ML20216B767
| ML20216B767 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/17/1987 |
| From: | Barlow D, Deangelis J, Russell Gibbs TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20216B630 | List: |
| References | |
| 80504-SQN, 80504-SQN-R06, 80504-SQN-R6, NUDOCS 8706300149 | |
| Download: ML20216B767 (54) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER 2 SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
~ REPORT TYPE 6
Element Report PAGE 1 0F 28 TITLE:
Quality Assurance. Records REASON FOR REVISION:
Revised to incorporate NRC couunents.
4 Revision indicators are shown in the right margin
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on each page.
Note:
Sequoyah Applicability Only
)
PREPARATION
' PREPARED BY:
D. G Bar ow/J. J. DeAngelis--
/w ML 6-M-87 SIGNAT
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A DATE REVIEWS PEER:
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SIGNATURE'
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DATE /
TAS:
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SIGNATURE
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/ DATE CONCURRENCES j
'J ShW8f CEG-N :
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4 SIGNATURE-DATE
/IGNATURE*[
DATE j
3 APPROVED ih4t/\\
N/A
" ~ ECSF ' MANAGER}
DATE I
MANAGER OF NUCLEAR DATE-l
' POWER. '
CONCURRENCE (TINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in' files.
8706300149 870622 PDR..ADOCK 05000327:.-
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I TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 6
Element Report PAGE 2 0F 28 TITLE:
-Quality Assurance Records 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction The issues described below were taken from employee concerns generated as a result of the Watts Bar Employee Concern Special Program.
The issues were investigated and evaluated at the Sequoyah Nuclear Plant (SQN) since they were deemed to be. site specific or to have generic applicability to SQN.
1.2 Description of Issues The conditions reported (Attachment A) by concerned employees are:
a.
Controlled documents contain conflicting or obsolete data or both.
(SQM-86-002-005, SQM-86-002-006, SQM-86-003-002) b.
Work which had been performed.had not been appropriately documented.
(SQM-86-011-002) c.
Poor material control.
Traceability of requirements and materials is inadequate and paperwork for quality records is poor.
(XX-85-122-042) d.
The retrieval of Quality Assurance (QA) records is inadequate and records t..
act identifiable.
(IN-85-357-001, SQM-86-002-001, SQP-8f.-002-001, anc WBP-86-009-001) e.
Welde.r Certification records were altered. -
(IN-85-612-X07, XX-85-088-IO4)
NOTE: Falsification of Welders' Qualification Records will be addressed seperately - by the TVA Office of the ' Inspector
- General, f.
Maintenance Requests (MRs) which specified the addition of grease for Limitorque. valve actuators were signed off 'as being unnecessary _or as ~being~ complete' even' though no -work ~ was i
~"
-=
I
-performed.
Non-QA materia'l was - installed in QA applications and :
traceability was f alsified on the MR.
(JLH-86-001) g.
Quality. Assurance (QA) documents were, lost by the' vault personnel and regenerated by the responsible unit.
(IN-85-091-001).
i h.
Inspection records may reflect improper' data.
( SQM-86-009-X04)
REPORT NUMBER:
TVA EMPLOYEE CONCERNS 80504-SQN SPECIAL PROGRAM REVISION NUMBER:
6 REPORT TYPE PAGE 3 0F 28 Element Report f
TITLE:
Quality Assurance Records 2.0
SUMMARY
Summary of Characterization of Issues _'
l 2.1 These issues were grouped into the element of Quality Assurance
)
been lost, l
Records since they indicated that quality documents have regenerated, altered and contained conflicting or obsolete data or both.
The issues also indicated that_ the QA records are not identifiable or retrievable.
2.2 Summary of Evaluation Process _
t l
The evaluation process' consisted of a search of the available concerns and industry standards.
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files and reviews of regulatory requirements TVA upper tier requirement Nuclear Quality ' Assurance-Manual l
- Likewise, reviews were made of. the i
j documents such as the Topical Report, and Final Safety Analysis Report together with lower tier implement ng as procedures and instructions to determine
{
Reviews of associated documents suchcommitments and responsibilities.
and field verification along with discussions with requirements, of the investigation documentation cognizant personnel were also performed as part of the issues.
of the documents utilized in the investigation-and listing _
is included as Attachment
]
Aevaluation process.for this Element Report J
j
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B.
2.3 Summary of Findings l
i Issue - Controlled documents contain conflicting or obsolete 1
l 2.3.1 data or both.
The Employee Concern file provided clarification of' this issue 1
which directed this investigation into the. area-of vendor 3
design drawings (mylars) and the system for requesting i
This replacement appears to duplicates of original drawings.those -vendor drawings ' received to 1976 y
be mainly ~ for of these I drawings were routinely; discardede when site copies i
t Thus, there was the ' need at the site for wash-offs (a wash-off original from the aperture. card in l
replacement
- There is a potential ' for the two " originals" to_
I being a
~~ conflicting' data when one drawing is-Knoxville).
contain obsolete or o ther.
Conflicting data occurs. when a l
updated _ and not' thefor an original drawing. is used ~ as_ the baseline for subsequent changes-and the-missing drawing replacement Controls _are now drawing reappears and is not properly dispositioned.
in place to avoid lost and duplicate drawings.
The Employee Concern file also provided clarification of i
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN j
REVISION NUMBER:
J REPORT TYPE 6
Element Report PAGE 4 0F 28 TITLE:
Quality Assurance Records another concern dealing with this issue which directed this investigation to a specific wiring diagram mylar which was 1
same revision number.
Failure to log-l issued twice with the the first release of Revision 8 also created the potential
{
for two mylars to contain obsolete or conflicting data when l
out one drawing is updated and not the other. This appeared to be
)
was due to the relocation of the SQN l
an isolated case and to the site with new clerical personnel in Engineering Project the Drawing Control Center.
Procedures are adequate and additional training has been provided in the area of drawing control and issue.
f Issue - Work which had been performed had not been 2.3.2 appropriately documented.
(Environmental Qualification of Equipment)
I investigation of the issue dealt with the actual employee The concern which said that Sequoyah was shutdown in August 1985 due to a failure of a group to appropriately document work which had been performed.
This investigation determined ' the concern was valid as Sequoyah was shutdown in August 1985 due l
to questions about the environmental qualification of electrical equipment.
The SQN Nuclear Performance Plan specifies the corrective actions to be taken by SQN for Environmental Qualifications.
Issue - Poor material control. Traceability of requirements 2.3.3 and materials is inadequate, and paperwork for quality records is poor.
The investigation of the issue of poor material traceability /
control, inadequacy of requirements, and inadequate quality records provided evidence that the major problem in material control was inadequate instructions or failure to follow procedures and instructions.
Examples of improper traceability of quality requirements for materials received were also found along with examples where traceability of paperwork to actual hardware could not be established.
The Material Control CEG has performed extensive investigations in the hardware areas of material control and has reported their findings separately, Issue - The retrieval of QA records is inadequate and records 2.3.4 j
are not identifiable.
The investigation of an inadequate QA records retrievable SQN was reviewed for Construction and Operation QA l
i system at Record retrievability was found to be inadequate for l
records.
f
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 6
Element Report PAGE 5 0F 28 TITLE:
Quality Assurance Records contruction records since the document retrieval system is not fully operational.
However, the retrieval of operational QA records (those needed for the operations phase) was found to be adequate.
Issue - Welder certification records were altered.
2.3.5 The investigation of the issue of welder certifications being altered provided evidence of various -types of documentation errors.
There was evidence of Corrective Action Requests (CARS), Deficiency Reports (DRs), and Survey Checklists also having been written which deal with altering welder records.
2.3.6 Issue - Maintenance Requests (MRs) which specified the addition.of grease for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed.
Non-QA material was installed in QA applications and traceability was falsified on MR.
The investigation of the issue produced evidence that all SQN i
Unit 2 Limitorque valve actuators have been inspected and that the actuators have been properly greased in accordance with the maintenance procedure.
2.3.7 Issue - Quality Assurance (QA) documents were lost by the vault personnel and regenerated by-the responsible unit.
The investigation into the issue of quality documentation being lost by the vault personnel and later regenerated by the e
j responsible unit found no evidence of this condition having j
been documented at SQN.
?'~
b When lost documents were identified at SQN, QA personnel did not document the condition.
In such cases, the records storage vault personnel identified the documents to the responsible unit and a duplicate copy was furnished for storage.
i 2.3.8 Issue - Inspection records may reflect improper data.
The issue that inspection records may contain conflicting ~ data f
was not addressed within the scope of the Quality Assurance.
Category Evaluation - Group (QACEG) evaluation.
The concerned-i individual (CI) was not specific to the ' type of data or inspection records that ' may contain conflicting data.
Additionally, the Employee Concern and Confidential Files contained-no information that identified the specific inspection records or data that would specify the subject of
'1 the employee concern.
Also, Nuclear Safety Review Staff
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.e TVA EMPLOYEE CONCERNS REPORT NUMBER:
' - 'i SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 6
Element Report PAGE 6 0F 28 TITLE:
Quality Assurance Records (NSRS)
Investigation Report.I-86-241-SQN was assigned..to 3
Employee Concern SQM-86-009-X04.
However, a NSRS Report was never issued..
.}
2.4 Summary of Corrective Actions Issue - Controlled documents contain conflicting, or obsolete.
2.4.1 data or both.
Corrective actions taken to date include:
I Procedural guidance in Sequoyah Engineering Project (SEQP) a.
Project Manual dated September 1985 provides tighter control over design' activities.
LTraining of newly i
arriving clerical personnel has been given in procedural requirements for -drawing control and. supervision has been increased for the drawing issue process..
b.
Wiring Diagram 45N1749-30 has been revised to reflect the the correct data and the drawing log corrected to reflect L
proper revision.
A Drawing Issue Checklist has also been added to Procedure SQEP-AI-08.
i 2.4.2 Issue - Work which had been.parformed had not been appropriately documented.
(Equipment Qualification Program)
The Equipment Qualification (EQ) Project was formed with' the an EQ responsibility for development and ' implementation of Program.
Work is ongoing by the project to resolve the equipment qualification problems.
SQN has committed to demonstrate qualification prior to restart of the. plant.
2.4.3 Issue - Poor material control.. Traceability of. requirements 3
and materials is inadequate and paperwork; for quality records is poor.
Corrective actions taken to date include:
- j attention,. andi ersonnel. awareness over ' th'e' entire j
p Management material-control area which appears to be adequate.
2.4.4 Issue - The retrieval of QA records is. inadequate and q
records are not' identifiable.
j
' Corrective actions taken to' date include:
j 3
a.
Established a.
work force to index and' microfilm i
i
}'
drawings and I
. construction - records, vendor documentation,.
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'TVA EMPLOYEE CONCERNS R2 PORT NUMBER 8 -
'2 SPECIAL' PROGRAM 80504-SQN.
o REVISION NUMBER:
REPORT TYPE _
6~
Element Report
.PAGE 7 0F 28 TITLE:
QualityAssurance Records manuals for SQNP Units 1 and 2.
Developing new and revised procedures.and instructions to b.
define organizational. responsibilities and; interface requirements with other departments.
.These procedures will' also include the methods of maintaining, storing, and contr'olling vendor QA records.
The above activities 'are. currently ongoing? 'and the adhedule for completion of these activities is December 1988.
2.4.5 Issue - Welder certification records were altered.
Corrective actions taken:to date include:
Corrective Action Report - (CAR)~ CAR-SQN 85-09-014-was written -
to.be and dispositioned as' -
"all SQN ~ active... welders'- files reviewed' and welders re-qualified. to ; current ' requirements."
This CAR has been closed and-all corrective actions have been verified as being complete.-
2.4.6 Issue - Maintenance Requests (MRs) which specified. the addition of grease for Limitorque valve actuators.were. signed off as unnecessary or. complete.even though. no. work was
. performed.
Non-QA material - was ; inst;alled ~ in.QA applications and traceability wa's falsified on the MRs.
Corrective actions taken to'date include:
All Sequoyah Unit 2 Limitorque ' valve actuators L have been inspected and verified that they have been properly greased.
2.4.7 Issue - Quality Assurance -(QA) documents' were lost by the*
vault and regenerated by the responsible unit.
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No corrective actions required.
3.0 LIST OF EVALUATORS W.-M. Akeley D. G. Barlow.
J. J.'DeAngelis
- J. E. Mann 4-
?!
4.0 EVALUATION PROCESS a
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5 TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN.
REVISION NUMBER:
REPORT TYPE 6
Element Report PAGE 8 0F 28 TITLE:-
Quality Assurance Records 4.1 General Method of Evaluation The evaluation process consisted of researching the Employee Concern
'~
files, Quality Technology Corporation (QTC) files, and Nuclear Safety
. Review Staff (NSRS) files to determine if additional information was available to assist. in the. investigation of issues associated with this element.
Reviews were conducted of regulatory requirements and industry the standards together with upper. tier requirements, documents such as TVA QA Topical Report and the Nuclear Quality ' Assurance Manual, along with lower tier implementing documents such as procedures and instructions to
~ determine requirements, commitments, and-responsibilities.
Documentation in the form of quality audit reports, survey checklists, inspection reports, Field. Change Requests (FCRw),
Significant Condition Reports -(SCRs), Nonconformance Reports (NCRs),
Discrepancy Reports (DRs), Maintenance ' Requests (MRs), work plans, microfilm records of inspections / tests and computer status reports
.were also reviewed.
The above documentation together with personnel discussions provided the basis for the' conclusions reached.
4.2 Epecifics of Evaluation This section describes the specific methodology used relating to the following issues:
4.2.1 Issue - Controlled documents contain conflicting,. or obsolete data or both.
The Employee Concern files were researched to determine if Quality Technology Company (QTC) and/or. the Nuclear. Safety Review Staff (NSRS) had. investigated and reported on the issue.
The following NSES reports were evaluated by the Quality Assurance Category Evaluation Group (QACEG) to determine the adequacy of the ocope and the results of their investigation.
_1 Concerns SQM-86-002-005 and -006.
b.
NSRS Investigation Report-- I-86-180-SQN
.for' Employee Concern SQM-86-003-002.
e-There were no QTC reports available.
The QA Topical Report TVA-TR75-1A Revision 8, and ' the. Nuclear Quality As surance Manual (NQAM) Part III,- were.- reviewed 1
together. with site practices, -procedures,. and policies to determine the' requirements and commitments during - the' time i
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 6
Element Report PAGE 9 0F 28 TITLE:
Quality Assurance Records frame the concerns wet reported.
l A review was made of the Wiring Diagram, Field Change Requests 4
(FCRs), Significant Condition Reports (SCRs), and Engineering Change Notices (ECNs) which document specific data relating to 1
the concerns of record.
Discussions were held with personnel in the Document Control Unit (DCU) to develop the historical background and current events pertaining to the issue.
4.2.2 Issue - Work which had been performed had not been appropriately documented.
'(Environmental Qualification of Equipment)
The Employee Concern files were researched to determine if QTC and/or NSRS had investigated and reported on the issue.
NSRS Investigation Report I-86-270-SQN was assigned to Employee l
Concern SQM-86-Oll-002.
However, a NSRS Report was never issued.
A review was made of Regulatory Requirement NUREG-0588,
" Interim Staff Position on Environmental Qualification of Safety-Related Equipment";. Industry Standard IEEE 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations"; Topical Report TVA-TR75-1A, Final Safety Analysis Report (FSAR) Section 3.11, Code of Pederal Regulations 100FR50.49, January 1,
1985
- Edition,
" Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants"; and. the Nuclear Quality Assurance Manual (NQAM),
Part II, to determine the requirements and commitments during -the time frame the concerns were repor r.ed.
. Environmental Qualification Documentation packages including ' test results were also reviewed to form a basis for the conclusions reached.
Discussions were held with. various site personnel. to develop the historical background and other information pertaining to
~~
the subject issues.
4.2.3 Issue - Poor material control. Traceability of requirements and materials is inadequate and paperwork for quality records is poor.
The Employee Concern files provided NSRS Investigation Report I-85-987-SQR dated 3/4/86. This report was evaluated by QACEG to determine the adequacy of the scope and the results of the NSRS investigation.
1 TVA EMPLOYEE CONCERNS.
REPORT NUMBERS SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 6
Element Report PAGE 10 0F.28 TITLE:
Quality Assurance Records Regulatory _ Guides 1.33, 1.38, and 1.123, the Topical Report TVA-TR75-1A Section 17, the Final Safety Analysis Report
)
(FSAR), the Nuclear Quality Assurance Manual -(NQAM) Parts II-
]
and III were reviewed together with Site Instructions AI-7, AI-11, AI-12, and AI-36, Standard Practice SQA45, seven (7) survey checklists, seven -(7) Audit Reports, and two (2) additional NSRS. Reports to' determine the commitments, requirements and audit results during the time frame the issue was reported.
q
'SQN Element Report MC-40703, Revision 0, ' dated 9/26/86 issued by the TVA Employee Concern Special Program Group was reviewed a'
for additional information relating to the issue.
4.2.4 Issue - The retrieval of QA records is inadequate' and records are not identifiable.
I The Employee Concern files and the Confidential Sensitive files were researched
.to determine if they contained additional information regarding this. issue.
The files provided the following:
a.
NSRS Investigation I-86-126-SQN was assigned to.' Employee Concern SQM-86-002-001.. However, a NSRS Report. was ~ never issued.
b.
NSRS Investigation Report I-86-129-SQN was issued March 3, 1986 for Employee Concerns SQP-86-002-001 and WBP-86-009-001.
Note:
Part of the issue included in Employee Concern SQP-86-002-001 references NSRS Reports I-83-13-NPS and R-85-07-RPS.
These NSRS Reports; were used to identify the specific issue (s) of. the concern only, and for th.is reason, the reports are not attached to this Element Report.'-
1 NSRS Report I-86-129-SQN-was evaluated by QACEG to determine
'i the adequacy of -the scope and the results of the NSRS.
j investigation.
j
-]
and site'
']
The QA Topical Report-TVA-TR75-1A, = the. NQAM, ~
practices,. procedures, and policies were reviewed to deterinine the compliance ' criteria. during the time frame ~ the concerns-were reported.
e The QA Auditing Branch files in' Chattanooga ( were reviewed to -
determine deficiencies identified by audits ' relating to the issue.
)
i
9 TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
TITLE:
PAGE 11 0F 28
' Quality Assurance Records 1
A review was also' conducted of the various forms of nonconforming conditions which were documented ' to. determine the types of deficiencies that relate to the issue.
Discussions were held with ;various ' site. personnel in. the Records Management and QA Vault areas ' to develop historical background and other additional information pertaining to the subject issue..
1 4.2.5 Issue - Welder certification records were altered.
1 The Employee Concern files provided two Employee Response Team (ERT) Reports by Quality Technology Company (QTC)' dealing with this subject (ERT Reports IN-85-612-X07 dated 10/24/85 and XX-85-088-X04 dated 3/4/86).
Although the ERT report dated 10/24/85 was evaluated for WBN, the QACEG 'has determined that this issue is generica11y' applicable to SQN and the results of the investigation at Sequoyah are included - in this report.
Also, NSRS Investigation Report I-86-120-SQN was assigned to Employee Concern XX-85-088-X04.
However,. a NSRS Report was never issued.
Site QA Procedure QAP 17.2 and Administrative Instruction AI-7 were reviewed to determine the-compliance requirements during o
the time frame the concerns ve;re reported..Also reviewed were
.six Survey Checklists, three Corrective ' Action Reports (CARS),
and six Discrepancy Reports (DRs). dealing with' welder qualifications.
4 i A review was made of the welder certification documentation which is on microfilm-and, currently stored in. the permanent record-retention system and ' hard copies. of ' Nuclear ' Power
~
Welder Certification. documentation whichL is. stored in the Solar Building.
Discussions were. held with various. site.' Records Management personnel.
to develop historical background and.other.
~ additional information pertaining to the' subject issue.
4.2.6 Issue - Maintenance Requests (MRs) which specified' the.
addition of ' grease for I.imitorque valve ~ actuators were signed:
off as unnecessary or. complete. even :though;'no. work.. was:
performed.
Non-QA material was installed' in QA applications
'and traceability was' falsified'on the MR.-
j 4
Research of the Employee Concern files and ' NSRS - files :. was conducted to-determine' if-additional information was
'I available.
One NSRS-Report vr.s' issued in February 1986 which j
c<
addressed this~. issue.-
o
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i 1y
1 TVA EMPLOYEE CONCERNS REPORT NUMBER:
j 3 FECIAL PROGRAM 80504-SQN
{
REPORT TYPE REVISION NUMBER:
j 6
1 Element Report PAGE 12 0F 28 i
TITLE:
Quality Assurance Records l.
A review was per.?orned of the ECTG Operations CEG Element Report (30840-SQN dated 9/12/86) for additional information since their investigation dealt with part of this issue.
A review was also performed of the NQAM Part II, Maintenance Instruction MI-10.46 and Standard Practice SQM2 to determine the c.ommitments end requirements surrounding 'the issue.
Discussions were also held with site QC inspection personnel who performed the Limitorque valve research.
j 4.2.7 Issue - Quality Assurance (QA) documents were lost by the veiult and regenerated by the responsible unit.
A review was performed of the Employee Concern and the Confidential-Files to determine if QTC or NSRS had investigated the issue and if the files could provide additional information regarding this concern.
It uns found that QTC had evaluated this concern and issued Report No.
IN-85-091-001 dated 9/16/85.
I I
The NQAM, site practices, and procedures were reviewed to determine the compliance criteria during the time frame che issue was reported.
The Nonconformance Report (NCR) Log was reviewed fear any information identifying lost QA documents or records.
\\
Discus 6ons were held with various site QA and Document i
Control-Ucit (DCU) personnel to develop information relating to lost QA documents.
1 l
5.0 FINDINGS f
The following contaias both a background discussion and a conclusion for
_j s
car.h issue as identified in Section 1.2.
j 5.1 Issue - Controlled documents contain conflicting nr obsolete data or l
~ ~
both.
5.1.1 Discussion i
Two reports (I-86-185-SQN and I-86N80-SQN) were issued by.
. i NSRS of which the above incue is a part.
Our inveutigation and this report will discuss each NSRS Report separately.
j 5.1.L1 NSRS Report I-86-185-SQN NYRS Repor: t-I-86-185-Sqh dated March 1986 described the iuvestigation of Vendor. Drawing Control. where five n.".
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TVA EMPLOVEE CONCERNS REPORT NUMBER SPECIAL hROGRff 4 80504-SQN REPORT TYPE
's REVISION NUMBER:
Element Report 6
TITLE:
i PAGE 13 0F 28 Quality Assurance Records 4.
y t
i-Employee Concerns were investigated by NSRS of which this issue was a part.
3 4
s The NSRS Report included a clarification of the issle' as provided to NSRS.by QTO which said Wat SQN design g
. ere issued by fthe ' Office -of
. drawings- (mylars)-
w Engineering Reprographics, Knoxvillek I
.l Our. investigation ttirefore, dealt with[ interviews of.
j personne1 at. SQN;. dd Untered around-I drawing control 7
the process.for. requesting dup 1Leates and determining how conflicting data coul'd exist?
/
4 If an original vendor drawing n cannot be located and the sign-out log 'does not ' indicate. that the drawing was removed 'from the ifile, the.Drhwing ' Control Unit'
.will. request a. replacement drawing. from the Technical Information Center. (TIC) at Knoxville.
'The.
i replacement drawings are referred to. as "washoffs"..
g' This "washoff" is iissued as a new ' original" and has'
~
the potential for ^ placing Lin\\ circu$ tion two ' original s
drawings which' could. contain ponflicting. data.'.This 4
and is not properly noted in the hav% ji file.
happens if the firstD issued' drawh should reappear in
%g p.
The replacement'. of ' duplicate or. "washrrff" diswings-
/*
appeared to primarily affect' those vendor.drsridgs, J.
received-at SQN' prior to 1976. b y W' '
', [,'
s-wg.
Discussions with ' Drawing" Control personnel, confirmidby that. these? site drawings ~were discarded ;and that.Ed Y
was possible for 'two ' original; vendor l drawings 1to" be:in -
(
circulation with conflicting data' for the reason.noted i J A
above although this -investigation ' did n'ot find where -
N' this happened.-
,To. avoid. this, the Drawing Control }
f personnel.are; nov/requireUby 7 procedure to place a g'.
notation inL.thd drawing ? check-out file 1that 1a ' "new-7-~
' ~
. original" - has' ; been irequested..
- Subsequen.tl vendor ' drawing reippears at ? Der % ring Control,'y, if.' one the clerk; 1
is-immediately alerted-t'o, the ' existlence of'- the duplicate drawing.- The c1Ed
engineering, c ' will determine j, with ! thp assistance of -
the correct Tdrawing to'
. retain,: then eliminati; the obsolete f drawirg ' from - the records ! sys tem.'
Toliverify. the_ control of 'this'-
particular-drawing; activity,'
QACEG confirmed.. the implementation.byL reviewing, th e ' vendorJ drawing; checkout files and found fish contaiaing the notation "new originals"' on the replacement drawings.
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TVA EMPLOYEE CONCERNS REPORT NUMBER SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
PAGE 14 0F 28 TITLE:
Quality Assurance Rec ords Controls are 'now in place to avoid lost and duplicate drawings in existence with incorrect data.
5.1.1.2 NSRS Report I-86-180"SQN NSRS Report I-86-180-SQN dated February 1986 described the investigation of Sequoyah Drawing Control.
Six Employee Concerns wern investigated of which the issue noted above and investigated by QACEG was a part.
The NSRS Report also included a clarification of the issue which was provided to NSRS by QTC, which said that drawing 45N1749-30 (R8) was issued twice on
[,
separate mylars.
The Mylar drawings were issued on 0 November 29, 1985 and November 30, 1985, respectively.
(
r 7
- h The investigation in the Drawing Control area included i
7 a review of the ~ SQN 't,ylar drawing number 45N1749-30, Revisioti S, Engineering Change Notice (ECN) L6202 and L6544, Field (Change Nor. ice (FCN) 3585 and 3966, and i
Significant condition ; Report (SCR)
SQN SQP-8601, Revision O.
,\\
, \\ 'r This review c;mfirmed the NSRS report that mylar i
drewing number 45n749-30 was issued twice as revision i
8.
The first ' issue was.for ECN L6202/FCR3583 dated 11/29/85, and the second issue was for ECN L6544/FCR 3966 dated 11/30/85.
Failure to adequately log-out the first release of Revision 8 mylar on November 29, 1985 created the potential for obsolete or conflicting i
data when one. drawing is updated and not the other.
As a result of the N!!RS ' investigation this Condition Adverse to Quality (C4Q) was reported on SCR No. SQN i
SQP-8601, Revision 0,' dated 1/11/86 QACEG verified the corrections es having been made and checked the
)
current log ocoks of issue tickets and could not find where other duplications have occurred.
Our discussi$ns.with Document Control personnel indicated that the condition happened because of ~
inexperienc e
.of new clerical personnel in the changeo,ver frem the Engineering Project Office in Knoxville to thei site of fice and lack of attention by the new personnd to ' t.he Engineering Change Notice, i
i Field Changa
- Request, and drawing issue process.
Prior to Septe.mber 1986 ' Drawing. Issue tickets which sre Ased, to s request copies of
- drawings, were codidered
".hg" atd were only kept for 6 months..
a piebp ' tickets plus rthe accompanying Drawing Issue i
l L.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
/
TITLE:
PAGE 15 0F 28 Quality Assurance Records Checklist are now being kept indefinitely by DCU.
Item 5 of the Drawing Issue Checklist instructs the j
DCU personnel to verify that the drawing and appropriate revision are clear for issue by using the Drawing Management System computer program.
The data l
on the screen will alert the operator of any inconsistencies.
Correc tive actions have been initiated by TVA by way of additional training from Drawing Management System personnel in Knoxville and the addition of a Drawing Issue Checklist.
Additional supervision has also been assigned to the DCC to control the issuance of drawing.
5.1.2 Conclusion The issue of controlled documents containing conflicting or obsolete data er both is considered valid.
The QACEG investig4 tion and evidence produced verifies the results obtaine by NSRS.
The NSRS Reports are considered f ac tur '..
There did exist the potential for two " original'.'
vendcc drawings to exist.
However, there now are adequate controls in effect to prevent this from occuring.
This investigation also found evidence to support the conclusion in that the wiring diagram was issued twice with the same revision number.,
This appears to be an isolated case having happened when the individual who furnished the first copy of the wiring diagram on November 29 failed to enter the drawing issue ticket in f
the log.
Turther reviews of drawings and issue ticket logs could not find where ' this condition happened again.
Procedures governing the issuance of drawings are adequate and additional training by Drawing Management Systems personnel was provided to correct this condition.
q 5.2 Issue Failure to appropriately document work which had been performed.
i 4
5.2.1 Discussion The issue raised was that "Sequoyah was allegedly shut down in 8
g'roup to. appropriately August 1985 due to the failure of a document work which had been performed".
Records indicate that SQN was shut down in August 1985 because TVA determined that they would not be in full compliance with regulatory.
requirements for equipment qualification, 10CFR50.49, by
i
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
l Element Report 6
t TITLE:
PAGE 16 0F 28 Quality Assurance Records November 30, 1985.
On that basis, it was concluded that the j
concerned employee was referring to the Environmental i
Qualification (EQ) documentation.
A review was made of the revised Sequoyah Nuclear Performance Plan-dated July 1986 to determine the background associated with the plant shut-down.
A review was also performed of the regulatory requirements in 10CFR50.49 to establish those requirements.which TVA has committed to comply with.
The Nuclear Performance Plan,Section III, Paragraph 1.0 stated the following:
"The environmental qualification of electric equipment
]
required to ensure reactor coolant pressure boundary integrity, shut down the reactor and maintain it in a safe shut-down condition, and prevent or mitigate the 1
consequences of accidents that could result in off-site l
exposures comparable to the 10CFR100 guidelines is required by 10CFR50.49.
It is further required that the evaluation of environmental qualification be documented
)
and maintained in auditable files.
The date required by
{
NRC for full compliance with 10CFR50.49 was November 30,-
]
1985.
TVA conducted a management review of the environmental qualification programs of SQN, BFN, and WBN in July and August 1985.
This review indicated that much of the 1
qualification documentation was not fully auditable and, j
in some
- cases, the documentation available did not demonstrate full qualification.
]
The cause for the failure to comply in a timely fashion with 10CFR50.49 requirements. was a lack of management attention to the environmental qualfication program.
SQN was shutdown voluntarily at the direction of the Manager of Nuclear Power with the concurrence of the TVA Board of Directors in August 1985.
b Subsequent to the voluntary shutdown of Sequoyah, the Equipment Qualification Project (EQP) was formed with the responsibility for development' and implementation of an EQ l
program.
Responsibility for engineering activities.
associated with environmental qualification - is presently assigned to Division of Nuclear Engineering (DNE) and detailed responsibilities,. scope, organization,. specific project procedures, and project' training program are defined in 'the project manuals for the EQP. and the Sequoyah Engineering Projeet (SQEP)."
Standard Practice SQA173, "Sequoyah. Nuclear Plant 10CFR50.49
5 TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
l Element Report 6
TITLE:
PAGE 17 0F 28 Quality Assurance Records Environmental Qualification Program," describes the overall program for achieving full compliance with 10CFR50.49.
5.2.2 Conclusion The issue is substantiated.
However, adequate attention is being paid by TVA to identify and correct the deficiencies.
TVA has tentatively scheduled completion of the necessary tasks to demonstrate equipment qualification by the 'end of April, 1987.
5.3 Issue - Material control is poor.
Traceability of requirements and materials is inadequate; paperwork for quality records is poor.
5.3.1-Discussion comprehensive NSRS The Employee Concerns files contained a report on the material control activities at SQN.
The. NSRS report addressed the points raised in the subje::t issue.
This investigation dealt with verifying the validity of the findings noted in NSRS Report I-85-987-SQN dated February 1986.
The QACEG considered the material control issue from a programmatic point.
Material Control CEG is addressing the hardware issues in SQN report MC-40703-SQN, Revision 1.
All the documents reviewed by both NSRS and QACEG were 4
generated during the operational phase as construction was essentially complete at the time the concern was generated.
4 The requirements for material control,- traceability and quality records at SQN are based upon Appendix B to 10CFR50, Regulatory Guides 1.33, 1.38, 1.123,.and 1.88, the TVA Topical j
Report and NQAM, Parts
.II and' III,.together with the Administrative Instructions AI-7, AI-ll, AI-12 and AI-36 and Standard Practice. (SQA45).
The NSRS findings were reviewed against the above requirement documents.
A selection was taken of all the documents used in. the NSRS investigation and a l review was performed by. QACEG of their
~
content to' independently verify the NSRS results.
The Quality.
As suranc e Category Group (QACEG). reviewed seven Surveillance Reports, seven audit reports, two Corrective Action ' Reports (CARS), and - nine Deficiency Raports (DRs).
These documents dealt exclusively 'with material. control activities.
The reviews produced evidence of a
significant-number of deficiencies (conditions adverse to quality) dealing with inadequate instructions being available and failure-of 1
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
3 Element Report 6
(
I TITLE:
PAGE 18 0F 28 Quality Assurance Records t
personnel to follow those instructions which were in place.
During the period 1981 through 1985 (when the above noted Conditions Adverse to Quality were reported),.NSRS compiled data on 15 instances of inadequate instructions to maintain adequate material control.
Likewise NSRS data revealed 134 l
instances attributable to failure to follow the instructions which were in place.
The NSRS data dealing with traceability of requirements indicated 49 conditions where there was inadequate l
traceability of requirements (those noted on procurement documents) to the material received.
It was also found that there were 97 conditions noted in the reports relating to improper traceability of paperwork and materials.
That is, maintaining traceability of documentation and material through the entire cycle of receipt, installation and operations.
In researching the allegation of poor quality records the NSRS data indicated 99 conditions being reported relating to inadequate documentary evidence of the quality of the material.
In addition to verifying the validity of the NSRS findings, the QACEG investigation. performed an evaluation of the areas covered by the Quality Assurance Audit Branch audits and site -
surveys (surveillances) and found that the depth and coverage was adequate to form an objective evaluation of the-conditions.
5.3.2 Conclusion By researching and reviewing the sample ' numbers of reports noted above and our independent verification the QACEG has determined, in agreement with the NSRS reports, that the issue raised by the concerned individual is valid.
However, there appears to be a decline in incidents of poor material control and related quality records.
This ~ was concluded because of the reduced number of findings ~ repo';ted in recent audits and surviellances even though the QACEG investigation found that the SQN QA Surveillance Staff has increased their effort of surveillance over the material control activities.
TVA has directed considerable attention in the years 1985 and 1986 to the improvement in the control of materials at SQN.
This has been verified by reviewing audits and surveillanc e '
reports of the Quality Assurance Surveillance Section.- There appears to be ~
downward trend in the number of conditions a
adverse to quality which' are being found.
Audits, increased.
surveillance by SQN Plant QA Staff, TVA Management attention,-
i 1
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN
)
REPORT TYPE REVISION NUMBER:
j j
Element Report 6
TITLE:
PAGE 19 0F 28 Quality Assurance Records i
and personnel awareness seem to have had an effect on reducing incidences of improper control of material and related documentation.
Corrective actions as a result of Element Report 40703 will also reduce the incidences of improper I
material control.
5.4 Issue - SQN records retrievability is inadequate.
The concerned employee alleged that the retrievabilty of SQN QA l
records generated during both the construction and the operational phases is inadequate.
The findings and conclusions' contained herein j
are discussed separately for the retrievability of quality related construction and operation records.
5.4.1 Retrievability of Quality Related Contruction Records.
I 5.4.1.1 Background The Records Retrievability ' Indexing -(RRI) system for QA construction records was addressed in NSRS Investigation Report I-86-129-SQN and the issue was reported to be substantiated.
The NSRS Report identified that SQN QA construction records including vendor drawings and manuals have not been completely entered into the records retrieval system.
Since the current RRI for QA construction records and the vendor drawings and manuals are less than 50 percent implemented, the records retrievability system was considered to be unreliable and incomplete.
5.4.1.2 Discussion i
The overall results-of the QACEG investigation indicated that QA construction records were-retrievable; however, ' the method was considered slow and unpredicable.
TVA management recognized this condition in early 1983 and since has been working to j
provide a complete index and document location on microfilm for each QA construction record for SQN
{
Units 1 and 2.
j i
d During the same period, the Vendor Drawing and Manual Control Program was considered by TVA to be a
potential problem.
. TVA surveillance groups had j
8 identified the following conditions relating to vendor i
drawings and manuals:
- a. Vendor - drawings and manuals were unorganized and difficult to retrieve.
1
I TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
PAGE 20 0F 28 TITLE:
Quality Assurance Records
- b. Vendor drawings and manuals were not controlled relative to the "as designed" specifications.
On February. 22, 1984, the Quality Engineering Branch (QEB) initiated a Nonconformance Report (NCR)
No'.
GENQEB8401 describing a ' deficient condition involving inadequate indexing and ineffective retrievalibity of-vendor QA records.
The corrective action measures for the ' CAR included the revising of Interdivisional Procedures ID-QAP 17.1, " Transfer of Quality Assurance Records", ID-QAP 17.2. " Quality Assurance Records for Design and Construction", and QEB-EP 24.37, " Product Compliance Data and Quality Engineering Records Indexing and Preparation".
Verifying and final completion of this CAR was performed on August 28, 1984.
In early 1985, the Office of Nuclear Power (ONP)'
conducted a review of the RRI for QA construction l
records and determined several areas to be deficient.
A task force was established to develop I
recommendations, including' the revising of instructions and procedures for each quality related construction QA record.. This revised retrieval system for QA construction records under new and revised guidelines has not been - fully implemented by. SQN at this time.
TVA Record Management personnel are presently in the process of identifying, indexing, and providing film locators on' each-construction QA record.
The purpose of the investigation ~ by QACEG of the RRI system for QA construction records was first to evaluate the present retrievability systeu and second, to determine. the present status and the scheduled completion dates for the implementation of SQN construction QA records.
The QACEG investigation of the. present 'RRI for QA construction records' involved the selection of 15 Cable Tray Inspection Reports for. SQN Unit I and four -
Hanger / Support inspection Reports.for SQN Unit-2.
These completed ' construction records ' were. transmit ted by Quality Control. to the Master Files for entry into the RRI.
The.
present retrieval method for' construction-' records.is controlled by the system number located on the microfilm reel.
The specific record must be located - by scanning' each frame until the desired document is located.- This method. involves
1 l
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
i SPECIAL PROGRAM E0504-SQN REPORT TYPE REVISION NUMBER:
i Element Report 6
TITLE:
PAGE 21 OF 28 s
Quality Assurance Records the possible scanning of approximately 4,000 frames per reel to locate the desired document.
The results of the investigation revealed that 18 of the 19 inspection reports were retrievable.
One Cable Tray Inspection Report could not be located.
The retrieval process for these records was accomplished by one individual in approximately six hours.
TVA's highest tier QA Program Manual, the Topical Report TVA-TR75-1A, Revision 8,
Section 17 requires that a
records index and retrieval system be established to assure that Quality Assurance Records are identifiable and retrievable.
Although the Construction QA Records, including Vendor QA Records, were available, the documents were not indexed to a degree of reliable retrievability.
j The current RRI for QA Construction Records. when completed will be capable of retrieving documents more efficiently by means of identifying documents by reel and frame number.
This method will provide direct l
access to a specific document' on each reel.
During 7
the discussion with the Supervisor of the.SQN Construction Records Project, it was determined that the Construction QA Records portion of the RRI was l
approximately 25-30 percent complete and final completion scheduled for December of 1988.
)
i The SQN QA Staff initiated a Corrective Action Report l
(CAR)
SQ CAR-86-01-004 dated-January 30, 1986 1
addressing a ' condition contrary to the requirements of -
)
Administrative Instruction, AI-23 -and the Nuclear Quality Assurance Manual (NQAM) Part. V.
This CAR noted numerous vendor drawings and manuals contained in the SQN Environmental Qualification (EQ) Binders that were inconsistent with the information identified in the plant controlled Drawing Management System
~ ~ 4 (DMS).
The' disposition for the CAR has not been resolved to date.
The vendor drawings and manuals are being verified for -
technical. adequacy-by-the Division of Nuclear Engineering (DNE) prior to forwarding to the Document.
Control Center for entry.in_the DMS.
SQN is upgrading the Vendor Drawing and Manual Control Program by developing new and revised procedural requirments in the. Nuclear Quality Assurance Manual (NQAM)' and lower-tier documents i.e.,
Administrative.
m
1 l
i
,1 TVA EMPLOYEE CONCERNS REPORT NUMBER SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
TITLE:
PAGE 22 0F 28 Quality Assurance Records Instructions AI-23 and AI-25, and Sequoyah Engineering Procedure, SQEP-39.
These procedures are presently in the review cycle and a scheduled. issue date has not been established.
In a discussion with cognizant DNE personnel, - it was l
indicated that the Vendor Drawing and Manual Control l
Program is approximately 40 percent complete.
The target date for completion is January of 1988.
5.4.1.3 Conclusion The issue of the document retrieval of QA records being inadequate and not identifiable in relation to vendor and construction QA records. is a valid issue.
Although our investigation indicated a high percentage-of retrieveable construction QA records, one must consider the delay and effort involved to retrieve these documents.
- However, this. condition is not considered a violation of present requirements.
The overall records
. retrieval system for. QA Contruction Records ' including vendor drawings and manuals is less than 40 percent complete; therefore, prompt, reliable, and adequate retrievability ~ is not feasible at this time.
Difficulty in, retrieving QA j
records could potentially. hinder the required evaluation of a safety-related part or component.. In addition, the numerous vendor drawings and manuals addressed in-CAR No.
S'Q-CAR-86-01-004 need to be corrected and up-dated to reflect the revision level l
of the "as designed" equipment and information j
included in the DMS.
The. CAR is the current document used by SQN as the tracking means for the ;above l
deficient condition.
1
~
Although corrective action is warranted pertaining to f
the issue of records retrievability 'of vendor ' dw.ings and manuals, a Corrective' Action Tracking Document (CATD) has not been issued. as part. 'of this ~ report.
CATD No. - 80503-SQN-07. addressing a similar ' is sue was included with QACEG Element Report No. 80503-SQN.-
4 i
5.4.2 Retrieveability of Quality Related Operation Records.
.j l
'i l
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L a
1 TVA EMPLOYEE CONCERNS REPORT NUMBERS j
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
6 Element Report TITLE:
PAGE 23 0F 28 Quality Assurance Records 5.4.2.1 Discussion This issue was investigated by QACEG by selecting nine f
types of operating QA records; such as, Engineering Change Notices (ECN),
Workplans (WP),
Corrective Action Reports (CAR), Inspection Reports, Discrepancy Reports (DR), Maintenance Requests, NRC Inspection Reports, Inplant Surveys, and Inservice Inspections, for retrievability from the RRI at SQN.
The nine types of QA records consisted of a total of 221 documents to be retrieved.
Of the 221 documents only three were not retrievable either on microfilm from the Document Control Center (DCC) or hard copy from the Permanent Storage Vault.
The three documents were further researched and it was found that one was cancelled and the other two need to be reviewed by QA prior to forwarding to the Permanent Record Storage Vault.
The selected Operating QA records were j
satisfactorily retrieved from the RRI and from the Permanent Storage Vault.
i In addition, QACEG reviewed five SQN QA audit reports relative to the records retrievability in the Document I
Control and QA Records areas for 1985 and 1986.
This review concluded that no major breakdown in the RRI was reported.
3 i
5.4.2.2 Conclusion Based on the above evidenc e, the issue of inadequate l
records retrievability for operating QA records is not a valid issue.
The QACEG evaluation of this issue has determined that j
the RRI was effective for the retrieval of operating l
QA documents.
The RRI is most effective when a unique identifier number, specific type document -or system number is used to retrieve desired records. '
5.5 Issue - Welder certification. records were altered.
5.5.1 Discussion QACEG reviewed Welding Project's (WP)
Specific Employee Concerns Report dated November 6,
1986 addressing Employee Concern XX-85-088-003.
The issue of alterations to welder i
qualfication records as noted in WP report was_ _ not substantiated in relation to' welder certifications being technically satisfactory.
This issue was investigated by
l TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
{
TITLE:
PAGE 24 0F 28 J
Quality Assurance Records
)
i 1
QACEG to determine if the velder certifications were actually altered.
Ihc investigation performed by QACEG did substantiate the issue that welder certifications were altered 1
contrary to TVA's established requirements.
This issue is discussed below.
A review was made of the QC Plant Log which documented. all i
3 Special Process Surveys conducted by TVA since 1982.
A sample.
of six surveys performed from July 1983 thru August 1985 was then selected for review to determine if the issue of " Altered j
Welder Certifications" had been identified as a problem.
{
These surveys encompassed welder qualifications and welder
]
continuity checks to determine if the program was being i
controlled in accordance with SQM 17 and Specification DPM-N73M2.
Each of these surveys identified various types of problems resulting in many DRs being issued.
Additionally, in some ins tances CARS were initiated which required root cause analysis, resolution of condition adverse to quality, remedial corrective
- actions, and corrective' actions necessary.to prevent recurrence.
The latest survey
- reviewed, dated August 26-September 5, 1985 identified numerous welder i
certification record discrepancies.
These problems included
'I the following:
j a.
Inappropriate changes were made by engineers or clerks to performance qualification records, b.
Welder Continuity Records contained conflicting entries.
c.
Weld Rod Issue Cards did not provide adequate information to verify that welding had actually been performed.
As a result of'the various problems identified, CAR SQN-CAR-85-09-014 was initiated which required immediate ' corrective action.
All SQN active welders'. files. were reviewed to identify and correct any discrepancies' related.to welder continuity and welder qualification.
This review did not identify any welders who were working in violation of the applicable code.
In several c as e s.,
however, welders were directed to.re-establish ' their certifications to ensure that all doubt had been removed concerning their qualifications.
The issue of welder certifications being altered by the use of -
correction fluids was reviewed-for. 75 welders from the.
Division of Nuclear Power and approximately 200 ' records from Construction revealed that contrary. 'to - the NQAM Part III,-
Section 4.1 and AI-7, para.
4.2.6, corrections were made to some Welding Ter-formance Qualification records. by use of correction fluid.
3 TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
TITLE:
PAGE 25 0F 28 Quality Assurance Records Based upon copies of welding records obtained from several microfilm rolls there was evidence that some of the welding records.did have corrections made to relevant information which could be significant to the quality information applicable to the welder certifications.
Corrections were made to Guided Bend Test
- results, entries on welder qualification. lists, position and specimen numbers, electrode or filler metal type and size, backing ring or strip and diameter and/or thickness.
With regard to the welding records of the Division of Nuclear Power, the certification records reviewed were the actual hard copies located both in the active and inactive files.
There was evidence of correction fluid being use.d on 'five of the seventy-five certification records reviem.d in the active Nuclear Power file.
These corrections were made to entries in the Qualification Test blocks, date qualified / locations blocks, welder continuity records and to the actual Test Results block for Guided Bend 3
tests.
These corrections could be significant to the quality information applicable to the welder certifications.
These conditions violate the. requirements of NQAM Part III,
'l Section 4.1, which states that in the preparation of a QA record changes / corrections should be made by marking a single line through the item to be changed making the new entry and i
entering the dated initials of the person making the j
change / correction.
SQNP AI-7, Paragraph 4.2.6 requirements are similar to the higher-tier document.
5.5.2 Conclusion Based on the above evidenc e, the issue of-welder certifications being altered is valid.
The documented evidence of welder certifications being altered is a violation of the requirements of TVA procedures and practices.
The Welder Performance Qualification Records maintained by both Construction and Nuclear Power. are defined as QA records,
- n. _. _ _
therefore, these records are within the scope of the NQAM and -
SQN site procedures.
5.6 Issue - Maintenance Requests (MRs) for Limitorque valve ' actuators were signed off as unnecessary or complete even though no work was performed.
Non-QA material was installed in QA ' applications and traceability was falsified on the'MRs.
i i
5.6.1 Discussion The investigation by QACEG concentrated on the specific
s
' ' ' ~
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION' NUMBER:
6 Element Report PAGE 26 0F 28' TITLE:
Quality Assurance Records employee concern and~ the' issue of the Limitorque' valve actuators. and whether 'or not Maintenance Request -(MRs) which j
require the addition 'of grease to the valve ac tuato rs were j
signed of f by a general foreman as not necessary;. whether the
,]
same MRs which the general foreman considered unimportant. were j
signed-off even though no work was performed; and whether or not - non-QA material was. installed in QA applications and i
whether-or not traceability was falsified on the MR. '
(QACEG assumed ' this to mean the' application 'of grease since the CI incorporated his allegation on the same concern with the j
i Limitorque valve issue.)'
The investigation.of this. issue was part of a larger
.i
' investigation done by the Operat' ions Concern Group and reported.in their. Element Report 30804 SQN.
A discussion with the SQN ' QC inspection' personnel by QACEG ' provided ' details of 1
an ' investigation and research by them into ' 102-Maintenance Request packages for all the Unit '2 Limitorque valves'.
That investigation'by SQN QC was done in June of 1986 to' verify-the application of correct grease-in the valve' actuators..The SQN.
i QC-investigation and the QACEG investigation verified that all'
{
Unit 2 Limitorque valves were inspected and it'was found that d
the actuators have been. properly greased ~.in - accordance with I
the requirements of Maintenance' Instruction MI-10.46.
This MI '
l stipulates a QC hold point for the verification of lubricant.
j 5.6.2 conclusion 4
This is sue.' is unsubstantiated since there were no ins tances observed in the' Maintenance - Request's; - reviewed :- where nthe general foreman cancelled or deleted 'a requirement.. Research-of the MR packages and our conversation ; with. - thel SQN - QC inspection 'personne1~ indicated - that - all ' '. Unit 2" Limitorque-valve actuators have.been inspected and' verified to have been
- )
greased with the proper lubricant.
]
5.7 Issue - Quality. documentation was lostz by the vault and regenerat'ed b'y the responsible unit.
-j i
5.7.1 Discussion j
i This issue was investigated and reported. by QTC on/ Sept' ember 16, 1985' specifically for a f condition 1 at? Watts e Bar ~ Nuclear L Plant (WBN).
The ' QACEG investigation ; at SQN' included the' review Jof ~ the' l
similar condition -and l documents which 'were J reported by.QTC.
QACEG : reviewed the Electrical' Inspec! tion ~ Log for: 19851 and y
1 REPORT NUMBER:
4 TVA EMPLOYEE CONCERNS 80504-SQN SPECIAL PROGRAM REVISION NUMBER:
i 6
' rt PAGE 27 0F 28
.asurance Records y
I 1986, five SQN QA audit reports, and approximately 400 NCRs to 1
j-determine if SQN documented conditions of lost QA records.
'I The results of this investigation revealed that the data
/
reviewed did not identify conditions of lost documentation.
QA personnel indicated that SQN did not report the condition of lost documents.
The SQN permanent vault personnel would to be included in the request copies from the responsible unit RRI.
5.7.2 conclusion.
i The issue of lost documents at the vault could not be q.]
'yg?
substantiated at SQN.
The investigation revealed this issue
]
to be specific to WBN only,
- g a
[h..y 58 Corrective Action
,.hiq issue of the controlled documents containing conflicting or obsolete data as described in Section 5.1.1.2 is valid.
However, this QQf The to be an isolated case as noted in Section 5.1.2 QQ i
condition appears MM T
The duplication has been corrected and a review of the hEk 2
" Conclusions".
?i issue ticket logs could not provide further evidence of this. happening 2.co I N
f.^
again., A Drawing Issue Checklist has been added to the procedure and
?
E additio'nal training has been provided by Drawing Management Systems
.a personnel. There will be no other corrective action necessary.
y.f gg)
Z Z
The issue of f ailure to appropriately document work which had been G ;l a
@d y~_
valid.
TVA has assigned lerforsed as1 described in -Section 5.2.2 - is h
.the responsibility for engineering activities associated with the
=
~
e.
Environmental _ Qualification' Program to DNE.
These detailed i:;., y
@W are described in
- respotisibilities and overall program. requirements evaluation will i
n
~
-determine if there is any potential impact on safety.
~,#
e a
s
?
r
~
5 r
m, m
The issue of material' control' is poor as -described in Section 5.3.2 is valid.. However, this condition has improved through the individual 7~
m
g1
~~ srsonner awareness, and corrective actions i
A T
- TVA management at tention, E
E C
Ts a3esulttof Material Controls Element Report MC-40703-SQN.
The H
p
~~~
~
h E
. material control report identified several. deficiencies relating to 1he control of material traceability.
These deficiencies will be Z
u
~
~.
2
.Z
~
" addressed tol SQN line management ' in a future revision to report MC-.
~
40703-SQN..
The corrective '. action will be tracked by the Material 4.-
Control Employee Concern Group. Additionally, during the conduct of
. the NRC Safety System. Outage T Yodifications. Inspection '(SSOMI, 50-327/86-68 and'50-328/86-68) as ' transmitted to TVA 6-Inspection Number
~
on April 24F1987F a number -of de'ficiencies were identified regarding
'sateri'al control. whir.h are being addressed for resolution.between the 3
' KRC and TVAE A description of these items ia contained in the Report referenced above.
N
..we..
m_,
- ]
e
., 3.. v -.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM-80504-SQN
_q REVISION NUMBER:
1 6
j REPORT TYPE
-Element' Report PAGE-28 0F 28-
]
TITLE:
,j Quality Assurance Records
.a l
of' inadequate document; retrieval ~of vendor and constructibn, The. issue
- QA records.- as ' described in Section 5.4.1.3 -is valid.. SQN QA ' issued CAR 86-01-004 addressing the inability. to retrieve the latest vendor j
drawings and manuals from DMS. The Vendor Drawing and Manual' Control
-j ij is approximate' y.40 percent complete.
In addition, CATD -
l Program 80503-SQN-05 L and' -07. addressing a'similar issue will be used ' to track this deficient. condition.
The' difficulty. in retrieving; QA-documents could potentially hinder the required : evaluation of a safety-related
~
When the Vendor Drawing and Manual Contro1~ Program part or component.-
it will reduce.the potential for ' this is completed and!put in place, condition.
The corrective action is being-' furnished by. SQN J Site
. Director's' Office.
The ' is sue of. welder certification records being altered.as described j
in Section 5.5.2 is valid.
The corrective action identified : on CAR' j
d 85-09-014-required.all ~ SQN active welders' files to be. reviewed and welders re-qualified / certified. to current requirements.
This CAR was dispositioned and QA verified completion. of corrective action on February 18, 1986.
6.0 ' ATTACHMENTS A.
- List of Employee Concern Information' Subcate' gory 80504 B.
List of References and Documents Reviewed-C.
NSRS Report I-86-129-SQN dated March'3,1986
.D.
RSRS: Report I-86-180-SQN dated March 4, 1986
'E..
NSRS Report I-86-185-SQN dated. March 5, 1986.
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REFERENCESfhcts.nN7ggggggjfy c
A.
Office of Engineering Procedure, OE-01 3001 Revision 0, " Drawing Originals
-Checking Out and Checking IH".
h' nagement and Engineering Data System, MEDS, HP B.
Division of-Engineering, a
23.05, Revision 1, "ENDES and Vendor Drawings Information Services".
Nuclear Quality Assurance Manual (NQAM), Parts I, II. and II, Revision dated C.
12/31/84.
Office of Engineering Procedure, OEP-08 Revision 0, " Design Output" D.
E.
- Administrative Instruction, 'AI-25 Revision 13, '.' Drawing Control Af ter Unit 1,ic ensing". -
F.
Significant Condition Report No. SQN.SQP 8601 Revision O.
c.
Final Safety Analysis Report f(FSAR) Section' 3.11, " Environment Design of Mechanical and Electrical: Equipment".
H.
TSAR Section 8.3.1.2.3,
" Safety Related Equipment in Potentially Hostile Inviroc.ent".
$ KIN M
- ^
fd 1.
h'N NUREG-0588, Eterim Staff Position on Envizonmental Qualification of Safety-F.P -
Related Equipment" '
.,J.
~IEEE-323-1974, "IEEE Standard for Qualifying Class - lE Equipment for' Nuclear.
Power Generating' Station" s
.K.
.L--
TVA Topical Report, TVA-TR75-1A' Revision 8 L.
Office of Construction Procedure, OC o QAPP-3 f Revision 5,
" Instructions, b
Procedures, and Drawings" M..
Of.fice of Construction; Procedure, OC QAPP-1.7,. Revisions 0 - 3,
'QA Records" Nonconfor=ing' Report (NCR) No.lSQN~CIB8502 Revision-1 7-N.-
O SQN Standard Operating Procedure, No. 551 Revision ' 6,, "Past. Records Review i
and Engineering Ivaluation" r:u2-P. JQuality - Assurance ~. Audit Report ~Nos.
SQ-8400-02,, SQ-84b0-0 3 -SQ-8500-01,. '
7 ~ ~Zi~
PSQ-A-85-005, QSQ-A-86-001-3 QSS-A-85-0009, and QSQ-A-85-0010-n - -.- -
Q.
SQN Complian'ce Visits,- Audits, and. Inspect; ions-7.n plant!. Survey,'
Checklist JNos.c 3-85-P-003,_,3c-85-P-004,-' 3h-83-A-017, ; 3h-84-S-004', 4a-85-A-
,j 001,.4a-85-A-013, and 15a-85-P-001'
.,c' jh. -
1 R.
LSQNIWork Plans Nos. 10803, 10806' 10830, 10842,!10850,fl0861, 10893,'10904, f
11139,11261,11277,11467,11481,' ~11582 and 11685. --
1
- l 4
x A
\\
'.':'T i
PACE 2 0F 2 r
i S.
SQN Corrective Action Report (CAR) Nos. SQ-CAR-85-03-004, SQ-CAR-83-07-022, j
SQ-CAR-84-01-001, SQ-CAR-86-01 -004, SQ-CAR-21-81-8, SQ-CAR-85-08-012, SQ-CAR--21-82-25, SQ-CAR-31-01-003, SQ-CAR-83-09-032, SQ-CAR-85-03-011, SQ-CAR-83-10-033, SQ-CAR-85-09-014, SQ-CAR-84-09-017, and SQ-CAR--85-03-005.
T.
SQN Deviation Report (DR) Nos. SQ-DR-85-05-047R, SQ-DR-85-12-148R, SQ-DR-85-06-060R, SQ-DR-84-07-077R, SQ-DR-34-03-023R, SQ-DR-83-12-117, SQ-DR 01-013R, SQ-DR-86-01-002R and SQ-DR-84-04-038R.
U'.
Generic Procedure No. ID-QAP-6.2, Revision 0 dated 6/18/85, " Vendor Manual Control".
V.
SQN Inplant Survey Checklists Nos. Sa-83-P-005, Sa-85-A-006, Sa-83-030, Sa-83-P-015, Sa-85-5-007, and Sa-84-S-025.
W.
Administrative Instruction AI-7,
" Recorder Charts and Quality Assurance Records", Rev. 36 dated 4/19/85.
X.
Generic Procedure No.
ID-QAP-17.2 Revision I dated 6/8/86,
" Quality Assurance Records for Design and Construction".
T.
Maintenance Instruction, MI-10.46 Revision 3 dated 6/26/86, "Limitorque, Moteor Operator / Control Valve".,
e Z.
SQN Standard Practice No.
SQM2 Revisions 18, 19 and 20,
" Maintenance
$' j Management System".
T.$F AA.
TVA 45 D Note, ' E. Hassell to J. Hamilton dated 6/13/86, " Evaluation of MR packages /Limitorque Operators".
3B.
TVA Drawing No. 45N17949-30 CC.
SQN Maintenance Instruction, SQM-17, Rev. 4 dated 10/14/86,
" General Requirements for Welding, Heat Treating and Allied Field Operations at a Nuclear Power Plant."
.e DD.
SQN DPM-N73M2 datd 10/10/86, " Process Specification for Welding, Heat Treating and Allied Field Operations."
EE.
NSRS Report I-85-987-SQN dated 3/4/86 FF.
QTC Reports IN-85-612-XO7.da ted
~}
IN-86-091-001 dated 9/16/85.
10/24/83, IX-85-088-XO4 dated 3/4/86, ~ ~and 2l
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ATTACllMENT C PAGE 1'OF 7
]
TEtitlESSEE VALLEY AUTHORITY NUCLEAR OAFETY REVIEW ETAFF NSRS INVESTICATION REPORT NO.
-129 EMPLOYEE CONCERN NO. SQP-6-002-001
SUBJECT:
SECDND FOLLOW-UP OF QEB RECORDS INVESTICATION I-83-13-NP DATES'0F-INVESTICATION:
February 6-14, 1986 IINESTICATOR:
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W. R. SIMONDS
.DATE'-
l REVIEWED BY:
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ATTACRMENT C PAGE 2 0F 7 1
c' I.
BACKCROUND A Hucicar Saf ety Revicw Staf f (NSRS) follow-up corrective action investinction was conducted to detcrmine the validity of an expressed employee concern received by Quality Technology Company (QTC)/ Employee Response Team (ERT).
The concern of record, as summarized on the Employee Concern Assignment Requcct Form f rom QTC and identified as SQP-6-002-001, stated:
s
. l CONCERU:
QA Records are not identifiable and retrievable.
NSRS Investigation I-83-13-NPS identified problems in 1983 and NSRS Report R-85-07-NPS indicates problems not corrected in mid-1985.
OE, OC and Nuclear Power Records are cited.
An NSRS follow-up revich of Investigation I-83-13-NPS did find that corrective actions resulting from the original NSRS investigation had not been completely closed out.
The results of that follow-up review are documented in NSRS Report R-85-07-NFS (Ref. 1) along with a recommendation (R-85-07-NPS-01) that the Manager of Power and Engineering appoint a records manager to provide upper management coordination for resolution of the open items which had been identified.
II.
SCOPE A.
The scope of'this investigation is defined by the concern of f;hjf5
- df record. It is that problems previously identified by NSRS investigation 7-83-13-NPS, and the corresponding follow-up review E-85-07-NPS, have not been corrected for Sequoyah Nuclear Plant (SQN).
The scope included determination of status and progress of the open B.
ite=s identified in I-83-13-NFS and R-85-07-NFS as they pertain to SQN.
C.
The scope of the follow-up investigation also included discussions with site and, task f orce personnel who are actively involved in the resolution of these ite=s.
~
j III.
SUmte.RY OF yINDINOS 2;....:.
R-85-07-NPS* contained reco=mendation R-85-07-EPS-01'which
~
A.
recommended that Power and Engineering (Nuclear);[p&E (Nuclear))
appoint an upper-level manager empowceed with the responsibility, y
authority, and organi ationaj freedom to assure that records
.l associated with the procurement and installation. of. Quality.
Engineering Branch (QEB) source inspected equipment and materials are assembled, verified for completeness, indexed, and stored for
,, y
. fing retrievability. The recommendation.further stated that the
'If appointee's scope should include all past andLfuture QEB source O'y inspected procurements for SQN, as well as Watts Bar and (a "
Bellefonte, and the establishment of a schedule f or completion af j
past records.
1 i
s
i l
t ATTACRMENT C PAGE 3 0F 7
,-s
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s..
P&E (Nucicar) subsequently informed NSRS (Ref. 3) that an appointment had been made, and identified personnel who would provide a:sistance to the appointee. Following the appointment, meetings of the personnel were held on September 17, 1985, and December 16, 1905, to discuss resolution of the open items identified in NSRS follow-up review Report R-85-07-NPS.,These meetingr are documented in references 4 and 13 along with specific action items and schedules f or resolution of the problens.
IV.
STATUS OF PREVIOUSLY IDENTIFIED OPEN ITEMS A.
Develop an Integrated Records Svstem for Quality Assurance (OA)
Records That Will Satisfy the Needs of Nuclear Power (UUC PR) and l
Office of Ennineering Design Construction (OEDC) 1.
Paragraph IV.A.1 of R-85-07-NPS states that a TVA task force was working on vender manuals at the time of the first USRS follow-up review, however, two areas of concern were identified regarding vendor manuals as follows:
A question was raised by USRS regarding whether any of the a.
manuals were considered "one-of-a-kint", and therefore, in need of fireproof storage. This finding was addressed in ces (g[fgg paragraph V.C of the report.
s'
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Subsequently, ID-QAp-6.2 (Ref.15) was revised to; require
- f. i'Y
~
U* t that those vender manuals utilized as plant instructions will be maintained as' QA records. This'fequirement, in co=bination with' existing requirements of LI-23 (Ref. 16),
~
appear to establish adequate protection for ender manuals v
for SQU.
b.
The applicable procedures for vender manual control were found to be~ vague in the delegation of responsibilities.
A task force was developing a new procedure regarding. the maintenance of vender manuals which was expected to correct the problem. This finding was addressed in paragraph V.E' of the report. Subsequently, ID-QAP-6.2 (Ref.1.5) was revised to more clearly prescribe organizational responsibilities regarding the control of vender manuals.
.1 h
NW f 5-0WS6 mum'Me indexing procedures,had been prepared and were in various stages of implementation.
It was further stated that this item
^
will remain open until more experience is gained by P&E (Nuclear) ^ with the records indexing system. This matter is discussed in the following paragraphs.
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ATTACRMENT C PACE 4 0F 7 n
-./
l B.
Correct Imvicmentine Deficiencies identified in the Existint Svstem 1.
Paragraph IV.A.2.a of R-85-07-UPS states that QEB records were not adequately indexed and-that there was some concern
)
~
regarding their completeness. -At the time of the the first USRS follow-up review, cfforts were'under way to index'and microflim completed contracts; however, a schedule had not been established for completing the overall task.
Initially, a completion date of December 31,,_1987,' was set by the P&E j
(Nuclear) task force (III.A).for completing the overall task f or 'all projects (Ref. 4).
However, a recent commitment.was made that appropriate manpower resources will be expended to ensure that a deadline of June 30, 1986,'will be met for SQN (Ref. 13).. QEB is utill:ing a four-step-approach which includes' identification, location, verify completeness, and microfilming of the records (Ref. 4).
Sequoyah has concurred with the parameters that QEB is using'to index their records (i.e... vendor / contract number).
- However, site personnel normally'must-request the records by Unique Identifier Number (UNID).
Therefore, efforts are in progress.
to provide a cross-reference between UNID and vendor / contract numbers.
The Equipment Qualification Information System (EQIS) is being investigated as the link to provide-.this
'e:--
cross-reference.(Ref. 6 and 13). This item remains open.
W
?.
2.- Paragrap'h IV.A.2.b of R-85-07-NPS states that all OC records g
np for Sequoyah had been transferred or were in the final' stages s of microfilming at the time of the first NSRS follow-up-reviest.
~
.' Microfilming of all the records underkay.at the time of.the'-
review have been completed. L'However, another T75 cubic feet of-contract-related files and various other reco~rds were.
discovered by SQN-DOU personnel in warehouses incated by 00, in addition-to several files'at other locations. 'SQN-DOU and RIMS-Chattoonsa personnel.are working to' microfilm these--
additional records and have completed filming.about 36 cubic
~
feet.* Eanual indices will be, established for these records-pending resolution of problems associated with the Records Retrieval.Tndex.(RRI) system. Microfilming'is proceeding on an "as-soon-as possible" basis (Ref. 10, 12, 13'and'14). ~This.
item remains open.
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i' Paragraph IV.A.2.b of E-85-07-NFS also states that,a-RRI system.-
~3.
was prepared but 'jud'ged to be not totally effective.at the L time of the first NSRS follow-up review.
UUC PR personnel subsequently conducted a review of' the.RRI to identify deficiencies and initiate recommendations to correct any problems (Ref. 4 and' 7).
The NUC PR review confirmed that the RRI;was deficient in several areas'and recommendations were i t,.
i made to identify all OC record types and develop detailed instructions,for thefretrieval of.each,reccrd.
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- o ATTACHMENT C PAGE 5 0F 7
- )
The P&E (Nuclear) task force (III.A) established to resolve the open items of E-85-07-UPS has taken the recommendations under concideration and has acted to establish a sub-task group to
rework the SQN RRI using original ERI guidelines" (Ref.13).
The chairman of the sub-task group has met with cognicant
~
personnci and is proceeding with efforts to rework,the REI.
A date for completion of the task has not been set.
This item remains open.
4 Paragraph IV.A.2.d states that continued upper management coordination involvement at a level capable of crossing organication boundaries is considered necessary until the problems are solved and records syste=s prove effective.
This matter appears to have been adequately addressed by P&E (Nuclear) through actions discussed in paragraph III.A above.
/
C.
clarifv orcanicational Reevensibilities Paragraph IV.A.4 stn'tes that with the exception of a clearly defined system for vendor manuals, organizational responsibilities have been defined.
Subsequent revision of ID-QAP-6.2 (Ref. 15)
~
appears to adequately prescribe responsibilities for vendor manual control as discussed in paragraph IV.A.1.b above.
d f.m g Tjby' D.
Planned Actions and Schedules for Comeletion of Action m%
swer Nid.?
Paragraph IV.B of R-85-07-NFS states that QEB had not' completed verification and indexing of their records for SQN nor had QEB established a schedule for doing so at the time of the first NSES follow-up review. Actions taken on this matter are discussed in paragraph IV.B.1 above.
V.
COHOLUSIONS AND RE00FS.ENDATIONS A.
Conclusien
~
The employee concern is substantiated in that' corrective action'.
items shown in NSRS investigation'I-E3-13-EPS have not been -
completed for SQN.
However, specific improvements have been achieved regarding vender manuals, and work is steadily progressins toward the resolution of the remaining ~open items identified by.
NSRS.
B.
Petermendatien 94
- 4 I-86-129-SQN-01, Continue Monitorint
,-Q NSES should continue to monitor the status of. open items.from
.J!i 1-83-13-NPS as they pertain to SQN. '[F3]
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ATTACHMENT C PAGE 6 0F 7
-w DOCUMENTS REVIEWED IN INVCSTICATION NO. I-86-129-0Qu AND REFERENCES 1.
Informal Memorandum from K. W. Whitt to H. G. Parris, "F,ollow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS -
Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NPS." dated May 28, 1985 (A02 850529 010) 2.
Hemorandum from M. G. Parris to K. W. Whitt " Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NPS " dated July 1, 1985 (L16 850624 840)
Memorandum from H. C.'Parris to K. W. Whitt, " Follow-up Review of Quality 3.
Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear j
Safety Review Staff (NSRS) Report No. R-85-07-NPS " dated August 14, 1985 (L16 850729 883)
Memorandum from R. A. Pedde to Tiles, "NSRS Report R-85-07-NPS - Follow-up 4.
Review of QEB Records Investigation - I-83-13-NPS," dated September 19,1985 (Col 850919 004) l l
S.
Memorandum f rom M.11. McGuire to R. A. Pedde, "USRS Report R-85-07-NPS,"
l dated Septe.ber 24, 1985 (L16 850924 833)
Memorandum frem $. M. McGuire to R. A. Pedde, "NSRS Report R-85-07-NPS,"
) ()
6.
'- W dated October 29, 1985 (L16 851029 887) 7.
Memorandum from M. W. Madacek to M. M. McGuire, "USRS Report R-85-07-NPS,"
dated November 13, 1985 (L16 851113 895) 8.
Memorandum from R.
D'. Cuthrey to James P. Darling, "Configuratipn Task.
Force - Activity Su= mary and General Assessment," dated August 8,
"~
1985 (R25 850808 861) 9.
Inf ormal note.f rom J. P. Vineyard to C. L. O' Dell regarding transf er cf 00 t
I records to-NUC FR, dated June 28,1985 (325 E50628 302) 10.
Memorandum from Alva LaMontagne to Nancy Welch, " Office of Construction (OC) - Sequoyah (SRQ) Site Records," dated September 24, 1985 ( A31 850925 001)
- = ~ ~....
11.
Eemorandum from M. M. McGuire, to R. A. Pedde., " Action Item 9-17-3 of NSRS Report Do-. R-85-07-NPS,** dated November 21, 1985 (L16 851121 802) 12.
Memorandum from Alva LaMontagne to John Ed Hayes,." Microfilming Sequoyah Construction Records," dated January 8,'1986.(AS1 860108 051-)
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ATTACHMENT C
' PACE 7 OF 7
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- 13. 'herrierandum f rorp R, A..Pedde to'. Files, "NSRT, deport R-85-07-NPS - Follow-up' Review of. QED Records Investigation.. !-83-13-NPS." dated January.9.'
1986 (Col 660109 003) 14.
Hemorandam from Alva LaMontagne to Nancy Welch, ". Office of Consttvetion.
(OC) - Sequoyah (SEQ) Site Contract Records," dat~ed January-22, 1986 (A31 860122 051)
'f c
Part V, Section 6.2~
- 15..UUC PR huelear Quality Assurance Mr.nual (NQAM),
(ID-QAP-6.2), " Vendor Manual control," revision dated De'cember 31,'
1985 16.
Sequoyah Instruction AI-23. " Vendor Manual Control, R21 I
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TENNESSEE VALLEY AUTHORITY
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i USRS IITVESTIGATION REPORT NO, I-86 *.80-SQN 1
EMPLOYEE CONCERNS.,
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SUBJECT:
SQN DRAWING CONTROIf 'S NI T$@3
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DATES OF
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s, INVESTIGATION:
FEBRUARY 5-7, 1986 d' ant i
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W TUVESTIGATOR:
J.,J. ICIGHTLY
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. ATTACHMENT D PACE 2 0F 7
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BACKCROUND r
A Nucicar Safety Review Staff (UdRS) investigation was conducted to determine the validity of six expressed employee concerns as received by the Quality Technology Company (QTC)/ Employee Responss Team (ERT).
The concerns of record, as summariced on the Employee Concern Assignment Request Form from QTC and identified as SQM-6-003-001 through -006, stated:
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'SOM-6-003-001 p/
t Specific documents have been improperly issued.
[
$ 31 ear Power concern.
CI'has no further information.
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/
'QTC Clarification:
Design drawings for ECN 1.6027 have 7
been improperly issued.
i
,SOM-6-003-002 t
Duplicate documqnts have been issued with conflicting j
data.
Nucitar Po.ier concerr..
CI has no further i
information, h
/
}
QTC Clarificati.on:
Drawing 45N1749-30 (RB) was issued F@$s twice on two dparate mylars dated Novedt.: 29, 1985
,.W and UcVe=ber 30, 1985.
V::+y uw SOMI6-003-003 Specific documents have been improperly altered.
Nuclear Power concern.
CI has no more information.
QTC Clarification:
Drawings ISWB10-44 (R7) and F
45WB33-1 (R9) were issued without Project Manager's initials,in title block.
Initir.ls'were added to the
. Itlers after issue.
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Yalsifica.tien of specifie. documents.
concern.;,CI has no farther information.
- /
QTC Cla~ifici:,?.sa:
he drawings identified in Concern-sag 003--003 dcde cohected" without going through l
( the UCR process.
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\\,p0M-6-003-00F E
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I4?'dyee was directed to improperly change ancther
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employee /s work. Nuclear Power concern.
C1 has no further ^inf orma' tion.
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ATTACRMENT D.
PACE 3 0F 7 C$ \\I The documentation included three QTC Clarification:
significant condition reports (SCRs) submitted January 11, 1986.
SOH-6-003-066 1
a
(
CI feels an attempt is in process to ' cover up' specific probicm.
Nuclear Power concern.
CI has no further information.
[
QTC Clarification:
CI feels the significant condition
. reports identified in SQH-6-003-005 are being rewritten in such a way,that the real problems will be misstated.
i~,
1 II. - SCOPE
(
The' scope of the investigation was determined from the stated A.
concerns of record and the. respective QTC clarifications to be-that of only the. specific concerns contained in'the stated-QIC clarifications.
j 1
B.
'To accomplish this investigation USRS' reviewed applicable f
requirements, procedures, drawings, drawing' management' system reports,fsignificant condition reports (SCRs), and open item k
tracking system reports.for these SCRs. Additionally, responsible D
4
'*nh drawing control personnel were~ contacted to discuss the unployee's concern.
.i III.
SUMMARY
OF FINDINCS A.
Requirements and Co=mitments
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1; Uuclear Quality Assurance Manual (NQAM); part III, Section 1.1, "DocumentLControl," Revisien' March 21.-1985.
" Preparation, 0
review, approval, and issuance of documents and their.revisiens l
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shall be accomplished in accordance with approved written
.l e7' procedures / instructions. 'These w....~. shall includen.. the following requirementst
... Finaliapproval.authcrity, i
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' Revision Controls..
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- L ' Of fice of ' Engineering Procedure DEP-DE, " Design Output." -.
l Proj ect. Manager ". :.. :. signs at. '. Issued By' and. distributes. the.
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drawing."
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ATTACHMENT'D PACE 4 OF 7-B.
Findings 1.
Concetn SQM-6-003-001 A query of the Drawing'nanagement System identified 25 drawings for ECN L6027.
A review of the file of issued-drawings maintained in the Office of, Engineering Technical information Center (T1C) f ound that 24 of ' the 25 drawings. were issued without' the. Proj ect Manager's signature / initials as required by '
OEP-08,' Paragraph 5.1.3.
The affect'ed drawings are as follow.
45N1673-5 (R9):
45N630-4 (R15) f45N655-19-(R7)-
45N1645-1 (Ell)!
45N1645-8-(R12) 45N655-44. (R7) 45N1'648-1 (R10) 45W1656-4 (R22)
'45N1648-4-(R16)'
45W1673-5 (R9) 45N1688-li(R23) 45W2673-5 (R4).
45N1688-3 (R26).
$47B601-55 46 (R12)?
45N1693-1 (R24) 47W605-15'(R13)-
45N1693-3)(R19) 47W605-16 (R13)-
45N2645-1 (R9) 47W605-33 (R15)~
45N2645-8 (R12).
47W605-35 (R16)--
45N2648-1 (R13).
47W610-3D-01 (R28).
45N2648-4~(R9)-
- issued with approval' signature
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.\\w..EL T1N The nonconforming conditions.for these drawings were reported in' SCR.SQN'SQP8602 R0 dated January' 11.11986.
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.,,2 ;,, Concern SQM-6-003-002 A review of Sequoyah Nuclear Plant (SQN) mylar drawings foundl
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that. wiring diagram 45N1749-30 was issued >twice at revision-
- level 8 on two separate. mylars. dated November 29 and -30,11985.
The drawing.was first issuadiat revision level.8 for LECN'
/p 6202/FCR 3583 : and then issued the nextLday. at the. same.. revision.
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n control er-ors,' the drawings were also issuedJwithout Project-level.8-for LRCN 6544/ICR 3966. Inadditiontothese[ revision-
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Manaser's signature / initials.- A-subsequent; revision,.R9, y
. ref erences in the title block the. Eovember 30 issue.
The.
nonconfor=ing condition f or the'. duplicate.-Essuance was reported ~
in SCR SQN SQP8601.RO. dated-January 11,;1986.
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3,,
ConcernSQM-6-003-003[
4-
- A reviewL of Ithe appficable drawings 15W810-45[17.and' 45WB33-1 Jt91-
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found that bothL were issued without the' Project Mnnager's:
' initials'in[the title blockm, 1The SQNl mylar copies' included
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. initials at the time;of? investigation butLthe' microfilmed-aperture cards which were sent~out;on. distribution did-not.
Since.the cards;were reproduced'from;the.mylars, it was: evident:
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that the initials were..added af. tar { ssuance and-i Q=1 c
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ATTACHMENT D PACE 5'0F 7
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distribution-.
SON document control personnci stated.that the-initials were added'by unauthorized.~ personnel and in a manner-which contradicted office' practice.
.~he DCU office supervisor stated that the proper' method of correction was by reissuance of the drawing, recall of the incorrect drawing, and a memorandum of explanation to the document holders.
He stated that this correction would be initiated promptly. The n~onconforming situation was reported in SCR SQN SQP8603'R0 dated January 11, 1986.
i.
Concern SQM-6-003-004 As noted above, it was found that drawings 1SW810-44 R7 and 45W833-1 R4 were issued without the Project Manager'sz initials and th'at, initials were added to the mylars without authori:ation after issuance.
Because of this. bypassing of appropriate corrective action, which should have included' recall of the:
incorrect. drawings.and reissue of correct one's, the' distributed drawings were left.in an uncorrected status. 'Thus, the addition of initials to the mylars did not cause anything to.be changed in the system of distribution. It was. determined that numerous individuals had access to the mylars;and could:have placed the initials.
It is not known who placed them or what'their motivation may have been. The nonconforming condition...
concerning the initials is included in SCR SQN SQP8603 RO.
5.
Concern lSQM-6-003-005
.:9 w#87
- hree draft SCRs dated January 11, 1986,Tecncerning document-control problems - identified -in this report: Were. f ound to' have been submitted to the' SQN' Design Project Coordinator.. The -
Project Coordinator stated during interviews with NSRS that an 7-initial decision had been made to consolidate the'threelSCRs into one. However, after the-writer?cf the SCRs indic.ated;that--
j this " consolidation" might obsesre the' facts of the nonconform-I ing conditions, it was decided' to go ahead' and issue" the SCRs -
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exactly as written by the criginal' writer; NSES confirmed;by 1
review of the'e=ployee's original handwritten' draft'SCRs:and the?
j issued SCRs (SQN SQP8601.RO, SQN SQF8602;RO,l and: SQNl SQP8603. RO)
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that the issued reports were word for word asJoriginally 9
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' drafted.. -The, issued SCRs weie' dated Januirh 11, 1986,1 and,-
l according to the Proj ect Coordinator,. were transmitted January 17. -NSRS confirmed that theiSCRscwere'transmittediana:
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s;;a~ u m : received for. traekingrevaluation, and '.correcti_ve' action TyT
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reviewing:the TROI;open item and. reporting system reportLdated[
j February 1, 1986, which showed the' applicable SCRs as assigned---
q and in progress With the transmittals having?been' initiated 1 I
Friday, January:17, and.the employee's statement of' concerns
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~ dated Tuesday, January'21,lit appears.that theiconcerned j
individual may'not.have'known'that;the SCRs had in fact beeno 1
W processed and transmitted.exactlyLas originally written..
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ATTACRMENT D PAGE 6 0F 7 3 3..
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6.
Concern SQM-6-003-006 The facts of this concern are covered fully in the above report
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f or SQM-6-003- 005.
IV.
CONCLUSIONS AND RECOMMENDATIONS
.i A.
C.onclusions
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1
'1.
Conecen SQM-6-003-001.
The employee's concern was substantiated.
2.
Concern'SQM-6-003-002.
The employee's concern was substantiated.
.'3. ' Concern SQM-6-003-003.. The employee's concern was substantiated.
'4.
. Concern SQM-6-003-004.
The employee's. concern was substantiated.
'i The. facts of.the employee's concern were
.5.
Concern SQM-6-003-005...
not substantiated.
1 6.'
Concern SQM-6-003-006.
The facts.cf he employee's concern were j
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not substantiated.
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- B.
Recommendations
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? pin None. The[ applicable' concerns have been documented for analysis and-
'TGY corrective ~ action by SCRs. SQN SQP86011En, SQN SQP8602' RO, and
'j SQN SQP8603 RO, all. dated January 11,'1986.
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' ATTACHMENT'D
' PAGE 7 0F 7-y.3 -
DOCUMENTS REVIEWED IN' INVESTICATION I-86-180-SQN AND REFERENCES.
i Nucicar Quality Assurance Manual (NQAM), Part III, Section 1.'1." Document'
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Control." Revision March 21,'1985
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2.
office of 1.agineering Procedure OEP-08'RO,'" Design Output" N 3. ' Sequoyah Nuclear. Plant. Administrative Instruction-SQNP AI-25 R12. " Drawing ~
control After Unit Licensing"
- 4.
Drawing Management System Report dated February 7, 1986, " Drawings Affected by ECN/FCE*!-(for EOU L6027).
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5.
Tracking and Reportirig of 'Open Items (TROI) Report dated ' February 1,1986 -
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\\ 6.. Significant Condition Reports (SCRs) SQN.SQP8601,. 8602, 8603 (ali RO)-
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l ATTACIOiENT E PAGE 1 0F 7 1
TENNESSCE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSES I!TVESTICATION REPORT NO. I-86-185-SQN EMPLOYEE CONCERN T M
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SQH-6-002-005 SQM-6-002-006 V SEQUOYAH NUCLEAR PLANT VENDOR DRAWING CONTROL
SUBJECT:
DATES OF FEBRUARY 12-13 and 19-20, 1986 INVESTICATION:
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-Yr HEVIEWED EY:
DATE M/ A-( KOLTOWICH APPROVED BY:
DATE W. D.
S*' EVENS i
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I, BACKCROUND' A Nucicar Safety Review Staff (NSRS) investigation was conducted to-detemine the. validity of expressed employee concerns received by the The-Quality Technology Company (QTC)/ Employee Response Team.(ERT).
concerns of record, as summarized on the Employee Concern Assignment-j g
through -006, Request Form from QTC and identifled as SQM-6-002-002 stated:
SOM-6-002-002' Specific supervision is not responsive to correcting a quality problem in a timely manner which can and is '
af f ecting the qualityl of. the plant.
(Names / details known to QTC, withheld.toimaintain confidentiality.)
No further information may.be released; : Nuclear Power CI has no further information.,
-concern.
QTC. Clarification:, The office. supervisor.for the.SQN Engineering Project was asked by the. employee to have a -
vendor. drawing audit conducted in 1985:-but'no audit was' performed.
.SOM-6-002-003 Specific. supervision has neglected to perform a
(,3767r' dh scheduled assi'gnment which results in a continuous-E quality impact on the plant.
(Names / details known to QTC, withheld to maintain confidentiality.)' Nuclear No further information'may be Power concern.
released.
CI has no.further information.-
QTC Clarification:
An audit of vendor drawings was to-have been performed in September 1985 : af ter ~a TVA drawing audit, but the vender audit was' cancelled'..
SOM-6-002-004-Specific supervision. stopped. corrective action on a
' quality problem that.had been identified months
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earlier.
(Names / details'known to QTC, withheld to maintain-confidentiality.); No further infornation may be released.,.Euclear. Power concern. [CI has noLfurther
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information.
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QTC Clarification:. Supervisor denied'a: written request' submitted by. employee'on January 9,.1986,:to perform a-vendor drawing' audit.
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..- SOM-6-002-005 i
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I Controlled documents.contain conflicting' data relating f
to the same installation. - (Nanies/ details. knoM to QTC,
'No further j
withheld to' maintain confidentiality;)
j information may be released.. Nuclear. Power concern 4 J
CI has no further information.
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QTC Clarification:
Applies ~to, design; drawings-mylars.
.l Check wash-off. log for specifics.
Better controls-are eeded for-the original mylars.
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. " -=SOM-6-002-006*
Work is being. performed to' documents.containing conflicting or obsolete' data. -(Names / details:known to No further :
'QTC. withheld to maintain. confidentiality.):
information may be released.
Nuclear Power concern.
CI-has no further information.
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QTC Clarification: -Concern is.. based on programmatic
' problems that both a new mylar and eld may exist with; 1
each containing different data.
1 II.
Scope,
s The scope of this investigation was' determined fecm the stated' concerns of record and the respective QTC clarifications to be that A.
of only the specific. concerns contained in the' stated.QTC clarifi,
cations.
To accomplish this inve tigation, NSRS reviewed applicable require -
B.
ments,' procedures, drawings, drawing logs,. and correspondence.
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Additionally, responsible drawing control.and repregraphics personnel were contacted to discuss t.he employee's concerns.
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III. SUMMAEI CF TINDINOS,
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'l A.
Requirements and Co=mitments 1.- Division of Engineering Design Management'andsEngineering Data Systems (MEDS) Procedure HP ' 23.CS, "EN DES and. Vendor Drawings T -'
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' "The TIC does not maintain pre-1975
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Information. Services."
original vendor drrawings unless they have 'been placed.under TVA1 l
revision control and sent' to TIC for storage. : All other vender-originals which were submitted ' to the TIC prior ~ to 1975; have
'j been or are being' microfilmed andLdestroyed."
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Of fice. of Engineering Of fice Instruction OE-01 3001, " Drawing Originals - Checking Out and' Checking in."
B.
Findings 1.
Concerns SQM-6-002-002 and SQM-6-002-003 The Office Supervisor for the Sequoyah Nuclear Plant.(SQN) i Engineering Project came to the position in January _1985.
He stated that' drawing controls at that time for both the TVA and vendor drawings were not fully adequate;:that' original drawings J
for SQN design work were not'always-immediately available as 1
needed;'and that first priorities for correction were placed on' the TVA drawings and on'several other critical matters affecting.
the SQN' engineering designLeffort..The vendor drawings received f
a second priority. The immediate' supervisor verified to NSRST that this, statement of priorities. represented'the management priorities at that time.
In order to. verify that all TVA drawings;were available and to correct any deficiencias by reordering replacements.(washoffs),
a TVA, drawing audit was ionducted during September'-October 1985. The office Supervisor verified the' employee's statement that an audit of vendor drawings-was-.to have been performed at the eenclusion of the TVA drawing audit.. He stated that the'
+$C M6 vendor drawing audit was postponed from October 1985 to January-i 1986 because staff was needed on other projects, butlthat the j
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Y' audit was begun in ~ January and, had' been in process l f or three j
weeks.
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In order to r.aintain a dated listing of all replacement drawings requested from Office of. Engineering Enoxville, a washoff. log was initiated.by the SQN Office Supe _rvisor on August 1, 1985. ~
The leg included 240 entries at the time of the investigation 1n.
February 1986.- Of thesa, approximately 220--over. 90 ' percent of
- j th^ ietal--were f or replacement. vender ~ drawings with the remainder being for.~VA drawings.s 1The,further investigation of.- H these orders is reported below under finding No. 3.
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-3 2.
Concern SQM...s.. 002-004 6
It was verified that the' e.:ployee submitted a written request
__.__ dated January-93.1986, requesting; overtime on1several weekdays; j
and a Saturday to set up contract files..and audit **B" size TVA drawings. This. rei;uest was denied by the supervisor in a fem l
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-TVA ASD memorandum also: dated.'. January 9, 1986'.'.Theisupervis'or stated-in the memorandum.that he" wanted to' work with.the employee with regards to: contract drawings' and noted that' "...
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we have.real problems with. manufacture drawing originals."
wrote that, "I' currently am' working on'other clerical. items with l
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deadlines and ennnnt work with (the employee)..... I am well aware of us being deficient as far as an audit is concerned but
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ATTACHMENT.E PACE 5 0F 7 l.
we have.been deficient since I. arrived in January 1985.
I don't; feel another two. weeks is going to-be that critical to us."
t,ater that same: month, the vendor drawing audit and corrective action activities were started and were in their third week at the time of this investigation.
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3.
Concerns SQM-6-002-005~and: SQM-6-002-006
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At the time a drawing. original is determined.to have been' lost, a replacement original ("washoff") is requested from the Office of Engineering, Knoxville.
The washoffs are produced fromithe'-
microfilm aperture cards-maintained by the-Technical ~1nformation Center.
As noted'above, approximately 240 washoffs were.
requested between August'1, 1985, and February 1986, with over 90 percent:of' the replacements being for. vendor drawings. The.-
OE Reprographics Supervisor stated that because the vendor drawing originals before 1976'were routinely discarded, there is_
a periodic need at the-sites to provide washoffs from the-aperture cards..He-did not believe that;the quantity-of.SQN' requests was unusu'a1.
.He. stated.that;SQN was'the first site to centralize the authority f'o'rlwashoff requests, thus minimizing duplicate or' unnecessary. requests'. He indicated that Knoxville desired similar.. centrali=ation at the.other sites.
Unen a replacement drawing is received'at the Office of..
Engineering SQN site, the replacementtis checked in and becomes s
the' nek " original" which will be'- the" bast.line' drawing f or "
i,kf <.h subsequent changes.. 'If-a missing drawins'should eventually
. reappear and not be properlyJdispositioned, the, potential would exist f or the two " originals" to contain. obsolete 'or conflict-ing data whenever one drawing was updated but;not.the:cther.
The controls which are now in place.to avoid lost and duplicative drawings include the following:
a..
(a) Drawing checkout system:.-Dradings-are'c.hecked out*from the-drawing tanks on a Drawing / print Request Form whichL includes a self-checking section for removal of drawings
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af ter hours if necessary.VIt was. deter =ined that thec Office of Ensinsering' Seetion; heads had keys to the drawingJ,
area for access after,ne.::a1 worki.s hours when drawing control.perscnnel were not present.- Although this provides:
some possibilities for drawings to" stray": af ter hours, the office supervisor did not-b'elieve: this to be any major.
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_ c_ 2_; problem.,He vigorously supported' the; necessity for 24-hour:
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access to the, drawing. originals, demonstrated 2theLease-of.
and stated that' the checkout -
use of the checkout formsr C_ _-.-.e.-
records, were updated. promptly: each morning}from. any forms.
leftduring t e:nish.
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Drawing check-in system: Whenever it is necessary to i
request a replacement for a lost original, a note is placed
- i in the drawing' checkout,fil'e.for any cases where the lost f
original reappears.
Subsequently, if a drawing being checked in is one for which a' replacement had been ordered, J
the document control clerk is flagged to cancel the pJJ replacement order or to withdraw one or the other original from the system.
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(c)
Centralized. ordering of replacements:
As noted above SQN
{
is the first TVA site to. centralize the authority'for washoff requests..OE Reprographics is to deny all requests except those channeled through the authority. The OE 4
Supervisch of-Reprographics stated,th'at'this centralization is helping to eliminate duplicative requests wherein' two or more individuals might order the same replacement.
IV.
CONCLUSIONS AND RECOMMENDATIONS l
A.
Conclusions 1.
Concern SQM-6-002-002..The employee concern for vendor drawing
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controls is substantiated, but the concern for superviso:y responsiveness is not substantiated.. The vendor drawing udit h..g;5 was delayed until,1986.because of'other reasonable priorities.
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The audit is now in progress.'
2.
Concern SQH-6-002-003. The employee concern is not substan-tiated. Supervisory neglect was not identified.
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3.
Concern SQM-6-002-004 The' employee concern is not substan-
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tiated. The superviser denied a request for overtime but did not stop corrective action.. Corrective action is in progress.
The.e=ployee conce:r.s 4.:. Concern SQM-6-002-005 and SQM-6-002-006.'
s..
" for duplicative mylars are' substantiated in that this condition
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does sometimes exist.. *"he concern is =itigated by the finding-ithat several.contrels are in place to u k8ve the condition.
Support was not identified for additional. controls such as further limitation of access to the mylars.
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-q -,:.u..A g. : Raeo=mendations -
7-1 T-86-1ES-SQN-01 Trackim of Co-rective Actien -
+
i Corrective action concerning SQN' vendor, drawing controls is in progress through (1) perf ormance of a vendor drawing ~ audit which' j
began January / February 1986.. and. (2) controlled replacement ;o_f..
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, f7 drawings where needed.. Controls to minimize recurrenca of'dupli-
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.cative mylars have been developed and are in place..There'are no additional' recommendations, but SQN should provide notification,to.-
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'.NSRS when corrective action is completed.
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,,M) w ATTACEMENT E
. PACE 7 0F 7 2
I DOCUMENTS REVIEWED IN INVE::TICA110H I-86-IES-SQN j
AND REFERENCES'
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Offlee of Engineering Office Instruction OE-0I'3001, " Drawing Originals -
1.
Checking Out and Checking In" Division of Engineering Design Management ' and Engine 2.
Services" Of fice of Engineering Of fice Instruction Manual ~ OE-DI 4003, " Prints and.
3.
Microfilm
. Routine Distribution"'
Memorandums S. L. Dodd to John Dennis, and Jack Va$entine dated Janu
. 1986; and Jack W. Valentine to John Dennis dated January 9,1986 4,
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