ML20207K641
| ML20207K641 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/07/1986 |
| From: | Walton R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K584 | List: |
| References | |
| 201.1(B), 201.1(B)-R, 201.1(B)-R00, NUDOCS 8701090473 | |
| Download: ML20207K641 (27) | |
Text
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 0 TITLE: INCORPORATION OF REQUIREMENTS AND COMMITMENTS IN DESIGN PAGE 1 0F 26 Regulatory Requirements (Reg. Guides, NUREG, Bulletins,etc.)
o Policy and Practice on Review, and Response and Implementation o Knowledge of Industry Practices o Attitude toward Safety and Regulations REASON FOR REVISION:
PREPARATION PREPARED BY:
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0
/( PAGE 2 0F 26
- 1. CHARACTERIZATION OF ISSUES:
_ Concerns: Issues:
WI-85-100-001 a. There is a general lack of knowledge
" Electrical and I&C regulations of Regulatory Guides, NUREGS, and IE (Reg. Guides, NUREGS, Bulletins Bulletins and Notices on part of and notices) have been ignored TVA personnel.
and violated to a very large degree at all plants. This has b. Regulatory Guides have been ignored been caused by a lack of know- and have been violated to a large ledge, a poor attitude toward degree.
safety and regulations, and a lack of knowledge of industry c. NUREGS have been ignored and have positions on regulations on the been violated to a large degree.
part of TVA personnel. CI has no further information, d. IE Bulletins and Notices have been Anonymous concern via letter." ignored and have been violated to a large degree.
XX-85-122-001, -002, -003 "Sequoyah - Electrical and e. There is a lack of knowledge of
/" I&C regulations (Reg. Guides industry positions on regulations on k NUREGS, Bulletins and notices) the part of TVA personnel, have been ignored and violated to a very large degree at all plants. This has been caused by a lack of knowledge, a poor attitude toward safety and NOTE: The following issue from the regulations, and a lack of know- concerns is addressed in another report.
ledge of industry positions on regulations on the part of TVA There is a poor attitude toward
, personnel. CI has no further safety and regulations on the part information. Anonymous concern of TVA personnel. (Addressed by TVA l
via letter." in Report MP-70600.)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0 d.f PAGE 3 0F 26 l
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO 1 Identified by TVA, NSRS Date March 10, 1986 Documentation Identifier:
TVA NSRS Investigation Report I-85-651-SQN, " Electrical Regulations Ignored and Violated," (03/10/86)
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
Electrical and I&C regulations (Regulatory Guides, NUREGS, Bulletins and Notices) are specifically noted.
- 4. INTERVIEW FILES REVIEWED:
Expurgated files WI-85-100 and XX-85-122 were reviewed and no additional unreviewed information was found.
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- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendir A.
- 6. WHAT REGULATIONS, LICENSING COMMITNENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREAT See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAN REVISION NUMBER: 0 e
, 0] PAGE 4 0F 26
- 8. EVALUATION PROCESS:
identifying applicable Regulatory Guides, NUREGS, Bulletins, and Notices applicable to Sequoyah (SQN) Plant.
- b. Reviewed a sample of design criteria to determine if appropriate Regulatory Guides, etc., were referenced.
! OEPs, NEPs) and SQN project engineering procedures (SQEPs) to determine if they adequately address these issues.
- d. Reviewed prior QA audits, NRC inspection reports, SALP reports, and other related documents, where available, for evidence that TVA might not have followed procedures,
- e. Reviewed available transcripts of NRC investigative
- interviews to gain additional information regarding the concerns.
- f. Reviewed the TVA Corporate Nuclear Performance Plan (CNPP),
Volume I, R1, and the Sequoyah Nuclear Performance Plan f (NPP), Volume II, R1 where they were related to this element, for additional information regarding these concerns.
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- g. Reviewed TVA program described by SQEP-18 for the generation, verification, and maintenance of the Commitments / Requirements (C/R) Database to determine the extent to which it will j
address these issues.
! h. Reviewed Design Baseline and Verification Program (DBVP) and l
Design Basis Program (DBP) for SQN to determine the extent to which they will address these issues.
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n TVA ENPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAN REVISION NUMBER: 0
-h~ PAGE 5 0F 26
- 9. DISCUSSION. FINDINGS. AND CONCLUSIONS:
Discussion:
9.1 BACKGROUND
The Sequoyah Plant design was begun in the late 1960s when regulatory requirements were not required to be well documented. 10CFR50 Appendix B criteria were not put in place until July 1970. Through the mid and late 1970s requirements were more rigorously and uniformly imposed throughout the industry. Many Regulatory Guides in use today were only in developmental stages during SQN design, and were issued by NRC after the Sequoyah initial design was completed.
Many regulatory changes now reflect later operating experience, and, of course, were not included in the original design. It is not practicable or necessary at this point to attempt to update the SQN plant to include all of the new guidance published by NRC, unless there are specific l requirements to do so.
O 9.2 CURRENT SEQUOYAH PROGRAMS The Sequoyah Design Baseline and Verification Program (DBVP) was established to assess, among many other things, the adequacy of all design criteria that form the design basis for the SQN plant safety-related systems required to mitigate
! FSAR Chapter 15 accidents or safely shut down the plant.
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This program includes review of all related items noted in
- the Commitment / Requirements Database and defines which items included in the design criteria must be completed prior to plant restart.
Sequoyah Engineering Procedure SQEP-18 now in place provides for the establishment, verification, and maintenance during the life of the plant, of the Commitments / Requirements (C/R)
Database. This database identifies SQN Licensing Commitments and Design Requirements that should be captured and reflected in design documents. The scope of this effort covers not only safety-related, but also nonsafety-related structures, systems, and components. This database provides the input to reconstruct the original design basis of the SQN plant.
The SQN Design Basis Program (DBP) is now being implemented to provide the needed SQN Plant Design Basis against which proposed plant modifications can be measured.
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TVA ENPLOYBE CONCERNS REPORT NUMBER? 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0
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-Vhe PAGE 6 0F 26 The following discussion further addresses these programs, which are-a systematic approach to establishing and-maintaining design requirements.
9.3 GOVERNING DOCUMENTS AND DEFINITIONS Documents Regulations and other formal requirements are established by the following controlling documents:
o .The Atomic Energy Act of 1954, as amended o Code of Federal Regulations, Title 10 o Show Cause Orders o Confirmatory Orders o 10CFR50.54(f) Letters o Amendments to Operating Licenses (licensing conditions) o Atomic Safety and Licensing Board and Appeal Board Decisions o ASME Code (endorsed by 10CFR50)
The following types of documents, among others such as Standard Review Plans and Branch Technical Positions, reflect
(@; NRC staff positions which, unless complied with or satisfied by an acceptable alternative, could be imposed by formal requirement. They establish regulatory guidance and are not mandatory unless implemented by formal requirements or formally conunitted to by TVA.
o Regulatory Guides o NUREG Reports o Office of Inspection and Enforcement (OIE) Bulletins o Office of Inspection and Enforcement (OIE) Notices Definitions Regulatory Guides. As defined by the NRC Directorate of Regulatory Standards on the first page of each Regulatory Guide:
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" Regulatory.. Guides are issued to describe and make available to'the public methods acceptable to the NRC Regulatory staff of implementing specific parts of the Commission's regulations, to delineate techniques used by the' staff in
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(8)
SPECIAL PROGRAN REVISION NUMBER: 0
( PAGE 7 0F 26 evaluating specific problems or postulated -
accidents, or to provide guidance to applicants.
Regulatory Guides are not substitutes for regulations and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.
"The NRC requires a separate review of any alternative methods or positions that are proposed; this review can result in an extension of the licensing schedule."
NUREGs. NUREGs are reports which address Unresolved Safety Issues (USIs) and other generic issues and may be transmitted directly to industry, usually by Generic Letter.
Inspection and Enforcement (OIE) Bulletins. These documents are issued to groups of licensees to provide information about, and to direct action on, generic problems that affect or may affect the licensee (s) facilities. The bulletins may variously require inspection, reporting, and the making of f<E ' commitments to implement controls ce remedial actions. The required action may pertain to safety, safeguards, or security-related conditions resulting from inadequacies or failures that occurred at the licensee's facilities or at similar facilities. A schedule for the responses is usually stated. Bulletins normally pertain to problems of considerable significance and demand quick response.
OIE Circulars and Information Notices. These documents are similar to NRC-0IE bulletins, but cover problems that are not as significant or immediate. Response to NRC is generally not required on these items, but TVA may be required to investigate these problems for applicability to TVA plants.
Commitment / Requirement. A commitment or requirement is a verbal or written statement made to the NRC or other regulatory body promising action on safety-related (nonenvironmental) matters, or a requirement by such a body for action on safety-related (nonenvironmental) matters.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAN REVISION NUMBER: 0 r
l' PAGE 8 0F 26 Najor sources of commitments are: ,
o Preliminary Safety Analysis Report (PSAR) o Final Safety Analysis Report (FSAR) o Updated FSAR (UFSAR) o PSAR Amendments o FSAR Amendments o TVA Letters to NRC (including responses to NRC-0IE) o TVA Meetings with NRC, Advisory Committee on Reactor Safeguards (ACRS), or Atomic Safety and Licensing Board (ASLB)'
o TVA telecons with NRC, ACRS, or ASLB The TVA licensing organization receives Regulatory Guides (drafts, formal issues, and revisions), NUREGs, and OIE Bulletins and Notices directly from the NRC. Where needed, response times are specified in the documents.
9.4 EVALUATION OF GOVERNING PROCEDURES In reviewing the issues contained in this element, the evaluation team examined the past and present practices, procedures, and processes used at Sequoyah for handling licensing commitments and regulatory requirements.
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The various engineering groups provide technical support to i the TVA Nuclear Safety and Licensing Staff, which in turn interfaces with NRC.
TVA engineering licensing support procedures were excmined for requirements regarding the Regulatory Guides, NUREGs, and
! OIE Bulletins and Notices as they have evolved for the Sequoyab Plant.
! The SQN Quality Assurance Nanual (App. A, 5.k) along with Engineering Design (EN DES) Procedures (App. A, 5.m), Office of Engineering Procedures (OEPs) (App. A 5.n), Nuclear l
Engineering Procedures (NEPs) (App. A, 5.o), and Sequoyah l Engineering Procedures (SQEPs) (App. A, 5.p) are applicable
. procedures for SQN from early design stages to the present.
The SQN QA Manual provided the original procedures for Engineering to use in the licensing support effort.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0 i PAGE 9 0F 26 Prior to October 1973, design engineering for TVA nuclear plants was performed by the Architectural, Civil, Electrical, and Mechanical engineering branches or discipline groups which worked on several nuclear plants concurrently. Each branch provided its engineering personnel with technical direction through Branch Design Manuals.
In October 1973, an organization change at TVA resulted in the establishment of the Division of Engineering Design. At this time a project system was established that assigned engineers from the engineering branches (which had evolved from the four branches noted in the preceeding paragraph into the Civil, Electrical, Mechanical and Nuclear Branches) to work exclusively on a specific project, such as Sequoyah.
New division-wide procedures, called Division of Engineering Design, Engineering Procedures (EN DES, EPs), were established and were in effect from 1974 to mid-1985. These EPs were quite detailed and prescriptive, and included many administrative controls in addition to addressing quality assurance requirements. The following procedures (App. A, 5.m) pertain to this element:
o EN DES-EP 2.07, initially issued in October 1974, outlined how nonenvironmental licensing commitments k's "
made by Office of Engineering (OE) to NRC were identified, controlled, and tracked to completion.
o EN DES-EP 2.08, initially issued in July 1975, provided for the review of NRC Regulatory Guides, the transmission of TVA's comments to NRC, and the establishment of a position concerning the degree of conformance of each TVA nuclear plant to any applicable guide.
o EN DES-EP 2.06, initially issued in 1976, addressed the distribution and review of regulatory documents such as Regulatory Guides. The focus of the procedure was the action required of the Nuclear Engineering Branch's (NEB) Nuclear Licensing Section (NLS).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 10 0F 26 o EN DES-EP 2.10, initially issued in January 1978, assigned responsibilities for processing a bulletin, circular, or information notice from the NRC Office of Inspection and Enforcement (OIE) when the NRC-0IE document related to any TVA nuclear plant. The procedure outlined how these documents should be handled, and how problems they addressed were to be resolved in Office of Engineering Design and Construction (OEDC) and the Office of Nuclear Power (ONP).
o EN DES-EP 2.11, also initially issued in January 1978, covered the EN DES handling of responses to NRC-0IE Inspection Reports Orders Immediate Action Letters, and Confirmation of Action letters.
In June 1985, the new procedures (OEPs) became effective, and OEP-14 (App. A, 5.n) addressing licensing support replaced the various EN DES EPs.
The new OEPs reduced or eliminated most of the administrative details previously found in the EPs. In place of a stand-alone procedure with many instructions, the OEP referred the reader directly to other procedures that Cf. -
controlled these individual actl>1 ties. The end result was a series of single sentences that provided anyone unfamiliar with the process rather minimal direct instructions on how to accomplish a given activity.
. In July 1986, the reorganized Division of Nuclear Engineering (DNE) procedures (NEPs) became effective, and NEP-2.1 (App. A, 5.o) addressing licensing support replaced OEP-14.
These procedures closely resembled the content, format, and brevity of the OEPs issued a year earlier. NEP-2.1,
" Licensing Support" requires the active use of other referenced NEPs for full understanding of what is to be done.
From NEP - 2.1, Section 1.0, Definitions:
" Licensing: Those activities required to derenstrate compliance with Federal, state, and local requirements in the design, construction, and operation of TVA facilities.
" Licensing Support: Regulatory engineering activities performed within DNE (Division of Nuclear Engineering) in support of licensing."
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 0 I PAGE 11 0F 26 TVA policy on Licensing Support, NEP-2.1, Section 2.0, states:
"DNE prepares input to support and obtain licenses and permits for the design, construction, and operation of TVA facilities in compliance with Federal, state, and local regulations and requirements. Licensing documents and responses to Federal, state, and local agencies must accurately reflect the technical requirements of the design, construction, and operation of TVA facilities as identified in design input and design output documentation.
"The coordination within DNE of submittals for licenses and permits will be delegated to a lead discipline branch."
The General Requirements of NEP-2.1, Section 3.0, state:
"3.1 Lead Responsibilities The following organizations in DNE have been assigned the lead responsibility to coordinate all licensing support
(" activities in their associated areas:
(NEB) Nuclear Engineering Branch, Nuclear Licensing (MEB) Mechanical Engineering Branch, Environmental Licensing (EEB) Electrical Engineering Branch, FAA Permits (CEB) Civil Engineering Branch, Security Permits" Each Engineering branch has an area of responsibility as appropriate in licensing support activities.
Responsibilities for regulations in the noted areas then rest with each organization.
Of the four areas defined above, this element report focuses on nuclear licensing support, and thus deals with NEB and the work of the Corporate Nuclear Safety and Licensing Group and with the Site Licensing Group at Sequoyah as outlined in the NPP Volume II (App. A, 5.x).
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0 I PAGE 12 0F 26 Subsection 3.2 of NEP-2.1 identifies required licensing documents. The following documents are mandatory in the nuclear licensing of TVA projects and facilities:
" Preliminary Safety Analysis Report (PSAR) -
Required with application for nuclear plant construction permit
" Final Safety Analysis Report (FSAR) - Required with application for nuclear plant operating license
" Updated Final Safety Analysis Report (UFSAR) -
Annual updating of operating plants' FSARs as required by 10CFR50.71(e)
" Topical Reports (TR) - Submitted to NRC on subjects common to several nuclear plants and which require a safety assessment by NRC (e.g.,
TVA Nuclear Quality Assurance Program)
"Other Licensing Submittals - Coordinated DNE responses to NRC Bulletins and Information Notices, and responses to questions, 10CFR50.55(e)
(?* and 10CFR21 reports, violations, etc.
" Physical Security / Contingency Plan (PS/CP)"
9.5 COMMITMENTS When a commitment that has a significant effect on LNE's scope of work, responsibilities, licensing, and safety is made to NRC or another regulatory body, the commitment will be tracked to closure with the Corporate Commitment Tracking System (CCTS) as described in Sequoyah Element Report 201.5.
The commitment is controlled and monitored by the PE/ Lead Nuclear Engineer. Procedures outline how licensing commitments made to the NRC are identified, controlled, and tracked to completion. In general, the various procedures are adequate.
Tracking of commitments at the SQN Plant was examined in Sequoyah Element Report 201.5 and found adequate.
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TVA ENPLOYEE CONCERNS REPORT NUNBER: 20101(B)
SPECIAL PROGRAN REVISION NUMBER: 0
-( PAGE 13 0F 26 The following excerpt is from the TVA Corporate NPP (CNPP)
(App. A 5.y):
d "TVA has had a nuclear licensing group at its corporate headquarters for a number of years, and it also has licensing groups at each of its nuclear plant locations which were essentially independent of the headquarters group. ... "
1 Because this has contributed to weaknesses in TVA's licensing activities, TVA has committed in the CNPP to centralize these activities under a single director who reports directly to the Manager of Nuclear Power.
Procedure SQEP-18 (App. A, S.p) identifies commitments and requirements as source information for Sequoyah design criteria development. The following excerpts from the procedure describe its key points:
"This procedure establishes a systematic approach to identify the licensing commitments and other 2 design requirements which should be captured and reflected in design documents. The scope includes both safety-related and nonsafety-related systems,
([ structures, and components."
! "A Licensing Commitment is an action related to i
the design, construction, operation or testing of a TVA nuclear plant that has been communicated to an organization authorized to regulate TVA activities." ,
"A Design Requirement is any technical requirement
, or internal TVA commitment which is essential for j
the safe or reliable operation of a nuclear plant."
- "The concept used is a top-down approach in which commitments made in generic upper tier design input documents,' commitments made in licensing documents, design requirements, TVA policies, and
> existing design criteria must be captured in l either plant-specific design criteria or other i design input documents."
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAN REVISION NUMBER: 0
( PAGE 14 0F 26 "The program requires senior engineers and managers who are familiar with the design evaluation to research the applicable source documents and identify the plant design requirements and commitments. [These reviewers]
. . . complete a comr.itment/ requirements (C/R) data sheet for each licensing commitment or design requirement identified in accordance. . . ."
[with the procedure. This information is then entered into the database.]
"The program establishes a database containing the commitments / requirements to be initially incorporated into the design criteria. The database will then be turned over to the project and maintained throughout the life of the plant."
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"A continuous review of new source documents (e.g., Change Documents, Vendor letters, Correspondences, System Design files, Job Books, etc.) for commitments / requirements will be done by the Responsible Engineer / personnel who deal with the various source documents."
9.6 EVALUATION TEAN INVESTIGATIONS In the NRC investigative interview the CI notes several specific cases where regulatory guides were allegedly not incorporated on time or at all. It also implies that the CI's real concern is perhaps with an apparent lack of timely communication between the group handling incoming NRC guidance and the ultimate user groups (engineers and designers) in the Electrical and I&C areas. The further implication is that design input documents (i.e., Design Criteria) are not either updated or generated in a timely manner.
The majority of the SQN licensing commitments were made in the late 1960s and early 1970s and many of the present day documents were not SQN requirements. This may have led the CI to perceive that some requirements were not properly addressed at SQN.
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TVA EMPLOYEE CONCERNS REPORT NUNBER: 201.1(B)
SPECIAL PROGRAN REVISION NUMBER: 0 f PAGE 15 0F 26 A sample of design criteria (App. A., 5.qq, re, ss, and tt) was reviewed and, in general, regulatory guides, generic letters, etc., were being addressed properly. This was not an in-depth review to determine if all applicable requirements were incorporated in each document.
Some specific inadequacies in the incorporation of Electrical and I&C Regulations in design documents are addressed in detail in Sequoyah Element Report 213.3.
i The TVA Investigative Report I-85-651-SQN (App. A 5.vv) l indicated that concerns raised in the Electrical and I&C area I
. . . were substantiated, but TVA management is fully aware of the conditions and has planned corrective action in accordance with the Nuclear Performance Plan."
Four SALP Board. reports were reviewed which cover the SQN Operations for the period from July 1, 1980 through May 31, 1985 ( App. A, 5.gg, hh,11, and jj ) . In general, the SALP Board evaluated the performance of several areas of plant operations rather than examining engineering design or construction. However, in the most recent report (App. A, 5.gg), the Board's examination in the area of fire protection
, and Appendix R requirements found four items that could be f"7 attributed to omission of required features by the engineering organization. These items were identified as one violation for several discrepancies of not meeting
. requirements of Appendix R of which three could be attributed to engineering. These are:
" Failure to provide adequate fuse / breaker protection for equipment required for test standby."
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" Failure of the oil collection system for reactor coolant pumps to meet Appendix R Section III.0 requirements."
" Emergency Lighting Units did not meet Appendix R Section III's requirements."
The fourth item was identified as a:
l " Deviation for failure to provide status lights in l the control room for fire protection system l containment isolation valves as stipulated in the FSAR."
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TVA RNPLOYRE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAN REVISION NUMBER: 0 h PAGE 16 0F 26 In addition to the SALP Board evaluation, TVA conducted an Appendix R reevaluation program that identified 121 safe shutdown system / cable interaction discrepancies (App. A, 5.gg)
The evaluation team also reviewed a sample of six NRC Inspection Reports (App. A, 5.kk, ll, mm, nn, oo, pp). These reports did not identify any violations that could be attributed to Engineering having violated or ignored a i requirement.
The C/R Dctabase program was discussed with cognizant TVA personnel on several occasions, and samples of the input data
' sheets and output reports were examined. If properly implemented, the program is adequate to capture both prior and future commitments and requirements and to maintain the database current.
Full implementation of the DBVP, DBP, and the C/R Database (per SQEP 18 R2) programs, which includes a controlled overview by the TVA Engineering Assurance (EA) organization
- (App. A, 5.uu) and external audits (App. A, 5.cc, dd, ee, ff),
should adequately resolve these programmatic issues.
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{} Documentation was examined (e.g., App. A, 5.ww) to determine the extent of TVA involvement with others in the industry regarding establishing and discussing industry positions on regulations and requirements published by NRC. Interviews and discussions (e.g., App. A, 7.m) were also conducted on this subj ect. Sufficient information was provided to the evaluation team to indicate more than adequate TVA participation in this area.
There is ample evidence of TVA participation in related i professional society (e.g., ASME, IEEE) activities during the design and construction phases of SQN. Involvement in various I
committees and subcommittees was at both chairperson and lower levels.
TVA has participated in NSSS Owners Group activities since the l~
mid-1970s, becoming more active following issuance of NUREG 0737 in 1979. Again, participation in committee work was at both Chairperson and lower levels. Participation with other Utilities (e.g., Duke Power) and other industry groups (e.g.,
EPRI) was also noted.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 0
(~ PAGE 17 0F 26 Findings
- a. The evaluation team found no evidence to support the allegation that there is a general lack of knowledge of Regulatory Guides, NUREGs, and OIE Bulletins and Notices on the part of TVA personnel. Based on the documentation reviewed and interviews conducted during the course of the employee concerns review, appropriate TVA personnel are cognizant of the requirements.
- b. Regulatory Guides provide guidance for licensees and do not define a regulation unless they are imposed by a requirement document or they are formally committed to by TVA.
Evidence was found to indicate that some regulatory guides applicable to SQN were not addressed or incorporated in a timely manner. An example of this is discussed in detail in Sequoyah Element Report 213.3.
In the evaluation team review no evidence was found of regulations or requirements being intentionally ignored or violated. Sometimes, however, action on such matters was not completed in an appropriate period of time.
- c. NUREGs provide guidance for licensees and do not define requirements unless the NUREGs are included in an NRC showcause order, letter, or other form of licensing commitment. Therefore in this context they cannot be violated. Most NUREGs also allow alternative approaches as long as deviations are identified and are justified. No evidence was found to indicate that NUREGs applicable to SQN that have been committed to were ignored or violated.
- d. OIE Bulletins reflect NRC staff positions which, unless complied with or a satisfactory alternative is offered, could be imposed by a formal requirement. Since they are not regulations, they cannot be violated. However, evidence was found to indicate that some TVA responses to bulletins were both late and partially incomplete or inadequate.
OIE Notices are issued by NRC to give early notification of possible significant events. Usually Notices suggest review for possible applicability, but no feedback to the NRC is requested. Since they are not regulations, they cannot be violated. No evidence was found that any Notices were intentionally ignored.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0
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- e. The evaluation team found no evidence of a general lack of knowledge of industry positions on regulations.
Documentation reviewed indicated active TVA participation in NSSS Owner's Group efforts as well as in technical societies (IEEE, ASME, etc.) at both committee and subcommittee levels.
Conclusions:
o Regulatory Guides, NUREGs, and OIE Bulletins do not by themselves define a regulation. They do not become a regulation unless imposed by an NRC requirement document or committed to by TVA. Appropriate TVA personnel are cognizant of regulations and requirements for SQN.
o No evidence was found of regulations or requirements being intentionally ignored or violated. However, evidence was found of late incorporation of some Regulatory Guides and of some late and incomplete TVA responses to NRC.
o The issues that there was a general lack of knowledge on the part of TVA personnel regarding Regulatory Guides, NUREGs, and OIE Bulletins and Notices and that they were generally
(; ignored and violated by design engineering is not valid, o Appropriate TVA personnel are indeed aware of industry positions on regulations. Examples of this are provided by the ongoing TVA participation in NSSS Owner's Group efforts and in Technical Society committees and subcommittees.
Therefore, the issue that there was a lack of such knowledge on the part of TVA personnel is not valid.
o Since the majority of the SQN licensing commitments were made in the late 1960s and early 1970s, many of the present day documents were not SQN requirements. This may have led the CI to perceive that some requirements were not properly addressed at SQN.
o Sufficient evidence has been noted to establish that in the past some regulatory requirements were not properly addressed at Sequoyah. However. TVA now has programs in place to correct and further mitigate such occurrences. Examples of those programs are the C/R Database (per SQEP 18, R2), the DBP, and the DBVP.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM I
REVISION NUMBER: 0
( PAGE 19 0F 26 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Chapter 1 Appendix B. " Quality Assurance Criteria For Nuclear Power Plants"
- b. ANSI N45.2.11 - 1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
- c. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- d. ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants"
- e. Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction) " RO, (06/07/72)
- f. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- g. Sequoyah Preliminary Safety Analysis Report, (PSAR)
?
- h. Sequoyah Final Safety Analysis Report (FSAR) Updated, through Amendment 3.
- 1. TVA TR 75-1A, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," R8
- j. TVA, Nuclear Quality Assurance Manual. (NQAM), (11/14/85)
- k. Sequoyah Nuclear Plant Quality Assurance Manual (SON OAM)
Quality Assurance Procedures (QAPs) employed in the review of this element are from Revision 11 of the SQN QAM (and prior).
I
- 1. Office of Engineering Design and Construction (OEDC) Quality Assurance Manual
( k l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0
( PAGE 20 0F 26 APPENDII A (Cont'd)
- m. TVA, EN DES Eng_i.neering Procedures Manual. This evaluation refers to the fellowing:
Volume 1 Section 1.0, Category: General Volume 2, Section 3.0, Category: Engineering EN DES Engineering Procedures (EP) reviewed were:
EP No. 2.06, R4 " Distribution and Review of Licensing and Regulatory Information," (04/06/81)
EP No. 2.07 R6 " Licensing Commitments - Control and Tracking " (02/28/85)
EP No. 2.08, R6 "NRC Regulatory Guides - Review, Comment, and Documentation of TVA Conformance,"
(09/14/84)
EP No. 2.10, R7 "NRC - OIE Bulletins, Circulars and Information Notices - Distribution and Preparation of Responses," (03/02/84)
(}
EP No. 2.11, R4 "NRC - OIE Inspection Reports, Orders, Immediate Action Letters, and Confirmation of Acting Letters - Handling and Preparation of Responses," (08/23/83)
EP No. 3.01, R6 " Design Criteria Documents - Preparation, Review, and Approval," (05/22/84)
The following OEPs are referred to in this evaluation:
OEP-06, R0 " Design Input," (04/26/85)
OEP-10, R0 " Review," (04/26/85)
OEP-14 R1 " Licensing," (12/02/85) k.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAN REVISION NUMBER: 0
(' PAGE 21 0F 26 APPENDII A (Cont'd)
- o. TVA, Nuclear Engineering Procedures (NEPs):
NEP-2.1, RO " Licensing Support" (07/01/86)
NEP-3.2, R0 " Design Input" (07/01/86)
NEP-5.2, R0 " Review." (07/01/86)
SQEP-13, R0 " Procedure for Transitional Design Change Control," (07/25/86)
Sequoyah Engineering Procedure SQEP-18 R2 " Procedure for Identifying Commitments and Requirements as Source Information for Sequoyah Design Criteria Development" SQEP-29, " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant," R1 (07/18/86)
- r. Sequoyah Nuclear Plant Design Criteria Manual (6 Volumes),
(06/26/86)
(N2
- s. TVA memo from W. C. Drotleff, to Those Listed (R. G. Domer, et al), " Design Basis Program for TVA Nuclear Plants,"
(B44 860402 007), (04/08/86)
- t. TVA Memo from W. C. Drotleff, to Those Listed (H. L. Abercrombie, et al), " Transition to Division of Nuclear Engineering Procedures," (B05 86 0410 008), (04/14/86)
- u. TVA memo from D. W. Wilson to Those Listed (G. Aklu, et al),
"Sequoyah Nuclear Plant - Design Baseline and Verification Program," (B25 860506 020), (05/06/86)
- v. Letter from NRC to S. A. White, TVA, " Transcript of Interview of Dallas R. Hicks," (06/23/86)
- w. TVA memo from R. L. Gridley to Those Listed (H. L. Abercrombie, et al), "Sequoyah Nuclear Performance Plan - Volume II - Final Concurrence," (L44 860714 800),
(07/34/86)
(
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0
~
( PAGE 22 0F 26 APPENDII A (Cont'd)
- x. Sequoyah Nuclear Performance Plan, Volume II, R1 (approval scheduled for July 16, 1986)
- y. TVA Revised Corporate Nuclear Performance Plan, Volume I, R2 (08/13/86)
- z. TVA memo from J. F. Cox to M. T. Tormay, "Sequoyah Design Basis Program to Support Restart," (B25 860811 100),
(08/11/86) aa. Letter from J. M. Taylor, NRC, to S. A. White, TVA, " Report Nos. 50-327/86-38 and 50-328/86-38," (09/15/86) bb. Letter from J. M Taylor, NRC, to S. A. White, TVA, " Report Nos. 50-327/86-45 and 50-328/86-45," (10/31/86) cc. Letter from M. J. Salerno, Impell, to H. Jones, TVA, " Design Control Program, External Audit Finding Evaluation,"
(06/19/86) dd. Letter from M. J. Salerno, Impell, To H. Jones, TVA, " Design Control Program, External Audit Finding Evaluation,"
( (. (860723 002) (07/10/86) ee. Letter from M. J. Salerno, Impell, to H. Jones, TVA, " Design Control Program External Audit Finding Evaluation," 07/23/86) ff. Letter from L. M. Mill, TVA, to R. Adensam, NRC, " Response to Generic Letter, 83-28," Docket 50-327, 50-328
, (A27 831107 026) (11/07/83) gg. Letter from Dircks, NRC, to TVA, (B45 850919 826), SALP Board Reports, (09/17/85) hh. Letter from Lewis, NRC, to TVA, (NEB 8406/14 612), SALP Board Reports, (06/12/84)
- 11. Letter from Lewis, NRC, to TVA, (A02 830415 001), SALP Board Reports, (04/13/83) jj. Letter from Lewis, NRC, to TVA, (A02 820823 010), SALP Board Report. 08/20/82)
(...
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0
( PAGE 23 0F 26 APPENDII A (Cont'd) kk. NRC letter from J. P. O'Reilly to H. G. Parris, Report Nos.
50-327/83-31 and 50-328/83-31, (02/14/84)
- 11. NRC letter from D. M. Verre111 to H. G. Parris, Report Nos.
50-327/85-23 and 50-328/85-23, (08/02/85) mm. NRC letter from J. A. 01shinski to S. A. White, Report Nos.
50-327/85-46 and 50-328/85-46, (03/05/86) nn. NRC letter from J. A. 01shinski to S. A. White, Report Nos.
50-327/86-06 and 50-328/86-06, (03/05/86) oo. NRC letter from G. G. Zech, NRC, to S. A. White, TVA, Notice of Violation (Inspection Report Nos. 50-327/86-31 and 50-328/86-31), (L44 860820311), (08/12/86) pp. NRC letter from G. G. Zech, NRC, to S. A. White TVA, Notice of Violation (NRC Inspection Report Nos. 50-327/86-42 and 50-328/86-42), (L44 861003356), (09/26/86) qq. SQN-DC-V-11.2, "125-V Vital Battery System," R3, (07/11/86) rr. SQN-DC-V-11.2.1, "125-Volt Fifth Vital Battery System," R2, (07/11/86) ss. SQN-DC-V-11.4.1, " Normal and Emergency AC Auxiliary Power Systems," R2, (07/22/86) tt. SQN-DC-V-11.6, "120-V AC Vital Instrument Power System," R3, (07/11/86) i
( uu. Action Items Originated by the Engineering Assurance Independent Oversight Review Team for the Sequoyah Nuclear Plant Design Baseline and Verification Program - Summary Report, Prepared By: John Von Weisenstein, (10/22/86)
I vv. TVA NSRS Investigation Report T d5-651-SQN, " Electrical Regulations Ignored and Vic1.cte ," (03/10/86) i ww. TVA memo from S. A. Shipr.an *- those Listed, (R. O. Barnett,
, et al), " Professional Society Committees and Industry
! Activities," (B02 860 903 001), (08/25/86) i I
1 l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAM REVISION . YUK 3ER: 0 h PAGE 24 0F 26 APPENDIX A (Cont'd)
- 6. WHAT REGULATIONS. LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
- a. 10CFR50, Appendix B, " Quality Assurance Criteria For Nuclear Power Plants"
- b. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- c. Sequoyah Final Safety Analysis Report (FSAR) Updated, through Amendment 3 (04/86)
- d. TVA Nuclear Engineering Procedures (NEPs):
NEP-2.1, RO " Licensing Support," (07/01/86)
NEP-3.2, R0 " Design Input," (07/01/86)
Project Manual I
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 0 f PAGE 25 0F 26 APPENDII A (Cont'd)
- 7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- a. Discussion, R. Wolters, Bechtel, with C. F. Bowman and D. T. Clift, TVA, in Knoxville, (08/28/86); IOM 438
- b. Discussion, R. Wolters, L. Anderson, Bechtel, with H. Jones and D. T. Clift, TVA, at SQN jobsite, (08/26/86); IOM 438
- c. Telecon, R. Wolters Bechtel, with C. F. Bowman, TVA, in Knoxville (10/22/86); ION 439
- d. Discussion D. Zwicky, B. Wolters, Bechtel, with H. Jones and D. T. Clift, TVA, at Sequoyah jobsite, (10/24/86); IOM 439
- e. Trip Report, visit by R. Wolters to Knoxville, 10/21-10/23/86 and to SQN jobsite 10/24/86; ION 439
- f. RFI # CQN-714 (11/20/86)
- g. TIB No. 092 (08/13/86)
(' _
- h. TTB No. 097 (08/20/86)
- 1. TTB No. 104 (09/03/86)
- j. TTB No. 122 (09/30/86) 2
- k. TIB No. 150 (11/12/86)
- 1. TTB NO. 156 (11/20/86)
- m. Telecon, R. Wolters, Bechtel, with D. T. Clift and D. Wilson, TVA, (12/05/86); ION 440 4
, , , - - - , - - - - - - - - - , , , - - - , - - - - - - - ~ .- - - - . - . - - - - , - - . - - - --
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAN REVISION NUMBER: 0 f PAGE 26 0F 26 CATD LIST The following CATD forms are included as part of this report:
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-} 9. APPROVAL: ECTG PROGRAM MGR.0 &&idr<~d. a4 DATE: 'AS-hZ 7
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- 10. PROPOSED CORRECTIVE ACTION PLAN:
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- 12. CONCURREN.CE: CEG-H: DATE:
3r SRP: DATE:
ECTG PROGRAM MGR: DATE:
VERIFICATION AND CLOSEOUT i
! 13. APPr .ed correcti.e .etion, n.v. n... v.riri.d .. ..ti r.etority
.l implemented.
i SIGNATURE TITLE DATE i
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