ML20212F275
| ML20212F275 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/23/1987 |
| From: | Haines E, Leslie J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20212F190 | List: |
| References | |
| 206.1(B), 206.1(B)-R01, 206.1(B)-R1, NUDOCS 8703050056 | |
| Download: ML20212F275 (29) | |
Text
o TVA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)
SPECIAL PROGRAM
~
REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER:
1 f
TITLE:
AS-BUILT RECONCILIATION As-Built Inaccuracies PAGE 1 0F 27 REASON FOR REVISION:
1.
Revised to incorporate SRP, TAS, and TVA Engineering comunents; to add chronology; to incorporate additional information supplied by TVA; and to add Section 10, Corrective Action.
PREPARATION lL
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" SIGNATURE DATE CONCURRENCES
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23/87 SIGNATURE DATE
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DATE APPROVED BY kh I'Vl T MANAGER Of NUCLEAR P0HER DATE D
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CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in flies.
0703050036 070226 PDR ADOCK 05000327 Y
TVA EMPLOYEE CONCERNS REPORT NUMBERS 206.1 (8)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 27
[
1.
CHARACTERIZATION OF ISSUE (Sh Issues:
Concerns:
In many instances, the as-built a.
XX-85-070-003 documents and drawings are "Sequoyah: Work plans contain nonexistent, are in poor condition, inaccurate data. Majorityof the DCR's taken care [of] but not contain many errors, and are documented right and drawings not a true representation of do not reflect the as-built installation.
conditions. Details withheld to maintain confidentiality.
b.
There is inadequate management of Nuc Power concern. C/I has no configuration control procedures covering plant change documentation further information."
'(FCRs, DCRs, etc.), and inconsistent control over plant chnge practices IN-85-152-001 resulting in unapproved plant changes
" Interviewee expressed concern that certain drawings (perhaps and. improper documentation.
as-built drawings) might not Changes are made to the plant be up-to-date because they had configuration often by FCRs, and c.
not been ' checked'. Inter-viewee had mentioned this to drawings are not changed in a timely
[e*
another person (but not to his manner.
\\ *'
supervisor) and was told that The ERCH piping is being changed drawings do not require d.
from carbon steel to stainless
' checking' until they are steel in a piecemeal fashion, and approved (' signed off').
all installed piping changes may not Many drawings are not have been stress analyzed.
' approved' although the a
hardware is already installed."
Certain drawings (perhaps as-built e.
drawings) might not be up-to-date XX-85-070-001 because they had not been checked.
"Sequoyah: Units 1 & 2 numerous documents contain a high percent of errors and drawings do not reflect the The following issues from these installations in many instances.
concerns are addressed in other (Names / Dept./ Details to the reports as indicated, specific case are known to QTC and withheld to maintain Issues indicated with an asterisk (*)
confidentiality). CI has no were developed from notes generated further information. Nuclear by the evaluation team during review Power Dept. concern."
of the expurgated file for I-85-128-NPS.
HI-85-100-045 "As-built drawings and documents Hork plans contain inaccurate data are nonexistent or in poor (addressed in Sequoyah Element Report condition in many cases. CI has no further information.
204.6).
Anonymous concern via letter."
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SPECIAL PROGRAM 4
REVISION NUMBER:
1 PAGE 3 0F 27 I
Basic calculations are not prepared XX-85-077-002 (addressed in Sequoyah Element Report "Sequoyah - Unit 1 & 2: Numerous 205.1)*.
design drawings are inaccurate and do not reflect as tuilt Basic calculations are not documented condition. Several FCR's were written but not reflected (addressed in Sequoyah Element on the design drawings. CI has Report 205.1)*.
no further information. Con-struction Department concern."
Design documents are not supported by calculations (addressed in Sequoyah Element Report 205.1)*.
XX-85-062-003 "Sequoyah, Browns Ferry: CI was There are no procedures to control unofficially informed that the and maintain calculations current drawings, in many instances,
- (addressed in Sequoyah Element are not a true representation t
of the installation. Nuclear Report 205.2)*.
[
Power concern. CI has no further Scope of engineering required for information."
modifications is not identified (addressed in Sequoyah Element I-85-128-NPS "An individual from BFN wrote Report 204.11)*.
- 3 NSRS expressing his concern that No attempt is made to identify the control and quality of OE's
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design effort is inadequate.
design activities for modifica-P'
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tions (addressed in Sequoyah Element The CI sent several roughly y,
written pages detailing and Report 204.11)*.
summarizing his evaluation and conclusion of three major areas:
(1) Design Calculations q"
(2) NCR's, and (3) Management Policies."
HI-85-094-N02 "The as-built condition of the plant does not match the design drawings.
"The ERCH is having its carbon steel piping changed to stainless r
steel, the work has been divided into many workplans which are being installed piecemeal at various outages. There is a good chance that Sequoyah has been operating the plant in an unanalyzed condition since it is doubtful that the stress analyst has analyzed all piping config d urations that have been installe during operation."
(
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 27
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YES X NO _
- 2. }@VE ISSUE (S) EEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALY o
Identified by TVA NSRS Date 03/03/86 TVA SNP - Nuclear Safety Review Staff (NSRS) Investigation Report No. I-85-637-SQN, Work Plan Processina Identified by TVA SON GCTF o
Date Circa 12/85 - 01/86 TVA SNP - Generic Concern Task Force Report GCC-09-55, Ccnfiauration Control l
o Identifled by TVA NSRS I
Date 03/07/86 p,
TVA 'SNP - Nuclear Safety Review Staff Investigation Report I-85-473-NPS, Confiauration Control at SON. BFN. and OE i
Identified by Gilbert / Commonwealth. Inc._
o Date 10/85 GIIbert/ Commonwealth, Inc. Report No. 2600, Assessment of the Desian Control Proaram for the Seauovah Nuclear Plant DOCUMMI._liOS.. TAG NOS.. LOCATI0t[S. OR OTHER SPECIF 3.
IDENTIFICAIID![S STATED IN ELEMENT <
raw cooling water (ERCH) piping system.
Essential i
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE S OF 27
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4.
INTERVIEN FILES REVIEHED:
Expurgated files for XX-85-070, IN-85-152. HI-85-100, XX-85-077, XX-85-062, and HI-85-094 were examined, and no additional unreviewed information was found.
The expurgated file for I-85-128 was examined by the evaluation team; notes were taken and the issues were identified.
5.
DOCUMENTS REVIENED RELATED TO THE ELEMENT:
See Appendix A.
6.
WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REOUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
7.
LIST. REQUESTS FOR_Il(EDRMATION. MEETINGS. TELEPHONE CALLS. AND OTHER 7
DISCUSSIONS RELATED TO ELEhERI.1 p
See Appendix A.
8.
EVALUATION PROCESS:
Determined mandatory requirements related to the issues by
,i a.
reviewing documents defining regulatory requirements, mandatory criteria, etc., that apply to operating nuclear power plants and are issued by NRC, recognized professional societies, etc.
b.
Reviewed documents such as OIE Information Notices and INP0 Good Practices publications which provide information on as-built / configuration control practices in the nuclear industry.
Reviewed documents issued by TVA that specify how regulatory c.
requirements will be met at SQN; these included the PSAR, FSAR, QA Topical Report, etc.
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SPECIAL PROGRAM REVISION NUMBER: 1 l
PAGE 6 0F 27 d.
Assessed the magnitude of the issues by reviewing documents that define their severity, including Audit / Inspection l
Reports from TVA QA, INPO, and NRC, as well as TVA meeting notes, reports, logs, memos, letters, and systematic evaluation reports from TVA and non-TVA entities.
Identified methods and practices proposed by TVA to address e.
the issues. This process included review of documents that define plans, methods, procedures, instructions, etc., that are designed to resolve or mitigate the issues to an acceptable level. The investigation of available literature included the Sequoyah Nuclear Performance Plan (SQN NPP), the SQN-Design Baseline and Verification Program (08VP), and other documents pertaining to plant change procedures, transitional change control, system evaluation, configuration control drawings, design change control improvement, etc.
f.
Determined the effectiveness of the procedures and practices
(
l designed to address the issues.
i Discussed the issues and corrective action with cognizant TVA g.
and Sequoyah individuals in Knoxville and at the SQN jobsite.
hil h.
Reviewed available transcripts of NRC investigative interviews for additional information.
4 1.
Assessed the steps TVA has taken to assure that the piping stress calculations performed for ERCH piping reflect the as-built piping during plant operation.
4 9
j.
Investigated the capabilities and methods of producing or revising engineering drawings at the SQN plant.
9.
DISCUSSION. FINDINGS. AND CONCLUSIONS:
Chronology:
09/73 to EN DES Engineering Procedures (EPs).-(Red Books),
06/85:
in effect; supersede SQN-QA Manual 09/80:
Operating license received for SQN Unit 1 09/81:
Operating license received for SQN Unit 2 07/83:
TVA Configuration Control Task Force chartered to investigate configuration control problems at SQN t
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SPECIAL PROGRAM REVISION NLMBER:
1 PAGE 7 0F 27
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Institute of Nuclear Power Operations (INPO) audit 02/84:
of SQN finds plant drawings not current TVA receives Employee Concern IN-85-152-001 05/85:
Office of Engineering Procedures (OEPs) in effect; 06/85 to 06/86:
supersede EN DES-EPs TVA receives Employee Concern XX-85-070-001 06/85:
08/85:
SQN voluntarily shut down by TVA TVA receives Employee concerns XX-85-070-003 and 08/85 XX-85-062-003 SQN Project Manual issued (SQEPs and SQEP-AIs) 09/85:
[
Gilbert / Commonwealth. Inc. report No. 2600 on 10/85:
design control at SQN cites deficient configuration control TVA receives Employee Concern HI-85-100-045 11/85:
Gilbert / Commonwealth. Inc. report No. 2614 on SON
('
03/86:
modifications cites inaccessibility of as-constructed drawings for use as design input SQN initiates Design Baseline and Verification 05/86:
ky Program TVA receives Employee Concern I-85-128-NPS L.
06/86:
Sequoyah Nuclear Performance Plan (SQN NPP), R1, 07/86:
issued Nuclear Engineering Procedures (NEPs) in effect; 07/86 to present:
supersede OEPs TVA receives Employee Concern HI-85-094-N02 08/86:
Discussion:
9.1 BACKGROUND
The Sequoyah Plant design was begun in the late 1960s when compliance with regulatory requirements was not required to be well documented. The majority of the SQN licensing i
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 27
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commitments were made in the late 1960s and early 1970s, and some of the present day regulatory documents are not applicable to Sequoyah. Therefore, it is not necessary to update the Sequoyah Plant to include all of the new guidance published by NRC, unless there are specific requirements or commitments to do so.
The employee concerns were originally raised at Hatts Bar Nuclear Plant (HBN).
They were considered generically applicable to Sequoyah Nuclear Plant (SQN) since the organization and procedures that governed SQN design were essentially identical to HBN.
The issues identified in this element refer to programmatic deficiencies in the area'of engineering control of as-built drawings and plant configuration control.
Plant drawings and diagrams are the vehicle by which day-to-day plant operations and maintenance are planned and conducted. They are used, for example, to determine which s
valves must be closed to isolate or bypass an item of equipment for inspection, calibration, adjustment, repair.
removal for replacement, etc. Schematics are used to
[Oc.?
troubleshoot electrical circuitry problems, to investigate malfunction of clectrical equipment, to determine which circuit breakers or switches must be opened to deactivate
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electrical circuits, etc. The use of drawings and diagrams which are not as-built and do not reflect the actual configuration of the plant can result in confusion and loss p
of time, and could result in errors which cause plant 9
shutdown, damage to equipment and other undesirable consequences.
9.2 AS-BUILT DRAHINGS/ PLANT CONFIGURATION CONTROL Issues "a." "b." and ac" Regulatory documentation (App. A, 5.11 and 5.mm) and governing codes and standards (App. A. 5.kk) state that l
procedures must be developed to specify that as-built drawings for safety-related systems and structures be current and be available at all locations where they are needed.
These documents also require periodic inspections or audits of the design, construction, and operational processes to ensure that the procedures are being followed, and that the drawings reflect the current as-built configuration of the plant.
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1 TVA EMPLOYEE CONCERNS REPORT NUMBERI 206.1 (B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 9 0F 27 l
TVA has acknowledged these regulatory requirements, and has stated in the TVA Topical Report (App. A, 5.nn) that safety-related drawings will be maintained in a current In response to these requirements, and as-built condition.
to maintain configuration control, TVA developed engineering procedures (EN DES-EPs, OEPs, and NEPs) to govern the preparation, approval, and tracking of change-authorizing These procedures require that drawings be updated documents.
to reflect the as-built configuration of the plant after a physical change is completed; however, they do not specify a time limit within which as-built drawings must be completed.
In addition to the regulatory requirements above, 10CFR50 Appendix E (App. A, 5.00) requires that the licensee provide an on-site Technical Support Center (TSC) to augment control The regulations also room operations during emergencies.
require a near-site Emergency Operations Facility (EOF) to be NRC guidance on meeting operational during an emergency.
requirements for Emergency Response Capability (ERC) are provided in Supplement I to NUREG-0737 (App. A, 5.tr) which states that the TSC and EOF will be "Provided with accurate, complete and current plant records (drawings, schematic diagrams, etc.) essential for evaluation of plant under NUREG-0737 also references NUREG-0696 t
Y.
accident conditions."
(App. A, 5.ss) which provides guidance criteria by which the NRC will evaluate how the licensee meets the requirements of y
These criteria state that both of these C
the regulations.
facilities shall have ready access to up-to-date plant records which shall include but not be limited to "up to date A
Conditions of drawings, schematics and diagrams showing:
plant structures and systems down to the component level and
~
l plant locations of these systems." The evaluation team in has been advised by TVA personnel that specific SON commitments for meeting the criteria of these documents has been negotiated with the NRC (App. A, 5.yy and zz) and these commitments are tracked by the NRC via its inspection program.
In June 1983 the Configuration Control Task Force (CCTF),
(App. A, 15.h) was initiated to resolve audit findings at In July 1983 the task Browns Ferry Nuclear Plant (BFN).
force was chartered to investigate configuration management throughout TVA nuclear plants, make recommendations for corrective action, and propose programs to prevent recurrence As of Dr. comber 1985, the task of drawing updato problems.
force found that a configuration management program for SQN was still in the investigative modo and no programmatic The task force found that approach was being developed.
configuration control /as-butit problems at TVA nucicar plants 01200 - 02/17/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B) i SPECIAL PROGRAM REVISION NUMBER:
1 i
PAGE 10 0F 27 b
were mostly due to (a) lack of management involvement and lack of emphasis on adhering to in-place procedures, (b) the use of a two drawing system of as-designed and as-constructed drawings, (c) partial implementation of ECNs without updating drawings, and (d) improper handling of the Design Change Request (DCR) process and documents.
As a consequence of NRC inspections, the CCTF investigations, and the NSRS intestigation of employee concerns (see Section 2 of this repora, iVA became increasingly conscious of potential deficiencies in the SON program for controlling plant changes and for maintaining current as-built drawings.
Consequently, part of the efforts of the Employee Concern Task Group (ECTG) was to establish the validity and determine the magnitude of the employee concerns pertaining to as-built / configuration control. Outside entitles were also contracted to independently ascertain the extent and severity
(
In the third quarter 1985, TVA contracted of the problem.
with Gilbert / Commonwealth. Inc. to review the SQN design control program (App. A 5.v).
As a result of NRC concerns about the adequacy of management functions at TVA and at the Sequoyah plant, Sequoyah management policies and programmatic deficiencies were
(', *.
investigated by TVA. Corrective action plans developed by 4
n TVA are reported in the TVA SQN NPP. Among other items, this report addresses plant change control and as-built configuration control (App. A 5.a and 5.b).
The Design Baseline and Verification Program (DBVP) (App. A, 5.g), has been developed and is being implemented as part of the Sequoyah plant restart program. The DBVP requirements include review and evaluation of all design change documents for safety-related systems necessary to mitigate FSAR Chapter 15 accidents; included are those pending implementation when the operating license was issued, and those originated after it was issued.
The DBVP also includes walkdowns of these safety-related systems to ensure that the Control Room Drawings (flow diagrams, control diagrams, and single line drawings) reflect the current as-butit These procen es vill result in a system conditions.
evaluation report (SYSTER) fur the selected safety system.
The report will list activities that must be completed before plant restart.
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To implement the D1VP, engineering and administrative procedures have been written to govern the identification, control, and evaluation of change documents; the production of as-built / configuration controlled drawings; the packaging and controlling of walkdown/ test documentation; and the specific contents, etc., of reporting documents (App. A, 5.1 through 5.u).
These activities are now underway.
The information for this element report was gleaned from documents that describe the problems and concerns and prescribe or indicate corrective actions. Additionally, information was obtained during conversations (App. A, 7.c through 7.h) with cognizant TVA personnel familiar with both the problem and the proposed solutions. Also, in the transcript of the NRC investigative interview, the concerned individual discussed the absence or lack of control of plant change documentation (App. A, 5.bb). A review was made of the Quality Management Staff (QMS) files of QA Audits i
(App. A, 5.cc) performed on Sequoyah Engineering practices, and, except for evidence that documentation deficiencies are present, very little specific as-built drawing information rg was obtained.
~
CE It was also confirmed that the present procedures do not establish a specific time period between the completion of a f'
physical change to the plant and the completion of as-built drawings reflecting that change.
It was stated by TVA Sequoyah personnel that Administrative Instruction AI-19 and
(
Engineering Project Procedure SOEP-30 will be revised in the 9
near term to specify a maximum time limit for the completion of as-built drawings.
Evidence to support this statement can be found in Corrective Action Plan (CAP) for CATO No.
307.13-SQN-02 (App. A, 5.aaa).
Conversations with TVA personnel confirmed that the immediate J
(Phase I) effort to update the as-built drawings pertains to the Control Room Drawings which consist only of flow diagrams, control diagrams, and single line drawings.
They also stated that updating of other drawings to reflect as-built conditions would not be initiated untti after plant restart (Phase II),
t 01200 - 02/17/87
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SPECIAL PROGRAM REVISION NUMBER:
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SON Administrative Instruction on Drawing Control - AI-25 (Ref. App. A. 5.tt) Section 4.0 Definitions provides the following definitions:
"4.6 Critical Drawings - Drawings depicting system features which are used by the plant Technical Support Center and the Chattanooga Emergency Center to determine system operation and function.
The drawings are for use in a radiological emergency to analyze problems and make recommendations for the mitigation of the consequences of an i-accident.
The following types of drawings may be included: Schematics, Electrical Single Lines, Control and Logic, Flow Diagrams, Structural and Equipment Arrangement Drawings.
m s
The Division of Nuclear Services (DNS)
Emergency Preparedness Group is responsible for the maintenance and distribution of the m"
list for these drawings."
"4.14 Primary Drawings - All drawings which are necessary to startup, operate, and shutdown k
the plant. Drawings for both emergency and normal shutdown are to be included. Primary drawings are located in the Unit Control Room and are referred to during daily
).
operation of the plant.
Section 7.0 Cr.l.tical and Primary Drawinas provide the following statements:
"7.2 Select drawings from the listed series shall J
be located in the unit control room. Those not maintained in the control room will be located in the Shift Engineers (SE) office and turbine ASE office. A list of drawings may be obtained from Document Control.
t I
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"7.3 Drawings located in the unit control room, including those deemed necessary to be critical, shall be designated as primary drawings.
"7.4
... Drawings located in the Unit Control room reflect the latest 'As Constructed' status."
9.3 AS-BUILT / CALCULATION CONTROL Issue "d" TVA has stated that there is no guarantee that every past configuration of ERCH piping had a design calculation on file demonstrating the qualification of the piping in such configuration before actually being placed in service (App.
A, 7.e).
TVA has stated that:
"All piping which had been changed or was scheduled to be changed through Unit 2 Cycle 3 outage was indicated on a set of drawings prepared by [the] Plant Modtfications Section. This piping was reviewed by the
(.
Rigorous Analysis section to ensure that all Rigorously analyzed piping which had been changed was adequately 1
cons 1dernd" (App. A, 7.I).
TVA has also stated that "any replacement done after November I
1985 w111 be under our present program which will have the analysis done before the actual pipe replacement" (App. A, 7.1).
The evaluation team concurs with the TVA approach of (a) identifying piping to be changed by a particular time (b) assuring that documentation exists showing such changed piping is qualified, and (c) requiring analysis to be complete before future changes are to be made.
However, the evaluation team also believes that the performance of these steps must be a quality controlled activity.
The drawings prepared by the Plant Hodifications Section for the ERCH piping system change were not formally prepared and transmitted (App. A, 7.n).
Therefore, the information provided to the Rigorous Analysis Group could be incomplete or incorrect.
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SPECIAL PROGRAM REVISION NUMBER:
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9.4 CHECKING ENGINEERING DRANINGS Issue "a" The issue pertaining to checking of drawings was cited in employee concern IN-85-152-001 received by TVA in May 1985.
l At that time the EN DES procedures (EPs) were in effect for issuing original (App. A. 5.pp) and revised (App. A. 5.qq) engineering drawings. The evaluation team found that the procedure was quite comprehensive and required at least seven signatures, including that of the checker, before the drawing could be issued. The checker's signature signified that (a) the design review is complete; (b) all required interface t
coordination (including requested review) is done; (c) the design complies with all design input and the necessary assumptions' and (d) calculations (including referenced computerprIntout)necessarytoprovethedesignonthebasis s'
of (c) are approved.
The present procedures (NEPs) are somewhat simplified and meet the requirements in a different manner but they also M
requiresixsignaturesbeforeadrawingisIssued.
.{.
A Wa The evaluation team determined that SON site organization (Division of Nuclear Construction (DNC) and Nuclear Site d'
Director (NSD]) did not have a capability for producing or revising enjineering drawings; therefore, and issue must have c
been applicable to the Department of Engineering Design (now g
the Division of Nuclear Engineering) in Knoxville.
Findinat:
a.
TVA and Gilbert / Commonwealth investigations and reports 3
indicate deficiencies in as-built drawings and configuration control.
The evaluation team found this evidence sufficiently conclusive to obviate the need for performing a separate confirming audit.
b.
TVA investigations and reports also indicate some deficiencies in the management and control of plant change and plant change documentation (FCRs, ECNs, etc.).
l
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e TVA EMPLOYEE CONCERNS REPORT NUMBERS 206.1 (8)
)
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1 PAGE 15 0F 27 i
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c.
The evaluation team found that none of the procedures or corrective actions (SQN NPP) reviewed define the time limit l
allowed between a physical change made to a Critical Structures, Systems and Components (CSSC) system and the updating of as-built drawings reflecting that change.
The evaluation team found no definition or listing in the D8VP, Drawing Control Instructions, or plant restart documents of which Control Room Drawings, before plant restart, would be updated to reflect "as-constructed" status.
. A List of Primary Control Room drawings does exist as noted in TVA Memo of 02/03/87 (App. A. 5.xx) and as specified in TVA's response to NRC dated 12/12/86 (App. A, 5.zz). The drawings listed are those required for safe operation, safe shutdown, and maintenance of safe shutdown conditions. The evaluation team has been advised by TVA personnel that at the l
time of restart of SQN Unit 2 these drawings will reflect the as-constructed configuration of the plant.
These drawings shall be maintained during the life of the plant to reflect the as-constructed configuration of the plant.
Additionally, the evaluation team found no upper limit to the amount of red-11ning permitted before a drawing must be redrafted as the next revision.
d.
The evaluation team found that the identification of ERCH stainless steel piping transmitted to the Rigorous Analysis Group was not made in accordance with standard quality l
assurance procedures and practices.
e.
The evaluation team found no evidence of as-built difficulties caused by unchecked drawings, f.
As an additional finding, it appears to the evaluation team that the Primary and Critical drawings listed in the Drawing Control Instructions do not meet the as-built drawing criteria of NUREG 0737 Supplement 1 or of NUREG 0696.
The above two NUREG documents provide NRC guidance on meeting requirements for Emergency Response Capability. The evaluation of the SQN plant complianca with these regulatory documents is beyond the scope of this element report.
Conclusioni:
a.
Issue "a" relating to as-built drawings and configuration control is valid.
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SPECIAL PROGRAM RCVISI ] NUMBERS 1 PAGE 16 0F 27 9
/
With the exception of Control room Drawings (flow diag ams,-
.1J and single lines), as-built deficiencies in control diagrams plantdrawingswIllpersistuntilcompletionofPhaseIIof the Design Baseline 'lartficacion Program.
The methods and plans specified by the Configuration Control 0
the Design Change Process Task Force (App. A 5.h), A, 5.1), and the D8VP (App. A 5.g)
Improvement Program (App.
will give SON personnel the means to greatly reduce concetas.
,Q and problems assectated with as-built drawings and N
configuration control.
i Issue "b" relating to management centrol over plut change and plant change documentation FCRs, ECNs, etc..f s valid.-
/,
b.
^
TheproceduresdevelopedaspartoftheDUVPwillprdidethe o
means to control plant changes and plant change documentation,
and should minimize the occurrence cf as-built inaccuracle
^
Issue "c" relating to a time limit for updsting as-built c.
drawings is valid Unless a time limit is specified in the controlling documents '
(procedures), the discrepancy between as-built drawings and actual plant configuration will persist and, through 10CFR50 '.
Appendix B or other audits, plant restart t.ould be delayed.
The inclusion in the procedures of a finite time to update as-built drawings after physical plant chinges have been completed will greatly assist in meeting 10CFR50 Appendix D Failure requirements and minimizing as-built diserscancies.
to provide as-built drawings within L reasonable time span af ter the physical change is completed could result in audit findings and possible restart delay.
'y f
Only the Control Room Drawings will be up-oAted to red-lined The evaluation team learned status before plant restart.
from TVA personnel that Control Room Drawings consist only of flow diagrams, control diagrams, and single line drawings.
- The Drawing Control Instructions lists types of orawings designated as Critical and Primary and include statements that (1) selected drawings from the listed series of primary and critical drawings shall be located in the control room, those not selected will be located elsewhere; (2) drawings located in the Unit Centrol Accm sM11 be designated as Primary drawings; and (3) drawings located in the Unit Control Room reflect the latest "as-constru:ted" status.
01200 - 02/17/87
f IVA EMPLOYEE CONCERNS REPORT NUMBER 9 20601 (B)
SPECIAL PROGPAM REVISION NUMBER 2 1 PAGE 17 0F 27 Again, the above does pot require that primary and critical drawlags be u) dated be: ora plant restart nor does it provide a time limit )etwoon plant change and completion of as-built drawings reflectirg that change.
d.
Issue "d" relating to the conformance of record pipe stress
.~
calculations with the ts-built piping is valid.
{
Not all correctivo'Tction taken to dato has been performed in
)
accordance with standard quality assurance proceduros and practices.
o.
Issuo "o" relating to checking drawings (perhaps as-built drawings) is not valid..Proceduros for checking engineering drawings ate adequate and the evaluation team found no evidence that the procedures wore not followed, f.
While guidance and critoria of NUREG-0737, Supplomont I and
.1UREG-0696 for as-built drawings for Emergency Response
/
Facilities have boon addressed in this element report, it is r
beyond the scope of this report to evaluate TVA's compliance with regulatory requirements for Emergency Response Capability (ERC). Additionally, the NRC has issued to TVA a
.(
Ccnfirmatory Order (App. A. 5.uu.) regarding TVA's commitment on ERC; therefore, the NRC will track TVA's response to these requirements and commitments.
t.
10.
CorrJ1ctive Action CAP. for_.CAID_206.01 SON 01 The findingt of the report expressed concern that there was no list of which drawings must be updated before startup to reflect the as built configuration of the plant. Also expressed was the concern that proceduros and governing documents do not impose a time limit betwoon the timo a physical chango is made to a CSSC sy'.tcm and engincoring drawings are issued to reflect that change.
The CAP identifies a TVA memorandum which transmits the list of Prit.iary Control Room drawings which will be rod-lined before rottart of Unit 2 and maintained thoroafter to reflect as. constructed configuration of the plant.
The CAP also identiflos the procedure which w111 be revised to contain that list.
The CAP also states that b6 fore the implementation of the permanent Plant Hodification Package (PHP) system, applicable Sequoyah project proceduros and/or nuclear engineering proceduros will bo i
revised to imposo an appropriato timo limit (not to exceed 90 days) l.
01000 - 02/17/07 r
x, q
~
Y TVA EMPLOYEE CONCERNS' REPORT NUMBER: 206.1 (B)
SPECIAL PROGRAM REVISION NUMBER:
l'
~
PAGE 18 0F 27 x
s between the time a physical change is m deqto a CSSC plant' system M
and-the tim the; engineering drawing is issued to reflect that change.'
~.
The evaluation team concurs with the. corrective action plan.
. ZAP for CATO 206.01 SON 02 The finding of the report and the CATD expressed. concern about insufficient management attention to engineering practices and to the Quality Assurance function of assuring that procedures for controlling plant changes and plant change documentation are adequate and that they are being followed. This inattention has resulted in extensive inaccuracies in as-built documentation.
The CAP cites the Sequoyah Nuclear Performance Plan (SQN NPP) as x
evidence that organizational changes, program changes, and e
corrective actions are being implemented to provide adequate management, attention'to all phases of Sequoyah Plant changes and corrective ~ actions.
The evaluation team is of' the opinion that the actions stated in the SQN NPP, if followed, will provide the means ~ to control plant m;.;.
. \\mp changes and plant change documentation and Qould minimize the occurrence of as-built inaccuracies.
[
The report and finding expressed concern that changing the Essential Raw Cooling Hater (ERCH) piping from carbon steel to e
stainless steel was made in a piecemeal fashion, was never completed, and resulted in piping being put into operation without u
qualt rying analysis having been comp 1sted. Addittenally, the t
piping changes and the analysis documentation were not completed in
~
y accordance with TVA Quality Assurance requirements.
The CAP states that the ERCH analysis documentation reflecting the present as-built status will be resubmitted as Quality information for reanalysis. Differences between the previous submittal and the
'new submittal will be evaluated for effects on the analysis. This j
l will be done before plant restart.
The CAP also states the ERCH design drawings will be revised to reflect the as-built condition. This will be a postrestart
--L'N activity.
l=
(
01200 - 02/17/87 i
s g
TVA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 19 0F 27 The CAP identifies the governing QA approved procedure that is being implemented to prevent problems of this nature during.the transitional change period.
It also identifies which procedures will be in effect at the time of implementation of the PHP program to control design and plant changes.
The evaluation team concurs with the above corrective action.
e g
i I
r f
(
l 01200 - 02/17/87 I
l
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 20 0F 27 APPENDIX A 5.
DOCUMENTS REVIEHED RELATED TO THE ELEMENT:
a.
Sequoyah Nuclear Performance Plan Volume II Final Concurrence, Chapter II, Paragraph 1.2.5 and Paragraph 3.0,
" Plant Modification and Design Control," (L44 860714 800),
(07/14/86) b.
Sequoyah Nuclear Performance Plan Volume II Final Concurrence, Chapter III, Paragraph 2.0 and Paragraph 2.2,
" Design Baseline and Verification Program," (L44 860714 800),
(07/14/86) c.
TVA DNE Procedure NEP-9.1, " Corrective Action," Rev. 0 (07/01/86) d.
TVA NQAM, Part V, Section 2.4 (ID-QAP-2.4) " Control'of Modifications," Rev. 1 (07/10/85)
?
e.
TVA DNE Procedure NEP-6.1, " Change Control," Rev. 0 (07/01/86) f.
TVA memorandum from S. A. White to Those Listed, " Policy 0" 9 Establishing the Nuclear Procedures System,"
e (LO2 860709 859), (07/10/86) g.
9 quoyah Nuclear Plant, " Design Baseline and Verification Program," Rev. O, (B25 860506 020), (05/06/86) y s
h.
Office of Nuclear Power (ONP), " Configuration Control Task Force (CCTF) Final Report," (R25 860626 833), (06/30/86) i.
TVA Division of Nuclear Engineering, " Design Change Process Improvement Program," (801 860801 001), (08/01/86) j.
TVA NQAM Part V Section 6.1 (ID-QAP-6.1), " Configuration Drawing Control," Rev. O, (12/31/84) k.
NSRS Investigation Report I-85-637-SQN, "Hork Plan Processing," (10-12/86) k i-01200 - 02/17/87
~
WA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 21 0F 27 APPENDIX A (continued) 1.
SQEP-08, " Packaging and Controlling of Walkdown/ Test Documentation," Rev. 3, (06/27/86) m.
SQEP-ll, " Procedure for Identifying and Assembling Change Documentation," Rev. 2, (06/16/86) n.
SQEP-12. " Procedure for Evaluating Engineering Change Notice and 'leid Change Notice Documents," Rev. 2, (07/14/86)
SQEP-13. " Procedure for Transitional Design Change Control,"
o.
Rev. O, (07/24/86) p.
SQEP-15, " Procedure DNE Interface with Change Control Board (CCB)," Rev. 0, (07/31/86)
B l
q.
SQEP-16, " Procedures for Systems Evaluation and Development of Systems Evaluation Report," Rev. O, (06/21/86) r.
SQEP-17, " Procedure for Origination and Categorization of Configuration Control Drawings (CCDS)," Rev. O, (06/01/86)g p
s.
SQEP-18, " Procedure for Identifying Commitments and Requirements as Source Information for Sequoyah Design
.i Criteria Development," Rev. 1, (07/08/86) t.
SQEP-19, " Comparison of Control Room As-Constructed Drawings j.
to As-Designed Drawings," Rev. O, (05/23/86) 1
~
u.
SQEP-29, " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant," Rev. 1, (07/18/86) i v.
Gilbert / Commonwealth, Inc. Report No. 2600, " Assessment of the Design Control Program for the Sequoyah Nuclear Plant,"
(10/85) w.
SQEP-30, " Control of As-Constructed Drawings," Rev. O, (08/29/86) x.
SQA 183 " Change Control Board (CCB)," Rev. 1, (08/06/86)
[
y.
SQN-AI-19 (Part III), " Plant Modifications: Modification l:
Requests," Rev. 13, (06/03/86)
(
01200 - 02/17/87
b TVA EMPLOYEE CONCERNS
' REPORT NUMBER: 206.1 (B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 22 0F 27-APPENDIX A (continued) z.
SQN-AI-19 (Part IV), " Plant Hodification After Licensing," Rev.
18, (07/07/87) aa.
Letter from B. J. Youngblood, NRC, to S. A. White, TVA,
" Concerns Regarding TVA Nuclear Program," (A02 860224 020)
(02/18/86) bb.
Letter from B. J. Youngblood, NRC, to S. A. White, TVA, with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Rank Building in Knoxville, TN, (B45 860714 832), (06/23/86) cc.
OE-QMS Files of Audits performed on Sequoyah Engineering practices as follows:
86-03, 86-05,-86-09, 86-15, 86-17, 86-24 dd.
SQN AI-25 (Part I), " Drawing Control After Unit Licensing,"
R14, (05/08/86) ee.
SQN AI-25 (Part II), " Revision of As-Constructed Drawings,"
Rev. O, (10/25/86) ff.
SQNSHD8603, "Sequoyah Nuclear Plant - Service Contracts -
Essential Raw Cooling Hater (ERCH) Piping Replacement," Rev. O, (01/22/86) gg.
NRC OIE, IE Information Notice No. 85-66, " Discrepancies r
between As-Built Construction Drawings and Equipment Installations," (08/07/85) hh.
INPO Good Practices document, DE-101 " Configuration Management," Preliminary (03/86) 11.
Gilbert / Commonwealth, Inc., Report No. 2614 "Sequoyah Nuclear Plant Modifications" (03/03/86) jj.
NSRS Investigation Report I-85-473-NPS " Configuration Control at SQN, BFN and OE," (10/02-11/04/85) kk.
ANSI N45-2.ll, " Quality Assurance Requirements for the Design of Nuclear Power Plants," Section 7 " Document Control," and Section 8, " Design Change Control"
(
01200 - 02/17/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)
SPECIAL' PROGRAM REVISION NUMBER:
1 PAGE 23 0F 27 APPENDIX A (continued) 11.
10CFR50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"Section VI,
" Document Control" mm.
10CFR50, Appendix A, " General Design Criteria for Nuclear Power Plants," Design Criterion 5, " Records Requirements" nn.
TVA TR-7.5-1A Rev. 8, " Quality Assurance Program Description for the Design, Construction, and Operation of the TVA Nuclear Power Plant" oo.
10CFR50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, " Content of Emergency Plans" pp.
TVA Division of Engineering Design, Engineering Procedure, EN DES-EP 4.01, " Signatures / Initials for Preparation, Review, 2
and Approval of EN DES Drawings," Rev. 10 (04/25/85) qq.
TVA Division of Engineering Design, Engineering Procedure, fx.*
EN DES-EP 4.21, " Revision and Voiding EN DES Engineering
\\[G Drawings," Rev. 3, (10/18/83) rr.
Letter from Darrell G. Eisenhut, NRC, To All Licensees of Operating Reactors... " Supplement 1 To 3
NUREG-0737-Requirements for Emergency Response Capability (Generic Letter No. 82-33)" and its attachment " Supplement 1 to NUREG-0737" (12/17/82) ss.
NRC OIE NUREG-0696, " Functional Criteria for Emergency Response Facilities," Final Report (07./81) b tt.
SNP Administrative Instruction AI-25 (Part 1), " Drawing E
Control After Unit Licensing," R18, (12/30/86), pp.1-12 l
uu.
Letter from L. M. Mills, NRC, to E. Adensam (TVA), " Issuance of Orders Confirming Licensee Commitments on Emergency l
Response Capability," (A02 840620 001) (06/15/84)
(
01200 - 02/17/87
WA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)
~
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 24 0F 27 APPENDIX A (continued) vv.
TCAB-013, G. McNutt, TVA, to G. Parkinson, Bechtel, Corrective Action Plans for Element 206.1, (11/25/86) ww.
-TCAB-073, G. McNutt, TVA, to G. Parkinson, Bechtel, Corrective Action Plans for Element 206.1, R1, (02/09/87)
TVA memo, D. H. Hilson to Those Listed, "Sequoyah Nuclear xx.
Plant, Primary Control Room Drawing List," (B25 870203 005),
(02/03/87) yy.
Letter from L. M. Mills, TVA, to Harold R. Denton, NRC, Re: "..information pertaining to Radiological Emergency Preparedness for Sequoyah Nuclear Plants Units 1 and 2,"
(A27 810416 019), (04/16/81)
'3 zz.
Letter from R. Gridley, TVA, to J. Nelson Grace, NRC, "Sequoyah Nuclear Plant Unit 2 - Restart Program for Drawing a
Update," (L44 861212 806), (12/12/86).
9 aaa.
TVA memo, H. L. Abercrombie to H. R. Brown, "SQN - Employee Concerns Task Group (ECTG) Element Report 307.13 SQN -
- +,,
("
Operations Category - Corrective Action Plan (CAP),"
j (S03 861212 804), (12/15/86) g Q
6.
WHAT REGULATIONS. LICENSING CO M ITMENTS. DESIGN REOUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
m a.
ANSI N45.2.11. " Quality Assurance Requirements for the Design of Nuclear Power Plants," Section 7, " Document Control," and Section 8, " Design Change Control" b.
10CFR50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"Section VI, l
" Document Control" 10CFR50, Appendix A, " General Design Criteria for Nuclear c.
Power Plants," Design Criterion 5, " Records Requirement" d.
TVA TR-75-1A Rev. 8, " Quality Assurance Program Description for the Design, Construction, and Operation of the TVA Nuclear Power Plant" NRC OIE, IE Information Notice No. 85-66, " Discrepancies e.
l between As-Built Construction Drawings and Equipment Installations," (08/07/85)
(
01200 - 02/17/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 25 0F 27 i
APPENDIX A (continued)
)
f.
10CFR50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, " Content of Emergency Plan" g.
TVA DNE Procedure NEP-6.1, " Change Control," Rev. 0 (07/01/86) h.
TVA Division of Nuclear Engineering (DNE), Sequoyah Engineering Report (SQEP), Proiect Manual 7.
' LIST RE00ESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
a.
RFI SQN-566, (09/15/86) a b.
TVA Transmittal No. 115, Item 7, (09/19/86) c.
Telecon from J. K. Leslie, Bechtel, to Harvey Mahlman, TVA, IOM 2f0 (09/15/86)
C_
d.
Telecon from Harvey Mahlman, TVA, to J. K. Leslie, Bechtel, hyf IOM 259 (09/18/86) e.
Telecon from Rick Daniels, Augie Manicz, Jim Southers TVA, to Suresh Chitnis, Jim Leslie, Ross Hilkinson, Bechtel, IOM 275 (09/24/86) e h
f.
Telecon from J. K. Leslie, Bechtel, to Terrell Clift, TVA, IOM 269 (09/25/86) g.
Telecon from J. K. Leslie, Bechtel, to Harvey Mahlman, TVA, IOM 282 (09/29/86) h.
Trip report, J. K. Leslie, Bechtel, to TVA Knoxville, Sequoyah Nuclear Plant, Hatts Bar, (10/07-09/86) (BLT-091) 1.
RFI SQN-633, (10/13/86) j.
Telecon from J. K. Leslie, Bechtel, to Harvey Mahlman, TVA, IOM 347 (10/17/86) k.
Telecon from J. K. Leslie, Bechtel, to Henry Jones, TVA, Sequoyah, IOM 348 (10/18/86) 1.
Reply to RFI SQN-554 (09/16/86) received 09/29/86 i
01200 - 02/17/87 i
I'
TVA EMPLOYEE CONCERNS REPORT NUMBER: 206.1 (B)~
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 26 0F 27
/
t.
APPENDIX A (continued)
Telecon from Ross Hilkinson, Bechtel, to Jim Southers, TVA, m.
IOM 341 (10/24/86)
Telecon from Ross Hilkinson, Bechtel, to Rick Daniels, TVA, n.
ION 340 (10/24/86)
Telecon from Harvey Mahlman, TVA, to J. K. Leslie, Bechtel, o.
IOM 454 (12/11/86)
Telecon from Harvey Mahlman, TVA, to J. K. Leslie, Bechtel, p.
IOM 558 (01/09/87) q.
r.
Telecon from K. Hardine, J. B. Violette, R.14. Holters, and s.
J. K. Leslie, Bechtel, to G. R. McNutt, John Cox, and Jim Maddox, TVA, IOM 587 (01/26/87) i.i
["cEl t.
Telecon from J. B. Violette, R. A. Holters, and J. K. Leslie,
( ~
Bechtel, to G. R. McNutt, TVA, IOM 588, (12:35 p.m., 01/27/87)
N' Telecon from G. R. McNutt and John Cox, TVA, to J. B.
u.
Violette, R. A. Holters, and J. K. Leslie, Bechtel, IOM 589, (13:00 p.m., 01/27/87) k"f -
Telecon from T. Clift, TVA, and D. Popham, Bechtel, to J. B.
v.
p~
Violette, R. A. Holters, and J. K. Leslie, Bechtel, IOM 582 J.
(01/28/87) a Telecon from H. Mahlman et al., TVA, to R. A. Holters and w.
J. K. Leslie, Bechtel, IOM 652 (02/17/87)
L4 l
t 01200 - 02/17/87
.j..
TVA EMPLOYEE CONCERNS REPORT NUMBER:. 206.1 (B)
'SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 27 0F.27 1
CATD LIST The following LATDs identify and provide corrective actions for the finding included in this report:
206.01 SQN 01 (il/25/86; CAP revised 02/06/87) 206.01 SQN 02 (11/25/86) 206.01 SQN 03 (11/25/86; CAP revised 02/06/87) a 4
I fd
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sM 01200 - 02/17/87
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REFERENCE
- ECPSI20J-ECPSI21C TENNESSEE VALLEY AUTHORITY
.PAGE 64-
)-
FREQUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:57:19 "I
ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS).
RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20601 AS-BUILT INACCURACIES I.)
KEYHORD A
)
S GENERIC
-KEYHORD B H
APPL QTC/NSRS P
CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT.
R DESCRIPTION KEYHORD D
.g
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HI 094-N02 EN 20601 N SQN NNNN SR HRC IDENTIFIED THE FOLL0HING CONCERN-K-FORM FROM REVIEH OF THE QTC FILE:
"THE AS-BUILT CONDITION OF THE PLANT DOES 3)
NOT MATCH THE DESIGN DRAHINGS. THE ERCH IS HAVING ITS CARBON STEEL PIP ING CHANGED TO STAIHLESS STEEL, THE HORK HAS BEEN DIVIDED INTO MANY HORK
")
PLANS HHICH ARE BEING INSTALLED PIEC EMEAL AT VARIOUS OUTAGES. THERE IS A GOOD CHANGE THAT SEQUOYAH HAS BEEN-OPERATING THE PLANT IN AN UNANALYZE-A)
)
D CONDITION SINCE IT.IS DOUBTFUL THA T-THE STRESS ANALYST HAS ANALYZED AL L PIPING CONFIGURATIONS THAT
')
1 I-85-128-NPS EN 20106 S BFN YYYY SS AN INDIVIDUAL FROM BFN HROTE NSRS EX EN 20411 REPORT PRESSING HIS CONCERN THAT THE CONTRO L AND QUALITY OF DE'S DESIGN EFFORT EN 20501 EN 20502 IS INADEQUATE. THE CI SENT SEVERAL 9
1 EN 20601 ROUGHLY HRITTEN PAGES DETAILING AND QA 80305 SUMMARIZING HIS EVALUATION AND CONCL USION OF THREE MAJOR AREAS: (1) D 8
IN 152-001 EN 20601 N HBN YYYY I-85-185-HBN SR INTERVIEHEE EXPRESSED CONCERN THAT C DESIGN REVIEW 3
T50022 REPORT ERTAIN DRAHINGS (PERHAPS AS-BUILT DH DRAHINGS GS) MIGHT NOT BE UP-TO-DATE BECAUSE ENGINEERING THEY HAD NOT BEEN " CHECKED".
INTERV INSTRUMENT / MECH
)
IEHEE HAD MENTIONED THIS TO ANOTHER PERSON (BUT NOT TO HIS SUPERVISOR) A ND HAS TOLD THAT DRAHINGS DO NOT REQ UIRE " CHECKING" UNTIL THEY ARE APPRO
.)
VED (" SIGNED OFF").
MANY DRAHINGS A RE NOT " APPROVED" ALTHOUGHs THE HARD HARE IS ALREADY INSTALLED' HI 100-045 EN 20601 N HBN YYYY SR AS-BUILT DRAHINGS AND DOCUMENTS ARE DRAHINGS
)-
T50215 REPORT
. NONEXISTENT OR IN POOR CONDITION IN NONCONFORMANCE-MANY CASES. CI HAS NO FURTHER INFOR GENERAL MATION. ANONYMOUS CONCERN VIA.LETTE GENERAL J
R.
XX 062-003 EN 20601 S NPS YYYY I-85-475-NPS SS SEQUOYAH, BROWNS FERRY: CI HAS UNOFF NONCONFORMANCE T50127 OP 50715 K-FORM ICIALLY INFORMED'THAT THE DRAHINGS,'
DOCUMENT CONTROL
-) ;'
IN MANY INSTANCES, ARE NOT A TRUE RE OPERATIONS-PRESENTATION OF THE INSTALLATION.
N' GENERAL UCLEAR P0HER CONCERN. CI HAS NO MOR
-]
E INFORMATION.
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7 PAGE 65 REFERENCE
- ECPSI20J-ECPS121C TENNESSEE VALLEY AUTHORITY' RUN TIME - 12:57:19
-w)' -
FREQUENCY
- REQUEST OFFICE OF NUCLEAR P0HER
+
-)
ONP - ISSS - RHN EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 12/02/86
' LIST OF EMPLOYEE CONCERN INFORMATION
i CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20601 AS-BUILT INACCURACIES
()
)
S GENERIC.
KEYHORD A H
APPL QTC/MSRS P
KEYHORD R -
CONCERN KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION.
S
. DESCRIPTION KEYNORD D.
.g -.
HUMBER CAT CAT D LOC FLQB REPORT R
)
XX 070-001 EN 20601 N SQN YYYY I-85-473-NPS SS SEQUOYAN: UNITS 1 & 2 NUMEROUS DOCUM DOCUMENT CONTROL T50140 REPORT ENTS CONTAIN A HIGH PERCENT OF ERROR, RECORD GENERATION S AND DRAHINGS DO NOT REFLECT THE IN OPERATIONS S. k.
)
STALLATIONS IN MANY INSTANCES.
(NAM-REPORTS ES/ DEPT./ DETAILS TO THE SPECIFIC CAS E ARE KNOHN TO QTC AND HITHHELD TO M AINTAIN CONFIDENTIALITY).
CI HAS N g),
-)
O MORE IHFORMATION. NUCLEAR PDHER D' EPT. CONCERN.
XX 070-003 EN 20406 S SQN YYYY I-85-637-SQN SS SEQUOYAH.HORK PLANS CONTAIN INACCU HORK PLAN / PACKAGE
- d. )
)
T50180 EN 20601 K-FORM RATE DATA. MAJORITY OF THE DCR'S TA.
DRANINGS KEN CARE BUT NOT DOCUMENTED RIGHT AN OPERATIONS OP 30704 D DRAHINGS DO NOT REFLECT THE AS-BUI GENERAL LT CONDITIONS. DETAILS HITHHELD TO
).
)
MAINTAIN CONFIDENTIALITY. NUC P0HER CONCERN. C/I HAS NO FURTHER INFORM ATION.
I) _
)
XX 077-002 EN 20601 N SQN YYYY I-85-473-NPS SS SEQUOYAH - UNIT 1 8' 2: NUMEROUS DESI-DRAHINGS T50186 REPORT GN DRAHINGS ARE INACCURATE AND DO NO DOCUMENT STATUS T REFLECT AS BUILT CONDITION. SEVER-GENERAL AL-FCR'S HERE HRITTEN BUT NOT REFLEC.
GENERAL 2)' -
L 3
TED ON THE DESIGN DRAHINGS. CI HAS NO FURTHER INFORMATION. CONSTRUCTIO N DEPT. CONCERN.
i)
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8 CONCERNS FOR CATEGORY EN SUBCATEGORY 20601
-3.
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