ML20212G991

From kanterella
Revision as of 03:39, 21 January 2021 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Rev 2 to Control of Design Calculations:Calculation Control & Interface Requirements
ML20212G991
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 01/13/1987
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20212G828 List:
References
205.2(B), 205.2(B)-R02, 205.2(B)-R2, NUDOCS 8701210254
Download: ML20212G991 (23)


Text

,

. TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM

( REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 2 TITLE: CONTROL OF DESICN CALCULATIONS Calculation Control and I Interface Requirements PAGE 1 0F 22

\'

REASON FOR REVISION:

1. Revised to incorporate TVA Engineering comments.
2. Revised to incorporate SRP/TAS coments, add chronology, add section 10 on corrective action, and include CAPS.

PREPARATION PREPARED Y:

(

) hN ~

/2-25l'-E%

DA)E

(/- (( SIGNATURE REVIEWS

} O 0

' ~ SIGNATURE / DATJ(

'^??$l6 d

'g]olH SIGNATURE ikIn '

DATE CONCURRENCE 5 Dr&dit id>+ hc.

CEG-H: N / ~1'/ *Ifl SRP:0fyi 11/04fL__J-/T: 8]

SIMXTURE DATE g SIGNATUp*/ DATE

%PPROVED BY:

N/$!k b ECSP 4ANAGER b/kU DATE n/^

MANAGER OF NUCLEAR POWlT .hYE O

  • SRP Secretary's signature denoteg0ggpRg[ggg, g g R[P0 g g y ), .

~

g ;. .

,f*  ; f I.

REPORT NUMBER: 205.2(B)

'~

TVA EMPLOYEE CONCERNS t' .SPECIAL PROGRAM REVISION NUMBER: 2 b PAGE 2 0F 22 l '. CHARACTERIZATION OF ISSUES:

- Conccrns: Issues:

A .,

WI-85-100-043 a. Tnere is inadequate control of design "There are problems in design calculations.

calculations, in that some are never prepared, some are in- b. There is inadequate interface s'

- adequate'in scope and quality coordination with design calculations and some are not stored as (e.g., Branch / project, OhP/0E).

quality records. -There is inadequate interf ace and c. There are no procedures to control of design calculations maintain calculations current.

s which impacts traceability of design requirements. CI has no further information. NOTE: The following issues from these Anonymous concern via letter." concerns are addressed in other reports:

+ I-85-128-NPS Some design calculations are never An individual from BFN wrote prepared. (Addressed in Sequoyah

, NSRS expressing his concern Element Report 205.1) that the control and quality of OE's design effort is Some design calculations are inadequate inadequate. The CI sent in scope and quality. (Addressed in

< several roughly written Sequoyah Element Report 205.1) pages detailing and sum-marizing his evaluation and Some design calculations are not stored conclusion of three major as quality records.

areas:

Element Report 205.3)(Addressed in (1) Design Calculations Lack of control of design calculations i impacts traceability of design require-(2) NCR's, and ments. (Addressed in Sequoyah Element Report 201.6)

(3)ManagementPolicies NOTE: The description of I-85-128-NPS included here and in issue "c" was developed from a review by

' #s

- the evaluation team of the 6 expurgated interview files for this employee concern.

,r I

0394D - 12/22/86

(

TVA EMPLOYEE CONCERNS REPORT NUMBER: .205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 I PAGE 3 0F 22

2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X N0 o Identified by TVA SQN NSRS Date March 6,1986 TVA SNP - Nuclear Safety Review Staff Investigation Report No. I-85-132-SQN, Diesel Generator Loads, (03/06/86) o Identified by TVA SQN NSRS Date April 7,1986 TVA SNP - Nuclear Safety Review Staff Investigation Report No. I-85-992-SQN, Control of AC and DC Electrical Loads, (04/07/86) o Identified by NRC ILE Inspection Report Date April 22, 1986 NRC - Office of Inspecticn and Enforcement Reports Nos. 50-327/86-27 and 50-328/86-27 (04/22/86) o Identified by Gilbert / Commonwealth, Inc.

Date March 3,1986 Gilbert /Conmonwealth, Inc. Report No. 2614, Sequoyah Nuclear Plant Modification for Tennessee Valley Authority, (03/03/86) o Identified by Sargent & Lundy Date April 8, 1986 Sargent & Lundy Final Report, Sequoyah Nuclear Plant, Nuclear Plant Electrical Calculation Program Assessment, (04/08/86) o Identified by TVA 00A Date August 1, 1984 TVA Office of Quality Assurance, Audit Deviation Report, 051-A-84-0006, (08/01/84) 03940 - 12/22/86

b TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PRDGRAM REVISION NUMBER: 2 I PAGE 4 0F 22 o Identified by TVA DNE EA Date September 16, 1986 TVA Division of Nuclear Engineering (DNE), Engineering Assurance Audit 86-23, Audit Report, (09/16/86)

3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:

I-85-128-NPS refers to a lack of electrical calculations for power systems, cable size, conduit, and instrumentation.

4. INTERVIEW FILES REVIEWED:

Expurgated file for WI-85-100 was reviewed and no additional unreviewed information was found.

Expurgated file for I-85-128-NPS was reviewed and notes were I

- 1 developed by the evaluation team.

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 7 See Appendix A.
7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

See Appendix A.

03940 - 12/22/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2

( PAGE 5 0F 22

8. EVALUATION PROCESS:
a. Reviewed upper-tier documents (e.g., regulatory standards) to determine the requirements for controlling and maintaining calculations current.
b. Reviewed Engineering Department and Project procedures that implement calculation policies; in particular, procedures that relate to the review / revision of design calculations supporting plant modifications and to the coordination / interface between branch and project.
c. Reviewed results of audits (QA, NRC) that investigated whether design calculations have been reviewed / revised to support design changes.
d. Reviewed available transcripts of NRC investigative interviews to gain additional information regarding these concerns.
e. Exam-ined results of prior independent reviews (e.g., S&L, G/C, etc.) listed in Section 2, for discussion of validity of concerns.
f. Reviewed the Essential Calculation Program (ECP), the Design Basis Program (DBP), and the Design Baseline and Verification Program (DBVP) for SQN to determine if these programs adequately address the issues in Section 1.
9. DISCUSSION, r4NDINGS, AND CONCLUSIONS:

Chronologv:

I Chronology of Calculation Issues:

03/84: Black & Veatch completes review of Watts Bar auxiliary feedwater system. Concerns arise over alternate analysis criteria for seismically supported piping and absence of calculations for power cable ampacities.

(

03940 - 12/22/86 1

i TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 4 PAGE 6 0F 22 I

06/84: TVA QA audit No. D51-A-84-0006 identified the failure to update and revise electrical calculations to support design changes. Corrective action included identification of electrical calculations to be revised or voided.

08/84: Duke Power Co. reviewed piping stress analysis and pipe support programs for Watts Bar Unit 2 and Bellefonte Units 1 and 2. Additional emphasis on accurate origination and checking of calculations and drawing recommended in final report.

09/84: Bellefonte Electrical Evaluation (BEE) report identified the lack of electrical calculations for voltage drop, short circuit, etc. Electrical Engineering Branch (EEB) initiates efforts to develop a minimum set of electrical calculations.

10/03/84: EEB committed to QA to provide by 03/01/85 a list for all four plants giving the status of each calculation (that is, whether each calculation is current, needs revising, or needs voiding) and a schedule for revising or voiding calculations.

03/85: A listing of all electrical calculations and studies for SQN was sent by EEB to Quality Management Staff.

06/85: Office of Engineering newly issued Office of Engineering Procedures (OEPs) became effective on June 28,1985. The four volumes of 145 Engineering Design Procedures, which included administrative controls and quality assurance requirements, were replaced by 18 OEPs.

11/85: QMS followup on the corrective action for the 06/84 audit deviations indicates that some SQN electrical calculations have not been updated and that EEB central staff have not been receiving drawing changes in order to review support calculations.

12/07/85: TVA receives concern I-85-100-043 11/26/85: Chief Electrical Engineer commits to completion of the minimum set of electrical calculation required to ensure plant safety prior to unit restart.

(

0394D - 12/22/86

I TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 l' PAGE 7 0F 22 12/11/85: Civil, Mechanical, and Nuclear Chief Engineers are requested to look at their discipline calculations to determine which, if any, need revising or updating.

01 /86: TVA EEB contracted with Sargent & Lundy to perform an independent assessment of the electrical calculation program for each nuclear plant.

01/86: Gilbert / Commonwealth (G/C) undertakes a survey of design changes to SQN main and ' auxiliary feedwater system from operating license to June 1985 and identifies deficiencies in design calculations.

02/18/86: TVA receives concern I-85-128-NPS.

03/07/86: TVA Director of Engineering and Technical Services requested the Civil, Mechanical, and Nuclear Branch Chiefs to identify, list, locate, and develop the essential design calcuiations required for each nuclear plant, similar to the electrical calculation effort. The issue of design calculations is emphasized as a SQN restart ites 04/22/86: NRC issues inspection report, Nos. 50-327/86-27 and 50-328/86-27, which reviewed G/C's findings and identified the lack of available calculations supporting the original design in some disciplines.

05/08/86: Electrical Engineering Branch Policy Memorandum PH 86 describes branch policy for the identification and listing of essential calculations required to support plant safety systems.

06/25/86: Mechanical Engineering Branch Policy Memorandum MPM.86-04 established branch policy for the identification and listing of essential and desirable mechanical calculations.

07/17/86: The Sequoyah Nuclear Performance Plan, Volume II is submitted to NRC, and describe the Electrical calculation program to develop a minimum set of electrical calculations.

(

03940 - 12/22/86 .

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 I PAGE 8 0F 22 09/09/86: Nuclear Engineering Branch issues a procedure for classifying nuclear calculations that are determined to be essential and which must be maintained current throughout plant life.

11/13/86: Sequoyah Civil Discipline issues revision to design calculation policy and master calculation list of essential and desirable civil calculations.

Discussion:

The concerned individuals raised generic issues that design calculations lack adequate control, interface, and procedures for maintaining calculations current. In reviewing these issues, the evaluation team examined past and present practices, procedures, and processes used at Sequoyah for preparing and controlling design calculations.

Reports and investigations performed by TVA and outside agencies and a review of calculations for other element reports were used to develop findings and conclusions. In this report, the control'of calculations has been interpreted to refer to the review and revision of calculations as plant changes are made. Control also is interpreted to refer to how calculations are treated after their approval. That is, are calculations considered official project documents that require filing, logging, filming, etc., or are they regarded as the personal working papers of the originator?

Interface refers to the needed coordination and communication between responsible organizations during the original design phase or design change process, for example, between branch and project and between Office of Engineering (OE), Office of Construction (0C), and Office of Nuclear Power (0NP).

a. Requirements for Design Control To address the issue of inadequate interface control and the revision and updating of design calculations, the regulatory requirements to which TVA has committed for the Sequoyah Nuclear Plart were first reviewed.

The essential regulations that affect calculations are contained in 10CFR50, Appendix B. TVA committed to 10CFR50 Appendix B in 1970. The applicable criteria include:

o Criterion III, " Design Control," requires establishment of measures to assure that regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and 03940 - 12/22/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 22 instructions. Measures must be established for the identification and control of design interfaces and for coordination among participating design organizations.

These measures are to include the development of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interface.

Design changes must be subject to the'same design control measures that were applied to the original design.

o Criterion VI, " Document Cotitrol," requires that measures be established to control the issuance of documents such as instructions, procedures, and drawings, including changes thereto, that direct activities affecting quality. These measures must assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.

TVA has committed in 1976 in the SQN FSAR to NRC Regulatory Guide 1.64, which endorses ANSI N45.2.ll, " Quality Assurance Requirements for the Design of Nuclear Power Plants"

( App A, 6.c) . The applicable requirements of ANSI N45.2.ll are:

o Section 4, " Design Process," paragraph 4.2, which states that design analyses (calculations) shall be performed in a planned, controlled, and correct manner o Section 6, " Design Verification," paragraph 6.2, which requires that when change- to previously verified designs have been made, de ign verification is required for the changes, including evaluation of the effects of those changes on the overall design o Section 8, " Design Change Control," which also requires that documented procedures be provided for design changes to approved design documents, including field changes. These procedures should assure that the impact of any change is carefully considered, that required actions are documented, and that information i

concerning the changes is transmitted to all affected persons and organizations. These changes must be justified and subjected to design control measures commensurate with those applied to the original design.

k 0394D - 12/22/86

f.

REPORT NUMBER: 205.2(B)

-TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 22

b. TVA Engineering Department Procedures A brief overview of TVA's early nuclear power plant engineering organization provides background information useful in assessing TVA's engineering practices and procedures pertaining to design calculations and interface review.

All design engineering for the TVA nuclear power plants prior to October 1973 was performed by the engineering branches.

These engineering discipline groups designed several nuclear plants concurrently, beginning in the early 1960s. In October 1973, an crganization changem at TVA resulted in the establishment of the Division of Engineering Design. At this time a project system was established that assigned engineers from the engineering disciplines to work exclusively on a specific project, such as Sequoyah 1 and 2. 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. The preparation and updating of calculations however was performed by both the project and the Branches.

Branch procedures provided engineering personnel with technical direction for developing and issuing calculations prior to the initiation of project engineering teams in late 1973. The first QA program procedure for calculations was contained in the SQN Quality Assurance Manual. Procedure SQN-QAP-III-1.2, " Preparation, Review, and Records of Design Calculations," which was first issued on March 8,1970, placed responsibility for the " orderly making, indexing, and filing of computations..." with the design engineers and supervisors in each design branch. Some detail was provided on how to structure a calculation package, assure adequate legibility and indexing, and the assignment of responsibility for checking,)

( App. A, 5.mm . review and final approval of calculations Since October 1973,'three separate engineering procedures manuals have been used by the TVA Engineering Branches and projects:

k 0394D - 12/22/86

t REPORT NUMBER: 205.2(B)

TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 2

' PAGE 11 0F.22 Title Effective Date o Division of Engineering Design, October 1973 Engineering Design Procedures (EN DES EPs) o Office of Engineering Procedures (OEPs) June 28, 1985 o Nuclear Engineering Procedures (NEPs) July 1, 1986 A general review of past and present TVA procedures covering the preparation and issue of design calculations is discussed in Sequoyah Element Report 205.1. This Element Report 205.2 centers on those procedural requirements for revising calculations, interface coordination, and updating calculations to support design evolution and revisions.

EP 3.03, " Design Calculations," Revision 6(01/31/83) l described changes or revisions to calculations. The procedure stated in Section 4.5.1 that:

" Calculations for the redesign of a component, system, or structure must be accompanied by review of associated calculations for possible updating.

Any configuration change given by an as-constructed drawing also must be reconciled with the associated calculations."

EP 3.03 also provided detailed instruction for revising calculation sheets, changing the cover sheet, and the revision log. Specific direction was given in Section 4.5.4 on checking, approving, and microfilming changed calculations. " ... a change to an approved calculations document is checked and approved like the original; once a calculations document is microfilmed, it must be remicrofilmed entirely as in Subsection 4.4 after a revision."

OEP-07, " Calculations," which was in effect from June 28, 1985 to June 30, 1986, instructs the Project Engineer (PE) or Group Head (GH) in Section 4.1.8 to ensure that calculations are revised in accordance with the Revision section of OEP-ll. The referenced section in OEP-ll on Change Control addresses changes to the ECN cover sheet and attached data sheets but does not refer directly to changes to a calculation package.

(

0394D - 12/22/86

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 12 0? 22 NEP-3.1 on Calculations (effective 07/01/86) repeats the basic direction on calculation revisions given in OEP-ll.

The user is referred to NEP-6.1 on Change Control which contains the same wording as OEP-11. However, NEP-3.1 does add four requirements for the Lead Engineer (LE) or GH.

These include tracking unverified assumptions, notifying users when previously unverified assumptions have been verified, processing calculation revisions in the same manner as the original, and evaluating calculations for inconsistencies, errors, omissions, etc.

In addition to the NEP's, project-specific requirements, such as the project organization, interfaces, and any variances from the Nuclear Engineering Procedures (NEPs) are identified, approved and controlled in a Project Manual. The Sequoyah Engineering Project (SQEP) Project manual was issued on September 27, 1985.

The SQEP Project Manual contains two variances to the procedure on calculations, NEP-3.1. These variances identify calculation packages prepared for the Appendix R effort and the Design Baseline and Verification Program as output documents subject to all DNE procedural requirements pertaining to the issue and control of output documents.

The Project Manual also contained a variance to the Design Input Procedure, NEP-3.2. This variance issued a modification criteria procedure that covers the responsibilities of various groups within the Division of Nuclear Engineering (DNE) for generating acceptable modification criteria for proposed plant modifications.

Attached checklists clearly highlight where calculations are required to be generated, reviewed, or revised to support Engineering Change Notices (ECN) and to confirm that appropriate design inputs have been selected and incorporated in the design.

c. Audits and Investigative Reports The issues raisec by the concerns regarding the inadequacy of interface coordination, up-to-date status, and control of calculations have been identified and addressed in TVA internal audits and investigations, as well as in independent verification reviews by outside consultants, b

0394D - 12/22/86

. c.

TVA EMPLOYEE CONCERNS REPORT'NUMSER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2

^

PAGE 13 0F 22 In July 1984, the Office of Quality Assurance (0QA) Audit Deviation Report 051-A-840006 (App. A, 5.mm) identified "a failure to establish an adequate system to ensure that calculations and studies performed by the Auxiliary Power System section of the Electrical Engineering, Branch (EEB) are updated and revised to support the design as changes are made  !

after plant operation." The request for corrective action l

stated that the EEB should establish controlled procedures to define the interfaces, methods, and requirements for l-evaluating the effect of changes on the design and  ;

incorporating these changes in calculation documents.

NSRS Report No. I-85-132-SQN (App. A, 5.nn) on Diesel Generator Loads reviewed the maintenance of DG load calculations. The report referenced 0QA Deviation Report D51-A-840006 and also identified a deficiency in the processing of an ECN in which EEB was r.ot notified of a change in the Auxiliary Power System (APS) loads during the ECN review cycle. ,

NSRS Report I-85-992-SQN (App. A, 5.00), on the Control of AC and DC Electrical Loads documented other discrepancies in the management and control of electrical load margins and interfaces.

External reviews of Sequoyah were performed by Gilbert /

Commonwealth (G/C) and Sargent & Lundy (S&L) beginning in January 1986. The G/C report noted a lack of documentation of design change evaluation and appropriate interface review involving mechanical, civil, and electrical disciplines (App. A, 5.b). The Sargent & Lundy Report on Sequoyah's Electrical Calculation Program listed electrical calculations that were not kept up to date including short circuit, instrument setpoint, cable, and a'2xiliary power system calculations. The NRC inspection of Sequoyah's design control practices in February 1986 identified deficiencies of a similar nature with the auxiliary feedwater pump station pressure switch setpoint calculations and concerns with battery sizing calculations (App. A, 5.a). Also, in the transcript of the NRC investigative interview, the concerned individual discussed the absence of control of calculations, including their informal preparation and issue (App. A, 5.f).

1 0394D - 12/22/86

. f.

TVA EMPLO'YEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2

' PAGE 14 0F 22
d. TVA Calculation-Related Programs TVA established an electrical calculations program in 1985 to correct and resolve deficiencies fcund in electrical calculations at the four nuclear plants (App. A, 5.qq). This program is designed to identify those calculations. required to support safety systems used for safe shutdown (essential calculations) and others needed to support plant reliability and availability (desirable calculations). After identification, the essential calculations are to be located and updated or superseded; if not available they must be generated. In March 1986, the Director of Engineering Technical Services made this effort a requirement for the Mechanical, Nuclear, and Civil engineering branches as well, and a Sequoyah Unit 2 restart item (App. A, 5.k).

In April 1986, a Design Basis Program was developed to address the lack of design criteria for each nuclear plant.

The program requires the development of a Design Basis Document (DBD) that compiles all commitments for each plant that are found in the FSAR, design criteria, NRC commitments, etc. Verification that calculations exist to support the DBD are an essential part of this program. TVA is committed to develop design basis documents for FSAR Chapter 15 safety-related systems prior to the restart of Sequoyah 2.

A Design Baseline and Verification Program (DBVP) was also established in May 1986 to assess the adequacy of past modifications at Sequoyah. The DBVP requires a review and evaluation of modifications since operating license issuance for safety-related systems including verification that calculations exist to support the changes. This phase of the program is also scheduled for completion prior to restart.

Findings:

a. The reports and documents reviewed by the evaluation team support the concern that some calculations prepared during the design phase of the Sequoyah plant were not treated by the design engineers as permanent project / plant support documents equally as important as design input or design output documents. Consequently, they were not controlled in the same degree and manner as design input / design output documents.

(

0394D - 12/22/86

n

~

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

" SPECIAL PROGRAM REVISION NUMBER: 2 I PAGE 15 0F 22

b. The lack of adequate coordination between branch and project for electrical design changes was documented in several reports (App. A, 5.mm and 5.nn) and resulted in inadequately prepared and controlled electrical load calculations (See Sequoyah Element Report 213.1).
c. Both past and current TVA engineering procedures require review of calculations that may be affected by or that support changes in design output documents.

Conclusions:

The issues of inadequate interface coordination and control of design calculations (issues "a" and "b"), in particular those that preceded the SQN operating license, are valid and are supported by the reports, documents, and calculations reviewed by the evaluation team.

There were and are procedures to control and maintain calculations and therefore, issue "c" is not valid.

In addressing the existence and updating of calculations required to support safety systems at SQN, the TVA Essential Calculation Program (ECP) takes an initial step in correcting past deficiencies. To ensure a fully responsive program, however, the ECP must pro /ide evidence to substantiate the following elements:

o Documentation criteria for the classification of calculations as essential, desirable, or obsolete o Verification that calculations have been reviewed for unverified assumptions, reasonable method / approach, reasonable results, etc.

o Documentation of independent review of the list of essential /

desirable calculations and approval of these lists by TVA management.

o Detailed schedules by engineering discipline for the postrestart. long-term completion of the Essential Calculation Program.

(

0394D - 12/22/86

- 1,

. TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 16 0F 22

10. CORRECTIVE ACTION:

TVA has submitted the following corrective action plan (TCAP-030):

a. Each engineering discipline is establishing criteria for .

classifying calculations as essential, desirable, or obsolete which are identified in their Essential Calculation Program.

b. Calculations are being reviewed for unverified assumptions, reasonable method / approach, etc., and are monitored in calculations logs in accordance with engineering procedures.
c. Each engineering discipline has been requested to address in their Essential Calculation Program the need to document an independent review of the list of essential / desirable calculations and approval by TVA management; and to provide a detailed schedule for the post-restart, long-term completion of the Essential Calculation Program.

The evaluation team concurs with the corrective action plans.

L 03940 - 12/22/86

. t:

. TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 I PAGE 17 0F 22 APPENDIX A

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a. Letter from J. M. Taylor, NRC, to S. A. White, TVA, "NRC Reports 50-327/86-27 and 50-328/86-27," [L44 860506 542],

(04/22/86)

b. Gilbert / Commonwealth Report No. 2614: Sequoyah Nuclear Plant Modifications for TVA, (03/03/86)

. c. Sequoyah Nuclear Plant - Design Baseline and Verification Program, RO, (05/01/86)

d. Sargent and Lundy Final Report, Sequoyah Nuclear Plant, Nuclear Plant-Electrical Calculation Program Assessment, (04/08/86)
e. Letter from R. Gridley, TVA, to J. Nelson Grace, NRC, "NRC-01E Region II Inspection 50-327/86-27 and 50-328/86 Response to Deficiencies and Unresolved Items,"

[L44860729 801], (07/28/86)

f. Letter from B. J. Youngblood, NRC, to S. A. White, TVA,

" Transcript of Interview of Dallas R. Hic'<s," (06/23/86) 9 Letter from D. G. Smith, INP0, to J. A. Coffey, TVA, transmitting JNP0 Evaluation of Bellefonte Construction Project,(06/05/86)

h. Letter from Z. T. Pate, INPO, to H. G. Parris, TVA, transmitting INP0 Evalustion of the Watts Bar Nuclear Plant Construction Project, (09/19/85)
1. Sequoyah Nuclear Performance Plan Volume II, Final Concurrence Transmitted July 14, 1986 (RIMS No. L44 860714 800), Chapter III, Paragraph 2.2, " Design Baseline and Verification Program."
j. Sequoyah Engineering Project (SQEP) Project Manual, R0,Section VII, " Project Specific Requirements (Variances / Expansions)," (09/27/85)
k. TVA memo from Kirkebo to Those Listed, (805 860307 006),

" Design Calculations," (03/07/86)

(.

i 03940 - 12/22/86

.. t TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2

~

PAGE 18 0F 22 APPENDIX A (Cont'd)

1. TVA memo from Drotleff to Those Listed, (B44 860402 007),

" Design Basis Program for TVA Nuclear Plants," (04/08/86)

m. TVA memo from Key to Chandley, (B44860729012), "Sequoyah Nuclear Plant - Design Calculation Review," (07/29/86)
n. 10CFR50, Appendix B, " Quality Assurance Criteria for. Nuclear Power Plants and Fuel Reprocessing Plants," Criterion III

. o. Regulatory Guide 1.64 (Rev. 2, dated 06/76), " Quality Assurance Requirements for the Design of Nuclear Power Plants"

p. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
q. TVA Topical Report, TVA-TR75-1A (Rev. 8), " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants"

- r. EN DES-EP-1.14, Rev. 10, " Engineering Records - Retention and Storage," (05/13/83)

s. EN DES-EP-3.03, Rev. 8, " Design Calculations," (04/24/84)
t. EN DES-EP-3.10, Rev. 7, " Design Verification Methods and Performance of Design Verification," (04/25/85)
u. EN DES-EP-4.04, Rev. 9, "Squadcheck Process," (04/24/84)
v. OEP-06, Rev. O, " Design Input," (04/26/85)

" w. OEP-07, Rev. O, " Calculations," (04/26/85)

OEP-10, Rev. O, " Review," (04/26/85)

~

x.

F'

~

y. OEP-11, Rev. O, " Change Control," (04/26/85)
z. OEP-16, Rev. O, " Design Records Control," (04/26/85) aa. NEP-1.3, Rev. O, " Records Control," (07/01/86)

(

.03940 - 12/22/86

. t.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 6' ' PAGE 19 0F 22 APPENDIX A (Cont'd) bb. NEP-3.1, Rev. O, " Calculations," .(07/01/86) cc. NEP-3.2, Rev. O, " Design Input," (07/01/86) dd. NEP-5.1, Rev. O, " Design Output," (07/01/86) ee. NEP-5.2, Rev. O, " Review," (07/01/86) ff. NEP-6.1, Rev. O, " Change Control," (07/01/86) gg. TVA memo from Chandley to Kirkebo, (B44 860814 014) "SQN -

Review of Existing Calculations," (08/14/86) hh. Not used.

ii. TVA memo from Raulston to Those Listed, (845 860909 258)

" Design Calculation Verification," (09/09/86) jj. TVA memo from Barnett to Kirkebo, (841860811013) " Design t Calculations," (08/11/86) kk. TVA memo from Johnson to Barnett, (B25 860819 499) "SQN -

Policy Memorandum PM 86-02 (CEB) Civil Discipline Policy for Design Calculations," (08/19/86)

11. TVA memo from Raughley to Those Listed, (843 860811 903)

" Policy Memorandum PM86-15 (ECB) Electrical Calculations Checklist," (08/06/86) mm. Office of Quality Assurance (0QA) Audit Deviation Report 051-A-84-0006, (07/02/84) (0QA 840801503) nn. NSRS Report No. I-85-132-SQN, (03/06/86) oo. NSRS Report No. 1-85-992-SQN (Final Report), (04/07/86) f pp. TVA memo from Weinhold to Wilson (B05 86 0916 001) " Division of Nuclear Engineering Assurance Audit 86 Sequoyah Electrical Evaluation Restart Issue," (09/16/86) l qq. TVA me.mo from Beasley to Chandler, (805 85 1107 003) " Audit Deviation Report D51-A-84-0006-001, Inadequate System to Ensure Calculations Are Updated to Support Design Change Made afte.r Plant Operation," (11/07/86) b 4

03940 - 12/22/86

~

< TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2

(~ PAGE 20 0F 22 APPENDIX A (Cont'd) rr. TVA memo from Abercrombie to Brown, (S03 861210 805) "SQN-ECTG Element Report 205.02 SQN R1 - Enginetring Category Corrective Action Plan (CAP)," (12/12/86)

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY 0R CONTROL IN THIS AREA?
a. 10CFR50, Chapter 1, Appendix B, " Quality Assurance Criteria

- for Nuclear Power Plants," (as amended, 01/75)

b. NRC Regulatory Guide 1.64, Revision 2, " Quality Assurance Requirements for the Design of Nuclear Power Plants," (06/76)
c. ANSI N45.2.ll - 1974 " Quality Assurance Requirements for
the Design of Nuclear Power Plants"
d. NQAM, Part IV, Section 2, " Design Service," (12/31/84)
e. NEP-1.3, Rev. O, " Records Control," (07/01/86)
f. NEP-3.1, Rev. O, " Calculations," (07/01/86) ,
g. NEP-3.2, Rev. O, " Design Input," (07/01/86)
h. NEP-5.1, Rev. O, " Design Output," (07/01/86)
1. NEP-5.2, Rev. 0, " Review," (07/01/86)
j. NEP-6.1, Rev. O, " Change Control," (07/01/86)

A q

l'

-5 03940 - 12/22/86

, - , .- - . , - .- , . , .- , ,e--, - - - - - -

. t.

~

- TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 21 0F 22 APPENDIX A (Cont'd)

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

RFI No. SQN-530, (09/04/86)

RFI No. SQN-533, (09/05/86)

RFI No. SQN-569, (09/16/86)

Report of meeting in Knoxville and at SQN site, August 27-29, 1986, BLT-043 (09/16/86)

(

s 03940 - 12/22/86

-. ,, e , - - nu- --.---, --,,-n ,-

  • t.

< TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.2(B)

SPECIAL PROGRAM REVISION NUMBER: 2

(;

PAGE 22 0F 22 CATD LIST The following CATDs identify and provide corrective actions for the findings included in this report:

205.02 SQN 01 (12/12/86) l 4

f 1

L ~

i i

I a

k,-

j 03940 - 12/22/86

ta . [ ' ~ ~ ~ . .y. . . ; & 4) ; . .  % , a y, 4 , , , , , g, ; _ a .a g, ,s , , ,- _

q ,

s til PAGE -

61 REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY OFFICE OF fiUCLEAR PONER RUN TIME - 12:57:19 FREQUENCY - REQUEST RUN CATE - 12/02/86 ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20502 CALCULATION CONTROL AND INTERFACE ,

GENERIC KEYHORD A S

APPL QTC/NSRS P KEYHORD E i H KEYNORD C CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN "

DESCRIPTION KEYNORD D HUMBER CAT CAT D LOC FLQB REPORT R

)

t I-85-128-NPS EN 20106 S BFN YYYY SS AN INDIVIDUAL FROM SFN WROTE NSRS EX EN 20411 REPORT PRESSING lfIS CONCERN THAT THE CONTRO EN 20501 L AND QUALITY OF OE'S DESIGN EFFORT 3 EN 20502 IS INADE00 ATE. THE CI SENT SEVERAL

! EN 20601 ROUGHLY WRITTEN PAGES DETAILING AND QA 80303 SUMMARIZING HIS EVALUATION AND CONCL 1 USION OF THREE MA.IOR AREAS: (1) D

) DESIGN PROCESS WI -8 5 -100-043 EN 20106 S HBN YYYY SR THERE ARE PROBLEMS IN DESIGN CALCULA 20501 REPORT TIONS, IN THAT SOME ARE NEVER PREPAR NONCONFORMANCE i T50213 EN ED, SOME ARE INADEGUATE IN SCOPE AND ENGINEERING 1 ,

EN 20502 OUALITY, AND SOME ARE NOT STORED AS REPORTS

' EN 20503 l QUALITY RECORDS. THERE IS INADEQUA TE INTERFACE AND CONTROL OF DESIGN C ALCULATIONS, NHICH IMPACTS TRACEABIL j ) ITY OF DESIGN REGUIREMENTS. CI HAS NO FURTHER INFORMATION. ANONYMOUS C ONCERN VIA LETTER.

"t 3 2 CONCERNS FOR CATEGORY EN SUBCATEGORY 20502 t

)

)

i i _

)

)

A 4

- _