ML20214T991
| ML20214T991 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/24/1986 |
| From: | Mcdonald J TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20214G966 | List:
|
| References | |
| NUDOCS 8612090093 | |
| Download: ML20214T991 (3) | |
Text
l o
TENNESSEE VALLEY AUTHORITY Watts Bar Nuclear Plant P. O. Box 800 Spring City, Tennessee 37381 November 24, 1986 Nr. Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Connaission 7920 Norfolk Avenue Bethesda, Maryland 20814
Dear Mr. Denton:
In the Matter of the Application of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328
SUBJECT:
EMPLOYEE CONCERNS TASK GROUP (ECTG)
Enclosure I to this letter transmits for NRC's review three initial reports addressing Sequoyah Nuclear Plant employee concerns in the enginee Ing category.
(These reports have been reviewed and approved by the Senior Review Panel). transmits the final report for 23 elements addressing Sequoyah Nuclear Plant employee concerns in the following categories:
Engineering
- 2 reports Operations
- 10 reports Welding
- 11 reports As has been previously discussed with your staff, the welding reports addressing employee concerns have been left in the format used by the Weld Task Group. In addition, the Weld Task Group had evaluated many of the Sequoyah welding employee concerns prior to categorization by the ECTG. Foc Sequoyah only, some concerns not categorized as welding in the database will be addressed by the welding category. For example, concern IN-85-339-005 is listed in the database in engineering subcategory 23200. For Sequoyah, this concern will not be addressed by EN 23200 but is addressed by welding report WP-05-SQN. The engineering category will conduct the evaluations at Watts Bar, Browns Ferry, and Bellefonte. We are currently developing a programming change to the database to automatically track this change in evaluation responsibility. Until the database is corrected, this tracking information will be provided as a part of these routine transmittals.
(See Enclosure 4.)
4{>
i 8612070093 861124 l
PDR ADOCK 05000327
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PDR An Equal Opportunity Employer
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2 Nr. Denton As indicated by the report cover sheets, these reports have completed final review by the Senior Review Panel and the Employee Concern Task Group management. With these final reports, all employee concerns related to Sequoyah have been addressed for operation subcategories 30400 - Cables and
. Conduit, 30600 - Fire Protection, 30900 --Engineering, and 31200 - Security.
'To assist you in your review of these reports, Enclosure 3 provides a comparison between the ECTG Writer's Guide recommended report format and the transmitted reports. Enclosure 4 provides a listing of the report numbers, the related employee concerns, and the previous submittal dates if applicable.
Please telephone Martha Martin at (615) 365-3587 (Watts Bar) if you have any questions.
Very truly yours, TENNESSEE VALLEY AUTHORITY
.GA; h
I J. A. Mcdonald Watts Bar Nuclear Plant Site Licensing Manager i
Enclosures cc (Enclosures):
Mr. James N. Taylor, Director U.S. Nuclear Regulatory Commission Office of Inspection _and Enforcement Region II U.S. Nuclear Regulatory Commission Attn: Mr. Gary Zech Washington, D. C.
20555 101 Marietta Street, NW, Suite 2900 Atlanta, G^orgia 30323 Nr. B. J. Youngblood, Project Director l
PWR Project Directorate #4 Nr. B. D. Liaw Branch Chief i
Division of PWR Licensing -
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue 7920 Norfolk Avenue Room T-1132 Room 440, 5 Story Phillips Bethesda, Maryland 20814 Bethesda, Maryland 20814 t
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.1(B)
SPECIAL PROGRAM
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REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 0 TITLE:
Q-LIST Q-List Differences PAGE 1 0F 15
- REASON FOR REVISION:
i PREPARATIUR PREPARED Y.
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E TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.l(B)
SPECIAL PROGRAM REVISION NUpBER: 0 PAGE 2 0F 15 1.
CHARACTERIZATION OF ISSUE (S):
Concern:
Issues:
IN-85-407-001
- a. The documents (Q-Lists or equivalent)
"CSSC Q-List is not accurate.
used on SQN to identify the applic-Not all components covered by ability of QA program controls are not QA program are listed. QE accurate and complete.
Department has list that docu-ments the inaccuracies. The
- b. The use of inadequate Q-Lists (or equi-CSSC Q-List is used to determine valents) on SQN could have adversely if QC inspections are required.
affected the establishment of appro-CI has no further information."
priate quality control on items that are related to plant safety. By IN-85-688-003 reference to an inadequate Q-List, the
" Concern over validity of Critical possibility exists that "Non-Q" items System, Structures and Components are installed in a safety-related
'Q' listing. Details knowa to system.
(Thisissueisaddressedin QTC. Details withheld to main-Element Report 209.2, not in this tain CI confidentiality."
report.)
G
- c. Various Q-Lists (or equivalents) exist IN-86-087-004 on SQN, which are different in content.
"Significant differences exist in
- d. The engineering design group (does not the content of the Nuclear Powee 'Q' List and the Critical provide input to the Q-Lists c,r Structures, Systems and Compo-equivalents) on SQN.
ments (CSSC)
'Q' List. Many items originally placed on the NUC Power 'Q' List are not reflected on the CSSC 'Q' List, which could adversely affect establishment of appropriate quality controls on items which are related to plant safety.
Nuclear Power concern. No specifics provided. CI has no further information."
IN-86-090-001 "NUC PWR (No name/ dept. given) issued a Critical Structures, Systems and Components List (CSSC) that does not include all 0929d (10/16/86)
L
[*
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.1(B)
REVISION NUMBER: 0
, (.
PAGE 3 0F 15 items identified on the site
'Q' List (No specifics given).
This was done without Office of ENG, ENG Design Group input /
approval (The originator of the site 'Q' List). By referring to the CSSC, the possibility exists for installing 'Non-Q' items 1
in a Safety-Related System. CI has no additional information.
i NUC POWER toncern."
2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by TVA SON Generic Task Force (GCTG)
Date June 2. 1986 Documentation Identifiers:
GOR-16-16, Rev.1
..g D9 Report GOR-16-16, Rev.1 documents results of an investigation for SQN of Concern Number IN-85-688-003.
3.
DOCUMENT N05.. TAG NOS.. LOCATIONS. OR OTNER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.
None 4.
INTERVIEW FILES REVIEWED:
a.
Expurgated QTC File for IN-85-688-003.
This file contained a copy of the Employee Concern "K" form, and a brief expurgated interview statement with no additional information.
h.
Expurgated QTC File for IN-86-090-001. This file contained a copy of the Employee Concern "K" form, and copies of documents previously reviewed by this evaluator, c.
Expurgated QTC File for IN-85-407-001.
This file contained copies of the Employee Concern "K" form, ECTG Administrative forms, and documents previously reviewed by this evaluator.
d.
Expurgated QTC File for IN-86-087-004.
This file contained copies of the Employee Concern "K" form, ECTG administrative 4:-
forms, and documents previously reviewed by this evaluator.
0929d (10/16/86)
I.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.l(8)
SPECIAL PROGRAM REVISION NUMBER: 0 l
PAGE 4 0F 15 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
6.
WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
7.
LIST REQUESTS FOR INFORMATION, hEETINGS, TELEPHONE CALLS, AND OTHER DISCU55Iussa RELAltu TO ELtMtRI.
See Appendix A.
8.
EVALUATION PROCESS:
a a.
Determine the use of Q-Lists (or equivalent)
I' N on SQN as the method for identifying which items require QA program controls, b.
Review the procedures and practices governing the methods determined in "a."
c.
Review the implementation of procedures and practices in "b."
d.
Evaluate the adequacy of this information to resolve the issues associated with this element.
9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
Discussion:
a.
The four employee K-forms associated with element 209.1 document general concerns about the existence of different Q-Lists on Watts Bar Nuclear Plant (WBNP), the accuracy of the lists, and the impact of using those lists. Although these concerns resulted from specific applications and conditions at WBNP, they have been classified as generically 0929d (10/16/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209. l(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 5 0F 15 applicable to the other TVA nuclear plants, including Sequoyah, because the potential exists for similar deficiencies in the related lists of the other facilities.
b.
"Q-List" is a generic term used by the nuclear power industry to describe a listing of the plant structures, systems, and components that are to be covered by the Quality Assurance (QA) program requirements of 10CFR50 Appendix B.
There is wide variation in the format and detail of the Q-Lists in existence within the nuclear power industry, from summary type lists containing only first-level identification, to extensive listings with subcomponent identification and detailed data.
The listing for Sequoyah is identified as the Critical Structure, Systems, and Components (CSSC) List, and is of the summary type. The SQN CSSC List is characterized as a working document, with everyday usage in Sequoyah activities including modifications, maintenance, and procurement.
However, the use of the SQN CSSC List is limited to only the Operations organization; the list was not used by
-J Construction or Engineering on SQN.
The individual system drawings (P& ids, flow diagrams, etc.)
developed by Engineering identified the safety-related structures, systems, and components on SQN. These drawings were the source documents, rather than the SQN CSSC List, used by the Construction organization to determine the items that required QA program controls.
Construction Specification N2G-877 was issued to provide guidance for Construction in identifying items requiring QA program controls. Tables were included as part of N2G-877 (prior to revision 5) which contained generalized convenience listings of safety-related items. However, the tables were used only as guidelines and do not constitute a "Q-List."
The current revision of N2G-877 (Rev. 5) allows Construction to use a "Q-List" (91QL series drawings) as an alternate to the system drawings for identification of items requiring QA program controls. However, the 91QL' series drawings have not been implemented on SQN, pending the Q-List development activity outlined in 9.c.
c.
Q-List development and implementation on the TVA nuclear plants are undergoing examination and change within TVA at present. TVA policy documents, including the Nuclear Quality Asserance Manual (NQAM), have established the commitment that 0929d (10/16/86)
TVA EMPLOYEE CONCERNS REPORT NUM8ER:
209.l(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 6 0F 15 the Division of Nuclear Engineering (DNE) will develop and maintain a Q-List for each nuclear plant. The DNE-developed Q-List will be used by all divisions within a plant to maintain uniformity.
As the lead plant for implementation of the DNE-developed Q-List, WBNP initiated replacement of the CSSC List by the Q-List.
Inaccuracies and problems subsequently identified in the WBNP Q-List were documented in NCR W-269 and reported to the NRC as a 10CFR50.55(e) "significant deficiency" for WBNP. Corrective actions for that condition are still in progress within TVA, and have impacted the development of a uniform Q-List approach for TVA. The employee concerns associated with this element directly involved the problems associated with the WBNP Q-List.
The timing for implementation of a DNE-developed Q-List has become a plant-unique situation, with the NQAM prescribing that the SQN Q-List will be put into effect, "... at a date mutually) agreed to by DNE and the NSD" (Nuclear Site 1_3 Director.
In the meantime, the SQN CSSC List continues in
']
use at SQN.
d.
The SQN CSSC List was developed and used by the Nuclear Power (NUC PR) organization for application to the Operational QA Program. The list hts successively been a part of the Operations Quality As:,urance Manual and the NQAM, and is now l
contained in Seg;oyah Standard Practice SQA-134. Since the SQN Q-List was developed, responsibility for it has passed from NUC PR to the QA Organization to the NSD at present.
Control of the SQN CSSC List is established through Sequoyah Administrative Instruction AI-39, which provides for a SQN l
CSSC Review Committee to maintain the SQN CSSC List. AI-39 cites the following pertir.ent requirements and l
responsibilities for the SQN CSSC Review Comittee:
o Membership consists of a designated representative from each of the following groups:
Engineering Group - Chairman-Administrative Services - Secretary Regulatory Engineering Quality Assurance Maintenance (Instrument, Electrical, Mechanical)
Design Services 3
0929d (10/16/86)
2 TVA EMPLOYEE CCNCERNS REPORT NUMBER:
209.1(8)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 7 0F 15 (Note: The evaluator was informed that conunittee membership requirements are being changed to reflect the present TVA organization. The " Engineering" representatives indicated above from the current revision of AI-39, are not DNE personnel, but are from the Operations organization..)
i o
The committee is required to meet at least once per i
quarter, and has had six formal meetings in the last 15
)
months.
o Meeting results are documented, and recommended changes 1
to the CSSC List are submitted for Plant Operations Review Committee (PORC) review and Plant Manager's approval o
The committee is required to perform a biennial review of the CSSC List to ensure that the list is accurate and complete
.h e.
The review of reference documents identified various cases of M
direct or inferred concern regarding the accuracy and completeness of the CSSC List, including the following:
o ANI Inspection of SQN dated September 10-13, 1984, (App. A, 5.r) recommended, "The safety-related equipment list should be reviewed periodically for completeness and accuracy by the cognizant group. Additionally,' the Office of Quality Acsurance (QA) should ensure an adequate review through the audit process."
o The Office of Engineering, Design, Construction a
document, OEDC-2QPD-5, (App. A, 5.1), established the j
consnitment for Engineering to prepare a Q-List for each f
nuclear plant, and includes the statement, "... The j
Sequoyah list is not current or specific...." This 4
apparently refers to the SQN CSSC List in place at that time (1982).
o SQN CSSC Review Committee Meeting' Minutes (App. A, 5.u) contain agenda items that imply that the completeness
)
and accuracy of the existing CSSC List is indeterminate, K
for example:
" Determine accuracy of SQN CSSC List for
{
instruments and controls and revise the CSSC List as required."
G 0929d (10/16/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.1(B)
SpECIAL PROGRAM
(.
REVISION NUMBER: 0 PAGE 8 0F 15 o
SQN Generic Concern Task Force Report G0R 16-16 ( App. A, 5.n) contains reccamendations which include:
"A timely review for completeness and accuracy should be conducted to ensure the adequacy of the 'CSSC' List as committed to in the response to ANI, dated December 19, 1984, letter (L64 850104 303)."
The review of case file documents did not indicate that a review of the SQN CSSC List had been accomplished to date.
Minutes of the CSSC Review Committee meetings reflected that the comittee performed numerous activities responding to
" Request for Revision to CSSC List" forms, but those activities do not constitute a complete review of the SQN CSSC List.
f.
There are indications (listed below) that action items associated with the SQN CSSC List are being deferred to the pending DNE Q-List development.
o The TVA commitment to review the SQN CSSC List for
[,~ '
accuracy and completeness on a biennial basis appears to
(
the evaluator to be an action drifting towards deferral to the pending Q-List completion.
o The CSSC Review Comittee has deferred the determination of proper CSSC classification of numerous items to the pending Q-List completion.
10-QAP-2.7, governing the development, control, and application of a Q-List for each nuclear plant has undergone several revisions extending the impicmentation comitment for the SQN Q-List.
It now states that the SQN Q-List will be put into effect at a date mutually agreed to by DNE and the NSD.
Ilowever, the development and implementation of the SQN Q-List will apparently not occur until after completion of the upgrade and revision activities currently in process for the WBN Q-List.
The pattern of deferring the resolution of various CSSC List items to an indeterminate date in the future (associated with completion of the Q-List and its implementation on SQN),
results in a status quo situation for the CSSC List.
g.
One of the four employee concerns in Element 209.1, IN-85-688-003, was investigated by the TVA SQN Generic Concern Task Force (GCTF). The results of that investigation are documented in GCTF Report G0R 16-16 (App. A 5.n), which states that the scope of that investigation was "To determine if the CSSC List used for Sequoyah is accurate."
0929d (10/16/86)
l TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0
(.
PAGE 9 0F 15 The evaluator considers that the conclusions and recommendations stated in GCTF Report GOR 16-16 are contradictory and inconclusive, in that Section IV A.1 states as a conclusion:
"The issue was determined not to be valid by this investigation because Sequoyah is using an accurate
'CSSC List' developed by Quality Assurance and not the
'Q-List' developed by the Office of Engineering."
While Section IV B.1 states as a recommendation:
"A timely review for completeness and accuracy should be conducted to ensure the adequacy of the 'CSSC' List as committed to in the response to ANI, dated December 19, 1984 letter (L64 850104 303)."
h.
NRC Report 50-327/86-11 (App. A, 5.s) documents NRC inspection activities associated with followup of TVA's response to NRC Generic Letter 83-28 (App. A, 5.q).
Sections
'. u ' '-
2.1 and 2.2 of GL83-28 contain requirements for licensees to confirm the safety-related identification of components of the reactor trip system, and to describe their program for ensuring that all components of other safety-related systems are identified as safety-related. Since TVA's response to this requirement referred to the SQN CSSC List as the program for equipment classification, the NRC inspection included the review of procedures and work documents associated with the CSSC List.
Results of the NRC inspection identified that the current program for maintenance of the CSSC List deviates from the program described by TVA in the initial responst: to GL83-28.
The NRC inspector also concluded that TVA's methods for revising the CSSC List lacked a formalized system for tracking CSSC Review Committee agenda items, and for requesting changes te the CSSC List. TVA's response (App. A, 5.t) to the NRC Inspection did not address eitter of these items.
The NRC inspection also included a limited review (sample of
- 7) of Maintenance Requests to verify that work activities were being properly classified as CSSC or non-CSSC.
In the area of equipment classification, the NRC determined that there were no violations or deviations.
(< -lV 0929d(10/16/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.l(B)
SPECIAL PROGRAM REVISION NUpBER: 0 i
e?
PAGE 10 0F 15 i
Findings:
a.
The SQN CSSC List is the "Q-List" type document in use on SQN to identify items that require QA program controls. Although a review l
of the SQN CSSC List for accuracy and completeness has been j
comitted to by TVA, such a review has not been performed to date.
k y
The activities of the SQN CSSC Review Comittee, while a positive U
factor towards maintaining the SQN CSSC List as an "living" k
document, are not sufficient to establish the accuracy and H
completeness of the list. The following shortcomings are evident
[
in the Review Comittee actions:
i o
A TVA review of the SQN CSSC List for accuracy and
)
completeness has not been accomplished to date. Therefore the baseline, to which the CSSC Review Comittee is providing F
g updates for plant modifications etc., is of undetermined accuracy and completeness.
o The practice of deferring numerous classification actions to (5].{g the pending DNE Q-List development, contributes to the Q
questionable status of SQN CSSC Lists accuracy and i
completeness.
b.
The investigation indicated that only a single listing, the SQN CSSC List, was used on Sequoyah. The Engineering organization had developed a " trial use" SQN Q-List, but it was not implemented on 2
the project. Thus, the problems associated with the existence of i
several Q-Lists having different content were not applicable to i
Sequoyah.
i I
Further, the TVA comitment to implement the forthcoming DNE-developed and maintained Q-List will adhere to the principle y
that a single list prescribing QA program applicability will be in existence for SQN. Thus, at some future date, the SQN CSSC List o
will apparently be superseded by an SQN Q-List.
c.
The SQN CSSC List was initially developed and issued by NUC PR, and is presently the responsibility of the NSD through the Operations organization.
The CSSC List is maintained by the SQN CSSC Review Cemittee, which membership lacks direct DNE participation.
+
0929d (10/16/86) i I
,e
?
TVA EMPLOYEE CONCERNS REPORT NUM8ER:
209.1(8)
SPECIAL PROGRAN REVISION NUMBER: O PAGE 110F 15 Review of CSSC Review Committee minutes indicates that specific items are referred to DNE for input, but that DNE involvement is only peripheral. However, there is an indication that the SQN CSSC Review Committee composition is in the process of being modified to include a DNE representative.
The apparent absence to date of active DNE involvement with the SQN CSSC List is considered by the evaluator to be a shortcoming that diminishes the confidence level of the accuracy and completeness of the CSSC List.
==
Conclusions:==
The employee concerns relating to the accuracy and completeness of the SQN CSSC List, and also those relating to Engineering design group input to the list, are considered by the evaluator to be valid concerns for SQN.
The concerns relating to the existence of multiple Q-Lists containing different content are not valid for SQN.
i}
A TVA review of the SQN CSSC List is necessary to confirm its v'. "3!
completeness and accuracy. The review should be performed with input from DNE to determine the degree of completeness appropriate for the list, and should include resolution of those action items previously deferred by the SQN CSSC List Review Committee.
0929d (10/16/86)
TVA EMPLOYEE CONCERNS REPORT NUM8ER:
209.1(8)
SPECIAL PR06RAN REVISION NUM8ER: 0 PAGE 12 0F 15 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
10CFR Part 50, Appendix B, Quality Assurance criteria for Nuclear Power Plants and Fuel Reprocessina Plan,t, Criterion II, " Quality Assurance Program" b.
Regulatory Guide 1.29 Rev. 2, Seismic Desian Classification, (02/76) c.
Regulatory Gulde 1.26, Rev. 2. Quality Group Classifications and Standard for Water-Steam, and Radioactive Weste Containino Components of Nuclear Power Plants (06/75) d.
SNP FSAR, Section 3.2 (Amendment 3), " Classification of Structures. Systems and Components" e.
SNP FSAR, Section 17 ( Amendment 3), " Quality Assurance"
(%'
f.
TVA Topical Report, TVA TR75-1 A (Rev. 8), Quality Assurance Qdl:
Procram Description for the Desian. Construction. and Operation of TVA Nuclear Power Plants g.
Nuclear Quality Assurance Manual. Part V, Section 2.7 (ID-QAP-2.7), Rev. O "Q-List," (06/18/86) h.
Nuclear Quality Assurance Manual, Appendix A. "CSSC Lists -
All Plants," (07/29/85) 1.
20PD-5, Rev. 1, All Nuclear Plants - The Identification and SDecification of items Covered By the OEDC Quality Assurance Program j.
NEP-5.1 Rev. O, Desian Outoul, Attachment 6 "Q-List,"
(07/01/86) k.
Construction Specification, N2G-877 (Rev. 5), Identification of Structure. Systems and Components Covered by the Seouoyah Nuclear Plant Quality Assurance Program 1.
SNP Administrative Instruction. Al-39, Rev. 2, Critical.
Structures. Systems and Components - (CSSC), (01/09/86) m.
SNP Standard Practice, SQA134. Rev. 8, Critical Structure.
Systems and Component) (CSSC) List, (01/27/86) 4 0929d (10/16/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.1(8)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 13 0F 15 APPENDIX A (Cont'd) n.
SQN Generic Concern Task Force Report, GOR 16-16, Rev.1, for Employee Concern Number IN-85-688-003, (06/02/86) o.
NSRS Investigation Report I-85-422-WBN, (10/04/85) p.
W8NP NCR No. W-269-P, (08/26/85) q.
Letter from Mills (TVA) to Adensam (NRC), (A27831107026),
"TVA Docket No. 50-327 & 50-328 TVA Response to Items 2.1 and 2.2 of NRC Generic Letter 83-28," (11/07/83) r.
Letter from Arms (TVA) to American Nuclear Insurers, (LO1841221 158), "SQN-ANI/MAELU Nuclear Liability Insurance
- Sept.10-13,1984 Inspection - Recommendations 84-2, 84-3, and 84-4," (12/19/84) s.
Letter from 01shinski (NRC) to White (TVA), (L44860429173),
" Report Nos. 50-327/86-11 and 50-328/86-11," (04/22/86)
(nA
("
t.
Letter f rom Gridley (TVA) to Grace (NRC), (L44860627800),
" Response to Inspection Report 50-307/86-11 and 50-328/86-11," (06/27/86) u.
Minutes of SQN CSSC Review Committee Meetings:
Meeting 85-02, (553 850730 825), (06/26/85)
Meeting 85-03, (553 851101 980), (09/10/85)
Meeting 85-04, (S53 851203 903), (11/14/85)
Meetin3 86-01, (553 860219 840), (01/14/86)
Meeting 86-02, (S53 860423 814), (04/15/86)
Meeting 86-03, (S53 860514 940), (04/24/86) v.
TVA memo f rom T. G. Campbell to W. E. Andrews, (L53840807942), "SQN-CSSC List," (08/09/84) w.
TVA memo from Law to Those Listed, (L16 851003 854), "Q-List Specification," (10/03/85)
TVA memo f rom Whitt to Parris, (No RI/$), "NSRS Investigation x.
Report I-85-422-W8N," (10/11/85)
M y.
TVAmemofromHowardtoEnnis,(NoRI)f$),"EmployeeConcern Investigation Report Transmittal Response," (12/06/85) 0929d (10/16/86)
E TVA ENPLOYEE CONCERNS REPORT NUMBER:
209.1(8)
SPECIAL PROGRAN REVISION NUMBER: 0 PAGE 14 0F 15 i
5 APPENDIX A (Cont'd)
TVAmemofromWhitttoEnnis.(NoRI/S),"CorrectiveAction
)
z.
Response Evaluation (I-85-422-WBN, Item 2)," (01/08/86) i aa.
TVA memo from Whitt to Ennis, (No RI
), " Corrective Action j
Response Evaluation (I-85-422-WBN, ems 1, 3, 4)," (01/08/86) f bb.
TVA memo from Raulston to Gridley, (B45 860306 260), " Final 10CFR50.55(e) Report on NCR W-269-P R1," (03/06/86) i J
6.
WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS OR OTNER APPLY OR CONTROL IN THIS AREA?
a.
10CFR50, Appendix B, Criterion II, " Quality Assurance Program" b.
Regulatory Guide 1.26, Quality Group Classifications t.nd 1
Standards for Water-Steam, and Radioactive Waste Containing 1
Components of Nuclear Power Plants g
{
.j c.
Regulatory Guide 1.29, Seismic Desian Classification d.
SNP FSAR, Section 3.2, " Classification of Structures, 1
Systems, and Components" l
e.
SNP FSAR, Section 17.0, " Quality Assurance" f.
TVA Topical Report, TVA-TR75-1 A, Quality Assurance Program Description for Design. Construction, and Doeration g.
TVA Nuclear Quality Assurance Menual (NQAN), Section 2.7, "Q-List," and Appendix A "CSSC Lists - All Plants" h.
Nuclear Engineering Procedures (NEP) - 5.1, Design Output 1.
SNP Administrative Instruction, AI-39, Critical Structures, I
Systems and Components - (CSSC) j.
SNP Standard Practice, SQA134, Critical Structure. Systems.
and Components (CSSC) List 1
's
{
0929d (10/16/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.1(B)
SPECIAL PROGRAM REVISION NUM8ER: 0 g.
PAGE 15 0F 15 i
j APPENDIX A (Cont'd) 7.
LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER I
DISCUSSIONS RELATED TO ELEMENT.
l a.
Request for Information (RFI), SQN-563, (09/15/86) b.
RFI, SQN-564, (09/15/86) c.
RFI, SQN-576, (09/18/86) q d.
RFI,SQN-583,(09/22/86) e.
Telecon, L. J. Anderson (Bechtel), with R. W. Fortenberry (TVA),10M-258, (09/18/86) i I
f.
Telecon, L. J. Anderson (Bechtel), with D. T. Clift (TVA),
{
10M-272,(09/24/86) g.
Telecon, L. J. Anderson (Bechtel), with D. T. Clif t (TVA),
10M-273,(09/29/86) h.
Telecon, L. J. Anderson (Bechtel), with D. T. Clift /R. Olson (TVA), 10M-306, (10/09/86) b i.
Telecon, L. J. Anderson (Bechtel), with D. T. Clift /R. W.
}
Fortenberry (TVA), 10M-308, (10/09/86)
{
jf f
5 e
0929d (10/16/86) l k
e ECTG C.3 Attactueent A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tractina Document (CATD)
INITIATION 1.
Isumediate Corrective Action Required: k Yes O No 2.
Stop Wort Reconumended: 0 Yes M No SdN
-\\
a.
INITIATION DATE 10AG/E 3.
CATD No._ M. l
=
5.
RESPONSIBLE ORGANIZATION:
DNP [oPresTseats) /'P4E 6.
PROBLEM DESCRIPTION
- M R O NQR TVA has a-od A FeAra M & SGN Cfic LAI in CMrm Tir nermu ad 'co.lahneu. In - -41rn. _ vekoneo in Sag ctrc Rev,eu (m.nrh wn_tra'. enrmfer indvmier +La arfat. ac h iteme MteeInit2 wik "deYerminima neona Csrc c -~ 4renku knut been d tferveA 4a +Le s'o 2:-
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< ef' redited AL 2 4tah) &
^
Smef' Pe eb4 M M ann ^^^ - **
~
_'l O ATTACHMENTS i
7.
PREPARED BY: NAME ME #-
DATE: 10/lb/f6 I
8.
CONCURRENCE: CEG-H N 'hu w A M M DATE: //- /W 9.
APPROVAL: ECTG PROGRAY iGR. '
/
DATE:
h CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
1 i
i l
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
ECTG PROGRAM MGR:
DATE:
VF.RIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
$1GNATURE TITLE DATE i
I s
l l
l
l i
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.2(B)
SPECIAL PROGRAN REPORT TYPE:
SEQUOYAH ELENENT REVISION NUMBER:
0 TITLE:
Q-LIST INPACT AND SIGNIFICANCE OF Q-LIST PAGE 10F 16 DIFFERENCES REASON FOR REVISION:
,, jg PREPARATION l0h//F6 SIGNATURE DATE REVIEWS 2.
REVIEW COMITT
/0/24 lod
~
'SI'GNATURE
~~
DATE TAS:
V SIGNATURE DATE CONCURRENCES 8612090169 861124
[
/8!M PDR ADOCK 05000327 P
PDR CEG-H:
4/Z4 [
//'/ 8I
/
SRP:
SIGNATURE DATE SIGNATURE DATE APPROVED BY:
ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
L
4 TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B) z..
SPECIAL PROGRAM REVISION NUM8ER: 0 PAGE 2 0F 16 1.
CHARACTERIZATION OF ISSUE (S):
Concerns:
_ Issues:
i IN-85-407-001 a.
The documents (Q-Lists or equivalents) r "CSSC Q-List is not accurate.
used on SQN to identify the applic-Not all components covered by ability of QA program controls are not i.
QA program are listed. QE accurate and complete.
(This issue is
[
Department has list that docu-addressed in Element Report 209.1 (B),
i ments the inaccuracies. The not in this report.)
l CSSC Q-List is used to determine l
if QC inspections are required.
b.
The use of inadequate Q-Lists (or equi-i CI has no further information."
valents) on SQN could have adversely i
affected the establishment of appro-j IN-86-087-004 priate quality control on items that l
"Significant differences exist are related to plant safety. By i
in the content of the Nuclear reference to an inadequate Q-List, the Power 'Q' List and the Critical possibility exists that "Non-Q" items
{
Structures, Systems and Compo-are installed in a safety-related nents (CSSC) 'Q' List. Many system.
items originally placed on the e,,
NUC Power 'Q' List are not c.
Various Q-Lists (or equivalents) exist 4
reflected on the CSSC 'Q'
- List, on SQN, which are different in content.
I y8 which could adversely affect (This issue is addressed in Element Report i
establishment of appropriate 209.1 (B), not in this report.)
l quality controls on items which i
are related to plant safety.
d.
The engineering design group does not j
Nuclear Power concern. No provide input to the Q-Lists (or i
specifics provided. CI has no equivalents) on SQN.
(This issue is e
further information."
addressed in Element Report 209.1 (B),
I not in this report.)
IN-86-090-001 i
"NUC 'WR (No name/ dept. given) issued a critical Structures, l
Syste.as and Components List 8
(CSSC) that does not include k
all items identified on the i
site 'Q' List (No specifics
[.
given). This was done with-out Office of ENG, ENG Design I
Group input / approval (The i
originator of the site 'Q' j
List). By referring to the CSSC, the possibility exists 4
for installing 'Non-Q' items i
in a Safety-Related System. C1
]
has no additional information.
(
,T _
NUC POWER concern."
13 l
01300 - 10/24/86 A
=
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(8) y SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 3 0F 16 2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES NO X Identified by Not applicable Date Not applicable Documentation Identifiers:
Not applicable 3.
ROCUMENT NOS.. TAG NOS.. LOCATIONS. OR OTHER SPECIFIC DESCRIPTIVE IE,ENTIFICATIONS STATED IN ELEMENT:
None 4.
INTERVIEW FILES REVIEWED:
a.
Expurgated QTC File for IN-86-090-001. This file contained a copy of the Employee Concern "K" form and copies of documents y
previously reviewed by this evaluator.
b.
Expurgated QTC File for IN-85-407-001. This file contained copies of the Employee Concern "K" form ECTG Administrative forms, and documents previously reviewed by this evaluator.
c.
Expurgated QTC File for IN-86-087-004. This file contained copies of the Employee Concern "K" form, ECTG administrative forms, and documents previously reviewed by this evaluator.
5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
6.
WHAT REGULATIONS. LICENSING COMITNENTS. DESIGN REQUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
7.
LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
01300 - 10/24/86
TVA ENPLOYEE CONCERNS REPORT NUN 8ER: 209.2(B)
SPECIAL PROGRAN REVISION NUN 8ER: 0 PAGE 4 0F 16
~'-(
8.
EVALUATION PROCESS:
The evaluation of concerns in this element is predicated on the findings and conclusions of element report 209.1 (B):
that the accuracy and completeness of the SQN CSSC List has not been adequately verified by TVA.
Review SQN practices and procedures to determine the use of a.
the SQN CSSC List.
Interview cognizant TVA personnel as necessary.
b.
Assess the potential for the use of an incomplete or inaccurate SQN CSSC List to adversely impact appropriate quality control measures on items related to plant safety.
i 9.
DISCUSSION. FINDINGS. AND CONCLUSIONS:
Discussion:
7 a.
The three employee concerns associated with Element 209.2
+
relate to the existence of different Q-Lists on Watts Bar Nuclear Plant (WBNP), the accuracy of the lists, and the effect of using those lists. Although these concerns resulted from specific applications and conditions at WBNP, i
they have been classified at generically applicable to the other TVA nuclear plants, including Sequoyah, because the potential exists for similar deficiencies in the related lists of the other facilities.
I l
l N!',
ts r 01100 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUM8ER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: 0 t-5 PAGE 5 0F 16 a
f
{
The investigation for Elem5nt 209.2 is limited to the issue of whether the use of inadequate Q-Lists (or equivalents) on SQN could adversely affect the establishment of appropriate quality controls on items related to plant safety. The related issues 1
[
of accuracy and completeness of the lists are addressed in Element Report 209.1, and certain information from it is il repeated here for continuity and to minimize cross referencing.
s f-Y.
{
b.
"Q-List" is a generic term used by the nuclear power industry f
to describe a listing of the plant structures, systems, and components subject to the Quality Assurance (QA) program requirements of 10CFR50 Appendix B.
The format and detail of Q-Lists used in the nuclear power industry vary from sunmary J
type lists containing only first-level identification to j
extensive listings with subcomponent identification and detailed data.
The only "Q-List" type document used on Sequoyah is identified I
as the Critical Structure, Systems, and Components (CSSC) List, and is of the summary type.
It is a working document, with everyday use in the activities of the Operations organization, such as modifications, maintenance, and procurement. However, the SQN CSSC List is used only by the Operations organization; the list was not used by Construction or Engineering at SQN.
01300 - 10/24/86
~.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: O PAGE 6 0F 16
(,
To accr>mplish the purpose of a Q-List, Engineering issued individual system drawings (P& ids, flow diagrams, etc.)
identifying the safety-related structures, systems, and components on SQN. These drawings were then the source documents, rather than the SQN CSSC List, used by Construction to determine the items requiring QA program controls.
Construction Specification N26-877 contains guidance for Construction in identifying items requiring QA program controls.
Prior to revision 5 N26-877 contained generalized
N convenience listings of safety-related items; however, these were used only as guidelines and do not constitute a "0-List."
The current revision of N2G-877 (Rev. 5) allows Construction to use a "Q-List" (91QL series drawings) as an alternate to the system drawings for identification of items requiring QA program controls.
In actuality, the 91QL series drawings have not been implemented on SQN, and this alternate method has not been used by Construction.
Therefore, this investigation of potential negative impact from using inadequate "Q-Lists" is limited to consideration of the use of the SON CSSC List by the Operations organization.
01300 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.2(B)
SPECIAL PROGRAM REVISION NUM8ER: O PAGE 7 0F 16 c.
Review of the case file documents shows that the SQN CSSC List is an integral part of procurement, maintenance, and modification activities at SQN. The SQN procedures (App. A, j
5.1, 5.n, and 5.0) that control these activities typically I
cite the CSSC List as the determinant of safety-related 1
(CSSC) items.
Proper classificatic9 as CSSC vs non-CSSC is
[
fundamental for incorporating of appropriate quality program requirements in the governing documents. Misclassification of an item as non-CSSC could cause the following types of essential requirements and activities to be omitted from procurement, maintenance, and modification processes:
S' o
Reviews for adequacy of technical and quality requirements o
Code requirements, such as 10CFR21 o
Supplier QA prograa requirements o
Documentation o
Inspections and tests l
8..i 01300 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: 0
]
PAGE 8 0F 16 o
Record retention o
Special requirements and procedures d.
The revision history of the SQN CSSC List evidences many additions since its initial issue. Sequoyah Administrative Instruction AI-39 requires that added items must be evaluated (and the CSSC List revised as necessary) prior to declaring the affected equipment operable. This procedure includes issuing deficiency reports as needed to document the resolution of items previcusly processed as non-CSSC.
Discussions with cognizant TVA personnel indicated that most additions to the SQN CSSC List resulted from plant modification actions rather than from reclassification of items or correction of omissions in the list.
e.
TVA policy documents, including the Nuclear Quality Assurance Manual (NQAM), commit the Division of Nuclear Engineering (DNE) to developing and maintaining a Q-List for each TVA nuclear plant. These lists will be used by all divisions within a plant to maintain uniformity. Thus, the SQN CSSC List will apparently be superseded by an SQN 0-List.
F 01300 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B) 4 SPECIAL PROGRAM REVISION NUMBER: O PAGE 9 0F 16 1
1 ID-QAP-2.7, governing the development, control, and i
.1 application of a 0-List for each nuclear plant, has undergone ij several revisions extending the implementation commitment for
.S the SQN Q-List.
It now states that the Q-List will be put q
9)f(
into effect at a date mutually agreed to by DNE and the Nuclear Site Director (NSD). However, the development and n
- i implementation of the SQN Q-List will apparently not occur q
until after completion of the upgrade and revision activities l
currently in progress for the WBN Q-List.
l
}
Review of the SQN CSSC Review Committee Meeting Minutes h
I (6/85 through 4/86, App. A, 5.u) indicates that the h
deterinination of proper CSSC classification for numerous items has been deferred to the pending DNE-developed Q-List.
TVA has not, to date, provided a rationale as to why it is q
i t acceptable to defer the review of the CSSC List to past restart. The effect of potential errors, as they relate to past procurement, maintenance and modification processes has n
not been addressed.
8h m
01300 - 10/24/86 i
)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 10 0F 16 i
Findings:
I The SQN CSSC List has been used only by the Operations a.
t organization; the list was not used by Construction or Engineering on SQN. Therefore, the potential effects of f
using an inaccurate or incomplete SQN CSSC List are limited to Operations activities, which include procurement, f
maintenance, and modification.
i i
b.
SQN procedures that control procurement, maintenance, and 8
f modification activities of the Operations organization I
establish the SQfi CSSC List as the base reference for q
identifying safety-related (CSSC) items.
Erroneous f
classification of an item as non-CSSC could result in
- s f
omission of essential requirements and activities.
4
==
Conclusions:==
l 4
The conclusions of this Element Report are subordinate to those of 1
l' Element Report 201.l(B), which concludes that the accuracy and completeness of the SQN CSSC List had not yet been adequately reviewed and verified by TVA, and that such a review is necessary.
d
- =
l 1'
01300 - 10/24/86
TVA ENPLOYEE CONCERNS REPORT NUMBER: 209.2(8)
SPECIAL PROGRAN REVISION NUMBER: 0
'~
PAGE 110F 16 The employee concerns relating to the possibility that use of an inadequate SQN CSSC List could adversely affect quality control on items related to plant safety are considered by the evaluator to be valid for SQN. This conclusion is based on the significant role of the SON CSSC List in SQN procedures controlling procurement, maintenance, and modification activities within the Operations organization. An inaccurate or incomplete SQN CSSC List could result in misclassification of an item or work activity as not being safety-related (CSSC) and omission of QA program requirements. This could adversely affect the establishment of appropriate quality controls on items affecting plant safety, and hf[.fi therefore needs resolution prior to restart.
The conclusion regarding the validity of the concerns to SQN is tempered by the condition that specific deficiencies in the SON CSSC List have not been identified. A review to verify the accuracy and completeness of the SQN CSSC List has.not yet been I
performed by TVA, and further TVA followup actions related to this element depend on the results of such a review.
t I
'l b
01300 - 10/24/86 3
_ _ _ _ _ _ _ _ - ~ _. - _ _ _.,.. -
__...-=_______._.,,_.-__---____,.m
- -.- _=,.__,
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.2(8)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 12 0F 16 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
10CFR 50, Appendix 8, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprccessing Plants, Criterion II,
" Quality Assurance Program" b.
Regulatory Guide 1.29, Rev. 2, Seismic Desian Classification.
(02/76) c.
Regulatory Guide 1.26, Rev. 2, Quality Group Classifications and Standard for Water-Steam, and Radioactive Waste Containing Components of Nuclear Power Plants, (06/75) d.
SNP FSAR, Section 3.2 (Amendment 3), " Classification of Structures, Systems and Components" e.
SNP FSAR, Section 17 (Amendment 3), " Quality Assurance" f.
TVA Topical Report TVA, TR75-1A (Rev. 8), Quality Assurance jfr Program Description for the Desion. Construction, and 7'
Operation of TVA Nuclear Power Plants g.
Nuclear Quality Assurance Manual, Part V, Section 2.7 (ID-QAP-2.7), Rev. O, "Q-List," (06/18/86) h.
Nuclear Quality Assurance Manual, Appendix A, "CSSC Lists -
All Plants," (07/29/85) 1.
Construction Specification, N2G-877 (Initial Issue through Rev. 5), Identification of Structure. Systems, and Components Covered by the Seouoyah Nuclear Plant Quality Assurance Program j.
SNP Construction Procedure, P-24 (Rev. 6), Inspection and Test Status, (05/07/82) i k.
SNP Administrative Instruction AI-39, Rev. 2, Critical Structures. Systems and Components - (CSSC), (01/09/86) 1.
SNP Administrative Instruction, AI-19, Part III, Rev. O,
" Plant Modifications: Modification Request," (06/03/86), and Part IV, Rev.18. " Plant Modifications:
After Licensing,"
(07/07/86) m.
SNP Standard Practice, SQA134, Rev. 8, Critical Structure.
cA Systems and Components (CSSC) List, (01/27/86)
B 01300 - 10/24/86
1 1
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(8)
SPECIAL PROGRAM REVISION NUMBER:
0 PAGE 13 0F 16 f
APPENDIX A (Cont'd) l n.
SNP Standard Practice, SQM2, Rev. 20, Maintenance Management System, (09/11/86) o.
SNP Standard Practice, SQA45, Rev. 22, Quality control of Material and Parts and Service, (09/11/86) l p.
NSRS Investigation Report I-85-422-W8N, (10/04/85) q.
WBNP NCR No. W-269-P, (08/26/85) r.
Letter from Mills TVA, to Adensam, NRC, (A27831107026), "TVA Docket No. 50-327 & 50-328, TVA Response to Items 2.1 and 2.2 of NRC Generic Letter 83-28," (11/07/83) s.
Letter from 01shinski, NRC, to White, TVA, (L44860429173),
" Report Nos. 50-327/86-11 and 50-328/86-11," (04/22/86) t.
Letter from Gridley, TVA, to Grace, NRC, (L44860627800),
Subject:
" Response to Inspection Report 50-307/86-11 and
, gj;.
50-328/86-11," (06/27/86)
- .9
- ~
u.
Minutes of SQN CSSC Review Committee Meetings:
Meeting 85-02, (S53 850730 825), (06/26/85)
Meeting 85-03, (SS3 851101 980), (09/10/85)
Meeting 85-04, (S53 851203 903), (11/14/85)
Meeting 86-01, (553 860219 840), (01/14/86)
Meeting 86-02, (S53 860423 814), (04/15/86)
Meeting 86-03, (S53 860514 940), (04/24/86) v.
TVA memo from Whitt to Parris, (no R(FS), NSRS Investigation Report I-85-422-W8N, (10/11/85)
M TVA memo from Howard to Ennis, (no R%), " Employee w.
Concern Investigation Report Transmittal Response,"
(12/06/85) i
" ?,
.i 01300 - 10/24/86 l
1 TVA EMPLOYEE CONCERNS REPORT NL'MBER: 209.2(8)
SPECIAL PROGRAN REVISION NUMBER: 0 i
PAGE 14 0F 16 l.
APPENDIX A (Cont'd)
)
TVA memo from Whitt to Ennis, (No RIJS), " Corrective Action x.
Response Evaluation (I-85-422-WBN, Item 2)," (01/08/86) e4 y.
TVAmemofromWhitttoEnnis,(NoRIf5),"CorrectiveAction Response Evaluation (I-85-422-W8N, Items 1, 3, 4)," (01/08/86) z.
TVA memo from Raulston to Gridley, (845 860306 260),
Final 10CFR50.55(e) Report on NCR W-269-P R1, (03/06/86) 6.
WHAT REGULATIONS. LICENSING COMITMENTS. DESIGN REQUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA?
i a.
10CFR50, Appendix 8, Criterion II, " Quality Assurance Program" b.
Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-Steam. and Radioactive Weste Containing Components of Nuclear Power Plants g
c.
Regulatory Guide 1.29, Seismic Desian Classification Y
d.
SNP FSAR, Section 3.2, " Classification of Structures, Systems, and Components" e.
SNP FSAR, Section 17.0, " Quality Assurance" f.
TVA Topical Report, TVA-TR75-1 A, Quality Assurance Procram Description for Desion. Construction, and Operation g.
TVA Nuclear Quality Assurance Manual (NQAM), Section 2.7, "Q-List," and Appendix A, "CSSC Lists - All Plants" h.
Construction Specification, N26-877, Identification of Structure. Systems. and Components Covered by the Sequoyah Nuclear Plant Quality Assurance Program.
1.
SNP Administrative Instruction, AI-39, Critical Structures, Systems and Components - (CSSC) i j.
SNP Administrative Instruction, AI-19, Part III, " Plant Modifications: Modification Requests," and Part IV, " Plant
{
Modifications: After Licensing"
,)
i 01300 - 10/24/86
i TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(8)
SPECIAL PROGRAM REVISION NUMBER: O l
PAGE 15 0F 16 APPENDIX A (Cont'd) k.
SNP Standard Practice, SQA134, Critical Structure. Systems, and Components (CSSC) List 1.
SNP Standard Practice, SQM2, Maintenance Managenent System m.
SNP Standard Practice, SQA45, Quality Control of Material and
(
Parts and Services i
i 7.
l LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
[
a.
Request for Information (RFI), SQN-563, (09/15/86) i b.
RFI, #SQN 564,(09/15/86) c.
RFI, #SQN 576, (09/18/86) d.
RFI, #SQN 583 (09/22/86)
$h h e.
RFI, #SQN 619, (10/06/86)
.tv f.
RFI, #SQN 641, (10/16/86) i g.
Telecon, L. J. Anderson, Bechtel, with R. W. Fortenberry, TVA, 10M-258, (09/18/86) h.
Telecon, L. J. Anderson, Bechtel, with D. T. Clift TVA, IOM-272, (09/24/86)
Q i.
Telecen, L. J. Anderson, Bechtel, with D. T. Clift, TVA, IDM-?73, (09/29/86) j.
Telecon, L. 2. Anderson, Berkiel, with D. T. Clift, TVA, IDM-306, (10/07/86)
?
l' k.
Telecon, L. J. Anot son, Bechtel, with D. T. Clift /R. W.
Fortenberry. 7th, 10!1-308, (10/09/86) e 4
)
01300 - 10/24/86
e RCTG C.3 Attachment A Page 1 et 1 Revision 2 - A ECSP CORRECTIVE Action Tract at Document (CATD)
INITIATION 1.
Isumediate Corrective Action Required: %'Yes O No 2.
Stop Wort Recoassended: 0 Yes M No 3.
CATD No.
Odl. 2
- SQd I
a.
INIJIATION DA E O NP f CPER4 m N (i>
5.
RESPONSIBLE ORGANIZATION:
6.
PRO Elj DESCRIPTION: K QR O NQR s, m W n J w % A CSsc % ml (B J. M k,~%
SUN CSsc Lt. n a rd / CTVAe & A & 4,w M 2rA. iib >. n
'--- v 4- # Jrir&t & w-m+cssM44 enM s mM V Th 'O A :.==__ A LE w *~ LTA br wL L m ' thJud h, k oA2XE MJ:a of &?n k Tia SON circ utt vr.wer resokdik, win a
n vish k.
.4 O ATTACHMENTS m
7.
PREPARED BY: NAME -dXc L-And DATE: f 'd3;Mrt, 8.
CONCURRENCE:
CEG-H, ZND huw RN DATE:
//- /-M 9.
APPROVAL: ECTG PROdIAP'4GE.
8 DATE:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
Q' O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /NGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
l 3RP:
DATE:
ECTG PROGRAN NGE:
DATE:
VERIFICATION AND CLOSEOUT I
13.
Approved corrective setions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE FQ.
,