IR 05000327/1987023
| ML20237H817 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/03/1987 |
| From: | Belke W, Ebneter S, Peranich M, Spraul J, Stein S NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20237H809 | List: |
| References | |
| 50-327-87-23, 50-328-87-23, NUDOCS 8708250162 | |
| Download: ML20237H817 (25) | |
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U. S. NUCLEAR REGULATORY COMMISSION ' . 0FFICE OF SPECIAL PROJECTS , Report Nos.: 50-327/87-23 and 50-328/87-23 Licensee: Tennessee Valley Authority 6N 38A Lookout Place ' 1101 Market Street Chattanooga, Tennessee 37402-2803 Docket Nos.: 50-327 and 50-328 Facility Name: Sequoyah Nuclear Power Plant Units 1 and 2 Inspection Conducted: April 6-17. 1987 ! Inspectors: /
- / GW lI
/ Mark W. Peranich, Team Leader D' ate Signed.
, Au/MZ11aaAC, 7Ar/F7 William L. Belke Sats Signed YI U hM f dimt John G. Spraul Oste Signed l ' htti YAGH/ h$f$ n Steven R. Stein D&te Sign'ed I Contractor Consultants: R. Compton, D. Ford, R. Pierson - -, Approved By: [I2:/e b< "4 9 8/8/[7 , . Stewart D. Ebneter, Director Date digned ! TVA Projects Division
Office of Special Projects l Scope: This special announced inspection was conducte6 at TVA's S'equoyah Nuclear l Plant site.
The inspection was performed to review and evaluate 15 QA Employee i Concern Task uroup (ECTG) final Sequoyah Element Reports to determine accuracy ! and adequacy of content and conclusions.
Inspections of procedures, hardware, l and records to verify concern evaluations, corrective actions, and status of corrective actions were performed by the NRC inspectors.
Results: Seven of the final Element Reports were evaluated to be r, satisfactory as l written; four were evaluated as requiring revision or written explanation to clarify or add details.
Four reports require additional information or 8708250162 870819 PDR ADDCK 05000327 G POR _ _ ___ _ ____ ___
- _ _ _ _ _ _ _ _ _ . d . . actions by TVA to ensure their adequacy and completeness and will be evaluated - in a future inspection.
The process for preparation of Element Reports was generally acceptable.
Management attention should be given to improving the effectiveness of the interface between Sequoyah (SQN) and Watts Bar (WBN) ECTG personnel to ensure that information exchanged and investigations conducted on employee concerns will achieve accurate, complete, and stand-alone Element Reports.
SQN management attitude toward auditors and audit findings has improved over the last few months, the number of deficiencies identified without appropriate QA corrective actions during a TVA field verification of instrument mountings indicate a less than effective corrective action program, and the instruction and practices used to implement corrective action for design / field verification of instrument mountings requires management attention in regard to the specific case and its implications.
One violation of 10 CFR 50, Appendix B, Criterion V was identified with instruction requirements for verification of instrument mountings.
(87-23-02) Two unresolved items were identified for followup NRC inspection: one regarding the control of safety-related spare components (87-23-01) and one item regarding apparent inconsistencies and errors in determining which instruments are safety-related when compared with documents such as the critical structures, systems, and components (CSSC) list (87-23-03).
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- - _ _ _ _ _ _ - . - _ . _ _ _ _ _ _ _ _ _ , e REPORT DETAILS - . 1.
Persons Contacted - Licensee Employees L.. Alexander, Modifications Superviser '*W.
Akeley, WBN ECTG
- N. Black, DNE
- H. Cooper, SQN Lic.
R. Denney, SQN ECSP Manager
- T. Flippo, DNQA
- M. Frye, TVA/0PS
- T.
Howard, DNQA
- T.
Hughes, DNE
- J.
Karr, WBN QACEG-H
- N. Kazanas, Dir. Nuclear QA G. Killian, Nuclear QA Audit Supervisor
- J. LaPoint, Deputy Site Director J. Maddox, DNE
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- M. Martin, WBN ECTG
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- R.
McCraney, WBN FCTG
- J. Miller, DNE
- L. Nobles, SQN Plant Manager
- A. Qualls, Plant Manager (Bellefonte)
J. Staub, DNE
- J.
Swearingen, SQN ECSP J. Russell, ECTG V. Whaley, MOD /E
- C. Whittemore, SQN Lic.
J. Hamillon, SQN QA A. Varner, SQN QA M. Stitts, SQN QA J. Howard, SQN QA J. DeAngelis, WBN ECTG J. Mann, WBN ECTG Other licensee employees contacted included engineers, auditors, technicians, security office personnel, and office personnel.
- Attended exit interview.
2.
Exit Interview .The-inspection scope, findings, and NRC inspector observations were summarized during an exit interview on April 17, 1987, with those persons indicated by an asterisk in paragraph 1 above.
NRC Resident Inspectors also were present.
, The NRC inspectors described the areas inspected and discussed the inspection j findings.
3.
Documents Reviewed In addition to the final Sequoyah QA Element Reports, which were issued at the time of the inspection, the ECTG Case files for the reports and other R_____________ .;
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, , supporting documents were reviewed to the extent necessary to support the
inspection.
The Element Reports and the major supporting documents reviewed during this inspection are listed below, a.
80000-SQN Administrative Instruction AI-3, " Clearance Procedure," Rev 33
Nuclear Safety Review Staff (NSRS) Report I-85-218-SQN, Subject: Use
of Nonconforming Electrical Cable - PJJ and PNJ, dated March 17, 1986 Memorandum, Abercrombie to Whitt, dated April 10, 1986
Nonconformance Report (NCR) SQNEEB8019R1
Equipment Qualification Documentation Package Binder SQN EQ-CABL-034 Employee Response Team (ERT) Investigation Report Concern No.
- XX-85-027-X07, dated January 17, 1985 NCR 2803 Procedure MEB811230-995, " Procedure for Reduction of Specific Gravity
of Battery Electrolyte," Rev 1 December 30, 1981 Sequoyah Nuclear Plant (SNP) Inspection Instruction No. 19, " Battery
Inspections," Rev 9, April 21, 1983 b.
80101-SQN TVA Kelly memorandum, dated July 23, 1986 Administrative 1y Confidential Concern Report dated July 21, 1986: Concern Report XX-85-116-008 (parts of) - Concern Report XX-85-116-009 (parts of) - Memorandum - QA File Sequoyah Nuclear Plant - Management Attitude, j dated June 10, 1985 ] Memorandum - Audit Process Integrity, G. W. Killian to QA Branch,
TVA, dated November 14, 1985 ! ! Memorandum - Transmittal of QAB Audit Report QSQ-A-85-0008, G. W.
- Killian to H. L. Abercrombie dated June 27, 1985 Memorandum - Audit Response to QSP-A-85-0008, H. L. Abercrombie to G. W. Killian, dated July 31, 1985
, Memorandum - Evaluation of Corrective Action Response for I
QSP-A-85-0008-001, G. W. Killian to H. L. Abercrombie, dated ! October 18, 1985 l l ! -2-I l
_ _ - - - _ - _ . . Memorandum - Request for Extension of QSQ-A-85-0008-D01 Response,-
- H. L. Abercrombie to G. W. Killian, dated November 7,1985
Memorandum.- Revised Response to QSQ-A-85-0008-D01, H.'L.
Abercrombie to G. W. Killian, dated November 19, 1985
TVA's Replacement Items Program (RIP) letter to NRC dated April 1, 1987 SQN Technical Instruction (TI) 104, " Installed Items Verification for
CSSC"
SQN TI-105, " Dedicating Commercial Grade Items for Use as 8asic Components" ' c.
80102-SQN TVA Director of QA letter, dated October 22, 1984
TVA Audit Status Report, Years 1983, 1984, and 1985 d.
80201-SQN
NCR/SCR 6278 N-VT-3, Visual Weld Inspection Procedure Surveillance Instruction (51)-114.1, Inservice Inspection Procedure
e.
80203-SQN e Nuclear Safety Review Staff GiRS) Investigation Report No.
I-86-101-SQN, Subject: Installation of Conax. Connectors, dated February 27, 1986 Corrective Action Report (CAR) SQ-CAR-86-02005, dated February 10, 1986 Quality Assurance Concern Evaluation Group (QACEG) Concern Report 00-85-005-003 (Sequoyah) - ECTG Construction Category Element Report C010900-SQN ]
l Memorandum, Chmielewski to Sauer, dated December 31, 1985 i i
Drawings Nos. 45N751-1 Rev 23 45N751-6 Rev 18 j i ~ f.
80401-SQN " NQAM Generic Procedure, Part III, Section 7.2, " Corrective Action"
Administrative Procedure AI-12, " Corrective Action"
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t.' e g.
80404-SQN - CAR /0R Logs, January 1985 through July 24, 1986
Nuclear Performance Plan, Section VI.D
Generic Procedure, Part I, Section 2.16
h.
80501-SQN Generic Concern Task Force Report for Concern IN-85-463-006, subject:
Typical Drawings for Instrumentation, dated June 27, 1986 SNP Inspection Instruction No. 84, " Instrumentation Location and/or
Installation Inspection," Rev 4, dated. April 21, 1983 SNP Inspection Instruction No. 85, " Installation Verification,
Flushing and Pressure Testing-of Instrumentation Sensing Lines, Sampling Lines, Control Supply Headers and Signal Lines," Rev 10, dated May 4, 1984
Division of Nuclear Engineering (DNE) Calculation SQN-El-005, dated March 8, 1987
NQAM Generic Procedure, Part III, Section 7.2, Corrective Action
Administrative Procedure AI-12 Corrective Action i.
80504-SQN SQEP-AI-08, " Drawing and Reproduction" 4.
Discussion and Observations The results of inspector observations relative to the review and confirmatory inspection of employee concerns and their resolution as documented in the QA Category Element Reports prepared by the ECTG are discussed below.
These reviews examined the adequacy of employee concern evaluations, findings, conclusions, and planned corrective actions discussed in the Element Report.
The confirmatory inspections selectively examined the adequacy of supporting documentation contained in the Element Report case files and the planned or ongoing corrective actions for resolution of employee concerns.
The details of the QA Category Element Report reviews will be documented in the Safety Evaluation Report (SER) for that category.
NRC review and inspection observations indicating a need for the ECTG to revise the Element Report or for TVA/SQN to address deficiencies identified in planned or ongoing corrective - actions are documented below.
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80000-SQN, Revision 4, March 31, 1987, " General Management and Policy": This Element Report addresses a variety of concerns from "... nonchalant , l regard for quality..." by management to coercion of a worker to ... sign-off data sheets on defective equipment."
" Review: The review of.the Element Report identified several inaccuracies and one instance of incomplete information on an ongoing replacement parts dedication program. The ECTG committed to correcting these items as summarized in the conclusions below.
Confirmatory Inspection: Impgoper sign-off on data sheets The NRC review of the applicable documents revealed several inaccuracies in the Element Report regarding the concern of the QC inspector's reluctance i to sign the battery surveillance checksheet.
The first is NCR 2803 which was written to correct the battery-specific gravity and not the electrolyte level as indicated in the Element Report.
The second is the significance of the inspector's signature on the data sheet.
Although the Element Report states that the signature only indicates who performed the inspection and does not indicate acceptance, the inspection instruction and data sheet clearly state that the signature does indicate acceptance, with any exceptions noted in a remarks section.
However, the ultimate conclusion in the Element Report that the inspector should not have refused to sign the checksheet is correct, although for the wrong reason.
As the batteries were in a nonconforming condition for approximately 1 year, the NRC inspectors attempted to determine their operational status during that time and also the current status of the batteries.
An attempt to locate and inspect the diesel generator batteries that were the subject of NCR 2803 and the employee concern was unsuccessful.
Discussions with SQN personnel and review of case file documents indicated the batteries were in a storage warehouse during the time of the concern and are spare batteries because they were purchased for the cancelled fifth diesel generator.
However, the contract documents do not specify the diesel generator for which the batteries were purchased, and TVA was unable to produce any documentation to show when the batteries were issued from the warehouse or where they are currently located.
A walkthrough of the diesel generator building found 27 battery cells in the radiation shelter room attached to two temporary chargers.
Of the 27 cells, 21 were on an unsupported rack and 6 were sitting on the floor.
Disintegrating paper tags provided sufficient information for site personnel to produce purchase documents and transfer documents which, by count, are apparently for the six battery cells on the floor.
The origin of the other 21 cells or their correlation to the batteries addressed in the Element Report could not be determined.
The control of these safety-related spare components beyond the confines of a designated warehouse is considered an unresolved item.
(87-23-01) -5- - _ - _ - _ _ _ _ _ _ _ _ _ _ -
- _ _ _ _ _ _ - - _ _ - . _ _ _ l l' NRC misinformed of cable removal - Regarding the adequacy of type PJJ and PNJ cable types installed at Sequoyah, the environmental qualification for PJJ cable documented in Environmental Qualification (EQ) Binder SQN-CABL-034 was reviewed.
The binder had previously been reviewed and approved by an NRC EQ inspection team as documented in report 50-327,328/86-01.
However, during this . inspection, the NRC inspectors noted that neither the Element Report nor the case file contains discussion or objective evidence supporting the , qualification of PNJ cable for use in safety-related, non-EQ circuits.
' Following this observation the licensee provided a copy of TVA specifi-cation 25.013. " Standard Specification for Polyethylene-insulated Wire and Cable," dated March 16, 1973.
Based-on a review of this document, the NRC inspectors concluded that it provides adequate assurance that type PNJ cable is designed and manufactured to meet the requirements for use in safety-related non-EQ circuits at SQN.
Conclusion: l The NRC staff believes that the TVA investigation of the concerns was l adequate and that the resolution of the concerns described in the Element Report is acceptable with the following exceptions that indicate less than effective interface between the ECTG and SQN in completing necessary evaluations.
The Element Report should: correct the statement regarding the significance of QC inspectors' signatures on the battery data sheets.
be corrected to indicate the true condition documented by NCR 2803, address TVA's position on whether the NRC was misinformed regarding removal of unqualified cable from the site.
address appropriate information in TVA's SQN Replacement Items Project (RIP).
b 80101-SQN, Revision 6, March 16, 1987, " Quality Assurance Program Adequacy": This report reflects the evaluation by the ECTG of six concerns pertaining to adequacy of the QA program.
Review: The review of the Element Report and case file indicated that the concerns were adequately investigated and resolved except as noted below.
Confirmatory Inspection: Excessive paperwork and procedures This issue was substantiated by TVA and was confirmed to be addressed in the TVA Corporate Nuclear Performance Plan, which is currently being reviewed by NRC.
The issue is currently being tracked by TVA with a corporate commitment tracking system (CCTS).
Excerpts from the CCTS were j provided to and reviewed by the NRC.
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. j - . ' - Procurement requirements not invoked In evaluating the concern relating to procurement requirements not being ! invoked, a number of case file documents were selected for review and inspection.
The inspector noted that the July 23, 1986, R. B. Kelly memorandum and SQ-CAR-86-02-006 documents relevant to this concern and referenced by the Element Report were not in the case file.
The documents were retrieved by ECTG and placed in the case file.
The NRC review of the case file documents determined that the content of the Element Report addressing this concern was acceptable, except for the following.
Although the overall issue for the substantiated concern OE-QMS-1 is being tracked on CATD 80101-01, the Element Report is not complete in that it does not adequately discuss the conclusions, and corrective action covered by TVA's SQN Program Plan Replacement Items Project (RIP), dated March 27, 1987.
A copy of the RIP transmitted to the NRC in an April 1, 1987 letter was obtained from ECTG and briefly reviewed by the NRC inspector.
The RIP describes the corrective action program for review, identification, and disposition of past procurement of commercial grade items that may have been installed as safety-related replacement parts without formally dedicating the item for that use as the means to ensure that applicable quality requirements for installation have been satisfied.
Although the intent to implement the RIP is briefly discussed in case file accuments attached to the Element Report, because the significance and implications of the action now being taken, the Element Report should be revised to recognize that TVA plans to utilize the RIP in addressing the employee concern and NSRS and NRC findings relative to past use of commercial grade i replacement parts in safety-related installations.
It would also appear that better communications between ECTG and SQN personnel should have included discussions of the RIP in the above noted revision of the Element Report.
Further review of the RIP found that a contract engineering group has been established to dedicate commercial grade parts currently installed in equipment as well as parts in storage, and also to dedicate parts for future procurement.
The contract engineering group has been trained to the applicable SQN Technical Instructions and to the Nuclear Quality Assurance Manual (NQAM) and procurement standard SQA-45, which have been revised to be consistent with the RIP.
NQAM requirements not complied with Documents in the case file were selectively examined to determine whether there was more specific information or examples where Sequoyah Nuclear Plant personnel were ignoring the HQAM instructions and writing their own.
This determination was unable to be made from the material available in the case file.
In discussions with the ECTG investigator, his interviews of TVA personnel determined that specific instances could not be found.
In addition, the CARS /CRs issued in 1982-1986 for Sequoyah did not reveal any instances where the QC program from the NQAM was being ignored.
The ECTG investigator confirmed that a 100% review of SQN procedures AI-20, " Quality Control Inspectors," and AI-34, " Training and Qualifications-7- . w - - - _ - _ _. _ _ - - _ _ - _ - _ _ - _ _ _ _
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of QC and NDE Personnel," for compliance with TVA NQAM procedures revealed . no discrepancies.
QA management pressure to prematurely close audit findings Selective examinations of the case file revealed a June 10, 1985 letter criticizing Sequoyah management's attitude toward auditors during a post audit exit for a fuel handling activities and operatives instructions audit.
Audit Report No. QSQ-A-85-008 (June 27, 1985) and the SQN line organization responses (July 31 and November 19, 1985) to the audit findings were obtained and reviewed.
These reviews determined that the audit findings appeared to be adequately addressed by the SQN management responses.
The review of these documents and interviews conducted with the individuals who performed the audit and other auditors, as discussed below, did not result in identifying that QA management had exerted pressure to close Audit QSQ-A-85-008 findings, or other auditor findings.
In regard to the issue discussed in the June 10, 1985 letter, the SQN Site Director's July 31, 1985 response to the audit findings also responded to the Chief QA Branch concern over statements made to audit team members by SQN management and also indicated the action he had taken to prevent recurrence.
In total, the NRC inspection of this issue resulted in interviewing seven TVA QA auditors (past and present) who had expertise in a number of technical plant discipline and QA/QC management program areas.
In general, the TVA auditors interviewed agreed that in the past, SQN management has not always been supportive of the QA audit function.
However, due to reorganizational changes, especially in the past several months, the concensus of the auditors was that TVA QA audit findings are now being supported, reviewed, and acted on by management in a receptive and constructive manner.
The auditors also indicated that they believe the change in SQN management attitudes has improved their attitude toward auditing and toward ensuring that SQN activities are being conducted in accordance with licensee FSAR and Technical Specification commitments.
However, because of past conflicts between TVA QA organization auditors and SQN management, two of the auditors interviewed retained some concern, based on their prior experiences in conducting audits at SQN.
One indicated that he believed he still would have some reservations in accepting a position at SQN.
Another expressed his belief that his job performance evaluation and work assignment were affected as a result of informing his QA management of the past attitude of SQN management toward QA auditors.
In response to NRC inspectors, he clarified that it was not his intent to request the NRC to pursue the matter on his behalf.
However, as a result of these discussions, the NRC inspectors conducted additional interviews with two other auditors known to have also informed their management of the same problems encountered by them during an audit of SQN activities.
Neither individual felt that his work assignments or job performance appraisal had been affected negatively as a result of the action he had taken to inform his management of the problem.
Conclusion: The Element Report adequately addresses the concerns, and the NRC staff finds the report to be acceptable with the following exceptions.
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contained in TVA's RIP and the ECTG clarification that a 100% review of procedures AI-20 and AI-34 was performed.
The absence of adequate discussion on TVA's RIP indicates less than effective interface and communications-between the ECTG and TVA/SQN.
c.
80102-SQN, Revision 4, March 16, 1987, " Quality Assurance Independence .and Authority": This Element Report add'resses 13 concerns involving the organizational independence of QA personnel and the lack of depth of QA audits.
Review: The review of this Element Report found that the investigation of the concern was adequate and that the resolution of the concern was acceptable.
Confirmatory Inspection: , Lack of depth of QA audits . Selective examinations of the case file documents referenced by the Element . Report, paragraphs 1.2.2 and 2.2.2, determined that the November 11 and November 25, 1985 letters from the Director of QA were not available for review.
The TVA reviewer indicated that the correct letter reference should be an October 22, 1984 letter, which was in the case file and was then reviewed by NRC.
The case file was further reviewed to determine the scope and depth of the Sequoyah audits from 1983-1985.
The NRC review of the audit status sheet indicated that the scope of the audits actually increased, i.e., more ' areas were audited with an increase in attributes witnessed.
Conclusion: ' The Element Report adequately addresses the concern and finds it acceptable except that changes should be made to reference the correct letter in the Element Report.
d.
80201-SQN, Revision 5, April 4,1987, " Inspection Criteria": This Element Report addresses six concerns related to acceptance of substandard vendor welds and examples of inadequate QA inspection acceptance criteria.
Review:
The review of the Element Report identified several open questions regarding the installation of compression fittings for instrument tubing and the area of procurement.
Confirmatory Inspection: Vender (SECO and NAVCO) welds are substandard In evaluating the concern related to vendor weld quality, the NRC inspector examined ANSI piping standard B31.7, site weld visual inspection procedure N-VT-3, and inservice inspection program procedure 51-114.1-9- .. _ __
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with regard to their applicability to the work, The NRC inspector , considered the action taken acceptable.
Inadequate quality controls for installation of instrument tubing Meetings with site QA and engineering personnel were held regarding compression-fitting installations These meetir.gs established that TVA should document an evaluation of the specific applicability of testing and evaluations performed to answer Watts Bar employee concerns to the hardware and conditions at the Sequoyah site.
Documentation on the results of the NRC-requested evaluation was not available for review during the inspection and must be discussed in the Element Report.
The ECTG wrote Corrective Action Tracking Document (CATD) 80201-SQN-2 to address a lack of specific training requirements in site procedures regarding installation and inspection of compression fittings.
The corrective action plan (CAP) from the site in response to the CATO indicated the specific training references were placed in Administrative Instruction (AI)-14, but were not considered to be necessary or required for other site procedures.
However, on the basis of discussions between the NRC inspector and site QA personnel, the need to more fully reference training requirements in other site procedures will be re-evaluated by TVA.
Conclusion: In general, the Element Report was considered to be detailed and complete with the following exceptions that indicate less than effective interface between the ECTG and SQN in completing necessary evaluations.
The Element Report will require revision to address the open questions regarding compression-fitting installations at SQN (i.e., to evaluate the appli-cability of the Watts Bar evaluations to SQN and to include training requirements in site procedures) and to reflect the information now contained in the SQN RIP, in letter to the NRC dated April 1,1987.
e.
80203-SQN, Revision 4, March 27, 1987, " Inspection Performance": The four concerns evaluated in this report involve inadequate performance of QC inspectors and possible falsification of QC inspection records.
Review: The review of the Element Report and discussions with site engineering and operations personnel identified several inaccuracies and omissions.
Confirmatory Inspection: ! Inadequate inspection of Conax connectors The installation of eight Conax seal assemblies in containment were visually inspected and found to be acceptable.
Evidence of Grafoil thread l sealant was noted on threads that were accessible for visual inspection, j and no cable bend radius problems were identified.
A review of the Conax Installation Manual IPS-725 (Revisions C through G) and TVA drawing 45W880-28 indicates that appropriate torque value and tape sealant
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- . d - . , instructions were available to craft and inspection personnel during - installation.
Inspector deliberately distracted from inspecting a cable with insulation damage Visual inspection was performed on the terminal ends of two power feed cables for the backflow gate hoist motors.
The inspection confirmed the current CATO CAP statement that design drawings accurately reflect plant conditions is correct.
It also determined that the Element Report conclusion and supporting documentation are not based on actual plant conditions.
The power feed cables are still identified as safety related and are still connected to a safety-related power source, as indicated on the wiring diagrams.
The cables are also routed with other safety-related cables in the auxiliary building.
Operation of the gates requires operator action at the reactor MOV boards in the auxiliary building-and at the motor control panels in the gate house.
Discussions with operations personnel indicate that the gates may be used for a maintenance function during cold shutdown or refueling modes.
Conclusion: The inspection of Conax seal assemblies verified that approved corrective actions had been properly implemented.
The review and inspections indicate that the Element Report content is acceptable with the following exceptions.
The additional Conax seal assembly installation problems identified in the ' NSRS report and their resolution need to be discussed in the Element Report.
The findings in the Element Report regarding the backflow gate hoist motor cables should more accurately describe the actual plant conditions and operation of the motors. The conclusion should be based on those conditions.
This item indicates less than effective interface between the ECTG and SQN in completing necessary evaluations.
The Element Report should be revised to address the omissions on the new information identifying the item of concern (3 heat exchangers) that was not adequately inspected.
f.
80303-SQN, Revision 4, April 6,1987, " Personnel Training and Experience": This report evaluated four concerns involving inadequate training and experience of personnel, failure to follow procedures, and failure to maintain proficiency.
Review: . The review of the Element Report and discussions with site personnel indicate that the concerns were adequately addressed and resolved.
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__ _ - _ - _ . . ' . Confirmatory Inspection: Training and experience of selected QA personnel was inadequate Regarding the qualification of QC inspectors, the new qualification program was reviewed, including interviews with TVA training personnel.
The NQAM has been revised and is consistent with the current QC inspector training activities. The on-the-job (0JT) training manual is still in the process of being revised.
0JT is documented, however, and is used to form the basis for waiving of training segments because of experience.
A formal training program for QC inspectors has been established in three parts: general training, basic training, and specific training.
Currently, 23 people have completed general training and 21 are in various stages of basic and specific training.
Only two SQN individuals have completed all training, including OJT.
Conclusion: The Element Report adequately and accurately addresses the concerns, and the NRC staff finds it acceptable.
The current QC training program is in place, but it is too early to measure the effectiveness of the program.
g.
80401-SQN, Revision 2, December 12, 1986, "Nonconformance Reporting": The single issue addressed in this report is that management hesitated or refused to issue corrective action reports and deficiency reports against inadequate procedures.
Review: The review of the Element Report and discussions with the ECTG personnel indicate that the concerns were adequately addressed and resolved.
Confirmatory inspection: NQAM Generic Procedure, Part III, Section 7.2, " Corrective Action," was reviewed.
Specifically, paragraph 4.1.6 of this procedure encourages employees to spontaneously report to their responsible supervisor any known or suspected condition they find.
In turn, the responsible supervisor is required to enter the problem into the appropriate corrective action system.
If management is not responsive, administrative procedure AI-12, " Corrective Action," requires conditions adverse to quality to be documented, processed, reviewed, effect determined, and escalated to higher management if necessary.
If the above two methods are not responsive, the inspector employee may revert to the use of the TVA Employees Concern Program.
The above three methods appear to provide sufficient controls for TVA employees to identify nonconforming and l potentially safety-significant items.
The ECTG investigation did identify a number of instances where CARS had been issued to correct procedural deficiencies as evidence that corrective action documents have been used , I for this purpose.
Conclusion: l The Element Report was found to adequately address the concern.
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80402-SQN,' Revision 4, March 16,1987, " Management's Interference in ' Deviation Reporting": The two concerns evaluated in this report stated that inspectors were not allowed to document deficiencies and supervision had stopped corrective action on an identified quality problem.
Review: The review of the Element Report found that the concerns were adequately addressed and resolved through pending corrective action.
Confirmatory Inspection: Inspectors not allowed to document deficiencies The corrective action for CATD 8042-SQN-01 indicated that a Section Instruction Letter (SIL) would be issued by November 28, 1986, describing j all aspects of the QC observation.
The NRC review of the Element Report ' case file indicated that the SIL was not in the case file or issued and available for review.
Although under the NQAM program the use of the prior SIL instruction is questioned, the action intended indicates that the concern should be adequately addressed, subject to implementing the , stated corrective action instruction.
Subsequent to the inspection, the ] NRC was informed by the ECTG that SIL 10.7, " Report of Potential Problems," had been revised to reinstate the "QC Observation Log" as Attachment 2 to .
Rev. 2, dated March 17, 1987.
TVA has also committed to incorporate all SIL instructions subject to QA/QC controls into the NQAM.
I Conclusion: The NRC review and inspection of the Element Report found it acceptable l with intended corrective action.
However, the adequacy of the SIL 10.7 l or NQAM instruction will be reviewed during a future inspection.
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80404-SQN, Revision 2, November 17, 1986, " Program Implementation": The i ' issue derived from two concerns evaluated in this report is the timely documentation of discrepancies.
Review: The review of the Element Report determined that it appeared to adequately address and resolve the concerns except for one area that was selected I for inspection.
) Confirmatory inspection: Corrective action reports / discrepancy reports not issued in a timely manner i l Select examinations were conducted on the case file CAR /0R logs for January 1985 through August 1986.
It was noticed that the last item was closed out on July 24, 1986; however, three items found in early 1985 still remained open in excess of a year, and this appeared contrary to l TVA's QA Topical Report for " timely" corrective action.
However, the issue of " timely" corrective action is now adequately recognized by TVA and is addressed in Section VI.0 of the Nuclear Performance Plan and j - 13 -
,
_ .
Generic Procedure, Part I, Section 2.16.
TVA's " timely" corrective action . will be monitored by Region II in future inspections of Sequoyah Nuclear Plant site.
The NRC was unable to substantiate that CARS were issued in a timely manner or did not take in excess of 3 months to issue (Element Report ~ 80404, paragraph 1.2); that is from the time the discrepancy was found to the time it was issued.
However, the prior CAR procedure did not specifically address this area of timeliness.
Discussions held with two TVA ECTG reviewers found that under the new procedure, SQN-AI-12, there are acceptable provisions to control the time between initiating and issuing a CAR.
Conclusion: The Element Report adequately addresses the resolution of the concern.
j.
80501-SQN, Revision 5, March 31, 1987 " Engineering Document Quality": The single concern addressed in this report is that " typical" installation drawings were not available for installation or inspection of some. installed safety-related instruments.
Review: The review of the Element Report indicated that the planned corrective action would adequately address and resolve the concerns.
However, the review and inspection of corrective actions performed by the site resulted in significant NRC inspector concerns that are discussed below and that , will require that the Element Report be revised.
' I Confirmatory Inspection: No typical installation drawings for locally mounted instruments.
TVA substantiated that locally mounted instruments (not installed in identified panels or racks) had been installed without detailed drawings.
I Further inspections performed for equipment qualification and design review l programs have identified discrepancies in instrument installations due, ] at least in part, to the lack of design drawings.
Corrective Action ' Plans (CAPS) were issued that provided for separate pre-restart and post-restart actions.
Pre-restart actions were to (1) identify safety-related instruments required for FSAR Chapter 15 events (seismic), (2) determine by drawing search and field inspection which instruments do not have design-approved mountings, (3) initiate a Condition Adverse to Quality Report (CAQR) for those without designs, and (4) issue approved mounting details as required.
The post-restart actions are to execute the same process for the remainder of the safety-related instruments.
Calculation SQN-El-005 was issued by DNE (electrical / instrumentation group) on March 18, 1987, as documentation of the pre-restart CAP.
Although this was formally a " calculation," it was in reality a procedure l by which DNE personnel performed and documented drawing searches, field l walkdowns, and engineering evaluations.
The practice of using a " calculation" as an instruction for the purpose stated should be reviewed 14 - - l l
_ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ . '
{ . by the licensee.
The NRC inspector reviewed the use of this calculation
- and identified numerous error and omission deficiencies in its implementa-tion.
Examples include the following: (1) In many cases steps were not signed off on the walkdown inspection - and drawing confirmation checklist, especially steps related to specifying field installations that differed from existing typical drawings and to identifying loose, missing, or damaged mounting
fasteners.
(2) There was no documentation in the calculation, or other files, of the engineering evaluation of installations that differed from typical drawings.
(3) In some instances, installations wert indicated to be in accordance with existing detail drawings although the photographs and sketches from the field (attached to the data theets) indicated they were not the same.
' . (4) There were no entries in the "results" column of the summary sheet (Attachment C of the calculation) for two instruments and no data sheets were on file.
(5) The Attachment C listing of instruments was in error in specifying layout and conduit grounding drawings as being instrument mounting detail drawings and in referencing the wrong drawing for newly generated mounting details.
(6) The summary and conclusion statements for the calculation were in error or misleading regarding the following items: (a) The conclusion stated that each item on the summary list had been inspected when only 210 of the initial selection of 547 items were determined to be within the scope of the program, and only 98 had inspection data sheets completed and filed with the calculation.
(b) The summary stated that for instruments that did not have an existing mounting detail, a sketch had been " submitted to Civil Engineering Branch (CEB) for seismic analysis to determine the acceptability." Only one CEB calculation could be provided.
It was an as-built analysis of two identical instruments for which no detail drawing existed.
No one in DNE (electrical or civil) could show that CEB had performed any evaluation of the many l remaining installations with field sketches.
(c) The conclusion stated that each item in the summary listing had " documented, design approved mounting details." The NRC inspector does not consider that the existing documentation supports this rtatement.
, Contrary to Criterion V of 10 CFR 50, Appendix 8, DNE Calculation l SQN-El-005 was not properly implemented and controlled, which resulted in j its completion with numerous errors and omissions.
(87-23-02)
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- _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . Two additional concerns were identified during the review of this issbe.
- As a result of the field walkdown of instruments by engineering, a large number of installation problems were identified (at least 25 work requests were issued).
These hardware problems included loose fasteners, misaligned unistrut nuts, and missing and loose brackets.
The NRC inspector considers that discovery of such a large number of deficiencies should have initiated a more formal inspection and evaluation within the existing QA program.
Combined with the incomplete engineering inspection documentation during the walkdown, this less than aggressive response to 3@4 hardware deficiencies demonstrates a less than effective QA program for corrective action and a lack of quality assurance awareness by engineering.
[[ l Secondly, there appears to be inconsistencies and errors in determining , ' l which instruments are safety related or are necessary in case of FSAR Chapter 15 seismic events.
These discrepancies appear when comparing the various site procedures involved (SQN-El-005, SMI-0-317-50) to the resource documents like instrument tabulation drawings and the critical I structures, systems and components (CSSC) list of SQA-134.
The l inconsistencies are in the identification of which instruments are locally mounted on identified panels or racks, which instruments are considered safety related, and which instruments would be required in case of the design-basis seismic events.
Examples include (1) numerous instruments listed in corrective action procedures (completed and proposed) as required in case of a seismic event which are not on the CSSC list; (2) instruments determined to be panel mounted in one inspection program which were not included in the program specifically for inspection of panel-mounted instruments, and vice versa; and (3) the instrument tabulation l drawings that do not appear to be accurate with regard to whether instruments are panel or rack mounted.
The accuracy and appropriateness of the selection process TVA uses for the instrument mounting corrective action program was not fully reviewed during this inspection and will be evaluated by the NRC in a future inspection.
This is considered an unresolved item.
(87-23-03) As a result of this inspection, meetings were held with responsible site personnel to discuss these concerns.
The licensee committed to completing a review of the instrument mounting Corrective Action Plan activities and to developing an effective program to properly resolve this issue.
Conclusion: Although the Element Report and case file appeared to adequately address the employee concern, the execution of the corrective action which is to be accomplished under the controls of the SQN QA program was inadequate in that the requirements of 10 CFR 50, Appendix B, Criteria V, " Instructions, Procedures, and Drawings," were not satisfied.
TVA management attention is required to assess the implication of the practices which caused the identified deficiencies.
The need for and extent of revisions to the Element Report will depend on TVA's assessment of the concerns and questions detailed above.
Issuance of an SER for this Element Report will be deferred until additional information regarding corrective actions is presented by TVA.
It should be noted that the adequacy of the installation of instruments in panels and racks is being evaluated under Element Report 22303.
The numerous deficiencies identified by TVA verification efforts should have resulted in takirg additional remedial corrective actions.
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . k.
80503, SQN Revision 3, February 26, 1987, " Document Distribution Contr'oT": - This report evaluated seven concerns identifying instances of inadequate procedures, instructions, and implementation of the document / drawing control progrcn.
Review The review of the Element Report before conduct of the inspection found it did not adequately address the concerns.
Therefore, no further review or inspection was performed for this Element Report pending NRC receipt of the next revision of the report addressing NRC prior review questions discussed with ECTG at WBN on March 3-4, 1987.
Site Meeting However, due to the significance of the questions raised by the NRC review, the NRC requested and conducted a meeting between ECTG and SQN plant engineering personnel with the intent of ensuring (1) that both ECTG and SQN personnel understood NRC questions on the adequacy of the Element Report in resolving the stated desigr. control concerns and (2) of enhancing the interface between ECTG and SQN engineering personnel.
Evidence of the lack of effective interface is provided by the current Element Report which does not reflect the effort TVA initiated to perform an extensive field as-built verification of design for selected safety-related systems and the extent that those efforts would or would not resolve the concerns of the Element Report concerns.
1.
80504-SQN, Revision 4, March 9, 1987 " Quality Assurance Records": The various concerns addressed in this report involved inadequate preparation, storage, and retrieval of quality documents.
The review of the Element Report indicated that adequate evaluation and investigation of the concerns was performed.
However, the scope of the evaluations and corrective actions in the Element Report is limited to the programmatic aspects of those concerns relating to material traceability.
Therefore, as a minimum, this Element Report should discuss which other Element Report or effort will address the hardware issues associated with the material traceability concerns and past NSRS-and NRC-identified deficiencies in this area.
Confi"matory Inspection: Controlled documents contain conflicting or obsolete data In evaluating actions taken to resolve the concern related to controlled documents containing conflicting or obsolete data, the NRC inspector interviewed the responsible TVA drawing issue personnel and their supervisor.
Procedure SQEP-AI-08, " Drawing and Reproduction," was reviewed to assess the adequacy of the current process.
Personnel were knowledgeable and the procedure and documentation being used should prevent any recurrence of this problem.
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. , Work not appropriately documented ' With regard to the concern that equipment environmental qualification (EQ) l work had not been properly documented, the inspector' interviewed site QA/QC personnel and NRC staff, and also reviewed procedures and documenta-tion to show that quality assurance coverage of this issue was effective.
TVA QA personnel responsible for audits, surveillance, and documentation and procedure reviews were interviewed.
Surveillance and audits of the EQ program and schedules for future activities were examined as well as the procedures governing audits, surveillance, and QA reviews of documents.
NRC personnel responsible for_ review of the EQ program were interviewed concerning their evaluation of programmatic aspects of EQ.
This inspection effort indicated that the EQ program is receiving a continuous high level of QA, as well as technical, attention.
QA records not identifiable or retrievable Vendor drawing control personnel were interviewed.
Applicable restart items list activities and revised administrative and implementation procedures were reviewed.
It appears that effective corrective action has been initiated and is progressing to a final resolution of this issue.
Conclusion: The NRC staff believes TVA's investigations of the concerns were adequate and that the resolution of the concerns described in the Element Report is acceptable except that the Element Report should be revised to reflect the pending material control Element Report (40703) and its impact on program and procedures and to address the impact of NRC Inspection Report i 50-327/86-68 findings on information contained in the Element Report.
Because of the relationship between this Element Report and Element Report 80503-SQN, the final determination on the adequacy of 80504-SQN will not be made until the NRC review of 80503-SQN is completed.
5.
Tracking of Corrective Actions and Commitments TVA's method of tracking open items resulting from its Employee Concern program was inspected by reviewing selected documents and discussions with TVA personnel.
Tracking system documents and procedures reviewed include the following: a.
ECTG Procedures C.3, " Corrective Action," Revision 3, March 14,1987, and A.3, " Employee Concerns Program Computer System (ECOS) Data Processing," Revision 3, March 14, 1987.
b.
ECTG Policy Statement 22, March 27, 1987, with corrective action plan flow chart, c.
Sequoyah Activities List #305, March 3,1987 (Computer Output).
d.
Corrective Action Tracking Report, Sequoyah, April 9, and April 15, 1987 (Manual System).
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n . . . . ' . , e.
TVA Corporate Commitment Tracking for ER 80101.
(Sample output data ' from the Corporate Commitment Tracking System dated April 9, 1987.)
The ECTG recently determined that corrective actions resulting from the employee concerns program are to be tracked on TVA's computerized TROI (Tracking and Reporting of Open Items) system.
This is a TVA corporate system which has the capability of accepting input and providing output at each nuclear plant site.
The TROI system will be used to track all CATDs (including the related CAPS) and other QA program deficiency , l documents resulting from the CATDs.
In addition, a computerized Sequoyah Activities List is being used to track.Sequoyah restart items, including the employee concern restart items.
Finally, for Element Report 80101, which refers to commitments made in TVA's Nuclear Performance Plan to satisfy an employee's concern, it has been verified that TVA's Corporate Commitment Tracking System is being used to track these commitments.
There appears to be a disconnect in the ECTG system established for tracking corrective actions from the separate tracking system established by the plant staff, which has a number of CATDs shown as " completed" (non-restart CATDs 80000-1, 80201-1, 80203-1, and 80203-2, and restart CATD 80303-2).
Yet there has been no formal notification to the ECTG that, as far as the plant is concerned, the CATDs are closed.
While it may be argued that the CATDs shown as completed require no corrective action, the ECTG needs the formal notification to complete its certifi-cation and closeout responsibilities.
Therefore, it is not consistent with ECTG procedures for the plant to indicate the status of a CATD as comoleted until after the ECTG verification and closeout effort is completed.
6.
Status of Corrective Actions a.
Restart Items The SQN plant's tracking system for restart CATO items resulting from the QA Element Reports showed the following schedule at the time of the inspection.
Element Scheduled Report CATD Completion Number Number Corrective Action Description Date 80101
Implement the dedication program for June 4, 1987 the Division of Nuclear Engineering restart scope 80303
Train electrical engineers for Complete Nuclear Engineering Procedures 3.1 and 9.1 - 19 - _ _ _ _
F i.
. ' . '- Element Scheduled Report CATD Completion Number Number Corrective Action Description Date 80501
Identify and document acceptable May 18, 1987* installations of safety-related instruments iequired for FSAR Chapter 15 events.
Initiate ECNs to correct any unacceptable installation.
Document seismic review.
Initiate CAQs as required.
- This date is to be revised based on TVA's decision during this NRC inspection to revise its previous corrective action plan.
b.
Non-restart Items Except a3 discussed above in Section 5 for CATDs 80000-1, 80201-1, 80203-1, and 80203-2, the completion dates have not yet been established by the plant staff for the majority of the non-restart CATD items resulting from the QA Element Reports.
The SQN plant staff tracking system showed the following non-restart items in the open status at the time of the inspection.
Element Report CATO Number Number Corrective Action Description 80101
Complete the Replacement Items Program 80201
Revise AI-14 80201
Same as 12304 SQN-1, -2 80202
Revise SQN-2 to provide for notifying the originating section of rejected / cancelled WRs i 80202
Revise M&AI-6 to include inspection instructions for running threads at couplings l 80303
Implement NQAM, Part II, Sec. 5.3A - Quality Control Inspector Training Program - Retrain QC 80303
Complete development of a training program for EEB calculations and train EEB employees 80402
Track the incomplete commitment made in response to concern XX-85-102-010 and j report status of the commitment '
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, , Element . Report CATO Number Number Corrective Action Description . l 80501
Identify and document acceptable installations { of safety-related instruments not required i for FSAR Chapter 15 events.
Initiate ECNs ' to cor>ect unacceptable installations 80503
Phase out the master drawing-list and use the DMS exclusively-80503
Implement the corrective action proposed by the DNE project records management and document control report.
Prepare directives and standards governing ONP document control and records 80503
Implement the ERIS program for timely DMS , update 80503'
Revise / implement AI-25, Part 1, SQEP-49, AI-23, and SQEP-39 80503
Revise AI-08 or issue a new procedure to establish controls of SQEP "As-constructed" originals.
Resolve SCR GENERI8602 - Legi-bility problems program to ensure compliance-l with programs and procedures.
80503
Voided by ECTG 80503
Same corrective action as 80503-5 7.
Overall Conclusions a.
Element Report Reviews A total of 15 quality assurance category final Element Reports were i reviewed and evaluated in part or in whole at the time of this NRC inspection.
The results of these reviews are summarized below.
l (1) SERs were prepared for the following three QA Element Reports after our initial meeting on these reports with the ECTG at Watts Bar during March 3-4, 1987.
80104-SQN 80205-SQN 80404-SQN ! - 21 - [ __ - .------------_ _--_-_------ _ ----------- _ - ---- - - -
_____ _ _ _ _ _ _ _ , ' N ,
,. % , e . , 'Y '(2): The SERB for the following four Element Reports will be prepared ' M ind issued based on the'results of this review and inspection.
80102-SQN 80303-SQN~ 80401-SQN 80402-SQN i .(3) Based on the inspection.results documented in this report and " understandings reached with the ECTG, SERs will be prepared and issued for the following Element Reports after our review of expected revisions to these reports incorporating other required information.
, , , "' 800%-SQN i .80101-SQN 80201-SQN .80203-SQN (4) The following' Element Reports will require additional information in writing from TVA before SERs can be written and issued.
80bCl-SQN - 80503-SQN ' 80504-SQN (May require revision subject to NRCs'eview'of r 80503-SQN) , (5) Element Report 30202-SQN was reviewed with the ECTG Et Watts Bar on March 3-5, 1987, and was found to require further' revision as documented in TVA minutes of that meeting.
Bdcause the indicated revision of this Element Report was not transit.itted to the NRC 'before or during this'. inspection, it will be reviewed during a future inspection.
b.
NRC Observations . (1) Element' Report Process To the extent examined to dats,s the MC considhrs the imple-mentation of ECTG instructions for conductit.g activities relative to the preparation of Element Reports to be generally acceptable, Further clarifications of the ECTG Elew nt Report review process, as discussed with the WBN ECTG during the Mar:ch 3-5, 1987 meeting, will be reviewed during a future visit to the site.
The clarifications related to when the Senior Review Panel sign-off on Element Report CATO corrective action indicate their review and approval; and the actir.h that. is being taken to ensure that. Element Reports previously transmitted to the NRC contain current CATD documents or have included dar.uments referenced as attached.
' Based on the conclusior.3 of this inspection, a number of Element Reports (80000, 80101, 80201, 80203, 80503) were viewed by the NRC inspectors as not containing complete ur accurate information i t - 22 - , . .. - ' _. - -
___ .,. with regard to the investigation conducted on the employee c'oncern.
, Therefore, management attention is required for improving the interface activities between SQN and ECTG personnel to ensure that information exchanged and investigations conducted will result in accurate, complete, and stand-alone Element Reports.
(2) Management Attitudes - Audits NRC observations recognized that SQN management attitudes towards auditors and audit findings, as viewed by the auditors interviewed, had improved in the last few months.
As a result,
it also was evident that the auditors' attitudes has improved concerning their contribution to ensuring the activities of SQN were consistent with licensee FSAR and Technical Specification commitments.
(3) Verification of Instrument Mountings NRC observations associated with Element Report 80501-SQN indicate further management attention is required for the following: the large number of deficiencies identified during verification of instrument mountings should have resulted in corrective action to institute a more formal QC inspection and engineering evaluation of this area of installation.
the practices utilized in the preparation and implementation of the engineering calculation instructions for field veri-fications and engineering reviews of as-built information on instrument mountings, which resulted in the numerous NRC identified deficiencies and their implications to other work, require management attention.
- the apparent inconsistencies and errors in determining which instruments are safety related or are necessary in case of FSAR Chapter 15 seismic events when compared to other applicable site procedures or resource documents like the
{ CSSC list require management attention.
c.
Corrective Actions ' The tracking of CATD corrective actions for pre-restart and post-restart Element Report concerns at the site and ECTG level was considered acceptable, except as follows.
The plant tracking system should not indicate that a CATD item is closed out until after the ECTG completes its followup verification or has agreed that no corrective action is required.
Because of the number of different tracking systems, TVA needs to ensure that procedures for each are followed and that the intent to now use the TVA computerized TROI system for the purpose of tracking j these corrective actions should be appropriately communicated to all affected organizations.
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