ML20237K820
| ML20237K820 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Bellefonte, 05000000 |
| Issue date: | 08/26/1987 |
| From: | Gass K TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18032A532 | List: |
| References | |
| BLN-NSRS-2, NUDOCS 8709080038 | |
| Download: ML20237K820 (51) | |
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,a-TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2
- b. ;
SPECIAL PROGRAM REPORT TYPE: 'Bellefonte Nuclear Plant Element REVISION NUMBER:
I TITLE:
Review of Nuclear Safety Review Staff PAGE 1 0F 40 a
Non-Startup Items at Bellefonte l
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A I-REASON FOR REVISION: N/A l
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SUMMARY
STATEMENT: The 68 non-startup items in this report were identified by the l
Nuclear Safety Review Staff (NSRS).and were assigned to the Employee Concerns Task 3
j, Group (ECTG) for verification and closure, The verification activities are described in this report.
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SRP:
4 SIGNATURE DATE SIGNATURE" DATE APPROVED BY:
N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRO Secretary's signature denotes SRP concurrences are in files.
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BROWNS FERRY NUCLEAR PLANT f
EMPLOYEE. CONCERNS TASK GROUP OTHER SITES CEG s
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' Subcategory :
Bellefonte Nuclear. Plant - NSRS' Classical Items
' l Element:
Review of Nuclear Safety Review Staff Non-Startup Items At.Dellefonte-Report Number:.BLN-NSRS-2 f!l7/l/
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Prepared By N 9
Date Reviewed By-M I. b p / 9-P7 Date
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM I
REVISION NUMBER:
PAGE 2 0F'40 Review of Nuclear Safety Review Staff (NSRS) Non-Startup Items Requiring f~
. Resolution at Bellefonte Nuclear Plant (BLN).
I.
Introduction NSRS conducted reviews of activities at Bellefonte Nuclear Plant (BLN) during its span of overview responsibility from 1979 to 1986. NSRS items remaining open in 1987.have been examined by the Employee Concerns Task Group (ECTG).
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ECTG examined the status of open NSRS issues, including those identified specifically-for BLN as_well as other sites' issues which could have j
generic applicability at BLN.
In all, a total of 86 issues were considered applicable to BLN including 18 requiring resolution prior to l.
Unit 1 startup. The status of these startup issues was the subject of'a previous report, BLN-NSRS-1. The status of 68 other. issues' ordinarily considered as non-startup is the subject of this report, BLN-NSRS-2.
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Sixty-one (61) of these 68 issues are closed.
Some associated activities or areas related to the closed items may in fact still be incomplete, g
However, these NSRS items are considered closed because ECTG, through the evaluation process, determined that sufficient resources have been committed to the issues to ensure their satisfactory completion and i
closure. This confidence is derived from interviews with cognizant TVA personnel and reviews of applicable documentation.
The status of the 68 NSRS non-startup issues for BLN is as follows:
I-l Open-79-09-01-1 Excessive Wire Lifting Practices to
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Facilitate Testing B
Closed 79-09-01-2 Excessive Wire Lifting Practices to j-Facilitate Testing i
Closed 79-09-01-3 Excessive Wire. Lifting Practices to
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Facilitate Testing t'
Closed 79-10-03-1 Reliability Closed R-80-10-BFN-01 Unreviewed Safety Question Determination 9
Closed R-80-10-BFN-IV A Expansion of DPM N73011 1
1 i
Closed R-81-02-BFN-01 Develop a TVA Policy Regarding Loss of Safety Function L
Closed R-81-04-YCN/NPS-1 Level of Safety Review of Yellow Creek l
Nuclear Plant (YCN)
J Closed R-81-04-YCN/NPS-2 Inadequacies of EP 4.02
..._m.____.__._
TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 3 0F 40 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 l
Closed R-81-08-BFN-41 QA&A Staff l
Closed R-81-14-0EDC(BLN)-32 Inadequate Storage of Audit Support Records Closed R-81-14-0EDC(BLN)-41 QAB Auditor Training i
Open R-81-22-BLN-03 Minor Improvements to Pipe Break Evaluations Closed R-82-08-NPS-01 Requirements /Needs/ Activities Matrir f
Closed R-32-08-NPS-02 Quality Assurance Program For Chemistry I
Activities
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Closed R-82-08-NPS-03 Chemistry Program Organization and Responsibility Review Closed R-82-08-NPS-07 Verification of Onsite Radiological Laboratory Analyst (RLA) Training Closed R-82-08-NPS-09 Integrated Calibration and Chemical Program Development Closed R-82-08-NP5-10C Issuing of Directives Contrary to TVA Commitments (Chemistry Program) l Closed R-83-08-BLN-02 Development of Cleaning / Flushing Program Control Procedures I'
Closed R-83-08-BLN-03 EN DES Review Site-Generated Construction Test Procedures Open R-83-08-BLN-05 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 Open I-83-13-NPS-02 Quality Engineering Branch Records
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NS RS-2 SPECIAL PROGRAM f
(.
REVISION NUMBER:
i PAGE 4 0F 40 f'.
s Closed R-83-18-NPS-01 Management of the Reorganization of TVA
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Radiation Protection and Radiological j;
Emergency Planning Program i.
Open R-83-18-NPS-02 Office of Nuclear Power and Licensing
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Documents Closed R-83-27-NPS-01 Weaknesses in Communication of' Requirements i
and Information f_
Closed R-84-05-WBN-14 Inspector Certification Records Closed,R-84-05-WBN-15 Material Inspection closed R-84-17-NPS-01A The Procurement System is too Cumbersome
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and Not Well Known by the Users
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Closed R-84-17-NPS-01B The Procurement System is too Cumbersome and Not Well Known by the Users Closed R-84-17-NPS-01D The Procurement System is too Cumbersome and Not Well Known by the Users.
Closed R-84-17-NPS-04 Insufficient Documentation for Transferred Material Closed R-84-17-NPS-06 BFN Power Stores Clerks Not Trained to Inspect Material Closed -R-84-17-NPS-07 Material With Limited Shelf Life Not Reordered in a Timely. Manner Closed R-84-17-NPS-09 10 CFR Part 21 Requirements Incorrectly Linked to Nuclear Power QA Requirements Open R-84-22-BLN-01 Adequacy of Low Temperature Reactor Vessel Overpressurization Protection l
Closed R-84-25-BLN-03 Design Modification to Prevent Steam Line I
Breat From Damaging Closed R-84-25-BLN-04 Inconsistencies in BLN Main Steam System Design and FSAR
TVA EMPLOYEE CONCERNS REPORT NUMBER: 'BLN-NSRS-2' SPECIAL PROGRAM
'1 REVISION NUMBER:
PAGE 5 0F 40 1
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. Closed R-84-25-B LN-05 Design Modification of Main Steam System or Main Valve Vaults Closed 'R-84-25-BLN-06 Documentation of Maximum Allowable Steam Flow Rate After Steam Line Break Closed I-84-31-BFN-03 Interpretation of Regulatory Requirements Closed I-84-31-BFN-04 Commitment to Procedural Controls.
Closed R-84-32-NPS-01 Inadequate TVA Quality Program i
Open I-84-33-BFN-07 Piping Analysis 1
Closed I-84-33-BFN-08 Failure of QA to Perform Audits and Surveillance of Identified Problem Areas within Piping Analysis Sections Closed I-84-34-SQN-02 Completion of IVA Mark Letter Description on the Transfer Requisition Documents closed I-85-06-WBN-04 Timely and Responsive Corrective Actions for Resolution of Identified Problems Closed I-85-06-WBN-05 Underdevelopment of Established and Documented Limited QA Program and Failure to Incorporate the Established Limited QA Program into NQAM.
l Closed R-85-07-NPS-01 Manager of Power and Engineering Appointment of a Records Manager Fourteen Safeguards Items Closed R-82-01-PSS-01 Authorities and Responsibilities'Not Clearly Defined in Writing Closed-R-82-01-PSS-02 Procedure for Functioning of Branch Staff l
Not Defined in Writing Closed R-82-01-PSS-03 Expectations of PSS Management Not Defined in Writing l'
l Closed R-82-01-PSS-04.B.1 Lack of Guidance and Support to Field Staffs t-i
j TVA EMPLOYEE CONCERNS RRPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:-
1
-PAGE 6 0F 40-Closed R-82-01-PSS-04.B.2 Lack of Guidance and Support to Field Staffs 1
Closed R-82-01-PSS-04.C.1 Lack of Guidance and Support to Field Staffs Closed R-82-01-PSS-05 Internal and External Interfaces Not Well' f
Defined Clored R-82-01-PSS-Oll' Lack of Document' Control Closed R-82-01-PSS-12 T&Q Implementing Instruction l
Closed -R-82-01-PSS Material Revisions - Material Review and i
Approval Closed R-82-01-PSS-15 Site Security Organization - Administration 5 -
Responsibilities and Authority Not Clearly I,
Defined Closed R-82-01-PSS-24 Bellefonte Security Facilities Tracking System Closed R-83-16-NPS-01 Revision of the Safeguards Information l-
' Closed R-84-06-NPS-01 Revision of the Safeguards Information II.
Verification of NSRS Non-Restart Items f
(0 pen) 79-09-01-1, Excessive Wire Lifting Practices to Facilitate Testing The above referenced NSRS. concern was initiated in 1979 at WBN and was also determinod to be generic to BLN.
It stated that testing of protective relays, meters, indicating instruments, and transducers on the 480 volt shutdown boards, 6900 volt shutdown boards, and diesel generator boards could not be performed without lifting leads, installing test j
leads, removing test leads, and reterminating board wiring.
The NSRS corrective action recommendation stated that DNP should submit a DCR to define where test blocks were needed and also provide a point of contact to assist EN DES in the design.
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ECTG's investigation revealed that BLN has not installed PK test blocks as a means to facilitate testing of protective relays, transducers,
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indicating instruments, and meters.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 7 0F 40 P.
During the investigation, the DPSD sup..J. ar stated emphatically that d
test blocks should be installed in the eq' pment referenced by this issue.
He also presented a fourteen (14) page handwritten report to ECTG
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that documented his views.
ECTG recommends that DNE review the DPS0 supervisor's report and discuss it with him to gain a complete understanding of his views.
ECTG further recommends, based on DNE's review of the issue, that either PK test blocks be installed or justification given to substantiate an engineering decis'an not to install them.
5 CATD 79-09-01-1 (BLN) has been initiated and issued to ensure this NSRS k
issue is properly addressed. This issue will remain open until CATD 79-09-01-1 (BLN) is closed.
5 (Closed) 79-09-01-2, Excessive Wire Lifting Practices to Facilitate Testing The above referenced NSRS concern was initiated at WBN in 1979 and was also determined to be generic to BLN.
It stated that EN DES was requested to install test blocks on the diesel generator logic and control board and the 6900V and 480V shutdown boards for relays, meters, indicating instruments, and transducers to facilitate testing.
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The NSRS Corrective Action Recommendation stated that DNP should submit a L
DCR to define where test blocks were needed and also provide a point of contact to assist EN DES in the design.
ECTG's investigation of this issue indicates it is duplicated by issue 79-09-01-1.
The corrective action regarding this issue is the same as that for 79-09-01-1 and will be satisfied by the completion and closure of CATD 79-09-01-1 (BLN).
This NSRS issue is closed.
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(CT.osed) 79-09-01-3, Excessive Wire Lifting Practices to Facilitate Testing The above referenced NSRS concern was initiated at WBN and was also determined to be generic to BLN.
It stated that in 1979, during times of testing, as many as fifty (50) wires, all of the same color, are lifted j
i and reterminated which creates a potential for damaging equipment or I
injuring personnel.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 8 OF 40 The NSRS Corrective Action Recommendation stated that DNP should submit a l
DCR to define where test blocks were needed and also provide a point of contact to assist EN DES in the design.
ECTG's investigation of this issue indicates it is duplicated by issue 79-09-01-1.
The corrective action regarding this issue is the same as the for 79-09-01-1 and will be satisfied by the completion and closure of CATD 79-09-01-1 (BLN).
This NSRS issue is closed.
(Closed) 79-10-03-01, Concern for Reliability There are no programmatic aspects of current reliability activities existing. One-time tests do little to establish the ability of items to f
perform satisfactorily over their expected service lives.
Reliability requirements are not being specified in requisitions. There is a lack of f
reliability engineering expertise in TVA.
l The ECTG investigation indicated that for the past several years, TVA has had an active reliability program: Division of Engineering Design t
(EN DES) and the former TVA Power Production (P PROD) have had both a steering committee and a working level task force. Both of these groups have been actively working for the last two years. 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 KAMAN and Mechenic Research.
In addition, there have been detailed exchanges with other utilities organizations There have been joint programs with several of i
these organizations on collecting data and investigating various systems. Also, TVA has been an associate member of the United Kingdom 6
Atomic Energy Authority (UKAEA) Systems Reliability Service for over two years and has access to the Statistical Reporting Service (SRS) data bank and counsel with SRS reliability engineers.
In addition, industry trending is being accomplished through the
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Institute of Nuclear Power Operations (INPO) by the Nuclear Plant l
i Reliability Data System (NPRDS).
Nuclear Power Procedure Number 1601.02, " Nuclear Plant Reliability Data System (NPRDS), Maintenance History and Class lE Tracking acd Trending -
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Reporting Failures of Components and Systems (Formerly DPM Number N73015B)" Revision 0, October 24, 1986, provides detailed instructions for reporting equipment reliability and performance data at all TVA site including BLN.
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~ 'fVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2
.SPECIAL PROGRAM FEVISION NUMBER:-
-PAGE 9 0F 40 e
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.# ' Based,0E review of applicable procedures and interviews with plant
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~l personnel, ECTG concludes that this NSRS has been satisfactorily; 4
addressed at BLN.
I This item is closed.
s (Closed)pR-80-10-BFN-01, Unreviewed Safety Ouestion Determination
,1 On July 9, 1980, at the. request of BFN, and because of extended hot weather, ONP authorized wire lifts to defeat the' automatic tripping g
3 function of the cooling tower lift pumps when cold water discharge t
temperature reaches 95'F.
This waiver was. extended to July 21 and again
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to July 28.
In addition, the 95'F. temperature trip requirement'in the cold water discharge channel was raised to 97'F.
The NSRS evaluation.
h revea' led that an unresolved safety question determination (USQD) had not
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J been conducted for this temporary safety-related alternation of an FSAR
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- requirement as required by 10CFR50.59 paragraph VI.A.
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. The NSRS recommended that DMP N73011 should be expanded to include a j
provision to ensure USQDs for propcsed alternations that make changes to i
s syste'ns or procedures described in the FSAR. NSRS further recommended that a copy of the USQD should then be forwarded to EN DES and NSRB.
The ECTG investigation of this issue at BLN identified two (2) site procedures in place that address USQDs'at the site level.
' Standard Practice BLO1.1, paragraph 1.1.2 contains requirements to
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perform an unreviewed safety question determination (USQD) for temporary
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alterations.
Standard Practice BLG 6, paragraph 3.4, contains Plant 0perational Review Committee (PORC) responsibility to ensure that no instruction is approved with an unreviewed safety question.
Based on interviews with a shift engineer, a document control. supervisor, and a review of the site pro edures, ECTG concludes that this NSRS issue has been satisfactorily addi,ssed.
This NSRS issue is closed.
(Closed) R-80-10-BFN-IV A, Expansion of P[M N73001 A review at Browne Ferry Nuclear Plant (BFN) in 1980 by NSRS noted that DNE divisional procedure DPM N73011. section 7.3, revision dated February 14, 1980 did not contain provisiores to ensure that proposed alterations chant;ing systems or procedures in the SAR are reviewed for safety questions, whether in written chapter material or drawings.
TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM i
REVISION NUMBER:
PAGE 10 0F 40 l
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The NSRS recommendation and the BLN corrective action for this issue are
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identified above under item R-80-10-BFN-01.
This NSRS issue is closed.
(Closed) R-81-02-BFN-01, Develop a TVA policy Regarding Loss of Safety
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Functions j
The above referenced NSRS report was initiated at BFN in 1981.
The concern stated that improper installation of piping supports in the g-Residual Heat Removal (RHR) and Emergency Equipment Cooling Water (EECW) pipe tunnels at BFN resulted in the potential for degradation of safety h
systems capabilities during earthquake loading. The report further stated that conditions allowed by BFN Technical Specification 3.5.C are in error.
Tne NSRS corrective action recommendation for BFN stated that NUC PR i
should revise and modify Technical Specification 3.5.C whereby a minimum of three (3) EECW pumps will be used instead of two (2).
The NSRS issue was considered potentially app 1'. cable to all TVA sites.
An investigation of this issue at BLN has been conducted by ECTG and the following information provided.
BLN is being constructed to ASME Code, Subsection 11, whereas BFN was built to ANSI Code, B31.1.
The decay heat removal system at BLN (referred to as the residual heat removal (RHR) system at BFN) has been designed and installed per the ASME Code.
The essential raw cooling water (ERCW) piping at BLN, (referred to as the emergency equipment cooling water (EECW) at BFN) does not pass through a pipe tunnel, as referenced in this issue, but is buried underground and covered with an eighteen (18) inch thick concrete missile shield.
The error in Technical Specification 3.5.C referenced in this issue is unique to BFN, a three (3) unit plant, and does not apply to BLN, a two (2) unit plant.
Based on interviews with supervisors from the Mechanical Engineering Group (MEG) and the Civil Engineering Group (CEG) and review of the differing codes to which the plants are constructed ECTG concludes that this NSRS issue is not applicable to BLN.
This NSRS issued is closed.
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t TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 11 0F 40 O
(Closed) R-81-04-YCN/NPS-01, Level of Safety Review of Yellow Creek 4
Nuclear Plant (YCN) s l
This NSRS concern was initiated at YCN in 1981. The concern states that no minimum safety review requirements had been established by the Nuclear Engineering Branch (NEB). 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.
The NSRS corrective action recommendation stated that NEB should 6
establish a written program to ensure that adequate safety reviews, including all safety-related features, were performed at YCN.
It further stated that procedures be initiated to provide guidance in performing e
safety reviews.
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ECTG's investigation of this issue indicates that Procedures DNE NEP 2.1 3
and NEP 6.1 concerning controls of the ECN process address the issue of safety reviews at the corporate level.
No responsibility for design engineering or design engineering safety reviews has been transferred from NEB / Knoxville to the BLN site.
Based on interviews with responsible engineers from DNE Electrical and j
Mechanical Groups and a review of Corporate procedures ECTG has concluded that this NSRS issue has been satisfactorily addressed.
This NSRS issue is closed.
(Closed) R-81-04-YCN/NPS-02, Inadequacies of EP4.02 The above referenced NSRS issue stated that EN DES procedure EP4.02 did not contain sufficient guidance for determining which organization needs to approve ECNs.
The corrective action recommended by NSRS was to revise EP4.02 to include guidance for determining which organizations are required to approve ECNs.
Further recommendations stated that the branches should periodically review all approved ECNs to ensure that proper approvals l
were obtained.
Procedure EP4.02, " Handling of Engineering Change Notices (TVA-ECN)" was I
revised and redesigned as OEP-1.
OEP-1 was revised and re-designated as i
NEP-6.1.
NEP-6.1 referenced in engineering element report 204.06 (A)
I address ECN responsibilities at a corporate level, while BNP-QCP-0.10
" Disposition and Documentation of Engineering Change Notices and Field i
Change Packages," addresses ECN responsibilities for Bellefonte.
Based on ECTG's investigation of the issue and a review of applicable
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l procedures, it is concluded that this issue has been properly addressed.
i This NSRS issue is closed.
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'i TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
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PAGE 12 0F 40
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(Closed) R-81-08-BFN-08, Increased Scope of OPOA&.A Staff Audit Program
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NSRS stated that audits required by BF SP 10.1, " Corrective Action q
-Policy" dated February 1980, were not adequately scoped to give management the assa ance that the corrective action system was working effectively. The audits did not include the LER Program, for example.
y which handled the identification, evaluation, correcting, and reporting of items identified in the NQAM as significant conditions adverse to quality.
E' The NSRS corrective action recommendation stated that the Office of.
Nuclear Power should increase the scope of the OPQA&A Staff Audit Program to provide reasonable assurance that corrective action programs are effective, s.
This recommendation was acted upon by ONP with development of Audit Module 23, " Corrective Action" to. provide verification of implementation h
and effectiveness of the CAQ program, i
I ECTG reviewed the audit module.and obtained samples of audit reports concerning corrective action implementation and effectiveness and found g
them satisfactory. Based on reviews of the program and samples taken, ECTG concludes that this issue has been satisfactorily addressed.
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l This NSRS issue is closed.
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(Closed) R-81-08-BFN-20, Quality Assurance and Quality Control of Operational Activities NSRS stated that'the scope of ONP's audit program was inadequate and did not ensure conformance to Technical Specifications.
T The NSRS Corrective Action Recommendation stated that ONP should increase the scope of the audit program to provide the NSRB reasonable assurance that the nuclear facility will be operated within the technical i
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specifications and conditions of the license.
ONP's corrective action response stated that QAB had developed an audit 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.
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. Based on interviews with cognizant personnel, a review of DQA instruction 322 (R2, March 1986) " Standard Audit Module Scoping Document," and a review of scoping documents, ECTG concludes that this issue has been satisfactorily addressed. This item is closed.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSES-2 SPECIAL PROGRAM REVISION NUMBER:
l PAGE 13 0F 40 (closed) R-81-08-BFN-41, QA & A Staff
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t There are inadequate resources (manpower) on the Audit Program Staff to
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perform necessary ' audits or implement the audit program.
k-The NSRS Corrective Action Recommendation stated that ONP should evaluate j
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the QA audit program to determine whether or not additional personnel resources are needed.to effectively implement the program. Action should be taken as appropriate to support the result of the evaluation.
l Through interviews with DQA personnel, it was determined that 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, increased staff resources, and future resource estimates. ECTG concluded that this issue has been j
satisfactorily addressed. This NSRS item is closed.
3 (Closed) R-81-14-0EDC (BLN)-32, Inadequate Storage of Audit Support
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Records k
In September 1981, the NSRS investigation found that the storage of audit support records was not in accordance with the requirements of ANSI f:
N45'.2.12 and ANSI N45.2.9.
Some records were being stored in non-fire rated cabinets.
s The NSRS recommended that provisions be made for protection of the records as required by the referenced standards.
ECTG's investigation of the issue reveals that Part 3. Section 5.1
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Paragraph 4.22 of the NQAM gives direction for retaining records from a corporate level. The Site Director Standard Practice BLAS.13 addresses the issue of record intention at BLN. Audits support records are g
protected through the TVA RIMS system. A sampling of the RIMS file verified that applicable procedures were being effectively implemented.
Based on the satisfactory results achieved from the sampling effort and interviews with personnel from the Document Control Section, ECTG l
concludes the NSRS issue has been addressed.
k This NSRS issue is closed.
(Closed) R-81-14-0EDC (BLN)-41, QAB Auditor Training
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The above referenced NSRS concern was initiated in 1981 at BLN Design Project.
It stated that EN DES failed to establish a written approved program for training auditors.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 14 0F 40 The Engineering Assurance (EA) organization within DNE does not have a formal procedure that gives direction for training personnel as auditors.
However, new suditors within EA are being given auditor 2
training at POTC.
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POTC is currently conducting auditor training and at the same time developing a training standards manual. The manual is scheduled to be issued on November 29, 1987, and will include, in part, the following training courses presently used in POTC training.
a.
QAT 008 - Introduction to Auditing i
QAT 002 - Observation Training for QA Audit Personnel j
b.
c.
QAT 007 - Codes and Standards d.
QAT 010 - Advanced Auditing Techniques g
The NSRS Corrective Action Recommendation suggested that QAB develop an administrative procedure delins? ting QA training requirements and 4
i provisions for management approval of QA auditor training programs.
I ECIG 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 is being tracked at Watts Bar with CATD R-81-14-0EDC(BLN)-41.
Resolution of this issue by WBN will resolve this issue for BLN. This 3
item is therefore considered closed for BLN.
(0 pen) R-81-22-BLN-03, Minor Improvements to Pipe Break Evaluations i
The NSRS conducted a review of the pipe break evaluation at Bellefonte Nuclear Plant (BLN) in 1981. The NSRS identified the following items
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which they considered deficiencies in the pipe break evaluation.
(1)
CEB report 77-10 mentioned several areas which at the time the report was issued were unresolved.
The design had advanced to the point where these areas had been resolved.
The resolutions should be documented in the CEB report.
(2) CEB report 77-10 did not clearly define when spurious operation of equipment is assumed.
1 The NSRS recommended clarifications, as follows, to improve the pipe break evaluation:
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I TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 i
SPECIAL PROGRAM REVISION NUMBER:
t PAGE 15 0F 40 j
(1)
CEB report 77-10 should be updated to reflect the resolution of several items which were open when the report was issued.
(2) CEB report 77-10 should clarify in more detail when spurious failures were assumed. A listing of the conditions under which spurious operation is assumed should be included in the report.
i i 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-81-22-BLN-03 is required. CATD R-81-22-BLN-01, issued with report BLN-NSRS-1, also covers this issue R-81-22-BLN-03.
This item remains open.
(Closed) R-82-08-NPS-01, Requirements /Needs/ Activity Matrix i
This NSRS issue states that the N-0QAM is not self sufficient and relles on division directives for supplemental detailed requirements.
Personnel are not comprehensively aware of what commitments and requirements had been made on behalf of water quality control or how they had been incorporated into directives and procedures except for the requirements of the specific plant technical specification.
The recommendation supplied by the NSRS stated that a requirements /needs/ activities matrix should be developed to identify and tabulate all requirements. TVA commitments, and program needs. The requirement should be indexed to the source control documents for trecLing and verification of implementation.
In response to this and subsequent R-82-08-NPS issues, CATD 30711-NPS-2 was initiated to provide corrective action for deficient conditions.
This CATD requested that all items in the R-82-08-NPS series reports (1 thru 10) be reviewed and e method of resolution for deficiencies be
)
provided.
l A Corrective Action Plan (CAP) was developed to implement a new program 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 j
develop an exceptional program that exceeds in quality all I
requirements commitments, and industry standards. As a result of the problems identified in this audit and other audits by NRC, INPO, j
Quality Assurance, etc., a Chemistry Program Manager's position was established at the corporate level with the responsibility and suthority to develop, impicment, and maintain a state-of-the-art chemistry program at TVA.
1 1
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TVA EMP14YEE CONCERNS REPORT NUMBER:
BLN-NSRS-2 SPECIAL PROGRAN REVISION NUMBER:
PAGE 16 OF 40 This program is presently under development and schedules have been submitted for its implementation. When implemented, this program will address the evncerns, both stated and implied, in the subject audit report.
ECTG obtained a copy of the proposed program schedule and further investigations determined 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 WBN, BFN, and BLN.
i This issue, as well as the otter R-82-08 issues following, is being tracked at Browns Ferry by CATD 30711-NPS-2.
The closure of this CATD will satisfy the corrective action requirements of this issue at BLN.
This NSRS issue is closed at BLN.
(Closed) R-82-08-NPS-02, Quality Assurance Program for Chemistry Activities The NSRS investigation in 1962 concluded that the ONP Quality Assurance Program, which provides QA program requirements for all of its facilities performing quality-related Octivities, was devoid of controls required for safety-related Chemistry activities.
Chemical and radiochemical program controls were not established to the degree warranted.
The corrective action recommendation made by the NSRS stated that the ONP Quality Assurance Program should include all safety related chemistry activities.
Tracking of corrective action for this item is by ECTG CATD 30711, as
]
described above under item R-82-08-NPS-1.
NSRS item R-82-08-NPS-02 is
{
closed.
(Closed) R-82-08-NPS-03, Chemistry Program Organization and
- ]
Responsibility Review l
The NSRS issue referenced above indicated that ONP's functional decentralized organization had bred autonomy among its organizational units.
Each of the six (6) project control staffs for chemical and radiochemical control within ONP had duplicated the efforts of the other causing confusion aa to the responsibility relationships with the plants and POTC.
l
TVA EMPLOYEE CONCERNS-REPORT NUMBER: BLN-NSRS-2' I
-l
}t SPECIAL PROGRAM ~
REVISION NUMBER:
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PAGE 17 0F 40 i
The corrective action recommendation offered by the NSRS stated that ONP F
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.
j l
i Tracking of corrective action for this item is by ECTG CATD 30711, as q
L described above under item R-82-08-NPS-1.
NSRS item R-82-08-NPS-03 is j
J closed.
J
-(Closed) R-82-08-NPS-07, Verification of Onsite Radiochemical Laboratory i
Analyst (RLA) Training l
This NSRS issue states that no onsite involvement or program effectiveness appraisals were being accomplished in the area of RLA training by the Nuclear Central Office Training Branch. There was some indication that the training program breaks down at the plant-level.
The NSRS corrective action recommendation suggested that the NCO training branch should review on-site RLA training activities at-periodi_c intervals.
Tracking of corrective action for this item is by ECTG CATD 30711, as described above under item E-82-08-NPS-1.
NSRS item R-82-08-NPS-07 is closed.
(Closed) R-82-08-NPS-09, Integrated Calibration and Chemical Program Development This issue was investigated in 1982 by NSRS and stated that even though the central laboratory had established controls for its M&TE calibration a
program, formal controls for the. safety-related chemical support functions had not been established.
The'NSRS corrective action recommendation suggested that the central i
laboratory should expand the formal controls to cover the chemistry and l
other quality-affecting activities to define the laboratory's QA J
responsibilities to ONP.
Tracking of corrective action for this item is by ECTG CATD 30711, as describcd above under item R-82-08-NPS-1.
NSRS item R-82-08-NPS-09 is closed.
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p TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2 i
SPECIAL PROGRAM REVISION NUMBER:
PAGE 18 0F 40 (Closed) R-82-08-NPS-10C, Issuing of Directives Contrary to TVA Commitments (Chemistry Program) 1 During the original review, NSRS concluded that procedural controls were
'I absent for the central office preparation, qualification, and issuance of 1
i analytical' procedures'. NSRS recommer.ded that nuclear power management direct their' attention to this procedure development.
Tracking of corrective action for this item is by ECTG CATD 30711, as described above under item R-82-08-NPS-1.
NSRS item R-82-08-NPS-10C is
.}
closed.
j (Closed) R-83-08-BLN-02, Development of Cleaning / Flushing Program Control i'
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 l
endorses ANSI N45.2.1 1973. The requirements specified in these' documents were to'be incorporated in OE-generated documents G-39 and NAM-891. Not all of the requirements of the RG and ANSI standard had been' incorporated into G-39 and N4M-891 and'the documents were very general ~in nature. As a result, the site-generated procedure, i
BNP-CTP
.1, and the construction test packages die not meet all the l
requirements of RG 1.37 and ANSI N45.2.1-1973.
Additionally, the procedure did not contain sufficient detail to provide guidance for inexperienced personnel to implement an acceptable flushing program.
NSRS recommended that OE review RG 1.37, ANSI N45.2.1-1973, other l
documents containing TVA commitments, and the details of the NSRS report I
and incorporate the programmatic requirements and applicable recommendations into G-39 and N.M-891 to ensure that responsibilities, j
technical requirements, documentation and records, training, and adequate
{
program test controls were defined. NSRS also recommended that the site review the site-generated procedures, OC test packages, and the flushing i
program to ar.t.re conformance to the OE-generated documents with specific r
emphasis on acceptance criteria and adequate detail in each system test i
package for controlling the accomplishment of the activity and documenting the results.
j The corrective action for this NSRS finding was compleced in early 1984 and a response provide to ECTG by the DNE office in Knoxville on June 4, 1987. The response stated that General Construction n
Specification G-39 was revised (Revision Number 6 effective t
February 2, 1984) to addrers 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.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2 s
SPECIAL PROGRAM REVISION NUMBER:
PAGE 19 0F 40
-Additionally, a DNE engineer confirmed that DNE documents G-39, N4M-891, t
and BNP-CTP.6.1 had been updated to agree with ANSI standards.
Based on interviews with DNE personnel and a review of the DNE documents,
'I ECTG concludes _that this NSRS issue has been satisfactorily addressed at f
BLN.
This'NSRS issue is closed.
(Closed) R-83-08-BLN-03. EN DES Review of Site-Generated Construction c!'
Test Procedures
[
The lnitial site-generated construction test procedure BNP-CTP
.1, l
Revision 0,' contained inadequate details and positive test controls for the development of an adequate flushing program to accomplish flushing of 3
safety-related systems. Individual test packages for flushes did not ll contain sufficient detail, adequate documentation, and test results
$J records for accomplishment and verification of the activity being
~
l performed.
1 J
NSRS recommended that OE review the site-generated construction test procedure and ensure conformance to ANSI standards. OE-generated h',,
documents, past TVA commitments, and past accepted program development and implementation at preceding TVA sites. In addition, NSRS recommended f
that completed test packages for past flushing activities at BLN also be l
review;d to ensure that compliance with applicable requirements could be q
demonstrated.
l ECIG's investigation involved interviews with DNE personnel and a review 1
of applicable procedures and flush packages.
e h
During interviews, DNE personnel stated that BNP-CTP.1 has been revised i
to agree with DNE_ documents G-39 and NAM 891.
In addition, all three (3) referenced documents have been revised to reflect the requirements of ANSI standards, h
A review of flushing documentation indicated that the fluth packages were complete and provided satisfactory verification of activities performed.
I Based on interviews with DNE personnel and a review of procedures and
'j flushing. documentation, ECTG concludes that this NSRS issue has been l
D satisfactorily addressed.
k 9
This NSRS issue is closed at BLN.
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.TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM
}
REVISION NUMBER:
e PAGE 20 0F 40 1
(0 pen) R-83-08-BLN-05, Approval of the 1/8-inch Variance for Acceptable Purge Dam Residual Particle Size i
NSRS' conducted a review at Bellefonte Nuclear Plant (BLN) concerning I
piping system flushing activities. They noted BLN was committed to the
' requirements of ANSI 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 j
' Specification G-39.
g1 NSRS noted that~a variance had been granted by EN DES to relax the L'
allowable size from 1/32 inch to 1/8 inch.
This is contrary to G-39
- Specification and ANSI Standard N45.2.1-1973.
3 f!
NSRS recommended that if the variance was not approved, EN DES must i -'
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 L
documenting the results to ensure that the 1/8 inch acc6ptance criteria is applied only to properly identified and measured purge dam materials.
ECTG's' interviews with DNE engineers from Knoxville indicate that the NRC i.
l-has not yet agreed to's variance as described in the issue. The issue cannot be closed unti: the NRC has made a decision.
CATD R-83-08-BLN-05'has been written and issued to track this open item' until a solution has been reached and the CATD closed.
This NSRS issue remains open at BLN.
1 (Closed) I-83-13-NPS-la, Quality Engineering Branch (CEB) Records i
j 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 plans to do so in the near future. This places TVA in violation of 10CFR50, Appendix B, Criterion VII, and Topical Report requirements.
Although this report examined the flow of records for SQN, there was no f
basis to believe that this conclusion could not also apply to other TVA j
nuclear facilities.
4 The NSRS recommended that an interdivisional task force reporting to the j
Assistant General Manager be formed to correct the problems identified and'to establish an effective records system.
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TVA EMPLOYEE C0hCERNS REPORT NUMBER:
BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 21 0F 40 A follow-up report, R-85-07-NPS, was initiated in May 1985 that addressed i
i; the same issue as I-83-13-NPS-la.
It stated that the NSRS had confirmed in the follow-up roport 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.
I
-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 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, transferring, and retrievability of vendor and construction records connected with procurement requiring QEB source inspection.
i i
l This issue is being tracked by CATD R-85-07-NPS-01 at Watts Bar.
Resolution of this issue by WBN will resolve the issue for BLN. This item is therefore considered closed for BLN.
I g
(Closed) I-83-12-NPS-lb, Quality Engineering Branch (CEB) Records NSRS concluded there was no overall OEDC effort to provide NUC PR a t
complete QA file integrating both CONSTRUCTION and QEB records in a usable form. This is in violation of TVA QAP PRM 17QPR-1.
s I
The NSRS recommended that an interdivisional task force reporting to the Assistant General Manager be formed to correct the problems identified and to establish an effective records system.
l A follow-up report, R-85-07-NPS was initiated in May 1985 that addressed
(
)
the same issue as I-83-13-lb.
It stated that the NSRS had confirmed in 1
the follow-up report that in response to the corrective action recommendation contained in I-83-13-NPS, a task force was established and l
functionally active between December 1983 and April 1984. Additionally, r
the report of May 1985 documented the results of the follow-up corrective action review by NSRS of the findings and recommendations associated with I
NSRS report I-83-13-NPS.
This review covered the activities of the I
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.
This issue is being tracked by CATD R-85-07-NPS-01 at Watts Bar.
Resolution of this issue by WBN will resolve this issue for BLN. This item is therefore considered closed for BLN.
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TVA EMPLOYEE. CONCERNS
-REPORT NUMBER:- BLN-NSRS-2 SPECIAL PROGRAM-REVISION NUMBER:
PAGE 22 0F 40
'(Closed) I-83-13-NPS-ld, Quality engineering Branch (CEB) Records The retrieval of information from vender 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 who were not readily-controlled by NUC PR.
There was no coordinated TVA effort.to ensure the adequacy of identification, collection, collation, indexing, and distribution of vendor QA records.
l
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The NSRS recommended that an interdivisional task force reporting to the l
Assistant Gene-al Manager be formed to correct the problems identified and to establish an effective records system.
l i
A follow-up report, R-85-01-NPS, was initiated in May'1985 that' addressed 1
l.
the same issue as'I-83-13-1d.- 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 f
functionally active between December 1983 and April of 1984.
(_
Additionally, the report of May 1.)85 documented the results of the p,
follow-up corrective action review by NSRS of the. findings and I
recommendations associated with NSRS report I-86-13-NPS..This 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 requirit:g QEB source inspection.
This issue is being tracked by CATD R-85-07-NPS-01 at Watta Bar.
I Resolution of this issue by WBN will resolve this issue for BLN. This l
j item is therefore considered closed for BLN.
e (0 pen) I-83-13-NPS-2, Quality Engineering Branch (OEB) Records 2
This issue, as investigated by NSRS in 1983, stated that no schedule was provided that established when vend.or records themselves would be verified as complete or indexed for retrievability. QEB has not established a schedule to verify or index records at SQN and WBN.
i This issue was investigated at SQN and WBN and as a result of the 4
investigation, NSRS recommended that the responsibility of' vendor records be assigned to a manager who would, be organizationally capable of a
' coordinating'the efforts of OE, 0C, and DNP regarding vendor records.
1 The ECTG investigation at BLN indicated that procedures are in place to index, file, and retrieve vendor records. QMI-446 (which superceded EB-EP-24.58) titled Supplier Document Review and QMI-450 (which operceded QEB-EP-24.37) titled Contract Record Index and Filing address she issue of vendor records.
TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 23 0F 40 However, QEB personnel stated that records for BLN have not been indexed g
or microfilmed at this time.
Records are in hard copy form with field and contractor copies used as back up.
?
Based on interviews with QEB personnel ECTG concludes that this NSRS issue has not been fully addressed.
CATD I-83-13-NPS-has been issued to insure satisfactory resolution of this issue. This isrue will remain open until CATD I-83-13-NPS-2 is closed.
e s
(Closed) R-83-18.-NPS-01, Management of the Reorganization of TVA Radiation Protection and Radiological Emergency s
i Planning Program 1
}
The NSRS evaluation of this issue stated that the responsibilities for
)
conducting TVA'r radiation protection and radiological protection program 3
ucre not well defined and disagreements as to the final disposition 'of some of its functions had not been resolved. TVA Organization Bulletins, i
Codes, and Instructions had not been issued a year after the j'
reorganization and this had led to interface and communications barriers.
1 l
The NSRS recommended that upper management in POWER should take actions to ensure that final decisions are promptly made regarding the assignment j
)
of responsibilities and all necessary TVA corporate documents (codes,
)
bulletins, instructions) are updated to reflect the final decisions.
1 POWER upper-management involvement should be maintained until the program l
has been implemented in accordance with the approved documentation.
l ECTG's evaluation of the issue revealed that the Radiation Protection Plan (RPP) Section A, Revision 3 dated July 15, 1986 details ONP's requirements and management controls for the radiation and radiological protection programs.
It applies to all aspects of radiation protection associated with TVA nuclear power plants and supporting functions and services.
Based on the review of the RPP, ECTG concludes that this NSRS issue has been satisfactorily addressed. This NSRS issue is closed at BLN.
(0 pen) R-83-18-NPS-02, Office of Nuclear Power Program and Licensing Documents This NSRS issue concerned Office of Nuclear Power program and licensing documents for radiation protection and radiological emergency planning 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 (0QAM),
l Technical Specifications, Final Safety Analysis Report, and plant standard practices in the areas of radiation protection and radiological emergency planning.
.h TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
l PAGE 24 0F 40 A
i Following review of the applicable documentation, ECTG determined that 3
this issue is still open. The FSAR and Technical Specifications do not reflect current organizational structures and need to be updated.
k
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The OQAM, as mentioned in the initial-report, no longer exists. It was replaced by the NQAM. _Later, the NQAM section concerning radiation I-protection was. removed and placed in the Radiation Protection Plan.
The Area Program Manual was replaced by the other sites Radiological Emergency Plan 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 structure will be ready for incorporation-into the Technical Specifications.
The completion of the updates to the Technical f
Specifications and FSAR will be tracked with ECTG CATD R-83-18-NPS-02 for BtN.
This item remains open.
(Closed) R-83-27-NPS-01. Weaknesses in Communication of Requirements and Information The NSRS report stated that weaknesses in the communication of
}-
requirements have delayed achieving consistency in various applied programs at each site and between sites. Three (3) examples are given in reference to the concern.
(1) The Quality Assurance Training Manual (QATM) does not provide l
guidance to eva'luate worker training or to evaluate the ability of l
the worker to p erorm independently.
(2) The performance of trend analysis and the inspection / rejection notice systems are insufficient.
(3) Trend Analysis or other means of communication did not disclose
{
generic problems.
The NSRS corrective action recommendation states that construction management should continue efforts to improve the division-level and the site-level quality programs in order to achieve the expressed goal of consistency of implementation and the uniformity of QA philosophy.
It i
further stated that specific program differences and communication i
weaknesses should be evaluated and modifications should be made as determined appropriate.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 25 0F 40 i
ECTG's investigation included an interview with the supervisor in the Procedures and Training Unit. He stated that BLN has implemented corporate procedures for evaluating worker training. The procedures being implemented include:
4 (1) QATM,Section II, " Experience, Training, and Qualifications of Personnel Not Requiring Certification."
(2) QATM,Section III,'" Experience. Training, and Qualifications of Personnel Requiring Certification."
Further interviews with Quality Assurance / Quality Improvement Trending and Analysis Evaluator revealed that NQAM, Section 2.16, part 1,
" Corrective Action" provided trending for CAQRs. He further stated that 4
procedure BNP-QCP-10.41 " Trend Analysis Program" is used at the site l
level for trending.
Based on the interviews with cognizant personnel in the training program organization and the trending program organization ECTG concludes that this NSRS issue has been satisfactorily addressed at BLN.
This NSRS issue is closed.
(Closed) R-84-05-WBN-14, Inspector Certification Records The NSRS report, dated June 1984, concluded that printouts (at Watts Bar) describing inspector certifications sometimes indicate that the 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 j
" partial" certification be identified, i
Subsequent to the NSRS report, the Nuclear Quality Assurance Manual (NQAM), Part II, Section 5.6.3 (dated July 1, 1987) established requirements for an up-to-date list of certified inspection personnel, 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.
Interviews were conducted with the DLN manager responsible for administering tests, validating certification records, and up-dating certification examinations. He stated that Inspector Certification Records are accurate and complete and that they are kept on site in the vault.
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t TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2' SPECIAL PROGRAM REVISION NUMBER:
PAGE 26 0F 40 S
2 Based on a review of the NQAM and interviews with on-site personnel. ECTG
',~
concludes this NSRS issue has been satisfactorily addressed at BLN.
This NSRS_ issue is closed.
[
(Closed) R-84-05-WBN-15. Material Inspection The NSRS investigation in 1984 at WBN indicated that installations were not checked against the modification workplans. Only a papercheck was performed.
Later, inspections of installations showed that the installations sometimes did not agree with the modification workplans.
The papercheck did not meet the requirements of " Material Control and Identification," of the OEDC QA manual for ASME Section III NCh (OEDC is 4
s Office of Engineering Design and Construction).
The investigation by ECTG involved a review of procedures and interviews with sit'e personnel.
d Procedure BNP-QCP-9.4 Revision 9 Section 5.5.1, " Work Plans," require QC to review and perform inspections as designated by workplans.
Both the supervisor of BLN DNC Completion Unit and the Group Leader of j
BLN Procedures and Training Unit stated that no discrepancies related to the referenced issue could be identified at BLN.
?
P Based on results of procedure reviewr, and personnel interviews, ECTG concludes this NSRS issue has been satisfactorily addressed at BLN.
This NSRS issue is closed.
I (Closed) R-84-17-NPS-01A, The Procurement System Is Too Cumbersome And Not Well Known By The Users NSRS stated that the biggest problem found with the procurement system
)
l used by NUC PR was its wasteful and cumbersome nature.
Procurement packages were overloaded with redundant reviews providing little or no j
value, and sometimes causing unnecessary time delays up to months.
Virtually anyone could initiate a procurement action with little or no training.
The report stated that no one was found in the procurement process that knew the process much beyond their sphere of involvement. That resulted in unrealistic expectations being placed upon the system by the originator with regard to delivery time, and in perpetuation by others in the process who did not correct the problems or expectations. One of the more cumbersome and redundant review processes occurred within the Nuclear Central Office. NSRS stated that the removal of that review process on October 1, 1984, with the transfer of people to the sites, would help streamline the process provided the Central Office problems were not also transferred to the sites.
k TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2
'j SPECIAL PROGRAM REVISION NUMBER:
PAGE 27 0F 40 I
V P:
The first of four NSRS recommendations to correct the problems was as
.i
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follows:
[
The Procurement Problem Task Force recommendation to eliminate all i
unnecessary steps in the procurement cycle with the goal of placing very.few, if any, steps between the requisitioner and the purchasing a6ent should.be given the highest priority.
ECTG determined that the procurement process at BLN is being revised with
- the goal of. making it user friendly to the ultimate user. BLN procurement
{
personnel outlined four main problems in the past as follows:
(1)
?
inventory level too low to support the level of activity, (2) inadequate planning at the original design stage to identify the basic components and related piece parts that would be needed by maintenance / modifications, j
(3) inadequate tracking system, and (4) lack of adequate automated systems
)
j to support the material logistics needs.
Corrective actions included:
i
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problem caused by " stock out". (2) analyzing the Q-list for its basic (1) restocking of heavily used items in inventory to ease the procurement
)
.i replacement items and components under contract *71C62-5411-2 with B&W so j
that the needed " mini-specs" are available when needed for procurement, f-(3) installing a tracking system by September 1, 1987 that will track the procurement status from the foreman to receipt inspection and (4) working l
[.
with DNE's ADP branch to structure a program that will handle the " cradle-to grave" information needed to procure safety related materials.
[j p
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Based on BLN's in-process and completed work to simplify the procurement system from the user's perspective, this NSRS item is closed at i
Bellefonte.
1
.l (Closed) R-84-17-NPS-01B, The Procurement System Is Too Cumbersome And l
Not Well Known By Yhe Users
]
1 NSRS identified problems with the procurement system used by NUC PR (see R-84-17-NPS-01A for problem description). The second of four NSRS recommendations to correct the problems was as follows:
A forma'.ized, documented training program covering the entire procurement process should be developed and required for all l
personnel within the procurement cycle form the originator I
(requisitioner) through the purchasing agent.
ECTG verified that the procurement process is now documented in NQAM Part III, Section 2.1 and BLN Site Director's Standard Practice BLA 9.1,
" Procurement of Materials, Components Spare Parts, and Services."
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 28 0F 40 b
j.,
j Training in the use of the MAMS system to enable employees to locate g
material and to track their own procurement is offered on a continuing basis. At the time of the ECTG verification activity, the most recent s
(
session had been held July 30, 1987 in Power Stores to train users in the tracking system feature of MAMS.
BLN procurement personnel stated that U
training on the entire procurement cycle from the originator thecuta the purchasing agent is now accomplished, but that improvements in the l
procurement process, as described above in R-84-17-NPS-OlA, also were i
expected to contribute a great deal to user understanding.
p Based on the continuing emphasis on training and user understanding, this NSRS issue is closed.
~
(Closed) R-84-17-NPS-01D, 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 a
R-84-17-NPS-01A for problem description). The NSRS recommende'. ion to P
correct the problems was as follows:
f Material availability and procurement timeframes should be included in all maintenanec and modification planning activities.
(NOTE:
j This recommendation is predicated upon information that NUC FR is developing a maintenance and modification planning and scheduling function at each site.)
BLN personnel stated that availability of material is now considered in all BLN construction and maintenance activities. BLN slowed down construction in FY 1985 and cut back on site activities. Along with these actions the inventory of materials was limited to only what was needed for repairs or the specific construction or modification.
Consequently, inventory of some items fell to zero which caused some delays in repairing equipment and structures.
However, recent accelerated inventory acquisitioning has reduced the problems of delays in the
)
procurement process.
Based on the implementation of the NSRS recommendation, with consideration of the overall BLN construction slowdown, this NSRS item.is closed.
(Closed) R-84-17-NPS-04, Insufficient Documentation For Transferred Material l
l The NSRS report concluded that sites requesting material to be transferred to them by another TVA organization or location did not specifically identify documentation requirements or require a copy of the 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 assumed that all applicable documentation had been sent by the transferring organization without knowing exactly what the original specifications (technical /QA) were.
TVA EMPLOYEE CONCERNS RRPORT NUMBER:
BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 29 0F 40 b
NSRS recommended chat NUC PR implement requirements regarding. transferred i
[
material.
A copy.of the original contract should be in the possession of j:
-and used by the receiving' site during receipt inspection, and QC
~ 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 BLN program.
ECTG verified that BLN Site Director's Standard Practice BLA 9.9, " Transfer of Material / Items," now requires the applicable documentation for transferred l
material.
[
Based on implementation of the NSRS recommendation, this NSRS issue is closed at Bellefonte.
(Closed) R-84-17-NPS-06, BFN Powers Stores Clerks Not Trained To Inspect Material l
In the original review, NSRS concluded that power stores clerks were not s
trained to receive materials with Certificates Of Conformance (C0C),
)
Certified Mill Test Reports (CMTR), or other similar QC documentation.
The NSRS report identified instances where personnel performed receipt f
inspection'and acceptance of material incorrectly. NSRS recommended that the Division of Nuclear Power revise the Operations Quality Assurance
)
' Manual (0QAM) to prohibit receipt inspection except by qualified QC inspectors of material'with QC documentation.
ECTG verified that the Nuclear Quality Assurance Manual (NQAM), Part II, f.
Section 5.3A now establishes requirements that only qualified and certified inspectors can receive safety-related materials. The NQAM requirements are implemented at Bellefonte through the BLN Site l
Director's Standard Practice BLA 9.2, " Receipt Inspection."
Based on implementation of the NSRS recommendation, this item is closed h
at Bellefonte.
(Closed) R-84-17-NPS-07, Material With Limited Shelf Life Not Recorded In A Timely Manner In the original review, NSRS concluded that Browns Ferry was not ordering material with sufficient lead time to have new material on hand before 1
existing material shelf life expired. The NSRS recommended the following q
program changes:
(1) Revise the 0QAM 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.
( s TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM L
REVISION NUMBER:
l PAGE 30 0F;40
)
r
- ECTG examined this issue for' applicability at BLN.
It was determined
(
that'BLN does not yet have a problem with shelf life of nuclear L
safety-related materials since there is very little such material in l
f inventory during the BLN construction slow-down. Material on hand is E
reviewed six months before expiration date in order to reorder in a-L timely manner.
1 Based on BLN's plant status and material ordering practices, this NSRS item.is closed.
W.
(Closed) R-84-17-NPS-09, 10 CFR Part 21 Requirements Incorrectly Linked To Nuclear Power QA Requirements p/
In the original review, NSRS concluded that the manufacturing quality and receipt inspections were automatically reduced when 10 CFR, Part 21 requirements were' determined not applicable. 'Also, the requirements of the OQAM, Part III Section 2.1, Appendix F, Attachment I were deficient F
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:
1.
Remove the influence of 10 CFR Part 21 applicability upon the
[
determination of required quality levels for items or services.
Revise OQAM Part III, Section 2.1 Appendix F accordingly.
2.
3-3.
Retrain all personnel involved in the procurement cycle.
4.
The OQAM shall be format ted so that all questions on the j
g applicability form are' answered whether or not 10 CFR, Part 21 is applicable to the item or service.
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 been revised to reflect the new program.
10 CFR Part 21 applic. ability is now determined separately from quality levels (reference: Appendix F, Section 3.0) and is also reviewed by trained DNE engineering personnel.
The NQAM requirements related to the manufactured quality and receipt inspections are being implemented in BLN Site Director's Standard l
Practices BLA 9.1 " Procurement of Materials, Components, Spare Parts, and Services" and BLA 9.2 " Receipt Inspection." Based on the revised ONP requirements and BLN implementing procedures concerning 10 CFR, Part 21 applicability, this NSRS item is closed.
(Open) R-84-22-BLN-01, Adequacy of Low Temperature Reactor Vessel Overpressurization Protection NSRS report R-84-22-BLN-01 found inadequate the Low Temperature Reactor i
Vessel Overpressurization Protection (LTOP).
This system is used to remove residual or decay heat from the reactor ces ing plant shutdown.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS.J SPECIAL PROGRAM REVISION NUMBER:
E PAGE 31 0F 40 There are pressure and temperature constraints on the LTOP system and the reactor vessel and primary system piping land components.. These t
constraints change as the reactor plant accumulates radiation 1 modifications during its operating life.
NSRS recommended that additional protection be provided and documented.
They also recommended that Babcock and Wilcox provide an analysis showing-that.the LTOP system will provide overpressurization protection for the full 32 effective full-power years required by.the FSAR.
The Bellefonte response to the subject NSRS report concerning the adequacy of low temperature reactor vessel overpressurization protection (Memorandum from W. R. Brown Jr., to K. W. Whitt dated May 28, 1985, RIMS B45 850528 251) states the following:
As noted by B&W,."The RCS pressure limit shown on FSAR figure.5.5.2-3 is based on a conservative prediction of the accumulated radiation for the reactor vessel over the plant lifetime." As seen in the NRC proposed standard tech specs for B&W plants, the heatup and cool down curves.give 2
a higher system pressure limit. The curves. include a 25 lb/in s margin for instrument error. These are the curves to be used for the first two to five years of plant life. As noted by B&W and in the standard tech specs, further revision of the tech spec RCS pressure limit figures would be based on the test results of the irradiation surveillance specimens when they are removed from the reactor vessel. B&W goes on to state that, " Surveillance specimen test results from the operating reactors are showing accumulated radiation of 60 to 70 percent below the predicted t.
.value; this would result in higher RCS precsure limits'than now f
predicted." Thus, TVA agrees with B&W that no additional low temperature reactor vessel'overpressurization protection measures be instituted.
i NSRS evaluated the DNE response and determined their concerns to be I-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.
Resolution of CATD R-84-22-BLN-02, issued with ECTG report BLN-NSRS-1, will resolve this item. This item remains open.
(Closed) R-84-25-BLN-03, Design Modification to Prevent Steam Line Breaks From Damaging Main Steam Isolation Valve (MSIV)
NSRS report R-84-25-BLN-03 findings concerned a need for design modifications to prevent steam line breaks from damaging a main steam valve.
Section 3.6.2.1.2.1.5 of the FSAR stated that pipe breaks outside l-of the main steam valve vaults do not jeopardize equipment within the main steam vaults.
However, report CEB-77-10 stated that a break of j
SMB-94 may damage the "A" steam generator MSIVs.
l
'TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2
+
i SPECIAL PROGRAM REVISION NUMBER:
PAGE 32 0F 40 j
.NSRS recommended that the design of BLN be modified to prevent all l
steam-line breaks.outside of'the valve from damaging an MSIV or demonstrate that the' break does not damage the MSIVs.
-1 The NSRS R-84-25-BLN' findings and implementation status'of the.
recommendations were investigated by ECTG and reported in ECTG' It was determined Report 30711 " Nuclear Power Site Program / Procedures."
that.CEB Pipe Break' Evaluation Report CEB 77-10.had been revised, and the.
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BLN design was. acceptable. Based on this resolution, the NSRS item is
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closed.
(Closed) R-84-25-BLN-04 Inconsistencies In BLN Main Steam System Design And FSAR NSRS report item R-84-25-BLN-04 concerned inconsistencies in the BLN Main Steam System Design and FSAR requirements.
Section 3.6.2.1.2.1.5 of the
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BLN FSAR states that the. pipe break exclusion applies only to the 32-inch diameter main steam piping and to the 20 and 22-inch diameter main feedwater. piping. However, CEB report 77-10 does not postulate'any.
breaks in any size piping within the main steam. vaults.
NSRS recommended that the inconsistencies in BLN design be corrected and that the commitments in FSAR section 3.6.2.1.5 and CEB 77-10 be fully met.
j l
The engineering response.to the above finding stated agreement that a discrepancy existed concerning break exclusion application. Engineering would use break exclusion for high energy branch line piping and main run piping in the main valve vaults.
Engineering stated that the BLN FSAR
)L and CEB 77-10 would'be updated to reflect the engineering position and provide consistency in BLN design documents.
b' The NSRS R-84-25-BLN findings and implementation status of the 4
i recommendations were investigated by ECTG and reported in ECTG It was determined Report 30711 " Nuclear Power Site Program / Procedures."
DNE that the Pipe Break Evaluation Report CEB 77-10 had been revised.
j committed (ECTG CAP 30711, Revision 2) to provide the FSAR clarifications prior to fuel loading, i
Based on the above resolution, and tracting of the item under CAP 30711-NPS-1, this NSRS item is closed.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2
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SPECIAL PROGRAM 1
REVISION NUMBER:
PAGE 33 0F 40 (Closed) k-84-25-BLN-05, Design Modification Of Main Steam System Or Main i.
Valve Vaults
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This NSRSl item. concerned the possibility of tornado damage causing a two steam generator blowdown type accident.
FSAR section 3.5.2 stated that if tornado mi!:siles damaged main steam lines and isolation valves in the unprotected "A" steam valve vault, the plant can be cooled down as described in FSAR section 15.1.5 with single failure capability.
However, said NSRS, if this described scenario occurred and an MSIV in j
the "B" main steam valve vault were postulated to fall open, then a j
two-steam-generator blowdown would occur which the turbine stop valves l
would not be able to terminate. The BLN FSAR states in section 10.3 that I
c the design of the main steam system prevents the uncontrolled blowdown of j
two steam generators after a steam line break and a postulated single l
failure.
i NSRS recommended that the design of the main steam system or the main steam valve vaults be modified to comply with the requirements of FSAR sections 3.5.2, 10.3, and 15.1.5 or that an analysis of a two-steam-generator blowdown event be made which shows that ttie l
consequences.are acceptable.
I l
OE responded (B45 8505 17263) that some clarification may be needed in FSAR sections 3.5.2 and 10.3 and in TVA's response to FSAR question 410.11.
These FSAR clarifications would explain assumptions made in the
]
TVA analyses.
Additionally, a summary of an EN DES calculation (TI-RAE-5) was provided to show that probability of a steam line rupture and failure of an MSIV due to tornado missile strike concurrent with a random single failure of one of the MSIVs on the opposite steam generator was determined to be 1.0x10-6 per year.
g OE concluded that, due to the extremely low probability of this scenario occurring, it would be very difficult, if not impossible, to justify any i
modification to prevent or lessen the likelihood of this event.
5 The NSRS R-84-25-BLN findings and implementation status of the recommendations were investigated by ECTG cnd reported in ECTG Report 30711 " Nuclear Power Site Program / Procedures." ECTG found the OE response adequate for BLN.
DNE committed (ECTG CAP 30711, Revision 2] to provide the FSAR clarifications prior to fuel loading.
i Based on the above resolution, and tracking of the item under CAP 30711-NPS-1, this NSRS item is closed.
p t
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 34 0F 40 (Closed) R-84-25-BLN-06, Documentation of Maximum Allowable Steam Flow Rate After Steam Line Brest The original report stated that the maximum allowable steam flow rate from the unaffected steam line break needed to be documented in the design bases for the main steam system.
NSRS was unable to find evidence of_these considerations by the NSRS vendor in the design basis for the main steam system.
NSRS recommended that the maximum allowable steam flow rate from the unaffected steam generator after a steam line break be established by the NSSS vendor based on analysis of such steam line breaks and that this flow and its basis be documented in the design bases for BLN and be traceable to the NSSS vendors " analysis."
The OE response (B45 8505 17263) stated that to determine the maximum allowable steam flow rete from the unaffected steam generator after a steam line break, it was required that the following sequence of events p
be postulated:
(1) a steam line break, (2) a failure of an MSIV on the unaffected steam generator, and (3) the failure of other parallel sets of l
valves downstream of the MSIV. OE stated that "due to the extremely low j
probability of this sequer.ce of events occurring, we see no benefit in performing costly analyses to determine the maximum allowable steam flow rate from an unaffected steam generator that Bellefonte can withstand
]
coincident with an MSLB."
The NSRS R-84-25-BLN findings and implementation status of the g
recommendations were investigated by ECTG and reported in ECTG Report 30711 " Nuclear Power Site Program / Procedures." ECTG verified that DNE had revised the CEB Pipe Break Evaluation Report CEB 77-10.
g Additionally, DNE committed to clarify FSAR provisions before BLN fuel load. The current BLN design was found acceptable.
ECTG CATD 30711-NPS-1, Revision 2 was issued to track completion of R-84-25-BLN 3
9 commitments at the TVA sites.
Based on the above resolution, 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 specification interpretations by line personnel were incorrect during a e
full power shutdown margin test.
NSRS recommended that ONP establish a policy and proceduces for the interpretation of regulations.
j ECTG has concluded that since BLN is still in the construction stage, no technical specifications have been issued at this time nor have I
L interpretation procedures been developed.
It has been determined this issue dees not apply to BLN.
i This NSRS issue is closed.
(
i TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2
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SPECIAL PROGRAM REVISION NUMBER:
PAGE 35 0F 40
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(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 JISRS~that procedural controls were of paramount importance. NSRS recommended that.ONP management. establish a written policy to ensure q
necessary commitment to procedural controls and to strict adherence to procedures.
ECTG interviewed the BLN Operations Supervisor and the following information was provided. He stated that BLN is not performin61 any pre-operational activities, however, they are.in'the process l.of develo?ing procedures for re-qualification of assistant reactor operators
{
(AR0s)'and reactor operators (Ros).
He further stated.that no complete systems have been' turned over from construction to nuclear power.
.c It has been determined by ECTG that, because BLN is still in the construction stage,.this NSRS issue does not apply-to BLN.
This NSRS issue is closed.
(Closed) R-84-32-NPS-1, Inadequate TVA Quality Program The NSR9 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:
1.
Identification of activities affecting quality, s?.
Identification of components, systems, structures to which the hualityprogramisapplied.
3.
Identification and definition of industry standards and guidhnee for control of activities outside the scope of regulatory requirement.
b 4.
Improvement of the Office of Engineering (OE) quality program and procedures and acceptance of the OE quality program by the Office of Nuclear Power.
5.
Incorporation of vendor data into a configuration management control system.
NSRS recommended that the Office of Nuclear Power as owner-operator should ensure that the integrated quality program, currently being j
planned and developed, will account for the identification and centrol of the attributes listed above.
p-TVA EMPLOYEE CONCERNS REPORI NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER:
PAGE 36 0F 40-i i
Based on this being a corporate issue and CATD R-84-32-NPS-1 having been l
g issued at BFN to track this' item until closure, this NSRS issue is closed for BLN.
[-
(Open)
I-84-33-BFN-07, Piping Analysis Not Satisfactory NSRS concluded that the Office of Engineering (CE) did-not perform generic' evaluation of problems identified in " Evaluation of WBN Piping y
' Analysis Review Team's Report," July 1982.
Conclusions of the 1982.
report were:
Piping analysis criteria are inaccurate and' incomplete b
Documentation of WB!( piping analysis in MEDS is incomplete Procedures for performing, verifying, and documenting WBN piping analysis do not exist E
Training is'not adequate
^*
Independent review is lacking h
QA auditors are not auditing to requirements 'f the controlling o
[.
documents NSRS recommended that the problems be reviewed, root causes determined, and corrective action established. The problems found at WBN were reviewed for applicability to BLN.
ECIG's investigation found that the above referenced issue could not be verified as being closed.
j r
CATD I-84-33-BFN-07 (BLN) has been initiated to resolve this issue.
This NSRS issue will remain open until CATD I-84-33-BFN-07 (BLN) has been satisfactorily completed and closed.
(Closed)
I-84-33-BFN-08, Failure of OA to Perform Audits and Surveillance of Identified Problem Areas Within Piping Analysis Sections The NSRS report stated that no audits or surveillance had been conducted l
or were scheduled to be performed by QA organizations of the BFN Piping 0
Analysis Section. No audits / surveillance were performed to verify the implementation and effectiveness of the piping analysis section j
procedures.
NSRS recommended performance of annual audits to encure that procedures and design criteria are being followed, and to evaluate effectiveness of the piping analysis programs.
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1
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TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2
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SPECIAL PROGRAM REVISION NUMBER:
PAGE 37 0F-40 l
ECTG reviewed applicable documentation and discussed the issue with central' office engineering design and quality assurance personnel..It was determined that the 1986 Division of. Nuclear En$ neering (DNE) Audit i
Plan' (B05 870310 001) and 1987 DNE Program Audit Schedule (B05 870303 002 and B05 870319 009) now require and schedule periodic audits of the piping analysis program, and that audits have been performed since the l'
NSRS' report.
Based on the requirements in place, and the scheduling and performance of
-audits'in this area, the NSRS item is closed at BLN.
(Closed) I-84-34 SQN-02, Completion of TVA Mark Letter Description on the Transfer Requisition Documents NSRS found a potential for Non-class IE. cable to be installed in a Class
.1E System when cables are transferred.from one site to another site where
)
h.
TVA cable mark letters do not define the cable the same way at both f
sites.' NSRS recommended that transfer requisitions contain the full L
description'of the cable mark letters so users would know which cables to use for which' application.
ECTG verified that the recommended information is now provided to the receiving organization and that the transferred material receives quality control material inspection.
ECTG considers the NSRS recommendations to have been appropriately implemented. This item is closed.
(Closed) I-85-06-WBN-04, Timely and Responsive Corrective Actions for Resolution of Identified Problems 3-The original NSRS report concluded that the quality assurance verification program for electrical engineering and design activities was 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.
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 Schedule - Preparation and Distribution), as well as the instruction for technical and program audits (EA-I 65.04, " Engineering Assurance Internal L
Audit Program").. The schedules identified at least eight electrical engineering audits in 1986 and additional oner in 1987, including an audit (Report B05 860428 004) for the BLEP Electrical Design Project.
I The guidance for verification of technical issues was verified to be included in the DNE procedures.
I Based on the above review, this NSRS item is closed.
j
TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2
- E SPECIAL PROGRAM REVISION NUMBER:
PAGE 38 0F 40 L
(Closed) I-85-06-VBN-05, Underdevelopment of Established and Documented
{
Limited 0A Program and Failure to Incorporate the Established Limited QA Program Into Nuclear b'
Ouality Assurance Martur.-(NOAM)
L.
The implementation 1 of the limit'ed QA program as established in OEDC-PRM-QAI-2 was determined by NSRS to be inadequate. Also, the NQAM was determined to be inadequate in addressing the limited QA program as l
established by the' superseded OEDC-PRM-2QAI-2 document.
NSRS recommended the Division of Quality Assurance (DQA) identify the s-required "special controls" applicable to systems previously identified as " limited QA",in the NQAM. Appropriate line organizations should f.'
incorporate those requirements into the OE, OC, and NUC PR procedures for implementation by the appropriate offices. In.the original report applicable 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 J
limited QA consideration, OE should perform an evaluation to ascertain the impact of not implementing the established " limited QA" program on the other. systems identified in OEDC-PRM-2QAI-2.
ECTG considered this issue potentially applicable to other sites and investigated it at BLN, as follows:
p' The portion of the issue concarning the NQAM was closed by issuance of s
NQAM Part 1. Section 1.3, Revision 1 dated December 12, 1986 which outlines the limited QA program requirements for ONP. This is a generic l
procedure.
Based on interviews with the BLN supervisors of Procedures / Training Unit
?
and Mechanical Engineering Unit, and reHew of BLN documentation concerning the limited QA program ECTG x termined that BLN has a program I
for identifying items classified as limited QA and for implementing the NQAM requirements.
b.
BLN site procedures (e.g., BNP-QCP 1.1, " Receiving Inspection" and p
BNP-QCP-10.3, " Preparation and Review of Field Procurement Documents")
discuss the BLN program for implementing limited QA requirements. The critical systems structures and components (CSSC) list identifies the BLN items classified as limited QA. Plant procedures (e.g.,, CTP 6.1,
" Construction Test Procedure, Cleaning and Flushing of Systems") indicate
[
the limited QA applications.
I
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In summary, the BLN list of plant equipment distinguishes among the 6'
classifications of QA, limited QA, and non-QA.
Limited QA is designated as "1".
Drawings identify components with limited QA classification.
BLN quality control procedures indicate if the procedure applies to limited QA classification activities.
Based on the above review of the BLN limited QA program, this NSRS issue is' closed at BLN.
i TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM I
REVISION NUMBER:
i PAGE 39 0F 40 (Closed) E-85-07-NPS-1, Manager Of Power and Engineering Appointment Of l
A Records Manager NSRS found that no upper management coordination entity was available as a focal point for resolution of programmatic problems regarding accumulation, storage, transfer, and retrieval of the records for procurement requiring Quality Engineering Branch (QEB) source inspection.
NSRS recommended that an upper-level manager be assigned with responsibility to include all past and future product verification records (fornially QEB records).
ECTG issued CATD R-85-07-NPS-1 at Watts Bar concern *ng assignment of upper-level management responsibility for the QEB records at all TVA sites.
Resolution of this issue by WBN will resolve this issue for BLN.
This item is therefore considered closed for BLN.
l (closed) Fourteen Safeguards Items Identified In Section I The following action was taken by ECTG to verify the closure of 14 NSRS 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.
l 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 security by ONP are:
I Procedure 0401.01 Procedure 0401.02 Procedure 0401.03 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 I
TVA Nuclear Security Program Enhancement Security Personnel Training and Qualification Plan Based on the review of the above documents, the 14 NSRS issues found in 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 870520 884, these issues are considered complete and closed.
l TVA EMPLOYEE CONCERNS REPORT NUMBER: BLN-NSRS-2 SPECIAL PROGRAM REVISION hW BER:
j.
PAGE 40 0F 40 Attachments:
d CATD 79-09-01-1 (BLN)
CATD I-83-13-NPS-2 f*
CATD R-83-08-BLN-05 CATD R-83-18-NPS-02 q-CATD I-84-33-BFN-07 (BLN) 7
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l
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ECTG C.3 Attachment A Page 1 of I Revision 4 4
ECTG Corrective s.
Action Tracting Document (CATD) l I
f INITIATION Applicable ECTG Report No.:
BLN-NSRS-2 1.
Immediate Corrective Action Required:
0 Yes ki No 2.
Stoo Work Recommended: O Yes
)( No 3.
CATD No. 79-09-01-1 (BLN) 4.
INITIATION DATE 07/09/87
)
5.
RESPONSIBLE ORGANIZATION:
BLN Site Director 6.
PROBLEM DESCRIPTION: 2(QR O NQR NSRS Report 79-09-01-1 Testing of Protective relays, meters, indicating instruments, and transducers on the 480V shutdown boards, 6900V shutdown boards, and diesel generator boards could not be performed without lifting leads, installing test leads, removing test leads, and reterminating board wiring.
2 ATTACHMENTS 7.
PREPARED BY: NAME Don CossetA(/b [#,M DATE:
07/09/87 8.
CONCURRENCE:
CEG-H lhh DATE:
t/s o / (7 9.
APPROVAL:
ECTG PROGRAM MGR.
- 8JZ An DATE:
1Fh.//87
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y
/ /
CORRECTIVE ACTION
!gY..>
10.
PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHMENTS 11.
PROPOSED BY:
DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSE0UT 13.
Approved corrective actions have been verified as satisfactorily implemented.
j SIGNATURE TITLE DATE l
5884T l<
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1 1
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FACT SHEET T-w h
(Open) 79-09-01-1, Excessive Wire liftinq practices to' Facilitate Testinq
- The above' referenced NSRS concern was initiated in 1979 at W8N and was also' determined"to be generic to BLN.
It stated that testing of y
protective relays, meters, indicating instruments, and transducers on the e-f' 480 volt shutdown boards, 6900 volt shutdown boards, and diesel generator L
' boards coulds not be performed without lifting leads, installing test leads, removing test leads, and reterminating board wiring, b;
The.NSRS corrective-action recommendation. stated that DNP should submit'a.
f DCR to define 'where ' test b]ocks' were needed and also provide a point of g
contact to assist EN DES in the design, p
ECTG's investigation revealed that BLN has not installed PK test blocks
[
as-a means to. facilitate testing of protective relays, transducers, g
indicating. instruments, and meters, g
L
- During the investigation, the DPSO supervisor stated emphatically that h.
test blocks should be installed in the equipment referenced by this l'
issue.
He also presented a fourteen (14) page handwritten report-to ECTG that documented his views.
p.#
ECTG recommends that DNE review the DPSO supervisor's report and discuss it with him to gain.a complete understanding of his views.
ECTG further
~
recommends, based on DNE's review of the issue, that either PK test blocks be installed or justification given to substantiate an engineering decir. ion not:to install them.
'I CATO 79-09-01-1 (BLN) has been initiated and issued to ensure this NSRS issue is properly addressed.
This issue will remain open unt-il h-CATD 79-09-01-1 (BLN) is closed.
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ECTG C.3 Attachment A Page 1 of 1 Revision 4
- . Ik ECTG Corrective Action Tracking Document (CATD) f' INITIATION'.
Applicable ECTG Report No.:
BLN-NSRS-2 1.
Immediate Corrective Action' Required: 0 Yes O No 2.
Stop Work Recommended: 0 Yes M No 3.
CATD No. I-83-13-NPS-2(BLN) 4.
INITIATION DATE 7/23/87 5.
RESPONSIBLE ORGANIZATION:
BLN Site Director 6.
PROBLEM DESCRIPTION: 5 QR O NQR NSRS Report I-83-13-NPS-2 t..
No schedule was provided that established when vendor records jD would be verified as complete or indexed for retrieveability. OEB
_has not established a schedule to verify or inder records at SON and WBN.
m E ATTACHMENTS-7.
PREPARED BY: NAME Don Cossiett h ( 0 -r F DATE:
7/23/87 8.
CONCURRENCE:
CEG-H (ha s DATE:
&/Jo/87 f'. '
9.
APPROVAL: ECTG PROGRAM MGR.
- M A DATE:
47u/87 y
i i 1
l' g CORRECTIVE ACTION
,.c.
10.
PROPOSED CORRECTIVE ACTION PLAN:
[
l-h 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 p-implemented.
SIGNATURE TITLE DATE f
~I 5967T
e (v.
FACT SHEET g
(Open) I-83-13-NPS-2, Quality Engineering Branch (CEB) Records d
u This issue, as investigated by NSRS in 1983, stated that no schedule was provided that established when vendor records themselves would be g
verified as c,omplete or indexed for 'retrievability.
QEB has not established a schedule to verify or index records at SQN and WBN.
This issue was investigated at SQN and 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, and ONP regarding vendor records.
The ECTG investigation indicated that procedures are in place to index, file, and retrieve. vendor records.
QMI-446 (which superceded i
OEB-EP-24.58) titled Supplier Document Review and QMI-450 (which superceded QED-EP-24.37) titled Contract Record Index and Filing-address j
the issue of vendor records,
g In addition, QEB personnel stated that records for BLN have not been N
indexed or microfilmed at this time.
Rccords are in hard copy form with field and contractor copies used as back up.
Based on interviews with QEB personnel, ECTG concludes that this NSRS issue has n;; been adequately addressed.
CATD I-83-13-NPS-2 has been issued to insure satisfactory resolution of this issue.
This issue will remain open until CATD I-83-13-NPS-2 is
- closed, i
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I ECTG C.3 Attachment A Page 1 of 1 le' vision 4 I>
ECTG Corrective y.
Action Tracting Document _
(CATD) y T
. INITIATION Applicable ECTG Report No.:
ECTG-NSRS B L kJ - u 5 p.r -
1_.
Il i
1.
Immediate Corrective Action. Required: 3 Yes O No 2.
Stop Work Recommended:
O. Yes
.S No 9
3.
CATD No.
R-83-08-BLN-05 4
' INITIATION DATE 05/14/87 5.
. RESPONSIBLE ORGANIZATION: BLN Site Director 6.
PROBLEM DESCRIPTION:.E QR O NQR NSRS Report R-83-08-BLN-5 i
Approval of the 1/8-Inch Variance for Acceptable Purge Dam Residual.
Partical Size g.
Specification Revision Notice SRN-NAM-891-2 states in part. " paper r, "
and glue particles up to 1/8-inch in any direction appearing on the strainer during proof flushing are acceptable."- The relaxation of
')
particle size from 1/32-inch to 1/8-inch Kranted by EN DES. had not been approved by either the ANSI committee or the NRC.
El ATTACHMENTS 7.
PREPARED BY: NAME K. R. Gass ff h_
DATE:
05/16/87 8.
CONCURRENCE:
CEG-H A. G. Debbage d/siv/nton-DATE:
05/16/87 I
9.
APPROVAL:
ECTG PROGRAM MGR.
- M4h
' /* DATE:
(/4/0,7 6/
/
/
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
1 l
L O ATTACHMENTS 11.
PROPOSED BY:
DIRECTOR /MGR:
DATE:
I 12.
CONCURRENCE: CEG-H:
DATE:
i ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSE0UT I
)
13.
Approved corrective actions have been verified as satisfactorily L
implemented.
l SIGNATURE TITLE DATE 5143T
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FACT SHEET 3
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.(Open) R-83-08-BLN-05,. Approval of the 1/8-inch Variance for Acceptable h.
Purge Dam Residual Particle Size NSRS' conducted a review at Bellefonte Nuclear Plant (BLN) concerning.
piping system, flushing activities.
They noted BLN was committed to the j
requirements of ANSI N45.2.1-1973.
This standard permits the allowable
?
size of purge' dam material to be no greater than 1/32 inch.
The q
1 implementing document for these activities is. General' Construction i
y-Specification G-39.
This issue was considered generic to Browns Ferry
- j Nuclear Plant (BFN).
1 y
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 Ga39
+
Specification' and ANSI Standard N45.2.1-1973.
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NSRSErecummended 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 f
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 f '. (%h documenting the results to ensure that the 1/8 inch acceptance criteria is applied only to properly identified and measured purge dam materials.
i ECTG's interviews with DNE engineers from Knoxville indicate that the NRC l
has not agreed to a variance as described in the issue.
He further L
stated that this issue could not be closed until the NRC had made a.
decisaon.
CATD R-83-08-BLN-05 has been written and issued to track this open item until a solution has been reached and the CATD closed.
This NSRS issue remains open at BLN.
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ECTG C.3 y
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D; Attachment A Page 1 of 1
' Revision 4 ap
, ECTG Corrective
{
Action Tracking Document
- j d
(CATD)
I w.
k INITIATION' A_p,plicable ECTG Report No.:
BLN-NSRS-2 g
. 1'.
Immediate Corrective Action Required: O Yes B No F
2.
Stop Work Recommended: O Yes E No 3.
CATD No. CATD R-83-18-NPS-02(BLN)4.
INITIATION DATE 7/23/87 5.
RESPONSIBLE ORGANIZATION:
BLN Site Director 6.
PROBLEM DESCRIPTION: p QR O NQR NSRS Report R-83-18-NPS-02 The ONP program and Licensing: Documents for Radiation Protection and Radiological Emergency Planning had not been issued or were out-of-date.
$r S ATTACHMENTS k.
7.
PREPARED BY: NAME.
Don Cos sett h, #,m /y%-- DATE:
7/23/87 8.
CONCURRENCE:
CEG-H d4r&.4/w.,
DATE:
t /2.4 / t 7 -
f,.
9.
APPROVAL: ECTG PROGRAM MGR.
- /fWfl An DATE: /h//h7 g
t t CORRECTIVE ACTION g:
10.
. PROPOSED CORRECTIVE ACTION PLAN:
p O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
-12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSE0UT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
(..
5967T
w I
r w s FACT SHEET
-?( J S
- (Open) R-83-18-NPS-02, Of fice of Nuclear Power Proqram and ' Licensinq Oocumenti n
W-7-
This 'NSRS issue concerned Of fice of Nuclear Power program and licensing-documents for radiation protection and radiological emergency planning-which had not been issued or were out-of-date.
NSRS recommended additional: re' sources 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 rediation protection and radiological.
emergency. planning.
4am
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Following L review of th'e applicable documentation, ECTG determined that k-this issue is still open, l The FSAR and. Technics 1 Specifications do 'not 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.
p
' protection was removed and placed-in the Radiation _ Protection Plan.
The Area Program Manual.was replaced by tbc other sites Radiological 9
. Emergency Plan' which now reflects. the current organizational structure.
Notification to _the NRC concerning the current organization wc-initiated 4
by TVA December 10, 1986 and, following NRC approval, the currant f?>
organizational. structure will be ready for incorporation into' the d'
~'
Technical Specifications.
The completion of the updates to the Technical 9
x Specifications ~ and FSAR will be tracked with ECTG CATD R-83-18-NPS-02 for BLN.
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This item remains open.
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ECTG C.3 e **
Attachment A I
Page 1 of 1 Revision 4
}, !
ECTG Corrective L
Action Tracking Document
_(.C. AT_D_1 fk '
5:
~. INITIATION Applicable ECTG Report No.:
BLN-NSRS-2 b; f.
I t
1.
Immediate' Corrective Action Required: O Yes 00 No 9
'2.
Stop Work Recommended: O Yes 00 No 3.
CATD No. I-84-33-BFN-07 (BLN) 4 INITIATION DATE 07/16/87 4
5.
RESPONSIBLE ORGANIZATION:
BLN Site Director D
6.
PROBLEM DESCRIPTION: % QR O NQR NSRS Report I-84-33-BFN NSRS concluded that Office of Engineering did not perform generic evaluation of problems in the piping' analysis area.
See attached sheet for details.
The NSFS recommendation should be followed.
f, Bellefonte Element Report 218.4(D) contains related issues, c
4 GirATTACHMENTS F
7.
PREPARED BY:.NAME W. S. Karsner W / # e DATE:
07/16/87 8.
CONCURRENCE:
CEG-H h
DATE:
t/.24 / t 7 -
[
9.
APPROVAL: ECTG PROGRAM MGR.
8./. A4/4
/e DATE: 6 fy / '/#7 V'
/~l g
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
f-i.:
O ATTACHMENTS 11.
PROPOSED BY:
DIRECTOR /MGR:
DATE:
E k
EhR E!
VERIFICATION AND CLOSE0UT i
13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE 5884T
- (
__________D
.vv FACT SHEET f
REPORT NUMBER:
I-84-33-BFN-07, Piping Analysis Not Satisfactory l
NSRS concluded that the Office of Engineering (OE) did not perform generic evaluation of problems identified in " Evaluation of VBN Piping Analysis Review Team's Report," July 1982. Conc 1 unions of p a 1982 report are:
1.
Inaccurate and incomplete piping analysis cri'teria 2.
Documentation of VBN piping analysis in MEDS is incomplete 3.
Procedures for performing, verifying, and documenting VBN piping analysis does not exist 4
Training not adequate 5.
Lack. of independent review NSRS RECOMMENDATION:
NSRS recommended that the problems be reviewed, root causes determined, and corrective action established.
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