ML20215D844
| ML20215D844 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/25/1986 |
| From: | Mcnutt G, Nesbitt P TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215D785 | List: |
| References | |
| 213.3-(B), 213.3-(B)-R, 213.3-(B)-R00, NUDOCS 8612170064 | |
| Download: ML20215D844 (14) | |
Text
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b-A TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3 (B)
SPECIAL PROGRAM W
REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 0 k;.
TITLE:
-ELECTRICAL PROCEDURES Inadequate Electrical Design Criteria.
Inadequate Consideration Given to PAGE 1 0F 11 Electrical Standards and Guides I
REASON FOR REVISION:
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ECSP MANAGER DATE MANAGER F NUCLEAR POWER DATE CONCURRENCE FINAL REPORT ONLY)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3 (B)
SPECIAL PROGRAM-REVISION NUMBER: 0 PAGE 2 0F 11 1.
~ CHARACTERIZATION OF ISSUE (S):
Concern:
Issues:
WI-85-100-019 a.
Standards are treated as guides.
" Electrical Standards and Guides (Addressed in Sequoyah Element are treated as guides, and are-Report 201.4) not incorporated in design criteria requirements.
Electri-b.
Standards and guides are not incor-cal design criteria, where it porated into the electrical design exists, is not complete, is criteria.
vague, and in general is inadequate. CI has no further c.
Sufficient electrical design information. Anonymous concern criteria to form a basis for via letter."
design are nonexistent.
d.
Electrical design criteria are inadequate to form a basis for design.
rnti,
e.
There appears to be programmatic 4'
inadequacy with regard to preparation and adequacy of design criteria. (Addressed in Sequoyah Element Reports 201.3 and 201.4) 2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by Gilbert / Commonwealth Inc.
Date 03/03/86 Documentation Identifiers:
Final Report No. 2614, " Technical Review of SQN Modifications" 3.
DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
Electrical Design Criteria in general.
4.
INTERVIEW FILES REVIEWED:
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File WI-85-100 was reviewed and no additional unreviewed information was found.
03100'(11/18/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 3 0F 11 5.-
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
6.
WHAT REGULATIONS, LICENSING C0f04ITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREAT See Appendix A.
7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEENT.
See Appendix A.
8.
EVALUATION PROCESS:
,o a.
Established requirements for the existence of design criteria
(
)
both historically and currently (Review of regulations and t/
TVAprocedures).
b.
Determined to what extent TVA (on SQN) has complied, is in compliance, or will comply with these requirements.
c.
Reviewed available transcripts of NRC investigative interviews for additional unreviewed information.
d.
Reviewed existing design criteria for adequacy and for reference to, adoption of, or compliance with design standards and/or guides.
e.
Reviewed existing reports, plans, and previously taken corrective actions for adequacy.
f.
Reviewed existing TVA Construction, QA/QC, Operations, and Material Control reports for the Employee Concern Evaluation Program for applicability to the concerns discussed in this report.
)
03100'(11/18/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
213.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 4 0F 11 9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
Discussion:
The concerned individual (CI) questions the existence and adequacy of electrical design criteria. Further, the CI asserts that guides and standards are not incorporated into design criteria and are therefore not required to be followed. Finally, the general issue of programmatic inadequacy with regard to the preparation of design criteria is raised.
Issue "a" is addressed in Sequoyah Element Report 201.4 " Standards and Guides," issues "b," "c,"
and "d" as they relate to SQN are discussed in this report, and the programmatic issue "d" is discussed in Sequoyah Element Reports 201.3 " Design Criteria," and 201.4 " Standards and Guides."
The intended purpose of design criteria is to establish the engineering requirements that are the basis for conceptual and detailed design. Design criteria are used in making design
$,[9 decisions, accomplishing design verification, and evaluating design w,
changes. The criteria should include, interpret, and amplify design commitments made in licensing documents; applicable industry standards; and NRC requirements. Additionally the criteria should specify major functional requirements, environmental constraints, and any system interf ace requirements.
During the period of the initial design and construction of SQN, there were no industry-accepted requirements for formal design criteria documents. However, design commitments were reflected in the PSAR, Westinghouse Power Division Standards, and other project documents. At that time, the governing procedure was quality assurance procedure SQN-QAP-III-1.1 (01/30/70), " Preparation and Review of Design Criteria for Sequoyah Nuclear Plant,"
subsequently, Engineering Procedure (EP) EN DES-EP 3.01 R0 " Design Criteria Documents - Preparation, Review and Approval" was issued (07/18/74). This procedure required all nuclear projects to I
prepare design criteria, and endorsed ANSI 45.2.11-1974 (Regulatory Guide [RG) 1.64). Revision 5 of EN DES-EP 3.01(12/13/82) exempted plants earlier than Bellefonte (including SQN) from the requirements of the EP. However, with the issuance of Office of Engineering Procedure OEP-06 " Design Input," which superseded EN DES-EP 3.01, SON was again required to produce design criteria g,-
03100'(11/18/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 0 g
PAGE 5 0F 11 documents.
Finally, OEP-06 was replaced by Nuclear Engineering Procedure (NEP) 3.2 R0 " Design Input" on 07/01/86. NEP 3.2 R0 is the procedure currently in force and it is applicable to the SQN project.
In e trly 1986, Gilbert / Commonwealth Inc. (G/C) performed a technical review of SQN modifications and concluded that the design criteria were " fragmented." G/C found that TVA had committed to various criteria and standards through NRC evaluations, FSAR references, various memoranda, and generic design criteria, but did not have a complete, up-to-date set of design criteria documents in a system / structure format that reflected these commitments. This led to difficulty in establishing design bases for plant modifications.
Acknowledging these deficiencies, TVA established the Design Basis Document Program (DBDP, 04/08/86, App. A, 5.1) to update the design criteria documents and capture licensing commitments and regulations. This program is in conjunction with the overall Design Baseline and Verification Program (DBVP, 05/01/86, App. A, 4' l>g 5.1).
These programs will be conducted in accordance with NEP 3.2, which provides for format, content, preparation, and approval of design criteria. Additionally, NEP 3.2 provides for the use of coninitment/ requirement (C/R) data sheets to identify commitments or requirements made in other documents (e.g., FSAR, memoranda, letters, etc.), and to ensure that these C/Rs are incorporated into the appropriate design criteria. Sequoyah engineering procedure (SQEP - App. A, 6.d) 29 R1 " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant," issued on 07/18/86, provides for the implementation of the DBDP for SQN in accordance with NEP 3.2.
The evaluation team reviewed several electrical design criteria (App. A, 5.k).
This review was performed using RG 1.64 and Engineering Procedures (NEP, OEP, EP) as the acceptance basis. The criteria appeared to be in compliance with the intent of the Engineering Procedures issued over the years. Moreover, the criteria revised or issued af ter the issuance of NEP 3.2 are in compliance with the NEP.
In general, adequate reference is made to appropriate standards, codes, guides, and regulations in both the reference sections and in discussion portions.
The criteria reviewed were found to be adequate and sufficient to form a design basis with some exceptions identified in the separation criteria, SQN-DC-V-12.1 R6. These separation criteria deficiencies are discussed in detail in Sequoyah Element Report 242.0 " Electrical Separation."
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03100 (l1/18/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 N
L...
PAGE 6 0F 11 Most of the design criteria reviewed have been revised to incorporate additional commitments and requirements as identified
'by the C/R data sheets as part of the DBVP. SQEP 29 provides for closure of C/R data sheets when design criteria are issued.
However, a sample review of C/R data sheets by the evaluator
-indicates that not all C/R data sheets that shculd be incorporated are_ included in the appropriate design criteria. Examples of these are separation criteria that.have outstanding C/R data sheets.
(A detailed verification for C/R data sheet incorporation was only performed for the separation criteria.) Furthermore, there are'C/R data sheets which identify commitments and requirements for subjects that are not covered in design criteria and therefore have nowhere to be incorporated.
Included in these are the C/R data sheets which identified comitments of FSAR Chapter 7 on instrumentation, and commitments of FSAR Chapter 9 concerning lighting and communications. Finally, the evaluator was unable to obtain an actual status list with regard to the disposition of C/R data sheets, or any tracking plans for closeout of this task.
To investigate the issue of the existence of all necessary design (Neh revealed that criteria exist for the major electrical systems A
criteria, the SQN Design Criteria Manual index was reviewed. This (i.e., APS,125 V dc, vital ac) and also for speciality systems such as Post-Accident Monitoring (PAM).
However, the evaluator was unable to verify existence of design criteria for:
o Overall plant security o
Instrumentation and controls (I&C) o Communications o
Lighting Additionally, there are several design criteria identified in the index which have never been issued. These unissued criteria are:
o SQN-DC-V-9.7,
" Emergency Operations Facility" o
SQN-DC-V-9.ll, " Safety Related Display Instrumentation" o
SQN-DC-V-10.6, "The Emergency Fire Protection Communications Systems" o
SQN-DC-V-ll.9, " Thermal Overload and Torque" None of the unidentified /unissued criteria listed above were committed to as required for restart per SQEP 29.
However, the titles of some of the unissued criteria imply that they may be safety-related, and portions of the unidentified criteria may have plant safety significance (e.g., emergency lighting sufficient to g.,
allow safe shutdown of the plant).
3t i) 03100(11/18/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
213.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 f,.
PAGE 7 0F 11 Per TVA memo (08/11/86, App. A, 5.0) Phase I of the DBVP (the completion of design criteria required for restart) is essentially complete; however, the areas identified above have not been addressed and not all C/Rs have been incorporated into the criteria required for restart.
To ensure that future licensing commitments are incorporated into design criteria, NEP 2.1 R0 (07/01/86) " Licensing Support" provides for coordination between licensing and engineering, and NEP 6.1 R0 (07/01/86)" Change Control" provides for the revision of design criteria. This issue is addressed in Sequoyah Element Report 201.1
" Regulatory Requirements."
Findings:
a.
Review of a sample of the electrical design criteria indicates that standards, guides, and regulations are part of these criteria and are committed to when appropriate.
b.
Although this review indicates that most of the electrical ga design criteria documents currently exist, design criteria 9
documents for the following could not be identified:
' communications, overall plant security, instrumentation and controls, and lighting. Additionally, it was determined that some design criteria were identified by TVA but never issued.
c.
Review of C/R data sheets indicates that some commitments have not yet been incorporated into the electrical design criteria required for restart and that no plans for closeout of unincorporated C/R data sheets currently exist, as TVA has
" essentially completed" the DBVP.
a d.
Provisions for the issuance or revision of electrical design criteria necessary to fully document the design bases (nonrestart portion) have not been made.
Procedures for the closeout of nonrestart C/R data sheets have not been formulated.
==
Conclusion:==
The issues of the concern for the adequacy and existence of formal design criteria documents are valid.
However, the Design Basis Program has been implemented by TVA to correct the problem. This program commits to the issuance of a minimum set of design criteria prior to restart, however, additional criteria may be necessary to fully document the design basis of the plant.
Efforts to establish
~
that all SQN commitments are covered in design criteria are still
~
needed.
0310D '(11/18/86)
^
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 0 G
PAGE 8 0F 11 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
SNP FSAR Chapters 7, 8, and 9 b.
Revised Sequoyah Nuclear Performance Plan, Volume II, Final Concurrence, (07/14/86) c.
Gilbert / Commonwealth Report No. 2614, " SON Modifications for TVA," (03/0/386) d.
TVA memo from W. C. Drotleff to Those Listed, " Transition from OEP to NEP," (805 860410 008), (04/10/86) e.
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 of 02/21/86 at the First Tennessee Bank Building in Knoxville, Tennessee j
f.
Nuclear Engineering Procedure 3.2, R0, " Design Input,"
w/
(07/01/86) g.
Office of Engineering Procedure OEP-06, R0, " Design Input,"
(04/26/86) h.
Engineering Procedure EN DES-EP 3.01, R6, " Design Criteria,"
(05/22/84) 1.
Design Baseline and Verification Program, Sequoyah Nuclear Plant, R0, (05/01/86) a j.
Nuclear Engineering Procedure 2.1, R0, " Licensing Support,"
(07/01/86) k.
SON Design Criteria:
SQN-DC-V-ll.2, R3 "125-V Vital Battery System,"
(07/11/86)
SQN-DC-V-ll.2.1, R2 "125-V Fifth Vital Battery System," (07/11/86)
SQN-DC-V-ll.4 & 11.5, R1
" Emergency Auxiliary Ac Power System," (07/25/86)
SQN-DC-V-ll.4.1, R2
" Normal and Emergency Ac Auxiliary Power System," (07/22/86) o)
03100'(11/18/86) l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 9 0F 11 APPENDIX A (cont'd)
SQN-DC-V-11.6, R3 "120-V Ac Vital Instrument Power System," (07/11/86)
SQN-DC-V-ll.8, R0
" Diesel Generator and Auxiliary Systems," (07/10/86) 5QN-DC-V-12.2, R6
" Separation of Electric Equipment and Wiring," (09/30/85) 1.
TVA memo from W. C. Drotleff to Those Listed, " Design Basis Program for TVA Nuclear Plant," (844 860402 007), (04/08/86) m.
TVA memo from D. W. Wilson to Those Listed, "Sequoyah Nuclear Plant - Design Basis Effort to Support Restart,"
(825860409009),(04/09/86) n.
TVA memo from W. S. Raughley to Those Listed, "Sequoyah Nuclear Plant Design Criteria," (08/01/86) o.
TVA memo from J. F. Cox to M. T. Tormey, "Sequoyah Design
)
Basis Program to Support Restart," (825 860811 100),
s (08/11/86) p.
Nuclear Engineering Procedure 6.1, R0, " Change Control,"
(07/01/86) q.
Quality Assurance Procedure SQN-QAP-III-1.1, R2, " Preparation and Review of Design Criteria for Sequoyah Nuclear Plant,"
(04/07/71) r.
All documents listed in Section 6.
6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
a.
Regulatory Guide 1.64 ( ANSI N45.2.11-1974), " Quality Requirements for the Design of Nuclear Power Plant" b.
10CFR50 Appendix B, Criterion II, " Design Control";
Criterion V, " Instructions, Procedures and Drawings,"
(06/26/71) c.
Nuclear Engineering Procedure (NEP) 3.2 R0, " Design Input,"
(07/01/86) a)
d.
Sequoyah Engineering Procedure (SQEP) 29 R1, " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant,"(07/18/86) 03100 (11/18/86)
6 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 10 0F 11 APPENDIX A (Cont'd) 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
a.
P. Nesbitt, J. Staub, TVA, I. Don-Doncow, Bechtel, meeting at SQN site, (08/20/86) b.
Teleconference between T. Sarver, I. Don-Doncow, Bechtel, and P. Nesbitt, TVA, (10/15/86) c.
Teleconference between T. Sarver, I. Don-Doncow, Bechtel, and P. Nesbitt, TVA, (10/21/86)
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REPORT NUMBER:
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SPECIAL PROGRAM REVISION NUMBER: 0 d-PAGE 11 0F 11 t
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CATD LIST The following CATD forms are included as part of this report:
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03100'(11/18/86)
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