ML20235U249
| ML20235U249 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/25/1987 |
| From: | Brown W, Cossett D, Gass K TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20235U231 | List: |
| References | |
| SQN-NSRS-2, SQN-NSRS-2-R02, SQN-NSRS-2-R2, NUDOCS 8710130424 | |
| Download: ML20235U249 (20) | |
Text
I TVA EMPLOYEE CONCERN REPORT NUMBER: SQiu-NSRS-2 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Subcategory REVISION NUMBER: 2 TITLE: Review of Nuclear Safety Review Staff PAGE 1 OF 17 Restart Items at Sequoyah REASON FOR REVISION: Revised to show current status (July 1987) of the NSRS items at Sequoyah.
SUMMARY
STATEMENT: The 17 items in this report were identified by the Nuclear Safety Review Staff (NSRS) and were assigned to the Employee Concerns Task Group (ECTG) for verification and closure. The verification activities are described in this report.
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Executive Summary SQN-NSRS-2 Review of Nuclear Safety Review Staff (NSRS) Open Items Requiring Resolution at Sequoyah Nuclear Plant (SQN) before Unit 2 Restart.
NSRS conducted reviews of activities at Sequoyah Nuclear Plant (SQN) during F. its span of overview responsibility from 1979 to 1986. NSRS items remaining open in 1987 have been examined by-the Employee Concerns Task Group (ECTG).
ECTG examined the status of open NSRS issues including those identified -
specifically for SQN as well as other sites' issues which could have generic applicability at SQN. In all, a total of 95 issues were considered applicable to SQN including 25 requiring resolution before Unit 2 restart. Eight (8) of the 25 restart issues have been addressed in report SQN-NSRS-1 Rev. 2; the remaining 17 issues are addressed in this report, SQN-NSRS-2, Rev. 2. Seventy (70) of the 95 issues have been considered non-restart issues and are addressed in report SQN-NSRS-3.
The 17 issues discussed in this revised report have been closed by ECTG.
These issues include the following:
R-80-05-SQN-10 Adequacy of Containment to Withstand Tornado Damage R-82-07-WBN-06 Visual Inspection of Welds Through Primer (Reopened by NRC)
R-82-08-NPS-10C Issuing of Directives Contrary to TVA Commitments R-84-07-WBN-1 Pipe Support Calculations Destroyed R-84-17-NPS-10 Commercial Grade Items With QA Level I and II Designations R-84-17-NPS-11 Quality Verification for Commercial Grade Items R-84-17-NPS-12 Receipt Inspection of QA Level I and II Items by Field Quality Engineers R-84-19-VBN-6 Instantaneous Trip Settings of the Breakers for Motor-Operated Valves.
I-84-34-SQN-3 Availability of the Material Certification and Requirements for Heat Number Sort Printout Entries I-85-06-WBN-3 Voltage Drop and Short Circuit Current Determination and Verification w------_-_------- ____x- - - - - - - - _ - _ _ _ _ - - - _
R-85-08-0E/NUC PR-1 ' Inadequate OE Environmental Qualific'ation Procedure
' for Fquipment Qualification by Similarity
.R-85-08-0E/NUC PR-2 Inadeguate OE and NUC PR Procedures for Initiating and Processing NCR-FE/ERs R-85-08-0E/NUC PR-3 Lack of Priority.on SQN NCR Initiation R-85-08-0E/NUC PR-4 Lack of Engineer Awareness of NCR-FE/ER Process R-85-08-0E/NUC PR-5 Lack of Timeliness in Initiating and Processing '
.NCR-FE/ERs j
'. y R-85-08-0E/NUC PR-6 . Failure of Management to Correct Problen.s with Timeliness and Responsiveness Involving the NCR-FE/ER-Process I-86-101-SQN Wire Bend Radius in Installations Using Conax Connectors l
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTliCR SITES CEG l
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l Subcategory: Gequoyah Nuclear Plent - NSRS Classical Items Subcategory: Review of Nuclear Safety Review Staff Restart Items At Sequoyah Report Number: SQN-NSRS-2 Revision 2 l
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I TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 i SPECIAL PROGRAM J REVISION NUMBER: 2 PAGE 2 0F 17 Review of Nuclear Safety Review Staff (NSRS) Open Items Requiring Resolution at Sequoyah Nuclear Plant (SQN) prior to Unit 2 Restart.
I. Introduction NSRS conducted reviews of activities at Sequoyah Nuclear Plant (SON) during its span of overview responsibility from 1979 to 1986. NSRS items.
remaining open in 1987 have been examined by the Employee Concerns Task Group (ECTG). -
ECTG examined the status of open NSRS issues including those identified i specifically for SQN as well as other sites' issues which could have generic applicability at SQN. In all, a total of 95 issues were considered applicable to SQN including 25 requiring resolution prior to Unit 2 restart. Eight (8) of the 25 restart issues have been addressed in report SQN-NSRS-1 Rev. 2; the remaining 17 issues are addressed in this report SQN-NSRS-2, Rev. 2. Seventy (70) of the 95 issues have been considered non-restart issues and are addressed in report SQN-NSRS-3. '
The 17 issues discussed in this. revised report have been closed by ECTG. i Full details concerning the investigation and examination of the items ~
were provided earlier in report SQN-NSRS-01, Rev. 1. Some associated i activities or areas related to the items may in fact still be incomplete.
However, these NSRS items are considered closed because ECTG through the evaluation process, determined that sufficient resources have been l committed to the issues to ensure their satisfactory completion and closure. This confiaence is derived from interviews with cognizant TVA !
personnel and reviews of applicable documentation.
The status of the 17 NSRS restart issues addressed by this report is as follows:
Closed R-80-05-SQN-10 Adequacy of Containment to Withstand j Tornado Damage 1 Closed R-82-07-WBN-06 Visual Inspection of Helds Through Primer 1 i
Closed R-62-08-NPS-10C Issuing of Directives Contrary to TVA I Commitments .
Closed R-84-07-WBN-1 Pipe Support Calculations Destroyed Closed R-84-17-NPS-10 Commercial Grade Items With QA Level I and II Designations ;
Closed R-84-17-NPS-ll Quality Verification for Commercial Grade !
Items I
E A EMPLOYEE CONCERNS' REPORT NUMBER:' SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: .2~
PAGE 3 0F 17 Closed R-84-17-NPS Receipt Inspection of QA Level I and II Items by Fleid Quality Engineers
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Closed R-84-19-WBN-6 Instantaneous Trip Settings of the Breakers for Motor-Operated Valves Closed I-84-34LSQN-3 Availability of the Material Certification -
and Requirements for Heat Number Sort Printout Entries Closed I-85-06-WBN-3 Voltage Drop and Short Circuit Current Determination and Verification closed R-85-08-0E/NUC PR-1 Inadequate OE Environmental Qualification
-Procedure for Equipment Qualification by Similarity ,
1 Closed R-85-08-0E/NUC PR-2 Inadequate OE and NUC PR Procedures for Initiating and Processing NCR-FE/ERs l Closed R-85-08-0E/NUC PR-3 Lack of Priority on SQN NCR Initiation Closed R-85-08-0E/NUC PR-4 Lack of Engineer Awareness of NCR-FE/ER Process Closed R-85-08-0E/NUC PR-5 Lack of Timeliness in Initiating and Processing NCR-FE/ERs Closed R-85-08-0E/NUC PR-6 Failure of Management to Correct Problems with Timeliness and Responsiveness Involving the NCR-FE/ER Process Closed I-86-101-SQN Wire Bend Radius in Installations Using Conax Connectors II. Verification of NSRS Restart Items (Closed) R-80-05-SQN-10, Adecuacy of Containment to Withstand Tornado Damage The NSRS conducted a review of the design of the Sequoyah containment -
to determine if it is adequate to withstand the effect of depressurization and missiles caused by tornados. Specific problem areas identified by the NSRS which appeared to lack adequate tornado depressurization and missile protection were the diesel generator exhaust stacks, and penetration through the' roof. Diesel Generator Building, refueling water storage tank, primary water storage tank, condensate storage tanks, and the 480 volt shutdown transformer rooms-on elevation 749 of the Auxiliary Building.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 17 The Civil Engineering Branch (CEB) reviewed the issue of tornado misslie protection and initiated the following reports.
Assessment of the Tornado Missile Protection at SQN (RIMS 800808 007).
Assessment of the Tornado Protection Criterion for WBN (RIMS 820412 003).
ECTG's investigation involved interviews with design personnel from the Knoxville office and SQN Site. The DNE office stated that tornado depressurization and missile protection had been adequately reviewed and evaluated. The ECTG investigation found the review of the NSRS Historical files substantiated the comments of DNE.
In 1981, all issues involving tornado depressurization and missile protection had been resolved to the satisfaction of NSRS, except for one area concerning vertical missile strikes down the exhaust vent of the containment. This issue has now been resolved by the Civil Engineering Branch (CEB). A missile plate has been installed beneath the opening of the exhaust vent in order to provide protection for equipment installed directly under the vent opening.
Attachment 13 to the CEB report, " Assessment of the Tornado Protection Criterion for WBN" addresses the results of NRC's review of Tornado protection performed in conjunction with the CEB review.
Based on review of file correspondence, ECTG concludes the issue of-tornado missile protection is no longer a concern to the NRC, DNE, or SQN. ECTG further cuncludes this NSRS issue hcs been satisfactorily addressed and is now closed.
(Closed) R-82-07-WBN-06, Visual Inspection of Welds Through Primer The NSRS stated that insufficient documentation existed to substantiate the Watts Bar weld sampling program conducted to verify that visual weld inspections could be made through Carbo zine primer. The NSRS recommended that TVA prepare a report describing the weld sampling program and provide technical justification for inspection through primer. This item was closed February 3, 1984.
The TVA general manager received a letter from a former NSRS member dated November 7, 1985, that questioned the validity of closing the item at Watts Bar. SQN identified this item as generically applicable. ECTG was requested by SQN to review this issue.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM I REVISION NUMBER: 2 l l
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In a recent review of this issue by ECTG at SQN, personal interviews were conducted with QA personnel who confirmed the results of 3 previous analysis by ECTG in report WP-02-SQN-R2. The report stated, j "The conclusion drawn by WP-02-SQN is that no initial acceptance {
inspections were performed on coated welds at SQN." The CAQR tracking system was reviewed for related problems to this issue and none were identified. The NSRS item is closed.
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(Closed) R-82-08-NPS-10C, Issuinr, of Directives Contrary to TVA j Commitments l The NSRS report stated there were no procedural controls established j for the central office preparation, qualification, and issuance of l analytical procedures. No documented qualification of analytical procedures was found before issuance from Nuclear Central Office 1 (NCO) for plant use. ANSI N18.7-1976, paragraph 5.2.15 requires an organization receiving documents for implementation or change, to '
have access to pertinent background information upon which to base j i its approval, and to have an adequate understanding of requirements j and intent of the original document.
l NSRS review of section II of DPM N79E2, Analytical Procedures, found j inconsistencies eristed between what was denoted in NSSS vendor and 1 ASTM procedures, including simple stoichiometry. These inconsistencies involved missing critical variable maintenance precautions, technically incorrect chemical equation balancing, and inadequate analysis technique. No formal record documents had been prepared to establish the fact that the procedures had been tested and qualified before their issuance for implementation.
ECTG's investigation at SQN verified that procedural controls are in place for qualifying and issuing analytical procedures. These controls are required by the NQAM and are implemented through site procedure SQE 22, technical instructions, and technical specifications.
Site procedure SQE 22, "Sequoyah Nuclear Plant Chemistry" reflects the requirements of the Nuclear Quality Assurance Manual (NQAM) and is implemented by approximately 70 procedures (technical instructions and technical specifications).
In addition, major modifications have been made to the count room in an effort to upgrade the water chemistry program. Also, " state of the art" equipment for analyzing ultra pure water has been installed, i
Based on a review of applicable procedures, ECTG concludes this issue I has been satisfactorily addressed and is now closed at SQN. ]
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.TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS SPECIAL PROGRAM' REVISION NUMBER: 2 PAGE 6 0F 17.
(Closed) R-84-07-WBN-1, Pipe Support Calculations Destroyed On April 6, 1984,.The NSRS conducted a special review of NCR WBN-SWP 8303 concerning missing pipe support calculations at Watts Bar Nuclear Plant. NSRS stated that safety-related pipe support-calculations' performed by Energy Data Systems (EDS) Nuclear, Incorporated had been destroyed and that no. quality records existed to document the adequacy.of the pipe supports. NSRS recommended that
- the calculations be recreated and maintained as TVA quality records.
The records status of calculations for EDS-designed supports at SQN needed to be determined.
It was determined that the calculations for some pipe supports at.SQN had also been destroyed. TVA has committed to regenerate the missing calculations. The categories and listings of required calculations and the schedules for their identification and regeneration are identified in the Sequoyah Civil Discipline Calculation Action Plan outlined in a November 13, 1986 memorandum. A technical. supervisor in SQN Division of Nuclear Engineering (DNE) Civil Engineering Branch (CEB) stated that the missing pipe support calculations are being regenerated as part of the above plan.
This issue was the. subject of ECTG's Engineering Category Report 205.01 SQN. The corrective action is being tracked by CATDs )
205.01-SQN-01 and 02 as indicated in the' approved Corrective Action l Plan (CAP). In addition, this issue has been addressed on the l Sequoyah P2 schedule by item number 11417. It has also been addressed by the Sequoyah Nuclear Performance Plan (NPP). Sequoyah l Action List (SAL) number 955. -Adequate corrective action for the L NSRS issue will be provided by closure of these CATDs. This NSRS issue is closed.
(Cirsed) R-84-17-NPS-10, Commercial Grado' Items With OA Level I and II Designation The NSRS investigation of this issue verified that TVA purchased commercial grade items from vendors lacking a QA program and had assigned the equipment a quality rating. In order for TVA to assign j a quality rating, the equipment should have been upgraded through ]
testing or receipt inspection, but this was not always done. .These items may have been used in a safety-related function. TVA should ensure that all equipment rated as QA level I be purchased from a vendor with an appropriate QA program or that equipment rated as QA level II be upgraded by'TVA through receipt inspection or testing.
ECTG's evaluation of the issue verified that SQN has a program for the commercial grade dedication of components'(those components- 1 purchased as QA' Level II). This conclusion was drawn as a result of interviews with site personnel and reviews of site procedures. ,
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 17 The supervisor of the Contract Engineering Group (CEG) stated that procedure SQA-45, Section 27, titled " General Comercial Grade Dedication Program Requirements" provides guidelines for implementing the relevant sections of the Nuclear Quality Assurance Manual (NQAM).
Administrative procedure AI-11 " Receipt Inspection Nonconforming Items, QA Level / Description Changes and Substitutions" is consistent with ANSI N45.2.
Procedure QMI 710.2 Revision 0, " Inspection Plans" and QMI 710.3.
Revision 0, " Inspection Reports" provide instructions for the l
engineering staff to develop receipt inspection plans for procuring l
items.
The issue is also being addressed and tracked in the Nuclear Performance Plan (NPP) by Sequoyah Action List (SAL) number 657.
Based on a review of applicable procedures and interviews with plant i personnel, this issue has been satisfactorily addressed. This NSRS issue is closed.
(Closed) R-84-17-NPS-11, Quality Verification for Commercial Grade l Items ]
l In the original review, NSRS concluded that the use of commercial grade items as basic components, placed solely upon TVA the j responsibility for ensuring that the item would function as intended {
under all conditions. The QA program within TVA was not capable of 1 providing that assurance because it did not include a receipt i inspection program which included testing of the item or comparable 1 mechanisms such as an audit of the vendor's QA program for commercial I grade items.
NSRS recommended that ONP should establish a receipt inspection program which included testing (or comparable mechanisms such as audit of vendor's QA program, verification of certification of conformance, etc.) for replacement commercial grade items that would be dedicated as basic components or parts. This would provide documented assurance that the items would function as intended -
including accident conditions.
ECTG's investigation at SQN verified that the QA program is capable of providing assurance that a QA level II item would function as intended under design basis conditions. The SQN QA program provides a receipt inspection program which involves testing the individual items or an audit of the vendor's QA program for QA level I items.
Based on the verification of the present QA program, ECTG concludes this issue has been satisfactorily addressed and is closed at SQN.
l TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 8 0F 17 (Closed) R-84-17-NPS-12, Receipt Inspection of 0A Levels I and II Items by Field Quality Engineers (F0E)
From the NSRS review of procurement practices and procedures for operating nuclear power plants, NSRS concluded the following:
Considering the changes recommended by NSRS in this report with regard to the procurement of QA levels I and II material and commercial grade items to be dedicated as basic components, the division of receipt inspections between Field Quality Engineering (FQE) and Power Stores, in effect during this review, would be inadeguate.
NSRS recommended that all items procured as QA Level I and II and commercial grade items to be dedicated as basic components should be I receipt inspected by Field Quality Engineers or others qualified to I ANSI N45.2.6.
ECTG's investigation at SQN verified that the receipt inspection of all items procured as QA Level I and QA Level II (commercial grade dedicated) are inspected by quality assurance personnel who are 1 qualified to ANSI N45.2. d Based on verification of present conditions, ECTG concludes that this i issue has been satisfactorily addressed. This NSRS issue is closed.
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l' (Closed) R-84-19-WBN-6, Instantaneous Trip Settings Of The Breakers For Motor-0perated Valves The NSRS report stated that the instantaneous trip settings of' breakerb for motor-operated valves were set too high at WBN. If breaker trips are set too high, the circuit that breaker is protecting may be damaged. SQN needs to ensure that the instantaneous trip settings at SQN are in agreement with the National j Electrical Code (NEC) as required by TVA design standard E.9.2.1 or I other appropriate standards.
The NSRS recommended that SQN verify that instantaneous trip settings for MOV Breakers agree with the intent of the NEC. The documentation for the design as well as for the testing and operations of equipment should reflect the proper values. The program should be implemented TVA wide, i l
ECTG's investigation involved an interview with the acting electrical ;
lead engineer in the Division of Nuclear Engineering (DNE) at the SQN plant. He stated that the breakers used for motor operated valves (MOV) at SQN do not have adjustable instantaneous trip settings. He further stated that the instantaneous trips on breakers insta11ed'in motor control center (MCC) are pre-set by the vendor and are.not adjustable.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 17 Based on interviews with DNE personnel, ECTG concludes this issue does not apply to SQN. This NSRS issue is closed.
(Closed) I-84-34-SQN-03, Availability Of The Material Certification And Requirements For Heat Number Sort Printout Entries This March 15, 1985., NSRS report stated that there appeared to he inconsistencies in the compilation of required material certification and some ambiguity in the program established to control it.
Specifically, NSRS could not conclude with certainity that the SQN Heat Number Sort Printout included only material with acceptable certification. NSRS recommended that a history of the Heat Number Sort be reconstructed to establish the program's purposes, controls, designed functions, actual functions, and data quality.
The evaluation of the Seguoyah Nuclear Plant (SQN), Construction Heat Code ProgreJn was performed due to recommendations contained in the Nuclear Safety Review Staff (NSRS) Report number I-84-34-SQN as follows:
"Therefore, it is NSRS's recommendation that a search of documents / files / procedures be made so that a history of the Heat Number Sort can be reconstructed to include the following:
(1) The purpose / reason the Heat Number Sort was generated.
(2) Those management controls designed and implemented to administer the program.
(3) The function the program was designed to serve and the l function it has been serving, if different.
l (4) The confidence DC (Office of Construction) management has l with the available information in the program (Heat Number I Sort printout)."
l This evaluation was t.lso performed due to a Watts Bar Nuclear Plant l (WBN) Employee Concerns Task Group (ECTG) report " Material Control, l procedural Control. Heat Code'. Report number MC 40703 was prepared !
for WBN and made generic to other TVA Nuclear Plant Sites, including SQN.
The findings of the ECTG investigation substantiated the above referenced concern, and in response, the Division of Nuclear Engineering (DNE) established a Heat Code Traceability Task Group (HCTTG) with responsibility to determine the extent of the findings and recommend a corrective action plan.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 17 The recommendation made by NSRS has been evaluated by the ECTG (Report 407.03 SQN R2) and again by the HCTTG (Executive report A02870428034 dated April 21, 1987). A further independent assessment l of the two evaluations was performed by two nationally recognized I experts in the areas of Quality Assurance and Code Material l applications for nuclear power plant construction, Richard B. Kelly, IR2 Vice President and Director of Quality Assurance, Stone & Webester 1 Engineering Services, and Don F. Landers, President, Teledyne l Engineering Services. I HCTTG and ECTG could not reach an agreement regarding the extent of required corrective actions necessary to resolve this concern. In accordance with the Nuclear Performance Plan and ECTGs program manual, this issue was escalated to the Manager of Nuclear Power.
Resolution was received from the manager of nuclear power in memorandum A02870428 034 dated May 4, 1987. The following nine CATDs were issued to replace the original one CATD (No 40703-SQN-01-R1) for Employee Concerns Report MC-40703-SQN:
CATD No. 40703-SQN-01-R2 CATD No. 40703-SQN-03-R0 CATD No. 40703-SQN-02-R0 CATD No. 40703-SQN-06-RO CATD No. 40703-SQN-07-R0 CATD No. 40703-SQN-04-R0 CATD No. 40703-SQN-05-R0 CATD No. 40703-SQN-08-R0 CATD No. 40703-SQN-09-R0 The executive report transmitted May 4, 1987 stated the following corrective action documents, addressed by the 9 CATDs, would correct the problem:
PIRSQNNEB8638, CAQR SQP870627, CAR-86-064, SCRSQNMEB8614 R1 and ECN L6784, AND PIRSQNMEB8793.
Revision 2 of the ECTG report MC-40703-SQN, dated May 12, 1987 stated that ECTG materials evaluators were not in agreement with the Corrective plans.
This item is on the P-2 schedule Bar chart, run 14 July 87 22:34 as a restart item. SWEC/NSRS has determined that this issue has been reviewed by senior management, and currently remains in ECTG and SQN j line tracking systems for corrective action. Tracking with the NSRS ;
issue is now redundant. This NSRS item is therefore closed.
(Closed) I-85-06-WBN-3, Voltare Drop and Short Circuit Current Determination The description of the deficiency as addressed in SCR WBN EEB 8571 j stated the following:
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 l SPECIAL PROGRAM l REVISION NUMBER: 2 l l
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The Watts Bar Nuclear Plant (WBN) INP0 review and TVA's Office of l' Quality Assurance audit identified specific electrical design calculations that had not been evaluated end documsnted, Becouco of these findings / deviations, problem identification reports (PIRs) WBN EEB 8527 and WBN EEB 8528 were initiated to correct the problems. In pursuing the corrective actions to resolve the PIRs, it was discovered that other calculations were missing.
Significant condition report (SCR) WBN EEB 8571 was written to lR2 i address the fact that for WBN, TVA had failed to identify the j minimum set of electrical calculations (calculations on l safety-related systems required to shutdown the plant), to revise existing calculations to incorporate subsequent design changes, and had issued design documents and drawings without preparing or before completing supporting calculations. These calculations are necessary to ensure technical adequacy and compliance with plant )
design basis. Affected systems include: auxiliary and control j power distribution, communications, instrument and control, !
lighting, raceway, switchyard and transformers.
I The condition resu3ted primarily from inadequately defined requirements to document supporting design calculations and studies. Those calculations that were formalized were not updated to support document and drawing revisions.
1 In NSRS report number I-85-06-WBN-3, the NSRS recommended that OE !
should perform short circuit and voltage drop calculations for the Level 3 power circuits to ensure the adequacy of the size of the installed cable to perform its intended functions. NSRS stated that ,
this recommendation was applicable to SQN and was identified by SCR l number SQN EEB 8527.
The SQN plant has implemented a number of policies and methods through the site engineering procedure SQEP-09, " Change Review lR2 Checklist for Electrical Calculations" to ensure the required calculations are performed and properly documented. The SQEP-09 l procedure provides definition of the minimum set of required l calculations as well as controls, review processes, and documentation IR2 requirements for the calculations. l The Assistant Chief Electrical Engineer at Knoxville stated that the electrical calculations for supporting SQN re-start have been performed. There are 576 calculations in the electrical calculations log at SQN that are being tracked in the Calculation Cross Reference Information System (CCRIS), all of which are given records information management system (RIMS) numbers. The CCRIS was made a Quality Assurance Record as of July 1, 1987.
TVA EMPLOYEE CONCERNS -REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 12 0F 17 The procedure methods (previously issued as policy memorandum) are quality assurance records and may therefore be audited to ensure they are being implemented.
These documents include:
Procedure Method PM86-24) (EEB), "EEB Design Control Process"
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The purpose of this document is, "to establish branch overall approach to be used in standardizing and controlling the EEB design process from both administrative and technical standpoints."
Policy Memorandam, PM86-15 (EEB), " Electrical Calculations Checklists," August 6,1986. The purpose of this memorandum is to l
establish branch policy regarding the documentation of the status of electrical calculations at SQN, 'IBN, and BFN. Policy Memorandum-PM86-02 (EED), Electrical Calculations," May 8,1986.- The purpose of this memorandum is to establish branch policy regarding the performance of electrical calculations for BFN, SQN, WBN, and BFN.
Based on verifications of present conditions, ECTG concludes this issue has been satisfactory addressed and is closed at SQN.
(Closed) R-85-08-0E/NUC PR-01. Inadeounte OE Environmental Qualification Procedure for Equipment Qualification by Similarity i
NSRS stated that the OE procedure EN DES SEP 82-11 for environmental qualification of SQN electrical equipment allowed qualification by
" similarity" but contained no definite criteria defining what constituted a "similar" item. NSRS recommended that these criteria be established and incorporated into the TVA procedures governing environmental qualification of electrical equipment, and that the criteria be used to re-evaluate the qualification status"of electrical equipment previously qualified by similarity.
l EQ requirements, including those for qualifying by similarity, are i now included in Office of Engineering discipline interface document IR2 NEB-DI-125.01 " Program Requirements for Environmental Qualification I of Electrical Equipment in Harsh Environment." l Additionally, ECTG's investigation of this issue confirms that the lR2 y SQN Environmental Qualification Project Manual (EQPM), Appendix 2B l addresses qualification by similarity and provides general guidance on important aspects of equipment environmental qualification. This guidance is used in conjunction with the qualification checksheets in the E.Q. Binder, Tab B.
3E. sed on a review of the EQPM, ECTG concludes that this issue has been satisfactorily addressed. ,!
This NSRS issue is closed. l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 (
PAGE 13 0F 17 (Closed) R-85-08-0E/NUC PR-02, Inadequate OE and NUC PR Procedures for Initiating and Processing
- Nonconforming Conditions Reports, Failure Evaluations. and Engineering Reports (NCR-FE/ERs) {
l NSRS concluded that the OE and ONP procedures for processing j nonconforming conditions reports (NCRs), failure evaluations (FEs), j and engineering reports (ERs) were inadeguate to ensure timely 1 initiation and processing. NSRS recommended in-depth review of TVAs ]'
program and possible changes to provide for effective interface between participating TVA organizations, establishment of centralized tracking, and significant reduction in the time required for ,
processing and dispositioning. l l
TVA's commitment to provide effective and timely corrective action f for a CAQ, including action involving multiple organizations, is described in the SQN Nuclear Performance Plan (July 17, 1986),
section II.2.5. l ECTG verified that revised procedures for the handling of CAQs have IR2 been issued as follows:
l SQN site procedure SQA118 " Handling of Nonconformance Reports or Conditions Adverse to Quality Received from Office of Engineering" (Revision 0, dated October 20, 1986)
Division of Nuclear Engineering Procedure NEP 9.1, " Corrective i Action" (Revision 0, July 1, 1986) l l
SQN Administrative Instruction AI-12 " Corrective Action" lR2 These procedures include provisions for the issues addressed in this NSRS item, as follows:
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Prompt preliminary evaluation to make assessment of potential safety significance Priority for identification and processing of operating plant CAQs Ilmely coordination between DNE and the site organizations Prompt notification of either the Site Director or Plant Manager as an initial step toward resolution of CAQs that present an immediate threat to health and safety Use of the Tracking and Reporting of Open Items (TROI) system as l the central system for tracking and trending information on IR2 conditions adverse to quality l
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l TVA 3MPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 l SPECIAL PROGRAM l REVISION NUMBER: 2 !
I PAGE 14 0F 17 Recent ECTG investigations have determined that the CAQ program is 1 receiving a high level of management attention. Managers are l demanding corrective actions in a timely manner, and are strongly l supporting this effort by conducting daily meetings with section ;
representatives. The CAQRs are also being tracked by the quality assurance section.
Based on the review of applicable procedures and the recent reviews ;
of the issue performed by ECTG, this issue has been satisfactorily )
addressed and is now closed. J (Closed) R-85-00-0E/NUC PR-03, Lack of Priority on SON NCR Initiation 4
The NSRS stated that a time period of approximately two months elapsed between the time the assignment was made to evaluate the adequacy of accuracies of the SQN containment pressure differential transmitters (CPDTs) until the NCR was issued. It was recommended that OE define and document a policy to ensure that operating plants are afforded the proper priority regarding work activities related to safety and quality. The policy should be effectively communicated to all levels of OE management and employees, and reemphasized periodically.
ECTG's investigation involved reviews of site documents and interviews with site personnel.
Procedures NEP 9.1, " Corrective Action," SQEP-6.1 " Handling of IR2 Conditions Adverse to Quality Reports (CAQRs), and AI-12 " Corrective Action" adequately address the CAQ program requirements and define IR2 l the policy that ensures operating plants are afforded the proper l l priority regarding work activities related to safety and quality.
General employee training GET 004, " Introduction to Quality Assurance / Quality Control" provides training for new employees in the
! CAQ program.
Interviews with site personnel indicate that site managers hold daily meetings to discuss the CAQ program status.
l Based on the reviews of applicable procedures and interviews with j site personnel, ECTG concludes this issue has been addressed.
This NSRS issue is closed.
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-TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL. PROGRAM REVISION NUMBER: 2 j l
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(Closed) R-85-08-0E/NUC PR-04, Lack of Engineer Awareness of the
_NCR-FE/ER Process The NSRS investigation concluded that some OE engineers were j unfamiliar with the process as a whole and the allowable timeframes for processing NCRs, FEs, and ERs. NSRS recommended establishment of
.a formal and effective training program on the OE procedures for initiating and processing NCR-FE/ERs.
ECTG's investigation involved reviews of site documents and.
interviews with site personnel.
Procedures NEP 9.1, " Corrective Action," SQEP-61 " Handling of-Conditions Adverse to Quality Reports (CAQR), and AI-12 " Corrective Action" adequately address the CAQ program requirements and define i the policy tha*. ensures operating plants are afforded the proper ,l priority regaralng-work activities related to safety and quality. ]
1 CAQ program training has been provided at all sites and for offsite I support organizations in accordance with the CAQ training i requirements identified'in the NQAM, Section 21.0 " Implementation -IR2 Requirements." l General employee training GET 004, " Introduction to Quality Assurance / Quality Control" provides training for new employees in the CAQ program.
Interviews with site personnel indicate that site managers hold daily meetings to discuss the CAQ program status.-
Based on reviews of applicable procedures and interviews with site .
personnel, ECTG concludes this issue has been satisfactorily 1 addressed. This NSRS issue is closed. )
l (Closed) R-85-08-0E/NUC PR-05, Lack of Timeliness in Initiating and l Processing Nonconforming Conditions Report - Failure Evaluations Engineering Reports (NCR-FE/ERs) j The NSRS stated that NCR SCRNEB8501 was not processed by Office of lR2 Engineering (OE) within the timeframes specified by established -
procedures. Additionally, NSRS stated that OE frequently exceeded l the specified time requirements for processing NCR-FE/ERs. It was l I
recommended that the necessity of compliance with NCR-FE/ER initiating and processing requirements be emphasized to all involved
, OE employees. j l
ECTG reviewed the NSRS report, current commitment in the SQN Nuclear J Performance Plan concerning the corrective action process, Nuclear Quality. Assurance Manual (NQAM) requirements, the Division of Nuclear 1 Engineering implementing procedures, and Administrative Instructions at SQN.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 SPECIAL PROGRAM REVISION NUMBER: 2 I
PAGE 16 0F 17 Interviews were conducted with SQN upper management, to include DNE, Office of Nuclear Power (ONP), and QA personnel with regard to the Conditions Adverse to Quality (CAQ) program.
TVA's commitment to timely and effective corrective actions are outlined in the Nuclear Performance Plan, Volume I Section VI, Revision 4, and are documented in the NQAM, Part I Section 2.16.
The NQAM section establishes timeliness requirements and describes a ;
process of escalating for failure to comply. CAQ timeliness will be l tracked by TROI, and overdue items will be tagged for management attention. Auditing data concerning the new program's adequacy is not yet available because of the program's recency. Based on the initiation of the CAQ program, including commitments, documentation, training, tracking, and reporting / auditing provisions, this NSRS item is closed.
(Closed) R-85-08-0E/NUC PR-06, Failure of Management to Correct Problems with Timeliness and Responsiveness Involving the NCR-FE/ER l Process l l
In the August 1985 report, NSRS concluded that problems with l timeliness and responsiveness in identifying, documenting, and I correcting nonconforming conditions adverse to quality had been l identified by audit organizations and recognized by TVA management as a problem as far back as 1980, but were yet to be corrected. NSRS recommended that improved management controls be established and that the audit activities be intensified in the areas of NCR-FE/ER procedural compliance.
ECTG reviewed the NSRS report, current commitment in the SQN Nuclear Performance Plan (NPP) concerning the corrective action process, Nuclear Quality Assurance Manual (NQAM) requirements, the Division of Nuclear Engineering (DNE) implementing procedures, and Administrative Instructions at SQN.
Interviews were conducted with SQN upper management, to include DNE, Office of Nuclear Power (ONP), and Quality Assurance (QA) personnel with regard to the Conditions Adverse to Quality (CAQ) program.
TVA's commitments to timely and effective corrective action are outlined in the Nuclear Performance Plan, Volume I,Section VI, Revision 4, and are documented in the NQAM, Part I, Section 2.16. The NQAM section establishes timeliness requirements and describes a process of escalation for failure to comply. The CAQ timeliness will be tracked by Tracking and Reporting of Open Items (TROI), and overdue items will be tagged for management attention. Interv3ews with site personnel indicate that site managers hold daily meeting to discuss the CAQ program status. Auditing data concerning the new program's adequacy is not yet available because of the program's recency. Based on the initiation of the CAQ program, including commitments, documentation, training, tracking, and reporting / auditing provisions, the NSRS item is closed.
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1 TVA EMPLOYEE CONCERNS REPORT NUMBER: SQN-NSRS-2 l SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 17 0F 17 i
1 (Closed) I-86-101-SQN, Wire Bend Radius In Installation Usinr. Conax Connectors
- ,1 The NSRS investigation revealed that conax connectors in the containment did not always meet vendor wire bend radius requirements;.
connector installations with deficiencies were inspected and accepted i by SQN'QC; no' action was taken by SQN QC management to investigate or document the deficiencies. i ECTG's review of the issue verified that work requests (WRs) were initiated in mid-1986 to correct problems found during the i verification activities. There were approximately 120 WRs initiated i with work being completed late in 1986. The WRs have been held by i 4
Electrical Modifications because of environmental qualifications (10 CFR 50.49) reporting. They are being transmitted via planning and scheduling to quality engineering for inspection.
ECTG concludes this issue has been satisfactorily addressed and is i now closed.
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