ML20235U256
| ML20235U256 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/25/1987 |
| From: | Brown W, Gass K, Knightly J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20235U231 | List: |
| References | |
| SQN-NSRS-3, SQN-NSRS-3-R, SQN-NSRS-3-R0, NUDOCS 8710130427 | |
| Download: ML20235U256 (55) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQW-NSRS-3 SPECIAL PROGRAM j
REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER:
0 TITLE: Review of Nuclear Safety Review Stnff PAGE 1 OF 37 Non-Restart Items at Sequoyah v
REASON FOR REVISION:
N/A
\\
SUMMARY
STATEMENT:
lhe 70 non-restart items in this report were identified by the j
Nuclear Safety Review Staff (NSRS) and were assigned to the Employee Concerns Task j
Group (ECTG) for verification and closure.
The verification activities are j
described in thic report.
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EXECUTIVE
SUMMARY
SQN-NSRS-3 Li -
Review of Nuclear Safety Review Staff (NSRS) Non-Restart. Items Requiring
- Resolution at Sequoyah Nuclear Plant (GQN).
NSRS conducted reviews of activities at'Sequoyah Nuclear Plant (SQN)
-during its. span of overview responsibility from 1979 to 1986. _NGRS items remaining open in 1987 have been examined'by the Employeo Concerns _ Task-Group (ECTG).
ECTG examined'the status of open 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 prior to Unit 2 restart. ~The status of these restart issues was the subject of previous reports, ECTG-NSRS-1 and.ECTG-NSRS-2. The status of 70 other issues ordinarily considered as non-restart is the subject of this report, SQN-NSRS-3.
Sixty-four (64) of these 70 issues are closed.
Some associated activities or areas related to the closed 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 been committed to the issues to ensure their satisfactory completion and closure. This confidence is derived from interviews with cognizant TVA personnel and reviews of applicable documentation.
The status of the 70 NSRS non-restart issues for SQN is as follows:
Open 79-09-01-1 Employee Concern Over Excessive Wire Lifting Practices to Facilitate Testing Open 79-09-01-2 Employee Concern Over Excessive Wire Lifting Practices'to Facilitate. Testing Open 79-09-01-3 Employee Concern Over Excessive Wire-Lifting Practices to Facilitate' Testing Closed 79-10-03-01 Concern'for Reliability Closed R-80-10-BFN-01 Unreviewed Safety' Question Determination Closed R-80-10-8FN-IV A Expansion of DPM N73011 i
Closed R-81-02-BFN-01 Develop a TVA Policy Regarding Loss of Safety Function
]
.)
Closed R-81-04-YCN/NPS-01 Level of Safety Review of Yellow Creek
~
j Nuclear Plant (YCN) l Closed R-81-04-YCN/NPS-02 Inadequacies of EP 4.02 l
i a
b Page 1 of 5 t
Closed R-81-08-BFN-08' Increased Scope of_OP QA&A Staff Audit
- Program.-
' Closed R-81 B FN-20 Quality Assurance and Quality' Control of
. Operation Activities
' Closed R-81-08-BFN-41 QA&A Staff Closed R-81-14-0EDC(BLN)-32 Inadequate Storage of. Audit. Support Records Open R-81-14-0EDC(BLN)-41 QAB Auditor Training Closed R-82-08-NPS-01 Requirements /Needs/ Activities Matrix Closed R-82-08-NnS-02 Quality Assurance Program For Chemistry Activities Closed R-82-08-NPS-03 Chemistry Program Organization and
. Responsibility Review Closed R-82-08-NPS-04 Procedura'l Controls.for Conducting,
Safety / Quality Affecting Activities Within the Chemical Engineering Group (CEG)
Closed R-82-08-NPS-05 Program Improvement Closed R-82-08-NPS-06 Internal Review and Feedback Process Closed R-82-08-NPS-07 Verification of Onsite Radiochemical Laboratory Analyst (RLA) Training Closed R-82-08-NPS-09 Integrated Calibration and Chemical Program Development Closed R-83-08-BLN-02 Development of Cleaning / Flushing Program Control Procedures Closed R-83-08-BLN-05
_ Approval of the 1/8-inch Variance for Acceptable Purge Dam Residual Particle Size Closed I-83-13-NPS-1.a Quality Engineering Branch (QEB) Records Closed I-83-13-NPS-1.b Quality Engineering Branch Records Closed I-83-13-NPS-1,d Quality Engineering Branch Records Closed I-83-13-NPS-02 Quality Engineering Branch Records Closed R-83-18-NPS-01 Management of the Reorganization of TVA
~
Radiation. Protection and Radiological Emergency Planning Program Page 2 of 5
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.I Clored R-83-18-NPS-02' Office of Nuclear Power Program and Licensing Documents i
' Closed R-83-18-NPS-03 Organizational' Emphasis o'f ONP Radiation' j
'l Protection and Radiological Emergency.
I Preparedness Programs.
\\
Cltsed -R-83-18-NPS-04' Organizational Placement of Health Physics at Nuclear Plants Cloted R-83-18-NPS-05 Health Physics Technical Staff Onsite Closed R-83-18-NPS-06 Radiological Health Staff (RHS) Technical Support Closec R-84-05-WBN-14
. Inspector Certification Records s
1 Closed R-84-17-NPS-01A-The Procurement System is too Cumbersome J
~
and Not Well'Known by the Users
]
Closed R-84-17-NPS-018 The Procurement System is'too' Cumbersome and Not Well Known.by.the Users Closed F-84-17-NPS-01C Tne Procurement System is too. Cumbersome and Not Well Known by the Users.
Closed R-84-17-NPS-010 The Procurement System is too Cumbersome and Not Well Known by the Users Closed R-t14-17-NPS-03 Excessive Review of Request for Deliveries (RDs) On Indefinite Quantity Term (1QT)
Contracts Closed R-84-17-NPS Insufficient Documentation for Transferred Material i
l j
Closed R-84-17-NPS-06 BFN Power Stores Clerks Not Trained to l
.InspectLMaterial
]
l Closed R-84-17-NPS-07 Material With Limited Shelf Life Not l
Reordered in a Timely Manner.
Closed R-84-17-NPS-08 Materials Management System (MAMS)
Under-utilized Closed R-84-17-NPS-09 10 CFR Part 21 Requirements Incorrectly Linked to Nuclear Power QA Requirements Page 3 of 5
.)
Closed I-84-31-BFN-01 Investigation of Potential Significant Events Closed I-8 4 D FN- 02 Interpretation of Regulatory Requirements Closed I-84-31-BFN-03 Interpretation of Regulatory Requirements Closed I-84-31-BFN-04 Commitment to Procedural Controls Closed R-84-32-NPS-01 Inadequate TVA Quality Program Open I-84-33-BFN-07 Piping Analysis Closed I-84-33-BFN-08 Failure of QA to Perform Audits and Surveillance of Identified Problem Areas within Piping Analysis Sections Closed I-84-34-SQN-01 Failure to Follow QA Procedures by an Individual at SQN Closed I-84-34-SQN-02 Completion of TVA Mark Letter Description on the Transfer Requisition Documents Closed I-85-06-WBN-04 Timely and Responsive Corrective Actions for Resolution of Identified Problems 1
Open R-85-07-NPS-01 Manager of Power a..d Engineering Appointment of a Records Manager Fourteen Safoquards Items Closed R-82-01-PSS-01 Authorities and Responsibilities Not Clearly Defined in Writing Closed R-82-01-PSS-02 Procedure for Functioning of Branch Staff Not Defined in Writing Closed R-82-01-PSS-03 Expectations of PSS Management Not Defined in Writing Closed R-82-01-PSS-04.B.1 Lack of Guidance and Support to Field Staffs Closed R-82-01-PSS-04.B.2 Lack of Guidance and Support to Field Staffs Closed R-82-01-PSS-04.C.1 Lack of Guidance and Support to Field Staffs Closed R-82-01-PSS-05 Internal and External Interfaces Not Well Defined Closed R-82-01-PSS-011 Lack of Document Control Page 4 of 5 I
Cloged R-82-01-PSS-12 T&Q Implementing Instruction Closed R-8 2 PSS-13 Material Revisions - Material Review and Approval Closed R-82-01-PSS-15 Site Security Organization - Administration Responsibilities and Authority Not Clearly Defined Closed R-82-01-PSS-24 Bellefonte Security Facilities Tracking System Closed R-8 3-16 -NPS-01 Revision of the Safeguards Information Closed R-84-06-NPS-01 Revision of the Safeguards Information I
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1 Page 5 of 5
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' TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR. PLANT EMPLOYEE CONCERNS TASK GROUP-OTHER SITES-CEG 1
l Subcategory :
Sequoyah Nuclear Plant - NSRS C'wssical Items Element:
Review of Nuclear Safety Review Staff Non-Restart Items At Sequoyah Revision:
0 1
8'[M/S 7 Prepared By o
u Date Reviewed By If R.26 h7 Date Reviewed By f/f/
Approved By h
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1
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS-3 SPECIAL PROGRAM REVISION NUMBER.:
0 PAGE 2 0F 37 Review of Nuclear Safety Review Staff (NSRS) Non-Restart Items Requiring Resolution at Sequoyah Nuclear Plant (SQN).
I.
Introduction NSRS conducted reviews of activities at Sequoyah Nuclear Plant (SQN)
NSRS items during its span of overview responsibility from 1979 to 1986.
remaining open'in 1987 have been examined by the Employee Concerns Task Group (ECTG).
ECTG examined the status of open 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 prior to.
Unit 2 restart. The status of these restart issues was the subject of previous reports, ECTG-NSRS-1 and ECTG-NSRS-2. The status of 70 other issues ordinarily considered as non-restart is the subject of this report, SQN-NSRS-3.
Sixty-four (64) of these 70 issues are closed.
Some associated activities or areas related.to the closed' items may in fact still be incomplete.
However, these NSRS items are considered closed i
because ECTG, through the evaluation process, determined.that sufficient resources have been committed to the issues to ensure their satisfactory completion and closure. This confidence is derived from interviews with
~ cognizant TVA personnel and reviews of applicable documentation.
The status of the 70 NSRS non-restart-issues for SQN is as follows:
Open 79-09-01-1 Employee Concern Over Excessive Wire Lifting Practices to Facilitate Testing Open 79-09-01-2 Employee Concern over Excessive Wire j
Lifting Practices to Facilitate Testing Open 79-09-01-3 Employee Concern Over Excessive Wire Lifting Practices to Facilitate Testing Closed 79-10-03.01 Concern for Reliability Closed R-80-10-BFN-01 Unreviewed Safety Question Determination Closed R-80-10-DFN-IV A Expansion of DPM N73011 l
Closed R-81-02-BFN-01 Develop a TVA Policy'Regarding Loss of.
]
Safety Function Closed R-81-04-YCN/NPS-01 Level of Safety Review of Yellow Creek Nuclear Plant (YCN) l Closed R-81-04-YCN/NPS-02.
Inadequacies of EP 4.02
~
TVA cMPLOYEE CONCERNS REPORT NUMBER: 'SQN-NSRS-3 GPECIAL PROGRAM REVISION NUMBER: O PAGE'3 0F 37 Closed R-81-08-BFN-08
' Increased Scope of OP QA&A Staff Audit-
- Program, i'
Closed R-81 B FN-20 Quality Assurance and Quality Control of Operation Activities Closed R-81-08-BFN-41 QA&A Staff Closed R-81-14-0EDC(BLN)-32 Inadequate Storage of Audit Support Records Open R-81-14-OEDC(BLN)-41 QAB Auditor Treining l
l Closed R-82-08-NPS-01 Requirements /Needs/ Activities Matrix l
Closed R-82-08-NPS-02 Quality Assurance Program For Chemistry l
Activities Closed R-82-08-NPS-03 Chemistry Program Organization and l
Responsibility Review l
l Closed R-82-08-NPS-04 Procedural Controls for. Conducting Safety / Quality'Affecting Activities Within the Chemical Engineering Group (CEG)
Closed R-82-08-NPS-05 Program Improvement Closed R--82-08-NPS-06 Internal Review and Feedback Process Closed R-82-08-NPS-07 Verification of Onsite Radiochemical Laboratory Analyst (RLA) Training-Closed R-82-08-NPS-09 Integrated Calibration and Chemical Program Development l
a closed R-83-08-BLN-02 Development of Cleaning / Flushing Program Control Procedures Closed R-83-08-BLN-05 Approval of.the 1/8-inch Varjance for Acceptable Purge Dam Residual Particle Size q
Closed I-83-13-NPS-1.a Quality Engineering Branch (QEB) Records Closed I-83-13-NPS-1.b Quality Engineering Branch Records Closed I-83-13-NPS-1.d Quality Engineering Branch Records Closed 1-83-13-NPS-02 Quality Engineering Branch Records Closed R-83-18-NPS-01 Management of.the Reorganization.of TVA Radiation Protection and Radiological Emergency Planning Program Y-
= - - -
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS-3 SPECIAL PROGRAM REVISION NUMBEll:
O PAGE 4 0F 37 Closed R-83-18-NPS-02 Office of Nuclear Power Program and Licensing Doiiments Closed R-83-18-NPS-03 Organizational Emphasis of ONP Radiation Protection and Radiological
".am gency Preparedness Programs.
Closed R-83-18-NPS-04 Organizational Placement of Health Physics at Nuclear Plants Closed R-83-18-NPS-05 Health Physics Technical Staff Ooxito Closed R-83-18-NPS-06 Radiological Health Staff (RHS) Technical Support Closed R-8 4- 05-WBN-14 Inspector Certification Records Closed R-84-17-NPS-01A The Procurement System is too Cumtmrcome and Not Well Knowe by the Users Closed R-84-17-NPS-01B The Procureno. nl System is too Cu..br'nomo and Not Well Known by the Users Closed !! tm 17-NPS-01C The Procurement System is too coa r.ome and Not Well Known by the Users i
Closed R-84-11-NPS-01D The Procurement System is too Cumborsome and Not Well Known by the Users Closed R-84-17-NPS-03 Excessive Review of Request for Deliveries (RDs) On Indefinite Quantity Term (IQT)
Contracts l
Closed R-84-17-NPS-04 Insufficient Documentation for Transferred l
Material l
l Closed R-84-17-NPS-06 BFN Power Stores Clerks Not Trained to In vert Malorial j
Closed R-84-17-NPS-07 Material With Limited Shelf Life Not Reordered in a Timely Manner Closed R-84-17-NPS-08 Materials Management System (MAMS)
Under-ut.ilized l
l
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-BSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 5 0F 37 Closed R-84-17-NPS-09 10 CFR Part 21 Requirements Incorrectly Linked to Nuclear Power QA Dw!uiremeats Closed I-8 4 B FN-01 Investigation of Potential Significant Fuents Closed I-8 4 D FN-02 Interpretation of Regulatory Requirements Closed I-84-31-BFN-03 Interpretation of Regulatory Requirements Closed I-84-31-DFN-04 Commitment to Procedural Controls Closed R-84-32-NPS-01 Inadequate TVA Quality Progr$m i
Open I-84-33-BFN-07 Piping Analysis Closed I-84-33-BFN-08 Failure of QA to Perform Audits and Surveillance of Identified Problem Areas within Piping Analysis Sections Closed I-84-34-SQN-01 Failure to follow QA Procedures by an Individual at SQN Closed I-84-34-SQN-02 Completion of TVA Mark Letter Description on the Transfer Requisition Documents Closed I-85-06-WBN-04 Timely and Responsive Corrective Actions for Resolution of Identified Problems Open R-85-07-NPS-01 Manager of Power and Engineering Appointment of a Records Manager Fourteen Safequards Items Closed R-82-01-PSS-01 Authorities and Responsibilities Not Clearly Defined in Writing Closed R-82-01-PSS-02 Procedure for Functioning of B*anch Staff Not Defined in Writing Closed R-82-01-PSS-03 Expectations of PSS Management Not Defined in Writing Closed R-82-01-PSS-04,B.1 Lack of Guidance and Support to Field Staffs Closed R-82-01-PSS-04.B.2 Lack of Guidance and Support to Field Staffs l
i Closed R-82-01-PSS-04.C.1 Lack of Guidance and Support to Field Staffs l
l Closed R-82-01-PSS-05 Internal and External Interfaces Not Well Defined Closed R-82-01-PSS-011 Lack of Document Control
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS-3 SPECIAL PROGRAM REVISION NUMBER: O PAGE 6 0F 37 Closed 9-82-01-PSS-12 T&Q Implomonting Instruction Closed R-82-01-PSS-13.
Material Revisions - Material Review and Approval Closed R-82-01-PSS-15 Site Security Organization - Administration Responsibilities and Authority Not clearly Defined Closed R-82-01-PSS-24 Bellefonte Security Facilities Tracking System Closed R-23-16-NPS-01 Revision of the Safeguards Information Closed R-84-06-NPS-01 Revision of the Safeguards Information 1
(Open) 79-09-01-1, Excessive Wire Liftinq Practicos to Facilitate Testing The above referenced NSRS concern was initiated in 1979 at WBN and was also determined to be generic to SQN.
It stated that testing of protective relays, meters, indicating instruments, and transducers on the 480 volt shutdown boards, 6900 volt shutdown boards, and diesel generator boards could not be performed without lifting leads, installing test leads, removing test leads, and reterminating board wiring. The NSRS corrective action recommendation stated that Division of Nuclear Power (DNP) should submit a DCR to define where test blocks were needed and also provide a point of contact to assist EN DES in the design.
(SQN-DCR-305 was written but disapproved).
SQN-DCR-305 was initiated for the purpose of nstalling test blocks in the equipment but.was disapproved by Division of Enc ineering Design (EN DES) because the testing intervals at that time wers considered too infrequent to justify installation.. On December 18, 1979, SQN-DCR-457 was initiated to install test blocks in the referenced equipment. The Design Change Request (DCR) was approved and Engineering Change Notice, ECN-L5360 was issued to implement the change.
As a result of the ECN, all applicable drawings were revised to reflect the :hange, however, no physical work was ever performed to implement the ECV. On April 1, 1986, a letter was issued, RIMS S53860422811, cancelling TCN-L 5360 and giving.
directions to ensure that applicable drawings reflect the cancellation.
ECTG recommends that test. blocks similar to those at Watts Bar be installed at SQN, since the intervals for testing at this time are different than those used at the time DCR 305 was disapproved in 1979, or provide justification through engineering evaluations why blocks should not be installed.
CATD 79-09-01-1 has been issued to track.this item. It will remain open until the issue has been resolved and CATD 79-09-01-1 closed.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-BSRS-3 SPECIAL PROGRAM REVISION NUMBER: O PAGE 7 0F 37 1
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(0 pen) 79-09-01-2, Excessive Wire Lifting Practices To Facilitate Testing l
The above referenced NGRS concern was initiated at WBN in 1979 and was also determined to be generic to SQN.
It stated that Division of Engineering Design (EN DES) was requested to install test blocks on the j
diesel generator logic and control board and the 6900V and 480V shutdown
]
boards for relays, meters, indicating instruments, and transducers to facilitate testing, SQN-DCR-305 was initiated to accomplish this task.
i EN DES rejected the Design Change Request (DCR) and the blocks were not l
installed. The NSRS Corrective Action Recommendation stated that Division of Nuclear Power (DNP) should submit a DCR to define whoro lost l
blocks were needed and also provide a point of contact to assist EN DES in the design.
Additional details are described above with issue 79-09-01-1.
CATD 79-09-01-2 has been issued to track this item.
It will remain open until the issue has been resolved and CATD 79-09-01-2 closed.
(0 pen) 79-09-01-3, Excessive Wire Lifting Practices To Facilitate Testing l
I l
The above referenced NSRS concern was initiated at WBN and was also determined to be generic to SQN.
It stated that in 1979, during Umes of testing, as many as fifty (50) wires, all of the same color, are lifted and reterminated which creates a potential for damaging equipment or injuring personnel. The NSRS Corrective Action Recommendation stated i
I that Division of Nuclear Power (DNP) should submit a DCR to define where test blocks were needed and also provide a point of contact to assist EN DES in the dr. sign.
(SQN-DCR-305 was written but disapproved.)
Additional details are described above with issue 79-09-01-1.
CATD 79-09-01-3 has been issued to track this item.
It will remain open until l
j the issue has been resolved and CATD 79-09-01-3 closed.
1 (Closed) 79-10-03-01, Concern for Reliability There are no programmatic aspects of current reliability activities existing. One-time tests do little to establish the ability of items to perform satisfactorily over their expected service lives.
Reliability j
requirements are not being specified in requisitions.
There is a lack of reliability engineering expertise in TVA.
The ECTG investigation indicated that for the past several years, TVA has had an active reliability program:
Division of Engineering Design (EN DES) and the former TVA Power Production (P PROD) have had both a steering committee and a working level task force.
Both of these groups have been actively working for the last two years. These two divisional efforts have worked closely with qualified reliability persons from organizations such as Electric Power Research Institute (EPRI),
Departmont of Energy i
l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRS-3 SPECIAL PROGRAM REVISION NUMBER: O PAGE 8 0F 37 (DOE), Electric Energy Institute (EEI), Nuclear Energy Research Center (NERC), Nuclear Plant Reliability Data System (NPRDS) and with private organizations such as KAMAN and Mechanics Research.
In addition, there have been detailed exchanges with other utility organizations. There have been joint programs with several of these organizations on collecting data and investigating various systems.
Also, TVA has been an associate member of the United Kingdom Atomic Energy Authority (UKAEA) Systems 1wo years and has access to the Statidical Reliability Service To mr Reporting Service (SRS) Data bank and counsel with SRS reliability engincurs.
In addition, industry trending is being accomplished through the Institute of huclear Power Operations (INPO) by the Nuclear Plant Reliability Data System (NPROS).
The document used for administering SQN monitoring and trending efforts is Plant Managers Procedure, PMP 1601.02, "NPRDS-Maintenance History and Clas s 1E Tracking and Trending - Reporting Failures of Components in Systems." Standard Practice, SQM-58, " Maintenance History and Tr ending" is the site procedure used to implement PMP 1601.02.
Basec on review of the applicable procedures and interviews with plant perscnnel, ECTG concludes this NSRS issur has been satisfactorily addressed. This item is closed.
(Closed) R-80-10-BFN-01, Unreviewed Safety Question Determination (USQD)
On July 9, 1980, at the request of BFN, and because of extended hot weather, Office of Nuclear Power (ONP) authorized wire lifts to defeat the automatic tripping function of the cooling tower lift pumps when the cold water discharge temperature reached 950F.
This waiver was extended to July 21 and again to July 28.
In addition, the 95*F temperature trip requirement in the cold water discharge channel was raised to 970F.
The NSRS evaluation revealed that an unreviewed safety question determination (USQD) had not been conducted for this temporary safety-related alteration of an FSAR requirement as required by 10 CFR 50.59 paragraph VI.A.
The NSRS recommended that the divisional procedure DPM N73011 should be expanded to include a provision to ensure USQDs for proposed alterations that make changes to systems or procedures described in the ' GAR.
NSRS further recommended that a copy of the USQD should then be torwarded to Division of Engineering Design (EN DES) and Nuclear Safety Review Board (NSRB).
The ECTG investigation of this issue revealed that DPM N73011 has been cancelled and replaced by SQN Administrative Instructions (AI) AI-9 and AI-4.
These procedures cover temporary alterations and procedural changes.
Division of Nuclear Engineering (DNE's) responsibilities for preparation of USQD's are described in AI-9, paragraph 5.3 and 5.8.
l TVA EMPLOVEE CONCERNS REPORT NUMBER:
SQitt-WSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O i
PAGE 9 OF 37 USQDs are prepared in accordance with Standard Practice SQA119 as j
required by AI-4 paragraph 7.2.
In addition, CATD R-80-10-HI N -01 was initiated previously to address the issue.
The completed corrective action response to the Corrective Action Tracking Documnnt (CATO) involved a review of the Tempora y Alteration Control Form (TACF) book to ensure all USQD's had been properly comploted.
Based on applicable procedures and the completed Corrective Action Plan (CAP) for CATD R-80-10-DFN-01, ECTG concludes this issue ha:. been j
satisfactorily addressed and is now closed.
{
(Closed) R-80-10-BFN-IV A, Expansion of DPM N73001 i
A review at Browns Ferry Nuclear (BFN) in 1980 by NSRS noted that Division Procedure Manual DPM N73011, section 7.3, revision dated February l i, 1980 did not contain provisions to ensure that proposed alterations changing systems or procedures in the Safety Analysis Report (SAR) are roviowed for safety questions, whether in written chapter material or drawings.
q The NSRS recommendation and the SQN corrective action for this issue are identified above under item R-80-10-BFN-01.
This NSRS issue is closed.
(Closed) R-81-02-BFN-01, Develop a TVA Policy Reqarding Loss of Safety Functions The above referenced NSRS report was initiated at BFN in 1981. The concern stated that improper installation of piping supports in the Residual Heat Removal (RHR) and Emergency Equipment Cooling Water (EECW)
I pipe tunnels at BFN resulted in the potential for degradation of safety systems capabilities during earthquake loading. The report further stated that conditions allowed by BFN Technical Specification 3.5.C are in error.
The NSRS corrective action recommendation for BFN stated that Nuclear Power (NUC PR) should revise and modify Technical Specification 3.5.C whereby a minimum of three (3) EECW pumps will be used instead of two (2).
ECTG requested SQN review of this issue with CATD R-81-02-UFN-01.
Subsequently, the investigation indicated that conditions described in this issue do not apply to SQN. Essential Raw Cooling Water (ERCW) piping at SQN is installed underground with an 18 inch concrete missile shield cover, rather than being installed on pipe hangers.
s Further, the conflict between technical specifications and system operating instructions (SOI) for the RHR system does not exist at SQN.
l The SOI does not reference the flow requirements of the technical specification; it only requires that the technical specification be met.
Based on a review of applicable documents, ECTG concludes that this NSRS j
issue does not apply to SQN.
Therefore this issue is closed.
l l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQW-NSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 10 0F 37
)
(Closed) R-81-04-YCN/NPS-01, Level of Safety Review of Yellow Creek Nuclear.P_lant (YCNJ This NSRS concern was initiated at YCN in 1981, and was determined to be applicable to SQN. The concern states that no minimum safety enview j
requirements had been established by the Nuclear Engineering Branch (NEB). The concern further stated that it had been a policy of NED to curtail safety reviews when manpower was in short supply or more pressing needs existed.
The Nuclear Safety Review Staff (NSRS) corrective action recommendation stated that NEB should establish a written program to ensure that adequate safety reviews, including all safety-related features, were performed at YCN.
It further recommended that procedures be initiated to provide guidance in performing safety reviews.
CATD R-81-04-YCN/NPS-01 was issued to SQN for review of the isue.
Subsequent investigation at SQN shows that Division of Nuclear Engineering Procedures NEP 2.1 and 6.1 address safety reviews at a corporate level.
Procedures to address this issued at the site level have not been developed, however, site procedure NEP 6.6 is cocrontly being :afted. Meanwhile at SQN, an interim document has been attached to NEP 2.1 (RIMS Number B05 870623 500) to address safety reviews at the site level. This interim document will remain in effect until NEP 6.6 RO is approved and issued.
Based on ECTG's investigation of the issue and a review of applicable procedures, it is concluded that this issue has been adequately addressed at SQN. This NSRS item is closed.
(Closed) R-81-04-YCN/NPS-02, Inadequacy of EP4._02 The above referenced NSRS issue stated that Division of Engineering Design (EN DES) procedure EP4.02 concerning the ECN process did not contain sufficient guidance for determining which organization needs to approve Engineering Change Notices (ECNs).
The corrective action recommended by NSRS was to revise Engineering Procedure (EP) guidance for determining which organizations are required to approve ECNs.
Further recommendations stated that the branches should periodically review all approved ECNs to ensure that proper opprovals were obtained.
Procedure EP4.02 was revised and redesignated as Operating Engineering Procedure, OEP-11.
OEP-11 was revised and redesignated as NEP-6.
l NEP-6.1, referenced in engineering element report 204.6(A), addresses ECN responsibilities at a corporate level, while SQ EP-13 and AI-11 address ECN responsibilities for Sequoyah.
i Based on ECTG's investigation of the issue and a review of applicable procedures, it is concluded that this issue has been properly addressed.
j This NSRS item is closed at SQN.
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SQN-@SRS-3 SPECIAL' PROGRAM REVISION NUMBER: 0 PAGE 11 0F 37 (Closed) R-81-08-UFN-08, Increased' Scope of OPQA&A Staff Audit Program Audits required by BF SP 10.1, " Corrective Action Policy" dated Febr^uary 1980, were not adequately scoped to give management the assurance that the corrective action system was working effectively. -The audits;did not include the Licensee Event Report.(LER) Program, for example,fwhich handled the identifying, evaluating, correcting, and reporting of items identified in the Nuclear Quality Assurance Manual (NQAM) as significant conditions adverso to qulity.
The Nuclear Safety Review Staff (KSRS) corrective action recommendation stated that the Office of Nuclear Power should increase its sn'po of the current 1981 Staff Audit Program to provide reasonable assurance that corrective action programs are effective.
j This recommendation was acted upon by_Cffice of Nuclear Power (ONP) who l
developed a' program entitled, " Audit Module 23 Corrective Action" to provide verification of implementation and effectiveness of the QA program.
j ECTG reviewed the audit module and samples of audit reports concerning corrective action implementation and effectiveness and found them
)
satisfactory.
Based on a review of the program and samples taken, ECTG concludes that this issue has been satisfactorily addressed. This NGRS issue is closed at SQN.
1 1
(Closed) R-81-08-BFN-20, Quality Assurance and Quality Control of Operational Activities The scope of ONP's audit program was considered inadequate and did not ensure conformance to Technical Specifications.
The NSRS Corrective Action Recommendation stated that ONP should increase the scope of the current 1981 audit program to provide the NSRS reasonable assurance that the nuclear facility will be operated withic the technical specifications and conditions of the license.
ONP's corrective action response stated that Quality Assurance Branch (QAB) had developed an audit plan matrix including scoping documents, and' made them an integral part of the quality assurance audit program by either direct inclusion or reference in a division-level' instruction.
In addition, QAB included examples of the Audit Plan Matrix and the scoping documents.
Based on the interviews with cognizant personnel and a review of' Division
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of Quality Assurance (DQA) instruction 322 (R2, March 1986) " Standard Audit Module Scoping Document", which indicates that the audit program is adequately scoped, ECTG concludes that this issue has been satisfactorily addressed. This NSRS issue is closed at SQN.
TVA EMPLOYEE CONCERNS REPORT WUMBER:
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O PAGE 12 0F 37 (Closed) R-81-08-BFN-41, QA & A Staff NSRS stated there were inadequate resources (manpower) on the Audit Program Staff to perform necessary audits or implement the audit program.
The NSRS Corrective Action Recommendation stated that Office of Nuclear Power (ONP) should evaluate the QA audit program to determine whether or not additional personnel resources are needed to effectively implement the program.
Action should be taken as appropriate to support the result of the evaluation.
During interviews with cognizant personnel, it was determined that the staff of Division of Quality Assurance (DQA) had tripled since this Nuclear Safety Review Staff (NGRS) issue was initiated in 1981.
In addition, new auditors are being acquired and trained on a continuing need basis providing adequate resources for DQA.
Based on interviews with DQA supervisors, and increased staff resources, ECTG concluded that this issue has been satisfactorily addressed. This NSRS issue is closed at SQN.
(Closed) R-81-14-0EDC (BLN)-32, Inadequate Storaqe of Audit Support Records In September 1981, the NSRS investigation found that the storage of audit support records was not in accordance with the requirements of ANSI N45.2.12 and ANSI N45.2.9.
Some records were being stored in non-fire rated cabinets.
The NSRS recommended that provisions be made for protection of the records as required by the referenced standards.
ECTG's investigation of the issue found that part 3, Section 5.1 Paragraph 4.22 of the Nuclear Quality Assurance Manual (NQAM) gives direction for retaining records from a corporate level.
Procedure AI-7, Revision 44, Attachment 1 gives direction to the site quality manager and addresses the issue of record retention at SQN.
Additionally, a sampling of the Records and Information Management System (RIMS) file verified that applicable procedures were being effectively implemented.
l I
Based on the satisfactory results achieved from the sampling effort and positive interviews with cognizant personnel from Document Control Section, the ECTG concludes the NSRS issue has been properly addressed.
This NSRS issue is closed.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQB-NSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 13 0F 37 (Open) R 14-0EDC (BLN)-41, QAH Auditor Training The ebove referenced NSRS concern was initiated in 1981 at BLN and was also determined to be applicable at BFN.
It stated that Division of Engineering Design (EN DES) failed to establish a written.pgoved program for training auditors.
The Engineering Assurance (EA) organization within Division of Nuclear Engineering (DNE) does not have a formal procedure that gives direction for training personnel as auditors.
However, new auditors within FA are being given auditor training at Power Operations Training Center (POTC).
POTC is currently conducting auditor training and at the samo time developing a training standards manual. The manual is scheduled to be issued on November 29, 1987, and will include, in part, the following training courses presently used in POTC training.
a.
QAT 008 - Introduction to Auditing b.
QAT 002 - Observation Training for QA Audit Personnel c.
QAT 007 - Code and m..ubrds d.
QAT 010 - Advanced Auditing Techniques The NSRS Corrective Action Recommendation suggested that Quality Assurance Branch (QAB) develop an administrative procedure delineating QA training requirements and provisions for management approval of QA auditor training programs.
ECTG recommends that DNE develop a procedure that provides guidance for auditor training, either by using the established POTC training program, or developing a new program unique to DNE auditing requirements.
l This issue will remain open until an adequate resolution han been initiated and implemented. This issue will be administratively tracked by i
CATD R-81-14-0EDC(BLN)-41 at Browns Ferry.
(Closed) R-82-08-NPS-01, Requirements /Needs/ Activity Matrix j
This NSRS issue states that'the Nuclear-Operational Quality Assurance Manual (N-0QAM) is not self sufficient and relies on division directives for supplemental detailed requirements.
Office of Nuclear Power (ONP)
Chemistry Engineering Group (CEG) personnel are not comprehensively aware of what commitments and requirements had been made on behair of water l
Quality Control or how they had been incorporated into directives and j
procedures except for the requirements of the specific plant technical l
specifications.
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PAGE 14 0F 37 l
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The recommendation supplied by the NSRS stated that a l
requirements /needs/ activities matrix should be developed to identify and j
i tabulate all requirements, TVA commitments, and program needs. The requirement should be indexed to the source control documents for tracking and verification of implementation.
In response to this and subsequent R-82-08-NPS issues, CATD 30711-NPS-02
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was initiated to provide corrective action for deficient conditions. This i
CATD requested that all items in the R-82-08-NPS series reports (1 through l
- 10) be reviewed and a method of resolution for deficiencies be provided.
A Corrective Action Plan (CAP), described as follows was developed to implement a new program:
In response to the subject NSRS audit report and discussions with persons involved in the audit, it was determined that oddrossing the j
10 recommendations, after such a long lapse in time, is not practical nor would it address all of todays problems.
Instead, a much broader j
approach will be taken that includes the stated scope and intent of l
this audit. The goal for the approach presently being pursued is to develop an exceptional program that exceeds in quality all requirements commitments, and industry standards.
As a result of the problems identified in this audit and other audits by NRC, INPO, Quality Assurance, etc., a Chemistry Program Manager's position was
]
established at the corporate level with the responsibility and i
authority to develop, implement, and maintain a state-of-the-art chemistry program at TVA.
This program is presently under development and schedules have been submitted for its implementation. When I
implemented, this program will address the concerns, both stated and
)
implied, in the subject audit report.
ECTG obtained a copy of the proposed program schedule and further investigations revealed that a portion of the program had been implemented and the remainder was reasonably following the prescribed schedule. The intent of the newly developed program is to establish and implement a model program at the Sequoyah NJclear Plant that is " State of the Art" and with its successful completion, to adopt and implement it at WBN, 8FN, and BLN.
l Based on satisfactory progress toward developing a model chemistry program at SQN, i.e.,
selection of a corporate manager, program development, program implementation, personnel training, and purchase of state-of-the-art equipment, ECTG concludes this issue has been satisfactorily addressed and closed at SQN.
However, CATD 30711-NPS-02 will remain open until the model program has been installed at all TVA nuclear plants and CATD 30711-NPS-02 is closed.
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PAGE 15 0F 37 (Closed) R-82-08-NPS-02, Quality Assurance Program for Chemistry Activities The NSRS investigation in 1982 concluded that the ONP Quality Assurance Program, which provides QA program requirements for all of its facilities performing quality-related activities, was devoid of controls required for safety-related Chemistry activities.
Chemical and radiochemical program controls were not established to the degree warranted.
The corrective action recommendation made by the NGRC stated that the Office of Nuclear Power (ONP) Quality Assurance Program should include all safety related chemistry activities.
Tracking of corrective action for this item is by ECTG CATD 30711, as described above under item R-82-08-NPS-01.
NSRS item R-82-08-NPS-02 is closed.
(Closed) R-82-08-NPS-03, Chemistry Proqram Organization and Responsibility Geview The NSRS issue referenced above indicated that ONP's functional decentralized organization had bred autonomy among its organinitional units.
Each of the six (6) project control staffs for chemical and radiochemical control within Office of Nuclear Power (ONP) had duplicated the efforts of the other causing confusion as to the responsibility l
relationship of the Chemistry Engineering Group (CEG) with the plants and Power Operations Training Center (POTC).
The Corrective Action Recommendation offered by the NSRS states that ONP should reexamine the assignment of authority and responsibility for Chemical and Radiochemical Control to ensure that authority, accountability, and responsibility is specifically defined and delegated.
Tracking of corrective action for this item is by ECTG CATO 30711, as l
described above under item R-82-08-NPS-01.
NSRS item R-82-08-NPS-03 is l
closed.
(Closed) R-82-08-NPS-04, Procedural Controls For Conducting Safetv/ Quality Affectinq Activities Within the Chemical Engineering Group (CEG) l l
l The NSRS investigation revealed that no procedural controls had been formulated to accomplish the safety / quality affecting activities being performed by CEG.
Certain actions taken by the group circumvented normal administrative controls for ensuring safety / quality objectives were The NSRS recommended that the Chemical Engineering Group maintained. lop procedural controls to formalize its activities, should deve
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.PAGE16Oh37 Tracking of corrective action for this item is by ECTC CATD 30711, as described ahave under' item R-82-08-NPS-01.
NSRS item R-82-08-NPR-04'is closed. -
(Closed) R-82-08-NPS-05, Program Improvements The NSRS investigation indicated that CEG had become a reactionary groups rather than a forward-thinking-group.
Part of this development had occurred as a result v. Chemistry Engineering Group (CEG) being confined to some degree to the central-office, This confinement may have resulted tho.CEG indirectly by self-imposition because of;the relationship between and the plants.
The recommendation given by NSRS stated that the Chemical Engineering Group needs,to be given strong management support which nilows its analysts to perform their prescribed functions.
Tracking of corrective action for this item is by ECTG CATO 30711, as described above under' item R-82-08-NPS-01.
NSRS item R-82-08-NPS-05 is closed.
(Closed) R-82-08-NPS-06, Internal Review and Feedback Process The NSRS investigation stated that Chemistry Engineering Group (CEG) had no internal review mechanism to apprise the group of administrative and program weaknesses; to identify which of its activities noe1 'o be more formally controlled; to verify through onsite reviews the implementation of its directives; to periodically advise uanagement of overall Chemistry l
Program status ar.d effectiveness; and to recommend corrective actions.
The NSRS recommended that responsibilities should be established within CEG to conduct internal reviews of its activities and assess the degree of implementation of Nuclear Control Office (NCO)-issued division directives. These reviews should be performed by qualified' persons who do not have responsibility for performing or directly supervising work activities being reviewed.
Tracking of corrective action for this item is by ECTG CATD 30711, as described above under item R-82-08-NPS-01.
NSRS item R-82-08-NPS-06 is closed.
(Closed) R-82-08-NPS-07, Verification of Onsite Radiochemical Laboratory Analyst (RLA)-Training 3
This NSRS issue states that no onsite involvement or. program effectiveness appraisals are being. accomplished in the area of RLA i
training by the Nuclear Central Office Training Branch. There is some indication that the training program breaks down at the plant level.
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O PAGE 17 OF 37 The NSRS corrective action recommendation suggested that the Nuclear Central Office (NCO) training branch should review on site RLA training activities at periodic intervals.
Tracking of corrective action for this issue is by ECTG CATD 30711, as described above under item R-82-08-NPS-01.
NSRS item R-82-08-NPS-07 is o l o wd.
(Closed) R-82-08-NPS-09, Integrate. Calibration and Chemical Program Development This issue was investigated in 1982 by NSRS. The report concluded that even though Central Laboratory Section (CLS) has est ablished cont role for its Maintenance and Testing (M&TE) calibration program, formal controls for the safety-related chemical support functions have not been established.
The NSRS corrective action recommendation stated that CLS should expand the formal controls to cover the chemistry and other quality-offorting activities to define the laboratory's QA responsibilities to ONP.
l Tracking of corrective m tion for t his issue is by ECTG CA"In 30711, as l
described above under item R-82-08-NPS-01.
NSRS item R-82-08-NPS-09 is closed.
(Closed) R-83-08-BLN-2, Development of Cleaning / Flushing Program Control Procedures The cleaning / flushing program for safety-related systems at the BLN site is governed by the requirements of NRC Regulatory Guide (RG) 1.37 which l
endorses ANSI N45.2.1 1973. The requirements specified in these documents wero to be incorporated in Office of Engineering (OE)-generated documents G-39 and N4M-891.
Not all of the requirements of the RG and ANSI standard had been incorporated into G-39 and N4M-891 and the j
documents were very general in nature.
As a result, the site-generated i
procedure, DNP-CTP-6.1, and the construction test packages did not uent all the requirements of RG 1.37 and ANSI N45.2.1-1973 and did not contain sufficient detail to provide adequate guidance for inexperienced personnel to allow development of an acceptable flushing program.
NGRG recommended that OE review RG 1.37, ANSI N45.2.1-1973, other i
documents containing TVA commitments, and the details of the NSRS reports and incorporate the programmatic requirements and applicable recommendations into G-39 and N4M-891 to ensure that responsibilities, j
technical requirements, documentation and records, training, and adequate program test controls were defined.
NSRS also recommended that the site review the site-generated procedures, Office of Construction (OC) test l
packages, and the flushing program to ensure conformance to the
}
OE-generated documents with specific emphasis on acceptance criteria and i
adequate details in each system test package for controlling the accomplishment of the activity and documenting the results, i
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0 PAGE 18 0F 37 l
The corrective action for this NSRS finding was completed in early 1984 and a response provided to ECTG by the DNE office in Knoxville on June 4, 1987.
The response stated that General Construction Specification G-39 was revised (Revision No. 6 effective February 15, 1984) to address the NSRS finding that TVA's Cleaning / Flushing procedures did not contain all the requirements of ANSI 2.1-1973.
The prim ipal construction test procedures which implement G-39 are reviewed by DNE each time they are revised for compliance with G-39 requiro w nts.
Additionally, cleaning and flushing activities at SQN are controlled by Technical Instruction TI-70 R.7.
This TI meets the requirement-of ANSI i
N45.2.1-1973 and Regulatory Guide 1.37-Water Quality for cleaning and flushing is addressed by SQE 22 R.4 and surveillance sc hedules are provided through Surveillance Instruction SI-1 Appendix F.
Based on the response received from the DNE office, reviem
,ylienble procedures and interviews with cognizant personnel ECTG concludes this issue has been addressed at SQN.
This NSRS item is closed.
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(Closed) R-83-08-BLN-5, Approval of the 1/8-inch Variance for Acceptable f
Purge Dam Residual particle Size I
4 NSRS conducted a review at Bellefonte Nuclear Plant (BLN) concerning piping system flushing activities covered by requir cent 3 of ANSI i
N45.2.1-1973.
This standard permits the allowable size of purge dam j
l material to be no greater than 1/32 inch.
The implementing document for I
these activities is General Construction Specification G-39.
NSRS noted that a variance had been granted by Division of Engineering Design (EN DES) to relax the allowable size from 1/32 inch to 1/8 inch.
This is contrary to the G-39 Specification and ANSI Standard N45.2 1-1973.
NSRS recommended that if the variance was not approved, EN DES must l
evaluate the flushing program and determine the adequacy of th: program l
for further flushing and the acceptability of systems previously flushed l
to the 1/8 inch acceptance criteria.
If the variance is approved by the NRC, an instr.uction should be prepared and implemented for classifying and measuring particulate matorials and documenting the results to ensure that the 1/8 inch acceptance criteria is applied only to properly identified and measured purge dam natorials.
i Since SQN is also committed to ANSI N45.2.1-1973 and uses G-39 Specification this issue was considered to have generic implications.
Discussions with cognizant personnel indicate that this issue applies only to BLN and is not applicable to SQN.
Clonning and riushing j
activities at SQN are controlled by Technical Instruction TI 70 R7, which meets the requirements of ANSI 45.2.1-1973, and Regulatory Guide 1.37, i
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O PAGE 19 OF 37 In addition, Knoxville DNE drafted a letter on June 4, 1987 stating that i suas-Construction Specification G-39 was revised to address the NSUR concerning cleaning / flushing p-ocedures.
Based on interviews with cognizant personnel and the memo from DNE, OCTG concludes that this NSRS issue has been satisfactorily addressed. This issue is clusod.
(Closed) I-83-13-NPS-la, Quality Engineering Branch (QEB) Records The NSRS investigation fevnd that vendor-supplied QA records obtained by QED for SQN had not been completely turned over to NUC PR and there appeared to be no plans to do so.
The report noted this as a uinlation of 10 CFR 50, Appendix B, Criterion VII and Topical Report Requirements.
The NSRS recommended that an interdivisional task force reporting to the Assistant General Manager be formed to correct the problems identified and to establish an effective records system.
A follow-up report, R-85-07-NPS, was initiated in May 1985 that addressed the same issue as I-83-13-NPS-la.
It stated that the NSRS had confirmod in the follow-up report that in response to the corrective action recommendation contained in I-83-13-NPS, a task force was established and functionally active between December 1983 and April of 1984.
Additionally, the report of May 1985, documented the results of the follow-up corrective action review by NSRS of the findings and recommendations associated with the NSRS report I-83-13-NPS.
This follow-up review covered activities of the Office of Engineering, Office of Construction, and NUC PR regarding the accumulation, storage, transferring, and retrievability of vendor and construction records connected with procurement requiring QEB source inspection.
To ensure the satisfactory completion of this and related records issues several NSRS item concerning QEB records have been consolidated into CATD R-85-07-NPS-01, which recommends designation of a records manager to assure adequacy of QEB Records for all sites.
Based on thit lemm being a corporate problem and tracked by r3TD R-85-07-NPS-01 which was sent to SQN, NSRS I-83-13-NPS-la is closed.
(Closed) I-83-13-NPS-1b, Quality Engineering Branch (QEB) Records The NSRS report concluded there was no overall OEOC effort to provide NUC PR a complete QA file integrating both construction and QEB records in a usable form. This was in violation of TVA Quality Assurance Procedure (QAP) PRM 17QPR-1.
The NSRS recommended that an interdivisional task force reporting to the Assistant General Manager be formed to correct the problems identified and to establish an eff ective records system.
TVA. EMPLOYEE CONCERNS REPORT NUMBER:
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'PAGE 20 0F 37 A follow-up report, R-85-07-NPS, was initiated in May 1985 that addressed the same issue as I-83-13-NPS-1b.
It stated that the NSRS had confirmed in.the follow-up report that in response to the corrective action recommendation contained in I-83-13-NPS, a task force was established and functionally active between December 1983 and April of 1984.
Additionally, the report of.May 1985 documented the results of the follow-up corrective action review by NSRS of the findings and recommendations associated with NSRS report I-83-13-NPS.
This review covered the activities of the Office of Engineering, Office of Construction, and NUC PR regarding the accumulation, s to rage,
transferring, and retrievability of vendor and construction records connected with procurement requiring QEB source inspection.
SQN Construction Records are now being indexed for retrievability and usability. This work is being tracked _by SQ-CAR-87-019.
ECP Investigation Report ECP-86-KX-055-01 indicates that the QEB Records are now in plate for SQN.
However, development of an integrated system for the Construction and QEB Records is still in process.
The 1985 follow-up NSRS report. recommended that a manager should be designated with the responsibility, authority and organizational freedom to assure that QEB Records are verified, stored, and indexed for retrievability by present and future users of those records. Since CATD R-85-07-NPS-01 was issued to track the open item from the 1985 Follow-up Report, this NSRS item I-83-13-NPS-1b is closed.
(Closed) I-83-13-NPS-1d, Quality Engineering Branch (QEB) Records The retrieval of information from vendor QA records at SQN by NUC PR was considered to be inadequate due to poor organization, lack of completeness, low level of indexing, and lack of editing. Retrieval depended upon use of individuals located away from the site.
There was no coordinated TVA effort to ensure the adequacy of identificat. ion, collection, collation, indexing, and distribution of vendor QA records.
The NSRS recommended that an interdivisional task force reporting to the 1
Assistant General Manager be formed to correct the problems idontified
]
and to establish an effective records system, 4
A follow-up report, R-85-07-NPS, was initiated in May 1985 that addressed 1
the same issue as I-83-13-NPS-Id.
It stated that the NSRS had confirmed in the follow-up report that in response to the corrective action recommendation contained in I-83-13-NPS, a task force was established and
'I functionally active between December 1983 and April of 1984.
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O PAGE 21 OF 37 Additionally, the report of May 1985 documented the results of the follow-up corrective action review by NSRS of the findings and recommendations associated with the NSRS report I-83-13-NPS.
This follow-up review covered the activities of the Office of Engineering, Office of Construction, and NUC PR regarding the accumulation, storage, transferring, and retrievability of vendor and construction rocords connected with procurement requiring QEB source inspection, The issues of QEB Records have now been consolidated into CATD R-85-07-NPS-01 which was written concerning the open recommendation in the 1985 NSRS Follow-Up Report.
Since this is a corporate problem and is tracked by the ECTG CATD, this NSRS Issue I-83-13-NPS-1d is closed.
(Closed) I-83-13-NPS-02, Quality Engineering Branch (QEB) Records l
l This issue, as investigated by NSRS in 1983, stated that no schedule was l
l provided that established when vendor records themselves would be I
verified as complete or indexed for retrievability. QEB had not established a schedule to verify or index records at SQN & WBN.
j l
A December 1986 ECP Investigation Report ECP-86-KX-055-01 concerning this l
issue found that the QEB Records for SQN are now indexed and retrievable.
Also, QMI-446, " Supplier Document Review" and QMI-450
" Contract Records Index and Filing" have been issued and address vendor record verification and storage.
Based on the implementation of the NSRS recommendation, this NSRS item is
- closed, i
I (Closed) R-83-18-NPS-01, Management of the Reorganization of TVA Radiation Protection and Radiological Emergency j
Planning prog ram The NSRS evaluation of this issue stated that tho osponsibilities for conducting TVA's radiation protection and radiological protection program
~
were not well defined and disagreements as to the final disposition of some of its functions had not been resolved. TVA Organization Bulletins, Codes, and Instructions had not been issued a year after the reorganization and this had led to interface and communications barriers.
The NSRS recommended that upper management should take actions to assure that final decisions are promptly made regarding the assignment of responsibilities and all necessary TVA corporate documents (codes, bulletins, instructions) are updated to reflect the final decisions.
Upper-management involvement should be maintained until the program has been implemented in accordance with the approved documentation.
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O PAGE 22 0F 37' ECTG's evaluation of the issue showed that the Radiation: Protectio % Plan i
(RPP) Section'A, Rev. 3 dated July 15, 1980 details ONP's requirndents -
i and management controls for the radiation and radiological protection
]
programs. 'It applies to all aspects of radiation protection associated J
with TVA nuclear ' power plants and supporting functions and services.
ECTG verified that the RPP is implemented at SQN through the SQN radiological control instructions RCI-1 through RCI-16 and the General Employee Training (GET) health physics courses HD 2,1 " Health Physics Training Level-I" and HP 2.2 " Health Physics Re-Training, Level II."
Based on the RPP definition of program responsibilities,'and verification of program conditions at SQN, this NSRS item is closed.
(Closed) R-83-18-NPS-02,'Offic'e of Nuclear Power program and Licensing Documents This NSRS issue concerned Office of Nuclear Power program and licensing documents for radiation protection and radiological emergency planning.
which had not been issued or were out-of-date.
NSRS recommended additional resources be directed toward preparing, updating, and issuing the Area Program Manual, Operations Quality Assurance Manual (0QAM),
Technical Specifications, Final Safety Analysis Report, and plant standard practices in the areas of radiation protection and radiological emergency planning.
The OQAM, as mentioned in the initial report, no longer exists.
It was replaced by the NQAM.
Later, the NQAM section concerning radiation j
protection was removed and placed in the Radiation Protection Plan. The j
Final Safety Analysis Report (FSAR) Amendment. Number 4 now reflects the current organizational structure. The Radiation Protection Plan is implemented at SQN through the SQN radiological control instructions RCI-1 through RCI-16 and the General Employee Training (GET) Health Physics (HP) courses HP 2.1 and HP 2.2 which concern HP training Ioval I and HP retraining Level II.
l Based on the updating of the ONP and SQN documentation, this NSRS issue is closed.
(Closed) R-83-18-NPS-03, Organizational Emphasis of Radiation Protection and Radiological' Emergency Preparedness Programs l
The NSRS report stated that the radiation protection and emergency.
preparedness programs had been organizational 1y-deemphasized.
NGRS recommended that more emphasis be placed on these programs and that staffing should be developed to the level and with the technical ~
expertise necessary to develop and maintain their respective programs, l '
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C PAGE 23 0F 37 ECTG determined that the radiation protection and emergency preparedness programs are now receiving more emphasis.
The SQN Nuclear Perfor mance Plan Volume 2, Appendix 2, establishes the Emergency Preparedness Program as a branch rather than a section. The Radiological Protection l
organization at SQN currently maintains its organizational function as a j
branch.
In addition to reorganization of the radiation protect ion and emergency preparedness programs, several new positions have been created.
Personnel assigned to the new positions have strong academic backgrounds and related work experience.
Based on the increased emphasis on the radiation protection and emergency preparedness programs, this NSRS item is closed.
(Closed) R-83-18-NPS-04, Organizational Placement of Health Physics at Nuclear Plants The NSRS report recommended that ONP formalize the reporting of the inplant Health Physics Section to the Plant Superintendent, thereby eliminating the requirement to report to either the Assistant Superintendent of Maintonanco or Assistant Superintendent of Operations and Engineering.
ECTG verified that organizational placement of health physics at the SQN site now satisfies the NSRS recommendation.
The SQN site radiological control superintendent reports directly to the plant manager.
This NSRS item is closed.
(Closed) R-83-18-NPS-05, Health Physics Technical Staff Onsite This NSRS issue concerned a lack of technical expertise in health physics I
to identify unique and new health physics problems as they occurred at l
each site.
There was a need for expertise to identify problem areas requiring further technical analysis by offsite personnel and to provide on-the-spot technical guidance.
NSRS recommended that there be established at each plant the position of assistant to the Health Physics Supervisor or similar position staffed with a highly qualified, degreed health physicist.
ECTG verified that the reorganization of Health Physics (HP) established a position of Superintendent Radiological Control.
The superintendent of the SQN HP program is a degreed health physicist.
Also at SQN, there i; a site Radiological ^ Assessor (degreed) position.
The radiological l
assessor conducts continuous assessments of the onsite radiological control program. The assessor also advises the Site Director and the Superintendent Radiological Control of significant radiation protection matters and the status of the onsite radiological control program.
Based on the strengthening of the onsite health physics technical staff, this NSRS issue is closed.
l
.y TVA EMPLOYEE CONCERNS.
REPORT NUMBER: SQB-NSRS-3 SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 24 0F 37'
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(Closed) R-83-18-NPS-06, Radiological Health Staff (RHS) Technical Support The NSRS. report concluded that the Radio' logical Health.Slaff (RHS) were spending too-much time in the office and not enough time.in the field where the problems were.
NSRS recommended a mechanism be established to j
{
provide more presence of.RHS personnel in the operating plants.
ECTG verified the increased presence of radiological control personnel at the SQN site.
As stated for item R-83-18-NPS-05, the Site Radiological Control Branch has been strengthened by additional positions to provide the. site with the necessary technical experience.
Based on the increased RHS technical support at SQN, this NSRS' issue is i
closed.
(Closed) R-84-05-WBN-14, Inspector Certification Records The NSRS report,' dated. June 1984, concluded that printouts (at Watts Bar) describing inspector certifications sometimes indicate.that the inspectors are only " partially" certified and do not' always identify the areas in which they are certified. In some cases the printouts contained errors in certification data..NSRS recommended that any areas of
" partial" certification be identified.
Subsequent to the NSRS report, the Nuclear Quality Assurance Manual (NQAM), Part II,~Section 5.6.3 (dated July 1, 1987) established requirements for an up-to-date list of certified inspection personnel, with distribution to each nuclear plant.
Specifications are provided i
concerning identification of certification areas for partially certified inspectors.
In addition to the clarification of requirements, improvements in the interactive computer system have improved the certification documentation process.
Areas of partial certification are now identified.
Based on the improvements in the certification process, this NSRS item is closed.
(Closed) R-84-17-NPS-01A The Procurement System is Too Cumbersome and Not Well Known by the Users NSRS stated that the biggest problem found with the procurement system used by Nuclear Power (NUC PR) was its wasteful and cumbersome nature.
Procurement were overloaded-with redundant reviews producing little-value added in most cases and causing unnecessary time delays up to months. Virtually anyone could initiate a procurement action with little or no training.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQN-NSRG-3 SPECIAL PROGRAM REVISION NUMBER:
0 I
PAGE 25 0F 37 NSRS said that no ene was found in the procurement section that knew the process much beyond their sphere of involvement. That resultod in unrealistic expectations being placed upon the system by the originator with regard to delivery time, and was perpetuated by others in the process who did not correct the problems. One of the more cumbersome and rvdundant review processes occurred within the Nuclear Central office l
(NCO). NSRS stated that the removal of that review process on October 1, 1984, with the transfer of people to the sites, would help streamline the 1
process provided the Central Office problems were not also transferred to j
j the sites, At SQN the procurement process has been extensively revised to reduce its complexity. The primary result in this effort was the creation of tho Contracts Engineering Group (CEG) under standard practice SQA-45.
This l
organization is charged with the review of all procurement packages for QA and technical requirements. This action has drawn the review function for procurement together under a single manager with inputs being provided by other groups such as Division of Nuclear Power (DNE) and QA, ECTG Element Report 80101-SQN discusses this issue and references the NSRS report. CATD 80101-SQN-01 requests the site to specify and explain what corrective action is being taken to resolve the issues.
An approved Corrective Action Plan (CAP) states that the Replacement Items Program will ensure that all installed items are adequate to perform their safety function and that new procedures will be developed to implement a commercial grade dedication program.
Further, the CAP states that DNE and site procedures are being developed to implement the NQAM procurement requirements.
A review of the subject procedures revealed they have in i
fact been issued, l
Based on the tracking of this issue by ECTG CATD 80101-SQN-01, this NSRS issue is closed.
l (Closed) R-84-17-NPS-018, The procurement System is too Cumbersome and i
Not Well Known by the Users l
NSRS identified problems with the procurement system used by Nuclear Power (NtC PR) (see R-84-17-NPS-01A for problem description).
NGRS recommendations to correct the problems follows:
A formalized, documented training program covering the entire procurement process should be developed and required for all personnel within the procurement cycle from the originator (requisitioner) through the purchasing agent.
1 I
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQM-NSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 26 OF 37 An ECTG review of the overall SQN procurement process was performed and reported in ECTG report 80101-SQN, This report includes the NGCI r eport R-84-17-NPS as an attachment. CATD 80101-SQN-01 was issut:d to request action on the items identified by the NSRS and validated by FUTG.
A Corrective Action Plan (CAP) has been issued and approved committing resources and outlining specific action to be taken to re m1vo the items.
Based on the tracking of this issue by ECTG CATO 80101-SQN-01, this NSRS issue '
chmed.
(Closed)
R-84-17-NPS-01C, The procurement System Is Too Cumbersome and Not Well Known By the Users NSRS identified problems with the procurement system used by Nuclear l
Power (NUC PR) (see R-17-NPS-01A for problem description).
NGRG recommendations to correct the problems follows:
A realistic timeframe(s) should be established for routine non-special order procurement, based upon past experience, to cover l
I the time required from procurement origination through receipt of the l
material onsite.
A mechanism should be included in the procurement system to periodically evaluate and adjust that timeframe as
)
nec'essary, as well as communicate the timeframe to involved personnel j
(planners, procurers, etc.).
j l
1 l
An ECTG review of the overall procurement process was performed and j
reported in ECTG report 80101-SQN. This report includes the NGRC report i
as an attachment. CATD 80101-SQN-01 was issued to request action on the items identified by 1.br NMR and um1 W ted by ECTG.
A CorreeM un Action Plan (CAP) has been issued and approved committing resources and outlining specific action to be taken to resolve the items.
Based on the tracking of this i ssue by ECTG CATD 80101-SQN-01, this NSRS issue is closed.
i (Closed)
R-84-17-NPS-01D, The Procurement Evstem Is Too Cumbersome and Not Nell Known Bt The Users NSRS identified problems with the procurement system used by Nuclear Power (NUC PR) (See R-84-17-NPS-0AA for problem description).
NGRS recommendation to correct the protlem follows:
Material availability and proctroment timeframes should be included in all maintenance and modification planning activities.
(NOTE:
This recommendation is predicated upon information that NUC PR is developing a maintenance and modification planning and scheduling function at each site.)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQM-NSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 27 0F 37 An ECTG review of the overall procurement process was performed and reported in ECTG report 80101-GQN.
This report includes the NGRO roport as an attachment.
CATD 80101-SQN-01 was issued to request action on the j
items identified by the NSRS and validated by ECTG.
A Corrective Action
{
Plan (CAP) has been issued and approved committing resources and outlining specific action to be taken to resolve the items.
Based on the tracking of this issue by ECTG CATD 80101-SQN-01, this NSRS issue is.losed.
(Closed) R-84-17-NPS-03, Excessive Review of Request tur Deliveries (RDs)
On Indefinite Quantity Term (IQT) Contracts The NSRS report stated the Office of Nuclear Power (ONP) was reviewing and approving RDs with the name rigor as the initial IQT contract.
ONP f
should streamline its procedure for the review and approval of RDs to be in line with the requirements of the TVA procurement manual.
An interview with the Materials and Procurement Support Section Supervisor revealed that the procurement process has been extensively revised to include the following changes.
An on-site Contracts Engineering Group (CEG) has been established to review all procurement packages.
Appropriate QA and technical requirements are being plw ed in each o
procurement package.
Standard Practice SQA-45 describes the function of the CEG and the entire procurement process.
ECTG's evaluation of this issue concludes that this NSRS item has been H
satisfactorily addressed and closed.
(Closed) R-84-17-NPS-04, Insufficient Documentation for Transmitted Material The NSRS report concluded that sites requesting material to be transferred to them by another TVA organization or location did not specifically identify documentation requirements or require a copy of the original contract the material was purchased under.
Thorofore, the receiving site had a limited basis for accepting material during the receipt inspection process. The site assumed that all applicablo documentation had been sent by the transferring organization without knowing exactly what the original specifications (technical /QA) were.
NSRS recommended that Nuclear Power (NUC PR) implement requirements regarding transferred material.
A copy of the original controct should be in the possession of and used by the receiving site during receipt inspection, and QC documentation required with the transfer should be specifically identified.
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: fSQM-NSRS SPECIAL PROGRAM
-j REVISION NUMBER:
0-PAGE 28 0F 37 At SQN requisitioning of material and equipment is carried'out under Standard Practice SQA-45 whether the procurement is by transfer or purchase.. The requirements for transferred items state that they shall be subject to the same reviews and approvals.as'a purchase requost or requisition. The Contracts Engineering Group (CEG) is charged with verifying the adequacy of QA and technical requiremooln of all requisitions. SQA-45 further mandates that each transfer requisition include a requirement that the supplying organization provido a copy of the contract on which was originally purchased.
i From an inspection standpoint, SQN Administration Io*Lruction AI-11 requires the receipt inspector to verify existence of the original contract in the documentation packages provided with any transferred item. AI-11 also places responsibility for the receipt inspection of QA Level I, II, and III items with the respective site manager.
Based on ECTG's evaluation, it is concluded this NSRS issue has been satisfactorily addressed. The issuo is'c}osed.
(Closed) R-84-17-NPS-06, BFN power Stores Receipt Inspection Clerks Not i
Trained to Inspect Material In the original review, NSRS concluded that power stores clerks were not trained to receive materials with Certificates of Conformanco (COC),
Certified Mill Test Reports (CMTR), or other similar QC documentation.
The NSRS report identified instances where personnel performed coroipt inspection and acceptance of material. incorrectly..NSRS recommended that the Division of Nuclear Power revise the Operations Quality Assurance-Manual (OQAM) to prohibit receipt inspection of material with QC documentation, except by qualified QC inspectors.
]
ECTG's investigation found that the SQN Administrative Instruction AI-11 governs receipt inspections.
Specifically, it states that the Site Quality Manager's organization is responsible for receipt inspection of; a.
QA Level I, II, and III items b.
QA Lovel Is, IIs, and IIIe services A QA survey performed in 1986, covering 1983-1986, revealed one receipt
~
inspector whose certification had lapsed for a short int erval.
This survey resulted in a Corrective Action Report (CAR SQ-86-01-003).
The response to this CAR resulted in a strengthening of the certification process and its attendant record keeping function.
]
ECTG's investigation concludes this issue has been satisfactorily addressed. This NSRS item is closed, l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: -SQN-NSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 29 0F 37 (Closed) R-84-17-NPS-07, Material With Limited Shelf Life Not Reordered In A Timely Manne,r In the original review, NSRS concluded that Browns Ferry was not ordering material with sufficient lead time to have new material on hand before existing material shelf life expired. The NSRS recommended the following program changes:
a (1) Revise the Operational. Quality Assurance Manual (0QAM) to establish programs to inspect and reorder limited shelf life material; (2) Reorder lead ' time should be re-evaluated and adjusted-as necessary.
ECTG's investigation revealed that SQN Power Stores engincors are reviewing all Limited Shelf Life items to establish required reorder lead time and stock quantity. This information is being inputted to the Materials Management System (MAMS) to facilitate automated reordering.
The work effort is tracked by the Tracking and Reporting of Open Items System (TROI) under CAR-86-046.
Based on ECTG's review of this issue, it is concluded that this NSRS item has been properly addressed. This item is closed.
(Closed) R-84-17-NPS-08, Materials Management System (MAMS) Under Utilized In the original review, NSRS concluded that the MAMS System was being under utilized in that its capability to track inventory' items usage and to reorder items automatically was not being used.
Additionally, the MAMS program lacked any quality assurance controls to prevent unauthorized changes to specifications or other information.
NSRS recommended the following program changes:
Office of Nuclear Power (ONP) power stores and materials management services should jointly increase efforts to utilize MAMS in the most J
effective manner possible.
ECTG interviewed the SQN Materials and Procurement Support Section (MPSS)
Supervisor, who revealed that the MAMS system is being utilized to generate orders for min / max items, and that it is being loaded with data to allow it to reorder Limited Shelf Life items.
Further, MPSS personnel are presently undergoing training on MAMS capabilities and operation.
Specifications utilized by MAMS have been placed under the exclusive control of Division of Nuclear Engineering (DNE) to prevent unauthorized j
changes.
Based on ECTG's review, it is concluded that this NSRS issue has been properly addressed.
This item is closed.
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SQid-NSRS-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 30 OF 37 (Closed) R-84-17-NPS-09, 10 CFR Part 21 Requirements Incorrectly Linked to Nuclear Power QA Requirements In the original review, NSRS concluded that the manufacturing quality and receipt inspections were automatically reduced when 10 CFR Part 21 requirements were determined not applicable.
Also, the requirements of the Operational Quality Assurance Manual (0QAM), Part III, Section 2.1, Appendix F, Attachment 1 were deficient in that if an item was determined to be commercial grade, then its effect upon or use within a critical system or component could (incorrectly) be ignored.
NSRS recommended the following program changos:
1.
Remove the influence of 10 CFR Part 21 applicability upon the determination of required quality levels for items or services.
I 2.
Revise OQAM Part III, Section 2.1, Appendix F accordingly.
3.
Retrain all personnel involved in the procurement cycle.
4.
The OQAM shall be formatted so that all questions on the applicability form are answered whether or not 10 CFR Part 21 is applicable to the item or service.
ECTG's evaluation found that the NQAM, Section 2.1 includes a rovised checklist Appendix F - Attachment 1, for determining basic component status and 10 CFR Part 21 applicability.
Use cf the checklist is mandated for all QA level I and II, or III purcnases. The format of this checklist ensures that 10 CFR Part 21 requirement are included with the documentation of any part or service which could cause a basic component not to perform it safety-related function or is connected with the design inspection, testing or consulting services important to safety that are associated with basic components.
The SQN Standard Practice for Quality Control of Material and Parts and Services (SQA 45) echoes the NQAM requirements.
The SQN instruction governing receipt inspections (AI-11) does not j
differentiate between items procured under 10 CFR Part 21 and other items.
A complete inspection by QC is mandated for all QA material, while Power Stores personnel perform inspection on non-QA items.
10 CFR Part 21 status is not a factor in the application of receipt inspection requirements.
ECTG's evaluation of this issue concludes it has been satisfactorily addressed and is closed.
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SQN-WSRS-3 SPECIAL PROGRAM REVISION NUMBER:
0 PAGE 31 0F 37 (Closed) I-84-31-BFN-01, Investigation of Potential Significant Events In the original report, NGRS recommended that NUC PR should establish an ongoing program to provide internal investigations of potential significant events. This recommendation was made following inumt'i<jat ion of an inadvertent unit 3 startup from cold condition with the RHR in shutdown cooling mode. The NSRS report stated that plant procedures should provide for well qualified and diversified internal review teams to investigate potential significant events.
l ECTG reviewed the functions of the SQN Plant Operations Review Staff (PORS) and the SQN Independent Safety Engineering Group (ISEG).
Documentation reviewed included Program Manual Procedure (PMP) 0604.05,
" Independent Safety Engineering Group (ISEG) Independent Review;" SQN Standard Practice SQA-84, " Potential Reportable Occurrences;" SQN I
Standard Practice SQA-11.7, " Responsibilities of IGEG;" GQN FSAR, pages 13.1 - 29.31 (PORS and PORS Supervisor duties); and the Nuclear Performance Plan Volume 1.
It was verified by ECTG that an ongoing workable program of internal investigation has been established at SQN.
Based on this program, the NSRS issue is closed.
(Closed) I-84-31-BFN-02, Interpretation of Requlatory Requirements i
The original NSRS report stated that the technical specifications violated during a full power shutdown margin test were perceived to be of the gray area type that could be interpreted differently with justification.
NSRS recommended that ONP management identify those areas i
of regulatory requirements, including technical specifications, that represent interpretation problems.
Operator training should be modified to include specific attention to the changes resulting from this effort.
ECTG reviewed the current Sequoyah documentation on this topic including Program Manual Procedure 0604.06, " Technical Specification Interpretations;" SQN Standard Fractice SQA-30, " Responsibility for Technical Specification Changes;" and, SQN Standard Practice SQA-12.1,
" Technical Specification Interpretation." It was determined that these documents are adequate to establish a program which ensures Technical Specification interpretation problems receive appropriate attention.
It was verified that the established operator training progrem covers the Technical Specification Interpretations. Topics for operator training are taught periodically during requalification training as the need is recognized, and changes to instructions are reviewed by operators continuously as part of their training requirements.
Based on SQN's established program for Technical Specification interpretation and training, this NSRS item is closed.
q TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQ MtlSRS-3 SPECIAL PROGRAM REVISION NUMBER: O PAGE 32 OF 37 i
(Closed) I-84-31-BFN-03, Interpretation of Requlatory Requirements The original NSRS report concluded that a number of technical specification interpretations by line personnel were incorrect during a full power shutdown margin test. NSRS recommended that ONP establish a policy and procedures for the interpretation of regulations for plant operation under temporary Technical Specification modifications, waivers, or exceptions.
ECTG verified that policy and procedures for the interpretation of regulations are in place at SQN. The.ONP policy and procedure are identified in procedure 0604.06 " Technical Specification Interpretations" and implemented at SQN by Standard Practice SQA-121, " Technical Specification Interpretations". The documents outline a program to ensure that nuclear regulations are thoroughly analyzed and a conservative interpretation placed upon them.
Based on this program, the N3RS issue is closed.
(Closed)
I-84-31-DFN-04, Commitment to Procedural Controls The NSRS report stated that after a number of prm olurn violations during a full power shutdown margin test, line personnel made little effort to show NSRS that procedural controls were of paramount importance.
The NSRS recommended that the Office of Nuclear Power (ONP) establish a written policy that would ensure the control of, adherence to, and effective implementation of procedures.
ECTG reviewed the TVA Nuclear Performance Plan, Volume I - Corporate, and Volume 2 - Sequoyah, which commit TVA to strict procedural controls.
Based on ONP's and Sequoyah's documented commitments, this NSRS item is closed.
(Closed) R-84-32-NPS-01, Inadequate TVA Quality Program The NSRS report stated that action was incomplete on developing and implementing an integrated quality program that includes the following attributes consolidated from previous NSRS findings:
1.
Identification of activities affecting quality.
2.
Identification of components, systems, structures to which the quality program is applied.
3.
Identification and definition of industry standards and guidance for control of activities outside the scope of regulatory requirements.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
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REVISION NUMBER: O l
PAGE 33 0F 37 4.
Improvement of the Office of Engineering (OE) quality program and procedures and acceptance of the OE quality program by the Offico of j
Nuclear Power.
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S.
Incorporation of vendor data into a configuration managenent control I
system.
l NSRS recommended that the Office of Nuclear Power as owner-operator should assure that the integrated quality program, currently being planned and developed, wi.ll account for the identification and cont rol of the attributes listed above.
As discussed in TVA's Corporate Nuclear Performance Plan, Volume 1, the responsibility for the various quality assurance functions is now cor slidated under the Director of Nuclear Quality Assurance. The TVA Top..al Report was revised and submitted to the NRC, and received NRC's approval (Topical Report, Revision 9) on January 30, 1987. The Nuclear Q%11ty Assurance Manual (NQAM) is being revised to reflect strong l
centralized control of the sito's QA programs.
Responn i.Ility has been established with the Division of Nuclear Quality Assuran
- for their review of and concurrence with all new ONP procedures, A ;tew corporate cor.ective action program to ensure timely resolution of deficiencies is wei underway This new program is described in the SQN Nuclear Performance Plan,Section II.2.5.
The QA organization at SQN has been restructured to provide that all site i
QA groups report to the site Quality Manager. This reporting policy includes the Engineering Assurance organization, which will help ensure that DNE quality -elated issues are addressed under the overall quality ass..ance program.
The site Quality Manager at SQN stated that significant progress has been made in upgrading the QA program including establishment of tho quality improvement (QI) organization, development of a trending program, and upgrading of the SQN Q-List of components, systems, structures to which the quwlity program is applied.
Based on the above corrective actions for the SQN quality assurance program, this NSRS item is closed.
(Open) I-84-33-BFN-07, Pipinq Analysis Not Satisfactory NSRS concluded that the Office of Engineering (OE) did not perform generic evaluation of problems identified in " Evaluation of WBN Piping Analysis Review Team's Report," July 1982.
Conclusions of the 1982 report were:
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQW-NE2S-3 SPECIAL PROGRAM REVISION NUMBER:
O PAGE 34 OF 37 l
Piping analysis criteria are inaccurate and incomplete o
Documentation of WBN piping analysis in MEDS is.i n n mpl e t.e o
Procedures for performing, verifying, and documenting WBN piping o
analysis do not omist Training is not adequate o
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I Independent review is locking o
QA aeditors are not auditing to requirements of the controlling j
o documents l
NSRG recommended that the problems be reviewed, root causes determined, and corrective action established. The problems found at WBN wore reviewed for applicability to SQN.
ECTG's investigation found that the above referenced issue could not be verified as being closed.
CATD I-84-33-BFN-07 has been initiated to resolve this issue.
This NSRS issue will remain open until CATD I-84-33-BFN-07 (SQN) h,o been satisfactorily completed and closed.
(Closed)
I-84-33-BFN-08, Failure of QA to Perform Audits and Surveillance of Identified Problem Areas Within Piping Ana_ lysis Sectio.ns The NSRS report stated that no audits or surveillance had been conducted or were scheduled to be performed by QA organizations of the urn Piping Analysis Section.
No audits / surveillance were performed to verify the implementation and effectiveness of the piping analysic section procedures.
NSRS recommended performance of annual audits to ensure that procedures and design criteria are being followed, and to evaluate effectiven9ss of the piping analysis programs.
ECTG reviewed applicable documentation and determined that the 1986 Division of Nuclear Engineering (DNE) Audit Plan (BOL 870310 001) and luu/ DNE Program Audit Schedule (805 870303 002 and B05 870119 009) now require and schedule periodic audits of the piping analysis program. The SQN audit " Seismic Category IL Piping Interaction Analysis was performed and reported October 21, 1986 (805 861021 002).
Based on the requirements in place, and the scheduling and performance of audits in this area, the NSRS item is closed.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SQW-MSRS-3 SPECIAL PROGRAM REVISION NUMBER: O PAGE 35 0F 37 (Closed) I-84-34-SQN-01, Failure to Follow QA Procedures by an Individual at SQN The NSRS report stated the alleged failure to follow QA procedures by individual "A" for the two exraples cited by individual "D" were substantiated.
NSRS recommended that QA conduct a survey of indavidual "A's" activities to determine other areas where he could have potentially failed to follow QA procedures and their safety implications.
}
ECTG's investigation revealed that the Construction Quality Assurance Branch (CQAB) reviewed individual n's activities and documented results of the review in memorandum C01 850515 005 dated May 15, 1985, "SQN Office of Construction Response to NSRS Report Number 1-84-34-SQN."
NSRS l
found the response " acceptable based on preliminary review."
(QO1 05020 j
I
)
050)
ECTG further verified that inspection performed by individual A in other l
areas were performed in accordance with applicable procedural requirements.
Based on ECTG's review, this NSRS issue has been properly addressed. The NSRS item is closed.
(Closed) I-84-34-SQN-02, Completion of TVA Mark Letter Description on the Transfer Requisition Documents The potential oi Non-Class 1E cable to be installed in a Class 1E System appears to be greater when cables are transferred from one site to i
another site where the TVA cable mark letters do not define the same cable at both sites.
SQN stated (805 050419 004) that transfer requisitions now define the classification of cable and stipulate any restrictions in its use.
This was acceptable to NSRS based on preliminary review by NSRS on May 20, 1905.
(QO1 850520 050).
SQN material control personnel stated, based on a review of 500 requisitions (not necessarily cabling requisitions) that there was no longer any EQ problems in this area.
(May 14, 1987 interview)
In addition, SQN Administrative Instruction (AI-36), requires comprehensive identification on the item or its container of all CSSC material.
Based on ECTG's investigation, it is concluded that this NSRS issue has been satisfactorily addressed.
This item is closed.
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O PAGE 36 0F 37 (Closed) I-85-06-WBN-04, Timely and Responsive Corrective Actions for Resolution of Identified Problems The original NSRS report concluded that the quality assurance verification program for electrical engineering and design activitine was inadequate based on problem areas being identified by organizations outside QA.
It was recommended that the Quality Management Staff of the Office of Engineering should plan, schedule, and conduct verification activities which include verification of technical issues, i.e.,
verification of technical adequacy.
The Division of Nuclear Engineering provided, for ECTG review, the copies of the FY 86 and FY 87 audit schedules (EA-I 65.03, " Quality Audit Schedule - Preparation and Distribution), as well as the instruction for technical and program audits (FA-I 65'.04, " Engineering Assurance Internal Audit Program"). The schedules identified at least eight elect rical engineering audits in 1986 and additional ones in 1987. The guidance for verification of technical issues was verified to be included in the Division of Nuclear Engineering (DNE) procedures.
Based on the above review, ECTG concludes this issue is closed.
(Open) R-85-07-NPS-01, Manager of Power and Engineering Appointment of A Records Manager NSRS found that no upper management coordination entity was available as a focal point for resolution of programmatic problems regarding accumulation, storage, transfer, and retrieval of the records for procurement requiring Quality Engineering Branch (QEB) source inspection.
NSRS recommended that an upper-level manager be assigned with responsibility to include all past and future product verification records (formally QEB records).
This issue was originally investigated by NSRS in 1983 by report I-83-13-NPS and resulted in establishing a Task Force to provide resolution. The Task Force was functionally operational from December 1983 through April 1984, however did not resolve the issue.
After the disbandment of the Task Force in 1984, a subsequent review was performed by NbRS and recorded by this report R-85-07-NPS-01.
This review verified that this issue was still unresolved.
The ECTG investigation substantiated the NSRS finding as being factual and issued CATD R-85-07-NPS-01 to ensure tracking and completion of this issue.
This NSRS item will remain open until CATD R-85-07-NPS-01 is completed and closed.
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O PAGE 37 0F 37 (Closed) Fourteen Safeguards Items 3dentified In Section I The following action was taken by ECTG to verify the closure of 14 NSRS safeguards issues listed in section I:
A review of documents, procedures, and TVA codes was performed to determine if reassignment of responsibility of the nuclear security program had been accomplished as indicated in memorandum L46 870520 884.
This review deter mined t hat the Office of Nuclear Power now has overall responsibility for the nuclear
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security program.
)
The TVA Code XI has delegated the responsibility for managing the security program for TVA's nuclear power plants with Public Safety Service (PSS) providing equipment and training of the security force.
)
)
Other DNP documents reviewed by ECTG that outline the responsibility of nuclear security include the following:
Procedure 0401.01 Procedure 0401.02 Procedure 0401.03 Procedure 0401.04 Procedure 0401.05 Procedure 0402.01 ONP Directive 10.1 (Draf t copy)
Policy and Organization Manual Volume 1 and 2 ONP organization charts TVA Nuclear Security Program Enhancement Security Personnel Training and Qualification Plan Based on the review of the above documents, the 14 NSRS issues found in NSRS reports R-82-01-PSS, R-83-16-NPS, and R-84-06-NPS; and the corrective action taken by ONP as outlined in memorandum L46 870520 884, these issues are considered complete and closed.
6.0 ATTACHMENTS CATD 79-09-01-1, Wire Lifting Practices CATD 79-09-01-2, Wire Lifting Practices CATD 79-09-01-3, Wire Lifting Practices CATD R-81-14-0EDC (BLN)-41, Auditor Training CATD I-84-33-BFN-07, Piping Analysis CATD R-85-07-NPS-01, QEB Records fMnager
1 ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECTG Corrective Action Tracking Document (CATD)
INITIATION
^
Applicable ECTG Report No.:
ECTG-NSRS-02 1.
Immediate Corrective Action Required: O Yes C No l
2.
Stop Work Recommended: O Yes N No 3.
CATD No.
79-09-01-1
- a..
INITIATION DATE 04-29-87 5.
RESPONSIBLE ORGANIZATION:
SON Site Director 6.
PROBLEM DESCRIPTION: 10 QR O NQR NSRS. Report 79-09-01-1 excessive wire lifting ocictices to facilitate testing.
In 1979, testing of protective relays, meters, indicating instruments, and transducers on the 480 volt shutdown boards.
6900 volt shutdown boards, and diesel generetor boards could not be performed without lifting leads, installing test leads, removing test leads, and reterminating board wiring.
(
ID ATTACHMENTS 7.
PREPARED BY: NAME Don.Cossett As F o E R DATE: 6-Z9ePr 8.
CONCURRENCE: CEG-Il 8 % d T. u m., /
DATE:
4 /.:t 9 / F 7 9.
APPROVAL:
ECTG PROGRAM MGR.
// / 9 M -
M DATE: 4&#e 7_
/ /
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
l O ATTACHMENTS 11.
PROPOSED BY:
DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
~
ECTG PROGRAM MANAGER DATE:
(
VERIFICATION AND CLOSEOUT 12.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE i
5108T D
9 L____.____
1 FACT SHEET 79-09 1 Excessive Wire Lifting Practices to Facilitate Testing The above referenced NSRS concern was initiated in 1979 at WBN and was also determined to be generic to SQN.
It stated that testing of protective relays, meters, indicating instruments, and transducers on the 480 volt shutdown a
boards, 6900 volt shutdown boards, and diesel generator boards could not be performed without lifting leads, installing test leads, removing test leads, and reterminating board wiring.
SQN-DCR-305 was initiated for the purpose of installing test blocks in the equipment but was disapproved by En Des because the testing intervals at that time were considered too infrequent to justify installation.
On December 18, 1979, SQN-DCR-457 was initiated to install test blocks in the referenced equipment. The DCR was approved and ECN-L5360 was issued to implement the change.
As a result of the ECN, all applicable drawings were revised to reflect the change, however, no wort was ever performed to implement the ECN.
On 4-1-86 a letter was issued, RIMS S 53860422811, canceling ECN-L 5360 and giving directions to ensure that applicable drawingsreflect the cancellation.
The NSRS corrective action recommendation stated that DNP should submit a DCR to define where test blocks were needed and also provide a point of contact to assist EN DES in the design.
(SQN-DCR-305 was written but disapproved).
ECTG recommends that test blocks similar to those at Watts Bar be installed at
- SQN, rince the intervals for testing at this time are different than those used at the time DCR 305 was disapproved in 1979.
Inform ECTG of corrective action taken.
510BT
~
Page 1 of 1
1 4
1 ECTG C.3 Attachment'A Page 1 of 1 Revision 2 ECTG Corrective Action Tractint Document (CATD) i
' INITIATION
~
Applicable ECTG Report No.:
ECTG-NSRS-02 1.
Immediate Corrective Action Required: O Yes E No 2.
Stop Worlt Recommended: O Yes 3 No 3.
CATD No.
79-09-01-2 4.
INITIATION DATE 04-29-87 l
S.
RESPONSIBLE ORGANIZATION:
SON Site Director 6.
PROBLEM DESCRIPTION: jib QR O NQR NSRS Report 79-09-01-2 I
Excessive wire liftint practices to facilitate testing In 1979. EN DES was reauested to install test bloets on the diesel j
tenerator logic and control board and the 6900V and 480V shutdown boards for relays, meters, indicating instruments, and transducers to facilitate testint. SON-DCR-305 was written to accomplish this tack.
EN DES reiected the DCR and the blocks were not installed.
E ATTACHMENTS 7.
PREPARED BY: NAME Don Cossett %)ou /dm zXC DATE: 4-29-/7 8.
CONCURRENCE: CEG-H N/ e DATE: c /.29 /t ?
9.
APPROVAL:
ECTG PROGRAM MGR4 df46 /L.
A DATE: //2 W W y
/
/
CORRECTIVE ACTION j
)
10.
PROPOSED CORRECTIVE ACTION PLAN:
)
l O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
~
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSE0UT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATF O
5108T
'p I
3 9
__.__._.___________a
FACT SHEET 4
79-09-01 Excessive Wire Lifting Practices To Facilitate Testing The above referenced NSRS contarn was initiated at WBN in 1979 and was also determined to be generic to SQN.
It stated that EN DES was requested to i
install test blocks on the diesel generator logic and control board and the 69007 and 480V shutdo'wn boerds for relays, meters, indicating instruments, and transducers to facilitate testing, SQN-DCR-305 was initiated to accomplish this task.
EN DES rejected the DCR and the blocks were not installed.
l i
SQN-DCR-305 was initiated for the purpose of installing test blocks in the equipment but was disapproved by EN DES because the testing intervals at that time were considered too infrequent to justify installation, j
On December 18, 1979 SQN-DCR-457 was written to install test blocks in the referenced equipment. The DCR was approved and ECN-L 5360 was issued to implement the change.
As a result of the ECN, all appliance drawings were revised to reflect the
]
change, however, no work was ever performed to implement the ECN.
)
ON-4-1-86 a letter was issued RIMS number $538860i.22811, canceling ECN-L 5360 and giving directions to ensure that applicablo drawings reflect the cancellation.
'The NSRS Corrective Action Recommendation stated that DNP should submit a DCR to define where test blocks were needed and also provide a point of contact to assist EN DES in the design.
(SQN-DCR-305 was written but disapproved.)
ECTG recommends that test blocks similar to those at Watts Bar be installed at SQN sfincetheintervalsfortestingatthistimearedifferentthanthose y
used at the time DCR 305 was disapproved in 1979.
Inform ECTG of Corrective Action taken.
5108T
. Page 1 of 1
1 ECTG C.3 I
Attachment A Page 1 of 1 Revision 2 i
ECTG Corrective Action Trackint Document (CATD)
{
INITIATION Applicable ECTG Report No.:
ECTG-NSRS-02 1.
Immediate Corrective Action Required: 0 Yes M No 2.
Stop Wort Recommended: O Yes S No 3.
CATD No.
79-09-01-3 4.
INITIATION DATE 04-29-87
)
J 5.
RESPONSIBLE ORGANIZATION: SON Site Director 6.
PROBLEM DESCRIPTION: 5 QR O NQR NSRS Report 79-09-01-3 Excessive wire liftint practices to facilitate testing.
]
In 1979. during times of testing, as many as fifty (50) wires, all of the same color are lifted and reterminated which creates a potential for damering eculpment or injurying personnel.
El ATTACHMENTS 7.
PREPARED BY: NAME Don Cossett f)ou (ibewJ'Z DATE: 4 - ? 9 - //
8.
CONCURRENCE: CEG-H
- fe dt )- A se v / /
DATE:
6/J 9/ r ?
9.
APPROVAL:
ECTG PROGRAM MGR.
dffFM 4r? DATE:
U.5d/F-7
/ '
/
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-E:
DATE:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE 5108T g
-)
FACT SHEIT 79-09-01 Excessive Wire Lifting PracticeuLTo Facilitate Testing The above referenced NSRS concern was initiated at WBN and was'also determined to be generic to SQN.
It stated that in 1979, during times of testing, as many as fifty (50) wires, all of the same color, are lifted and reterminated which creates a potential for' damaging equipment or injuring personnel.
~
SQN-DCR-305 was initiated for the purpose of installing test blocks in the equipment but was disapproved by EN DES because the testing intervals at that time were considered too infrequent to justify installation.
On December 18, 1979 SQN-DCR-457 was written to install test blocks in the referenced equipment. The DCR was approved and ECN-L 5360 was issued to implement the change.
As a result of the ECN, all applicable drawings were revised to reflect the change, however, no work was ever performed to implement the ECN.
On 4-1-86 a letter was issued. RIMS number S 53860422811, cancelling ECN-L 5360 and giving directions to ensure that applicable drawing reflect the l
cancellation.
I The NSRS Corrective Action Recommendation stated that DNP should submit a DCR
]
to define where test blocks were needed and also provide _a point of contact to assist EN DES in the design.
(SQN-DCR-305 was written but disapproved.)
ECTG recommends that test blocks similiar to those at Watts Bar be installed' l
l at SQN since the intervals for testing at this time are different than tho8e j
used-at the time DCR 305 was disapproved in 1979. Inform ECTG of Corrective Action taken.
i l
i 5108T Page 1 of 1 O
9
l c
ECTG C.3 Attachment A Page 1 of 1 Revision 4 I
ECTG Corrective Action Tracking Document (CATD) q INITIATION Applicable ECTG Report No.:
ECTG-NSRS-02 1.
Immediate Corrective Action Requi'ed: O Yes M No
~
r 1
2.
Stop Work Recommended: O Yes E N'o 3.
CATD No.
R-81-14-0EDC(BLN)-41 4.
INITIATION DATE 05-13-87 5.
RESPONSIBLE ORGANIZATION:
SON Site Director 6.
PROBLEM DESCRIPTION: 5 QR O NQR NSRS Retort R-81-14-0EDC-(BLN)-41 l
OAB Auditor Training l
I EN DES has not developed or established an approved program for auditor training.
~
S ATTACHMENTS 7.
PREPARED BY: NAME Don Cossett (/Jea M DATE:
05-13-87 DATE:
f/32/ f ?
8.
CONCURRENCE:
CEG-H GAL /Av e.
i 9.
APPROVAL:
ECTG PROGRAM MGR.
/9f/4/l
- n DATE:
lo/70 4 7
/ /
gy l
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
)
l l
1 i
l 1
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER DATE:
VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE 5108T k
J
FACT SHEET R-81-14-0EDC-(BLN)-41-QAB AUDITOR TRAINING The above referenced NSRS concern was initiated in 1981 at BLN and was also determined to be generic at SQN.
It stated that EN DES failed to establish a written approved program for training auditors.
The Engineering Assurance (EA) organization within DNE does not have a formal
' procedure that gives direction for training personnel as auditors. However, new auditors within EA are being given auditor training at POTC.
POTC is currently conducting auditor training and at the same time developing a training standards manual. The manual is scheduled to be issued on 11-29-87 and will include, in part, the following training courses presently used in POTC training.
A) QAT 008 - Introduction to Auditing B) QAT 002 - Observation Training For QA Audit Personnel C) QAT 007 - Codes and Standards D) QAT 010 - Advanced Auditing Techniques The NSRS Corrective Action Recommendation suggested that QAB develop an administrative procedure delineating QA training requirements and provisions for management approval of QA auditor training programs.
ECTG recommends that DNE initiate a procedure to provide guidance for auditor training, using the established POTC program as a means to implement the procedure.
i l
l 5108T Page 1 of 1 k.__.______-__
_.___.__m_
m
.-____..-_._____..__._.__m....______a
~l l
i ECTG C.3 Attachment A Page 1 of 1 Revision 4 ECTG Corrective Action Tracking Document (CATD)
INITIATION Applicable ECTG Report No.:
SON-NSRS-3 1.
Immediate Corrective Action Required:
E2 Yes O No 2.
Stop Work Recommended: O Yes ED No 3.
CATD No.
I-84-33-BFN-07 (SON) 4.
INITIATION DATE 7/24/87 5.
RESPONSIBLE ORGANIZATION:
SON Site Director 6.
PROBLEM DESCRIPTION: 3 QR O NQR NSRS Report I-84-33-BFN - NSRS concluded that the Office of Engineering did not perform generic evaluation of problems in the piping analysis area.
See attached sheet for details. The NSRS recommendation should be followed.
Sequoyah Element Report 218.4(B) contains related issues.
5 ATTACHMENTS 7.
PREPARED BY: NAME W Z Em DATE:
f/.2d/ P 7 8.
CONCURRENCE: CEG-H (U/J,2A,a DATE:
p/au/ f'7 9.
APPROVAL: ECTG PROGRAM MGR.
/
DATE:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
l l
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
ECTG PROGRAM MANAGER DATE:
i VERIFICATION AND CLOSE0UT 13.
Approved corrective actions have been verified as satisfactorily implemented.
i SIGNATURE TITLE DATE I
6388T w~-__________._--____....__
-J.
EXTRACT FROM REPORT SQN-NSRS-3 (0 pen) I-84-33-BFN-07, Piping Analysis Not Satisfactory NSRS concluded that the Office of Engineering (OE) did not perform a generic evaluation o,f problems identified in " Evaluation of WBN Piping Analysis Review Team's Report," July 1982. Conclusions of the 1982 report were:
- Piping analysis criteria are inaccurate and incomplete
- Documentation of WBN piping analysis in MEDS is incomplete
- Procedures for performing, verifying, and documenting WBN piping analysis j
do not' exist j
- Training is not adequate i
- Independent review is lacking l
- QA auditors are not auditing to requirements of the controlling documents NSRS recommended that the problems be reviewed, root causes determined -and-corrective action established. The problems found at WBN were reviewed for applicability to SQN ECTG's investigation found that the above referenced issue could not. be verified l
as being closed CATD I-84-33-BFN-07 has been initiated to resolve the issue This NSRS issue will remain open until CATD I-84-33-BFN-07 (SQN) has been satisfactorily completed and closed.
s i
e 9
6388T J
4 ECTG C.3 Attachmsnt A Page 1 of 1 Revision 3 ECTG Corrective Action Tracting Document (CATD)
INITIATION Applicable ECTG Report No.:
ECTG-NSRS-SON-01 1.
Immediate Corrective Action Required: O Yes 2 No 2..
'Stop Work Recommended: 0 Yes ll5.. No 3.
CATD No. R-85-07-NPS-01 4.
INITIATION DATE 2/14/87 5.
RESPONSIBLE ^ ORGANIZATION: SON Site Director 6.
PROBLEM DESCRIPTION: jib QR O NQR NSRS Report R-85-07-NPS-01 A Manager should be designated with authority / responsibility to ensure that records of OEB source inspected equipment and materials are indexed and stored. The scope should include all past and future OEB source inspected procurement records for SON. VBN.
and BLN.
3 ATTACHMENTS 7.
PREPARED BY: NAME T. V. Hunt ~7Zdh-v DATE:
4/22/P7 8.
CONCURRENCE:
CEG-H A. G. Debbare dA4.//w DATE:
4/22/87 9.
APPROVAL: ECTG PROGRAM MGR.
t##f%/l,
'/~n DATE:
//5eVf ?
O'
/ /
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE Af. ION PLAN:
D ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
DATE:
ECTG PROGRAM liANAGER VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE IITLE DATE S138T h
O
^'
FACT SHEET R-85-07-NPS-01 Manager of Power and Engineering Designation of A Records Manager NSRS found that no upper management coordination entity was available as a focal point for resolution of programmatic problems regarding accumulation, storage, transfer, and retrieval of the records for procurement requiring QEB source inspection.
NSRS recommended that an upper-level manager be designated with authority /_
responsibility for past and future product verification records (formally QEB l
records). NSRS also recommended verification that WBN vendor records are identified, indexed, stored, and retrievable.
Corrective Action for the managerial designation was previously taken, j
H. G. Parris named Robert A. Pedde on August 14, 1985. After subsequent
)
promotion, no replacement was named for R. Pedde.
j Corrective action for the processing of records is progressing.
Employee Concern Program (ECP) investigation report ECP-86-KX-055-01 found a great deal of progress had been made since the initial NSRS investigation in 1983. QEB records were found to be in place for SQN, and completion date of December 1987 seemed likely for WBN.
ECTG concurs with the NSRS recommen.dation that an upper-level manager be designated with authority and responsibility for management of past and future product verification records. A CATD for this same subject has been issued for WBN.
l 5138T l
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Page 1 of 1 I
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