ML20210H262

From kanterella
Jump to navigation Jump to search
Rev 3 to 80203-SQN, Insp Performance, Employee Concerns Special Program Rept
ML20210H262
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 02/02/1987
From: Akeley W, Barlow D, Halverson R
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20210F779 List:
References
80203-SQN, 80203-SQN-R03, 80203-SQN-R3, NUDOCS 8702110402
Download: ML20210H262 (45)
v • d • e


Text

{{#Wiki_filter:_ j#- I TVA EMPLOYEE CONCERNS . REPORT NUMBER: SPECIAL PROGRR4 80203-SQN REPORT TYPE REVISION NUMBER: 3 Element Report PAGE 1 OF 11 TITLE: Inspection Per foripance REASON FOR REVISION: Rewritten to incorporate corrective action response to CATD 80203-SQN-02. Revision indicators are not shown on each page as the report was reformatted. Note: Sequoyah Applicability Only PREPARATION PREPARED BY: D. G. BARLOW /R. D. HALVERSON d'. V h07'D / f7 ff 'DATt SIGNATUREJ [ 'j ' ' (/ REVIEWS PEER: 'IWuh.bihd ~ DATE //77/f7 [ SIGNATURE TAS: ? f h_, /u$ e 'f? SIGNATUR$ DATE CONCURRENCES A /1 .A -n ~ C SRP 0 6 prEr 2- $ ? ~ IGNATURE*[ DATE SIGNATURE DATE APPROVED B : /37 I-N/A M ECSP MyAGER DATE MANAGER OF NUCLEAR DATE PC'4ER CONCURRENCE (FINAL REPORT ONLY) 402 870205 Q21kDOCK0500g7 s, c i r i t e SRP co teurr >nces are in files. asR) p .s

8 \\

g

( TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPE: SPECIAL PROGRAM 80203-SQN Element Report REVISION NUMBER: TITLE: 3 -Inspec tion Performance PAGE 2 0F 11 1.0 CilARACTERIZATION OF ISSUES 1.1 Introduction The issues desc ribed below were derived from Employee Concerns generated as a result of the Watts Bar Employee Conce rn Special Program. The issues were specific to the Sequoyah Nuclear Plant. 1.2 Description of Issues The conditions reported ( Attachment A) by concerned employees are: a. Inspection personnel were distracted by craft personnel and did not observe damaged cable insulation. (00-85-005-003) b. Craft and inspection personnel falsified anchor pull tests and applicable documents. (XX-85-023-x02) c. Conax connectors in the containment did not always meet vendor wire bend radius in s truc tions, connector installations with de ficiencie s vere inspected and accepted by Sequoyah Quality Control (SQN QC); no action was taken by SQN QC management to investigate or document the deficiencies. (I-86-101-SQN) d. An item of equipment may not have been adequately inspected. (SQM-6-009-001) 2.0

SUMMARY

2.1 Sucmary of Characterization of Issues

  • Ih e issues raised by the employee concerns suggest that:

inspection ' personnel were distracted by craft personnel and did not perform their required functions; test results and ' documents were falsified; inspection personnel did not perform an adequate inspection of an item; and QC Management failed to investigate or document identified de fic ienc ie s. 2.2 Summary of Evaluation Process The evaluation process consisted of a review of the Employee Concern files, Qua lity Technology Company (QTC) files, and Nuclear Sa fe ty Review Sta f f (NSRS) file s to dete rmine the scope and extent of the concerns id ent i fied. The Nuc lear Quality Assurance Manual, lower tier procedures and instructions, Gene ra l Cons truc t ion Speci ficat ions, Work Requests and other related correspon.lonce and documents we re reviewed to d ete rmine the prog rmmna t i t r quire,nts and management directives re la t ed to the i 4 Sit * *.

I \\ 5 :.' TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPE: SPECIAL PROGRAM 8020 3-SQN REVISION NUMBER: Element Report 3 TITLE: PAGE 3 0F 11 Inspec tiott Performance . Discussions were held with Quality

Control, Construction, and Modification personnel to ob tain more specific in formation regarding the issues.

The documents reviewed during the investigations and ' used in the evaluation are listed on Attachment D. 2.3 Summ3rv of Findings 2.3.1 Issue -- Inspection personnel were distracted by craft personnel and did not observe damaged cable insulation. The conc ern ' from which this issue was extracted provided (00-85-005-014) which noted~ re ference to a similar concern specific cable / conduit runs and identified the period in which the incident occurred as 1977. The records that were applicable to the specific cable pulling operation were rev iewed. It was determined that the cables tests. The cables received and passed High Potential (Hi-Pot) have since been de-energized and the electrical circuit for the back flow gate hoist mo tors have been connec ted from automatic control to manual control. 1ssue -- Craf t and inspection personnel falsified anchor pull 2.3.2 tests and related documentation. The investigation identified an Employee Responte Team (ERT) Report dealing with the same issue. The investigation also produced a copy of a comorandum from the Of fice of the General further Counsel which agreed with the ERT findings and took no action on the falsification issue ra ised. Based on the ERT Report, the inte rviews conducted, and the Quality At.surance Category Evaluation Group (QACEG) evaluation o f the ~ re sult s, the QACEG could find no cases where anchor pull te st s were falsified. Issues -- Conax connectors in the containment did not always ( 2.3.3 vt.nd or wire bend radius instructions; connector meet installations with deficiencies were inspected and accepted by SQN QC; no action was taken by SQN QC management to investigate or document the deficiencies. t The NSRS investigated these issues and issued report No. I 101-SQN dated February 1986 (Attachment B). A Correc tive dated February 1986 was also issued. Two valves l Action Report found to have connectors where wire bend radii were below we re minimum requirements and workplans were found to have been performed and inspec ted; however, the written where work was phns. lid not re fer to the vendor manual for installation of 1

_o g TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPE: SPECIAL PROGRAM 8020 3-SQN Element Report REVISION NUMBER: TITLE: 3 Inspection Performance PAGE 4 0F 11 the connectors. Lack of QC management action could not be verified since the QACEG could ' find no evidence to determine if the concerned individual brought this issue to QC Management prior to the NSRS investigation. The issue ' ot the connectors not meeting the wire bend radius instructions and connectors being installed and accepted with deficiencies is valid. A reinspection was initiated by TVA Management. Specific corrective actions and the results achieved to date are discussed below. 2.3.4 Issue -- A item of equipment may not have been adequately inspected. This issue could not be evaluated since there was insufficient information available to perform an investigation. 2.4 Corrective Actions Taken and the Results Achieved to Date It could not be de termined if cable insulation was improperly repaired. However, QACEG investigation has determined, through the issuance of Corrective Action Tracking Documents and Responses from the SQN Site Direc to r, that the subject cables have been tested, experienced worst case conditions, and been in service since 1977. Engineering concluded if there was insulation damage, it was not suf ficient to impair the fuention of the cable and no further action is needed. Conax connec tors were installed outside the allowable limits. A Corrective Action Report was issued causing for a QA Program revision, reinspec tions and rework. This was comple ted in August 1986 and no further actions are required. 3.0 EVALUATORS D. G. Barlow R. D. Halverson 4.0 EVALUATION PROCESS 4.1 General Methods of Evaluation Research of the files produced additional information to support the investigation by way of NSRS Reports and an additional concern. Construction specifications, procedures and instructions were reviewed to extract the requirements and determine adequacy of the details provided.

i TVA EMPLOYEE CONCERNS REPORT NID1BER: REPORT TYPE: SPECIAL PROGRAM 80203-SQN REVISION NUMBER: Element Report 3 TITLE: PAGE 5 0F 11 Inspection Performance Microfilm records provided details of inspections and tests per formed and personnel discussions were held to support the records reviewed. Corrective action records and supporting data were also reviewed to provide details on the deficiencies noted and the corrective actions taken. 4.2 Specifics of Evaluation 4.2.1 Issue -- Inspection personnel were distracted by craft personnel and did not observe damaged cable ' instruction. In researching the files for additional information regarding c ra f t dis tracting inspection personnel and cable insulation damage, QACEG personnel reviewed a related concern (00-85-005-014) which identified the specific cable / conduit runs involved. Four cables were identified. That concern also identified the period of time as mid-1977. Micro film records relating to the above identified cable / conduit runs were reviewed (cable pulling

cards, cable / conduit inspection card s,

and Hi pot records) to determine if inspections were performed and tests completed. An inte rview was held with an individual involved in the inspection of three (3) of the above noted cable pulls. The interview centered around how an inspector may become dis trac ted and how an inspector can cover the inspections given the various areas cable is pulled through. Gene ral Con s truc t ion Specification G-38, Revision 1, dated October 22, 1975 " Installing Insulated Cable Up to 15,000 volt Inc lus ive ", was reviewed to determine if instructions were provided for repairing damaged cable and/or insulation. Likewise, Sequoyah Inspection Instructions Numbers SNP 11-28, " Cable Pulling Inspection" Revision 0 (dated May 26, 1977), f. Revision 1 (dated June 11, 1977), Revision 2, (dated October 4, 1977); SNP 11-10, "Elec tric al Penetration and Interconnecting Cable Termination and Insulation Inspection" Revision 6 (dated Decembe r 27, 1976), Revision 7 (dated May 26, 1977), Revision 8 (dated June 11, 1977), Revision 9 (dated December 21, 1977); SNP 11-26, " Exposed Conduit and 5 Conduit Box Inspection", Revision 0 (dated May 26, 1977), Revision 1 (dated June 11, 1977), Revision 2 (dated September 13, 1977), Revi' ion 3 (dated October 14, 1977), were reviewed to determine inspection requirements and adequacy of those methods and acceptance criteria to enable an inspector to per fo rm the intended fene tions.

TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPE: SPECIAL PROGRAM 8020 3-SQN Element Report REVISION NUMBER: TITLE: 3 Inspection Performance PAGE 6 0F 11 A Construction Category Evaluation Group Element Report No. C010900-SQN dated Nov. 1986 was also reviewed for additional information pertaining to the subject issue. 4.2.2 Issue -- Craf t and inspection personnel falsified anchor pull-tests and related documentation. Ar. Employee Response Team (ERT) Repor t (XX-85-023-X02, dated March, 1986) (Attachment C) was found to address the same j issue. The QACEG investigation attempted to secure a listing b of the hangers in the Unit 2 Annulus area since the employee concern identified this area specifically. A list of hangers by location does not exist, according to Engineering, and it was concluded that if records were located it would be extremely difficult to establish if the test results we re falsified. There fore, emphasis was placed on locating and discussing the issue with personnel who were involved in anchor bolt installations / inspections in that period. A review was performed of General Construction Specification G-32, " Bolt Anchors Set In Hardened Conc re te" Revision 4 (dated April 21, 1976) and Revision 5 (dated July 21, 1977) to. determine the installation and test requirements. Inspection Instruction SNP II-93, "Te sting of Expansion Anchors Set in Hardened Concrete", Revision 0 (dated February 14, 1977), f Revision 1 (dated March 15, 1977), Revision 2 (dated November 2, 1977) were also reviewed to determine testing requirements and the associated documentation. 4.2.3 Issue -- Conax connectors in the containment did not always meet vendor wire bend radius in s truc t ions, connector installations with deficiencies were inspected and accepted by Sequoyah Quality Control (SQN QC); no action was taken by SQN 4 QC management to investigate or document the deficiencies. } NSRS Report I-86-101-SQN dated February 1986 was written on the above issues along with a Corrective Action Report CAR-86-02-005 also dated February 1986 describing deficiencies 1 on Conax connector bend radii. d 1 The CAR and subsequent revis ion to Ma intenanc e and Addition Instructions M&AI-19 (RI), " Installation of Conax Connectors" i were reviewed to d ete rmine if adequate requirement s for l inspection of wire bend radii had been provided and if the CAR had been closed satisfactorily. g In researching the issues concern ing Conax connector 3 l' de fic ienc ies, the QACEG Evaluation Group inte rv iewed the QC Elec tr ic al Supervisor. A copy of Corrective Ac tion Report SQ C A R 4 6-0 2 - 00 ~* <la t al February 10 1986 wu furaishmt by this ind iv idua 1. i

TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPE: SPECIAL PROGRAM 8020 3-SQN Element Report REVISION NUMBER: TITLE: 3 Inspec tion Performance PAGE 7 0F 11 4.2.4 Issue -- An item of equipment may not have been adequately inspected. Insu f fic ient in formation available to perform an investigation. 5.0 FINDINGS 5.1 Findings on Issue - Inspection personnel were distracted by craft personnel. 5.1.1 Discussion Concern No. 00-85-005-003 dealing with the inspec tor being distracted and preventing him from noticing damage to cable insulation re ferenced Concern No. 00-85-005-014 which identi fied four specific cable / conduit runs. That concern stated in part, " Insulation was mistakenly cut off of a 440 volt cable and the insulation was reattached with elec trical tape." The concern went on to identify the cable s as the power feed to the Back Flow Cate Hoist Motors. There are four such motors and are part of the Essential Raw Cooling Water (ERCW) System. That same concern identified four cable / conduit runs as 1-PL-6370-B, 1-PL-6360-A, 2-PL-6370-B and 2-PL-6360-A and also identified the period of time as mid-1977. Conc e rn No. 00-85-005-014 is a reissue of Concern No. 00 005-001. The reason for reissue was a correction of one of the cable numbers referenced in the concern. This concern was part of the Construction Element Report No. C010900-SQN and the particular issue is addressed under the heading " Insulation Damage". Inspection record s show that two (2) inspectors were involved with the cable visual examinations of the identified cable / conduit runs in the period from June-September 1977. An in te rview was held with an individual involved in the inspec tion of three (3) cable pulls (1-PL-6370-B, 1-PL-6360-A, and 2-PL-6360-A).

  • Ih e inte rview centered around how an inspector may become distracted and how an inspector can cover the inspections given the various areas cable is pulled through.

The individual involved with cable pull 2-PL-6370-B inspection could not be interviewed as he is no longer employed by TVA. The individual inte rviewed, who inspected three of the four cables in question, stated that because of the various treas a c.1h le my % palled through the inspector could not always wit, e 5 n ire ope r:it ion. In his opinion, the point at

\\ s TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPE: SPECIAL PROGRAM 80203-SQN Element Report REVISION NUMBER: TITLE: 3 Inspec tion Performance PAGE 8 0F 11 issue could have happened. In reviewing the records it was noted that the four (4) cable / conduit runs re fe renced indica ted acceptable installation and testing through the period June-September 1977. These cables received and passed a Hi-Pot Te s t. It was also found that the cables have been de-ene rg ized since the Back-Flow Gate Hoists are no longer needed. l In discussions with the Design Engineering personnel and a review of the drawings associated with the motors and cables, it was found that the design drawings 45N-751-1, -2, -5, and - 6 do not reflect that the cables have been de-energized and motors taken out of service. GB 5.1.2 Conclusion l The issue of an inspector bei*ng deliberately distracted from noticing a cable insulation nonconformance and the same i inspector being dis trac ted while the cable was improperly repaired and pulled into the conduit cannot be substantiated. However, since the re fe renced cable s have been d e-energiz ed the issue raised by the concerned employee is invalid at this time. 5.2 Finding on Issue Craft and inspection personnel falsified anchor I pull tests and applicable documents. 5.2.1 Discussion The SQN Inspection Supervisor provided the names of five (5) inspection personnel who we re involved in anchor bolt inspections in 1977. These personnel were inte rviewed to determine tneir knowledge of falsification of test records or other wrongdoing involving records. They all said they had heard that falsification had happened at Watts Bar, but no one could recall an instance of falsification of test results having happened at SQN. The ERT report mentioned conducting inte rviews with 27 individuals involved in the installation and inspec tion of anchor bolts. They too denied knowlege of falsification of test records. The Office of General Counsel (OGC), in their menorandum to i the Manager of Nuclear Power dated April 30, 1986, concluded that in its review of the QTC investigation into the issue of craft and inspection personnel falsifying anchor pull tests i an3 documentation there was "...no collabora ting /ob jec tive l . id m - ... f.., n d to allow :mb s tan t ia t ion. " The Office of c

4 l TVA EMPLOYEE CONCERNS REPORT NUMBERT REPORT TYPE: SPECIAL PROGRAM 80203-SQN 1 - Element Report REVISION NUMBER: TITLE: 3 i .Inspec tion Performance PAGE 9 OF 11 4 General ~ Counsel will take no further action on this issue. In a phone conversation with the Office of the Manager of Nuclear Powe r, ONP advised that it has accepted the decision of the Of fice of General Counsel regarding this issue. 5.2.2 Conc lu sion Based _ on inte rviews, lack of data to support the issue, the ERT Report and the OGC memorandum,. it is concluded that the issue of craft and inspection personnel falsifying anchor pull j_ tests and applicable documents is not substantiated. 5.3 Finding on Issues - Conax connectors in the containment did not always - meet vendor wire bend radius instructions, connector. Installations with deficiencies were inspected and accepted by Sequoyah Quality Control (SQN QC); no action was taken by SQN QC management to investigate or document the deficiencies. i 5.3.1 Discussion i The issue dealing with Conax connectors and deficiencies noted was the subject of a NSRS Report of " Installation of Conax Connec tors", I-86-101-SQN dated February 1986 and a Corrective Action Report (CAR) SQ CAR 86-02-005 dated February 10, 1986. Two valves were verified to have wire bend radii below mininum allowed. A sample was than taken from b Units 1 and 2 and an additional 14 valves were -found to have l deficient wire bend radii. Workplans were written to install j the connectors, field installation was completed and i inspections were performed. Work plans did not contain steps to verify wire bend radius nor did they reference the vendor [ manual for installation. A review was made of the CAR and a subsequent revision to l Maintenance and Addition Instruction MEAI-19 (RI), " Installation of Conax connec tors". It was dete rmined that the requirements for inspection of wire bend rodii have been added, reinspection for the minimum bend radius and rework as necessary to all Conax connectors, and the EQ Project Manager's cconcurrence with the vendor manual revision have been performed. TVA QA verified corrective action was taken l and the CAR was closed in August 1986. t 5.3.2 Conc lusion l The issue of Conax connectors installed in containment that do i not meet the vendor wire bend radius instructions was substantiated. Howeve r, this condition was documented in SQ CAR-86-02-005, reinspections have been per formed, and correc tive ac tions have been completed.

p TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPE: SPECIAL PROGRAM 8020 3-SQN Element Rcport REVISION NUMBER: TITLE: 3 Inspec tion Perfor nance PAGE 10 0F 11 The issue of connectors being inspected and accepted by QC with deficiencies is fac tua l sinc e there were cases found whe re wire bend radii was inadequate. Work Plans for the installation of the connectors did not address bend radii when issued. Gene ra l Construction Specifica tion G-38 did not address wire bend radii either. Inspections were conducted to the requirement s of the approved workp lans. It was the omission' of minimum wire bend radius inspection c rite ria in the workplans which allowed the connector installation to be accepted by QC. The inclusion now, of vendor instructions for minimum bend radius in the M&AI-19 (RI) will prec lude the omission of bend radii inspections in the future. The issue of no action being taken by SQN QC Management to investigate and document the deficiencies prior to the NSRS investigation cannot be susbtantiated. No evidence exists to dete rmine if anyone knew there were deficiencies prior to the investigation. 5.4 Finding on Issue - An itert of equipment may not have been adequately inspected. In researching this issue the QACEG c ould not find any specific information to aid in a meaningful investigation. 5.5 Correc tive Ac tion Co rrec t ive Action Report CAR-86-02-005 was issued in February 1986 to document that Conax connectors we re installed outs ide the allowable limits. Correc tive actions inc luded Environmental Qualification (EQ) reviaw and concurrence with the Conax Vendor Manual and issuance of Rev. I to Ma intena nce and Add ition Instruction M&AI-19 to inc luded wire bend radii criteria. Reinspections and rework was performed on all Conax connec tors and verification by Quality Assurance (QA) was completed in August 1986. No further actions were required. The ECSP Co rrec tive Action Tracking Document No. 80302-SQ N-01 (Attachment E) which was issued on Sep tembe r 18, 1986 was issued for Engineering to evaluate the long term e f fect on the cable s being repaired with electrical tape. The SqN Site Di rec to r has since responded by saying that reco rd s indicata acceptable installation and testing (Ili-Pot and Megge r). The cables have been in service since 1977 and it is likely that they have expe r ienced the worst conditions including subme rgence during tha t time without any p rob le ms. Engineering conc luded that if there was d a.na g e, it was not su f fic ient to impair the function of the cable and no forther action is needed.

~ TVA EMPLOYEE CONCERNS REPORT NUMBER: REPORT TYPd: SPECIAL PROGRAM 80203-SQN Element Report REVISION NUMBER: TITI.E: 3 Inspection Performance PAGE 11 0F 11 With the additional information made available to QACEG and further research where it was found that Engineering did not reflect the status of the cables as being de-energized on the design drawings, QACEG has prepared CATD 80203-SQN-02 (Attachment F) for SQN to evaluate the problem condition in light of their response to CATD 80203-SQN-01. The SQN Site Director has responded by stating: " Design Drawings 45N751-1, -2, -5 and -6 do reflect the system status, however, the electrical circuit for the back flow gates had.been converted from automatic control to manual control by the unit operator (ECN L5720) which he has authority to do. The breakers for the back flow gate hoist motors are being tagged with ' caution order' of the administrative operation." QACEG concurs with this response and no further is required. Attachment A identified these issues as potentially safety related and safety significant.

However, corrective measures which include procedural revisions rework and reinspection have been completed.

No further action is required. 6.0 ATTACHMENTS A. List of Employee Concern Information Subcategory: 80203 Inspection Performance B. NSRS Report I-86-101-SQN C. QTC Enployee Response Team (ERT) Report No. XX-85-023-X02 0. Listing of documents and correspondence reviewed during the investigation of these issues. F.. CATD No. 80203-SQN-01 and SQN Memorandum dated October 29, 1986 (RIMS S03 861022 808) P. CATD No. 80203-SQN-02 and SQN Memorandum dated January 24, 1987 (RIMS SO3 870123 803)

FERE!!CE - ECPS120J-ECPS121C TE!!NESSEE VALL EY AUTHORITY PAGE' 1(- IQUE!!CY - REOUEST OFFICE OF NUCLEAR P0HER RtlN TIllE - 13:483- ? - 1550 - Rt.it EMPLO(EE C0llCERtl I'ROGRA!! SYSTEM (ECPS) RUll DATE - '10/16 LIST OF EMPLOYEE CD:CER!! INFORt1ATION 2 GORY: % QA/QC PROGP.J.;;S SUBCATEGORYs 80203 INSPECTION PERFORMAt!CE S GENERIC KEYHORD A APPL QTC/fl5RS P KEYMORD B C0!!CEP'! SU3 R PLT B B 5 li IrlVESTIGATION 5 C0!!CERil KEYMORD C tlUi:S EI; CAT CAI D LOC FLQ3 REP 0"T R DESCRIPTION KEYMORD D

02'-X02 IN 00C:10 5 SQll il N Y !!

SS CRAFT AND INSPECTION PERSOftllEL FALSI FALSIFICATION T50133 QA 80203 K-FORM FIED AtlCHOR PULL TESTS AND APPLICADL RECORDS E DOCUTIENTS. MID 1977. UtlIT 82, Allti OPERATIO!!S ULUS AREA. (DETAILS TO SPECIFICE CA ANCHORS SE KIIDHN TO QTC AND HITHELD TO MAIllT AIN CONFIDENTIALITY). CONSTRUCTION DEPT CONCERN. CI HAS NO MORE INFOR11A T10ll. s 9

ATTACHMENT A ~EREf:CE - ECPSIr0J-ECPSI21C TE!!NESSEE VALLEY AUTHORITY PAGE 1? JOU ::'. - REQUEST Oi FICE OF !!UCLEAR PO!!ER R Ull tit 1E - 13:48: - IS. - R :!! EtPLO'IEE COUCER!1 PRCGRAtt SYSTEM (ECPS) RU:1 DATE - 10/16v I LIST GF Et1 PLOY:.E CD:iCER!1 IllFORI1ATIO!!

COFY QA/0C PRCORI
:S SUCCATEGSCI E0203 Iti:PECT10:1 PERFORilA!!CE S

GE!!ERIC KEYt!3?D A 11 APPL OTC/f0RS P KEYMCRD B CCSCE0*! S *F1 R PLT B B S :. IfiV E STIGATIO!! S CollCERil KEY 610RD C flu:*: J CAT CAT DLL FLQE REPudT R DESCRIPTION KEYt!0RD D i ':6 -101 - DN1 QA E02 03 il 00;l N N !! 1 Ils 1.C0!!AX CON!!ECTORS IllST ALLED IllSIDE K-! ORti SEQtl0YAH tlUCLEAR PLAllT (SQti) UtlI I 1 Curli AIt!!iEf1T D0 t10 f ALHT.YS I1EET VEllDO j R HIRE BEllD RADIUS P.EQUIREllEllTS. 2.A 1 LLEGED DEFICIEllCIES Ill C0llAX CutillECT j OR IllSTALLATIOil HERE INSPECTED BY SQ Il QUALITY CONTROL (QC) AllD ACCEPTED. j 3.110 ACTI0tl HAS TAKEtt I,Y SQll QC IAri 1 AGE!1ENT TO INVESTIGATE OR DOCUMEllT T l HESE DEFICIEllCIES llHEll THEY HERE MAD E AHARE OF THEM. N N 6 I N m ! S 005-003 QA 80203 N SQN YYNY SS SEQUDYAH: CRAFT FOREMAN (KNOWN) AND NONC0t1FORMANCE T50224 K-FORM OTHER MEMBERS OF THE CREW DELIBERATE CORRECTIVE ACTION I LY DISTRACTED AN IllSPECTOR TO PREVEtt GEllERAL T THE INSPECTOR FROM NOTICING A fl0 tlc FOREMAtl i DNFORMANCE REGARDING CABLE IllSULATIO l N DAt1 AGE. THE INSPECTOR HAS DISTRAC I TED HHILE THE CABLE DAMAGE HAS REPAI I RED It1 PROPERLY, AND THE CABLE PULLED INTO THE CollDUIT. (SPECIFIC CABLE CONCERN ADDRESSED' IN THIS FILE, CONC ERil 001) DETAILS Kt10HN TO QTC, HITHH ELD DUE TO CONFIDENTIALITY. NO FURT lier IrlFORt1ATI0tl MAY BE RELEASED. CD j ilST. DEPT. CONCERN. CI HAS NO F i t'-86-309-001 CA S0233 N SQ!1 NNNN I-86-242-SQN SS A PIECE OF EQUIPMENT (110T SPECIFIED) 110NC0!1FORitAtlCE l T50262 K-FORM MAY NOT HAVE BEEN ADEQUATELY INSPEC IllSPECTIO!1 TED. DETAILS KN011N TO QTC, HITilHELD QUALITY j DUE TO C0tlFIDENTI ALITY. NO FURTHER EQUIPf1EllT i INFunt1ATION f1AY BE RELEASED. IlUCLE i AR P011ER DEPART!!ENT C0t3CERN. I

\\ TVn c 4 (OS-9 65) (OWWf*-S-85) UNITED STATES GOVERN.%!ENT ATTACitMENT B Memoyandum TENNESSEE VALLEY AUTIIORITY TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FROM: K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K ((Q Q71966 DATE:

SUBJECT:

NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL N Transmitted herein is NSRS Report No. I-86-101-SON Subj ect INSTkLLATIONOFCONAXCONNECTORS Concern No. N/A .and associated prioritized recommendations for your action / disposition. ~ It is requested that you respond to this report and the attached Priority 2 [P2] recommendation by April 28. 1986. Should you have any questions, please contact W. D. Stevens at telephone 6231-K Recomend Reportability Determination: Yes No X ~ l ^ ' irector, NS w nesiltree warrs ata f w rLt.R9 tan,t WDS:JTl! Sif M:rcreser,,:, Attachment cc (Attachment): MAR 0 Pd6 U. C. Bibb, DFil\\ W.T.Cottle,WBN\\ James P. Darling, BLN , j g R. P. Denise, LP6N40A-C S # 2 G. B. Kirk, SQN i-EJ,', D. R. Nichols, E10A14 C-K Q QTC/ERT, Watts Bar Nucicar Plant _a. Eric Sliger, LP6N48A-C _D J.11. Sullivan, SQN f,7g' " 5430 ..;ifo 4=s

s

  • =

TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. I-86-101-SQN N SUBJECT INSTALLATION OF CONAX CONNECTORS ~~~ DATES OF INVESTIGATION: FEBRUARY 10-13,'1986 / a /ar '6 4 7' IUVCSTICATOR: + N. T. HEURICli DATE REVIEWED BY: 2 30 ~ L. E. BROC'K DI.TE k. W. D. STEVE (3 DATE / I en S 9 9 = 0

i I. DACKCROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern identified to the NORS during the investigation of employee concern XX-85-087-001. The concern addressed by this report was not related to the concern under investigation at that time and was outlined in a memorandum from C. E. Chmielewski to R. C. Sauer dated December 31, 1985 (Ref. 1). The employee con:ern addressed by this investigation report did not come through the Quality Technology Company (QTC)/Employes Response Team ~ (ERT). Therefore, no Employee Concern Assignment Request Form is available summarizing the concern of record. II. SCOPE-A. The scope of this investigation was determined from the concern of record as summarized in reference 1 to be that of three specific issues requiring investigation: 1. Conax connectors installed inside Sequoyah Nuclear Plant (SQU) unit 1 containment do not always meet vendor wire bend radius requirements. 2. Alleged deficiencies in Conax connector installation were inspected by SQU Quality Control (QC) and accepted. 3. No action was taken by SQN QC management to investigate or document these deficiencies when they were made aware of them. D. .To accomplish this investigation, vendor manuals and environmental qualification data sheets were reviewed to determine Conax connector installation requirements. Procedures governing the actual installaticn of these connectors were reviewed and compcred against these requirements. Discussions were also hold with QC personnel to determine if Conax connector installation deficiencies have been identified and any corrective action planned or taken to resolve the deficiencies should they exist. III. Sur.MLRY OF FINDINGS A. Requirements and Commitments Not applicable to this investigation. B. Findings 1. Conax Corporation Manual, Installation Manuni for Electric Conductor Seal Assemblies with Lonr, Body for Pipe Thrend Emainment Interface, IPS-725, was originally issued Junn 26, 1981. The latest revision to this manual is revision "C" which 1 ,r--.-

+ \\ s was issued rebruary 15, 1985 (Ref. 4). This manual provides basic information, handling, and install'ation instructions for Conax cicctrical conductor seal assemblies type ECSA. Section 7.2 of the manual specifies the minimum wire bend radii requirements. Based on a review of the manual revision log, it appears that these requirements were identified in the original issuance of the manual. 2. Reference 3 documents that Conax electrical conductor seal assemblies type ECSA are environmentally qualified for forty years with one design basis accident and 100-day postaccident operation. However, the initial installatioa and subsequent ~ reinstallation or replacement of the seal following maintenance must be performed in.accordance with Conax installation instructions outlined in reference 4. 3. Workplans 11077 R1,11231, and 11335 (Refs. 6, 7*, and 8, respectively) were written to install Conax connectors to meet environmental qualification requirements set forth in NUREG-0588. Each of these workplans were prepared and worked prior to issuance of a modification and additions instruction regarding installation of Conax connectors. These workplans did not, specify minimum connector wire bend radius requirements and did not require verification of installed wire bend radii. Each of these workplans had been reviewed and approved by SQN QC personnel. Work was performed in accordance with the workplans, and specified QC inspections were performed. 4. Discussions with QC personnel revealed that some, but not all, of the SQN QC inspectors received Conax connector _ installation training when it was offered to craf t personnel. QC inspectors evaluated Conax connector installations against requirements identified in approved workplans. The inspection criteria did not include evaluation of wire bend radii. 5. Hodifications and Additions Instruction H&AI-19 R0 (Ref. 2a) was approved April 12, 1985, and provides guidelines for initial field installation of electrical Conax connectors for SQN. As initially issued, this procedure did not address minimum bend radius requirements for these connectors nor did it identify a need to inspect completed installations for acceptable wiro bend endli. 6. Hodification and' Additions Instruct [on H&AI-19 was subscquently revised July 26, 1985 (Ref. 2b) and incorporated vendor recommendations for the minimum bend radius of electrical pigtails as specified by Conax Corporation in reference 4. 2

g 7. Maintenance activities have confirmed that' valves 2-FSV-43-310 and 2-FSV-43-319 installed under wokplan 11077 R1 have wire bend radii which do not meet minimum requirements set forth in M&AI-19 R1 (Ref. 2b) and Conax manual IPS-725 (Ref 4). 8. Work requests B-106737 and B-106242 have been initiated to inspect a sample of installed Conax connectors for proper wire bend radli. Preliminaty inspections indicate that a number of valves using Conax connectors on both units do not meet the specified wire bend radii requirements. 9. On February 10, 1986, SQN Corrective Action. Report (CAR) SQN-CAR-86-02-005 (Ref. 5) was issued to identify an adverse condition related t.o the installation of Conax connectors. This CAR states: Contrary to the requirements of M&AI-19 and the Conax vendor manual IPS-725, not all Conax connectors were installed with wire bend radii within allowable limits. In addition, M&AI-19 is not consistent with the vendor manual revision referenced in the EQ binder. Adherence to these requirements is~necessary to maintain equipment environmental qualification, s As written, M&AI-19 R1 (Ref. 2b) specifies a different torquing sequence and different final torquing values than Conax installation manual IPS-725 (Ref. 4). In addition, M&Al-19 R1 does not provide details regarding application of Grafoil cealant. 10. In accordance with SQU Administrative Instruction AI-12 (Ref. 9) an evaluation of the root cause of the deficiency-addressed by SQN-CAR-86-02-005 must be completed within 30 days of the issuance of a CAR. This evaluation cust also address remedial correctivo action, action to prevent recurrence, cnd a an estimated schedule for completing the corrective action. 11. QC has begun reviewing all workplans and/or work instructions for work affecting any equipment within the scope of the environmental qualification program against vendor instructions to ensure compliance with vendor recommendations. IV. CCNCI.U::IOUS AND RECOMMENDATIONS ~ A. Conclusions 1. The first issue raised by the concern of record is substantiated in that several Conax connectors have been installed on both units 1 and 2 without meeting the minimus wire bend radii requirements set forth in Conax installation manual IPS-725. 3

s ~ 2. The second issue raised by the~ concern o'f record could not be substantiated. Conax connectors were installed in accordance with approved workplans. These workplans had been reviewed and approved by QC. QC inspectors were not directed to inspect Conax installations for proper bend radii. It should be noted, however, that the workplans did not adequately address Conax installation recommendations identified in the vendor's manual regardins minimum wire bend radii. 3. The third issue raised by the concern of record could not be substantiated. CAR SQN-CAR-86-02-005 has been. issued to document Conax connector installation deficiencies. A response, is required by March 12, 1986, unless an extension is approved. B. Recommendations I-86-101-SQN-01, Resolution of Deficiencies The deficiencies identified in corrective action report SQN-CAR-86-02-005 should be addeessed and resolved in accordance with SQN AI-12. (P2] h e e 9 4 O 9 e N e 4 3 yy*_,-

s a DOCUMENTS REVIEWED IN INVESTICATION 1 '86-101-SQti AND REFERENCES 1. Informal memorandum from C. E. Chmiclewski to R. C. Sauer, " Employee Conccen at Sequoyah Nuclear Plant (SQN)," dated December 31, 1985 2. 11odifications and Additions Instruction M&AI-19. " Installation of Conax Connectors" a. RO dated April 12, 1985 b. R1 dated July 26, 1985 3. SQti Environmental, Qualification Binder, "Cenax Conducto.' Seal Assemblies (ECSA) " No. SQt!EQ-CSC-001 4. Cenax Corporation. Installation Manual for Electrical Conductor Seal Assemblies with Long Body for Pipe Thread Equipment Interface, IPS-725 RG, dated February 15, 1985 5. SQti corrective Action Report SQN-CAR-86-02-005 dated February 10, 1986 i 6. Workplan 11077 R1, " Installation of Conax Conne' tors in PASF Valves Inside c Containment," prepared October 15, 1984 s 7. Ucrkplan 11231, "Various Equipment Seals - IIUREG-0588," prepared September 24, 1984 8. Workplan 11335, "Various Equipmer.t Scals - NUREG-0588," prepared November 7, 1984 9. SQt! Adminis. Mtivo Instruction - AI-12. ". Adverse Conditions and Corrective

Actions, 220, dated August 2, 1985.

et e 5

(' (' ATTACHMENT C QUALITY TECHNOLOGY 1 COMPANY g P.O. 00X 600 . Sweetwater. TN 37874 (615)365 4414 ERT I1VESTIGATIOli REPCRT PAGE 1 OF 4 CONCERT 1 NO: XX-85-023-X02 CONCERN: 'Sequoyah; Craft and inspection personnel falsified anchor pull-toutn a::d applicable documents, (Mid-1977, Unit 2, Annulus). INVESTIGATION -PERFORMED BY: T. Ilough DETAILS PERSOt1NEL cot 1TACTED: (CONFIDENTIAL) i 1 e t t

i h ( PAGE 2 OF 4 ERT IMVnGTICATION REPORT CONCCHN :;o: XX-85-023-XO2' DETAILS, cont:nueu 5 DOCUMENTS REVIENED: 1. SNP Incpection Instruction - 93 (II-93) " Testing of Expansion in liardened Concrete and Grouted Anchors" Anchors Set l' R-0 (2/22/77), R-1 (3/22/77), R-16 (8/1/84). 2. General Construction Spoc. G-32 " Bolt Anchors Set in liardened Cencrete" R-0 (9/72), R-4 (4/21/76), R-5 (7/21/77), R-6 i t 4 (2/17/81), and R-10 (4/1/85). t 3. St:P 47A050 " General Notes" (Support Typicals) 4.' Craft Time Cards (1978)

SUMMARY

.0F INVESTIGATION: substantiated. Interviews were conducted with (27) This concern was not anchorc individuals involved in the installation of concrete expansion i-No Eaquoyah during the time frame specified in the concern. ( CEA 's ) ct collaborating /ob3ective evidence was found to allow substantiation of the ccncern. This investigation was conducted. intermittently from 11/25/85 to 2/21/86. FI::DI::GS : review cr The investigation of this conce'rn was approached in two ways; .applic:~r'.e documentation and interview of personnel involved in CEA Insta'4 ncien during 1977. Ac noted during the investigation of a 1 related concern (XX-85-023-001), applicable documentation preved diffic;1: tc cotain. Thic is due tc the fact that work plans were net utilized at SUP until 1981. This fact, when combined with the myriad cf docucented exceptions to anchor pull-testing (Ref: 47A050 notes and applicab:e procedures) and the unlikelihood of finding documentation dictated that the investigation prczing falsificaticn of pull-testing, offert m: ~ ceaarntrated on the interviewing of personnel.

'e rcor n a l reccrd and cost accounting records were reviewed to determine nppropriate perconnel to interview.

A list was developec com p c 19 percennel certified to cer. duct inspections of CEA's and i s v +, wo-e.,a, --.--,----m-y,-- - - - - - +

r-( PAGE 3 Ol' 4 ERT INVMSTIGATION REPORT CONCCHN NO. XX-85-023-X02 D ETAILS, continued ~ . FINDINGS,' continued those persons involved in CEA installation. The list was narrowed by determining whom within the list are still employed locally (i.e., immediately available for interview). Interviews were ccnducted to verify involvement (during specified time-frames), determine compliance with precedural requirements, and ascertain knowledge of wrongdoing activities. Results of the interview process are as follows: o Acquaintance with the individual alleged to have been involved _ in falsification activities could not be established, (even after prompting). o Knowledge of alleged wrongdoing activities was ' limited to WBNP and was denied in_ relation to Sequoyah. Several craft perconnel and a few inspection personnel made reference to activities such as cutting off. " Red-Head" CEA's, welding bolts to the backs of base-plates, etc., but only at

NEMP, nce at~SMP. (Reference various'other ERT concerns).

exception, inspection personnel interviewed o With few. expressed concern regarding the quantity of "47A050 Motes" generated and the ability of anyone to keep abreast of the "050 Notes" and subsequent changes. (Reference varicus other ERT concerns) CONCLUSICUS: This ccncern in not substantiated. Thic ccnclusion is based on the following: o The "47A050 Notes" allowed numerous exceptions to pull-testing, i.e., there were few personnel kncwledge:Lle nbcut exactly when a pull-test abcolutely had to be parfcrmed.

r s. -CRT IllVESTIGATION REPORT PAGE 1 OF 1 5 CCt!CElui -!!O. XX-85-023-X02 DETAILS, continued COlCLUSIONS, continued - ~ o tio documentation could be obtained that would support occurrence of this wrongdoing activity (falsifying pull-test records) o tio collaborating testimony was obtained from personnel involved in CEA installation in the Sequoyah Unit-2 Annulus durin'g 1977. 9 2 6 / PF.EFAFED BY: b f Jh/E DATE 0Df Wsf 3/7/6 V.?'i.' T:.'CD D's : /- ' DATs i i i i

t ATTACllHENT D List of Documents Reviewed in the Evaluation Process Element Report 80203 Quality Technology Corportation Employee Response Team (ERT) Report No. XX-a. 85-023-001 (Revised 10/22/85) b. Me.aara ndum, SQN Site Director to Manager of Nuclear Manager's Review Group, April 24, 1986. c. Memorandum, General Counsel to Manager Nuclear Power, April 30, 1986 (Administratively Confidential) d. Construction Specifications: G-38, R1 " Installing Insulated Cable UP to 15,000 Volt Inclusive" G-32, R4, R5 " Bolt Anchors Set in Hardened Concrete" e. Sequoyah Inspection Instructions: SNP-II-93, R0, R1,'R2 SNP-II-10, R6, R7-SNP-II-26, R0, R1, R2, R3 SNP-II-28, R0, R1, R2 f. Maintenance and Addition Instructions: M&AI-4, R8 M&AI-7, R6 g. Construction QA Procedure, Const. QAP-10.01, R1 h. Haager Drawing General Notes, 47A050 (latest issue of each page) i. NS33 Report I-86-101-SQN, February 27, 1986 j. Corrective Action Report, SQ CAR 86 02 005, 2/10/86 k. Construction CEG Element Report C010900-SQN, November 1986

  • )

s ATTACilMENT E Page 1 ATTAC::i;LNT "- ECSP CORRECTIVE Action Tracking Document (CATD) INITIATION 1. Immediate Corrective Action Required: /Y/ Yes // No 2. Stop 11ork Recommended: // Yes /X/ No 3. CATD No. 80203-SQN-1 4. INITIATION DATE 9/5/86 5. RESPONSIBLE ORGANIZATION: QACEG 6. PROBLEM DESCRIPTION: /X/ QR /[/ HQll

  • k:

Engineering to determine by evaluation, the long term effect on cable where insulation was possibly repaired by the use of electrical tape. 440 vole cable feeding Back Flow Cate lloist Motors (IAA, IBB, 2AA, 2BB) A /* // r////// // \\ / /ATTACIL'1ENTS 7. PREPARED BY: NAME D.G. Barlow /W'[/ AP/qo..) DATE:

0. / f. f[

8. CONCURRENCE: CEG-H A'M/)'M M , DATE: 0-tk 's(, 9. APPROVAL: ECTG PROGRAM f1GR: fFhlfLf4 f DATE: 2[2[9/ CORRECTIVE ACTION 10. PROPOSED CORRECTIVE ACTION PLAN: Nonll ~ SfL fufflFIC*tnod D*J Mnfo%M" It OF /fEAfof%tiDud 13 2'T t0IOIJ O9& DMc D Oc's1~l,l'!ff fg .,, 7 e / / /// / / /ATTACl41EN,TS 11. PROPOSED BY: DIRECTOR /MGR: ht/h//////4(t/At4-DATE: ///2/W f 12. CONCURRENCE: CEG-ll ~ DATE: SRP: DATE: ECTG PROGRAM MGR: DATE: VERIFICATIO!I AND CLOSE0UT g 13. Approved corrective actions have been verified as satisfactorily implemented. SIGNATURE TITLE liATE um

iva a io... ATTACHMENT E Pzge 2 i sirui sran:s iawi:nn.ui:xr S03 8G1022 808 Mcmorandum TENNESSEE VALLEY AUTIIOI!ITY 1"- W. R. Brown, Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant l'33 OI

11. l.. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant li ATI:

Del.ober 29, 1986 srlui:cr: SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 802.03 SQN - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)

Reference:

Your memorandum to me dated October 2, 1986, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report 80203-SQN - Inspection Performance (Sequoyah)" (T25 861002 871) I acknowledge receipt of your element report and in accordance with your request (see reference), Element Report 802.03 SQN has been reviewed for applicable corrective action. By way of this memorandum I am endorsing the site line organization CAP and attaching the CAP for your review / concurrence and returning your Corrective Action Tracking Docament 80203-SQN-1. 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. U $?lM?! H. L. Ab6rcrombid RCD:JDS:JB:CS Attachments cc (Attachments): R E C E *i E n RIMS, MR 4N 72A-C (B25 '861017 076) A. G. Dobbage, ONP, ECTG Building, WDN gg 3 g# i I 0221T Emp!om C nu..

n,t l C-ce
r a B.ra m

-- t-- m; - - ,3 .s.m 5- -~- ---~,.- q. _.,- I r- _~), F .a - Y-j t~--- --y.... ,g [ ,;----{--4._..',__ -y-~--. --p.-......_ 0 5.. ~774 Y .l..... f f m_r-i _ l' ^. /

\\ i a Standard Practice Page 8 SQA166 Revision 8 Attachment A Page 1 of 2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Number 80 2 O Y % A/ 47b# FO2d3-S M -/ Lead Organization Responsible for Corrective Action Plan bM 4,#,'F3rP/X/4 Initiation Date /d 74, CCRRECTIVE ACTICN PLAN (CAP) 1.Doesthisreportrequire[correctiveaction? Yes No N (If yes, describe corrective action to be taken, if no, provide justification) Sroel 17HWL /$ rio Mntillo IMfvimM1& AI 7NL MLt4@ CMtWidsutened fdf91L hV nW uSL of St4cnud OffL APO 8/10/r C4d 6C Tkth) f0/L nM. 77WL-fifM1fv, ${A'ortBS f0/Z 7NL('n Cedf ileltDusT* AMW3 FM /s/DIC47f Kofff}t!0Lf-tusrm M'no.J wo 7tsnrG f th-hr m 'mitML). 7?Nkst C40tf3 Hikil 64bJ oJ selficL stoel 1911 it.JO id ML LIrlL1 Hood Du24df-7?t/S AI/WL Yb91t N/Zwo th%Al BYf%dllAtib 7% wcMr CoJoanodSf/r)CluDrH&- Submil04&C) TihW MCY sullL dl SutSittite TD wnMuT MY Piobl4.ms. DMio oJ 7NL Rtkvl-tuf CobOb 7N#f 77tt IAhsw/J1102 5 t 2. Identify any similar item / instances and corrective action taken.

3. Will corrective action preclude recurrence of findings?

Yes K No

4. Does this report contain findings that are conditions adverse to quality (CAQ) as defined by AI-12 or NEP 9.1?

YES No X

5. IF a CAQ condition exists, what CAQ document was initiated?

MlA

6. Uhich site section/ organization is responsible for corrective action?

M ova L

7. Is corrective action required for restart?

Yes No X (This determination is to be made using Attachment C of SQA166.)

8. P2 :one number for restart corrective action? Zone eJ f A l
9. Estimate completion date for correction action, t4 l A Compieted By

'//Mj. m Date Ocf /g /0/g(, O, j E G Concu rence ^ lf Date g / h ?>Pn1PGL w&S mot Sarfter bl** TD Intfftt/L 77tl AsJCr7& 9F dt%tf /hvD rio fullTilff ACDe>J IS AdQ't//l@- l i l i O'0 M ".nlt l l L

t ~ Standard Practics Paga 9 SQA166 Revision 8 ATTACHMDIT A Page 2 of 2 CAP CLOSURE 10._ Was your corrective action initiated and completed in accordance with step l? Yes No

11. If step 10 is no, describe the corrective action taken.
12. Is the corrective action implementation complete?

Yes No

13. Is the corrective action documentation closed?

Yes No

14. What documents were used to implement the corrective action?

Completed By: Date Verified By: 'Date ECTG Closure: Date (Step No.) -Description 0206S/mit

s ATTACitMENT F 1 ECSP CORRECTIVE Action Tracking Document (CATD) INITIATION ~ 1. Immediate Corrective Action Required: // Yes 7 // No 2. Stop Work Recommended: // Yes /X/ No 3. CATD No. 80203-SQN-02 4. INITIATION DATE 11/18/86 5. RESPONSIBLE ORGANIZATION: Office of Nuclear Power 6. PROBLEM DESCRIPTION: /X/ QR /;/ NQR Employce' concern 00-85-005-003 was investigated by QACEG and COCEG. COCEG investigation C010900-SQN indicates that cables 1-PL-6370-B l-PL-6360-A, 2-PL-6370-B and 2-PL-6370 which supplies power feed to the ERCW Backflow Gate Hoist Motors have been de-energized and the motors permenately taken out of service. QACEG invstigation reveals Design Drawings 45N-751-1, -2, -5, and -6 do nct reflect this system status. A / //ATTACIBIENTS 7. PREPARED BY: NAME R. D. Halverson, @ DATE: 11/18/86 8. CONCURRENCE: CEG-il R. K. Maxon N'!C ff. ! I, /. DATE: >r ! 9, 9 'e 9. APPROVAL: ECTG PROGRAM MGR: /R!ffiz,.4 ' d DATE: 2/2/p') CORRt'CTlV6 A'J f10N 10. PROPOSED CORRECTIVE ACTION PLAN: / /ATTACIDIENTS 11. PROPOSED BY: DIRECTOR /MGR: DATE: 12. CONCURRENCE: CEG-H DATE: SRP: DATE: ECTG PROGRAM MCR: DATE: VERIFTCATION AND CLOSEOUT 11 Approved corrective actions have been verified as satisfactorily implemented. SIGNATURE TITLE DATE

. m.. o... u. g g I'NITED 8TxrEs i;oVERN. TIE.vr 3 8 0 M C 4 - 80 (i Mearioratidttm TENNESSEE VALLEY AUTIlORITY T"

11. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant FU"33 H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant DATE Deceraber 24, 1986 8UH W T:

SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 802.03 SQN - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)

Reference:

YourmemorandumtomedatedNove$ber 25, 1986, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report 80203-SQN - Inspection P6cformance (Sequoyah)" (T25 861125 891) I acknowledge receipt of your element report and in accordance with your request (see reference), Element Report 802.03 SQN has been reviewed for applicable corrective action. By way of this memorandum I am endorsing the site line organization CAP, returning your Corrective Action Tracking Document No. 80203-SQN-02, 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 checkl i s t. f H. L. Abe r e r.mM e _.__ ____.. _, P F :'E tV F r RCD:JDS:JB:CS l A t t.achmen ts p' -, pg cc (Attachments): l RIMS, MR AN 72A-C (B25 '861218 025) r.m g,g.,, ,g, T. C. Price, 5-212 SB-K e:.i.p r.. - I l~_T_.,.. ___"! n er.n n 0495T iD ~ ___.l .p__.' i .. ~ i_.. L ..(.(.. l g-l--, i

t...

.' __..}.._. l. ; 9.,... j _. _.... L U Ir ~ i G) LL6.1,J .~I. .I: 1 l

\\ s ECSP CORRECTIVE Action Tracking Document (CATD) INITIATION 1. Immediate Corrective Action Required: // Yes // No ~ 7 2. Stop Work Recommended: // Yes /I] No 3. CATD No. 80203-SQN-02 4. INITIATION DATE 11/18/86 5. RESPONSIBLE ORGANIZATION: Office of Nuclear Power 6. PROBLEM DESCRIPTION: /K_/ QR /;/ NQR Employee concern 00-85-005-003 was investigated by QACEG and COCEG. COCEG investigation C010900-SQN indicates that cables 1-PL-6370-B l-PL-6360-A, 2-PL-6370-B and 2-PL-6370 which supplies power feed to the ERCW Backflow Gate Hoist Motors have been de-energized and the motors permenately taken out of service. QACEG invstigation reveals Design Drawings 45N-751-1, ~2, -5, and -6 do reflect this system status. not / // ATTACHMENTS 7. PREPARED BY: HAME R. D. Halverson, KLi W DATE: 11/18/86 8. CONCURRENCE: CEG-H R. K. Maxon /</< // fl-f; DATE: /t /]S /V L-9. APPROVAL: ECTG PROGRAM MGR: 8/u/(.p V 'd-DATE: 7//// > CORRECTIVE ACTION 10. PROPOSED CORRECTIVE ACTION PLAN: SbE tat MP 7"DIA'Smi#s7) BY /Mexmbl^ 'om,' /?]'A'?S */ E *if A6 /2/5' 025' r a V? / / ATTACHMENTS 11. PROPOSED BY: DIRECTOR /MGR: # /# h /4., DATE: /J -M-/-4 12. CONCURRENCE: CEG-H. DATE: SRP: DATE: ECTG PROGRAM MGR: DATE: VERIFICATION AND CLOSEOUT 13. Approved corrective actions have been verified as satisfactorily implemented. SIGNATURE TITLE DATE

s Standard Practice Page 8 SQA166 Revision 8 ( Attachment A w Page 1 of 2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Number 7 0 2,O 3 5 9 M bM 702.C5-5 9,u - o 7-Lead Organi=ation Responsible for Corrective Action Plan P 6. Initiation Date // % CORRECTIVS ACTION PLAN (CAP) ~

1. Does this report require corrective action?

Yes No (If yes, describe corrective action to be taken, if no, provide justifi ation) 7Ae elu2kal. M w A M d-w sak & Acm ufA:%A M -to %ent eM /n -fla A M L EcNL 571,0). 7he. Jna Am 4,v s /, >L 0 Lfew-s-afa., 'ttoi<t & t%tz M i= ""A w;k E Ou% 6vdW' % dJ M M ? PJ92-m -1/u a&M Gmmo L HS8 Plo70 ?O/C'. C/m M aul -tha h. 2. Id6ntify any similar item / instances and corrective action taken. 2 N/A i;- r / (

3. Will corrective action preclude rec rence of findings?

Yes No

4. Does this report contain findings t at are conditions adverse to aualitv (CAQ) as defined by AI-12 or NEP 9.l?

YES No

5. IP a CAQ condition exists, what CA(

ocument was initiated?

6. Which site section/ organization is sponsible for corrective action?
7. Is corrective action required for estart?

Yes No _ _ l (This determination is to be made using Attachment C of SQA166.) 1

8. P2 one number for restart corre tive action? Zone
9. Estimate completion date for cor ection action.

Approved By ##6 ['.~ OL// h Date /7- / f.- J-l. [ Date /2-/7-$Y f)) Completed By ECTG Concurrence ~ ~ ~ Date l 0.'06S/mit l

t s s Standard Practice Page 9 + SQA166 Revision 8 ATTACIIMDIT A Page 2 of 2 CAP CLOSURE

10. Was your corrective action initiated and completed in accordance with step 17 Yes No
11. If step 10 is no, describe the corrective action taken.
12. Is the corrective action implementation complete?

Yes No

13. Is the corrective action documentation closed?

Yes No

14. What documents were used to implement the corrective action?

Completed By: Date Verified By: Date ECTG Closure: Date (Step !!o. ) Description d L 02063/mit

nao mv. n.u w , m ns.-au,mr morandum TENNESSEE VALLEY AUTIIORITY 810717E0130 2. Rose Listed C. A. Chandley, Chief, Hechanical Engineering Branch, W10D224 C-K JUL 8 1981 SEQUOYAll NUCLEAR PLANT - DISPOSITION OF DESICN CilANGE REQUEST (DCR) , g., SQ-DCR-891 CONDENSER CIRCULATING WATER SYSTEM (CCW) AND PREOP TEST - TVA-17 TEST

  • DEFICIENCY NO. PT-600 ricuiocanduw from 11. J. Green to M. N. Sprouse dated Dec, ember 6,
n. &

..a 19fl0 (DES-80-12-17-021), and DCR-971 We recommend disapproval of SQ-DCR-891. The subject pressure switches for units 1 and 2; PS-0131 A and B, -132 A and B, and -134 A and B; were safety-related switches to activate the closure of the CCW backflow gates. This functional requirement was deleted when the new essential raw cooling water pumping station was activated. As long as these suitches are installed, they can activate the closure of the backflow gates and possibly trip the unit. Since the safety-related closure requirement of the backflow gates no longer exists, the closure of the backflow gates and the shutdown of any CCW pumps should be under the control of the unit operator and not automatically actuated. D erefore, we recommend the following: 1. Removal from both units of PS-027-131 A and B, -132 A and B, and -134 A and B. 2. Do not buy any replacement switches. 3. Revise the following drawings to delete the above pressure switches and ~ their functional use: ~ Control Diagram 47W810-27-series Logic Diagram 47W611-27-series Instrumentation Tab 47B601-27-series Pumping Station 37W205-series Any other drawings l If you are in concurrence, we will revise the scoping document for the l preop test TVA-17. l Buy I'.S..\\atano Bonal> R, uutarly an slu l'apull Savino I'lan sa l l

\\ \\ 2 Those Linted JUL 8 1981 SEQUOYAll NUCLEAR PLANT - DISPOSITION OF DESIGN CHANGE REQUEST (DCR) SQ-DCR-891 CONDENSER CIRCULATINC WATER SYSTEM (CCW) AND PREOP TEST - TVA-17 TEST DEFICIENCY NO. PT-600 Please correct the reference drawing number 47W601-27-series instrumentation tabulation to read 47B601-27-series on drawing 47W610-27-1. Please respond by July 31, 1981. C. A. Chandley F. W. Chandler, W8Cl26 C-K J. E. Holladay, W2D224 C-K J. A. Raulston, W10Cl26 C-K g R. W. Cantrell, 204 GB-K

  • ff7 JEM:JES cc M. N. Sprouse, W11A9 C-K f ;., $

UL n 1981 MNS:JES-- ,H. J. Green, 1750 CST 2-C - Please respond by July 31, 1981. cc [MEDS, E4B37 C-K v f i E81187.09

v' .7, pa-t s CLEARANCE SHEET ORoEn NO. 20(2 SHLET NO. SEQUOYAH NUCLEAR PLANT

p. nu-t s o n omL OF st-f N. -

'y' ( ) " "^'" C t...a..., ,.c f. r. u b. r.'.- ldnTe c Sbk 7 \\n-b& l - [*UEl.D DATE REQUESTED BY EQUIPMENT CLEARED DY /"I 54 /./ - d 7i. e n e, e k cAu,._m.s. WORK TO DE DONE.)e O..} <> n v,-n e 7.<> VMd4-- ti I;e K lx l\\ e n ( bD i nc. ck..,iis s l i i

c. c u s'., M.. -

1b nv du le a ',n a u r.n a k a -t, i r ()t.*i/t.'nt' GDe c% '< *. m E/ kin?_ (' b i v e-REMARKS AND INSTRUCTIONS K 4 ISSUE RELEASE ISSUED TO TIME DATE TIME DATE 14 5 /r l') f4 / -I -M i i c a.2 e / 2. ~; ~' J;,,7 i -r a_ L' y b'k * C' ,,.3

  • p J

fgg,g &Mctr ne f/ ,.t* l l ,A. Vr s/ C/ens** C t/" Q g u.v, u, w c c u ".*/'A fo, ce> W l/ V /o / (* fvg /, 9s sy ..s- / 9 6 / J' 5' I .o 7 // AJJ4 N l W M" m ?dditional clearanco sheels are a part of this clearanco and must be properly roloosed. O ves ( '..'- 4 rounds have boon placed in conjunction with this clearanco. YES O Aiioch Sareiv cround ror-Ct. EAR At4CI RELE AWD Oy TIME DATE ,Wrcett) t' age t ~

CLE AR ANCE l..EET ORDEn NO., ee<c SEQUOYAH NUCLEAR PLANT C.,,,3,. n d-i,W , p, c,,,,,,, j APPARATUS s (A-)OTr' r 7l_) fo r IT kisw P[ h:' c } ( n t'. th A res p t r r La C. A DETERMINATION OF 2nd PARTY N IRED (CHECK ONE) DEIpRMitJED DY: (SRO) VERIFICATION REQUIREMENT [] REQUIRED % '3 h h 3 c w_ %g REMOVAL FROM SERVICE / RELEASE OF CLEARANCE O VALVE DRAIN 2nd EQUIPMENT RETURN 2ed U CLOSED OR PERSOf4 RELEASED PERSON E TO NORMAL E VALVES BREAKERS. SwlTCHES. OREAKER VENT VERIFI-no7

yggggg, N

OR SWITCH OPEN CATION N AllGNED CATICN i C OR FUSES HELD. OPEN. IF C NORMAL Ip E FUSE PULLED REQUIRED E RECulRED (LOCATION AS NEEDED) g no, initials initials inittels NO. Initials initials initials //Ill) On Ol(Y C m) 9C I s In t n 0 i nu. t/ c MAI Y0 I min % nw cd w hRG I BAln Rx Ale t/L.h 7cI f.- ] l i j _Q.. l l l l l 1 a t I ~ (' ~ ~,

'[k% l(]' O _____ 7 q j 3 - {,,...

.p.7 r.

3 .7 .,. ( j {k..'.f }i 7 f $, /, I .. g. I j 8*' p ,9) [' , ! '~ r.. g-% c1. Y o. g:l=, - ) E -

Wj

. ? \\;f[' lf ':W,' h

  • '1

'i ' {y. . ? h. (J . f;'I '.. ' <,.h.'. ', -..y $' yg12iCW.. ' ^. ~

  • gq~ Q k

N'*:\\~ .i Qi ' ~qw. 9 i [g & ik ~ ' f g /4 W (/PL 6560A) winM M no of W R ,f_'TY?y) & AAL 'Mef. l ,y. z. -.,.- - _.,, ) .i ~ j geen- 'c' s ,C1 g., -n- .~

3. w sy1. a
  1. e.

a rA

  • I

,l k [ f,'.'.~ hh k'}.. e ~ 0;4.. v.w "'$lh( N S & =;; Q~: %, ' c==a c,,, -;., m..g , m /.; ~. ; ~ .F : - .a.r. Ed w

c. m yw-.

..<hc vg . p l yY. 7-gAr h t- ~i la r. y 1,g. ' d.'. 2.T. 3'.. Eng%. f d.;. b 2*M ~ ~2 'C ~ .se.is c )l N u ' G 8 1 vt O r W 2 e l?- l& Ogh 2oi2-e hk bryf IL (hj It"' ' I im :.cw f ~ ^~"!TFo

\\ 000 " ^ ' i sm:i, m n:s em cus3iixr [V[CHIOTdHcfH)H TENNESSEE val.l.EY Ai;Tilol:ITY W. R. Brown, Jr., Program Manager, Employee Concerns Task Group ONP, To Watts Bar Nuclear Plant H. L. Abercromble. Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant

non

.lanuary 24, 1987 luTI: SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) s r H.f ECT: REPORT 802.03 SQN R1 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP) REVISION

Reference:

My memorandum to you dated December 24, 1986, "Sequoyah Nuclear Plant (SQN) - Employee Concerns Task Group (ECTG) Element Report 802.03 SQN - Quality Assurance Category - Corrective Action Plan (CAP)" (S03 861224 806) Attached is my revised CAP for Element Report 802.03 SQN R1, Corrective Action Tracking Document No. 80203-SQN-02 for your review / concurrence. This revised CAP supersedes the CAP previously transmitted to you (see reference) and 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. Ykk jg H. L. Abercrombie RCD:JDS:JB:CS Attachment RIMS, HR 4N 72A-C (B25 '870123 037) RE;EIVED cc: T. C. Price, 5-212 SB-K (Attachment) <c JA6' 2 6. *67 0569T Emplo/ 2 Cence r s Task C.mus, wy s ' ' * $ _S 454 g Grcz.ns r- ..s g;-- ..___.i g

l.W

~ p g-- g-Z C _.i ~~ ,.YF + i. __ 1_7b. ' ~ ~ ~ (3 sx o ~ SIP ~I'AS iS5?P i t.T W 7,.u

-} --

f ~l' .._ O Jff-Q GODg b\\! n a ri r.. r,.,,,, r t,. 15,,,.7,,11 Sm.;,, y e p/,r rr

g OHDER, tJO.[ .! t- /C \\ SEOUOYAH NUCLtaR PLANT Ca.,; i,,. n e - o e-f 9,.,,, ^ APPARAIUS s k < n. {s 1 r r ga

t. hnn rgTr* y-

]lJ c, e h k ki _,w - chet c e a t.,p w DETERutt4ATIOta OF 2nd PARTY VERiflCATIOtJ REQUIREMENT (CHECK OtJE) OUIRED TN @DETENNED BW (SAO)\\h(*% [ [] REQUIRED REMOVAL FROM SERVICE g RELEASE OF CLEARAtiCE j U. VALVE DRAIN 2nd EQUIPMENT RETURil "?nd CLOSED OR PERSON E VALVES. DRE AKERS. SWITCHES. BREAKER VENT VERIF1-E RELEASED uor TO tJORMAL ERS N vggi,. C OR FUSES HELD. OR SWITCH OPEN CATION N AllGt4ED OPEN. IF C NORMAL CATIC gp (LOCATION AS NEEDED) NO. Initials Initials Inillels NO. Inlllais Inillais initly Inin Rx 0ku' c 4 7Cl bb I in H s Gy n\\ t. v' ec 1AI Y0 anin nw ch w hRG anm n, nwnh,a lhlk3 ~ I l I aum i e E ~}.~ ' I,J.i_

  1. 89.. h t om...

g o Standard Practice Page 3 SQA166 Revisicn 3 ( Attachment A Page 1 of 2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Number 802..O 3 SGM E.( / CMTD # SO Z.03 - SQ # -0 2.- Lead Organization Responsible for Corrective Action Plan N(r-Initiation Date l /~ 2. 8-6(o CCRRECTIVE ACTION PLAN (CAP) f!

1. Does this report require corrective action?

Yes No (If yes, describe corrective action to be taken, if no, provide justification) of > > M 0,1 nwi&S HA) 7Cl - I - /. - s~ M.o b -6 DC MhlerTM mrCrn

  • rmen Mt wfs't.< THE 14dCTitledb C4btuif" l'svl 17th /$bCL fusJ thr1T5,'ht1) N C.d

' fe,A'[it[th flun) /111rsmitMC l'Comu l. To m h httt& & n:rt:tL. 13y 11ti .tisto r' _cl{rtmbL f fed L.E'1 w) n'entll 1/f- )tns /MrkittiY -tv Oc, Off-621r98t: < feil 7/te. JACL Fred GnTG ikoU" ths ;TK'i ACf, Mous' Mk!CCD seint 'Cmint ~) t i:0Ci-* ' :f' ;* t'*- ilD. inh Mahib ((Yetmwd PLC<ML "XL rift-IMT)W(4(6 /h(int 4 mfA 6 s u 1 t.'l( i4 ) ' C L(tu.'nas. hKET' tb>h fKn4 MS /W AmirW te am fMt ito t00 t 2. Identify any simil'ar item / instances and corrective action taken. ., Is N / r7

3. Will corrective action pre ude recurrence of findings?

Yes flo

4. Does this report contain f ndings that are conditions adverse to quality (CAQ) as defined by AI-12 or flE 9.l?

YES No

5. IF a CAQ condition exist, what CAQ document was initiated?
6. Which site section/organiza ion is responsible for corrective action?
7. Is corrective action requi ed for restart?

Yes No (This determination is to e made using Attachment C of SQA166.)

8. P2 zone number for resta corrective action? Zone
9. Estimate completion dat for correction action.

<M,f w, Date / '~d/ 'b 7 Completed By d Approved By g af. h Date /-23-f7 ECTG Concurrence Date 0206S/mit

~ ............. m... s 1 neo o n vWm m o ra n d u m Texxesses vau.sv wrnourr 810717E0130 1 hose Listed 2. C. A. Chandley, Chief, Hechanical Engineering Dranch, W10D224 C-K JUL 8 1981 SEQUOYAll NUCLEAR PLANT - DISPOSITION OF DESIGN CHANCE REQUEST (DCR) 3., SQ-DCR-891 CONDENSER CIRCULATING WATER SYSTEM (CCW) AND PREOP TEST - TVA-17 TEST

  • DEFICIENCY NO. PT-600 lict.toi autluta from H. J. Creen to M. N. Sprouse dated Dec, ember 6,

.u. i u o..c e : 1980 (DES-80-12-17-021), and DCR-971 i We recommend disapproval of SQ-DCR-891. The subject pressure switches for units 1 and 2; PS-0131 A and B, -132 A and B, and -134 A and B; were safety-related switches to activate the closure of the CCW backflow gates. functional requirement was deleted when the new essential raw cooling [

  • This I

water pumping station was activated. As long as these suitches are installed, they can activate the closure of the backflow gates and possibly trip the unit. Since the safety-related closure requirement of the backflow gates no longer exists, the closure of the backflow gates and the shutdown of any CCW pumps should be under the 7 re control of the unit operator and not automatically actuated. Therefore, we recommend the following: ? e[,, 1. Removal from both units of PS-027-131 A and B, -132 A and B, and -134 A end B. ,] 2. Do not buy any replacement switches. w A 3. Revise the following drawings to delete the above pressure switches and ~ their functional use: p. Control Diagram 47W810-27-series g', ~ l Logic Diagram 47W611-27-series Instrumentation Tab 47B601-27-series ,h. Pumping Station 37W205-series Any other drawings i If you are in concurrence, we will revise the scoping document for the r* preop test TVA-17. ,g ..i - h h n,,,. v.s. s,,,....,, n...s, n.. a,,a... a. v..r,ai s,,a,, a. a r

s Those Li s t eil JUL 8 1981 SEQUOYAll NUCLEAR PLANT - DISPOSITION OF DESIGN CilANCE REQUEST SQ-DCR-891 CONDENSER CIRCULATING WATER SYSTEM (CCW) AND PREOP TEST - DEFICIENCY NO. PT-600 Please correct the reference drawing number 47W601-27-series instrumentation tabulation to read 47B601-27-series on drawing 47W610-27-1. Please respond by July 31, 1981. C. A. Chandley F. W. Chandler, W8Cl26 C-K J. E. Holladay, W2D224 C-K J. A. Raulston, W10Cl26 C-K R. W. Cantrell, 204 GB-K 1 l "If7 ^ JEM:JES jg',j cc: M. N. Sprouse, WllA9 C-K HNS JES-J O L O Ibbi cc: H. J. Green, 1750 CST 2-C - Please respond by July 31, 1981. [HEDS, E4B37 C-K = s E81187.09

g i o - CLEARAtJCE SHEET oRDEn no 2 c,._ 3.u.: SEQUOYAH NUCLEAR PLANT ,,i:__ cr n a,a son u\\ e Y, r, (P s-rg W \\c,y h \\ t* r '~ r... \\ s,, *.. r- .ee ~ ~~ c. 1p:[*.. ELD I 8 !] $'f DATE[ !' $ _. T,\\'f\\E,C.N Cds M,,=w_w ED BY REQUESTED BY EQUIPMENT CLEAR s, WORK TO DE DOtJE _)c tT t.l e m v r n,. x e s i -d'mTlnn c.l,,,,, f_ u 736 x tuh e n i C C Id I, d ,w Onr in)s'l'a/lcet cN< A f.Di-6k D e 'I <, m a i r h t' './ < GD? ':,tw t- / l 4 n t. O \\ L 1 'e' REMARKS AND lidSTRUCTIONS \\ g 4 ISSUE RELEASE ISSUED TO TIME DATE TIME DATE M $ /r l1 f4 / - / -f(, I C O.t o li hs "rs[ /4 ?)h...' Nw= o ge,,: s sc \\: au., nn e w-- f,'/r*t/ C/c rrein g t.p* ,o /,. o s &t,,7, s7 U of$d"4 " UO ce yf/t*/~AO ' /Vaf Yl Y f,- * .e,eo // PC JY s' f/ 96 f)

  • I,. A

// A J cF6 s/ E' 4W-I "' ' * = @?-?dditional clearanco shoots are a part of this clearance and must O ves '"E * * aroundS have boon placed in conjunction with thl3 Cloerence. YES O ^iiach Soleiv crouad ra<- CLEARANCE REMD DY TIME DATE . Vicat) Page 3 .-7. - +.. - - - + = -+- - m -}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20210H262&oldid=4020832"