ML20212G859
| ML20212G859 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/13/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20212G828 | List: |
| References | |
| 201.3-(B), 201.3-(B)-R01, 201.3-(B)-R1, NUDOCS 8701210209 | |
| Download: ML20212G859 (24) | |
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TVA EMPLOYEE CONCERNS REP 0'tT NUMBER: 201.3 (B)
SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 1
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TITLE: INCORPORATION OF REQUIREMENTS AND COMMITMENTS IN DESIGN Design Criteria PAGE 1 0F 24 REASON FOR REVISION:
- 1. Revised to incorporate SRP/TAS coments, add chronology, and add Section 10 on corrective action.
PREPARATION PREPARED BY:
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 i
PAGE 2 0F 24 l
- 1. CHARACTERIZATION OF ISSUES:
Concerns: Issues:
WI-85-100-019 a. Electrical and other engineering design
" Electrical Standards and criteria are not. always complete, are Guides are treated as guides, vague, and are inadequate.
and are not incorporated in design criteria requirements. b. Many design crite_ria are changed late Electrical design criteria, in the project.
where it exists, is not complete, is vague, and in c. Engineering design criteria are often general is inadequate. CI nonexistent.
has no further information.
Anonymous concern via letter." d. Many design criteria were set up, then inactivated, and cannot be IN-85-886-001 retrieved for use as a basis for "TVA designs were not developed modification of the original design.
well enough to be constructible:
- 1) design changes are still NOTE: Issues "a" and "c" are also being instituted in areas addressed in Sequoyah Element Report where there should have been 213.3.
minimal changes especially in area of conflicts between TVA and vendor dwgs. 2) engineering NOTE: The following issues from these design criteria is often non- concerns are addressed in other reports, existent, particularly for seismic hanger design. Many design criteria or acceptance Engineering designs are not construct-criteria are still being ible. (This issue is addressed in c hanged. This is generic Sequoyah Element Rcport 204.4.)
concern. Any further informa-tion would divulge confidenti- Too many design changes made late in ality. Constructicn Dept. the project. (This issue is addressed concern." in Sequoyah Element Report 204.4.)
WI-85-100-044 Many acceptance criteria were changed "TVA has set up design late in the project. (This issue is criteria for WBNP and, af ter addressed in Sequoyah Element the fact, has inactivated a Report 204.4.)
large percentage of t he criteria.
CI has no further inf onnation. Too many conflicts between TVA Anonymous concern via letter." drawings and vendor drawings exist late in the project. (This issue is addressed in Sequoyah Element Report 204.4.)
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03770 - Pecember 23, 1986
t TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 i
PAGE 3 0F 24 1ssues:
Electrical and other engineering standards and guides are treated as guides only. (This issue is addressed
- in Sequoyah Element Report 201.4.)
Electrical and other engineering standards and guides are not incorporated in design criteria. (This issue is addressed in Sequoyah Element Report 201.4.)
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X N0 o Identified by TVA SQN GCTF Date June 1, 1936 TVA SQN - Generic Concern lask Force Report GCC-16-62, " Design Drawings Not Constructible; Design Criteria Nonexistent," (06/01/86) o Identified by Gilbert /Commorwealth, Inc.
Date October 1985 Assessment of the Design Control Program for the Sequoyah Nuclear Plant, G/C Report No. 2600(10/85) o Identified by Gilbert / Commonwealth, Inc.
Date March 3,1986 Final Report No. 2614, " Technical Resiew of SQN Modifications" (03/03/86)
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
None t
0377D - December 23, 1986
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (8) s SPECIAL PROGRAM REVISION NUMBER: 1 1
PAGE 4 0F 24 4 INTERVIEW FILES REVIEWED:
- a. Expurgated file for WI-85-100, was examined and no additional unreviewed information was found.
- b. Expurgated file for IN-85-886, was examined and some additional information relating to isolation valve closing time and seismic analysis for locally mounting of instruments was found.
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
- 6. WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
- 8. EVALUATION PROCESS:
- a. Reviewed current and past procedures and practices for development and use of design criteria:
o Determined if they are sufficient to develop complete, clear, and adequate design criteria o Reviewed sampling of design criteria for completeness, adequacy, and degree of vagueness, including electrical and seismic hanger criteria documents
- b. Determined if these issues have been identified in any other prior review (i.e., QA Audit, INP0 findings, etc.).
- c. Reviewed Design Criteria Index to assess scope of concern by determining which criteria have been inactivated.
03770 - December 23, 1986
TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 24
- d. Determined why design criteria were inactivated, and if reason-was valid (i.e., superseded by another document).
- e. Reviewed procedure for inactivating criteria and evaluated retrievability and need for reactivation or replacement.
- f. Reviewed available transcripts of NRC investigative.
interviews to gain additional information regarding the concerns.
- g. Reviewed Design Baseline and Verification Program (DBVP) for Sequoyah Plant to see if program will adequately address the issues.
- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronolooy:
01/70- SQN-QA Manual, through R12, Constitutes Engineering 12/73: Design Prccedures in effect 09/73- EN DES Engineering Procedures (EPs), (Red Book) in 06/85: effect. Superseded SQN-QA Manual 1976: TVA commits to ANSI N45.2.ll-1974 in SQN FSAR 09/27/80: Operating License (0L) issued for SQN Unit 1 1
09/15/81: OL issued for SQN Unit 2 l
04/09/85: TVA Topical Report TVA-TR75-1A, Rev. 8, issued J
06/85- Office of Engineering Procedures (OEPs) in effect.
06/86 Superseded EN DES-EPs 08/85: SQN voluntarily shut down by TVA because of questions 4
about the environmental quality of electrical equipment.
09/85 to Sequoyah Project Manual (SQEPs) in effect Present:
09/17/85: NRC requests TVA submit plans for correcting SQN problems
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i 03770 - December 23, 1966
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SPECIAL PROGRAM REVISION NUMBER: 1
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PAGE 6 0F 24 10/07/85: NSRS receives concern IN-85-886-001 11/01/85: TVA presents Sequoyah Nuclear Performance Plan and their Corporate Nuclear Performance Plan to NRC 11/17/85: NRC receiyu employee letter regarding concerns about TVA's nuclear program 12/07/85: TVA receives concerns WI-85-100-019 and WI-85-100-044 02/18/86: NRC letter forwards copy of concerned Employee's letter to TVA for review and response 02/21/86: NRC investigative inter'iew v with concerned individual I
03/10/86: TVA Corporate Nuclear Performance Plan (CNPP) Volume I, R0, submitted to NRC 04/08/86: Design Basis Program for TVA Plants accepted and adopted (formaldesi gn basis document to be captured and maintained) 05/01/86: Formal Design Baseline and Verification Program for Sequoyah, R0, issued 06/23/86: NRC forwards transcript of interview with concerned individual to TVA 07/86 to Nuclear Engineering Procedures (NEPs) in effect.
present: Superseded OEPs 07/17/86: Sequoyah Nuclear Performance Plan, Volume II, R1, submitted to NRC with CNPP, Volume I, R1 08/13/86: TVA CNPP, Volume I, R2, issued
Background:
Before examining issues "a" through "d" listed in Section 1, this section establishes which engineering procedures were applicable at various times, and defines basic terms.
Applicable Procedures: The following documents provide procedures for the control of engineering for SQN from project inception to the present:
- o SQN-Quality Assurance Manual, through R12 03770 - December 23, 1986
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 7 0F 24 '
o EN DES Engineering Procedures (Red Book) o Office of Engineering Procedures (0EPs) o Nuclear Engineering Procedures (NEPs) o Sequoyah Project Manual (SQEPs) ,
Definition of Basic Terms:
Design: From ANSI N45.2.11 (App. A, 5.b), the definition of Design is:
" Technical and management processes which commence with identification of design input and which lead to, and include, the issuance of design output documents."
Desian Criteria: From procedure EN DES-EP 3.01 ( App. A, 5.m):
" Design Criteria are Engineering requirements which provide the basis for conceptual and detailed design. Design criteria are the basis for making design decisions, establishing design inputs, accomplishing design verification measures, and evaluating design changes. Design criteria include, interpret and amplify:
- a. Design commitments in the Safety Analysis Reports (SARs) and other environmental and licensing documents.
- b. Design requirements of applicable industry standards and Nuclear Regulatory Commission requirements."
Design Basis: Per TVA memorandum ( App. A, 5.u) and SQEP-18 (App. A, 5.p):
"A design basis (1) identifies and interprets generic upper tier design input documents which are applicable to a specific plant, (2) identifies and evokes commitments made by TVA in licensing documents, (3) defines the general design 03770 - December 23, 1986
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SPECIAL PROGRAM REVISION NUMBER: 1 i
PAGE 8 0F 24 requirements for the plant as required to satisfy the plant safety analysis, and (4) establishes any other general design input which may be dictated by TVA policy."
Design Basis Document (DBD): Per TVA memorandum (App. A, 5.u) and SQEP-18:
"A DBD consists, as a minimum, of those general design criteria for site, plant, structures, and systems which constitute the upper tier plant-specific design input. It may also include those detailed design criteria, system descriptions, and design input drawings, discretionary engineering decisions and rationale, analysis results, and engineering parameters and associated margins for
, detailed design."
Design Input: From ANSI N45.2.11, the definition of Design Input is:
"Those criteria parameters, bases, or other design requirements upon which detailed final design is based."
Desion Output: From ANSI N45.2.ll, the definition of Design Output is:
" Documents such as drawings, specifications and other documents defining technical requirements of structures, systems and components as delineated in Section 4." (Section 4 describes Design Process requirements.)
Discussion:
- a. Engineering procedures were reviewed regarding design
! criteria development requirements.
Formal design criteria were not developed by TVA as of the ;
late 1960s. General Design Criteria were, towever, recognized and discussed in the Sequoyah PSAR (subsection 1.4), which was submitted to the NRC (AEC) on 10/15/68.
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SPECIAL PROGRAM REVISION NUMBER: 1
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PAGE 9 0F 24 Design criteria procedures existed as early as January 1970 in TVA Division of Engineering Design (EN DES) Quality Assurance Procedure (QAP), SQN-QAP-III-1.1. The SQN QAP was superseded by EN DES-EP 3.01 in July 1974. The initial issue of EN DES-EP 3.01 endorsed ANSI N45.2.11, however, TVA did not actually commit to comply until the 1976 issue of the SQN FSAR. EP 3.01 was superseded by 0EP-06 in June 1985. OEP-06 was superseded by NEP-3.2 in July 1986.
SQN-QAP-III-1.1, EN DES-EP 3.01, OEP-06 and NEP-3.2 identify design criteria as design input. The specifics as to preparation are quite detailed, including requirements for preparation, review, approval, revision, and ample guidance in the form of attachnents to the procedure. Therefore, from a procedural standpoint all of the essentials have been and are in place to eliminate vagueness and to ensure completeness and adequacy.
Based on discussion (App. A, 7.c) with Civil Engineering Branch (CEB) personnel regarding design criteria and incpection of available criteria, the criteria were ccmplete, comprehensive, and current.
Discussion (App. A, 7.a) with Mechanical Engineering Branch (MEB) personnel and observation of criteria available found design criteria were being updated to support the D8VP.
Complcteness and adequacy are being established throu design verification and interface review (squadcheck)gh the procedure, per NEP-5.2.
Discussion (App. A, 7.b) with the Electrical Engineering Branch (EEB) indicated that EEB, as an enhancement to the NEPs, has set up an internal program to address shortcomings in its design control process. This program, which adds detailed instructions relative to the procedures, is discussed in a memcrandum (App. A, 5.z). Additional detail in Gilbert / Commonwealth Report 2614 ( App. A, 5.t), relative to EEB, indicates that a more comprehensive effort is needed for the collection and distribution of design criteria.
Some specific adequacies and inadequacies relative to EEB criteria are discussed in Element Report 213.3.
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 i'
PAGE 10 0F 24 i The DBVP is established through the Sequoyah Nuclear .
Performance Plan ( App. A, 5.y). Within the detailed scope of the prerestart phase, as presented in a DBVP memorandum .
(App. A, 5.v), it is indicated that walkdown/ test data will be compared to the licensing commitments and the design criteria / design basis for an engineering evaluation.
In addition the Sequoyah Nuclear Performance Plan (App. A, 5.y) provides that the TVA Engineering Assurance (EA) organization will monitor the implementation of the DBVP.
EA has monitored the DBVP and has ferreted out certain inadequacies in the design criteria reconciliation as evidenced by an Action Items tabulation originated by the EA Independent Oversight Review Team, ( App. A, 5.bb). Items noted by EA are tracked to completion.
The NRC conducted special inspections of the DBVP (App. A, 5.cc and 5.dd), including the TVA EA Independent Oversight Team activities. From the latest NRC inspection l ( App. A, 5.dd), the NRC team concluded that the preparations-and approach for the program were in most cases in a'ccordance with the program plan, subject to some general comments.
On four different occasions Impell was called on to make independant external audit finding evaluations of the DBVP Design Control Program. Impell reports (App. A, 5.hh, 5.11, 5.jj, and 5.kk) were reviewed for additional information pertinent to the issues. Impell report 86-162 (App. A, 5.hh) compares the findings of NRC Inspection Report 86-27 with TVA's actions outlined in the DBVP. Impell report 86-180 4
(App. A, 5.11) compares findings of Gilbert / Commonwealth Reports G/C 2600 and 2614 with TVA's actions outlined in the 4
DBVP. Impell report 86-197 ( App. A, 5.jj) compares the
" Bender Report" (App. A, 5.11) and the INP0 Corporate Evaluation with the actions outlined in the DBVP. Impell '
! report 86-233 (App. A, 5.k'<) compares the findings of the OE
- ' review of unimplemented ano partially implemented ECNs for selected systems with TVA's actions outlined in the DBVP.
The point is that controls are in operation which should ensure that the DBVP will establish complete, comprehensive, and adequate design criteria.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:- 201.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 11 0F 24 The DBVP establishes a data base containing the commitments / requirements to be initially incorporated into the design criteria. SQEP-18 is being revised (Rev. 2) to require that this data base will be turned over to the project and maintained current throughout the life of the plant. This will help to ensure that the Sequoyah design criteria will reflect the latest licensing commitments and other design requirements.
- b. Design criteria are considered by TVA to be design input documents. Design input constitutes design requirements that govern the design of all structures, systems, and components. Design criteria are addressed under NEP-3.2.
l NEP-3.2 states in Section 2.0, " Policy" that " Changes to design input will be evaluated and where appropriate will be reflected in revisions to other affected design input .
documents." EN DES-EP 3.01 and OEP-06 say essentially the same thing. ,
It would appear from the procedure and discussions with TVA personnel that changes to design criteria are made when
! justification for changes has been established. It is standard practice to make changes when changes are needed to correct a deficiency, or for other reasons, regardless of when during the life of the SQN project they are found. For example:
o Design criteria document, SQN-DC-V-1.1.1.1 was revised to add, among other items, (i) Pipe break loads (ii) Tornado loads (iii) Flood loads o Design criteria document, SQN-DC-V-1.1.9 was revised to change design pressure of some doors.
The TVA SQN Generic Concern Task Force investigated concern IN-85-886-001. The results of the investigation were issued as report GCC-20-66, identified in Section 2 of this report.
i The conclusion of the investigation relative to this issue stated, in part:
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0377D - December 23, 1986 i
. TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 1
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PAGE 12 0F 24 "This investigation verified that design / acceptance criteria are still being changed but it failed to substantiate the implication that these changes are unwarranted . . ."
- c. NEP-3.2, Section 2.0, " Policy" states in part:
" Design criteria documents will be prepared for all designs and will identify the effective revision of all design inputs and the portions of each design input that are applicable to each design."
. The nonexistence of some design criteria was noted in discussions with personnel in EEB (App. A, 7.b) as well as in discussions at the SQN jobsite (App. A, 7.d). The nonexistence of specific EEB design criteria is discussed in Sequoyah Element Report 213.3.
Conclusions of the TVA SQN Generic Concern Task investigation of concern IN-85-886-001, report GCC-20-66, relative to this issue stated, in part:
"This investigation verified that there were design criteria which are needed and do not exist. In particular the design criteria for seismic hangers is scheduled to be issued for SQN by May 30, 1986. There was [ sic] identified ten other design criteria in various stages of preparation of SQN."
The Gilbert / Commonwealth report No. 2614 (App. A, 5.t) in subsection 3.1.1.3 "Previously Identified Issues," stated in part:
"The review team found that some documentation of original design bases was either not readily available or nonexistent."
It was also confirmed that corrective action to develop needed design criteria, where missing, is underway as required to support SQN restart. The corrective action is defined in the DBVP. .
03770 - December 23, 1986
A TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 1
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PAGE 13 0F 24 As follow on to the DBVP and design basis document j development, a TVA EEB memorandum (App. A, 5.z) establishes a program for improving the EEB design control process, which includes recognition of the procedural requirements relating to design criteria as well as the need to relate final design back to the source of design input.
- d. Inactivation of design criteria was first addressed in EN DES-EP 3.01, revision 4, (11/19/80). The revision added Section 10.0, "Inactisation of Design Criteria," with three subsections: 10.1 " Definition of Inactivated Design Criteria," 10.2 " Time of Inactivation," and 10.3 " Process of Inactivation." Of particular note is subsection 10.2, which states that design criteria may be inactivated in the following situations:
"a. After approval of the system preoperational test (EN DES-EP 6.01) or post modification test and before the design project is disbanded (for design criteria controlling initial plant design and not modifications),or
- b. If the entire system is replaced by a different system in the plant design.
NOTE The selection of the time of inactivation is at the discretion of the section supervisor responsible for the design criteria within the guidelines of a. and b.
above."
Revision 6 of EP 3.01, (05/22/84) changed this section to
. read:
" Design criteria may be inactivated only when the entire subject system, structure, or component has been deleted from the plant design or permanently removed from operation at the plant site."
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0377D - December 23, 1986
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3 (B)
-SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 14 0F 24 It is apparent that from 1980 to 1984 design criteria were permitted by procedure to be inactivated. This is consistent with the discussion at the Sequoyah jobsite noted below.
NEP-3.2, Section 2.0, " Policy" states, in part:
" Design criteria documents may be inactivated only when the entire subject system, structure, or component has been deleted from the plant design or permanently removed from operation at
' the plant. Design requirements in the design criteria may be incorporated in a system description or design basis document (DBD).
" Exception to design criteria documents may be taken if they are technically justifiable and j
are documented in accordance with this procedure."
?
"A D8D shall be prepared for each nuclear power plant. The D8D shall define, establish, and maintain the upper tier design documentation
! requirements for operating nuclear plants. The DBD and its subsequent revisions shall be subject to review for approval by the discipline branch chiefs as in NEP-5.2 and shall be controlled and maintained throughout the life of the plant."
OEP-06 states essentially the same policy as NEP-3.2, except it does not address the preparation of the DBD.
In a discussion at the Sequoyah jobsite (App. A, 7.d) it was
! indicated that design criteria were also inactivated when construction was completed and the system was put into operation. This practice was based on the rationale that all of the necessary information was contained in design output documents. The reason given for inactivating the design criteria was to cut down on surplus documentation, and retain only documentation needed to support the operating plant.
l This statement confirms the discussion on page 178 of the transcript of NRC investigative interview (App. A, 5.w). As noted earlier there was a time between 1980 and 1984 when such inactivation was allowed by procedure, t
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It is true that many design criteria were set up and then l
inactivated. However, Engineering has initiated restoration
- of these criteria through the DBVP. It will be necessary to j update these criteria, however, before they can be reissued.
Inactivated design criteria are identified in the Sequoyah
, Design Criteria Manual Index. Thirty-two issued criteria l were identified in the index as inactivated. All 32 were j readily retrieved.
Engineering is aware of the necessity to have these design criteria, and has initiated their restoration and updating as l
part of the DBVP.
t
! Monitoring implementation of the DBVP by EA should ensure
! adequacy and completeness of design criteria issued; l maintaining commitments / requirements tracking throughout the life of the Sequoyah plant and should ensure that criteria are maintained current.
Findings:
- a. Procedural essentials exist for eliminating vagueness, for achieving completeness, and for assuring adequacy of design criteria.
Completeness and adequacy are being established through design verification and interface review. This situation should be mitigated for SQN through the DBVP when walkdown/ test data are compared to the licensing and the design basis criteria.
- b. Design criteria are sometimes changed late in the project.
Changes are made when necessary to correct deficiencies.
Appropriate procedures are in place for making necessary changes.
- c. The issue that some needed criteria did not exist was found to be true. Appropriate procedures, such as NEP-3.2, SQEP-18, and SQEP-29, are in place for generating such criteria.
- d. It is true that some design criteria were set up and then inactivated. However, it was found that the inactivated criteria could easily be retrieved although they required update after retrieval.
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 16 0F 24 i
Some design criteria documents were inactivated when construction was completed and the system was put into operation, using the rationale that all necessary information was contained in design output documents. This was allowed by EP-3.01 at the time.
The current procedure NEP 3.2 allows design criteria documents to be inactivated only when the entire subject system, structure, or component has been deleted from the plant or permanently removed from operation at the plant.
Design requirements in the design criteria may be incorporated in a system description or design basis document.
Conclusions:
- a. The issue that some electrical and other engineering design criteria were inadequate is valid. However, this issue should be resolved as corrective actions resulting from programs currently in place (i.e., DBVP & DBD which include SQEP-18 and SQEP-29) are fully implemented.
. b. The issue is valid in that some design criteria were changed late in the project. However, design criteria changes are, and should be, made when circumstances dictate or deficiencies must be corrected.
- c. The issue is valid in that some needed design criteria did not exist. However, corrective actions resulting from full implementation of the DBVP (specifically including SQEP-18 and SQEP-29) should create design criteria where they are needed.
- d. The issue is valid in that some design criteria were inactivated. However, a part of the issue is n'ot valid, in that the criteria can be retrieved and reactivated once they are reviewed and brought up to date in accordance with NEP procedures.
- 10. CORRECTIVE ACTION:
In accordance with the Design Baseline Verification Program and associated Design Basis Documents, the Design Criteria that are identified in SQEP-29 as requirements for restart will be reviewed, revised, or generated as applicable prior to restart.
The evaluation team has reviewed the CAP (App. A, 5.nn) and concurs I that complete and satisfactory implementation of the plan should preclude recurrence of the problems identified by the issues.
03770 - December 23, 1986
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PAGE 17 0F 24 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Chapter 1, Appendix B, " Quality Assurance Criteria For Nuclear Power Plants."
- b. ANSI N45.2.11 - 1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
- c. Regulatory Guide 1.64, "0uality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- d. ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants"
- e. Regulatory Guide 1.28, " Quality Assurance Program Requirements (DesignandConstruction),"R0,(06/07/72)
- f. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- g. Sequoyah Preliminary Safety Analysis Report, (PSAR)
- h. Sequoyah Final Safety Analysis Report (FSAR) Updated, through Amendment 3.
Design, Construction, and Operation of TVA Nuclear Power Plants," R8
- j. Tennessee Valley Authority, Nuclear Quality Assurance Manual, (NQAM),(11/14/85)
- k. Sequoyah Nuclear Plant Quality Assurance Manual (SQN QAM)
Quality Assurance Procedures (QAPs) employed in the review of this element are from Revision 11 of the SQN QAM (and prior).
The following QAP is referred to in this evaluation:
SQN-QAP-III-1.1, R2, " Preparation and Review of Design Criteria for Sequoyah Nuclear Plant," (04/07/71)
- 1. Office of Engineering Design and Construction (0EDC), Quality Assurance Manual
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 G~ PAGE 18 0F 24 APPENDIX A (Cont'd)
- m. Division of Engineering Design, Tennessee Valley Authority Engineering Procedures Manual. This evaluation 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: Procurement Division of Engineering Design (EN DES), Engineering Procedures (EP) reviewed were:
EP No. 4.12, R5 "EN DES Design Guides and Design Standards - Preparation, Review, Approval, Distribution, and Revision," (04/15/82)
EP No. 3.01, R6 " Design Criteria Documents - Preparation, Review,andApproval,"(05/22/84) k EP No. 5.20, R7 " Processing Procurement Requests,"
(11/05/84)
EP No. 5.30, R6 " Standard Format for the Preparation of Procurement Specifications," (07/29/83)
EP No. 5.33, R8 " Procurement Quality Assurance," (10/26/84)
Management Manual, (04/26/85)
The following 0EPs are referred to in this evaluation:
0EP-06, R0 " Design Input," (04/26/85) l OEP-07, R0 " Calculations," (04/26/85)
OEP-08, R0 " Design Output," (04/26/85) 0EP-09, R0 " Procurement," (04/26/85)
OEP-10, R0 " Review," (04/26/85) l l
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SPECIAL PROGRAM REVISION NUMBER: 1
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- o. TVA Division of Nuclear Engineering, Nuclear Engineering Procedures (NEPs):
NEP-3.2, R0 " Design Input," (07/01/86)
NEP-4.1, R0 " Procurement,"(07/01/86)
NEP-5.1, R0 " Design '0utput," (07/01/86)
NEP-5.2, R0 " Review,"(07/01/86)
- p. TVA Division of Nuclear Engineering (DNE), Sequoyah Engineering Project (SQEP), Project Manual SQEP-13, R0 " Procedure for Transitional Design Change Control,"(07/25/86)
SQEP-18, R1 " Procedure for Identifying Commitments and c Requirements as Source Information for Sequoyah Design k Criteria Development," (07/09/86)
SQEP-18, R2 " Procedure for Identifying Commitments and Requirements as Source Information for Sequoyah Design CriteriaDevelopment,"(DRAFT)"
SQEP-29, " Procedure for Preparing the Design Basis Document for Sequoyah Nuclear Plant," R1 (07/18/86)
- q. Tennessee Valley Authority Sequoyah Nuclear Plant, Standard Practice, SQA0134, " Critical Structure, Systems, and Components (CSSC) List," R8, (01/27/86)
- r. Sequoyah Nuclear Plant Design Criteria Manual (6 Volumes),
(06/26/86)
- s. Gilbert / Commonwealth, Inc. Report No. 2600, " Assessment of Design Control Program for the Sequoyah Nuclear Plant, Prepared for the Tennessee Valley Authority," (10/85)
- t. Gilbert / Commonwealth, lac. Report No. 2614, "Sequoyah Nuclear Plant Modification for Tennessee Valley Authority," (03/03/86)
- u. TVA memo from W. C. Drotleff, Jr., to Those Listed, (R. G. Domer, et al), " Design Basis Program for TVA Nuclear
_ ([, Plants," (B44 860402 007), (04/08/86) j 0377D - December 23, 1986
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
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PAGE 20 0F 24 APPENDIX A (Cont'd)
- v. TVA memo from D. W. Wilson to Those Listed, (G. Aklu, et al),
"Sequoyah Nuclear Plant - Design Baseline and Verification Program,"(B25860E06020),(05/06/86)
- w. Letter from NRC to S. A. White, TVA, " Transcript of Interview of Dallas R. Hicks," (06/23/86)
- x. TVA memo from R. L. Gridley to Those Listed (H. L. Abercrombie, et al), "Sequoyah Nuclear Performance Plan - Volume II - Final Concurrence," (L44 860714 800),
(07/14/86)
- y. Sequoysh % clear Perf armance Plan, Volume II, R1, (07/86)
- z. TVA memo from W. S. Raughley to J. D. Collins, et al, " Policy Memorandum PM 86-24 (EEB) - EEB Design Control Process,"
(843 861017 904), (10/17/86) aa. TVA memo from J. F. Cox to M. T. Tormay, "Sequoyah Design Basis Program to Support Restart," (B25 860811 100),
(08/11/86) bb. Action Items Originated by the Engineering Assurance Independent Oversight Review Team for the Sequoyah Nuclear Plant Design Baseline and Verification Program - Summary Report, Prepared By: John Von Weisenstein, (10/22/86) cc. Letter from NRC to S. A. White, TVA, " Report Nos. 50-327/86-38 and 50-328/86-38," (09/15/86) dd. Letter from NRC to C. C. Mason, TVA, " Report Nos. 50-327/86-45 and 50-328/86-45" (10/31/86) ee. TVA memo from L. L. Jackson to Those Listed (H. L. Abercrombie, et al), " Institute of Nuclear Power Corporate Evaluation Responses" Operations (INPO)(08/14/86)
(A02 860813 012) ff. SQN-DC-V-1.1.1.1, " Detailed Design Criteria for Evaluation of Unreinforced Masonry Walls Constructed from Solid Concrete ,,
Blocks," R1, (05/21/81) gg.
SQN-DC-V-1,1.9, " Design Criteria for Pressure Confining Personnel Doors," R2, (10/1/86)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 201.3(B)
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( PAGE 21 0F 24 APPENDIX A (Cont'd) hh. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-162), (06/19/86)
- 11. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
-(Impell/TVA-86-180), (06/30/86) jj. LetterfromImpelltoTVA(Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-197),(07/10/86) kk. Letter from Impell to TVA (Attention: Mr. Henry Jones),
" Design Control Program External Audit Finding Evaluation,"
(Impell/TVA-86-233),(07/23/86)
- 11. Report: " Assessment of Engineering Design Control for the Browns Ferry Nuclear Plant," written by Myer Bender, F. E.
Laurent, E. H. Cole and R. D. Sabin, (09/85)
{
mm. INP0 Report of Sequoyah Nuclear Plant TVA, February 1984 Evaluation
. nn. Letter from G. R. McNutt, TVA, to G. L. Parkinson, Bechtel,
" Employee Concern Evaluation Program - Sequoyah Restart Program - Corrective Action P1an (CAP)," <(TCAB-026),
(12/12/86)
- 6. WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREBENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
- a. 10CFR50, Appendix B, " Quality Assurance Criteria For Nuclear Pcwer Plants"
- b. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- c. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
- d. Regulatory Guide 1.28, " Quality Assurance Progran, Requirements (Design and Construction)," R0, (06/J7/72)
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- e. ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants"
- f. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions"
- g. Sequoyah Final Safety Analysis Report (FSAR) Updated, through Amendment 3.
- h. TVA Division of Nuclear Engineering, Nuclear Engineering Procedures (NEPs):
NEP-3.2,R0"DesignInput,"(07/01/86)
NEP-5.2, R0 " Review," (07/01/86)
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT. .
- a. Discussion, D. Zwicky, Bechtel, with S. Rudell and H. Mahlman, TVA Mechanical Engineering Branch in Knoxville, (10/22/86) (10M-469)
- b. Discussion, D. Zwicky, Bechtel, with G. Reed and P. Nesbitt, TVA Electrical Engineering Branch in Knoxville, (10/23/86)
(10M-469)
- c. Discussion, D. Zwicky, Bechtel, with C. Glidewell, J. Williams and N. Liakonis, TVA Civil Engineering Branch in Knoxville,(10/23/86)(IOM-469) l
- d. Discussion D. Zwicky, B. Wolters, Bechtel, with Henry Jones and Terrell Clift of TVA at Sequoyah jobsite, (10/24/86)
(10M-469)
- e. Trip Report, D. Zwicky personal visit to Knoxville, October 21-23, 1986, and SQN Site, October 24,1986 (IOM-469)
- f. RFI #712, (11/13/86)
L 0377D - December 23, 1986
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- g. RFI #718, (11/15/86)
- 1. Telecopy TVA to R. Wolters, submittal of INP0 February 1984 Evaluation of SQN (Response to RFI #712)
- j. Telecon, D. Zwicky, R. Wolters, J. Violette and C. Jordan, Bechtel, with T. Clif t, P. Nesbitt and G. McNutt, TVA, l (11/11/86),(IOM-462) l G
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PAGE 24 0F 24 CATD LIST The following CATD identifies and provides corrective action for the findings included in this report.
, 201.03 SQN 01 (12/05/86) 4 f
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TENNESSEE VALLEY AUTHORITY PAGE -
44 REFERENCE - ECPS120J-ECPS121C RUN TIME - 12:57:19 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER s
EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 ONP - ISSS - RHM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20105 DESIGN CRITERIA '
S GENERIC KEYHORD A H APPL QTC/NSRS P KEYNORD B BBSH CONCERN KEYWORD C CONCERN SUB R PLT INVESTIGATION S KEYHORD D NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION
)
20103 S HBN YYYY SR TVA DESIGNS HERE NOT DEVELOPED HELL DESIGN REVIEH IN 886-001 EN ENDUGH TO Bt CONSTRUCTABLE: li DESIG DESIGN CHANGES T50157 EN 20404 REPORT ENGINEERING EN 22003 N CHANGES ARE STILL VEHING INSTITUTE D IN AREAS HHERE THERE SHOULD HAVE B HANGERS EEN MINIMAL CHANGES ESPECIALLY IN AR EA 0F CONFLICTS BETHEEN TVA AND VEND OR DHGS. 2) ENGINEERING DESIGN CRIT ERIA IS OFTEN NON-EXISTENT, PARTICUL ARLY FOR SEISMIC HANGER DESIGN. MAN Y DESIGN CRITERIA OR ACCEPTANCE CRIT ERIA ARE STILL BEING CHANGED. THIS IS GENERIC CONCERN. ANY FURTHER INF ORMATION HOULD DIVULGE CONFIDENTIALI TY. CONSTRUCTION "EPT. CONCERN.
YYYY SR ELECTRICAL STANDARDS AND GUIDES ARE STANDARDS HI 100-019 EN 20103 S HBN TREATED AS GUIDES, AND ARE NOT INCOR DESIGN RELATED T50212 EN 20104 REPORT ELECTRICAL EN 21303 P0 RATED IN DESIGN CRITERIA REQUIREME NTS. ELECTRICAL DESIGN CRITERIA, NH GENERAL ERE IT EXISTS, IS NOT COMPLETE, IS V AGUE, AND IN GENERAL IS INADEQUATE.
CI HAS NO FURTHER INFORMATION. ANO NYMOUS CONCERN VIA LETTER.
HI 100-04f; EN 20103 N HBN YYYY SR TVA HAS SET UP DESIGN CRITERIA FOR H DESIGN PROCESS T50213 REPORT ENP AND, AFTER THE FACT, HAS INACTIV NDHCONFORMANCE ATED A LARGE PERCENTAGE OF THE CRITE GENERAL RIA. CI HAS NC FURTHER INFORMATION. GENERAL ANONYMOUS CONCERN VIA LETTER.
3 CONCERNS FOR CATECORY EN SUBCATEGORY 20103 I
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