ML20215A738

Rev 2 to Sequoyah Element Rept 213.2(B), Electrical Procedures, TVA Employee Concerns Special Program

ML20215A738
Person / Time
Site:	Sequoyah
Issue date:	05/07/1987
From:	Shaun Anderson, Russell Gibbs, Parkinson J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215A652	List: ML20215A649 ML20215A738 ML20215A775 ML20215A797 ML20215A813 ML20215A837 ML20215A851
References
213.2(B), 213.2(B)-R02, 213.2(B)-R2, NUDOCS 8706170057
Download: ML20215A738 (24)

Text

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REPORT NUMBER: 213.2(B)

( TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 2 REPORT TYPE: SEQUOYAH ELEMENT TITLE: ELECTRICAL PROCEDURES (

' Inadequate Electrical Testing, PAGE 1 0F 23 Planning, and Engineering <

Participation, Deviation to Preoperational Test Acceptance Criteria REASON FOR REVISION:

1. TVA comments.

2. Revised to incorporate SRP/TAS comments, include chronology, address NRC questions, and combine Element 207.3 with this report.

PREPARATION PREPARED BY:

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[ CEG-H: $ f 'ff/# d/ g/fa/5>7

%0 {$0 SRP0surej Ju& -2297 SIGNATURE DATE y SIGNAT y DATE APPROVED BY: }

[ / '

- N/A DATE v ECSP' MANAGER D TE MANAGER OF NUCLEAR POWER

• SRP Secretary's signature denot s S. ch hgggg g ,sq RO 0

TVA EMPLOVEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 l

PAGE 2 0F 23 i

1. CHARACTERIZATION OF ISSUES:

Concerns: Issues:

WI-85-100-018 a. The electrical test program l1

" Electrical testing and planning and planning are-inadequate.

is inadequate. Engineering I j

either does not address testing b. Engineering participation or de s so inadequately. Accep- in the program in providing l acceptance criteria is inadequate. Ii tance criteria for testing is 1 inadequate to non-existent."

c. Engineering participation-IN-86-077-001 regarding the conduct of the tests and

" Deviations to pre-op test review of the test results is inadequate.

acceptance criteria were accepted by ENDES without d. Deviations to preoperational test written justifications. It acceptance criteria were accepted cannot be determined by the by Engineering without justification.

documentation in the test (CI indicates written justification ]

package whether or not a is necessary.) Documentation of the detailed evaluation of the Engineering evaluation of preopera-

~.

deviation was performed by tional test deviations (deficiencies)

') was inadequate.

g.y ENDES." This concern applies to all pre-op tests. (Unit 1)

)

Details know to QTC, withheld due to confidentiality. CI has no further information. NUC POWER concern.

N0 X

2. HAVE ISSUES BEEN IDENTIFIED IN ANOTEER SYSTEMATIC ANALYSIS? YES Identified by N/A Date N/A Documentation Identifiers:

N/A 20840-3 (05/07/87)

J

TVA EMPLOYEE CONCERNS REPORT NUMBER: '213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 23 I

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

Na further information is available. [

4. INTERVIEW FILES REVIEWED:

Files WI-85-100 and IN-86-077 were reviewed, and no additional unreviewed information for Sequoyah (SQN) regarding these concerns j was identified. j i

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

1 See Appendix A. l f

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?

See Appendix A.

{}

\;-

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

See Appendix A.

8. EVALUATION PROCESS:

a. Reviewed available transcripts of the Nuclear Regulatory Commission (NRC) investigative interviews for additional information regarding these concerns. i

b. Reviewed design criteria,' regulatory requirements, scoping [ l documents, Final Safety Analysis Report (FSAR), and any other I j applicable documents to establish extent of past and current '

SQN preoperational testing requirements.

c. Reviewed Construction, QA/QC, Operations, and Material Control repnrts for TVA Employee Concerns Special Program for I applicability.

1 20840-2 (05/07/87) I l

TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 23 I

d. Interviewed cognizant TVA personnel and reviewed past and current test programs (preoperational and postmodification) for compliance with regulations, general design criteria, and licensing commitments,

e. Assessed the results of the above evaluation steps in determining the adequacy of Engineering's eva'.uation and the documentation of " accept-as-is" dispositions for preoperational test deficiencies,

f. Reviewed sample preoperational test procedures and results I for adequacy of:

o Acceptance criteria l 1

o Resolution of test closure o Followup for test exception closure o Engineering evaluation of test deficiencies l

\

n .)

. g. Reviewed sample postmodification test procedures and results for adequacy same as "f" above. l l

9. DISCUSSION, FINDINGS, AND CONCLUSIONS:

Chronology:

06/27/70: AEC issues 10 CFR 50, Appendix B 06/06/74: ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants, is issued 06/10/74: TVA issues EN DES-EP 6.01, R0, Preoperational Testing l Documents - Processing 09/19/75: TVA memo from Patterson to Those Listed establishes need for electrical discipline coordination of certain preoperational tests 06/76: TVA commits to Regulatory Guide 1.64, R2, Quality Assurance Requirements for the Design of Nuclear Power Plants, which endorses ANSI N45.2.ll-1974 20840-2 (05/07/87) i

TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(8)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 23

)

1 1

NRC issues Regulatory Guide 1.68, R1, Initial Test l 01/77: l Programs for Water-Cooled Nuclear Power Plants I

i 08/78: NRC issues Regulatory Guide 1.68, R2, Initial Test j Programs for Water-Cooled Nuclear. Power Plants 1

03/01/79: TVA memo from Patterson to Those Listed re-emphasizes need for electrical discipline coordination of certain preoperational tests 02/27/80: TVA memo from Pierce to Ballentine to evaluate all approved unimplemented changes including open preoperational test items 02/29/80: TVA memo from Dunham to Fox determines that unimplemented items would not affect Unit 1 safety )

I 02/09/81: TVA memo from Raulston to Those Listed indicates a deficiency in the electrical discipline review of preoperational tests on Unit 2 and identifies corrective action

- ) 06/09/81: TVA issues Procedure EN DES-EP 6.03, Post-Modification

Testing Documents - EN DES Processing After Issuance of Operating License, R3, 07/01/81: TVA me w from Sprouse to Green determines that {

unimplemented items would not affect Unit 2 safety J 03/23/82: TVA memo from Green to Sprouse proposes to transfer all open preoperational test deficiencies to postmodification test (PMTs) 07/28/82: TVA memo from Raulston to Campbell furnishes PMT numbers for tracking unresolved preoperational test items ,

10/22/83: Deficiency log is issued to provide a preoperational test program history 06/28/85: TVA memo from Vineyard to Raulston provides scope of work for establishing the status of the SQN preoperational/postmodification test program and for developing an administrative / procedural process to handle the program 20840-2 (05/07/87)

m s

TVA EMPLOYEE' CONCERNS REPORT NUMBER: '213.2(B)-

SPECIAL PROGRAM' REVISION NUMBER: '2 PAGE 6-0F 23 j j

~i 07/01/85: TVA issues Procedure NEB-DI 125.03, Preoperational-Testing Documents - Processing (supersedes EN DES EP-6.01) 07/01/85: TVA issues Procedure NEB-DI-125.05, Postmodification.

Testing Documents'- OE Processing after. Issuance of. 1 Operating License (supersedes EN DES-EP 6.03) 08/13/85: TVA' receives Employee Concern IN-86-077-001 11/85: TVA receives ~ Employee Concern WI-85-100-018 -

11/14/85: TVA memo from Cottle to Parris addresses performance of'

.an independent assessment to' prepare;for returning the units to service Discussion:

~

On the basis of comments in the transcript of the NRC' investigative interview made by the concerned individual regarding inadequate electrical testing and planning, the evaluation team interpreted the concern as inadequacies in the Sequoyah preoperational test:and 9 postmodification test programs.

. .gf These employee concerns were raised at Watts Bar Nuclear Plant'(WBN) and are considered generically applicable to Sequoyah (SQN).

9.1 OBJECTIVES OF TEST PROGRAMS The objectives of the test programs as they relate to these concerns are contained in the following:

o 10 CFR 50, Appendix B, " Quality Assurance Criteria for . ]

Nuclear Power Plants and Fuel Reprocessing Plants" (App. A, 5.bbb)

Criterion "XI, Test Control":

"A test program shall be established to assure that .

- all testing required to demonstrate-that structures, systems, and components will perform satisfactorily.

in service is identified'and performed.in accordance  ;

j

.with written test procedures which incorporate the H requirements and' acceptance limits contained in applicable design documents. The test program shall ,

include, as appropriate, ~. . . preoperational tests,

... Test results shall be documented and evaluated to assure that test requirements have been satisfied."

,i 20840-2 (05/07/87) I l

TVA EMPLOYEE CONCERNS REPORT. NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 23 Criterion "III, Design Control":

1)

" . . . measures shall include provisions to assure that appropriate quality standards are specified . . . and that deviations from such standards are controlled."

2) "The design control measures shall provide for 1 verifying or checking the adequacy of design, l such as by the performance of design reviews, by l the . . . performance of a suitable testing l program."

3) " Design control measures shall be applied to items such as the . . . delineation of  ;

acceptance criteria for inspections and tests."  ;

1 Criterion "V, Instructions, Procedures, and Drawings": l

. . . procedures . . . shall include I appropriate quantitative or qualitative acceptance criteria for determining that 9} important activities have been satisfactorily accomplished. "

o Regulatory Guide 1.68, " Initial Test Program for Water-Cooled Nuclear Power Plants," R1, R2 (App. A, 5.b and 5.ccc)

"l) To provide additional assurance that the facility has been adequately designed and, to the extent practical, to validate the analytical models and to verify the correctness or conservatism of assumptions used for predicting plant responses to anticipated i transients and postulated accidents. l

2) To provide assurance that construction and installation of equipment in the facility have been j; accomplished in accordance with the design."

9.2 REVIEW 0F SYSTEMS l] l With these regulatory objectives established, the evaluation team reviewed a sample of nine systems ( App. A, 5.e) to determine the adequacy of the Sequoyah preoperational test program. The nine systems were selected to constitute a ' stratified" sample of the work of the various design discipline teams. They were selected to I

include a nuclear steam supply system (NSSS), an air system, severa? ;1 20840-2 (05/07/87) i

TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM i

REVISION NUMBER: 2 PAGE 8 0F 23 liquid systems, several electrical systems, and a radiation monitoring system. They were chosen because of the size and ,

complexity of the systems, their significance to safety and their electrical engineering involvement. The selected systems also include systems whose design required coordination between the various design disciplines. The evaluation team believes that this sample emphasizes those areas which are most likely to contain  ;

errors. )

The first step in a preoperational test, in accordance with l EN DES-EP 6.01, "Preoperational Test Documents - Processing" {

(App. A, 5.hh, 5.k), is to prepare a test scoping document. This l document was superseded by Procedure NEB-DI 125.3 (App. A, 5.fff), ,

which is a marked version of EN DES-EP 6.01 with minor changes to  !

reflect organizational name changes. Test scoping documents are l i

I preptred by the Office of Engineering Design (EN DES) Test Representative and are intended to completely describe the l preoperational test to be performed for each system. In addition, 1 i

scoping documents are intended to reflect the commitments to the various applicable regulatory requirements and acceptance criteria stated in design documentation and the FSAR. Review of the scoping {

documents for the nine systems determined that licensing commitments s g} were properly included and acceptance criteria per FSAR adequately reflected. In general, the scoping documents were prepared and structured in accordance with EN DES-EP 6.01 requirements and l provided adequate references to design documentation for functional requirements.

Using the scoping documents, the p)reoperational test director, Div instructions (PTIs). For the nine systems reviewed, the evaluation i team determined that the PTIs were based on the scoping document and )'

the requirements in Procedure adequately follow, EN DES-EP 6.01.

step-by-step,ferences They include re to system design criteria, I the FSAR, technical specifications, design drawings, and other applicable design requirements.,

Once PTIs are completed, Engineering reviews revision 0 (RO) of each PTI to ensure that the scoping document and applicable FSAR commitment are adequately covered. At this time, Engineering either submits comments to the preoperational test group or approves RO.

If Engineering comments are extensive, the preoperational test group prepares a new revision of the PTI and resubmits it for review.

Engineering approves the PTI only after all comments have been resolved and implemented. The evaluation team determined that this I approval cycle for the nine systems was properly carried out and Engineering adequately ensured that requirements and comments were I

properly resolved and implemented in the PTIs.

2084D-3 (05/07/87)

i TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 23 Prior to performing any preoperational testing, the test director must obtain from the Engineering Test Representative approval of the i test drawings and an evaluation of the impact of any outstanding Engineering Change Notices (ECNs) on testing. The Engineering Test Representative reviews and verifies that this approval process is properly documented in the PTIs and complies with EN DES-EP 6.01." ,

J After conducting the preoperational test, the test director prepares  !

a test results package for Engineering approval. Engineering, under j the coordination of the Nuclear Engineering Branch (NEB), performs a comprehensive review and analysis of test deficiencies, in l accordance with engineering procedures, to assure that all needed  ;

4 safety evaluation documents are addressed.

I The Preoperational Test Deficiency Report documents any significant '

deviations from established acceptance criteria for structures, systems, and components important to safety that are being l preoperationally tested to determine their ability to accomplish  !

their safety functions.

~,

The Engineering Test Representative reviews the entire test results i' j package, and " full approval" is given only if there are no open

~) exceptions or unacceptable deficiencies. Unacceptable deficiencies are deficiencies that have not been satisfactorily resolved. Full approval may also be given if only acceptable deficiencies exist.

Acceptable deficiencies are deficiencies that have been  ;

satisf actorily resolvec'. Upon completion of this review and j resolution of all test deficiencies, Engineering certifies by i memorandum that the product or system tested performed in accordance with the acceptance criteria. The test results package, with memorandum, is then transmitted to NUC PR.

l 9.3 EVALUATION TEAM REVIEW 0F RESULTS ,

i

?ssue "c".

The evaluation team reviewed nine preoperational test and two postmodification test results packages applying the following considerations:

o Engineering participation in preoperational tests f i

o Adequacy of the actual tests compared to the Engineering j specified scope of testing and comparison of the test j results with the specified acceptance criteria o Evaluation of " closed" test exceptions and/or deficiencies  ;

)

I 20840-2 (05/07/87) l

TVA EMPLOYEE CONCERNSI ~ REPORT NUMBER: 213'.2 (B) {

SPECIAL PROGRAM REVISION NUMBER: -2' f

'l PAGE 10 0F 23 J o ~ Evaluation of all' "open" or unresolved test exceptions and/or deficiencies o Certification that the system or component did functionally, operate in accordance with the acceptance criteria No indication was detected by the evaluation' team of. inadequate engineering participation during the. testing of.the nine systems.

Also, test results were properly recorded, exceptions and/or deficiencies identified and sent to Engineering for evaluation, and'  :

test results packages submitted to and reviewed by-Engineering for approval. The deficiencies and/or-exceptions identified in~the test package were adequately resolved except for the following:

l o For Test TVA-1, although Engineering . indicated .qfter ~

review of'the test results that deficiencies DNi-7 -i (PT2 -352), DN-9 (PT-417), DN-15 (PT-418), DN-20 .

(PT-352), and DN-16 required resolution prior to initial-criticality, resolution and closure did not occur until after initial criticality. Determination was made,

', however, by Engineering that no plant. safety implications

) existed. Review of these deficiencies by the evaluation y/ team determined that their original classification as

" required prior to initial criticality" was not correct, For Test TVA-1, although Engineering was aware of the Iy o

resolution of deficiencies PT-386 and-PT-427, it failed to issue the required closure forms.

Notes: 1. D,3 is a test deficiency found during the test. It may or may not require design engineering resolution; therefore, every PT;will have a ,

corresponding DN except for PT.s assigned after the test is completed l and closed. .

2. _P.J is a test deficiency that required design engineering resolution so that the site personnel can successfully complete the test. Also, it l ,

could be a generic deficiency that was found in a different plant and l required investigation to determine applicability after test completion.  ;

i ,

20840-2 (05/07/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)  !

I SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 11 0F 23 o For Test TVA-30, deficiency number PT-250 was assigned by I error to a suggested modification. Although the error was recognized, it was not corrected and, therefore, the deficiency remained outstanding until 1986. J o For Test TVA-18A, " Essential Raw Cooling Water," l Engineering erroneously gave full approval to the test results although deficiency D-11 (PT-85) was outstanding.

The deficiency, however, had been classified as not required for any major milestone (e.g., fuel load, initial criticality, etc.) as it.did not affect plant safety.

o For Test TVA-33, although the test deficiency resolution I (DN-6 and DN-7) had been submitted to Engineering for ,l review and approval, Engineering overlooked PT-298 as being' associated with these deficiencies, and PT-298 was  ;

outstanding for several years (1979 to 1986). i I'

o For Test TVA-41, the evaluator found that deficiency 0-19 l was dispositioned by maintenance request (MR) prior to review by Engineering; however, no.MR number was i identified and no record of the sign-off sheet or closure g/

} form was included in the test results package, i

j i

The evaluation team found that all problems identified above had no p1 ant safety implications and have been corrected. The program that

~

I detected and corrected these problems evolved as described below. )

l TVA memo from Pierce to Ballentine (App. A, 5.00; 02/27/80) indicated that Engineering will make an evaluation of all changes l approved but not implemented and of unimplemented original design -;

for Unit 1. This evaluation will be performed to determine that the l l unit is safe for startup with the unimplemented items. Included in those items were open preoperational test items.

TVA memo from Dunham to Fox (App, A, 5.pp; 02/29/80) determined that the unit is safe for startup with the unimplemented items.

TVA memo from Sprouse to Knight (App. A, 5.qq; 06/06/80) refers to the development and drafting of an engineering proced tre which evolved into EN DES-EP 2.13 (App. A, 5.hh). This pro edure addresses evaluation of unimplemented design items. inis procedure also employs methoos developed and used by Engineering to evaluate I

SQN ECNs.

A similar evaluation was made on SQN Unit 2, and TVA memo from Sprouse to Green (App. A, 5.tt; 07/01/81) determined that the unit

' is safe for fuel loading with the unimplemented items.

20840-2 (05/07/87)

9 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 3 PAGE 12 0F 23 In connection with Engineering' participation in the close-out of the preoperational test deficiencies / exceptions and incomplete tests, TVA memo from Green to Sprouse (App. A, 5.ii; 03/23/82) proposed to transfer all open preoperational test deficiencies / exceptions by systems to a postmodification test (PMT) and to reissue all incomplete preoperational tests as PMTs. These proposed actions would allow the close-out of the existing preoperational testing j

program and provide a means for completing existing incomplete preoperational testing requirements through an established PMT program. Memo from Sprouse to Green (App. A, 5.jj; 05/12/82) concurred with the proposed action and indicated that Engineering would review incomplete preoperational test activities to determine which of these activities were to be included in the program and which could be closed out. ,

TVA memo from Raulston to Campbell (App. A, 5.kk; 07/28/82) furnished PMT numbers for tracking unresolved preoperational test items. On 10/22/83, a deficiency log was issued providing a preoperational test program history. This log included the status for each deficiency as of that date. A program concerning postmodification and remaining open preoperational . test items was

~- initiated for Sequoyah on 04/18/85 (Preop-278) . TVA memo from

)

. ,/ Vineyard to Raulston (App. A, 5.mm; 06/28/85) provided a scope of work by Office of Engineering / Nuclear Engineering Branch (0E/ NEB)  :

for establishing the status of the SQN PRE 0P/PMT program and for developing an administrative / procedural process to handle this program. This ultimately resulted in the current SQN program for j identifying, tracking, and resolvina test deficiencies / exceptions. <

Also, TVA memo from Cottle to Parris (App. A, 5.11;11/14/85) addressed the performance of an independent assessment and resulting efforts initiated by Sequoyah site management in preparation for ,

j returning the units to service. One item requiring correction prior to restart is a review of the outstanding.preoperational test open ll items to determine whether their status constitutes an unreviewed safety question. .The TVA evaluation concluded that there are no apparent weaknesses, either programmatic or personnel related, which would prevent the return of Sequoyah Units 1 and 2 to service.

The original procedure established for handling postmodification testing documents was Engineering Procedure EN DES-EP 6.03 (App. A, 5.uu). This procedure has recently been replaced by Procedure NEB-DI 125.05 (App. A, 5.dd). Other procedures (App. A, 5.g, 5.1, 5.j, 5.cc) have also been issued to cover the Division of Nuclear Engineering (DNE) processing of postmodification testing documents for modification to tae equipment and systems. The current procedures establish administrative controls for handling test

' deficiencies identified during the conduct of tests. The procedures 2084D-2 (05/07/87)

I TVA EMPLOYEE CONCERNS' _' REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM _

REVISION NUMBER: 2 i

PAGE 13 0F 23-

. . =

also describe how to document, report, and resolve test deficierities f discovered during testing activities. In addition,_a computer-program (App. A, 5.h) has been established for use as a management tool. This program tracks all open deficiencies and exceptions to 3 prevent recurrence of exception / deficiency closure problems. l l To verify compliance with current-procedures mentioned above, the evaluation team reviewed two postmodification test programs, PMT-50, i Pressurizer PORV Test and PMT-38, Containment Isolation System l (App. A, 5.f). The review found that the tests were in accordance' '

with postmodification testing documents EN DES-EP 6.03 and NEB-D1 125.05. No deficiencies were identified regarding preparation of scoping documents, postmodification test instructions (PMTIs), i conduct of tests, coordination between Engineering and the test i group, resolution of test exceptions / deficiencies, and approval of i

l test results.

The evaluation team has also reviewed two inspection level IV l violations that were identified in early 1984 by the NRC at the Watts Bar Nuclear Power Plant. The first violation, 390/83-51-01 i and 391/83-40-01, concerned failure to follow procedures during

', _} performance of preoperational Test TVA-14E " Diesel Generators and

_/ Supporting Auxiliaries (Diesel Generator Functional Tests)." This was also identified as a generic nroblem concerning the inadequate review and documentation of preoperational test results. On the (

basis of the NRC review of the corrective action taken by TVA.

(correction of minor documentation problems), the violation was closed in accordance with NRC letter to TVA (App. A, 5.vv; .

t 03/11/85). The second violation, 390/83-51-02 and 391/83-40-02, concerned inadequate evaluation and documentation of test results l for preoperational Test TVA-14E. This was also identified as a generic concern along with the review of test data packages. On the basis of the TVA corrective action (retraining of certain test personnel) and the results achieved, NRC concluded that the inadequate reviews appeared to be limited to a few test  :

representatives, and NRC letter to TVA (App. A, 5.ww; 04/03/85) .!

closed the second violation. The' documentation of the DNE's review j of test deficiencies are further discussed in the following i paragraphs.

Issue "d".

The evaluation team reviewed all preoperational test deficiency reports for SQN Units I and 2. The reports were reviewed to  ;

determine if objective evidence of engineering evaluations for all

" accept-as-is" dispositions had been documented.

A total of 800 preoperational test deficiency reports (App. A, 5.hhh) were reviewed, of which 337 were dispositioned 2084D-3 (05/07/87)

i

TVA EMPLOYEE l CONCERNS ' REPORT NUMBER: 293.2(B)

SPECIAL' PROGRAM REVISION NUMBER: 1 PAGE 14 0F 23-e.

' accept-as.is.(-These'337reportswerethenreviewedfurtherto determine if objective evidence-of engineering evaluat fon ant decisions was apparent.

It~was determined that' exceptions.and/or. defic'iencie's had been identified and sent to Engineering for evaluation and approval.: The deficiencies and/o.r exceptions. identified in the test. packages were resolved by EN DES and the Test Director. The records ir.dicate that all " accept-as-is" dispositions' of'preoperational tests were -

supported with written justification by EN DES as required by TVA procedures EN DES-EP 6.01 or NEB-DI 125.03.-

9.4 INTERDISCIPLINE C0CRDINATION The need for interdiscipline coordination of the.preoperational test program was recognized by TVA and documented'in a memo from D..R.

Patterson to Those Listed ( App. A, 5.xx; 09/19/75). This memo identified nineteen electrically or.iented . systems ( App. A, .5.yy),

and directed that copies of test instructions, test results, and test deficiency documentation be'provided'to the Chief of the Electrical Engineering Branch (EEB)' for his review and approval of

)

all test results and test deficiencies. The need for this s_p coordination was again emphasized by a TVA memo from D. R. Patterson to Those Listed (App. A, 5.zz; 03/01/79) and placed the responsibility for obtaining EEB concurrence on the individual test representative. A TVA memo from J. A.-Raulston to Those Listed (App. A, 5.aaa; 02/09/81) indicates that fourteen systems on Unit 2 were not reviewed by EEB in accordance with the initial policy memo and identifies corrective action.

On the basis of the uncertainties noted in the above memos that proper coordination with EEB occurred for these systems,;the evaluation team reviewed all test instructions and test results for the nineteen systems on Unit 1 and fourteen' systems on Unit-2 for evidence of electrical' discipline review and approval. In all cases, except Test TVA-22, " Auxiliary Feedwater System," evidence was found to substantiate electrical discipline approval. Although this review did not establish complete . compliance with the policy memo, in all cases where EEB approval was not noted, project l electrical engineering approval was evident. Since the primary concern is that an electrical engineering review be performed for

these systems, the engineering organization which provides this review is not relevant.

With. regard to the Auxiliary Feedwater (AFW) System, the purpose of this-test, similar to all other liquid and air system preoperational tests, is to demonstrate that mechanical design requirements (e.g.,

flow, head, valve operation) have been met, and is not intended to demonstrate adequacy of electrical parameters (e.g., voltage, 2084D-3 (05/07/87)

9 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 15 0F 23 current. frequency) These parameters aro demonstrated, as require., by other electrical preoperational tests or tests perfconed prior to system turnover for preoperational testing. This is consistent with industry practice, and, therefore, electrical review and approval of mechanically o'riented. test instructions are not' required. Electrical interface relative to mechanical system test programs would typically occur only .if an electrical design modification is required to meet a mechanical design parameter. The-evaluation team has reviewed the AFW test instruction and has confirmed that the parameters monitored are, indeed, mechanical.ly oriented.

In addition 1 the above, the evaluatien team reviewed the titles of all test instructions to independently judge which system tests would normally require an electrical engineering discipline review.

In addition to the above syst, ems, the following systems would normally require this "w and approval:

TVA-11 Plan m?m kions TVA-14D Pim .m . Battery System TVA-31 R itoring-Systems '

TVA-41 Co tru, .c Isolation TVA-56 ESFAS E .,et All of these additional systems were confirmed to have had electrical discipline participation.

On the basis of the above, the reviews and approvals of preoperational test documentation are typical for the nuclear industry, and ,

j interdiscipline coordination is considered adequate.

l Findings:

a. The overall electrical preoperational and postmodification test ll programs were found to be adequatt,

b. On the basis of the informatfor' reviewed, Engineering participation in the program for providing hcceptance criteria is adequate. ' PTIs, t.

PMTIs, and acceptance criteria were properly reviewed and documented by TVA Engineering.  !

I The following problems regarding Engineering participation in the l

c. 2 review of test results were identified-o Engineering was not properly advised in a timely manner of a milestone change for the completion of test deficiencies or of completion and closure of certain test deficiencies.

i 2084D-2 (05/07/87)

4 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 16 0F 23 o A suggested modification was assigned a deficiency number by mistake.

o Engineering erroneously gave full approval for a test results l

package with an outstanding deficiency.

l o A deficiency for a test results package was not closed out, although resolution of the deficiency was submitted to Engineering.

o Engineering received a test results package erroneously indicating an open deficiency that had already been resolved.

Although the above items remained open for several years after completion of the preoperational tests, they are now closed and an adequate system f was in place at the time of this evaluation to assure the resolution and closure of similar items.

d. Deviations (deficiencies) from preoperational test acceptance criteria were accepted by EN DES in accordance with TVA procedural requirements contained in EN DES-EP 6.01. Supporting documentation of EN DES acceptance of preoperational test deficiencies .eas adequate to determine the extent of the Engineering evaluation performed.

Conclusions:

The concern about adequacy of electrical systems and equipment testing programs and about Engineering's participation in them has some validity but little significance. Engineering input to scoping documents and to preoperational and postmodification test ,

instructions is adequate to furnish acceptance criteria. A few test  !

I deficiencies and exceptions were not administrative 1y followed through, but none of them were items that could compromise safe l plant operation. Although these items remained open for several years, they have been adequately resolved and closed. To prevent il recarrence of these problems, TVA has established an internal computer tracking system for test deficiencies. This will ti f acilitate the proper identification of their status, resolution, and closure.

On the basis of the investigation of the 337 preoperational test deficiency reports with ' accept-as-is' dispositions, the evaluation team concluded that documentation included in each test package was adequate to determine that Engineering provided and recorded all resolutions for each deficiency. Documentation indicated that all

' accept-as-is' dispositions of preoperational test deficiencies (deviations from acceptance criteria) were supported with written justification of the evaluation by EN DES as required by procedures. {

2084D-2 (05/07/87)

l TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 17 0F 23

10. CORRECTIVE ACTION Corrective action has been implemented and no further corrective i action is required. I l

i ew' l

4 l

l 2084D-2 (05/07/87)

l p

TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(P)-

SPECIAL PROGRAM REVISION NUMBER: 2  !

PAGE 18 0F 23 APPENDIX A i

5. DOCUMENTS REVlEWED RELATED TO THE ELEMENT: l

a. General Design Criteria (10 CFR 50, App. A Criteria 17 and 18)

b. ' Regulatory Guide 1.68, " Initial Test Program-for Water-Cooled Nuclear Power Plants", R1 (01/77)- .I

c. Regulatory Guide 1.108, " Periodic Testing of Diesel Generator ,

Units Used As Onsite Electric Power Systems at Nuclear Power s Plants", R1 (08/77) l

d. FSAR, Sections 8.3.11 and 14.1.1

e. Sample of preoperational test results package':

TVA-15 and 15RT " Vital 120-V AC Power System" .

TVA-16 " Vital 125-V AC Power System"  !

TVA-41 " Containment Isolation System"

_ ., W-2.2 " Residual Heat Removal System" TVA-13B1 "Onsite AC Distribution System"

,, TVA-1 " Emergency Gas Treatment System" TVA-18A " Essential Raw Cooling Water System" TVA-30 " Condenser Vent System" TVA-33 " Radiation Monitoring System"

f. Sample of Post Modification Test Procedures and Results (PMT-50) " Pressurizer PORY Test," and (PMT-38) " Containment Isolation System-Containment Vacuum Relief Isolation Valve"

g. Test Scoping Documents and Instruction (NEP-10.4) R0, l (07/01/86)

h. Internal computer program for tracking open deficiencies and exceptions, " Report of Modification Testing by PMT No.,"

(03/25/80) 9

i. Sequoyah Engineering Procedure (SQEP)-14, R0, " Assembly end Evaluation of Electrical . Test Results," (05/15/86) J

j. Nuclear Engineering Procedure (NEP)-10.3 R0, " Testing,t' (07/01/86) 4

k. Division of Engineering Design - Engineering Procedure (EN DES-EP) 6.01, R5, "Preoperation Testing Documents - )

Processing," (01/12/83) 2084D-3 (05/07/87)

l l

TVA EMPLOYEE CONCERNS REPORT NUMBERL 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 19 0F 23 1

APPENDIX A (Cont'd)

1. Preoperational, Procedure No. 5, "PMT Identification and Handling", (no revision number or date) l' 3 1

m. Preoperational. Procedure No. 7 (handling test results l1 packages),(03/15/84) l

n. EN DES Test Representative Handbook; R2, (4/83). ]

o. TVA memo from Raulston to Campbell, " Post Modification Test Program - Post modification Test PMT-5," (02/28/83) ]

p. TVA memo from Vineyard to Rankin,-" Post Modification Test Program - Post modification Test PMT-22A," (07/03/85)

q. TVA memo from Raulston to Dewease, " Post Modification Test l PMT-5," (02/09/81)  !

4

r. TVA memo from Raulston to Campbell, " Post Modification ,

l

- .. Testing of the Additional Diesel Generator System," (05/26/82) i l

._, s. TVA memo from Rankin to Vineyard, " Review of Test Results,"

(12/19/85)

t. TVA memo from Rankin to Vineyard, " Post Modification Test Program - Review of Test Results," (12/30/85)

u. TVA memo from Patterson to Green, " Interim Review and Approval of Preoperational Test Results TVA-18A," (09/13/79)

v. TVA memo from Dilworth to Green, " Final Review and Approval of Preop. Test Results - Preop. Test TVA-33," (12/20/79) q

w. TVA memo Rankin to Vineyard, " Post Modification Test Program

- Review of Test Results," ~(12/16/85)

x. TVA memo from Vineyard to Rankin, " Final Review and Approval j of Post Modification Test Results PMT-TVA-33," (01/02/86) l i

y. TVA memo from Rankin to Vineyard, " Post Modification Test j Program - Review of Test Results," (12/12/85)

z. TVA memo from Vineyard to Rankin, " Final Review and Approval of Post Modification Test Results PMT-TVA-30," (01/08/86) aa. TVA nemo from Patterson to Green, " Final Review and Approval 1 of Preop. Test Results - Preop.' Test TVA-30," (10/16/79) 2084D-3 (05/07/87)

, TVA EMPLOYEE-CONCERNS REPORT NUMBER: 213.2(B)-

SPECIAL' PROGRAM REVISION NUMBER: 2 PAGE 20 0F 23 APPENDIX A'(Cont'd) bb. TVA memo from Featherston to Nuclear Enginee' ring Branch File, "SQN/WBN Nuclear Plant - Diary Note No. 56," (06/28/84) cc.- TVA Nuclear- Quality Assurance Manual, Part II,-Section' 4.9, R0,

" Handling of.CSSC Test Deficiencies," (06/20/86) >

dd. " Post Modification Testing Documents - OE Processing After Issuance of Operating License," NEB-DI-125.05, R0, (07/01/85),

supersedes EN DES-EP 6.03 ee. " Control of Modifications," NQAM, Part V,-Section 2.4 (ID-QAP-2.4),(07/10/85) ff. Letter from B. J. Youngblood, . NRC, .to S. A. White, TVA, with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN, (06/25/86)'

e gg. Division of Engineering Design - Engineering Procedure i (EN DES-EP) 6.01, R3, "Preoperation Testing Documents -

%. . Processing," (05/25/79) hh. Division of Engineering Design - Engineering Procedure (EN DES-EP) 2.13, R3, " Initial Fuel Loading Safety Evaluation -

Handling," (11/29/84) ii. TVA memo from Green to Sprouse, "Preoperational Testing Program ,

Phasecut," (03/23/82) i jf. TVA memo from Sprouse to Green, "Preoperational and NCS j (Noncritical System) Testing Programs Phasecut," (05/12/82) -

kk. TVA memo from Raulston to Campbell, "Preoperational Test Program Phasecut,"-(07/28/82)

11. TVA memo from Cottle to Parris, " Operational Readiness Review," -]

(11/14/85) mm. TVA memo from Vineyard to Rankin, "Preoperational (PRE 0P) Test '

Program - Scope-of-Work Proposal," (06/28/85) nn. Document Routing / Task Management Assignment .TVA Number PREOP-278  ;

oo. TVA memo from Pierce to Ballentine, "EN DES Certification for Fuel Loading," (02/27/80) 2084D-2 (05/07/87)

. .TVA EMPLOYEE CONCERNS REPORT NUMBER:' 213.2(B).

SPECIAL PROGRAM

-REVISION NUMBER: 2 PAGE 21 0F 23 i APPENDIX A (Cont'd) pp. TVA memo from Dunham to Fox, "EN DES Certification for Fuel Loading," (02/29/80) qq. TVA memo from Sprouse to Knight,:"0EDC Audit MBO-4," (06/06/80) rr. TVA memo from Cantrell to Ballentine and Stack, "EN DES Certification'for Fuel Loading," (06/12/81) ss. TVA memo from Stack to Cantrell " Status of Construction Items Required for Fuel Loading," (06/16/81) tt. TVA memo from Sprouse.to Green, "EN DES Certification for Fuel Loading," (07/01/81) uu. Division of Engineering Design - Engineering Procedure (EN DES-EP) 6.03, R3 "Postmodification Testing Documents - EN DES Processing' After Issuance of Operating License," (06/09/81)

'e vv. Letter from Varrelli, NRC, to Parris, TVA, " Report Nos.

50-390/85-10 and 50-391/85-10," (03/11/85) v ww. Letter form Varrelli, NRC, to Parris, TVA, " Report Nos.

50-390/85-19 and '60-391/SM 7," (04/03/85) xx. TVA memo from D. R. Patterson to Those Listed, " Electrical Engineering Branch Review of Electrical and Instrumentation in Control Systems Preoperational Test," (09/19/75)'

yy. Preoperational test documentation requiring electrical review:

1 TVA-12 TVA Offsite Power Systems  !

TVA-13 Onsite AC Distribution System j TVA-15 Vital 120 V AC Power System 1 TVA-16 Vital 125 V DC Power System 'J TVA-22 Auxiliary Feedwater System l TVA-36 Emergency Lighting System W-8.1 Reactor Protection System Time Response W-8.2 Reactor Protection Operational Test W-8.3 Engineering Safety Features Actuation System Operational Tests W-8.4 Control System Tests for Turbine Run Back W-8.5 Reactor Plant . System Set Point Verification .

W-10.1 Automatic Reactor Control l W-10.2 Automatic Steam Generator Level Control W-l l .1 Nuclear Instrumentation System W-il.3 Incore Thermal Coupler and'RTD Cross Calibration t

2084D-2 (05/07/87)-

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]

TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 22 0F 23 APPENDIX A (Cont'd) )

W-ll.5 Preop Testing of Computer W-ll.6 Computer Data Printout Verification W-il.7 Calibration of Steam and Feedwater Flow W-12.2 Annunciator Equipment Checkout zz. TVA memo from D. R. Patterson to Those Listed, "Preoperational Testing Program - Electrical Engineering Branch Review,"

(03/01/79) aaa. TVA memo from J. A. Raulston to Those Listed, "Preoperational Testing Program - Electrical Engineering Branch Review,"

(02/09/81) bbb. 10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" ccc. Regulatory Guide 1.68, " Initial Test Program for Water-Cooled Nuclear Power Plants," R2, (08/78) ddd. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76) eee. ANSI N45.2.ll-1974, " Quality Atsurance Requirements for the Design of Nuclear Power Plants" fff. NEB-DI 125.03, R0, "Preoperational Testing," (07/01/85),

supersedes EN DES-EP 6.01 ggg. OEP-13, R0, " Testing," (04/26/85) ,

hhh. Deficiency Reports PT-001 Through PT-800 i I

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER j APPLY OR CONTROL IN THIS AREA?  ;

l

a. General Design Criteria (10 CFR 50, App. A Criteria 17 and 18) {

b. Regulatory Guide 1.68, " Initial Test Program for Water-Cooled )

Nuclear Power Plants," R2, (08/78)

c. Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units Used As Onsite Electric Power Systems at Nuclear Power Plants," R1, (08/77)

d. FSAR, Section 8.3.11 ind 14.1.1 20840-3 (05/07/87)

, TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 23 0F 23 l

APPENDIX A (Cont'd) <

e. 10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"

f. Reru~otory Guide 1.64, " Quality Assurance Requirements for the Des,gn of Nuclear Power Plants," R2, (06/76) 9 NEB-DI 125.03, "Preoperational Testing," R0, (07/01/85)

h. NEB-DI 125.05, " Post Modification Testing Document - DE Processing After Issuance of Operation License," R0, (07/01/85)

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

a. Visit to TVA Knoxville Office by A. Rifai, Bechtel, to review and evaluate test procedures and test results packages,

, . , IOM 546, (10/09/86)

._- b. Meeting, Featherston, TVA, Rif ai, Bechtel, IOM 546,(10/09/86)

I

c. Telecon, McKeehan, TVA, Don-Doncow and Rifai, Bechtel, '

IOM 547, (11/10/86) j i

d. Telecon, L. Anderson, Bechtel, to D. Clift and R. McKeehan, TVA, IOM 418, (11/20/86)

e. Trip Report - Knoxville, Tennessee D. Popham, " Summary of Meetings with TVA Cognizant Personnel on Various Programmatic Element Reports," IOM 691,(01/21-30/87)

f. RFI, SQN-731, (11/19/86) 2084D-2 (05/07/87)

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