform business analysis- l 1.1.2 Implement MAMS system enhancements ;
}
1.2 Establish mechanism that would allow transmission of prime data.to item identification'section
'Also complete program enhancements listed in' sections F2, F3, F4, F5, , ,
F6, F7, F8 not listed here. Task F5 includes performance.of a total -
. I MAMS records review.to enhance data quality.
.\1 The -above task is currently scheduled on the site P-2 schedule under
~
materials management improvement project number 7024. Verification of l , , ,
closure of task F will close this NSRS-item. This item remains open, i li a
with' tracking by ECTG CATD R-84-17-NPS-08.
(Open) R-84-17-NPS-09, 10 CFR Part 21 Requirements Incorrectiv Linked to h Nuclear Power QA Requirements In the' original review, NSRS concluded that the manufacturing quality and f
receipt inspections were automatically reduced when 10 CFR, Part 21
- requirements were determined not appl'icable. Also, the requirements of b the OQAM,.Part III, Section 2.1, Appendix F, Attachment..I were deficient in that'if an item was determined to be commercial grade, then its effect -
!. . - .upon or. use within a critical system or component could (incorrectly) be ignored. .NSRS. recommended the following program changes:
l'. Remove'the influence of 10 CFR 50 Part 21 applicability upon the s- determination of required quality levels for items or services.
, 2. Revise OQAM Part III, Section 2.1,-Appendix F accordingly.
1 ic
- 3. _ Retrain all personnel involved in the procurement cycle, f q
s
- 4 .. The OQAM shall be formatted so that all questions on the -)
- applicability form are answered whether or not 10 CFR, Part.21 is applicable to the item or service.
The original report details were reviewed to determine all of the -
specific recommendations and compared with the current drowns Ferry
" Dedication Program for Commercial Grade Material, Parts or Components
' for CSSC Application". Discussions were also held with cognizant
'r personnel to determine program implementation status, and relative understanding by site personnel.
NQAM Part I Section 2.7.2 Revision 1 " Dedication of Commercial Grade Items" and NQAM, Part III, Section 2.1, Revision 1, Appendix F '
" Procurement of Materials, Components, Spare Parts, and Services" have l 1
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been revised.to reflect the.new program. 10 CFR Part 21 applicability is nowLdetermined separately from quality levels (reference: Appendix F, Section'3,0) and is also reviewed by trained DNE engineering personnel.
The following actions were found necessary'to close the issue:
1 The Browns Ferry Items Evaluation Group, as established through the BFN 9ntract engineering group,.must complete a site specific. evaluation of installed " Commercial Grade" items and those warehoused prior to BFN unit 2 restart. The program is specified in BF Standard Practice, SOSP 16.1-02, Revision 1, " Dedication Program for .Comn.ercial Grade Material, Parts, or Components for CSSC Application." Wyle contract TV-56071A and-f Bechtel contract TV-65375A (current performance date is August 17,-1987 for both) will assist TVA in this task. Completion'of these actions will D close this issue.
I '
i
( Pending completion of corrective actions, this NSRS item remains open with tracking by ECTG CATD R-84-17-NPS-09.
f (Closed) I-84-31-BFN-01,. Investigation of Potential Significant Events
{ '
4 In the original report, NSRS recommended that NUC PR should establish an F ongoing program to provide internal investigations of. potential p significant events. This recommendation was made following
(
investigations of an inadvertent unit 3 startup from cold condition with the RHR'in shutdown cooling mode. The NSRS report-stated that plant procedures should provide for well qualified and diversified internal review teams to investigate potential.significant events ECTG reviewed the functions of the BFN Plant Operations Review Staff (PORS) and the BFN Independent Safety Engineering Group (ISEG). The ISEG p ' reviewers at 9ach site provide an independent review and assessment of safety-related activities, programs, and events. The PORS organization j~ has responsibility to investigate events as requested by the plant manager. The PORS organization includes an investigative section and an' assessment section, and can pull in other staff as needed for review of significant problems.
.ECTG interviews with PORS and ISEG personnel established that BFN now has an established program for investigation of potential significant t events. Based on this, the NSRS item is closed, s
(Closed) I-84-31-BFN-02, Interpretation of Regulatory Requirements V. s The original NSRS report stated that the technical specifications violated during a full power shutdown margin test were perceived to be of the gray area type that could be interpreted differently with justification. NSRS recommended that ONP management should identify J.
I
. TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-19SRS-2 SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 42 OF 52 those areas of regulatory requirements, including technical specifications, that are considered to represent interpretation problems. Clarification should be provided with NRC assistance as needed.
ECTG verified that the TVA Office of Nuclear Power policy with respect to the interpretation of the-technical specifications for operation at each site is implemented through procedure 0604.06 " Technical Specification Interpretations". The 0604.06 procedure is implemented at BFN by Standard Practice / Instruction BF-12.23 " Technical Specification Interpretations" (approved June 19, 1985).
Based on provisions of the Technical Specification Interpretation procedures in place at Browns Ferry, this NSRS item is closed.
(Closed) I-84-31-BFN-03, Interpretation of Regulatory Requirements The original NSRS report concluded that a number of technical i specification interpretations by line personnel were incorrect during a full power shutdown margin test. NSRS recommended that ONP establish a policy and procedures for the interpretation of regulations.
{ I ECTG verified that policy and procedures for the interpretation of regulations are in place at BFN. The ONP policy and procedure are
.' Identified in procedure 0604.06 " Technical Specification Interpretations" h and' imp}emented at BFN by Standard Practice BF-12.23 " Technical Specification Interpretations".
l Based on ECTG's review of the above procedures, the NS'RS item is closed. '
r (Closed) I-84-31-BFN-04, Commitment to Procedural Controls
{ The NSRS report stated that after a number of procedure violations during a full power shutdown margin test, line personnel made little effort to show NSRS that procedural controls were of paramount importance. NSRS
[ recommended that ONP management establish a written policy to ensure the a necessary commitment to procedural controls and to strict adherence to procedures.
- The TVA Nuclear Performance Plan, Volume II, has committed TVA's nuclear program to strict procedural compliance. The Performance Plan, Volume
. III, details BFN's procedure upgrade programa to ensure that procedures 0 are correct and workable. Operator training and general employee 3 compliance training emphasize the adherence to procedures and the basis I' for following procedures. Standard Practice BF 12.24 " Conduct of Operations" further defines operator responsibility for adherence to <
d' procedures. Standard Practice BF 19.11 delineates disciplinary action for failure to follow plant policies and procedures.
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i TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 43 OF 52 Based on the established commitment to procedural controls, the NSRS item is closed.
(Open) R-84-32-NPS-01, Inadequate TVA Quality program The NSRS report stated that action was incomplete on developing and implementing an integrated quality program for TVA nuclear facilities that includes the following attributes consolidated from previous NSRS findings:
I' 1. Identification of activities affecting quality.
! 2. Identification of components, systems, structures to which the quality program is applied.
I
- 3. Identification and definition of industry standards and guidance for f
i control of activities outside tha scope of regulatory requirement. '
)
- 4. Improvement of the C#fice of Engineering (OE) quality program and procedures and acceptance of the OE quality program by the Office of f
Nuclear Power.
- 5. Incorporation of vendor data into a configuration management control system.
NSRS recommended that the Office of Nuclear Power as owner-operator h should assure that the integrated quality program, currently being J planned and developed, will account for the identification and control of l, the attributes listed above.
As discussed in TVA's Corporate Nuclear Performance Plan, Volume 1, the i responsibility for the various quality assurance functions is consolidated under the Director of Nuclear Quality Assurance. An h
upgraded TVA standard nuclear QA program is being implemented at BFN by the Site Quality. Manager's organization. Improvements are in process for the BFN Q-List, the Vendor Manual Program, and corporate and P site-specific procedures.
Completion of activities now in process will close this NSRS item. CATD 1 R-84-32-NPS-01 has been issued to track the item until closure.
b Acceptance of Pipe Stresses and/or Support
, (Open) I-84-33-BFN-02,
? Stresses in Excess of Defined Allowable Stresses The support design review by NSRS showed that in most cases the criteria were folluwed and the acceptance criteria were met. However, there were examples of existing supports being accepted even though complete analytical calculations to qualify the support to revised-analysis 1
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REPORT NUMBER: BFN-fdSRS-2
-[ TVA EMPLOYEE CONCERNS SPECIAL PROGRAM h.
REVISION NUMBER: 1 PAGE 44.OF 52 results were not available. There were instances where stresses,-.in l1 . excess of the code defined allowables, had been. accepted without-L documented justification.
4 NSRS recommended a' piping review to ensure that all cases exceeding allowable stress'were-identified and corrected, and train engineers that allowable stresses are not to be exceeded for the as-built. configuration.
ECTG reviewed memoranda (B41 850624 003) and (B22 060912 201) which provided previous Browns Ferry Engineering Project responses.to the'NSRS item aslwell' as: the current ECTG reports 218 4 and 218.5 concerning pipe stresses and' support stresses. ECTG CATD 21804-BFN-01 of the type was: issued to identified request. correction for' pipe overstress problems in I--84-3 3-BFN-02. Overall programs are in process or. complete to create calculations to document the qualification of all safety-related piping, The ECTG investigator found that calculations were not yet available to close the NSRS. issue. CATD I-84-33-BFN-02 was issued to track the issue j until closure. This item remains open, Written Guidance and Traininq for - Performing h'
(Open) I-94-33-BFN-03A, Piping Analysis ~
{f NSRS stated that the design criteria'BFN-50-D707, written to define '
technical' requirements of the 79-14 piping analysisAnalysts effort, does'not were given no g- provide a' complete guide-for performing' analysis.
additional instructions, training'or general orientation to BFN analysis and procedures when they entered the section nor on a periodic basis to
{ verify consistency of approach when information relating to a new analysis: method became available.
NSRS recommended that technical guidance in the form of a controlled 0
handbook or similar mechanism should be issued and made available to the
. section.
k ECTG reviewed the original NSRS report and the Browns Ferry Engineering Additionally, Project (BFEP) responses to it (B22 860912 201).
interviews were conducted with BFEP personnel.
Commitments for the piping and supports program were reviewed in the BFN Nuclear Performance Plan. The following documentation for the program was identified:
- Program plan BFEP-PI-86-05 describes the BFN 79-02 and 79-14 efforts
- Initial inspection for 79-14 was performed in accordance with Mechanical Maintenance Instruction - 99 (MMI-99).
- Engineering evaluations were performed under project instruction BFEP-PI-85-01 l'
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- ' l' TVA EMPLOVEE' CONCERNS REPORT NUMBER: BFN-NSRS-2' SPECIAL PROGRAM REVISION NUMBER: I f
PAGE 45 OF 52 o Final-reinspection process is described by program document
.BFEP-PI-86-06 Based on the documentation review and 'BFN discussion, ECTG was not able to verify that the NSRS item is ready for closure. CATD I-84-33-BFN-03A was issued by ECTG. This item remains open.
(0 pen)' I-84-33-BFN-03B, Written Guidance and Traininq for Performinq Pipinq Analysis l
This NSRS item 03B is closely related to 03A above. The item 03A emphasized the need for technical guidance in the form of a controlled i
handbook. The item 030 ' emphasizes the need for general orientation and training specific to DFN practices for performing piping analysis.
ECTG . reviewed the original NSRS report 'and . the Browns Ferry Engineering l
Project (BFEP) responses to it (B22.860912 201). Additionally,-
i-interviews were conducted with BFEP personnel. ECTG was not able to verify.that this NSRS item is ready for closure. CATD I-84-3 3-BFN -03B was issued by ECTG. This item remains open.
l; e- (0 pen) I-84-33-BFN-04, Calculations Checked by Non-Independent, Inexperienced Personnel k'
h In the original report, NSRS stated that inexperienced personnel were L assigned to check the work of the engineer who was training them.
Requirements for independent verification were not being met. NSRS recommended that (1) personnel-not be assigned areas of responsibility until they have received adequate training to qualify for the i responsibility,'and (2) qualified personnel be utilized to maintain independent verification for all problems. Browns Ferry Engineering Project personnel responded (822 851106 021)' that calculations which may not have received an independent check would be reverified by an independent checker. ECTG's discussion with BFN personnel concerning
{c: this item did not confirm that the independent check had been completed.
ECTG issued CATD I-84-33-BFN-04. This item remains open.
(Closed) I-84-33-BFN-05A Failure to Implement Discrepancy Status Trackinq g
System j 1
l., According to the requirements of NRC IE Bulletin 79-14, "Scismic Analysis for As-Built Safety-Related Piping Systems", TVA is to provide analysis h
4 results for safety-related piping systems. NSRS concluded that the
- tracking system defined in SEP 81+02, " Implementation of NRC-OIE Bulletin 79-14 for Browns Ferry Nuclear Plant", was never fully implemented and was abandoned due to the time involved in maintaining it. There was no J
controlled system being utilized to track and document the status of !
r 79-14 discrepancies.
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/ TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 1 ;
f PAGE 46 0F 52 In order to close the issue, the following actions were recommended by NSRS:
- a. Identify and assimilate the current status of all discrepancies.
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- b. Establish and implement a system which tracks 79-14 discrepancies.
The BFN response (B22 860912 201) to the subject NSRS report was ;
reviewed. The response stated that (1) the tracking system was I abandoned because it was not cost effective (2) manual tracking of discrepancies was maintained in its place, and (3) a revised computer l tracking system was being developed.
ECTG verified implementation of BFN corrective action to track and document the status of 79-14 discrepancies. At BFN, the 79-14 program was merged with the 79-02 program " Pipe Support Base Plate Designs Using Con rete Expansion Anchor Bolts". The overall program plan is described in BFN engineering project procedure BFEP-PI 86-05 "NRC-OIE Bulletin 79-02/79-14 Program Document for Browns Ferry Nuclear Plant", Revision 0 dated January 29, 1986. Implementation is detailed in procedure l
BFEP-PI-85-01 " Implementation of NRC-OIE Bulletins 79-02/79-14 for Browns Ferry Nuclear Plant", Revision 1, dated January 28, 1987.
l ECTG rs dewed the 79-14 tracking system at Browns Ferry during June 1987. Based on this review, it was determined that BFN had completed corrective actions. This NSRS item is closed.
l (Closed) I-84-33-BFN-05B, Failure to Control Proqress of 79-14 Through Accurate Schedule b
In the original review, NSRS concluded the tracking system defined in SEP g
)
B1-02 was never fully implemented. The lack of control is further :
evidenced in past scheduling which projected all 79-14 related work for all units to be complete by May 1985. A controlled tracking system is i
h necessary in order to identify the completion of the total scope of I 5
work. An accurate schedule which represents real progress is necessary to complete the work.
j In order to close this issue, the following actions were recommended.
l
- a. Identify current status of all analysis and support design work which l g
remains for the 79-14 effort.
E b. Track actual progress of work performed, document, and reflect in accurate schedules.
The DFN responso (B22 860912 201) to the subject NSRS report was reviewed. The procedures referenced in the response have been issued and I
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( TVA EMPLOYEE CONCERNS ~ REPORT NUMBER: BFN-NSRS-2 i SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 47 OF 52 a tracking system established. A discussion with BFN engineering 4 personnel verified the corrective action completion, Based on D 1 implementation of the accurate scheduling system, the NSRS item is closed, f i
(Closed)L I-84-33-BFN-06 Failure to Revise SEP'81-02 to Adequately Define 79-14~ Program I
The NSRS found that (SEP) 81-02, " Implementation of NRC-OIE Bulletin l' 79-14 for Browns Ferry Nuclear Plant," detailed the, initial handling of -
discrepancies but failed to consider the coordination required to verify
!! completion of field modifications and preparation of the final closure g
documentation for the 79-14 report to the NRC. NSRS recommended that SEP la 81-02 be revised to define activities required to complete and document-the completion of the 79-14 program.
The BFN response (B22 860912 201) to the NSRS was reviewed, ECTG verified that engineering procedure BFEP-PI 8501." Implementation of NRC-OIE Bulletins 79-02/79-14 for Browns Ferry Nuclear Plant" was issued l
as: stated in the BFN response and replaced SEP 81-02'. Based on the development of this procedure defining activities required to complete and document the'79-14 program, the NSRS item is closed.
(Closed) I-84-33-BFN-07, Pipinq Analysis Not Satisfactory NSRS concluded that-the Office of Engineering (OE) did not-perform h' generic evaluation of problems identified in " Evaluation of WBN Piping Analysis Review Team's Report," July 1982. Conclusions of the 1982-report were:
E
- Piping analysis' criteria inaccurate and incomplete Documentation of WBN piping analysis in MEDS is incompleto
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- Procedures for performing, verifying, and documenting WBN piping
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l analysis do not exist
- Training not adequate
- Independent review lacking .J
- QA auditors not auditing to requirements of the controlling documents k NSRS recommended that the problems be reviewed, root causes determined, s, and corrective action established. The problems found at WBN should be reviewed for applicability to all other projects.
. I I
A BFN engineering response (B22 860912 201), dated September 12, 1986, outlined actions up to that time to apply the WBN findings at BFN.
ECTG's piping analysis reports 218.4 and 218.5 examined the current status of piping analysis and identified deficiencies to be tracked by 1
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'*- I' TVA EMPLOYEE'CONCERNSE REPCRT NUMBER: BFN-NSRS22 h
.SPECIAL' PROGRAM' REVISION NUMBER: 1 PAGE'48 0F 52 ECTG CATD's_2iB04-BFN-01, and 21805-BFN-01. Additionally, ECTG CATDs I-84-22-BFN-02, I-84-33-BFN-03A, I-84-33-BFN-038, and I-84-33-BFN-04 were issued to track completion.and closure of several aspects of the NSRS report. ECTG concluded that recommendations for review, root cause analysis,- and corrective action for BFN are complete or in process. Item I-84-33-BFN-07 is closed, )
(Closed) .I-84-33-BFN-08, ' Failure of QA to' Perform aud'its'and 3
Surveillance of Identified Problem Areas Within Piping Analysis Sections' The NSRS report' i stated that no audits or surveillance had been conducted i
Analysis Section. .No audits / surveillance were performed to verify the l implementation and effectiveness of the piping analysis section procedures.
[ ,
h, NSRS recommended performance of annual audits to ensure that procedures and design criteria are being followed, and to evaluate effectiveness of
- l. the piping analysis programs, s
, ECTG reviewed applicable documentation and discussed _the issue with I cognizant BFN site'and central office engineering design and quality assurance personnel. It was determined that the 1986 Division of Nuclear h Engineering (DNE)-Audit PlanL (B05'870310 001) and 1987 DNE Program Audit Schedule (BO5 870303 002 and 805 870319 009) now require and schedule periodic audits of the piping analysis ' program, and that audits have been
[: performed since the NERS report (for example, see audit report a -805'870403 025).
Based on the requirements in place, and the scheduling and performance of p, audits in this area, the NSRS item is closed.
i J (Closed) I-84-34-SQN-02, Completion of TVA Mark Letter Description on the E. Transfer Requisition Documents e
NSRS found a potential for Non-class 1E cable to be installed in a Class 1E System when cables are transferred from one site to another site where l TVA cable mark letters do not define the cable the same way at both sites. NSRS recommended that transfer requisitions contain the full description of the cable mark letters so users would know which cables to use for which application.
u '
ECTG reviewed BFN Quality Control Instruction QCI-1.1 " Receipt Inspection" and BFN Standard Practice BF 16.4 " Material, Components, and Spare Parts Receipt, Handling, Storage, Issuing, Return to Storcroom and Transfer," It was verified that BF 16.4, Section 6.5, requires transfer requisitions to contain a complete description of cable for maintenance
'and modifications including mark number when applicable.
o e TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 SPECIAL PROGRAM j
REVISION NUMBER: 1 PAGE 49 OF 52 Additionally, ECTG discussions with BFN Quality Control receiving unit 5 personnel indicated that all Class 1E cable is reviewed by Engineering before QC's material inspection. QC verifies all cable at issue to ensure material as issued is as requested.
Based on the BFN procedures in place and QC practices, ECTG considers the N'dRS recommendations to have been appropriately implemented. This item i is closed.
(Closed) I-85-06-WBN-04, Timely and Responsive Corrective Actions for i j Resolution of Identified Problems s The original NSRS report concluded that the quality assurance verification program for electrical engineering and design activities was .
I inadequate based on problem areas being identified by organizations outside QA. It was recommended that the Quality Management Staff of the Office of Engineering should plan, schedule, and conduct verification
, activities which include verification of technical issues, i.e., ,
'- verification of technical adequacy. !
i l The Division of Nuclear Engineering provided for ECTG review the copies of the FY 86 and FY 87 audit schedules (EA-I 65.03, " Quality Audit l Schedule - Preparation and Distribution), as well as the instruction for technical and program audits (EA-I 65.04, " Engineering Assurance Internal Audit Program"). The schedules identified at least eight electrical l engineering audits in 1986 and additional ones in 1987, including an audit (Report BOS 860414 003) for the BFN Electrical Design Project. The guidance for verification of technical issues was verified to be included l in the DNE procedures.
Based on the above review, this NSRS item is closed. ,
I (Open) I-85-06-WBN-05, Underdevelopment of Established and Documented I Limited QA Prgqram and Failure to Incorporate the
! Established Limited QA Proqram Into Nutlear Quality Assurance Manual (NQAM)
The implementation of the limited QA program as established in OEDC-PRM-2QAI-2 was determined by NSRS to be inadequate. Also, the NQAM was determined to be inadequate in addressing the limited QA program as established by superseded OEDC-PRM-2QAI-2 document.
NSRS recommended the Division of Quality Assurance (DQA) identify the required "special controls" applicable to systems previously identified
> as " limited QA: in the NQAM. Appropriate line organizations should l
incorporate those requirements into the OE, OC, and NUC PR procedures for implementation by the appropriate offices. In the original report opplicable to Watts Bar, NSRS stated that in view of the fact that WBN had recognized security and fire protection as the only two systems for i
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ai '/. TVA EMPLOYEE CONCERNS- REPORT NUMBER: BFN-NSRS-2 SpECIAL PROGRAM
. REVISION NUMBER: 1 PAGE 50'OF'52' limited QA consideration, OE should perform an evaluation to ascertain-k the impact.of not implementing the established " limited QA": program on the other systems identified in OEDC-PRM-2QAI-2.
This NSRS issue is considered generically applicable to th'e other sites'.
-NQAM Part li Section 1.3, Revision 1, dated December 12, 1986 outlines E the limited QA program requirements for ONP. This is a. generic procedure which satisfies a portion of the NSRS recommendation. However, ECTG did not identify a basis for closing the overall item at BFN. Personnel l' interviewed at BFN indicated that items are now regarded as either quality or non-quality. There is no " limited QA." ECTG issued CATO-
- j. I-85-06-WBN-05 stating that BFN had not incorporated requirements of.NQAM Part 1, .section 1.3 'regarding limited QA into the site' DNE, DNC, ONP procedures. 'This. item remains open.
(Closed) .i-85-07-NPS-01, Manager of power and Engineering Appointment of
~
A Records' Manager NSRS found that no. upper management coordination entity.was available as e a_ focal point for resolution of programmatic problems regarding accumulation, storage,' t'ransfer, and retrieval of the records for
- h. procurement requiring Quality Engineering Branch (QEB) source inspection.
NSRS. recommended that an upper-level manager be appointed with scope to include all'past and future product verification records (formally'QEB records).
This issue was investigated by NSRS in 1983 at SQN and WBN, and was not
- identified as an issue at BFN. ECTG verified through interviews with QEB that, during the timeframe of the NSRS issae, all vendor records pertaining to BFN had been transferred to the site for indexing and storage.
[
Further investigation by ECTG determined that BFN Instructions QMI-446
- k. (which superceded OEB-EP-24.58), titled " Supplier Document Review" and QMI-450 (which superceded QEB-EP-24,37) titled " Contract Records Index
^
g and Filing" address the handling of vendor records at Browns Ferry.
>_ Based on the-interviews with QEB personnel and reviews of appropriate documentation, ECTG concludes that this issue has been adequately addressed'and is now closed.
L (Closed) I-95-10-BFN-01, Lack of Procedures for Handling Emplovoo G Concerns / Allocations I
L1 The'NSRS report stated that a plant notice was in place to provide guidance to employees in how to identify problems to their supervision, other plant groups, the NSRS, or the NRC. However, no procedures could i
be identified which covered the handling of employee-identified problems,
. safety concerns or allegations once received by supervision.
_]
5 TVA EMPLOYEE CONCERNS REPORT NUMBER: BFN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 51 OF 52 The NSRS recommendation was to develop and implement procedures which I provide guidance and instructions for plant supervisors in recognizing ,
P responding to, and overall handling of employee-identified problems, F safety concerns, or allegations.
1 I TVA's new ONP Employeo Concern Program (ECP) was implemented at all sites on February 1, 1986. The Browns Ferry Nuclear Performance Plan states that TVA established in this program a number of methods by which employee concerns can be received, not only through TVA supervision and management but also through the TVA ECP or the TVA Inspector General (IG). In the case of the ECP and the IG, confidentiality provisions have been provided. These methods provide an atmosphere where employees may l express concerns without fear of reprisal and foster (hopefully) an attitude which would improve employees' confidence in TVA's desire and
- ability to receive and resolve employees concerns. The key element of the now program is the Employee Concern Program Site Representative f (ECP-SR). The ECP-SR is a full-time employee at BFN who reports to the a Employee Concern Program Manager, who in turn, reports directly to the Manager of Nuclear Power. Presently, one Assistant Site Representative
" is supporting the ECP-SR. Two additional Assistant Site Representatives will be selected, increasing the total staff to four.
Also during February 1986, TVA began a substantial effort to evaluate and g
resolve employee concerns already identified through previous formal y programs. This work is being accomplished by the TVA Watts Bar Employee Concern Task Group (ECTG).
h Based on the established TVA programs for handling both old and new y amployee concerns, this NSRS issue is now closed.
[ (Closed) Fourteen Safoquards Items Identified In Section I 4
The following action was taken by ECTG to verify the closure of 14 NSRS j safeguards issues listed in section I: A review of documents, procedures, and TVA codes was performed to determine if reassignment of responsibility of the nuclear security program had been accomplished as indicated in memorandum L46 870520 884. This review determined that the Office of Nuclear Power now has overall responsibility of the nuclear security program, j The TVA Code XI has delegated the responsibility for managing the
( security program for TVA's nuclear power plants with Public Safety Service (PSS) providing equipment and training of the security force.
Other documents reviewed that outline the responsibility of nuclear
^ secur.ty by ONP are:
Procedure 0401.01 Procedure 0401.02 Procedure 0401.03
i p
L
- REPORT NUMBER: BFN-NSRS-2
. TVA EMPLOYEE CONCERNS SPECIAL PROGRAM r REVISION NUMBER: 1 PAGE 52 OF 52 Procedure 0401.04 Procedure 0401.05 Procedure 0402.01 ONP Directive 10.1 (Draft copy)
Policy and Organization Manual Volume 1 and 2 ONP organization charts TVA Nuclear Security Program Enhancement Security Personnel Training and Qualification Plan Based on thc= review of the above documentd, the 14 NSRS issues found in p.
NSRS reports R-82-01-PSS , R-83-16-NPS , and R-84-06-NPS : and the corrective action taken by ONP as outlined in memorandum L46 *S70520 884,
>. these issues are considered complete and closed.
i L.
6 . 0' ATTACHMENTS
$ CATD R-81-02-BFN-01 CATD R-81-04-YCN/NPS-01 l
CATD R-81-14-0EDC (BLN)-41
{
CATD R-83-18-NPS-02 CATD R-84-17-NPS-07 CATO R-84-17-NPS-08 R CATD R-84-17-NPS-09 f CATD R-84-32-NPS-01 yj CATD I-84-33-BFN-02 CATD I-84-33-BFN-03A CATD I-84-33-BFN-038 4
CATD I-14-33-BFN-04 CATD I-85-06-WBN-05
ECTG C.3
. v Attachm2nt A 4 Page 1 of 1 Revision 4 ECTG Corrective Action Tracting Docume'nt (CATD)
Applicable ECTG Report No. : BFN-NSRS-2
_INIT AI TION Immediate Corrective Action Required: O Yes O( Ne 1.
- 2. Stop Work Recommended: O Yes f( No R-81-02-RFN-01 4. INITIATION DATE 6-19-87
- 3. CATD No.__
- 5. RESPONSIBLE ORGANIZATION: BFN Site Director i NSRS Report R-81-02-BFN-01
- 6. PROBLEM DESCRIPTION:)E QR O NQR ECN PO 289, the working document of NRC IE 79-14, has not been completed regarding pipe tunnel supports. Tech Spec 3.5.C. __
' table 3.5-1. requirint two (2) RHR pump operation conflicts with operatint instruction OI-67, design criteria EFN-50-7023, and BFN's 57 which recuires the capacity of 3
_ commitment requirement NEB RAC 10
) pumps for operation of a three (3) unit plant.
O ATTACHMENTS 6-19-87 E
- 7. PREPARED BY: NAME Don Cossett t A (bs/4' _ DATE: 6/x /P7 M)/ h w DATE:
- 8. CEG-H .
3 CONCURRENCE:
- fMZ /a DATE: As-h v/r7 0 9. APPROVAL: ECTG PROGRAM MGR. - j CORRECTIVE ACTION j 10. PROPOSED CORRECTIVE ACTION PLAN: .
I h
n,,
O ATTACHMENTS _
DATE:
- 11. PROPOSED BY: DIRECTOR /MGR:
DATE:
- 12. CONCURRENCE: CEG-H: DATE:
,. ECTG PROGRAM MANAGER VERIFICATION AND CLOSE0UT m 13. Approved corrective actions have been verified as satisf actorily implemented.
l
. ,8 IITLE DATE SIGNATURE 5553T _
l .
l 1
ECTG C.3 Attachm:nt A ,
Page 1 of 1 l'
Revision 4 ECTG Corrective Action Tracking Docum'e'nt (CATD) i f -
d Applicable ECTG Report No.: B FN-N'3 RS-2 !
)
[ --INITIATION Immediate Corrective Action Required: O Yes % No {
1.
- 2. Stop Work Recommended: O Yes pl No 6-19-87
- 4. INITIATION DATE
- 3. CATD No._ R-81-04-YCN/NPS-01
- 5. RESPONSIBLE ORGANIZATION:
EFN Site Director NSRS Report R-81-04-YCN/NPS-02
- 6. PROBLEM DESCRIPTION: JLQR O NQR Q NEB.
No minimum safety review requirements had been established by Safety reviews had been curtailed when manpower was in short supply V
' or more pressing nt-ds existed.
O ATTACHMENTS ,
I h & W w f DATE: r 6-19-87 _,
- 7. PREPARED BY: NAME Do1Cossettt' C/Ja/t? l CEG-H d4645dL/w;c- - , DATE:
d 8. CONCURRENCE:
4' #M24 A DATE: ta,ye7
- 9. APPROVAL: ECTG PROGRAM MGR. I /
V CORRECTIVE ACTION k 10. PROPOSED CORRECTIVE ACTION PLAN:
h ';
ll) e
- p ,
O ATTACHMENTS DATE:
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
.. ECTG PROGRAM KANAGER Aa VERIFICATION AND CLOSEOUT j
- 13. Approved corrective actions have been verified as satisfactorily l implemented. 1 DATE e'
SIGNATURE TITLE l i
1 5553T l
(
s
ECIG C.3
' 4' Attachmant A
~Page 1 of 1 Revision 4
~
ECTG Corrective Action Tracting Documb'n t (CATD)
Applicable ECTG Report No.: BFN-NSRS-2 INITIATION
- 1. Immediate Corrective Action Required: 0 Yes @f No
- 2. Stop Work. Recommended: O Yes ps No i
- 3. CATD No.__R-81-14-0EDC(BLN)-41 4. INITIATION DATE 6-19-87
- 5. RESPONSIBLE ORGANIZATION: BFN - Site Director PROBLEM DESCRIPTION: jf QR O NQR NSRS Report R-81-14-OEDC(BLN)-41 6.
pNE has not established a formal approved trainint protram for OAB auditors involved in conducting DNE audits of BFN design activities.
l
-s D ATTACHMENTS Don Cossett 'd.4ay ( C s/ R 1-DATE: 6-19-87
- 7. PREPARED BY: NAME 6 42u/f 7 6)24<l/sc- . DATE:
- 8. CONCURRENCE: CEG-H _
4/2WF 7
! 9. APPROVAL:- ECTG PROGRAM MGR. # /f/#Mll
- 4 DATE: '
/
/
- j. CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
i l
} -
~
O ATTACHMENTS DATE:
t 11. PROPOSED BY: DIRECTOR /MGR:
DATE:
- 12. CONCURRENCE: CEG "'
DATE:
, ,. ECTG PROGRAM MANAG.
a VERIFICATION AND CLOSEOUT h'
j 13. Approved corrective actions have been verified as satisfactorily implemented.
[
1 TITLE DATE SIGNATURE L
i ;
l 5553T i n
- ~ ,
ECTG C.3
Attachm:nt A Page 1 of 1 Revision 4 ECTG Corrective
- Action Tracting Docum'e'n t (CATD) -
4 INITIATION Applicable ECTG Report No.: BFN-NSRS-2 2 1. Immediate Corrective Action Required: O Yes 5 No P 2. Stop Work Recommended: O Yes p[ No
- 3. CATD No. R-83-18-NPS-02 4 INITIATION DATE 6-19-87 6 5. RESPONSIBLE ORGANIZATION: BFN Site Director
- 6. PROBLEM DESCRIPTION: E1QR O NQR NSRS Report R-83-18-NPS-02
$ The FSAR, Technical Specifications, and TVA Code XI do not reflect-current organizational structures. These documents need to be k.
revised to reflect the current organizational structures.
-7 .
O ATTACHMENTS _a
- 7. PREPARED BY: NAME T"HTke Wavcaster 13e DATE: 6-19-87
- 8. CONCURRENCE: CEG-H (Lf2TVAs ~ DATE: c/av//7
$ 9. APPROVAL: ECTG PROGRAM MGR. /f/465Z '
4 DATE: l'/1%97 b $ /
f CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
A b
d 8
5
- h. 0 ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
i DATE:
- 12. CONCURRENCE: CEG-H:
ECTG PROGRAM KANAGER DATE:
VERIFICATION AND CLOSE0UT M
g 13. Approved corrective actions have been verified as satisfactorily implemented.
or
- SIGNATURE TITLE DATE 5553T l
l l
' , J.y ,,.
.- . ECTG C.3
~ ' ' Attachm'Jnt A
[. . Page 1 of 1 Revision 4 ECTG Corrective _
Action Tracting Document ~ l (CATD)
L Applicable ECTG Report No._: BFN-NSRS-2
' INITIATION _
1, Immediate Corrective Action Required: O Yes I No
- 2. Stop Work. Recommended: O Yes )2I. No .
CATD No, R-84-17-NPS-07 4. INITIATION DATE ..6-25-87 3.-
- 5. RESPONSIBLE ORGANIZATION:
BFN Site Director
- 6. PROBLEM DESCRIPTION: 38(QR O NQR Browns Ferry's Materials of Manage-the Project ment Improvement Project #7024 must complete task D14
{ Managers Report dated April 13. 1987 to develope a comprehensive shelf life program. This tast is currently scheduled on the site j P-2 schedule under Materials Management Improvement Proiect #7024. '[
Verification of completion of this task will close this item.
O ATTACHMENTS DATE: 6-25-87 ~
- 7. PREPARED BY: NAME7ob Brown . EV _ DATE: 4/J4 /17
- 8. ' CONCURRENCE: .CEG-H (444.aw.
ECTG PROGRAM MGR.
- /2M/., /e DATE: //2#/B 7 f 9. APPROVAL: / /
(/
f- CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
f L
e h _
- O ATTACHMENTS DATE:
I 11. PROPOSED BY: DIRECTOR /MGR:
DATE:
- 12. CONCURRENCE: CEG-H:
DATE:
. .. ECTG PROGRAM MANAGER 0
i VERIFICATION AND CLOSEOUT '
c.
4 13. Approved corrective actions have been verified as satisfactorily q implemented.
)'
e, si TITLE DATE SIGNATURE
=
- - - i
_____-________0
c .;,
, , , 4 _. - ECTG C.3
,. Attachment A-n Page 1 of 1 Revision 4 ECTG Corrective
' Action Tractinr. Document * *
(CATD)
Y ,
Applicable ECTG Report No.: BFN-NSRS-2 INITIATION Immediate Corrective Action Required: O Yes R No 1,
s.' '
- 2. Stop Work. Recommended: O Yes R No 6-25-87
- 4. INITIATION DATE
- 3. CATD No._ R-84-17-NPS-08 RESPONSIBLE ORGANIZATION:
BFN Site Director-5.
PROBLEM DESCRIPTION: J& QR O NQR Browns Ferry's Materials Manage-
- 6. must cornplete tast F1 of the Proiect rnent__
e Improvement Proj ect //7024
{ Managers Report dated April 13, 1987 to enhance the MAMs inventory This task is currently scheduled on the site j
} analysis program.P-2 schedule under Materials Management Improvement Projec i,
verification of' closure of tast F will close this item O ATTACHMENTS DATE: 6-25-87 !
- h. PREPARED BY: NAME N ob Brown- /,M --
'7.
(44A /h _. DATE: 4 /.n / r 7
- 8. CEG-H:
CONCURRENCE:
ECTG PROGRAM MGR. #f##2 A DATE: J/JPN7 'l,
- 9. APPROVAL:
y i /
)
' CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
t er Y
y W -
~
O ATTACHMENTS DATE:
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:. )
- 12. CONCURRENCE: CEG-H: DATE:
. . , ECTG PROGRAM MANAGER VERIFICATION AND CLOSE0UT n
N 13. Approved corrective actions have been verified as satisfactorily implemented.
i , TITLE DATE SIGNATURE I-6 l
_ - -_ _o
= ,
1
^
')
,;d* .;
ECIG C.3 {
., .,. Attachant A {
Page 1 of 1 Revision 4 ECTG Corrective Action Tracting Document'*
(CATD) i Appilcable ECTG Report No.: BFN-NSRS-2 f INITIATION. ,
'Immediate Corrective. Action Required: O Yes 12( No
} 1. 38(, No
- 2. Stop Work Recommended: O Yes 4.. INITIATION DATE 6-25-87
- 3. CATD No. R-84-17-NPS-09 RESPONSIBLE ORGANI2ATION:
BFN Site Director 5.
- 6. PROBLEM DESCRIPTION: 21 QR D NQR Browns Ferry's Items Evaluation Group must complete a site specific evaluation of installed "Commer h'
cial Grade" items and those warehoused prior to BF Unit 2 restart.
16.1-02 Revision 1 titled " Dedication Program for Commercial Wylie Grade Con-j Materials, Parts or Components for CSSC Application."
tract TV-56071A and Bechtel Contract TV-65375A will assist TVA in this task. Completion of these actions will close this issue.
O ATTACHMENTS DATE: 6-25-87 h '
- 7. PREPARED BY: NAMEk ob R Brown _M-C - , DATE:. 6/n /19
- 8. CONCURRENCE: CEG-H dN4/w ,
f 9. APPROVAL: ECTG PROGRAM MGR. -
- M M DATE: 4/./W4,7
- p. 7y
_f CORRECTIVE ACTION _
'10. PROPOSED , CORRECTIVE ACTION PLAN:
h9 et I
O ATTACHMENTS 1
DATE: f
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
.. ECTG PROGRAM MANAGER VERIFICATION AND CLOSEOUT glf
{
E 13. Approved corrective actions have been verified as satisfactorily ;
A implemented.
n k jj TITLE DATE SIGNATURE l
l 1
i
- 5 !
- l. ,, ,
l
s
- 4. '
ECTG C.3
'' Attachm2nt A Par,e 1 of 1 Revision 4 ECTG Corrective
$ Action Tracting Document' (CATD)
~
INITIATION. Applicable ECTG Report No.: BFN-NSRS-2
)
a
'1. Immediate Corrective Action Required: O Yes % No j
- 2. Stop Work Reconsnended: O Yes O!C No
- 3. CATD No. R-84-32-NPS-01 4. INITIATION DATE 6-19-87 I. 5. ' RESPONSIBLE ORGANIZATION: BFN Site Director
NSRS Report R-84-32-NPS-01
- 6. PROBLEM DESCRIPTION: 15 QR O NQR h An integrated qua'lity program for TVA nuclear facilities has not been completed or implemented that includes (
1 - Identifying activities affecting quality
). 2 - Identifying CSSC to which the cuality program is applied
'3 - Identifying standards outside the scope of regulatory l
requirements A - Improvement of quality programs and procedures 0 5 - Incorporating vendor data into conf 5guration management
- ., O ATTACHMENTS PREPARED BY; NAME79im Gorham M C_ DATE: 6-19-87 f 7.
- 8. CONCURRENCE: =CEG-H (lM4bNM , . _ DATE: 6 /.N/ r7
- 9. APPROVAL: ECTG PROGRAM MGR. [f#8/;M /,4 DATE: Mv47 l:..
y t- y CORRECTIVE' ACTION _
)
Y 10.. PROPOSED CORRECTIVE ACTION PLAN:
f b
i 4 -
l S O ATTACHMENTS )
DATE:
(- 11. PROPOSED BY: DIRECTOR /MGR:
DATE: <
- 12. CONCURRENCE: CEG-H:
.. ECTG PROGRAM MANAGER DATE: )
VERIFICATION AND CLOSE0UT
?
g,
- 13. Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE l
5553T _
t ECTG C.3
- Attachmsnt A Page 1 of 1 Revision 4 l ECTG Corrective Action Tracting Docum'eht l (CATD)
INITIATION Applicable ECTG Report No.: BFN-NSRS-2
- 1. Immediate Corrective Action Required: D Yes R No l
- 2. Stop Work Recommended: O Yes Ef No i
- 3. CATD No. I-84-33-BFN-02 4. INITIATION DATE 6-19-87
- 5. RESPONSIBLE ORGANIZATION: BFN Site Director PROBLEM DESCRIPTION: p( QR O NQR NSRS Report I-84-33-BFN-02 (
6.
BFN-DNE has not provided verification documentation for the following:
- 1. That DNE engineers have been made aware of the fact that stress allowables are not to be exceeded.
- 2. That the examples of excess stresses given in NSRS report l I-84-53-BFN-02 section IV.D.3 hase been corrected.
e 3. That a review has been performed of support calculations to ensure that all cases exceeding allowable stress have been identified and corrected. (Note: Pipe stress is addressed by CATD 218 04 BFN 01). O ATTACHMENTS
- 7. PREPARED BY: NAMfTA/ David Vinchester /a# DATE: 6-19-87
- 8. CONCURRENCE: CEG-H dNA A s.. DATE: C/u /f7
- 9. APPROVAL: ECTG PROGRAM MGR. MMM /A DATE: //2 #e7 V ! Y CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
I i
O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSEOUT
- 13. Approved corrective actions have been verified as satisfactorily implemented.
,o SIGNATURE TITLE DATE 5553T g %
.. q, ; . -
- i ECTG C.3
- ~ * '* Attachmsnt A Pkge 1 of 1 Revision 4 ECTG Corrective Action Tracking Do c unte'n t (CATD) h
. ,IJITI ATION Applicable ECTG Report No.: BFN-NSRS-2
[
- 1. Immediate Corrective Action Required: O Yes E No.
- No
- 2. Stop. Work Recommended: O Yes
- 3. CATD No. I-84-33-BFN-03A 4 INITIATION DATE 6-19-87 Lf ' 5. RESPONSIBLE ORGANIZATION: BFN Site Director PROBLEM DESCRIPTION: pf.QR D NQR NSRS Report I-84-33-BFN-03A 6.
BFN Piping Analysis Section and employees working on the 79 program are not receiving adeauste training and technical guidance.
- h. (I.E. - Issue a controlled handbook and train on its use. Provide verification documentation for the above and establish a mechanism
- i. for periodic updates to program changes.)
~ l .'
I-84-33-BFN-03A Addresses issuance of controlled hnndbnnv
- n O ATTACHMENTS b Don Owen.hJ e M m DATE: 6-19 7. PREPARED BY: NAME
- 8. CONCURRENCE: CEG-H h . DATE: - 4 /.su/ F7
- 9. APPROVAL: ECTG PROGRAM MGR. ## #fA //a DATE: #f4' We 7 k --
p i ;
CORRECTTVE ACTION h<
- 10. PROPOSED CORRECTIVE ACTION PLAN:
s.
. 1
~~
Eb O O ATTACHMENTS
- DATE:
...-+ 11. PROPOSED BY: DIRECTOR /MGR:
DATE:
- 12. CONCURRENCE: CEG-H:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSEOUT 4
- 13. Approved corrective actions have been verified as satisfactorily W implemented.
~
l
[ '
ii SIGNATURE IITLE DATE 1.
5553T
- = %
i , . e' . *
ECTG C.3
, s Attachm2nt A
- c. Page 1 of 1 ,
Revision 4 ECTG Corrective Action Trackint Docum'eht
( CATD ).
Applicable ECTG Report No. BFN-NSRS-2 INITIATION 1, Immediate Corrective Action Required: O Ye.s d( No Stop Work Recommended: O Yes DC No
- 2. 4. INITIATION DATE 6-19-87
- 3. CATD No._ I-84-33-BFN-03B
- 5. RESPONSIBLE ORGANIZATION: BFN Site Director NSRS Report I-84-33-BFN-03B
- 6. PROBLEM DESCRIPTION: QCQR O NQR BFN Pipinr Analysis Section and employees workint on the 79-14 program are not receivint adequate trainint and technical Kuldance.
Provide (I.E. - Issue a controlled handbook and train on its use.
verification _ dor.ur.entation for the above and establish a mechanism for periodic updates to program change. )
' I-84-33 BFN-03B Addresses training on controlled handbook a .
O ATTACHMENTS
{ Don Owen M ~ h DATE: 6-19-87
- 7. PREPARED BY: NAME * /u / r 7
- 8. CONCURRENCE: CEG-H- #AAL4A.a ,, . DATE: !
- l. #I#MM44 /a DATE: //29Af7
$1 9. APPROVAL: ECTG PROGRAM MGR.
f / /
l' 1
Cyt;KECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
?
b M
-O ATTACHMENTS DATE:
- 11. PROPOSED BY: DIRECTOR /MGR:
DATE:
- 12. CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER VERIFICATION AND CLOSE0UT 4 13. Approved co"rective actions have been verified as satisfactorily implemented.
- e. TITLE DATE SIGNATURE l
5553I _
k 46
p .-
[a .
- ECTG C.3 r
Attachmant /.
, g- -
Page 1 of 1 Revision 4 ECTG Corrective Action Tracking Docum'ent (CATD)
JApplicable ECTG Report No.: BFN-NSRS-2
' INITIATION-Immediate Corrective Action Required: O Yes pi No ,
1.
- 2. :Stop Work Recommended: 0 Yes N No
-3. CATD No. I-84-33-BFN-04 4 INITIATION DATE 6-19-P7
- 5. RESPONSIBLE ORGANIZATION: BFN Site Director NSRS Report I-84-33-BFN-04
- 6. PROBLEM DESCRIPTION: % QR O NQR Verification Documentation is not available indicating that
" Piping Analysis Sections design calculations have not been verified by an independent checker.
O ATTACHMENTS j NAM F Don Owen ,t h DATE: 6-19-87
- 7. PREPARED BY:
CEG-H llM L / h ., DATE: 4 /ht/ P7 i 8. CONCURRENCE:
- (#MM, /M DATE: M/2#9 7 l 9. APPROVAL: -ECTG PROGRAM MGR. i ( /.
COLRECTIVE ACTION f =.
h 10. PROPOSED CORRECTIVE ACTION PLAN:
l i i h
1
- O ATTACHMENTS DATE:
k 11. PROPOSED BY: DIRECTOR /MGR:
DATE:
- 12. CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER
- g. ,,
VERIFICATION AND CLOSEOUT ]
g i M
if 13. Approved corrective actions have been verified as satisfactorily l l
implemented. l
' TITLE DATE SIGNATURE j
5553T s
s p
_-___________3
n ,: -
'~
ECTG C.3 1l(*
C- Attachm2nt A Page 1 of 1 Revision 4 ECTG Corrective i Action Track. int Documo'nt 1 (CATD)-
~
)
l INITIATION _ Applicable ECTG Report No.: BFN-NSRS-2
- 1. Immediate Corrective Action Required: O Yes E No
- 2. Stop Work Recommended: 0 Yes J8. No
- 3. CATD No. I-85-06-VBN-05 4 INITIATION DATE' 6-19-87
- 5. RESPONSIBLE ORGANIZATION: BFN Site Director
- 6. PROBLEM DESCRIPTION: )2 QR O NQR - NSRS Report I-85-06-VBN-05 Il BFN has not incorporated the requirements of NOAM Part 1 Section 1.3' regarding limited OA into the site OE, OC, and ONP procedures.
a O ATTACHMENTS I 7. PREPARED BY: NAME Don Cossett ,(7 b /4 o ef CDATE: 6-19-87
- 8. . CONCURRENCE: CEG-H h. DATE: (,/se/ E >
- 9. ~ APPROVAL: ECTG PROGRAM MGR. ## E/2 Et DATE: /,h ## 7-l --
r y .,- s.
CORRECTIVE ACTION
'10 . ' PROPOSED CORRECTIVE ACTION PLAN:
i j' i l
t O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSEOUT l l
- 13. Approved corrective actions have been verified as satisfactorily I implemented. j
.l SIGNATURE TITLE DATE
. 1 5553T ,
1