ML20213A447
| ML20213A447 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/23/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20213A334 | List: |
| References | |
| 201.1(B), 201.1(B)-R01, 201.1(B)-R1, NUDOCS 8702030281 | |
| Download: ML20213A447 (31) | |
Text
I TVA EMPLOYEE CONCERNS REPORT NtNBER: 201.l(B)
SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 1 TITLE: INCORPORATION OF REQUIREMENTS AND COPHITMENTS IN DESIGN PAGE 1 0F 29 Regulatory Requirements (Reg. Guides, NUREG, Bulletins, etc.)
o Policy and Practice on Review, and Response and Implementation o Knowledge of Industry Practices o Attitude toward Safety and Regulations REASON FOR REVISION:
- 1. Revised to incorporate SRP and TAS coments, add chronology, and add Section 10, Corrective Action.
PREPARATION PREPARED BY:
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CSRP Secretary's signature denotes SRP concurrences are in files.
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TVA EMPLOYEE CONCERNS REPORT NtmBER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 29
- 1. CHARACTERIZATION OF ISSUES:
Concerns: Issues:
WI-85-100-001 a. There is a general lack of knowledge
" Electrical and I&C regulations of Regulatory Guides, NUREGS, and IE (Reg. Guides, NUREGS, Bulletins Bulletins and Notices on part of and notices) have been ignored TVA personnel.
and violated to a very large deg.ee at all plants. This has b. Regulatory Guides have been ignored been caused by a lack of know- and have been violated to a large ledge, a poor attitude toward degree, safety and regulations, and a lack of knowledge of industry c. NUREGS have been ignored and have positions on regulations on the been violated to a large degree, part of TVA personnel. CI has no further infonnation. d. IE Bulletins and Notices have been Anonymous concern via letter." ignored and have been violated to a large degree.
XX-85-122-001, -002, -003 "Sequoyah - Electrical and e. There is a lack of knowledge of I&C regulations (Reg. Guides industry positions on regulations on NUREGS, Bulletins and notices) the part of TVA personnel.
have been ignored and violated to a very large degree at all plants. This has been caused by a lack of knowledge, a poor attitude toward safety and NOTE: The following issue from the regulations, and a lacP of know- concerns is addressed in another report.
ledge of industry positions on regulations on the part of TVA There is a poor attitude toward personnel. CI has no further safety and regulations on the part infonnation. Anonymous concern of TVA personnel. ( Addressed by TVA via letter." in Report MP-70600.)
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TVA OMPLOYEE CONCERNS REPORT NUMBER: 201.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 29
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by TVA, NSRS Date March 10,1986 Documentation Identifier:
TVA NSRS Investigation Report I-85-651-SQN, " Electrical Regulations Ignored and Violated," (03/10/86)
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
Electrical and I&C regulations (Regulatory Guides, NUREGS, Bulletins and Notices) are specifically noted.
- 4. INTERVIEW FILES REVIEWED:
Expurgated files WI-85-100 and XX-85-122 were reviewed and no additional unreviewed information was found.
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
l 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 10 ELEMENT.
See Appendix A.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 29
- 8. EVALUATION PROCESS:
identifying applicable Regulatory Guides, NUREGS, Bulletins, and Notices applicable to Sequoyah (SQN) Plant.
- b. Reviewed a sample of design criteria to determine if appropriate Regulatory Guides, etc., were referenced.
- c. Reviewed past and current DNE Engineering procedures (EPs, OEPs, NEPs) and SQN project engineering procedures (SQEPs) to determine if they adequately address these issues.
- d. Reviewed prior QA audits, NRC inspection reports, SALP reports, and other related documents, where available, for evidence that TVA might not have followed procedures,
- e. Reviewed available transcripts of NRC investigative interviews to gain additional infonnation regarding the Concerns.
- f. Reviewed the TVA Corporate Nuclear Performance Plan (CNPP),
Volume I, R1, and the Sequoyah Nuclear Performance Plan (NPP), Volume II, R1 where they were related to this element, for additional infonnation regarding these concerns.
- g. Reviewed TVA program described by SQEP-18 for the generation, verification, and maintenance of the Consnitments/ Requirements (C/R) Database to detennine the extent to which it will address these issues.
- h. Reviewed Design Baseline and Verification Program (DBVP) and Design Basis Program (DBP) for SON to detennine the extent to which they will address these issues.
- f. Reviewed the Index of Stone & Webster Engineering Corporation (SWEC) Reports for SQN to identify any that may address these concerns. Reviewed applicable reports for any additional infonnation regarding the concerns, i
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TVA EMPLOYEE CONCERNS REPORT Nl4WER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 29
- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
Late 60s: SQN design begirs 10/15/68: SQN PSAR issued Mid-1969: Draft 10CFR50 Appendix B issued 01 / 7 0 - SQN-QA Manual, through R12, Constitutes Engineering 12/73: Design Procedures in effect 06/27/70: 10CFR50 Appendix B formally issued 10/73- EN DES Engineering Procedures (EPs), in 06/85: effect. Superseded SQN-QA Manual 1976: TVA comits to ANSI N45.2.11-1974 in SQN FSAR 09/27/80: Operating License (0L) issued for SQN Unit 1 11/80: NUREG 0737 issued 09/15/81: OL issued for SQN Unit 2 12/17/82: NUREG 0737 Supplement 1 issued (Generic Letter 82-33) 04/09/85: TVA Topical Report TVA-TR75-1A, Rev. 8, issued 06/85- Office of Engineering Procedures (0EPs) in effect.
06/86: Superseded EN DES-EPs 08/85: SQN voluntarily shut down by TVA because of questions about the environmental quality of electrical equipment.
09/85 to Sequoyah Project Manual (SQEPs) in effect Present:
09/17/85: NRC requests TVA submit plans for correcting SQN problems 04110 (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NL9WER: 201 .1 (8 )
SPECIAL PROGRAM REVISION NLSEER: 1 PAGE 6 0F 29 11/01/85: TVA presents Sequoyah Nuclear Perfomance Plan (Draf t) and their Corporate Nuclear Performance Plan (initial issue) to NRC 11/17/85: NRC receives employee letter regarding concerns about TVA's nuclear program 12/07/85: TVA receives concern WI-85-100-001 12/09/85: TVA receives concerns XX-85-122-001, XX-85-122-002, and XX-85-122-003 02/18/86: NRC letter forwards copy of Concerned Employee's letter to TVA for review and response 02/21/86: NRC investigative interview with Concerned Employee 03/10/86: TVA Corporate Nuclear Performance Plan (CNPP) Volume I, R0, submitted to NRC 03/10/86: TVA NSRS Investigation Report I-85-651 issued on subject of Electrical Regulations being ignored and violated 04/08/86: Design Basis Program for TVA Plants accepted and adopted (formal desi maintained) gn basis document to be captured and 05/01/86: Formal Design Baseline and Verification Program for Sequoyah, RO, issued 06/23/86: NRC forwards transcript of interview with concerned individual to TVA 07/86 to Nuclear Engineering Procedures (NEPs) in effect.
l present: Superseded OEPs 07/17/86: Sequoyah Nuclear Performance Plan, Volume II, R1, l submitted to NRC with CNPP, Volume I, R1 i
! 08/13/86: TVA CNPP, Volume I, R2, issued I
0411D (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.1(B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 7 0F 29 Discussion:
9.1 BACKGROUND
The Sequoyah Plant design was begun in the late 1960s when regulatory requirements were not required to be well documented. 10CFR50 Appendix B criteria were not put in place until July 1970. Through the mid and late 1970s requirements were more rigorously and unifonnly imposed throughout the industry. Many Regulatory Guides in use today were only in developmental stages during SQN design, and were issued by NRC after the Sequoyah initial design was completed.
Many regulatory changes now reflect later operating experience, and, of course, were not included in the original design. It is not practicable or necessary at this point to attempt to update the SQN plant to include all of the new guidance published by NRC, unless there are specific requirements to do so.
9.2 CURRENT SEQUOYAH PROGRAMS The Sequoyah Design Baseline and Verification Program (DBVP) was established to assess, among many other things, the adequacy of all design criteria that form the design basis for the SQN plant safety-related systems required to mitigate FSAR Chapter 15 accidents and safely shut down the plant.
The DBVP also defines both pre-start and post-restart work items. This program includes review of all related items i
noted in the Commitment / Requirements Database and defines which items are included in the design criteria.
l Sequoyah Engineering Procedure SQEP-18 now in place provides for the the establishment, life of verification, the plant, of the Commitmentsand maintenance during)
/ Requirements (C/R Database. This database identifies SQN Licensing Commitments and Design Requirements that should be captured and reflected in design documents. The scope of this effort covers not only safety-related, but also nonsafety-related structures, systems, and components. This database provides the input to reconstruct the original design basis of the SQN plant.
The SQN Design Basis Program (DBP) is now being implemented to provide the needed SQN Plant Design Basis against which proposed plant modifications can be measured.
l 0411D (01/15/87) 1
TVA EMPLOYEE CONCERNS REPORT NUISER: 201.1(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 29 The following discussion further addresses these programs, which are a systematic approach to establishing and maintaining design requirements.
9.3 GOVERNING DOCLNENTS AND DEFINITIONS Documents Regulations and other fomal requirements are established by the following controlling documents:
o The Atomic Energy Act of 1954, as amended o Code of Federal Regulations, Title 10 o Show Cause Orders o Confirmatory Orders o 10CFR50.54(f) Letters o Anendments to Operating Licenses (licensing conditions) o Atomic Safety and Licensing Board and Appeal Board Decisions o ASME Code (endorsed by 10CFR50)
The following types of documents, among others such as Standard Review Plans and Branch Technical Positions, reflect NRC staff positions which, unless complied with or satisfied by an acceptable alternative, could be imposed by fomal requirement. They establish regulatory guidance and are not mandatory unless implemented by fomal requirements or fomally committed to by TVA.
o Regulatory Guides o NUREG Reports o Office of Inspection and Enforcement (0IE) Bulletins o Office of Inspection and Enforcement (0!E) Notices Definitions l Regulatory Guides. As defined by the NRC Directorate of l Regulatory Standards on the first page of each Regulatory Guide:
" Regulatory Guides are issued to describe and make available to the public methods acceptable to the l NRC Regulatory staff of implementing specific l parts of the Commission's regulations, to delineate techniques used by the staff in evaluating specific problems or postulated accidents, or to provide guidance to applicants.
Regulatory Guides are not substitutes for 04110 (01/15/87)
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 9 0F 29 regulations and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a pemit or license by the Comission.
"The NRC requires a separate review of any alternative methods or positions that are proposed; this review can result in an extension of the licensing schedule."
NUREGs, NUREGs are reports which address Unresolved Safety Issues (USIs) and other generic issues and may be transmitted directly to industry, usually by Generic Letter.
Inspection and Enforcement (0IE) Bulletins. These documents are issued to groups of licensees to provide infomation about, and to direct action on, generic problems that affect or may affect the licensee (s) facilities. The bulletins may variously require inspection, reporting, and the making of comitments to implement controls or remedial actions. The required action may pertain to safety, safeguards, or
- security-related conditions resulting from inadequacies or failures that occurred at the licensee's facilities or at similar facilities. A schedule for the responses is usually stated. Bulletins nomally pertain to problems of considerable significance and demand quick response.
OIE Circulars and Infomation Notices. These documents are similar to NRC-0IE bulletins, but cover problems that are not as significant or imediate. Response to NRC is generally' not required on these items, but TVA may be required to investigate these problems for applicability to TVA plants.
Commitment / Requirement. A comitment or requirement is a verbal or written statement made to the NRC or other regulatory body promising action on safety-related (nonenvironmental) matters, or a requirement by such a body for action on safety-related (nonenvironmental) matters.
Major sources of comitments are:
o Preliminary Safety Analysis Report (PSAR) o Final Safety Analysis Report (FSAR) o Updated FSAR (UFSAR)
, o PSAR kendments l o FSAR kendments i
! 04110 (01/15/87)
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SPECIAL PROGRAM REVISION NIMBER: 1 PAGE 10 0F 29 o TVA Letters to NRC (including responses to NRC-01E) o TVA Meetings with NRC, Advisory Connittee on Reactor Safeguards (ACRS), or Atomic Safety and Licensing Board (ASLB) o TVA telecons with HRC, ACRS, or ASLB The TVA licensing organization receives Regulatory Guides (drafts, fonnal issues, and revisions), NUREGs, and OIE Bulletins and Notices directly from the NRC. Where needed, response times are specified in the documents.
9.4 EVALUATION OF GOVERNING PROCEDURES In reviewing the issues contained in this element, the evaluation team examined the past and present practices, procedures, and processes used at Sequoyah for handling licensing commitments and regulatory requirements.
The various engineering groups provide technical support to the TVA Nuclear Safety and Licensing Staff, which in turn interfaces with NRC.
TVA engineering licensing support procedures were examined
, for requirements regarding the Regulatory Guides, NUREGs, and OIE Bulletins and Notices as they have evolved for the Sequoyah Plant.
The SQN Quality Assurance Manual ( App. A, 5.k) along with Engineering Design (EN DES) Procedures (App. A, 5.m), Office of Engineering Procedures (0EPs) ( App. A, 5.n), Nuclear Engineering Procedures (NEPs) (A Engineering Procedures (SQEPs) (pp.
App. A, 5.p)A,are 5.o), and Sequoyah applicable procedures for SQN from early design stages to the present.
The SQN QA Manual provided the original procedures for Engineering to use in the licensing support effort.
Prior to October 1973, design engineering for TVA nuclear plants was performed by the Architectural, Civil, Electrical, and Mechanical engineering branches or discipline groups which worked on several nuclear plants concurrently. Each branch provided its engineering personnel with technical direction through Branch Design Manuals.
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 engineering branches (which had evolved 04110 (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 110F 29 from the four branches noted in the preceeding paragraph 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 following procedures (App. A, 5.m) pertain to this element:
o EN DES-EP 2.07, initially issued in October 1974, outlined how nonenvironmental licensing comitments made by Office of Engineering (OE) to NRC were identified, controlled, and tracked to completion.
o EN DES-EP 2.08, initially issued in July 1975, provided for the review of NRC Regulatory Guides, the transmission of TVA's coments to NRC, and the establishment of a position concerning the degree of conformance of each TVA nuclear plant to any applicable guide.
o EN DES-EP 2.06, initially issued in 1976, addressed the distribution and review of regulatory documents such as Regulatory Guides. The focus of the procedure was the action required of the Nuclear Engineering Branch's (NEB) Nuclear Licensing Section (NLS).
o EN DES-EP 2.10, initially issued in January 1976, assigned responsibilities for processing a bulletin, circular, or information notice from the NRC Office of Inspection and Enforcement (0IE) when the NRC-01E document related to any TVA nuclear plant. The procedure outlined how these documents should be handled, and how problems they addressed were to be resolved in Office of Engineering Design and Construction (0EDC) and the Office of Nuclear Power (ONP).
o EN DES-EP 2.11, also initially issued in January 1978, covered the EN DES handling of responses to NRC-01E Inspection Reports, Orders, Immediate Action Letters, and Confinnation of Action letters.
In June 1985, the new procedures (0EPs) became effective, and OEP-14 ( App. A, 5.n) addressing licensing support replaced the various EN DES EPs.
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SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 12 0F 29 The new OEPs reduced or eliminated most of the administrative details previously found in the EPs. In place of a stand-alone procedure with many instructions, the OEP referred the reader directly to other procedures that controlled these individual activities. The end result was a series of single sentences that provided anyone unfamiliar with the process rather minimal direct instructions on how to accomplish a given activity.
In July 1986, the reorganized Division of Nuclear Engineering (DNE) procedures (NEPs) became effective, and NEP-2.1
( App. A, 5.o) addressing licensing support replaced OEP-14.
These procedures closely resembled the content, format, and brevity of the OEPs issued a year earlier. NEP-2.1,
" Licensing Support" requires the active use of other referenced NEPs for full understanding of what is to be done.
From NEP - 2.1, Section 1.0, Definitions:
" Licensing: Those activities required to demonstrate compliance with Federal, state, and local requirements in the design, construction, and operation of TVA facilities.
" Licensing Support: Regulatory engineering activities perfonned within DNE (Division of Nuclear Engineering) in support of licensing."
TVA policy on Licensing Support, NEP-2.1, Section 2.0, states:
"DNE prepares input to' support and obtain licenses and pennits for the design, construction, and operation of TVA facilities in compliance with Federal, state, and local regulations and requirements. Licensing documents and responses to Federal, state, and local agencies must accurately reflect the technical requirements of the design, construction, and operation of TVA facilities as identified in design input and design output documentation.
"The coordination within DNE of submittals for licenses and permits will be delegated to a lead discipline branch."
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.1(B)
SPECIAL PROGRAM REVISION NUpWER: 1 PAGE 13 0F 29 The General Requirements of NEP-2.1, Section 3.0, state:
"3.1 Lead Responsibilities The following organizations in DhE have been assigned the lead responsibility to coordinate all licensing support activities in their associated areas:
(NEB) Nuclear Engineering Branch, Nuclear Licensing (MEB) Mechanical Engineering Branch, Environmental Licensing (EEB) Electrical Engineering Branch, FAA Pennits (CEB) Civil Engineering Branch, Security Permits" Each Engineering branch has an area of responsibility as appropriate in licensing support activities.
Responsibilities for regulations in the noted areas then rest with each organization.
Of the four areas defined above, this element report focuses on nuclear licensing support, and thus deals with NEB and the work of the Corporate Nuclear Safety and Licensing Group and with the Site Licensing Group at Sequoyah as outlined in the NPP Volume II ( App. A, 5.x).
Subsection 3.2 of NEP-2.1 identifies required licensing documents. The following documents are mandatory in the nuclear licensing of TVA projects and facilities:
" Preliminary Safety Analysis Report (PSAR) -
Required with application for nuclear plant construction pennit
" Final Safety Analysis Report (FSAR) - Required with application for nuclear plant operating license
" Updated Final Safety Analysis Report (UFSAR) -
Annual updating of operating plants' FSARs as required by 10CFR50.71(e)
" Topical Reports (TR) - Submitted to NRC on subjects common to several nuclear plants and which require a safety assessment by NRC (e.g.,
TVA Nuclear Quality Assurance Program) 04110 (01/15/87)
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TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 14 0F 29 "Other Licensing Submittals - Coordinated DNE responses to NRC Bulletins and Information Notices, and responses to questions, 10CFR50.55(e) and 10CFR21 reports, violations, etc.
" Physical Security / Contingency Plan (PS/CP)"
9.5 COMMITNENTS When a commitment that has a significant effect on DNE's scope of work, responsibilities, licensing, and safety is -
made to NRC or another regulatory body, the commitment will be tracked to closure with the Corporate Comitment Tracking System (CCTS) as described in Sequoyah Element Report 201.5.
The comitment is controlled and monitored by the PE/ Lead Nuclear Engineer. Procedures outline how licensing comitments made to the NRC are identified, controlled, and tracked to completion. In general, the various procedures are adequate.
Tracking of comitments at the SQN Plant was examined in Sequoyah Element Report 201.5 and found adequate.
The following excerpt is from the TVA Corporate NPP (CNPP)
( App. A, 5.y):
"TVA has had a nuclear licensing group at its corporate headquarters for a number of years, and it also has licensing groups at each of its nuclear plant locations which were essentially independent of the headquarters group. . . ."
Because this has contributed to weaknesses in TVA's licensing activities, TVA has committed in the CNPP to centralize these activities under a single director who reports directly to the Manager of Nuclear Power.
Procedure SOEP-18 ( App. A, 5.p) identifies commitments and requirements as source infonnation for Sequoyah design criteria development. The following excerpts from the procedure describe its key points:
"This procedure establishes a systematic approach to identify the licensing comitments and other design requirements which should be captured and reflected in design documents. The scope includes both safety-related and nonsafety-related systems, structures, and components."
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SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 15 0F 29 "A Licensing Comitment is an action related to the design, construction, operation or testing of a TVA nuclear plant that has been comunicated to an organization authorized to regulate TVA activities."
"A Design Requirement is any technical requirement or internal TVA comitment which is essential for the safe or reliable operation of a nuclear plant."
"The concept used is a top-down approach in which comitments made in generic upper tier design input documents, comitments made in licensing documents, design requirements, TVA policies, and existing design criteria must be captured in either plant-specific design criteria or other design input documents."
"The program requires senior engineers and managers who are familiar with the design evaluation to research the applicable source documents and identify the plant design requirements and comitments. [These reviewers]
". . . complete a comitment/ requirements (C/R) data sheet for each licensing comitment or design requirement identified in accordance. . . ."
[with the procedure. This infomation is then entered into the database.]
"The program establishes a database containing the comitments/ requirements to be initially incorporated into the design criteria. The database will then be turned over to the project and maintained throughout the life of the plant."
"A continuous review of new source documents (e.g., Change Documents, Vendor letters, Correspondences, System Design files, Job Books, etc.) for comitments/ requirements will be done by the Responsible Engineer / personnel who deal with the various source documents."
9.6 EVALUATION TEAM INVESTIGATIONS In the NRC investigative interview the CI notes several specific cases where regulatory guides were allegedly not incorporated on time or at all. It also implies that the CI's real concern is perhaps with an apparent lack of timely 0411D (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NLM8ER: 201.1(8)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 16 0F 29 communication between the group handling incoming NRC guidance and the ultimate user groups (engineers and designers) in the Electrical and I&C areas. The further implication is that design input docuents (i.e., Design Criteria) are not either updated or generated in a timely manner.
The majority of the SQN licensing comitments were made in the late 1960s and early 1970s and many of the present day doc u ents were not SQN requirements. This may have led the CI to perceive that some requirements were not properly addressed at SQN.
A sample of design criteria (App. A., 5.qq, rr, ss, and tt) was reviewed and, in general, regulatory guides, generic letters, etc., were being addressed properly. This was not an in-depth review to detennine if all applicable requirements were incorporated in each docuent.
Some specific inadequacies in the incorporation of Electrical and I&C Regulations in design docuents are addressed in detail in Sequoyah Element Report 213.3.
The TVA NSRS Report I-85-651-SQN (App. A, 5.vv) indicated that concerns raised in the Electrical and I&C area ". . .
were substantiated, but TVA management is fully aware of the conditions and has planned corrective action in accordance with the Nuclear Perfonnance Plan."
Four SALP Board reports were reviewed which cover the SQN Operations for the period from July 1,1980 through May 31, 1985 (App. A, 5.gg, hh,11, and jj). In general, the SALP Board evaluated the performance of several areas of plant operations rather than examining engineering design or construction. However, in the most recent report (App. A, 5 99), the Board's examination in the area of fire protection and Appendix R requirements found four items that could be I attributed to omission of required features by the i
engineering organization. These items were identified as one violation for several discrepancies of not meeting requirements of Appendix R of which three could be attributed to engineering. These are:
" Failure to provide adequate fuse / breaker protection for equipment required for test j standby."
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SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 17 0F 29
" Failure of the oil collection system for reactor r coolant pinps to meet Appendix R Section III.0 L_
requirements."
=
" Emergency Lighting Units did not meet Appendix R Section III'.s requirements."
The fourth item was identified as a:
" Deviation for failure to provide status lights in ~
the control roam for fire protection system _
containment isolation valves as stipulated in the
~
FSAR."
In addition to the SALP Board evaluation, TVA conducted an Appendix R reevaluation program that identified 121 safe shutdown system / cable interaction discrepancies =
(App. A, 5.gg)
The evaluation team also reviewed a sample of six NRC Inspection Reports (App. A, 5.kk,11, nn, nn, oo, pp).
These reports did not identify any violations that could be attributed to Engineering having violated or ignored a requirement.
The C/R Database program was discussed with cognizant TVA personnel on several occasions, and samples of the input data sheets and output reports were examined. If properly implemented, the program is adequate to capture both prior and future cannitments and requirements and to maintain the database current.
A Stone & Webster Engineering Corporation (SWEC) report (App. A, 5.xx) for SQN was reviewed and it indicated that corrective action on an NRC concern relating to failure to submit FSAR changes is assessed to be progressing satisfactorily.
Full implementation of the DBVP, DBP, and the C/R Database (per SQEP 18, R2) programs, which includes a controlled overview by the TVA Engineering Assurance (EA) organization (App. A, 5.uu) and external audits (App. A, 5.cc, dd, ee, ff), should adequately resolve these programmatic issues.
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 18 0F 29 Documentation was exanined (e.g. , App. A, 5.ww) to determine the extent of TVA involvement with others in the industry regarding establishing and discussing industry positions on regulations and requirements published by NRC. Interviews and discussions (e.g.,
App. A, 7.m) were also conducted on this subject.
Sufficient information was provided to the evaluation team to indicate more than adequate TVA participation in this area.
There is ample evidence of TVA participation in related p ofessional society (e.g., ASME, IEEE) activities auring the design and construction phases of SQN.
Involvement in various cannittees and subcommittees was at both chairperson and lower levels.
TVA has participated in NSSS Owners Group activities since the mid-1970s, becoming more active following issuance of NUREG 0737 in 1980. Again, participation in l committee work was at both Chairperson and lower levels. Participation with other Utilities (e.g., Duke Power) and other industry groups (e.g., EPRI) was also noted.
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TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 19 0F 29 Findings
- a. The evaluation team found no evidence to support the allegation that there is a general lack of knowledge of Regulatory Guides, NUREGs, and OIE Bulletins and Notices on the part of TVA personnel. Based on the doc u entation reviewed and interviews conducted during the course of the employee concerns review, appropriate TVA personnel are cognizant of the requirements.
- b. Regulatory Guides provide guidance for licensees and do not define a regulation unless they are imposed by a requirement document or they are fomally committed to by TVA.
Evidence was found to indicate that some regulatory guides applicable to SQN were not addressed or incorporated in a timely manner. An example of this is discussed in detail in Sequoyah Element Report 213.3.
In the evaluation team review no evidence was found of regulations or requirements being intentionally ignored or violated. Sometimes, however, action on such matters was not completed in an appropriate period of time.
- c. NUREGs provide guidance for licensees and do not define requirements unless the NUREGs are included in ar. NRC showcause order, letter, or other fom of licensing commitment. Therefore in this context they cannot be violated. Most NUREGs also allow alternative approaches as long as deviations are identified and are justified. No evidence was found to indicate that NUREGs applicable to SQN that have been committed to were ignored or violated.
- d. ole Bulletins reflect NRC staff positions which, unless complied with or a satisfactory alternative is offered, could be imposed by a fomal requirement. Since they are not regulations, they cannot be violated. However, evidence was found to indicate that some TVA responses to bulletins were both late and partially incomplete or inadequate.
OIE Notices are issued by NRC to give early notification of possible significant events. Usually Notices suggest review for possible applicability, but no feedback to the NRC is requested. Since they are not regulations, they cannot be violated. No evidence was found that any Notices were intentionally ignored.
0411D (01/15/87)
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SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 20 0F 29
- e. The evaluation team found no evidence of a general lack of knowledge of industry positions on regulations.
Documentation reviewed indicated active TVA participation in NSSS Owner's Group efforts as well as in technical societies (IEEE, ASME, etc.) at both committee and subcomittee levels.
Conclusions:
o Regulatory Guides, NUREGs, and 0IE Bulletins do not by themselves define a regulation. They do not become a regulation unless imposed by an NRC requirement document or committed to by TVA. Appropriate TVA personnel are cognizant of regulations and requirements for SQN.
o No evidence was found of regulaticns or requirements being intentionally ignored or violated. However, evidence was found of late incorporation of some Regulatory Guides and of some late and incomplete TVA responses to NRC.
o The issues that there was a general lack of knowledge on the part of TVA personnel regarding Regulatory Guides, NUREGs, and 0IE Bulletins and Notices and that they were generally ignored and violated by design engineering is not valid.
o Appropriate TVA personnel are indeed aware of industry positions on regulations. Examples of this are provided by the ongoing TVA participation in NSSS Owner's Group efforts and in Technical Society committees and subcomittees.
Therefore, the issue that there was a lack of such knowledge on the part of TVA personnel is not valid.
o Since the majority of the SQN licensing comitments were made in the late 1960s and early 1970s, many of the present day documents were not SON requirements. This may have led the l CI to perceive that some requirements were not properly j addressed at SQN.
o Sufficient evidence has been noted to establish that in the past some regulatory requirements were not properly addressed at Sequoyah. However, TVA now has programs in place to l
correct and further mitigate such occurrences. These j i programs are the C/R Database (per SQEP 16, R2), the DBP, and the DBVP.
i l
0411D (01/15/87) l
TVA D4PLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 21 0F 29
- 10. CORRECTIVE ACTION:
TVA corrective action plan TCAB-039 states the following:
"The C/R Database progran (SQEP 18 R2), Design Basis Program and Design Baseline and Verification Program shall be completed as applicable to meet the restart requirements for each unit at Sequoyah. The post-restart phases for these programs will be completed as schedules are established."
The evaluation team concurs with the TVA corrective action plan.
1 0411D (01/15/87)
. l TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.l(B)
SPECIAL PROGRAM i REVISION NUMBER: 1 PAGE 22 0F 29 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Chapter I, Appendix B, Quality Assurance Criteria
- For Nuclear Power Plants" l b. ANSI N45.2.ll - 1974, " Quality Assurance Requirements for the l Design of Nuclear Power Plants"
- c. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- d. ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants"
- e. Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction)," R0, (06/07/72)
- f. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- g. Sequoyah Preliminary Safety Analysis Report, (PSAR)
- h. Sequoyah Final Safety Analysis Report (FSAR) Updated, through Amendment 3.
- i. TVA, TR 75-1A, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," R8
- j. TVA, Nuclear Quality Assurance Manual, (NQAM), (11/14/85)
- k. Sequoyah Nuclear Plant Quality Assurance Manual (SQN QAM)
Quality Assurance Procedures (QAPs) employed in the review of this element are from Revision 11 of the SQN QAM (and prior).
- 1. Office of Engineering Design and Construction (0EDC) Quality Assurance Manual 1
l 0411D (01/15/87) l 1
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TVA EMPLOYEE CONCERNS REPORT NLSEER: 201.l(B)
SPECIAL PROGRAM REVISION Nt#EER: 1 PAGE 23 0F 29 APPENDIX A (Cont'd)
- m. TVA, EN DES Engineering Procedures Manual. This evaluation refers to the following:
Volume 1, Section 1.0, Category: General Volume 2, Section 3.0, Category: Engineering EN DES Engineering Procedures (EP) reviewed were:
EP No. 2.06, R4 " Distribution and Review of Licensing and Regulatory Information," (04/06/81)
EP No. 2.07, R6 "Licensin Tracking,g (02/28/85)
Commitments - Control and EP No. 2.08, R6 "NRC Regulatory Guides - Review, Comment, and Documentation of TVA Conformance,"
(09/14/84)
EP No. 2.10, R7 "NRC - OIE Bulletins, Circulars and Information Notices - Distribution and Preparation of Responses," (03/02/84)
EP No. 2.11, R4 "NRC - OIE Inspection Reports, Orders, Immediate Action Letters, and Confirmation of Acting Letters - Handling and Preparation of Responses," (08/23/83)
EP No. 3.01, R6 " Design Criteria Documents - Preparation, Review, and Approval," (05/22/84)
- n. TVA, Office of Engineering (0E) Management Manual, (04/26/85)
The following 0EPs are referred to in this evaluation:
1 OEP-06, R0 " Design Input," (04/26/85) 0EP-10, R0 " Review," (04/26/85)
OEP-14, R1 " Licensing," (12/02/85) 04110 (01/15/87) l
TVA EMPLOYEE CONCERNS REPORT NLMBER: 201.l(B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 24 0F 29 APPENDIX A (Cont'd)
- o. TVA, Nuclear Engineering Procedures (NEPs):
NEP-2.1, R0 " Licensing Support" (07/01/86)
NEP-3.2, R0 " Design Input" (07/01/86)
NEP-5.2, R0 " Review," (07/01/86)
SQEP-13, R0 " Procedure for Transitional Design Change Control," (07/25/86)
Sequoyah Engineering Procedure SQEP-18, R2 " Procedure for Identifying Comitments and Requirements as Source Infomation for Sequoyah Design Criteria Development" SQEP-29, " Procedure for Pregaring the Design Basis Doceent for Sequoyah Nuclear Plant, R1 (07/18/86)
- r. Sequoyah Nuclear Plant Design Criteria Manual (6 Volmes),
(06/26/86)
- s. TVA memo from W. C. Drotleff, to Those Listed, (R. G. Damer, et al), " Design Basis Program for TVA Nuclear Plants,"
(B44 860402 007), (04/08/86)
- t. TVA Memo from W. C. Drotleff, to Those Listed (H. L. Abercrombie, et al), " Transition to Division of Nuclear Engineering Procedures," (805 86 0410 008), (04/14/86)
- u. TVA memo from D. W. Wilson to Those Listed, (G. Aklu, et al),
"Sequoyah Nuclear Plant - Design Baseline and Verification Program," (B25 860506 020), (05/06/86)
- v. Letter from NRC to S. A. White, TVA, " Transcript of Interview of Dallas R. Hicks," (06/23/86)
- w. TVA memo from R. L. Gridley to Those Listed (H. L. Abercrombie, et al), "Sequoyah Nuclear Perfomance Plan - Volume II - Final Concurrence," (L44 860714 800),
(07/14/86) 0411D (01/15/87)
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SPECIAL PROGRAM REVISION WlMBER: 1 PAGE 25 0F 29 APPENDIX A (Cont'd)
- x. Sequoyah Nuclear Performance Plan, Volme II, R1 (approval scheduled for July 16, 1986)
- y. TVA Revised Corporate Nuclear Perfomance Plan, Volme I, R2 (08/13/86)
- z. TVA memo from J. F. Cox to M. T. Tormay, "Sequoyah Design Basis Program to Support Restart," (B25 860811 100),
(08/11/86) aa. Letter from J. M. Taylor, NRC, to S. A. White, TVA, " Report Nos. 50-327/86-38 and 50-328/86-38," (09/15/86) bb. Letter from J. M Taylor, NRC, to S. A. White, TVA, " Report Nos. 50-327/86-45 and 50-328/86-45," (10/31/86) cc. Letter from M. J. Salerno, Impell, to H. Jones, TVA, " Design Control Program, External Audit Finding Evaluation,"
(06/19/86) dd. Letter from M. J. Salerno, Impell, To H. Jones, TVA, " Design Control Program, External Audit Finding Evaluation,"
(860723 002) (07/10/86) ee. Letter from M. J. Salerno, Impell, to H. Jones, TVA, " Design Control Program, External Audit Finding Evaluation," 07/23/86) ff. Letter from L. M. Mill, TVA, to R. Adensam, NRC, " Response to Generic Letter, 83-28," Docket 50-327, 50-328 (A27 831107 026) (11/07/83) gg. Letter from Dircks, NRC, to TVA, (B45 850919 826), SALP Board Reports, (09/17/85) l hh. Letter from Lewis, NRC, to TVA, (NEB 8406/14 612), SALP Board
- Reports, (06/12/84)
- 11. Letter from Lewis, NRC, to TVA, (A02 830415 001), SALP Board Reports, (04/13/83) jj. Letter from Lewis, NRC, to TVA, (A02 820823 010), SALP Board Report, 08/20/82) 0411D (01/15/87)
9 TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.l(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 26 0F 29 APPENDIX A (Cont'd) kk. NRC letter from J. P. O'Reilly to H. G. Parris, Report Nos.
50-327/83-31 and 50-328/83-31, (02/14/84)
- 11. NRC letter from D. M. Verrelli to H. G. Parris, Report Nos.
50-327/85-23 and 50-328/85-23, (08/02/85) mm. NRC letter from J. A. Olshinski to S. A. White, Report Nos.
50-327/85-46 and 50-328/85-46, (03/05/86) nn. NRC letter from J. A. Olshinski to S. A. White, Report Nos.
50-327/86-06 and 50-328/86-06, (03/05/86) oo. NRC letter from G. G. Zech, NRC, to S. A. White, TVA, Notice of Violation (Inspection Report Nos. 50-327/86-31 and 50-328/86-31), (L44 860820311), (08/12/86) pp. NRC letter from G. G. Zech, NRC, to S. A. White, TVA, Notice of Violation (NRC Inspection Report Nos. 50-327/86-42 and 50-328/86-42), (L44 861003356), (09/26/86) qq. SQN-DC-Y-ll .2, "125-Y Yital Battery System," R3, (07/11/86) rr. SQN-DC-V-11.2.1, "125-Volt Fifth Vital Battery System," R2, (07/11 /86) ss. SQN-DC-Y-ll.4.1, "Nonnal and Emergency AC Auxiliary Power Systems," R2, (07/22/86) tt. SQN-DC-V-11.6, "120-V AC Vital Instrisnent Power System," R3, (07/11 /86) uu. Action Items Originated by the Engineering Assurance Independent Oversight Review Team for the Sequoyah Nuclear Plant Design Baseline and Verification Program - Simnary Report, Prepared By: John Von Weisenstein, (10/22/86) vv. TVA NSRS Investigation Report I-85-651-SQN, " Electrical Regulations Ignored and Violated," (03/10/86)
I ww. TVA memo from S. A. Shipman to Those Listed, (R. O. Barnett, et al), " Professional Society Committees and Industry Activities," (802 860 903 001), (08/25/86) xx. Stone & Webster Engineering Corporation (SWEC) Report No.
SWEC-SQN-06, (09/15/86) 1 0411D (01/15/87)
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 27 0F 29 APPENDIX A (Cont'd)
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
- a. 10CFR50, Appendix B, " Quality Assurance Criteria For Nuclear Power Plants"
- b. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- c. Sequoyah Final Safety Analysis Report (FSAR) Updated, through Amendment 3 (04/86)
- d. TVA Nuclear Engineering Procedures (NEPs):
NEP-2.1, R0 " Licensing Support," (07/01/86)
NEP-3.2, R0 " Design Input," (07/01/86)
Project Manual 0411D (01/15/87)
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 28 0F 29 APPENDIX A (Cont'd)
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- a. Discussion, R. Wolters, Bechtel, with C. F. Bowman and D. T. Clift, TVA, in Knoxville, (08/28/86); IOM 438
- b. Discussion, R. Wolters, L. Anderson, Bechtel, with H. Jones and D. T. Clift, TVA, at SQN jobsite, (08/26/86); IOM 438
- c. Telecon, R. Wolters, Bechtel, with C. F. Bowman, TVA, in Knoxville (10/22/86); IOM 439
- d. Discussion D. Zwicky, B. Wolters, Bechtel, with H. Jones and D. T. Clift, TVA, at Sequoyah jobsite, (10/24/86); IOM 439
- e. Trip Report, visit by R. Wolters to Knoxville, 10/21-10/23/86 and to SQN jobsite 10/24/86; IOM 439
- f. RFI # SQN-714 (11/20/86)
- g. TTB No. 092 (08/13/86)
- h. TTB No. 097 (08/20/86)
- 1. TTB No.104 (09/03/86)
- j. TTB No.122 (09/30/86)
- m. Telecon, R. Wolters, Bechtel, with D. T. Clift and D. Wilson, TVA, (12/05/86); IOM 440 04110 (01 /15/87)
TVA EMPLOYEE CONCERNS REPORT NIMBER: 201.l(B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 29 0F 29 CATD LIST t The following CATD identifies and provides corrective actions for the findings included in this report:
201.01 SQN 01 (12/16/86) 1 l
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