ML20237K808
| ML20237K808 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Bellefonte, 05000000 |
| Issue date: | 07/23/1987 |
| From: | Cossett D, Gass K TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18032A532 | List: |
| References | |
| BLN-NSRS-1, BLN-NSRS-1-R, BLN-NSRS-1-R00, NUDOCS 8709080033 | |
| Download: ML20237K808 (23) | |
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'TVA EMPLOYLI CONCERN REPOR1 NUMulR.
BL N-NURG-1 l
i SPECIAL PROGRAM REPORl 1YPE -
Dellefunte Nutleur Plant Llement Rt VISJON NUMBL R ;0 T37tE Review of Nuclear Safety Review Stotff Stc<rtup Items at Bellefonto i
REASON FOR REVISION:
N/A
SUMMARY
STATEMENT: The 18 items in this report were identified by the Nuclear Safety Review Staff (NSRS) and were assigned to the Employee Concerns Task Group (ECTG) for verification and closure. The verification activities are described in this report.
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SIGNATURE DATE CONCURRENCES
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l SIGNATURE Dt5TE SIGNATURE" DATE APPROVED BY:
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ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) j l
"SRC Secretary's signature denotes SRP concurrences are in files.
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1 B709080033 G70828 PDR ADDCK 05000259 P
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l TENNESSLI VALLEY AUTHORITY UROWNS FERRY NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTilER UllES CEG Subcategory:
Dellefonte Nuclear Plant - NSRS Classical Items Element:
Review of Nuclear Safety Review Staff Startup Items At Bellefonte Report Number:
BLN-NSRS-1 i
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' Review of Nuclear' Safety Review Staf f L (NSRS) Open Items Requiring Resolution -
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.at.Bellefonte. Nuclear Plant (BLN)~ prior to start ap.
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Introduction-
,NSRS conducted reviews of activities at Bellefonte Nuclear Plant (BLN)
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during'its span of overview responsibility from 1979 to 1986.
NSRS items-remaining open in 1987 have been examined by the Employee Concerns Tast Group.(ECTG).
i ECTG examined the status of:open NSRS issues. including.those identified specifically for BLN as well as other sites' issues which could have' generic' applicability at BLN, In.all..a total of 86 issues were.
considered applicable to BLN-including 18 requiring resolution prior to startup.. The status of these startup issues is the subject'of'this BLN-NSRS-1 report, with the status of the 68 non-startup' issues to be addressed in a subsequent report, BLN-NSRS-2.
The status of the.18 NSRS startup issues for BLN is as follows:
Closed R-80-05-SQN-4B Configuration Control Open F-81-22-BLN-01 Incomplete Documentation of Pipe Break
' Evaluation Openl R-81-22-BLN-02 Inadequate Justification of Exceptions to Regulatory Guidance Closed R-84-17-NPS-10 Commercial Grade Items With QA Level I and II Designations Closed R-84-17-NPS-11 Quality Verification for Commercial Grade Items Closed R-84-17-NPS-12 Receipt Inspection of QA Level I and II Items by Field Quality Engineers Closed R-84-19-WBN-01 Clear Identification of Purposes and Uses of All Controlled Documents Closed R-84-19-WBN-06.
Instantaneous Trip Settings of the Breakers for Motor Operated Valves Open R-84-19-WBN-07 Development of Criteria for Cable Tray Fill Level and QA Inspection Open R-84-22-BLN-02 Adequate Design Martin for Decay Heat Removal Isolation Valve Opening Closed-R-84-25-BLN-01 Resolution of Conflict between the FSAR and Design Criteria'of Main Steam System Design Basis Page 1 of 13
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Closed R-84-25-BLM-02
-Design Modifications to Proeide. Redundancy in the Isolation of Steam Lines as Required by NUREG40338 OpenL I-84-34-SQN-03 Availability of the Material Certification and Requirements for. Heat Number Sort Prirtout Entries Open.
I-85-06-WBN-01' The Adequacy of.the Dispositions for Identified Cable' Bend Radius Problems
' Open I-85-06-WBN-02 The Adequacy of the Program for Cable Pulling Activities Open' I-85-06-WBN-03 Voltage Drop land Short Circuit Current Determination and Verification Closed R-85-08-0E/NUC PR-1 Inadeguate OE Environment Qualification Procedure for Equipment Qualification by Similarity Closed: R-85-08-0E/NUC.PR-2 Inadequate OE and NUC PR Procedure for
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Initiating and Processing NCR-FE/ERs II.
Verificat. ion of NSRS Restart Items.
(Closed) R-80-05-SQN-04B, Configuration Control In the original review dated June 1980 NSRS concluded from electrical-
' deficiencies it found that configuration control was inadequate at SQN
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and made the following recommendations:
lEsteblish Critical' Systems, Structures, Components-(CSSC)
-configuration control Verify through walkdown of several CSSC systems that physical configuration agrees alth CSSC configuration control drawings Correct any deficiencies, and walkdown additional systems if significant problems have been found The configuration control issue was considered by ECTG to be potentially
' applicable to all sites.
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. The original NSRS report details were reviewed, as were later BLN
'l configuration control evaluations conducted by the Institute of Nuclear I
. Power Operation (INPO, 1984) and NRC (1985 Systemetic Assessment of Licensee Performance). Additionally, BLN guality control procedures
- related to the issue were reviewed and discussions were held with the BLN f
document. control and electrical / instrumentation supervisors.
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y BLN. guality/ control procedure BNP-QCP-9.3, R-13 '". Configuration Drawing n;
Control" covers the development of the System Configuration Control Drawing List.(SCCDL), the operation of.the Drawing. Control Center (DCC), the certification of as-construded drawings,.the: updating of.the Drawing Management System (DMS), and the approval of plant configuration for fuel loading. Procedure BNP-QCP-9.4, R-8 " Work Plans" applies to completion and modification work on plant.eguipment, systems,'and structures.
The 1984 INPO report identified a drawing control weakness; the 1985 NRC Systematic Assessment:of Licensee Performance (SALP) report did not identify
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deficiencies with dr. wing control or onsite design activities. The BLN document control and electrical / instrumentation supervisors both indicated confidence in the control of configuration. based on the following:
Work plans do not get closed until the drawings are changed per the work plan.
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Temporary altecativns control forms are used to contre >l configuration l
documentation.
Terminations cards are used extensively.
Tomporary installation or omissions documents are used.
Drawings are marked up and checked before transfer to nuclear power.
l Based on the interviews and documentation review, ECTG concludes that the NSRS issue is being addressed adequately at BLN. This issue is closed.
(0 pen) R-81-22-BLN-01, Incomplete Documentation of Pipe Break Evaluation This routine NSRS review covered the analysis of postulated high energy pipe ruptures outside, containment;at BLN.
NSRS concluded that the pipe break evaluation appeared to be adequate to, meet regulatory requirements and commitments, liowever, NSRS found the design basis for features which actively mitigate the consequences of pipe breaks was not adequately documented in the
. pipe break evaluation to ensure that' future des'ign changes do not invalidate the pipe break evaluation.
ANSI N45.2.11, section 3.1, requires that design bases be documented, s a F3RS Recommended that DNE document the basis for concluding that a particular
, pipe break analysis results in acceptable consequences tu order to facilitate evaluation of future design changs.. AIL design features that are specifically provided to actively'airdgate the consequences of a pipe break should be identified with respective design criteria, o
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'In a response of August 9,1985, _(F03 850809 70J ) DNE stated that the BLM system descriptions, when issued, wou3d address the NSRS concernfin an appropriate way.
DNE stated thut the pipe rupture specific design criteria, which are the working documents and which contro) the work had already been updated to reflect the NSRS concern.
CEB Report 77-10 " Evaluation of tho Effects of Postulated Pipe Ruptures Outside Containment" would be revised to reflect updated documentation.
ECTG reviewed the-revised CEB Report 77-10, but could not specifically verify
.that all issues were completely covered. An independent verification that report CEB 77-10, revision 1, adeguately reso3ves NSRS issue R-81 22-BLN-03 is required.
CATD'R-81-22-BLN-01 was issued.
This_ item remains open.
(0 pen) R-81-22-BLN-02, Inadeaunte Justification of Exceptions to Regulatory Guidance The BLN Final Safety Analysis Report (FSAR), section 3.6. commits TVA to document and justify less conservative criteria than those Siven in standard review plan sections 3.6.1 and 3.6.2.
Contrary to the above, no justification for using the 1-percent rule was found.
I NSRS recommended that DNE provide justification of the above exception to
. regulatory Buidance.
In their response (EDC 820405 013), DNE stated they would incorporate the justification for the I-percent rule in CEB Report 77-10 and would modify wording to avoid further misunderstanding 6 particularly in the area of design classification.-
In a followup response of August 9, 1985, (F01 850809 701) DNE stated that the BLN system descriptions, when issued, would address the NSRS concern in an
' appropriate way.
DNE stated that the pipe rupture specific design criteria, which are the working documents and which control the work, had already been updated to reflect the NSRS concern.
CEB Report 77-10 " Evaluation of the Effects of Postulated Pipe Ruptures Outside Containment" would be revised to reflect updated documentation.
ECTG reviewed the revised CEB Report 77-10, but could not specifically verify that all issues were completely covered. An independent verification that report CEB 77-10, revision 1, adequately resolves NSRS issue R-83-22-BLN-02 is required.
CATD R-81-22-BLN-01, noted above also includes this issue, This item remains open.
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(C]osed) R-84-3 7.NPS-10, Commercial Grade Items with QA Levels I ard II Designations In the original report NSRS found that commercial grade items were being purchased with little or no QA requirements or from vendors or manufacturers without TVA approved QA programs and classified as QA Leve) I and II.
That practice was contradictory to the purpose of having QA Level I and II items with considerable QA documentation attesting to the items suitability for fulfilling an intended function. NSRS recommended that items purchased with no QA requirements or no requirements for material certification (C0C, CMTR) or from vendors or manufacturers without TVA-approved QA programs should not be purchased with a QA Level I and II designation for use in nuclear power installations.
In response to identified problems of the type cited by NSRS, TVA has established an on-going program for assuring proper control over purchased material and items. The specific program for evaluating items purchased with no QA requirements or no requirements for material certification, or from vendors or manufacturers without TVA-cpproved QA programs is described in NQAM, part I, Section 2.7.2, " Dedication of Commercial Grade Items,"
ECTG reviewed details of the original report, applicab.c procedures, and related documentation.
Interviews concerning the issue were conducted with the quality assurance and procedures supervisors.
ECTG's review of the NSRS issue at BLN did not identify examples of the degradation of quality and/or qualified equipment from the installation of commercial grade parts. The site procedure, QCP 10.55 " Control of Replacement Items" addresses adequately the use of commercial gride parts and components in quality equipment.
Based on the ECTG review, this issue is closed at Bellefonte.
(Closed) R-84-3 7-NPS-11. Quality Verification for Commercial Grade Items In the original report NSRS stated that the use of commercial grade items as basic components places the responsibility for assuring that the items will function as intended under all conditions solely upon TVA. The QA progrea within TVA, at the time of the NSRS review, was not capable of providing that assurance because it did not include a receipt inspection program or audit of the vendor's QA program for commercial grade items. NSRS recommended that NUC PR establish a receipt inspection program which includes mechanisms such as audit of vendor's QA program, verification of certificate of conformance, etc., for replacement commercial grade items that will be dedicated as basic components or parts thereof, that would provide documented assurance that the items will function as intended.
In response to identified problems of the type cited by NSRS, TVA has i
established an on-going program for assuring that received items satisfy requirements.
The receipt inspection program is described in NQAM Part I Section 2.7.2, Revision 1, " Dedication of Commercial Grade Items", and in BLN site procedure BNP-QCP-10.55, " Control of Replacement Items".
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ECTG verified that the BLN site procedure provides for verification of certificate of conformance and other documentation for commercial grade items that will be dedicated as basic components for Quality Level I and II equipment. Additionally, a review of other ECTG investigation reports concerning receipt inspection, as well as discussion with the DNQA Quality Engineering supervisor did not identify instances of inadequate receipt inspections at BLN.
Based on the above ECTG review, this NSRS item is closed at BLN.
(Closed) R-84-17-NPS-12, Receipt Inspection of OA Level I and II Items By Field Quality Enr.ineers The NSRS report found that TVA did not require use of qualified inspectors for receipt inspections concerning commercial grade items to be dedicated as basic components in quality equipment.
NSRS recommended that receipt inspections be performed by Field Quality Engineers or other inspectors qualified to ANSI N45.2.6.
TVA's requirements for qualified inspectors are now provided in the Nuclear Quality Assurance Manual Part III, Section 2.2, Revision 1, " Receipt, Inspection, Handling, and Storage of Materials, Components, and Spare Parts".
QC inspectors for parts for Quality Level I and II items are qualified to TVA procedures consistent with ANSI N45.2.6.
ECTG reviewed the original NSRS report, the NQAM requirements, and ECTG report 801.04 " Procurement". Additionally, a discussion of the issue was conducted with the DNQA Quality Engineering supervisor.
Based on this review activity.
ECTG determined that the NSRS recommendations for use of qualified inspectors are being implemented satisfactorily at BLN.
This issue is closed.
(Closed) R-84-19-WBN-01, Clear Identification of Purposes and Uses of All Controlled Documents In the original report, NSRS identified instances at WBN where logic and control drawings did not agree with electrical drawings and termination lists.
Following review for generic applicability, this NSRS item was assigned by ECTG to all sites for review and correction as needed.
ECTG reviewed the original report and responses to it.
Additionally, several other reviews concerning BLN design control and drawing control were evaluated as follows for their assessment of the BLN controls.
The latest NRC Systematic Assessment of Licensee Performance (SALP) for BLN covering the period March 1984 through May 1985 did not identify deficiencies in the site design activities or drawing control system.
TVA Nuclear Quality Assurance Audit QBL-A-87-0009 found the drawing files in the plant well maintained and in order. The Institute for Nuclear Power Operation (INPO) Report June 5, 1984 did not cite deficiencies but did recommend improvements be made in the control of drawings during constru..lon and in control of permanent plant records.
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Nonconformance report NCR BLN QAB 8101 was issued to address the WSRS finding..The NCR was closed July 5, 1983 (BLp 830705 019) following
' correction of discrepancies.. BLN stated that the erro's in logic were of a random nature and did not indicate a generic problem.
The Office of Engineering (OE) responded to.NSRS October'1, 1984 (QMS 5840928 201) that the
' issue was considered closed at Bellefonte.
Based on the history of logic / control drawings and electrical drawings at BFN, WBN, and SQN, and the stages of construction at these plants compared to BLN, ECTG determined that BLN does not share their problem.
This NSRS issue is closed for BLN.
(Closed) R-84-19-WBN-06. Instantaneous Trip Settinr,s of_the Breakers for Motor-0perated Valves (MOVs)
The original NSRS report for WBN stated that instantaneous trip settings for motor-operated valve breakers were not in accordance with Engineering Design 1.'
(EN DES) criteria and vendor recommendations.
NSRS recommended that instantaneous trip breakers be set in agreement with the National Electric Code (NEC), and that WBN documentation reflect the proper values.
ECTG's generic review of the NSRS item assigned the item to all sites for evaluation.
BLN's circuit protection sizing and settings are controlled by the Motor Control Center (MCC) Circuit Schedule which is a design issued drawing.
Before any equipment is energized, a functional test and a motor rotation is performed in accordance with BLN procedure BNP-CTP-3.17 Revision 8,
" Electrical / Instrumentation Functional and Motor Rotation and Performance".
Circuit components (breaker size, settings, fuses, e.g.) are verified to the circuit schedule and the drawing is recorded on the procedure test package verification sheet.
Based on the ECTG verification that circuit protective devices are clearly defined, controlled by-preenergization and energization tests, and verified-for adequacy by Quality Control, this NSRS issue is closed at BLN.
l (0 pen) R-84-19-WBN-07, Development of Criteria for Cable Tray Fill i
Level and OC Inspection In the original review at WBN, NSRS concluded that criteria should be developed for field use to control actual cable tray fill levels and to provide a basis for Quality Control (QC) inspection.
ECTG's generic review of the item found it potentially applicable to all sites including BLN.
ECTG Report CO-10900 " Cable" examined the cable tray fill issue and assigned CATD 10900-NPS-5. The corrective action plan (CAP) for the CATD is for each site to evaluate any existing overfill conditions and correct as needed.
Closure of the ECTG CATD 10900-NPS-5 will close NSRS item R-84-19-WBN-07.
At i
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(0 pen) R-84-22-BLN-02, Adequate Desir,n Mart n for Decay Heat Removal i
Isolati.on Valve Opening.
The NSRS performed a review of the Decay Heat Removal System (DHRS) at Bellefonte Nuclear Plant (BLN) in 1984. This review was restricted to a functional review of the system.
One of the reviewed areas concerned adequacy of the design margin for the DHR Isolation Valve opening.
FSAR Figure 5.2.2-3 indicates that the DHR section isolation valves must be open when the reactor coolant temperature f alls below 305"F to ensure adequate low temperature reactor vessel overpressure protection.
Bellefonte General Operatin6 Instruction BLG01-IC also requires the operator to open the DHR isolation valves at 305'F.
The DHR pump equipment specification, B&W document number 08.1130000007-07, lists the maximum liquid temperature of the pump suction as 305"F.
Thus it appears that there is no margin in the desitn for l
instrument error and operator action.
NSRS recommended that additional temperature mar 61n be incorporated into the DHRS desi6n and be documented ir, the DHRS design basis.
The Bellefonte response to the subject NSRS report concerning the design of.
the Decay Heat Removal System (Memorendum from W.. R. Brown Jr., to K. W. Whitt dated May 28, 1985, RIMS B45 850528 251) states the following:
The DHR pump equipment specification (B&W document number 08-1130000004-07) also lists a desitn temperature to 350*F for the pump.
The 305'F maximum temperature is the normally expected worse condition at the DHR pump suction. The 350*F design temperature will allow a 45'F temperature margin for instrument error and operator action at the DHR pump suction when the DHR isolation valves are opened.
NSRS evaluated the DNE response and determined their concerns to be unresolved (QO1 850828 050).
ECTG's review did not resolve the technical differences between the DNE response and NSRS rejection. An independent evaluation of the DNE and NSRS positions should be accomplished to assure this NSRS issue has been resolved.
CATD R-84-22-BLN-02 was issued.
This item remains open.
(Closed) R-84-25-BLN-0'... Conflict between FSAR and TVA Internal Design Criteria NSRS concluded that TVA had not met the requirements of 10CFR50.34 inasmuch as the design bases for the main steam system which have been implemented were not accurately described by the BLN FSAR.
Specifically, TVA did not consider failure of the main steam isolation valves to be credible, as stated in the design criteria for the main steam system, since the valves have redundant closure signals.
However, the BLN FSAR did consider sin 61e failures of MSIVs. Therefore, the FSAR conflicted with TVA's internal desitn criteria.
NSRS recommended that TVA resolve the conflict between the FSAR and the design criteria and document the resolution in the design criteria or FSAR as appropriate.
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The Office-of Engineering responded'(B45'850537 263) with an explanation that l
the FSAR accurately reflected the bounding conditions for~ steam line breaks and that the assumptions used in the analyses were clearly stated.
- However, OE stated that the FSAR may not adeguately reflect TVA's design basis for the Steam Generator' isolation system.
l The NSRS R-84-25-BLN findings.and implementation status of the recommendations were investigated by ECTG and reported in ECTG Report 30711 " Nuclear Power Site' Program / Procedures." ECTG found acceptable the OE response
.(B45 850517 263). DNE committed IECTG Corrective Action Plan 30711, R2] to provide clarification to the FSAR as discussed in the memorandum noted above, before ' fuel load for BLN.
Based on the'above resolution and tracking of the item under CAP 30711, this NSRS item is closed.
(Closed) R-84-25-BLN-02, Main Steam System Design Does Not Meet Regulatory Requirements NSRS concluded that:the present main steam system design did not' meet q
regulatory requirements in the following area.
NUREG-0138, issue 1, allows, credit for the turbine stop valves in preventing a two-steam-generator blowdown after a steam line break and the failure of an MSIV.
However, the design arrangement at BLN is such that in the event of a break, as postulated in NUREG-0138, the closure of the turbine stop valves will not terminate the two steam generator blowdown since the steam lines are cross-connected by a 42-inch diameter header upstream of the stop valves.
Furthermore, the NRC in FSAR question 430.67 asked TVA to provide additional information in the FSAR concerning all flow paths between the MSIVs and the TSVs.
In TVA's response to this request, the 42-inch-diameter crosstie ~ header between the main steam lines was omitted. NSRS concluded that the answer to FSAR question 430.67 was not complete.
NSRS recommended that design modifications be made to provide redundancy in the isolation of steam lines as required by NUREG-0138 or that conservative analysis of a two-steam-generator blowdown event be completed which shows that the consequences are acceptable. Additionally NSRS recommended that the l
response.to FSAR question 430.67 be amended to more accurately reflect the
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design of BLN.
OE responded (B45 8505 17263)' that current design was acceptable and "
probably one of the more rigorous and conservative designs for steam generator l
I isolation in the industry " Additionally, the response stated that amendment of the response to the FSAR question was unnecessary "because the 42-inch header did not enter into the design basis or beyond the design basis assumptions, and was not related to the NRC's true concern (isolation of steam flowpaths)."
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The NSRS' R-84-75-BLH findings and implement ation - status.of : the~ reconuwndations
,were investigated by ECTG and reported in ECTG Report 30711 " Nuclear Power Site Program / Procedures.".ECTG found the OE r( ponse adeguate for BLN.
' committed [ECTG' CAP 30711-NPS-01] to provide FSAR clarifications.
Based on the above resolutions, and tracking of the item under CAP 30711-NPS-01, this NSRS item is closed at BLN.
(Open)'I-84-34-SQN-03, Availabilityoof_the_ Material Certification'and Requirements _for Heat Number Sort Printout Entries This March 15, 1985, NSRS report stated that there appeared to be inconsistencies in the compilation of required material certification and some
, ambiguity.in the program established to control it.
Specifically, NSRS c ould not conclude with certainty that the SQN Heat Number Sort Printout included only material with acceptable certification.
NSRS recommended that a history i
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of the Heat Number Sort be reconstructed to establish the program's purposes, controls, designed functions, actual functions, and data quality.
Following review by ECTG for generic applicability, this NSRS item was also assigned to other sites including BLN.
The ECTG Report MC-40703, " Material Control, Procedural Control Heat Code,"
dated September 26, 1986 examined the SQN status of this issue. The issue status at Bellefonte will be reported in ECTG subcategory report MC-40700,
" Procedural Control". The evaluation report is not complete at this time.
Completion of the ECTG 40700 evaluation and subsequent corrective action if necessary will close this item. At this time, the issue remains open.
(0 pen) I-85-06-WBN-01, The Adequacy of the Dispositions for Identified Cable Bond Radius Problems In the original review at Watts Bar, NSRS investigators determined that there was not sufficient manufacturers' documentation / justification / test data nor OE engineering basis to substantiate the final dispositions documented for NCRs or establishment of cablebend values for multiconductor cables. The available information, as well as the acceptance criteria for sampling used to justify the as-installed conditions, lacked engineering support. The report stated that OC was permitted by OE to bend the cables permanently to a radius of one-half of values which in 1981 were recognized to be an industry standard for minimum values to which a cable can be permanently bent. Although OE and OC's final disposition accepted the installed condition of these cables at WBN based on "0E/0C developed" values, NSRS questioned the validity of these i
values.
Following review for generic applicability, ECTG also initiated review of this issue at other sites including BLN.
ECTG's evaluation of the cable bend radius problem is reported in construction category. report'10900.
ECTG findings included those of the NSRS report.
CATD 10900-NPS-1 was issued to correct identified problems.
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<1 EAcceptable closures of ECTG CATD 10900-NPS-1 will close the NSRS issue.
At this' time the issue remains open.
(Open) I-85-06-WBN-02, The Adequacy of the Program for Cable Pulling Activities' In the July 1985 report, NSRS concluded that OE and OC's cable pulling programs were inadeguate and in violation of.the accepted industryLstandards and practices. The report' stated that Construction Specification G-38 had not defined the method for calculating maximum allowable tension for multicable pulls nor had it finally established the method of pulling multicables utilizing a break link.
Also, the industry considered the side wall pressure-as'a limiting factor for cable pulling activities.
Failure to ensure that maximum allowable' tension, as well as sidewall pressure, was not exceeded in any cable pulling operation. increased the potential for cable damage (insulation degradation). NSRS recommended that the construction
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specifications G-38 and G-40;be revised to incorporate resolutions to the identified problems.
Final adequacy of the present cable installation should then'be evaluated per the revised acceptance criteria.
ECTG considered this issue potentially applicable at all sites..The ECTG
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Construction Evaluation Group identified cable problems in report CO-10900-
" Cable".
CATD 10900-NPS-01 addresses the corporate problem of cable
-installation deficiencies.
Cable installation deficiencies at BLN are addressed in Problem Identific tion Report (PIR) BLN EEB B518. This PIR concerns effects of cable tension and sidewall pressure.
CATD I-85-06-WBN-02 has been issued pending completion and closure of pIRBLNEEB8518. The NSRS issue remains open.
(0 pen) I-85-06-WBN-03, Voltare Drop and Short Circuit Current Determination In NSRS report number I-85-06-WBN-3, the NSRS recommended that OE perform short circuit and voltage drop calculations for the Voltage Level 3 power circuits to ensure the adequacy of the size of the installed cable to perform its intended functions.
ECTG's generic review of the open issue found it potentially applicable to BLN.
NSRS noted that voltage drop calculations, when done, were based on the design projected estimated length and not the installed length.
Since cable length is the controlling factor-in determining acceptable voltage drop, NSRS recommended the calculations be performed based on actual installed length to ensure operability of equipment under worst conditions.
Based on a documentation review, ECTG determined that measurements of actual installed lengths had been completed at BLN with two exceptions.
CATD I-85-06-WBN-03 was issued to track completion.
This item remains open.
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' (Closed)fR-85-08-0E/NUC PR-01, Inadequate OE Environment Qualification Procedure for Equipment Qualification by Simil a. ri t y NSRS stated' that. the OE procedure for environmental qualification of SQN electrical equipment allowed qualification by " similarity" but contained no
. definite criteria defining what constituted a "similar"' item.
NSRS recommended that.these criteria be established-and incorporated into the TVA procedures governing environmental qualification of electrical equipment, and that the criteria be used to re-evaluate the qualificatiia status of electrical equipment previously qualified by similarity.
ECTG's review of this item found.it potentially applicable to BLN.
4 The verification activities included interviews with cognizant EQ personnel at
' SQN and.WBN. It was determined there were no design personnel on site at BLN who will be engaged in replacement of equipment quallfled by similarity.
EQ requirements, including those for qualifying by similarity, are included in Office of Engineering discipline interface document NEB-DI-125.01 " Program j
Requirements for Environmental. Qualification of Electrical Equipment in' Harsh
- Environment." -
Based on the provisions of current procedures, this issue is closed'for BLN.
(Closed) R-85-08-0E/NUC PR-2, Inadeaunte OE and'NUC PR Procedures for Initiating and Processing NCR-FE/ERs NSRS concluded that the OE and ONP procedures for processing nonconforming conditions reports (NCRs), failure evaluations (FEs), and engineering reports (ERs) were inadequate for assuring their timely initiation and processing.
NSRS recommended in-depth review of TVA's program and possible changes to provide for effective interface between participating TVA organizations, establishment of centralized tracking, and significant reduction in the time required'for processing and dispositioning.
ECTG reviewed the NSRS report, NQAM requirements, and the corrective action i
program implementation at the BLN site. A.new Conditions Adverse to Quality
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(CAQ) program with centralized tracking and specific time requirements was to be implemented at all sites by March 30, 1987.
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ECTG verified that the CAQ program is established in the Nuclear Quality Assurance Manual (NQAM), Part I, Section 2.16, Revision 2.
At BLN, CAQ procedures are in place and overall site training has been completed. There is a commitment to timeliness in the CAQ report initiation and processing.
The Tracking and Reporting of Open Items (TROI) computer system has been selected as the single corporate system for tracking CAQs. The CAQ timeliness will be tracked by TROI and overdue items tagged for management attention.
Auditing data concerning the new program's adequacy was not available at the time of the ECTG verification activities because of the program's recent implementation.
Based on the CAQ program initiation including commitments, documentation, training, tracking, and reporting / auditing provisions, the NSRS item is closed.
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Page 12 of 13 1
Attachments l
ECTG CATD R-82-22-BLN-01 l
ECTG CATD R-84-22-BLN-02 i
)
ECTG CATD I-85-06-WBN-02 ECTG CATD I-85-06-WFJ-03 1
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l Page 13 of 13 L _-_. _ _
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ECTG'C.3 Attachment A Page 1.of 1 Revision 4 ECTG Corrective Action Tractinr. Document (CATD)
BLN-NSRS-1 Applicable ECTG Report No.:
_ INITIATION
-Immediate Corrective Action Required: O Yes G[ No l
1.
2.
Stop Wort Recommended: O Yes C/ No
'3.
CATD No. R-81-22-BLN-01 4
INITIATION DATE 7/24/87 5.
RESPONSIBLEORGAN12ATIpN:__B;W Site Director 6,
PROBLEM DESCK1PTION: G QR O NQR R-81-22-BLN-01 & 02
~
revision 1 An independent verification that report CEB 77-10, l
adecuately resolves NSRS concerns R-81-22-BLN-01 and 02 is NSRS was disbanded prior to acceptance of the DNE l
required.
j closure reauest (B41 851022 002) attached E ATTACHMENTS,_
DATE:
7/24/87 7.
PREPARED BY:
NAME W f Xc-s 6/rz/r7
8.
C0CJURRENCE:
CEG-H 6L4/ W
. DATE:
9.
APPROVAL:
ECTG PROGRAM MGR.
p', //fE22.
A DATE:
d/747 p
1/
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
~
O ATTACHMENTS DATE:
PROPOSED BY: DIRECTOR /MGR:
11.
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM KANAGER I
I I
VERIFICATION AND CLOSE0UT Approved corrective actions have been verified as satisfactorily
]
13.
implemented.
TITLE DATE SIGNATURE 5812T 4
-- - ~ - _. - - _ _ _ _. _ _
y u.. is...
u 1
UNITED STATES GOVERNMENT Memorandton rtxxtsset vittty Aurnoniry e
B41 T51022 002 K. W. Whitt, Direc tor o f Nuclear Sa fe ty Review Sta f f, E3 A8 C-K TO R. W. Cantrell, Manager of Engineering, W12 A12 C-K FROM OCT 2 21985 DATE SUB.hECT:
BELLEFONTE NUCLEAR PLANT - NSRS REPORTS R-81-22-BLN AND R-84-25-BLN -
POSWLATED PIPE RUPTURE OUTSIDE CONTAINMENT i
Re ferenc e s:
1.
NSRS Report R-81-22-BLN dated November 4,1981 (CNS 811105 051) 2.
NSRS Report R-84-25-BLN dated Oc tober 17, 1984 (GNS 841017 052) 3.
Your memorandum to me dated April 25, 1985 (QO1850425 052) j 4.
N. A. Poe's memorandum to Bellefonte Engineering *roject Files dated April 18,1985 (B21850419 004)
The documentation update to resolve the recom:nendations of the subjec t NSRS
- reports has been completed as of Oc tober 1,.1985.
The report CEB-77-10 has
-t) been updated and ' issued as revision 1.'
a Since the original NSRS concerns have been addressed, it is reque sted that these NSRS items be closed.
Ori"r.nl Ti-ed Dy '
i nr,..
e _ v.
R. W. Cantrell ROB: NAP:DCG cc: RIMS, SL 26 C-K R. O. Barne tt, W9 D224 C-K (2)
E. G. B ea s ley, W12 C61 C-K Prajec t Manager's Of fice, 9-167 SB-K J. C. Standifer, 9-113 SB-K This was prepared principally by N. A. Poe, extension 3143.
bA C m C -(
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O h
.f..
s
'O L - ----__
ECTG C.3 Attachment A Par,e 1 of 1 Revision 4 l
ECTG Corrective Action Tractinr. Document (CATD)
BLN-NSRS-1
.INITI ATION_
Applicable ECTG Report No.:
'Immediate Corrective Action Required: O Yes.
No 1.
2 Stop Wort Recommended: O Yes G No 4.
INITIATION DATE_.7/24/87 3.
CATD No. R-84-22-BLN-02 5.
RESPONSIBLE ORGANIZATION:
BLN Site Director 6.
PROBLEM DESCRIPTION: ETQR O NQR R-84-22-BLN-02 NSRS (001 850828 050) evaluated DNE response (B45 850528 251) to report NSKS R 84-22-BLN and determined their concerns to be unresolved.
OfATTACHMENTS 7.
PREPARED BY: NAME W I M a u -..
DATE:
7/24/87 i
8.
CONCURRENCE:
CEG-H 6f/2L/&
DATE: _fr/iG r 7
)
9.
APPROVAL:
ECTG PROGRAM MGR.
/f /Fl/d
/s) DATE: _T// J# /
J 1
V f.
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
l 1
f l
l 1
O ATTACHMENTS
~
DATE:
11.
PR0 POSED BI:
DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER VERIFICATION AND CLOSEOUT Approved corrective actions have been verified as satisfactorily 13.
implemented.
I SIGNATURE TITLE DATE i
f i
5812T
~
]
FACI SHEET Adequate Design Mart n for Decay Heat Removal Isolation Valve i
b R-84-22-BLN-02' 3
Opening.
l f
l The NSRS performed a review of the Decay Heat Removal System (DHRS) at l
J This review was restricted to a
.in 1984 Bellefonte Nuclear Plant (BLN)
One of the areas reviewed was for adequate
' functional review of the system.
Design Margin for DHR Isolation Valve opening.
i FSAR Figure 5.2.2-3 indicates that the DHR section. isolation valves must be open when the reactor coolant temperature falls below 305'F to ensure adequate Bellefonte General low temperature reactor vessel overpressure protection.
Operating Instruction BLGOI-IC also requires the operator to open the isolation valves at.305*F. list the maximum liquid temperature of the pump number 08.1130000007-07 Thus it appears that there is no margin in the design for suction as 305'F.
' instrument error and operator action.
NSRS recommended that additional temperature margin be incorporated into the DHRS design and be documented in the DHRS design basis.
Bellefonte response'to the subject NSRS report concerning the design of the Decay Heat Removal System (Memorandum from W. R. Brown Jr.,to K. W. Whitt dated May 28, 1985, RIMS B45 850528 251) states the following:
08-1130000004-07)
The DHR pump equipment specification (B&W document numberThe 305'F. maximum also lists a design temperature to 350*F for the pump. ~
temperature is the normally expected worse. condition at the DH for instrument error and operator action at the DHR pump suction when the suction.
DHR isolation valves are opened.
NSRS evaluated the DNR response and determined their concerns to be unresolved (QO1 850828 050).
5149T page 1 of 1 l
1 1
ECTG C.3 r
Attachment A Page 1 of 1 Revision 4 ECTG Corrective Action Tracting Document
( CATD_)_
Applicable'ECTG Report No.:
NS ES-BLN-1
_I_NITI ATION Inmediate Corrective Action Required: Er Yes O No 1.
2.
Stop Wort Recommended: 0 Yes B' No 4.
INITIATION DATE 07-23-87 3.
.CATD No. _I.-85-06 VBN-03 Site Director, Bellefonte Nuclear Plant 5.
RESPONSIBLE ORGANIZATION:
NSES Report I-85-06-VBN-03 PROBLEK DESCRIPTION: Ef QR O NQR 6.
identified problems with voltage drop and short circuit current ECTG determined that measurements of actual _,-
determination.
installed lengths had been completed at BLN with two exceptions.
This CATD is issued to tract completion.
BLN contact for additional details - Lynn Colvin I
R ATTACHMENTS
. R. Gass. _ W f / M DATE:
07-23-E7 7.
PREPARED BY: NAME 8.
CONCURRENCE:
CEG.
(/Mc1hev DATE:
P//L/E7 9.
APPROVAL:
ECTG PROGRAM MGR.
f 42M8-
/e DATE:
5/WA 7' l
u 1
CORRECTIVE ACTION-10.
PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHMENTS DATE:
l 11.
PROPOSED BY:
DIRECTOR /MGE:
DATE:
j 12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM KANAGER VERIFICATION AND CLOSEOUT Approved corrective actions have been verified as satisfactorily
)
13.
implemented.
m TITLE DATE SIGNATURE 5971T
of the Prorran for Cable Pulling
. Opzo) I-85-06-VEN-02. Tbs Adecuacy
(
Activities In the July 1985 report, NSRS concluded that OE and OC's cable pulling accepted industry standards programs were inadequate and in violation of theThe report stated that Construc defined the method for calculating maximum allowable tension for multicable and practices.
pulls nor bad it finally established the method of pulling multicablesAlso, t utilizing a breat lint.
Failure to ensure that as a limiting factor for cable pulling activities.
in maximum allowable tension, as well as sidewall pressure, was not exceeded any cable pulling operation increased the potential for cable damage NSRS reconenended that the construction
}
(insulation degradation).
specifications G-38 and G-40 be revised to incorporate resolutions to the Final adequacy of the present cable installation should identified problems.
then be evaluated 'per the revised acceptance criteria.
The ECTG ECTG considered this issue potentially applicable at all sites.
Construction Evaluation Group identified cable problems in report CO-10900" CATD 10900-NPS-01 addresses the corporate problem of cable
" Cable".
installation deficiencies.
Cable installation deficiencise at BLN are addressed in Problem Identificaf, ion This PIE concerns effects of cable tension and -
l I
sidewall pressure.
CATD I-85-06-VEN-02 has been issued pendint completion and closure of pIRBLNEEBB518. The NSRS issue remains open.
and Short Circuit Current (Open) I-85-06 VBN-03, Voltare Drop l
Determination In NSRS report number I-85-06 VBN-3, the NSRS r'Ecor nended that OE perf orm short circuit and voltage drop calculations for the Voltage Level 3 power circuits to ensure the adequacy of the size of the installed cable to perform ECTG's generic review of the open issue f ound it j
its intended functions.
potentially applicable to BLN.
NSRS noted that voltage drop calculations, when done_, were based on the design the installed length, Since cable length projected estimated length and notis the controlling factor in determining ac j
l reconrnended the calculations be perf ormed based on actual installed length to l
ensure operability of equipment under worst conditions.
ECTG determined that measurements of actual Based on a documentation review, CATD installed lengths had been completed at BLN with two exceptions.
This ites restins open.
I-85-06-VBN-03 was issued to tract completion.
t I
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Page 11 of 13 I
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ECTG_C.3 o
l-Attachment A Page 1 of 1 l'
Revision 4 ECTG Corrective i
Action Tractint Document l
(CATD)
Applicable ECTG Report No.:
NSES-BLN-1 INITIATION Immediate Corrective Action Required: ET Yes O No 1.
~
2, Stop Wort Recommended: O Yes ET'No 3.
CATD No._
I-85-06-WBN-02 4.
INITIATION DATE '07-23-87 5.
RESPONSIBLE ORGANIZATION:
Site Director. Bellefonte Nuclear Plant 6.
PROBLEM DESCRIPTION: EfQR O NQR Cable installation deficiencies (PIR) at BLN are addressed in problem identification report This PIR concerns effects of cable tension and BLN EEB 8518.
This CATD has been issued pendint completion sidewall pressure.
and closure of PIR BLN EEB 8518.
BLN contact for additional details - Lynn Colvin 2 ATTACHMENTS 7.
PREPARED BY:
NAME K. R. Gass _. T /' h DATE:
07-23-87 8.
CONCURRENCE: CEG-H UML.J./w,
DATE:
9/#1-/f7 9.
APPROVAL:
ECTG PROGRAM MGR.
- #/M %
/m DATE:
inf/87 i !
y CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHMENTS DATE:
11.
PROPOSED BY:
DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
ECTG PROGRAM MANAGER _ _
DATE:
VERIFICATION AND CLOSEOUT Approved corrective actions have been verified as satisfactorily 13.
implemented.
TITLE DATE SIGNATURE
~
5971T I
of the Prorram f or Cable Pulling,
'(0pon ) I-85-06-t!BN-02, The Adecuacy Activities f
i In the July 1985 report, NSES concluded that OE and OC's cable pulling programs were inadequate and in violation of the sceepted in
~
defined the method for calculating maximum allowable tension for multicable and practices.
pulls nor had it. finally established the method of pulling multicablesA utilizing a breat lint.
Failure to ensure that as a limiting factor for cable pulling activities.
d d in maximum allowable tension, as well as sidewall pressure, was not excee e any cable pulling operation 1.nu eased the potential for cable damate
~
NSF', reconsnended that the construction (insulation degradation).
specifications G-38 and G-40 i>e revised to incorporate resolutio identified problems.
then be evaluated per the revised acceptance criteria.
~
The ECTG ECTG considered this issue potentially applicable at all sites.
Construction' Evaluation' Group identified cable problems in report C0-10900 CATD 10900-NPS-01 addresses the corporate problem of cable q
" Cable".
installation deficiencies.
i Cable installation deficiencies at BLN are addressed in problem Identificat on This PIR concerns (:ffects of cable tension and Report (PIR) BLN EEB 8518.
m sidewall pressure.
CATD I-85-06-VBN-02 has been issued pending completion and closure of pIRBLNEEB8518. The NSRS issue remains open.
and Short Circuit Current (open) I-85-06-VBN-03, Voltare Drop Determination In NSRS report number I-85-06-VBN-3, the NSRS recommenced that OE perform short circuit and voltage drop calculations for the Voltag ECTG's generic review of the open issue found it its intended functions.
potentially applicable to BLN.
NSRS noted that voltage drop calculations, when dona, were based cc the d Since cable length projected estimated length and not the installed length.
is the controlling factor in determining acceptable voltage drop, NSRS reconsnended the calculations be perf ormed based on actual installed length to ensure operability of equipment under worst conditions.
I Based on a documentation review, ECTG determined that measurements of ac CATD installed lengths had been completed at BLN with two exceptions.
l This item remains open.
I-85-06-VBN-03 was issued to tract completion.
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page 11 of 13 I
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