ML20214U174
| ML20214U174 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/01/1986 |
| From: | Anderson F, Mason P, Parkinson J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214G966 | List:
|
| References | |
| 209.2(B), 209.2(B)-R, 209.2(B)-R00, NUDOCS 8612090169 | |
| Download: ML20214U174 (16) | |
Text
's TVA ENPLOYEE CONCERNS REPORT NUNBER:
209.2(B)
SPECIAL PROGRAN REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER:
0 TITLE:
Q-LIST INPACT AND SIGNIFICANCE OF Q-LIST PAGE 1 0F 16 DIFFERENCES REASON FOR REVISION:
9 PREPARATION 9 PREPARE Y
Iohilec e
SIENATURE DATE REVIEWS
~2.
REVIEW C0f91ITT
/0/24/84
'SI'GNATURE
~
DATE TAS:
V SIGNATURE DATE CONCURRENCES B612090169 861124
/
/8!M PDR ADOCK 05000327 7
CEG-H:
/JZ4 [M
//-/ fl P
/
SRP:
SIGNATURE DATE SIGNATURE DATE L
i EPROVEDBY:
ECSP MANAGER DA1E MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
~
TVA EMPLOYEE CONCERNS REPORT NUM8ER: 209.2(B)
+
' )
SPECIAL PROGRAM REVISION NUM8ER: 0 PAGE 2 0F 16 1.
CHARACTERIZATION OF ISSUE (S):
Concerns:
Issues:
IN-85-407-001 a.
The documents (Q-Lists or equivalents)
"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.
(This issue is Department has list that docu-addressed in Element Report 209.1 (B),
ments the inaccuracies. The not in this report.)
CSSC Q-List is used to determine if QC inspections are required.
b.
The use of inadequate Q-Lists (or equi-CI has no further information."
valents) on SQN could have adversely affected the establishment of appro-IN-86-087-004 priate quality control on items that "Significant differences exist are related to plant safety.
By 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 NUC Power 'Q' List are not c.
Various Q-Lists (or equivalents) exist i
reflected on the CSSC 'Q'
- List, on SQN, which are different in content.
1E' which could adversely affect (This issue is addressed in Element Report establishment of appropriate 209.1 (B), not in this report.)
quality controls on items which are related to plant safety.
d.
The engineering design group does not Nuclear Power concern. No provide input to the Q-Lists (or specifics provided. Cl has no equivalents) on SQN.
(This issue is further information."
addressed in Element Report 209.1 (B),
not in this report.)
IN-86-090-001 "NUC PWR (No name/ dept. given) issued a Critical Structures, Systems and Components List (CSSC) that does not include all items identified on the site
'Q' List (No specifics given). This was done with-out 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 in a Safety-Related System. CI i
has no additional informatloa, l
NUC POWER concern."
01300 - 10/24/86 i
4*
4 5
TVA EMPLOYEE CONCERNS REPORT NUM8ER: 209.2(B) y
~SPECIAL PROGRAM REVISION NUMBER: 0 r
PAGE 3 0F 16 C
2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS 7 YES NO X Identified by Not applicable Date Not applicable Documentation Identifiers:
Not applicable 3.
DOCUMENT N05.. TAG NOS.. LOCATIONS. OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS 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 previously reviewed by this evaluator.
(1-.
b.
Expurgated QIC 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 COMMITMENTS. DESIGN REQUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
7.
LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. %ND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
01300 - 10/24/86
i TVA ENPLOYEE CONCERNS REPORT NUM8ER:
209.2(B)
SPECIAL PROGRAN REVISION NUMBER: O PAGE 4 0F 16 m
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.
a.
Review SQN practices and procedures to determine the use of 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 imonet appropriate quality control measures on items related to plant safety.
9.
DISCUSSION. FINDINGS. AND CONCLUSIONS:
Discussion:
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 W8NP, they have been classified as 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.
01300 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUM8ER: 209.2(8) i-SPECIAL PROGRAM REVISION NUMBER: 0 f
PAGE 5 0F 16 l
l-l The investigation for Element 209.2 is limited to the issue of I
l whether the use of inadequate Q-Lists (or equivalents) on SQN could adversely affect the establisiiment of appropriate quality i
controls on items related to plant safety. The related issues h
of accuracy and completeness of the lists are addressed in Element Report 209.1, and certain information from it is repeated here for continuity and to minimize cross referencing.
I
{
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
_3 f
requirements of 10CFR50 Appendix 8.
The format and detail of
(
Q-Lists used in the nuclear power industry vary from sumary type lists containing only first-level identification to i
extensive listings with subcomponent identification and L
[f detailed data.
t The only "Q-List" type document used on Sequoyah is identified I
as the Critical Structure, Systems, and Components (CSSC) List, I
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, f
the SQN CSSC List is used only by the Operations organization; I
the list was not used by Construction or Engineering at SQN.
01300 - 10/24/86
~
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(8)
SPECIAL PROGRAM REVISION NUM8ER: O PAGE 6 0F 16
(,
To accomplish 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 N2G-877 contains guidance for Construction in identifying items requiring QA program controls.
Prior to revision 5, N26-877 contained generalized h
convenience listings of safety-related items; however, these 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.
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 SQN CSSC List by the Operations organization.
01300 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER:
209.2(8)
SPECIAL PROGRAM REVISION NUMBER:
0 PAGE 7 0F 16 i
c.
Review of the case file documents shows that the SQN CSSC List is an integral part of procurement, maintenance, and 1
modification activities at SQN. The SQN procedures (App. A, 5.1, 5.n, and 5.0) that control these activities typically cite the CSSC List as the determinant of safety-related (CSSC) items.
Proper classification 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:
~, '.
l o
Reviews for adequacy of technical and quality requirements 3
o Code requirements, such as 10CFR21 o
Supplier QA program requirements a
o Documentation i
o Inspections and tests t
Ire 01300 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 20902(8)
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 Adr...:.istrative Instruction AI-39 requires that addad 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 previously 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), conunit 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 Listwil)apparentlybesupersededbyanSQNQ-List.
01300 - 10/24/86
i TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(8)
SPECIAL PROGRAM REVISION NUMBER: 0 I
PAGE 9 0F 16 ID-QAP-2.7, governing the development, control, and application of a 0-List for each nuclear plant, has undergone several revisions extending the implementation commitment for i
the SQN Q-List.
It now states that the Q-List will be put
)}
into effect at a date mutually agreed to by DNE and the l
Nuclear Site Director (NSD). However, the development and j
implementation of the SQN 0-List will apparently not occur j
until after completion of the upgrade and revision activities currently in progress for the W8N Q-List.
i 1
1 Review of the SQN CSSC Review Conunittee Meeting Minutes (6/85 through 4/86, App. A, 5.u) indicates that the determination of proper CSSC classification for numerous ti items has been deferred to the pending DNE-developed Q-List.
TVA has not, to date, provided a rationale as to why it is 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 not been addressed.
i h
g 01300 - 10/24/86 i
TVA EMPLOYEE CONCERNS REPORT NUM8ER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: O PAGE 10 0F 16 Findinos:
r i
I a.
The SQN CSSC List has been used only by the Operations organization; the list was not used by Construction or Engineering on SQN. Therefore, the potential effects of using an inaccurate or incomplete SQN CSSC List are limited to Operations activities, which include procurement, i
maintenance, and modification.
l b.
SQN procedures that control procurement, maintenance, and I
modification activities of the Operations organization g
establish the SQN CSSC List as the base reference for l
identifying safety-related (CSSC) items. Erroneous i
j classification of an item as non-CSSC could result in omission of essential requirements and activities.
i i
==
Conclusions:==
i k
1
]
The conclusions of this Element Report are subordinate to those of i
Element Report 201.1(B), which concludes that the accuracy and
?
completeness of the SQN CSSC List hcd not yet been adequately reviewed and verified by TVA, and that such a review is necessary.
1 G.
Iy l
01300 - 10/24/86 6
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(8)
SPECIAL PROGRAM 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 SQN CSSC List in SQN procedures controlling procurement, maintenance, and modification activities within the Gperations 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 k[
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 SQN CSSC List have not been identified. A review to verify the i
accuracy and completeness of the SQN CSSC List has not yet been l
performed by TVA, and further TVA followup actions related to this element depend on the results of such a review.
l n
01300 - 10/24/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: 0 l
PAGE 12 0F 16 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
10CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion II,
" Quality Assurance Program" b.
Regulatory Guide 1.29, Rev. 2, Seismic Design Classification, (02/76) 1 c.
Regulatory Guide 1.26, Rev. 2, Quality Group Classifications and Standard for Water-Steam, and Radioactive Waste Containino Components of Nuclear Power Plants, (06/75) d.
SNP FSAR, Section 3.2 (Amendment 3), " Classification of Structures, Systems and Components" i
e.
SNP FSAR, Section 17 (Amendment 3), " Quality Assurance" f.
TVA Topical Report TVA, TR75-1 A (Rev. 8), Quality Assurance gR-Program DescriDtion for the Design. Construction, and
[/j(
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 Sequoyah Nuclear Plant Quality Assurance Program J.
SNP Construction Procedure, P-24 (Rev. 6), Inspection and Test Status, (05/07/82) l 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.
Ac Systems and Components (CSSC) List, (01/27/86) 01300 - 10/24/86
TVA EMPLOYEE CDNCERNS REPORT NUMBER: 209.2(8)
SPECIAL PROGRAM REVISION NUM8ER:
0 PAGE 13 0F 16 APPENDIX A (Cont'd) i l
n.
SNP Standard Practice, SQM2, Rev. 20, Maintenance Management System,(09/11/86) o.
SNP Standard Practice, SQA45, Rev. 22, Quality control of i
Material and Parts and Se.rvice, (09/11/86) p.
NSRS Investigation Report I-85-422-W8N, (10/04/85) q.
WBNP NCR No. W-269-P, (08/26/85)
Letter f rom Mills, TVA, to Adensam, NRC, ( A27831107026), "TVA r.
Docket No. 50-327 & 50-328 TVA Response to Items 2.1 and 2.2 of NRC Generic Letter 83-28," (11/07/83)
Letter from 01shinski, NRC, to White, TVA, (L44860429173),
s.
" Report Nos. 50-327/86-11 and 50-328/86-11," (04/22/86) t.
Letter f rom Gridley, TVA, to Grace, NRC, (L44860627800),
Subject:
" Response to Inspection Report 50-307/86-11 and 3,
50-328/86-11," (06/27/86) c.y..
u.
Minutes of SQN CSSC Review Committee Meetings:
Meeting 85-02, (S53 850730 825), (06/26/85)
Meeting 85-03 (S53 851101 980), (09/10/85)
Meeting 85-04, (S53 851203 903), (11/14/85)
Meeting 86-01, (S53 860219 840), (01/14/86)
Meeting 86-02, (S53 860423 814), (04/15/86)
Meeting 86-03, (S53 860514 940), (04/24/86) kt v.
TVA memo from Whitt to Parris, (no R4NS), NSRS Investigation Report I-85-422-W8N, (10/11/85)
NI TVAmemofromHowardtoEnnis,(noR%)," Employee w.
Concern Investigation Report Transmittal Response,"
(12/06/85)
D j
01300 - 10/24/86
.TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: 0 i
PAGE 14 0F 16 o
APPENDIX A (Cont'd) x.
TVA memo from Whitt to Ennis, (No RI S), " Corrective Action Response Evaluation (I-85-422-WBN, Item 2)," (01/08/86)
M y.
TVA memo from Whitt to Ennis, (No RIf5), " Corrective Action Response Evaluation (I-85-422-WBN, Items 1, 3, 4)," (01/08/86) z.
TVA memo f rom Raulston to Gridley, (B45 860306 260),
Final 10CFR50.55(e) Report on NCR W-269-P R1, (03/06/86) 6.
WHAT REGULATIONS. LICENSING C0petITMENTS. DESIGN REOUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA?
10CFR50, Appendix B, Criterion II, " Quality Assurance Program" a.
b.
Regulatory Guide 1.26, Quality Group Classifications and Standards for Vater-Steam. and Radioactive Waste Containing Components of Nuclear Power Plants
- g c.
Regulatory Guide 1.29, Seismic Desian Classification
~>
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 Program DescriDtion for Design. 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, N2G-877, Identification of Structure. Systems, and Components Covered by the Seauoyah Nuclear Plant Quality Assurance Program.
1.
SNP Administrative Instruction, Al-39, Critical Structures.
Systems and Components - (CSSC) j.
SNP Administrative Instruction, AI-19, Part III, " Plant Modifications: Modification Requests," and Part IV, " Plant Modifications: After Licensing" l.rlj 01300 - 10/24/86 5
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 209.2(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 15 0F 16 APPENDIX A (Cont'd) k.
SNP Standard Practice, SQA134, Critical Structure. Systens, and Components (CSSC) List 1.
SNP Standard Practice, SQM2, Maintenance Management System m.
SNP Standard Practice, SQA45, Quality Control of Material and j
Parts and Services i
7.
LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
a.
Request for Information (RFI), SQN-563, (09/15/86) b.
RFI, #SQN 564, (09/15/86) c.
RFI, #SQN 576, (09/18/86) d.
RFI, #SQN 583, (09/22/86) 5; Mg\\!
e.
RFI, #SQN 619, (10/06/86) f.
RFI, # SON 641, (10/16/86) 6 g.
Telecon, L. J. Anderson, Bechtel, with R. W. Fortenberry, TVA,10M-258, (09/18/86)
-2
,(b9/k4 6 f
1.
Telecon, L. J. Anderson, Bechtel, with D. T. Clift, TVA, 10M-273,(09/29/86)
V
[
J.
Telecon, L. J. Anderson, Bechtel, with D. T. Clif t, TVA, 10M-306, (10/09/86) 6j k.
Telecon, L. J. Anderson, Bechtel, with D. T. Clift /R. W.
Fortenberry, TVA, 10M-308, (10/09/86) 01300 - 10/24/06 f
i J'
ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document i
(CATD) l 4
INITIATION 1
1.
Immediate Corrective Action Required: %'Yes O No 2.
Stop Wort Reconenended: O Tes
[ No 1
3.
CATD No.
- 26) 2
- SQd I
a.
INIIIATION DA E 5.
RESPONSIBLE ORGANIZATION:
ONP (ors 24 mas 6.
PRO EN DESCRIPTION: M QR O NQR waaruuu or Wea d GSsc % a+L l&Mbnk h,'UJ St)N css'C % t. u a ruJttd CVAe & A & W M 2rR.sta). x
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.4 O ATTACHMENTS m
7.
PREPARED BY: NAME -d h li. -
J%f DATE: f 'dariru' 8.
CONCURRENCE:
CEG-H, WC/ bu w f M DATE:
//- /-M 9.
APPROVAL: ECTG PR0dlf.AV)GR.
DATE:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
3 4
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
ECTG PROGRAN N R:
DATE:
VERIFICATION AND CLOSE0tfT e
13.
Approved corrective actions
- ave been verified as satisfactorily implemented.
SIGNATURE TITLE DATE l
I i
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