ML20207L057

Rev 4 Sequoyah Nuclear Plant Element Rept, Workplan Process

ML20207L057
Person / Time
Site:	Sequoyah
Issue date:	12/19/1986
From:	Murphy M, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K654	List: ML20207K650 ML20207K665 ML20207K686 ML20207K717 ML20207K731 ML20207K740 ML20207K758 ML20207K785 ML20207K800 ML20207K821 ML20207K827 ML20207K849 ML20207K858 ML20207K881 ML20207K917 ML20207K942 ML20207K968 ML20207K979 ML20207L004 ML20207L017 ML20207L057 ML20207L069 ML20207L089
References
307.04-SQN, 307.04-SQN-R04, 307.04-SQN-R4, NUDOCS 8701090606
Download: ML20207L057 (10)

Text

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 307.04-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 4 TITLE: Workplan Process REASON FOR REVISION:

Revised to incorporate SRP and TAS comments Revision 1 Revised to incorporate SQN corrective action response and SRP comments Revision 2 Revised to incorporate 4 additional concerns Revision 3 and SRP comments on Revision 2.

Generic Applicability made consistent with findings Revision 4 and data base PREPARATION PREPARED BY:

J. K. McClanahan

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

1635T 8701090606 861224 PDR ADOCK 05000327 p

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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Nuclear Power / Site Program / Procedure Element: Workplan Process Report Number:

307.04 - SQN, Revision 4 E-85-070-005

'y H-85-070-003 l

SQP-86-003-003 l

IN-85-305-NO3 SQP-86-003-N06 E-85-070-002 H-85-070-006 l

Evaluator:

J. K. McClanahan

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Reviewed by:

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W. R. Lagergren Date 1635T

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TITLE Workplan Process This report is the result of an evaluation of the workplan processing procedures and the reuse of certain materials during plant modification work at the Sequoyah Nuclear Plant (SQN).

In addition, concern number XX-85-070-003 is a shared concern with the Engineering Category and XX-85-070-006 is a shared concern with the Intimidation and Harassment Category.

II.

METHODOLOGY The K-forms for the seven concerns which make up this element were reviewed and are stated as follows:

1.

XX-85-070-005 Sequoyah: Workplan (number known) to take equipment out of service for repair / modification was never authorized by engineering but work plan modifications have been completed.

(names / details to the specific case are known to QTC and withheld to maintain confidentially). Nuclear Power Concern. CI has no further information.

2.

XX-85-070-003 Sequoyah: Workplans contain inaccurate data. Majority of the DCR's taken care of but not documented right and drawings do not reflect the as-built conditions. Details withheld to maintain 4

confidentiality. Nuclear Power Concern. CI has no further l

information.

3.

SQP-6-003-003 Conduit is currently being removed and reinstalled (rerouted) without proper documentation. Lower containment.

Fan room 1, unit 2, approximate elevation 680'.

Workplan 11882. Nuclear Power Concern. CI has no further information.

4.

IN-85-305-NO3 No administrative procedure exists for controlling field

)

modifications for vendor supplied items. NRC concern.

5.

SQP-86-003-N06 If documentation deficiency for SQP-86-003(-003) is substantiated, it would be QA violation of Appendix B and would be reportable.

The subject form (ERT fonn M) indicated it is not reportable. NRC concern.

i i

Page 1 of 6

6.

XX-85-070-002 Sequoyah units 1 and 2.

CI expressed a concern that specific quality problem (open since 1980) are in the process of being intentionally closed in a dubious manner to prevent attracting the attention of the NRC.

(Names / details to the specific case are known to QTC and withheld to maintain confidentiality). CI has no more information. Nuclear power department concern.

7.

XX-85-070-006 Sequoyah unit 1 and 2: Closure of specific quality documentation is being falsified in order to close these problems out before the NRC becomes aware of them.

(Names / details to the specific case are known to QTC and withheld to maintain confidentiality). Nuclear power concern. CI has no further information.

The documents which define the requirements applicable to these concerns were reviewed as well as the plant standard practices and instructions which implement these requirements. A listing of these documents is contained in the Reference section of this report. Two Nuclear Safety Review Staff (NSRS) reports (I-85-637-SQN and I-85-206-SQN) which deal with these concerns were also reviewed for information applicable to this evaluation.

No personnel interviews were conducted during this investigation.

This element consists of three distinct issues which will be referred to as supplements. The first issue (supplement A) addresses concerns SQP-86-003-003 and SQP-86-003-N06 which deal with the reuse of electrical conduit at SQN and the alleged failure to document this work. The second issue (supplement B) addresses concerns IX-85-070-002, XX-85-070-003, XX-85-070-005, KK-85-070-006 which deal with the failure of the modification program to ensure that drawings are updated to reflect system changes and the failure to obtain the necessary authorization for each workplan. The third issue (supplement C) deals with the procedural controls for plant modifications to vendor supplied itcm and addresses concern IN-85-305-NO3.

III. FINDINGS A.

Evaluation Results Supplement A - Undocumented reuse of electrical conduit i

NSRS Report I-86-206-SQN addresses this issue and contains additional clarification of the concern from the concerned individual (CI). The CI identified the specific incident which precipitated the concern.

In this additional information the CI describes the reuse of rigid conduit, which the CI believed to be a violation of TVA procedures and the failure to document this rework.

Page 2 of 6

4 The reuse of materials. (i.e., cable, conduit, etc.) is not a violation of TVA policy as long as the materials meet the specifications for the new application. However, no procedures exist which specifically address the reuse of rigid electrical conduit.

Procedures do exist for the repulling of cable, for example, which suggests that procedures for the reuse of conduit should also be prepared.

Supplement B - Failure to update drawings and obtain proper sign-offs for modification workplans.

NSRS Report I-85-637-SQN documents several cases in which workplans were completed without the required sign-offs and without completion of documentation, specifically the updating of plant drawings. Based on the specific examples in the NSRS report, these conditions are shown to be prevalent especially in workplans dealing with non-CSSC equipment which do not receive QA review.

i Supplement C - No administrative control procedure for modifications to vendor items.

Administrative Instruction (AI)-19 (Part IV) is the controlling document for all plant modifications after the plant is licensed.

This procedure controls the preparation, execution and close-out of all workplans which are required for the modification of any plant equipment.

B.

Conclusions Supplement A This concern is not valid and, based on the above findings, is not safety-related. The reuse of rigid electrical conduit is not a violation of any plant policy or procedure. The NSRS report recommends that the reuse of conduit be specifically described in a plant procedure to ensure that the conduit meets the specifications for the new application. This evaluator agrees and concurs with the NSRS report findings and recommendations.

• Since the concern expressed in SQP-86-003-003 is not substantiated, no QA violation of Appendix B has occurred and concern SQP-86-003-N06 is not substantiated The plant staff response to this recommendation is concurrence.

This procedure revision is being tracked on the Corrective Action Tracking System (CATS) as items86-103 and 86-104.

The current completion date is August 31, 1986.

Supplement B The concern addressing the failure to update plant documentation.

specifically plant drawings, to show new equipment configurations was validated by the NSRS review. This report confirmed the NSRS report findings. In response to this item the plant initiated a plant wide system walkdown program to ensure the current Page 3 of 6

o configuration and a program to review and close all open engineering change notices (ECNs).

Both of these programs are now in progress. The system walkdown program is described in Special Maintenance Instruction Procedure SMI-0317-30, and is scheduled to be completed by November 30, 1986. The ECN Closure Project is conducted in accordance with AI-19 and is under the direction of the ECN Closure Project Supervisor. This program currently has no completion date assigned, although this lack of completion scheduling appears to present no problem to plant safety because any configuration discrepancies resulting from open ECNs will be identified by the currently active plant system walkdown programs.

These programs exceed the recommendations of the NSRS report by attempting to identify any configuration discrepancies that may exist.

The concern addressing the failure to obtain all required signatures before the completion of workplans was also validated.

However, the NSRS report recommendations to require that all workplans be reviewed by the Quality Assurance Supervisor was rejected by the plant staff in their response to the NSRS report. The QA staff deals only with QA documentation. The non-CSSC workplans are not QA documents and the review of these non-CSSC workplans should remain with the workplan initiator.

To alleviate the appearance of insufficient documentation on non-CSSC workplans, AI-19 may need to be revised to allow non-CSSC workplans to be handled differently than CSSC workplans. This revision may describe the less restrictive documentation necessary for non-CSSC workplans.

Supplement C This concern alleged that for field modifications to vendor supplied items there exists no administrative control procedures. This concern is not substantiated since AI-19 (Part IV) controls all field modifications made after the plant is licensed. AI-19 (Part IV requires that a workplan be written and approved before modification to any plant equipment). Controls exist for field modifications regardless of how the item is supplied or who initiates the modification.

IV.

ROOT CAUSE I

Supplement A root cause, was the lack of procedures that specifically addressed the reuse of rigid electrical conduit.

The root cause for Supplement B was a failure to update plant documentation, specifically plant drawings, to show new equipment configurations and the lack of differentiation between CSSC and non CSSC workplans in procedure AI-19.

The concern in Supplement C was not validated, therefore no root cause exists.

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e V.

GENERIC APPLICABILITY Six of the seven concerns composing this element are specific to the l

Sequoyah Plant. The applicability of the validated concerns to other l

~TVA plants must be determined by a review of the modification I

' procedures at each plant and a review of completed workplan packages.

lR4 The unvalidated concerns are considered not to be generic to other I

sites. Hence, concerns XI-85-070-002, 003, 005, and 006 are generic to l

all sites.

Concern IN-85-305-N03 is specific to WBN.

I VI.

REFERENCES 1.

Topical Report TVA - TR 75-1, R8 a.

Section 17.2.3, " Modification Control" b.

Section 17.2.5, " Instructions, Procedures, and Drawings" 2.

ONP Nuclear Quality Assurance Manual a.

Part II, Section 3.2, " Plant Modifications: After Licensing,"

June 24, 1986 b.

Part I Section 2.2 (ID-QAP-2.4). " Control of Modifications "

June 24, 1986 l

c.

Part I, Section 2.6 (ID-QAN-6.1), " Configuration Drawing Control." June 18, 1986 3.

Sequoyah Instruction Manuals a.

SQA 122 "Non-CSSC Equipment Performance Assurance Program " RO b.

AI-19 (Part III), " Plant Modifications: Modification l

Requests " R13 i

c.

AI-19 (Part IV), " Plant Modifications: After Licensing," R18 d.

AI-25 (Part I), " Drawing Control After Unit Licensing," R15 e.

AI-25 (Part II), " Revision of As-Constructed Drawings," RO Page 5 of 6

l I

4.

Memorandum from K. W. Whitt to H. L. Abercrombie dated March 3, 1986, " Nuclear Safety Review Staff Investigation Report Transmittal," Report Number I-85-637-SQN, " Work Plan Processing."

5.

Memorandum from H. L. Abercrombie to R. P. Denise dated July 8, 1986, " Nuclear Safety Review Staff (NSRS) Report No. I-85-637-SQN,

" Work Plan Processing" 6.

Memorandum from K. W. Whitt to H. L. Abercrombie dated March 17, l

1986, " Nuclear Safety Review Gtaff Investigation Report Transmittal, " Report Number I-86-206-SQN Conduit Removal and Replacement Without Proper Documentation" 7.

Memorandum from H. L. Abercrombie to K. W. Whitt dated April 17, 1986, " Nuclear Safety Review Staff (NSRS) Investigation Report I-86-206-SQN El, " Conduit Removal and Replacement Without Proper Documentation" VII. INNEDIATE AND LONG-TERM CORRECTIVE ACTIONS Supplement A:

MLAI-6 " Conduit Installation," is being revised.

The revision is typed and awaiting PORC approval.

Supplement B:

No corrective action required. All sign-off not applicable to a non-CSSC workplan must be marked "N/A."

No workplan sign-off shall be left blank.

The above corrective action statements are as stated by the SQN Corrective Action Plan (CAP) in response to RCTG element report 307.04 SQN.

(S03 860916 801 and CATD 30704-SQN-01 and CATD 30704-SQN-02)

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O SETI&Ie:E

- ISSS*2IJ-fCPSI2IC TFumFttEE VALLEY AUTNGRITY PAGE FRE4;ENCY

- REQUEST OFFICE OF NUCLEAR PDHER RUN TEUE -

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ONP - 1555 - NNM EMPLOYEE CONCER:] P 0 GRAM SYSTEM (ECPS)

RUN DATE -

LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30704 NORK PLAN PROCESS 3

S GENERIC KEYHORD A H

APPL QTC/NSRS P

KEYHORD B CONCERN SUB R PLT BBSW INVESTIGATION S

CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB

' REPORT R

DESCRIPTION KEYHORD !

D IN 305-NO3 EN 20410 S HBN YYYY NS NRC IDENTIFIED THE FOLL0HING CONCERN OP 30704 REPORT FROM QTC REPORT IN-85-305-001.

"N0 ADMINISTRATIVE PROCEDURE EXISTS FOR CONTROLLING FIELD MODIFICATIONS FOR

)

VENDOR SUPPLIED ITEMS."

SQP-86-003-N06 OP 30704 N SQN NNNN NS NRC IDENTIFIED THE FOLLOHING CONCERN

)

K-FORM BASED ON REVIEH OF QTC FILE.

"IF D OCUMENTATION DEFICIENCY FOR SQP-86-0 03C-003) IS SUBSTANTIATED, IT HOULD BE QA VIOLATION OF APPENDIX B AND H0 ULD BE REFORTABLE.

THE SUBJECT FORM

)

(ERT FORM M) INDICATED IT IS NOT RE FORTABLE."

3 SQP-86-003-303 DP 30704 N SQN NNNN I-86-206-SGN SS CONDUIT IS CURRENTLY BEING REMOVED A NONCONFORMANCE T50246 K-FORM ND REINSTALLED (REROUTED) HITHOUT PR CORRECTIVE Af OPER DOCUMENTATION.

LOWER CONTAINME ELECTRICAL NT, FAN ROOM 91, UNIT 2, APPROXIMATE CONDUIT LY ELEV. 680'.

HORK PLAN 11882. NU 3

CLEAR P0HER CONCERN. CI HAS NO FURT HER INFORMATION.

)

XX 070-003 EN 20601 S SQN YYYY I-85-637-SON SS SEQUOYAH: HORK PLANS CONTAIN INACCU HORK PLAN / PACKS T50I80 OP 30704 K-FORM RATE DATA. MAJORITY OF THE DCR'S TA DRAHINGS KEN CARE BUT NOT DOCUMENTED RIGHT AN OPERATIDHS D P1AHINGS DO NOT REFLECT THE AS-BUI GENERAL LT CONDITIONS. DETAILS HITHHELD TO

)

MAINTAIN CONFIDENTIALITY. NUC P0HER CONCERN.

C/I HAS NO FURTHER INFORM ATION.

)

XX 070-005 OP 30704 N SQN YYNY I-85-637-SQN SS SEQUOYAH: HORK PLAN (NUMBER KNOHN) T RECORDS 750I80 K-FORM 0 TAKE EQUIPMENT DUT OF SERVICE FOR NONCONFORMAN(

REPAIR / MODIFICATION HAS HEVER AUTHOR OPERATIONS

)

IZED BY ENGINEERING BUT HORK PLAN MO REPORTS DIFICATIONS HAVE BEEN COMPLETED.

(N AMES/ DETAILS TO THE SPECIFIC CASE AR E KNDHN TO QTC AND HITHHELD TO MAINT

)

~

• AIN CONFIDENTIALITY). NUCLEAR P0HER CONCERN. C/I HAS NO FURTHER INFORM ATION.

)

,s' CONCERNS FOR CATEGORY OP SUBCATEGORY 30704 7

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RtrrRINCE

- ECPS112J-ECPSII2C TENNESSEE VALLEY AUTHORITY PAGE

- e 1.':

IK!QULNCY

- REQUEST OFFICE OF NUCLEAR PONER RUN TIME - 19 :

DNP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DATE - 09/t LIST OF EMPLOYEE CONCERN INFORMATION S

GENERIC KEYHORD A H

APPL STC/NSRS P

KEYUORD B CONCERN SUB R PLT BBSW INVESTIGATION 5

CONCERN KEYMORD C NUMBER CAT CAT D LOC FL45 REPORT R

DESCRIPTION KEYHORD D XX 070-002 4NH

• Cl S-N SQN YEYY I-85-637-SON SS SEQUOYAN UNITS SI & 02.

CI EXPRESSE QA PRGGRAM

~

T50140 op 3c7c4 K-FORM D A CONCERN THAT SPECIFIC QUALITY PR PROGRAMMATIC OBLEMS (OPEN SINCE 1980) ARE IN THE OPERATIONS PROCESS OF BEING INTENTIONALLY CLOSE GENERAL D IN A DUBIOUS MANNER TO PREVENT ATT i

I RACTING THE ATTENTION OF THE NRC.

(

NAMES / DETAILS TO THE SPECIFIC CASE A RE KNONN TO QTC AND HITHHELD TO MAIN TAIN CONFIDENTIALITY). CI HAS NO M0 RE INFORMATION. NUCLEAR POWER DEPT CONCERN.

XX 070-006 IH 00000 S SQN YYNY I-85-637-SON SS SEGUOYAH, UNIT I AND 2: CLOSURE OF S QA PROGRAM T50180 db&- 4HHHHF S K-FORM PECIFIC QUALITY DOCUMENTATION IS BEI RECORDS cP 3o7 c"&

NG FALSIFIED IN ORDER TO CLOSE THESE OPERATIONS PROBLEMS OUT BEFORE THE NRC BECOMES REPORTS ANARE OF THEM.

(NAMES / DETAILS TO T HE SPECIFIC CASE ARE KNOHN TO QTC AN D HITHHELD TO MAINTAIN CONFIDENTIALI TY).

NUCLEAR P0HER CONCERN. C/I HA S NO FURTHER INFORMATION.

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