ML20236E294

Rev 1 to Engineering Change Notice Process & Scope of Engineering Required for Mods, TVA Employee Concerns Special Program Element Rept

ML20236E294
Person / Time
Site:	Sequoyah
Issue date:	06/10/1987
From:	Walters R TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20236E191	List: ML20236E186 ML20236E237 ML20236E273 ML20236E282 ML20236E287 ML20236E291 ML20236E294 ML20236E298 ML20236E304 ML20236E309 ML20236E325 ML20236E329 ML20236E350 ML20236E496 ML20236E516 ML20236E613 ML20236E618 ML20236E649 ML20236E657 ML20236E672 ML20236E675 ML20236E693
References
204.6(B), 204.6(B)-R01, 204.6(B)-R1, NUDOCS 8710290166
Download: ML20236E294 (41)

Text

F.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.6(B)

SPECIAL PROGRAM REPORT TYPE:

SEQUOYAH ELEMENT REVISION NUMBER:

1

[

TITLE:

ECN PROCESS AND SCOPE OF ENGINEERING REQUIRED FOR MODIFICATIONS PAGE 1 0F 30 REASON FOR REVISION:

1.

Issued to incorporate TVA comments and delete CATDs 204 06 SQN 01 and 204 06 SQN 03.

PREPARATION PREPARED BY:

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DATE REVIEWS

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REVIEW C MM TTEE:

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TAS:

SIGNATURE DATE CONCURRENCE 5

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DR PDR CEG-H:

O SRP:

SIGNATURE DATE SIGNATURE

• DATE APPROVED BY:

ECSP MANAGER DATE FMNAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files,

y i

TVA EMPLOYEE CONCERNS REPORT NUMBER:

204.6(B)

SPECIAL PROGRAM REVISION NUMBER:-

1-PAGE 2 0F 30 l

a 1

1.

CHARACTERIZATION OF ISSUES:

Concerns:

Issues:

Engineering Change Notices (ECNs)

WI-85-100-055 a.

" Untimely closecut of ECN's, are closed out in-an untimely due to a lack of knowledge' of' manner, without proper status status of ECNs or designs of ECN and affected design being affected.

CI has no further known. There is a lack of information. Anolymous concern adequate tracking for EN DES via letter."

(TVA) design changes (e.g...ECNs).

^

WI-85-100-041 b.

Procedure OEP-il revision eliminated 3

" Lack of adequate tracking for space on the front cover page

'j EN DES commitment and design ~

for identification of other documents i

changes.

CI has no further and plant areas affected by ECNs.

l information. Anonymous concern Elimination of this " checklist,"

vi a letter.'.'

which required consideration and positive action by the ECN preparer l

PH-85-038-001 and reviewer, may result in an af-Office of Engineering's fected document or plant area being Procedure OEP-ll ' Changes to overlooked.

Plant' was revised. The revision eliminated the front c.

The majority of design change requests page of-the ECN form which DCRs are not documented properly, identified the documents /other areas of plant the ECN could d.

The engineering scope and design affect. The old ECN front activities required for modifications page had, as an example - FSAR-are not adequately identified.

affected Yes No Appendix

'R' - affected.

Yes No e.

TVA does not coordinate the effects which required some positive of upcoming (near-or long-term) action by requiring the yes design changes with all disciplines or no bluck to be checked.

The and site construction. This results new revision to OEP-11 has an in an inadequate evaluation of the attachment two (2) which is only impact of design changes, a list of possible areas which might be affected and requires f.

An excessive number of ECNs hinders no check off. Therefore no one the quality of work by delaying con-is using it.

CI has no addi-struction activities and causing tional information.

Anonymous rework.

concern."

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' Concerns (continued):-

Issues (continued):

1 NOTE:

The following issues from these concerns are addressed in XX-85-070-003 Sequoyah Element Reports as "Sequoyah: Work plans contain indicated.

Issues indicated-with an inaccurate data.

Majority of asterisk (*) were developed

'the DCR's taken care [of] but from notes generated by the.

not documented right and draw-evaluation team when' the l-ings do not-reflect the as-built expurgated file for I-85-128-NPS conditions. Details withheld was reviewed.

to maintain confidentiality.

Nuc Power concern.

C/I has no Basic design calculations are not p(repared and not documented.

further information."

205.1)*

I-85-128-NPS "An individual from BFN wrote There are no procedures to control NSRS expressing his concern and maintain calculations current.

that the control and quality (205.2)*

.of OE's design effort is.

inadequate. The.CI'sent Basic design input, design require-several roughly written ments, and the basis of determina-pages detailing and sum-tion of design requirements are not marizing his evaluation and readily available.. (201.6)*

conclusion of three major Configuration control does not areas:.

exit.

(206.1 )*

(1) Design Calculations, (2) NCR's, and (3) Management Policies."

There is inadequate tracking of EN DES commitments.

(201.5)

Note:

Issue "d" i

was developed from a review Drawings do not reflect the as-built by an evaluation team member conditions.

(206.1) of the expurgated interview files for this employee concern.

Workplans contain inaccurate I-85-128-NPS.

data. Majority of the OCRs have been implemented but ECTG-2 documentation has not been prepared

" Lack of coordination of effects correctly.

(307.04, prepared by of upcoming (near or long-term)

TVA) design changes with all dis-ciplines and site construction

-inadequate evaluation of impacts (not under configuration control)."

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t-TVA EMPLOYEE CONCERNS REPORT NUMER:

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SPECIAL PROGRAM REVISION NUMBER:

1-PAGE 4 0F 30' Concerns (continued):

IN-85-929-001 l

"The excessive number of Engineering Change Notices (ECN) l l

hinders.the' quality.of work at WBNP by bogging down the mech-2 anisms of normal construction activities and causing rework.

i CI has no further information."

'2.

HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO l

o Identified by-TVA Nuclear Safety Review Staff (NSRS)

Date 12/17/85 Documentation Identifier:

NSRS Report I-85-546-WBN, " Employee Concern PH-85-038-001, OEP-ll Changes to Plant" l

o Identified by TVA NSRS V

Date 03/03/86 4

Documentation Identifier:

NSRS Report I-85-637-SON, " Employee i

' Concerns XX-85-070-002 through 006,_ Workplan Processing" i

o Identified by TVA Generic Concern Task Group (GCTG)

Date 04/24/86 1

Documentation Identifier:

TVA Report (SQN) GCC-17-63, " Employee Concern PH-85-038-001, OEP-ll Inadequate" J

o Identified by Configuration Control Task Force-(CCTF)

Date 06/30/86 Documentation Identifier:

Memo R. D. Guthrie (CCTF) to S. A. White, subject CCTF Final Report, RIMS R25-860626 833.

3.

DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:

No specific identification.

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SPECIAL PROGRAM-c PAGE 5 0F 30 i

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{

4.

INTERVIEW FILES REVIEWED:

J Expurgated files for WI-85-100, PH-85-038, ECTG-2, IN-85-929, and XX-85-070 were reviewed, and no additional unreviewed information-was found. Expurgated file for I-85-128-NPS was reviewed and notes were developed by the evaluation team.

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,'AND OTHER l

DISCUSSIONS RELATED TO ELEMENT.

See Appendix A.

8.

EVALUATION PROCESS:

a.

Reviewed the hierarchy of applicable documents (e.g., 10CFR50, Appendix 3, ANSI N45.2.ll, PSAR, FSAR) to establish criteria requirements and pertinent TVA commitments relative to the issues in Section 1.

b.

Reviewed engineering department procedures and practices relative to the ECN and DCR systems, including controls for tracking completion status, to determine if they meet 1

requirements.

Evaluated.0EP-ll (superseded) and NEP-6.1 for adequacy in addressing all possible documents that may be impacted by changes.

l c.

Reviewed Corporate and Sequoyah Nuclear N rformance Plans for TVA commitments relative to the design change process.

d.

Reviewed results of program audits by TVA, NRC, and Institute of Nuclear Power Operations (INP0).

e.

Reviewed available transcripts of NRC investigative interviews to gain additional information regarding the concerns.

f.

Reviewed draft copy of the NRC staff evaluation on the SQN Design Baseline and Verification Program (DBVP) to determine NRC acceptance requirements for the TVA plant modification and change control icng-term program.

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1 9.

DISCUSSION, FINDINGS, AND CONCLUSIONS:

i Chronology:

Mid-1960s:

Sequoyah (SQN) plant design begins 10/15/68:

SQN PSAR issued mid-1969:

Oraft 10CFR50 Appendix B' issued 06/27/70:

10CFR50 Appendix B formally issued i

l 07/70-SQN-QA Manual,. through R12, constitutes Engineering 12/75:

Design Procedures in effect 09/73-Division of Engineering Design (EN DES) Engineering l

06/85:

Procedures (EPs) in effect l

06/06/74:

ANSI N45.2.ll-1974 issued 1975:.

Topical Report TVA-TR75-1 A initially issued 06/76:

TVA commits to Regulatory Guide 1.64 which endorses ANSI N45.2.11-1974 09/27/50:

Operating License (0L) issued for SQN Unit 1 09/15/81:

Operating License-(OL) issued for SQN Unit 2 04/09/85:

Topical Report TVA-TR75-1A, R8, issued l

06/85-Office of Engineering Procedures (0EPs) are in 06/86:

effect; supersede EN DES-EPs 1

1 07/85:

TVA receives Employee Concern IN-85-929-001 08/85:

TVA voluntarily shuts down SQN Units 1 and 2 09/85:

TVA receives Employee Concern PH-85-038-001 09/85:

SQN Project Manual (SQEPs and SQEP-Als) issued 1

i 11/85:

TVA receives Employee Concern XX-85-070-003 11/85:

TVA presents its Corporate Nuclear Performance Plan (initial issue) and Sequoyah Nuclear Performance Plan (Draft) to NRC 12/85:

TVA receives employee concerns WI-85-100-041 and j

WI-85 -100-055 l

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^f 03/10/86:

TVA Corporate Nuclear Performance Plan (CNPP)

Volume 1, R0,' submitted'to NRC.

05/01/86:

Formal Design Baseline and Verification Program (DBVP) for Sequoyah', R0, issued 06/86:

TVA receives Employee. Concern I-85-128-NPS 07/86:

TVA CliPP, Volume 1, and SQN Nuclear Performance Plan', Volume 2, revised and issued as R1 07/86-Nuclear Engineering Procedures (NEPs) in effect; present:

supersede OEPs 4

08/86:

TVA CNPP, Volume 1, revised and issued as R2 10/86 TVA receives Employee Concern ECTG-2=

01/20/87:

.NRC transmits draft SQN Safety Evaluation Report (SER) of the Design Baseline and Verification Program (DBVP) to TVA Discussion:

9.1 BACKGROUND

Sequoyah is a two-unit nuclear power plant. Each of the two units employs a pressurized water reactor (PWR) nuclear steam supply system (NSSS) with four coolant loops, furnished by Westinghouse Electric Corporation.

The plant has been l

designed, built, and operated by TVA.

Because of questions about the environmental qualification of electrical equipment at Sequoyah, TVA voluntarily shut down Unit 2 on 08/21/85, and. Unit.1 on 08/22/85.

These questions, and other events which reflected adversely upon the quality of performance of TVA's nuclear activities, have led to a thorough evaluation of the TVA nuclear program, including its management and operation of Sequoyah.

)

l The Sequoyah plant design was begun in the late 1960s when regulatory requirements were not required to be well I

documented. The majority of the SQN licensing commitments were made in the late 1960s and early 1970s and some of the present day regulatory documents do not pertain to Sequoyah.

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.It is not necessary to update the.Sequoyah. plant to include all of the new guidance published by NRC,. unless there are specific requirements or commitments to do so.

The issues in this element report center ~on.the premature' and/or delayed closure of some engineering change notices (ECNs)' the elimination of a checklist of affected documents from the ECN cover sheet, inadequate. documentation of design change requests (DCRs), and the volume, interdiscipline coordination, and handling'of ECNs'.

9.2 REGULATORY REQUIREMENTS AND TVA COMMITMENTS The applicable requirements pertaining to these issues are contained in the following:

o

'10CFR50, Appendix B " Quality Assurance Criteria for

-Nuclear Power Plants and Fuel Reprocessing Plants,"

(App. A,'6.a)' Criterion-III. Design Control

" Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant' designates another responsible organization."

Criterion V. Instructions,' Procedures and Drawings

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances...."

ANSI N45.2.ll-1974 " Quality Assurance Requirements o

for the Design of Nuclear Power Plants,"

(App. A, 6.b) Section 7.

Document Control

" Documented procedures shall be'used to control issuance of design documents and changes thereto.

These procedures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are properly distributed."

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Secti.on 8.

Design Change Control.'

" Documented procedures shall be provided for design changes to approved design documents, including field changes, which assure that the impact of the change is carefully considered, required actions documented and information concerning the change is transmitted to all affected persons and organizations. These changes shall be justified and subjected to design control measures commensurate with those applied to the original design."

Section 8.2.

Review of Changes "Normally, the procedures for effecting design changes shall raquire that the documents which reflect the design change be reviewed and approved by the same groups or organizations which reviewed and approved the original design documents."

1 Although the Sequoyah Preliminary Safety Analysis Report (PSAR) was released prior to issuance of 10CFR50 Appendix B, the Sequoyah engineering organization began to comply with the applicable criteria upon its issuance as a draft document in mid-1969.

TVA has committed to 10CFR50 Appendix B,- ANSI I

N45.2.ll-1974, and Regulatory Guide 1.64 since their issuance.

The SQN PSAR (App. A, 5.f) and FSAR (App. A, 6.d) through Amendment 3, updated 04/86, contain commitments that specify requirements in compliance with the criteria of 10CFR50 Appendix B, and ANSI N45.2.11-1974 dealing with design change control.

9.3 TVA ENGINEERING DEPARTMENT PROCEDURES The evaluation team reviewed the past and present engineering procedures (EPs, OEPs, and NEPs) which dealt with design change control.

The procedures reviewed cover the period of time-from the development of the Division of Engineering Design Engineering Procedures (EN DES EPs) in 09/73 through the current Division of Nuclear Engineering (ONE) Nuclear Engineering Procedures.(NEPs) issued 07/01/86.

All design engineering for the TVA nuclear power plants before 10/73 was performed by the engineering branches.

These engineering discipline groups designed several nuclear plants 10550-26 (06/02/B7)

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concurrently, beginning in the late 1960s.

In 09/73, an organizational change'at TVA resulted in the establishment of 7

the Division of Engineering Design (EN DES). At.that time a project system was established that assigned engineers from i

the various engineering branches (Civil, Electrical, and Mechanical) to work exclusively on a specific project, such as Sequoyah.

The Sequoyah project engineering team members, under a project manager, were assigned responsibility.for maintaining the design activ.ities related to Sequoyah, including any needed design changes.

New divisionaide procedures, called EN DES EPs, were established and were in effect from 09/73 to mid-1985.

The EPs were quite detailed and prescriptive, and included many administrative controls in addition to addressing quality assurance requirements. The EPs that were reviewed in detail for this evaluation are listed in Appendix A. 5.1.

In 06/85 new Office of Engineering Procedures (OEPs) became effective. The OEPs reviewed in detail for this evaluation are listed in Appendix A, 5.j.

The new OEPs reduced or eliminated most of the administrative details previously found in the EPs.

In place of a stand-alone procedure with many instructions, the OEP referred the reader directly to other procedures that controlled individual activities. The end result was a series of single sentences that provided anyone unfamiliar with the process minimal direction on how to accomplish a given activity.

1 In 07/86, the reorganized Division of Nuclear Engineering procedures (NEPs) became effective. The NEPs reviewed in detail for this evaluation are listed in Appendix A, 5.k.

Although these procedures closely resemble the content, format, and brevity of the OEPs issued a year earlier, there are some exceptions. The current procedures require the active use of other referenced NEPs for full understanding of what is to be done.

EN DES-EP 4.02 covered ECNs both before and after licensing until 10/83.

At that time, the portion of EP 4.02 that deals with ECNs for licensed units was issued separately as EP 4.52.

These EPs contained detailed instructions and administrative details on the processing of ECNs.

In 06/85, OEP-il, " Change Control," replaced the extremely detailed EN DES-EP instructions with abbreviated and streamlined directions for controlling ECNs.

NEP-6.1, " Change Control,"

became effective one year later and provides essentially the L

I.

same procedural guidance as OEP-ll.

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1 PAGE 11 0F 30 9.4 OVERVIEW 0F THE DESIGN CHANGE PROCESS Design modifications for the Sequoyah Nuclear Plant after issuance of operating license were normally initiated by development of a DCR. The OCRs are prepared by the site NUC PR organization.

DCRs were not considered design documents, and, therefore, controls placed upon their use were for administrative purposes only.

Upon receipt of approved DCRs, Engineering generated an ECN.

The ECN.was' circulated to each discipline for review. NUC PR then'provided approval to proceed with design work. The approved ECN was not a design change document, but rather a document that authorized design work to begin.

Design drawings were issued as they were revised and approved.

Each drawing revision referenced the authorizing ECN, and was issued to NUC PR individually upon approval.

The workplan was prepared, reviewed, and approved at several' levels of the NUC PR organization, including QA and the Plant Operations Review Committee (PORC). The workplan becane.the r,ucleut cf all documentation partaining to modification implementation. The drawings and other documents prepared by Engineering became a part of the workplan.

Any conditioas requiring design revision encountered during implementation of a modification resulted in initiation of a field change request (FCR), which was sent to Engineering.

These were normally accomplished under the authorization of the original ECN, and additional design drawing revisions resulted.

Upon completion of the workplan, the cognizant NUC PR Modifications engineer marked up the drawings in the workplan to reflect as-constructed conditions. The same engineer also marked up the drawings in the control room as appropriate.

The completed workplan was forwarded to the NUC PR Drawing Control Section, where the official as-constructed drawings were revised to reflect the modification.

Two variations of the process described above allowed NUC PR to proceed with safety-related work in advance of formal Engineering design activities. One was the temporary l

l f

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l alteration control form (TACF), which was intended to j

recognize and control activities such as routine maintenance l'

' functions. However, it was used to-make more substantial.

changes in plant hardware. The TACF was prepared.and subjected to'an unreviewed safety question determination (USQD) review"and a PORC review, 'all witl.in NUC PR. Only if.a TACF was subsequently made a permanent change did Engineering get involved. The design change process was then initiated, except for the field work, which had already been completed..

The second variation allowed by the TVA program was the Category "0" FCR, a field change request that was relatively y

minor and did not change the function of a system. To accommodate fiUC PR needs for quick response, procedures.

I allowed work to proceed af ter Plant Manager approval and issuance of an ECN from Engineering.

The follow-through activities resulted in issuance of as-designed drawings l

after-the-fact (App. A, 7.e).

' 9.5 EVALVATI0f10F PAST SQN PLANT MODIFICATION 1S In the Sequoy'ah Naclear. Performance Plan (SQN NPF)

~( App. A, 5.r.), TVA ma lagement acknowledges past problems with design change control similar to. those expressed in the issues in this Element Report:

"In the pas't, problems and confusion existed J

within TVA's Nuclear Engineering Program, as both the Engineering Organization and the Sequoyah. Nuclear Power Organization performed engineering activities.

These problems occurred in areas such as design control and configuration control prograhis."

i "Sequoyah has experienced problems with the control of design changes and plant modifications. Weaknesses have been identified i

in the depth and documentation of engineering work for design changes and in maintaining consistency between 'as configured' and 'as designed' information."

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TVA' attributed these weaknesses to the' following root ~causes:

o-The lack of centralized' lines of authority, responsibility, and accountability'for the performance of' key design' control. functions o

Inadequate engineering evaluations,.a lack.of detail Lin design output, and the absence of centralized design input / design bases

-j 1

o' Us'e of design and modification control methods that'did not provide the coordination required among groups i

The design of plant mod.ifications on a drawing-by-drawing

)

o' I

basis, making establishment of the USQD of the final.

- design configuration and comprehensive review difficult ~

o The large volume of plant modifications o

Poor followup by SQN on paperwork for plant changes.

l o

Use of a design control program using two separate drawings, an as<onstructed drawing maintained by the plant and an as-designed drawing maintained by DNE o

Lack,of current design criteria and design basis l

informat' ion o

The wide scope of individual engineering change notices.

(ECN) and the large number of workplans 9.6 INVESTIGATION OF ISSUES ECN Closeout (Issue "a")

l The ECN is not a design document but a list of design documents that will require revision to incorporate the design change. A review of the past and present division-wide engineering procedures (EN DES-EPs, OEPs, NEPs), and the l

Sequoyah Engineering Project Manual (SQEPs) has revealed the following for the tracking and closecut of ECNs.

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f ECN design status was tracked within engineering by adding the issue date of a drawing listed on the ECN data sheet to the original data sheet filed with the project manager's staff. When the original data sheets for an ECN showed issue dates for all drawings listed, the ECN was " design complete." EN DES did not, however, track the field implementation of the ECN.

During the period of the EN DES-EPs (09/73 to 06/85), ECNs were closed differently for construction permit (CP) plants and operating license (OL) plants (EP 4.02 and EP 4.52).

For CP plants, ECNs were closed when all Engineering design work was completed and the design drawings listed in the ECN were issued incorporating the design change.

For OL plants, a unique ECN cover sheet was used.

At the discretion of the design project manager, the ECN could be closed either when all design work had been completed and drawings revised, or upon written notification fron the plant that all work had been field-implemented.

During the period of the OEPs (06/05 to 07/86), ECNs were allowed tc be closed after all Engineering design work was accomplished, regardless of whether it was a CP or an OL plant (CEP-ll).

In the current NEPs, the distinction beween CP and OL plants has been reinstated, although no unique ECN cover sheet is used (NEP-6.1).

l For OL plants, an ECN may be closed only after all changes have been ".., physically implemented at the plant by the Division of I

Nuclear Construction's (NU CON) modifications organization."

Fowever, as noted above, althougn division-wide procedures at I

times allowed for ECNs to be closed prior to field completion of the modification, project-unique procedure SQEP-AI-11

( App. A, 5.p), in place at SQN, required a written notification from ONP that the field implementation had been complete before any normal DCR or category "0" FCR-based ECN could be closed

( App. A, 7.e).

Thus, no ECNs should have been closed at SQN until all field implementation had been completed.

During an NRC inspection in 11/86, an assessment was made of SQN activities associated with the closecut of ECNs (App. A, 5.u).

In i

08/85, TVA established an ECN closecut group consisting of 12 full time personnel.

The purpose of this group was to establish closecut criteria and perform closecut reviews of long outstanding modifications packages. At the time of the inspection, only 145 of approximately 1,400 safety-related ECNs had been closed.

An inspection of five ECN closure packages revealed that most of the problems identified by the closecut project were attributable to drawing update requirements.

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-The Sequoyah Nuclear Performance Plan indicates that ECNs will not undergo the complete closure process before restart. The NRC has taken the position that closure of ECNs appears prudent because the closure review is the vehicle which triggers the FSAR update process as well as ensuring that affected drawings are revised. TVA has been requested by the NRC to provide a schedule and reasons for not closing ECNs l

~

before restart (App. A, 5.u).

ECN Cover Sheet Checklist (Issue "b")

The -ECN cover sheets in EN DES-EPs 4.02 and 4.52 had nine questions which required a positive response of "yes" or "no" (Example:

FSAR Drawing Modified? FSAR Text Modified?). These questions were removed from the cover sheet in OEP-11 and l-l expanded into a 28-point list of considerations in.

Attachment.2 of the OEP-il. An additional consideration was added.to the attachment for the current NEP-6.1.

However, no positive response is required in OEP-il or NEP-6.1.

The SQN and WBN Project Manuals, in the section on Clarification and Variances to NEP-3.2, show that project procedures at both plants require positive responses to a multipage list of considerations for the Design Modification Criteria.

It is i

the opinion of the evaluation team, and is typical of industry practice, that a positive response be reouired to ensure that all possible implications of the design change are being considered.

DCR Documentation (Issue "c")

A design change request (DCR) is a formal written request, generally initiated by NUC PR, that provides authorization to Engineering for a modification to a nuclear plant.

As noted above in Section 9.4, DCRs are not considered design documents. They provide a description of the requested change and reasons the change is necessary. DCRs are reviewed by the i

Project Engineer (PE) who distributes them to the appropriate j

discipline Lead Engineer (LE) for detailed evaluation and i

initiation of an ECN cover sheet. The PE and LE determine I

others involved, and, if necessary, coordinate a prescoping j

meeting with all involved organizations in order to determine j

work scope, feasibility, and identification of design j

documents affected by the proposed change.

If Engineering agrees with the OCR, it will issue an ECN which references the DCR.

Documentation of DCRs is the responsibility of NUC PR.

Element Report 307.04-SQN covers other issues raised by the l

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o NUC PR individual over work plan, DCR, and as-built' drawing Concerns.

Engineering Scope and Desion Activities for Modification Work (Issue "d")

i The evaluation team interprets the concern as referring to the

' change description written on the ECN cover sheet by the lead discipline engineer (LE), and that an incomplete description of the change may cause an involved discipline reviewer to underestimate the design change' requirements for his discipline.

For example, a change description to " Add a-third i

pump to the system" might not mention the pedestal' required of the civil section, the heat tracing required of electrical, the new nozzle to be installed on the suction tank, etc.

The result would be an incomplete design that would be found by the various ' checks and balances' such as a review by

~

construction or during startup testing.

I The description provided on the ECH cover sheet must be brief.

How much information is placed in this description is a matter of engineering judgment.

EN DES-EP 4.52 directed that "the description of the change should be stated concisely and. in terms of the objective to be obtained."

Identification of the complete scope of the change relies greatly on informal communication between disciplines.

Needed communication has l

been provided for in OEP-ll and the current NEP-6.l' through a "prescoping meeting" coordinated by the project engineer at his discretion.

The SQN NPP ( App. A, S.n, page 11-47) has identified the following weakness in the plant modification and design control program:

"Use of design and modification control methods that did not provide the coordination among groups required to en3ure accurate documentation of plant configuration and I

performance of effective safety evaluations."

1 Because there is no way to determine the amount of informal communication that transpired at the time the ECN was

{

prepared, the evaluation team did not attempt to judge the adequacy of the change descriptions of any ECNs.

Instead, focus was placed on the improvements in defining and communicating the change scope that should result from the new design change program and proposed in the Sequoyah NPP (App. A, S.n).

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"0nsite DNE personnel are now performing plant.

constructability reviews as part of the design process to reduce interference problems, field changes, and design errors...

During the design work, there are frequent face-to-face meetings between the plant personnel who request design changes and the design engineer.

DNE personnel will develop implementation instructions as part of the design change package and identify test requirements."

The current Sequoyah procedure for the control of transitional design changes (SQEP-13, R3) requires the Project Administration Section to coordinate a meeting with discipline Lead Engineers, Modifications, and Operations and Maintenance.

The purpose of the meeting is to determine the number and preliminary scope of ECNs required to implement a DCR.

Interdiscipline Desian Change Coordination (Issue "e")

TVA management has acknowledged in the SQN NPP, problems with the control cf design changes and plant modifications (App. A, 5.n).

One of the root causes has been identified as the "use of design and modification control methods that did not provide the coordination among groups required to ensure accurate documentation of plant configuration and perfor: nance of effective safety evaluations." Additionally, "because each group releases its drawings to Modifications at different times, it is difficult to resolve design conflicts between groups before part of the modification is under construction." These comments highlight the past lack of coordination between disciplines and between engineering and site construction and the resulting inadequate evaluation of the impact of design changes.

1 In the proposed plant modifications program, all design activity will be completed and drawings prepared prior to release of an ECN.

Necessary interdiscipline and interdepartment coordination should occur as part of the plant modification package (PMP) system prior to the installation of physical changes by Modifications.

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Excessive-NumberofECNsl(Issue"f")

This concern states tnat, "the excessive number of ECNs hinders the quality of work at Watts Bar.by bogging down thel mechanisms of normal construction activities and causing rework."- When focused on a plant under construction, such as Watts Bar,. it is clear that inultiple changes can disrupt.

construction schedules and activities and resultTin rework;-

.The concern in:this case, if substantiated, can be viewed as.-a

criticism of Engineering for inadequate designs that result;in l

an excessive number of ECNs.that impact construction work.-.

.In the casc of Sequoyah, an operating plant, ECNs are normallyf prepared in response to an identified need for a design change such as NCRs, FCRs,-and DCRs.

Following OL, Engineering does-l not control the volume' of ECNs issued.

.j However, TVA has stated 1n the SQN NPP (App. A, 5.n, page-

]

II-47)' that "the large volume of modifications work at -

i SQN

.. has presented a significant challenge." Also, "the' large scope of individual engineering change notices (ECNs)-

l and the number of workplans'has' been a problem."

l 4

r

9. 7 TVA SQN DESIGN CHANGE CONTROL PROGRAMS The SQN NPP. details the following corrective cction prograns, which, when fully implemented, are intended to resolve the anomalies noted in the Plan and prevent their recurrence, q

~

SQN NPP Action Plan TVA is improving its design control program for SQN by unifying engineering responsibilities and' strengthening the SQN Project Engineering Group. The design control program and.

j the quality of completed plant changes will be improved through comprehensive plant modification packages and a single drawing system.

With strengthened authority and responsibility, the Project Engineer is now responsible for the technical aspects of the total design for Sequoyah.

Centralization of the responsibilities for design changes will establish accountability for the quality of changes made.

l The quality of design work will also be improved by having onsite DNE personnel perform constructibility reviews and through frequent meetings between design engineering and plant personnel involved in design changes.

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To improve the design control process, a Change Control Board (CCB) has been established at SQN, consisting of senior plant personnel.

This board will provide overall management control of the transition from the existing modification control process to permanent modification control process.

The CCB will:

o Evaluate existing and proposed plant modifications to minimize changes

~

Review plant modifications to ensure that line managers o

are accomplishing the changes in accordance with adequate design and configuration controls o

Ensure that necessary interface and implementing procedures exist to establish a closed loop system for modifications in order to maintain design integrity o

Ensure that statusing of ECNs and associated design and plant implementing documents is adequate to reflect the status of the modific.itions

/

Transitional Design Control System In the SQN.NPP, TVA committed to implementing a transitional design control system prior to restart. The transitional program is designed to ensure that, once the Design Baseline and Verification Program (DBVP) has reestablished the plant design basis and configuration control, it is properly j

maintained.

At Sequoyah, engineering procedure SQEP-13,

)

" Procedure for Transitional Design Change Control," defines in j

detail the design change control process that is being followed in the transition between the past design change control process and the new Plant Modification Package (PMP) system.

The interim procedure introduces an integrated design change package approach which calls for all engineering design work for each new ECN to be completed, reviewed, and approved as a unitized package before it is released for implementation.

The completed ECN modification package includes or references new or revised design change authorizations (DCAs) to revise portions of issued drawings, modification criteria, specifications, schedules, USQDs, testing and inspection requirements, other design documents, etc., affected by the modification.

Another key element of this transitional design control system is the conversion to a single controlled drawing system by issuing configuration control drawings (CCD) and placing responsibility for the 10550-26 (06/02/87)

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control and maintenance of plant configuration drawings with the Division of Nuclear Engineering (DNE).

In addition to i

engineering designing, and issuing the ECN modification packages, DNE is responsible for resolving drawing discrepancies affecting. plant configuration, and incorporating as-installed modifications on the CCDs.

Administrative Instruction ( AI)-19 (Part III), " Plant Modifications: Modification Requests," describes the methods for processing, approving, and scheduling all plant modifications to the physical facilities of Sequoyah Nuclear Plant.

SQEP-AI-19 (Part IV), " Plant Modifications: After Licensing," describes the requirements for implementing and controlling acdifications to the physical facilities at Sequoyah.

It contains instructions for preparing, reviewing, approving,. implementing, and closing workplans and providing l

input to DNE in order to close ECNs after physical modification work has been completed. SQEP-AI-llA, " Field Change Requests," covers the responsibilities of the DNE Resident Engineer in dispositioning requests initiated by NUC PR to make a change to engineering approved documents in order to facilitate construction work, correct drawing discrepancies, or provide additional design information.

TVA is implementing these procedures only on new modifications. By 12/86, approximately 60 ECNs were in various stages of preparation using SQEP-13. Following design completion, the modification will be turned over to plant modifications for actual physical work following AI-19.

An NRC inspection ( App. A, 6.u) of the SQN plant modification program from 11/12/86 to 11/21/86 identified the following two problems with the transitional design change control

)

procedures: (1) the absence of a time limit to review and

]

close ECNs after field work completion which will ensure drawings are updated in a timely manner, and (2) the need for a commitment to review and close ECNs in a timely manner after 1

completion of field work in order to insure that applicable modifications are factored into the annual FSAR update within i

6 months of the modifications.

Permanent Plant Modification System TVA's permanent design control system is to include several key concepts:

The use of the actual plant configuration for designing o

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Updated design criteria l

o Accurate reflection of plant modifications in licensing j

documents (FSAR, technical specifications) 1 Integrated approach to handling changes rather than the.

-l o.

past fragmented, workplan approach l

1 The permanent design control system is based on a plant l

modification package (PMP) concept. Each plant modification I

will be issued by DNE as a single, stand-alone plant modification package which becomes the key document to maintain design control.

PMP preparers are to consider g

regulatory and FSAR commitments, impacts on other design changes, environmental qualification, ALARA, inservice inspection, unresolved safety question determination, installation and testing requirements, and many other considerations documented on PMP checklists.

Proposed modifications will be issued as approved and controlled,.

l unitized PMPs which will totally define a specific, executable scope of work and include such items as drawings, installation-specifications, workplans, and inspection requirements.

~

j Central to the permanent PMP system is the assignment of 1

' responsibility for all engineering and design functions to l

DNE. Previously, there were two sets of drawings applicable to plant systems: the "as-designed" drawing which represented Engineering's efforts and the "as-constructed" drawing which represented construction / modification efforts.

With past dual Engineering responsibility, the two drawings were not always reconciled when work was complete.

The new system assigns DNE i

sole responsibility for the engineering integrity and accuracy of drawings.

This sho61d result in one set of drawings, called " configuration control drawings" (CCDs), which accurately reflect plant configuration.

The transitional design change control process has already begun the conversion from the two-drawing system to single configuration control drawings.

Control room primary drawings, which include approximately 900 drawings maintained in the plant control room, will be converted into CCDs by the end of the fuel cycle 4 outage (the second outage after restart).

Changes will be red-lined on the control room drawings before a system can be operated.

TVA has established a target of 15 days from the completion of a field modification to updating of these primary drawings. Secondary safety-related drawings will also be maintained as-configured 1055D-26 (06/02/87)

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and are to be updated within 90 days of receipt by DNE of completed workplans and drawings from the Modifications group.

Nonsafety-related drawings required to support plant maintenance are also to be updated within 90 days of work completion.

All other drawings, such as structure location drawings, isometrics, load tables and bills of material, will not be as-configured but are to be updated and maintained as d es i gn ed ( App. A, 5. y) +=---

TVA has committed to begin implementation of the permanent design control system after completion of the safety-related system design criteria.

These design criteria are planned for completion by 12/31/87 ( App. A, 5.w).

Cetain defined design criteria will be completed prior to restart.

TVA has also committed to provide the NRC with a detailed scope and schedule for the postrestart (Phase II) portion of the DBVP.

The NRC's draft Safety Evaluation Report on the DBVP stated that because the definition of the long-term fixes for design control problems relates to the reasons behind the shutdown of TVA facilities, the NRC staff will ensure that the scope and schedule of implementation of Phase II are evaluated and are acceptable before restart of either Sequoyah unit.

TVA's response on the Phase II program was to be submitted by 03/21/87, ( App. A, S.x).

Findings:

a.

TVA reports and the SQN NPP do not substantiate the finding that ECNs have been prematurely closed out without knowledge of the implementation status.

On the contrary, these reports indicate that a large j

number of ECNs have remained open for some time, i

awaiting notification from ONP of the completion of I

the field implementation.

{

1 TVA has acknowledged however, that effective control d

of ECNs was not maintained at SQN.

Administrative controls, tracking, closure processes, and loop closure procedures were not adequately implemented and l

maintained (App. A, 5.n).

j TVA is reviewing the implementation status of all ECNs issued at SQN Unit 2 since receiving operating license (OL).

In addition, TVA is in the process of revising its DNE and SQEP procedures to establish better control of future plant modifications at SQN.

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Mi SPECIAL PROGRAil.

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l$

PAGE 23 0F130; Sk.{q gjr/7 gy 1

^

f f,d f j

?

i

,l Da M,ir

. 3 b.

'The ECN cover page it formation titch identified other:

documents 1ffected bysthe ECN iboow. addressed:6y.-

%%r A

s to NEP-6.1, and by:the~ current.

6

<y w

e

.'Q.

A modification criteria required by the.SQEP project:

(

manual Variance /Expssions to NEP-3.2, "Duign Input."

q

~I The. evaluation team verified th'at, while the OEP-ll

~

form did not contain squares forecheck-off of specifici l

. questions, the~ECN process hast improved from that previously in place because of additional requirements in the latest. project procedures.

Engineering'isLinvolve'd in review of DCRs'only.

The c.

i "w

preparation'and. documentation of DCRs is the 4

responsibility of the originating organization-(f.e.,

J - '

-A NUC P_R).-

'd..

The amount of detati in Tuded 'in the brief' change' x

descript. ion provided on the ECN cover is 'left to the engineering judgment.and' experience oflthe preparer.

Identification of th,e complete design change scope is

/

ggreatly dependent on. informal discussions between

~

> engineers from the affected disciplines and' plant

' personnel. TVA nas ' indicated ( App. A, 5.n,Section II.3.3) improvements in its design change.

f i

i system that should provide greater ability to informally communicate the entire desigri change scope to each engineering discipline invc1ved in the change. - The evaluation team ~ found no evidence of o

provision for such communication in procedures that j

M ik implement the ' permanent design control system.

TVA has acknowledged having a past problem in l

e.

coordinating design changes within engineering

,,f

~

~

disciplines and between organizations (App. A, 5.n).

)'/

~l Currently, coordination.is dictated by the SQEP

~

Project Manual procedures.

Design changes (ECNs) include a Design Modification Criteria, which is routed.to all disciplines for comment and signature

'?

t

/

before issuance of the ECN.

Additionally, the SQN NPP 7

f has established the CCB, chaired by the Deputy Site t

Director, to review all ECNs for final approval, f.

ECNs-are prepared in response to some identified need for a design change such as NCRs, FCRs, DCRs, etc.

EC M centrol the design work that is to be performed v

+9d' delineated on drawings or other design documents.

i

'2A yj 055D-26 (06/02/87) n.s

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Engineering does not control the volume of ECNs issued.

In addition, any negative impact on the quality of construction work resulting from a large number of ECNs should be reduced by proposed changes to the design change process.

These planned improvements include frequent meetings during design work phase between NUC PR, construction, and design engineering, and implementation of the design change package concept.

Conclusions :

TVA, NRC, and INP0 audits, as well as the Corporate and Sequoyah Nuclear Performance Plans, all acknowledge that the Sequoyah design change control and documentation program have not been adequate.

Issues "a,"

"d," and "e" identified in this report are valid.

Protracted delays at SQN in Enginering's scope of

(

responsibility have occurred in areas such as closing ECNs, responding to DCRs, dispositioning nonconformance reports a.nd TACFs, and updating drawings. The Sequoyah design change control program permitted prolonged delays in closing change authorization and documentation loops.

That is,.the program did not force action to resolve outstanding documentation issues by designating time restraints or assigning organizational accountability for tracking and closing ECNs and affected drawings, substantiating Issue "a."

In some cases, Engineering was not informed or aware of the status of physical work completion and field changes to approved modifications which impacted subsequent design changes.

The evaluation team has concluded that, contrary to the allegations of Issue "b," the design changs ;ontrol process for SQN was improved by issuance of an expanded check-sheet as an attachment to the ECN cover sheet.

4 The adequacy of DCR documentation, Issue "c," was regarded as 1

the responsibility of the originating organization (i.e., NUC PR) and, therefore, not an engineering concern.

The concern that an excessive number of ECNs hinders work quality by delaying construction activities, Issue "f," was not considered a valid engineering concern because ECNs after i

OL are generated in response to other design change documents (NCRs, FCRs, etc.) whose quantity is not controlled by Engineering.

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PAGE 25 0F 30 Therefore, only Issues "a,"

"d," and "e" are valid. TVA is now implementing an improved design control program for SQN.

When this program is incorporated into documented procedures and subjected to engineering assurance audits, these issues should be resolved.

(

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APPENDIX A I

5.

DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a.

Title 10 of the Code of Federal Regulations, Part 50 k

(10CFR50),. Chapter 1, Appendix B, " Quality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants;"

1 Criterion III, " Design Control," and Criterion V, j

" Instructions, Procedures, and Drawings" b.

ANSI N4E.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants" L.

c.

ANSI N45.2.11 - 1974, " Quality Assurance Requirements for.the.

Design of Nuclear Power Plants," Section 7, " Document-Control," and Section 8, " Design Change Control" d.

ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions" i

i Regulatory Guide 1.64, " Quality Assurance Requirements for e..

(.

the Design of Nuclear Power Plants," R2, (06/76) f.

Sequoyah Preliminary Safety Analysis Report (PSAR), (10/15/68) g.

Sequoyah Final Safety Analysis Report (FSAR) updated through Amendment 3 (04/86) h.

Sequoyah Nuclear Plant Quality Assuranu Manual (SQN QAM),

R12, (12/31/75) 1.

TVA EN DES Engineering Procedures Manual q

EP 4.02, R16 " Engineering Change Notices (ECNs) Before Licensing Handling," (07/23/84) l i

EP 4.18, R4 " Design Change Requests (DCRs) - Processing, Reviewing, and Approving," (05/22/84)

EP 4.22, R0 " Preliminary Design Changes Requests (PDCRs)

- Handling," (04/13/83)

EP 4.52, R1

" Engineering Change Notices (ECNs) after Licensing - Handling," (04/24/84)

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l APPENDIX A (Cont'd) l j.

TVA Office of Engineering (0E) Procedures Manual:

OEP-08, R0 " Design Output," (04/26/85) 7 OEP-10, R0 " Review," (04/26/85)

OEP-ll, R0 " Change Control," (04/26/85)

.k.

TVA Division of Nuclear Engineering (DNE) Procedures Manual:

NEP-5.1, R0 " Design 0utput," (07/01/86)-

NEP-5.2, R0 " Review," (07/01/86)

. NEP-6.1, R0 " Change Control," (07/01/86) 1.

TVA-TR75-1A, " Quality Assurance Program Description for the Design, Construction, and 0peration of TVA Nuclear Power Plants," R8, (04/09/85)

TVA memo from L. L. Jackson to Those Listed, (A02 860813 012) m.-

" Institute of Nuclear Power Operations (INP0) Corporate

.(

Evaluation Responses," (08/14/86)

Sequoyah Nuclear Performance Plan, Volume 2, R1, (07/17/86) n.

TVA Corporate Nuclear Performance Plan, Volume 1, R4, o.

(03/26/87) p.

Sequoyah Engineering Project, Project Manual:

NEP-6.1, R2 "SQN Variance / Expansions to NEP-6.1, Change Control" (09/08/86) q

.SQEP-AI-ll R2

" Engineering Change Notices (ECNs),"

i (02/06/86)

SQEP-AI-llA R1

" Field Change Requests (FCRs)," (11/14/85)

SQEP-AI-19, (Part III), R14 " Plant Modifications:

Modifications Requests,"

(10/20/86)

(Part IV), R21

" Plant Modifications: After Licensing," (03/13/87)

SQEP-12 R2

" Procedure for Evaluating Engineering Change Notice and Field Change Notice Documents,"

I (07/23/86) 1055D-26 (06/02/87)

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APPENDIX A (Cont'd) d SQEP-13, R3

" Procedure for Transitional Design Change Control" (03/05/87) l 1

SQEP-36 R1 "Workplan/ Work Request Reviews," (09/08/86) 1 g

q.

TVA memo from J. C. Standifer to ihose Listed " Checklist Attachments to ECN Cover Sheets (informal)," (03/07/86) r.

Letter fro.n G. Zech, NRC, to S. A. White, TVA, "Sequoyah ECN i

Closecut and FSAR Update," (12/18/86) j s.

Sequoyah Corrective Action Report No. SQ CAR 86 04021,

]

(04/16/86) t.

Gilbert / Commonwealth Report No. 2614:

"Sequoyah Nuclear-j Plant Modifications for TVA," (03/03/86) 3 u.

Letter from G. Zech, NRC, to S. A, White, TVA, " Notice of i

(-

Violation (Inspection Report Nos. 60-327/86-62 and l'

60-328/86-62), (03/04/87) A02 870309 006 v.

Letter from B. Youngblood, NRC, to S.- White, TVA,

" Transmittal of Draft Safety Evaluation Report on the Design Baseline Verification Program," (01/20/87) w.

Letter from R. Gridley, TVA, to B. Youngblood, NRC,

" Additional Information on Sequoyah Design Baseline and Verification Program," [L44 861211801], (12/11/86) t x.

Letter from R. Gridley, TVA, to B. Youngblood, NRC, " Draft Safety Evaluation Report - Design Baseline and Verification Program," [L44 870227 805], (02/27/87) y.

Letter from R. Gridley, TVA, to NRC, "Sequoyah Nuclear Plant

- Drawings to be Maintained As-Configured," [L44 870401 811],

(04/01/87) 1 6.

WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?

10CFR50 Chapter 1, Appendix B, " Quality Assurance Criteria a.

['

for Nuclear Power Plants and Fuel Reprocessing Plants" i

10550-26 (06/02/87)

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ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"

.s.

c.

Regulatory Guide 1.64, " Quality Assurance Requirements for c

the Design of Nuclear Power Plants," R2, (06/76)

[

d.

Sequoyah FSAR updated through Amendment 3, (04/86)

\\:

e.

TVA Division of Nuclear Engineering (DNE) Procedures Manual NEP-6.1 R0, " Change Control," (07/01/86) f.

Sequoyah Nuclear Performance Plan, Volume 2, R1, (07/14/86) g.

TVA Corporate Nuclear Performance Plan, Volume 1, R4, (03/26/87) 1.

7.

LIST REQUESTS FOR INFORMATION MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELtre.NT:

~

a.

Report of meetings in Knoxville, January 21-30,1987, IOM 619, (03/13/87) b.

Teleconference between Clift, Lyons, TVA, and Dowd, Bechtel, (IOM 723) (02/26/87) c.

RFI SQN-781, (03/26/87) d.

RFI SQN-783, (03/31/87) e.

Teleconference between Clift, Maddox, and Miller of TVA and Denny, Dowd, and Frane of Bechtel, subject: TVA comments to Element Report 204.6(B), R0, (IOM 1091), (06/01/87) l 10550-26 (06/02/87)

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r-(

(-l CATO LIST.

The following CATD form is included as part of this report:

'204 06'SQN 02 (Issues "a," "d," and "e")

J

The following CATD' identifies and provides corrective action for findings "a," "d," and "e' of this report:

201 01 SQN - 01 ( Issues "a,"

"d," and "e";. 12/16/86)

A copy of the above CATD is included for tracking purposes.

The CATDs noted below have been deleted from this report.

204 06 SQN 01, deleted 06/03/87~

204 06 SQN 03, deleted 06/03/87 g

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ECTG Corrective i

J 1

Action Iracking Document-

-(CATD)

LINITIATION ADDlicable RCTG Report No.:.

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Immediate-Corrective Action Required: -D Yes 5 No 2.'

Stop Work Recommended

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CATD No.-

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INITIATION DATE f* f' 9 7 '-

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CONCURRENCE:

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PROPOSED CORRECTIVE ACTION PLAN:

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CONCURRENCE: CEG-H:

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I ECTG PROGRAN MANAGER DATE:

i VERIFICATION AND CLOSEOUT 1

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Approved corrective actions have been verified as satisfactorily implemented, i

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Approved corrective actions have been fled iTa orily implemented.

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ization Responsible for Corrective Action Plan.

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@hu.fE ACTION PLAN (CAP):

1. Does-this report require. corrective action? <

.Yes -

No 2

-(If yes, describe corrective action to be taken, if no, provide justification):

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Identify any lar item / instances-and corrective., action taken.

3. Will corrective action preclude recurrence of findings?

Yes-

'(.No H

. 4. Does this report contain findings that are conditions adverse to cualitv (CAQ) t l'

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as defined by AI-12 or NEP 9.17:

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condition exists, what CAQ document was initiated?

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6. Which. site sagtion/ organization is responsible for corrective action?

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7. Is corrective action required for restart?

Yes V-No H

'(This detenninati'on is to be made using' Attachment C of SQA166. )-

8. P2 :one number for' restart corrective action? Zone 9///

9. Estimate completion date for correction action.

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' Mcmorandam Texxessen vattsy acritouiry To

. H. L. Abercrombie. Site Director, ONP, Sequoyah Nuclear Plant W. R. Brown, Jr.

Program Manager Employee Concerns Task Group, FROM ONP, Watts Bar Nuclear Plant DATE-

1. 13, ;. ;,,.

SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK G ELEMENT REPORTS-- ENGINEERING CATEGORY '- CONCURRENCE WIT

SUBJECT:

1

' ACTION PLAN (CAP)

The category evaluation group leader, Engineering, concurs with the CAP presented in the. referenced transmittal for the listed CATD.

CATD No.

Transmittal RIMS No.

20406-SQN-02

.T41 870729 985

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'W. R. Brown', Jr.

MT:GB Attachments cc (Attachments):

RIMS, MR AN 72A-C Phil'Brackins, FSB, ONP, Watts Bar Drue Chesney,-ECTG Bldg., ONP, Watts Bar (2)

Jack Howard, ECTG Bldg., ONP, Watts Bar k

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G. R. McNutt. ECTG Bldg., ONP, Watts Bar i

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J. gm August 18, 1987f BLT-436 Mr. George R. McNutt Engineering CEG-H Tennessee Valley Authority Knoxville, Tennessee 37902

Subject:

Watts Bar Nuclear Plant Employee Concerns Evaluation Program Tennessee Valley Authority Job No. 16985-026 CAP FOR CATD 20406 SQN 02, CAP CONCURRENCE i

Reference:

1 Letter, BLT-384, dated 08/07/87, Parkinson to McNutt Telecon, B. Wolters (Bechtel) to Roy Denney and D. T. Clift (TVA) 2 date 08/14/87 (10M-1730)

Letter, Gridley to NRC, [L44 870512 802], dated 05/12/87, 3

"Sequoyah Nuclear Plant - Postrestart Scope and Schedule for the DBVP"

Dear Mr. McNutt:

In Reference 1 Bechtel indicated that the CAP for CATD 20406 SQN 02 tran f

was not acceptable to the evaluation team and by TCAB-100, dated 07/28/87, provided the basis for the rejection. The purpose of this letter is to withdraw that rejection of the CAP.

The CAP transmitted by TCAB-100 committed only to the issuance of DHE procedures NEP-6.3, 6.4, 6.5, 6.6 and 6.7 to reflect the design control program committed to in the Corporate and SON Nuclear performance plans, and did not adequately address the implementation schedule.

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Reference 2 records the discussion of this CAP between the named individuals l

08/14/87, following receipt and review by Bechtel of Reference 3.

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D. McMutt 4uqust 14, 1997 Pane Two-Reference 3 contains a formal commitment by TVA to t(s NRC to implement the PMP at SON;and also provides a schedule for doing so. 'The commitments are listed in.

the Coroorate Tracking System (CCTS) as Items NCO-0870184001, NCO-0870184002, NC0-0870184003, and NC0-0870184004. This schedule.is acceptable to the l

l Evaluation Team.-

The aforementioned CAP, as supplemented by the commitments of Reference 3, is now acceptable to the Evaluation Team and will be incorporated-in the_ subcategory report.

Very truly yours, I

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G. L. Parkinson l

Project Manager (f

GLP/RW/rl/34660 i

8/19/87---GRM:RMW 4

-cc:. RIMS, MR 4N 72A-C D. T. Clift, 9-162 SB-K i

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~ W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, l

Watts Bar Nuclear Plant 'P. D. Brackins, Project' Manager, ONP, Watts Bar Nuclear Plant FROM July 29, 1987 DATE (

SUBJECT:

WATTS BAR NUCLEAR PLANT (WBN) - TRANSMITTAL OF ECSP CORRECTIVE ') ACTION TRACKING DOCUMENT (S) (CATD) l ECSP Fact Sheet Number ECSP CATD(s) Number ?O406-m N-02 F1 The above listed, completed CATD(s) are being returned according to j your instructions. D s. t 1 P. D. Brackins PDB:NC' l Attachments i cc (Attachments): RIMS, MR 42 72A-C 7 ;:wm l J..- '[ 'l i i s a [ h. ~ 7 C9 &, ~ Mr -. 69.: :. :.. ~., .m .... ~. .. j O\\ %% t* SU - - - _ _ _ - _ _. - _ _ __ ____ h _.

v i ......s~. ' r N n E n,o N11:8 G oVI:R N Ml W l' 503 870721 851 -sses vmv acTury 1M em o ra n d um 'J. L. McAnally, Corrective Action Program Manager, ONP, Watts Bar Nuclear Plant ; T" I H. L. Abercrombie, Site Director. 0&PS-4, Sequoyah Nuclear Plant F"UM-July [27,1987 DATE SEQUOYAH' NUCLEAR PLANT (SON) - EMPLOYEE CONCERNS T St* HJ ECT: REPORT 204.06 SQN R1 - ENGINEERING CATEGORY - CORRECT j Your memorandum to R. C. Denney dated June 16,.1987,. " Watts - Bar ~

Reference:

Nuclear Plant (WBN) - Transmittal of ECSP Fact Sheets and' l Corrective Action Tracking Documents (CATDs) - WBN" 1 I acknowledge. receipt of your element report and in accordance with your i request (see reference), Element Report 204.06 SQN has been reviewed.for 'i applicable corrective action. 1 By way of this memorandum-I am endorsing the site line i This CAP is not a restart-attaching the CAP for your review / concurrence. requirement. .below item 9 on the CAP tracking checklist and return the C l checklist. $$ k M H. L. Abercrombie RCD:JDS:JB:MJW Attachments cc (Attachments): RIMS, MR 4N 72A-C (B25 '870715 034) (w/ reference) W. R. Brown, ONP, Watts Bar (w/ reference) T. C. Price, 5-212 SB-K (w/ reference) 04330 { l l 1{ j OI .m_

I j 1 j i 3 ECTG Corrective Action Trectinr. Document 1_CATD ) ~ -IflITIATION Applicab1<, EC G Roport No.: c) O y, d (, h,) i 1. Imediato Corrective Action Requirodi O Yes a No l 2. .Stop Wort Rococznonded: O Yes a No 3. CATD No. JoV o6 5au o2 4 INITIATION DATE f-6 9 7 5. RESPONSIBLE ORGANI*lATION: 1Ms $ C d' I 6. PROBLEM DESCRIPTION: E QE.O NQR Al A k m fL-e 1- - ' mmA AJ U - 6. t, j ~ ' Ckt W "JJ &,Jw M C n%# M A-m i M MA_ M <h h h A O t 4 h* C 5 uM d #A Esh m.<ch e.44_ W 4 C 'A-MhW 'M' (Ce b ) a-- / W di %da cM Ars-M M w.2 M.4A M v+ L.4Wa J O m J a. ' P' : i m /' L_ M A m ak %. -J_ 4 t W i O ATTACHMEhTK 7. PREPARED BI: NAME h 4 ,0. dw r-*'.- - W hf/d'L'DATE: O F E'? 8. CONCURRENCE: CEG-H VMu (L N O W A W / DATE: 4 t0 Y7 9. APPROVAL: ECTG PROGRAM MGR. 4 '65 A% /44 /2tDATE: 6/ ///47 .i .y (, s %.~".0 ERECTIVE ACTIOK [ ) 10. PROPOSED CORRECTIVE ACTION PLAN: Tec 'T/ # bA 8 ' M2 /' /> 6Af NT @ } f f //ffA13CA/JT>vM 8 ? 5 E?~') o *7 i G O S i.f O ATTACHMENTS 11. PROPOSED BY: DIRECTOR /MGR: 4 # /#ed /A, DATE: '7 -2. 7-/ ~1 12. CONCURRENCE: CEG-H: %; /,4ve 4-San DATE: F->v-P7 ECTG PROGP.AM.MARAGER

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DATE: (/2dh7 VEEIFTCATION AND CLOSEOUT U i 13. Approved corrective actions have been verified as satisfactorily i:::pleme n t ed. j i i SIGNATURE

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] e t 1 Standard Practice Page 9 f + l SQA166 ~ L' 1 Revision 9 ~ I Attachmeat A Page 1 of 2 ? i Corrective Action Plan of Employee Concern Investigation ~ l Tracking Checklist ECTG Report /CATD Number Et%#6 58///'/ ft14.#6.IfM MS-f Lead Organization Responsible for Correc6ive Action Plan B//g S#A/ Initiation Dato e77//4*/(V / / 4 CORRECTIVE ACTION PLAN (CAP)

1. Does this report require corrective action?

Yes / 'No (Ifyes,describecorrectiveactiontobe)taken,ifno,providejustification1'b 8%&?A /s(GtA'fejn/A k&'tWbWfAd //Vff - 6.i' l'.4-6 Fh& /?A O h Y / T ida. At/fraco Af #srvstezcaK /7stkirspshs(1A17t> /etkr WM bff44A } DA%fel A?tYd/as Gm&/77?> 171/Af D/S 0/LA14/9/X. /7s/D ffa' ist? yds / >Vw't in t fMArA/M/9 ATE f/AAT. 2. Identify i,milar item / instances and corrective action taken. ) 4/\\No

3. Will corrective action preclude recurrence of findings?'

Yes

4. Does this report contain findings that are, conditions adverse to cuality /(CAC YES No as define'd by AI-12 or NEP 9,17

5. IF a C Q ondition exists,.what CA@' document was initiated?

e section/ organization is responsible for corrective action?

6. Which sit,//$

l l DAf / K., Yes No /

7. Is corlective action required for restart?

(This determination is to be made using Attachment C of A166.) ( t

8. P2 zone number for restart corrective action? Zone A,

i j

9. Estimate completion date f orrection action. Ad -#4W4/F #

1 ~

1. 7//P/8'/

Completed By [.// / Date l Approved By ' (AC -/d. ~ 5 //h ,3 Date 77/6/d'd i ECTG Concurrence 7)U% f//t/ f/cd7 Date E"46 4 7 ? \\ / \\ 1 J t I i ( l~ 0206S/mit i

.,--.,'6-i l 4 Standard Practice Page 9 '.f SQA166 Revision 9 l ATTACIMENT A Page 2 of 2 CAP CLOSURE

10. Was your-corrective action initiated and completed in accordance with. step l?

Yes - No

11. If step 10 is no, describe the corrective action taken.

~ ~ ~ ~ ~ ~

12. Is the corrective action implementation complete?

Yes No

13. Is the corrective action documentation closed?

Yes No

14. What documents were used to implement the corrective action?

. Completed By: Date Verified By: Date ECTG Closure: Date (Step No.) Description \\ i \\ - 4 l / m s }}