ML20215C394
| ML20215C394 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/21/1986 |
| From: | Grimes R, Howard J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215C295 | List: |
| References | |
| MC-40709-SQN, MC-40709-SQN-R01, MC-40709-SQN-R1, NUDOCS 8612150120 | |
| Download: ML20215C394 (10) | |
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9, TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40709-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER:
1 TITLE: Material Personnel - Search for PAGE 1 0F 8 lR1 Defective Material l
REASON FOR REVISION:
To incorporate Technical Assistance Staff and Senior Review Panel Comments.
Revision 1 PREPARATION PREPARED BY:
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../A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files, 2154T
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I TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40709-SQN j
SPECIAL PROGRAN REVISION NUMBER: 1 PAGE 2 0F 8 I.
INTRODUCTION This evaluation was performed as a result of a Sequoyah Nuclear Plant (SQN) specific concern No. XX-85-027-X04 and addresses the conclusion:
.. a need to re-evaluate the material control and accounting program relative to Ray Hiller, Inc.,
material at the Sequoyah Nuclear facility."
as stated in the Employee Response Team (ERT) Interim Report No. XX-85-027-X04.
lR1 II.
SUMMARY
OF PERCEIVED PROBLEM The perceived problem is that materials personnel at SQN were not given l
an opportunity to verify whether or.not defective material had been l
received on site from a certain manufacturer and a report to Knoxville IR1 that the material was not on site was made without input from materials l
personnel.
l III.
EVALUATION METHODOLOGY A.
Reviewed Employee Concerns Task Group (ECTG) working files, expurgated files, and Nuclear Safety Review Staff (NSRS) unexpurgated flies to obtain additional information.
B.
Reviewed ERT Interim Report No. XX-85-027-X04 to determine if it adequately addresses the perceived problem.
C.
Reviewed the Nuclear Regulatory Commission (NRC) Office of l
Inspection and Enforcement Bulletin (IEB) 83-07, "APPARENTLY l
FRAUDULENT PRODUCTS SOLD BY RAY MILLER, INC.", to determine the lR1 reporting requirements relative to Ray Miller, Inc., material.
l D.
Conducted interviews with NRC personnel to gain a clearer lR1 perspective of the scope and reporting requirements of IEB 83-07.
l E.
Reviewed Watts Bar Nuclear Plant (WBN) ECTG Element Report lR1 No. MC-40709, " Material Personnel", for application to SQN.
l F.
Conducted interviews with personnel in various Tennessee Valley l
Authority (TVA) nuclear power organizations to determine if l
materials personnel were given an opportunity to verify whether or lR1 not defective material was on site and if a report was made to l
Knoxville that material was not on site.
l m
r
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40709-SQN SPECIAL PROGRAN REVISION NUMBER: 1 PAGE 3 0F 8 G.
Reviewed documentation associated with the TVA response to IEB 83-07 to determine whether or not a report was made to Knoxville that no Ray Miller, Inc., material was on site.
H.
Reviewed documentation associated with the TVA response to IEB 83-07 to determine whether or not the TVA response to IEB 83-07 was adequate.
IV.
SUMMARY
OF FINDINGS A.
A review of the ECTG working files, expurgated files, and NSRS unexpurgated flies revealed no additional information.
B.
A review of ERT Interim Report No. XX-85-027-X04 revealed that the concern grew out of the TVA investigation into whether or not any material from a-certain vendor (Ray Miller, Inc.), identified by lR1 IEB 83-07, had been received at SQN.
l The ERT report does not adequately address the perceived problem that material personnel were not allowed to determine whether or not receipt of Ray Miller, Inc., material and the subsequent reporting to Knoxville of no such material being on site, occurred at SQN.
The ERT report states, "A complete investigation was not conducted and a conclusive statement relative to substantiation cannot be provided.
However, based upon the information presented in several Nonconforming Item (NCI) reports and the TVA response to IEB 83-07, it concluded;
. a need to re-evaluate the material control and accounting program relative to Ray Miller, Inc.,
material at the Sequoyah Nuclear facility."
lR1 This conclusion is valid; however, part of the basis for the ERT conclusion is in error, in that the referenced NCIs, are for l
Ray Miller, Inc., material purchased on contracts that are outside l
the required time frame (1975 through 1979). This ECTG evaluation lR1 also revealed the TVA response to IEB 83-07 to be in error, see l
Section IV.H of this ECTG report for details. The NCIs referenced l
by the ERT report are as follows:
l l
i
- - _. -.,. - - - - ~,
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_ _. -. -, _,,.,,. _..._- -.-- _,.. ~ _. _ -. _ _ _ _ _. -.. _. - ~ _ _. _ _. _
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i.
L TVA EMPLOYEE CONCERNS REPORT NUMBER: MC,40709-SQN SPECIAL PROGRAM
' 1, REVISION NUMBER: 1 s
1 PAGE 4 0F 8 NCI NO.
CONTRACT NO.
CONTRACT,DATE lR1 N2-80-1210 80PK2 - 304432 07/23/80 N2-81-1251 80PK7 - 307141 09/39/80 N2-81-1252 80PK7 - 307141 09/19/80 N2-83-1887 80PK2 1304432 07/23/80 N2-83-1888 80PK2 - 289063 07/22/80 N2-83-1889 80PK/'- 307141 09/19/80 N2-83-1890 80PK6 - 323787 09/28/81 N2-83-1897 82PK6 - 323787 f9/28/01 N2-83-1901 80PX7 - 307141 09/19/80 N2-83-1902
-80PK2 ' 289063
'07/22/80 C.
AreviewofIEB83-07,"APPARENTLYFRAUDULENTPR0hUCTS'SOLDBY l
RAY MILLER, INS.", revealed that TVA must file'a repcet on the i
receipt and disposition of all Ray Miller, Inc., material received l
during the timeframe 1975 through 1979. This report must contain l
a l
information about Ray Miller, Inc., material whether identified lR1 through an apparently fraudulent data file:aupplied with the i
bulletin, or identified by TVA's own initiative. The report raust l
contain the identification of all Ray Miller, Inc., material 1
installed in safety-related systems along with its I
safety-significance evaluation and the disposition of all Ray l
Miller, Inc., material that remained in stock.
l D.
Interviews were conducted with NRC personnel to gain a clearer l
perspective concerning.the scope and reporting requirements of
[R1 IEB 83-07.
These interviews revealed the following:'
l 1.
The timeframe of interest is January 1975 through lR1 December 1979.
l 2.
Reporting is required for any item installed in a safety-related lR1 system along with its safety-significance evaluation.
l 3.
Reporting the disposition of any material that remained in stock lR1 is required.
l 4.
Any reporting of material received outside the timeframe IR1 requires complete reportability of material on that contract.
l E.
A review of WBN, ECTG Element Report No. MC-40709 " Material l
Personnel", revealed that the investigation for Ray Miller, Inc.,
I material for WBN was performed by the Nuclear Engineering Support IR1 Branch (NEB), Knoxville, in preparation for the formal response to l
This report further revealed that NRC had closed i
l
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40709-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 8 The report concluded.
lR1 "Through interviews and research no evidence l
was found to indicate WBN had received material lR1 from Ray Miller, Inc., or that any employee was l
impeded in the search for this material."
l The conclusion is not concurred with because evidence was found
{
during the SQN evaluation indicating WBN had received Ray Miller, IR1 Inc., material, see Section IV.H.2 of this ECTG report for details.
l F.
Interviews conducted with TVA personnel involved in the search for l
Ray Miller, Inc., material at TVA Nuclear Plant Sites, including l
SQN, did not reveal any instances of material personnel not being l
given an opportunity to verify whether or not defective material had I been received on site from Ray Miller, Inc. However, interviewees l
indicated that possibly a report of no material being on site was IR1 made to Knoxville.
Interviewees further revealed that documents I
(both formal and informal) describing the search and reporting l
process for Ray Miller, Inc., material were stored in the Quality l
Services Branch (QSB) Library, in Chattanooga. A review of this l
documentation is contained in Sections IV.G and IV.H of this ECTG l
report.
l G.
A review of the documentation associated with TVA's response to IEB 83-07 revealed the following:
1.
A memorandum from the Manager, Nuclear Licensing, to the l
Director of Nuclear Power and the Chief, Nuclear Engineering i
Support Branch (A27 830819 003), dated August 19, 1983, I
designated the responsibilities for preparation of the TVA l
response, for certain plants, to the specific actions required lR1 of them by IEB 83-07.
The Division of Nuclear Power (DNP) was l
designated to be the lead organization in developing the l
SQN-related response to the bulletin. NEB was designated to be l the lead organization for the WBN and Bellefonte Nuclear Plant l
(BLN) response.
l 2.
A response to IEB 83-07 for all TVA nuclear plants was outlined in a memorandum from the Chief. Nuclear Engineering Support l
Branch, to the Manager of Nuclear Licensing (A27 840228 006),
l dated February 24, 1984. This memorandum identified only one l
instance of Ray Miller, Inc., material used in a safety-related lR1 system, at BLN, and none for other TVA nuclear plants, including l SQN. This response was written for all TVA nuclear plants even l
though DNP was to respond for SQN.
I
,I TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40709-SQN
.SPECIAL PROGRAM i
REVISION NUMBER: 1 PAGE 6 0F 8 i
3.
The'SQN-related response to IEB 83-07 was outlined in a memorandum from the Director of Nuclear Power, to the Manager, lR1 Nuclear Licensing (L16 840224 884), dated March 2, 1984. This' memorandum identified five instances of Ray Miller, Inc.,
matorial-installed in safety-related systems, at SQN. Two were.
In Critical Systems, Structures and Components (CSSC) applications and three were in non-CSSC applications.
4.
A response, superseding memorandum No. A27 840228 006, to IEB 83-07 for all TVA nuclear plants was outlined in a memorandum from the Chief, Nuclear Engineering Support Branch, lR1 to the Manager of Nuclear Licensing (A27 840321 011), dated l
March 20, 1984. This memorandum identified four instances of Ray Miller, Inc., material installed in safety-related systems at TVA nuclear plants. Two of these items were for SQN and the others were for BLN and Yellow Creek Nuclear Plant (YCN).
Again, this memorandum was written for all TVA nuclear plants even though DNP was to respond for SQN and did, as indicated in paragraph three above.
5.
TVA's official response to IEB 83-07 for SQN and other TVA nuclear plant sites, is outlined in a letter from the Manager, l
Nuclear Licensing, to the Regional Administrator, Region II, l
United States (U.S.) NRC (A27 840322 014), dated March 22, 1984. l This letter contains only the items identified by the NEB lR1 mamorandum (A27 840321 011) and does not include items l
identified in the DNP memorandum (L16 B40224 884) discussed in l
paragraph three above.
l t
In summary, although no evidence was found that a report was made to Knoxville, it is believed that this portion of the concern stems from a memorandum (A27 840228 006) issued by NEB, from Knoxville, indicating that no Ray Miller, Inc.,r.caterial was supplied to or installed in any safety-related system, at SQN. This memorandum was superseded by a memorandum (A27 840321 Oll). identifying only two instances of Ray Miller, Inc., material having been installed in safety-related systems, at SQN. These merorandums are contrary to a DNP memorandum (L16 840224 884) identifying five instances of Ray Miller, Inc., material having been installed in safety-related systems, at SQN. Although DNP was responsible for the SQN related response (A27 830819 003), the NEB response memorandum (A27 840321 011) became the basis for TVA's response to IEB 83-07.
This has resulted in identified Ray Miller, Inc., material installed in safety-related systems, at SQN, that has not been reported to NRC.
(-
IVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40709-SQN SPECIAL PROGRAM i
REVISION NUMBER: 1 PAGE 7 0F 8 H.
A review of TVA's response (A27 840322 014) to IED 83-07, dated March 22, 1984, and associated documentation revealed the following:
1.
The two items identified in TVA's response (A27 840322 014) l to IEB 83-07 for SQN are Ray Miller Inc., material l
purchased and received on contracts that are outside the lR1 1975 through 1979 timeframe (i.e., 80PK2 - 289063 and l
80PK7 - 307141).
l 2.
The following contracts for Ray Miller, Inc., material purchased and received, both directly and indirectly, during the 1975 through 1979 timeframe were not dispositioned or addressed in IVA's response (A27 840322 014) to IEB 83-07.
SQN 78K80 - 772426 SQN 78K82 - 779675 - 1 SQN 79K82 - 782908 SQN 79K88 - 780547 SQN 79P87 - 272960 - 02 WBN 78K87 - 556304 WBN 78P82 - 235168 WBN 79P82 - 269979 3.
A TVA memorandum from the Head, Procurement Program Group to l the Quality Engineering Branch (0QA 840210 703), dated l
February 10, 1984, contained a list, of secondary companies l
identified as having potentially supplied material from Ray lR1 Miller Inc., resulting from an evaluation of IEB 83-07, l
Supplement 1.
The results of this evaluation, including the l response from Goulds Pumps, Inc., (L16 840323 194) were l
omitted from TVA's response (A27 840322 014) to IEB 83-07.
l 4.
TVA's evaluation of SQN contract No. 79P88-1613 (identified l
in IEB 83-07, Attachment 1, page 259 of 277) is omitted from l TVA's response (A27 840322 014) to IEB 83-07.
SQN is lR1 identified as both the " buyer" and " delivery point" for this l contract with the " order date", 03/02/79.
l CONCLUSION:
This evaluation revealed the search for Ray Miller, Inc., material at SQN included site " Material Personnel". No evidence or indication was lR1 found, that:
l
. materials personnel were not given an opportunity to verify whether or not defective material had been received on site, from a certain manufacturer (Ray Miller, Incorporated)
- r:
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40709-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 8 Therefore, this portion of the perceived problem is not valid.
lR1 Even though no report was found, the remaining portion of the lR1 perceived problem:
l
. a report to Knoxville that the material was not on site was made without input from materials personnel."
is believed to be valid. This conclusion is based upon interviews l
with TVA personnel (see Section IV.F) and memorandum (A27 840228 006) l issued by NEB, from Knoxville, indicating that no Ray Miller, Inc.,
IRI material was supplied to or installed in any safety-related system, at l
SQN, (see Section IV.G).
l While the material on contract No. 80PK2-289063 and 80PK7-307141 was not subject to the reporting requirements of IEB 83-07, the fact that TVA has reported the status of a portion of this material requires that the status of all material on these contracts be reported to NRC.
Due to this deficiency and the fact that the status of material on several contracts, falling within the timeframe 1975 through 1979, was not reported, it is concluded that a re-evaluation of the identification and subsequent reporting of Ray Miller, Inc., be made [ reference SQN l
specific Corrective Action Tracking Document (CATD) No. 40709-SQN-01 and lR1 corporate CATD No. 40709-NPS-01).
I V.
ROOT CAUSE There was no clear understanding on the part of Nuclear Licensing, NEB, l
and DNP of TVA's reporting responsibilities for the SQN response to lR1 IEB 83-07.
I VI.
CORRECTIVE ACTION To be provided by line organizations.
IR1 Reference CATD Nos. 40709-SQN-01 and 40709-NPS-01 lR1 VII.
GENERIC APPLICABILITY Determined generic to Browns Ferry Nuclear Plant (BFN), BLN, SQN and WBN due to the fact that TVA's response to IEB 83-07 is in error and must be re-evaluated. This re-evaluation must include Hartsville Nuclear Plants (HTN), Phipps Bend Nuclear Plant (PBN), and YCN because these canceled nuclear plants are potential material suppliers to the other TVA sites.
VIII.
ATTACHMENTS Attachment A - Concerns Printout (Identifies relationship to Nuclear Safety and Generic Applicability)
PAGE 4
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XX 027-XO4 MC 407 SQN NNNY (ERT)
SS MATERIALS PERSONNEL NOT GIVEN AN OPP T50056 REPORT Interim Report ORTUNITY TO VERIFY WHETHER OR NOT DE g
FECTIVE MATERIAL HAD BEEN RECEIVED 0 n
No. II-85-027-IO4.
N SITE FROM A CERTAIN MANUFACTURER.
(NAME KNOWN) A REPORT TO KNOXVILLE THAT THE MATERIAL WAS NOT ON SITE WA S MADE WITHOUT INPUT FROM MATERIALS PERSONNEL. NO FURTHER INFORMATIONIS
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CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY HUMBER.
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ENCLOSURE 2