ML20215A837

Rev 5 to Sequoyah Element Rept 80000-SQN, General Mgt & Policy, TVA Employee Concerns Special Program

ML20215A837
Person / Time
Site:	Sequoyah
Issue date:	05/27/1987
From:	Russell Gibbs, Gray T, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215A652	List: ML20215A649 ML20215A738 ML20215A775 ML20215A797 ML20215A813 ML20215A837 ML20215A851
References
80000-SQN, 80000-SQN-R05, 80000-SQN-R5, NUDOCS 8706170105
Download: ML20215A837 (19)

Text

1. i l

TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80000-SQN REPORT TYPE REVISION NUMBER:

Element Report 5 -

TITLE: PAGE 1 0F 14 l General Management and Policy  ;

REASON FOR REVISION: Incorporation of NRC comments.

l Revision indicators are found in the right margins to i note changes made.

Note: Sequoyah Applicability Only PREPARATION PREPARED BY: Wayne M. Akeley/ Ronald D. Halverson

' ' ' /

SIGNATURE '

DATE REVIEWS PEER:

J I

d d Srsu K- 2 7 - F -'

SIGM\TURE DATE j

TAS:

b ri"ls' d],udf6P W s/ze47 SIGNATURE / py,E CONCURRENCES CEG-H: / n ,

f,/2,7/$7 sRP: Ye,ff(2uad 6 2-e7  ;

SIGNATURE DATE SIGNATURE

• DATE APPROVED BY:

f

-D - DhD L0 --

{ff.3h] N/A W SP MANAGER DATE MANAGER OF NUCLEAR POWER DATE c- s CONCURRENCE (FINAL REPORT ONLY)

O

• SRP Secretary's Signature denotes SRP concurrence are in files.

8706170105 870605 ,

PDR ADOCK 05000327 l P PDR '

6 1

REPORT NUMBER:

REPORT TYPE- 80000-SQN l Element Report REVISION NUMBER:

TITLE: 5 l

General Management and Policy PAGE 2 0F 14 j 1.0 CHARACTERIZATION OF ISSUE 1.1 Introduction I l

The issues described in this element report were derived from employee concerns generated as a result of the Watts Bar Employee Concern Special Program. The issues were determined to be applicable to the Sequoyah Nuclear Plant (SQN) and were investigated and evaluated on that basis. i j

1.2 Description of Issues The conditions reported by concerned employees are:

a. A nonchalant regard for quality sets an example for subordinate employees to likewise promote and tolerate poor quality at Sequoyah. (XX-85-116-005)

b. During the exit interview the concerned individual (CI)' expressed

~

4 the concern that mistakes made at SQN and other plants are not corrected. (WBN-86-066-001) i

c. Electrical General Foreman was reprimanded for using Non 'Q' materials in 'Q' systems, but continued to tell his workers to do this. (XX-85-033-006)

d. CI was requested by superviso rs to sign-off data sheets on defective equipment. CI initially re fused to sign because corrective action had not been taken. CI was asked second time to sign the data sheets and did so to avoid getting a letter for insubordination. (XX-85-027-X07)

e. TVA informed the Nuclear Regulatory Commis sion (NRC) that cable ,

had been removed from the site in 1981. When in fact the cable "

was still being removed in 1984. This is documented on Nonconformance Report (NCR) SQN EEB 8019Rl. (XX-85-027-X03) f.

Process for evaluation of 10CFR21 applicability. (BFN-IESC 03) ,

I

g. Inadequate understanding of the level of control required in  !

nuclear parts program is indicative of weakness in NQAM. (

(BFN-IESC-85-03) {

h. The issue of " configuration control" was not evaluated as this i

issue is adequately covered in operations Element Report 307.13-SQN. (BFN-IESC-85-03) l 1

t REPORT NUMBER:

REPORT TYPE 80000-SQN Element Report . REVISION NUMBER: ]

TITLE: 5 General Management and Policy PACE 3 0F 14 2.0

SUMMARY

]

1 2.1 Summary of Characterization of Issues j

I Principal issues raised by concerned employees are: nonchalant regard ]

for quality, mistakes are not corrected, Non-Q materials are used in Q '

systems, improper sign-off on data sheets, the NRC was misinformed of 3 cable removal, the process for evaluating 10CFR21 applicability is questioned, inadequate understanding of the nuclear parts program, and 3 configuration control. '

l 2.2 Summary of Evaluation Process 1

Upper tier and lower tier documents were reviewed 'to determine requirements and responsibilities along with _ the procedural direction. -j Correspondence, codes,. standards, procedures, instructions, inspection {

reports, nonconformance reports, and memorandums were also reviewed to '

determine the full extent of the concerns and their overall significance to the Sequoyah Nuclear Plant. Additionally, discussions were held with various TVA personnel pertaining to specific problem areas regarding electrical cables, spare parts, procurement, and battery inspections.

2.3 Summary of Findings The conclusions reached as a result of the Quality Assurance Category Evaluation Group (QACEG) evaluations of these issues are: >

The issues regarding " nonchalant regard for quality promotes poor quality" and " mistakes made were not corrected" could not be properly evaluated due to the vagueness and lack of specific information.

The issue of using "Non 'Q' materials in 'Q' systems" was substantiated in that a general foreman instructed craft personnel to use a QA Level I or II part which did not have the required documentation.

The issue of " improper sign-offs on data sheets" could not be substantiated. The sign-offs required of the inspector did signify QA 5 i acceptance, however, the data sheet in question provided a means by I which the inspector could document " Exceptions."

The issue that "TVA informed the Nuclear Regulatory Commission that cable had been removed from the site in 1981 when in fact the cable 5 was still being removed in 1984" is not substantiated. No documented i

evidence exist that TVA informed the NRC that the cable in question l was removed from the site.

l l

l l

l

REPORT NUMBER:

REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

TITLE: 5 General Management and Policy PAGE 4 0F 14 The issue of " Process for evaluation of 10 CFR 21 applicability" is unsubstantiated in that documentation pertaining to these reviews was available and that procedural guidelines were properly followed. l The issue of " inadequate understanding of the control required for the  ;

nuclear parts program" is substantiated. Personnel did not fully i understand procurement requirements due to program inadequacies.

2.4 Summary of Corrective Action Regarding the use of Non "Q" materials it was determined that an isolated instance did exist where Non "Q" Material was improperly installed in a "Q" System. However, the part was replaced and appropriate disciplinary action taken. With respect to the PJJ and PNJ cable, it was determined that all cable had not been removed which has resulted in Environmental Qualification for those type cables. In addition, a CATD has been initiated to provide expected completion dates for cable testing. Responses to this CATD were evaluated and results concurred with the QACEG. Corrective actions toward s improving the Procurement Program have been initiated which should help streamline the system.

3.0 LIST OF EVALUATORS W. M. Al'eley R. D. Halverson 4.0 EVALUATION PROCESS 4.1 General Method of Evaluation This evaluation was performed by reviewing many documents such as inspection reports, Inspection Instructions / Guidelines, Notice of Indications (NOI), Construction Procedures / Specifications, Quality Assurance Procedures, American Society of Mechanical Engineers (ASME) l Boiler and Pressure Vessel codes, Design Standards, Work Requests, 1 Nuclear Quality Assurance Manual (NQAM), Nonconformance Reports (NCR),

memorandums, and TVA's QA Topical Report. In addition, discussions with cognizant personnel were held pertaining to specific problem areas regarding each issue.

4.2 Specifics of Evaluation l

' 4.2.1 Issue - Nonchalant Regard for Quality l Reviewed Employee Concern File including Confidential Files for any additional information pertaining to this concern. No additional information was available.

REPORT ' NUMBER:

. REPORT TYPE- 80000-SQN-Element Report REVISION NUMBER:  !

TITLE: 5' .!

General Management and Policy

~

PAGE.5 0F 14 )

i I

4.202 Issue - Mistakes Not Corrected

- Reviewed . Employee ' Concern File including . Confidential Files ,

for any additional. information pertaining to this concern. No l additional information was available. )

1 4.2.3 Issue - Use of Non "Q" Materials in "Q" Systems Reviewed . Employee Concern Files including Confidential ' Files for any additonal information pertaining to this concern.

Nuclear Safety Review Staff (NSRS) Report I-85-814-SQN was reviewed documenting the investigation and findings of this l concern. Codes, standards, procedures, instructions, and reports reviewed-during this investigation'are included in the NSRS_ Report.-

4.2.4 Issue - Data Sheet Sign Off

')

Reviewed Employee Concern Files including Confidential Files for any additional information pertaining -to this concern.

Quality Technology Company (QTC) Report XX-85-027-X07 documenting the investigation and findings o': this concern was reviewed. This report was utilized during the evaluation process of thic concern and its contents re-evaluated by QACEG. This report draws the same conclusion as the QACEG evaluation.

In conjunction with the QTC Report, Inspection Instruction No.

19, Revision 9, " Battery Inspection", Inspection Instruction No. 30, Revision 7, " Receipt Inspection", and Nonconformance Report 2803, were also reviewed during this investigation.

4.2.5 Issue - Nonconforming Cable Not Removed From Site, i

Reviewed Employee Concern File including Confidential Files for additonal information pertaining to this concern. 'NSRS Report I-85-218-SQN, documenting the investigation and j findings of this concern, was used as the basis of the Summary )

and Findings section of this report and includes various.

documents reviewed during this investigation.

I l

4.2.6 Issue - Process For Evaluation of 10 CFR 21 Applicability.

i 1 Reviewed Employee Concern File including Confidential Files l for any additional information pertaining to ' this concern. l The Nuclear Operations Quality Assurance Manual (N0QAM) Part #

l l

l l J

I 1

l REPORT NUMBER:

REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

TITLE: 5 General Management and Policy PAGE 6 0F 14 III Section 2.1, entitled " Procurement of Materials, Components, Spare Parts, and Services" was reviewed in conjunction with Appendix F, Attachment 1 of N0QAH Part III,  !

Section 2.1 to determine if appropriate requirements were contained . in N0QAM and implementing procedures. SQNP SI-114.1

" Inservice Inspection" in conjunction wit :1 N0QAM Part III, Section 7.2 was also reviewed to aucertain if unacceptable indications noted during random inspections were in fact evaluated for significance and for potential reportability.

Four Notice of Indications (NOIs) and associated documentation of unacceptable conditions, identified by liquid penetrant methods, were reviewed to assure that these indications were properly evaluated for 10 CFR .21 applicability in accordance l with the site inservice inspection program. Additionally, six purchase requaitions were also reviewed attesting to the  !

implementation of 10 CFR Part 21 requirements.- i Reviewed Engineering Procedure NEP-4.1 Revision 0,

" Procurement", and recently prepared material requaitions . to determine engineering involvement as it also applies to the {

requirements of 10CFR21. t 4.2.7 Issue - Inadequate Understanding of Level of Control Required in Nuclear Parts Program (

x.

l The initial investigation was spent gaining an . und ers ta nding  !

of the basic mechanics of site procurements (forms used, I terminology, and coordination required) and reviewing  ;

procurement files. Four Quality Control personnel were '

interviewed to a sc ertain their understanding of the total' t procurement system and to identify their specific 1 responsibilities.  !

5.0 FINDINGS i

5.1 Findings on Issue - Nonchalant regard for Quality i

Discussion I This issue, can not be properly investigated or evaluated due to the vagueness and lack of specific information. l i

i 1

8 5.2 Findings on Issue - Mistakes are not corrected. 1 Discussion f

t This issue, can not be properly investigated or evaluated due to the  !

vagueness and lack of specific information. l l

t

, a 1

. _ -a

l

, I

' REPORT NUMBER:

REPDFT TYPE 80000-SQN Element Report REVISION NUMBER:

5 TITLE: 3 ceneral Management and Policy PAGE 7 0F 14 l 7

i l

5.3 Findings on Issue - Use of Non "Q" materials in "Q" systems Discussion Further information was requested from the Employee Response Team (ERT) to identify the approximate time frame to which the concerned individual was referring. The ERT indicated that the events occurred sometime between February 1984 and early 1986.

QACEG utilized NSRS Report I-85-814-SQN in the evaluation of this concern. On May 9, 1985, during maintenance on solenoid valves 2-FSV-1-183A, an electrical general foreman in the Sequoyah Electrical Maintenance Section instructed craft personnel to use a.QA level I or II part (diode) which did not have required documentation. This work was being performed under maintenance request MR A-300161. Solenoid valve 2-FSV-1-183A is a critical component as defined by Sequoyah Standard Practice SQA134, Appendix A, part III, " Critical Structures, Systems, and Components CFC List". MR A-300161 stipulated the specific use of Maintenance Instruction MI-6.20 and Modification and Addition Instruction MAI-12. These procedures require, among other things, that QA personnel inspect the crimping of the diode. Contrary to these requirements, the general foreman instru:ted craft personnel ,

to install the diode without proper documentation and QA inspection. 1 This action by the general foreman resulted in a formal reprimand. )1 MR A-201208 was submitted and work initated on May 10, 1985, to j inspect and replace the Non-Q diode with a diode having the proper 1 documentation. On May 16, 1985, the Electrical Maintenance Section l Supervisor discussed the gravity of the general foreman's failure to l' follow procedures and his responsibility. Based on this discussion ar.d the formal reprimand, the section supervisor was of the opinion that the general foreman clearly understood the significance of his actions and what is expected in the future. The section supervisor is not aware of any additional instances where this or any other electrical general foreman has instructed craft to use Non-Q parts in QA systems. The Electrical Maintenance Section Craft Unit Supervieor directly supervises the section's electrical general foreman. The unit supervisor recommended the disciplinary action to the section supervisor following the May 9, 1985 incident. To the best of the unit supervisor's knowledge, the practice of instructing the craf t to violate plant procedures has not continued.

The Electrical Maintenance Section is staffed with seven electrical crew foreman and approximately 42 journeyman electricians. Interviews

' were conducted with two of the crew foremen from day shift, the evening shift crew foreman, a dual rate foreman, and the d ay shift general foreman. In additon, three electricians were interviewed from the day n,hif t and four electricians from the evening shif.t . These

1 REPORT NUMBER:

REPORT TYPE 80000-SQN Element Report REVISION NUMBER: j TITLE: ,

5 I General Management and Policy PAGE P z ' 14 l l

individuals were selected at random. None of the individuals )

interviewed stated that they were ever instructed to use Non-Q parts l in QA systems nor were they aware of any electz ical general foreman {

current lyy doing so.

Conclusion The concern of record is substantiated in part. It was substantiated

.i i> that a situation occurred in which craft personnel had been instructed f to install a QA level part without. proper documentation and to proceed j with its installation in violation of approved plant procedures.  !

Actiori was taken immediately to replace the part and action was taken to discipline the responsible electrical general foreman. The dischlinary action appears to have been effective. No evidence i exists that the general foreman continued to tell his workers to do this or of similar failures to follow plant procedures.

5.4 Findings on Issue - Data sheets sign-off l Discussion 4

This issue is based upon SQN NCR 2803 written on July 21, 1982 identifying unacceptable specific gravity level with the (never commissioned) fifth diesel generator battery ec11s. This -

5 nonconforming condition was originally identified in accordance with j SNP Inspection Instruction No. 19 and documented on Data Sheet 1,

" Battery Inspections", dated 6/18/82. Office of Nuclear Power (ONP) disposition to NCR 2803 was to reduce the specific gravity of the battery electrolyte by using the " Approved Power System Procedure" l (MEB '811230 995). This disposition, Rev. 1, was written 12/22/82.

However, it wasn't approved by the Design Project Organization and assigned to disposition Block 6 of NCR 2603 until 6/14/83. As evidenced by the NCR (Block 8), the assigned dispu ition was completed znd the batteries released from a nonconforming status on 7/5/83.

During the period when the nonconforming condition was identified (6/18/82) and when corrective petions were completed (7/5/83), l periodic inspections (bi-weekly, sconthly, and quarterly) were being performed as required by SNP Inspection Instruction No. 19. This procedure required the Electrical Engineering Unit to issue Data Sheet 1, " Battery Inspection," and 'tne Inspection Group inspector to document the results of this inspection a this form. On the bottom of Data Sheet 1, there is an area provided for the signature of the inspector and the date the inspection ucs performed. Data Sheet 1

} also provides a section in which the inspector can document any l exceptions. Inspection Inc.truction No. 19, Paragrcph 9.0 states in 5 e part; " cells not meeting the acceptance criteris of this instruction shall be listed in the ' exceptions' space of ".ta Sheet 1." In this instance, the inspector did document exceptions as "all cells specific gravity too high to that called for by procedure." ,

I

i l

' REPORT NUMBER: i REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

5 TITLE:

General Management and Policy PAGE 9 0F 14 i

Conclusions The concern indicates the Concerned Individual (CI) is reluctant to sign off data sheets when the acceptance criteria of SNP Inspection Instruction No. 19 has not been met was unsubstantiated. The concerned employee has no valid reason to refuse to sign the data sheet as the signature on Data Sheet 1 is attesting to the exceptions taken as well as the acceptance of a item, 5.5 Findings on Issue - NRC misinformed of cable removal Discussion  ;

As a result of OE evaluations of NUREG-0588, specific applications of PJJ and PNJ types of cable were identified as not qualified for the accident environmental condition. This entailed the issuance of NCR SQN EEB 8019 and various TVA letters to the NRC informing them of 10 CFR 50.55 (e) deficiencies < Between June 16, 1980 and June 29, 1981, five status reports concerning NCRs issued on environmental qualification were sent to the NRC. However, none addressed PJJ and PNJ cable nor contained any information that indicated to NRC that issued PJJ and PNJ cables had been removed from SQN in order to prevent further installation. The disposition of NCR 8019 required removal of all remaining cable of type PJJ and PNJ. Although this was not completed in a timely manner, a majority of PJJ and 'NJ cable was

~

s removed from Sequoyah as evic' enced by Trans f er Requisiticn 828512.  ;

However, NCR 5019 improperly ed that all PJJ and PNJ cable had been removed by Transfer Requis. n 828512.

1 Conclusion This issue is not substantiated. Although NCR 8019 improperly stated that all PJJ and INJ had been removed from the site, no evidence was 5 )

found that the NRC was misinformed of its removal. l 5.6 Findings on Issue - Process for evaluation of 10 CFR 21 applicability Discussion It was determined from reviewing all pertinent correspondence and infor.ation provided in the Confidential Files that the concerned individual was concerned with the 10 CFR Part 21 reportability of vendor supplied items.

There are two distinct groups within the Sequoyah organization

' The Nuclear Power Division procures currently purchasing material.

items in ac cord anc e with Part III of the Nuclear Quality Assurance Manual, supplemented with Standard Practice SQA45 (" Quality Conte al of Materials and Parts and Services") and the Nuclear Engineering Group procures material for modifications in accordance with NEP-4.1,

l

• I REPORT NUMBER i REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

TITLE: 5 l General Management and Policy PAGE 10 0F 14 I i

l 1

entitled " Procurement". Each group determines whether 10CFR21 l requirements are applicable to the supplier for procurement of items and services. The Nuclear Engineering Group, is required in .,

accordance with Section 3.0, paragraph 3.6 of NEP-4.1, and Attachment j 24, "10CFR21 Applicability" to assure that TVA procureruent i specifications and requisition packages for nuclear safety-related items meet the reporting requirements of 10CFR21.

This concurrence is documented on material requisitions. Ten SQN requisitions prepared during 1979-1981, and five recently prepared requisitions of material purchased by the Design Engineering Group,  !

were reviewed to assure that documentation attent ng to 10CFR21 l applicability was available. All documentation reviewed was satisfactory. The Nuclear Power Group currently purchases items' in accordance with Nuclear Operations Quality Assurance Manual (N0QAM)

Part III, Section 2.1, evaluates each item or service for 10CFR21 applicability by the use of Attachment 1, Appendix F entitled

" Determination of Basic Component Status and 10CFR Part 21 Applicability". The review of the fifteen SQN Purchase Requisitions prepared between 1979-1986 revealed that all had been appropriately reviewed for 10CFR Part 21 applicability with corresponding documentation substantiating all reviews.

Further investigation was conducted to assure that the process for evaluation of 10CFR Part 21 applicability was conducted regarding the

~. Inservice Inspection (ISI) Program. Surveillance Instruction SI-114.1, Section 17,0 entitled " Notification of Indication" requires the organization assigned responsibility for repair within NUC PR to determine if the unacceptable condition is significant and potentially reportable in accordance with the requirements of N0QAM, Part III, Section 7.2. A review of four of 34 Notification of Indication forms reporting unacceptable indications identified by the liquid penetrant examination method, indicated each had been evaluated for 10CFR Part 21 r.pplicability as required.

Conclusion This issue is unsubstantiated at . SQN, based on the fact that the appropriate documentation prepared by each purchasing group was reviewed and found satisfactory. Additionally, the process by which determinations of 10CFR Part 21 applicability are made was found to be satisfactory. Futher information regarding the procurement program for replacement items is contained in paragraph 5.7 of this report. 5l l J

5.7 Findings on Issue - Inadequate understanding of the level of control

' in the nuclear parts program. .

Discussion l The issue of whether inadequate understanding of the level of control in the Nuclear Parts Program was indicative of a NQAM programmatic i weakness was substantiated by the QACEG investigation.

l l

i I

- REPORT NUMBER:

REPORT TYPE. 80000-SQN -

Element Report REVISION NUMBER:

' TITLE: 5 General Management and' Policy PAGE 11 0F 14 Part III, Section 2.1 of the Nuclear Quality Assurance Manual (NQAM) provides the methods for controlling the procurement of materials components and spare parts. A review of the NQAM determined' that' it assigns responcibilities and provides interpretation of ~ regulatory -

requirements, invokes the applicable' quality assurance program requirements lis ted in , ANSI N45.2, Appendix B to 10CFR50, ASME Section III- and Oection XI, and further implements the requirements of ANSI N45.2.13.

-Prior to 1984, TVA recognized that the procurement program was in need of strengthening. This was further substantiated by the' fact that.the NSRS investigation performed'during June 11, 1984 and December 5, 1985 also reiterated the f act that deficiencies did ' exist - with various aspects of the program.- The problems were categorized into five areas:

a. General unfamiliarity with procurement cycle

b. Excessive and/or ineffective review of Purchase Requests and requisitions

c. Ineffective use of the available procurement system

d. Apparent lack of planning, and

-x

e. Quality Assurance These deficient areas were also addressed and recommendations provided. These recommendations consisted of:

a. Establish a planning group

b. Improve Purchasing / site communications

c. Eliminate unneesssary procurement cycle steps, and

d. Better utilize automated systems Additionally, interorganizational- communications- 'and working relationships were developed to help solve problems and streamline operations. With respect to previously identified weaknesses within the NQAM, several revisions have been issued which provide for additional training requirements,. organizational changes, review approval cycles, and current commitments. The QACEG evaluation

' concentrated on interviews with six personnel in the Sequoyah Procurement Program. These' interviews indicated that although weaknesses have been identified as previously noted, the program has been expanded and enhanced to comply with procurement commitments.

4

• REPORT NUMBER:

REPORT TYPE 80000-SQN l Element Report REVISION NUMBER:

TITLE: 5 Ge'Teral Management and Policy PAGE 12 0F 14 Al c.o , the personnel actually involved currently in day to day procurement activities appeared to have adequate knowledge of the level of control regarding nuclear parts. Additionally, SQA45, entitled " Quality Control of Material, Parts and Services", dated May 30, 1984 and Administrative Instruction Al-11 entitled " Receipt Inspection Nonconforming Items, QA Level / Description Changes and Substitiutes", dated May 21, 1984 with recent revisions, were reviewed to determine program compliance. It would appear that the many problems previously experienced with the NQAM prior to 1984 caused confusion among those involved in daily procurement activities. 'With j recognition of these program inadequacies by management and site i personnel, and the retraining and program manual revisions, indications are that the program is better organized and capable of controlling materials at SQN.

Conclusion This issue is subotantiated by the fact that the' many problems identified with the NQAM did in f act cause confusion and contribute to the misunderstanding of the control requirements by the the procurement program.

5.8 Corrective Actions This section encompasses corrective measures taken and the results

' achieved to date on behalf of TVA and also those corrective actions identified during this evaluation.

Issue - Use of Non "Q" materials in "Q" systems Maintenance Request (MR) A-201208 was submitted and worked on May 10, 1985, to replace the Non-QA diode with a diode having proper j documentation and required inspections were performed. On May 16, 1986, the general foreman responsible was formally reprimanded by the Maintenance Section Supervisor for not following site procedures. The results of the QACEG investigation indicates this was an isolated incident with no further corrective actions necessary.

Issue - NRC was misinformed of cable removal all PJJ and PNJ cable was not removed from the site as stated in the NCR.

At the time of NCR 8019 closing, inadequate action was taken to prevent further installation, and action was not taken to ensure that all unused cable had been removed from the site. Failure to write a j

site NCR and to quickly remove from the site these cables resulted i.n its noncontrolled use. However, the adequacy of PJJ and PNJ cables i installed at SQN has been evaluated as part of the electrical equipment Environmental Qualification Project. Corrective action regarding this issue was determined to be required. SQN EQ Project has demonstrated Environment Qualification for TVA Type PJJ Cable

REPORT NUMBER:

REPORT TYPE 80000-SQN Elament Report REVISION NUMBER:

TliLE: 5 General Management and Policy PAGE 13 0F 14' installed ' in 50.49 circuits. Review of the SQN Electrical Equipment List shows that no PNJ Cables (or cables of the same family) have been installed in 50.49 circuits.

Issue - Inadequate understanding of level of control required in the Nuclear Parts Program.

Corrective actions regarding the procurement program are presently ongoing in that improved interorganizational communications and working. relationships

~

have been developed to help streamline operations. Additionally, several recommendations directed toward changing and improving the system have also been initiated. In a ,,

letter to the NRC dated April 1, 1987 (RIMS L44 870401 807), TVA l acknowledges problems in the procurement program with regards to I commercial-grade items and has initiated the Replacement Items Program (RIP) at SQN. The RIP Program describes the methodology for performing engineering evaluations ' and dedications in support of the following:

A. The procurement and dedication of commerical grede material for use in safe cy-related applications.

B. The evaluation of commercial grade items installed in safety-related equipment.

x. C. The assessment of previous item replacements during maintenance activities for seicmic sensitivity.

D. The evaluation of commercial grade itees located in the plant warehouse (Power Stores).

E. The evaluation of balance-of plant (BOP) items, inventoried 5 within Power Stores, for which a specific safety-related application has been defined.

F. The development of preengineered specifications for safety- l related equipment to provide assurance that replacement items are not introduced into critical components / systems that .could degrade their ability to perform the required safety-related function (s).

The pre and post-restart of the replacement items project has been clearly defined in the program plan. To summarize, seismically sensitive equipment within the boundaries of the phase I Design  !

Baseline and Verification Program and 10CFR50.49 equipment will be  !

evaluated before restart.

Issue - NRC misinformed of cable removal.

REPORT NUMBER:

REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

5 TITLE:

General Management and Policy PAGE 14 0F 14 A Corrective Action Tracking Document (CATD) No. 80000-SQN-01 was initiated to provide an expected completion date for testing the PJJ PNJ cable in question. l I

i A response to this CATD was prepared and acknowledged by the Watts Bar ECTG on 11/21/86. Corrective action regarding this issue was determined not to be required in that additional Analysis provides ,

documentation which supports a qualified life of 20 years plus the i required accident and post accident operating time. The SQN EQ 5 Project has documentation to demonstrate environmental qualification j for TVA type PJJ cable installed in 50.49 circuits at SQN. This documentation is contained in Sequoyah Environmental Packages, Revision 1, SQNEQ-CABL-001, -015, -020, and -034. Review of the Sequoyah Electrical Equipment List (SQEL) shows that no PNJ cables (or cables from the same family) has been installed in 50.49 circuits.

The QACEG has evaluated this response and concurs with it's conclusion.

Attachment A, identified the issues as potentially safety-significant or safety related. However, QACEG evaluation concludes that only issue XX 027-X03 was potentially safety-significant. This identifies that unacceptable cable was not properly controlled which resulted in its subsequent use. This issue was determined to have no impact on safety and although some of the remaining issues were substantiated, they were not considered detrimental to the safe or reliable operation of the Sequoyah

~ Nuclear Plant.

6.0 ATTACHMENTS i

A. Employee Concern Program System (ECPS) List of Employee Concern ]

Information j 1

B. Corrective Action Tracking Document (CATD) No. 80000-SQN-01 j s

l 1

I l

L  ;

)9 F EDRtl l i l A S

. F1 tR 1 l l AilAII F Ill :i l lOi t

LE I 1

- V l 0 TfEI I _

l 22 RUDS PAitI _

/ -

I OAD 0Ei l I AlEARD 01 l 01I i l

- OQEE 1 tti l

DRDD0D ) Qo1 l 41 C A D AEP!AR lI."

l 10 - FLRi 1 lLDl l l rA XT I l 0 OI K S1 FYIE S

- SAUA DI RAu CCL FL0iRR l lol 0A l E0RIi 1 A ,0R Rf r -

SI QEI Ell U DI1TEL 8 liI1I l

- EIEI I

SAS il Et1!

0A 1 I A TH K l l0ECfL l

lip t

C R SiL l lDl TI (SSI ARLl EPA Ei t O i PCQI

.A s

- O R .LO F

R Dl5I iGlAGED II l IL l

l AEC LR/

S U C -

ID -

PRE 1T SlIt AIK IEHORI P2O l ll SAl D t

m E -

RE XER DI I l l RR) Fd TEQ _

ACsD l 11 - El A l l

Si l

Gll l 0- I V .

I AlD 0 o0 A EECi l l

l I .

YEl t.llfRA AoU 1 - . .HIL i I FiA l 1Il1G Rill R l l i

PRR lDS E T - 1YOTO E T / Ci ll , OA l TCAR C E l TKAuUl P-Cl DK I l i

P R O

cell l Ili FlSCl I IIYl FIl I - I Et A I Dl U .Al !l U LLOK R- LFIll K S iTL C- GIOD0 i AI l

S Al Cl 4C IiETEf l L

A "Q! C A U0QS1 U 0S 1 I S- l D i C l

T E8A VlV l GP R"L S E- liALl ll l l l l REID I) E Li Q1EL Tll19B E Ali SI d D- DCE iQI l

Ef I l DUl l l lllEl l

l RIVSo ES l

i EuIE RS A .U -

b -

E l

PPCoIQt l l OETIYQ li_ ALEIl I l

i l

l . UIECOEu Gi l FEAEIE m

R GPL l Vl l

.l SUREV a

Oi -

l l A RAA II l LGTR Y DlR b E _-

C-EP RAEAR E S C1 R8D9 R

YEU QRSA S

,K All A DOY l AI IE CIDP RLT iRU CD0EE l

- I 9E1 B .lC iDE l

0- D1l GG

! I E l R ISEL APIlil 1V0 E1lAA l .

RUUD Gll E2 OI lAS DVEK E

I C_

SRFRFl SfOPl T I

I E ll ll08!

ill!

l EISS0ll TIUA5( l T

CRllll Ul l l EEARl R UEE l

EC o ISI TIEE SCA l

0 EOi0I EQCDD1 1 R0GSC XE RE LFl lI l iI LIE 0 l

EECSD UFEAIl Il 1

l Y _ DE i . -

R _ P1lI l

EK AD E1GGE E 0IA l l l

AlOCI lAR0FS1 AI I -

O _ X iR EIE l 1lSL I QEfll l D0A ' .DCCi UR LiO OEA -

G _ EFDA . i HSl I EDliIDTR 1 l

i lie ADPiCLG 0lP3 l l SI DII0 EY _

iTlC 0 ERF P S0I 11GCllAlFAO EI l

TC _ S A iE FEBC lAllUSf IR ICOEE0RI l

AI _ il IR ll glr ll ll l

YAIlf l li l DT l1 S R0SA . ll ll A S ii l

Ol l Ul loUAI EE l

)CL SDO E1REl l

! TR t IILlI Ll  ! S l.SDl UI ,C SRREDV IAU QRS(R l RlC1 1 PUP C1ELA l Al IAl l i T0lIR l E

f EAU l l

l ADCQ IC1EECL EPl CS - loUllOI l UI 1 11 VoT TRSII I 0 CE .KEDA SEE l

I ARLPDYI E/D l

- CIUl l

D T1 -

(Yl Y l RA -

T lO l

- i' IREGi l iRl - l REIEl P S C C C

DlSTE ll0YAl l

l Ei_

CG_

C E

R S

C T T Q

I Q

T Q

IPSCl I D

l l Q G _

1 0

1RlYA l l

lloR_

CO .

- ~nADl R A _ 7 RGGllll tOu L i

Q 0

X ,

l lQ uRlL AI _ S - S AlPlA l CR. - 7 4

V Fil L l AR IO_

RP_

5 1

2 0 *  : t 1

_ EOl lltl l l

OE_ - 2: -

8

/

E EOE TR_ - 5 -

SECFG S 5i 8 5 SClli l I

I

,'. 8 - 8 , -

EIoI - I _

• i T* X I

!!FC l 0 _ I X

!F l 0 _

E0ER0 0 A I EE0 AA, Aa AA S 0 YC8

'l O!l LD _ ilAA ll!

AA R lI AAI lll lff ll l lIl ll li lfYS 0 0

Lo: PES IB_ tfl l

ll!YS lII tt PIS I

S S S AA 8 E PCY R S l

ll l

l R AAAQ_

LLS_ YSC S

YSAlfI lAA lI YSE YSD YSC YSAllIIII Y EEO AA AA S R Cl EG TEC AA O A YE RR L- 1II AA 1 AA R IIf lYS 1IAA I

!lfl l 1 !

1!II llfIYS lI G -

T OI O DB_ 1' I 1 1II AA S E T LA PFll AA AA AA A PC I ll EAIF RSFD_

_ lAAI IlfI 1AA 1I IYS I I

R

!!Ii Il 1l l 1ff 11lII f l!IYS l! I T A

l-123123. 123123 C EU 123123 123 123123 D S 123 123123 -

U S

l l l

1 l ll l l 1 1 1 l 1 l Q Q Q A TC_ l 1B l

y 9 lQ Q S S Q LO-  ; 0 1D 1 1 S 5 S S S -

PL - B 1 1 1 1 Y

S S S S S1RU_

1 S S S S 1

1 S 5 R w C O 1

0 0 0 0 5 G 2

_ 3 0 0 1 0 0 0 0 0 0 E -

1 0 0 0 0 T 5 DI _ 1 0 0 0 4 0 0 6 S l UA_ 7 0 0 6 ' 0 4 0 0 0 0 A P 0 0 0 0 0 8 C lA SC- 0 0 8 6 8 8 C 3 8 8 8 8 6 E R -

R

- G A A O J O A A A l

A l

l .A Q F _

R T _ P A l Q I Q h _

0I 0 Q Q Q Q I 2S 1E P

A_

C

/ /

/ /

s i

SU C Q

[ /

2 1 2 1 2 i

R a .

At _ 1 2 1 2 1 1 0 0 0 0 E _

ri / 0 0 0 0 0 C ll A R_ 0 0 7 6 5 l x E - 1 3 0 0 l E Q D - 3 0 O 0 0 0 o ._

- - l

- 0 0 X X - - C _

- lf - -

A l - - -

7 3 6 .

5 6 7 11 6 .

5 Q li -

26 28 31 EY5 - 8 6 05 07 08 1/ _

f . - 0 2 .

CC5  : .

- 0 - 0 1 l ll 1 Y iR- C 6

50 50 50 50 85 lEl R E- S 85 85 85 RU- O E 8

- 1 - 1 - 1 1 l Q G lC_

l l 1

X fLP E U- li 1 X X X. (

II I r 1 1

m .o o s...., u o..-~.m T2o

. cun no axres am cus~L,~,... ,,

870204 998 .

1 i

" {cmO7cn dum TENNESSEE VAREY AUTHOmTY 1

l TO  : James L. McAnally, Corrective Action Program Manager, A108 I0B, Watts Bar Nuclear Plant ONP FROM  : U. R. Brown Jr., Program Manager, Employee Concerns Task Group, Watts Bar Nuclear Plant ONP FEB 0 4.1987 )

I

SUBJECT:

SEQUOYAH NUCLEAR PLANT - EMPLOYEE CONCERN TASK GROUP (ECTG) ELEMENT REPORT 80000-SQN - QUALITY ASSURANCE CATEGORY - CORRECTjVE ACTION f PLANS (CAP) '

Attached are copies of ECSP Co: rective Action Track.ing Document (CATO) No. 80000-SQN-01 and Corrective Action Plan responses concerning the subject e3ement repo

• The Quality Assurance Category Group ::ead concurs with your corrective action plans and has incorporated them into Element "'

Report 80000-SQN.

I7 CI*2...!. a.~h '

/Hbf r i /

! W. E. Brown, Jr.

f l .: ' ,

b .(,cc . /7r-4W gg3.gg; -- . . . . .

- Attachment **

cc (Attachment):

~

s '~ '

~ RIMS, NE AN 721-C" .

P.. L.1.ber crombie, Sequoys.h ONP '

l E. C. Denney, DSC-P, Sequoyah ONP -

i o r v . ,. m ei 3 e- n-- getu ge .

{

i t

3528T __ , , .

1

=Y

• d' ,

r.

f* ,,

f* g.

C h1 W

ds

L encarn 3 Page 2 or 5  % k

=.

hrd "2 - %W - -

c i

c n g - v== rrim om.non mw=h nurr maor.:rr l

$ Memorandum gne a_.se a_nges 570 's 111E. -

. 0 0 2.

r.r. =r, m e-r.

-i

$. m i s. c. o. , 1 7.e co-.ro w.41 rro3ect ]

wma >- 1 , n ot  !

F n. v. vu.o., troj ect zazioner, mr. twe-t. s.q ya n.ctor not ,

== * (.-

g% eut : OY 14 G?$ Bo1121R0408 @ m ., ' . .. n m

.4.

E3 SEQ CUR N"C' IM r1.MT (SQE) - DCOTIZ C0f 0Z128 T.dI G20Cr (ICTO)..;?:Q:::.

3. ,bI" ',i[&.

Z1.EXIIT g

7. 3NCI uretTs - trrorT 800.00 sqr - trr:rv Arn cout:T:vs A ::a r:.As (car) '

v'

% ;K;: u:1on 1 ff f.'?p yL% .* p;;-'_ g y

.! .Nh- l

'.$M ',b Evalasticm Laport (800.00 SQN) vtich .

i.5;.^c 1r.i l Attaebed 'ia tbe car f or 20:0 Ilenatt was requested try yoi:r samorandum to me dated Octooer

16. 1984 ( 2:3 461016 extension 7:15 W/.[6

'r. O',V,'y -  !

If yao tunre a=y quaseirna. Please contact E. L Lean, E j ac:). ...

M or L.1. Arp, extension 6539. -f o %_ - - s. .f. --; w. g

!- I

/* [ M

- 3xO;c:;M. i

2. s. v u- c.=- .. .. ~~_,

es:..

p. ~;c

$,,, , u ,

w

.,.m . .

$0 j> f*.a).oc Ac e ,w a (Ac w w a):

p  :

t- - -

WL L e ~< u-s . cetr. cz.re-4 , i.e m .h w . m - .1 u ~ L < L Ammer,ess. W . EbPD-3 W *

=)

f A 2- ~ -

4 L h. W. GW9-3. 9.vuurd (de h L b Elliacs. 92 BBC=4. &mporum IE

\

L L an - . me,, M. h ym

.:. L hal.lteen, M. 86-2. huousyd .

F. L hallana. W . Pe>=2. &mwearen -

g L c= t',114mma, met-f --_.2 I h

5 i ,

M_ii

~- % *. R- 3; Mi '.i R ~ ;Y

--gg

_n

~

j.%,%

-C-4 ,&W f

^ - --=

& -  : = e7 y _

. ~ ?**; -% m

,. .G

. =

'* I- ~-

py a

=

y.g;Tg'ak g

- --%,m g~g-- - ..

__- e:hwW i m^

-. ^~

p ,

e.( _ s _

$ ^~ ~~ . ^*-

- MC_ ~me. ww-=*w -

---_e . _

m

. s J

' )

, '; a )

ATTACFy2N! 3'

/; Paga 1 of 4 1

j ATTACF2'.ENT Q ECSP CORRECTIVE Action Trackine Docu=ent (CATD)

INITIATION  :

1. I==ediate corree:ive Ac. tion Required:

2. S top 'Jork Reco== ended : // Yes /N/ No

3. CATD No. 80000-SON-01

/.~./ Yes /.I/ No 4 1

5. F2SPONSISLE ORGANI:'.ATION:

INITIATION DATE 10/1/86 ,

ON?

6. PROBLEM DES"CRI?* ION: /;/ QR /I/ NQR Failure to write a site NCR and to cuick1v re=ove from

, .-.' ..'. . '. . ' .FJJ and PNJ cables resulted in its subsecuent noncentrolled use.

.' y.

Testine

'in SON-EO-CA3L-034 was rec en t iv conducted to cualifv the cables identified-*

q years. and the cables have a cualified life of 20

• F.ovev e r , additienal testine has been deemed recuired to a

. :r.:5 ,

extend the life of these cables however, this extension is recuired not..

n erior to start up.

. 7.  ??2?A?2D 3Y: NA".E //ATTACFF.ENTS

8. . Wavne M. Akelev te m A.

CONCUFJINCE: DATE: 10/1/86

,@. 9. CEG-E_R. R. Maxon 'KVfVhe - -r" DA~E: / c - /-N

.' N APPROVA.L: ECTO PROGRAM MOR: # #3-4<//. '#,

~

~ DATE: _3/07/?v

' COPJ2CTIVE ACTION- / / -

. .3,43.

."w- .

.10.'T. PROPOSID CO?J2C7:., ACTION PLAN: ~~.

__ ... x.:>. .. ........., .. .. ..:.- .  !

~

%f .. _..... .

g lb' .,=.~. .,-

' :. 00

$t'Y (k ? $4W. iU $N/ W&.) SnY $ & W $d/d Uffl E '7 0 TG /// V 00%

. ~ .

,, - ,8P*,

, 3.-

_f..

. ,. v

11. / / ATTAC F2'lNTS

12. PROPOSED 3Y: DIF20!OR/MGR: g'd /fm / f CONCUEJ2NCE: CEG-E O V.8v_- f A MM r DCE: #4 0 -/ '.

a SRP:

' DATE: 'Z. /4 / V) v '

DATE:

ECTO PROGRAM MOR:

DATE:

~

VER. ICATION_ AND CLOSIOUT .

.13 .

7 Approved implemented.

corrective ac tions have been verified as t s a tis f ac torily .

f l

5 IGH A':"J72

. u :. DA!E l

i

e ,- . - -

ATTACIOiET! B ( Page 3 of 4 A

, 1

,,,.- STANDARD FRACTICE Page 8 SQA166 Rev. 8 i

A::ach=ent A J Page 1 of 2 Correc{:ive Action Plan of E=ployee Concern Investigation Tracking Checklis:

ECTG Repor /CATD Nu=ber 800.00 - SON /CATD 480000 - SON '01 Lead Organication Responsible f or Corrective Action ENG Ini:iation Date 10-16-86 COR.RECTIVE ACTION FLAN (CAP)

1. Does this report require corrective action? Yes No _ _I__

(If yes, describe corrective ac: ion to be ta ke n , if no, provide j us ti_,ica:L on)

The SON EO eroieet has documentation to demonstrate environmental cuall' _eatien f or TVA-tvoe PJJ cable int alled in 50.49 circuits at \

SON. This docu=entation is contained in Secuevah Invirennental Pack-sees SONEC-CAEL-001, -015, -020, and -034 Review of the Secuevah l

. . ... . Electrical Ecuiteent Liet ( SOEL) shows that no PNJ cables ( or cables f ree the s ame c ab l e f a=ilv) has been installed in 50.49 eircuits.

.F. M.2 .

g:-

. . . - . . . . /

2. Identify any si=ilar ite:/ instances and correc:ive action taken. . --

1

,,s . . .c.w

.g:.

Refer to W. L. Elliott's re=e to C. T.  ?!all dated Februa-v 11. 1986

( 370 860211 001). This re=orandur identified all cables in the eu--

rent cable vard invente-v that vere considered bv E0? as not suitable-for installatice in new 50.4 9 circuits. In addition. the remerandue reeer= ended that c ab l e in this cateco v be "crecer1v disnesitioned and i reved te a non-nuclear site." The vard'inventerv at that time showed l that ne troe ?JJ er PNJ vas en site. The inventer did shev that tvre i

?N ( same family as PNJ) vas en site. The tvoe PN cable vas inc lud ed {

in the vroue of cable that E0? rec e~: ended te cove of f sit e. l

3. Will correc:ive ac: ion preclude reccurrence cf findings? Yes I No

4. Does this repor: contain findings that are eceditions adverse to cuality

( CAQ) as defined bv AI-12 or NE? 9.l?

. Yes No I . i

5. 17 a CAQ condicion exists, what CAQ documen: vas initiated? '

6. *rnich site section/organication is responsible f or cc :ective action?

7. Is corrective action w,uired f or restart? Yes _ . _ No (This de:er=ination is to be =ade using Attacb=en: C of SyA166.)

8. F2 cone nu=ber f or restart corree:ive action? Zone

9. Esci= ate co=pletion date f or cc rectiv- action.

19h Completed By d -4 ,

Date _// /// //4'

"~

}'WWW Appr oved By Date // /N/K-ECTO Concurrence WW lc 4A. /K/M Date 2. M ll~7 i y A C2 6318.01