ML20210P786
| ML20210P786 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/04/1987 |
| From: | Youngblood B Office of Nuclear Reactor Regulation |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8702170022 | |
| Download: ML20210P786 (2) | |
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Mt FEB 0 4.1987 MEMORANDUM.TO:
- R.L. Spessard, Deputy Director
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Division,of Inspection Program 9 gygf FROM:
. B.J. Youngblood, Director PWR Project Directorate #4 Division of PWR Licensing-A
SUBJECT:
- TRANSMITTAL OF JANUARY 20, 1987 LETTER Attached is a copy of. a January 20, 1987 letter from the Tennessee Valley Authority which describes its Division of Nuclear Engineering Design Calculation
- Efforts. - A copy of this letter was inadvertently omitted from my January 29, 1987
. memorandum to you.
- If you have any additional questions please call the Sequoyah Project Manager, Joe Holonich, at X27270.
B.J. Youngblood, Director PWR Project Directorate #4 r
Division of PWR Licensing-A l-
Enclosure:
As stated PRC System PWR #4 Reading uncan BJYoungblood Reading TVAOP (3) S. Richardson AR 5029 HDenton JTay1or BHayes NGrace LSpessard' KBa rr SAConnelly GZech, RII DMuller TNovak
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UNITED STATES I,o NUCLEAR REGULATORY COMMISSION f
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R.L. Spessard, Deputy Director Division of Inspection Prograrr FROM:
B.J. Youngblood, Director PWR Project Directorate #4 Division of PWR Licensing-A
SUBJECT:
TRANSMITTAL OF JAh'UARY 20, 1987 LETTER Attached is a copy of a January 20, 19P7 letter from the Tennessee Vc11cy Authority which describes its Division of Nuclear Engineering Design Calculation Efforts. A copy of this letter was inadvertently onitted from my January 29, 1987 rnernorandum to you.
If you have any additional questions please call the Sequoyah Prcject Panager, Joe Holonich, at X27?70.
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irector PWR Proje et Dire forate 44 Divisj on of PUR Licensing-A
Enclosure:
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 1575 Lookout Place SAN 20 set U. S. Nuclear Regulatory Conunission
. Attn: Document Control Desk Office of Nuclear Reactor Regulation Washington, D. C.
20555 Attention:
Mr. B. J. Youngblood In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 TENNESSEE VALLEY AUTHORITY - DIVISION OF NUCLEAR ENGINEERINC DESIGN CALCULATION EFFORTS Based upon discussions held in November and December 1986 with members of an-NRC inspection team, TVA proposed to meet with NRC to present an overview of the TVA design calculations related efforts. This presentation was offered to NRC in order to describe the interface of these efforts with the Sequoyah Design Baseline and Verification Program (DB&VP) and to provide visibility of the TVA-wide calculations efforts to NRC. On December.15, 1986 TVA representatives met with NRC representatives from the Office of Nuclear Reactor Regulation (NRR) and the Office of Inspection and Enforcement (IE).
This submittal documents and expands upon TVA's presentation at that meeting. to this letter is a written description of the TVA design calculations efforts and the relationship between these efforts and the Sequoyah DB&VP. Attachments 1 and 2 provide illustrations of this relationship.
Subsequent to the December 15, 1986 meeting, the calculations review effort was assessed to consider comments and discussion provided to TVA by the NRC Staff. As a result, it was decided that the definition of i
" essential calculation" should be adjusted for clarity and to ensure applicability to the efforts of each engineering discipline. TVA believes that the revised definition (reflected in this submittal) addresses staff comunents from the December 15, 1986 meeting and provides the necessary clarification for successful completion of this work. The SQN unit 2 l
calculations effort is scheduled to be completed by TVA at the end of January 1987. At that time, essential calculations for SQN unit 2 will have been completed as described in this submittal and/or scheduled in accordance with the restart requirement criteria for remaining work items.
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If you have any questions concerning these efforts, please get in touch with Beth L. Hall, of the SQN Site Licensing Staff, at (615) 870-7459..
Very truly yours, p
TENNESSEE VALLEY AUTHORITY i
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.. U. S. Nuclear Regulatory Commission cc (Enclosures):
U. S. Nuclear Regulatory Commission Region 11 Attn:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. J. Holonich Sequoyah Project Manager U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. G. C. Zech, Director TVA Projects U. S. Nuclear Regulatory Commission Region Il 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant P. O. Box 2000 Soddy Daisy Tennesseo 37319 D
ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY DIVISION OF NUCLEAR ENGINEERING DESIGN CALCULATION EFFORTS TABLE OF CONTENTS I.
Introduction II.
Purpose III. Background IV.
DB&VP Calculation Elements V.
DNE Branch Calculation Efforts A. Mechanical Engineering Branch (MEB)
B. Nuclear Engineering Branch (NED)
C. Civil Engineering Branch (CEB)
D. Electrical Engineering Branch (EEB)
VI.
Relationship of DNE Branch Calculation Efforts with DB&VP VII. Engineering Assurance (EA) Technical Audit VIII. Summary O
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TENNESSEE VALLEY AUTHORITY DIVISION OF NUCLEAR ENGINEERING DESIGN CALCULATION EFFORTS I.
INTRODUCTION Past audit findings by organizations both internal and external to TVA have shown that calculations supporting the design basis for TVA's nuclear power plants have not been adequately documented. To address these findings, the Division of Nuclear Engineering (DNE) initiated calculation related efforts to resolve these previous audit findings and their generic implications. These calculation related activities apply to all four technical branches in DNE.
In addition to the design
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calculation efforts by DNE technical branches, other efforts and programs are underway. The Design Baseline and Verification Program (DB&VP) is one of these efforts which complements the calculation efforts.
These efforts apply to all TVA plants; however, this document focuses on the Sequoyah Nuclear Plant (SQN).
II.
PURPOSE The purposes of the design calculation related efforts are to:
(1)
Identify all calculations that are considered to be essential.*
(2)
Verify the existence of the essential calculations and be able to retrieve them.
(3)
Assure that the essential calculations are technically adequate.
(4)
Establish an effective process that will assure that essential calculations will be maintained current with the plant design.
It is also the purpose of this document to show the relationships between the SQN DB&VP and the DNE calculation efforts.
- Essential calculations are defined in Section V of this document.
III. BACXCROUND Over the past several years, the TVA design control program has been the focus of a number of internal and external reviews. These reviews include audits by TVA's quality assurance organizations, inspections conducted by NRC, and evaluations performed by the Institute of Nuclear Power Operations (INPO). From these reviews, problems were identified regarding calculations needed to support approved designs.
Calculations were identified in these reviews as being missing, incomplete, or not T
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updated. While these weaknesses were initially. defined in the electrical discipline area, subsequent assessment of the condition by TVA management' concluded that a review of design calculations should be conducted by the n
f othergngineering disciplines.
,f' The causes of this situation can be generally attributed to weak i
procedural controls, inadequate training, failure to follow procedures, d'
and inadequate design review..The design aspects of this condition are j ~,
being addressed by TVA through an improved design control process. In addition, each engineering discipline within DNg is perfor1 ming a review to assess the extent of this condition and adequacy of its calculations.
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Further details are provided in Section V of this document.
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, Mi t v)IV.' DB&VP CALCULATION gLgNgNTS
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In order to addren, the calculation elements within the DB&VP, one needs l
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(1) Obtain plant functional configuration via walkdowns/postnodification
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test evaluations.
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l (2) Reestablish design criteria documents.
l (3) Prepare system evaluation reports.
(4) Provide basis for future design control that reconciles the "as-conatructed" plant with the engineering process.
2 (5) Review engineering changes since issuance of the operating license,
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This is being done for all plant modifications made since OL to systems, or portions thereof, required to mitigate FSAR Chapter 15 design basis accidents and,to provide for safe shutdown of the plant.
I The calculation effort associated with supporting the DB&VP includes a f
review to ensure that plant modifications since OL are supported by calculations. The elements of this effort include a verification that proper" calculations exist; verification that the calculation supports the scope of the engineering change; and that deficiencies uncovered are resolved via the TVA Condition Adverse to Quality (CAQ) process. This calculation effort is proceduralized and carried out as part of the j
review ofingineering changes (Procedure SQsP-12).
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The results, thus far, have uncovered deficiencies that calculations are not always retrievable or available and that some calculations are not i
suit.able to support the engineering change.
gngineering Assurance (gA) is providing a technical and progransnatic l
assessment of this effort through independent reviews by the gA Oversight i
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Team. This provides the assurance that the activities are identified, y,/ j tracked, resolved, and implemented as required by the procedures and that t
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DNE BRANCH CALCULATION EFFORTS As stated previously in this document,.each engineering branch within DNE is reviewing its calculations. The separate discipline reviews have the common objectives of identifying essential calculations, verifying the existence of essential calculations, assuring'the technical adequacy of essential calculations, and assuring that essential calculations are current. For the purpose of this review " essential calculations" is defined as calculations which address existing plant systems or features.
whose failure could:
A.
Result in a loss of Reactor Coolant System (RCS)' integrity B.
Result in the loss of ability to place the plant in the e
appropriate shutdown mode, or C.
Result in a release of radioactivity offsite in excess of a significant fraction of the 10 CFR 100 guidelines.
The following TVA procedures are associated with this effort:
NEP CALCULATION RELATED PROCEDURES
'n NEP 1.3 Records Control NEP 3.1 Calculations r
s NEP 6.1 Change Control NEP 9.1 Corrective Action 0
SEOUOYAH PROCEDURES )
i SQEP 12 - Evaluating ECN & FCN Documents SQEP 13 - Transitional Design Change Control SQEP 28 - Evaluating ECNs, Category D FCRs, FCNs, L-DCRs and TACFs not reviewed by Design Baseline and Verification Program SQEP 45 - Control of Design Baseline and Verification Program Action Items i
Additionakdetailsontheeffortsundertaken_by_eachDNEengineering
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branch in this area are discussed below:
A.
MECHANICAL ENGINEERING BRANCH (MEB)
One objective of the mechanical calculation review effort is to have in place a complete set of technically adequate essential mechanical calculations before SQN restart.
The ultimate intent is to maintain this complete set of calculations throughout the operating life of SQN.
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Corrective' action associated with mechanical calculations has been addressed in five basic steps:
1.
Identify all required essential mechanical calculations. This effort was initiated on June 25, 1986, when MEB issued a list of mechanical calculation types necessary to fully document the design basis of mechanical systems.
2.
List all existing mechanical calculations and identify each as either " essential" or " desirable." DNE Procedure NEP-3.1 requires the (Mechanical) Lead Engineer to maintain a calculation log. MEB has this log, and it identifies the essential and desirable calculations.
3.
Verify existence of essential mechanical calculations. On October 7, 1986, MEB issued an initial list of missing essential mechanical calculations to be regenerated.
4.
MEB is also examining all existing essential mechanical calculations to determine if they were properly reviewed and approved. Those which were not will be reviewed and approved before SQN unit 2 restart.
5.
To ensure technical adequacy of essential mechanical calculations for SQN, MEB has randomly selected 55 of approximately 328 existing essential calculations for the purpose of reviewing each for technical adequacy. This sample was randomly drawn from six selected mechanical systems.
These systems were selected because the design responsibility for these systems has passed through several organizations as reorganizations occurred in past years. A branch procedure was written to guide the reviewers in determining if the sampled calculations have (a) adequate, current, and complete design input data; (b) current and complete references; (c) complete and adequate assumptions; (d) an adequate analytical approach; (e) logical and valid conclusions; j
(f) unverified assumptions which can now be verified; and (g) results which remain within the bounds of the current plant design.
The reviewers are all degreed engineers with experience in similar systems on which they are reviewing the calculations. An independent reviewer, experienced in similar systems on which the calculation has been performed, will review and document his agreement with the reviewer's assessment. All independent reviewers are senior engineers as a minimum, hold engineering degrees, are typi< sily registered professional engineers, and have from 8 to 27 years of engineering experience.
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Mechanical calculations found to be outside the beunds of the as-designed configuration will be categorized as " unacceptable." A CAQ will be identified for unacceptable calculations per DNE Procedure NEP-9.1.
Documentation will be avs11able on the sample review results.
Further actions to prevent recurrence are in progress and will continue in.the long term. MEB has revised its branch procedures to be consistent with the division procedure system. Training of mechanical personnel performing calculations has already taken place and refresher courses will be given periodically. procedures already in place require mechanical designers to evaluate all design change proposals to determine if calculated design parameters and related safety margins are affected. When such parameters and margins are affected, the calculations are revised.
B.
NUCLEAR ENGINEERING BRANCH (NEB)
The NEB response to the calculations issue encompassed the overall goals of DNE to establish the list of essential calculations for l
Sequoyah, ensure that these essential calculations exist, ensure that they are up-to-date, and ensure that they are technically adequate. NEB's guidelines for accomplishing this effort were tailored to the discipline specific responsibilities. In addition, no significant deficiencies in calculations have been noted in 1-previous QA audits of NEB.
Specifically, for the nuclear discipline, existing calculations were located and categorized as essential, desirable, file only, or superseded. Approximately 350 existing essential calculations have been identified for SQN in NEB. A procedure and evaluation are currently being developed to identify any missing essential calculations. The existing essential calculations, as determined from the DNE definition of essential, were then compared to the current plant as-designed configuration and reviewed for technical adequacy. This review for technical adequacy was separated into l
two aspects to address specific rress of the branch l
responsibilities. First, the Safety Systems Analysis group initiated a review of all essential calculations in that area.
Approximately 110 calculations have been identified and reviewed.
The remainder of the branch instituted a random sample of 65 essential calculations with no bias c7. calculation vintage or section which performed the calculation. Branch procedures have been issued which specifically govern these calculation reviews.
l NEB has used, primarily, staff-augmented contract personnel from Impell Corporation and Enercon Services to perform the SQN calculations review. This work has been performed directly under the supervision of senior TVA engineers and managers with an approval cycle involving, in general, two levels of NEB management. The experience levels of the engineers performing the reviews range from a minimum of 4-5 years experience to 10+ years experience with the nuclear field. TVA personnel involved in directing the calculation examination and review approvals range from 8 to 20+ years experience in the nuclear field..
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The calculation review effort is tied to the DB&VP through the corrective action process (see discussion in Section VI).
Individual calculation reviews have been documented and will be submitted as a package for archival purposes upon completion of the review effort.
To date, the deficiencies noted in the NEB calculation review efforts have been minimal, in that no errors or omissions requiring plant modifications have been identified. Twenty-seven calculations of approximately.150 reviewed to date have been noted as requiring updating, but without significant impact on the calculation conclusion, and one calculation has been determined as missing. These deficiencies are being processed through the corrective action procedure. The corrective action is underway on these deficiencies. The NEB calculations review effort for SQN unit 2 will be completed before restart.
Actions to prevent recurrence are in progress and will continue in the long term. NEB is revising branch procedures to encompass the essential determination on each issued calculation. NEB will ensure that employees are routinely trained on procedures pertinent
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to calculations.
C.
CIVIL ENGINEERING BRANCH (CEB)
The Civil Engineering Branch has a program that addresses design i
calculations on a generic basis for the civil discipline.
Requirements or features of the program are:
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A master calculations list i
2.
Identification of all essential calculations 3.
Verification of existence of all essential calculations 4.
Technical review of essential calculations t
5.
Categorization of all calculations as essential or desirable 6.
Retrievability/ regeneration of missing essential calculations 7.
Establishment of effective calculations maintenance process Before unit restart, essential calculations are required to be identified, and revised or regenerated, as necessary.
The technical adequacy of the civil discipline's approximately 10,000 calculation packages for SQN has been evaluated by the following methods:
1.
Routine Engineering Support Since October 1983, 7,053 (69 percent) calculation packages have been reviewed.
Since October 1983, 1,221 (12 percent) calculation packages have been revised.
This process has identified 41 calculation deficiencies, of which 28 relate to technical adequacy.,
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Review by Contractors
.o Civil calculations have been reviewed by architect / engineer (A-E) firms such as Black and Veatch, Gilbert-Commonwealth, Impell, and Bechtel. This process has identified deficiencies.
3.
Other External and Internal Reviews Reviews have been performed.by Engineering Assurance (EA)
. personnel, Quality Assurance (QA) personnel, and NRC audits.
This process has identified deficiencies.
Examples of CAQ review findings relate to:
1.
Cable tray supports 2.
Conduit supports 3.
Alternate analysic 4.
Thermal effects un miscellaneous steel structures 5.
Embedded plates All the deficiencies identified have been captured within the CAQ process. This process requires generic reviews', corrective action, and preventive actions. With completion (implementation) of the CAQ process, technical adequacy of the calculations are assured.
In addition, depending on the extent and significance of the CAQs, programs have been developed such'as the cable tray and alternate analysis programs, to define and implement resolution.
Technical reviews of recent calculations indicate significant improvement in the quality of calculations compared to older vintage calculations. Reviews for technical adequacy have been performed by technical supervisors, section supervisors, and technical specialists with several years of experience and technical expertise in the area being evaluated. Reviews and evaluations to establish the technical adequacy of calculations have been or will be documented, and the documentation will be available for inspection.
D.
ELECTRICAL ENGINEERING BRANCH (EEB)
The electrical calculations effort for SQN is as described in TVA's Nuclear performance plan, Volume 2 under " Electrical System Review" (section III, pages 20 through 23).
Basically, this effort involves the identification of the essential calculations and 100-percent review of these calculations, as well as an independent assessment of these calculations for technical adequacy. Each electrical calculation required to support SQN restart has been prepared, checked, reviewed, and approved. The independent verification is performed by the checker who is independent (from a supervisory standpoint) of the preparer, and is typically an engineer / engineering associate with several years of experience.
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O The reviewer performs an overall review to ensure conformance to general design concepts, established format and style, and proper interpretation of codes and standards. This individual is a principal or senior level electrical engineer with several years of
. experience.
The calculations were performed in accordance with NEP 3.1.
A detailed listing of essential calculations is given in policy EEB PM 86-02.
The DB&VP was used, among other things, to:
o Update data bases used in the calculations using nameplate information from the field walkdown.
o Field-verify (as-construct) essential drawings used as input.
o Review all changes since OL to assure that calculations, if required, were performed and are adequate.
These DB&VP efforts were documented under SQN procedure SQEP-12.
Furthermore, corrective actions from the calculations effort and ~
DB&VP have been placed in the TVA CAQ process for evaluation and resolution.
Completion of these efforts will assure technical adequacy of the essential calculations, and continued implementation of the change review for electrical calculations will assure that the calculations are kept current.
In addition, these efforts will provide adequate assurance that the electrical systems will perform l
their intended safety functions and will provide a design basis for SQN unit 2 restart.
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The independent assessment of the electrical calculations by Sargent and Lundy concluded that SQN calculations were typical for SQN vintage of plants. The assessment also identified the need for corrective actions of electrical calculations. This effort has been completed for SQN. The interface with and feedback from the l
DB&VP is in progress. EEB has obtained a calculation software package from an architect / engineer (A/E), and the A/E is presently providing TVA with training in the use and technical applications of this software.
VI.
RELATIONSHIP OF DNE BRANCH CALCULATION EFFORTS WITH DB&VP The relationship of the DNE branch calculation efforts with the DB&VP is depicted on Attachments 1 and 2.
The DNE branch calculation efforts include:
(1) Identification of essential calculations.
(2) Verification that essential calculations exist.
l (3) Review of technical adequacy of essential calculations..
The DB&VP calculation effort verifies that proper calculations exist for the engineering changes being reviewed and that the calculations support the scope of the engineering change. The DB&VP relies on the DNE branch calculation efforts to determine technical adequacy of calculations.
Both of these efforts resolve identified deficiencies through the TVA CAQ process. Both efforts are proceduralized and performed in a controlled manner. Both efforts are being reviewed by Engineering Assurance to provide a technical and programmatic assessment. This provides the assurance that the activities are identified, tracked, resolved, and implemented as required by the procedures and that conclusions and actions taken are acceptable.
It should be noted that the DB&VP calculations which_ support engineering changes may or may not be included in the specific sample chosen by the DNE branch calculation effort. The conclusions drawn from the sample of calculations being reviewed by the DNE branch calculation effort can, however, be applied to all calculations which include calculations that support specific engineering changes.
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VII.
ENGINEERING ASSURANCE (EA) TECHNICAL AUDIT EA has scheduled a technical audit of the DNE calculation review efforts, which is intended to ensure that each DNE engineering branch satisfactorily implements the details of their respective calculation -
review efforts. EA has assembled a team of reviewers, using technical resources from the EA Oversight Review Team presently overseeing the Sequoyah DB&VP activities. This team will verify that the DNE branches have properly implemented their programs and that EA concurs with the conclusions of the branch reviews. The goal of both efforts is to ensure that all essential calculations do exist and that they are technically adequate.
In order to accomplish this, EA will independently review a sample of calculations from each discipline to determine the technical adequacy of the calculations. EA is presently developing an audit plan and detailed review checklists in order to carry out this audit, which will be performed in January 1987. This documentation and the audit results will be available for NRC review.
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VIII.
SUMMARY
TVA has recognized that calculation adequacy issues exist. TVA has been pro-active in resolving the issues in all engineering branches.
DNE has activities underway within the engineering branches in conjunction with the DB&VP which will provide the basis and actions required to resolve the calculation issues.
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Deficiencies identified by TVA will be corrected through the existing TVA corrective action process which ensures specific corrective action is taken, generic implications are considered, and root causes are analyzed.
In the future, to ensure that all essential calculations are developed; that they are technically adequate; and that they are maintained current to support plant designs, DNE has provided training and placed additional controls on how engineering work is done. This includes improved procedures and verification through EA technical audits that the procedures are implemented as intended.
TVA will have the necessary essential calculations which support plant designs, which are technically adequate, and which sre maintained current.
For SQN, those efforts will be completed by January 31, 1987, and/or scheduled in accordance with the restart requirements criteria.
TVA is committed to demonstrate technical adequacy of calculations by conforming to TVA procedures, regulatory requirements, and Industry standards.
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9 D8&VP INTERFACE DNE ECN CA L
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a INTER ACTION BETWEEN DNE C ALCUL ATION EFFORTS AND DB&VP I
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DESIGN BASEl.INE & 1/ERIFl0ATION PROGRAM l
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SUPPORTS SYSTEM 8
IDENTIFY ESSENTIAL CALCS X
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ATTACl4ENT 2 i
ENCLOSURE 2 l.IST OF COMMITMENTS MADE IN ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY - DIVISION OF NUCLEAR ENGINEERING DESIGN CALCULATION EFFORTS
- 1. Complete essential calculations efforts for SQN unit 2 by January 31, 1987, and/or schedule efforts in accordance with restart requirements.
- 2. Complete review and approval of all MEB essential calculations before restart of SQN unit 2.
- 3. Identify and revise or regenerate, as necessary, CEB essential calculations before restart of SQN unit 2.
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- 4. The NEB calculations review effort for SQN unit 2 will be completed before restart.
- 5. The technical audit performed by Engineering Assurance will be completed by January 31, 1987.
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