ML20207P608
| ML20207P608 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/06/1987 |
| From: | Hutzler C, Stewart D, Wiley M TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P454 | List: |
| References | |
| MC-40201-SQN, MC-40201-SQN-R03, MC-40201-SQN-R3, NUDOCS 8701160310 | |
| Download: ML20207P608 (9) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAN REPORT TYPE: Sequoys.h Nuclear Plant - Element REVISION NUMBER: 3 (Final)
TITLE: Instruments, Material. Equipment PAGE 1 0F 8 as it Relates to Purchasing and Requisitions REASON FOR REVISION:
Revision 1: Revised to incorporate conunents from the Technical Assistance Staff (TAS) and the Senior Review Panel (SRP).
Revision 2: Revised to incorporate comments from TAS and SRP.
Revistor. 3: Revised to include corrective action, make minor editoral changes, and add Attachment A.
PREPARATION PREPARED BY:
12-ll"8b SIGNX58RE DATE REVIEWS PEER:
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'DATE' TAS:
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{/ii SIGNATURE DATE CONCURRENCES
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ff), l~h'Y N/A on: ECSP MANA(IER DATE MANAGER OF NUCLEAR POWER DATE ggQ CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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O TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 2 0F 8 I. INTRODUCTION There were four concerns (EX-85-181-001, IN-85-463-008 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 IN-85-463-008. IN-85-463-007, and IN-85-964-003 at SQN.
II.
SUMMARY
OF PERCEIVED PROBLEMS Two issues were identified from these concerns. An investigation IR3 was conducted to assess:
- 1. The adequacy of drawing revisions to reflect changes for the lR3 substituted / replaced equipment or material transferred.
- 2. The adequacy of documentation and drawing generation / revision lR3 for the transfer of unit 2, pressure differential transmitters 2-PDT-30-42, a'. A4, and 45 to SQN from WBN.
III. EVALUATION METHODOLOGY A. Reviewed expurgated files to determine if additional information existed for applicable equipment and material transferred between TVA facilities, units, or systems.
l B. Determined if concerns had been previously evaluated and reports '
l issued.
I C. Reviewed the following documents / procedures l 1. Purchase requisitions l 2. Requests for shipment of material
- 3. Shipping tickets / orders
- 4. Power storeroom requisition orders
- 5. Materials receipt inspection reports
- 6. Receiving reports l 7. Statements of certification
- 8. Quality release reports
- 10. Changes of contracts
- 11. Surveillance Report No. 3-86-5-002
- 12. Corrective Action Report SQ-CAR-86-04-023
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 3 OF 8 III. EVALUATION METHODOLOGY (continued)
C. Reviewed the following documents / procedures: (continued)
SQA45 Revision 21, " Quality Control for Materials, Parts and Services SQA134. Revision 7 " Critical Structures. Systems, and Components (CSSC) List" SQA159, Revision 1. " Standards and Guides for Quality Assurance Level III Items" SQA160, Revision 3, " Material Which May Come In Contact With Reactor Coolant" 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 Order" AI-ll, Revision 35, " Receipt Inspection Non-Conforming Items, QA Level / Descriptions Changes and Substitutions" AI-19, Part III, Revision 23 " Plant Modifications:
Modification Requests" 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, IN-85-463-007, and IN-85-964-003 to determine adequacy of findings and conclusions.
E. Interviewed knowledgable individuals from Maintenance, Design 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 elemunt report.
- TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 4 0F 8 IV.
SUMMARY
OF FINDINGS Lettered findings correspond to lettered evaluation methodologies.
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 resolved to the satisfaction of the concerned individual and is no longer a concern.
Purchase Requisition 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 EK-85-181-001. GCTF investigation report was found for concerns IN-85-463-007, 008, and IN-85-964-003.
C. Reviewed SQN documentation and procedures listed in section III C of this element report and found that all the procedures in section III C were complied with and documentation was properly generated 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), ,
Quality Control for Materials, Parts and Services, which governs i 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 I originator as the person responsible for specifying quality I assurance (QA) requirements for the purchase. The Standard l Practice requires the originator to specify several characteristics including component ID number, system number, exact location or ;
function, piping class, vendor style, vendor part of vendor drawing j number, size, and design, 10 CFR Part 21 applicability, QA level, j Environmental Qualification (EQ) applicability, and Certification of Conformance documentation.
The current procedure (SQA45, Revision 21) requires a review of the l 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 l guidance is given by references to SQA134, 159, 160, 161, and 162 l for determining original specifications.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN
.SPECIAL PROGRAM REVISION NUMBER: 3
- PAGE 5 0F 8 d
IV.
SUMMARY
OF FINDINGS (continued)
For borrowed or transferred equipment, SQA45 requires that a Transfer Request be initiated in accordance with the requirements for a Purchase Request. Emergency Purchase Requests must also follow these requirements.
SQA45 was revised on November 21, 1985 (Revision 18), to provide for
, proper handling of equipment and documentation covered by 10 CFR 50.49. Multiple references in SQA45 direct a purchase originator to SQA161,." Purchase of 10CFR50.49 Equipment." SQA161 defines the overlapping ^ responsibilities of the originator, the Materials Unit, and the EQ Coordinator.
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 is required to forward the vendor information to the Supervisor, Drawing and Vendor Manuals Unit for approval and inclusion into the appropriate control system. A copy of the shipping ticket is to accompany the vendor information as a covershoet.
Reviewed Administrative Instruction AI-11. Receipt Inspection, Revision 35, Section 6, and found that it provides guidance for cond'2cting receipt inspection of transferred materials and equipment. Section 8 provides instructions for upgrading QA lovels 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 Maintenance Instruction MI-6.21 for parts borrowed or transferred for CSSC application. SQM 2 specifies that borrowed parts must meet SQA45 standards if being used on another system (difference class).
Appendix C of SQM 2 requires that the planners (Maintenance) ensure that no modifications are involved. Planners require a Design Change Request (DCR) or Field Change Request (FCR) whenever a
- drawing revision is necessary.
1 A transfer may be initiated by a DCR directly or a Maintenance Request-Design Change Request (MR-DCR). AI-19, Parts III and IV, controls the processing of transfers. The DCR/FCR is often used to update drawings for simple changes. Conversations with onsite
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAN REVISION NUNBER: 3 PAGE 6 0F 8 IV.
SUMMARY
OF FINDINGS (continued) design support engineers verified that they routinely receive DCRs/FCRs.that update the instrument tabulations (TVA 47B601 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 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 programmatic deficiencies. As a result, Corrective Action Report (CAR)
SQ-CAR-86-04-023 for missing documentation (Watts Bar receipt inspectior, reports, contracts, vendor documentation, and certifications), was issued to ensure that resolution of the deficiencies is tracked and closed out.
E. During interviews with knowledgeable individuals from Maintenance, Design Support, Power Stores, 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, documentation, or drawing revision updates being incorrect except for deviations relative to documentation received during receipt inspection identified in SQ-CAR-86-04-023 sbove. The corrective action report also requires corrective action to prevent reccurrences. All who wore interviewed were aware of the procedures for the correct '
preparation and implementation according to the appropriate procedures as previously listed in sections III C.
V. CONCLUSIONS Numbered conclusions correspond to numbered perceived problems. lR3
- 1. Provisions are made in the Maintenance Management and Design Change IR3 systems for drawing updates. Interviews with knowledgeable individuals indicate that drawings are routinely 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 whether an MR requires a DCR or FCR. Therefore, the recommendation in the GCTF Investigation Report,Section V, does not require implementation. The perceived problem of inadequate documentation to reflect changes for substituted / replaced equipment or material transferred is not valid. IR3 l
. TVA EMPLOYEE CONCERNS REPORT NUMBER: NC-40201-SQN SPECIAL PROGRAN
, REVISION NUMBER: 3 PAGE 7 OF 8
- 2. Documentation generation and drawing revisions were found to be IR3 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 documentation and drawing revisions for the transfer of 2-PDT-30-42, 43, 44, and 45 to SQN from WBN is not valid.
Although the perceived problems were determined not to be valid, l an associated issue requiring corrective action was identified. l As a result of the GCTF investigation and report, lR3 CAR SQ-CAR-86-04-023 was' issued for missing documentation for i material transferred to SQN. This CAR must be completed to I correct documentation discrepancies. [ Reference Corrective Action l Document (CATD) Number 40201-SQN-01]. l VI. ROOT CAUSE Not applicable with respect to the perceived problems.. Problems not IR3 validated / substantiated. l With respect to the associated issue, the root cause was failure to lR3 follow procedure. I VII. CORRECTIVE ACTION One side issue was identified at SQN as a result of the SQN GCTF l evaluation. The SQN QA staff, as a result of the SQN GCTF report, I reviewed documentation for equipment transfers and found that l documentation for some transfers was missing. A complete review lR3 l was initiated and more documentation was found to be missing. This I j
was documented on Corrective Action Report, SQ-CAR-86-04-023. l The SQN corrective action plan for this issue is as follows: 'l
- 1. All unresolved items are required to be completed prior to l l
closing the corrective action. This will be accomplished by l obtaining the documentation required by the transfer document. lR3 or performing an evaluation to ensure the integrity of the l plant has been maintained. I
- 2. SQA 45 was revised to disallow transfer of any QA level material l that cannot be positively traced to its original procurement lR3 document, and l
- 3. Any Transfer Requisition for which documentation cannot be obtained I will have a Nonconformance Investigation (NCI) issued in IR3 accordance with AI-11. I i lR3
Reference:
CATD Number 40201-SQN-01 I
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 8 0F 8 VIII. GENERIC APPLICABILITY None IX. ATTACHMENTS Attachment A: Listing of concerns indicating relationship to Nuclear l Safety and Generic Applicability. lR3 9
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201'SQN.
SPECIAL PROGRAM -
REVISION NUMBER: 3 PAGE 1 OF 2 ATTACHMENT A .
LIST OF CONCERNS INDICATING SAFETY REALTIONSHIP AND GENERIC APPLICABILITY CATEGORY: MC ADEQUACY OF MATERIAL ELEMENT: 40201 PURCHASING REQUISITIONING f
GENERIC l
APPLICABLE QTC/NSRS P#
! CONCERN SUB PLT B B S W INVESTIGATION S 4
NUMBER CAT CAT LOC F L Q B REPORT R CONCERN DESCRIPTION i
! EX-85-181-001 MC 402 WBN N Y Y Y SR On valve inspections (Test 70), QC verifies the i T50225 proper valve by the mark number tag which is
' Note: Only the underlined installed by the warehouse or vendor and is often portion of this concern is just a paper or metal tag which can be removed or applicable to this element replaced by anyone. If the valve has been report. substituted from what the drawing lists, the bill
- of materials does not properly reflect the
! change. No paperwork is provided to Watts Bar Engineering to document that it is an acceptable replacement. Many substitutes have come in from Hartsville. Phipps Bend. Yellow Creek and are a different type than what the drawing calls for.
! Check unit 2 Steam Generator Blowdown System as an example. Construction Department concern. CI has no additional information.
l IN-85-463-007 MC 402 WBN N N Y N I-85-172-WBN SS Instruments dedicated for a particular unit or
. T50036 system are frequently sent to another unit, I
system or even plant, i.e., Watts Bar to Sequoyah. The drawings and other applicable I
1 documentation is not revised for months if ever.
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REPORT NUMBER: NC-40201-SQN TVA ENPIhYRE CONCERNS ..
' SPECIAL PROGRAN .
REVISION NUMBER: 3 -
PAGE 2 0F 2 ATTACHNENT A LIST OF CONCERNS INDICATING SAFETY REALTIONSHIP AND GENERIC APPLICABILITY CATEGORY: NC ADEQUACY OF Nf.TERIAL ELENENT: 40201 PURCHASING REQUISITIONING
! GENERIC
) APPLICABLE QTC/NSRS P#
1 CONCERN SUB PLT B B S U INVESTIGATION S NUMBER CAT CAT Ihc F L 0 B REPORT R CONCERN DESCRIPTION IN-85-453-008 NC 402 WBN N N Y Y SS Unit 2. System 30. TVA identifiers: 2-PDT-30-42; j
1 T50036 2-PDT-30-43; 2-PDT-30-44; 2-PDT-30-45. These
! instruments transmitters (Westinghouse) were sent l
to Sequoyah and documentation generated to i reflect this (including drawings) have not been done, l
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IN-85-964-003 NC 402 WBN N N Y Y I-85-720-WBN SS Naterial/Equipseent is ordered dedicated to a
, T50177 specific system, unit, etc., but is frequently i installed /used elsewhere and it is unknown if documentation is revised to reflect this cannibalization. CI has no further information.
- PSR Codes:
i SR - Nuclear Safety-Related SS - Nuclear Safety Significant NO - Not Nuclear Safety-Related i .
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