ML20207S481

Rev 4 to Instruments,Matl,Equipment Re Purchasing & Requisitions

ML20207S481
Person / Time
Site:	Sequoyah
Issue date:	03/11/1987
From:	Hutzler C, Stewart D, Wiley M TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207S465	List: ML20207S464 ML20207S467 ML20207S470 ML20207S473 ML20207S481
References
MC-40201-SQN, MC-40201-SQN-R04, MC-40201-SQN-R4, NUDOCS 8703190523
Download: ML20207S481 (9)

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- TVA RMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN

- SPECIAL PROGRAN ,

REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 4 ,

(Final)

IITLE: Instruments. Material, Equipment PAGE 1 0F 8 as it Relates to Purchasing and Requisitions RRASON FOR REVISION:

Revision 1: Revised to incorporate comments from the Technical Assistance Staff (TAS) and the Senior Review Panel (SRP). ,

Revision 2: Revised to incorporate comments from TAS and SRP.

Revision 3: Revised to include corrective action, make minor editoral changes, and add Attachment A.

Revision 4: Revised to include comments from NRC,

- PREPARATION PREPARED BY:

7 7/a d / & b bg sh/s, SIONATURE DATE REVIEWS _

PEER:

M LJ. H S ' NATURE 3- to - s 7 DATE htTAS:

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N/ SIGNATURE DATE t- CONCURRENCES

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CEG , (R $fl0f07 SRP: 3-1I~ 7 SIGNATURE DATE SIGNATURE

• DATE APPROVED BY: \/

u p) &.0b%{ A 8 ln lR] N/A ECSP MANAGER DATE _ MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) l *SRP Secretary's signature denotes SRP concurrences are in files.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN

, SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 2 0F 8

-I . INTRODUCTION There were three concerns IN-85-463-008. IN-85-463-007, and. IR4 IN-85-964-003) in this element relating to the relocation of equipment. All of these concerns were specific to Watts Bar Nuclear Plant (WBN) and determined to be potentially generic to Sequoyah (SQN) during the WBN evaluation. Additionally, the TVA-SQN Generic Concern Task Force (GCTF) evaluated concerns IN-85-463-008, IN-85-463-007, and IN-85-964-003 at SQN. j II.

SUMMARY

OF PERCEIVED PROBLEMS Two issues were identified from these concerns. An investigation -

was conducted to assess:

1. The adequacy of drawing revisions to reflect changes for the substituted / replaced equipment or material transferred.

2. The adequacy of documentation and drawing generation / revision for-the transfer of unit 2. proccure differential transmitters 2-PDT-30-42, 43, 44, and 45 to SQN from WBN.

III. EVALUATION METHODOLOGY A. Reviewed expurgated files to determine if additional information existed for applicable equipment and material transferred between TVA facilities, units, or systems.

B. Determined if concerns had been previously evaluated and reports issued.

C. Reviewed the following documents / procedures

1. Purchase requisitions

2. Requests for shipment of material

3. Shipping tickets / orders

4. Power storeroom requisition orders

5. Materials receipt inspection reports

6. Receiving reports

7. Statements of certificatten

8. Quality release reports

9. TVA NSSS shipping releases

10. Changes of contracts

11. Surveillance Report No. 3-86-5-002

12. Corrective Action Report SQ-CAR-86-04-023 4

f TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN

- SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 3 0F 8 I III. EVALUATION METHODOLOGY (continued) i

( C. Reviewed the following documents / procedures: (continued) i I SQA45. Revision 21, " Quality Control for Materials, Parts and Services SQA134, Revision 7, " Critical Structures, Systems, and

) Components (CSSC) List" l SQA159. Revision 1, " Standards and Guides for Quality j Assurance Level III Items" i

I SQA160, Revision 3, " Material Which May Come In Contact With Reactor Coolant"

- SQA161, Revision 1, " Procurement of 10CFR50.49 Equipment" SQA162. Revision 1 " Purchase Specifications For CSSC l Materials' t

SQM2, Revision 16. " Maintenance Management System" 4

i AI-9, Revision 19, " Control of Temporary Alterations and Use of the Temporary Alteration Order" j AI-11 Revision 35 " Receipt Inspection, Non-Conforming Items, QA

< Level / Descriptions, Changes and Substitutions"

$ AI-19, Part III, Revision 23, " Plant Modifications:

Modification Requests" AI-19, Part IV, Revision 12 " Plant Modifications: After Licensint" l AI-36, Revision 8. " Storage, Handling, and Shipping of QA l Material" h

D. Reviewed SQN Generic Concern Task Force report for IN-85-463-008,

IN-85-463-007, and IN-85-964-003 to determine adequacy of findings and conclusions.

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. E. Interviewed knowledgable individuals from Maintenance Design Support, Pcwer Stores, and Quality Assurance to determine if adequate guidance was available from the procedures and reports as listed in part III C in this element report.

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 4 0F 8 IV.

SUMMARY

OF FINDINGS Lettered findings correspond to lettered evaluation methodologies.

A. ECTG expurgated files were reviewed and it was found that concern number IN-85-463-008, for the transfer of Pressure Differential Transmitters 2-PDT-30-42, 43, 44, and 45, has been resolved to the satisfaction of the concerned individual and is no longer a concern.

Purchase Requisition 970095 was written to transfer the above PDTs from WBN.- The documentation was reviewed in accordance with AI-11. Subsequently, it was also reviewed by Quality Assurance (QA), Division of Nuclear Engineering (DNE), and Environmental Qualification Project (EQP) personnel and found acceptable.

No further information was found from the ECTG expurgated files

. involving concern numbers IN-85-463-007 and IN-85-964-003. lR4 B. GCTF investigation report was found for concerns IN-85-463-007, 008, IR4 and IN-85-964-003.

C. Reviewed SQN documentation and procedures listed in section III C 4 of this element report and found that all the procedures in section III C were complied with and documentation was properly ~

generated to transfer transmitters 2-PDT . 42, 43, 44, and 45 in concern IN-85-463-008.

Reviewed Standard Practice, SQA45 Revision 18 (November 21, 1985),

Quality Control for Materials, Parts and Services, which governs the procurement of parts, materials and services for application to q the SQN and found that it established purchasing as the responsible staff for all procurement. SQA45 designates the purchase request originator as the person responsible for specifying quality assurance (QA) requirements for the purchase. The Standard Practice requires the originator to specify several characteristics

] including component ID number, system number, exact location or function, piping class, vendor style, vendor part of vendor drawing

! number, size, and design, 10 CFR Part 21 applicability, QA level, g Environmental Qualification (EQ) applicability, and Certification of Conformance documentation.

The current procedure (SQA45. Revision 24) requires a review of the lR4 purchase request by the Support Services, Material Unit for appropriate QA Level, and a technical review of QA Level I and II items. The QA levels are defined in the procedure. Adequate guidance is given by references to SQA134, 159, 160, 161, and 162 for determining original specifications.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 5 0F 8 IV.

SUMMARY

OF FINDINGS (continued)

For borrowed or transferred equipment, SQA45 requires that a Transfer Request be initiated in accordance with the requirements for a Purchase Request. Emergency Purchase Requests must also follow these requirements.

SQA45 was revised on November 21, 1985 (Revision 18), to provide for proper handling of equipment and documentation covered by 10 CFR 50.49. Multiple references in SQA45 direct a purchase originator to SQA161, " Purchase of 10CFR50.49 Equipment." SQA161 defines the overlapping responsibilities of the originator, the Materials Unit, and the EQ Coordinator.

SQA45, Revision 24 Section 6, ensures that transfers of materials IRA originally purchased from suppliers that provided vendor information -

such as manuals or drawings, shall require that the vendor information be transferred as an item on the transfer request. This information was required to complete the receipt inspection of the transferred material. After completion of the receipt inspection Power Stores is required to forward the vendor information to the Supervisot, Drawing and Vendor Manuals Unit for approval and inclusion into the appropriate control system. A copy of the shipping ticket is to accompany the vendor information as a coversheet.

Reviewed Administrative Instruction AI-ll, Receipt Iaspection, Revision 35 Section 6, ead found that it provides guidance for conducting receipt inspection of transferred materials and equipment. Section 8 provides instructions for upgrading QA levels for parts and materials.

Activities that would lead to transfer / replacement of equipment are conducted under the Maintenance Work Request Control Systens. SQM 2 Revision 16 " Maintenance Management System", governs work performed under a Maintenance Request (MR). It refers to Maintenance Instruction MI-6.21 for parts borrowed or transferred for CSSC application. SQM 2 specifies that borrowed parts must meet SQL45 standards if being used on another system (difference class).

Appendix C of SQM 2 requires that the planners (Maintenance) ensure i I

that no modifications are involved. Planners require a Design Change Request (DCR) or Field Change Request (FCR) whenever a drawing revision is necessary.

A transfer may be initiated by a DCR directly or a Maintenance Request-Design Change Request (MR-DCR). AI-19, Parts III and IV, controls the processing of transfers. The DCR/FCR is often used to update drawings for simple changes. Conversations with onsite i

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN

' SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 6 0F 8 IV.

SUMMARY

OF FINDINGS (continued) design support engineers verified that they routinely receive DCRs/FCRs that update the instrument tabulations (TVA 47B601 Series drawings) and feel comfortable with this process.

D. During the original GCTF investigation of concerns IN-85-463-008 IN-85-463-007, and IN-85-964-003, additional transfer documentation was checked. The GCTF report to the Management Review Group (MRG) dated, January 10, 1986, recommended a detailed review of equipment documentation. The plant QA staff subsequently reviewed documentation for equipment transfers and found programmatic deficiencies. As a result, Corrective Action Report (CAR)

SQ-CAR-86-04-023 for missing documentation (Watts Bar receipt inspection reports, contracts, vendor documentation, and certifications), was issued. lR4 Each specific deficiency identified on the CAR was verified to be l acceptable. The records which were missing are now available on i microfilm with three exceptions. Two of the items identified as i missing documentation are QA level III material which should not IR4 have been required to have traceability from the material to the l procurement document per SQA 4-5. On the third item, Power Stores l 1s searching for the required documentation to complete the package. l Also, Power Stores issued Secton Instruction incter (SIL) 9 to l insure that QA records are reviewed for conformance to existing l procedures and that all required documentation is properly I microfilmed to maintain record traceability. l E. During interviews with knowledgeable individuals from Maintenance, Design Support, Power Stores, and Quality Assurcnce, they stated the procedures (reviewed and listed in part III C in this element report) contain all the necessary instructions, guidance and provisions to fully meet all the criteria for the transfer, substitution and documentation of material and equipment.

The engineers interviewed, could give no examples of transfers. lR4 substitutions, documentation, or drawing revision updates being incorrect except for deviations relative to documentation received during receipt inspection identified in SQ-CAR-86-04-023 above. The corrective action report also required corrective action to prevent IR4 reccurrences. All who were interviewed were aware of the procedures for the correct preparation and implementation according to the appropriate procedures as previously listed in sections III C.

. TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN

- SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 7 0F 8 V. CONCLUSIONS Numbered conclusions correspond to numbered perceived problems.

1. Provisions are made in the Maintenance Management and Design Change systens for drawing updates. Interviews with knowledgeable individuals indicate that drawings are routinely updated and documentation is routinely transferred along with equipment. It was found in the Summary of FindingsSection IV A through D, that the planners (maintenance) were comfortable making the decision on whether an MR requires a DCR or FCR. Therefore, the recommendation in the GCTF Investigation Report,Section V, does not require implementation. The perceived problem of inadequate documentation to reflect changes for substituted / replaced equipment or material transferred is not valid.

. 2. Documentation generation and drawing revisions were found to be adequate and complete for the transfer of 2-PDT-30-42, 43, 44, and 45 to SQN from WBN. Therefore, the perceived problem of inadequate documentation and drawing revisions for the transfer of 2-PDT-30-42, 43, 44, and 45 tc SQN from WBN is not valid.

Although the perceived problems were determined not to be valid, an associated issue requiring corrective action was identified.

An a result of the GCTF investigation and report, CAR SQ-CAR-86-04-023 was issued for missing documentation for material transferred to SQN. This CAR must be completed to correct documentation discrepancies. [ Reference Corrective Action Document (CATD) Number 40201-SQN-Ol].

VI. ROOT CAUSE Not applicable with respect to the perceived problems. Problems not validated / substantiated.

Wi'.h respect to the side issue, the root cause was failure to microfilm lR4 the in processing and completed QA records as required by AI-7. I

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- - TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN SPECIAL PROGRAN q>' REVISION NUMBER: 4 PAGE 8 OF 8 i:

j VII. CORRECTIVE ACTION q One side issue was identified at SQN as a result of the SQN GCTF

) evaluation. The SQN QA staff, as a result of the SQN GCTF report, y reviewed documentation for equipment transfers and found that cocumentation for some transfers was missing. A complete review was initiated and more documentation was found to be missing. This was documented on Corrective Action Report, SQ-CAR-86-04-023.

The SQN corrective-action plan for this issue was as follows:

IR4 g 1. All unresolved items are required to be completed prior to i closing the corrective action. This will be accomplished by obtaining the documentation required by the transfer document, or performing an evaluation to ensure the integrity of the plant has been maintained.

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2. SQA 45 was revised to disallow transfer of any QA level material that cannot be positively traced to its original procurement document, and 6

3. Any Transfer Requisition for which documentation cannot be obtained will nave a Nonconformance Investigation (NCI) issued in g

acccedance with AI-11.

Verifications of these items have been completed by SQN QA staff as lR4 described in section IV.D of this report. ]

Reference:

CATD Number 40201-SQN-01

$ VIII. GENERIC APPLICABILITY s

None b

j IX. ATTACHMENTS Attachment A: Listing of concerns indicating relationship to Nuclear Safety and Generic Applicability.

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1 TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40201-SQN .

SPECIAL PROGRAM

'\

REVISION NUMBER: 4

• 1 t PAGE 1 OF 1 ATTACHMENT A LIST OF CONCERNS INDICATING SAFETY REALTIONSHIP AND GENERIC APPLICABILITY CATEGORY: MC ADEQUACY OF MATERIAL ELEMENT: 40201 PURCHASING REQUISITIONING.

9 GENERIC APPLICABLE QTC/NSRS P CONCERN SUB PLT' B B S W INVESTIGATION S NUMBER CAT CAT LOC F L Q B REPORT- R CONCERN DESCRIPTION IN-85-463-007 MC 402 WBN N'N Y N I-85-172-WBN SS Instruments dedicated for a particular unit or T50036 system are frequently sent to another unit, system or even plant, i.e., Watts Bar to Sequoyah. The drawings and other applicable documentation is not revised for months if ever.

WBN N N Y Y SS Unit 2, System 30. TVA identifiers: 2-PDT-30-42; IN-85-463-008 MC 402 T50036 2-PDT-30-43; 2-PDT-30-44; 2-PDT-30-45. These instruments transmitters (Westinghouse) were sent to Sequoyah and documentation generated to reflect this (including drawings) have not been done.

IN-85-964-003 MC 402 WBN N N Y Y I-85-720-WBN SS Material / Equipment is ordered dedicated to a T50177 specific system, unit, etc., but is frequently installed /used elsewhere and it'is unknown if documentation is revised to reflect this cannibalization. CI has no further information.

1. PSR Codes:

SR - Nuclear Safety-Related SS - Nuclear Safety Significant NO - Not Euclear Safety-Related