IR 05000327/1986029

Insp Repts 50-327/86-29 & 50-328/86-29 on 860408-11.No Violations Identified.Major Areas Inspected:Status of TVA Employee Concerns Program Implemented at Plant,Including Review of Changes to Procedures & Processes

ML20197J303
Person / Time
Site:	Sequoyah
Issue date:	05/14/1986
From:	Joseph Holonich, Hooks K, Jenison K, Lloyd R, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20197J297	List: IR 05000327/1986029 ML20197J292
References
50-327-86-29, 50-328-86-29, NUDOCS 8605190418
Download: ML20197J303 (12)

Text

{{#Wiki_filter:- .- U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION II

Report Nos.: 50-327/86-29 and 50-328/86-29 Docket Nos: 50-327 and 50-328 License No. DPR-77 and DPR-79 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Facility Name: Sequoyah 1 and 2 Inspection conducted: April 8-11, 2986 Inspectors: <[ son d } Kenneth R. Hooks, IE, Team Leader, IE

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5l/4l% Date c- '! Y E-Joseph /J. Holonich, NRR ' ' ' Date f./)v w< L - /3 Kenneth M. Jenison, RII SRI

     .r/l4/Ft Date Approved by: -
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  -k/M -  V R. Lee Spessard, Deputy Director, DI/IE  Date Inspection Summary Scope: This special, announced inspection was conducted at the Sequoyah sit Areas inspected included status of the TVA Employee Concern Programs, as implemented at the Sequoyah site, including review of changes to procedures and processes resulting from the special inspection conducted January 21-24, 198 PDR ADOCK 05000327 g  PDR     Enclosure

, O Results: No violations were identified. The inspectors made findings relative to the content of procedures and implementation of the Employee Concern Program / e 1. Entrance / Exit Interviews The NRC team held an entrance interview with TVA management at the Sequoyah site on April 8,1986. The inspection findings were summarized during an exit interview at the Sequoyah site on April 11, 198 The attachment sists the TVA personnel who attended the exit intervie . Inspection Scope This inspection was conducted to assess the present status of the Employee Concern Program (ECP) as implemented at the Sequoyah Nuclear Plant, and to follow up on related items identified during the NRC inspection of January 21-24, 1986 (Inspection Report Nos. 50-327/86-08 and 50-328/86-08). The inspection was conducted in accordance with the requirements of Temporary Instruction 2515/74, as applicabl . Documents Reviewed The following TVA procedures, memoranda, reports, and files were reviewe Sequoyah Nuclear Plant Standard Practice SQA 166 "Sequoyah Employee Concern Program - Disposition of Concerns Generated Prior to February 1,1986," Rev. 6, March 24,198 Memorandum L12'860130 802 "New TVA Employee Concern Program," January 30, 1986, by S. A. White, Manager of Nuclear Powe Sequoyah Nuclear Plant Standard Practice SQA 178 "TVA Office of Nuclear Power - Employee Concern Program Line Organization Procedure," Rev. O, February 6, 198 Memorandum E. K. Sliger to M. W. Alexander et al. (ECP Site Representatives) " Common Definitions and Criteria for

" Safety-Related," " Safety-Significant," and Generic Applicability,"

March 5, 1986, Memorandum 504 '860205 801 "New TVA Employee Concern Program," February 5,198 Memorandum B25 '860208 001 "New TVA Employee Concern Program," February 8, 198 ECP Site Representative files, A sample of onsite ECP files (prior to February 1,1986). A sample of Generic Concern Task Force Reports to the Sequoyah Management Review Tea . Discussion and Findings There are presently four separate ECP-related activities ongoing at Sequoyah. They are:

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e-(1) The "new" ECP which began February 1,1986 (ECP Site Representatives, etc.),

(2) The ECP in effect prior to February 1,1986, parts of which are still in effect until the items are completed. This includes:
 (a) Responses / corrective actions to generic concerns identified through Watts Bar Special Program, (b) Responses / corrective actions to Sequoyah - specific concerns identified through the Watts Bar Special Program, and (c) Review of files of site originated employee concerns (onsite concerns) developed through the onsite ECP (employee / supervisor interface) prior to February 1,198 b. Prior ECP (1) The NRC inspection team reviewed SQA 166, which describes the ECP prior to February 1,1986, and states:
 " Concerns generated prior to February 1,1986 are identified through three processes. " Site generated" concerns are those concerns which result from employee / supervisor discussions or exit interviews. " Site specific" concerns are generated via the Watts Bar Employee Response Team (ERT) or the Nuclear Safety Review Staff (NSRS). The third process includes those concerns identified by any process (most are generated through the ERT process) which are evaluated by cognizant personnel at that site as potentially applicable to Sequoyah. These concerns are referred to as " Generic Concerns."

"This standard practice shall remain in effect until such l time as concerns identified prior to February 1,1986 are l dispositioned. This includes concerns which could ' potentially arise from the investigations of the original, pre-February 1,1986 concerns."

(2) Standard Practice SQA 166 "Sequoyah Employee Concern Program , Disposition of Concerns Generated Prior to February 1,1986" was recently revised to include definitions of key terms such as safety-related and safety-significant. Other improvements to SQA 166 included reviews by Regulatory Engineering Staff (RES) of onsite concerns including signature verification on the

 "Onsite Employee Concern Impact Evaluation" form, and instructions for the review of onsite concerns (site originated employee concerns) for generic applicability at other TVA sites, as documented by completion of the Attachment B.3 form. SQA 166 Wds changed in response to observations made in NRC inspection reports 50-327/86-08 and 50-328/86-0 __   . - _ _ - - .

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.(3) Of the 86 files generated by the onsite ECP prior to February 1, 1986, the following were reviewed by the NRC inspector DHT-86-001 CWL-85-001* JAM-86-001*

EAC-86-001 MAS-86-004* JAN-86-001* EAC-86-002 MAS-86-005* TAK-86-007* These files consisted of copies of hand written notes of Sequoyah managers / supervisors relating to concerns identified by their personnel. In some cases short statements of investigations, corrective action and notification of the concerned individuals were included. Some files contained copies of "B.1" and "B.3" forms (forms described in SQA-166).

(4) The Watts Bar Special Program identified 279 concerns (K-forms) as being generic and potentially applicable to Sequoyah. The Sequoyah Generic Concern Task Force identified 154 of these concerns as Priority 1 (either potentially safety-related or safety-significant, and requiring investigation and resolution prior to startup), and prepared reports resolving these concerns for the Sequoyah Management Review Team. None of these reports have been transmitted to the NRC. The NRC inspection team reviewed 21 of these reports, and their supporting files which are listed below. All reports involved issues identified as potentially safety-related or safety-significant. Of the 21 reports i reviewed, 19 addressed individual concerns. The remaining two reports addressed four concerns and two concerns, respectivel The NRC inspectors noted that TVA was conducting a management review team audit of these records at the time of this inspectio EX-85-023-001 IN-85-688-001 IN-86-293-001** ' EX-85-181-001 IN-85-767-006** PH-85-002-027** IN-85-033-001** IN-85-894-001** WI-85-053-011 IN-85-243-002 IN-85-933-001 WI-85-060-001** IN-85-289-001** IN-86-011-003 WI-85-011-001 IN-85-332-001 IN-86-073-001 XX-85-050-003** IN-85-339-005** IN-86-079-002 XX-85-089-001 IN-85-346-002 IN-86-209-003 XX-85-093-002** IN-86-266-X09 (5) Of the sample of 21 Generic Concern Task Force Reports,15 were evaluated by the NRC inspectors as reaching conclusions not substantiated by the report or associated files. Some of the reports were written for an audience with Sequoyah-specific

* Noted as PSR by TVA reviewer (Form 8.2 from SQA-166).

• • Concerns which were adequately addressed by the Investigation Repor . . . - _ - . . _ - --.-. _

. o knowledge, some lacked information which was apparently available, but not included in the reports or the files, and some reports did not appear to answer the right question. Three examples of this last category are as follow (a) IN-85-688-001, Overfill of Cable Trays - A concerned individual made a statement that plant procedures don't prohibit overfill of cable trays. The completed investigation report indicated that the concern was not substantiated since the FSAR includes restrictions on cable tray fill requirements based on voltage or amperage specifications. The report also quoted the presence of procedure M&AI-04 which indicated that it is acceptable to fill to the side rails of the cable tra Procedure M&AI-04 appears to conflict with the FSA It was not apparent from the investigation report that an inspection sample was selected to prove the acceptability of cable tray fill requirements at Sequoyah, or that procedures (other than M&AI-04) were examined to determine if a problem existed with cable tray overfil (b) XX-85-089-001, Procedure Violations - A concerned individual made a statement that procedures were knowingly violated during the performance of work, and that once work was completed the procedures would be revised to agree with the work that was actually accomplished. The completed investigation report indicated that improvements were needed regarding procedures, and that improvements were being mad It appeared the investigator missed the point of the concern, that people willfully violate procedures and work was accomplished which was in disagreement with what was approved. It could not be determined by the NRC inspectors that an inspection sample was selected by TVA to prove / disprove the concer (c) IN-85-332-001, Valve Motor Operators - The employee expressed a concern that the fuses protecting these types of circuits were designed to protect the motor and not the entire circuit. As an example, the employee identified the emergency reactor cooling water (ERCW) valve for the fifth diesel at Watts Bar which is fused for 5.2 amps and has a running current of 4.0 amp The Sequoyah investigation into this concern stated that the employee concern was with the ERCW valves for the fifth diesel at Watts Bar. The report then proceeded to discuss the protection offered the diesels at Watts Bar and Sequoyah. However, TVA did note that motor operated valves were used for containment isolation at Sequoyah. Based on a review of the information, TVA concluded that:

.. The circuits containing limitorque valves for the fifth diesel at Sequoyah have 15.0 amp fuses,
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  . . The penetrations at Sequoyah have Limitorque valves, and
  . . The thermal overload protection devices for motor operated valves are rated and tested at locked rotor current Although the employee concern dealt with the proper fusing of circuits for Limitorque valve operators, TVA addressed the specific problem of the circuit protection afforded the fif th diesel at the Watts Bar and Sequoyah units, rather than the generic question of fusing for valve motor operators .

c. New ECP (Beginning February 1,1986)

 (1) Memorandum L12 '860130 802 was issued by S. A. White, Manager of Nuclear Power, to define and implement the new TVA ECP. It contains the ECP Line Organization Procedure (issued as SQA 178 at Sequoyah), instructions for employee orientation to the new ECP, and Employee Concern Program Instruction 1, " Employee

' Concern Program-Site Representative Procedure" and Instruction 2,

  " Employee Concern Program-Reporting."

The Employee Concern Program Instructions are the " implementing" procedures for the ECP Site Representatives (ECP-SRs). The ECP Manager and Site Representatives are in the process of implementing these procedures. Some of the requirements of Instruction 1 are:

  "The ECP Site Representative shall monitor the effectiveness of the employee-supervisor relationship for identification i   and resolution of employee concerns."

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   . . . specific information regarding individual concerns will be input into a computer data base. The ECP-SR may use the data base to determine if the concern has already been raised and, if so, the findings and the corrective action."

"The Employee Concern Program files are not considered quality records and as such are not public document . . . ANSI N45.2.9 will be used as a guide to assemble, control, and store these file The contents of the completed files should be indexed, segregated, total pages numbered, and maintained in a folder."

"The program manager will provide each site representative with a copy of the other sites' reports. Site representatives should review these to identify any common areas of concern."

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9 Instruction 1 does not identify how the ECP-SR is to monitor the effectiveness of the employee-supervisor relationship. There is no longer any requirement for managers / supervisors to make and retain " notes" of employee concerns identified to them. SQA 178 states:

"If the concern is resolved using existing procedures or through verbal agreement between the supervisor and employee, no special documentation is required (other than that required by existing procedures)."

No information regarding individual concerns from the new ECP had been entered into a computer data base as of the time of this inspectio The Sequoyah ECP-SR files had not yet been indexed, page numbered, etc., and consisted mainly of handwritten notes. None of the Sequoyah ECP-SR files have been copied for the other ECP-SRs or reviewed by the ECP manage (2) The ECP-SRs for Sequoyah (T. Galbreth) and Chattanooga (D. Baker) were interviewed by the NRC inspectors. The NRC inspectors determined, through discussion with the ECP-SRs and review of resumes, that the 6 present ECP Site Representatives all have technical degrees (engineering or science), have all worked for TVA for at least 5 years, and received special training in conducting interviews (from QTC and EG&G) and investigations (from hSRS). Some of the ECP-SRs have limited experience (6 months or less) with the Watts Bar Special Program, investigating concerns for NSR (3) Memoranda SO4 '860205 801 and B25 '860208 001 were issued to Sequoyah Office of Nuclear Power (0NP) and Office of Engineering (OE) managers / supervisors, respectively, directing training for all employees in the new TVA Employee Concern Program. All employees were required to be trained by February 14, 198 Attendance list rosters were signed for the training sessions, and the ECP Site Representative had a copy of these roster The NRC inspectors requested evidence from the Sequoyah ECP Site Representative that the rosters had been reviewed to verify training of "all" employees, but he was unable to provide such evidence prior to completion of the inspectio (4) The 154 files generated by the Sequoyah ECP Site Representative from exit interviews, walk-ins, telephone calls and mail-ins since the start of the program, February 1,1986, were reviewe The 154 Sequoyah ECP-SR files contain 24 concerns from Sequoyah, and 5 concerns from the Power Operations Training Center (P0TC).

Three of the Sequoyah concerns had been closed by the ECP-S The majority of the files were for exit interviews with no-8-

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concerns expressed, and concerns associated with personnel problems. None of the concerns had been evaluated by the ' Sequoyah ECP-SR as 'potentially safety-related (PSR).

(5) The ECP Site Representative was not identifying subsidiary  )
(offshoot) concerns separate from the main concerns. As an example, an employee told the Sequoyah ECP-SR that he was being accused of tampering with quality control inspected and accepted equipment. The ECP-SR did not identify this item as safety-related, nor did he separate out the subsidiary concern of damage to safety-related equipment. In discussion with the NRC inspectors, he stated that he knew about the equipment described, knew it had passed a reinspection, and thus knew there was no technical issue. However, none of this knowledge or reasoning process was documented in the fil (6) The threshold for classification of employee concerns as potentially safety-related or safety-significant by the Sequoyah ECP Site Representative is not consistent with that used by QTC/NSRS. Several files reviewed by the NRC inspectors would probably have been classified as PSR by QTC and NSRS, based on the NRC inspectors' familiarity with the Watts Bar Special Program. As discussed in Paragraph d.(3) below, a similar issue was identified during a previous inspection of the ECP for Sequoyah.

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" Safety related" is not defined in SQA 178, ECP Instruction 1 or ECP Instruction 2, although ECP Instruction 2 requires the ECP-SR to designate whether a concern is " Nuclear Safety Related" on the weekly summary sheets (Attachment 3 to ECP Instruction 2). The definition of " safety-related" given in the E. Sliger memorandum of March 5, 1986 to the ECP-SRs appears to be an expanded version of the definition in SQA 166, and includes such items as control room habitability and radioactive waste system (7) The NRC inspectors discussed the new ECP and its relationship with the Watts Bar Special Program with E. Sliger, the ECP Manager, and R. Denise, who is now managing the Watts Bar Special Progra They both report directly to S. White, the Manager of Nuclear Power. Mr. Sliger stated that the ECP-SR files will be subject to audit by QA for compliance with procedures, and that he intends to review the files. Mr. Sliger and Mr. Denise agreed that the ECP-SR file data would be loaded into the same data base as the Watts Bar Special Program, and that the same " key words" used in identifying information for the Watts Bar Special Program would be used for the new ECP dat (8) There is no documentation describing the linkage between the previous and current ECP As an example, the two ECP Site Representatives interviewed were unaware that their information

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o I regarding individual concerns was to be input into the same data base as the Watts Bar Special Program, nor is there any statement to this effect in the implementing procedures for the new ECP. In addition, the ECP-SRs appeared to have If ttle knewledge of the Watts Bar Special Progra d. The following observations from IR 50-327-328/86-08 (with Paragraph number in parenthesis) were reviewed and the action (s) taken determined (see Attachment 2 for additional details).

(1) Changes in the ECP anticipated by TVA to go into effect about February 1,1986 may make some of the inspection observations not applicable. 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 (8.d).

The directives for the new ECP (starting February 1,1986) have been issued and training for the new ECP accomplished for Sequoyah personne (2) Site-generated employee concerns do not receive a generic review and the B.1 Form is only used to document a concern and not to track or audit resolution (8.d). TVA should revise their program to incorporate a generic review (7).

SQA-166, Rev. 6 contains instructions for review of onsite concerns for potential generic applicability of the concern to other TVA sites. The generic review is to be accomplished and documented by completion of the Attachment 8.3 form, "Sequoyah Nuclear Plant Review for Generic Evaluation." The NRC inspectors review of the Onsite Concern files indicated that review and evaluation of the files had not been complete (3) Site procedure SQA-166 does not define safety significance (i.e., requiring resolution prior to startup), but relies on the experience of the reviewers (8.d). The licensee committed to enhancing their procedures in order to better define the terms safety-related and safety-(significant the intended fashion (4.d 1)). and to use the terms in SQA-166, Rev. 6 defines " safety-related" and " safety-significant," as does E. Sliger's memorandum of March 5, 1986. A single, TVA-wide definition has not yet been implemented. NRC review of TVA's implementation (interpretation and use in categorizing concerns) of these definitions was not accomplished during this inspectio (4) TVA needs to resolve concerns as they relate to specific hardware or programs as a group and not as individual issue This requires integrating the output of the three programs into groups of related concerns (8.d). The licensee committed to enhancing uniformity of their program implementation into a more

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auditable program. This coment proceeds from the licensee's failures to deal with all related issues (from generic, site specific, and onsite programs) in one technical area as a coordinated package (4.d(2)). The NRC inspectors did not observe any evidence that the output of the three pre-February 1,1986 ECP activities had been integrate (5) No TVA Division of Quality Assurance reviews of the ECP had been conducted at the time of the inspection (8.d).

No Quality Assurance audit /surveillances of ECPs had been performed at Sequoyah; not inspected for other location . Conclusions Data from several ECP sources have not been transmitted to the NR (1) Onsite ECP prior to February 1,1986 (Manager's/ Supervisor's notes, 86 files).

(2) Generic Concerns Task Force Reports (114 reports).

(3) Onsite ECP since February 1,1986(154 files), except for a summary (approximately equivalent to K-form) for those concerns evaluated by the ECP-SRs as safety-related, The reports developed by the Generic Concerns Task Force were found to be inadequate with regard to either investigation scope, or the required documentation to support the investigation conclusions, and will require additional TVA investigation to closecut issues / concern Upon completion of the upgrading of these reports, they should be transmitted to the NRC for review in accordance with the H. R. Denton letter to TVA (W. F. Wills) dated September 26, 198 The files from the onsite ECP (prior to February 1,1986) and the new ECP should be formalized by TVA. Upon completion of this action, these files should be submitted to the NRC under the scope of the H. R. Denton letter to TVA (W. F. Willis) dated September 26, 198 The " linkage" between the new ECP and past ECP should be clearly documented by TVA. This linkage should include a process for correlating multi-site concerns to avoid duplication of effort and result in the eventual formulation of a single employee concerns data base which is both accessible to the ECP Site Representatives and can be used for trending the combined Watts Bar Special Program, the pre-February 1,1986 ECP (onsite concerns) and the new EC a J LICENSEE EMPLOYEES AT EXIT INTERVIEW H. L. Abercrombie, Site Director R. P. Denise, Program Manager D. E. McCloud, Licensing Support Supervisor T. D. Knight, Assistant to the Site Director R. C. Birchell, Mechanical Engineer F. C. Mashburn, Nuclear Engineer C. G. Hudson, Project Engineer L. M. Nobles, Superintendent (0&E) B.Patterson, Superintendent (Maintenance) P. R. Wallace, Plant Manager G. B. Kirk, Compliance Staff Supervisor J. Blankenship, Manager, Information Office A. Kitter, Engineer Assurance Supervisor W. E. Anchans, Site Quality Manager W. R. Lagergren, Employee Concerns Task Force P. L. Shepherd, Electrical Engineer F. Campbell, Nuclear Licensing W. P. Turner, Project Coordination C. R. Brimer, Site Support Manager R. C. Denney, Design Service Staff E. K. Sliger, ECP Manager T. M. Galbreth, ECP Site Representative Attachment }}