ML20215L852

Rev 3 to TVA Employee Concerns Special Program Element Rept 229.1(B), Instrumentation & Control Design

ML20215L852
Person / Time
Site:	Sequoyah
Issue date:	05/07/1987
From:	Russell Gibbs, Martin M TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215L813	List: ML20215L810 ML20215L829 ML20215L842 ML20215L852 ML20215L857 ML20215L860 ML20215L872
References
229.1(B), 229.1(B)-R03, 229.1(B)-R3, NUDOCS 8705120400
Download: ML20215L852 (32)

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e D'S TVA EMPLOYEE CONCERNS REPORT NUMBER: 229.1 (B)

J SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: -3 TITLE: INSTRUMENTATION AND CONTROL DESIGN Questionable Calculation of PAGE 1 0F 30 Orifice Hole Design REASON FOR REVISION:

2. Incorporated SRP and TAS comments and added Section 10. " Corrective Action."

3. Incorporated revised CAP PREPARATION A

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8705120400 87050s PDR ADOCK 05000327 ikNer  %/f/f7 P PDR CEG-H: NA N 4-P'-27 SRP:k ki S -l= - 8 7 SIGNATURE DATE SIGNAiURE* DATE

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APPROVED BY:

M.5. dub - SPECIAL PROGRAM REPORT NUMBER: _ 229.1 (B)

REVISION NUMBER: 3

'N PAGE 3 0F 30

3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:

Contract 83520-1.

4. INTERVIEW FILES REVIEWED:

NS-85-004 and PH-85-022 expurgated and working files containing the following were reviewed on October 15, 1986.

NS-85-004-001 Exp. File: 1. K-form 001

2. Form 0350, file screening sheet, QTC Employee Concern file Working File: .l. Copy K-form 001

2. Form G-A

3. Form N

4. Form I

, 'eg 5. From D

) 6. Form 1, 2 i- 7. Memo K. W. Whitt to W. T. Cottle, 02/27/86, with attached WBNP response to NSRS.

Investigation Report I-85-525-WBN

8. Copy of meno, 01/30/86, W. T. Cottle to K. W.

Whitt with attached NSRS Report I-85-525-WBN, dated 12/17/85 for concerns PH-85-022-001 and NS-85-004-001

- PH-85-022-001 Exp. File: 1. K-form 001

2. Form 04350, file screening sheet, QTC Employee Concern file Working File: 1. ' Copy of K-form 001

2. Forms G-A, 0, 1 and 2

3. Memo K. W. Whitt to W. T. Cottle, 02/27/86 with attached NSRS Report I-85-525-WBN

4. Memo W. T. Cottle to K. W. Whitt, dated 01/30/86

5. Memo J. C. Standifer to W. T. Cottle, dated 01/17/86

6. Memo W. T. Cottle to J. C. Standifer, dated 01/03/86 with attached NSRS Report I-85-525-WBN, dated 12/17/86 0378D-2 (03/31/87)

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,... r Pf : .; TVA EWLOYEE CONCERNS-

', REPORT. NUMBER:. 22921-(B)!

A _

~SPECIAL PROGRAM-

~ REVISION NUMBER: '3

?.' PAGE 4 0F 30

5. DOCUMENTS REVIEWED RELATED T0 THE ELEMENT:

-See Appendix ~A.

6.- WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?.

See' AppendixA.

7. LIST REQUESTS FOR-INFORMATION, MEETINGS, TELEPHONE-CALLS, AND'OTHER~

DISCUSSIONS RELATED TO ELEMENT.

See Appendix:A.

8. EVALUATION PROCESS:

/G,p a. Reviewed N'SRS Investigation Report I-85-525-WBN and SQN GCTF-3 4);

Investigation of EC IN-85-293-001,- PH-85-022-001,t and

O NS-85-004-001 to determine applicability to Sequoyah and validity / adequacy _of corrective actions.

b. Reviewed calculational data on the existing TVA contract with Meriam Instrument-Co. to establish methodology of orifice sizing and resulting bore sizes.

c. . Compared this methodology with industry standard practices on accuracy requirements for orifice plate flow elements.

d. Reviewed TVA Design Standards (DS-E18.3.6 and DS-E18.1.10) to establish specific SQN accuracy requirements.

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_e. By separate calculations determined the impact the above comparisons would have on the SQN performance requirements including Post Accident Monitoring.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 229.1 (B) 1 SPECIAL PROGRAM REVISION NUMBER: 3

'. PAGE 5 0F 30

9. DISCUSSION, FINDINGS, AND CONCLUSIONS:

Discussion:

Generic Applicability and Background Concern PH-85-022-001 was raised in June 1985 with specific reference to Watts Bar Contract No. 85320-1 with Meriam Instrument Co. and dealt with theoretical differences in calculating the required bore size of flow measuring orifice plates. Concern PH-85-022-001 made no reference to SQN.

Concern NS-85-004-001 was also raised on WBN in August 1985 regarding incorrect bore size but suggested that the issue could also be,a problem on SQN. Concern NS-85-004-001 did not stipulate the sourc'e of the " incorrect hole size" problems. However, investigations conducted by the evaluation team on SQN concluded, as a result-e 'ile research and personnel interviews, that concern NS-85-004-001 w..i also based on differences in calculational methods and not on such peripheral issues as manufacturing

^Q tolerance errors not detected by receiving inspection. The

,) following evaluation proceeds on this basis.

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Both concerns PH-85-022-001 and NS-85-004-001 were thoroughly investigated on WBN by NSRS which documented their investigation in Report No. 1-85-525-WBN on December 20, 1985. This was followed by a June 1986 GCTF investigation on SQN that largely depended upon and concurred with the NSRS investigation on WBN.

Definitions and Terminology The term " false," as used in Concern NS-85-004-001, is interpreted by the Evaluator as a statement of relative accuracy. This is in contrast to the more normal usage which is to convey an entirely misleading, erroneous, untrue, or wrong message. In the present case, a flow indication is considered " false" only if it is so inaccurate as to cause the plant operator or control device to take an inappropriate control action.

Previous Investiaations The GCTF SQN investigation dealt with an additional programmatic concern (IN-85-293-001) regarding documented close out of NCR 4412R. This NCR dealt with an orifice plate Beta ratio (d/D) near the upper level of acceptable tolerance. While the 0378D-2 (03/31/87)

e Y t *: .TVA EMPLOYEE' CONCERNS REPORT NUMBER: ~229.1'(B)~

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'~ ~ SPECIAL-PROGRAM.

REVISION NUMBER: 3

[ PAGE 6 0F 30 Meriam orifice plates in question were replaced, the GCTF SQN

.. investigation did not find that the changes were technically necessary.' . In reporting the basis for these changes to the NRC,.

TVA pointed'out that, "although EN DES felt that the-orifice plates were sufficient for the system design, rather than expending time, money.and effort to verify the accuracy, it would be more cost-effective to purchase new plates". The SQN Investigation did conclude that Meriam orifice plates were used at SQN.

The NSRS Investigation on WBN (I-85-525-WBN) provided a well-balanced and technically supportable conclusion that the orifice plates in question "will-perform their intended design function." This conclusion was limited to flow signals that did not involve post accident monitoring (PAM). For PAM flow signals the NSRS report went on to say:

...overall acceptability of those plates providing signals to the PAM system was considered indeterminate pending a documented design evaluation to ensure they will perform within the accuracies assumed in the design calculations."

GN C)- The overall issue of flow signal accuracy differences developed by

• various orifice plate sizing methods is . generic to SQN and is investigated here accordingly. The " indeterminate" issue.of such flow signal acceptability for PAM, as left open in the WBN' Investigation Report statement above, is equally generic to SQN and will be given special emphasis in-this report to close out the issue.

Industry Practices A review of industry flow metering practices was conducted. From the review, the evaluators were able to draw some conclusions as to when precise flow measurements are necessary and when still accurate but less precise applications are acceptable. Generally, whether an orifice plate (and the care taken in its sizing, installation and subsequent maintenance) constitutes a proper flow metering application depends on process conditions (flow velocity, acceptable head loss, etc.), the medium being measured (e.g.,

water, gas, oil, steam, etc.), and the end use of the flow signal.

Orifice plates are acceptable metering devices for subcooled water of reasonable purity when a ratio of orifice plate bore to pipe diameter (d/D or " Beta ratio") between 0.1 and 0.7 will produce the desired differential pressure. The ratio of inertial to viscous forces, commonly called the "Reynolds Number," is another key

-)

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i. TVA EMPLOYEE CONCERNS 7 REPORT NUMBER: 229.1 '(B)

SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 7 0F 30 factor limiting-the application of these flow elements. Minimum Reynolds Number above 10,000 for small lines and 500,000 for larger lines and maximum Reynolds Numbers of about 1,000,000 in either generally establish the domain for successful applications. Beyond these Beta ratios and.Reynolds Numbers, these flow elements suffer substantial decreases in accuracy.

Where the signal use is for vernier control of level or fluid flow, as is the case for precise mixing or close tolerances of liquid level, " precise" (i.e., derived from formulae containing Reynolds Number correction factors) designed orifice plates are more suitable than " plant" (i.e., derived from tables containing no correction factors) designed plates. The quantitative value of the flow being measured is very.important in such applications.

However, where more qualitative' fluid flow information is acceptable, " plant" designed orifice plates are quite proper. Such qualitative applications are found where the fluid flow is measured only to establish maximum or minimum limits (e.g., alarm annunciation, equipment operation) or where the flow inventory is secondary to the variable of real interest, such as tank level or

!p) temperature differential. Whether a qualitative reading is acceptable or the required accuracy of a quantitative signal is necessary, is, therefore, closely tied to the design purpose of.the system and the use of the flow reading.

TVA Desian Guidance Electrical Design Standard DS-E18.1.10, " Instrument Set Points and Limits," deals especially with the issue of instrumentation accuracy. Standard DS-E18.1.10 defines accuracy as:

"The degree of conformity of an indicated value to a recognized accepted standard value, or ideal value" The accuracy definition is expanded in DS E18.3.6 and elaborated a bit by saying:

"The degree of conformity of an indicated value to a recognized standard value, or ideal value; e.g., an accuracy of + 10 psig means that for an actual value of 100 psig, indication can range from 90 to'110 psig."

Within the overall accuracy of the instrumentation system, certain errors due to the physical properties of the sensed medium must be factored in. These " Process Measurement Errors" are defined in DS-E18.1.10 as:

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SPECIAL PROGRAM REVISION NUMBER: 3

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" Process errors that include those inherent in the measurement technique,-for example the fluid stratification effects on temperature measurements, or the effect of fluid

' density changes on level measurement."

These definitions-and standards are consistent with and derived from industry practices (App. A, 5.j, k, 1, m). Section 5 of.

DS-E18.1.0 clearly draws a relationship between required accuracy I and system design in stating that:

" Required accuracy is that accuracy necessary to ensure that the safety limit is not. exceeded by any operational transient or design basis event for which the instrument loop is required to function. The accuracy calculations must consider all sources of inaccuracy" From this it is clear that quantitative accuracies are necessary where safety limits are involved. Presumably when safety limits are not involved, .the less accurate qualitative approach is

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acceptable. This is consistent with industry practice. The only

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exceptions being in control applications where the sensed and the

'D) controlled. variables are the same. In these cases, TVA, like all other process designers, would use the measurement accuracy necessitated by the control application. This is standard design common knowledge and need not be documented in design standards.

With this guidance, the evaluation team focused on identifying systems and applicaticns that could have safety limits and on determining whether they could be exceeded by these flow elements.

System Identification The NSRS investigation on WBN listed all systems containing Meriam orifice plates. This listing, as presented in NSRS Investigation Report 1-85-525-WBN, is:

" Component Cooling System (70)

Essential Raw Cooling Water (67)

Heater Drains (6)

Raw Cooling Water (24)

)

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.. je Yd - TVA EMPLOYEE CONCERNS REPORT NUMBER: 229.1 (B) 1SPECIAL. PROGRAM REVISION NUMBER: 3

'. PAGE 9 0F 30 Waste Disposal (77)

Main Steam (1)

Feedwater (3)

High Pressure Fire Protection (26)

Demineralized Water (59)

Water Treatment (28)

Condensate (2)"

=

The parenthetical is the system number.

To ensure that the WBN listing was complete and also applicable to SQN, the evaluation team reviewed the complete SQN Instrument

~($5h~

Tabulation (App. A, 5.1) and identified all in-line differential-(({jf producing flow elements. From this the Meriam orifice' plate elements were separated from the other types of _ flow elements (e.g.,venturinozzles). Each flow element uniquely identifies the system to which it belongs by the first set of numbers on its tag (e.g., FE-67-61 is item number 61 in System 67, Essential Raw Cooling Water). Using this information, the SQN systems using Meriam orifice plates were easily identified.

Flow Signal Applications-With the SQN systems identified, the evaluation team reviewed the FSAR (App. A, 5.0), and each system's control diagram (App. A, 5.x), logic diagram ( App. A, 5.y) flow diagram ( App. A, 5.a and 5.aa, bb), design criteria (App. A, 5.cc) and design guide (App. A, 5.dd) to identify the use of the signal developed by each Meriam orifice plate flow instrument. A total listing of the 123 SQN flow elements reviewed and their related systems use is presented in Appendix E. No instances were found where flow was the primary variable and the flow signal was used for modulating control. A majority of the orifice plate flow signals are used in limit setting applications to initiate alarms or stop/ start equipment.

Typically these flow switch applications do not require precise accuracy. Where orifice plates are used to provide flow indication, the measurement is more for qualitative than for I

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• TVA EW LOYEE CONCERNS REPORT NUMBER: 229.1 (B) f- SPECIAL PROGRAM REVISION NUMBER: 3

". PAGE 10 0F 30 precise quantitative information. In many cases flow is not the primary variable of interest. For example, Heater Drains flow is indicated but system temperatures and levels are the variables of primary interest. (This distinction of " primary variable" applies to instances where the measured and the controlled variable are the same, as is the case in steam generator level control.)

Orifice plate flow elements FE-3-142 A, B and C generate signals to

.the auxiliary feedwater pump / turbine flow control system. However, review of the Main Steam and Feedwater Systems drawings, Design Criteria, Design Guides, and FSAR description (App. A, 5.0) show that these flow elements are used to limit feedwater pump / turbine maximum speed and not for modulating flow control or establishing steam generator level.

Of all .the listings in Appendix E, only the limit setting auxiliary feedwater pump flow signal mentioned above and those flow signals in safety systems used for PAM qualified for closer examination and compliance with TVA Design Standard DS-E18.1.10.

PAM Flow Signals g;'

'D-The evaluators used Regulatory Guide 1.97 to identify the typical PAM variables. Regulatory Guide 1.97 identifies the following flow variables as " Type D" required to indicate the operations of individual safety systems and other systems important to safety.. ,

RHR System Flow SI Boric Acid Charging Flow Flow in HPI System Flow in LPI System Main Feedwater Flow Auxiliary Feedwater Flow Containment Spray Flow CVCS Makeup Flow In CVCS Letdown Flow Out CCW Flow to ESP System 03780-2 (03/31/87) w- e- .- -t

V4  :. TVA EMPLOYEE CONCERNS REPORT NUMBER: 229.1 (B) i SPECIAL PROGRAM REVISION NUMBER: 3

'. PAGE 11 0F' 30 In each case, Regulatory Guide 1.97 establishes the required flow range as being from "O to 110% of the maximum flow anticipated during operation"; no specific accuracy requirements are stated.

The stipulated purpose of each flow signal is "To monitor operation" of the safety system.- This is a qualitative purpose to be contrasted with a more quantitative purpose such as controlling or metering flow. A flow indication for this purpose does not directly cause a safety limit to be exceeded and, therefore, the qualitative application the flow signal stipulated in Regulatory Guide 1.97 should make the " plant" calculational method acceptable. Nevertheless, the accuracy statements of DS-E18.1.10 which tie the flow element accuracy to a systems requirement that "the safety limit is not exceeded by any operational transient or design basis event for.which the instrument loop is required to function" were applied to these PAM flow signals.

Review Program Analyses of the safety systems and numerical development of safety limits followed by an assessment of total instrumentation loop accuracy would be necessary to determine if the flow element sizing Q)

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calculational methods are sufficient to support TVA design criteria. Such a design verification program goes well beyond the scope of the ECTG charter. However, without such a review the EC validity can not be directly or conclusively resolved. The evaluation team was informed of a loop accuracy verification program presently in progress at TVA that was already addressing this work. To avoid duplication of effort, the evaluation team conducted the following approach.

1. All PAM variables using orifice plates to generate their signals were identified. The auxiliary feedwater flow signal from FE 3-142 would be included in this list.

2. The actual Meriam Co. " plant" sizing calculations for these flow elements were verified, and the key parameters selected to establish uncompensated flow at the full scale differential pressure specified.

3. Bechtel entered the key parameters used by Meriam into computer programs which employ the " precise" calculational method to establish compensated flow at the same differential.

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(TVA EMPLOYEE CONCERNS REPORT NUMBER:-'229.l'(B) i'

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REVISION NUMBER: .3-

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[- ' 4. . .The flow differences between1the verified "Meriam/ Plant" Jand '

"Bechtel/ Precise"' calculations were then used to assess-the significance'to system operation. ,

5. :Bechtel- also reviewed TVA : loop accuracy calculations for ;

.FE-3-142, the only control variable using an orifice plate, to' determine the significance of flow element sizing accuracy differencesLin relation to other accuracies in the calculation'.

Results I,

SQN calculation SQN-SQS4-0068, Table 7 (App. A, 5.t) identified the 4

following flow indications as those intended for SQN compliance with Regulatory Guide 1.97. Review of.the systems -flow diagrams .

j. ' identified the flow-element tag numbers. 'These wereLthen compared with the Meriam contract and only the variables _ marked with an ~

asterisk .(*).have.their signal generated by an orifice plate.-

Variable- Flow-Element

/9;g,-

', . ib); 'RHR Pump Flow- FE-74-12 & FE-74-24 o , _ -

SI Pump. Flow FE-63-20 & FE-63-151 '

Boron Injection. Flow (CCP through BIT) . FE-63-170 I' Main Feedwater Flow FE-3-70 & FE-3-84

• Auxiliary Feedwater Flow FE-3-142 Containment Spray Flow- FE-72-13 & FE-72-34

' CVCS Charging Pump Flow - .FE-62-93

• CCS Flow to ESF and Other Equipment FE-70-818

• ERCW Header Flow FE-67-61 & FE-67-62 p

The calculations produced the following results for those flow signals asterisked above.

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i . TVA EMPLOYEE CONCERNS REPORT NUMBER: 229.1 (B)-

t SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 13 0F 30 Flow Diff. Pipe Beta Bore Plant " Precise" Percent Element Pres. I.D. Ratio Diam. Calc. Calc. Diff.

(WC) (inches) (inches) (GPM) (GPM).

FE-3-142 300 5.5 01_ 0.691305 3.8029 1,000 973 2.68%

FE-67-61 200 29.250 0.653670 19.1198 20,000 19,502 2.49%

FE-67-62 FE-70-818 100 3.068 0.719836 2.2085 200 195 2.58%

The detailed calculational results supporting the above are attached as-Appendices B, C, and D. The programs used have been verified, and the source program is on file. Complete information regarding these calculations is found in Appendix A, 5.p.

It was noticed in the calculations for FE-67 61 and 62 that the Reynolds Number boundary conditions established for use of the

" Precise" calculations were not adhered to by Meriam.- Referring to Appendix C one can see that the Reynolds Number of 2,691,312 is well beyond the limit (approximately 1,000,000) where Reynolds

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Number corrections are meaningful.

With the above data the evaluation reviewed TVA Demonstrated Accuracy Calculation for 1,2 FT-3-142 ( App. A, 5.q). _ The flow element section of this calculation has two accuracy factors listed, '! Repeatability Error" and " Process Error." Their sources were not identified in the calculation. In telephone conferences j with TVA personnel (App. A, 7.f), it was established that neither factor accounted for error in establishing Beta ratio. The

" Repeatability Error" was intended to accommodate longterm changes l

in the element itself (wear, sludge buildup, etc.). The " Process l

Error" was to accommodate process induced changes in fluid l temperature, pressure, etc., over the operating range of the auxiliary feedwater system.

l The Repeatability Error was based upon empirical data provided by different manufacturers. No documentation presently exists to support this factor which is currently estimated as "+ 2% of L range." The process error is derived from known changes in the l auxiliary feedwater system and is established as "+ 1% of reading." The only point of intersection between the " range" and the " reading" errors is presumably at full scale. This would correlate to the flow element sizing errors at the full differential outlined above. However, since the TVA instrument loop accuracy calculations for FT-3-142 did not accommodate flow element sizing error, they should be revised to include an appropriate factor to accomodate flow element sizing error.

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• TVA EMPLOYEE' CONCERNS REPORT NUMBER: 229.1 (B)-

4 SPECIAL PROGRAM REVISION NUMBER: 3

', PAGE 14 0F 30 In the case of FT-3-142, the inaccuracy resulting from the two sizing methods will be between 20 and 30 gpm. On the bases of design and operating experience, the evaluation team does not believe that this error would produce pump runout or turbine overspeed trip as a result of excessive feedwater flow to a damaged steam generator. A numerically based systems analysis to support this judgment has not been performed and is beyond the scope of the ECTG program.

The purpose of FE-70-81B, FE-67-61, and FE-67-62 is to monitor system operation per Regulatory Guide 1.97 (App. A, 6.b). This is a qualitative purpose that would not be affected by the level of error (2% to 3%) involved. Detailed systems operational analyses would be necessary.to conclusively prove this judgment. In no case do the error margins involved violate any regulatory criteria or FSAR statements.

Findings:

a. Calculations performed by the evaluation team on flow elements that come under the required accuracy definition of

.O (Q= 1 ' TVA Design Standard DS-E18-1.10 established differences between 2 percent and 3 percent of full scale flow. This difference was judged by the evaluation team to be too small to be considered " false," as defined.

b. Whether the orifice plates in question are " properly sized" depends on their intended design purpose. Of the 123 plates installed at SQN-no misapplication based on improper sizing could be established. However, errors due to use of the

" Precise" vs. the " Plant" sizing methods were not considered in TVA accuracy calculations.

Conclusion:

The concern is factual to the extent potential errors due to using the " Plant" sizing method were not considered in the accuracy j calculations for flow parameters considered to be critical to system design purpose. Of the 123, orifice plate applications reviewed, only four were considered to have functions which were sufficiently quantitative to warrant consideration of " precise" accuracy sizing calculations. In the opinion of the evaluation team, the calculated error of 2 percent to 3 percent should be acceptable for the design purposes intended. A program for verifying loop accuracy calculations, presently in progress at TVA, has not considered errors due to flow element sizing. This should j

be done to adequately document the accuracy of these loops. A numerically based systems analysis would be necessary to

substantiate these judgments.

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+* TVA EMPLOYEE CONCERNS REPORT NUMBER:' 229.1.(B).

.'- SPECIAL PROGRAM

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'.. PAGE 15 0F 30 l'0. CORRECTIVE ACTION

'The TVA SQN Corrective Action Plan (CAP) TCAB-045 (App. A,: 5.ee) has been reviewed. :In summary, the. CAP commits to reviewing and revising the.SQNP . safety calculations'.for flow measurement developed

from Orifice plates, to accommodate potential errors introduced by sizing calculational methods. This review process constitutes an acceptable corrective action on this issue.

The TVA SQN' CAP was revised (App. A, 5.ff) so that the_ corrective

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action is not required for restart. The basis was a calculation review (App. A, 5 99) which determined that the present error is in the conservative direction and that the inaccuracies are insignificant. The calculations will be revised after restart.

This revised CAP is acceptable.

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• TVA EMPLOYEE CONCERNS- REPORT NUMBER: 229.1 (B)

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\ PAGE 16 0F 30 APPENDIX A

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a. NSRS Investigation Report No. I-85-525-WBN, covering the referenced concerns, (12/17/85).

b. TVA, SQN Generic Concern Task Force Investigation,

" Employee Concerns IN-85-293-001, PH-85-022-001, NS-85-004-001" (06/06/86)

c. .TVA memo from Cottle _to Whitt, Response to above NSRS Report I-85-525-WBN, (01/30/86)

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d.- TVA letter,- D. M. Verrelli (TVA), to H. G. Parris (NRC)',

" Reports 50-390/84-32 and 50-391/84-27" (06-11-84).

e. TVA Electrical ' Design Standard DS-E18.10, R0, " Instrument Setpoints and Limits," (11/21/83)

TVA contract 73C 38-83520-1 with Meriam Instrument Co.,

Ah f.

Oc DJ (10/20/72) w

g. TVA preliminary Electrical Design Standard DS-E-18.3.6,

" Documentation of Instrument Setpoints, Accuracies, and Limitations - Balance of Plant," (undated)

h. Modeling of Sequoyah Unit 2, TVA, Principal Investigators E. J. Bradley, T. L. Thiele (1983)

1. SQN Mechanical Instrument Tabulation, Drawing Series M478601 -XX.

j. Principles and Practices of Flow Meter Engineering, L. K. Spink, The Foxboro Company, Ninth Edition, r March 1978.

k. Process Measurement, Instrument Engineers' Handbook, Revised Edition

- Chapter 2.12 Orifice

- Chapter 2.23 Venturi Tubes, Flow Nozzles and Flow Tubes I

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TVA EMPLOYEE CONCERNS' REPORT NUMBER: 229.1 (B)

SPECIAL PROGRAM REVISION NUMBER: '3

._ PAGE 17 0F 30 APPENDIX A (Cont'd)

1. Fluid Meters, Their Theory and Application, edited by H. S.

Bean, The American Society of Mechanical Engineers, Sixth Edition, 1971.

- Part One, Theory and Mode of Operation, Chapter I-5, Differential Pressure Meters: Theory of Fluid Flow in Terms of Differential Pressures and Equations for Differential Pressure Meters

- Part Two, Application of Fluid Meters - Especially Differential Pressure Types. Chapter II-III, Primary Elements and Equations for Computing Flow Rates.

m. Performance Test Code PTC-6-1976, The American Society of Mechanical Engineers

n. Selecting the Right Flow Meter, Parts I and II, by D. H.

Lomas, Kent Instrument Ltd., Instrumentation Technology, May, June 1977.

C2 o. SQN FSAR Sections and related Flow Diagrams for the following systems.

9.2.1 Component Cooling System 9.2.2 Essential Raw Cooling Water 9.2.3 Demineralized Water Makeup System 9.2.7 Raw Cooling Water System 10.3 Marin Steam Supply System 10.4.7.1 Condensate-Marin Feedwater System 10.4.7.2 Auxiliary Feedwater System 10.4.9 Heater Drains and Vents

p. Bechtel Memo from J. W. Hefler, to D. L. Damon, "SQN Generic Employee Concern-Incorrectly Sized Orifice Plates" (12/02/86)

q. SQN TVA Demonstrated Accuracy Calculation 1,2-FT-3-142 Instrument Loop

r. Meriam Instrument Co., Primary Element Calculation Report for Orifice Plates, Contract 73C38-83520-1, Drawings A-32500-1 through A-32500-130 03780-2 (03/31/87)

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. PAGE 18 0F 30 APPENDIX A (Cont'd)'

s. Nuclear Power Experience (Oct. 86) Vol. PWR-2, XVI.

Operational Problems, C. Misc, p. 922. Problem 3012. " Range and Accuracy Requirements Not Met on Pump Pressure and Flow Instrumentation," (Sequoyah 1 and 2 July 1986 - cold shutdown)

t. TVA Calculation SQN-SQS4-0068, " Final Type D Variable List for SQN"

u. SQN TVA Drawing Series 47W427:

-1 Mechanical Auxiliary Feedwater Piping

v. SQN TVA Drawing Series 47W464:

-4 Mechanical Component Cooling System

-13 Mechanical Component Cooling System

w. SQN TVA Drawing Series 47W605:

-1 Flow Diagram, H.P. Heater Drains & Vents

-2 Flow Diagram, L.P. Heater Drains & Vents f%

P Jl x. SQN TVA Drawing Series 47W610:

U 1 Mechanical Control Diagram, Main Steam System 2 Mechanical Control Diagram, Main Steam System 3 Mechanical Control Diagram, Main Steam System 4 Mechanical Control Diagram, Main Steam System 1 Mechanical Control Diagram, Condensate System 2 Mechanical Control Diagram, Condensate System 3 Mechanical Control Diagram, Condensate System 4 Mechanical Control Diagram, Condensate System 5 Mechanical Control Diagram, Condensate System 1 Mechanical Control Diagram, Main & Auxiliary Feedwater Sys.

2 Mechanical Control Diagram, Main & Auxiliary Feedwater Sys.

3 Mechanical Control Diagram, Main & Auxiliary Feedwater Sys.

1 Mechanical Control Diagram, Heater Drains & Vents Systems 2 Mechanical Control Diagram, Heater Drains & Vents System 3 Mechanical Control Diagram, Heater Drains & Vents System t

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V SPECIAL PROGRAM

REVISION NUMBER: 3

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APPENDIX A (Cont'd)-

4 Mechanical Control Diagram, Heater Drains & Vents -

-System 5 Mechanical Control Diagram, Heater Drains & Vents System 1 Mechanical Control Diagram, Demineralized Water &

Cask Decontamination Syrtem c 1 Mechanical Control Diagram, Essential Raw Cooling Water System 2 Mechanical Control Diagram, Essential Raw Cooling Water System 3 Mechanical Control Diagram, Essential Raw Cooling Water-System 4 Mechanical' Control Diagram, Essential Raw Cooling -

Water System 5 Mechanical Control Diagram, Essential Raw Cooling; Water System-6 Mechanical Control Diagram, Essential Raw Cooling Water System jecgs . 7 Mechanical Control Diagram,- Essential Raw Cooling Water System

'Z #.)

1 Mechanical Control . Diagram, Component Cooling Water System 2 Mechanical Control Diagram, Component Cooling Water System 3 Mechanical Control Diagram, Component Cooling Water System

y. SQN TVA Drawing Series 47W611:

1 Mechanical Logic Diagram, Feedwater Pump Turbine Auxiliaries 2 Mechanical Logic Diagram, Feedwater System 3 Mechanical Logic Diagram, Auxiliary Feedwater System 4 Mechanical Logic Diagram, Auxiliary Feedwater System 5 Mechanical Logic Diagram, Auxiliary Feedwater Sys.

1 Mechanical Logic Diagram, Component Cooling System 4

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SPECIAL PROGRAM REVISION NUMBER: 3

'. PAGE'20 0F 30 APPENDIX A (Cont'd) 2 Mechanical Logic Diagram, Component Cooling System 3 Mechanical Logic Diagram, Component Cooling System-4 Mechanical Logic Diagram, Component Cooling System

z. SQN TVA Drawing Series 47W801:

-1 Flow Diagram - Main & Reheat Steam aa. SQN TVA Drawing Series 47W803:

-2 Flow Diagram, Auxiliary Feedwater

-3 Flow Diagram, Auxiliary Feedwater bb. SQN TVA Drawing Series 47W859:

-1 Flow Diagram, Component Cooling System

-2 Flow Diagram, Component Cooling System s-3 Flow Diagram, Component Cooling System

-4 Flow Diagram, Component Cooling System

-5 Flow Diagram, Component Cooling System fr7cg cc. TVA Design Criteria SQN-DC-V:

-4.1.1

~

Main Steam

' ALT} -4.2 Main Feedwater Makeup Water Treatment

-6.5.1 Plant Demineralized Water

-7.4 Essential Raw Cooling Water

-9.6.7 Raw Cooling Water

-13.9.8 Auxiliary Feed Water

-13.9.9 Component Cooling Water

-22.0 Liquid Radwaste Disposal dd. TVA Mechanical Design Guide DG:

-M2.1.1 Main & Reheat Steam - Nuclear

-M2.2.1 Main Feedwater System - Nuclear

-M2.3.1 Condensate System l -M2.5.1 Heater Drains & Vents - Nuclear

-M2.19.1 Main Feed Pump Turbine System - Nuclear

-M5.2.3 Orifices-sizing & Applications

-M6.3.2 Raw Cooling Water

-M6.3.3 General Design of Essential Raw Cooling Water Systems

-M6.3.4 Raw Cooling Water Systems for Nuclear Power Plants L

l ee. TVA SQN Corrective Action Plan TCAB-045, (12/30/86) ff. TVA SQN revised Corrective Action Plan TCAB-080, (03/31/87)

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SPECIAL PROGRAM REVISION NUMBER: 3

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PAGE 21'0F 30 APPENDIX A (Cont'd) gg. TVA memo from Wilson to Wallace, Sequoyah Nuclear Plant Units 1 and 2 - Engineering Report for CAQ Report SCR SQNEE386205, R0, [B25.870119 025], (01/19/87)

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA? .

a. NUREG-0737, " Clarification of TMI Action Plan Requirements,"

November,- 1980,Section II.F.1, " Additional Accident Monitoring ~ Instrumentation"

b. Regulatory Guide 1.97, " Instrumentation to Follow the Course of an Accident"

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER f ,- DISCUSSIONS RELATED TO ELEMENT.

'W a.- RFI #SQN-673 (10/29/86)

b. RFI #SQN-677 -(10/31/86)

c. RFI #50N-678 (11/01/86)

d. RFI #SQN-684 (11/03/86)

e. RFI-#SQN-740 (11/26/86)

f. Telephone Conference, D. L. Damon, Bechtel, with Marvin Belew, TVA, Error Factors in TVA Calculation FT-3-142, (12/01/86) i 4

A I

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~' SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 22 0F 30 APPENDIX B 0ERIVATION OF " PRECISE" FLOW M ETERNUMBEk' FE-3 -142 '

FLUID METERED WATER TYPE 0F TAPS FLANGE PLATE MATE, RIAL: TYPE 304.SS FA = 1.0008 300 INCHES RANGE [

VOLUME' RATE. 1000.00 GPM WEIGHT RATE 497245.60 LBS/HR

, DENSITY (STD): 1.00000 SG(W)

DENSITY (ACT)- . 99400 SG(W)

~ VISCOSITY.. .68000 CP EXPANSION FACTOR .000 1014.7 PSIA lb)${'

'45 PRESSURE TEMPERATURE 100.0- DEG F-BETA' .6913 PIPE DIl.M. 5.5010 INCHES PLATE BORE 3.8029 INCHES REYNOLDSi10."(PIPE) 839501.

" PRECISE FLOW" 973.18 GPM i

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.C APPENDIX C DERIVATION OF " PRECISE" FLOW METER NUMBER FE-67-61, FE-67-62 FLUID METERED WATER TYPE OF TAPS FLANGE TYPE'304 SS FA = 1.0004 PLATE MATERIAL 400 INCHES RANGE 20000.00 GPM VOLUME RATE WEIGHT RATE 9971924.00 _LBS/HR DENSITY (STO) 1.00000 SG(W)

DENSITY (ACT)- .99670 SG(W)_

VISCOSITY .80000: CP 170.7 PSIA PRESSURE TEMPERATURE 83.0 DEG F l<.?

M BETA .6537 29.2500 INCHES PIPE DIAM.

19.1198 INCHES PLATE BORE REYNOLOS NO. (PIPE) 2691312.

" PRECISE FLOW" 19501.63 GPM v

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SPECIAL PROGRAM REVISION NUMBER: 3 --

J PAGE 24 0F 30 c

APPENDIX D DERIVATION OF " PRECISE" FLOW METER NUMBER FE-70-81B FLUID METERED WATER TYPE OF TAPS FLANGE TYPE 304 SS FA = 1.0010 PLATE MATERIAL 100 INCHES RANGE 200.00 GPM VOLUME RATE 99155.96 LBS/HR

. WEIGHT RATE DENSITY (STO) 1.00000 SG(W)

DENSITY (ACT) .99107 SG(W)

VISCOSITY .68000 CP 134.7 PSIA PRESSURE 110.0 DEG F TEMPERATURE V

BETA

.7199 3.0680 INCHES PIPE DIAM.

2.2085 INCHES PLATE BORE REYN0LOSN0.(PIPE) 300162.

i 194.84 GPM

" PRECISE FLOW" i

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SPECIAL PROGRAM

• ~^-. ' REVISION NUMBER: 3 Y PAGE 25 0F 30 c

Appendix E ORIFICE PLATES System Application Element No.

Alarm FE-6-107 Heater Drains & Vents Alarm FE-6-205 Heater Drains & Vents FMater Drains & Vents Alarm FE-6-231 Alarm FE-6-233 Heater Orains & Vents Heater Drains & Vents Alarm FE-6-244 Alarm.

FE-6-246 Heater Orains & Vents Alarm FE-6-256 Heater Drains & Vents Alarm FE-6-258 Heater Drains & Vents Alarm FE-24-26 Raw Cooling Water Raw Cooling Water- Alarm FE-24-33 Alarm - FE-24-39 Raw Cooling Water Alarm FE-24-46 Heater Drains & Vents Raw Cooling Water Alarm FE-24-59 Alarm FE-24-64 Raw Cooling Water Essential Raw Cooling Water Alarm

- FE-67-61 Alarm FE-67-62 Essential Raw Cooling Water Essential Raw Cooling Water Alarm

- FE-67-69 Essential Raw Cooling Water Alarm FE-67-74 Alarm Essential Raw Cooling Water _

FE-67-122 Alarm FE-67-136 Essential Raw Cooling Water Essential Raw Cooling Water Alarm FE-67-159 Alarm FE-67-163 Essential Raw Cooling Water Essential Raw Cooling Water _ Alarm FE-67-165 Alarm FE-67-169 Essential Raw Cooling Water Essential Raw Cooling Water Alarm FE-67-171 i

I f

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SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 26 0F 30 Appendix E (Cont'd)

ORIFICE PLATES System Application Element No.

Essential Raw Cooling Water Alarm FE-67-173 Essential Raw Cooling Water Alarm FE-67-177 Essential Raw Cooling Water Alarm FE-67-183 Essential Raw Cooling Water Alarm FE-67-185 Essential Raw Cooling Water _ Alarm FE-67-187 Essential Raw Cooling Water Alarm FE-67-189 Alarm Essential Raw Cooling Water _

FE-67-191 Essential Raw Cooling Water Alarm FE-67-196 Alarm Essential Raw Cooling Water FE-67-198 Essential Raw Cooling Water Alarm -

FE-67-200 Alarm Essential Raw Cooling Water FE-67-202 Essential Raw Cooling Water Alarm FE-67-204 Essential Raw Cooling Water Alarm FE-67-207 Alarm Essential Raw Cooling Water FE-67-210 Alarm Essential Raw Cooling Water _

_' FE-67-214 Essential Raw Cooling Water Alarm FE-67-216 Alarm

- Essential Raw Cooling Water FE-67-218 Essential Raw Cooling Water Alarm FE-67-220 Alarm Essential Raw Cooling Water FE-67-222 Essential Raw Cooling Water Alarm FE-67-226 Alarm Essential Raw Cooling Water

- FE-67-231 Alarm Essential Raw Cooling Water FE-67-233 Alarm Essential Raw Cooling Water FE-67-235 Essential Raw Cooling Water Alarm FE-67-237 Alarm Essential Raw Cooling Water FE-67-239 Essential Raw Cooling Water Alarm FE-67-241 Essential Raw Cooling Water Alarm FE-67-245 Issential Raw Cooling Water Alarm FE-67-247 Essential Raw Cooling Water Alarm FE-67-249 Essential Raw Cooling Water Alarm FE-67-251 Essential Raw Cooling Water Alarm FE-67-255 Essential Raw Cooling Water Alarm FE-67-257 Essential Raw Cooling Water Alarm FE-67-259 Alarm Essential Raw Cooling Water FE-67-263 Essential Raw Cooling Water _ Alarm FE-67-265 Essential Raw Cooling Water Alarm FE-67-267 Essential Raw Cooling Water Alarm FE-67-269 Essential Raw Cooling Water Alarm FE-67-332

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. , TVA EMPLOYEE CONCERNS REPORT NUMBER: 229.1 (B)

1. SPECIAL PROGRAM

REVISION NUMBER: 3 PAGE 27 0F 30 Appendix E (Cont'd)

ORIFICE PLATES Element No. System Application FE-67-333 Essential Raw Cooling Water Alarm FE-67-334 Essential Raw Cooling Water Alarm FE-67-335 Essential Raw Cooling Water Alarm FE-67-337 Essential Raw Cooling Water Alarm FE-67-339 Essential Raw Cooling Water Alarm FE-67-343 Essential Raw Cooling Water Alarm FE-67-345 Essential Raw Cooling Water Alarm FE-67-347 Essential Raw Cooling Water Alarm FE-67-349 Essential Raw Cooling Water Alarm '

FE-67-351 Essential Raw Cooling Water Alarm FE-67-353 Essential Raw Cooling Water Alarm FE-67-355 Essential Raw Cooling Water Alarm FE-67-357 Essential Raw Cooling Water Alarm FE-70-21 Component Cooling System Alarm Indication / Alarm FE-70-81A Component Cooling System

( FE-70-818 Component Cooling System Alarm FE-70-84 Component Cooling System Alarm FE-70-95 Component Cooling System Alarm FE-70-96 Component Cooling System Alarm FE-70-98 Component Cooling System Alarm FE-70-105 Component Cooling System Alarm FE-70-106 Component Cooling System Alarm FE-70-108 Component Cooling System Alarm FE-70-ll5 Component Cooling System Alarm FE-70-ll6 Component Cooling System Alarm FE-70-119 Component Cooling System Alarm FE-70-124 Component Cooling System Alarm FE-70-125 Component Cooling System Alarm FE-70-128 Component Cooling System Alarm FE-70-142 Component Cooling System Alarm FE-70-145 Component Cooling System Alarm FE-70-146 Component Cooling System Alarm FE-70-147 Component Cooling System Alarm FE-70-148 Component Cooling System Alarm FE-70-149 Component Cooling System Alarm FE-70-150 Component Cooling System Alarm FE-70-151 Component Cooling System Alarm i

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• • • - )~ TVA-EW LOYEE CONCERNS REPORT NUMBER: 229.1 (B)

' SPECIAL PROGRAM

' A_ REVISION NUMBER: 3 PAGE 28 0F 30

(.

Appendix E (Cont'd)

ORIFICE PLATES Element1 No. System Application FE-70-152 Component Cooling System Alarm FE-70-155 Component Cooling System Alarm Component Cooling System Alarm FE-70-158 Component Cooling System Alarm FE-70-159 FE-70-164 Component Cooling System Alarm Component Cooling System Alarm FE-70-165 Component Cooling System Alarm FE-70-170 FE-1-152 Main Steam Indication FE-1-156 Main Steam Indication FE-1 -160 Main Steam- Indicatioii' FE-1 -164 Main Steam Indication Condensate Alarm FE-2-200 Condensate Alarm FE-2-201 FE-3-142 Main and Aux Feedwater Indication / Control Main and Aux Feedwater Indication y FE-3-147 FE-3-155 Main and Aux Feedwater Indication ~

FE-3-163 Main and Aux Feedwater Indication FE-3-170 Main and Aux Feedwater Indication Raw Cooling Water Alarm FE-24-53A

. Raw Cooling Water Alarm FE-24-538 FE-59-20 Demin Water & Cask Decon Breakdown Orifice FE-67-211 Essential Raw Cooling Water Restriction FE-67-253 Essential Raw Cooling Water Indication j

FE-67-277 Essential Raw Cooling Water Indication FE-67-280 Essential Raw Cooling Water Indication FE-70-81B Component Cooling System Indication / Alarm FE-70-110 Component Cooling System FE-70-132 Component Cooling System Restriction FE-70-176 Component Cooling System Indication / Alarm FE-70-181 Component Cooling System Indication / Alarm FE-70-184 Component Cooling System Indication / Alarm FE-70-190 Component Cooling System Indication / Alarm FE-70-199 Component Cooling System Indication FE-70-200 Component Cooling System Indication l

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r- SPECIAL PROGRAM I'

4 REVISION NUMBER: 3 7- PAGE 29 0F 30

'\d Appendix E (Cont'd)

ORIFICE PLATES Element No. System Application FE-70-201 Component Cooling System Indication FE-70-202 Component Cooling System Restriction FE-70-204 Component Cooling System

• FE-77-230 Waste Disposal System Indication / Control FE-77-249 Waste Disposal System Indication / Control Note: Asterisk (*) in Application Column denotes instrument purchased according to Contract 73C38-83520-1, but not shown on system drawings ~

or listed in Design Criteria.

'(1 i5 03780-2(03/31/87)

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.". TVA' EMPLOYEE CONCERNS REPORT NUMBER: -229.1 (B) e SPECIAL PROGRAM

-y . (. , REVISION' NUMBER: 3 PAGE 30 0F 30 CATD LIST The following CATD identifies and provides corrective action for the findings included in this report:

229.01 SQN 01 (12/23/86) l 0

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• PAGE - 61 TENNESSEE VALLEY AL:~.i10RITY RUN TIME - 13:58 I9 REFEREllCE - ECPS120J-ECPS121C OFFICE OF NUCLEAF. ForiER RUN DATE - 03/19/87 '

FREQUENCY - REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

Ot4P - 1555 - RHM EMPLOYEE22901 SUSCATEGORY CONCERN INFORMATION BY CATEGORY /SUBCATEGORYQUESTI0HABL CATEGORY: Eri DES PROCESS & OUTPUT S

H I REPORT APPL CONCERN R PLT 2 SAF RELATED HISTORICAL CONCERtl DESCRIPTI0ft SUB REPORT ORIGIN .--- _.

CAT CAT D LOC BF BL SQ HB .- _

CONCERN NUMBER QTC ORIFICE PLATES INSTALLED IN MANY PLANT SYSTEMS, B0 1N N Y Y I-85-525-HBN TH UNITS 1 AtlD 2 (HATTS BAR) HAVE INCORRECT HOLE NS 004-00101 EN 22901 N HBN THIS S

! 2 flA NA SS SS IZE HHICH HILL RESULT IN FALSE FLOH READING.

L T50124 SAME C0ilDITION MAY EXIST AT SEQUOYAH. 110 FURTHER l

INFORMATION AVAILABLE. NO FOLLOH UP REQUIRED.

I-85-525-HBN QTC ORIFICE PLATES RECEIVED UNDER CONTRACT 883520-1 TO PH 022-00101 EN 22901 N HBN IN NY Y MERIAf1 INSTRUMENT CD. ARE IN ERROR BECAUSE THE B0 {

2 NA NA SS SS RE SIZES HERE NOT CALCULATED USING A FLOH COEFFICI j l T50050 ENT BASED ON REYNOLDS NUMBER. CREFER TO L.K. SPIN i K, 9TH EDITION, FOXBORE CO.) IE: MERIAM INSTRUMEN b T CO USED THE PLANT EQUATION VS PRECISE EQUATION

' HHEN CALCULATION THE ORIFICE PLATES BORE SIZES ON N

. CONTRACT 183520'1. THESE ORIFICE PLATES HAVES BEEN

" i INSTALLED IN MANY SYSTEMS IN BOTH UNITS 1 & 2.

UPPORTING DOCUMENTATION IS IN 2 CONCERNS FOR CATEGORY EN SUBCATEGORY 22901 4

x a

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==

U 45 ==

s

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. Attachment A

,[ # (3

• Pago 1 of 1

< - .* Revision 2 - A e

ECSP CORRECTIVE Action Tracting Document (CAID)

INITIATION

1. Immediate Corrective Action Required: O Tes No

2. Stop Wort Reconenended O Tes

3. CATD No. '2.'2 CI 0 L (81604-1 4  % No DATE INITIATION d-H -%

5. RESPONSIBLE ORGANITATION: D IE.' *F S

6. PROBLEM DESCRIPTION: O QR O NQR C. rt tT*s t. A L. f:Lovy E LS A4 EAli"' Loop Ace _vrt4c.g c.4 Lc t> L A.ra n d5 56.10 v L D 8E f2 E.V i E vv (Et D ArtD R E.V s E D /QS NEGESTAIE/

TO PrC ( OMc DAT'E. }>o TE- M TI /4 L ERt.of 5 /Nrto pric E D BV S t Z.t. N C, CALG. U LA T f ord A L- /Vt ET H ODS n a _ O ATTACHMENTS

7. PREPARED BY: NAME k)MW DATE: / #-' //d C

8. CONCURRENCE:hCEG-H h it. N W . DATE: # 2-is-s L

9. APPROVAL: ECTG PROGRAM MGlH 71##hM ene DATE: tr//S/#

CORRECTIVE ACTION

10. PROPOSED CORRECTIVE ACTION PLAN:

,5EE & OAP -hfAW5 naflEn by NL*nto /j'4Nt it na G27 8& /lZ// e/2 O ATTACHMENTS

11. PROPOSED BY: DIRECTg/MGR: /// h //., DATE: /.2-N ,/l

12. CONCURRENCE: CEG-H: D W r2. A 65%.Ak-'

DATE: 1-t7'P7 i SRP: DATE:

ECTG PROGRAM MGR: DATE:

g VERIFICATION AND CLOSEOUT '

13. Approved corrective actions have been verified as satisf actorily implemented. '

SIGNATURE TITLE DATE

-- - .e xx m v. . ny - rua3. , a.. raa r ,; . .y . ;,