ML20236B914
ML20236B914 | |
Person / Time | |
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Site: | Sequoyah ![]() |
Issue date: | 09/28/1987 |
From: | Belisle G, Russell Gibbs, Julian C, Moore L, Runyan M, Shannon M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20236B848 | List: |
References | |
50-327-87-55, 50-328-87-55, NUDOCS 8710260405 | |
Download: ML20236B914 (20) | |
See also: IR 05000327/1987055
Text
{{#Wiki_filter:' [[km 8 Ecog}o NUCLEAR REGULATORY COMMISSION ' I UNITED STATES . REGloN il n 5 ,j 101 MARIETTA STREET, N.W. ATLANTA, GEORGI A 30323 !
\\*****p'e Report Nos.: 50-327/87-55 and 50-328/87-55 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 1 Docket Nos.- 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 ) Facility Name: Sequoyah 1 and 2 Inspection Conducted: August 10-14 and August 17-20, 1987 j . Inspectors: c4 7 G. A,'8 li le, Tead Inspector Date Signed - ~L<
- [[h 7 R. D. Gibb / D' ate ' Signed ~ . Y 7 j 0 1 L. R. Moore D'a'te Signed ' 'V ' ,) 9NS 07 uw M. F. Runyan ( Date Signed [8 /$e-z1 I s h M. C. Shanno'n" ' ~9b$7 Date Sig'ned b~ h D Approved by: ' C. A. Julian, Ch N f <0 ate Mgned' Operations Branch' Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted in the areas of licensee action on previously identi fied enforcement matters, corrective actions, and licensee action on presiously identified inspection findings. Results: No violations or deviations were identified, ho 7 D G ___ _ _ _ _ _ _ - _ _ _ - _ _ _ _ - _ _
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. . . i i 1 REPORT DETAILS l ! 1. Persons Contacted 1 Licensee Employees ) M. Ali, Technical Supervisor, Division of Nuclear Engineering !
- T. Arney, Assistant Director of Nuclear Quality Assurance
W. Aslinger, Quality Assurance Specialist B. Ballard, Assistant to the Director, Division of Nuclear Quality- Assurance B. Brown, Assistant to the Lead Mechanical Engineer, Mechanical Engineering Branch R. Bryan, Staff Specialist, Nuclear Engineering Branch T. Burdette, Tennessee Valley Authority Managers Office D. Butler, Site Quality Assurance _0ffice W. Carson, Principle Engineer, Division of Nuclear Engineering L. Chacon, Civil Engineer, Technical Supervisor a A. Chakraberti, Electrical Engineer l I l S. Childers, Supervisor, Operations Procedures Group l
- M. Cooper, Site Licensing
i S. Crowe, Site Quality Control Supervisor { B. Eaton, Conditions Adverse to Quality Coordinator, Division of Nuclear , l Engineering 1 ' T. Flippo, Site Quality Control Supervisor ) J. Fox, Power Stores ! S. Fried, Bechtel Consultant, Division of Nuclear Engineering l T. Frizzell, Chief, Quality and Systems Management Branch l K. Gawthaman, Nuclear Engineering Branch
- M. Harding, Site Licensing
B. Harris, Mechanical Engineer, Modifications Group
- T. Horst, Site Operations
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- T. Howard, Quality Control Supervisor
j S. Jackson, Mechanical Engineering Branch i
- S. Johnson, Manager, Site Quality Assurance, Bellefonte
i R. Jones, Quality Assurance Assessment Engineer i B. Kagay, Lead Engineer, Civil Engineering Branch l L. Katcham, Principle Engineer, Civil Engineering Branch 1 l !
- N. Kazanas, Director, Division of Nuclear Quality Assurance
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- G. Kirk, Site Licensing
j C. Lafeber, Instrument Maintenance j
- J.
Lapoint, Deputy Site Director j E. Law, Chief, Quality Systems Branch, Division of Nuclear Quality ' Assurance J. Lewis, Principle Inservice Inspection Engineer J. Maddox, Project Administration Supervisor l i
- ,l 1 . , . 1 2 j l 0. Manez,. Mechanical Engineer i
- L. Martin, Site Quality Assurance Manager
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- C. Mason, Assistant Manager, Office of Nuclear Power
1 i 3. Mcdonald, Quality Assurance Engineering Associate R. McKay, Site Directors Staff
- E. McKeowen, Site Licensing
i ' P,. Mooney, Supervisor, Systems' Engineering D. Moore, Systems Engineer A. Nakashima, Project Engineer
- L. Nobles, Plant' Manager
. S. Orr, Nuclear Engineer, Division of Nuclear Engineering ' P. Perez, Section Supervisor, Engineering Services S. Patel, Principle Engineer, Pipe Supports L. Phillips, Conditions Adverse.to Quality Coordinator, Mechanical . Engineering Branch 1 ) R. Proffitt, Site Licensing L. Rather, Principle Engineer, Structures
- A. Ritter, Engineering Assurance
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- H. Rogers, Plant Operations Review Staff
D. Rudder, Administrative Assistant T. Sanders, Mechanical Engineer ! Q. Seals, Nuclear Engineer ] , l 1
- E. Sliger, Project Manager
l W. Smathers, Lead Civil Engineer, Division of Nuclear Engineering j l J. Smith, Nuclear Engineer l R. Smith, Quality Improvement Supervisor l J. Stapelton, Nuclear Engineering Branch !
- J. Sullivan, Plant Operations Review Staff
1 A. Thomas, Materials Specialist l B. Tompkins, Design Engineering Associate l
- P.
Trudel, Bechtel Consultant A. Varner, Quality Engineering Unit Supervisor l B. Voge, Training Specialist, Audit and Surveillance Training Unit L. Wheeler, Materials and Procurement Services Supervisor
- C. WFittemore, Site Licensing
- W. Wilburn, Sequoyah Maintenance
J. Wright, Supervisor, Mechanical Engineering Branch , P. Zaloum, Mechanical Engineer ' E. Ziauari, Electrical Engineer Other licensee employees contacted included office personnel. NRC Resident Inspectors
- K. Jenison
P. Harnon D. Loveless K. Poertner M. Brar,ch
- AttendeJ exit interview
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. . . . ' . 3 Abbreviat'ons CAQ C=aitions Adverse to Quality CAQR Conditions Adverse to Quality Report (After February 23,1987) CAR Corrective Action Request CCS Component Cooling System DC Direct Current DNE Division of Nuclear Engineering DR Discrepancy Report EQ Environmental Qualification i HVAC Heating Ventilation and Air Conditioning JC0 Justification for Continued Operations NCR Nonconformance Report NOS. Numbers NRC Nuclear Regulatory Commission PIR Problem Identification Report PORC Plant Operations Review Committee P0RS Plant Operations Review Staff' I QA Quality Assurance .
l SCR Significant Condition Report SI Surveillance Instruction ' TROI Tracking and Reporting of Open Items j i i TVA Tennessee Valley Authority WP Work Plan i 2. Exit Interview j i The inspection scope and findings were summarized on August 20, 1987, with l l those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. No i dissenting comments were received from the licensee. ! I The licensee did not identify as proprietary any of the materials provided 1 to or reviewed by the inspectors during this inspection. 3. Licensee Action on Previous Enforcement Matte s (92702) . I a. (Closed) Severity Level IV Violation 327, 328/82-16-01: Failure to i Take Prompt Corrective Action for QA Audic Findings. ! b. (Closed) Severity Level IV Violation 327, 328/83-27-01: Failure to Correct Conditions Adverse to Quality In A Timely Manner. l l . 1 c. (Closed) Severity Level IV Violation 327, 326/6F D N - Failure M i Respond to Audits Within Required Timeframes. l ' l d. (Closed) Severity Level IV Violation 327, 328/85-04-01: Failure to Correct Conditions Adverse to Quality Promptly. , i 3 I '! I . a
_ _ _ - _ _ __ _ _ _ _ . . . . . 4 Licensee responses dated September 21, 1982, February 15, February 22, April 25, and May 31, 1984, and April 24, 1985, were individually considered acceptable to Region II. However, generic implications consistently identified corrective action problems. Additionally, NRC Inspection Report Nos. 50-327, 328/86-53 identified additional problems in this same area. TVA implemented a CAQ program at Sequoyah on February 23, 1987. Prior to this program, CAQs were identified by multiple mechanisms. The CAQ program is defined by the Nuclear Quality Assurance Program (NQAM), Part 1, Section 2.16, Corrective Action, Revision 3. These requirements are implemented on site by AI-12, Part II, Adverse Conditions and Corrective Actions, dated February 20, 1987, and NEP-9.1, Corrective Action, dated February 20, 1987. Items identified prior to February 23, 1987, are administratively controlled by AI-12, Part I, Corrective Action, Revision 0. Due to extensive organizational, program, and management changes since 1982, the specific corrective actions for these items (except for those identified in NRC Inspection Report Nos. 50-327,328/86-53) are no longer directly applicable or the individual items have been corrected as stated in the licensee's responses. The generic applicability related to inadequate corrective action was addressed by TVA in their Corporate and Sequoyah Nuclear Performance Plans and by implementing the CAQ program. Previous inspections have been performed on the CAQ program and are documented in NRC Inspection Report Nos. 50-327, 328/87-09, 87-16, 87-25, and 87-26. The inspector specifically reviewed the corrective action for audit findings that were identified to have not been corrected promptly, in NRC Inspection Report Nos. 50-327, 328/86-53. Current status indicated that Audit Findings QSQ-A-84-0014(02), QSS-A-84-0011(02), QSS-A-85-0006(03), and QSS-A-86-0001(02) have been resolved. Audit Finding QSS-A-86-0001(01) remains to be resolved; however, this finding has been categorized as inactive due to the long time required for resolution. This management decision is documented in Quarterly Corrective Action Meeting minutes dated March 20, 1987 (L17 870414 802). The inspector also reviewed Audit SQ-A-87-0016 (TS), Correction of Deficiencies, which was conducted June 12-30, 1987, and was issued on July 29, 1987. This audit did not review the CAQR process since this process had been recently implemented (February 1987), and other multiple reviews had been performed. Additional information on these reviews is discussed in paragraph 5.
, 4 , t ' ,r , , ., . 5 0 - 4. Unresolved. Items 'i Unresolved items were'not identified during this inspection.
' 5. General' . TVA .'has peEformed : multiple ~ reviews related .to the CAQ.' program since: . ' program. implemention 'on February.23, 1987. .These include aJ March 18, .1987, review conducted _ by ' TVA personnel from . the -.Managerst .of fice; ..a - June. 3,1987,: review conducted' by TVA personnel from the Nuclear Quality Assurance and Evaluation Branch; : Quality Systems Branch, Engineering 4 Assurance, and Nuclear ~ Managers Review Group -.(L17 870603 800),' 'andi a-' i June 16, 1987, review conducted by TVA personnel from the Quality SystemsL Branch (L16 870616 800). - The . inspector closely; surveyed uthe June L16, . , 1987, recommendations and conclusions since -this review .. . speci fically - stated that. the CAQ program- was not being adequately? 1mplemented at Sequoyah, and that unless expeditious corrective action was. taken, . the.; Unit 2 startup schedule may be affected. 'The conclusion also stated that' the primary cause was the lack of'line and QA management attention. . Other ' 1 contributing causes were also_ delineated. Sequoyah management responded. to this review's recommendations on July 23,1987.(503.870721850)._' The ~ inspector verified that corrective actions were being taken and either had been completed or_were,in the. completion process. Since the CAQ program impl'ementation in February 1987, approximately:1300 CAQRs have been opened, and approximately 750 CAQRs had been closed at the Lj time of this inspection. Conclusion This inspection concluded that the CAQ program is receiving concentrated- upper level management attention. Corrective action . for CAQRs is' being vigorously pursued at all levels; however, significant CAQR; resolution for Unit 2 startup activities and multiple problems with CAQR processing _still- need additional attention. 6. Corrective Action Program (92720) a. Conditions Adverse to Quality Reports The adequacy of the CAQR process was. assessed by reviewing 'a large
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- sample of open and. closed CAQRs. Greater emphasis was placed on the 1 - quality and progress of corrective action thanon strict adherenceito- d procedural details. The review concentrated on 'significant CAQRs'
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and, due to the current management emphasis, on items idertified as.. required for the restart of Unit 2. . 1 .) 1 . _ _ _ =-
_ - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ ._ -_ 4 . 6 Each CAQR was examined for the following elements: - adequacy of problem statement - appropriateness of significant-nonsignificant determination and whether various reviews are needed - generic reviews - root cause analyses recurrence control actions - - adequacy and timely progress of corrective action - determinations for operability and deportability - 10 CFR 21 evaluations JCOs - - justification for CAQR closure On August 10, 1987, IROI indicated that only three significant CAQRs (SQN 871096, SQP 870080, SQP 870247) were closed. Each of these CAQRs was reviewed. The inspector questioned the validity of closure for SQP 870247, which documented contamination problems with both the Turbine Building Sump radiation . monitor and Waste Disposal Liquid Effluent radiation monitor. Corrective action (a procedure for backflushing the detector) was taken only for the Waste Disposal Liquid Effluent radiation monitor. The licensee stated that Turbine Building Sump radiation monitor should not have been added to the CAQR and that contamination of this detector would be significantly decreased as a result of recent repairs to steam generator . tube leaks. This explanation appeared reasonable, but should have been documented in the CAQR. The closure of SQP 870080 was an example of what the inspector perceived throughout the inspection, as a tendency to close items by cancelling long-term corrective actions. In this CAQR, a fire damper was discovered nonfunctional, and the interim corrective action was a roving fire watch to check dampers once per shift. The proposed long-term action to install a removable screen on the back of the damper frame to prevent unauthorized manipulation was cancelled and the CAQR was closed on the basis of the roving watch,
, > . . .. . l n I 7 ( l , The inspector reviewed l- the. fol' lowing' ;open, significant ICAQRs' designated as Unit 2 restart items (and.being tracked by.DNE): I SQF 870008 HVAC ducts' , . ' SQP.870161. Low. flow logic switches . H 1 l SQP 870419- Electrical contact isolation SQP 870515 Pipe supports' 1 ]j SQP 870600 . Pipe sizing l SQP:871007
- Instrument'line sloping
SQP 871011 HVAC high-temp cutout' switches ~q SQP-871075 P.ipe supports ' H SQP 871129 CCS pump seals SQP 871160 Cascading. fuses j , SQT 870102 Calculation error- ? SQT 870349 EQ temperature profile SQT 870385 Orifico' sizing ' 1 SQT 870626 _ Conduit support. 1 SQT 870643 Pressurizer safety valves C l SQT 870791- <0C' emergency'. lighting . .. . SQT 871238 Voltage and frequency testing 1 The inspector reviewed each package, formulated questions, ' and d presented the questions to DNE personnel cognizant of the item. ^{ Overall, DNE personnel appeared to have positive cont'rol with respect ' > to the progress of corrective actions. However', some information- appeared to be difficult to extract. Often the exact status.of'the- ] project, particularly if field work was in progress,.was unknown. A ) formal corrective action tracking system giving updated,- detailed, item-by-item status did not exist, ' Several of the CAQRs violated' time constraints presented in procedure AI-12 (Part I). Due to the volume of CAQRs 'in the- system and the newness of the program, - plus the fact that missed - time limits were ~ not excessively tardy, this element of-.the inspection ~was deemphasized in favor of an assessment of the1 quality and progress of~. ! corrective action taken for each-item. ' ' l There appeared to be an interface problem between DNE and'PORS. On j several occasions, the problem statement provided' on the CAQR- ! contained insufficient information for P0RS to-determine if 'the. CAQR - af fected operability. of the plant or was reportablet to NRC. In this' case, P0RS.would send written questions to DNE to which DNE-would respond. ' An example of this process was CAQR SQP 870515,- where the , above process was~ proceeding so slowly that P0RS had yet to make its i operability and deportability determinations for a CAQR that was over four months old. , Taken as'a whole, .the root cause analyses', - recu'rrence control , i 'h t I ' &' & -_ ,.-- ' ' _ _ _ _ _ - _ . _ _ _ - - =_
a - ' j , , , , , . . . . < - , 8
, actions, and the generic concern reviews : were~ well done. Some , deficiencies were noted, such as :CAQR SQP 870600,. for which the . recurrence control summary was merely a statement of what should have ' H taken place, but did not'. ' Root cause analyses for '.CAQRs' SQP 1871011 ' and SQT 870349 pr'esented-more a.. list'of associated circumstances than- the'true root cause.of the' event. ~ . Each CAQR had a' schedule completion date that wasi tied :toJvarious l critical' stages. of, the startup of Unit 2. 'In almost all' cases,. the ~ scheduled completion date .had been extended, of ten more than once~. l These extensions appeared exce'ssive, but may have: been more (the1 R resul't of a reshuffling of J resources lin: the wake. of ' retreating scheduled Unit 2 startup dates, than a cha'racteristic failure of the- corrective-action system to; force the: item to' completion. The oldesti CAQR in this reviewed set was SQT 870102, which had been initiated' February 28, 1987, and originally-scheduled 1for. completion 1on'May-~30, 1987. The. current scheduled completion date is September 30,;1987. y , 1 This CAQR identified the need to :re perform electrical calculations ( -l for which the impedance of thermal overloads ~ had 'been: overlooked. " The calculations were revised, but are being revised again. Another' element which delayed completion of this item was that ONE and P0RS. disagreed over whether it was'significant; but it eventually was determined to be so, i l The inspector's review of the technical adequacy of proposed corrective actions did not reveal any major -discrepancies. In each- I case, the corrective action appeared to' fully encompass the scope of the original problem. As mentioned before, at -times the original ) long-term corrective action was cancelled in cases where the-licensee i determined that the short-term action was sufficient. A further review was conducted of the 'following open, significant CAQRs: SQP 870189 SQP 870193 SQP 870217 SQP 870199
. SQP 870203 ' ! SQP 870304 l SQP 870236 SQP 870242 SQP 871276 ' 4 CAQR SQP 870199 was determined to be significant, but was judged not- to require a root cause analysis or recurrence' control determination contrary to AI-12 (Part I),'which requires these -reviews for every - significant CAQR. The. licensee stated that- this was an- administrative oversight ~ and that a revision ~.to the CAQR will be . ' issued which addresses root cause and recurrence control. I J _ _ _ _ = _ _ _ _ _ _ _ _ _ _ - . _ _ __ _a
z 1 r , , , , ' $ , . . , h ti- s- l ' - 1 , 'CAQR SQP 870304 i nvolved 'an : extension request foricompletion . of - " corrective' action to August 30,-1987. This request was denied'due to. the ' fact that neither PORC ' norf the Plant Manager had. signedsfor - approva! Lof the' : proposed corrective action, and 'the .CAQR 'was subsequently returned to DNE .on June .5,1987p - As. of August 13,1987,; - there still did not exist ;a -va11dLcorrective action extension .for - this CAQR. 'The same scenario . occurred - for CAQR 1SQP '870189. .It appears that the're.is an administrative problem. obtaining: expeditious . , . PORC and. Plant. Manager approval'of proposed. corrective actions. . Thei inspector also reviewed a. sample. of insignificant ~ closedL CAQRsi to' evaluate, among other elements,4 the bases upon ~which the 'CAQRs were closed. This. review included'the~following CAQRs: SQP 870200 SQP 870201- SQP.870202. SQP 870205 SQP.~870280 SQP 870281 SQP 870282- SQP 870283 SQP 870285 SQP 870287 SQP 870289 SQP 870290 SQP 870291 SQP 870297 The inspector was able to ascertain or obtain> a' satisfactory - explanation for the closure of each of these . items'. .This review reconfirmed the con _clusion of the previous NRC inspections ~ that' the CAQR system appears to. work well for problems of minor significance. The following additional significant CAQRs associated .with. maintenance activities.were reviewed: SQP 870015 SQP 870043 SQP 870169- SQT 870502 SQP 870524 j SQP 870654 SQP 870729 SQP 870777 SQP 871116 Three cases were noted dur'ing 'the. review-.of these CAQRs where the ~ ~ corrective, action plan specified in ' the Evaluation . section < of: the 1 ) 1 -l l ..; . i ] .sMw .a
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. . .. . i - . . 10- 1 CAQR was inadequate or incomplete. In each _ case, subsequent .; investigation by the inspector . determined that the appropriate ' corrective action .was being taken. Therefore,~although proper , corrective actions were .being' .taken, the CAQR itself did not l adequately document this. The licensee needs additional management ' attention to strengthen this area, due'to the fact that an incomplete i corrective action plan could' lead to an inadequate review ' and { closecut of the deficiency by - the : site's QA organization. The' ] specific examples of this problem are as-follows a 1 - SQP 870043, Unreliability of Containment: Sump ~ Transmitters: The i evaluation f ailed' to incorporate the Watts Bar Generic Review l ~ Response 'into the corrective action plan for Sequoyah. This response indicated ' the need. to weld - the fill / vent / isolation , valve caps in order to completely solve the problem. ) 1 - SQP 870654, Unreliability. of Safety Injection Transmitters 2-PT-63-83C (E13GM) and 2-FT-63-92C (E11DM): ' The evaluation - j failed to specify what action was being taken to resolve the " drift" problem on 2-PT-63-83C (E13GM), and also failed to specify what final actions were to be taken if both transmitters were determined to be faulty (i.e., replacement). - SQP 871116, Inadequate Testing of Diesel Generators: The evaluation failed to specify that .the Surveillance Inst'ruction for testing of the D/Gs required revision, and also failed to specify that the D/Gs needed to be retested to the new requirements. CAQRs generated by the onsite PORS - group were reviewed in order to verify program effectiveness. A total of 12 significant and 5 nonsignificant CAQRs were reviewed. The specific CAQR numbers are as follows: CAQR Number Subject SQP 870018 Pressure Switch Failure SQP 870019 Auxiliary Feedwater Flow Calibration SQP 870022 Auxiliary Feedwater Level Control Valves SQP 870023 Compression Fittings for Reactor Coolant < System Instrumentation SQP 870024 Auxiliary Air Compressor Operating Setpoints SQP 870025 Chicago Fittings on Vital Instrument Air Lines
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, 11 SQP 870027 Recurring Relay Failures SQP 870031 Diesel Generator Cooling Water Valve Failures SQP 870142 Containment Isolation Check Valve Surveillance Failures SQP 870159 Upper Head Injection Isolation Valve Surveillance Failures SQP 870162 Pressurizer Level Instrumentation SQP 870163 Instrumentation Calibrations SQP 870164 Auxiliary Building . Ventilation Damper Operability SQP 870165 Annulus Ventilation Damper Response SQP 871277 Residual Heat Removal Wiring Problems SQP 871184 Defective Fuse Replacement SQP 870857 Appendix R Separability of Instrument Lines A total of 50 closed nonsignificant CAQRs were also reviewed. The CAQRs reviewed are as follows: SQP 870028 SQP 870205- SQP 870150 SQP 870207 SQP 870151 SQP 870208 SQP 870152 SQP 870211 SQP 870153 SQP 870212 SQP 870154 SQP 870213 SQP 870155 SQP 870214 SQP 870156 SQP 870218 SQP 870160 SQP 870219 SQP 870166 SQP 870221 SQP 870167 SQP 870222 SQP 870172 SQP 870223 SQP 870173 SQP 870224 SQP 870174 SQP 870225 SQP 870175 SQP 870227 SQP 870177 SQP 870229 SQP 870178 SQP 870231 SQP 870182 SQP 870232 SQP 870185 SQP 870233 _ - __ ____ - _ ____ _
o. a s - . . ., , , .4 l 12
1 'SQP 870191. SQP 870234' O l SQP 870193 SQP 870235 ' .SQP 870196 SQP;870239; ' SQP 870200 1SQP.870247? SQP 870201 SQP~870248 j -SQP 870202. SQP 870249 The review ' indicated that deficiencies and ' areas: of.. concern . are Ll documented, but that final. resolution! requires - extensive' managements j attention. Response : dates' Land', corrective action' -dates- were ! '] , frequently missed 'and many werei forced 'into escalation. -None of the
P0RS' initiated , significant items pertaining - to Unit 2 startup had) d l been resolved. SQP - 870142 . addresses a' probl_em with ~: containment < .
- isolation valves. failing R their ' integrated leak 1 rate ' test. 'The
problem was due to improper 1 valve position "in1.the. system. !A: j ' temporary repair called for. replacing the valves. iThe new : valves failed to pass the leak rate test'. The 50 closed' CAQRs were ' minor in' nature and most .did not cross . 'I ' responsibility boundaries. The 12 significant and. 5 nonsignificant- ' CAQRs are more complex with more than one group responsible for , eventual closure, Extensive management attention will.be required to close all CAQRs identified as. required for Unit' 2 startup. It appears that the present CAQR system'should work, but only if.the total number of discrepancies . is reduced and only. with continued motivation provided by upper management, , 1 l Within this' area, no violations or deviations were' identified. b. Corrective Action-Request and Discrepancy Reports During the previous inspection of TVA's: Corrective Action. program (documented in NRC Inspection Report Nos. 50-327, . 328/87-26), . it was -i noted that there were a total of 41 CARS and 89_ DRs outstanding on i site. Some improvement in the reduction'of numbers was.noted, with a l total of 32 CARS and 29 -DRs outstanding. - During the previous ! inspection, 12 DRs were selected for:a detailed review of' corrective- action. The review determined that corrective action.for two of'the DRs was insufficient . (i;e. , SQ-DR-86-02-017R ' and ' SQ-DR-86-184R) . j Similarly,.during this inspection, 18 CARS and DRs..were re.viewediand ) , problem areas were noted with one- CAR and two DRs'. The details of' ' this review are as follows- ! SQ-DR-86-02-017R and SQ-DR-86-184R: . Corrective action for these 'l - ' DRs was noted to be insufficient during the previous inspection. l .
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c:- 1 'o .., . . , , ' - ;. ,s 13 . ,' , a i , Review of these deficienc'ies,. during . this.. inspection: revealed - ' that'~ adequate corrective -action _: plans Lhad 'been:: established for> ~ , each, and that the ; corrective actions hadEbeen' completed ^i'n'Lai l time 19 ' manner. Both of ' these 'deficienc9 r'eports had been - c l o s r.d . O Corrective . action for the. following CARS and - DRs 'was progressing ' sati sf actor.1ly: SQ-DR-86-03-075R ~ SQ-DR-86-05-120R" SQ-DR-86-242 SQ-DR-86-287 ~SQ-DR-86-308R- SQ-DR-86-321R' j i SQ-DR-87-003R SQ-DR-87-008R' SQ-0R-87-037. y SQ-CAR-86-01-002 j SQ-CAR-86-06-033 J SQ-CAR-86-07-038 1 SQ-CAR-86-046 Corrective action concerning the following deficiencies was,noted to be inadequate
i - SQ-CAR-86-058, Incorrect' Installation of Raychem. Splices. This 'l CAR had been escalated once. An extension - of . the corrective action completion date was granted one month at a time for three months. The most recent action -in the deficiency ~ package is a delinquent notice from site- QA to Instrument . Maintenance personnel concerning incomplete corrective f action. Management' needs to obtain a detailed' listing of required - splices, and ' should monitor corrective action on a more.' frequent basis to'. assure progress is being made toward CAR closeout. SQ-DR-86-292, QA Review of Draft sis. During the review of-this- -
DR, an issue was raised concerning the partial .closecut- (for j Unit 2 restart) of deficiencies. which ' cover ~ both units. i Discussion with site personnel identified thatJthere :was no system in place to properly follow or. document partial closecut. y Discussion of f this issue with '- the Assistant Site Director's j staff established that this.'probl.em was in.the process of-being: ' ' resolved via a' change to site Administrative. Instruction, AI-12,- and via a memo from the. Site Director which provide's-the.needed ' procedural and documentation requirements. SQ-DR-87-075R, Breakers Not~ Interchanged as . Required by - .i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - . . _ _ - -
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- - , . . ' . . . ~,- 1 14: j > a_ ! ! L WP 10118. This DR was Written on February 18,-1987, Hand is- designated as a' . Unit 2 restart item. cDiscussion :of :this' - deficiency with the Assistant' Site Director's staff indicated' d that the work to' interchange ' the .b'reakers .would requirelabout ' two, 8-hour 'shif ts; to ' complete. . As of f August.:17, 1987, Jthe- ] , corrective action hadlnot been completed. ~; i . . . . d Within this area, 60; violations.or deviations were:. identified,- j l c. Significant Condition . Reports, Problem 1 Identification Reports and- 1 Nonconformance Reports , 1 .! 4 ~ . . . . The inspector reviewed .the status of ' DNE -generated CAQs which?were ' identified prior to the i n'i tiation of ..the : current l CAQR ; system These CAQs included SCRs, PIRs, and .NCRs. This~ area was previously L d, inspected by the NRC (Inspection Report Nos. 328,L328/87-26MApril 27.o J to May 1, 1987), and weaknesses were identified in thelDNEtindividual' 'l ~ ' discipline corrective action trending and; tracking, programs;and ;the ' 1 reliability of the TROIesystem. Although some weaknesses. were still- ?j evident in resolving the backlog of CAQs, it : appeared that? the licensee's management of and progress toward resolution .had . signi ficantly -- improved. As of August 7,1987, - the TROI . identified
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' approximately 600 DNE related CAQs which encompassed 'the backlogito .~ be resolved by- DNE. Those items identified as Unit 2. restart' items were approximately 33 percent of this v'alue. These restart . items were being monitored closely by DNE in an : effort to establishJa baseline which would provide the status of each item and demonstrate progress towards completion. Overall " progress in 7the backlog- reduction was demonstrated by' a bar chart which identified that 172- CAQs had been closed since May 22, 1987. It appeared that'the less . i complex items had been closed first, with the ' rate of closure. now levelling off. Although it was apparent that corrective actions were l continuing, the documentation of corrective l action completion'did not ' appear to adequately reflect field work completion. The inspector reviewed the following sampleL of. CAQs,which approximated a 30 percent sample of Unit 2 restart identified items. This selection reflected the licensee focus on Unit 2 restart activity. l NCR PIR SCR 7 Open 16 Open 9 Open. 5 Closed 12 Closed 13 Closed y i l The following weaknesses were evident in the program to resolve the backlog of DNE CAQ items: l
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(1) Redundancy in CAQ/CAQR identification of inms (2) Indeterminate status of CAQ items outside of DNE 4 (3) Poor interface between DNE and plant organizations performing ). 1 , "' field work , (4) No method t'o track partial completion of CAQs relating 7to Unit 2 . <I ' ' restart p \\l L' ! (5) No formal metbod of documenting partial completions 1 L The inspector identified several items which were identified as a PIR initially, then as an' SCR, and finally transferred to the new CAQR system; however, the items were not closed out of the initiay 1 < identifying system. While this represents a con'servative weaknesk it provides a misrepresentation of the volume of ' CAQ backlog a nd -' . providesmanagementanunclearpictureofsystemconditjons. // l ~
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? Poor interf ace between DNE and; plant groups performVng field work resulted in an indeterminate status of CAQ items outside. of DNE. Although DNE generally tracked and resolved items adequitely within DNE, once an item interfaced with plant personnel, )ba status appeared to no longer be under the cognizance of ' DNE shich was - ultimately responsible for resolution and closecut. The engineering . change notice which authorized the field work was the sole mechanism utilized .by DNE for closecut. DNE utilization of ECN closecut as official verification may be reliable, but at the cost of' untimely' i resolution of eved smal) issues. .ECN scopes frequently included more { work than that specif$ dally required for CAQ closure, and although ] 1 the CAQ related work may have bean completed, ECN completion and closure delayed CAQ closure. DNE accepted only completed ECN packages as evidence of completed work, ,rather than other documenta- tion such as completed' work packages or , documented field verifica- i tions; therefore, items remainerl'open.whp,i closure was possible. The 'l inspector did not identify evidence via df.scussion or' sample review, that a specific individual person in DNE was responsible for maintaining status of an item beyond the interface. As a result,cCliQ ' , status was 1 cst and an important management tool, i.e., reliaMn, accurate determination of the system status, was not available. It j was evident that frequent, periodic communication, (i .e. , weekly or 4 biweekly), between DNE personnel and plant personnel performing and scheduling field work, would resolve many overlooked obstacles to increase progress of reducing the CAQ backlog and expediting the CAQR process in general. Prior t'o this inspection, the licensee had identified the need for a method to track and document partial completions of CAQs, but had not Q f \\ i - I f~ , m, u
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. g* , , , . u% v. j m .l ., ' .. 'q HL 16f i B i yet devWoped this into' the program. LThe. inspector reviewed afdraft.: , revision to AI-12, Adverse Conditions' and Corrective Actions, which . appeared to provide adequate. controls.for partial'. completion closures a,# - ! , and ' stated that ECN closure 'was - not necessary for L CAQ closupe. - l partial closures were- necessary due 'to ,a"need to _documentr work- M, , completed: in support:-of LUnit 2 restart Mhenithe(associated work on'. M l Unit l'was to be delayed. The TROI tradking system;did not have: thel -[. '
flexibility to reflect this partialEclosure .: status; nor wasJa.. E docunntation pethod developed. in' lieu 'of .the ECN: closure package. ,l , l This factor contributed to 'the inabil.ityntoiprovidel an accuratet ] l O' picture of what works.was completed in ~ the ' plantLandi once; 'again'. 9 L .( invalidated the management-tool of a. reliable system status. 7' ? The weaknesses previously enumerated n resulted Lin Lthejloss' of. a '
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J - ~ jl necessary management tool and reflects? the .:lackdf? a centralized' overview mechanism for the CAQ. pflocess. A reliable,: accurate status. ') provides prompt identification of poor' performance,Lweak programmatic . ' ' < elements, or system bottlenecks for " management i . attention and - w a resolution, and additionally reduces feedbackitime from" management: adjustments. Although.each group appeared to be knowledgeable.ofJthe ' 1 , W ' work within their own occupational sphere, no centralize 6' overview j existed which coordinated DNE and plant activities to close out CAQs.' o l The licensee has tSken action and monitored development.ofx the CAQ ji program since the previous NRC inspection of this area.- . In May 1987, a CAQ multi-disciplined task force evaluated each CAQ in conjunction: il withtheresponsibleplant/designgroufinput;to' determine;' y H P { l (1) Restart applicability ' , l (2) Priority ! ' i " j ' (3) Current status f 7 This information was ' entered into = TROI andr a baseline' status ') ' , established. Work on resolutions was apparently continued with i . particular emphasis' on Unit 2 restart items. Although disciplines , <were correcting problems and moving on ' to the ? next items, 'the J maleted documentation was either delayed on not passed tayond. the d!scipline, and subsequently the baseline < Witus was lost. In.an j / effortt t6' regain this status, the -licensee contracted i Bechtel personnel tr work with DNE to achieve this status and; establish j . J < control over the CAQ system. During .this ; inspection,. this group was - K , in their 't:hird week on site and was reestablishing this baseline. 9" The group was recommended via a corporate QA Team review of.the CAQR 'j system at Sequoyah performed May .29.'- June 5,1987.. This inspection, ' F by Corporate QA' identified 15 significant weaknesses .of the process ~ ' at 'Sequoyah- and suggested recommendations: to ? overcome--these., , wyaknesses." The report demonstrated thpcensee's determined effort: ! ! to identify and correct problems wibhin . the: system. With the = ' L j > I' . n d l. ,' .; ' a i ) - ( .! 'Ok . i' ' A
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'p - . . , , , -} r - ., g- M t i [h;d 17 ., i v ,, y , establishment of a' reliable- 4tetus for all CAQs, which ;was nearing d completion at.the conclus' ion of this NRC inspection, and the approval I. j$ .of the AI-12 draft revision partial closure documentation - which was projected to Pc co d.eted by September 1, 1987 (projection,.not a commitment), it appears the CAQ backlog will 'be ' demonstrably. progressing (towards resolution. ' ij , i Within this akea, c no 4thlations or' deviations were identified. t'l
~ , l 7. Licensee Action,or$ Previousi$ Identitled Inrepection Findings (92701) ! D i i .i ,/'a. (Closed) Inspector' Followup lyvii 327/76-04-0E: Procedure G01-1 and I, 1 , S0W 00 Not Address Hoy Long Completed Instructions Are to- be a <, , Retained As Quality Assurance Records- The inspector's conirn at the time was that onceithe plant started . )l4 operating, procedures in draft form, when reviewed, did not contain . l ' s definitive guidance for. record retention; The procedures i n' .v ' question, GOI-1, Plant Startup from Cold Shutdown. to Hot Standby; l " ' , Revision 0, dated May 8, 1976; and SQO-3, g Sequoyah . Nuclear P1, ant Operating Mapual, dated October 14, 1976, didnot ha've prdisions for
record retqtion . The inspector reviewed AI-7, Quality Assurance I Records, TM ision 0, dated January 27, 1977; ~Thisinspet tre /ction instru 'l nlso j contgens quNan:c , for procedure retention. The t reviewed Revision 45 of this same procedure dated August Id 1987. i ' \\ Controls for procedire retention are clearly delineated. 4 N t , b. (Closed) 80-8U-02: Inadequate Quality Assurance for Nuclear Supplied Equipe nt. l.
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/, N s , ' ' This Inspection any Enforcement Bulletin was issued January 20, 1980, /3 and detLiled problems relative to deficiencies in the implementation of t.Mf Marvin Engineering Company's' Quality Assurance program ., , relati ve to thep manuf acture of boiling water reactor intern } / 3 feedwater sparaprs and feedwater therul sleeves. This bulletfr. xas j not applicable to pressurized water riactorr.. ' . , j < c. (Closed) Inspector Followup Item 327. 328/8S MI 01: Erroneous ' / Information and Incomplete Records for % sign Changes Listed ' in ' , ! ' ' O Annual Operating Report. , . i
< The inspector reviewed Engineering ; Change. Notices (ECNs) 2404 and ' j ,3 L5550 and ve-ified that complete documents. tion was available. The- l ' 3 inspector reviewed the '1986 Sequoyah- Annual Operating Repcet. From l the Facility Changes - Modifications section of this' report, thV 'j inspector selected ECNs L5798 and L5293, and verifind ithat the ) ,- , information from the Annual Operating Report was correct y that tne j necessary documentation was available. i 1 l i , . 4 , > . j s . ,q, , \\ , x '
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. } " -d. -(Closed) . Inspector - - Followup -Item 327,3 328/86-73-01,-:259, q 1260,296/86-43-01, 390, 391/86-26-01, a n'd . - 4 3 8 ,' ' -439/86-11-01i a Evaluation of theLlicensee's New Corrective. Action Program.'
' - H The inspector's'concernsiregarded: ? unclear requirement's'on' immedIate d " -notification of . appropriate L. personnel ' upon ' identification - of CAQs: d - whichl couldiaffect safety .in F an Joperating plant; . qualification - H ~ requirements we're 'not referenced : for personnel evaluating J CAQs'; .and: j Disposition and justification by other units at the same site of.CAQs: a where the issue was determined-to be generic. At the time'this 1 tem- ~ - wa's identi fied _ (December i1986) , thel CAQ program hade note been implemented by any TVA nuclear; sites. _ This program ihas now ~been ; Part'1, Section-2.'16~, Corrective' Action. ~ 1 implemented, and several . revisions have been . made to ' the . NQAM,- "
The inspector reviewed Revision 3 of this- procedure and , identified' ' that requirements '_ have .been ; clearly delineatedLin paragraph 9.0 - l , regarding immediate notification of appropriate._ personnel ;upon 1 identification of CAQs . which .'would affect safety / inc an operating- ' plant. i , ' .The inspector _' discussed ~ qualification requiremen_ts for personnel' evaluating CAQs with: licensee ~ training and._ QA personnel. All- ( evaluati' g1 CAQs have received specialized , training. .i personnel n Additionally, 'other classes are being formulated 4for more training. ") ' . This is scheduled to , commence - August 24,1987. Approximately71000 ' H personnel are'. scheduled to receive this training. The inspector, during the review of- Revision 3, ' identified that requirements ~ have been clearly ' delineated in paragraph 10.0 _for. aj processing regarding generic CAQR issues. ' V e. NRC Inspection Report Nos. 50-327/87-15 and 50-328/87-15 revfewed ,k corrective actions relating to Nuclear Manager's Review Group (NMRG) 1 Findings in Report R-86-02-NPS-(Revision l'). ' ' ' This NRC report states the following relative to Finding 0-2-Category . 1: , 1 The NMRG found that corrective actions for . some ' problems j identified by the plant Quality Assurance staf f had 'notLbeen c effective. The NMRG recommended that management attention 1to I corrective action for these items be increased;iline. management appreciation for, and attention to, quality program requirements - y be strengthened; mechanisms for evaluation .of the effectiveness . 1 ' of corrective actions be improved; 'and repetitive problems. be_- escalated. . . 1 E I* 9 p _ __ -
. . , . . , . , . ' 19 > The CAQR process was reviewed in-depth and is discussed .throughout this report. The specific NMRG concern dealt with QA reviews of completed Work Requests.(WRs). -The inspector discussed the current WR rejection rate with QA personnel . SQM2,. Maintenance Management System, Revision 23, was implemented on. March 25, 1987. QA reviews of completed WRs after implementation of Revision 23, indicated a- near' 100 percent rejection rate. Since that time, however, the rejection rate decreased considerably once personnel understood how to process WRs. The rejection rate for the weeks of July 29 - August 4, 1987, and August 5 - August 11, 1987 were approximately i 32 percent and ' 15 percent (414 processed, 132 rejected and 225 reviewed, 34 rejected)'respectively.
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