ML20207P583

Rev 5 to Configuration Control

ML20207P583
Person / Time
Site:	Sequoyah
Issue date:	01/07/1987
From:	Murphy M, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207P454	List: ML20207P453 ML20207P468 ML20207P564 ML20207P573 ML20207P578 ML20207P583 ML20207P600 ML20207P604 ML20207P608 ML20207P629 ML20207P641 ML20207P647 ML20207P650 ML20207P653 ML20207P654 ML20207P656
References
307.13-SQN, 307.13-SQN-R05, 307.13-SQN-R5, NUDOCS 8701160270
Download: ML20207P583 (16)

Text

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

l ,

TVA EMPLOYEE CONCERNS REPORT NUMBER: 307.13-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element Report REVISION NUMBER: 5 TITLE: Configuration Control REASON FOR REVISION:

To incorporate TAS and SRP comments. IR1 To add two new concerns and incorporate SRP comments and corrective IR2 action tracking documents. l To incorporate SRP comments IR3 To add an additional concern lR4 To incorpocate SRP comments and Sequoyah Corrective Action Response IR5 PREPARATION PREPARED BY:

W. L. Aycock * / / U h /r SIGNATURE D' ATE REVIEWS PEER:

/

Y d'//iV$ /?l/7 fb

/ / SIGNATURE ' IfATE M * '

'DATE

~

F/4/tt SIGNATURE CONCURRENCES wCEG-H:x W -

/k/7,[8h SRP: Ed LL)&, / - 7 'Q SIGNATURE DATE ' DATE

~ SIGNATUR((

APPROVED BY:

MU/8etol ' Hva7 Na DATE ECSP MANACER DATE MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY)

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

1449T G701160270 870109 PDR ADOCK 05000327 P PDR ____________j

TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Nuclear Power / Site Program / Procedure Element: Configuration Control 307.13 Report Number: 307.13 - SQN Revision 5 XX-85-062-003 XX--85-071-N05 BFN-IESC-85-03 IN-85-984-001 t

Evaluator: W. L. Aycock /r//7//4 W. L. Aycock ' Date Evaluator: J. S. Manuel /r//7/94 J. S. Manuel< ' D a'te Reviewed by: /lA Y f /7//f/fb

'Da t'e OPS CE(![edfber Approved by: M /2!/7![b

~W. R. Lagergren 'Date 1449T i

R;visien 5 I. CONFIGURATION CONTROL This element report addresses four employee concerns. XX-85-062-003 is specific to Sequoyah Nuclear Plant (SQN) and was closed out via NSRS Evaluation Report I-85-473-NPS. This concern is also being addressed by the Engineering (EN) Category Evaluation Group. Concern XX-85-071-N05 is also specific to SQN but was not included in the NSRS investigation.

Concern BFN-IESC-85-03 was expressed for Browns Ferry, but was made generic to SQN. Concern IN-85-984-001 was originated at Watts Bar Nuclear Plant (WBN) and was evaluated as generic to SQN.

II. SPECIFIC EVALUATION METHODOLOGY The employee concerns are as follows:

XX-85-062-003

, Sequoyah, Browns Ferry: CI was unofficially informed that the drawings, in many instances, are not a true representation of the installation. Nuclear Power Concern. CI has no more information.

Concern XX-85-062-003 is shared with the Enginepring Concern Evaluation lR5 Group and is also addressed by element report 206.01. l XX-85-071-N05 NRC identified the following concern from review of the QTC file.

" Drawings in the control room do not reflect actual plant configuration."

BFN-IESC-85-03 Concerns expressed regarding:

1. Process for evaluation of 10 CFR 21 applicability

2. Inadequate understanding of the level of control required in nuclear parts program is indicative of weakness in NQAM

3. Configuration control The first two items in this concern are not related to configuration control and are being addressed by the Quality Assurance CEG.

Page 1 of 13

R visicn 5 IN-85-984-001 The Nuclear Power Department changes hardware without changing the drawings. EG: Ladders to tops of filter cubicles in Auxiliary Building Number 1 and common areas on 676', 692' and 737' elevations were cut in half to allow removal during filter plug removal, but drawinCs were not changed. 1982 Construction Department concern. CI has no further information.

This concern was made in regard to a manifestation of configuration I control breakdown at WBN. It was resolved by an FCR which revised l the design drawings to show the new ladder configuration. Thus, the lR5 specific installation was not evaluated at SQN, but was taken as a l part of the overall configuration control issue. l The concerns were evaluated as one under the topic of configuration control.

The evaluation of these concerns and the associated NSRS evaluation response concentrated on five aspects:

1. The validity of the concerns.

2. The adequacy of the NSRS evaluation report and the recommendations contained therein.

3. Verification of the line response to the NSRS report.

4. Verification of corrective action taken by line management.

5. The adequacy of corrective action to resolve the concern and prevent recurrence.

Appropriate regulatory requirements and Sequoyah specific procedures were reviewed to ensure programmatic compliance for configuration f control at SQN. 9 III. FINDINGS NSRS investigated concern XX-85-062-003 (reference 7) and determined it to be valid due to the following:

l

1. Field Change Requests (FCRs) specifically concerning configuration deviations have been initiated at SQN to correct drawings that do not accurately reflect the plant conditions. A sample review found l

23 FCRs that corrected configuration differences, j A related finding was that several FCRs had been logged by l construction, but were not documented in construction files, l Management and Engineering Data Systems (MED) or in the available l OE FCR logs.

l Page 2 of 13 L

Rsvisica 5

.The timeframe. associated with processing FCRs has also been a

-problem, sometimes taking up to several months. This leads to long e

periods during which the plant configuration is not accurately

represented on drawings. (See Reference 15)

2. 'In-plant surveys by the SQN Quality Surveillance Section have resulted in Discrepancy Report SQ-DR-85-10-131 R and Corrective.

• Action Reports SQ-CAR-84-12-20 and SQ-CAR-84-03-008. These reports

, identify 19 drawings that did not agree with'the plant

! ' configuration. Workplans 11378, 11424, 11458,'and 9609 were.

written to correct these identified plant configuration-deficiencies. TVA memoranda from R. W. Olsen to P. R. Wallace dated January 31, 1985, and Nay 29.-1985, documented these problems but deferred actions. ,

1

3. The examples of failure to produce as-constructed drawings, instrument tabs, and bills of material partially result from a lack of formal written instructions and inadequate training of personnel.

There was not a clear understanding by plant personnel as to what constituted as-constructed drawing requirements. Document Control ,

I Center (DCC) pointed out to the NSRS investigator that they are not i in a position to make judgments on what items are to be l' ar-constructed. The process of producing as-constructed drawings

, correctly rests with the workplan initiator alone.

!' 4. Within the last twelve months there have been several investigations

). into configuration control by personnel within TVA and by experts j outside TVA. (See References 6, 9, and 34) Each review has exposed configuration control weaknesses and has made ,

recommendations to improve the process. A co'porate configuration management program manager has been named, and TVA committed to develop an improved program for all sites by July 1986. Evidence of '

this effort is contained in the Corporate Nuclear Performance Plan (CNPP).

NSRS made three recommendations as a result of their investigation.

b

1. I-85-473-NPS-01, " Systematic Configuration Control." NSRS l recommended that the corporate configuration manager develop a configuration control program at all TVA nuclear plants which l systematically confirms the safety-related, as-built configuration.

i i

i-1 l

i l

! Page 3 of 13 i

t

Revision 5

2. I-85-473-NPS-02, " Additional Instructions on As-Constructed Drawing Requirements." Additional written instructions should be developed which include how to "as-construct" bills of material, vendor manuals, and instrument tabs. It should also include _ procedures for maintaining a drawing which is needed for operation, maintenance, or modification but is not in the Drawing Management System (DMS). Also, SQN AI-25 (Reference 8) should be revised to reflect these instructions as well as to relieve the-workplan cognizant engineer of the responsibility for deciding about plant configuration record keeping matters.

3. I-85-473-NPS-03, " Improve As-Constructed Drawing Process."

Each of the plants should establish an as-constructed drawing review process as part of workplan closure to eliminate the potential for error of single point control responsibility assigned to the workplan initiator and to ensure timely processing of workplan drawing changes.

The NSRS evaluation was sufficiently thorough to cover the IRS issues raised by all four concerns as outlined above. 1 Following the NSRS investigation, SQN line management agreed to implement the recommendations, but gave them a low priority.

Consequently, no specific action has been taken by SQN to address them. Other corporate TVA programs, however, are working to improve the configuration control process. These include the Configuration Control Task Force (CCTF), and the Configuration Control portion of the Sequoyah Nuclear Performance Plan. IRS The TVA Corporate CCTF was created in June 1983 to resolve audit j findings at Brown's Ferry, but was later chartered to evaluate and propose solutions to configuration control issues throughout

! TVA-Nuclear.

! CCTF identified nine issues which led to ineffective configuration control:

1. Insufficient management emphasis.

2. Insufficient and incorrect use of the existing design and modification controls.

3. Insufficiently documented design criteria and basis.

I

4. Lack of a comprehensive and integrated TVA vendor information program.

5. Use of multiple and inaccurate drawing management data bases.

l.

6. Inadequate and inaccurate content and control of procedures.

I Page 4 of 13

Revision 5

7. Lack of a prioritized drawing list for updating drawings to reflect the plant status.

8. Problems with legibility, unitization, and accuracy of drawings.

9. Insufficient document control.

Out of these issues CCTF proposed ten improvements:

1. A single, unitized drawing system (CCD), which represents the design and configuration status of the plant.

2. Unitized design change packages as defined by Nuclear Quality Assurance Manual (NQAM) Part V. Section 2.4 Quality Notice on design change supplements.

3. Closure of the backlog of open ECNs and workplans.

4. Constructability walkdowns between the designer and constructor.

5. Drawing discrepancy program as defined by NQAM Part III, Section 1.1 Quality Notice.

6. Vendor information program established per NQAM Part V, Section 6.2 and NQAM Part III, Section 1.1 Quality Notice.

7. Establishment of a design basis documentation program.

8. Establishment of the Drawing Management System (DNS) as the ONP drawing and document status system.

9. Upgrade of data bases and information systems, and

10. Consolidated document control centers.

The CCTF charter did not mandate tracking of the recommendations, therefore the essence of the recommendations have become part of the '

Sequoyah Nuclear Performance Plan (SNPP) and the CNPP.

The SNPP was originally presented to NRC in November 1985 to satisfy a request to address some specific corrective actions. In July, 1986, TVA submitted a revised (Reference 11) SNPP to the NRC as part of the overall re-organization of the nuclear program. The CNPP outilnes system-wide enhancements to the nuclear program, including configuration control.

4 Page 5 of 13

Revision 5 In the SNPP, TVA related the findings of two design control surveys performed by Gilbert / Commonwealth (G/C) (Reference 9). Problems

+- identified by the first survey were:

1. Need for reliable information on plant configuration for engineering personnel.

2. Need for increased emphasis on the documentation of design inputs.

3. Requirement for completed design work to be reviewed for potential unreviewed safety questions.

The second G/C review team selected the main and auxiliary feedwater systems for a review of design changes made since issuance of the operating license. The survey identified nineteen technical issues and eighteen observations. The recommendations made to resolve the technical issues were put into the form of TVA action plans. Root causes identified by the survey were:

1. Engineering evaluation of design changes.

2. Documentation of evaluation.

3. Detail in design output.

4. Identification of design input and design bases.

An additional finding from the second G/C review was that the Unreviewed Safety Question Determination (USQD) activities require improvement. Division of Nuclear Engineering (DNE) initiated a review of the current configuration and determined that fourteen Engineering Change Notices (ECN) would require a USQD based on the current state of the plant. This is considered symptomatic of the lack of coordinated configuration control practices. DNE accordingly made several recommendations.

1. Initiate a review of shutdown and accident-mitigating systems to uncover any USQs.

2. Check accure.cy of markups on as-configured drawing in the SQN control room.

l 1

3. Review unimplemented ECNs for the necessity of incorporation

4. Revise AI-19 (Reference 36) to require DNE concurrence on USQD's

l. prepared at SQN for partially implemented ECNs to ensure that DNE design analyses are not impacted.

i

1. 5. Revise design change procedures to delineate the scope of a l

change and to specify those changes which are made to support licensing commitments or to resolve Conditions Adverse to Quality (CAQs).

l Page 6 of 13 l

._ . _ . -. _. _ _m . .____ __ _

R visien 5 In addition to the DNE recommendations, an NRC inspection of the G/C survey.resulted in these findings:

1. Industry codes and standard were not followed in some parts of the original design.

2. Design calculations were not available to support some of the original design.

l

3. Temporary alteration procedures have been used for permanent design; management controls did not provide for engineering review and closure.

4. Seismic requirements were not being adequately handled as design input in some instances nor were they translated into design f

output documents.

5. Five cases were identified where design modifications violate the assumptions or the statements contained in USQD.

The above findings were assessed by TVA as being attributable to the root causes defined in Section II.3.2 of the SNPP.

i Per the DNE recommendation, a Sequoyah Design Baseline and Verification Program was initiated under the SNPP. The focus of this project as it applies to configuration control is to assess the adequacy of post-modification work and correct deficiencies.

Specific directives of this project are:

i 1. Verifying and establishing the plant configuration.

i 2. Reconstructing the design basis.

3. Reviewing and evaluating modifications since OL issuance against i

the design basis.

l 4. performing the required tests or modifications developed from this review and evaluation.

( The program encompasses all of those systems or portions of systems which are required to mitigate accidents analyzed in FSAR chapter 15 and provide for safe shutdown. An additional effort, to be completed after restart, extends the program to system corrections not required for restart and to other safety related systems. ,

Methodology of the program includes development of design basis documents, performance of system walkdowns, evaluation of all changes to the systems, and comparison of all data to licensing ,

! commitments and design bases. The effort will follow through with

! correction of any discrepancies found. Independent verification of the program will be provided by DNE's Engineering Assurance group.

Page 7 of 13

R2visien 5 Another major action resulting from the SNPP and CNPP was total revision of the NQAM (See References 18 and 19). In the  ;

configuration control area, the NQAM now defines the program on a TVA generic " Quality" level and strengthens the"As-Constructed Drawing Discrepancy" form (SQN AI-25) by making it a permanent QA ~

record. These changes are intended to implement the increased [

d management commitment to configuration control.

Below the NQAM level, program changes made under the SNPP have at least partially satisfied the NSRS recommendations. Specific actions are as follows.

Recommendation I-85-473-NPS-01 " Systematic Configuration Control."

Section II.3.3 of the SNPP details a three part SQN design control improvement program. First a Change Control Board (CCB) consisting of senior plant personnel from management, licensing, QA, DNE and chaired by the Site Director was established. CCB l objectives are to evaluate and minimize changes, review for adequate design control, implement a " closed loop" design

, feedback system, and track changes to ensure completion / closeout. ,

Secondly, a transitional design control system has been implemented under Sequoyah Engineering Procedure SQEP-13 (Reference 35). Key features of this program are a new unitized, i integrated design package, review by a quality engineering group,

' management of each package by an assigned task engineer, and limitation of change scopes to ensure manageability. Finally, a permanent design control system will be implemented by DNg, based

on the plant modification package concept. The goal of this system-l 1s to ensure that design drawings are:

?

All identified

! Prepared, reviewed for technical adequacy, and approved by j qualified personnel d

Consistent with the appropriate design basis

- Developed and controlled in a systematic fashion

! Reviewed using suitable review / verification criteria Issued to appropriate personnel f Updated to reflect actual plant configuration Accurately reflected in licensing documents

. Additionally the new program will force DNE to provide all

supporting material and documentation including schedules, i bills of material, USQD, calculations, tests, etc.

1 -

l Page 8 of 13

-- w, v.--.~._,_.. ..,y. . .

c,_,,,_,%,-mc%_,-r, __,.,_,n_ , - , . ,,,r,-m_,,m_.___-_._,.-m.. _.r_.,__.-

,_ ,__.,m,

4 Ravisien 5 Recommendation I-85-473-NPS-02 called for additional instructions on as-constructed drawing requirements. The request to provide instructions for as-constructing bills of material, vendor manuals and instrument tabs has not been addressed. Similarly, no procedure yet exists for maintaining a drawing which is needed for maintenance, operation or modification but is not present in the DMS. Finally, AI-25 still shows the workplan cognizant engineer as responsible for deciding plant configuration.

Recommendation I-85-473-NPS-03 to establish an as-constructed drawing review proces3 as part of the workplan closeout has not been incorporated into AI-25.

Conclusion:

This evaluation produced findings which substantiate the facts forming the basis for the concern. The NSRS recommendations could correct the deficiencies. The corporate management attention to configuration control as evidenced by the CCTF and the new design control programs initiated under the CNPP are consistent with the NSRS recommendations. Until all of the commitments made in this area are implemented in working-level procedures, however, configuration control may continue to be inadequate when station modifications are made.

At present, the SQN as-constructed drawings do not completely represent the plant configuration, but the ongoing Sequoyah Design Baseline and Verification Program should resolve the deficiencies and produce a set of accurate drawings.

IV. ROOT CAUSE The procedures previously used for configuration control were inadequate to ensure that design changes were carried through to a completed station modification and revised design documents (drawings, specifications, etc.). Further, insufficient controls '

existed to mandate reporting of discrepancies in the as-constructed drawings.

V. GENERIC APPLICABILITY

Concern XX-85-062-003 was a SQN and BFN concern, XX-85-071-N05 was SQN specific, and BFN-IESC-F5-03 was BPN specific. IN-85-984-001 was a WBN concern. The NSRS investigation report covered SQN, BFN, and BLN.

The recommendations made were specific to the plants as well as programmatic in nature, thus impacting DNE. For this reason, the concerns are considered generic to all TVA nuclear plants.

Page 9 of 13

R visien'5 VI. REFERENCES

1. 10CFR50, Appendix B, Criterion III, " Design Control;" Criterion V,

" Instructions, Procedures, and Drawings;" and Criterion VI,

" Document Control"

2. Topical Report TVA-TR75-1A, Sections 17.1 and 17.2, Revision 8

3. Nuclear QualityiAssurance Manual (NQAM), Part II, Section 3.1,

" Plant Nodifications: Before Issuances of the Operating License,"

Revision 0,' June 24, 1986

4. NQAM, Part II, Section 3.2, " Plant Modifications: After Licensing," Revision 0, June 24, 1986

5. NQAM, Part III, Section 1.1, " Document Control," Revision 0, June 18, 1986

6. Institute of Nuclear Power Operations (INPO) Corporate Evaluation, December 30, 1985, Finding 2.5A-4, WBN RIMS A02 851230 027

7. Nuclear Safety Review Staff (NSRS) Investigation Report I-85-473-NPS, " Configuration Control at SQN, BFN, and BLN,"

March 7, 1986

8. SQN Administrative Instruction (AI)-25, Part 1, " Drawing Control After Unit Licensing," Revision 15, July 21, 1986; Part 2,

" Revision of As-Constructed Drawings," Revision 0, October 25, 1985

9. Gilbert / Commonwealth Report No. 2600 dated October 1985,

" Assessment of the Design Control Program for the Sequoyah Nuclear Plant (SQN)"

10. Nuclear Performance Plan, Volume 1. " Corporate" (CNPP),

Revision 1. July 22, 1986

11. Nuclear Performance Plan, Volume 2 "Sequoyah" (SNPP), Revision 1, July 17, 1986

12. SQN - Corrective Action Report (CAR)03-008, " Contrary to the requirements of AI-25 and M&AI-3, as-constructed drawings do not always show the actual configuration of the plant." 03-27-84, closed 04-01-85

13. SQN - CAR-84-12-20, " Contrary to the requirements of AI-19, Part IV, Steps 4.4.7 and 4.4.8, the markup of drawings to reflect modification changes is not being performed in an adequate manner." 12-13-84, closed 09-19-85 Page 10 of 13

'R2Visica 5

14. SQN - CAR-85-03-005, Contrary to the requirements of AI-25 Revision'10, vendor drawings used in the performance of maintenance activities affecting quality are not controlled or verified copies." March 14, 1985, closed April 11, 1986

15. Significant Condition Report (SCR) - Genins-8501-R1, " Untimely entry of Og nuclear drawing information into the Drawing Management System (DMS)," November 1, 1985, RIMS-B04-851104-001

16. -Draft Quality Notice, NQAM Fart III, Section 1.1, " Interim Procedure for Using and Evaluating Vendor Drawings Which are not Included in the Configuration Control System," August 14, 1985

17. Quality Notice, NQAM Part III, Section 1.1, " Program for Including

• Vendor Drawings in the " Configuration Control" System,"

November 29, 1985 18 . - TVA Memorandum from S. A. White to NQAM Distribution List,

" Distribution of the Interim Nuclear Quality Assurance-Manual (NQAM)," July 2, 1986, RIMS-L860702-805

19. TVA Memorandum from R. B. Kelly to NQAM Distribution List,

" Distribution of the Interim Nuclear Quality Assurance Manual (NQAM)," July 2, 1986, RIMS-L860702-805

20. TVA Memorandum from Configuration Control Task Force to-S. A. White, " Office of Nuclear Power (OMP) - Configuration Control Task Force (CCTF) Final Report," June 30, 1986, RIMS-R15-860626-833

21. TVA Memorandum from R. K. Seiberling to Carl Crawford, "FOI Request - Knoxville Journal," May 9, 1986, RIMS-Q01-860509-233

22. IVA Memorandum from D. C. Cravens to B. M. Patterson," Corrective Action Report No. SQ-CAR-85-03-005 - Verification of Corrective Actions Involving the Use of Vendor Drawings," March 10, 1986

23. TVA Memorandum from.B. M. Patterson to P. R. Wallace,

" CAR-85-03-005, Use of Vendor Drawings," July 23, 1985

24. TVA Memorandum Form B. M. Patterson to P. R. Wallace,

" CAR-85-03-005, Vendor Manual Problems," July 9, 1985

25. TVA Memorandum from T. G. Chapman to E. G. Beasley, " Documentation Problems Identified in Configuration Control Task Force Metting Notes of March 6, 1985," June 3, 1985, RIMS B45-850603-200

26. TVA Memorandum from R. D. Guthele to Joe W. Anderson, " Request for Drawing Management System (DMS) Quality Control and Information Systems Analysis Services," May 3, 1985 RIMS-R25 850501 910 Page 11 of 13 i

C. R:visica 5

27. TVA Memorandum from J. B.' Krell to All Plant Maintenance Employees, "Use of Drawings in Vendor Manuals," April 24. 1985

28. TVA Memorandum from K. W. Whitt to J. P. Darling, " Browns Ferry, Watts Bar, and Sequoyah Nuclear Plants - Review of Corrective Action Program - Nuclear Safety Review Staff Report No.

R-85-11-NPS," April 17, 1985, RIMS-Q01-850417-052

29. TVA Memorandum from D. C. Craven to J. B. Krell, " CAR No.

SQ-CAR-85-03-005 - Use of Vendor Drawings," May 1, 1985

30. TVA Memorandum from Michael L. Scalf to R. D. Guthrie "DMS Overviuw," March 12, 1985, RIMS-B04-850312-440

31. TVA Memorandum from R. W. Wright to Design Services Files, " Browns Ferry Nuclear Plant (BFN) - Office of power Engineering Configuration Control Task Force (CCTF)," January 31, 1985 RIMS

32. TVA Memorandum from R. W. Cantrell to D. B. Bowen and R. G. Domer,

" Drawing Management System (DMS) - Engineering Projects Responsibilities," November 21, 1984, RIMS-IMS-841121-002

33. TVA Memorandum from R. D. Guthrie to Those Listed, " Configuration Control Task Force - Subtask Groups," October 9, 1984, RIMS-0EN-841011-011

34. Querytech Associates Report to R. Cantrell Dated September 1985,

" Assessment of Engineering Design Control for the Browns Ferry Nuclear Plant"

35. Sequoyah Engineering Procedure SQEP-13. Revision 0; Procedure for Transitional Design Change Control

36. SQN Administrative Instruction (AI-19 Revision 17, Modifications after Licensing 9

VII. IMMEDIATE OR LONG-TERM CORRECTIVE ACTION Corrective Action Tracking Document (CATD) 30713-SQN-01 has been issued to document Sequoyah's Corrective Action Plan which states "Section VII.1 (307.13 Rev. 0) requires corrective action (See S11 861017 800) in that SQEP30 must be revised (Restart).Section VII.2&3a (307.13 Rev. 0) corrective action is complete." These statements and above referenced memorandum ensure that AI-25 will be revised and further ensure that:

a) specific instructions will be produced for as-constructing drawings which include notes only and b) the workplan initiator will be made responsible for configuration control decisions rather than the cognizant engineer. The response to these two issues is acceptable and is tracked by the CATD.

Page 12 of 13

~

C

~

Revision'5-CATD 30713-SQN-02 has been issued to request that Sequoyah implement an as-constructed drawing review process as part of the workplan

~c losure to eliminate the single point failure mechanism of the workplan initiator and to ensure timely processing of workplan drawing changes.

Since this requires DNE action, the CATD serves as the tracking device for their response.

Corrective action commited to by SQN with respect to the review process l 1s as follows: l' l

Before the plant declares operability on a system, PNC will submit l completed Work Plans or Partial Completion Forms to DPn. In the case ~  !

of Partial Completion Forms, DNE will perform an Unreviewed Safety- l Question Determination (USQD) and generate Unimplemented Design Item l Evaluation (UDIE) as required prior to PORC approval of the partial l modification,'before drawings can be issued. USQDs, as described in l NEP-2.1, are required for all proposed changes to operating nuclear- l plant features described in the FSAR in accordance with requirements l

-of 10 CFR 50.59.. A UDIE, as described in NEP-2.1,-is required to l evaluate unimplemented designs. l l

Primary drawings will be issued within 15 days, and secondary drawings I will be issued within 90 days from determination of system operability. 'l l

The procedures are expected to be in place by March 31, 1987. The l process should be implemented by June 30, 1987. l lR5 The concern of timely updating of drawings is also being addressed by l ELE 206.01.. l I

Further commitments made to improve the time factor involved with I drawing update include: l i l

, As part of the program to improve the timeliness of updating drawings, I the Modifications Branch will send to DNE the markedup primary drawing l within 10 days after Operations accepts the modification (shift engineer l l signoff) in the workplan. For a modified system that is declared l

[ operable, Modifications will provide to DNE markedup drawings via a l l .workplan, partial modification form, or a drawing transmittal form l

( within 3 days of system operability (if the drawing transmittal form is l

[ used, the field-complete workplan will be sent to DNE within 5 days l

[ of operability). The operability point for a workplan with multiple l l -components that requires each to be declared operable as they are l

[ installed will be the completion (field complete) of the workplan after l l Operations accepts it. This program will be accomplished in several l ways: l I

I 1. AI-19, Part IV, will be revised to enable the workplan drawings to l I be sent to DNE as soon as the required approval is obtained, i.e., l l routine workplan-closure items accomplished after drawing update. l I I

2. Strong management attontion will be focused on ensuring that as the I modification is fleid complete, all appropriate steps are completed I in a timely manner to get the markedup drawings to DNE within the l time limit. l

Page 13 of 13 L

3 _. y _ ._.

.a TENNESSEE VALLEY AUTHORITY PAGE -

PLfLRiflCE - ECPSI20J-ECPS12IC OFFICE OF NUCLEAR PDHER RUN TIME - 11 W I Rt 00E!1Cy - REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/M U W* - 1555 - Ri1M LIST OF EMPLOYEE CONCERN INFORttATION .

.e SUBCATEGORY: 30713 CONFIGURATION CON 1RCL g:,.

C t. !ECORY : OP PLAtti OPER. SUPPORT S GENERIC KEYHORD A Ir D'.'

H APPL QTC/NSRS P KEYHORD B BBSW- INVESTIGATION S CONCERN - -

KEYHORD C @~.

C0tiCLRN SUB R PLT DESCRIPTION KEYHORD D f.

, Nur1BER CAT CAT D LOC FLQB REPORT R 9

YYYY I-85-473-NPS SS SEQUDYAH, BROWNS FERRYa CI HAS UNDFF N01;CONFORMANCE r0 XX 062-003 EN 2060I S NPS ICIALLY INFORMED THAT THE DRAHINGS, OP 307I3 K-FORM DOCUMENT CONTROL [.t T50127 IN MANY INSTANCES, ARE NOT A TRUE RE OPERATIONS g&

PRESENTATION OF THE INSTALLATION. H GENERAL d UCLEAR POWER CONCERN. CI HAS NO MOR F.m-EL E INFORMATION.

OP ~37'7/[ [ch W3 NRC IDENTIFIED THE FOLLOHING CONCERN fg XX -E5-071-1105 0? 0 0.,;l i; SZi NNNN Ng FROM REVIEH OF QTC FILE. "DRAHINGS K-FORM IN THE CONTROL ROOM DO NOT REFLECT ACTUAL PLANT CONFIGURATIONS."

g f,

G r;

.w li3 w o'"r YYYY SS CONCERNS EXPRESSED REGARDING: 1. P r BFNIESC-85-03  ? n-949 N BFN ROCESS FOR EVALUATION OF 10CFR21 APP g QA F000D K-FORM LICABILITY. 2. INADEQUATE UNDERSTA . g-HDING OF THE LEVEL OF CONTROL REQUIR 4 ED IN NUCLEAR PARTS PROGRAM IS INDIC b ATIVE OF HEAKNESS IN NQAM. 3. CONF

. IGURATI0ll CONTROL.

~

3 IN 4-001 OP 30713 N HBN NNNY K_ FORM NS THE NUCLEAR POWER DEPARTMENT CHANGES DRAWINGS 3 HARDHARE HITHOUT CHANGING THE DRAHI DOCUMENT STATUS NGS. EG LADDERS TO TOPS OF FILTER CIVIL :4 q

,E v/ CUBICLES IN AUXILLIARY BLDG. 81 AND STRUCTURES S COMMON AREAS OH 676', 692' AND 737 8 LLEVATIONS HERE CUT IN HALF TO ALLO h'$

h H REMOV4L DURING FILTER PLUG REMOVAL *

, BUT DRAHING HERE NOT CHANGED. 198 S' 2 CONSTR. DEPT. CONCERN. C1 HAS NO  ?.

FURTHER INFORMATION. NO FOLLOW REQU J*

IRED. d

• 1 J

• rs

~

+

r I \

- - I?

d

= i

+

j

. 4 5

1

-~ . n _-- -

e w -- - - - ~ ~ -