ML20045D284
| ML20045D284 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/21/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306280174 | |
| Download: ML20045D284 (10) | |
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t Tennessee Valley Authonty, Post Office Box 2000. Sraddy-Daisy, Tennessee 3737F-2000 Robert A. Fenech
%ce Presdent. Sequoyah Nuclear Plant l
June.21, 1993 U.S.' Nuclear: Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-Gentlemen:
In'the Matter of 3-A Docket N s.-50-327-'
- Tennessee Valley Authority
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L50-328 SEQUOYAH NUCLEAR P1 ANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/93 RESPONSE' TO NOTICE OF VIDIATION- (NOV) ~ 50-327, 328/93 14-01,..
-02, AND -03 Enclosed is.IVA's response to Albert F.'Gibson's letter to-Mark O. Medford. dated May 20, 1993, which transmitted the: subject h0V.
The' fitst and second violations addressed the-untimely' update ~ of drawings and drawing errors, respectively..The third', violation addressedL
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inadequate corrective action in the implementation'of' maintenance.
requirements recommended by environmental qualification;(EQ); A: weakness was identified regarding the. backlog. of EQ program binder linformation.-.
, provides IVA's?. response.to theLNOVs and-.the requested response to the weakness. Commitments contained in'this submittal:are provided in
Enclosure:
2.
T If-you have any questions concerning this submittal, please telephone-R.LH. Shell att(615) 843-7170.
Sincerely,'
Y.
Robert'A. Fenech-
- Enclosures'
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U.S. Nuclear Regulatory Commission Page 2 June 21 1993 cc (Enclosures):
Mr. D. E~.LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North' 11555 Rockville Pike
- Rockville, Maryland' 20852-2739 NRC Residen'tLInspector
- Sequoyah Nuclear Plant.
2600:Igou Ferry Road.
Soddy-Daisy.nTennessee 37379-3624.
RegionalLAdministrator U.S. Nuclear Regulatory Commission Region II
,r 101lMarietta Street, NWs Suite 2900
' Atlanta, Georgia; 30323-2711 J
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' ENCLOSURE:l'
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TESPONSE TO NRC INSPECTION REPORT WOS. 50-327/93-14 AND 50-328/93-14 ALBERT F. GIBSON'S LETTER TO MARK 0. MEDFORD DATED MAY ' 20,1993 Violation 50-327. 328/93-14-01 "10 CFR 50, Appendix B, Criterion V requires,. in :part',; that activities L
affecting quality shall'be accomplished-in accordance.with documented instructions.
Instructions documented ~in Sequoyah' Engineering Procedure,-
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SQEP-17. Procedure ~for Drawing' Control,l require:that drawings;needediforf R
support or plant operations be classified as Category 2 and updatedi j
within 180 days from the-issuance of; Drawing Change. Authorizations.
Instructions documented.in Site Standard. Procedure, SSP-2.ll,'Drawingi 9j Deviations, require a documented evaluation of'the potential. adverse; 1
impact for Design' Change Notices.which are not expected _to be issued within 60 Gays from the date that the need for.a drawing change'is:
verified..For Category 1 (Control Room) drawings, SSP-2.11Mfurther
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requires that the DDs be engineered-(drawings;and'related documents d
affected by-the DD must be reviewed and corrected) within 90'daysLof the'.
2 DD being posted as INSTV (verificatist that the installed condition is correct) in-the DCCM data base.,
" Contrary to the above, on April 20, 1993:.
1.
The following drawings'needed'for support'of-plant _ operations wera erroneously classified as: Category 3 and had notL been update'd within 180 days from the issuance of Design Change ~A'thorizations:
u Drawine Number
' Dgairn Change' Authorization CCD No. 2-45N2638-13 L6478-664-CCD No. 2-45N2639-9
~L6478-671
.CCD No. 2-45N2639 'L6478-673.
2.
Design Change Notices had not been issued,LnorTha' l impact d
evaluations been documented, within the specified'60 days'for over 1100 drawing deviations.. Also, for over'250 Category l' drawings, the applicable drawing deviations had not beenLengineered;(i. e'.,
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drawings and related documents'affected had not:been fully reviewed-and corrected)'within the required.90 days.-
"This is a Severity Level IV violation (Supplement.1)."'
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Reason for the Violation-Example No. 1:
An inadequate. procedure was7the.cause for the. drawing; classification that' resulted in. the drawings 'not' being updated.,1The procedure. contained f an
. inadequate' definition and process description ^ for:-. Category' 2 drawings.
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before issuance of the revised Nuclear Engineering (NE). procedures-for' drawing control, the NE organization' requested that the plant Operations _
and Maintenance organizations identify high-use~ secondary drawings. -The plant responded with a list of high-use drawings that.resulted in the current smaller Category 2 drawing population that was coded'in the Document Control Change Management System (DCCM). NE performed a drawing-review and identified an additional group of drawings.(approximately.
5,400) that were high-use drawings-and requested: plant fundf.ng for updating (incorporation'of outstanding. posted change documents) and rollover to Category 2.
After these e*aluations had been~ completed,.the.
NE drawing control-procedure was' revised. The' Category 2 definition and' implementation process that was contained in the procedure.was inccrrectly interpreted by the users as.being consistent with the preplanned process for Category 2. drawing identification.- It has buen concluded that the procedural definition of Category 2 drawings was incorrect and that the, correct population of-Category 2 drawings was identified by NE, Operations, and Maintenance efforts.
Example No. 2:
The cagge for the failure to incorporate drawing deviations (DDs) within administrative timeframes is inadequate manageme 6 attention to DDs, resulting in the DD program receiving low priority.{
High'r-priority; work e
resulted in the reassignment of resource. and' allowed DDs to remain open' and accumulate into a backlog..
Carrective Steps That Have Been Taken and'the Results Achieved' Example No. 1:
The Category 3 drawings identified in the NE review as high use are a backlog issue that has been incorporated into the Site Improvement Plan (SIP). NE is scheduled to start-updating these drawings by. July 1993, with a scheduled completion date of March 31, 1994.
Example No. 2:
NE is in the process of upe aing the drawings to incorporate approximately 500 DDs through the current effort.to complete the engineering of DDs' associated with Category 1 drawings.
This effort.is scheduled to be completed by August 15, 1993.- The remaining DD backlog has been factored into the SIP, with a scheduled completion date of March 31, 1994.
. Corrective Actions That Will be Taken to Avoid FurthcI_31Dlations Example No.1:
l NE procedures associated-with drawing control will be revised tol correctly address the definition of Category 2 drawings.
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' Example No. 2:
A management, performance-indicating tool will be developed for the DD process to raise management's attention to DD implementation.
The Date When Full Compliance Will be Achieved Full compliance will-be achieved by August 23, 1993, after the revision of NE drawing control procedures and the development'of a management,:
performance-indicating tool for the DD process. The existing configuration management program at SQN allows'the use of'as-constructed or configuration-control drawings plus posted changes in the DCCM to define the configuration of plant, systems..comronents, and structures.
Violation 50-327. 328/93-14-02 "10 CFR 50, Appendix B, Criterion III, and the licensee's accepted Quality Assurance Program, TVA-NQA-PLN89-A, Nuclear Quality Assurance-Plan, Revision 3, Section 7, require measures which assure that' applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
IVA-NQA-PLN89-A, through Section 7'and Appendix B, endorses requirerrats of ANSI N45.2.ll-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants. This standard, Section 4.0, requires that design activities shall'be prescribed and accomplished.in accordance with procedures which assure that applicable' design inputs are correctly-translated into specifications, drawings, procedures or instructions.
" Contrary to the above, the design. input was not correctly-incorporated i
into drawings, as the drawings werc found to exhibit errors. Sequoyah Engineering Procedure, SQEP-17, Procedure for Drawing Control, Revision 13, describes the process used at Sequoyah. Nuclear Plant to develop, revise, and issue design output drawings.. Section 3.2.12 of this procedure requires that the Responsible Discipline Engineer revise Configuration Controlled Drawings (CCDs) to eccurately reflect engineering changes conveyed by Design Change Authorizations, marked-ups
[ sic] drawings, and associated Field Change Requests / Field-Design' Change Notices. The following drawings were approved and issued for use on the 1
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's'pecified dates without complying with the-requirements of SQEP 17 in that draftingLerrors were contained on the drawings.
Drawing Number
.lasue Datg-
-DIAftine Error
.,r CCD No 2-45N2638 '04/21'92 JIncorrect wire numbers on.
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.TB-123 points 5, 6,'anda7.
j CCD No'2-45N2638-8 04/21/92;
-Incorrect' vendor drawingi number:
il CCD No 2-45N2638-51 04/22/92
-Incorrectiwire number,
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-onLTB-3-11[ point'2<
.3 "This is a Severity' Level V violation (Supplement:1)."-
Beason for the Violation The - cause for errors on' drawings was detemined 'to be 'a : result of
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. inattention'toidetail. Drawing (reviews' indicated'thaththe errors were.
l the result of' drafting transpositions and; omission'.f.A review'of the1 drawing revision process'indicctedLthst these! deficiencies were.
-individua1Limplementation problems.-
r Corrective Steps That Have Been Take.n and the:R'esults Achleied
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The drawings containing the errorsithat were: identified during;the
. i inspection were revised. The revised drawings.wereLreviewed'and:the
'information was found to'be~ correct.
Corrective Actions That Will be'Taken to Avoid Further Violationg'
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Management will--discuss the need.for' attention to detail relative to the issue of drawing errors with NE employees toLraise~ employee! sensitivity.'
This is being conducted in conjunction ~with-ongoing efforts:to.iraise'the sensitivity of~the general site population in support of: restart.-
Date When Full Compliance Will be Achieved ~
Full compliance will;be achieved by July 23, 1993,- after management-completes' meetings with~ employees tol raise l employee sensitivity to1the issue of drawing errors.
Violation-50-327. 32&/93-14-03 "10'CFR 50, Appendix B, Criterion'XVI, Corrective Action, requires that measures shall:be established'to: assure that conditions adverseEto.
quality areJpromptly11dentified"and;correctedI.-IIn:theicase'of significantJconditionsfadverse to, quality the_ measures sha11; assure that:
the' corrective ~actionitaken will preclude. repetition.,
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" Contrary to the above, since 1989 the licensee had repeatedly failed to implement prompt corrective action to resolve the condition adverse to quality described in Quality Assurance (QA) audit finding PRD SQA890203910P.
The audit finding revealed for the first time that some of the recommended maintenance / surveillance activities' ortlined in the environmental qualification (EQ) documentation. files (Binders) were not being properly addressed by the plant preventive maintenance program or surveillance program.- The EQ Administrative procedure'in effect at the time (SQA 173) required one of three actions: (1) implement the recommendation fully, (2) establish and implement an alternative, or (3) do not perform the recommendation. The'latter two action items required that an evaluation be documented justifying that' the alternative action or nonperformance will not have a detrimental effect on the reliability of the equipment.
The= audit finding indicated that contrary to the requirements of Sequoyah Administrative Procedure SQA 173 that not all EQ recommended maintenance and surveillance items had been properly incorporated into the plant preventive maintenance program'or.
surveillance program. The correct 3vt. action proposed to.close out the audit finding was never fully implemented by the licensee. The problem was re-identified in auditing findings SQFIR910084 and SQFIR920059, in 1991 and 1992 respectively, with corrective action still not'being completed. As a consequence, the' licensee has continued to be in nonconformance with procedure. requirements, now Site Standard Practice SSP 6.5,'to either perform or. justify nonperformance of EQ reenmmended maintenance / surveillance items.- For example, the recommended EQ Maintenance for EQ Binder SQNEQ-MOT-004 had not been implemented and an evaluation had not been performed.
"This is a Severity Level IV violation (Supplement 1)."
Reason for the Violation Because of inadequate program accountability, the organizations responsible for program implementation were unable to resolve the issues associated with the method and time for implementation of the EQ maintenance recommendations. Upon initial development of the EQ program, one organization provided oversight of the various program requirements.
This accountability was not maintained by the Maintenance organization for continued program implementation. The lack of program accountability-resulted in inadequate resources for program implementation and a lack of.
management attention to resolve issues between the Maintenance and NE organizations.
The Maintenance organization requested that NE evaluate EQ recommendations because Maintenance believed that some EQ recommendations may not require the issuance of preventive-maintenance (PM) instructions. NE believed that'the justification for not performing
'the recommendations must be provided before dispositioning the recommendations.
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"The Corrective Steos That.Have Been Taken and the Results Achieved l
An EQ PM file has been developed.to identify maintenance items outlined on the qualification maintenance data sheets (QMDSs). NE has reviewed existing EQ maintenance recommendations and.has idc-atified'those required-to maintain qualification of the' equipiaent. Two binders werel identified with items that needed to be. completed before-restart from~the current outages and have been scheduled for implementation..
Ibe Corrective Actions That Will be Taken to Avoid Further Violationg The QMDS requirements and recommendations.have been reviewed a d revisions are being identified in the EQ PM file.. PM requests will be issued to address these revisions,. including scheduled implementation dates.
A site EQ program organization has been formed under the Technical Programs and Performance Manager that will oversee both plant and-engineering activities. LThis will provide' program ownership and responsibility to one organization'and ensure appropriate program accountability.
The site procedure addressing the EQ program will be revised to incorporate the requirement for the EQ PM file.- This revision will also incorporate the new organizational changes for management offthe EQ-program.
The Date When F.pli Compliance Will be Achieved Full compliance will be achieved before restart from the current outages after the revision of the EQ procedure incorporating.the changes in organization and tracking methodology (EQ PM file), incorporation of QMDS revisions in the EQ PM file, and' issuance'of related PM requests.
Haakness "The inspector noted that a backlog of EQ items was being maintained by the Electrical Engineering Section.
This backlog list had items dating back to 1990.
The inspector reviewed the list with the keeper and determined that most if not all of the 250 or more' items relate to updating EQ documentation files (Binders). Based on a discussion of the items and the proposed corrective action to. resolve ~the' items the inspector concluded that each item on the listfhad minimal safety.
significance but collectively they showed that the licensee wss'not maintaining the EQ files current. This was considered to be a weakness in the licensee's EQ program."
Besponse The cause of'the descri~oed weakness was inadequate prioritization and utilization of resources applied to'the EQ program during the implementation phase of the program. Higher-priority work resulted in.
the reassignment of rdsources and allowed the EQ program to accumulate a backlog of.EQ documentation file-(binder), updates.
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'Dae backlog of EQ binder update items was reviewed and a schedule has been developed to address its' reduction. No restart issues were identified from the' review.
The EQ backlog is comprised of four item.
types:
1.
Changes resulting from the implementation of design changes.
2.
Changes required by' conditions adverse to quality.
'3.
Changes and reviews from nuclear experience review documents.
4.
Program enhancements that would include life extension evaluations-and other optional work.
There are no delinquent binder updates resulting from the implementation of design changes.
The backlog: includes Types 2 and 3 items (as-described above) that are procedurally past due or have been open-for over six months. This backlog is being worked off by. supplemental:
contract personnel and is currently scheduled to be eliminated by November 1, 1993.
NE is combining specific EQ work responsibilities from Electrical and Mechanical / Nuclear Engineering into one'EQ section. Design change notices or engineering changes that impact'these EQ Program documents will be reviewed by the EQ section. <The consolidation of EQ personnel will provide for a consistent, focused approach to'the: resolution of ongoing NE issues. This organization will receive functional oversight from the site EQ program supervisor.who has overall responsibility for the prevention of EQ backlog items.
ENCLOSURE 2-RESPONSE TO NRC INSPECTION' REPORT NOS. 50-327/93-14'AND 50-328/93-14 ALBERT F. GIBSON'S LETTER TO MARK 0. MEDFORD DATED MAY 20, 1993 Commitmenta 1.
The Nuclear Engineering (NE)Lprocedure associated with drawing control will be. revised by August:16, 1993,uto correctly address the definition of Category.2 drawings.-
2.
A management, performance-indicating tool will be developed by August 23, 1993, for the DD process to raise management'sLattention to DD implementation.
3.
Management will discuss the need for attention to detail with-appropriate'NE employees by July-23, 1993, to raise employee sensitivity to the issue of' drawing errors.
4.
The completion of drawing updates for' drawing deviations'that are identified as the backlog population is currently scheduled for March 31, 1994.
5.
The. completion of drawing updates for drawings identified by NE as high use to incorporate outstanding posted change documents is currently scheduled for March 31, 1994.
6.
The site procedure addressing'the EQ program will:be revised before restart from the current ~ outages to incorporate the requirement'for the EQ PM file and to incorporate'the organizational changes for management of the program.
7.
The elimination of the delinquent backlog of EQ documentation file (binder) updates (changes'from conditions adverse to. quality or Nuclear Experience Review documents that are procedurally past due or have been open for over six months) is currently scheduled for November 1, 1993.
8.
The identification of QMDS requirement and recommendation revisions in the EQ PM file and the issuance of'related FM requests before restart from the current outages will be completed.
9.
Outstanding' items identified in two EQ binders will be completed before restart from the current outages.
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