ML20204G330

Rev 2 to TVA Employee Concerns Special Program Sequoyah Element Rept 301.12-SQN, Hardware Not Properly Identified

ML20204G330
Person / Time
Site:	Sequoyah
Issue date:	03/17/1987
From:	Gardner G, Martin M, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20204G202	List: ML20204G199 ML20204G237 ML20204G282 ML20204G330 ML20204G377 ML20204G409 ML20204G430
References
301.15-SQN, 301.15-SQN-R02, 301.15-SQN-R2, NUDOCS 8703260379
Download: ML20204G330 (7)

Text

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'* TVA EMPLOYEE CONCERNS REPORT NUMBER: 301.15-SQN

. . 4, SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 ,

TITLE: Hardware Not Properly Identified RRASON FOR REVISION:

To incorporate SQN Corrective Action Plan. Revision 1 To incorporate NRC comments. Revision 2 PREPARATION PREPARED BY:

G. Darrell Gardner 88f/ SMI/f'/

SIGNATURE DATE REVIEWS A lY Yf SIGNATURE s//:rll 4

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• 317-87 DATE APPROVED BY:

' [l d.Vb)ak-TCSP MANAGER 1hl DATE N/A MANAGER OF NUCLEAR POWER DATE

' CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotos SRP concurrences are in files.

??HHT 0703260379 070319 P,DR ADOCK 05000327 PDR

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.. W 9 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Mechanical Equipment Reliability and Design Element: Hardware Not Properly Identified Report Number: 301.15-SQN Revision 2 XX-85-102-005 Evaluator: G. Darrell Gardner 5//f/f7 G. Darrell Gardner Da'te Reviewed by: / # ff// 5Yff OPS CBC Member Date

- Approved by: a! # O//J/8[

g V. R. Lager 6ren 'Date 2195T

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Revision 2 I. HARDWARE NOT PROPERLY IDENTIFIED This report evaluates the issue that hardware is not properly identified in the field. The issue was identified for Browns Ferry Nuclear Plant (BFN) and was evaluated generically for Sequoyah Nuclear Plant (SQN).

II. SPECIFIC EVALUATION METHODOLOGY The following issue was identified by Quality Technology Company (QTC) for BFN and was determined generic to SQN:

XX-85-102-005 Brown's Ferry: Hardwaro is not properly identified in the field. A person needs a drawing to identify it. Nuclear Power Dept concern.

CI has additional information.

i The scope of this issue for SQN is perceived as relating to incorrect l or missing equipment identification tags. The Nuclear Regulatory l Commission (NRC) expurgated file for this issue was reviewed and no additional information was obtained. The SQN Special Maintenance Instruction (SMI) for system walkdowns was reviewed to determine actions underway at SQN to identify problems with equipment tags. An interim report prepared by the Office of Nuclear Power Configuration Management Survey Team was also reviewed to provide supplemental information related to component identification. Results of the evaluations at Watts Bar Nuclear Plant (WBN) and BFN were also reviewed. Interviews with the walkdown manager at SQN and with the Corporate Configuration Manager were conducted for supplemental l

Information.

l III. FINDINGS SQN SMI 0-317-30 (Reference 1) requires equipment tags to be checked against the flow and control drawings during system walkdowns. The l- walkdown manager at SQN confirmed that this was being done. According

' to the manager, several hundred missing tags have been identified. Not many casos have been identiflod where tags were incorrect. Those cases are being documented and corrective actions initiated in accordance l with tho SMI. The manager stated that not all systems are being l reviewed; only those systems or portions of systems identiflod by the l

Division of Nuclear Engineering (DNE) in walkdown packages are being

! vorified against the design drawings, i

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l Page 1 of 4

Rsvision 2 The Configuration Management Survey and Analysis Report (Reference 2),

Section II.C states that proper identification of items and documents .

will enable TVA management to ensure that:

Items are designed, manufactured, installed / erected, tested, operated, and maintained in accordance with the design criteria and licensing commitments.

The report notes in section III.C.1 that procedures exist for all sites, except BFN, which provide general instruction for assigning identification numbers to components, however, there is no consistent review process to ensure that unique ids are assigned in accordance .

with prescribed standards. As a result, multiple data bases (with different owners) exist (instruments tabs, Equipment Qualification IR2 identification System (EQIS), Q-lists, drawings, etc.) which contain i data discrepancies.

According to the Corporate Configuration Manager, Division of Nuclear Services, and a consultant in that office, the interim report has been included as an appendix to the new corporate Configuration Plan which is in review at this time. This new plan provides various task activities for plant sites and other central organizations to provide for new numbering schemes and new rules for maintaining cata bases.

Conclusions The issue that hardware is not properly identified was validated for SQN. The walkdown effort at SQN has identified numerous missing equipment tags and some casos of incorrect tags have been identified and are being corrected.

Tho scopo of the walkdown offort does not include verifying that data bases and drawings reflect the correct component identifiers. Although not specifically evaluated, traceability for testing and maintenance activities and proper operation of plant equipment may be compromised and are not precluded by the current situation. For these reasons, this issuo is considered safoty-related and may represent a significant condition adverse to quality. The new corporate configuration plan will addrons the issues related to drawing / data base discrepancies.

IV. ROOT CAUSE No root causo could be dotormined for missing oquipment tags at SQN.

The fact that multiple or incorrect ids exist is perceived to result from the lack of a contral point for control and review of ID assignments.

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.* Revision 2 3

i V. GENERIC APPLICABILITY l

Evaluations have been conducted at SQN, WBN, and BFN with similar findings. The' issue is considered generic to Bellefonte based on these findings, however, since BLN is presently in a limited construction phase, the new corporate configuration plan should be adequate to address and resolve these issues. For this reason, an evaluation at Bellefonte Nuclear Plant (BLN) will not be conducted by the Employee Concerns Task Group (ECTG).

VI. REFERENCES

1. - SQN SMI 0-317-30 Revision 2. " System Walkdown," August 11, 1986

2. TVA Office of Nuclear Power Interim Report, " Configuration Management Survey and Analysis Report," March 1986 VII. INMEDIATE OR LONG-TERM CORRECTIVE ACTIONS  ;

l Corrective Action Tracking Document (CATD) OP-30115-SQN-01 requested l SQN to provide a plan to determine the extent of missing or incorrect l tags and propose corrective measures or detail measures already in l progress. l l

L Sequoyah's Corrective Action Plan (CAP) stated that the plant would: l l l l

Complete before Restart, tagging deficiencies identified and l classified as " Restart" by TVAs Design Baseline and Verification l l

Program (DB&VP). Corrections before Restart will be limited to components l Identified by the main control flow and control drawings and corrocted l under the DB&VP program. l l l Further discussion with a responsible individual in the Modifications l Group revealed that the work scope referenced by the CAP is limited to l resolution of discrepancies between the tags and the primary flow and I control drawings for safety-related equipment. Correctivo actions' l

, include tag replacements or drawing revision as necessary. The DB&VP l does not include all plant drawings, nor manuals and procedures, thus lR2

the "fix" provided is not all-encompassing. It is, however, sufficient l l to ensure that the plant's nuclear safety is not degraded by tagging l l discrepancies. l l

l l The plant further proposed to: l l

l l Initiate a long-term CAP to reflect the unique identification I of mechanleal, electrical, and instrumentation components on the l necessary drawings to allow the components to be reflected in l procedures and identified in the fleid. l I

Discussion with the modifications representative indicated that tho I t

goal of this effort is to institute a uniquo equipment identification l l (UNID) system slallier to that employed by BLN. This project is I t i

j scheduled for completion in January 1988. I Page 3 of 4 I  ;

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i-R:visien 2 CATD OP 30115-NPS-01 was written to the corporate configuration manager's office to address the resolution of data base and drawing .

discrepancies. Because the latter issue is generic, the corrective IR2 action response from the corporate configuration manager will be included in subcategory report 301 rather than in this report.

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- ECPS120J-ECPS121C TENNESSEE WALLEY AUTNORITY RUN Tile -

REFERENCE OFFICE OF NUCLEAR POIER FREQUENCY - REQUEST RUN BATE -

EMPLOYEE CONCERN PR00 Raft SYSTEft (ECPS) *

(3 ONP - ISSS - RHM

' LIST OF EMPLOYEE CONCERN IIIFORMATI0Il CATEGORY: OP PLANT OPERe SUPPORT SUBCATEGORY: 30115 IMPROPER NameMARE IDEIITIFICATION e KEYMORD A S GENERIC KEYtIORD B g H APPL QIC/NSRS P KEYNORD C SUB R PLT BBSH INVLSTIGATION S CONCERN KEYHORD I CONCERN R DESCRIPTION NUMSER CAT CAT D LOC FLQB REPORT NS DRONIt'S FERRY: NARONARE IS NOT PROPE TA0GIIIG XX 102-005 OP 30115 N BFN YYYY I-85-733-BFN geOllC000FORMAIK REPORT RLY IDEllTIFIED IN TNE FIELD. A PERS OPERATIDstS T50172 ON NEEDS A BRAMIDIS TO IDENTIFY IT. GENERAL 100 CLEAR PetfER DEPT C080CERN. CI NAS 3 ADDITIOllAL INFORetATICII. NO FOLLON U P REGUIRED.

f 3 1 CONCERNS FOR CATEGORY OP SUBCATEGORY 30115 G

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