ML18033A566
| ML18033A566 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/10/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 22600, 22600-V02-R03, 22600-V2-R3, NUDOCS 8902150121 | |
| Download: ML18033A566 (88) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG VOLMriE2 ENGINEERING CATEGORY SUBCATEGORY REPORT 22600 SEISMIC INTERACTION'DESIGN UPDATED TVA NUCU~ POWER:
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:
SUBCATEGORY REPORT FOR ENGINEERING TITLE:
SEISMIC INTERACTION DESIGN REPORT NUMBER:
22600 REVISION NUMBER:
3 Page 1 of 45 N:
1.
Revised to incorporate initial SRP and TAS comments and latest element evaluation status.
2.
. Revised to incorporate additional SRP comments and BFN and BLN CAPs.
3.
Revised to incorporate additional SRP and TAS comments; added Attachment C
(References).
PREPARED BY:
SIGNATURE EPARA ION XO-%
S DATE
%DR:
REVIEW COMMITTEE:
N TUR DATE CON URR NCES CEG-H:
SIGNA SRP:
'&$7 APPROVED MANA N
POW 5(
CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER:
3 Page ES-1 of 2 EXECUTIVE
SUMMARY
This subcategory report summarizes and evaluates the results of four Employee Concerns Special Program element evaluations prepared under Engineering Subcategory
- 22600, Seismic Interaction Design.
The perceived problem was that lighting fixtures could 'become free missiles or swinging missiles during a
seismic event and'ould damage Category I equipment.
The element evaluations document the evaluation of 20 issues related to TVA's four nuclear plants,
- Sequoyah, Watts Bar, Browns Ferry, and Bellefonte.
The basic issues were derived from one employee concern filed for Watts Bar, which cited presumed deficiencies or inadequacies in the design of lighting fixtures.
In addition, one concern specifically applies to Bellefonte, but its scope is enveloped by that of the Watts Bar concern.
The evaluation determined that the designs for Sequoyah, Watts Bar, and Bellefonte provide adequate vertical restraint to withstand seismic loads and prevent lighting fixtures from becoming free missiles; the Browns Ferry design does not substantiate such adequacy.
When examining horizontal support, however, the evaluation team determined that the TVA design will not preclude pendant-mounted lighting fixtures becoming swinging missiles that might damage Cateqory I (or Class I for Browns Ferry) components during a seismic event.
The issues evaluated resulted in negative findings which required corrective action.
Eight corrective actions were developed to remedy the 20 negative findings.
For three of the 20 negative findings, TVA had initiated corrective actions before the Employee Concerns Task Group evaluations, and three other negative findings required new actions to resolve the findings.
The remaining 14 negative findings resulted from peripheral findings identified during the evaluations.
'he causes for the negative findings were diverse, with causes stemming from design process ineffectiveness being dominant.
All of the eight corrective action descriptions for this subcategory were judged to be individually significant from a licensing standpoint.
This design area may appear limited, but the cause implies broader siqnificance in ONE management's lack of attention to selection, training, and super, vision of first-and second-line engineering supervision assigned to this work.
TVA has developed corporate and plant-specific nuclear performance plans (NPPs).
These plans identify corrective actions to remedy existing problems and to improve TVA's nuclear program.
2643D-R26 (10/15/87)
TVA EMIPLOYEE CONCERNS SIPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER:
age ES-2 of 2 Although the employee concer ns and issues evaluated for this subcatego'z'y did'dentify some valid problems, the relatively small number of negative findin'gs and the. random nature of the causes do.not lead to the conclusion that. seismic interaction design constitutes a significant, technical problem for the
- Sequoyah, Watts BarBir owns Ferry, and Bellefonte nuclear power p'lants.'he findings of this subcategory are combined with those of other subc5teQor'y reports and reassessed in the I=ngineering category evaluation, which has assessed the broader issues identified and has issued the necessary codreCtiVe
'ction tracking documents.
2643D-R26 (10/1 5/87)
- Preface, Glossary, and L'ist of Acronyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUMBER PAGES'EVISED REASON FOR CURRENT REVISION To clarify that one or more attachments will help the reader find where a particular concern is evaluated
J
,c r
'lb 0
TVh cnPLOYEE CONCERNS SPECIhL PROGRAM REc ~RT NUNBER:
22600 FRONT Nb.TTER REV:
3 PAGE i OF viii Preface This subcategory report 'is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley huthority (TVh).
The ECSP and the organization which carried out the program, the
. Employee Concerns Task Group (ECTG), were established by TVh's Nanager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986.
Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns.
Each of the concerns was a
formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the
- NRC, and the general public.
The results of these investigations are communicated by four levels of ECSP reports:
element.
subcategory,
- category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2.
hn element consists of one or more closely related issues.
hn issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns.
For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself,.
Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
- However, the subcategory. report does more than collect element level evaluations.
The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the eztent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
hddit'ionally, at the end of each subcategory report will be a Subcategory Summary Table that includes the concern.numbers; identifies other subcategories that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of. the two will enable the reader to find the report section or sections in which the issue rai'sed by the concern is evaluated.
TVA EMPLOYEE CONCERNS SPECIAL FROG'RM'Et'ORT NUBBER:
22600 FRONT NATTER REV:
2 PAGE ii OF viii.
The subcategories are themselves sussaariz'ed in a series of eight dathgory
'eports.
Each category report reviews the major findings and collective significance of the subcategory repOrtS i'n dne of the following aa'ea5:
'anagement and personnel relationS industrial safety construction, material con,trol operations quality assurance/quali.ty control weld,ing engineering A separate report on employee concerns'-de'ali'ng'wi'th 'specific contentions of intimidat.ion, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate~ the information collected
'at 'the element level, the category reports 'integrate the'nf'ormation assembled.
in all the subcategory reports within the~category, addressing particularly the underlyi.ng causes of those problems that run across more than one subcategory.
h final report will integrate and assess the" informa'tion collected by all of the lowet level reports prepared
'foL the ECSP.
including the Insp'ect'or General's report.
For more, detail on the methods by wh,ich ECTG employee concerns were
'valuated a'nd reportedconsult the Tennessee Valley Authority Employeei Concerns Task Group Program Nanual.
Tlie Hanua1I. spells ou't the program's objectives.
- scope, organisation, and, responsibilities.
It also spec'ifies'he procedures that were f'ollowed in, the investigation reporting',
a'nd
'loseout of'he issues raised tiy employee concerns.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22eOO FRONT MATTER REV:
2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS~
classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A:
Issue cannot be verified as factual Class B:
Issue is factually accurate, but what is described is not a
problem (i.e., not, a condition requiring corrective action)
Class C:
Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of'he issue was undertaken Class D:
Issue is factual and presents a problem for which corrective action has
- been, or is being, taken as a result of an evaluation Class E:
A problem, requiring corrective action, which was not identified by an employee
- concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
collective si nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see "employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.
criterion
( lural:
criteria a basis for defining a performance,
- behavior, or quality which ONP imposes on itself (see also "requirement").
element or element re ort an optional level of ECSP report, below the.
subcategory level, that deals with one or more issues.
em lo ee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
TVh EPIPLOYEE CONCERNS SPECIE]'BOGiRhl(
REPORT NUMBER:
226OO FRONT lQGTER REV:
2 PdGE iv OP viii evaluator(s).
the individual(s) assigned the responsibility to assess' specif ic grouping of emplbyee concerns.
f~indin s
inc'Ludes both.statements of patt ond the yudtmhnts made about those facts 'during the -evaluat]ion process; negative findings require cor'rect].ve action.
issue a potent'i'al problem, as interprethd by, th6 ECTd,during the evaluation
- process, raised
]in one or more concerns.
K-yourn (sae
."employee coincacn'")
evaluation,judg'ment or decision may be'ased.
root cause the underlying'eason for a 'problem.
-~Terms essent],al to,the'rogram but which require detailed definition'aVe beeh defined in the IECTG Pruocedurii )(anuil'cages
- generic, sPecific, nuclear
,safety-related, unreviewed safety-significant question)...
TVA. aHPLOYEE CONCERNS SPECIAL PROGRAN RhcORT NUNBER:
22600 FRONT KNITTER REV:
2 PAGE v OF viii
- Acronyms AI AISC ANSI ASME'STN AMS BFN BLN Administrative Instruction American Institute of Stoel Construction As Low hs 'Reasonably Achievable American Nuclear Society American National Standards Institute American Society of Nechanical Engi'neers American Society for Testing and Naterials American Melding Society Browns Ferry Nuclear Pl'ant Bellefonte Nuclear Plant CAQ CAR CATD CCTS CEG-H CFR Condition Adverse to Quality Corrective Action 'Report Corrective Action Tracking Document Corporate Commitment Tracking 'System Category Evaluation Group Head Code of Federal Regulations CI CNTR COC DCR DNC Concerned Indivi'dual Certified Naterial Test. Report Certificate of'onformance/Compliance Design Change Request Division of Nuclear Construction (see also NU CON)
TVh ~APL,OYEE CONCERNS SPECIbL PROGRhà Rh,.aRT NUMBER:
22600 FRONT MhTTER REV:
2 PhGE vi OF vii.i DNE DNQh Division of Nuclear Engineering
.Division of Nuclear Quality bssurance Division of Nuclear Training DOE DPO DR ECN ECP ECP-SR ECSP ECTG EEOC EQ EMRT EN DES FCR FShR FY HCI Department of Energy Division Personnel Officer Discrepancy Report or Deviation Report Eng,ineeri,ng Change Notice Employee Concerns Program Employee Concerns Program-Site Representative Employee Concerns Special Program Employee Concerns Task Group Equal Employment Opportunity Commission Environmental Qual ification Emergency Medical Response Team Engi.neer ing Design Employee
Response
Team or Emergency
Response
Team Field Change Request Final Safety hnalysis
- Report, Fiscal Year
'I General Employee Training Hazard Control Instruction Hvhc Heating, 'Ventilating, Air Conditioning Installation Instruction INPO IRN Institute of Nuclear Power Operations Inspection Rejection Notice
TVA EMPLOYEE, CONCERNS SPECIAL PROGRAM RE( VRT NUMBER:
22600 FRONT MATTER REV:
2 PAGE vii OF viii L/R M6hI MI MSPB NCR NDE NPP NPS NQAM NRC NSB NSRS NU CON Labor Relations Staff Modifications and Additions Instruction Maintenance Instruction Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Examination Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Manual Nuclear Regulatory Commission Nuclear Services Branch Nuclear Safety Review Staff Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUMARC Nuclear Utility Management and'esources Committee OSHA ONP OMCP PHR PT QAP QC Occupational Safety and Health Administration (or hct)
Office of Nuclear Power Office of'orkers Compensation Program Personal History,Record Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures Quality Control QCI Quality Control Instruction
Pl%A El1PLOYEE CONCERNS SPECIAL PROGRAÃ REPvRT NUltBER:
22600 FRONT NATTER RLV:
2',
PAGE viii OF v:iii QCP QTC RIF RT SQN SI SOP SRP SPEC TAS Qual.ity Control Procedure Quality Technology Company Reduction in Force Radiographic Test:ing Sequoyah Nuclear Plant Surveillance Instruction Standard Operating Procedure Senior Review Panel Stone and webster Engineering Corporation Technical Assistance Staff TLL TVA TVTLC WBECSP WBN Trades and Labor Tennessee Valley Authorit)r Tennessee Valley Trades at>d Labor Counc,il, Ultrasonic Testing Visual Testing watts Bar Employee Concern Spec,'ial Program Matts Bar Nuclear Plant, Mork Request or Work Rules Morkplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 2 of 45 Section Executive Summary Preface ECSP Glossary of Report Terms Acronyms CONTENTS
~Pa e
ES-1 1
Introduction 2
Summary of Issues 3
Generic Applicability/Evaluation Process 4
Findings 5
Corrective Actions.
6 Causes 7
Collective Significance Glossary Supplement for the Engineering Category 35 36 38 43 Attachments A
Employee Concerns for Subcategory 22600 B
Summary of Issues,
- Findings, and Corrective Actions for Subcategory 22600 C
References A-1 B'-1 C-1 Table TABLES Classification of Findings and Corrective Actions Findings Summary Matrix of Elements, Corrective Actions, and Causes
~Pa e
40 41 2643D-R26 (10/15/87)
~O
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 3 of 45 1.
INTRODUCTION This subcategory report summarizes and evaluates the results of the ECSP element evaluations prepared under Engineering Subcategory
- 22600, Seismic Interaction Design, which contains concerns about the design and instal'lation of lighting fixture supports.
The concerns cited the perceived problem of lighting fixtures becoming free missiles or swinging missiles during a seismic event and damaging Category I equipment.
Two employee concerns provide the basis for the element report evaluations and are listed by element number in Attachment A.
The plant location where the concerns were originally identified and the concern applicability to other TVA nuclear plants are also identified.
4'he evaluations are summarized in the balance of this report as follows:
r o
Section 2 summarizes, by element, the issues stated or implied in the employee concerns o
Section 3 outlines the process followed for the element and subcategory evaluations and addresses the determination of generic applicability o
Section 4 summarizes, by element, the findings and identifies the negative findings that must be resolved o
Section 5 -- highlights the corrective actions required for resolution of the negative findings cited in Section 4 and relates them to element and to plant site o
Section 6 identifies causes of the negative findings o
Section 7 assesses the significance of the neqative findings o
Attachment A lists, by element, each employee concern evaluated in the subcategory.
The concern's number is given, alonq with notation of any other element or category with which the concern is shared; the plant sites to which it could be applicable are noted; and the concern is, quoted as received by TVA, and characterized as safety related, not safety related, or safety siqnificant.
o Attachment B contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and. corrective actions.
The reader may trace a concern from Attachment A to an issue, in Attachment B by 'using the element number and applicable plant.
The 2643D-R26
( 10/15/87)
TVA EMPI.OYEE CONCERNS SPECIAL PROGRAM RI=PORT NUMBER:
0261)0 REVISION NUMBER: 3 Page 4 of 45-reader may relate a corrective~ action description in Attachment 8 to causes and significance in Tab~le
~3 by usi~ng ~the CATO number which appears in>>ttachment,B in parentheses at the end of 'the corrective action descripti on.
The term "Periphera'I finding" in th0 issue column refers.to a finding that occurred during the course of evaluating a concern but did not stem directly frcm a employee concern.
These are c'lassified as
"'E" in Tables 1 and 2 of this report o
Attachment C -- lists the references cited in the text 2..
SUMMARY
OF ISSUES The employee concerns listed in Attachment A f'r each element and plant have been
- examined, and the potential problems raised by the two concerns h'ave b>en'dentified as two separate issues.
A summary of the issues evaluated under lthis kubkategory for each element and each plant is listed below:
o 226~0 Desiqn of Light~in'ixt0reI Supports -.Lighting fixtur'es,'are Fi:
W equipment during a seismic event-(SC)N, WBN,,BFN, and BLN).
Safety cable is not adequate to seismically support lighting fixtures shlown in: drawinqs 4BAl0893-'>l2-43, Rev.
1, and -44, Rev.
1 (BLI'f).
The issue summary above covers a pre'sumed deficiency or inadequacy in the design of lighting fixtures and is associated with the quality of that design.
A statement describing the issues evaluated within'he element reports'c provided in Attachment 8; This attachment also identifies findings and corrective actions, which wil'l be discussed
'in Sections 4 and 5 of thi's r'eport'.
As the following sections
- shov, the above issues we~re ~found to be valid and to require corrective action at each of the four plants.
3.
GENERIC APPLICABILITY/EYALllAT ION ~PR CESS This subcategory reoort is based on.the information contained in the element reports prepared to address the, specific~ employee concerns related to ~the issues broadly defined 'in Section 2.
The eva1luaItion plrocess is described in the following subsections.
2643D-R26 (10/15/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 5 of 45
- 3. 1 Generic Applicabilit Review Two emoloyee concerns provide the basis for the element evaluations and are listed by element number in Attachment A.
The plant location where the concerns were originally identified and the concern applicability to other TVA nuclear plants are also identified.
One concern was initiated at Watts Bar (WBN) and is sufficiently broad to generically apply to the three other TVA nuclear plants, as shown in the applicability column.
The second concern soecifically applies to Bellefonte and is enveloped by the scope of the Watts Bar concern.
3.2 General Evaluation Process a.
Developed issues from the employee concerns.
b.
Reviewed current regulatory requirements, industry standards, and TVA criteria documents related to the issues to develop an understanding of the design basis.
c.
Reviewed applicable design documents and conducted facility walkdowns, as appropriate, to devel'op design understanding and to verify implementation status.
d.
Reviewed applicable FSAR, Safety Evaluation Report (SER),
and SER Supplements to understand scope and basis of NRC review, determine regulatory compliance, and to identify any open issues and/or TVA commitments related to the design.
e.
Reviewed any other documents applicable to the issues and determined to be needed for the evaluation-such as correspondence, transcripts of interviews, procedures, test reports, nonconforming condition reports (NCRs), engineering change notices (ECNs), evaluation
- reports, etc.
f.
Using the results from steps a through e above, evaluated the issues for each el'ement and documented the findings in element reports.
g.
Tabulated
- issues, findings, and corrective actions from the element reports in a plant-by-plant arrangement (see Attachment B).
h.
Prepared other tables, as
- needed, to permit comparison and identification of common and/or unique issues,
- findings, and corrective actions among the four plants.
2643D-R26 (10/15/87)
TVA EMPLOYEE CONCI=RNS SP'ECIAL PROGRAM
,REPORT NUMBER;
'2600 IREVISION NUMBER: 3 Page 6 of 45 Classif ied the findings and cor!Iective actions from the eleme!I!t reports using the ECSP definitions.
j.
On thee basis of ECSP guidelines, analyzed the causes and established the col'iective significance of the findingS from the element reports.
k.
Evaluated defined corrective actions to 'determin'e if addition<%1 actions are requiried as a result of c'aus'es found in step j.
1.
Provided additional judgment or info&atIion that may not be apparent at thee element report 1<!vel.
- 3. 3 Spec ific Evallua tion Process In addition to the gienerall evaluat:ion, as deScribed
- above, performed by the evaluation team for each plant, specific dlocuments were also reviewed, on the basis of their apj!licability to the issues.
These documents and other unique information are. listed in Attachment C.
'a ~
b.
Evaluated program to assure that lighting fixtures do not becdme seismic interact:ion items.
Reviewed attachments to the two NRC letters from Youngblood to Wlsite (February
'18, lg86, and June 23, 1986) f'r 'possible additional relevant information.
Obtained and reviewed design drawings four light 'fixtures.
Reviewed selected calculations of light fixture restraints.
(SQiIi, WBN, BFN, and BLN) e ~
Performed walkdown in Category I't:ructu'res to view lighting fixture installations (all plants) and.exit; signs (BLN).
f.
Revieweci program and results to idate in resolving SCR SQN MEB 8610 and Gilbert/Commonwealth Technical Issue ll.
(SQN)
,g.
Revieweci program and results to date in resolving SCR WBN CEB 8537 and TVA generic review of SCR SQ'N MEB'8610.
Revieweci program and result:s to date in resolving and TVA generic review of SCR SQN MEB 8610 SCR WBN CEB 8537,'SCR BFN MEB 8605, And PIR MBN CEB 8572.
(BIEN) 2643D-R26 (10/1 5/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 7 of 45 4.,
FINDINGS The findings from each of the four element evaluations for this subcategory are listed in Attachment B by element number and by plant in a matrix form alonq with corresponding issues and corrective actions.
The discussion and summarized element findings for each plant follow.
- 4. 1 Desiqn of Li htinq Fixture Supports - Element 226.0 Individual lighting fixtures are typically lightweight, generally 50 pounds or less and rarely exceeding 100 pounds, and are adequately supported for
- Sequoyah, Watts Bar, and Bellefonte to withstand a seismic event and, prevent the fixtures from becoming free-falling missi'les that might damage seismic Category I components.
However, the TVA design of pendant-mounted lighting fixtures does not,, in general, provide adequate horizontal support during a
seismic event to prevent them from becoming swinging missiles that might damage adjacent seismic Category I components.
4;2
~Seauo ah 4.2.1,Detailed Findings for SgN Lioht Fixture Su port Criteria for SON.
NRC General Design Criterion 4
requires that Category I structures,
- systems, and. components be appropriately protected aqainst dynamic effects, including the effects of missiles, pipe
- whiopinq, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit.
S(N commitment to comply with this criterion is contained in FSAR Section 3.2.
Position C-2 of Regulatory Guide 1.29, "Seismic Design Classification," states that those port'ions of structures,
- systems, or components that are non-Cateqory I,, i.e., I(L), but whose failure could reduce the functioning of a Cateqory I item to an unacceptable safety level should be designed and constructed so that the Safe Shutdown Earthquake (SSE) would not cause such failure.
SON commitment to comply with this regulatory guide is contained in FSAR Section 3.2. l.
The desiqn of S0N electrical system is based, in part, on Standard IEEE-308-1971 as stated in FSAR Section
- 8. 1.5.
This standard establishes and defines Class lE as the classification of electrical equipment required to achieve safe shutdown.
S0N was originally designed with three lighting systems:
o Normal Lighting - This system is powered from non-Class 1E power sources.
26430-R26 (10/15/87)
IVA EMPLOYEE CONCERNS SPECIAL PROGRAM, REPORT NUMBER:
22600 REVISION NUMBER!
3'age 8 of 45 o
Standby L',ighting - This system is normally powered from non-Class lE power sources and transfers to ths! ohsite Class IE diesels upon failure of non-Class 1E sources.
o Emergency Lighting - This system is powered from the onsite Class 1E vital battery -boards and iis activated by failure of the offsite
- sources, and operates untill transfer from the normal to standby
'ystem is completed when the diesels are fully functional.
Thi< 125
'dc system is designed for 2-hour operation.
The structural support of these three systems is descri,bed in SQN-DC-V~13311 and shown.on drawinq series 47A057.
NCR SON MEB 8304, Rev.
2, indicates that
'TVA committed to the NRC on Oc'tober~
23, 1979,,to provide a fixed self-contained
'second e'me<'gehcy lighting syst: em consisting of Fluorescent or sealed beam units wi th an individual 8-hour minimum battery power supply in areas that must be manned for safe cold shutdown and for access and egress routes'o'r'id fro'm a'ill fire areas.
This commitment was made in response to NRC review of FSAR for 10 CFR Part, 50, Appendix R requirements.
The structural support for thiis system is not included in SQN-DC-V-13.11, but is shown on drawing '47N1410-1, Rev.
18.
TVA design criteria for seismic support of oiriqinhl design lighting fixtures in Category I structures are contained in'i'vi1 Design 'Guide OG-C1.6.3, which states that a 'literature survey of damage due to'arthquakes finds lighting fixtures highly susceptible to failure.
This is particularly true for pendant-mounted fluorescent and incandescent fixttir'es.
The criteria conclude that, with certain stated exceptions, the incorpo~ation of an auxiliary'upport cable as an inteqr al part of the light 'fixtuire 'is 'the most effective approach for ensurinq an appropriate degree bf seismic vertical restr aiht.'his support is a 1/16-inch flexible corrosion-resistant cab'le (MIL-C-5424').
'dditional requirements aire imposed for the first emergency lighting system to maintain the e'lectrical, power supply to the fixture during or after a si~ismic event.
This is accomp1 i s lied by a three-way
'I aterail cable support system which keeos the fixture in a plumb position.
Oesiqn Guide OG-C-1.6.3 further states that "In the event of a "lighting fixture failure due to seismic conditi<)ns, motion of the fixture in any direction wil'1 be limited to the length of
'ree cable.
Care must be taken to eliminate or otherwise protect any safety-rel,ated equipment within the range of. motion afforded by the cable from impact by the fixture."
26430-R26 (10/15/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 9 of 45 The evaluation team has reviewed these criteria in light of general engineering industry experience and determined that they are adequate.
The SQN design criteria for support. of original lighting fixtures in Cateqory I structures (which predate the civil design guide) are contained in SQN-DC-V-13.11, which forms the design commitment for SQN.
The two sets of design criteria are very similar.
With the exceptions noted later, after review of the 47A057 series lighting fixtures support drawing, the evaluation team determined that SQN-DC-V-13. 11 criteria are adequate based on general engineering industry experience.
Criteria Application for SQN.
The implementation of the SQN design criteria is contained in the. notes and details shown on the 47A057 series lighting fixture support drawing which is invoked by lighting plan and detail drawings such as 45N1410-1, 55N416-1, and 55N416.2.
Individual lighting fixtures in nuclear industry facilities are typically light weight, general.ly 50 pounds or less and rarely exceeding 100 pounds.
These weights are confirmed by SON-OC-V-13. 11 Section 4.0, which indicates weights in the 20- to 35-pound range.
Smaller and lighter fixtures have one auxiliary cable support at the fixture
.stem while larger and heavier fixtures generally have more than one stem with auxiliary cable supports at each stem.
The minimum breaking strength of the cable is specified to be 480 pounds.
The cable is generally attached to a
sinale expansion anchor either 1/4-or 3/8-inch in diameter.
Specification G-32 indicates allowable tension working loads of 500 and 700 pounds and shear workinq loads of 300 and 500 pounds.
Thus the evaluation team concludes that the light fixtures are properly designed with adequate vertical support to withstand a seismic event.
The evaluation team has reviewed this drawing series and concludes that it is technically adequate, subject to one observation which is similar to that for Design Criteria SQN-DC-V-1'3.11.
This observation is that Figure 5.0-1 of SQN-DC-V-13. 11 and the principal detail for emergency liqhting fixtures on 47A057-21, Rev.
3, correctly illustrate aoplication of Section 5.0 criteria.
However, the details in Figure 4.7-1 for the emerqency liqht and the alternate detail shown on 47A057-21 and the emergency light detail shown on 47A057-6, Rev.
5, do not agree with the text of Section
- 5. 0 and with Figure 5. 0-1.
The evaluation team reviewed drawings 47N1410-1, Rev.
18, 55N416-1, Rev.
18, and 55N416-2, Rev.
19, and noted that they refer to a battery, pack emergency liqht system that differs from the types described in either the SQN design criteria or drawing 47A057, as discussed earlier.
This battery pack emergency liqhtinq system is not required to withstand a SSE, as indicated by general note 5
of drawing 47N1410-1, but must be restrained from becoming a hazard to Cateaory I systems during or following a SSE.
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Seismic Interaction Program for SQN.
The discussion below <
Technical Issue ll of that report is titled "Seismic Interactions" and describes a condition where a 2-inch 0.0 Category I(L) primary makeup water suoply piping system was located near tubing sup>lying air to the auxilia'ry
'eedwater bypass valve 2-LCV-3<<148A.
This piping is not seismically restrained to prevent lateral displacemer<<t and tI<<e striking of the air supply line.
G/C found no documentation to demonstrate that this interaction would not impair the auxiliary feedwater system safety functions.
G/C also found that INPO Fi,nding DC;-3-2 (1985) for WBN identified a prbximity issue regarding displaicement of Category I(L) piping systems as a potehtially generic concern.
This INPO find'ing and the resultant SCR SQN-CEB 8514 address the position retention (f'alldown) but not the displacement (swinging) 6f a Cateqory I(L) system.
T)ie TVA ac~tion plan to resolve G/C Issue No.
11 resulted in the generaition of SCR SQN MEB 8610.
From February 12 through March 14, 1986, 'the NRC.'staff conducted a special insoection to examine design control praCtiCes fdr SQN.
The main focuS o'
this inspection was on the findings of the 6/C technical review and additional items.
The inspection results are contained in NRC IEE Inspection Reports 50-327/86-27 and 50-32'8/86-27 transmitted by NRC letter from Taylor to,'Wh<<te (Aoril 22, 1986).
The NRC iconcluded that the G/C review was thorough and appropriate in technical depth within the selected review scope and that the technical and generic issues identified appea'r to be valid.
G/C Technical Issue No.
11 indicated thati a prbximity <<ssue was identified with reaard to the displacement of Category I(L) piping as a potentia11ly qeneric concer'n by INPO 'Finding OC.3-2 in 1985 for WBN.
This finding resulted in SCR SON CEB 8514 (December 24,
- 1985, aind Fe'bruary 28, 1986),.
'The IIIPO findinq states:
"An engineering evaluation has not been performed to justify th'e des'Ign criteria of seismically supported nonshfety
( IL) LI(L)] systems.
'The present design criteri a for IL [I(L)] rod hangers is not adhered to consistently.
Some IL (I(L)] support designs do not consider all seismic loadings."
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3 Page ll of 45 The INPO finding contained the following as'upporting facts:
o Undocumented development df vertical load criteria for piping support rod hangers o
Inconsistent factors of safety not meeting design criteria for piping supports o
Undocumented development of flexibilitycriteria for HVAC duct rod hangers o
The potential for rod hanger supported pipe displacing and impacting other nearby components/systems is not addressed o
,Rigid supports are interspersed with rod hangers in HVAC I(L) duct systems.
Distribution of horizontal loads in a seismic event is not modeled consistently with actual structural behavior Further Relevant Document Review for S N.
The evaluation team reviewed the attachments to N
etter s from oungblood to White (February 18,
- 1986, and June 23, 1986) for issues or information, relevant to this report, that are not included in the concern statement,.itself.
No such issue or information was found in the February 1986 letter; however, on pages 131-133 of the attachment to the June 1986 letter, it became apparent to the evaluation team that the term "caged" used in the concern relates to prevention of the light bulbs or tubes from falling out of the fixtures as a result of a seismic event.
This associated issue does not appear to have been subjected to a
documented review by TVA.
However, the evaluation team's generic conclusion is that because light bulbs and tubes have brittle glass and light mass (usually one pound or less',
they do not generally present a significant safety hazard that might compromise the function of adjacent Category I
equipment, which is of greater ruggedness and mass.
According to criteria developed by the evaluation team for other nuclear power plant facilities, the item being struck will not generally be adversely affected if the size or mass of the striking item is less than or equal to that of the item being struck.
Exceptions for this conclusion might be found in areas such as over the main control room semi-horizontal panels where plant operators or panel switches or buttons might be impacted.
During the evaluation team walkdown during the week of June 24, 1986, for evaluation of Sequoyah Element Report 224;5, it was noted that there was a grate or grid for diffusing light between the tubes or bulbs and the control panels which will mitigate any falling tubes or bulbs.
Thus the evaluation team considers this associated issue to be of no safety siqnificance.
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Inspection criteria for rod hung
! I I~"." <<Q (April 22, 1986)'This memo, which has been checked,
<i li0 inches or + 30.degrees swing angle, whichever is 1less, for pendant-mounted light fixtures.
Evaluation team discussion with TVA persdnnel indicated that, there are no calculations or other documentation for t'he<<'e cri'ter'ia which are based on informal studies of ground motion displacemdntd a't rock-based sites within the TVA service territory,plus consideration
'of 'build'ing movements during ain SSE..
TVA personnel agreed to provide such documentation in the corrective action
'l an.
On the basis of evaluation team discussions with 'TVA personnel, new engineering. change notices will address seismic interaction concerns as a part of the seismic review, process.
These new evaluations will be. similar t'o,'anl'5 compatible with, those completed under SCR SgN MEB 8610.
This seismic 'reviey process will be in accordance with CEB-OI-121.03, Rev.
1, "Seismic Oesign, Review and Control.'"
The CEB seismic evaluation for seismic interaction wil'i include the following elements'.
o Ensure equipment aind systems will 'not, hhve'nacCeptable impact from existing rod hung Categiory I(L) items o
Ensuiie thait new raid hung Categoiiy iI(L) iteims 'will not impact existing Category I fragile,items in an unacceptable manner These two elements are current1ly expected to b6 based on design consultation and walkdown information and evaluation.
As these elements are currently based on verba'I instructibn, TVA personne'I understand that there is a need t6 formally document this instruction by revisibn 'of CEB-DI-121.03.
A walkdown of the Auxiliary Building was 0;onkluc'ted (March 8 and 9, 1986,',
a'nd
'ocumente'd by TVA memo from Estes to Brow',
faun'e 5, 1986) 'to identify possibl'e interactions between Category I(L) supported compdnehts'nd
<<;afety-related components which could result in degrading a safety systemi.
This.TVA walkdown of the Auxiliary Building ide'ntified 204 possible interactions of which 98 were reviewed by CEB.
The remainder were justified by Electrical Engineering Branch (EEB) and MEB.
Approximately 20 interactions involved lightiing fixtures or ster>s.
TVA coricliuded that 10 interactions-none involving lighting - required fiel'd dork. 'V'A detl rmined that one'of' 26430>>R26 (10/15/87)
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A second walkdown of the Control Building, Diesel Generator Building, Additional Diesel Generator Building, emergency raw cooling water (ERCW) pumping station, and the annulus areas of both units 1
and 2 Reactor Buildings was conducted on April 26 and 27,
- 1986, as documented by TVA memo from Estes to Brown (June 11, 1986), for similar purposes and with similar methodology as the first walkdown.
This TVA walkdown identified 90 possible interactions of which 49 were reviewed by CEB.
The remainder were justified by EEB and MEB.
There were two interactions involving lighting fixtures and/or stems.
TVA concluded that two interactions - none involving lighting - required field work for reasons other than seismic interactions.
The first walkdown was surveyed by the TVA guality Surveillance Group (on April 18 through 22,
- 1986, and documented by TVA memo from Andrews to Wilson, May 14, 1986) to assess the adequacy of the walkdown procedures.
and walkdowns performed by Division of Nuclear Engineering (DNE) in the Auxiliary Building.
The weaknesses listed by this memo appear to the evaluation team to have been satisfactorily resolved based on review of the walkdown package.
Technical Instruction TI-98, Rev.
0 (April 25, 1986) and a similar predecessor document were used to perform the walkdowns.
This iqstruction was reviewed and aporoved by Plant Operations Review Committee (PORC) as documented by Unreviewed Safety guestion Determination (USED) for TI-98, Rev.
0 (April 25, 1986), in response to directions in. a TVA memo from Andrews to Abercrombie (April 18, 1986) that walkdowns or surveys of safety-related matters must be oerformed by PORC-reviewed instructions pending an approval programmatic instruction.
The evaluation team reviewed TI-98 and concluded that it was adequate for its stated scope.
Durinq review of the walkdown instruction and resultant documentation the evaluation team noted that portions of the Auxiliary Building and the containment vessel portion of the Reactor Buildings were excluded from the scope of the walkdowns.
TVA's Action Plan to resolve G/C technical Issue 11 (February 24, 1986) agreed to list, walkdown, and evaluate all Seismic.I(L) systems for S(}N as corrective action.
The evaluation team notes the lack of a document describing the complete program for controlling this seismic interaction activity.
The technical instruction will effectively implement the walkdown activities of this program.
The TVA memo from Handy to S(N files (April 22, 1986) contains 2643D-R26 (10/15/87)
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,adequate threshold criteria for subsequent kvaluati(ins when its basis is adequately documented.
lhe division of des)onkitIilities between disciplines is defined in CEB-DI 121.036 Rev.
1,.
Such a prog'ram might include thresholds of fragility/ductility/flex'ibilityto pralvile add'itiional criteria for interaction resolution.
The walkdowns and eva'luations performed to date and those that are required to complete this effort will resolve near-term issues and furnish an adequate baseline for future evaluations as additional plant modifications are made.
Recognition of this future need is alluded to 'in'it'em of block 5e in SCR SQN MEB 8610, wh.ich states:
"Corrective action will be readdressed,to,the
'post-modification w'alkdown phase'ather than. to the 'design phase,'and w'ill be included in the acceptance criteria of the post-modificatiion walkclown."
TYA personnel will rev'ise CEB-OI-12.1.03 to provide a complete program as a
oart of the corrective action plan..
The walkdown results are indicated on a mhrk'ed sei: of plant drawiriigs an'd a'omputerized listing attached to the two TVA memos from Estes to Brown.
The documentation of the EEB and MEB evaluatidns appears'o be principallly the interaction resolution contained
.in the computerized listings while that; fear the CEB is calculation CEB CAS 214, Rev.
1.
The evaluation team reviewed both the computerizedi listings of potential seismic interactions and the calculations and noted the following:
o Many interactions are reso'Ived by-4he, ndtatioh that the nonrod-hung item is nondivisional, nontra'indd,'et'. 'his'is acceptable since neither item in the interaction is clearly required for safe plant ooeration or shutdown.
o The eva1lua'tion team reviewed a
c'op)< og the 'CEB calculation (CEB-CAS-214) for 'iiglhting fixtures and other itI ms included within'he scope of SCR S(iN IIiEB 8610The calculation I~as reviewed for its assumptions, collection of data,'o'gid,
- analysis, and conclusi'on~.
This calcu'lation i. based cin photographs of the interaction, the interaction description in the cIomputerized listing, the design criteria ',n the TVA memo from Handy to Si/N files (April 22, 1986) and.other data gathered during the walkdowns.
The evaluation team considers the calculation to be generally adequate;
- however, additional written justification'is'eeded in some areas to permit another engineer who did not participate in the original walkdowns to arrive at the same conclusions.
Our ing th'e discI)ssions with TVA personnel it became apparent thaIt e'nhalnckd underStanding may be obtained by viewing the original co'lot'hotographis.
During these 0
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This action is a part of the corrective action plan.
The evaluation team considers the TVA action plan response to G/C Issue No.
11 and corrective action/action required to prevent recurrence portions af SCR SON MEB 8610 generally adequate in concept.
- However, some deficiencies and discrepancies exist in TVA evaluations and design documents regarding prevention of lighting fixtures from becoming swinging missiles (seismic interaction) and the application of the lighting design criteria.
TVA personnel agreed to correct these deficiencies and discrepancies as part of their corrective action plans.
4 4.2.2 Summarized Findings for SgN
- Overall, on Sequoyah, the basic structure of a program to control seismic interaction design,was in place as a direct result of an early 1986 Gilbert/Commonwealth technical review of the Sequoyah main and auxiliary feedwater systems.,
However, portions of this basic structure were not cohesively integr ated.
There is no document which describes the complete program for controlling the seismic interaction design activity.
A properly documented instruction has been issued to effectively implement the walkdown activities of this program when amended to address all plant areas.
There is documentation that provides. adequate threshold criteria but no technical basis for the criteria has been documented.
The Civil Engineering Branch staff has formally revised a design interface document for seismic design, review and
- control, and the division of responsibilities between engineering disciplines after report preparation.
This document contains generic instructions for seismic interaction design.
In addition, several inconsistencies were observed wi.thin. and. between both the desiqn criteria and the construction drawings for the support of lighting fixtures.
The Sequoyah project has agreed to resolve the inconsistencies as part of their corrective action plans.
At the time of evaluation team review, Sequoyah reviews were documented as being complete.
The evaluation team'noted that the Sequoyah action plan to resolve the Gilbert/Commonwealth issues committed to list, walk down, and evaluate all seismic interaction conditions at Sequoyah.
The evaluation team found that the scope of the completed reviews for these mechanical, electrical, and civil interface reviews excluded portions of the Auxiliary Buildings and the containment portions of the Reactor Buildings.
Sequoyah corrective action plan is. to walk down and evaluate these areas.
The evaluation team reviewed the calculation which supported the conclusions for 2643D-R26 (10/15/87)
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'age 16 of 45 the completed effort:s, and considers it, to be generally adequate.
- However, additional written jiustification is lacking in some areas to permit another engineer who did not: participate in the original walkdowns to arrive at the same conclusions as, required by sound engineering pract:ice and TVA mana'gement pol icy.
4.3 Watts Bar 4.3.
1 Detailed Findings for WBN Light Fixture Support Criteria for WBN.
NRC'G4net al Design Criterion 4 requires that 'Category I structures,
- systems, and componer!ts be appropriately protected against dynamic effects, including'he Lffects of missiles,,
pipe whioping; and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit WBN commitment to comply with this criterion is contained in WBN
'FSAR Section
- 3. l.
Position C-2 oF Regulatory Guide '1.29, "Seismic Design Classification," st'atds that those portions of st;ructures,,
system.>>,
or components that are non-Category I,, i.e., I(L), but whose fai'lure couIld:reduce! the funct'ioning of a Category I iI:em to an unacceptable safety lev'el> should be designed and constructed so that the safe shutdown earthquake (SSE)- Would'not cause 5uc'h failure.
WBN commitment..to comply with this regulatory guide is cont:ained in FSAR Section 3;,2. 1.
The desian of the WBN-electrical system is base'd, in part, on Standard IEEE-308-1971 as stateel in FSAR Section 8'1.5. 'his't'andard establishI s and defines class
'IE as the classification of electrical equipment required~ to~
achieve safe shutdown.
FSAR Section 9.5.3 and NCR WI3N MEB 8305.indiCatL that, WBN was originally desiigned with three lighting systems (hereinafter'alled "ori'ainal lighting syst;ems"):
o Normal ll.ighting - This !>>ystem is pI>were
The evaluation team reviewed drawings 47M14110-'1, 55M416-1, and 55M416-2 a4d noted that they refer to a "'second emergency light system"'hat differs from the types described in either the WBN 'design crit'eria or drawing 47A057, as discussed earlier.
This "second emergency lighting sy. tern" is not reqdirI d t:o
'ithstand a
- SSE, as indicated by general note 5
of drawing 47M1410-1, but must be restra,ined from becoming a hazard to Category I systems during or following a SSE.
These restraint details are shown as detail A of drawing 47W1410-1, and the evaluation team deems them to be adequate fOr the pdrpOse.
Seismic Interaction ProcCram for 'WBN The discuss'ion below is not specificalhy
'bout the support of lighting fixtures.
~lt does, however, relate to the development of TYA's seismic interaction prbgram and the subsequent addreSsihg of lighting fixtures as.a component of th'at'prOgr'am.
In early 1986, Giilbert/Commonwealth (G/C) conducted a technical review of the SQN main and auxiliary feedwater systems modifications made between issluakce of the operating license (September 17, 1980) and June~1985.
G/C Repor't 2614 (March 3, 1986) describes the approach, methodology, results, and coriclusionls 2643D-R26
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Technical Issue No.
11 of that report, titled "Seismic Interactions,"
describes a condition where a 2-inch-O.D. Category I(L) primary makeup water supply piping system was located near instrument tubing supplying air to the auxiliary feedwater bypass valve 2-LCV-3-148A.
This piping is not laterally restrained to prevent it from striking the air suoply line valves.
G/C found no documentation to demonstrate that this interaction would not impair the auxiliary feedwater system safety functions.
G/C also found that INPO Finding 'DC.3-2 (1985) for WBN identified a proximity issue regarding displacement of Category I(L) piping systems as a potentially generic concern.
This INPO finding and the resultant SCR WBN CEB 8537 address the position retention (falldown) but not the displacement (swinging) of a Category I(L) system.
The INPO finding states:
"An engineering evaluation has not been performed to justify the design criteri a of seismically supported nonsafety
( IL) [I(L)] systems.
The present design criteria for IL [I(L)]rod hangers is not adhered to consistently.
Some IL [I(L)] support designs do not consider all seismic loadings."
As a result of the G/C findings, SQN issued SCR SQN MEB 8610.
The WBN generic
. evaluation was performed before the SQN extension of the scope of the SCR.
A documented re-review of this present SQN SCR would be appropriate.
TVA Evaluation of SCR SQN MEB 8610 for WBN.
Inspection criteria for rod hung Cateqory I L items are established in TVA memo from Handy to SQN Files (April 22, 1986).
This memo, which has been checked,
- reviewed, and approved by TVA, establishes a maximum horizontal displacement of + 6 inches for such
.pioes,
- conduits, HVAC ducts, and cable trays and a maximum horizontal displacement of + 10 inches or + 30 degrees swing angle, whichever is less, for pendant-mounted light fixtures.
Evaluation team discussion with TVA personnel indicated that there is no documentation-for these criteria.
They are based on informal studies of qround motion displacements at rock-based sites within the TVA service territory plus consideration of building movements during an SSE.
TVA personnel agreed to providing such documentation in their corrective action plan.
On the basis of evaluation team discussions with TVA personnel, new engineering change notices will address seismic interaction concerns as a part of the seismic review process.
These new evaluations will be similar to, and 26430-R26 (10/1 5/87)
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This seismic review process will be in accordance with CEB-DI-121.03, "Seismic Design, Review and Control."
The CEB seismic evaluation for seisrhic'inter'act'.ion will ensure that:
o Eauipment and systems will not have unaccepta'bid impact from existing 'rod hung Category I(L) items,,
and o
New rod hung Category I(L) itemS will nOt impact existing Category I fragile items in an unacceptable manner These two elements are currentlly expected~to bei based on design consultation and walkdown information and evaluation.
As these clem'ents are currently based on verba'I instruction, TVA personne'I understand that: there is
'a need td formally document this instruction by revision of CEB-D~I-121,.03.
The evaluation team notes the lack of a d6cukent describing the complet>
program for controlling this seismic inte&action-Activity.'he technichl
'nstruction wi'll effectively implement the walkdov~n activities of this program.
The TVA memo from Handy to SQN files (April 2'2, '1986) containS adequate threshold criteria for subsequent.
evaluations when its basis i0 adequately documented.
The division of responsibilities between disciplin'es
's defined in CEB-DI 121.l33.
Such a program might include thresholds of fragility/ductility/flexibilityto provide additiona'I criteria for interac'tion resolution.
.The walkdowns and evaluations performed to date and those that are required to complete this effort will resolve near-term iissues and furnish an adequate baseline for future evaluations as additional'lant modifications are made.
Recognition of this future need is alluded to in item c. of block
'e in SCR SQN MEB 8610, which states:
"Corrective action will be readdressed to the 'post-modification whlkdowin phase'ather than to the 'design phase'nd will be included in thei acceptance criteria of the post-modific<stion walkdown."
TVA personnel agreed to revise CEB-DI-12. 1.03 td provide a complete program as a corr'ective actidn plan litem.
The evaluation team considers the TVA action plan response to G/C Issue No.
11 and corrective action/action required to Prevent r'ecurrence portions of SCR SON MEB 8610 generally adequate in concept,.
- However, some deficiencies and discrepancies exi! t in TVA evaluat.ions and dd'sign 'documents regarding prevention of lighting fixtures from becottting swinging missiles (seismic:
interaction) and t:he application aif the lighttin) desi'gn'cr'iteria.
Further Relevant Document Review for WBN.
The i:valuation team reviewed th0 attachments to NRC letters from Youngblood t6 White (February 18, 1986, 'and June 23, 1986) for their relevance to this repoiit, theat are not included in 0
0
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3'age 21 of 45 the concern statement itself.
No relevent information was found in the February 1986 letter; however, on pages 131-133 of the attachment to the June 1986 letter, it became apparent to the evaluation team that the term "caged" used in the concern relates to prevention of the light bulbs or tubes=from falling out of the fixtures as a result of a seismic event.
This associated issue does not appear to have been subjected to a documented review by TVA.
However, the evaluation team' generic conclusion is that because light bulbs and tubes have brittle glass and li'ght mass (usually one pound or less),
they do not generally present a significant safety hazard that might compromise the function of adjacent Category I equipment, which is of greater ruggedness and mass.
According to criteria developed by.the evaluation team for other nuclear power plant facil-ities, the item being struck will not generally be adversely affected
~f the size or mass of the striking item is less than or equal to that of the item being struck.
The one likely exception for this conclusion would be over the main control room semi-horizontal panels where plant operators or panel switches or buttons miqht be impacted.
During the evaluation team walkdown on January 30,
- 1987, for other element evaluations, it was noted that there was a grate or grid for diffusing light between the tubes or bulbs and the control panels which will mitioate any fall,ing tubes or bulbs.
Thus the evaluation team considers this associated issue to be of no safety significance.
4.3.2 Summarized'indings for WBN Eval.uation team discussions with Watts Bar personnel indicate that they are aware of the design oversights on the subject of seismic interaction, but they have not initiated activity in this design area as they are waiting for the completion of Sequoyah work to enable them to make maximum use of those efforts in developing an effective Watts Bar program.
However, the tracking documentation. indicates that the subject is closed since the design oversights were not noted during a generic design evaluation feedback from Sequoyah.
In addition, several inconsistencies were observed within and between both the desion criteria and the construction drawings for the support of lighting fixtures.
The Watts Bar corrective action plan is to resolve the
'nconsistencies.
4.4.1 Detailed Findings for BFN Light Fixture Support Criteria for BFN.
NRC General Design Criterion 4 previously AEC General Design Criterion 2) requires Category I* (Class I for Browns Ferry) structures,
- systems, and components to be appropriately I
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pipe whipping,-
and discn'arging fluids, that may result from equipment failures'and from events and conditions outside the nuclear power unit.
The BFN commitment to ccmply with this criterion is contained in the Browns Ferry Final Safety Analysis Report (FSAR), Appendices A and C.
Position C-2 of Regulatory (Iuide 1.29, "Seismic Design Classification" (previously Safety Guide 29 issued ilune 7, 1972), states that those portions of structures,
- systems, or components that are non-Category I* (Class II for'rowns Ferry), but whose failure could reduce the fu'nctioning of a Category I
(Class I for Browns Ferry);item to an unacceptable safety level, should. be designed and constructed so that the safe shutdown earthquake (SSE) would not cause such failure.
BFN cmwnitment to complly with this regulatory guide Iis contained in the BFN FSAR,, Section 1.6.7 iand Appeindix C, Section C.2.1.
BFN FSAR Section 1.b.7 defines Class I and Class II items as follows:
o Class I
"This class includes tnose structures, equipment, and components whose failure or ioalfuriiction might cause, or increase the severity of, an accident which would endanger the pubilic health and safety.
This category inc'ludes those structures, equipment, and ccmponents required for safe shutdown and isolation of the reactor."
o Class II "This class includes those structures,,equipment, and components which are important to reactor, operation,,but are not, essential for preventing an accident which wquld endanger the publ ic health and safetyand are not essential for, the mitigation of the consequences of the.e accidents.
A Class-II-designated item shall not deqrade the integrity of any item designated Class I."
NRC has initiated several unresollved safety issues (USIs) which affect the seismic design basis at Browns Ferry.
This is indicatied in the draft version of TVA BFN Seismic Des,ign Basis Status Report.
For example, the safety issue in USI A-17 (NUREG-0606) considers "system interact'ions" which include seismic interaction between Clas.
I and Class II ccmponents.
Part of the NRC Nuclear Reactor Regulation (NRR) plan to resolve A-'17 is to assign the responsibility These non-Category I items are designated as Category I(L) for TVA othelr nuclear power plants 2643D-R26
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This is indicated in Advisory Committee on Reactor'Safeguards (ACRS) Full Committee meeting on the resolution of USI A-17 on May 8, 1986.
The safety issue in USI A-46 (NUREG-0606) is the concern that the margins of safety provided by equipment in operating nuclear power plants under seismically induced loads may vary considerably.
These variations were due to the significant change in design criteria and methods for seismic qualification of equipment which have been adopted since these plants were reviewed. for their operating license.
NRC indicates that the seismic capability of equipment in operating plants should be reassessed to assure that the plant can be brought to a safe shutdown condition when subjected to a design basis seismic event.
The NRC resolution of USI A-46 is contained in NUREG-1030 and NUREG-1211.
Implementation of the requirements delineated in NUREG-1030 will have a duration of approximately 40 months (Table 4 of NUREG-1211).
The design of the BFN electrical system is stated in FSAR Section 8.0.
This section together with FSAR Appendix C indicate class lE as the classification of electrical'quipment required to achieve safe shutdown.
The BFN lighting system is addressed in FSAR Section 10.19.
This section indicates that BFN is designed with normal lighting and emergency lighting systems:
the normal lighting is supplied free nonclass lE power sources, and the emergency lighting is generally battery powered from class 1E batteries.
Standby lighting which is class lE diesel-backed is also provided for fixtures in the main control rocm as stated in TVA BFN Oesign Criteria BFN-50-789.
TVA's new plan for c'cmpliance to 10 CFR 50, Appendix R, ccmmits to upgrade BFN emergency lighting with at least an 8-hour battery power supply in all areas needed for operation of safe shutdown equipment and in access and egress routes to and from all fire areas.
This new pl'an was attached
=in TVA's letter to NRC
( January 31, 1986).
Based on evaluation team discussions with TVA on March 9,
No original design criteria were implemented for design other than the National Electrical Code for the given year in which the design was issued.
Civil Oesign Guide OG-C1.6.3, "Seismic Support of Lighting Fixture in Category I
Structures,"
was'ssued in July 1978, and BFN has not implemented this'esign guide nor evaluated the adequacy of the previously installed lighting fixture supports against the criteria and/or the intent of the design guide.
TVA stated that this design guide was not a BFN design commitment, and implementation would represent a, plant back-fit.
Typical drawings or-specific drawings showing support details for lighting.fixtures do not exist,. other than drawings 4N1284-1, -2, and -3 of the main control rocm lighting 26430-R26
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- supports, which were initially issued ir') late 1982'or unit 2 and in 1983 For units 1 and;I.
In a subsequent discussion at Br owns Ferry during the week of March 2, 1987; TVA indicated that no ca1Iculations have been performed on BFN lighting fixture supports other than the recent calculation on supports
'foH the main contro'I room.
TVA BFN Oesiqn Criteria BFIN-50-789 for lighting syStems for the main kontrll rocms were issued on January 9,
1984; Section 4.0 of the design-.critAria required lighting fixtures in the main Control rooms to be mounted in accordance with Civil Design Guiide OG-C1.6.3 or as approved by Civil Engineering Branch (CEB).
The evaluation team reviewed drawings 48W1284-1, -2, and
-.3 and noted that the drawings were initially issued for modifications to the contr'ol,room lighting structure.,
Additional 'lateral bracing was added between the existing bracing,,
and end bracing members were added to the.>>outh wall on the existing braces.
However, the evaluation team observed that there are no end bracing members in the east-west, direction;, tlhe lighting fixture supports are different fram those shown in Civil Oe. ign Guicle OG-Cl'6.3.
review of TVA EN OES Calculati'on on "Miskellariieous Steel Main Control Room Lighting" revealed TVA CEB had reviewed and approved the main control'ro'cm
'eiling and ligiiting.fixture supports shown on drawings 4N1284-1,
-2I, ahd
-3.
CEB review and appi oval for seismid adequacy of these drawings iS indicated by TVA memoranda from Coleman and Huie to CIEB files (December 22,'982, and July 7, 1983).,
However, the evaluation team did not find any analytical data in the calculation or memos anda to deIiionstrate the adequ'acy'f the control room lighting structure and lighting fixture support to withstand a seismic event.,
Seismic Interaction Prol~ram for BFN.
THe discu5sion below is not speCifically about the support oMTigMting Rixt(Pre's.
It d'oes', however,'relate to ijhe current development of l*VA's seiismic interaction program and the subsequent addressing of' ighting fixtures as a ccmponent of that program.
During late 1985 and early 1986; BFN generated several significant condition reports (SCRs).
They indicated that an engineering evaluation was not performed which would'nsure that vario0s Cla'ss II features cannot degrade the integrity of Class I features as a result iaaf forces caused by earthquake'ound motions.
Tlhis is genera1lly refei'red to as evaluation of II over I II/I) or seismic interaction between Class I and II ccmponents.
In July
s ingle gerieric significant condition report to reduce, if not'liminate, the writing of additiional SCRs on the subject of II/I.
Conditions Adverse to Quality (CAQ) Engi~neering Report for SCR BFN MEB 8605 stated that this SCR is intended to adddesg all
~BFN C"iass II features and their canponents wIhen they are located riiear Class, I features.
Tlhe Engineer'ingi 26430-R26 (10/'II5/87) ik
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 25 of 45 Report stated that the SCR is also intended to address potential damage to Class I features caused by impact from fai lure and excessive movement of Class II lighting fixtures.
The report concluded that no documentation exists to assure that the integrity of Class I features has been considered in the design of Class II features; neither does documentation exist that would assure that the design of Class I features recognizes the presence o,
Class II features.
Further, the potential exists that failure of Class II features could degrade the integrity of Class I features as a result of a seismic event.
The Engineering Report recommends that BFN develop a seismic II/I program or obtain the services of an engineering firm that has an acceptable II/I program developed to evaluate seismic interaction between Class I and Class II components.
TVA Division of Nuclear Engineering (DNE) is developing a program to evaluate seismic-induced effects of Class II items on Class I components.
This was confirmed by the evaluation team discussion with TVA at Browns Ferry during the week of March 2, 1987.
The program consists of two phases.
Phase I
establishes acceptance criteria, develops procedures, and defines"work scope for evaluation of seismic-induced effects of Class II items on Class I
components.
Phase II implements the program.
Phase I already has been awarded to two contractors.
TVA, after reviewing the program, will select one contractor for Phase II.
Phase II also will include development of a lonq-term program for the design of future modifications at Browns Ferry to prevent problems due to seismic interaction between Class I and Class II components.
This plan is indicated in TVA's letter to EgE Inc.,
as well as in a letter from -TVA to Sargent and Lundy (both dated November 24, 1986).
BFN has reviewed the applicability of Watts Bar SCR CEB 8537 which addressed the "position retention (falldown)" of a Category I(L) (class II for BFN) system as a result of INPO Finding DC.3-2 against WBN.
BFN found the condition does exist and is being covered by SCR BFN CEB 8602 (indicated in a memo from Marshall to Barnett).
SCR BFN CEB 8602 was later superseded by SCR BFN MEB 8605.
BFN has also reviewed the applicability of Sequoyah SCR MEB 8610, which addressed the horizontal movement (swinging) of seismic Category I(L)
(Class II for BFN) supported items (including lighting fixtures) and their effect on adjacent seismic Category I (Class I for BFN) items.
Sequoyah SCR MEB 8610 was generated as a result of G/C Technical Issue 11'.
BFN found the condition does exist and is being covered by SCRs BFN CEB 8602, CEB 8524, and NEB 8514.
This.was indicated in a memo from Crisler to Chandley (March 7, 1986).
SCRs BFN CEB 8602 and CEB 8524 were later superseded by SCR BFN MEB 8605.
For SCR BFN NEB 8514, portions related to seismic interaction are also covered by SCR BFN MEB 8605 as indicated in CA( Engineering Report for SCR BFN MEB 8605.
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22600 REVISION NUMBER: 3 Page 26 df 45 Evaluation Team Walkdown of L~intin Fixture Supports for BFN.
The evaluation I
I 1B 2., III understandinq oF how the liqhting fixtures were supported.
The specific areas included as a sample were the control r<)om fear units 1, 2,
and 3, and'arious other areas of the unit 2,Reactor Building, at, e)evationS 593 feet and 621 feet.
The following observations were ladle during'he walkdown:
o The structural framinq of the unit 3 control room lightinq Fixtures
~
mainly consists of, Unistrut P1000 charinels ancl 1/2-inch diameter or'maller threaded rodsThe Ulisitrut c,hahne'ls
'span the cont~ol room in the east,-west direction and aire int:erconnected with 1/2-inch-diameter rods spanninq in ',the north-south direction.
The horizontal frami,ng structure has'n'd bradin'gs 'in'the north-south direction but no end bracinqs in the east-west, direction.
The horizontal Unistrut P1000 is Penkra~llg st>pp'orted'by a vertical 3/B-inch-diameter, threaded rod anch'ored to the ceiling concrete slab.
Two rows of fluorescent; fixt'ures running parallel to each row of Unistrut P1000 are attached to each end of a mounting arA connected to the Unistrut channel at mid-length of the mounting arm o
Safety cables are installed above the 'control room in unit 3 for emergency light <Fixtures,.
The suspended ceiling in the contr ol room for units 1,
2, and 3
would protect control panels from falling light tubes or bulbs.
In other areas of the Reactor 'Build'ing', both fluorescent and incandescent fixtures haue bee'n irised. 'ixtbres are typically supported from the ceiling wit'h Ste>1
'rod or conduit.
For rooms with high ceilings and a heavp 'cdnghst'i oh of c'ommodities 'routed below the ceiling, the fixtures are't'tached to the support of one of these camnodities (e.g.,
HVAC durt or cable tray support).
No safety cables were found.,
Wal'1-mouhte'd battery pack, emerqe!ncii light fixtures were observed i~n Cevkra'1 locations.
Each battery pack fixture was resting on a steel angle attached to the wa,ll;1 A
steel strap attached to the wall prevents, the battery pack from sliding off the support angle.
Further Relevant Document Review for BFN..
.The evaluation team reviewed the attachments tolls Metters Prom YoungMood 'to'White'Feb'a'ry
- 181986, and June 23, 1986) for issues, or information relevant to this report,, that'He hot'ncluded in the concern statement itself.
No such issue or information was found in the February 1986 letter; however, on pages 131-133 of the attachment to the June 1986 letter, it: became apparent to the evaluation team that the term "caqed" used in the concern relates to prevention of the liqht bu'lb'i.
0 2643D-R26 (10/15/87)
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22600 REVISION NUMBER: 3 Page 27 of 45 tubes from falling out of the fixtures as a result of a seismic event.
This associated issue does not appear to have been subjected to a documented review
,by TVA.
However, the evaluation team's generic conclusion is that because light bulbs and tubes have brittle glass and light mass (usually one pound or less),
they do not generally present a significant safety hazard that might ccmnromise the function of adjacent Class I equipment, which is more ruqged and has greater mass.
According to criteria for other power plant facilities, the item being struck will not generally be adversely affected if the size or mass of the striking item is less than or equal to that of the item being struck.
Exceptions to this conclusion might be found in areas such as over the main control room inclined panels, where plant operators or panel switches or buttons might be impacted.
Ouring the same evaluation team walkdown for lighting fixture supports (week of March 2, 1987), it was noted. that there was a qrate or qrid,for diffusing light between the tubes or bulbs and the control panels that will mitigate the effect of any falling tubes or bulbs.
Thus the evaluation team considers this associated issue to be of no safety significance.
4.4.2 Summarized Findings for BFN The. Browns Ferry design of light fixtures in aeneral may not provide adequate vertical support to withstand a seismic event and to prevent the fixtures from beccminq free missiles that miqht damage Class I equipment.
Also, the Browns Ferry desiqn of light fixtures does not provide ade'quate evaluation of horizontal support durinq and after a seismic event to prevent the fixtures from becoming swinging missiles that miqht damage adjacent Class I equipment.
Both of these desiqn items have been documented and are beinq addressed.
Browns Ferry ONE is developing a program to address seismic interaction between 'Class I and II components.
The proqram consists of two phases:
Phase I is the program development, which has been started, and Phase II is the implementation of the proqram.
This oroqram will also include development of a long-term program to preclude future II/I problems; No calculations, exist for liqhtinq fixture supports, other than those for the main control room.
No analytical data were provided in supporting calculations to demonstrate the adequacy of the control rocm liqhtinq structure and fixture supports to withstand a seismic event.
No end bracing members are shown in the east-west direction of the control room liqhting structure on the construction drawings.
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3 Page 28 of 45
- 4. 5 Be 1 1 ef ante 4.5.
1 Oetai1ed Findings for BLN Light Fixture Support Criteria for BLN.
NRC General Design Criterion'4
'rotected aqainst dynamic effects, including the effects of'issiles, pipe
- whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear p'ower unit.
The BelleiI'once
'uclear Plant (BLN) conmitment to ccmply with this criterion is contained in the Final Safety Anal,ysis Report (FSAR),'ect'ion
- 3. 1.
Position C-2 of Regulatory Guide 1,.29,
"'Seismic Oe~igh C'lassification," <tates that those portions of structures, syste'ms,',
oui canponents that are non-Category I, i.e.,
Category I(L), but wiiose failure could reduce the
'unctioning of a Category I item to an unacceptable safety level, should be designed and constructed so that the safe shutdown earthquake (SSE) would not cause such failure.,
IBLN ccnmitment to comply with this requlatory guide'is'ontained in the BLN FSAR, Sei:tion 3.2. l.
BLN FSAR Section 3.,2.1 descrilbes Category I(L) items as follows:
"Scrne safety-related components or systems perform a secondary safety function and are seismically designed to a limited,extent, because their locations create a potential f'r damaging features which perform a
primary safety function.
Those components or systems, which must retailh limited structural integrity because tneir failure could jeopardi2e to an utiacceptable extent the achievement of a primary safety function are designated as Seism~ic Category I(L) (i.e., limited requirements).
Those fluid.containinq elements which are included in 'Seismic Category ~I(L) hre'eismically qualified to meet Position C2 and Position C.3 of NRC Requlatory, Guide 1.29."
BLN is designed with three basic lighting systems:
o The Normal I ighting System Js lesiqkedI to, econmically provide the amount and quality of. illumination to meet normal plant oper'ati'on<
and maintenance requirement0.
o The Standby Light,ing System,
.upon loss of the Normal Lighting Sys'em, provides ad<!quate illumin'ation'or the'afe shutdown of the reactor and the evacuation of personnel from the plant if the need should occur.
It, forms an inteqral part of the normal liqhtinq requirements and is fed from an independent class 1E source.
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The Emergency Lighting System is composed of two separate systems:
(1) the 125V dc lighting system, which is designed to provide immediately the minimum illumination level in areas vital to the safe shutdown of the reactor for the 30-second period for diesel loading or for a two-hour period upon the loss of all ac auxiliary power; and (2) an individual eiaht-hour battery pack network, which is used to supplement the 125V dc emergency lighting, provide emergency lighting in areas that must be manned for safe
- shutdown, and to enable access and egress to and from all fire areas.
The supports for the components of these systems that are located in seismic Category I structures are to be seismically qualified to prevent failure that could impair the functioning of any safety-related plant feature.
Details of the supports for the three systems (except for the emergency 8-hour battery pack network) are described in Design Criteria N4-50-0719.
Details of the various support types are shown on drawing series 4BA0893-X2.
Details of the 8-hour battery pack supoorts are shown on the various liqhting plans, such as the 5AM0420-RM, SCM0420-RW, 5DM0420-RM, and 5RM0420-RW series.
Additional requirements are imposed for the first emergency liqhting system to maintain the electrical power supply to the fixture during or after a seismic event.
This is accomplished by a three-way lateral cable support, which is intended to keep the fixture in a plumb position.
BLN also utilizes Desiqn Guide DG-C-1.6.3 in accordance with the limitations described in the TVA policy statement.
The design guide states that:
"In the event of a lightinq fixture failure due to seismic conditions, motion of the fixture in any direction will be limited to the length of free cable.
Care must be taken to eliminate or otherwise protect any safety-related equipment within the range of motion afforded by the cable free impact by the fixture."
The evaluation team has reviewed the above reauirements in light of oeneral engineering industry experience and determined that tney are adequate.
The BLN Desiqn Criteria N4-50-D719 forms the design ccmmitment for BLN.
The criteria and General Design Guide DG-C-1.6.3 are similar.
Mith the exceptions noted later, after review of 4BA0893-X2.lightinq fixtures support drawinq, the evaluation team determined'hat N4-50-D719 criteria are adequate for preventing lighting fixtures fran becaninq free-falling missiles, based on general engineering experience.
Criteria Application for BLN.
To implement the BLN design criteria and FSAR commitments, notes and details are shown on drawing series 4BA0893-X2 except for.the emergency eight-hour battery pack network, which is shown on the 2643D-R26 (10/15/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER.I l22500 REVISION NUMBER: '3 Page 30 of 45 various lighting plans.
Individual lig&tihg fittures in nuclear indu.~trv facilities are typically lightweight, qenerally 50 pounds or less and ra'rely exceeding 100 pounds.
These weights are confirmed by N4-50-0719 Section 4.0,
'hich indicates weights, in the 20 to 35 pound range.
Small and lighter fixtures, including the emergency exit signs, have one 1/16-inch-diameter auxiliary cable support at the fixture stem, while lonqer and heavier fit:tu're~
generally have more than one stem with an lux'hali'ary cabl'e at each stem.
, The minimum breaking strength of the cable is 480 pounds.
The cable is generally attached to a single expansion anchor either 1/4-or 3/8;inch in diameter.
Specification G-32 indicates allowable loads of 50() apd,700 pounds in tensi on and 300 and 500 pounds in shear for the 'twk spec'ified sizes of expansion anchors.
Thus the evaluation team concludes that the light. fixtures are properly designed with adequate vertical support to withstand a seismi'c bvelnt.'he evaluation team has reviewed the 4BA0893-X2 drawing series and coriicli'ide's
.that it is technically adequate subject to the following observations:
o The requirements for conditions under which the three-way lateral'able support may be deleted i's tarot'cohsistent between drawi'ng'BA0893-X2-21 and Design Guide'l'.6.',3,'tqur'e 18.
Desiqn Criteria N4-50-0719, Figure 5.0-2, is c'onkist'en( with ti>e drawing series.
TVA did not furnish a calculation fear BLN'hat'uppOrtS Fiqure 5.0-2 of the criteria.
o Drawing 4BA0893-X2 series does not havta a detail showing sla'ck
'in'he electrical cables at the emergeriicy lighting fixture as required by Desiqn Criteria N4-50-0719, Fiqur'e 5.0 3.
o Drawing 4BA0893-X2-32, Rev.
1, shows a
4 by 4 by 1/4 inch structural tube support up to B,feet long which may be used in lieu of the three-way lateral cable support.
This detail was developed when Bellefonte construction personnel encountered difficulties in apolying the 4BA0893-X2-21, Rev. ), ~detail as described in TVA memos from Hodqes to Barnettand Barnett to Hodges.
Althouqh the correspondence and the resultant Calculation refer to the support as "riqid" and the evaluation teak ektijnat'es the support freouency's in the 9 to 12 hertz range, for 20- to 50-pound fixtures, review of the calculation and projert response spectra by the evaluati~in
'team indicates the design output is adequate.
However, this change has not been reflected in the design criteria.,
o The details in the design critkrik F'igure '4.7-1'or the emergency liqhit and the emergency 1 jqht detail sh'own on 4iBA0893-X2'-7, Rev 1,
do not agree with the text of Section 5.0 and with Figure 5.CI-1 26430-R26
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22600 REVISION NUMBER: 3 Page 31 of 45 Seismic Interaction Pr ram for BLN.
During a trip to Knoxville, the eva uation team determined that did not have a ccmplete seismic interaction proqram at BLN.
This situation was expected'ecause TVA's qeneric seismic design interface
- document, CEB-DI 121.03 did not address the control and coordination of an overall program.
- Recently, TVA has revised this design interface document..
Although, the details of the revisi on have not been completely reviewed by the evaluation team, it appears that TVA has adequately defined an overall umbrella program.
To implement this program on BLN, a walkdown and evaluation will be performed at a time near fuel load.
Specific details of the criteria to be used will need to be developed for BLN.
Evaluation Team Walkdown of Liqhtin Fixture Supports for BLN.
Durirfq a trip to BLN, the eva uation team performed a wa kdown o portions of the Category I
structures with the intent of observinq lightinq fixture installations.
The evaluation team observed the installation of safety cables for the lighting fixtures; however, installations were also observed where the rod hangers supporting lighting fixtures were in contact with other commodity supports.
No false ceiling was observed in the. main control room.
When information was requested by the evaluation team regarding any proposed false ceiling, TVA advised that there will be no false ceiling in the main control room.
A properly designed false ceiling would mitigate the sway of the fixtures and prevent loosened bulbs from fallinq on operators or the semihorizontal control panels.
For fluorescent light fixtures, the tubes appeared to be adequately restrained by the metal reflector bars that run perpendicular to the fixture.
On the other hand, the incandescent fixtures do not have grilles or cages to retain the bulbs.
The bulbs,
- however, are made of brittle qlass and are liqht in mass (usually one pound or less).
Theref ore, although there i s a remote possibility that the bulbs could becone loose and fall durinq a seismic event, tne evaluation team does not consider that this could have any significant impact on the safe operation or shutdown of the plant.
A separate walkdown was performed by the evaluation team specifically to view emerqency exit signs in Cateqory I structures.
This walkdown revealed the fol 1 owing:
o Certain installations had safety cables and certain ones did not.
No consistency was evident.
o Where safety cables were installed, they appeared to be adequate to prevent the fixture from becoming a free-falling object.
Therefore, it appears the field has satisfied the desiqn intent relative to proper location of safety cables for emergency exit lights.
2643D-R26 (10/15/87)
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foo',
REVISION NUMBERS: 3 Page 32 of 45 o
As would be 'expected, most lodation's wIhere exit signs have iteeh installed are in corridors and other areas
(~here the potential'f'mpact with'eismic Category I cbnpbnents i's minimal.
Review of SCR~s PIRs,.and NCRs for BLIN., Nume'rous documents have been issued T
interactions between seismic Category I and non-Cateqory I ccamodities.
The following listing identifies the Conditions Adverse to Quality documents'urnished by TVA to the evaluation team ancl BLN's resuitinq actions:
l.
Initiating Document:
SCR SQN MEB 86'10 BLN Document:
None.
Issue:
Seismic Categ'or/ I(L)'ipinq supports wi 1.1 not prevent the piping from swaying andi possibly damaging adjacent safety-related cceponents during a sei,smic event.
BLN Disposition: Although the roncern for swinging pipes exists at BLN, it is st<ited in the Poter>tial Generic Condition Eva'luation that construction specii ication N4C'-913 controls interferences.
'iscussion:
A review of construction. specification N4C-913 revea',Ied that Construction was informed that, for pipinq, certain interactions durinq seismic events should be prevented.
The specification ind/cate) that whe~e riqor ous analysis is not performs.d,'onstruction should assu~se the Cateqory I(L) pipe movement is 1 inch.
Accordinq to d1scussions wit'h TVA personnel, this 1-inch movement is believeid to acccmmodate thee worst pipe movementbut thtis
'ssumption has not been validated.
In addition, this doe<a not preclude the possibility of safety-related commodities being insta'iled aftrr the Category I(L) p'ipinq is in place and violatinq the clearance requirements.
Further, it does not'.
take into account, the possible later al di,splacement
'f the saf ety>>related ccmponents.
2643D R26
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22600 REVISION NUMBER: 3 Page 33 of 45 2.
Initiating Document:
SCR BFN MEB 8605 BLN Documents:
SCR BLN MEB 8509 and NCR BLN EEB 8420 Non-seismic Category I HVAC piping and ccmponents may impact safety-related components in the vicinity during a seismic event.
BLN Disposition:
BLN reviewed the plant arrangement and determined that one seismic Category I locally mounted instrument panel was susceptible to damaqe from non-seismic Category I HVAC equipment.
Accordingly, the HVAC component supports in the vicinity were upgraded to seismic Category I(L).
Discussion:
BLN di soos it i on adequately addresses thi s particular seismic interaction issue.
3.
Initiating Document:
PIR MBN CEB 85?2 BLN Document:
Oesiqn criteria for seismic Category I(L) rod nanqers are not consistently adhered to (INPO Finding OC.3-2)
BLN Disposition: Pipinq supports that, do not meet the requirements of Design, Criteria N4-50-0725 will be redesigned and modified as required; Also the NRC has identified an unresolved safety issue, and ASME III is reviewinq modified seismic analysis rules.
Additional corrective actions, are to be identified after 09/86.
Discussion:
The referenced criteria (N4-50-D725) indicate the use of Design'Criteria N4-50-0711, for the analysis of Cateqory I(L).piping systems.
These criteria limit the design consideration to failure of the pipinq system and do not address lateral displacements of Category I(L) ccmponents damaging adjacent Category I items.
In addition, the NRC and ASME efforts have not been canpleted.
Accordingly, no additional corrective actions have been identified.
2643D-R26 (10/15/87)
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$2Ej00, REVISION NUMBER: 3 Page 34 of 45 4.
Initiating Document:
SCR WBN CEB 8537 BLN Document:
None Issue:
Lateral loads on certain types of seismic Category I(IL) supports could cause 1Failure.
BLN Disposition: It was determined that the potential generic condition does not exist at BLN.
This determination was based on the fact that Odsign Criteria N4-50-. 072!~ require only dead load considerations and not lateral loads.
Discussion:
To comply with NRC General Design Criteriol 4'anted the BLN FSAR, consideration of both verticail and lateral effects from seismic events is required.
5.
Initiating Document:
Same as abovei Issue:
Lighting fixtiure's lith gla<s or porcelain c'annot'e'estrained with safety cab1es since the cables would damage the fixture.
BLN Disposition:
Where attachmI.'nt's Sandlot'e made to q1lass or porcelain 1lamp shades,,
safety cables must be attaclhed to lamp hous'ings.
Discussion:
TVA dispositibn of this 'issue'is reasonable based on current enqineering practice.
Further Relevant Document Review for BLN.'hd ev'al'uat',ior'i tham reviewed the attachments to NIP letters fr(m Youngbiood to White (February 18,
- 1986, and June 23, 1986) for issues or information relevant to this report, ttiat are rIot, included in the concern statement itselfNo such issue or informatioh w'as found in the February 1986 letter; however,,
on pages 131 133 of the attachment to the June 1986 letter, it became apparent'o the evaluation team that the term "caqed" used in the concern relates to prevention of the liqht bulbs or tubes frcm falling out of the fixtures as a resullt of a seismic event.
This associated, issue does not appear to have been subjected to a documented r'eview'y TVA. It has, however,,
been addi. essed by the dvaluation team in the evaluation team walkdown of lightinj fixturI supports
'abdve.,
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 35 of 45 4.5.2 Summarized Findings for BLN Evaluation team discussions with Bellefonte personnel indicate that they are aware of the design oversights on the subject of seismic interaction, but they have not initiated activity in this design area because TVA experience indicates little benefit in developing a program for seismic interaction 4 years before unit 1 fuel load.
However, the tracking documentation shows the subject closed since the design oversights were not noted during a generic design evaluation feedback free Sequoyah.
In addition, several inconsistencies were observed within and between both the design criteria and the construction drawings for the support of lightinq
.fixtures.
4.6 Summarized Subcateqor Findinqs The classified findings are summarized in Table 1.. Class A and B findings indicate that there is no problem and that corrective action is not required.
Class C, 0, and' findings reauire corrective actions.
The corrective action class is identified in the table by the numeral combined with the finding class.
The findings are summarized by classification in Table 2, which identifies one finding for each issue evaluated.
Of the 20 findings sh'own in Table 1, three had corrective actions initiated before the ECTG evaluations and three required new corrective actions to be identified.
The remaining 14 had actions reauired to resolve peripheral findinqs noted durinq the ECTG evaluation.
5.
CORRECTIVE ACTIONS Since sane of the corrective actions apply to more than a sinqle plant and since some of the findings may be addressed by a single corrective action plan description for an individual plant, only eiqht different corrective action plan descriptions are required to remedy the 18 negative findings.
The detailed cor recti ve 'acti on plans are described in Attachment B.
A condensation of this information, with the applicable plant identified in parentheses, follows:
226.0 Oesi n of Liqhtinq Fixture Supports o
Complete the resolution of plant-specific significant condition reports (SQN and'FN).
o Provide a complete proqram to describe and control the seismic interaction evaluations for current and future design activities (SQN, MBN, and BLN).
2643D-R26
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TVA EMPLOYEE. CONCERNS SPECIAL PROGRAM Rl..PORT NUMBER:
22600 REVISION NUMBER: 3 Page 36 of 45 o
Perform walkdown(s),, evaluatioIis,'dd Pal'cul',ations for plant areas previ ously excluded (SQN).
o Provide technical basis for inspecti'on'cr'ite'ria (SQN).
o Review the adequacy of calculation CEB,CAS F14 for written thcHnidal'ustif icati on (SQN).
o Revise design documents to eliminate ihconsistencies and evalua'te',
any potentiail hardware impact (SQH, MBN,,BFN, and BLN).
o Provide a generic review of cu&reht
'SCR SQN MEB 8610 (WBN and BLN)'.
o Finish development oif a ciomplete program to describe and control the seismic interaction evaluations for current and future desiqn activities (BFN).
These corrective actions also appear in Tab/e 3, along with their corresponding finding/corrective action classif icati'ons.
The table indicates the plant or plants to which a corrective action plan description is applicable by the Corrective Action Tracking Document (CATD) column where the applicable plant is identif ied by the CATO renumber.
From the Finding/Corrective Action Classification column of Table 3, it, can be seen that of the.eiqht corrective action plan descriptions identified, 'nohe
'xplicitly reauire hardware. or plant modification, four involve additional analysis to validate the desiqn and determine;if plant modifications ar' necessary, and the remaining four require scime type of documentation remedy.
The evaluation team found the corrective action plans for SeouOyah, Watts Bar, Browns Ferry, and Bellefonte to be acceptabl'e to resolve t;he findings.
6.
CAUSES Table 3 identifies one or more causes.for each problem requi~ing correcti0e
'ction.
For each corrective action description,
)he primary or most important cause i s ident ifi ed.
For the eight corrective action descriptions 1i'stud in Table.3, eight causes have been identified.
These are shown in the t'ablie and totailled at the'en'd.
'he two most frequent causes are "inadequate as-built. reconciliation,-"
<;ol,umtl 10, and "engineering judgment not justi'fied," column 12.
These tw'o c~auses, which reflect on the design pt ocess
- and, EI>ore particularly on design 2643D-R26
(,10/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT, NUMBER:
22600 REVISION NUMBER: 3 Page 37 of 45 documentation, ccmbine to represent four of the ten causes identified.
This indicates that weakness in the design documentation area have contributed to a number of problems and, 'therefore, improvement in this area appears warranted.
In addition, a number of the causes in Table 3, such as "Engineering Error,"
"Engineering Judgment Not Documented,"
and "Inadequate Design Bases,"
suggest a weakness in TVA's design review process.
Besides impr oving the quality of the design, a stronger design review process would also be expected to resolve some of the weakness noted above in the design documentation area.
The bases for identifying specific causes for each corrective action description in Table 3 with the negative findings are as follows:
o Completion of resolution of plant-specific significant condition reports on Sequoyah and Browns Ferry requires walkdowns because the as-built plant conditions have not been reconciled with the design basis.
o Provision of a complete program to describe and control the seismic interaction evaluations for current and future design activities on
- Sequoyah, Watts Bar, and Bellefonte is required because the existing procedures are incunplete.
o 'erformance of walkdown(s),. evaluations, and calculations for.plant areas previously excluded is required for Sequoyah to rectify an engineering error that permitted exclusion of the Reactor Building and portions of the Auxiliary Building.
o Provision of a technical basis for Sequoyah inspection criteria is required because the current criteria are not based on documented enqineerinq judqment.
o Review of the adequacy of calculation CEB CAS 214 for written technical justifications is necessary because the current revision is not based on adequately documented engineering judgment as required by TVA policy.
This policy requires that the written basis be sufficiently clear to permit another engineer to understand the preparer's thought process.
o Revision of design documents.to eliminate inconsistencies and to evaluate any potential hardware impact is required for the four plants because design bases are fragmented and incomplete.
2643D-R26
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TVA EMPLOYEE CONCERNS SPECIAL PRO(IRAM REPORT NUMBER:
226OO REVISIOiN NUMBER: 3 Page 38'f 45 o
Provis'ion of' generic Watts BI!r iand BaIllefonte review of current SCR SQN MEB 8610 is required because the existing Watts Bar i!nd Bellefonte generic reviews were performed before completion Of Sequoyah scope definition.
Thus,'h'e procedures for such generic reviiew were not ccmpiletely fol1iowed.
o Development of a finished program'n'rowns Fer'ry is required to describe anci control the seismic interaction evaluation for current and future ciesign activities.
Thiie as-built coriiditions will be reconciled with a revised design basis conforming to NRC guiIfelineIs, neit:her of which has been issued.
7.
COLLECTIVE !)IGNIFICANCIE.
The evaluation team's
- judgment, as to the significance of the corrective actions is inciicated in the last three cOluirins of'abl'e 3.
Significance is rated in accordance with the types of'hanges that may be expected to result from the corriective action.
All of the, corrective action plan descriptionsi for this subcategory aire judged to be individually significant from a licensing standpoint because there. is
- a. potential for degrading the fuhct'ioriai'apability of adjacent Category I or Class I equipment during a seismic eve~t.
When all of the findings and corrective action descriptions for the four nuclear plants are viewed collectively, t:he following overall conclusions emerge:
o Because of the relatively low number of negative f'indinqs in this subc;ategory, the random nature of the CauSes, and the overal'I signif icance level of t:he corrective acitiOns, it cannot be concluded that: the seismic interaction design for the Four nuclear plant sites investiqated represents a significant technical'roblem.
o Although the desiign area of lighting may appI ar limited, the'cause implies broader significance in ONE 0anaqement's lack of attr!nt'ion'o selection, training,,
and supervision of first-and second-line engineering supervision aSsigne,d to this work which represenf;s a
microcosm of activity t:hat will be assessed in det,ail in the Engineering category evaluati oh.
To address the; general broader issues of TVA's past diFficulties in the nuclear area, a Corporate Nuclear PerfoWanCe Plan CCNPP) was created.
In
i~
26430-R26
( 10/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 39 of 45 In general, TVA senior management has identified the need for strengthening its Enqineering organization in response to the requirements of nuclear olant design.
The Engineering organization is responsible for the content and quality of the design documents and for ensurinq that they conform to sound engineering principles, licensing commitments, and guality Assurance program requirements.
This need for strengthening is based, in part, on deficiencies in design process effectiveness, which are partially illustrated by the cause discussion in Section 6.
This need is also partially based on past implementation of the TVA guality Assurance program.
Thus, the need for strengthening the Enqineerinq organizati on, as indicated 'by the NPPs, is accanplished primarily through additional training of the ONE personnel to the requirements of that program and to basic management principles.
DNE Nuclear Engineering Procedure NEP-5.2 and policy memo PM 87-35 clearly delineate the responsibi.lity, authority, and accountability of the Project Engineers and Branch Chiefs.
The Project Engineer is responsible for work scope,
- budget, and schedule, and for ensuring that project work is executed accordinq to plan and in conformance with the technical direction of the Branch Chiefs and the requirements of the corporate gA program.
The Branch Chiefs are responsible for staffing levels and qualifications of technical personnel on the projects, and for the technical adequacy of the engineering design.
The Branch Chiefs are the final technical authority within ONE, and have the authority to stop work that does not conform to established requirements.
In the past, Branch Chiefs'uthority or resources to fully administer technical reviews was limited.
Under the restructured orqanization, the Branch Chief provides engineers and technical direction for the Project Engineer; the Branch Chief also assesses the need for technical
- reviews, develops a document review and approval matrix, and schedules reviews as required.
These programs have been started but have not, as of Revision 2 of this report, been fully implemented.
An independent audit on the effectiveness of the implementation of the total
(}uality Assurance proqram is instituted by Enqineerinq manaqement, as a
management tool, to additionally ensure that management policy is beinq enforced.
This audit function is provided by the Enqineerinq Assurance (EA) organization.
The findinqs of this subcategory report are combined with those of other subcategory reports and reassessed in the Engineering category evaluation, which has assessed the broader issues identified and has issued the necessary corrective action tracking documents.
26430-R26
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
- 22tIOO, REVISION NUMBE(: 3 P'age 40 of 45 TABLE 1
CLASSIFICATION,OF FINDINGS AND CORRECTIVE ACTIONS Element Issue/
F i'ndi~n~*
'indinq/Corrective Action Class*
226.0 Seismic InIi:eracti on Design b
C6 E6, E6 E6 E3 E3 E6 06 C6 06 E6 C6, 06 E6 E6 E6 E6 E3 E6 E6 I
- Classification of Findin~s and CorrectiIIe Ackiohs 1.'ardware
- 2. Procedure
)le.
- 3. Documeritation
- 4. Training
- 5. Analysis
- 6. Evaluation
- 7. Other.
+"Defined in Attachment B.
A.
Issue not valid.
No corrective acti'on required.
B.
Issue valid Ibut consequences acceptat No corrective action required.
C.
Issue valid.
Corrective action initiated before ECTG evaluat;.ion.
0.
Issue valid.
Corrective action taken as a result of ECTG evaluation.
E.
Peripheral issue uncovered durinq ECTG-evaluation.
Corrective action required.;
2643D-R26 (10/15/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 41 of 45 Classification of Findin s TABLE 2 FINDINGS
SUMMARY
Plant Total A.
Issue not valid.
No corrective acti on required.
B.
Issue valid but consequences acceptable.
No c or recti ve action required.
C.
Issue valid.
Corrective action initiated before ECTG evaluation.
D.
Issue valid.
Corrective action taken as a result of ECTG evaluation.
0 0
0 0
0 0
0 0
0 1
0 2
0 0
1 0
2 E.
Peripheral issue uncovered durinq ECTG evaluation.
Corrective action required.
6 2
4 2
14
[
Total 7
3 6
20 2643D-R26
( 10/15/87)
TABLE 3 HATRIX OF ftfHENTS, CORRECTIVE ACTIONS, ANO CAUSES SUBCATEGORV 22600 REVISION NICER: 3 ~
PAGE CZ OF 45 HsnAGEHENT EFffCTIVENfSS CAUSES OF NfGATIVE FINDINGSa I
TECHNICAL DESIGN PROCf 55 ffffCllVENESS ADE CV I
2 3
6 5
6 7
8 g
10 11 12 13 16 15 16 IT F INOINGI CORRECTIVE ACTION ELEH CLASS.at CORRECTIVE ACTION Frag-I I
IProce-llnade-I
~entedllnade-llnade-)dares
)quate IUn-Organ-)quate
)quate )not ICon-ltlnely Lack
'ite-I 0-IProce-IFol-Inunl- )Res of of Hgt tlpn tr dureS IOved Cat lan ISSutt Atten I
I I lnade-I quate Ilnade-Detlgnlquate Bases Calcs Ilnade-I IEngrg Iquate I Lack ltudgnt As-bltl of I not Recon-IDeslgnlDocu-cll.
Detail vented Coaa1 t IDocu-Not Inenta-Het tlon Not Fol-loved Oeslgnl Insuf.l Crit/ IVerlf IStds fngrg Vendor
~error frror 5 Igni fI-cence of Corrective Actions'D H I H 226.0 CS Conplete resolution of plant speci f 1 c s Ignif1cant con4ltlon rtports.
SON 03 SFN Ol A I PIP I Prnvsde n en+lain nronren en describe and control the
~
~
~
~
~ ~
1 1 1 en I~, nl 1af ~1 1 Inn evaluations for current and future design acLlvltles ~
tnN n02 NN 02 OLN 01 E6 Parfum valkdovnls) ~
tvaluaLlons and calculations for plant areas previously teel udtd e SQN 03 A
PIP ES E3 f6 Provide technical basis for Inspection crlteria.
Revlev adequacy of calculation Cf8 CAS Zlq for Justl fI cat Ion.
Rev1 st design docunents to
~Ilnlnate lncons lstenc les and
~valuate anx potential hardvare Inpact ~
Provldt a generic NN and SLN revIH of currert cr'N HES 8610.
srlN oz SON OZ SON 01 NN 03
,SFN 02 SLN Ol NBN 01 a Nnl I
x IAI I
I I
I I P I-
~
~
IAIPIPI' AIP I P I
C6 flnlsh developnent of ~
coaplett piogran to describe and control the selsnlc Interaction evaluations for Cus rent an4 fnturi dna lan acti v l ties.
~
O<<fined In the Glossary Supplenent.
~n Defined In Table I.
SFN Ol IOIALS 2
IAI-I I
I I
I 28880-87 I
)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 43 of 45 GLOSSARY SUPPLEMENT FOR THE ENGINEERING CATEGORY Causes of Negative Findinqs - the causes f'r findinqs that reauire corrective action are categorized as ollows:
1.
Fraqmented or anization - Lines of authority, responsibility, and accountabi ity were not clearly defined'.
2.
Inadequate qualit O
traininq - Personnel were not fully trained in the procedures estab ished or design process control and in the maintenance of design documents, including audits.
3.
Inadequate rocedures - Design and modification control methods and
.procedures were de scient in establishing requirements and did not ensure an effective design control program in some areas.
4.
Procedures not followed - Existing procedures controlling the design process were not u
y adhered to.
5.
Inadequate communications - Communication, coordination, and cooperation were not u
y effective in supplying needed information within plants, between plants and organizations (e.g.,
Engineering, Construction, Licensing, and Operations),
and between interorganizational disciplines and departments.
6.
Untimel resolution of issues - Problems were not resolved in a
time y manner, and the>r resolution was not agqressively pursued.
7.
Lack of mana ement attention - There was a lack of management a
ention in ensurinq t a
proqrams reauired for an effective desiqn process were established and implemented.
8.
Inadequate desiqn bases - Design bases were lacking,
- vague, or incanp e
e or esign execution and verification and for design chanqe evaluation.
9.
Inadequate calculations - Design calculations were incomplete, used incorrect input or assumptions, or otherwise failed to fully demonstrate compliance with design requirements or support desiqn output documents.
P 10.
Inadequate as-built reconciliation - Reconciliation of licensing or design documents with plant as-built condition was lacking or incomplete.
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TVA BIPLOYEE CONCERNS SPECIAI PROGRAM REPORT NUMBER:
22600 REVISION NUMBER,age 44 of 45 11.
Lack of design detail - Detail in design output documents was insu77i~csent to ensure compliance with design requirements.
9 enqaneennq judgments used in tlhe desiqn process was lacking or incompl,ete.
13.
Design criteria/cewnitments not met - Design criteria or licensing ccamitments were not met.
14.
Insufficient verification documentation - Documentation (Q) was snsuR>cient to aijdst the -adequacy oMesign and installation.
15.
Standards not f'ol'lowed - Code ot jndust'ry'standards and practic0s were not comMpsed wctu.
16.
~En ineerinq error - 'There were error S or oversiqhts in the assumptions, methodology, or jUdgrhents used in 'the design process.
17.
Vendor error - Vendor design or sqpplie'd items were deficient: for the intended purpose.
Classification of Corrective Action.', coirrective, aqtiOns are classified as ll 1.
Hardware - physical plant chang'es Procedure
- changed or generated 0 procedure, 3.
Documentation - affected i)A records 4.
Training - required personnel educat'ion, 5.
Analysis - required desiqn calcul gati ons,, etc., to resolve 6.
Evaluation - initial correct'ive, action plan indicated a need to evaTuate the issue before a definitive plan could be established.
Therefore all hardware, procedure, etc.,
changes are not yet'nown 7.
Other - items not listed above 0
Peripheral Findin~ Issue/ - A negative finding that does not result directly evaluating an employee concern IBy definition,, pLri'pheral findings (issues) require corrective action.
2643D-R26 (10/15/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page 45 of 45 Si nificance of Corrective Actions - The evaluation team's judgment as to the sign>>cance o t e corrective actions listed in Table 3 is indicated in the last three columns of the table.
Significance is rated in accordance with the type or types of changes that may be expected to result from the corrective action.
Changes are categorized as:
o Oocumentati on change (0) - This is a chanqe to any desiqn input or output document (e.g.,
drawing, specification, calculation, or procedure) that does not result in a significant reduction in design margin.
o Change in design margin (M) - This is a change in design interpretation (minimum requirement vs actual capability) that results in a significant
( outside normal limits of expected accuracy) change in the design margin.
All designs include margins to allow.for error and unforeseeable events.
Changes in design margins are a normal and acceptable part of the design and construction process as long as the final design margins satisfy regulatory requirements and applicable codes and standards.
o Change of hardware (H) - This is a physical change to an existing plant structure or component that results from a change in the desiqn basis, or that is required to correct an initially inadequate design or design error.
If the chanqe resulting from the corrective action plan descriptions is judqed to be significant, either an "A" for actual or "P" for potential is entered into the appropriate column of Table 3.
Actual is distinguished from potential because corrective actions are not complete and, consequently, the scope of required changes may not be known.
Corrective action plan descriptions are judged to be significant if the resultant changes affect the overall quality, performance, or marqin of a safety-related structure,
- system, or ccmponent.
26430-R26
( 10/15/87)
~
~
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4
~
~'b ~ ~
~
~IW
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER: 3 Page A-1 of 2 ATTACHMENT A EMPLOYEE CONCERNS FOR SUBCATEGORY 22600 Attachment A -- lists, by element, each employee concern evaluated in the subcategory.
The concern's number is given, along-with notation of any other element or category with which the concern is shared; the plant sites to which it could be applicable are noted; and'he concern is quoted as. received by TVA, and characterized as safety related, not safety related, or safety significant.
'01 07A-R43 (10/09/87)
ELEIEIT CONCERN kIIIEI PLANT LOCATIUN ATTACHNEHT A EMPLOYEE CUNCEKHS FUK SUBCATEGORY 22600 APPLICABILITY SIIN wUN B H BLN CONCERN DESCRIPT ION'EVISION HBNBER:
3 PAGE A-2 OF 2 226.0 ul-85-100-023 EEBH "Lighting f/xtures at uBHP are not properly restrained and caqed to prevent tnem from becoming missiles or suinginq missiles durinq seismic events.
Cl nas no further Information.
Anonymous concern via 1etter."
(SR)
BHP-IICP-10.3B-I3 BLH "Safety cable (shown on draEEIngs 4BA0893-X2-43R I and 44RI) does not aka Eaa tha FE t ~.
Et
..I s
I
~
t a
Icnl I k vk ~ kka
~ I~ T
~
~atul I:
~ at
~ coul ~ cM 3T Itlllll QUPPUI t ~
tJhJ SRiNOiSS indicates safety related, not safety related, Or Safety SiqnlfiCant per aeterEnlnatlon criteria In the ECTG Program manual and applied by TVA before evaluations.
PYfiln-'.\\
itlohll/RlI
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER:
3 Page B-1 of 10 ATTACHMENT B
SUMMARY
OF
- ISSUES, FINDINGS, AND CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 Attachment B -- contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and corrective actions.
The reader may trace a concern from Attachment A to an issue in Attachment B by using the element number,and apolicable plant.
The reader, may relate a corrective action description in Attachment B to causes and significance in Table 3 by using the CATO number which appears
'in Attachment 8 in parentheses at the end of the corrective action description.
The term "Peripheral finding" in the issue column refers to a finding that occurred during the course of evaluating a concern but did not stem directly from a emoloyee concern.
These are cl'assified as "E" in Tables 1
and 2 of this report 01 07A-R43 (10/09/87)
Issues ATTACHHENT B SUHHARY OF ISSUES, FINDINGS, ANO CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 Findings REVISION NUHBER:
3 Page B-2 of 10 Corrective Actions 1111111t1111111111 Element 226.0
- Seismic Interaction Design 111111111111111111 SqN a.
Lighting fixtureS are not properly dLsigneU Lo prevent them from becomlngi o
Free missiles o
Swinging missiles which might damage Category I equipment during a seismic event.
C>>O~X
'&i ittndsn P'4
~ CP AS>>A>>
LA gQ
). ~>>L>> ~
K9 -"t
)~A a.
The TVA design of light fixtures provides for adequate vL'IALIC4I supporL Lo LIILnsL4nd 4 seismic cvcnl oAd prevcAt their becoming free missiles that might damage Category I equipment.
The TVA design of light fixtures, per Se, does not. In general, provide adequate horizontal support during and after a seismic event to prevent their horominn swtnninn missiios thtt minht damane Ariidrolit Category I equipment.
However, this design overslgnt has A
s
~ I rr>>>>
C>>>>>>
sn'l>> Udlh IA A
C
\\
A lr ULcll UULUAlcnscU Lvl ol n Ji/n la U UUIU LnPP>> nt U>>v/
ar>>>>>>
~ S being addressed.
SI)N orrec ll l
~~
.pic IA ia escrflgg ction ture I~i ast tud~. t~
Cri:,
~s ~
v SION t~
a ion V'I W fOr j&
ision~
b g~,in am~
u r~fQ~)
i a.
A TVA transmittal submit a c s ~
1 II Ani
.Ll k 1'E ol L IUII t>>loll LI nr / Wll ~ CII
~ l the discrepancies betwee tihi design drawings and desi cTTT provide a complete progr and control the seismic I
e evaiudtinns for current a
design activities;.and pro I
tnrhn/rsl hsrtr
/n>>
tnn tn n
~ ol
~ ~ >> ~ ~ \\>>>> ~
>>>>>>>>s
~ s
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memo from Handy to SI)N fil
$ UV/CC/QQ/ ~
An 4UUILIVII~
II provide for an evaluation the plant previously exclud evaluation Mill use an appr tecnnical program followed oVaiudtinn VIA raiCuiat inn CEO CAS 214, Rl.
This calcu l evlsloA MIII irlcliidc 4 re-r adequacy of written technlca justification of tne existin and as described in findings IOH )399 ( 11/14/86) and IOH f
( 11/19/Bd).
The evaluation t concludes that the stated CAP srrnntshln rninlutinn nf thn C that should also preclude rec Al Al
~ lIIUll>>>>/S ~
UC TD ZZ6 00 S
23400-10 ~/87)
ATTACINENT 8 SUHHARY OF
- ISSUES, FINDINGS, ANO CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 REVISION NUNBER:
3 Page 8-3 of 10 Issues Findings Corrective Actions Element 226.0 - SI)N (Continued) b.
Peripheral Finding.
c.
Peripheral Finding.
d.
Peripheral Finding..
b.
The evaluation team noted that there is no document which describes tne complete program for controlling the seismic interaction design activity.
Technical Instruction TI-98, RO (App. A, S.s) will effectively implement the walkdown activities of this program when amended to address all plant areas.
The TVA memo from Handy to SJN files (04/22/86)
(App. A, 5.k) prov'ides adequate tnresnold criteria for subsequent evaluations.
The division of responsibilities between disciplines is defined in CEB-UI 121.03, Rl, (App. A, 6.f).
In addition, tne CEU seismic review process for future revie~s is to be in 'accordance with a future revision of CEB-OI-121.03, Rl (App. A, 7.o) and includes an evaluation for adverse impact of rod hung items as indicated by IOH f326 (10/Ol/86) (App. A, 7.k).
- However, this evaluation is cqrrently in the form of verbal Instructions which:TVA personnel have comnltted to properly document.
Evaluations of these areas are necessary to determine the need for any potential hardware fixes.
TVA personnel comxitted to perform a walkdown and evaluation of these areas in ION f416 (ll/19/86) (App. A, l.p).
d.
Tne technical basis for the inspection criteria established in TVA memo from Handy to SUN Files (04/22/86) has not been documented.
TVA personnel cmnxitted to providing such documentation in IOH )326 (IO/01/86) (App. A, 7.k).
b.
Refer to a. above.
c.
Refer to a. above.
d.
Refer to a.
above 23400-10 (10/ l2/81)
Issues Element-226.0 - SOH (Continued)
I e.
Peripheral Finding.
1 II f.
Peripheral f1nding.
g.
Peripheral Finding.
a.
Lighting fixtures are not properly designed.to prevent them from becomino '
Free missiles 4
~
~
~
<1 li aII ~ llljIII'l
~ aa
~ Iaa Ourin<) a seismic event, these missl<es mignt damage Caiegory I equipment.
ATTACHHENT 8 SUNHARY OF
- 155UES, FINDINGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 Findings e.
Tne evaluation team considers calculation CEB-CA5-214, Rl generally adequate; however, additional written justification is needed in some areas to permit another engineer who did not participate in the original
- WlalkdOWns io arriVC ai tne Salve I,OOCIUSIOOS ~
IVA personnel coe<aitted to re-review the calculation based on ine above ano make any'ecessary cnanges (App. A, 7.p).
- f. Figure 5.0-1 of the design criteria SON-"OC-V-13. II (App, A. S,rl correctiv illuatrateS the Or<ter<a appliCatlOn Of SeCtiOn 5.0; hOweVer, the detai lS in e<rs ra 4 V
1 4
ts I ~
~ ~
a
~
..Ias l Ivul a aar=
~ Iul aua Yalal vainj
~ igiiaiug uu uus agree wiui the text of Section 5.0.
- g. The principal 'detail for emergency lighting fixtures on 47A057-21, R3 (App. A, 5.u) correctly illustrates tne application of desian Criteria 50N-UC-V-13 ii Section 5.0 (App. A, 5.r).
Ho~ever, the aiternate detail shown on a7A057 21 nd tha amargency'1<ghi deta<1 shot<n on 47A057-6, R5 do not agree with the text of Section 5.0.
MBH a.
Tne TVA design of light fixtures provides for adeauate vertical support to witnstand a seismic event and nrevents the fixtdires from becot<<nn frea la<ss<1as that might damage Category I equipment.
The TVA design of light flxiulCs ~ pCI SYI dOCS not< 'ln geiler41
~ Piruv<de adequate horizontal support during and after a seismic eveni to prevent them from becoming s~inging missiles that might damage adjacent Category I equipment; This design oversight for MBN has not been. documented as a
generic revie~ of tne present=prooram'on SUH as a result of SCR SUN tKB 8610.
Also, no technical instruction was found to effectively
'impIIeealnt plant walkllown act<vities of this program.
REVISION NUHBER:
3 Page 8-4 of 10 Corrective Actions e.
Refer to a. above.
f.
Refer 'to a. above.
g.
Refer to a.
above.
MBH a.
TVA tranSmittalS TCAB 227-MBN through 229-MBH submit corrective action plans Irqpa1 h<
h
<1'I I \\ 1<<
t tl 1
r<
I
~i ~ ~ a ~ ~ ~
1 a<
a ~
~ la ~ ~la ac alla discrepancies between the various design draiingS 4nd design rrlieria, (b) PrOvide a generic MBH review for SCR SON HEB 8610, (c) provide a compiete program to describe and control the seismic interaction evaluations for current and future deSian aetivitieS baaeil On niant walkdown(s) generated information, and ldl v<d t
al<
I b
~
ao internal TVA memo from Handy to SIN files (04/22786) and make ii appiicable io MBH.
In addition, these CAPs will provide for an evaluation via required calculation.
- Further, these CAPS will result ln a new drawing to provide
issues ATTACllHENT 8 SUHHARY OF
- ISSUES, FINDINGS, AHO CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 Findings REVISIOH NUMBER:
3 Page B-S of 10 Corrective Actions Element 226.0 - HBN (Continued) emergency light details which will be forwarded to ONC for retroactive application via tne ECN process; DNC will tnen review completed work to ensure installation in accordance with the drawing or obtain ONE approved variance on a case-by-case basis.
The evaluation team concludes that the stated CAPs are an acceptable resolution of the concern that should also preclude 'recurrence of findings.
CATD 226 00 HBN Ol)
CATO 226 00 HBN 02)
CATD 226 00 MBN 03) b.
Peripheral Finding.
b.
Tne evaluation team noted tnat there is no document that describes tne complete program for controlling the seismic interaction design activity.
The TVA memo from Handy to SlIN files (04/22/86) provides adequate tnreshold criteria for evaluations but does not document the technical basis for the inspection criteria (nor does any other document);
the memo has not been made applicable to MBH.
The div5sion of responsibilities between discipl5nes is defined 5n CEB-Ol )21.03, Rl.
In addition, the CEB seismic review,process for future reviews is to folio~ revision I of CEB-DI-)21.03 when it is issued.
This review process includes an evaluation for adverse 5mpact of rod hung items as indicated by ION 326 ( 10/Ol/86).
This evaluation is currently in tne form of verbal instructions which TVA personnel have coamltted to properly document.
b.
Refer to a.
above.
23400-10
( 10/12/87)
Issues ATTACIUIENT B SUHHARY UF ISSUES, FIHUINGS, ANO CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 Findings REVISION NUHBER' Page 8-6 of 10 Corrective Actions Element 226.0 - NBH (Continued) c.
Peripheral'Finding.
- c. Figure 5.0-1 of Uesign Criteria NB-UC-40-3l.Il correctly illustrates the application of the criteria in Section 5.0; nowever, the details in Figure 4.1-1 and drawing 47A057-6 for the "original e'mergency lignting system" do not auree witn tne.text of WB-DC-40-31 ll Section 5.U.
Detail M of drawing 45H1418-4 shows a
nnrt inn nf tho ocoennlt oleorIIoneu I<oht <no euetooo woe v< I
~
C J
~
Q
~ ~ IQ ef evvlv vv ~ U ~
~
corresponding.to Figure 5.0-I of the design criteria with a reference to drawiAg 41A057 for remaining detaiis.
Drawing 47A051 contains no sucn details.
BFN c.
Refer to a. above.
a.
Liahtino fixtures are nnt proporly desfgned to prevent them from IIoetue<UUI VI I VWI~IJ ~
o Free missiles o
Swinging missiies During a seismic event, these missiles might damage Category I equipment.
lho TVA aoc <on of I <otlt f<vtIIeoe
<o ooooeet 4
J
~
~IIIII I e
~ ~ ~ JI
~ ~I
~ UI Ivuy
~Iuv provide adequate vertical support to withstand a seismic ever<t and io preveAt ihe fixiures from becoming free missiles tnat might damage Class I equipment.
Also, the TVA design of light fixtures does not provide adequate evaluation of horizontal support during and after a
seismic event to prevent the fixtures from becoming swinging miss!Ies that might damage adjacent Class I equipment.
Both of these design issues have been documented -on SCR BFlf&B B605-and are being -addressed.
NRC has initiated several uriresolved safety fssues (USis) that affect the seismic design basis at Browns Ferry.
USI A-17 considers wsystems interactions,"
which include seismic interaction between Class I and bass LI components.
Part of the NRC NRR plan to resolve A-17 is to assign tf<e responsStl<ty for identifying seismic ll-induced adverse system interactions to the USI A-46
- progrmx, SelSmic <fuallffcat-fon Of Equipment in Operating P lants.'-46 concerns margins of safety 'provided by equipmeni in operating power plants to resist seismically induced loads.
The NRC resolution of A-46 is contained in NUKEG-103U and NUREG-1211.
TVA's Browns Feiry Huclear Plant is identified in NUREG-121 1 as one of tne operating plants to be reviewed to A-46 requirements.
~
vcvclop 4 sclslmllc Intel octlon piogl am to evaluate seismic-induced effects of Class ii iiems inciuding lighting fixtures on Class I components.
Perform a walkdown to identify II/I seismic interaction between as-built Class I and Class ll components.
Develop an evaluation methodoleny and prOV<do fivee ac required.
Class II/I evaluation for
'SRISQIIC <AieraCiioA beiWeen as-bu< 1t Class I and Class Il components will be performed under the Unresolved Safety Issue (USI) A-46 program as a
post-restait activity.
A procedure for centrnll<nn futuro II/I co<cmfC interaction will be developed prior to I tt e
eL L
1 ~
e ee ee I VV<I~ CV ~Vll lll lllC VotC I IIIC II 'IV CI I Vl k ~
This procedure will meet the more general requiremenis of aesign interface document CEB-OI-121.03.
(CATO ZZ6 00 BFN Ol)
I i
l I
I, i
2340D-10 ~/87)
Issues ATTACtNtHT 8 SUHHARY OF
- ISSUES, FIHDIHGS, AHD CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 Findings REVISION HUHBER:
3 Page B-l of 10 Corrective Actions Element 226.0 - BFH (Continued) b.
Peripheral Finding.
c.
Peripheral Finding.
d.
Perlpneral Finding.
- b. Tne evaluation team noted tnat there is no document that describes tne complete program for controlling the seismic interaction design activity.
TVA UHE is developing a program to address seismic Interaction between Class I and ll components.
The program consists of two phases:
Pnase I is the program development, which has been started, and Pnase II is the Implementation of the program.
This program will also include development of a long-term program to preclude future ll/I problems.
c.
BFN haS no original design criteria for lignting fixture support.
Ho original design criteria were implemented for design other than the National Electrical Code for the year in which tne design was issued.
Civil Design Guide UG-C1.6.3 for seismic support of lighting fixtures was issued 07/28.
BFN has not implemented this design guide as it was no) a design ceaxitment.
d.
BFN has no typical drawings or specific drawings showing SuppOrt detailS fOr lighting fiXtureS Other than dra~ingS 48WI284-I, -2, and -3 of the main control room lighting supports.
These dra~ings were initially issued for modifications to the control room lighting structure in late 1982 for unit 2 and in 1983 for units 1 and 3.
b.
Refer to a. above.
c.
Watts Bar Design Criteria for lighting fixture supports WB-OC-40-31.11 will be used for the current design of BFH lighting fixture supports.
A criteria wi11 be developed for the future lighting fixture supports based on the A-46 resolution methodology or TVA design guide DG-C-1.6.3 or Watts Bar Design Criteria WB-OC-40-31. I I ( Including the future versions).
(CALO 226 00 BFN 02) d.
Existing lighting fixture support installations wi11 be assessed for structural adequacy and documented under the seismic interaction program which ls part of USI A-46 program and fixes will be provided as required.
Provide drawings <<1th support details or approved field change requests for new installations or rework of lighting fixture supports.
Perform supporting calculations to document structural adequacy for these new or rework supports.
(CATO 226 00 BFN 02) 23400-10
( IO/12/87)
Issues i
Element 226.0 - BFII (Continuedj e.
Peripheral Finding.
f, Perinheral Finding ATTACINENT 8 SUHHARY OF ISSUES, FINUINGS, AND CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 Findings e.
No calculations were performed on lighting fixture supports other than those on the main control room lighting fixtures which were generated in )2/82.
4 Tua L'4 IC'C nkln Ilht tnn n vtlin I I Ct I
~
~ ~
~ ~
a v
~ vs v vvsvu ~ vvevs ~ vs ~
~IIuvti ~ oncvut vlcc ~ laQIn Control Room Lighting" documents the fact that TVA CEB rcVIemed 4n'd 4ppl VVLd LnC ITI4ln COALIol Iumm Cei Ilng and lighting fixture supports shown on drawings 48MI284-I,
-2, and -3.
CEii review and approval for seismic adequacy of these drawings is indicated by TVA memoranda from Coleman and Huie to CEB files.
- However, no analytical data are nrnVtded In the CalCIIlatinn nr 4Iamnrand>> tn demonstrate the adequacy of the control room lighting SLIuCLUIc 4nd IlghLIng I IXLure,Suppnr'L LO With'SL4nd 4 seismic event.
Also, dra~ings 451284-1, -2, and -3 do not snow any end bracing memberS provided in the east-west direction of the control room lightlno structure.
REVISION NUHBER:
3 Page 8-8 of 10 Corrective Actions e.
Refer to d. above.
I.
nucqu4oy or Lnu matIt conLro> roora lighting structure and fixture supports to withstand a seismic event wiii be assessed under the A-46 seismic interaction program.
This assessment will take into consideration that there were no end bracing members provided in thn naet-unct dtrnnttnn nt thn nnntvn)
~
\\ vv ~ vI~ vi vnI \\ VI~vI v ~
room lighting structures.
(CATD 226 00 BFN 02j nsann In II~L 44'1vv Iv L
/
ATTACIIHENT 8 SUHHARY OF
- ISSUES, F INUINGS, ANU CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 REVISION NUHBER:
3 Page B-9 of 10 Issues F
I Element 226.0 - BLN BLN Findings BLN Corrective Actions a.
Lighting fixtures are not properly designed to prevent them from becomingt o
Free miss 1 les o
Swinging missiles Ouring a seismic event, these missiles eight damage Category I equipment.
a.
Tne TVA design of light fixtures provides for adequate vertical support to witnstand a seismic event and prevent the fixtures from becoming free-falling missiles that might damage seismic Category I components.
However, the TVA design of pendant-mounted light fixtures does not, in
- general, provide adequate horizontal support during a seismic event to prevent them from becoming swinging missiles that might damage addacent seismic Category I components.
Inis design oversight for BLN was not addressed during any potential generic condition evaluations such as for SCR SUN HEB 86IO.
a.
Generate a CAIIR to adequately document the BLN generic review of the present program on SIN as a result of SCR SIIN HEB 8610.
(CATO 226 00 BLN Ol) b.
Safety cable is not adequate to seismically support lighting fixtures shown on dra~ings 48A0893-X2-43RI and 44RI.
c.
Peripheral Finding.
.b. Safety cables for emergency exit lignts, where they have been inStalled, appear to be adequate to prevent the items from becoming free falling missiles.
However, the requirement to have a safety cable on all emergency exit lignts In seismic Category I structures nas not been satisfied at this time.
The evaluation team was not able to determine wnether tne installations observed without safety cables were work in progress or had already been accepted by IIuality Control. It snould be noted tnat most installations observed without safety cables were located in areas where the potential for unacceptable interaction witn seismic Category I components was not likely.
The assignment of responsibility to the field for locating safety cables is adequate.
- c. In addition, tne evaluation team noted that there was no document provided by TVA tnat describes a complete and overal I program for control ling seismic interaction design activities.
b.
Complete installation and inspection of lighting fixtures in accordance with project procedures and construction drawings.
Approve any variations prior to final quality control acceptance.
(CATO 226 00 BLN Ol) c.
Prepare a complete procedure for performing a seismic interaction walkdown and evaluating its results to supplement the generic requirements of CEB Ol I2I.03.
Revise tne BLN Engineering Project Hanual to require establishment of spacing criteria for seismic interaction and verification of existing spacing adequacy.
Implement such walkdowns and evaluations before fuel load of each unit.
(CATO 226 00 BLN Ol) 2340D-10
( IO/12/81)
Issues ATTACiUIENT 8 SUNNAqY OF ISSUES, FINDINGS, ANO CORRECTIVE ACTIONS FOR SUBCATEGORY 22600 F indlngs REVI SION NUHBER:
3 Page 8-10 of 10 Corrective Actions Element 226.0 - BLN (Continued) d.
Peripheral Finding.
- d. In addition, the requirements for conditions under which the three-way lateral cable support may be deleted are not consistent between design guide 01.6.3, Figure 18, and design criteria N4-50-0119, Figure 5.0-2, and reconciliation is not available, Bra<<inn 4BA0893-XZ series does not have detail showing Slack in the olort ~ Irsl rshloc st tho oooo nonru llnnttnn ftvtII~ n sr vn J
s J
~
~ V
~
V
~ InsvI %
Qs required by design criteria N4-50-0119, Figure 5.0-3.
Ofailng 4BA0893-X2 ~ although tcchn leo I ly adcquatet does not agree <<ith design criteria K4-50-0119.
The details in Figure 4.2-1 of design criteria N4-50-Oiig and drawing 4BA0893-XZ-1 do not agree with the text of Section 5.0 and figure 5.0-1 of design criteria N4-50-0119.
d.
Revise design criteria, drawings, and I
calculations to remove inconsistencies.
Evaluate any potential hardware impact resulting from these revisions and prOVide anv necoccarv mOdifiCatlenc (CATO 226 BLH 01) 2340D-IZ/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER:
3 Page C-1 of 13 ATTACHMENT C REFER'ENCES l.
Sequoyah Element Report 226.0, "Seismic Interaction Design",
Rev.
2 (12/18/86) 2.
TVA Nuclear Performance Plans:
Revised Corporate Nuclear Performance
- Plan, Volume 1 (03/86)
Revised Sequoyah Nuclear Performance
- Plan, Volume 2 (03/87)
Browns Ferry Nuclear Performance
- Plan, Volume 3 (06/87)
Watts Bar Nuclear Performance
- Plan, Volume 4 (03/87) 3.
Se uo ah Documents a.
Gilbert/Commonwealth's "Final Report Technical Review of SNP Modifications for TVA," G/C Report No. 2614, Technical Issue Data Sheet No.
11 (03/03/86) b.
Letter from J.
H. Taylor, NRC, Director of Office of Inspection and Enforcement to S.
A. White, TVA, Manager of Nuclear Power.
Subject:
"NRC Reports 50-327/86-27 and 50-328/86-27,"
[L44 860506 5423, (04/22/86) c ~
Letter from B.. J. Youngblood, NRC, Director PWR Project Directorate
¹4, NRR to S.
A. White, TVA, Hanager of Nuclear Power,
Subject:
"Concerns Regarding TVA Nuclear Program,"
[L44 860226 0013, (02/18/86) d.
Letter from B. J.
Youngblood, NRC, Director PWR Project Directorate
¹4, NRR to S.
A. White, TVA, Manager of Nuclear Power,
Subject:
"Transcript of Interview...," [nonel, (06/23/86) e.
P. Vineyard, Project Manager to H.
B. Rankin, Manager Design Services.
Subject:
"Routing of Safety Related
- Conduits, Cable Trays, Piping'nd Instrument Lines in Nonseismic Designated Areas in Category I, Structures,"
[825 851205 004],
(12/05/85) f.
TVA SQN memo from H. B. Rankin, Hanger Design Services to J.
P.
Vineyard, Project Manager.
Subject:
[S01 860102 805], (01/03/86) g.
P. Vineyard, Project Hanager to H.
B. Rankin, Manager Design Services.
Subject:
[B25 860107 0113, (01/07/86) 3&60D-RO (10/12/87)
TVA EMPLOYEE CONCERNS
.'iPECIAL PROGRAM'EPORT NUMBER:
22600 REVISION NUMBER:
3 Page C-2 of 13 h.
C. Key,.Mechanicall Lead Engineer to C.
N.
johnson, Civil Lead Engineer, Subject;
,"SCR 8610 Nalkdown Civil Involvement,"
(825 860408 0023',
(l04/08/86')
1.
E,. Andrews to D. N. Wilson.
Subject:
"Nal,kdowns conducted by DNE,"
I'.SOS 860."i02 8143,,
<05/14/86)
E. Andrews, Site (Iuality Manager to H. L.
Abercrombie, Site Director.
Subject:
"Conduct of Plant Walkddwn~
and Surveys,"
l(S08 860418 8113 (04/18/86)
Handy, Mechanical Engineer to SQN Fil.es'.
Subject:
"SCR SQN NEB 8515 - food Hung Category I(L) Sy'tem Interaction Limits with Safety Related Targets
<}uality Design Information," l:825 860422 008] (I)4/22/86)
N. johnson, Civil Lead Engineer to 3. C.
Key,'echanical Lead Engineer.
Subject:
"SNP'-SCR 8610 - Nalkdown Civi,l Involvement,"
I:825 860516
- 0213,
<05/16/86)
TVA SQN memo from D. N. Wilson,'roj'ect Engiheer to H. L. Abercrombie, Site Di rectcIr.
Subject:
"SNP - Seismic Dq~ad, Lqad, Supports Used f'r Class lE Electr)ca'1 Condu1't I'nstal'lation,"
[B25 860603'13],
(06/03/86) n.
o.
E. Estes,
'MeChahical'En)in'eer to W.
1Il. Brown, Mechanical Engineer.
Subject:
"Report'of Results of March 8-9, 1986 Walkdown of 'the Auxiliary Building for Interactions,"
f825 '860606 0033, (06/G5/86) o TVA SQN computerized "Nalkdown Report for Sei'smlc Safety Interfaces SQEP Mechanical Section No. 'I" for the Auxiliary Buiidin'g attached to (825 860606 0033, (04/17/86)
E.
E tes,
'Mechanic'al Engineer to W.
H. Brown Mechanica'I Engineer.
Subject:
"Report of Results of April 26-27,'986 Nalkdown of the Ul and U2 Annulus, Control and Diesel Generator Buildings, and the ERCW Intake Pumping Station,"
[825 860610 00'I].
(06/11/86) o TVA SQN computerized "Nalkdown Report for Identifying Interactions in the Control and Diesel Generat1ng Buildi'ng".~,
'RCN Pump Station and Ul and U2 Annulus" attached to
,[825 860610 001], (04/26-27/86) 3860D-RO (10/12/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'2600 REVISION NUMBER:
3 Page C-3 of 13 p.
N. Johnson, Civil Lead Engineer to SQN CEB files.
Subject:
"Sequoyah Nuclear Plant
'Design Input Memorandum for Location and Design of Piping and Supplemental Steel in Category I Structures Design Criteria, SQN-OC-V-24.1," preliminary (10/03/86) q.
TVA Memo from J.
C. Key, SQN Mechanical Lead Engineer to N. A.
Liakonis.
Sub)ect:
"Auxiliary Building Piping Interaction Nalkdown," f825 861014 0153, (10/14/86) r.
TVA Design Criteria/Guides:
o TVA Design Criteria SQN-OC-V-13.11, Rl, "Support of Lighting Fixtures in Category I Structures,"
(03/23/73) o TVA General Design Information, OG-C1.6.3, "Seismic Support of Lighting Fixtures in Category I Structures,"
(06/05/81) s.
TVA Procedures:
o TVA SQN Technical Instruction TI-98 RO, "Nalkdown Procedure for Identifying Interactions in the Control and Diesel Generating Buildings, ERCH Pump Station and Ul and U2 Annulus," (04/25/86) o TYA SQN USQD for TI-98 RO, (04/25/86) t.
TVA Specification:
o TVA General Construction Specification No. G-32, Rev.
11, "Bolt Anchors Set in Hardened Concrete,"
[B42 851216 5003 (01/31/86) u
~
TVA Drawings:
o
- 47A057, R10, "Mechanical Seismic Supports - Lighting Fixtures" o
45N1410-1, R18, "i.ighting - Plans and Details -
Elev
. 653.0" o
55N416-1, R18, "Lighting - Floor ELev. 732.0 - Plans and Details" o
55N416-2, R19, "Lighting - Floor Elev. 732.0 - Plans and Details" 3860D-RO (10/12/87)
TVA EMPLOyEE CONiCERNS SPECIAL PRO(/RAIN RE:PORT NUMBER:
22600 REVISION NUM8ER:
3 Pa.ge C-4 of 1I3 v.
TVA Conditions Adverse to Quality (C'AQ):
o N~CR SQN MIEB 8304, R2,
[B44 860404 007] (04/04/86) o SCR SQN CEB 8514, RO,
[B4'I 851231 021] and
[841 '860228 017],
(12/24/85) and (02/28/86) o SCR SQN MEB 8610, Rl,
[B44 860611 047] (06/1'I/86)
TVA Ca'lculation:
o CEB CAS 214, Rl "IEvaluation of Walkdown Report for Seismic Safety Interfer ences,"
t:B41 860516 004] (05/16/86) x.
(:825 8606i17'27] (00/19/86) y.
107602,'67603 and l()7627 dated 05/20i/86, 03/09/86, and 03/09/86 respective'ly '[Ihteractions TPW/734/003; HVG/734/003,"i HVG/734/004]
z.
INPO WBN 1985 Audit Finding DC.3-2 aa.
TVA ECEP-SQN Restart Program - Corrective'c'ti*n IPlan (CAP) for Element 226,.0(B),
T(MB-029 (12/i 12'/86) ab.
SNP FSAR Update through Amendmknt 00 3.1 "Conformance witlh NRC General Design Criteria" 3.2 "Classification of Structures, Systems and Components" 3.0 "Electric Power" ac.
NRC Regulatory Guiide 1.29 Rl, 'Seisniilc Dehlg'n Classification," (8/73) ad.
TVA Design Criteria SQN-DC-V-13I.11, Rl, "Support of Lighting Fixtures in Category I Structures',"
'(03/23/73)'e.
TVA General Design, Information',
D'G-(',1.6.3',
Seismic Support of Liglhting Fixtures, in Category I Structures,"
(06/05/81) af.
TVA Policy Memorandum PM86-04(ONE) f'rom W. C. Drotleff, Director of Nuclear Engineering to Those List'ed.'ub)ect:
"Engineering Judgment,"
ltB20 860424 001] (04/25/86>
ag.
TVA Design Interface Document CEB-Dk 151.03, Rl, "Seismic Design,
- Review, aind Control,," (05/16/86) 3860D-RO (10/12/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM'EPORT NUMBER:
22600 REVISION NUMBER:
3 Page C-5 of 13 ah.
IEEE Standard Criteria for Class 1E Power Systems for Nuclear Power Generating Stations, IEE Std 308-1971 4.
Watts Bar Document Gilbert/Commonwealth, "Final Report Technical Review of SNP Modifications for TVA," G/C Report No. 2614, Technica.l Issue Data Sheet No.
11, (03/03/86) c ~
d.
e.
Letter from J.
M. Taylor, NRC, Director of Office of Inspection and Enforcement to S.
A. White, TVA, Manager of Nuclear Power.
Subject:
"NRC Reports 50-327/86-27 and 50-328/86-27,"
[L44 860506 542], (04/22/86)
Letter from B."'. Youngblood, NRC, Director PWR Project Directorate
¹4, NRR to S. A. White, TVA, Hanager of Nuclear Power,
Subject:
"Concerns Regarding TVA Nuclear Program,"
[L44 860226 001],
(02/18/86)'etter from B. J. Youngblood, NRC, Director PWR Project Directorate
¹4, NRR to S, A. White, TVA, Manager of Nuclear
- Power,
Subject:
"Transcript of Interview
.," [B45 860714 832], (06/23/86)
TVA SQN memo from K. D. Handy, Mechanical Engineer to SQN Files.
Subject:
"SCR SQN NEB 8515 - Rod 'Hung Category I(L) System Interaction Limits with Safety Related Targets Quality Design Information,"
EB25 860422 008], (04/22/86) f.
TVA 'Design Cri teria/Guides:
o TVA Design Criteria WB-DC-40-30.11, RO, "Support of Lighting Fixtures in Category I Structures,"
(07/03/75) o TVA General Design Information, DG-C1.6.3, "Seismic Support of Lighting Fixtures in Category I Structures,"
(06/05/81) o Electrical Design Standard DS-E 17.,1.1, R2, "Lighting and Heating - Lighting Design Standards and Practices,,"
(06/15/83)
TVA Specification:
o TVA,General Construction Specification No, G-32, Rev.
11, "Bolt Anchors Set in Hardened Concrete,"
[B42 851216 500], (01/31/86) 3&60D-RO (10/12/&7)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'2600 REVISION NUMBER:
3 Page C-6 of l3 h.
TVA Drawl ng.:
o 47A057 <Revisions as of 01/24/87),
"Mechanical.Seismic Supports
- Lighting Fixtures" o
45H1410-1, R21 "Lighting - Plans and Details - Elev. 676.0" o
45H1418-4, R10 "Lighting - Plans and Details" o
55H416-1, R15, "Lighting - Floor Elev.. 755.0 - Plans and Deta,i ls" o
55H416-2, R15, "Lighting - Floor Flev. 755.0 Plans and Details" TVA Conditions Adverse to Quality (CAQ):
o NiCR HBN MEB 8305, R2, EMEB 840111 018] (01/li/84) o SCR HBN C'EB 8537.,
RO.,
[B4'I 861010 003] (10/10/&6) o SCR SQN MEB 8610, Rl, (B44 860611 047] <06/1'1/86)
INPO HBN 1985 Audit Finding DC.3-2 k.
TVA memo from E. Chi twood to C. A. Charidliey, Chief Mechanical Eng'ineer, "Potential Generic Cbndition'Evaluation (OEP-17),"
[B43 860404 913], (04/04/86)
TVA meimo from R.
O. Barnett, Chief C:iviil iEngineer, to C. A.
Chandley, Chief Mechanical Engine'er,'Potential Generic Cond'jti'on'va'luatjori (OEP-17),"
1[841 860311'()6],
(59/11/86)
HBN FSAR through Amendment 54 3,.1 "Conformance with NRC General, De~~ign Crit;eria" 3,.2 "Classification of Structures'ystems and Components"',.0 "Electric Power" 9,.5.3 "Lighting Systems" n.
o.
NRC Regulatory Guide 1,.29 Rl, "Seismic Design Classification," (8/73)
TVA. Design Criteria HB-DC-40-30.11, RO "Support of Lighting Fixturies in Category I Structures,"
(0//03/75) 3860D-RO (10/12/87)
TVA EHPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'2600 REVISION NUMBER:
3 Page C-7 of 13 p.
TVA General Design Information, DG-C1.6.3, "Seismic Sup'port of Lighting Fixtures in Category I Structures,"
(06/05/81) q.
TVA Policy Memorandum PH86-04(DNE) from W. C. Drotleff, Director of Nuclear Engineering to Those Listed.
Subject:
"Engineering Judgment,"
[B20 860424 001], (04/25/86) r.
TVA Design Interface Document CEB-DI 121.03, Rl, "Seismic Design,
- Review, and Control," (05/16/86),
s.
IEEE Standard Criteria for, Class lE Power Systems for Nuclear Power
.Generating
- Stations, IEEE Std 308-1971 5.
Browns Ferr Documents a.
Gilbert/Commonwealth's "Final Report Technical Review of SNP Modifications for TVA," G/C Report No. 2614, Technical Issue Data Sheet No.
11 (03/03/86) b.
Letter from J.
M. Taylor, NRC, Director of Office of Inspection and Enforcement to S. A. White, TVA, Manager of Nuclear Power.
Subject:
"NRC Reports 50-327/86-27 and 50-328/86-27,"
[L44 860506 542], (04/22/86) c.
i.etter from B. J. Youngblood, NRC, Director PWR Project Directorate 4,
NRR to S.
A. White, TVA, Manager of Nuclear Power,
Subject:
"Concerns Regarding TVA Nuclear Program,"
[L44 860226 001],
(02'/18/86) d.
Letter from B. J. Youngblood, NRC, Director PWR Project Directorate 4,
NRR to S.
A. White, TVA, Manager of Nuclear Power,
Subject:
"Transcript of Interview...," [845 860714 832], (06/23/86) e.
TVA memo from J.
P. Stapleton to H.
P.
Pomrehn.
Subject:
"Browns Ferry Nuclear Plant Unit 1, 2, 3 Engineering report for CAQ Report No.
SCR BFN HEB 8605, Rev. 0," (B22 86 0717 003], (07/17/86) o CAQ Engineering
TVA memo from R.
W. Cantrell to G.
W. Painter.
Subject:
"Browns Ferry Nuclear Plant Request for use of existing, personal serv,ices contract,"
L'no RIMS number],
(01/26/87) g.
Letter from R. 0. Barnett, TVA, to P. Yanezfv]',
EQE Inc., "Seismic Interaction (II/I Program),"
(S41 861124 001], (ll/24/86) 3860D-RO (10/12/87)
TYA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
Z2 00 REYISION NUMBER' Page C-8 of 13 h.
Letter from R. 0. Barnett, TVA to R.
- 1. Pruski, Sargent and'undy Engineers,
'"Seismic Interactior) (II/I Program>,"
l'.841 86lll24 002]
(11/24/86>
i.
Proposal 0197-33 from R.,3. Pruski, Sargent and Lundy Engineers, to R. 0. Barnett, TVA, "Seismic Interac'tion Between Class I and Class II ~Components,"
(12/16/86)
A Proposed Plan for Evaluation of Seismic Related Category II oyer Category I and Proximity Conditions at Browns Ferry Nuclear I~lant Unit 2 (12/17/86) k.
TVA memo From,'I.
M. Mar.shall tci R,.
O. 8'arnett, "Applicability of'att:s Bar SCR CEB 8537 to Brownis Ferry,'" [822 860107 004], (01/07/86) 1.
TVA memo from H.
I~. Crisler to C. A. Chandley, "Applicability of Sequoyah SCR MEB 8610 to Browns'erry," 'f822'60307 008], (03/07/86) m.
TVA Draiwings:
o 48Hll?84-1, R;I, "Miscellaneous Steel Main Control Room Lightin'g Supports" o
48H1284-2; Rl, "Miscellaneous Steel Main Control Room Lightin'g Supports" o
48Hl?84-3, RO, "Miscell'aneous Steel Main Control Room Lighting Supports" o
45N1408-3, RB, "Lighting Floor Elevation 6'17.0 Plan and Dekaiis Sheet 3"
o 45NZ408-3, R6, "'Lighting Floor Elevation 6'I7.0 Plan and 'Dei'.ails Sheet 3"
0 n.
o.
o 45N3408-3, R9, "Lighti'ng Floor Elevation 617.0 Plan
- Shee't 3"
SCR IBFN CEB 8602, RO, (841 860109 014],
[841 860312 007]
E841 861020 001];
(011/09/86),,
(03/'12/86) ahd '(10/20/86)
SCR BFN CEB 8603, Rl [IB41 8604it8 00ki],
(0'4/2'8/86)'CR l3FN CE'8 8524, RO 6841 8511~+2 50$ ].
', 5841,'860203 006]
8610;?0 015];
( 1 1 /21/85),
(Ol /24/86')
and '10/20/86>
and 'Det';ail s and'nd f841 3860D-RO (10/lI2/87)
TVA EMPLOYEE CONCERNS SP ECIAI PROGRAM REPORT NUMBER:
22600 REVISION NUHBER:
3 Page C-9 of 13 s
~
u ~
V.
w.
x ~
y ~
SCR BFN NEB 8514, RO [B45 851223 852] (12/23/85); Rl, [no RIHS number],
(01/14/87)
SCR BFN EEB 8543, Rl, [822 861117 034], (10/14/86)
[844 860703 007], (07/02/86)
TVA EN DES Calculation "Miscellaneous Steel Main Control Room Lighting," [BWP 830707 101], (07/07/83)
INPO WBN 1985 Audit Finding DC.3-2 Letter from R. Gridley, TVA, Manager of Licensing to D.
R. Muller,
- NRC, BWR Project Directorate 2, "TYA's new plan for compliahce to 10 CFR 50 Appendix R for BFN," [L44 860131 809], (01/31/86) o 10 CRF 50 [10 CFR 50] Appendix R Submittal Fire Protection and Safe Shutdown Systems Analyses Report for Browns Ferry Nuclear Plant TVA Draft version of TVA-BFN "Seismic Design Basis Status Report,"
(03/86)
Service for Evaluating Regulatory Changes, MS-86-53, "ACRS Full Committee Meeting on the Resolution of Unresolved Safety Issue A-17, Systems Interactions in Nuclear Power Plants,"
(05/08/86)
TVA memo from F.
H. Coleman to CEB Files,
Subject:
"Browns Ferry, Squadcheck TP-00103, Main Control Room Ceiling and Lighting Fixture Supports -
ECN P0590,"
[CEB 821222 257], (12/22/82)
TVA memo from J.
T. Hule to CEB Files,
Subject:
"Browns Ferry, Hain Control Room Ceiling and Lighting Fixture Supports ECN P0590,"
[CEB 830707'51],
(07/07/83) aa.
BFN FSAR Update Through Amendment 4 dated 08/06/86 Section 1.6, "Plant Description" Section 8.0, "Electrical Power Systems" Section 10.19, "Lighting System" Appendix A, "Conformance to AEC Proposed General Design Criteria" Appendix C, "Structural Loading Criteria" 3860D-RO (10/12/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600
'EVISION NUMBER 3
Page C-'ll0 of 13 ab.
NRC Regulatory Gu'ide 1.29 Rl', "Sel,smlc Design Classification" (08/'73) ac.
Atomic Energy Commission Safety Guide 29, "Seismic Design Classification,"
<06/07/72)
(superseded by NRC Regulatory Guide 1.29) ad.
NRC NUREG-0606, "Unresolved,Saflet)
IIssu'es'Summary,"
USI-A17 and USI-A46 (0&/16/&5) ae.
NRC NUREG-1030, "Seismic (}ualifiicitidn0f Equipment in OperatinI]
Nuclear Power Plants," Unresolved Safety 1ssipe A-46, Draft RepoIit for Comment
<0&/85) andi Final Report -(02/87) af.
TVA-BFN Design Cr'iteria BFN-50~789 "Nor'mal, Standby, and Emergency Lighting Systems for the Hain Control Rooms," (01/09/84) ag.
TVA General Design Guide, DG-C1~.6.'3,'S'eismic Support of Lighting Fixtures ln Category I Structur'es,'"
<06'/05/81) ah.
TVA Design Interface Document CEB-'DI'2'1.03, Rl',
Seismic
- Design, Review and Control," (05/1I6/86) ai.
. 10 CFR 50,, Appendix R, "Fire Protection Program for Nuclear Facilities Operating Prior to 3anuary 1,
1979" a).
NRC NUREG-1211, "Regulatory Analysis for Resolution of Unresolved Safety Issue A-46 Seismic Qualification of Equipment in Operat'ing Plants,"
<02/87) 6.
Bellefonte Documents 0
a.
b.
c ~
Gilbert
/Commonwealth
"Final Repc>rt, Technical IReview of SNP
'odifications for TVA," G/C Report:
NI>. 2614, Technical Issue Data Sheet hlo.
11 (03/03/86)
Letter from 3.
M. Taylor, NRC, Director of'ffice of Inspection anId Enforcement to S.
A.. white, TVA, Manager. of Nuclear Powe~r.
Sub]ect:
"NRC Reports 50-327/86-27 and 50-32&/86-27,"
[L44 860506 542], (04/22/86)
Letter from B. 3. Youngblood, NRC, Director PNR Pro)ect Directoratie 4,
NRR to S.
A. Nhite, TVA, Manager of Nuclear Power, Sub)ect:
"Concer:ns Regarding
'TVA Nuclear Program,"
[L44 860226I 001],
(02/18/86) 3860D-RO (10/12/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER:
3 Page C-11'f 13 d.
Letter, from B. J.
Youngblood, NRC, Director PWR Project Directorate 4,
NRR to S.
A. White, TVA, Manager of Nuclear Power,
Subject:
"Transcript of Interview...," [845 860714 832], (06/23/86) e.
INPO WBN 1985 Audit Finding DC.3-2 f.
TVA Design Criteria/Guides:
o TVA Detailed Design Criteria N4-50-0719, Rl, "Seismic Support of Lighting Fixtures in Category I Structures,"
{:ESB 840717 204], (07/09/84) o TVA General Design Criteria N4-50-D725, Rl, "Assignment of Responsibility for Analysis,
- Support, and Fabrication of Piping Systems,"
{:ESB 831115 217], (11/09/83) o TVA General Design Criteria N4-50-0711, R3, "Detailed Analysis and Seismic Qualification of Category I and I<L) Piping Systems,"
(B42 851112 524], (10/17/85) o TVA General Design Information, Civil Design Guide DG-C1.6.3, Rl, "Seismic Support of Lighting Fixtures in Category I Structures,"
{:ESS 810608 229], (06/05/81) g.
TVA Specifications:
o TVA Construction Specification No. N4C-913, R4, "Support and Installation of Piping Systems in Category I Structures,"
[BOS 86027 501], (06/18/86) o TVA General Construction Specification No. G-32, Rll, "Bolt Anchors Set in Hardened Concrete,"
{:842 851216 500], (01/31/86) h.
TVA Drawings:
o 4BA0893-X2 Series, (latest revisions as of 06/87),
"Seismic Supports
{.ighting Fixtures" o
5AW0420-RW Series, (latest revisions as of 06/87), Auxiliary Building Lighting Floor Plans and Details o
5CW0420-RW Series,
<latest revisions as of 06/87), Control Building Lighting Plans, Sections and Details 38600-RO
<10/12/87)
TVA EMPLOYEE CONCERINS SPEC:!Al PROGRAM REPORT NUMBER:,
22600 REYIS[ON NUMBER.'3 Page C-12 of 13 o
SDW0416-RN Series,
('atest revisions as of 06/87),. Diesel Generator Building Lighting Plans and Details o
SRW0416-Rll Series,
('atest revisions as of 06/87), Reactor Building Lighting Plans and Details TYA ca1lculatlop 48893-01, R9, "Seismic l lghting Fixture Supphrti,"
i
[821 860423 401,], (01/29/87)
TVA Conditions Adverse to Quality (CAQ):
o SCR
'SQN MEB 8610, Rl, [844 860611 047], (06/11/86) o SCR BFN MEB 8605, RO, E844 860703 007], (07/02/86)
.o SCR BLN,MEB 8509, RO, E844 851219 009], (12/18/85) o NCR BLN EEB 8420, RO, EEEB 8412'31 912], (12/31/84) o PI[R WBN CEB 8572, RO,
[841 851212 014], (12/12/85) o PER BLN CFB 8519, RO,
[841 869303 902], (03f03/86) o SCR NBNI CEB 8537, RO,
[841 861010 003], (10/10/86) o BLN NCR 2058, RO,
[Bl N 830503 709], (04/27/83) k.
TVA memo from H.
N. Benninghoff t6 C. A. Chandley, "Potential Generic Condition Evaluation (OEP-17),
[821 860715 093], (07flS/86) 1.
TVA,memo from.'I. P.
Nooten to R. 0.. Barnett,'"P'otential Generic CondIit'Ion Evaluation (OEP-17),'821'5'1126 010], (11/26/85)
TVA memo from R.
M. Hodges to R.
O. IBarnett, "BLN - Emergency Lighting Fixture Supports,"
[BLP 820517 008], (05/14/82) n.
o.
TVA memo from R. 0. Barnett to 'R.'M.'odge's, "BLN - Emergency Lighting Fixture Supports,"'CEB 820614 013], (06/14/82)
TYA Report ciEB 80-33,
'"Be'I lefonte'NuIcle'ar Plant, Dynamic Earthquake Analys',Is of the Auxiliairy-Control Building and
Response
Speci:ra for Attached Equipment,"
R4,. [CEB 841015 017], ('IO/15/84) 3&60D-RO.
(10/12/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22600 REVISION NUMBER:
3 Page C-13 of 13 p.
BLN FSAR through Amendment 27 3.1 "Conformance with NRC General Design Criteria" 3.2 "Classification of Structures, Systems and Components" 8.0 "Electric Power" 9.5.3 "Lighting Systems" NRC Regulatory Guide 1.29, Rl, "Seismic Design Classification" (08/73)
TVA Design Interface Document CEB-DI 121.03, Rl, "Seismic Design,
- Review, and Control," [B05 860516 500], (05/16/86) s.
TVA Design Interface Document CEB-DI 121.03, R2, "Seismic Design,
- Review, and Control," [B41 870702 002], (07/02/87)
~
'860O-RO (10/12/87)
I
~
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~i 0
E il