ML20206U855
| ML20206U855 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/16/1986 |
| From: | Hutzler C, Workman J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20206U835 | List: |
| References | |
| MC-40201-SQN, MC-40201-SQN-R02, MC-40201-SQN-R2, NUDOCS 8610080437 | |
| Download: ML20206U855 (9) | |
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T7A EMPLOYEE CONCERNS REPORT NUMBER: MC-40201 - SQN SPECIAL PROGRAM f3. REPORT TIPE: Sequoyah Nuclar Plant - Element REVISION NUMBER: 2 TITLE: Instruments, Material. Equipment PAGE 1 0F 7 as it Relates to Purchasing and Requisitions REASON FOR REVISION:
Revised to incorporate comments from the Technical Assistance Staff (TAS) and the Senior Review Panel (SRP).
PREPARATION PREPARED BY:
W F /Befn ebr/ea SIGNATURE DATE
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REVIEWS b PEER: CLJL u. HJ A 9 - no - u, 3
SIifRATURE DATE TAS:
SIGNATURE DATE CONCURRENCES Q lbf%
CEG-SRP:
DATE SIGNATURE DATE SIGNATURE APPROVED BY:
s ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 1387T i
8610080437 860929 PDR ADOCK 05000327 P
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201 - SQN SPECIAL PROGRAM -
REVISION NUMBER:
2 PAGE 2 OF 7 1
I.
Introduction There were four concuena (EX-85-181-001, IN-85-463-008, i
IN-85-463-007, and IN-85-964-003) in this element relating to the relocation of equipment. All of these concerns were specific to Watts Bar Nuclear Plant (WBN) and determined to be potentially generic to Sequoyah (SQN) during the WBN evaluation.. Additionally, the TVA-SQN Generic Concern Task Force (GCTF) evaluated concerns l
IN-85-463-008 IN-85-463-007, and IN-85-964-003 at SQN. -
lR2 II.
Summary of Perceived Problems Three issues were identified from these concerns. An investigation lR2 was conducted to assess:
- 1. The adequacy of documentation for equipment and material transfered between TVA facilities, units or systems.
- 2. The adequacy of drawing revisions to reflect changes for the substituted / replaced equipment or material transferred.
- 3. The adequacy of documentation and drawing revisions for the transfer of unit 2, pressure dif$erential transmitters lR2 2-PDT-30-42, 43, 44, and 45 to SQN from WBN.
III.
Evaluation Methodology A.
Reviewed expurgated files to determine if additional information l
existed for applicable equipment and material transferred between IR2 TVA facilities, units, or systems.
l B.
Determined if concerns had been previously evaluated and reports lR2 issued.
l C.
Reviewed the following documents / procedures 1.
Purchase requisitions l
2.
Requests for shipment of material l
3.
Shipping tickets / orders l
4 Power storeroom requisition orders l
S.
Materials receipt inspection reports l
6.
Receiving reports lR2 7.
Statements of certification l
8.
Quality release reports l
1 9.
IVA NSSS shipping releases l
10.
Changes of contracts l
11.
Surveillance Report No. 3-86-5-002 l
12.
Corrective Action Report SQ-CAR-86-04-023 l
TVA EMPIAYEE CONCERNS REPORT NUMBER: MC-40201 - SQit SPECIAL PROGRAM REVISION NUMBER:
~2 PAGE 3 0F 7 i
l III.
Evaluation Methodology (continued) i C.
Reviewed the following documents / procedures: (continued)
SQA45, Revision 21, " Quality Control for Materials, Parts and lR2 Services SQA134 Revision 7. " Critical Structures, Systems, and Components (CSSC) List"--
SQA159, Revision 1, " Standards and Guides for Qu'ality Assurance Level III Items" SQA160, Revision 3. " Material Which May Come In> Contact With Reactor Coolant" l
SQA161, Revision 1, " Procurement of 10CFR50.49 Equipment" SQA162. Revision 1, " Purchase Specifications For CSSC Materials' SQM2, Revision 16. " Maintenance Management System" AI-9, Revision 19. " Control of Temporary Alterations and Use of the Temporary Alteration Ordern AI-11, Revision 35, " Receipt Inspection, Non-Conforming Items, QA lR2 Level / Descriptions, Changes and Substitutions" AI-19 Part III, Revision 23 " Plant Modifications:
Modification Requests" i
AI-19, Part IV, Revision 12. " Plant Modifications: After Licensing" AI-36, Revision 8, " Storage Handling, and Shipping of QA Material" D.
Reviewed SQN Generic Concern Task Force report for IN-85-463-008, lR2 IN-85-463-007, and IN-85-964-003 to determine adequacy of findings and conclusions.
E.
Interviewed knowledgable individuals from Maintenance, Design IR2 Support Power Stores, and Quality Assurance to determine if adequate guidance was available from the procedures and reports as listed in part III C in this element report.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201_ 39 SPECIAL PROGRAM
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REVISION NUMBER:
2 PAGE 4 OF 7 IV.
Summary of Findings A.
ECTG expurgated files were reviewed and it was found that concern number IN-85-463-008, for the transfer of Pressure Differential Transmitters 2-PDT-30-42, 43, 44, and 45, has been lR2 resolved to the satisfaction of the concerned individual and is no longer a concern.
PurchaseRequsit[on 970095 was written to transfer the above PDTs from WBN. The documentation was reviewed in accordance with AI-11.
Subsequently, it was also reviewed by Quality Assurance (QA). Division of Nuclear Engineering (DNE), and Environmental Qualification Project (EQP) personnel and found acceptable.
No further information was found from the ECTG expurgated files involving concern numbers EX-85-181-001, IN-85-463-007, and IN-85-964-003.
B.
No investigation report was found for EX-85-181-001.
GCTF l
investigation report was found for concerns IN-85-463-007, 008, lR2 and IN-85-964-003.
l C.
Reviewed SQN documentation and pr.9pedures listed in section III C lR2 of this element report and found that all the procedures in section III C were complied with and documentation was properly generated lR2 to transfer. transmitters 2-PDT-30-42, 43, 44, and 45 in concern IN-85-463-008.
Reviewed Standard Practice, SQA45 Revision 18 (November 21, 1985),
lR2 Quality Control for Materials, Parts and Services, which governs the procurement of parts, materials and services for application to the SQN and found that it established purchasing as the responsible staff for all procurement. SQA45 designates the purchase request originator as the person responsible for specifying quality assurance (QA) requirements for the purchase. The Standard lR2 Practice requires the originator to specify several characteristics l
including component ID number, system number, exact location or function, piping class, vendor style, vendor part of vendor drawing number, size, and design, 10 CFR Part 21 applicability, QA level, Environmental Qualification (EQ) applicability, and Certification lR2 of Conformance documentation.
l The current procedure (SQA45, Revision 21) requires a review of the lR2 purchase request by the Support Services, Material Unit for appropriate QA Level, and a technical review of QA Level I and II items. The QA levels are defined in the procedure.
Adequate guidance is given by references to SQA134, 159, 160, 161, and 162 for determining original specifications.
TVA EMPLOYEE CONCERNS
--reb)RTNUMBER: MC-40201 - SQlt SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 7 IV. Summary of Findings (continued)
For borrowed or transferred equipment. SQA45 requires that a lR2 Transfer Request be initiated in accordance with the requirements for a Purchase Request. Emergency Purchase Requests must also follow these requirements.
lR2 SQA45 was revised on November.:21, 1985 (Revision 18), to provide lR2 for proper handling of equipment and documentation covered by 10CFR50.49. Multiple references in SQA45 direct a purchase originator to SQA161, " Purchase of 10CFR50.49 Equipment." SQA161 defines the overlapping responsibilities of the originator, the lR2 Materials Unit, and the EQ Coordinator.
i SQA45, Revision 21, Section 6, ensures that transfers of materials originally purchased from suppliers that provided vendor information such as manuals or drawings, shall require that the vendor information be transferred as an item on the transfer request. This information was required to complete the receipt inspection of the transferred material. After completion of the receipt inspection Power Stores ic required to forward the vendor infonmation to the Supervisor, Drawing and Vendor Manuals Unit for l
approval and inclusion into the appropriate control system. A copy of the shipping ticket is to accompany the vendor information as a coversheet.
Reviewed AdministrativetInstruction AI-11, Receipt Inspection, Revision 35, Section 6, and found that it provides guidance for lR2 conducting receipt inspection of transferred materials and equipment.
Section 8 provides instructions for upgrading QA levels for parts and materials.
Activities that would lead to transfer / replacement of equipment are conducted under the Maintenance Work Request Control Systems.
SQM 2, Revision 16. " Maintenance Management System", governs work performed under a Maintenance Request (MR). It refers to lR2 Maintenance Instruction MI-6.21 for parts borrowed or transferred for CSSC application. SQM 2 specifies that borrowed parts must meet lR2 SQA45 standards if being used on another system (difference class).
Appendix C of SQM 2 requires that the planners (Maintenance) lR2 ensure that no modifications are involved.
Planners require a Design Change Request (DCR) or Field Change Request (FCR) whenever.
a drawing revision is necessary.
lR2 A transfer may be initiated by a DCR directly or a Maintenance l
l Request-Design Change Request (MR-DCR).
AI-19, Parts III and IV, lR2 controls the processing of transfers. The DCR/FCR is often used to update drawings for simple changes.
Conversations with onsite i
TVA ENPLOYEE CONCERNS REPORT NUMBER: MC-40201 - SQN SPECIAL PROGRAM
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REVISION NUMBER: 2 PAGE 6 0F 7 IV.
Summary of Findings (continued) design support engineers verified that they routinely receive lR2 DCRs/FCRs that update the instrument tabulations (TVA 47B601 l
Series drawings) and feel comfortable with this process.
D. During the original GCTF investigation of concerns IN-85-463-008 IN-85-463-007, and IN-85-964-003, additional transfer lR2 documentation was checked. The GCTF report to the Management Review Group (MRG) dated, January 10, 1986, recommended a detailed review of equipment documentation. The plant QA staff subsequently reviewed documentation for equipment transfers and found lR2 programmatic deficiencies. As a result, Corrective Action Report SQ-CAR-86-04-023 for missing documentation (Watts Bar receipt lR2 inspection reports, contracts, vendor documentation, and certifications), was issued to ensure that resolution of the deficiencies is tracked and closed out.
lR2 E. During interviews with knowledgeable individuals from Maintenance, Design Support, Power Storet, and Quality Assurance, they stated the procedures (reviewed and listed in part III C in this element report) contain all the necessary instructions, guidance and provisions to fully meet all the criteria for the transfer, substitution and documentation of material and equipment.
The knowledgeable engineers interviewed could give no examples of transfers, substitutions, documentationr or drawing revision updates being incorrect except for deviations relative to documentation received during receipt inspection identified in SQ-CAR-86-04-023 above. The corrective action report also requires corrective action to prevent reccurrences. All who were interviewed I were aware of the procedures for the correct preparation and l
Implementation according to the appropriate procedures as previously lR2 listed in sections III C.
l V.
Conclusions
- 1. After reviewing the documents / procedures in part III C and others listed in the body of this element report, it was found that all the lR2 documents were adequate and all the procedures,were followed for the proper transfer of equipment and material between TVA facilities, units, and systems except for items identified in SQ-CAR-86-04-023.
Therefore, the perceived problem of inadequate documentation for equipment and material transferred is valid lR2 to the extent that some documentation was not received.
l 2.
The existing procedures give adequate guidance to ensure initiation of requests for documentation and inspection upon receipt when equipment is transferred between plants, units or systems.
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TVA EMPLOYER CONCERNS REPORT NUMBER: MC-40201 - SqN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 7 V. Conclusions (Continued)
Provisions are made in the Maintenance Management and Design Change i
systems for drawing updates.
Interviews with knowledgeable individuals indicate that drawings are continely updated and documentation is routinely transferred along with equipment. It was found in the Summary of Findings,Section IV A through D, that the planners (maintenance) were comfortable making the decision on IR2 whether an MR requires a DCR or FCR. Therefore, the recommendation in the GCTF Investigation Report,Section V, does not require i
implementation. The perceived problem of inadequate documentation i
to reflect changes for substituted / replaced equipment or material IR2 is not valid.
l 3.
Documentation and drawing revisions were found to be adequate and complete for the transfer of 2-PDT-30-42, 43, 44, and 45 to SQN from WBN. Therefore, the perceived problem of inadequate l
documentation and drawing revisions for the transfer of 2-PDT-30-42, 43, 44, and 45 to SQN from WBN is not valid.
f 4
VI. Root Cause Root causes correspond to numbered conclusions and perceived l
problems.
l 1
1.
Failure to follow procedures lR2 1
2.
No problem identified l
3.
No problem identified l
r VII. Corrective Action Corrective action required by line organization for SQ-CAR-86-04-023.
VIII. Generic Applicability None II. Attachments None lR2 i
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MATERIALS CONTROL Enc 1csura 2 ECTG WRITER'S GUIDE ELEMENT REPORT FORMAT 1.0 Issue I.
Introduction Characterization II.
Sununary of Perceived Problem 2.0 Suasaary IV.
Suasaary of Findings Conclusions (Portion) 3.0 Evaluators Cover Sheet Information 4.0 Evaluation III.
Evaluation Process Methodology S.0 Findings IV.
Sununary of Findings 6.0 Root Cause V.
Root Cause (Collective Significance)**
- Overall Root cause will not be considered at this A
report level.
7.0 Attachments /
VIII. Attachments List of Concerns Other items included VI.
Corrective Actions in Construction Element (To be provided by Reports line organizations)
VII.
Generic Applicability 1905T
Page 1 of 1 l
SEQUOYAH EMPLOYEE CONSTRUCTION CATGORY CONCERN ELEMENT REPORT NUMBER ISSUE Material Control 40302 PH-85-035-002 Valve (cracked) as Related to Material l
Control Material Control 40201 EX-85-181-001 Instruments Material.
IN-85-463-008 Equipment as it Re-IN-85-463-007 lates to Purchasing IN-85-964-003 and Requisitions 1
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