ML20214U216
| ML20214U216 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/28/1986 |
| From: | Mason P, Mcnult G, Parkinson J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214G966 | List:
|
| References | |
| 243.0(B), 243.0(B)-R, 243.0(B)-R00, NUDOCS 8612090185 | |
| Download: ML20214U216 (15) | |
Text
_ _ _ _ - _ _ _ _ _
l J.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
243.0 (B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 0 TITLE:
DIESEL DESIGN MARGINS Inadequate Diesel Generator Margins j
PAGE 1 0F 11 i
REASON FOR REVISION:
1 j
A 1
fh PREPARATION 0;fgh PREPARED BY:
Y 6%
/0/ss/r6 m
SIGNATURE
'DATE REVIEWS 1
h REVIEW C TTEE dd Z hb j
SIGNATURE DATE TAS:
V i
SIGNATURE DATE CONCURRENCES e
8612090185 861124 y
je/z g/(f M'y; d
PDR ADOCK 05000327 P
PDR NESI
/0-J P Fl CEG-H-SRP:
SIGNATURE DATE SIGNATURE DATE 5 ',L APPROVED BY:
ECSP MhMAGER BATE MMthEER OF MUCLEAR PmfER DATE CONCURRENCE (FINAL REPORT ONLY)
,1
]
TVA EMPLOYEE CONCERNS REPORT NUMBER:
243.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 2 0F 11
(
1.
CHARACTERIZATION OF ISSUE (S):
Concerns:
JjLsues:
XX-85-122-006, 007 a.
Diesel generator capacity / margins are WI-85-100-002, 010 inadequate.
I-85-132-SQN-01
" Diesel generator margins are b.
Diesel generator (DG) loading and margin inadequate. TVA has added records are inadequately maintained, diesel generators to Browns resulting in a new study every time a Ferry, Sequoyah and Watts question is raised regarding current Bar. Each time a question is loads and margins.
raised, TVA must conduct another study. TVA adds diesel c.
Diesel generators were added without generators without upgrading updating licensing documents.
licensing documents."
d.
Because of inadequate capacity, XX-85-122-030, 031, 032 diesel generators were added.
" Inadequate management, control and status listing of ac and e.
Ac and de electrical loads and margins pg,'
de electrical loads, including are not kept current (updated) as W
diesel generator loads. This changes (additions or deletions of involves inadequate control of, loads) occur.
(Addressed in Element or preparation of, calculations Report 213.1) for loads, and inadequate management and control of load f.
Electrical calculations for loads margins, including electrical are inadequately prepared and loads and mechanical loads controlled.
(Addressed in Element j
(heat, BHP, etc.) that translate Report 213.1) into electrical loads."
g.
There is programmatic inadequacy with regard to preparation and control of I
calculations.
(Addressed in Element l
Report 205.2) h.
There is programmatic inadequacy with regard to updating licensing documents.
(Addressed in Element Report 201.5) 2.
HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by NSRS/0AQ/S&L OQA gut gdg9 Date For dates see Documentation Identifiers below i
'? T ',
h 1044d (10/21/86)
4 TVA ENPLOYEE CONCERNS REPORT NUNBER: 243.0 (B)
SPECIAL PROGRAN REVISION NUNBER: 0 i
(.
PAGE 3 0F 11 Documentation Identifiers:
a.
NSRS Investigation Report No. I-85-132-SQN, " Diesel Generator Loads," (3/6/86) b.
NSRS Investigation Report No. I-85-992-SQN, " Control of Ac and Dc Electrical Loads," (4/7/86) c.
Office of Quality Assurance, Audit Deviation Report D-51-A-84-0006, (08/01/84) d.
Sargent & Lundy Final Report, " Electrical Calculation Program," (04/08/86) 3.
DOCUMENT NOS. TAG NOS.. LOCATIONS. OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.
All auxiliary power system diesel generators. Tag Nos lA-A, 1B-B, 2A-A, 2B-B, and the " Additional Diesel Generator Unit" (ADGU) 4.
INTERVIEW FILES REVIEWED:
F.iles XX-85-122 and WI-85-100 were reviewed and no additional unreviewed information was found.
5.
DOCUMENTS REVIEWED RELATED TO THE ELENENT:
See Appendix A.
6.
WHAT REGULATIONS. LICENSING COMNITNENTS. DESIGN REOUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
i 7.
LIST REQUESTS FOR INFORMATION. NEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
v.
S. f!*. }
1044d (10/21/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 243.0 (B)
SPECIAL PROGRAM REVISION NUMBER: O PAGE 4 0F 11 8.
EVALUATION PROCESS:
a.
Review the licensing commitments, design criteria, and the governing regulations, standards, and guides for establishing required load margins (capacity) for the four original diesel generators (DG) and the additional fifth DG.
b.
Review existing reports and TVA documents:
o To determine the extent of TVA compliance with the established criteria and commitments o
To determine how this compliance is currently documented o
For discussion of validity of the concerns o
For discussion of what corrective action, if any, has been implemented c.
Review transcript of NRC investigative interview.
. b.
hh; d.
Assess previous corrective actions taken by TVA in response to other systematic analyses.
9.
DISCUSSION. FINDINGS. AND CONCLUSIONS:
Discussion:
The concerned individual raises the general issues that preparation, management, and control of calculations for electric loads are inadequate.
It is asserted that this inadequacy, as it specifically applies to diesel generator loads and margins, has led to the addition of a fif th diesel generator to increase system capacity.
The concerns question the ability of the Auxiliary Power System (APS) to perform its intended safety function.
Issues "a" through "d" in Section 1, as they relate to the Sequoyah Nuclear Plant (SQN) diesel generators, are discussed in this report.
Issues "e" and "f" are addressed in Subcategory 213
" Electrical Procedures," issue "g" is addressed in Subcategory 205
" Control of Design Calculations," and issue "h" is addressed in Subcategory 201 " Incorporation of Requirements and Consnitments in Design."
Lack of documentation of the diesel generator loads and margins has been substantiated by several reports. The first systematic e
i%
analysis of this issue was NSRS Report I-85-132-SQN, which 1044d (10/21/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
243.0 (8)
SPECIAL PROGRAM REVISION NUMBER: O PAGE 5 0F 11 referenced Office of Quality Assurance (00A) Audit Deviation Report D51-A-84-0006. The deviation report found there is insufficient design control 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 No.
I-85-992-SON further documented this lack of design control and concluded that it was generic to the Division of Nuclear Engineering (DNE). Finally, a Sargent & Lundy (S&L) Report on the SQN electrical calculations program found that the majority of the calculations were prepared informally by TVA during the design period and were not maintained in a manner that would allow easy j
retrieval over the life of the plant (the evaluation team has made similar observations during this review). S&L concluded, however, that "Sequoyah is, in general, typical of industry practice in the time frame involved."
As a result of all the identified deficiencies of SQN calculations, a program was established to generate a minimum set of calculations required to support the design bases. To ensure proper maintenance of these calculations, Nuclear Engineering Procedures (NEP) 3.1
" Calculation" and 6.1 " Change Control" have been established.
@g,gM This program is discussed in element reports for Subcategory 205.
- ?
Calculation SQN-E3-002, " Diesel Generator Load Analysis," is part of this minimum set of calculations.
The evaluator reviewed calculation SON-E3-002 R2 to determine the 5
adequacy of the DG capacity. The calculation contains loading sequence tables corresponding to several Design Basis Events (D8E). However, these tables are based on plant configurations t
i that did not exist at the time Revision 2 of the calculation was performed. These postulated plant configurations were termed
]
" unverified assumptions" and are to be implemented per ECN L6715 l
prior to restart, i
L None of the DBE loading sequences completely enveloped the rest; therefore, all the sequences were evaluated.
Loading simulations were performed for the identified loading sequences to demonstrate adequate loading capability and compliance with Regulatory Guide 1.9.
Further, the steady state DG load was calculated and found to be acceptable if credit was taken for operator action of tripping 4
certain long-term loads. TVA advised via teleconference (App. A, l
7.b) that operating procedures exist for monitoring steady state DG L
loads, and a list of equipment that may be tripped to maintain the long-term load within the DG limit is established. However, no evidence exists that these procedures have been revised, and no commitment to do so was identified. Finally, this calculation p* f.M assumes that Unit 1 is in cold shutdown; therefore, this t
Q, calculation must be revised prior to Unit 1 restart.
1044d (10/21/86)
I TVA EMPLOYEE CONCERNS REPORT NUMBER: 243.0 (B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 6 0F 11
(
i l
The only other DG calculation known to exist prior to SQN-E3-002 is a steady state analysis issued in November 1985 ( App. A, 7.b).
This calculation also identified a need to change plant configuration and formed a basis for (and was superseded by) the current calculation SQN-E3-002. No calculations made prior to November 1985, to demonstrate adequate capacity and margins, were identified.
The fif th DG is being added in accordance with Design Criteria SQN-DC-V-ll.1.1 R0 ( App. A, 5.f). This criterion explicitly states that the additional diesel generator unit is being added to increase plant availability.
This is furtMr supported by engineering design drawings which show provis*nns to ensure that the fifth DG cannot be connected to the APS withc'it disconnecting one of the other four. Therefore, credit for the fifth diesel capacity is not taken.
As indicated by the concerned individual, there is currently no reference to the fifth diesel generator in the licensing documents (e.g., FSAR).
TVA personnel advised the evaluator that there is no A
need to license the fifth diesel generator before restart of Unit 2 h.3 (App. A, 7.a and 7.c).
Evaluator's concurrence with this
+
conclusion is based on the facts that 1) the fifth diesel is not required for restart of Unit 2, and 2) 10CFR50.71 ( App. A, 6.k) does not require revision of the FSAR until design modifications are implemented and are to become operational. Licensing issues are addressed in more detail in Element Report 201.5.
Findings:
a.
Diesel generator capacity margin is adequate for restart of Unit 2 with four diesel generators available and Unit 1 in cold shutdown.
However, modifications must be made to the load configurations per ECN L6715, and operating procedures require updating to reflect the additional long-term loads that may be tripped.
b.
Diesel generator loading and margin records had not been adequately maintained. To rectify this, TVA has implemented a program to identify, update, and maintain the minimum calculation set. These calculations will be controlled per NEP 3.1.
c.
The fifth DG is not presently included in the SQN licensing documents and is not a licensing issue until it is to be put into operation.
- l 1044d (10/21/86) 1
TVA EMPLOYEE CONCERNS REPORT NUMBER: 243.0 (B)
SPECIAL PROGRAM REVISION NUMBER: O PAGE 7 0F 11 d.
The fifth diesel generator is being added to increase plant availability when one of the four DGs is taken out of service, not for additional capacity.
==
Conclusions:==
The employee concerns raised valid issues regarding adequacy of the DG load calculation and, in general, the DG system capacity. The problems associated with these issues have been recognized by TVA and corrective actions initiated. Completion of changes per ECN L6715, implementation of TVA's long-term calculation program, and future adherence to the new procedures (Nuclear Engineering Procedures and SQN Engineering Procedures) will correct the problems and prevent future recurrence.
D,,):.,
. ;7 1044d (10/21/86)
TVA EMPLOYEE CONCERNS REPORT NUN 8ER: 243.0 (8)
SPECIAL PROGRAN REVISION NUMBER: O PAGE 8 0F 11 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
NSRS Final Report I-85-992-SQN, " Control of Ac and Dc Electrical Loads," (04/07/86) b.
NSRS Interim Report I-85-992-SQN, " Control of Ac and Dc Electrical Loads," (03/17/86) c.
NSRS Report I-85-132-SQN, Diesel Generator Loads, (03/06/86) 1 d.
SNP FSAR Chapter 8 7
e.
Sequoyah Unit 1 Tech. Spec. 3/4.8.1 Amendment No.12,
" Auxiliary Power Systems (APS)," (03/25/82) f.
Design Criteria: SQN-DC-V-11.1.1 RO, " Design Criteria for the Additional Diesel Generator," (05/16/80)
. A A, g.
Division of Engineering Design (EN DES) Electrical Design W$$
DS-E-2.2.2 R0, " Performance and Equipment Application W
l Criteria - Medium Voltage Auxiliary Power System Standard,"
l (12/01/82) h.
Sequoyah Engineering Procedures 11 - Rev. 4. " Procedure for Identifying and Assembling Change Documentation," (08/18/86) l 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 i
Transitional Design Change Control," (07/25/86) k.
Sequoyah Engineering Procedures 15 - Rev. O, " Procedure for l
DNE Interface with Change Control Board (CC8)," (05/15/86) 1.
Nuclecr Engineering Procedures (NEPs):
i 3.1 R0, " Calculations," (07/01/86) 4.1 RO, " Procurement," (07/01/86) 5.1 RO, " Design Output," (07/01/86) 6.1 RO, " Change Control," (07/01/86) i m.
Revised Sequoyah Nuclear Performance Plan, Volume II, Rev. 1 I$/ :',
I t
1044d (10/21/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 243.0 (8)
SPECIAL PROG?AN REVISION NUMBER:
O PAGE 9 0F 11 i
APPENDIX A (cont'd) n.
Sequoyah Nuclear Plant Electrical Calculation Program Assessment Final Report by Sargent & Lundy, (04/08/86) 1 o.
Scope of Work Documents:
l SONSWD8506 R0, "APS Load Analysis," (12/06/85)
SQNSWD8503 R0, "D-G Analysis," (12/06/85) p.
Gilbert /Comonwealth Report P!o. 2614 "SQN Modifications for TVA," (03/03/86) 4 TVA memo from W. S. Raughley to G. T. Vall, (843 860716 904)
Subject:
0-G Action Items r.
DNE calculation: Diesel Generator Load Margins SQN-E3-002, R.2 (B43 860827 909) s.
Engineering Change Notice, ECN L6715 (09/86) t.
TVA memo from W. C. Drotleff to Those Listed,
(.., sf (805 860410 008)
Subject:
Transition From OEP to NEP u.
TVA memo from W. S. Raughley to Those Listed, (B05 860508 902)
Subject:
Policy Memorandum PM 8602 (EEB) -
j Electrical Calculations v.
Significant Condition Report, SCR SQN EEB8629 R3 l
Subject:
Violation of Voltage and Frequency Variance l
w.
Significant Condition Report, SCR SQN EEB8646 R1
Subject:
Violation of Voltage and Frequency Variance x.
TVA memo f rom D. W. Wilson to R. L. Gridley, (B25 860613 023)
Subject:
SQN-Electrical Calculation Program y.
Quality Information Requests / Releases:
l QIR SQN EEB86070, (B43 860728 901) l QIR SQN EEB86081, (B43 860808 910)
I QIR MEB 86008, (B44 860820 004) l QIR NEB 86126, (845 860826 255) z.
Letter from B. J. Youngblood, NRC, to S. A. White, TVA, (06/25/86), with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First
,yp, ib Tennessee Bank Building in Knoxville, TN aa.
All documents listed in Appendix A, Section 6 1044d (10/21/86) l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
243.0 (B)
SPECIAL PROGRAM REVISION NUMBER:
O PAGE 10 0F 11 APPENDIX A (cont'd) 6.
WHAT REGULATIONS LICENSING COMMITMENTS. DESIGN REOUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA?
a.
Regulatory Guide 1.64 ( ANSI N45.2.ll-1974), " Quality Requirements for the Design of Nuclear Power Plant" b.
Regulatory Guide 1.9 Rev. O, " Selection of Diesel Generator Set Capacity for Standby Power Supplies" c.
Regulatory Guide 1.81, " Shared Emergency and Shutdown Electric Systems for Multi-Unit Power Plants" d.
SNP FSAR Section 8.3.1.2, "Onsite Power System Analysis" e.
SNP FSAR Section 8.1.5.3, " Compliance to Regulatory Guides and IEEE Standards" f.
10CFR50 Appendix A, " General Design Criteria 17 and 18,"
. ; yy, (07/07/71) 3 g.
10CFR50 Appendix B, Criterion II, " Design Control";
Criterion V, " Instructions, Procedures and Drawings,"
(06/26/71) h.
10CFR50.71, " Maintenance of Records, Making of Reports" 1.
IEEE 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Stations" j.
IEEE 308-1971, " Criteria for Class lE Power Systems for Nuclear Power Generating Stations" k.
IEEE 387.1972, " Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations" yhe.
1044d (10/21/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
243.0 (B)
SPECIAL PROGRAM REVISION NUMBER:
0
[
i.
PAGE 11 0F 11 3
]
APPENDIX A (cont'd) 3 l
7.
LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER j
DISCUSSIONS RELATED TO ELEMENT:
a.
Teleconference between I. Don-Doncow and T. Sarver, Bechtel, j
and P. Nesbitt, J. Hutson, and H. Frederick, TVA, (09/05/86) 14 b.
Teleconference between T. Sarver, Bechtel, and H. Frederick,
)
TVA, (09/19/86) h c.
Nesbitt, Hutson, TVA, Don-Doncow, Bechtel, meeting in Knoxville, TN, (08/21/86)
I L
P
_. t. a.
f..jf ;
Ii i
1 I
l 4
i l
' R q....
1044d (10/21/86)
l l
ECTG C.3 Attaciunent A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tractinz Docuanent ICATD)
INITIATION 1.
Isumediate Corrective Action Required: 0 Yes E No 2.
Stop Wort Reconumended: O Yes 5 No 3.
CATD No.
243.0 - SQN - i 4
INITIATION DATE
/0h7/a"-
5.
RESPONSIBLE ORGANIZATION:
DA/E 6.
PROBLEN DESCRIPTION: 5 QR O NQR pleu-r Mao /A'/tA yuux frsyman To WAt iMff -rfg snmanizwn A madPW '_t ap' cni/ in drMM SAS Al-A A-On 9 MA Vf Ade Y AffM t AMP 117sn.
I a
O ATTAC#_MENTS 7.
PREPARED BY: NAME
_ 7" be art M JdeT DATE: /#//7/M n
8.
CONCURRENCE: CEG-H
- 74. % W hi' M DATE: h t >-N 9.
APPROVAL: ECTG PROGRAN NGE.'
DATE:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
l l
O ATTACNNFNTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENC CEG-H:
DATE:
RP:
DATE:
l ECTG PROGRAN NGR:
DATE:
l i
VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
I SIGNATURE TITLE DATE p
e
- e ECTG C.3 l
Attachment A Page 1 of 1
~~'
Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION 1.
Isumediate Corrective Action Required: 0 Yes E No 2.
Stop Wort, Recomunended: O Yes E No 3.
CATL No.
2/S.o -SdDN-1 4.
INITIATION DATE 10 // 7 /st, 5.
RESPONSIBLE ORGANIZATION:
DXE 6.
PROBLEN DESCRIPTION: E QR O NQR
/*Ad Aw d fAau. fan EE -oos Ltds pe nser m n for nwr s nomra ranas Asus*>w.
-enn -r
_ns/s 1~ s ss ni esin eno r1% rwa 1.
fwasse/ s-147 -rArt fA1/11.A 71AA) s.t AAnVMM Asf
)*bFAF Y1am
-@- *T*
D_"M[gggf noss mr ns.c r.
O ATTACHMENTS 7.
PREPARED SY: NAME 7
.Cne - s
'tAL,
DATE:
/s/s 7/ma 8.
CONCURRENCE: CEG-H h"r IL8%* W DATE:
re.ti N 9.
APPR0iffi: ICTG PROGRAM NGR. '
DATE:
CORRECTIVE ACTION
!l 10.
PROPOSED CORRECTIVE ACTION PIAN:
(
t l
i
'l i
i l
r O ATTACHNENTS 11.
PROPOSED BY: DIRECTOR /NGR:
DATE:
l 12.
CONCURREN : CEG-H:
DATE:
f RP:
DATE:
ECTG PROGRAN NGR:
DATE:
VERIFICATION AND CLOSE00T l
13.
Approved corrective actions have been verified as satisfactorily ireplemented.
1 l
SIGNATURE TITLE DATE r g..
}
b l
t
~
ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Trackinit Document (CATD)
INITIATION 1.
Immediate Corrective Action Required: 0 Yes 5 No 2.
Stop Wort Recomunended: O Yes a No 3.
CATD No.
f M. d -SGA/- 2 4.
INITIATION DATE
/d//7 /86 5.
RESPONSIBLE ORGANIZATION:
M OAJF A4 w1mt, 6.
PROBLEN DESCRIPTION: E QR O MQR CAudrmaf Sm-f3-ss e J^=
rsrm.srussAt uus -rsnar isnm e
-rAAr suA Y 2-M "Y$1/>F)A/&
79 fff?
'rds 1A M -1M99{
AAMAdfC LAff Y)l]Af
'Thlf b/fsfL GMW12A T3FA *A JYLADY JTA71 l'A Pb9 A J1) Y K "Ta DA Yf.
A/d MWohMAMM Bf' JAJ/ A99s9ATM / DW YAJMAA" aNAA7en Af YAnA/_t JAs Ye B)hedA f/A/6 M r.:fbMAft
+/As AMMA/ /DFAtr/f/fD.
0 ATTarummTS 7.
PREPARED BY: NAME
-1~
Ams neer
%Aa E DATE:
io//7/mA m
8.
CONCURRENCE: CEG-H 1)h & W ' M DATE:
Id. RF +k 9.
APPROVAL: ECTG PROGRAN NGR. 8 DATE:
CORRECTIVE ACTION P-
. f, o,N.
10.
PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHNENTS 11.
PEOPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRE E: CEG.H:
DATE:
4A SRP:
DATE:
i ECTG PROGRAN NGR:
DATE:
l VERIFICATION AND CLOSE0tfT 13.
Approved corrective actions have been verJfied as satisfactorily implemented.
l l
l SIGNATURE IITLE DATE 9
l t
r
/
ENCLOSURE 2 i
t i
e r
M 1
l l
9
/
J
/
J
/
.