ML20205Q813

Discusses Adequacy of Facility Design.Questions Whether NRC Being Strong & Clear in Stating Expectations of Util.Answers to Listed Questions Requested in Order to Better Understand Staff Position

ML20205Q813
Person / Time
Site:	Sequoyah
Issue date:	03/18/1987
From:	Asselstine J NRC COMMISSION (OCM)
To:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20205Q725	List: ML20205Q722 ML20205Q813
References
NUDOCS 8704060063
Download: ML20205Q813 (3)

Text

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EE UNITED STATES

+/ o y o NUCLEAR REGULATORY COMMISSION W ASHINGTON. D.C. 20555

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March 18, 1987

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• p OFFICE OF THE COMMISSIONER MEMORANDUM FOR: Victor Stello, Jr. ,

Executive Director for Operations l FROM: James K. Asselstine _i .

SUBJECT:

ADEQUACY OF SEOUOYA DESIGN In my ilanuary 21, 1986 memorandum to you regarding quality assurance at TVA, I asked, given the known inadequacy of TVA quality assurance programs in 1976, for what periods of time between 1976 and 1985 does the staff -

believe "TVA had and implemented an adequate QA program in the Headquarters Offices, at Browns Ferry, at Sequoyah and at Watts Bar." I continue to believe that such an assessment is necessary to reach judgments on, for example, whether the original licensing basis of Sequoyah was adequately justified and demonstrated at the time of licensing. If there are questions, uncertainties or unknowns in this regard because of QA and/or management problems, then clearly we would have to require TVA to do more than just evaluate the Sequoyah plant modifications subsequent to licensing. This was the approach the Comission took in the Diablo Canyon case. To my knowledge, the staff has yet to perform such an assessment.

The March 5,1987 letter from the Director of Inspection and Enforcement to the Manager of Nuclear Power at TVA raises questions about the adequacy of

! the initial design activities at Sequoyah. In addition, the TVA Manager of Nuclear Power in describing the weaknesses in TVA's nuclear program, indicated to the Comission on March 16, 1987 that the TVA organization was fragmented, unfocused and lacked proper direction and control for its nuclear activities. The TVA Director of Engineering also described the weaknesses in TVA's nuclear engineering program, including the lack of design control and the lack of coordination and comunication between engineering, operations and construction. There appears to be growing evidence that these problems did not sinply crop up in 1985 and 1986.

Rather, it appears that they are long-standing and systemic in nature. It also appears that these problems were not detected by our nomal licensing and inspection process.

l l The March 5,1987 letter transmits a sumary of a two-week inspection of TVA's Division of Nuclear Engineering design calculation review effort.

l i Following is an excerpt from that letter:

Many of the deficiencies identified by the inspection team as well as by TVA in its review involve initial design activities.. While the focus of TVA's effort in the DBVP has appropriately been on the design l

change process after the operating license was issued, TVA must, in l

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some fashion,-address the generic implications of instances where initial design deficiencies were identified. In this connection, we recognize that, in some areas, TVA has already indicated that it will conduct a complete review of calculations similar to those that have been found to be deficient.

In SECY 86-1C dated May 14, 1986, you made the following connents about design control at Sequoyah:

A TVA evaluation by Gilbert / Commonwealth, and confirmed by IE, revealed extensive design discrepancies. Examples include lack of-available calculations supporting the original design in some disciplines, temporary alteration procedures have been used for permanent design changes, and seismic requirements were not being adeauately handled. TVA is developing a design baseline and verification program. Resolution of design control issues may be the pacing item for Sequoyah restart.

At a February 13, 1987 meeting of the Office of Special Projects and the 4 outgoing project staff, Hugh Thompson informed Jim Keppler that NRP treated Watts Bar as Sequoyah Units 3 and 4 in their licensing review efforts of the Watts Bar facilities because the same organization, procedures and approaches were used at Watts Bar as were used at Sequoyah Units 1 and 2.

Given the above, I wender whether the NRC is being strong and clear in stating what we expect of TVA. In order to understand the staff's position, I would appreciate responses to the following:

1. Given the long history of TVA QA problems and the recently discovered problems in the prelicensing design work for the plants, why is the Design Baseline and Verification Program (DBVP) at Sequoyah

" appropriately" focused on the " design change process after the operating license was issued." In responding, I would appreciate the staff addressing the extent to which the Sequoyah plants have been subjected to design basis accidents or events during their operating histories.

2. What is meant by "...TVA must, in some fashion, address the generic implications of instances where initial design deficiencies were identified?" Does the staff have a clearer position on this matter?

3. In Enclosure 1, page 3 of SECY 86-1C the staff took the following position on design control problems at Sequoyah:

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TVA is developing a major design baseline and verification program. The program is expected to encompass plant systems necessary for safe shutdown and accident mitigation and provide

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assurance that the Sequoyah plant, as presently configured, meets all regulatory requirements and FSAR commitments. IE plans to review this TVA effort and assess the adequacy of th,is program and its implementation.

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. . Is this still the staff position? If not, what is the current staff position and what is the rationale for the change in position?

4. Given the above mentioned deficien'cies in the initial design .

activities for Sequoyah, what assurance is there that the Sequoyah l FSAR comitments are adequate? I

5. To what extent were the Watts Bar design approaches and controls the same as those for Sequoyah?

6. To what extent were the Watts Bar construction / procurement approaches and controls the same as those for Sequoyah?

7. At the time TVA requests restart of Sequoyab, shculd TVA be required to certify that the plant has been designed, constructed, and modified in accordance with the national standards and regulations applicable at the time of initial licensing? If not, why not? l

8. Should the NRC, at a minimum, conduct a detailed independent design inspection of all aspects of at least two safety systems of the i Sequoyah plants which would be of sufficient scope and depth to I determine the adequacy of the licensing of the plants prior to any i decision on restart?

cc: Chairman Zech Comissioner Roberts Comissioner Bernthal Comissioner Carr

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