IR 05000327/1993041
| ML20057C269 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/15/1993 |
| From: | Casto C, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057C267 | List: |
| References | |
| 50-327-93-41, 50-328-93-41, NUDOCS 9309280154 | |
| Download: ML20057C269 (12) | |
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Report Nos.:
50-327/93-41 and 50-328/93-41 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-327 and 50-328 License Nos.:
DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: August 16-20, 1993
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Inspector:
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H. M Trener Fate Signed
Other Inspectors:
C. F. Smith A. R. Long
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Approved by:
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C. Casto, Chief
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Test Programs Section
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Engineering Branch Division of Reactor Safety
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SUMMARY Scope:
This special, announced inspection was conducted in the areas of drawing
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control, drawing backlogs, and followup on previously identified drawing control issues.
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Results:
In the areas inspected, violations or deviations were not identified.
The licensee has reduced the number of Category 1 drawing deviations on Unit 2 to 115. The remaining Category I drawing deviations will be resolved and closed out prior to restart. Violation 50-327,328/93-14-01 remains open pending completion of this task.
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9309280154 930916 PDR ADOCK 05000327 G
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As part of the Site Improvement Plan the licensee is formulating plans to ensure that drawing changes are completed at closure of design change
documentation and resources are allocated and a schedule developed to upgrade
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the Category 3E backlog to Category 2 by March 31, 1994. Additionally, a plan for evaluation of Category 3 drawings to identify the need for revising these drawings will be completed by November 30, 1993.
i The inspectors considered these initiatives to be positive steps toward the resolution of drawing problems at Sequoyah.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- M. Anderson, Design Control Manager, Site Engineering
- J. Bajraszewski, Licensing Engineer
- J. Baumstark, Operations Manager
- C. Brimer, Project Engineering and Support
- L. Bryant, Maintenance Manager
- M. Burzynski, Site Engineering Manager
- M. Cooper, Maintenance Program Manager
- R. Drake, Project Management / Controls Manager
- R. Driscoll, Site Quality Manager
- R. Fenech, Sequoyah Site Vice President
- T. Flippo, Site Support Manager
- D. Lundy, Technical Support Manager
- J. Maciejewski, Operations and Maintenance (0&M) Manager K. Meade, Licensing Engineer
- M. Needham, Customer Group 0&M Manager
- S. Poage, Quality Audit and Assessment Manager
- K. Powers, Plant Manager
- J. Proffitt, Licensing Engineer H. Rogers, Technical Support Program Manager
- R. Shell, Site Licensing Manager
- M. Skarzinski, Technical Programs and Performance Manager
- R. Thompson, Compliance Licensing Manager P. Trudel, Design Engineering Manager
- J. Ward, Enginereing and Modifications Manager Other licensee employees contacted included engineers, operators, QA/QC personnel, and other plant personnel.
NRC Employees
- C. Casto, Section Chief, Region II
- W. Holland, Senior Resident Inspector
- P. Kellogg, Section Chief, Region II
- A. Long, Resident Inspector
- S. Shaeffer, Resident Inspector
- Attended exit meeting Acronyms and initialisms used throughout this report are listed in the last paragraph.
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2.
Drawing Control
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a.
Background Information An NRC review of the drawing control program was performed at Sequoyah in April 1993 (NRC Inspection Report 50-327,328/93-14).
In that assessment the inspectors identified violations related to timely engineering closecut of primary (Category 1) Drawing Deviations (DDs) and timely incorporation of drawing change paper (DDs, DCAs, FCRs, TACFs, etc.) in secondary drawings.
Category 1 drawings (also called primary, critical or control room drawings) are those drawings which are required to startup, operate, or shut down the plant. Category 2 drawings are drawings needed in support of plant operations.
Category 3 drawings are all other drawings not category 1 or 2.
As a result of the previous findings, this inspection focused on
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the category 1 DD backlog and corrective actions taken by the licensee in regard to the violations identified in NRC Report 93-14.
b.
Proposed Drawing Control Program Changes The Licensee has formulated various long term plans for accomplishing the following:
o Improving the design change control program to ensure that drawings impacted by plant modifications will be
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updated in a timely manner.
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o Performing an evaluation to identify the need to update Category 3 drawings in order to stop the current practice of the craft working with numerous
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outstanding change papers.
j The first item has been made a part of the Site Improvement Plan and is identified as Activity Number DD-34-501. The proposed i
program changes involve revising SSP 9.3, " Plant Modifications and Design Change Control" and SSP 2.10, " Vendor Manual Control," to i
provide for complete document updates prior to the design change implementation package closure. This will be accomplished by
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ensuring the availability of funds for updating the drawings within consistent closure times. The second item is also part of
the Licensee's Site Improvement Plan and is identified as Activity J
Number (M07-002A).
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Item M07-002A indicated that a plan for dispositioning Category 3
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drawings is currently being formulated. The scope of this action item is to have a plan completed by November 30, 1993, to evaluate the feasibility of dispositioning the Category 3 drawings. With a population in excess of 80,000 Category 3 drawings and with
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drawings having outstanding change papers that affects approximately 29,093 Category 3 drawings the resolution of this issue yill require long term management.
Preliminary numbers discussed by licensee management estimated approximately eight
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million dollars in resources expended over a three year period to accomplish the task.
The inspectors considered the above licensee initiatives to be significant steps in the right direction for resolving the recurring drawing problems / errors st Sequoyah.
c.
Drawing Backlogs In the April 1993, review of the licensee's drawing control, the i
inspectors concluded that the incorporation of drawing changes posted against Category I drawings was reasonably current and no backlog, with the exception of DDs, had occurred. With the resolution of the Category 1 DD backlog prior to restart, the
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inspectors considered that Category I drawings, with a few
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identified exceptions, are up to date and acceptable for restart.
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The licensee provided the current status of Category 1 outstanding changes that further supports this position.
Specifically, of 1,608 Category I drawings, 34 drawings have 37 unincorporated change papers, excluding outstanding DDs.
For Category 3E a significant backlog of unincorporated drawing changes has occurred. Category 3E drawings are drawings the licensee has determined meet the criteria for Category 2 drawings.
These drawings are scheduled to be reclassified as Category 2 with the outstanding changes incorporated on the drawings. There are 4,558 drawings in this Category with 3,898 unincorporated changes affecting 2,144 drawings. The licensee's projected date of March 31, 1994, to complete this task was considered a reasonable goal. These drawings are used in support of routine plant operations and need to be updated to reduce the burden on the user and the potential for human error. This issue was not considered a restart item based on the licensee's actions taken for resolution of the outstanding backlog.
In addition, these drawings do not directly impact routine plant operations.
A major group of uncorrected drawings is in Category 3.
These are drawings which are not needed for routine plant operation or in support of routine plant operation. Consequently, there is no time limit specified in the Administrative Procedures for incorporating drawing changes. As these drawings are not normally needed for plant operations, updating is at the discretion of the Engineering Manager; however, all change papers are on file with the drawings.
Because resources have been directed to higher priority tasks a large backlog of unincorporated changes had developed.
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The numbers provided by the licensee show that there are in excess of 80,000 Category 3 drawings. There are 42,719 unincorporated
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changes affecting 29,093 drawings. With a' backlog of this
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magnitude the inspectors decided that review of a small sample of
uncorrected drawings would not provide meaningful information r
concerning the potential for adverse impact on plant operations.
Therefore, the licensee was requested to provide a breakdown of the nature or type of drawings in Category 3.
While the description of the drawings was general, it did provide a
perspective of the nature of Category-3 drawings. An example of
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the type of drawings identified included:
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Hangers and Supports
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Architectural
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Structural Steel and Concrete
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Various Vendor Drawings (Polar Crane, Turbine Building
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Stairs, Service Building steel, etc.)
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Conduit and grounding
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Based on the inspectors evaluation of the above' types of Category 3 drawings the inspectors concluded that in general these drawings do not directly impact routine plant operation and support.
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for final disposition of these drawings are being formulated. As
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indicated above, resources have been. identified for managing this review.
Within this area no violations or deviations were identified.
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3.
Drawing Deviation's The inspectors reviewed all or portions of the selected CDs. issued against Category I drawings. The DDs were reviewed for technical i
adequacy, and the configurations described in the DDs were compared to
the drawings to confirm that the changes had been accurately reflected.
In addition, approximately twenty items from selected DDs were compared to the as-installed hardware in the field to verify that the drawings correctly depicted the actual plant configuration. The DDs reviewed
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were as follows:
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DD/Drawina Number Description i
87DD3158/1,2-47W814-1 Missing sightglasses, drains, and UNIDs on Ice
Condenser glycol mixing tank
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88DD3586:1-47W830-1 Correct piping arrangement for Monitor Tanks 88DU995/2-45N724-4 Correction of drawing notes to reflect disconnection of auto transfer from the normal to alternate feeder
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88DD4170/1,2-47W802-1; Corrections of legends for 47WA366-5-3 Extraction Steam Valves 88DD4196/1,2-47W814-1 Addition of drain isolation valves for ice making machines, and UNIDs 89004596/1,2-47W810-1 Modification of drawing to properly reflect manner in which RHR valve is locked 90DD4707/1,2-47W845-1 Addition of Unit 1 EDG Heat Exchanger Shell Side Drains to ERCW Drawing 90DD4720/1,2-47W813-1 Revisions to RCS Flow Diagram, addition of PRT sample containment isolation valves 90DD4959/2-47W811-1 Flow reducer upstream of SI Pump 2B-B and 2A-A drain valves 90DD4962/2-47W809-1 Revisions to CVCS Flow Diagram to Correct Duplicate valve numbers 900D5034/1,2-47W810-1 Revisions to RHR Flow Diagram 91DD6116/1-47W811-1; Revisions'to SI and Containment Spray 2-47W811-1; Flow Diagrams to Correct Valve 2-47W809-1 Symbols 88DD3778/1,2-47W812-1 Revisions to Containment Spray System Flow Diagram Two minor discrepancies were identified by the inspectors. Both were found to have been previously identified by the licensee and appropriately documented on restart item DCN D-09333-A.
The discrepancies were as follows:
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ERCW drawing 1,2-47W845-1 had been modified to reflect the shell side drains on Unit 1, as specified by 90DD4707.
However, these drains also existed on the Unit 2 equipment but were not shown on the drawing. This discrepancy had been identified for correction via DCN 0-09333-A. The shell sides drains were added to an ERCW drawing because there are no drawings for diesel jacket water (System 82).
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Ice condenser system sightglasses and sightglass-drains had not been added to drawing 47W8814-1 as specified by 87DD3158. The discrepancy was appropriately documented in DCN 0-09333-A.
Several hardware items examined during the inspectors' walkdowns did not yet have UNIDs due to the DDs being open and the engineering still incomplete. Examples included DD's 87DD3158, and 88DD419 '
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The inspectors selected seven DDs, issued during the previous twelve months, which represented situations where the plant hardware was known to be incorrect and the drawings correct. The selected DDs were reviewed and discussed with operations personnel in order to evaluate the rationale for the operability and reportability determinations; operator cognizance of the hardware issues; whether configuration control was adequately maintained in accordance with procedural requirements; and the timeliness of correcting the plant hardware. The i
following DDs were reviewed:
93DD6578:
Wiring discrepancy on Waste Disposal System pressure switches.
93DD6564:
Wiring discrepancy on Raw Service Water System.
93006557:
Wiring discrepancies on high radiation isolation signals to discharges of RCDT and RB Floor and Equipment Drain Sump.
93DD6553:
Wiring discrepancy affecting mid-travel indication for turbine runback.
93DD6552:
Check valve missing on control air line for MSIV.
93006549:
Hiswiring on zone switch for mid-travel indication and local annunciator on the turbine exhaust hood spray.
92DD6513:
Sensing line on 2-FSV-2-329A was connected to the exhaust port.
Of the above DDs, none were classified as affecting operability. The inspectors concurred with these determinations and with the licensee's decision that the issues were not reportable. All of the operability determinations were timely. Generally they were made the same day as the initiation of the DD.
Operator cognizance and configuration control of these issues was maintained in an acceptable manner through the WR process.
In one case, for 930D6553, the wiring discrepancy was documented in the AS05 log to apprise the operators of the status of the repair.
With the exception of 93DD6549, all equipment repairs associated with the above DDs had been completed as of the time of the inspection.
Completion of the work request associated with this DD was assigned a low priority for completion but due to the nature of the hardware problem the inspector did not consider this to be a safety concern.
Based on the review of DDs and plant drawings and the walkdown of plant hardware, the inspectors concluded:
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The DDs which have been posted and backcircled on Category
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I drawings accurately depict the plant configuration.
The licensee review of DDs for reportability and operability
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has been adequate.
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The DD screening process for matters which could affect safe plant operation appears effective as the DDs reviewed by the inspectors had minimal safety significance.
Within this area of the inspection, no violations or deviations were identified.
In all cases examined, plant hardware problems addressed through the DD process were resolved in an acceptable manner.
4.
Action on Previous Inspection Findings (92702)
a.
(Closed) Severity Level V Violation-(50-327,328/93-14-02):
Failure to follow procedure for elimination of drafting errors.
The licensee response dated June 21, 1993, was considered acceptable by Region II. The inspector reviewed an Attendance Roster and verified that on June 24, 1993, a training meeting was conducted with Sequoyah Site Engineering personnel concerning the responsibilities of drawing preparers and checkers. Additional training sessions were held on July 7 and 8, where the importance of everyone checking their work was further discussed. The inspectors determined that a total of approximately 150 persons attended the above training sessions. The Licensee also performed an incident investigation to identify the root causes of the violation. The results of this investigation are documented in report number II-S-93-037, Drawing Control.
Paragraph "V" of that report concluded that drawing problems / errors were recurring problems at Sequoyah and past corrective actions had not been effective in correcting these problems.
On June 13, 1993, Licensee personnel, while establishing a clearance to implement Design Change Notice (DCN) M-9507 on moisture element ME-32-8, initiated an event which resulted in the isolation of the "A and B Control Air Headers" in the Auxiliary Building.
The Licensee performed an incident investigation and determined the root cause to have been drawing errors involving mislabeling of Headers A and B on drawing number 47W482-2. These drawing errors occurred in 1977 during revision of the control air flow diagrams. The inspectors reviewed the results of the incident investigation documented in report number II-S-93-050, Loss of Non-essential Air, and interviewed Station Management to determine what additional corrective action plans had been developed to address the recurring drawing errors / problems. The inspectors were informed that a comprehensive evaluation of the drawing program functionality was being conducted at the time of the inspection. This effort consisted of distributing a " Drawing
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l Program Questionnaire" to approximately 129 employees soliciting.
their opinions concerning various attributes of Categories 1, 2 and 3E drawings. Analysis of the responses from this survey of the end users of the station drawings will be used by Station Management for accomplishing the following:
o Identify problem drawings / series e
Determine the extent to which each drawing series is used e
Identify program enhancements similar to the transition flag location program o
Determine priorities for focusing resources in drawing i
problem resolution I
The inspectors concluded that the Station Management's effort to identify.the scope of the drawing proolems/ errors at Sequoyah and develop long term corrective action plans for its resolution was
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acceptable.
Based on the completed short term corrective actions
involving personnel training and the ongoing long term corrective actions involving evaluation of the drawing program functionality, this item is closed.
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extent of the violation, taken action to correct current
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conditions and developed corrective actions needed to preclude l
recurrence of similar problems. Corrective actions stated in the i
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(0 pen) Severity Level IV Violation (50-327,328/93-14-01):
Failure to follow procedure resulted in untimely updating of drawings.
l The licensee response dated June 21, 1993, was considered acceptable by Region II. The inspector reviewed Incident j
Investigation Report-No. S-93-037, Drawing Controls and verified
that the Licensee had identified the root causes and had developed corrective action plans for their-resolution.
Commitment Completion Form No. NC0930163001, dated August 1, 1993, documented
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completion of the corrective action involving revision of SQEP-17,
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Section 2.5, to clarify the definition of Category 2 drawings.
The need for revising Nuclear Engineering Procedure NEP-5.1 will be determined up::n Corporate Nuclear Engineering completing an j
assessment of the implementation of drawing category definitions i
in NEP-5.1 at all sites.. Also, Commitment Completion Form No.
NC0930163002 documented completion of corrective action related to developing a management performance indicator for the Drawing Deviation (DD) process to alert Station Management of any deficiencies in DD implementation. Additional corrective actions delineated in the Licensee's response of June 21, 1993, involved updating Category 1 drawings to incorporate approximately 500 DDs
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by August 15, 1993.
Long term corrective actions were also committed to with regard to (1) updating high use Category 3 i
drawings by March 31, 1994 and (2) dispositioning remaining DDs with a scheduled completion date of March 31, 1994.
Both of these corrective actions will be performed as part of the Site Improvement Plan (SIP).
The inspectors reviewed objective evidence in the form of line graphs for Units 1 and 2 category 1 Primary DDs and determined that the licensee had an outstanding balance of 76 DDs and 115 DDs for Unit I and 2 respectively as of August 15, 1993. The inspectors expressed concern at the Licensee's failure to complete the corrective action stated in their response of June 21, 1993.
Discussions with Station Management was held concerning this issue and it was mutually agreed that the Category 1 primary drawings would be made operationally ready prior to restart by incorporating all outstanding DDs. The Licensee did not specify a date when this corrective action would be completed. Station Management, however, said that all outstanding DDs for Category 1 primary drawings would be incorporated prior to entering mode 4.
This violation is left open pending the licensee completion of the Catt. gory 1 primary drawings update to incorporate all outstanding DDs.
5.
Exit Interview The inspection scope and results were summarized on August 20, 1993, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
(1)
Violation 50-337,338/93-14-01 remains open pending incorporation of drawing deviations, for Category 1 primary drawings.
(2)
Violation 50-337/338/93-14-02 is closed.
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Acronyms and Initialisms ASOS -
Assistant Shift Operations Supervisor Chemical Volume Control System CVCS
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Drawing Change Authorization DCN
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Design Change Notice DD
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Drawing Deviation ERCW -
Emergency Raw Cooling Water FCR
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Field Change Request II
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Incident Investigation Main Steam Isolation Valve MSIV
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NRC
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Nuclear Regulatory Commission PRT
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Pressurizer Relief Tank RB
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Reactor Building RCDT -
Reactor Coolant Drain Tank RCS
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Safety Injection
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Site Improvement Plan TACF -
Temporary Alteration Control form UNID -
Unique Identifier
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