ML20207L017
| ML20207L017 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/22/1986 |
| From: | Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K654 | List: |
| References | |
| 307.01-SQN, 307.01-SQN-R01, 307.01-SQN-R1, NUDOCS 8701090592 | |
| Download: ML20207L017 (8) | |
Text
ai TVA EMPLOYEE CONCERNS REPORT NUMBER: 307001-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 1 TITLE: Plant Operations Review Committee (PORC) Process REASON FOR REVISION:
Incorporate comments from SRP and TAS Revision 1 PREPARATION PREPARED BY:
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EMPLOYEE -CONCERNS-TASK- GROUP -------
OPERATIONS CEG Subcategory: Nuclear Power / Site Program / Procedures
- Riement: Plant Operations Review Committee (PORC) Process Report Number: 307.01 - SQN Revision 1
- 118285-457-001 Evaluator: //* < / /2-4/ -M T. W. Whits Date s/ / // ,
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R:visicn 1 I. PLANT OPERATIONS REVIEW COMMITTEE (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 METHODOLOGY 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 Head (CEG-H) and determined to be 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 asse'ss the' effectiveness of implementation in actual' practice; The requirements for the PORC process are delineated in Regulatory Guide 1.33 (reference 10). This Regulatory Guide implements and endorses ANSI N18.7 (reference 11). Commitment to these documents by the Teanessee Valley Authority (TVA) for SQN is contained la 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 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 reviewed and informal interviews were held with various members of the SQN staff, notably, the Plant Operations Review Staff Supervisor, 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.
III. FINDINGS The adequacy of the SQN PORC process has been evaluated by the U.S.
Nu'e lear Regulatory Commission'OTRC) and by TVA Division of^ Quality -t 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.
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R;visica 1 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, Radwaste 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 revi ewed - vi olations-o f-the -admi n is trative-secti on -of- the-Techni cal Specifications (T.S.) as required by TS 6.5.1.6. Deviation D04 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 formal review and make a report.of a potential safety hazard as associated with t.he accuracy of Measuring and Test Equipment (M&TE) used for calibrating the Reactor Protection Sy' stem (RPS) instrumentation. ~The~M&TE used did not meet the accuracy assumptions used in the setpoint methodology fo* RPS trip setpoints.
The NRC raised other issues concerning PORC activities in the timeframe IR1 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 (ref'rence"4)' e 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
' wort'for PORC. These two l'tems, among others,'were'iden'tified as '
" Potential Violations." '
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)i Specific plant staff i~ndivlduals~a're identified as Qualified Individuals (QI) within their discipline and area of expertise. Also included are specific qualification requirements that Page 2 of 5
R:visien 1 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, subcommittee 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 October 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 rand ~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 comunitments made for PORC. responsibilities in SQA 21 (reference 4). The purpose for.this comparison was to ensure that all Technical
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Specifl'ea' tion items had been accurately translated' info"SQA 21,'the
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working document governing PORC activities. Once assured that SQA 21 was accurately aligned with Technical Specification 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 (R1 (October 1, 1986), 4003 (October 2, 1986), 4004 (October 3, 1986), and 4005 (October 6, 1986). These documents were obtained from the PORC Secretary; they consisted of the typed minutes, the, cough 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.
Conclusion During the timeframe of the concern at WBN, it was valid for SQN. l Corrective'a'etion's to' deficiencies' identified by'NRC and DQA have been I
implemented. The corrective actions discussed in this evaluation. in I their aggregate provide positive controls for the PORC activities. iR1 Routine scheduled audits will be conducted by DQA to assess the i effectiveness of the changes made in the PORC process. I i
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i R;visien 1 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 Tha root cause of this issue was a failure to assign fixed lR1 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.
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
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- Operatiott 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) i
- 5. Sequoyah Nuclear Plant Standard Practice, SQA 119, "Unreviewed Safety Question Determination," (revision 6, dated '
September'26, 1986)
- 6. Sequoyah Nuclear Plant, Unit 1 Technical Specifications, l Section 6.0, " Administrative Controls," (Amendment 44, dated July l
28, 1986)
- 7. Sequoyah Nuclear Plant, Unit 2 Technical Specifications, Section 6.0, " Administrative Controls," (Amendment 36, dated
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July 28, 1986)
- 8. Draft, " Plant Operations Review Committee Charter," (dated October 28, 1986)
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- 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)
- 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 . - Qu alitrAssurance - Aud it- Report- QSQ- A-86-00057- 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.0ctober 6, 1986. .
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f5. Memorandum fromPOR'C Sube~ommitt'ee to P. R.'Wa'11dee. " Seq'uoyah' Nuclear Plant - PORC Review of Sequoyah Nuclear Plant Standard Practices", dated August 13, 1986, (SS3 860812 928)
- 16. NRC Internal Memorandum, "STS, Section 6.5.1," dated October 1, 1980
- 17. SQN Corrective Action Tracking System (CATS), number 85495, originated December 31, 1985, completed October 27, 1986
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- 18. NRC Report'50-327/85-46 and 50-328/85-46 (dated January 29; 1986)
VII. IMMEDIATE OR LONG TERM CORRECTIVE ACTION No further corrective action, immediate or long term, is deemed necessary by this evaluation.
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$ 4 REFERENCE - ECPS120J-ECPS121C TENNESSEE' VALLEY AUTHORITY
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