ML20215A399

TVA Employee Concerns Special Program Rev 2 to Subcategory- Const 11200, Workplan/Work Control

ML20215A399
Person / Time
Site:	Browns Ferry
Issue date:	06/02/1987
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215A402	List: ML20215A399 ML20215A416
References
NUDOCS 8706160644
Download: ML20215A399 (130)

Text

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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 11200 REPORT TYPE: Subcategory - Construction REVISION NUMBER:

2 TITLE: Workplan/ Work Control PAGE 1 0F 93 REASON FOR REVISION:

Incorporation of corroctive action plans Revision 1 Incorporation of SRP coments Revision 2 PREPARATION PREPARED BY:

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• SRP Secretary's signature denotes SRP concurrences are in files.

3187T 8706160644 870605 DR ADOCK O y9

TVA EMPLO12E CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM FRONT MATTER REV:

2 PAGE i 0F vili Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA). The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP)

Concerns filed after that employee concerns filed before February 1, 1986.

date are handled by the ongoing ONP Employee Concerns Program (ECP).

The ECSP addressed over 5800 employee concerns.

Each of the concerns was a formal, written description of a circumstance or circumstances that anThe employee thought was unsafe, unjust, inefficient, or inappropriate.

mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the NRC, and the general public. The results of these investigations are communicated by four levels of ECSP reports: element, subcategory, category, and final.

Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2.

An element consists of one or more closely related issues. An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns.

For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself.

Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.

Subcategory reports summarize the evaluation of a number of elements.

However, the subcategory report does more than collect element level evaluations. The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.

This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.

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To make the subcategory reports easier to understand, three items have been j

placed at the front of each report: a preface, a glossary of the j

terminology unique to ECSP reports, and a list of acronyms (terms formed from the first letters of a series of words).

i Additionally, at the end of each subcategory report the reader will find at least two attachments. The first is a Subcategory Summary Table that includes the following information:

the concern number, a brief statement of the concern, and a designation of nuclear safety-related concerns. The second attachment is a listing of the concerns included in each issue evaluated in the subcategory.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM FRONT MATIER REV: 2 PAGE 11 0F vili The subcategories are themselves summarized in a series of eight category reports.

Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:

management and personnel. relations industrial safety construction material control operations quality assurance / quality control welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.

Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.

A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP, including the Inspector General's report.

For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual. The Manual spells out the program's i

objectives, scope, oe;anization, and responsibilities.

It also specifies the procedures that were followed in'the investigation, reporting, and closeoat of the issues raised by employee concerns.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM FRONT MATTER REY:

2 PAGE 111 0F viii ECSP GLOSSARY OF REPORT TERMS

• classification of ovaluated issues the evaluation of an issue leads to one of the following determinations:

Class A: Issue cannot be verified as factual Class B: Issue is factually accurate, but what is described is not a problem (i.e., not a condition requiring corrective action)

Class C: Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D: Issue is factual and presents a problem for which corrective action has been, or is being, taken as a result of an evaluation Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.

collective significance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.

concern (see " employee concern")

corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.

criterion (plural: criteria) a basis for defining a performance, behavior, or quality which ONP imposes on itself (see also " requirement").

element or element report an optional level of ECSP report, below the subcategory level, that deals with one or more issues.

employee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM FRONT MATTER REV:

2 PAGE iv 0F vili evaluator (s) the individual (s) assigned the responsibility to assess a specific grouping of employee concerns.

findings includes both statements of fact and the judgments made about those facts during the evaluation process; negative findings require corrective action.

issue a potential problem, as interpreted by the ECTG during the evaluation process, raised in one or more concerns.

K-form (see " employee concern")

requirement a standard of performance, behavior, or quality on which an evaluation judgment or decision may be based.

root cause the underlying reason for a problem.

• Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear safety-related, unreviewed safety-significant question).

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM FRONT MATTER REV:

2 PAGE v 0F viii Acronyms AI Administrative Instruction AISC American Institute of Steel Construction ALARA As Low As Reasonably Achievable ANS American Nuclear Society

ANSI, American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials AWS American Welding Society BFN Browns Ferry Nuclear Plant BLN Bellefonte Nuclear Plant CAQ Condition Adverse to Quality CAR Corrective Action Report CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual CMTR Certified Material Test Report COC Certificate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU CON) e

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM FRONT MATTER REV:

2 PAGE vi 0F vili DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DNT Division of Nuclear Training DOE Department of Energy DP0 Division Personnel Officer DR Discrepancy Report or Deviation Report ECN Engineering Change Notice ECP Employee Concerns Program ECP-SR Employee Concerns Program-Site Representative ECSP Employee Concerns Special Program ECTG Employee Concerns Task Group EEOC Equal Employment Opportunity Commission EQ Environmental Qualification EMRT Emergency Medical Response Team EN DES Engineering Design ERT Employee Response Team or Emergency Response Team FCR Field Change Request FSAR Final Safety Analysis Report FY Fiscal Year GET General Employee Training HCI Hazard Control Instruction HVAC Heating, Ventilating, Air Conditioning II Installation Instruction e

INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE vli 0F vill f

L/R Labor Relations Staff M&AI Modifications and Additions Instruction MI Maintenance Instruction MSPB Merit Systems Protection Board MT Magnetic Particle Testing NCR Nonconforming Condition Report NDE Nondestructive Examination I

.NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission NSB Nuclear Services Branch I

NSRS Nuclear Safety Review Staff NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC) j NUMARC Nuclear Utility Management and Resources Committee f

OSHA Occupational Safety and Health Administration (or Act) j ONP Office of Nuclear Pcwer OWCP Office of Workers Compensation Program PHR Personal History Record PT-Liquid Penetrant Testing 3

QA Quality Assurance 4

QAP Quality Assurance Procedures 4

QC Quality Control 6

QCI Quality Control Instruction 9

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE viii 0F vill QCP Quality Control Procedure QTC Quality Technology Company RIF Reduction in Force RT Radiographic Testing SQN Sequoyah Nuclear Plant SI Surveillance Instruction SOP Standard Operating Procedure SRP Senior Review Panel SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff T&L Trades and Labor TVA Tennessee Valley Authority TVILC Tennessee Valley Trades and Labor Council UT Ultrasonic Testing VT Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant WR Work Request or Work Rules 3

WP Workplans 6

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200-SPECIAL PROGRAM-

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2 PAGE 2 0F 93 4

OUTLINE OF CONTENTS EXECUTIVE

SUMMARY

PAGE 1.0 CHARACTERIZATION OF ISSUES 6

4 1.1 Introduction 6

4 1.2 Description of Issues 6

1.2.1 Unauthorized / Undocumented Work 1.2.2 Craftsmen Doing Engineering Work I

1.2.3 Poor Planning and Coordination 1.2.4 Inadequate Walkdown and Walkdown Information 1.2.5 Poor Quality of Work Packages and Work Package Control 1.2.6 Questionable Engineering Practices ll I

1.2.7 Improper Installation 2.0

SUMMARY

10 2.1 Summary of Issues 10 i

2.2 Summary of Evaluation Process 12 i

1 2.3 Summary of Findings 14 j

2.3.1 Unauthorized / Undocumented Work 2.3.2 Craftsmen Doing Engineering Work 2.3.3 Poor Planning and Coordination

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2.3.4 Inadequate Walkdown and Walkdown Information i

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 3 0F 93 PAGE 2.3.5 Poor Quality of Work Packages and Work Package Control 2.3.6 Questionable Engineering Practices 2.3.7 Improper Installation 2.4 Summary of Collective Significance 18 2.5 Summary of Causes 19 2.6 Summary of Corrective Actions 20 3.0 EVALUATION METHODOLOGY 22 3.1 General Methods of Evaluation 22 3.2 Evaluation Methodologies Established for Individual 23 Issues 3.2.1 Unauthorized / Undocumented Work 3.2.2 Craftsmen Doing Engineering Work 3.2.3 Poor Planning and Coordination 3.2.4 Inadequate Walkdown and Walkdown Information 3.2.5 Poor Quality of Work Packages and Work Package Control 3.2.6 Questionable Engineering Pract.:es 3.2.7 Improper Installation 4.0 FINDINGS 35 4.1 Unauthorized / Undocumented Work 35 4.2 Craftsmen Doing Engineering Work 55 e

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 4 0F 93 L

1 PAGE i

4.3 Poor Planning and Coordination 60 4.4 Inadequate Walkdown and Walkdown Information 66 4.5 Poor Quality of Work Packages and Work Package Control 69 4.6 Questionable Engineering Practices 73 j

4.7 Improper Installation 77 5.0 COLLECTIVE SIGNIFICANCE 78 I

6.0 CAUSES 80 i

7.0 CORRECTIVE ACTIONS 81 7.1 Generic Corrective Actions 81 i

7.2 Site Specific Corrective Actions 81 1

j 7.2.1 Unauthorized / Undocumented Work 83 7.2.2 Craftsmen Doing Engineering Work 91 7.2.3 Poor Planning and Coordination 91 1

7.2.4 Inadequate Walkdown and Walkdown Information 93 j

7.2.5 Poor Quality of Work Packages and Work Package 93 Control 7.2.6 Questionable Engineering Practices 93

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7.2.7 Improper Installation 93 i

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 5 0F 93 PAGE 8.0 ATTACHMENTS 93 8.1 Attachment A " Subcategory Summary Table and List of Concerns" 8.2 Attachment B " List of Evaluators" 8.3 Attachment C " List of Concerns by Issue" e

Construction Subcategory Report 11200 Workplans/ Work Control Executive Summary Summary of Issues This report addresses seven issues that were derived from one hundred employee concerns. The concerns were generally broad in scope and rather than identifying specific hardware deficiencies, the concerns typically focussed on deficiencies in the administrative controls, practices, and procedures governing construction work. The seven issues identified were unauthorized / undocumented work, craftsmen doing engineering work, poor planning and coordination, inadequate walkdown and walkdown information, poor quality of work packages and work package control, questionable engineering practices, and improper installation. Ninety-six of the one hundred concerns were identified at Watts Bar Nuclear Plant (WBN) and, as one might expect, six of the seven issues were potentially applicable to WBN and evaluated accordingly. No Browns Ferry Nuclear Plant (BFN) concerns were included in this subcategory and no issues were evaluated there. Three Sequoyah Nuclear Plant (SQN) concerns were included in the subcategory and four issues were evaluated at SQN. Only one Bellefonte Nuclear Plant (BLN) concern was included in the subcategory but since construction work is ongoing at BLN, every issue evaluated at WBN was evaluated at BLN.

Major Findings The Employee Concerns Task Group (ECTG) evaluation found major work control problems at WBN only.

Four of the six issues evaluated at WBN were determined to be factual and to require corrective actions. These findings indicated that significant programmatic work control problems existed at WBN. This conclusion was explicitly corroborated by WBN construction management and was the impetus for a major overhaul of the WBN site procedure governing work control that was initiated by WBN construction management. The ECTG evaluation at SQN and BLN, however, did not identify significant programmatic problems.

One issue, poor planning and coordination, was a factor in relatively minor problems confirmed to be factual at SQN and BLN.

Collective Significance The ECTG evaluators concluded that the WBN work control program deficiencies represent the failure of management to edequately define the task of work control, the objectives of the work control program, and the critical sources of error that can cause the program to fail. These shortcomings preclude effective monitoring of the work control program and therefore. effective management of the program.

The safety implications of the work control program deficiencies are as difficult to quantify as the safety implications of the concerns included in the subcategory. There are no inevitable hardware deficiencies that result from work control program deficiencies; however, failure to effectively administer the work control program can result in random aberrations in work 8

activities.

3187T Page 1 of 2 l

These problems m:y be significant or individually inconsequential.

In the latter case though, even individually inconsequential discrepancies can have adverse consequences in the aggregate. Therefore, the cited work control deficiencies were considered to be safety-related in a qualitative sense.

However, the ECTG evaluators were not able to identify any specific condition that would be considered a condition adverse to safety.

Causes The proximate causes of the deficiencies identified were typically traced either to procedural inadequacies or failures to execute the procedures as intended. The proximate causes, however, resulted from conceptual shortcomings in the work control program itself cr from f actors that degraded worker's performance such as low morale.

Corrective Actions The ECTG evaluation found that corrective actions had been initiated before the ECTG evaluation to address some of the problema identified. At SQN, installed fuses are being reconciled with design drawings and, at WBN, construction management issued a consolidated work control procedure that addressed some of the concerns included in the subcategory.

However, a need for additional corrective actions was identified particularly in the area of work control program improvements. The major thrust of these improvements is to increase managerial control of the work control process by devising a program performance monitoring system and providing performance data to management on an ongoing basis.

In addition, problems were identified in upper-tier corporate management practices that resulted in inefficient transfer of program enhancements from plant to plant.

In response to the ECTG evaluation, WBN construction management has committed to implement a surveillence program that will monitor the performance of the work control program and provide management with meaningful performance data.

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l WORKPLANS/ WORK CONTROL j

_Erecutive Summary Table #1 i

j ISSUES lSR INS l FINDINGS I

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WORKPLANS/ WORK CONTROL Executive Summery Table #1 ISSUES ISR INS l FINDINGS l

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 0F 93 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction This report addresses 100 employee concerns that have been associated with the concept of work control. The term " work control" in this context is applied to the activities that precede and follow the direct work of building the plant. Correct execution of these activities ensures that the right work is done at the right time by the right individual (s) and is documented appropriately.

The concerns addressed in this report allege that work control activities were either done incorrectly or inefficiently.

Note that the activities in question are primarily DNC activities although there are concerns that involve DNE and ONP activities.

However, DNE and ONP activities addressed more fully in other reports. Therefore, the emphasis in this report is placed on DNC activities and corrective actions.

The following sections detail the concerns and issues addressed in this report.

1.2 Description of Issues 1.2.1 Unauthorized / Undocumented Work BLNDNEEC85-11 IN-85-297-001 IN-86-232-X03 EX-85-048-003 IN-85-410-011 IN-86-266-004 EX-85-052-006 IN-85-579-002 PH-85-001-007 IN-85-019-001 IN-85-847-006 PH-85-035-005 IN-65-046-002 IN-85-850-004 QCI-1.31-7-85 IN-85-046-008 IN-85-915-001 WBP-85-017-006 IN-85-093-001 IN-85-947-003 WI-85-061-001 IN-85-277-001 IN-85-962-003.

WI-85-068-002 IN-85-286-007 IN-86-102-001 WI-85-091-005 IN-85-293-005 IN-86-102-002 WI-85-100-032 IN-85-293-014 IN-86.-103-001 IN-86-103-002 XX-85-077-X04 Thirty-three WBN concerns and one concern at both BLN and SQN were evaluated with regard to this issue. Thirty-one of the concerns were considered generically applicable to BLN. A cummary of the expressed concerns follows:

Craftsmen perform work without all the required authorizing paperwork.

REPORT NUMBER:

11200 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 7 0F 93

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Managers / supervisors / engineers direct craftsmen to perform work without all the required authorizing paperwork.

Work that has been completed is not reflected on life-of-plant documents.

1 QA documents were falsified to cover up unauthorized work.

1.2.2 Craftsmen Doing Engineering Work l

EX-85-082-002 IN-85-293-026 EX-85-085-001 EX-85-104-002 IN-85-349-003 EX-85-105-002

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IN-85-447-003 WBP-86-013-002 EX-85-121-004 l

IN-85-520-003 WI-85-091-006 IN-85-111-001 IN-85-595-003 XX-85-120-006 Thirteen WBN concerns and one Sequoyah Nuclear Plant (SQN) concern were identified that are related to the issue of craftsmen doing engineering work. The cited concerns allege j

that craftsmen are required to perform various engineering i

tasks in order to expedite their work. The allegations are

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paraphrased as follows:

I Engineers ask cet a to resolve problems by whatever l

means available enc f uen justify the work on paper af ter the fact.

(All concerns listed above except as noted below)

Craftsmen are doing engineering work such as " drawing i

logic".

(IN-85-293-026) l Instrumentation is being designed in the field and documented on a sketch. (IN-85-447-003) 1 Craftsmen are expected to find a way to install hangers and then to call engineering to sketch the as-constructed drawing.

(IN-85-349-003, IN-85-520-003, IN-85-595-003, i

WI-85-091-006 XX-85-120-006) 1.2.3 Poor Planning and Coordination EX-85-002-004 IN-85-514-003 IN-86-179-002 IN-85-514-007 IN-86-257-002 IN-85-057-003 IN-85-787-001 IN-86-261-002 IN-85-362-002 j

IN-85-816-002 MAS-86-003 IN-85-377-001 IN-85-978-008 WI-85-091-012 IN-85-409-002 IN-85-978-009 IN-85-437-002 IN-85-999-001 i

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 8 0F 93 Seventeen WBN ccocerns and one SQN concern are addressed within the context of this issua. Typical concerns included in this issue are paraphrased as follows:

Improper seguencinr, of tasks requires excessive rework and delays.

Equipment / component integrity is compromised by rework.

Time and material are wasted by failing to learn from mistakes.

Intentional errors have caused rework and delays Design modifications and material shortages have caused delays Poor coordination between design, construction engineering and crafts caused delays.

1.2.4 Inadequate Walkdown and Walkdown Information IN-85-215-001 IN-86-019-006 IN-85-442-009 IN-86-309-002 IN-85-442-014 Five WBN concerns form the basis for this issue.

The concerns are paraphrased as follows:

The outstanding work items list (OWIL) is not complete.

The craft superintendent arbitrarily adds and deletes items from the list (IN-85-215-001)

The responsible system engineer did not participate in the system transfer walkdown. Outstanding work items were not identified as a result (IN-85-442-009)

Drawings used in unit I walkdowns were not current.

No walkdown group exists.

(IN-85-442-014)

Construction transfer drawings do not agree with operation's transfer drawings.

(IN-86-019-006)

Workplan completion is not verified before the release of the punch list.

Punch list completion verification is performed concurrently with the punch list workplan.

(IN-86-309-002)

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 9 0F 93 i

,f 1.2.5 Poor Quality of Work Packages and Work Package Control EX-85-052-003 IN-85-348-00A IN-85-743-010 EX-85-094-002 IN-85-418-001 IN-85-762-002 EX-85-121-002 IN-85-423-001 IN-85-898-002 III-85-093-001 IN-85-480-006 IN-86-134-001 IN-85-263-001 IN-85-480-007 IN-85-889-N09 IN-85-281-002 IN-85-618-002 IN-86-309-001 i

Eighteen WBN concerns were related to this issue; fourteen of these concerns were generically applicable to BLN.

The concerns allege that work packages issued by construction engineering are deficient in various ways and that the packages are implemented in an uncontrolled manner. The concerns are paraphrased as follows:

Engineers omit essential information and documents from work packages.

F Engineers provide erroneous information and documents with work packages.

j Waltdowns are not conducted before engineering issues j

i workplans.

l Work packages that are split up among several foremen are improperly controlled.

Foremen assigned responsibility tat one work package do not have access to related work e kages.

1.2.6 Questionable Engineering Practices

?

EX-85-053-006 IN-85-286-001 IN-85-397-001 IN-86-270-007 EX-85-058-001 IN-85-388-007 IN-85-728-003 EX-85-058-002 IN-85-388-009 IN-85-670-002 Ten WBN concerns have been related to this issue and five of these concerns were determined to be potentially generic to Bellefonte Nuclear Plant (BLN). Therefore, the Employee Concern Task Group (ECTG) evaluated this issue at WBN and BLN.

These concerns allege that the methods used by construction field engineering units fail to adequately support construction activities. The specific allegations are paraphrased as follows:

Engineers inadequately research work packages (EX-85-053-006) i

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 93

• Engineers allow craftsmen to build whatever is needed and then generate documentation to legitimatize the installation.

(EX-85-058-001)

Engineers avoid writing field change requests (FCRs) when needed.

(EX-85-058-002)

Craftsmen must field route some conduit because' installed equipment interferes with engineering specified routes.

(IN-85-286-001)

Civil engineers do not have the necessary background to label pipe without assistance.

(IN-85-388-007)

Civil engineers cannot support work in unit 1 because they do not have unit 1 security clearances.

(IN-85-388-009)

Unit 1 prints are marked opposite hand and used for unit 2.

(IN-85-397-001)

Engineers do not respond in a reasonable time to craft requests for engineering support.

(IN-85-728-003 and IN-85-670-002)

Engineers do not adequately monitor and control I

construction activities and they allow management l

decisions to stand even when those decisions conflict with I

good engineering judgment.

(IN-86-270-007) l 1.2.7 Improper Installation l

This issue was defined by one SQN concern, XX-85-101-002, I

that states:

" Improper installation of non-nuclear system could' adversely affect public health and safety."

i 2.0

SUMMARY

2.1 Summary of Issues The workplan/ work control subcategory concerns have been subdivided into seven issues: unauthorized / undocumented work, craftsmen doing engineering work, poor planning and coordination, inadequate walkdown and'walkdown information, poor quality of work packages and work package control, questionable engineering practices, and inadequate installation. A brief summary of each issue follows.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200-SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 11 OF 93 2.1.1 Unauthorized / Undocumented Work This issue includes concerns that allege that work was performed without written authorization or that authorized work was not documented properly when completed.

2.1.2 Craftsmen Doing Engineering Work This issue includes concerns that allege that craftsmen are expected to perform engineering work in order to do their jobs. Typical examples are building and installing pipe and conduit hangers and routing conduit and instrument lines.

2.1.3 Poor Planning and Coordination The concerns included in this issue allege that poor scheduling, poor communications, design changes and mistakes have caused delays and rework.

2.1.4 Inadequate Walkdown and Walkdown Information Walkdowns are physical inspections of a system or part of a l

system by a group of engineers, craftsmen, and inspectors I

conducted to identify outstanding work and verify correctness l

of completed work. The concerns in this issue allege that IR2 some walkdowns were not very useful because the system I

engineer did not participate or the drawings were incorrect i

or changes were arbitrarily made in the outstanding work items I

list.

2.1.5 Poor Quality of Work Packages and Work Package Control Engineers compile the information necessary for craftsmen te do a job into work packages. The concerns included in this issue allege that work package information is either missing, wrong, or inaccessible or that work packages are worked by more than one crew.

2.1.6 Questionable Engineering Practices This issue involves perceived inadequacies in the engineering support of construction activities. The CIs expressed a variety of concerns including failing to respond to requests for engineering support, providing poor written directions, assuming tasks for which the engineers were not qualified, and failing to oppose bad management decisions.

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2 PAGE 12 0F 93 2.1.7 " Improper Installation This issue is correlated with only one SQN concern which states that improper installation of a non-nuclear system could adversely affect public health and safety.

2.2 Summary of Evaluation Process The concerns included in the workplan/ work control subcategory were primarily programmatic or generic concerns. The individual concerns were typically expressed as symptomatic of an underlying, sometimes implied, program deficiency. This perception is supported by the lack of detail given in the concerns included in this issue. A review of all accessible files related to all 100 concerns in the workplans/ work control subcategory revealed only 11 concerns that potentially included sufficient details of specific hardware deficiencies to allow evaluation of those specific concerns. The tsiaining 89 concerns were clearly general in nature.

Therefore, one major element of the evaluation process was partitioning the concerns into general issues for analysis and evaluation. The seven issues thus defined were evaluated at WBN, SQN, and BLN if the issue included concerns from those plants or if the issues were considered generically applicable to the other plants.

It should be noted, however, that the category and subcategory these concerns fall into involve work activities conducted under Division of Nuclear Construction (DNC) procedures.

Consequently, work activities conducted by operations or maintenance personnel were specifically excluded from this ECTG subcategory evaluation. For this reason and because no concerns related to DNC workplans/ work control were expressed there BFN workplan/ work control activities were not evaluated. SQN evaluations were j

performed on four of the seven subcategory issues because SQN concerns were raised that were related to those issues. Although only one BLN concern was included in the workplan/ work control subcategory, every issue except improper installation was evaluated at BLN. The ECTG evaluators judged that most of the issues raised were at least potentially applicable to BLN since BLN is still being built and extensive DNC activities at BLN are scheduled.

Most of the workplan/ work control concerns were identified at WBN; consequently, the WBN evaluations were performed first followed by the SQN and BLN evaluations. This approach resulted in a more discriminating, concentrated evaluative effort at SQN and BLN j

because of the experience gained at WBN.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 13 0F 93 In addition to the investigations performed by the ECTG evaluators, reports of previous investigations performed by NSRS investigators and the WBN DNC Project Manager's Office (WBN-PMO) were reviewed where available.

Reports from one of these two sources were available for thirty of the workplan/ work control concerns. These reports served as a useful counterpoint to the ECTG evaluation because they were focused on a single concern.

The primary method of evaluation used by the ECTG evaluators was qualitative analysis. The work control environment at each plant was determined by reviewing the pertinent site work control procedures. At WBN, the evaluators also attended a training class on QCI 1.60, R0, " Work Control" to ensure their understanding of the intent of the procedure. After determining the adequacy of the work control procedures, the ECTG evaluators then interviewed appropriate personnel to corroborate or discount the issues. This methodology was used to evaluate all issues at each plant except for one issue at WBN and BLN.

The unauthorized / undocumented work issue was evaluated at WBN and BLN using qualitative and quantitative analyses. In addition to the qualitative methodology outlined previously, statistical measures of error rates were generated using data available from previous walkdowns and documentation studies. The data sources included:

NRC Inspection and Enforcement Bulletin (IEB) 79-14 walkdowns for pipe support configuration discrepancies, Black and Veatch auxiliary feedwater review findings, a comprehensive WBN work release study conducted by the WBN-PMO, reviews of analyses and corrective actions taken to address several Nonconforming Condition Reports (NCR) documenting configuration control problems, and a small samplin6 of electrical punchlist items to determine if the items had been properly inspected and documented upon completion.

This approach was necessary because of the nature of the unauthorized / undocumented work issue. By definition, no " paper trail" exists documenting such deficiencies. Ilowever, the ECTG evaluators reasoned that if unauthorized / undocumented work did occur then discrepancies between design drawings and as-built drawings, i.e., configuration problems, would result.

Unauthorized / undocumented work would not be the only cause of configuration problems but if configuration problems were shown to be minimal then ene could conclude that unauthorized / undocumented work was minimal.

1 TVA EMPLOYEE CONCERNS REPORT NUMBER:

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REVISION NUMBER:

2 PAGE 14 0F 93 2.3 Summary of Findings 2.3.1 Unauthorized / Undocumented Work The issue of unauthorized / undocumented work was evaluated at SQN, WBN, and BLN.

The SQN evaluation was limited to consideration of one concern dealing with " falsified" drawings. A Nuclear Safety Review Staff (NSRS) report was issued on this concern before the ECTG evaluation and this report is the basis on which the ECTG evaluation was made.

The alleged falsification cited by the CI consisted of a unit supervisor's signature on an "as-built" drawing. The CI said his supervisor signed the as-built drawing after the CI refused to sign the drawing.

Review of the pertinent SQN procedures revealed that no procedural violation resulted from the supervisor's action and consequently no falsification took place. Therefore, the concern was not found to be factual. The NSRS report also indicated that the CI was contacted during the course of the NSRS investigation and that the CI was no longer concerned aoout the issue. Consequently, the ECTG evaluator felt no further evaluation was necessary.

The WBN evaluation addressed 33 concerns correlated with unauthorized / undocumented work. The evaluators reviewed numerous CAQ reports, a WBN management Work Release study, the NRC IEB 79-14 walkdown findings, a Black and Veatch study of the auxiliary feedwater system, NSRS reports on seven concerns and WBN-PM0 responses on three concerns before concluding that unauthorized / undocumented work did occur at WBN with a frequency high enough to prompt WBN management into a wholesale revision of the WBN work control program.

QCI 1.60 is the result of WBN management's effort to address the issue. Therefore, the unauthorized / undocumented work issue was factual for WBN.

The BLN evaluation revealed no evidence of unauthorized /

undocumented work. The rework work releases reviewed were properly handled and QC inspection records were current on all reworked items. The work control procedures were adequate with respect to documentation requirements. Finally, the craft and engineering supervisors interviewed did not believe that unauthorized / undocumented work was a problem at BLN.

On this basis the evaluators concluded that the unauthorized /

undocumented work issue was not factual for BLN.

TVA EMPLOYEE CONCERNS

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REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 15 0F 93 2.3.2 Craftsmen Doint Engineering Work In general, the concerns included in this issu practices involved, i.e., fabricating and installing hangers and routing instrument lines, were unacceptable was wrong.

" Field engineering" is an acceptable and even necessary industry-wide practice providing that the product of these efforts is reviewed for compliance with design requirements.

TVA procedures require that design complia concerns were found to be factual but not CAQs.

Poor Planning and Coordination 2.3.3 The WBN This issue was evaluated at WBN, SQN, and BLN.

evaluation found that there was a WBN mana Consequently, WBN management included elements in QCI 1.60, R0, to address the inadequacies reflected in the WBN.

The WBN concerns were therefore considered factual but did not required further corrective actions.

WBN concerns.

The SQN concern included in this issue was a SQN-specific The concern and therefore not evaluated at WBN ECTG and an investigation was conducted and a resolution The concern was reached before the ECTG evaluation.

determined to be factual and to require corrective action.

The CI was consulted during an NSRS investigation precedin the ECTG investigation and concurred with both t and the resolution.

d plan and schedule and corrective actions have been initiate l

The BLN evaluation of the poor planning and coordination concerns concluded that of the 13 WBN concerns e BLN, 11 concerns were not factual, one was factual but not a CAQ and one concern was factual and requires corrective 2

actions that have not yet been implemented.

4 Inadequate Walkdown and Walkdown Information 2.3.4 This issue was not considered applicable to SQN and was evaluated at WBN and BLN only.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 16 0F 93 The WBN procedures governing transfer walkdowns were found to Interviews with personnel who are normally be adequate.

involved in transfer walkdowns revealed that they were well informed with regard to their procedural responsibilities and that they gave no indications of concern with respect to Therefore, the concern was not found to walkdown activities.

be factual at WBN.

Since none of the concerns included with this issue were BLN concerns, the BLN evaluation was limited to an investigation of potential programmatic deficiencies affecting walkdowns.

A review of the BLN transfer of permanent features program did not identify any significant deficiencies in the transfer This perception was confirmed by interviews with On this program.

the personnel responsible for transfer walkdowns.

basis, the issue was found not to be factual at BLN.

Poor Quality of Work Packages and Work Packages Control 2.3.5 This issue was not considered applicable to SQN and was evaluated at WBN and BLN only.

The WBN evaluation was conducted by determining the documentation standards and controls that apply to work packages and then determining if they were adequate and if they were implemented. The evaluators took a training class on the current work control procedure at WBN, QCI 1.60, " Work Control," and reviewed the work control procedures superceded Interviews were then conducted with 21 by QCI 1.60.

Finally, WBN craftsmen, engineers, and managers.

construction management responses to four concerns and an NSRS report on one concern were reviewed.

The types of problems identified in the concerns were found For to be factual and recognized by WBN management.

instance, there were no specific guidelines on work package size or content in the work control procedures superceded by Large work packages were split up between QCI 1.60.

different crews and problems did result from this practice.

Also, work packages were found to have been incomplete or inaccurate.

The evaluators found that these problems were recognized by

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WBN management and that QCI 1.60 instituted changes in the The main work control program to address these problems.

elements of QCI 1.60 that address these concerns are the 3,000 man-hour limit on workplans and the joint pre-issuance walkdown required of the involved engineer, craft foreman, and inspector.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 17 0F 93 The BLN evaluation of this issue proceeded along similar The procedures governing work control were reviewed lines.

to determine documentation and control requirements and interviews were conducted with three craft foremen, one engineer, and one manager.

The BLN work control procedure was significantly different from the current or former WBN work control procedure (s).

However, the review of the work control procedure and the interviews with the BLN personnel indicated that the WBN A related concerns were not factual when applied to BLN.

problem was identified in that the current BLN work control procedure should be revised to more accurately reflect the current BLN organizational structure.

2.3.6 Questionable Engineering Practices WBN management agreed with the CIs that some questionable engineering practices such as those noted by the pertinent Therefore the concerns were considered concerns occurred.WBN management issued QCI 1.60 to correct factual for WBN.

the problems; therefore, no further corrective actions were required.

The BLN evaluation failed to uncover any evidence of similar The BLN procedures governing the activities cited problems.

3 j

in the concerns were judged to be adequate and the BLN personnel interviewed did not express similar concerns.

Therefore, the issue of questionable engineering practices was not considered factual for BLN.

2.3.7 Improper Installation This issue was defined by only one SQN concern and was not considered potentially applicable to any other plant.

Consequently, the issue was evaluated at SQN only.

The allegation investigated was that improper installation of a non-nuclear system could adversely affect public health and 1

Since there were no specific systems identified by safety.

the CI and no other details were available, the findings are On that derived from the scope of the concern as stated.

basis and interpreting the term "non-nuclear systems" narrowly, the evaluator determined that non-nuclear systems Therefore,'

do not normally perform safety-related functions.

by definition, improper installation of a non-nuclear system e

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 18 0F 93 It is would not adversely affect public health and safety.

possible, however, to interpret the term "non-nuclear systems" more broadly and thereby include soms safety-related systems such as auxiliary feedwater, safety-related electrical power systems, essential air systems and others that do not come into contact with radioactive materials in the category of "non-nuclear systems."

If the CI intended such systems to be included in the scope of his (or her)

However, concern, then the concern could certainly be true.

note that the concern is stated as a policy concern and not as allegation of a specific deficiency.

In that context, TVA has documented the safety significance of all plant features in the SQN FSAR and established design parameters and QA requirements with the intent of assuring TVA's success in the integrity of safety-related systems.

realizing this objective is debatable but the TVA policy on this matter is clear:

systems that are required to protect the safety and health of the public are to be built, maintained and operated with a commitment to quality and in a Therefore, the concern was not found to be safe manner.

factual.

2.4 Summary of Collective Significance One of One hundred concerns were addressed in this subcategory.

these concerns was a BLN concern; three of the concerns were SQN Four of the The remaining 96 concerns were WBN concerns.

concerns.

six issues evaluated at WBN were found to be factual and to require corrective actions. One of the six issues evaluated at BLN and one of the four issues evaluated at SQN were found to be factual and to require corrective actions.

It should be noted, however, that the factual SQN concern requiring corrective actions was not a This was programmatic concern related to the work control program.

not the case with the WBN concerns and the BLN concern.

The WBN evaluations tended to confirm the perceptions of the WBN The work control managers who initiated and issued QCI 1.60: This should not have program at WBN was in need of an overhaul.

been unexpected however, since the concept of work control has evolved continuously since its formal introduction at WBN in 1981.

The evolutionary changes in work control are the results of a trial and error process guided by the need to respond to specific problems and intuitive perceptions of the causes of these problems. Although the trial and error process has worked to a degree, the pervasive WBN work control problems identified in this report illustrate the

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 19 0F 93 need for a better understanding of the work control process than has been achieved to date. Without such a conceptual framework, TVA will remain subject to the vagaries characteristic of the intuitive approach to problem analysis. Development of a work control process conceptual design will allow definition of the fundamental work control tasks and responsibilities and critical sources of error.

This, in turn, will aid in the development of qualitative and guantitative measures that management can use to monitor the work control process in a systematic manner.

2.5 Summary of Causes Since the scope of the work control problems identified at each plant varied widely, the causes of those problems varied in scope from plant to plant as well. Therefore, the causes of the problems are discussed in the following sections on a plant specific basis.

2.5.1 Sequoyah The only significant problem identified at SQN involved the installation and maintenance of control fuses by DNC The CI found discrepancies between the fuses personnel.

denoted on design drawings and the fuses actually installed.

The ECTG evaluation determined that the proximate cause of this problem was the failure to follow work instructions to keep as-constructed drawings up-to-date.

2.5.2 Watts Bar Four of the issues evaluated at WBN were found to represent problems that require corrective action: Questionable engineering practices, poor planning and coordination, poor quality of work packages and work package control, and unauthorized / undocumented work. The causes that contributed to these problems are presented in the following sections.

Unauthorized / Undocumented Work The ECTG evaluators concluded that unauthorized / undocumented work resulted from several independent causes.

Inadeguate work control procedures resulting in unclear, incomplete work instructions, Inadequate review of work instructions issued with work e

releases and punchlists.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 20 0F 93 Lack of an audit and feedback mechanism to measure and monitor unauthorized / undocumented work.

A procedural discontinuity between ONP and DNC procedures that allows ONP to change plant features without updating DNC's test documentation.

Deliberate failure to perform tasks in accordance with established procedures.

Poor Planning and Coordination The problems that relate to this issue were primarily attributable to poor communications between engineers and craftsmen. The ECTG evaluation found that the communications problems resulted from an inadequate definition of responsibilities in the work control procedures in effect before the issuance of QCI 1.60.

Poor Quality of Work Packages and Work Fackage Control The problems associated with this issue involved deficient work package documentation, oversized work packages, and inefficient distribution of work. The proximate cause of these problems was the failure to provide pertinent qualitative and quantitative criteria to guide the preparation and implementation of work package documents.

Questionable Engineering Practices The three concerns that identified problems requiring corrective actions were related to engineering support of field activities. The proximate cause of these problems was engineering's failure to maintain sufficient contact with craftsmen and the work and thereby ensure that the engineers 4

knew what the job requirements and problems were.

I 2.6 Summary of Corrective Actions The corrective actions taken to address the CAQs identified during the ECTG investigation varied from plant-to-plant. A summary of the required corrective actions follows.

Sequoyah Only one issue, poor planning and coordination, was found to require corrective actions at SQN. The problem involved discrepancies between fuse data noted on the design drawings and the installed fuses. To resolve the problem, SQN maintenance personnel will verify that IEEE Class IE and penetration cable protection fuses and

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 21 0F 93 and fuse identification tags match design specifications. Any discrepancies identified will be resolved by Division of Nuclear j

Engineering (DNE) and the drawings revised if necessary. In addition, administrative instruction AI-16 " Fuse control" will be revised to incorporate DNE issued documents and requirements.

Bellefonte Poor planning and coordination was again the only issue evaluated at BLN that requires corrective actions. The BLN personnel interviewed indicated that BLN Standard Operating Procedure (BNP-SOP)-2, " Work Packages," should be revised to reflect the current organizational structure and additional training in work control procedures should be provided to all appropriate personnel.

BLN DNC has committed to revise BNP-SOP-2 to accurately reflect current organizational responsibilities. In addition, a training module on work control and work implementation documents will be prepared and given to DNC employees on an as-needed basis.

Watts Bar Four issues were found to require corrective actions at WBN:

Questionable engineering practices, poor planning and coordination, poor quality of work packages and work package control, and unauthorized / undocumented work. Before the ECTG evaluation, WBN management recognized some of the problems subsequently identified by the ECTG evaluators and issued a new work control procedure, QCI 1.60, that consolidated and updated four obsolete work control procedures. The following features of QCI 1.60 address specific deficiencies identified by the ECTG evaluation.

Engineers are required to maintain daily contact with the craft foremen.

Joint walkdowns by engineering and craft personnel are required before workplans are issued.

The maximum size of workplans is limited so that the work can be completed without splitting the work up among several crews.

Engineering is responsible for checking material availability before the workplan is issued and ordering material if necessary.

Engineering is responsible for specifying the construction tests required for each workplan and updating the tests' status in the Records Accountability Program.

In addition to these program enhancements, DNE now requires that written approval of a Field Change Request (FCR) must to received before the FCR can be implemented.

1 TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 22 0F 93 In addition to the corrective actions specified above, WBN-DNC has initiated programmatic actions required to prevent recurrence that address the collective significance findings summarized in section 2.4.

A work control process monitoring system has been conceptually defined and is bein8 incorporated into implementing procedures.

Information derived from the data gathered by the monitoring system will be provided to project and line managers to allow real-time management of the work control process.

Also, the DNC corporate management staff indicated that the new Nuclear Standards Program currently under development will incorporate features that will facilitate the transfer of program enhancements from site-to-site.

3.0 EVALUATION PROCESS 3.1 General Methods of Evaluation The evaluation process followed by the ECTG evaluators was derived Three from the nature of the concerns included in the subcategory.

characteristics of the concerns defined the scope and direction of the evaluation.

First, the concerns addressed DNC activities, documents, and personnel. DNE and Office of Nuclear Power (ONP) matters were only indirectly involved. Second, the work control Therefore, concerns involve perceived deficiencies in a process.

the deficiencies alleging inadequate execution of the process could not be directly observed and could be evaluated only by examining the paperwork and interviewing the personnel associated with the Finally, the majority of the concerns were expressed given concern.

as generic deficiencies indicative of fundamental program The ECTG evaluators initially intended to evaluate deficiencies.

each concern and determine its validity on an individual basis.

However, with a few exceptions, this approach was not fruitful because of the nonspecific nature of the typical concern.

Consequently, the concerns were separated into groups that These issues were represented seven distinct programmatic issues.

then analyzed to determine what evidence could be expected to exist if the issues did represent actual problems.

For example, one of the issues involved allegations of unauthorized or undocumented If work was performed without authorization or documentation, work.

then the associated documentation would not be available and a Therefore, the ECTG paperwork review would not be productive.

evaluators decided to review configuration control data reasoning that unauthorized or undocumented work would result in an as-constructed configuration that departs from the design configuration.

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2 PAGE 23 0F 93 Other elements common to the evaluation of each issue were reviewing the procedures and criteria pertinent to the work involved and interviewing personnel knowledgeable of the application of those procedures and criteria. Examination of the procedures and criteria established whether or not the concerns documented acceptable practices. The personnel interviews were useful in identifying the problems or strengths of a given procedure or program from an applications perspective.

Another factor that affected the evaluation of the issues was the order in which the plants were evaluated. Since most of the 4

concerns were identified at WBN, WBN was evaluated first. By the time the SQN and BLN evaluations were conducted, the evaluation plans were revised to delete unproductive efforts or to incorporate productive ones. Therefore, there were some variations in the evaluation methodologies used for a given issue as the investigations progressed from plant-to-plant.

3.2 Evaluation Methodologies Established for Individual Issues One of the initial steps taken in the evaluation of an individual l

issue was the determination of the applicability of a given issue to l

plants other than the plant at which the concern was initially 1

identified.

BFN was excluded from consideration for all issues IR2 because no work control concerns were identified at BFN'and because i

no DNC activities were occurring there. Evaluations were conducted I

at SQN for four of the seven issues identified because concerns were l

raised at SQN that were related to those issues. The six issues evaluated at WBN were also evaluated at BLN because BLN is still being built and therefore extensive DNC activities are scheduled there. The following issue summaries note which plants were evaluated for the issue in question.

3.2.1 Unauthorized / Undocumented Work Unauthorized / undocumented work was evaluated at WBN and BLN.

i The evaluation of this issue was directed to answer three basic questions:

Did unauthorized or undocumented work occur? Do current work control pro 5 rams ensure that unauthorized or undocumented work will not occurf If work control problems have resulted in unauthorized or undocumented work, has the scope of the problem been established or is further evaluation necessary?

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2 PAGE 24 0F 93 The first question was answered by several techniques:

Reviewing CAQ reports of unauthorized /ut. documented work, reviewing the findings of a WBN work release study and BLN work releases, review of inspection documentation, and review of configuration control studies.

CAQ reports such as SCRs, NCRs and NSRS reports that identified unauthorized /

undocumented work were strong corroborative evidence of a problem. The WBN work release study documented cases of undocumented work and the examination of inspection records documented cases of undocumented work.

Configuration control problems were quantified by analyzing data available from walkdowns and reinspections conducted by DNC to identify configuration control problems. Details of these programs and findings are given in section 4.1.

The second question was answered by a review of the WBN and BLN work control programs.

In addition, at WBN, the evaluators took a training class in QCI 1.60, " Work Control,"

to facilitate their review. Superceded work control procedures were also reviewed to determine the enhancements incorporated into the current program.

The third question was addressed in conjunction with the first question. Since direct documentary evidence of unauthorized / undocumented work was, by definition, nonexistent, the evaluators felt that the scope of unauthorized / undocumented work could best be estimated by establishing the scope of configuration control problems.

Although configuration control problems could result from problems other than unauthorized / undocumented work, if configuration control problems were found to be minimal then one could conclude that unauthorized / undocumented work was minimal as well. The analysis of configuration control problems was further targeted toward those areas which were felt to be most likely to be subject to unauthorized /

undocumented work such as rework work releases and punch list items in the electrical and pipe support areas.

In addition to these steps, seven NSRS reports and three WBN-PMO reports addressing individual concerns correlated with this issue were reviewed, e

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2 PAGE 25 0F 93 i

i Watts Bar The methodology for this issue evaluation was to answer the following questions:

Did unauthorized work occurf Were there instances of authorized but undocumented work? If so how mucht Is the current WBN work control program good enough to ensure that unauthorized or undocumented work will not occurf Is there evidence to indicate that past work control problems s

have caused a significart configuration control problem that would necessitate further walkdowns, reinspection, and/or rework?

The methods for answering the first question "Did unauthorized /

undocumented work occurf" were as follows:

Reports documenting and listing instances of unauthorized /

'i undocumented work were reviewed. These included Significant Condition Reports (SCRs), Nonconformance Reports (NCRs), and reports done by the NSRS.

(See evaluation steps A, B. D, E F, G and same items under Findings.)

The findings of the work release study were reviewed. This information documented cases where work was authorized but was inadvertently not documented. It also documented cases where workers onceeded the intended scope of the work release because of unclear instructions.

(See evaluation step J, same item under Findings.)

Since there is usually no clear document trail to prove that unauthorized work occurred, another method was employed. This was to look for the results of unauthorized work in the form of configuration problems (configuration problems meaning that the features did not match the drawings.) This method of proving or disproving unauthorized work had its weaknesses, but it was the i

best available method. Its weaknesses were that configuration problems have many more potential root causes than unauthorized work. The only valid conclusions that could be drawn were that 1

if configuration problems were minimal, then the effects of unauthorized, or authorized-but-undocumented work were minimal, when the evaluator did find evidence of configuration control l

problems, an attempt was made to determine the root cause to see If it was unauthorized or undocumented work,

{

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 26 0F 93 Configuration control problems were quantified by evaluating data from previous walkdowns and reinspections.

(See evaluation steps H. I, J. L and same items under Findings.)

A fourth method used to address the question of authorized but undocumented work was to conduct an inspection documentation search. This was done to see if the appropriate inspections were completed after work was finished.

(See evaluation stop K, and same item under Findings.)

The methodology for answering the second question "Is the current work control program good enough to ensure that unauthorized or undocumented work will not occur?", was to review WBN's new work control program. This was outlined by QCI 1.60, " Work Control."

The evaluator also reviewed the procedures it replaced. The review was subjective, meaning that it was based on the evaluator's knowledge and experience regarding the working environment and the types of mistakes that can be mado in processing work control information. For each critical step in the process the evaluator asked, "What could go wrong? What is the probability that it could to wrong?" Deficiencies were noted and justified.

(See evaluation stop C and same item under Findings.)

The third question was "Is there evidence to indicate that past work control problems have caused a significant configuration control problem that would necessitate further walkdowns, reinspections, and/or rework?" The methodology for answering this question overlaps with that for our first question. To reiterato, our only workable mothodology was to look for the results of unauthorized / undocumented work in the form of configuration problems.

Configuration problems were quantified by evaluating data from previous walkdowns and reinspections. The objective was to develop statistical measures that showed, for a set of features, the percentage of inspection points that could not pass reinspection.

The logic was that if configuration problems were minimal, then one could conclude that unauthorized / undocumented work had had a minimal impact. When configuration problems woro found, the root cause was datormined to see if it was unauthorized / undocumented work.

The analysis of configuration problems was targoted toward the areas that unauthorirod/ undocumented work were most likely to have affected. Those were:

s Documentation Problems - Rowork Work Releases Punch 11st Items

)

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 27 0F 93 Configuration Problems - Electrical Instrumentation Pipe supports All of these were explored except instrumentation.

Error rates for instrumentation items were not developed because this problem area has already been well defined and is being addressed by the Instrument Project, a special task group.

A. Reviewed NSRS reports:

Report Concern I-85-669-WBN EX-85-052-006 I-85-360-WBN IN-85-847-006 I-85-513-WBN IN-86-102-001 I-85-427-WBN IN-86-103-001 I-85-428-WBN IN-86-103-002 I-85-674-WBN IN-85-277-001 I-85-623-WBN IN-86-232-X03 B. Hoviewed Project Manager's Office (PMO) responses for the following employee concerns:

IN-85-093-001 IN-85-847-006 IN-86-232-X03 C. Reviewed appropriate procedures and instructions.

QCI 1.30 R10

" Control of Work... unit 1" QCI 1.56 R9

" Work Packages" QCI 1.22 R8

" Transfer... to Nuclear Power" QCI 1.07 R11

" Work Release"

" Work Control" (Replaces procedures listed QCI 1.60 RO above)

Took official training class on QCI 1.60.

Interviewed a representative cross section of engineers, managers, and foremen (22 people) to determine their interpretation of the procedure, e

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2 PAGE 28 0F 93 Reviewed SCR-6497 titled " Inadequate Construction Work Control."

D.

Also reviewed NCRs 6497, 6382, 6530, 6525, 6476, 6526, 6600, 6616, 6613, 6558, 6595, 6604, 6589, 6626, 6440, 6636, 6625, and 6664.

E.

Reviewed SCR 6297 titled "As-Constructed Drawing Program Deficiencies."

Reviewed NCR W-346-P titled " Violation of WBN QCI 1.30 Control F.

of Work on Transferred Systems and Untransferred Systems behind unit 1 Security."

Reviewed NCR 6734 titled "Inadequato Construction Work Control" G.

and 6727 with the same title.

Reviewed IEB 79-14 program deficiencies for pipe supports and H.

developed error or discrepancy rates.

Pulled a 10-percent sample of deficiencies (379 supports) 1.

2.

Categorized deficiencies by type (some supports with multiple deficiencies) 3.

Categorized deficiencies by disposition (used as is or reworked) 4.

Determined number of supports inspected Interviewed 79-14 inspectors regarding inspection criteria 5.

6.

Developed average number of inspection points according to support based on 79-14 inspection critoria. Average support based on 25 support sample (solected as representative by HQC). Drawings for each support usod to determine number of inspection points.

7.

Calculated:

- Percent of inspection points with discropancies

- Porcent of inspection points with discrepancios that were not used as constructed

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM

,r REVISION NUMBER: 2 PAGE 29 0F 93 I.

Reviewed Black and Veatch " Auxiliary Feedwater Review" and

" Evaluation of Black and Veatch Findings." Analyzed pipe support deficiencies and developed an error or discrepancy rate.

1.

Reviewed scope and methodology of review 2.

Interviewed contract administrator 3.

Reviewed discrepancy category reports 4.

Determined number of discropancies not used as constructed 5.

Developed average number of inspection points according to support using same method described in section G-6 6.

Determined number of supports in system 7.

Calculated percent of inspection points with discrepancies that were not used as constructed J.

Reviewed the Work Release Study done in response to audit deviation WB-A-86-02-D03.

1.

Interviewed the study team leader 2.

Determined the scope and methodology of the study 3.

Analyzed error rates established after two-thirds of all unit 2 rework work releases had been reviewed.

K.

Analyzed a 100-item sample of electrical punch 11st items to determine if the items were properly inspected and documented upon completion.

L.

Reviewed NCR W-205-P written by Nuclear Power Operations. The hCR was concerning configuration problems. Analyzed the available electrical discrepancy data and developed an error or discrepancy rate.

1.

Interviewed original walkdown team members to get background.

2.

Interviewed QC group loader who coordinated second walkdown.

3.

Determined approximate number of terminations and number of inspection points e

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2 PAGE 30 0F 93 1

4.

Calculated:

- Percent of terminal points with discrepancies

- Percent of inspection points with discrepancies 5.

Attempted to analyze discrepancies for root cause 6.

Analyzed dispositions of discrepancies 7.

Analyzed root cause of discrepancies by interviews with four individuals who were intimately involved with the engineering construction and inspection of features addressed by NCR W-205-P 8.

Conducted a total of 10 interviews regarding NCR W-205-P M.

Conducted two meetings with Construction and Power Operations j

personnel to discuss their perceptions of the problem and their action plans.

3.2.2 Craftsmen Doing Engineering Work This issue was evaluated at SQN, WBN, and BLN. The evaluation methodology used at each plant is outlined below.

1 Watts Bar Interviews were conducted with engineering personnel to determine the engineering practices on problem hangers.

Eight craft supervisors, four engineers, and ten engineering managers wore interviewed.

Plant procedures WBN QCP 1.13. Revision 14. "FCRs," dated October 25, 1985 and WBN QCI 1.28 Revision 6. " Variances,"

4 dated May 7, 19P5, were reviewed to determine if they adequately addressed the resolution of problem hangers including field fabricated hangers.

In addition, DNE's policy on the design approval of field fabricated hangers as expressed in DNE's policy memo issued by W. C. Drotleff, i

Director of DNE, to the sites and dated April 4, 1986, was reviewed.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 31 0F 93 Finally NSRS Report I-85-194-SQN. " Hanger Drawings Made and Design Completed After Hanger Fabrication and Installation."

was reviewed to determine the applicability of the SQN disposition to WBN.

Seouoyah The SQN evaluation addressed three SQN concerns that dealt specifically with the installation of hangers. Installations that varied from design specified locations by an amount greater than applicable design tolerances were alleged to have been improperly handled.

The expurgated QTC flies on the subject concerns were reviewed for additional information. Knowledgeable personnel, who were involved in the installation of SQN pipe supports, were interviewed to verify or disprove concerns about hanger installation. NSRS reports I-86-194-SQN and I-85-925-SQN were reviewed to determine if they adequately addressed the perceived problem of craft designed hanger installations.

Bellefonte BLN plant procedure BNP-QCP-6.17. Revision 14 " Seismic Support Installation and Inspection," dated June 12, 1986, was reviewed to determine if it adequately addressed the issue of making fleid installations without having a controlled drawing in hand.

BLN plant procedure BNP-QCP-4.3, Revision 13. " Instrument Tubing Installation," dated June 25, 1986 was reviewed to determine if it adequately addressed the subject of field routing instrument lines.

Two hanger engineers and two civil engineers were interviewed on the subject of craft designed hangers. One steamfitter superintendent was interviewed about craft designed hangers.

One instrumentation engineering supervisor was interviewed about fleid routed instrument lines.

3.2.3 Poor Planning and Coordination This issue was also evaluated at SQN, WBN and BLN. The evaluation methodology used at each plant is outlined below.

e

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11300 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 32 0F 93 4

Watts Bar The ECTG evaluators attended a training class on WBN QCP 1.60 Revision 0, " Work Control," to become familiar with the standards established for the planning and coordination of work.

In addition, the evaluators reviewed WBN-QCP-1.30

" Control of Work on Transferred Systems and Untransferred Systems Behind Unit 1 Security " WBN QCP-1.56, " Work Packages," and WBN-QCP-1.07, " Work Releases," all of which were replaced by QCI-1.60, to determine the procedural environment affecting planning and coordination of work prior to the issuance of QCI-1.60.

The ECTG evaluators also interviewed eight craft supervisors, three engineers, nine engineering supervisors, and three QC supervisors to determine how planning and coordination of work is actually conducted.

Finally, WBN construction management responses to five of the concerns included in this issue were evaluated to determine if they adequately addressed the issue.

Sequoyah The SQN evaluation was confined to consideration of the single SQN concern included in this issue, KAS-86-003. The ECTG evaluators discussed the concern with knowledgeable electrical maintenance personnel to determine the scope and specifica of the concern.

In addition, the workplan under which the work in question was performed, workplan 10512, was reviewed to determine the content of the plan and the areas covered.

Bo11efonte The ECTG evaluators reviewed the BLN procedures that affect the subject concerns. The procedures reviewed were BNP-SOP-2, Rovision 5, " Work Packages," dated April 8, 1985 BNP-QCP-5.3, Revision 10 " Concrete Placement," dated July 23, 1985, and BNP-QCP-6.18, Revision 5. " Metallic and Non-Metallic Thermal Installation," dated October 8, 1985.

The evaluators then interviewed two craft superintendents.

two engineers, one engineering supervisor, five QC inspectors 4

and two QC supervisors to determine the appilcability of the concerns in light of the BLN work environment.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 33 0F 93 3.2.4 Inadequate Walkdown and Walkdown Information This issue was evaluated at WBN and BLN. The evaluation methodologies used at these plants are detailed below.

Watts Bar The ECTG evaluators reviewed the transfer of permanent features program as described in WBN-QCI-1.22. Revision 8

" Transfer to NUC POWER," dated December 21, 1984, to determine the method of accomplishing transfers and the role that walkdowns serve in the transfer program. WBN-QCI-1.25 Revision 8 " Control of As-Constructed Drawings," dated October 16, 1984, was reviewed to determine how as-built features that are not installed or operational within a transferred boundary are depicted (re:

paragraph 6.3.4.1.5).

Startup, testing and coordination unit (STCU) personnel were interviewed to determine if they were aware of their responsibilities and procedures pertinent to the transfer program and the resolution of configuration control problems.

Nuclear Services Branch (NSB) personnel were interviewed to determine the approach being taken to resolve configuration control problems.

Bellefonte Bellefonte procedure BNP-QCP-9.2, Revision 10. " Transfer of Permanent Plant Equipment, Systems, or Structures to the Division of Nuclear Power," dated March 21, 1985, was reviewed to determine the method of accomplishing transfers.

BNP-QCP-9.3, Revision ll, " Configuration Drawing Control,"

dated February 24, 1986, was reviewed to determine the method for documenting the as-built status of transferred features on as-built drawings.

Completions Unit personnel were interviewed to determine what was required to transfer permanent features.

3.2.5 Poor Quality of Work Packages and Work Package Control This issue was evaluated at WBN and BLN. Th1 evaluation methodology used at each plant is detailed below.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 34 0F 93 Watts Bar Current and superceded WBN work control procedures were reviewed to determine if the subject of work package composition, distribution, and control were adequately addressed.

In addition to reviewing the current work control procedure, WBN-QCI-1.60, the ECTG evaluators took a training class in QCI 1.60 to better understand the history of work control at WBN and the intent and implementation of QUI 1.60.

In addition, the work control procedures that were replaced by QCI 1.60, e.g., QCI 1.30, QCI 1.56, and QCI 1.07, were reviewed to further develop an understanding of the historical handling of work packages.

Eight craft supervisors, three engineers, nine engineering supervisors, and three QC supervisors were interviewed to elicit their comments and observations on the subject concerns.

Finally, WBN construction management responses to two of the subject concerns and NSRS reports on two of the subject concerns were reviewed to determine if they adequately addressed the issue.

Bellefonte BLN standard operating procedure SOP-2, RS, " Work Packages,"

dated April 8, 1985, was reviewed to determine how work packages are compiled, distributed, and controlled at BLN.

One engineer, one engineering supervisor, and three craft supervisors were questioned about their responsibilities under SOP-2 and the handling of work packages under SOP-2.

3.2.6 Questionable Engineering Practices This issue was evaluated at WBN and BLN. The evaluation methodologies used at each plant are detailed below.

Watts Bar WBN procedures that cover the engineering practices cited in the concerns were reviewed. WBN QCI 1.60, " Work Control "

was reviewed to see if it adequately addressed engineering control of field work in progress. QCI 1.02, Revision 15

" Control of Nonconforming Items," dated November 1, 1985, was reviewed to determine the method to be used for nonconformances that deal with "use-as-is" situations.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 35 0F 93' An electrical craft supervisor was interviewed to determine conduit installation practices. One hanger engineer was interviewed to determine if FCRs were written on request or if they were investigated first. A staff engineer in the construction engineer's office was interviewed to clarify the security clearance status of construction engineers. One instrumentation engineer and one document control unit employee were interviewed to determine how the records accountability program is maintained.

Finally, WBN construction management responses to two concerns were reviewed to determine if they adequately addressed the concerns.

3.2.7 Improper Installation This report was evaluated at SQN only. The issue was defined by one SQN concern that was not considered generically applicable to any other plant.

The expurgated QTC files were reviewed in an attempt to clarify the nature of the concern. The findings on other work control issues were also reviewed to further define the problem.

4.0 FINDINGS 4.1 Unauthorized / Undocumented Work Thirty-three WBN concerns, one SQN concern, and one BLN concern which are listed in section 1.2.1 have been correlated with the issue of unauthorized / undocumented work. The perceived problems included in this issue are work being performed without documented authorization and failure to document work performed on permanent plant records. Typical concerns are paraphrased as follows:

Craftsmen perform work without all the required authorizing paperwork.

Managers / supervisors / engineers direct craftsmen to perform work without all the required authorizing paperwork.

Work that has been completed is not reflected on life-of-plant documents.

QA documents were falsified to coverup unauthorized work.

TVA EMPLOYEE CONCERNS

-REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 36 0F 93 The single SQN concern was evaluated at SQN since DNC activities at SQN are minimal; therefore, the potential for generic applicability of the WBN concerns to SQN is minimal. The BLN evaluation, however, was conducted to assess the full range of concerns included in the issue. The evalustion methodology and findings pertinent to each plant are presented in the following sections.

Summary of Findings (Note:

the Alpha characters correspond with those for the methodology)

A.

Review of NSRS Reports Reports I-85-513-WBN, I-85-427-WBN, and I-85-428-WBN concerned fire breaches without proper documentation or authorization.

Two were in their words "not substantiated."

One was " substantiated" and the error was subsequently repaired.

I-85-674-WBN dealt with alleged unauthorized work. The NSRS report said that this concern was "not substantiated."

I-85-360-WBN dealt with " bootleg" work packages (meaning unauthorized).

The NSRS report said that this was

" substantiated" through interviews with foremen. Their findings were that construction personnel performed " preliminary" work such as procuring material, installing concrete anchors, bending conduit, and prefabricating conduit supports before workplan approval. The NSRS report stated that despite this they found "no condition adverse to quality." The final Construction Manager's response was that they would overhaul their work l

control procedures. This resulted in QCI 1.60 which significantly tightened control of work authorizations.

i I-85-623-WBN dealt with whether or not an NCR should be written if an FCR is misincorporated. The concern in NSRS words is "not l

substantiated." The PMO response followed the same line of reasoning.

I-85-669-WBN dealt with conduit being removed without i

documentation being updated. NSRS found the claim "not substantiated".

l l

The evaluator concluded that the NSRS evaluations were well done and does not find fault with their conclusions. The evaluator j

feels that construction's final responses were appropriate, i

l l

I

TVA EMPLOYEE CONCERNS REPORT NUMBER: -11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 37 0F 93 B.

Reviewed Project Manager's Office (PMO) Responses Regarding IN-85-847-006, this was covered in item A as a response to NSRS Report I-85-360-WBN.

Regarding IN-85-093-001, PM0 was unable to respond directly to the concern for lack of details.

Regarding IN-86-232-X03, this was covered in item A in conjunction with NSRS Report I-85-623-WBN.

C.

Reviewed Appropriate Procedures and Instruction.

The new work control procedures have been analyzed and compared to the procedures they replaced.

The evaluators also attended 4

the training class for the new QCI 1.60 and interviewed a representative cross section (22 people) of managers, engineers, inspectors, and foremen regarding work control procedures.

The key differences between the old and new work control procedures as they relate to this element are:

1. The number of different ways to authorize construction work was greatly reduced. Under the old procedures work could be done via work packages, workplans, work releases, and punchlists. This variety of options made it more difficult to track and control work. Work releases and punchlists in particular had a higher probability for missed inspections because of the less formal process. This led to situations where work would be authorized but might not be inspected.

Under the new procedure, there is only one formal way to authorize work and this is by the workplan. There is less probability that inspections will be missed because:

- The inspections required must be listed in the workplan.

- If the work is in unit 1, ONP will review the plan.

- The responsible engineer and craft foreman must sign off upon closure that all field work and inspections listed have been completed.

2. The size of the workplan has been limited.

Future workplans must not exceed 3,000 man-hours. In the past, bulk packages presented tracking difficulties and it was easier for the inspection requirements and test statusing to be overlooked.

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2 PAGE 38 0F 93 The results of the interviews of managers, engineers, inspectors, and foremen showed that there is a good consistency of interpretation of the new procedure itself, and of the reasons it was written. All interviewees appeared to understand that WBN must give work control a higher priority than in the past.

The training class attended by the evaluators on QCI 1.60 was very well conducted.

It provided a history of work control at WBN and explained how the site developed a problem with work control. The instructor clearly communicated the new emphasis on work control and added illustrations to the words of the procedure.

After reviewing the new construction work control procedure, the evaluators conclude that the procedure will significantly strengthen Construction's ability to control work at WBN.

It should reduce the probability of inspections being missed.

However, the work control program does appear to have some weaknesses. These concerned unauthorized work and the establishment and statusing of tests.

Regarding tests, the evaluators see as a potential weakness the fact that there is little or no formal review of whether or not the engineer has listed the right inspections or tests in the workplan. There are about four ways where such a mistake might be caught, the pre-issue walkdown with the foreman, the ONP review (if work is on transferred features),

the QC inspection, or a QA audit.

All but the first of these were available with the old i

procedure. The more significant of the two problems, is that DNC has not increased the assurance that the Records l

Accountability Program (RAP) will be properly statused.

Signoffs have been added to the sheets that document tests required and status changed, but no additional audit feature j

or third-party review has been added to catch or measure such i

errors. Such errors have been a problem in the past. This I

weakness should be addressed.

l Regarding unauthorized work, the procedure does address it from the standpoint of improving the quality and completeness of the work instructions. This should reduce those instances of unauthorized work due to misunderstood instructions.

i l

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m TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200-SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 39 0F 93 However, the evaluator sees a weakness in terms of feedback to management regarding the extent and frequency of

~

unauthorized work occurrences. There is a need for an in-process audit program to reduce the probability that I

unauthorized work will occur and to provide prompt feedback i

'to management'when it does occur.

~

D.

' Reviewed Significant Condition Report SCR-6497 SCR-6497 was titled " Inadequate Construction Work Control." The report contained 18 NCRs and described a condition of

" Unauthorized work performed on documented features resulting in

-discrepancies between the as constructed condition and

. documentation as reflected by the RAP.

The report mentioned 96 NCRs written on this subject from 1983 through February 1, 1986, that have been identified by our trend analysis.

i Of the 18 NCRs reviewed, 9 were electrical 3 were pipe related, 3 were on pipe supports, 2 instrumentation, and 1 on concrete chipping. Four-of the 18 were definitely a result of unauthorized work. ' Thirteen of the instances were probably caused by unauthorized work but this could not be definitely established. One was caused by engineering failing to_ realize that a particular hanger location would be moved out of tolerance by moving a pipe. In summary, these 18 NCRs document' l

17 cases of probable unauthorized work.

It was via this SCR that construction announced its conclusion that a work control problem existed. Out of it came QCI 1.60 Revision 0 " Work Control," which was a major overhaul of their work control program.

The evaluators concur with the SCR's root cause descriptions and actions required to-prevent recurrence with two exceptions. It is felt that the corrective actions do not adequately address root cause item 2, which deals with craftsmen doing work without authorization. This was mentioned previously in item C.

There was also the root cause statement about work done under the scope of AI-8.5, an ONP procedure.

This is concerning the fact that it is possible for ONP l-personnel to perform work without addressing the possible impact i

on items documented under the construction records l.

accountability program. This item has resulted in confusion i

regarding whether or not unauthorized work actually occurred.

It could result in NCRs being written when authorized work j

occurred. This issue must be addressed by OMP.

l l

l

TVA EMPLOYEE CONCERNS

~

REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 40 0F 93 There is also the issue of whether or not this SCR should be considered generic to unit 1.

This has been reviewed by ONP management and their response, essentially, was that it was not.

The evaluators do not agree based on the following logic:

Unit I was built by the same people using the same procedures as unit 2.

Secondly, there is the issue mentioned in the root cause of the SCR about work done under AI-8,5 discussed in the preceding paragraph.

Third, there were NCRs (in the 96 written on work control since early 1983 mentioned in the SCR) that pertain to unit 1.

Fourth, SCR 6297 has been written and covers unit 1 configuration control problems.

Configuration control problems can be caused by unauthorized or undocumented work.

It is felt that these two SCRs overlap to a degree.

E.

Reviewed Significant Condition Report SCR 6297 - Configuration Control This SCR was written for unit 1.

It contains 20 NCRs documenting instances where drawings do not correctly depict the existing configuration of installed features.

As of this writing, SCR 6297 has not been completed and cannot be finally reviewed.

However, assuming that the description of condition will not change, the evaluator feels that there was some overlap between SCR 6297 and SCR 6497 which was discussed in item D.

SCR 6297 is concerned with configuration control and 6497 is concerned with work control. Configuration control problems can be caused by work control problems but work control problems are only one of several possible causes of configuration control problems.

During our consideration of configuration control problems as a symptom of work control problems, it was concluded that there are a variety of possible causes.

These include, but are not limited to:

1. Construction work control problems.

2. Modifications and maintenance work control problems.

3. Inspection errors.

4. Misincorporation of FCRs on the drawings.

S. Outstanding FCRs (not yet incorporated).

6. Deviations between vendor hardware and vendor drawings.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 41 0F 93

7. ECNs mistakenly issued "for documentation only" that actually require hardware or labeling changes in the field.

8. Workplans, or other work authorizing documents, remaining open for extended duration.

9. Inadequate inspection criteria in early stages of construction.

Many of these issues were discussed in an informal memorandum from the Site Services Director to the Site Director, dated January 23, 1986, " Configuration Control Task Force" (see copy in case file).

F.

Reviewed NCR W-346-P This NCR was titled " Violation of WBN-QCI-1.30 - Control of Work on Transferred Systems'and Untransferred Systems behind unit 1 Security."

This NCR was added evidence of work control problems in that a workplan was reopened after being signed off as complete. This is clearly a violation of this procedure.

G.

Reviewed NCRs 6734 and 6727 Both NCRs were titled " Inadequate Construction Work Control" and both were added evidence of work control problems. NCR 6734 documented a case where temporary welds were made to permanent plant features. NCR 6727 documents loose bolts found in the b;seplate of a documented hanger.

H.

Reviewed 79-14 program deficiencies for pipe supports to develop-discrepancy rates, j

Because of their complexity, pipe supports were the nonfunctional feature most likely to show evidence of configuration _ problems. It was decided that the discrepancy data from the 79-14 walkdown could be used to devolcp an error or discrepancy rate. The evaluator used a calculation method similar-to that used in the Braidwood Construction Assessment Program (BCAP) to arrive at the percent of inspection points with discrepancies. The methodology is described in section H.

The results of the analysis were as follows:

12 4

i i -

1. Percent of inspection points with discrepancies.

31 (There were an average of 20 inspection points i

per support based on the 79-14 inspection criteria) i L

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2 PAGE 42 0F 93 2.

Percent of inspection points with discrepancies

- 1.2%

that were not used as constructed after engineering evaluation.

One point two percent is an acceptable deficiency rate. This evidence suggests that there is not a significant configuration problem with pipe supports.

This in turn is evidence that past work control problems did not leave a safety significant configuration problem with pipe supports.

Note: All discrepancies identified during the 79-14 program oither have been fixed or are scheduled to be fixed.

I.

Reviewed the Black and Veatch " Auxiliary Feedwster Review" The Black and Veatch review was narrow in scope nnd covered only one system. Its main thrust appeared to be a review of the design and design process, but it did include a rather thorough walkdown of this system's pipe supports. The resulting data was used to calculate a discrepancy rate.

This analysis followed the same logic and path as the 79-14 data analysis. The methodology, assumptions, and purpose were the same.

The results of the calculations were as follows:

Percent of inspection points (assuming an

.071 average of 76 per support) with discre,pancies that could not be used as-is after engineering evaluation.

This discrepancy rate supports the findings of the 79-14 analysis. This is an additional layer of evidence that past work control problems did not leave a safety significant configuration problem with pipe supports.

Note: All discrepancies discovered during this review have either been fixed or are scheduled to be fixed.

8

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 43 0F 93 J.

Reviewed the data from the work release study.

Since work done on work releases has proven to be a weak area in terms of work control, the discrepancy data from this study should be a key indicator of the extent and seriousness of the work control problem.

The work release study was done in response to audit deviation WB-A-86-02-D03.

The study scope was a review of all rework work releases written for unit 2.

The study team reviewed each work release and recorded any procedural deviation. The deviations included whether or not the required inspections were specified with QCP number and revision level, and whether or not the engineer coordinated with other engineering disciplines. Thef also reviewed to see if the work releases were routed to the Authorized Nuclear Inspector (ANI) on code items, and N r ather clerical details. Deviations were noted and followed up with checks to see if inspections were complete, if documents could be retrieved, and if field walkdowns or reinspections were appropriate.

As of April 1, 1986, the study was 70-percent complete. The data at this point showed:

1.

Ihree percent of the work releases showed a failure to follow procedure that will require reinspection of the feature in question.

2.

An additional 41 percent showed some degree of failure to follow procedure, but do not require reinspection.

The three percent discrepancy rate is higher than is l

desirable but it does not indicate a condition that warrants l

a full scale construction assessment program, or large scale lR2 configuration walkdown. Some of the items in the three l

percent will be reinspected and accepted, and some undoubtably l could be deemed not safety significant after further engineering evaluation.

Note: All discrepancies discovered during this study either have been resolved or are scheduled for resolution.

K.

Electrical punchlist documentation sample.

It was determined that punchlist work, done before transfer, was another area proven to be weak in terms of work control.

The most likely work control error to occur on punchlisc work was that an inspection would be missed if the engineer failed

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 44 0F 93 to specify the required inspections or if he failed to " bump" (i.e., indicate that additional testing or inspection was required) the test levels in the records accountability program.

To test the degree to which this problem existed, the evaluator pulled a 100-item sample from punchlists for unit 1.

Electrical punchlist items were chosen because it was felt that the electrical area had a high probability for mistakes.

Unlike hangers or pipe welding, where the craftsmen calls for an inspection, electrical inspections are requested by the engineer, usually in bulk.

Of the 100 identifiers in the sample, 23 identifiers had been deleted or changed to non-QA. Of the remaining 77, documentation was found for all but one. This one item was a handswitch which had been installed and inspected two years earlier. It is suspected that it was mistakenly put on the punchlist and was signed off the punchlist later when it was found to already be bought off, meaning no work was done.

Thus the" discrepancy rate was either 0 or 1.3 percent at worst.

The evaluator concluded that the 1.3 percent error rate was acceptable. The data, although not sufficient in volume to be wholly conclusive, indicated no significant problem with electrical punchlist work.

L.

Reviewed NCR W-205-P concerning unit 1 control room configuration problems.

e NCR W-205-P provided what was initially the most disturbing information found during the evaluation. The initial data indicated unacceptable deficiency rates. However, a detailed analysis of the situation uncovered clear and addressable j.

root causes not related to work control, l

NCR W-205-P grew out of what was originally intended to be a ONP Power configuration walkdown covering BFN, SQN, and WBN.

Because of task force schedule problems at the first two plants, WBN conducted its own sample walkdown. The deficiency rates indicated a problem area in the control room electrical panels. As a result NCR W-205-P was written. The disposition of the NCR was a large scale configuration walkdown of approximately 40 electrical panels in the main i

and auxiliary control rooms.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 45 0F 93 Using the deficiency data from the walkdown, the evaluators calculated a discrepancy rate. Twenty-one panels were chosen as a representative 50 percent sample. This data indicated the following:

Number of discrepancies 3,675

=

Number of terminations inspected

= *8,400 Average number of inspection points per termination

= 3.5 Percent of inspection points with discrepancies 3.675 x 100 " 12.5%

=

8,400 x 3.5

• Estimated, considered to be accurate plus or minus 20 percent Note: All discrepancies found as a result of these walkdowns have been fixed.

A very peculiar _ feature of these discrepancies was that 92.8 percent of them dealt with labeling problems. These were mainly terminal block strip labeling and wire labeling problems. Physical damage made up 3.9 percent, and configuration problems (mainly wire on wrong terminal) 3.3 percent.

The majority of the physical damage items were nicks or scratches on wire insulation. Most of these were dispositioned to be used as is.

Other problem areas were improper crimps and bare wire showing near the lugs. About two-thirds of these were dispositioned to be used as is by an engineering evaluation.

A review of 50 percent of the Maintenance Requests (MRs) used to disposition all discrepancies revealed the following:

41 percent were reworked (most were labeling changes) 24 percent dispositioned by a drawing change 35 percent were dispositioned to be used as is In our discrepancy rate calculations for nonfunctional items, we treated a drawing change as a use-as-is disposition. On electrical or other functional items this logic is not appropriate. This is because electrical maintenance is a i

more frequent occurrence, and because electrical troubleshooting is very dependent on drawings.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 46 0F 93 Therefore, our adjusted discrepancy rate was:

Percent of inspection points with discrepancies not used as-is (12.5% x.65) = 8.l' percent.

The next step was to attempt to further translate this deficiency rate. After interviewing several cognizant individuals including the inspectors who did the walkdown, the evaluator concluded that the data was clouded with deficiencies that did not constitute a QA violation. One example is where the drawing showed a jumper on one side of a terminal block and it was installed on the other. These and other similar items were written up as discrepancies.

Many of these items were not considered discrepancies by the electricians or Construction inspection persocnel that were interviewed. Some, but not all of these items, were later dispositioned by maintenance as not being a discrepancy. The item concerning the jumpers is not a discrepant condition by any construction procedure.

Another issue concerning exactly what constitutes a labeling problem has to do with vendor wiring. There appeared to be a wide variety of labeling schemes on vendor wiring. The evaluator did not succeed in determining how many vendor items were written up or how many of them were questionable in terms of being significant. Some of the discrepancies were that extra labels or tags were present but not shown on the drawings. In some cases it was shown that these were additional information tags added for clarification purposes and did not constitute a potentially confusing scheme.

Some of these tags were removed.

The evaluator attempted to determine how many of the discrepancies fell into this doubtful category, but the effort required was extreme. This part of the effort was dropped because it was not crucial to the evaluation.

However, based on a limited search for doubtful discrepancies, the evaluator felt that even without them the discrepancy rate would still have been too high.

The main question at this point of the evaluation was how did so many discrepancies occur? The key to the answer lay in the peculiar distribution of the discrepancies among the categories. There were relatively few problems where a wire i

was on the wrong terminal and 92.8 percent of the problems

)

1

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 47 0F 93 were with labeling. The work had obviously been either well done and/or well inspected or there would have been more problems with items wired wrong. This led the evaluator to believe that there was an inspection criteria problem with regards to labeling. After a considerable number of interviews the following conclusions were drawn:

Inspection criteria for labeling of terminal block strips 1.

was essentially nonexistent when these panels were installed. In the early years of the project, an agreement was made between Construction and ONP that Construction would wait until just before transfer to install or update terminal block identification strips.

The electrical inspectors were required only to verify that each wire was attached to the appropriate terminal (e.g. one through 12). In many cases the terminal block strips were not installed when the inspection was made.

The strips were later made up and installed by the electrical craft. Thus, most of these labels were never inspected prior to this walkdown.

2.

The great majority of the wire labeling problems were on vendor wiring (often called internal wiring). Almost all field wiring is color coded and not labeled with tags. In the early years of the project a policy was made that TVA would not inspect vendor wiring since each vendor had a i

certified QA program. Thus, TVA never inspected vendor wire labeling before this walkdown.

3.

TVA has had, and continues to have a problem with Engineering Change Notices (ECNs) that are categorized i

i l

"for documentation only." To fit this category they must l

not require physical changes to plant features. After these control panels were installed, TVA received many i

ECNs with terminal block strip label changes mistakenly categorized "for documentation only." These changes were missed by construction engineers because of the ECNs category.

Since terminal block strip identifiers and wire ID tags made up the large majrrity of all deficiencies, the above findings are the essential root cause of the configuration problems f

addressed by this NCR. There was no evidence that problems with work control caused these deficiencies.

Regarding corrective actions for the three root cause items discussed, the following steps have been taken.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 48 0F 93 1.

Inspection procedures now in effect do cover labeling for electrical items.

2.

Vendor wiring in unit 2 main control room panels is now scheduled to be inspected.

3.

The electrical engineer now in charge of the main control room for unit 2, reviews all ECNs, regardless of category for labeling changes.

Possible deficiencies that may require line management action are:

- 1.

The inspection criteria for labeling of. vendor wiring is 4

It leaves the inspector to interpret what is vague.

" appropriate." Plus, this criteria covers only field modifications or vendor modifications. There is no labeling inspection criteria for other vendor wiring.

I 2.

The evaluator is sure that many vendor wired panels have not been inspected and are not scheduled to be inspected.

3.

The evaluator is not sure if all electrical engineers are reviewing " documentation only" ECNs. Also we should address the fact that DNE is improperly categorizing some of these ECNs.

M.

Two meetings were conducted with Construction and Power Operations personnel.

These two meetings were held to discuss perceptions of the problem and possible actions plans being considered.

To summarize the meetings it can be said that Construction personnel continued to maintain their position as stated in SCR 6497 concerning unit 2.

Nuclear i Power representatives from modifications contended that I

the SCR was not generic to unit 1, and that no further I

action was required on their part. The evaluator took lR2 exception to this last conclusion and proceeded to I

evaluate both units 1 and 2.

For further comment on this l

item, refer back to Section 4.1-D.

l

==

Conclusions:==

All of the employee concerns in this issue which could be addressed individually were adequately addressed by NSRS reports.

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REPORT NUMBER:

11200 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 49 0F.93 x

Q.

Did unauthorized work occur? If so how much?

A.

Yes. SCR 6497 documented four cases which were definitely unauthorized work,~plus 14 more that were.

probably because of' unauthorized work. NCRs 6734 and 6727 documented two cases that were definitely l

unauthorized work.. The seven NSRS reports reviewed found two " substantiated" cases of unauthorized work. This is l

a total of 22 cases of unauthorized work documented.

Q.

Were there instances of authorized but undocumented i

work? If so how much?-

A.

Yes. The Work Release study, as of report issue, showed that 3 percent of 4198 (.03 x 4198 = 126) work releases 1

did not have inspections. documented. The inspections were either, not completed or not documented.

I Q.

Is there evidence to indicate that past work control problems have caused a significant configuration control problem that would necessitate further walkdowns or reinspection?

A.

No.

Tae second phase of this evaluation was to determine-l the extent to which past work control problems have r

affected test documentation reliability and configuration.

control. This was done by looking at NCRs, SCRs, existing walkdown data..and documentation studies. The data to be analyzed was. chosen from areas where work l-control problems were expected to be the worst. The i

instrumentation and welding areas were excluded because

~

other groups are addressing them as special categories.

We found no evidence to suggest that past work control problems have caused a significant configuration control-

[

I problem. All of the data reviewed showed acceptable deficiency rates except for an electrical labeling l

problem; but this set of deficiencies did not have poor work control as root cause. However, it must be i-understood that this evaluation was not an attempt to address the entire spectrum of problems that can cause configuration control problems; neither was it an attempt to qualify the configuration of the entire plant.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 50 0F 93 Q.

Is the current Watts Bar work control program good enough l

to ensure that unauthorized or undocumented work will IR2 not occur?

l A.

The new work control procedure QCI 1.60 recently implemented as a result of SCR 6497 was a major improvement over the procedures it replaced. The new procedure will significantly strengthen management's ability to control work in the future.

However, there are three areas of potential weakness in the work control program. They are as follows:

1.

This item is in regards to the establishment and statusing of tests (inspections).

There is a need for a formal audit of work plans before issue to insure that the proper test c'equirements have been established, and upon closure to insure that the records accountability program has been properly changed.

It is the evaluator's opinion that TVA's past deficiencies on these items existed primarily because management did not insure performance of these tasks by closely monitoring and measuring performance.

2.

Regarding unauthorized work, the procedure does address it from the standpoint of improving the quality and completeness of the work instructions. This should reduce those instances of unauthorized work because of misunderstood instructions. However, the evaluator sees a weakness in terms of feedback to management regarding l

the extent and frequency of unauthorized work occurrences.

l l

The evaluators sees the need for an in-process audit IR2 program to reduce the probability that unauthorized work l

will occur, and to provide prompt feedback to management I

when it does occur.

l 3.

The new work control program does not address, in any way, one of the root causes of work control problems listed in SCR 6497.

Specifically that "there is no requirement for ONP or NSB personnel performing work under the scope of AI-8,5 to address possible impact on items documented under the DNC records accountability procedure." This is a critical weakness, in that it can lead to NCRs mistakenly being written for unauthorized or undocumented work.

It can also lead to NCRs being written against the wrong organization.

It can cause the disconnection of the audit trail used to hunt root causes of configuration control problems.

- ~

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 51 0F 93 In rummary, our conclusions are that unauthorized and autttorized-but-undocumented work did occur.

Both occurred with a frequency high enough to spur management into'a major overhaul of the WBN work. control program. The evaluator's conclusion is that_the new program will significantly strengthen the control of work.

It is adequate with the exceptions noted in items 1, 2, and 3 above. The evaluator found no evidence to suggest that poor work control has caused a significant configuration control problem.

Bellefonte The BLN evaluation of unauthorized / undocumented work concerns focussed on the generic issues rather than individual concerns.

A generic approach was chosen because only one BLN concern (BLNDNEEC 82-11) was expressed that correlated to the unauthorized / undocumented work issue, and that concern was essentially generic in nature. The remaining concerns, with one exception, were expressed at WBN and in all cases were not specifically applicable to BLN because of differences in plant procedures and personnel. Consequently, the BLN evaluation

- assessed work performed without documented authorization and failure to document work performed on permanent plant records.

The evaluation methodology used was to review the procedures and documents used at BLN to authorize and document work, interview knowledgeable personnel concerning implementation of said procedures, and auditing work control documents.

A list of the BLN procedures reviewed follows:

BNP-QCP-10.7 Ell - Quality Assurance Records Indefinite Status Control During BNP-QCP-3.27 R7 Troubleshooting Installation and Test Activities l

i Work Packages BNP-SOP-2-RS Inspection Control During Equipment i

BNP-QCP-3.31 R6 Modification BNP-QCP-10.40 R1 -

Cross-work Control for Tentatively Transferred ASME Code Systems 6

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 52 0F 93 BLM 11.4 R1 Cross-work Control for Maintenance of Transferred ASME Section III Cade Class 1, 2, and 3 Systems and Components BNP-QCP-10.6 R18 -

Work Release BNP-QCP-10.4 R14 -

Control of Nonconformances and Significant Condition Reports BNP-QCP-9.4 R7 Work Plans BNP-QCP-10.53 R1 -

Field Change Request (FCR), Weld Map Change Request (WHCR), and Duct Map Change Request (DMCR)

BNP-QCP-1.3 R8 Preventive Maintenance Interviews were conducted with a cross section of knowledgeable DNC and ONP personnel including three DNC craft superintendents, four DNC engineering managers, one Drawing Control Unit (DCU) employee, and two ONP managers. The purpose of the interviews was to assess the perceived effectiveness of BLN's work control program.

Finally, a sample of 180 work releases was taken to estimate the extent of unauthorized / undocumented work at BLN. The WBN evaluation revealed that work releases were sometimes used to document and approve previously unauthorized work.

In addition, work releases were frequently associated with rework activities that subsequently went undocumented. The WBN review identified a number of cases where rework occurred that invalidated previous construction tests or QC inspections, thus requiring that the tests or inspections be performed again. In some cases, particularly in the electrical area, construction test or QC inspection records were not reviewed, or " bumped", to indicate that additional tescing or inspection was required. Therefore, the evaluators concluded that a review of BLN work releases could give a good indication of the extent of unauthorized / undocumented work at BLN. The BLN evaluation of unauthorized / undocumented work revealed no evidence of such problems at BLN. The BLN procedures reviewed were judged adequate to accomplish their intended purpose although there was a consensus construction management opinion that BLN-S0?-2 should be updated.

c TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 53 0F 93 The personnel interviewed were' satisfied that unauthorized /

undocumented work is not a problem at BLN.

In general, both craft and engineering supervisors were satisfied with the work control procedures and documents. There was, however, a perceived need for additional training in work control procedures l

to enhance implementation of the procedures by all personnel and to make all personnel aware of procedures not normally used in their area of responsibility.

The work release phase of the evaluation was conducted using a stratified sampling technique. A sample of thirty work releases was taken from the mechanical, hanger, civil and instrumentation engineering units; sixty electrical work releases were reviewed.

The work releases were reviewed to identify those releases that specified rework.

If rework was specified that invalidated a previous QC inspection QC inspection records were reviewed to determine if the rework was inspected.

Of the sixty electrical work releases reviewed, fifty-two required rework and reinspection.

Some of the work releases required as many as eighteen reinspections. All the inspection records were found to be complete and current, and all required inspections had been performed.

Of the other one-hundred and twenty work releases in the sample, only nine specified rework requiring follow-up inspections; one mechanical wort release, three civil work releases, and five instrumentation work releases. No hanger work release affected QC inspections. All inspections required by the nine work releases were performed.

Conclusions The review of BLN work control procedures and interviews with BLN personnel failed to identify any problems associated with unauthorized / undocumented work. In addition, the review of work l

releases failed to identify corroborating evidence of unauthorized / undocumented work.

Consequently, this issue is not factual for BLN.

Secuoyah The SQN evaluation of unauthorized / undocumented work was limited j

to the consideration of only one concern, XX-85-077-X04, which was identified at SQN. The concern stated, " Drawings have been falsified".

)

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 54 0F 93 The concern was evaluated by reviewing all the available ECTG files on this concern and SQN Construction Standard Operating Procedure No. 303, RS, " Configuration Centrol" dated April 18, 1980 and SQN Construction Procedure No. P-15, R3, " Transfer of Permanent Features and Associated Documentation to the Division of Power Production" dated October 15, 1976.

Review of the expurgated QTC files revealed an NSRS report, I-85-860-SQN, which addrecsed this concern.

Review of the report revealed the following information:

1.

The SOP 308, revision 5, was written to provide a common method of marking drawings required for a system transfer.

The procedure utilized a common method within TVA of cognizant working level individuals performing the tasks, and then the unit supervisor reviewing that work. The assignment of a responsible reviewer within a unit is made by the unit supervisor.

2.

Within the Construction organization, the unit supervisor is the person responsible for assuring that cognizant engineers are qualified and are performing the assigned work in a satisfactory manner.

3.

The unit supervisor, by position, education, and experience, is considered to be qualified to initial that a drawing is marked correctly and, in fact, is called by procedures SQNP S0P 308 and SNP Construction Procedure P-15 to do so.

Technically, the cognizant engineer would initial the construction revision block in the appropriate space, and the unit supervisor should initial in the designated space.

No objective evidence of drawing falsification was found in 4.

this investigation.

5.

The CI said when he refused to sign an as-built drawing status sticker, his boss would take a look at the drawing and sign it.

This supposedly occurred on electrical drawings around 1980 at the time of systems transfer before preoperational testing.

6.

The CI said this was no longer a concern.

Review of SQN Construction Standard Operating Procedure 308, Revision 5, dated April 18, 1980, " Configuration Control" revealed the responsible construction engineer as the designated individual to mark the current configuration and initial the construction revision block. This procedure also showed that the construction unit supervisor as being required to affix his initials on the construction revision block.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PF0 GRAM REVISION NUMBER:

2 PAGE 55 0F 93 Review of SQN Plant construction Procedure P-15. Revision 3, dated October 15, 1976, " Transfer of Permanent Features and Associated Documentation to the Division of Power Production," revealed the responsible engineering unit is responsible for identifying incomplete work and that the section unit supervisor signs the Incomplete Work. Item Form.

Conclusion The ECTG evaluation agreed with the NSRS report that drawings of this type had not been falsified, and misunderstanding of the No procedures by the concerned individual led to the concern.

further evaluation was deemed necessary.

4.2 Craftsmen Doint Engineering Work Thirteen WBN concerns and one SQN concern listed in section 1.2.2 were identified that are related to the issue of craftsmen doing engineering work. The cited concerns allege that craftsmen are required, either by direction or circumstance, to perform various engineering tasks in order to expedite their work. The allegations are paraphrased as follows:

Engineers ask craftsmen to resolve problems by whatever means are available and then justify the work on paper after the fact.

Craf tsmen are doing engineering work such as " drawing logic" Instrumentation is being designed in the field and documented on a sketch.

Craftsmen are expected to find a way to install hangers and then to call engineering to sketch the as-constructed drawing.

The issue was evaluated by ECTG at WBN, SQN, and bLN. The evaluation methodology and findings pertinent to each plant are presented below.

Watts Bar The WBN concerns were evaluated by reviewing the pertinent site procedures, interviewing knowledgeable engineering and crafts personnel, and reviewing NSRS Report I-86-194-SQN, " Hanger Drawings Made and Design Completed after Hanger Fabrication and Installation."

WBN QCI 1.13 Revision (R) 14 " Field Change Requests," dated October 25, 1985, VBN-QCI 1.28, R6, " Variances," dated May 7, 1985, and WBN QCP 4.23-8,R8, " Support Final Inspection," dated September 9, 1986, adequately addressed the use of conditional approval to install hangers and ensured confirmation of design

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 56 0F 93 approval before final inspection. Until recently, the conditional approval of a construction deviation could be either oral or written; however, a memorandum from W. C. Drotleff, Director of Nuclear Engineering, dated April 4, 1986, (B05 860404 003) stated that henceforth formal written approval of Field Change Requests (FCRs) will be required before work can proceed.

Hanger engineering personnel confirmed that hangers cannot always be installed as designated because of interferences with previously installed components.

Variances from design specifications are controlled; however, final inspections of all hangers must be performed using the latest revision of the applicable design drawing. Consequently, since the as-constructed configuration of field-designed hangers is reviewed by DNE for conformance to design requirements and inspected by DNC to approved design drawings, no CAQ was identified by the subject concerns relative to hanger installations.

Concern IN-85-243-026 alleges that craftsmen are sometimes responsible for " drawing logic." The precise meaning of this concern is unclear, but it is presumed to involve electrical logie diagrams. The task that would most likely be affected by field generated logic diagrams is cable terminations. A review of WBN-QCP-3.06-3, R10. " Inspection of Cable Terminations," dated September 24, 1986, determined that electrical inspectors are required to inspect conductor terminations in accordance with approved design drawings specified on the rear of the termination slip. Therefore, although craftsmen could generate " drawing logic,"

the configuration of conductor terminations is controlled by approved design drawings and could not be adversely affected by informal drawings generated by craftsmen.

Concern IN-85-447-003 alleges that instrumentation is designed in the field and documented on a sketch. The concern was interpreted to mean that the sensing, sampling, control air, radiation monitoring, and signal lines associated with instrument installations are designed in the field rather than the instrumentation itself.

The concern was evaluated by reviewing WBN QCP-3.11-1, R10

" Supports and Slope for Instrument Lines," dated October 17, 1986.

It should also be noted that concerns related to the cited concern are addressed in subcategory report 17300, " Instrument Line Installations." Specific deficiencies and recommended corrective actions addressing those deficiencies are detailed in the cited report.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 57 0F 93 The review of QCP-3.11-1, RIO revealed that DNC's Instrumentation Engineering Unit (IEU) is responsible for instrument line installations.

In practice, this means that IEU responsible engineers (REs) coordinate, among other responsibilities, the installation of instrument lines.

QCP 3.11-1 specifies that instrumentation mechanics are to field route instrument lines in accordance with documented design criteria and refer any problems encountered during installation to the RE.

When the installation is complete, the craftsmen requests that a draftsman generate an installation operation sheet (IOS). documenting the as-built configuration. The RE reviews the IOS for compliance to the design criteria and documents the pertinent inspection criteria on the IOS. The augmented IOS is then used to inspect the installation for final approval. The ECTG evaluation thus confirmed that IN-85-447-003 was factual; however, field routing of instrument lines was an acceptable practice governed by site procedures and monitored by site engi'noering personnel.

Consequently, the concern, though factual, did not identify a CAQ with regard to craftsmen installing instrument lines.

Concern IN-85-111-001 alleges that work done on nonsafety-related, field routed instrument lines is not reflected on "as-built" drawings. The ONP response to this allegation is that it is true but not a problem. Certain nonsafety-related, field-routed components are not documented on as-built drawings because the costs of documentirs the installation exceed the benefits of having the information readily available. All safety-related installations are documented for future reference to support design, operation, and regulatory objectives and requirements.

Since the generation of as-built drawings for nonsafety-related features is not a safety issue ONP is justified in deciding the propriety of generating as-built drawings on a cost / benefit basis.

Consequently, although the concern was factual it does not represent a problem and corrective actions are not required.

Sequoyah Concern XX-85-120-006 was a SQN specific concern related to the subject of craft designed hangers. The concern alleged that craftsmen installing hangers were instructed by a supervisor to build hangers without drawings and engineering would document and validate tho hangers later.

It should also be noted that the SQN element report on this issue, C0ll202-SQN, referenced a WBN concern, IN-86-261-002, which was thought to be correlated with the issue of craftsmen doing engineering work.

Review and investigation of the concern resulted in the determination that the concern was more appropriately corre16ted with the issue of poor planning and coordination and was addressed accordingly.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 58 0F 93 The concern was evaluated by reviewing the QTC expurgated files for additional information, interviewing knowledgeable personnel who were involved in hanger installations, and reviewing NSRS Reports I-86-194-SQN and I-85-925-SQN to determine if they addressed the concern adequately.

No additional information was found in the QTC expurgated files.

The interviews with hanger personnel supported the allegation documented in the concern, in that some hangers were installed at SQN before the final hanger design drawings were issued. However, as was the case at WBN, the as-constructed configuration of the hangers was subject to design review and approval before final inspection of the affected hangers.

It should also be noted that most of the field desip.ad hangers were based on typical hanger designs.

Typical hangers are, by definition, hanger configurations that are widely used and familiar to craftsmen, and generally incorporate factors of safety at least several times greater than the factors of safety required by design considerations and regulatory requirements. Consequently, field " engineered" hangers based on typical hanger designs are intrinsically conservative designs for most applications.

The NSRS reports corroborated these findings and also documented the failure to find any evidence that hangers were currently (January-February, 1986) being installed without approved design drawings included in the applicable workplan.

Therefore, the subject concern was factual but did not result in identification of a CAQ.

Bellefonte Although no BLN specific concerns were identified relating to this issue, since construction activities continue at BLN an ECTG evaluation of the BLN construction practices that could be considered " field engineering" was conducted. The objective of the evaluation was to determine if BLN craftsmen install hangers or field-route instrument lines without approved design drawings in hand and, if they do, are such activities procedurally controlled to ensure that the pertinent design requirements are met.

The evaluation methodology used was to interview knowledgeable craftsmen and engineers to determine if craft designed installations were used and, if so, to review the governing site procedures to determine if they adequately control craft designed installations.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 59 0F 93 Interviews with four hanger engineering unit (HEU) engineers established that the only hangers that could be considered craft-designed hangers, are hangers used on field routed systems.

All other systems hangers are fabricated and installed in accordance with hanger packages. Hanger packages are compiled by HEU as directed by BLN QCP-10.2, R15 " Document Control," dated April 16, 1986 and DLN QCP-6.17. R14 " Seismic Support Installation and Inspection," dated June 12, 1986.

The packages include all the necessary design information to fabricate and install hangers.

If modifications are required beyond those allowed by installation tolerances, a design engineering approved field change request (FCR) is required before work can proceed.

Therefore, only those hangers used on field routed systems could be considered craft designed.

Field routed system hangers are not fabricated and installed using hanger packages; instead, non-QA/QC preliminary drawings are used.

If problems are encountered that necessitate a change to the preliminary layout, the appropriate layout revisions are made and marked in red on the preliminary drawing. When the installation is complete, the marked-up preliminary drawing is given to site DME engineers, who then generate an approved design drawing. All QC inspections are performed using the approved design drawing.

Therefore, all hangers installed on field routed systems are reviewed and approved by DNE engineers before final inspection and acceptance.

The issue of craft designed hangers is therefore considered to be factual, but not a CAQ, at BLN. No corrective actions were required.

t Concerns IN-85-lll-001 and IN-85-447-003 represent another aspect of the field engineering issue: field routing and documentation of instrument lines. The specific allegations are that the craft must route some instrument lines without design drawings that specify the exact locations of the lines (i.e. field routing lines) and that field routed lines are not reflected on as-built drawings.

The concerns were evaluated at BLN by interviewing the instrumentation engineering unit (IEU) supervisor and reviewing the procedures governing instrument tubing installations.

The IEU supervisor confirmed both allegations, but contended that neither condition represented a CAQ.

DNE established specific criteria to guide the field routing of instrument lines to preserve the design integrity of the lines.

In addition, DNE specified the end points between which instrument lines must be run and any intermediate containment sleeves or penetrations that the tubing should pass through. Any chango in these parameters requires formal DNE approval on an FCR which

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 i

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 60 0F 93 ensures that the design drawings will be revised to reflect the change. These requirements are documented in BNP-QCP-4.3 R13

" Instrument Tubing Installation" dated June 15, 1986 and drawing series 56B0925-IO.

Therefore, the cited concerns were found to be factual, but not CAQs No corrective actions were required.

Conclusion The issue of craftsmen doing engineering work was evaluated at WBN, SQN, and BLN and found to be factual, however, in no case was a CAQ identified nor were corrective actions required.

4.3 Poor Planning and Coordination Seventeen WBN concerns and one SQN concern which are listed in section.1.2.3 of this report were correlated to the poor planning and coordination issue. Thirteen of the WBN concerns were considered potentially applicable to BLN and evaluated accordingly.

Typical concerns included in this issue are paraphrased as follows:

Improper sequencing of tasks requires excessive rework and delays.

Equipment / component integrity is compromised to rework.

Time and material are wasted by failing to learn from mistakes.

Intentional errors have caused rework and delays.

Design modifications and material shortages have caused delays.

Poor coordination between design, construction engineering, and crafts caused delays.

Evaluation of the concerns at WBN, SQN, and BLN was condceted in a manner consistent with the information contained in the concerns, Specific allegations were addressed where possible; otherwise, the general implications of the concern were evaluated. The evaluation methodology and findings pertinent to each plant are detailed in the following plant specific sections.

I Watts Bar The seventeen WBN concerns were evaluated by reviewing both superceded and current work control procedures, interviewing knowledgeable engineers, managers and foremen, and reviewing construction management responses to ten of the subject concerns.

In addition, the ECTG evaluators attended a training class en the current comprehensive construction work control procedure, QCI 1.60, RO, " Work Control," dated February 21, 1986. The superceded work control procedures reviewed were WBN-QCI-1.30, R11

" Control of Work on Transferred Systems and Untransferred Systems

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 61 0F 93 Behind Unit 1 Security," WBN-QCI-1.56, R10. " Work Packages," and WBN-QCI-1.07, Rll, " Work Releases." Twenty-one people were interviewed including seven craft supervisors, five engineers, and nine engineering and QC managers.

There was a management consensus that planning and coordination was a problem to a degree at Watts Bar. As a result, when the new work control procedure, QCI 1.60 R0, was written, changes were incorporated to eliminate those problems. The Responsible Engineer (RE) has the charge of writing a workplan that provides detailed steps by which work is identified, planned, approved, performed and inspected. The RE is responsible for identifying the need for and determining the scope of the workplan. The RE will review the plan for impact on other features and develop a step by step list of work and hold points on QCI 1.60 Attachment H.

The RE will determine the needed documents for the workplan, such as drawings, weld assignment sheets, specifications, procedures, vendor manuals, and the controlled documents. These documents will be included in the workplan. During the pre-planning, the RE and craft foreman will walkdown the work included in the plan. They may request anyone they feel will be of assistance to them, such as the Project Control Group, Quality Control and safety engineers, to accompany them on the walkdown. The RE will closely monitor ongoing work and provide assistance and, upon completion of work, the craft foreman and RE will sign QCI 1.60 Attachment A, concurring that all field work (including field inspection work) is adequately completed. The craft foreman returns the workplan to the Workplan Control Group.

Except for the four concerns explicitly addressed below, the procedure outlined above addresses the concerns included in the issue of poor planning and coordination.

The following four concerns are addressed individually because specific problems or solutions are detailed in the response to the subject concern.

The lack of communication between craft and engineering (concern EX-85-052-002) is addressed by QCI 1.60.

As indicated above, a craft representative and RE are required to walkdown the work together before a workplan is written. Also, the RE is required to closely monitor the ongoing work and to provide assistance to achieve maximum quality and productivity.

Concern IN-85-816-002 stated that DNE should be more efficient when developing workplans to prevent costly rework. The concern stated a final walkdown before final issue would help. DNE does not make up or issue work packages, but the site engineers who do make up and issue the workplans are now working to QCI 1.60 which requires a pre-walkdown by the engineer and a craft representative. This should help to reduce the amount of rework.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 62 0F 93 The proper material not being available at time of work (Concern IN-86-179-002) should be covered ty QCI 1.60.

The RE has the responsibility to check out material availability during pre-planning of workplan. The RE has the responsibility to get material ordered if not on hand, and to issue the material request forms to obtain material from warehouse if necessary. During the pre-planning walkdown, the craft foreman has the opportunity to question the availability of material.

Concern IN-85-437-002 alleged that hangers have been installed to the wrong drawing revision. The 79-14 walkdown, which was done after system transfers, covered about half of the hangers in the plant and all of the most critical system hangers.

During this walkdown some hangers were found to be installed to the wrong revision, but there were very few. All of the.e have been reworked or dispositioned by engineering.

The concerns included in this issue were factual. Poor planning and coordination of work was a problem at WBN and was recognized as a problem by WBN management. WBN management issued QCI 1.60. R0, to correct the deficiencies in the previous work control procedures.

If QCI 1.60 is implemented consistently, the planning and coordination of work should be improved.

Sequoyah Only one concern, MAS-86-003, was evaluated at SQN that was related to the issue of poor planning and coordination. The CI apparently felt no corrective action was being taken to resolve discrepancies noted between fuse specifications on design drawings and fuses installed by workplan number 10512.

The concern was determined to be unique to SQN and was not evaluated at any other IVA plant.

MAS-86-003 was evaluated by reviewing workplan 10512 and interviewing knowledgeable Electrical Maintenance personnel. The discussions with Electrical Maintenance personnel revealed this was a concern received under the "old" Employee Concerns Program, and a resolution had been discussed with the concerned individual. This resolution would involve DNE, the Inspector General, DNC, and an l

assistant unit operator. The design engineer will authorize changes I

in fuse size and manufacture type.

FCRs will be submitted to correct I

any drawing discrepancies.

Drawings will be marked up showing the IR2 correct fuse configuration before workplan closure. This discussion I

also revealed that the concerned individual agreed that these I

corrective steps should resolve any problems that exist and would I

also satisfy his concerns.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 63 0F 93 A review of workplan 10512 revealed the work was to install nameplates or unique identifiers to all control fuses.

Identification will consist of a unique identifier, a manufacturers code, and fuse rating.

Concern MAS-86-003 was determined to be factual and ;orrective actions have been initiated to correct the problem. The ECTG issued, on August 1, 1986 (T25860901981), CATD 1120J-SQN-01 to the SQN Site Director to document the ECTG findings ard to request documentation from SQN detailing the corrective actions scheduled.

The ~QN Site Director responded, on October 15, 1986, to the CATD with SQN's corrective action plan (S03861015803) which includes the corrective actions to be taken, the implementation schedule and the SQN organization responsible for implementing the corrective actions.

Bellefonte Thirteen of the 17 WBN concerns were considered potentially applicable to BLN and evaluated at BLN by the ECTG. The evaluation methodology used at BLN differed from the approach used at WBN in that each of the 13 concerns were evaluated individually; in other respects the evaluation methodology was the same, i.e.,

knowledgeable personnel were interviewed about the pertinent aspects of the concerns and documentation relevant to each concern was reviewed to determine it's adequacy relative to the cited concern.

The findings relative to each concern are presented below.

Concern IN-85-816-002 stated that DNE should be more efficient when developing work packages and that a walkdown should be conducted prior to issuance of the work package. The evaluation revealed that BLN Standard Operating Procedures (BNP-S0P)-2, RS, " Work Packages,"

issued April 8, 1985, paragraph 6.4.2.9 requires a detailed system walkdown by the DNC (not DNE) responsible engineering unit (REU) and the affected craftsmen with DNE input as required, before the work package is issued. Therefore, this concern was not factual.

Concern IN-86-257-002 alleged that in WBN units 1 and 2, a 3-inch conduit was installed before the steam generator was insulated resulting in costly rework.

This concern does not apply to BLN because the BLN steam generators are designed differently than the WBN steam generators and are not insulated. Therefore, this concern was not factual.

Concern EX-85-002-044 steted that installation of conduit takes priority over the design and installation of piping.

Interviews with the electrical craft superintendent, two engineering supervisors, one electrical engineer, and two electrical quality control inspectors established that installation of piping has priority over the installation of conduit at BLN. The concern was not factual.

m.

1NA EMPLOYEE CONCERNS REPORT NUNBER:

11200

' SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 64 0F 93 i

Concern IN-85-514-007 stated that process piping is connected to local panels before the panels' anchor bolts are pull-tested and accepted.

Interviews with four instrumentation and civil QC inspectors determined that anchor bolt pull tests are required at BLN before the panel is set.

Confirmation of the pull test is required before the installed panel.is approved by QC. The concern was not factual.

Concern IN-85-978-008 alleged that TVA poured large concrete r

structures such as walls even though they knew that the structures would be unacceptable.

Concrete placement is controlled at BLN by BNP-QCP-5.3, R10. BLN by BNP-QCP 5.3, R10. " Concrete Placement,"-

dated July. 23, 1986. Attachment A to QCP 5.3, which is designated a concrete card, must be signed off by crafts, engineering and/or QC inspectors before concrete is placed. Their signatures affirm that i

all features of the pour within the scope of their responsibilities meet the specifications denoted on the current DNE design drawings.

Therefore, this concern was-not considered factual.

z Concern IN-85-514-003 alleges that TVA wastes time and material by i'

installing temporary hangers. An interview with a senior hanger engineer revealed that piping installation activities are scheduled

[

before permanent hanger installation activities are scheduled to give maximum flexibility and minimum interference to piping. This l

practice necessitates the use of temporary hangers to support the~

dead loads the installed piping represents. The concern was not factual.

Concern WI-85-091-012 stated that the hanger group claims credit for a completed hanger when the hanger is submitted for inspection. If the hanger is rejected and reworked, the CI alleged that the hanger j

-group again claims credit for a completed hanger. An interview with' i

a senior hanger engineer revealed that the status of a given hanger:

is tracked in a computer-based accounting system by hanger engineering. Once credit is claimed for a completed hanger, the l'

computer program protocol will not allow the hanger to be claimed again. This concern was not factual.

Concern IN-85-409-002 alleged that mistakes made in routing unit 1 conduit were repeated on unit 2.

Interviews with an electrical l

craft supervisor, an electrical engineer, and two electrical QC supervisors indicated that duplication of errors is certainly possible; however, as a general rule, deficiencies identified on unit 1 that were corrected with an FCR were also corrected on unit 2.

The concern was not factual.

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4 TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200-SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 65 0F 93 Concern IN-85-978-009 stated that.TVA made a practice of installing equipment out of. sequence, resulting in damage to the equipment when it was removed and reinstalled.

Interviews with craftsmen,

. engineers, and QC inspectors established that equipment installation activities are prioritized and scheduled so that equipment is not installed until all necessary supporting hardware is in place. This preserves the procedure relationships established by project control personnel and minimizes the type of problem cited in the concern.

The concern was not factual.

Concern IN-85-362-002 states that welds are often inspected after insulation has been applied which is costly since the insulation must be removed and reapplied. Insulation is applied at BLN.only after approval'for the work is obtained from the insulation engineer. To approve the work, the insulation engineer must obtain 4

J a written release from the welding engineering unit (if welding was required) according to the requirements of BNP-QCP-6.18 RS,

" Metallic and Nonmetallic Thermal Insulation." The concern was not factual.

Concern IN-85-377-001 alleges that the cost of prepping welds for in service inspection (ISI) could have been prevented if preps had been made when the pipe was fabricated. Presently, hangers must be i.

removed and reinstalled to perform the weld preps. The ECTG evaluator concluded that the.CI was misinformed about the intent of pre-ISI. weld preps. Pre-ISI weld preps are performed to establish a baseline for future:ISI-inspections.

In any event, removal of hangers may be required in the future depending on ISI requirements. The concern was factual with regard to the removal and reinstallation of hangers but was not a problem.

Concern IN-85-787-001 states.that lack of communication between crafts and engineering causes long delays in completing work.

Rework due to design and redesign is a continual problem and communication breakdowns exist but are not a prevalent problem at BLN.

Concern EX-85-052-003 alleges that engineering personnel prepare l

poorly planned work packages. Layouts are inadequate and important i

details are omitted. Interviews with craft representatives and QC inspectors confirmed the allegation's applicability to BLN. The i

consensus among those interviewed was that SOP-2, RS, " Work Packages," is in need of revision and that engineers responsible for preparing work packages should receive more training to insure that they execute the task adequately. Therefore, the concern was determined to be factual and to require corrective actions.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 66 0F 93 Conclusion Poor planning and coordination of construction work activities was found to be a problem at both WBN and BLN. The single concern evaluated at SQN was not sufficient to identify a generic or programmatic deficiency beyond the scope of the identified concern.

Since the SQN concern has already been addressed, no further action at SQN is required. Programmatic corrective actions have been implemented at WBN with the issuance of QCI 1.60.

Assuming that QCI 1.60 is adequately implemented, ne further programmatic corrective actions should be required.

Programmatic deficiencies in the work control area were identified at BLN that have not yet been addressed.

The work control procedure SOP-2, may need revision and additional training for engineers who prepare work packages may be required to ensure'the adequacy of BLN work packages.

4.4 Inadeauste Walkdown and Walkdown Information Five WBN concerns, listed in section 1.2.4, have been related to the issue of inadequate walkdowns and walkdown information. The concerns are paraphrased as follows:

The outstanding work items list (OWIL) is not complete. The superintendent arbitrarily adds and deletes items from the list.

The responsible system engineer did not participate in the system transfer walkdown. Outstanding work items were not identified as a result.

Drawings used in unit I walkdowns were not current. No walkdown group exists.

Construction transfer drawings do not agree with operations transfer drawings.

Workplan completion is not verified before the release of the punch list. Punchlist completion verification is performed concurrently with the punchlist workplan.

All of the cited concerns were identified at WBN and were considered potentially applicable to BLN. Therefore, an ECTG evaluation of the issue was conducted on both plants. However, BLN has completed construction and transferred only a few unit 1 components. As a result, the BLN evaluation was limited to an examination of the procedures governing walkdowns and walkdown documentation and interviews with completions unit personnel to review the transfer process. On the other hand, the WBN review included reviews of

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 67 0F.93 outstanding nonconformance reports (NCRs) on related issues and corrective actions addressing those NCRs, as well as procedure reviews and interviews with personnel involved with permanent features transfers. The findings pertinent to each plant are presented in the following plant specific sections.

Watts Bar The review of the transfer of permanent features program revealed that the program was being administered by the startup, testing, and coordination unit. There was not any major problem with the program as established except the review did reveal a problem with as-constructed drawings. There have been more than 20 NCRs initiated documenting as-constructed drawings which do not correctly depict the as-built configuration of installed features.

These situations would seem to exist because personnel in ONP, Construction Engineer's Office, and Nuclear Services Branch failed to identify problems during the initial statusips of drawings, and possibly in subsequent statusing of drawings. (

The existing WBN QCI 1.25, revision 8, dated October 16, 1984, did adequately address the control of as-constructed drawings, specifically the depiction of as-built features

-(concern IN-86-019-006) that are not installed or not operational within a transferred boundary.

(Reference paragraph 6.3.4.1.5)

The existing WBN QCI 1.22, revision 8, dated December 21, 1984, did adequately address the transfer of permanent features to ONP.

Interviews with cognizant startup, testing, and coordination personnel revealed they were well informed on what their responsibilities are and what procedures they need to follow to accomplish these tasks to provide a corrective action to the identified configuration control problems.

Interview with cognizant Nuclear Services Branch personnel revealed that SCR 6297, revision 2, was being written at the time of the ECTG evaluation to provide a corrective action to the identified configuration control problems.

Based on the above findings, the cited concerns were not found to be factual. The evaluation did, however, identify a related problem with as-constructed drawings.

Corrective actions for this problem will be specified in the disposition of SCR 6297.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 68 0F 93 Bellefonte Since none of the concerns included in this issue were identified at BLN, the BLN evaluation focused on potential programmatic deficiencies affecting walkdowns. Consequently, the transfer of permanent features program was the primary subject of review. This program specifies the criteria and methodology used to transfer portions of the plant from DNC control to ONP control.

The ECTG evaluator reviewed BLN quality control procedures BNP-QCP-9.2 R10 " Transfer of Permanent Plant Equipment, Systems or Structures to the Division of Nuclear Power" dated March 21, 1985 and DNP-QCP-9.3, R11 " Configuration Drawing Control" dated February 24, 1986 to determine the formal requirements for handling transfers. The evaluator also interviewed members of the DNC completions unit (CU) to determine the strengths and weaknesses in the transfer program.

BNP-QCP-9.2 paragraph 6.1.3.6 requires each engineering unit to prepare a list of the incomplete work on each portion of the plant being readied for transfer.

This list typically includes outstanding ECNs, FCRs, NCRs, IRNs, Temporary Installations or Omissions (TIDs), Indefinite Status Control Forms (ISCs), Work Releases (WRs), Sequence Control Charts (SCCs), construction tests, QC inspections, and work items within the physical transfer boundary. Work items within the confines of a structural (e.g., a building) transfers are not listed on the outstanding work items list (0WIL). The OWIL is compiled or updated after walkdowns of the proposed transfer are conducted. The CU coordinates the walkdowns between the construction engineering units and the operations units and ensures that all necessary documentation is generated and maintained. Three walkdowns are conducted before transfer: One 12 weeks before, another 6 weeks before, and the final walkdown 4 weeks before transfer. After the final walkdown, a punchlist is generated that reflects a consensus between Construction and Operations on the work that will be done by Construction either before transfer or before preoperational testing. These measures ensure that the OWIL is both comprehensive and accurate and coordinated with all affected parties.

The concerns that deal with drawing control are addressed by l

BNP-QCP-9.3.

QCP-9.3, R11, paragraph 5.1.1 assigns coordination l

responsibility for configuration control activities involving lR2 as-constructed (AC) drawings to the CU.

AC drawings are generated I

after completion of all pertinent work plans and before transfer.

l AC drawings are reviewed by DNE for conformance to design i

requirements.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 69 0F 93 The CU is also responsible for maintaining AC drawings after transfer. These measures ensure that AC drawings are accurate, current and in conformance with design requirements.

Interviews with CU personnel confirmed the results of the procedure review and failed to identify indications of programmatic deficiencies in the transfer program.

Based on the above findings, the cited concerns were not factual with respect to BLN.

Conclusion The cited concerns were not found to be factual at WBN or BLN. A problem was identified at WBN, however, in a related area that is being addressed by DNC and documented on SCR 6297 R2.

No corrective actions were required at BLN.

4.5 Poor Quality of Work Packages and Work Package Control Eighteen WBN concerns listed in section 1.2.5 were evaluated at WBN as example of poor quality work packages or poor work package control. Thirteen of the concerns were considered potentially applicable to BLN and evaluated accordingly.

The concerns allege that work packages issued by construction engineering are deficient in various ways and that the packages are implemented in an uncontrolled manner. The concerns are paraphrased as follows:

Engineers omit essential information and documents from work packages.

I Engineers provide erroneous information and documents with work j

packages.

Walkdowns are not conducted before engineering issues workplans.

Work packages that are split up among several foremen are improperly controlled.

Foremen assigned responsibility for one work pactage do not have access to related work packages.

i The findings relevant to each plant are presented below.

Watts Bar The subject concerns collectively allege that the quality of work packages is poor and that work packages are poorly controlled when l

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 70 0F 93 issued. The evaluation methodology used was first to determine what documentation work packages should contain and how they should be used and then to determine how these requirements are implemented.

Therefore, the evaluators reviewed QCI 1.60, " Work Control," and attended a training class on QCI 1.60.

They also reviewod the work control instruction superceded by QCI 1.60: QCI 1.07, " Work Release," QCI 1.30 " Control of Work on Transferred Systems and Untransferred Systems Behind Unit 1 Security," and QCI 1.56 " Work Packages."

The evaluators then interviewed 7 craftsmen and craft supervisors, 3 construction engineers, and 11 engineering supervisors and managers. Finally, the evaluators reviewed construction management responses to concerns IN-85-418-001, IN-85-423-001, IN-85-618-002 and IN-85-898-002, as well as NSRS' report I-85-461-WBN on concerns IN-86-134-001.

The evaluators found that before the work package /workplan changes brought about by QCI 1.60. R0, there were problems with incomplete packages and packages that were split between foremen. This was because there were no clear limits on work package size, nor were there specific instructions regarding the contents of a work package. This led to a situation where craftsmen had to spend their time hunting drawings, procedures, and material. It also led to packages being broken up among several crews. This increased the probability of controlled drawings not being used.

QCI 1.60 was designed to overcome these deficiencies.

WBN QCI 1.60 does not allow workplans to be so large that there would be a need to split workplans between different crews. In general, workplans contain a maximum of approximately 3,000 man-hours of work.

Inadequate distribution and control of work packages (concerns IN-85-281-002, IN-85-618-002 IN-85-348-004, and IN-85-418-001) should not be a problem in the future.

Because of the amount of man hours according to the workplan, only one foreman should be involved and control should not be a problem. Additional copies of the workplan can be obtained upon request.

WBN QCI 1.60, RO dated April 1, 1986, did have provisions to check for completeness and accuracy of the workplans. The responsible engineer and the craf t foreman are required to jointly walkdown the work to be included in the workplan. Accountability for the preplanning has been established, and the QCI provides accountability for updating the Records Accountability Program (RAP).

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 71 0F 93 Procedures and 47A050 notes not being available to the crafts (concern IN-85-134-001) was not found to be a problem. For more information please see Subcategory Report C0110, Hangers and Supports, Attachment E. "Use of Specifications."

The NSRS reports reviewed corroborated the findings of this report.

The WBN evaluation of the subject concerns confirmed that they were factual and that corrective actions were appropriate for the identified deficiencies.

Bellefonte Thirteen of the WBN concerns related to the issue of poor quality and control of work packages were evaluated at BLN. The evaluation consisted of a review of the BLN plant procedure controlling work, BNP-SOP-2 " Work Packages," and interviews with three craft superintendents, one construction engineer and one engineering line manager.

The review of BNP-SOP-2 revealed that formal work packages are required for any work before system transfer with the following exceptions:

work involving only one craft work involving less than 100 manhours shop fabrication in some cases, job performed by craftmen with extensive classroom or on-the-job training, such as hanger installations or highly repetitious work such as concrete pouring or pulling electrical cable Work that is not covered by a formal work package is covered by an informal work package. The primary purpose of the informal work package is to document concurrence by the responsible engineering unit (REU), the responsible quality control unit (RQC) and the construction superintendent that the personnel assigned to the work are qualified in the requirements pertinent to the work packages.

Formal work packages are compiled by the REU. The work activities included in a work package are limited to the incomplete work inside a transfer or work package boundary established by the completions unit (CU). The REU, with support from RQC and the craft, identifies the work to be done. The REU then schedules and sequences all necessary work items and coordinates concurrence from RQC and the craft with the activities and schedule outlined.

Included in the work package is a list of all drawings associated with the work

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 72 0F 93 packages. The craft obtains controlled copies of the listed drawings from the drawing control unit (DCU) thus assuring that revised drawings will be sent to the craft upon issue. After all other work package preparations are complete, the REU, with necessary craft and DNE input, performs a detailed walkdown of the workplan activities and prepares a quantity walkdown sheet listing all remaining work within the transfer boundary.

The quantity walkdown sheet is compared to the work activity schedule and discrepancies resolved before the work package is issued. These steps should ensure that the description of the work to be performed is accurate, adequate, and complete and that all necessary supporting information is either in the work package or referred for easy access.

SOP-2 also provides for an area planner who is responsible for, administering work packages in a designated area of the plant from issuance to completion. The area planner ensures that a work package is issued to the appropriate general foreman, updated when revisions are issued and closed properly when the work is complete.

This provides a measure of consistency in the way that work packages are processed. In addition, the area planner serves as a coordinator between crafts when their activities overlap.

The procedure review determined that adequate programmatic controls are in place to address the WBN concerns if the controls are implemented.

Interviews with craft and engineering personnel were held to identify any implementation problems that may exist.

Interviews were conducted with craft and engineering representatives.

Questions asked during the interviews were derived from the subject concerns.

Some of the questions asked were:

"Are work package documents being split up among several foremen thus losing control of the work packages?"

"Are work packages complete when received by the craft-latest FCRs, ECNs?"

The interviewees did not indicate that there are major problems in any area with the scope of the subject issue. They indicated that work packages are typically accurate and contain adequate references to the documents required to perform the assigned tasks. They also indicated that work packages are generally handled in accordance with the requirements of S0P-2; however, a problem was noted in that a reduction-in-force (RIF) that occurred in July 1985 reduced on-site personnel so that maintenance of non-QA documents, such as work packages, suffered. This problem can be seen in the failure of SOP-2 to accurately reflect the BLN-DNC organizational structure.

For instance, the startup test and coordination unit (STCU) is cited as the unit responsible for the establishment of and revision to transfer boundaries and work packages boundaries.

STCU no longer exists and was replaced by the completions unit (CU).

In addition,

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 73 0F 93 there is now only one area planner; before the RIF there were four area planners. These problems have resulted in less consistent documentation of work activities.

Conclusion The ECTG evaluation confirmed that poor quality of work packages and

(

poor work package control was a problem at WBN.

However, the inadequacies that led to those problems were addressed at WBN by the d

issuance of QCI 1.60.

Assuming that QCI 1.60 is consistently 1;

implemented, the problems noted in the subject concerns should not i

be repeated.

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l The BLN evaluation did not reveal a pattern of deficiencies similar to those cited in the WBN concerns. A related problem was identified, however, in that BLN SOP-2 is out of date with respect l-i-

to BLN's current organizational structure and staffing levels.

Revision of BLN SOP-2 may be warranted to streamline the work i

control process at BLN.

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4.6 Ouestionable Engineering Practices

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This issue is correlated with ten WBN concerns, four of which were i

considered generically applicable to BLN and evaluated accordingly.

The ten concerns are listed in section 1.2.6 of this report. The issue identified by these concerns involves perceived inadequacies with the engineering support of construction activities.

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Specifically the concerns allege that:

Engineers inadequately research work packages.

i Craftsmen build features without documentation and their j

engineers generate the supporting design documents.

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Engineers avoid writing FCRs when needed.

Craftsmen must field route some conduit to avoid installed l

equipment.

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Civil engineers do not have the necessary background to label pipe without assistance.

Civil engineers cannot support unit 1 activities because they don't have unit 1 security clearances.

Unit 1 prints are marked opposite hand and used for unit 2.

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Engineers do not respond in a reasonable time to craft requests for engincoring support.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 74 0F 93 Engineers fall to adequately monitor and control construction activities and allow management decisions to stand even when those decisions conflict with good engineering judgement.

2.

These concerns were evaluated at both WBN and BLN using the same general approach. The pertinent site procedures were reviewed to determine if the concerns documented unacceptable practices.

Knowledgeable personnel were interviewed to assess the perceived scope of the alleged problems.

In addition, the WBN Project Manager's Office (PMO) reports on WhN concerns IN-85-286-001 and IN-85-388-009 were reviewed to determine if they adequately addressed the subject concerns.

Specifically, WBN QCI 1.60 Revision (R)0 " Work Control" dated April 1, 1986, BNP-QCP-10.36 R3 " Sequence Control Chart" dated June 1, 1986 BNP-QCP-10.12 R10 " Material Issue Control" dated June 27, 1986 and BNP-QCP-3.13 R13 " Equipment Installation" dated July 8, 1986 were reviewed to determine how engineering controls field work in progress. Fifty-eight managers, engineers, craftsmen and contractor personnel were interviewed at WBN during the course of the ECTG investigation, s

Ten managers, engineers and craftsmen were interviewed at BLN. A summary of the findings relevant to each issue follows:

1 Concerns EX-85-053-006, EX-85-058-002, IN-86-270-007. IN-85-728-003, and IN-85-670-002 allege that WBN engineers fall to adequately control or support craft personnel by failing to respond to requests or write FCRs in a reasonable time, preparing deficient work packages and failing to adequately monitor work in progress.

Evaluation of this issue was accomplished by reviewing the WBN work 1

control procedure, QCI 1.60, and interviewing WBN management representatives. The managers interviewed agreed that engineering control of field work had been deficient but that QCI 1.60 was l

issued on April 1, 1986, to correct the identified deficiencies, i

The engineer responsible for the work package must now conduct a pre-planning walkdown with a craft representative and maintain c

personal daily contact with each foreman under his direction.

If consistently implemented, these requirements will improve the quality of work packages and will expedite the resolution of 1

problems. It should be noted, however, that engineers disagreed with the implicit allegation that a delay in writing FCRs is undesirable. The engineers contend that FCRs should not be written without first researching applicable tolerances and design-allowed deviations. This approach can identify simpler, more expeditions remedies than an FCR but even if unsuccessful entails only a delay, not a condition adverse to quality. Therefore, concern, EX-85-058-002 although factual, does not represent a deficiency i

l requiring corrective actions.

r

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 75 0F 93 The remaining four concerns were factual and WBN management took corrective actions to address the concerns prior to the ECTG evaluation.

Concerns EX-65-058-002 and IN-86-270-007 were considered potentially applicable to BLN and evaluated accordingly. The applicable BLN work control procedures were reviewed and managers, engineers and craf tsmen interviewed to determine the work control methods used at BLN and their perceived effectiveness. The ECTG investigator found no evidence of inadequate engineering support of construction activities or similar concerns from BLN employees. The handling of FCRs was also reviewed and found to be basically identified to the WBN process. Consequently, no conditions adverse to quality were identified.

Concerns EX-85-058-001 and IN-85-286-001 allege that craftsmen must work without workable design documentation. Typical examples of such work include fabricating and installing hangers and routing conduit. The conduit routing concern had been investigated by the WBN Project Managers Office (PMO) before the ECTG investigation.

The WBN PM0 report was reviewed to determine if it was responsive to The WBN PMO and ECTG investigations revealed that for the concern.

economic and scheduling reasons, field " design," fabrication and installation of some hangers and conduit is an industry-wide practice.

Such practices allow resolution of physical interferences with previously installed equipment and piping in a cost effective The design integrity of field engineered safety-related manner.

installations is assured by a design review of the as-built Only after design approval of the as-built configuration.

configuration is documented can the field engineered installation pass final inspection. The BLN ECTG evaluation corroborated the WBN findings. Therefore, the cited concerns were factual but did not represent a condition adverse to quality requiring corrective actions.

alleges that WBN civil engineers are assigned Concern IN-85-388-007 to label pipe and that they do not have the expertise to competently execute that task. The evaluation nethodology used at both VBN and BLN was to determine who was responsible for pipe labeling at each plant and, if civil engineers were responsible, to interview craftsmen and engineers to determine the extent of the problem.

The BLN evaluation revealed that mechanical engineering unit (MEU) system engineers are responsible for pipe labeling as documented in MEU-Standard Oparating Procedure (SOP)-616 " Identification of Piping," paragraph 5.1.

Therefore, IN-85-388-007 was not generically applicable to BLN.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 76 0F 93 At WBN, however, civil engineers are responsible for pipe labeling.

Interviews with civil engineers and steamfitters substantiated the Civil engineers commonly do require the allegations of the concern.

assistance of knowledgeable craftsmen one mechanical engineers to correctly identify pipe. However, while such a situation does not seem to be an efficient use of resources, it does not necessarily mean that a condition adverse to quality will result.

The ECTG evaluator inspected piping in four different safety-related In addition, systems and found no examples of mislabeled piping.

even if piping was mislabeled, the consensus of those interviewed, including an assictant Sift engineer, was that mislabeled pipe does During not present a problem aven during an operational emergency.

such an emergency, sys tem opera'.ing instruction (SOI) manuals are used instead of relying on pipe labels. Therefore, IN-85-388-007 was found to be factual but it does not represent a condition adverse to quality.

Concern IN-85-397-001 stated unit 1 drawings are marked " opposite hand" and used for unit 2 construction activities which can create The concerns was evaluated by interviewing contractor confusion.

personnel with nuclear experience outside TVA, craft foremen and The consensus of opinion was that the use of " opposite engineers.

hand" prints was common industry practice.

It was also agreed that

" opposite hand" prints do represent an increased level of complexity for those who use them, but the increased complexity should represent no great impediment to their use.

Consequently, the conclusion drawn from the ECTG evaluation was that the concern was factual but does not represent a condition adverse to quality.

Concern IN-85-388-009 asserts that civil engineers cannot support The concern work in unit 1 because they have no security clearance.

was addressed by a WBN PM0 report filed in response to this Civil engineers currently have access to unit 1 ff concern.

One of the six escorted by an individual with a security clearance.

civil engineers in the unit had a security clearance at the time of the ECIG evaluation. In addition, the other five civil engineers in the unit could obtain a security clearance for unescorted access by l

taking the required training courses.

Since the civil engineers do have access to unit 1, albeit limited, the concern was determined not be factual.

Conclusion Of the ten concerns evaluated as questionable ongineering practices, three concerns were found to be factual and to require action to 8

correct a CAQ. The other seven concerns were either not factual or did not identify a CAQ requiring corrective actions.

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 77 0F 93 The three concerns requiring corrective action documented CAQs that resulted from the failure of construction engineers to adequately The cited deficiencies were recognized by support craftsmen.

DNC-WBN management personnel and addressed by the issuance of WBN-QCI 1.60.

4.7 Improper Installation This issue is correlated with only one concern, XX-85-101-002, which The concern states " Improper installation of was identified at SQN.

non-nuclear system could adversely affect public health and safety."

Additional information was sought by the ECTG evaluator from the QTC No further expurgated files to perform a meaningful evaluation.

information was found. Consequently, the scope of the evaluation was limited to the explicit, but vague, scope of the concern.

The concern is limited to safety concerns resulting from the Non-nuclear systems, improper installation of non-nuclear systems.

assuming the term is understood correctly, do not normally perform safety-related functions. Therefore, by definition, improper installation of a non-nuclear system could not adversely affect public health and safety.

It is possible, however, to interpret the term "non-nuclear systems" more broadly and thereby include some safety-related systems such as auxiliary feedwater, safety-related electrical power system, essential air systems and others that do not come into contact with radioactive materials in the category of "non-nuclear systems." If the CI intended such systems to be included in the scope of his (or her) concern, then the concern However, note that the concern is stated could certainly be true.

as a policy concern and not as allegation of a specific deficiency.

In that context. TVA has documented the safety significance of all plant features in the SQN FSAR and established design parameters and QA requiremetns with the intent of assuring the integrity of TVA's success in realizing this objective safety-related systems.

is debatable but the TVA policy on this matter is clear:

systems that are required to protect the safety and health of the public are to be built, maintained and operated with a commitment to quality Therefore, the concern was not found to be and in a safe manner.

factual.

Conclusion Concern XX-85-101-002 could not be determined to be factual due to Other the broadness of scope and lack of definition of the concern.

work control evaluations did not reveal problems in the area of i

improper installations; therefore, no further evaluation was necessary.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 78 0F 93 5.0 COLLECTIVE SIGNIFICANCE Manar,ement Effectiveness The work control concerns included in thic subcategory are unique in the construction category in that they are primarily targeted on The administrative processes rather than specific hardware deficiencies.

few hardware problems cited are used mainly as examples of what are more ECTG has classified fundamental concerns with the construction process.

these concerns as " work control" concerns. This seems appropriate because usually the problems cited are in the process that can result in hardware CAQs.

In some cases, the CI does not even contend that a deficiency necessarily results from the problem he was concerned with.

Instead, the CI said that events led to wasted time and effort, poor communications between engineering, craft and QC, delays, circumvention of procedures, and inconsistencies in the implementation of procedures. These concerns did not document problems with obvious adverse safety consequences; however, there was obviously an adverse effect on the CI's morale, enthusiasm and confidence in the work control system.

Erosion of employees' attitudes cannot f all to eventually degrade work performance and therefore the quality of the plant itself.

If the work control problems are programmatic in nature, then, by definition, the problems potentially affect all workers subject to the program. Consequently, the impact of a programmatic deficiency in the work control program could extend to every facet of the plant. The obvious questions then are "Do we have a programmatic work control problem?" and "flas work performance been significantly degraded as a result of the problem"?

1 Ninety-six of the one hundred concerns correlated with work control were identified at WBN.

If there is a programmatic work control problem at l

any TVA plant, WBN is that plant. WBN management acknowledged the l

I existence of work control program deficiencies when SCR-6497 was generated.

SCR 6497, which was entitled " Inadequate Construction lR2 i

Work Control," upgraded 18 NCRs describing a significant condition l

adverse to quality in that " unauthorized work performed on documented features resulted in discrepancies between the as constructed condition l

l and documentation as reflected by the RAP (Records Accountability Program).

In addition to SCR-6497, TVA QA audito. INPO findings, and NRC inspection report deficiencies have been filed documenting diverse work control WBN management recognized the r.ignificance of all these problems.

deficiencies in an informal memorandum issued to all WDN engineering 25, 1986. The memorandum announced the impending personnel on February release of a new work control procedure QCI 1.60, because of "... Work e

control methods which have been confusing and ineffective." Therefore, there is ample evidence that programmatic work control problems erinted at WBN.

i TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 79 0F 93 Havint, recognized that there was a work control problem, the next guestion to answer was how badly work performance was affected by the program deficiencies. Unfortunately, there was no way to answer the question. No data was available on which a quantitative analysis of the work control program could be performed. Therefore, it was not possible to make informed judgements about where work performance declined or the degree to which work performance was affected. The reason for this is that there was no provision made in the program for the generation and collection of performance data on an ongoing basis. This also obviously means that construction management has no capability to monitor the performance of the work control system. This means that engineering's performance in specifying the tasks to be performed, the craft's performance in executing the tasks, and the QC inspector's perfor mance in certifying the adequacy of the work is not systematically evaluat.< by management. If one believes that an effective work control system must be properly managed, as well as properly executed, then the lack of management information feedback loop must be considered to be a problem with the work control system, as well as the problems noted in the concerns.

Conclusion Upon review of the history of work control at WBN, it is apparent that management's failure to systematically monitor and analyze work performance has necessitated a trial-and-error approach to improvements in the work control program.

As noted previously, QCI 1.60 was issued to upgrade the work control program only after overwhelming evidence from diverse sources forced recognition of deficiencies in the work control In the future, effective work control will be achieved and program.

maintained when management can define its work control objectives and devise measuring systems to monitor the critical parameters of the work control program.

Employee Effectiveness The concerns included in this subcategory imply, and the ECTG evaluation confirmed, that employee effectivonoss has been degraded by inadequate work control information and support. The high incidence of rework, incomplete, obsolete or incorrect information, poor coordination between ongineerinf, cr.stts, and QC, procedure inadequacies and inconsistent implementation af procedures led to employee perceptions of manatorial ineffectivenece and substandard work. The following quotes from work conteci concerns illustrate this point.

" Integrity is degraded by rework..." (IN-85-057-003)

"Almost every platform and ladder in the plant has boon modified / replaced o

due to lack of forethought" (IN-85-999-001)

L

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2 PAGE 80 0F 93 "The craft many times are working to an obsolete drawing" (IN-86-261-002)

"... (management) will bypass the G-procedures to get the job done" (PH-85-035-005)

" lack of communication between crafts and engineering causes long delays in completing work" (IN-85-787-001)

" Work packages received by the craft are incomplete and inaccurate" (IN-85-480-006)

Technical _ Adequacy The regulatory requirements that apply to work control at TVA's nuclear plants are speciflod in 10 CFR Part 50, Appendix B, General Design Critorion V as follows " Activities affecting quality shall be proscribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance critoria for determining that important activities have been satisfactorily accomplished." The ECTG ovaluation identified neither quantitative nor qualitative acceptance criteria incorporated into the work control program for the purpose of notifying construction management that work control activities are being satisfactorily accomplished.

6.0 Causes This section of the subcategory report addresses the proximate situations and agents responsible for the negative findings discussed in the collective significance analysis. Actions required to provent recurrence of the causes identified will be detailed as well. The causes identified, as well as the actions requirod to prevent recurrence are site-specific since establishment of work control policios and procedures is the responsibility of each site organization. Since work control concerns were found to have collective significance at WBN only, the causes discussed were identified relative to WBN only.

As detailed in section 5.0, the ECTG work control findings indicated that the WBN work control concerns are indicative of a need for more effective managerial oversight of the work control process. To accomplish this goal WBN construction management needs performance data to determino if the work control program is functioning as intended and, if not, whore breakdowns are occurring and why. There are no provisions in QCI 1.60 for generating performance data and providing performanco data to management.

In order to generate such data, the critical parameters of work control must be defined and appropriate measures chosen to describe thoso parameters.

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2 PAGE 81 0F 93 Recognition of the types of errors that prevent the work control program from controlling the critical parameters will provido the understanding necessary to effectively monitor and therefore manage the program.

7.0 CORRECTIVE ACTIONS 7.1 Conoric Corrottive Actions No specific ONP programmatic corrective actions were found to have been taken to address work control problems.

However, in accordance with the Nuclear Procedures System Policy signed by S.A. White on June 6, 1986, the ECTG perceives a need for a DNC corporate review of work control policies to ensure that the benefits realized through oxperience are shared equally by all DNC organizations.

(CATD 11200-NPS-01)

The DNC corporate response to this finding was as follows:

Work on the Nuclear Standards Program is currently in progress.

May 1987 is the targot date for completion of the Standards.

Subsequent to the completion of the ONP Standards, implementing standards for the Nuclear Construction Program Manual can bo initiated. There will be division level Construction Engineering Procedures (CEPs), General Construction Engineering Procedures (GCPs), Modification and Addition Procedutos (MAPS), and Technical Performance Procedures (TPPs) written to provide a corporate position for standardization of the construction and modification work control program. There may exist some differences between the sites, but thic is due to s)te-specific requirements.

72 Sito-Speelfic Corrective Actions WBN initiated a completo overhaul of the WBN work control system before ECTG was established that addresses many of the specific problems cited in the work control concerns. WBN QCI 1.60. R0 implomonted the corrective actions deemed necessary by WBN construction management and the provisions that address the factual issues identified in this report are detailed in the following issue specific sections.

However, the ECTG investigation identified a programmatic weakness in the current work control program that was not addressed by WBN construction management.

The ovaluators concluded that management has failed to identify critical performance indicators and therefore cannot monitor the work control e

TVA EMPLOYEE CONCERNS REPORT NUMBER:

112(",

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2 PAGE 82 0F 93 program's perforn.ance.

If the current work control program is not adeguate, WBN management will not be aware of problems until significant breakdowns have been documented by the CAQ reporting system. The ECTG ovaluators are of the opinion that this problem should be addressed at both the DNC corporate level and by WBN construction managers.

(CATD 11200-WBN-01)

The WBN-DNC response to this finding was as follows:

WBN will develop and implement SOP-49 entitled " Surveillance of Critical Paramotors in Work Control." This procedure will provide for an initial representative sample, based on recognized statistical sampling methods, of the work control program. After completion of the initial sample and resolution of identified problems the procedure will be applied on an as-nooded basis to investigate adverse trends in the work control program.

The program will initially use existing CAQs and IRN trends as a means of identifying problem areas and will review work plans in the pre-issue, in-process, and post completion stages in order to apply remedial actions at the source of the problem. The program will considor the following parameters as a minimum:

Accuracy of estimates Records Accountability Program (RAP) completeness of specified unique identifiers promptness of input / updates comprehensiveness of inspections Quality of work Quality of pre-work walkdown Wort description Lovel of detail Appropriatenosa of hold points Field presence of engineers during installation phase e

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 83 0F 93 Field presence of craft supervision during installation phase Necessity of revisions Scope Size Items to be installed consistent with schedule logic Existence of informal scope changes Workplan accessibility to craftmen Adequacy of boundary descriptions for partial inspection Overall content Proponsity of craftsmon to stop work when uncertain Material availability Correct / current drawings Appropriate safety precautions Initial operations release impact This procedure will be developed and implemented by May 1, 1987, and should assure that the work control program meets all desired objectites.

Note that with the exception of poor planning and coordination, none of the issues were factual at SQN or BLNi therefore, for the other issues the corrective actions indicated are pertinent to WBN only.

7.2.1 Unauthorized / Undocumented Work This issue was found to be factual and to require corrective actions, some of which were incorporated into QCI 1.60.

QCI 1.60 now allows only one formal method of authorizing work thus simplifying the control process and allowing fewer chances for error.

Fewer inspections will be missed for n

REPORT NUMBER: 11200 TVA EMPLOYEE CONCERNS

~

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 84 0F 93 i

several reasons:

all inspections must be listed in the workplan, ONP will review all unit I workplans, and both the responsible engineer (RE) and the craft foreman must sign the closed workplan indicating that all work including inspections is complete.

In addition, the maximum size of workplans is now limited to approximately 3000 manhours which makes it easier to ensure that all the applicable requirements have boon specified.

However, there is still no workplan review to ensure that the correct inspections or tests are specified.

In addition, there is no independent review of the RAP updates entered by the RE. Errors in these arean have been a significant problem in the past.

(CATD 11200-WBN-02)

The WBN-DNC response to this finding was as follows:

WBN-QCI-1.60 has recently been strengthened in the area of accuracy of RAP inputs / updates. This was primarily in response to adverse trends identiflod through the project's IRN trending mechanism which identified rejotted inspections due to failure to update the RA'i.

The present program provides for the following:

1) The responsible engineer specifies UNID's and associated tests affected by the workplan, 2) A designated individual then makes adjustments to the RAP. The signatures for these activities establish accountability for these functions on Attachment D to the workplan. This accountability was lacking in the past and now serves as an auditable link between drawings, the RAP and hardware. At the conclusion of the activity, the QA Records Review Program updates the RAP.

Another peoblem not addressed by QCI 1.60 was that of unauthorized work. The ECTG evaluation failed to identify any procedural feature or program to prevent the recurrence of unauthorized work.

(CATD 11200-WBN-03)

The WBN-DNC response to this finding was as follows:

Construction management is aware of longstanding problems in the area of unauthorized / uncontrolled work. One of our primary motives in consolidating work control procedures was to address this problem. Our work control program is subjected to continual review at all lovels of the organization.

The desired result of this review program is to incorporate suggestions and enhancements to improve the

f I

l TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 85 0F 93 efficiency and the effectiveness of the program. We have recently placed additional management emphasis on craft foremen and supervisors responsibilty to ensure that workplans are available at the appropriato location in the field. This is to enhance their ability to manage the work and prevent unauthorized work. Another recent program enhancement requires craftsmen to document workplan numbers on timo cards. This readily indicates any excessive time charged to a workplan and discourages work on unauthorized activities. These stops should greatly reduce instances of unauthorized / uncontrolled work.

A problem related to the problem of unauthorized work was also noted involving work performed under ONP procedure AI-8.5.

Personnel working under AI-8,5 havo performod work in the past on safety-related components without assassing the impact on the RAP. This practico has resulted in confusion regarding whether or not unauthorized work actually occurred. This issue should be addressed either by operations personnel or at the CNP corporate level.

(CATD 11200-NPS-02)

The ONP Division of Nuclear Services response to this finding lR2 was as follows:

l The Document Control and Records Management Branch (DCRMB).

DNS has been reorganized to provide program support to site records management units.

One of the primary responsibilities of those program managers is to examino existing records systems and recommend and implomont needed changes.

The draft DCRM directive on Record Manatomont states that one of the goals of this program is " Consistency - Provide consistency of practico between the various TVA document control / records management systems.

As part of the DCRMB five-year plan, currently under development; a method of easily retrieving records /filos on any work performed on QA components will be developed. The system development will allow for retrieval by plant feature or unique identifier.

Although system development has not begun, it is anticipated that historical records such as BFN, SQN. WBN construction records will not be input into the data base.

e w

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2 PAGE 86 0F 93 Implomontation will be in accordance with the five-year plan which is scheduled to be issued by January 1988.

Further action is also required from ONP to substantiate their determination that SCR 6497 is not applicable to WBN unit 1.

SCR 6497 documents unauthorized work that resulted in configuration problems on unit 2.

Since the work on unit I was performed by basically the name people using the same proceduros (or no proceduros), unit 1 may exhibit the same deficienclos as those noted on unit 2.

(CATD 11200-WBN-09)

The WBN-DNC response to this finding was as follows:

SCR 6497 was reviewod for appilcability to unit 1 and it was determined that the SCR did not identify a condition adverso to quality on unit 1.

The lack of propor work control does not necessarily indicate a condition adverse to quality. The basis for determining that a condition adverse to quality does not oxist was as follows:

1.

Work control is a program to be utilized to ensure that an end is achieved. On unit 1 the end of the construction program has been achloved in that all the systems required for unit I have been transferred to the operating organization.

2.

The system transfer process for unit 1 included numerous reviews and walkdowns which would have identiflod and corrected any work control problems.

3.

The Peroperational testing program has virtually boon completed and the systems have been proven to be operable through the performanco of various surveillance instructions.

4.

Configuration control could be the only condition adverse to quality resulting from poor work control and it was already being addressed by SCR 6297.

To assure that the position outlined above is sufficient, the following additional stops will be followed All NCRs generated as a result of the work roloaso review program on unit 2 will be evaluated for applicability on unit 1.

i

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2 PAGE 87 0F 93 Additionally, a corporate study is being performed to datormine the applicability to unit 1.

Any corrective actions resulting from the above-listed actions will be added in a revision to this Corrective Action Plan (CAP).

The ECTG ovaluation also identiflod correctivo actions that were taken to resolve configuration control problems with electrical items.

Inspection procedures now cover labeling of electrical components. Vendor wiring in unit 2 control panels are now being inspected. The electri:a1 engineer responsible for the unit 2 control room reviews all ECNs for labeling changes.

While these changes address some of the def:cienclos identified during the ECTG evaluation, other problems were identified that may require further line mat.agement action.

The vendor wiring inspection criteria is vague and requires the inspector to interpret what is " appropriate".

(CATD 11200-WBN-05)

The WBN-DNQA response to this finding was as follows:

The problem with inspection criteria for vendor labeling is being reviewed by DNE and DNQA to better clarify the criteria on how labeling will be handled in the future and implemented into the procedures (Soo NCR 7225). The schedule for identifying all safety related panels which require reinspection and to bring the as-designed drawings into agrooment with the as-built drawings is currently being proposed.

The number of vendor wired panels inspected or scheduled to be inspected was not clear (CATD 11200-WBN-06).

The WBN-DNE response to this finding was as follows:

1.

Labeling problems do exist in vendor wired safety-related panels.

Contributing factors to those problems includedt a.

Vendor labels do not in all casos match the latest vendor drawing (the vendor drawing was not "as-built" by the vendor).

REPORT NUMBER:

11200 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 88 0F 93 b.

Some TVA modifications to vendor wired panels were made prior to the inspection requirements for verification of labeling being incorporated into applicable procedures, The system tranfer program does not require vendor c.

drawings to be as constructed.

2.

The labeling problems are not considered to be a significant safety concern nor to require resolution prior to fuel loading for WBN. The basis for this includes:

Vendors supplying safety-related equipment have a a.

qualified QA program as required by TVA NQAM.

b.

Point-to-point inspection verification of modifications performed by TVA ensures configuration adequacy (QCP-3.06-2 and MAI-5).

Proop testing program proves operability.

c.

d.

Non-signficant NCRs W-205-P and W-237-P.

e.

Maintenance procedures require that permanent labels be in agreement with the controlling drawing before maintenance is performed (AI-9.2).

3.

Documentation for equipment in the QA program should be consistent.

Based on 1 and 2 above, necessary changes will be made to bring the TVA drawings into agreement with the as-built labeling for all safety-related panels. The labeling upgrado program detailed in 4 will be done on an after fuel load (AFL) schedule for tranferred panels and prior to tranfor of unit 2 panels, if feasible.

4.

PIR WBNWBP8770 has boon initiated to document these labeling problems and to control necessary correctivo actions to bring TVA drawings tnd as-built labeling into agreement for vendor wired safety-related panels.

A preliminary definition of corrective actions under consideracion includet All vendor wired safety-related panels requiring a.

re-inspection will bo defined by DNE.

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2 PAGE 89 0F 93 b.

A procedure will be prepared by DNE to coordinate the efforts of DNE, NUC PR, and DNC in bringing TVA drawings into agreement with as-built labeling configuration.

Scope, organizational responsibilities, correction methods, acceptance criteria and other procedures requiring revision (such as inspection and system transfer) will be clearly defined in this document.

c.

Transfer of Unit 2 equipment after a basoline date defined in the procedure of 4 (b) will require that associated TVA drawings and as-built labeling be in agreement.

5.

No additional corrective action or action to provent recurrence is necessary in the DNE procuremont program due to the current requiremont that vendors of QA equipment supply cortified as-built drawings with shipment. This requiremont was instituted based on the direction of a November 26, 1985 policy memorandum (843 851120 928).

In summary of items 1 thru S. PIR WBNWBP8770 will be initiated. The disposition of this PIR will define corrective action for CATD 11200-WBN-06 in greater detail and will include a schedule for completion of the major tasks involved. The disposition of the PIR will be issued by September 1, 1987.

Not all electrical engineers are receiving " documentation only" ECNs.

(CATD 11200-WBN-07)

The WBN-DNC response to this finding was as follows:

DNC Modifications reviews all ECNS on tranferred equipment and is responsible for the implementation of the ECNs. AI-8,5 and AI-8.8 require all ECNs be documented via a workplan which includes documentation only ECNs.

For documentation only ECNs, the cognizant engineer (COG ENGR) is still required to verify that the field conditions do match the design changes, and then the COG ENGR is required to write a documentation only workplan to as-construct the drawings. The documentation only workplan goes through the same workplan review that field work workplans to through. They are reviewed (for CSSC systems) as a minimum, by the section supervisor, and all sections that the ECN may affect, tuch as

TVA EMPLOYEE CONCERNS REPORT NUMBER:

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2 PAGE 90 0F 93 Electrical Maintenance, Mechanical Maintenanco, Instrument Maintenanco, and Engineering. They are further reviewed by Industrial Safety Section. Test Section, Rad Control, Operations, SQA staff PORC Chairman, and the Plant Manager, prior to approval to as-construct the drawings.

For Non-CSSC workplans, the same review is completed, except the SQA staff and PORC Chairman are not required in the review.

Prior to transfer of equipment of systems to ONP, the drawings are compared with the fleid via walkdown procedures and transfer proceduros, and thoso items that are found deficient are olther corrected, added to a Punchlist, or are reflected on the OWIL of ONP. Therefore, at tranfer all items are as-constructed and any further work, such as ECNs, are worked under the abovo noted program, such as AI-8,5 or AI-8.8.

The probability of error with DNC Modifications not implementing field changes on documentation only ECN is minimized by the review proceduro.

It is true that if the ECN were addressed correctly when it is issued from DNE, the problem would not exist. The terminal block strip label problems were addressed under NCR W-205-P.

We feel DNC Modifications and ONP have a working program and no further changes are required.

DNE's response to 11200-WBN-08 will resolvo any future problems concerning this issua.

Any further discropanclos will be resolved under the corrective action program.

In addition, the " documentation only" ECN classification may be inappropriato in some cases.

(CATD 11200-WBN-08)

The WBN-DNE response to this finding was as follows:

1.

Revise Watts Bar Engineering Project Procedure WBEP-EP 43.02 to completely describe the types of changos that can be considered documentation only chanlos. This revision will be coordinated with DNC (U2), MODS (U1) and Maintenance to ensure consistent plant understanding. WBEP personnel will be trained.

2.

Perform a multi-disciplino review of a representativo sample of documentation ECNs to determino, based on the revised WBEP-EP 43.02, if drawings issued por these ECNs involved fleid work.

The review sample will consist of all documentation ECNs issued from

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 91 0F 93 January 1, 1986 until the revised EP is issued, and will ensure that labeling issues identified in report 11200 are adequately evaluated.

3.

Prepare CAQs (based on review of the documentation ECNs) to identify conditions adverse to quality if required.

7.2.2 Craftsmon Doing Engincoring Work This issue was found to be factual but did not represent a problem. No corrective actions were required.

7.2.3 Poor Planning and Coordination This issue was found to be factual and to require corrective actions at SQN, WBN, and BLN. The corrective actions pertinent to each site are discussed in the followint sections.

Scouovah Poor planning and coordination was correlated with only one concern, MAS-86-003, that pertained to SQN. The problem involved discrepancies between fuse data noted on design drawings and the installed fuses. (CATD 11203-SQN-01)

Corrective actions were initiated at SQN before the ECTG investigation to correct the deficiencies. SQN maintenance personnel will verify that IEEE class IE and penetration cable protection fuses and fuse identification tags are verified to match design specifications. Any discrepancies identified will be resolved by DNE and the drawings revised if necessary.

In addition, administrative instruction AI-16

" Fuse Control" will be revised to incorporate DNE issued documents and requirements.

Dollefonto Poor planning and coordination was the only issue evaluated at BLN that requires corrective actions.

The BLN personnel interviewed indicated that BLN Standard Operating Procedure (DNP-SOP)-2, " Work Packages," should be revised to reflect the current organizational structure (CATD 11200-BLN-01) and additional training in work control procedures should be provided to all appropriate personnel. (CATD 11200-BLN-02) i

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 92 0F 93 The BLN-DNL response to these findings was as follows:

BLN-SOP-2 will be revised by April 30, 1987, to accurately reflect current organizational responsibilities.

1.

Develop a Training Module (TM) on work control and work implementation documents. Completion date August 31, 1987.

2.

Site personnel will be trained on the TM on an as-needed basis which will be determined by project management.

Watts Bar WBN managers recognized poor planning and coordination to be a major program deficiency in the work control program. When QCI 1.60 was issued, program changes were incorporated to address the problems.

The responsible engineer (RE) has the charge of writing a workplan that provides detailed steps by which work is identified, planned, approved, performed and inspected. The RE is responsible for identifying the need for and determining the scope of the workplan. The RE will review the plan for impact on other features and develop a step by step list of work and hold points on QCI 1.60 Attachment H.

The RE will determine the needed documents for the workplan, such as drawings, weld assignment sheets, specifications, procedures, vendor manuals, and the controlled documents.

These documents will be included in the workplan. During the preplanning, the RE and craft representative will walkdown the work included in the plan. They may request anyone they feel will be of assistance to them, such as the Project Control Group, Quality Control and safety engineers, to accompany them on the walkdown. Before the workplan is issued, the RE must also check on the availability of materials, order any materials not on hand, and submit material request forms to secure materials for the workplan in question. The RE will closely monitor ongoing work and provide assistance and, upon completion of work, the craft foreman and RE will sign QCI 1.60 Attachment A, concurring that all field work (including field inspection work) is adequately completed. The craft foreman returns the workplan to the Workplan Control Group. These measures should address the poor planning and coordination concerns at WBN.

l

TVA EMPLOYEE CONCERNS REPORT NUMBER:

11200 SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 93 0F 93 7.2.4 Inadequate Walkdown and Walkdown Information This issue was not found to be factual and therefore corrective actions were not required. A related problem involving as-constructed drawings was identified but corrective actions for that problem will be specified in the disposition of SCR 6297.

7.2.5 Poor Quality of Work Packages and Work Package Control Several features of WBN QCI 1.60 address the concerns included in this issue. The maximum size of workplans is now limited so that the work can be handled by one crew per shift. The constructability walkdown conducted before the workplan is issued should help identify missing information and ambiguous directions. The RE also has clear responsibility for updating the RAP. These improvements in the work control program address the weaknesses identified in this issue.

7.2.6 Qtestionable Engineering Practices The only concerns found to be factual in this issue involved i

engineering control of field work. QCI 1.60 now requires a constructability walkdown by the responsible engineer (RE) and craft representative, close monitoring of ongoing work by the RE and hand delivery of revised workplans by the RE to the field. Assuming that these requirements are met, engineering control of field work should be improved.

7.2.7 Inadequate Installation This issue, which pertained to SQN only, was found not to be factual and therefore did not require corrective actions.

8.0 ATTACHMENTS 8.1 Attachment A " Subcategory Summary Table and List of Concerns" 8.2 Attachment B. " List of Evaluators" 8.3 Attachment C " List of Concerns by Issue" e

i

OtttmillLLif~L3

-PAGE

=

1 TENNESSEE VALLEY AUTHORITY RUN TIME - 12:51:16

/REQUEllCY

- REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)..

RUN DA1E - 12/02/86 tEF EREllCE-

- ECPS131J-ECPSI31C OFFICE OF NUCLEAR PDHER-JilP - ISSS - RHM LIST OF EMPLOYEE C0tiCERN INFORMATICH

'ATEGORY: CD C0!!ST RUCTI0ll-PROCESS SUBCATEGORY ll2 HORK PLAN /HORK CONTROL REFERENCE SECTION #

GENERIC APPL QTC/NSRS P

CATEGORY - CD C0!1CERfl SUB PLT BBSH INVESTIGATION S

CONCERN SUBCATEGORY - 112 '

flu!!BER CAT CAT LOC FLQB REPORT R

DESCRIPTION EVALUATION PROCESS:

4 SS,TOO MANY TIMES DRAHIllGS HERE NOT FOL LHED BY CONSTRUCTI0tt RESULTING IN FC SECTION: 3'2*1 BLt4DilEEC8 5-ll CD 112 BLil II Y N N RIF LET A. LOT OF GOOD FINDINCS:

REPORT RS AND NCRS.

PEOPLE GO AND KEPT SOME VERY QUEST 10 SECTION: 4.1 NABLE PEOPLE.

l INSTALLATION OF CONDUIT TAKES PRIORI EVALUATION PROCESS:.

1 NO l EX 002-004 CO 112 HBil if Y ll Y TY OVER DESIGN AND INSTALLATION OF P CREATES DIFFICULT DESIGN AND SECTION: 3.2.3 REPORT IPING.

AS-BUILT CONDITI0liS FOR PIPE RutlS.

FINDINCS8 T50088

.l CI HAD HO FURTHER SPECIFIC DETAILS.

SECTION: 4.3 A CERTAIN FOREMAtt IS OtiLY CONCERNED EVALUATION PROCESS:

SR EX 048-003 CD 112 HBil N ti if Y HITH PRODUCTION tl0T SAFETY.

Tile FOR T50168 f1P 710 K-FORM EMAN BYPASSES PROCEDURES AND DOES tiG SECTION: 3.2.1 C0llSR FINDINCS:

T GET PROPER PAPERHORK FIRST, IIAMES AtID DETAILS T SECTION: 4.1 UCTION CONCERN.

t O THIS SPECIFIC CASE ARE KN0llN TO QT C AND ARE HITHELD TO MAINTAIll CONFID a'

ENTIALITY.

ENGINEERING SH0HS VERY POOR PLAHilIllGEVALUATION PROCESS:

l SR

' EX 052-003 CD 112 HBil if Y N Y IN MUCH OF THEIR HORK PACKAGE PREPA SECTION: 3.2.5 150172 RATION.

EllGINEERING IS Tile BIGGEST REPORT PROBLEM, NOT THE CRAFTS.

THE LAYOUT FINDINCS:

S ARE It4 ADEQUATE HilEti GIVEli TO THE C SECTION: 4.5 I

RAFTS. THEY OFTEtt OMIT IMPORTAllT DE CONSTRUCTION DEPT. CONCERN.

TAILS.

CI HAS NO ADDITI0llAL INFORMATION.

l HO FOLLOH UP REQUIRED.

CONDUIT IS FREQUENTLY TORil OUT HHEli EVALUATION PROCESS:

EX 052-006 CD 112 HBil 11 Y ll Y I-85-669-HBil SR IT SH0HS ON THE DRAHINGS AS BEING IN SECTI0ti: 3.2.1 REPORT PLACE AND IT IS DOCUMEllTED AS DEIND THERE. CONSTRUCTION DEPT CollCERN.

FIllDINGS :

T50171 CI HAS NO FURTHER IliFORMATI0ll.

SECTION: 4.1 MOST ENGINEERS ARE L AZY AND Doll'T.D0 EVALUATION PROCESS:

SR

• EX 053-006 CO 112 HBN ti il N Y THEIR J08.

THEY SELDOM TAKE THE t4E SECTION: 3.2.6 8

T50171 tIP 710 K-FORM CESSARY TIME TO RESEARCH PROBLEMS BEFINDINGS:

FORE PUTTING HORK PACKAGES TOGETilER.

CONSTRUCTION CONCERN. CI HAS 110 A SECTION:

4.6 DDITI0tlAL IliFORMAT10tl.

i C0llCERilS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY HUMBER.

~

I'

1 i

ATTACNHENT A REFEREllCE

- ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY PAGE 2

Rull TIME.- 12:51:16 FREQUEtlCY

- REQUEST OFFICE OF NUCLEAR P0HER RUN DATE - 12/02/86 EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

OllP - ISSS - Rilft LIST OF EMPLOYEE CONCERN INFORMATION

'RTEGORY: CO CallSTRUCTION-PROCESS

. SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GENERIC APPL QTC/NSRS P

REFERENCE SECTIDH B CollCERil SUB PLT BBSH INVESTIGATION S

CONCERN CATEGORY - CO-llul1 DER CAT CAT LOC FLQB REPORT R

DESCRIPTION SUBCATEGORY

'112 EX 058-001 CD 112 HBil il il 11 Y SR T!!E HORKING KN0HLEDGE OF SOME ENGIllE. EVALUATION PROCESS:

T50184 11P 717 K-FORM ERS AT HATTS BAR IS VERY QUESTIO!!ABL' SECTION: 3.2.6 E.

SOME ENGINEERS HAVE TOLD THE CI FINDINGS:

TO GO AHEAD AND BUILD THIllGS THE HAY THEY NEED TO AND EllGINEERIllG HOULD SECTION: 4.6 CATCHUP HITH PAPERHORK LATER. CONST RUCTION CONCERN. CI HAS NO ADDITION AL INFORMATION. CI COULD fl0T PROVID E NAMES.

EX 058-002 CO 112 HBil 11 Y N Y SR ENGINEERING HOULD QUITE OFTEli TRY 10 EVALUATION PROCESS:

T50184 REPORT AVOID HRITING FCRS HHEN IT HAS llECE SECTION: 3.2.6 1

SSARY TO MAKE FIELD CHANGES AT UllIT l

FINDINGS:

2 - HBilP. CONSTRUCTIull CollCERN. CI HAS NO ADDITI0llAL INFORMATI0ll OR NA SECTION: 4.6

.MES.

EVALUATION PROCESS:

EX 082-002 CD 112 HBil 11 Y N Y SR ENGINEERS ASK FITTERS To DO HHATEVER T50187 HP 710 REPORT IS NECESSARY TO ACCOMPLISH A JOB All SECTION: 3.2.2 D THEY HILL DRAH IT UP LATER. CONST FINDINGS:

RUCTION DEPT CollCERN. Cl HAS 110 ADD SECTION: 4.2 ITIONAL INFORMATI0ll. GENERIC CollCER N.

EX 085-001 CO 112 Ilati il Y H Y SR ENGINEERS TELL FITTERS TO DO HHATEVE EVALUATION PROCESS:

T50192

!!P 710 REPORT R THEY HAVE TO DO TO MAKE IT RIGili A SECTION: 3.2.2 ND THEY HILL MAKE DRAHING CHAllGES LA FINDINGS:

TER, CONSTRUCTION DEPT. CollCERil. C I HAS NO ADDITIONAL INFORMATION.

-G SECTION: 4.2 l

ENERIC CONCERN-EX 094-002 CO 112 HBH 11 Y N Y NO PEOPLE CONTROLLING HORK PACKAGES flee EVALUATION PROCESS:

T50190 REPORT D TO BE BETTER ORGANIZED. CONSTRUCT ION DEPT. CONCERN. CI HAS NO ADDITI SECTION:

3f.5 OllAL INFORMATION. -GENERIC CONCERil-FINDINGS:

?

SECTION: 4.5 EX 104-002 CD 112 Hall if Y N Y SR ENGINEERS TELL CRAFT (KN0Hil) TO "FIX T50190 HP 710 REPORT IT AND HE'LL DO THE PAPERHORK LATER

." CONSTRUCT 10ll DEPT. CollCERil.

CI-EVALUATION PROCESS:

HAS NO ADDITI0llAL INFORMATI0ll.

SECTION: 3.2.2 FINDINGS:

SECTION: 4.2 C0llCERNS ARE GROUPED BY FIRST 3 DIGITS"0F SUBCATEGORY NUMBER.

ATTACHMENT A

?3.

REFEREllCE

'- ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY PAGE;

, FREQUEllCY

- REQUEST OFFICE CF NUCLEAR P0HER RUll TIME - 12:51:16' ONP - ISSS - Ril!1 EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DAYEJ-12/02/86' LIST OF EMPLOYEE CONCERN INFORMATION ATEGORY: 00 ColeSTF.UCTI ON-PF.3 CESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GEllERIC APPL QTC/HSRS P

REFERENCE SECTI0ll I CutlCERN SUB PLT BBSH

. INVESTIGATION S

CONCERN CATEGORY - CO NUllBER CAT CAT LOC FLQB REPORT R.

. DESCRIPTION SUBCATEGORY - 112 EX.-85-105-002 CO 112 HBN 11 Y ll Y SR ENGINEERS TELL THE FITTERS TO ROUTE EVALUATION PROCESS:

T50201

!!P 710 REPORT A LINE IN' AND THEY HILL DO THE ilECES SECTION: 3.2.2 SARY PAPERHORK LATER.

(SITE HIDE) C FINDINGS:

ONSTRUCTION DEPT. CONCERil.

CI HAS N O NAMES OR ADDITIONAL INFORMATION, SECTION: 4.2 EX 121-002 CO 112 HBN N Y ll Y SR DRAHINGS ARE NOT HALKED DOHN BEFORE EVALUATION PROCESS:

T50203 HP 710 REPORT HORK PACKAGES ARE PUT TOGETHER BY Ell GINEERS, ON SITE. CONSTRUCTION DEPT SECTION:-3.2.5

. CONCERN. CI IIAS No ADDITIONAL IllF FINDINGS:

ORMATION. -GENERIC CONCERN-SECTION: 4.5 EX 121-004 CO 112 HBN NYNy SR SEVERAL ENGINEERS (DISCIPINE KNOHN)-

EVALUATION. PROCESS:

T50203 HP 710 REPORT

-TELL CRAFT To "FIX IT" AS I HANT IT, THEN I'LL COME BACK AND DO THE PAPE SECTION: 3.2.2 R HORK LATER. CONSTRUCTION DEPT. CD FINDINGS:-

NCERN. CI HAS.H0 NAMES OR ADDITIONA SECTION: 4.2 L INFORMATION.

-GENERIC CONCERN-HI 093-001 CO 112 HBil NNNY NO PEP.SONNEL (NAMES KH0Hil) HAVE BEEN TH EVALUATION PROCESS:

T50143 IH 000 REPORT REATENED WITH FIRING BY CRAFT SUPERV SECTION: 3.2.5 ISOR (NAME Kil0HN) IF HORK IS NOT PER FORMED EVEN THOUGH THE HORK PLAN IS FINDINGS:

KNOHN TO BE HRONG UR THE APPROVED PA SECTION: 4.5 PERHORK FOR THE JOB IS NOT AVAILABLE CONSTRUCTION DEPT. CONCERN. CI H AS No FURTHER. IllFORMATI0tl.

I4 019-001 CO 112 HBN N Y ll Y SR OTHER UNITS (DEPTS) llAVE ATTACHED OR EVALUATION PROCESS:

T50170 REPORT CUT-00T MEMBERS OF OUR FEATURES HNI CH RESULTED IN NCR'S.

ALL AFFECTED SECTION: 3.2.1 FEATURES HERE NOT IDENTIFED,.RESULTI FINDINGS:

NG IN OVERLOADED STRUCTURES.

ERT AT SECTION: 4,1 TEMPTED TO CONTACT CI.

CI HOULD fl0T RESPOND / PROVIDE ANY ADDITIONAL INFO RHATION. CONSTRUCTION DEPT CollCERN.

CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY HUMBER.

sATTACllHENT At REFEREllCE

- ECPS131J-ECPS131C

. TENNESSEE VALLEY AUTH2RITYJ PA!E 4-FREQUEllCY

- REQUEST OFFICE OF NUCLEAR PDHER RUN TIME - 12:51:14 UllP - ISSS '- RitM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DATE -112/02/86' LIST OF EMPLOYEE C0llCERN INFORMATION

'ATEGORY: CO C0llSTRUCTI oll-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GENERIC APPL

'QTC/NSRS P

' REFERENCE SECTION 8 CATEGORY'- C0 CollCERil SUB PLT BBSH INVESTIGATION S'

CDNCERN SUBCATEGORY - 112-flV!1BER CAT CAT LOC F L Q B' REPORT R

DESCRIPTION Ill -8 5-046-002 CO 112 HBil il Y N Y

'IN-85-046-002 NO DURING FEERUARY 1985,.GEllERAL;FOREMA EVALUATION PROCESS:

T50064 REPORT H (NAME KN0Hil). DIRECTED ELECTRICI Alls SECTION: 3*2.1 c

TO INSTALL 3" CollDUIT HITHOUT AUTH0 RIZATION OR HORK ORDER PACKAGE. f1HI FINDINGS:

S OCCURRED IN UNIT 2, EL EV. 7 57 ', C0 SECTION: 4.1 LUMN 13 BETHEEN R & S LINE.

IT 100K 1 HEEK TO INSTALL THIS CollDUIT HHIC H HAS SUBSEQUENTLY REMOVED 2 HEEKS L ATER. C/I DOES NOT RECALL CollDUIT H UMBER OR ANY ADDITIONAL INFORMATION.

NO FOLLOH-UP REQUIRED.

Ill -8 5-046-008 CO 112 11L11 11 Y !! Y SR HHILE FORTHCOMING IllSTALLATI0ll DESIO EVALUATION PROCE3S:

T50221 RSPORT NS ARE STILL ON THE "DRAHING BOARD",

SECTION: 3*2*1 SPECIFIC SUPERVISORS (KHollli) HILL "

BOOTLEG" INFORMATION AND INSTRUCT CR FINDINGS:

EHS TO COMMENCE UNAUTHORIZED ll0RK. Ill SECTION: 4.1 AN EFFORT TO CONVIllCE HAllAGEMEllT TH EY CAN COMPLETE THE JOB Ill LESS TIME THAN ESTIMATED lillEN ACTUALLY TAKING MORE TIME IN SOME CASES. TilESE UNA UTHORIZED INSTALLATI0llS FREQUEllTLY R EQUIRE REMOVAL AS THE "B00TLEGOED" I NFORMATION HAS 110T THE SAllE AS Tile F INAL DESIGN. THIS REMOVAL IS-D0llE H -

ITHOUT AUTHORIZATI0ll DR EVEN TO

$fikEbR$TYISbEGRADbBYREHORKEVEtl.EVALUATIONPROCESS:

Ill 057-003 CD 112 HBil 11 Y N Y SR T50170 REPORT HITH QUALITY, CONTROL IllSPECTORS.

E. SECTION: 3.2.3 CI HOUL RT ATTEMPTED TO CollTACT CI.

D NOT RESP 0llD/ PROVIDE ANY ADDITIDilAL FINDINGS:

INFORMATION. CONSTRUCTI0ll DEPT CUlj SECTION: 4.3 CERN.

CollCERilS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

" 4D 9

i---

ATTACHMENT A REFEREllCE

- ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY PAOC 5'

FREQUEllCY

- REQUEST DFFICE OF NUCLEAR P0HER RUll TIME - 12:51:16

' OllP - ISSS - P;1H EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS3 RUll 04TE

.12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION

'TEGORY: CO CONSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GEllERIC APPL QTC/NSRS P

REFEREllCE SECT 1014 5:

, CollCERil SUB PLT BBSH IllVESTIGATION S

CONCERN CATEGORY - CD llul1BER CAT CAT LOC FLQB REPORT R

DESCRIPTION SUBCATEGORY - 112

, Ill 093-001 CD 112 HBil N Y ll Y IN-85-093-001 NO GENERAL FOREMAN (NAME GIVEN) DIRECTE EVALUATION PROCESS:

)

T50019 REPORT D C/I TO RE-INSTALL A SECTION OF CAB SECTION: 3.2.1 l

LE TRAY HHICH HAS REMOVED TO ALLOH I 1

NSULATORS TO HORK. GENERAL FOREMAN FINDINGS:

HANTED C/I TO Do THE HORK llITHOUT AN SECTION: 4.1 Y PAPERl10RK (HORK AUT110RIZATION). C

/I REFUSED TO PERFORM HORK HITHOUT ll ECESSARY PAPERHORK. CABLE TRAY SECT ION IS LOCATED IN UllIT 51, ELEV. 757

', NORTH END OF AUX CollTROL ROOM.

INCIDENT OCCURRED BETHEEN MAY -- JUllE 1982.

C/I DOES NOT REMEMBER CADLE 4

l TRAY NUMBER, QA LEVEL DR ANY OTHER D 4

ETAILS.

I Ill -8 5-111-001 CO 112 HBN 11 Y ll Y IN-85-lll-001 HD HORK PERFORMED BY FIELD HORK FORCE, EVALUATION PROCESS:

l T50004 REPORT HHICH IS NOT COVERED BY DESIGN DRAHI SECTION: 3.2.2 NGS, - ARE Il0T - REFLECTED Dil AS-BUILTS.

REFERENCE SAMPLE AND FIELD RUll LIN FINDINGS 4

ES (N0ll-SAFETY RELATED). NO ADDITIO SECTION: 4.2 NAL CONTACT REQUIRED Ill 215-001 CD 112 HBN 11 Y ll Y SR OUTSTANDING WORK ITEMS LIST (OHIL) N EVALUATION PROCESS:

T50089 REPORT OT COMPLETE / ACCURATE FOR UllIT 1; ITE SECTION: 3*2*4 t

MS ARE ARBITRARILY DELETED OR NOT AD DED BY SUPERIllTENDEllT -(NAllE KNOIIN).

FINDINGS:

SECTION: 4.4 i Ill 26 3-001 CD 112 HBil ll Y ll Y SR CI STATED THAT THE STEEL FAB SHOP IS 150057 REPORT NOT GETTING FCRS 011 HORK PACKAGES T 0 FABRICATE THE MATERIAL BY.

AREA EVALUATION PROCESS:

FOREMEN CALL AND GIVE A NUMBER AND S SECTION: 3.2.5 TATE HHAT THEY llEED. HORK PACKAGES FINDINGS:

i ARE SENT TO Tile FIELD. FAB.Sil0F CAN NOT VERIFY CORRECT MATERIAL IS BElllG SECTION: 4.5 SUPPLIED IF AN "FCR" IS Ill EFFECT C i

i HANGING MATERIAL.DESIGilATI0ll.

C011CERilS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUH8ER.

q 4

• en L

d

ATTACHNENT A -

REFEREllCE

- ECPS151J-ECPS151C TENNESSEE VALLEY AUTHORITY PAGE.

6-i FREQUEllCY

- REDUEST OFFICE OF NUCLEAR P0HER RUll TIME ?.12:51:1 DNP - ISSL - Rllii EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DAl E -- 12/02/8" LIST OF EMPLOYEE CONCERN INFORMATI0ll CATEGORY: CD CONSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GENERIC

~

APPL QTC/NSRS P.

REFERENCE SECTION s-C0!!CERN SUB PLT BBSH INVESTIGATION S

CONCERN CATEGORY - CD tlUMBER CAT CAT LOC FLQB REPORT

.R-DESCRIPTION SUBCATEGORY - 112

?

IN 277-001 CO 112 llBN 11 Y N Y I-85-674-HBN SR CRAFT-(KN0HN) HAS INSTRUCTED BY FORE EVALUATION PROCESS:

T50166 REPORT MAN (NAME KN0Hil) TO INSTALL 3" PIPE

.i RUN IN TURBINE BUILDING HITHOUT ANY SECTION: 3.2.1 DESIGN DRAHINGS FROM ENGINEERIllG IN FINDillCS '

THE HORK PACKAGE.

THIS OCCURRED BET SECTION: 4.1 HEEN SEPT. 1983 TO SEPT. 1984. Colls TRUCTION DEPARTMENT CONCERN. C/I CO 4

ULD NOT PROVIDE ANY ADDITIONAL DETAI LS/ SPECIFICS. No FOLLDH-UP REQUIRED IN 281-002 CO 112 HBN NNNY SR HORK PLANS ARE GENERATED TO PERFORM-EVALUATION-PROCESS:

T50199 HP 710 K-FORM A JOB, H0HEVER, SUPERVISION /MANAGEME SECTION: 3.2.5 NT INSTRUCTS PERSONNEL NOT TO FOLLOH. FINDINGS:

JUST GET JOB DONE. CI HOULD NOT PR OVIDE ANY ADDITIONAL INFORMATI0ll.

C-SECTION: 4.S ONSTRUCTION DEPT. CONCERil. UNIT 1 8' 2.

IN -G5-286-001 CD 112 HBli

!! Y N Y IN-85-286-001 NO ELECTRICAL ENGINEERING MUST RELY ON EVALUATION PROCESS:

T50160 REPORT THE CRAFT To " FIELD RUN" CollDUIT BEC SECTION: 3. 2. 6 '

AUSE ENGINEERIllG DOES NOT TH0HN HHER E EQUIPMENT AND PENETRATIONS ARE ALR FINDINGS:

EADY INSTALLED:

EG., DURIllG SUf1HER SECTION: 4.6 r

OF 1984, ELECTRICIANS HERE GIVEN DRA 4

HING THAT SH0HED LOCATION OF LARGE (

2-STORY) VESSEL Ill llATER TREAlllEllT P LANT, BUT SH0HED LIGHTING CIRCUIT CO NDUT TO BE RUN THROUGH IT'S CEllTER A BOUT, HALFHAY UP VESSEL'S TOTAL llEIGil

}

T (IE. HEAR CIRLING OF LOHER LEVEL 0 F H.T. BUILDING) CONDUIT NAD TO BE F

)

IELD RUN.

(CONSTRUCTI0ll DEPT CD-CONCERilS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

N 1

1 9

m

ATTACilHENT A REFEREllCE

- ECPS131J-ECPS131C TEllHESSEE VALLEY AUTil0RITY PAGE

.7 FREQUENCY

- REQUEST OFFICE 0! NUCLEAR P0HER RUll TIttE - 12:51: 1 UllP - ISSS - Rilti EMPLOYEE C0!ICERN PROGRAM SYSTEM (ECPS)

RUll DA1E - 12/02M LIST OF EMPLOYEE CollCERil IllFORI1ATI0tl CATEGORY: CO CollSTRUCTIO!!-PROCESS SUBCATEGORY: 112 HORK PLAT 1/HORK C0!ITROL GEllERIC APPL QTC/flSRS P

REFEREllCE SEC1Iull I CollCERf1 SUB PLT BBSH IllVESTIGATIDH S

CollCERil CATEGORY - CU liUt1 DER CAT CAT LOC FLQB REPORT R

DESCRIPTI0fl SUBCATEGORY - 112 Ill -8 5-286-0 07 CD 112 HBil il Y ll y SR APPROXIMATELY DECEl1BER, 1984 SUPPORT EVALUATION PROCESS:

T50160 REPORT S HERE RELEASED FROH CollDUIT, HilICil SECTION: 3.2.1 HAS TilEli BEllT -I/2" D0liff, BELIEVED T 0 HAVE BEEN DollE IIITil 110 IIORK RELEAS FillDINCS :

E AUil10RIZATI0ll. CI IIAllTS TO KH0li I SECTION: 4.1 F THERE HAS A HORK RELEASE. LOCATIO ll s REACTOR BUILDIllG 82 713' ELEVATI 0 11. GO THROUGil DOUBLE DOORS FROM AU X 82, GO RIGilT, LOOK BACK To llEST.

CollDUIT IS 10' FRott FLOOR Oli ilALL B ETHEEll DOORS AN " CAGE" 0F LOIl CABLE TRAYS (YOU tlABE TO DUCK TO GET UllDER TliEH - 5' ilIGH). C0tlSTRUCTION DEPT CutlCERil. CI ilAS 110 HORE IllFORM Ill 293-005 CO 112 HBil if Y N Y SR Tile VAULT AllD RENS Sil0llED A SPECIFIC EVALUATION PROCESS:

T50266 REPORT HORK RELEASE (I Kil0HN) TO BE CLOSED SECTION: 3.2.1 (SIGilED OFF) YET IIORK HAS BEIllG Dull FINDINGS:

E OH IT Ill Tile FIELD. CollSTRUCTI0ll DEPARTHEllT C0tlCERH. CI ilAS 110 FURTil SECTION: 4.1 ER IllFORl1ATIOil.

Ill -8 5-29 3-014 CD 112 HBH N Y ll Y SR SPECIFIC PERS0llHEL (llAHES Kilallti) HR0 EVALUATIOff PROCESS:

T50266 IH 000 REPORT llGLY CHANGED Tile Ilut1BERS 011 SOME ilAR SECTION: 3*2*1 DilARE (KHoll!!) AND H0H IT IS UllKil0Hil HilAT DOCUMENTATI0ll GUES To lillAT llARD FINDINGS:

llARE. CONSTRUCTI0tl DEPARTHEllT CollCER SECTION: 4.1 II. CI llAS 110 FURTilER lilFORMATI0ll.

IN 293-026 CO 112 HBH 11 Y N Y I-86-107-HBH SR A GROUP OF CRAFT ARE DOIHG EllGIllEERI EVALUATION PROCESS:

T50267 HP 716 REPORT llG HORK, E.G.,

DRAHIll0 LOGIC.

DETAI LS Kil0Hil TO QTC, HITilllELD DUE TO C0ll SECTION: 3.2.2 FI DEllTI AL ITY.

110 FURTilER IllFORilATIO FINDINGS:

la MAY BE RELEASED. CONSTRUCTIUll DEP SECTION: 4*2 ARTi1EllT CollCERN. CI IIAS 110 FURTilER IllFORMATI0ll.

C0tlCERilS ARE GROUPED BY FIRST 3 DIGITS OF SilBCATEGORY NUHDER.

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REFERENCE

- ECPS131J-ECPS131C FREQUEllCY

- REQUEST TENNESSEE VALLEY AUTHORITY

. ATTACHMENT A' O'fP - 1555 - Ri!H OFFICE OF NUCLEAR P0HER PAGE' 8

EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN TIME

.12:51:

LIST OF EMPLOYEE CONCERN INFORMATION RUN DATE - 12/02/J IATEGORY: CD CONSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GENERIC APPL QTC/NSRS P

CONCERif SUB PLT BB5H INVESTIGATION S

CONCERN.

REFEREllCE SECTION NUMBER CAT CAT LOC FLQB REPORT R_

DESCRIPTION CAIEGORY - CD -

SUBCATEGo? V 1f2 IN 297-001 CD 112 HBH NYNY NO T50022 MP 710 REPORT CRAFTS (IRON HORKERS) MODIFYIN0/ INST ALLING DECK PLATE TO PUMP PLALECTM1,EW.tGkfION PROCE SECTION: 3.2.1 2, LOOP 83, UNIT 2 HITILO'M-tkAHINGS AND/OR FCR'S IN TJfC-WoNK PACKAGE. A FINDINGS-*

PPROX 1 HEEK PkEVIOUS To Tite EVENT, SECTION: 4.1 FEB./ MARCH 1985 CRAFTS HERE TOLD IN HEEKLY SAFETY MEETING THAT THEY HERE NOT TO PERFORM ANY HORK llIT1100T Tile PROPER DOCUMENTATION. HitEN THE CRA FTS QUESTIONED Tite CONIRADICTION AND ATTEMPTED TO LOCATE THE PROPER DOCU MENIATION, TilEY HERE TOLD (NAME KN0H N) TO COMPLETE Tile JOB OR 1.

RECEIV E AND ORAL HARNING 2 RECEIVE A IN 348-004 CO 112 HBN NYNY SR HORK PACKAGES ARE ISSUED SINGULARLY LETTER OR

3. IIIT Tile CATE.

T50023 REPORT EVALUATION PROCESS:

FOR A SPECIFIC HORK ACTIVITY.

(t0llEV ER, DUE TO THE HUMDERS OF CREH/SitIFT SECTION: 3*2*5 S HHICH MAY HORK DH A PACKAGE, SONE FINDINCS:

HORK HAS BEEN DONE TO A COPY (UNCONT SECTION: 4.5 ROLLED) 0F A DRAHING AS Tile ONLY REF ERENCE.

BEING UNCONTROLLED, THE DRA HING COPY MAY NOT REFLECT ALL FIELD CHANGE REQUEST NUMBERS APPLICABLE TO THE CONSTRUCTION ACTIVITY IN 349-003 CO 112 HBN ll Y ll Y SR HHEN INFORMED THAT A HANGER CANNOT B EVALUATION P T50209 MP 710 K-FORM E INSTALLED AS PER DRAllING, ENGINEER ING (SPECIFIC INDIVIDUAL UNKNDHN) HI.SECTION: 3.2.2 LL TELL CRAFTS (KNOHN) TO INSTALL HA FINDINGS:

NGER AS BEST THEY CAN AND THAT ENGIN SECTION: 4.2 EERING HILL "AS-BUILD" LATER.

UNIT 1 & 2.

CONSTRUCTION DEPT. CONCERN.

CI COULD NOT PROVIDE ANY ADDITIONAL INFORMATION.

IN 362-002 CD 112 HBN NYN7 IN-85-362-002 NO HELDS ARE OFTEN INSPECTED AFTER IllSU T50023 REPORT LATION HAS BEEN APPLIED HHICHIS COST EVALUATION PROCESS:

LY AS INSULATION MUST BE REMOVED AND SECTION: 3.2.3 RE-APPLIED AFTER INSPECTION. UNIT FINDINGS:

il CONTROL ROOM 1984 SECTION: 4.3 CONCERNS ARE GROUPED BY FIR 3T 3 DIGITS OF SUBCATEGORY NUMBER.

_ _ - _ _ _. - _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ ~

ATTACHMENT A

'REFEREllCE

- ErtS131.1-ECPS151C TENNESSEE VALLEY AUTHORITY PAGE' 9-FREQUENCY' - F.EQUEST OFFICE OF HUCLEAR PDHER-Ruti TIME - 12:51 )'

011P - ISSS - RllM EMPLOYEE CONCERN-PROGRAM SYSTEM (ECPS)

RUN DATE - 12/02/1-LIST OF EMPLOYEE CONCERN INFORMATION ATEGORY: CO. CONSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CollTROL GEllERIC

~

APPL QTC/NSRS P

REFERENCE SECTION 8 CONCERN SUB PLT BBSH INVESTIGATION-S CONCERN

. SUBCATEGORY - 112 :

CAIEGORY - CD flUMBER CAT CAT LOC F L'Q B REPORT R

DESCRIPTION Ill 377-001 CD 112 HBil

1. 1 Y N Y IN-85-377-001 NO THE COST OF PREPPING HELDS FOR'ISI N EVALUATION PROCESS:

T50019 REPORT OH COULD HAVE BEEN PREVENTED, IF Tile

. PREPS HAD BEEN DONE HilERE THE PIPE SECTION: 3.2.3 HAS BEING FABRICATED. HAITING UNTIL FINDINGS:

NDH CAUSES HANGERS TO BE REH0VED/IN SECTION: 4*3 STALLED.TO PERFORM THE HELD PREPS.

Ill 388-007 CD 112 HBil 13 Y ll Y SR CIVIL ENGINEERIllG RESPONSIBLE FOR "P EVALUATION PROCESS:

T50015 HP 717 REPORT IPE LABELING" DUE To NOTE ON ARCHITE SECTION: 3*2*6 i

CTURAL DHG.

46H HHICH IllCLUDES ASCE RTAINING HHICH MECHANICAL DHG. IS AP FINDINGS:

PLICABLE TO EACH HORK PACKA0E. CIVI SECTION: 4.6 L ENGINEERIllG IS NOT KNDHLEDGEABLE E NOUGH To COMPETENTLY PERFORM THIS AS SIGNMENT AND RELIES 011 CRAFT TO ADVI SE THEM OF THE FUNCTInil OF EACH PIPE THE PIPES COULD VERY POSSIBLY BE MIS-LABELED HHICH COULD BE A SERIOUS PROBLEM IF A LINE NEEDED TO BE SHUT DOHN QUICKLY.DURING AN OPERATIONAL EMERGENCY.

Ill 388-009 CO 112 HBN tl 11 il Y NO CIVIL ENGINEERING DOES NOT HAVE A SE EVAI*UATION PROCESS:

T50015 REPORT CURITY CLEARANCE FOR UNIT B 1 AND TH EREFORE CAN NOT DO OR OVERSEE ANY PI SECTION: 3.2.6 PE LABELING HHICH IS THEIR RESPONSIB FINDINGS:

ILITY.

SECTION: 4.6' IN 397-001 CO 112 HBil il il N Y NO UNIT 1 PRINTS ARE BEING USED FOR UNI T50017 EN 204 REPORT T 2 AllD ARE MARKED OPPOSITE HAND HHI EVALUATION PROCESS:

CH MAKES HORK 110RE C3NFUSING FOR HUR SECTION: 326 KERS AND ENGINEERS, FINDINGS:

Ill -8 5-4C9-002 CD 112 HBil il Y H Y IN-85-409-002 NO THE SAME MISTAKES MADE IN UNIT 1 HER SECTION: 4.6 T501/5 REPORT E DUPLICATED IN UNIT-2 CONCERilING FI ELD ROUTED CONDUIT. THIS CAUSED CON DUIT TO BE REROUTED AN EXCESSIVE NUH ' EVALUATION PROCESS:

BER OF TIMES. C/I DECLINED To PROVI SECTION: 3.2.3 DE FURTHER DETAILS. CollSTRUCTION DE FINDINGS:

SECTIONS.4.3 CONCERilS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY HUMBER.

~

~

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ATTACNMENT'AL i' REFERENCE

- ECPS131J-ECPS131C

' TENNESSEE VALLEY AUTNORITY FREQUENCY

- REQUEST

~

PAGE

' -1

. - 10 :

'ONP - ISSS - RHH OFFICE OF HUCLEAR POWER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN TIME - 12:51r' LIST OF EMPLOYEE CONCERN INFORMATION-RUN DATE - 12/02/.

2ATEGORY

CO CONSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL

{+

I GEllERIC APPL QTC/HSRS P

REFERENCE SECTION Rf CONCERN SUB.

PLT BBSH

. INVESTIGATION-S CONCERN NUMBER CAT CAT LOC FLQB REPORT R

DESCRIPTION CATEGORY - CO SUBCATEGORY - 112 IN 410-011 CD 112 HBit it Y ll Y SR CRAFT-(KNOHN) IN DEPARTMENTS (KH0HN) EVALUATION PROCESS:

T50258 REPORT DO PATCHING AND CHIPPING OF CONCRET SECTION:

3.2.1 E HITHOUr-INSPECTION. AND DRILL HOL ES IN THE FLOOR HITHOUT PROPER PAPER FINDINCS:

HORK.

CONSTRUCTION DEPARTHENT CONCE SECTION: 4.1 RN.

CI HAS NO FURTHER INFORMATION.

IN 418-001 CO 112 HBil NYHY IN-85-418-001.

NO IMPROPER CONTROL OF INSTRUMENTATION EVALUATION PROCESS -

T50012 REPORT HORK PACKAGE DOCUMENTS HHICH ARE BEI SECTION: 3.2.5 HG SPLIT UP AMONG SEVERAL FOREMEN FINDINGS:

SECTION: 4.5 114 423-001 CO 112 llBil 11 Y 11 Y IN-85-423-001 NO HORK PACKAGES ARE SENT TO-THE CRAFT l

T50018 REPORT S INCOMPLETE FCRS-ECilS ARE MISSING F EVALUATION PROCESS:

ROM THE PACKAGES. THIS CONCERN OCCU 1

RS AT UNIT 2.

UPPER LEVEL HANAGEMEN SECTION:~3*2*5 r

]

T IS ANARE OF THE=PROBLEH, DUT IT PR FINDINCS:

)

OLONGS THE JOB, SO NOTHING IS DONE.

SECTION: 4.5 l Ill 437-002 CO 112 HBil il V tl Y SR HGRS (REACTOR BLDG., UNIT 1) INTENTI T50027 K-FORM OHALLY INSTALLED TO HRONG REV0F DHO EVALUATION PROCESS:

JUST TO KEEP HGR. COUNT UP.. HGRS ARE. SECTION: 3.2.3 SUBSEQUENTLY CUT 00T AND INSTALLED i

TO CORRECT REV.

H0HEVER,~ INDIVIDUAL FINDINGS' i

STATED HE IS CONVINCED THAT-THERE S SECTION: 4,3 i

TILL EXISTS HGRS INSTALLED To THE HR DNG REV 0F THE ASSOCIATED DHG.

IN 442-009 CO 112 HBN NYNY IN-85-442-009 HO ON UNIT 91 SYSTEM TURNOVER HALKD0HNS T50043 REPORT

, THE COGNIZANT DISCIPLINE SYSTEM EN EVALUATION PROCESS:

GINEER HAS NOT INVOLVED IN THE HALKK SECTION: 3.2,4 i

i DOHN PROCESS TO VERIFY INC0HPLETE IT; FINDINGS' i

Ells PRIOR TO SYSTEM HALKD0HilS; HERE ~

EXPRESSED AS HAVING CONSISTED OF A C SECTION, 4.4 ASUAL HALKDOHN FOR OBVIOUS SYSTEM DA i

MAGE ONLY.

(EXAMPLE: CRANE 8 CAVITY 4

1 AREA, 702-757' SLAB, BOTT0H OF STEA-M GENERATOR) 1 III 442-014 CD 112 HBil il Y N Y SR THE UNIT 1 SYSTEM TURNOVER HALKDOHN l

T50086 REPORT ARE NOT ADEQUATE BECAUSE DRAHINGS US EVALUATION PROCESS:

ED HERE NOT CORRECTED AND THERE -IS N SECTION: 3.2.4 j

'O HALKDOHN GROUP (QCP 2.04 ATTACH J) FINDINGS:

SECTION: 4.4 CONCERilS ARE GROUPED Bv '.IRST 3 DIGITS OF SUBCATEGORY HUMBER.

I

~-

t i

I

ATTACllMENT A-REFFR8 !!CE

- ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY PAGE 11 FREQUE!!CY

- REQUEST OFFICE OF NUCLEAR P0HER RUN TIME - 12:513)'

OllP - ISSS - RilM EMPLOYEE C0!1CERil PR00 RAM SYSTEM (ECPS)

RU!I DATE - 12/02/1 LIST OF EMPLOYEE CONCERN INFORMATION

.ATEGORY: CO CollSTRUCTI0ll-PROCESS SUBCATEGORY: 112 HORK PLAll/HORK CONTROL GENERIC APPL QTC/HSRS P

REFERENCE SECTION 3 CONCERN SUB PLT BBSH IllVESTIGATION S

C0tlCERN CATEGORY - C0 flUT1BER CAT CAT LOC FLQB REPOR1 R

DESCRIPTION SUBCATEGORY - 112 Ill 447-003 CD 112 HDil NYNY SR THE INSTRUMEllTATION IS AS-BUILT IN T EVALUATION PROCESS:

T50034 REPORT HE FIELD THEN A SKETCil IS IIADE SH0HI SECTION: 3.2.2 f4G THE AS-BUILT C0tlSTRUCTI0tl.

FINDINGS:

SECTION: 4.2 Ill 48 0-0 06 CO 112 HBil il Y ll Y NO HORK PACKAGES RECEIVED BY Tile CRAFT EVALUATION PROCESS:

T50137 REPORT ARE IHCOMPLETE AND INACCURATE. THE SECTION: 3*2*5 CRAFT ARE REQUIRED 10 PERFORil All EllG IllEERIllG REVIEH OF lilE IIORK PACKAGE FINDINGS:

FOR ERRORS AND ARE GIVEN DISCIPLINAR SECTION: 4.5 Y ACITON IF TilEY D0 fl0T IDEllTIFY TiiE ERRORS BEFORE IllSTALLATION BEGINS.

(DETAILS TO THE SPECIFIC CASE ARE K N0 Hit TO QTC AND HIlllHELD TO IMIllTAIN CollFIDEN TI AL I TY). C0llSTRUCTI0tl DEP T. CONCERN. 110 FOLL0ll-UP REQUIRED.

Ill 480-007 CD 112 HBil il Y N Y 11 0 UPON RECEIPT OF A Il0RK PACKAGE THE C EVALUATION PROCESS:

T50137 REPORT RAFT MUST REVIEH Tile CODE HELDING SH SECTION: 3.2.5 EET FOR ERRORS.

IF THE CRAFT FAILS TO IDEllTIFY THE ERROR PRIOR TO FIT-U, FINDINGS:

P THEY HILL RECEIVE TIME OFF llITHOUT SECTION: 4.5 PAY.

(DETAILS TO THE SPECIFIC CASE ARE KN0Hil TO QTC AND HITilllELD TO HA IllTAIll CONFIDEllTIALITY). CollSTRUCTI ON DEPT. CONCERil. CI IIAS 110 HORE IN FORMATION. NO FOLLOH-UP REQUIRED.

Ill 514-005 CO 112 HBil il Y ll Y Ill-8 5-514-003 11 0 TVA HASTING TIME & MATERIAL HilEN INS EVALUATION I,ROCESS:

T50043 REPORT TALLING TEMPORARY HANGERS. HilEN EllG IllEERING HAS ASKED HilY PERMANEllT Hall SECTION: 3.2.3 GERS COULD fl0T BE IllSTALLED, INDIVID FINDINGS:

UAL HAS TOLD THAT EllGINEERING llAS HA SECTION: 4*3 ITING FOR THER!1AL HOVEMENT DATA.

CollCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

_ _ - - _ _ ~ _ _ _ _ _ _.. _ _..

a ATTACHMENT A' REFERENCE

- ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY FREQUENCY

- REQUEST OFFICE OF NUCLEAR P0HER PAGE "12-RUN TIME - 12:5139 OllP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM-(ECPS)

RUti DATE

+12/02/.'

LIST OF EMPLOYEE CONCERN INFORMATION ATEGORY: CD -CONSTRUCTION-PROCESS SUBCA1EGORY: 112 HORK PLAN /HORK CONTROL GENERIC APPL.. QTC/NSRS P

REFEREHCE SECTION t CONCERif SUB PLT-BBSH INVESTIGATION S

CONCERN CATEGORY - CD

-NUMBER CAT CAT LOC FLQB REPORT R'

DESCRIPTION SUBCATEGORY - 112 IN 514-007 CO 112 HBil NYNY< I!1-85-514-007 NO PROCESS PIPING (SYS UNKNOHN) HAS CON EVALUATION PROCESS:

T50053 REPORT NECTED TO LOCAL PANELS SYSTEM 276 BE SECTION: 3.2.3 o

FORE PANELS ARE ACCEPTED BY QC TENSI FINDINCS:

ON TESTS OF PANEL'S BASE BULT.

IT I S IMPOSSIBLE TO PERFORM PULL TESTS A SECTION: 4.3 FTER PIPING IS CONNECTED TO PANELS.

HORK RELEASES HAD TO BE HRITTEN TO REMOVE PIPE TO HANGER ATTACHHEllTS TO ALLOH LIFTING PANEL AND PERFORNING TENSION TEST OF PANEL'S BASE ANCHOR BOLTS, THIS DCCURRED DURING DECEMBER 1984 TO JANUARY 1985. CI CITES THI S AS AN EXAMPLE OF POOR PLANNIllG BY INSTRUMENTATION ENGINEERING A&B GROUPS RESULTING IN EXCESSIVE COST AND WASTE AT WBN UNITS 1 & 2.

IN 520-003 CO 112 HBil NYNY SR 1983-1984 AUX BLDO. SPRINKLER SYSTEM T50033 REPORT

, 785' ELEV.

(N0H UNDER SECURITY).

EVALUATION PROCESS:

ENGINEERING DIRECTIllG CRAFT TO FIND A HAY TO INSTALL 1HE HAtlGER AND AFT SECTION: 3*2.2 ER INSTALLATION, ENGIllEERING HOULD S FINDINGS:

KETCH THE "AS CONSTRUCTED" DHG. CRAF SECTION: 4.2 T HAS PUT IN THE POSITION OF DESIGNI NG RATHER THAN CONSTRUCTING.

Ill 579-002 CO 112 HBil il Y N Y NO: FOREHAN (KNOHN) AND GEllERAL FOREMAH EVALUATION PROCESS:

T50219 REPORT (KNOHN) HAD 2" DIAHETER CARBull STEEL PIPE BENDING PERFORHED HITHOUT AN A SECTION: 3.2.1 PPROVED PROCEDURE. ADDITIONAL EQUIP. FINDINGS:

HENT BUILDING, 748' ELEV., 1977 AND SECTION: 4.1 1978.

CI HAD No FURIHER INFORMATION CONSTRUCTION DEPARTHENT. CONCERN.

IN 595-003 CD 112 HBil NYNY SR CRAFT ARE EXPECTED'TO AND REQUESTED EVALUATION PROCESS:

T50056 REPORT To -FIND A HAY TO INSTALL HANGERS AllD THEN CALL ENGINEERING TO STETCH THE SECTION: 3.2.2 AS-CONSTRUCTED DRAHING. THIS IS AN FINDINGS:

ON-GOING PROCESS THAT HAS CONTINUED SECTION: 4.2' FOR YEARS.

C0llCERiiS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

"4D

ATTACllllENT A 13 REFERENCE

- ECPS131J-ECPS131C TEN!1ESSEE VALLEY AUTHORITY PAGE FREQUENCY

- REQUEST OFFICE OF HUCLEAR P0HER RUll TIME - 12:51:1 OrlP - ISSS - Rilft EMPLOYEE C0tlCERll PROGRAM SYSTEM (ECPS)

RUll DATE - 12/02/1 LIST OF EMPLOYEE C011CERil INFORMATI0tl ATEGORY: CO C0flSTRUCTI0ft-PROCESS SUBCATEGORY: 112 HORK PLAll/ll0RK CONTROL GEllERIC APPL QTC/flSRS P

REFERE!!CE SECTI0li a CONCERf1 SUB PLT BBSH IllVESTIGATION S

CollCERN CATEGORY - CD flUf1BER CAT CAT LOC FLQB REPORT R

DESCRIPTI0tl SUBCATEGORY - 112 Ill -8 5-618-0 02 CD 112 HBil N Y ll Y IN-85-618-002 fl0 HORK PACKAGES, HNERE 11ULTIPLE PACKAG EVALUATION PROCESS:

T50059 REPORT ES ARE REQUIRED TO CollPLETE A PARTIC SECTION: 3.2.5 ULAR IllSTALLATION, ARE NOT ISSUED fl0 FINDINGS 8 R AVAILABLE TO THE FOREHAll PERFORMIll G ONE OF THE PACKAGES. THIS IllPEDES SECTION: 4.5 EFFECTIVE UTILIZATI0li 0F AVAILABLE CRAFT PERS0tlHEL. 110 FURTilER SPECIFI CS AVAILABLE.

Ill 67 0-002 CO 112 HBil

!! Y N Y SR RECElli REVISION TO METil0D OF IllSTALL EVALUATION PROCESS:

T50079 t1P 710 REPORT IllG llAllGER PER DESIGil MAY COST PRODU SECTION: 3 2*6 CTION UP TO TilREE DAYS HAITIllG Dil Ell GIllEERING'S RESP 0tlSE.

EXAf1PL E: CRAF FINDINGS:

T ARE NDH REQUIRED 10 Il0TIFY FOREMEli SECTION: 4.6 tillEli CRAFT CAN'T MAKE All IllSTALL ATI Oil PER DRAllING.

Tile FOREMEll IllEll Ill FORMS EllGIllEERING AND EllGIllEERIllG GE HERATES A VARIAllCE OR FCR.

TilIS TAK g

ES SEVERAL DAYS.

BEFORE, CRAFT HOUL D FIND A HAY TO MAKE Tile IllSTALL ATIO fl, t1AKE IT, AND THEN INFORH EllGIllEER IllG HNO HOULD GEllERATE A VARI AllCE OF FCR.

IN 728-003 CO 112 HBil il il N Y 11 0 EllGIllEERIllG DOES NOT RESP 0tlD HITHIll EVALUATION PROCESS:

REPORT A REAS0tlABLE TIME HilEtt CRAFT REQUEST SECTION: 3.2.6 TilEtt TO LOOK AT N0LES DRILLED FOR R FINDINGS:

SECTION: 4.6 Ill 743-010 CD 112 HBil N Y ll Y SR DOCUMENTATI0ll PROVIDED TO CRAFT IS 0 T50076 REPORT FTEN LACKING SUFFICIENT IDENTIFICATI EVALUATION PROCESS 8 Off REL ATIVE TO LOCATION, ELEVATIDH, AZIl1UTil, DRAllIllG flUMBERS, ETC.

INIS SECTION: 3.2.5 NECESSITATES EXPEllDITURE OF flUMEROU FINDINGS:

S MAtHIOURS To RESEARCN REQUIRED IllFD SECTION: 4*5 RMATION, AllD MAY POTEt4TIALLY IHPACT QUALITY, IF All IllADVERIElli MISTAKE H AS MADE. 110 FURTHER DETAILS AVAILAB LE.

Ill 762-002 C0 112 HBil il il N Y SR DRAHINGS MARKED "SEQUOYAN-INTERIM" il EVALUATION PPOCESS' T50076 REPORT ERE USED IN TifE CONSTRUCTION OF llBilP (C/I DECLIllED TO PROVIDE SPECIFICS) SECTION: 3.2.5 FINDINGS:

SECTION: 4.5 CONCERilS ARE GR0bPED BY FIRST 3 DIGITS OF SUBCATEGORY HUMBER.

ATTACllHENT A REFEREllCE

- ECPS131J-ECPS131C TEllflESSEE VALLEY AUTif0RITY PAGE 14 FREQUEllCY

- REQUEST OFFICE OF fluCLEAR P0HER Ruti TIME - 12:51:

DNP - ISSS - Riitt EMPLOYEE CollCERN PROGRAM SYSTEM (ECPS)

RUll DATE - 12/02/.

LIST OF EMPLOYEE CollCERll IllFORMATIOli CATEGORY: CO C0!ISTRUCTI0ll-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CollTROL GEllERIC APPL QTC/flSRS P

REFEREllCE SECTIort a C0llCERil SUB PLT BBSH IllVESTIGATI0tl S

C0llCERil CATEGORY - C0 fluMBER CAT CAT LOC FLQB REPORT R

DESCRIPTIOil SUBCATEGORY - 112 Irl 787-001 CO 112 HDit

!! Y ll Y Ill-85-787-0 01 11 0 LACK OF COMilutlICATI0ll BETHEEll CRAFTS EVALUATION PROCESS:

T50081 REPORT AllD EllGIllEERIllG CAUSES LollG DEL AYS SECTION3.2.3 Ill COMPLETIllG ll0RK.

O!IE HELD HAD TO DE D0llE THREE TIllES.

TliE LAST TIllE FINDINGS:

TOOK 2 1/2 DAYS.

IIAMES AND LOCATIO SECTION: 4.3 115 ARE Ktt0HII. PIPE CllASE EI. 713' 1 1'E OF "U" LIllE UllDER GRATIllG. 110 F URTHER DETAILS AVAILABLE.

Ill 816-002 CO 112 HBN

!! Y !! Y Ill-85-816-002 11 0 EllDES SHOULD BE MORE EFFICIEllT HHEll EVALUATION PROCESS:

T50082 REPORT DEVELOPIt10 HORK PACKAGES.

THE SYSTE N SHOULD BE ilALKED Doliti PRIOR TO Fill SECTION:

3.2.3 AL DRAHING Ill ORDER 10 PREVEllT COSTL FINDIliCS :

Y REHORK. 110 FOLLOH-UP REQUIRED. Il SECTIoti 4.3 0 ADDITIONAL IllFORMATION AVAILABLE.

Ill -8 5-847-006 CO 112 llBil 11 Y ll V I-85-360-HBN SR STANDARD PRACTICE FOR CRAFT SUPERVIS EVALUATION PROCESS:

T50107 REPORT I0tl TO ALLOH 110RK TO BE PERFORt1ED Ill SECTION: 3.2.1 Tile FIELD USIllG UllAPPROVED " BOOTLEG

" COPIES OF HORK PLAllS. CI GAVE flui1 FINDINGS:

EROUS HORK PLAllflVHilERS TO ERT AS EX SECTION: 4.1 At!PLES OF HORK PERFORtlED Ill Tile FIEL D PRIOR EllGIllEERIllG APPROVAL. ADDITI ONAL DETAILS (llAtlES OF (,1(AFT SUPERVI SION AIID HORK PLAN flullBERS) Ill FILE.

110 FOLLOH UP REQUIRED.

IN 850-004 CO 112 HBil if Y ll Y I-8 5-353-IIBil SR TOP LEVEL MGMT (NAMES Kil0llff TO QTC) ' EVALUATION PROCESS:

T50085 MP 711 REPORT PROMOTES Tile PROCEDURE OF 110RKING FR SECTION:

3.2.1 Oil A " BOOTLEG" COPY OF THE HORK PACK AGE.

ENGIllEER (llAMES Kilullia To QTC)

FINDINGS:

GIVES All ADVAllCE COPY OF THE HORK PA SECTION:

4.1 CKAGE, il0RK BEGIllS IIITil00T OFFICIAL APPROVAL, APPROX. 2-3 llEEKS LATER PA CKAGE IS APPROVED (ALL Tile TIllE l!DRK IS GOING Oll) HORK IS CollPLETED AtlD REPORTED TilAT JOB HAS CollPLETED Ill 5 110RTER PERIOD OF TIl1E, GIVIll0 All ILL USTRATI0tl T!!AT N0!!EY/ Mall HOURS HAD B EEN SAVED FROM Tile ESTI!!ATES. THIS MAKES CERTAlti GMT LOOK LIKE EXTREMELY EFFICIENT MANAGERS CAUSING Ti!EM TO CONCERilS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

RECEIVE PROMOTIONS.

ATTAC11HENT A REFERENCE

- ECPS131J-ECPS131C TEllflESSEE VALLEY AUTHORITY PAGE 15 FREQUENCY

- REQUEST OFFICE OF fiUCLEAR P0HER Rut! TIME - 12:51 :

OllP - ISSS - RIH 1 EMPLOYEE CollCERil PROGRA!1 SYSTEM (ECPS)

RUti DATE - 12/02/.

LIST OF EMPLOYEE C0llCERN IllFORMATI0il ATEGORY:.CO C0tiSTRUCTI0ti-PROCESS SUBCATEGORY: 112 lt0RK PLAN /HORK CONTROL GEllERIC APPL QTC/NSRS P

REFERENCE SECTIO!! s CONCERil SUB PLT BBSH IllVESTIGATI0tl S

CONCERif CATEGORY - CD HUMBER CAT CAT LOC FLQB REPORT R

DESCRIPTIO!!

SUBCATEGORY - 112 IN 889-H09 CD 112 HBil 11 11 11 y SR NRC IDEllTIFIED THE FOLLOHIllG CONCERll EVALUATION PROCESS:

K-FORM FROH REVIEH OF QTC FILE.

"MAllAGENE SECTION:

IIT D0ft'T FOLLOH PROCEDURES Colli Altu1E 11T PRESSURE.n FINDINGS:

SECTION:

IN 898-002 CO 112 HBN 11 Y ll Y Ill-85-898-002 11 0 HORK PACKAGES SEllT TO THE FIELD ARE T50090 REPORT SOMETIHES IllC0t1PLETE OR HAVE THE IIRO EVALUATION PROCESS:-

IIG REVISI0tl 0F DRAHINGS.

Tile CRAFTS SECTION: 3.2.5 ARE ilELD RESPollSIBLE FOR TilESE PACK FINDINGS:

AGES AtlD CAtt BE PUNISHED FOR 810RKIllG TO A HRONG REVISlott OF A DRAlllllG.

SECTION: 4.5 HHY ISil'T Tile PUNISilHEllT AIHED llHERE IT BEL 0tlGS, HilICH IS THE PERS0ll Hilo ASSEHBLES Tl!E 110RK PACKAGET Ill 915-001 CO 112 HBil

!! Y N Y IN-85-915-001 SR HHY ARE CRAFTS ALLOHED TO HAVE "FOR EVALUATION PROCESS:

T50092 REPORT IllFORMATIOil DNLY" DRAHINGS llHEli TilEY SECTION: 3.2.1 llAVE 110 flEED FOR TilEHT C/I HAS 110 FURTilER INFORMATI0!I. 110 FOLL0ll UP R FINDINGS:

EQUIRED.

SECTION: 4.1 1:1 947-005 CO 112 ilBil il Y ll Y SR CI Kil0!!S OF A C0flSTRUCTI0ft PRACTICE T50169 REPORT TilAT REllDERED llARDHARE QUALITY QUEST EVALUATION PROCESS:

10tl ABL E.

DETAILS Kt10H!i TO QTC, HITH SECTION: 3.2.1 ELD TO HAINTAlti C0tlFIDENTIALITY. CD FINDINGS:

NSTRUCTI0li DEPT CONCERN. CI HAS 110 FURTilER IllFORMATI0ll.

SECTION: 4.1 IN 962-003 CD 112 HBil N Y N 'l SR INSTRUMENTS, AS llELL AS OTilER EQUIPM EVALUATION PROCESS:

T50245 REPORT EllT, ARE FREQUEllTLY CAtitlIBALIZED FOR UTilER SYSTEMS, UtIITS, OR EVEll flUCLE SECTION: 3.2.1 AR SITES.

IT IS UNKl10HH IF THE DRAll FINDINGS:

IllGS, HORK PACKAGES, ETC. IIAVE BEEN SECTION: 4.1 REVISED TO SHoll Tile REH0 VAL OF AN IT EH THAT HAS INSTALLED PER DRAHIllG, E TC. CI DECLIllED TO PROVIDE FURTHER I flFORf1ATI0ll. CollSTRUCTION DEPARTHENT C0tiCERN.

C0llCERilS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY llUMBER.

u

FREQUENCY

- REQUEST TENNESSEE VALLEY-AUTHORITY ATT!CHHENT A

~ REFEREt4CE

- ECPS131J-ECP3131C 4

PAGE Rd 16' ONP - ISSS - RHM OFFICE OF NUCLEAR PDHER s

i EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)-

RUN TIME - li,51:

LIST OF EMPLOYEE CONCERN INFORMATION RUN DATE - 12/d2/-

1. ATEGORY: CO CONSTRUCTION-PROCESS SUBCATEGORY: -112 HORK PLAN /HORK CONTROL GENERIC

.QTC/NSRS.

APPL P

~

C0flCERif SUB PLT BBSH

. INVESTIGATION S

CONCERN

.REFEREllCE SECTION B ilUMBER CAT CAT LOC FLQB REPORT-R DESCRIPTION CATEGORY - CD -

c' SUBCATE00RY - 112 IN 978-008 CO 112

' llBil il Y ll Y NO TVA POURED LARGE CONCRETE STRUCTURES T50208 REPORT EVALUATION PROCESS:

HEY HOULD BE UNACCEPTABLE.SUCH AS HALLS HHE I

I THEY HOU i

LD THEN RIP OUT THE HORK HITH HEAVY FINDINGS:

i MACHINERY AND MOVE IT TO HHERE IT SH SECTION: 4.3-OULD HAVE BEEN.

DNE HALL IN THE INT AKE PUMPIllG STATION HAS KNOHINGLY-PG URED AROUND THE HRONG SIZE OF PIPE, THEN HAS TORN OUT AtID RE-DONE HITH T i

HE CORRECT. SIZE PIPE.

1976. CI HAS 3

NO FURTHER INFORMATIO. CONSTRUCTION t

4 DEPT. ColiCERN.

} IN 978-009 CO 112 HBN 11 Y N Y NO TVA MADE A' PRACTICE OF INSTALLING EQ T50208 REPORT UIPMENT GUT OF SEQUENCE, AND AS A RE EVALUATION PROCESS' SULT, IT HAS DAMAGED AND REQUIRED NE SECTION: 3.2.3 EDLESS PEPAIRS DUE TO REMOVAL AND RE FINDINGS:

INSTALLATION. CI HAS NO SPECIFIC DR l

ADDITIONAL INFORMATI0fl. CollSTRUCTI SECTION: 4*3 ON DEPT. Cot 4CERN.

f' i IN 999-001 CO 112 HBN 11 Y H Y NO DEPARTMENT-(KNOHN) NEEDS MORE C00RDI T50099 i

REPORT HATION. ALMOST EVERY PLATFORM AND L EVALUATION PROCESS -

ADDER IN THE PLANT HAS BEEN fl0DIFIED SECTION: 3.2.3 i

/ REPLACED'DUE 10 LACK OF FORETHOUGHT FINDINGS:

IT IS DIFFICULT TO THINK OF "CRAF i

TSMANSHIP" HHEN REPLACING A LADDER F SECTION:

4.3 DR THE-THIRD TIME, CI HAS NO ADDITI-ONAL INFORMATION. No FOLLDH UP REQU IRED.

IN 019-006 CO 112 HBN NYNY SR TRANSFER DRAHINGS USED To SH0H SYSTE T50219 REPORT H STATUS (CONSTRUCTI0ti/0PERATIONS) C EVALUATION PROCESS:

DNFLICT HITH EACH OTHER.

ELECTRICAL SECTION: 3.2.4 i

SCHEMATICS SH0H THE SAHf CABL E ON D FINDINaN IFFERENT DRAHINGS UNDER THE Col 4 TROL-t

.l OF DIFFERENT ORGANIZATIONS. Tile INA SECTION: 4*4 CCURATE TRANSFER DRAHINGS COULD IMPA l

CT PRE-OP-TESTIllG. CI COULD NOT PRO VIDE ANY SPECIFIC DRAHING NUMBERS.

CONSTRUCTION DEPT. CONCERN. UllIT 1

+

AND 2.

CONCERNS ARE GROUPED.BY FIRST 3 DIGITS OF SUBCATEGORY HUMBER.

i

(

l i

r

ATTACllHENT A REFEREllCE

- ECPS131J-ECPS131C TEti!!ESSEE VALLEY AUTillRITY PAGE 17 FREQUEllCY

- REQUEST OFFICE OF flUCLEAR Poller Rut! TIME - 12:51: s OHP - ISSS - Ri!M EMPLOYEE CONCERil PROGRAM SYSTEM (ECPS)

RUll DATE - 12/02/3 LIST OF EMPLOYEE CONCERil IllFORMATI0li

ATEGORY: CO C0tlSTRUCTI0ti-PROCESS SUBCATEGORY: 112 HORK PL AN/HORK CollTROL GEllERIC APPL QTC/flSRS P

REFEREllCE SECTI0tl t CollCERil SUB PLT BBSU INVESTIGATIO!!

S C0llCERil CATEGORY - CD flUMBER CAT CAT LOC FLQB REPORT R

DESCRIPTI0tl SUBCATEGORY - 112 Ill 102-001 CD 112 HBil 11 Y N Y I-85-427-HBil SR THE REQUIREMEllT FOR CollDUIT IllSULATI EVALUATION PROCESS:

T50119 REPORT Dil DELETED AtlD IllSUL ATI0tl REMOVED FR SECTION:

3.2.1 OH MC 847B.

AT Tile HAtlGER ATTACllMEll T CONDUIT A IS O!! Tile SAME IIAllGER.

FINDINGS:

REQUIREHEllTS FOR HAllGER FIREPR00FIllG SECTION:

4.1 FOR CONDUIT A IllCLUDES 12".

THIS C 0HSTITUTES A BREACH Ill A.

A VHY-SI-2 ATTACllHENT D IS REQUIRED FOR EACll BREACH AND ATTACHMENT D IS tl0T FILLE D OUT.

CI llAS 110 HORE IllFO.

UNIT 1 737' ELEV, Oil Q llALL FORM A-14 TO

+

A-12 Oil ELEV 752', llUCLEAR POER C0 llc ERil, TIME FRAl1E-CURREllT.

IN 102-002 CO 112 HBil il Y N Y I-85-513-HBil SR C0tIDUIT HC 846 A IS RUll IllTO OPEll J.

T50119 REPORT B.

1220 AllD llAS 110 VHY-SI-2 ATTACHME EVALUATION PROCESS:

IIT D FORM FILLED OUT.

LOCATI0ll ELEV SECTION: 3.2.1 737 BETHEElf A14 & R AllD A9 & Q.

CI FINDINGS:

HAS 110 ADDITI0tlAL IllFORMATI0tl. UllI T 1, HUCLEAR P0HER CollCERN, TIllE FRA SECTION: 4.1 HE-CURRENT.

IN 103-001 CD 112 HBil 11 Y ll Y I-8 5-427-H Bit SR 110 ATTACHMENT D FROM VHY SI-2 ISSUED T50119 REPORT FOR BREACH TO IllSULATI0tl Oil CABLE C EVALUATION PROCESS:

OllDUIT. CONDUIT 847 B' Oli Q HALL ELE SECTION:

3.2.1 VATICH 737 ADOUT 15' ABOVE Tile FLOOR FINDINGS:

A 10 TO A 8.

ALSO 945 B (SAHE LOCA TIDH) DVER COOLING TAHK 82.

CI HAS SECTION: 4.1 110 ADDITI0llAL INFORMATIDil, llUCL EAR Poller C011CERH. UllIT 1.

OHGOIllG IN 103-002 CD 112 HBil 11 Y !! 7 I-85-428-HBN SR IllSULATI0li IS BEIllG REH0VED (DEPARTM T50119 REPORT EllT Kil0Hil) FROM HORE TilAN OllE BASE P EVALUATION PROCESS:

LATE OF C0llDUIT liANGERS UllDER Tile SA SECTION:

3.2.1 ME VilY S1-2, A1TACilMENT D.

CI EXPRE

$$ED THAT SEPERATE ATTACllMENT D MUST FIND 1Nass BE FILLED OUT FOR EACilllAllGER BREAC SECTION: 4.1 H.

UllIT 1, ELEVATI0ll 713', NUCLEAR P0HER CONCERN, TIME FRAME-CURREHTLY OCCURRING. CI HAS 110 FURTHER INFORM ATI0H.

COHCER!1S ARE GROUPED BY fir.ST 3 DIGITS OF SUBCATEGORY HUMBER.

l ATTACHMENT A REFERENCE

- ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY PAGE' 18 FREQUEllCY

- REQUEST OFFICE OF NUCLEAR P0HER RUll TIME - 12:51:1 OllP - ISSS - RilM EMPLOYEE CONCERil PROGRAM SYSTEM (ECPS)

RUll DATE - 12/02/2 LIST OF EMPLOYEE CONCERN INFORMATI0ll ATEGORY: CO C0tlSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GEllERIC APPL QTC/HSRS P

REFEREliCE SECTION 8 ~

CarlCERil SUB PLT BBSH IllVESTIGATION S

CONCERN CATEGORY - CD NUl1BER CAT CAT LOC FLQB REPORT R

DESCRIPTION SUBCATEGORY - 112 IN 134-001 CO 112 HBil fl Y N Y I-85-461-HBN SR CI EXPRESSED THE CONCERN TNAT THE CU EVALUATION PROCESS:

T50124 REPORT RREllT CONTROLLED HORK PROCEDURES, 05 SECTION:

3.2.5 O NOTES, AND QUALITY CONTROL INSTRUC FINDINGS

• TI0liS ARE NOT READILY AVAILABLE Ill T HE FIELD TO THE CRAFT.

TilIS LACK OF SECTION: 4,5 INSTALLATI0ll REQUIREMENTS FORCED TH E CRAFT TO SEEK INSTALLATI0ll ADVISE FROM QC IllSP. IN Tile PAST (llNICil llAS RECENTLY BEEN STOPPED) OR 10 RELY 0 N THEIR MEMORY AS TO TOLERAllCE RAll0E FTC.

IN ADDITION, THE DRAllING PRO VIDED IN THE HORK PACKAGE IS DIVIDED AMONG NO FOLLC11 UP REQUIRED.

Ill -G6-179-002 CO 112 IlBil il Y N Y NO CRAFT CANil0T STAY BUSY BECAUSE SD MA EVALUATION PROCESS:

T50130 REPORT NY REACTOR BLDG., 52 HAllGERS MUST BE REDESIGNED, AND BECAUSE THE PROPER SECTION: 3.2.3 MATERIAL IS NOT ON SITE. All EXAMPLC FINDINGS:

)

GIVEN HAS HANGER 828 (J003 P60 - CC SECTION: 4*3 T)) LOCATED Ill DVERHEAD OF 729' ELEV

- A2 105. - 2G' ROD SUSPEllDED FR0 M CEILING EMBED TO SUPPORT 4" DIAMET ER STAINLESS STEEL FEEDilATER LINE.

HANGER llAS BEEN DELAYED FOR SEVERAL HEEKS, DUE TO THE PROPER SIZE SPRING CAN NOT BEING AVAILABLE ON SITE. C OllST. DEPT. CollCERII. CI HAS 140 FURT HER INFORMATION. 110 FOLLOH UP R IN 232-X03 CO 112 HBN N Y ll Y I-85-623-HBN SR FCRS ARE NOT APPROVED BY DESIGN ENGI EVALUATION PROCESS:

T50141 REPORT llEERIllo PRIOR TO INSTALLATI0!l AND IN SPECTIO!i, CAUSING ALOT OF CollFUSIGH SECTION: 3.2.1 AllD REHORK. CollSTRUCTION DEPT CollCE FINDINGS:

Ril. CI IIAS No FURTilER IllFORMATION.

gECTION: 4.1 Ill 257-002 CO 112 HBH HYNY Ill-86-257-0 02 NO UtlIT 81 AND 2: 3" CONDUIT HAS IllSTAL T50144 REPORT LED BEFORE THE STEAH GENERATOR HAS I EVALUATION PROCESS:

ilSULATED, CAUSING COSTLY REHORK. TV SECTION: 3.2.3 A SHOULD llAVE LEARNED FR0ll THEIR MIS FINDINGS' TAKE ON UllIT 81 BUT THEY ARE DOING T HE SAME TILING ON UNIT 82.

CollST. DE SECTION: 4.3 PT. CONCERil. CI HAS NO FURTHER INFO RHATION.

110 FOLLOH UP REQUIRED, CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

'ATTACNMENT'AL REFERENCE.

- ECPSI3IJ-ECPS131C TENNESSEE-VALLEY AUTH!RITY

'PAGE 19 ' '

FREQUEllCY

- REQUEST OFFICE OF NUCLEAR PDHER 4

'RUN TIME - 12:51:1 OllP - ISSS - RUM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DATE - 12/02/11 LIST OF EMPLOYEE CONCERN INFORMATION.

ATEGORY: CO - CONSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL.

GENERIC APPL QTC/NSRS P

REFERENCE SECTION B C0tiCERN SUB PLT BBSH IllVESTIGATION S

CONCERN CATEGORY - CD NUMBER CAT CAT LOC FLQB REPORT.

R DESCRIPTION SUBCATEGORY - 112:

_IN 261-002 CO 112 HBH NYYY SR DUE TO HORK REQUIRED BY FCR'S/ECN'S EVALUATION PROCESS:

T50230 REPORT NOT BEING PERFORMED PROMPTLY, THE CR SECTION: 3.2.3 AFT MANY TIMES ARE HORKIllG TO AN 055 FINDINGS:

OLETE DRAHING. AFTER REQUESTING Ilis PECTION FOR COMPLETED HORK, QC MAY I SECTION: 4.3 NFORH CRAFT THAT COMPLETED HORK IS N DT ACCEPTABLE AS A PREVIOUS FCR/ECN REQUIREMENT HAS INCORPORATED IN THE DRAHING, BUT THE HORK HAS NOT BEEN P ERFORMED.

EXAMPLE: PANELS IN THE UN

-IT 2 RELAY ROOM.

CONSTRUCTION DEPAR THENT CONCERN. CI HAS NO ADDITIONAL INFORMATION. NO FOLLOH UP REQUIRED Ill 266-004 CO 112 HBil il Y N Y SR IN 1979-80, AN ELECTRICAL FOREMAN IN T50255 REPORT STRUCTED ELECTRICIANS TO SPLICE CABL EVALUATION l'ROCESS:

ES AND THEN CLOSE CONDUITS SD NO DNE SECTION:

3.2.1 COULD SEE THEM.

DETAILS Kil0HN TO 4 FINDINCS:

TC, HITHHELD DUE TO CONFIDEllTIALITY.

NO FURTHER INFORMATION MAY BE RELE SECTION: 4.1-ASED. CONSTRUCTION DEPARTMENT CONCE RN.

Ill 270-007 CD 112 HBil N Y ll Y SR ENGINEERS DO NOT CONTROL FIELD INSTA EVALUATION PROCESS:

T50237 REPORT LLATIONS OR FIELD EllGINEERING-TYPE H SECTION: 3.2.6 ORK THEY ARE RESPONSIBLE FOR.

THEY FINDINGS:-

DO NOT FOLLOH UP AND VERIFY CONSTRUC TIDH ACTIVITIES. THEY ALLOH CONSTRU SECTION: 4.6 CTION MANAGEMENT TO DETERMINE THE ME THOD AND MANNER OF COMP 0HEllT/MATERI A L INSTALLATI0H HITil0UT ENGIllEERING D IRECTION. THIS CONDIII0tl EXISTS IN ALL CRAFTS: UNITS 1 AND 2.

CI HAS N O ADDITIONAL INFORMATION. CONSTRUCT ION DEPARTHENT CONCERN. NO FOLLOH U P REQUIRED.

CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

'M E

ATTACHMENT &

REFEREllCE

- ECPSI51J-ECPS131C TEllflESSEE VALLEY AUTHORITY PAGE 20 FREQUEllCY

- REQUEST OFFICE OF flUCLEAR P0HER RUll TIME - 12:51:I OtlP - ISSS - RUM EMPLOYEE CollCERN PROGRAM SYSTEM (ECPS)

RUll DATE - 12/02/8 LIST OF EMPLOYEE C0llCERil INFORMATIDH RTEGORY: CO CONSTRUCTI0tl-PROCESS SUBCATEGORY: 112 110RK PLAll/HORK r0!IIROL.

GENERIC APPL QTC/NSRS P

REFEREllCE SECTION I CollCERil SUB PLT BBSH IllVESTIGATI0tl S

CollCERil CATEGORY - CD flUMBER CAT CAT LOC FLQB REPORT R

DESCRIPTIOls SUBCATEGORY - 112 Ill 309-001 CO 112 HDN fl Y ll Y SR APPROXIMATELY 20 PERCENT OF Tile TIME EVALUATION PROCESS:

150232 REPORT TilAT ELECTRICAL llDRK PLANS ARE ISSU SECTION: 3.2.5 ED.

TilEY ARE MISSIllG DRAHIllGS, AND FINDINGS:

11 0. 575 MATERIAL ORDER FORMS.

TifIS SITUATI0ll RESULTS Ill UllHARRAllTED HOR SECTION: 4.5 K DELAYS, CI HAS 110 ADDITIO!!AL IllF0 RHATI 0tl. CONST. DEPT C0!!CERil.

NO FOLL0ll-UP REQUIRED.

Ill 309-0 02 CD 112 HBil 11 Y 11 Y NO VERIFICATI0tl 0F HORK PLAtl COMPLETI0ll EVALUATION PROCESS:

T50232 REPORT Is il0T BElllG DollE PRIOR TO ISSUIllG SECTION: 3.2.4 PUllCil LISTS.

PUllCH LIST ARE DElflG I SSUED TO CREHS TO VERIFY COMPLETED H FINDINGS:

ORK AT Tile SAME TIME IllE HORK PLAll I SECTIC'!: 4.4 S BElllG ISSUED TO AH0 tiler CREH TO Ill ITIALLY PERFORM THE HORK Oil Tile PUllC H LISTS.

THIS RESULTS IN A LOT OF R EHORK. CI IIAS 110 ADDITI0llAL IHFORMA TIDH.

CollSTR. DEPT. CollCERil. 110 F0 LLOH-UP REQUIRED.

MRS-86-003 CD II2 SQll

!! 18 Y N SR ADEQUACY OF ll0RK BEIllG D0llE BY CONST REPORT RUCTION C0llCERilING FUSE IllDEllTIFICAT EVALUATION PROCESS:

1011 HORK PLAtlS SECTION: 3.2.3 FINDINGS:

PH 001-007 CO 112 LIBil il Y ll Y SR HANGER CLAMPS HERE REHORKED AFTER IN SECTION: 4.3 T50139 REPORT SPECTION HITHOUT AUTHORIZATI0tl. SUP ERVISOR (FLAME Kt10liti) IIR0TE !! Ell IllSPE EVALUATION PROCESS:

CTI0tl RECORD FOR REIt1SPECTI0tl.

THE 110tlCONFORMANCE HAS tlEVER DOCUMEllTED SECTION: 3.2.1 BY Tile SUPERVISOR.

DETAILS KH0Hil TO FINDINGS:

QTC, llITHELD DUE To C0!!FIDEllTIALITY SECTION: 4.1 CONST. DEPT C0llCERil. CI IIAS 140 F URTHER INFORMATI0ll.

PH 035-005 CO 112 liLtl 11 Y ll Y SR CI STATED A LOT OF TIMES THEY (MAtlAG EVALUATION PROCESS:

150259 REPORT EMEllT ) HILL BYPASS THE G-PROCEDURES TO GET THE JOB D0llE. CI HAS NO FURT SECTION: 3.2.1 IlER INFORMATION. 110 FURTHER INFOR!!A FINDINGS:

TI0tt Ill THE FILE. C0!!STRUCTI0tl DEPA SECTION: 4.1 RTMENT CONCERil. Il0 FOLLOH-UP REQUIR ED.

C0llCERilS ARE GROUPED EY FIRST 3 DIGITS OF SUBCATEGORY llUMBER.

ATTACHMENT-A-REFERENCE

- ECPS131J-rCPS131C TENNESSEE VALLEY AUTHIRITY-PAGE

. 21.

FREQUEHCY

- REQUEST OFFICE OF-HUCLEAR PDHER RUN TIME - 12:513)

ONP - ISSS - RHtt EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DATE - 12/02/2 LIST OF EMPLOYEE CONCERN INFORMATION

ATEGORY: CD CONSTRUCT!0H-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GENERIC APPL QTC/NSRS P

REFERENCE SECTION B CONCERN SUB PLT BBSH INVESTIGATION S

CONCERN CATEGORY - CD HUMBER CAT CAT-LOC FLQB REPORT R

DESCRIPTION-SUBCATEGORY - 112 QCI-1.31-7-85 CD 112 HBN NNNY SR A QUESTION HAS BEEN RAISED CONCERNIH EVALUATION PROCESS:

K-FORM G CUTTING INTO A HALL TO LEVEL A BAS SECTION: 3*2.1 E PLATE.

IF THE AREA IS LARGER THAN 10 INCHES SQUARE AND DEEPER THAN 1 FINDINGS:

5/8 INCHES ENGINEERING IN THE PAST S SECTION: 4.1 AID To LEVEL A PLATE ON AN UVAL PLAC E ON THE HALL IT IS OK TO CHIP DOHH THE HIGH SIDE OF THE PLANT HNEN IT I S TO BE FLUSH HITH THE HALL HITHOUT A CHIPPING RELEASE. CANNOT FIND IN ANY PROCEDURE HHERE IT ALLOHS US TD CHIP MORE THAN 10 INCHES SQUARE OF 1 5/8 INCHES DEEP.

G-32 4.6.1 DOES E XPLAIN H0H TO FILL THE GAP BE1HEEN THE PLATE AND THE SURFACE QUIPkEkkfSNTkNS Lhhb Phk Hk D HBP-85-017-006.

CD 112 HBN NYHY SR T50241 REPORT RAHING.

(DETAILS KH0HH TO QTC AND H ITHHELD TO MAINTAIN CONFIDENIIALITY) EVALUATION PROCESS:

NO FURTHER INFORMATION MAY BE REL SECTION: 3.2.1 EASED. NUCLEAR PDHER CONCERN. CI H AS NO FURTHER INFORMATION.

FINDINGS:

SECTION: 4.1 HBP-86-013-002 CO 112 HBN HYHY SR CRAFT (KNOHH) 0FTEN DETERMINES THE C T50244 REPORT ONFIGURATION OR DESIGN THAT CAN BE I HSTALLED AND THEN ENGINEERING PERFOR EVALUATION PROCESS:

MS THE SKETCH AND CLAIMS CREDIT FOR SECTION: 3.2.2 THE DESIGN. CONSTRUCTION DEPARTHENT FINDINGS:

CD CERN.

CI HAS NO FURTHER INFORMA SECTION: 4.2 HI 061-001 CD 112 HDH HYNY SR EQUIPMENT HAS REMOVED, POSSIBLY TO A T50151

. REPORT VOID AN INSPECTION OF EQUIPMENT BY N EVALUATION PROCESS:

RC, AND SUBSEQUENTLY REPLACED. DETA SECTION: 3.2.1 ILS KNOHN TO QTC, HITHELD DUE TO CON FIDENTIALITY. CONSTRUCTION DEPT CON FINDINGS:

CERN.

CI HAS NO FURTHER INFORMATI0H SECTION: 4.1 No FLLOH-UP REQUIRED.

HI 068-002 CO 112 HBN NYHY NO CABLE TRAY MAY HAVE BEEN REH0VED HIT T50278 REPORT HOUT PROPER DOCUMENTATI0H.

DETAILS EVALUATION PROCESS:

KN0HN TO QTC, HITHHELD DUE To CONFID SECTION: 3.2.1 ENTIALITY. NO FURTHER INFORMATION N FINDINGS:

AY BE RELEASED. CONSTRUCTION DEPART MENT CONCERN.

SECTION: 4.1 CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

W

ATTACitHENT A '

REFERENCE

- ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY-PAGE'

' FREQUENCY. - REQUEST OFFICE OF NUCLEAR PDHER 22-I EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS).

RUll TIME - 12:51:

DNP - ISSS - RHM RUN DATE - 12/02/-

LIST OF EMPLOYEE CONCERN INFORMATION p 2ATEGORY: CO CONSTRUCTION-PROCESS SUBCATEGORY: 112-HORK PLAN /HORK CONTROL GENERIC APPL QTC/NSRS P

REFERENCE SECTION O C0tlCERN SUB PLT BBSH INVESTIGATION-S CONCERN CATEGORY - CD NUMBER CAT CAT LOC FLQB REPORT R-DESCRIPTION SUBCATEGORY - 112 HI 091-005 CO 112 HBil il Y H Y SR EMPLOYEES HAVE BEEN DIRECTED TO PERF T50197 REPORT ORM AN INSTALLATION HITHOUT THE APPL EVALUATION PROCESS 8 ICABLE FCR OF FF.

CI HAS NO FURTHER SECTION: 3.2.1 INFORMATION. ' CONSTRUCTION DEPT. CD FINDINGS:

NCERN.

SECTION: 4.1 HI 091-006 CD 112 HBN 11 Y N Y SR HANGERS ARE FREQUENTLY IllSTALLED AND T50197 REPORT THEN ENGINEERING DOES THE AS-CONSTR EVALUATION PROCESS:

i UCTED DRAHING. CI HAS No FURTHER IN SECTION: 3.2.2 FORMATION. CONSTRUCTION DEPT CONCE FINDINGS:

RN' SECTION: 4.2

~ 111 091-012 CD 112 HBil if Y N Y NO-THE HANGER GROUP CLAIHS CREDIT FOR A T50197 REPORT COMPLETED HANGER HilEli THEY SUBMIT T EVALUATION PROCESS:

j HE HANGER FOR INSPECTION.

IF TifE HA SECTION: 3.2.3 NGER GETS REJECTED IT HILL BE SUBMIT

}

TED AGAIN AS A COMPLETED HAl4GER AFIE.. FINDINGS:

g R THE REHORK, ETC., HAS BEEN DONE.

SECTION: 4.3 THIS IS A PROCEDURAL VIOLATION.

EXA MPLE: DURING A ONE MONTH PERIOD THE HANGER GROUP CLAIMED CREDIT FOR 63 H ANGERS HHILE El4GINEERING REPORTED 3 HAllGERS. CI HAS NO FURTHER INFORMAT 10N.

CONSTRUCTIDH DEPT CONCERN.

1'HI 100-032 CO 112 HBil il Y N Y SR CONSTRUCTION PROCESS DOES.NOT ALHAYS EVALUATION PROCESS:

T50212 REPORT FOLLOH ENDES REQUIREMEllTS DOCUMEllIS

, OR VENDOR REQUIREMENTS /INSTRUCTIOil SECTION: 3.2.1 S.

THESE DEVIATI0lls D0 fl0T ALHAYS G FINDINGS:

j ET INCLUDED ON AS-BUILT DOCUMEllTS, A SECTION: 4.1 i

ND THERE IS TOO HUCH "AFTER THE FACT

" APPROVAL. CI IIAS No FURTHER IliFOR j

MATION. ANONYMOUS. CONCERN VIA LETTE R.

XX 077-XO4 CD 112 SGH 14 N Y N I-85-860-SQN SS SEQUOYAH - DRAHINGS HAVE BEEN FALSIF EVALUATION PROCESS:

T50194 IH 000 REPORT IED.

DETAILS KNDHN TO QTC, HITHHELD SECTION: 3.2.1 DUE TO C0teFIDEllTIALITY. CONSTRUCTI FINDINCS:

Dil D COICERN. CI tlAS NO FURTHER SECTION: 4.1 1

j C0tlCERilS ARE GROUPED BY FIRST 3~ DIGITS OF SUBCATEGORY HUMBER.

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ATTACHMENT A REFERENCE ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY PAGE

' 23

-FREQUENCY

- REQUEST OFFICE OF NUCLEAR P0HER RUN TIME - 12:51 ::

ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DATE - 12/02/;

LIST OF EMPLOYEE CONCERN INFORMATION

.:ATEGORY: CD CONSTRUCTION-PROCESS SUBCATEGORY: 112 HORK PLAN /HORK CONTROL GENERIC APPL QTC/NSRS P

REFERENCE SECTION 8 CONCERN SUB PLT BBSH INVESTIGATION S

CONCERN CATEGORY - CO -

HUMBER CAT CAT-LOC FLQB REPORT R

DESCRIPTION SUBCATEGORY - 112 XX 101-002 CD 112 SQN HHYN SR SEQUOYAH-IMPROPER INSTALLATION OF N EVALUATION PROCESS:

T50162 REPORT ON-NUCLEAR SYSTEM COULD ADVERSELY AF SECTION: 3.2.7 FECT PUBLIC HEALTH AND SAFETY, DETA ILS KH0HN TO QTC, HITHELD DUE TO CON FINDINGS:

FIDENTIALITY. CONSTRUCTION DEPT CON

• SECTION: 4.7-CERN. CI HAS NO FURTHER INFORMATI0H-NO FOLLOHUP REQUIRED.

XX 120-006 CD 112 SQN NYYY I-86-194-SQN SS SEQUOYAH - HANGER CREHS HERE INSTRUC - EVALUATION PROCESS:

T50247 REPORT TED (SUPERVISOR KNOHN) TO GO AHEAD A ND BUILD HANGERS HITHOUT DRAHINGS, A SECTION: 3.2.2 ND ENGINEERING HOULD DRAH THE HANGER FINDINGS:

UP LATER. MANY OF THESE HANGERS HE RE SUBSEQUENTLY REJECTED AND REHORKE SECTION: 4.2 D.

CONSTRUCTION DEPARTMENT CONCERN.

CI HAS No FURTHER INFORMATION.

100 CONCERNS FOR CATEGORY CD SUBCATEGORY 112 CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

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Attechment B -

List of Evaluators Evaluator Plant Sito Jim Russell WBN, SQN Guy Huff WBN, BLN John Campbell WBN, BLN I-David Shelton BLN e

Page 1 of I

Attachment C -

List of Concerns by Issue 1.

Unauthorized / Undocumented Work BLNDNEEC85-11 IN-85-297-001 IN-86-232-X03 EX-85-048-003 IN-85-410-011 IN-86-266-004 EX-85-052-006 IN-85-579-002 PH-85-001-007 IN-85-019-001 IN-85-847-006 PH-85-035-005 IN-85-046-002 IN-85-850-004 QCI-1.31-7-85 IN-85-046-008 IN-85-915-001 WBP-85-017-006 IN-85-093-001 IN-85-947-003 WI-85-061-001 IN-85 277-001 IN-85-962-003 WI-85-068-002 IN-85-286-007 IN-86-102-001 WI-85-091-005 IN-85-293-005 IN-86-102-002 WI-85-100-032 IN-85-293-014 IN-86-103-001 WI-85-100-032 IN-86-103-002 XX-85-077-X04 2.

Craftsmen Doing Engineering Work EX-85-082-002 IN-85-293-026 EX-85-085-001 EX-85-104-002 IN-85-349-003 EX-85-105-002 IN-85-447-003 WBP-86-013-002 EX-85-121-004 IN-85-520-003 WI-85-091-006 IN-85-111-001 IN-85-595-003 XX-85-120-006 3.

Poor Planning and Coordination EX-85-002-004 IN-85-514-003 IN-86-179-002 IN-85-514-007 IN-86-257-002 IN-85-057-003 IN-85-787-001 IN-86-261-002 IN-85-362-002 IN-85-816-002 MMAS-86-003 IN-85-377-001 IN-85-978-008 WI-85-091-012 IN-85-409-002 IN-85-978-009 IN-85-437-002 IN-85-999-001 4.

Inadequate Walkdown and Walkdown Information IN-85-215-001 IN-86-019-006 IN-85-442-009 IN-86-309-002 IN-85-442-014 5.

Poor Quality of Work Packages and Work Package Control EX-85-052-003 IN-85-348-004 IN-85-743-010 EX-85-094-002 IN-85-418-001 IN-85-762-002 EX-85-121-002 IN-85-423-001 IN-85-898-002 HI-85-093-001 IN-85-480-006 IN-86-134-001 IN-85-263-001 IN-85-480-007 IN-86-309-001 IN-85-281-002 IN-85-618-002 Page 1 of 2

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Attcchment C (Continusd)

List of Concerns by Issue 6.

Questionable Engineering Practices EX-85-053-006 IN-85-286-001 IN-85-397-001 EX-85-058-001 IN-85-388-007 IN-85-728-003 EX-85-058-002 IN-85-388-009 IN-85-670-002 c

IN-86-270-007 7.

Improper Installation XX-85-101-002 i

Page 2 of 2