ML20210G367
| ML20210G367 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/02/1987 |
| From: | Akeley W, Joyce J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| 80000-SQN, 80000-SQN-R03, 80000-SQN-R3, NUDOCS 8702110266 | |
| Download: ML20210G367 (20) | |
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,- TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80000-SQN REPORT TYPE REVISION NUMBER:
Element Report 3 TITLE: PAGE 1 0F 14 General Management and Policy REASON FOR REVI3 ION: Rewritten to comply with Writer's Guide and incorporate of any SRP and TAS consnents.
Deletion of issue.
Revision indicators are not shown on each page as the reformatting entailed a complete rewrite.
Note: Sequoyah Applicability Only PREPARATION PREPARED BY: Waync M. Akeley/ Ronald D. Halverson ft W W )h. 0 ?c Qt, Ilds/E7 s SIGNATURE / ' DATE REVIEWS PEER:
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APPROVED BY:
MO/h 8 ECSP MANAGBR 1/I/37 DATE N/A MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's Signature denotes SRP concurrence are in files.
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I. t REPORT NUMBER REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3 General Management and Policy PAGE 2 OF 14 1.0 CHARACTERIZATION OF ISSUE 1.1 Introduction The issues described in this element report were derived from employee concerns generated as a re su lt of the Watts Bar Employee Concern Special Program. The issues were determined to be applicable to the Sequoyah Nuclear Plan t (SQN) and were investigated and evaluated on s that basis.
1.2 Description of Issues The conditions reported by concerned employees are:
- a. A nonchalant regard for quality sets an exagle for subordinate employees to likewise promote and tolerate poor quality at Sequoyah. (XX-85-ll6-005)
- b. During the exit interview the concerned individual (CI) expressed the concern that mistakes made at SQN and other plants are not corrected. (WBN-86-066-001)
- c. Elec trical General Foreman was reprimanded for using Non 'Q' materials in 'Q' systems, but continued to tell his workers to do this . (XX-85-033-006)
) d. CI was requested by supervisors to sign-o ff data sheets on de fective equipment. CI initially re fused to sign because corrective action had not been taken. CI was asked second time to sign the data sheets and did so to avoid getting a le tter for insubordination. (XX-85-027-X07)
- e. TVA informed the Nuc lear Regulatory Commission (NRC) that cable had been removed from the site in 1981. When in fact the cable was still being removed in 1984. This is documented on l Nonconformance Report (NCR) SQN EEB 8019RI. (XX-85-027-X03)
- f. Process for evaluation of 10CFR21 applicability. (BFN-IESC 03)
- g. Inadequate und ers tand ing of the level of control required in nuclear parts program is indicative of weakness in NQAM. (BFN-l IESC-85-03) p h. The issue of " con figura tion control" was not evaluated as this
[ issue is adequately covered in operations Element Report 307.13-l SQN. (BFN-IESC-85-03) 1 t
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REPORT NUMBER:
REPORT: TYPE 80000-SQN
' Element Report REVISION NUMBER:
TITLE: 3
' General Management and Policy PAGE 3 0F 14 2.0
SUMMARY
2.1 Sununary of Characterization of Issues Principal issues raised by concerned employees are: nonchalant regard for quality, mistakes are not corrected, Non-Q materials are used in Q systems, improper sign-of f on data sheets, the NRC was misinformed of cable removal, the process for evaluating 10CFR21 applicability is questioned, inadequate understanding of the nuclear parts program, and configuration control.
2.2 Sunnary of Evaluation Process Upper tier and lower tier documents were reviewed. to determine requirements' and responsibilities along with the procedural direction.
Correspondence, codes, standards, proce,dures, instructions, inspection reports, nonconformance reports, and memorandums were also reviewed to determine the full extent of the concerns and their overall significance to the Sequoyah Nuclear Plant. Additionally, discussions were . held with various TVA personnel pertaining to specific problem areas regarding elec trical cables, spare parts, procurement, and battery inspections.
2.3 Sunenary of Findings The conclusions reached as a result of the Quality Assurance Category Evaluation Group (QACEG) evaluations of these issues are:
The issues regarding " nonchalant regard for quality promotes poor quality" and " mistakes made were not corrected" could not be properly evaluated due to the vagueness and lock of specific information.
The issue of using "Non 'Q' materials in 'Q' systems" was substantiated in that a general foreman instructed craft personnel to use a QA Level I or II part which did not have the required documentation.
-The issue of " improper sign-o f t s on data sheets" could not be sub stant ia ted. The sign-o f ts required of the inspector did not signify QA acceptance, but rather documents the identity of the in spec tor performing and documenting the results of the inspection.
The issue that "TVA in formed the Nuclear Regulatory Commis sion that cable had been removed from the site 'in 1981 when in fact the cable was still being removed in 1984" is substantiated, in that SQN Nonconformance Report (NCR) 8019 improperly stated that all PJJ and PNJ cable had been removed as documented by Transfer Requisition 858512.
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, REPORT NUMBER REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3 General Management and Policy PAGE 4 OF 14 The issue of " Process for evaluation of 10 CFR 21 applicability" is unsub stantia ted in that documentation pertaining to these reviews was available and that procedural guidelines were properly followed.
The issue of " inadequate understanding of the control required for the nuclear parts program" is sub stantiated. Personnel did not fully understand procurement requirements due to program inad equac ie s.
2.4 Sumary of Corrective Action Regarding the use of Non "Q" materials it was determined that an isolated instance did exist where Non "Q" Material was improperly installed in a "Q " System. However, the part was replaced and appropriate disciplinary action taken. With respect to the PJJ and PNJ_ cable, it was determined that all cable had not been removed which has resulted in Environmental Qualification for those type cables. In addition, a CATD has been initiated to provide expec ted completion dates for cable testing. Responses to this CATD were evaluated and results concurred with the QACEG. Correc tive actions towards improving the Procurement Program have been initiated which should help streamline the system.
3.0 LIST OF EVALUATORS W. M. Akeley R. D. Halverson 4.0 EVALUATION PROCESS 4.1 Ceneral Method o f Evaluation This evaluation was performed by reviewing many documents such as l inspection reports, Inspection Ins tructions / Guideline s , Notice of Indic ations (NOI), Construction Procedure s/ Spec ifications, Quality Assurance Procedures, American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel codes, Design Standards, Work Requests, Nuclear Quality Assurance Manual (NQAM), Nonconformance Reports (NCR),
l memorandums , and TVA's QA Topical Report. In addition, discussions l with cognizant personnel were held pertaining to specific problem
! areas regarding each issue.
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REPORT NUMBER:
-REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3 General Management and Policy PAGE 5 0F 14 4.2 Specifics of Evaluation 4.2.1 Issue - Nenchalant Regard for Quality Reviewed Employee Concern File including Confidential Files for any additional information pertaining to this concern. No additional information was available.
4.2.2 Issue - Mistakes Not Corrected
< Reviewed Employee Concern File including Confidential Files for any additional information pertaining to this concern. No additional information was available.
4.2.3 Issue - Use of Non "Q" Materials in "Q" Systems Reviewed Employee Concern Files including Confidential Files for any additonal information pertaining to this concern.
Nuclear Safety Review Staff (NSRS) Report I-85-814-SQN was reviewed documenting the investigation and findings of this concern. Codes, standards, procedures, instructions, and reports reviewed 'during this investigation are included in the NSRS Report.
4.2.4 Issue - Data Sheet Sign Off Reviewed Employee Concern Files including Confidential Files for any additional information pertaining to this concern.
Quality Technology Company (QTC) Report XX-85-027-X07 documenting the investigation and findings of this concern was reviewed. This report was utilized during the evaluation process of this concern and its contents re-evaluated by QACEG. This report draws the same conclusion as the QACEG eva luation.
In conjunction with the QTC Report, Inspection Instruction No.
19, Revision 9, " Battery Inspection", Inspection Instruction No. 30, Revision 7, " Receipt Inspection", and Nonconformance Report 2803, were also reviewed during this investigation.
4.2.5 Issue - Nonconforming Cable Not Removed From Site.
Reviewed Employee Concern File including Confidential Files for additonal information pertaining to this conc ern . NSRS Report I-8 5-218-SQN , documenting the investigation and findings of this concern, was used as the basis of the Summary and Findings section of this report and includes various documents reviewed during this investigation.
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REPORT NUMBERt .
REPORT TYPE 80000-SQN Element Report . REVISION NUMBER:
TITLE: 3
- General Management and Policy . PAGE 6 OF 14 e
4.2.6 Issue - Process. For Evaluation of 10 CFR 21 Applicability.
Reviewed Employee Concern File including Confidential Files for any additioral information pertaining to - this concern.
The Nuclear Operations Quality Assurance Manual (N0QAM) . Part III- Section 2.1, entitled " Procurement of Ma te rials ,
Components, Spare Parts, and Services" was reviewed in conjunction with Appendix F, Attachment 1 of N0QAM Part III, i Section 2.1 to determine if appropriate requirements were contained in N0QAM and implementing procedures. SQNP SI-114.1
" Inservice Inspection" in conjunction with N0QAM Part III, 4
Section 7.2 was also reviewed . to ascertain if unacceptable i indications noted during random inspections were in fact evaluated for significance and for potential reportability.
Four Notice of Indications (NOIs) and associated documentation of unacceptable conditions, identified _ by liquid penetrant 4 me thods , were reviewed to assure that these ' indications were properly evaluated for 10 - CFR 21 applicability in accordance with the site inservice inspection program. Additionally, six purchase requsitions were also reviewed attesting to the implementation of 10 CFR Part 21 requirements.
Reviewed Engineering Procedure NEP-4.1 Revision 0,
" Procurement", and recently prepared material requaitions to determine engineering involvement as it also applies to the requirements of 10CFR21.
4.2.7 Issue - Inadequate Understanding of Level of Control Required in Nuclear Parts Program-The -initial investigation was spent gaining an understanding of the basic mechanics of site procurements (forms .used, terminology, and coordination required) and reviewing procurement files. Four Quality Control personnel were interviewed to ascertain their understanding of the total procurement system and to identify their specific re sponsibilitie s.
5.0 -FINDINGS 5.1 Findings on Issue - Nonchalant regard for Quality Discussion This issue, can not be properly investigated or evaluated due to the vagueness and lack of specific information.
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REPORT NUMBER:
REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
, TITLE: 3 General Management and Policy PAGE 7 OF 14 5.2 Findings on Issue - Mistakes are not corrected.
Discussion This issue, can not be properly investigated or evaluated due to the vagueness and lack of specific information.
5.3 Findings on Issue - Use of Non "Q" materials in "Q" systems Discussion Further information was requested from the Employee Response Team (ERT) to identify the approximate time trame to which the concerned individual was referring. The ERT indicated that the events occurred sometime between February 1984 and early 1986.
QACEG utilized NSRS Report I-85-814-SQN in the evaluation of this concern. On May 9, 1985, during maintenance on solenoid valves 2-FSV-1-183A, an elec trical general foreman in the Sequoyah Elec trical Main tenance Section instructed craf t personnel to use a QA level I or II part (diode) which did not have required documentation. This work was being performed under maintenance request MR A-300161. Solenoid valve 2-FSV-1-183A is a critical component as defined by Sequoyah Standard Practice SQA134, Appendix A, part III, " Critical Structures, Systems, and Components CFC List". MR A-300161 stipulated the specific use of Maintenance Instruction MI-6.20 and Modification and Addition Instruction MAI-12. These procedures require, among other things, that QA personnel inspect the crimping of the diode. Con trary to these requirements, the general foreman instructed craft personnel to install the diode without proper documentation and QA inspection.
This action by the general foreman resulted in a formal reprimand.
MR A-201203 was submitted and work initated on May 10, 1985, to inspect and replace the Non-Q diode with a diode having the proper g documentation. On May 16, 1985, the Elec trical Maintenance Section Supervisor discussed the gravity of the general foreman's failure to follow proc edures and his responsibility. Based on this discussion and the formal reprimand, the section supervisor was of the opinion that the general fo reman clearly understood the signi ficance of his actions and what is expected in the fu ture. The section supervisor is not aware of any additional ins tances whe re this or any o ther electrical general foreman has instructed craf t to use Non-Q parts in QA systems. The Electrical Maintenance Section Craft Unit Supervisor directly supervises the section's electrical general foreman. The unit supe rvisor recommended the disciplinary action to the section supervisor following the May 9, 1985 inc ident. To the best of the unit supervisor's knowledge, the practice of instructing the craft to violate plant procedures has not continued.
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REPORT NUMBER:
- REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3 Ceneral Management and Policy PAGE 8 OF 14 The Elec trical Maintenance Section is stafted with seven elec trical crew foreman and approximately 42 journeyman electricians. Inte rviews were conducted with two of the crew foremen from day shift, the evening shift crew foreman, a dual rate foreman, and the day shift general foreman. In additon, three electricians were interviewed from the day shift and four electricians from the evening shift. These individuals were selected at random. None of the individuals interviewed stated that they were ever instructed to use Non-Q parts in QA systems nor were they aware of any electrical general foreman currently doing so.
Conclusion The -concern of record is substantiated in part. It was substantiated that a situation occurred in which craft personnel had been instructed to install a QA level part without proper documentation and to proceed with its installation in violation of approved plant procedures.
Action was taken immediately to replace the part and action was taken to discipline the responsible electrical general foreman. The disciplinary action appears to have been e f fec tive. No evidence exists that the general foreman continued to tell of his workers to do this or similar failure to follow plant procedures.
5.4 Findings on Issue - Data sheets sign-off Discussion This issue is based upon SQN NCR 2803 written on July 21, 1982 identifying unacceptable electrolyte level with the fifth diesel generator battery cells. This nonconforming condition was originally identified in accordance with SNP Inspection Instruction No. 19 and documented on Data Sheet 1, " Battery Insp ec tions", dated 6/18/82.
Office of Nuclear Power (ONP) disposition to NCR 2803 was to reduce the specific gravity of the battery electrolyte by using the " Approved Power System Procedure" (MEB '811230 995). This disposition, Rev. 1, was written 12/22/82. However, it wasn't approved by the Design Project Organization and assigned to disposition Block 6 of NCR 2803 until 6/14/83. As evidenced by the NCR (Block 8), the assigned disposition was completed and the batteries released from a nonconforming status on 7/5/83. During the period when the noncon forming condition was identified (6/18/82) and when corrective actions were completed (7/5/83), periodic inspec tions (bi-weekly, mon thly, and quarterly) were being per formed as required by SNP Inspection Instruction No. 19. This procedure required the Electrical Engineering Unit to issue Data Sheet 1, " Battery Inspection," and the Inspection Group inspector to document the results of this inspection On the bottom of Data Sheet 1, there is an area
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provided for the s igna ture of the inspec tor and the date the inspection was per formed. In this instance, this signature and date does not signify QA acceptance, but rather documents the identity of the inspector performing the periodic inspections.
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REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3
> General Management and Policy PAGE 9 0F 14 Conclusions The concern indicates the Concerned. Individual (CI) is re luc tant to sign off data sheets when the acceptance criteria of SNP Inspection
. Instruction No. 19 has not .been met was . unsubstantiated. The
, concerned employee has no valid reason to . refuse to sign the data sheet as the signature on Data Sheet 1 is for identifying the inspec tor . entering the inspection results and does not signify acceptance of the item.
5.5 Findings on Issue. - IELC misinformed of cable removal Discussion As a result of OE evaluations of NUREG-0588, specific applications of PJJ and PNJ types of- cable were identified as not qualified for the accident environmental condition. This entailed the ' issuance of NCR SQN EEB 8019 and various TVA letters to the NRC informing them of 10 CFR 50.55 (e) deficiencies. Between June 16,-1980 and June 29, 1981, five status reports concerning NCRs issued on environmental
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qualification were sent to the NRC. However, none addressed PJJ and PNJ cable _ nor contained any information that indicated to NRC that issued PJJ and PNJ cables had been removed from SQN in order to prevent further installation. The disposition of NCR 8019. required
- e:.wn1 of all remaining cable of type PJJ and PNJ. Although this was wt completed in a timely manner, a majority of PJJ and PNJ cable was i-removed from Sequoyah as evidenced by Trans fer Requisition 828512.
However, NCR 8019 improperly stated that all PJJ and PNJ cable had been removed by Transfer Requisition 828512.
Conclusion This issue is sub stantia ted in that all PJJ and PNJ cable was not removed from the site as stated in the NCR. Five status reports from June 16, 1980 to June 29, 1981 concerning NCRs written on environmental qualification were sent to the NRC. However, all five
'did not address PJJ and PNJ cables.
5.6 Findings on Issue - Process for evaluation of 10 CFR 21 applicability Discussion It was determined from reviewing all pertinent correspondence and in formation provided in the Confidential Files that the concerned individual was conc erned with the 10 CFR Part 21 reportability of vendor supplied items.
There are- two dis tinc t groups within the Sequoyah organization currently purchasing ma ter ial . The Nuclear Power Division procures items in accordance with Part III of the Nuclear Quality Assuranc e
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- REPORT NUMBER REPORT TYPE 80000-SQN '
Element Report REVISION NUMBER:
TITLE: 3 Ceneral Management and Policy PAGE 10 0F 14 Hanual, supplemented with Standard Practice SQA45 (" Quality Control of Mate rials and Parts and Services") and the Nuclear Engineering Group
, procures material for modifications in accordance with NEP-4.1, entitled '? Procurement". 'Each group determines whether 10CFR21 requirements are applicable to the supplier for procurement of items and services. The -Nuclear Engineering Group, is required in accordance with Section 3.0, paragraph 3.6 of NEP-4.1, and Attachment 24 , "10CFR21 Applicability" to assure that. TVA procurement
- specifications and requisition packages for nuclear safety-related items meet the reporting requirements of 10CFR21.
This concurrence is documented on material requisitions. Ten SQN requisitions prepared during 1979-1981, and five recently prepared requisitions of material purchased by the Design Engineering Group, were reviewed to assure that documentation attesting to 10CFR21 j
applicability was available. All documentation reviewed was satis fac tory. The Nuclear Power Group currently purchases items in accordance with Nuclear Operations Quality Assurance Manual (N0QAM)
Part III, Sec tion _2.1, evaluates each item or service for 10CFR21 applicability by the use of Attachment 1, Appendix F entitled
" Determination of Basic Component Status and 10CFR Part 21
' Applic ability". The review of the fif teen SQN Purchase Requisitions prepared between 1979-1986 revealed that all had been appropriately reviewed for 10CFR Part 21 applicability with corresponding documentation substantiating all reviews.
Further investigation was conducted to as sure that the process for evaluation of 10CFR Part 21 applicability was conducted regarding the Inservice Inspection (ISI) Program. Surveillance Instruction SI-114.1, Section 17.0 entitled " Notification of Indication" requires the
! organization assigned responsibility for repair within NUC PR to dete rmine if the unacceptable condition is significant and potentially reportable in accordance with the requirements of N0QAM, Part III, Sec tion 7.2. A review of four of 34 Notification of Indication forms reporting unacceptable indications identified by the liquid penetrant examination method, indicated each had been evaluated for 10CFR Part 21 applicability as required.
Conc lu s ion This issue is unsubstantiated at SQN, based on the fac t that the appropriate documentation prepared by each purchasing group was reviewed and found satis f ac tory. Additionally, the process by which determinations of 10CFR Part 21 applicability are made was found to be satis fac tory.
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REPORT NUMBER:
REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3 General Management and Policy PAGE 11 0F 14 5.7 Findings on Issue -
Inadequate understanding of the level of control in the nuclear parts program.
Discussion The issue of whether inadequate understanding of the level of control in the Nuclear Parts Program was indicative of a NQAM programmatic weakness was substantiated by the QACEG investigation.
Part III, Section 2.1 of the Nuclear Quality Assurance Manual (NQAM) provides the methods for controlling the procurement of materials components and spare parts. A review of the NQAM determined that it assigns responsibilities and provides interpretation of regulatory requirement s, invokes the applicable quality assurance program requirements listed in ANSI N45.2, Appendix B to 10CFR50, ASME Section III and Section XI, and fur ther inplement s the requirements of ANSI N45.2.13.
Prior to 1984, TVA recognized that the procurement program was in need of strengthening. This was further substantiated by the fact that the l NSRS investigation performed during June 11, 1984 and December 5,1985
+ also reiterated the fact that de ficiencies did exist with various aspects of the program. The problems we re categorized into five areas:
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{ a. General unfamiliarity with procurement cycle i
Excessive and/or ine f fec tive review of Purchase Requests and b.
j requisitions i
- c. Ineffective use of the available procurement system
- d. Apparent lack of planning, and
- e. Quality Assurance
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i j These de ficient areas we re also addressed and reconunendations provided. These recommendations consisted of:
- a. Establish a planning group
- b. Improve Purchasing / site communications
- c. Eliminate unneesssary procurement cycle steps, and
- d. Better utilize automated systems
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j Additionally, interorganizational communic ations and working i relationships we re d eveloped to help solve problems and streamline operations. With respect to previously identified weaknesses within
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REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3 General Management and Policy PAGE 12 0F 14 the NQAM, seve ral revisions have been issued which provide for additional training . requirements, organizational changes, review approval cyc le s, and current commitments. .The QACEG evaluation concentrated on inte rviews with six personnel in the Sequoyah Procurement Program. These interviews indicated that although weaknesses have been identified as previously noted, the program has been expanded and enhanced to comply with procurement commitment s.
Also, the personnel actually involved currently in day to day procurement activities appeared to ' have adequate knowledge of the level of control regarding nuclear parts. Additionally, SQA45, entitled " Quality Control of Material, Parts and Se rv ices ", dated May 30, 1984 and Administrative Instruction AI-ll entitled " Receipt Inspection Nonconforming Items, QA Level / Description Changes and Sub st itiu te s", dated May 21, 1984 with recent revisions, were reviewed to determine program compliance. It would appear that the many problems previously experienced with the NQAM prior to 1984 caused confusion among those involved in daily procurement activitie s. With recognition of these program inadequacies by management and site personnel, and the re training and program manual revisions, indications are that the program is better organized and capable of controlling materials at IQN.
Conclusion This issue is sub stantiated by the fact that the many problems identified with the NQAM did in fact cause confusion and contribute to the misunderstanding of the control requirements by the the procurement program.
5.8 Corrective Actions This section encompasses correc tive measures taken and the results achieved to date on behalf of TVA and also those corrective actions identified during this evaluation.
Issue - Use of Non "Q" materials in "Q" systems Maintenance Request (MR) A-201208 was submitted and worked on May 10, 1985, to replace the Non-QA diode with a diode having proper documentation and required inspections were per formed. On May 16, 1986, the general foreman responsible was formally reprimanded by the Ma intenance Section Supervisor for not following site procedures. The re su lt. s of the QACEG investigation indicates this was an isolated incident with no further corrective actions necessary.
Issue - NRC was misinformed of cable removal all PJJ and PNJ cable was not removed from the site as stated in the NCR.
At the time or NCR 8019 c los ing, inadequate action was taken to prevent further installation, and ac tion was not taken to ensure that
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REPORT TYPE 80000-SQN Element Report REVISION NUMBER:
TITLE: 3 General Management and Policy PAGE 13 0F 14 all unused cable had been removed from the site. Failure to write a site NCR and to quickly remove from the site these cables resulted in its noncontrolled use. However, the adequacy of PJJ and PNJ cables installed at SQN has been evaluated as part of the elec trical equipment Environmental Qualification Project. Corrective action regarding this issue was determined to be required. SQN EQ Project has demonstrated Environment Qualification for TVA Type PJJ Cable installed in 50.49 circuits. Review of the SQN Electrical Equipment List shows that no PNJ Cables (or cables of the same family) has been installed in 50.49 circuits.
Issue - Inadequate understanding of level of control required in the Nuclear Parts Program.
Correc tive actions regarding the procurement program are presently ongoing in that improved interorganizational ' communica tions and working relationships have been developed to help streamline operations. Additionally, several recommendations directed toward changing and improving the system have also been initiated. The re sult s of the QACEG investigation indicates that these corrective actions are all essential elements within the procurement process.
A Corrective Action Tracking Document (CATD) No. 80000-SQN-01 was initiated to provide an expected completion date for testing the cable in question.
A response to this CATD was prepared and acknowledged by the Watts Bar ECTG on 11/21/86. Corrective action regarding this issue was determined not to be required. The SQN EQ Project has documentation to demonstrate environmental qualification for TVA type PJJ cable installed in 50.49 circuits at SQN. This documentation is contained in Sequoyah Environmental Packages SQNEQ-CABL-001, -015, -0 20, and -
0 34. Review of the Sequoyah Electrical Equipment List (SQEL) shows that no PNJ cables (or cables from the same family) has been installed in 50.49 circuits. The QACEG has evaluated this response and concurs with it 's conc lusion.
Attachment A, identified the issues as potentially sa fety-significant or safety related. However, QACEG evaluation ccncludes that only issue XX 027-X03 was potentially sa fe ty-s ignific ant. This identifie s that unacceptable cable was not properly controlled which resu lted in its subsequent use. This issue was determined to have no impact on safety and although some of the remaining issues were sub stan tiated, they were not considered detrimental to the sa fe or reliable operation of the Sequoyah Nuclear Plant.
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REPORT NUMBER:
- REPORT TYPE 80000-SQN
- Element Report REVISION NUMBER:
TITLE: 3 Ceneral Management and Policy PAGE 14 OF 14 6.0 ATTACHMENTS A. Employee Concern Program System (ECPS) List of Employee Concern In formation B. Corrective Action Tracking Document (CATD) No. 60000-SQ3-01 I
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ATTACHMENT A $db lb
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TENNESSEE VALLEY AUTHORITY PAGE %
REFERENCE - ECPS120J-ECPS121C FREQUENCY - REQUEST OFFICE OF HUCLEAR P0HER RUN TIME - 14:2-ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 01/2 EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY CATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80000 GENERAL MANAGEMENT AND POLICY S 1 REPORT APPL H 2 SAF RELATED SUB R PLT 3 FIND CLASS HISTORICAL CONCERN CONCERN NUMBER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION
________________ ___ _____ _ ___ __ __ __ __ ______________ ______ __---=_ _________________________________-
BFNIESC-85-03 01 v# OP 30713 S BFN 1 OECP CONCERNS EXPRESSED REGARDING: 1. PROCESS FOR 2 LUATION OF 10CFR21 APPLICABILITY. 2. INADEQUA 3 UNDERSTANDING OF THE LEVEL OF CONTROL REQUIRED 02 QA 80000 S BFN 1N N Y N NUCLEAR PARTS PROGRAM IS INDICATIVE OF HEAKNESS 2 NA NA SS NA NQAM. 3. CONFIGURATION CONTROL.
3 NA NA C NA HBN-86-066-00101 / QA 80000 S HBN 1N N Y N NSRS DURING THE EXIT INTERVIEH THE CI EXPRESSED COMO 2 NA NA SR HA THAT MISTAKES MADE AT SQN AND OTHER PLANTS ARE 3 NA NA A NA T CORRECTED. THESE SAME MISTAKES ARE ALSO MADE 02 QA 80601 S HBN 1Y Y N Y HBN.
2 SR SR NA SR 3 NA XX -G5-027-X0301 / QA 80000 N SQN 1N N Y N I-85-218-SQN QTC TVA INFORMED THE NRC THAT CABLE HAD BEEN REMOVE T50056 2 NA NA SS NA ROM THE SITE IN 1981. HHEN IN FACT THE CABLE H 3 NA NA E NA STILL BEING REMOVED IN 1984. THIS IS DOCUMENTE N AN NCR SGNEEB8019RI. BACKUP / ADDITIONAL INFOR ION IN FILE.
XX 027-X0701 / IH 60400 S SQN 1 XX-85-027-X07 QTC CI HAS REQUESTED BY SUPERVISOR TO SIGN OFF DATA T50078 2 EETS ON DEFECTIVE EQUIPMENT. CI INITIALLY REFU 3 TO SIGN BECAUSE CORRECTIVE ACTION HAD NOT BEEN 02 QA 80000 S SQN 1N N Y N KEN. CI HAS ASKED SECOND TIME TO SIGN THE DATA 2 NA NA SS NA EETS AND DID SO TO AVOID GETTING A LETTER FOR I 3 NA NA B NA BORDINATION. (NAMES, EQUIPMENT, AND OTHER ADDIT AL INFORMATION ARE KN0HN)
XX 033-00601 V'IH 60400 S SQN 1 I-85-814-SQN QTC SEQUDYAH ELECTRICAL GENERAL FOREMAN (KNOHN) HA T50181 2 EPRIMANDED FOR USING NON "Q" MATERIALS IN "Q",S 3 EMS, BUT CONTINUED TO TELL HIS HORKERS TO DD 1H 02 QA 80000 S SQN 1N N Y N (CONSTUCTION DEPARTMENT CONCERN) C/I HAS NO F 2 NA NA SS NA HER INFORMATION.
3 NA NA C NA XX 116-00501/ QA 80000 S SQN 1N N Y N QTC A NONCHALANT REGARD FOR QUALITY SgTS AN EXAMPLE T50271 2 NA NA SS NA R SUBORDINATE EMPLOYEES TO LIKEHISE PROMOTE AND 3 NA NA A NA LERATE POOR QUALITY AT SEQUDYAH. NUCLEAR POWER PARTMENT CONCERN. DETAILS KNOHN TO QTC, HITHHE 02 QA 80605 S SQN 1Y Y H Y 2 SS SS NA SS DUE TO CONFIDENTIALITY. NO FURTHER INFORMATION 3 NA Y BE RELEASED. CI REQUESTS THAT QTC PERFORM TH i INVESTIGATION.
6 CONCERNS FOR CATEGORY QA SUBCATEGORY 80000 7
l
< ' s \ ATTACHMENT B \ Page 1 of 5
/ z ,/ '
i ,
KITAr^il/4?JJT [',
p 1/5 E7 / ECSP CORRECTIVE Action Tracking Document (CATD)
, INITIATION
^
- 1. Immediate Corrective Action Required: /_/ Yes /_l_i/ No
- 2. Stop Work Reconsnended: /[/ Yes /X/ .No
- 3. CATD No. 80000-SQN-01 4. INITIATION DATE 10/1/86
- 5. RESPONSIBLE ORGANIZATION: ONP 6.' PROBLEM DESCRIPTION: /g
- Failure to write a site NCR and to quickly remove from the site
[ PJJ and PNJ cables resulted in its subsequent noncontrolled use. ~
Testing was recently conducted to qualify the cables identified-in SQN-EQ-CABL-034, and the cables have a qualified life of 20
, years. However, additional testing has been deemed required to I extend the life of these cables however, this extension is not_. _
required prior to start up.
4 // ATTACHMENTS
- 7. PREPARED BY: NAME Wayne M. Akeley em4 DATE: 10/1/86 i
- 8. CONCURRENCE: CEG-H R. K. Maxon ,
j _ DATE: . ,
E 9. APPROVAL: ECTG PROGRAM MGR: Ql/Eshv M 4 DATE: 2/8/f/'7 -
t
~
CORRE0TIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
n .. : ,i _
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.___.. __o es, L ll'
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SeY CM MAUSM/1191> BY MfM@(NDUAn k 890 2'6 /// Y 00 ~2 l4 4
, / / ATTACHMENTS o 11. PROPOSED BY: DIRECTOR /MGR: / d 44.,,43 //., DATE: //-RO-fl.
- 12. CONCURRENCE: CEG-H DATE:
SRP: DATE:
ECTG PROGRAM MGR: DATE:
VERIFICATION AND CLOSEOUT .
, 13. Approved corrective actions have been verified as; satisfactorily -
impicmented. y' ;,
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- a
!! SIGNATURE TITLE -
DATE 1 .
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ATTACHMENT B Page 2 of 5
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L:Nf?ID STATES 00TERNMENT .
Memorandum mw-s nuzr wrnoarrr 870 '861114. 002 TO E. C. Deaney. Seployee Conceras Special Project Namager. MF. DSC-F.
Sequoyab Buclear Flaat NM 2 D. W. Wilsoas, Project Begineer. 555. DSC-E. Sequoyah Baclear Flaat
"^" """ 861121R0408 @
smect: sunc0TAa 2 CLEAR PLANT (SQN) - ENFLOTEE CONCIEES TABE CBOUP (ECTC) ELEMENT l REPORTS - EI? ORT 800.00 SQ3 - EETIEW AND CORIECTITE ACTION FLAB (CAF)
IIITIATION Attached is the CAF for ECTC Elemost Braluation Report (800.00 SQ8) which was requested by your memorandma to se dated October 16.1906 (803 M1016 802). If you have any guentions, plasse contact W. L Deen, entension 7225 er D. 3. arf. entenaien 4559.
. h- - .
U B. L Wileen F
- CJB Cah. At-h e es (Asteekseets):
te men . et sa e r L L. metercette. W. SPD-4. Sagesysk ele attaehmeate)
- 5. L Andrere. W. mfd-3 Segeerek C. L h M. GBD-3. Gegearch (e/o Asseekssets)
- u. L. M 11att. E SBD 8. Gegesych
/ L W. Esen. WE. M. Segosych J. & Se11&sen. W. S-E. Sequerch F. A mettane. W. 33-8. toqueye L C. 9L11&ame. SSH. Sagespek 4
, a_-,-- .., - - - , , . , _ _ _ _ - - - , ,
UNITED STATES GOVERNMENT 808 t o61r18 803
~ Memorandum TENNESSEE VALLEY AUTHORITY TO : W. R. Brown, Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant FROM : H. L. Abercrombie, Site Director, ONP, O&PS-4 Sequoyah Nuclear Plant DATE : November 20, 1986
SUBJECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 800.00 SQN - QA/QC CATEGORY - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated October 14, 1986, " Watts Bar Nuclear
- Plant - Employee Concerns Task Group (ECTG) Element Report 80000-SQN - General Management and Policy (Sequoyah)"
(T25 861014 944)
I acknowledge receipt of your element report and in accordance with your request (see reference). Element Report 800.00 SQN has been reviewed for applicable corrective action.
By way of this memorandum I an endorsing the site line organization CAP, returning your Corrective Action Tracking Document No. 80000-SQN-01, and attaching the CAP for your review / concurrence. This CAP is not a restart requirement.
If you agree with the proposed CAP, please sign the ECTG concurrence space below item 9 on the CAP tracking checklist and return the CAP tracking checklist.
$$$L_h A
~
H. L. Abercrombie RCD:JDS:JE:CS Attachments RECEgyED !
cc (Attachments):
RIMS, NR 4N 72A-C b0 T. C. Price, 5-212 SB-K (
EmP6Yee Cct.mrs rea Group nEra 0340T
. ,9 Nu?=an-sit ivtB U h n . t ,
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- , .- s (
- f. STANDARD PRACTICE Page 8 SQA166 Rev. 8 Attachment A Page 1 of 2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist
- t i
4 ECTG Report /CATD Number 800.00 - SON /CATD #80000 - SON-01 Lead Organisation Responsible f or Corrective Action ENG Initiation Date 10-16-86
! CORRECTIVE ACTION PLAN (CAP) i i
- 1. Does this report require corrective action? Yes No I (If yes, describe corrective action to be taken, if no, provide j ustification)
- The SON EO oroiect has doc-- =tation to d--a==trate envira====tal analification for TVA-tyne PJJ cable installed in 50.49 eircuits at
! SON. This documentation is contained in Seanovah Enviro ====tal Pack-anes SOMEO c A_mL-001. -015. -020. and -034. Review of the Seeuovah Electrical Eauipment List ( SOEL) shows that no PNJ cables ( or cables l from the same cable f amily) has been installed in 50.49 circuits.
i
- 2. Identify any similar item / instances and corrective action taken.
Refer to W. L. Elliott's ===o to G. T. Hall dated February 11. 1986
( B70 860211 001) . This ===orandum identified all cables in the cur-rent cable yard inventory that were considered by E0P as not suit able j
- for installation in new 50.49 circuits. In addition. the ---orandum recommended that cable in this category be "cronerly dianositioned and
! moved to a non-nuclear site." The yard inventory at that time showed that no tyne PJJ or PNJ was on site. The inventory did show that tvoe PN ( same f amily as PNJ) was on site. The tvoe FN cable was included l in the troun of cable that E0P recommended to move off site. j
- 3. Will corrective action preclude reccurrence of I findings? Yes X No
, 4. Does this report contain findings that are conditions adverse to cuality (CAQ) as defined by AI-12 or NEP 9.17 Yes No X
- 6. Which site section/ organization is responsible f or corrective action?
- 7. Is corrective action required for restart? Yes No (This determination is to be made using Attachment C of SQA166.)
- 8. P2 zone number for restart corrective action? Zone
- 9. Estimate completion date f or corrective action.
Completed By Oh M Date 1/ /8 /44 Approved By '
MM Date h hf/fff.
3 ECTG Concurrence Date C26318.01
4
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N - C ~ *
?.
ATTACHMENT B Page 5.of 5 c Standard Practice
' Page 9
) i SQA166 I Revision 8 -
'~
l ATTAODELT A I Page 2 of 2 CAP CLCSURE ,
- 10. Was your corrective action initiated and completed in accordance with step I?
Yes No
- 11. If step 10 is no, describe the corrective action taken.
r -
e J
- 12. Is the corrective action implementation ~ complete? Yes No
- 13. Is the corrective action documentation closed? Yes No !
- 14. What documents Completed By: were used to implement the corrective action? _
Verified By: Date Date ECTG Closure:
Date (Step No.) Descripbion i
P
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