ML20235U241
| ML20235U241 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/25/1987 |
| From: | Brown W, Cossett D, Gass K TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20235U231 | List: |
| References | |
| SQN-NSRS-1, SQN-NSRS-1-R03, SQN-NSRS-1-R3, NUDOCS 8710130422 | |
| Download: ML20235U241 (18) | |
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TVA EMPLOYEE CONCERN REPORT NUMLER: SQN-NSRS-1 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Subcategory REVISION NUMBER:
3 IITLE:
Review of Nuclear Safety Review Staff PAGE 1 of 8 Restart Items at Sequoyah REASON FOR REVISION:
Revised to incorporate SRP conunents
SUMMARY
STATEMENT: The 8 items in this report were identified by the Nuclear Safety Review Staff.(NSRS) and were assigned to the Employee Concerns Task' Group (ECTG) for verification and closure. The verification activities are described in this report.
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EXECUTIVE
SUMMARY
SQN-NSRS-1 Review of Nuclear Safety Review Staff (NSRS) Open Items Requiring Resolution at Sequoyah Nuclear Plant (SQN) before Unit 2 Restart.
NSRS conducted reviews of activities at Sequoyah Nuclear Plant (SQN) during its span of overview responsibility from 1979 to 1986. NSRS items remaining open in 1987 have been examined by the Employee Concerns Task Group (ECTG).
ECTG examined the status of NSRS issues including those identified specifically for SQN as well as other sites' issues which could have generic applicability at SQN. In all, a total of 95 issues were considered applicable to SQN including 25 requiring' resolution before Unit 2 restart. The status of eight of these restart issues 1s the subject of this SQN-NSRS-1 report, with
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the status of the other 17 restart issues addressed in report SQN-NSRS-2. The remaining 70 issues are considered non-restart items and are addressed in report SQN-NSRS-3.
I The eight issues discussed in this revised report have been closed by ECTG.
These issues include the following:
R-80-05-SQN-4B Configuration Control R-84-19-WBN-01 Clear Identification of Purposes and Uses of All Controlled Documents at All Plants R-84-19-WBN-07 Development of Criteria for Cable Tray Fill Level and QC Inspection R-85-02-SQN/WBN-2 Maintenance, Operating, and Test Instruction I-85-06-WBN-01 The Adequacy of the Dispositions for Identified Cable Bend Radius Problems I-85-06-WBN-02 The Adequacy of the Program for Cable Pulling Activities I-85-06-WBN-05 Development of Established and Documented Limited QA Program and Failure to Incorporate the Established Limited QA Program Into Nuclear Quality Assurance Manual (NQAM)
R-86-01-SQN-01 Improvements in Overall As Low as Reasonably Achievable (ALARA) Program.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM FRONT MATTER REV:
3 PAGE f OF v113 Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (T7A).
The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986.
Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns. Each of the concerns was a formal, written description of a circumstance or circumstances that an j
employee thought was unsafe, unjust, inefficient, or inappropriate.
The 4
mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, j
the NRC, and the general public. The results of these investigations are communicated by four levels of ECSP reports:
element, subcategory, category, and final.
Element reports, the lowest reporting level, will be published only for 1
those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2.
An element consists of one or more closely related issues. An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns. For efficient handling, what appeared to be similar concerns were grouped i
into elements early in the program, but issue definitions emerged from l
the evaluation process itself. Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
However, the subcategory report does more than collect element level evaluations. The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level. This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
l To make the subcategory reports easier to understand, three items have i
been placed at the front of each report:
a preface, a glossary of the i
terminology unique to ECSP reports, and a list of acronyms.
Additionally, at the end of each subcategory report will be a Subcategory Summary Table that includes the concern numbers; identifies other subcategories that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM FRONT MATTER REV:
2 PAGE 11 0F vili The subcategories are themselves summarized in a series of eight category reports.
Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial safety construction material control operations q
1 quality assurance / quality control f
i welding
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engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP, including the Inspector General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual. The Manual spells out the program's objectives, scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and closecut of the issues raised by employee concerns.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS--
SPECIAL PROGRAM FRONT MATTER REV:
2 PAGE 111 0F vili ECSP GLOSSARY OF REPORT TERMSt classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A:
Issue cannot be verified as factual Class B: Issue is factually accurate, but what is described is not a problem (i.e., not a condition requiring corrective action)
Class C: Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D: Issue is factual and presents a problem for which corrective action has been, or is being, taken as a result of an evaluation Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
collective significance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see " employee concern")
corrective action steps taken to'fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.
eriterion (plural:
criteria) a basis for defining a performance, behavior, or quality which ONP imposes on itself (see niso " requirement"),
element or element report an optional level of ECSP report, below the subcategory level, that deals with one or more issues.
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employee concern a formal, written description of a' circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM FRONT MATTER REV:
2 PAGE iv 0F vill _
l evaluator (s) the individual (s) assigned the responsibility to assess a specific grouping of employee concerns.
findinr,s includes both statements.of fact and the judgments made about those-j facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during'the evaluation process, raised in one or more concerns.
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I K-form (see " employee concern")
reautrement a standard of performance, behavior, or quality on which an
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evaluation judgment or decision may be based.
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i root cause the underlying reason for a problem.
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- Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear j
safety-related, unreviewed safety-significant question).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE v 0F viii Acronyms AI Administrative Instruction AISC American Institute of Steel Construction ALARA As Low As Reasonably Achievable ANS American Nuclear Society ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials AWS American Welding Society BFN Browns Ferry Nuclear Plant l
BLN Bellefonte Nuclear Plant CAQ Condition Adverse to Quality CAR Corrective Action Report CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual CMTR Certified Material Test Report COC Certific. ate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU CON)
TVA EMPLOYEE CONCERNS' REPORT NUMBER:
SQN-NSRS-1 SPECIAL PROGRAM-FRONT MATTER REV:
2 PAGE vi 0F viii DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DNT Division.of Nuclear Training DOE Department of Energy DP0 Division Personnel Officer DR Discrepancy Report or Deviation Report ECN' Engineering Change Notice ECP Employee Concerns Program ECP-SR Employee Concerns Program-Site Representative ECSP Employee Concerns Special Program ECTG Employee Concerns Task Group EEOC Equal Employment Opportunity Commission
.EQ Environmental Qualification EMRT Emergency Medical Response Team EN DES Engineering Design ERT Employee Response Team or Emergency Response Team FCR Field Change Request FSAR Final Safety Analysis Report FY Fiscal Year GET General Employee Training HCI Hazard Control Instruction HVAC
!! eating Ventilating Air Conditioning II-Installation Instruction INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice j
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE vii 0F vili L/R Labor Relations Staff M&AI
- Modifications and Additions Instruction.
MI Maintenance Instruction MSPB Merit Systems Protection Board MT Magnetic Particle Testing NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission NSB Nuclear Services Branch NSRS Nuclear Safety Review Staff 1
NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC)
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NUMARC Nuclear Utility Management and Resources Committee OSHA Occupational-Safety and Health Administration (or Act)
ONP Office of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record 1
PT Liquid Penetrant Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality Control QCI Quality Control Instruction
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS-1 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE viii 0F vill' QCP-Quality Control Procedure j
QTC
- Quality Technology Company
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RIF-Reduction.in Force RT Radiographic Testing SQN Sequoyah Nuclear Plant SI Surveillance Instruction J
SOP Standard Operating Procedure i
SRP.
Senior. Review Panel l
SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff j
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T&L Trades and Labor TVA Tennessee Valley Authority TVILC Tennessee Valley Trades and Labor Council UT Ultrasonic Testing VT Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant WR Work Request or Work Rules WP Workplans i
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TENNESSEE VALLEY AUTHORITY l
SEQUOYAH NUCLEAR PLANT
' EMPLOYEE CONCERNS TASK GROUP 1
OTHER SITES CEG i
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-I subcategory:
Sequoyah Nuclear Plant - NSRS Classical Items Review of Nuclear Safety Review Staff.
Restart Items At Sequoyah Report Number:
SQN-NSRS-1 Revision 3
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.l TVA EMPLOYEE CONCERNS REPORI NUMBER: SQN-NSRS-1 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 2 of 8 Review of Nuclear Safety Review Staff (NSRS) Open Items Requiring Resolution at Sequoyah Nuclear Plant (SQN) before Unit 2 Restart.
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I.
. INTRODUCTION NSRS conducted reviews of activities at Sequoyah Nuclear Plant (SQN) during its span of overview responsibility from 1979 to 1986. NSRS items remaining open in 1987 have been. examined by the Employee Concerns Task Group (ECTG).
ECTG examined the status of NSRS issues including those identified l
specifically for SQN as well as other sites' issues which could have j
generic applicability at SQN. In all, a total of 95 issues were considered applicable to SQN including 25 requiring resolution before unit 2 restart. The status of eight of these restart issues is the subject of this SQN-NSRS-1 report, with the status of the other 17 restart issues addressed in report SQN-NSRS-2.
The remaining 70 issues are considered non-restart items and are addressed in report SQN-NSRS-3.
The eight issues discussed in this revised report have been closed by ECTG. Full details concerning the investigation and examination of the items were provided earlier by report SQN-NSRS-1, Revision 1 and 2.
Some associated activities or areas related to the items may in fact still be incomplete. However, these NSRS items are considered closed because ECTG, through the evaluation process, determined that sufficient resources have j
been committed to the issues to ensure their satisfactory completion and j
closure. This confidence is derived from interviews with cognizant TVA j
personnel and reviews of applicable documentation.
The status of the eight NSRS restart issues for SQN is as follows:
1 Closed R-80-05-SQN-4B Configuration Control l
Closed R-84-19-WBN-01 Clear Identification of Purposes and Uses I
of All Controlled Documents at All Plants l
Closed R-84-19-WBN-07 Development of Criteria for Cable Tray Fill Level and QC Inspection i
Closed R-85-02-SQN/WBN-2 Maintenance Operating, and Test Instruction Closed I-85-06-WBN-01 The Adequacy of the Dispositions for Identified Cable Bend Radius Problems Closed I-85-06-WBN-02 The Adequacy of the Program for Cable Pulling Activities A
I TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS-1
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SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 3 0F 8 Closed I-85-06-WBN-05 Development of Established and Documented i
Limited QA Program and Failure to Incorporate the Established Limited QA Program Into Nuclear Quality Assurance j
Manual (NQAM)
Closed R-86-01-SQN-01 Improvements in Overall As Low as Reasonably Achievable (ALARA) Proijram.
II. Verification of NSRS Open Items Closed R-80-05-SQN-048, Configuration Control In the original review dated June 1980, NSRS concluded from electrical deficiencies found, that configuration control was inadequate and made the following recommendation:
Revise the existing Configuration Control Program including appropriate instructions to require more frequent and indepth inspections such that the entire plant has been inspected each refueling cycle.
ECTG has monitored the progress of this issue since August 1986 to verify that walkdowns have been performed and completed.
ECTG has concluded that resources and commitments are dedicated toward this effort.
Interviews with ECTG and DNE personnel from SQN, and a review of the P-2 schedule (Run 14, July 87, 22:34) confirm that the Design Base Verification Project is scheduled for closure in September 1987.
In addition, this issue is also being addressed by the Sequoyah Nuclear Performance Plan (NPP), Sequoyah Action List (SAL) Number 101.
A Corrective Action Plan (CAP) has been submitted by DNE/0NP in response
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to CATD 201.01 SQN 01.
ECTG concludes this CAP provides a satisfactory solution to this issue.
This NSRS issue is closed at SQN.
Closed R-84-19-WBN-01, Clear Identification of Purpose and Use of All Controlled Documents at All Plants
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In the original review, NSRS identified the following situation:
Controlled documents are not clearly identified for all plants.
The
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purposes and uses for each of the documents have not been delineated.
Information contained in documents designated to be controlled has not been assessed for contribution to the intended purpose and use.
The NSRS also referenced an instance at WBN where logic and control drawings in the control room did not agree with electrical drawings and termination lists.
This was determined to be generic to SQN.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS-1 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 4 0F 8 The NSRS recommended that unnecessary information in controlled documents should be deleted and discrepancies in documents with overlapping information should be corrected. The SQN plant position on the logic drawings from the 1984 time period until the present time has been that the logic drawings at SQN are not regarded as controlled documents.
The SQN Site Director stated in a memorandum dated September 12, 1984 (SQP-840913 002) that "0NP (Office of Nuclear Power) recognized that the logic prints were not properly controlled.
Electrical prints were used for actual equipment operation.
This negated the safety impact of the discrepancies between the logic prints and electrical prints."
ECTG's investigation at SQN determined the following:
R3 The electrical prints at SQN are controlled for work purposes; the logic drawings are not regarded as controlled documents and ha.
_,een i
removed from the control room.
In accordance with SQN document control procedures, the SQN logic drawings are labeled "For Information Only" to indicate they are not 4
controlled at a level for work activities.
l Based on the above verification activities, ECTG concludes that the identification of purpose for the logic and control drawings has been i
accomplished at least to an acceptable level.
This item is closed.
Closed R-84-19-WBN-07, Development of Criteria for Cable Tray Fill Level and QC Inspections In the original review at HBN, NSRS concluded that criteria should be developed for field use to control actual cable tray fill levels and to
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provide a basis for Quality Control (QC) inspection.
A feedback system should be included from the construction forces pulling cable, to the designers routing cable, to avoid the overfill problems to date.
ECTG's generic review of the item found it potentially applicable to SQN.
A computerized system was being used to route cables and to limit the fill in the cable trays.
Although this system was used to assist and to l
document what was actually accomplished in the field, the computer system j
could not be used as a final acceptance vehicle without some verification of what existed in the field.
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The SQN corrective action for this issue was identified in the SQN Nuclear j
l Performance Plan as Action Item No. 657.
The cable tray fill criteria is I
provided in SQEP-06 (Revision 2, June 18, 1987).
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ECTG concludes, based on applicable procedures, that this NSRS issue is closed.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 5 of 8 Closed R-85-02-SQN/WBN-02, Maintenance. Operatinr, and Test Instruction In the original review, NSRS concluded that SQN instructions were not sufficiently clear and did not include sufficient precautions and other measures to preclude degradation of the high-pressure seals. The NSRS recommended that some of the Special Maintenance Instructions relating to thimble tubes be reviewed / revised and that the primary system pressure not be increased while the thimole tubes are disconnected from the overhead path transfer system.
The latter recommendation was intended to preclude the ejection of a thimble tube in the event of failure of a high pressure seal.
The original report details were reviewed to determine all of the specific l
recommendations made following the thimble tube event.
Instructions l
SMI-0-94-3, MI-1.9. 1.10, and 1.11 were reviewed for adequacy, compared I
with the original review recommendations, and found acceptable.
IR3 Interviews were held with cognizant personnel to verify that the level of I
understanding and the " lessons learned" as a result of the incident were I
also acceptable.
I ECTG concludes this issue has been satisfactorily addressed and is now closed.
Closed I-85-06-WBN-01, The Adequacy of the Dispositions For Identified Cable Bend Radius Problems In the original review at Wetts Bar, NSRS investigators determined that there was not sufficient manufacturers' documentation / justification / test data nor Office of Engineering (OE) basis to substantiate the final j
dispositions documented for Nonconformance Reports (NCRs) or establishment l
of Minimum Training Radius (RImin) values for multiconductor cables.
The available information, as well as the acceptance criteria for sampling used to justify the as-installed conditions, lacked engineering support.
The report stated that Office of Construction (OC) was permitted by OE to bend the cables permanently to a radius of one-half of values which in 1981 were recognized to be an industry standard for minimum values to which a cable can be permanently bent.
Although OE and OC's final disposition accepted the installed condition of these cables at WBN based on "0E/0C developed" values, NSRS questioned the validity of these values. Following review for generic applicability, ECTG also initiated review of this issue at SQN.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 6 of 8 NSRS recommended that OE should establish values for RTmin, as well es Minimum Pulling Radius (R min.) that are fully supported by P
manufacturers' test data. A sample size should be selected at WBN unit 1 for class IE cables, then a controlled inspection conducted based on fully supported R min and R min values, and the result used to support the P
T adequacy of as-installed cables.
If evaluation of the results of the sampling program failed to adequately justify the as-installed conditions, then the development of a formal in-service / inspection program should be considered.
In addition to ECTG's investigation, the cable bend radius issue was also the subject of an extensive evaluation by ECTG's Construction Evaluation j
Group (CEG) in Report 10900. This report concurred with the finding _of the NSRS report and issued CATD 10900-NPS-01 which identified minimum band radius deficiencies.
In response-to the NSRS and ECTG findings, an evaluation by Electrical Engineering Branch (EEB) to determine the adequacy of Class 1E cable which does not meet minimum bend radius 1
requirements was initiated.
This activity is being performed under Significant Condition Report (SCR)
SQNEEB8703. Discussions with EEB personnel at SQN indicated that the bend radius portion of the SCR has been resolved. The SCR is still open pending resolution of other cable issues. This issue is also being addressed by the Seguoyah Performance Plan, Sequoyah Action List (SAL),
Number 657. Based on the fact that ECTG CATD 10900-NPS-01 and SCREEB8703 are tracking this issue at SQN, this NSRS issue is closed.
Closed I-85-06-WBN-02, The Adequacy of the Program for Cable Pulling Activities In the July 1985 report, NSRS concluded that Office of Engineering (OE) and Office of Construction (OC) cable pulling programs were inadequate and j
in violation of the accepted industry standards and practices. The report stated that Construction Specification G-38 had not defined the need for calculating maximum allowable tension for multicable pulls nor had it established the method of. pulling multicables by utilizing a break link.
Also, the industry considered the side wall pressure as a limiting factor for cable pulling activities.
Failure to ensure that maximum allowable tension, as well as sidewall pressure, was not exceeded in any cable pulling operation increased the potential for cable damage (insulation degradation).
ECTG's generic review of the issue found it potentially applicable to SQN.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 7 of 8 NSRS recommended that OE management should review G-38 and G-40 to incorporate resolutions to the identified problems. Subsequently, WBN OE, 00, and Office of Nuclear Power (ONP) management should revise the relevant OE documents as well as OC and ONP procedures. The final adequacy of the present cable installation should then be evaluated according to revised acceptance criteria. A sampling approach should be considered.
If evaluation of the result of the sampling program failed to adequately justify the ar-installed conditions, then development of an in-service inspection program should be considered.
The NSRS cable pu211ng issues were also the subject of an extensive l
evaluation by ECTO's Construction Category Evaluation Group (CEG) in l
Report 10900. This report concurred with the finding of the NSRS report l
and issued CATD 10900-NPS-01 which identified deficiencies with maximum l
In lR3 pull tension as well cs sidewall pressure and minimum bend radius.
l response to the NSRS and ECTG findings, an evaluation by Electrical Engineering Branch (EEB) to determine the adequacy of Class IE cable l
was initiated. This activity is being performed under SCR SQNEEB8703.
l Discussions with EEB personnel at SQN indicated that the bend radius l
portion of the Significant Condition Report (SCR) has been resolved.
The SCR is still open pending resolution of the other cable pulling issues. This issue is also being addressed by the Sequoyah Performance Plan, Sequoyah Action List (SAL), Number 657. Based on the fact that ECTG CATD 10900-NPS-01 and SCREEB8703 are tracting this issue at SQN, this NSRS issue is closed.
Closed I-85-06-WBN-05, Development of Established and Documented Limited QA Program and Failure to Incorporate The Established Limited 0A Program Into NOAM In the original review at WBN, NSRS concluded that implementation of the limited QA program, as established in The Office of Engineering Design and Construction (OEDC) instruction OEDC-PRM-QAI-2, was inadequate. Also, the Nuclear Quality Assurance Manual (NQAM) was determined to be inadequate in addressing the limited QA program as established by the superseded OEDC-PRM-QAI-2, document.
NSRS recommended that the Division of Quality Assurance (DQA) should identify the required "special controls' applicable to systems previously identified as " limited QA" in the NQAM.
The NSRS further concluded that appropriate line organizations should incorporate those requirements into the Division of Nuclear Engineering (DNE )
Division of Nuclear Construction (DNC ) and Office of Nuclear Power (ONP) procedures for implementation by the appropriate offices.
In view of the fact that WBN had recognized security and fire protection as the only two systems for limited QA consideration, DNE should perform an evaluation to ascertain the impact of not implementing the established " limited QA" program on the other systems identified in OEDC-PRM-QAI-2.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-1 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 8 of 8 The ECTG investigation found that NQAM I, Section 1.2, Rev. 1, contains a
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revised description of the limited QA program and specifies the i
requirements LLat are imposed on the 13 features and programs to which
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limited QA applies. These requirements are implemented at SQN by Standard Practice SQA-189.
SQA-189 defines which control elements (l.c. design control, training, d
inspections, and testing) are applicable to each feature or program and lists the instructions that implement the requirements. A comparison of NQAM I, Section 1.3 and SQA-189 revealed that the standard practice adequately supports the NQAM.
1 ECTG concludes this NSRS issue has been satisfactorily addressed and is closed.
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Closed R-86-01-SQN-01, Improvements in Overall As Low As a
Reasonably Achievable (ALARA) Program In the original review reported in I-84-12-SQN-13, NSRS recommended that it be emphasized to plant employees that preplanning as specified in Radiation Control Instruction RCI-10 must be accomplished. During the February 1986 follow-up, NSRS determined that sufficient corrective action had been taken to satisfy the NSRS open item. 'dowever, discussions with the Health Physics section staff, ALARA engineer, and review of documentation led tho NSRS reviewer to conclude that additional specific actions should be taken to strengthen the ALARA program at SQN.
The ECTG investigation revealed that corporate changes identified in the Nuclear Performance Plan, Volume II, have given improvements to the program and increased corporate involvement with the objective to minimize employee exposure and improve regulatory performance.
1 Some changes include the following:
A Radiological Assessor position has been established on the Site Director's Staff.
k The Manager of the Radiological Control Section now reports directly i
to the SQN Plant Manager.
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SQN has implemented a contamination area control program.
Radiological area work is being coordinated between the Health Physics (HP) Shift Supervisor and the Maintenance Department.
An HP Training Officer position has been implemented at SQN.
ECTG concludes, based on their investigation, that this issue has been j
satisfactorily addressed. This NSRS issue is closed at SQN.
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