IR 05000327/1986008

Insp Repts 50-327/86-08 & 50-328/86-08 on 860121-24.No Violation or Deviation Noted.Major Areas Inspected: Evaluation of Criteria & Procedures Used by TVA to Screen Employee Concerns Re Applicability of Safety Significance

ML20214D341
Person / Time
Site:	Sequoyah
Issue date:	02/19/1986
From:	Barker J, Holmesray P, Lloyd R, Singh B, Verrelli D, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214D337	List: IR 05000327/1986008 ML20214D334
References
50-327-86-08, 50-327-86-8, 50-328-86-08, 50-328-86-8, NUDOCS 8603050123
Download: ML20214D341 (18)

Text

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me ticg UNITED STATES

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Do NUCLEAR REGULATORY COMMISSION

,[ ", REGION 11 g j 101 M ARIETTA STRE ET, i

• I g ATLANTA. GEORGI A 3o323

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Report Nos.: 50-327/86-08 and 50-328/86-08 l t

Licensee: Tennessee Valley Authority .

6N38 A Lookout Place i 1101 Market Street Chattanooga, TN 37402-2801 ,

Docket No and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah I and 2 Inspection Conducted: Janesry 21-24, 1986 Inspectors: I de.-

S. P. Weise, Chief, Reactor Projects Section 1A Date Signed

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fpTli L7 M, lu l IE Date Sig~ned

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J. Barker, 5 Ada L  % hc R. Lloyd, IE /

Date Signed v /1 !N B. K. Singh, NR / Date Signed

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P. Holm Ray, Region 11 '

Date Signed l Approved by: ' UY7 M '

- - - f6 D.M./Ver 'lli, Branch Chief Date Signed Division f Reactor Projects SUMMARY .

i Scope: This special, announced inspection entailed 160 inspector-hours at the Sequoyah site,at the Watts Bar site, and at the Corporate Offices in Knoxville to conduct a programmatic review of the TVA employee concerns program facets appli-cable either specifically or generically to .the Sequoyah site. Areas inspected

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included evaluation of criteria and procedures used by TVA to screen employee concerns for applicability to Sequoyah and for safety significance, review of program implementation, review of TVA oversight of the Sequoyah employee concern

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resolu-tion effort, and verification of employee concern program training and safety notice Results: Of the areas inspected, no violations or deviations were identifie The inspectors had observations relative to the procedures and criteria used to categorize and prioritize employee concerns and the consistency of program implementatio e60220 PDR G ADOCK 05000327 PDR l _ _ - . - - - _ . , , - _ _ , , - . , . . _ . _ , . , . - _ , , - _ , _ _ - - , . , _ . - , _ _ , _ . . _ , , _ , . _ , . . _ - , . , _ .

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1. Entrance / Exit Interviews Entrance interviews with TVA management were held at the Nuclear Safety Review Staff (NSRS) offices in Knoxville on January 21, 1986. Exit inter-views were held with NSRS on January 22, 1985, and with TVA management on January 24, 1985. Attachment 1 lists those individuals who attended the exit. interview on January 24. This exit interview summarized the inspector observations delineated in paragraph 8 from the inspections at each of the

three locations. These observations are provided in more detail in the

following paragraphs. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspec-tion. No written material was provided to the licensee during this inspec-tion.

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2. Inspection Scope i l This inspection was conducted to assess the status of TVA's program to

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J I identify and resolve employee concerns having impact on the safe operation i

of the Sequoyah Nuclear Plant. These concerns have been generated mainly

! through the activities of the Employee Response Team (ERT) program at TVA's ,

Watts Bar Nuclear Plant.

i The program is being conducted by Quality Technology Company (QTC) under ,

, contract to the licensee's NSRS. (The ERT Program has been previously l

! inspected as documented in Inspection Reports 50-390/85-49 and i 50-390/85-57.) Additionally, a smaller number of employee concerns have j i been generated through the interaction of plant employees with Sequoyah line l

managers and supervisor i Using TVA's 50.54(f) submittal dated November 20, 1985, concerning the Employee Concern Program, and TVA's December 27, 1985 response to the NRC

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clarification request dated December 6,1985, the inspection team conducted j document reviews and interviews of TVA personnel at the NSRS offices in i Knoxville, TN, at the Watts Bar Nuclear Plant, and at the Sequoyah Nuclear Plant. The inspection involved the following:

, An evaluation of the criteria and procedures used by Watts Bar i personnel and NSRS personnel to screen ERT generic items for applic-i ability to Sequoyah and a review of implementation adequacy. This

included a review of 74 (about 7'4) concerns that had been screened out j as not generic to Sequoyah and a review of NSRS screening of prior to

startup (safety significant) concern An evaluation of the criteria and procedures used by NSRS to screen I

safety-related employee concerns from ERT that were specific to

. Sequoya This included a review of 66 out of 74 specific concerns

that were determined to be not safety-related, and a 100's review of the

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subject descriptions of the 23 Sequoyah specffic issues for which j K-Forms had not been received from the contracto i

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3 An evaluation of the criteria and procedures used by Seouoyah site personnel to determine the significance of Sequoyah specific and Sequoyah site generated employee concerns, including implementatio A review of TVA's oversight of the Sequoyah employee concern resolution effort and any internal quality assurance review A review of posted signs, safety notices, and training lesson plans associated with educating plant personnel on the employee concern progra An evaluation of the 56 generic issues determined by Sequoyah personnel to be not safety-relate . Documents Reviewed The following TVA submittals, procedures, and internal memoranda were reviewed during this inspection: Part E, Sequoyah Employee Concern Program of TVA's submittal dated November 20, 198 TVA submittal dated December 27, 1985, supplementing submittal abov TVA memorandum 506 850709 800 dated July 12, 1985, concerning Sequoyah Employee Concern TVA memorandum LOO 851210 800 dated December 10, 1985, Procedure for Review of Employee Concern General Employee Training Module on expression of safety views by employee NSRS Procedure 0307 Employee Response Team Program, Rev. 3, November 6, 198 NSRS Procedure 0308, Employee Response Team Program Administration, Rev. 2, September 16, 198 NSRS Procedure 0310, Assessing Potential Impact of Unvalidated Employee

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- Concerns on the Watts Bar Nuclear Plant for the Purpose of Establishing Priority for Investigations, Rev.1, October 21, 198 Informal NSRS Checklist - Minimum Nuclear Safety Review Criteria Questions to be Answered In Determining If a Safety Significant Question or Safety Hazard Exist Informal NSRS Checklist - Minimum Generic Evaluation Criteria to be Answered to an Expressed Employee Concern.

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i i Sequoyah Procedure, SQA-166, Program for Informing Employees How to j Report Their Safety Concerns, Rev. 4, January 7, 198 . Sequoyah Procedure, SQA-119, Unreviewed Safety Question Determination,

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Rev. 5, September 25, 198 . TVA Review of Employee Concerns For Generic Applicability ,

The purpose of this portion of the inspection was to determine the adecuacy of the licensee's review of employee concerns for generic applicability to 3 the Sequoyah Nuclear Plan The inspection was performed at three loca-j tions:

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Knexville, Tennessee to determine the adequacy of the Nuclear Safety

, Review Staff's (NSRS) review,

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Watts Bar Nuclear Station to review adequacy of the review of concerns

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originated at the Watts Bar Station, and

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Sequoyah Nuclear Station to review adequacy of the station's processing

! of concerns determined to be generic to Sequoyah af ter review at another TVA facilit l

] Generally, the employee concerns are reviewed for generic applicability at --

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three levels: the "K-Form" level, the investigation completion level, and

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the plant response level (corrective action determination). The licensee

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reviews employee concerns for generic applicability to all TVA nuclear j stations, but this inspection's activities were specifically directed toward Sequoyah concern ; The inspectors reviewed the licensee's program for review of employee i i

concerns at the NSRS offices in Knoxville, Tennesse NSRS receives employee concerns from the Employee Concern Program through QTC as i

"K-Forms" af ter a preliminary safety-related determination is made; ,

NSRS reviews safety related concerns for generic applicability, t although TVA's program does not specifically assign NSRS as a primary (

reviewer. The NSRS performs an independent generic review as a quality  ;

r check on other TVA reviews. The inspectors had the following observa-

tions relative to the NSRS reviews.

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(1) Although appearing to be technically adequate, the procedure used

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by NSRS to determine generic applicability is handwritten and not 1 approved by TVA management. The licensee committed to formalizing

] the procedur (2) Based on a review of the resumes of NSRS personnel conducting the review, those personnel assigned review responsibility appeared to be qualified to perform the review .

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l The inspectors reviewed the licensee's program for review of generic applicability at the Watts Bar Nuclear Station. As a result of the large number of concerns reported by QTC to NSRS, Watts Bar implemented i a Concern Response Task Force (CRTF) to perform preliminary reviews and l act as a " clearing house." One of the reviews performed was to be for l

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generic applicability. Watts Bar reviewers had experience in welding, mechanical engineering, electrical engineering, regulatory engineering, and system design and operation, and included a qualified Shift Technical Advisor (STA). The procedures and guidance to be used by CRTF for its reviews were transmitted to the respective nuclear plant '

site directors via a memorandum from TVA management on December 10, 1985. This memorandum contained specific program documentation forms including Forms D, I, and N for generic applicability review at the ,

K-form, investigation report, and corrective action stages, respec- )

l tively.

l The inspectors reviewed the licensee's procedure for generic applic- I ability review. The inspectors also reviewed the following sample of l 74 concerns (about 7%) of those employee concerns determined as not generic at the "K-Form" stage: l IN-85-300-002 IN-85-915-X04 IN-85-196-004 IN-85-200-X04 IN-85-919-001 IN-85-197-001 ,

IN-85-301-003 IN-85-923-002 IN-85-197-002 '

IN-85-302-001 IN-85-926-001 IN-85-198-001 IN-85-303-001 IN-85-927-X01 IN-85-400-001

, IN-85-304-001 IN-85-930-001 IN-85-400-002 l IN-85-305-001 IN-85-932-001 IN-85-404-001 l

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IN-85-307-003 IN-85-933-001 IN-85-405-001 IN-85-310-004 EX-85-012-001 IN-85-406-002 l

i IN-85-310-005 EX-85-021-001 IN-85-406-003 l IN-85-310-006 EX-85-021-002 IN-85-407-001 i IN-85-311-008 EX-85-023-001 IN-85-409-001 IN-85-312-001 EX-85-026-001 EX-85-008-001 IN-85-313-001 EX-85-027-001 IN-85-018-004 l

IN-85-313-002 EX-85-034-001 IN-85-241-001 l IN-85-314-001 IN-85-130-001 IN-85-279-005 l IN-85-316-006 IN-85-186-004 IN-85-485-X01 IN-85-316-007 IN-85-186-005 IN-85-688-004 IN-85-900-X01 IN-85-186-010 IN-86-158-005 IN-85-911-001 IN-85-189-001 IN-85-115-001

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IN-85-913-001 IN-85-185-002 I N-85-049-002 ---

IN-85-913-003 IN-85-192-001 IN-85-088-002 IN-85-915-001 IN-85-194-004 IN-85-016-001 IN-85-915-003 IN-85-196-003 IN-85-814-001 IN-35-824-001 IN-85-815-001 The inspectors had the following observations relative to their review:

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6 Although the personnel assigned review responsibility at Watts Bar appeared to be qualified to perform the reviews, there was little or no training on the implementation of the procedure, resulting in inconsistent use of the Form D. The licensee committed to enhancing the procedures to clarify the use of Form D, training personnel in the use of the procedures, and reexamining those employee concerns previously screened as not generic by Watts Ba The inspectors expect that such training and clarification would apply to other forms and procedures, as appropriat . The criteria used to arrive at generic applicability relied upon the " reasonable man" concept and could easily result in many differing opinions. This was mitigated somewhat by the additional reviews conducted at the investigation report and plant response stages, where better information should be availabl The licensee committed to better define the criteria for generic applicabilit . The licensee would be able to perform a more meaningful review if the concerns were concentrated in issue areas based on discipline interface d. The inspectors reviewed the licensee's program for handling generically applicable concerns at the Sequoyah Nuclear Plant (SQN). The SQN implemented a Generic Issue Task Force (GITF) composed of senior, generally STA qualified personnel, to review those concerns generically applicable to Sequoyah in order to identify issues which require investigation and corrective action identification prior to the restart of Sequoyah. The inspectors reviewed licensee procedures, SQA 166,

" Program for Informing Employees How to Report Their Safety Concerns" and SQA 119, "Unreviewed Safety Question Determination," interviewed licensee personnel, and reviewed documentation to determine the adequacy of the licensee's program. The flow chart of the site generic process is provided as Attachment 2.

l The purpose of the GITF was to review employee concerns generic to SQN at the "K-Form" stage and prioritize followup based on evaluations using SQA 166 and SQA 119. This review should determine which concerns are safety significant and require corrective action recommendation approval of management prior to Sequoyah restar The GITF took the concerns and identified the following priorities:

Priority 1 - Investigate and resolve prior to startu *

Priority 2 - Investigate, but not prior to startu *

Priority 3 - No investigation necessar The inspectors reviewed the following Priority 3 concerns (total of 24)

which were determined not safety significant and not requiring investi-gation:

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XX-85-062-002 IN-85-480-004 WI-85-042-001 IN-85-841-001 EX-85-086-001 IN-85-869-001 IN-85-935-001 IN-85-029-002

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IN-85-596-004 IN-85-171-001 IN-86-034-001 IN-86-305-002 PI-85-030-001 IN-86-262-003 IN-85-642-001 XX-85-080-001 IN-85-733-001 IN-85-046-001 IN-85-144-001 IN-85-719-002 IN-86-262-002 XX-85-094-009 IN-85-300-002 IN-85-436-004 l The inspectors had the following observations relative to their review (1) The licensee's screening process essentially equated the defini-tions of safety-reiated and aafety significant while meaning i safety significant (eg., required for startup). The licensee committed to enhancing their procedures in order to better define the terms safety-related and safety significant and to use the terms in the intended fashio (2) The licensee assigned to Priority 3 several employee concerns (e.g., welder certification update, overfilling cable trays) which i

the inspectors considered safety significant and required licensee resolution prior to startu The issues identified by the inspectors were being addressed under the SON site specific

, concerns review. The licensee committed to enhancing uniformity

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of their program implementation into a more auditable progra This comment proceeds from the licensee's failure to deal with all related issues in one technical area as a coordinated packag . Trending of Employee Co cerns

The purpose of this portion of the inspection was to determine the adequacy 1 of the licensee's program for trending employee concerns such that TVA '

management could make meaningful decisions based on the analyzed trend The inspectors reviewed the licensee's program in the NSRS offices in Knoxville, Tennesse The inspectors made the following observations: Trending was not being kept current in that the last graphs were

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produced during November 1985. The licensee, at the request of the inspectors, updated the trend graph through January 198 TVA management was not using the trending derived by NSRS to make l decisions relative to the direction of the employee concerns progra l The trending report received from QTC was not an effective tool in its I present cumulative for The licensee committed to implementing an effective trending program for employee concern .

8 TVA Review of Sequoyah Site Specific Concerns The purpose of this portion of the inspection was to determine the adequacy of the Nuclear Safety Review Staff (NSRS) and Regulatory Engineering Staff

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(RES) review of Sequoyah site specific employee concerns reported by QTC.

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This inspection was performed at two locations:

- Knoxville, Tennessee; to determine the adequacy of K-Form classifica-tion as to nuclear safety-related or non safety-related by NSR Sequoyah Nuclear Station; to detarmine the adequacy of K-Form classifi-cation as to nuclear safety-related or not nuclear safety-related by RE Employee Concern K-Form Review Process Those employee concerns identified as " site specific concerns" were those that originated from the QTC effort conducted primarily at the Watts Bar Nuclear site. These concerns were recorded by the QTC on

"K-Forms" and classified by the QTC as nuclear safety-related or not nuclear safety-related and were then forwarded to NSRS. NSRS personnel reviewed each incoming K-Form using NSRS procedures 0307, 0308, and

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0310 to determine whether the issue was nuclear safety-relate A determination as to safety significance of each concern was being performed using an informal checklist developed by the NSRS Sequoyah Section Head. This was done to prioritize the order in which investi-gations would be performe NSRS classified each concern as either potentially safety-related (PSR)

or non safety-related (N). K-Forms classified as N by NSRS were not 4 forwarded to Sequoyah. For those K-Forms sent to Sequoyah, site personnel processed them in accordance with SQA 166. SQA 166 required each PSR concern to be reevaluated for safety significance and generic applicability to other TVA site Attachment 3 provides a flow chart l of the site proces (1) NSRS Site Specific Concern Review I At the time of the inspection, 74 Sequoyah site specific employee concerns had been classified as N by NSR The inspection team reviewed 66 N classified K-Forms to determine if the K-Forms were properly classified. The inspection sample is listed below:

XX-85-004-001 XX-85-033-006 XX-85-071-001 XX-85-007-001 XX-85-033-008 XX-85-077-003 XX-85-007-003 XX-85-033-009 XX-85-084-003 XX-85-009-003 XX-85-035-001 XX-85-089-004 XX-85-012-001 XX-85-036-001 XX-85-092-001 XX-85-015-001 XX-85-042-001 XX-85-094-012 _ _

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XX-85-017-001 XX-85-043-001 XX-85-094-013 XX-85-017-002 XX-85-043-002 XX-85-098-001 XX-85-018-001 XX-85-043-003 XX-85-101-001

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XX-85-018-002 XX-85-043-X04 XX-85-101-005 XX-85-021-001 XX-85-048-001 XX-85-101-007 XX-85-021-002 XX-85-048-002 XX-85-105-001 XX-85-024-001 XX-85-048-003 XX-85-109-001 XX-85-026-001 XX-85-054-002 XX-85-114-001 XX-85-027-X05 XX-85-057-002 XX-85-114-002 XX-85-027-X08 XX-85-058-001 XX-85-115-001 XX-85-031-001 XX-85-059-001 XX-85-120-001 XX-85-032-001 XX-85-059-002 XX-85-120-004 XX-85-033-001 XX-85-064-001 XX-85-120-005 XX-85-033-003 XX-85-066-001 XX-85-123-001 XX-85-033-004 XX-85-067-002 XX-85-123-002 XX-85-033-005 XX-85-069-010 XX-85-127-001 Of the 66 K-Forms reviewed by the team, eight (listed below)

should have been classified as safety-related in the opinion of the inspection team. As a result of being classified as N by NSRS, these employee concerns were not forwarded to Sequoyah and consequently did not receive site revie Employee Concern Number Subject XX-85-007-001- Radiation Overexposure XX-85-015-001 Radiation Exposure During plant Operations XX-85-018-001 Safeguards Information Not Properly l Controlled XX-85-024-001 Exposure to Airborne Contamination

! XX-85-026-001 Employees Bypassing Radiation Monitors XX-85-031-001 Radioactive Material Not Properly ,

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i XX-85-043-001 Falsification of Qualification, Certification and Documentation of 3 Security Personnel XX-85-048-003 Radiation Exposure During X-Ray of Welds It was also noted that conce'rn XX-85-026-001 was classified as nuclear safety-related by the ERT, however, NSRS downgraded the concern to non-nuclear safety-related without proper notification on the K-For (2) RES Employee Concern Review RES personnel were interviewed at Sequoyah to determine how PSR K-Forms were being processed. Sequoyah Procedure SQA 166 was found to be the controlling document for employee concerns, and as l

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written, provides for yet another review of K-Forms and potential reclassificatio Sequoyah was using about five STA qualified individuals to conduct the reviews. RES downgraded many K-Forms to non nuclear safety-related because of a narrower definition of

" nuclear safety-related." RES indicated that the term " nuclear safety-related" applied only to those items / concerns that would direct.ly impact startup. This was inconsistent with NSRS, QTC and the inspection team's understanding of what should be classified as safety-related. The definition actually used by Sequoyah would be best defined as safety significan Inspection Results In general, the inspection team concluded that the screening process used by NSRS, ERT and RES to delineate nuclear safety-related/non-nuclear safety-related was not broad enough to encompass security, fire protection, emergency planning and radiological controls /ALARA issue Official NSRS office procedures 0307 0308 and 0310 were developed specifically for the Watts Bar (under construction) nuclear site employee concerns program, but were being used for processing employee concerns at operating sites within TVA. NSRS personnel had developed additional unofficial procedures which were being used in parallel with the Watts Bar procedures to determine the safety significance of site specific (Sequoyah) employee concerns. These unofficial checklists were of broader scope and judged to be more appropriate for operating facilities. The screening process used by RES was also noted to be too restrictive and did not adequately address issues / concerns that were safety-relate The Team concluded that NSRS, RES and ERT needed to integrate their approach to reviewing, classifying, investicating, and i

resolving employee concerns in order to achieve consistenc Estab-lishing key definitions, such as safety-related and safety significant, should be part of any improvement.

. Line Employee Concern Program at Sequoyah i

The inspection team reviewed onsite the current procedures, training, and status of implementation of the existing employee concern program within the j line organization. By memorandum dated July 12, 1985, the Sequoyah Site

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Director provided gcidance and a draft of procedure SQA-166 for use by TVA managers / supervisors .~or their review and implementation. In particular, i this memorandum required that each supervisor and employee receive a copy of a safety notice on how to voice a concern and directed that supervisor's document followup on written employee concern It also established a requirement for exit interviews with employees who terminate or transfe SQA-166, Revision 4, requires use of a supervisor record book for recording nuclear safety concerns brought to the supervisor. The concern must also be documented on Attachment B.1 of the procedure and be transmitted to the Regulatory Engineering Section (RES). This form documents the supervisor's

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assessment of potential safety significance. At the time of the inspection, site personnel were in the process of backfitting all previous site i generated concerns onto the B.1 Form. As of January, SQN employees had

! identified 29 concerns, of which eight were categorized as safety signifi-cant. TVA requires that significant safety improvements made as a result of j written employee concerns be documented and results provided for dissemina- 1

, tion to all employee Attachment 4 provides a flowchart of the site j proces l l

1 The inspectors identified that the B.1 Forms were being initiated by i supervisors (although the retrofit of concerns previous to SQA-166, '

l Revision 4 was not complete) and these forms went to RE At this point, I however, these forms were not being utilized, trended, or audited. RES only -

filed the form Based on this observation, the form served mainly to 6

) emphasize to the supervisor, the significance of handling the concern, but i did not serve as a tool for site management to evaluate for trends or corrective action effectivenes Site management should review this documentation program and make revisions to better formalize use and evaluation of the completed form.

l The inspectors reviewed the 14 B.1 Forms in the RES files. Eight were found '

! to have been identified by SQN as having potential safety significanc For l the small number of concerns available, SQN's classification _ genert:ly 1 appeared acceptable. Sufficient time was not available to interview

employees / supervisors to determine if the B.1 Form properly characterized the employee ec*<ern.

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! As noted earlier, in paragraph 6.b, the inspectors found that the licensee's definition of nuclear safety-related was not sufficiently broad to include t

] radiological controls /ALARA, security, fire protection, cnd emergency {

planning issues. Additionally, the licensee had no specific guidance for i

determining safety significance, although site personnel generally defined i safety significant concerns as those which involved license or Technical  ;

i Specification compliance publems or unreviewed safety questions.

I i The inspectors' review also identified that the site procedures for i

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site generated employee concerns did not require a generic review for J

applicability at other site Interviews with plant personnel confirmed i 1 that these concerns were not reviewed for generic impact. TVA should revise i j their program to incorporate a generic review.

j Summary of Observations i

i At the time of the inspection, the inspectors understood that NSRS was l providing an independent review of site classification of concerns and

! evaluation of proposed corrective actions. Both the site and NSRS developed l lists of concerns that each considered safety significant. These lists were

, Stegrated to yield a total list of issues to be investigated and resolved I

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prior to plant startup. Additionally, the inspectors understood that NSRS had an informal hold on' plant startup which both parties characteri:ed as a

" gentlemen's agreement." The team noted that the TVA reorganizations in progress during the inspection could affect NSRS's input to a startup

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decision. TVA management indicated that a submittal clarifying the

anticipated changes to the employee concerns program would be made to NRC in

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the futur The following observations are provided as a summary of the issues identi-fied in the preceding paragraphs: Observations at NSRS

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Screening process of K-Forms is for nuclear safety-related issue This is not sufficiently broad to include the regulatory areas of radiological controls /ALARA, security, fire protection, and emergency planning. TVA should rereview those K-Forms not sent to the site using broader criteri The formal procedures in use were written for Watts Bar issue Procedures were not established for handling of operating plants such as Sequoya The NSRS Section Head for Sequoyah had developed informal checklists to better screen issues for safety significance and generic applicability. While the criteria were more inclusive of disciplines of regulatory concern, TVA management should review and approve these checklist Trending was not current at the time of the inspection, and NSRS management did not appear to be regularly reviewing trending informatio Interface Problems Between Sites and NSRS

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NSRS viewed the term nuclear safety-related as encompassing hardware and program problems af fecting Technical Specification

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compliance or potentially allowing a 10 CFR Part 100 releas ,

Sequoyah site, through use of SQA 119, expanded this to include

! security, fire protection, and radioactive waste issue Issues screened out as non-safety-related by NSRS are not seen by Sequoyah site unless sent to the site by TVA's Office of Employee Relation Observations of Generic Review at Watts Bar

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Personnel conducting the review received little training on philosophy and use of generic review forms, which resulted -in inconsistent documentation of the revie TVA incicated that i

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generic review guidance would be clarified and a rereview of ,

K-Forms conducte ;

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- The reasonable man criteria of the December 10, 1985 Denise

! memorandum is sufficiently broad to allow knowledgeable indivi- !

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l duals to reach opposite conclusions. This is partially due to the

vagueness of many K-Form This problem is mitigated by the

generic reviews performed at the investigation report and plant

response stages. However, timeliness of those subsequent reviews i with respect to Sequoyah restart is of concern to the NR i l-t

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The generic review is done on individual K-Forms not on an overall I package collated by hardware or program. Examples of significant issues are welding, electrical design, and instrument tubing.

j 1 d. Observations at the Site I

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Site generated employee concerns do not receive a generic review, j and the B.1 Form is only used to document a concern and not to l track or audit resolutio !

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Site procedure SQA-166 does not define safety significance (i.e.,

i requiring resolution prior to startup), but relies on the

experience of the reviewers.

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A dichotomy existed on issues screened out of one concern review i l source (i.e., Sequoyah specific, generic, and site generated) and i i not of another. Welding issues, for example,-might be a restart i l item in the Sequoyah specific program, but be considered insigni- .

i ficant in the generic applicability program. TVA needs to resolve i

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concerns as they relate to specific hardware or programs as a l

group and not as individual issues. This requires integrating the l

output of the three programs into groups of related concern !

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Changes in the ECP anticipated by TVA to go into effect about l February 1, 1986, may make some of the inspection observations

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not applicabl At the time of the inspection, no Corporate Directives had been issued and site personnel were not sure of the final direction of the program.

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With the exception of radiological controls /ALARA, emergency

planning, fire protection, and security, the inspectors found that i TVA was properly categorizing safety-related concerns.

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TVA has not established one overall, consistent approach to j identifying and resolving those concerns which impact restart, b l

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No TVA Division of Quality Assurance reviews of the CCP had been conducted at the time of the inspection. Preparation for such an audit appeared to be in progress based on information received from TVA at the exit meetin The above observations and TVA's response to resolving those observations that require corrective action will be reviewed during future inspections, including TVA's supplemental submittal on employee concarns program changes implemented since this inspectio ,

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ATTACHMENT 1

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ATTENDANCE ROSTER EXIT MEETING ON JANUARY 24, 1986 ,

Name Position Oraanization Robert C. Birchell Mechanical Engineer TVA 3 Stephen P. Weise Section Chief NRC R. Lee Spessard Deputy Division Director NRC 1 i Joe Youngbloca Director NRC

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Lawrence Martin Office of Nuclear Operations TVA I

Glenn B. Kirk Compliance Supervisor TVA Robert C. Sauer NSRS Section Leader TVA Andrew J. Cassell Contractor to NRC FRC  !

W. R. Lagergren Task Team Leader-Generic Issues TVA ,

j B. K. Singh Project Manager NRC

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, Fisher Campbell Licensing En TVA  ;

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Jim Domer Chief, Nuclear Licensing TVA

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Everett Whitaker Sr. Licensing Eng TVA Wesley L. Byrd Engineering Sup TVA

, P. R. Wallace Plant Mg TVA L. M. Nobles Supt. (0&E) TVA M. R. Harding Eng. Group Sup TVA Fredrick C. Mashburn Regulatory Engineer TVA John H. Sullivan Supervisor, RES TVA

. Douglas C. Craven QA Staff Sup TVA

! T. Knight Asst. to Site Director TVA J. Blankenship Info. Officer TVA R. J. Griffin NSRS Site Rsp-SQN TVA

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K. M. Jenison Senior Resident NRC R. L. Lloyd IE Engineer NRC J. L. Barker Sr. Construction Engineer, IE NRC

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GENERIC EMPLOYEE CONCERN l l

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OTHER SITES  :

U u K FORMS INVESTIGATION GENERIC REPORTS FROM OTHER INCOMING E s!TEs 5, u u NUCLEAR

'*"'""C" PE REVIEW

@ PROGRAW 5 u

CATEGORIES and U U ISSUES

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METHOD FOR U msmc LONG TERM RESEARCH mcam @ ITEMS 5 SHORT TERM ISSUES E u

MRT >

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SCHEDUli and PE - preliminary evaluation ..

COMPIITE MRT - Management Review Team -

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INVESTIGATIONS u

CORRECTIVE ACTION @ occVMDHAh0N TAKEN g AVMLABLE ATTACILMENT 2 .

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SITE SPECIFIC EMPLOYEE CONCERN

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EMPLOYEE  :

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GENERIC NPSSC 4- PE -+ K FCRM LATER 5 0UTG0ING g t l

CATEGORY l

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NSRS  !

INVESTIGATES l REPORT 5 l t

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CORRECTIVE ACTION g RES t NER RESPONSE OUTG0ING g T0 h NSRS 5 t

FEEDBACK TO [

EMPLOYEEE b DOCUMENTATION AVAllABLE PE - preliminary evaluation NER - nuclear plant experience review ATTACHMENT 3 s-

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SITE ORIGINATED EY?LOYEE CONCERN

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EMPLOYEE 4 v

CONCERN EXPRESSED TO AND RECE!VED

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BY THE

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SUPERVISOR 5

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ROUTES TO RES '

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EMPLOYEE I SUPERVISOR 5 RESOLVES J L CONCERN g  ;

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REPORTS MD m us imm a"c= = 5 0 DOCUMENTATION AVAILABLE

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