ML20204J839
| ML20204J839 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 03/12/1987 |
| From: | Russell Gibbs, Joyce J, Murphy M TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 1635T, 307.04-SQN, 307.04-SQN-R07, 307.04-SQN-R7, NUDOCS 8703270316 | |
| Download: ML20204J839 (21) | |
Text
TVA EMP14YE3 CONCERNS REPORT NUMBER: 307.04-SQN p
SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER:
7 TITLE: Workplan Process
+
REASON FOR REVISION:
Revised to incorporate SRP and TAS coments.
Revision 1 Revised to incorporate SQN corrective action response and SRP coments.
Revision 2 Revised to incorporate 4 additional concerns Revision 3 and SRP coments on Revision 2.
Generic Applicability made consistent with findings Revision 4 and data base.
Revised to incorporate additional concern and general Revision 5
^
revision for clar1ty.
Revised to incorporate TAS coments.
Revision 6 Revised to incorporate NRC coments and SQN Corrective Revision 7 Action response.
PREPARATION PREPARED BY:
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SIGNATURE DATE 1
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SIGNATURE DATE TAS:
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DATE SIGNATURE DATE APPROVED BY:
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' ECSP MA' NAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) h kh es SRP concurrences are in flies.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS
- y zgg Subcategory
- Nuclear Power / Site Program / Procedure.
Element: -Workplan Process Report Number: 307.04 - SQN, Revision 7 XX-85-070-005 XX-85-070-003 SQP-6-003-003 IN-85-305-NO3 SQP-86-003-N06 XX-85-070-002 XX-85-070-006 HI-86-090-N02 Evaluatoe:
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R visien 7 I.
-TITLE Workplan Process This repo'et is the. result of an evaluation of the workplan processing
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procedures and the reuse of.certain materials during plant modification work at the Sequoyah Nuclear Plant (SQN).
In addition, concern number XX-85-070-003 is a shared concern with the Engineering Category and XX-85-070-006'is a shared concern with the Intimidation and Harassment Category.
I II.
METHODOLOGY I
The K-forms for the eight concerns which make up this element were reviewed and are stated as follows:
L 1.
XX-85-070-005
)-
"Sequoyah: Workplan (number known) to take equipment out of service for repair / modification was never authorized by engineering but work plan modifications have been completed.
(names / details to the specific case are known to QTC and withheld to maintain j
. confidentially). Nuclear Power Concern. CI has no further Information."
I 2.
XX-85-070-003 f
_"Sequoyah: Workplans contain-inaccurate data. Majority of the DCR's taken care of but not documented right and drawings do not reflect the as-built conditions. Details withheld to maintain i
confidentiality. Nuclear Power Concern. CI has no further f
information."
k 3.
SQP-6-003-003
)
" Conduit is currently being removed and reinstalled (rerouted) without proper documentation. Lower containment. Fan room 1, g
unit 2, approximate elevation 680'.
Workplan 11882. Nuclear Power i
Concern. CI has no further information."
r 4.
IN-85-305-N03 "NRC identified the following concern from QTC report IN-85-305-001.
j No administrative procedure exists for controlling fleid
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modifications for vendor supplied items."
k 1
1 Page 1 of 18 a
L
Rsvisien 7 5.
SQP-86-003-N06 i
i "NRC identified the following concern. based on review of QIC file.
If documentation deficiency for SQP-86-003(-003) is substantiated.
(
it would be QA violation of Appendix ~B and would be reportable.
The subject form-(ERT form N) indicated it is not reportable."
s 6.
XX-85-070-002
}L "Sequoyah units 1 and 2.
CI expressed a cor.cern-that specific quality problem (open since 1980) are in the process of being intentionally closed in a dubious manner to prevent attracting the attention of the NRC.
(Names / details to the specific case are known to QTC and withheld to maintain. confidentiality).. CI has no more information. Nuclear power department concern."
t 7.
XX-85-070-006 E
'"Sequoyah unit 1 and 2: Closure of specific quality documentation is being falsified in order to close these problems out before the NRC becomes aware of them.
(Names / details to the specific case are known to QTC and withheld to maintain confidentiality). Nuclear n
power concern. CI has no further information."
i 8.
HI-85-090-N02
" Untrained individuals were brought to Sequoyah ECR0s, DCRs, and l3 WPs."
The documents which define the requirements applicable to these
,i concerns were reviewed as well as the plant standard practices and instructions which implement these requirements. A listing of these I
documents 1s contained in the Reference section of this report. Two
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Nuclear Safety Review Staff (NSRS) reports (I-85-637-SQN and
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I-85-206-SQN) which deal with these concerns were also reviewed for information applicable to this evaluation.
i Interviews were conducted during this investigation with cognizant engineering ~and modifications personnel.
b 3
A review and evaluation was conducted of the NRC expurgated files for
/
additional information for concern HI-85-090-N02.
This element consists of four distinct issues which will be referred to j
as supplements. The first issue (supplement A) addresses concerns i
SQP-86-003-003 and SQP-86-003-N06 which deal with the reuse of I
electrical conduit at SQN and the alleged failure to document this work. The second issue (supplement B) addresses concerns
]
XX-85-070-002, XX-85-070-003, XX-85-070-005, XX-85-070-006 which deal with the failure of the modification program to ensure that drawings are updated to reflect system changes, and the failure to obtain the necessary authorization for each workplan, and to process open 3
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1 Page 2 of 18 1
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R3risien 7 workplans (WPs) to avoid NRCs knowledge of quality problems and errors with the WPs. Note: NSRS report I-85-637-SQN, assumed that the CI's concerns, (XX-85-070-002 and XX-85-070-006) about quality problems were with WPs, due'to the lack of clarification, and that additional information'obtained from QTC was too voluminous. The third issue (supplement C) deals with the procedural controls for plant modifications to vendor supplied items and addresses concern IN-85-305-N03. The fourth issue (supplement D) deals with untrained individuals brought to Sequoyah (SQN) to work Engineering Change Notices (ECNs) Design Change Requests (DCRs).-and WPs.
III. FINDINGS A.
Evaluation Results Supplement A - Undocumented reuse of electrical conduit NSRS Report I-86-206-SQN addresses this issue and contains additional clarification of the concern from the concerned individual (CI). The concern was clarified and corrected by follow-up contacts between QTC and the CI.
The workplan number was corrected to 11808, and the following concern statement was added:
"At the building location noted in concern SQP-6-003-003, old conduit was being reused. About 150 feet of 1-inch rigid conduit is involved. TVA is not allowed to re-use conduit, and that's why there is no record being made of the re-use (hence improper documentation)."
The NSRS investigation concluded that the concern was l
unsubstantiated. TVA procedures were cited which mandate all l
materials used in a particular application meet the appropriate I
specification. The investigation did not locate any procedure or i
policy to prohibit re-use of conduit or other materials for l
modifications. The ECTG evaluation supports the NSRS conclusions lR7 and further establishes the finding via SQN AI-19 which l
specifically exempts rigid conduit and fillings from material l
traceability requirements. This position is acceptable under the l
TVA QA program since conduit is considered an off-the-shelf item l
even when used in a safety-related or seismic application.
l Supplement B - Failure to update drawings and obtain proper sign-offs for modification workplans, and to process open workplans to avoid NRCs knowledge of quality problems and errors with the WPs.
NSRS Report I-85-637-SQN documents several cases in which workplans were completed without the required sign-offs and without completion of documentation, specifically the updating of plant drawings.
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Page 3 of 18
R;visicn 7 The following is a summary of specific examples and conclusions of the NSRS report findings:
a.
Lack of configuration control in that drawings de not reflect actual plant conditions.
WP 8631 (Non-CSSC) added adjustable snubbers to the electro-hydraulic fluid reservoir pressure switch lines per Westinghouse Operation and Maintenance Memorandum No. 009 dated September 14, 1979. No drawing or manual could be found as-constructed (or revised to) show this change.
WP 9150 (Non-CSSC) concerned the installation of storage hooks for chokers. No drawing was as-constructed.
WP 9738 (Non-CSSC) was initiated on April 5, 1982, to document a valve cage change of the seal oil airside heat exchanger temperature ennten1 val va (1-TcV-24-73) per SQ-DCR-L-1520.
TACF 82-65-24 and MR 169797 actually accomplished the work and were referenced in the WP.
Section XIII of the WP control form,
" Instructions and Manuals Requiring Revision," shows the WP initiator signed that the ITT Hammel Dahl (contract number was not given but determined to be 83522-2) Bill of Materials had been revised. Item 4 of the WP Drawing Sheet does list the Bill of Materials HDC 11009 but denotes it as "for information only."
No other drawings were listed. Master files did not contain an as-constructed drawing showing the smaller cage P/N6198618EF. Also, no Vendor Manual Change Form (SQNP AI-23) was found in the WP, and the manual records unit shows no revision has ever been processed.
WP 10002 (Non-CSSC) was initiated to fabricate and install 15 heat collectors on auxiliary boiler fire protection water spray nozzles. No manual or drawing was listed as being revised. The 47W491 drawing series does show heat collectors by specific location.
WP 10181 (Non-CSSC) involved modification of the main feedwater pump discharge isolation valves (FCV-3-81 and -67).
The valves tongue and groove dimensions were modified in order to install Flexseal gaskets as a replacement for the original ingot iron gaskets. The WP drawing sheet lists Walworth Company drawing A-6240003-M-3 but was crossed out on June 4, 1984. No vendor drawing or manual changes were indicated.
WP 10420 (Non-CSSC) involved relocating thermowells on the main turbine oil drain line from the No. 11 bearing to the opposite side of a nearby insulated flange. The WP drawing sheet had N/A for affected drawings. Also, the WP control form had N/A for drawing requirements and vendor manuals. However, there was a portion of a Westinghouse drawing included in the 11P marked "for in-field work."
This drawing was marked to show the old and new location of the thermowell.
Page 4 of 18
R:visien 7 Lack'It' configuration control,in thatLdrawings do not reflect
.a.
actual plant conditions.
(Continued).
WPfl0427 (Non-CSSC) had been removed from the vault because an electrical drawing had not been as-constructed..The corrections are being coordinated by the WP initiator.
WP 10588 (Non-CSSC) replaced a balance chamber needle' valve on Jthe main feed pump drive turbines (unit I and 2) with~a seal' welded plug.- The master file copy,of the Westinghouse manual.
1150C171, figure.11(IL.1150-536).. was revised'on November 9,:
1983, to show a seal welded plug.
WP 10629 (Non-CSSC) involved the replacement of a smaller cage in the seal oll' hydrogen side temperature control valves 1-TCV-24-74 and 2-TCV-24-74.
This modification was to allow greater flow control. The WP; drawing sheet has111sted " cont.
2 83527-2" and was dated October 12. 1983..This was marked out on May 16, 1984. The WP control form shows that drawing requiraments were N/A on October 12.-1983.
It also' indicated that vendor manual changes were completed on June 14, 1984, and listed 83522-2 as being revised. The contract information in-master files did not contain a revised Bill'of Materials nor any other references to a part number change. The drawing control manual unit found no evidence that the manual had been revised.
to show.the smaller cage.
WP 10650 (CSSC) was initiated to seal weld a threaded plug on the stuffing box of valve 1-FCV-1-182.
The WP shows no-drawings or vendor manuals were as-constructed to reflect this improvement. A " Request to As-Construct Drawings"-in the WP show drawing CPI-6-219. Rev. 901, contract 83577, was as-constructed on July 19, 1985. The reason stated for the attachment 15 request to as-construct the drawing was that EN-DES issued the drawing after the WP was closed. The WP was signed complete on November 9, 1983, but the drawing was issued on September 26, 1983.
It was noted in the NSRS report that this item was corrected.
WP 10651 (CSSC) was. written for the installation of an additional valve (63-697) downstream of existing valve 63-564 in the Safety Injection System in order to provide level control.
-TACFs 81-2550-63 and 82-61-63 were referenced in the WP.
Date changes to previous signatures and cosigning on the WP indicate that some change was made to the 47W811-1 drawing after the WP was initially processed. Copies of the latest as-constructed 47W811-1 for unit 1 and 2 do show valve 63-697.
It was noted in the NSRS report that this item was corrected, i
Page 5 of 18
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'R;visien 7 l
a.
Lack'of configuration control in that drawings do not reflect actual plant conditions.
(Continued)
WP 10738 (Non-CSSC) was to document the welding of brackets on each side of the unit 2 main feed pump turbine bearing pedestal at the-coupling end. This was done by MR A017009 to stiffen the bearing support. The WP control form shows the vendor manual changes were complete as of February 13, 1984. Actually this figure was revised on November 9, 1983, and is in the master files manual.
WP 10866 (Non-CSSC) was for documentation only and involved _the addition of a reinforcement modification to the main condenser shell lower rib joints. TVA drawing 48A361 RO found in the WP was marked by EN DES to show the proposed modification in a TVA memorandum from C. A. Chandley to N. F. Neperud, Jr., dated June 18, 1981-(LOO.810623 331). The WP drawing sheet shows no d* awing were affected. However, the SQN DCC produced 48A361 RO showing it was approved on November 21, 1980. The drawing has never been as-constructed according to DCC.
WP 10881 1Non-CSSC) was to document the installation of pressure taps on the low pressure gland seal supply flow element and to install test line isolation valves on the balance weight flange of the mein feed pump turbine. SOI 1.1 R17, and SOI 2.2 R12 reflect these changes but did not number the valves. The WP control form and the WP. drawing sheet states no vendor manuals or drawings were affected. TVA drawings 47W801-1 and 47W807-1 are referenced on the SOI and do show other isolation valves.
WP 8950 (Non-CSSC) references ECN L5250 TACF 81-593. FCR 449, and FCR 521. The work involved replacement of existing level measurement instrumentation in the spent resin shipping cask.
Instrument 0-LS-77-225 was existing, but a new junction box (JB 3936) and terminal block were to be added at EL 710'6" on the wall where the level switch was mounted per FCR 521. Then a terninal strip was added to the junction box in order to extend the cable from the wall to the instrument per FCR 449.
The new junction box was to be installed between the existing junction box (JB 3017) and the instrument. However, when 45N1630-79 was as-constructed, the new junction box (JB 3936) was omitted.
Based on the specific examples, these conditions are shown to be prevalent especially in workplans dealing with Non-CSSC equipment which do not receive QA review.
Page 6 of 18
R3visien 7
.a.
Lack of configuration control in that drawings do not reflect actual plant conditions.
(Continued)
The conclusions of the NSRS report finding which involved improper as-constructed. drawings, were substantiated and the NSRS made the following recommendations:
- 1.. Correct all of the discrepancies identified.
2.
Review all previous WPs initiated by individuals who failed I
to correct as-constructed drawings and manuals.
3.
Retrain all personnel who initiate WPs on the requirement to as-constructed drawings and revise manuals.
4.
The site QA unit should evaluate the present schedule of frequency and scope of surveillance on completed workplans.
b.
Failure to obtain proper sign-offs for modification workplans.
Eight WPs listed by the-CI were reviewed in the QA records vault that concerned lack of proper signature. This review validated l
the concern 1of not having the Workplan Complete signature of the Modifications Manager at the time of transfer to the records vault. However, it was also noted that a QA Record Change Form had recently been added to each workplan package, and the proper signature had been affixed to each WP control form. This led to a review of'the QA Record Change Log. These eight QA record changes and nineteen other entries of this nature were documented in the sequential log.
This log did not contain many completed forms, but a spot check of three others listed
-confirmed their completion.
It was also noted that'the copy of the QA Record Change Form in the WP and in the change log was not reviewed by the-QA unit.
Instruction Letter MS/DCU-6, Revision 0, does not make the distinction that records for non-CSSC equipment are exempt from the plant QA review and approval. The plant QA Engineering and Control Group informed the change processor and the NSRS investigator that they were not involved and that although AI-7 lists WP data as a lifetime QA record, it also defines QA records as only those involving CSSC.
SQA 122, "Non-CSSC Equipment Performance Assurance Program" notes that modifications on non-CSSC equipment will be performed in accordance with AI-19.
WP 9530 (Non-CSSC) was not processed in accordance with AI-19, part IV.
Three notes on the WP control form appear near signatures attesting that their review was performed after the work was performed. Also, two TVA 45 forms were found in the WP that note this.
Page 7 of 18
R2visicn 7 b.
Failure to obtain proper sign-offs for modification workplans.
(Continued)
WP 9830 (Non-CSSC) was'also not processed per procedure. A note on page 2 of the workplan control form reads, " System engineer responsible for workplan overlooked requirement for S.E. signature prior to work start.
Employee-left TVA in December of 1983."
NSRS notes that although these two examples should not have occurred, the WP review-process did cause these to be flagged.
The original of workplan 10524 R1, (Non-CSSC) was reviewed in the QA records vault. On the B.2 line of AI-19, part IV, attachment 2, is the Workplan Complete verification which requires the Shift Engineer's (SE) signature and date. An asterisk (*) flag is noted there and at the bottom of the page. The note reads, "This is not my signature, this needs to be taken to the S.E. for signature." The NSRS investigator contacted the individual whose name was lined through on the WP and confirmed that the note had been written by that person.
No other examples or similar cases could be identified, and this individual's opinion was that it did not happen very often.
The conclusions of the NSRS report findings which involved failure to obtain proper sign-offs for modification workplans were j
substantiated and the NSRS made the following recommendations:
f-1.
Expand AI-19 to provide instructions on preparing documenta-tion only workplans.
2.
Delete MS/DCU-6 and incorporate its contents into AI-7, l'
" Records Retention Recorder Charts and Quality Assurance Records." Attachment 10, Field Service Records, should be revised to delete the word " data" under record type and note that instruction, implementing documents, design drawings, j
ECNs, USQDs, and tests or inspections are to be included.
[
Also, consider a procedure change that would allow the j'
Document Control Unit to receive a completely signed QA record change form.before it is logged or comply with the procedure as written in a timely manner.
3.
The QA section supervisor should review and approve all WP record changes, not just those involving CSSC.
c.
Processing open workplans to avoid NRCs knowledge of quality
^
problems and errors with the WPs.
The WP process has been in effect since the system transfer from Construction to Nuclear Power.
It is the method of control used in implementing changes to the plant. Over the years, a lot of WPs have been written but not completed to i
closure. These backlogged WPs are in various stages of t
1 Page 8 of 18
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R vislen 7.
-c.
Processing.open:workplans.to avold' NRCs knowledge of quality problems and errors with'the WPs.
(Continued)-
completion and have been allowed to remain.open because of higher priority: work. Mandated modifications have historically been worked before documentation or loose ends of less critical WPs. The cumulative effect has been that a lot of WPs have remained'open for a long time. Modifleations management t
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recognized this adverse trend and started efforts to reverse this condition.
Several reasons for correcting these cummulative. effects were
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noted during'an interview. One was to avoid the situation at BFN where a.very large backlog of open.WPs existed..Another reason was that from a good business point of-view a large backlog of uncompleted work is undesireable.. The third reason.
is-that the volume of open work, both safety-related and'
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nonsafety-related, presents a negative picture to a lot'of people inside and outside of TVA. Although the NRC had not expressed'this concern to the modification manager, it was felt.
iand expressed by him that if SQN_did not get the work cleaned
!I up, then someone else could be brought in to do it for us.
The conclusions of.the NSRS. report findings which involved processing open workplans to avoid NRCs knowledge of quality problems and errors with the WPs was not substantiated for the-y following reasons:
1.
No evidence was found that SQN was withholding reportable information in the WP process.
2.
As the industry regulator, the NRC is often perceived as the p
sole reason for correcting or changing the way business is conducted.
3.
No NRC guide or TVA conunitment could be found concerning how many or within what timeframe WPs should be completed.
- A review of the NSRS Reconunendations and the SQN line responses was conducted. The following are the NSRS Recommendations:
j 1.
I-85-637-SQN-01, Documentation Only Workplans Expand AI-19 to provide instructions on preparing documentation only workplans.
2.
I-85-637-SQN-02, OA Record Change 51
]
Delete MS/DCU-6 and incorporate its contents into AI-7, 4
" Records Retention Recorder Charts and Quality Assurance Records." Attachment 10. Fleid Service Records, should be g',
revised to delete the word " data" under record type and note that instruction, implementing documents, design drawings.
ECNs, USQDs, and tests or inspections are to be included, t
I[
p Page 9 of 18 L
r R;visitn 7' o
Processing open workplans to avoid NRCs knowledge of quality c.
problems and errors with the WPs.
(Continued)
Also, consider a procedure change that would allow the Document Control Unit to receive a completely signed QA record change form before it is logged or comply with the procedure as written in a timely manner.
3.
I-85-637-SQN-03, Implement QA Unit Review of All WP Record The QA section supervisor should review and approve all WP record changes, not just those involving CSSC.
4.
I-85-637-SQN-04, Correct Discrepancies Correct all of the discrepancies identified.
5.
I-85-637-SQN-05, Search for Other Improper Workplan Closures Review all previous WPs initiated by individuals who failed to correctly as-construct drawings and manuals.
6.
I-85-637-SQN-06, WP Initiator Training Retrain all personnel who initiate WPs on the requirements to as-contstruct drawings and revise manuals.
7.
I-85-637-SQN-07,-0A Review of Completed WPs The site QA unit should evaluate the present schedule of frequency and scope of surveillance on completed workplans.
8.
I-85-637-SQN-08, Close Preoperational Test Deficiencies Take the action necessary to close preoperations test deficiencies.
9.
I-85-637-SQN-09, Close Old WPs Continue the program to work off the WP backlog.
10.
I-85-637-SQN-10 Improve DCC Turnaround Time Eliminate the DCC as-constructed drawing backlog and improve the turnaround time. This should also include response improvement of WP initiators to review and sign off drawings in a more timely manner.
11.
I-85-637-SQN-11, Continue ECN Closeout Continue the ECN closeout function on a permanent basis with increased effort by support groups to respond in a timely manner.
Page 10 of 18
R;visicn 7
- e Processing 1open workplans to avoid NRCs knowledge of quality c.
problems and errors with the WPs.
(Continued) 12.
I-85-637-SQN-12. Add Unit Check to Procedure Revise AI-19, part IV, attachment 12, to verify that-the WP and the DCR specify the correct unit designation.
The SQN line responses are as follows:
1.
I-86-637-SQN-03, SQN disagrees with this recommendation.
'Non-CSSC workplans are not QA documents and the original workplan nor changes to it are required to be reviewed by the QA section supervisor.
2.
I-86-637-SQN-05, SQN is in process of performing walkdowns of systems to ensure the as-constructed drawings and actual systems agree.
In addition, a program.is in nlace to review and close open ECNs. These programs will ennure that.the system installed will agree with the appropriate drawings and documentation.
3.
I-85-637-SQN-08, SQN is currently evaluating all open preoperational test items. This evaluation is scheduled to be completed before startup.
4.
I-85-637-SQN-12, SQN has initiated a program to unitize ECNs, DCRs, WPs, etc. to ensure correct identification. This program will correct the problem with unit designation and will prevent reoccurrence of the problems.
This report concurs with the SQN line responses as stated above.
In response to the NSRS recommendation the plant initiated a plant wide system walkdown to ensure the current configuration, and a program to review and close all open ECNs as stated above in response I-86-637-SQN-05. This action taken appears to address NSRS recommendations I-85-637-SQN-04, I-85-637-SQN-05, I-85-637-SQN-09. I-85-637-SQN-10, and I-85-637-SQN-11.
A review of the above NSRS recommendations and SQN responses revealed that NSRS recommendations I-85-637-SQN-01, I-85-637-SQN-02, I-85-637-SQN-06, and I-85-637-SQN-07 had not been addressd by SQN line management.
This report concurs with the findings and conclusions of the NSRS report.
Page 11 of 18
..m R3 vision 7 9 -.
- s;
-Supplement C - No administrative control procedure for modifications'to vendor. items.
1 Administrative Instruction!(AI)-19 -(Part IV) is the controlling document for_all plant modifications after the plant is. licensed.
l '
This procedure controls the preparation.. execution and close-out of.
all workplans which are required for the modification of,any plant.
equipment.
Supplement D - Untrained individuals were brought to Sequoyah to
Reviews of the NRC expurgated files for concern HI-85-090-N02 was L
conducted. It was found that the CI was concerned that untrained individuals were brought to SQN from Bellefonte Nuclear Plant (BLN)
R to work ECNs,lDCRs and WPs.
Interviews with cognizant; engineering-supervisors were conducted from BLN and SQN. ~The cog'nizant supervisor from BLN stated that only.two individuals had been sent to SQN to work in'the modification section at SQN to his knowledge and the. individuals were from the construction section and not nuclear power. The supervisor stated that one of the individuals sent was an engineer and had extensive experience in construction ECNs, DCRs, and WPs at BLN, the other individuals qualifications'were not known by the supervisor. The cognizant supervisor from SQN stated that a froup of engineers and associate engineers were sent to the modifications r
group at SQN from BLN. The supervisor stated that all individuals g
were selected by their past work performance and experience level working in modifications related work ECN,- DCRs, WPs, etc. during j
the layoffs at BLN. The supervisor also stated that the
}
modifications group at SQN was staffed by individuals from Watts Bar Nuclear Plant (WBN) as well as, contract personnel. The supervisor stated that.each new individual that is assigned to work ECNs, DCRs, or WPs are assigned to work with other personnel at SQN that are familiar with the site specific program and are trained by U
the supervisor (himself/herself) Informally (not documented) on the SQN program specifies. The supervisor also stated, that the performance of these individuals was above average and there had 4'
been no problems with the quality of work, and that these U
individuals were considered highly trained and experienced.
A review of QA audit report 19C-85-S-006, was conducted. It was t
found that this audit evaluated the effectiveness of the ECN f
closure project activities to determine the adequacy of existing closures. The following is a summary of the report findings:
"Overall, the ECN Closure Project is well equipped to perform technical reviews of completed ECNs for adequacy in preparation for their subsequent closure. This conclusion is based, in part, on the following observations:
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2.
The formulation,end implementat$ M of % won thought out work activity p1'ha which desci'lbhJ theprOhttN' perceived
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N' i
yerifjcation activ'ities.
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- 3. ' Staffing-of the project wit.h technically.-gualified.
' ~
,3_ 'eggineeringpersonnel.
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The posi!!ve attitude exhib (ed byihrojNt P [sU1nel' tot $tr3A A
4.
ensuring'. that a quality pro uct ih atteb ed.""
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B,- Conclusions c.'
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Supplement A 1
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Concern SQP-6-003-003 was not validalad. Thereu$aof electrical, conduit'is not s'vio M tion'of cny plantN oh rigid s
icy or' procedure. 'The NSRS _ report recommends \\that the reuse of. conduit ben
.sppelf'ically-described in a pla5Y procedure to ensure thnt thi coniiu'it meets the specificatIionf: for the new applicat.ld k Th'is, evaluator agrees.and: concurs with the NSRS report fin;tingeandh recommendations.
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o.
Sine $ concern expressed in SQP-6-003-403 was not valihated, no QE' I
L' violatio3 of Appendix B has occurred and concern SQP-86-003-N66 is 0
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5 I
not sub O.antiated.
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.s Thh plant staff response to this recommendation is concurren\\,
- b. Q \\
t ts.
This Nocedure revision isityped and awaiting PORC approval.\\ '(CATD5
(
30704-SQN-01)
')
Supplement B
[
s Concern'XX-85-070-003, addre'< sing the fai. lure to update plant 3
documentation,specifica1Yf'plantdrawings,to)howneweqviknent configurations was validRed,byf the NSRS revietA In retponsa to this i$em the plant ir'tif.iated ap plant wide systka walklown program to-otsure,the current cenfiguration and a program to reviN and close all open ECNs. Both of these programs are now in p ogress.
- The system walkdown program is describcd in Special Maintayance
- ' Instruction Procedure SMI-0317-30. The ECN Closure Proje n is tl conducted in accorditnce,$dth AI-19 and-is under the direchi'on of l
i the ECN Closure Project Supervisor. These programs currently have no completion dat'e assigned,, altho %h this lack of completion l
scheduling appears to present no ptoblem to plant gafety because l
- any configuration discrepancies resulting from open Echs will be identified by the currently active plant system walkdown programs.
These programs, address NSRS reconunendations I-85-637-SQN-04, I-85-637-SQN-05, I-85-637-SQN-09. I-85-637-SQN-10, and I
I-85-637-SQN-11.
This report concurs with the NSRS report U ndings and reconunendations.
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Page E3'of 18 ',,'l
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F,[
Rsvision;7' s,
A review of the NSRS recommendations and SQN responses revealed "that recommendations I-85-637-SQN-01, I-85-637-SQN-02,-
-I-85-637-SQN-06,'and'I-85-637-SQN-07 had not been' addressed by SQN
- line mhnagement.
(C&TD 30704-SQN-03) 5
(
~
~
ConceNSXX-85-070-005, a'ddressing the failure to obtain al1~
required}dgnatures.before the Leospletion of workplans was also valjdatedl'However,theNSRSreport:recommendationstorequire all workplens be reviewed by the Quality Assurance: Supervisor tha{rejectedbytheplantstaff.intheirresponseto.theNSRS~
wa's
- repdct.- The QAfataff deals only with QA documentation. The non-CSSC workplans are not QA documents.and the review of_these..
,r' non'-c5dC workplans, should remain with the:workplan initiator.
4 A
. (CATD 30704-SQN-02)
Concerns XX-45-070-002.and XX-85-070-006,' addressing.the processing k' -
of Npen workplans to' avoid NRCs knowledge.of quality problems and o'erors edittl the WPs was.not-. validated. Based on the NSRS report, hoevidence:wasfoundthat-SQNwaswithholdingreportable information in the WP process and no NRC guide or TVA commitment could be,found concerning how ma'ny or within what timeframe WPs
-should'be completed. This report concurs with:the-NSRS report 6
finding's.
4 Supplement C
[
c i
d( u Concern IN-85-305-N03, alleged that for field modifications to
(
3 vendor' supplied items there exists no' administrative control
$.h[c procedures. This concern is not substantiated since AI-19 (Part p
IV) controls all field modifications made after the-plant is i;d licensed.( AI-19 (Part IV requires that a workplan be written and
't y.
approved before modification to any plant equipment). Controls h
exist [ for field modifications regardless of how the. item is 1
supplied or who initiates the modification.
.s.
f
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Supplement D-4
- , )
Concern HI-85-090-N02, alleged that untrained individuals were A'
r
. C
.e,[
brought to SQN from BLN to work on ECNs, DCRs, and WPs. This concern was not substantiated. Based en interviews with cognizant engineering supervisors from t'oth SQN and BLN the individuals were; j
'A (1) engineers and associate e 9gineers that had previous experience in workirg ECNs, DCRs, and WPs; (2) new individuals were. assigned l
to work with sother personnel at SQN; (3) there had been no problems identified ~with the qual uy of work. The statements by the supervisors,were supported with QA audit report 19C-85-S-006 findings that staffing of the project war with technically qualified engineering personnel.
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R;visica 7 q
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IV.
ROOT CAUSE g
The concerns in Supplement A were rot validated, therefore no root cause exists, Therootcause'forSupplementNwasafailuretoupdateplant g
documentation,'specifically plant drawings, to show new equipment
,i configurations and the lack of differentiation between CSSC and non CSSC workplans in. procedure AI-19.
.i
'l' The concern in Supplement'C wasjnot validated, therefore no root cause exists'.
Tile concern in Supplement D was n'ot valtdated, therefore no root cause exists.
V.
GENERIC APPLICABILITY SQN specific concerns XX-85-070-003 and XX-85-070-005 were validated at f
SQN and are considered to'be generic at all TVA sites.
+
SQN specific concerns SQP-6-003-003, SQP-86-003-N06, XX-85-070-002, XX-85-070-006, and HI-85-090-N02, were not validated at SON and are not considered gener:ic to other TVA sites.
WBN spac.lfic concern IN-85-305-NO3 evaluated generically at SQN was not validated.
p
- VI.
REFERENCES 1.
Topical Report TVA - 71 75-1, R8 a.
Section 17.2.3, " Modification Control" j
b.
Section 17.2.5, " Instructions Procedures, and Drawings" 2.
ONP NNiear Quality Assurance Manual a.
'Part II, Section 3.2, " Plant Modifications: After Licensing,"
June 24, 1986 I
b.
Part 1 Section 2.2 (ID-QAP-2.4), " Control of Modifications,"
U[,.[..
June 24, 1986 c.
Part I, Section 2.6 (ID-QAN-6.1), " Configuration Drawing j
Control," June 18, 1986 s
t 3.
Sequoyah Instruction Manuals i,
a.
SQA 122, "Non-CSSC Equipment Performance.issurance Program " RO I
I Page 15 of 18
R3visien 7 0
b.
AI-19 (Part III), " Plant Modifications: Modification Requests " R13
- c.. AI-19 (Part IV), " Plant Modifications: After Licensing," R18 d.
AI-25 (Part I), " Drawing Control After Unit Licensing," R15 e.
AI-25 (Part II), " Revision of As-Constructed Drawings," RO 4.
Memorandum from K. W. Whitt to H. L. Abercrombie dated March 3, 1986, " Nuclear Safety Review Staff Investigation Report Transmittal " Report Number I-85-637-SQN, " Work Plan Processing."
~
5.
Memorandum from H. L. Abercrombie to R. P. Denise dated July 8, 1986, " Nuclear Safety Review Staff (NSRS) Report No. I-85-637-SQN,
" Work Plan Processing" 6.
Memorandum from K. W. Whitt to H. L. Abercrombie dated March 17, 1986, " Nuclear Safety Review Staff Investigation Report Transmittal, " Report Number I-86-206-SQN Conduit Removal and Replacement Without Proper Documentation" 7.
Memorandum from H. L. Abercrombie to K. W. Whitt dated April 17, 1986, " Nuclear Safety Review F*sff (NSRS) Investigation Report I-86-206-SQN R1, " Conduit Ret.o el and Replacement Without Proper Documentation" 8.
" Compliance Visits, Audits, and Inspections - Inplant Survey Checklist No. 19C-85-S-006," dated December 20, 1985 (No RIMS Number)
{
VII.
IMMEDIATE AND LONG-TERM CORRECT]VE ACTIONS The following corrective action statemests are as stated by the SQN Corrective Action Plan (CAP) in response to ECTG element report 307.04 SQN.
(S03 860916 801) i' Supplement A:
(CATD 30704-SQN-01) M&AI-6 " Conduit Installation "
l 1s being revised. The revision is typed and l
awaiting PORC approval.
l lR7 l
Stpplement B:
(CAID 30704-SQN-02) All sign-off not applicable to l
a non-CSSC workplan must be marked "N/A."
l No workplan sign-off shall be left blank. No I
corrective action required.
l b
Page 16 of 18
.x R; vision'7 0
l
-Supplement B:
(continued)
I Response to_CATD 30704-SQN-003 l
l q
1.
I-85-637-SQN-01 Sequoyah Nuclear Plant management _ l believes that AI-19. part IV, I
currently addresses-the l
preparation of documentation i
only workplans sufficiently.
I Documentation only workplans
.- l are prepared in_the same l-manner as any other workplan.
. l.
l 2.
I-85-637-SQN-02 The contents of Section l
Instruction Letter l
MS/DCU-6 have (been, sic) incor-l porated into AI-7, in accordance.
l with Jannean Elliott, Document l
. Control Unit. A similiar 1
issue addressing records l.
identification is being l-addressed by CAR No.
l SQ-CAR-86-024.
l 1
3.
I-85-637-SQN-06 Personnel who initiate workplans IR7 are retrained each time a change l
is made to the workplan procedure l (AI-19, part IV).
People who l
write workplans are required to I
markup drawings or reference l
manuals in'the workplan prior
-l to that workplan.being approved.
l The ECN closure process will also l check to ensure that all_ required l-drawings are as-constructed.
l A recent training program was l
conducted at the plant to train I
personnel on how to markup control l room drawings upon completion of l
a workplan. The handout used and l the attendance roster was I
provided.
l 1
4.
I-85-637-SQN-07 Quality Assurance has responded l
to this recommendation and the l
following actions have been I
and are being taken which i
address this item. QA has l
performed a review of l
activities which need to be l
evaluated as part of its l
periodic surveillance program.
I Workplan review is included in l
this program. A recommended l
Page 17 of 18 i
_. _ _ _ ~ --- _
r R;visies 7 Supplement B:
(continued) l l
Response to CATD 30704-SQN-003 l
l 4.
I-85-637-SQN-07 (continued) l standard review schedule has l
been drafted and is expected l
to be published in a corporate l
DNQA procedure as Management l
Review Guidelines (MRG).
l The MRG's section 4.1 through l
4.8 addresses Engineering-Change l
Notice and workplan review l
1 with recommended frequencies I
normally quarterly or semi-l annual.
l CATD 30704-SQN-04 is being used to track the plant wide system walkdown program to ensure the current configuration and the engineering change notices (ECNs) review and clossout effort are completed.
(CAID 30704-SQN-04).
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Page 18 of 18 i
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y-PtGE' E Y' TENNESSEE VALLEY AUTHORITY Eltta TIME - I ECPS112J-ECPSII2C OFFICE OF NUCLEAR PONER EUf3 DATE
- 0W:^
EliI RT 13CC Nt.quCST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
I kt out.riCY OttP - 1553 - R11M LIST OF EMPLOYEE CONCERN INFORMATION KEYll0RD A S
DENERIC KEYt:0R0 B H
APPL QTC/NSRS P
KEYl10RD C' C0riCERil SUB R PLT BBSN INVESTIGATION
.S CONCERN KEYHORD D
!!Uff8ER CAT CAT D LOC F.L Q B,
REPORT R
DESCRIPTION SEQUOYAH UNIT 3'91 8 92.
CI EXPRESSE QA PROGRAM PROGRAHl1ATIC XX 070-002 6-44MS-H SQN YYYY I-85-637-SQN SS D A CONCERN THAT SPECIFIC QUALITY PR OPERATIONS OBLEMS (OPEN SINCE 1980) ARE IN THE GENERAL T50140 op ac rc4 K-FORM PROCESS OF BEING INTENTIONALLY CLOSE D IN A DUBIOUS MANNER TO PREVENT ATT
-(
RACTING THE ATTENTION OF THE NRC.
NAMES / DETAILS TO THE SPECIFIC CASE A RE KNONN TO QTC AND WITHHELD TO MAIN CI HAS NO MG TAIN CONFIDENTIALITY).
RE INFORMATION. NUCLEAR POWER DEPT CONCERN.
SEQUOYAH, UNIT I AND 2: CLOSURE OF S-CA PROGRAM
,/
RLCORDS XX 070-006 IH 00000 S SQN YYNY I-85-637-SQN SS PECIFIC QUALITY DOCUMENTATI0tl IS BEI OP ET!/.T I Ofl5 T50130 t0W9-S K-FORM NO FALSIFIED IN ORDER TO CLOSE THESE REPORTS CP 3aTo4 PROBLEMS OUT BEFORE THE NRC BECOMES ANARE OF THEM.
(NAMES / DETAILS TO T HE SPECIFIC CASE ARE KNOHN TO QTC AN D WITHHELD TO MAINTAIN CONFIDEllTI ALI TY).
HUCLEAR P0HER CONCERN. C/I HA 5 NO FURTHER INFORMATION.
Tr.,aAase.lh.~NsYsa,o u d e,: m,/ ; a ; s; 4 4,,,, a so poaj is H J' - BS' 090 - /#2-
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