ML20207L147
| ML20207L147 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/30/1986 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K584 | List: |
| References | |
| 213.4(B), 213.4(B)-R, 213.4(B)-R00, NUDOCS 8701090654 | |
| Download: ML20207L147 (10) | |
Text
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,. 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 0 TITLE: ELECTRICAL PROCEDURES Electrical Procedures Do Not Properly Identify IEEE Standards PAGE 1 0F 9 hEASON FOR REVISION:
PREPARATION f PR'EPARE,0 BY:
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- SRP Secretary's signature denotes SRP concurrences are in files.
I b APPROVED BY:
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b CONCURRENCE (FINAL REPORT ONLY)
. 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0 b PAGE 2 0F 9
- 1. CHARACTERIZATION OF ISSUES:
Concern: Issues:
IN-86-259-X11 a. TVA electrical design documents and "If TVA electrical procedures procedures do not include require-do not include IEEE standard ments of IEEE standards or other requirements or their equiva- industry standards.
lent, numerous problems can result. Construction Dept. b. If these standards are not included, concern. CI has no additional numerous problems may result.
information".
The following issues from this concern are addressed in another report:
TVA electrical design criteria documents do not include requirements of IEEE standards or Other industry standards.
(.i.. (addressed in Sequoyah Element Report 213.3).
TVA electrical procedures do not include IEEE standard requirements or their equivalent, therefore, numerous problems can result.
(addressed in Sequoyah Element Report 201.4)
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X N0 o Identified by TVA WBN NSRS Date November 14, 1985 TVA Nuclear Safety Review Staff Investigation Report No.
I-85-545-WBN, Industry Requirements In TVA Electrical Procedures,(11/14/85) o Identified by TVA SQN GCTF Date Circa Jan 1986-June 1986 TVA SQN Generic Concern Task Force Report GCC-19-65, IEEE b Standards Not Included in Electrical Procedures, (01/86-06/86) 05390
- 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 3 0F 9
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
Concern applies to all design criteria, design standards, design guides, construction specifications and site procedures.
- 4. INTERVIEW. FILES REVIEWED:
File IN-86-259 was reviewed and no additional unreviewed information for Sequoyah regarding this concern was identified.
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
- 6. WHAT REGULATIONS, LICENSING COM ITMENTS, 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 available transcripts of NRC investigative interviews to extract information applicable to the employee concern.
- b. Reviewed existing reports, findings, and responses to findings to assess their adequacy and the extent to which they satisfy the employee concern. Identified other documents needed to perform the review.
- c. Reviewed design criteria, design standards, design guides, engineering procedures, construction specifications and a sampling of site procedures to determine whether the requirements of IEEE standards or other industry standards are referenced.
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. 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0 b PAGE'4 0F 9
- d. Reviewed existing TVA construction, QA/QC, Operation, and Material Control reports for the Employee Concern Evaluation Program for applicability to the concern discussed in this report.
- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
. 09/23/85: Concern submitted to TVA for Watts Bar Sometime TVA established the EEB council for standards in 1985: planning and review 10/31/85 to NSRS investigation for WBN 11/07/85:
11/18/85 and OE/0C/NUC PR meeting to coordinate revision 11/19/85: of two construction specifications
(
01/30/86 to SNP Generic Task Force investigation 04/26/86:
Discussion:
- a. The concern was raised on Watts Bar but is considered to be a generic problem for Sequoyah since many procedures, standards, and specifications are common to all plants. NSRS Report I-85-545-WBN for Watts Bar (App. A, 5.a) concluded that IEEE standard requirements or their equivalent were incorporated in design documents and procedures. However, the NSRS concluded further that the presentation of the information and the user's understanding of it have not always been effective and, as a result, some requirements may not have been implemented. NSRS recommended that an interorganizational review of all applicable procedures be conducted to ensure that industry standards are understood and implemented.
The SQN GCTF Report GCC-19-65 ( App. A, 5.b) concluded that TVA electrical design documents and procedures are not required to include "all IEEE standards;" however, they "do 1 include the standards to which TVA is committed."
(.
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, 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0
[ PAGE 5 0F 9 As reported in TVA memo from Domer to Cottle (App. A, 5.c),
the Electrical Engineering Branch (EEB) established in 1985 a standards planning and review council dedicated to maintain quality design standards, guides, and construction specifications. The same memo describes actions by the EEB council and by a TVA interorganizational group in November 1985 to promote a better understanding of the standards and to coordinate discussion and subsequent modifications of two construction specifications. The need for future activity, if any, of the EEB council, or other program with similar objectives, is assessed from a
, programmatic viewpoint in Sequoyah Element Report 201.4.
A review of the current Nuclear Engineering Procedures (NEPs) indicated that they provide adequate direction for the inclusion of the requirements of industry standards in design documents and procedures. NEP-3.2 (App. A, 6.a) requires that reference to design inputs, such as codes, standards, and regulations with the applicable issue noted, be included. This NEP specifically requires the identification of "the effective revision of all design inputs and the
( portions of each design input that are applicable to each design." NEP 5.1 (App. A, 6.b) requires design output documents to be traceable to their design bases.
The evaluation team reviewed the FSAR, Chapters 7 and 8, electrical design criteria contained in the SQN Design Criteria Manual (App. A, 5.1), and electrical design standards and guides contained in the TVA EN DES Design Manual (App. A, 5.1), and determined that references to applicablo electrical TVA standards were incorporated Construction Specificationsproperly. Also, (App. A, 5.k )
were reviewed and found to contain either direct reference to industry standards, or reference to TVA design standards, guides, or drawings. These TVA design documents referred in turn to industry standards.
In addition, the evaluation team reviewed the TVA OE Procedures Manual (App. A, 5.f), the TVA DNE Procedures Manual procedures (AppApp. (. A,A,5.g),
5.m)andandasite sampling of TVA procedures SQN (App. A,engineering 5.h).
No instances were found where requirements of standards should have been included and were not. Generally, engineering procedures convey nontechnical direction for a particular activity; therefore, references to industry b
.. 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 6 0F 9 standards are rarely needed. Although reference to standards may be found in some procedures, TVA considers it more appropriate to reference standards in design criteria, standards, and guides and in construction specifications.
This is consistent with industry practice.
The results of the evaluation team review support the conclusions of the NSRS and GCTF reports that requirements of IEEE standards or their equivalent were incorporated properly in electrical documents.
. b. The employee concern has raised the issue: if the requirements of IEEE standards or other industry standards are not included in electrical design documents and procedures, numerous problems may result. This issue has not been addressed directly in the NSRS or GCTF reports or in other TVA documents reviewed. The issue is academic for Sequoyah since no instances were found where requirements of standards should have been included and were not. The evaluation team found that many design documents do not require reference to industry standards and, therefore, are
( complete without them.
Compliance with an IEEE or other industry standard is not mandatory unless a commitment to comply has been made in a licensing or design basis document. TVA Nuclear Engineering Procedure (NEP) 3.2 (App. A, 6.a) requires inclusion of applicable industry standards in design documents. In addition, as the GCTF Report GCC-19-65 points out, TVA may use their own analysis or experience to form part of the design basis.
Findings:
The alphabetic identifiers below correspond to the list of issues in Section 1.
- a. The NSRS report concluded that IEEE standard requirements or their equivalent were incorporated in design documents and procedures. The GCTF report concluded that all electrical design documents and procedures include standards to which TVA is committed. Results of the document review by the evaluation team support the conclusions of the NSRS and GCTF reports. Futhermore, current NEPs provide adequate directions for including requirements of industry standards in design documents and procedures.
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. 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 7 0F 9 The NSRS report also recommended that an interorganizational review of all applicable documents be conducted to ensure that the requirements of industry standards are understood and implemented.
Subsequently, a meeting of interorganizational representatives in November 1985 (App. A, 5.c) resolved comments on proposed revisions of two construction specifications and their concurrence led to issue of the revisions. Future requirements for similar interorganizational reviews are discussed in Sequoyah Element Report 201.4.
- b. The issue, that numerous problems may result if requirements of IEEE and other industry standards are not included in electrical documents, is academic for Sequoyah since no such deficiencies were found.
Conclusions:
The first issue of the concern is not valid since requirements of IEEE standards and other industry standards were found to be
(- incorporated properly in electrical documents. Also, requirements for future incorporation of these standards are properly covered in current NEPs. Consequently, the second issue, that numerous problems may result if these requirements are not included, is academic and not valid for Sequoyah.
- 10. CORRECTIVE ACTION:
No corrective action is required.
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. , . 12/15/86
, TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 8 0F 9 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. NSRS Investigation Report No. I-85-545-WBN, " Industry Requirements in TVA Electrical Procedures," (11/14/85)
- b. TVA SNP Generic Concern Task Force Report GCC-19-65, "IEEE Standards Not Included in Electrical Procedures," R2 (06/04/86)
. c. TVA memo from Domer to Cottle, WBN - Employee Concern Investigation Report Transmittal (03/10/86)
- d. TVA memo from Ennis to Standifer, WBN - Employee Concern Investigation Report Transmittal (12/09/85) e.
TVA Division Procedures of Engineering Manual (supersededDesign (DED),
by 5.f below) Engineering)
(06/28/86
- f. TVA Office of Engineering (0E) Engineering Program
(,.-
Directives, Procedures Manual Section (04/26/85)
- g. TVA Division of Nuclear Engineering Procedure Manual (07/01/86)
- h. Site Procedures:
Maintenance Instructions MI-8.10 R5, 8.12 R6, 8.17 R5, and 10.52 R0 Surveillance Instructions SI-72 Rll, 73 R3, 75 R12, 94.1 R1, 95 R3, 96 R2, 97 R11, 251.1 R3, and 251.2 R3 Special Maintenance Instructions, SMI-0-317-39 R2, 0-317-40 R1, and 0-364-1 R2 Special Operation Instructions 501-30.6 R14, 30.7 R11, 30.8 R3, 32.1 R12, and 32.2 R14 Technical Instructions TI-41-28 R2, 41-29 R0, and 76 R5 Modification and Additions Instructions M&Al-4 R10, 7 R9, and 13 R6 Inspection Instructions 11-10 R16, and 28 R6
- 1. SQN Design Criteria Manual
- j. SNP FSAR, Chapters 7 and 8
(
- k. TVA General Construction Specifications
- 1. TVA EN DES Design Manual 05390
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_ . . 12/15/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 213.4(B)
SPECIAL PROGRAM REVISION NUMBER: 0 b PAGE 9 0F 9 APPENDIX A (cont'd) ,
- m. Sequoyah Engineering Procedures SQEP-06 R0, 08 R3, 11 R4, 12 R2,13 R0,14 R0,15 R0,16 R0,18 R1, 29 R1
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA 7
- a. Nuclear Engineering Procedure (NEP) 3.2, " Design Input" R0 (07/01/86)
- b. Nuclear Engineering Procedure (NEP) 5.1, " Design Output" R0 (07/01/86)
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
None.
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REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -
81 3 FREQUENCY - REQUEST OFFICE OF HUCLEAR POWER RUN TIME - 12:57:19 CHP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 21304 ELECT PROC DO NOT PROPERLv ID IEEE STANDARDS
) S GENERIC KEYHORD A H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C FLQB DESCRIPTION KEYHORD D
) NUMBER CAT CAT D LOC REPORT R IN 259-X11 EN 20104 S HBN YYYY I-85-545-NBN SR IF TVA ELECTRICAL PROCEDURES DO NOT PROCEDURES T50149 EN 21304 K-FORM INCLUDE IEEE STD. REQUIREMENTS OR TN STANDARDS EIR EQUIVALENT, NUMEROUS PROBLEMS CA ELECTRICAL 3 H RESULT. CONSTRUCTION DEPT. CONCER GENERAL N. CI HAS NO ADDITIONAL INFORMATION
. NO FOLLOH-UP REQUIRED.
3 I CONCERNS FOR CATEGORY EN SUBCATEGORY 21304 7
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