ML20215D796
| ML20215D796 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/25/1986 |
| From: | Mcnutt G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215D785 | List: |
| References | |
| 201.3-(B), 201.3-(B)-R, 201.3-(B)-R00, NUDOCS 8612170040 | |
| Download: ML20215D796 (23) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
- SPECIAL PROGRAM REPORT TYFi' SEQUOYAH ELEMENT REVISION NUMBER
- 0
- TITLE
- INCORPORATION OF REQUIREMENTS AND COMMITMENTS IN DESIGN
- Design Criteria PAGE 1 0F 22 .
1 1
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TVA EMPLOYEE CONCERNS ' REPORT NUMBER: 201.3('B)
SPECIAL PROGRAM
, _ - REVISION NUMBER: 0 PAGE 2 0F 22
- 1. CHARACTERIZATION OF ISSUES:
Concerns: Issues:
.WI-85-100-019 a. Electrical and other engineering design
" Electrical Standards and criteria are_ not always complete, are Guides are treated-as guides, vague, and are inadequate.
and are not incorporated in design criteria requirements. b. Many design criteria are changed late Electrical design criteria, in the project.
where it exists, is not complete, is vague, and in c. Engineering design criteria are often
-general is inadequate. CI nonexistent.
has no further information.
Anonymous concern via letter." d. Many design criteria were set up, then inactivated, and cannot be IN-85-886-001 retrieved for use as a basis for "TVA designs were not developed modification of the original design.
well enough to be constructible:
, 1) design changes are still NOTE: Issues "a" and "c" are also 4 -
.being instituted in areas addressed in Sequoyah Element Report
.where there should have been 213.3.
minimal. changes especially in area of conflicts between TVA and vendor dwgs. 2) engineering design criteria is of ten non- NOTE: The following issues from these existent, particularly for concerns are addressed in other reports.
seismic hanger design. Many design criteria or acceptance criteria are still being Engineering designs are not construct-changed. This is generic ible. (This issue is addressed in concern. Any further inform- Sequoyah Element Report 204.4. )
ation would divulge confident-iality. Construction Dept. Too many design changes made late in concern." the project. (This issue is addressed in Sequoyah Element Report 204.4.)
WI-85-100-044
{ "TVA has set up design Many acceptance criteria were changed criteria for W8NP and, af ter late in the project. (This issue is the fact, has inactivated a addressed in Sequoyah Element large percentage of the criteria. Report 204.4.)
CI has no further information.
Anonymous concern via letter." Too many conflicts between TVA drawings and vendor drawings exist late in the project. (This issue is
.3 addressed in Sequoyah Element dj} Report 204.4.)
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.- TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
, 4, SPECIAL PROGRAM r REVISION NUMBER: 0 PAGE 3 0F_22 Issues:
Electrical and other engineering standards and guides are treated as guides only. (This issue is addressed in Sequoyah Element Report 201.4.)
Electrical and other engineering standards and guides are not incorporated in design criteria. (This issue is addressed in Sequoyah Element Report 201.4.) "
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? X N0 o Identified by TVA SQN GCTF Date June 1, 1986
_A
'%{lj@ Drawings Not Constructible; Design Criteria Nonexistent,"'(06/01/86) o Identified by Gilbert / Commonwealth, Inc.
Date October 1985
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Assessment of the Design Control Program for the Sequoyah Nuclear Plant, G/C Report No. 2600(10/85) o Identified by Gilbert / Commonwealth, Inc.
a -
Date March 3,1986 Final Report No. 2614, " Technical Review of SQN Modifications" (03/03/86)
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
None N'?
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM
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REVISION NUMBER: 0
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- 3.- PAGE 4 0F 22
- 4. INTERVIEW FILES REVIEWED:
a .- -Expurgated QTC File for WI-85-100, and no additional unreviewed information was found
- b. Expurgated QTC File for IN-85-886, and some additional information was found
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
- 6. WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREAT See Appendix A.
sh,? 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER
'd DISCUSSIONS RELATED TO ELEENT.
See Appendix A.
- 8. EVALUATION PROCESS:
- a. Reviewed current and past procedures and practices for development and use of design criteria:
a -
o Determined if they are sufficient to develop complete, clear, and adequate design criteria o Reviewed sampling of design criteria for completeness, adequacy, and degree of vagueness, including electrical and seismic hanger criteria documents
- b. Determined if these issues have been identified in any other prior review (i.e., QA Audit, INP0 findings, etc.).
- c. Reviewed Design Criteria Index to assess scope of concern by determining which criteria have been inactivated.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
+ SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 5 0F 22
- d. Determined why design criteria were inactivated, and if reason was valid (i.e., superseded by another document).
e.. Reviewed procedure for inactivating criteria and evaluated retrievability and need for reactivation or replacement.
f.- Reviewed available transcripts of NRC investigative interviews to gain additional information regarding the -
concerns.
- g. Reviewed Design Baseline and Verification Program (DBVP) for Sequoyah Plant to see if program will adequately address the issues.
- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
Before examining issues "a" through "d" listed in Section 1, this section establishes which engineering procedures were applicable at various times, and defines basic terms.
p.
Q, Applicable Procedures: The following documents provide procedures M for the control of engineering for SQN from project inception to the present:
o SQN-Quality Assurance Manual, through R12 o EN DES Engineering Procedures (Red Book) o 0ffice of Engineering Procedures (0EPs) o Nuclear Engineering Procedures (NEPs) a o SequoyahProjectManual(SQEPs)
Definition of Basic Terms:
Design: From ANSI N45.2.11 (App. A, 5.b), the definition of Design is:
"Techr.ical and management processes which coamence with identification of design input and which lead to, and include, the issuance of design output documents."
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... TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 6 0F 22 Design Criteria: From procedure EN DES-EP 3.01 (App. A, 5.m):
" Design Criteria are Engineering requirements which provide the basis for conceptual and detailed design. Design criteria are the basis for making design decisions, establishing design inputs, accomplishing design verification measures, and evaluating design changes. Design criteria include, interpret and amplify:
- a. Design commitments in the Safety Analysis Reports (SARs) and other environmental and licensing documents.
- b. Design requirements of applicable industry standards and Nuclear Regulatory Commission requirements."
Design Basis: Per TVA memorandum (App. A, 5.u) and SQEP-18 (App.A,b.p):
l' "A design basis (1) identifies and interprets generic upper tier design input documents which are applicable to a specific plant, (2) identifies and evokes commitments made by TVA in licensing documents, (3) defines the general design requirements for the plant as required to satisfy the plant safety analysis, and (4) establishes any other general design input which may be dictated by TVA policy."
.< Design Basis Document (DBD): Per TVA memorandum (App. A, 5.u) and SQEP-18:
"A DBD consists, as a minimum, of those general design criteria for site, plant, structures, and systems which constitute the upper tier plant-specific design input. It may also include those detailed design criteria, system descriptions, and design input drawings, discretionary engineering decisions and rationale, analysis results, and engineering parameters and associated margins for detailed design."
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z e TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
SPECIAL PROGRAM
- REVISION NUMBER: 0 PAGE 7 0F 22 Design Inpot: From ANSI N45.2.11, the definition of Design Input is:
"Those criteria parameters, bases, or other design requirements upon which detailed final design is based."
Design Output: From ANSI N45.2.ll, the definition of Design Output is:
" Documents such as drawings, specifications and other documents defining technical requirements of structures, systems and components as delineated in Section 4." (Section 4 describes Design Process requirements.)
Discussion:
- a. Engineering procedures were reviewed regarding design g criteria development requirements.
IU Formal design criteria were not developed by TVA as of the late 1960s. General Design Criteria were, however, recognized and discussed in the Sequoyah PSAR (subsection 1.4), which was submitted to the NRC (AEC).on 10/15/68.
Design criteria procedures existed as early as January 1970 in TVA Division of Engineering Design (EN DES) Quality Assurance Procedure (QAP), SQN-QAP-III-1.1. The SQN QAP was superseded by EN DES-EP 3.01 in July 1974. The initial issue of EN DES-EP 3.01 endorsed ANSI N45.2. ll, however, TVA did
, not actually commit to comply until the 1976 issue of the SQN FSAR. EP 3.01 was superseded by OEP-06 in June 1985. OEP-06 was superseded by NEP-3.2 in July 1986.
SQN-QAP-III-1.1, EN DES-EP 3.01, OEP-06 and NEP-3.2 identify design criteria as design input. The specifics as to preparation are quite detailed, including requirements for preparation, review, approval, revision, and ample guidance in the form of attachments to the procedure. Therefore, from a procedural standpoint all of the essentials have been and are in place to eliminate vagueness and to ensure completeness and adequacy.
Based on discussion (App. A, 7.c) with Civil Engineering Branch (CEB) personnel regarding design criteria and
- h. , inspection of available criteria, the criteria were complete, comprehensive, and current.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM
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Discussion (App. A, 7.a) with Mechanical Engineering Branch 1 (MEB) personnel and observation of criteria available found -
i design criteria were being updated to support the DBVP.
Completeness and adequacy are being established throu design verification and interface review (squadcheck)gh the procedure, per NEP-5.2.
Discussion (App. A, 7.b) with the Electrical Engineering Branch (EEB) indicated that EEB, as an enhancement to the NEPs, has set up an internal program to address shortcomings in its design control process. This program, which adds detailed instructions relative to the procedures, is
( discussed in a memorandum (App. A, 5.z). Additional detail in Gilbert /Comonwealth Report 2614 (App. A, 5.t), relative to EEB, indicates that a more comprehensive effort is needed for the collection and distribution of design criteria.
Some specific adequacies and inadequacies relative to EEB criteria are discussed in Element Report 213.3.
M Ch'i The DBVP isPlan Performance established 5.y h
(App. A, throuf. the Sequoyah Within Nuclear the detailed the prerestart phase, as presented in a DBVP memorandum scope of (App. A, 5.aa), it is indicated that walkdown/ test data will be compared to the licensing commitments and the design
- criteria / design basis for an engineering evaluation.
In addition the Sequoyah Nuclear Performance Plan (App. A, 5.y) provides that the TVA Engineering Assurance (EA) organization vill monitor the implementation of the DBVP.
EA has monitored the DBVP and has ferreted out certain inadequacies in the design criteria reconciliation as evidenced by an Action Items tabulation originated by the EA Independent Oversight Review Team, (App. A, 5 bb). Items noted by EA are tracked to completion.
The NRC conducted special inspections of the DBVP (App. A, 5.cc and 5.dd), including the TVA EA Independent Oversight Team activities. From the latest NRC inspection
- (App. A, 5.dd), the NRC team concluded that the preparations and approach for the program were in most cases in accordance
[ with the program plan, subject to some general comments.
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0
!_ PAGE 9 0F 22 On four different occasions Impell was called on to make independent external audit finding evaluations of the DBVP Design Control Program. Impell reports (App. A, 5.hh, 5.11, 5.jj, and 5.kk) were reviewed for additional information pertinent to the issues. Impell report 86-162 (App. A, 5.hh) compares the findings of NRC Inspection Report 86-27 with TVA's actions outlined in the DBVP. Impell report 86-180 (App. A, 5.ii) compares findings of Gilbert / Commonwealth Reports G/C 2600 and 2614 with TVA's actions outlined in the DBVP. Impell report 86-197 (App. A, 5.jj) compares the
" Bender Report" (App. A, 5.11) and the INP0 Corporate Evaluation with the actions outlined in the DBVP. Impell report 86-233 (App. A, 5.kk) compares the findings of the OE review of unimplemented and partially implemented ECNs for selected systems with TVA's actions outlined in the DBVP.
The point is that controls are in operation which should ensure that the OBVP will establish complete, comprehensive, and adequate design criteria.
The DBVP establishes a data base containing the (04 commitments /requiraments to be initially incorporated into the design criteria. SQEP-18 is being revised (Rev. 2) to require that this data base will be turned over to the project and maintained current throughout the life of the plant. This will help to ensure that the Sequoyah design criteria will reflect the latest licensing commitments and other design requirements.
- b. Design criteria are considered by TVA to be design input documents. Design input constitutes design requirements that
, govern the design of all structures, systems, and components. Design criteria are addressed under NEP-3.2.
NEP-3.2 states in Section 2.0, " Policy" that " Changes to design input will be evaluated and where appropriate will be reflected in revisions to other affected design input documents." EN DES-EP 3.01 and OEP-06 say essentially the same thing.
It would appear from the procedure and discussions with TVA personnel that changes to design criteria are made when justification for changes has been established. It is standard practice to make changes when changes are needed to correct a deficiency, or for other reasons, regardless of g when during the life of the SQN project they are found. For example:
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- e TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 0 CL PAGE 10 0F 22 o Design criteria document, SQN-DC-V-1.1.1.1 was revised to add, among other items, (i) Pipe break loads (ii) Tornado loads (iii) Flood loads o Design criteria document, SQN-DC-V-1.1.9 was revised to change design pressure of some doors.
The TVA SQN Generic Concern Task Force investigated concern IN-85-886-01. The results of the investigation were issued as report GCC-20-66, identified in Section 2 of this report.
The conclusion of the investigation relative to this issue stated, in part:
"This investigation verified that design / acceptance criteria are still
< being changed but it failed to
(#r, substantiate the implication that these id changes are unwarranted . . ."
- c. NEP-3.2, Section 2.0, " Policy" states in part:
" Design criteria documents will be prepared for all designs and will identify the effective revision of all design inputs and the portions of each design input that are applicable to each design."
< The nonexistence of some design criteria was noted in discussions with personnel in EEB (App. A, 7.b) as well as in discussions at the SQN job.;ite (App. A, 7.d). The nonexistence of specific EE8 dssign criteria is discussed in Sequoyah Element Report 213.3.
Conclusions of the TVA SQN Generic Concern Task investigation of concern IN-85-886-01, report GCC-20-66, relative to this ,
issue stated, in part: l 6;
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% TVA EMPLOYEE. CONCERNS REPORT NUMBER: 201.3(B)~
SPECIAL PROGRAM REVISION NUMBER: 0 j\ c PAGE 11 0F'22 "This investigation verified that there-were design criteria which are needed and do not exist. In particular the design criteria for seismic hangers is scheduled to be issued for SQN by May 30, 1986. There was [ sic] identified ten other design criteria in various stages of preparation of SQN."
The Gilbert / Commonwealth report No. 2614 (App. A, 5.t) in subsection 3.1.1.3 "Previously Identified Issues," stated in part:
"The review team found that some documentation of original design bases was either not readily available 'or nonexistent."
It was also confirmed that corrective action to develop needed design criteria, where missing, is underway as z.s required to support SQN restart. The corrective action is
.,g g defined in the DBVP.
- L% I As follow on to the DBVP and design basis document l development, a TVA EEB memorandum (App. A, 5.z) establishes a l program for improving the EEB design control process, which includes recognition of the procedural requirements relating to design criteria as well as the need to relate final design back to the source of design input.
- d. Inactivation of design criteria was first addressed in EN DES-EP 3.01, revision 4,(11/19/80). The revision added
, - Section 10.0, " Inactivation of Design Criteria," with three subsection.s: 10.1 " Definition of Inactivated Design Criteria," 10.2 " Time of Inactivation," and 10.3 " Process of Inactivauon." Of particular note is subsection 10.2, which states that design criteria may be inactivated in the following situations:
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (8)
SPECIAL PROGRAM REVISION NUMBER: 0
.(x c_ . PAGE 12 0F 22 "a. After approval of the system preoperational test (EN DES-EP 6.01) or post modification test and before the design project is disbanded (for design criteria controlling initial plant design and not modifications),or
- b. If the entire system is replaced by a different system in the plant design.
NOTE The selection of the time of inactivation is at the discretion of the section supervisor responsible for the design criteria within the guidelines of a. and b.
above."
Revision 6 of EP 3.01, (05/22/84) changed this section to m read:
A .t
[O " Design criteria may be inactivated only when the entire subject system, structure, or component has been deleted from the plant design or permanently removed from operation at the plant site."
It is apparent that from 1980 to 1984 design criteria were permitted by procedure to be inactivated. This is consistent with the discussion at the Sequoyah jobsite noted below.
, NEP-3.2, Section 2.0, " Policy" states, in part:
" Design criteria documents may be inactivated only when the entire subject system, structure, or component has been deleted from the plant design or permanently removed from operation at the plant. Design requirements in the design criteria may be incorporated in a system description or design basis document (DBD).
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- TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(8)
SPECIAL PROGRAM REVISION NUMBER: .0 PAGE 13 0F 22-
" Exception to design criteria documents may be taken if they are technically justifiable and are documented in accordance with this procedure.
"A DB0 shall be prepared for each nuclear power plant. The DBD shall define, establish, and maintain the upper tier design documentation requirements for operating nuclear plants. The DBD and its subsequent revisions shall be subject to review for approval by the discipline branch chiefs as in NEP-5.2 and shall be controlled and maintained throughout the life of the plant."
0EP-06 states essentially the same policy as NEP-3.2, except it does not address the preparation of the 080.
In a discussion at the Sequoyah jobsite (App. A, 7.d) it was m indicated that design criteria were also inactivated when '
6, construction was completed and the system was put into "s operation. This practice was based on the rationale that all of the necessary information was contained in design output documents. The reason given for inactivating the design criteria was to cut down on surplus documentation, and retain only documentation needed to support the operating plant.
This statement confirms the discussion on page 178 of the transcript of NRC investigative interview (App. A, 5.w). As noted earlier there was a time between 1980 and 1984 when such inactivation was allowed by procedure.
< ' It is true that many design criteria were set up and then inactivated. However, Engineering has initiated restoration of these criteria through the D8VP. It will be necessary to update these criteria, however, before they can be reissued.
Inactivated design criteria are identified in the Sequoyah Design Criteria Manual Index. Thirty-two issued criteria were identified in the index as inactivated. All 32 were readily retrieved.
Engineering is aware of the necessity to have this design criteria, and has initiated its restoration and updating as part of the DBVP.
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.TVA EMPLOYEE CONCERNS' REPORT NUMBER: 201.3(B) g SPECIAL PROGRAM r . .
REVISION NUM8ER: 0 L:h;. Q PACE 14 0F 22 t
,. Monitoring implementation of the DBVP by EA should ensure adequacy and completeness of design criteria issued;
. maintaining comatitments/ requirements tracking throughout the L life of the Sequoyah plant and should ensure that criteria -
are maintained current.
Findings:
- a. Procedural essentials exist for eliminating vagueness, for achieving completeness, and for assuring adequacy of design criteria.
Completeness and adequacy are being established through design verification and interface review. This situation should be mitigated for SQN through the DBVP when walkdown/ test data are compared to the licensing and the design basis criteria,
- b. Design criteria are sometimes changed late in the project.
< Changes are made when necessary to correct deficiencies.
g4 Appropriate procedures are in place for making necessary C'm d!, changes.
- c. The issue that some needed criteria did not exist was found to be true. Appropriate procedures are in place for generating such criteria.
- d. It is true that some design criteria were set up and then inactivated. However, it was found that the inactivated criteria could easily be retrieved although they required update after retrieval.
[ Some design criteria documents were inactivated when construction was completed and the system was put into operation, using the rationale that all necessary information was contained in design output documents. This was allowed by EP-3.01 at the time.
The current procedure NEP 3.2 allows design criteria documents to be inactivated only when the entire subject system, structure, or component has been deleted from the l
plant or permanently removed from operation at the plant.
Design requirements in the design criteria may be j incorporated in a system description or design basis document.
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h TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B) k SPECIAL PROGRAM L ,cv REVISION NUMBER: 0
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Conclusions:
$ a. The issue that some design criteria were inadequate is Q valid. However, this issue should be resolved as programs 3 currently in place (i.e., DBVP & DBD) are fully implemented.
- b. The issue-is valid in that some design criteria were changed 1 .
late in the project. However, design criteria changes are, E and should be, made when circumstances dictate or deficiencies must be corrected.
! .c. The issue is valid in that some needed design criteria did v not exist. However, full implementation of the DBVP should create design criteria where they are needed.
- d. The issue is valid in that some design criteria were inactivated. The criteria can be retrieved and reactivated once they are reviewed and brought up to date in accordance with NEP procedures.
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SPECIAL PROGRAM REVISION NUMBER: 0
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+< PAGE 16 0F 22 APPENDIX A 5.- DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Chapter 1, Appendix B, " Quality Assurance Criteria For Nuclear Power Plants."
- b. ANSI N45.2.ll - 1974, " Quality Assurance Requirements for the 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)
- n. f. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- h 2' g. Sequoyah Preliminary Safety Analysis Report, (PSAR)
- h. Sequoyah Final Safety Analysis Report (FSAR) Updated, through Amendment 3.
- 1. TVA, TR 75-1A, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," R8
" ' j. Tennessee Valley Authority, Nuclear Quality Assurance Manual, (NOAM),(11/14/85)
- k. Sequoyah Nuclear Plant Quality Assurance Manual (50N QAM)
Quality Assurance Procedures (0APs) employed in the review of this element are from Revision 11 of the SON QAM (and prior).
The following QAP is referred to in this evaluation:
SON-0AP-III-1.1, R2, " Preparation and Review of Design Criteria for Sequoyah Nuclear Plant," (04/07/71)
- 1. Office of Engineering Design and Construction (0EDC) Quality Assurance Manual 0377D - November 20, 1986
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 17 0F 22 APPENDIX A (Cont'd)
- m. Division of Engineering Design, Tennessee Valley Authority Engineerir.g Procedures Manual. This evaluation refers to the following:
Volume 1, Section 1.0, Category: General Volume 2, Section 3.0, Category: Engineering Volume 3, Section 4.0, Category: Design Volume 4, Section 5.0, Category: Procurement Division of Engineering Design (EN DES), Engineering Procedures (EP)reviewedwere:
EP No. 4.12, R5 "EN DES Design Guides and Design Standards - Preparation, Review, Approval, Distribution,andRevision,"(04/15/82)
EP No. 3.01, R6 " Design Criteria Documents - Preparation, Review, and Approval," (05/22/84) 3: .
'fy: EP No. 5.20, R7 " Processing Procurement Requests,"
u (11/05/84)
EP No. 5.30, R6 " Standard Format for the Preparation of ProcurementSpecifications,"(07/29/83)
EP No. 5.33, R8 " Procurement Quality Assurance," (10/26/84)
ManagementManual,(04/26/85)
The following OEPs are referred to in this evaluation:
0EP-06, R0 " Design Input," (04/26/85)
OEP-07, R0 " Calculations," (04/26/85)
OEP-08, R0 " Design Output," (04/26/85)
OEP-09, R0 " Procurement," (04/26/85)
OEP-10, R0 " Review," (04/26/85)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 18 0F 22 APPENDIX A (Cont'd)
- o. TVA Division of Nuclear Engineering, Nuclear Engineering Procedures (NEPs):
NEP-3.2, R0 " Design Input," (07/01/86)
NEP-4.1, R0 " Procurement," (07/01/86)
NEP-5.1, R0 " Design Output," (07/01/86)
NEP-5.2, R0 " Review," (07/01/86)
- p. TVA Division of Nuclear Engineering (DNE), Sequoyah Engineering Project (SQEP), Project Manual SQEP-13, R0 " Procedure for Transitional Design Change Control," (07/25/86)
SQEP-18, R1 " Procedure for Identifying Commitments and tr: , Requirements as Source Information for Sequoyah Design Yly Criteria Development," (07/09/86) zu SQEP-18, R2 " Procedure for Identifying Commitments and Requirements as Source Information for Sequoyah Design CriteriaDevelopment,"(DRAFT)"
SOEP-29, " Procedure for Preparing the Design Basis Document ,
for Sequoyah Nuclear Plant," R1 (07/18/86)
- q. Tennessee Valley Authority Sequoyah Nuclear Plant, Standard Practice, 50A0134, " Critical Structure, Systems, and
< ' Components (CSSC) List," R8, (01/27/86)
- r. Sequoyah Nuclear Plant Design Criteria Manual (6 Volumes),
(06/26/86)
- s. Gilbert / Commonwealth. Inc. Report No. 2600, " Assessment of Design Control Program for the Sequoyah Nuclear Plant, Prepared for the Tennessee Valley Authority," (10/85)
- t. Gilbert / Commonwealth, Inc. Report No. 2614. "Sequoyah Nuclear Plant Modification for Tennessee Valley Authority," (03/03/86)
- u. TVA memo from W. C. Drotleff, Jr., to Those Listed, (R. G. Domer, et al), " Design Basis Program for TVA Nuclear P1 ants," (B44 860402 007), (04/08/86) 03770 - November 20, 1986
7 1 . .
2 TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 0 Cy PAGE 19 0F 22 APPENDIX A (Cont'd)
- v. 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)
- w. Letter from NRC to S. A. White, TVA, " Transcript of Interview of Dallas R. Hicks," (06/23/86)
- x. TVA memo from R. L. Gridley to Those Listed (H. L. Abercrombie, et al), "Sequoyah Nuclear Performance Plan - Volume II - Final Concurrence," (L44 860714 800),
(07/14/86)
- y. Sequoyah Nuclear Performance Plan, Volume II, R1 (approval scheduled for July 16, 1986)
- z. TVA memo from W. S. Raughlcy to J. D. Collins, et al, " Policy Memorandum PM 86-24 (EEB) - EEB Design Control Process,"
(843 861017 904), (10/17/86)
(' aa. TVA memo from J. F. Cox to M. T. Tormay, "Sequoyah Design Basis Program to Support Restart," (B25 860811 100),
(08/11/86)
'bb. Action Items Originated by the Engineering Assurance Independent Oversight Review Team for the Sequoyah Nuclear Plant Design Baseline and Verification Program - Summary Report, Prepared By: John Von Weisenstein, (10/22/86) cc. Letter from NRC to S. A. White, TVA, " Report Nos. 50-327/86-38 and 50-328/86-38," (09/15/86) a dd. Letter from NRC to C. C. Mason, TVA, " Report Nos.50-327/86-45and50-328/86-45"(10/31/86) ee. TVA memo from L. L. Jackson to Those Listed (H. L. Abercrombie, et al), " Institute of Nuclear Power Corporate Evaluation Responses" Operations (INP0)(08/14/86)
( A02 860813 012) ff. SQN-DC-V-1.1.1.1, " Detailed Design Criteria for Evaluation of Unreinforced Masonry Walls Constructed from Solid Concrete Blocks," R1, (05/21/81) 99 50N-DC-V-1.1.9, " Design Criteria for Pressure Confining PersonnelDoors,"R2,(10/1/86) g 03770 - November 20, 1986
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 r
_he PAGE 20 0F 22 APPENDIX A (Cont'd) hh. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-162), (06/19/86) ii. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-180), (06/30/86) jj. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-197), (07/10/86) kk. Letter from Impell to TVA ( Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-233), (07/23/86)
- 11. Report: " Assessment of Engineering Design Control for the Browns Ferry Nuclear Plant," written by Myer Bender, F. E.
7 Laurent, E. H. Cole and R. D. Sabin, (09/85) t V mm. INP0 Report of Sequoyah Nuclear Plant TVA, February 1984 Evaluation
- 6. WHAT REGULATIONS, LICENSING C069tITMENTS, 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. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
- d. Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction)," R0, (06/07/72)
- e. ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants"
- f. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- g. Sequoyah Final Safety Analysis Report (FSAR) Updated, through
l Amendment 3.
, 03770 - November 20, 1986
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: .0
_ . . PAGE 21 0F 22 APPENDIX A (Cont'd)
- h. TVA Division of Nuclear Engineering, Nuclear Engireering Procedures (NEPs):
NEP-3.2, R0 " Design Input," (07/01/86)
NEP-5.2, R0 " Review," (07/01/86)
< 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEE NT.
- a. Discussion, D. Zwicky, Bechtel, with S. Rudell and H. Mahlman, TVA Mechanical Engineering Branch in Knoxville, (10/22/86) m l b. Discussion, D. Zwicky, Bechtel, with G. Reed and P. Nesbitt,
'x.s)' TVAElectricalEngineeringBranchinKnoxville,(10/23/86)
- c. Discussion, D. Zwicky, Bechtel, with C. Glidewell, J. Williams and N. Liakonis, TVA Civil Engineering Branch in Knoxville,(10/23/86)
- d. Discussion D. Zwicky, B. Wolters, Bechtel, with Henry Jones and Terrell Clift of TVA at Sequoyah jobsite, (10/24/86)
- e. Trip Report, D. Zwicky personal visit to Knoxville, October
, 21-23, 1986, and SQN Site, October 24, 1986.
- f. RFI #712, (11/13/86)
- g. RFI#718,(11/15/86)
- 1. Telecopy TVA to R. Wolters, submittal of INP0 February 1984 Evaluation of SQN (Response to RFI #712)
- j. Telecon, D. Zwicky, R. Wolters, J. Violette and C. Jordan, Bechtel, with T. Clif t, P. Nesbitt and G. McNutt, TVA, (11/11/86)
G 03770 - November 20, 1986
e ,
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
. . SPECIAL PROGRAM
,. 7 . ,. _ REVISION NUMBER: 0
,e
'(( __ __ PAGE 22 OF 22 CATD LIST The following CATD forms are included as part of this report:
201.03 SQN 01
. f' p c( s.
l l
s l
l l
l 0377D'- November 20, 1986
-?
p ..
4
~
ECTG C.3 Attachment A 4 Page 1 of 1
{Oi z .a Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD)
INITIATION
- 1. Inunediate Corrective Action Required: % Tes O No
- 2. Stop Wort. Recotirnended: 0 Yes O( No
- 3. CATD No. 2 o I, o 3 *=Qu o14 INITIATION DATE // - 2. 0- e r,
- 5. RESPONSIBLE ORGANIZATION: DNE
- 6. PROBLEM DESCRIPTION: W QR O NQR O tE 9 G W C.6t t T C 2 i A, T H A -t- A m.E i o er v T sre i e o tw -5 cc e P - 7_ 9 As G2_ E CL u s EE M E N "T S P o v. (2_gr. g T A S T M u ST AE Gils.v ie wtED - 2.t!rvi5 E D o it. C.= E N erv A 7 E D AS AP P t i c. A thUiF Noa to 9Le 5 T A w T .
U i O ATTACHMENTS
- 7. PREPARED SY: NAME D. A . "Z.wi sc v s V 'JE/ DATE: i I / t.o /8 (,
- f.y;3
. 8. CONCURRENCE: CEG-Hy 'O 'fi W /4. h C W DATE: / f -29 94 4yj 9. APPROVAL: ECTG PRO 6 LAM MGR. _ DATE:
e ,-
CORRECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
a l
O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H: DATE:
SRP: DATE:
ECTG PROGRAM MGR: DATE:
VERIFICATION AND CLOSEOUT n
W ,' l .) . Approved corrective actions have been verified as satisfactorily
/
implemented.
SIGNATURE TITLE DATE
. *