ML20210H369
| ML20210H369 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/02/1987 |
| From: | Barlow D, Deangelis J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| 80504-SQN, 80504-SQN-R03, 80504-SQN-R3, NUDOCS 8702110417 | |
| Download: ML20210H369 (53) | |
Text
s a s
TVA EMPLOYEE CONCERNS REPORT NilHBER:
SPECIAL PROGRAM 80504-SQN REVISION NLIMBER:
REPORT TYPE 3
Element Report PAGE 1 0F 27 TITLE:
Quality Assurance Records
~~~~~
REASON F0t1 REVISION: Revised to incorporate SRP comments.
Revision indicators are shown in the right margin on each page.
Note: Sequoyah Applicability Only
~
PREPARATION PREPARED BY: D, G. Barlow /J. J. De Angelis
'k /->+-S1 l A '
wL ~
Y'Ws1 DATE
/ GNATURE (5 REVIEWS PEER:
k - / M
@ ATE' SIGNA $RE TAS: ,
L h, k 7 ,
g .
88Y7 DATE I SIGNATURE CONCURRENCES
~~~ ~
-- m / / /- ,_
ypf K/l'(-f ny ,s )r SRP mdf,// %- Z-2 7 DATE SIGNATilRE DATE /IGNATURE*[
APPROVED BY: ,. /. 7 N/A
/dd '
- D'ATS MANAGER OF NUCLEAR
~
0ATA l ECSP" M6MAGER l POWER '
CONCURRENCE (FINAL REPORT ONLY)
<S;tP Ne ro t .iry ' a signature denotes SRP concurrences are in files. J 8702110417 070205 PDR ADOCK 05000327 P PDR _
. )
l TVA EMPLOYEE CONCERNS REPORT NUMiiER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 3
Element Report PAGE 2 0F 27 TITLE:
Quality Assurance Records 1.0 CliARACTERIZATION OF ISSUES 1.1 Introduction ,
The issues described below were taken from employee concerns generated as a result of the Watts Bar Employee Concern Spec i'ai Program. The issues we re investigated and evaluated at the Sequoyah Nuclear Plant (SQN) since they were deemed to be site specific or to have generic applicability to SQN.
1.2 Description of Issues The conditions reported (Attachment A) by concerned employees are:
- a. Controlled documents contain conflicting or ob solete data or both. (SQM-86-002-005, SQM-86-002-006, SQM-86-003-002)
- b. Work which had been per formed had not been approp riately documented. (SQM-86-011-002) material control. Traceability of mquirements and
- c. Poor materials is inadequate and pape rwork for quality records is poor. (XX-85-122-04 2)
- d. The retrieval of Quality Assuraxe (QA) records is inadequate and (IN-8 5-357-001, SQM-86-002-001, records are not identi fiable.
SQP-86-002-001, and WBP-86-009-001)
(IN-85-612-XO7, XX-
- e. Welder Certification records were alte red .
85-088-X04)
~
NOTE: Falsification of Welders' Qualification Records will be addressed seperately by TVA Of fice of Inspector General.
Maintenance Requests (MRs) which specified the addition of grease
- f. _
were signed off as being for Limitorque valve ac tua tors unnecessary or being complete even though no work was performed.
Non-QA material was installed in QA applications and traceability was falsified on the MR. (J LH-86-001)
- g. Quality Assurance (QA) documents were lost by the vault personnel and regenerated by the responsible unit. (IN-85-091-001)
Inspection records may reflect improper data. (SQM-86-009-X04) h.
i TVA EMPLOYEE CONCERNS HEPORT NilMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVLSION NUMBER:
Elemen t Report 3 TITLE: PAGE 3 0F 27 Quality Assurance Records 2.0 SUM!!ARY 2.1 Sumary of Characterization of Issues Tim sc issues we re grouped in to the element of Quality Assurance Records since they indicated that quality documents have been lost, regenerated, altered and conta ined conflicting or obsolete data or both. The issues also indicated that the QA records are not identifiable or retrievable.
2.2 Sumraary of Evaluation Process
' The evaluation process consisted of a search of the available concerns files and reviews of regulatory requirements and industry standards. m Likewise, reviews were made of the TVA upper tier requirement [
documents such as the Topical Report, Nuclear Quality Assurance Manual [
and Final Safety Analysis Report together with lower tier implementing L documents such as procedures and instructions to determine requirement s , commitments and responsibilities. Reviews of associated documentation and field verification along with discussions with cagnizant personnel were also performed as part of the investigation af the issues.
A listing of the document s utilized in the investigation and evaluation process for this Element Report is included as Attachment B.
2.3 Suttnary of Findings 2.3.1 Issue - Controlled documents contain conflicting or obsolete data or both.
The Employee Concern file provided clarification of this issue which directed this investigation in to the area of vendor design drawings (mylars) and the system for requesting duplicate original drawings. This replacement appears to be ma inly for those vendor drawings received prior to 1976 when site copies of these drawings were routinely discarded. Thus, there was the need at the site for wash-offs (a wash-o f f being a replacement original from the aperture card in Knoxville).
There is a potential for the two " originals" to contain ob sole te or conflicting data when one d rawing is updated and not the other. Conflicting data occurs when a replacement for an original d rawing is used as the baseline drawing for subsequent changes and the missing drawing reappears and is not properly dispositioned. Controls are now in place to avoid lost and duplicate drawings.
5
i
- 1. , ,
TVA EMPLOYEE CONCERNS REPORT NilMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE 3
Elenm t Report PAGE 4 0F 27 TITLE:
Quality Assurance Records The Employee Concern file also provided clarification of another concern dealing with this issue which d irec ted this investigation to a specific wiring diagram mylar which was Failure to log-issued twice with the same revision number.
out the first release of Revision 8 also created the potential for two mylars to contain obsolete or conflicting data when one drawing is updated and not the other. This appeared to be an isolated case and was due to the relocation of the SQU Engineering Project to the site with new clerical personnel in the Drawing Control Center. Procedures are adequate and additional training has been provided in the area of drawing control and issue. ,
2.3.2 Issue - Work which had been performed had not been appropriately documented. (Environmental Qualification of Equipment)
The invertigation of the issue dealt with the actual employee concern which said that Sequoyah was shutdown in August 1985 due to a failure of a group to appropriately document work which had been performed. This investigation determined the concern was valid as Sequoyah was shutdown in August 1985 due to questions about the env ironmental quali fica t ion of e lec tr ic al equipment. The SQN Nuclear Per fo rmance Plan specifies the correct ive :tions to be taken by SQN for Environmental Qualificatio .
2.3.3 Issue - Poor material control. Traceability of requirements and materials is inadequate, and paperwork for quality records is poor.
The investigation of the issue of poor material traceability /
control, inadequacy of requirements, and inadequate quality rec ord s provided evidence that the major problem in material control was inadequate in s tructions or failure to follow procedures and instructions. Examples of imprcper t raceabili ty of quality requirements for materials received we re also found along with examples where traceability of paperwork to actual hardware could not be established.
The Material Control CEG has performed extensive investigations in the hardware areas of material control and has reported their findings separately.
2 . 'l . 4 Issue 'Ihe retrieval of QA records is inadequate and records are not identi fiable.
The investigation of an inadequate QA record s re tr ievable aystem at SQN was rev iewed for Construction and Ope ra t ion QA
8 s TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 3 TITLE: PAGE 5 OF 27
. Quality Assurance Records re c o rd s. Record retrievability was found to be inadequate for contruction records since the document retrieval system is not fully operational. However, the retrieval of operation QA records (those needed for operations phase) was found to be adequate.
2.3.5 Issue - Welder certification records were altered.
The investigation of the issue of welder certifications being altered provided evidence of various types of documentation errors. 'Ihe re was evidence of Corrective Action Requests (CARS), De ficiency Reports (DRs), and Survey. Checklists also having been written which deal with altering welder records.
2.3.6 Issue - Maintenance Requests (MRs) which specified the addition of grease for Limitorque valve actuators were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications and traceability was falsified on MR.
The investigation of the issue produced evidence that all SQN Unit 2 Limitorque valve actuators have been inspected and that the actuators have been properly greased in accordance with the maintenance procedure.
2.3.7 Issue - Quality Assurance (QA) docume,nts were lost by the vault personnel and regenerated by the responsible unit.
The investigation into the issue of quality documentation being lost by the vault personnel and later regenerated by the responsible unit found no evidence of this condition having been documented. at SQN.
When lost documents were identified at SQN, QA personnel did not document the condition. In such cases, the records storage vault personnel identified the documents to the responsible unit and a duplic a te copy was few.i shed for storage.
1
'!.3.8 1ssue - Inn,pec tion records may re flec t improper data.
'Ihe issue that inspection records may contain conflicting data was not addressed within the scope of the Quality Asrurance Category Evaluation Group (QACEG) evaluation. "Ih e concerned ind iv idual (CI) was not specific to the type of data or inspection records that may coata in conflicting data.
Additiona lly, the Employee Conce rr. and Con fid en t ial Files contained no in forma t ion that iden ti fied the spec i fic i n espec t ion records or data that would spec i fy the subject of I
I
. . i TVA EMPLOYEE CONCERNS REPORT NllMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
- Element Report - 3 .
-TITLE: PAGE 6 0F 27 Quality Assurance Records the etaployee concern. Also, Nuclear Safety -Review Staff (NSRS) Investigation Report 1-86-241-SQN was assigned .to Employee Concern SQM-86-009-X04.- _However, a NSRS Report was never issued.
2.4 Susanary of Corrective' Actions 2.4.1 Issue - Controlled documents contain conflicting, or obsolete data or both.
Corrective actions taken to date includes
~
- a. Procedural guidance in Sequoyah Engineering Project (SEQP)
Project - - Manual dated September 1985 provides tighter control over design ac tivitie s. Training of newly arriving - clerical personnel- has been 'given in procedural requirements for drawing control and supervision has been ~
increased for the drawing issue process.
b .- Wiring Diagram 45N1749-30 has been revised to reflect the correct data and -drawing log corrected to reflect proper revision.
2.4.2 1ssue - Work which had been performed had not been appropriately documented. (Equipment Qualification Program)
The Equipment Qualification (EQ) Project'was formed with the re sponsibility for development and implemen tat ion of an EQ Program. Work- is ongoing by the project to resolve the equipment qualification problems. SQN has connait ted to this ac tivity completed prior -to start-up.
2.4.3~ Issue - Poor material control. Traceability of requirements and materials is inadequate and paperwork for quality records is poor.
Corrective actions taken to date include:
Audits, increased SQN Plant QA Staff surveillanc e , TVA Management attention, and personnel awareness over the entire ;
material control area which appears to be adequate.
2.4.4 Issue - The retrieval of QA records is inadequate and records are not identifiable.
Corrective actions taken to date include:
- a. Established a work force to index a nd microfilm construction records, vendor documentation, d raw i ngs and manuals for SQNP Units 1 and 2. I 9
-- n o: * ,
TVA EMPLOYEE CONCERNS REPORT NUMEER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
3 Element Report TITLE: PAGE 7 0F 27 Quality Assurance Records
~
- b. Developing new and revised procedures and instructions to de fine organizational responsibilities and in ter f ace require ment s with o ther departments. These procedu re s will also include the methods of maintaining, storing, and
. controlling vendor QA records.
The above activities are currently ongoing and the schedule ,
for completion of these activities is December 1988.
2.4.5 Issue -_ Welder certification records were altered.
Corrective actions taken to date include: .
Correc tive Action Report (CAR) CAR-SQN 85-09-014 was written I and dispositioned as - "all SQN active welders' files to be reviewed and welders re-quali fied to current re quire me n t s. "
This CAR has been closed and all corrective actions have been verified as being complete.
2.4.6 lasue - Maintenance Requests (MRs) which specified the addition of grease for Limitorque valve actustors were signed off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications and traceability was falsified on the MRs.
Corrective actions taken to date include:
All Sequoyah Unit 2 Limitorque valve actuators have been inspected and verified that they have been properly greased.
2.4.7 Issue - Quality Assurance (QA) documents were lost by the vault and regenerated by the responsible unit.
No corrective actions required.
3.0 LIST OF EVALUATORS W. M. Akeley D. G. Barlow
.J . .I . De Ange lis i l
J. E. Mann i
l l
TVA EMPI,0YEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Elemen t Report 3 TITLE: PAGE 8 0F 27 Quality Assurance Records 4.0 EVALUATION PROCESS 4.1 General Methods of Evaluation The evaluation p'rocess consisted of researching the Employee Concern files, Quality Technology Corporation (QTC) file s , and Nuclear Sa fe ty Rev iew Staff (NSRS) file s to dete rmine if additional information was available to assist in the investigation of issues associated with this element.
Reviews were conducted of regulatory requirements and industry standards together with upper tier requirements, documents such as the TVA QA Topical Report and the Nuclear Quality Assurance Manual, along with lower t ie r implementing documents such as procedures and instructions to determine requirement s , consnitments, and responsibilities. Documentation in the form of quality audit reports, survey checklists, inspection reports, Field Change Requests (FCRs),
Significant Condition Reports (SCRs), Nonconformance Reports (NCRs),
Discrepancy Reports (DRs), Ma intenance Request s (MRs ) , work pl::ns ,
micro film records of inspec t ions / te sts and computer status reports were also reviewed. The above documentation together with personnel discussions provided the basis for the conclusions reached.
4.2 Specifics of Evaluation This section describes the specific methodology used relating to the foIlowing issues:
4.2.1 Issue - Controlled documents contain conflicting, or obsolete data or both.
The Employee Concern file s were researched to determine if Qua lity Technology Company (QTC) and/or the Nuc lear Sa fe ty Rev iew Staff (NSRS) had investigated and reported on the issue. The following NSRS reports we re eva lua ted by the Quality Assurance Category Eva lua tion Group (QACEG) to determine the adequacy of the scope and the re su lt s of their invptigation.
- a. NSRS Investigation Report I-86-185-SQN for Employee Concerns SQM-86-002-005 and -006.
- b. NSRS Investigation Report I-86-180-SQN for Employee Concern SQM-86-003-002.
There were no QTC reports available.
The QA Topical Report TVA-TR75-1 A Revis ion 8, and the Nuc lea r quality As su ra nc e Manual (NQAM) Part III, were re v iewe<l
=
O 1 4
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
REPORT TYPE
' Element Report 3 TITLE: PACE 9 OF 27 Quality Assurance Records together with site prac tices, procedures, and polic ie s to determine the requirements and commitments during the time frame the concerns were reported.
~
A review was made of the Wiring Diagram, Field Change Requests (FCRs), . Significant Condition Reports (SC Rs) , and Engineering Change Notices (ECNs) which document . specific data relating to the concerns of record.
Discussions were held with personnel in the Document Control Unit (DCU) to develop the historical background and current events pertaining. to the subject issue. .
4.2.2 Issue - Work which had been performed had not been appropriately documented. (Environmental Quali fication of Equipment)
The Employee Concern files were researched to determine i f QTC
[
l and/or NSRS had investigated and reported on the issue. .NSRS Investigation Report I-86-270-SQN was assigned to Employee Concern SQM-86-Oll-002. However, a NSRS Report was never issued.
' A review was made of Regulatory Requirement NUREG-0588, i " Interim Staff Position on Environmental Qualification of Sa fety-Related Equipment"; Industry Standard IEEE 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Gene ra ting Stations"; Topical Report TVA-TR75-1A, Final Sa fe ty Analysis Report (FSAR) Section 3.11, Code of Federal Regulations 10 CFR 50.49, Janua ry 1, 1985 Edition,
" Environmental Qualification of Elec tric Equipment Important l
l.
to Sa fe ty for Nuclear Power Plants"; and the Nuclea r Quality I Assurance Manual (NQAM), Part II, to determine the requirements and commitments during the time -frame the concerns were reported. Environmental Qualification Documentation packages including test results were also reviewed to form a basis for the conclusions reached.
Discussions we re held with various site personnel to develop the historical background and other in forma t ion pe r ta ining to the subject issues.
i 4.2.3 1ssue - Poor material control. Traceability of l
requirements and materials is inadequate and paperwork for quality records is poor.
The Employee Concern files provided NSRS Investigation Report 1-85-987-SQN dated 3/4/86. This report was evaluated by QACEG u dete rmine the adequacy of the scope and the resalts of the NSRS investigation.
TVA EMPLOYEE CONCERNS REPORT NUMBER: ->
SPECIAL PROGRAM 80504-SQN REVISION NUMBER:
- REPORT TYPE 3
Element Report' PACE 10 0F 27
. TITLE:
- Quali ty Assurance Records
~
Regulatory- Guides 1.33, 1.38, and 1.123, the Topical Report TV A-TR7 5-1 A Section 17, the Final Sa fe ty Analysis Report (FSAR), the Nuclear Quality Assurance Manual (NQAM) Parts II and - III were rev iewed together with Site Instructions AI-7, AI-ll, AI-12, AI-36, Standard Prac tices SQA45, seven '(7)-
su rvey checklist s , seven (7) Audit Reports, and tuo (2)-
additional -NSRS Reports to determine the commitments, requiremen ts and audit re sult s written during the time frame the issue were reported.
SQN Element Report MC-40703, Revision 0, dated 9/26/86 issued by the TVA Employee Concern Special Program Gr.oup was rev iewed for additional information relating to the issue.
4.2.4 Issue - The retrieval of QA records is inadequate and records c are not identifiable.
The Employee Concern files and the Confidential Sensitive files were researched to determine if they contained additional in forma tion regarding this issue. The files provided the following:
- a. NSRS Investigation I-86-126-SQN was assigned to Employee Concern SQM-86-002-001. However, a NSRS Report was never issued.
- b. NSRS Investigation Report I-86-129-SQN was issued March 3, 1986 for Employee Concerns SQP-86-002-001 and WBP-86-009-001.
Note: Part of the issue included in Employee Concern SQP-86-002-001 re fe rences NSRS Reports I-83-13-hPS and R-8 5-07 -NPS . These NSRS Reports we re used to identify the specific issue (s) of the concern only, and for this reason, the reports are not attached to this Element Report.
NSRS Report I-86-129-SQN was evaluated by QACEG to d ete rmine the adequacy of the scope and the results of the NSRS investigation.
The QA Topic al Report TVA-TR75-1A, the HQAM, and site p ract ice s , procedures, and policies were reviewed to determine the compliance criteria during the time frame the concerns were-reported.
The QA Auditing Branch files in Chattanooga were rev iewed to determine de fic ienc ies identified by aud it s relating to the issue.
5 TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REVLSION NUMBER:
REPORT TYPE .
3 Elemen t Report PAGE 11 0F'27 TITLE:
Quality Assurance Records A review was also conducted of the various fo rms of nonconforming conditions which were documented to dete rmine the types of deficiencies that relate to the issue.
Discussions were held with various site personnel in the Record s Management and QA Vault areas to develop historical background and other additional information pertaining to the-subject issue.
4.2.5 Issue - Welder certification records were altered.
- lhe Employee Concern files provided two Employ,ee Response Team (ERT) Reports by Quality Technology Company (QTC) dealing with this subject (ERT Reports IN-85-612-X07 dated 10/24/85 and XX-85-088-X04 dated 3/4/86). Although the ERT report dated 10/24/85 was evaluated , for WBN, the QACEG has determined this issue to be generically applicable to SQN and the results of the investigation at Sequoyah are included in this report.
Also, NSRS Investigation Report I-E6-120-SQN was assigned to Employee Concern XX-85-088-X04. However, a NSRS Report was never issued.
Site Procedures QAP 17.2 and Adminis trative Instruction AI-7 we re reviewed to determine the compliance requirements during the time frame the concerns were reported. Also reviewed were six Survey Checklists, three Corrective Action Reports (C ARs ) ,
and six Discrepancy Reports (DRs) dealing with welder qualifications.
A review was made of the welder certification documentation wh ich is on microfilm and currently stored in the permanent record re tention system and hard copies of Nuclear Power We lder Je rti fica t ion documentation which is stored in the Solar Building.
Discussions were held with variou s e,ite Rccorda Management develop historical background and o the r personnel to l additional information pertaining to the subject issue.
4.2.6 Issue - Maintenance Requests (MRs) which specified the addition of grease for Limitorque vaIve actuators were s igned off as unnecessary or complete even though no work was performed. Non-QA material was installed in QA applications and traceability was falsified on the MR.
Research of the Employee Concern files and NSRS files was dete rmine if additional in fo rma t ion was conducted to available. One NSRS Report was issued in February 1986 which a.l.lresel this issue.
- - - - - - _ . =
i TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 3 TITLE: PAGE 12 0F 27 Quality Assurance Records A review was per formed of the EC'IU Operations CEG Element Report (30840-SQN dated 9/12/86) for additional in forma t ion since their investigation dealt with part of this issue.
A review was also performed of the NQAM Part II, Maintenance Instruc tion MI-10.46 and Standard Practice SQM2 to d ete rmine the commitments and requirement s surrounding the issue.
Discussions were also held with the site QC inspec t ion personnel who performed the Limitorque valve research.
4.2.7 Issue - Quality Assurance (QA) documents were lost by the vault and regenerated by the responsible unit. ,
A review was per formed of the Employee Concem and the Con fidential Files to determine if QTC or NSRS had investigated the issue and if the files could provide additional in formation regarding this concern. It was found that QTC . had evaluated this conce rn and issued Report No.
-IN-85-091-001 dated 9/16/85.
The NQAM, site prac tices , and procedures we re reviewed to determine the compliance criteria during the time frame the issue was reported.
The Noncon fo rma nce Reports (NCR) Log was reviewed for any information identifying lost QA documents or records.
Discussions were held with various site QA and Document Control Unit (DCU) personnel to develop in format ion re la ting to lost QA documents.
5.0 FINDINGS The following addresses both a background discussion and a conc lu sion of each issue as identified in Section 1.2.
5.1 Issue - Controlled documents contain conflicting or obsolete data or bath.
5.1.1 Discussion Two reports (I-86-185-SQN and I-86-180-SQN) we re issued by NSRS of which the above issue is a part. Our investigation and this report will discuss each NSRS Report separately.
5.1.1.1 NSRS Report I-86-185-SQN NSRS Report I-86-18 5-SQN dated March 1986 desc ribed the investigation of Vendor Drawing Control where five
TVA EMPLOYEE CONCERNS. REPORT NUMBER:
'SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
. Element Re por t 3 TITLE: PACE 13 0F 27 Quality Assurance Records Employee Concerns we re invest igated by NSRS of which this issue was a part..
The NSRS Report included a clarification of the issue which was provided to NSRS by QTC which said that SQN design drawings (mylars) were issued by the Of fice of Engineering Reprographics, Knoxville.
Our investigation there fore, dealt ' with ~ interviews of drawing control personnel at SQN and centered around the process of requesting duplicates and dete rmin ing how conflicting data could exist. .
If an original vendor drawing cannot be located and the sign-out log does not indica te that the drawing was removed from the file, the Drawing Control ' Unit will request a "wa sho f f" from the Technical In forma tion Center (TIC) at. Knoxville. The rep lacement drawings are re ferred to as "wa sho f f s " .
This "washoff" is _ issued as a "new original" and has the potential' of placing in circulation two original drawings which cou ld conta in conflic ting data. This happens if the first issued drawing shou ld reappear and is not properly noted in the drawing file.
'Ihe replacement of duplicate or " wash-off" drawings appeared to be primarily to those vendor drawings received at SQN prior to 1976.
Discussions with Drawing Control personnel confirmed that these site drawings were discarded and thet it l was possible for two original vendor drawings to be in I circulation with conflicting data for the reason noted
. above although this investigation did not find where this happened. To avoid th is , the' Drawing Con trol personnel are now required ' by procedure to place a notation in the drawing check-out - file that a "new orig ina l" has been requested. Sub sequent ly , if one vendor drawing reappears at Drawing Cor. trol, the c le rk is immediately ale rted to the existence of the duplicate drawing. '1he c lerk, with the assistance of engineering, will de te rmine the correc t drawing to retain, then eliminate the obsolete drawing from the record s sy st em. To verify the control of this l- par t icu lar d rawing act iv i ty, QACEG con firmed the i
implementation by reviewing the vendor drawing l checkout files and found five containing the no ta t ion "new originals" on the replacement drawings.
i
TVA EMPLOYEE CONCERNS REPORT NUMBKR:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 3 TITLE: PAGE 14 OF 27 Quality Assurance Records Controls are now in place to avoid lost and duplicate drawings in existence with incorrect data.
5.1.1.2 NSRS Report I-86-180-SQN NSRS Report I-86-180-SQN dated February 1986 described the investigation of Sequoyah Drawing Control. .Six Employee Concerns were investigated of which the issue noted above and investigated by QACEG was a part.
The NSRS Report also included a clarification of the issue which was provided to NSRS by QTC, which said that drawing 45N1749-30 (R8) was issued twice on separate my lar s . The Mylar drawings we re issued on November 29, 1985 and November 30, 1985, re spec tively.
The investigation in the Drawing Control area included a review of the SQN mylar drawing number 45N1749-30, Revision 8, Engineering Change No t ic e (ECN) L6202 and L6544, Field Change Notice (FCN) 3585 and 3966, and Significant Condition Report (SCR) SQN SQP-8601, Revision 0.
This review con firmed the NSRS report that mylar drawing number 45N1749-30 was issued twice as revision
- 8. The first issue was for ECN L6202/FCR3583 dated 11/29/85, and the second issue was for ECN L6544/ FCR 3966 dated 11/30/85. Fa ilure to adequately log-out the first release of Revision 8 mylar on Novembe r 29, 1985 created the potential of obsolete or conflicting data when one drawing is updated and not the other.
As a result of the NSRS investigation this Cond i t ion Adverse to Quality (CAQ) was reported on SCR No. SQN SQP-8601, Rev is ion 0, dated 1/11/86. The wiring diagram has since been corrected to re f lec t the correct data and the drawing issue log has been updated.
Our discussions with Document Control personnel indica ted that the condition happened because of inexperience of new cle rical personnel in the changeover from the Engineering Project Of fice in Knoxville to the site of fice and lack of attention by the new personnel to the Eng ineering Change Na t ic e ,
Field Change Request a nd drawing issue process.
Correc t ive actioas have been init ia ted by TVA to prec lude this from happening in the fu tu re .
Additional supervision has been assigned to the DCC to control the issuance of drawing.
\
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPOR'r *I"l?E REVISION NUMBER:
Element Report 3 TITLE: PACE 15 0F 27 Quality Assurance Records 5.1.2 Conclusion The issue of controlled documents containing conflic ting or obsolete data or both is considered valid. The QACEG investigation and evidence produced verifies the results obtained by NSRS. The NSRS Reports are conside red f ac tua l. There did exist the potential for two " original" vendor drawings to exist. Iloweve r, there now are adequate controls in effect to prevent this from occuring.
This investigation also found evidence to- support the conc lu sion in that the wiring diagram was issued twice with the same revision number. This ap' pea red to be an isolated case having happened as a result of inexperience of new employees. Procedures governing the issuance of drawings are adequate and additional training has been provided.
5.2 Issue - Failure to appropria tely document work which had been per formed.
5.2.1 Discussion, The issue raised was "Sequoyah was allegedly shut down in August 1985 due to the failure of a group to appropriately document work which had been per formed". Records indicate that SQN was shut down in Augus t 1985 because TVA determined that they would not be in full complia nce with regu la to ry requiremen t 10 CFR 50.49 by November 30, 1985. On that basis, it was concluded that the concerned employee was referring to the Environmental Qualification (EQ) documentation. A review was made of the revised Sequoyah Nuclear Per fo rma nce Plan dated July 1986 to de te rmine the background associated with the plant shut-down. A review was also performed of the regulatory requirements in 10 CFR 50.49 to e s tab lish those requiremants which TVA is committed to comply with. The Nuclear Per formanc e Plan,Section III, Pa ragraph 1.0 stated the following:
"The env ironmental qualification of e lec tr ic equipment required to ensure reactor coolant pre s su re boundary integrity, shut down the reactor and maintain it in a sa fe shut-down condi t ion, and prevent or mitigate the consequences of accidents that cou ld result in o f f-s ite exposures comparable to the 10 CFR part 100 guidelines is required by 10 CFR 50.49. It is further required that the eva lua t ion of environmental qualification be documented and maintained in auditable files. The date required by NRC for full compliance with 10 CFR 50.49 was November 30, 1985.
.. + , g TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Repor t 3 TITLE: PAGE 16 0F 27 Quality Assurance Records TVA conducted a management review of the environme nta l quali fication programs of SQN, BFN, and WBN in July and August 1985. This review indicated that much of the qualifica tion documentation wa s _ no t fully auditable and, in some cases, the documentation available did not demonstrate full qualification. ,
The cause for the failure to comply in a timely fa shion with 10 CFR 50.49 requirements was a lack of management attention to the environmental qualfication program.
The SQN was shutdown voluntarily at the direction of the Manager of Nuclear Power with the concurrence of the TVA Board of Directors in August 1985.
Subsequent to the voluntary shutdown of Sequoyah, the Equipment Qualification Project (EQP) was formed with the responsibility for development and implementation of an EQ p rogra m. Responsibility for engineering act ivities associated with environmental quali fication is pre sently assigned to Divis ion of Nuclear Engineering (DNE) and detailed re sponsib ilitie s , scope, organization, specific project procedures, and project training program are de fined in the project manuals for EQP and Sequoyah Engineering Project (SQEP)."
Standard Prac tice SQA173, "Sequoyah Nuclear Plant 10 CFR 50.49 Environmental Qualification Program," describes the overall program for achieving full compliance with 10 CFR 50.49.
5.2.2 Conclusion The issue is sub st ant ia ted . However, adequate attention is being paid by TVA to identify and correct the de fic iencies wuich TVA has committed to complete prior to start-up.
5.3 Issue - Ma ter ial control is poor. Traceability of requirements and ma te r ia ls is inadequate; paperwork for quality records is poor.
'i . ') .1 Discussion 4
The Employee Conce rn s files con ta ined a comp rehensive NSRS report on the material control activities at SQN. The NSRS report addressed the points raised in the subject issue. This inve st iga t ion dealt with verifying the validity of the findings noted in NSRS Report 1-85-987-SQN dated February l.
1986.
i
- .. =
q
~ TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Elemen t Report 3 TITLE:- PAGE 17 0F 27 Quality Assurance Records The QACEG considered the mate rial control is s'ue - from a programma tic po in t. Material Control CEG is addressing - the hardware issues and is reporting on these separately.
All the - documents . rev iewed by both NSRS and QACEG were generated during the operational phase as construction was essentially complete at the time the concern was generated.
The requirements for material control, traceability and quality records at SQN are based upon Appendix B to 10 CFR 50, Regula tory - Guid es 1.33, 1.38, 1.123, and 1.88, the TVA Topical Report and NQAM, Parts II and III, toge ther with the Administrative Instructions AI-7, AI-11, AI-12 and AI-36 and Standard Practices (SQA45). The NSRS findings were reviewed against the above requirement documents.
A selection was taken of all the documents used in the NSRS investigation and a review was performed by QACEG of their content to independently verify the NSRS results. The - Quality Assurance ' Category Group (QACEG) reviewed seven Surveillance Reports, seven audit reports, two Corrective Action Reports (CARS), _ and nine De ficiency Reports ( DRs ) . These documents dealt exclusively with the material control act ivitie s. The reviews produced evidence of a significant numbe r _of de ficiencies (conditions adverse to quality) dealing with inadequate instructions being available and failure of personnel to follow those instructions which were in place.
During t'he period 1981 through 1985 (when the above - noted Conditions Adverse to Quality were , reported), NSRS compiled data on 15 instances of inadequate instruc tions to maintain adequate material control. Likewise NSRS data revealed 134 instances at tr ibu table to failure to follow the instructions which were in place.
The NSRS data dealing with traceability of requirements indica ted 49 conditions whe re the re was inadequate traceability of requirement s (those no ted on procurement
! documents) to the material received. It was also found that i there were 97 conditions noted in the reports relating to
[ improper traceability of pape rwork and materials. That is, maintaining traceability of documentation and material through
- the entire cycle of receipt, installation and operations.
! In researching the allegation of poor quality records the NSRS data indicated 99 conditions being reported relating to inadequate documentary evidence of the quality of the ma ter ial.
j
. . . .. .. __ __ . ~ . _ _ .__ ~ _ . _ _ . _ _ . _ . __ __ _ _ _ --
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
3 Element Report TITLE: PAGE 18 0F 27 Quality Assurance Records In addition to verifying the validity of the NSRS find ings ,
the QACEG investigation performed an evaluation of the areas covered by the Quality Assurance Audit Branch audits and site surveys ( surveillance s) and found that the depth and coverage was adequate to form an objec tive evaluation of the condit ions.
5.3.2 Conc lu sion By re searching and reviewing the sample numb ers of reports noted above and our ind ependent verification the QACEG has dete rmined , in agreement with the NSRS, that the issue raised by the concerned individual is valid. However, there appears to be a decline in incidents of poor material control and related quality records. This was concluded due to the reduced number of findings reported in recent audits and surviellance s . The QACEG investigation has found that the SQN QA Surveillance Staff has increased their effort of surveillance over the material control activities and it is ongoing.
TVA has directed considerable attention in the years 1985 and 1986 to the improvement in the control of materials at SQN.
This has been verified by reviewing audits and surveillance reports of the Quality Assurance Surveillance Section. There appears to be a downward trend in the number o f conditions adverse to quality which are being found. Audits, increased surveillance by SQN Plant QA Sta ff, TVA Management attention, and personnel awareness seem to have had an ef fect on reducing incidences of improper control of material and re la ted documentation. Corrective actions as a result of Element Report 40703 will also reduce the incidences of improper material control.
5.4 Issue - SQN records retrievability is inadequate.
The concerned employee alleged that the retrieVabilty of SQN QA records generated during both the construction and the operational phases is inadequate. Subsequently, the findings and conc lus ions contained here in are discussed separately for the retrievability of quality related construction and operation records.
5.4.1 Retrievability of Quality Related Contruction Records.
5.4.1.1 Background The Record s Retrievability Indexing (RRI) system fo r QA construction records was add re s s ed in NSRS Investigation Report 1-86-129-SQN and the issue was
.o .
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Elenint Re por t 3 TITLE: PAGE 19 0F 27 Quality Assurance Records reported to be substantiated. The NSRS Report identified that SQN QA construction records including vendor drawings and manuals have not been comp le te ly entered into the records retrieval system. Since the current RRI for QA construction records and the vendor drawings and manuals are less than 50 percent imple e nted , the records re trievability system was considered to be unreliable and incomplete.
5.4.1.2 Discussion The overall re sult s of the QACEG investigation indica ted that QA construction records were retrievable ; however, the method was considered slow and unpred ic ab le. TVA management recognized this condition in early 1983 and since have been working to provide a complete index and document location on mic ro film for each QA construction record for SQN Units 1 and 2.
During the same period, the Vendor Drawing and Manual Control Program was cons ide red by TVA to be a potential p rob le m. TVA surveillance groups had identified the following conditions relating to vendor drawings and manuals:
- a. Vendor drawings and manuals we re unorganized and dif ficult to re trieve.
- b. Vendor drawings and manuals were not controlled relative to the "as designed" specifications.
On February 22, 1984, the Quality Engineering Bra nch (QEB) initiated a Noncon formance Report (NCR) No.
GENQEB8401 describing a deficient condition involving inadequate indexing and ine f fec tive retreivalibicy of vendor QA records. The corrective action measures for the CAR included the revising of In te rd ivis ional Procedures ID-QAP 17.1, " Transfer o f Quality Assurance Records", ID-QAP 17.2. " Quality Assurance Records for Design and Cons t ruc tion", and QEB-EP 24 .37, " Product Compliance Data and Quality Engineering Records Indexing and Pre para t ion". Ve ri fic ation a nd final comp le t ion of this CAR was performed on August 28, 1984.
In early 1985, the Office of Nuclear Power (ONP) conducted a rev iew of the RRI for QA construction records and dete rmined several areas to be deficient.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 3 TITLE: PAGE 20 0F 27 Qua1ity - Assurance Records A task force was established to deve lop recommendations, including the revising of instructions and procedu re s for each quality re la ted construction QA record. This revised retrieval system for QA construction records under new and revised guidelines has no t been fully implemented by SQN at this time. TVA Record Management personnel are presently in the process of iden ti ficat ion, indexing, and providing film locators on each construction QA record.
The purpose of the investigation by QACEG of the RRI system for QA construction records was first to evaluate the present retrievability system and second, to determine the present status and the schedu led comple tion dates for the implementat ion of SQN construction QA records.
The QACEG investigation of the present RRI for QA construction records involved the selection of 15 Cable Tray Inspection Reports for SQN Unit I and four llanger/ Support Inspection Reports for SQN Unit 2.
These completed construction records we re transmitted by Quality Control to the Master Files for en try in to the RRI. The pre sent re trieva l method for construction records is controlled by the system number located on the micro film reel. The specific record must be located by scanning each frame until the desired document is located. This method involves the po ssible scanning of approximately 4,000 f rame s per reel to locate the desired document. The results of the investigation revealed that 18 of 19 inspection reports were retrievable and one Cable Tray Inspection Report could not be located. 'Ih e retrieval process for these records was accomplished by one individual in approximately six hours.
TVA's highest tier QA Prog ra m Manual, the Topical Report TVA-TR75-1A, Revis ion 8, Section 17 requires that a records index and re tr ieva l system be e s tab lished to as su re that Quality As su rance Records are id enti fiable and retrievable. Although the Construction QA Records, including Vendor QA Reco rd s ,
we re available, the d ocument s we re not indexed to a
, degree of reliable retrievability.
The current RRI for QA Construction Reco rd s when completed will be capable of retrieving documents more e f fic iently by means of identi fy ing document s by reel i
g TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 3 TITLE: PAGE 21 0F 27 Quality Assurance Records
.E and frame number. This method will provide direct access to a specific document on each - reel . During the discussion with -the Supervisor of the SQN Cons truc t ion Records Project, it was determined that the Const ruc tion QA Records portion of the RRI was approximately 25-30 percent complete and final completion scheduled for December of 1988.
The SQN QA Staf f initiated a Corrective Action Report-(CAR) SQ CAR-86-01-004 dated January 30, 1986 addressing a condition contrary to the requirements of Admin is tra tive Instruction, AI-23 and the Nuclear Quality As surance Manual (NQAM) Part V. This CAR noted numerous vendor drawings and manuals contained in the SQN Environmental Qualification (EQ) Binders that were inconsistent with the information identified in the plant con trolled Drawing Management System (DMS). The disposition for the CAR has not been resolved to date.
The vendor drawings and manuals are being verified for technical adequacy by the Division of Nuc lea r Engineering (DNE) prior to forwarding to the Document Control Center for entry in the DMS.
SQN is upgrading the Vendor Drawing and Manual Control Program by developing new and revised procedural in the Nuclear Quality As su ra nc e Manual requirments~
(NQAM) and lower-t ier documents i.e., Admin is tra tive Instructions AI-23 and AI-25, and Sequoyah Engineering Procedure, SQEP-39. These procedures are presently in the review cycle and a scheduled issue date has not been established.
In a discussion with cognizant DNE personnel, it was indica ted that the Vendor Drawing and Manual Con trol Program is approximately 40 percent comp le te . The target date for completion is scheduled for January of 1988.
5.4.1.3 Conclusion The issue of the document re trieval of QA records being inadequate and not identifiable in re la t ion to vendor and construction QA records is a valid issue.
Although our investigation indicated a high percentage of retrieveable construction QA rec o rd s , one must consider the delay and e f fort involved to re t r ieve these documents. lloweve r, this condition is not considered a violation of present requ i re men t s .
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVLSION NUMBER:
Element Report 3 TLTLE: PAGE 22 0F 27 Quality Assurance Records The overall record s retrieval system for QA Con truc t ion Records including vendor drawings and manuals is less than 40 percent comple te ; the re fo re ,
promp t , re liable, and adequate re tr ievability is not feasible at this time. Difficulty in retrieving QA records could potentially hinder the required evaluation of a safety-related part or component. In addition, the numerous vendor drawings and manuals addressed in CAR No. SQ-CAR-86-01-004 need to be corrected and up-dated to reflect the revision level of the "as designed" equipment and in forma tion included in the DMS. The CAR is the current document used by SQN as the tracking means for the above deficient condition.
Although corrective action is warranted pertaining to the issue of records retrievability of ' vendor drawings and manuals, a Co rrec tive Action Tracking Document (CATD) has not been issued as part of this report.
CATD No. 80503-SQN-07 addressing a similar issue was included with QACEG Element Report No. 80503-SQN.
5.4.2 Retrieveability of Quality Related Operation Records.
5.4.2.1 Discussion This issue was investigated by QACEG by selecting nine types of operating QA records; such as, Engineering Change No tices (ECN), Workplans (WP), Correc tive Action Reports (CAR), Inspection Reports, Discrepancy Reports (DR), Ma intenance Req ues t s , NRC Inspection Reports, Inplant Surveys, a nd Inse rvice Inspections, for retrievability from the RRI at SQN. The nine types of QA records consisted of a to ta l of 221 documents to be retrieved. Of the 221 documents only th ree were not retrievable either on micro film frora the Document Control Cente r (DCC) or hard copy from the Permanent Storage Vault. We three documents were further re searched and it was found that one was cancelled and the other two need to be reviewed by QA prior to forwarding to the Permanent Rec ord Storage Vault. We selected Ope ra t ing QA records we re satis fac torily re tr ieved from the RR1 a nd from the Permanent Storage Vault.
In addition, QACEG reviewed five SQN QA audit reports relative to the records retrievability in the Document Control and QA Records areas for 1985 and 1986. Th is rev iew conc luded that no major breakdown in the RRI was reported.
1 j
. +
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
Element Report 3 TITLE: PAGE 23 0F 27 Quality Assurance Records 5.4.2.2 Conclusion Based on the above evidence , the issue of inadequate records retrievability for operating QA records is no t a valid issue.
The QACEC evaluation of this issue has determined that the RRI was e f fective for the retrieval of operating QA documents. The RRI-is most effective when a unique identifier number, specific type document or sy s tem number is used to retrieve desired records.
5.5 Issue - Welder certification records were altered.
-5.5.1 Discussion QACEG reviewed Welding Project's (WP) Specific Employee Concerns Report dated November 6, 1986 addressing Employee Conce rn XX-85-088-003. The issue of alterations to' welder qualfication records as noted in WP report was not substantiated in relation to welder certific ations being technically satis fac tory. This issue was investigated by QACEG to ' determine if the welder certifications were actually a lte red. The investigation per formed by QACEG did substantiate the issue that welder certifications were altered con trary to TVA's e stablished requirement s. 'lh is - issue is further discussed within this section of the report.
A review was made of the QC Plant Log which documented all Special Process Surveys conducted by TVA since 1982. A sangle of six surveys per formed from July 1983 thru August 1985 was then selected for review to determine if the issue of " Altered Welder Ce r ti fica t ions" had been identified as a prob lem.
These surveys encompassed welder qualifications and welder continuity checks to determine if the program was b'e ing controlled in accordance with SQM 17 and Specification DPM-N73M2. Each of these surveys identified various types of problems resulting in many DRs being issued. Add itiona lly, in some instances CARS we re initiated which required root cause ana ly sis , resolution of condition adverse to quality, remedial correc t ive actions, and correct ive actions necessary to prevent recurrence. The latest su rvey rev iewed , dated August 26-September 5,1985 identi fied nu::e rous we lde r certification record disc re panc ie s. These prob lems encompassed the following :
- a. Inappropriate changes were made by engineers or clerks to per formance quali fication records.
._..-e- . - . ,. . .. . - - . . .
. TVA EMPLOYEE CONCERNS REPORT NtIHilER:
SPECIAL PROGRAM 80504-SQ N REVLSION NINBER:
REPORT TYPE 3
Element Report PAGE 24 0F 27 TITLE:
Quality Assurance Records
- b. Welder Continuity Records contained conflicting entries.
- c. Weld Rod Issue Cards did not provide adequate in forma t ion
~
to verify that welding had actually been performed.
t As a result of the various problema . identified, CAR SQN-CAR-85-09-014 ' was initiated which required immediate . corrective action. All SQN ac tive we ld e rs ' files we re rev iewed to identify and correct any discrepancie s related to - we lde r continuity and welder qualification. This review did not identify any welders who were working in violation of the 4
~
applicable cod e. In several cases, however, we ld ers we re directed to re-e stablish their certi fications to ensure all 4
doubt had been removed concerning their qualifications.
The issue of welder certifications being altered by the use of correction fluids was reviewed for 75 welders from the Division of Nuclear Power and approximately 200 records from f
Construction revealed that contrary to the NQAM Part III, 1
Section 4.1 and AI-7, para. 4.2.6, . corrections were made to i
some Welding Per formance Qualification record s by use of correction fluid.
Based upon copie s o f welding records obtained from seve ra l 4
micro film, rolls there was evidence that, some of the welding records did have corrections made the to relevant quality in forina in formation tion which could be significant to applicable to the welder - certifications. Correc tions we re made to Guided Bend Test results, entr ies on we lder qualification lists, position and specimen numbers, electrode or ' filler metal type and size, backing ring or strip and diameter and/or thickness. With regard to the welding records of the Division of Nuc lear Powe r, th e certification records reviewed were the actual hard copies located both in the active and . inactive files. There was evidence of correction fluid being used on five ,c f the seventy-five certification j ~
I The se
- records reviewed in the active Nuclear Power fi le.
corrections we re made t? entr ies in the Quali fic ation Test b lock s , date qualified /tocations b lock s , we lde r continuity records and to the actual Test Result s block fortoGuided the quality fiend tests. These corrections could be signi ficant information applicable to the welder certifications.
i These conditions viola te the requirements of HQAM Part III, l Section 4.1, which states that in the prepara t ion of a QA record changes / corrections should be made by marking a single 4
line through' the item to be changed making the new entry and mak ing the entering the dated initials of the person
- change /co rrec t ion. SQNP AI-7, Parag raph 4.2.6 r.eq u ire m.e nt s are similar to the higher-tier document.
er- - , - , , . - - < -
v- --y.mm-,,.-,., , , , ~ . - - ~~...,..,,,.-.,..----,,.,--.~-,.._..w,m.., - . ~ . . - - . , , ,.--,-..e.-----+.#4m-vm
s t TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION NUMBER:
- Element Report 3 TITLE: PAGE 25 0F 27 Quality - Assurance Records 5.5.2 conclusion Based on the above evidence, the is sue of welder certifications being altered . is valid, he documented evidence of welder certifications being altered is a violation of the requirements of TVA procedures and p ractice s. he Welder Performance Qualification Record s maintained by both Construction and . Nuclear Power are de fined as QA records, there fore , these records arc within the scope of the NQAM and SQN site procedures.
5.6 lasue - Maintenance Requests (MRs) for Limitorque valve actuators were signed off as unnecessary or complete even though no work was per formed. Non-QA material was installed in QA applications and traceability was falsified on the MRs.
5.6.1 Discussion The investigation by QACEG concentrated on the specific employee concern and the issue of the Limitorque valve actuators and whether or not Maintenance Request (MRs) which require the addition of grease to the valve ac tua tors were signed off by a general foreman as not necessary; whether the same MRs which -the general foreman considered unimportant we re signed-o ff even though no work was performed; and whether or not non-QA material was installed in QA applications and whether or not traceability was falsified on the MR. (QACEG assumed this to mean the application of grease since the CI incorporated his allegation on the same concern with the Limitorque valve issue.)
The investigation of this issue was part of a larger investigation done by the Operations Concern Group and reported in their Element Report 30804 SQN. A discussion with the SQN QC inspection personnel by QACEG provided details of an investigation and research by them into 102 Maintenance Request packages for all the Unit 2 Limitorque valves. Wat investigation by -SQN - QC was done in June 1986 to verify the application of correct grease in the valve actuators. he SQN QC investigation and the QACEG investigation verified that all Unit 2 Limitorque valves were inspected and it was found that the actuators have been properly greased in accordance with the requirements of Maintenance Instruction M1-10.46. This MI stipulates a QC hold point for the verification of lubricant. ,
5.6.2 Conc lu sion This issue is unsub stantia ted since there were no instances obse rv ed in the Ma in tenance Requests reviewed whe re the
TVA EMPLOYEE CONCERNS - REPORT NUMBER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVISION INMBER:
Ele ment Repor t 3 T1rLE: PAGE 26 0F 27 Quality Assurance Records general foreman cancelled or deleted a requirement. Research of the MR packages and our conversation with the SQN QC
- inspec t ion personnel indicated that all Unit 2 Limito rque valve actuators have been inspected and verified to have been greased with the proper lubricant.
5.7 Issue - Quality documentation was lost by the vault and regenerated by the responsible unit.
- 5. 7 .1 Discussion This issue was investigated and reported by QTC on Sep tembe r
- 16, 1985 specifically for a condition at Watts Bar Nuclear l Plant (WBN).
The QACEG investigation at SQN included the review of the similar condition and documents which were reported by QTC.
QACEG reviewed the Elec trical Inspection Log for 1985 and 1986, five SQN QA audit reports, and approximately 400 NCRs to determine if SQN documented conditions of lost QA rec o rd s .
'lh e re sult s of this investigation revealed that the data reviewed did not identify conditions of lost docunentation.
QA personnel indicated that SQN did not report the condition of lost docutae n t s . The SQN permanent vault personnel would i request copies from the responsible unit to be included in the RRI.
5.7.2 Conclusion The issue- of lost documents at the vault could not be substantiated at SQN. 'lh e investigation revealed this ~ issue to be specific to WBN only.
5.8 Correc tive Ac tion The issue of the controlled documents containing conflic ting or obsolete data as described in Section 5.1.2 is valid. Iloweve r , this l
condition appeared to be an isolated case which was corrected by DCC personnel. There will be no other corrective action necessary.
The issue of failu re to appropriately document work uhich had been par formed as de sc r ibed in Section 5.2.2 is valid. TVA has a s s igned the responsibility for engineering ac tivities associated with the Environmental Qualification Program to DNE. 'lh e se detailed responsibilitie s and overall p rogram requirement s are de sc ribed in Standard Practice SQA 173. 'lh e results of the DNE's evaluation will determine if there is any potential impact on safety.
4
-. , - , - - , - . , - - - - - - . , - - - , . , . y, ., .v.,. _ , - . .- -.,-..yn-, ..y.. - , . . - , _ , - - . , , ~ - - -
i TVA EMPLOYEE CONCERNS REPORT NUMilER:
SPECIAL PROGRAM 80504-SQN REPORT TYPE REVLSLON NUMBER:
Element Report 3 TITLE: PAGE 27 0F 27 Quality Assurance Records The issue of material control is poor as described in Sec tion 5.3.2 is va l id . Ilo weve r, this condition has improved through the individual efforts of QA Audits, increased surveillance by SQN Plant QA Staff, TVA management attention, personnel awareness, and corrective actions as a result of Material Control Element Report 40703.
The issue of inadequate document retrieval of vendor and construction QA records as desc ribed in Section 5.4.1.3 is valid. SQN QA issued CAR 86-01-004 add ress ing the inability to re tr ieve the latest vendor 4
dre ings and manuals from DMS. The Vendor Drawing and Manual Control
? Program is approximately 40 percent comp le t e . In addition, CATD 80503-SQN-05 and -07 addressing a similar issue will be used to track th is de ficien t condit ion. The difficulty in re trieving QA documents could potentially hinder the required evaluation of a sa fe ty-related part or component. When the Vendor Drawing and Manual Control Program 3 is completed and put in place, it will reduce the potential factor of this condition. The corrective action is being furnished by SQN Site Director's Of fice.
The issue of welder certification records being altered as described in Section 5.5.2 is valid. The corrective action identi fied on CAR 85-09-014 required all SQN active we ld ers ' file s to be rev iewed and we lders re qualified / certified to current requirement s . This CAR was dispositioned and QA verified this deficiency on February 13, 1986.
6.0 ATTACIMENTS A. List of Employee Concern Information Subcategory 80504
- 3. List of References and Documents Reviewed C. NSRS Report I-86-129-SQN dated March 3,1986 D. NSRS Report 1-86-180-SQN dated March 4, 1986 E. NSRS Report I-86-185-SQN dated March 5,1986 I
i i
i
' ..y..g. .' -
F . ,
i PAGE 1 OF 3 ATTACIL' LENT A PAGE -
Ih2 RUERLt3CE - ECPS120J-ECPS121C TEllllESSEE VALLEY AUTHORITY rut! TIME - 14:29 : W
- FREGUEHCY - REQUEST OFFICE OF HUCLEAR Poller RUll DATE - 01/21/c,/
OllP - IS^,5 - RilM EMPLOYEE C0!!CtRil PROGRAtt SYSTEM (ECPS)
EHPL OYEE CollCERH IllFORMATIUll BY CATEGORY /SUDCATEGORY CATEGORY QA QuQC PROGRA!15 SUBCATEGORY 80504 AS-bull T t.ollDIT 10lls S 1 REPORT APPL H 2 SAf RLL AlLD SUB R PLT 3 FIllD CL ASS HISTORICAL C0 llc ERil BF Bt SQ lia REPORT ORIGIH CONCERN DESCRIPTIDH Col &CERrl flUMBER CAT CAT D L OC -------------------------------------------------.
QA 80504 S SQti 1 11 N Y H Ill-8 5-091- 0 01 QTC QUALITY DOCUMENTATI0H IIAS LOST BY VAULT AND THEH H Ir4 091-00101 2 flA IIA SS tlA EGEtaERATED BY THE RESPONSIBLE UHil'.
150001 3 IIA flA A HA 02 QA 80514 5 SQN 1N Y H Y 2 IIA SS tlA SS 3 tlA flA QA 80504 S llBN 1H tl Y N IH-85-357-001 QTC RECORDS RETRIEVABILITY FROM QC STAGE VAULT IS lESS IN 557-00101 2 HA IIA Ho NA THAH ADEQUATE.SEVERAL IllSTANCES (SPECIFIC UNKt1011tl 150026 ) HHERE THE INDIVIDUAL COUL D IIDT OBI AIN RECORDS till 3 NA NA A NA 02 QA 4MM S IIBM 1Y -Y H Y Ett REQUESTED. S0tlE RECORDS 100K SEVERAL DAYS Tu t 2 NO No flA fl0 DCATE AND SOME COULD NOT BE FOUllD Al ALL . IllDIV I D M 3 flA UAL DID ST ATE H061EVERs IHAT RECURDS HERE PR0llABLY AVAILABLE, JUST HOTRETRIEVABLE j(g 1N N Y H IN-85-770-002 QTC HELDER CERTIFICATION CARD FALSIFIED. (DETAILS 10 IN 612-X0701 IH 60300 S tlBN 2 THE SPECIFIC CASE KH0HH To QTC AtID llITHHELD 10 ftAl T50137 HTAIN CONFIDENTIALITY). C0taSTRUCTIUti DEPT. C0tlCLR 3
02 QA 80504 5 H8N 1N N Y N H. CI HAS NO MORE INFORMATI0H. NO FUL L ull-UP REQU 2 flA flA SR HA IRED. (SQN ISSUES ADDRESSED IN RPT HP-19-SQH RI) 3 NA HA C HA 03 QA 80519 S llBN 1N H 11 Y 2 NA flA flA SR 3 NA IIA HA 04 HE 50119 S HBN 1N N .Y N 2
3 JLH-86-001 01 IH 60300 S SQH 1 DECP (1) HRS HHICH REQUIRE THE ADDITIDH OF GREASE 10 L 2 IMITORQUE VALVE OPERATORS ARE SIGilED isY A GEllERAL 3
FOREMAN AS "HO GREASE NECESSARY" lillEH, Ill FACT, TH 02 OP 30804 S SQH 1 E GREASE LEVELS ARE LOli OR NEEDS REPLACING. (2) 2 MRS HHICH THE GENERAL FOREMAll C0llSIDERS Uti!MPORI AH 3 T ARE SIGHED OFF AS COMPLETE EVEli Til0 UGH 110110RK ll 03 QA 80504 5 SQH I il Il Y N AS PERFORMED. (3) N0ll-QA MATERIAL IS INSTALLl'D i 2 NA flA SS tlA H QA APPLICAT10HS, AllD TRACEABILITY IS FALSIFIED 0 3 IIA NA A HA N THE MR.
04 QA 80519 S SQH 1Y Y ll Y 2 SS SS HA SS 3 NA QA 80504 S SQH 1N N Y H QIC THE CONTROLLED DOCUMENT RETRIEVAL SYSTEM IS 1HADI4-SQM-86-002-00101 UATE. (HAMES/DET AILS KHolill TO QTC, IllitillEt D 10 ttA 150254 2 IIA IIA SR tlA 3 NA NA A NA IHTAIN CONFIDEllTIALITY.) IlUCL EAR Poller COHCERil . C 02 QA JtaS34 S SQH IY Y H Y I HAS NO FURTHER INFORMAT10tl. No f uRillER I NF ORitA l l 2 SR SR HA SR ON MAY BE RELEASED. HU FOLLOH-UP RL4UIRED. .
- $pg) 3 NA JS
l.
. . y ' . .-
e ATTACH;iENT A PAGE 2 OF 3 R E F L k t ta.E - ECPS120J-ECPS121C TEll!!ESSEE VAL 1IY AUTHORITY PAGE -
185 .
FRtOuttCY - RE4UEST OFFICE OF lluCLEAR Pul4ER RUll TIME - 14:29:59 OllP - ISSS - RilM EllPLOYEE C0!ICERil PROGRAt1 SYSTEtt (ECPS) RUti DATE - 01/21/b/
EMPLOYtE C0!4CERil IllF0Hi1Alloil BY CATEGORY / SUBCATEGORY CATE60k(> 4A Q A/QC PROGRArts SUBCATEGORY: 80504 AS-bull T C0!4DITIONS S 1 REPORI APPL H 2 SAF RELAILD SUB R Pli 3 FIND CL ASS HISTORICAL C0flC ERil Cot 4CL M4 fiUMBER CAT CAT D L UC BF BL SQ llB REPORT ORIGIH CONCERN DESCRIPTIOli SOM-86-032-00501 QA 80504 il SQil 1 ti 11 Y N I-86 -18 5-SQti QTC CONTROLLED DOCUMENTS CollTAlla CollFL ICTING DATA RFI A 150254 2 !!A HA SS IIA TIllG TO THE SAME IllST ALL AT10H. (llATIES/ DET AILS Kilu 3 flA flA C HA Hit TO QTC, HITHHEL D 10 Mall 4TAIN CUlli IDENTI ALITY.1 HD FURIHER INFORMATI0H MAY DE RELEASED. HUCLEAR -
P0HER C0HCERN. CI flAS NO FURTHER lilFORMAT I 0tl. 11 0 FOLLDH-UP REQUIRED.
SQM-86-002-00601 QA 80504 H SQH 1 il N Y 11 I-86-18 5-SQll QTC HORK IS BEING PERFORMED TO DOCUMEllTS C0llTAIlllllG CU T50254 2 IIA IIA SS IIA HFLICTIllG OR OBSOL ETE DA1 A. (llAl1ES/ DET AILS Kri0llia 3 IIA flA C HA 10 QTC, HITHHEL D TO MAINI AIN C0!IFIDLilTI AL ITY. ) 11 0 FURIHER INFORMATIDH MAY bE RELEAStD. HUCLEAR l'uti FR CollCERil. CI HAS NO FURTHER liiFORMATIDH. Ho Fu LLOH-UP REQUIRED.
SQM-86-003-00201 QA 80504 N SQN 1N H Y !! I-86-180-SQH QTC DUPLICATE DOCUMENTS HAVE BEEN ISSUED HITH C0liFLICI T50253 2 ilA HA SS tlA ING DATA. (HAMES/DET AILS KHoliti TD QiC, HITHilELD T 3 tiA flA C HA 0 MAINTAIN CONFIDENTIALITY.) 110 FURTHER IllFORMAI!
OH MAY BE RELEASED. HUCLEAR P0HER CullCERil. CI ilA S NO FURTHER INFORMATI0H. H0 FOLL0ll-UP REQUIRED.
SQM-86-009-X0401 QA 80504 Il SQH 1N N Y H' QTC INSPECTION RECORDS MAY REFLECT IMPROPER DATA. DEI 150262 2 HA NA SS HA AILS KNOHN TO QTC, HIlHHELD DUE 10 CollFIDEllTI ALIIY 3 flA flA A HA . NO FURTHER INFORMAllotl MAY BE RELEASED. IlVCLLA R P0HER DEPARTMENT CONCERN.
SQM-86-011-00201 QA 80504 N SQN 1N 11 Y H QTC SEQUOYAH HAS ALLEGEDLY SHUT DOHN IN AUGUST 1985, D 150264 2 ilA NA SS tlA UE To THE FAILURE OF A GROUP (KHoliti) TO APPROPRIAT 3 IIA IIA D HA ELY DOCUMENT HORK (SPECIFICS t:0T Kil0lin) HHICH HAD BEEN PERFORMED. NO FURTHER INFORflATION IN FILE.
ANONYMOUS CONCERN.
SQP-86-002-00101 QA Il SQN 1N N Y H I-86-129-SQti QTC QA RECORDS ARE NOT IDENTIFIABLE AtID RETRIEVABLE.
150240 2 IJA NA SS HA NSRS IllVESTIGATION I-83-13-ilPS IDEllTIFIED PROBL Et15 g 3 flA flA A IIA Ill 1983 AND HSRS REPORT R-85-07-flPS IllDICATES l'No BLEMS Il0T CORRECTED IN 811D-1985. UE, OC AllD 14UCII; 4
} i N f'7 AR P0HER RECORDS ARE CITED. CI HAS 110 FURTHER Illi URMAT l ott. H0 FOLLOH UP REQUIRED.
DebP-86-009-00101 QA 80504 S llBil 1H H Y la QTC QA RECORDS ARE 140T IDEllTIFIABLE AND RETRIEVABLE.
150243 2 14A flA SR HA IISRS INVESTIGATI0tl I-83-13-flPS IDEllIIFIED PRODL Lt15 3 IIA flA A IIA Ill 1983 AllD HSRS REPORT R-85-07-itPS INDICATES itu 02 QA te H 6- S IIBil 1 Y Y ll Y BLEMS NOT CORRECTED III MID-1985. OE, UC AllD 11004 1 2 SR SR ila SR AR e0HER RECORDS ARE CITED. 130 FURIllER lilF0kl1A l l u 4o5)- 3 IIA 11 MAY BE RELEASED. CI HAS 110 FURIHLR lilFORMAT10H.
- ( i Q 110 FOLLOH UP REQUIRED.
. . .js ;;, -
i PAGE 3 OF 3 NETACIL*1ENT A PAGE -
. 184 RE F ER Eri;E - ECPS120J-ECPS121C TEllilESSEE val L EY AUTHORITY kut! IIME - 14429:59 .
t RL uot t.? ( - REQUEST Off ICE Ut- tiUCI EAR Puller RUll DAIE - 01/21/El OteP - 1355 - kitti Et!PLOYEE CollCtRif PROGRAM SYSTEM (ECPS)
EMPLOYLE CollCERil IllFuki1A110tl DY CATEGORY / SUBCATEGORY CATEGGR(. QA QA/QC PROGRAMS SUBCATEGORY 80504 AS-BUIL1 00tIDIT10 tis S 1 REPORT APPL H 2 SAF RELA 1ED SUS R PLT 3 FIliD CL ASS HISTORICAL CollCERI4 D L OC BF bt SQ lia REPORT ORIGIN C0tlCERif DESCRIPTIDil Cot 4CE R!4 13 UMBER CAT CAT -------------- ------ ---------------------------------- ------
XX 088-XO401 IH 60500 S SQH 1 QTC SEQUOYAH - HEL DIllG CERTIFICATI0fiS llERE ALTERED BY 2 THE USE OF CORRECTION FLUID. PROCESS MARKIllGS SUC 150M 8 H AS FILE IllDEXES AIID PAGE COUNTS, AS llELL AS Ally 3
I 11 H Y H HARKS. NOTATIDHS OR ANY DATA THAT DID HDT LOOK LI ,
02 QA 80504 S SQH KE EllGINEERING DA1A OH 1HE BACK OF THE DOCUI1Elli.
218A IIA SR IIA 3 flA flA C HA HERE DELETED li1TH CORREC110ll FLUID. CollSTRUCiluti 05 QA 80516 S Syli 1Y Y ll Y DEPARTMEHI C0liCERN. CI tiAS HU FUR 1HER Il4 FORMAL!Uti 2 SR SR IIA SR .
5 NA QA S0109 5 SQH IY Y ll Y I-85-987-SQH QTC SEQUDYAH MATERI AL CollTROL IS POOR. TRACEABILITY XX 122-04201 GF REQUIREMENTS, PAPERl10RK AllD MATERIALS IS lilADE4 150215 2 SS SS IIA SS UA1E, PAPERil0RK FUR QUALITY RECURUS IS PUOR. Cl il 3 flA 02 QA 80504 S SQ'l 1N N Y H AS 110 FURIHER INFORMATIDH. ANONYr10U5 CutiCERN VIA 2 ilA flA SS tlA LETTER.
3 flA tlA C llA 14 CONCERitS FOR CATEGORY QA SUBCATEGORY 80504 e
de M
S S-
ATTACHMENT B PACE 1 0F 2 REFERENCES A. Office of Engineering Procedure, OE-01 3001 Revision 0, " Drawing Originals t
-Checking Out and Checking IN".
B. Division of Engineering, Management and Engineering - Data System, MEDS, MP 23.05, Revision 1, "ENDES and Vendor Drawings Information Services".
C. Nuclear Quality Assurance Manual (NQAM), Parts I, II and II, Revision dated 12/31/84.
D. Office of Engineering Procedure, OEP-08 Revision 0, " Design Output" E. Administrative Instruction, AI-25 Revision - 13, " Drawing Control . Af ter Unit Licensing". .
F. Significant Condition Report No. SQN SQP 8601 Revision 0.
G. Final Safety Analysis Report (FSAR) Section 3.11, " Environment Design of Mechanical and Electrical Equipment".
H. FSAR Section 8.3.1.2.3, " Safety Related Equipment in Potentially Hostile Enviroment".
- 1. NUREG-0588, Eterim Staff Position on Environmental Qualification of Safety- t Related Equipment" J. IEEE-323-1974, "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Station" l K. TVA Topical Report, TVA-TR75-1A Revision 8 L. Office of Construction Procedure, OC QAPP-5 Revision 5, " Instructions, Procedures, and Drawings" M. Office of Construction Procedure, OC QAPP-17, Revisions 0 - 3, "QA Records" N. Nonconforming Report (NCR) No. SQN CEB8502 Revision 2 0 SQN Standard Operating Procedure, No. 551 Revision 6, "Past Records Review and Engineering Evaluation" P. Quality Assurance Audit Report Nos. SQ-8400-02, SQ-8400-04, SQ-8500-01, PSQ-A-85-005, QSQ-A-86-001, QSS-A-85-0009, and QSQ-A-85-0010 SQN Compliance Visits, Audits, and Inspections --
In plant Survey, Q.
checklist Hos. 3-85-P-003, 3c-85-P-004, 3h-83-A-017, 3h-84-S-004, 4a-85-A-001, 4n-85-A-013, and 15a-85-P-001 R. SQN Work Plans Hos. 10803, 10806, 10830, 10842, 10850, 10861, 10893, 10904, 11139, 11261, 11277, 11467, 11481, 11582 and 11685.
l PAGE 2 0F 2 S. SQN Corrective Action Report (CAR) Nos. SQ-CAR-85-03-004, SQ-CAR-83-07-022, SQ-CAR-84-01-001, SQ-CAR-86-01-004, SQ-CAR-21-81-8, SQ-CAR-85-08-012, SQ-CAR--21-82-25, SQ-CAR-31-01-003, SQ-CAR-83-09-032, SQ-CAR-85-03-011, SQ-CAR-83-10-033, SQ-CAR-85-09-014, SQ-CAR-84-09-017, and SQ-CAR--85-03-005.-
SQ-DR-85-12-148R, SQ-DR-T. SQN Deviation Report _ (D'R) Nos. SQ-D R-85-05-047 R, 85-06-060R, SQ-DR-84-07-077R, SQ-DR-34-03-023R, SQ-DR-83-12-117, SQ-DR 01-013R, SQ-DR-86-01-002R and SQ-DR-84-04-038R.
U. Generic Procedure No. ID-QAP-6.2, Revision 0 dated 6/18/85, " Vendor Manual Control".
V. SQN Inplant Survey Checklists Nos. 5a-83-P-005, Sa-85-A-006, Sa-83-030, Sa-83-P-015, Sa-85-S-007, and Sa-84-S-025.
W. Administrative Instruction AI-7, " Recorder Charts and quality Assurance Records", Rev. 36 dated 4/19/85.
i dated 6/8/86, " Quality X. Generic Procedure No. ID-QAP-17.2 Revision Assurance Records for Design and Construction".
Y. Maintenance Instruction, MI-10.46 Revision 3 dated 6/26/86, "Limitorque, l
Moteor Operator / Control Valve".
19 and 20, " Maintenance Z. SQti Standard Practice No. SQM2 Revisions 18, Management System".
i i AA. TVA 45 D Note, E. Itassell to J. Itamilton dated 6/13/86, " Evaluation of MR packages /Limitorque Operators".
I
- BB. TVA Drawing No. 45N17949-30 i
SQM-17, Rev. 4 dated 10/14/86, " General CC. SQN Maintenance Instruction, Requirements for Welding, Ileat Treating and Allied Field Operations at a l
l Nuclear Power Plant."
DD. SQN DPil-N73M2 datd 10/10/86, " Process Specification for Welding, Ileat Treating and Allied Field Operations."
EE. NSRS Report I-85-987-SQN dated 3/4/86 FF. QTC Reports IN-85-612-X07 dated 10/24/85, XX-85-088-X04 dated 3/4/86, and 2 IN-86-091-001 dated 9/16/85.
l l
l l
t
~ .
ATTACilHENT C PAGE 1 0F 7 TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. 1293 EMPLOYEE CONCERN NO. SQP-6-002-001
SUBJECT:
SECDND FOLLOW-UP OF QEB RECORDS INVESTICATION I-83-13-NPS DATES OF ,
INVESTIGATION: February 6-14, 1986 INVESTIGATOR: / [
W. R. SIMONDS BATE #
C 'N REVIEWED BY: s J 1 f4
/ ~~J. C. CATLIN -
DATE APPROVED BY: !/ ' M./F l 8
- f D. STEVENS DATE t
l l
i e l
l f
l
' \
ATTACHMENT C PAGE 2 0F 7 I. BACKGROUND A Nuclear Safety Review Staff (NSRS) follow-up corrective action investigation was conducted to determine the validity of an expressed I employee condern received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the
' Employeo Concern Assignment Request Form from QTC and identified as SQP-6-002-001,~ stated:
- CONCERN: QA Records are not identifiable and
- retrievable. NSRS Investigation I-83-13-NPS identified
- problems in 1983 and NSRS Report R-85-07-NPS indicates problems not corrected in mid-1985. OE, OC, and
{. Nuclear Power Records are cited.
An NSRS follow-up review of Investigation I-83-13-NPS did find that corrective actions resulting from the original NSRS investigation had l not been completely closed out. The results of that follow-up review are documented in NSRS Report R-85-07-NPS (Ref. 1) along with a ,
i recommendation (R-85-07-NPS-01) that the Manager of Power and Engineering appoint a records manager to provide upper management coordination for resolution of the open items which had been identified.
i II. SCOPE I A. The scope of this investigation is defined by the concern of record. It is that problems previously identified by NSRS investigation I-83-13-NPS, and the corresponding follow-up review R-85-07-NPS, have not been corrected for Sequoyah Nuclear Plant ;
i (SQN).
B. The scope included determination of status and progress of the open items identified in I-83-13-NPS and R-85-07-NPS as they pertain to P SQN.
I C. The scope of the follow-up investigation also included discussions with site and task force personnel who are actively involved in the i resolution of these items. ,
l i
I III. SUKHARY OF FINDINGS 1
A. R-85-07-NPS contained recommendation R-85-07-NPS-01 which I .-
recommended that Power end Engineering (Nuclear) [P&E (Nuclear))
appoint an upper-lovei manager empowered with the responsibility, 7 authority, and organizational freedom to assure that records 1
i associated with the procurement and installation of Quality Engineering Branch (QEB) source inspected equipment and materials are assembled, verified for completeness, indexed, and stored for retrievability. The recommendation further stated that the i !
l appointee's scope should include all past and future QED source inspected procurements for SQN, as well as Watts Bar and Hollefonto, and the establishment of a schedulo for completion of i
pact records.
i t- *- m re-e-- -.r--'e- we,%~.e--.u-*>--'y-,+w--,,woww,,w-..w,.---w -y:-s-- ,..m%,.----.-_--.,..-.-e---m,_i.-,--me,- - - -4y'-%. - - . +...r-.--
\
ATTACllMENT C PAGE 3 0F 7 P&E (Nuclear) subacquently informed USRS (Ref. 3) that an appointment had been made, and identified personnel who would provide assistance to the appointee. Following the appointment, meetings of the personnel were held on September 17, 1985, and December 16, 1985, to discuss resolution of the open items identified in NSRS follow-up review Report R-85-07-NPS. These meetings are documented in references 4 and 13 along with specific action items and schedules for resolution of the problems.
IV. STATUS OF PREVIOUSLY IDENTIFIED OPEN ITEMS A. Develop an Integrated Records System for Quality Assurance (OA)
Records That Will Saticfy the Needs of Nuclear Power (RUC PR) and Of fice of Ennineerinn Design Construction (OEDC).
- 1. Paragraph IV.A.1 of R-85-07-NPS states that a TVA task force was working en vendor manuals at the time of the first NSRS follow-up review, however, two areas of concern were identified regarding vendor manuals as follows:
- a. A question was raised by NSRS regarding whether any of the manuals were considered "one-of-a-kind", and therefore, in need of fireproof storage. This finding was addressed in paragraph V.C of the report.
Subsequently, ID-QAP-6.2 (Ref.15) was revised to require that those vendor manuals utilized as plant instructions
~
will be maintained as' QA records. This requirement, in combination with' existing requirements of AI-23 (Ref. 16),
appear to establish adequate protection for ' vendor manuals for SQN.
- b. The applicable procedures for vendor manual control were found to be vague in the delegation of responsibilities.
A task force was developing a new procedure regarding the maintenance of vendor manuals which was expected to correct the problem. This finding was addressed in paragraph V.E of the report. Subsequently, ID-QAP-6.2 (Ref.15) was revised to more clearly prescribe organizational responsibilities regarding the control of vendor manuals.
- 2. Paragraph IV.A.1 of R-85-07-UPS also states that records indexing procedures,had been prepared and were in various stages of impicmentation. It was further stated that this ites will remain open until more experience is gained by P&E (Huc1 car) with the records indexing system. This matter is discussed in the following paragraphs.
2
_, s ,
ATTACllMENT C PACE 4 0F 7
.)
B. Correct implementinn Deficiencies Identified in the Existinn System
- 1. Paragraph IV.A.2.a of R-85-07-NPS states that QEB records were not adequately indexed and that there was some concern regarding their completeness. At the time of the the first NSRS follow-up review, efforts were under way to index and microfilm completed contracts; however, a schedule had not been established for completing the overall task. Initially, a completion date of December 31 _1987." was set by the P&E (Huclear) task force (III.A) for completing the overall task for all projects (Ref. 4). Ilowever, a recent commitment was made that appropriate manpower resources will be expended to ensure that a deadline of June 30, 1986, will be met for SQN (Ref. 13). QEB is utilizing a four-step approach which includes identification, location, verify completeness, and microfilming of the records (Ref. 4).
- Sequoyah has concurred with the parameters that QEB is using to index their records (i.e., vendor / contract number). However, site personnel normally'must request the records by Unique Identifier Number (UNID). Therefore, efforts are in progress to provide a cross-reference between UNID and vendor / contract numbers. The Equipment Qualification Information System (EQ1S) is being investigated as t,he link to provide this cross-reference (Ref. 6 and 13). This item remains open.
- 2. Paragraph IV.A.2.b of R-85-07-NPS states that all OC records for Soquoyah had been transferred or were in the final stages s of microfilming at the time'of the first USRS follow-up review.
.n Microfilming of all the records underway at the time of the review have been completed. However, another 175 cubic feet of contract-related files and various other records were discovered by SQN-DCU personnel in warehouses vacated by OC, in addition to several files at other locations. SQN-DCU and RIMS-Chattoonga personnel are working to microfilm these additional records and have completed filming about 36 cubic feet.
- Manual indices will be es'tablished for these records pending resolution of prob 1 cms associated with the Records Retrieval Index (RRI) system. Hierofilming is proceeding on an
, "as-soon-as possible" basis (Ref. 10, 12, 13 and 14). This item remains open.
- 3. paragraphl IV.A.2.b of R-85-07-NPS also states that a RRI system was prepared but'jud'ged to be not totally effective at the Limo of the first NSRS follow-up review.
NUC PR personnel subsequently conducted 'a review of the RRI to identify deficiencies and initiate recommendations to correct any problems (Ref'. 4 and 7). The NUC PR review confirmed that the RR1 was deficient in several are'as and recommendations wore made to identify all OC record types and develop detailed instructions, for the retrieval of each record.
3
e
. . i ATTACHMENT C PAGE 5 0F 7 The P&E (Nuclear) task force (III.A) established to resolve the open items of R-85-07-NPS has taken the recommendations under consideration and has acted to establish a sub-tank group to
" rework the SQti RRI using original RRI guidelines" (Ref.13).
The chairman of the sub-Lask group has met with cognizant personnel and is proceeding with efforts to rework the RRI. A date for completion of the task has not been set. This item remain,s open.
- 4. Paragraph IV.A.2.d states that continued upper management coordination involvement at a level capable of crossing organization boundaries is considered necessary until the problems are solved and records systems prove ef fective.
This matter appears to have been adequately addressed by P&E
.- (Nuclear) through actions discussed in paragraph III.A above.
' Clarify ornanizational Responsibilities C.
Paragraph IV.A.4 states that with the exception of a cicarly defined system for vendor manuals, organizational responsibilities
~
have been defined. Subsequent revision of ID-QAP-6.2 (Ref. 15) appears to adequately prescribe responsibilities for vendor manual control as discussed in paragraph IV.A.1.b above.
D. Planned Actions and Schedules for Completion of Action Paragraph IV.B of R-85-07-NPS states that QEB had not completed verification and indexing of their records for SQN nor had QEB established a schedule for doing so at the time of the first t1SRS follow-up review. Actions taken on this matter are discussed in paragraph IV.B.1 above.
V. CONCt.USI0tlS AtlD RECOMMEllDATI0 tis A. Conclucion The employee concern is substantiated in that corrective action items shown in llSRS investigation *I-83-13-ilPS have not been completed for SQN. Ilowever, specific improvements have been achieved regarding vendor manuals, and work is steadily progressing toward the resolution of the remaining open items identified by
!!SRS. ,
D. Recommendntion I-86-129-SQti-01, Continue Honitorint tlSRS should continue to monitor the status of open items from I-83-13-ilps as they portain to SQN. (p3]
4
ATTACllHENT C PAGE 6 0F 7 DOCUMENTS REVIEWED IN INVESTICATION NO. I-86-129-SQN AND REFERENCES
- 1. Inf ormal Memorandum f rom K. W. Whitt to 11. G. Parris, " Follow-up Review of Quality Engineering Branch (QED) Records Investigation 1-83-13-NPS -
fluclear Safety Review Staf f (NSHS) Report No. R-85-07-NPS," dated May 28, 1985 (A02 850529 010)
- 2. Itemorandum f rom 11. C. Parris to K. W. Whitt, " Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NPS," dated July 1, 1985 (L16 850624 840)
- 3. Hemorandum from II. G. ' Parris to K. W. Whitt, " Follow-up Review of Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NPS," dated August 14, 1985 (L16 850729 883)
- 4. Hemorandum from R., A. Pedde to Files, "NSRS Report R-85-07-NPS - Follow-up Review of QEB Records Investigation - I-83-13-NPS." dated September 19, 1985 (Col 850919 004)
- 5. licmorandum from H. H. McGuire to R. A. Pedde, "NSRS Report R-85-07-NPS."
dated September 24, 1985 (L16 850924 833)
- 6. licmorandum from H. H. McGuire to R. A. Pedde, "HSRS Report R-85-07-NPS,"
dated October 29, 1985 (L16 851029 887)
- 7. licmorandum from H. W. !!adacek to H. H. McGuire "NSRS Report R-85-07-tTPS,"
dated November 13, 1985 (L16 851113 895)
- 8. Ilomorandum from R. D. Guthrey to James P. Darling, " Configuration Task Force - Activity Summary and General Assessment," dated August 8, 1985 (R25 850808 861)
- 9. Informal note from J. P. Vineyard to C. L. O' Dell regarding transfer of OC records to NUC PR, dated June 28, 1965 (B25 850628 002),
. 9
- 10. Hemorandum from Alva LaMontagne to llancy Welch, " Office of Construction (OC) - Sequoyah (SEQ) Site Records," dated September 24, 1985 (A31 850925 001)
- 11. }1emorandum from it. H. McGuiro to R. A. Pedde, " Action Item 9-17-3 of IISRS Report tio. R-85-07-tips, dated November 21, 1985 (L16 851121 802)
- 12. licmorandum from Alva LaMontagno to John Ed llayes,."Hierofilming Sequoyah Conctruction Records," dated January 8, 1986 (A31 860108 051) 5
,i .
ATTACilHENT C PACE 7 0F 7
- 13. Hemorandum from R. A. Pedde to Files, "NSRS Report R-85-07-NPS - Follow-up Review of QEB Records Investigation 83-13-NPS " dated January 9, 1986 (C01 860109 003) 1, 4
14, Heniorandum from Alva LaMontagne to Nancy Welch, " Office of Construction (OC) - Sequoyah (SEQ) Site Contract Records," dated January 22, 1986 (A31 860122 051)
- 15. NUC PR Nuclear Quality Assurance Manual (NQAM), Part V, Section 6.2 (ID-QAP-6.2), " Vendor Manual control." rev sii on dated December 31, 1985
- 16. Sequoyah Instruction AI-23. " Vendor Manual Control." R21
)
l .
1 l
4 A
I j .
D l
1 1
6 l
3
---.-- ---...,.. ,, ,. , _ _ _ . _ , - . _ , , _ . _ . _ , . , , . ,m.,., _ . . _ , ,_ _ , , , _ , _ _ _ . _ . . _ , , . _ _ . . _
ATTAClelENT D PAGE 1 0F 7 TEtJNESSEE VALLEY AUTliORITY HUCLEAR SAFETY REVIEW STAFF USRS INVESTIGATION REPORT No. I-86-180-SQN
., EtiPLOYEE CONCERNS: M/
- SQM-6-003-002 /
N I
I SUDJECT: SQN DRAWING CONTROL DATES OF ltlVESTICATION: FEBRUARY 5-7, 1986 INVESTIGATOR:
I! Wb/ - O-d7~8"b J. J. KNIGliTLY DATE REVIEWED BY: . b "E/f'7//$
L'. E. DROCK~ DATE
~
APPROVED BY:
AJn O A 2~
W. D. STEVENS DATE l
l l
ATTACHMENT D PAGE 2 0F 7 I. DACKCROUND A Huclear Safety Review Staff (HSRS) investigation was conducted to determine the validity of six expressed employee concerns as received by The the Quality Technology Company (QTC)/ Employee Response Team (ERT).
concerns of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as SQM-6-003-001 through -006, stated:
/SOM-6-003-001 Specific documents have been improperly issued.
Nuclear Power concern. CI has no further information.
QTC Clarification: Design drawings for ECN L6027 have been improperly issued. .
SOM-6-003-002 Duplicate documents have been issued with conflicting data. Nuclear Power concern. CI has no further information.
QTC Clarification: Drawing 45N1749-30 (RB) was issued twice on two separate mylars dated November 29, 1985 and November 30, 1985.
SOH-6-003-003 Specific documents have been improperly altered.
Nuclear Power concern. CI has no more information.
QTC Clarification: Drawings 15W810-44 (R7) and 45W833-1 (R9) were issued without Project Manager's initials in title block. Initials were added to the mylars after issue.
/
f/ SOH-6-003-004 ..
Falsification of' specific documents. Nucicar Power concern. CI has no further information.
QTC Clarification: The drawings identified in Concern SQM-6-003-003 were " corrected" without going through the NCR process.
SOH-6-003-005 Employee was directed to improperly change another employee's work. Nucicar Power concern. CI has no further information.
l 1
o
ATTAC!! MENT D PAGE 3 0F 7 QTC Clarification: The documentation included three significant condition reports (SCRs) submitted January 11, 1986.
SOM-6-003-Od6 Cl feels an attempt is in process to ' cover up' a specific problem. Nuclear Power concern. CI has no further information.
QTC Clarification: CI feels the significant condition reports identified in SQM-6-003-005 are being rewritten in such a way that the real problems will be misstated.
II. SCOPE A. The scope of the investigation was determined from the stated -
concerns of record and the respective QTC clarifications to be that of only the specific concerns contained in the stated QTC clarifications.
B. To accomplish this investigation, NSRS reviewed applicable requirements, procedures, drawings, drawing management system reports, significant condition reports (SCRs), and open item tracking system reports for these SCRs. Additionally, responsible drawing control personnel were contacted to discuss the employec's concern.
III.
SUMMARY
OF FINDINGS A. Requirements and Commitments
- 1. Nuclear Quality Assurance Manual (NQAM), Part III, Section 1.1,
" Document Control," Revision March 21, 1985. " Preparation, review, approval, and issuance of documents and their revisions shall be accomplished in accordance with approved written
. shall include . . the procedures / instructions. These . .
following requirements: . . . Final approval authority, Revision Controls. . . ."
- 2. Office of Enginocring Procedure OEP-08, " Design Output."
Project Manager ". .
. signs at ' Issued By' and distributes the drawing."
)
l l
2 -
o I
J
ATTACitMENT D PAGE 4 0F 7 B. Findings
- 1. Concern SQM-6-003-001 A query of the Drawing Management System identified 25 drawings for ECH L6027. A review of the file of issued drawings maintained in the Office of Engineering Technical Information Centor (TIC) found that 24 of the 25 drawings were issued without the Project Manager's signature / initials as required by OEP-08, Paragraph 5.1.3. The affected drawings are as follow.
45N1673-5 (R9) 45N630-4 (R15) 45N655-19 (R7) ;
45N1645-1 (R11) '
45N1645-8-(R12) 45N655-44 (R7) 45N1648-1 (Rio) 45W1656-4 (R22) 45N1648-4 (R16) 45W1673-5 (R9) 45N1688-1 (R23) 45W2673-5 (R4) 45N1688-3 (R26) *47B601-55-46 (R12) 45N1693-1 (R24) 47W605-15 (R13) 45N1693-3 (R19) 47W605-16 (R13) 45N2645-1 (R9) 47W605-33 (R15) 45N2645-8 (R12) 47W605-35 (R16) 45H2648-1 (R13) 47W610-30-01 (R28) 45N2648-4 (R9)
- issued with approval signature The nonconformlng conditions for these drawings were reported in SCR SQN SQP8602 RO dated January 11, 1986.
..J2. , concern SQM-6-003-002 A review of Sequoyah Nuclear Plant (SQN) mylar drawings found that wiring diagram 45N1749-30 was issued twice at revision level 8 on two separate mylars dated November 29 and 30, 1985.
The drawing was first issued at revision level 8 for LECN
/ 6202/FCR 3583 and then issued the next day at the same revision level 8 for LECU 6544/FCR 3966. In addition to these revision
/
f 3 control errors, the drawings were also issued without Project gl ((2 Manager's signature / initials. A subsequent revision R9
((. The references in the title block the November 30 issue.
nonconforming condition for the duplicate issuance was reported in SCR SQN SQP8601 R0 dated January 11, 1986.
- 3. Concern SQM-6-003-003 A review of the app 1'icable drawings 15W810-44 R7 and 45W833-1 R9 found that both were issued without the Project Manager's initials in the title block. The SQN mylar copies included initials at the time of investigntion but the microfilmed aperture cards which were sent out on distribution did not.
Since the cards were reproduced from the mylars, it was evident that the initials were added after issuance and 3
e
)
. s
- ATTACHMENT D PAGE 5 0F 7 distribution. SQN document control personnel stated that the initials were added by unauthorized personnel and in a manner which contradicted office practice. The DCU office supervisor stated that the proper method of correction was by reissuance of the drawing, recall of the incorrect drawing, and a memorandum of explanation to the document holders. He stated that this -
correction would be initiated promptly. The nonconforming situation was reported in SCR SQN SQP8603 RO dated January 11, 1986.
4 Concern SQM-6-003-004 As noted above, it was found that drawings 15W810-44 R7 and 45W833-1 R4 were issued without the Project Manager's initials and th'at, initials were added to the mylars without authorization after issuance. Because of this bypassing of appropriate corrective action, which should have included recall of the incorrect drawings and reissue of correct ones, the distributed drawings were left in an uncorrected status. "Thus, the addition of initials to the mylars did not cause anything to be changed in the system of distribution. It was determined that numerous individuals had access to the mylars and could have placed the initials. It is not known who placed them or what their motivation may have been. The nonconforming condition concerning the initials is included in SCR SQN SQP8603 RO.
- 5. Concern SQM-6-003-005 Three draft SCRs dated January 11, 1986, concerning document control problems identified in this report were fcuno to have been submitted to the SQN Design Project Coordinator. The Project Coordinator stated during interviews with NSRS that an initial decision had been made to consolidate the three SCRs into one. However, after the writer of the SCRs indicated that this " consolidation" might obscure the facts of the nonconform-ing conditions, it was decided to go ahead and issue the SCRs exactly as written by the original writer. USRS eonfirmed by review of the employee's original handwritten draft SCRs and the issued SCRs (SQN SQP8601 R0, SQN SQP8602 RO, and SQU SQP8603 RO)
N that the issued reports were word for word as originally drafted. The issued SCRs were dated January 11, 1986, and, according to the Project Coordinator, were transmitted January 17. USRS confirmed that the SCRs were transmitted and received for tracking, evaluation, and corrective action by reviewing the TROI open item and reporting system report dated February 1,1986, w'hich showed the applicable SCRs as assigned and in progress. With the transmittals having been initiated Friday, January 17, and the employee's statement of concern dated Tuesday, January 21, it appears that the concerned individual may not have known that the SCRs had in fact been processed and transmitted exactly as originally written.
4
.. ATTACitHENT D PAGE 6 OF 7
- 6. Concern SQM-6-003-006 The facts of this concern are covered fully in the above report for SQM-6-003-005.
IV. CONCLUSIONS AND RECOHHENDATIONS A. Conclusions
- 1. Concern SQM-6-003-001. The employee's concern was substantiated.
- 2. Concern,SQM-6-003-002. The employee's concern was substantiated.
- 3. ConcernSUM-6-003-003. The employee's concern was substantiated.
- 4. Concern SQM-6-003-004. The employee's concern was substantiated.
- 5. Concern SQM-6-003-005. The facts of the employee's concern were not substantiated.
- 6. Concern SQM-6-003-006. The facts of the employee's concern were not substantiated.
B. Recommendations None. The applicable concerns have been documented for analysis and corrective action by SCRs SQN SQP8601 RO, SQN SQP8602 R0, and SQN SQP8603 R0, all dated January 11, 1986.
..s. .
l 5
o
r -
, s
. ATTACHMENT D PAGE 7 0F 7 DOCUMENTS REVIEWED IN INVESTIGATION 1-86-180-SQN AND REFERENCES
- 1. Nuclear Quality Assurance Manual (NQAM), Part III, Section 1.1, " Document
\ Control " Revision March 21, 1985 Office of Engineering Procedure OEP-08 RO, " Design Output" h 2.
N 3. Sequoyah Nuclear Piant Administrative Instruction SQNP AI-25 R12. " Drawing Control After Unit Licensing"
- 4. Drawing Management System Report dated February 7, 1986, " Drawings Af fected by ECN/FCR (for ECW L6027) ,
- 5. Tracking and Reporting of Open Items (TROI) Report dated February 1, 1986
\ 6. Significant Condition Reports (SCRs) SQN SQP8601, 8602,'8603 (all RO)
- 9, 6%
- O I
6 o
_._ ._._ _ _ r .._ _ _ _ . _ _ . . - , . _ _ _ . ___ . _ _ _ _ _ . _ _ . . _ _ _ _ _ _ _ . _ - _ . _ _ . _ , _ _ , _ . _ _ _ __ . _ _ _ _
1 ATTACllMENT E PAGE 1 0F 7 TENilESSEE VALLEY AUTil0RITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT No. I-86-185-SQN EMPLOYEE CONCERN
- ....-../
SQll-6-002-005 SQM-6-002-006 /
SUBJECT:
SEQUOYAll NUCLEAR PLANT VENDOR DRAWING CONTROL DATES OF FEBRUARY 12-13 and 19-20, 1986 INVESTIGATION:
3 /6 INVESTIGATOR:
W mqle v
' DATE J. J. KNIGilTLY REVIEWED BY: /d/r er 9 I<d _7 d No DATE
!!/ Af K6LTOWICll
~ ~
JM/ DATE APPROVED DY:
W. D. STEVENS e .
88e, e
4 0
, a .
- ATTACHMENT E PACE 2 0F 7
- 1. DACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to 8 determine the. validity of expressed employee concerns received byThe the Quality Technology Company (QTC)/Employeo Response Team (ERT).
concerns of record, as summarized on the Employee Concern throughAssignment
-006, Request Form from QTC and identified as SQH-6-002-002 stated:
son-6-002-002 Specific supervision is not responsive to correcting a quality probicm in a timely manner which can and is affecting the quality'of the plant. (Names / details known to QTC, withheld to maintain confidentiality.)
No further information may be released. Nuclear Power concern. CI has no further information.
The office supervisor for the SQN ,t QTC Clarification:
Engineering Project was asked by the employee to have a vendor drawing audit conducted in 1985 but no audit was performed.
SOM-6-002-001 Specific supervision has neglected to perform a scheduled assignment which results ir a continuous quality impact on the plant. (Names / details known Nuclear to QTC, withheld to maintain confidentiality.)
No further information may be Power concern.
released. CI has no further information.
An audit of vendor drawings was to QTC Clarification:
havo been performed in September 1985 af ter a TVA drawing audit, but the vendor audit was cancelled.
b) ' SOM-6-002-004 J \h Specific supervision stopped corrective action on a quality problem that had been identified months earlier.
(Names / details known to QTC, withheld to maintain confidentiality.) No further information may CI has no further be released. Nuclear Power concern.- -
information. ,
Supervisor denied a written requent QTC Clarification:
submitted by employco on January 9, 1986, to perform a vendor drawing audit.
1
r--
l l
.~ . .
[ *
!. ' ATTACHHENT E PACE 3 0F 7
- c S
_OH-6-002-005 Controlled documents contain conflicting data relating (Names / details known to QTC, to the same installation. No further ,
withheld to maintain confidentiality.)
information may be released. Nuclear Power concern.
CI has no further information.
Applies to design drawings-mylars.
QTC Clarification:
' check wash-off los for specifics. Better controls are
/
}/neededfortheoriginalmylars.
l '
' SOH-6-002-006_'
Work is being performed to documents containing(Names / details known t conflicting or obsolete data. No further QTC. withheld to maintain confidentiality.)
I information may be released. Nuclear Power concern.
CI has no further information.
Concern is based on programmatic QTC Clarification:
c problems that both a new mylar and old may exist with l each containing different data.
l II. Scope A.
The scope of this investigation was determined from the stated concerns of record and the respective QTC clarifications to be that of only the specific concerns contained in the stated QTC clarifi-cations. .
B.
To accomplish this investigation, NSRS reviewed applicable require-L ments, procedures, drawings, drawing logs, and correspondence.
Additionally, responsible drawing control and reprographics i
personnel wore contacted to discuss the employee's concerns, i
III. SUHKARY OF fit! DINGS Requirements an Commitments A.
1.
Division of Engineering Design Management and Engineering Data Systems (HEDS) Procedure "The TICMP does23.05, "EN DES not maintain and Vendor Dr pro-1975 l Information Services."
- original vendor derswings unless they haveAllbeen otherplaced vendorunder TV l
revision control and sent to TIC for storage.
originals which were submitted to the TIC prior to 1975 have l been or are being microfilmed and destroyed."
l .
2
1 g . . ,
l
/
]
ATTACliMENT E PAGE 4 0F 7
- 2. Of fice of Engineering Of fice Instruction OE-01 3001, " Drawing Originals - Checking Out and Checking In."
B. Findings
- 1. Concerns SQM-6-002-002 and SQM-6-002-003 The Office Supervisor for the sequoyah Nuclear Plant (SQN)
Enginocring Project came to the position in January 1985. He stated that drawing controls at that time for both the TVA and vendor drawings were not fully adequate; that original drawings for SQN design w?rk were not always immediately available as needed; and that first priorities for correction were placed on the TVA drawings and on several other critical matters affecting the SQN' engineering design effort. The vendor drawings received a second priority. The immediate supervisor verified to NSRS that this statement of priorities represented,the management priorities at that time.
In order to verify that all TVA drawings were available and to correct any deficiencies by reordering replacements (washoffs),
l a TVA drawing audit was conducted during September-October 1985. The Office Supervisor verified the employee's statement that an audit of vendor drawings was to have been performed at
?
the conclusion of the TVA drawing audit. He stated that the vendor drawing audit was postponed from October 1985 to January 1986 because staff was needed on other projects, but that the audit was begun in January and had been in process for three weeks.
. In order to maintain a dated listing of all replacement drawings I
requested from Office of Engineering, Knoxville, a washoff log was initiated by the SQN office Supervisor on August 1, 1985.
The log included 240 entries at the time of the investigation in
! February 1986. Of these, approximately 220--over 90 percent of the total--were for replacement vendor drawings with the remainder being for TVA drawings. The further investigation of those orders is reported below under finding No. 3.
I
- 2. Concern SQM ,6-002-004 It was verified that the employee submitted a written request dated January 9, 1986, requesting overtime on several weekdays
- and a Saturday to set up contract flies and audit "B" size TVA
- drawings. This request was denied by the supervicor in a form i
TVA ASD memorandum also dated January 9, 1986. The supervisor
- stated in the memorandum that he wanted to work with tho l cmployee with regards to contract drawings and noted that ". . .
! we have real problems with manufacture drawing originals." He l wrote that, "I currently am working on other clorical items with l deadlines and cannot work with (the employce) . . . I am well j aware of us being deficient as far as an audit is concerned but t
3 f
- o. ,
l ATTACHMENT E PAGE 5 0F 7 we have been deficient since I arrived in January 1985. I don't feel another two weeks is going to be that critical to us."
Later that same month the vendor drawing audit and corrective action activitics were started and were in their third week at the time of this investigation. ,
- 3. Concerns SQM-6-002-005 and SQM-6-002-006 At'the time a drawing original is determined to have been lost, a replacement original ("washoff") is requested from the Office of Engineering, Knoxville. The washoffs are produced from the microfilm aperture cards maintained by the Technical Information Conter. As noted above, apptwimately 240 washoffs were requested between August 1, 1985, and February 1986, with over 90 percent of'the replacements being for vendor drawings. The OE Reprographics Supervisor stated that because the vendor drawing originals before 1976 were routinely discarded, there is a periodic need at the sites to provide washoffs from the aperture cards. He did not believe that the quantity of SQN requests was unusual. He stated that SQN was the first site to centralize the authority for washoff requests, thus minimizing duplicate or unnecessary requests. He indicated that Knoxville desired similar centralization at the other sites.
When a replacement drawing is received at the Office of Engineering SQN site, the replacement is checked in and becomes the new " original" which will be the baseline drawing for subsequent changes. If a missing drawing should eventually reappear and not be properly dispositioned, the potential would exist for the two " originals" to contain obsolete or conflicting data whenever one drawing was updated but not the other. The controls which are now in place to avoid lost and duplicative drawings include the following:
(a) Drawing checkout system: Drawings are checked out from the drawing tanks on a Drawing / Print Request Form which includes a self-checking section for removal of drawings after hours if necessary. It was determined that the Office of Engineering Section heads had keys to the drawing area for access after normal working hours when drawing control personnel were not present. Although this provides some possibilities for drawings to " stray" af ter hours, the office supervisor did not believe this to be any major problem. He vigorously supported the necessity for 24-hour access to the, drawing originals, demonstrated the case-of-use of the chockout forms, and stated that the checkout records woro updated promptly each morning from any forms left during t e night-fV f Q <j p g -
6cd,;hk/[A sne jf
a se o . .
ATTACliMENT E PAGE 6 0F 7 (b) Drawing check-in system: Whenever it is necessary to p, request a replacement for a lost original, a note is placed in the drawing checkout file for any cases where the lost ff original reappears. Subsequently, if a drawing being
,j $/ checked in is one for which a replacement had been ordered.
'r / .
/ f the document control clerk is flagged to cancel the J replacement order or to withdraw one or the other original Jb>'
fN,tg[$
from the system. ,
g- (c) Centralized ordering of replacements: As noted above, SQN is the first TVA site to centralize the authority for washoff requests. OE Reprographics is to deny all requests except those channeled through the authority. The OE Supervisor of Reprographics stated.that this centralization is helping to eliminate duplicative requests wherein two or more individuals might order the same replacement.
IV. CONCLUSIONS AND RECOMMENDATIONS A. Conclusions
- 1. Concern SQM-6-002-002. The employee concern for vendor drawing controls is substantiated, but the concern for supervisory responsiveness is not substantiated. The vendor drawing audit was delayed until 1986 because of other reasonable priorities.
The audit is now in progress.
- 2. Concern SQM-6-002-003. The employee concern is not substan-tlated. Supervisory neglect was not identified. .
- 3. Concern SQM-6-002-004 The employee ccncern is not substan-tiated. The supervisor denied a request for overtimo but did not stop corrective action. Corrective action is in progress.
The employee concerns
- 4. Concern SQM-6-002-005 and SQM-6-002-006.
f or duplicative mylars are substantiated in that this condition does sometimes exist. The concern is mitigated by the finding that several controls are in place to minimize the condition.
Support was not identified for additional controls such as further limitation of access to the mylars.
D. Recommendations 1-86-185-SQN-01, Tracking of corrective Action Corrective action concerning SQN vendor drawing controls is in progrecs through (1) performance of a vendor drawing audit which began January / February 1986 and (2) controlled replacement of drawings where needed. Controls to minimize recurrence of dupli-cative mylars have been developed and are in place. Thero are no additional recommendations, but SQN should provide notification to llSRS when corrective action is completed. [P-3)
S
^
,s- o_ . ,.
V., ,
ATTACHMENT E PAGE 7 0F 7 1-86-185-SQN DOCUMENTS REVIEWED IN INVESTICATION AND REFERENCES 1.
Office of Engineering Office Instruction OE-OI 3001, " Drawing Originais -
Checking Out and Checking In" 2.
Division of Engineering Design Hanagement and Engineering Data Systemsi (MEDS) Procedure HP 23.05, "EN DES and Vendor Drawings - Inf ormat on Services" 3,
Office of Engineering Office Instruction Manual OE-01 4003, " Prints and Microfilm - Routine Distribution" 4.
Memorandums S, L,"Dhdd to John Dennis.and Jack Valentine dated January 9, 1986; and Jack W. Valentine to John Dennis dated January 9, 1986 s
t I
~
s e
9 O 9 g
D 9 .
- hQ6 9
4 1
I
_ _ _ _ , _ . , _ _ _ . _ _ _ . _ , . _ _ _ , . _ , _ , , . , _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _____, ___ ._. __ .. _ __ . . _ _ , _ _ _ _ _ _ , _ _ _ _ _ _ _ . _