ML20237K579
| ML20237K579 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/20/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8708270221 | |
| Download: ML20237K579 (4) | |
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. TENNESSEE VALLEY AUTHORITY
~ CHATTANOOGA TENNESSEE 37401 SN 157B Lookout Place.
AUS #01987 U.S. Nuclear Regulatory Commission-ATTN: Document Control Desk i
Washington, D.C.
20555 g'
' Gentlemen:
In the Matter of.
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Docket Nos. 50-327 4
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50-328' SEQUOYAH NUCLEAR PLdNT (SQN) _ CONTROL AND PROCESSING 0F. CHANGES TO PUNCHLIST During the'recent NRC inspection of the Design Baseline:and Verification Program-(DBVP),'the inspection team issued an observation that was related to the control of changes to punch 11st action items generated by DBVP. 'Although these items are controlled by SQN Engineering Procedure SQEP-45, " Control'of Design Baseline and Verification _ Program Action 1
Items," NRC expressed a concern that changes are now occurring to the
-punchlist without DBVP' system engineer (SE) concurrence.
SQEP-45, section 3.2, provides means to update action item status and specifies..that the' responsible action party-(RAP) pr_ ovide a proposed corrective action and restart category for punchlist items.
Revision 3 of the~ procedure also requires RAP to obtain concurrence from the DBVP SE and discipline evaluation supervisors-on punchlist item corrective action and categorization; however, SQEP-45 does not address the necessary actions to be taken when RAP. determines that subsequent changes to these decisions are appropriate.
To address this situation and in conjunction with the disposition of
-Condition Adverse to Quality Report (CAQR) SQT871268, Directive DBVP-D-87-008 (enclosed) has been issued to clarify the requirements for controlling changes to the SQEP-45 punchlist. _The Engineering Assurance Oversight Review Team has concurred with the disposition of CAQR SQT871268 and, as'part of their independent review of DBVP, will verify
. implementation of actions defined by the subject directive.
Use of the directive.in conjunction with SQEP-45 will control future changes to the punchlist.
Punchlist changes occurring before l
. implementation of the directive are being reviewed, categorized, and I
dispositioned in accordance with the directive's punchlist change categories.
TVA believes that these actions adequately address NRC's concerns.
8708270221 870820 PDR ADOCK 05000327 o)
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An Equal Opportunity Employer
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-U.S. Nuclear Regulatory Commission MB 201987
.If'you have any questions concerning this issue, please telephone Beth L. Hall at (615) 870-7459.
Very truly yours, TENNESSEE VALLE AUTHORITY R. GYidley, Dire tor Nuclear Safety nd Licensing Enclosure cc (Enclosure):
Mr. G. G. Zech, Assistant Director for Inspection Programs Office of Special Projects U.S.-Nuclear Regulatory Commission Region II.-
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. J.-A. Zwolinski, Assistant Director for Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
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Direc tive' No. : DBVP-D-87-008 B25
,870806 008'
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-Affeeted Procedures.SQEP-45 i
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Date: August 5, 1987.
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SUBJECT:
Control and Processing of Chang's to SQEP-45 Punchlist l
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J This ' directive clarifies the requirements. for controlling changes to l
the SQEP-45 punchlist. This guidance is to be used in conjunction j
with SQEP-45 when preparing and processing a change to the SQN Ur.it 2 i
-punchlist.
Section. I provides a categorization of changes to the punchlist. All future changes to the punchlist must specifically state, on all Attachment 2s, the'section I category which applies and must be processed in accordance with section II of this directive l
which clarifies the review approvals necessary for each of the i
punchlist change categories discussed in section I.
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,i section III of this directive clarifies the administrative requirements for verifying accuracy of the punchlist data prior to '
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dis tribution.
I Section I.
Punchlist Change Categories 1
A.
Administrative Changes - Changes which are based on an existing Attachment 2 and are being made for clarity and/or consistency between the existing Attachment 2 and the punchlist with no changes on Attachment 2 for' restart category or to the corrective actions.
4 B.
Implementation Status Changes - Changes where the punchlist corrective action consists of both restart and post-restart j
corrective action elements and/or the restart work is fully implemented and the restart categorization is being changed as a result of work implementation providing that the SE has already signed an Attachment 2 agreeing with the pre / post restart category and corresponding corrective actions.
C.
Technical Changes - Changes to punchlist corrective actions and/or restart categories other than those outlined above.
Section II - Required Review Approvals for Punchlist Changes The approvals required for the different punchlist change categories of this directive are as follows:
A.
Administrative Changes
- Require no additional RAP, SE, or DES review / approval as no changes to the Attachment 2 are required.
B.
Implementation Status Changes
- If the change is determined to be an implementation status changes as defined in Section I.B above, the change requires RAP sign-offs of Attachment 2 in accordance with SQEP-45 but does not require SE or DES approval signatures.
R71208.01
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Examples of implementation status changes are:
- 1) MCR Drawing Changes - Correction of DD's involving MCR drawings involve a two step process. MCR drawings are red-lined prior to restart and actual changes to drawing originals are accomplished post restart.
In this case, it would, be acceptable ~ after the red-line process is complete i
to" change-the restart category from "Y" to "N" without SE/ DES concurrence.
- 2) SQEP-14 Testing - It is acceptable to change the restart status of a punchlist item on SQEP-14 testing from "Y" to "N" af ter review and approval of the test results by the appropriate RAP.- No concurrence of this type change is required of the SE or DES.
C) Technical Changes - Require RAP, SE, and DES approval in
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full accordance with SQEP-45. The RAP must ensure that no
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technical changes to existing punchlist items are completed j
before Attachment 28 are processed in full accord with SQEP-45.
I Section III - Punchlist Administrative Requirements In ' order to ensure consistency and correctness of the' punch Ust and data entry, the following control process will be used. All changes will be
-j submitted to the Punchlist Coordinator on an Attachment 2 in accordance j
with SQEP-45. The Punchlist Coordinator will perform an administrative
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review of the attachment to ensure that the requirements of SQEP-45 and l
this directive have been met.. Upon completion to this review, the punchlist will be updated to reflect the revised information.
After data, 3
entry ar..d p_rior to distribution, the Punchlist Coordinator will verify the correctness of the data entry.
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l yJ.B.Hosmer See page 3 for distribution h
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i R71208.01 i
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