ML20212G962

Rev 1 to Organization or Operating Procedures: (Engineering)

ML20212G962
Person / Time
Site:	Sequoyah
Issue date:	01/13/1987
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20212G828	List: ML20212G824 ML20212G859 ML20212G962 ML20212G991 ML20212H051 ML20212H072 ML20212H095 ML20212H103 ML20212H128 ML20212H145
References
204.0(B), 204.0(B)-R01, 204.0(B)-R1, NUDOCS 8701210247
Download: ML20212G962 (46)

Text

--

3

+

TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.0(B)

SPECIAL PROGRAM REPORT TYPE: SUBCATEGORY REVISION NUMBER: 1 NON-RESTART JUSTIFICATION

SUMMARY

TITLE: ORGANIZATION OR OPERATING PROCEDURES (Engineering) PAGE 1 0F 18 REASON FOR REVISION:

1. Revised to incorporate SRP/TAS coments.

I PREPARATION PREPARED .

hv / SIGNATURE

/2-29 4ff, DATE REVIEWS

_ t.E

_ kr VIEW COMMI EE YNfW" ' SIGNATURE

~ ~~

b DfE /

ggd f i /J 2

,/i>/8 7 SIGNATURE DATE CONCURRENCES A972/Lp Abtdir, CEG-H: M /2-19 E SRP: OM,ctd /dhn+g/ /-/.3S[

SIGNATURE DATE g SIGNATURE /* [/

~DATE

'ATT@0VED BY:

/

V)(//h4,Y /-IS-T7 m ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE i

CONCURRENCE (FINAL REPORT ONLY) 0586D/R0 *SRP Secretary's signature denotes SRP concurrences are in files.

8701210247 DR 870115 ADOCK 05000327 ma

SEQUOYAH NUCLEAR PLANT

( ENGINEERING RELATED EMPLOYEE CONCERNS SPECIAL PROGRAM NON-RESTART JUSTIFICATION

SUMMARY

SUBCATEGORY 204.0(B) 1.0 CPARACTERIZATION OF ISSUES The issues in Subcategory 204 (Engineering Organizatic, or Operating Procedures) refer to alleged organizational and/or procedural deficiencies in the engineering design process for the production of design output documents. This report addresses 24 individual concerns that were categorized into the following elements:

204.1 - Organizational Structure 204.2 - Systems Design Responsibility 204.3 - Design Responsibility, Field vs. Office 204.4 - Design Document Completeness  !

204.5 - Design Review Process 204.6 - ECN Process 204.7 - Vendor Documents 204.8 - Communication and Interface Control 204.9 - Use of Reverse Prints 204.11 - Scope of Engineering for Modifications The concerns in this subcategory were originally raised at Watts Bar Nuclear Plant (WBN). Although there were no specific concerns raised in this area for Sequoyah Nuclear Plant (SQN), the organization and procedures that governed the SQN design were essentially idestical to WBN. WBN is a Construction Permit (CP) Plant while SQN is an Operating License (0L) P1 ant. Construction is not yet complete at WBN, while SQN received Operating Licenses on Unit 1 and 2, on 09/27/80 and 09/15/81, respectively. However, SQN was voluntarily shutdown by TVA in August, 1985 for the reasons noted in Section 2.1.

Technical deficiencies or procedural difficulties initially encountered at SQN were essentially resolved before and/or during initial startup (including PRE-OP testing) through applicable inspection, test, and change control programs, or will be discovered and resolved in the implementation of the Design Baseline and Verification Program (DBVP) and the Design Basis Program (DBP).

Specific technical or hardware problems that may have resulted for the reasons alleged by the organizational or procedural employee concerns being discussed herein, are addressed in individual Sequoyah element reports as restart issues.

\

0586D/R1 (12/24/86) Page 2 of 18

This report addresses only the programmatic aspects of the concerns. If found valid, these programmatic deficiencies must be formally addressed

( as needed improvements in .the design process. However, full implementation of these programmatic improvements or enhancements is not considered to be a requirement for plant restart, for the reasons outlined in the following sections. The current programs planned, or in the implementation phase, should give reasonable assurance that any unidentified major deficiency in the design and construction of SQN will be discovered and resolved.

2.0 CRITERIA AND COMPLIANCE 2.1 Backaround Sequoyah is a two-unit nuclear power plant. Each of the two units employs a pressurized water reactor nuclear steam supply system with four coolant loops, furnished by Westinghouse Electric Corporation. The plant has been designed, built, and operated by TVA. Unit 1 began commercial operation July 1,1981, and Unit 2 began commercial operation June 1, 1982.

Because of questions about the environmental qualification of electrical ~

equipment at Sequoyah,' TVA voluntarily shutdown Unit 2 on August 21, 1985, and Unit 1 on August 22, 1985. These questions, and other events which reflected adversely upon the quality of performance of TVA's nuclear activities, have led-to a thorough evaluation of the TVA nuclear program, including its management and operation of Sequoyah.

The Sequoyah plant design was begun in the late 1960s when regulatory requirements were 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 documents are not Sequoyah reauirements. It is not necessary to update the Sequoyah Plant to l

include all of the new guidance published by NRC, unless there are l

specific requirements or commitments to do so.

t l Although the Sequoyah Preliminary Safety Analysis Report (PSAR) was l released prior to issuance of 10CFR50 Appendix B, the Sequoyah engineering organization began to comply with the applicable criteria upon its issue as a draft document in mid-1969. The subsequent issuance of 10CFR50 Appendix B, ANSI N45.2.11, and Regulatory Guide 1.64 have i

also been complied with by TVA since their issuance.

j TVA Engineering Quality Assurance program policy directives and Engineering implementation procedures for the Sequoyah Nuclear Plant

! have stipulated compliance requirements with the applicable criteria and l

are equivalent to those used by other utilities in the nuclear power industry.

L l

t 05860/R1 (12/24/86) Page 3 of 18

. u 2.2 Governing Documents Engineering Quality Assurance program policy for the Sequoyah nuclear plant has been documented in the following:

, 1. Sequoyah Preliminary Safety Analysis Report (mid 1968 through 1973)

2. Sequoyah Nuclear Plant Quality Assurance Manual (SQN-QA-Manual)

(early 1970 through late 1973)

3. Sequoyah Final Safety Analysis Resort (1974 until present)

4. Office of Engineering Design and Construction Quality Assurance Manual for Design and Construction (0EDC - QA Manual) (January 1974 through 1977)

5. Quality Assurance Program Requirements Manual for Design, Procurement, and Construction (PRM) (January 1978 tbrough 1984)

6. Interdivisional Quality Assurance Procedures Manual for Nuclear Power Plants (IPM) (January 1979 through 1984)

7. Nuclear Quality Assurance Manual (January 1985 through mid-1986)

8. Nuclear Quality Assurance Manual'(Interim) (1986 until present)

Engineering implementation procedures for the Sequoyah Nuclear Plant have been documented in the following:

l- 1. Sequoyah Nuclear Plant Quality Assurance Manual (SQN-QA-Manual)

(early 1970 through late 1973)

2. Division of Engineering Design Engineering Procedures Manual (EN DES) (late 1973 through mid-1985)

3. Office of Engineering Design and Construction Quality Assurance Manual for Design and Construction Volume II (Volume II OEDC QAM)

(January 1974 through 1977) 4 Engineering Program Directives, Office of Engineering Procedures Manual (0EPs) (mid-1985 through mid-1986)

5. Nuclear Engineering Procedures Manual (NEPs) (mid-1986 until present)

6. Sequoyah Project Manual (SQEPs and SQEP-AIS) (late 1985 until present)

These procedures have been reviewed by the evaluation team. The evaluation team concludes that if properly implemented, these procedures represent an adequate program for the control of the design process.

Procedures in and of themselves cannot be all inclusive stand alone documents. Proper training, management, design checks, and use of experienced personnel are all necessary ingredients to implement an adequate design program and correct deficiencies that may have resulted from procedural shortcomings or from not implementing the procedure. l The design, construction, start-up, and operation phases of the Sequoyah Nuclear plant each have had quality verification processes that provide l for the detection and correction of conditions adverse to quality. The TVA Quality Assurance Program has been in effect through each of these phases and includes requirements for surveillance and audits to assess engineering compliance to applicable procedures and requirements for remedial and corrective actions when required. Thus, if properly implemented the TVA Quality Assurance Program should have provided easonable assurance that applicable procedures were followed and/or deficiencies identified for corrective action.

0586D/R1 (12/24/86) Page 4 of 18

• b 2.3 Regulatory Requirements

(

The regulatory requirements applicable to this subcategory are specified in the Sequoyah updated FSAR (Ref. 4) and are contained in the following:

o- 10CFR50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" (Ref. 3) o ANSI N45.2.ll-1974 ". Quality Assurance Requirements for the Design of Nuclear Power Plants" (Ref 6)

Both criteria documents contain specific requirements pertaining to design control. Applicable quotations from these governing criteria documents are stated below:

o 10CFR50, Appendix B, Criterton III, " Design Control" states in part:

'.The design control measures shall provide for verifying or checking and adequacy of design, such as by the performance of design' reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program."

" Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization."

Criterion V, " Instructions, Procedures, and Drawings" states:

" Activities affecting quality shall be prescribed by documented

. instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or cualitative acceptance criteria for determining that important i activities have been satisf actorily accomplished."

o ANSI N45.2.ll-1974, Section 4, " Design Process," and Section 8, I. " Design Change Control" (App. A, f) states in part:

i

" Design activities shall be prescribed and accomplished in accordance with procedures of a type sufficient to assure that applicable design inputs i are correctly translated into specifications, drawings, procedures or instructions."

. . . Documented procedures shall be provided for j design changes to approved design documents, L

including field changes, which assure that the

' , impact of the change is carefully considered, 0586D/R1 (12/24/86) Page 5 of 18 i

1 required actions documented and information

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

2.4 TVA Compliance Programs and Procedures Sequoyah PSAR and FSAR updated through Amendment 3 (04/86), contain commitments that outline requirements that comply with 10CFR50, Appendix B, and ANSI N45.2.11 design and design change control criteria.

TVA Engineering' Department Procedures wfiich address the regulatory criteria outlined above are listed below:

o Office of Engineerinc Design and Construction Quality Assurance Manual for Design anc, Construction (OEDC QA Manual, Volume II -

Ref. 7) contains requirements for design control. It specifies procedures to be followed for design and revisions of design documents.

o Quality Assurance Program Requirements Manual for Design, Procurement, and Constructio_n (PRM, Ref._8), Section 3.0, Design control procedure " Office of Engineering Design and Construction Requirements for Specifying Codes and Standards" imposes performance requirements that comply with 10CFR50, Appendix B criteria. For example, systems and structures are to be designed

-t by EN DES prior to any construction activities, and further imposes restriction on Construction to: " Refer all field changes to EN DES for approval prior to work." ,

o Interdivisional Quality Assurance Procedures Manual for Nuclear Power Plants (IPM - Ref. 9). This document includes interf ace procedures for design and design change control across-interdivisional organizations.

o Nuclear Quality Assurance Manua1 (TVA NQAM - Ref.10).

The procedures contained in this manual impose requirements for design and change control which, if followed, would prevent field design, installation or modification to any component or structure without EN GES prior approval.

o Nuclear Quality Assurance Manual (Interim) (TVA NQAM - Ref.11).

This interim manual imposes requirements upon Engineering, Operations and Construction which fully comply with 10CFR50, Appendix B and ANSI N45.2.ll design and design change control l criteria. When properly implemented, these requirements preclude f abrication or modifications to any component or structure without prior Engineering approval.

o Sequoyah Nuclear Plant Ouality Assurance Manual (SQN NQAM -

t Ref. 12). This manual contains procedures that impose requirements on Engineering and Construction that comply with applicable code '

criteria and 10CFR50 Appendix B.

0586D/R1 (12/24/86) Page 6 of 18 i

L

_w,r,v- ,-w---,,,-, --,nn_ .,__,.._g, , _ , , _ _ . __

o Division of Engineering Design - Engineering Procedures Manual

.( (Ref. 13). These EN DES procedures (EPs) provide a regulated system for design control from initial design through field request 3 for changes, o Engineering Proaram Directives Office of Engineering Procedures Manual (Ref. 14). These engineering procedures (OEPs) imposed requirements pertaining to design and design change control that require fabrication installation and/or modification to any component or structure not proceed prior to the issuance of Engineering authorization. OEPs replaced EPs (above) in mid-1985.

o Nuclear Enaineering Procedure Manual (Ref. 15). This manual contains procedures (NEPs) that also provide design and design change control requirements for release of design and/or design change authorization prior to f abrication, installation, or modification. NEPs replaced OEPs in mid-1986.

2.5 New TVA Proarams for Sequoyah o The Sequoyah Desian Baseline and Verification Program (DBVP, Ref. 22) has been established and is being implemented.

The essential elements of the overall program are as follows:

- " Verification of actual plant configuration.

- " Reconciliation to engineering design documents including supporting calculations and design criteria.

- " Reconciliation to the FSAR, licensing commitments, and technical specifications.

- " Performance of Safety Evaluation Reports and Unreviewed Safety Questian Determinations (USQDs) for the system configuration.

- " Issuance of revised key plant drawings which are essential for operations."

The implementation of this program has been structured into two p hases. The pre-restart phase is to carry out the program for the systems required to mitigate FSAR Chapter 15 accidents and to provide for safe shutdown.

The post-restart phase will continue the engineering activities to complete engineering documentation and evaluations describing the as-constructed configurations.

Special programs which have been identified in addition to the DBVP as important to be resolved prior to restart include: completing tfe documentation and resolving equipment environmental qualification questions; verifying the adequacy of past design modifications due to inadequate design control programs; reexamining cable tray support analysis for weaknesses in 0586D/R1 (12/24/86) Page 7 of 18

analytical basis; completing an electrical system analysis where

- g' design requirements did not exist in the past; verifying adequacy of nonrigorously analyzed piping and supports where alternate analysis methodology had been improperly applied; resolving a concern about the effects of . increased temperatures during main steam lines breaks due to revised vendor analysis; examining issues identified by expressed employee concerns; resolving identified areas of noncompliance with 10CFR Part 50 Appendix R fire protection requirements; and assessing the adequacy of the welding program at Sequoyah raised through the employee concern program.

o Desion Basis Program (DBP - Ref. 23)

The TVA Design Basis Program (DBP) has been established and is now being implemented.

The DBP concept ". . . . is a top-down approach in which commitments made to generic upper tier design input documents, commitments made in licensing documents, design requirements needed to satisfy the plant safety analysis, and TVA policies and existing design criteria must be captured in either plant-specific design criteria or other design input documents. These design criteria must include, as a minimum, those general design criteria for site, plant, structures, and systems which when adopted by the project manager constitutes the DBD for that plant."

"The DBD constitutes an additional design input document in that it is commitment-driven." [These design criteria documents are]

. . . . initially issued for a trial use period during which they should be compared to the as-built configuration of the plant and -

any discrepancies resolved. Finally, the project manager . . . ."

[ accepts and adopts] ". . . . this collection of design criteria documents as the DBD for the plant."

The DBD provides the basis against which future plant modifications are measured over the life of the plant.

o Additional confidence in Sequoyah Plant system integrity for restart will be derived through implementation of the following:

- Office of Nuclear Power (ONP) - Configur a. ion Control Task Force (CCTF) (Ref. 24) l

- Design Change Process Improvements Program (Ref. 25)

- Sequoyah Nuclear Plant Change Control Board (CCB) (Ref. 27)

- Specification Improvement Program (Ref. 28)

All of the above programs, plus ongoing TVA QA and external audits, NRC l

inspections, and other categories of employee concerns investigations l (e.g., welding, construction, operations, management, QA), should provide additional confidence that there is no large probability for a major unidentified problem at Sequoyah.

0586D/R1 (12/24/86) Page 8 of 18 l

3.0 EXAMINATION OF ISSuiS The evaluation team has examinad the individual concerns in each element. The following 10 subsections address each of the elements providing.a list of the applicable issues, and summarizing the safety-related implications, if any.

3.1 Organizational Structure (204.1)

The one concern covered under this element contained the following issues:

o TVA's Managerial structure is unwieldy and cumbersome - which sometimes leads to confusion in the design process o Excessive paperwork involved o Too many people in review cycle for ECNs, ECRs, and memos o Paperwork passes through too many hands o Too many EP procedures exist and they need to be streamlined The concern addresses difficulty in performing the design process. If valid, it would indicate a cumbersome design process, but no direct compromise of safety-related design can be inferred from these issues.

Enhancement of document control procedures will address problems with excessive paperwork.

The Sequoyah Nuclear Performance Plan (NPP - Ref.16) contains dialogue pertaining to some of these issues as follows:

o "In the past, major site projects could have benefited from improved control and coordination of functional activities. Also, responsibility was often divided among several groups."

o "In the past, problems and confusion existed within TVA's Nuclear Engineering Program, as both the Engineering Organization and the Sequoyah Nuclear Power Organization performed engineering activities. These problems occurred in areas such as the design control and configuration control programs."

While acknowledging the above, the NPP also contains details of corrective actions which should resolve these anomolies.

G TVA response to Institute of Nuclear Power Operations (INP0) regarding corporate evaluation report findings and recommendations (Ref.18) accepts as valid the findings and recommendations regarding organization and design process deficiencies, however, it also specifies corrective measures.

Regarding the other issues in this element, engineering procedures have ,

already been streamlined, and programs, as noted in Section 2.5, are now in place and being implemented at Sequoyah to resolve these issues.

05860/R1 (12/24/86) Page 9 of 18

3.2 System Design Responsibility (204.2) 1 The one concern covered under this element contained the following issues:

o Overall system design responsibility is not assigned to a specific person.

o No one is monitoring overall design. Responsibility is fragmented with one person handling contract, another mechanical portions, another controls, another electrical, etc. They all together handle the system.

o There is no one person you can contact at Knoxville and depend on for technical responsibility.

The concern states that no one within TVA has specific overall system design responsibility.

Design and interf ace responsibilities for Sequoyah were established and documented in EN DES procedures. The Sequoyah mystems are now designed and constructed. The issue of one person being assigned over-all systems design responsibility, as opposed to the EN DES procedural assignment of responsibility, is academic at this point in time since the plant has been constructed. However, recognizing that a design question may have gone unanswered because of the above assignment of responsibility, necessary safety-related system integrity will be verified prior to restart through the DBVP, the DBP, and the other programs now being implemented at Sequoyah.

3.3 Design Responsibility, Field vs. Office (204.3)

The one concern covered under this element contained the following issue:

o TVA permits too many technical decisions to be made by the craft personnel. (e.g., hangers)

This element alleges that Engineering permitted craf t personnel to participate in the pipe hanger design process. If valid, no compromise to safety-related systems would result, because engineerirg now prepares as-built drawings of all pipe hangers and is responsible for the design.

See Reference 20 for discussion of TVA design verification and compliance with NRC Bulletin 79-14 which reconciles the differences between as-constructed and as-designed pipe supports for safety-related systems.

Even if the as-built drawings and the 79-14 program were to miss some deficiencies, the Sequoyah DBVP (Ref. 22) provides further assurance of the integrity of design and construction of pipe hangers. In this program safety-related systems will be walked down and reviewed to assure that as-built drawings are reconciled with the plant design basis

, and that Engineering has approved all design.

05860/R1 (12/24/86) Page 10 of 18

P 3.4 Design Document Completeness (204.4)

The five concerns covered under this element contained the following issues:

o Construction, Test, and Installation Specifications (called General Construction specifications with a "G" number) are of ten incomplete and inadequate.

o Engineering drawings cause problems (constructibility) during installation, and have insufficient technical detail.

o Engineering design drawings and acceptance criteria are changed late in the project.

o Too many conflicts between TVA drawings and vendor drawings exist late in the project.

o Engineering drawings do not always include or represent design requirements.

These concerns allege that construction, testing, and installation '

requirements contained in G-Specs are incomplete and inadequate, and that engineering drawings have insufficient technical detail, conflict with vendor drawings late in the project, and do not always include or rep' resent design requirements. The concerns further allege that engineering drawings and acceptance criteria are changed late in the project.

Although G-Specs may not contain full construction, test, and installation requirements, Sequoyah design output documents which were to comply with TVA Quality Assurance requirements were issued and augmented the G-Specs. If properly utilized, these documents together with interf ace / communication between the design and construction organizations, provide adequate information to construct the plant.

The allegetion that engineering drawings have insufficient design requirements and technical detail pertains to construction of SQN.

During construction, TVA engineering procedures pro'vided several mechanisms to resolve design irregularities and questions through use of FCRs, ECNs, etc. Construction is now complete. All pre-operation and start-up testing is complete and the plant has operated for about three years. Programs were in place during these various phases of the work which contained provisions for resolving any engineering issues.

The allegation that design drawings and acceptance criteria was changed late in the project is probably true in some instances as would be expected in any large engineering and construction project. Needed changes should have been accomplished through the design change control procedures which were in place regardless of the state of the project at the time. The timing of the change does not compromise the safety-related Design.

(

0586D/R1 (12/24/86) Page 11 of 18

The contention that TVA engineering drawings conflict with vendor g

drawings late in the project is also probably true in some instances.

However, changes to the plant that were required should have been made through the plant change control process before or during start-up of t he plant. The timing of the change does not compromise the 4 safety-related design.

l The new programs now being implemented should resolve any safety-related discrepancies which could have resulted it Ay prior procedures were not properly implemented.

1 3.5 Design Review Process (204.5) 4 The eight concerns covered under this element contained the following issues:

o Design drawings, technical specifications, design criteria documents, and pre-op test packages do not receive a second independent technical review as required, but are reviewed primarily for nontechnical, editorial details (English, spelling,-

t etc.)

o Technical reviews (second independent technical reviews) performed at Knoxville are inadequate.

o No technical review is performed after the checkers have reviewed pipe hanger calculations.

l' o Calculations are not generally reviewed by technical supervision.

o TVA independent verification of vendor calculations and designs are either not adequate or not done at all, and design reviews of l vendor designs are not done. (Additional issues relative to calculations are addressed in Sequoyah Element Reports 205.1 and j

205.2; Ref. 21 and 22.)

i o TVA does not conduct independent design reviews of its work.

4 o Design checks and reviews are being performed by technicians ("SE" i level personnel) in lieu of graduate engineers at TVA/ Knoxville i Pipe support group. I o Design analysis and verification processes are not adequately controlled.

2 This, element was considered as a potential restart item based on the j

need for the SQN project to have properly implemented the TVA

Engineering Procedures that involve nuclear safety related activities, structures, system and components. However, now that the investigation and data collection portion of the element report has been completed, l

the evaluation team has determined that the subject issues are not valid. The evaluation process, findings, and conclusions are summarized j below.

i l

)

05860/R1(12/24/86) Page 12 of 18 l

t

1. The issues in this element which were considered as potential-restart items, are related to the design review / independent p verification requirements established by 10CFR50 Appendix B, Criterion III.

2. This evaluation addressed the related engineering procedures and definitions of terms identified in the issues. It was found that-the true independent verification at TVA is done by the checker.

This is all that is required by regulations or by TVA commitments.

3. It was found that second independent verifications and technical reviews are not required by regulations or by TVA commitments.

4 Technical reviews, however, are scheduled only when deemed necessary by the Branch Chiefs. There are existing procedures in place for conducting these technical reviews. Technical reviews observed by the evaluation team demonstrate technical evaluation beyond editorial details.

The evaluation team determined that i.ane of the issues are valid and no direct compromise of safety-related design can be inferred.

3.6 ECNProcess(204.6) 1 The four concerns covered under this element contained the following issues:

l o ECN's are prematurely closed out without the proper status of ECNs

! and affected design being known.

o It takes too long to close out ECN's l

o Procedure OEP-ll revision eliminated the ECN front cover page which provided space for identification of other documents and plant areas affected by ECN. Elimination of this " check-list" which required conside' ration and positive action by the ECN preparer and reviewer may result in an affected document or plant area being

, overlooked.

! o Majority of DCR's are not documented properly.

This element addresses concerns regarding the timely closure and adequate tracking of plant modifications. All modifications to plant j safety systems after OL are being reviewed prior to restart. If there are any problems associated with early Engineering Change Notices (ECNs) and Design Change Requests (DCRs) tiey will be resolved by the Design Baseline and Verification program (DBVP, Ref. 22). The ECN cover page i

information which identified other documents affected by the ECN is now

! addressed by Attachment 2 to NEP 6.1, and by the current modification criteria required by the SQEP project manual Variance / Expansions to i

HEP-3.2 " Design Input." The procedures and forms in place for handling ECNs at SQN are adequate.

' Therefore, the concern is not valid, and no compromise of safety-related

< design can be inferred from these issues.

0586D/R1 (12/24/86) Page 13 of 18 i

., c 3.7 Vendor Documents (204.7)

{.

The two concerns covered under this element contained the following

-issues:

Vendor drawings received by the plant from engineering for

~

o as-constructed drawings are of poor quality.

o Updates.of vendor manuals are sent to Knoxville or Chattanooga Engineering, but they are not received at the plant in a reasonable time thereafter.

This concern is about the quality and timeliness of vendor drawings and other documents received at the SQN plant. TVA Nuclear. Performance Plan includes provisions to preclude recurrence of this anomaly, and all modifications to safety-related systems which have occurred subsequent to_0L are being reviewed through the DBVP. Therefore, no direct compromise of safety-related design can be inferred from these issues.

3.8 Communication and Interface Control (204.8)

The one concern covered under this element contained the following issue:

o There is a lack of effective communication and interface control among organizations,within EN DES (i.e., Branches, Projects,

Procurement,etc.)

The issues identified in this element imply that the interface control and communication among the engineering organizations was not as i effective as it could have been. These issues relate to engineering .

practices which have been procedurally controlled. Therefore, the adequacy and implementation of the procedure is being challenged by the Concern.

If valid, necessary changes will be considered to be program improvements or enhancemeats.

( Since the concern has not given specific examples of a failure to _ _

control the various engineering interfaces and since any findings likely to be identified would be considered program improvements or i enhancements, the evaluation of this element should not be considered a j requirement for restart.

l l

The restructuring of TVA's Organization in the areas of lines of

authority and responsibilities, as noted in the CNPP should improve communication and coordination in engineering and design actitivities.

! The CNPP states "Each site is supported by an engineering project team headed by a project engineer responsible for all engineering on site."

4 i (

i

! 0586D/R1 (l?/24/86) Page 14 of 18

3.9 Use of Reverse Prints (204.9)

The one concern covered under this element contained the following issue:

o Unit 1 prints marked " opposite hand" are being used for Unit 2 which makes work more confusing for engineers and construction workers.

This concern addresses the confusion caused by trying to use original plant drawings for an " opposite hand" application in engineering and construction, including design modifications.

It is true that this practice caused considerable confusion and construction workers and engineers did spend considerable hours using light boxes and window panes to trace drawings on the back of the sheet to get " proper hand" configuration.

However, there were " checks-and-balances," such as inspection and testing, and design change control procedures (e.g., FCRs, ECNs, etc.)

in place to ensure that necessary safety aspects were evaluated and corrected as required. Even if some discrepancies occurred, the DBVP will review safety-related systems for anomalies.

3.10 Scope of Engineering Required for Modifications Not Identified (204.11)

The one concern covered under this element contained the following issues:

o Scope of engineering required for modifications is not identified, o No attempt is made to identify design activities for modifications.

This concern addresses both the extent of Engineering design activities required for plant modifications and the scope of design documents and engineering evaluations required for all plant modifications. This issue is identified and addressed by the Plant Modifications and Design Control programs, as discussed in the Nuclear Performance Plan,Section II, paragraph 3.0 (Ref.16). Also, modifications to safety-related systems subsequent to OL are being reviewed as a part of the DBVP. l Review and verification of those modifications required for restart are addressed accordingly in the DBVP.

t 0586D/R1 ( f/24/86) Page 15 of 18

4.0 CONCLUSION

S o The issues evaluated in this subcategory refer to possible deficiencies which can be categorized as programmatic. That is, they relate to organizational or procedural type (i.e., peperwork) deficiencies. The implications of these issues primarily relate to the engineering department and to engineering / construction interfaces. Typically the issues cited cumbersome processes, untimely receipt of information, difficulty in obtaining engineering decisions and untimely receipt of drawings and

' documents, o The f act that documentation rather than hardware is addressed in this subcategory, provides some latitude in determining when necessary corrective measures should be completed. Also, there are

" checks-and-balances,".such as inspection and testing, in place during and subsequent to the design phase which should provide assuranc'e that necessary safety aspects are evaluated and corrected, as required, on a case by case basis.

o Items requiring resolution prior to restart are addressed accordingl

> programs (y in the above noted Sequoyah element reports ande.g., DB

" t herewith. Additional program control is attained through Engineering Assurance surveillance.

o Completion of the post-restart phases of the above noted Sequoyah -

programs will provide any other needed programmatic enhancements in  ;

the design process.

i o None of the issues in this subcategory were determined to be safety-related or to preclude SQN plant restart. i 1

i i

g I f I

0586D/R1 (12/24/86) Page 16 of 18

- 4

5.0 REFERENCES

1. Sequoyah Preliminary Safety Analysis Report (PSAR)

2. Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Appendix B (Draft)

3. Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Appendix B

4. Sequoyah Final Safety Analysis Report (FSAR), through Amendment 3 (updated 04/86)

5. Regulatory Guide 1.64, " Quality Assurance Reauirements for the Design of Nuclear Power Plants," R2, (06/76)

6. ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"

7. Office of Engineering Design and Construction Quality Assurance Manual for Design and Construction (0EDC) Volume II; procedures reviewed included EN DES-QAP 2.1, " Design

' Review"

8. 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"

9. Interdivisional Quality Assurance Procedures Manual for Nuclear Power Plants (IPM); procedures reviewed include ID-QAP-3.2 R1, " Processing of Construction Change Notifications (CCNs)," and ID-QAP-3.1 R0, "0EDC Site Investigation for Design Purposes"

10. Nuclear Quality Assurance Manual (TVA NQAM), procedures

, reviewed include ID-QAP-1.3, " Work Control;" and Part V.

Section 2.4, " Design Change Control System Using Design Change Supplements" I

11. Nuclear Quality Assurance Manual (Interim); procedures reviewed include Part 1, Section 2.3, " Design Control"

12. Sequoyah Nuclear Plant Quality Assurance Manual (SQN-NQAM),

Section III, " Quality Assurance Procedures - Design," and Section IV, " Quality Assurance Procedures - Construction"

13. Division of Engineering Design - Engineering Procedures Manual. This element report refers to the following:

Volume 1, Section 1.0, Category: General Volume 2, Section 3.0, Category: Engineering

, Volume 3, Section 4.0, Category: Design Volume 4, Section 5.0, Category: Procurements i 05860/R1 (12/24/86) Page 17 of 18 yn n.- -

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

m a,y._-. . . - - _ . , - . . ,_,,_.-yug, a- g>---ww m. +. - , - ,, - - -mn ., -,.m,_..--~,-- --a.

4 e

[.

REFERENCES (cont'd) 14 Engineering Program Directives Office of Engineering Procedures Manual (0EPs) (06/29/85).

15. Nuclear Engineering Procedures Manual (NEPs) (07/01/86).

16. Sequoyah Nuclear Performance Plan (NPP) Volume II, (07/22/86)

17. Sequoyah Project Manual (SQEPs and SQEP-Als) (09/27/85)

18. TVA memo from L. L. Jackson to Those Listed, " Institute of Nuclear Power Operations (INPO) Corporate Evaluation Responses,"(08/14/86).

19. TVA Employee Concerns Special Program Report Number 212.2(B)

Revision 1, " Pipe Support Program NRC Bulletin 79-14 ABR Program"

20. TVA Employee Concerns Special Program Sequoyah Element Report Number 205.1, " Control of Design Calculation - Calculation Preparation Requirement Policy and Practice Scope and Standards"

21. TVA Employee Concern Special Program Sequoyah Element Report Number 205.2, " Control of Calculation - Calculation Control and Interface Requirements"

22. Sequoyah Nuclear Plant - Design Baseline Verification Program, Rev. O, (05/01/86)

23. TVA memo from W. C. Drotleff to Those Listed, " Design Bases Program for TVA Nuclear Plants," (04/08/86)

24. TVA memo from CCTF to S. A. White, " Office of Nuclear Power (0NP) - Configuration Control Task Force (CCTF) Final Report," (06/30/86)

J

25. TVA memo from W. C. Drotleff to S. A. White, " Design Change Process Improvements Program," (08/01/86) 4

26. Procedure for DNE Interface with Change Control Board (CCB)

SQEP-15, (08/01/86)

27. Sequoyah Nuclear Plant Standard Practice SQA A183, " Change Control Board (CCB)," R1, (08/06/86)

28. TVA memo from J. A. Kirkebo to J. E. Houston, " Revision to Specification Improvement Plan," (10/08/86)

ATTACHMENT: List of Issues for Programmatic SUBCATEGORY NO. 204.0(B)

! Date: 12/05 & 22/86 05860/R1 (12/24/86) Page 18 of 18

' SU8 CATEGORY 204 - ORGANilAil0N 04 OPERATING PROCEDURES ELEMENT NUNDER 209.1 Lisi 0F PR0sRAsesATIC IMun APPLICA8tE ELEMENT DESCRIPilDN [NPLOYll_ CONCERN 5 EON RESTART - NO DATE: 12/05/86

, Crganizational Structure Requires Escessive: IN-85-02g-002 l Doc umen ta t ion Reviews / Approvals

, Procedures Response time (Set Points-Sys 90) .

ELEMENT WHERE RESPON-LQwcERN wumstais) 155uf5 j A oRLSE s .sistL sENERAL APPROACN/pETH000'_06Y FOR ELENENT REPORT 14-85-029-002 1. TVA's Managertal structure is 204.1 DP A. Investigate concerns relating to organtrational IVA's Managerial structures is unwieldy and cumbersome which and managerial structure.

unwielding and cumbersome. This sometimes leads to confusion in o Review Engineering organizational structure ,

situation sometimes lead to design process, and lines of responsibility conf usion in the desigg process. o Determine existence of recent reviews.

Esample: escessive amount of 2. Excessive paperwork involved 204.1 DP analyses, studies, of organizational paperwork; too many people in efficiency. Review results of such the review cycle for ECM's. 3. Too many people in review cycle 204.1 DP activities if available ECR's, memos; too many EP for ECN's. ECR's, and memo's o Consider whether characteristics of proc edures . EP's need to be orgshtzational and managerial structure streamlined. 'The paperwork 4. Paperwork passes through too many 204.1 CP at 504 are consistent with counterparts passes through too many hands'. hands. In industry.

Ci stated that this concern is general and could not provide 5. Too many EP procedures e:Ist 204.1 DP 3. Investigate concerns relative to the FCN system.

any specifics. and they need to be streamlined, o Determine the procedures and requirements for ECN system o Review procedures for development of ECNs and controls of ECNs o Determine ECN laplementation requirements o Consider ef fectiveness of procedures in meeting objectives of ECN system o Review ECN practices for compliance tu procedure requirements, including review of results of program audits in this area C. Investigate concerns relative to design document reviews and checking.

o Review Engineering Department procedures

! which establish document review and checking practices and responsibilities o Consider adequacy of the procedures in meeting policy and requirements o Review practices for compilance to procedures, including review of results of program audits in this area 089Fd-15 i

/

i SCC ATEGORY 204 f0RGANIZAT10N OR OPERATING PROCEDURE S ELEMENT NUMBER 204.2 LIST OF PROGRAMMATIC ISSU(S. '

APPLICABLE ELEM[NT DESCRFPTION EMPLOYEL CONCERNS SON RESTART - NO DATE: /z/zz/s6 System Design Responsibility IN 209-010

?

/ FIEMENT WHERE RESPON-CONCERN NUMBER [$1 ISSUES ADDRESSED SIBg_ GENERAL APPROACH / METHODOLOGY FOR ELEMENT REPORT 1:1-86-209-010 1. Overall system design responsibility 204.2 DP Note: It is very unlikely that any one person can to specific overall system ' is not assigned to a specific person. be f amiliar and knowledgeable about all f acets drsign responsibility is and details of design of any (except the very currenity assigned to a 2. No one is monitoring overall design. 204.2 DP simplified) system.

specific persen. There is not Responsibility is fragmented with someone monitoring overall .. one person handling cot: trac t. 1. Investigate TVA's job descriptions to determine design. The responsibility is another mechanical portions, another whether system engineer is addressed, fragmented. Someone handles controls, another electrical, etc.

the contract, another handles They all together handle the 2. Review present TVA procedures to determine if the mechanical portions, another system, overall system design responsib111ty to controls Instrumentation, another one person is adequately covered.

the electrical, etc. They all 3. There is no one person you can 204.2 DP together handle the system. contact at Knoxv111e and depend 3. Examine INPO's Good Practice reports regarding There is no one person you can on for technical responsibility. Systems Engineers and compare to TVA practice, call at Knoxville and depend en for technical responsibility. k. [6v/ew GMwdMAa/4 APA47MdW7*

You may have a person's name, but pgocgpeedy 70 AETWEAvod /# 7"W e ne yo 1 ery

1. U # ##Y/# e!

Quickly that the person is not fd8hMS/d/L/77&S

• knowledgeable of the system.

As a result of this fragmented I, /dWSU ##Sv4TS ## MfeG44^145/0/ff gpproach, quality has been M@ gg447/pg 75 fMM affected. Cl has no additional details. NUC POWER Dept. IS$dII .

concern.

• nMd %

~~

~

SUBCATEGORY 204 - ORGANilATIDN OR OPERATING PROCEDURES ELEMENT INSEER E LIST OF PROGRAMMATIC 1550(1 APPLICARtf ELEMENT DESCRIPi!ON EMPLOVIE CONClRNS SON RESTART - NO DATE: 12/05/86 Design Responsibility WI-85-091-015 Field vs. Cf fice ELEME NT n WHERE RESPON-CONCERN NUMBLR[5] ISSUES ADDRESSED SIBLE ._ GENERAL APPROACH /NETHODOLOGY FOR ELEMENT REPORT WI-85-091-015 1. TVA leaves too many technical 204.3 DP 111ue 1 TVA leaves too many technical decisions to the discretton of 1. Review procedures for field to coordinate decisions up to the crafts' the craft personnel. (e.g. hangers) questions or difficulties back to engineering, discretion, e.g. Craft design the hanger and then engineering 2. Review procedures for handling field installa-does the as-constructed drawing. tions/ modifications (e.g. FCR's, etc.).

CI has no f urther inf ormation.

Construction Dept. concern. 3. Review procedures for 'as-built' drawing requirements.

4 Coordinate response with element report 206.1 covering 'as-built' procedures.

5. Coordinate response with Plant Design Group as it related to hangers, element report 220.7.

1 0897d-17 i

SU8 CATEGORY 204 - ORGANilATION OR OPERATING PROCEDURIS ELEMENT NUMBER [04.4 LIST OF PROGRAMMATIC _!SSUES APPLICABLE ELEMENT DESCRIPTION EMPLOYEE CONCERNS SON RESTART - NO DATE: 12./21/86 Dgsign Document Completeness - Inadequacy Ex-RS-061-004 Constructibility Concerrs/FCR Use IN-85-886-001 Detail lacking (weld sizes) IN 133 - 004 No. of Drawing Revisions Wl-85-IDO-017 General Construc tion Specs W1 100 -038 Design Criteria ELEMENT W'IE RE RESP 04-ISSUES ADDRESSED _SIBLE GENERAL APPROACH / METHODOLOGY FOR ElfMENT REPORT CONCERN NUMBER 1SJ WI-CS-100-017 1. Construction. Test, and 204.4 JL 1. Review Engineering Department procedures for Construction test and install- Installation Specifications general construction specs. which establist ation specifications (called (called General Construction document review and checking practices and g2neral construction specs, with specifications with a 'G" responsibilities, a G _ number) are often number) are often incomplete incomplete and inadequate. C1 and inadequate. 2. Consider adequacy of the procedures in meeting has no further information. requirements.

Anonymous concern via letter.

3. Review practices for compliance to procedures, including review of results of program audits in this area.

4. Determine applicablitty of G-Specs to plant modifications following start of plant operation.

TVA management has difficulty 204.4 JL 1. This issue is too broad and vague to be IN-86-133-004 1.

Management has problems with creating workable drawings addressed in any specific detat1. However, we creating workable drawings will review and evaluate the TVA progransnatic without having many problems 2. TVA Engineering drawings cause 204.4 JL systems addressing requirements for engineering in Installation. Construction problems during installation. design to include construction requirements, concern. Cl has no additional Evaluate TVA progransnatic systems for require-information or details. 2.

ments directing consnunication between construction and engineering regarding problems during installation.

3. Review practices for compliance to procedures including review of results of program audits in this area.

% fewsw 6N6AgggAAyf OffMdVMOeff Atoccoeeds M MesmeM6 Hrs rk fourt DdS/drM DecMdWM Y>

coAssrwocriou m uusreucrM/ury ceAJ3tedde 7 ton.S .

OR9 7d -1 R

SUBCATEGORY 2D4 - ORGANilAilDN OR OPERATING PROCEDURES LLEMENT NUMBER 204.4 Lisi 0F PROGRAMMATIC 155jLE}

APPLICARIE ELEMENT DESCRIP]l0N EMPLOYEE CONLERNS 50N RESTART - NO DATE: 12/05/86 Design Document Completeness - Inadequacy E X 061 -004 Constructibility Concerns /FCR Use IN 85-886-001 Detat! lacking (weld slles) IN-86-133 004 No. of Drawing Revisjons Wi 85-100-017 n General Construction Specs Wl-85 100-038 ,

Design Criteria ELEME NT WHERE RESPON-CONCERN NUMBERf51 ISSUE 5 ADDRESSED S18tl GENERAL APPROACH / METHODOLOGY FDR ELEMENT REPORT IN-85-886-001 1. Engineering designs are not 204.4 JL Issues 1 throveh 4 IVA designs were not developed constructible well enough to be constructable: 1. This issue is too broad and vague and cannot

1) design changes are $t111 2. Too many design changes made late 204.4 JL addressed in any specific detall. However, we being instituted in areas in the project. will review and evaluate the TWA programmatic where there should have been systems addressing requirements for engineering alnimal changes especially in 3. Many acceptance criteria are changed 204.4 JL design to include construction requirements, area of conflicts between TVA late in the project.

and vendor dwgs. 2) engineering 2. Review Engineering Department procedures which design criterla is of ten non- 4. Too many conflicts between TVA 204.4 JL estabilsh document review, checking, and design existent, particularly for drawings and vendor drawings exist verification practices and responsibilities selsmic hanger design. Many late in the project. regarding construction requirements.

design criteria or acceptance criteria are still being 5. Engineering design criteria are of ten 201.3 DZ 3. Consider adequacy of the procedures in meeting changed. This is generlC non-existent (i.e., for selselC requirements.

concern. Any further inform- hangers) ,

atton would divulge confident- 4. Review practices for compilance to procedures,

, tality. Construction Dept. 6. Many design criteria are changed late 201.3 DZ including review of program audits in these concern. Follow-up not required. In the project. areas.

5. Coordinate response with Plant Design Group, Element report 220.3 Issues 5 and 6 See element repert 201.3 089 Fd -19

SUBCATEGORY 204 - ORGANilAil04 OR OPERATING PROCEDURES REMENT INNg[1 294_,1 LIST OF PROGRANNATIC ISSUES APPilCARlt REMENT DE}CRIPTION [NPLOYt t CONCEENS $QN RESTART - NO DATE: 12/05/86 Design Document Coneleteness - Inadequacy EX-85-061 004

. Constructibility Concerns /FCR Use IN 85-886-001 Detail lacking (weld sizes) IN-86-133 004 No. of Drawing Revisions WI-85 -100-017

! General Construction Specs WI-85-100-038 Design Criteria ELEMENT WHERE RESPON-(ONCERN NUM8 Q[}l ISSUES ADDRESSED SJ8ti; GENERAL APPROACN/NETH000 LOGY FOR ELEMENT REPORT EX-85-061-004 1. Drawings do not always show complete 204.4 JL Issues 1 and 2 Orawings do not always show details needed to complete the work.

complete details 1.e. specific Example: Specific weld sizes are 1. Review Engineering Department procedures and weld size. Construction concern. not always shown standards which estab11sh drawing requirements CI has no additional detall. for defining detall of work necessary for

2. Drawings do not always show complete 204.4 JL construction completion (including discipline-details needed to complete the work specific standards and procedures).

(not Ilmited to weld sizes).

2. Consider adequacy of the procedures in meeting requirements.

3. Review practices for compliance to procedures, and standards, including review of results of program audits in the procedural area (s).

4. Coordinate response with Plant Design Group, for weld size, element report 222.3.

Other Issues See elements where addressed.

0897d-20

SU8CAllGORY 204 - ORGANIZATION OR OPERATING PROCEDURES ELEMENT NUMBER 204 A LIST OF PROGRAMMATIC ISSUES APPLIC A8t E (LEMENT DESCRIPTIDN (NPLOYtt CONCLRNS SON RESTART - NO DATE: 12/05/86 Design Document Completeness - Inadequacy EX-85-061-004 Constructibility Concerns /FCR Use IN 85-886-001 Detail lacking (weld stres) 14 86-133 004 No. of Drawing Revisions Wi-85-100-Ol7 ',

General Construction Specs WI-85-100-038 Design Criterla ELE MENT WHERE RESPON-(ONCERN NUMBER (S) ISSUES ADDRESSED SIDLE GENERAL APPROACH /NETH000 LOGY FOR ELEMENT REPORT Wi-85-100-038 1. Design / Installation Drawings do not 204.4 JL Issues 1 and 2 Design / installation drawings always represent design requirements, do not always represent or 1. Review engineering procedures and their include design requirements. 2. Design / Installation Drawings do not 204.4 JL references to guides and standards to determine Design guides / standards are always include design requirements. which requirements are to be included on the utt11 ed only when designers drawings, want to use them. Design 3. Design Guldes and Standards are 201.4 DZ guides / standards are inadequate only used when desired by Designer. 2. Establish esemples of drawings from in many areas, and there are each discipilne to be reviewed against design alsuses, such as appilcable 4. Design Guldes and Standards are 201.4 DZ requirements.

parts are not referenced or inadequate in many areas.

- encerpted as requirements. CI 3. Review drawings and evaluate.

has no f urther Information. S. Design Guides and Standards are 201.4 DZ Anonymous concern via letter. misused.

6. Applicable parts of Guides / 201.4 DZ Standards are not referenced or encerpted as requirements on drawings, i

I 089 Fd -21

SUBCAl[ GORY 204 - ORGANIZATION OR OPERAllNG PRDCEDURES CLtMENT NUMOCR 204.5 [MT OF PROGRAMMATIC 155U[}

APPLICABLE ELEMENT DESCRIPilDN [M_PLO]((_CONCfRNS $0N RESTART - 20 DATE: 12/05/86 Design Review Process / Independent WI 100-04 7 Verification Policy and Practice Wi 100 -04 6 a Vendor Designs and Calcs IN 85-143-001 ,

Changes to vendor Designs IN-85-103-003 IN-86-209-003 .

IN-85-103-N04 WBP-86-025-x02 ELEMENT WHtRE RESPON-CONCERN NUN 8ER($) ISSUES ADDRESSED SIBLE GENERAL APPROACH / METHODOLOGY FOR ELERENT REPO#f I N 209 -003 1. Design Dwgs do not receive a second 204.5 DZ All issues Design drawings, technical independent technical specifications, design crl- review as required. 1. Review hierarchy of documents to establish teria documents, pre-op tests pertinent TWA licensing commitments relative pkg., etc. are not receiving a 2. Technical Specifications do not 204.5 DZ to issues.

second independent review receive a second independent as required, but are reviewed technical review as required. 2. Review Engineering Department procedures which primarily for cosmetic details, establish documents review and check practices (English, spelling, etc.). The 3. Design Criteria documents do not 204.5 DZ and responsibilities.

technical reviews are performed receive a second independent at Knouv111e and the personnel technical review as required. 3. Review other procedures whlch establish performing the reviews are practices and responsibilities, such as, vendor either not esperienced enough, or 4. Pre-op Test Packages do 204.5 DZ design interf ace and receiving inspection, as schedule pressure prevents them not receive a second independent applicable.

from performing an adequate technical review as required.

technical review. This has 4. Consider adequacy of. the procedures in meeting been going on since late 70's. 5. Design documents are given only 204.5 DZ commitment requirements.

The potential exists for vaulted a cosmetic review for English, test records, and design spelling. etc. 5. Review practices for comp 11ance to procedures, documents to be nonconforming, including review of results of program audits, which would ef fect construction 6. Technical reviews performed at 204.5 DZ as applicable, quality. Cl has no additional Knoxville are inadequate, thtre-detalls. NuC Power Concern, fore undocumented prob 1 ras n0y exist.

0897d-22

SUBCATEGORY 204 - ORGANilATION OR OPERATING PROCEDURES EEEMERT NUMB [R 204,5 LIST OF PROGRAMMATIC 155UE1 APPilCARLE

[lENENT DESCRIPTIDN EMPLOYEE CONCERNS $QN RESTART - NO DATE: 12/05/86 Design Review Process / Independent Wi ~85-100-04 T Verification Policy and Practice WI#95-100-046 Vendor Designs and Calc 5 IN 85 148-001 Changes to vendor Designs IN 85-103-003 _

IN-86 ."01-003 IN-85-101-N04 WBP 86 C)5-X02 EEENENT WHERE RESPON-CONCERN NUMBERf51 ISSUES _

ADDRESSED 518tE EENERAL APPROACH / METHODOLOGY FOR EEEMENT REPORT I N 103-003 1. No technical review is ; '*ormed 204.5 OZ All Issues l For pipe / hanger calculations, after the checkers have no technical review is performed reviewed pipe calculations. 1. Review hierarchy of documents to establish af ter checkers have reviewed pertinent TVA licensing commitments relative them. No further information 2. No technical review is performed 204.5 OZ to issues.

In flie. Construction Depart- af ter the checkers have ment concern. reviewed hanger calculations 2. Review Engineering Department procedures which establish documents review and check practices NOTE: See also IN-85-103-N04 3. No technical review 15 performed 204.5 OZ and responsibilities, af ter checkers have reviewed other calculations. 3. Review other procedures which establish practices and responsib111tles, such as, vendor design interfaces and receiving inspection, as I N 103 -N04 1. Calculations are not generally 204.5 OZ applicable.

NRC Identifled the following reviewed by technical supervision.

concern from review of Qit flie. NOTE: Interpret technical super- 4. Consider adequacy of the procedures in meeting l

• Calculations are not generally vision to mean engineering super- commitment requirements, reviewed by technical super- vision, vision. (Note: This is same 5. Review practices for compliance to procedures, as IN 85-103-003), Plant Design including review of results of program audits, as applicable.

6. Coordinate response with interf ace groups as appilcable.

l 0897d-23

a ,

.n SUBCAltGORY 204 - ORGANIZATION OR OPERATING PROCEDURES ELEMENT Wi m ER 204,5 LIST OF PtoGaAnNATIC 155uE_]

APPLICARLE ELEMENT DESCRIPTION EMPLOYEE CONCERNS $QN RESTART - NO DATE: 12/05/86 Design Review Process / Independent WI-85-100 -04 T verification Policy and Practice WI-85-100-046 vendor Designs and Calcs 14-85-148-001 Changes to Vendor Designs IN-85-103-003 -

IN-86-209-003 .

IN-85-103 N04 W8P-86-025-X02 ELEMENT WHERE RESPON-(OMCERN NUMBER (5) ISSUES ADDRESSIO SIBLE SENEAAL APP 904CN/NETH000 LOGY f 08 ELEMENT REPORT WI 100-04 6 1. TV4 does not adeguately perform inde- 204.5 DZ All Issues IVA does not adequately (or at . Pendent verificattors of vendor all) injependently verify calculations. 1. Review hierarchy of documents to establish vendor calculations or designs. pertinent TWA licensing commitments relative lhere are no design reviews 2. TVA does not perf orm independent 204.5 OZ lt issues.

of vendor designs. CI has no verification of vendor calculations f urther information. Anonymous adequately. 2. Review Engineering Department procedures which concern via letter. 204.5 OZ estabitsh documents review and check practices

3. TVA does not perform independent and responsibilities.

verification of vendor designs.

3. Review other procedures which establish

4. TVA does not perform independent 204.5 DZ practices and responsibilities, such as, vendor verifications of vender designs design interface and receiving inspection, as adequately, applicable.

5. There are no design reviews of vendor 204.5 DZ 4. Consider adequacy of the procedures in meeting designs. commitment requirements.

5. Review practices for compliance to procedures, including review of results of program audits, as applicable.

6. Coordinate response with interface groups as appitcable.

Wi 100-04 7 1. TV4 does not conduct independent 204.5 DZ IVA does not conduct Indepen- design reviews of its work dent design reviews of its work.

CI has na further Information.

Anonymous concern via letter.

08974-74

/-

stfBCATEGORY 204 - ORGANIZATION OR OPERATING PROCIDURES ELEMENT NupWER 204.5 LIST CF PROGRAMMATIC 1550EJ APPtlCABit LL{#ENT DESCRIPTIDN E MPL OYt E_ CON ([RN$ SQN RESTART - NO DATE: 12/05/86 Design Review Process / Independent Wi-85-100-047 verification Policy anJ Practice Wl-85-IDO 046

! Vendor Designs and Calts IN 14 8 -001 Changes to vendor Designs IN-85-103-003 ,

IN-86-20g-003 IN-85-103-NG4 W8P-86 025-102 E L EME NT WHERE RESPON-(03CE Rg_Num6ER($1 155UES ADDRESSED 518tE_ GENERAL APPRDACH/ METHODOLOGY FDR ELEMENT REPORT IN-85-148-001 1. Design checks are being performed by 204.5 DZ All Issues Design checks (reviews) heing Techniclans (*SE* Ievel personnel) in performed by Technicians (*5t* lieu of Graduate engineers at TVA/ 1. Review hierarchy of documents to establish level personn ') in Iteu of Knouv111e pipe support groups. pertinent TWA licensirg commitments relative graduate engineers at TVA/Enos- to issues.

ville pipe support group. CI 2. Design reviews are being performed 204.5 OZ stated that watts ser Pipe by Technicians (*5E' level 2. Review Engineering Department procedures which Support Group does not have personnel) in lieu of establish documents review and check practices this problem. CI cited name of Graduate engineers at TVA/ and responsibilities.

M-5 in Knouv111e who is Knouv111e pipe support group.

responsible f or this program. 3. Review other procedures which establish Construction Department concern. 3. Design checks /revie=n are being 204.5 DZ practices and responstb111tles. such as, vendor Cl had no additional Informa- performed by Technicians (*SE* design Interface and receiving inspection, as tion. No follow up required. level personnel) ta ileu of applicable graduate engineer ni other IVA design groups. 4. Consider adequacy of the procedures in meeting commitment requirements.

4 l 5. Review practices for compilance to procedures.

W8 P 02 5-302 1. Design analysts processes are not 204.5 BZ including review of results of progree audits.

TWA did not control naclear adequately controlled. as applicable.

plant design analysis or verif-l 1 cation analysis processes in an 2. Design verification analysts 204.5 OZ 6. Coordinate response with interf ace groups as adequate manner. Nuclear Power processes are not adequately applicable.

Department concern. Cl has controlled no further information.

e 089Fd-25

r SU8 CATEGORY 204 - ORGANilATION OR OPERATING PROCEDURES ELEMENT MuMcER 204,6 LIST OF PR06#A854AllC 1550f_1 APPLICA8tE RE ME NT . 0E SCR I Pil0N [NPL0ft G ONCERNS SQN R(START - NO DATE: 12/05/86 ECM process Wi 100-055 Policy and Practice Wi-85-100-041 Implementation Timellness PH-85-038-001 f onnat Change (Downgrade 7) M-05-070-oo3 ElfMENT WHERE RESP 089-CONCERN NL998tE M ISSUES ADDRESSED SIBLE E(NTRAL APPROACH /NETN000t06Y FOR ELEN(NT RLPORT hl 100-055 1. ECN's are prematurely closed out 204.6 Jo issues 1. 2 Untimely closecut of ECN'5. due without proper status of ECN and to a lack of knowledge of status affected design being known. 1. Review the procedures and/cr requirements for of ECNS or designs af f ected. CI the ECN system including Controls for tracking has no further information. 2. It takes too long to close out ECN's 204.6 JO completion status.

Anonymous concern via letter

. 2. Review practices for compliance to procedures.

Wi-85-100-041 g m, nasue cp DM*

Lack of adequate tracking J. tor.f for EN DES cosenttment and j,%w,,.gmoirse M mq,ym  % g, dico s esra; w , mas design changes. Cl has no f urther infonnetton. Anonymous w rsme.s rec. rh cea* ace nea>

g, /.4cac. ,,e asspgers rar4cauwd 204. (. ./ D s rm.

concern via letter

• M fN DES Decr4M M Emawm

' M " ",

• N '* " * '# F#

%ssvG /

Sac w ecear r zot.c.

08Hd -26 i

l

s e

SUBCATEGORY 204 - ORGANIZATION OR OPERATING PROCEDURES ELENENT NUISER 2n4.6 LIST OF PROGRANNATIC ISSUE APPLICABif ELEMENT DESCRIPTION E MPt 0TE L_ CONC E RNS SON RESTART - NO DAIE: 12/05/86 ECN process Wi-85-100-055 Policy and Practice Wi-85-1G0-041 Implementation Timeliness PH 85-038-001 format Change (Downgrade?) XX-85-070-003 "

EL E MENT WHERE RESPON-CCNCERN Num8ERf51 155UES ADDRESSED .518tE . GENERAL APPROACH /NETM000t0GY FDR ELEMENT REPDRT PH-85-039-001 1. Procedure OEP-11 revision eliminated 204.6 JD 1. Examine Procedure DEP-11 to determine how I Of t tce of Engineering's front cover page which provided space applicability to other documents is controlled.

Procedure OEP-11

• Changes to for identification of other documents Plant" was revised. The and plant areas affected by ECN. 2. Evaluate DEP-11 for adequacy in addressing all i revision eliminated the front Elleination of this

• check-Ilst" which possible documents that may be lupacted by page of the ECN form which required consideration and positive changes.

Identified the documents /other action by the ECN preparer and areas of plant the ECN could reviewer may result in an affected 3. Consider the adequacy of the current NEP's in affect. The old ECN front document or plant area being meeting this concern.

page had. as an example . FSAR- overlooked.

affected Yes No Appendla

• R* - affected. Yes No which required some positive action by requiring the yes or no block to be checked. The new revisten to OEP-11 has an attachment two (2) which is only a list of possible areas which 1

might be affected and requires no check of f. Therefore no one is using it. CI has no addt-tional information. Anonymous c once rn.

31-85-070-003 1. Majority of DCR's are not documented 204.6 JD IssusLJ Sequoyah: Work plans contain p roperly.

Inaccurate data. Majority of 1. Review procedures for generating work plans the DCR's taken care but not 2, SW,s ao var Ma scr "es A.,ny* 20(,.l JL for adequacy.

documented right and drawings wirious.

do not reflect the as-built 2. Review practices for compliance wit procedures.

c ondi t ions . Details withheld to maintain confidentiality. 3. Evaluate magnitude of problem by determining if NuC Power concern. C/l has no these issues show up in a QA audits, etc.

f urther Information.

Isson 2 Sne etewT /%mer toL./

069Fd-27

SUBCATEGORV 204 - ORGANilATION OR OPERATING PROCEDURES ELEnEmi NuNsER 204.7 tlsi 0F PROGRANmAH C E UJ5 APPLICABLE

[tfMENT DESCRIPTION [MPt0 VEL _[0NCERNS SQN RESTART - NO DATE: 12/05/86 Vendor Documents IN-85-505-001 tegiblitty IN-86-073-001 Dissemination System EtlpENT MHERE RESPON-(ONC(RN NUMBER (S) ISSUES ADDRESSED SIBLE EENERAL APPROACH /METHOOOLOGY FDR ELEMENT REPORT IN-85-505-001 1. Vendor drawings received by the 204.7 JL 1. Review engineering procedures for requirements Poor quality of vendor drawings plant f rom (NDES f or as-constructed of vendors to provide legible reproducible that W8MP receives from ENDES drawings are of poor quality, doc uments, f or as-constructed purpose.

2. Review Engineering document control procedures which cover quality of reproduced vendor drawings transmitted to site.

3. Review actual practices for compilance to procedures.

IN-86-073-001 1. L'pdates of nuclear renuals are sent 204.1 JL 1. Review Engineering Department procedures which Updates to vendor manuals are to Knouville or Chattanooga establish vendor manual review, checking and not being supplied to the field Engineering, but they are not distribution requirements, in a timely penner. For example, received at the plant in a forboro revises their schematics reasonable time thereafter. 2. Review practices far compliance with procedures, and transmits the changes to Knouv111e or Chattanooga Engl-neering. but the revisions are not received at WSNP. CI has no more information. NUC Power concern. Unit 1.

0897d-29

. ~ , - -.

SUBCATEGORY 204 - ORGANIZATION OR OPERATING FROCEDURES ELEIElli IUBER M LI$T OF PROGAAfstATIC I55UE.5 APPLICABLE ELENENT DESCRIPTION [NPLOYEE CONEJERN1 $0N RESTART - NO DATE: 12/05/86 I

Consnunication and Interf ace Control WI-85-100-052 ELENENT WHERE RESPON- .-

(ONCERN_N_UNBER(5) ISSUES ADORE 55ED SitLE GENERAL APPROACNMIETNODOLOGY FOR ELENENT REPORT 4 Wi-85-100-052 1. There is a lack of ef fective com- 204.8 DP 1. Review Engineering Department procedures which 1 tack of effective comununication munication and interf ace control estabitsh interf ace and/or connunciation and interf ace control among among organlaations within EN0ES requirseent within ENDES.

organitations within INSE5 - (i.e.. Branches. Projects.

Branches. Projects. Procurement. Procurement,etc.) 2. Constder adequacy of the procedures in meeting etc. CI has no further infonne- requirements.

tion. Anonymous concern via letter 3. Review practices for compilence to procedures.

k i

a 1

4 08176-21

[

l _ .

e SUBCATEGoaf 204 - ORGANilATION 08 OPERAllMG PROCEDURis ELLIENT IRpWER 298.9 LIST OF PROGRAMMATIC 155UL}

APPtlCA8tE EtEnENT O(SCalPflow (NPLOY(E CONCIRNJ }{It RESTART - NO DATE: 12/05/06 Use of Beverse Prints IN-85-397-001 ELEMENT WHE RE RESPoll-(0etERN Munstaf51 ISSUES ADDRESSEO Slett GENEaAt APPSOACNMilIO90 LOGY FOR ELEnENT REPORT 14-85-397-001 1. Unit 1 prints marked

• opposite hand

• 204.9 JL 1. Examine current practices and procedures to Unit 1 prints are being used are being used for Unit 2 which makes determine if Unit 1 prints are still being f or Unit 2 and are marked work more confusing for Engineers used for Unit 2.

opposite hand which makes work and construction workers, more conf estag f or workers 2. Review Oc inspection reports for and engineers. occurrences of errors resulting from opposite hand drawings.

l l 3. Review engineering documents for revisions j attributable to confusion f rom use of opposite hand drawings.

I l

I 08sid-30

$UgCATEGOef 204 - CRGANi2ATION 04 OPERATING PROCEDURES ELDIENT IMWER 204.11 List OF P90GRAfst4 Tic ISSUES APPLICA8tE EttaENT DESCRIPTIDs Emet 0 TEE CowCLBe} SON RESTART - NO DATE: 12/05/96 Scope of Engineering Regoired for I-85-128-NPS modtistations not Identifled ELEMEmi WHERE SE5Pou-(c=CErg numsEBf51 155UES AsseE55ES . 518tt . GEntaAL APP 904Cil/nETM000 LOGY FOR ELINENT REPORT I 129-hP5 1. Basic calc's are not prepared. 205.1 JS Issues e and g An individual from Of 4 eerste uses espresstag his concern 2. Basic calc's are not documented. 205.1 JS 1. Determine if precedures exist iAlch define /

that the control and esality control /tdentify Engineering Department of CE's design etfort is 3. Design documents are not supported by 205.1 Je role in plant modifications.

Snadequate. The CI sent calc's several roughly terttten 2. Consider the adequacy of these procedures.

pages detalitag and sun- 4. There are no procedores to control 205.2 JS martzing his evaluation and and selatain calc's current conc 1ssion of three major Othet- Issues areas: 5. Basic design input is not available 208.6 SZ See element reports where addressed.

(1) Design Calculations, E. Besign requirements are not seedily 201.6 92 available (2) WCR's, and

1. Basis of deterst*.ation of design 201.6 SZ (3) Renagement Policles requireme.ts is not readily avallable m3ft: The issues stated here S. Scope of engineering regelred for 204.11 JS escre developed from a review modifications is not required.

by Bechtel personnel of the espurgated laterview file for g. Its attenet is made to identify design 204.11 J8 this employee concern. activities for modifications e

08114-32

[ .

.] .

l l

TENNESSEE VALLEY AUTHORITY PAGE - 50 l REFERENCE - ECPS120J-ECPS121C RUN TIME - 12:57:19 FREOUEriCY - REQUEST OFFICE OF NUCLEAR POWER l

CNP - 1555 - RMt EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGCRY: EU DES PROCESS & OUTPUT SUBCATEGORY: 20401 ORGANIZATIONAL STRUCTURE S GENERIC KEYWORD A H APPL GTC/NSRS P KEYHORD B l KEYWORD C CONCERN SUB R PLT BB$H INVESTIGATION 5 CONCERN "

l DESCRIPTION KEYHORD D NUMBER CAT CAT D LOC FL95 REPORT R EN 20401 N H5N YYYY SR TVA'S MANAGERIAL STRUCTURE IS UNNIEL ORGANIZATION IN 029-002 DESIGN PROCESS T50054 K-FORM DING AND CUMBERSOME. THIS SITUATION SOMETIMES LEADS TO CONFUSION IN THE GENERAL l

DESIGN PROCESS. EXAMPLE EXCESSIVE GENERAL AMOUNT OF PAPERWORKs T00 MANY PEOPL E IN THE REVIEH CYCLE FOR ECN'S, ECR

'S, MEMOS; TOO MANY EP PROCEDURES.

EP'S NEED TO BE STREAMLINED. "THE P APERNORK PASSES THROUGH TOO MANY HAN D5" CI STATED THAT THIS CONCERN IS G ENERAL AND COULD NOT PROVIDE ANY SPE CIFICS.

I CONCERNS FOR CATEGORY EN SUBCATEGORY 2J401 1

m

rs '

• 7

-l

!st TENNESSEE VALLEY AUTHORITY PAGE -

51 REFERENCC - ECPS120J-ECPS121C RUN TIME - 12:S7:19 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 OMP - ISSS - RWM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORT: 20402 SYSTEM DESIGN RESPONSIBILITY I S GENERIC ,

KEYWORD A H APPL QTC/NSRS P KEYHORD 5 SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C ^

CONCERN KEYHORD D NUMBER CAT CAT D LOC F L.Q B REPORT R DESCRIPTION 3

20402 N HBN YYYY NO NO SPECIFIC OVERALL SYSTEM DESIGN RE ORGANIZATION ZN 209-010 EN SPONSIBILITY IS CURRENTLY ASSIGNED T SCHEDULE T50218 REPORT O A SPECIFIC PERSON. THERE IS NOT S SYSTEMS I DMEONE MONITORING OVERALL DESIGN. T GENERAL HE RESPONSIBILITY IS FRAGMENTED. SO MEONE HANDLES THE CONTRACT, ANOTHER HANDLES THE MECHNICAL PORTIONS, ANOT I HER CONTROLS INSTRUMENTATION, ANOTHE R THE ELECTRICAL, ETC. THEY ALL TOGE THER HANDLE THE SYSTEM. THERE IS NO ONE PERSON YOU CAN CALL AT KNOXVILL I E AND DEPEND ON FOR TECHNICAL RESPON SIBILITY. YOU MAY HAVE A PERSON'S N AME, BUT AS SOON AS THAT PERSON

) 1 CONCERNS FOR CATEGORY EN SU8CATE00RY 20402 i

)

e

~.

TtH?1ESSEE VALLEY AUTHORITY PAGE -

52 REFERENCE - ECPS120J-ECPS121C RUN TIME - 12:57:19 FREQUENCY - REQUEST OFFICC Or NUCLEAR POWER I EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 ONP - 1555 - RWM LIST OF EMPLOYEE CONCERN INFORMATION CATEGCRY: EN . DES PROCESS & OUTPUT SUBCATEGORY: 20403 DESIGN RESPONSIBILITY GENERIC KEYHORD A l S APPL QTC/NSRS P KEYHORD 5 H KEYHORD C CCHCERN SUB R PLT BBSH INVESTIGATION S CONCERN ~'

DESCRIPTION KEYHORD D NUMBER CAT CAT D LOC FLQB REPORT R YYYY SR TVA LEAVES T00 MANY TECHNICAL DECISI NONCONFORMANCE HK 091-015 EN 20403 S HBN ONS UP TO THE CRAFTS' DISCRETIDH, E. DESIGN RELATED T50197 EN 22007 REPORT PIPING G. CRAFT DESIGN THE HANGER AND THEN ENGINEERING DOES THE AS-CONSTRUCTED GENERAL DRAMING. CI HAS NO FURTHER INFORMAT ION. CONSTRUCTION DEPT. CONCERN.

') 1 CONCERNS FOR CATEGORY EN SUBCATEGORY 20403 1

i.

)

)

J

.)

p- .

~

Il TENNESSEE VALLEY AUTHORITY PAGE -

53 REFEREFCE - ECPS120J-ECPS121C RUti TIME - 12:57:19 FREQUEt4CY - REQUEST OFFICE OF flUCLEAR P0HER DNP - ISSS - RHM EMPLOYEE CONCERf1 PROGRAM SYSTEM (ECPS) rut 1 DATE - 12/02/86 LIST OF EMPLOYEE C0!1CERN INFORMATI0t3 CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20404 DESIGil DOCUMEllT COMPLETENESS - IllADEQUACY S GENERIC KEYHORD A H APPL QTC/ tlSRS P KEYHORD B SUB R PLT BBSH INV ESTIGATIOll S CONCER?1 KEYI10RD C 1 C0flCERN KEYHORD D I;'JMB ER CAT CAT D LOC FLQB REPORT R DESCRIPTION 20404 S HBil YYYY SR DRAHINGS DO NOT ALHAYS SH0H COMPLETE DOCUMEllT CollTROL EX 061-004 Ett DETAILS, I.E. SPECIFIC HELD SIZE. DRAHINGS T50183 EN 22203 REPORT HELDIrlG CONSTRUCTION CONCERN. CI HAS NO ADD ITIONAL DETAIL. IIELDS EN 20103 S HBN YYYY SR TVA DESIGils HERE NOT DEVELOPED HELL DESIGN REVIEW IN 886-001 DESIGli CHANGES T50157 EM 20404 REPORT Ett0 UGH TO BE CONSTRUCTABLE: 1) DESIG EN 22003 H CHANGES ARE STILL VEHIt1G IllSTITUTE ENGIllEERING D IN AREAS HHERE THERE SHOULD HAVE B HANGERS EEli MINIMAL CHANGES FSPECIALLY IN AR EA 0F CONFLICTS BETHEE!I TVA AllD vet 3D OR DHGS. 2) ENGINEERING DESIGli CRIT ERIA IS OFTEN NON-EXISTENT, PARTICUL ARLY FOR SEISMIC HANGER DESIGN. MAN Y DESIGN CRITERIA OR ACCEPTANCE CRIT

' ERIA ARE STILL BEIllG CHANGED. THIS IS GENERIC Cat 1CERN. AtlY FURTHER It1F ORMATI0la HOULD DIVULGE C0tIFIDENTIALI TY. CONSTRUCTION DEPT, C0!!CERii.

EN 20404 !! HBil YYYY Iti-86-133-004 NO MAtlAGEMENT HAS PROBLEMS HITH CREATIll DESIGN PROCESS Iti 133-004 DRAllINGS T53128 REPORT G HORKABLE DRAHINGS HITHOUT HAVING H ANY PROBLEMS IN INSTALLATION. C0tiST ENGIllEERIllG I RUCTI0ft CONCERN. CI HAS NO ADDITI0tl GEt4ERAL AL I!3FORMATI0tl OR DETAILS.

HI 100-017 Eri 20404 N H5N YYYY SR CollSTRUCTI0tl, TEST AtID INSTALLATI0t3 SPECIFICATI0 tis N0!!CO?lFORMAtlC E l ! T50212 K-FORT 1 SPECIFICATIONS (CALLED GErlERAL Cat 1ST RUCTIOtt SPECS, HITH A G ___HUMBER) A C0ftSTRUCTI0ti RE OFTEN IllC0f1PLETE A!!D INADEQUATE. GEtiERAL

' CI HAS 140 FURTHER IIIFORt1ATION. At10

' ItYt100S CONCERN VIA LETTER.

Ett 20104 5 HBN YYYY SR DESIGil/ INSTALLATION DRAHIt1GS D0 fl0T DRAHIl1GS

. NI I00-038 130!!C0f1FCRMAtlCE T50213 Ett 20106 REPORT ALHAYS REPRESENT OR IFICLUDE DESIGN R Lt3 20404 EQUIREMENTS. DESIGN GUIDES /STAtlDARD EtiGIllEERIllG S ARE UTILIZED ONLY HHEN DESIGtIERS 18 GEtlERAL

"* AFIT TO SUE THEM. DESIGil GUIDES /STAN DARDS ARE IrlADEQUATE IN MAIIY AREAS, AtlD THERE ARE MISUSES, SUCH AS APPLI CABLE FARTS ARE NOT REFERENCED OR EX CERPTED AS REQUIREMEf4TS. CI HAS t10 FURTHER It3 FORT 1ATIO!I. At10t4YMOUS CONC ERii VIA LETTER.

"; 5 C0r3 CERT 33 FOR CATEGORY EN SUBCATIGORY 20404 i

f-n.

til REFERENCE - ECPSI20J-ECPSI2IC TENNESSEE VALLEY AUTNORITY PAGE -

54' FREQUENCY - REGUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:57:19 CNP - ISSS - REM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGCRY: EN DES PROCESS & OUTPUT SUBCATEGORYs 20405 DESIGN REVIEN PROCESS / INDEPENDENT VERIFICATION 5 GENERIC KEYHORD A H APPL QTC/NSRS P KEYNORD B CONCERN SUB R PLT DRSH INVESTIGATION $ CONCERN KEYHORD C tu;M5ER CAT CAT D LOC FL45 REPORT R DESCRIPTION KEYHORD D

)

IK 105-N04 EN 20405 N HEN YYYY SR NRC IDENTIFIED THE FOLLOHING CONCERN REPORT FROM REVIEH OF GTC FILE. "CALCULAT IONS ARE NOT GENERALLY REVIENED BY T ECHNICAL SUPERVISION." (NOTE: THIS IS SAME AS IN-85-105-005)

IB 105-005 EN 20405 5 HBN YYYY NO FOR PIPE / HANGER CALCULATIONS, NO TEC DESIGN PROCESS T5C265 EN 22C12 REPOR1 HNICAL REVIEH IS PERFORMED AFTER CHE SPECIFICATIONS CKERS HAVE REVIEHED TNEM. NO FURTHE ENGINEERING R INFORMATION IN FILE. CONSTRUCTION HANGERS DEPARTMENT CONCERN.

IN -8 5-148-001 EN 20405 N HBN YYYY SS DESIGN CHECKS (REVIENS)SEING PERFORM

• DESIGN PROCESS T50115 K-FDRff ED BY TECHNICIANS ("SE" LEVEL PERSONN EXAMINATION EL) IN LIEU OF GRADUATE ENGINEERS AT ENGINEERING TVA/KN0XVILLE PIPE SUPPORT GROUP. INSPECTORS CI STATED THAT HATTS BAR PIPE SUPPOR T GROUP DOES NOT NAVE THIS PROBLEM.

CI CITED MAME OF M-5 IN KN0XVILLE H HG IS RESPONSIDLE FOR TNIS PROGRAM.

CONSTRUCTION DEPARTMENT CONCERN. C I NAD NO ADDITIONAL INFORMATION. NO FOLLOM UP REGUIRED.

IO 209-005 EN 20405 N H5N YYYY SR DESIGN DRAMINGS, TECHNICAL SPECIFICA RECORDS T5G218 K-FORM TIONS, DESIGN CRITERIA DOCUMENTS, PR EXAHINATION E-OP TESTS PEG., ETC. ARE NOT RECEIV QUALITY ING A SECOND INDEPENDENT REVIEH AS R REPORTS EQUIRED, BUT ARE REVIEHED PRIMARILY FOR COSMETIC DETAILS, (ENGLISH, SPEL LING, ETC.). THE TECHNICAL REVIENS ARE PERFORMED AT ENOxWILLE AND THE P ERSONNEL PERFORMING THE REVIENS ARE EITHER NOT EXPERIENCED ENOUGH, OR SC NEDULE PRESSURE PREVENTS THEM FROM P ERFORMING AN ADEOUATE TECNNICAL REVI EH. THIS NAS DEEN GOING ON SINCE LA

~ - TE 70's. THE POTENTIAL EXISTS F H3P-36-025-X02 EN 2048S N HBN NNYY SS TVA DID NOT CONTROL NUCLEAR PLANT DE T53278 REPORT SIGN ANALYSIS OR VERIFICATION ANALYS IS PROCESSES IN AN ADEPUATE MANNER.

NUCLEAR POWER DEPARTMENT CONCERN.

CI NAS NO FURINER INFORMATION.

i .

f a tt i

TENNESSEE VALLEY AUTHORITY PAGE -

55 I REFERENCE - ECPS12OJ-ECPS121C Ruta TIttE - 12:57:19 FREGD;CY - EE;UEST OFFICE OF ttUCLEAR PDHER EMPLOYEE C0!!CERf4 PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 1 CH? - ISSS - RWT i

LIST OF Ef1PLOYEE CONCERN INFORMATION 1 CATEGORY: EN DES FROCESS & CUTPUT SUSCATEGORYs 20405 DESIGN REVIEN PROCESS / INDEPENDENT VERIFICATION GENERIC KEYWORD A

! S KEYWORD B

' H APPL STC/NSRS P CDNCERN KEYHORD C l CONCERM SUB R PLT BB$H INVESTIGATION S KEYHORD D

~

FCit2ER CAT CAT D LOC FL03 REPOK! R DESCRIPTION

{

YYYY SR TVA DOES NOT ADE90ATELY (OR AT ALL) SUPPLIER 1

HI -8 5-103-046 EN 23405 N MSN AUDIT T50215 REPORT INDEPENDENTLY WERIFY VENDOR CALCULAT IGNS OR DESIGNS. THERE ARE NO DESIG VENDOR I

N REVIENS OF VENDOR DESIGNS. CI HAS GENERAL 1

NO FURTHER INFORMATION. ANONYMOUS

]' CONCERN VIA LETTER.

YYYY SR TVA DOES NOT CONDUCT INDEPENDENT DES DESIGN PROCESS HK Ic3-047 EN 20405 N M5N AUDIT 4

T532IS REPORT IGN REVIENS OF ITS WORK. CI HAS NO FURTHER INFORMATION. ANONYMOUS CONC ENGINEERING l CottST MANAGEMLNT ERN VIA LETTER.

l 7 CONCERNS FOR CATEGORY EN SU5 CATEGORY 20405 1

4 k

)

4 j J

+ ,

i

)

2 i ~

2 )

) >

7 I l >

i

~

s ,

41I TENNESSEE VALLEY AUTHORITY PAGE -

56 REFEPENCE - ECPS120J-ECPSI21C RUN TIME - 12:57:19 FRECUENCY - REQUES) 0FFICE OF NUCLEAR POWER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/s6 CnP - ISSS - R1:M LIST OF EMPLOYEE CONCERN INFORMATION CATEGCRY: EN DES PROCESS & GUTPUT SUBCATEGORY: 20406 ECH PROCESS S GENERIC KEYHORD A H APPL QTC/NSRS P KEYNORD B BB5H INVESTIGATION S CONCERN KEYHORD C CONCERN SUB R PLT KEYHORD D NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION YYYY I-85-546-HBN SR OFFICE OF ENGINEERING'S PROCEDURE DE PROCEDURES PH 038-001 EN 20406 N H5N DOCUMENT STATUS T50143 K-FORM P-11 " CHANGES TO PLANT

• HAS REVISED.

THE REVISION ELEMINATED THE FRONT ENGINEERING PAGE OF THE ECN FORM HHICH INDENTIFI GENERAL ED THE DOCUMENTS /0THER AREAS OF PLAN T THE ECN COULD AFFECT. THE OLD ECN FRON1 PAGE HAD, AS AN EXAMPLE - FSA R-AFFECTED YES NO APPENDIX "R" -

AFFECTED. YES NO HHICH REQUIRED SOME POSITIVE ACTION BY REQUIRING TH E YES OR NO BLOCK TO BE CHECKED. TH E NEH REVISION TO DEP-11 HAS AN ATTA CHMENT TH0 (2) HHICH IS ONLY A LIST OF POSSIBLE

' 20105 S HBN YYYY SR LACK OF ADEQUATE TRACKING FOR ENDES DESIGN CHANGES HI 100-041 EN AUDIT T50213 EN 20406 REPORT COMMITMENTS AND DESIGN CHANGES. CI HAS NO FURTHER INFORMATION. ANONYM 0 ENGINEERING US CONCERN VIA LETTER. GENERAL 3

MI 100-055 EN 20406 N HBN YYYY SR UNTIMELY CLOSEOUT OF ECNS, DUE 70 A DESIGN RELATED REPORT LACK OF KNOHLEDGE OF STATUS OF ECNS NONCONFCRMANCE T50218 ENGINEERING OR DESIGHS AFFECTED. CI HAS NO FURT l HER INFORMATION. ANONYMOUS CONCERN GENERAL VIA LETTER.

20406 S SQN YYYY I-85-637-SQN SS SEQUOYAH HORK PLANS CONTAIN INACCU HORK PLAN / PACKAGE XX 070-005 EN DRAHINGS

> T50180 EN 20601 K-FORM RATE DATA. MAJORITY OF THE DCR'S TA KEN CARE BUT NOT DOCUHENTED RIGHT AN OPERATIONS OP 30704 GENERAL D DRAHINGS DO NOT REFLECT THE AS-BUI LT CONDITIONS. DETAILS HITMHELD TO

) MAINTAIN CONFIDENTIALITY. HUC P0HER CONCERN. C/I HAS NO FURTHER INFORM ATION.

I 4 CCNCERNS FOR CATEGORY EN SUBCATEGORY 20406 e

TENNESSEE VALLEY AUTHORITY PAGE- -- 57 REFERENCE - ECPS120J-ECPS121C RUN TIME - 12:S7:19 FREGUENCY - REQUEST OFFICE OF NUCLEAR POWER OEP - ISSS - RNM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86' LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20407 VENDOR DOCUMENTS S -GENERIC KEYHORD A H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BB5H INVESTIGATION S CONCERN ' KEYHORD C -

CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D Nut 1BER

)

20407 N HBN YYYY IN-85-505-001 NO POOR QUALITY OF VENDOR DRAHINGS THAT DRAHINGS IN 505-001 EN HBNP RECEIVES FROM ENDES FOR AS-CON SUPPLIER 750032 REPORT ENGINEERING 3' STRUCTED PURPOSE.

GENERAL 20407 N HBN YYYY SR ' UPDATES TO VENDOR MANUALS ARE NOT BE SUPPLIER IN 073-001 EN ING SUPPLIED TO THE FIELD IN A TIMEL RECORDS T50194 REPORT

) Y MANNER. FOR EXAMPLE, FOXBORO REVI INSTRUMENTATION SES THEIR SCHEMATICS AND TRANSMIT TH INSTRUMENT / MECH E CHANGES TO KNOXVILLE OR CHATTAN00G A ENGINEERING, BUT THE REVISIONS ARE

) NOT RECEIVED AT HBNP. CI HAS NO MO RE INFORMATION. NUC. PDHER CONCERN.

UNIT 1.

2 CONCERNS FOR CATEGORY EN SUBCATEGORY 20407

)

M 1

O

)

as PAGE -

58 REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIME - 12:57:19

- REQUEST OFFICE OF HL* CLEAR PDHER

) FREQUENCY EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)- RUN DATE - 12/02/86 ONP - ISSS - RHM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20408 COMMUNICATION AND INTERFACE CONTROL

) S GENERIC APPL- QTC/NSRS P KEYHORD A KEYHORD B H KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN "

DESCRIPTION KEYHORD D NUMBER CAT CAT D LOC FLQB REPORT R

-) SR LACK OF EFFECTIVE COMMUNICATION AND COMMUNICATION HI 100-052 EN 20408 S HBN YYYY NONCONFORMANCE T50213 MP 71000 REPORT INTERFACE CONTROL AMONG ORGANIZATION S HITHIN ENDES - BRANCHES, PROJECTS, GENERAL PROCUREMENT, ETC. CI HAS NO FURTHE CONST MANAGEMENT R INFORMATION. ANOKYMOUS CONCERN VI A LETTER.

I 1 CONCERNS FOR CATEGORY EN SUBCATEGORY 20408 i

b

)

7

)

3

-m e

' ~

[ 4

~'1: .

?~'

,111

- ECPSI20J-ECPS121C TEMNESSEE VALLEY AUTNORITY PAGE -

145 REFERENCE FREQUENCY - REQUEST OFFICE OF NUCLEAR PDHER RUN TIME - 12:53:36 ONP - 1553 - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCEPN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20409 USE OF REVERSE PRINTS .

') S GENERIC KEYWORD A H APPL GTC/NSRS P KEYWORD B l SUB R PLT BBSH INVESTIGATION S CONCERN KEYWORD C &

6 CONCERN KEYNORD D

~I NUMBER CAT CAT D LDC FL03 REPORT R DESCRIPTION IN 397-001 CD 11200 S "ABN YYYY NO UNIT I PRINTS ARE BEING USED FOR UNI DRAHINGS 150017 EN 20407 REPORT T 2 AND ARE MARKED OPPOSITE MAND HHI DOCUMENT CCNTROL

)

! CH MAKES WORK MORE CONFUSING FOR HOR ENGINEERING KERS AND ENGINEERS. GENERAL l . I CONCERNS FOR CATEGORY EN SUBCATEGORY 20409 l

l3 l b 1

1 l

l

==

i l

1 M

~

1 1 '

l

7 4..

l J O .

ill PAGE -

59 REFERENCE - ECPSI20J-ECPSI21C TENNESSEE VALLEY AUTHORITY' RUN TIME - 12:57:19

- REQUEST OFFICE OF NUCLEAR PONER F:.E7JENCY EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/B6 Ch? - 1555 - luct LIST OF EMPLOYEE CONCERN INFORMATION CATEGCRY: DI CES PROCESS 8 CUTPUT SUBCATEGORY: 2041I SCOPE OF ENGINEERING RESS FOR MOSS NOT IDENTIFIED KEYHORD A

$ GENERIC KEYNORD B H APPL STC/MSRS P CONCERN KEYNORD C CD*:CERN SUB R PLT BB$H INVESTIGATION S KEYNORD D NUMBER CAT CAT D LCC FLGB REPORT R BESCRIPTION

)

I-85-128-NPS EN 20186 S BFN YYYY $$ AN INDIVIDUAL FROM SFN NROTE NSRS EX EN 20411 REPORT PRESSING NIS CONCERN THAT THE CONTRO EN 20501 L AND SUALITY OF OE'S DESIGN EFFORT 3 EN 20582 IS INABEGUATE. THE CI SENT SEVERAL EN 20681 ROUGMLY NRITTEN PAGES DETAILING AND QA 48383 SWWEARIZING NIS EVALUATION AND CONCL USION OF THREE MRJOR AREAS: (I) D I CCNCERNS FCR CATEGCRY EN SUSCATEGORY 20411 l

1 I

l l

)

l l

l b

1

)

)

i l )

O l