ML20204J783
| ML20204J783 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 03/16/1987 |
| From: | Russell Gibbs, Murphy M, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 2288T, 307.01-SQN, 307.01-SQN-R02, 307.01-SQN-R2, NUDOCS 8703270307 | |
| Download: ML20204J783 (8) | |
Text
.
TVA EMPIATER CONCREES REPORT NUMBER: 307.01-SQN SPECIAL PROGRAN RRPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 TITLE: Plant Operations Review Committee (PORC) Process REASON FOR REVISION:
Incorporate comments from SRP and TAS Revision 1 Additional evaluation based on NRC review comments Revision 2 PRRPARATION PREPARED BY:
b lY NA LS '27
~
SIGNATURE DATE 4
REVIEWS
/
?b $Y
/
DATE
//
SIGNATURE TAS:
lb Y
3k2b7 (IGNATURE
' 'DATE CONCURRENCES 7!8[
CEG-H1 7#
A#t.
3'/d'0 7 SRP:
m SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
e3 !bf8]
'03 b MC N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
2288T B703270307 B70319 PDR ADOCK 05000327 P
TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG b
Subcategory: Nuclear Power / Site Program / Procedures Element: Plant Operations Review Committee (PORC) Process Report Number:.307.01 - SQN Revision 2 IN-85-457-001 h[{ #((
Evaluator:
T. W.
ite Date
_M ///
r/$[g Reviewed by: I
' Date OPSCFgNger 2[J7[67 Approved by:
Oate p....taEe+Ere.
2576T 4
,,,,.m.w.,-.m.-
,,4 a,,
,,.y,
,_,,,-.,_w_,
y--.,e
~
.e
R:visica 2 I.
PLANT OPERATIONS REVIEW CONNITTEE (PORC) PROCESS This report evaluates a Watts Bar Nuclear Plant (WBN)- specific concern -
that was determined to be generically applicable to the Sequoyah Nuclear Plant (SQN). The identified concern alleges that PORC does not perform an adequate technical review of issues and that the reviews are not' performed in accordance with established procedures and practices.
II.
SPECIFIC EVALUATION NETHODOLOGY Employee Concern IN-85-457-001, identified at WBN, states:
" Inadequate review of plant procedures by Plant Operations Review Committee (PORC). Reviews not conducted in accordance with AI 3.1 (refer to Site Surveillance Instruction Procedure)."
{
This concern was evaluated by the Operations Category Evaluation Group J
He&d (CEG-H) snd determined to *ue generically applicable to SQN.
The scope of this evaluation was to review the PORC process at SQN for adequacy of development in accordance with the requirements and to assess the effectiveness of implementation in actual practice.
The requirements for the PORC process are delineated in the Technical Specifications and the Regulatory Guide 1.33 (reference 10). This Regulatory Guide implements and endorses ANSI N18.7 (reference 11).
Commitment to these documents by the Tennessee Valley Authority-(TVA) for SQN is contained in the SQN Final Safety Analysis Report (FSAR)
(reference 1) and the Quality Assurance Topical Report (reference 2).
Effectiveness of implementation was assessed through a review of SQA 21, "Onsite Independent Review (PORC)," (reference 4), SQN Technical Specifications (T.S.) for units 1 and 2, (references 6 and 7, respectively) and AI-4, " Plant Instructions - Document Control "
(reference 9).
Pertinent documentation from the above references was i
reviewed and informal interviews were held with various members of the SQN staff, notably, the' Plant Operations Review Staff Supervisor (PORS),
the PORC secretary, a PORC chairman and a member of the Nuclear Safety Review Board (NSRB). Additionally, the evaluator attended a regular meeting of PORC on Wednesday, November 11, 1986, to witness the conduct of business.
i.
III. FINDINGS The adequacy of the SQN PORC process has been evaluated by the U.S.
l Nuclear Regulatory Commission (NRC) and by TVA Division of Quality Assurance (DQA). Two DQA audit reports, QSQ-A-86-0001 and QSQ-A-86-0005 (references 12 and 13, respectively) were reviewed for specific problems cited in the SQN PORC process.
t l
Page 1 of 6
Rsvisica 2 Audit Report QSQ-A-86-0001 Deviation D01 identified in part 2 that the requirement for biennial reviews was not being fully accomplished.
Part 2, item A identified that a PORC review of insturment maintenance instructions had been scheduled for. June of 1985 and was not accomplished. Part 2, item B identified that 127 procedures / instructions in 7 categories (e.g., Restart Test Instructions, Radweste Handling and Shipping Instructions, Startup Instructions, etc.) were to have been scheduled for biennial review by PORC and had not been scheduled. Deviation D01, part 3, identified 29 Temporary Procedure changes that exceeded the 14 day requirement to have been reviewed by PORC.
Audit Report QSQ-A-86-0005, Deviation D02 identified that PORC had not reviewed violations of the administrative section of the T.S. as required by TS 6.5.1.6.
Deviation DO4 identifies that PORC meeting minutes are not being maintained and distributed as specified in SQA 21.
The NRC, in Report numbers 50-327/85-46 and 50-328/85-46 (reference 18),
identified that the PORC had failed to perform a forn.a1 review and make a report of a potential safety hazard as associated with the accuracy of Measuring and Test Equipment (M&TE) used for calibrating the Reactor Protection System (RPS) instrumentation. The M&TE used did not meet the accuracy assumptions used in the setpoint methodology for RPS trip setpoints.
The NRC raised other issues concerning PORC activities in the timeframe of August 6 through September 5, 1986, (no report has yet been received). These details are contained in a memorandum, "SQN-Minutes of the September 5, 1986. Monthly NRC Resident Inspection Exit Meeting,"
(reference 3).
In this meeting, two issues were raised concerning PORC activities. The first item concerned SQA 21 (reference 4) stating that a qualified PORC alternate can be named after consulting with the appropriate central office supervisor. This is not allowed by T.S.; no examples were found where this had actually been done. The second item was that the NRC took the position that a PORC member should have personal knowledge of what he is to vote on in a PORC meeting as opposed to accepting the work of an established, qualified reviewer performing work for PORC. These two items, among others, were identified as
" Potential Violations."
i j
In view of the foregoing, SQN has taken positive corrective actions to correct the deficiencies identified with the PORC process. One of the primary changes instituted was the formation of a qualified group of plant personnel to serve as a subcommittee for PORC reviews. This process is delineated in SQA 21. "Onsite Independent Review (PORC)"
(reference 4).
Specific plant staff individuals are identified as Qualified Individuals (QI) within their discipline and area of expertise. Also included are specific qualification requirements that l
l Page 2 of 6
l Rsvisien 2 4
p f
. 1 r
. must be met to be designated as a QI. This approach allows PORC to achieve its responsibilities through the use of QI's on a delegated,
' subcammittee approach. An effort is underway to adapt this methodology at all TVA nuclear plants.through a proposed revision to the NQAM, Part II, section 1.5.
The draft document explaining this proposed change is titled, "Onsite Independent Review - PORC," dated.0ctober 28, 1986.
This draft is currently circulated for review and comment; no scheduled date for potential implementation was projected.
Another positive step identified was that SQN Plant Manager established a PORC subcommittee and chartered them to review all SQN Standard Practices to evaluate their need for PORC review. The output memorandum (reference 15) from the subcommittee provided recommended changes; some standard practices not being PORC reviewed should be PORC reviewed, some standard practices should be combined with others, and still other existing standard practices should be deleted. This data was acted upon by the Plant. Manager and provided an effective cleanup of this one time problem area.
A one-to-one comparison was made of the PORC requirements contained in section 6.0 of the Technical Specifications (references 6 and 7) and the commitments made for PORC responsibilities in SQA 21 (reference 4).
The purpose for this comparison was to ensure that all T.S. Items had been accurately translated into SQA-21, the working document governing PORC activities. One minor discrepancy was identified in this review.
l Item 6.5.1.7.a of the T.S.-was not' reflected in SQA-21. Once identified, I
the PORS supervisor initiated an immediate change to incorporate this lR2 commitment into section 6.4.5 of SQA-21.
Revision 15 of SQA-21 was.
- l accomplished on December 16, 1986. Once assured that SQA 21 was I
accurately aligned with T.S. requirements, the responsibility items in SQA 21 were individually assessed to determine how they were implemented. Each PORC responsibility item was tracked to an acceptable activity function or family of procedures that result in the required PORC review. While the trail of documents to accomplish some of the PORC responsibilities is unavoidably vague, no PORC functions were found to be outside the system for controlling such reviews.
A sample of four (4) recent PORC meeting minutes were selected for review. The sample (reference 14) consisted of meetings 4002 l
(October 1, 1986), 4003 (October 2, 1986), 4004 (October 3, 1986), and 6
4005 (October 6, 1986). These documents were obtained from the PORC Secretary; they consisted of the typed minutes, the rough work sheet from the meeting and copies of the pertinent pages of documents reviewed in the meeting. These packages were reviewed for completeness and accuracy in reflecting the identified business conducted at the PORC meeting. No discrepancies were identified during the original l
evaluation, however, subsequent review of this data indicates a potential l
edministrative problem. It does not appear that SQA-21 has accurately l
translated the T.S. requirements for establishing a quorum of PORC l
members. The TS states in section 6.5.1.3:
l l
lR2 "All alternate members shall be appointed in writing by the PORC l
chairman to serve on a temporary basis; however, no more than two I
alternates shall participate as voting meinbers in PORC activities l
at any one time."
l Page 3 of 6
R vision 2 SQA-21 specifies that the position of PORC chairman may be fulfilled l
by either the plant manager, nuclear power plant superintendent, or l
maintenance superintendent.
SQA-21 does not view this three way l
possiblity as an " alternate" when adding up the maximum of ".
. no I
more than two alternates..." as specified in T.S.
S1cce all three of l
the positions that can fill the chairman's position are full-fledged l
PORC members, there does not appear to be a violation of the IR2 requirement or the spirit of the T.S.
A revision to SQA-21 has been l
initiated by the PORS supervisor to clarify the application of the number l of alternates allowable for a quorum of PORC. The chairman is not l
included as an alternate since any of the three plant positions that can l
be the PORC chairman is a member of PORC. This revision should be l
implemented in March 1987.
l Conclusion During the timefreme of the concern at WRM, it was valid for SQN.
Corrective actions to deficiencies identified by NRC and DNQA have been implemented. The corrective actions discussed in this evaluation, in their aggregate, provide positive controls foc the PORC activities. Two l
CATD's were issued; one to track the implementation of the revision to l
the NQAM allowing review by qualified individuals for material going to l
PORC and the second to track a clarification to SQA-21 explaining that l
the PORC chairman is not included in the allowable maximum of two lR2 alternates when establishing a quorum of PORC. Routine scheduled audits l
will be conducted by DNQA to assess the effectiveness of the changes made l
in the PORC process.
- l Resolution to the two NRC potential deficiencies remain indeterminate until receipt of the NRC report.
No safety-related deficiencies were identified during this evaluation.
IV.
ROOT CAUSE~
The root cause of this issue was a failure to assign fixed responsibility for technical review of documents. This problem should be resolved by the programmatic change to use designated qualified group (subcommittee) reviews as specified in SQA-21 (reference 4).
V.
GENERIC APPLICABILITY Employee concern IN-85-457-001 was specific to WBN and was determined to be generically applicable at SQN and Browns Ferry Nuclear Plant (BFN) by the Operations CEG-H.
i Page 4 of 6
e =
- g R3 vision 2 VI.
REFERENCES 1.
Sequoyah Nuclear Plant Final Safety Analysis Report, Chapter 17.2,
" Quality Assurance Programs for Station Operation" 2.
Quality Assurance Program Description for Design, Construction and Operation of TVA Nuclear Power Plants," TVA-TR75-1A, (revision 8) 3.
Memorandum, "Sequoyah Nuclear Plant (SQN)-Minutes of the September 5, 1986 Monthly NRC Resident Inspection Exit Meeting "
(S10-860909-865, dated September 9, 1986) 4, Sequoyah Nuclear Plant Standard Practice, SQA 21. "Onsite Independent Review (PORC)," (revision 15. dated October 31, 1986) 5.
Sequoyah Nuclear Plant Standard Practice, SQA 119, "Unreviewed Safety Question Determination," (revision 6, dated i
c
...-hor os 1986) 6.
Sequoyah Nuclear Plant, Unit 1 Technical Specifications,.
1 Section 6.0, " Administrative Controls," (Amendment 44, dated July 28, 1986) 7.
Sequoyah Nucisar Plant, Unit 2 Technical Specifications, Section 6.0, " Administrative Controls," (Amendment 36, dated July 28, 1986) 8.
Draft, " Plant Operations Review Committee Charter," (dated October 28, 1986) 9.
Sequoyah Nuclear Plant Administrative Instruction AI-4, " Plant Instruction - Document Control," (revision 56, dated October 31, 1986) 10.
Regulatory Guide 1.33. " Quality Assurance Program Requirements (Operations)," (revision 2, dated February, 1978)
I l
11.
ANSI N18.7-1976/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants,"
(revision, 1976) 12.
Quality Assurance Audit Report QSQ-A-86-0001, dated December 6, 1985 13.
Quality Assurance Audit Report QSQ-A-86-0005, dated April 16, 1986 14.
Plant Operations Review Committee meeting minutes:
- 4002, dated October 1, 1986
- 4003, dated October 2, 1986
- 4004, dated October 3, 1986
- 4005, dated October 6, 1986 Page 5 of 6
1 Rsvisica 2
,-."e.
i
{
15.
Memorandum from PORC Subcommittee to P. R. Wallace "Sequoyah Nuclear Plant - PORC Review'of Sequoyah Nuclear Plant Standard Practices", dated' l
August 13.-1986, (S53 860812 928) t 16.
NRC Internal Memorandum, "STS, Section 6.5.1," dated October 1, 1980 2
i 17.
SQN Corrective Action Tracking System (CATS), number 85495, originated-December 31, 1985, completed October 27, 1986 18.
NRC Report 50-327/85-46 and 50-328/85-46 (dated January 29, 1986)
VII. IMMEDIATR OR IANG TERN CORRECTIVE ACTION I
CATD 30701-SQN-01 was written to track the revision to the NQAN, l
I part II, section 1.5 and its implementation.
l I
l' CATU 3UIU1-8QN-U2 was written to tracs. One casratacatzon et aya-4A-gas
~
{
to show that the position of PORC chairman, when filled by other than the l plant manager, does not constitute the use of one of the two allowable I
alternates (maximum) in achieving a quorum.
l i
4 I
a l
4 k
ar 1
h-Page 6 of 6 0