ML20206C275

Rev 4 to General Mgt & Policy, TVA Employee Concerns Special Program

ML20206C275
Person / Time
Site:	Sequoyah
Issue date:	03/31/1987
From:	Aheley W, Russell Gibbs, Halverson R TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20206C172	List: ML20206C168 ML20206C206 ML20206C275 ML20206C335 ML20206C425 ML20206C446 ML20206C473
References
80000-SQN, 80000-SQN-R04, 80000-SQN-R4, NUDOCS 8704130022
Download: ML20206C275 (19)

Text

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6 TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80000-SQN P2 VISION NUMBER:

REPORT TYPE 4

Element Report PAGE 1 0F 14 TITLE:

General Management and Policy REASON FOR REVISION: , Incorporation of NRC comments.

Revision indicators are found in the right margins to note changes made.

Note: Sequoyah Applicability Only PREPARATION PREPARED BY: Wayne M. Akeley/ Ronald D. Halverson (Ahaw % Ob/n 3*M2

' DATE SIGNATURE

/

REVIEWS PEER:

i

. 4 4 CD

/ DATE SIGNATIJdE TAS: /

'/"k7 SIGNATURE

/N TA747

/ Dp CONCURRENCES l

CEG-H:- -

J[r/[A y SRP: w) Mh(( '3 M87 DATE SIGNATURE DATE [ SIGNATU p [

i APPROVED BY:

! M.b .M 3 [8'l N/A DATE

.oECSP MANAGER DATE MANAGER OF NUCLEAR POWER l CONCURRENCE (FINAL REPORT ONLY) l

• SRP Secretary's Signature denotes SRP concurrence are in files.

8704130022 870406 ,

PDR ADOCK 05000327 P. PDR

REPORT NUMBER:

80000-SQN PIPORT TYPE REVISION N'u'riBER:

Element Report 4

TITLE: PAGE 2 0F 14 General Management and Policy 1.0 CHARACTERIZATION OF ISSUE 1.1 Introduction The issues described in this element report were derived from employee

, concerns generated as a result of the Watts Bar Employee Concern Special Program. The issues were determined to be applicable to the Sequoyah Nuclear Plant (SQN) and were investigated and evaluated on that basis.

1.2 Description of Issues The conditions reported by concerned employees are:

a. A nonchalant regard for quality sets an example for subordinate employees to likewise promote and tolerate poor quality at Sequoyah. (XX-85-116-005)

b. During the exit interview the concerned individual (CI) expressed the concern that mistakes made at SQN and other plants are not corrected. (WBN-86-066-001)

c. Electrical General Foreman was reprimanded for using Non 'Q' materials in 'Q' systems, but continued to tell his workers to do this. (XX-85-033-006)

d. CI was requested by supervisors to sign-off data sheets on defective equipment. CI initially refused to sign because corrective action had not been taken. CI was asked second time to sign the data sheets and did so to avoid getting a letter for insubordination. (XX-85-027-X07)

e. TVA informed the Nuclear Regulatory Commission (NRC) that cable had been removed from the site in 1981. Whenisindocumented fact the cable on was still being removed in 1984. This Nonconformance Report (NCR) SQN EEB 8019RI. (XX-85-027-X03)

Process for evaluation of 10CFR21 applicability. (BFN-IESC f.

03)

g. Inadequate understanding of the level of control required in nuclear parts program is indicative of weakness in NQAM. (BFN-12SC-85-03)

h. The issue of " configuration control" was not evaluated as this issue is adequately covered in operations Element Report 307.13-SQN. (BFN-IESC-85-03)

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m.

' REPORT NUMBER *

' REPORT TYPE 80000-SQN

-Element Report REVISION NUMBER:

TITLE: 4 General Management and Policy PAGE 3 0F 14

. 2.0L

SUMMARY

Susanary of Characterization of Issues 2.l' 2

Principal issues raised by concerned employees are: nonchalant regard

-. for quality, mistakes are not corrected, Non-Q materials are used in'Q 4- systems, improper sign-off on data sheets, the NRC was misinformed of:

cable removal, the process for evaluating 10CFR21 applicability is questioned, inadequate understanding of the nuclear parts program, and configuration control.

2.2 Summary of Evaluation Process l Upper tier and lower tier documents were reviewed to determine requirements and responsibilities along with the procedural direction.

i Correspondence, codes, standards, procedures, instructions, inspection '

!- reports, nonconformance reports, and memorandums were also reviewed to determine the full extent of the concerna and their overall-

!' significance to the Sequoyah Nuclear Plant. Additionally, discussions were held with various TVA personnel pertaining to - specific problem

' areas regarding electrical cables, spare parts, procurement, and battery inspections.

2.3 Summary of Findings q

j The conclusions reached as a result of the Quality Assurance Category Evaluation Group (QACEG) evaluations of these issues are:

The issues regarding " nonchalant regard for quality promotes poor l.. quality" and " mistakes made were not corrected" could not be properly evaluated due to the vagueness and lack of specific t information.

The issue of using "Non 'Q' materials in 'Q' systems" was substantiated in that a general foreman instructed craft personnel to use a QA Level I or II part which did not have'the required documentation.

l The issue of " improper sign-offs on data sheets" could not be j substantiated. The sign-offs required of the. inspector did not signify QA acceptance, but rather documents the identity of the

inspector performing and documenting the results of the inspection.

{

The issue that "TVA informed the Nuclear Regulatory Commission that cable had been removed from the site in 1981 when in fact i the cable was still being removed in 1984" is substantiated, in that SQN Nonconformance Report (NCR) 8019 improperly stated that all PJJ and PNJ cable had been removed as docinnented by Transfer Requisition 858512.

I

REPORT NUMBER:

80000-SQN REPORT TYPE Element Report REVISION NUMBER:

4 TITLE:

General Management and Policy PAGE 4 0F 14 The issue of " Process for evaluation of 10 CFR 21 applicability" is unsubstantiated in that documentation pertaining to these reviews was available and that procedural guidelines were properly _followed.

The issue of " inadequate understanding of the control required for the nuclear parts program" is substantiated. Personnel did not fully understand procurement requirements due to program inadequacies.

2.4 Summary of Corrective Action Regarding the use of Non "Q" materials it was determined that an isolated instance did exist where Non "Q" Material was improperly installed in a "Q" System. However, the part was replaced and appropriate disciplinary action taken. With respect to the PJJ and PNJ cable, it was determined that all cable had not been removed which has resulted in Environmental Qualification for those type cables. In addition, a CATD has been initiated to provide expected completion dates for cable testing. Responses to this CATD vere evaluated and results concurred with the QACEG. Corrective actions towards improving the Procurement Program have been initiated which should help streamline the system.

3.0 LIST OF EVALUATORS W. M. Akeley R. D. Halverson 4.0 EVALUATION PROCESS 4.1 General Method of Evaluation This evaluation was performed by reviewing many documents such as inspection reports, Inspection Instructions / Guidelines, Notice of Indications (NOI), Construction Procedures / Specifications, Quality Assurance Procedures, American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel codes, Design Standards, Work Requests, Nuclear Quality Assurance Manual (NQAM), Nonconformance Reports (NCR),

memorandums, and TVA's QA Topical Report. In addition, discussions with cognizant personnel were held pertaining to specific problem areas regarding each issue.

REPORT NUMBER

&  :; . REPORT TYPE- 80000-SQN-7i'

Element Report. REVISION NUMBER

TITLE:- 4 .

General Management and Policy PAGE 5 0F 14

' 4. 2 Specifics of Evaluation 4.2.1 Issue - Nonchalant Regard for Quality 3-

' Reviewed Employee ' Concern File .. including Confidential Files for any additional information pertaining to this concern.. No additional information was available.

4.2.2 Issue - Mistakes Not Corrected Reviewed Employee Concern File including Confidential Files for any additional information pertaining to this concern. No-additional information was available.

I 4.2.3 Issue - Use of Non "Q" Materials in "Q" Systems-

~ Reviewed Employee Concern Files including Confidential Files for any additonal information pertaining to this concern. ,

Nuclear Safety Review . Staf f (NSRS) Report I-85-814-SQN was reviewed _ documenting the investigation and findings of this concern. Codes, standards, procedures, instructions, and

• reports reviewed during this investigation are included in the NSRS Report.

Issue - Data Sheet Sign Off 4.2.4 Reviewed Employee Concern Files including Confidential Files for any additional information pertaining to this concern.

Quality Technology Company (QTC) Report XX-85-027-X07 documenting the investigation and findings of this concern was reviewed. This report was utilized during the evaluation

! process of this concern and its contents re-evaluated by QACEG. This report draws the same conclusion as the QACEG 1

evaluation.

In conjunction with the QTC Report, Inspection Instruction No.

19, Revision 9, " Battery Inspection", Inspection Instruction 4

No. 30, Revision 7, " Receipt Inspection", and Nonconformance 1 Report 2803, were also reviewed during this investigation.

4.2.5 Issue - Nonconforming Cable Not Removed From Site.

! Reviewed Employee Concern File including Confidential Files ,

for additonal information pertaining to this concern. NSRS Report I-85-218-SQN, documenting the investigation and i

findings of this concern, was used as the basis of the Summary and Findings section of this report and includes various documents reviewed during this investigation.

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I REPORT NUMBER lt

- REPORT TYPE S0000-SQN Element Report- REVISION NUMBER:

TITLE: 4 General Management and Policy PAGE 6 0F 14 4.2.6 Issue - Process For Evaluation of 10 CFR 21 Applicability.

Reviewed Employee Concern File including Confidential - Files for any additional information pertaining to this concern.

The Nuclear Operations Quality Assurance Manual (N0QAM) Part III Section 1.1, - entitled " Procurement _of Materials, Components, Spare Parts, and Services" was reviewed in conjunction with Appendix F, Attachment 1 of NOQAM Part III, Section 2.1 to determine if appropriate requirements were contained in NOQAM and implementing procedures. SQNP SI-114.1

" Inservice Inspection" in conjunction with NOQAM Part III, Section 7.2 was also reviewed to ascertain if unacceptable

! indications noted during random inspections 'were in fact evaluated for significance and for potential reportability.

Four Notice of Indications (NOIs) and associated documentation 4

of unacceptable conditions, identified by liquid penetrant

? methods, were reviewed to assure that these indications were properly evaluated for 10 CFR 21 applicability _in accordance with the site inservice inspection program. Additionally, six purchase requaitions were also reviewed attesting to the implementation of 10 CFR Part 21 requirements.

i Reviewed Engineering Procedure NEP-4.1 Revision 0,

" Procurement", and recently prepared material requaitions to i determine engineering involvement as it also applies to the requirements of 10CFR21.

i 4.2.7 Issue - Inadequate Understanding of Level of Control Required in Nuclear Parts Program The initial investigation was spent gaining an understanding of the basic mechanics of site procurements (forms used, l.

terminology, and coordination required) and reviewing i procurement files. Four Quality Control personnel were

interviewed to ascertain their understanding of the total

! procurement system and to identify their specific l

res ponsibilitieg .

, 5.0 FINDINCS l- 5.1 Findings on Issue - Nonchalant regard for Quality l

l Discussion

}

l This issue, can not be properly investigated or evaluated due to the

! vagueness and lack of specific information.

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f

' REPORT NUMBER:

REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

4 TITLE:

General Management and Policy PAGE 7 OF 14 5.2 Findings on Issue - Mistakes are not corrected.

Discussion This issue, can not be properly investigated or evaluated due to the vagueness and lack of specific information.

5.3 Findings on Issue - Use of Non "Q" materials in "Q" systems Discussion Further information was requested from the Employee Response Team (ERT) to identify the approximate time frame to which the concerned individual was referring. The ERT indicated that the events occurred sometime between February 1984 and early 1986.

QACEG utilized NSRS Report I-85-814-SQN in the evaluation of this concern. On May 9, 1985, during maintenance on solenoid valves 2-FSV-1-183A, an electrical general foreman in the Sequoyah Electrical Maintenance Section instructed craft personnel to use a QA level I or II part (diode) which did not have required documentation. This work was being performed under maintenance request MR A-300161. Solenoid valve 2-FSV-1-183A is a critical component as defined by Sequoyah Standard Practice SQA134, Appendix A, part III, " Critical Structures, Systems, and Components CFC List". MR A-300161 stipulated the specific use of Maintenance Instruction MI-6.20 and Modification and Addition Instruction MAI-12. These procedures require, among other things, that QA personnel inspect the crimping of the diode. Contrary to these requirements, the general foreman instructed craf t personnel to install the diode without proper documentation and QA inspection.

This ac cion by the general foreman resulted in a formal reprimand.

MR A-;.01208 was submitted and work initated on May 10, 1985, to inspec : and replace the Non-Q diode with a diode having the proper documentation. On May 16, 1985, the Electrical Maintenance Section Supervisor discussed the gravity of the general foreman's failure to follow procedures and his responsibility. Based on this discussion and the formal reprimand, the section supervisor was of the opinion that the general foreman clearly understood the significance of his actions and what is expected in the future. The section supervisor is not aware of any additional instances where this or any other electrical general foreman has instructed craf t to use Non-Q parts in QA systems. The Electrical Maintenance Section Craft Unit Supervisor directly supervises the section's electrical general foreman. The unit supervisor recommended the disciplinary action to the section supervisor following the May 9, 1985 incident. To the best of the unit supervisor's knowledge, the practice of instructing the craft to violate plant procedures has not continued.

nr.rvnA nunor.nl

. REPORT' TYPE 80000-SQN Element Report REVISION NUMBER:

TITLE: .

4

-General Management and Policy PAGE 8 0F 14 The Electrical Maintenance Section is staffed with seven electrical crew foreman and approximately 42 journeyman electricians. Interviews were conducted with two of - the crew ' foremen from day shift, the evening shift crew foreman, a dual rate foreman, and the day shift general foroman. In additon, three electricians were-interviewed from the day ahift and four electricians from the evening shift. These individuals were selected at random. None of the individuals interviewed stated that they were ever instructed to use Non-Q parts in QA systems nor were they aware of any electrical general. foreman currently doing so.

Conclusion The concern of record is substantiated -in part. It was substantiated that a situation occurred in which craft personnel had been instructed to install a qA level part without proper' documentation and to proceed with its installation in violation of approved plant procedures.

Action was taken immediately to replace the part and action was taken to discipline the responsible electrical' general foreman. The disciplinary action appears to have been - effective. No evidence exists that the general foreman continued to tell of his workers to do this or similar failure to follow plant procedures.

5.4 Findings on Issue - Data sheets sign-off Discussion This issue is based upon SQN NCR 2803 written on July 21, 1982 identifying unacceptable electrolyte level with the fifth diesel generator battery cells. This nonconforming condition was originally identified in accordance with SNP Inspection Instruction No. 19 and documented on . Data Sheet 1, " Battery Ins pec tions", dated 6/18/82.

Office'of Nuclear Power (ONP) disposition to NCR 2803 was to reduce the specific gravity of the battery electrolyte by using the " Approved Power System Procedure" (MEB '811230 995). This disposition, Rev. 1, was written 12/22/82. However, it wasn't approved by the Design Project Organization and assigned to disposition Block 6 of NCR 2803 until 6/14/83. As evidenced by the NCR (Block 8), the assigned disposition was completed and the batteries released from a nonconforming status on 7/5/83. During the period when the nonconforming condition was identified (6/18/82) and when corrective actions were completed (7/5/83), periodic inspections (bi-weekly, monthly, and quarterly) were being performed as required by SNP Inspection Instruction No. 19. This procedure required the Electrical Engineering Unit to issue Data Sheet 1, " Battery Inspection," and the Inspection Group inspector to document the results of this inspection on this fonn. On the bottom of Data Sheet 1, there is an area provided for the signature of the inspector and the date the inspection was performed. In this instance, this signature and date

. REPORT NUMBERt '

REPORT TYPE 80000-SQN Element Report REVISION NLMBER:

TITLE: 4 General Management and Policy PAGE 9 0F 14 does not signify QA acceptance, but rather documents the identity of the inspector performing the periodic inspections.

Conclusions The concern - indicates the Concerned Individual (CI) is reluctant to sign off data sheets when the acceptance criteria of SNP Inspection Instruction No. 19 has not been met was unsubstantiated. -The concerned employee has no valid reason to refuse to sign the data sheet as the signature on Data : Sheet 1 is for identifying the inspector entering the inspection results and does not signify-acceptance.of the item.

5.5 Findings on Issue - NRC misinformed of cable removal Discussion As a result of OE evaluations of NUREG-0588, specific applications of PJJ and PNJ' types of cable were identified as not qualified for the accident environmental condition. This entailed the issuance of NCR SQN EEB 8019 and various TVA letters to the NRC informing them of 10 CFR 50.55 (e) deficiencies. Between June 16, 1980 and June 29, 1981, five status reports concerning NCRs issued on environmental qualification were sent to the NRC. However, none adaressed PJJ and PNJ cable nor contained any information that indicated to NRC that issued PJJ and PNJ cables had been removed from SQN in order to prevent further installation. The disposition of NCR 8019 required removal of all remaining cable of type PJJ and PNJ. Although this was not completed in a timely manner, a majority of PJJ and PNJ cable was removed from Sequoyah as evidenced by Transfer Requisition 828512.

However, NCR 8019 improperly stated that all PJJ and PNJ cable had been removed by Transfer Requisition 828512.

Conclusion This issue is substantiated in that all PJJ and PNJ cable was not removed from the site as stated in the NCR. Five status reports from June 16, 1980 to June 29, 1981 concerning NCRs written on environmental qualification were sent to the NRC. However, all five did not address PJJ and PNJ cables.

5.6 Findings on Issue - Process for evaluation of 10 CFR 21 applicability Discussion It was determired from reviewing all pertinent correspondence and information providad in the Confidential Files that the concerned individual was concerned with the 10 CFR Part 21 reportability of vendor supplied items.

REPORT NUMBER REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

TITLE: 4 General Management and Policy PAGE 10 0F 14 There are two distinct groups within the Sequoyah organization currently purchasing material. The Nuclear Power Division . procures items in accordance with Part III of the Nuclear Quality Assurance Manual, supplemented with Standard Practice SQA45 (" Quality Control of Materials and Parts and Services") and the Nuclear Engineering Group procures material for modifications' in accordance with NEP-4.1,.

entitled " Procurement". Each group determines .whether .10CFR21 requirements ' are applicable to the supplier for procurement of items and- services. The Nuclear Engineering Group, -is required .in accordance with Section 3.0, paragraph 3.6 of NEP-4.1, and Attachment 24, "10CFR21 Applicability" to assure that TVA procurement specifications and requisition packages for nuclear safety-related items meet the reporting requirements of 10CFR21.

This concurrence is documented on material requisitions. Ten SQN requisitions prepared during 1979-1981, and five recently prepared requisitions of material purchased by the Design Engineering Group, were reviewed to assure that documentation attesting to 10CFR21 applicability was available. All documentation reviewed was satisfactory. The Nuclear Power Group currently purchases items in accordance with Nuclear Operations Quality Assurance Manual (NOQAM)

Part III, Section 2.1, evaluates each item 'or service for 10CFR21 applicability by the use of Attachment 1, Appendix F entitled

" Determination of Basic Component Status and 10CFR Part 21 Applicability". The review of the fifteen SQN Purchase Requisitions prepared between 1979-1986 revealed that all had ~ been appropriately reviewed for 10CFR Part 21 applicability with corresponding documentation substantiating all reviews.

Further investigation was conducted to assure that the process for evaluation of 10CFR Part 21 applicability was conducted regarding the Inservice Inspection (ISI) Program. Surveillance Instruction SI-114.1, Section 17.0 entitled " Notification of Indication" requires the organization assigned responsibility for repair within NUC PR to determine if the unacceptable condition is significant and potentially reportable in accordance with the requirements of N0QAM, Part III, i Section 7.2. A review of four of 34 Notification of Indication forms

! reporting unacceptabic indications identified by the liquid penetrant f examination method, indicated each had been evaluated for 10CFR Part

21 applicability as required.

{. Conclusion l

This issue is unsubstantiated at SQN, based on the fact that the appropriate documentation prepared by each purchasing group was reviewed and found satisfactory. Additionally, the process by vnich l determinations of 10CFR Part 21 applicability are made was found to be j satisfactory.

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REPORT NUMBERt REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

TITLE: 4 General Management and Policy PAGE 11 0F 14 5.7 Findings on Issue - Inadequate understanding of the level of control in the nuclear parts program.

Discussion The issue of whether inadequate understanding of the level of control in the Nuclear Parts Program was indicative of a NQAM programmatic weakness was substantiated by the QACEG investigation.

Part III, Section 2.1 of the Nuclear Quality Assurance Manual (NQAM) provides the methods for controlling the procurement of materials components and spare parts. A review of the NQAM determined that it assigns responsibilities and provides interpretation of regulatory requirements, invokes the applicable quality assurance program requirements listed in ANSI N45.2, Appendix B to 10CFR50, ASME Section III and Section XI, and further implements the requipements of ANSI N45.2.13.

Prior to 1984, TVA recognized that the procurement program was in need of strengthening. This was further substantiated by the fact that the NSRS investigation performed during June 11, 1984 and December 5, 1985 also reiterated the fact that deficiencies did exist with various aspects of the program. The problems were categorized into five areas:

a. General unfamiliarity with procurement cycle

b. Excessive and/or ineffective review of Purchase Requests and requisitions

c. Ineffective use of the available procurement system

d. Apparent lack of planning, and

e. Quality Assurance These deficient areas were also addressed and recommendations provided. These recommendations consisted of:

4

a. Establish a planning group

b. Improve Purchasing / site communications

c. Eliminate unncesssary procurement cycle steps, and

d. Better utilize automated systems Additionally, interorganizational communications and working relationships were developed to help solve problems and streamline operations. With respect to previously identified weaknesses within

REPORT NUMBER:

REPORT TYPE 80000-SQN Element Report REVISION NUMBER:

. TITLE: 4 General Management and Policy PAGE 12 0F 14 the NQAM, several revisions have been issued which provide for additional training requirements, organizational changes, review approval cycles, and current commitments. The QACEG evaluation concentrated on interviews with six personnel in the Sequoyah Procurement Program. These interviews indicated that although weaknesses have been identified as previously noted, the program has been expanded and enhanced to comply with procurement commitments.

Also, the personnel actually involved currently in day to day procurement activities appeared to have adequate knowledge of the level of control regarding nuclear parts. Additionally, SQA45, entitled " Quality Control of Material, Parts and Services", dated May 30, 1984 and Administrative Instruction AI-11 entitled " Receipt Inspection Nonconforming Items, QA Level / Description Changes and Substitiutes", dated May 21, 1984 with recent revisions, were reviewed to determine program compliance. It would appear that the many problems previously experienced with the NQAM prior to 1984 caused confusion among those involved in daily procurement activities. With recognition of these program inadequacies by management and site personnel, and the retraining and program manual revisions, indications are that the program is better organized and capable of controlling materials at SQN.

Conclusion This issue is substantiated by the fact that the many problems identified with the NQAM did in fact cause confusion and contribute to the misunderstanding of the control requirements by the the procurement program.

5.8 Corrective Actions This section encompasses corrective measures taken and the results achieved to date on behalf of TVA and also those corrective actions identified during this evaluation.

Issue - Use of Non "Q" materials in "Q" systems Maintenance Request (MR) A-201208 was submitted and worked on May 10, 1985, to replace the Non-QA diode with a diode having proper documentation and required inspections were performed. On May 16, 1986, the general foreman responsible was formally reprimanded by the Maintenance Section Supervisor for not following site procedures. The results of the QACEG investigation indicates this was an isolated incident with no further corrective actions necessary.

Issue - NRC was misinformed of cable removal all PJJ and PNJ cable was not removed from the site as stated in the NCR.

At the time of NCR 8019 closing, inadequate action was taken to prevent further installation, and action was not taken to ensure that

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REPORT NUMBER:-

REPORT TYPE' 80000-SQN

~ Element Report REVISION NUMBER:

TITLE:- 4 General Management and Policy PAGE 13 OF 14' i

all unused cable had been removed from the site. Failure to write a y site NCR and to quickly remove from1the site.these cables'resulted in its noncontrolled use. However, the adequacy of PJJ and PNJ cables '

installed at SQN has been evaluated as part of the electrical-

[ equipment' Environmental Qualification Project. Corrective action' .

regarding this issue was determined to be required. SQN EQ Project

- has demonstrated Environment Qualific'ation for TVA Type PJJ Cable installed in 50.49 circuits. Review of the SQN Electrical Equipment 4

List shows that no PNJ Cables ' (or cables of the same family) has been

! installed in 50.49 circuits.

I i Issue - Inadequate understanding of level of control required in the h Nuclear Parts Program.

Corrective actions regarding the procurement ' program are presently e ongoing in that improved interorganizational communications and l working relationships have been developed to help streamline operations. Additionally, several recommendations directed toward changing and improving the system have also been initiated. The results of the QACEG investigation indicates that these corrective l actions are all essential elements within the procurement process.

1.

A Corrective Action Tracking Document (CATD) No. '80000-SQN-01 was initiated to provide an expected completion date for testing the cable

in question.

. A response to this CATD was prepared and acknowledged by the Watts Bar j

ECTG on 11/21/86. Corrective. action regarding this issue was.

- determined not to be required - in that additional ' Analysis provides documentation which supports a qualified life of ' 40 years plus' the 4

i required accident and post accident operating time. The SQN EQ j Project has ' documentation to demonstrate environmental qualification j for TVA type PJJ cable installed in 50.49 circuits at ' SQN.~ This i documentation is contained in Sequoyah Environmental Packages, l Revision 1, SQNEQ-CABL-001, -015, -020, and -034. Review of the 4

Sequoyah Electrical Equipment List (SQEL) shows that no PNJ cables (or j- cables from the same family) has been installed in 50.49 circuits.

( The QACEG has evaluated this response and concurs with it's

}- conclusion.

l Attachment A, identified the issues as potentially safety-significant or

, safety related. However, QACEG evaluation concludes that only issue XX '

027-X03 was potentially safety-significant. This identifies that

! unacceptable cable was not properly controlled which resulted in its subsequent use. This issue was determined to have no impact on safety and although sone of the remaining issues were substantiated, they were not ,

considered detrimental to the safe or reliable operation of the Sequoyah

{ Nuclear Plant.

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l REPORT NUMBERt l

• l REPORT TYPE 80000-SQN

.- Element Report REVISION NUMBER:

TITLE: 4 General Management and Policy- PACE 14 0F 14 6.0 ATTACHMENTS A.- Employee Concern Program System (ECPS) List of Employee Concern Information B. Corrective Action Tracking Document (CATD) No. 80000-SQN-01

_ _ . _ _ ._ _ ___ _ m s . .

ATTACliMENT A g;

$Jb ,

SI20J-ECPS121C REFERENCE TENNESSEE V AUTHORITY I PAGE; <- 2 FREQUEllCY -

6UEST KFFICE OF N R P0HER rut 1 T s /- 14:2 OTIP - ISSS - RitM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DA)E - 01/2:

EMPLOYEE CONCERN INFORMATI0H BY CATEGORY / SUBCATEGORY CATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80000 GENERAL MANAGEMENT AND POLICY S 1 REPORT APPL l H 2 SAF RELATED SUB R PLT 3 FIllD CLASS HISTORICAL CONCERN j CollCERif flu!1BER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION

, --- _ =- --- -- - --- -- -- -- -- - --- _ ___ _ _ _ _ _ _ =_=--------------------------

BFilIESC-85-03 01 v! DP 30713 S BFN 1 DECP CONCERilS EXPRESSED REGARDING: 1. PROCESS FOR 2 LUATIDH OF 10CFR21 APPLICABILITY. 2. IllADEQUA 3 UNDERSTANDING OF lHE LEVEL OF C0tlTROL REQUIRED 02 QA 80000 S BFN 1N N Y H i. HUCLEAR PARTS PROGRAM IS IllDICATIVE OF HEAKilESS 2 NA flA SS tlA .- HQAM. 3. CONFIGURATION COIIIROL.

3 NA NA C NA HBil-86-066-00101 / QA 8000& S HBN 1N 11 Y N NSRS DURING THE EXIT INTERVIEH THE CI EXPRESSED C0f1 "

2 flA flA SR HA THAT MISTAKES MADE AT SQll AND OTHER PLAllTS Akut i 3 NA IIA A NA .. T CORRECTED. THESE SAME MISTAKES ARE ALSO MADE

! 02 :QA 80601 S HBN 1Y Y H Y HBN.

' 2 SR SR NA SR -

3 NA

! XX 027-X0301 / QA 80000 N SQN 1 il N Y H Ih85-218-SQN QTC TVA INFORMED THE NRC THAT CABLE HAD BEEN REMOVE 1 T50056 2 ilA flA SS HA ~i ' -

ROM THE SITE Ill 1981. HHEll IN FACT THE CABLE H 3 NA NA E HA STILL BEING REMOVED IN 1984. THIS IS DOCUMEllTE a .

N AN flCR SGNEEB8019RI. BACKUP / ADDITIONAL IllFOR

] ION IN FILE.

5 XX 027-XO701 / IH 60400 S SQN 1 XX-85-027-XO7 QTC CI HAS REQUESTED BY SUPERVISOR TO SIGN OFF DATA i T50078 2

• EETS ON DEFECTIVE EQUIPMEllT. CI IllITI ALLY REFU i 3 TO SIGN BECAUSE CORRECTIVE ACTION HAD NOT BEEN

02 QA 80000 5 SQN 1N N Y N KEN. CI HAS ASKED SEC0!1D TIME .a SIGN THE DATA 1 2 NA flA SS tlA

EETS AND DID S0 TO AVOID GETTIliG A LETTER FOR I i

3 NA NA B NA i

- BORDINATION. (NAMES, EQUIPMEllT, AND OTHER ADDIT

,. AL INFORMATION ARE KNDHN)

, XX 033-00601 W IH 60400 S SQN 1 I-85-814-SQH QTC SEQUOYAH: ELECTRICAL GEllERAL FOREMAtt (KN0Hil) Ha 1

T50181 2 i EPRIMAllDED FOR USING NON "Q" MATERI ALS IN "Q"

) . 3 -EMS, BUT CONTINUED TO TELL HIS HORKER

] 02 QA 80000 S SQN 1N N Y N (CollSTUCTION DEPARTMENT CONCERN) C/I HAS fl0 F 2

2 NA NA SS tlA HER INFORMATION.

3 NA NA C HA XX 116-00501 / hA 80000 S SQN 1N N Y ll QTC A 110NCHALANT REGARD FOR QUALITY SETS AN EXAMPLE j _

T50271 2 NA NA SS NA ,. R SUBORDIllATE EMPLOYEES TO LIKEHISE PROMOTE AllD 1

3 NA NA A flA LERATE POOR QUALITY AT SEQUDYAH. IlUCLEAR P0HER 02 QA 80605 S SQN 1Y Y N Y PARTHENT CONCERN. DETAILS Kt10llfi TO QTC, HITHHE 2 SS SS tlA SS DUE TO CONFIDENTIALITY. NO FURTHER IllFORMATI0li 3 NA Y BE RELEASED. CI REQUESTS THAT QTC PERFORM TH INVESTIGATION.

6 CONCERNS FOR CATEGORY QA SUBCATEGORY 80000 1 - ,

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TV A 64 (Ok9 60 (09-WD+8H UNITED STATES Govct:NMEN1 T25 870204 998

']TCm0Tandum

.N TENNESSEE VALLEY AUTHORITY TO  : James L. McAnally, Corrective Action Program Manager, A108 IOB, Watts Bar Nuclear Plant ONP FROM  : W. R. Brown Jr., Program Manager, Employee Concerns Task Group, Watts Bar Nuclear Plant ONP DATE  :

FEB 0 4.1987

SUBJECT:

SEQUOYAH NUCLEAR PLANT - EMPLOYEE CONCERN TASK GROUP (ECTG) ELEMENT REPORT 80000-SQN - QUALITY ASSURANCE CATEGORY - CORPECTJVE ACTION i

PLANS (CAP)

Attached are copies of ECSP Corrective Action Tracking Document (CATD) No. 80000-SQN-01 and Corrective Action Plan responses concerning the subject e3ement report. -

The Quality Assurance Category Group Head concurs with your corrective action plans and has incorporated them into Element e Report 80000-SQN.

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W

. . h . R. Brown, Jr.

WEB:EMC " '

Attachment cc (Attachment): * .

~

' RIMS, MR 4N 72A-C "

H. L. Abercrombie, Seguoyah ONP c R. C. Denney, DSC-P, Sequoyah ONP P. f. Maron. TOB Trailer /17. Watts Bar 3528T _

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i ATTACIMENT B Page 2 of 5 I

t== mm om-o, 9A M Memorandum unM nuzr wrsoarrr DO g uM. 002 To L C. Deamey. Employse Conceras 8pecial Frejec& Manager. (NF. 38C-F.

Sequoyah Buclear Flant NM 1 D. W. Wilson. Project Engineer. IEIE. D8C-1. Sequoyah teclear Flant

"^'" ' """ 861121R0408 @

SUBJECT:

ggQUCTAE NUC:. EAR FLANT (SQI) - EXFLCTIE (DECEIES TAEE CEDUF (ECTC) E:.Daar?

EXPotTS - RZFORT 800.00 SQE - EETIEV AND COE1ECTIVE ACTItat FLAB (CAF)

IIITIATI05 Attached is the CAF f or ECTC Element tvaluation taport (800.00 SQI) which 16, 1986 (803 861016 was requested by your memoranham to me dated October 802). If you have any questions. please contact V. L Dean, extension 7:25 or D. 3. Arp. extension 6159.

. '_: _h-# Y D. 5. WLlose J .

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LTf'L L L hersrembia. EEF. SM. Segueyah e/o aethe)

L L Amergue. W. e679-3 Sagesyd =1 C. A h W. EPS-3. tagesyd (ute At:_ ^

L L. E11Latt. E B30-8. Sagasye

' L L eLesa WC. 2-2.Segmore J. L enllisen. W. #-2. Sagasyd F. A tallame. W. 84>=2. Sagasye L C. WL11 Lame. 33D4, tagusyd

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a. ATTACHMENT B Peg 2 1 of 4

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O ATTACHMENT Q ECSP CORRECTIVE Action Tracking Document (CATD)

INITIATION

l. Immediate Corrective Action Required: // Yes /N/ No

2. Stop Work Recommended: /[/ Yes /X/ .No

3. CATD No. 80000-SQN-01 4. INITIATION DATE 10/1/86

5. RESPONSIBLE ORGANIZATION: ONP 6.

PROBLEM )E5CRIPTION: /[/ QR /X/ NQR . -

• i 1

Failure to write a site NCR and to quickly remove from the site ,,

~ PJJ and PNJ cables resulted in its subsequent noncontrolled use.

, ' 1..n

.;w Testing was recently conducted to qualify the cables identified l' 16 _i. in SQN-EQ-CABL-034, and the cables have a qualified life of 20 years. However, additional testing has been deemed required to '

extend the life of these cables however, this extension is not..

I,

• reouired prior to start up.

e

// ATTACHMENTS

. 7. PREPARED BY: NAME Wayne M. Akeley tom A. DATE: 10/1/86 3 ,, 8.- CONCURRENCE: CEG-H R. R. Maxon A / h DATE: / O-/-t"Q ~

,m. 9. APPROVAL: ECTG PROGRAM MGR: 6fffM//' 'L DATE: ~3/z gp7

. CORRECTIVE ACTION - *

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^... 10.*?' PROPOSED CORRECTIVE ACTION PLAN:'

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, / / ATTACHMENTS

11. PROPOSED BY: DIRECTOR MGR: g/f /46,4 . //

12. DATE: //-A O-/ J.

CONCURRENCE: CEG-H A b4 4 Mh's '

DATE: 7,/4 / f')

-r # #

_ SRP: DATE:

ECTG PROGRAM MGR: DATE:

. VERIFICATION AND CLOSEOUT ,

13. Approved corrective actions have been verified as satisfactorily -

. yp

< implemented.

~ 4 ,.

SIGNATURE TITLE DATE

- _ m_. y. ._ _,,___,._.-y ._ y , , . _ . . _ - - . . __ - . . . _ . - _ _ , , . .y --- , , - -

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._ ATTACHMENT B h. Pega 3 of 4

Lf/*{

j .c. l STANDARD PRACTICE Page 8 SQA166 N .

Rev. 8 Attachment A

, Page 1 of 2 Ccrrective Action Plan of Fmployee Concern Investigation Tracking Checklist ECTG Report /CATD Number 800.00 - SON /CATD #80000 - SON *01 Lead Organization Responsible f or Corrective Action ENG Initiation Date 10-16-86 CORRECTIVE ACTION PLAN (CAP)

1. Does this report require corrective action? Yes No I (If yes, describe corrective action to be taken, if no, provide justification)

The SON EO oroiect has documentation to demonstrate environmental cualification for TVA-tvoe PJJ cable installed in 50.49 circuits at ,

SON. This ~ documentation is contained in Seouovah Environmental Pack-ares SONEO-CABL-001. -015. -020. and -034. Review of the Secuovah Electrical Eauinment List ( SOEL) shows that no PNJ cables (or cables

[. .M.h .

from the same cable family) has been installed in 50.49 circuits. - /

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j

2. Identify any similar item / instances and ccrrective action taken. - ---

Refer to W. L. Elliott's ===o to G. T. Hall dated February 11. 1986 (B70 860211 001). This ===orandum identified all cables in the cur-rent cable yard inventory that were considered by E0P as not suit able -

for installation in new 50.49 circuits. In addition. the memorandum recommended that cable in this catenory be "oroneriv disoositioned and R2y_ed to a non-nuclear site." The yard inventory at that time showed

• that no tvoe PJJ or PNJ was on site. The inventory did show that tvoe PN ( same family as PNJ) was on site. The tvoe PN cable was included in the aroun of cable that E0P ree-anded to move off site.

3. Will corrective action preclude reccurrence of findings?

Yes I No

4. Does this report contain findings that are conditions adverse to cuality (CAQ) as defined by AI-12 or NEP 9.17 Yes No I

5. IF a CAQ condition exists, what CAQ document was initiated?

6. Which site section/ organization is responsible for corrective action?

7. Is corrective action required f or restart? Yes No (This determination is to be made using Attachment C of SQA166.)

8. P2 zone number for restart corrective action? Zone _ _ . .

9. Estimate completion date f or corrective action. ,

N,, ' * '

Completed By 10w O~~so Date 1) /,2/92 Approved By M/ M Date h // MM ECTG Concurrence Adllwkt- df/d +/ Date 2./4/'f~7

• 6 y t C26318.01