ML20207P600
| ML20207P600 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/06/1987 |
| From: | Gunnels R, Murphy M, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P454 | List: |
| References | |
| 308.02-SQN, 308.02-SQN-R05, 308.02-SQN-R5, NUDOCS 8701160295 | |
| Download: ML20207P600 (8) | |
Text
5 TVA EMPLOYEE CONCERNS REPORT NUMBER: 308.02-SQN SPECIAL PROGRAM a
REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 5 TITLE: Preventive Maintenance REASON FOR REVISION:
To incorporate SRP and TAS comments. Revision 1 To incorporate additional SRP comments. Revision 2 To incorporate additional SRP comments. Revision 3 To incorporate SQN corrective action response Revision 4 To incorporate adcitional SRP comments Revision 5 PREPARATION PREPARED BY:
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APPROVED BY-i bh*h? N/A DATE ECSP MANAGER DATE MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY) l l *SRP Secretary's signature denotes SRP concurrences are in files, 1781T 8701160295 87010T PDR ADOCK 05000327 P PDR _ - ,
TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Maintenance Element: Preventive Maintenance Report Number: 308.02-SQN Revision 5 IN-86-316-X09 l
l Evaluator: WitM /2//4[d Richard Gunn s Date Reviewed by: /W A/> /Z!/7/f6
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6PS CE @ e er 'Datie Approved by: M - / /8/8[
W. R. Lagergren Date 1
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Rsvisien 5 I. PREVENTIVE MAINTENANCE This report evaluated one concern regarding engineering disregard towsed the use of vendor manuals in the Preventive Maintenance Program at Sequoyah Nuclear Plant (SQN).
II. SPECIFIC EVALUATION METHODOLOGY One concern was included in the element evaluation report.
Concern Number IN-86-316-XO9 states: "TVA cannot have a safe and adeguate Preventive Naintenance Program if engineering continues to disregard the vendor's manual for safety-related equipment."
The interface issue concerning Vendor Nanual Control between Tennessee Valley Authority (TVA) and Vendors, as addressed by Nuclear Regulatory Commission (NRC) Generic Letter 83-28, was not evaluated as a part of this concern. The issues of NRC Generic Letter 83-28 are being addressed by TVA Corporate commitments. Vendor manual use was evaluated from corporate program procedures down to the implementing preventive maintenance procedures to deternita if engineers had
! disregarded the use of vendor manuals in the performance of preventive 1 maintenance activities.
Engineers from the Division of Quality Assurance (DQA), Nuclear Engineering (DNE), maintenance, and craft personnel were interviewed.
In addition, document research, procedure reviews, and comparison to regulatory requirements were conducted.
This concern was previously evaluated by Generic Concern Task Force (GCTF) report " Vendor Manual Control and Use," dated June 3, 1986, and a report was issued which contained their findings.
The above referenced GCTF report was reviewed to determine whether the l evaluation conclusively established the validity of the concern, and l
j verify that the report information was current. ,
NRC Generic Letter 83-28 dated July 8, 1983, " Required Actions Based on Generic Implications of Salem ATWS Events," was reviewed.
l III, FINDINGS Previous to the issuing of Generic Letter 83-28 by the NRC, (as noted above in section II) TVA did not have a uniform Vendor Nanual Control Program. This lack of program control led to problems with processing l
Vendor manual revisions at DNE. The site Vendor Manual Control Units
' could not be assured of receiving the latest revisions to vendor manuals to be incorporated into their control copies in a timely manner.
However, there were no identified instances where engineers had disregarded the use of vendor manuals during this timeframe. This Page 1 of 6
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R: vision 5 problem has since.been corrected at the corporate level by the issuing of Part V, Section 6.2, " Vendor Manual Control" to the Nuclear Quality Assurance Manual (NQAN). However, problems still exist in the implementation of Generic Letter 83-28 commitments, and these are documented in Corrective Action Report (CAR) SQ-86-01-004, and Institute of Nuclear Power Operations (INPO) reports dated February 1984 and April 19b5.
Administrative Instruction (AI)-23, was revised to, address Environmental Qualification (EQ) application of Vendor Manual and to implement a control program to be in line with Generic Letter 83-28.
AI-23, " Vendor Manual Control," was reviewed to determine the requirements for the use of vendor manuals. The scope of the instruction applies to activities affecting Critical Systems Structures and Components (CSSC) and 10 CFR 50.49 equipment for SQN. The responsibilities, vendor manual control, and requirements of vendor manuals were found to be clear and concise as written in the
! procedure. The effort to control and validate vendor manuals is in progress at this time.
A review of standard practice SQN57, " Preventive Naintenance Program,"
was made to determine the requirements and use of vendor manuals for the l Preventive Maintenance Program. It was found that reference was made I . to the use of vendor manuals or 10 CFR 50.49 Environmental Qualification (EQ) Binders.
An interview with a cognizant engineer from the Preventive Maintenance QA Staff was conducted about problems with the Preventive Maintenance Program. The cognizant engineer stated that the Preventive Naintenance '
- Program needed completo procedure reviews, that the Preventive r Maintenance Instructions were un'elear as written, and more detail was f needed to ensure all information necessary to perform the work 1- activities was included. A review of NMRG Naintenance Review, " Exit Noeting at Sequoyah Nuclear Plant," dated July.29, 1986, was conducted and found to be in agreement with the cognizant engineer's statement.
A review and evaluation was conducted on 15 preventive maintenance j
instructions (PNs) on CSSC equipment. Note the sample of 15 PNs was not intended to produce statistically correct projections of trends in the parameters sampled, but it was sufficient to identify the existence of problems. The PNs were reviewed to verify that requirements as stated in the source docuponts (vendor manuals, FSAR, and instruction manuals) were implemented into the PN instructions. All requirements were met, and no discrepancies were found.
Interviews were conducted with DQA engineers, DNE engineers EQ Engineers, Maintenance Section engineers, and Maintenance Section craft personnel. During the interview, cognizant individuals were asked if they had any knowledge of engineer (s) that disregarded the use of vendor manuals in the performance of preventive maintenance activities l
on CSSC equipment. They all replied, "no, not to their knowledge."
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R3visien 5 A review and evaluation of the GCTF report was conducted. The' findings of this report.were found to be correct and in full agreement with this evaluation. Follow-up evaluation of the recommendations of GCTF ;
report found that:
- 1. AI-23, should be revised to require stickers to be placed on certified vendor manuals by Vendor Manual Control stating, " Drawings
.for Info Only."~ The evaluator verified that AI-23, was revised and incorporated the requirement that stickers-stating, " Drawings for Info Only," will be placed on certified manuals by Vendor Manual Control.
- 2. "AI-19 and SQM2 should be revised to add a statement that vendor manuals be used, where applicable, when writing Workplans and Maintenance Requests on CSSC equipment." The evaluator verified
- - that AI-19, was revised and incorporated the use of vendor manuals.
However, SQM2 was reviewed and no statement referenced the use of vendor manuals.
NOTE: Corrective Action Tracking Document CATD-30802-SQN-02, SQN I Corrective Action Response, SQM1, Sequoyah Nuclear Plant lRS Maintenance Program adequately addresses the use of vendor l manuals and meets the recommendation of the GCTF report. l
- 3. As recommended, implementing all~ changes to the Vendor Manual Program for NRC Generic Letter 83-28 should be completed before the March 1988 due date. The implementation of a Vendor Manual Control Program is currently in development by DNE.
Conclusions Concern IN-86-316-X09 was not valid. The PMs reviewed showed no discrepancies in implementing the vendor manual control requirements of AI-23 and SQM57. Interviews with cognizant engineers and craft personnel found that to their knowledge no engineer (s) disregarded the i use of vendor manuals in the performance of preventive maintenance activities. GCTF report found that " problems with engineers not using
- vendor manuals was not validated based on interviews with maintenance and modification craftworkers." This evaluation is in agreement lRS with GCTF report findings except for item 2 of the above findings. l However, problems with the Vendor Manual Program previously identified by QA, in CAR SQ-86-01-004, are still open. Efforts to incorporate requirements of NRC Generic Letter 83-28 into procedures are in progress at this time.
l-The identified problems with the Vendor Manual Control Program prior I to the revision of AI-23 had the potential to be safety-related in l 'the performance of preventive maintenance on CSSC equipment. However, i the review and evalution of 15 preventive maintenance instructions on CSSC equipment, found that the requirements from the vendor manuals had been incorporated into those preventive maintenance instructions.
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RAvisicn 5 IV. ROOT CAUSE Based on the findings that concern IN-86-316-X09 was not valid, there is no root cause.
V. GENERIC APPLICABILITY Concern IN-86-316-X09 is generic to all TVA nuclear sites because of the TVA-wide use of vendor manuals.
VI. REFERENCES
- 1. 10 CFR 50.49-1985
- 2. SQA-174, 10 CFR 50.49, " List and Environmental Qualification Binder Control," Revision 0, dated November 18, 1985
- 3. FSAR, Sections 11.2.4, 11,3.4
- 4. NRC - Generic Letter 83-28, Section 2.2, " Equipment Classification and Vendor Interf ace" (Progre.ms for all safety-related components) dated July 8, 1983
- 5. NQAM, Part 1. Section 6.2, " Vendor Manual Control," Revision 0 dated June 18, 1986
- 6. AI-23, " Vendor Manual Control " Revision 22, dated July 30, 1986
- 7. Area Plan 1707.03.04, " Vendor Marual Program," dated December 21, 1984
- 8. SQM57, Preventive Maintenance Program, Revision 5, dated February 25, 1986
- 9. NMRG Maintenance Review, " Exit Meeting at Sequoyah Nuclear Plant" dated July 29, 1986, S53-860805-256 e
- 12. Corrective Action Report (CAR) Number SQ-CAR-86-01-004, dated January 30, 1986
- 13. NSRS Report I-85-788-WBN dated December 18, 1985
- 14. Generic Concern Task Force (GCTF) Employee Concern Numbers IN-86-073-001, IN-86-073-002, IN-86-316-X09, " Vendor Manual Control and Use," Revision 1 dated June 3, 1986 Page 4 of 6
. Rsvisien 5
- 15. The following listed Preventive Maintenance (PMs), and Instruction Source Documents (Vendor Manuals) on CSSC equipment,
- a. PM number 1477-032, Revision 1. " Auxiliary Control Air Prefilter B-B Operation Maintenance Manual Contract 74C35-83630-1"
- b. PM number 1588-062 Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge, PMP Westinghouse Letter, TVA-85-065 " Dated April 4, 1985
- c. PM number 1589-062 Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge PHP Westinghouse Letter, TVA-85-065," dated April 4, 1985
- d. PM number 1590-062, Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge, PHP 1-PHP-062-108 SPD, INCR. Westinghouse Letter, TVA-85-065," dated Apell 4, 1985
- e. PM number 1591-062, Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge, PHP 2-PHP-062-108 SPD. INCR. Westinghouse Letter, TVA-85-065," dated April 4, 1985
- k. PM number 1640-001, Revision 0, " Auxiliary Feedwater Pump Turbine, 1-TRB-001-0017" Vendor Manual Contract Number 92610"
- 1. PM number 1640-001, Revision 0, " Auxiliary Feedwater Pump Turbine, 2-TRB-001-0017" Vendor Manual Contract Number 92610"
- m. PM number 1642-032, Revision 0, " Auxiliary Control Air After Cooler A-A Ingersoll-Rand Instruction Manual-Contract Number 73C31-83582"
- n. PM number 1643-032, Revision 0, " Auxiliary Control Air After Cooler A-A Ingersoll-Rand Instruction Manual-Contract Number 73C31-83582" Page 5 of 6 f
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- Rsvisicn 5
- o. PN number 1633-043 Revision 0, "RCS Hot Legs HDR. CNTNT Isolation Valve 1-FCV-043-0022" Instruction Source Document PRO 1-85-249
- 16. AI-25. Revision 15. " Drawing Control After Unit Licensing" (Part I)
- 17. AI-19 Revision 18. " Plant Nodifications After Licensing," approved July 7, 1986
- 18. SQN2, Revision 19. " Standard Practice Maintenance Nanagement System" VII. IMMEDIATE AND LONG-TERN CORRECTIVE ACTION SQN Corrective Action Response is as follows:
s
- 1. CATD-30802-SQN-01 The issues identified in the ECTG report 308.02 SQN concerning problems with PN instructions should be resolved when the NMRG findings are resolved. Since the enhancement plan has not been developed and a final is not available, the CAP for this report should be to adequately resolve NMRG findings A-3, E-1, E-3 E-5 and F-2 which will also satisfy problems identified in this report.
- 2. CATD-30802-SQN-02 A revision to SQN2 to include a statement on the use of vendor. manuals for WR work instructions is not needed, SQN1, Sequoyah Nuclear Plant Naintenance Program, appendix C gives guidelines for determining when WR work instructions are appropriate and when PORC reviewed instructions are needed for CSSC maintenance activities. As indicated in SQM-1 appendix C, whenever step by step instructions from a vendor mar.ual is needed for CSSC work that is not within the skill of the craft, a PORC reviewed insicuction is required.
l 3. CATD-30802-SQN-03 ,
A Quality Notice is being prepared to replace IDQAP6.2 which will
!. define the vendor manual program for SQN. This Quality Notice is l on the DQA restart list. Procedures AI-23 and SQEP39 will be i revised to reflect the requirements in the Quality Notice before restart. A program plan is being developed to identify pre-restart and post-restart scope and implementation schedules.
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