ML20212H128
| ML20212H128 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/13/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20212G828 | List: |
| References | |
| 213.1-(B), 213.1-(B)-R02, 213.1-(B)-R2, NUDOCS 8701210285 | |
| Download: ML20212H128 (14) | |
Text
. _ - .- -.. . .
. *l
, J "'- TVA EMPLOYEE CONCERNS. REPORT NUMBER: 213.1 (B)
. SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER:- 2
-(--
- TITLE: ELECTRICA
L. PROCEDURE
S
~ Inadequate Management, Control and Status Listing of AC 8 DC Electrical Loads, PAGE 1 0F 12 Including Diesel Generator Margins. .
REASON FOR REVISION:
- 1. Revise to restate problems on the corrective action tracking documents.
i
- 2. Revise to incorporate 'SRP and TAS consnents and to add Section 10, Corrective Action.
i PREPARATION
- PREPARED BY:
.=- Y A. n
~
/ S 97 DATE
, / SIGNATURE REVIEWS r II:t. REVIEW C TT :
- AY1b h l
~
SI ATURE ~ ~ ) / DiiE T {j/ Band if D/' ' ' SIGNATURE bby DATE
' CONCURRENCES j rk b. mk ll8/ f)
CEG-H: N / ~i
- . SRP:dd , /dhr*If /'/3 87 SIGNATURE DATE SIGNATU *g DATE i
t APPROVED BY:
f)/) //) l-0-$l Nh DATE ECSP MANAtER DATE MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY) i "' 91g ature denotes SRP concurrences are in files.
8701210285 7d1
, . PDR ADOCK 05000327 i, , R_ . , _ _ ., ___ ___ . _. P D R _,_ _ _ , _ _ _ _ _ , _ _ _ _
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
( PAGE 2 0F 12
- 1. CHARACTERIZATION OF ISSUE (S):
Concerns Issues WI-85-100-010 XX-85-122-030, 031, 032 a. Ac and dc electrical loads and
" Inadequate management, control margins, including diesel generators, and status listing of ac & dc are not kept current as changes electrical loads, including (additions or deletions of loads) diesel generator loads. This occur.
involves inadequate control of, or preparation of, calculations b. Electrical calculations for loads for loads, and inadequate manage- are inadequately prepared and ment and control of load margins, controlled.
includino electrical loads and mechanical loads (heat, BHP, etc.) that translate into elec-trical loads." The following issue from this concern is addressed in other reports:
i There appears to be programmatic
(' inadequacy with regard to preparation and control of calculations (addressed in SQN Element Reports 205.1 and 205.2).
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X N0 o Identified by 00A Date 08'/01/84 Office of Quality Assurance, Audit Deviation Report D A-84-0006 o Identified by G/C Date 03/03/86 Gilbert / Commonwealth Report No. 2614, Final Report " Technical Review of SON Modifications" o Identified by NSRS Date 03/06/86
(
! USRS Report I:0. 1-8E-l ?2-SQli, " Diesel Cenerator Loads" 00260 (01/02/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 12
'(
o Identified by NSRS Date 04/07/86 NSRS Report No. I-85-992-SQN, " Control of Ac and Dc Electrical Loads" o Identified by S&L Date 04/08/86 Sargent & Lundy Report, " Electrical Calculation Review Program"
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.
Electrical calculations in general with specific reference to load calculations.
l
('.
4 INTERVIEW FILES REVIEWED:
Files XX-85-122 and WI-85-100 were reviewed, and no additional unreviewed information for Sequoyah was found for the concern in this report.
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
i 002fD (01/02/87)
. l
- 1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL. PROGRAM REVISION NUMBER: 2
', PAGE 4 0F 12 EVALUATION PROCESS:
P.
- a. Reviewed the existing reports (e.g., I-85-992-SQN) for findings to assess the condition of SQN calculations and reviewed previous management, control, and status listings of calculations.
- b. Reviewed the recomendations in existing reports for evaluators' concurrence.
- c. Reviewed established TVA precedures for performing hnd updating electrical calculations to determine if procedures are adequate, g
- d. Reviewed available transcripts of NRC investigative interviews for additional information on the concerns.
- e. Established that electrical load lists exist and are being maintained / controlled in an appropriate raanner.
(l '_
- f. Reviewed existing TVA Construction, QA/QC, Operations, and Material Control reports for the TVA Employee Concerns Special Program for applicability to the concerns discussed in this report.
- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
08/01/84: Office of Quality Assurance issues audit deviation report citing a lack of design control with regard to calculations.
11/85: Employee concerns received by TVA for BFN, SQk, WBN, and BLN 03/03/86: Gilbert / Commonwealth issues Final Report on SQN modifications citing a lack of formal documentation of design changes.
03/06/86: NSRS issues Investigative Report on diesel generator loads 002fD (01/02/87)
, t TVA EMPLOYEE CONCERNS REPORT NtMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NIMBER: 2 PAGE 5 0F 12 04/07/86: NSRS issues report further documenting this lack of design control and determines it to be generic to DNE.
04/08/86: Sargent & Lundy issues results of their review concluding most calculations were either informally prepared or not maintained 10/85: TVA retains Sargent & Lundy to a'ssist in Electrical Calculation Program Discussion:
The issues raised by these concerns regarding inadequacy of preparation, management, and control of calculations for electrical loads have been identified and addressed in several TVA internal audits and investigations, as well as in external evaluations and review programs. These programs have substantiated the concern for Sequoyah Nuclear Plant (SQN), and, in addition, it has been determined that the concern is generic to all TVA plants. The
( safety implication of the concern is the potential inability of safety-related. equipment to supply the electrical loads and, therefore, to perform its intended safety function.
The first systematic analysis of these issues was included in NSRS Report I-85-132-SQN ( App. A, 5.d; 03/06/86) which referenced Office l of Quality Assurance (00A) Audit Deviation Report 051-A-84-0006
( App. A, 5.u; 08/01/84). The deviation report found that there is "no adequate system to ensure that calculations and studies performed by the APS section of the Electrical Engineering Branch (EEB) are updated and revised to support design changes." NSRS Report I-85-992-SON ( App. A, 5.b; 04/07/86) further documented discrepancies in the design control area and concluded that this is generic to the Division of Nuclear Engineering (DNE).
External reviews were performed-by Gilbert / Commonwealth (G/C) and by Sargent & Lundy (S&L). The G/C report (App. A, 5.e; 03/03/86) highlighted a lack of formal documentation of design change evaluation (ECN review). The Sal report indicated that many electrical calculations were not formally prepared nor retrievable, but concluded that in this respect, "Sequoyah is, in general, typical of industry practice in the time frame involved." In addition, the S8L final report ( App. A, 5.g; 04/08/86) identified a minimum set of calculations required to support the design bases and also identified which of these calculations should be conpleted or updated prior to restart.
k 00200 (01/02/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 0F 12 In response to the-S&L report and recommendations, TVA committed to adopt the S&L list of minimum set of calculations and committed to complete the required calculations prior to restart ( App. A, 5.m; 05/08/86). This was further confirmed by teleconference ( App. A, 7.a; 09/05/86) and by a review of the Minimum Set of Calculations Status for SQH ( App. A, 5.p). Additionally, TVA has committed to a -
long-term calculation program to complete the additional calculations required to document the design basis but are not required for restart.
To ensure proper preparation and control (i.e., review, approval, revision, tracking, etc.), all calculations will be performed in accordance with the new Nuclear Engineering Procedure (NEP) 3.1, "Calcul ations. " Similarly, NEP 6.1, " Change Control," establishes procedures for the review of change-authorizing documents (ECNs, FCRs) for impact on drawings, calculations, and other design documents to ensure all are updated to reflect the change.
Requirements of the NEPs-have been incorporated into the SQN program through revisions to existing, and preparation of new, Sequoyah Engineering Procedures (SQEPs). These procedures were
/ reviewed by the evaluator and found to adequately cover the t requirements for preparing, maintaining, and controlling electrical calculations. Additionally, TVA has engaged S&L (10/85) to provide technical and managerial support for the electrical calculation program. This support will include S&L's providing procedures, software, a QC/QA documentation program, and the training of TVA personnel in the performance and maintenance of calculations.
Findings
- a. Issue "a," regarding ac and dc electrical loads and margins, has been substantiated as a valid concern. However, actions have been taken by TVA to correct the problem.
Specific to the diesel generators, calculation SQN-E3-002 has been issued to document the diesel generator loads (this is covered in more detail in Sequoyah Element Report 243.0).
TVA has committed to and is in the process of updating the ac and de load lists for all electrical systems. The load lists for each system will be incorporated as part of the calculation for the respective system. Updating loads contained in calculations required for restart will be completed prior to Unit 2 restart, and the remaining will be completed as part of the long-term calculation program.
Additionally, the evaluation team concurs with the list of
\ required calculations identified by S&L and adopted by TVA.
00200 (01/02/87)
~
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 12
- b. Issue "b," relating to inadequate preparation and control of electrical load calculations, was also verified to be a valid concern. However, review of TVA's commitments and corrective--
actions and of the new procedures (NEPs and SQEPs) indicates that SON has an adequate program for preparation and control of calculations, and for their revision.
Conclusion:
The concerned individual raises valid issues stemming from inadequacies in the previous design process control system. The problems associated with these issues have, however, been recognized by TVA and corrective actions initiated. Acceptable completion of the currently established corrective actions -- the completion of the minimum required set of electrical calculations prior to Unit 2 restart, completion of the long-term calculation program (post restart), and adherence to the new procedures -- will correct the problems and will prevent recurrence in the future.
t
( 10. CORRECTIVE ACTION:
Corrective Action Plans (CAPS) have been generated by TVA as identified by TCAB-014 dated 11/26/66 and TCAB-041 dated 12/24/86
( App. A, 5.u) . The CAPS respond to Corrective Action Tracking Docurents (CATDs) 213.01 SQN 01 and 213.01 SQN 02 and commit to these actions:
- a. Completion of electrica! ;alculations required for restart of SQN, in accordance with NEP 3.1, from minimum set of electrical calculations.
- b. Maintenance of SON electrical calculations in accordance with SQEP 9.
- c. Performance of the remaining calculations in long-term electrical calculations program (Sargent & Lundy program).
- d. Revision of SCR SQNEEB8527 to include reference to CATD 213.01 5QN 01 and 02.
Actions "a" and "d" are to be completed prior to Unit 2 restart; action "b" is to be a continuous effort; and action "c" is to be initiated but not completed prior to Unit 2 restart.
( ,
00200 (01/02/87)
TVA EMPLOYEE CONCERNS REPORT NtMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NtMBER: 2.
PAGE 8 0F 12
(
Action "a" directly responds to CATD 213.01 SQN 02 which had the following problem description: " Electrical calculations to support and document the design basis were inadequately prepared or are unretrievable. The required minimum set of electrical calculations has been identified, but not yet completed." This action is an acceptable solution to this problem, as it provides for the completion of the required calculations for Unit 2 restart from the minimum set of electrical calculations, in accordance with established procedures and prior to Unit 2 restart.
Action "b" of the CAP is intended to assure the future adequacy of maintenance of calculations thereby preventing the recurrence of the maintenance problem as identified in both CATDs. If continuously carried out (as stated in CAP), this action should have its intended effect.
Action "c" addresses the problem described in CATD 213.01 SQN 01
" Electrical calculations have not been maintained in a manner sufficient to document current plant configuration. An established long-term electrical calculation program to update and adequately j
control electrical calculations is in progress but has not been i'
completed." The action is a commitment to complete all of the remaining electrical calculations in the long-term program (S&L program) by 12/31/88. This conritment resolves the described problem.
Finally, action "d" is an appropriate action designed to close the documentation loop and, thereby, to maintain adequate (uality Assurance Records. ,
4 002fD (01/02/87)
L
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
_ PAGE 9 0F 12
(-
APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Revised Sequoyah Nuclear Performance Plan, Volume 11, Rev.1.
- b. NSRS Final Report I-85-992-SQN, (04/07/86)
- c. NSRS Interim Report I-85-992-SQN, " Control of Ac and Dc Electrical Loads," (03/17/86)
- d. NSRS Report No. I-85-132-SQN, " Diesel Generator Loads,"
(03/06/86)
- e. Gilbert / Commonwealth Report No. 2614, Final Report " Technical Review of SQN SNP Modifications for TVA," (03/03/66)
- f. Design Baseline and Verification Program, Sequoyah Nuclear Plant, Revision 0, (05/01/86)
- g. Sargent and Lundy Final Report "Snquoyah Nuclear Plant,
(' Nuclear Plant Electrical Calculation Program Assessment,"
(04/08/86)
- h. Sequoyah Engineering Procedures 11 - Rev. 4, " Procedure for
- Evaluating Engineering Change Notice and Field Change Notice Documents," (08/18/86)
- 1. Sequoyah Engineering Procedures 12 - Rev. 2, " Procedure for Evaluating Engineering Change Notice and Field Change Notice Documents," (07/23/86)
- j. Sequoyah Engineering Procedures 13 - Rev. O, " Procedure for Transitional Design Change Control," (07/25/86)
- k. Sequoyah Engineering Procedures 15 - Rev. O, " Procedure for DNE Interface with Change Control Board (CCB)," (05/15/86)
- 1. Nuclear Engineering Procedures (NEPs):
3.1 R0 " Calculation," (07/01/86) 6.1 R0 " Change Control," (07/01/86)
- m. TVA memo from W. S. Raughley to Those Listed, (B05 860508 902), " Policy Memorandum PM 86 02 (EEB) -
Electrical Calculations" (05/08/86) 0026D (01/02/87)
. r.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
( PAGE 10 0F 12 APPENDIX A (cont'd)
- n. TVA memo from J. A. Raulston to J. A. Kirkeba, (B45 860619 252), " Design Calculations," (06/19/86)
- o. TVA memo from W. C. Drotleff to Those Listed, (B05 860410 008), " Transition from OEPs to NEPs," (04/14/86)
- p. Minimum Set of Electrical Calculations Status
- q. TVA letter from W. S. Raughley to Carmen Chiappetta of S&L,
" Electrical Calculation -Program," (05/30/86)
- r. TVA memo from J. P. Fenton to J. Q. Webber, (B43 860827 901),
"Sargent & Lundy Engineers Proposed Services for Electrical Calculations Program"
- s. Letter from B. J. Youngblood, NRC, to S. A. White, TVA, (05/25/86), with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First r Tennessee Bank Building in Knoxville, TN
\
- t. All documents listed in section 6.
- u. Office of Quality Assurance, Audit Deviation Report D-51-A-84-0006, (08/01/84)
- v. Corrective Action Plans transmitted by TCAB-014 (11/26/86) and TCAB-041 (12/24/86)
- w. Sequoyah Engineering Procedure 9 - unissued Rev. O, " Review Plan for Electrical Changes," (12/09/86)
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
- a. 10CFR Part 50, Appendix B (June 26, 1971)
Criterion III " Design Control" Criterion V " Instructions, Procedures and Drawings"
- b. Regulatory Guide 1.64, "Cuality Assurance Requirements for the Design of Nuclear Power Plants"
- c. ANSI N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants" 00?fD (01/02/27)
.- TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
( PAGE'11 0F 12 APPENDIX A (cont'd)
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- a. Telecon I. Don-Doncow, T. Sarver, Bechtel, to P. Nesbitt, J. Hutson, H. Frederick, TVA, (09/05/86), IOM #249
- b. Telecon I. Don-Doncow, J. Wheeler, R. Principe, T. Sarver, Bechtel, to P. Nesbitt, T. Shea, TVA, (09/16/86)
- c. Telecon I. Don-Doncow, T. Sarver, Bechtel, to P. Nesbitt, J.
Ibtson, TVA, (12/12/86) 00260 (01/07/87)
,.~- TVA EMPLOYEE CONCERNS REPORT NLMBER: 213.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2
- _ PAGE 12 0F 12 CATD LIST The following CATDs identify and provide corrective actions for the findings -included in this report
213.01 SON 01 (11/21/86) (CAP revised 12/18/86) 212.01 SQN 02 (11/21/86) (CAP revised 12/18/86)
\.
00260 (01/02/87)
'e
~
g Ji Ill REFERENCE - ECPS120J-ECPS12IC TENNESSEE VALLEY AUTHORITY PAGE -
77 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME -- 12:57:19 I ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 21301 INADEQUATE MANAGEMENT, CONTROL AND STATUS I S GENERIC KEYHORD A H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYNORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D 3
HI -8S-100-010 EN 21301 S HBN YYYY SR INADEQUATE MANAGEMENT, CONTROL AND S NONCONFORMANCE T50211 EN 24300 REPORT TATUS LISTING OF A.C. AND D.C. ELECT CORRECTIVE ACTION RICAL LOADS, INCLUDING DIESEL GENERA ELECTRICAL-s' TOR LOADS. THIS INVOLVES INADEQUATE GENERAL CONTROL OF OR PREPARATION OF CALCUL ATIONS FOR LOADS, AND INADEQUATE MAN AGEMENT AND CONTROL OF LOAD MARGINS,
) INCLUDING ELECTRICAL LOADS AND MECH ANICAL LOADS CHEAT, BHP, ETC) THAT T RANSLATE INTO ELECTRICAL LOADS. CI HAS NO FURTHER INFORMATION. ANONYM 0
' US CONCERN VIA LETTER.
XX I22-030 EN 21301 S SQN YYYY I-85-992-SQN SS SEQUOYAH: INADEQUATE MANAGEMENT, CON NONCONFORMANCE T50215 EN 24300 K-FORM TROL AND STATUS LISTING OF A.C. AND CORRECTIVE ACTION:
D.C. ELECTRICAL LOADS, INCLUDING DIE ELECTRICAL SEL GENERATOR LOADS. THIS INVOLVES GENERAL INADEQUATE CONTROL OF OR PREPARATION OF CALCULATIONS FOR LOADS, AND INAD EQUATE MANAGEMENT AND CONTROL OF LOA D MARGINS, INCLUDING ELECTRICAL LOAD S AND MECHANICAL LOADS (HEAT, BHP, E TC) THAT TRANSLATE INTO ELECTRICAL L DADS. CI HAS NO FURTHER INFORMATION
, ANONYMOUS CONCERN VIA LETTER.
XX 122-031 EN 21301 S BLN YYYY I-85-977-BLN SR BELLEFONTE: INADEQUATE MANAGEMENT, C- NONCONFORMANCE T50215 EN 24300 K-FORM ONTROL AND STATUS LISTING OF A.C. AN CORRECTIVE ACTION D D.C. ELECTRICAL LOADS, INCLUDING D ELECTRICAL IESEL GENERATOR LOADS. THIS INVOLVE GENERAL S INADEQUATE CONTROL OF OR PREPARATI ON OF CALCULATIONS FOR LOADS, AND IN ADEQUATE MANAGEMENT AND CONTROL OF L DAD MARGINS, INCLUDING ELECTRICAL LO ADS AND MECHANICAL LOADS (HEAT, BHP, ETC) THAT TRANSLATE INTO ELECTRICAL LOADS. CI HAS NO FURTHER INFORMATI ON. ANONYMOUS CONCERN VIA LETTER.
T
. ,- , :w-. _
-n g-~
til REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -
78 FREQUENCY - REQUEST
) CHP - ISSS - RHM OFFICE OF NUCLEAR P0HER EMPLOYEE CONCERN PROGRAM SYSTEM CECPS)
RUN TIME - 12:57:19 RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATECORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 21301 INADEQUATE MANAGEMENT, CONTROL AND STATUS l S GENERIC KEYWORD A H APPL QTC/NSRS P KEYNORD B CONCERN SUB R PLT BBSH INVESTIGATION S CoriCERN KEYNORD C
) NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D "
XX 122-032 EN 21301 S BFN YYYY I-85-978-BFN SR BROWN'S FERRY: INADEQUATE MANAGEMENT NONCONFORMANCE T50215 EN 24300 K-FORM , CONTROL AND STATUS LISTING OF A.C. CORRECTIVE ACTION
)
AND D.C. ELECTRICAL LOADS, INCLUDIN ELECTRICAL G DIESEL GEhERATOR LOADS. THIS INVQ GENERAL LVES INADEQUATE CONTROL OF OR PREPAR ATION OF CALCULATIONS FOR LDADS, AND
' INADEQUATE MANAGMENT AND CONTROL OF LOAD MARGINS, INCLUDING ELECTRICAL LOADS AND MECHANICAL LOADS (HEAT, BH P, ETC) THAT TRA!4 SLATE INTO ELECTRIC
) AL LOADS. CI HAS NO FURTHER INFORMA TION. ANONYMOUS CONCERN VIA LETTER.
4 CONCERHS FOR CATEGORY EN SUBCATEGORY 21301
)
)
m
,