ML20236E291

Rev 0 to Organization or Operations Procedudesign Responsibility Field Vs Ofc, TVA Employee Concerns Special Program

ML20236E291
Person / Time
Site:	Sequoyah
Issue date:	04/11/1987
From:	Leslie J, Walters R TENNESSEE VALLEY AUTHORITY
To:
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References
204.3(B), NUDOCS 8710290160
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7 TVA' EMPLOYEE-CONCERNS-REPORT. NUMBER: -204.3(B)-

-SPECIAL PROGRAM.

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' REPORT TYPEi SEQUOYAH ELEMENT

' REVISION NtMBER:

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TITLE:

10 ORGANIZATION OR OPERATIONS PROCEDURE Design Responsibility.

PAGE 10F 17

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-REASON FOR REVISION:

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~TVA EMPLOYEE CONCERNS REPORT NUMBER:

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SPECIAL PROGRAM REVISION NUMBER: 0 h

PAGE?2 0F 17.

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~ CHARACTERIZATION OF ISSUES:_

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Concern:

Issue:

l WI-85-091 -015 a.

'TVA leaves too many technical H

"TVA leaves too many technical-decisions-.to the discretion of 1

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. decisions up to the crafts' the craft personnel (e.g., hangers).-

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-discretion, e.g. craft design L

the' hanger.and then engineering does'the as-constructed drawing.

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'CI has no further information.

NOTE:

l Construction Dept concern."

Sequoyah Element Reports 212.2, 223.3, 220.3 and 80501 relate to this issue of field fabricated supports.

2.

HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES-NO X-Identified.by Not Applicable Date Not Applicable' Document Identifiers:. Not Applicable l

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DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE

-i IDENTIFICATIONS STATED IN ELEENT:

No specific identifications.

4.

INTERVIEW FILES REVIEWED:

Expurgated file WI-85-091 was reviewed, and no additional unreviewed information was found.

5.-

DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

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6.

WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?

See Appendix A.

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REVISION NUMBER: 0 PAGE 3 0F 17 7..

' LIST REQUESTS FOR 'INFORMATION, ' MEETINGS, TELEPHONE CALLS, AND' 0THER LDI5GU55 IONS RELATED TO ELEMENT.

.See Appendix-A'.

8.-

' EVALUATION PROCESS:

a.

. Reviewed hierarchy of documents (e.g.,-10CFR50,- Appendix B and ANSI N45.2.11) 'to determine' criteria requirements and TVA.

coninitments pertinent to the issue ~ iniSection 1.

1 b.-

Reviewed adequacy of engineering department procedures that' establish omanizational structure as well as~interf ace and communications control between the design office,and the '

field craf ts.

c..

Reviewed other mechanisms for. establishing practices and-1

. responsibilities, such as quality assurance program.(Topical

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5 (b

. Report TVA-TR75-1 A) and EN DESiorganization;~ reviewed reports -

(e.g... Institute of Nuclear Power Operations [INP0] findings, i

Nuclear Performance Plans [NPPs]). relative to the abov ;

d.

Examined adeauacy of; the active. procedures to meet criteria req ui rements.

e.

Reviewed EN DES practices for compi.iance to procedures;-

I reviewed results of program audits.

f.

Reviewed TVA trend reports to identify any findings and trends relative to design and design change control.

9.

DISCUSSION, FINDINGS, AND CONCLUSIONS:

Chronology:

Late 1960s:

Sequoyah (SQN) plant design begins j

10/15/68:

SQN PSAR issued mid-1969:

Draft 10CFR50 Appendix B issued 06/27/70:

10CFR50 Appendix B formally issued 07/70-SON QA Manual, through R12, constitutes Engineering i

12/75:

Design Procedures in effect j

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Office of Engineering Design (EN DES) Engineering mid-85:

Procedures (EPs)ineffect 06/06/74:

ANSI N45.2.11-1974 issued 1

1975:

Topical Report TVA-TR75-1 A initially issued 06/76:

TVA commits to Regulatory Guide 1.64 which endorses ANSI N45.2.11-1974 09/27/80: _

Operating License (0L) issued for SQN Unit 1 09/15/81:

Operating License (OL) issued for. SQN Unit 2 05/85:

TVA receives employee concern WI-85-091-015 l

06/85 -

Office of Engineering Procedures (0EPs) are in effect; 06/86:

supersede EN DES EPs j

08/85:

'TVA voluntarily shuts down SQN Units 1 and 2 l

09/85:

SQN Project Manual issued.(SQEPs and SQEP-AIs) 11/85:

TVA presents SQN Nuclear Performance Plan (draft') and its Corporate Nuclear Performance Plan (initial-issue) to NRC 03/86:

TVA Corporate Nuclear Performance Plan (CNPP) Volume I, R0, submitted to NRC 07/86:

TVA CNPP, Volume I and SQN Nuclear Performance Plan, Volume II, revised and issued as R1 07/86 -

Nuclear Engineering Procedures (NEPs) are in effect; present:

supersede OEPs 08/86:

TVA CNPP Volume I, revised and issued as R2 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 j

Westinghouse Electric Corporation.

The plant has been

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designed, built, and operated by TVA.

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.f,u REVISION NUMBER: 0 PAGE 5 0F 17 Because of. questions about the environmental. qualification.of '

electrical equipment at Sequoyah, TVA voluntarily shut' down J

Unit 2 on August 21,1985, and Unit l'on' August 22, 1985.

These questions, and other events !which reflected. adversely.

f upon the. quality-of performance of TVA's nuclear activities, have led to a thorough evaluation'of the TVA nuclear program, 1

inc'luding its management and operation of Sequoyah.

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The Sequoyah plant design'was begun in the late 1950s when

'1 implementation of regulatory requirements was not required to be well documented. The majority of the SQN licensing-commitments were made. in the late 1960s and early 1970s, and some of'the present day regulatory requirements do:not pertain-tc Sequoyah.

It is'not necessary to update the Sequoyah Plant.

to include a11Lof the' new guidance published' by NRC, unless there are specific requirements or commitments to do so.

i Although the Smuoyah Preliminary Safety Analysis Report (PSAR) j!

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was released before issuance of 10CFR50 Appendix 0, the Sequoyah engineering organization began to comply with the j

applicable criteria upon its issue as 'a draf t. document in mid-1969. This compliance continued af ter 10CFR50 Appendix B, ANSI N45.2.11,- and Regulatory' Guide 1.64 were officially issued.

TVA Engineering Quality Assuranc'e program policy directives and Engineering implementation procedures for the Sequoyah Nuclear

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. Plant specify requirements to comply with the applicable regulatory criteria and are comparable to those used by other utilities in the nuclear power industry.

The issues identified in this element refer to the division of responsibility between design engineering and the crafts, j

9.2 REGULATORY REQUIREMENTS i

The criteria requirements applicable to this issue are contained in the following:

o Title 10 of the Code of Federal Regulations, Part 50 (10CFR50),

Chapter 1, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants" ( App. A, 6.a).

Criterion I, " Organization;"

Criterion III, " Design Control;" and Criterion VI, " Document Control" are specifically applicable, o

ANSI N45.2.11-1974, " Quality Assurance Requirements for the

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Design of Nuclear Power Plants" ( App. A, 6.c) 1 05510-18 (04/01/87) j

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9.3 TVA' COMPLIANCE PROGRAMS'AND' ENGINEERING PROCEDURES

-1 The_Sequoyah PSAR (App. A, 5.f) and FSAR through Ameadment 3, n

updated April 1986 ( App.. A, 6.d), state that TVA will comply with the regulations 10CFR50 Appendix B and ANSI N45.2.11-1974' for organization, design. control,~and design change control.

-Topical Report TVA-TR75-1A, R8, " Quality Assurance Program Description for the design, Construction, and Operation of TVA -

1 Nuclear Power. Plants" (App. A, 6.e) presents TVA's program to meet the requirements of the regulatory documents.. It contains the QA requirements pertaining to procurement, construction, tests, operation, and maintenance of-TVA nuclear plants. All' programs,'

procedures, design processes, and document controls must meet the requirements of the QA program.

1 The evaluatior, team first reviewed the Sequoyah Nuclear Plant

-Quality Assurance Manual (SQN QAM App. A, 5.1) and then the past and present engineering procedures (EPs, OEPs, and NEPs)'to determine..

i which dealt with division of responsibility between design

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engineering ~and the crafts. The procedures reviewedLcover the W +

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. period of time from the development ofithe.0ffice of; Engineering Design Engineering' Procedures (EN DES-EPs) in 1973 through' the-current Division of Nuclear Engineering (DNE)' Nuclear Engineering Procedures (NEPs) issued July.1, 1986.

3 All design engineering.for the TVA nuclear power pla'nts before September 1973 was performed by the engineering branches.

These engineering discipline groups designed several nuclear plants concurrently, beginning in the early 1960s.

In September 1973, an organization change at TVA resulted in the establishment of the Division of-Engineering Design (EN DES). At that time a project i

system was established that assigned engineers from the various engineering branches (Civil, Electrical, and 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 maintaining the design activities related to Sequoyah, including any needed design changes.

L Concurrent with establishment of the project system concept, new divisionwide engineering procedures, called EN DES-EPs, were established and were in effect from September 1973 to mid-1985.

The l-EPs were quite detailed and prescriptive and included many i

administrative controls i

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PAGE 7 0F 17 in addition'to addressing quality. assurance requirements. The EPs that' were reviewed in detail:for this evaluation are listed in.

Appendix A, 5.o.

In June 1985, new Office of Engineering Procedures'(0EPs) became effective. The new OEPs. reduced or eliminated most of the administrative ' details previously found in the EPs. 'In place n'f a -

stand-alone procedure with many instructions, the OEPs referred.the reader directly to other OEP procedures that controlled individual E

activities. The end result' was a series of single sentences that provided anyone unf amiliar with the process minimal ~ direction ~ on how j

to accomplish a given activity. The OEPs reviewed in detail for this' evaluation are listed in Appendix A,.5.p.

1 In July 1986, 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-W-

current procedures' require the active use of other referenceti NEPs for full understanding of what is to be done. The NEPs reviewed in-detail for this evaluation are listed'in Appendix A, 5.q.

i 9.4 INV ESTIGATION

- Engineering Department Procedures 1

Engineering department procedures applicable to the issue were reviewed to determine compliance with the requirements. The TVA Engineering Department procedures that address the regulatory criteria and TVA. policy cited in Subsections 9.2 and 9.3 are discussed below:

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Office'of Engineering Design and Construction Quality Assurance Manual for Design and Construction (0EDC QA Manual, Volume II -

App. A, 5.1) contains requirements for design control.

It specifies procedures for revising design documents that, when i

adhered to, would prevent fabrication or revision of pipe l

hangers without an approved design drawing or design change authorization.

o Quality Assurance Program Requirements Manual for Design, Procurement, and Construction (PRM, App. A, 5.g), Section 3.0.

L' Design control procedure 30PD-1, R2, " Office of Engineering Design and Construction Requirements for Specifying Codes and Standards" imposes performance requirements that comply with 05510-18'(04/01/87) j

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10CFR50. Appendix B criteria.. For example, a pipe hanger must be' desig'ned:by EN DES before start of 'any construction activities on-that hanger. The procedure _' requires Construction ;

to referLall field changes to Engineering' for approval. prior to Work.-

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Interdivisional Quality Assurance Procedures Manual for Nuclear i

Power Plants (IPM - App.' A, 5.j)' includes adequate procedures for design and design change control.

o Nuclear Quality l Assurance' Manual' (TVA NOA' '- App. 'A,"5.h)

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contains procedures that impose requirements for design and change control which, if followed, would prevent field design, j

installation, or modification without EN 'OES prior approval.-

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o Nuclear Quality Assurance Manual (Interim) (TVA NQAM - App. A,

~ 5.k).. imposes requirements ~on Engineering, Operations, and...

Construction which fully comply with 10CFR50 ' Appendix B and ANSI-N45.'2.11-1974 design and design change control criteria.,

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When adhered to,. these requirements preclude f abrication of, or modification to pipe hangers.without prior Engineering, approval, o

Sequoyah Nuclear Plant Quality Assurance Manual (SQN QAM -

App. A, 5.1) contains procedures that impose requirements on Engineering and Construction that comply with ' applicable code criteria and satisfy the intent of 10CFR50 Appendix B.

o Division of Engineering Design - Engineering Procedures Manual

( App. A, 5.0) contains procedures (EPs) for a regulated system of design control from initial design through field requests for changes.

If adhered to, these procedures would prevent conditions such as alleged by the issue.

o Engineering Program Directives Office of Engineering Procedures Manual (App. A, 5.p) contains procedures (0EPs) that prevent design and design changes that require fabrication, installation, or modification to a pipe hanger from proceeding prior to Engineering authorization.

t procedures (NEPs) g Procedures Manual (App. A, 5.q) contains Nuclear Engineerin o

that also require Engineering authorization prior to fabrication, installation, or modification of pipe hangers.

Scpuoyah Nuclear Performance Plan (SON NPP)

In the SQN NPP ( App. A, 5.m), Section 11 titled " Conduct of Seouoyah Activities," paragraph 3.0, TVA management acknowledges problems with design change control similar to those expressed in this issue:

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Sequoyah has experienced problems with the control of design changes and plant modifications.

Weaknesses have been-identified in the depth and documentation of engineering work for design changes and in maintaining consistency between 'as i

configured' and 'as designed' information."

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" Problems with control of plant design changes have been recognized and a long term improved design change control program is being iraplemented.

In the interim and prior to plant restart, a change control. board has.been-established to review proposed design changes for approval and a transitional design change program will be put in place.

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TVA Audit Reports and Memoranda i

A review of TVA audit reports ( App. A, 5.u through 5.x) indicates that some SQN pipe supports may have been f abricated and installed without formal engineering approval, which is in deviation of design-documents and applicable procedures.

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'I A trend analysis of WBN nonconformance reports disclosed a significant condition adverse to quality caused by unacceptable variation of the installed pipe supports from the designs and design deviation allowances.

l A review of the 12/01/86 printout of the Condition Adverse to i

Quality (CAQ) Data Base Frequency Report for Sequoyah indicated that 24 out of 3750 (0.64 percent) documents listed involve piping analysis and/or support design. This indicates only that there are some, but not many, CAQs for this type of item.

Other Analyses i

Other Stauoyah element reports which relate to this issue were reviewed to determine the applicability and relevance of their conclusions to this investigation.

SON Element Report 220.3 (App. A, 5.7) covers the same type of issue specific to the adequacy of design for pipe supports. This analysis j

concluded:

i "The SON design criteria for pipe support design are adequate for addressing seismic design requirements, l

but implementation of the criteria could not be verified for all pipe support designs within the

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sample, since some of these calculations were partial calculations performed by TVA as technical justification for design changes."

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PAGE 10 '0F 17 SQN Element Report 212.2 (App. A, 5.t) addresses the adequacy of SQN's compliance to NRC IE Bulletin 79-14 which required a program to demonstrate, with a high level of confidence, that the es-constructed safety-related piping system configuration agreed with the analyzed configuration. The element report states:

l "Further inspection performed by NRC during August 6

- September 5,1981 included review by Region II p! ping specialists of TVA's IE Bulletin 79-14 program for. Unit 2.

On the basis of TVA's final ritport.

>(App. A, 5.ee) [ App A, 5.s in this t'epodL] and NRC's l

inspections, this bulletin was considered closed for j

t Unit 2."

The closure of IE Bufiatin 79-14 for SQN Unit 2 was confirmed by an October 14, 1981 NRC letter to TVA (App. A, 5.bb). ' The 79-14 action for Unit 1 is not yet complete.

i SQN Element Repcrt 223.3 (App. A, 5.y) also. evaluated the adequacy of design etail for instrument supports tad mountings.

This analysis concluded:

"there was a lack of design mounting detail for a field-mounted. temperature switch."

"The lack of.an appropriate design mounting detail or evaluation prior to this investigation for the temperature switch indicates a need for TVA review of other field-mounted local instruments."

SQN Element Report 80501 - SQN ( App. A, 5.aa) pertains to a concern that typical instrumentation installation detail drawings were not provided. This report contains the following summary of findings:

"The investigation substantiated this issue and identified the following findings:

There were no " typical" drawings for locally a.

mounted safety related instruments prior to March 31,1981.

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The environmental qualification "walkdowns" have i

shown that there are problems with instrument j

mountings.

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PAGE 11 0F 17 Gilbert / Commonwealth Report, " Technical Review.

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of Scaucyah Nuclear Plant Modifications,"-

March '23,1986 (Report Number 2164) indicated that discrepancies with. instrument mountin

' exist due to inadequate design drawings." gs The above reports indicate inadcauacy of TVA design-detail, as implied in.this issue.

Interviews With TVA Personnel Discussions with cognizant TVA personnel. (App. A, 7.a.

through h)- regarding the issue indicate that some j

as-constructed pipe supports may not be in conformance with as-designed engineering documentation. ~These discussions substantiate a need for reconciliation of-installed hardware with applicable design documents.

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TVA Remedial Action-

.Q In order to reconcile design control issues the Division of Nuclear Engineering developed the Sequoyah Design Baseline and Verification Program (DBVP) (App. A,. 5.n).

"The objectives of this program are:

o To verify the adequacy of the plant modifications made since operating license (OL) to systems, or portions thereof, required to mitigate design basis events and to provide for safe shutdown of the plant o

To provide confidence that these modifications are supported by engineering analysis and documentation o

To provide confidence that these modifications are made in confonnance with licensing commitments "The essential elements of the overall program are as follows :

o Verification of actual plant configuration o

Reconciliation to engineering design documents including supporting calculations and design criteria o

Reconciliation of the FSAR, licensing commitments, and technical specifications J0551D-18. (04/01/87)

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o Performance of safety evaluation reports and unreviewed safety question determinations (USQDs) for the system configuration o

Issuance of revised key plant drawings which are

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J essential for operations" These program objectives.and elements will be met in two phases.

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'The pre-restart phase is to meet the above objectives for selected 7(

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 selected f

systems-are.those systems or portions of*those systems required to N

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e mitigate FSAR Chapter 15 design basis accidents, safely shut down

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the plant, and maintain safe shutdown concitfoa.

Part of the DBVP programiequires that all : hinges and change.

documentation pending at time of issue of SQN operating license, and issued thereafter, pertaining to these selected systems be evaluated for engineering adequacy.

Physical ch6ngesLimplemented will be those required for system compliance to licensing _comitments and

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design basis criteria.

f Post-restart activities would be those necessary to meet the program objectives for those systems not included in ttm pre-restart phase.

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Findings- j [' a. TVA. procedures do not provide for craft personnel to make technical decisions. Procedures contain requirements to control and approve p, design and design changes. j y 7 s 1; Although TVA procedures-) comply with applicable criteria, QA audit and surveillance reports document that some pipe supports have been fabricated and installed in variance with these procedures. ] 4 ./ There is evidence o' inadequate documentation of pipe support analysis and instances where field mountings for instruments were inu1 equate. I i The' evaluation team found no evidence to support the implication that decisions by J.he crafts were responsible for the inadequacies described in any of the ebove findings. In addition, the evaluation 1,r team has found in its Operience that input or suggestions f volunteered by the crafn are often very helpful, especially in y/ 2

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== Conclusions:== The evaluation team cow.luded that TVA SON and other engineering procedures are adequate and a circumvented approval process, as described in the issue, should not occur. However, a review of TVA audit reports, and discussions with cognizant personnel tend to validate the issue and indicate a problem may exist. However, corrective action programs, as noted below, have been completed or are now in place, which will resolve the problem. Any improperly designed and/or installed pipe supports or hangers on safety systemr 'or Units 1 and 2 which remained in the plant after completion of construction were corrected during the implementation of the IE Bulletin 79-14 program. The 79-14 program was completed one month after issue of the operating license (0L) for Unit 2. The Design Baseline and Verification Program (DBVP-App. A, 5.n) requires an engineering evaluation of all changes made after OL to safety systems required to mitigate Chapter 15 accidents. Any engineering or physical inadequacies on those systems are to be corrected before plant. restart. Corrections 'to the remaining safety systems will be completed in the i(_ post-restart phase of the DBVP. The corrective action plans (CAPS) resulting from SON Element Reports 220.3, 212.2, 223.3, and 80501 should alleviate concerns pertaining to inadequate instrument mo' nting and inadequate hanger analysis. Element u reports for categories ether than engineering may address concerns to those addressed in this report. 10. CORRECTIVE ACTION: No corrective action is required. 4 ( 05510-19 (04/01/87) -_-_A

I i TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.3(B) SPECIAL PROGRAM REVISION NUMBER: O PAGE 14 0F 17 i APPENDIX A i l 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT: a. Title 10 of the Code of Federal Regulations, Part 50 L (10CFR50), Appendix B (Draft) I b. Title 10 of the Code of Federal Regulations, Part 50 - (10CFR50), Appendix B (06/27/70) c. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76) d. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants" e. Sequoyah Final Safety Analysis Report (FSAR), through Amendment 3 (04/86) f. SequoyahPreliminarySafetyAnalysisReport(PSAR) g. Quality Assurance Program Requirements Manual for Design, Procurement, and Construction (PRM); procedures reviewed include 3QPD-1, " Requirements for Specifying Codes and Standards," and 3QPR-1, " Design Control" j i h. Nuclear Quality Assurance Manual (TVA NQAM), procedures I reviewed include 10-QAP-1.3, " Work Control;" and Part V, i Section 2.4, " Design Change Control System Using Design I ]I Change Supplements" l i. Office of Engineering Design and Construction Quality A.ssurance Manual for Design and Construction (0EDC), Volume II; procedures reviewed included EN DES-QAP 2.1, " Design Review" ) l l j. Interdivisional Quality Assurance Procedures Manual for l Nuclear Power Plants (IPM); procedures reviewed include ID-QAP-3.2 R1, " Processing of Construction Change Notifications (CCNs)," and 10-QAP-3.1 R0, "0EOC Site Investigation for Design Purposes" l k. Nuclear Quality Assurance Manusi (Interim); procedures reviewed include Part 1, Section 2.3, " Design Control" 05510-19 (04/01/87) )

l 4 / TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.3(B) f SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 15 0F 17 APPENDIX A (cont'd) l. Sequoyah Nuclear Plant Quality Assurance Manual (SQN QAM), Section III, " Quality Assurance Procedures - Design," and f 7 Section IV, " Quality Assurance Procedures - Construction" i m. Sequoyah Nuclear Performance Plan (NPP), Volume II, (07/22/86) n. Sequoyah Nuclear Plant Design Baseline and Verification Program, R0, (05/01/86) o. EN DES Engineering Procedures Manual: EP 3.57, R0 " Design Evaluation," (01/26/86) l EP 4.02, R16 " Engineering Change Notices (ECNs)," (07/23/84) EP 4.03, Ril " Field Change Requests," (11/21/84) '1 EP 4.07, R1 "As-Constructed Drawings," (08/08/79) EP 4.18 R4 " Design Change Requests (DCRs)," (07/11/78) l p. Engineering Program Directives Office of Engineering Procedures Manual (0EPs). The following OEPs are referred to in-this evaluation:- OEP-08, R0 " Design Output," (04/26/85) OEP-10. R0 " Review," (04/26/85) OEP-11, R0 " Change Control," (04/26/85) q. Nuclear Engineering Procedures Manual (NEPs). The following NEPs are referred to in this evaluation-NEP-3.2, R0 " Design Input," (07/01/86) ) NEP-3.3, R0 " Internal Interface Control," (07/01/86) i NEP-5.1, RO " Design Output," (07/01/86) NEP-5.2, R0 " Review," (07/01/86) NEP-6.1, R0 " Change Control," (07/01/86) r. Sequoyah Project Manual (SQEPs and SQEP-Als), (09/27/85) s. Letter from L. H. Mills, TVA, to James P. O'Reilly, NRC, " Office of Inspection and Enforcement Bulletin 79-14-RII: JP0 50-328, Sequoyah Nuclear Plant Unit 2" re: final response i to IE Bulletin 79-14, [A27 810709 005], (07/09/81) t. Sequoyah Element Report 212.2, "NRC Bulletin 79-14, ABR Program"R1,(12/03/86) Audit File QMS85-33, Sequoyah Engineering Project May 14-16, u. 1985 05510-19 (04/01/87) ___ A

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w.. r ai 3 ~ ^ 1: }TVA EWLOYEE CONCERNS REPORT-NUMBER: 204.3(B). +. SPECIAL PROGRAM REVISION NUMBERi 0, PAGE 16 0F 17 h ' APPENDIX A (cont'd) y f Design Project'(CDP)quoyah Engineering Project (SQEP)LC ~ Audit File 86-24,.Se i v.' - j , Alternate Analysis' Review Program, f c August.5-8 and 27-29,1986

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' Audit File 86-27, No'nconformance. Conditions Disposition, Documentation, and' Control,' Watts _Bar Engineering Project,

September 15-19,-1986-x.

Audit File 87-02, Corrective' Action and Control of: i- . Modifications, Sequoyah Engineering Project (SQEP) '1 y.1 Sequoyah Element Report 223.3, " Local Instruments Seismic- ~ - Qualification," R1, (01/15/87) l

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Sequoyah Element Report 220.3, " Design'.of Supports," R1, (12/03/86) Sequoyah Element Report' 80501' SQN, " Engineering Document aa.- ,M Quality," R4,'(01/07/87), N. bb. Letter:from R. C. Lewis, NRC, to H. G. Parris, TVA, " Report . Nos. 50-327/81-33 and 50-328/81-42" re: IE Bu11etin.79-14 closure for Unit 2, [A02 811019 014], (10/14/81). r ~ 4 cc. TVA memo from L. L. Jackson to Those Listed, " Institute of-s Nuclear Power Operations-(INP0) Corporate Evaluation Responses," (no RIMS number), (08/14/86) dd. TVA memo from W. C. Drotleff to lhose-Listed, " Design Basis. Program for TVA Nuclear-P1 ants," [B44860402007], (04/08/86)- i .6. WHAT REGULATIONS,' LICENSING COMMITENTS, DESIGN REQUIREMENTS OR OTHER ' APPLY OR CONTROL IN THIS AREA? a. 10CFR50 Chapter 1, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" b. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76) t c. ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants" d. Sequoyah FSAR - through Amendment 3, (updated 04/86) ( 05510-19 (04/01/87) j

b TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.3(B) SPECIAL PROGRAM REVISION NUMBER: 0 I PAGE 17 0F 17 APPENDIX A (cont'd) e. TVA-TR75-1 A,- R8, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," (no RIMS number), (04/09/85) I f. Sequoyah Nuclear Performance Plan, Volume II, (07/22/86) 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT. a. Meeting with W. E. Troutt. TVA, and D. Popham, Bechtel, regarding audits of Sequoyah, IOM 517, (11/21/86) b. Meeting with D. White, G. I. Palmer, TVA, and D. Popham, Bechtel, regarding audit activities, IOM 517, (11/24/86) c. Meeting with T. Clift, J. Robinson, TVA, and D. Popham, Bechtel, regarding Engineering approvals of NCRs and FCRs for (-r pipe hangers, IOM 517, (11/21/86) ~ d. Meeting with R. Hoekstra, J. Robinson, TVA, and D. Popha'm, Bechtel, regarding Er.gineering Design Control Practice, IOM 517, (11/21/86) e. Telephone conversation between Lewis Chacon, TVA, and D. Popham, Bechtel, regarding Sequoyah construction practices during installation of pipe hangers, IOM 517,(11/24/86) f. Meeting with R. Enis, E. Harmon, TVA, and D. Popham, Bechtel, regarding TVA trend data pertaining to pipe hangers, IOM 517, (11/24/86and11/26/86) 9 Telephone conversation between C. Henderson, TVA, and D. Popham, Bechtel, regarding actual practices during Sequoyah pipe hanger f abrication and installation, IOM 517, (11/24/86) h. Telephone conversation between R. Bill, TVA, and D. Popham, Bechtel, regarding actual practices during Sequoyah pipe hanger fabrication and installation, IOM 517, (11/24/86) 05510-19 (04/01/87) i}}