ML20236B348

Rev 0 to TVA Employee Concerns Special Program Seqouyah Element Rept 207.4(B), Deviation Documentation:Caq Documentation

ML20236B348
Person / Time
Site:	Sequoyah
Issue date:	10/15/1987
From:	Clift D, Walters R, Worthy J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20236B339	List: ML20236B336 ML20236B344 ML20236B348 ML20236B351 ML20236B354 ML20236B358
References
207.4(B), 207.4(B)-R, 207.4(B)-R00, NUDOCS 8710260094
Download: ML20236B348 (17)

Text

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.TVA EMPLOYEE CONCERNS REPORT NUMBER: 207.4(B)

SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 0

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TITLE: DEVIATION DOCUMENTATION CAQ Documentation PAGE 1 0F 17

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REASON FOR REVISION:

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PREPARATION PREPARED BY:

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/ $1GNATURE REVILW5 .

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. ] SIGNATURE / G ATf TA5:

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CONCURRENCES

/[ [ M cP-[4j[f'f 8710260094 B71016 PDR ADOCK 05000327 P PDR CEG-H: W 2 -M~[

SRP f /4-/f-6 7 SIGNATURE

• DATE SIGNATURE DATE APFROY 'I L [ \ A/A

' DATE

" ~ ECSP' MANAGER q D

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( MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY) l

• SRP Secretary's signature denotes SRP concurrences are in files.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 207.4(B)

SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 2 0F 17

1. CHARACTERIZATION OF ISSUES:

Concern: Issue:

1-85-761 -NPS a. Existing practice for approval of DHE practice 'or approval of CAQ (Conditions Adverse to Quality)

CAQ Docunnntation (i.e., PIR & documentation (i.e., PIRs and SCRs)

SCR) hinders the reporting of hinders reporting of CAQs by conditions adverse to quality employees (e.g., there is no by employees. " appeal" process).

P. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES N0 X Identified by Not applicable Date Not applicable

3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:

/ No specific identifications.

4. INTERVIEW FILES REVIEWED:

Expurgated file for WI-85-761 was reviewed, and no additional unreviewed information was found.

S. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?

See Aprendix A.

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

. See Appendix A.

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8. EVALUATION PROCESS:

a. Reviewed the hierarchy of applicable documents (e.g.,

10CFR50, ANSI-N45.'2.11, PSAR, FSAR) to establish criteria requirements and pertinent TVA commitments relative to the issue in Section 1.

b. Reviewed engineering department procedures and practices relative to corrective action control to determine if they meet requirements.

c. Reviewed applicable practices for compliance to procedures and reviewed results of program audits by TVA, HRC, and INP0 as . applicable.

9. DISCUSSION, FINDINGS, AND CONCLUSIONS:

Chronology: -

Late 60s: Sequoyah (SQN) plant design begins q

'i {I 10/15/68: SQN PSAR issued mid-1969: Draft 10CFR50 Appendix B issued 06/27/70: 10CFR50 Appendix B formally issued t

09/73 - Division of Engineering Design (EN DES) Engineering l 06/85: Procedures (EPs) in effect i 1

06/06/74: ANSI N45.2.11-1974 issued 1975: TVA Topical Report TR 75-1 A initially issued 06/76: TVA commits to Regulatory Guide 1.64 which endorses ANSI N45.2.11-1974 09/27/80: Operating. License (OL) issued for SQN Unit 1 09/15/81: 0L issued.for SQN Unit 2 04/09/85: TVA Topical Report TVA-TR75-1 A, R8, issued 06/85 - Office of Engineering Procedures (0EPs). are in 06/86: effect. Superseded EN DES EPs

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08/85: TVA voluntarily shuts down SQN Units 1 and 2 l

11/01/85: TVA presents:its Corporate Nuclear Performance Plan (initial issue) and Sequoyah. Nuclear Performance Plan (Draft) to NRC. ,

03/10/86: TVA Corporate Nuclear Performance Plan (CNPP)

Volume I, R0, submitted to NRC.  ;

05/01/86: -Formal Design Baseline and Verification Program for Sequoyah, R0, issued.

06/86: TVA receives employee concern I-85-761-NPS 07/86 to Nuclear Engineering Procedures (NEPs) in effect.  ;

Present: Superseded OEPs 07/17/86: Sequoyah Nuclear Performance Plan (SQN-NPP) Volume II' l

is revised and issued as R1

... 07/22/86: TVA CNPP, Volume' I, revised (R1) i.

A "} ~ 08/13/86: TVA CNPP, Volume I, revised (R2) .

j Discussion: J

9.1 BACKGROUND

The Sequoyah Plant design was begun in the late 1960s when compliance with regulatory requirements was not required to be well documented. The majority of the SQN licensing ,

commitments were made in the late 1960s and early 1970s, and l some of the present day regulatory documents are not Sequoyah requirements. It is not necessary to update the Sequoyah Plant to include all of the new guidance published by NRC, j unless there are specific requirements or commitments to do i l

so.

}

This concern was originally raised at Watts Bar Nuclear Plant 1 (WBN). It was considered generically applicable to Sequoyah l:

Nuclear Plant (SQN) since the organization and procedures that governed SQN design were essentia11y' identical to WBN. l l

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The issue identified in this element refers to a programmatic deficiency in the engineering corrective action process. The issue is that practices within engineering require an approval' cycle for the documentation of conditions adverse to quality (CAQ) prior to issue, and that the approval cycle may hinder or prevent employees from reporting some conditions adverse to. quality.

9.2 CURRENT SEQUOYAH PROGRAMS Even if some CAQs were not documented, as implied by this

. concern, the integrity of Sequoyah safety systems will be verified prior to restart, through full implementation of Sequoyah programs now in place. These programs will be monitored by the Engineering Assurance (EA) organization.

The Sequoyah Design Baseline and., Verification Program (DBVP -

App. A, 5.r):is being implemented, and appropriate portions are to be completed prior to restart.

"The essential elements of this program are as

' follows:

"o ., Verification of actual plant configuration "o Reconciliation to engineering design documents including supporting calculations and design criteria "o Reconciliation to the icAR, licensing commitments, and technical specifications "o Performance of Safety Evaluation Reports and Unreviewed Safety Question Determinations l (USQDs)forthesystemconfiguration  ;

l "o Issuance of revised key plant drawings which are essential for operations" Additional confidence in Sequoyah Plant system integrity for restart will be derived through full implementation of the following:

o Design Basis Program (DBP - App. A, 5.s)

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o Office of Nuclear Power (0NP) - Configuration Control Task Force (CCTF - App. A, 5.t) o Design Change Process Improvements Program ( App. A, 5.u) o Sequoyah Nuclear Plant Change Control Board (CCB -

App. A, 5.v) o Specification Improvement Program ( App. A, 5.w)

All of these programs, plus ongoing TVA QA and external audits, NRC inspections, and other categories of employee concern investigations (e.g., welding, construction, ,

operations, management, QA), should provide additional confidence that there is no large probability for a major unidentified problem at Sequoyah.

9.3 REGULATOR.Y REQUIREMENTS The applicable requirements pertaining to this concern are i contained in the following:

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~- o 10CFR50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"

(App. A, 5.a) ,

o 10CFR50.55, " Conditions of Construction Pennits,"

Reporting Criteria for Significant Deficiencies 50.55(e)

(App. A, 5.b) o ANSI N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants, ( App. A, 5.d)

These criteria documents contain specific requirements pertaining to corrective action. The NRC also requires that the more significant of these deficiencies be reported in accordance with 10CFR50,55(e). Excerpts from these governing criteria documents follow:

o 10CFR50, Appendix B, Criterion XVI, " Corrective Action" states:

" Measures shall be established to assure that conditions adverse to quality, such as failures,

- malfunctions, deficiencies, deviations, defective t ..)

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matetial a'nd equipment, and nonconfomances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."

o 10CRF50.55(e) states, in part:

"The holder of the pennit shall notify the Commission of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the j safety of operations of the nuclear power plant at any time throughout the expected lifetime of the pl ant. "

!  ? o ANSI N45.2.11-1974 Section 9, " Corrective Action"

\ . states, in part:

"In addition to correcting a deficiency (or error), corrective action also includes, for significant or. recurring deficiencies (or errors),

determining the cause and instituting appropriate changes in the design process and the quality assurance program to prevent similar types of deficiencies (or errors) from recurring. A procedure shall be employed for providing such corrective action. The procedure shall also contain provisions for reporting the deficiency and corrective action to appropriate levels of supervision and management. The procedure shall also include follow-up actions that cannot be immediately completed to assure timely resolution and/or completion of the corrective action."

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1 9.4 TVA COMPLIANCE PROGRAMS AND ENGINEERING PROCEDURES SQN PSAR ( App. A, 5.g) and Sequoyah FSAR ( App. A, 5.h) through Amendment 3, updated 04/86, contr in commitments that specify requirements in compliance with the criteria of 10CFR50 Appendix B and ANSI N45.2.11 dealing with corrective f action, e.g.:

" NONCONFORMING MATERIALS, PARTS, OR COMPONENTS

" Measures to control nonconforming materials, parts, or components are prescribed in a construction procedure ' Processing of Nonconforming Material During Construction.'

This procedure includes means for identification, documentation segregation, and disposition of nonconforming items and for notification of affected organizations to prevent their inadvertent use for installation.

"The controls applicable to suppliers are g

\ fy prescribed by Quality Assurance Procedures for

'" ' Handling of_ Vendor Nonconformances.'" ,

" CORRECT.I.VE ACTION ,

" Corrective action r,sasures are prescribed in construction procecures ' Processing of "

Nonconforming Material During Construction' and

' Reporting and Documenting Conditions Adverse to Qu ali ty. ' These procedures provide for the identification and correction of adverse conditions and for the identification of the cause '

of significant adverse conditions to permit action leading towards prevention of recurrence."

TVA Topical Report TR 75-1A, Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants (App. A, 5.m) which was first issued in 1975 contains requirements that comply with the regulatory criteria. ,

Applicable engineering department procedures were reviewed to determine compliance with the above requiremen,ts:

o Sequoyah Nuclear Plant Quality Assurance Manual 1 (SON QAM - App. A, 5.1) contains procedures that comply

\.,;)/ with corrective action criteria, e.g.:

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- SQN-QAP-IV-6.2 Procedures for Handling i Nonconforming Material Parts, or Components During Construction

- SQN-QAP-IV-6.3 Procedure for Reporting and Documenting Conditions Adverse to Quality Although these procedures comply with the regulatory ,

criteria, they specify a _ sequence of approval steps'for  !

issuance of CAQ reports. They do not provide recourse for the reporting employee to circumvent undue restrictions in the event of disagreement between the l originator and supervisor t. bout the validity of the concern.

o EN DES Engineering Procedures Manual ( App. A, 5.j) contains procedures that address the requirements pertaining to CAQ control and demonstrate TVA cognizance of the need for controlling procedures.

However, they also do not provide recourse for the

.- reporting employee e.g., EN DES-EPl .26 Rev. 9

( d. paragraph 5.2 step 2 specifies the procedure for

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processing a potential NCR, prior to documenting the condition:

"2. Works with his immediate supervisor to determine who has technical responsibility." '

This provides an opportunity for the concern to be suppressed should the immediate supervisor be motivated .

to nonaction or coverup of errors, etc. No recourse is l available to the employee should this occur. Another  !'

potential for suppressing employee concerns occurred in step 6 when, subsequent to recording the condition on an EN DES NCR form, the reporting employee "6. Immediately submit to his supervisor.9"the

• potential NCR l

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• A supervisor (M-5 section supervisor or above) in an EN DES Sranch or project, nonna11y having supervisory and technical ,

- responsibility in the area addressed by the NCR." l

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4 Again it w'as possible to circumvent further processing of the NCR should the section supervisor be so j motivated. No recourse was specified for the employee should this occur. These procedures were in effect ,

from September 1973 through June 1985. l o Office of Engineering (0E) Management Manual ,

( App. A, 5.k) contains OEP-17, R2 " Corrective Action," I which complies with the applicable regulatory criteria and establishes policy applicable to all- OE employees and which states in part "Each OE employee is responsible to identify and document any CAQ which I renders an item unacceptable to perform its required function or creates -l uncertainty concerning its ability to I meet design requirements." l l

"All OE employees are responsible for immediately documenting any CAQ ,

identified and to promptly evaluate l

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generic implications especially with ,;

respect to OL nuclear plants. If the CAQ represents an immediate threat to  !

health and safety at an operating 1, nuclear plant, the appropriate division director is to be intnediately notified for notification to the affected site .

director." f This procedure is very thorough and fully complies with the applicable regulatory criteria. OE employees are free to, and in fact responsible to, immediately document any CAQ, and the procedures establish records of all processing, concurrence, approval, and issuance steps in the CAQ cycle. They do not, however, provide j recourse for the reporting employee to circumvent undue l restrictions should they occur, or if he questions a 1 decision regarding the CAQ report by any of the (

personnel responsible for concurrence and/or approval. 1 These procedures were in effect from July 1985 through j f

June 1986.

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.w o TVA Division of Nuclear Engineering (DNE) Procedures l Manual ( Agp. A, 5.1) contains the current procedure, l NEP-9.1, Corrective Action," issued R0 July 1,1986, ^

which complies with the applicable criteria and also provides measures enabling the originator of a CAQ to escalate a concern to nigher management if CAQ j documentation is not being processed to his I satisfaction.

9.5 SEQUOYAH NUCLEAR PERFORMANCE PLAN (SQNNPP) q l

In the Sequojah Nuclear Performance Plan (SQN NPP), Volume II

( App. A, 5.0), TVA management acknowledges that CAQs have been a problem. The plan states, -in part:

i "In the past, TVA has not always taken timely i action to resolve conditions adverse to quality in  !

its nuclear activities. This weakness included the' lack of upper level management involvement and timely processing of conditions adverse to quality involving multiple organizations. TVA has taken 1 actions to improve its performance in these areas."

To comply with the applicable criteria, all CAQs must be promptly identified and corrected. If, through a lack of upper level management involvement, personnel who are responsible for concurrence and approval of employee-reported CAQs failed to respond in a timely manner, or failed to respond at all, the issue would be substantiated.

9.6 INSTITUTE OF NUCLEAR POWER OPERATIONS (INP0) FINDINGS A TVA memo dated August 14,1986 ( App. A, 5.n) dealing with j the Institute of Nuclear Power Operations'(INPO) corporate I evaluation was reviewed. In this memorandum TVA management f accepted as valid three findings and recommendations i regarding CAQs, as assessed by this independent auditing I

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group.

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j I PAGE 12 0F 17 TVA corrective-action program deficiencies include acknowledgement _ of major deficiencies identified in equipment qualification and seismic analysis programs and failure to determine root causes and establish action plans for corrective action. A lack of. management support and tracking of. externally and internally prompted corrective actions was also documented by INP0 as a finding. Another finding cited failure' to complete corrective actions resulting from Nuclear Safety Review Board (NSRB) reviews.

The above deficiencies appear to substantiate the issue.

. They imply that conditions adverse to quality were not documented and dispositioned in a timely manner as required by 10CFR50 Appendix B and ANSI N45.2.11. Furthermore, a lack of management support and attention to the corrective action program,'is noted.

This TVA memo also contains details of planned corrective actions which should, if properly implemented, correct these findings and preclude recurrence, i.e.:

TVA is in the process of reviewing its various (f nuclear programs to ensure they contain appropriate provisions for identifying and addressing the root causes of problems. ' Although the details of these provisions have not yet been i developed, guidelines for their development have been established. Conditions adverse to quality (CAQs) - Nonconforming Condition Reports, Problem Identification Reports, Discrepancy Reports, NRC and INP0 evaluation findings and deficiencies identified in reports submitted to NRC - will be tracked and their significance will be assessed.

TVA will take two steps to identify the root causes of these conditions. First, each significant CAQ will be individually analyzed to detennine its root cause and to recommend action to remedy that cause. Second, each CAQ will be placed in various categories, such as the group responsible for causing the condition, the type of condition, the type of item or matter that is deficient, and the immediate cause of the 8

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condition. . An ana l ys i s will be~ periodically performed to identify any adverse trends, and '

-these trends will be evaluated to determine their root cause and to recommend action to remedy that cause. . In both cases, management will be informed of.any significant CAQs~ and any. adverse trends, their root causes, and the recommended action to remedy those causes."

Findinas:

a. 'Sequoyah Safety Analysis Reports (PSAR and FSAR) adequately respond to the applicable regulatory criteria and impose

appropriate requirements on the project for CAQ reporting and processing.

b. 'Ouality Assurance Program Description for the Design, Construction, and Operations of TVA Nuclear Power Plants .

~.....# adequately address the applicable criteria for CAQ reporting

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and processing. , .

c. The Sequoyah NPP ( App. A, 5.0) acknowledges that CAQs havel been a problem and also addresses corrective action.

-d. ' TVA ' management has accepted as valid three' INPO findings - ,

regarding CAQs (App. A, 5.n). These findings were critical ,

of the following elements of TVA's CAQ programs:

documentation of CAQ, CAQ evaluation, establishment of basic ,. i cause of CAQ, and implementation of timely and effective. ,

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corrective action for all CAQs.-  ; ~'

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e. Prior to the issuance of NEP-9.1 in July, .1986, the ~

. engineering procedures implementing the corrective action' ~

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process at SQN did not offer a means for the initiator of a

potential CAQ to escalate a concern to. higher management if a supervisor disagreed about the validity of t.he concern. -

- NEP-9.1 now provides such measures..

f. The new Employee Concerns Program now provides additional ---

- - measures, if needed, to escalate a concern to higher 7' -

management. . . .

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Conclusions:

The issue identified in this element refers to a programmatic deficiency in the engineering corrective action process that

- hinders employees from reporting conditions adverse to quality.

The evaluation team investigation has indicated that engineering procedures have now been changed to satisfactorily address the issue. Specifically, NEP-9.1, " Corrective Action" (RO, 07/01/06),

now enables the originator of a CAQ to escalate a concern to higher  ;

management if the originator and supervisor disagree about the validity of the concern. The previous engineering procedures did not provide for such recourse.

Even if some CAQs were not documented prior to issuance of NEP-9.1, as implied by this issue, the integrity of Sequoyah safety systems will nevertheless be verified as required prior to restart, through the Design Base.line and Verification Program (DBVP) and similar programs as described in section 9.2 of this report.

In addition to modification of the engineering procedures, the

(.)

existence of the new TVA Employee Concerns Special Program allows employees to circumvent any perceived undue restrictions in the ,,

formal . CAQ process. l The evaluation team concludes that although the issue was valid at the time stated, subsequent procedure and program modifications have adequately addressed and resolved it.

10. CORRECTIVE ACTION:

No corrective action is required.

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APPENDIX A.

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a. . Title .10 of the Code. of Federal Regulations, Part 50 (10CFR50),.

Chapter 1, Appendix B, " Quality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants;" Criterion XVI,

" Corrective Action" i

b. Title 10 of the Code of. Federal Regulations, Part 50.55,

" Conditions of Construction Permits," Reporting Criteria for Significant Deficienchs _10CFR50.55(e), (04/19/76)

c. ANSI N45.2-1971, " Quality Assurance Program Requirements for-Nuclear Power Plants"

d. ANSI N45.2.11 - 1974, " Quality Assurance Requirements for the Design of' Nuclear Power Plants," Section 9, " Corrective Actions"

e. ANSI N45.2.10-1973, " Quality Assurance Tenns and Definitions"

$ .f. Regulatory Guide 1.64, " Quality Assurance Requirements for the

\ Design of Nuclear Power Plants,". R2, (06/76):

g. Sequoyah Preliminary Safety Analysis Report (PSAR)

h. Sequoyah Final Safety Analysis Report (FSAR) updated through Anendment 3 (04/86). This evaluation refers to the following:

17.1 A.15 " Nonconforming Materials, Parts or Components" 17.1 A.16 " Corrective Action" r i. Sequoyah Nuclear Plant Quality Assurance Manual (SQN QAM);

R12, (12/31/75)

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j. TVA EN DES Engineering Procedures Manual, EP 1.26, R9 "Nonconformance - Reporting and Handling in  !

EN DES" (03/15/85) ll l

EP 1.48, R2 " Preparation of Failure Evaluations /

Engineering Reports of Deficient Conditions for Nuclear Plants" (03/15/85) .

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l APPENDIX A (Cont'd)

EP 1.51, R1 " Conditions Adverse to Quality (CAQ) Trend Analysis Program" (04/24/84)  ;

1 EP 4.03, R11 " Field Change Requests Initiated by Construction" (11/21/84)

k. TVA Office of Engineering (OE) Procedures Manual, OEP-14, R1 " Licensing" (12/02/85)

OEP-16, R0 " Design Records Control (04/26/85)

OEP-17, R2 " Corrective Action" (08/30/85)

1. TVA Division of Nuclear Engineering (DNE) Procedures Manual, NEP 1.3, R0 " Records Control" (07'/01/86)

NEP 9.1, R0 " Corrective Action" (07/01/86)

m. TVA TR 75-1 A, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power

(,) .

Plants," R8, (04/09/85)

n. TVA memo from L. L. Jackson to Those Listed, " Institute of '

Nuclear Power Operations (INP0) Corporate Evaluation Responses," ( A02 860813 012), (08/14/86). Specific findings reviewed include 1.2A-2,1.2A-3, and 2.8A-1

o. Sequoyah Nuclear Perfonnance Plan, Volume II, R1, (07/17/86)

p. TVA Corporate Nuclear Performance Plan, Volume 1, R2 4 (08/13/86)

q. TVA New Employee Concerns Special Program, (12/01/86)

r. Sequoyah Nuclear Plant, " Design Baseline Verification Program," R0, B25860506020, (05/06/86)

s. TVA memo from W. C. Drotleff to Those Listed, " Design Bases Program for TVA Nuclear Plants," (B44 860402 007), (04/08/86)

t. TVA memo from CCTF to S. A. White, " Office of Nuclear Power (0NP) - Configuration Control Task Force (CCTF) Final Report," (R25 860626 833), (06/30/86) .

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APPENDIX A (Cont'd)

u. TVA memo from W. C. Drotleff to S. A. White, " Design Change Process Improvements Program," (801 860801 001), (08/01/86)

v. Sequoyah Nuclear Plant Standard Practice SQA A183, " Change l Control Board (CCB)," R1, (08/06/86) l l

w. TVA memo from J. A. Kirkebo to J. E. Houston, " Revision to l Specification Improvement Plan," (B80 861008 001), (10/08/86) j

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?

a. 10CFR50 Chapter 1, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"

b. 10CFR50.55, " Conditions of Construction Permits"

c. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Q Design of Nuclear Power Plants"

d. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)

e. Sequoyah FSAR updated through Amendment 3, (04/86)

f. TVA Division of Nuclear Engineering (DNE) Procedures Manual ,

NEP-9.1 R0, " Corrective Action," (07/01/86)

g. Sequoyah Nuclear Performance Plan, Volume II, R1, (07/17/86)

h. TVA Corporate Nuclear Performance Plan, Volume I, R2 (08/13/86)

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT:

a. Telephone conversation, D. T. Clift, E. G. Beasley, TVA, and L. J. Anderson, Bechtel, IOM 135, (05/22/86)

b. RFI 057, (05/13/86)

,- c. RFI, SQN-533, (09/05/86) w 0629D (02/04/87) w___.__ ____