ML20207L069
| ML20207L069 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/19/1986 |
| From: | Halley M, Murphy M, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K654 | List: |
| References | |
| 308.04-SQN, 308.04-SQN-R02, 308.04-SQN-R2, NUDOCS 8701090611 | |
| Download: ML20207L069 (17) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 308.04-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 TITLE: Program / Procedure Violations REASON FOR REVISION:
To incorporate SRP and TAS comments and SQN Corrective Revision 1 Action Response.
To incorporate SRP comments Revision 2 i
i PREPARATION PREPARED BY:
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- SRP Secretary's signature denotes SRP concurrences are in files.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG !
Subcategory: Maintenance k Element: Program / Procedure Violations
\
f Report Number: 308.04-SQN Revision 2 IN-86-073-002 IN-86-315-002 IN-86-110-001 SQP-85-004-006 JAN-86-001 I-86-233-SQN JLH-86-001 Evaluator: M. Halley /A//9/f/
M. Halley Date Revieued by: iffAd))h g 1 //F/&'
OPS CEG f nep6er 'Date Approved by: h /A//f[#6 W. R. Lagergren 'Date 1791T
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- Revision 2 I.
Title:
Program / Procedure Vio1a'tions This report evaluates the general issue of following required-maintenance programs and procedures at Sequoyah Nuclear Plant (SQN).
Seven specific employee concerns related to this are itemized below, i' Concern JLH-86-001 is shared with the Quality Assurance (QA) and IR2 Intimidation and' Harassment (IH) Category Evaluation groups. l y,
II. Specific Evaluation Methodology l.
- The employee concerns identified for this element are stated as follows:
M;3 1 Concern IN-86-073-002:
- i "The mechanism exists for technicians to verify if the vendor manuals 3 kept in the shop contain the latest updated drawings or schematics.
- j Using out of date drawings or schematics could cause the plant instruments to be placed (unknowingly) in an out of configuration Details known to QTC withheld to maintain confidentiality.
}3?
status Concerned individual (CI) has no additional information. Nuclear power j concern. unit 1." (Watts Bar) li Concern IN-86-315-002:
" Engineering design drags problems off before they are fixed. To make 4 this point clear. CI stated that when inspection department issues notice of indications (NOIs) or maintenance requests (MRs) that engineering will disposition them without fixing. CI stated this as a j generic concern. Nuclear power concern. CI has no further information."
l Concern IN-86-110-001:
j.,
d "During ice loading. TVA used jack hammers to compact ice to achieve the i minimum basket weight requirements. This could result in " CHANNELING" of ice and endanger containment integrity during a 10CA (loss of coolant accident). CI has no addition.a1 information. Unit 1/ Nuclear power
)[.
l concern."
]
.i j Concern SQP-85-004-006:
1
!$ " Procedure MI-10.37 requires a 0-30 in. Ib. torque wrench be used, yet p craft are told to use a 0-24 in. Ib. torque wrench. CI feels craft should not be asked to violate a procedure. Nuclear power concern. CI
!J has not further information."
lj h
i Concern JAN-86-001:
1
" Phone call received about drawings being marked up for WP 10512 (class 4 1E fuses ID) without completing the work."
Concern I-86-233-SQN:
- n fl "An anonymous individual mailed in a potential safety hazard associated P with the Condensate Demineralizer Waste Evaporator (CDWE) on EL 706 of Page 1 of 13
! )"1
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Revision 2 the Auxiliary-Building at SQN. The original stainless steel piping for pumping " bottoms"-from the CDWE was removed and replaced by a temporary ,
rubber hose. Extensive modifications are being performed over the rubber hose. Welding hot chips have been observed falling on the rubber hose. Damage to :r rupture in the hose would result in possible personnel exposure of a very high amount."
Concern JLH-86-001:
"1. MRs which require the. addition of grease to limitorque valve operators are signed by a general foreman as "no grease necessary" when, in fact, the grease levels are low or need replacing.
- 2. MRs which the general foreman considers unimportant are signed off as complete even though no work was performed. ;
i The evaluations for the concerns included in this report included l
interviews with cognizant SQN personnel who had or have responsibilities in the specific area being evaluated.
Applicable TVA procedures, records, correspondence, regulatory
- requirements, and other upper-tier documents were also reviewed.
Existing NSRS reports were also utilized as source information for j concern evaluation. Reference documents and procedures are listed
! in section VI of this report.
I
- III. Findings i
Evaluation Results o- A. IN-86-073-002
?
l Examination of the documentation associated with Corrective Action Report (CAR), " CAR 85-03-005 " revealed that significant corrective action has been implemented to ensure that vendor drawings are 7
l properly validated. This CAR was issued by SQN QA when it was discovered that the SQN instrument section was working from unvalidated vendor drawings in the field. At this time vendor IR2 drawings were to be used for information only and no program existed for verifying or "As-Constructing" (AC) these drawings. Drawing control procedure. Administrative Instruction (AI)-25 (reference 2),
was modified at the b3 ginning of 1986 to implement a new program for
, vendor drawings configuration control. The parent document. TVA Nuclear Quality Assurance Manual. (NQAM, part III, section 1.1) was l' also revised by issuance of a quality notice (appendix A, dated l
November 29, 1985). This quality notice provided for use of best
! copy available vendor drawings. Specifically, AI-25 requires the .
l Vendor drawing user to verify if a " Configuration Control Drawing" oxisted before doing work in the field by requiring completion of the appropriate forms and consequently making a determination of the "Best Copy Available" (BCA) vendor drawing. A BCA vendor drawing is Page 2 of 13 ,
i :
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Revision 2 -
a unverified drawing or a drawing which has not been completely verified (" Partially Verified") against the existing plant configuration. It is the drawing that is determined to be the best 4
available information onsite for'a particular job application. BCA drawings are stamped "Best Copy Available" and also marked "Use with '
I Caution." "Best Copy" authorization is good for 30 days from the i
date stamped. During the use of this drawitt, the
! equipment / component will be visually inspected to compare the drawing to actual configuration if the portion being used has not been previously verified. The portion of a drawing which has been verified will be circled; eventually the entire drawing will be "As-Constructed." Consequently, this program provides for field 7 .
-verification of an unconfigured vendor drawing by field inspection
{
and subsequent cognizant engineer review and approval. In
! accordance with current AI-25 (section 5.2.10) requirements, only L j drawings listed as " Controlled Copy," " Verified Copy," " Partially .
y-Verified, " and "Workplan Copy" shall be allowed for use in the plant main control room. Other drawings are allowed in the plant but shall not be utilized in activities affecting quality. The new
~ vendor drawing program is being utilized by plant personnel; four vendor drawing configuration packages (AI-25, attachment B's) were located in the drawing control unit. No additional problems in this
- area were identified by drawing control personnel.
1
. B. IN-86-315-002 Examination of a Nuclear Safety Review Staff (NSRS) investigation report I-85-738-SQN, which is related to this problem, and discussions with Inservice Inspection (ISI) personnel, revealed Notice of Indications (NOIs) have been dispositioned without h providing apparent documentation of the final NOI resolution. NOIs can legally be reevaluated or rectified by acceptance criterial
)_ change or reinspection by an NDE supervisor or a higher-level examiner. This was substantiated by the NSRS report (reference 10);
in addition the report did not identify any improper NOI i acceptance. The SQN implementing Surveillance Instruction 1 (SI-114.1, Unit 1; SI 114.2 Unit 2) is currently being changed to provide better documentation of NOI resolution. New forms are being added which will require a statement to be made about how NOIs are l resolved.
9
- The NSRS made recommendations in two areas: (1) NDE procedure
h revisions will adequately correct the NSRS concerns in this area.
j This is currently in progress. Surveillance Instruction revision is
~
identified as a restart item.
1 1 There were three NSRS concerns noted in the NSRS report that were d related to documentation discrepancies. The first two were similar d in that apparently the NDE examiner's certification was inadvertently s omitted from the NDE personnel certification summary. In both cases 1
- t 5
i; 1 Page 3 of 13 0
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i 1 Revision 2 documentation indicating proper certification was located by the NSRS and no corrective action was necessary. The third documentation problem was that the re-examination sheet for NOI SQ-0189 indicated that a WR had been written to replace a missing lock wire (not associated with the re-examination) which was i discovered during re-examination to verify corrective action for a l previously rejected hanger. Part III of the NOI does not indicate that there was follow-up verification that the WR haJ been completed. This should be verified and documented.
l Upper-tier requirements for this program are 10 CFR part 50.55 which specifies inservice inspection requirements for NDE of SQN components in addition to the ASME Boiler and Pressure Vessel Code section XI which specifies the rules for inservice inspection of nuclear plant components. These are adequately implemented in SI 114.1 and 114.2.
C. IN-86-110-001 Ice condenser weighing, addition, and removal is controlled by SQN -
maintenance procedure MI-5.3. At SQN basket space for ice addition is made utilizing a thermal drill. This is a cone-shaped insulated heat element that melts the necessary cavity for ice addition. A jack hammer or concrete vibrator was used briefly for demonstration purposes about four years ago. The demonstration was for evaluation
, of acceptable ice addition techniques. SQN maintenance personnel [
- were concerned about potential basket damage that could be created by jack hammer usage. As noted in NSRS report I-85-455-WBN,
- Westinghouse has tested various shapes and configurations and verified that ice condenser bed performance is not significantly l affected by configuration or shape and size of pieces of ice. This i is documented in Westinghouse reports
- WCAP-2951 and WCAP-7040. In
! conclusion SQN has never routinely utilized a jack hammer for ice
! addition.
[ D. SQP-85-004-006 The SQN Technical Specification, Section 6.0, " Administrative Controls", paragraph 6.8.1 requires that written procedures be established, implemented, and maintained covering activities as i recommended in appendix A of Regulatory Guide 1.33. The TVA NQAM, i part III, section 1.1, part 5.4 also requires that activities i affecting nuclear safety be prescribed in documented procedures and
- instructions. The SQN implementing procedures for these j requirements are Administrative Instructions AI-4 (reference 6) and AI-30 (reference 13).
j Examination of NSRS report I-86-165-SQN related to this concern indicated that 11 of 16 craft personnel interviewed stated that they j had been directed to work without procedures or proper paperwork. l i
1 Page 4 of 13
P ,
J.-
Revision 2 Some craftsmen stated that they had been directed to sign off Critical Systems, Structures, and Components (CSSC) work performed by others and some stated that they had been asked to perform steps-out of order. Nine of eighteen craftsmen stated that they had been directed to use tools different from those required by the procedure. On December 31, 1985. MI-10.37 was performed.- The MI
! specified the use of a torque screwdriver with a range of 0-30 in.
Ibs. The specified torque screwdriver was unavailable and the CI 1 was allegedly instructed by management to use a 0-24 in. Ib. tool.
This was done without processing the required nonintent procedure change.
1 The SQN electrical maintenance supervisor stated that he could not
- refute the NSRS findings. He also stated that use of the-0 to-24
- in. Ib. torque screwdriver fulfills the technical requirements for i torquing screws to a maximum of 20 in. Ibs, In addition he stated j that this has not happened since it was identified during an NRC.
j inspection conducted on December 8, 1985, through January 5, 1986.
The Electrical Maintenance Section has, subsequently, conducted
- j - special training and workday feedback meetings to stress requireteents and identify problems. In view of the extensive NSRS 1 investigation report, discussions with maintenance personnel, and j NRC violations (327/85-47-03, 378/85-47-03) this concern is valid, i
j The SQN data base for NRC violations related to procedure problems was searched. The existing CARS data base combines a record of all h'
NRC violations. There were 56 records listed as NRC violations of unit 1 and unit 2 procedures. 21 of the unit. 1 violations were also common to unit 2; thereby making
- 35 unique procedure related violations. A significant I number of violations, 21, were related to either having
) inadequate procedures or not having procedures. At SQN there have
( been 12 NRC violations for not following procedures. Of these, eighc were related to organizations other than maintenance.
, Therefore, there have been four unique NRC violations issued for not 1 following maintenance procedures. There were four unit i violations I also common to unit 2 that were caused by not following maintenance i
- procedures. A survey of the gus11ty assurance records revealed that one CAR (85-05-008) had been issued for not following maintenance f
procedures.
The fifth annual Systematic Assessment of Licensee Performance (SALP)
)f report (reference 16) rated overall SQN maintenance as category 3,
'I which indicated that both NRC and licensee action should be j increased in this area. The report stated that personnel errors by instrument technicians caused several plant trips; however, some 4
-) technicians performing maintenance tasks were observed using good
! work practices and implementing the management expressed philosophy of adhering to procedurel requirements. It stated that some maintenance instructions were weak or nonexistent for some safety-related activities. There were several procedural violations (six) involving the failure to establish or implement t
1 l *:
Page 5 of 13
Revision 2 procedures. In general, maintenance procedures were adequately written and followed. However, many procedures were cascaded and interwoven with other procedures, requiring personnel to transfer between documents in order to complete a single activity. The overall summary results indicated that " increased management attention is needed in the maintenance area to eliminate cumbersome procedural interdependencies and affect stronger controls on the use of quality maintenance procedures." This summary also stated that there were" only minor weaknesses due to personnel errors and failure to follow procedures."
E. JAN-86-001 Interviews with involved personnel established that this concern related to prematurely closing WP 10512 and electrical fuse installation. This has been completely resolved. WP 10512 was also reviewed and it was verified that it was properly closed out. There are several workplans associated with Engineering Change Notice (ECN) lR2 L5880 to identify all auxiliary power systems that utilize fuse protection with L unique identifier in a format specified by the TVA, SQN Unique Identification of Structure Systems, and Components (UNID) task force. Completion of all associated workplans will complete the entire fuse identification program. In addition, there are no generic problems with premature close-out of individual workplans prior to drawing mark up. In accordance with plant modification procedure AI-19 (reference 14), workplans are not verified complete by the document coordinator until it is verified that the appropriate preceding workplan steps are completed. This includes drawing requirements, spare parts, nameplate data, and post modification tests.
F. I-86-233-SQN Interviews with cognizant personnel established that the Condensate Demineralizer Waste Evaporator (CDWE) was shut down in August 1985, for modification of the reflux system and also for addition of a rubber, wire reinforced bull hose which is routed from the evaporator off grade distillate and bottoms pump to the Plant Floor Drain Collector Tank (FDCT). The hose is routed from the CDWE room through the upper head injection (UHI) area and Auxililary Building Gas Treatment System (ABGTS) area to the 690 ft.el. pipe chase to the 653 ft.el, to the FDCT. Radiation monitors are installed in key locations with flashing red lights and radiation meters that will warn personnel when high level effluent exists. Additionally drainage is by gravity flow and the hose is not subject to high pressures. During routine operation, the hose is utilized to drain very low level radiation (less than background) off grade distillate that eventually goes to the river.
Therefore, during normal operation there is no danger of personnel contamination. Draining contaminated fluid is only necessary durinr.
and subsequent to an emergency Ovaporator shutdown necessitated by pump seal failure or other similar problem.
l l
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e Revision 2 The CDWE operation procedure, Syste'n Operating Instruction (SOI)-77.1B3, " Waste Disposal System (Liquid)" was reviewed. It provides for personnel. protection during evolutions of high radiation level drainage for pump seal failure, which requires.
dumping bottoms, and discharging the slurry tank to the FDCT. In these cases the procedure requires notification of health _ physics so that personnel can be cleared from the area. The addition of this hose provided for CDWE drainage in lieu of having all evaporator drainage _ routed to various floor drains which have occasionally backed up and caused contaminated water to flood the floors. Design work is in progress to remove the hose and install permanent pipe.
Protection of burnable material during cutting and welding is adequately provided for in plant procedure AI-15 (reference 15).
One individual stated that he has seen the CDWE bull hose covered during welding.
G. JLH-86-001 This concern, which is related to unit 2, was investigated by the SQN QC' organization. The grease has been sampled on all unit 2 Limitorque operators, and maintenance verified that they are properly greased. This was done in accordance with Maintenance Instruction MI-10.46. There was no indication that a foreman had canceled or deleted corrective action. This is documented in the QC inspection report dated June 13, 1986.
The concern related to a general foreman considering some_MRs l unimportant and signing them off as completed, even though the-associated work is incomplete, must be considered valid. The CI j identified this problem by observing'that the white linen tags i associated with MRs A299897. A298222, and A298220 were still intact yet the maintenance records (computer printout) indicated that the work was complete. The portion of the work not completed was reinstallation of conduit covers. The Electrical Maintenance l Section attempted to verify if the covers had been replaced and I subsequently removed for other work or to verife if the MRs properly fi
- required cover reinstallation; however, the MRs could not be located, and this could not be established. A Work Request was
/ written to have the covers installed. The Electrical Maintenance i supervisor stated that reinstallation and maintenance of condulet covers is a problem and that removal of white linen tags upon work
( completion is also a problem. White linen tags are not being used under the new SQN Work Request (WR) system which is a more convenient way to tag and identify deficiencies in the field. In accordance with SQM-2, the new WR system utilizes a two part form for planning and implementing maintenance work. Field tagging of I. work in progress is accomplished by separating mutually identifiable e portions of the WR, thus making it obvious that a tag is in place e that must be removed subsequent to work completion. The old system l did not adequately identify when tags had been placed in the field.
s The Electrical Maintenance supervisor has stressed the importance of I strictly following procedures and has taken disciplinary action when
! it could be proven that an individual improperly signed off a document.
Page 7 of 13
Revision 2 The concern with traccability of QA material was investigated by the NSRS (reference 12). The NSRS performed a review of the Electrical Maintenance toolroom receiving, issuing, and storage practices for small parts drawn from Power Stores for general plant use. Problems identified were: 1) QA and non-QA bins not segregated, 2) QC documentation, TVA Form 575, not being kept with the parts, and 3) new parts with different TVA Form 575 numbers were added to existing stock. The NSRS identified an improper bolted connection on cell 10 of the diesel generator 1A-A battery. The bolt was plated carbon steel rather than the required stainless steel. This bolt was replaced by WR B116001 dated February 23, 1986.
Following identification of the material traceability problem, the Electrical Maintenance (EM) Craft Supervisor issued a memorandum defining corrective action (see attachment B). All items were to be bagged and placed with the appropriate 575. Items which could not be identified were segregated to be used for non-CSSC applications only. Electrical Maintenance Section Instruction Letter EM SIL-48 (reference 17) has been issued to ensure traceability is maintained in the shop area. As recommended in the NSRS report, to determine the impact of this concern, an evaluation has been prepared by the Electrical Maintenance Section and is being submitted to PORC at the preparation of this report, (see attachment D). This will be complete before startup. This evaluation stated that there has been no need at SQN to trace material issued to resolve manufacturing defects for small parts such as adhesives, threaded fasteners, conduit fittings, lamps, lamp holders, tape, and terminal lugs that are commonly stored in the Electrical Maintenance toolroom. In addition, CSSC work package review and surveillance testing provide protection against the use of non-QA material on CSSC.
Conclusions:
A. IN-86-073-002 The concern that uncontrolled vendor drawings have been used in the field is valid. This concern is safety-related. However, this lR2 problem has been adequately documented, corrected, and a new program is in effect to "as-construct" or partially verify vendor drawings. lR2 B. IN-86-315-002 The concert, that in-service inspection or design personnel have written off NOIs without taking proper corrective action was not valid. Better documentation traceability is needed in this lR2 area, and this is being provided by revising ISI procedures, SI-114.1 and 114.2. Follow-up should be effected to verify that the WR associated with the NOI SQ-189 re-examination is complete.
The fifth SALP report (reference 16) stated, "The implementation of the In-Service Inspection / Inservice Testing programs were well managed, and the inspection and testing activities well organized."
Page 8 of 13 i
Revision 2 C. IN-86-110-001 Addition of ice to SQN ice baskets is not done using a jack hammer or concrete vibrator; this concern is not valid. SQN maintenance lR2 personnel utilize a thermal drill.
D. SQP-85-004-006 The concern related to electrical craft being instructed to deviate from procedure MI-10.37 is valid. .This is a safety-related I concern. A nonintent procedure change was not processed as IR2 required to allow using a 0-24 in. Ib. torque screwdriver rather l-than the required 0-30 in. Ib. device. A review of the NRC' violation data base and quality assgfance-records indicates that there have been occasional problems with following maintenance procedures; however, these problems are not at the level or severity to be of significant safety concern. The SQN Maintenance Sections have made substantial progress and significant changes to improve performance in this area and also to provide-management feedback if problems are identified by craft. Special maintenance training has been conducted by POTC training personnel which stressed the importance of following procedures to maintenance craft personnel.
A two day program was conducted subsequent to the problem identification and an additional course was taught in March and April of 1986 for all craft personnel. This training is in accordance with EMSIL A-67. In addition to special training, the electrical maintenance has 11 a.m. feedback meetings every workday in which foremen have the opportunity to discuss problems.
Corrective action for this type problem is in progress and is a goal of the new TVA Nuclear Performance Plan. TVA is upgrading its nuclear operation, maintenance, and surveillance procedures, placing increased emphasis on compliance with procedures and has taken steps to identify any developing problems in nuclear operations. In accordance with this, SQN is taking steps to improve maintenance i accountability. Steps are being taken to improve maintenance l procedures.
E ., JAN-86-001 The concern related to closing workplan 10512 before work completion i is valid. However, this concern is resolved and the CI no lR2 longer has a problem. Fuse identification is currently in progress (ECN 5880) and will be completed before restart. (Attachment A).
i F. I-86-233-SQN The concern related to extensive modifications and welding over the CDWE bull hose is not valid. There have not been extensive IR2
[g modifications in this area. In addition, the likelihood of
) personnel contamination is very remote. Plant procedures require that burnable material be protected during welding and grinding.
Local alarms also warn personnel if high level effluent is being 7
) drained to the FDCT.
l a
Page 9 of 13 I
t
Revision 2 G. JLH-86-001 ,
. Interviews.with cognizant SQN personnel, and examination of appropriate documentation revealed that the concern related to i addition or replacement of Limitorque grease was not valid.
i' All unit 2 operators have been inspected and it has been verified that they have been properly greased. There was no indication,that foreman had canceled or deleted corrective action. The concern related to general foreman signing off MRs before-work completion is valid (i.e.), conduit covers apparently removed to facilitate
[- operator inspection for adequate grease were not replaced before MR sign-off as required.
I This is a sa'fety-related concern. Corrective action related to maintenance training, following procedures, and accountability is a -
goal of the Nuclear Performance Plan. For example, the Electrical i Maintenance supervisor has taken disciplinary action when it could be proven that a document was improperly signed off. This portion of the concern is valid and safety-related. Immediate corrective action has been implemented, and program enhancements are consistent with the i Nuclear Performance Plan. The portion of this concern related to I traceability of QA parts is valid and safety-related. Corrective
. action in the form of procedure change, issuance of EMSIL-E48, and immediate corrective action associated with the toolroom storage of l CSSC parts has been implemented. The recommended NSRS evaluation to
- determine impact is complete and is being submitted to PORC.
i IV. Root Cause A. IN-86-073-002: Misinterpretation of the requirements for using vendor drawings in the field.
B. IN-86-315-002: Concern not validated.
C. IN-86-110-001: Concern not validated.
4 D.* SQP-85-004-006: Inadequate training and lack of maintenance management j
and craft conununication in the area of procedure requirements.
1 E. JAN-86-001: Communication problem, CI no longer has a concern.
F. I-86-233-SQN: Concern not validated.
l G. JLH-86-001: Inadequate training of Cognizant General Foreman relative to all work being complete before Maintenance Request final I sign-off.
l V. Generic Applicability A. IN-86-073-002: Concern applicable to WBN, BFN and BLN q B. SQP-85-004-006: Concern applicable to WBN, BFN and BLN j Page 10 of 13
a, Revision 2 VI. References
- 1. SI 114.1, revision 6. "ASME Section XI Inservice Inspection Program
-unit 1"
- 2. AI-25, revision 15. " Drawing Control after Unit Licensing"
- 3. NQAM Part III, Section 1.1, revision 0, " Document Control"
- 4. SQN Technical Specification Section 6.0,- Administrative Controls" -
- 5. Regulatory Guide 1.33, revision Appendix A" f 6. AI-4, revision 54, " Plant Instructions - Document Control"
?
3 7. MI-5.3, revision'2 " Ice Servicing"
)
j 8. EMSIL A67, revision 1, " Electrical Craft Training Program" l
j 9. SQM 2, " Maintenance Management System," revision 15 i
)C 10. NSRS Report number I-85-738 SQN, " Acceptance of Previously Rejected NDE Items"
- 11. NSRS Report number I-85-455-WBN, " Ice Basket Loading"
- 12. NSRS Report number I-86-165-SQN, " Craftsmen Direted to violate procedures, use tools other than those specified, and use question-
, able QA material
- 13. AI-30, revision 7. " Nuclear Plant method of Operation
- 14. AI-19 (Part IV), revision 13. " Plant Modifications: After j Licensing" b
j 15. AI-15, revision 15. " Torch Cutting, Welding. Open Flame, Grinding and Spark Production Work Permit - Program Area 19 - Fire
[j ,
Protection Manual (Formerly DPM N82FD1)"
a l 16. Fifth Systematic Assessment of Licensee Performance (SALP) Report, transmitted September 17, 1985 (B45 850919 826)
J
) 17. Electrical Maintenance Section Instruction Letter EMSIL-E48, revision 0, " Storage and Handling of General Purpose QA Parts" a
k 1 u
j Page 11 of 13 lt a
a Revision 2 VII. Immediate or Long-Term Corrective Action (CATD 30804 SQN-01)
SQN has'provided the following response to this evaluation.
A. IN-86-073-002 Per the conclusions of this report, "this problem has been adequately documented, corrected, and a new program is in effect."
B. IN-86-315-002 The verification of the WR associated with the NOI SQ-189 re-examination is complete and the issue is resolved. The required revisions to SI-114.1 and .2 to address 1) NDE record changes and
- 2) NDE procedure revisions are complete and PORC-approved C. IN-86-110-001 Per conclusions of this report, this concern is not valid.
D. SQP-85-004-006 )
The actual concern related to electrical craft being instructed to deviate from procedure MI-10.37 has been corrected. The SQN maintenance sections have made substantial progress and significant changes to improve performance in associated problem areas (examples of such are identified in the element report).
Continuing corrective action for this problem area is in progress and is a goal of the new TVA Nuclear Performance Plan. Since this is an ongoing type of endeavor without a finite ending, no specific follow-up assignment will be made, but a continued effort will be maintained.
E. JAN-86-001 Per the conclusions portion of this report, this concern is resolved, and the CI no longer has a problem. Since the completion of ECN L5880 has no bearing on the actual concern, the completion of ECN LS880 will not be tracked in accordance with this element report.
F. I-86-233-SQN Per conclusions of this report, this concern is not valid.
Page 12 of 13
?o Revision 2 G. JLH-86-001
- 1. Per conclusions of this report, the Limitorque grease concern is unsubstantiated.
- 2. The item concerning the signing off of MRs incorrectly as complete per this report has been addressed. The long-term corrective action is covered by Concern Number. SQP 004-006, plus the new WR program is in effect.
- 3. The non-QA material and traceability concern has also been addressed. The corrective action necessary to resolve this concern has been completed.
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REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -
28 '.
FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:57-ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02, i LIST OF EMPLOYEE CONCERN INFORMATION ATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30804 PROGRAM DEFICIENCIES, PROCEDURE VIOLATIONS S GENERIC. KEYHORD A H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C
.I NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D lI-86-233-SGN OP 30105 S SQN NNNN. SR AN ANONYMOUS INDIVIDUAL MAILED IN A OP 30804 K-FORM POTENTIAL SAFETY HAZARD ASSOCIATED H
- ITH THE CONDENSATE DEMINERALIZER HAS
} TE EVAPORATOR (CDHE) ON EL 706 0F TH E AUXILLARY BUILDING AT SON. THE OR i IGINAL STAINLESS STEEL PIPING FOR PU
] MPING " BOTTOMS" FROM THE CDHE HAS RE
! MOVED AND REPLACED BY A TEMPORARY RU BBER HOSE. EXTENSIVE MODIFICATIONS
- ARE BEING PERFORMED DVER THE RUBBER
! HOSE. HELDING HOT CHIPS HAVE BEEN O
- BSERVED FALLING ON THE RUBBER HOSE.
l DAMAGE TO OR RUPTURE IN THE HOSE NO ULD RESULT IN POSSIBLE PERSONNEL l
!IN 073-002 OP 30804 H HBN YYYY SR THE MECHANISM EXISTS FOR TECHNICIANS DESIGN CHANGES T50194 REPORT TO VERIFY IF THE VENDOR MANUALS KEP DOCUMENT CONTROL 1 T IN THE SHOP CONTAIN THE LATEST UPD INSTRUMENTATION :
i , ATED DRAHINGS OR SCHEMATICS. USING INSTRUMENT /MEC OUT OF DATE DRAHINGS OR SCHEMATICS C OULD CAUSE THE PLANT INSTRUMENTS TO l- BE PLACED (UNKN0HINGLY) IN AN DUT OF
! CONFIGURATION STATUS. DETAILS KNOH i N TO QTC, HITHHELD TO MAINTAIN CONFI i
i DENTIALITY. CI HAS NO ADDITIONAL IN FORMATION. NUC. POWER CONCERN. UNI
] T 1.
30804 N HBN NNYY I-85-455-HBN SS DURING ICE LOADING, TVA USED JACK HA NONCONFORMANCE lIN-86-110-001 i
T50129 OP K-FORM MMERS TO COMPACT ICE TO ACHIEVE THE CORRECTIVE ACTION !
MINIMUM BASKET HEIGHT REQUIREMENTS. OPERATIONS
- THIS COULD RESULT IN " CHANNELING" O GENERAL F ICE AND ENDANGER CONTAINMENT INTER ,
GRITY DURING A LOCA (LOSS OF COOLANT
- ACCIDENT). CI HAS NO ADDITIONAL IN FORMATION. UNIT #1/NUC POWER CONCER j N.
IIN 315-002 OP 30804 N HBN YYYY SR ENGINEERING DESIGN DRAGS PROBLEMS OF NONCONFORMANCE T50210 REPORT F BEFORE THEY ARE FIXED. TO MAKE TH DESIGN CHANGES i IS POINT CLEAR, CI STATED THAT WHEN HAIVER
] INSPECTION DEPT. ISSUES NOTICE OF I GENERAL
! HDICATIONS OR MAINTENANCE REQUESTS (
l NOI'S & HR'S) THAT ENGINEERING HILL ,
DISPOSITION THEM HITHOUT FIXING. CI t STATED THIS AS A GENERIC CONCERN.
i NUCLEAR P0HER CONCERN.
- CI HAS NO FU RTHER INFORMATION.
9 e Q.
m._ _ _ _ _ _ _ _ _ _ _ _ -- _
- . - _ _- --- =s 7w- - -~~~~~~ ~~w-t-;,-7aMw:+ h MM~l'"~ '"
,s' TENNESSEE VALLEY AUTHORITY, 28 ~A REFERENCE - ECPS120J-ECPS121C PAGE -
FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:57.
ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE -~12/02 LIST OF EMPLOYEE CONCERN INFORMATION ATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30804 PROGRAM DEFICIENCIES, PROCEDURE VIOLATIONS S GENERIC KEYWORD A H APPL QTC/NSRS P KEYNORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYNORD D JAN-86-001 OP 30804 N SQN NNNN SS PHONE CALL RECEIVED ABOUT DHG. BEING K-FORM MARKED UP FOR HP10512 (CLASS 1E FIL ES ID) HITHOUT COMPLETING THE HORK.
JLH-86-001 IH 00000 S SQN YYYY SS (1) MRS HHICH REQUIRE THE ADDITION OP 30804 K-FORM OF GREASE TO LIMITORQUE VALVE OPERAT QA 80519 ORS ARE SIGNED BY A GENERAL FOREMAN AS "NO GREASE NECESSARY"'HHEN, IN FA CT, THE GREASE LEVELS ARE LOH OR NEE DS REPLACING. (2) MRS HHICH THE GE NERAL FOREMAN CONSIDERS UNIMPORTANT ARE SIGNED OFF AS COMPLETE EVEN THOU GH NO HORK HAS PERFORMED. (3) NON-QA MATERIAL IS INSTALLED IN QA'APPLI CATIONS, AND TRACEABILITY IS FALSIFI ED ON THE MR.
SQP-85-004-006 OP 30804 N SQN NNNN I-86-165-SQN SR PROCEDURE MI-10.37 REQUIRES A 0-30 I NONCONFORMANCE T50233 K-FORM N. LB. TORQUE HRENCH BE USED YET CRA CORRECTIVE ACTION FT ARE TOLD TO USE A 0-24 IN. LB. TO GENERAL RQUE HRENCH. CI FEELS CRAFT SHOULD GENERAL NOT BE ASKED TO VIOLATE A PROCEDURE.
NUCLEAR P0HER CONCERN. CI HAS NO FURTHER INFORMATION. NO FOLLOH UP R EQUIRED.
7 CONCERNS FOR CATEGORY OP SUBCATEGORY 30804 k
i '!
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