ML20236E287
| ML20236E287 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/28/1987 |
| From: | Frane J, Grill J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20236E191 | List: |
| References | |
| 204.2(B), NUDOCS 8710290158 | |
| Download: ML20236E287 (13) | |
Text
,
/ ' TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.2(B)
SPECIAL PROGRAM j
-REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: -1 TITLE:
-ORGANIZATION OR OPERATING PROCEDURES
. System Design Responsibility PAGE.1 0F 13
. REASON FOR REVISION:
1.
Revised format of text to improve clarity, deleted CATD 204 02 SQN 01 t
.because findings do not require corrective action.
PREPARATION PREPARED BY:
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DATE REVIEWS Wh.K:
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[IGNATURE TAS:
1 SIGNATURE DATE I
CONCURRENCE 5 8710290150 871023 ~
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PDR ADOCK 05000327 P
PDR CEG-H:
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SRP:
SIGNATURE DATE SIGNATURE
- OATE APPROVED BY:
ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE
(-
CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files, a___-________-
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^-
-' TVA EMPLOYEE CONCERNS ~
1 REPORT' NUMBER:: 204.2(B) L:
SPECIAL PROGRAM REVISION NUMBER:-
l' PAGE-2 0F _13 1.
- CHARACTERIZATION OF 'I'SSUES:-
l Concern:
Issues:
Respons bility and monito' ring for i
.IN-86-209-010 a.
"No specific. overall system overall system design isinot assigned
'l design responsibility.is-to a specific individual who:is know-ledgeable of.all aspects'of the. system,-
-currently assigned to a.
including interfacing support systems.:
specific person; There is not' someone monitoring overall
. design. 'The responsibility is
- b.
With one person. handling contract-fragmented.
Someone handles support, another mechanical,~another;
.the, contract,-another handles controls, another.electr.ical, etc, the mechanical' portions, another-
-responsibility.is fragmented and
- controls. instrumentation, another
-quality has been affected.-
- the electrical, etc.
They all.
together handle.the system.
There:is no one person you
- call'at' Knoxville and depend'
-on for technical responsibility.-
'You may have'a person's name, but
(,.
- as soon as:that person gets on the phone you find out very quickly'that the person is not' knowledgeable of the system.
. As=a' result of this fragmented
- approach, quality has' been affected..;CI has no. additional details. NUC POWER. Dept.
Concern."'
2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES NO X Identified by Not Applicable Date Not Applicable 3.
DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE
-IDENTIFICATIONS STATED IN ELEMENT:
No specific identifications.
04970-10 _(05/14/87)
l
)
l TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.2(B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 3 0F 13 4.
INTERVIEW FILES REVIEWED:
Expurgated file IN-86-209 was 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.
8.
EVALUATION PROCESS:
a.
Reviewed hierarchy of documents (e.g., 10CFR50, Appendix B, ANSI N45.2.ll, Regulatory Guides 1.64, and UFSAR) to l
establish criteria requirements and TVA commitments relative to the issues in Section 1.
b.
Reviewed engineering department quality assurance programs and procedures that establish design control to determine if they identify system design and responsibilities.
c.
Reviewed other documents to evaluate TVA's design practices, such as Institute of Nuclear Power Operations (INPO) reports, TVA memoranda, and Nuclear Performance Plans.
d.
Considered practices of other design organizations in tne industry.
4 04970-10 (05/14/87)
4 TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.2(B)
SPECIAL PROGRAM REVISION NUMBER:
1 i
PAGE 4 0F 13 9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
)
Chronology:
Late 1960s:
Sequoyah (SQN) plant design begins 10/15/68:
SQN issues PSAR to obtain construction permit 05/70:
AEC issues construction permit for Units 1 and 2 06/27/70:
10CFR50, Appendix B formally issued 01/70-SQN-QA Manual, through R12, Constitutes Engineering l
12/75:
Design Procedures in effect 09/73 -
Division of Engineering Design (EN DES) Engineering I
06/85:
Procedures (EPs) in effect I, i 1975:
Topical Report TVA-TR75-1A initially issued I
i 06/76:
TVA commits to Regulatory Guide 1.64 which endorses ANSI N45.2.ll-1974 09/27/80:
Operating License (0L) issued for SQN Unit 1 09/15/81:
Operating License (0L) issued for SQN Unit 2 l
06/85 -
Office of Engineering Procedures (0EPs) in effect, 06/86:
supersede EN DES EPs i
08/23/85:
TVA receives employee concern IN-86-209-010 08/85:
TVA voluntarily shuts down SQN Units 1 and 2 09/85 to SQN Project Manual (SQEPs and SQEP-AIs) in effect l
present 11/01/85:
TVA presents SQN Nuclear Performance Plan (Draft) and its Corporate Nuclear Performance Plan (Draft) to NRC 03/10/86:
TVA Corporate Nuclear Performance Plan (CNPP) Volume 1, R0, submitted to NRC 07/14/86:
Sequoyah Nuclear Performance Plan (SQN NPP),
Volume 2, revised and issued as R1 0497D-10 (05/14/87)
' TVA EMPLOYEE CONCERN 3 REPORT NUMBER:
204.2(B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 5 0F 13
(-
07/86 to Nuclear Engineering Procedures (NEPs) are.in effect; present:
supersede OEPs 08/13/86:
TVA CNPP Volume 1, revised and issued as R2 1
Discussion-
9.1 BACKGROUND
- Sequoyah is a two-unit nuclear power plant. Each of the two units employs a pressurized water reactor (PWR) nuclear steam supply system (NSSS), with four coolant loops, furnished by Westinghouse Electric Corporation.
The plant has been designed, built, and operated by TVA.
i The Sequoyah plant design was begun in the late 1960s when
)
implementation of regulatory requirements was not required to l
be well documented. The majority of the SQN licensing j
commitments were made in the late 1960s-and early 1970s, and j
some of the present day regulatory requirements do not I
pertain to Sequoyah..It is not necessary to update the
(..
Sequoyah plant to include all of the new guidance published by NRC, unless there are specific requirements or commitments to do so.
Although the Sequoyah Preliminary Safety Analysis. Report (PSAR) was released prior to issuance of 10CFR50, Appendix B, i
the Sequoyah engineering organization began to comply with the applicable regulatory criteria upon its issue as a draft document in mid-1969. Upon their. subsequent issuance, Appendix B of 10CFR50, ANSI N45.2.11, and Regulatory Guide j
1.64 were also complied with by TVA.
TVA engineering quality assurance program policy directives and engineering implementation procedures for the Sequoyah Nuclear Plant specify requirements to comply with the applicable regulatory criteria and are comparable to those
'3 used by other utilities in the nuclear power industry.
The issues identified in this element refer to the assignment of system design responsibility.
9.2 REGULATORY REQUIREMENTS The applicable regulatory requirements pertaining to these issues are contained in the following:
04970-10 (05/14/87)
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- TVA EMPLOYEE CONCERNS-REPORT NUMBER: ! 204.2(B).
- SPECIAL PROGRAM'
-REVISION NUMBER:
1:
PAGEL6_0F 13 s
q{
~: -
Title'10oftheCode:ofFederalRegulations,PArt50) o-(10CFR50), ChapterL1, ' Appendix B, " Quality Assurance Criteria for Nuclear Power Plants" (App.-'A,,6.a),-
a
. Criterion III, l' Design Control":is specifically
. applicable to these issues.
o
. ANSI N45.2.11-1974, " Quality Assurance-Requirements for the Design of Nuclear. Power Plants" (App. A, 6.c) o Regulatory _ Guide 1.64, " Quality Assurance. Requirements; for the Design of Nuclear Power Plants," R2,.(06/76).
(App.=A, 6.b), which accepts. ANSI N45.2.11-1974 as j
meeting 10CFR50, Appendix B
. \\;}
The.above criteria impose requirements to define.the j
- organizational structure within which the quality assurance -
j
- program.is to be implemented, and.to' delineate the authority and responsibility of the persons performing _ design.
activities.
The-criteria do not. however, specifically designate system design responsibilities.
1 1
9.3-TVA COMPLI ANCE PROGRAM AND' ENGINEERING PROCEDURES J
The Sequoyah Updated Final Safety Analysis Report..(UFSAR);
-(App.'A,6.d), including-topicalQA'programTVA-TR75-1A-
- (App. A, 6.e), commits' to-compliance with 'I.0CFR50, Appendix B criteria for establishing program documents to define design i
authority and responsibility.
The evaluation team first-reviewed-the Sequoyah Nuclear Plant Quality Assurance Manual (SQN-QAM - App. A, 5.g)' and-then the
'l past and present engineering procedures (EPs, OEPs,'and NEPs) y to determine which ones dealt with system design responsibility. The procedures reviewed cover the period of time from the development'of the Division of Engineering Design Engineering Procedures (EN DES-EPs) in 1973 through-the current Division-of Nuclear Engineering (ONE) Nuclear EngineeringProcedures(NEPs) issued 07/01/86.
All design engineering for the TVA nuclear power plants before j
09/73 was performed by the engineering branches in the Office 1
of Engineering Design and Construction. These engineering
)
discipline groups designed several nuclear plants concurrently, beginning in the late 1960s.
In 09/73, an
)
organization change at TVA resulted in the establishment of the Division of Engineering Design (EN DES). At that time, a project system was established that assigned engineers from the various engineering branches (Civil, Electrical, and i
4 04970-10 (05/14/87)
i TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.2(B)
~
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE 7 0F 13 Mechanical) to work exclusively on a specific project, such as Sequoyah. The Sequoyah project engineering team members, under a project manager, were assigned responsibility for r
maintaining the design activities related to Sequoyah, L
including any needed design changes.
Concurrent with establishment of the project system concept, new division-wide procedures, called EN DES-EPs, were established and were in effect from 09/73 to mid-1985.
The EPs were quite detailed and prescriptive, and included many administrative controls in addition to addressing quality 1
assurance requirements.
The EPs that were reviewed in detail for this evaluation are listed in Appendix A, 5.j.
In 06/85, new Office of Engineering Procedures (OEPs) became effective. The rf,w OEPs reduced or eliminated most of the administrative letails previously found in the EPs.
In place of a stand-alor,e procedure with many instructions, the OEPs referred the reader directly to other procedures that I
controlled individual activities. The end result was a series
(.
of single sentences that provided anyone unfamiliar with the process minimal direction on how to accomplish a given activity.
The OEPs reviewed in detail for this evaluation are listed in Appendix A, 5.1.
In 07/86, -the reorganized Division of Nuclear Engineering (DNE) Nuclear Engineering Procedures (NEPs) became effective.
Although these procedures closely resemble the content, format, and brevity of the OEPs issued a year earlier, there are some exceptions. These current procedures require the engineering Project Manual (App. A, 5.n)g the Sequoyah active use of other references, includin
, for full understanding of what is to be done. The NEPs reviewed in detail for this evaluation are listed in Appendix A, 5.m.
9.4 INVESTIGATION Proc _e_d_u_res_ _Appli_ cable to _ Issues The TVA engineering department quality assurance program manuals (App. A, 5.e through g) contain requirements and procedures that comply with applicable design control criteria. Although the procedures do not address " systems" design control, they do establish a responsible organization for all design control; i.e., EN DES, OE, or DNE.
l 04970-10 (05/14/87)
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- TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.2(B)
SPECIAL PROGRAM REVISION NUMBER:
1 1
PAGE 8 0F 13 Within EN DES, the assigrment of individual responsibility for system design and documer tation is indicated by the following i
definitions from the EN DES-EP manual (App. A, 5.j):
l
" System - A group of interrelated components that.
accomplishes some primary function of a plant. For
[ identification] purposes, all possible systems in a power plant are listed in... (1) Civil and Structural Systems List and (2) Electrical and Mechanical Systems List."
" System Engheer - The person (normally from the engineering support branch) who is responsible for the development of the system design criteria and is the most knowledgeable person en the requirements for system functioning."
" System Design Engineer _ - The person (normally from the design project) who is responsible for the detailed system design."
/
" Contract Engineer - A person who, in most cases, is
\\;
responsible for the preparation of specifications and requisitions, the review and evaluation of bids, 'and/or the technical administration of contracts."
l Very similar position descriptions appear in.the Office of Engineering (DE) Organization Manual (App. A, 5.k), which was in effect when concern IN-86-209-010 was received.
These position descriptions indicate that more than one engineer was responsible for the design and documentation of each system. Furthermore, the responsibility for multiple, interfacing systems was divided among various engineers, often j
from different disciplines.
j The current NEPs (App. A, 5.m), which supersede the f
corresponding OEPs, in like manner do not require that overall 1
system design control be assigned to one individual.
l l
Substantiation of Issues l
In 1981 and 1982, TVA internal memoranda (App. A, 5.p through 5.u) documented deficiencies in system design responsibility.
However, the authors of the memoranda advocated assigning a scope of responsibility to various individuals working on a system, rather than total system responsibility for one person.
0497D-10 (05/14/87)
L_ __ _ _ _ __ __
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
20'4.2(B)
SPECIAL PROGRAM REVISION NUMBER:
1-1 PAGE 9 CF 13 1
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In 1984, the Institute of Nuclear Power Operations (INPO) did j
recommend (App. A, 5.0) assigning-the responsibility for specific systems to individual engineers. This recommendation-was not adopted by EN DES because a multidiscipline team is necessary to design large, complex systems, and individual engineers could not be responsible for system components designed by other disciplines. Furthermore, while the system design work (including specifications and contract support) is divided with the team approach, there were, nonetheless, assistant project engineers who had overall responsibility for 4
guiding the system design effort.
The SQN Nuclear Performance Plan (SQN NPP - App. A, 6.f)
I describes a newly created System Engineering Section at SQN responsible for all aspects of their assigned systems including performance, modification, and troubleshooting. The section comprises multidisciplined engineers who provide a single contact point for system history, status, testing, and resolution of major system prablems. The Systems-Engineering Section at SQN was created in response to past instances of inadequate resolution of equipment-related problems.
It
. /y should be noted, however, that assigning individual I-
\\
responsibility for an operating system does not imply that the design responsibility for a new system can be assigned to one engineer.
After reviewing the decisions above and considering the systems involved, the evaluation team concurred that it was j
not possible in the design stage for individual engineers to be informed about all aspects of their system (s), including the interf acing support systems.
l Findings:
a.
In 1973, EN DES was established and engineers were assigned to project teams. Within each project team there were engineers who wer' responsible for the components (mechanical, electri al, etc.) in the system (s) assigned to them.
No one individual was responsible for the design and documentation of a complete system, including supporting systems.
A System Engineering Section has recently been established at SQN to proside a single contact point for each system.
These system engineers are responsible for performing or supervising l
engineering work, such as troubleshooting and modifications, on existing systems.
04970-10 (05/14/87)
(
TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.2(B)
SPECIAL PROGRAM REVISION NUMBER:
1 PAGE-10 0F 13 b.
Because the mechanical and electrical systems in a nuclear power plant are-large and complex, the. industry practice has been to design these systems ~with teams of engineers. divided into disciplines. At TVA, design engineers are responsible for certain components (mechanical, electrical, controls, etc.) within the systems assigned to them. Assistant Project l
Engineers have overall responsibility for guiding the combined i
system engineering efforts. TVA's assignment of responsibility for system design complied with the regulatory criteria and matched the practices of many private engineering firms engaged in power plant design.
i
==
Conclusions:==
Issue "a" is valid in that it is a statement of fact. However,
(
neither. regulatory criteria nor industry practice require that-individuals be responsible for the design and documentation of an entire system.
Issue "b" is not valid. While the actual design of interf acing systems is divided among the disciplines, the assistant project
('
engineers are responsible for the overall system engineering efforts. There is no evidence that the team design approach used by TVA detrimentally affected the quality of any TVA plant.
I 10.
CORRECTIVE ACTION:
No corrective action is required.
04970-10 (05/14/87)
[j.e I TVA EMPLOYEE CONCERNS-REPORT [NUMBERi 204.2(B);
SPECIAL PROGRAM
. REVISION NUMBERi 1
' PAGEcli 0F.13 -
f L
. 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 and Fuel Reprocessing Plants;"-
Criterion'III, " Design: Control" 4
b.
Regulatory Guide 1.64, " Quality Assurance Requirements' for the Design of Nuclear Power Plants," R2,- (06/76)-
c.
. ANSI N45.2.11-1974. " Quality Assurance Requirements 'for the -
Design of Nuclear Power Plants," Section 4, " Design Process" d.
Sequoyah' Updated Final Safety Analysis Report (UFSAR)- through~
Amendment'3 (04/86) e.
TVA-TR75-1A, " Quality Assurance Program Description for the =
Design, Construction, and Operation of TVA Nuclear' Power-Plants," R8.-(04/09/85)
.g f.
TVA Nuclear Quality Assurance Manual -(NQAM), (11/14/85) g.
Sequoyah Nuclear Plant Quality Assurance Manual (SQN-QAM),
(
'R12, (12/03/75);Section III, " Quality Assurance Procedures -
Design" h.
TVA NPP, Volume 1, Corporate Nuclear Performance Plan, R2, (08/13/86) 1.
TVA NPP, Volume 2, Sequoyah Nuclear Performance Plan, R1, (07/17/86) j.
TVA Division of Engineering Design (EN DES) Engineering Procedures Manual:
Definitions and Abbreviations EP 4.01, R10
" Signature / Initials," (04/25/85) f EP 4.04, R9 "Squadcheck Process," (04/24/84)
EP 4.25, R8
" Interface Coordination," (04/24/84) k.
TVA Office of Engineering (0E) Organization Manual, (04/26/85) 04970-10 (05/14/87)
=__
m,
,,,n
~
<W.
I TVA' EMPLOYEE CONCERNS'
' REPOR'T; NUMBER:. 204.2(B)~
SPECIALLPROGRAM REVISION' NUMBER: ;1-PAGE 12 0F 13
.5
~
APPENDIX A (Cont'd)
'1.
TVA Office'of Engineering-(OE). Procedures Manual:
0EP-08, R0_~
" Design.0utput,'f. (04/26/85)
H
'0EP-15, R0
" Interface _ Control," (04/26/85) 1 m.
TVA Division of Nuclear Engineering (ONE) Procedure's Manual: ~
NEP-3.3, R0
" Internal Interface Control,"-(07/01/86)
NEP-5.1, RO
" Design Output," (07/01/86) l Sequoyah Engineering Project
. Project Manual,gR0,-.(09/27/85)'
n.
O.
TVA Report " Recurring Findings, Recommendations,~and Good-Practices for INP0 Operating Plant Evaluations," (05/84);
~
p.
TVA memo from J. S. Colley to QAB Files,
Subject:
Situation-Study -~ System Engineers in EN DES-Report No.J1,
'[QAS810729004],(03/02/81).
q.
TVA memo from J. A. Raulston to-Those Listed, Subjecti j
Sequoyah and Watts'Bar Nuclear Plants - EN DES System Responsibility,[ NEB 810807-286],.(08/07/81) i r.-
TVA'memu from J. A. Raulston to M. N. Sprouse,
Subject:
All
.i Nuclear P1 ants - System Descriptions, [ NEB 810110 266],
- l (01/19/81)
J s.
TVA memo from M. N. Sprouse to Those Listed,
Subject:
Bellefonte,.Hartsville, Phipps Bend, and Yellow Creek Nuclear
)
Plants System Descriptions, [0ES 810202 003], (02/02/81)
{
t.
TVA memo from R. W. Cantrell to Those Listed,
Subject:
Sequoyah_and Watts Bar Design Projects - Syntem Design Responsibility,[SWP 811016 083], (10/16/81) l u.
TVA memo from M. N. Sprouse to Those Listed,
Subject:
All
]
Nuclear Plants - System Responsibility, [ NEB 820824 254],
l (08/24/82) i l
i k
04970 (05/14/87) i l
i TVA EMPLOYEE CONCERNS REPORT NUMBER:
204.2(B)
SPECIAL PROGRAM j
REVISION NUMBER:
1 PAGE 13 0F-13 APPENDIX A (Cont'd) l 6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR s
OTHER APPLY OR CONTROL IN THIS AREA?
a.
10CFR50, Chapter 1, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" l
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" i
d.
Sequoyah UFSAR updated through Amendment 3 (04/86) f e.
TVA-TR75-1A, " Quality Assurance Program Description for the i
Design, Construction, and Operation of TVA Nuclear Power Plants," R8, (04/09/85) f.
Sequoyah Nuclear Performance Plan, Volume 2, R1, (07/17/86) 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT:
Meeting with W. E. Troutt, TVA, and D. Popham, Bechtel, 9
a.
regarding audits of Sequoyah, IOM 51/ (11/21/86) b.
Meeting with J. French, TVA, and O. Popham, Bechtel, regarding) study of TVA systems design responsibility, IOM 51 (11/24/86 4
l 3
l l
k l
04970-10 (05/14/87) 1
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