ML20206C473
| ML20206C473 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/06/1987 |
| From: | Barlow D, Brown W, Deangelis J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20206C172 | List: |
| References | |
| 80504-SQN, 80504-SQN-R04, 80504-SQN-R4, NUDOCS 8704130066 | |
| Download: ML20206C473 (54) | |
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'; ' h. , TVA EMPLOYEE CONCERNS REPORT NUMBERt SPECIAL PROGRAM 80504-SQN i . REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 1 OF 28 Quality Assurance Records REASON FOR REVISION: Revised to incorporate NRC conunents.
Revision indicators are shown in the right margin on each page.
Note: Sequoyah Applicability Only PREPARATION PREPARED BY: D. G. Barlow /J. J. DeAngelis
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NATURN ML
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sl9kT DATE REVIEWS PEER:
4%Jc SIGNATURE 0 3l9ln DATE TAS:
J{B1 / e SIGNATURE
- en DATE CONCURRENCES CCC -H : /h n
_ 3/9/97 SRP : Erub/ // 3 ff SIGNATURE DATE DATE flGNATURE*[
APPROVED :
i lMjk N/A DATE MANAGER OF NUCLEAR DATE
" ECSP'"MANA'GtR Q \
l POWER CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
8704130066 870406 PDR ADOCK 05000327 P PDR
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?.* TVA EMPLOYEE CONCERNS .
REPORT NUMBERt
$ 80504-SQN.
SPECIAL PROGRAM REVISION NUMBER:
REPORT TYPE 4 Element Report PAGE.2 OF 28
' TITLE:.
-Quality Assurance Records 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction The ' issues described below were taken from employee concerns generated The Bar Employee Concern Special Program.
as a result of the Watts and evaluated at the Sequoyah Nuclear Plant investigated issues were (SQN) since they were deemed to be site specific or to have generic applicability to SQN.
1.2 Description of Issues The conditions reported (Attachment A) by concerned employees are:
i a.
Controlled documents contain conflicting or obsolete data or l both. (SQM-86-002-005, SQM-86-002-006, SQM-86-003-002) l Work which had been performed had not been appropriately.
b.
documented. (SQM-86-011-002)
Traceability of requirements and t
- c. Poor material control.
l materials is inadequate and paperwork for quality ' records. is 4
poor. (XX-85-122-042) f 1 The retrieval of Quality Assurance (QA) records is inadequate _and j
- d. (IN-85-357-001, SQM-86-002-001, l
records are not identifiable.
l SQP-86-002-001, and WBP-86-009-001) altered. (IN-65-612-XO7, XX-
' e. Welder Certification records were 85-088-X04)
NOTE: Falsification of Welders' Qualification Records will be
- addressed seperately by the TVA Of fice of the Inspect or General.
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- f. Maintenance Requests (MRs) which specifiedsigned the addition of grease off as being
! valve actuators were for Limitorque unnecessary or as being complete even though no work was and i
performed. Non~QA material was installed in QA applications i
traceability was f alsified on the MR. (JLH-86-001) l
- g. Quality Assurance (QA) documents were lost by the vault personnel (IN-85-091-001) f and regenerated by the responsible unit.
(SQM-86-009-X04)
!' h. Inspection records may reflect improper data.
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A REPORT NUMBERS
's . ' . TVA EMPLOYEE CONCERNS i ,
SPECIAL PROGRAM 80504-SQN i REVISION NUMBER:
REPORT TYPE 4 Element Report PAGE 3 0F 28 TITLE:
Quality Assurance Records 2.0
SUMMARY
2.1 Summary of Characterization of Issues These issues were grouped into the element of Quality Assurance Records since they indicated that quality documents have been lost, regenerated, altered and contained conflicting or obsolete data or both. The issues also indicated that the QA records are not identifiable or retrievable.
2.2 Summary of Evaluation Process The evaluation process consisted of 'a search of the available concerns files and reviews of regulatory requirements and industry standards.
Likewise, reviews were made of the TVA upper tier requirement documents such as the Topical Report, Nuclear Quality Assurance Manual and Final Safety Analysis Report together with lower tier to implementing determine documents such as procedures and instructions requirements, commitments and responsibilities. Reviews of associated documentation and field verification along with discussions with cognizant personnel were also performed as part of the investigation of the issues.
investigation and A listing of the documents utilized in the evaluation process for this Element Report is included as Attachment B.
2.3 Summary of Findings 2.3.1 Issue - Controlled documents contain conflicting or obsolete data or both.
The Employee Concern file provided clarification of this issue which directed this investigat, ion into the area of vendor for requesting design . drawings (mylars) and the system duplicates of original drawings. This replacement appears to be mainly for those vendor drawings received prior to 1976 when site copies of these drawings were routinely discarded.
Thus, there was the need at the site for wash-offs (a wash-off being a replacement original from the aperture card in Knoxville). There is a potential for the two " originals" to contain obsolete or conflicting data when one drawing is updated and not the other. Conflicting data occurs when a replacement for an original drawing is used the missing as the baseline drawing drawing for subsequent changes and reappears and is not properly dispositioned. Controls are now in place to avoid lost and duplicate drawings.
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.' ' TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBERt 80504-SQN
$' REVISION NUMBER:
. REPORT TYPE 4 Element Report PAGE 4 0F 28 TITLE:
Quality Assurance Records The Employee Concern file also provided clarification of another concern dealing with this issue which directed this investigation to a specific wiring diagram mylar which was Failure to log-issued twice with the same revision number.
out the first release of Revision 8 also created the potential for two mylars to contain obsolete or conflicting data when one drawing is updated and not the other. This appeared to be an isolated case and was due to the relocation of the SQN Engineering Project to the site with new clerical personnel in the Drawing Control Center. Procedures are adequate and additional training has been provided in the area of drawing control and issue.
i 2.3.2 Issue - Work which had been performed had not been appropriately documented. (Environmental Qualification of Equipment)
The investigation of the issue dealt with the actual employee concern which said that Sequoyah was shutdown in August 1985 due to a failure of a group to appropriately document work which had been performed. This investigation determined the concern was valid as Sequoyah was shutdown in August 1985 due questions about the environmental qualification of to electrical equipment. The SQN Nuclear Performance Plan specifies the corrective actions to be taken by SQN for Environmental Qualifications.
2.3.3 Issue - Poor material control. Traceability of requirements and materials is inadequate, and paperwork for quality records is poor.
The investigation of the issue of poor material traceability /
control, inadequacy of requirements, and inadequate quality
{ records provided evidence that the major problem in material control was inadequate instructions or failure to follow and instructions. Examples of improper procedures traceability of quality requirements for materials received were also found along with examples where traceability of paperwork to actual hardware could not be established.
1 Control has performed extensive The Material CEG investigations in the hardware areas of material control and has reported their findings separately.
2.3.4 Issue - The retrieval of QA records is inadequate and records are not identifiable. ;
l The investigation of an inadequate QA records retrievable l system at SQN was reviewed for Construction and Operation QA t
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- G REPORT NUMBER
. 's' ? i ~ TVA EMPLOYEE CONCERNS SPECIAL PROGRAM 80504-SQN f I REVISION NUMBER: i REPORT TYPE 4
Element Report PAGE 5 0F 28 TITLE:
-Quality Assurance Records records. Record retrievability was ' found to be inadequate for '
contruction records since the document retrieval system is not.
fully operational. However, the retrieval of operational QA records (those needed for the operations phase) was found to be adequate..
2.3.5 Issue - Welder certification records were altered.
The investigation of the issue of welder certifications being altered provided evidence of various types of documentation errors. There was evidence of Corrective Action Requests (CARS), Deficiency ~ Reports (DRs), and Survey Checklists also having been written which deal with altering welder records.
2.3.6 Issue - Maintenance Requests (MRs) which specified the addition of grease for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications ,
and traceability was f alsified on MR.
The investigation of the issue produced evidence that all SQN Unit 2 Limitorque valve actuators have been inspected and that the actuators have been properly greased in accordance with the maintenance procedure.
2.3.7 Issue - Quality Assurance (QA) documents were lost by the vault personnel and regenerated by the responsible unit.
The investigation into the issue of quality documentation being lost by the vault personnel and later regenerated by the responsible unit found no evidence of this condition having been documented at SQN.
When lost documents were identified at SQN, QA personnel did not document the condition. In such cases, the records storage vault pctsonnel identified the documents to the responsible unit and a duplicate copy was furnished for storage.
2.3.8 Issue - Inspection records may reflect improper data.
The issue that inspection records may contain conflicting data was not addressed within the scope of the Quality Assurance Category Evaluation Group (QACEG) evaluation. The concerned ,
individual (CI) was not specific to the type of data or inspection records that may contain conflicting data.
Additionally, the Employee Concern and Confidential Files contained no information that identified the specific inspection records or data that would specify the subject of
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'. TVA EMPLOYEE CONCERNS REPORT NUMBERt SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE Element Report 4 TITLE: PAGE 6 0F 28 Quality Assurance Records the employee concern. Also, Nuclear Safety Review Staff (NSRS) Investigation Report I-86-241-SQN was assigned to Employee Concern SQM-86-009-X04. However, a NSRS Report was never issued.
2.4 Summary of Corrective Actions 2.4.1 Issue - Controlled documents contain conflicting, or obsolete data or both.
Corrective actions taken to date include:
- a. Procedural guidance in Sequoyah Engineering Project (SEQP)
Project Manual dated September 1985 provides tighter control over design activities. Training of newly arriving clerical personnel has been given in procedural requirements for drawing control and supervision has been increased for the drawing issue process.
- b. Wiring Diagram 45N1749-30 has been revised to reflect the correct data and the dravieg log corrected to reflect the proper revision. A Drawing Issue Checklist has also been 4 added to Procedure SQEP-AI-08.
2.4.2 Issue - Work which had been performed had not been appropriately documented. (Equipment Qualification Program)
The Equipment Qualification (EQ) Project was formed with the responsibility for development and implementation of an EQ Program. Work is ongoing by the project to resolve the equipment qualification problems. SQN has committed to 4
demonstrate qualification prior to restart of the plant.
2.4.3 Issue - Poor material control. Traceability of requirements and materials is inadequate and paperwork for quality records is poor.
Corrective actions taken to date include:
Audits, increased SQN Plant QA Staff surveillance, TVA Management attention, and personnel awareness over the entire material control area which appears to be adequate.
2.4.4 Issue - The retrieval of OA records is inadequate and records are not identifiable.
Corrective actions taken to date include:
- TVA EMPLOYEE CONCERNS REPORT NUMBERt
- SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 4 Element Report PAGE 7 0F 28
' TITLE:
Quality Assurance Records
- a. Established a work force to index and microfilm construction records, vendor documentation, drawings and manuals for SQNP Units 1 and 2.
- b. Developing new and revised procedures and instructions to define organizational responsibilities : and interface requirements with. other departments. These - procedures will also include the methods of maintaining, storing,.and controlling vendor QA records.
The above activities are currently ongoing and the schedule for completion of these activities is December 1988.
2.4.5 Issue - Welder certification records were altered.
Corrective actions taken to date include:
Corrective Action Report (CAR) CAR-SQN 09-014 was written-and dispositioned as - "all SQN active welders' files to be reviewed and welders re-qualified to current requirements."
This CAR has been closed and all corrective actions have been verified as being complete.
2.4.6 Issue - Maintenance Requests (MRs) which specified the addition of grease for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications and traceability was f alsified on the MRs.
Corrective actions taken to date include:
All Sequoyah Unit 2 Limitorque valve actuators have been inspected and verified that they have been properly greased.
2.4.7 Issue - Quality Assurance (QA) documents were lost by the
- vault and regenerated by the responsible unit.
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No corrective actions required.
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3.0 LIST OF EVALUATORS, W. M. Akeley D. G. Barlow J. J. DeAngelis J. E. Mann
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- TVA EMPLOYEE CONCERNS REPORT NUMBER J SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 8 0F 28 Quality Assurance Records 4.0 EVALUATION PROCESS 4.1 General Method of Evaluation The evaluation process consisted of researching the Employee Concern files, Quality Technology Corporation (QTC) files, and Nuclear Safety Review Staff (NSRS) files to determine if additional information was available to assist in the investigation of issues associated with this element.
Reviews were conducted of regulatory requirements and industry standards together with upper tier requirements, documents such as the TVA QA Topical Report and the Nuclear Quality Assurance Manual, along with lower tier implementing documents such as procedures and instructions to determine requirements, commitments, and responsibilities. Documentation in the form of quality audit reports, survey checklists, inspection reports, Field Change Requests (FCRs),
Significant Condition Reports (SCRs), Nonconformance Reports (NCRs),
Discrepancy Reports (DRs), Maintenance Requests (MRs), work plans, microfilm records of inspections / tests and computer status reports were also reviewed. The above documentation together with personnel discussions provided the basis for the conclusions reached.
4.2 Specifics of Evaluation This section describes the specific methodology used relating to the following issues:
4.2.1 Issue - Controlled documents contain conflicting, or obsolete data or both.
The Employee Concern files were researched to determine if Quality Technology Company (QTC) and/or the Nuclear Safety Review Staff (NSRS) had investigated and reported on the issue. The following NSRS reports were evaluated by the Quality . Assurance Category Evaluation Group (QACEG) to determine the adequacy of the scope and the results of their investigation.
- a. *lSRS Investigation Report I-86-185-SQN for Employee Concerns SQM-86-002-005 and -006.
- b. NSRS Investigation Report I-86-180-SQN for Employee Concern SQM-86-003-002.
There were no QTC reports available.
The QA Topical Report TVA-TR75-1A Revision 8, and the Nuclear Quality Assurance Manual (NQAM) Part III, were reviewed
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g- TVA EMPLOYEE CONCERNS REPORT NUMBER:
' 3PECIAL PROGRAM 80504-SQN
- -REPORT TYPE REVISION NUMBER: ,
Element Report 4 TITLE: PAGE 9 OF 28 Quality Assurance Records:
together with site practices, procedures, and policies to I determine the requirements and commitments during the time frame the concerns were reported.
A. review was made of the Wiring Diagram, Field Change Requests (FCRs), Significant Condition Reports (SCRs), and Engineering Change Notices (ECNs) which document specific data' relating to l' the concerns of record.
Discussions were held with personnel in the Document Control Unit (DCU) to develop the historical background and current events pertaining to the issue.
4.2.2 Issue - Work which had been performed had not been appropriately documented. (Environmental Qualification of Equipment)
The Employee Concern files were researched to. determine if QTC l- and/or NSRS had investigated and reported on the issue. NSRS Investigation Report I-86-270-SQN was assigned to Employee
! Concern SQM-86-Oll-002. However, a NSRS Report was never issued.
i A review was made of Regulatory Requirement NUREG-0588,
" Interim Staff Position on Envirotroental Qualification of Safety-Related Equipment"; Industry Standard IEEE 323-1974, "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations"; Topical Report TVA-TR75-1A, Final Safety Analysis Report (FSAR) Section 3.11, Code of Federal Regulations 10CFR50.49, January 1, 1985 Edition,
" Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants"; and the Nuclear Quality Assurance Manual (NQAM), Part II, to determine the the time frame the requirements and commitments during concerns were reported. Environmental Qualification Documentation packages including test results were also l reviewed to form a basis for the conclusions reached.
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! Discussions were held with various site personnel to develop the historical background and other information pertaining to i the subject issues.
4.2.3 Issue - Poor material control. Traceability of requirements and materials is inadequate and paperwork for quality records is poor.
! The Employee Concern files provided NSRS Investigation Report I-85-987-SQN dated 3/4/86. This report was evaluated by QACEG il - - _ _
TVA EMPLOYEE CONCERNS REPORT NUMBERt
,. SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 10 0F 28 Quality Assurance Records to determine the adequacy of the scope and the results of the NSRS investigation.
Regulatory Guides 1.33, 1.38, and 1.123, the Topical Report TVA-TR75-1A Section 17, the Final Safety Analysis Report (FSAR), the Nuclear Quality Assurance Manual (NQAM) Parts II and III were reviewed together with Site Instructions AI-7, AI-ll, AI-12, and Al-36, Standard Practice SQA45, seven (7) survey checklists, seven (7) Audit Reports, and two (2) additional NSRS Reports to determine the commitments, requirements and audit results during the, time frame the issue was reported.
SQN Element Report MC-40703, Revision 0, dated 9/26/86 issued by the TVA Employee Concern Special Program Group was reviewed for additional information relating to the issue.
4.2.4 Issue - The retrieval of QA records is inadequate and records are not identifiable.
The Employee Concern files and the Confidential Sensitive files were researched to determine if they contained additional information regarding this issue. The files provided the following:'
- a. NSRS Investigation I-86-126-SQN was assigned to Employee Concern SQM-86-002-001. However, a NSRS Report was never issued.
- b. NSRS Investigation Report I-86-129-SQN was issued March 3, 1986 for Employee Concerns SQP-86-002-001 and WBP-86-009-001.
Note: Part of the issue included in Employee Concern SQP-86-002-001 references NSRS Reports I-83-13-NPS and R-85-07-NPS. These NSRS Reports were used to identify the specific issue (s) of the concern only, and for this reason, the reports are not attached to this Element Report.
NSRS Report I-86-129-SQN was evaluated by QACEG to determine the adequacy of the scope and the results of the NSRS investigation.
The QA Topical Report TVA-TR75-1A, the NQAM, and site practices, procedures, and policies were reviewed to determine the compliance criteria during the time frame the concerns were reported.
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- TVA EMPLOYEE CONCERNS REPORI' NUMBER
~,. SPECIAL PROGRAM .80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 11 0F 28 Quality Assurance Records The QA Auditing Branch files in Chattanooga were reviewed to determine deficiencies identified 'y audits relating - to the-issue.
A review was also = conducted of the various forms of' nonconforming conditions which were documented to determine the types of deficiencies that relate to the issue.
Discussions were held with various site personnel in the Records Management and QA Vault areas to develop _ historical background and other additional information pertaining to the subject issue.
4.2.5 Issue - Welder certification records were altered.
The Employee Concern files provided two Employee Response Team (ERT) Renorts by Quality Technology Company (QTC) dealing with '
this subject (ERT Reports IN-85-612-X07 dated 10/24/85 and XX-85-088-X04 dated 3/4/86). Although the ERT report dated 10/24/85 was evaluated for WBN, the QACEG has determined- that this issue is generically applicable to SQN and the results of the - investigation at Sequoyah are included in this report.
Also, NSRS Investigation Report I-86-120-SQN was assigned to Employee Concern XX-85-088-X04. However, a NSRS Report was never issued.
Site QA Procedure QAP 17.2 and Administrative Instruction AI-7 were reviewed to determine the compliance requirements during the time frame the concerns were reported. Also reviewed were six Survey Checklists, three Corrective Action Reports (CARS),
l and six Discrepancy Reports (DRs) dealing with welder
! qualifications.
f A review was made of the welder certification documentation which is on microfilm and currently stored in the permanent
- i. record retention system and hard copies of Nuclear Power i Welder Certification documentation which is stored in the t Solar Building.
t Discussions were held with various site Records Management l' personnel to develop historical background and other j additional information pertaining to the subject issue.
! 4.2.6 Issue - Maintenance Requests (MRs) which specified the
' addition of grease for Limitorque valve actuators were signed off as unnecessary or complete even though no work was
, performed. Non-QA material was installed in QA applications and traceability was falsified on the MR.
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.> '. . TVA EMPLOYEE CONCERNS REPORT NUMBERt
,,' SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 12 0F 28 Quality Assurance Records Research of . the Employee Concern files and NSRS files was conducted to determine if additional information was available. One NSRS Report was issued in February 1986 which addressed this issue.
A review was performed of the ECTG Operations CEG Element Report (30840-SQN dated 9/12/86) for additional information since their investigation dealt with part of this issue.
A review was also performed of the NQAM Part II, Maintenance Instruction MI-10.46 and Standard Practice SQM2 to determine the commitments and requirements surrounding the issue.
Discussions were also held with site QC inspection personnel who performed the Limitorque valve research.
4.2.7 Issue - Quality Assurance (QA) documents were lost by the vault and regenerated by the responsible unit.
A review was performed of the Employee Concern and the Confidential Files to determine if QTC or NSRS had investigated the issue and if the files could provide additional information regarding this concern. It was found that QTC had evaluated this concern and issued Report No.
IN-85-091-001 dated 9/16/85.
The NQAM, site practices, and procedures were reviewed to determine the compliance criteria during the ti=e frame the issue was reported.
The Nonconformance Report (NCR) Log was reviewed for any information identifying lost QA documents or records.
Discussions were held with va-ious site QA and Document Control Unit (DCU) personnel to develop information relating to lost QA documents.
5.0 FINDINGS The following contains both a background discussion and a conclusion for each issue as identified in Section 1.2.
5.1 Issue - Controlled documants contain conflicting or obsolete data or both.
5.1.1 Discussion Two reports (I-86-185-SQN and I-86-180-SQN) were issued by NSRS of which the above issue is a part. Our investigation and this report will discuss each NSRS Report separately.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
,. SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 13 0F 28 Quality Assurance Records 5.1.1.1 NSRS Report I-86-185-SQN NSRS Report I-86-185-SQN dated March 1986 described the investigation of Vender Drawing Control where five Employee Concerns were investigated by NSRS of which this issue was a part.
The NSRS Report included a clarification of the issue as provided to NSRS by QTC which said that SQN design drawings (mylars) were issued by the Office of Engineering Reprographics, Knoxville.
Our investigation therefore, dealt with interviews of drawing control personnel at SQN and centered around the process for requesting duplicates and determining how conflicting data could exist.
If an original vendor drawing cannot be located and the sign-out log does not indicate that the drawing was removed from the file, the Drawing Control Unit will request a replacement drawing from the Technical Information Center (TIC) at Knoxville. The replacement drawings are referred to as "washoffs".
This "washoff" is issued as a "new original" and has the potential for placing in circulation two original drawings which could contain conflicting data. This happens if the first issued drawing should reappear and is not properly noted in the drawing file.
The replacement of duplicate or " wash-off" drawings appeared to primarily affect those vendor drawings received at SQN prior to 1976.
Discussions with Drawing Control personnel confirmed that these site drawings were discarded and that it was possible for two original vendor drawings to be in circulation with conflicting data for the reason noted above although this investigation did not find where this happened. To avoid this, the Drawing Control personnel are now required by procedure to place a notation in the drawing check-out file that a "new original" has been requested. Subsequently, if one vendor drawing reappears at Drawing Control, the clerk is immediately alerted to the existence of the duplicate drawing. The clerk, with the assistance of engineering, will determine the correct drawing to retain, then climinate the obsolete drawing from the records system. To verify the control of this particular drawing activity, QACEG confirmed the
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TVA EMPLOYEE CONCERNS '
REPORT NUMBER:
. SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element' Report 4 TITLE: PAGE 14 OF 28'
_ Quality Assurance Records 1
implementation' by . reviewing the vendor drawing checkout files and found five containing the notation "new originals" on the replacement drawings.
Controls are now in place to avoid lost and duplicate
, . drawings in existence with incorrect data. ,
5.1.1.2.NSRS Report I-86-180-SQN
. NSRS Report . I-86-180-SQN dated February 1986 described the investigation of Sequoyah Drawing Control. Six:
i Employee Concerns were investigated of which the issue noted above and' investigated by QACEG was a part.
The NSRS Report also included a ~ clarification of the -
1 issue which was provided to NSRS by .QTC, which said*
that drawing 45N1749-30 (R8) was issued twice .on separate mylars. The Mylar drawings were issued on November 29, 1985 and November 30, 1985, respectively.
The investigation in the Drawing Control area included a review of the SQN mylar drawing number 45N1749-30, Revision 8, Engineering Change Notice (ECN) L6202 and L6544, Field Change Notice (FCN) 3585 and 3966, and Significant Condition Report (SCR) SQN SQP-8601, Revision O.
This review confirmed the NSRS report that -mylar drawing number 45N1749-30 was issued twice as revision
- 8. The first issue was for ECN L6202/FCR3583 dated 4 11/29/85, and the second issue was for ECN L6544/FCR 3966 dated 11/30/85. Failure to adequately log-out the first release of Revision 8 mylar on November 29, 1985 created the potential for obsolete or conflicting data when one drawing is updated and not the other.
). As a result of ' the NSRS investigation this Condition Adverse to Quality (CAQ) was reported on SCR No. SQN SQP-8601, ' Revision 0, dated 1/11/86. QACEG verified the corrections as having been made and checked the 4 current log books of issue tickets and could not find
, where other duplications have occurred.
Our discussions with Document Control personnel indicated that the condition happened because of inexperience of new clerical personnel in the changeover from the Engineering Project Office in Knoxville to the site office and lack of attention by the new personnel to the Engineering Change Notice, Field Change Request, and drawing issue process.
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- TVA EMPLOYEE CONCERNS REPORT NUMBER:
,1 SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 15 0F 28 Quality Assurance Records Prior to September 1986 Drawing Issue tickets which are used to request copies of drawings, were considered a " log" and were only kept for 6 months.
These tickets plus the accompanying Drawing Issue Checklist are now being kept indefinitely by DCU.
Item 5 of the Drawing Issue Checklist instructs the 4 DCU personnel to verify that the drawing and I appropriate revision are clear for issue by using the Drawing Management System computer program. The data on the screen will alert the operator of any inconsistencies.
Corrective actions have been initiated by TVA by way of additional training from Drawing Management System personnel in Knoxville and the addition of a Drawing Issue Checklist. Additional supervision has also been assigned to the DCC to control the issuance of drawing.
5.1.2 Conclusion The issue of controlled documents containing conflicting or obsolete data or both is considered valid. The QACEG investigation and evidence produced verifies the results obtained by NSRS. The NSRS Reports are considered factual. There did exist the potential for two " original" vendor drawings to exist. However, there now are adequate l controls in effect to prevent this from occuring.
This investigation also found evidence to support the conclusion in that the wiring diagram was issued twice with the same revision number. This appears to be an isolated case having happened when the individual who furnished the first copy of the wiring diagram on November 29 failed to enter the drawing issue ticket in 4 the log. Further reviews of drawings and issue cicket logs could not find'where this condition happened again.
Procedures governing the issuance of drawings are adequate and additional training by Drawing Management Systems personnel was provided to correct this condition.
5.2 Issue -
Failure to appropriately document work which had been performed.
5.2.1 Discussion The issue raised was that "Sequoyah was allegedly shut down in August 1985 due to the failure of a group to appropriately
. 4 TVA EMPLOYEE CONCERNS REPORT NUMBERt
. g.' .SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION IIUMBER:
Element Report 4 TITLE: PAGE 16 0F 28 Quality Assurance Records document work which had been performed". Records _ indicate that SQN was shut down in August 1985 because TVA determined that they would not be in full compliance with regulatory requirements for equipment qualification,- 10CFR50.49, by November 30, 1985. On that basis, it was concluded that the concerned employee was referring to the Environmental Qualification (EQ) documentation. A review was made of the .
revised Sequoyah Nuclear Performance Plan dated July 1986 to determine the background associated with the plant shut-down.
A review was also performed of the regulatory requirements in 10CFR50.49 to establish those requirements which TVA has committed to comply with. The Nuclear Performance Plan,Section III, Paragraph 1.0 stated the following:
"The environmental qualification of electric equipment required to ensure reactor coolant pressure boundary integrity, shut down the reactor and maintain it in a safe shut-down condition, and prevent or mitigate the consequences of accidents that could result in off-site exposures comparable to the 10CFR.100 guidelines is required by 10CFR50.49. It is further required that the evaluation of environmental qualification be documented and maintained in auditable files. The date required by NRC for full compliance with 10CFR50.49 was November 30, 1985.
TVA conducted a management review of the environmental qualification programs of SQN, BFN, and WBN in July and August 1985. This review indicated that much of the qualification documentation was not fully auditable and, in some cases, the documentation available did not demonstrate full qualification.
The cause for the failure to comply in a timely fashion with 10CFR50.49 requirements was a lack of management attention to the enviromnental qualfication program.
SQN was shutdown voluntarily at the direction of the Manager of Nuclear Power with the concurrence of the TVA Board of Directors in August 1985.
Subsequent to the voluntary shutdown of Sequoyah, the Equipment Qualification Project (EQP) was formed with the responsibility for development and implementation of an EQ program. Responsibility for engineering activities associated with environmental qualification is presently assigned to Division of Nuclear Engineering (DNE) and detailed responsibilities, scope, organization, specific project procedures, and project training program are
- * ' ' ' ' '+ ' TVA EMPLOYEE CONCERNS REPORT NUMBER:
.} SPECIAL PROGRAM 80504-SQN.
REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 17 0F 28 Quality Assurance Records defined in the project manuals for the EQP and the Sequoyah Engineering Project (SQEP)."
Standard Practice SQA173, "Sequoyah Nuclear Plant 10CFR50.49
-Environmental Qualification . Program," describes the overall program for achieving full compliance with 10CFR50.49.
5.2.2 Conclusion The issue is substantiated. However, adequate attention is being paid by TVA to identify and correct the deficiencies.
TVA has tentatively scheduled completion of the necessary 4 tasks to damonstrate equipment qualification by the end of April, 1987.
5.3 Issue - Material control is poor. Traceability of requirements and materials is inadequate; paperwork for quality records is poor.
5.3.1 Discussion The Employee ~ Concerns files . contained a comprehensive NSRS report on the material control activities at SQN. The NSRS report addressed the points raised in the subject issue. This investigation dealt with verifying the validity of the findings noted in NSRS Report I-85-987-SQN dated February 1986.
The QACEG considered the material control issue from a' programmatic point. Material Control CEG is addressing the hardware issues and is reporting on these separately.
All the documents reviewed by both NSRS and QACEG were generated during the - operational phase as cons truction was essentially complete at the time the concern was generated.
The requirements for material control, traceability and quality records at SQN are based upon Appendix B to 10CFR50, Regulatory Guides 1.33, 1.38, 1.123, and 1.88, the TVA Topical Report and NQAM, Parts II and III, together with the Administrative Instructions AI-7, AI-11, AI-12 and AI-36 and Standard Practice (SQA45). The NSRS findings were reviewed against the above requirement documents.
A selection was taken of all the documents used in the NSRS investigation and a review was performed by QACEG of their content to independently verify the NSRS results. The Quality Assurance Category Group (QACEG) reviewed seven Surveillance Reports, seven audit reports, two Corrective Action Reports (CARS ), and nine Deficiency Reports (DRs). These documents
r---
L TVA EMPLOYEE CONCERNS REPORT NUMBER
' j SPECIAL - PROGRAM - 80504-SQN REPORT TYPE REVISION NUMBER:
Element' Report 4 I
! TITLE: PAGE 18 OF 28 Quality Assurance Records dealt exclusively with material control activities. The reviews produced evidence of a significant number of
- deficiencies (conditions adverse to quality) dealing with inadequate instructions being available and failure of personnel to - follow those instructions which were in place.
l During the period 1981 through 1985 (when the above noted Conditions Adverse to Quality were reported), NSRS . compiled l data on 15 instances of inadequate instructions to maintain adequate material control. Likewise NSRS data revealed 134 instances attributable to failure to follow the instructions which were in place.
The NSRS data dealing with traceability of requirements j indicated 49 conditions where there was inadequate traceability of requirements (those noted on procurement' documents) to the material received. It was also found that there were 97 conditions noted in the reports relating to improper traceability of paperwork and materials. That is, maintaining traceability of documentation and materist through .
l the entire cycle of receipt, installation and operations.
In researching the allegation of poor quality records the NSRS data indicated 99 conditir.ns being reported relating to inadequate documentary evidence of the quality of the material.
In addition to verifying the validity of the NSRS findings, the QACEG investigation performed an evaluation of the areas covered by the Quality Assurance Audit Branch audits and-site surveys (surveillances) and found that the depth and coverage was adequate to form an objective evalaation of the conditions.
5.3.2 Conclusion l
[ By researching and reviewing the sample numbers of reports
! noted above and our independent verification the QACEG has determined, in agreement with the NSRS reports, that the issue raised by the concerned individual is valid. However, there appears to be a decline in incidents of poor material control and related quality records. This was concluded because of the reduced number of findings reported in recent audits and surviellances even though the QACEG investigation found that the SQN QA Surveillance Staff has increased their effort of surveillance over the material control activities.
TVA has directed considerable attention in the years 1985 and 1986 to the improvement in the control of materials at SQN.
This has been verified by reviewing audits and surveillance
- TVA EMPLOYEE CONCERNS REPORT NUMBERt j SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 19 0F 28 Quality Assurance Records reports of the Quality Assurance Surveillance Section. There appears to be a downward trend in the number of conditions adverse to quality which are being found. Audits, increased surveillance by SQN Plant QA Staff, TVA Management attention, and personnel awareness seem to have had an effect on reducing incidences of improper control of material ano related documentation. Corrective actions as a result of Element Report 40703 will also reduce the incidences of improper material control.
5.4 Issue - SQN records retrievability is inadequate.
The concerned employee alleged that the retrievabilty of SQN QA records generated during both the construction and the operational phases is inadequate. The findings and conclusions contained herein are discussed separately for the retrievability of quality related construction and operation records.
5.4.1 Retrievability of Quality Related Contruction Records.
5.4.1.1 Background The Records Retrievability Indexing (RRI) system for QA construction records was addressed in NSRS Investigation Report I-86-129-SQN and the issue was reported to be substantiated. The NSRS Report identified that SQN QA construction records including vendor drawings and manuals have not been completely entered into the records retrieval system. Since the current RRI f or QA construction records and the vendor drawings and manuals are less than 50 percent implemented, the records retrievability system was considered to be unreliable and incomplete.
5.4.1.2 Discussion The overall results of the QACEG investigation indicated that QA construction records were retrievable; however, the method was considered slow and unpredicable. TVA management recognized this condition in early 1983 and since has been working to provide a complete index and document location on microfilm for each QA construction record for SQN Units 1 and 2.
During the same period, the Vendor Drawing and Manual Control Program was considered by TVA to be a potential problem. TVA surveillance groups had
t TVA EMPLOYEE CONCERNS REPORT NUMBERS
.- SPECIAL PROGRAM 80504-SQN
. REPORT TYPE REVISION NUMBER:
Element Report 4
- TITLE: PAGE 20 OF 28 i: Quality Assurance Records identified the following conditions relating to vendor drawings and manuals:
a.' Vendor drawings and manuals were unorganized and I -
difficult to retrieve.
i
- b. Vendor drawings and manuals were not controlled
[ relative to the "as designed" specifications.
l On February 22, 1984, the Quality 2ngineering Branch
! (QEB) initiated a Nonconformance Report (NCR) No.
l GENQEB8401 describing a deficient condition involving inadequate indexing and ineffective retrievalibity of vendor QA records. The corrective action measures for the CAR included the revising of Interdivisional Procedures ID-QAP 17.1, " Transfer of Quality Assurance Records", ID-QAP 17.2. " Quality Assurance Records for Design and Construction", and QEB-EP 24.37, " Product Compliance Data and Quality Engineering Records Indexing and Preparation". Verifying and final i completion of this CAR was performed on August 28, 1984.
In early 1985, the Office of Nuclear Power (ONP) l conducted a review of the RRI for QA construction l
records and determined several areas to be deficient.
A task force was established to develop recommendations, including the revising of instructions and procedures for each quality related construction QA record. This revised retrieval system for QA construction records under new and revised guidelines has not been fully implemented by SQN at this time. TVA Record Management personnel are presently in the process of identifying, indexing, and I providing film locators on each construction QA record.
l The purpose of the investigation by QACEG of the RRI l
system for QA construction records was first to i evaluate the present retrievability system and second, l to determine the present status and the scheduled l completion dates for the implementation of SQN l
construction QA records.
l The QACEG investigation of the present RRI for QA construction records involved the selection of 15 l Cable Tray Inspection Reports for SQN Unit 1 and four Hanger / Support Inspection Reports for SQN Unit 2.
These completed construction records were transmitted l l l
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- TVA EMPLOYEE CONCERNS REPORT NUMBERt
,. SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 21 0F 28
,aality Assurance Records by Quality Control to the Master Files for entry into the RRI. The present retrieval method for construction records is controlled by che system number located on the microfilm reel. The specific record must be located by scanning each frame until the desired document is located. This methoe .2volves the possible scanning of approximately 4,000 frames per reel to locate the desired document. The results of the investigation revealed that 18 of the 19 inspection reports were retrievable. One Cable Tray Inspection Report could not be located. The retrieval process for these records was accomplished by one individual in approximately six hours.
TVA's highest tier QA Program Manual, the Topical Report TVA-TR75-1A, Revision 8, Sectiot. 17 requires that a records index and retrieval system be established to assure that Quality Assurance Records are identifiable and retrievable. Although the Construction QA Records, including Veodor QA Records, were available, the documents were nest indexed to a degree of reliable retrievability.
The current RRI for QA Construction Records when completed will be capable of retrieving documents more efficiently by means of identifying documents by reel and frame number. This method will provide direct access to a specific document on each reel. During the discussion with the Supervisor of the SQN Construction Records Project, it was determined that the Construction QA Records portion of the RRI was approximately 25-30 percent complete and final completion scheduled for December of 1988.
The SQN QA Staff initiated a Corrective Action Report (CAR) SQ CAR-86-01-004 dated January 30, 1986 addressing a condition contrary to the requirements of Administrative Instruction, AI-23 and the Nuclear Quality Assurance Manual (NQAM) Part V. This CAR noted numerous vendor drawings and manuals contained in the SQN Environmental Qualification (EQ) binders that were inconsistent with the information identified in the plant controlled Drawing Management System (DMS). The disposition for the CAR has not been resolved to date.
The vendor drawings and manuals are being verified for technical adequacy by the Division of Nuclear
TVA EMPLOYEE CONCERNS REPORT NUMBER:
[. SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Elment Report 4 TITLE: PAGE 22 0F 28 Quality Assurance Records Engineering (DNE) prior to forwarding to the Document Control Center.for entry in the DMS.
SQN is upgrading the Vendor Drawing and Manual Control Program by developing new and revised' procedural requirments in the Nuclear Quality ' Assurance Manual (NQAM) and lower-tier documents i.e., Administrative Instructions AI-23 and AI-25, and Sequoyah Engineering Procedure, SQEP-39. These procedures are presently in the review cycle and a scheduled issue date has not been established.
In a discussion with cognizant DNE personnel, it was indicated that the Vendor Drawing and Manual Control
' Program is approximately 40 percent complete. The target date for completion is January of 1988.
5.4.1.3 Conclusion The issue of the document retrieval of QA records being inadequate and not identifiable in relation to vendor and construction QA records is a valid issue.
Although out investigation indicated a high percentage of retrieveable construction QA records, one must consider the delay and affort involved to retrieve these documents._ However, this condition is not considered a violation of present requirements.
The overall records- retrieval system for QA Contruction Records including vendor drawings and manuals - is less than 40 percent complete; therefore, prompt, reliable, and adequate retrievability ' is not feasible at this time.. Difficulty in retrieving QA records could potentially hinder the required evalust *.on of a safety-related part or component. In additiw , the numerous vendor drawings and manuals addressed in CAR No. SQ-CAR-86-01-004 need ~to be corrected and up-dated to reflect the evision level of the "as designed" equipment and information included in the DMS. The CAR is the current document used by SQN as the tracking means for the above deficient condition.
Although corrective action is warranted pertaining to the issue of records retrievability of vendor drawings and manuals, a Corrective Action Tracking Document (C'TD) has not been issued as part of this report.
j CATD No. 80503-SQN-07 addressing a similar issue was
- included with QACEG Element Report No. 80503-SQN.
l
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1
. 1 TVA EMPLOYEE CONCERNS REPORT NUMBER
,' ' SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 23 0F 28 Quality Assurance Records 5.4.2 Retrieveability of Quality Related Operation Records.
5.4.2.1 Discussion This issue was investigated by QACEC by selecting nine types of operating QA records; such as, Engineering Change Notices (ECN), Workplans (WP), Corrective Action Reports (CAR), Inspection Reports, Discrepancy Reports (DR), Maintenance Requests, NRC Inspection Reports, Inplant Surveys, and Inservice Inspections, for retrievability from the RRI at SQN. The nine types of QA records consisted of a total of 221 documents to be retrieved. Of the 221 documents only three were not retrievable either on microfilm from the Document Control Center (DCC) or hard copy from the Permanent Storage Vault. The three documents were further researched and it was . nd that one was cancelled and the other two ne d to be reviewed by QA prior to forwarding to the Pt :nent Record Storage Vault. The selected Operat ;A records were satisfactorily retrieved from . RRI and from the Permanent Storage Vault.
In addition, QACEG resiewed live SQN QA audit reports relative to the records retrievability in the Document Control and 1A Records areas for 1985 and 1986. This review concluded that no major breakdown in the RRI was reported.
5.4.2.2 Conclusion Based on the above evidence, the issue of inadequate records retrievability for operating QA records is not a valid issue.
The QACEG evaluation of this issue has determined that the RRI was effective for the retrieval of operating QA documents. The RRI is most effective when a u11gue identifier number, specific type document or system number is used to retrieve desired records.
5.5 Issue - Welder certification records were altered.
5.5.1 Discussion QACEG reviewed Weldirg Project's (WP) Specific Employee Concerns Report dated Hovember (, 1986 addressing Employee Concern XX-85-088-003. The isste of alterations to welder qualfication records as noted in WP report was not i
TVA EMPLOYEE CONCERNS REPORT NUMBER:
, SPECIAL PROGRAM 80504-SQN REPORT TYPE- REVISION NUMBER:
Element Report 4 TITLE: PAGE 24'OF 28 Quality Assurance Records substantiated in relation to welder certifications being technically satisfactory. This issue was investigated by QACEG to determine if the welder certifications were actually altered. The investigation performed by QACEG did substantiate the issue that welder certifications were altered contrary to TVA's established requirements. This issue is discussed below.
A review was made of the QC Plant Log which documented all Special Process Surveys conducted by TVA since 1982. A sample of six surveys performed from July 1983 thru August 1985 was then selected for review to determine if the issue of " Altered Welder Certifications" had been identified as a problem. f These surveys encompassed welder qualifications and welder continuity checks to determine if the program was being controlled in accordance with SQM 17 and Specification DPM-N73H2. Each of these surveys identified various types of problems resulting in many DRs being issued. Additionally, in some instances CARS were initiated which required root cause analysis, resolution of condition adverse to quality, remedial corrective actions, and corrective actions necessary to prevent recurrence. The latest survey reviewed, dated August 26-September 5, 1985 identified numerous welder certification record discrepancies. These problems included the following
]
- a. Inappropriate changes were made by engineers or clerks to performance qualification records.
- b. Welder Continuity Records contained conflicting entries.
- c. Weld Rod Issue Cards did not provide adequate information !
to verify that welding had actually been performed.
As a result of the various problems identified, CAR SQN-CAR-85-09-014 was initiated which required immediate corrective action. All SQN active welders' files were reviewed to l identify and correct any discrepancies related to welder ,
continuity and welder qualification. This review did not identify any welders who were working in violation of the applicable code. In several cases, however, welders were directed to re-establish their certifications to ensure that all doubt had been removed concerning their qualifications.
The issue of weldet certifications being altered by the use of correction fluids was reviewed for 75 welders from the Division of Nuclear Power and approximately 200 records from Construction revealed that contrary to the HQAM Part III, 1 Section 4.1 and AI-7, para. 4.2.6, corrections were made to 1
4
- TVA EMPLOYEE CONCERNS REPORT NUMBER:
,.' SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PAGE 25 0F 28 Quality Assurance Records some Welding Performance Qualification records by use of correction fluid.
Based upon copies of welding records obtained from several microfilm rolls there was evidence that some of the welding records did have corrections made to relevant information which could be significant to the. quality information applicable to the welder certifications. Corrections were made to Guided Bend Test results, entries on welder qualification lists, position and specimen numbers , electrode or filler metal type and size, back{ng ring or strip and diameter and/or thickness. With regard to the welding records of the Division of Nuclear Power, the certification records reviewed were the actual hard copies located both in the active and inactive files. There was evidence of correction fluid being used on five of the seventy-five certification records reviewed in the active Nuclear Power file. These corrections were made to entries in the Qualification Test blocks, date qualified / locations blocks, welder continuity records and to the actual Test Results block for Guided Bend tests. These corrections could be significant to the quality information appilcable to the welder certifications.
These conditions violate the requirements of NQAM Part III, Section 4.1, which states that in the preparation of a QA record changes / corrections should be made by marking a single line through the item to be changed making the new entry and entering the dated initials of the person making the change / correction. SQNP AI-7, Paragraph 4.2.6 requirements are similar to the higher-tier document.
5.5.2 Conclusion Based on the above evidence, the issue of welder certifications being altered is valid. The documented evidence of welder certifications being altered is a violation of the requirements of TVA procedures and practicos. The Welder Performance Qualification Records maintained by both Construction and Nuclear Power are defined as QA records, therefore, these records are within the scope of the NQAM and SQN site procedures.
5.6 Issue - Maintenance Requests (MRs) for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications and traceability was falsified on the MRs.
- *
- TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 60504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLE: PACE 26 0F 28 Quality Assurance Records 5.6.1 Discussion The investigation by QACEG concentrated on the specific employee concern and the issue of the Limitorque valve actuators and whether or not Maintenance Request (MRs) which require the addition of grease to the valve actuators were signed off by a general foreman as not necessary; whether the same MRs which the general foreman considered unimportant were signed-of f even though no work was performed; and whether or not non-QA material was installed in QA applications and whether or not traceability was f alsified on the MR. (QACEG assumed this to mean the application of grease since the CI incorporated his allegation on the same concern with the Limitorque valve issue.)
The investigation of this issue was part of a larger investigation done ly the Operations Concern Croup and reported in their Elesent Report 30804 SQN. A discussion with the SQN QC inspectic's personnel by QACEG provided details of an investigation anj research by them into 102 Maintenance Request packages for all the Unit 2 Limitorque valves. That investigation by SQN QC was done in June of 1986 to verify the application of correct grease in the valve actuators. The SQN QC investigation and the QACEG investigation verified that all Unit 2 Limitorque valves were inspected and it was found that the actuators have been properly greased in accordance with the requirements of Maintenance Instruction MI-10.46. This MI
, stipulates a QC hold point for the verification of lubricant.
5.6.2 Conclusion This issue is unsubstantiated since there were no instances observed in the Maintenance Requests reviewed where the general foreman cancelled or deleted a requirement. Research of the MR packages and our conversation with the SQN QC inspection personnel indicated that all Unit 2 Limitorque valve actuators have been inspected and verified to have been greased with the proper lubricant.
5.7 Issue - Quality documentation was lost by the vault and regenerated by the responsible unit.
5.7.1 Discussion This issue was investigated and reported by QTC on September 16, 1985 specifically for a condition at Watts Bar Nuclear Plant (WBN).
r
. . TVA EMPLOYEE CONCERNS REPORT NUMBER:
. SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 4 TITLEt PAGE 27 0F 28 Quality Assurance Records The QACEG investigation at SQN included the review of the similar condition and documents which were reported by QTC.
QACEO reviewed the Electrical Inspection Log for 1985 and 1986, five SQN QA audit reports, and approximately 400 NCRs to determine if SQN documented conditions of lost QA records.
The results of this investigation revealed that the data reviewed did not identify conditions of lost documentation.
QA personnel indicated that SQN did not report the condition of icst documents. The SQN permanent vault personnel would request copies from the responsible unit to be included in the RRI.
5.7.2 Conclusion :
The issue of lost documents at the vault could not be substantiated at SQN. The investigation revealed this issue to be specific to WBN only.
5.8 Corrective Action The issue of the controlled documents containing conflicting or obsolete data as described in Section 5.1.1.2 is valid. ilowever, this condition appears to be an isolated case as noted in Section 5.1.2
" Conclusions". The duplication has been corrected and a, review of the 4 issue ticket logs could not provide further evidence of this happening again. A Drawing Issue Checklist has been added to the procedure and additional training has been provided by Drawing Management Systems personnel. There will be no other corrective action necessary.
The issue of failure to appropriately document work which had been performed as described in Section 5.2.2 is valid. TVA has assigned the responsibility for engineering activities associated with the Sn'ironmental Qualification Program to DNE. These detailed
,e tonsibilities and overall program requirements are described in Sts adard Practico SQA 173. The results of the DNE's evaluation will determine if there is any potential impact on safety.
The issue of material control is poor as described in Section 5.3.2 is valid. Ilowever, this condition has improved through the individual efforts of QA Audits, increased surveillance by SQN Plant QA Staff, TVA management attention, personnel awareness, and corrective actions as a result of Haterial Control Element Report 40703.
The issue of inadequate document retrieval of vendor and construction QA records as described in Section 5.4.1.3 is valid. SQN QA issued CAR 86-01-004 addressing the inability to retrieve the latest vendor drawings and manuals from DHS. The Veredor Drawing and Manual control Program is approximately 40 percent complete. In addition, CATD 80503-SQN-05 and -07 addressing a similar issue will be used to track
TVA EMPLOYEE CONCERNS REPORT NUMBERt SPECIAL PROGRAM 80504-SQN
- REPORT TYPE REVISION NUMBER:
Element Report 4 TITLEt PAGE 28 0F 28 Quality Assurance Records this deficient condition. The dif ficulty in retrieving QA documents could potentially hinder the required evaluation of a safety-related part or component. When the Vendor Drawing and Manual Control Program is completed and put in place, it will reduce the potential for this condition. The corrective action is being furnished by SQN Site Director's Office.
The issue of welder certification records being altered au described in Section 5.5.2 is valid. The corrective action identified on CAR 85-09-014 required all SQN active welders' files to be reviewed and welders re-qualified / certified to current requirements. This CAR was dispositioned and QA verified completion of corrective action on February 18, 1986.
6.0 ATTACHMENTS A. List of Employee Concern Information Subcategory 80504 B. List of References and Documents Reviewed C. NSRS Report 1-86-129-SQN dated March 3, 1986 D. NSRS Report 1-86-180-SQN dated March 4, 1986 l E. NSRS Report 1-86-185-SQN dated March 5, 1986 l
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Tiit QuinC Y - REQUESI DITICE OF I4UCL EAR Puller DitP - 1555 - Rigt kult TillE - 14s2*1:*/*
LHPic)[E COI4CLRil PRCGRAH SYSTEM (ECPS) RUll DAIE 01/28/51 CAIEGORY QA QA/QC PROGRAftS EllP10YLE COIICERil IHIORilAIID8I BY CAIEGORY/5UBCAIEGORY SUDCAIEG0dYs 88504 AS-BUlti CONDITIONS S 1 REPORT APPL ll 2 sal REL Alt.D SUB k Pli 3 FillD CtASS HISTORICAL C094CERN CotiCLRit flUMBER CAT CAT D L OC BF EL SQ las REPORT ORIGIN CONCERN DESCRIPTI0tt SQH-86-002-00501 QA 80504 Il SQll IH H Y H I-86-185-SON QiC CONTROLLED DOCUtlENTS CONI AIN CCNFL ICilllG DAT A Ril A 150254 2 NA IIA 55 HA TING 10 Tile sal 1E IllSI AL L AT ION. filAllf S/DET AIL S ILitu 3 NA HA C HA HH IO QIC, HIIH.itID IG HAINIAIN CUtilIDtHIIAtllY.3 140 FURIHER INIORMAIION HAY BE ret 1.%51D. 14UCL t AR - -
Pol 4ER CONCERN. El NAS NU IURIMER Ifit0RHA110tl. Iso l'OL L OH-Ul* REQUIRED.
SQfi-86-002-00601 QA 80504 H SQil 1H H Y ll I-46-185-50ft QTC HORK IS BEING PERFORHED TO DOCINSENIS C0fil AINII4G ru 150254 2 IIA IIA 55 IIA HFLICilleG OR OB50t[IE DAIA. (HAllES/I:EI Alt $ lt18081H 3 IIA NA C HA 10 Qic, HITHNELD 10 h4INIAIN CONIIDLilIIAllIV.) flu FURIHER IHf 0RHAI!ON t!AY BE REL EASI D. 14UCLEAR l01:
ER CollCERH. CI HAS HG FURillER INFORMAIICII. 110 l u LLOH-UP REQUIRED.
5Qtt 86-003-00201 QA 80504 11 SQN 1 II H Y II I-86-188-5GN QTC DUPLICATE DOCUMENTS HAVE BEEN ISSUED tlIIH Calif t Irl 150253 2 HA flA SS HA ING DATA. (NAMES /DE1 Alls AHolNI IO GIC. IllitillLI D I 3 HA NA C HA 0 MAINI AIN Col 4FIDEHil AL IIY. ) llo TURIHER liit uRilA l l DH HAY BE REttASED. HUCLEAR PolltR CollCERN. CI IIA S Ho FURTHER IHf0RitATI0ll. No FULloII-UP HEQUIRtD.
SQH-86-009-X0401 QA 80504 H SON IN N Y N QTC INSPECTION RECORDS HAY REFtECT IMPROPER DATA. Ut i ISO 262 2 IIA NA SS HA AILS Ks40HN TO QIC, IlllilHEt B DUE 10 CollFIDLNTI AI IlY 3 IIA HA A NA . N0 FURIMER INFGHHAIIUH HAY BE RtLEASED. IIUCILA R P0HER DEPARIMENT CONCERil.
SGH-86-011-04201 QA 80504 N SON 1N N Y N QIC SEQUOYAH HAS Alt EGEDLY SiluT Dollst IN AUGUST 1985. D 150264 2 IIA NA SS IIA UE TO THE FAILURE OF A GROUP (KHolWI) 10 APPROPRIAI 3 IIA NA D NA ELY DOCUMENT HoltK (SPECIFICS tecT KI40llH) tillICH llAD BEEN PERFORNEB. NO FURTHER Ilif 0RHATIUf4 IN FILI..
ANONTHOUS CONCERN.
SQP-86-002-00101 QA N SQN IH H Y N I-86-129-SON OfC QA RECORDS ARE NOT IDENTIFIABLE AND REIRIEVABt f.
850240 2 HA NA SS HA NSRS INVESTIGATION I-85-13-ilPS IDElllIFIED PROBiltri 3 NA HA A NA IN 1983 AHO HSRS REPORT R-85-87-flPS Il3DICATES Pl:0 k BLt'H3 NOT CORRECTED IN HID-1985. UE, OC AllD 840018.
2gP7 AR PolsER RECORDS ARE CIIED. CI HAS N0 fuRIHER lill' ORHAll0N. NO FOLLOH UP REQUIRED.
IIBP-86-009-00101 QA 80504 5 ll&N 1H H Y H QIC -QA RECORDS ARE NOT IDENTIFI ABLE AND REIRIEVABt f.
150243 2 NA HA SR HA NSRS INVESIIGATION I-85-13-14PS IDtilllFIED PROBilli",
3 HA NA A NA IN 1983 AND NSRS REPORT R-55-87-HPS IllDICAl[5 Itu 02 QA 19H4 S IIBM 1Y Y N Y BLEHS NOT CORRECIED IN HID-1985. UE, UC Allu liutil 105)1 2SRSRliASR AR P0ilER RECORDS ARE CITED. H0 FURI ltR Itse 0NilAllu 3 NA N HAY BE RELEASED. CI HAS NO FURIHLH Illf ukitAlluta.
f [s] NO FOLLoll UP REQUIRED.
. - - - . - ~ - . _ . _ . - - -_ _ . . . . _ - . _ _ _ . _ - . . . ..___--_ . . - - . - -
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. s ATTACIDtENT A FACE 3 OF 3 -r TElstiESSEE VAlt EY AUilf0RITY PAGE -
IH4 CE F E R Etic E - ECPS12eJ-ECPS121C kult TIME - 14:29:M tRLQUtisCY - REQUEST OFFICE OF ##UCLEAR Puller 1
1 OtIP - 1555 - Rist EMPLOYEE CDitCERN PROGRAM SYSTEM (ECPS) kull DALE - 01/28/81 i EllPLOYEE Col 4CERN INFONHA110N BY CATEGORY /5USCATEGORY CAIEGOR(e QA QA/QC PROGRAttS SUBLAIEGORY 88584 AS-BulLI CONDillel45 J
5 1 REP (RT APPE H 2 SAF RELAIED
< 10B R PLI 3 FIND CL ASS NISTORICAE CONCERN CAI CAT D L OC BF SL SQ 118 REPORT ORIGIN Col 4CERN DESCRIPTISH C0 tac E RI4 18UMB ER _
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XX 088-X0401 IH 60300 5 5014 1 GTC SE YhH - HELDING CERilflCATIDHS tit RE AL IERI'D BY 150268 2 1HE USE OF CORRECT 1014 flu!D. PROCESS HARILIllGS suc 3 H AS FILE INDEXES Allu PAGE Coutli5. AS llLLL AS Allt 02 QA 80594 5 SGN IH H Y N HARKS. 180l ATIONS OR ANY DAT A THAT DID 140I L OOK I I .
2 2 IIA NA SR 184 KE ENGINEERING DA1 A pil 1HC BACK DI- tile DOCul1Lill .
' 5 IIA NA C IIA HERE DEL ETED lillH CURNECiloll FL UID. C01451HUC I l ois 05 QA 80516 5 5918 1Y Y ll Y DEPARIMENI COIICERN. CI HAS 140 IUNIHLR liliURMAllo!8 j
2SKSRNASR ,
3 NA i
I-85-737-SQH QiC SEquGYAHs HATERI A! CONTROL IS POOR. IRACEABitIIY j XX 122-04201 QA 80189 5 SQH 1Y Y ll Y OF REQUIREHEHIS, PAPERI10RK Allu Half RI AL S IS lilAlif 83 150215 25555flASS UAIE, PAPEkilGRK IuR QUA!ITY NECORDS IS PuoR. 01 ll 3 13 4 l AS NO FURIHER IH10lelAIIDH. Allollyll0US CullCLRN VI A i 02 QA 80504 5 5018 iN N Y II LEXIER.
I 2 IIA IIA SS IIA j 3 IIA NA C MA I 14 CCf3CER185 FOR CATEGORY QA SUBCATEGORY 88504 l
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.. ATTACHMENT B PAGE 1 0F 2 REFERENCES A.
Office of Engineering Procedure, OE-01 3001 Revision 0, " Drawing Originals I
-Checking Out and Checking IN".
B.
Division of Engineering, Management and Engineer'ing Data System, MEDS, HP 23.05, Revision 1, "ENDES and Vendor Drawings Information Services".
C. Nuclear Quality Assurance Manual (HQAM), Parts I, II and II, Revision dated 12/31/84.
D.
Office of Engineering Procedure, OEP-08 Revision 0, " Design Output" E. Administrative Instruction, AI-25 Revision 13, " Drawing control Af ter Unic Licensing".
F. Significant.. Condition Report No. SQN SQP 8601 Revision 0.
G.
Final Safety Anal sis Report (FSAR) Section 3.11, " Environment Design of l Mechanical and Ele::trical Equipment".
H. FSAR Section 8.3 1.2.3, " Safety Related Equipment in Potentially Hostile r
4 Enviroment". '
I.
NUREG-0588, Eterim Staff Posi' tion on Environmental Qualification of Safety-Related Equipment" J.
IEEE-323-1974, "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Station" i K. TVA Topical Report, TVA-TR75-1A Revision 8 1
L. Office of Construction Procedure, OC QAPP-3 Revision 5, " Instructions, Procedures, and Drawings" M.
Office of Construction Procedure, OC QAPP-17, Revisions 0 - 3, "QA Records" N. Nonconforming Report (NCR) No. SQN CEB8502 Revision 2 O
SQN Standard Operating Procedure, No. 351 Revision 6, "Past Records Review and Engineering Evaluation" P.
Quality Assurance Audit Report Nos. SQ-8400-02, SQ-8400-04, SQ-8500-01, PSQ-A-85-005, QSQ-A-86-001, QSS-A-85-0009, and QSQ-A-85-0010 Q. SQN Compliance Visits, Audits, r.nd Inspections - In-plant Survey, checklist Hos. 3-85-P-003, 3c-85-P-004, 3h-83-A-017, 3h-84-5-004, 4a-85-A-001, 4a-85-A-013, and 15a-85-P-001 R.
SQN Work Plans Nos. 10803, 10806, 10830, 10842, 10850, 10861, 10893, 10904, 11139, 11261, 11277, 11467, 11481, 11582 and 11685.
t PACE 2 0F 2 S. SQN Corrective Action Report (CAR) Nos. SQ-CAR-85-03-004, SQ-CAR-83-07-022, SQ-CAR-84-01-001, SQ-CAR-86-01-004, SQ-CAR-21-81-8, SQ-CAR-85-08-012, SQ-CAR--21-82-25, SQ-CAR-31-01-003, SQ-CAR-83-09-032, SQ-CAR-85-03-011, SQ-CAR-83-10-033, SQ-CAR-85-09-014, SQ-CAR-84-09-017, and SQ-CAR--85-03-005.
T. SQN Deviation Report (DR) Nos. SQ-DR-85-05-047R, SQ-DR-85-12-148R, SQ-DR-85-06-060R, SQ-DR-84-07-077R, SQ-DR-34-03-023R, SQ-DR-83-12-117, aQ-DR 01-013R, SQ-DR-86-01-002R and SQ-DR-84-04-038R.
U, Generic Procedure No. ID-QAP-6.2, Revision 0 dated 6/18/85, " Vendor Manual Control".
V. SQN Inplant Survey Checklists Nos. 5a-83-P-005, Sa-85-A-006, Sa-83-030, Sa-83-P-015, Sa-85-S-007, and Sa-84-S-025.
W. Administrative Instruction AI-7, " Recorder Charts and Quality Assurance Records", Rev. 36 dated 4/19/85.
X. Generic Pro edure No. ID-QAP-17.2 Revision 1 dated 6/8/86, " Quality Assurance Records for Design and Construction".
Y. Maintenance Instruction, MI-10.46 Revision 3 dated 6/26/86, "Limitorque, Hoteor Operator / Control Valve". ,
Z. SQN Standard Practice No. SQM2 Revisions 18, 19 and 20, " Maintenance Management System".
AA. TVA 45 D Note, E. Hassell to J. Hamilton dated 6/13/86, " Evaluation of MR packages /Limitorque Operators".
BB. TVA Drawing No. 45N17949-30 CC. SQN Maintenance Instruction, SQM-17, Rev. 4 dated 10/14/86, " General Requirements for Welding, Heat Treating and Allied Field Operations at a Nuclear Power Plant."
DD. SQN DPM-N73H2 dato 10/10/86, " Process Specification for Welding, Heat Treating and Allied Field Operations."
EE. NSRS Report I-85-987-SQN dated 3/4/86 TF. QTC Reports IN-85-612-X07 dated 10/24/85, XX-85-0P8-X04 dated 3/4/86, and IN-86-091-001 dated 9/16/85. . 2
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ATTACletENT C . PACE 1 0F 7
, TEtitlESSEE VALLEY AUTit0RITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. -129 EMPLOYEE CONCERN NO. SQP-6-002-001 *
SUBJECT:
SECDND FOLLOW-UP OF QEB RECORDS INVESTICATI0tl I-83-13-NPS DATES OF INVESTICATION: February 6-14, 1986
? .
INVESTICATOR: M w M $7 [ ,
W. R. SIMONDS DATE#
.. m REVIEWED BY s J/J[f4
/ J. C. CATLIN -
DATE APPROVED BY !/ ' M.JF M ./ b Wl D. STEVENS DATE 6
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ATTACHMENT C PACE 2 0F 7 I. BACKCROUND A Nuclear Safety Review Staff (NSHS) follow-up corecctive action investigation was conducted to determine the validity of an expressed employee concern received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the Employee Concern Assignment Request Form from' QTC and identified as SQP-6-002-001, stated:
- - CONCERN: QA Records are not identifiable and retrievable. NSRS Investigation I-83-13-NPS identified problens in 1983 and NSRS Report R-85-07-NPS indientes problems not corrected in udd-1985. OE, OC, and Nuclear Power Records are cited.
An NSRS follow-up revie'w of Investigation I-83-13-NPS did find that corrective actions resulting from the original NSRS investigation had not been completely closed out. The results of that follow-up review are documented in NSRS Report R-85-07-NPS (Ref.1) along with a recommendation (R-85-07-NPS-01) that the Manager of Power and Engineering appoint a records manager to provide upper management coordination for resolution of the open items which had been identified.
@ II. SCOPE A. The scope of this investigation is defined by the concern of record. It is that problems previously identified by NSRS investigation I-83-13-NPS, and the corresponding follow-up review R-85-07-NPS, have net been corrected for Sequoyah Nuclear Plant (SQN).
B. The secpe included determination of status and progress of the open items' identified in I-83-13-NPS and R-85-07-NPS as they pertain to SQN.
C. The scope of the follow-up investigation also included discussions with site and, task force personnel who are actively involved in the resciution of these items.
III.
SUMMARY
OF FINDINOS A. R-85-07-NPS contained recommendation R-85-07-NPS-01 which
- recommended that Power and Engineering (Nuclear) [P&E (Nuclear)]
appoint an upper-level manager empowered with the responsibility, authority, and organi:stional freedom to assure that records associated with the procurement and installation of Quality Engineering Branch (QEB) source inspected equipment and materials are assembled, verified for completeness, indexed, and stored for s retrievability. The recommendation further stated that the appointet's scope should include all past and future QEB source
, inspected procurements for SQN, as well as Watts Bar and l Bellefonte, and the establichment of a schedule for completion of past records.
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ATTACHMENT C PAGE 3 OF 7
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P&E (Nuclear) subsequently informed _NSRS (Ref. 3) that an appointment had been made, and' identified personnel who would, provide assistance to the appointee. Following the appointment.
meetings of the personnel were held on September 17, 1985, and December 16, 1985, to discuss resolution of the open items identified in NSRS follow-up review Report R-85-07-NPS. These meetings are documented in references 4'and 13 along with specific-action items and schedules for resolution of-the problems.
IV. STATUS OF PREVIOUSLY IDENTIFIED OPEN ITEMS A. Develop an Intenrated Records-System for Ouality Assurance (OA)
Recore; That 'Will Satisfy the Needs of Nuclear Power (NUC PR) and Office of Enmineerinz Desien Construction (OEDC)
- 1. iParagraph IV.A.1 of R-85-07-NPS states that a TVA task force ,
,,was working on vendor manuals at the time of the first NSRS I
- follow-up review, however, two areas of' concern were identified regarding vendor manuals as follows:
-a. A question was raised by NSRS regarding whether any of the' manuals were considered,"one-of-a-kin 8", and therefore, in
. g, *. need of fireproof storage. This finding was addressed in paragraph V.C of the report.
Subsequently, ID-QAP-6.2 (Ref.15) was. revised to require .
. that those vendor manuals utilized as plant instructions will be maintained as' QA records. This' requirement, in
. combination with ' existing requirements of AI-23 (Ref. 16),
appear to establish adequate protection for 'v'endor manuals for SQN.
- b. The applicable. procedures for vendor manual control were found *1 be vague in the delegation of responsibilities.
A task fcrce was developing a new procedure regarding the maintenance of vendor manuals which was expected to correct the problem. This finding was addressed in paragraph V.E of the report. Subsequently, ID-QAP-6.2 (Ref. 15) was revised to more clearly prescribe organizational responsibilities regarding the control of vendor manuals.
- 2. Paragraph IV.A.1 of R-85-07-NPS also states that records indexing procedures,had been prepared and were in various stages of implementation. It was further stated that this Acem l '
will remain open until more experience is gained by PT.E i j~ (Nuclear)' with the records indexing system. This matter is T discussed in the following paragraphs.
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- ATTACHMENT C PACE 4 0F 7
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B. Correct Impicmentinn Defielencies Identifled In the Existine Svstem
(_ 1. Paragraph IV.A.2.a of R-85-07-NPS states that QEB recceds'were l'
not adequately indexed and that there was some'cohcern
-regarding their completeneis. At the time of the the first NSRS follow-up review, efforts were under way to index and microfilm completed contracts however, a schedule had not been i established for completing the overall task. Initially, a completion date of December 31', _19 8 7 ,*' was set by the P&E I (Nuclear) task force (III.A) for completing the overall task for all projects (Ref. 4). However, a recent commitment was made that appropriate manpower resources will be expanded to ensure that a deadline of June 30, 1986, will be met for SQN' (Ref. 13). QEB is utilizing a four-step approach which 1- , includes' identification, location, verify completeness, and microfilming of the records (Ref. 4).
- Sequoyah has concurred with the parameters that QEB is using to I - index their records (i.e. , vendor / contract number) . However.
site personnel normally*must request the records by Unique-j- Identifier Number (UNID). Therefere, efforts are in progress i to provide a cross-reference between UNID and vendor / contract '
numbers. The Equipment Qualification Information System (EQIS) is being investigated as t,he link to provide this
'- " , cross-reference (Ref. 6 and 13). This item remains open.
7 .
L.' 2. Paragraph IV.A.2.b of R-85-07-NPS states that all'OC records for Sequoyah had been transferred or were in the final stages j s of microfilming at the time'of the first NSRS follow-up review.
.. Microfilming of all the records underway at the time of the review have been completed. However, another 175 cubic. feet of
. , contract-related files and various other records were discovered by SQN-DCU personnel in warehouses vacated by OC, in addition to several files at other locationsi SQN-DCU and RIMS-Chattoonsa personnel are working to microflim these additional records and have completed filming about 36 cubic 1
feet.' Manual indices will be es'tablished for these records pending resolution of problems associated with the Records
. Retrieval Index (RRI) system. Microfilming is proceeding on an i ,
- . "as-soon-as possible" basis (Ref. 10, 12, 13 and 14). This j item remains open.
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- 3. Paragraphl I .A.2.b of R-85-07-NPS also st,ates that a RRI system
} was prepared but'jud'ged t6 be not totally effective at the time 1 of the first NSRS follow-up review.
NUC PR personnel subsequently conducted 'a review of the RRI to
' identify deficiencies and initiate recommendations to correct any problems (Ref. 4 and 7). The NUC PR review confirmed that
, the RRI was deficidnt in several are'as and recommendations were
. made to identify all OC record types and develop detailed instructions, for the retrieval of each record.
3
'*'f..5; ATTACHMENT C PAGE 5 0F 7 The P&E (Nuclear) task force (III.A) established to resolve the a open items of R-85-07-NPS has taken the recommendations undere consideration and has acted to establish a sub-task group to
" rework the SQN RRI using original RRI guidelines" (Ref. 13).
The chairman of the sub-task group has met with cognizant personnel and is proceeding with effcrts to rework the RRI. A date for completion of the task has not been set. This item
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remain,s open.
- 4. Paragraph IV.A.2.d states that continued upper management coordination involvement at a level capable of crossins organization boundaries is considered necessary until the probless are solved and records systems prove effective.
This matter appears to have been adequately addressed by P&E
. (Nuclear) through actions discussed in paragraph III.A above.
Clarifv Ornanizational Responsibilities C.
PaEagraph IV.A.4 states that with the exception of a clearly
. defined system for vendor manuals, organizational responsibilities
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have been defined. Subsequent revision of ID-QAP-6.2 (Ref. 15) ,
appears to adequately prescribe responsibilities for vendor manual control as discussed in paragraph IV.A.1.b above.
D. Planned Actions and Schedules for Comoletion of Action Paragraph IV.B of R-85-07-NPS states that QEB had'not completed verification and indexing of their records for SQN nor had QEB'
. established a schedule for doing so at the time of the first NSRS follow-up review. Actions taken on this matter are discussed in paragraph IV.3.1 above.
V. CON 01.USIONS AND RECOPE.ENDATIONS .
A. Conclusion The employee concern is substantiated in that corrective action items shown in NSRS investigation *I-83-13-NPS have not been co=pleted for SQN. However, specific improvements have been achieved regarding vendor manuals, and work is steadily progressing toward the resolution of the remaining open items identified by NSRS. .
- B. Recommendation I-86-129-SQN-01. Continue Monitorinn i
NSRS should continue to monitor the status of open items from I-83-13-UPS as they pertain to SQN. [P3) 4
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ATTACHMENT C PAGE 6 0F 7 DOCUMENTS REVIEWED IN INVESTICATION NO. 1-86-129-SQN AND REFERENCES
- 1. . Informal Memorandum' f rom K. W. Whitt .to M. G. -Parris ** Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS -
Nuclear Safety Review Staff-(NSRS) Report'No. R-85-07-NPS." dated May 28,-1985 (A02 850529 010)
- 2. Memorandum f rom M. G. Parris to K. W. Whitt. " Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear-Safety Review Staff (NSRS) Report No. R-85-07-NPS " dated July 1, 1985 (L16 850624 840)
- 3. 'Homorandum from M. C. Parris o K. W. Whitt, " Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff.(NSRS) Report No. R-85-07-NPS," dated August 14, 1985 (L16 850729 883)
- 4. Memorandum from R. A. Pedde to Files, "NSRS. Report R-85-07-NPS - Follow-up Review of QEB Records Investigation - I-83-13-NPS." dated September 19, 1985 (Col 850919 004) '
. 5. Memorandum from M. M. McGuire to R. A. Pedde, "NSRS Report R-85-07-NPS."
~S dated September 24, 1985 (L16 850924 833)
- 6. Memorandum from H. M. McGuire to R. A. Pedde, "NSRS Report R-85-07-NPS," ,,
dated October 29, 1985 (L16 851029 887)
- 7. Memorandum from M. W. Madacek to M. M. McGuire, "NSRS Report R-85-07-NPS "
dated November 13, 1985 (L16 851113 895)
- 8. Memorandum from R. D'. Guthrey to James P. Darling, " Configuration Task Force - Activity Su:cary and General Assessment," dated August 8, 1985 (R25 850808 861)
- 9. Informal note from J. P. Vineyard to C. L. O' Dell regarding transfer of OC
-records to NUC PR, dated June 28, 1985 (B25 850628 002)
- 10. Memorandum from Alva LaMontagne to Nancy Welch, " Office of Construction (OC) - Sequoyah (SEQ) Site Records," dated September 24, 1985 (A31 850925 001)
- 11. Memorandum from M. M. McGuire,to R. A. Pedde, " Action Item 9-17-3 of NSRS Report No. R-85-07-NPS," dated November 21. 1985 (L16 851121 802)
- 12. Memorandum from Alva LaMontagne to John Ed Hayes,." Microfilming Sequoyah Construction Records " dated January 8, 1986 (A31 860108 051) 5
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ATTACRMENT C PAGE 7 0F 7 Memorandum from R. A. Pedde to Files "NSRS Report R-85-07-NPS - Follow-up
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13.
Review of QED Records Investigation - I-83-13-NPS." dated January 9, 1986 (Col 860109 003)
- 14. Memorandum from Alva LaMontagne to Nancy Welch, " Office of Construction (DC) - Sequoyah (SEQ) Site Contract Records," dated January 22, 1986 (A31 860122 051)
- 15. NUC PR Nuclear Quality Assurance Manual (NQAM), Part V. Section 6.2 (ID-QAP-6.2), " Vendor Manual control " revision dated December 31, 1985
- 16. Sequoyah Instruction AI-23,'" Vendor Manual Control." R21
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- . , ATTACID1ENT D PAGE 1 0F 7 i
TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-86-180-SQN
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' ,EHPLOYEE CONCERNS:
SQM-6-003-002 /
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SUBJECT:
SQN DRAWING CONTROL
'I 2 DATES OF INVESTIGATION: FEBRUARY 5-7, 1986 INVESTIGATOR: Lub' - '
O-d7~8'b J. J. KNIGHTLY DATE
( REVIEWED BY: bv 2/f"7/?/o l L. E. BROCK DATE A
APPROVED'BY: @A 2~
W. D. STEVENS DATE h
...' , ATTACHMENT D .
PAGE 2 0F 7 I. BACKCROUND
'A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of six expressed employee concerns as received by the Quality Technology company (QTC)/ Employee Response Team (ERT). The concerns of record, as summariced on the Employee Concern Assignment Request Form from QTC and identified as SQM-6-003-001 through'-006, stated:
SOM-6-003-001 Specific documents have been improperly issued.
Nuclear Power concern. CI has no further information.
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QTC Clarification: Design drawings for ECN L6027 have been improperly issued.
i=
SOM-6-003-002 Duplicate documents have been issued with conflicting data. Nuclear Power concern. CI has no further '
information.
-% QTC Clarification: Drawing 4SN1749-30 (R8) was issued twice on two separate mylars dated November 29, 1985 and November 30, 1985.
SOM-6-003-003 Il .
Specific documents have been improperly altered.
Nuclear Power concern. CI has no more information.
QTC Clarification: Drawings 15W810-44 (R7) and
- l. 45W833-1 (R9) were issued without Project Manager's initials in title block. Initials were added to the mylars after issue.
SOM-6-003-004 Falsification of' specific documents. Nuclear Power concern. CI has no further information.
QTC Clarification: The drawings identified in Concern SQM-6-003-003 were "coirected" without going through the NCR process.
SOM-6-003-005 Employee was directed to improperly change another employee's work. Nuclear Power concern. CI has no further information.
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. ATTACHMENT D PAGE 3 0F 7 QTC Clarification: The documentation included three significant condition reports (SCRs) submitted January 11, 1986.
SOM-6-003-Od6 CI feels an attempt is in process to ' cover up' a specific problem. Nuclear Power concern. CI has no further information.
- QTC Clarification: CI feels the significant condition reports identified in SQM-6-003-005 are being rewritten in such a way that the real problems will be misstated.
II. SCOPE A. The scope of the investigation was determined from the stated concerns of record and the respective QTC clarifications to be that of only the specific concerns contained in the stated QTC clarifications, i
B. To accomplish this investigation, NSRS reviewed applicable requirements, procedures, drawings, drawing management system
- reports, significant condition reports (SCRs), and open item tracking system reports for these SCRs. Additionally, responsible drawing control personnel were contacted to discuss the employee's .
concern. ,
III.
SUMMARY
OF FINDINCS A. Requirements and Co=mitments
- 1. Nuclear Quality Assurance Manual (UQAM), Part III, Section 1.1,
" Document Control," Revision March 21, 1985. " Preparation, review, approval, and issuance of documents and their revisions shall be accomplished in accordance with approved written procedures / instructions. These . . . shall include . . . the following requirements: . . . Final approval authority, Revision Controls. . . ."
- 2. Office of Engineering Procedure OEP-08, " Design output."
Project Manager ". .
. signs at ' Issued By' and distributes the drawing."
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, ATTACHMENT D PAGE 4 0F 7 B. Findings
- 1. Concern SQM-6-003-001
. A query of the Drawing Management System identified 25 drawings for.ECN L6027. A review of the file of issued drawings maintained in the Office of Engineering Technical Information Center (TIC) found that 24 of the 25 drawings were issued without the Project Manager's signature / initials as required by OEP-08. Paragraph 5.1.3. The affected drawings are as follow.
45N1673-5 (R9) 45N630-4 (R15) 45N1645-1 (Ell) 45N655-19 (R7) 45N1645 (R12) 45N655-44 (R7) 45N1648-1 (Rio) 45W1656-4 (R22) 45N1648-4 (R16) 45W1673-5 (R9)
- 45N1688-1 (R23) 45W2673-5 (R4) 45N1688-3 (R26) *47B601-55-46 (R12) 2 45N1693-1 (R24) 47W605-15 (R13) 45N1693-3 (R19) 47W605-16 (R13)
. 45N2645-1 (R9) 47W605-33 (R15) 47W605-35 (R16) '
45N2645-8 (R12) 45N2648-1 (R13) 47W610-30-01 (R28)
, 45N2648-4 (R9)
- issued with approval signature The nonconforains conditiens for these drawings were reported in SCR SQN SQP8602 RO dated January 11, 1986.
'. ,,,2.;,, Concern SQM-6-003-002 A review of Sequoyah Nuclear Plant (SQN) mylar drawings found that wiring diagram 45N1749-30 was issued twice at revision q level 8 on two separate mylars dated November 29 and 30, 1985.
The drawing was first issued at revision level 8 for LECN 6202/FCR 3583 and then issued the next day at the same revision h level 8 for LECN 6544/FCR 3966. In addition to these revision f y control errors, the drawings were also issued without Project f
V/ (g }ianager's signature / initials. A subsequent revision R9, references in the title block the November 30 issue. The nonconforming condition for the duplicate issuance was reported in SCR SQN SQP8601 RO dated January 11, 1986.
- 3. Concern SQM-6--003-003 A review of the appl'icable drawings 15W810-44 R7 and 45W833-1 R9 found that both were issued without the Project Manager's initials in the title block. The SQN mylar copies included initials at the time of investigation but the microfilmed sperture cards which were sent out on distribution did not.
Since the cards were reproduced from the mylars, it was evident that the initials were added after issuance and 3
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. ATTACRMENT D PAGE 5 0F 7 distribution. SQU document control personnci stated that the initials were added by unauthorized personnel and-in a manner which contradicted office practice. The DCU office supervisor stated that the proper method of correction was by reissuance of the drawing, recall of the incorrect drawing, and a memorandum of cxplanation to.the docume'nt holders. He stated that this correction would be initiated'prorptly. The nonconforming situation was reported in SCR SQN SQP8603 RO dated January 11, 1986.
4' . Concern SQM-6-003-004-As noted above, it was found that drawings 15W810-44 R7 and 45W833-1 R4 were issued without the Project Manager's initials and thInt., initials were added to the mylars without authorization after issuance. Because of_this bypassing of appropriate
. corrective action, which should have included recall of the incorrect drawings and reissue of correct ones, the distributed drawings were left in an uncorrected status. Thus, the additior.
.**of initials to the mylars did not cause anything to be changed in the system of distribution. It was determined that numerous individuals had access.to the mylars and could have placed the initials. It is not known who placed them or what their i
motivation may have been. The nonconfocming. condition
.concerning the initials is included in SCR.SQN SQP8603 RO.
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- 5. Concern SQM-6-003-005 Three draft SCRs dated January 11, 1986, concerning document control problems identified in this report were found to have
- been submitted to the SQN Design Project Coordinator. The Project Coordinator stated during interviews with NSRS that an-initial decision had been made to consolidate the three SCRs into one. However, after the writer of the SCRs indicated that this " consolidation" might obscure the facts of the nonconform-ing conditions, it was decided to go ahead and issue the SCRs exactly as written by the original writer. NSRS confirmed by review of the e=ployee's original handwritten draft.SCRs and the issued SCRs (SQN SQP8601 RO, SQN SQP8602 RO, and SQN SQP8603 RO) that the issued reports were word for word as originally drafted. The issued SCRs were dated January 11, 1986, and, according to the Project Coordinator, were transmitted
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l January 17. USRS confirmed that the SCRs were transmitted and received for tracking, evaluation, and corrective action by reviewing the TROI open item and reporting system report dated February 1,1986, w'hich showed the applicable SCRs as assigned and in progress. With the transmittals having been initiated l-Friday, January 17, and the employee's statement of concern dated Tuesday, January 21, it appears that the concerned i
l individual may not have known that the SCRs had in fact been j- peccessed and transmitted exactly as originally written.
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.. ATTACHMENT D PAGE 6 0F 7
- 6. Concern SQM-6-003-006 The facts of this concern are covered fully in the above report for SQM-6-003-005.
IV. CONCLUSIONS AND RECOMMENDATIONS A. Conclusions
- 1. Concern SQM-6-003-001. The employee's concern was substantiated.
- 2. Concern SQM-6-003-002. The employee's concern was substantiated.
- 3. Concern SQM-6-003-003. The employee's concern was substantiated.
4., Concern SQM-6-003-004. The employee's concern was substantiated.
5.' Concern SQM-6-003-005. The facts of the employee's concern were not substantiated.
- 6. Concern SQM-6-003-006. The facts of the employee's concern were not substantiated.
. ' ? /;*; B. Recommendations
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None. The applicable concerns have been documented for analysis and ..
corrective action by SCRs SQN SQP8601 RO f.QN SQP8602 RO, and SQN SQP8603 RO, all dated January 11, 1986.
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. ATTACHMENT D PACE 7 0F 7 DOCUMENTS REVIEWED IN INVESTICATION I-86-180-SQN AND REFERENCES
- 1. Nuclear Quality Assurance Manual (UQAM). Part III, Section ill, " Document
\ Control " Revision March 21, 1985
\ 2. Office of Engineering Procedure OEP-08 R0, " Design Output" N 3. Sequoya'h Nuclear Plant Administrative Instruction SQNP AI-25 R12 " Drawing Control After Unit Licensing"
- 4. Drawing Management System Report dated February 7, 1986, " Drawings Affected by ECN/FCR** (for ECN L6027) .
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- 5. Tracking and Reporting of Open Items (TROI) Report dated February 1, 1986
\ 6. Significant Condition Reports (SCRs) SQN SQP8601, 8602, 8603 (all RO)
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.f ATTACHMENT E PAGE I 0F 7 TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-86-185-SQN EMPLOYEE CONCERN
. _/
,. SQM-6-002-005 SQM-6-002-006 s/
SUBJECT:
- - SEQUOYAH NUCLEAR PLANT VENDOR DRAWING CONTROL DATES OF i FEBRUARY 12-13 and 19-20, 1986 INVESTIGATION
9.-
(/ b O D .3-4-[6 INVESTIGATOR: ' pg7g J. J. KNIGHTLY kus ?r he ,s.
r 2 d. M DATE REVIEWED BY:
M/ A( KOLTOWICH JMMr 3 "J' ~ h APPROVED BY: DATE W. D. STEVENS
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ATTACID1ENT E PAGE 2 0F 7
- 1. BACKGROUND l
A Nuclear Safety Review Staff (USRS) investigation was conducted to determine the. validity of expressed employee concerns received byThe the Quality Technology Company (QTC)/ Employee Response Team (ERT).
concerns of record, as summarized on the Employee Concern Assignment through -006, Request Form from QTC and identified as SQM-6-002-002 I stated:
SOM-6-002-002 Specific supervision is not responsive to correcting a quality problem in a'timel'y manner which can and is '
af fecting the quality' of the plant. (Names / details known to QTC, withheld to maintain confidentiality.)
No further information may be released. Nuclear Power concern. CI has no further information.
The office . supervisor for the SQN .,
QTCCIArification:
Engineering Project was asked by the employee to have a vendor drawing audit conducted in 1985 but no audit was ,
performed.
SOM-6-002-003 Specific supervision has neglected to perform a scheduled assignment which results in a continucus quality impact on the plant. (names / details known Nuclear to QTC, withheld to maintain confidentiality.)
Power concern. No further information may be released. CI has no further information.
An audit of vendor drawings was to QTC Clarification:
have been performed in September 1985 after a TVA drawing audit, but the vendor audit was cancelled.
SOM-6-007-004_
Specific supervision stopped corrective action on a quality problem that.had been identified months earlier. (Names / details known to QTC, withheld to maintain confidentiality.) No furtner information may be released. Nuclear Power concern. '-,.- CI has no further information. ,
QTC Clarification: Superv:Lsor denied a written request submitted by employee on January 9, 1986, to perform a vendor drawing audit.
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' ATTACHMENT E 'PAGE 3 OF 7 i ,.f- s
_ 0M-6-002-005 Controlled documents contain conflicting data relating (Names / details known to QTC,
-to the same installation. No further ,
withheld to maintain confidentiality.)
information may be released. Nuclear Power concern.
CI has no further information.
Applies to design drawings-mylars.
QTC Clarification:
l Check wash-off log for specifics. Better controls are
'eeded for the original mylars.
h -
- SOM-6-002-006- '
f Work is being performed to documents containing(Names / details known to conflicting or obsolete data. No further QTC, withheld to maintain confidentiality.) Nuclear Power concern.
information may be released.
CI'has no further information.
Concern is based on programmatic ,
QTC Clarification: problems that both a new mylar and old may exist each containing different data. '
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II. SCOPE -
A.
The scope of this investigation was determined frem the stated ht i
concerns of record and the respective QTC clarif cations. i B.
To accomplish this investigation. USRS reviewed applicable requ re-ments, procedures, drawings, drawing logs, and correspondence.
Additionally, responsible drawing control and reprographics personnel were contacted to discuss the e=ployee's concerns.
III.
SUMMARY
OF FINDINGS A. Requirements and Commitments
- 1. Division of Engineering Design Management "The TIC does not maintain pre-1975
! , VA Information Services." original vendor derawings All other vendor unless they ha revision control and sent to TIC for storage. have originals which were submitted to the TIC prior to 1975 been or are being microfilmed and destroyed."
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- * ' ATTACHMENT E PAGE 4 OF 7
- 2. Office of Engineering Office Instruction OE-0I 3001, " Drawing Originals - Checking Out and Checking In."
B. Findings
- 1. Concerns SQM-6-002-002 and SQM-6-002-003 The Office Supervisor for the Sequoyah Nuclear Plant (SQN)
Engineering Project came to the position in January .1985. He stated that drawing controls at that time for both the TVA and vendor drawings were not fully adequate; that original drawings for SQN design work were not always immediately available as needed; and that f-irst priorities for correction were placed on '
the TVA, drawings and on several other critical matters affecting the SQN engineering design effort. The vendor drawings received a second priority. The immediate supervisor verified to NSRS that this statement of priorities represented the management priorities at that time.
In order to. verify that all TVA drawings were available and to
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correct any deficiencies by reordering replacements (washoffs),
a TVA drawing audit was conducted during September-October ,
1985. The Office Supervisor verified the employee's statement that an audit of vendor drawings was to have been performed at 9,Q%i the conclusion of the TVA drawing audit. He stated that the vendor drawing audit was postponed from October 1985 to January 1986 because staff was needed on other projects, but that the -
audit was begun in January and had been in process for three weeks.
In order to maintain a dated listing of all replacement drawings requested from Office of Engineering, Knoxville, a washoff log was initiated by the SQN Office Supervisor on August 1, 1985.
The log included 240 entries at the time of the investigation in February 1986. Of these, approximately 220--over 90 percent of I the total--were for replacement vendor drawings with the remainder being for TVA drawings. The further investigation of these orders is reported below tuder finding No. 3.
- 2. Concern SQM...,6. 002-004 .
It was verified that the employee submitted a written request dated January 9, 1986, requesting overtime on several weekdays and a Saturday to set up contract files and audit "B" size TVA drawings. This request was denied by the supervisor in a form TVA 45D memorandum also dated January 9, 1986. The supervisor stated in the memorandum that he wanted to work with the employee with regards to contract drawings and noted that ". . .
we have real problems with manufacture drawing originals." He wrote that, "I currently am working on other clerical items with deadlines and cannot work with (the employee) . . . I am well aware of us being deficient as far as an audit is concerned but 3
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... ATTACHMENT E PACE 5 0F 7 we have been deficient since I arrived in January 1985. I don't feel another two weeks is going to be that critical to us."
Later that same month, the vendor drawing audit and corrective action activities ~were started and were in their third week at the-time of this investigation. .
3 .' Concerns SQM-6-002-005 and SQM-6-002-006 At the time a drawing original is determined to have been lost, a replacement original'("washoff") is requested from the Office of Engineering, Knoxville. The washoffs are produced from the microfilm aperture cards maintained by the Technical Information
' Center. As.noted above, approximately 240 washoffs were requested between August 1, 1985, and February 1986, with over 90 percent of' the replacements being for vendor drawings. The OE Reprographics Supervisor stated that because the vendor drawing originals before 1976 were routinely discarded, there is 1
a periodic need at the sites to provide washoffs from the aperture cards. Ile did not believe that the quantity of SQN
,," requests was unusual. He stated that SQN was the first site to centralize the auth'ority for washoff requests, thus minimizing duplicate or unnecessary' requests. No indicated that Knoxville i
desired similar centralization at the other sites. ,
When a replacement drawing is received at the Office of
6 Engineering SQN site, the rytplacement is ' checked in and becomes the new " original" which will be the baseline drawing for l
subsequent changes. If a missing drawing should eventually reappear and not be properly dispositioned, the potential would
( exist for the two " originals" to contain obsolete or conflicting The l data whenever one drawing was updated but not the other.
controls which are now in place to avoid lost and duplicative drawings include the following:
, (a) Drawing checkout system: Drawings are checked out from the
! drawing tanks on a Drawing / Print Request Form which includes a self-checking section for removal of drawings after hours if necessary. It was determined that the
- Office of Engineering Section heads had keys to the drawing area for access after normal working hours when drawing
~l control . personnel were not present. Although this provides some possibilities for drawings to " stray" af ter hours, the office supervisor did not believe this to be any major
' problem. He vigorously supported the necessity for 24-hour access to the, drawing originals, demonstrated the ease-of- ,
use of the checkout forms, and stated that the checkout records were updated promptly each morning f rom any foms left during t a nigh 1
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. * i ATTACHMENT E PAGE 6 0F 7 l (b) Drawing check-in system: Whenever it is necessary to-request a replacement for a lost original, a note is placed j in the drawing checkout file for any cases where the lost
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original reappears. Subsequently. if a drawing being.
checked in is one for which a replacement had been. ordered, y
the document control clerk is flagged to cancel the qf ,jhs# ,
replacement order or to withdraw one or the other original from the system. '
l4' (c) Centralized ordering of replacements: As noted above..SQN is the first TVA site to centralize the authority for washoff requests. OE Reprographics is to deny all requests 4
except those channeled through the authority. The OE Supervisor of Reprographics stated.that this centrali=ation is helping to eliminate duplicative requests wherein two or more individuals might order the same repl~acement.
IV. CONCLUSIONS AND RECOMMENDATIONS A. Conclusions ,
i 1. Concern SQM-6-002-002. The employee concern,for vendor drawing p a f,r controls is substantiated, but the concern for supervisory responsiveness is.not substantiated. The vendor drawing audit was delayed until.1986 because of other reasonable priorities. -
The audit is now in progress.
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- 2. Concern SQM-6-002-003. The employee concern is not substan-tlated. Supervisory neglect was not identified.
- 3. Concern SQM-6-002-004. The employee concern is not substan-tlated. The supervisor denied a request for overtime but did not stop corrective action. Corrective action is in progress.
- s. 4.:. Concern SQM-6-002-005 and SQM-6-002-006.- The e=ployee concerns ,
' for duplicative mylars are substantiated in that this condition does sometimes exist. The concern is mitigated by the finding that several. controls are in place to minimize the condition.
Support was not identified for additional controls such as further limitation of access to the mylars.
B. Recommendations I-86-185-SQN-01, Trackint of Corrective Action -
Corrective action concerning SQN vendor drawing controls is in progress through (1) performance of a vendor drawing audit which began January / February 1986 and (2) controlled replacement of drawings where needed. Controls to minimize recurrence of dupli-cative mylars have been developed and are in place. There are no additional recommendations, but SQN should provide notification to NSRS when corrective action is completed. IP-3]
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ATTACHMENT E PAGE 7 0F 7 DOCUMENTS REVIEWED IN INVE::TICATION 1-86-185-SQN AND REFERENCES 1.
Office _od Engineering Office Instruction OE-0I 3001, " Drawing originals Checking Out'and Checking In" 2.
Division of Engineering Design Management and Engineering Data Syste:as (MEDS) Procedure MP 23.05, "EN DES and Vendor Drawings - Inf ormation Services" 3.
Office of Engineering Office Instruction Manual OE-0I 4003, " Prints and Microfilm - Routine Distribution" * .
4.
Memorandums S. t..Yodd to John Dennis. and Jack Valentine dated January 9,
' 1986; and Jack W. Valentine to John Dennis dated January 9, 1986 o- ,
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