ML20212J521

Rev 3 to Employee Concerns Special Program Rept 205.1(B), Control of Design Calculations,Calculation Preparation Requirements Policy & Practice Scope & Stds

ML20212J521
Person / Time
Site:	Sequoyah
Issue date:	01/14/1987
From:	Clift D, Dowd J, Jordan A TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20212J485	List: ML20212J480 ML20212J521 ML20212J545 ML20212J590 ML20212J627
References
205.1(B), 205.1(B)-R03, 205.1(B)-R3, NUDOCS 8701280220
Download: ML20212J521 (23)

Text

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/ , TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.1(B)

SPECIAL PROGRAM

(' REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 3 TITLE: CONTROL 0F DESIGN CALCULATIONS Calculation Preparation Requirements Policy and Practice PAGE 1 0F 22 Scope and Standards REASON FOR REVISION:

1. Revised to incorporate TVA Engineering coments.

2. Revised to incorporate additional TVA Engineering comments.

3. Revised to incorporate SRP/TAS coments, add chronology, section 10 on corrective action, and include CAPS.

PREPARATION PREPARED BY:

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'ECSP MXNAGER~ DATE 7 MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

i , TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.1(B)

SPECIAL PROGRAM REVISION NUMBER: 3

[ PAGE 2 0F 22 1.- CHARACTERIZATION OF ISSUE (S):

Concerns: Issues:

WI-85-100-043 a. Some design calculations are never "There are problems in design prepared.

calculations, in that some are never prepared, some are in-- b. Some design calculations are inadequate adequate in scope and quality, in scope.

and some are not stored as quality records. There is c. Some design calculations are inadequate inadequate interface and in quality.

control of design calculations, which impacts traceability of NOTE: For this element report, in issue design requirements. CI has "c," quality is defined as compli-no further information. ance with procedures as opposed to Anonymous concern via letter."- technically error-free calcula-tions. Technical adequacy is addressed in other elements.

-I-85-128-NPS An individual _from BFN wrote NSRS expressing his concern that the control and quality NOTE: The following issues from these of OE's design effort is concerns are addressed in other reports.

inadequate. The CI sent several roughly written There is inadequate control of design pages detailing and sum- calculations. (This issue addressed marizing his evaluation and in Sequoyah Element Report 205.2) conclusion of three major areas: There is inadequate interface coordination with design calculations (1) Design Calculation (e.g., Branch / Project). (This issue (2)NCRs,and addressed in Sequoyah Element Report (3) Management Policies 205.2)

NOTE: The description of Some design calculations are not I-85-128-NPS included here stored as quality records. (This issue was developed from a review by addressed in Sequoyah Element Report the evaluation team of the 205.3) expurgated interview files for this employee concern. Lack of control of design calculations impacts traceability of design require-ments. (The traceability issue is addressed in Sequoyah Element Report 201.6)

Tiere are no procedures to maintain

(^ calculations current. (This issue addresssed in Sequoyah Element Report 205.2) 0299D(12/23/86)

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PAGE 3 0F 22

2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by NRC, Gilbert / Commonwealth, Inc., Sargent & Lundy Date For dates, see documentation identifiers below.

Documentation Identifiers:

a. NRC I&E Inspection Report Nos. 50-327/86-27 and 50-328/86-27, (04/22/86)

b. Gilbert / Commonwealth Report No. 2614,(03/03/86)

c. Sargent & Lundy Report, (04/08/86)

3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:

I-85-128-NPS refers to a lack of electrical calculations for power systems, cable size, conduit and instrumentation.

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4. INTERVIEW FILES REVIEWED:

Expurgated file for WI-85-100 was reviewed and no additional unreviewed information was found.

Expurgated file for I-85-128-NPS was reviewed and notes were l developed by the evaluation team.

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.

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7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED 10 ELEMENT.

See Appendix A.

8. EVALUATION PROCESS:

a. Reviewed baseline documents to determine policy and procedures for development and control of design calculations.

b. Reviewed Engineering Department and Project procedures that implement the identified calculation policies for development and control of design calculations.

c. Reviewed results of audits (QA, NRC) to substantiate that design calculations have been performed to support existing design.

d. Reviewed available transcripts of NRC Investigative interviews to gain additional information regarding these concerns,

e. Examined results of prior independent verification reviews (e.g., S&L, G/C, etc.) for discussion of validity of concerns.

f. Reviewed the Essential Calculation Program, the Design Basis Program and the Design Baseline and Verification Program for Sequoyah Plant to determine if these programs will adequately address these issues.

9. DISCUSSION, FINDINGS, AND CONCLUSIONS:

Chronology:

Chronology of Calculation Issues:

03/84: Black & Veatch completes review of Watts Bar auxiliary feedwater system. Concerns arise over alternate analysis criteria for seismically supported piping and absence of calculations for power cable ampacities.

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PAGE 5 0F 22 06/84: TVA QA audit No. D51-A-84-0006 identified the failure to update and revise electrical calculations to support design changes. Corrective action included identification of electrical calculations to be revised or voided.

08/84: Duke Power Co. reviewed piping stress analysis and pipe support programs for Watts Bar Unit 2 and Bellefonte Units 1 and 2. Additional emphasis on accurate origination and checking of calculations and drawing recommended in final report.

09/84: Bellefonte Electrical Evaluation (BEE) report identified the lack of electrical calculations for voltage drop, short circuit, etc. Electrical Engineering Branch (EEB) initiates efforts to develop a minimum set of electrical calculations.

10/03/84: EEB committed to QA to provide by 03/01/85 a list for all four plants giving the status of each calculation (that is, whether each calculation is current, needs revising, or needs voiding) and a schedule for revising or voiding calculations.

03/85: A listing of all electrical calculations and studies for SQN was sent by EEB to Quality Management Staff.

06/85: Office of Engineering newly issued Office of Engineering Procedures (OEPs) became effective on June 28,1985. The four volumes of 145 Engineering Design Procedures, which included administrative controls and quality assurance requirements, were replaced by 18 OEPs.

11/85: QMS followup on the corrective action for the 06/84 audit deviations indicates that some SQN electrical calculations have not been updated and that EEB central staff have not been receiving drawing changes in order to review support calculations.

12/07/85: TVA receives concern I-85-100-043 11/26/85: Chief Electrical Engineer commits to completion of the minimum set of electrical calculation required to ensure plant safety prior to unit restart.

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PAGE 6 0F 22 12/11/85: Civil, Mechanical, and Nuclear Chief Engineers are i requested to look at their discipline calculations to determine which, if any, need revising or updating.

01/86: TVA EEB contracted with Sargent & Lundy to perform an independent assessment of the electrical calculation program for each nuclear plant.

01/86: Gilbert / Commonwealth (G/C) undertakes a survey of design changes to SQN main and auxiliary feedwater system from operating license to June 1985 and identifies deficiencies in design calculations.

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02/18/86: TVA receives concern I-85-128-NPS.

03/07/86: TVA Director of Engineering and Technical Services requested the Civil, Mechanical, and Nuclear Branch Chiefs to identify, list, locate, and develop the essential design calculations. required for each nuclear plant, similar to the electrical calculation effort. The issue of design calculations is emphasized as a SQN restart item.

04/22/86: NRC issues inspection report, Nos. 50-327/86-27 and 50-328/86-27, which reviewed G/C's findings and identified the lack of available calculations supporting the original design in some disciplines.

05/08/86: Electrical Engineering Branch Policy Memorandum PH 86 describes branch policy for the identification and listing of essential calculations required to support plant safety systems.

06/25/86: Mechanical Engineering Branch Policy Memorandum MPM 86-04 established branch policy for the identification and listing of essential and desirable mechanical calculations.

07/17/86: The Sequoyah Nuclear Performance Plan, Volume II is submitted to NRC, and describe the Electrical calculation program to develop a minimum set of electrical calculations, t

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PAGE 7 0F 22 09/09/86: Nuclear Engineering Branch issues a procedure for classifying nuclear calculations that are determined to be essential and which must be maintained current throughout plant life.

11/13/86: Sequoyah Civil Discipline issues revision to design calculation policy and master calculation list of essential and desirable civil calculations.

Discussion:

The concerned individuals raised general issues that the preparation, control, and quality of design calculations are inadequate. This report addresses issues "a", "b," and "c";

namely, that some calculations are never prepared, some calculations are inadequate in scope, and some are inadequate in quality. In reviewing these issues, the evaluation team attempted to understand the past and present practices, procedures, and processes used at Sequoyah for generating and controlling design calculations.

A technical review of sample SQN calculations was not done for this report.since it was judged to be outside the scope of the employee concern special program. Rather, the reports and investigations l performed by TVA and outside agencies and a review of calculations for other element reports were used to develop findings and conclusions. In this report, scope as related to a calculation has been interpreted to mean that a calculation does address the essential parameters required by the calculations. Quality refers to the technical aspects of input, procedures, and the correctness of results.

a. In addressing the issues of the lack of and the inadequacy of design calculations, the basic regulatory requirements to which TVA has committed for the Sequoyah Nuclear Plant were first reviewed.

The essential regulations that affect calculations stem from 10CFR50 Appendix B, effective July 21, 1970. The applicable criteria of 10CFR50, Appendix 8 include:

o Criterion III " Design Control," requires measures to be establisted for assuring incorporation of regulatory requiremente and the design basis into specifications, 02990(12/23/86)

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PAGE 8 0F 22 drawings, procedures, and instructions. The design control _ measures must provide for verifying or ctecking the adequacy of design by the use of alternate or

-simplified calculation methods o Criterion V " Instructions, Procedures, and Drawings,"

requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings.

These documents must include acceptance criteria for determining that important activities have been satisfactorily accomplished o Criterion VI " Document Control," requires that measures be established to control the issuance of documents which prescribe all activities affecting quality o Criterion XVII " Quality Assurance Records," requires that sufficient records be maintained to furnish evidence of. activities affecting quality. Records are also required to be identified and retrievable In addition, TVA has committed to NRC Regulatory Guide 1.64, Revision 2 which was issued in June 1976. This Regulatory Guide endorses ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants." Some of the applicable requirements include Section 4.2, which states that design analyses [ calculations] shall be performed in a planned, controlled, and correct manner. Procedures must also include requirements for identifying documents to permit ready reference and retrieval; defining the objective of the analyses; definition of design inputs and their sources; documenting assumptions, and identifying those assumptions that must be verified as the design proceeds; identification of computer calculations, including computer type, code or programming inputs and outputs; and review and approval,

b. A review was made of the applicable engineering department procedures that have governed the preparation and issue of calculations since the initial design of the Sequoyah plant.

Prior to October 1973, design engineering for TVA nuclear plants was performed by the Architectural, Civil, Electrical, and Mechanical engineering branch or discipline groups which worked on several nuclear plants concurrently. The Branches l 0299D(12/23/86)

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PAGE 9 0F 22 provided their engineering personnel with technical direction for the preparation of certain types of calculations through Branch Design Manuals. The Sequoyah nuclear plant Quality Assurance Manual contained procedure SQN-QAP-III-1.2,

" Preparation, Review, and Records of Design Calculations,"

which was first issued on March 8,1970. This procedure placed responsibility for the " orderly making, indexing, and filing of computations..." with the design engineers and supervisors in each design branch. Some detail was provided on how to structure a calculation package, assure adequate legibility and indexing, and the assignment of responsibility for checking,) review and final approval of calculations (App.A,5.mm.

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 four engineering Branches (which has evolved 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 first procedure to control design calculations on a division-wide basis was EN DES-EP 3.03, " Design Calculations," which was issued as Revision 0 on August 22, 1974. EP 3.03 provided a great amount of detail on the preparation, checking, approval, and revision of calculations. Additional guidelines were offered for the microfilming and storage of calculations, changes to calculations, and the checking of vendor calculations.

The Office of Engineering (0E) Management initiated changes to the design control program with the issue of the Engineering Program Directives Manual on June 28, 1985.

These directives replaced the EN DES Engineering Procedures with new procedures (0EPs) governing the engineering design process. The new OEPs reduced or eliminated most of the administrative details previously found in EPs. In place of a stand-alone procedure, with instructions on reviewing, issuing, and revising calculations, the reader of the new 0299D(12/23/86)

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PAGE 10 0F 22 OEP-07, " Calculations," was referred directly to other

-procedures that control these individual activities. OEP-07 abbreviated the thirteen pages of directions found in EP 3.03 into three and a half pages. The end result is a series of single sentences that provide anyone unfamiliar with the process rather minimal direct instruction on how to accomplish a given activity.

Beginning on July 1,1986, Nuclear Engineering Procedures (NEPs) were issued to govern the reorganized Division of Nuclear Engineering (DNE) design engineering activities.

Calculations were covered in NEP-3.1, " Calculations," which closely resembled the content, format, and brevity of OEP-07 issued a year earlier. This procedure required the active

. use of five referenced NEPs for full understanding of how to verify, issue and revise TVA design or, vendor calculations.

The earlier EP3.03 provided guidance on the indexing, binding and storage of calculations. However, this effort of pulling together calculations in an orderly, systematic manner was left optional for the project manager or branch chiefs.

Also, no mention was made in EP 3.03 of a calculation log to record new calculations and control revisions. The June 28, 1985 issue of 0EP-07 first provided for such a log.

A January 15, 1986 revision to OEP-07 identified another useful purpose for the calculation log, namely, to track those calculations containing assumptions that require later reevaluation and verification.

The OEPs and the current NEPs are silent on filing, retention, and microfilming of calculations. In addition, present procedures do not provide sufficient detail regarding organizational responsibility for calculation preparation and revision (project versus branch) and design interfaces which would ensure a more effective calculation control program.

Past procedural guidelines on computer calculations (EP 3.23) and human factors (EP 3.36), for example, are not retained in the new NEPs.

In summary, the three different sets of engineering department procedures (EPs, OEPs and NEPs) addressed the letter of the applicable regulatory requirements. That is, they reference such re Jirements as Checking, review, approval, issue, revision, and retention of calculations in a generic, non-specific manner. The deficiencies described 02990 (12/23/86)

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PAGE 11 0F 22 below related to the availability and quality of calculations, however, suggest that design calculation procedures have not been definitive or complete enough to assure that there is an effective program for calculation

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t control.

< c. A review was made of audits (QA, NRC) and independent verification reviews (G/C, S&L) to substantiate that design j' calculations ~have been performed to support existing design.

TVA had two surveys of the SQN design control program performed by Gilbert-Commonwealth (G/C). The first survey covered the program activities af ter June 1985. The second survey covered program activities from operating license to June 1985 ( App. A, 5.b). This second survey had extensive i

, NRC involvement and resulted in a special inspection by NRC of G/C's final report (App. A, 5.e).

In addition, TVA surveyed the Sequoyah design control program in a review of unimplemented and partially implemented ECNs issued against three plant systems. Both this survey and the results of the G/C inspection are documented in NRC I&E i Inspection Reports 50-327/86-27 and 50-328/86-27

(App. A, 5.a).

I The second G/C review team identified 19 technical issues and 18 observations as a result of changes pertaining to the main and auxiliary feedwater systems. Seven technical issues and oneobservationwererelatedtocalculations(App.A,5.a).

A general conclusion of the NRC inspection of the second G/C

review and the TVA survey was that there was a lack of  ;

j available calculations supporting the original design in some disciplines.

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. A significant deficiency associated with electrical calculations for Sequoyah was confirmed in November 1985 (App.A,5.1). Electrical calculations were identified as l' not properly documented and controlled, and those that were

> documented were not kept up to date. This type of deficiency was first identified to TVA in an Institute of Nuclear Power

. Operations (INPO) evaluation at Bellefonte and Watts Bar Nuclear Plants ( App. A, 5 9 and 5.h). In January 1986, TVA l

contracted with Sargent and Lundy Engineers (S/L) to perform an independent assessment of TVA's program to identify the J

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PAGE 12 0F 22 minimum set of electrical calculations required both for restart and to support the original plant design basis. The S/L report concluded that while TVA has all or portions of many of the calculations required to support restart currently up to date, the majority of calculations necessary to fully document the design basis of the plant ". . . were prepared informally by TVA during the design period and were not maintained in a manner, as required by today's standards, that would allow easy retrieval over the life to the plant."

(App. A, 5.d)

d. TVA programs which address calculations issues directly or indirectly were reviewed.

In response to TVA QA audits, INP0 evaluations, NRC inspections, and the Watts Bar Employee Concern Program, TVA management initiated an essential calculation program. The goal of this program was to identify those calculations required to support safety systems used for safe shutdown (essential calculations), and other calculations appropriate for plant reliability, availability and economic operation (desirablecalculations). The essential calculation program was (EEB) atand firstfour mandated nuclear for the Electrical projects in September Engineering 1984. (Branch This program was initially referred to as the minimum calculation setbyEEB.) In response to QA Audit Report D51-A-84-0006, the electrical discipline committed to list all current applicable calculations and studies, and to update or void these calculations, as required by March 1,1985 (App. A, 5.qq). While some lists of required calculations were completed by March 1985, there did not appear to be any clear definition of whether the project or the staff electrical groups would actually be responsible for actually revi d ng and updating these calculations. This issue was finaliy resolved in November 1985 and a commitment made to complete the SQN essential electrical calculations program prior to restart ( App. A, 5.rr) .

The other Branch chiefs were requested in December 1985 to review the generic applicability of the electrical calculation problem to their discipline (App. A, 5.nn). In March 1986, the Director of Engineering Technical Services extended this requirement to the Civil, Mechanical and 02990(12/23/86)

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SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 13 0F 22 Nuclear Branches, where following development of lists, essential calculations for each plant were to be located and reviewed; updated or superseded; and if not retrievable, they were to be generated. For Sequoyah, this program plan was judged to be a plant restart requirement (App. A, 5.k).

At the time this element report was prepared, the Electrical and Mechanical disciplines were in the final stages of completing the preparation and review of essential calculations required for restart. The nuclear discipline had completed procedures for the classification and review of essential calculations, and completed a detailed review of some 260 calculations issued by the Safety Analysis Group. A sampling program was under development for the Nuclear Analysis and Operations Support groups' calculations. The Civil discipline, however, has focused restart calculation efforts on verification that calculations exist to support SQN plant safety system modifications made af ter OL in June 1981, and all calculations necessary to support ongoing restart ECNs on the Sequoyah activities list. The remainder of the identified essential calculations will be determined to be pre-restart or post-restart essential calculations.

This selection will be made based on establishea criteria and documented engineering judgment and will be completed prior to restart (App. A, 5.00, 7.f).

In April 1986, a Design Basis Program was approved in a memo from the Manager of Engineering (App. A, 5.1). The program was developed in an effort to address the issues of a lack of design criteria for each of the nuclear plants. The program centered around the development of a design basis document (DBD) that compiles all commitments for each plant contained in the FSA3, design criteria, NRC commitments, etc.

Essential to each DB0 are those calculations required to support the design. Design basis documents for those systems required to mitigate FSAR Chapter 15 accidents and provide for safe shutdown will be developed prior to restart of Sequoyah 2.

In July 1986, the Sequoyah Nuclear Performance Plan (NPP) was issued to the NRC describing TVA's action program to be implemented as part of the restart effort for SQN2 (App.A,5.1). The NPP, Section lil, described the Design Baseline and Verification Program (DBVP) as a program "to access [ sic] the adequacy of past modification work and correct as required. This program has been designed to address the design control issues by:

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SPECIAL PROGHAM REVISION NUMBER: 3 PAGE 14 0F 22-o Verifying'and establishing the plant configuration i Reconstructing the design basis o Reviewing and evaluating modifications since OL issuance against the design basis o Performing the required tests or modifications developed from this review and evaluation" A key component of the review of ECNs and other change documents was the evaluation of all calculations needed to support engineering changes. The pre-restart DBVP effort focuses, however, on those modifications made to FSAR Chapter 15 safety systems since the operating license was granted in June 1981.

1 In summary, these programs described above address SQN calculation issues. The essential calculation program is the most comprehensive. It asks the questions, "What calculations are required for plant safety and support systems; which ones are needed to ensure performance, reliability and availability? Which of these required calculations do we have; and are they current and up to date?" The Design Basis Program requires calculations to support the design basis documents. These required ,

calculations may overlap those addressed in the essential calculation program. The Design Baseline and Verification Program will require review, prior to restart, of the 4

adequacy of calculations related to safety system modifications made since OL.

Findings:

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a. INPO evaluations at Bellefonte (March 1984) (App. A, 5 9) and

! WattsBar(May1985)(App.A,5.h)firstidentifiedtoTVA

! that some electrical calculations were not available. This discrepancyw)asalsoconfirmedatSequoyahinNovember1985

( App. A, 5.1 where calculations could not be retrieved to support voltage levels, acceptable maximum cable lengths and 4

diesel generator loads. The Sargent & Lundy SQN electrical

calculation program assessment report in April 1986 (App. A, 5.d) also indicated that a large number of

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calculations that TVA may have oerformed were informal or are 1 l

not retrievable or available for review.

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( PAGE 15 0F 22 The lack of calculation documents to support the plant design bases was not limited to the electrical discipline. As part of the essential calculation program, the Sequoyah mechanical group identified missing calculations for a number of plant systems including the main and auxiliary feedwater, chemical cleaning, essential raw cooling water, main' steam, plant air, and steam generator blowdown systems (App. A, 5.m). Also, evaluation team members were advised by TVA that Civil calculations were not available for review for issues related to Sequoyah Elements 215.6, 215.9, 218.4, 220.3, 222.3, 222.5, 222.6.

b. The reports and documents reviewed also identified deficiencies in the scope of some design calculations. The G/C and NRC reviews of Sequoyah plant modifications made to the auxiliary feedwater system since operating license cited TVA failure to systematically address pipe support thermal loads for field routed pipe; and failure to consider torsional shear stress effects on weld design for cable tray supports (App. A, 5.a and 5.b). The Sargent & Lundy report

' indicated deficiencies in the scope of some electrical calculations reviewed including those for cable ampacity and containment electrical penetrations (App. A, 5.d). Also,

evaluation team members confirmed that some calculations were inadequate in scope in reviews for Sequoyah Element Reports 1 215.2, 215.6 and 220.3.

c. Deficiencies related to the quality of design calculations

< (clear statement of purpose, listing of assumptions and indication of unverified assumptions, reasonableness of approach and results, etc.) were documented in both the G/C and S&L reports (App. A, 5.b and 5.d). Examples include the steam generator access platform design, cable tray support loads, short circuit and station battery calculations.

Conclusions The reports and documents reviewed by the evaluation team substantiate that issue "a" is valid; namely, that some design l '

calculations, in particular those that preceded the operating license, are not presently avcilable or retrievable and therefore do not provide support for the Sequoyah design bases. The reports do not necessarily support the conclusion, however, that some

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calculations were never prepared. TVA, like other utilities and

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PAGE 16 0F 22 A/Es involved in the design and construction of nuclear power plants in the '60s and early '70s, followed industry practice of a more informal, less rigorous approach toward documenting design calculations. This distinction does not, however, eliminate the need to have essential calculations required to support the design basis of safety systems.

The documents reviewed also support the validity of issues "b" and "c" regarding the inadequate scope and quality of some design calculations. The majority of reviewed calculations, however, were found to be adequately prepared. In fact, many of the findings regarding TVA design calculations produced years ago are the result of reviewing these calculations using today's more rigorous standards rather than by using those standards and procedures in effect at the time of the actual design process.

The evaluation team has determined that, when completed, the Design Baseline and Verification Program should provide for adequate review of calculations required to support modifications made since OL issuance. Other on going programs at Sequoyah which concern calculations include cable tray support analysis, alternately analyzed piping and supports, and the electrical system review.

The identification of essential calculations by each SQN engineering group, and the review, updating, and/or development of these essential calculations are regarded as basic to meeting regulatory requirements and should be completed prior to restart.

Although the Civil discipline has prepared a master list of essential calculations, only certain classifications of these essential calculations will be reviewed prior to plant restart.

The Civil group has committed to justify, prior to restart, the postponement of the review of the other classifications of essential calculations until after restart.

10. CORRECTIVE ACTION:

TVA has submitted the following corrective action plan (TCAP-027):

a. The Sequoyah Civil discipline is indexing and categorizing calculations in accordance with their action plan. The Civil group is preparing written justification for tiose essential calculations not needed for the restart phase.

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b. All engineering disciplines, are implementing Essential Calculation Programs. Their programs-and the review of calculations that support modifications to safety systems within the pre-restart phase of the Design Baseline and Verification Program will be completed by plant restart.

The evaluation team concurs with this corrective action plan.

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PAGE 18 0F 22 APPENDIX A

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a. Letter from J. M. Taylor, NRC, to S. A. White, TVA, "NRC Reports 50-327/86-27 and 50-328/86-27," [L44 860506 542],

(04/22/86)

b. Gilbert / Commonwealth Report No. 2614: Sequoyah Nuclear Plant Modifications for TVA, (03/03/86)

c. Sequoyah Nuclear Plant - Design Baseline and Verification Program, RO, (05/01/86)

d. Sargent and Lundy Final Report, Sequoyah Nuclear Plant.

Nuclear Plant Electrical Calculation Program Assessment, (04/08/86)

e. Letter from R. Gridley, TVA, to J. Nelson Grace, NRC, "NRC-0IE Region II Inspection 50-327/86-27 and 50-328/86-27 Response to Deficiencies and Unresolved Items,"

[L44 860729 801], (07/28/86)

f. Letter from B. J. Youngblood, NRC, to S. A. White, TVA,

" Transcript of Interview of Dallas R. Hicks," (06/23/86)

I

g. Letter from D. G. Smith, INP0, to J. A. Coffey, TVA, transmitting INPO Evaluation of Bellefonte Construction Project,(06/05/86)

h. Letter from Z. -T. Pate, INPO, to H. G. Parris, TVA, transmitting INP0 Evaluation of the Watts Bar Nuclear Plant Construction Project, (09/19/85)

1. Sequoyah Nuclear Perfonnance Plan Volume II, Final Concurrence Transmitted July 14, 1986 (RIM 5 No. L44 860714 800)

j. Sequoyah Engineering Project (SQEP) Project Manual, R0,Section VII, " Project Specific Requirements (Variances / Expansions),"(09/27/85)

k. TVA memo from Kirkebo to Those Listed (805 860307 006),

" Design Calculations," (03/07/86) l 02990 (12/23/86) l J

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.1(B)

SPECIAL PROGRAM REVISION NUMBER: 3 I PAGE 19 0F 22 APPENDIX A (Cont'd)

1. TVA memo from Drotleff to "Those Listed," (B44 860402 007),

" Design Basis Program for TVA Nuclear Plants," (04/08/86)

m. TVA memo from Key to Chandley, (B44860729012), "Sequoyah Nuclear Plant - Design Calculation Review," (07/29/86)

n. 10CFR50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," Criterion III

o. Regulatory Guide 1.64 (Rev. 2, dated 06/76), " Quality Assurance Requirements for the Design of Nuclear Power Plants"

p. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the '

Design of Nuclear Power Plants"

q. TVATopicalReport,TVA-TR75-1A(Rev.8),"QualityAssurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants' -

r. EN DES-EP-1.14, RIO, " Engineering Records - Retention and Storage," (05/13/83)

s. ENDES-EP-3.03,R8,"DesignCalculations,"(04/24/84)

t. EN DES-EP-3.10, R7, " Design Verification Methodt; and Performance of Design Verification," (04/25/85)

u. EN DES-EP-4.04, R9, "Squadcheck Process," (04/24/84)

v. OEP-06, R0, " Design Input," (04/26/85)

w. OEP-07, R0, " Calculations," (04/26/85)

x. OEP-10, R0, " Review," (04/26/85) 4 y. OEP-11, R0, " Change Control," (04/26/85) i z. OEP-16, R0, " Design Records Control," (04/26/85) aa. NEP-1.3, RO, " Records Control," (07/01/86)

I t

l l

02990(12/23/86) l i

, . TVA EMPLOYEE CONCERNS REPORT NUMBER: 205,1(B)

SPECIAL PROGRAM REVISION NUMBER: 3 I PAGE 20 0F 22 APPENDIX A (Cont'd) bb. NEP-3.1, R0, " Calculations," (07/01/86) cc. NEP-3.2, R0, " Design Input," (07/01/66) dd. NEP-5.1, R0, " Design Output," (07/01/86) ee. NEP-5.2,R0," Review,"(07/01/86) ff. NEP-6.1, RO, " Change Control," (07/01/86) 99 TVAmemofromChandleytoKirkebo,(B44860814014)"SQN-Review of Existing Calculations," (08/14/86) hh. TVAmemofromKeytoChandley,(B44860729012)"SQN-Design Calculation Review," (07/29/86) ii. TVA memo from Raulston to Those Listed, (B45 860909 258)

" Design Calculation Verification," (09/09/86) jj. TVA memo from Barnett to Kirkebo, (B41 860811 013) " Design Calculations," (08/11/86) kk. TVA memo from Johnson to Barnett, (B25 860819 499) "SQN -

Policy Memorandum PM 86-02 (CEB) Civil Discipline Policy for

' LesignCalculations,"(08/19/86)

11. TVA memo from Raughley to Those Listed, (843 860811 903)

" Policy Memorandum PM86-15 (ECB) Electrical Calculations Checklist," (08/06/86) mm. SQh-QAP-III-1.3, (03/08/70) nn. TVA memo from Beasley to Those Listed, (805 851211 001),

" Design Calculation," (12/11/85) oo. TVA memo from Johnson to Hernandez, (B25 861117 304), "SQN -

Implementation of Sequoyah Civil Discipline Calculation Action Plan," (11/13/86) pp. TVA memo from Barnett to Those Listed, (841 860616 011),

" Policy Memorandum PM 86-02 (CEB) - Civil Discipline Policy for Design Calculations," (06/16/86) i I

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l 02990 (12/23/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.l(B)

SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 21 0F 22 APPENDIX A (cont'd) qq. TVA memo from Cooney to Beasley, (ESB 840907003),"Officeof Quality Assurance Audit Report No. D51-A-84-0006," (09/07/84) rr. TVA memo from Chandler to Beasley, (B43 851126 936), " Audit Deviation Report D51-A-84-0006-D01," (11/26/85) ss. TVA memo from Abercrombie to Brown, (503 861210 802)

"SQN-ECTG Element Report 205.01 SQN R2 - Engineering Category - Corrective Action Plan (CAP)," (12/10/86)

6. WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA 7

a. 10CFR50, Appendix B Criterion III " Design Control" Criterion V " Instructions, Procedures, and Drawings" Criterion VI " Document Control" Criterion XVII " Quality Assurance Records"

b. NRC Regulatory Guide 1.64, Revision 2, " Quality Assurance Requirements for the Design of Nuclear Power Plants"

c. ANSI N45.2.ll - 1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants"

d. NQAM, Part IV, Section 2, " Design Services," (12/31/84)

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

a. RFI No. SQN-530, (09/04/86)

! b. RFI No. SQN-533, (09/05/86) l

c. RFI No. SQN-534, (09/08/86) 48

d. RFI No. SQN-569, (09/16/86)

e. Report of meeting in Knoxville and SQN site, August 27-29,1986, BLT-043 (09/16/86)

f. Teleconference between Clift, et al., TVA, and Dowa, et al.,

Bechtel, (IOM #412) (11/17/86)

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l 0299D (12/23/86)

e. ..

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.1(B)

SPECIAL PROGRAM I- REVISION NUMBER: 3 PAGE 22 0F 22 CATD LIST The following CATDs identify and provide corrective actions for the findings included in this report:

205.01 SQN 01 (12/10/86) 205.01 SQN 02 (12/10/86) 0299D(12/23/86)

. - _ _ _ - . . - - . . - . . .- . _ . . - _ . _ _ _ _ _ _ _ ~

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A y '

Ill ..

TENNESSEE VALLEY AUTHORITY PAGE -

60 REFERENCE - ECPS120J-FCPS121C RUN TIME - 12:57:19 FREQUENCY - REQUEST OFFICE OF NUCLEAR P0HER I EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 ONP - ISSS - RHM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20501 CALCULATION PREPARATION REQUIREMENTS l S GENERIC KEYWORD A H APPL QTC/NSRS P KEYHORD B BBSH $ CONCERN -KEYHORD C CONCERN SUB R PLT INVESTIGATION KEYWORD D CAT D LOC FLQB REPORT R DESCRIPTION

) NUMBER CAT 20106 S BFN YYYY SS AN INDIVIDUAL FROM BFN HROTE NSRS EX I-85-128-NPS EN PRESSING HIS CONCERN THAT THE CONTRO EN 20411 REPORT

+ EN 20501 L AND QUALITY OF DE'S DESIGN EFFORT

' EN 20502 IS INADEQUATE. THE CI SENT SEVERAL Cd 20601 ROUGHLY HRITTEN PAGES DETAILING AND 11A 80505 SUMMARIZING HIS EVALUATION AND CONCL USION OF THREE MAJOR AREAS: (1) D

) DESIGN PROCESS HI 100-045 EN 20106 S HBN YYYY SR THERE ARE PROBLEMS IN DESIGN CALCULA 20501 REPORT TIONS, IN THAT SOME ARE HEVER PREPAR NONCONFORMANCE T50213 EN ED, SOME ARE INADEQUATE IN SCOPE AND ENGINEERING EN 20502

-)- EN 20503 QUALITY, AND SOME ARE NOT STORED AS REPORTS QUALITY RECORDS. THERE IS INADEQUA TE INTERFACE AND CONTROL OF DESIGN C ALCULATIONS, NHICH IMPACTS TRACEABIL

) ITY OF DESIGN REQUIREMENTS. CI HAS NO FURTHER INFORMATION. ANONYMOUS C ONCERN VIA LETTER.

3 2 CONCERNS FOR CATEGORY EN SUBCATEGORY 20501 3

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