ML20214K610
| ML20214K610 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/24/1986 |
| From: | Mcdonald J TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8612020375 | |
| Download: ML20214K610 (129) | |
Text
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, s. TENNESSEE VALLEY AUTHORITY m
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q Watts Bar Nuclear Plant P. O. Box 800 Spring City, Tennessee 37381 October 24, 1986 Mr. Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814
Dear Mr. Denton:
In the Matter of the Application of ) Docket Nos. 50-327 Tennessee Valley Authority ) 328
SUBJECT:
EMPLOYEE CONCERNS TASK GROUP (ECTG)
Enclosure 1 to this letter transmits the final report for one element-addressing Sequoyah Nuclear Plant (SQN) employee concerna in the quality assurance category, two elements in the material control category, one element in'the construction. category, and 13 elements.in the operations category. As indicated by the report cover sheets, these reports have cosapleted final review by the Senior Review Panel and the Employee Concern Task Group management. These particular reports did not require any corrtetive actions by the line organization as a result of the employee concerns.
I To assist you'in your review of these reports, Enclosure 2 provides a comparison between the ECTG Writer's Guide recommended report format and the l' transmitted reports. The report from the quality assurance category complies fully with the Writer's Guide. Enclosure 3 provides a listing of the report numbers, the related employt? concerns, and the previous submittal dates if
- applicable.
Please telephone Martha Martin at (615) 365-3587 (Watts Bar) if you have any questions.
I
! Very truly yours, TENNESSEE VALLEY AUTHORITY
- We
! . A. Mcdonald Watts Bar Nuclear Plant Site Licensing Manager Enclosures 8612O20375 861024
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PDR ADOCK 05000327 'I P PDR L l An Equal Opportunity Employer -
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2 Mr. Denton ec (Enclosures):
Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. B. J. Youngblood, Project Director PW2 Project Directorate #4 Division of PWR Licensing - A U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Room 440, 5' Story Phillips Bethesda, Maryland 20814 U.S. Nuclear Regulatory Commission
. Region II Attn: Mr. Gary Zech 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 i
- >- TVA EMPLOYEE CONCERNS REPORT NUMBER: 309.05-SQN
? SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 1 TITLE: Engineering Training REASON FOR REVISION:
Revised to incorporate SRP and TAS comments Revision 1 PREPARATION
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b TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Engineering Element: Engineering Training Report Number: 309.05 - SQN, Revision 1 IN-86-209-012 Evaluatoe: f/6k J/)f7/)&$$
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I. Shift Technical Advisor Training This report evaluates one concern regarding the qualifications of the Sequoyah Nuclear Plant Shift Technical Advisor (STA) instructors.
II. Specific Evaluation Methodology Concern IN-86-209-012 stated: " Personnel performing STA (Shift Technical Advisor) Training are engineers with little or no experience as an STA themselves.,It was noted that two persons that were being processed through a particular STA class, were scheduled to teach the next class of STA's. Engineers are being assigned the task of training STA's in plant operations, for which they themselves have little or no experience."
Evaluation of this concern involved the review of regulatory requirements, TVA commitments and procedures, STA instructor assignments, and the qualifications of the instructors for those assignments. Interviews with cognizant personnel were also conducted to determine the adequacy of the instructor's techniques.
III. Findings A review of regulatory requirements in ANSI 3.1, NUREG 0660, and NUREG l 0737, revealed that there are no requirements for STA instructors to be l experienced STAS. Rather, the requirements are that the instructors be lR1
" technically qualified for the subjects taught." l Nuclear Training Program Manual Procedure 0202.07 governs the TVA Shift Technical Advisor Training Program and Sequoyah Engineer Training Section Letter ETS-1-STA implements the requirements of 0202.07. Listed below are the qualifications for SIA instructors defined in ETS-1-STA.
Instruction and Instructors All instruction is provided as follows:
Section I - Plant Systems--Certified STA or qualified Shift Engineer, RO or SRO.
Section II - Plant Familiarization and W<.lkthrough--Experienced Certified STA, RO, SRO, or experienced AUCJ with approval of Training Shift Engineer, anung Section III - Applied Heat Transfer. Fluid Flow, and Thermodynamics Bachelor's degree in engineering or physical sciences with specific training or experience in subject areas, preferably a mechanical, nuclear, or chemical engineer.
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_ Section IV - Simulator Training--Classroom - Qualified SRO or Certified STA; Simulator - Qualified SRO or simulator Certified STA.
Section V - Applied Reactor Physics--Eachelor's degree in engineering or physical sciences with specific training or experience in subject area, preferably a nuclear engineer.
Section VI - Applied Radiochemistry and Nuclear Materials Radiochemistry: Qualified Radiochemical Lab Analyst or bachelor's degree in engineering or physical sciences (preferably chemical engineering) with specific training in the subject area.
Nuclear Materials: Bachelor's degree in engineering or physical sciences with specific training or experience in subject area (preferably a mechanical or nuclear engineer.)
Section VII - Simulator Transient and Accident Analysis Classroom: Certified STA Simulator: Qualified SRO or simulator Certified SIA Section VIII - Management and Supervisory Skills--Industrial educator-skilled in human relations and supervisory techniques.
Section IX - Health Physics and Mitigating Core Damage Health Physics: Qualified HP Technician Mitigating Core Damage: Certified STA Section X - Electrical and Process Control--Bachelor's degree in engineering or physical sciences with specific training or experience in subject area (preferably an electrical engineer.)
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s Individuals who have technical expertise in any subject area as a result 1 of previous training or extensive experience may be used to provide instruction-for that topic even though they do not meet these specific guidelines. Instruction provided by such individuals must utilize training materials developed and approved in accordance with Nuclear !
Training Branch Standard Practice TCT-15. Also, if these individuals have not attained the necessary instructional qualifications, training quality is maintained through appropriate and qualified assistance and supervision by an individual with full Instructor Certification as required by ICT-16. In such instances, the Section Supervisor shall give his permission for these individuals to conduct this training.
These requirements meet or exceed the regulatory requirements for STA instructors.
During the course of the evaluation, a memorandum from R. Joe Johnson, Chief, Nuclear Training Branch to J. P. Darling, Site Director, Bellefonte, was found which contained the Nuclear Training Branch response to the concern involved in this evaluation. This response was written because of a request from Bellefonte personnel to address the concern for Bellefonte.
l Page 2 of 4 i
. The memorandum lists.the qualifications of STA instructors used'during the last two years and identifies two individuals assigned training duties for the class immediately following the classes they were attending. These instructors were used only in areas where they had particular expertise due to previous 6xperience. This is in accordance with the requirements of ETS-1-STA as noted above.
A smamary of the two individual's qualifications and assignments follows:
Instructor #1 had extensive training and experience in l Instrumentation and Control Systems and training in Transient and i Accident Analysis inside and outside TVA. He was used to instruct l several STA classes in areas where he had particular expertise. The I following is a list of several courses he has successfully completed I prior to instructing any of the STA classes: l l
- 1. Westinghouse Transient and Accident Analysis l
- 2. Westinghouse AEH Control and Maintenance l
- 3. Bellefonte Cold License Training l
- 4. IEEE Sponsored Transient Stability Analysis Course lR1 lR1 He also has extensive operating plant experience at Sequoyah Nuclear i Plant (SQN), during the period from March 1980 to March 1982, by I participating in both units startup as an Instrumentation Engineer. 1 He has 4 years of instructional experience at the Power Operations l Training Center. He taught subjects concerning instrumentation and I control to instrument mechanic students, and planL systems to plant l
. maintenance personnel. l l
Instructor #2 has extensive operational experie~nce at SQN. He was l responsible for preoperational testing of the Rod Control System for l both units during their respective initial startups. This was the l only system that he provided instruction for during STA Training. l A review of instruction assignments and class rosters at the Power i Operations Training Conter revealed that the instructors noted in the lR1 memorandum had taught only those classes noted in the memorandum. 1 It was also noted during this review of records that one of the l individuals had previously achieved full instructor certification in l l accordance with TCT-16 while assigned to another training unit before l l joining the STA Tesining Section. The other instructor referenced, while l l not fully certified, was pursuing certification and was within the lR1 i allowable time limits specified by TCT-16. Also, his performance as an 1 j inst'ructor has boon evaluated by both his supervisor and the Instructor l Certification and Staff Development (ICESD) Unit in accordance with l TCT-16. These evaluations indicated his performance was adequate with l minor comments.
J Additionally, it should be noted that, while these two instructors did l l not have experience as STAS, they did have extensive experience previous 1
, to their assignments as STA instructors and had passed the STA lR1 certification course which requires an average of 80 percent scores. l Page 3 of 4
b L .2 m
, Element report 307.08 SQN also addressed a portion of STA training. It l
, reviewed the reportability determination portion of STA training with l the findings that the STA training course included a lesson plan which l-covered 10 CFR 72 and 10 CFR 73 reporting requirements with practical lR1
. exercises. This area was covered twice, once during classroom and again 'l prior to simulator training. l I
Based on these findings, no further evaluation of STA training was l conducted. l
Conclusions:
Concern IN-86-209-012 was substantiated, in that there were two instructors assigned training duties with little or no STA experience.
However..the qualifications of these two individuals were well matched to the subject matter assigned. The duties assigned were also well within the requirements, both regulatery and TVA, for STA instructor qualification.
No remedial action is necessary nor were any safety-related or safety-significant issues identified.
IV. Root Cause Root cause of this concern appears to be that the concerned individual l was not fully aware of the previous experience of the instructors IR1 involved. l Y. Generic Applicability As all training conducted at the sites is governed by Nuclear Training l Branch procedures and the Nuclear Training Program Mannual, this l evaluation determined the adequacy of those procedures for STA lR1
, instructors. This concern is not considered generically applicable l to other sites. l j VI. References
- 1. ANS-3.1; Standards for Selection, Qualification, and Training of j
P.arsonnel'in Nuclear Power Plants - 1981
- 2. NUREG-0737; Clarification of TNI Action Plan Requirements - October 31, 1980
- 3. Nuclear Training Program Manual Procedure 0202.07, Revision 0; Shift Technical Advisor
- 4. Sequoyah Engineering Section Letter ETS-1-STA, Revision 1; Shift Technical Adviser
- 5. Nuclear Training Branch Standard Practice TCT-16; Certification of All Instructors - September 20, 1985 i VII. Immediate and Long-Term Corrective Action l
None required Page 4 of 4
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REFERENCE - ECPSI20J-ECPSIZIC TENNESSEE VALLEY AUTH!RITY PAGE -2db
() FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - I:
ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE I LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30905 TECHNICAL TRAINING ,
S GENERIC KEYHORD A H APPL QTC/NSRS P .
KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C C) NUMBER CAT CAT D LOC FLQB REP. ORT R DESCRIPTION KEYNORD D IN 209-012 OP 30905 N WBN NNYN PERSONNEL PERFORMING STA (SHIFT TECH TRAINING T50218 . REPORT ICAL ADVISOR) TRAINING ARE ENGINEERS QUALIFICATION
() HITH LITTLE OR NOT EXPERIENCE AS AN STA THEMSELVES. IT HAS NOTED THAT ENGINEERING GENERAL TWO PERSONS THAT HERE BEING PROCESSE D THROUGH A PARTICULAR STA CLASS, HE 4b -
RE SCHEDULED TO TEACH THE NEXT CLASS OF STA'S. ENGINEERS ARE BEING ASSI GNED THE TASK OF TRAINING STA'S IN P LANT OPERATIONS, OF HHICH THEY THEMS .
db ELVES HAVE LITTLE OR HO EXPERIENCE.
CI HAS NO ADDITIONAL INFORMATION.
NUC. P0HER DEPT. CONCERN.
4b I CONCERNS FOR CATEGORY OP SUBCATEGORY 30905 4
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. . , TVA EMPI4YEE CONCERNS REPORT NUMBER: 307.08-SQN ,
. SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 1 TITLE: Training Programs for Employees REASON FOR REVISION: Incorporate SRP Comments Revision 1 PREPARATION PREPARED BY:
M. W. Murphy 10/13/86 SIGNATURE DATE
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4 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Nuclear Power Site Programs / Procedures Element: Training Programs for Employees Report Number: 307.08-SQN Revision 1 XX-85-122-036 XX-85-058-001 Evaluator: / // // #/b5 f.5 M. W. r hp Date Reviewed by: .- -Il! % 9 I [
{0PS DEG Mergber 'Date Approved by: h. o" Tk 3hl, W. R. Lagpedren / Da1(e 4
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1 Rsvisien 1 I. Event Reporting i
This report evaluates two concerns, one regarding the required reporting of events at Sequoyah Nuclear Plant (SQN) and the other regarding the size of General Employee Training classes at SQN.
II. Specific Evaluation Methodology Concern XX-85-122-036 states:
" Improper reporting of events at operating plants or in design / construction. IVA personnel are not adequately trained and are not knowledgeable in what is reportable."
To evaluate this concern, regulatory requirements for reporting of operating events were reviewed. TVA procedures governing those reportability requirements were reviewed and the training of individuals responsible for reporting events were reviewed.
A review of the report history since 1984 was conducted to determine if significant events were gorrectly reported and a document search for NRC
- or NSRS problems with reports was conducted.
The second concern XX-85-058-001 states:
" Employees at Sequoyah are run through indoctrination training classes "like cattle." Insufficient time is spent in training classes (specifically Health Physics) prior to being given tests. i Instructors who are familiar with the subject matter " breeze . ,
through" the lessons.
This concern was previously evaluated by the Nuclear Training Branch and a report t'ts issued which contained their findings (Reference 12). lR1 A review of the above referenced Nuclear Training Branch report was conducted to determine whether the evaluation conclusively established <
the validity of the concern. In addition, an interview with a cognizant training representative was conducted to verify that the report information was current.
III. Findings A. XX-85-122-036 Reporting of potentially significant events at operating nuclear power plants is defined in 10 CFR 50.72 and 10 CFR 50.73 and 10 CFE 21. lR1 These regulations require the utility to notify the NRC of certain events within specified timeframes depending on the severity of the event.
Page 1 of 5
, Revision 1 III. Findings (continued)
The format and content of follow-up written reports is defined in NUREG 1022. These Licensee Event Reports (LER) must be filed within 30 days of the occurrence of an event and must adequately describe the event, the cause of the event and corrective actions taken to prevent recurrence of the event.
Sequoyah Standard Practice SQA 84 contains TVA's system for identifying potentially reportsble occurrences. The occurrence may be reported by anyone, then forwarded to the Shift Technical Advisor (STA) and the Shift Engineer (SE) for evaluation of immediate reportability under 10 CFR 50.72 or 50.73. The guidance for that evaluation is contained in Sequoyah Administrative Instruction AI-18, file package 18. The Potential Reportable Occurrence (PRO) form is then forwarded to the Plant Operating Review Staff (PORS) for further evaluation and preparation of an LER, if necessary. A comparison of the guidelines in AI-18 to the lR1 requirements of 10 CFR 50.72, 50.73 and 10 CFR 21 revealed no l deficiencies. Upon completion of LER preparation, the LER is l transmitted directly to the NRC from SQN. l A review of training records for STA's, SE's and PORS personnel verified that. training was conducted for all STA's and licensed operators during December 1983. This was the time that the revision to 10 CFR 50.72 and 50.73 was to be implemented. In this same timeframe four personnel assigned to what is now the PORS group attended a seminar given by NRC in Atlanta regarding the changes to 10 CFR 50.72 and 50.73 as well as NUREG 1022.
STA training course content contains a comprehensive lesson plan on reportability requirements which includes practical exercises on determining reportability for various scenarios. This is again reviewed towards the end of the course.
Classes on reportability requirements have been conducted during licensed operator requalification and simulator scenarios include reportability requirements as objectives.
Further, the PORS Supervisor indicated informal (no documentation maintained) classes have been held with newly assigned personnel on the reportability requirements.
A computer search through Document Control for NRC or NSRS generated communications regarding LERs or Reportable Occurrences (R0s) since 1983 revealed only one instance of questionable accuracy of an LER.
This LER was submitted as a result of the unit 1 incore instrumentation thimble tube ejection accident which occurred on April 19, 1984. NSRS, while not disputing the accuracy of the LER, did not feel the LER was complete, and by ommission, was misleading. The NSRS recommendation to submit a revised report containing the additional information was followed and the revised LER was determined to be adequate by NRC.
Page 2 of 5
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'* . Revision 1 III. Findings (Continued)-
A review of 762 PR0s issued since January of 1985 indicated a wide I diversity of_ potential events reported. -This review determined that l there were no areas of required reporting under 10 CFR 50.72 or l 10 CFR 50.73 that were consistently not reported. A review of the l PORS database did not reveal any instances where a situation I required reporting and an LER was not issued. It should be l noted, however, that the majority of PR0s initiated do not' I requira NRC reporting. It is possible that the initiator could lR1 disagree with the final disposition of the PRO, but no instances I were found to indicate-incorrect determinations. A random sample l of 30 PR0s were reviewed which revealed no instances of improper l '
determination of reportability requirements. A random sample of 14 l
LERs issued were reviewed for adequacy and content with no I deficiencies found. l B. XX-85-058-001 The Nuclear Training Branch evaluation report for concern XX-85-058-001 did not substantiate the concern. The following excerpt from the report documents the reasoning behind this conclusion.
General Employee Training (GET) classes are attended by employees with various educational backgrounds and occupations. The time allotted to a specific class is based on experience with typical classes containing a cross section of employees. An instructor may not know if a'particular person is having difficulty unless that individual informs the instructor. It should be noted that .
instructors are certified by TVA, through special training courses.
The approved instructor lesson plans specify what material is to be covered and also specify the timeframe allotted. At SQN, when an instructor is aware that a particular employee needs individual attention, special arrangements may be made to tutor the individual. This has occurred on at least one occasion .
4 With regard to class size the following actions are being or have been taken:
I
- 1. Additional classes are scheduled for peak periods, such as outages.
- 2. AsintheweekofSeptember9,1985,s[ecialclasseswereheld 1
on back shifts.
- 3. An evaluation of position requirements is being conducted to determine if some employees are being required to attend unnecessarily. This could contribute to reduced class size.
- 4. GET-2.4, Level 0 Health Physics was recently implemented for those employees not requiring access to the Power Block. This also contributes to reduced class size in HP GET.
Page 3 of 5
Revision 1 III. Findings (Continued)
Additionally, it should be noted that all instructors are evaluated by the Instructor Certification and Staff Development (IC&SD) Unit, annually. Also, the Plant Training Supervisor sits on two classes per week for the purpose of instructor evaluation. These evaluations are documented in his weekly. activity report to the Power Operations Training Center (POTC).
It should also be noted that each individual attending a GET class is handed a course evaluation form by which they may provide feedback to the training section regarding both the program and the instructor. A review cf recent evaluation forms did not reveal any comments similar to the concern.
Conclusions Concern XX-85-122-036 was not substantiated. The program, training and implementation for reporting of events at SQN meets the regulatory requirements and allows for additional conservatism. The one instance where questions arose cannot be construed as programmatic in nature, but rather an isolated case which was caught and corrected.
Concern IX-85-058-001 was not substantiated. While GET class sizes may be large at times, no evidence that the quality of instruction is impacted was found. In addition, efforts have been effected to reduce the class sizes to a manageable level.
IV. Root Cause
. Nu root cause was determined, as neither of the concerns was valid. lR1 V. Generic Applicability As neither of the concerns was valid, no generic applicability to other l i sites is considered. However, concern XX-85-122-038 is identical to lR1 XX-85-122-036. It is issued specifically to Browns Ferry and will be l evaluated at Browns Ferry. l l
l l
l Page 4 of 5
R3risien 1. '
4 VI. References
- 1. 10 CFR 50.72; 1985
- 2. 10 CFR 50.73; 1985
- 3. NUREG 1022; 1984; Licensee Event Reports 4 '. SQA 84, Revision 4; Reportable Occurrences
- 5. AI-18. Revision 43; Plant Reporting Requirements
- 6. PRO database (PORS maintained)
- 7. Licensee Event Reports
.a. 1-84030
- b. 1-84030, Revision 1
- c. 1-85001
- d. 1-85019 j e .- 1-85026
- f. 1-85029
- g. 1-85040
- h. 1-86004 1, 1-86008 i j. 85001
- k. 2-85005
- 1. 2-85009
. m. 2-85012
- n. 2-86003
- 8. NSRS report I-84-12-SQN
- 9. STA lesson plans
- s. SYS 003.55, Revision 0. Technical Specifications and -
Reportability Requirements
- b. SMT 202C341 Revision 0, Review of Technical Specifications and Reportability Requirements ,
- 10. Nuclear Training Program Manual Procedure 0202.04, Revision 0; e
General Employee Training
- 11. Nuclear Training Branch Standard Practice TCT-16; Certification of All Instructors; September 20, 1985
- 12. Memorandum from H. L. Abercrombie to W. H. Thompson dated September 19, 1985, regarding XX-85-058-001 (S00 850917800).
{ VII. Immediate and Long-term Corrective Actions None f
Page 5 of 5 i
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,, NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D XX 058-001 OP 30708 N SQN NNYH XX-85-058-001 NS EMPLOYEES AT SEQUDYAH ARE RUN THROUG TRAINING T50I08 K-FORM H INDOCTRINATION TRAINING CLASSES "L HEALTH PHYSICS'
IKE CATTLE". INSUFFICIENT TIME IS S OPERATIONS PENT IN TRAINING CLASSES (SPECIFICAL GENERAL LY HEALTH PHYSICS) PRIOR TO BEING GI VEN TESTS. INSTRUCTORS, WHO ARE FAMI LIAR HITH THE SUBJECT MATTER, " BREE ZE THROUGH" THE LESSONS. CI HAS NO ADDITIONAL INFORMATION NO FOLLOH UP REQUIRED XX 122-036 OP 30708 N SQN NNNN I-85-981-SQN NS SEQUDYAH: IMPROPER REPORTING OF EVEN TRAINING T502I5 K-FORM TS AT OPERATING PLANTS OR IN DESIGN / PROGRAMMATIC CONSTRUCTION. TVA PERSONNEL ARE NOT GENERAL
"" ADEQUATELY TRAINED AND ARE NOT KNOHL GENERAL EDGEABLE IN HHAT IS REPORTABLE. CI H AS NO FURTHER INFORMATION. ANONYMOU S CONCERN VIA LETTER.
2 CONCERNS FOR CATEGORY OP SUBCATEGORY 30708 W
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..., TVA EMPLOYEE CONCERNS REPORT NUMBER: 307.07-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant-Elernent REVISION NUMBER: 0 TITLE: Radiological Emergency Plan REASON FOR REVISION:
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Nuclear Power / Site Program / Procedure Element: Radiological Emergency Preparedness Report Number: 307.07 - SQN JLH-86-004 XX-85-035-OO1
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I. Title Radiological Emergency Plan Two Sequoyah Nuclear Plant (SQN) specific concerns are addressed in this re po rt. One concern questions the adequacy of evacuation routes, the other concern questions the prudence of issuing potassium iodide (KI) to Sequoyah site employees. and the general public.
II. Specific Evaluation Methodology Concern JLH-86-004 states:
"The evacuation route away from Sequoyah Nuclear Plant for area residents on both sides of the Tennessee River is inadequate. A four-lane highway from the new Highway 27 to SQN and across the Tennessee River to connect with I-75 would provide for a safe evacuation in case of a nuclear related accident."
Concern XX-85-035-001 states:
"Iodire tablets have been issued to Sequoyah site employees and the general public in the Sequoyah area, before the occurrence of a radiation incioent. The result is that these tablets may be used in an unsupervised and possible hazardous manner."
The evaluation of these concerns included a review of applicable NRC and FEMA emergency preparedness criteria. This included 10 CFR 50, Appendix E and NUREG 0654/ FEMA Repl. .
TVA, State of Tennessee, Bradley and Hamilton County emergency preparedness documents were reviewed.
Cognizant emergency preparedness personnel at SQN and Chattanooga were interviewed. State and local emergency preparedness personnel were not contacted. Recent FEMA evaluations of SQN emergency exercises were also reviewed. <
III. Findings Evaluation Results JLH-86-OO4 NRC requires nuclear power plants to develop and implement emergency response plans. These plans must address protective measures, including evacuation, to protect the general public. However, TVA has no legal authority to implement protective measures outside the plant boundarie s . Tne Tennessee Emergency Management Agency (TEMA), Hamilton and Bradley Counties have developed a " Multi-Jurisdictional Radiological Emergency Response Plan," which provides for the evacuation of a 10-mile area around SQN.
Page 1 of 4
.. e The multi-jurisdictional response plan includes the emergency response plans for Hamilton and Bradley Counties (counties within the 10-mile emergency planning zone). The plan identifies the evacuation routes for area residents, gives population and vehicle estimates for both the permanent and transient populations, describes the roadway characteristics of evacuation routes, and provides estimates of the time required to evacuate the population.
The plan also includes the responsibilities and means for alerting and warning the public, traffic control points for rerouting or diverting traffic from crowded routes, and traffic aseistance teams to assist vehicles that have broken down or run out of gas.
The Federal Emergency Management Agency (FEMA) has reviewed the multi-jurisdictional plan and has evaluated the annual emergency preparedness exercises conducted jointly by TVA, the State of Tennessee, and Hamilton and Bradley Counties. FEMA has found that the multi-jurisdictional response plan provides adequate protection for the population around SQN. The FEMA Evaluation Report on the 1985 emergency exercise for SQN stated:
"Dradley and Hamilton counties demonstrated an adequate capability to evacuate the populace of an endangered area."
. Residents living within 10 miles of SQN have received an information brochure on emergency actions in case of a radiological emergency at SQN. The brochure includes information on:
o
- Emergency classifications
- Potassium Iodide pills
- Evacuation and evacuation routes
- SQN - Radiological Emergency Plan (REP)
- SQN Emergency Information Brochur e i
XX-85-035-00,1 Potassium iodide (KI) tablets are used to reduce the uptake of radioactive iodine by individuals exposed to airborne radioactive material. The issuance of KI to site employees is controlled by SQN-IPs. KI has not been distributed to employees at SQN. During an actual radiological emergency, KI may be issued to individuals suspected i
Page 2 of 4 l
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of receiving thyroid doses greater than 10 rem. Currently, KI is stored onsite. The supply of KI is maintained and inventoried quarterly by the plant nurse. Information on KI, including who should and should not take it and possible side effects, is provided by the manufacturer.
This literature is contained in the KI packages and SQN-IP-14.
The State of Tennessee has distributed KI to each household within a 5-mile radius of SQN. In addition, KI is stored at each school within the 5-mile radius. This decision was made by the State of Tennessee, not TVA. TVA has no authority or control over decisions made by the State. The decision to actually use KI would be made by the State Division of Radiological Health and the State Medical Officer. The Emergency Information Brochure informs residents that "you should not take the pills unless you have been specifically told to do so by State Health Officials."
Conclusions Neither concern was validated. FEMA has stated that the counties within 10 miles have " demonstrated an adequate capability to evacuate the populace." The distribution of KI to site personnel is controlled by plant procedures. KI has not been given to site personnel. The distribution of KI to area residents is a function of state and local government. TVH has no authority or control over decisons made by the
. State of Tennessee.
IV. Root Cause N/A V. Generic Applicability Concern JLH-06-004 is Sequoyah specific and is not applicable to other TVA sites. The distribution of KI to site personnel, Concern XX-85-035-001, is applicable to other TVA sites.
VI. References
- 3. Sequoyah Nuclear Plant - Radiological Emergency Plan (REP)
- 4. SQN-IP-14, " Health Physics Procedure," Revision 9, December 27, 1984 page 3 of 4
.+ ,
- 5. SQN-IP-17, " Emergency Equipment and Supplies," Revision 10, October 16, 1985
- 6. " Tennessee Multi-Jurisdictional Radiological Emergency Response Plan for Sequoyah Nuclear Plant," March 1986
- 7. Sequoyah Emergency Information Booklet, Spring 1986
- 8. Sequoyah Nuclear Power Plant Exercise Report, FEMA, March 5, 1986
- 9. NUREG/CR-1856, "An Analysis of Evacuation Time Estimates Around 52 Nuclear Power Plant Sites," USNRC, May 1981
- 10. " Employee Response Team Investigation Report For Concern IN-85-170-002," J. W. Hufham to K. W. Whitt, June 19, 1985 (L63 850612 810)
- 11. Employee Concern Disposition Report, Concern No. XX-85-035-001, July 12, 1985
- 12. Response.to Employee Concern JLH-86-004, W. S. Wilburn to J. L. Hamilton, March 5, 1986 (S01 860305 995)
-VII. Immediate or. Long-Term Corrective Action None required Page 4 of 4
l .. .
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TENNESSEE VALLEY AUTHORITY PAGE . '-30$i REFERENCE - ECPS120J-ECPS121C OFFICE OF NUCLEAR PDHER RUN TIME '12:1
) FREQUENCY - REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DKTE L- 10/t ONP - ISS$ - RHM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30707 RADIOLOGICAL EMERGENCY PLAN
) ". KEYWORD A S GENERIC KEYNORD B H APPL QTC/NSRS P S CONCERN KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION KEYNORD D CAT D LOC FLQB REPORT R DESCRIPTION i NUMBER CAT 30707 N SQN NNNN SS THE EVACUATION ROUTE AHAY FROM SEQUO JLH-86-004 OP K-FORM YAH NUCLEAR PLANT'FOR AREA RESIDENTS ON BOTH SIDES OF THE TENNESSEE RIVE
) R IS INADEQUATE. A FOUR-LANE HIGHHA Y FROM THE NEN HIGHHAY 27 TO SQN AND ACROSS THE TENNESSEE RIVER TO CONNE CT HITH I-75 HOULD PROVIDE FOR A SAF
) E EVACUATION IN CASE OF A NUCLEAR RE LATED ACCIDENT.
o XX-85-035-001 10DIHE TABLETS HAVE BEEN ISSUED TO S HEALTH PHYSICS
) XX 035-001 DP 30707 N SQN EQUOYAH SITE EMPLOYEES AND THE GENER SAFETY CONDITION T50007 K-FORM AL PUBLIC IN THE SEQUOYAH AREA, PRIO HEALTH PHYSICS-R TO THE OCCURRENCE OF A RADIATTON I GENERAL NCIDENT. THE RESULT IS THAT THESE T
) ABLETS MAY BE USED IN AN UNSUPERVISE D AND POSSIBLE HAZARDOUS MANNER.
) 2 CONCERNS FOR CATEGORY OP SUBCATEGORY 30707
)
)
)
)
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TVA ENPLOYEE CONCERNS REPORT NUMBER: OP 303.01-SQN '
.. SPECIAL P20GRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 1 TITLE: Difficulty of Obtaining Obsolete Equipment REASON FOR RETISION: To incorporate SRP comuments. Revision 1 PREPARATION PREPARED BY:
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- SRP Secretary's signature denotes SRP concurrences are in files.
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a TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Instrumentation and Radiation Monitoring Element: Difficulty of Obtaining Obsolete Equipment Report Number: 303.01 SQN Revision 1 IN-85-841-001 Evaluator: IG.bmo# dW Darrell Gardner 9-N-DL Date Reviewed by: .} d f +-) _
7 [1.1 P 'ClG ember / Datel -
Approved by: kli P. W kb W. R. Lagerdrin i Dat/e 1123T
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. ,, Rsvision 1 I.- Difficulty of Obtaining Obsolete Equipment IR1 This report evaluates employee concern IN-85-841-001 on obtaining spare
! parts for plant instrumentation at Sequoyah Nuclear Plant ~(SQN). This concern was determined potentially safety related and generic to SQN by the Employee Concerns Task Group Technical Assistance Staff.
II. Specific Evaluation Methology The employee concern identified to Quality Technology Company (QTC) for Watts Bar Nuclear Plant (WBN) is as listed below:
IN-85-841-001 "Old" plant instrumentation (procured 10-12 years ago) is often no longer manufactured / spare parts are difficult or not possible to obtain. Purchase requisitions for unobtainable parts ars cancelled, yet cognizant management (department known) have ,
instituted no alternatives measures to obtain substitutions of parts / replacement items. This has the potential to adversely impact plant operations. CI postulated this concern to both units 1 and 2. Management (name known) is aware of this problem, but has provided no action / response. No further details
- available.
3 Since the concern was specific to WBN, the scope with regard to SQN was lR1 ,
determined to be the adequacy of procedures for obtaining space parts or :
replacing obsolete plant' instrumentation. An informal interview with a cognziant supervisor in SQN Instrument Maintenance was conducted and SQN Administrative Instructions and Standard Practices were reviewed (Reference 1-3) to support the evaluation effort. The WBN plant i response to this concern was also reviewed for supplemental information (Reference 4).
III. Findings ;
I The WBN plant response to this employee concern states that WBN AI-9.11 provides a method for obtaining new plant instrumentation to replace obsolete instrumentation utilizing a Design Change Request (DCR).
Sequoyah's Standard Practice SQM-60 is equivalent to WBN AI-9.11 in that each provides instructions for replacing obsolete equipment using the DCR process., This Standard Practice refers to Division Procedure Manual (DPM) N77A12 (Reference 5) although it has been cancelled (References 6 and 7). SQM-60 is nearly identical in its wording to DPM N77A12 which was a QA implementing document. The change request that cancelled the DPM stated transfer of responsibility to the sites as the reason for. request. The reason for a cancellation was given as "no longer applicable" although no justification was provided. The cancelled cover sheet references NQAM, Part II, Section 3
. " Modifications." No statements regarding replacing obsolete equipment were found in the NQAM.
Page 1 of 4
l R3 vision 1 A cognizant supervisor in the SQN Instrumentation Maintenance section was contacted and stated that when Power Stores could no longer provide a spare parts inventory for original equipment, the responsible i sections are notified to initiate a DCR for replacement / substitution equipment in accordance with AI-11 and SQA-45. The supervisor stated that there are no adverse effects to safety because the equipment is periodically verified to meet design / technical specification requirements by Surveillance Instructions. Should any equipment be found inoperable or fail to meet these requirements, then the plant must take action in accordance with the applicable Technical Specification Action Statement. SQN AI-11 and SQA-45 were reviewed for equipment substitution procedures. SQA-45 refers to AI-ll for substitutions and detailed procedures are provided for ensuring substituted equipment meets the original design requirements. Standard Practice SQM-60 was found to provide equivalent instructions to WBN AI-9.11 for replacing obsolete equipment using a DCR (Reference 1).
SQM-60 states that any responsible or knowledgeable person may propose a modification to replace or repair obsolete instrumentation in-accordance.with AI-19 on DCRs.
Conclusion The issue presented by IN-85-841-001 was not validated for SQN nor were l any potential safety-related issues identified. Procedures exist at l SQN for identifying and replacing obsolete plant instrumentation. SQN lR1 ,
Standard Practice SQM-60 states that any knowledgeable person may l propose to replace obsolete instrumentation by initiating a Design l Change Eequest in accordance with AI-19. 1 IV. Root Cause No deficiencies were identified during this evaluation, therefore, no IR1 root cause analysis was performed. I Y. Generic Applicability Although the concern was not valid for SQN the same investigation should lR1 be conducted for BFN. I Page 2 of 4
, , Revision 1 VI. References
- 1. SQN Standard Practice SQM-60, Revision 0, " Requirements for Repair and/or Replacement of Nuclear Power Plant Process Control Instrumentation - DPM N77Al2," January 18, 1983
- 2. SQA-45, Revision 21, " Quality Control of Material and Parts and Services," June 23, 1986
- 3. Administrative Instruction (AI) - 11, Revision 37, " Receipt Inspection, Nonconforming Items. QA Level / Description changes and Substitutions," June 20, 1986
- 4. WBN Plant Response to IN-85-841-001, Memorandum from W. T. Cottle to William H. Thompson, March 10, 1986
- 5. Division Procedure Manual, DPM - N77A12 " Requirements for Repair and/or Replacement of Nuclear Power Plant Process - Control Instrumentation," January 6, 1982
- 6. DPM- N77Al2, Cancellation, September 27, 1985
- 7. Change. Request Form, August 20, 1985 (L65 850823 525) to cancel -
DPM N77A12
- 8. NQAM, Part II, Section 3. " Modifications" Page 3 of 4 c
- l
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. .. i Revision 1'
- VII. Inunediate or Long-Term Corrective Action -
' Concerns were not validated-for SQN, hence no corrective actions are IR1 required. l i
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- ECPSI20J-ECPSI21C TENNESSEE VALLEY AUTHORITY PATE -db3 REFERENCE OFFICE OF NUCLEAR PDHER RUN TIME - Ital
) FREQUENCY - REQUEST ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/t LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30301 DIFFICULTY OF OBTAINING OBSOLETE EQUIPMENT-
)
- KEYWORD A S GENERIC KEYHORD B H APPL QTC/NSRS P CONCERN KEYWORD C CONCERN SUB R PLT BBSH INVESTIGATION S KEYHORD D' CAT CAT D LOC FLQB REPORT R DESCRIPTION
) NUMBER "0LD" PLANT INSTRUMENTATION (PROCURE DESIGN RELATED I: 841-001 OP 3030I N HBN YNYY NS SPECIFICATIONS REPORT- D 10-12 YEARS AGO) IS OFTEN NO LONGE T50084 R MANUFACTURED / SPARE PARTS ARE DIFFI INSTRUMENTATIDI-
) CULT OR NOT POSSIBLE TO OBTAIN. PUR' GENERAL
- CHASE REQUISITIONS FOR UNOBTAINABLE PARTS ARE CANCELLCD, YET COGNIZANT M .
ANAGEMENT (DEPARTMENT KN0HN) HAVE IN p STITUTED NO ALTERNATIVES MEASURES TO OBTAIN SUBSTITUTIONS OF PARTS /REPLA CEMENT ITEMS. THIt '*AS THE POTENTIA L TO ADVERSELY IMPACT PLANT OPERATIO
) NS. CI POSTULATED THIS CONCERN TO B OTH UNITS 1 & 2. MANAGEMENT (NAME K ,
NDHN) IS AHA o
1 CONCERNS FOR CATEGORY OP SUBCATEGORY 30301 !
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IY3 EMPLOYEE CONCERNS REPORT NUMBER: 312.01-SQN *
".'..'t SPECIAL PROGRAN l
REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 1 TITLE: Adequacy of Public Safety Service (PSS)
Officer Uniforms in Nuclear Plant ,
Environment REASON FOR REVISION: Incorporate SRP and TAS Comments Revision 1 l l
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PREPARATION PREPARED BY:
J. L. McVav .
[M 10-20-86 S iATORE . DATE l
- e REVIEWS PEER: / -
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DATE TAS: p RAW f .
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CONCURRENCES l CEG-H: m" 10-2 7 - D
- SRP:\o,e44. . IO*23* E SIGNATURE DATE SIGNATURE
- DATE l APPROVED B -
Yb ECSP MedAGER MNA6 l0-2f-yh DATE N/A MANAGER OF NUCLEAR POWER DATE j
1 CONCURRENCE (FINAL REPORT ONLY) 2116T *SRP Secretary's signature denotes SRP concurrences are in files.
- -- --.---,---.--,n. - . , . _ , _ _ _ _ _ _ _ _ _ _ _ _ __
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERN:: TASK GROUP OPERATIONS CEG Subcategory: Adequacy of Public Safety Service (PSS)
Officer Uniform in Nuclear Plant Environment Report No.: 312.01 SQN,. Revision 1 XX-85-048-001 l
l Evaluator: J. L. McVay 10-20-86 J. L. He ay Date
. Reviewed by: //// //////fes
'6PS CWMpf6bers Da'te
- Approved by: bi - ,- /0-2 t-7(
W. R. Lagefgren Date 1275T
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.. Revision 1 I. Adequacy of Public Safety Officer Uniforms This evaluation centers around the concern that Public Safety Services I (PSS) unifers trousers may attract airborne contamination or contribute IR1 to injury to the wearer ^during the performance of firefighting i activities normally expected of the FSS Officer. l II. Specific Evaluation Methodology This report evaluates one concern, XX-85-048-001, which states that PSS l Officer trousers, (which are made of synthetic materials) pose two lR1
, safety problems. These are:
- 1. Clothing made of synthetic materials does not burn, but melts to a person's skin.
- 2. The trousers build up a great deal of static electricity and will attract airborne contamination in the event of an airborne radiation leak. .
The methodology for this. evaluation addresses four aspects of the concern.
- 1. The validity of the concerr.
- 2. The adequacy of any recommendations resulting from NSRS or line investigation
- 3. Verification of any line response to recommendations f
- 4. Verification of any corrective actions
!- The concern is considered as a closed issue as a result of a line management response dated August 19, 1985. The concern and the
!, associated response were reviewed and some additional background I
information is included for clarity. Physical Security Instruction, PHYSI-13 was also reviewed to determine Public Safety Services responsibilities during fire emergencies.
III. Findings Backrround Information (Airborne Contamination)
When an individual is exposed to airborne contamination, there are two j primary concerns: Internal disposition of radionuclides and/or external radiation exposure from the airborne cloud.
TVA Nuclear Plants are required to monitor radiation areas and to post the area as an " Airborne Contamination Area" whenever the concentration of airborne radionuclides reach 25 percent of the maximum permissible concentration (MPC). Entry into an airborne contamination area is Page 1 of 3 1
(, Revision 1 strictly controlled by a Radiation Work Permit (RWP). All security officers who would have a need to enter an airborne contamination area would be required to wear full C-zone clothing and respiratory protective equipment. General Employee Training which is required for Public Safety Officers who require access to the Power Block, fully -
explains these controls and processes and includes the dress out procedure for removing street clothing and donning protective anti-C clothing. The TVA radiation protection program prohibits wearing street clothing in areas designated and controlled as airborne contamination areas.
General Employee Training also addresses controls inLplace to detect accidental releases of airborne contamination through discussions relating to the purpose of Continuous Air Monitors (CAM), the alarm function of the CAM and instructions to the individual should he/she be in an area when a CAM alarms. The individual is trained to immediately evacuate the area and to call Health Physics (HP) to ensure that any resultant contamination, either internal or external, is detected and the clothing, hair, skin is appropriately decontaminated. Should the Public Safety Officer approach his/her quarterly.MPC limit, which is continually monitored and documented on individual exposure records by MP, then that individual would be prohibited from working in a radiation or regulated area for the remainder of the quarter.
Adequate training and controls are in place at SQN to ensure that airborne contamination attracted to Public Safety Officer uniforms would represent only a small fraction of the radiological hazard to an individual exposed to radioactive gaseous releases even though double-knit trousers may attract airborne contamination more than would, for instance, cotton trousers. Although radioactive noble gases decay to rubidium 88 and cesium 138, which exhibits a high affinity for clothing and hair, these elements have a very short half-life and any l airborne contamination that was attracted to the uniforms in the shor;t lR1 period of time the officer would be in the area after the CAM alarmt, l would decay to nondetectable limits. l l
Background Information (Heat versus Synthetic Material)
Public Safety Officer uniform trousers are made of polyester double-knit materials which are generally recognized as being susceptible to melting and burning at high temperatures. The concern expressed centers around the requirement for Public Safety Officers to assist the ONP fire i brigade in fighting plant fires.
i The plant implementation procedure PHYSI-13 defines the Public Safety Officer role in fighting fires as a support function with actual firefighting to be conducted by plant operators specifically traincd for this function. Public Safety Officers do not have a primary fire brigade membership responsibility and, as a consequence, the use of polyester double-knit trousers as a part of their uniform, should not be a problem related to their firefighting responsibilities.
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, , Revision 1 1
Line Management Investigation Report The line management response dated August 19, 1985, to this concern did !
not find the employee concern to be valid and does not contain any )
recommendations or corrective actions. The report found that: I I (1) PSS officers do not participate in actual firefighting activities; I and (2) low level radiation attracted to uniform trousers decay rapidly IR1 and poses no health threat. The response is adequate. The response I references earlier evaluations done by the Plant Uniform Committee composed of Public Safety Officers and line management which support '
the August 19 1985 report findings. The additional background details l contained in this report was not included in the response, however, line -
management has responded appropriately.
Conclusion This evaluation of concern XX-85-048-001 concurs with the line management report findings. The uniform trousers do not present an unacceptable level of risk to the officers wearing synthetic trousers and the concern is not a valid concern.
IV. Root Cause None .
V. Generic Applicability This element does have a generic applicability for TVA because the Public Safety Officer uniform worn is the same at each Nuclear Generating Plant. However, a site specific evaluation for other TVA Nuclear Plants is not required because site specifics relative to these concerns will not change between plants.
VI. References
- 1. Physical Security Instruction Manual PHYSI-13 Revision 48
- 2. Line Management Investigation Report, August 19, 1985 VII. Proposed Immediate or Long-term Corrective Action None i
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- ECPSI20J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE - 242 REFERENCE RUN TIME - 12:19 FREQUENCY - REQUEST OFFICE OF NUCLEAR P0HER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/05, DNP - ISSS - RHM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORYs 31201 ADEQUACY OF PSO UNIFORM IN NUC PLANT ENVIRONMENT-S GENERIC KEYHORD A H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT , R DESCRIPTION KEYNORD D XX 048-001 OP 31201 N SQN NNYY XX-85-048-001 AT SEQUOYAH, THE UNIFORM TROUSERS HO . SAFETY CONDIT OIN REPORT RN BY TVA PUBLIC SAFETY OFFICERS ARE SAFETY PROGRAM T50073 OPERATIONS MADE OF SYNTHETIC MATERIAL. C/I IS CONCERNED THAT THE UNIFORM TROUSERS CONST MANAGEMEP POSE THE FOLLOHING TH0 SAFETY PROBL EMS: 1) CLOTHING MADE FROM SYNTHETI C MATERIAL DOES NOT BURN BUT MELTS T 0 A PERSON'S SKIN. SINCE FIREFIGHTIN .
- G IS INCLUDED IN PUBLIC SAFETY OFFIC ER'S JOB DUTIES, THE UNIFORM TROUSER S INCREASE THE HAZARDS FACED IN A FI RE SITUATION. 2) BECAUSE THESE TROU SERS BUILD-UP A GREAT DEAL OF STATIC ELECTRICITY HHEN HORN, THE TROU 1 CONCERNS FOR CATEGORY OP SUBCATEGORY 31201 9
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e TVA EMPI4YEE CONCERNS REPORT NUMBER: 313.07-SQN ,
,, SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 1 TITLE: Sequoyah Nuclear Plant (SQN) Insulation ,
REASON FOR REVISION:
Revised to incorporate SRP conunents. Revision 1 PREPARATION PREPARED BY:
R. E. Jones 10/13/86 SIGNATURE DATE
/ REVIEWS PEER:
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SIGNATURE DATE CONCURRENCES CEG-H:hi . c% 4 - 10- # O fl.
SRP: M . 10
- 21 1L SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
$k' ECSP NAWAGER 6 /O-2l*$b DATE n/A MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 2019T SRP Secretary's signature denotes SRP concurrences are in files.
TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Miscellaneous Element: Sequoyah Nuclear Plant (SQN) Insulation Report Number: 313.07-SQN, Revision 1 SQN-85-001-02 Evaluator: [ f/27/fd R.A..Jo s 'Dats Reviewed by: / /////IN f "J d OPSCfM ber Date Approved by: b0' 0 W. R. Lagefghen Y/d/N
~/Date 1195T
l Revision 1 I. SQN Insulation The concern expressed in this element addresses improper insulation )
(fiberglass) inside of containment at SQN.
II. Specific Evaluation Methodology The employee concern identified to Quality Technology Company (QTC) is listed as follows:
SQN-85-001-02 Fiberglass insulation installed inside containment at the bottom of the steam line next to the steam i generator. i Two associated NSRS Reports (References 1 and 2) and all NSRS recommendations were reviewed for adequacy in closing out this concern.
A telephone interview was conducted to ensure that NSRS recommendations were being implemented at SQN and the associated documents referenced in the NSRS report were reviewed to ensure that line management responses
- were adequate to close this concern.
III. Findings Improper Insulation Inside of Containment To reduce the possibility of stress corrosion cracking, NRC Regulatory Guide (RG) 1.36 provides allowable levels for cholorides and fluorides which may be present in nonmetallic thermal insulation installed on stainless steel safety-related systems. Any nonmetallic thermal insulation coming in' contact with austenitic steel pipe must meet the requirements of Regulatory Guide 1.36. Mirror insulation contains no cholorides er fluorides and meets these requirements.
Nonconformance Report (NCR) SQN MEB 8411, written November 27, 1984, l documented the existence of foam plastic insulation on small (< 2") l l stainless steel piping for essential raw cooling water (ERCW) and ice i condenser systems. The foam plastic insulation did not meet the l requirements of RG 1.36 but the NCR evaluation stated that no corrective l action was required because: l lR1
" Discussions with MEB core personnel have concluded that chances of l intergranular stress corrosion cracking of stainless steel piping is l
- significantly reduced at low operating temperatures (< 140 degrees F). l Both the ERCW (design temperature = 130 degrees F) and ice condenser l (design temperature < 32 degrees F) systems have operating temperatures l 1ess than 140 degrees F. For this reason, it is recommended that the l subject insulation be used as is." l l
Page 1 of 4
Revision 1 NSRS Investigation Report I-85-106-SQN (Sept. 25-Oct. 8, 1985) addressed the use of fiberglass insulation and other nonmetallic types of insulation on stainless steel safety-related piping in violations of RG 1.36 (not limited to the specific location of concern SQN-85-001-02).
NSRS research substantiated the concern because SQN could not document that nonmetallic insulation installed on stainless steel safety-related systems met the requirements of RG 1.36; SQN took corrective actions to: 1) revise purchasing requiremer.ts and receipt inspections to ensure that all nonmetallic insulation meet the requirements of RG 1.36;
- 2) ensure that all insulation in Power Stores meets the requirements of RG 1.36; 3) ensure that nonmetallic insulation is purchased with a certificate of conformance and satisfactory RG 1.36 test results; and
- 4) ensure that all insulation on safety-related systems meets the requirements of RG 1.36. These corrective actions are documented in a memorandum to SQN Plant Compliance dated May 1, 1986, (reference 3).
In response to Concern SQN-85-031-02 (December 1985 timeframe) NSRS Investigation Report SQN-85-001-02 (Reference 1) addressed the specific concern of fiberglass insulation inside the SQN containment at the bottom of the steam line next to the steam generator. An inspection by NSRS and Plant Metallurgical Engineering personnel found only metallic mirror insulation on the steam lines inside of containment.
Conclusion Employee Concern SQN-85-001-02 (D'cember e 1985 timeframe) was not R1 validated. Before this concern, NCR SQN MED 8411 (November 27, 1984) and NSRS Investigation I-85-106-SQN (September 25 - October 8, 1985) addressed the use of nonmetallic thermal insulation on austentic stainless steel systems.
NCR SQN MEB 8411 confirmed the use of foam plastic insulation on small R1 stainless steel piping. This use was not in the area of the subject concern. However, the engineering analysis determined that this instance had no sdverse effects to safety systems and recommended that the insulation be used "As Is."
NSRS Invest.*gation Report I-85-106-SQN fcund that SQN could not document R1 that nonmetaille insulation used on stainless steel safety-related systems met the requirements of RG 1.36. Reference 3 documented that the following NSRS recommended action have been completed:
- 1. A random sample of installed insulation at SQN and all insulation in Power Stores was tested by the Site Chemical Engineering Unit and Singleton Laboratories to determine if the materials meet the requirements of Regulatory Guide 1.36. The tests were conducted in accordance with ASTM C 692 and Singleton Lab Test Procedure SME-CORL-3. Acceptance criteria and test results are documented in attachment 1 to reference 3 to this report. Test results revealed that the insulation meets specifications required by Regulatory Guide 1.36.
Page 2 of 4
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Revision 1
- 2. Procedure SQM-35 (reference 5) was revised May 21, 1986, to specify that all nonmetallic insulation be tested to RG 1.36 and that the appropriate certification of conformance be required from the supplier for all future purchase orders for insulation materials.
- 3. QA and Power Stores has assigned a QA level to insulation materials to provide for traceability and to ensure proper receipt inspection and storage requirements upon receipt of the materials.
Concern SQN-85-001-02 addresses a problem in December 1985 (after NCR SQN MED 8411 and NSRS Investigation Report I-85-106-SQN), with fiberglass insulation at the bottom of each steam line next to the steam generator. NSRS Investigation Report SQN-85-001-02 found that there was mirror insulation at this location, NSRS Investigation Report I-85-106-SQN recommendations were being implemented, and the concern was not validated.
At the time of Concern SQN-85-001-002, NCR SQN MEB 8411 and NSRS Investigation Report I-85-106-SQN had adequately addressed the issue of nonmetallic thermal insulation on austenitic stainless steel system.
This evaluation concurs with NSRS Investigation Report SQN-85-001-02 that the concern was not validated and that the subject of nonmetallic thermal insulation on austenitic stainless steel was adequately addressed in NSRS Investigation Report I-85-106-SQN.
IV. Root Cause No root cause was identified since problems with insulation were recognized and corrected by TVA independent of the concern.
V. Generic Applicability The concern is considered to be generic to Browns Ferry, Watts Bar, and Bellefonte Nuclear Plants based on this reports findings because documentation for insulation testing or procurement actions at these facilities for materials installed prior to 1986 has not been evaluated.
VI. References
- 1. NSRS Investigation Report SQN-85-001-02, " Fiberglass Insulation Inside Containment," February 12 - 20, 1986
- 2. NSRS Investigation Report I-85-106-SQN, "Nonmetallie Thermal / Insulation on Austenitic Stainless Steel Systems,"
September 25 - October 8, 1985 Page 3 of 4
Revision 1 VI. References (continJed)
- 3. Memorandum from D. F. Goetcheus to G. B. Kirk dated May 2, 1986, "Sequoyah Nuclear Plant - Test Results from Nonmetallic Thermal Insulation Used on CSSC Stainless Steel Piping - CATS Nos. 86012, 86013, and 86025" (S01 860502 922)
- 4. NCR SQN MEB 8411. "Use of Unqualified Insulation," dated November 27, 1984
- 5. SQN Standard Practice SQM 35, Revision 1
- 6. NRC Regulatory Guide 1.36, " Nonmetallic Thermal Insulation For Austenitic Stainless Steel," February 23, 1973 VII. Immediate or Long-Term Corrective Action None. The concern was not valid and recommendations of NSRS R1 Investigation Report I-85-106-SQN have been completed. No further actions are required.
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TENNESSEE VALLEY AUTHORITY PAGE 1 *b REFERENCE - ECPS120J-ECPS121C RUNTIME**2 12i 9 FREQUENCY - REQUEST OFFICE OF HUCLEAR P0HER RUN DATE - 10/;
ONP - ISSS - RHM EMPLnYEE CONCERN PROGRAM SYSTEM (ECPS)
LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 51307 SQN INSULATION
! ) -
KEYHORD A -
S GENERIC H APPL GTC/NSRS P KEYNORD B~
SUB R PLT BBSW INVESTIGATION S CONCERN KEYHORD C CONCERN KEYHORD D .
) NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION l
SQN-85-001-002 OP 31307 N SQN YYYY SS THERE IS FIBERGLASS INSULATION AT TH K-FORM E BOTTOM OF EACH STEAM LINE NEXT TO THE STEAM GENERATOR. CI HAS BEEN TO
). LD THAT THERE SHOULD BE NO INSULATIO N OTHER THAN MIRROR INSIDE CONTAINME NT. DECEMBER 1985 TIMEFRAME.
)
1 CONCERNS FOR CATEGORY OP SUBCATEGORY 31507' i
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- ** TVA EMPLOYEE CONCERNS REPORT NUMBER: 313.04-SQN
., SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 0 I l
l TITLE: Environmental l REASON FOR REVISION:
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PREPARATION PREPARED BY:
Willie Mills 10/13/86 SIGNATURE DATE
/ REVIEWS PEER: /
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/ [ SIGNATURE TAS*
PAW i ' l$ 0 _
SIGNATURE DATE CONCURRENCES CEG-H: d, a- 10- 44-?b SRP: w 1 i D 21 '8(.
SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
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ECSP MANAGER
- fj b /O*'E/$h DATE N/A MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG I Subcategory: Miscellaneous Element: Environmental Report Number: 313.04-SQN RII-86-A-OO22 RII-86-A-0100 1
(
l Evaluator: Willie Mills , 10/13/86
} Wil ie M ls Date Reviewed by: [ 8 84 [ // ((
! ' OPS CE e'ger 'Date Approved by: - . w& /dh4M
[ W. R. Lagdef ren (Date l
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I. ENVIRONMENTAL This evaluation report addressas employee concerns RII-86-A-0100 and RII-86-A-0322. The scope of this report is limited to the evaluation of the possible violations of nonradiological controls and environmental protection.
II. SPECIFIC EVALUATION METHODOLOGY The concerns, as stated on the K-Forms, read as follows:
RII-86-A-0022 Sequoyah specific - An anonymous alleger stated that over the past year (since about January 1085) the piping for routing the raw -
water from the Turbine Building sump at Sequoyah has had a large leak to
~
the open ground when the Turbine Building sump pumps operate.
RII-86-A-0100 Sequoyah specific - The alleger stated that during 1974 and 1975, toxic chemicals were buried on site in a pit. This chemical was a jelly-like substance useJ to finish concrete. Truckloads of the chemical were dumped into the pit. On one occasion, the materials were in cardboard boxes and plastic trach bags which were dumped into the pit. Also, another environmental concern was expressed by the alleger related to the use in 1983 of fuel oil to burn wood left over from the
- construction of the cooling towers.
These allegation are specific to Sequoyah but may have application to other TVA nuclear facilities.
This evaluation reviewed the K-Forms, Rules of Tennessee Department of Health and Environment, Chapter 1200-1-11, " Hazardous Waste Management,"
Technical Instruction (TI), ERT Investigation Report, Hazardous Control Instruction (HCI), Construction Policy Manual, Environmental Protection Manual and Design Change Request. These reviews were conducted to ensure regulatory requirements relating to nonradiological controls and environmental protection are implemented properly at Sequoyah Nuclear Plant.
Interviews were conducted with personnel from the Environmental Section, Chemical Section, Mechanical Maintenance, Planning and Scheduling Section and Operation Section. Also, interviewed representives from the Environmental Protection Agency (EPA) and Air Pollution Bureau.
III. FINDINGS A. The CI was concerned that the piping for routing raw water from Turbine Building sump because it has a large leak to the open ground.
From a physical observance of the pipe, there is a leak to the open ground. Sequoyah maintenance section is aware of this problem and initiated a DCR 2243 (Reference 11) to replace sump discharge piping and valves from the Turbine Building to the point where water is discharged to the ponds and river. This maintenance activity will start af ter the outage, according to Phil R. Wallace, Plant Manager.
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A temporary trench was constructed below the pipe where the water from the leaking pipe would flow to the low volume pond and then discharge to the river. Before the discharge of effluents from the low volume pond to the river, samples are taken,to ensure ccmpliance with the National Pollutant Discharge Elimination System (NPDES) permit.
TI-64 (Reference 10) is the plant instruction that implements the National Pollutant Discharge Elimination System (NPDES) permit.
Within this instruction, the responsibility of the chemical section to monitor discharge points for the selected NPDES parameters is identified. The instruction that the chemical section monitor selected discharge points are SI-460.1, SI-460.2, SI-461, SI-462, SI-463, SI-465 and SI-466.1 (Reference 3, 4, 5, 6, 7, 8, and 9.
respectively). If an NPDES parameter as noted in any SI mentioned previously exceeds its limits, the chemical engineering staff will investigate to determine the cause and possible solution. When a violation has occurred (non-compliance), the lead shift chemist shall report to the shif t engineer who in turn will notify the operations duty specialist. A written follow-up report will be submitted with the weekly NPDES data reports in accordance with A!-18, file package 53 (Reference 1).
A review of file package 53 (Reference 20) was conducted to identify any non-conformance associated with the leaking pipe. There were not any non-conformance reports associated with the leaking pipe. ,
B. The CI was concerned about a toxic chemical being buried in a pit on
. site.
The jelly-like substance that was mentioned by the concern individual was buried in a pit on site. From ar informal interview with C. Cole of Haliburton, this jelly-like' substance is called acrylamide which is composed of grouting powder and a catalyst "T", "SP" or "AP." The, grouting powder is a toxic chemical but when combined or mixed with r one of the catalysts, it becomes a jelly-like substance. Burying this . substance in an approved sanitary landfill complies with SQA 126 (Reference 13).
From the interviews, in the years of 1974 and 1975, there were no federal regulations or state requirements on the disposal of hazardous material in a landfill. The Hazardous Waste Act which control the disposal of hazardous waste came ir.to effect in 1977.
Before 1981, the state of Tennessee did not have a. document to implement this act. Since there were no federal or state regulations in 1974 and 1975 on the disposal of hazardous materials in a landfill, Sequoyah was not required to record or report any burial of a toxic chemical in an approved landfill. The state document that applies to Sequoyah today for the disposal of hazardous material is Chapter 1200-1-11 (Reference 16).
C. The CI was concerned about the use of fuel oil to burn wood left over from construction.
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The use of fuel oil to burn wood left over from construction is in accordance with the Hamilton County Air Pollution Control Regulation (Reference 19). Open burning of vegetation and wood materials has to be approved by the Director of Hamilton County Air Pollution Bureau provided the following conditions are met:
- a. An application shall be submitted to the director giving the reasons why no other method of disposal can be employed, amount .
of material to be burned and locatio,of material to be burned.
- b. A fee of $10.00 shall be included with the application, which fee shall be collected by the bureau and remitted to Chattanooga City Treasure. '
- c. No burning shall occur until such inspection of the material as may be required by the bureau is conducted.
- d. Burning shall be conducted only on days of low pollution potential, as determined by the Bureau, and only between the hours of 9:00 a.m. and 4:00 p.m. on such days.
- e. Only clean fuel not containing garbage, rubber, plastics, roofing materials, tar paper or other refuse shall be allowed for the start-up of fires.
- f. Written approval is received from the director.
SQA 120 (Reference 17) instruction outlines the prerequisites, procedures, permits, and reporting requirements for all open burning conducted in areas under Nuclear Power Jurisdictions at Sequoyah Nuclear Plant. The Construction Policy Manual, Instruction K (Reference 18) provides guidance for construction in controlling air quality impacts from open burning in accordance with local, state and federal regulations. From an interview with the local representative in the Hamilton County Air Pollution Bureau, TVA has not violated any regulations set by the state for open burning.
D. Conclusion Those findings for the leaking pipe indicate that there is no danger to the environment as long as TVA follows the procedure that were mentioned in the findings. SI-460.1, SI-460.2, SI-461, SI-462, SI-463, SI-465 and SI-466.1 are the instructions used for the report in AI-18 File Package No. 53 to nonitor selected discharge points for the selected NPDES parameters. Attachment A of Part A of AI-18 File Package No. 53, will be completed and attached to the weekly report for any and all non-complaince conditions. From the review of the NPDES non-compliance report form (Reference 20), there were no non-compliance associated with the leaking pipe. For the above reason this concern is determined to be valid on the grounds that the pipe does need to be repaired but not valid as far as an environmental problem.
These findings for the burial of a jelly- like substance called acrylamide indicates that there were no violations committed at the time the substance was buried. Since the substance was in the i jelly-like form at the time of burial, it is considered to not be Page 3 of 5 l
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detrimental to the environment. To bury this substance in an approved landfill complies with the Hazardous Waste Act of 1977.
Since the time the Hazardous Waste Act and the state regulation on Hazardous Waste Management was in effect, TVA has complied through plant procedure, all the requirements necessary to manage hazardous waste. For the above reasons this concern is determined to be not valid.
These findings for the use of fuel oil to burn wood indicate that no procedure was violated. The Hamilton County Air Pollution Bureau allows the use of clean fuel oil for the start-up of fires. For the above reasons, this concern is determined to be not valid.
Based on the findings presented above, there are no nuclear safety-related issues.
IV. ROOT CAUSE None V. GENERIC APPLICABILITY
- Since the concerns were not valid at SQN, they are not considered generically applicable to other sites.
VI. REFERENCES
- 1. AI Plant Reporting Requirements, Appendix A File Package No. 53, Revision 42
- 2. SI-460 - Daily - NPDES Liquid Effluent Monitoring Requirements, Revision 12
- 3. SI-460.1 - Daily - NPDES Monitoring, Revision 3 l
l
- 4. SI-460.2 - 5/ Week - NPDES Monitoring, Revision 7
- 5. SI-461 - TRI-Weekly - NPDES Monitoring, Revision 16
- 6. SI-462 - Twice Per Week - NPDES Monitoring, Revision 15
, 7. SI-463 - Weekly NPDES Monitoring, Revision 11 l
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- 8. SI-465 - Radwaste System Weekly Release NPDES Monitoring, Revision 13
- 9. SI-466.1 - Condensate Demineralizer Waste NPDES Monitoring, Revision 8
- 10. TI Implementation of NPDES Permit, Revision 6 l
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- 11. Design Change Request No. SQ-DCR-2243, February 27, 1985
- 12. RM-0800 - Environmental Protection Manual, September 16, 1985
- 13. SQA 126 - Liquid Solid and Hazardous Waste Management, Revision 5
- 14. ERT Investigation Report XX-85-031-001
- 15. Resource Conservation and Recovery Act of 1976, PL 94-580, October 21, 1976
- 16. Tennessee Department of Health and Environment Rule 1200-1-11-Hazardous Waste Management
- 17. SQA 120 - Open Burning Requirements, Revision 1
- 18. Construction Policy Manual, Instruction K - Open Burning and Fugitive Dust Control, September 1, 1983
- 19. The Hamilton County Air Pollution Control Regulation (as amended)
Rule 6 . Prohibition of Open Burning
- 20. File Package No. 53, Attachment A:
Permit No. Sequence No.
TN0026450 85-NC-44-103-11 TN0026450 85-NC-4G-103-12 TN0026450 85-NC-20-103-1 TNOO26450 85-NC-21-103-2 TN0026450 85-NC-22-103-3 TNOO26450 85-NC-23-103-4 TN0026450 85-NC-34-103-5 TN0026450 85-NC-35-102-2 TN0026450 85-NC-37-103-6 TN0026450 85-NC-39-103-7 TN0026450 85-NC-40-103-8 TN0026450 85-NC-41-103-9 TN0026450 85-NC-42-103-10 VII. IMMEDIATE AND LONG-TERM CORRECTIVE ACTION No corrective actions are necessary.
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PAGE S
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY
)
REFERENCE FREQUENCY - REQUEST OFFICE OF NUCLEAR P0HER RUN TIME M 12:1 DNP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/('
LIST OF EMPLOYEE CONCERN INFORMATION
- CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31304 ENVIRONMENTAL
) KEYHORD A S GENERIC -
H APPL- QTC/NSRS P KEYHORD B SUB R PLT BBSH INVESTIGATION 'S CONCERN KEYHORD C CONCERN KEYNORD D-i NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION RII-86-A-0022 OP 31304 N SQN AN ANONYMOUS ALLEGER STATED THAT OVE K-FORM R THE PAST YEAR (SINCE ABOUT JANUARY
)
1985) THE PIPING FOR ROUTING THE RA H HATER FROM THE TURBINE BUILDING SU MP AT.SEQUOYAH HAS HAD A LARGE LEAK TO THE OPEN GROUND HHEN THE TURBINE I BUILDING SUMP PUMPS OPERATE. THIS M ATTER APPLIES TO SEQUOYAH ONLY.
RII-86-A-0100 OP 31304 N SQN THE ALLEGER STATED THAT DURING 1974 K-FORM OR 1975, T0XIC CHEMICALS HERE BURIED
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ON SITE IN A PIT. THIS CHEMICAL HA S A JELLY-LIKE SUBSTANCE USED TO FIN ISH CONCRETE. TRUCK LOADS OF THE CH p EMICAL HERE DUMPED INTO THE PIT. ON ONE OCCASION, THE MATERIALS HERE IN CARDBOARD BOXES AND PLASTIC TRASH B AGS HHICH HERE DUMPED INTO THE PIT.
ALSD, ANOTHER ENVIRONMENTAL CONCERN
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HAS EXPRESSED BY THE ALLEGER RELATE D TO THE USE OF FUEL OIL TO BURN H00 D LEFT OVER FROM THE CONSTRUCTION OF
) THE COOLING T0HERS.
2 CONCERNS FOR CATEGORY OP SUBCATEGORY 31304 I
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.- TVA EMPLOYEE CONCE.IS REPORT NUMBER: 313.03-SQN ,
. SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Elernent REVISION NUMBER: 0 TITLE: Housekeeping REASON FOR REVISION:
PREPARATION PREPARED BY:
J. S. Manuel 10/13/86 SIGNATURE DATE REVIEWS
)
PEER:
% d 716 [ L SIGNATURE 8/h/Tl I DATE~
ia (TMAw / SIGNATURE kWsDATE CONCURRENCES CEG-H: i . %,s 10-N - fd SRP: aett.A. . /O* 2I *8b SIGNATURE DATE DATE G SIGNATURE
- APPROVED BY:
k! >8 JO-2l-8(9 N/A ECSP MAWAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 2019T SRP Secretary's signature denotes SRP concurrences are in files.
1-TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG 4
Subcategory: Miscellaneous Element: Housekeeping Report Number: 313.03 - SQN SQM-6-001-001 l
Evaluator: W Y l
J. S. Manuel 'Dat'e Reviewed by: .[__bfI A h /i
- l. ODSCEGGember Date Approved by:
/ W. R. Lagergren 'Date i
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-I. Housekeeping This element report addresses Employee Concern SQM-6-001-001 which is specific to SQN, and which was closed out by way of SQN investigation
- attached to memorandum from H. L. Abercrombie to W. H. Thompson dated February 28, 1986.
II. Specific Evaluation Methodology The following employee concern was investigated.
SQM-6-OO1-001 - CI feels the vacuum cleaners are too big to properly clean in-small areas and are too heavy to maneuver easily or quickly therefore losing time to do the job.
The evaluation of this concern and associated SQN investigative response will concentrate on four aspects:
- 1. The validity of the concern.
- 2. The adequacy of the SQN evaluation report and the recommendations
- - contained therein.
- 3. Verification of corrective action taken by line management.
- 4. The adequacy of corrective action to resolve the concern and prevent recurrence.
Appropriate regulatory requirements and -SQN specific procedures were reviewed to ensure programmatic compliance for housekeeping at SQN.
III. Findings A. SQN Evaluation Results
- 1. Building Services has several different types and sizes of vacuum cleaners that are available for different jobs. There are twelve vacuum cleaners that are equipped with high efficiency particulate absolute (HEPA) filters for use in regulated areas, six of which were new at the start of unit 1, cycle 3 outage in August 1985. These vacuum cleaners weigh approximately 50 pounds and have 5-gallon holding cans and are equipped with castors.
- 2. There are also four backpack vacuum cleaners with HEPA filters for use in regulated areas, weighing approximately 25 pounds each. They are issued from the toolroom for work in small and congested areas. Lightweight vacuum hoses are available for use in areas that are congested and hard to get to.
Page 1 of 3
- a. . 3. Building Services also has a large number of other types of vacuum cleaners for use outside C-zone areas, including the l 55-gallon Black & Decker type. There is a sufficient amount of vacuum cleaners for office and carpet areas.
B. SQN Recommendations In the investigation, it was found that there is another smaller vacuum cleaner with a HEPA filter available that is believed to be very effective and popular. Arrangements are being made to purchase this type of vacuum cleaner.
Justification The SQN investigation has identified two types of vacuum cleaners with HEPA filters. The four smaller vacuum cleaners must be checked out from the tool room. The Building Services Supervisor indicated that perhaps the CI was unaware of this alternative. He also said that at times, all four are checked out for long periods of time.
So he agreed that additional small vacuum cleaners would be a good idea.
C. Verification of Corrective Action The Building Services Supervisor initiated a Purchase Request (PR)
- on February 24, 1986. He ordered four 4-gallon, 22-1/2-pound vacuum cleaners with HEPA filters. The request was approved, authorized, and assigned a "date wanted" of April 30, 1986. This original PR became lost in the system and the Building Services Supervisor
. issued a second PR on May 21, 1986, to expedite the purchase.
D. Conclusion
- 1. Based on the findings, there was an adequate closeout of this item. The concern was substantiated and corrective action is adequate.
- 2. This concern is one of those which falls into the employee suggestion category and is a case of applying practical common sense to provide the best available tool so that the employee can do the job correctly and efficiently. Plant supervision has responded to the employee and SQN management in the appropriate manner.
- 3. This item is not safety-related.
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. . l IV. Root Cause As a result of this investigation, it was determined that no root cause exicts for this concern.
V. Generic Applicability This concern represented an isolated incident at SQN. It does not have any generic applicability to other TVA plants.
VI. References A. Memorandum from H. L. Abercrombie to William H. Thompson, " Employee Concern Program - SQM-6-001-001," data February 28, 1986, and attachment, "Sequoyah Investigation /Evlaution of the NSRS Referred Employee Concern Number SQM-6-001-001," by P. R. Wallace B. Purchase Requisition (PR) 86PSA-37573, February 24, 1986 C. PR 86-1352, May 21, 1986 VII. Immediate and Long-Term Corrective Actions There is no immediate or long-term corrective action to be taken since the conclusion states that plant response has been satisfactory.
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REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTNORITY PAGE .-
- REQUEST OFFICE OF HUCLEAR POWER RUN TIME'< 12 -
- O FREQUENCY ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE -'10 -
LIST OF EMPLOYEE CONCERN INFORMATION ..
CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31303 HOUSEKEEPING '
i O S GENERIC KEYWORD A H APPL QTC/NSRS P KEYHORD R CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C CAT D LOC FL4B REPORT R DESCRIPTION KEYNORD D lQ NUMBER CAT SQM-86-001-001 OP 31303 N SQN CI FEELS THE VACUUM CLEANERS ARE T00 PERSONNEL FEELING T50240 K-FORM BIG TO PROPERLY CLEAN IN SMALL AREA FLUSHING S.AND ARE T00 HEAVY TO MANEUVER EASI GENERAL.
IQ LY OR QUICKLY THEREFORE LOSING TIME HOUSEKEEPIN 4
TO DO THE J08. NUCLEAR P0llER CONCER N. CI HAS NO FURTHER INFORMATION. N O FOLLOH UP REQUIRED.
O
, 1 CONCERNS FOR CATEGORY OP SUBCATEGORY 31303 io iO jo
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TVA EMPLOYEE CONCERNS- REPORT NUMBER: 313.02-SQN e SPECIAL PROGRAN 2EPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 0 TITLE: Personnel Safety (Hardware)
REASON FOR 5thVISION:
PREPARATION PREPARED BY:
J. S. Manuel 10/16/86 SIGNATURE DATE REVIEWS PEER:
6 .t NYt9n /0/W8d_
S$GNATURE ' DATE
N '7hf/#amd SIGNATURE s4hrDATE CONCURRENCES l
CEG-H: Ci . 3- fo[ld(([
SRP: \ w b. le /11 f 36 SIGNATURE DATE DATE Q SIGNATURE *
, APPROVED BY:
/0 /D"f/~85 N/A ECSP MANkUER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
I SRP Secretary's signature denotes SRP concurrences are in files.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Miscellaneous Element: Personnel Safety (Hardware) 313.02 Report Number: 313.02 - SQN RfM-85-OO1 RMM-85-OO2 Evaluator: /!M // / / / ////f*I5"A J.S./iapel 'Date Reviewed by: k.d .Nfl % /6/M [
PS dEG Memder T)ath Approved by: [a . %3- /#[Ed/88
'W. R. Lagek ken ' Da t'e 1536T
I. . Personnel Safety ~(Hardware)
This element report addresses employee concerns RMM-85-OO1 and RMM-85-002 which are specific to SQN and which were closed out via CI's supervisory and maintenance department actions and changes.
II. Specific Evaluation Methodology The following employee concerns were investigated:
RMM-85-001 - Lights out in stairwell in Office & Power Stores (0&PS) Building. ,
RMM-85-OO2 - Light out again in stairwell in O&PS Building. PM program needed.
The evaluation of the above concerns and the associated line management responses to the concerns will concentrate on four aspects:
- 1. The validity of the concern
- 2. Verification of the line response
. 3. Verification of corrective action taken by line management
- 4. The adequacy of corrective action to rerolve the concern and prevent its recurrence Appropriate Regulatory requirements and SQN's specific procedures were reviewed to ensure programmatic compliance for preventative maintenance at SQN.
III. Findings A. Line Response to Concerns
- 1. On the same day as RMM-85-001 was filed (8/14/85), MR-A-116723 was written to repair the lights. The lighting was repaired the following day.
- 2. Five days after the lighting was repaired (8/20/85), the concerned individual was informed of the same.
- 3. One month later (9/17/85) at the safety meeting, a member of the Plant Manager's Staff reminded employees to know the hazards and to be careful. On the same day, the same CI reported, via RMM-85-002, the lights were out again. The CI also requested a check on a Preventative Maintenance (PM) program for lighting.
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- 4. The following day (9/18/85) a SQN electrical maintenance en.ployee was interviewed. There it was determined that the O&PS Building's south stairwell lights were not in a PM program, and that the Electrical Maintenance Group would not be responsible for the office building maintenance af ter October 1, 1985. The interviewer was then referred to a third person (a different department, no department name was mentioned) who said they had not gotten word that they were to be responsible for building maintenance yet so they could not say what kind of program they would have. They would call the interviewer when they get the official word and tell the interviewer what kind of preventative maintenance program they would have.
- 5. Two months later (11/19/85), the new general building maintenance unit responded that they were now responsible for building lighting. To report lights out or general building maintenance call extension 7160 or leave a note at the office located in O&PS-1 south end. The same day, the CI was given a form TVA 45 containing this resolution.
B. Corrective Action
- 1. When the first concern (RMM-85-001) was filed (8/14/85),
. Maintenance Request (MR) A-116723 was written to repair the lights. The lights were reportedly fixed the next day.
However, this investigator was unable to obtain a copy of the MR. A computer search failed to turn up the MR.
- 2. When the second concern (RMM-95-002) was filed (9/17/85), no MR was written. The lights were later repaired. No documentation could be located to substantiate the repair work.
- 3. The supervisor of the new maintenance unit for O&PS could not locate a copy of MR A-116723. He also indicated that under their present operating situation, most of their work is phoned in by other employees. The resulting corrective action is then performed without any paperwork. Only on rare occasions does an item come in on paper. He went on to say that a problem like the lights being out in the stairwell would be handled within a day. It would involve dispatching maintenance personnel to correct the problem. No paperwork would be created to document the action.
- 4. The maintenance supervisor stated that under the new maintenance units's program, a problem could be voiced either in person or by calling extension 7160. Their office is located in the O&PS which makes for very good responsiveness.
Page 2 of 3
C. Conclusions
- 1. Both concerns have been validated by line management.
Corrective action was implemented and the problems have been completely corrected. The resulting new maintenance unit will be capable of responding to similar concerns, even if they do not discover the problem themselves.
- 2. There are no regulatory requirements to govern this situation.
These concerns are not safety-significant or safety-related.
This element can therefore be considered closed.
- 3. Stairwell lighting is an important personnel safety concern which has been validated at SQN. Although backup lights are available during a power outage, the loss of individual lighting could result in personal injury. As mentioned in the Institute of Nuclear Power Operations (INPO) Good Practice MA-307, a good FM program should be an evolutionary process. It should start with the scheduling of routine tasks to be accomplished (based on vendor recommendations, past experience, etc.) and then revised as additional operational experience is gained.
Although guidelines on the preparation of PM instructions are only mandatory for all safety-related instruction (including 10 CFR 50.49 scope equipment), they should also be followed in the preparation of nonsafety-related maintenance instructions when applicable.
IV. Root Cause Based on the evaluation it appears that SQN is responsive to corrective action needs when identified by employees thus no root cause determination has been made.
V. Generic Applicability Based on report findings these two concerns were isolated incidents at SQN. There is no reason to consider these concerns as generically applicable to other TVA nuclear plants.
VI. References A. Institute of Nuclear Power Operations (INPO) Good Practice MA-307, Preventative Maintenance, INPO 85-032, September 1985
- 8. 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants" VII. Immediate or Long-Term Corrective Action No additional corrective actions are necessary.
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TENNESSEE VALLEY AUTHORITY
-247; REFERENCE - ECPS120J-ECPS121C OFFICE OF NUCLEAR P0HER PATE RUN TI *AE - '
) FREQUENCY - REQUEST RUN DATE.- 10/4 DNP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
LIST OF EMPLOYEE CONCERN INFORMATION
- CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31302 PERSONNEL SAFETY (HARDHARE)
KEYHORD A S GENERIC KEYHORD B H APPL QTC/NSRS P KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD D CAT CAT D LOC FLQB REPORT R DESCRIPTION
) NUMBER OP 31302 N SQN NNNN LIGHTS OUT IN STAIRHELL IN O & PS BU RMM-85-001 ILDING.
K-FORM
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RMM-85-002 OP 31302 N SQN NNNN LIGHTS OUT AGAIN IN STAIRNELL IN O 1 K-FORM PS BUILDING. PM PROGRAM NEEDED
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) 2 CONCERNS FOR CATEGORY OP SUBCATEGORY 31302
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- ' t TVA EMPLOYEE CONCERNS REPORT NUMBER: 302.06-SQN
?* SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant-Element REVISION NUMBER: 1 TITLE: Transfer Canal Electrical Equipment Problem REASON FOR REVISION: Revised to incorporate SRP comments Revision 1 PREPARATION PREPARED BY:
> b5- N Vh
/ 'dfIGNATURE DATK
/ REVIEWS PEER:
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SIGNATURE DATE CONCURRENCES CEG-H: i c+ a - 10-t 4-?l, SRP: W N. 16218(,,
SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
M00&As ' H'*8 to 2/-B(D N/A ECsP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
SRP Secratary's signature denotes SRP concurrences are in files.
2019T
e' TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Cable and Conduit Element: Transfer Canal Electrical Equipment Problem Report Number: 302.06 - SQN Revision 1 SQP-5-004-002 SQP-6-011-001 Evaluator: vNW , /0 J/fd Ben Meer , 76. Date Reviewed by: /OPS
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I. ' Transfer Canal Electrical Equipment Problem This report evaluates the concern that the electrical equipment in the fuel transfer canal is not installed according to the drawings and the concern that the same electrical equipment was tested using inadequate ;
"Information Only" drawings.
The scope of this report is limited to the evaluation of electrical equipment presently found in the fuel transfer canal and used in the process of fuel transfer.
II. Specific Evaluation Methodology This element is made up of two K-forms:
"SQP-5-004-002 - The configuration of the electrical equipment in the Transfer Canal is not par the drawing. Details known to QTC and withheld to maintain confidentiality.
Nuclear Power concern. No further information may be released. CI has no further information."
"SQP-6-Oll-001 - The fuel transfer system was upgraded from non-QA to a QA Level II; however, there are no "as constructed" drawings. Nuclear Power concern. CI has no further information."
The K-forms were reviewed to determine the area of concern. The referenced documents were reviewed to determine the requirements and testing conditions of the electrical equipment presently located in the transfer canal. The Engineering Change Notice (ECN) authorizing the equipment modification and the testing workplan were reviewed. .
Interviews were held with cognizant engineers in SQN Systems
- Engineering to evaluate the testing history of the equipment in question. It was not necessary to review any " upper tier" documents, l work requests, regulatory requirements, or NCRs.
I III. Findings Following initial construction, the electrical equipment in the transfer canal was tested by Preoperational tests W-7.2B Unit 1 and W-7.2B Unit 2 (References 1 and 2).
The equipment tested by these Preoperational Tests was subsequently l replaced with the presently existing equipment. This was done by authority of ECN L5867 R0 (Reference 3). Following the modification, the new equipment including the electrical equipment now in question was tested by Pcst Modifications Test (PMT) - 48. This was done by Workplan 10736 for Unit 1 (Reference 4) and by Workplan 11177 for Unit 2 (Reference 5). Cognizant engineers in SQN Systems Engineering stated that the only electrical equipment now in the transfer canal is one limit switch per unit and that they were satisfactorily tested and conformed to the drawings. The cognizant engineers also stated that "Information Only" drawings which had been verified correct by Page 1 of 2 L
III. Findings (Continued) comparison with the drawings used for installation were used for testing. This procedure is necessary because only one official drawing (or set of drawings) is used in the installation Workplan.
If changes are made during installation (authorized only by approved changes), they are noted, in ink, on the installation Workplan copies and transfered later to the PMT copy - this eliminates any drawing differences and the PMT drawings are effectively "As Constructed" copies. The installation Workplan must be complete before any testing is started. This assures that the drawings will not be further changed as a result of the installation Workplan.
Administravtive Instruction AI-19 provides for "As Constructing" l drawings following modification by work plan. (Reference 6) lR1
Conclusions:
No problems were identified concerning the testing of the electrical equipment now located in the transfer canal. The concern probably was expressed because of lack of knowledge of the details of Workplan procedure and Post Modification Testing procedure.
The concerns SQP-5-004-002 and SQP-6-011-001 are determined to be not valid.
IV. Root Cause None V. Generic Applicability ho generic applicability could be identified. lR1 VI. References
- 1. SQN Preoperational Test Data Package W-7.2B for Unit 1
- 2. SQN Preoperational Test Data Package W-7.2B for Unit 2
- 4. Post Modificatione Test 84, Workplan 10736 for Unit 1
- 5. Post Modifications Test 84, Workplan 11177 for Unit 2
- 6. SQN Administrative Instruction AI-19, Part IV, " Plant l Modifications: After Licensing," Revision 18, dated lR1 July 7, 1986. I VII. Immediate or Long Term Corrective Action None Page 2 of 2 l
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TENNESSEE VALLEY AUTHORITY PAGE' -l$211 REFERENCE - ECPS120J-ECPS121C RUN TIME - 12:1 OFFICE OF NUCLEAR POWER RUN DATE - 10/0
) FREQUENCY - REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
ONP - 1S55 - RHM LIST OF EMPLOYEE CONCERN INFORMATION SUBCATEGORY: 30206 TRANSFER CANAL ELECTRICAL EQUIPMENT CATEGORY: OP PLANT OPER. SUPPORT KEYNORD A S GENERIC KEYHORD B APPL QTC/NSRS P H
S- CONCERN KEYNORD C CONCERN SUB R PLT BB5W INVESTIGATION KEYMORD D:
FLQB REPORT R DESCRIPTION i NUMSER CAT CAT D LOC SS THE CONFIRGURATION OF THE ELECTRICAL HONCONFORMANCE OP 30206 N SQN I! N N Y I-86-163-SQN CORRECTIVE ACTIOh SQP-85-004-002 K-FORM EQUIPMENT IN THE ~ TRANSFER CANAL IS T50229 NOT PER THE DRAWING. DETAILS KNOHN ELECTRICAL TO QTC AND HITHHELD TO Mall:TAIN CONF EQUIPMENT 3-IDENTIALITY. NUCLEAR PONER CONCERN.
NO FURTHER INFORMATION MAY BE RELE-ASED. CI HAS NO FURTHER INFORMATION
) ,
. NO FOLLON UP REQUIRED.
.30206 N SQN NNNN SS THE FUEL TRANSFER SYSTEM HAS UPGRADE SQP-86-Oll-001 OP D FROM NON-QA TO A QA LEVEL II, H0HE T50277 K-FORM
) VER THERE ARE NO "AS CONSTRUCTED DRA HINGS".
) 2 CONCERNS FOR CATEGORY OP SUBCATEGORY 30206
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, TVA EMPLOYEE CONCERNS REPORT NUMBER: 312.08-SQN ,
- SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 0 TITLE: Security at Plant Entrances REASON FOR REVISION:
PREPARATION PREPARED BY:
R. E. Jones 10/13/86 SIGNATURE DATE REVIEWS PEER:
$ JL l0fl4 SIGNATURE / DATE f
TAS:
A$N '
H. // 7 f f SIGNATURE DATE CONCURRENCES CEG-H: .1 . %1s 10 i4 N ,
SRP: e ~
IO* 2I* U SIGNATURE DATE G SIGNATURE
- DATE APPROVED BY:
MUAub&le ECSP NANAUER 10-un DATE RiA MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
SR? Secretary's signature denotes SRP concurrences are in files.
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TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Security Element: Security At Plant Entrances Report Number: 312.08-SQN Concern Number: SQM-6-010-001 Evaluator: // /#/Z/f/,
/pf-R. E. Iones ' D" ate.
Reviewed by: Dd/Iffk l ~
/d//[92 Ps 'CEG (ember IDdte
/0[Mid Approved by: - %n" W. R. Lagefglen 'D6te 1779T J
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V. .
I. Security At Plant Entrances The concern expressed in this element addresses inadequate " Lunch Box" searches.
II . : Specific Evaluation Nethodology The employee concern identified to Quality Technology Company (QTC) is listed as follows:
SQM-6-010-001 - "Many Public Safety Officers do not require female employees to submit to a search of their purses during afternoon " Lunch Box Checks". This has allowed thefts of TVA property to occur (two calculators, no other details known). No further information in file. Anonymous concern.
Concern SQM-6-010-001 is an open SQN-specific item which was evaluated to determine the validity of the concern. The evaluation is based upon a review of NRC commitments, SQN Physical Security Plan, Section Instruction Letters, and plant procedures. Two interviews with Public Safety Services Personnel were conducted.
III. Findings The requirements for the protection of Nuclear Power plants are specified in-10CFR73.45, " Performance Capabilities for Fixed Site Physical Protection Systems" and Regulatory Guide (REG GUIDE) 5.7,
" Entry / Exit Control for Protected Areas, Vital Areas, and Material Access Areas".
Exit searches are only required to ensure that concealed Strategic Special Nuclear Material (SSNN) is not removed from the Material Access Area (NAA). This search uses Special Nuclear Naterial (SKM) detectors and metal detection equipment to search all materials leaving the NAA. There are no other regulatory requirements to search personnel exiting vital areas, protected areas or the site area. <
As a deterrent to theft of TVA property, Sequoyah Nuclear Plant conducts unannounced searches of personal packages and vehicles exiting the site area. These searches are conducted in accordance with Physical Security Instruction PHYSI-6, " Searches"; Surveillance Instruction SI-684, " Weekly Lunch Box and Vehicle Searches" and Public Safety Service (PSS) Section Instruction Letter (SIL) 38.0,
" Searches - Personnel Packages Vehicles and Gate Access". ,
Page 1 of 3
These random searches are conducted by each shift at least once per week and are used to detect the theft of expensive items easily identifiable as TVA material. Security personnel informed the interviewer that small inexpensive items such as portable calculators are usually not labeled as TVA material. Unless an easily identifiable calculator is reported stolen, Public Safety Officers (PS0) would not inspect each portable calculator taken out of the site area.
PSS Officers interviewed reported that they inspected all hand carried items during the random searches. These officers also reported that they knew of no members of the security force who failed to inspect purses during searches of hand carried items. The interviewer observed security personnel inspecting purses during a random search of hand carried items.
Conclusion The issue expressed by concern SQM-6-010-001 could not be validated and was not safety-related. The physical se' arch of hand carried items is conducted as a deterrent to the theft of TVA equipment and is not required by NRC commitments (except for SNM as defined in paragraph 2 of the Findings, section III). Security personnel stated that they inspected all hand carried items during random searches and the interviewer observed purses being searched.
IV. Root Cause None. Concern SQM-6-010-001 could not be validated. Therefore, no root cause was determined.
V. Generic Applicability Concern SQM-6-010-001 is not generically applicable. The concern could not be validated and the random searches of hand carried items exiting the site area are not required by NRC regulations.
VI. References
- 1. Code of Federal Regulations, 10CFR73.45
- 2. PSS SIL 38.0, " Searches - Personnel, Packages, Vehicles and Gate Access" Revision 10, (SAFEGUARDS INFORMATION)
- 3. Physical Security Instruction PHYSI-6, " Searches", Revision 7
- 4. Surveillance Instruction SI-684, " Weekly Lunch Box and Vehicle Searches", Revision 2 Page 2 of 3
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VII. Inunediate or Long-Term Corrective Action None required. Concern SQM-6-010-001 was not validated.
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REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -2LN"f FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:2 ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)' RUN DATE - 10/t LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31208 SECURITY AT PLANT ENTRANCES
' KEYWORD A S GENERIC H APPL QTC/NSRS P KEYWORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYNORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D 3
j SQM-86-010-001 OP 31208 N SQN MANY PUBLIC SAFETY OFFICERS DO NOT R PERSONNEL FEELINGS T50264 K-FORM EQUIRE FEMALE EMPLOYEES TO. SUBMIT TO PUBLIC SAFETY A SEARCH OF THEIR PURSES DURING AFT GENERAL
)
ERN00N " LUNCH BOX CHECKS". THIS HAS SECURITY ALLOHED THEFTS OF TVA PROPERTY TO O CCUR (TH0 CALCULATORS, NO OTHER DETA
- ) ILS KNCHN). NO FURTHER INFORMATION
' 'IN FILE. ANONYMOUS CONCERN.
1 CONCERNS FOR CATEGORY OP SUBCATEGORY 31208 iI I
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TVA EMPL',YEE CONCERNS REPORT NUMBER: 312.04-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 1 TITLE: Management and Personnel Issues REASON FOR REVISION:
Incorporate SRP and TAS comments Revision 1 PREPARATION PREPARED BY:
R.-E. Jones /#28 [d SIGNATURE ' DME
, / REVIEWS PEER:
$N h HIf0
/
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$Y / n DATE SIGNATURE CONCURRENCES CEG-H: ,d D-20 N SRP: m 10/2 [8C SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
h /g O-8/-86 N/A ECSP MM AGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 1549T SRP Secretary's signature denotes SRP concurrences are in files, i
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE ONCERNS TASK GROUP OPERATIONS CEG -
Subcategory : Security Element: Management and Personnel Issues Report Number: 312.04 - SQN, Revision 1 XX-85-043-OO3 Evaluator:
[ /0/pd /JId R.g. Jones -
'Uate Reviewed by: / [/'/i[/- .f4 /> [/$
OPS C ,Me(nbe r ' Date Approved by: _hti - %nu / 28!Y[
__ W. R. Lagebfren ' Date 1549T i
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-I. Management and Personnel Issues The concern addressed by this evaluation is the apparent inconsistency in the way Public Safety Service (PSS) Supervision implements regulatory requirements at Sequoyah Nuclear Plant (SQN).
l II. Specific Evaluation Methodology The employee concern was listed as a closed concern based upon a line management response. The line management response was not a specific response directed to SQN. The response on file was addressed specifically to Watts Bar Nuclear Plant. As a consequence this concern was evaluated as an open concern at SQN.
The employee concern is stated as follows:
A. XX-85-043-003 "Public safety supervision changes regulations at their own discretion."
This evaluation is based on a review of appropriate sections of the plant specific Security Plan, appropriate plant procedures and post orders.
. Public Safety Services personnel were interviewed, security related Quality Assurance audit reports from August 1984 through January 1985 were reviewed, and security related NRC region II audit reports from March 1984 through May 1985 were reviewed to determine if any regulatory non-compliance was identified during the period in question.
III. Findings Public Safety procedures, Section Instruction Letters (SILs) and post orders provide guidelines for the conduct of security activities. A review of selected PSS SILs determined that post orders allow shift supervisors some flexibility to change the requirements of an individual post station, as long as such changes do not violate the SQN Security Plan or NRC committments. These changes are documented on the post logs by the individual assigned to that post and are subject to review by Public Safety Management on a daily basis.
A review of security related NRC audit reports March, 1984 through May 1985 identified instances of regulatory non-compliance. Examplos include:
A. Vital area boundary found open and unmanned.
B. Improper vehicle search.
C. Vehicle found inside the protected area with keys in the ignition switch, i
Page 1 of 3
III. Findings .(Continued) i D. Lack of increased surveillance activity during partial loss of protected area lighting.
E. Badge to protected area taken outside protected area.
While these deficiencies may be indicative of programatic problems at SQN, no objective evidence could be found to demonstrate that these deficiencies are representative of actions resulting from Public Safety Supervisors directing changes that create instances of non-compliance. A review of Quality Assurance Security related audit reports for 1984 and 1985, also provided no objective evidence to support this concern.
An example of post order changes within the prerogative of the Public Safety Shif t Supervisor would be his requirements for manning access control to the power block. During periods of high activity several officers may be required to man this post. On a backshif t during low activity periods the shift supervisor may decrease the number of officers manning the post, yet still meet regulatory requirements to control access to the power block. Interviews with Public Safety line management documented their concurrence that such post order changes occur frequently, but they are reviewed by management to ensure they do not violate regulatory requirements.
The interview process also determined that any problem areas which might be created by shift supervisory variations on post orders have a vehicle for investigation and resolution. Officers can submit problems and questions to their supervision or union officers for discussion at a monthly meeting between security management and union officers. Results of these union / management meetings are posted on the recurity bulletin boa rd . A review of the meeting results for the last three months found no major complaints with the conduct of individual shifts.
The interview process also identified that additional opportunities for discussion between security management and Public Service Officers (PSO) are: 1) each shift supervisor holds meetings with members of his shift to discuss any potential problems, and 2) security management holds meetings with each class of PSS officers during retraining to discuss any problem areas.
Conclusions Employee concern XX-85-043-003 was not substantiated. Within the guidelines of the SQN Security plan, NRC requirements, and post orders; supervisory preogative is allowed to fit changing security conditions as long as regulatory requirements are not compromised.
As for the indications relating to programatic problems at SQN found during this evaluation, these are not newly identified. The SQN Systemmatic Assessment of License Performance (SALP) conducted by the NRC has identified these for line management. NRC has also increased their security audit frequency at SQN as a result of the declining SALP report rating for security during the report period.
Page 2 of 3
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IV. Root Cause This concern was not substantiated, therefore, no root cause was identifiable.
V. Generic Applicability These concerns were determined to be not generic. Supervisory perogative was allowed by SQN procedures and were not found to violate programmatic requirements.
VI. References
- 1. Code of Federal Regulations, 10CFR73
- 2. SQN Security Plan
- 3. PSS SIL 19, " Post Orders, Post 3," Rev 11
- 4. PSS SIL 20, " Post Orders, Post 4," Rev 10
- 5. PSS SIL 21, " Post Orders, Post 5," Rev 13
- 6. Region I'I NRC Security Inspection Reports for periods:
- a. March 20-22, 1984
- b. November 18-22, 1985
- c. September 3-6, 1985
- d. July 8-11, 1985
- e. January 21-25, 1985
- f. July 22-26, 1984
- g. May 8, 1985
- 7. SALP Reports dated September 17, 1985
- 8. QAB Audit Report for periods:
- a. OSS-A-85-006 - January 7-22, 1985
- b. SQ-8400-05 - February 6-10, 1984 VII. Immediate or Long-Term Corrective Action The concern was not valid and corrective action is not required.
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REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE t *'-2N3
) FREQUENCY - REQUEST DNP - 1555 - RHM OFFICE OF NUCLEAR P0HER EMPLOYEE . CONCERN PROGRAM SYSTEM (ECPS) RUN TIME'10/
RUN DATE ~f.1
. LIST OF EMPLOYEE CONCERN INFORMATION -
CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31204 MANAGEMENT AND PERSONNEL ISSUES
) S GENERIC - KEYNORD A H APPL QTC/NSRS P KEYHORD 5 CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C
) NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D XX 043-003 OP 31204 N SQN NNNN NS SEQUOYAH PUBLIC SAFETY SUPERVISION PERSONNEL ~ FEELINGS T50237 K-FORM CHANGES REGULATIONS AT THEIR OWN DIS PUBLIC SAFETY
) CRETION. CI DECLINED TO PROVIDE ADD GENERAL ITIONAL INFORMATION. NUCLEAR PONER GENERAL DEPARTMENT CONCERN. NO FOLLOH UP RE QUIRED.
1 CONCERNS FOR CATEGORY OP SUBCATEGORY 31204
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- , TVA EMPLOYEE CONCERNS REPORT NUMBER: 301.12-SQN
, SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant-Element REVISION NUMBER: 1 TITLE: System 31 Not Operated Properly REASON FOR REVISION: Revised to incorporate SRP comunents Revision 1 PREPARATION PREPARED BY:
G. D. Gardner 10/13/86
- SIGNATURE DATE
/ REVIEWS PEER:
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[/ SIGNATURE IIATE RW l d' N 2 SIGNATURE DATE CONCURRENCES A
CEG-H: i m- 1014-7 b
_ SRP: m . 10'21 8 [.
SIGNATURE DATE DATE Q SIGNATURE
- APPROVED BY:
M u $ A W #so$e to 21olo NiA ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files.
TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Nechanical Equipment Reliability / Design Element: System 31 Not Operated Properly Report Number: 301.12 SQN Revision 1 IN-86-064-001 Evaluator: G. D. Gardner 10/13/86 G. D. Gar ner Date Reviewed by: ,6 / 4 / //>//5/f[r OPS Cli e%r / Date Approved by: * . ,m - (0//Y[%
W. R. Lager sfen / Dale 1439T
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, Revision 1 I. System 31 Not Operated Properly 4
'This report evaluates for Sequoyah Nuclear Plant (SQN) an employee l concern _regarding air flow switches on 480-volt board room air handling lR1 i units. This issue was determined potentially safety significant by the l-
! Employee Concerns Task Group (ECTG) Technical Assistance Staff. l i 1 .
II. Specific Evaluation Methodology
]
The employee concern identified to Quality Technology Company (QTC) for 1
Watts Bar Nuclear Plant (WBN) is as follows:
- IN-86-064-001 Four (4) air follow switches on the 480 volt board '
room air handlers do not function, Aux Bldg., Unit's 1
& 2, Elevs. 772' & 786'. These switches have been removed and re-calibrated and results have always been within acceptable tolerance; however, they remain I
inoperable. (Names / details known to QTC and release of this information would jeopardize CI's
, confidentiality) CI has no further information. ;
, Nuclear Power Concern.
The ECTG files were reviewed and a Nuclear Safety Review Staff (NSRS) ,
report was found to address the issue at WBN. This report along with I 4
informal interviews with cognizant engineers in SQN instrument maintenance formed the basis of the evaluacion.
1 III. Findings !
The NSRS report for WBN (reference 1) was reviewed and it was determined !
that the area of concern was with Fluid Components Incorporated (FCI) i j flow switches. The report stated that the FCI probes were slow acting measuring up to 20 seconds to clear. Unless the operator held the start button for more than 20 seconds, the alrhandling units (AHUs) would trip l on low flow. The report noted that WBN instrument maintenance had i
initiated corrective action to relocate some of the probes in the j ductwork and replace others with fast response probes to resolve the i problems at WBN.
l The cognizant engineers at SQN instrument maintenance for systems 30 and l 31 (ventilation and air conditioning) were contacted. They stated that 1
Dwyer diaphram type flow switches are used on the 480-volt board room
equipment. Most of the FCIs were added as a result of modifications and
! were successfully tested. Both slow and fast probes are used at SQN and i
- both engineers stated no problems had occurred sielliar to WBN. Should !
any problems occur, they would be addressed at that time. i 1
- An EQIS listing of the FCI slow probes was obtained and indicates that i the probes are used on the emergency gas treatment system (EGTS) and IR1 EGTS room coolers. A review of Maintenance Requests (MRs) written on l
- these instruments did not indicate problems similar to WBN. l 4
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- Page 1 of 4 I
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i Revision 1 Conclusion The issue presented by employee concern IN-86-064-001 was not validated for SQN. The responsible engineers contacted and maintenance history lR1 4
reviewed indicate problems which occurred at WBN have not occurred at SQN. l IV. Root Cause No deficiencies were identified, therefore a root cause analysis was not lR1 performed. l V. Generic Applicability Evaluations conducted at both SQN and WBN resulted in no corrective actions. The concern was specific to WBN and was being addressed according to NSRS evaluations. This issue is therefore not considered generic.
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... Revision 1 VI. Reference
- 1. NSRS Investigation Report I-85-416-WBN, "Aleflow Switches Inoperable," Raployee concern IN-86-064-001, December 18, 1985
- 2. RQIS Listing of Fluid Components Incorporat ed Model 12-64 flow l switches used at SQN, September 26, 1986 l 1
- 3. MR A-300822 on 0-FS-65-25B/A, November 20, 1985 l 1
- 4. MR A-523744 on 0-FS-65-31A/B-B, December 27, 1985 l l
S. MR A-546145 on 0-FS-65-44B/A, November 6, 1985 l l
- 6. MR A-530544 on 0-FS-65-44B/A, July 19, 1985 l lR1
- 7. MR A-546144 on 0-FS-65-31A/B, November 6, 1985 l l
- 8. MR B-116963 on 2-FS-30-200-B, January 13, 1986 l l
- 9. MR B-102508 on 2-FS-30-200-B, January 21, 1986 l l
- 10. MR 165462 on 2-FS-30-200-B, August 27, 1981 l l
- 11. MR B-116964 on 2-FS-30-207-A, March 17, 1986 l l
- 12. MR 165224 on 2-FS-30-207-A, September 11, 1981 l Page 3 of 4
- ._. .. _. . _ . . . ... . __ .=. _ _ _ - _ . _. ..-
- Revision 1
! VII. Immediate or Long-Term Corrective Action No deficiencies were identified by this evaluation an no corrective IR1 action is required.
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.EEFERENCE - ECPS128J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -I$ II:
() FREGUENCY - REQUEST ONP - 15S5 - RHM .
OFFICE OF NUCLEAR POWER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN TIME - Ital' RUN DATE - 18/0:
LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30112. IMPROPER OPERATION OF SYSTEM 31 S GENERIC '
KEYNORD A.
H APPL QTC/NSRS P KEYWORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYWORD C
() NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYNORD D IN 064-001 OP 30112 N HBN NNYN I-85-416-H5N SS FOUR (4) AIR FLON SWITCHES ON THE 48 NONCONFORMANCE T50119 REPORT 0 VOLT BOARD ROOM AIR HANDLERS DO NO CONST PROCESS-ap T FUNCTION, AUX BLDG., UNITS 1 & 2, ELECTRICAL ELEVS. 772' & 786'. THESE SHITCHES CONTROL PANEL HAVE BEEN REMOVED AND RE-CALIBRATED AND RESULTS HAVE ALHAYS BEEN HITHIN ACCEPTA3LE TOLERANCE; H0HEVER THEY R J EMAIN INOPERABLE. (NAMES / DETAILS KN DHN TO QTC AND RELEASE OF THIS INFOR MATION HOULD JEOPARDIZE CI'S CONFIDE
- p NTIALITY) CI HAS NO FURTHER INFORMAT ION. NUCLEAR POWER CONCERN.
. 1 CONCERNS FOR CATEGORY OP SUBCATEGORY 30112 J
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s TVA EMPLOYEE CONCERNS REPORT NUMBER: C011206-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 (Final Report)
TITLE: Unauthorized Work / Undocumented Work PAGE 1 0F 4 As Related to Construction REASON FOR REVISION:
To incorporate Technical Assistance Staff and SRP comments and finalize report Revision 1 PREPARATION PREPARED BY:
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DATE N/A MANAGER OF NUCLEAR POWER DATE ECSP MANAGKR CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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- , TVA EMPLOYEE CONCERNS REPORT NUMBER: C011206-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 4
-l SUPPLEMENT FOR SEQUOYAH NUCLEAR PLANT I. Introduction This report addresses one concern, IK-85-077-X04 that states: " Drawings Have Been Falsified."
II. Summary of Perceived Problems The concerned individual (CI) felt that his supervisor was signing lR1 as-built drawin3s that the CI had refused to sign-off on before l '
transfer for preoperational testing. l III. Evaluation Methodology A. Reviewed expurgated files and other available flies to gain additional information regarding this concern.
B. Reviewed Sequoyah Nuclear Plant (SQN) Construction Standard Operating Procedure No. 308, Revision 5, dated Apell 18, 1980,
" Configuration Control."
C. Reviewed SQN Construction Procedure No. P-15. Revision 3, dated October 15, 1976, " Transfer of Permanent Features and Associated Documentation to the Division of Power Production."
IV. Summary of Findings A. Review of the expurgated flies revealed an NSRS Report No.
I-85-860-SQN. The NSRS Report I-85-860-SQN revealed the following information:
- 1. The SOP 308. Revision 5, was written to provide a common method of marking drawings required for a system transfer. The procedure utilized a common method within TVA of cognizant working level individuals performing the tasks and then the unit supervisor reviewing that work. The assignment of a responsible
- reviewer within a unit is made by the unit supervisor. lR1
v s T TVA ERP! AYRE CONCERNS REPORT NUMBEtt C011206-SQN ,
.* SPECIAL PROGRAN REVISION NURBER: 1 PAGE 3 0F 4
- 2. Within the Construction organization, the unit supervisor is the person responsible for assuring that cognizant engineers are gus11fied and are performing the assigned work in a satisfactory IR1 manner.
- 3. The unit supervisor, by position, education, and experience, is I considered to be qualified to initial that a drawing is marked I correctly and, in fact, is called by procedures SNP SOP 308 and l SNP Construction Procedure P-15 to do so. Technically, the lR1 cognizant engineer would initial the construction revision block I in the appropriate space, and the unit supervisor should initial I in the designated space. I
- 4. No objective evidence of drawing falsification was found in this investigation.
- 5. The CI said when he refused to sign an as-built drawing status l sticker his boss would take a look at the drawing and sign it. l This supposedly occurred on electrical drawings around 1980 lR1 at the time of systems transfer before preoperational I testing. l I
- 6. The CI said this was no longer a concern. l B. Review of SQN Construction Standard Operating Procedure 308 Revision 5, dated April 18, 1980, " Configuration Control" revealed the construction responsible engineer as the individual to mark current configuration and' initial the construction revision block. This proceduce also showed that the construction unit supervisor as being required to affix his initials on the construction revision block.
C. Review of SQN Plant Construction Procedure P-15 Revision 3, dated October 15, 1976, " Transfer of Permanent Features and Associated Documentation to the Division of Power Production" revealed the responsible engineering unit is responsible for identifying incomplete work and that the section unit supervisor signs the Incomplete Work Item Form. lR1 Conclusion This evaluation agrees with the NSRS Report that drawings of this type I had not been falsified and misunderstanding of the procedures by the lR1 concerned individual led to the concern. No further evaluation was I deemed necessary. I
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- . TVA EMPLOYEE CONCEENS REPORT NUNBER: C011206-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 4 Y. Root Cause None VI. Corrective Actions None VII. Generic Applicability None VIII. Attachments '
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Attachment A - Listing of concerns indicating Safety Relationship and lR1
- Generic Applicability. l t
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- IED. DETAILS KH0HN TO QTC, WITHHELD DUE TO CONFIDENTIALITY. CONSTRUCTI
- '0N DEPT. CONCERN. CI HAS NO FURTHER l
. INFORMATION.
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REPORT NUMBER: NC-40206-SQN ,
.+- SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 (Final Report)
TITLE: Natorials as it Relates to Purchasing and PAGE 1 0F 6 Requisition REASON FOR REVISION:
Revision 1: Revised to incorporate comments from the Technical Assistance Staff (TAS) and the Senior Review Panel (SRP).
Revision 2: Revised for minor gransnar and format corrections, wording clarifications, and the addition of Attachment A.
PREPARATION PREPARED BY:
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f g/t) SO lO*W'80 N/A ECSP RAWAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
'SFP secretary's signature indicates that SRP files contain documentation of full Panel concurrence.
1427T
-. -. _ _ _ _ _ _ - _ _ _ _ .~. .- - - _ - - - , _ _ _ - - _ - _ - _ _
TYA EMPLOYEE CONCERNS REPORT NUMBER: MC-40206-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 OF 6 I. Introduction This element contains one concern, WI-85-053-011, relating to the material procurement policy and was not made generic to Sequoyah Nuclear Plant (SQN) during the Watts Bar Nuclear Plant (WBN) evaluation. However, this concern was evaluated by the Generic Concerns Task Force (GCTF) at SQN, and the GCTF report was reviewed for adequacy.
II. Summary of Perceived Problems Other TVA sites are not on the approved vendors list for supplying i
materials to SQN.
III. Evaluation Methodology A. Reviewed Employee Concerns Task Group (ECTG) files, Quality lR2 Technology Corporation (QTC) expurgated files, and WBN Element i Reports MC-40201 and MC-40206 to cetermine if applicable information was available to assist in the evaluation. lR2 B. Searched for Nonconforming Condition Report's (NCRs), audits, etc., lR2 relating to other TVA sites supplying questionable quality materials.
C. Interviewed knowledgeable individuals about Quality Assurance (QA) requirements for suppliers of materials to SQN.
D. Reviewed SQN GCTF Report WI-85-053-011 to determine adequacy of investigative methodologies, findings, and conclusions. IR2 IV. Summary of Findings A. Reviewed expurgated QTC flies and WBN Element Reports MC-40201 and lR2 MC-40206 and found no further information.
B. Reviewed NCR printout and audit inder, and interviewed lR2 knowledgeable individuals. No NCRs or audit findings relative l to inferior or unacceptable items received from other TVA l sites were found. l
,. TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40206-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 6 IV. Summary of Findings (Continued)
C. Interviews with knowledgeable QA individuals indicated that the policy is to designate the material and documentation requirements on the requisition and verify upon receipt that the requirements are met. Knowledgeable QA individuals also stated the site procedures (Administrative Instruction AI-ll IR2 and Standard Practice SQA45) are being implemented. 1 D. A review of the GCTF report revealed the following: lR2 Code'of Federal Regulations, 10 CFR 50, Appendix B, criteria II, l IV, and VII, requires establishment of a QA program that covers l procurement of material, parts, and services. Nuclear Regulatory l Commission (NRC) Regulatory Guide (RG) 1.123, "QA Requirements for l Control of Procurement of Equipment, Materials and Services."
establishes acceptable standards for procurement programs.
RG 1.123 (Revision 1) endorses American National Standards Institute (ANSI) Standard N45.2'.13. "QA Requirements for Control lR2
. of Procurement of Items and Services for Nuclear Power Plants." l The TVA Topical Report includes these regulatory guides with no exceptions taken.
ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants," sets up the general guidelines for a QA program. Section 8 requires measures to assure that material or lR2 services purchased conform to the procurement documents. It also I requires that a purchasing entity make provisions for source I avaluation/ selection, obtaining objective evidence of quality, source verifications, and receipt inspections.
ANSI N45.2.13-1976, " Quality Assurance Requirements for Control of Procurement of Items and Service for Nuclear Power Plants,"
provides further details pertinent to a QA program for procurement. lR2 Section 7 gives broad guidelines for ascertaining quality of parts. Sections 10.2 and 10.3 give specific details on parts documentation. Section 10.3 states that verifications can be performed by source inspections, receipt inspections, certificate of conformance, or post-installation testing. Each of these is acceptable under certain criteria which are provided in Sections 10.2 and 10.3.
Nuclear Quality Assurance Manual (NQAM) Part III, Section 2.1 requires that only QA sources (i.e., acceptable suppliers) be used for QA Level I, II, and IS items.
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.. TVA EMPLOYER CONCERNS REPORT NUMBER: MC-40206-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 4 OF 6 IV. Summary of Findings (continued)
Paragraph 2.1.2 assigns the Division of Quality Assurance (DQA) lR2 Procurement Evaluation Branch (PEB) with responsibility for establishing and maintaining an Acceptable Suppliers List (ASL).
The ASL is on TVA's computer system and accessible by all plants. -lR2 It was found that not all TVA facilities are listed on the ASL. l However, TVA facilities do transfer material and equipment on a routine l basis within the constraints and guidelines as outlined in the procedures and instructions listed in this Element' Report. A cover memorandum (L19 851107 806) to the ASL restates that before IR2 a contract is signed, the supplier must be approved by PEB.,spther TVA facilities that fully comply with these requirements, as previously lR2 stated, ara acceptable suppliers and are approved by PEB.
Sequoyah Standard Practice SQA45, " Quality Control of Material, Parts and Services," provides-guidance on responsibilities for the procurement process for SQN.
SQA45. Section 5 provides a list of 26 items to be considered lR2 during preparation of a purchase requisition. Item 10 requires designation of a supplier and that the ASL shall be used for
. source selection, except for material and equipment transferred from other approved TVA facilities as previously stated. Item 15 lR2 provides for source inspection access. Item 16 requires I consideration of the need for a Certificate of Conformance-(C0C). lR2 SQA45, Section 6 discusses the SQN procurement process and lR2 responsibilities in detail. It defines the QA Levels and I details review responsibilities. Both QA and Power' Stores are assigned responsibility for review of Purchase Requisitions / purchase documents before final approval. This includes administrative and technical reviews. Section 6.10 provides guidance on use of IR2 each request form type. Section 6.12 provides guidance l on specifying QA requirements that meet 10 CFR 50, Appendix B, ANSI, and American Society of Mechanical Engineers (ASME) lR2 standards, by paraphrasing ANSI N45.2.13, Section 10.3. l SQA45, Section 11 provides guidance for specifying a source inspection lR2 en the purchase documents. The criteria cited are taken from ANSI N45.2.13.
SQA45, Section 17 assigns QA and Power Stores the responsibility for IR2 performance of receipt inspections in accordance with Administrative Instruction AI-11.
4 .i TYA EMPLOYEE CONCERNS REPORT NUMBER: MC-40206-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 6 IV. Summary of Findings (continued)
AI-11. " Receipt Inspection, Nonconforming Items, QA Level / Description Changes and Substitutions," Section 5.1, designates responsibility for receipt inspections to Power Stores. A receipt inspection is required for all Critical Systems Structures and l Components (CSSC) parts and services. QA must also review receipt of lR2 any item designated QA Level I, IS, II, IIS, (requiring a COC),
Engineering Change Notice (ECN) QA Part 21 or ECN QA Part 21 indeterminate. These reviews must include verification that the material or service conforms to the purchase requisition.
Paragraph 6.5.4 addresses transfers, and paragraph 6.5.8 specifically lR2 i calls for a review of the vendor QA program requirements. l NOTE: This evaluation found the GCTF report findings above to be adequate and the conclusion that no problem existed to be i correct.
~
Conclusions Not all TVA sites are listed on the Acceptable Suppliers List (ASL). l i TVA sites are not considered to be vendors in the normal sense. It l 1s not a requirement that all TVA sites are on the ASL because TVA i sites must fully meet all the requisitioning requirements described in lR2 criteria discussed in this element. report. A program is in place to l ensure that adequate technical and QA requirements are met on items l transferred from other TVA sites. Therefore, no problem exist relative l
- to the perceived problem and the perceived problem is not valid. l I
i V. Root Cause f
i Not applicable. No problem validated / substantiated. lR2 t
VI. Corrective Action None required.
VII. Generic Applicability l This concern has been determined to be generically applicable to lR2
! Browns Ferry Nuclear Plant (BFN) and to Bellefonte Nuclear Plant i (BLN) since both plants received material from other TVA sites.
VIII. Attachments i
! Attachment A: Concerns Printout (Identifies relationship of Nuclear R2 Safety and Generic Applicability.)
5 i <
PA5F A '3 REFERENCE - ECPS131J-ECPS131C TENNESSEE VALLEY AUTHORITY RUN TIME *12:09:48 FREQUENCY - REQUEST + OFFICE OF NUCLEAR PONER RUN DATE - 1*p/03/86 -
ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
LIST OF EMPLOYEE' CONCERN INFORMATION CATEGORY: MC ADEQUACY OF MATERIAL SUBCATEGORY: 402 PURCHASING & REQUISITIONING ,
GENERIC REFERENCE SECTION APPL QTC/NSRS Pf CATEGORY - MC CD:ICERN SUB PLT BBSH ' INVESTIGATION S* CONCERN . 402 DESCRIPTION SUBCATEGORY NUf1BER CAT CAT LOC FLQB REPORT R 402 HBH YYYY NS MATERIALS ARE RECEIVED AT HBNP FROM HI -8S-0S3-011 MC OTHER TVA SITES HITH COMPLETE DOCUME K-FORM NTATION, H0HEVER, THESE OTHER SITES TS0134 ARE NOT ON THE HBNP VENDOR LIST. TH -
IS HAS ALSO FOUND DURING THE JUNE 19 8S ASME SURVEY. DETAILS KNOHN TO QT C, HITHHELD DUE TO CONFIDENTIALITY.,
CONSTRUCTION DEPT CONCERN. CI HAS NO.FURTHER INFORMATION. NO FOLLOW UP REQUIRED.
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NS -- Nuclear Safety'Related SS -- Nuclear Safety Significant NO -- Not Nuclear Safety Related 5 $ E R :i a o, 5 n o E 2 2 E E E E 5 5
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,. TVA EMPLOYEE CONCERNS REPORT NUMBER: MC40510-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report)
TITLE: Requisitions PAGE 1 0F 6 REASON FOR REVISION:
Revision 1. Revised to incorporate Technical Assistance Staff (TAS) and Senior i
Review Panel (SRP) comments.
Revision 2. Revised for minor formst and grammar corrections, wording clarification, and the addition of attachment A.
PREPARATION PREPARED BY:
--- 4- D ~ \ h'blO SIGNATURE DATE REVIEWS PEER:
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- SIGNATURE / DATR SIGNATURE l6f h DATE CONCURRENCES CEG-H @b /4 SM SRP: /0/21/II.
SIGNATURE DATE
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$ll $$ 6 lO~2l~$(o NlA ECSP'MiNAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature indicates that SRP flies contain documentation of full panel concurrence.
1261T
i
..' TVA EMPLOYEE CONCERNS REPORT NUMBER: MC40510-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 6 I. Introduction This element was extracted from concern WI-85-036-002 and was determined to be generic to Sequoyah Nuclear Plant (SQN) by Watts Bar Nuclear Plant (WBN) Employee Concerns Task Group (ECTG), Material Control Element Report MC-40510.
II. Summary of Perceived Problem Requisitions are being changed and altered later. (Suggesting that
. changes were not being properly concurred with.)
III. Evaluation Methodology A. Reviewed expurgated file WI-85-036.
B. Determined if any Employee Response Team (ERT), Quality Technology l Corporation (QTC), Nuclear Safety Review Staff (NSRS) or other lR2 reports exist on the subject concern. l C. Reviewed Site Procedure Administrative Instruction AI-11, Section 8.0, "QA Level Changes and/or Description Changes and/or Substitutions," Revisions 32, 34, 35, and 36.
D. Reviewed site-initiated requisitions and determined if changes had been made according to the procedural requirement.
E. Interviewed knowledgeable personnel associated with the initiation of site requisitions and determined if additional information was available regarding the concern.
F. Reviewed WBN ECTG Material Control Element Report MC-40510, Requisitions, to determine if the findings addressed a perceived problem at SQN, and if corrective actions were initiated which would address the findings.
IV. Summary of Findings A. A review of expurgated file WI-85-036 revealed no additional information regarding this concern.
B. WBN ECTG Element Report MC-40510 stated that QTC files indicated the concern was either a Division of Nuclear Construction (DNC) or Office of Nuclear Power (ONP) concern.
.. TVA EMPLOYEE CONCERNS REPORT NUMBER: MC40510-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 OF 6
(.
C. Measures established in SQN Site Procedure AI-11 Section 8.0, control the altering and changing of site-initiated requisitions.
Section 8.0, "QA Level Changes and/or Description Changes and/or Substitution," required that Attachment 9 to the procedure be completed for Quality Assurance (QA) level changes, QA description lR2 changes, and substitutions. Subsection 8.1, "QA Level Changes and/or '
i Description Changes," paragraph B " During Procurement Cycle (Up to lR2 Receipt)," requires, that during the procurement cycle, changes chall j not be made to approved procurement documents without the review and l
approval of the originator's organization or designated plant f procurement organization (Material Services SQN) and the designated QA organization (s). This review and approval of changes shall be documented on the affected procurement document, or by signed correspondence of which a copy is filed with the record copy of the procurement document, or by using Attachment 9 and Attachment 16 (as needed according to paragraph 8.2.1). Attachment 16. " Evaluation for Acceptability of Class 1E Substitutions," shall be completed and attached to Attachment 9 for substituted equipment identified for use in a class 1E application.
D. A random review of site-initiated requisitions for the period 1 April 8, 1985 through July 1, 1986 revealed four contracts (362725, 1 362791, 364203 and 364239) where changes had been made to approved l requisitions. These changes were implemented by the completion of IR2 Attachment 9 as required according to Site Procedure AI-11. Other l requistions reviewed did not reveal any changes which had been made I to the initial request. l Note: This review encompassed the time period for which IR2 deficiencies were discovered and identified at WBN-ONP in the corrective action report initiated by V. L. Patuzzi on January 13, 1986, and transmitted on January 28, 1986 by TVA lR2 memorandum T19 860128 800. l E. Interviewed personnel from Electrical Maintenance, Mechanical Maintenance, Instrumentation, and Materials Unit's Designated Project Procurement Office (DPPO). As a result of these interviews, it was revealed that virtually no instances could be recalled where changes were made to requisitions initiated by the units which would affect the quality of material received or work schedule. en interview with an Electrical Maintenance individual revealed that minor changes had been made to the quality levels of material by the Materials Unit (DPPO) on requisitions 376851 and 377154. In review of the aforementioned requisitions, it was found that the changes had been made by DPPO and technical and QA review had been performed. This review was annotated on the requisition and is an acceptable practice according to paragraph B of Section 8.1 of AI-11. An interview with an instrumentation engineer revealed that requisition 453114 had been changed by the Purchasing Agent without prior notification to the responsible site personnel. The initial
.*- - TVA EMPLOYEE CONCERNS - REPORT NUMBER: MC40510-SQN SPECIAL PROGRAN l REVISION NUMBER: 2 PAGE 4 0F 6 4
requisition required a source inspection of the material before being shipped to the site. The contract indicated that no source inspection was required. Upon receipt of the material at the site, a Nonconforming Item form (NCI, N2-86-228) was initiated indicating that a quality release source inspection was needed. (As a result of previously mentioned reviews and interviews this was determined to be an isolated occurrence.)
- F. Through review of WBN ECTG, Material Control Element Report i
MC-40510 " Requisitions," it was indicated by a Corrective Action Report (CAR) that problems involving the unauthorized changing or.
4 altering of requisitions by Purchasing Agents (pas) did exist. The corrective actions taken by the Division of Purchasing regarding this matter were to reduce the number of pas who purchase safety-related material from 75 to 23 to train and continue to periodically train the 23 pas at the division, branch, and section levels as needed, and to develop a checklist for pas and supervisors to use in assuring that our QA manual requirement are implemented (Reference TVA memorandum TOO 860304 718 depicting the corrective actions which have been taken by the Division of Purchasing in regard to the finding of Element Report 40510.)
f conclusions ;
Through research of requisitioning documentation and interviews with site personnel, it was determined that very few, if any, problems exist at SQN regarding the improper altering or changing of requisitions by site or Division of Purchasing personnel. Although one example of an improper change to a contract was identified and was determined to have been made by the Division of Purchasing, the incident was identified by site personnel l and cited by the QA Receipt Section at SQN and did not present a condition IR2 adverse to quality. Other incidents of improper changes to requisitions l were not identified. l V. Root Cause Not Applicable. No problem validated / substantiated. lR2 i
i VI. Corrective Action i
None required by line organization. Corrective actions were previously implemented as a result of the corrective actions report. These actions are identified in paragraph F of the summary of findings.
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. - TVA EMP!4YEE CONCERNS ' REPORT NUMBER: MC40510-SQN ,
.*' SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 6 VII. Generic Applicability None: This concern was made generic to SQN, Office of Nuclear Power only, due to the finding indicated in the WBN evaluation MC-40510. However, the corrective actions stated in paragraph F's reference memorandum, TOO 860304 718, involved the training of all pas in the Division of Purchasing. Therefore, this concern is determined not to be generic to Bellefonte and Browns Ferry Nuclear Plants.
VIII. Attachments Attachment A. Concerns Printout (Identifies relationship to Nuclear lR2 Safety and Generic Applicabilitf). l
~ " . .. -
PAGE - 4 RUll TIME - 12:09:44 RUN ' D AT E - 10/03/86 REFEREllCE SECTION 8-CATEGORY - MC
- ~ SUBCATEGORY - 405 r ...,
t TENNESSEE VALLEY AUTHORITY REFERENCE - ECPS131J-ECPS131C OFFICE OF NUCLEAR POWER FREQUEllCY - REQUESr EMPLOYEE CutlCER!l PROGRAM SYSTEM (ECPS)
OrlP - ISSS - RHM LIST OF EMPLOYEE CollCERil IllFORMATI0tt SUBCATEGORY: 405 MATERIAL IDENTIFICATI0tl ATEGORY: MC ADEQUACY OF MATERIAL GEllERIC APPL QTC/NSRS Pt S CONCERN y SUB PLT BBSH INVESTIGATION R DESCRIPTI0tl CollCERil CAT LOC FLQB REPORT llUMBER CAT m ri d Cd
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ill 036-002 MC 402 HBN NNYN NS MATERIAL REQUISITIONS ARE Il0T BEING PREPARED AS PER PROCEDURE; THE REQUI
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80104-SQN REPORT TYPE REVISION NUMBER:
Element Report 1 TITLE: PAGE 1 0F 4 Quality Assurance Management Performance REASON FOR REVISION: Rewritten to incorporate SRP and TAS conunents.
Note: Sequoyah Applicability Only PREPARATION PREPARED BY: W. E. BEZANSON b / *l/ 7lN QGNATURE DATE REVIEWS PEER:
CMu ~
SIGNXTDRE i
InJa DATE TAS:
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SRP :
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CE [O'2O' SRP M 80*2I-84 SIGNATURE DATE jGNATURE* D/ fE APPROVED BY:
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lOdl'$h N/A DATE MANAGER OF NUCLEAR DATE CSRP Secretary's signature denotes SRP concurrences are in fileg0WER CONCURRENCE (FINAL REPORT ONLY)
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- REPORT NUMBER:
80104-SQN-REPORT TYPE: REVISION NUMBER:
~ Element Report 1 TITLE: PAGE 2 OF 4 Quality Assurance Management Performance.
1.0 ' CHARACTERIZATION OF' ISSUE a.. Concern SQN-86-035-003 (Attachment A) K-Form dated 2/20/86 During interview, the CI stated and later documented the concern that time sheets used by Inservice Inspection (ISI)' Inspectors, violate 10CFR50 requirement that inspectors in a nuclear plant cannot be l placed on production.
2.0
SUMMARY
Inservice Inspection (ISI) Inspectors being l
- a. The issue raised was:
placed on production.
- b. Relevant documents were reviewed (letters, memorandums, codes, etc.)
to determine those requirements pertaining to this concern.
- c. Discussions were held with various personnel 'in the ISI Group and Accounting Department representatives pertaining to time sheets l requirements,
- d. No findings that substantiated the basis for the concern were identified as a result of this investigation. The perceived cause for issuing this concern was the CI's incorrect interpretation of Appendix."B" to 10CFR50. y
- e. As the concern was uroubstantiated ,
no corrective action was required.
3.0 EVALUATORS l W. E. Bezanson-4.0 EVALUATION PROCESS
- a. -The evaluation included a review of Employee Concern Files, including the Confidential Files, which resulted in no additional data.
However, the discussions held with three (3) ISI personnel, indicated two (2) memorandums (dated 12/20/85 and 12/26/85) were issued v
" time. reporting". Discussions were held with accounting personnel at Sequoyah and CDattanooga pertaining to procedural requirements for completing time sheets.
- b. In addition, Appendix B to 10CFR50 (dated 1/20/75) was reviewed, to determine if the concern, as written, was a violation of that
- document. >
- ![ 'c. The concern is generic to all sites as the ISI Group functions under However, the concern one program, which is applicable to all sites.
was not substantiated.
i l
1
T REPORT NUMBER:
REPORT TYPE: 80104-SQN Element Report REVISION NUMBER:
TITLE: 1 Quality Assurance Management Performance PAGE 3 OF 4 5.0 FINDINGS
- a. Discussions with the ISI .Non Destructive Examination (NDE) Section l Supervisor, ISI Site Coordinator (Sequoyah) and Unit Supervisor, all stated the requirement for ISI Inspectors to complete Individual Bi-weekly Time Reports (Attachment B) was instituted in late December, 1985. Prior to that date, the ISI Inspectors were completing a similar, more detailed record (Attachment C). l The present Bi-weekly Time Report was instituted by the Manager-Maintenance and Engineering, per memorandum (L 25-851220801) dated 12/20/85, (Attachment D) on the ISI Group, for the purpose of '
"reporcing time under new service' agreements" being accomplished by that group.
Discussions with accounting personnel (Sequoyah and Chattanooga) l indicated no document was available which specified the requirements for completing Individual Bi-Weekly Time Reports.
- b. Based on the limited information available in the concern and files, it is assumed the CI was referring to the following statement in Appendix B to 10CFR50 (dated 1/20/75) Criterion I, which states:
, " persons and organizations performing quality assurance functions l shall have sufficient authority and organziational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and . organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided." As a result, the issue " time sheets used by ISI Inspectors constitutes them being placed on production", is not a violation of Appendix B to 10CFR50.
- c. Based on the results of this investigation, the concern could not be substantiated, as the action taken by management was not in violation of Appendix B to 10CFR50. The generation of time sheets by ISI Inspectors is an administrative function, which is consistent with the same requirements performed by other site personnnel. The time sheet is utilized to account for time spent on a given task, wnich has no. bearing or impact on prcduction requirements.
- d. The review of this concern indicated it would have generic applicability, if substantiated.
- e. As a result of this investigation the concern is considered non-safety related.
e 6.0 ATTACHMENTS A. List of Employee Concern Information Subcategory 80104, dated 9/17/86
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REPORT NUMBER:
REPOP.I TYPE: 80104-SQN Elesc.nt Report REVISION NUMBER:
TITLC: 1 Quality Assurance Management Performance PAGE 4 0F 4 B. Bi-weekly Time Report C. Time sheet prior to 1/86 D. Memorandum L 25851220801, dated 12/20/85 E. Memorandum G.W. Minton to Those Listed dated 12/26/895 I
ATTACHMENT A TENNESSEE VALLEY AUINOIlfY PAGE - 260 i
'REFERE! ICE - ECPS123hECPS!21C Rifts TIME - 13:33,7 )
FRED"*NC't -- REQUEST OFFICE OF NUCLEAR P0llER RUtt DATE - 09/17tg (Le - 2:45 **FI EMPLOYEE CONCERN PROGRAM SYSTEM IECPS3 LIST OF EMPLOYEE CONCERN INFORMAft0H CATE00 rye GA GA/0C PR00RANS SUSCATECORYe 80104 QUAT!TY ASSURANCE MAllAGEMEHf PERFORMANCE 3 CENERIC KEYHORD A H APPL STC/NSRS P KEYHORD 5 INVE5flGATIOtl 5 CONCERN KEYHORD C CONCERII SUB R PLT I 8 5 la KEYHORD D HUMSER CAT CAT D LOC FL03 REPORT 4 DESCRIPTION YYYY SS DURING Att INTERVIEH C0tITACT THE CI 5 l SON =84-035-003 OA 80104 N BFN K-FORM T AT ED AtID L ATER 00CUllENT ED INE CollCE RN THAT IINE SNEE15 USED BY 151 INSP ECTOR$ VIOL ATE 10CFR5n RE00TRTMENT T HAT Itt3PECTORS 114 A flUCL E AR PL ANT CA ,
HNOT BE PLACED 01; PRODUCTION.
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"**"I I ATTACHMENT D c UNITED STATES COVERN3 TENT L u) 5 8 b 12 2 0 801 -
TMemorandum TENNESSEE VALLEY AUTHORITY TO Those listed '
FROM ,: R. A. Sessoms, Manager, Maintenance and Engineering, LP SS 85E-C /-
.-- DATE ~: DEC 2 01985 .
7
SUBJECT:
_' REPORTING TIME UNDER THE
_ . . . - - . . . . . .. NEW . . . SERVICE
. . . . . . . .AGREEMENTS
. . - REVISED ATTACHMENTS
- 1. The, revised attachments are annotated to reflect approved contracts and pending contracts that may be assumed to be 4-approved.
t
- 2. Cenerally speaking, charges should be made utilizing the
! following guidelines.
- a. If an approved contract is in place, tasks performed in support of that contract should be char'ged to the appropriate contract task number for time, material, per diem, or otherwise. -
- b. If there is no approved contcact that reflects tasks the customer has requested be peofomed, then:
(1) If time and circumstance preclude having a written -
, contract in place before commencement of. work, attempt *
! to obtain a " gentleman's agreement" between the prospective activity managers that a verbal authorization from the site agreement officer has been obtained to negotiate a contract between Maintenance and Engineering and the customer. Obtain a new contract activity number and initiate contract paperwork.
(2) If no verbal authorization can be obtained, capture - -
expenditures in an appropriate account number that 4-reflects the actual work performed (e.g., charging to a non-effective variable scope task). Initiate contract negotiations as rapidly as possible, and attempt to write a contract to capture the applicable backcharges.
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Page 1 of 2
" Ruv l'..t .7ar inne Rands Rnnlariv nn the Pavroli .tarrin er Plan
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2 Those listed .
DEC 2 01985 REPORTING TIME UNDER THE NEW SERVICE AGREEMENTS - REVISED ATTACHMENTS
- c. If work is performed that is not covered by a contract and is not requested by the customer, then a 764 or 986 subprogram (overhead) account number should be used.
However, if the work involved has direct customcr benefit, it should be assig'ned an appropriate overhead task number in order to properly capture expenditures of resources (e.g.,
section QA program for future site work).
W\
R. A. Sess' oms
- C. L. Breeding LP SS 101E-C C. E. Cantrell, LP SS 83E-C T. H. Durham, LP SS 38E-C (3)
J. E. Flack, LP AS 51B-C E. F. Harwell, LP SS 103E-C J. M. McGriff, BR SN 75A-C (4)
_ J. H. Miller, LP SS 150D-C (15)
J. R. Ratliff, BF 6N 32A-C M. L. Rollins, LP SS 102E-C WRB:RMT Attachments cc (Attachments):
NUC PR RIMS, LP AS 132D-C June Rains, LP 4S 115B-C 0006R
.. A
. Page 2 of 2
-- r- r.- . _ _ _ _ , ,, ,_ _ , -
^' '
.- t ATTACHMENT E .
s*
December 26, 1985 Those listed
Subject:
NEW SERVICE AGREEMENT - REVISED ATTACHMENTS Attached for your infonnation and use are the latest revisions to our timekeeping system.
All work, except true emergencies, which are dangerous to life or limb, shall be documented to us from the plant ISI contact, i.e., Harding, Mimms, etc. This document shall define work, give schedule for completion, authorize overtime, identify procedures, acceptance criteria, identify hold points, etc. Emergency work shall be followed up with a written contract change. All contract changes shall be submitted to me ASAP.
As you can readily see, it is essential that we track our costs and properly assign time and other expenses to the right account number.
3
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G.W.Minton(
vT. T. Gilbert, SQN
- vJ. ' L. Goodner, WBN "
l 6R. A. Latimer, BFN - y j G. L. Wade . BR 9S 192Y-C /
j-
,, F. 'S. Wells, BR 53 125X-C i
GWM:DRL cc: D. A. Howard, 1186D-C J. H. Miller, 150D-C B1AN.RL
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Page 1 of 7
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- Revised December 18, 1985 MAINTENANCE AND ENGINEERING MECitANICAL BRANCH AUTHORIZED ACCOUNTS .
CONTRACTS ISI INSPECTION SECTION (48)
Description Account No.
~
- ' , ,BFN --ISI Program Fixed Contract 8348-76570-20-F06M9
~"" BFN - ISI Program variable contract 8348-76570-20-V06M9xx***
BFN - ISI A&I Project Support *8348-54670-xxxxx-F06WBxx***
SQN - ISI Program Fixed Contract 8348-76571-20-F06M9xx***
SQN - ISI Program Variable Contract 8348-76571-20-VCf,M9xx***
- --NOT AN WBN - ISI Program Fixed Contract WBN - ISI Pergram variable Contract 8348-38572-20-F06M9xx***-------EFFECTIVE 8348-38572-20-V06M9xx*** CONTRACT
- WBN- ISI A&I Project Support *8348-54672-xxxxx-F06WCxx***----NOT AN
- SQN - ISI Eddy Current Testing 8348-76571-20-V06MJ EFFECTIVE CONTRACT
- Use appropriate work order number for "xxxxx"
- ** Account Number not presently effective.
- Use one of the following appropriate task numbers for "xx" Acoustic Emission 01 Cal Block Control 02 Contractor Support .
03 Data Mgt/ Development 04 Data Mgt/ Entry 05 Decontamination 06 Document Review 07 Equipment Control /M&TE 08 ET Heat Exchanger 09 ET Steam Generator 10 ISI Single Point Contact 11 Meetings 12 MT (III) 13 MT (XI) 14 Other Sprt Activities 15 Pipe Crawler 16 Prepare Final Report 17 Prepare SenPin/Schding/Alara 18 Preparc/ Issue MRs 19
g Process / Escort Non TVA Psnl 20 Process /TVA Psnl 21 PT (III) 22 PT (XI) 23 RT Isotope (III) 24 RT Isotopo (XI) 25 RT Minne (III) 25 RT Minac (XT) 27 .
- Standby / Equipment 28 Standby /H.P. 29 Standby / Scheduling 30
. Page 2 of 7 0007R '
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Revised December 18, 1985 ISI INSPECTION SECTION (48) 1 Description Account No.
Standby / Security '
Standby / Support 31 Supv..ISI Psnl & Contractors 32 33 S.G. Tube Pig & Insp Sprt 34 .
Travel
. Turbine NDE 35
40 VT (XI) 41 VT (XI) (Remote) 42 Walkdowns 43 O
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_ Page 3 of 7 0007R r - - . . - - . . . . . . ,_w .
__.r..-. . . , . . , _ . ----
. Revised December 18, 1985 MAINTENANCE AND ENGINEERING AUTHORIZED ACCOUNTS
- OVERHEAD AND OTHER NONCONTRACT ACCOUNTS '
. (Use these accounts only if not covered on existing contracts)
Description *See NOTE 1 Account Number 2
General Administration 83XX-YYY77-ZZ-ADMZ100 Activity Ping, Sch, Budgeting 01 Compliance with Policy Directives 02 Clerical, General
- 03 Procedures and Instructions 04
- Medical & Badging 05 General Contract Administration . 06 Customer Work Without Contract 83XX-YYY77-ZZ-ADMZ200 Preliminsry P'roject Proposal Work 01 Work with Contract Rev Pending 02 Oversigt.t (Working Without Contract)' 03 Warranty Claims -
04 Plant Documentation Review 05 Resolve reg. Concerns 06 Plant Shipments 07 Work for greater than 1 Contract - Program 83KX-YYY77-Z Z-ADMZ300 Generic Reviews 01 Addressing Generic Concerns 02 IQT Contracts 03 Maintenance History pgm 04 Data Systems 05 Cancelled Plant Mat'l Transfer 06 PIMS 07 Package QA Program 08 -
Reg Culde 1.97 Implementation 09 Work for greater than 1 Contract - Equipment 83XX-YYY77-Z i
Z-ADMZ400 Equipment Studies 01 Repair / Replacement Studies 02
- Environmental Qualification 03
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Improved Processes / Techniques 04 Technical Standards Development 05 Equipment Handling Problems 06 special Tooling Develop. 07 Equipment Interchangeability 08 Pager 09 Equipment Procured or Leased 10 .
- Page 4 of 7 0007R
, - - ,- , - ----,,-r - , , - - - , . , . - , . , . - - ,. - _ - . ., - . - - - - - . - - - -,
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Revised December 18, 1985 Work for Other Than Customers 83XX-YYY77-ZZ-ADMZ500 Design Support 01 CECC Support -
. 02
, Vendor & Project Exploration 03
- Corporate Support Projects 04 -
f u POTC Assist. 05
[ .![.~.PSOSupport
. 06
^-^ Operate P&M Voice Not 07 Operate P&M Data Net 08 Operate Radio Sys. 09 Operate Emerg. Phone Net . 10 INPO Participation 11 Non-Plant Shipment 12 Employee Concerns -
13 Trainint (Plant Required) 83XX-YYY17-ZZ-ADMZ600 Training to Meet Access Rqmts. 01 Trainint '
(General)
General H&S Training 83XX-YYY77-ZZ-ADMZ602 Technology Training 03
. Professional Development 83XX-YYY77-ZZ-ADMZ700 Prof. Society Conferences & Fees . 01 Reading Professional Info. 02 Professional Education 03 Author Industry Papers 04 NOTE 1: .
"XX" - Appropriate section code.
"YYY"- 764 or 986. Generally speaking, ma,nagement and their clerical support should utilize 986 when not charging their time to a specific contract. -
"ZZ" - 764:30 - Staff
- 31 - Mechanical Branch
- 32 - EI & C Branch
- 33 - Fuels Branch
,, 986:34 - All Organizations A
NOTE 2: ADM stands for administrative, since contract information is not applicable. However, if, for accounting purposes, it is determined that such charges may need to be associated with a particular contract (e.g., costs may be assigned to a particular customer at the end of the year), then substitute the YEAP ISSUED AND ACTIVITY SEQUENCE CODE OF THE DESIRED CONTRACTS in place of ADM.
Page 5 of 7 0007R -
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Rsvisad December 18. 1985 EXAMPLE: 8339-98680-34-6M42301 would be assigned in ancitipation of -
revising existing contract 70-20-F06M4 during the year to include experience review activities. Note that, when using a 764 or 986 subprogram, the location codes are as follows:
77 - Central Office Charge (normally used) 80 - BFN 81 - SQN 82 - WBN 83 - BLN
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- Page 6 of 7
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( ,t Revised l December 18, 1985 Account Number Format -
Div. Sub Type Rev. Yr. Act. Task 1831 Sect. Program Location FERC Contract Level Issued Sec. No. No Optional 2 xx xx - axx xx -a x- a x x ax xx A Note 1 Note 2 Description of Fields ,
- 1. Division - 83 .
- 2. Section - Organization Making Charge
- 3. Subprogram - Operations: 765; Most Overhead: 764 or 9'86; capital Projects:
546; Watts Bar and Bellefonte: 3851, A. Location - Customer: 70, 71; etc. (or 77 for 764 subprogram). See Note 1 of
. Attachment B for Further Explanation.
- 5. FERC - Previously Assigned to Sectio,n (usually 20).
- 6. Type Contract - F: Fixed Cost; V: Variable Cost. -
- 7. Revision Level - P: Preliminary for Nonapproved Contracts. Normally 0 through 9, and if needed, A-Z.
- 8. Year Issued - Fiscal Year Issued; "6" for FY 86.
- 9. Activity Sequence Mc. - Alpha Numeric Firt) Position: "E": EI&C Branch Assigned Activity "M": Mechanical Branch ^
"F": Nuclear Fuels "W": Capital Projects "Z": Administratican.and overhead Second Position: 1 through 9 and then A through Z. Start again with 1 at beginning of each FY.
g
- 10. Task No.: 01 through 99 (Start 01 for each activity)
- 11. Optional Code: At Discretion of Branch (EC: Plant Org. Receiving Service)
Note 1: For 546 Subprogram ("W" Activities), Use 5-Digit Work Order No. In Lieu of 2-Digit FERC Code.
Note 2: Avoid the use of the letters B, I, 0, and S. Use only as a last resort.
Page 7 of 7 0007R .
NATERIALS CONTROL Erc11:stra 2 ECTG WRITER'S GUIDE ELEMENT REPORT FORMAT
- 1.0 Issue I. Introduction Characterization II. Sunnary of Perceived Problem 2.0 Summary IV. Sussnary of Findings Conclusions (Portion) 3.0 Evaluators Cover Sheet Information 4
4.0 Evaluation III. Evaluation Process Nethodology 5.0 Findings IV. Sunnary of Findings 6.0 Root Cause V. Root Cause (Collective Significance)** ** Overall Root Cause will not be considered at this report level. ,
i 7.0 Attachsaents/ VIII. Attachments List of Concerns Other items included VI. Corrective Actions in Element (To be provided by Reports line organizations)
VII. Generic Applicability i
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, , , , - , ,,c -e._.- - - . _ . - , - - - - . - - - , , , _ _ , , . , - - . - -. - - - - . _ . - , , - , - -
CONSTRUCTION CATEGORY E ;c l o st:r o 2 ECTG WRITER'S GUIDE ELEMENT REPORT FORNAT 1.0 Issue I. Introduction Characterization II. Summary of Perceived Problem 2.0 Summary IV. Summary of Findings Conclusions (Portion) 3.0 Evaluators Cover Sheet Information 4.0 Evaluation III. Evaluation Process Nethodology 5.0 Findings IV. Summary of Findings ,
6.0 Root Cause V. Root Cause (Collective Significance)** ** Overall Root Cause will not be considered at this report level. ;
l 7.0 Attachments / VIII. Attachments !
List of Concerns '
Other items included VI. Corrective Actions '
in Construction Element (To be provided by Reports line orgainzations)
VII. Generic Applicability 190ST A
0FERATIONS CATEGORY Enclosure 2 ECTG WRITER'S GUIDE OPERATIONS (OP) ELEMENT REPORTS NOTES /CONNENTS 1.0 Issue I. Title The brief introduction Characterization Very brief introduction touches on the source of the concerns.
2.0 Summary I. Title 1. The Conclusions are Very brief introduction towards the end of the findings.
III. Finding (Conclusions) 2. The Conclusions services as a summary of the findings.
3.0 Evaluators Cover Sheet 1. The printed name of the original evaluator (s) appears on the cover sheet.
- 2. The peer reviewer and CEG-H approval signa-tures are also on the cover sheet.
4.0 Evaluation II. Specific Evaluation Process Nethodology S.0 Findings III. Findings 1880T
E;citsura 2 ECTG WRITER'S GUIDE OPERATIONS (OP) EIJIENT REPORTS NOTES /C01DIENTS l
6.0 Root cause IV. Root Cause 1. At the element level (Collective significance) the Root Cause is often j not identifible.
- 2. Collective significance is not addressed at the element report level.
7.0 Attachments / II. Specific Evaluation 1. A list of the concerns List of Concerns Nethodology with text are included within this section.
- 2. Other reports are sometimes attached.
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O Enclosure 3 Page 1 of 4 EMPLOYEE SEQUOYAH CONCERN ELEMENT REPORT NUMBER ISSUE Operations 30905 IN-86-209-012 Engineering Training (final)
Note: Initial report transmitted 10/22/86 Operations 30708 XX-85-122-036 Training Programs (final) X1-85-058-001 for Employees Note: An initial report was not necessary.
This will be the only submittal for 30708.
Operations 30707 XX-85-035-001 Radiological (final) JLH-86-004 Emergency Plan Note: Initial report transmitted 9/15/86 Operations 30301 IN-85-841-001 Difficulty of (final) Obtaining Obsolete Equipment Note: An initial report was not necessary.
This will be the only submittal for 30301.
Operations 31201 KI-85-048-001 Adequacy of Public (final) Safety Service (PSS)
Officier Uniforms in Nuclear Power Plant Environment Note: Initial Report transmitted 9/9/86 l
_m_-.___ _
(I Enclosure 3 Page 2 of 4 EMPLOYEE SEQUOYAH CONCERN ELEMENT REPORT NUMBER ISSUE Operations 31307 SQN-85-001-02 Sequoyah Nuclear (final) Plant (SQN)
Insulation Note: An Initial report was not necessary.
This will be the only submittal for 31307.
Operations 31304 RII-86-A-0022 Environmental (final) RII-86-A-0100 Note: An Initial report was not necessary.
This will be the only submittal for 31304 Operations 31303 SQM-6-001-001 Housekeeping (final)
Note: Initial report transmittal 9/23/86 Operations 31302 RMM-85-001 Personnel Safety (final) RMM-85-002 (Hardware)
Note: Initial report transmitted 9/15/86 Operations 30206 SQP-85-004-002 Transfer Canal (final) SQP-86-011-001 Electrical Equipment Problem Note: Initial report transmitted 9/9/86 l
s Enclosure 3 Page 3 of 4 EMPLOYEE SEQUOYAH CONCERN ELEMENT REPORT NUMBER ISSUE Operations 31208 SQM-86-010-001 Security at Plant (final) Entrances Note: Initial report transmitted 10/7/86 Operations 31204 XX-85-043-003 Management and (final) Personnel Issues Note: Initial report transmitted 9/15/86 Operations 30112 IN-86-064-001 System 31 not (final) Operated Properly Note: Initial report transmitted 9/9/86 Construction 11206 XX-85-077-XO4 Unauthorized Work /
(final) Undocumented Work as Related to Construction.
Note: An Initial Report was not necessary.
This will be the only submittal for 11206 Materials Control 40206 WI-85-053-011 Material as it (final) Relates to Purchasing and Requisition.
Note: Initial report transmitted 9/15/86
t Enclosure 3 Page 4 of 4 EMPLOYEE SEQUOYAH CONCERN
. ELEMENT REPORT NUMBER ISSUE Materials Control 40510- WI-85-036-002 Requisitions (final) s Note: Initial report transmitted 9/15/86 Quality Assurance 80104 SQN-86-035-003 Quality Assurance (final) XX-85-069-003* Management Performance.
Note: An Initial report was not necessary.
This will be the only submittal for 80104
- This concern will be addressed in the welding category for SQN. This change in category assignment was made after 9/26/86. 4 s
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