ML20207K680

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Rev 0 to, Stds & Guides:Policy & Practice on Utilization, Adequacy & Completeness
ML20207K680
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 12/18/1986
From: Zwisky D
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K578 List:
References
201.4(B), 201.4(B)-R, 201.4(B)-R00, NUDOCS 8701090484
Download: ML20207K680 (6)
v • d • e


Text

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.4(B)

SPECIAL PROGRAM

! . REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 0

\ NON-RESTART .10STIFICATION

SUMMARY

TITLE: Standards and Guides o Policy and Practice on Utilization o Adequacy and Completeness PAGE 1 0F 2 l REASON FOR REVISION:

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. VSIGNATURE ' DATE REVIEWS

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  1. V SIGNATURE / DATE "N @Whad' r

SIGNATURE ek/w DATE CONCURRENCES -

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8701090484 861222 / /#

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SIGNATURE DATE DATE SIGNATUK*/

APPROVED BY:

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oQ hh j /f-/8-80 N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

  • S Secret ry's signature dentoes SRP concurrences are in files.

,;_ SEQUOYAH NUCLEAR PLANT k

ENGINEERING RELATED EMPLOYEE CONCERNS SPECIAL PROGRAM NON-RESTART JUSTIFICATION

SUMMARY

SUBCATEGORY / ELEMENT 201.4(B)

The issues identified in this element refer to possible programmatic deficiencies in the engineering design process.

The issues address misuse, and lack of use of both industry and TVA engineering standards and guides.

Items in this element are considered to be addressing those non-mandatory industry standards, and non-mandatory TVA engineering standards and guides. Such standards and guides are included as applicable in design output documents.

Procedures place the responsibility for application of these engineering standards and guides on the engineer (i.e., they are used or not as applicable to the design, at the discretion of the engineer).

jj This type of situation, if found to be valid, would represent a

.: programmatic deficiency that must be formally addressed as needed

, improvement in the design process.

However, full implementation of this improvement is not considered to be a requirement for plant restart, because the issues do not present a programmatic problem with specific safety-significance.

Items such as mandatory regulatory guides and mandatory industry standards will be addressed as restart items in element reports 204.4 and 201.3 where they are used in nuclear safety significant design criteria.

ATTACHMENT
List of Issues for Programmatic ELEMENT NO. 201.4(B)

Date: 10/05/86

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0211D - Page 2

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  • SUBCATEGORY 201 - INCORPORATION OF REQUIREKNTS AND COPetITMENTS IN DESIGN 201.4 LIST OF PROGRAPeuTIC ISSUES
  • ELE 8ENT NUMBER _ ,

APPLICABLE EPFLOYEE CONCERNS SQN RESTART - NO DATE: 10/05/86 ELEENT DESCRIPTION Standards and Guides WI-85-100-019 WI-85-100-038 o Policy and Practice on Utilization - IN-86-259-X11 o Adequacy and Completness BNP-QCP-10.35-8-26-2 ELEMENT WHERE RE SPON-

!$5UES ADDRESSED SIBLE GENERAL APPROACH / METHODOLOGY FOR ELE E NT REPORT CONCERN NUMBER (S) 204.4 BW Issues 3 through 6 W1-85-100-038 1. Design / Installation Drawings do not Design / installation drawings always represent design requirements. Review engineering procedures and their 1.

do not always represent or references to guides and standards to determine include design requirements. 2. Design / Installation Drawings do not 204.4 BW which requirements are to be included on the Design guides / standards are always include design requirements. drawings, utilized only when designers want to use them. Design 3. Design Guides and Standards are 201.4 DZ

2. Establish examples of drawings from guides / standards are inadequate only used when desired by Designer. each discipline to be reviewed against design in many areas, and there are requirements, misuses, such as applicable 4. Design Guides and Standards are 201.4 DZ parts are not referenced or inadequate in many areas, Review drawings and evaluate.

3.

excerpted as requirements. CI 201.4 DZ has no further information. 5. Design Guides and Standards are Anonymous concern via letter. misused.

6. Applicable parts of Guides / 201.4 DZ Standards are not referenced or excerpted as requirements on drawings.

Engineering changes TVA standards 201.4 DZ !ssue 1 BNP-QCP-10.35-8-26-2 1.

Engineering can do a job within after the job is complete, perhaps The word standard is interpreted to mean because the completed job did not 1.

their standards, then they " criteria" or design basis, (i.e., a TVA change those standards after meet the original standards. Standard) since an industry standard cannot be the job is complete. changed by TVA.

2. Review appropriate " deviation" reports which
  • - describe cases where standards were violated.
3. E.aluate magnitude of review findings back as far as start of original construction.

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SUBCATEGORY 201 - INCORPORATION OF REQUIREENTS AND C0 Pet! TENTS IN DESIGN '

ELEE NT NUMBER 201.4 LIST OF PROGRAF 9 ETIC ISSUES - ,

APPLICABLE ELEENT DESCRIPTION EpFLOYEE CONCERNS SON RESTART - NO DATE: 10/05/86 Standards and Guides WI-85-100-019 WI-85-100-038 o Policy and Practice on Utilization . IN-86-259-111 o Adequacy and Completness BNP-QCP-10.35-8-26-2 ELEENT bHERE RESPON-CONCERN NUMBER (5) ISSUES ADDRESSED SIBLE GENERAL APPROACH / METHODOLOGY FOR ELEENT REPORT WI-85-100-019 1. Electrical and other Engineering 201.4 02 Issues 1 through 4 ,

Electrical Standards and Standards are treated as guides only, Guides are treated as guides, 1. Review Engineering procedures to determine and are not incorporated in 2. Electrical and other Engineering 201.4 DZ how standards ar.d guides are to applied.

design critcria requirements. Standards are treated as guides only.

Electrical design criteria, 2. Has this issue been identified in prior where it exists, is not 3. Electrical and other Engineering 201.4' DZ evaluations (audits,INPOreport.)?

complete, is vague, and in Standards are not incorporated ir.

general is inadequate. CI Design Criteria. 3. Evaluate if option for use is given to designer.

has no further information.

Anonymous concern via letter. 4 Electrical and other Engineering 201.4 DZ Issues 5 through 8 Guides are not incorporated in Design Criteria. See element report 201.3

5. Electrical and other Engineering 201.3 DZ Design Criteria do not always exist.

! 6. Existing Electrical and other 201.3 DZ

.I Engineering Design Criteria are not

. always complete.

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7. Existing Electrial and other 201.3 DZ Engineering Design Criteria are vague.
8. Existing Electrical and other 201.3 DZ Engineering Design Criteria are.

inadequate.

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SUBCA tGURY 201 - INCORPORATION OF REQUIREMENTS AND COMMITMENTS IN DESIGN OY '

ELEE NT NUMBER 201.4 LIST OF PROGRAledTIC ISSUES .

APPLICABLE ELEMENT DESCRIPTION EMPLOYEE CONCERNS SON RESTART - NO DATE: 10/05/86 Standards and Guides WI-85-100-019 WI-85-100-038 o Policy and Practice on Utilization ,

IN-86-259-X11 o Adequacy and Completness BNP-QCP-10.35-8-26-2

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ELEMENT WHERE RE SPON-CONCERN NUMBER (S) ISSUES ADDRESSED SIBLE GENERAL APPRDACH/ METHODOLOGY FOR ELEMENT REPORT IN-86-259-X11 1. TVA electrical procedures do not 201.4 DZ Issue 1 through 3 If TVA electrical procedures include IEEE standard do not include IEEE standards requirements or their 1. Implications is that concern is related only to requirements or their equivalent, therefore, numerous electrical procedures, however, we will examine equivalent, numerous problems problems can result. broader scope.

can result. Construction Dept. concern. CI has no 2. CI refers to IEEE requirements 213.4 ELEC. 2. Determine if these issues have been identified further information. No in particular. in any other prior review (i.e., QA Audit. INPO follow-up required. findings,etc.).

3. Other TVA Engineering procedures 201.4 DZ do not include industry standards 3. Review Design Baseline and Verification requirements. Program for Sequoyah Plant to see if program will adequately address this issue.
4. Do current procedures cover this issue to prevent recurrence of problem?
5. Coordinate response with Electrical group, element report 213.4 e

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REFERENCE - ECPSI20J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -

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  • FREQUENCY - REQUEST OFFICE OF NUCLEAR PONER RUN TIME - 12:57:19

() ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20104 STANDARDS AND GUIDES

() S GENERIC KEYWORD A H APPL QTC/NSRS P , KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYNORD D

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IN 259-X11 EN 20104 S HBN YYYY 1-85-545-HBN SR IF TVA ELECTRICAL PROCEDURES DO NOT PROCEDURES l T50149 EN 21304 K-FORM INCLUDE IEEE STD. REQUIREMENTS OR TH STANDARDS EIR EQUIVALENT, NUMEROUS PROBLEMS CA ELECTRICAL  !

O N RESULT. CONSTRUCTION DEPT. CONCER GENERAL l N. CI HAS NO ADDITIONAL INFORMATION l

. NO FOLLOH-UP REQUIRED. ,

() QCP10.35-8-262 EN 20104 N BLN YYYY SR ENGINEERING CAN-DO A JOB-HITHIN THEI R STANDARDS, THEN THEY CHANGE THOSE REPORT STANDARDS AFTER THE JOB IS COMPLETE.

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HI 100-019 EN 20103 S HBN YYYY SR ELECTRICAL STANDARDS AND GUIDES ARE STANDARDS T50212 EN 20104 REPORT TREATED AS GUIDES, AND ARE NOT INCOR DESIGN RELATED EN 21303 P0 RATED IN DESIGN CRITERIA REQUIREME ELECTRICAL

() NTS. ELECTRICAL DESIGN CRITERIA, NH ERE IT EXISTS, IS NOT COMPLETE, IS V GENERAL AGUE, AND IN GENERAL IS INADEQUATE.

CI HAS NO FURTHER INFORMATION. ANO O NYMOUS CONCERN VIA LETTER.

HI 100-038 EN 20104 S HBN YYYY SR DESIGN / INSTALLATION DRAMINGS DO NOT DRAHINGS T50213 EN 20106 REPORT ALHAYS REPRESENT OR INCLUDE DESIGN R NONCONFORMANCE

() EN 20404 EQUIREMENTS. DESIGN GUIDES / STANDARD ENGINEERING GENERAL S ARE UTILIZED ONLY HHEN DESIGNERS H ANT TO SUE THEM. DESIGN GUIDES /STAN DARDS ARE INADEQUATE IN MANY AREAS, O AND THERE ARE MISUSES, SUCH AS APPLI CABLE PARTS ARE NOT REFERENCED OR EX CERPTED AS REQUIREMENTS. CI HAS NO FURTHER INFORMATION. ANONYMOUS CONC O ERN VIA LETTER.

4 CONCERNS FOR CATEGORY EN SUBCATEGORY 20104 ._

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