ML20216H239
| ML20216H239 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/15/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20216H211 | List: |
| References | |
| 204.4(B), 204.4(B)-R01, 204.4(B)-R1, NUDOCS 8707010358 | |
| Download: ML20216H239 (28) | |
Text
S
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM i
REPORT TYPE:
SEQUOYAH ELEMENT-REVISION NUMBER: 1 TITLE:
ORGANIZATION OR OPERATING PROCEDURES Design Document Completeness - Inadequacy PAGE 1 0F 27.
Constructibility Concerns Missing Detail G-Specs REASON FOR REVISION:
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1.
Revised to incorporate TVA comments related to Revision 1 of the Sequoyah Design Baseline and Verification Program.
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PREPARATION PREPARED BY:
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APPROVED BY
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MANAGER OF NUCLEAR POWER DATE i
- SRP Secretary's signature denotes SRP concurrences are in filesCONCURRENCE (FINAL REPORT ONLY
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TVA EMPLOYEE CONCER'NS REPORT NUMBER:
204.4(B)
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SPECIAL PROGRAM REVISION NUMBER: 1 H
PAGE 2-0F 27 1.
CHARACTERIZATION OF-ISSUES:
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NOTE: These concerns and' issues were originally addressed to Watts Bar Nuclear Plant (WBN), which is' a construction permit (CP) plant.still under
. construction.. :Their applicability to a constructed, ' operating license (0L) plant which has been in operation,-is addressed in this report.
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Concerns:
Issues:
. WI-85-100-034 Engineering (EN. DES) inadequately ad-
" Engineering (ENDES) inadequately a.
addresses and considers' opera-dresses and considers construction,
, tion, maintenance, testing testing, operation,. maintenance, and construction requirements and general industry practices in and general industry practices the design process.
-in the design process.. There are'not forced interactions b.
The TVA General Construction Speci-with other utilities, no formal fications-(G-specs) are often system to track and assign inadequate and incomplete.
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commitment for problems identified to INPO, and poor c.
Engineering drawings often are tracking of NRC experience inadequate in that they information."
lack some technical detail (i.e., weld detail), do not always include or represent
.- WI-85-100-017
" Construction, test and install-design requirements, or ation specifications (called create interferences and cause general construction specs, with other constructibility problems a G-number) are often during installation.
incomplete'and inadequate. CI has no further information.
d.
There are conflicts between TVA ll Anonymous concern via letter."
drawings and vendor drawings.
TVA design not developed well-N EX-85-061-004 e.
" Drawings do not always show enough to be constructible; complete details,ti.e. specific therefore, drawings and 7
weld. size. Construction concern.'
acceptance criteria were frequently CI has no additional detail."
revised late in the project.
WI-85-100-038
" Design / installation drawings-do not always represent or 4
include design requirements.
Design guides / standards are utilized only when designers want to use them.
Design 0441D-29 (05/27/87) i
- 6. -
t TVA EMPLOYEE CONCERNS
' REPORT' NUMBER:
204.4(B)
SPECIAL PROGRAM
-REVISION NUMBER: 1 PAGE 3 0F 27 Concerns (cont'd):
Issues (con't):
guides / standards are inadequate NOTES:
The following~ issues from-in many. areas, and there are these concerns are_ addressed in other misuses, such.as applicable' Sequoyah element reports as parts are not referenced or indicated:
excerpted as requirements. CI-has no further information.
There.is no formal system to track Anonymous concern via letter."
and assign commitments for problems-identified by'the Institute of Nuclear 1
IN-86-133-004 Power Operations (INP0); there are'no-
" Management has problems with forced interactions'with other creating workable drawings utilities for information exchange; without having many problems and tracking of NRC experience infor-in ' installation.
Construction mation is poor (203.3).
concern. CI has no additional information'or details."
Design guides and standards are inadequate, misused, optional to IN-85-886-001 designers, and not referenced or "TVA designs were not developed excerpted as requirements on wel_1 enough to be constructible:
drawings (201.4).
- 1) design changes are still being instituted in areas Pipe support designs are'not where there should have been constructible(220.3).
minimal changes especially in area of conflicts between TVA Engineering design criteria are often and vendor drawings. 2) engi-nonexistent (201.3).
neering design criteria is often non-existent, particularly for Seismic support design criteria are
. seismic _ hanger design. Many nonexistent (201.3 and 220.3).
design criteria or acceptance criteria are still being Many design criteria ar'e changed late changed. This is generic in the project (201.3).
concern. Any further inform-
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ation would divulge confident-Pipe support drawings do not always iality. Construction Dept.
show all details, particularly weld concern. CI has not further sizes (222.3).
information."
p 04410-29 (05/27/87)
'E TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 27 4
2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by TVA SQN GCTF Date See documentation identifiers below:
Document Identifiers:
TVA SQN Generic Concern Task Force Report GCC-16-62 " Design a.
Drawings Not Constructible; Design Criteria Nonexistent," R1, (06/01/86) b.
TVA SQN Generic Concern Task Force Report GCC-12-58, "G-Specs Are Inadequate and Incomplete," R1, (06/06/86)-
3.
DOCUMENT NOS., TAG N05., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
None.
S 4.
INTERVIEW FILES REVIEWED:
Expurgated files for WI-85-100, EX-85-061, IN-86-133, and IN-85-886 were examined and no additional unreviewed information was found.
5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
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.
i 0441D-29 (05/27/87)
1 TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 27 8.
EVALUATION PROCESS:
Reviewed the hierarchy of applicable documents (e.g., 10 CFR 50, a.
Appendix B; ANSI N45.2.ll; FSAR) to establish criteria requirements and pertinent TVA commitments relative to the issues, i
b.
Reviewed for adequacy, current and past engineering department procedures establishing document review; checking and design verification practices; and responsibilities regarding construction, testing, operation, and maintenance requirements.
Reviewed for adequacy EN DES procedure 3.04, " Construction j
c.
Specifications - Preparation, Review, and Approval."
d.
Reviewed 27 G-Specs (of 59 G-Specs total) that relate to construction of nuclear power plants. The assessment of the l
adequacy of these specifications is based on the experience of the evaluation team and what they deem to he required in General Construction Specifications.
Reviewed approximately 500 SQN engineering drawings for specific l
e.
- -)
technical details, as part of the investigation for other Sequoyah g
element reports.
f.
Reviewed the Generic Concern Task Force (GCTF) reports of TVA's investigation of employee concerns for additional information.
Reviewed available transcripts of NRC investigative interviews for g.
additional information.
h.
Reviewed Sequoyah Nuclear Performance Plan (SQN NPP) and other TVA reports (i.e., CAQ Frequency Report) for information relative to this report.
9.
DISCUSSION, FINDINGS,ANDCONCLUSIONS:
Chronology:
i Late 1960s: Sequoyah (SQN) plant design begins 10/68:
SQN issues PSAR to obtain construction permit 05/70 AEC issues construction permit for Units 1 and 2 l
i 01/70-SQN-QA Manual, through R12, constitutes engineering 12/75:
design procedures in effect 0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS' REPORT NUMBER:
204.4(B)'
SPECIAL PROGRAM REVISION NUMBER: 1 l
{
PAGE 6 0F 27 09/73-Division of Engineering Design (EN DES) Engineering l
06/85:
Procedures (EPs) are in effect 09/80:
NRC issues Operating License (OL) for SQN Unit 1 l
09/81:
NRC issues OL for SQN Unit 2 04/85:
TVA issues Topical Report TVA-TR75-1 A, R8 06/85-Office of Engineering Procedures (0EPs) are in 06/86:
effect; supersede EN DES-EPs 07/85:
-TVA receives Employee Concern IN-85-886-001 08/85:
TVA voluntarily shuts down SQN Units 1 and 2 08/85:
TVA receives Employee Concern IN-86-133-004 09/85-Sequoyah Project Manual (SQEPs) is in effect present:
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10/85:
TVA receives Employee Concern EX-85-061-004 11/85:
TVA presents Sequoyah Nuclear Performance Plan (SQN NPP) initial issue and its (draft) Corporate Nuclear Performance Plan (CNPP) to NRC 11/85:
TVA receives employee concerns WI-85-100-017, -034, and -038 l
02/86:
TVA initiates Office of Nuclear Power Employee Concern Special Program 03/86:
TVA submits CNPP, Volume 1, R0, to NRC 05/86:
TVA issues formal Design Baseline and Verification Program for Sequoyah, R0 07/86-Nuclear Engineering Procedures (NEPs) in effect; present:
supersede OEPs 07/86:
TVA submits SQN NPP, Volume 2, R1, to NRC with CNPP, Volume 1, R1 i
08/86:
TVA revises CNPP, Volume 1, R2 0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 7 0F 27
9.1 BACKGROUND
The Sequoyah Nuclear Plant (SQN) design was begun in the late 1960s when documentation of compliance with regulatory requirements was not required to meet today's criteria. The majority of the SQN licensing commitments were made in the late 1960s and early 1970s, and some of the present day regulatory documents are not applicable to Sequoyah. Therefore, it is not mandatory to update SQN to include all of the new guidance published by NRC, unless there are specific NRC requirements and TVA commitments to do so.
The issues identified in this element refer to possible programmatic deficiencies in engineering design documents.
9.2-APPLICABILITY OF CONCERNS The concerns in this element were originally raised at Watts Bar Nuclear t
Plant (WBN). Because that plant and SQN have basically the same design and were completed utilizing the same engineering procedures, the concerns were deemed to be generically applicable to SQN. WBN is a construction permit (CP) plant still under construction, while SQN
' J) received operating licenses on Unit 1 and Unit 2, on 09/27/80 and 09/15/81, respectively. Construction and startup concerns are only partially applicable to a plant that already has begun operations.
Thus most originally stated concerns associated with drawing conflicts, acceptance criteria, interferences, constructibility, etc., should have been essentially resolved at SQN before or during preoperational and startup testing. Other concerns of this report could have persisted through the startup process and have some applicability to a plant that was in operation and might be extended to post-operating license (0L) modification work.
9.3 REGULATORY REQUIREMENTS AND CRITERIA The criteria cited in this section, as they became official, defined requirements for latter stages of original design and construction and for post-OL design changes and modification work at SQN. The applicable requirements pertaining to the issues in this element are contained in the following documents:
10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power o
Plants and Fuel Reprocessing Plants," (App. A, 6.a) 04410-29 (05/27/87)
i.
' TVA EMPLO.YEE CONCERNS REPORT NUMBER:
204.4(B) l SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 27 i
Criterion III, " Design Control" states:
. The design control measures shall provide ~for verifying or checking the adequacy of design, such as by j
the performance of design reviews, by the use of alternate j
or simplified calculation methods, or by the performance.
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of a suitable testing program.
l Criterion V. " Instruction, Procedure and Drawings" states:
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" Activities)affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type' appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria.
Criterion VI, " Document Control." states:
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" Measures shall be established to control the issuance of documents, such as instructions, procedures', and drawings, including changes thereto, which prescribe all activities
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affecting qualit_y. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel...."
Criterion XVI, " Corrective Action" states:
" Measures shall be established to assure that conditions adverse to quality, such as f ailures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective eetion taken to
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preclude repetition. The identification of the i
significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
y.
E TVA EMPLOYEE' CONCERNS REPORT. NUMBER:
204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1
'PAGE 9 0F 27
'o' 10 CFR 50.55, " Conditions of Construction Permits," Reporting Criteria for Significant 0eficiencies 50.55(e) (App. A, 6.c)
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50.55(e) states, in part:
- The holder of the permit shall notify the Commission of-each
. deficiency found in design and construction, which, were it to have. remained uncorrected, could have affected' adversely the safety of berations of the nuclear power plant at any time throughout'the expected lifetime of the plant."
ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design o
of Nuclear Power Plants" (App. A, 6.e)
TVA Engineering Quality Assurance' program policy directives and
- Engineering implementation procedures for. SQN have stipulated:
requirements in compliance with the applicable regulatory criteria, as they were' developed and published. Regulatory requirements were quite well established at the time of OL issue for SQN Unit 1 and are fully applicable to post-OL modificaiton work.
10 CFR 50, Appendix B contains requirements for quality assurance
-programs which require auditable engineering procedures. TVA engineering issued formalized engineering procedures-(EN DES-EPs) in 09/73.
Before l
that time, as was true throughout the nuclear industry, engineering processes were well established, and documents were issued in a controlled manner, even though formal procedures had not been written.
9.4 " CURRENT SEQUOYAH PROGRAMS In order to reconcile engineering design control and other issues, the Division of Nuclear Engineering (DNE) developed the Sequoyah Design Baseline and Verification Program (DBVP) (App. A, 5.h).
"The objectives of this program are:
To verify the adequacy of the plant modifications made since o
operating license (0L) to systems, or portions thereof, required to mitigate design basis events and to provide for i
safe shutdown of the plant To provide confidence that these modifications are supported by o
engineering analysis and documentation j
To provide confidence that these modifications are made in i
o conformance with licensing commitments 04410-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 10 0F 27 "The essential elements of the overall program are as follows:
Verifying and establishing the plant configuration o
o Reconstructing the Design Basis Reviewing and evaluating modifications since OL issuance o
against the design basis Performing the required tests or modifications developed from o
this review and evaluation."
These program objectives and elements will be met in two phases; pre-and post-restart phases. The pre-restart phase is to meet the above objectives for the selected systems for Unit 2, common systems, and Unit 1 systems required to operate Unit 2.
Unit 1 systems will be considered thereafter in accordance with schedules yet to be established.
The pre-restart selected systems are those systems or portions of those systems required to mitigate FSAR Chapter 15 design basis accidents, safely shut down the plant, and maintain safe shutdown condition. The 1
post-restart phase activities are those necessary to meet the program objectives for the remainder of the safety systems.
The DBVP requires that all design changes and design change documentation pending at the time of issue of SQN operating licenses, and issued thereafter, pertaining to these selected systems be evaluated for
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engineering adequacy. Physical changes implemented will be those required for system compliance with licensing commitments and design basis criteria.
A Desion Basis Document (DBD) procram has also been established for Sequoyah (SQEP-29) and is now being implemented (App. A, 5.q).
The DBD developm nt concept
....'is a top-down approach in which commitments made in generic l
upper tier design input documents, commitments made in licensing l
documents, design requirements, TVA policies and existing design criteria must be captured in either plant-specific design criteria or other design input documents. These design criteria must include, as a minimum, those general design criteria for site, plant, structures, ard systems which constitute the DBD.
Note that the design criteria required to be prepared prior to Sequoyah restart will be limited to those systems or portions of systems identified by SQN-0SG7-048."
8 0441D-29 (05/27/87)
L
TVA EMPLOYEE' CONCERNS REPORT NUMBER:
204.4(B)
SPh.CIAL PROGRAM REVISION NUMBERi 1 PAGE 11 0F 27 i
"The DBD constitutes a design input document that is commitment-driven. The development requires a combination of senior engineers and managers, who are familiar with the design evolution, to research the documents and identify the plant design requirements and commitments; and experienced working level engineers to prepare or revise the design criteria documents while ensuring that these design requirements and commitments are captured. The PE will accept and adopt this collection of design criteria documents along with the_ mechanical flow diagrams, functional control and logic diagrams, single line diagrams, the site plan, and plot plan, and the general arrangement drawings as the DBD for the plant.
The drawings will be the latest revision of the Configuration Control Drawing (CCD), if available, or the latest revision of the As-Constructed ( AC) drawing if the CCD is not available."
The DBD= provides, over the life of the plant,'the basis against which future plant modifications are measured.
In addition to the DBVP, special programs which have been identified as
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important to be resolved prior to restart include items such as:
resolving equipment environmental qualification questions; conducting a
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Control Room Design Review; reexamining cable tray support analysis for weaknesses in analytical basis; completing an electrical system analysis where design requirements'did not exist in the past; verifying adequacy of nonrigorously analyzed piping and supports where alternate analysis methodology had been improperly applied; and resolving a concern about
'the effects of a revised vendor analysis that increased temperatures during main steam lines break.
Also, additional confidence in Sequoyah Plant system integrity for restart should be gained through implementation of the following:
Office of Nuclear Power (ONP) - Configuration Control Task Force o
(CCTF) (App. A, 5.cc)
Design Change Process Improvements Program (App. A, 5.dd) o
'Sequoyah Nuclear Plant Change Control Board (CCB) (App. A, 5.r) o Specification Improvement Program (App. A, 5.bb) o All of the above programs, plus ongoing TVA QA and external audits, NRC inspections, and other categories of employee concerns investigations (e.g., welding, construction, operations, management, QA), are intended to provide additional confidence in the integrity of the plant design and construction, and its readiness for operation.
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04410-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
~
SPECIAL PROGRAM REVISION NUMBER: 1 s
PAGE 12 0F 27
'9.5 INVESTIGATION OF ISSUES A review of the NRC investigative interview (App. A, 5.z) did not disclose any additional information regarding these issues.
9.5.1 Considerations in the Enaineering Design Process - Issue "a" The engineering procedures that address the engineering design process (EN DES-EPs, OEPs, and NEPs) have been in effect from 09/73 to the present and thus are applicable to post-0L modification work. They list, among many other things, construction, testing, operations and maintenance as items to be considered as design input during the production of design documents and construction drawings.
If the above listed design considerations were not addressed because of lack of knowledge on the part of the designers and their supervisors, no programmatic correction, except perhaps additional training, would have solved the problem.
Constructibility.
If drawings failed to address construction requirements and caused "constructibility" problems, they could have
' 71 caused schedule delays and had adverse economic effects, but they should not have been allowed to compromise the integrity of safety systems. At SQN, problems of this type should have been resolved to an acceptable status before or during startup through the use of plant change documentation such as Field Change Requests (FCRs), and Engineering Change Notices (ECNs).
Issues regarding any problems associated with design drawings for modification work at SQN, are addressed in Sequoyah Element Report 204.6.
Testing.
It is the position of the evaluation team that the expressed concerns were applicable to testing associated with completion of construction and the start of plant operation. The power industry has continually questioned the inclusion of plant testing and startup facilities in the design.
The advisability and economics of installing testing equipment (gauges, pipe stubs, valves that must be serviced, etc.) that is used only once or twice in the life of the plant is a subject of some controversy.
Prudent engineerin'g practice, however, would address testing requirements in the design.
As a minimum, the design provided should not preclude the addition or installation of the required testing equipment when needed.
Some utilities have opted to add needed testing connections and other requirements during the latter phases of construction when the actual i
plant configuration becomes known.
I 04410-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)'
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 13 0F 27 The startup and testing of the NSSS safety-related systems were accomplished in accordance with the commitments made in the FSAR and under the purview of the NSSS vendor and the AEC/NRC.
.The issues regarding any problems associated with preoperational and postmodification testing are covered by Sequoyah Element Report 213.2.
Operations and Maint anance Requirements. Prudent engineering practice addresses operations and maintenance requirements in the design process.
There is a tradeoff between the preferences of the operations and maintenance personnel, the realities of design requirements, and consideration of plant economics. The plant design can favor any of these elements, btt usually at the expense of the others. The priorities are often dictated by econrmic requirements of the utilities.
If it is-more appropriate to finance maintenance costs than it is to finance
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construction ecsts, the management may insist on a lower first cost plant, perhaps at the opense of higher maintenance costs.
Ideally, the design of the plant properly balances all considerations. The design provided should not preclude the addition of any required items when needed, and.should allow accessibility to all plant features for maintenance.
.m While TVA's Sequoyah Nuclear Performance Plan (SQN NPP) (App. A, 5.1)
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cites difficulties in performing plant maintenance, it does not cite Engineering, or the content of engineering drawings, as a cause.
It does, however, cite the "as-constructed" and "as-designed" drawing system as-a source of the drawing congruency difficulties that have affected i
maintenance work. This subject is addressed in detail in Sequoyah Element Report 206.1.
General Industry Practices. Utility personnel attend industry meetings and seminars where industry methods are discussed.. Methods that work well and have general. application eventually become accepted'and in time become recognized as a general practice. However, it is always subject i
to change.
Practices that approach standardization throughout the industry are
- usually those that meet applicable codes and standards, and are economically advantageous. TVA must meet the requirements of industry codes and standards, but is not under a mandatory commitment to follow any other " general practices." For example, INP0 suggested good practices are not mandatory.
g l
The SQN NPP cites an NRC inspection and a TVA survey which resulted in i
the following. issue:
04410-29 (05/27/87) 1
-TVA EMPLOYEE CONCERNS' REPORT NUMBER:
204.4(B)-
SPECIAL PROGRAM REVISION NUMBER: -1 PAGE 14 0F 27 "In several cases standard industry codes and practices were l
not followed in the samples of original work examined by the' j
- NRC staff in conjunction with the review of the Gilbert / Commonwealth effort."
9.5.2 General Construction Specification (G-Specs) - Issue "b" TVA G-Specs have been in existence since 1939 when they applied'to construction of dams and reservoirs. They have since been updated and expanded to be applicable to power plants. Project Construction Specifications are used.to augment or modify'G-Specs for a specific project-or site application.
In 1974, EN DES Procedure 3.04 (App. A, 5.j) was issued to govern the preparation and approval of G-Specs for the nuclear plants. At.that time, the specs were-also indexed and formal control was initiated.
The SQN construction permit was issued in 05/70. The G-Specs that affect safety-related structures. and systems for SQN were issued after 08/76,.
when the project was well into the-construction phase. Parts of the
-G-Specs could have been. referenced or included in later stages of construction and in post-0L modification work.
TVA is now undertaking a Specification Improvement Plan (App. A, 5.aa and
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5.bb), which requires replacement of " General Construction Specifications"_with " Engineering Requirements (ER) Specifications." The new specifications will take precedence over drawings, will be project-unique, and will require additional approvals. This approval will come from appropriate departments, including. responsible discipline branch, construction / modifications, and nuclear quality assurance.
Twenty-seven G-Specs, of a total of 59, are applicable to TVA nuclear plants and were reviewed for adequacy and completeness. Two of the specifications, G-43 and G-73 (App. A, 5.s), were examined by the evaluction team in detail during evaluations for other Sequoyah element reports. Twelve of the remaining G-Specs were reviewed by specialists on the evaluation team for specific content pertaining to pipe supports, bolting, cadwelds, etc.
The balance of the specs were given a cursory review. The TVA SNP GCTF Investigation Report, "G-Specs Are Inadequate and Incomplete," (App. A, 5.v) was not comprehen,ive and did not address G-Spec adequacy or completeness.
9 5.3 Engineerino Drawings - Issue "c" The objective of the regulations and other documentation listed in Section 6 of Appendix A of this report is to control the design process i
and to help prevent drawing and other design document deficiencies, such as those alleged in the issues. The regulations require procedures for 0441D-29 (05/27/87)
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 15 0F 27 review, approval, checking, control of changes, etc., of the engineering
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design.
1 Drawina Procedures and Reviews. The SQN-QA manual, which contained a few
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procedures in effect from 01/70 to 09/73, was not specific about approval j
requirenents for engineering design drawings. The Division of
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Engineering Design (EN DES) engineering procedures (EPs), which superseded the procedures, in the QA manual in 09/73, were quite specific. While reviewing the EPs in effect for issuing original (App.
A, 5.m) and revised ( App. A, 5.n) engineering drawings, the evaluation team found that the procedures were quite comprehensive and required at least seven signatures, including that of the checker, before the drawing could be issued. The procedures stated that the checker's signature signified that (a) the design review is complete; (b) all required
. interface coordination, including requested review, is done; (c) the 4
design complies with all design input and the necessary assumptions; and (d) calculations (including referenced computer printout) necessary to prove the design on the basis of (c) are approved.
Office of Engineering Procedures (0EPs), which superseded EN DES EPs in 06/85, required five approval signatures on the drawing before issue.
Depending upon the extent of the review, the design input review
-s documentation required additional approval signatures. The present Department of Nuclear Engineering (DNE) procedures (NEPs), which superseded corresponding OEPs in 06/86, meet the requirements in a slightly different manner; however, they require six signatures before a drawing is issued.
The issue that engineering drawings do not include or reflect design requirements depends on the postulate that the design error or omission remained after all drawing checks and design reviews. Therefore, the type of technical deficiencies stated in the issues would be the result of lack of knowledge on the part of the document originator and subsequent reviewers, and would not be prevented by any programmatic process or procedure.
Other Desian Reviews. Most of the safety-related plant components were produced and supplied by the NSSS vendor. The NSSS vendor reviewed the designs of some safety-related systems and components supplied by others. The nuclear safety systems were given detailed scrutiny by the NRC during the licensing process as well as thereafter.
NRC IE Bulletin 79-14, issued in 1979 ( App. A, 5.d), required a program to demonstrate, with a high level of confidence, that the as-constructed piping configuration agrees with the as-analyzed configuration. The i
scope of this program included all seismic Category I piping systems regardless of pipe size if they were computer analyzed, and all Seismic Category I piping systens larger than 2-1/2 inches in diameter if they were analyzed using the span methui.
0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS
' REPORT NUMBER:
204.4(B)
~ '
SPECIAL PROGRAM REVISION NUMBER: l' l
PAGE 16 0F 27 As a result of this program, all SQN seismic Category I piping systems were or are'to be examined to verify the agreement between as-constructed and as-analyzed configurations. This configuration check included verification of pipe support locations and types, clearances between the piping and adjacent plant features, etc. This program is complete for SQN Unit 2 and is essentially complete for SQN Unit.1.
Federal Regulation 10 CFR 50.49, (App. A, 6.b), which became effective on 02/22/83, requires that all electrical equipment important to safety be evaluated for its ability to remain functional in the environment to which it would be subjected during normal operation and'during design basis events (including earthquakes).
A program to demonstrate environmental qualification of SQN electrical equipment and components important to safety was implemented, completed, and documented.
Issues regarding problems associated with equipment qualification are
. addressed in Sequoyah Element Report 210.2.
In the late 1970s and thereafter, as a result of the Three Mile Island l
(TMI) incident, all nuclear power plants received extensive evaluations resulting in considerable rework to plant safety systems and components.
.n9 In. addition-to the above evaluation program, SQN has, as part of' its
~
. restart program, committed to the DBVP (see Section 9.3 above), which contains constituent efforts intended to evaluate and update specific areas of concern to meet present day regulations and requirements.' As part of this program, applicable control room drawings are to be updated l
and corrected.
Other SQN programs include investigation, evaluation, and updating of required information in systems and categories, such as cable tray support, electrical systems, pipe supports, main steam temperature, welding, and programmatic considerations (procedures and policies). The first phase of this program (that necessary for Unit 2 restart) is near completion.
In addition, TVA has the Conditions Adverse to Quality (CAQ) document data base program that lists CAQs in alpha numeric order and indicates the involved component, organization responsible, and type of problem.
It also has the trend analysis program that handles, categorizes, and provides feedback on the source and cause of continuing problems.
In the CAQ-bata Base Frequency Report of 12/01/86,3750 CAQ documents are categorized and fifty seven (57) CAQ documents, or 1.5 percent, address problems associated with engineering drawings.
i 0441D-29 (05/27/87) 1
TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.4(B) j SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 17 0F 27 9.5.4 Vendor - TVA Drawing Conflicts - Issue "d"
The issue of conflicts between TVA drawings and vendor drawings, as it applies to a plant that has been in operation, was not exhaustively investigated, because at SQN any significant discrepancies had to have i
been resolved to the extent necessary to start up and operate the plant.
TVA corrective action report SQ CAQ 86-01-004 (01/30/86) ( App. A, 5.y) states, "Certain vendor manual and drawings contained in SQN Environmental Qualification (EQ) Binders do not match with plant controlled vendor manuals..."
Nuclear Safety Review Staff (NSRS) Investigative report I-85-473-NPS (03/07/86 - App. A, 5.x) confirmed that vendor manuals were found with drawings that did not meet the "as-built" plant hardware.
Conversations with TVA personnel have also indicated that there are conflicts between vendor information, SQN documentation, and installed hardware.
The SQN CAQ Data Base Frequency Report of 12/01/86 indicates that of the
's I 3750 CAQ documents catalogued, 47 or 1.3 percent are germane to vendor documentation.
In addition, the examination of all safety system electrical equipment required by the Environmental Qualification Program and the TMI rework could help to identify discrepancies between SQN drawings and vendor drawings.
9.5.5 Late Enaineering Changes - Issue "e" The issue of design drawings and acceptance criteria heing changed late in the project construction phase was not addressed in detail in this report. At SQN, these issues should have been resolved to the extent necessary to complete construction, and to start up and operate the plant. Needed and justified changes would have been made regardless of the state of the project at the time.
Issues regarding problems with design drawings and acceptance criteria for modification work are addressed in Sequoyah Element Report 204.6.
Findinos:
TVA engineering procedures that have been in effect since 09/73 (EN l
a.
DES-EP 4.25, OEP-06, and NEP-3.2) all state that construction, testing, operations, and maintenance requirements and codes and standards must be considered during the design process. The 0441D-29 (05/27/87)
1
]
h.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 l'
s PAGE 18 0F 27 evaluation team found that these procedures are adequate for addressing these requirements.
Although specific instances have been identified where certain aspects.of the design process were in error, the evaluation team did not find pervasive evidence to indicate that the design considerations stated above had been ignored or neglected for SQN.
The evaluation team ulso found that, in the past, SQN engineering design processes did not always adhere to applicable regulations and industry accepted codes and standards.
b.
The evaluation team's review of the G-Specs that pertain to TVA nuclear plants found that for general specifications they are sufficiently complete and are adequate.
There are several instances of outdated references and in one instance, a minor conflict with another construction document was found; G-Spec 43 contains information on pipe supports that conflicts with the Construction-issued Modifications and Additions Instruction 11 (M&AI-ll). This subject is addressed in detail in
^;)
Sequoyah Element Report 220.1.
L A review of the CAQ Data Base Frequency Report indicated that only
[
one SQN CAQ document of the 3,750 listed was G-Spec related.
c.
The evaluation team found instances where SQN design drawings were inadequate and did not include or reflect all necessary details and design requirements.
In one instance, the drawings omitted several pipe hanger welds. Another instance involved the use of mixed bolted and welded beam connections.
Another instance involved the L
investigation of the employee concern (IN-85-886-N04) that no seismic analysis was performed for local instruments. There are others instances cited in other Sequoyah element reports.
i Also, Gilbert / Commonwealth Report 2614 ( App. A, 5.t) found that mounting details for instrumentation were inadequate. TVA Employee Concern Special Program Element Report 80501-SQN ( App. A, 5.w) also found problems with instrument mountings.
A review of the 12/01/86 CAQ Data Base Frequency Report revealed that 57 out of the 3,750 CAQ documents listed (1.5 percent) indicated that drawings were the source of the problem or the at-fault item.
i d.
The issue that there are sone conflicts between TVA drawings and vendor drawings late in the project was found to be true.
04410-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE-19 0F 27 The issue that engineering design drawings and acceptance criteria e.
are changed late in the project was found to be true. Changes are made when needed and to respond to regulatory or design requirements. Procedures are, and have been, in place for making needed changes.
==
Conclusions:==
The finding that SQN did not always adhere to applicable regulations a.
and industry accepted codes and standards is valid.
It is noted that, except for those practices that meet requirements of accepted codes and standards, TVA is not obligated to comply with other industry. practices.
It is reasonable to assume that some of the operation, maintenance, construction, and testing problems at SQN are the result of inadequacies in the engineering process.
It can also be concluded that problems of this type that would have prevented construction, startup, and operation of the plant would have been resolved.
@~
In addressing engineering concerns and in instances where engineering inadequacies were identified, the evaluation team either acknowledged in its Sequoyah element reports that corrective rocesses were in place, or corrective action tracking documents p(CATDs) were issued with the element report to start the corrective action process. Engineering inadequacies are addressed in the SQN Element Reports 201.1 through 243.0.
b.
The G-Specs applicable to SQN when compared to those in use in the industry, are sufficiently complete and adequate, and are also applicable to post-OL modification work. Therefore, the issue is not valid for SQN.
In addition, the present G-Specs are being l
replaced with Engineering Requirements (ER) Specifications in accordance with the TVA-Specification Improvement Program now being implemented. These ER Specs are intended to be site-specific rather than of a general nature.
The issue that engineering drawings do not always include or c.
represent design requirements is valid, but only to a limited l
extent.
In general, the SQN drawings reviewed are adequate.
Any instances of missing design requirements which would have prevented SQN construction, testing, or plant operation would have been resolved.
0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 20 UF 27 In addressing engineering concerns and in instances where technical details became identified as missing or in error, the evaluation team either acknowledged in its Sequoyah element reports that corrective processes were in place, or CATDs were issued with the element report to start the corrective action process.
Engineering inadequacies are addressed in the Sequoyah Element Reports 201.1 through 243.0.
d.
The issue that some TVA drawings conflicted with vendor drawings-late in the project is valid as with any large construction project such as SQN. However, there is no apparent reason to believe that any significant problems that would affect plant operation would not have been resolved during the construction /startup phase of the project.
TVA has, however, committed to developing and implementing the ONP Configuration Management Plan, which should correct these problems and ensure that vendor manuals are maintained current. This subject is covered in Sequoyah Element Report 204.7.
e.
The issue that engineering drawings and acceptance criteria were-l i
.M..
changed late in the project is valid. However, this situation does not represent a problem, because changes are made when they are needed and justified, regardless of the timing. Procedures are, and have been, in place for making such changes.
- 10. CORRECTIVE ACTION:
Since the above noted corrective actions required by other engineering category element reports are now in place and being implemented, no l
further corrective action is noted in this Sequoyah element report.
Corrective action programs at SQN include the Design Basis and Verification program which provides procedures for:
Packaging and Controlling walkdown/ test documentation SQEP-08 o
Identifying and assembling change documentation SQEP-11 o
e Evaluating engineering change notice (ECN) and field change notice l
o (FCN) documents SQEP-12 l
o Transitional design change control SQEP-13 l'
Interface with change control board (CCB) SQEP-15 o
Systems evaluation and development of systems evaluation report o
SQEP-16 Comparison of control room as-constructed drawings to as-designed i
o drawings SQEP-19 0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 i
1 PAGE 21 0F 27 Also included are SQN NPP programs intended to:
o Resolve questions about electrical equipment qualification o
Verify adequacy of past plant modification o
Reexamine cable tray support analysis o
Complete electrical system analysis o
Verify adequacy of piping supports o
Resolve questions on main steamline break temperature o
Verify plant configurations o
Find trends in the CAQ "at-fault" items 1
f 0441D-29 (05/27/87) j
TVA EMPLCYcE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 22 0F 27 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
Title 10 of the Code of Federal Regulations, Part 50, (10 CFR 50), Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" 5.
Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Section 50.49, " Environmental Qualification of Electrical Equipment Important to Safety For Nuclear Power Plants," (01/01/86) c.
Title 10 of the Code of Federal Regulations, Part 50, 10 CFR 50.55, " Conditions of Construction Permits," Reporting Criteria for Significant Deficiencies 50.55(e) d.
NRC OIE IE Bulletin 79-14, " Seismic Analysis for As-Built Safety-Related Piping Systems," R2, (07/18/79)
[')
e.
NRC Regulatory Guide 1.64 " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76) f.
ANSI N45.2.11, " Quality Assurance Requirements for the Design of Nuclear Power Plants," Section 4, " Design Process,"
Section 7 " Document Control," and Section 8, " Design Change Control" g.
TVA Topical Report TVA-75-1A R8, " Quality Assurance Program Description for the Design, Construction, and Operation of the TVA Nuclear Power Plant," (Section 17 of the FSAR) h.
Sequoyah Nuclear Plant, " Design Baseline anh-Verification Program," R1, (B25 870212 041), (02/12/87) 9 1.
Sequoyah Nuclear Performance Plan, Volume 2, Final Concurrence, Chapter II-4, " Maintenance" (L44 860714 800),
(07/14/86) j.
TVA Engineering Procedure EN DES-EP 3.04, '"EN DES Construction Specifications - Preparation, Review, and Approval," R13, (02/14/84) i k.
TVA Engineering Procedure EN DES-EP 4.01, " Signature / Initials for Preparation, Review, and Approval of EN DES drawings,"
R10,(04/25/85) 0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS-REPORT NUMBER:
204.4(B) l SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 23 0F 27 l
APPENDIX A (Cont'd) 1.
TVA Engineering Procedure EN DES-EP 3.10, " Design Verification tiethods and Performance of Design Verification,"
R7,(04/25/85) i m.
TVA Division of Engineering Design, Engineering Procedure, EN DES-EP 4.01, " Signatures / Initials for Preparation, Review, and Approval of EN DES Drawings," R10, (04/25/85) l n.
TVA Division of Engineering Design, Engineering Procedure, EN DES-EP 4.21, " Revision and Voiding EN DES Engineering Drawings," R3, (10/18/83)-
Office of Engineering (OE) Procedures (OEPs) Manual o.
p.
DNE Nuclear Engineering Procedures (NEPs) Manual q.
Sequoyah Engineering Procedures (SQEPs) Manual Procedure for DNE Interface with Change Control Board (CCB)
E'*
r.
SQEP-15, (08/01/86) s.
TVA General Construction Specifications (G-Specs) as follows:
G-1, " General Instructions Applying to the Construction of Major TVA Projects," R0, (02/15/80)
G-2, " Plain and Reinforced Concrete," R5, (11/01/85)
G-8, "Formwork for Concrete," R0, (02/08/76)
G-9, " Rolled Earthfill for Dams and Power Plants," RS, (11/16/79)
G-21. " Masonry," R1, (06/28/84)
G-22, " Finishing Concrete Floor Surfaces," R1, (04/23/79)
G-27, " Quality Control for Construction of Pipint Systems for l
Boiling Water Reactor Nuclear Power Plants," RO, (12/12/68)
G-28, " Construction of Piping Systems for Boiling Water Reactor Nuclear Power Plants," R7, (12/30/82) i G-30, " Fly Ash for Use as an Admixture in Concrete," R1, (09/18/80) 0441D-29 (05/27/87)
'TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 i
PAGE 24 0F 27-1 APPENDIX A (Cont'd)
G-36, " Quality Levels of Structural Materials," R0, (08/09/83)
G-38, " Installing Insulated Cables Rated Up to 15,000 Volts,"
R7,(01/15/86)-
G-39, " Cleaning During Fabrication of Fluid Handling Components," R9,.(09/05/85)
G-40, " Installing Electrical Conduit Systems and Conduit Boxes," R9, (01/15/86)
G-43, " Support and Installation of Piping Systems in Category I Structures," R8, (08/08/85)
G-46, " Installation and Initial Operation of EHV Transformers, Large Power Transformers, and Shunt Reactors,"
R0,(02/12/75)
I G-47, " Installing Electrical Grounding Systems," R1, (07/09/84)
G-50, " Torque and Limit Switch Settings for Motor-0perated Valves," R2, (03/14/84)
G-51, " Grouting and Dry-Packing of Base Plants and Joints,"
-R2, (11/01/85)
G-52, " Mechanical (Cadweld) Splices in Reinforcing Bars of Category I Concrete Structures," R1, (10/31/79)
G-53, "ASME Section III and Non-ASME Section III (Including AISC, ANSI /ASME B31.1, and ANSI B31.5) Bolting Material," R5, (10/10/85)
G-55, " Surface Preparation, Application, and Inspection of Special Protective Coatings for Nuclear Plants," R4, (08/10/84)
G-59, " Installation of Condenser Tubes," R0, (01/11/79)
G-60, Bellefonte and Future, " Field Routing of Instrument Impulse Lines, Sample Lines, and Control Air Lines," R1, (ECB i
850211 503), (02/14/85) 0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 204~.4(B) c SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 25 0F 27-APPENDIX A (Cont'd)
G-64, " Installation of Buried Piping - Civil Aspects," (R0 in work)
G-69, " Quality Assurance Requirements for Construction of Radioactive Waste Management Systems," R1, (10/18/84)
G-73, " Inspection, Testing, and Documentation Requirements for Fire Protection Systems and Features," R0, (0?/16/82)-
G-80, " Limited Quality Assurance Requirements for Security
' Systems," R1 (08/12/83) l t.
Gilbert / Commonwealth, Inc., Report No. 2614, " Final Report Technical Review of Sequoyah Nuclear Plant Modification for TVA," (03/03/86)
TVA SNP GCTF Investigation Report, " Design Drawings Not u._
Constructible; Design Criteria Non Existent," R1, _(06/01/86) q.;
TVA SNP GCTF Investig(ation Report, "G-Specs Are Inadequat v.
and Incomplete," R1, 06/06/86)
TVA Employee Concern Special Program Element Report w.
80501-SQN, Engineering Document Quality," R4, (01/07/87) x, NSRS Report I-85-473-NPS (03/07/86) l TVA QA Corrective Action Report SQ-CAR-86-01-004, (01/04/86) y.
Letter from B. J. Youngblood, NRC, to S. A. White, TVA z.
(B45 860714 832), 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, (06/23/86) l TVA memorandum from W. C. Drotleff to Those Listed, aa.
" Specification Improvement Plan," (RIMS No. B05 860808 001),
i (08/08/86) bb.
TVA memorandum from J. A. Kirkebo to J. E. Huston, " Revision to Specification Improvement Plan" (RIMS No. 880 861008 001),
(10/08/86) e TVA memo from CCTF to S. A. White, " Office of Nuclear Power cc.
(ONP) - Configuration Control Task Force (CCTF) Final Report," (06/30/86) 04410-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: ' 204.4(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 26 0F 27 APPENDIX A (Cont'd) dd.
TVA memo from W. C. Drotleff to S. A. White, " Design Change Process Improvements Program," (08/01/86)
Sequoyah Element Reports 201.1 through 243.0 ee.
6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
Title 10 of the Code of Federal Regulations, Part 50, a.
(10 CFR 50), Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" b.
Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Section 50.49, " Environmental Qualification of
-l Electrical Equipment Important to Safety For Nuclear Power Plants," (01/01/86)
Title 10 of the Code of Federal Regulations, Part 50,
)
c.
10 CFR 50.55, " Conditions of Construction Permits," Reporting
'~
Criteria for Significant Deficiencies 50.55(e) d.
NRC Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
ANSI N45.2.11, " Quality Assurance Requirements for the Design e.
of Nuclear Power Plants," Section 4, " Design Process,"
Section 7, " Document Control," and Section 8, " Design Change Control" f.
Sequoyah Updated FSAR (UFSAR) through Amendment 3, (04/86)
Sequoyah Nuclear Performance Plan, Volume 2, Final g.
Concurrence, Chapter II-4, " Maintenance" (L44 860714 800),
(07/14/86) h.
DNE Nuclear Engineering Procedures (NEPs) Manual i.
Sequoyah Engineering Procedures (SQEPs) Manual i
0441D-29 (05/27/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.4(B)
SPECIAL PROGRAM j
REVISION NUMBER: 1 l
PAGE 27 0F 27 APPENDIX A (cont'd)
~
7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND 0THER DISCUSSIONS RELATED TO ELEMENT.
a.-
RFI-SQN 680 (11/03/86) b.
RFI-SQN 689 (11/04/86) c.
RFI-SQN 721 (11/17/86) d.'
RFI-SQN 730 (11/19/86) e.
RFI-SQN 799 (02/19/87) 04410-29 (05/27/87)
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