ML20153B010
| ML20153B010 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/11/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20127A683 | List:
|
| References | |
| NUDOCS 8803210326 | |
| Download: ML20153B010 (3) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION n
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SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS EMPLOYEE CONCERN ELEMENT REPORT 20101 "INCORPORATION OF REQUIREMENTS AND COMMITMENTS IN DESIGN" TENNESSEE VALLEY AUTHORITY SE000YAH NUCLEAR POWER PLANT UNITS 1 AND 2 I.
SUBJECT Category:
Engineering (2000)
Subca tegory:
20101 Element:
Incorporation of Requirements and Comitments in Design Employee Concern:
WI-85-100-001, XX-85-122-001, -002 and -003 The basis for Element Report 20101 Revision 1, dated January 23, 1987, is an Employee Concern stating, "Electrical and I&C Regulations (Reg. Guides, NUREGs, Bulletins and Notices) have been ignored and violated to a very large degree at all pla nts.
This has been caused by a lack of knowledge, a poor attitude toward safety and regulations, and a lack of knowledge of industry positions on regulations on the part of TVA personnel."
II. EVALUATION The TVA Employee Concern Task Group (ECTC) in their investigation of Element Report 21303, "Inadequate Electrical Design Criteria and Inadequate Considera-tion Given to Electrical Standards and Guides" which in part is similar to Element Report 20101, substantiated that in early 1986 TVA detennined, through Gilbert /Comonwealth, Inc., reviews of Sequoyah's modifications, that the design criteria did not reflect TVA comitments made in the FSAR, responses to NRC avalua' ions and generic design criteria.
This finding applied to Instru-mentation and Controls along with other desian items. As a result, TVA established a Design Basis Document Program (DBDP) to update the design criteria documents and capture licensing comitments and regulations.
Further details on this overall subject are addressed in the TVA's Element Report 21303 and the NRC's Safety Evaluation Report for Employee Concern 21303.
In TVA's investigations of TVA's knowledge of appropriate regulatory guides, NUREGs, bulletins and notices in Electrical and Instrumentation and Control areas, it was detemined that in general appropriate personnel were knowledge-able of design requirements and that they were familiar with the industry positions to these documents.
However, it was apparent that regulatory documents ccmitted to by TVA were not, ir, all cases, properly incorporated in design documents and implemented.
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____ - -_. These findings were based on a review of NRC requirements and design documents and interviews with technical personnel.
NRC through its investigations essentially agrees with the above findings.
As a result of these investigations TVA took measures ta correct existing deficiencies and deterrine the adequacy of designs and installation of hardware. TVA has developed and implemented several corrective action programs which include the Sequoyah Design Baseline and Verification Program for assessing the adequacy of design criteria the m the design basis for systems required to mitigate FSAR Chapter 15
.ients and safely shut down the piant; the Comitments/ Requirements Database rrugram for identifying, verifying and maintaining Sequoyah's licensing comitments and design requirements and providing input to reconstruct the original design basis; and the Design Basis Program for providing the Sequoyah Plant Design Basis against which proposed plant modifications can be measured.
The staff has reviewed and inspected these programs and finds that they are being implemented in an acceptable manner and that proper corrective actions have been initiated to assure that the designs and installed hardware are acceptabic.
Further discussion of this issue are addressed in Section 2.3.3 of Volume 2, Part 1 of NUREG-1232, "Safety Evaluation Report on TVA Sequoyah Nuclear Ferformance Plan."
In regard to the allegatior of TVA's poor attitude towards safety and regula-tiens, it is apparent through TVA's efforts to respond to the NRC 10 CFR 50.54(f) letter of September 17, 1985 that poor management was a significant factor in contributing towards poor attitudes and ineffective implementation of the OA program.
The problem with the management of TVA's nuclear program was the widespread shortage of experienced managers.
To remedy this situatior, TVA has hired new experienced managerr, to fill key positions.
Collectively, these new managers have a broad base of experience and knowledge in the design, construction, modification and operations of nuclear facilities.
Another part of the problem with TVA management was a poorly structured organi-
- ation.
TVA undertook a major reorganization of its nuclear program.
The new organization concentrates authorit)y for nuclear operations within a single position (Manager of Nuclear Power and divorces nuclear operations from all non-nuclear acs.ivities within TVA.
TVA has assigned the responsibility for its nuclear utivities to the Manager of Nuclear Power.
The concentration of responsibilities and authority in the Office of the Manager of Nuclear Power provides the incumbent with broad power to identify and correct problems with the nuclear program. TVA has stressed and emphasized the importance of management's new comitment to conduct activities in accordance with TVA's standards and regulatory requirements.
To ensure this is acccmplished TVA has documented its improved organizational and program changes in TVA's Corporate and Sequoyah Nuclear Performance Plans.
These plans provide evidence that TVA management supports the proper implementation of the revised 0A program.
In addition TVA through its QA Topical Report, TVA-TRS-1A, Revision 9 has revised its QA program comitments in the areas of organization, engineering (design) assurance, technical auditing, nonconfurmance track'ng, trend analysis, corrective actions, and root-cause analysis.
' Overall the staff finds these plans and the implerrentation of these plans acceptable recognizing that NRC continue to inspect and monitor them.
Sound corrective measures have taken place in TVA's organization management systems and QA program.
In sumary the staff finds the corrective measures acceptable with reasonable assurance that TVA now has the capabilities and program improvements to conduct their activities in accordance with SAR and regulatory requirements.
The staff finds these overall management and program improvements acceptable.
III. SUPNARY Instances were identified where some TVA connitted to regulatory documents were not properly incorporated in the design.
Also there were examples found where TVA management expressed a poor attitude toward safety and regulations.
In general, personnel'were knowledgeable of those regulatory requirements refer-enced in design documents.
Corrective action programs have been established to assure the design accurately reflects NRC requirements and that these design documents are properly maintained.
Also, TVA's QA program controls and management systems have been restructured and improved to provide the necessary emphasis and direction in assuring regulatory and FSAR comitments are correctly implemented.
IV.
REFERENCES Element Report 21303 "Inadequate Electrical Design Criteria and inadequate a.
Consideration Given to Electrical Standards and Guides."
b.
NRC Safety Evaluation Report for Employee Concern 21303.
c.
NUREG-1232 "Safety Evaluation Report on TVA Sequoyah Nuclear Perforwance Plan."
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