ML20203P369
| ML20203P369 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/21/1986 |
| From: | Belisle G, Julian C, Mcneil S, Runyan M, Walenga C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20203P355 | List: |
| References | |
| 50-327-86-12, 50-328-86-12, NUDOCS 8605070072 | |
| Download: ML20203P369 (26) | |
See also: IR 05000327/1986012
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UNITED STATES y
/jn3 Kf 44'o NUCLEAR REGULATORY COMMISSION
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[3 p REGION il .
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g' ,j ' 101 MARIETTA STREET, N.W,'_
- ~t ATLANT A, GEORGI A 30323
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Report Nos.: 150-327/86-12.and 50-328/86-12'
Licensee: Tennessee Valley Authority -
6N 38A' Lookout Place
-1101-Market Street
Chattanooga, TN 37402-2801
Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79
racility Name: Sequoyah 1 and 2
Inspection Conducted: February 10-14, 1986
Inspectors: /'
G. A. Belisle'si
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Date Signed
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S. A."McNeil ' t Date Signed
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M. F. Runyan [ Date Signed
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C. G. Walenga s
Date Signed
Approved by: Ch 4/Z //d/>
Date Sfgned
-C. A. .:uliart/ 8 ranch Chief
Divisian of Reactor Safety
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SUMMARY
- Scope: This spet tal, unannounced inspection entailed 133 inspector-hours at
corporate officer and on site in the area of quality assurance related
consnitments and ,oals delineated in the Corporate Nuclear Performance Plan,
the Sequoyah Nuciear Performance Plan, and Division of Quality Assurance (DQA)
personnel performance.
- Results: One violation was identified - Inadequate Record Controls.
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
Corporate Offices in Chattanooga
W. Andrews, Operations Quality Assurance (QA) Branch Manager
P. Border, Head, Browns Ferry Plant Evaluation Group
C. Chmielewski, Nuclear. Engineer, Nuclear Safety Staff
- J. Huston, Deputy Director, Division of Quality Assurance (DQA)
- R. Kelly, Director, DQA
. G. Killian -Branch Chief, Quality Audit Branch
R. Large, Quality Analysts (Training)
D. McCloud, Supervisor, Licensing Support Group
L. McCloud, Head, Watts Bar Plant Evaluation Group
R. Moore, Head, Sequoyah Plant' Evaluation Group
- R. Mullin, DQA
B. Roberts, Nuclear Engineer, Nuclear Safety Staff
C. Stinson, Supervisor, Quality Programs Training Unit
Sequoyah and Sequoyah Training Center
- H. Abercrombie, Sequoyah Site Director
- L. Alexander, Mechanical Supervisor, Modifications
J. Anderson, Quality Control (QC) Supervisor
W. Baker, Fire Protection Engineer
- R. Birchell, Compliance
- C. ' Brimer, Site Services Manager
D. Cowart, Supervisor, Quality Surveillance
M. Crane, Supervisor, Materials Unit
D. Craven, Supervisor, QA Staff
T. Frizzell, Supervisor, QA Training Section
M. Hall, Acting Support Services Supervisor
- J. Hamilton, Supervisor, Quality Engineering and Control Group
- G. Kirk, Compliance Supervisor
- S. Littrell, Environmental Qualification (EQ) Coordinator
R. Manley, Acting Supervisor, Planning and Scheduling
R. Merring, Acting Section Supervisor, Engineering Training
- R. Mooney, Supervisor, Systems Engineering Section
J. Naik, Supplemental Resources Manager, Modifications
- R. Olson, Modifications Manager
J. Owenby, Supervisor, Office of Engineering (OE)
- B. Patterson, Supervisor, Instrument Maintenance Section
M. Rinehart, Maintenance Planner
R. Rudman, Project Control Supervisor
L. Sain, Assistant Branch Chief, Training Branch
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- M. Sedlacik, Modifications Supervisor
J. Staley, Power Stores Supervisor
C.' Stutz,-Quality Engineer, QA
J. Traffanstedt, General Foreman
J. Walker, Modifications Scheduling Supervisor, Planning and Scheduling
- P. Wallace, Plant Manager
-J. Wheeler, Supervisor, Maintenance Scheduling
D. Widner, Modifications
A. Varner, Engineer, Quality Engineering and Control Group
J. Vineyard, Project Manager, OE
Other licensee employees contacted included technicians and office
personnel.
NRC Resident Inspectors
K. Jenison, Senior Resident Inspector
-L. Watson,-Resident Inspector
P. Harmon, Resident Inspector
- Attended exit interview
2. Exit Interview
The inspection scope and findings were suumarized on February 14, 1986, at
the corporate- offices and on site with those perst:ns indicated in the
paragraphs above. The inspector described the areas inspected and discussed
in detail the inspection findings listed below. No dissenting coments were
received from the licensee.
Violation - Inadequate Record Controls, paragraph 8.
The licensee did not. identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
.3. Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4. Unresolved Items.
Unresolved items were not identified during the inspection.
5. -Quality Assurance Review (General Background)
In correspondence dated September 17, 1985, the Executive Director of
Operations for the NRC notified the Chairman of the Board of Directors of
TVA that previous Systematic Assessment of Licensee Performance (SALP)
indicated significant and continuing weaknesses in TVA performance. General
areas of concern were also identified for which specific actions were
required to be addressed by TVA in their response to this letter.
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In correspondence dated December 1,1985, TVA responded to the September 17,
1985, request. This information was submitted as two volumes, the Corporate
Nuclear Performance Plan (Volume 1) and the Sequoyah Nuclear Performance
Plan (Volume 2).
In correspondence dated December 23, 1985, TVA stated that Volume 1 and 2
would be revised to reflect TVA's decision not to decentralize the QA
organization. TVA further stated that Volume 3, related to Browns Ferry,
would be submitted by February 17, 1986, and a Watts Bar Volume was under
consideration but a submittal date had not been established.
In correspondence dated February 4,1986, TVA stated that Volume 1 was being
reevaluated and based on this reevaluation Volume 1 was being rewritten . A
newly revised Volume 1 would be submitted at a later date.
This inspection reviewed 13 QA related items from Volume 1, DQA personnel
performance, and 24 QA related items fron Volume 2. The inspection results L
are discussed in the following paragraphs.
6. Inspection Items from Volume 1, Corporate Nuclear Performance Plan
a. Licensee and QA Functions were Elevated to a Direct Reporting
Relationship to the Office of Manager, Power and Engineering (P&E),
Paragraph 2.2.2.1(9)(1).
The licensee organization charts contained in the TVA Topical Report
(TVA-TR75-1A), Quality Assurance Program Description for Design,
Construction, and Operation of TVA Nuclear Power Plants, Revision 8,
identifies that DQA reports to the Office of Nuclear Power (NUC-PR)
which reports to the Manager of Power and Engineering. Revision 8 was
submitted to the NRC on September 7, 1984, and approved after certain
clarifications, on April 9,1985. Since April 1985, several changes
have occurred within DQA and NUC-PR. In correspondence dated
December 9, 1985, TVA requested a delay in submitting TVA-TR75-1A,
Revision 9, until May 1, 1986. This request was approved by the NRC on
January 13, 1986. Since January 1986, additional organizational
changes have been made within TVA. The inspectors reviewed draft
organizational charts which delineated that the Director of Nuclear
Quality Assurance reports to the Manager, Office of Nuclear Power. As
previously stated, Volume 1 is undergoing revision and Revision 9 to
TVA-TR75-1A has been delayed. Consequently, until these documents .can
be reviewed and TVA's organizational structure stabilizes, an
assessment could not be made in this specific area.
b. Manager QA Will Provide Corporate Oversight of QA Functions,
Decentralize to the Sites, and Strengthen Corporate Management in
Assurance of Quality, Paragraph 2.2.2.1.(9)(b).
Due to organizational changes, Volume I resubmittal, and TVA-TR75-1A,
Revision 9, transmittal delays, an assessment could not be made in this
area.
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c.- Corporate Team Headed by Manager, P&E, Whose First Priority Will be to
Establish Clear Duties, -Responsibilities, and Authority for Each
Organization. QA Manager is a Member of this Team, Paragraph
2.2.2.1(10).
In a memorandum (A02 860130 047) dated January 30, 1986, the Manager of
Nuclear Power directed the Office of Nuclear Power Managers to prepare
Responsibility and Accountability Profiles (RAPS). This is intended to
establish and maintain clear lines of responsibility, authority, and
accountability within TVA's nuclear organization. The RAPS are to be
used as the basis for realizing the functions and reorganization,
upgrading the job description system, and ultimately for evaluating the
performance of employees assigned to these positions. These RAPS are
scheduled to be completed for all management positions (M-1 to M-12) no
later than February 27, 1986. The inspectors interviewed selected DQA
as well as Office of Nuclear Power personnel and were informed that
RAPS were being written as required by the memorandum,
d. QA Training for Managers and Other Employees, Paragraph
2.2.2.2.(13)(g).
The Quality Training Group is comprised of the QC Training Section and
the QA Training Section. The QC Training Section has been functioning
for several years. The QA Training Section consists of a Quality
Programs- Training Unit (QPTU), an Audit and Surveillance Training Unit
(ASTU), and a Codes and Standards Training Unit (CSTU). The QA
Training Section Supervisor position was filled on February 3,1986.
The QPTU and CSTU supervisors had been previously filled. Recruiting
was underway for the ASTU Supervisor.
The inspector conducted discussions with the Supervisor, QA Training
Section and the Quality Analyst (training). During these discussions,
the inspector was informed that QA training had been incorporated into
ongoing training for managers. This training involved a one week
course in the following topics: plant specific codes and standards
(for Watts Bar and Sequoyah), Nuclear Plant Reliability Data System
(NPRDS), functions of the NRC, NRC regulations, identification and use
of regulatory guides, and QA/QC. This course was conducted in
November 1985, for four Sequoyah management personnel and was being
integrated into the Managers and Engineers Certification training.
Personnel previously undergoing manager training are also required to
participate in annual requalification. This is a two week course and
is scheduled to begin in March 1986. Two days are scheduled for
refresher courses in regulatory requirements. A total of ten Sequoyah
personnel and four Watts Bar personnel are scheduled for this
requalification training.
Additional QA training is being formulated to be included in General
Employee Training and specific discipline training.
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e. Indicators to Monitor Plant Performance. Quality Problem Isolation
Timeliness. Each Plant's Performance Will be Monitored at Monthly Top
Management (HTM) Meetings, Paragraph 2.2.2.5.
The inspectors reviewed MTM meeting agendas dated August 28, 1985;
September 9, 1985; October 25, 1985; November 15, 1985; January 3,
1986; and January 24, 1986. Typical personnel attending these meetings
included the DQA Director, Nuclear Unit Site Directors, Watts Bar
Project Manager, Office of Construction and Engineering Managers, and
the Nuclear Services Director. Each person was allotted time to
present key performance indicator charts and top priority potentially
significant safety issues. An attachment to the August 28 meeting
agenda presents guidelines for performance indicator charts. These
guidelines also state that presentations should include charts and
focus on data related to Licensee Event Reports / 10 CFR 50.55(e)
Reports, Corrective Action Reports (CARS), Conditions Adverse to
Quality (CAQs), personnel errors, unplanned scrams, audit findings,
NSRS recommendations, INP0 recommendations, and NRC violations.
Additional time was also allotted for special reports. The inspectors
concluded that these meetings appear to be more information status
oriented than performance oriented. During discussions with the Chief,
Nuclear Safety Staff, the inspectors were informed that MTM meetings
had been temporarily suspended by the Manager of Nuclear Power.
f. Integrated Comitment Tracking System, Escalation of QA Findings,
Paragraph 3.1 (page 3-3).
The Verification and Improvement Administration System (VIAS), a
computerized data base, will eventually provide TVA with an excellent
tool to manage the tracking and closure of identified conditions
adverse to quality. Currently, the information concerning QA
deficiencies in VIAS is incomplete in that the VIAS data base could not
be relied upon to provide all information relevant to deficiencies
that were found in the deficiency document packages. Some coments were
inserted without associated dates for the inputs. The use of internal
coments, which would have been useful in maintaining a complete
picture of closure activities, was very limited. All of the above
resulted in a system that presently leaves the reviewer without an
adequate picture of the chronological events leading up to the deficiency
closure for many of the deficiencies.
g. Sequoyah Will Have Full Implementation of Tracking NRC Commitments,
Paragraph 3.1 (page 3-5 and 3-6).
The Nuclear Licensing Staff (NLS) is tasked with the implementation of
the Corporate Commitment Tracking System (CCTS). According to a NLS
engineer in charge of the implementation of the CCTS, Sequoyah and
Watts Bar have completed a review of all NRC commitments and have had
the open commitments added to the CCTS. However, a procedure had not
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been drafted for the implementation of the CCTS and the use of TVA's QA
organization to conduct independent closure verification has not been
finalized. According to a NLS engineer, any closure of an NRC
comitment requires the NLS to receive written confirmation from the
NRC of its closure before the CCTS will be changed to indicate the
closure. Due to the planned revision to the TVA Corporate Performance
Plan, plans to finalize the whole CCTS program are being delayed,
h. Escalation of .QA Audit Findings, DQAI-104 Will Control Escalation
Policy, Paragraph 3.3 (page 3-8).
A review was conducted of TVA's QA corporate program to escalate the
closure of QA audit deviations in accordance with DQAI-104, Escalation
of Responsibility for Deviation Corrective Action, Revision 0, dated
9/25/85. Procedure DQAl-104 appears administratively adequate and is
being implemented. The effectiveness of the escalation program based
on the audit deviations reviewed appears to be weak for the following
reasons:
(1) QA verification followup, after scheduled comitment dates are
reached, is not timely in some instances, thus allowing further
delays before the failure to complete the corrective action is
identified.
Examples for 1:
QBF-A-84-0013-02 Comitment Date 12/31/85; Verification 1/28/86
QBF-A-84-0014-02 Commitment Date 12/31/85; Verification 1/24/86
QSQ-A-85-0001-01 Comitment Date 12/27/85; Verification 1/22/86
(2) The Director, DQA, does not have to act immediately to obtain
appropriate corrective action to escalated deviations if, in his
consideration, the deviation is not severe or important to the QA
program, licensee commitments, or safe operation. (Reference:
Section 6.5 of DQAI-104). The Director is permitted to delay
discussion on the item with line management until the next
scheduled quarterly meeting. Based on the items reviewed, Section 6.5 of
DQAI-104 produces another delay factor in obtaining corrective
action resolution from line management.
Examples for 2:
QBF-A-85-0015-01 Escalated 12/13/85; no further action noted.
QBL-A-85-0002-01 Escalated 11/22/85; no further action noted.
QBF-A-85-0008-01 Escalated 11/22/85; no further action noted.
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QBF-A-83-0207-04 Draft memo written on 6/11/85 but as of 1/9/86
memo never sent. Finally 2/6/86 an escalation
memo released.
QSQ-A-84-0014-02 Issued 11/2/84, escalated 10/9/85, finally on
1/29/86 a commitment date of 4/15/86 was
accepted through escalation process.
By allowing these delays, it implies that commitment dates are not
important. The last deficiency has been delayed to the point
that allowing two or three additional months appears
inappropriate.
(3) The use of the terms immediately, timely, and promptly are not
well defined and, as such, add confusion in reaching the
resolution of deficiencies by allowing individual interpretation
of the terms.
Examples for 3:
QBF-A-84-0013-2 Section 6.6 of DQAI-104 apparently applies as
of 1/29/86 but no memo to the Manager of
Nuclear Power has been found to have been
drafted.
QBF-A-85-0004-02, Section 6.6 of DQAI-104 apparently applies due
-03, -06 -07 to the changing of scheduled completion dates
since the Director, QA can only accept one
completion date due to an escalation. No memo
to Manager of Nuclear Power has been
considered though apparently required as late
as 12/31/85.
QBF-A-85-0009-01 Escalation memo issued 1/21/86 but QA engineer
initiated the escalation process on 12/18/85.
QSS-A-84-0018-01 Per VIAS, a second escalation to the Director,
QA had been done, the first, 8/21/85 and, the
second, 11/1/85. The second escalation
apparently should have been to the Manager of
Nuclear Power.
QSS-A-84-0016-03 Escalation memo issued on 2/7/86, yet on
1/17/86 escalation action was initiated.
QSS-A-84-0020-01 Records show that an undated memo to escalate
the deviation to the Manager of Nuclear Power
was drafted but never issued. However, there
now exists another escalation to the Director,
QA. New escalation memo dated 2/11/86 but
1/14/86 was date when verification was
completed.
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Conclusion
DQAI-104 appears adequate if DA management and line management would
require and take prompt action on item resolution. Prompt action
should imply that action is completed within a short period of time
such as within one week of initiation. When entering the escalation
phase, the Director, DQA needs to ensure that actions required by
DQA are completed in a timely manner.
List of QA Deviations Reviewed
Deviation No. Date Escalation Date(s)
OSS-A-81-0006-01 1/28/82 2/21/85
QBF-A-84-0013-02 7/13/84 6/6/85
QBF-A-84-0014-02 8/24/84 2/11/86
QBF-A-85-0004-02 4/5/85 5/31/85
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QBF-A-85-0009-01 7/3/85 1/21/86-
QBF-A-85-0014-04 8/15/85 1/16/86
QBF-A-85-0015-01 8/23/85 12/13/85
QSS-A-84-0018-01 10/5/84 11/1/85
QBL-A-85-0002-01 5/22/85 11/22/85
QBF-A-85-0008-01 4/1/85 11/22/85
QSS-A-85-0015-07 9/13/85 10/31/85
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QBF-A-85-0016-02 10/18/85 2/11/86
QSS-A-84-0016-03 8/24/84 11/26/85
QSS-A-84-0020-01 10/16/84 2/11/86
QBF-A-83-0207-04 6/23/84 2/6/86
QSS-A-85-0003-16 11/23/84 1/21/86
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Deviation No. Date Escalation Date(s)
QSQ-A-84-0014-02 11/2/84 10/9/85
QSQ-A-84-0014-03 11/2/84 10/9/85
QSQ-A-85-0001-01 1/16/85 9/11/85
QSQ-A-85-0008-01 6/27/85 1/29/86
QSS-A-84-0011-02 8/9/84 2/11/86
QSS-A-85-0006-03 3/22/85 1/17/86
QWB-A-85-0014-05 6/27/85 2/11/86
1. Office of Engineering (0E) and Office of Construction (0C) Procedures
to Formalize Escalation Process, Paragraph 3.3 (page 3-9) and Uniform
and Cohesive Method Needed throughout P&E for Escalating Unresolved QA
Problems. Policy Directive By December 31, 1985, Paragraph 3.3 (page
3-11).
In a memorandum (L20 851224 986) dated December 27, 1985, from the
Manager of Power and Engineering to those listed, a policy regarding
escalation of responsibility for resolving Conditions Adverse to
Quality (CAQs) was discussed. Basically this memorandum requires the
Nuclear Safety Board, OE, OC, all sites, and DQA to submit implementing
procedures for resolving CAQs to DQA for review by January 31, 1986.
(DQA's procedure, DQAI-104 was issued September 25, 1985). The DQA
review of these procedures was scheduled to be completed by
February 14, 1986. The inspectors reviewed these draft procedures and
noted that DQA had made some substantive coments.
All groups were scheduled to implement these procedures by March 15,
1986, and they were to be fully implemented (effective) by April 1,
1986.
TVA has not yet implemented improved escalation programs for most
organizations within TVA. However, draft procedures have been written
and reviewed. The finalization and subsequent implementation has been
scheduled for March 15 and April 1,1985, respectively. Administra-
tively the procedures appear adequate. The effectiver.ess of implemen-
tation cannot be determined at this time.
Documents reviewed:
QMS-P 65.07, OE Procedure for Escalation of QA Program Deficiencies
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, OC QABP 3.2, Deviation Reports, Management Requests, and Stop Work ,
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Orders, Revision 1
! OESP 7.6, Reporting and Disposition of Deviations, Revision 0
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Memo R. J. Mullin to K. W. Whitt, February 4, 1986, Subject:
Applicability of the Office of Nuclear Power (0P) Policy on the
Escalation'of Conditions Adverse to Quality.
Policy Statement of H. G. Parris, Manager of P&E, dated December 27,
1985, Policy Regarding Escalation of Responsibility for Resolving
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TVA Nuclear Performance Plan Volume 1 Corporate (November 1,1985)
j. Revision of Topical Report, Revision 9 Will Define QA Program
This revision is not scheduled to be submitted for NRC review and
approval until May 1, 1986. Discussions with DQA personnel identified
that TVA may request an extension to this date.
- k. Managers, P&E Will Issue Directions and Monitor (Through DQA) the Site
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Program Through Overview Audits of OE and OC, Paragraph 3.3 (page
3-10).
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The DQA reorganization and overview of the site program through
overview audits of OE and OC was cancelled.
i 1. Assign QA Site Representatives to Site Director and Submit %
Organizational Changes to the NRC, Paragraph 5 (page 5-2 Items 12 & 14)
This reorganization of QA to put audit personnel on site has been
cancelled. ,
m. Readiness Review of QA Will be Conducted Prior to Restart and Quarterly
Meetings Between Site Director and QA Manager, Paragraph 6.1 (page 6.1
, - 38).
i A memorandum (A02 851113 016) from the Site Director, Watts Bar, to the
, Manager of Power and Engineering (Nuclear) dated November 14, 1985,
states the results of an operational readiness review conducted at
Sequoyah Nuclear Plant during the week of October 28, 1985. As stated
in the memorandum, the object was to perform an independent assessment
of the self-evaluation and the resulting efforts initiated by Sequoyah
. site management in preparation for returning the units to service. The
review concentrated on the following six primary areas; management
goals and objectives, management structure, quality assurance and
management control, radiological emergency planning, regulatory
performance operation activities, and maintenance. This review
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identified areas requiring improvement, areas having significant
strengths, and two items requiring correction prior to restart. These
two . items involved training for the Shif t Technical Advisor in the
Safety Parameter Display System and review of outstanding
preoperational test open items and a determination made that their
status does not constitute an unreviewed safety question.
Quarterly meetings between the Site Director and the QA Manager have
been ongoing. This was determined by direct questioning of QA
personnel.
7 .- DQA Personnel Performance
The inspector conducted interviews with Seqas <>a QA personnel and corporate
DQA personnel relative to problem identificac on and closure. All personnel
interviewed stated that once an item has been identified by the various
established mechanisms (site personnel identify items by Discrepancy Reports
(DRs) or Corrective Action Reports (CARS) and audit persnnnel identify items
by audit findings), then the item can only be closed by verification of
corrective action. All personnel interviewed stated that they could not
recollect where items were closed without verification of corrective
actions. Corporate DQA personnel perform audits of corrective actions as
required by DQA procedures. Audit findings have been identified where site
QA personnel misclassified findings as DRs when by procedure they should
have been CARS. One example was identified at Browns Ferry. Examples of
misclassification were not identified at Watts Bar. Corrective actions have
been taken by site personnel to prevent recurrence of this problem.
. Site management has set goals to reduce the number of findings identified by
site QA personnel and DQA personnel. These goals indicate that site
management hopes to improve site operations; however, neither site QA
personnel nor DQA personnel feel restricted by these goals and categorically
stated that problems, if found, would be identified.
8. Inspector Items From Volume 2, Sequoyah Nuclear Performance Plan (SNPP)
a. Five Goals: Management Controls /QA, Introduction (page 4) >
The five goals delineated in the introduction pertaining to management
controls and quality assurance are general statements which encompass
all of the remaining items inspected and, as such, were not ,
individually verified. These goals remain as long term objectives
toward which, based on the specific inspection items described below,
some progress has been made, but for which, additional work remains to
be completed.
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b. EQ Binders Subjected to Management or QC Review, Section 1 (page 3)
The quality review of EQ binders was conducted at TVA-Knoxville as a
combined effort of TVA and its EQ consultant, Westec, prior to delivery
of the binders to Sequoyah. A member of the TVA QA staff participated
in the review. No further assessment could be made in this area.
c. Timely Responses for Deficiencies, Section 3-1.1.5 (page 4)
The goal of assigning responsibility to a specific supervisor for
responses to deficiencies has not yet been realized, though some
progress has been made. A January 30, 1986, letter (LP 6N 38A-C) from
S. A. White, Manager of Nuclear Power, to the Office of Nuclear
Managers delineated a formal system for generating responsibility and
accountability profiles for each manager. This general action may be
perceived as a first step to solving a long term problem at TVA of a
lack of accountability for internal deficiencies.
d. Additional Staffing, Section 3-2.4.2(a) (page 12)
The licensee states in section 3-2.4.2(a), 3-4.11.1, and 3-4.11.2(c)
that the root cause of poor performance of modifications and the outstanding
nadifications backlog was due to use of too many craftsmen of limited
experience in the performance of the modifications. This overload of
craftsmen constrained the ability of personnel to properly and
cohesively perform modifications, especially in the constricted work
areas found in the plant. The licensee decided that the quality and
control of modification work being performed could be significantly
improved by reducing the total number of craftsmen working on a
modification, by improving the ratio of supervisors to craftsmen, and
by closing, consolidating, or cancelling over 30 percent of the proposed
workplans (those apparently lacking any safety significance).
The inspector identified that the licensee had indeed reduced the
number of craftsmen from a total of 1150 to less than 250 permanent
employees during nonoutage periods and had made provisions to augment
the staff to approximately 400 craftsmen during outages. The
additional personnel were generally hired for the duration of the
outage. Also, the inspector verified that the licensee had reduced the
total number of work plans by over 30 percent.
Due to the large scope and limited time provided for this inspection,
the safety significance of the cancelled workplans and the effects of
the staff reductions on the quality and control of plant modifications
could not be evaluated.
e. Plant Modifications, Section 3-2.4.2.(b) (page 13)
The licensee stated that to improve planning modifications, a goal
would be set to hire six implementation estimators by January 1986.
These estimators would be used to improve front-end decision making and
.
.
13
planning for major modifications. Additionally, the scheduling of
major modifications would be based on an improved estimate of
implementation requirements resulting in a more realistic modification
schedule.
The inspector determined that only three out of six of the
implementation estimator positions were filled (two permanent employees
and one contract employee). The other three positions were not
scheduled to be filled due to changes being made to the job selection
criteria. Additionally, the licensee had not issued the procedure for
performing modification estimates though it had been craf ted in
August 1985 and distributed for comment in September 1985.
The scheduling of modifications did not appear to be currently based on
these " improved estimates" as the licensee was undergoing severe
scheduling perturbations, generally subjugating all previously planned
modifications to upcoming environmental qualifications work.
f. SR0 Assigned to QC, Section 3-2.4.5(a) (page 16)
The licensee stated that an SR0 would be assigned to the QA Staff. The
inspector determined that an SR0 was assigned to the plant Quality
Surveillance Section on August 19, 1985. Additionally, adequate
provisions had been made to periodically rotate this SR0 into line
operations positions for short periods to permit the maintenance of an
active license. However, official plans have not been developed to
permit the continuation of this program past the initial one year
assignment.
g. QA Staff Hiring Expertise, Section 3-2.4.5(b) (page 16)
The inspector identified that the licensee's past QA surveillance staff
hiring practices were consistent with 3-2.4.5(b) in that they did place
some emphasis on previous experience and expertise in hiring personnel.
Additional personnel have not been hired for the surveillance section
since that time.
h. QA Training for QC, Attachment ES-1.3
A document entitled Quality Control and Nondestructive Examination
On-the-Job Training Manual was issued June 17, 1985, based on the
guidelines of INP0 TQ-501, Development and Implementation of On-the-Job
Training. The training manual divides QC inspectors into three groups
- electrical, and instrumentation and control; mechanical-
nondestructive examination; and mechanical-civil. The format of the
manual is question / answer and signoffs of performance factors.
Sequoyah has started this program informally but is awaiting
confirmation from the corporate staff prior to formal implementation.
l
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l
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14 ,
,
1. Training Managers and Engineers, Attachment 2.3.2
'
The Managers and Engineers Pressurized Water Reactor (PWR)
Certification Training Program was started in 1981 and to date four
- classes have been completed. A fifth class comprising eight students
'
is -in progress. The inspector reviewed the revised training manual
entitled Managers and Engineers Certification Training Program,
Revision 1, dated November 30, 1985, and interviewed several personnel
.
.who; had completed at least some portion of the training. All evidence
i suggested that this has been a high quality training program.
j. Training QA/QC Personnel, Attachment 2.4.3
This statement of the training status of selected key personnel is
t still accurate. Continued training will be provided on a priority and
availability basis. ,
'
i- k. Reduce Tiering of Procedures (QA/QC Procedures), Section 3-3.2.3 (page
22)
The inspector determined that the reduction of tiering in plant QA/QC i
procedures as described in 3- 3.2.3(c) has been negligible. The L
L licensee asserts that a large-scale revision project is being con-
sidered, though start or completion dates have not apparently been
established.
1. Management Appraisal System, Section 3-3.3.3 (page 25)
This statement that the rating and pay of managers will depend on [
performance against plant objectives beginning in 1986 is slightly
misleading in that this rating system had been in place prior to 1986, t
e However, it has been reemphasized and formalized for use this year.
i SQA-129, Objectives in Plant Operation, Revision 5, dated January 2,
1986, expands and upgrades the annual statement of goals for each
! management level position. The rating and pay of managers will now be
e
affected to a larger extent by performance against factors delineated
- in SQA-129.
m. Plant.QA Goals - Monthly Report, Section 3-3.4.1 (page 27)
i
! The inspector verified that the Monthly Report is being developed and -
disseminated by the licensee in order to formally trend plant goals
against the performance of each plant organizational unit.
n.- Increased Surveillance Activity, Section 3-3.4.2 (page 27)
< In November 1984,-the QA staff employed three surveillance inspectors.
Since then two have left and five have been hired, making a total of
. six. Of the new hirees, three were selected from line organizations
(Operations, Chemistry, Instrument and Control) and two from QC.
l
. , . _ - . _ . . _ - , _ _ _ _ . . _ . _ _ . , _ _ , , _ . _ . _ _ . . . , _ . _ . _ . . , _ , . _ _ _ _ . _ . _ _ . . , , _ _ . _ . _ _ _ _ . . _ . . _ . _ . . _ . . _ _ _
_
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15
The inspector reviewed the training manual for the new observation
training program. Introduction to Observation Training, Revision 1,
issued October 24, 1985, was written by the corporate staff and
contains a twelve page lesson plan plus appendices. Training is
scheduled to begin in the near future.
Only one management review guideline has been written since the
issuance of the SNPP. The guideline for post maintenance testing was
issued December 26, 1985. Thirty-five guidelines have been developed
to date with fifty-one scheduled for future development.
o. Corrective Action, Section 3-3.5 (page 27)
Daily staff meetings are held each workday at 8:15 a.m. The Plant
Manager meets with key plant managers each Wednesday at 11:00 a.m. The
plant QA Supervisor meets with the Site Director on a monthly basis as
stated.
The Nuclear Safety Monthly Top Management (MTM) meetings for February
and March have been cancelled apparently due to the perception that
they have not been productive. This is also discussed in paragraph
6.e. A letter (LP 6N 37A-C) from C. C. Mason, Deputy Manager of
Nuclear Power, dated February 4,1986, states that further direction
regarding periodic reporting of performance indicators will be included
in the Policy and Directives Manual.
Quarterly corrective action meetings were held June 18, 1985,
September 19, 1985, and January 28, 1986, the latter meeting delayed
presumably due to the holiday vacation season. Minutes from these
meetings describe what appears to be a serious appraisal of the status
of Corrective Action Reports (CAR) and other tracking vehicles.
A new procedure was developed which requires the automatic escalation
of deviations to higher levels of management when timeliness is
inadequate. The inspector reviewed DQAl-104, Escalation of
Responsibility for Deviation Corrective Action, Revision 0, issued
September 25, 1985. This procedure is discussed in paragraph 6.h.
Managers have been instructed on an informal basis to become more
involved in working level activities of their organization. Imple-
mentation of this goal was not assessed during this inspection. The
Site Manager's goals for management's corrective action performance
is delineated in procedure SQA-129 as discussed in paragraph 8.1. The
policy goal of arranging meetings between the Site Manager and/or the
Plant Manager with employees responsible for NRC violations is familiar
to the Compliance Supervisor but such a meeting has not as yet been
arranged.
As a result of the general actions described, TVA claimed that the
average age of CARS is trending downward. However, this can be a
misleading statistic. If several new CARS are opened in a short period
k
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,
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16
.
of time, the average age decreases without an accompanying effort to
close out old CARS. QA staff personnel indicated that a different
performance factor may be considered.
Sequoyah has encountered problems with the handling of nonconformance
reports (NCR) involving multiple organizations. SQA-118. Handling of
Nonconformance Reports or Conditions Adverse to Quality Received from
Office of Engineering, Revision 6, was issued October 7, 1985.
Attachment 1 to this procedure was revised to include an immediate
assessment of the safety significance of the deficiency to ensure that
it is properly prioritized. Another procedure change was made to OE
Procedure OEP-17, Corrective Action, Revision 2, to require interface
coordination between the OE and the site. Revisions were made to
OEP-17 as stated in the SNPP to require prompt notification of either
the Site Director or plant operations management for NCRs which involve
an immediate operability problem. Attachment 5 to OEP-17 was revised
to require a generic condition elicited by NRC to be translated into a
Problem Identification Report (PIR) or Significant Condition Report
(SCR) in two weeks. This effort should improve the timeliness of the f'
review of NCRs for applicability to other TVA nuclear plants. *
A recent site QA survey was conducted to assess compliance with the new.
NCR procedural controls. Survey 21-85-P-014, Compliance Visits, s
Audits, and Inspections, was issued October 7, 1985, and did not
identify deficiencies in this area. J
Training was conducted for OE personnel and others affected on the
proper disposition of SCRs. The inspector reviewed attendance. sheets
which indicated that three li hour training sessions were held
October 17, 1985, at Sequoyah. This date met the commitment made in
the SNPP to complete this training no later than November 27, 1985.
Likewise, training for OE personnel on the revised OEP-17 procedure was
concluded by November 1985 as committed.
The inspector verified that the OE Quality Management Staff has
increased the depth and frequency of verification activities to monitor
OE compliance with procedural requirements regarding Condition Adverse .
to Quality (CAQ) reports. 01
p. Plant QA Staff, Section 3-3.6 (page 32)
The inspector determined that the following statements from the SNPP
were representative of the facts:
3-3.6.2 Involvement
The plant QA Staff is integrally involved in all aspects of
nuclear safety-related operations. For example:
(a) The QA Supervisor is a member of the Plant Operations
, Review Committee (PORC).
.
17
.
(b) All safety-related instructions, modification work
plans, and MRs receive a prework Plant QA Staff Review.
(c) The Plant QA Staff has free access to all records and
participates in meetings relevant to its activities.
Further inspector review of plant QA staffing identified that the
licensee was employing the number of QA staff personnel as described
in section 3-3.6.3 of the SNPP. The staff appears to Dossess the
knowledge and experience to adequately conduct the performance of it's
functions. Though licensee asserts in this section that additional
inspectors may be borrowed from other plants during outages, evidence
was not provided by the licensee regarding the use of additional
inspectors from other TVA plants, though the licensee was in an
extended outage and was performing extensive environmental
qualifications modifications.
An inspection of the licensee was performed regarding tfie following QA/QC
qualification goals provided in the SNPP:
3-3.6.4 Qualifications
(a) The qualifications of the staff continue to be upgraded.
Whenever possible, highly qualified line personnel are
considered for positions with the QA Staff to take
advantage of their valuable technical expertise. For
example, over the last year, the Surveillance Section
has hired experienced maintenance and chemistry
personnel, and an SR0 has been assigned to the section
on long-term loan.
(b) QC inspectors are required to successfully complete a
rigorous and formal training program involving classroom
lectures, structured laboratory exercises, and
on-the-job (0JT) training. The CJT portion of this
training is being restructured to meet INP0
recommendations. TVA plans to seek accreditation for
the QC inspector training program if INP0 provides for
such accreditation.
(c) Consideration is being given to the rotation of key
managers into line positions during the refueling
outages to increase their knowledge of plant systems and
of plant maintenance / modification activities.
-
9,,j'-
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.
, ,
18
,
-
.(.
The inspector identified the folicwing:
(1) The QA , Staff qualification upgrade program through hiring
individJals with expertise was stagnant. Qualified line personnel
had,not been placed in QA positions since the issuance of the SNPP
though there have been 3 QA Staff positions that have been vacant
the entire time. Additionally, no program exists to improve or
maintain the qualifications of current QA Staff members for
exatr91e, through refresher training.
(2) The formal training program consists of coursework at the -
licensee's training center, followed by selected 0JT exercises.
The qualifying inspector is not normally. required to perform all
of the 0JT qualification factors as thlicensee usually gives the
inspector credit for previous work expedience. The 0JT training
program was issued on June 17, 1985, prior to the issuance of the
performance plan.
(3) INP0 accreditation for this training progran apparently has. not
been actively pursued as' the licensee is curfently unaware whether
INP0 can provide such accreditation.
(4) QA/QC managers have not been placed in line positions during
outages. The licensee stated that this was due to the additional
QA/QC work load imposed.
l The inspector ' identified that the licensee's description of the QA
organization in section 3-3.6.5 was accurate at the time of the inspection.
q. Missed Surveillance, Section 3-4.6.3 (page 42)
The inspector verified that special performance of surveillance
instructions (SI) are stamped as stated in the text. A computer
program is used to schedule future surveillance tests and to compute
the next required date independent of performance dates unless the
previous performance was early. Unit 2 SI folders are color coded
,
green; Unit 1, red. The inspector reviewed several checksheets
involved in the review of less frequent sis. All sis of periodicity
one year or greater were reviewed, The checksheets implied a
comprehensive review. -
r. Modification Program, Sectto -4 (page 50)
The licensee asserted in section 3-4.11.1(c) that the Superintendent of
Operations and Engineering and the Superintendent of Maintenance were
each reviewing, approving, and prioritizing every proposed plant
change. 'Rc inspector reviewed the licensee's procedure governino
modifications approval AI-19 (Part III), Plant Modifications:
Modification Requests, Revision 12. The procedure did not require the
approval of both superintendents but either one. Additionally, the
inspector determined that these superintendents were assigning blocks
A
\
f
8 7 9
M__-.-._-.--__--_.-.-.-_----..---
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19
of days during which they desired the modifications to be performed,
whereas the engineers of the Planning and Scheduling Section were
actually assigning the priority (i.e., priority 1 through 9) to the
modifications proposed for each block.
The inspector determined that an engineering change notice (ECN) task
force (3-4.11.2(b)) was manned in August 1985 and assigned the function
of closing out the backlog of completed, but not closed ECNs. A
procedure MODL-A23 was issued on March 29, 1985 to provide guidance for
conducting t'ne closeout process. In October 1985 the task force was >
redirected to initially close only aspects of each ECN that were safety
related. This process is still continuing. Af ter all safety
significant aspects are complete, the task force is directed to
complete the closures of the backlogged ECNs.
Though the task force was assigned to close only the ECN backlog, all
ECNs that have been subsequently completed have also been assigned to
this group for closure rather than to the engineer responsible for the
ECN performing the closure. Consequently, the backlog of ECNs
requiring closure is increasing steadily, whereas very few ECNs have
been entirely closed by the task force as demonstrated below:
August 1985 December 1985 January 1986
Complete Modifications 785 834 886
Closed Modifications 206 224 224
The licensee asserts that the current backlog of ECNs should be
entirely closed out approximately 38 weeks to one year after unit
startup.
The inspector verified that the licensee's Project Engineering Group
was reviewing all major design changes and that the design engineers
had been relocated to the site to assist in correcting problems noted
with the pre-implementation review of design packages (5 4.11.3(a) and
(b)).
s. Post Modification Testing, Sections 3-4.12 and 3-4.14.3 (pages 51, 57)
The inspector reviewed the following licensee procedures to verify the
incorporation of planned improvements to the post modification
functional test program.
AI-7 Recorder Charts and Quality Assurance Records, Revision 37
AI-19 (Part IV), Plant Modifications: After Licensing,
Revision 13.
These procedures were found to have been appropriately revised to
clearly and succinctly reflect the desired guidance. However, these
procedures were revised to incorporate this guidance prior to the
issuance of the SNPP; AI-7 on April 19, 1985, and AI-9 on June 7, 1985.
__ ._, _ _ , _
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20
In 3-4.12 the licensee also took credit for self-appraised, significant
improvement in the adequacy of the post-modification functional tests
during the period of 1979 through 1985. The licensee especially noted
the improved adequacy of the functional test instructions for the
motor-operated valves (MOVs). But in inspection report 50-327/85-14
the NRC noted that "during the conduct of ... testing, the limitorque
motor tripped on overload as opposed to the torque switch as specified
in the procedure. Investigation ... determined that a jumper was
installed ... which prevented the torque switch from operating. This
jumper should have been removed during the performance of the work plan
... prior to turning the valve over ... for testing." This incident
necessitated the licensee's revision of the functional tests in order
to verify the correct wiring in the valves yet to be tested.
t. QC Training, Section 3-4.13.3(d) (page 55)
System orientation training was conducted for 21 QC inspectors between
June and August, 1985. This training is now part of the QC inspector
certification process. The inspector reviewed the course manual, Plant
Systems Training Module 1 SQN PWR Introduction, which appeared
adequate.
u. QA/QC Training, Section 3-4.13.6 (page 56)
A schedule had been generated describing a four week technical training
program for newly hired technical staff personnel. This training
program was scheduled to begin January 27, 1986, but was delayed when
the site could not release the scheduled personnel. The long term goal
is to hold ten classes within the next 18 months with approximately 20
students per class. The course is designed for personnel with a
college degree but will probably include non-degreed personnel from
time to time. A course manual has not been developed; however, the
inspector reviewed lesson plans which appeared adequate in scope.
v. Procurement, Section 3-4.20 (page 63)
With respect to the six specific statements made in the text, the
following was identified:
4.20.1 - A long range procurement training plan scheduled training
sessions from February through October 1985, covering the QA
procurement program, preparation of specifications, and Public Law
98-72. For various reasons, the schedule could not be met. To
date, two of the scheduled training sessions, for Modifications
and Plant Engineers have not been completed. The inspector
reviewed attendance records for various completed training
sessions.
..
21
4.20.2 - Actions to streamline the procurement approval cycle have
included increasing the dollar amount certain supervisors can
approve without upper management concurrence and the elimination
of selected procurement document review requirements.
4.20.3 - Increasing the use of indefinite quantity term (IQT)
contracts has been an informal effort only; however, based on
lists of current IQT contracts provided to the inspector, it
appears that the use of IQT contracts is heavily emphasized.
4.20.4 - The most recent figures show that over the last six
months, emergency procurement requests comprised between 7 and 14
percent of the total procurement requests. A year ago, emergency
procurement requests comprised between 25 and 51 percent of the
total procurement requests.
'
4.20.5 - According to a Procurement Group Schedule and Plan,
various specific actions should take place by March 3,1986. The
,
first major step will be the transfer of OE procurement engineers
to the site, which is now scheduled to occur on February 17, 1986.
Other actions include various training sessions for the new
procurement engineers and the revision of affected procedures.
4.20.6 - The Central Office revised the Nuclear Quality Assurance
Manual (NQAM) Section 2.1, Procurement of Materials, Components,
Spare Parts, and Services, on December 23, 1985. Sequoyah is
therefore committed to implement this change by March 23, 1986,
and will do so by revising SQA-45, Quality Control of Materials
and Parts and Services, and AI-11, Receipt Inspection,
Nonconforming Items, QA Level / Description Changes and
Substitutions. These two revisions are currently in typing and
the connitment date should be met.
w. Measuring and Test Equipment (M&TE) Out of Tolerance, Section 3-6.1.1
(page 75)
The inspector reviewed the latest Monthly Progress Report on M&TE
Program letter dated January 16, 1986, which indicated that the average
time to complete evaluations of out-of-tolerance M&TE had decreased to
22.4 days. This letter and statistics provide positive evidence that
the licensee continued to address this problem after the initial
six-month reporting period expired in November 1985.
Within the SNPP review, one violation was identified. During the modification and
post modification testing review, the inspector also selected the following
preoperational tests for review:
,
, Test Unit Title
W-6.1B 2 SIS Accumulators and Related System
Performance Test
_ . _ _ . . . , _ _ , _ , , . . , . , _ _ _ _ . . . _ , , , _ _
. .- .- .. -- - -
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22
W-6.1D 2 SIS Safety Injection Pump and Related
Injection System Performance Test
-
W-6.1A3 2 SIS Integrated Check Valve Flow and
Integrity
W-6.1F 2 Integrated Engineering Safeguards
Actuation
W-6.2 2 Upper Head Injection System
W-8.1B 2 Reactor Protection System Operational
Time Response Test
W-8.5 2 Reactor Plant System Setpoint Verifi-
cation
W-9.1 2 Control Rod Drive Mechanism Timing
. W-10.1 2 Automatic Reactor Control Systems ,
W-10.2 2 Automatic Steam Generator Level Control
System
'
W-10.4 2 Initial Turbine Roll
'
W-10.5 1 Dynamic Automatic Steam Pump Control
System
W-11.1 2 Nuclear Instrumentation System
W-11.3 2 Incore Thermocouples and RTO Cross
Calibration
W-11.7 2 Calibration of Steam and Feed Water Flow
Instrumentation at Power
W-11.10 2 Reactor Startup Adjustments
W-11.10 1 Reactor Startup Adjustmen'.s
W-10.1 1 Automatic Reactor Control Systems
W-10.1 1 Automatic Steam level Generator Level
Control System
During the onsite inspection and in telephone conversations conducted with
licensee personnel on February 25, 26, and 27,1986, the inspector was
informed that all preoperational tests had been signed by the test director,
- . - - - - .- - ,_ - -
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,' 23
!
_
several had been signed off by the NSSS supplier, Westinghouse, most had
been signed off by OE, and none were signed by the plant superintendent.
The lack of preoperational test review completion was identified by the
licensee as described in paragraph 6.m. above. Completion of the review
and approval of all preoperational tests was identified by the licensee as
an item requiring resolution prior to restart. NRC will follow up this
item as Inspector Follow-up Item 327, 328/86-12-02. Results of the
inspection and subsequent conversations is tabulated in the following:
Test Dir. Westinghouse OE
Test Signoff Signoff Signoff
W-6.1B (2) 12/17/80 12/19/80* 09/03/81
W-6.1D (2) 10/30/80 11/11/80* 08/03/81
W-6.1A3(2) 05/08/81 05/08/81* 01/13/86
W-6.1F(2) 07/10/81 07/09/81* 09/21/81
W-6.2 (2) 10/31/80 10/31/80* 12/12/83
,
W-8.18 (2) 06/05/81 06/11/81* 08/24/81
,
W-8.5 (2) 04/22/82 08/10/83 01/09/86
W-9.1 (2) 09/14/81 09/17/81* 02/26/82
W-10.1(2) 03/02/82 03/09/82* 01/08/86
.
W-10.2 (2) 03/26/82 08/16/83 01/13/86
W-10.4 (2) 12/30/81 12/31/81* 10/24/83
W-10.5 (1) 10/31/80 12/08/80* 02/05/81
W-11.1 (2) 05/15/81 05/28/81* 07/27/81
W-11.3 (2) 05/08/81 05/11/81* 09/10/81
W-11.7(2) 07/08/82 08/16/83 01/24/86
W-11.10(2) 02/17/84
W-11.10(1) 09/22/81 09/16/82 01/22/86
W-10.1 (1) 11/12/80 01/07/81* 02/12/81
W-10.2 (1) 12/24/80 02/31/81* 01/22/86
- Indicates that document was forwarded to Westinghouse for review and
approval. As of the date of this inspection, no response has been
received.
. , .. .- _ - ___ _ - .-. - . ..
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24
10 CFR 50, Appendix B, Criterion XVII, requires that sufficient records
shall be maintained to furnish evidence of activities affecting quality,
including the results of reviews, inspections and tests. Additionally,
records shall be identifiable and retrievable. The licensee shall establish
requirements for record retention including location.
TVA Topical Report, Table 17D-3 states that the licensee comits to
maintaining and controlling quality assurance records in accordance with
Regulatory Guide 1.88, (Revision 2), October 1976, Collection, Storage and
Maintenance of Nuclear Power Plant Quality Assurance Records. One exception
is stated in that the licensee is permitted to follow the fire protection
guidance of NFPA 232-1975 for Class 1 records or ANSI N45.2.9. When NFPA
232 is used, he must perform an annual worst case fire load surveys to
confirm the validity of the licensee's initial fire load analysis.
The inspectors performed a review of the licensee procedure AI-7, Recorder
Charts and Quality Assurance Records, Revision 37, the Nuclear Operations
Quality Assurance Manual, the previous completed fire load survey, and an
examination of one storage area located outside of the vault in which
preoperational test records were stored. This evaluation resulted in the
following:
The inspectors identified that the preoperational test records used to
verify the operability of various Unit 1 and Unit 2 reactor safety
systems (including safety injection, rod control, reactor protection,
nuclear instrumentation, and engineered safety feature actuation
systems) were not being controlled or stored in accordance with the
commitments of the licensee's Topical Report or with 10 CFR 50,
Appendix B, Criterion XVII. The following were noted in the control of
these preoperational tests:
(1) The records were not being stored in an predetermined, approved
storage location as required by ANSI N45.2.9, Section 5.2.
(2) The records were not stored in accordance with the guidance
provided by Sections 5.3 or 5.5 of ANSI N45.2.9 as there was no
filing system for these records, no access control to the records
including any methods to prevent unauthorized personnel access to
guard against thef t or vandalism, no control of or accountability
for the records removed from the storage location, and no method
to verify that the records were the actual original records.
(3) The records did not meet the fire protection requirements of
either ANSI N45.2.9 or NFPA 232 as they were being stored in a
non-fireproof cabinet, there were no dual official record copies
kept at any other location, either on or off site, and no fire
load analysis of this storage location had ever been conducted.
(4) The licensee had not specified any predetermined storage locations
for quality assurance records.
The failure to adequately control quality assurance records is
identified as Violation 327, 328/86-12-01.
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25
Three additional problems were identified with the preoperational test
records previously referenced and are described below:
Results of the Unit 2 preoperational test W-11.7, Calibration of Steam
and Feedwater Flow Instrumentation at Power were out of the allowable
acceptance criteria and the zerc power portion of the test had been
performed utilizing test equipment that had not been properly
backfilled or calibrated. The licensee acknowledged in the test
summary that the results did not meet the acceptance criteria and even
could not be made to do so by manipulating the test data through time
averaging. The licensee did not repeat the test but rather accepted
the test results as did Westinghouse in their post-testing review. The
senior resident inspector is evaluating this problem.
The following tests had deficiencies noted in the interim review and
approval report that were required to be closed prior to unit startup
after the first refueling outage. These deficiencies are just now
being closed.
Units 1 and 2: W-10.1, Automatic Reactor Control System
Fifteen of these 19 preoperational test results have not as yet been
reviewed by Westinghouse as required by Section 14.2.1.2 of the
Sequoyah Final Safety Analysis Report (FSAR). Though four of these
test results had received Westinghouse review by 1983, they still had
not undergone review by the Sequoyah plant manager.
These last two preoperational test problems were discussed with the licensee
by NRC management during conversations conducted on February 20 and 21,
1986.