ML20214Q741
| ML20214Q741 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/18/1987 |
| From: | Barlow D, Deangelis J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214Q673 | List: |
| References | |
| 80504-SQN, 80504-SQN-R05, 80504-SQN-R5, NUDOCS 8706050145 | |
| Download: ML20214Q741 (33) | |
Text
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 5
Element Report PAGE 1 0F 28 TITLE:
Quality Assurance Records REASON FOR REVISION: Revised to incorporate NRC comments.
Revision indicators are shown in the right margin on each page.
Note: Sequoyah Applicability Only PREPARATION PREPARED BY: D. G. Barlow /J. J. DeAngelis
/
' b/n SIGNA
\} 9 [
.L DATE
'YE7 REVIEWS PEER:
m h- f.Ill S-// f 7 DATE SIGNA 711RY '
TAS:
$6 Y' 'l $bs<te SIGNATURE 4, AAG,f.6f ,
S//8/87
/ DATE CONCURRENCES CEG-H :
i A f,/ i
[6 SRP z u _ E nr:// k SIGNATURE DATE [IGN/sTURE*////l6 fl DATE APPROVEDBJ ECIP MANAGER yi b
DtTE
N/A MANAGER OF NUCLEAR DATE POWER CONCURRENCE (FINAL REPORT OhlY)
- SRP Secretary's signature denotes SRP cencurrences are in files.
8706050145 DR 870526 p ADOCK 05000327 PDR
'd, f TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 2 0F 28 Quality Assurance Records 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction The issues described below were taken from employee concerns generated as a result of the Watts Bar Employee Concern Special Program. The issues were investigated and evaluated at the Sequoyah Nuclear Plant (SQN) since they were deemed to be site specific or to have generic applicability to SQN.
1.2 Description of Issues The conditions reported (Attachment A) by concerned employees are:
- a. Controlled documents contain conflicting or obsolete data or both. (SQM-86-002-005, SQM-86-002-006, SQM-86-003-002)
- b. Work which had been performed had not been appropriately documented. (SQM-86-011-002)
- c. Poor material control. Traceability of requirements and materials is inadequate and paperwork for quality records is poor. (XX-85-122-042)
- d. The retrieval of Quality Assurance (QA) records is inadequate and records are not identifiable. (IN-85-357-001, SQM-86-002-001, SQP-86-002-001, and WBP-86-009-001)
- e. Welder Certification records were altered. (IN-85-612-X07, XX-85-088-X04)
NOTE: Falsification of Welders' Qualification Records will be addressed seperately by the TVA Office of the Inspector General.
- f. Maintenance Requests (MRs) which specified the addition of grease for Limitorque valve actuators were signed off as being unnecessary or as being complete even though no work was performed. Non-QA material was installed in QA applications and traceability was falsified on the MR. (JLH-86-001)
- g. Quality Assurance (QA) documents were lost by the vault personnel and regenerated by the responsible unit. (IN-85-091-001)
- h. Inspection records may reflect improper data. (SQM-86-009-X04)
O s TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 3 0F 28 Quality Assurance Records 2.0
SUMMARY
2.1 Summary of Characterization of Issues These issues were grouped into the element of Quality Assurance Records since they indicated that quality documents have been lost, regenerated, altered and contained conflicting or obsolete data or both. The issues also indicated that the QA records are not identifiable or retrievable.
2.2 Summary of Evaluation Process The evaluation process consisted of a search of the available concerns files and reviews of regulatory requirements and industry standards.
Likewise, reviews were made of the TVA upper tier requirement documents such as the Topical Report, Nuclear Quality Assurance Manual and Final Safety Analysis Report together with lower tier implementing documents such as procedures and instructions to determine requirements, commitments and responsibilities. Reviews of associated documentation and field verification along with discussions with cognizant personnel were also performed as part of the investigation of the issues.
A listing of the documents utilized in the investigation and evaluation process for this Element Report js included as Attachment B.
2.3 Summary of Findings 2.3.1 Issue - Controlled documents contain conflicting or obsolete data or both.
The Employee Concern file provided clarification of this issue which directed this investigation into the area of vendor design drawings (mylars) and the system for requesting duplicates of original drawings. This replacement appears to be mainly for those vendor drawings received prior to 1976 when site copies of these drawings were routinely discarded.
Thus, there was the need at the site for wash-offs (a wash-off being a replacement original from the aperture card in Knoxville). There is a potential for the two " originals" to contain obsolete or conflicting data when one drawing is updated and not the other. Conflicting data occurs when a replacement for an original drawing is used as the baseline drawing for subsequent changes and the missing drawing reappears and is not properly dispositioned. Controls are now in place to avoid lost and duplicate drawings.
The Employee Concern file also provided clarification of
'o .
TVA EMPLOYEE CONCERNS REPORT NUMBERt SPECIAL PROGRAM 80504-SQN
~
REVISION NUMBER:
REPORT TYPE Element Report 5 TITLE: PAGE 4 0F 28 Quality Assurance Records another concern dealing with this issue which directed this investigation to a specific wiring diagram mylar which was issued twice with the same revision number. Failure to log-out the first release of Revision 8 also created the potential for two mylars to contain obsolete or conflicting data when one drawing is updated and not the other. This appeared to be an isolated case and was due to the relocation of the SQN Engineering Project to the site with new clerical personnel in the Drawing Control Center. Procedures are adequate and additional training has been provided in the area of drawing control and issue.
2.3.2 Issue - Work which had been performed had not been appropriately documented. (Environmental Qualification of Equipment)
The investigation of the issue dealt with the actual employee concern which said that Sequoyah was shutdown in August 1985 due to a failure of a group to appropriately document work which had been performed. This investigation determined the concern was valid as Sequoyah was shutdown in August 1985 due to questions about the environmental qualification of electrical equipment. The SQN Nuclear Performance Plan specifies the corrective actions to be taken by SQN for Environmental Qualifications.
2.3.3 Issue - Poor material control. Traceability of requirements and materials is inadequate, and paperwork for quality records is poor.
The investigation of the issue of poor material traceability /
control, inadequacy of requirements, and inadequate quality records provided evidence that the major problem in material control was inadequate instructions or failure to follow procedures and instructions. Examples of improper traceability of quality requirements for materials received were also found along with examples where traceability of paperwork to actual hardware could not be established.
The Material Control CEG has performed extensive investigations in the hardware areas of material control and has reported their findings separately.
2.3.4 Issue - The retrieval of QA records is inadequate and records are not identifiable.
The investigation of an inadequate QA records retrievable system at SQN was reviewed for Construction and Operation QA records. Record retrievability was found to be inadequate for
a .
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE . REVISION NUMBER:
Element Report 5 TITLE : PAGE 5 0F 28 Quality Assurance Records contruction records since the document retrieval system is not fully operational. However, the retrieval of operational QA records (those needed for the operations phase) was found to be adequate.
2.3.5 Issue - Welder certification records were altered.
The irivestigation of the issue of welder certifications being altered provided evidence of various types of documentation errors. There was evidence of Corrective Action Requests (CARS), Deficiency Reports (DRs), and Survey Checklists also having been written which deal with altering welder records.
2.3.6 Issue - Maintenance Requests (MRs) which specified the addition of grease for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications '
and traceability was falsified on MR.
The investigation of the issue produced evidence that all SQN Unit 2 Limitorque valve actuators have been inspected and that the actuators have been properly greased in accordance with the maintenance procedure.
2.3.7 Issue - Quality Assurance (QA) documents were lost by the vault personnel and regenerated by the responsible unit.
The investigation into the issue of quality documentation being lost by the vault personnel and later regenerated by the responsible unit found no evidence of this condition having been documented at SQN.
When lost documents were identified at SQN, QA personnel did not document the condition. In such cases, the records storage vault personnel identified the documents to the responsible unit and a duplicate copy was furnished for storage.
2.3.6 Issue - Inspection records may reflect improper data.
The issue that inspection records may contain conflicting data was not addressed within the scope of the Quality Assurance Category Evaluation Group (QACEG) evaluation. The concerned individual (Cl) was not specific to the type of data or inspection records that may contain conflicting data.
Additionally, the Employee Concern and Confidential Files contained no information that identified the specific inspection records or data that would specify the subject of the employee concern. Also, Nuclear Safety Review Staff
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE : PAGE 6 OF 28 Quality Assurance Records (NSRS) Investigation Report 1-86-241-SQN was assigned to Employee Concern SQM-86-009-X04. However, a NSRS Report was never issued.
2.4 Summary of Corrective Actions 2.4.1 Issue - Controlled documents contain conflicting, or obsolete data or both.
Corrective actions taken to date include:
- a. Procedural guidance in Sequoyah Engineering Project (SEQP)
Project Manual dated September 1985 provides tighter control over design activities. Training of newly arriving clerical personnel has been given in procedural requirements for drawing control and supervision has been increased for the drawing issue process.
- b. Wiring Diagram 45N1749-30 has been revised to reflect the correct data and the drawing log corrected to reflect the proper revision. A Drawing Issue Checklist has also been added to Procedure SQEP-AI-08.
2.4.2 Issue - Work which had been performed had not been appropriately documented. (Equipment Qualification Program)
The Equipment Qualification (EQ) Project was formed with the responsibility for development and implementation of an EQ Program. Work is ongoing by the proj ect to resolve the equipment qualification problems. SQN has committed to demonstrate qualification prior to restart of the plant.
2.4.3 Issue - Poor material control. Traceability of requirements and materials is inadequate and paperwork for quality records is poor.
Corrective actions taken to date include:
Audits, increased SQN Plant QA Staff surveillance, TVA Management attention, and personnel awareness over the entire material control area which appears to be adequate.
2.4.4 Issue - The retrieval of QA records is inadequate and records are not identifiable.
Corrective actions taken to date include:
- a. Established a work force to index and microfilm construction records, vendor documentation, drawings and
. 'e s TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 7 0F 28 Quality Assurance Records manuals for SQNP Units 1 and 2.
- b. Developing new and revised procedures and instructions to define organizational responsibilities and interface requirements with other departments. These procedures will also include the methods of maintaining, storing, and controlling vendor QA records.
The above activities are currently ongoing and the schedule for completion of these activities is December 1988.
2.4.5 Issue - Welder certification records were altered, j Corrective actions taken to date include:
j Corrective Action Report (CAR) CAR-SQN 85-09-014 was written and dispositioned as - "all SQN active welders' files to be reviewed and welders re-qualified to current requirements."
This CAR has been closed and all corrective actions have been verified as being complete.
2.4.6 Issue - Maintenance Requests (MRs) which specified the addition of grease for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications and traceability was falsified on the MRs.
Corrective actions taken to date include:
i All Sequoyah Unit 2 Limitorque valve actuators have been inspected and verified that they have been properly greased.
2.4.7 Issue - Quality Assurance (QA) documents were lost by the *;
vault and regenerated by the responsible unit.
i No corrective actions required.
- 3.0 LIST OF EVALUATORS W. M. Akeley D. G. Barlow l J. J. DeAngelis
- - J. E. Mann 4.0 EVALUATION PROCESS l
e .
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN
> REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 8 0F 28 Quality Assurance Records 4.1 General Method of Evaluation The evaluation process consisted of researching the Employee Concern files, Quality Technology Corporation (QTC) files, and Nuclear Safety Review Staff (NSRS) files to determine if additional information was available to assist in the investigation of issues associated with this element.
Reviews were conducted of regulatory requirements and industry standards together with upper tier requirements, documents such as the TVA QA Topical Report and the Nuclear Quality Assurance Manual, along with lower tier implementing documents such as procedures and instructions to determine requirements, commitments, and responsibilities. Documentation in the form of quality audit reports, survey checklists, inspection reports, Field Change Requests (FCRs),
Significant Condition Reports (SCRs), Nonconformance Reports (NCRs),
Discrepancy Reports (DRs), Maintenance Requests (MRs), work plans, microfilm records of inspections / tests and computer status reports were also reviewed. The above documentation together with 1.ersonnel discussions provided the basis for the conclusions reached.
4.2 Specifics of Evaluation This section describes the specific methodology used relating to the following issues:
4.2.1 Issue - Controlled documents contain conflicting, or obsolete data or both.
The Employee Concern files were researched to determine if Quality Technology Company (QTC) and/or the Nuclear Safety Review Staff (NSRS) had investigated and reported on the issue. The following NSRS reports were evaluated by the '
Quality Assurance Category Evaluation Group (QACEG) to determine the adequacy of the scope and the results of their investigation.
- a. NSRS Investigation Report I-86-185-SQN for Employee Concerns SQM-86-002-005 and -006.
- b. NSRS Investigation Report 1-86-180-SQN for Employee '
Concern SQM-86-003-002.
There were no QTC reports available.
The QA Topical Report TVA-TR75-1A Revision 8, and the Nuclear Quality Assurance Manual (NQAM) Part III, were reviewed together with site practices, procedures, and policier to determine the requirements and commitments during the time
~. .- - . _ . _ . _ _ __ .- - . - . . . -
f
- TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE : PAGE 9 0F 28 Quality Assurance Records frame the concerns were reported.
A review was made of the Wiring Diagram, Field Change Requests (FCRs), Significant Condition Reports (SCRs), and Engineering Change Notices (ECNs) which document specific data relating to the concerns of record.
Discussions were held with personnel in the Document Control Unit (DCU) to develop the historical background and current events pertaining to the issue.
4.2.2 Issue - Work which had been performed had not been appropriately documented. (Environmental Qualification of Equipment)
The Employee Concern files were researched to determine if QTC and/or NSRS had investigated and reported on the issue. NSRS Investigation Report I-86-270-SQN was assigned to Employee Concern SQM-86-011-002. However, a NSRS Report was never issued.
A review was made of Regulatory Requirement NUREG-0588,
" Interim Staff Position on Environmental Qualification of Safety-Related Equipment"; Industry Standard IEEE 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations"; Topical Report TVA-TR75-1A, Final Safety Analysis Report (FSAR) Section 3.11, Code of Federal Regulations 10CFR50.49, January 1, 1985 Edition,
" Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants"; and the Nuclear Quality Assurance Manual (NQAM), Part II, to determine the requirements and commitments during the time frame the concerns were reported. Environmental Qualification Documentation packages including test results were also reviewed to form a basis for the conclusions reached.
Discussions were held with various site personnel to develop the historical background and other information pertaining to the subject issues.
4.2.3 Issue - Poor material control. Traceability of requirements and materials is inadequate and paperwork for quality records is poor.
The Employee Concern flies provided NSRS Investigation Report I-85-987-SQN dated 3/4/86. This report was evaluated by QACEG to determine the adequacy of the scope and the results of the NSRS investigation.
(
TVA EMPLOYEE CONCERNS REPORT NUMBEkt SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 10 0F 28 Quality Assurance Records
)
Regulatory Guides 1.33, 1.38, and 1.123, the Topical Report TVA-TR75-1A Section 17, the Final Safety Analysis Report (FSAR), the Nuclear Quality A saurance Manual (NQAM) Parts II and III were reviewed togeth 2r with Site Instructions AI-7, AI-11, AI-12, and AI-36, Stradard Practice SQA45, seven (7) survey check 11ats, seven (7) Audit Reports, and two (2) additional NSRS Reports to determine the commitments, requirements and audit results during the time frame the issue was reported.
SQN Element Report MC-40703, Revision 0, dated 9/26/86 issued by the TVA Employee Concern Special Program Group was reviewed for additional information relating to the issue.
4.2.4 Issue - The retrieval of QA records is inadequate and records are not identifiable.
The Employee Concern flies and the Confidential Sensitive files were researched to determine if they contained ,
I additional information regarding this issue. The files provided the followingt
- a. NSRS Investigation I-86-126-SQN was assigned to Employee Concern SQM-86-002-001. However, a NSRS Report was never issued.
- b. NSRS Investigation Report I-86-129-SQN was issued March 3, 1986 for Employee Concerns SQP-86-002-001 and WBP-86-009-001.
I
) Note Part of the issue included in Employee Concern SQP-86-002-001 references NSRS Reports 1-83-13-NPS and R-85-07-NPS. These NSRS Reports were used to
- identify the specific issue (s) of the concern only, and for this reason, the reports are not attached to this Element Report.
NSRS Report 1-86-129-SQN vss evaluated by QACEG to determine the adequacy of the scope and the results of the NSRS investigation.
The QA Topical Report TVA-TR75-1A, the NQAM, and site
- practices, procedures, an1 policies were reviewed to determine i the compliance criteria during the time frame the concerns I were reported.
The QA Auditing Branch files in Chattanooga were reviewed to i determine deficiencies identified by audits relating to the ;
issue.
I i
o .
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBERt REPORT TYPE Element Report 5 PAGE 11 0F 28 TITLE:
Quality Assurance Records
! A review was also conducted of the various forms of nonconforming conditions which were documented to determine the types of deficiencies that relate to the issue.
Discussions were held with various site personnel in the Records Management and QA Vault areas to develop historical background and other additional information pertaining to the subject issue.
4.2.5 Issue - Walder certification records were altered.
The Employee Concern files provided two Employee Response Team (ERT) Reports by Quality Technology Company (QTC) dealing with
' this subject (ERT Reports IN-85-612-X07 dated 10/24/85 and XX-85-088-X04 dated 3/4/86). Although the ERT report dated 10/24/85 was evaluated for WBN, the QACEG has determined that this issue is generically applicable to SQN and the results of the investigation at Sequoyah are included in this report.
! Also, NSRS Investigation Report I-86-120-SQN was assigned to Employee Concern XX-85-088-X04. However, a NSRS Report was j
never issued.
I Site QA Procedure QAP 17.2 and Administrative Instruction AI-7 were reviewed to determine the compilance requirements during the time frame the concerns were reported. Also reviewed were six Survey Checklists, three Corrective Action Reports (CARS),
and six Discrepancy Reports (DRs) dealing with welder qualifications.
4 A review was made of the welder certification documentation which is on microf tim and currently stored in the permanent j
i record retention system and hard copies of Nuclear Power j Welder Certification documentation which is stored in the Solar Building.
Discussions were held with various site Records Management personnel to develop hlstorical background and other additional information pertaining to the subject issue.
Issue - Maintenance Requests (MRs) which specified the 1
4.2.6
! addition of grease for Limitorque valve actuators were signed 1
off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA appilcations
]
and traceablitty was f alsified on the MR.
j Research of the Employee Concern files and NSRS files was
! conducted to determine if additional information was
! avallable. One NSRS Report was issued in February 1986 which l addressed this issue. 1 l
l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 12 0F 28 Quality Assurance Records A review was performed of the ECTG Operations CEG Element Report (30840-SQN dated 9/12/86) for additional information since their investigation dealt with part of this issue.
A review was also performed of the NQAM Part II, Maintenance Instruction MI-10.46 and Standard Practice SQM2 to determine the commitments and requirements surrounding the issue.
Discussions were also held with site QC inspection personnel who performed the Limitorque valve research.
4.2.7 Issue - Quality Assurance (QA) documents were lost by the vault and regenerated by the responsible unit.
A review was performed of the Employee Concern and the Confidential Files to determine if QTC or NSRS had investigated the issue and if the files could provide additional information regarding this concern. It was found that QTC had evaluated this concern and issued Report No.
IN-85-091-001 dated 9/16/85.
The NQAM, site practices, and procedures were reviewed to determine the compliance criteria during the time frame the issue was reported.
i The Nonconformance Report (NCR) Log was reviewed for any information identifying lost QA documents or records.
Discussions were held with va..ous site QA and Document Control Unit (DCU) personnel to develop information relating to lost QA documents.
5.0 FINDINGS The following contains both a background discussion and a conclusion for each issue as identified in Section 1.2.
5.1 Issue - Controlled documents contain conflicting or obsolete data or both.
5.1.1 Discussion Two reports (1-86-185-SQN and 1-86-180-SQN) were issued by NSRS of which the above issue is a part. Our investigation and this report will discuss each NSRS Report separately.
5.1.1.1 NSRS Report I-86-185-SQN NSRS Report 1-86-185-SQN dated March 1986 described the investigation of Vendor Drawing Control where five
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 13 0F 28 Quality Assurance Records Employee Concerns were investigated by NSRS of which this issue was a part.
The NSRS Report included a clarification of the issue as provided to NSRS by QTC which said that SQN design drawings (mylars) were issued by the Office of Engineering Reprographics, Knoxville.
Our investigation there fore , dealt with interviews of drawing control personnel at SQN and centered around the process for requesting duplicates and determining how conflicting data could exist.
If an original vendor drawing cannot be located and the sign-out log does not indicate that the drawing was removed from the file, the Drawing Control Unit will request a replacement drawing from the Technical Information Center (TIC) at Knoxville. The replacement drawings are referred to as "washoffs".
This "washoff" is issued as a "new original" and has the potential for placing in circulation two original drawings which could contain conflicting data. This happens if the first issued drawing should reappear and is not properly noted in the drawing file.
The replacement of duplicate or " wash-o f f" drawings appeared to primarily a f fect those vendor drawings received at SQN prior to 1976.
Discussions with Drawing Control personnel confirmed that these site drawings were discarded and that it was possible for two original vendor drawings to be in circulation with conflicting data for the reason noted above although this investigation did not find where this happened. To avoid this, the Drawing Control personnel are now required by procedure to place a notation in the drawing check-out file that a "new original" has been requested. Subsequently, if one vendor drawing reappears at Drawing Control, the clerk is immediately alerted to the existence of the duplicate drawing. The clerk, with the assistance of engineering, will determine the correct drawing to retain, then eliminate the obsolete drawing from the records system. To verify the control of this particular drawing activity, QACEG confirmed the l implementation by reviewing the vendor drawing checkout files and found five containing the notation "new originals" on the replacement drawings.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE Element Report 5 TITLE: PACE 14 0F 28 Quality Assurance Records Controls are now in place to avoid lost and duplicate drawings in existence with incorrect data.
5.1.1.2 NSRS Report I-86-180-SQN NSRS Report I-86-180-SQN dated February 1986 described the investigation of Sequoyah Drawing Control. Six Employee Concerns were investigated of which the issue noted above and investigated by QACEG was a part.
The NSRS Report also included a clarification of the issue which was provided to NSRS by QTC, which said that drawing 45N1749-30 (R8) was issued twice on separate mylars. The Mylar drawings were issued on November 29, 1985 and November 30, 1985, respectively.
The investigation in the Drawing Control area included a review of the SQN mylar drawing number 45N1749-30, Revision 8, Engineering Change Notice (ECN) L6202 and L6544, Field Change Notice (FCN) 3585 and 3966, and Significant Condition Report (SCR) SQN SQP-8601, Revision 0.
This review confirmed the NSRS report that mylar drawing number 45N1749-30 was issued twice as revision
- 8. The first issue was for ECN L6202/FCR3583 dated 11/29/85, and the second issue was for ECN L6544/FCR 3966 dated 11/30/85. Failure to adequately log-out the first release of Revision 8 mylar on November 29, 1985 created the potential for obsolete or conflicting data when one drawing is updated and not the other.
As a result of the NSRS investigation this Condition Adverse to Quality (CAQ) was reported on SCR No. SQN SQP-8601, Revision 0, dated 1/11/86. QACEG verified the corrections as having been made and checked the current log books of issue tickets and could not find
! where other duplications have occurred.
Our discussions with Document Control personnel indicated that the condition happened because of inexperience of new clerical personnel in the changeover from the Engineering Project Office in Knoxville to the site office and lack of attention by the new personnel to the Engineering Change Notice, Field Change Request, and drawing issue process.
Prior to September 1986 Drawing Issue tickets which are used to request copies of drawings, were considered a " log" and were only kept for 6 months.
These tickets plus the accompanying Drawing Issue
TVA EMPLOYEE CONCERNS REPORT NUMBERS SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 15 0F 28 Quality Assurance Records Checklist are now being kept indefinitely by DCU.
Item 5 of the Drawing Issue Checklist instructs the DCU personnel to verify that the drawing and appropriate revision are clear for issue by using the Drawing Management System computer program. The data on the screen will alert the operator of any inconsistencies.
Corrective actions have been initiated by TVA by way of additional training from Drawing Management System personnel in Knoxville and the addition of a Drawing Issue Checklist. Additional supervision has also been assigned to the DCC to control the issuance of drawing.
5.1.2 conclusion The issue of controlled documents containing conflicting or obsolete data or both is considered valid. The QACEG investigation and evidence produced verifies the results obtained by NSRS. The NSRS Reports are considered factual. There did exist the potential for two " original" vendor drawings to exist. However, there now are adequate controls in effect to prevent this from occuring.
This investigation also found evidence to support the conclusion in that the wiring diagram was issued twice
, with the same revision number. This appears to be an isolated case having happened when the individual who furnished the first copy of the wiring diagram on November 29 failed to enter the drawing issue ticket in the log. Further reviews of drawings and issue ticket logs could not find where this condition happened again.
Procedures governing the issuance of drawings are adequate l and additional training by Drawing Management Systems
! personnel was provided to correct this condition.
5.2 Issue -
Failure to appropriately document work which had been performed.
5.2.1 Discussion The issue raised was that "Sequoyah was allegedly shut down in August 1985 due to the failure of a group to appropriately j document work which had been performed". Records indicate that SQN was shut down in August 1985 because TVA determined that they would not be in full compliance with regulatory
- requirements for equipment qualification, 10CFR50.49, by
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROCRAM 80504-SQN REVISION NUMBER REPORT TYPE Element Report 5 TITLE t PACE 16 0F 28 Quality Assurance Records November 30, 1985. On that basis, it was concluded that the concerned employee was referring to the Environmental Qualification (EQ) documentation. A review was made of the revised Sequoyah Nuclear Performance Plan dated July 1986 to determine the background associated with the plant shut-down.
A review was also performed of the regulatory requirements in 10CFR50.49 to establish those requirements which TVA has committed to comply with. The Nuclear Performance Plan,Section III, Paragraph 1.0 stated the following:
"The environmental qualification of electric equipment required to ensure reactor coolant pressure boundary integrity, shut down the reactor and maintain it in a safe shut-down condition, and prevent or mitigate the consequences of accidents that could result in o f f-s ite exposures comparable to the 10CFR100 guidelines is required by 10CFR50.49. It is further required that the evaluation of environmental qualification be documented and maintained in auditable files. The date required by NRC for full compliance with 10CFR50.49 was November 30, 1985.
TVA conducted a management review of the environmental qualification programs of SQN, BFN, and WBN in July and August 1985. This review indicated that much of the qualification documentation was not fully auditable and, in some cases, the documentation available did not demonstrate full qualification.
The cause for the failure to comply in a timely fashion with 10CFR50.49 requirements was a lack of management attention to the environmental qualfication program.
SQN was shutdown voluntarlly at the direction of the Manager of Nuclear Power with the concurrence of the TVA Board of Directors in August 1985.
Subsequent to the voluntary shutdown of Sequoyah, the Equipment Qualification Project (EQP) was formed with the responsibility for development and implementation of an EQ program. Responsibility for engineering activities associated with environmental qualification is presently assigned to Division of Nuclear Engineering (DNE) and detailed responsibilities, scope, organization, specific project procedures, and project training program are defined in the project manuals for the EQP and the Sequoyah Engineering Project (SQEP)."
Standard Practice SQA173, "Sequoyah Nuclear Plant 10CFR50.49
l TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER: ,
REPORT TYPE Element Report 5 l l
TITLE: PACE 17 0F 28 i
Quality Assurance Records l
I Environmental Qualification Program," describes the overall program for achieving full compliance with 10CFR50.49. l i
l 5.2.2 conclusion l l
I The issue is substantiated. However, adequate attention is being paid by TVA to identify and correct the deficiencies.
TVA has tentatively scheduled completion of the necessary ,
tasks to demonstrate equipment qualification by the end of !
April, 1987.
5.3 Issue - Material control is poor. Traceability of requirements and materials is inadequate; paperwork for quality records is poor.
5.3.1 Discussion The Employee Concerns flies contained a comprehensive NSRS report on the material control activities at SQN. The NSRS report addressed the points raised in the subject issue. This !
investigation dealt with verifying the validity of the .
I findings noted in NSRS Report I-85-987-SQN dated February 1986. f The QACEG considered the materiaf wontrol issue from a progransnatic point. Material Control CEG is ade're s s ing the hardware issues in SQN report MC-40703-SQN, Revision 1, 5 All the documents reviewed by both NSRS and QACEG were generated during the operational pTase as construction was r essentially complete at the time the concern was generated. [
i The requirements for material control, traceability and quality records at SQN are based upon Appendix B to 10CTR50, "
Regulatory Guides 1.33, 1.38, 1.123, and 1.88, the TVA Topical Report and NQAM, Parts 11 and III, together with the 6 Administrative Instructions AI-7, A1-11, AI-12 and AI-36 and Standard Practice (SQA45). The NSRS findings were reviewed against the above requirement documents.
A selection was taken of all the documents used in the NSRS investigation and a review was performed by QACEG of their content to independently verify the NSRS results. The Quality Assurance Category Group (QACEG) reviewed seven Surveillance Reports, seven audit reports, two Corrective Action Reports (CARS), and nine Deficiency Reports (DRs). These documents dealt exclusively with material control activities. The reviews produced evidence of a significant number of i deficiencies (conditions adverse to quality) dealing with !
inadequate instructions being available and failure of j i
1
TVA EMPLOYEE CONCERNS REPORT NUMBERS :
SPECIAL PROGRAM 80504-SQN ,
REPORT TYPE REVISION NUMBER:
i Element Report 5 I
TITLE: PAGE 18 0F 28 Qua11ty Assurance Records personnel to follow those instructions which were in place.
During the period 1981 through 1985 (when the above noted Conditions Adverse to Quality were reported), NSRS compiled data on 15 instances of inadequate instructions to maintain adequate material control. Likewise NSRS data revealed 134 i instances attributable to failure to follow the instructions which were in place. I j The NSRS data dealing with traceability of requirements indicated 49 conditions where there was inadequate traceability of requirements (those noted on procurement documents) to the material received. It was also found that '
there were 97 conditions noted in the reports relating to l improper traceability of paperwork and materials. That is, maintaining traceability of documentation and material through the entire cycle of receipt, installation and operations.
I In researching the allegation of poor quality records the NSRS data indicated 99 conditions being reported relating to inadequate documentary evidence of the quality of the material.
In addition to verifying the validity of the NSRS findings, the QACEO investigation performed an evaluation of the areas covered by the Quality Assurance Audit Branch audits and site
> surveys (surveillances) and found that the depth and coverage ;
was adequate to form an objective evaluation of the conditions.
! 5.3.2 conclusion l By researching and reviewing the sample numbers of reports noted above and our independent verification the QACEO has determined, in agreement wlLh the NSRS reports, that the issue i raised by the concerned individual is valid. However, there l
appears to be a decline in incidents of poor material control !
i and related quality records. This was concluded because of l the reduced number of findings reported in recent audits and i surviellances even though the QACEO investigation found that the SQN QA Surveillance Staff has increased their effort of survalliance over the material control activities.
TVA has directed considerable attention in the years 1985 and 1986 to the improvement in the control of materials at SQN.
This has been verified by reviewing audits and surveillance i reports of the Quality Assurance Surveillance Section. There
< appears to be a downward trend in the number of conditions adverse to quality which are being found. Audits, increased surveillance by SQN plant QA Staf f, TVA Management attention, l
j . .
TVA EMPLOYEE CONCERNS REPORT NUMBERS SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE t PAGE 19 0F 28 Quality Assurance Records and personnel awareness seem to have had an effect on reducing incidences of improper control of material and related documentation. Corrective actions as a result of Element Report 40703 will also reduce the incidences of improper material control.
! 5.4 Issue - SQN records retrievability is inadequate.
The concerned employee alleged that the retrievablity of SQN QA records generated during both the construction and the operational phases is inadequate. The findings and conclusions contained herein are discussed separately for the retrievability of quality related construction and operation records.
5.4.1 Retrievab(11ty of Quality Related Contruction Records.
5.4.1.1 Background j The Records Retrievability Indexing (RRI) system for QA construction records was addressed in NSRS Investigation Report 1-86-129-SQN and the issue was reported to be substantiated. The NSRS Report identified that SQN QA construction records including vendor drawings and manuals have not been completely i entered into the records retrieval system. Since the I current RRI for QA construction records and the vendor drawings and manuals are less than 50 percent ;
! implemented, the records retrievability system was considered to be unreliable and incomplete.
1
- 5.4.1.2 Discussion i The overall results of the QACEG investigation ludicated that QA construction records were i retrievable; however, the method was considered slow and unpredicable. TVA management recognized this condition in early 1983 and since has been working to provide a complete index and document location on microfilm for each QA construction record for SQN Units 1 and 2.
During the same period, the Vendor Drawing and Manual control Program was considered by TVA to be a potential problem. TVA survalliance groups had identified the following conditions relating to vendor drawings and manualst 1
- a. Vendor drawings and manuals were unorganized and difficult to retrieve.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 20 0F 28 Quality Assurance Records
- b. Vendor drawings and manuals were not controlled relative to the "as designed" specifications.
On February 22, 1984, the Quality Engineering Branch (QEB) initiated a Nonconformance Report (NCR) No.
GENQEB8401 describing a deficient condition involving inadequate indexing and ineffective retrievalibity of vendor QA records. The corrective action measures for the CAR included the revising of Interdivisional Procedures ID-QAP 17.1, " Transfer of Quality Assurance Records", ID-QAP 17.2. " Quality Assurance Records for Design and Construction", and QEB-EP 24.37, " Product Compliance Data and Quality Engineering Records Indexing and Preparation". Verifying and final completion of this CAR was performed on August 28, 1984.
In early 1985, the Office of Nuclear Power (ONP) conducted a review of the RRI for QA construction records and determined several areas to be deficient.
A task force was established to develop recommendations, including the revising of instructions and procedures for each quality related construction QA record. This revised retrieval system for QA construction records under new and revised guidelines has not been fully implemented by SQN at this time. TVA Record lianagement personnel are presently in the process of identifying, indexing, and providing film locators on each construction QA record.
The purpose of the investigation by QACEG of the RRI system for QA construction records was first to evaluate the present retrievability system and second, to determine the present status and the scheduled completion dates for the implementation of SQN construction QA records.
The QACEG investigation of the present RRI for QA construction records involved the selection of 15 Cable Tray Inspection Reports for SQN Unit 1 and four llanger/ Support Inspection Reports for SQN Unit 2.
These completed construction records were transmitted by Quality Control to the Master Flies for entry into the RRI. The present retrieval method for construction records is controlled by the system number located on the microfilm reel. The specific record must be located by scanning each frame until the desired document is located. This method involves
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PACE 21 0F 28 Quality Assurance Records the possiblo scanning of approximately 4,000 frames per reel to locate the desired document. The results of the investigation revealed that 18 of the 19 inspection reports were retrievable. One Cable Tray Inspection Report could not be located. The retrieval process for these records was accomplished by one individual in approximately six hours.
TVA's highest tier QA Program Manual, the Topical Report TVA-TR75-1A, Revision 8, Section 17 requires that a records index and retrieval system be established to assure that Quality Assurance Records are identifiable and retrievable. Although the Construction QA Records , including Vendor QA Records, were available, the documents were not indexed to a degree of reliable retrievability.
The current RRI for QA Construction Records when completed will be capable of retrieving documents more efficiently by means of identifying documents by reel and frame number. This method will provide direct access to a specific document on each reel. During the discussion with the Supervisor of the SQN Construction Records Project, it was determined that the Construction QA Records portion of the RR1 was approximately 25-30 percent complete and final completion scheduled for December of 1988.
The SQN QA Staff initiated a Corrective Action Report (CAR) SQ CAR-86-01-004 dated January 30, 1986 addressing a condition contrary to the requirements of Administrative Instruction, AI-23 and the Nuclear Quality Assurance Manual (NQAM) Part V. This CAR noted numerous vendor drawings and manuals contained in the SQN Environmental Qualification (EQ) Binders that were inconsistent with the information identified in the plant controlled Drawing Management System (DMS). The disposition for the CAR has not been resolved to date.
The vendor drawings and manuals are being verified for technical adequacy by the Division of Nuclear Engineering (DNE) prior to forwarding to the Document Control Center for entry in the DMS.
SQN is upgrading the Vendor Drawing and Manual Control Program by developing new and revised procedural requirments in the Nuclear Quality Assurance Manual (NQAM) and lower-tier documents i.e., Administrative
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 22 0F 28 Quality Assurance Records -
Instructions AI-23 and AI-25, and Sequoyah Engineering Procedure, SQEP-39. These procedures are presently in the review cycle and a scheduled issue date has not been established.
In a discussion with cognizant DNE personnel, it was indicated that the Vendor Drawing and Manual Control Program is approximately 40 percent complete. The target date for completion is January of 1988.
5.4.1.3 Conclusion The issue of the document retrieval of QA records being inadequate and not identifiable in relation to vendor and construction QA records is a valid issue.
Although our investigation indicated a high percentage of retrieveable construction QA records, one must consider the delay and effort involved to retrieve
- l. these documents. However, this condition is not considered a violation of present requirements.
The overall records retrieval system for QA Contruction Records including vendor drawings and manuals is less than 40 percent complete; there fore ,
prompt, reliable, and adequate retrievability is not feasible at this time. Difficulty in retrieving QA records could potentially hinder the required evaluation of a safety-related part or component. In addition, the numerous vendor drawings and manuals addressed in CAR No. SQ-CAR-86-01-004 need to be corrected and up-dated to re flect the revision level of the "as designed" equipment and information included in the DMS. The CAR is the current document used by SQN as the tracking means for the above deficient condition.
Although corrective action is warranted pertaining to the issue of records retrievability of vendor drawings and manuals, a Corrective Action Tracking Document (CATD) has not been issued as part of this report.
CATD No. 80503-SQN-07 addressing a similar issue was i.
included with QACEG Element Report No. 80$03-SQN.
5.4.2 Retrieveability of Quality Related Operation Records.
l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROCRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLEt PAGE 23 0F 28 Quality Assurance Records 5.4.2.1 Discussion This issue was investigated by QACEG by selecting nine types of operating QA records; such as, Engineering Change Notices (ECN), Workplans (WP), Corrective Action Reports (CAR), Inspection Reports, Discrepancy Reports (DR), Maintenance Requests, NRC Inspection Reports, inplant Surveys, and Inservice Inspections, for retrievability from the RRI at SQN. The nine types of QA records consisted of a total of 221 documents to be retrieved. Of the 221 documents only three were not retrievable either on microfilm from the Document Control Center (DCC) or hard copy from the Permanent Storage Vault. The three documents were further researched and it was found that one was cancelled and the other two need to be reviewed by QA prior to forwarding to the Permanent Record Storage Vault. The selected Operating QA records were satisfactorily retrieved from the RRI and from the Permanent Storage Vault.
In addition, QACEG reviewed five SQN QA audit reports relative to the records retrievability in the Document Control and QA Records areas for 1985 and 1986. This review concluded that no major breakdown in the RRI was reported.
5.4.2.2 Conclusion ;
Based on the above evidence, the issue of inadequate records retrievability for operating QA records is not a valid issue.
The QACEG evaluation of this issue has determined that the RRI was effective for the retritval of operating QA documents. The RRI is most effective when a unique identifier number, specific type document or system number is used to retrieve d(stred records.
5.5 Issue - Welder certification records were altered.
5.5.1 Discussion QACEG reviewed Welding Project's (WP) Specific Employee Concerne Report dated November 6, 1986 addressing Employee Concern XX-85-088-003. The issue of alteratio1s to welder qualfication records as noted in WP report was not substantiated in relation to welder cer ti f tet.tlons being technically satisfactory. This issue was investigated by
TVA EMPLOYEE CONCERNS REPORT NUMBER SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 24 0F 28 Quality Assurance Records QACEG to determine if the welder certifications were actually altered. The investigation performed by QACEG did substantiate the issue that welder certifications were altered contrary to TVA's established requirements. This issue is discussed below.
A review was made of the QC Plant Log which documented all Special Process Surveys conducted by TVA since 1982. A sample of six surveys performed from July 1983 thru August 1985 was then selected for review to determine if the issue of " Altered Welder Certifications" had been identified as a problem.
These surveys encompassed welder qualifications and welder continuity checks to determine if the program was being controlled in accordance with SQM 17 and Specification DPM-N73H2. Each of these surveys identified various types of problems resulting in many DRs being issued. Additionally, in some instances CARS were initiated which required root cause analysis, resolution of condition adverse to quality, remedial corrective actions, and corrective actions necessary to prevent recurrence. The latest survey reviewed, dated August 26-September 5, 1985 identified numerous welder certification record discrepancies. These problems included the followings
- a. Inappropriate changes were made by engineers or clerks to performance qualification records.
- b. Welder Continuity Records contained conflicting entries.
- c. Weld Rod Issue Cards did not provide adequate information to verify that welding had actually been performed.
As a result of the various problems identified, CAR SQN-CAR-85-09-014 was initiated which required immediate corrective action. All SQN active welders' flies were reviewed to identify and correct any discrepancies related to welder continuity and welder qualification. This review did not identify any welders who were working in violation of the applicable code. In several cases, however, welders were directed to re-establish their certifications to ensure that all doubt had been removed concerning their qualifications.
The issue of welder certifications being altered by the use of correction fluids was reviewed for 75 welders from the Division of Nuclear Power and approximately 200 records from Construction revealed that contrary to the NQAM Part III, Section 4.1 and AI-7, para. 4.2.6, corrections were made to some Welding Performance Qualification records by use of correction fluid.
TVA EMPLOYEE CONCERNS REPORT NUMBERt SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE Element Report 5 TITLE: PAGE 25 0F 28 Quality Assurance' Records i
Based upon copies of welding records obtained from several microfilm' rolls there was evidence that some of the welding records did 'have corrections made to relevant information which could be significant to the quality information applicable to the welder certifications. Corrections were made to Guided Bend Test results, entries on welder qualification lists, position and specimen numbers, electrode or filler metal type and size, backing ring or strip and diameter and/or thickness. With regard to the welding records of the Division of Nuclear Power, the certification records reviewed were the actual hard copies located both in the active and inactive files. There was evidence of correction fluid being used on five of the seventy-five certification i records reviewed in the active Nuclear Power file. These corrections were made to entries in the Qualification Test blocks, date qualified / locations blocks, welder continuity records and to the actual Test Results block for Guided Bend tests. These corrections could be significant to the quality information applicable to the welder certifications.
These conditions violate the requirements of NQAM Part III, Section 4.1, which states that in the preparation of a QA record changes / corrections should be made by marking a single
' line through the item to be changed making the new entry and entering the dated initials of the person making the change / correction. SQNP AI-7, Paragraph 4.2.6 requirements
- are similar to the higher-tier document.
5.5.2 Conclusion Based on the above evidence, the issue of welder certifications being altered is vslid. The documented evidence of welder certifications being altered is a violation of the requirements of TVA procedurea and practices.
The
{ '
Welder Performance Qualification Records naintained by both Construction and Nuclear Power are defined as QA records, therefore, these records are within the scope of the NQAM and SQN site procedures.
5.6 Issue - Maintenance Requests (MRs) for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications and traceability was falsified on the MRs.
i 5.6.1 Discussion i
4 The investigation by QACEG concentrated on the specific s'
7
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 26 0F 28 Quality Assurance Records employee concern and the issue of the Limitornse valve actuators and whether or not Maintenance Request (hrs) which require the addition of grease to the valve actuators were signed off by a general foreman as not necessary; whether the same MRs which the general foreman considered unimportant were signed-off even though no work was performed; and whether or not non-QA material was installed in QA applications and whether or not traceability was falsified on the MR. (QACEG assumed this to mean the application of grease since the CI incorporated his allegation on the same concern with the Limitorque valve issue.)
The investigation of this issue was part of a larger investigation done by the Operations Concern Group and reported in their Element Report 30804 SQN. A discussion with the SQN QC inspection personnel by QACEG provided details of an investigation and research by them into 102 Maintenance Request packages for all the Unit 2 Limitorque valves. That investigation by SQN QC was done in June of 1986 to verify the application of correct grease in the valve actuators. The SQN QC investigation and the QACEG investigation verified that all Unit 2 Limitorque valves were inspected and it was found that the actuators have been properly greased in accordance with the requirements of Maintenance Instruction MI-10.46. This MI stipulates a QC hold point for the verification of lubricant.
5.6.2 Conclusion This issue is unsubstantiated since there were no instances observed in the Maintenance Requests reviewed where the general foreman cancelled or deleted a requirement. Research of the MR packages and cur ccaversation with the SQN QC inspection personnel indicated that all Unit 2 Limitorque valve actuators have been inspected and verified to have been greased with the proper lubricant.
5.7 Issue - Quality documentation was lost by the vault and regenerated by the responsible unit.
5.7.1 Discussion This issue was investigated and reported by QTC on September 16, 1985 specifically for a condition at Watts Bar Nuclear Plant (WBN).
The QACEG investigation at SQN included the review of the similar condition and documents which were reported by QTC.
QACEG reviewed the Electrical Inspection Log for 1985 and
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 5
Element Report PAGE 27 0F 28 TITLE:
Quality Assurance Records 1986, five SQN QA audit reports, and approximately 400 NCRs to determine if SQN documented conditions of lost QA records.
The results of this investigation revealed that the data reviewed did not identify conditions of lost documentation.
QA personnel indicated that SQN did not report the condition of lost documents. The SQN permanent vault personnel would request copies from the responsible unit to be included in the RRI.
5.7.2 Conclusion The issue of lost documents at the vault could not be substantiated at SQN. The investigation revealed this issue to be specific to WBN only.
5.9 Corrective Action The issue of the controlled documents containing conflicting or obsolete data as described in Section 5.1.1.2 is valid. However, this condition appears to be an isolated case as noted in Section 5.1.2
" Conclusions". The duplication has been corrected and a review of the issue ticket logs could not provide further evidence of this happening again. A Drawing Issue Checklist has been added to the procedure and additional training has been provided by Drawing Management Systems personnel. There will be no other corrective action necessary.
The issue of failure to appropriately document work which had been performed as described in Section 5.2.2 is valid. TVA has assigned the responsibility for engineering activities associated with the Environmental Qualification Program to DNE. These detailed responsibilities and overall program requirements are described in Standard Practice SQA 173. The results of the DNE's evaluation will determine if there is any potential impact on safety.
The issue of material control is poor as described in Section 5.3.2 is valid. However, this condition has improved through the individual efforts of QA Audits , increased surveillance by SQN Plant QA Staff, TVA management attention, personnel awareness, and corrective actions as a result of Material Control Element Report MC-40703-SQN. The material control report identified several deficiencies relating to 5 the control of material traceability. These deficiencies will be addressed to SQN line management in a future revision to report MC-40703-SQN. The corrective action will be tracked by the Material Control Employee Concern Group.
The issue of inadequate document retrieval of vendor and construction QA records as described in Section 5.4.1.3 is valid. SQN QA issued CAR 86-01-004 addressing the inability to retrieve the latest vendor drawings and manuals from DMS. The Vendor Drawing and Manual Control
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN i REPORT TYPE REVISION NUMBER:
Element Report 5 TITLE: PAGE 28 0F 28 Quality Assurance Records Program is approximately 40 percent complete. In addition, CATD 80503-SQN-05 and -07 addressing a similar issue will be used to track this deficient condition. The difficulty in retrieving QA documents could potentially hinder the required evaluation of a safety-related part or component. When the Vendor Drawing and Manual Control Program is completed and put in place, it will reduce the potential for this condition. The corrective action is being furnished by SQN Site Director's Office.
The issue of welder certification records being altered as described in Section 5.5.2 is valid. The corrective action identified on CAR 85-09-014 required all SQN active welders ' files to be reviewed and 4 welders re-qualified / certified to current requirements. This CAR was dispositioned and QA verified completion of corrective action on February 18, 1986.
6.0 ATTACHMENTS A. List of Employee Concern Information Subcategory 80504 B. List of References and Documents Reviewed C. NSRS Report I-86-129-SQN dated March 3, 1986 D. NSRS Report I-86-180-SQN dated March 4, 1986 E. NSRS Report I-86-185-SQN dated March 5, 1986 4
1
, , . , - , + - , , , , , - - - - - ,-- --
--e,------.a - - - , - - , , , , , - ,-,,, ,, - ~ , - - - , - - - - - - , , >
. s .
.Lbyy,:,-e.. ~~
.I. ,
[ .. ,jfl ; .
NrTACitlEllT A -
PACE 10F 3 ,.
R[fERillCE - [CPSI20J-LCPS121C lEllllESSEE val t EY Aull10RiiY l' AGE -
132 IRLQUtilCY - REQUEST Ol'l: ICE - or IlUCl[ AR PollLR Rull IlllE - 14e79:*21 OllP - ISSS - Rlill EllPL OYEE CollCERll l'ROGRAll SYSilli ([ CPS) RUll DAl0 - 01/21/El-Illi'L OYEE CollCERil Illf 0RilAIIUll DY CAILGURY/SUBCAi[ GORY CAILGURYs QA QA/QC PROGRAlls SUBCAILGORYe 80504 AS-buiti Collb!TIDils S 1 R[ PORT APPL 11 2 Salt RIIAILD SUB R Pt T 3 IlliD CL ASS lilSTORICAL CollCERil CollCI Ril flullBER CAT CAI D 10C HF BL SQ 118 REPORT ORIGill CollCERil DESCRIPilull
________________ __, _____ _ ___ _ _ _ _ _ _ _ _ __________,___ ______ _____ - =______________________________________-
til -8 5-091-00101 QA 80504 5 SQll 1 11 11 Y ll 114-85-091-001 Qlc QUAL ITY DocUl1[Ill AT I0li llAS L OSI BY VAUll AllD liit ti R 150001 2 ilA ilA SS IIA EG[IlERAILD BY lilE RisrollSIBLE U1111.
3 IIA IIA A IIA 02 QA 80514 S SQll 1 11 Y ll V .
Ill -8 5- 5 57 -0 0101 QA 80504 S IIDil I il ll Y ll 111-85-357-001 QIC RECORDS REIRIEVADIlliY IR011 QC ST AGE VAUl l I S I I '.'i 150026 2 IIA IIA flu llA lilAll AD[QUAIE.SLVERAI lilSI AllCE S I SPI Cil IC U. trill 8titi 3 llA flA A flA ) Illll RE IllE IllDI V I DUAL COUL D 1101 ODI Alli RI COR D'i lHI 02 QA 40516 S IIBil IY Y ll Y [Il HEQUESIED. SollE RECORDS IUUK SlVIRAL DAY" 10 I b5ft 2 110 llo llA 180 DCAT E AllD SollE COUL D 180i BE fUUllD Al At t . IllDI V I D
( (I 3 flA UAL DID SIATE II0llEVERs IllAI R[ CURDS llLRE PF0hAllt Y AVAILABLE, JUST !!UIREIRILVABL E j
Ill -8 5-612-XD7 01 Ill 60300 5 llBil 1 18 11 Y la 114-85-770-002 QIC llELDER CERTIFICATI0ll CARD FALSIFIED. (D[TAlts 10 350131 2 IllE SPEC 1FIC CASE Kilullit 10 4IC AllD litlillitt D IO llAI 3 til Alli CollFIDEllll AL IIV) . CollSIRUCilull ll PI . Colltl R 02 QA 80504 5 18011 1 11 il Y 11 II . CI IIAS 110 110RE Illl 0RilAI I 0ll. Rio f oll oll-UP kl 911 2 flA IIA SR llA IRED. (5918 ISSUES ADDRESSED lli RPI IIP-19-SQll RI) 3 ilA ilA C flA 03 QA 80519 5 llDil 1 Il il if Y 2 IIA lia llA SR 3 llA IIA 114 04 llE 50119 S IIBil I il il Y 18 2
3 J i ll- 8 6 - 0 01 01 Ill 60300 S Sqll 1 DECP (1) IIRS lillICll REQUIRE illE ADDI110ll UF GRI ASE 10 1 2 IlllIORQUE VALVE Or[RAIURS ARE SIGill.D BY A 6tilf RAI 3 ruR[tlAll AS "l10 GREASE IIICLSSARY" tilllli, Ill IACI . t il 02 OP 30804 5 Sqll 1 E GREASE L EVELS ARE 1011 UR llLEDS RI PL ACIllG. 12) 2 IIRS 18111Cll IllE GEllERAL I URLNAll CollSil[RS UlilllPORI All 3 T ARE SIGilED Off AS C0!!Pl[IE EV[Il ll100Gil fl0 laul:K ll 03 QA 80504 5 Sqll 1 11 11 Y ll AS PERIORilED. (3) llull-QA IIAIERI Al IS lilSIAlltu I 2 IIA flA SS IIA ll QA APPLICAII0l45, AllD IRACLA8illlY IS I AL Sillin 0
~
3 11A IIA A flA II IllE IIR.
04 QA 80519 S SQil IY Y ll Y 2 SS SS IIA SS 3 il A '
S ell- 8 6 -0 0 2- 0 0101 QA 80504 5 Sqll 1 11 11 Y ll ' Q1C IllE C0iliRot t ED DOCUllElli REIRIEVAt SYSl[Il IS IllADf 0 150254 2 IIA IIA SR llA UAIE. IllAllES/ DEI AIL S Kilullit 10 QIC, Illlllillt D f u IIA 3 IIA IIA A llA lill Alli CollFIDLllll AI IIY. ) llOCt f. AR l'UllIR COHCl kil . r 02 QA 80336 S Sqll IY Y ll Y I HAS 110 FURill[R IllI DHilA I I nfl. ll0 I UR illl R Illl 0 Hila l l jpg 2 SR SR SR Die HAY BE RELEASED. Il0 10L L oll- UP ' R14U I RI D.
d
sn.
- - ' . y- .c .s. y . ys ATTAdlRIEllt A -
PAGE' 2 OF 3 .
1[IlllESSEE VAllrY Aulil0RI1Y PAGE -
185 ,
R[l E R[ llc E - ECPS120J-[ CPS 121C kull 11110 - 14 29:5'l TRIQUfflCY - Rf.QUESI of flCE or llUct LAR PullLR RUll DAlt - 01/28/8/
UllP - I SSS - Rlill litP10YLE CollCI Ril PROGRAll SYSIEll ([ CPS) litPL OY[E CollC[Ril Illf 0RilAII0ll BY CAIEGORY/SUBCAIEGORY cal [GURY QA QA/QC PROGRAlls SUDCAILGORY 80504 AS-UUILI CORulitollS S 1 RI PORI Al'PL 11 2 SAF RilAILD SUB R Pi i 3 IlllD CLASS lil SioRIC Ai. CollCERil j
CAI D toc BF BL SQ llD R[ PORT ORIGill CollC[Rll DESCRIPiloll CollC[Rif flullBER CAT i
5Q11- 8 6 - 002- 00 501 QA 80504 ll Sqli 1 ll 11 Y ll I -8 6 -18 5-5Q11 QIC CollIROLI ED DOCullfill5 CDill Alli CollfllCilllG DAI A Fil A '
150254 2 flA !!A SS IIA IIllG 10 illE SAllE IllSI All Allull. (IIAllt S/ f t I All 5 tilu 3 IIA IIA C llA .
lill 10 QIC, Illilllitt D 10 flAllll Alli C0111 I Dilill Al llY . p 110 fuRillER IIll ORilAl1011 IIAY BE Rtli ASI p. IlUCt I AR -
Pollf R CullCERil. CI ilAS 110 (URillLR lill 01'llA l l ull . 11 0 ,.
- ?- IULLOll-UP REQUIRED.
1 SQll-86-002-00601 QA 80504 ll 5Q11 1 il 11 Y ll I-86 -18 5-S Qll Qic ll0RK IS Bell 10 PERf0 riled 10 DOClll1Ellis Colll Altllll0 00 l
150254 2 ilA flA SS llA lif L IClllin OR OBSul[II: DAlA. (llAllt'S/ lit I All S 1t1101111 3 IIA IIA C llA 10 QIC, lit 11111Et D 10 llAIlli AIll Cuill Ilit tilI Al iI f. I flu IURillLR Illl 0RilAII0ll llAY BE REL L ASI D. IluCll AR l tHI IR CollCERil. CI IIAS 180 I URillLR lill DRilAIInll. Ilu t o Llull-UP REQUIRED.
QA 80504 11 54ll 1 Il 11 Y ll I-86-180-54ll QIC DllPLICATE DOCullElllS llAVE BEIll I SSUI D 111 111 Colll t 101 SQll- 8 6 - 00 5-0 0 2 01 IllG DA1 A. (llAll[S/ DEI AIL S Kiloilll 10 QIC, Illitilli t D I 150253 2 flA flA SS IIA 3 flA IIA C llA 0 llAllll Alli CollrIDLitt l AL IIY. I lin I URilll R lill 0RilAll Oli ilAY BE REL E ASED. IlOCL LAR PUllt R CollC[Ril. CI flA
' S 110 IURill[R Illr0RilAT I0ll. 110 l ut t ull UI RLQUIRtD.
J QTC IllSPECTI0li RECORDS flay RfftfCT IllPROPE R DAIA. 128 I
] S Ql1 - 8 6 - 0 0 9 -X 0 4 01 QA 80504 18 SQll I il 11 Y ll AILS Kilollli 10 QIC, Illlilll[l D DUE 10 Collfl Dt illI At I l Y 150262 2 llA IIA SS IIA 3 flA flA A flA . l10 FURill[R Ilif0RllAlluttilAY BE RLLLASLD. Iluti t A .'
4
- R Poller DLPARilitill CollC[Ril.
i S Qil- 8 6 - O l l -0 0 2 01 QA 80504 11 SQll 1 11 11 Y ll QIC SEQUDYAll llAS All EGEDtY SilUT Dolfli Ill AUGUSI 1985. It i 150264 2 IIA IIA SS llA UE 10 lilE Fall URE OF A GROUP (F.ll0 Dill 10 AtlROPRIAI
' 3 llA flA D flA ELY DOCullLili Il0RK (SPECIFICS 180i Kilollill tillitti ilAD
- BEEli PERI:0 riled. 110 I URillLR liif 0RilAI!Oll Ill flL L.
Allollfl1005 CollCLRil. ,
11 SQll I il 11 Y ll 1-86-129-5Q11 QTC QA RECORDS ARE 180T IDEllTIFI ABLE AllD REIRIIVADI f.
SQP-86-002-00101 QA llSRS IllVESIIUAllull 1-8 3-13-flPS I Dilli t r it p PRODi llPi 150240 Qe6 2 IIA IIA SS llA 3 flA flA A flA Ill 1983 AllD llSRS REPORT R-8S-01-IIPS lilDIC AIES l'l:0 BL LilS liGI CORRECIED Ill tilD-1985. UE, UC AllD laut il I 2gljg AR PolarR RECORDS ARE CIILD. CI IIAS 110 IURilll R lill i ORilAllt'll, ll0 F0t t ull UP REQUIRCU.
ilBP-86-009-00101 QA 80504 S llBil 1 11 11 Y ll Qlc -QA REcaRDS ARE Il0T ID[IlilFI ABL E AllD REIRIEVADi f.
150243 2 IIA IIA SR llA IISRS IhVESIIGAII0li 1-8 3-13-ilPS I Di lll Il ll D PRODi lliS 3 flA flA A IIA Ill 1983 AllD flSRS REPORI R-85-01-fli S lilul0 All', I'l:0 02 QA $8518 S llDil IY Y ll Y BLillS 1801 CORRECILD Ill IIID-1985. 00, OC AllD lloill 2 SR SR flA SR AR PositR RtCORDS ARE Ci!tD. lio l unisii R iili owliA s i n 1 o 5 11 3 llA 14IIAY BE REtEASED. CI IIAS llo i URillt R lill 0RilA l I(Hl .
110 F0LL Ull UP REQUIRED.
G
~ . -- - ~~ - - . - . . ..
t
. . ;- ) , ,
,* * '8, ** If 8.**'f'.*
,T.' -
,+- .- . ,
.. , ;r b .8?..-' "s
. .'a .~ ,Y
( .
I
? j ')
' ATTA0lBIEN E ' A -
PAGE 3 0F 3 .
lEllllESSEE VAll[Y AllillGRilY PAGE -
184 REIERrilCE - ECPS120J-ECPS12tC Ellli IINE - 14:29:59.
IRLQULilCY - REQUEST OITICE OF fl0Ct CAR l'UllER '
EHPLOYEE C0llCERll PROGRAll SYSTEll (ECPS) RUll DAIE - 01/21/81 OllP - 1555 - Rilli i IllPL OYEE CollCERIl Illf 0HilAlIUll BY CAT EGORY/ SUBCATEGORY-CAIEGORYs QA QA/QC PROGRANS SUBCAILGORY 80504 AS-BUILI CollD1110llS S I RtPORI APPL i ll ' 2 sal REIAIED . '
SUB R PLI 3 FillD CLASS llI SinRIC AL - CollCERil .
CAT D LOC Bf- --BL SQ lin REPORT ORIGill CollCERil DESCRIPTIntt CollCERil flullBER CAT XX 088-X0401 Ill 60300 S Sqll I QIC SEQUDYAll - IlEL DIllG CERTIFICAllolls Ill RE At ILRI D DY 150268 2 illE llSE OF CURRECIlotl ItulD. l'ROCLSS tlARK illGS *.HC [ '
3 ll AS FIL E IllDEXES AllD l'AGL CoulliS. AS lillt AS All( .
llARKS. Il0l AT I0lls OR Ally DATA III A I DID lloi 100K II ,
QA 80504 5 SQll -
02 I il ll Y 11 2 flA flA SR llA KE EllGillE[RillG DAI A 011 IllE B ACK Ul' 1 111 DOCill1L ill .
3 llA IIA C llA ,^,, llERE DEL ET ED lit ill CURRLClloil fl UI D. CollSIRtit.Ilull j 03 QA 80516 S SQll IY Y ll Y DEPARillElli CollCERil. CI IIAS l10 I URilll R ll!! URl1A l l uf t d 2 SR SR llA SR .
3 llA XX 122-04201 QA 80109 S SQll 1Y Y ll Y I-85-987-SQll QIC SEQUOYAlle llATERIAI C0lliROL IS POUR. IRAtl ABil li f 2 SS SS flA SS OF REQUIRillElliS, PAPERilullK AllD 11AII RI AI S IS tilAlil Q 150215 UAT E. PAPERituRK IUR QUAT I T Y RLCURD's 15 l'uoR. (l 11 3 ilA Allolitilous CollCI Ril VI A '
02 QA 80504 5 SQll I 11 11 Y ll AS 110 I URillt.R Illl 0RilA T I0ll.
' 2 IIA IIA SS llA LElIER.
5 llA IIA C llA
, 14 CollCERilS IOR CATEGORY QA SUBCATEGORY 80504 1
emme 1
i 4
7
ATTACH".ENT B PACE 1 0F 2
- r. '
REFERENCES A. Office of Engineering Procedure, OE-01 3001 Revision 0, " Drawing Originals
-Checking Out and Checking IN".
B. Division of Engineering, Management and Engineering Data Syste=, MEDS, MP 23.05, Revision 1, "ENDES and vendor Drawings Information Services".
C. Nuclear Quality Assurance Manual (NQAM), Parts I, 11 and II, Revision dated 12/31/84.
D. Office of Engineering Procedure, OEP-08 Revision 0, " Design Output" E. Ad=inistrative Instruction, AI-25 Revision 13, " Drawing Control After Uni Licensing".
F. Significant Condition Report No. SQN SQP 8601 Revision O.
G. Final Safety Analysis Report (FSAR) Section 3.11, " Environment Design of Mechanical and Electrical Equipment".
H. TSAR Section 8.3.1.2.3, " Safety Related Equipnent in Potentially Hostile 7g Enviroment".
v5!n .
W I. NUREG-0588, Eterim Staff Position on Environmental Qualifica: ion of Safety-Rela:ed Equipment"
, J. IEEE-323-1974, "IEEE Standard fer Quclifying Class lE Equipment for Nuclear Power Generating Station"
.K. TVA Topical Report, TVA-TR75-1A Revision B L. Office of Construction Procedure, OC QAPP-5 Revision 5, " Instructions, Procedures, and Drawings" M. Office of Construction Procedure, 00 QAPP-17, Revisions 0 - 3, "QA Records" N. Nonconfor=ing Report (NOR) No. SQN CE38502 Revision 2 O SQN S:andard Operating Procedure, No. 551 Revision 6, "Past Records Review and Engineering Evaluation" P. Quality Assurance Audi Report Nos. SQ-8400-02, SQ-8400-04, SQ-8500-01, PSQ-A-85-005, QSQ-A-86-001, QSS-A-85-0009, and QSQ-A-85-0010 Q. SQN Compliance Visits, Audits, and Inspec: ions - In-plan: Survey, Checklist Nos. 3-85-P-003, 3c-85-P-004, 3h-83-A-017, 3h-64-S-004, 4a-85-A-001, 4a-85-A-013, and 15a-85-P-001
.c h R. SQN
- Work Plans Nos. 10803, 10806, 10830, 10842, 10850, 10861, 10893, 10904, 11139, 11261, 11277, 11467, 11481, 11582 and 11685.
\
n PAGE 2 0F 2
~.)
S. SQN Corrective Action Report (CAR) Nos. SQ-CAR-85-03-004, SQ-CAR-83-07-022, SQ-CAR-84-01-001, SQ-CAR-86-01-004, SQ-CAR-21-81-8, SQ-CAR-85-08-012, SQ-CAR 82-25, SQ-CAR-31-01-003, SQ-CAR-83-09-032, SQ-CAR-85-03-011, SQ-CAR-83-10-033, SQ-CAR-85-09-014, SQ-CAR-84-09-017, and SQ-CAR--85-03-005.
T. SQN Deviation Report (DR) Nos. SQ-DR-85-05-047R, SQ-DR-85-12-148R, SQ-DR-85-06-060R, SQ-DR-84-07-077R, SQ-DR-34-03-023R, SQ-DR-83-12-117, SQ-DR 01-013R, SQ-DR-86-01-002R and SQ-DR-84-04-038R.
tr. Generic Procedure No. ID-QAP-6.2, Revision 0 dated 6/18/85, " Vendor Manual Control".
V. SQN Inplant Survey Checklists Nos. Sa-83-P-005, Sa-85-A-006, Sa-83-030, Sa-83-P-015, Sa-85-S-007, and Sa-84-s-025.
W. Adciinistrative Instruction AI-7, " Recorder Charts and Quality Assurance Records", Rev. 36 dated 4/19/85.
X. Generic Procedure No. ID-QAP-17.2 Revision 1 dated 6/8/86, " Quality Assurance Records for Design and Construction".
Y. Maintenance Ins:ruction, MI-10.46 Revision 3 dated 6/26/86, "Limitorque, Moteor Operator / Control Valve".
M t[d Z. SQN Standard Practice No. SQM2 Revisions 18, 19 and 20, " Maintenance Management System".
AA. TVA 45 D Note,'E. Hassell to J. Hamilton dated 6/13/86, " Evaluation of MR
-. packages /Limitorque Operators".
3B. TVA Drawing No. 45N17949-30 CC. SQN Maintenance Instruction, SQM-17, Rev. 4 dated 10/14/86, " General Requirements for Welding, Heat Treating and Allied Field Operations at a Nuclear Power Plant."
DD. SQN DPM-N73M2 datd 10/10/86, " Process Specification for Welding, Heat Treating and Allied Field Operations."
EE. NSRS Report I-85-987-SQN dated 3/4/86 FF. QTC Reports IN-85-612-X07 dated 10/24/85, XX-85-088-X04 dated 3/4/86, and 2 IN-86-091-001 dated 9/16/85.
.T .
m.11 -)
. ~.
- - - . . - ~ . , . - ,
.. l .
ATTACHMENT C PAGE 1 0F 7
,\ .
TENNESSEE VALLEY AUTHORITY NUCLEAR SAFE Y REVIEW STAFF NSRS INVESTIGATION REPORT NO. 129-SQN EMPLOYEE CONCERN NO. SQP-6-002-001
SUBJECT:
SECDND FOLLOW-UP OF QEB RECORDS INVESTICATION I-83-13-NFS DATES OF INVESTIGATION: February 6-14, 1986 INVESTIGATOR: [I b [
W. R. SIMONDS DATE' P C' REVIEWED BY: > # A 7 3!94 DATE
/~J.C.CATLIN A? PROVED BY: ! ' M)Y J 8 M D. STEVENS DATE 9
1 m
[W
-. - .= -_- - .
~ \
ATTACHMENT C PAGE 2 OF 7 I. BACKGROUND A Nuclear Safety Review Staff (NSRO) follow-up corrective action
- investigation was conducted to determine the validity of an expressed employeo concern received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summariced on the Employec' Concern Assignment Request Form from QTC and identified as SQP-6-002-001, stated:
? . CONCERN: QA Records are not identifiable and retrievable. NSRS Investigation I-83-13-NPS identified
,l problems in 1983 and NSRS Report R-85-07-UPS indicates
' problems not corrected in cid-1985. OE, 00, and Nuclear Power Records are cited. .
An'USRS follow-up review of Investigation.I-83-13-UPS did find that corrective actions resulting from the original NSRS investigation had not been completely. closed out. The results of that follow-up review are documented in NSRS Report'R-85-07-NPS (Ref. 1) along with a reco=mendation (E-85-07-NPS-01) that the Manager of Power and Engineering appoint a records manager to provide upper management i-coordination for resolution of the open items which had been identified.
' '" n II. SCOPE M .
i .
A. The scope of this investigation is defined by the concern of record. It is that problems previcusly identified by NSRS investigation'I-83-13-NPS, and the ccrresponding follow-up review E-85-07-NPS, have not been corrected fer Sequoyah Nuclear Plant j .
' (SQN).
- 3. The scope included determinatien of status and progress of the open ite=s identified in I-S3-13-NFS and E-25-07-NFS as they pertain to SQN.
C. The scepe of the follow-up investigation also ircluded discussiens with site and, task force persennel who are actively involved in the resolutien of these items.
t' .
III.
SUMMARY
OF FINDINSS i A. R-ES-07-NFS centained recc=mendation R-E5-07-NFS-01 which a reco= mended that Power and Engineering (Nuclear) [P&E (Nuclear
- appoint an upper-level manager e= powered with the responsibility, authority, and organizational freedom to assure that records associated with the procurement and installation of Quality Engineering Branch (QEB) source inspected equipment and materials are assembled, verified for co=pleteness, indexed, and stored for
',fi retrievability. The reco=mendation further stated that the
~ ,.
appointee's scope should include all past and future QEB source d inspected procurements for SQN, as well as Watts Bar and Bellefonte, and the establishment of a schedule for completien of past records. }
. . . , . , . .., . .m.. _ . _ . _ _ _ , , , , , , _ , . _ - , . . . - _ _ _ . . , _ , _ _ . _ . -___-.-,--.,__..,_,m _,
s-ATTACHMENT C PACE 3 0F 7 n\ P&E (Nuclear) subsequently inf onned USRS (Ref. 3) that an appointment.had been made, and identified personnel who would provide assistance to the appointee. Following the appointment, meetings of the-personnel were held on September 17. 1985, and December 16, 1985, to discuss resolution of the open items identified in USRS follow-up review Report R-85-07-NPS. These neetings are documented in references 4 and 13 along with specific action items and schedules for resolution of the problems. IV. STATUS OF PREVIOUS;.Y IDENTIFIED OPEN ITEMS A. Develep an Intenrated Records Svstem for Quality Assurance (OA) Records That Will Satisfv the Needs of Nuclear Power (UUC PR) and Office of Ennineerinn Desinn Construction (OEDC) , 1. paragraph IV.A.1 of R-85-07-NFS states that a TVA task force was working on vendor manuals at the time of the first USRS follow-up review, however, two areas of concern were identified regarding vendor manuals as follows:
- a. A quesf. ion was raised by USRS regarding whether any of the manuals were considered "one-of-a-Lind", and therefere, in need of fireproof storage. This finding was addressed in
- a. v. paragraph V.C of the report.
p
%$g .
~
Subsequently, ID-QAp-6.2 (Ref. 15) was revised to require that those vender manuals utili::ed as plant instructicns will be maintained as' QA records. This' 5equirement, in
~
combination with ' existing requirements of AI-23 (Ref. 16), appear to establish adequate protection fer ' ender v manuals for SQN.
- b. The applicable procedures for vender manual control were found to be vague in the delegation of responsibilities.
A task feree was develeping a new procedure regarding the maintenance of vender manuals which was expected to correct the problem. This finding was addressed in paragraph V.E of the repert. Subsequently, ID-QAp-6.2 (Ref. 2.5) was i' revised to more clearly prescribe crganizational responsibilities regarding the control of vender nanuals. I 2. Paragraph IV.A.1 of R-85-07-UpS also states that records indexing procedures,had been prepared and were in various stages of implementation. It was further stated that this ite: will remain open until more experience is gained by P&E (Nuclear) with the records indexing syst.em. This matter is discussed in the following paragraphs.
. ?* s ,
n) 2 i
. ._.-__ ___ _ . . _ _ . _ _ . . . - _ _ _ . _ _ _ _ - _ _ , .__ _ - _ . . _ . . . _ - . . _ . . ~ . . _ . . - ~ . - - . _ _ _..._ _
ATTACHMENT C PAGE 4 OF 7 n\ G
.)
Correct Irelementine Deficiancies Identified In the Existine Svetem B.
- 1. Paragraph IV.A.2.a of E-85-07-NPS states that QEB records were not adequately indexed and that there was some concern regarding their completeness. At the time of the the first NSRS follow-up review, cfforts were under way to index and microfilm completed contracts; however, a schedule had not been established for completing the overall task. Initially, a e
completion date of December 31._1987~ was set by the P&E (Nucicar) task force (III.A) for completing the overall task
. for all projects (Ref. 4). However, a recent commitment was
-made that appropriate manpower resources will be expended to ensure that a deadline of June 30, 1986, will be met for SQU (Ref. 13).
QEB is utilizing a four-step approach which includes' identification, location, verify completeness, and microfilming of the records (Ref. 4). Sequoyah has concurred with the parameters that QEB is using to index their records (i.e., vendor / contract number). However, site personnel normally'must request the records by Unique Identifier Number (UNID). Therefore, efforts are in progress to provide a cross-reference between UNID and vendor / contract numbers. The Equipment Qualification Information Syste= (EQIS) is being investigated as t,he link to provide this a sa.. cross-reference (Ref. 6 and 13). This item remnins open.
~ .
.. .a{$.'r4 ' 2 .- Paragraph IV.A.2.b of R-85-07-NFS states that all 00 records for Sequoyah had been trans' erred or were in the final stages s of microfilming at the time of the first USRS follo.:-up review.
.'MicrofiL=ing of all the records underway at the time of the g
review have been co=pleted. However, another 175 cubic feet of
. , contract-related files and various other ree6~rds were discovered by SQN-DOU personnel in warehouses vacated by 00, in addition to several files at other locations.
SQN-00U and E!MS-Chattoonga persennel are working to ~2a-a#8' these additicnal records and have co=pleted filming about 36 cubic feet.' Manual indices will be es'tablished for these records
< pending resolution of probleri associated with the Reccids Retrieval.Index (RRI) system. Eicrofilming is proceeding on an
.. "as-soon-as possible" basis (Ref. 10, 12, 13 and 14). This item remains open.
i
~3. ParagraphI IV.A.2.b of R-85-07-NFS also states that a RI. system was prepared but 'jud'ged to be not totally eff ective at the time of the first NSES follow-up review.
NUC PR personnel subsecuently conducted a review of the-ERI to identify deficiencies and initiate recommendations to correct
.- s any proble=s (Ref' A and 7). The NUC PR review confirmed that Yrn.} ,
the RRI was deficient in several are'as and reco=mendations were
;p_ '. made to identify all 00 record types and develop detailed instructions f or the retrieval of each record.
3 I I
s
. . ,. , ~ -
ATTACRMENT C PAGE 5 0F 7
.. :) The P6E (Nuclear) task force (III.A) established to resolve the open items of E-85-07-NPS has taken the recommendations under consideration and has acted to establish a sub-task group to
" rework the SQN RRI using original ERI guidelines" (Ref. 13).
The chairman of the sub-task group has met with cognicant
> persennel and is proceeding with efforts to rework the RRI. A date for completion of the task has not been set. This ites remain,s open.
4 Paragraph IV.A.2.d states that continued upper management coordination involvement at a level capable of crossing organization boundaries is considered necessary until the problems are solved and records systems prove effectivo. This matter appears to have been adequately addressed by P&E (Nuclear) through actions discussed in paragraph !!!.A above.
/
C. Clarifv Ornanizational Reseensibilities Paragraph IV.A.4 states that with the exception of a clearly defined system for vendor manuals, organizational responsibilities
~
have been defined. Subsequent revisier. of ID-QAP-6.2 (Ref.15) appears to adequately prescribe responsibilities for vender manual
~
centrol as discussed in paragraph IV.A.1.b above. z.m 473',. D. Planned Actiens and Schedules fer Cemeletien of Action v . , Paragraph IV.B of R-85-07-NPS states that QEB had not ecmpleted verification and indexing of their records for SQU nor had QE3
- established a schedule for doing so at the time of the first USRS follow-up review. Actions taken on this matter are discussed in paragraph IV.B.1 above.
V. CONOI.USIONS AND RE0012'.ENDATIONS . A. Cenelusien The employee concern is substantiated in that ccrrective action ite=s shown in NSRS investigation *I-E3-13-NFS have not been ecmpleted for SQN. However, specific improvements have been achieved regarding vender manuals, and work is steadily progressing toward the resolutien of the remaining open items identified by USRS. , B. Pecernendatien I-86-129-SQN-01, Continue Monitoring NSRS should continue to monitor the status of open items fren 4 . I-83-13-NPS as they pertain to SQN. [F3] i 4
s ATTACRMENT C PAGE 6 0F 7
"()
g ..o DOCUMENTS REVIEWED IN INVCSTICATION NO. I-86-129-SQu AND REFERENCES
- 1. Informal Hemorandum from K. W. Whitt to H. G. Patric, " Follow-up Review of Quality Engineering Branch (QEB) Records investigation I-83-13-NPS -
Nuclaar Safety Review Staff (NSRS) Report No. R-85-07-NPS," dated May 28, 1985 (A02 850529 010)
- 2. Hemorandum from H. C. Parris to K. W. Whitt, " Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff (NSES) Report No. R-85-07-NPO," dated July 1, 1985 (L16 850624 840)
- 3. Memorandum from H. C. Parris to K. W. Whitt. " Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NPS," dated August 14, 1985 (L16 850729 883)
- 4. Memorandum from R. A. Pedde to Files, "USRS Report R-85-07-UPS - Follow-up Review of QEB Records Investigation - I-83-13-NPS," dated September 19, 1985 (Col 850919 004)
-, 5. Me=orandum frem M. M. McGuire to R. A. Pedde, "NSRS Report E-85-07-UPS ,"
Nihe,A dated September 24, 1985 (L16 850924 833)
'e. aie ,
w.e .
- 6. Memorandum f ecm M. M. McGuire to R. A. Pedde, "NSRS Report E-85-07-NPS,"
dated October 29, 13C5 (L16 851029 887)
- 7. Memorandum frem M. W. Madacek to M. M. McGuire "USES Report R-85-07-NFS,"
dated November 13, 1985 (L16 851113 895) Mc=orandum from R. D. Guthrey to Ja=es ?. Oarling, "Confi5uration Task
~
8. Force - Activity Sur=ary and General Assessment," dated August 8, 1985 (R25 850808 861)
- 9. Infernal note f rem J. P. Vineyard to 0. L. O' Dell regarding transfer cf 00 i recceds to NUC PR, dated June 28, 1985 (R25 850628 002)
- 10. Memerandem frem Alva LaMontagne to Mancy Welch, " Office of Ccnstructicn (00) - Sequoyah (SEQ) Site Records," dated September 24, 1985 (A31
. 250925 001)
- 11. Memorandum frem M. M. McGuire to R. A. Pedde, " Action item 9-17-3 of USRS Report No. E-85-07-UPS," dated November 21, 1985 (L16 851121 802)
- 12. Memerandum frem Alva LaMontagne to John Ed Hayes " Microfilming Sequoyah Construction Records," dated January 8,1986 ( A31860108 051) 5
ATTACILMENT C PAGE 7 OF 7 m I
- 13. Memorantim f rom R. A. Pedde to Files, "t:SRS Report R-85-07-flP: - Follow-up Review of QED Records Investigation - I-83-13-tips," dated January 9, 1986 (C01 860109 003)
- 14. Mcmorandum f rom Alva 1.ationtagne to !!ancy Welch, "Of fice of Construction (00) - Sequoyah (SEQ) Cite Contract Records," dated January 22, 1986
(/J1 860122 051)
- 15. 1;UC PR tiuclear Quality Assurance Manual (tiQAM), Part V, Section 6.2 (ID-QAP-6.2), " Vendor Manual control," revision dated Dece=ber 31, i 1985
- 16. Sequoyah Instruction AI-23, " Vendor Manual Control." E.21 g&,
M . O
\
J D 9
',,'t.
6
ATTACHMEtiT D PAGE 1 OF 7 TElil!ESSEE VA1. LEY AUTHORITY
!!UOLEla SAFETY REVIEW STAFF
!!SES IITVESTIG/sTIO!I REPORT 1;0. I-86-180-SQIt EMPLOYEE C0!!CERIS: s .. . . . ., .
.
- SQM-6-003-002 /
Kf
- m. . ... ...--
SUBJECT:
SQIl DE/A'II!O COI? TROL c3'%~1 DATES OF
'4ff d%+2~
I!!VESTICA !Oll: - FEBRUARY 5-7, 1986
'~
I:VESTIGATOR: @ S-S7~ b J . J . 12iIGHTLY DATE REV!EWED BY: bw MfM/1b DATE L. E. 3 ROCK A AFFROVID BY: JJ A 2- 'N k'. D. STEVE!!S DATE 1 A a
.5
[
ATTACHMENT D PACE 2 OF 7
.C\ ~ ' %. ' . )
I. BACKCROUND A Nuclear Safety Review Staff (UCRS) investigation was conducted to determine the validity of six expressed employee concerns as received by the Quality Technology Company (QTC)/ Employee Response Team (ERT). The concerns of. record, as summariced on the Employee Concern Assignment Request Form from QTC and identified as SQM-6-003-001 through -006, stated:
)
/ SOM-6-003-001 Specific documents have been improperly issued.
Nuclear Power concern. CI has no further information, e-QTC Clarification: Design drawings for ECN L6027 have been improperly issued. t
.SOM-6-003-002 Duplicate documents have been issued with conflicting data. Nuclear Power concern. CI has no further information.
Drawing 45U1749-30 (R8) was issued h kiy QTC Clarification: twice on two separate =ylars dated November 29, 1985 and November 30, 1985. SOM-6-003-003 Specific documents have been i : properly altered. Nuclear Power concern. CI has no more information. QTC Clarification: Drawings 15W810-44 (R7) and 45W833-1 (R9) were issued without Project Manager's initials in title block. Initials were added to the nylars after issue. SOM-6-003-004 Falsification of' specific documents. Nuclear Power concern. C has no further information. QTC Clarification: "he drawings identified in Concern SQM-6-003-003 were "coirected** without going through the UCR process. SOM-6-003-005 Employee was directed to improperly change another Q '; employee's work. Nuclear Power concern. CI has no 2l " further information. 1 e
4 ATTACHMENT D PACE 3 0F 7
.,f.. )
QTC Clarification: The documentation included three significant condition reports (SCRs) submitted January 11, 1986. SOM 6-003-Od6 CI feels an attempt is in process to ' cover up' a specific probicm. Nuclear Power conce"n. CI has no further information. QTC Clarification: CI. feels the significant condition reports identified in SQM-6-003-005 are being rewritten in such a way that the real problems will be misstated. II. SCOPE A. The scope of the investigation was determined from the stated concerns of record and the respective QTC clarifications to be that of only the specific concerns contained in the stated QTC clarifications. B. To acec=plish this investigation, NSRS reviewed applicable requirements, procedures, drawings, drawing management system fff 7.3 reports, significant condition reports (SCRs), and open item 94fM tracking system reports for these SCRs. Additionally, responsible drawing control personnel were contacted to discuss the employee's < concern, t 4 TII. SUF2iAR". 0F FINDINOS A. Requirements and Oc==it=ents
- 1. Nuclear Quality Assurance Manual (UQAM), Part III, Section 1.1,
" Document Centrol," Revision March 21, 1985. "Preparatien, review, approval, and issuance of docunents and their revisiens shall be acec=plished 2 accordance with approved written procedures /instructiers. These . . . shall include . . . the following requirements: . . . Final approval authcrity, Revicien Centrels. . . ."
- 2. Office of Engineering Procedure OEP-08, " Design output."
Project Manager ". . . signs at ' Issued By' and distributes the drawing " e'.8?. a . *'%
' . .)
1-2 f O
,,-,m,, - - . _ . . . -,,_...m,,...,,_,-.-.,,7.,,._ , , _ , - . , r. ,,.,.-._.-,,m ,-1 ~- -- - .-.,.r.--
.. . . _. _ . . ~ .. . . _ . =.
.. ~ ,
ATTACHMENT D PACE 4 0F 7 B. Findings
- 1. Concern SQM-6-003-001 i A query of the Drawing Management System identified 25 drawings for ECM L6027. A review of the file of issued drawings maintained in the Office of Engineering Technical Information Center (TIC) found that 24 of the 25 drawings were issued 4
without the Project Manager's. signature / initials as required by
OEP-08, Paragraph 5.1.3. The affected drawings are as follow.
45N1673-5 (R9) 45N630-4 (R15) 45N1645-1 (Ell) 45N655-19 (R7) 45N1645 (R12) 45N655-44 (R7) 45N1648-1 (R10) 45W1656-4 (R22) 45N1648-4 (R16) 45W1673-5 (R9) 1 45N1688-1 (R23) 45W2673-5 (R4) ; 45N1688-3 (R26) *473601-55 46 (R12) 45N1693-1 (R24) 47W605-15 (R13) 45N1693-3 (R19) 47W605-16 (R13) l . 45N2645-1 (R9) 47W605-33 (R15) 45N2645-8 (R12) 47W605-35 (R16) 45U2648-1 (R13) 47W610-30-01 (R28) 45N264S-4 (R9)
- issued with. approval signatu.e fiik 976 The non.conferming cenditions for these drawings were reported in SCR SQN SQP8602 R0 dated January 11, 1986.
2.;;Ccncern SQM-6-003-002
. 3 ,
A review of Sequoyah Nuclear Plant (SQN) mylar drawings found that wiring diagram 45N1749-30 was issued twice at revision level 8 on two separate mylars dated November 29 and 30,1985. The drawing was first issued at revisien level 8 for LEON
/ p 6202/FOR 3583 and then issued the next day at the same revision
*- level 8 fer LEON 6544/FCR 3966. In additien to these revision
- control errors, the drawings were also issued without Prcject f f ,*32 V
Manager's signature / initials. A subsequent revisien, R9, i references in the title block the Nove=ber 30 issue. The n=nconforming ecndition for the duplicate issuance was repcrted I in SCR SQN SQP8601 RO dated January 11, 1986. L > 3. Concern SQM-6-003-003 A review cf the appficable drawings 15WS10-44 E7 and 45W833-1 R9 found that both were issued without the Project Manager's initials in the title block. The SQN mylar copies included
' initials at the time of investigatien but the microfilmed aperture cards which were sent out on distribution did not.
l Since the cards were reproduced from the mylars, it was evident 1 -,. ' "- that the initials were added after issuance und
'}
- 3 I
t i
.--,- . , - . , , , ..-__m . . _ . . . _ . _ , . . . . . . . . _- . . - - . . ~ . . . . . . _ , _ , . . -__,_ ~ . - .
. . - . . - - . - _ ~. . ~ _ _- -. _ _ - - . . . - - . --
r i *
.- ATTACHMENT D PAGE 5 OF 7
* OQN document control personnel stated that the distribution.
initials were added-by unauthoriced personnel and in a manner which contradict'ed office practice. The DCU office cupervisor stated that the proper method of correction was by reissuance cf the drawing, recall of the incorrcet drawing, and a memorandum of explanation to the document holders. He stated that this
~
correction would be initiated promptly. The nonconforming situation was reported in SOR SQN SQP8603 RO dated January 11, 1986. 4' . Concern SQM-6-003-004 As noted above, it was found that drawings 15W810-44 R7 and 45WS33-1 R4 were issued without the Project Manager's initials and th'at, initials were added to' the mylars without authorization after issuance. Because of this bypassing of appropriate corrective action, which should have included recall of the incorrect drawings and reissue of correct ones, the distributed drawings were left in an uncorrected status. Thus, the addition i of initials to the mylars did not cause anything to be changed 7' in the system of distribution. It was determined that numerous individuals had access to the mylars and could have placed the initials. It is not known who placed them or what their - motivation may have been. The conconforming condition concerning the initials is included in SCR SQN SQP8603 RO. 5@$k 5. Concern,'SQM-6-003-005 Three draft SCRs dated January 11, 1986, concerning document control problems identified in this report were found to have 7 been submitted to the SQN Design Project Coordinator. The Project Coordinator stated during interviews with NSES that an initial decision had been made to consolidate the three S0as ) into one. However, after the writer of the SORS indicated that this " consolidation" =ight obscure the facts of the nonconfern-ing conditions, it was decided to go ahead and issue the SORS exactly as written by the original writer. KSRS confirmed by-review of the employee's original handwritten draft SCRs and the l_ issued SORS (SQU SQPB601 RD, SQN SQP8602 RO, and SQN SQP8603 RO) that the issued reports were word for word as originally drafted. The, issued SCRs were dated January 11, 1986, and, according to the Project Coordinator, were transmitted l January 17. USES confirmed that the SORS were transmitted and a
- received for tracking, evaluation, and corrective action by reviewing the TROI open item and reporting syste= report dated
' February 1,1986, w'hich showed the applicable SCRs as assigned and in progress. With the transmittals having been initiated Friday, January 17, and the e=ployee's statement of concern dated Tuesday, January 21, it appears that the concerned individual may not have known that the SCRs had in fact been
.ceps processed and transmitted exactly as originally written.
4 sv>) i 4 e
.--r-,,-m-r - m . . -, --,,- -.-----4. - , ,-ym-n- .p,r----w-m---,--mm,,,.,-y- ,-g.~ .y . ,-,---+---,-----m- - , - -w- -n n
I
.. c.
ATTACHMENT D PAGE 6 0F 7 g 6. Concern SQM-6-003-006 The facts of this concern are covered fully in the above report for SQM-6-003-005. I V .- CONCLUCIONS AND RECOMMENDATIONS
-A. Conclusions
- 1. Conecen SQM-6-003-001. The employee's concern was substantiated.
- 2. Concern SQM-6-003-002. The e=ployee's concern was substantiated.
- 3. Concern SQM-6-003-003. The employee's concern was substantiated.
- 4. Concern SQM-6-003-004. The c=ployee's concern was substantiated.
i 5. Concern SQM-6-003-005. The facts of the e=ployee's concern were i not substantiated.
- 6. Concern SQM-6-003-006. The facts of the employee's concern were not substantiated.
Mi B. Recommendations bre.~. C?!! . V ~ None. The applicable concerns have been documented for analysis and corrective action by SCRs SQN SQP8601 RO, SQN SQP8602 RO, and SQN SQP8603 RO, all dated January 11, 1986. 4 . i J T
. m .,
4 i(".
,- ..)
. l A
i S e
- .- . ._ - -, --.m__ ._ , , . ~ - - - . , , , _ , . . . - , , . _ , _ . - . _ _ _ . - . . - . ~ _ _ . . , _ , , . _ , _ . . . _ . _ . . - - - - . _ , _ . , _
. . - . - . _ . . - . - . - _ - ~ . . ---- - .- . _ . - . . . . - - . - . - .
. ,e .
ATTACR'1ENT D PAGE 7 0F 7 <
*: 4 * ?)
M*- DOCUMENT REVIEWED IN INVESTICATION I-86-180- QN AND
REFERENCE:
i 1, Nuclear Quality Assurance Manual (NQAM), Part III, Section 1.'1, " Document
.\ Control." Revision March 21, 1985 1
- 2. Office of Engineering Procedure OEP-08 RO, " Design Output" .
N 3. Sequoya'h Nuclear Plant Administrative Instruction SQNP AI-25 R12 " Drawing l. - Control After Unit Licensing" f 4. Drawing Management System Report dated February 7, 1986, " Drawings f Affected by EON /FCR*' (for E::N L6027) !
- 5. Tracking and Reporting of Open Items (TROI) Report dated February 1, 1986
\ 6. Significant Condition Rcports (SCRs) SQN SQP8601, 8602, 8603 (all RO) i
\
* . e 4
4 ? I
*%8*
I
- I I
l 1
.*" t.s u .. ~ ~?
*se*
] 6 i
~.
ATTACID!EliT E PAGE 1 0F 7 TE!I:lE::SEE VALLEY AUTHORITY
!!UOLCAR S/JETY REVIEW OT/EF N::RS INVE::TICATIO!! REPORT No. I-86-185-SQti EMPLOYEE CONCERN ' M;_._ .... - -
_s
- SQH-6-002-005 SQM-6-002-006 /
SUBJECT:
SEQUOYAH !!UCLEAR PLA!!! VE!! DOR DRAWII:0 CO:: TROL DATES OF
!!NE:;TIGATION: FEBRUARY 12-13 and 19-20, 1986 b INVESTIGATOR: N/ iTL b me 0 3'4~
~
J. J. }3;IGHILY DATE
" r 'J - # ' #* #" _
RIVIEWED BY: - - - M/ Af ROLTOWICH DATE W
~
AFFROVED 3Y: W. D. O! EVENS DATE e e
*A .e e e 4
,#W"%
o ATTAC&fEnr g PACE 2 op 7
,rss i
- 1. BACKCRCUfD A Nuclear Safety Review Staff (USRO) investigation was conducted to determine the. validity of expressed employee concerns roccived by the The Quality Technology Company (QTC)/tmployee Response Team (ERT) .
concerns of record, as summariced on the Employee Concern Assignment Request Form f rom QTC and identified as SCH-6-002-002 through -006, stated: SOM A-007 002 Opecific supervision is not responsive to correcting a quality problem in a timely manner which can and is ' af f ecting the quality' of the plant. (Names / details known to QTO, withheld to maintain confidentiality.) No further information may be released. Nuclear Power concern. CI has no further information. Q*C Clarification: The of fice supervisor f or the SQN Engineering Project was asked by the employee to have a vender drawing audit conducted in 1985 but no audit was performed. SOM-6-002-003 jg 7% h.t?N 34$2/ Specific supervision has neglected to perform a scheduled assi*gnment which results in a continuous quality impact on the plant. (Names / details known to QTO, withheld to maintain confidentiality.) Uucien; Power concern. No further information may be released. CI has no further infcemation. QTC Clarification: An audit of vender drawings was to have been perf ormed in Septe=ber 1985 af ter a VA drawing audit, but the vender audit was cancelled. 50M 6-ec2-004 ' s) Specific supervisicn stopped corrective action on a quality problem that.had been identified months earlier. (Uames/ details known to QTO, withheld to maintain confidentiality.) No further information may ' be released. Nuclear Power concern. C; has no further information. , QTO Clarification: Supervisor denied a written request submitted by employee on January 9, 1986, to perform a l vendor drawing audit. j
')
1
. N ATTACRMENT E PACE 3 0F 7 3
)
4
%(7 - SOM A 002-005 Controlled documents contain conflicting data relating to the same installation. (Names / details known to QTC, withheld to maintain confidentiality.) No further
- information may be released. Nuclear Power concern.
CI has no further inf ormation. QTC Clarification: Applies to design drawings-mylars. Check wash-off los for specifics. Better controls are
/needed for the original mylars.
'~' I pg 309-6-007-006- ,
Work is being performed to documents containing conflicting or obsolete data. (Names / details known to QTC, withhold to maintain confidentiality.) No further information may be released. Nuclear Power concern. C: has no further information. Concern is based on programmatic QTC Clarification: problems that both a new mylar and old may exist with each containing different data. 6% . Q?f:Q'" II. SCOPE , .' , A. The scope of this investigation was determined frem the stated concerns of record and the respective QTC clarificatiens to be that l of only the specific concerns contained in the stated QTC clarifi-cations. . B. To accomplish this investigation, UCRS reviewed applicable require-
- ments, procedures, drawings, drawing logs, and correspendence.
Additionally, responsible drawing control and reprogrcphics ' personnel were contacted to discuss the employee's concerns. T :.
SUMMARY
OF TINDINCS, A. Requirements and Cc==itments
- 1. Division of Engineering resign Management and Engineering Data Systems (MIOC) Procedure MP 23.05, "EN DES and vender Drawings -
"The 7:C does not maintain pre-1975 Information Services."
original vender derawings unless they have been placed under TVA revision control and sent to TIC for storage. All other vendor originals which were submitted to the TIC prior to 1975 have been or are being microfilmed and destroyed."
.~.
s
':)
' 2
\
~.
, '6 ATTACHMENT E PACE 4 07 7
- 2. Of fice of Engineering Of fice Instruction OE-0I 3001, " Drawing Originals - Checking Out and Checking In."
B. Findings
- 1. Concerns SQM-6-002-002 and SQM-6-002-003 The Office Supervisor for the Sequoyah Nuclear plant (SQN)
Engineering Project came to the position in January 1985. He stated that drawing controls at that time for both the TVA and vendor drawings were not fully adequate; that original drawings for SQN design work were not always irmediately available as needed; and that first priorities for correction were placed on the TVA drawings and on several other critical matters affecting the SQN' engineering design effort. The vendor drawings received a second priority. The immediate supervisor verified to USRS that this statement of priorities rcpresented the management priorities at that time. In order to verify that all TVA drawings were available and to
- correct any deficiencias by reordering replacements (washoffs),
a TVA drawing audit was conducted during September-October 1985. The office Supervisor verified the employee's statement that an audit of vender drawings was to have been performed at the conclusion of the TVA drawing audit. He stated that the [fh$h vendor drawing audit was postponed from October 1985 to January ig.sd j ,
- 1986 because staff was needed on other projects, but that the audit was begun in January and had been in process for three weeks.
In order to maintain a dated listing of all replacement drawings requested from Office of Engineering, Knoxville, a washoff log was initiated by the SQN office Supervisor on August 1, 1985. The los included 240 entries at the time of the investigation in February 1986. Of these, approxt=stely 220--over 90 percent of the total--were for replacement vendor drawings with the remainder being for TVA drawings. The further investigation of these orders is reported below under finding No. 3.
- 2. Concern SQH...,6-002-004 It was verified that the employee sub=1tted a written request dated January 9, 1986, requesting overtime on several weekdays and a Saturday to set up contract files and audit "B" size TVA drawings. This request was denied by the supervisor in a form TVA ASD memorandum also dated January 9, 1986. The supervisor stated in the memorandum that he wanted to work with the employee with regards to contract drawings and noted that ". . .
we have real problems with manufacture drawing originals." He wrote that, "I currently am working on other clerical items with
-m ,
deadlines and cannot work with (the employec) . . . I am well
] aware of us being deficient as far as an audit is concerned but
- 3
v;.. ATTACRMENT E PACE 5 0F 7 .' l
, y. g l we have been deficient since I arrived in January 1985. I don't '
feel anothcr two weeks is going to be that critical to us." tater that same month, the vendor drawing audit and. corrective action activitics were started and were in their third week at the tire of this investigation. ,
- 3. Concerns SQM-6-002-005 and SQM-6-002-006 At the time a drawing original is determined to have been lost, a replacement original ("washoff") is requested from the office of Engineering. Knoxville. The washoffs are produced from the microfilm aperture cards maintained by the Technical Information Center. As noted above, approximately 240 washoffs were requested between August 1, 1985, and February 1986, with over The 90 percent of' the replacements being for vendor drawings.
OE Reprographics Supervisor stated that because the vendor drawing originals before 1976 were routinely discarded, there is a periodic need at the sites to provide washoffs from the aperture cards. He did not believe that the quantity of SQN requests was unusual. He stated that SQN was the first site to centralize the authority for washoff reque'sts, thus minimi:in's duplicate or unnecessary requests. He indicated that Knoxville desired similar centrali:ati'on at the other sites. When a replacement drawing is received at the Office of e Engineering SQN site, the replacement is checked in and becomes khr WD-the new " original" which will be the baseline drawing for subsequent changes. If a missing drawing should eventually reappear and not be properly dispositioned, the potential would exist for the two " originals" to contain obsolete or conflicting The
' data whenever one drawing was updated but not the other.
controls which are now in place to avoid lost and duplicative drawings include the following: (a) Drawing checkout system: Drawings are checked out frcm the drawing tanks on a Drawing / print Request Fo:n which includes a self-checking section for re= oval of drawings after hours if necessary. It was determined that the Office of Engineering Section heads had keys to the drawing area for access after normal working hours when drawing control. personnel were not present. Although this provides some possibilities for drawings to " stray" after heurs, the office supervisor did not believe this to be any =ajor problem. He vigorously supported the necessity for 24-hour access to the, drawing originals, demonstrated the ease-of-use of the checkout forms, and stated that the checkout records were updated pro:ptly each morning from any forms left during t e nish' , pu V G p c
, d *" R)V ,v
'.('5 .-
Vl$ n e pOc i4/ 'J 'j34)ll ( u>s$n;G f/ e ryi s . .e i A. >u i 1
~ .
L' 5 . ATTACHMENT E PAGE 6 0F 7
,.q g I
(b) Drawing check-in system: k*henever it is neccusary to request a replacement for a lost original, a note is placed
? in the drawing checkout file for any cases where the lost
/
/ original reappears. Subsequently, if a drawing being I
checked in is one for which a replacement had been ordered, the document control clerk is flagged to cancel the jhs J [ j ', replacement from the system. order or to withdraw one or the o , (c) Centralized ordering of replacements: As noted above, SQN 4 is the first TVA site to centralize the authority for
- washoff requests. OE Reprographics is to deny all requests except those channeled through the authority. The OE Supervisos of Reprographics stated.that this centrali=ation is helping to eliminate duplicative requests wherein two or more individuals might order the same replacement.
IV. CONCLUSIONS AND RECOMMENDATIONS A. Conclusions 1, Concern SQM-6-002-002. The employee concern for vendor drawing 1. controls is substantiated, but the concern for supervisory a responsiveness is not substantiated. The vendor drawing audit Tf was delayed until,1986 because of other reasonable priorities. The audit is now in progress. l
- 2. Concern SQM-6-002-003. The a=ployee concern is not substan-tiated. Supervisory neglect was not identified.
- 3. Concern SQM-6-002-004 The employee concern is not substan-tlated. The supervisor denied a request for overtime but did not stop corrective action. Corrective action is in progress.
The e=ployee concerns
- s. 4.:. Concern SQM-6-002-005 and SQM-6-002-006.
1.
'for duplicative nylars are substantiated in that this conditien does sometimes exist. The cencern is =itigated by the finding
-that several. controls are in place to =in 2 e the conditlen. d Support was not identified for additional controls such as further limitation of access to the =ylars.
B. Recc=mendations 1ES-SQN-01, Track!Er of Cerrective Actien 1 Corrective action concerning SQN vendor drawing controls is in progress throu8 h (1) performance of acontrolled vendor drawing audit which replacement of began January / February 1986 and (2) Controls to minimize recurrence of dupli-
~~', drawings where needed. There are no 7.) .cative mylars have been developed and are in place.
- additional reco=mendations, but SQN should provide notification to NSRS when corrective action is completed. (p-3]
I 5 4
.- _ _ - _ . _ _ . , , _ _ . . _ , , . - _ . , , . , __...,_r.c.,_ .,y-.-. . . , . . ._ __m.,,
w < q
- p.. s., . .
+ .
ATTACHMENT E PACE 7 0F 7 DOCUME!.TO REVIE'w'ED IN INVE0!! CATION 1-86-185-SQN AND REFERENCES 1 Office of Engineering Office Instruction OE-0; 3001, " Drawing Originals - Checking Out and Checking in" 2. Division of Engineering Design Management and Engineering Data Systems (MEDS) Procedure MP 23.05, "EN DES and vendor Drawings - Inf errat:.cn Services" 3. Office of Engineering Office Instruction Manual OE-0; 4003, " Prints and Microfil= - Routine Distribution" Menorandums S. L.Yodd to John Dennis and Jack Valentine dated January 9, 1986; and Jack k'. Valentine to John Dennis dated January 9, 1986 4. s S t* I 6
',. o um%,, . 'vL9? .
A i, - , . t
- s M e
./.
5 e
.ge
*Qes .
e e
**9
.* , 5
' 6
- , - - , - . ,--- , . - - . - - - -}}