ML20214V377
| ML20214V377 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/06/1986 |
| From: | Lagergren W, Murphy M TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214T770 | List: |
| References | |
| 307.11-SQN, 307.11-SQN-R02, 307.11-SQN-R2, NUDOCS 8612090655 | |
| Download: ML20214V377 (17) | |
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TENNESSEE VALLEY AUTHORITY I
SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS ,
CEG Subcategory: Nuclear Power / Site Program / Procedure Element: Management Non-responsiveness Report, Number: 307.11-SQN-Revision 2 E-85-116-001 H-85-116-003 H-85-116-006 H-85-116-014 OW-85-001-002 TAK-86-007 Evaluator: Walt Strodl /#-29-f4 Walt Strodl Date Evaluator: _D. W. Stewart //-29-P4 D. W. Stewart Date Evaluator: D. E. Smith //> 84 D . E . Sm h j Date Reviewed by: I/
[ //'dYd Date Approved by: -
m" ll I b W. R. Lag (egren Date 2034T 8612070655 861120 PDR ADOCK 05000327 P PDR
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Revision 2 i I. Management Non-Responsiveness l The concerns expressed in this element discuss the following issues at Sequoyah Nuclear Plant (SQN): (1) the suspect quality of chemistry and radiochemistry data. (2) inadequate chemical / radiochemical program, (3) unresolved definition of single failure criteria, (4) unit operator (UO) not informed of maintenance activities, and (5) the violation of Technical Specifications for secondary system water chemistry.
II. Specific Evaluation Methodology The employee concerns are stated as follows:
A. II-85-116-001 " Chemical and radiochemical data of poor quality at Sequoyah could be very costly and cause
- embarrassment to TVA."
- 8. II-85-116-003 "TVA has exhibited a lengthy disregard toward fulfilling commitments made to various regulatory and vendor organizations with respect to chemical and radiochemical data used to monitor and control operations of SQN."
C. II-85-116-006 "Sequoyah - Recommendations made by internal TVA organizations such as Nuclear Safety Review Staff (NSRS) have produced little results regarding correcting practices which lead to chemical and radiochemical data of poor quality."
D. OW-85-001-002 "A difference of opinion was identified between line management and NSRS regarding the definition of single failure criteria. This difference was dropped by NSRS and line management with no resolution."
! E. TAK-86-007 " Safety margin will be greatly reduced because Shift Engineer / Senior Reactor Operator (SE/SRO) is busy and does not inform lead UO of maintenance activities."
F. II-85-116-014 "Sequoyah - Management (known) has signed off secondary water chemistry conditions that were in violation of the Technical Specifications without having an engineering evaluation performed in violation of site procedures. Time e
period of 1985.
Page 1 of 13
Revision 2 II. Specific Evaluation Nethodology (continued)
Concern XX-85-116-001 was evaluated in order to determine the " quality" of chemical-and radiochemical data at SQN, the laboratory quality control program was investigated. The principal base documents reviewed to identify criteria for a laboratory QC program were:
USNRC Regulatory Guide RG 4.15. Revision 1. February 1979, " Quality
, Assurance for Radiological Monitoring Programs (Normal Operations) -
Effluent Streams and the Environment".
INPO Good Practice CY-701, May 1983, " Quality Control Program for Chemistry Instrumentation."
d INPO Good Practice CY-702, July 1982, " Verification of Analytical Performance."
, INPO Good Practice CY-704, February 1986, " Chemistry Analytical Data Review."
- The evaluation included interviews with SQN chemical personnel, review of chemistry procedures, review of INPO, NRC, and internal TVA audits and evaluations, and review of the results and data from the laboratory QC program. Review of INPO evaluations included review of the INPO evaluator's field notes which contain additional detcils on any i findings. Also included was a tour of the chemical laboratory.
Concern II-85-116-003 and II-85-116-006 are of such similar nature that 3 it was determined to evaluate the issues simultaneously. The cognizant supervisor was contacted. A completed Nuclear Safety Review Staff lR2 1 (NSRS) report for both of these concerns was reviewed and evaluated for adequacy and completeness. Also reviewed were applicable procedures, i NRC reports, and INPO reports. These concerns are Sequoyah specific.
The concerns are addressed by NSRS Report I-86-130-SQN.
Concern OW-85-001-002 was evaluated by discussions with cognizant lR2 individuals and by comparing Design Criteria SQN-DC-V-2.16 for single
", failure criteria for fluid and electrical safety systems, with upper tier documents for completeness. This is a concern determined to be j generically applicable to Sequoyah.
Concern TAK-86-007 was evaluated based on information obtained through lR2
] contact with individuals from the Operations organization of SQN and by y examination of applicable procedures. This is a Sequoyah-specific j concern.
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R3 vision 2 II. Specific Evaluation Methodology (continued)
Concern XX-85-116-014 is a specific concern for the Sequoyah site. The K-form and the NSRS Investigation Report, I-86-132-SQN, on this' concern was reviewed. The evaluation of this concern includes a review of Sequoyah Plant Technical Specifications, applicable chemistry procedures, secondary water chemistry data, and interviews with cognizant chemistry personnel.
III. Findings Concern X1-85-116-001 Standard Practice, SQE 22 Revision 3 "Sequoyah Nuclear Plant Chemistry Program," describes the methods used at SQN to comply with the requirements of R.G. 4.15. Each requirement of R.G. 4.15 is listed in the procedure along with SQN's method of compliance. The program described in SQE 22 includes:
Instrument calibration requirements Duplicate sampling and analysis Back6round count rate and check source response j Blank and spiked sample analysis Interlaboratory cross-checks Quality control trend charts Appendix E of Technical Instruction TI-20. " Chemical Laboratory Test Equipment Calibration Program," delineates the analytical chemistry Quality Control (QC) program. This program includes:
Laboratory Cross-checks with Power Operations Training Center (POTC)
Spiked and unknown semple analysis Duplicate sampling and analysis Use of log sheets and control charts.
Laboratory QC data from these programs were reviewed and discussed with cognizant chemical personnel. Data outside of preset limits have been investigated by chemical personnel. The chemical unit also conducts in-house QC audits on a routine basis as described in ES-SIL C7,
" Radiochemical Laboratory In-House Quality Control Auditing Program."
The results of those audits are reviewed by the Chemical Laboratory Supervisor and the Chemical Unit Supervisor.
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Ravision 2 III. Findings (continued) "
The 1985 INPO Evaluation stated that, "The chemistry quality control
- program needs improvement" and "Some chemistry laboratory activities need to be improved." Specific areas requiring improvements included use of spiked samples, use of control charts, and review of control charts and trend plots. The laboratory QC program has been expanded
, since the INPO evaluation and the specific INPO concerns addressed.
NRC inspections of SQ3 include a confirmatory measurement program where selected radioactive systems are sampled and analyzed by both NRC and the plant. SQN's results have generally been in agreement with NRC.
Specific results not in agreement have been investigated and the causes identified and corrected. The 1985 NRC Investigation Report states that, "The inspectors noted a general uncleanliness in the laboratory." This was not observed by the writer nor was it diccussed in the 1986 NRC Inspection Report. Laboratory cleanliness is now included in the in-house QC audits conducted by the chemical unit. The 1986 NRC Inspection Report states, "The inspector believed that the Chemistry Unit was capable of performing the responsibilities defined l in its water chemistry program." No violations or deviations were (
identified during the 1986 NRC inspection. An internal TVA memorandum )
on the exit meeting for the 1986 NRC inspection attributed the l following remarks to the NRC inspection.
"The SQN Chemistry procedures conformed to those of the Westinghouse Owners Group, which he (the inspector) strongly endorsed. The quality control in the chemistry laboratory had )
improved since his last inspection. He (the NRC inspector) l believed that positive actions were being taken in this area."
A tour of the chemical / radiochemical lab indicated that, in general, the lab was clean and maintained. The writer was informed that work requests have been submitted for the painting and tiling of the lab, and for improvements to the ventilation system. It was observed that a fan was being used to cool the electronics associated with the gamma spectroscopy system.
Concerns 1I-85-116-003 and II-85-116-006 These two concerns were investigated and documented by NSRS
, Investigation Report No. I-86-130-SQN (reference 23). The scope of that report was determined to be: "1. TVA has disregarded commitments
. made in the chemical and radiochemical data area, and 2.
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III. Findings *(continued) , y ;.t(
3 s Recommendations made by daternal TVA drganizations have had little effect on poor quality ' chemical and radiochemical data." This idencified scope addresses thesel,two c'oncerns. The NSRS report findings with respect to the disregard of the previous NSRS audit findinge inEthe chemistry aria are stated as follows:
NSRS Report No. R-82-08-NPS, " Review of the Office of Power Water Quality Program," da,ted February 22, 1983', and a follow-up review, R-83-26-NPS, approved on February 9. 1984, reviewed the entire TVA nuclear power chemistry program', These reports contained SQN
. specific findinss. 'Ihe initial report was 149 pates'long. This report (R-82-08-NPS) had its findings summa:*ized into ten general findings thai had generic application to all, T/A nuclear plants and the NUC PR.Contr41 Office organization. The;11RS intended for the generic findings to re'etify programmatic deficiencies in the water quality. program.. Thus the specific' findings' contained in the body of ,the report would' be rectified as better programs were put.in place. The follow-up report (R-83-26-NPS) lasued a year later found that'only one of the ten findings could be closed. A response to the NSRS follow-up report was written by the !GC PR lR2 Central Office (NCO)'.1 This meno addressed programs that pere to be in place in 1984 to resolve the generic issues raised f.n 'tM NSRS report. Neither ChemiaT.ry personnel nor Compliance personnel at SQN were aware of any commitments due to the findings in these reports. As proper corrective action had not been taken by the NCO to address each of the ten identified generic findings, thosej specific findings at SQN remain uncorrected. '
lR2 The Chemistry Section at SQN is aware of most of the deficiencies that outside organizations (INPO and NRC) have found to be problems in the implementation of the chemistry program at SQN/ The organir.ation within TVA that has made a review of the program at the plant and has had no action taken on its recomunendations by the same SQN staff is the NSRS. The NSRS Report No. R-82-08-NPS has a number of SQN specific deficiencies included in its 149 pages.
These deficiencies are not clearly identified and are'not reflected I
in the ten generic deficiencies contained in the summary, "Conclus(ons and NSRS Positions" section found on page 6. The specific findings contained in the NSRS reports were discussed with the Chemistry Section managettent during both exit reviews and a 4
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Rsvisien 2 III. Findings (continued) marked-up copy of the original report (with SQN deficiencies highlighted) was provided to the Chemistry Section management prior to its follow-up review. .No SQN items from the original report were contained in the list of outstanding NSRS items in the follow-up report. This includes the following:
- 1. Pages 34 and 35 "TI-27 specifications conflicts with FSAR commitments."
- 2. Pages 52 and 53, " Laboratory Quality Control Program has not been established to include all of the requirement of RG 4.15 and section III of DPN N79E2."
- 3. Page 65, "Not all of the analyses required for acceptance in section IV of DPN N79E2 are included in the implementing document at SQN."'
- 4. Page 68, "NSRS recommended to station management that the SQN staff do an internal review to determine the status of programs implementation (procurement and receipt program for QA Level III bult chemicals) and take corrective actions."
- 5. Page 42, "NSRS believes that SQN plant chemistry staff should review their TI-ll analytical procedures and evaluate DPN N79E2, section II, prior to implementing them directly'into their program."
After having discussed the above referenced NSRS reports with SQN Compliance and Chemistry cognizant individuals, it was determined that these identified report deficiencies and recommendations have not been acted upon or resolved as of this date. Compliance has just recently issued a CAT (Corrective Action Tracking) document on the two recommendations in NSRS report I-86-130-SQN.
The report recommendations were prioritized [P3], which is a low priority which does not receive immediate management attention and officially doer not require any written response.
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d Revision 2 III. Findings (continued)
Concern OW-85-001-002 - For SQN, there currently exists a Design Criteria Document. SQN-DC-V-2.16 " General Design Criteria (GDC) for ,
Single Failure Criteria for Fluid and Electrical Safety-Related Systems." This document is based on the requirements of the FSAR which incorporates the requirements of 10 CFR 50 Appendix A, which clearly defines single failure criteria.
The evaluation could not determine whether or not a disagreement between NSRS and line management existed for single failure criteria.
The FSAR was used to determine single failure criteria requirements before developing SQN-DC-V-2,16, dated June 27, 1986. The FSAR was consistent with 10 CFR 50 Appendix A. Through review of records and interviews with several cognizant individuals on the plant staff and NSRS no incident was noted of incorrectly applying the single failure criteria.
Concern TAK-86-007 - Documentation and connunication of the plant configuration is controlled by Operations Section Letter -
Administrative (OSLA) 58 " Maintaining Cognizance of Operational 1
Status." Continuity of information between shifts is ensured by AI-5
" Shift and Relief Turnover." There is a configuration log, per OSLA j'
58, which records a;f off-normal alignment of Critical Safety Systems and Components (CLSC) equipment. The lead unit operator is charged with the responsibility of maintaining this log. The clearance sheet has a signoff signifying the configuration log has been updated. This verification of the plant status is made by the lead operator. Any entry into the configuration control log must be reviewed and approved by the unit SRO. MI 6.20, which controls mechanical and electrical
' maintenance, does not require an authorizing signature to begin work (a previous revision did have this requirement). However, most MI6.20 work involves a clearance for maintenance activities. IMI-134, which controls instrument maintenance, requires the unit operator's signature to authorize work.
Four of four interviewed unit operators were familiar with the requirements of the procedure and were comfortable with the effectiveness of the procedures, with none reporting any personal experience with not knowing equipment status.
Concern 11-85-116-014 - Sequoyah Plant Technical Specifications 6.8.Sc requires:
"A program for monitoring secondary water chemistry to inhibit steam generator tube degradation."
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Revision 2 III. Findings (continued)
The specification lists seven items the program shall include. No limits, frequencies, or required corrective actions are included in the specification. These items are addressed in the program described in SQE-22. "SNP Chemistry Program." SQE-22 identifies specific actions to be taken when various secondary water chemistry parameters are exceeded. Action Level I (lowest level) requires a reduction in power to less than 30 percent within a given timeframe, depending on which limit is exceeded. Action Level II requires a reduction in power (<30 percent) within four hours and "an immediate engineering review. . . to determine if the out-of-limit condition is a spurious chemistry i
perturbation." Cognizant chemistry personnel stated that this review is completed by the Chemistry Shift Supervisor as part of his
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recommendations to the shift engineer. TI-37, " Chemistry Laboratory
, Los Systems," requires the Chemistry Shift Supervisor to fill out a
" Chemical Laboratory Plant Recommendation" (SIL-C10, Attachment 8) and
- forward it to the shift engineer. Action Level III requires a reduction in power to mode 4 within eight. hours. Table la of SQE-22 i
also provides an exception to the sulfate limits for Action Levels I, II, and III during Mode 1 operation until the time that installation of the steam generator blowdown system was completed. It also should be noted that TI-37, which is the procedure used by laboratory personnel, does not list any limits for sulfate in the steam generator blowdown.
However TI-37 references SQE-22 where the sulfate limits are listed.
A review of the daily chemistry trend chart for 1985 (Note: The plant was shut down from mid-August through December) did not identify any incident requiring Action Level III response. One incident was identified where the Level II action limit for dissolved oxygen in the hotwell was exceeded. A " Chemical Laboratory Plant Recommendation" sheet was completed per procedure and power reduction initiated. Prior to reducing power to less than 30 percent, dissolved oxygen was returned to acceptable levels and the plant returned to 100 percent power. Several incidents were identified where a parameter exceeded a Level I action limit. With the exception of sulfates (January and Apell), the parameters were returned to acceptable levels within the time limit specified. Cognizant chemistry personnel stated that as
'. noted in SQE-22, Table la, sulfates cannot be met until the installation of the steam generator blowdown system (which is now installed). The NSRS investigation included a random sampling of a
secondary water chemistry log sheets and "did not identify an error of the type described in the employee's statement of concern". NSRS did
- not substantiate the concern.
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Revision 2 Conclusions XX-85-116-001 The concern was not validated. A laboratory QC program based on NRC and INPO guidelines is being implemented at Sequoyah, including laboratory cross-checks with NRC and TVA's POTC Laboratory. The results of the laboratory QC program indicated that the quality of data meets WRC and INPO guidelines. Discussions with cognizant personnel and review of NRC and INPO reports indicates that improvements have been made in the laboratory QC program during the past year.
The lack of adequate ventilation in the laboratory could affect the operation of the gamma spectroscopy system. However, the current QC program is in place to identify erroneous data before its use in required analysis.
XX-85-116-003 and XX-85-116-006 The conclusions identified by NSRS report I-86-130-SQN are stated as follows for these concerns:
The concern is valid because the deficiencies in the NSRS report were never acted upon by the plant, and there are remaining open items from audits of the chemistry program.
For most audits of the SQN chemistry program, efforts were made to correct deficiencies. This is demonstrated by the response to NRC, QA, and INPO audits and investigations. THe SQN Chemistry Section appears to be working to. correct any identified problems and has taken action on deficiencies in a timely manner in most cases. Outstanding deficiencies in the chemistry area, identified in NSRS Report No.
R-82-08-NPS, were presented by the report author to SQN Chemistry management at exit meetings. The deficiencies were not listed and tracked on any commitment system, and no corrective action has been taken.
OW-85-001-002 Concern OW-85-001-002 is not valid for Sequoyah. No specific incident of disagreement of the application of single failure criteria was found through examination of plant records and interviews.
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Ravision 2 Conclusions (continued)
TAK-86-007 Concern TAK-86-007 is validated because the potential exists for a l reduction in the safety margin due to unit activities occurring without lR2 l i licensed operators cognizance. Not having the unit operator authorize, l l
by signature, maintenance activities covered by MI-6.20 is not a l problem since, except for unusual cases, the equipment will be covered i by a clearance and documented in the Configuration Log. For cases i where activities performed under MI-6.20, which do not require a i clearance such as troubleshooting or preventatiave maintenance, it is recommended the UO signature requirement be returned to MI-6.20. The l l potential exists during these times of troubleshooting and preventative l maintenance where plant activities are occurring without the SE or UO lR2 cognizance, therefore, a problem could arise which could adversely l affect safety, l-II-85-116-014 t Concern II-85-116-014 was not validated. There was one incident in 1985 requiring an engineering review. The review was completed by the Chemistry Shift Supervisor and recommendation forwarded to the shift engineer in accordance with approved procedures, However, due to the differences in wording and the problem with meeting the sulfate limit in SQE-22 and TI-37, some confusion may have existed in the interpretation of an " engineering review". However, now that the Steam l Generator Blowdown System is installed, the exception to the sulfate lR2 limit in SQE-22 no longer is applicable. I IV. Root Cause Based on the findings of this evaluation the following concerns have no i root cause due to the invalidity of the coraerns:
11-85-116-001 !
OW-85-001-002 l 11-85-116-014 For concern 11-85-116-003 and 11-85-116-006 the root cause is determined to be the non-responsiveness to the low priority items on l ,
NSRS report I-86-130-SQN. lR2 Page 10 of 13
Rsvision 2 IV. Root Cause (continued)
For concern TAK-86-007 the root cause is the removal of the UO signature from MI-6.20.
V. Generic Applicability l Two concerns, XX-85-116-001 and XX-85-116-014 are deemed not y generically applicable due to being non-valid SQN specific concerns.
h* Concerns XX-85-116-003 and XX-85-116-006 is deemed not generically
. applicable to other TVA sites due to the information in the referenced a NSRS reports which states that the other plants have responded to or incorporated NSRS recommendations.
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N Concern OW-85-001-002 should be considered generically applicable to d other sites because it was not determined if the other sites have 7 similar single failure documents to SQN.
1 3 Concern TAK-86-007 should be considered for generic applicability to 4 all TVA nuclear plants because the potential for inadequate exchange of j information could exist at any plant without proper procedural control.
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.- VI. References d
3 1. " Quality Assurance for Radiological Monitoring Programs (Normal j Operations - Effluent Streams and the Environment, USNRC Regulatory 2 Guide 4.15. Revision 1. February 1979 a
if 2. " Quality Control Program for Chemistry Instruments," INPO Good i Practice CY-701, May 1983
i 4. " Chemistry Analytical Data Review," INPO Good Practice CY-704,
.] February 1986 A
j:j 5. INPO Plant Evaluations 1981 through 1985 (including evaluator field notes for 1985)
J 6. NRC Inspection Reports 50-327/86-14 and 50-328/86-14, February 1986 50-327/86-02 and 50-328/86-02, January 1986 50-327/85-15 and 50-328/85-15, April 1985 50-327/84-16 and 50-328/84-16, July 1984 50-327/83-25 and 50-328/83-25 November 1983 l Page 11 of 13
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Ravision 2 VI. References (continued)
- 7. QA Audit 2-85-P-003
- 8. Deviation Report QSQ-A-84-0014-D03 and Follow-up reports ,
Nemorandum from Craven to Nullin "SQ-CAR-84-06-014 Escalation" dated December 17, 1985 (RINS LO4 851217 937)
Nemorandum from Nullin to Abercrombie, " Evaluation of Corrective Action Taken - Deviation Report Closure (RINS L17 860425 800)
- 9. US NRC Reg Guide 4.15. Quality Assurance for Radiological
, Monitoring Programs (Normal Operation - Effluent Streams and the Ravironment) Revision 1. February 1979
- 10. SQN SQE-22, Sequoyah Nuclear Plant Chemistry Program, Revision 3 April 29, 1986
- 11. SQN TI-20 Chemical Laboratory Test Equipment Calibration Program, Revision 19. June 27, 1986 l
- 12. Memorandum to H. L. Abercrombie from W. R. Brown dated July 11, 1986 on RCTG Element Reports (T25 860711 912)
- 13. Memorandum to H. L. Abercrombie from K. W. Whitt dated March 18, 1986, on NSRS Investigation Report
- 14. Memorandum to T. G. Campbell from T. D. Knight on NSRS Review of Division of Nuclear Power Water Quality Program
- 15. SQN-DC-V-2.16. General Design Criteria for Fluid and Electrical Safety-Related Systems I
- 16. Sequoyah FSAR Sections 3.1 & 7.1
- 17. 10 CFR 50 Appendir A
- 18. SQN MI-6.20, Configuration Control During Maintenance Activities.
Revision 9. August 11, 1986 i
i 19. SQN INI-134. Configuration Control of Instrument Naintenance Activities, Revision 3, September 5, 1985
- 20. SQN OSLA-58, Maintaining Cognizance of Operational Status, June 27, 1986
- 21. SQN AI-5. Shift Relief and Turnover, Revision 36, August 11, 1986
- 22. SQN AI-3, Clearance Procedure Revision 31, June 27, 1986 1
! 23. NSRS Investigation Report No. I-86-130-SQN, dated I February 12-20, 1986 i
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I Revisicn 2 VI. References (continued)
- 24. SQN TI-37, Chemical Laboratory Log System, Revision 28
- 25. SQN Technical Specifications
- 26. SQN Daily Chemistry Trend Charts, January-August, 1985
- 27. NSES Investigation Report I-86-132-SQN, March 31, 1986
- 28. NSRS Investigation Report R-82-08-NPS, February 22, 1983 l lR2 t -
- 29. NSRS Investigation Report R-83-26-NPS, February 9, 1984 l J
VII. Immediate or Long Term Corrective Action SQN has committed to implement corrective actions in response to l the following NSRS recommendations by July 1987. lR2
- 1. I-86-130-SQN-01 Resolution of NSES - Identified Deficiencies l SQN should take action to investigate and I correct the deficiencies identified in i NSES Report No. R-82-08-NPS. l
- 2. I-86-130-SQN-02 Resolution of All Other Deficiencies lR2 j hanagement attention should continue to l be focused on the area of chemistry until l all other current deficiencies are resolved. l 1
SQN should inform NSRS when corrective I action is complete." l SQN will reinstitute the requirement for the UO signature in IR2 NI-6.20 for work on equipment not covered by a clearance within l six months. (CATD No. 30711-SQN-03) l 9
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II PAGE -
REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIME -
FREQUENCY - REQUEST OFFICE OF NUCLEAR PONER RUN DATE -
- ONP - ISSS - RHM EMPLWYEE CONCERN PROGRAM SYSTEM (ECPS)
() LIST OF EWLOYEE CONCERN INFORMATION .
CATEGORY: OP PLANT OPER. SUPPORT SUSCATEGORY: 30711 'NANAGEMENT.NONRESPONSIVENESS KEYHORD A S GENERIC g H APPL STC/MSRS .
P KEYHORD 5
$ CONCERN KEYHORD C CONCERN SUB R PLT BBSW INVESTIGATION KEYHORD I HUMBER CAT CAT D LOC FLeB REPORT A DESCRIPTION SS A DIFFERENCE OF OPINION HAS IDENTIFI CORRECTIVE ACTI CH 001-002 OP 3071I N NSN YYYY PROGRAMMATIC K-FORM EB BETHEEN LINE MANAGEMENT AND NSRS
! T50246 REGARDING THE DEFINITION OF SINGLE F ENGINEERIN(
t AILURE CRITERIA. THIS 91FFERENCE WA GENERAL i
3 S DROPPED BY NSRS AND LINE MANAGEMEN T HITH NO RESOLUTION. NO FURTHER IN FORMATION IN FILE.
TAK-86-007 OP 30711 N SON NNNN NS SAFETY MARGIN WILL BE GREATLY AFFECT K-FORM ED BECAUSE SE/SRO IS SUSY AND DOES N OT INFORM LEAD U0 0F MAINTENANCE ACT IVITIES.
D NONDESTRUCTVE I 307Il N SON YYYY CHEMICAL AND RADI0 CHEMICAL DATA 0F P XX 116-001 OP 00R SUALITY AT SEQUDYAH CQULD BE VER RECORDS i T50271 K-FORM OPERATIONS Y COSTLY AND CAUSE EMBARRASSMENT TO D TVA. DETAILS KNOWN TO QTC. HITHHEL REPORTS
' D DUE TO CONFIDENTIALITY. NO FURTHE R INFORMATION MAY BE RELEASED. CI R E0UESTS THAT QTC PERFORM THIS INVEST D IGATION. NUCLEAR POWER DEPARTMENT C
' 'ONCERN.
TVA HAS EXHIBITED A LENGTHY DISREGAR PROGRAMMATIC O XX 116-003 OP 30711 N SQN YYYY I-86-130-SON CORRECTIVE A' T5027I K-FORM D T0HARD FULFILLING COMMITMENTS MADE j TO VARIOUS REGULATORY AND VENDOR OR GENERAL 1
GANIZATIONS WITH RESPECT TO CHEMICAL GENERAL
- AND RADI0 CHEMICAL DATA USED TO MONI i O TOR AND CONTROL OPERATIONS OF THE SE l 000YAH PLANT. NUCLEAR P0HER DEPARTM ENT CONCERN. DETAILS KNOHN TO QTC, HITHMELD DUE TO CONFIDENTIALITY. NO D FURTHER INFORMATION MAY BE RELEASED j . CI REQUESTS THAT QTC PERFORM THIS INVESTIGATION.
\ O AUDIT j XX 116-006 OP 30711 N SQN YYYY I-86-138-SON SEGUOYAH - RECOMMENDATIONS MADE BY Z CORRECTIVE A T50271 K-FORM NTERNAL TVA ORGANIZATIONS SUCH AS NS GENERAL R$ HAVE PRODUCED LITTLE RESULTS REGA GENERAL
' . RDING CORRECTING PRACTICES HHICH LEA O D TO CHEMICAL AND RADI0 CHEMICAL DATA 1
i 0F POOR QUALITY. NUCLEAR P0HER DEP ARTMENT CONCERN. DETAILS KNOHN TO Q TC, MITHHELD DUE TO CONFIDENTIALITY.
O NO FURTHER INFORMATION MAY BE RELE ASED. CI REQUESTS THAT GTC PERFORM l' THIS INVESTIGATION.
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0 TENNESSEE VALLEY AUTHORITY PAGE -
REFERENCE - ECPS120J-ECPSI2IC RUN TIME - -
- REQUEST OFFICE OF NUCLEAR PSHER FREQUENCY .
BFLOYEE CONCERN P900 RAM SYSTEM (ECPS) RUN DATE -
- 1 Q ONP - 1555 - RHM i LIST OF S FLOYEE CONCEAN INFORMATION SUBCATEGORY: 34711 m a m atENT NONRESPONSIVENESS ,
i CATEGORY: OP PLANT OPER. SUPPORT KEYWORD A g S DENERIC -
KEYNORD B N APPL STC/NSES P
$ CedCERN KEYHORD C CONCERN SUS R PLT BB$N INVESTIGATION KEYNORD D NUMBER CAT CAT 3 LOC FL45 REPSRT R DESCRIPTION SS SEGUSYAM-MANAGEMENT (KNOWN) HAS SIGN HONCONFORMAllCE XX 116-014 OP 30711 N S4N NNYY CORRECTIVE AC T50271 K-FORM EB 0FF SECONDARY NATER CHEMISTRY CON BITIONS THAT HERE IN VIOLATION OF TH ENGINEERINC E TECHNICAL SPECIFICATIONS HITHOUT N GENERAL g AVING AN ENGINEERING EVALUATION PERF ORMES IN VIOLATION OF SITE PROCEDURE
- 5. TINE PERIOD OF 1985. NUCLEAR PO NER CONCERN. DETAILS KN0HN TO OTC, g MITNNELB DUE TO CONFIDENTI ALITY. NO FURTHER INFORMATION MAY BE RELEASED
. CI REQUESTS THAT STC FiNFORN THIS INVESTIGATION.
3 6 CONCERNS F0k CATEGORY OF SUBCATEGORY 30711 D
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'. 2 TV2 EMPL@YEE CONCERNS REPORT NUMBER: 307.11-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 TITLE: Management Nonresponsiveness REASON FOR REVISION:
Revised to incorporate SRP and TAS comments and incorporate Revision 1 w
307.11(a) and 307.11(b)
Revised to incorporate SQN correctve action response Revision 2 PREPARATION PREPARED BY:
D. E. Smith 10-29-86 SIGNATURE DATE Q
,# REVIEWS PEER:
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/ SIGNATURE DATE
'W [ s SIGNATURE
//b bf DATE CONCURRENCES CEG-H: , , m- I l' $~ N SRP: s eaA ' , -t** l.5 86 SIGNATURE DATE SIGNATUREM DATE APPROVED BY:
- l lfb N/A ECSP MANAG 6 DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
MSRP Secretary's signature denotes SRP concurrences are in files.
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