IR 05000327/1986051

Insp Repts 50-327/86-51 & 50-328/86-51 on 860826-28.No Violations Identified.Major Areas Inspected:Implementation of Employee Concerns Task Group Program,W/Emphasis on QA-QC Aspects

ML20214Q325
Person / Time
Site:	Sequoyah
Issue date:	09/18/1986
From:	Belisle G, Belke W, Belko W, Gilray J, Hooks K, Poindexter T, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214Q318	List: IR 05000327/1986051 ML20214Q316
References
50-327-86-51, 50-328-86-51, NUDOCS 8609240283
Download: ML20214Q325 (11)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Report Nos.: 50-327/86-51 and 50-328/86-51 Docket Nos.: 50-327 and 50-328 License No. DPR-77 and DPR-79 Licensee: Tennessee Valley Authority ,

6N 38A Lookout Place l 1101 Market Street Chattanooga, Tennessee 37402-2801 Facility Name: Sequoyah 1 and 2 Inspection Conducted: August 26-28, 1986 Inspectors: u> d P P Pl

. Kenn'eth R. poks, IE, Team Leader Date YE Y Ib 0 '

Jo ' . Gil ray, M 4 ' Da te'

am Hilliam t. Belke, IE

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ma Date vbfvnL f Y,$

ThomasC.Poipdexter,NRR Date'

t.a rwl l l G. Alan BelisJe, RII Da te'

Approved by: ' 9 6 R. Lee Spessard,,@eputy Director, DI/IE Cate D AD 5 00327 G PDR Enclosure

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Inspection Summary Scope: This special, announced inspection was conducted at the Watts Bar Nuclear Plant site. The inspection was performed to review and evaluate the implementation of the Employee Concerns Task Group (ECTG) program within TVA, with particular emphasis on QA/QC-related aspects of the program and employee concerns investigations accomplished by ECTG personnel for the Sequoyah Nuclear Plan Results: No violations were identified. The inspectors made findings relative to the content of procedures and implementation of the Employee Concern Task Group progra :

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1. Entrance / Exit Interviews The NRC team held an entrance interview with TVA management at the Watts Bar site on August 26, 1986. The inspection findings were summarized during an exit interview at the Watts Bar site on August 28, 1986. A list of TVA personnel who attended the exit interview is attache . Inspection Scope The inspection was performed to review and evaluate the implementation of the Employee Concerns Task Group (ECTG) program within TVA, with particular emphasis on QA-related aspects of the program and employe2 concerns investigations accomplished for the Sequoyah Nuclear Plan Since the ECTG personnel and files are located at the Watts Bar Nuclear Plant, the inspection was held at that location. The inspection was conducted in accordance with the requirements of NRC Temporary Instruction 2515/74, as applicabl . Documents Reviewed The following TVA procedures, reports, and files were reviewe . TVA Employee Concerns Task Group (ECTG) Procedure M.1, untitled, draft revision 2- TVA ECTG Procedure A.1, " Processing of Generically Applicable Employee Concerns," draft revision 2- TVA ECTG Procedure A.2, " Protection of Sensitive Information," draft revision 2- TVA ECTG Procedure A.3, " Employee Concerns Program Computer System (ECPS) Data Processing," draft revision 2- . TVA ECTG Procedure A.3, " Program Procedure Revisions," draft revision 2- TVA ECTG Procedure B.1, " Evaluate Training and Indoctrination," draft revision 2- TVA ECTG Procedure C.1, " Receipt, Processing, and Evaluation of Concerns," draft revision 2- TVA ECTG Procedure C.2, " Analysis and Reporting of Evaluation Results," draft revision 2- i. TVA ECTG Procedure C.3, " Corrective Actions," draft revision 2-A.

, Employee Concern Special Program (ECSP) Reports Writer's Guide, t

Rev. O, July 23, 198 Restar t Implementation Plan for Startup of the Sequoyah Nuclear Plant, 2 page undated draf .__

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. Quality Assurance Category Evaluation Group (QACEG) Sequoyah (SQN)

Element Report 80105-I, Rev. O, August 6, 198 QACEG SQN Element Report 80201, Rev. O, August 12, 198 QACEG SQN Element Report 80204, Rev. O, August 14, 198 QACEG SQN Element Report 80205, Rev. O, August 12, 198 QACEG SQN Element Report 80404, Rev. O, August 15, 198 Operations CEG SQN Element Report 307.07-SQN " Radiological Emergency Preparedness," August 14, 198 Engineering CEG Watts Bar Nuclear Plant (WBNP) Subcategory Report 233, July 198 , Construction CEG WBNP Subcategory Report C017300 " Instrument Line Installation," May 28, 198 Management and Personnel CEG WBNP Subcategory Report 7.17 Personnel Qualifications Related to Management and Personnel," Rev. O undate Nuclear Quality Audit and Evaluation Branch (NQAEB) Audit Report No. QSQ-A-86-0009, June 12, 198 NQAEB Audit Report No. QSS-A-86-0014, June 13, 198 NQAEB Audit Report No. QSS-A-86-0012, July 24, 198 . Discussion and Findings a. The draft ECTG procedures were reviewed by the NRC inspectors. The status of the procedures and their implementation were discussed with TVA personnel. The procedures reviewed were a draft of Revision 2 (the final versions of Revision 2 were approved by the ECTG Program Manager August 28, 1986 and docketed by TVA to the NRC by letter dated August 29,1986).

Pertinent portions of the draft procedures which were used to evaluate the adequacy of the element reports are quoted belo EGTG M.1, Section 2.h, states that the ECTG program shall include:

" Generation and retention of sufficient re:ords to provide auditable evidence of the adequacy of the logic and rationale that provided the basis for judgments made during the evaluation process that support findings and conclusions provided in the Progran's reports."

ECTG M.1, Section 6.4 states that: "The evaluation process shall be documented in a Case File that provides sufficient objective evidence to provide the basis for all judgments made to ensure that the logic and rationale is clearly identifie . _ _ - . - - - _ . - _ . - . .-

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i ECTG M.1, Section 7.1 states that element reports: " . . . should contain sufficient detail to make it unnecessary for a reader to examine cue files for the concerns summarized. See the ESCP Report Writer's Guide for content and format guidance."

Section 7.1 of ECTG M.1 states: " Element Reports shall be reviewed by an independent peer and the TAS (Technical Assistance Staff), concurred with by the SRP (Senior Review Panel), and approved by the responsible CEG-H (Category Evaluation Group Head)."

The ECSP Reports Writer's Guide states in Section 6.0 that: "Subca+,egory Reports are intended to contain adequate information to stand alone and provide sufficient information on which responsible line management can prepare a corrective action plan. ... Subcategory Reports are intended for readership by the SRP, ECSP, management, USNRC, ONP responsible line management, TVA employees and the general public."

Since TVA is, due to time constraints, issuing Element Reports rather than Subcategory Reports for Sequoyah, it is necessary that the Sequoyah Element Reports provide the same level of detail that the Subcategory Reports would provide for employee concerns affecting other TVA site TVA has stated that the Sequoyah restart plan will indicate the exceptions taken to the ECTG procedures for preparation and issuance of report The two page draft Restart Implementation Plan for Startup of the Sequoyah Nuclear Plant states that employee concern evaluations will: " Review the results of previous evaluations by other than the ECTG as related to the elements to determine if each issue is sufficiently addressed." It also states that: "The reports will contain sufficient information and references to facilitate an independent review and assessment."

Procedure ECTG C.3 requires that Corrective Action Tracking Documents (CATDs) be prepared and sent to the Site Directors or other responsible TVA managers for any items which are evaluated by the ECTG personnel as requiring corrective actio Corrective action (s) will be defined by the TVA line organization and concurred in by the responsible CEG-H and the ECTG Program Manage A new definition of the term " nuclear safety-related" for use in categorizing employee concerns was issued by the Director of Nuclear Quality Assurance on August 15, 1986 (TVA Memorandum L16 860815 819).

This definition is to be incorporated into the final Revision 2 of ECTG M.I. Particular attention will be focused on the definition of nuclear safety-related when Revision 2 is reviewed by the NR The ECTG program is not controlled by the requirements of 10 CFR 50 Appendix B; however, any deviations identified by the program are reported on nonconformance reports (NCRs) or other documents, as appropriate, and are then processed in accordance with TVA's procedures which are controlled by 10 CFR 50 Appendix B. ECTG M.1 assigns the responsibility for auditing the ECTG progran to the Director of Nuclear Quality Assurance (DNQA).

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The NRC inspectors evaluated the draft ECTG procedures and found them to generally provide adequate guidance for performance of the tasks (e.g.,

evaluation of concerns, preparation of reports, identification of required corrective actions). In addition, procedural controls and checks and balances from the independent SRP and the TVA Quality Assurance (QA)

organization appear generally adequate from a QA perspective. . The NRC staff will review the final versions of the procedure Further implementation inspections of the procedures by NRC personnel will be required; this need should be satisfied by the presently planned review of reports and confirmatory inspection Personnel files for the nine members of the QACEG were reviewed by the NRC inspectors (resumes / Evaluator's Profiles, Evaluator's Training Records);

the QACEG personnel (all contractor personnel) had adequate experience and training to perform their tasks. The QACEG-H stated that his evaluators were looking mainly at programmatic issues. Any hardware inspections required as part of the investigations are performed by TVA Quality Control (QC) inspectors with QACEG members as observers. The CEG for the QA Category is working exclusively on Sequoyah concerns at this time, due to manpower limitations. At the time of the NRC inspection, work had not been started on 8 of the 21 QA/QC Category Sequoyah Element Report Five draft QA Category Element Reports had been submitted by the QACEG-H to the SRP and TAS for review prior to formal issuance to TVA Management and NRC. These reports, their associated files, and the SRP and TAS comments on four of the draft reports were reviewed by the NRC inspector The NRC inspectors evaluated the draft reports and files based upon their interpretation of the ECTG procedural requirements, particularly those concerning adequacy of information which are quoted in Section 4.a of this repor SQN Element Report 80201, which concerned QC inspection criteria, was evaluated by the NRC inspectors and found to be generally adequate in depth and detail. SQN Element Report 80205, which concerned improper receiving / receipt inspection of quality items, was generally adequate when evaluated with its referenced Nuclear Safety Review Staff (NSRS) materia The three remaining reports were not adequate in depth and detai Report 80105-I, relating to as-built drawings and improper processing of l

work plans, and Report 80404, concerning timely issue of corrective action reports, were evaluated as inadequate in depth and detail but when reviewed in conjunction with their associated QACEG files an adequate evaluation could be performed. Report 80204 which involved "050" notes-(general pipe support installation notes) was evaluated as inadequate since even when reviewed with its associated file, there appeared to be insufficient detail and depth of information to support the finding The NRC inspectors noted that the investigations perfonned as the bases for the Sequoyah Element Reports may be correlated only with other concerns identified as affecting Sequoyah. As an example, the QACEG file for Element Report 80204, included only concern IN-85-596-004 and stated

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that there was no supplementary information in the ECP files. The NRC

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been gained if the QACEG evaluator had looked at other concerns related to the "050" notes, such as PH-85-006-001, IN-85-024-001, IN-85-052-001, and IN-85-413-001 (see paragraph 10.d in NRC Inspection Report No /85-57 and 50-391/85-46, December 13,1985).

As previously noted in NRC Inspection Report Nos. 50-390/86-15 and 50-391/86-15, July 7, 1986, (Section 4.b.1) the Element Reports prepared for concerns not previously investigated by QTC or NSRS do not reflect the same investigation depth. Additional investigations as required to support root cause identification and develop corrective actions will be performed by the TVA line organization and will be documented in the line organization responses and corrective actions. TVA stated that such additional detail will be included in the revised Sequoyah Element Reports which will be issued to the NRC after.ECTG concurrence with the proposed corrective action The QACEG draft Element Reports were formatted in accordance with the guidance of the ECSP Reports Writer's Guide, including a section titled

" Collective Significance." Discussion between the NRC inspectors and TVA personnel indicated that this section was inappropriate for Element Reports concerning a single plant (i.e., SQN), and TVA is considering removing this section from the reports. TVA now intends to submit the Element Reports for Sequoyah in various formats, rather than reformatting existing reports. All Element Reports for a Category will have the same format, and all Element Reports will contain the same type of information; referenced Quality Technology Company /NSRS investigation reports will be attache The TAS and SRP comments on specific portions of the Sequoyah Element Reports were similar to those of the NRC inspectors, although they did not generally draw the same bottom line conclusions as to whether the reports contained sufficient information and references to support an independent review and assessment (i.e., by the NRC). It is possible that the file draft Element reports would have been revised sufficiently to meet ECTG procedure requirements prior to formal issuance to the NRC and TVA management, based on the TAS and SRP comment d. The NRC inspectors asked TVA personnel whether " root causes" would be included in the Sequoyah Element Reports. TVA will include a discussion of the cause(s) of deficiencies as well as corrective action (s), in the appropriate Sequoyah Element Reports; however, the cause(s) identified could be different from the " root causes" determined when the Sequoyah Element Reports are combined with the data from other sites to create the TVA Subcategory and Category Report e. Element and Subcategory Reports for several other Categories were reviewed and evaluated. They varied in format and content, but were generally acceptable. Discussions with M. Bender of the SRP verified that the SRP .

is requiring stand alone reports which provide sufficient infomation to j support an independent review and assessment. The SRP members reviewed ,

and commented on the draft ECTG procedures and the draft Employee Concern i Special Program (ESCP) Writers Guid _ . _ _ _ - _ _ _ _ _ - - -

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. TVA intends to formally submit the first Sequoyah Element Reports for NRC review within the next two weeks. The first reports will be in the Welding Category, followed by Operations, Material Control, and Construc-tion. The CEO for the Engineering Category is working exclusively on Sequoyah concerns and has not yet submitted any draft Element Reports to the SR The NRC inspectors reviewed three audit reports covering recent Quality Assurance audits of the Employee Concerns Programs. Reports QSQ-A-86-0009 and QSS-A-86-0012 involved ECTG activities at Sequoyah and Watts Bar, respectively; QSS-A-86-0014 involved the new Employee Conci.rns Program.

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The TVA QA auditors identified problems with program procedures and documentation / content of reports, and all three QA audits identified the lack of a formal system to track corrective actions resulting from the Employee Concerns Programs. Discussions between the NRC inspectors and TVA personnel indicated that most of the items identified.in the audit reports had been corrected, although they were not considered deviations and no formal response to the audits was required. In particular, the CATD system was established by the ECTG to provide for positive identification and tracking of corrective action . Conclusions: The ECTG procedures currently implemented by TVA are generally adequate for the performance of the specified tasks and from a QA perspectiv While this program is not controlled by 10 CFR 50, Appendix B, we find sufficient controls and checks and balances through the Senior Review Panel (SRP) and QA audits to reasonably conclude the overall progran can be acceptably carried ou Some draft QA/QC Sequoyah Element Reports did not contain adequate depth and detail, based on the NRC inspectors' understanding of the requirements of the ECTG procedures. Action is being taken by TVA to correct this proble l l-8-

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TVA PERSONNEL WHO ATTENDED EXIT MEETING G. McNutt, Eng. ECTG/CEG-H L. Smith, DNQA/QA/QSS-R. K. Maxon, QACEG-H D. W. Stewart, ECTG M. Martin, ECTG J. E. Karr, Asst. Mgr. ECTG W. R. Brown, ECTG Mg J. T. LaPoint, ONP-WBN

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Attachment

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e Document Name:

LTR TO TVA FM PARTLOW Requestor's ID:

SUSIED Author's Name:

Hooks Document Connents:

Special Team Inspection of EC TGP FOR SEQUOYAH 327 and 328

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, Document Name:

INSPECTION REPORT /SEQUOYAH

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! Requestor's ID:

SUSIED Author's Name:

Hooks Document Coments:

Report Nos. 50-327/86-51 and 50-328/86-51 - Sequoyah I and 2

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