ML20207P573

Rev 1 to Incorporation of Requirements & Commitments in Design,Traceability of Design Requirements

ML20207P573
Person / Time
Site:	Sequoyah
Issue date:	01/06/1987
From:	Zwicky D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207P454	List: ML20207P453 ML20207P468 ML20207P564 ML20207P573 ML20207P578 ML20207P583 ML20207P600 ML20207P604 ML20207P608 ML20207P629 ML20207P641 ML20207P647 ML20207P650 ML20207P653 ML20207P654 ML20207P656
References
201.6, 201.6-R01, 201.6-R1, NUDOCS 8701160258
Download: ML20207P573 (8)

Text

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• TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.6 SPECIAL PROGRAM I REVISION NUMBER: 1 REPORT TYPE: SEQUOYAH ELEMENT NON-RESTART JUSTIFICATION

SUMMARY

TITLE: INCORPORATION OF REQUIREMENTS AND COMITMENTS IN DESIGN Traceability of Design Requirements PAGE 1 0F 2 REASON FOR REVISION:

Revised to incorporate TVA Engineering coments and expanded scope of discussion based on evaluation to date.

i PREPARATION PREPARED BY:

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/-8-f gy, DATE DATE MANAGER OF NUCLEAR POWER ECSPENdG[' CONCURRENCE (FINAL REPORT ONLY) 12/05/86 - 02070

4 SEQUOYAH NUCLEAR PLANT 9

ENGINEERING RELATED EMPLOYEE CONCERNS

-i SPECIAL PROGRAM NON-RESTART JUSTIFICATION

SUMMARY

SUBCATEGORY / ELEMENT 201.6 The issues identified in this element refer to possible programmatic deficiencies having to do with availability and traceability of design input.

The issues are documentation and records related.

The documentation and records requirements stipulated by 10CFR50 Appendix B, and ANSI N45.2.9, are reflected in the appropriate engineering procedures.

The procedures were reviewed and in general were found adequate. These procedures place the responsibility for creation of engineering records on all professional employees of the Office of Engineering.

Investigation to date has revealed that in some cases the issues are valid.

Examples of some missing or inadequate design criteria are addressed in Sequoyah Element Reports 201.3 and 213./Sas restart issues. Examples of some procedural shortcomings are noted in the area of calculations and are addressed in Sequoyah Element Reports 205.1 and 205.2 as restart issues.

These findings then represent programmatic deficiencies that must be, and are being, formally addressed as needed improvements in the design process.

i' The fact that documentation rather than hardware is addressed in this element, provides some latitude in determining when necessary corrective measures should be completed. Also, there are " checks-and- balances," such as inspection and testing, which can ensure that necessary safety aspects are evaluated and corrected, as required, on a case by case basis.

TVA is aware of the need for traceability of design input and has instituted corrective measures at Sequoyah, such as the program for development of design basis documents and the Design Baseline and Verification Program (DBVP).

These programs have both prerestart and postrestart phases. Walkdown/ test ,

data which is compared to the licensing basis criteria as part of the DBVP, should mitigate any conditions adverse to safety.

Items requiring resolution prior to restart are addressed accordingly in the above noted Sequoyah element reports and programs, and are controlled in accordance therewith. Additional program control is attained through Engineering Assurance surveillance.

Completion of the postrestart phases of the above noted Sequoyah programs will provide any other needed programmatic enhancements in the design process relating to design input traceability.

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ATTACHMENT: List of Issues for Programmatic ELEMENT NO. 201. 6( B)

Date: 12/05/86 02070 - Page 2

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SUBCATEGORY 201 - INCORPORATIDN OF REQUIREMENTS AND COMMIIMENTS IN DESIGN ELEMENT NUMBER 201.6 - t lST OF PROGRAMMATIC ISSUES APPLICABLE

[tEMINT DESCR!Pil0N EMPt0VE1 CONCERNS SON RESTART - NO DATE: 12/05/86 Traceability of Design Requirements Wl-85-100-037 Wi-85-100 -043 1-85-128-NPS ELEMENT ,

WHERE RESPON-ISSUES ADORESSED $18tE GENERAL APPROACH /METH000 LOGY FOR EtEMEhT REPORT

[0NCERN NUMBERIS)

I-85-128-NPS 1. Basic desig4 cales not prepared. 205.1 JD issues 5. 6 and 7 An individual from BFN wrote hSRS expressing his Concern 2. Basic design Calcs not documented. 205.1 JD 1. Review management procedures establishing that the control and quality hierarchy of documents, of DE's design effort is 3. Design documents not supported by 205.1 JD inadequate. The CI sent calc's 2. Establish Sequoyah program commiltawnts several roughly written through FSAR and other hierarchy of documents pages detailing and sun- 4. There are no procedures to control 205.2

• JD that define design requirements that govern marizing his evaluation and and maintain calcs current the design of:

conclusion of three uujor - o project systems g

areas: 5. Basic design input is not available 201.6 ] DZ o project structures o project components (1) Design Calculations, 6. Design requirements are not readily 201.6 DZ available 3. Review baseline documents (QA Program Manual, '

(2) NCR's, and FSAR) to determine policy and procedures for

7. Basis of determination of design 201.6 ) DZ development and control of design calculationdL (3) Management Policies. requirements is not readily available M i Note: The issues stated here 8. Scope of engineering required for 204.11 JD tion of design input, including those for:

were developed from a review modifications is not identified o calculations by Bechtel Personnel of the O modifications expurgated interview files 9. .No attempt is uude to identify 204.11 JO for this employee concern. activities for modifications 5. Check engineering procedures for incorpora-tion of traceability requirements.

l 10. Configuration control does not exist 206.1 JL

6. Review Engineering Department and Project procedures that implement the identifled calculations policies for development and control of design calculations. Considered the adequacy of the procedures.

7. Review results of audits (QA, INPO, NRC) to substantiate that design calculations have been performed to support existing design.

8. Review available transcript of NRC investigative interviews to gain additional information regarding the concerns,

g. Review engineering documents against the program requirements to evaluate traceability of design requirements.

10. Review the Design Baseline and verification Program for Sequoyah Plant to determine if the program would adequately address these issues.

Other issues See Element Reports where addressed.

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SUBCATEGORY 201 - INCORPORATION OF REQUIREMENTS AND COMMITMENTS IN DESIGN ELEMENT NUMBER 191 6 LIST OF PROGRAMMATIC ISSUES APPLICABLE ELEMENT DESCRIPTION [MPLOYEE CONCERNS SON RESTART - NO DATE: 12/05/86 Traceability of Design Requirements W1-85-100-037 Wi-85-100-043 I-85-128-NPS ELEMENT WHERE RESPON-CONCERN NUMBERfS) ISSUES ADDRESSED SIBLE GENERAL APPROACH / METHODOLOGY FOR ELEMENT REPORT -

l W1-85-100-037 1. There is a lack of traceability of 201.6 DZ Lack of traceability of design design requirements.

requirements. The standard . Define traceability to mean maintaining records I answer is "it's TVA practice", of engineering documents and revisions from CI has no further information, basic design through installation (i.e.,

Anonymous concern via letter. keep design input and design output records.)

1. Review management procedures establishing hierarchy of documents.

2. Establish Sequoyah program commitments through FSAR and other hierarchy of documents that define design requirements that govern the design of:

o project systems o project structures o project components

3. Review baseline documents (OA Program Manual, FSAR) to determine policy and procedures for

• development and control of design input.

4. Review engineering procedures defining preparation of design input, including those for modifications:

5. Check engineering procedures for incorporation of traceability requirements.

6. Review Engineering Department and Project procedures that implement development and control of design. Considered the adequacy of the procedures.

7. Review available transcript of MRC investigative interviews to gain additional information regarding the concern.

8. Review engineering documents against the program requirements to evaluate traceability of design requirements.

9. Review the Design Baseline l Verification Program for Sequoyah Plant to determine if the program would adequately address the issue.

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.o-f }'  ;*i ELENE~T NUMBER 201.6 ,.

APPLICABLE .

ELEMENT DESCtlPTION EMELQ1EL_ CONCERNS SON RESTART - NO DATE: 12/05/86 Traceability of Design Requirements Wl 100-037 WI-85-100-043 1-85-128-NPS ELEMENT WHERE RESPON-CDNCERN NUMBERfS1 ISSUFS ADDRESSED SiBLE ~ GENERAL APPRGACH/NETH000 LOGY FDR ELEMENT REPORT Wi-85-100-043 .1. Some destga calcs are never prepared 205.1 JD Issue 7 There are problems in design

' Review management procedures establishing calculations. In that some are 2. Some design calcs are inadequate in 205.1 JD 1.

never prepared, some are in- scope hierarchy of documents.

adequate in scope and quality, .

and some are not stored as 3. Some design cales are inadequate in 205.1 JD - 2. Establish Sequoyah program commitments

> quality records. There is quality through FSAR and other. hierarchy of inadequate interface and .

documents that define design requirements.

control of design calculations, 4. Some design calcs are not stored as 205.3 Je

which impacts traceability of quality records 3. Review baseline documents (QA Program

, design requirements. CI has Manual. FSAR) to determine policy and i no further information. 5. There is inadequate control of design 205.2 JD procedures for development and control' Anonymous concern via letter, cales of design Calculations.

6. There is inadequate interf ace 205.2 JO 4. Review engineering procedures defining coordination with design cales preparation of design input, including y

(e.g.. Branch / project) _

those for:

o calculations 1

7. Design requirements traceability 201.6 DZ o modifications impacted by inadequate design cales

5. Check engineering procedures for incorporation i NOTE: In issue 3, define aca11ty as of traceability requirements.

compliance with procedures as

~ opposed to technically error free 6. Review Engineering Department and Project l

! calculations. procedures that implement the identified calculations policies for development and

} control of design calculations. Considered i

I the adequacy of the procedures.

7. Review results of audits (OA. INPO, NRC) to substantiate that design calculations have been performed to support existing design.

! 8. Review available transcript of NRC I investigative interviews to gain additional information regarding the concerns.

g. Review engineering documents against the i

program requirements to evaluate traceability <

of design requirements. t

10. Review the Design Baseline and Licensing Verification Program for Sequoyah Plant to determine if the program would adequately

address the issue.

• i Other issues

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See element reports where addressed.' ,

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TENNESSEE VALLEY AUTHORITY PAGE -

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- ECPS120J-ECPS121C REFERENCE RUN TIME - 15:52:21*

(I FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN DATE - 12/31/84 ,

ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

• e LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY 20106 TRACEABILITY OF DESIGN REQUIREMENTS C S GENERIC KEYNORD A H APPL QTC/NSRS P KEYHORD B SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C CONCERN .

KEYHORD D

(' NUHBER CAT CAT D LOC FLQB REPORT R DESCRIPTION I-85-128-NPS- EN 20106 S BFN YYYY SS AN INDIVIDUAL'FROM BFN HROTE NSRS EX EN 20411 REPORT PRESSING HIS CONCERN THAT THE CONTRO

( EN EN 20501 20502 L AND QUALITY OF DE'S DESIGN EFFORT IS INADEQUATE. THE CI SENT SEVERAL EN 20601 ROUGHLY HRITTEN PAGES DETAILING AND-QA 80303 SUMMARIZING HIS EVALUATION AND CONCL

(,) USION OF THREE MAJOR AREAS: (1) D YYYY SR LACK OF TRACEABILITY OF DESIGN REQUI DESIGN PROCESS HI 100-037 EN 20106 N HBN TRACEABILITY T50213 REPORT REMENTS. THE STANDARD ANSHER IS "IT

'S TVA PRACTICE". CI HAS NO FURTHER ENGINEERING

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INFORMATION. ANONYMOUS CONCERN VIA GENERAL LETTER.

YYYY SR THERE ARE PROBLEMS IN DESIGN CALCULA DESIGN PR3 CESS f". HI 100-043 EN 20106 S HBN

• NONCONFORMANCE T50213 EN 20501 REPORT TIONS. IN THAT SDME ARE NEVER PREPAR ED, SOME ARE INADEQUATE IN SCOPE AND ENGINEERING EN 20502 QUALITY, AND SOME ARE NOT STORED AS REPORTS EN 20503 QUALITY RECORDS. THERE IS INADEQUA

(' TE INTERFACE AND CONTROL OF DESIGN C ALCULATIONS, NHICH IMPACTS TRACEABIL ITY OF DESIGN REGUIREMENTS. CI HAS NO FURTNER INFORMATION. ANONYMOUS C

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ONCERN VIA LETTER.

3 CONCERNS FOR CATEGORY EN SUBCATEGORY 20106 e

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