ML20205J274

Review Plan for Sequoyah Nuclear Plant Mods for Tva

ML20205J274
Person / Time
Site:	Sequoyah
Issue date:	01/31/1986
From:	GILBERT/COMMONWEALTH, INC. (FORMERLY GILBERT ASSOCIAT
To:
Shared Package
ML20205J269	List: ML20205J265 ML20205J274
References
2606, NUDOCS 8601300145
Download: ML20205J274 (19)

Text

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l REVIEW PLAN FOR SEQUO.YAH NUCLEAR PLANT MODIFICATIONS FOR TENNESSEE VALLEY AUTHORITY l

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. BY GILBERT / COMMONWEALTH, INC.

JANUARY 1986 G/C REPORT NO. 2606 IO*$00$!SIOb $7 r 3 ,

Gilbert / Commonwealth ENGINEERS / CONSULTANTS Reading, PA/ Jackson, MI ,

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1 TABLE OF CONTENTS ]

Title Page Section 1

1.0 PURPOSE OF REVIEW 1

2.0 SCOPE 3.0 ORGANIZATION 1 j 1

3.1 G/C REVIEWTEAM 3.2 REVIEW BOARD 2 4.0 APPROACH 2 4.1 PHASE 1 - REVIEW PREPARATION 2 4.2 PHASE 2 - PROGRAM REVIEW 5 4.3 PHASE 3 -TECHNICAL REVIEW 5 4.4 PHASE 4 - RESOLUTION OF ISSUES 8 4.5 PHASE 5 - REPORT DEVELOPMENT 8 List of Exhibits Exhibit 1 -Technical Data Sheet Exhibit 2 - Observation Sheet Exhibit 3 - Personnel Contacted Exhibit 4 - Documents Reviewed Exhibit 5 -Observation Log Exhibit 6 -TechnicalIssue Log Exhibit 7-Summary of ActionsTaken -

Exhibit 8 - Report Content / Format Exhibit 9 -Technical Review Process 1

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1.0 - PURPOSE OF REVIEW The purpose of this review is to provide TVA management with additional l assurance that the modifications on the Sequoyah Nuclear Plant (SQN) Units 1 1 and 2 are technically adequate and consistent with safety and licensing commitments.

2.0 SCOPE The scope will cover modifications initiated and implemented on the Main and

! Auxiliary Feedwater System since issuance of the operating license for SQN Unit 1. The modifications will be evaluated for effect on system operation, conformance with original design bases (including design parameters and

< licensing commitments), interfaces with other plant systems and structures, ,

and field implementation and documentation. Methods of implementing i Unit 1 modifications on Unit 2 will be assessed and discussed in the final report.

3.0 ORGANIZATION 3.1 G/C REVIEW TEAM The G/C review team will be directed by a Team Leader or, in his ab~sence, an appointed designee. Team. membership will consist of senior representatives of the technical disciplines, quality assurance, and design control. The

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l designated lead from each discipline is indicated below. Additional resources j will be provided, as needed, in the interest of expeditious completion of the review.

-Team Leader ' W.J. Leininger

- Structural Lead G.B. Sanders

- Mechanical Lead M.J. Akins  !

- Electrical Lead R.P. Cronk i l

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- Control Systems lead A.P. Smith

- Piping Lead C.W. Whitehead l

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- QA Lead H.A. Manning

- Design Control Lead C.C. Paschall

-3.2 REVIEW BOARD The review board will consist of the G/C Team Leader, the Sequoyah Office of Engineering (OE) Project Manager, and the Manager of Design Services -

Sequoyah. They will review identified issues to confirm or obtain clarification of the issue description and to assure that proposed resolutions are appropriate and completed in a timely manner. Each board member has available the resources of the technical department / branch chiefs of their respective organizations to aid in confirmation of the issues' merit and the ultimate acceptance, refinement, or rejection of the issues. The review board has the authority to initiate further action as deemed necessary.

4.0. APPROACH The proposed approach for the review has been divided into five phases:

Phase 1 Review Preparation Phase 2 Program Review Phase 3 Technical Review Phase 4 Resolution of Issues Phase 5 Report Preparation.

Phases 2 and 3 will be conducted concurrently and, following identification of issues to be resolved during Phase 3, Phase 4 can proceed concurrently with Phase 3. Because the scope of Phase 4, Resolution of Issues,is contingent upon the number and complexity of issues identified, the schedule for completion of f Phases 4 and 5 will be determined at the end of Phase 3.  !

4.1 PHASE 1 -REVIEW PREPARATION

1. Prior to initiation of the review,TVA will have provided:

a. The list of plant modifications (sorted by system) made since issuance of the operating license.

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b. Identification of the Design Control Program requirements applicable to Sequoyah design for each discipline between 1980 and 1985.

c. Identification of the sources of the design bases, such as the FSAR and design criteria documents for the Main and Auxiliary Feedwater System.

2. Independent of TVA, G/C has selected the Main and Auxiliary Feedwater System for review. This selection was based upon the following criteria:

a. The system has nuclear safety-related functions.

b. The system has undergone a sufficient number of modifications to enable adequate review.

c. The system modiikations appear to be multidisciplinary or of sufficient number to enable review of work performed by key.

engineeringdisciplines.

d. The modifications are such that an assessment can be made regarding configuration control, identification of design inputs, and performance of Unreviewed Safety Question Determinations.

e. The modifications.are such that the impact of their mplementation on interacting systems can be assessed.

f. The modifications appear to be significant to the operating onditions of the system.

g. The modifications appear to include one or more external interfaces.

Further examination of identified or suspected technical issues may require lateral expansion of the review to other systems.

3. This review plan has been developed by G/C and' accepted by TVA as part of the review preparation to identify the purpose, scope, organization, methodology, and documentation requirements of the review. While most of these details are contained in other sections of the plan, one significant planning activity not described elsewhere has been the i 3- . _

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establishment of categories for identification and expeditious disposition of review results.

" In essence, two categories of issues have been defined as requiring different levels of priority in resolution. Because the focus of this review is technical adequacy of design, a distinction has been drawn between l technical issues and those concerning discrepant or nonconforming l documentation: l

a. Cateaory 1 - Questions of Technical Adequacy .

1 These issues are the most significant results of the review, and the l apparent consequence of failure to meet design or licensing l criteria. Category I issues will be identified on Technical issue Data Sheets (see Exhibit 1). Because these issues may have safety implications, Category I has been further divided:

Cateaory lA - Questions of Technical Adequacy Which Appear to Have Potential Safety Sionificance These issues will be communicated to TVA most expeditiously. It is recognized that OEP-17 establishes a corrective action system via the Significant Condition Report (SCR) for those items identified by TVA as conditions adverse to quality. The G/C review team will assist to the extent possible in providing the information needed to fully execute the appropriate TVA program controls.

Cateaory IB - Questions of Technical Adequacy Which Do Not Appear to Have Potential Safety Sionificance

. These issues will be so noted and identified to TVA promptly for  ;

resolution as conditions adverse to quality. l l

b. Cateaory II - Documentation Discrepancies. Omissions, or Noncompliance Category 11 issues are considered of less significance to the purpose of this review, but will be identified to TVA on Observation Sheets (see Exhibit 2) for TVA disposition. The close-out of issues in this category will not be pursued by the review team unless an issue

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appears to be generic or traceable to root caus? of a Category I issue.

4.2 PHASE 2 - PROGRAM REVIEW G/C will review the Design Control Program in effect from issuance of the operating license for Unit 1 until June 1985 for the purpose of confirming that a controlled process was in place governing design modifications o'n both units. Conclusions of this review will provide a basis for analysis of the generic implications of any technical issues identified during Phase 3. Apparent program omissions will be evaluated in light of the current Design Control l

Program requirements, if a concern arises from this' review, it will be reported as a Category ll issue, unless attributed as root cause to a Category I issue.

Ultimately, recognition of programmatic controls over the design change process will serve as a basis for extrapolation of the technical review results to the balance of modifications on both Units 1 and 2.

4.3 PHASE 3 -TECHNICAL REVIEW The technical review will be accomplished.in accordance with the following guidelines:

1. If possible,it is the intent of the review team to review all of the design changes completed for the Main and Auxiliary Feedwater System since issuance of the operating license. In . general, the changes will be reviewed in chronological order. In the event that there are too many changes in one or more disciplines to be reviewed in the three weeks scheduled for Phase 3, the Team Leader will:

a. Authorize the deletion of certain types of changes not deemed as

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b. Add personnel to the review team in the disciplines where needed, or

c. Extend the review period (TVA concurrence required).

During both the design change research and the review of documents, all team personnel will maintain individual lists of persons contacted (see

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Exhibit 3) and of documents reviewed (see Exhibit 4). These will be submitted to the Team Leader at the end of each week.

2. Each reviewer will research the conditions and status of each design modification by interviewing responsible personnel or, when available, the historical participants. The purpose of this research is to establish the framework and context of the design work. This information can be oral and informal during the research and interview process. To the extent possible, the following sh'o uld be determined:

a. Reason for the change

b. Scope of the change

c. Schedule and duration of design

d. Criteria and inputs, including licensing commitments

e. Internal and externalinterfaces

f. Functionalinteraction

g. P hysical i nte ra ctio n/inte rfe re n ces

h. Design completion status

i. Implementation status.

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3. The reviewer should request access to documents for each change under i review:

a. Documentinitiating or requesting change 4 b. Engineering Change Notice

c. Design criteria

d. Calculations / Analyses performed 1

e. Verification documentation

f. Design output documents 6- .

g. Vendor drawings

h. As-built drawings

i. Applicable sections of Technical Specifications and FSAR

j. Other regulatory commitments i

k. Unreviewed Safety Question Determinations. l l

To determine the technical adequacy and correctness of the design work, l the reviewer may perform a step-by-step review or independently 1 perform informal approximate calculations. When calculations are performed and the results indicate a possible problem, the reviewer must go back into the original documentation to identify the source of the discrepancy.

4. All issues identified during the review of documents which constitute a nonconformance with program requirements, documentation discrepancies or omissions, violation of code, regulation, or commitment, or an inadequate or incorrect design will be documented either on a Technicalissue Data Sheet (see Exhibit 2) or on an Observation Sheet (see Exhibit 3) as described above. All issues thus documented will be considered drafts until they are reviewed by the review board, clarified as necessary, and assigned an identifying number. Thereafter they will be considered controlled documents.

TechnicalIssue Data Sheets will include a recommendation for corrective action, based upon the review team's understanding of the technical issue, root cause, and extent of the concern.  ;

The G/C Team Leader will maintain separate logs for observations and technical issues. The Observation tog (see Exhibit 5) is used solely for j tabulation of total observations resulting from the review since accoun, ting for disposition of observations is not within the scope of this I review. The Technical Issues Log (see Exhibit 6) is used for identification and tracking of issues to close out.

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4.4 PHASE 4- RESOLUTION OF ISSUES The review board is responsible for maintaining control of follow-up activities .

to achieve expeditious close-out of each Technicallssue Data Sheet.

Close-out of issues will be based upon:

1. Additional analysis / documentation by TVA or,

2. Development of a documented justification by G/C, or

3. Recognition of an existing TVA program which will resolve the issue, including any generic implications, as part of its scope.

The program plan for handling issue close out activities is as follows:

1. Upon the review board concurrence with the validity of an issue, a target completion date and responsible party for close-out will be assigned.

2. When recommended action is completed, the individual responsible for issue resolution will complete the Summary of Actions Taken (see Exhibit

7) and submit it to the review board for concurrence.

3. The review team discipline lead will review the Summary of Action Taken, including any additional or revised documentation. Upon his acceptance of the follow-up activities, the discipline lead will then I

complete the " Description of Action Taken" section of the Technical issue Data Sheet, change the revision level, and notify the review board that the issue is closed.

To the extent possible, Category lA issues will be resolved and closed before the final report is written. Any issues remaining open at the start of Phase 5 will be so noted in the final report.

i 4.5 PHASE 5 - REPORT DEVELOPMENT The final report will be developed in accordance with the format shown in Exhibit 8. As indicated in the format, the report will summarize the review methodology, consolidate technical results, and state the review team's overall conclusions. The focus of the report will be upon the Category Iissues, with particular emphasis on any issues found to be of safety significance. The 8

- specific details concernin'g the issues (i.e., Technical Issue. Data Sheets and .

Observation Sheets) will be included in the report as appendices. l The report will be submitted to TVA management for comment prior to final issue to ensure that no incorrect information is inadvertently reported.

Key activities associated with the technical review process are presented in flow chart format in Exhibit 9.

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r 3 TECHNIC.' L ISSUE DATA SHEET caen SEQUC ' AH NUCLEAR PLANT N O.:

Commonwealth Qompanies y l ORIGINATOR: REVISION: DATE:

l ISSUE DESCRIPTION:

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OF ACTIONS TAKEN SEQUOYAH NUCLEAR PLANT ISSUE NO.:

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DESCRIPTION OF SPECIFIC AND GENERIC CORRECTIVE ACTIONS:

l DESCRIPTION OF PREVENTIVE MEASURES TAKEN:

REFERENCES (DOCUMENTS DEVELOPED OR REVISED FOR CLOSE OUT):

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r 3 REPORT / CONTENT FORMAT ciie.n SEQUOYAH NUCLEAR PLANT

. Ccamonweaitn Qompaniesj Section Title Pace EXECUTIVE

1.0 INTRODUCTION

1.1 Purpose of the Review 1.2 Scope of Work 1.3 Organization 2.0 REVIEW METHODOLOGY 2.1 Review Preparation 2.2 Program Review 2.3 Technical Review 2.4 Resolution of issues 3.0 REVIEW RESULTS 3' Program Review Results 3.4 Technical Review Results 3.2.1 Mechanical j 3.2.2 Electrical )

3.2.3 Controf 5ystems 3.2.4 Structural 3.2.5 Piping -

4.0 CONCLUSION

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APPENDICES l Appendix A -

Personnel Contacted Appendix B -

Documents Reviewed .

Appendix C - Technical Issue Data Sheets Appendix D -

Observation Sheets sy m arr a