ML20236E325
| ML20236E325 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/17/1987 |
| From: | Dowd J, Walters R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20236E191 | List: |
| References | |
| 205.3(B)-01, 205.3(B)-1, 205.3(B)-R, 205.3(B)-R00, NUDOCS 8710290177 | |
| Download: ML20236E325 (36) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0
, REPORT. TYPE: SEQUOYAH ELEMENT TITLE: CONTROL OF DESIGN CALCULATIONS Calculation Records Retention PAGE 1 0F 21 1
REASON FOR REVISION:
PREPARATION PREPARED BY:
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/DATg REVIEWS R; - EVIEW COMMITTEE:
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~SIGNATU / i DATE SIGNATURE DATE CONCURRENCES I 2-// 7[I[
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[kO2}gbc 0 00' 7 CEG-H: d 2 1 -%7 SRP:
DATE SIGNATURE
- DATE SIGNATURE
~
APPROVED BY:
DATE MANAGER OF NUCLEAR POWER DATE ECSP MANAGER CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
TVA EMPLOYEE CONCERNS REPORT NUMBER: ~205.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 2 0F 21 i l
- 1. CHARACTERIZATION OF ISSUES:
Concerns: Issues:
WI-85-100-043 a. Some design calculations are not "There are problems in design. stored as quality records.
calculations, in that some are i never prepared, some are in- b. TVA management is not aware of the adequate in scope and quality, requirements of ANSI N45.2.9 for and some are not stored as retention of design calculations as quality records. There is permanent plant records, inadequate interface and control of design calculations, NOTE: lhe following issues from which impacts traceatliity of these concerns are addressed in other design requirements." reports.
IN-85-110-004 Some design calculations are never
" Lack of awareness by TVA OE prepared (addressed in Sequoyah Management (names given) of Element Report 205.1).
requirements to document the load carrying capabilities Some design calculations are inadequate of pipe supports for future in scope and quality (addressed in reference. TVA Management Sequoyah Element Report 205.1).
ignoranc of requirements of ANSI N45.2.9 for retention There is inadequate interface and of design calculations as control of design calculations permanent plant records." (addressed in Sequoyah Element Report 205.2).
Lack of control of design calculations impacts traceability of design requirements (addressed in Sequoyah Element Report 201.6),
i TVA OE Management is unaware of requirements to document the load carrying capabilities of pipe supports for future reference (addressed in Sequoyah Element Report 220.3). .
NO X
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES Identified by N/A Date N/A l
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SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 3 0F 21 4
- 3. DOCUMENT NOS., TAG N05., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE l IDENTIFICATIONS STATED IN ELEMENT:
None l
- 4. INTERVIEW FILES REVIEWED:
Expurgated files WI-85-100 and IN-85-110 were reviewed, and no additional unreviewed information was found.
- 5. DOCUMENTS RELIIEWED RELATED TO THE ELEMENT: l See Appendix A.
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
,- See Appendix A. i 1
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER l
DISCUSSIONS RELATED TO ELEMENT.
l' See Appendix A. l l
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- 8. EVALUATION PROCESS:
I
- a. Reviewed upper-tier documents (10CFR50, Appendix B; ANSI :
N45.2.9; QA Program Manual; FSAR; etc.) to ded. ermine policy l and procedures for development and control of design j
)
calculations. !
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- b. Examined TVA procedures covering the storage and retention of design calculations for evidence of compliance with ANSI ,
N45.2.9. ;
- c. Reviewed results of audits (QA, INP0, NRC) to determine if j' design calculations have been stored and retained according to policy and procedures.
- d. Reviewed available transcripts of NRC investigative -
interviews to gain additional information regarding the concerns.
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b 39 :u 1" 'TVA: EMPLOYEE. CONCERNS REPORT: NUMBER: -205.3(B)
SPECIAL-PROGRAM-REVISION' NUMBER: 10 t PAGE 4 0F 21 ,
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- e. Reviewed the' Essential Calculation Program,' the Design ~ Basis- I Program, and the Desig'n Baseline and Verification' Program for SQN to determine if these programs address the issuesLin Section 1.
_ .9. DISCUSSION, FINDINGS, AND CONCLUSIONS: .
Chronology:
o03/08/70: -SQN-QAP-III-1. 2, " Preparation, Review, and Records of- 1 Design. Calculations," issued 06/27/70:- .10CFR50 ' Appendix B formally issued i
-10/73 - DivisionofEngineeringDesign(ENDES) Engineering 06/85: Procedures-(EPs)in.effect-
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'08/74: Regulatory Guide 1.88, Revision 0, which endorsed ANSI N45.2.9-1974, published a- 06/22/74: EN DES-EP 3.03, " Design Calculations," issued for use by Branch and Project Engineering staff.
09/17/74: EN DES-EP 1.14, ". Engineering Records - Retention and'
. Storage," issued; reference ANSI N45.2.9
'06/76: TVA commits to Regulatory Guide 1.64, Revision 1, which endorsed ANSI N45.2.ll-1974 ,
09/01/76: Management and Engineering Data System (MEDS) Branch becomes responsible for retention, storage, and ,
microfilming of records .
1 09/16/80: Operating License (0L) issued for SQN Unit 1
' M/25/81: Operating License (0L) issued for SQN Unit 2 06/84: TVA QA audit No. D51-A-84-0006 identifies failure in !
documenting electrical calculations i 09/84: Bellefonte Electrical Evaluation (BEE) report by TVA identifies the lack of certain electrical l calculations. Electrical Engineering Branch (EEB) initiates efforts to develop a minimum set of electrical calculations
,.- 10/03/84: EEB commits to QA to provide calculation status for all j
' four plants j l
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o TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 5 0F 21 03/85: EEB sends list to Quality Management Staff (QMS) of all electrical calculations and studies for SQN 05/15/85: TVA receives employee concern IN-85-110-004 06/85 - Office of Engineering Procedures (0EPs) in effect; 06/86: Superseded EN DES-EPs 08/85: TVA voluntarily shuts down SQN Units 1 and 2 11/85: QMS followup on 06/84 audit deviations indicates corrective actions not complete 11/26/85: Electrical Engineer Branch Chief commits to completion of the minimum set of electrical calculations 12/07/85: TVA receives employee concern WI-85-100-043 12/11/85: Civil, Mechanical, and Nuclear Chief Engineers are requested to examine discipline calculations for
,, possible revision or update 01 /01 /86: Records ana Information Management System (RIMS) integrates earlier Automated Records Management System (ARMS) and Management and Engineering Data System (MEDS) 01 /86: TVA EEB contracts with Sargent & Lundy for an independent assessment of the electrical calculation program for each nuclear plant 01/86: Gilbert / Commonwealth (G/C) undertakes a survey of design changes to SQN main and auxiliary feedwater system and identifies deficiencies in design s.
calculations 03/07/86: All Branch Chiefs requested to perform essential '
calculation program similar to one for electrical calculations 04/22/86: NRC inspection reports 50-327/86427 and 50-328/86-27 i identify the lack of calculations to support original !
design l l
, 07/86 - Nuclear Engineering Procedures (NEPs) in effect; I present: superseded OEPs l 1
07/17/86: Sequoyah Nuclear Performance Plan (SQN NPP), Volume II
' R1, issued in which TVA commits to developing a minimum ;
set of electrical calculations 0477D (02/12/87)
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-TVA EMPLOYEE CONCERNS REPORT. NUMBER: 205.3(B) ]
SPECIAL PROGRAM l k REVISION NUMBER: 0 l o.
-l PAGE.6 0F 21' I
. Discussion:
This element repoitl addresses two issues relating to the preservation of design calculations. The first issue is that some i calculations are'not stored as quality _ records; the second states.
that TVA management is not aware of the ANSI N45.2.9 requirements
- for the retention of design calculations.
Review of the'first issue focuses on meeting. collection, filing, h storage, and permanent retention requirements _for design calculations. This review did~not extend to the adequacy of TVA corporate permanent storage systems and facilities, including the ;
- remote storage facility in Boyers, PA, because that activity is beyond the_ scope of this report.
9.1 CALCULATION RETENTION REQUIREMENTS AND TVA COMMITMENTS-The evaluation team reviewed applicab'le criteria and
~
-licensing documents to establish the_ requirements and commitments for SQN relating to design calculations.
< o 10CFR50: The essential regulations thaticover the control of calculation records are contained in 10CFR50, Appendix B, to which TVA committed to in 1970 ;
(App. A, 5.a). Criterion XVII, " Quality Assurance 1 Records," states, in part,.that ". . . sufficient records shall be maintained to furnish evidence of j activities affecting quality. . . . Records shall be j identifiable and retrievable. Consistent with l applicable regulatory requirements, the applicant shall 1 establish requirements concerning record retention, 'l f
such as duration, location, and assigned {
responsibility." 1 I
o Regulatory Guide 1.88: TVA committed in 1974 to NRC j Regulatory Guide 1.88 ( App. A, 5.c) which endorses ANSI J N45.2.9, " Requirements for Collection, Storage, and i Maintenance of Quality Assurance Records for Nuclear Power Plants" ( App. A, 5.b). This standard provides general requirements for the control of quality assurance records associated with"the design, manufacture, construction, and operation activities of nuclear power plants. The requirements mentioned in l this standard are intended to assure that records are available when needed. Section 2.1 of the standard requires the establishment of a records system that must be defined, implemented, and enforced in i
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n .1 TVA EMPLOYEE CONCER'NS REPORT NUMBER: 205.3(B)'-
.SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 7 0F 21
- accordance with written procedures, instructions, and other documentation. Appendix A to the standard
- recommends that' design calculations and record checks be retained as lifetime records.
o Regulatory Guide 1.64: TVA committed in 1976 in the SQN FSAR to NRC Reguiatory Guide -164 (App. A, 5.d) which endorses ANSI N45.2.11-1974, " Quality- Assurance ~
Requirements for the Design of Nuclear Power Plants" (App. A, 5.e). This' ANSI standard in Section 10,
" Records," calls for the collection, storage, and
- retention-of design documents and records that provide ~
evidence that the design and review process'was performed in accordance with ANSI N45.2.ll. .Such documents include not only the final design documents such as drawings and specifications,.but also records <
of important steps, including sources of design inputs,.
such as design calculations, that support the design process.
Not until the early 1970s were regulatory and industry guidelines for preparing and documenting design calculations developed and issued. TVA, like other utilities .and Architect / Engineering firms involved in the design and constructic_n of nuclear power plants, has followed i.ndustry practice _regarding the development of-calculations to support design decisions.
Chapter 17 of the Sequoyah FSAR dealing with Quality Assurance (also identified as TVA Topical Report TR-75-1A, R8, Quality' Assurance Program - App. A, 5.f) identifies
- - requirements for the control'of design calculations in 17.1.6, " Document Control," and in 17.1.17, " Quality Assurance Records." TVA's records management program conforms to ANSI N45.2.9-1974, which treats design calculations as lifetime quality records.
9.2 TVA ENGINEERING DEPARTMENT PROCEDURES i A brief overview of TVA's early nuclear. power plant !
engineering organization provides background information j useful in assessing TVA's engineering practices and l j
procedures pertaining to design calculations and the control and retention of calculation records. j l
All design engineering for the TVA nuclear power plants prior j to October 1973 was performed by Engineering Branches or j discipline groups. These Engineering Branches designed !
several nuclear plants concurrently, beginning in the early l f
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0
) PAGE 8 0F 21 1960s. In October 1973, an organization change at TVA resulted in the establishment of the Division of Engineering Design. At that time, a project system was established that i assigned engineers from the engineering disciplines to work exclusively on a specific project, such as Sequoyah 1 and 2.
The Sequoyah project engineering team members, under a project manager, were assigned responsibility for maintaining the design activities related to Sequoyah, including any needed design changes. The preparation, updating, filing, and retention of calculations, however, was the 3
responsibility of both the project and the Branches.
Calculation Procedures Prior to 1973 Engineering Branches provided engineering personnel with technical direction for developing and issuing calculations in the early days of the TVA nuclear program. The first QA program procedure for calculations was contained in the SQN Quality Assurance Manual. Procedure SQN-QAP-III-1.2,
" Preparation, Review, and Records of Design Calculations,"
( App. A, 5.g) which was first issued on March 8,1970, placed l responsibility for the " orderly making, indexing, and filing of computations" with the design engineers and supervisors in each design branch. Some detail was provided on how to structure a calculation package; assure adequate legibility and indexing; assign responsibility for checking, review, and final approval of calculations. Section 6, " Filing," states that final calculations shall be rearranged and reparated into volumes as soon as final design is completed for each project feature. These final calculations, and others that may have possible future value, are to be sent to the Engineering Records Section for filing in the design master file where they will be available for reference. This early procedure does not provide directions on the handling and storage of individual final calculations during the period between their approval and the final assemblage of related calculations into indexed volumes. The procedure is also silent on the microfilming of calculations.
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.4 TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.3(B) ,
SPECIAL PROGRAM REVISION NUMBER: 0
- 1 PAGE 9 0F 21 j 1
Engineering Design Division Procedures Since 1973 Since October 1973, three separate engineering procedure manuals have been used by the TVA engineering branches and .
projects: j Title Effective Date o Division of Engineering Design, October 1973
- Engineering Design Procedures i (EN DES-EPs) o Office of Engineering Procedures (0EPs) June 28,1985 ;
o Nuclear Engineering Procedures (NEPs) July 1, 1986 l
A general review of past and present TVA procedures covering the preparation and issue of design calculations is presented '
in Sequoyah Element Report 205.1. Sequoyah Element Report 205.2 discusses procedural requirements for revising calculations, interf ace coordination, 'and updating ;
calculations to support design evolution and revisions. TVA I engineering practices and procedures that pertain to the control of design calculation records are reviewed in this l element report.
EN DES-EPs. EP 3.03, " Design Calculations," was first issued in August 1974. This procedure called for all design ;
calculations to be prepared, approved, and filed in an orderly and controlled manner. Section 6.0, " Filing," ;
repeats the basic directions of SQN-QAP-III-1.2 by requiring final calculations to be separated into volumes and identified by a unique numbering system as soon as final ,
design for a unique system is completed. Other calculations, !
not final, are to be arranged in folders and indexed. "In some instances it may be desirable to have critical calculations microfilmed while the' calculation is being prepared. Originals of approved calculations (not i necessarily final) shall be transmitted by the originating )
organization to the Maps and Engineering Records (M&ER) t organization. M&ER shall reproouce a set for vital records storage, a set for the Engineering Records file, and maintain ;
a file of the originals. . ." (emphasis added). ;
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EP 1.14, " Engineering Records - Retentio'n and Storage,"
issued 09/17/74, outlined the requirements, responsibilities, and methods of retention and storage of engineering records.
The procedure clearly stated that all engineering records of whatever kind are TVA property and provided instruction on the retention'and storage of correspondence, drawings, quality assurance records, and calculations. The procedure also references sections of ANSI N45.2.9 which was issued in June 1974.
Section 3.4 of EP 1.14 on " Design Computations" states that 3 engineering design computations are retained by the originators during active design work on a project. This statement reflects common industry practice in the early 1970s whereby engineers were responsible for filing and storing both draft and approved calculations in personal files. The same section of the procedure, however, required biweekly microfilming of all active calculations in any state of preparation. After each revision or final checking, calculations were to be resubmitted for microfilming.
Completed sets of final calculations were to be bound and a final microfilm copy made for record purposes. This more stringent requirement for the biweekly microfilming of all in-process calculations was not included in revisions of the basic procedure on calculations, EP 3.03, that were made on 05/07/75 and 04/14/76.
The requirement for the biweekly microfilming of calculations was eliminated by Revision 2 of EP 1.14 issued in December 1976 when microfilming was reserved for final design calculations. In October 1977, Revision 3 of EP 1.14 further defined final calculations for filming as completed sets of calculations for major structures or systems and components.
EP 3.03, Revision 3, issued 09/28/78, was a general revision to the design calculation procedure. In addition to other changes, this revision required the use of a standard calculation cover sheet and a Management and Engineering Data System (MEDs) accession number on the cover sheet as a unique identifier for calculation retrieval purposes. Instructions on the filing and microfilming of. calculations remained unchanged.
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In January 1979, EP 3.03 R4 was issued to require that. .{
calculations be approved and microfilmed before or during the issuance of a design drawing or design document supported by- t the calculations. -(This change was not. reflected in EP l'.14, Section'4.4.until Revision 9,' issued 01/31/83.) EP 3.03,-
Revision 6, issued'01/31/83, was another general revision that included more than 20 modifications to the design I calculation procedure. An important change that affected calculation records was the requirement.to microfilm calculations as soon as possible but, in any case, not more a than 30 days after their approval. l OEPs. Effective 06/28/85, OEP-07, R0, " Calculations," became !
the controlling procedure for the preparation and handling of
. design calculations. The thirteen pages of detailed.
instruction contained in EP 3.03 were reduced to three and a-half pages_ of concise instruction on the key elements of i preparation, checking, review, approval, issue, 'and revision of calculations. At many of the steps in the calculation i process, the' reader was referred directly to other OEPs that-control these activities. For example, while EP 3.03, R8,
' required calculations to be microfilmed within 30 days of approval, the new OEP-07 states that. calculations. are issued '
according to.the' procedure on design records' control, OEP-16. This later procedure directs the Project Engineer / Group Head to distribute calculations to RIMS only. i No specific directions on storage or the time requirement for l microfilming is mentioned. A new requirement introduced with OEP-07 was the use of a calculation log to record information on all new calculations and their revisions, including the ;
calculation subject, identifying number, and responsible supervisor. <
Procedure OEP-16, " Design Records Control," makes several brief references to design calculations. Section 1.0, ;
" Definition," lists calculations as design records. Section j 3.0, " Procedure," provides for the issue of calculations by a the Project Engineer (PE) or Group Head (GH) after approval, in accordance with the procedure governing calculations (0EP-07), and distribution to the Records Information Management Syctem (RIMS). Directions for the storage and retrievability of records, other than drawings and Bills of Material, require the Information Management System (IMS) {
group to establish recctdkeeping methods and media for preserving the OE Master File. IMS is also required to 1
define the reproducible quality of records, to provide backup l storage for records, and to make records available to OE j personnel when requested, j i
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On July 1, ~1986, Nuclear Engineering Procedures 1(NEPs) l NEPs.
were issued to govern the reorganized Division of Nuclear h Engineer (DNE) design engineeringLactivities. Calculations - J are covered in NEP-3.1, " Calculations," which is basically identical .in content, format, and brevity to _0EP-07,' issued a l year earlier. As in OEP-07, the reader is referred to five i other procedures for coverage of the verification, issue, and revision'of TVA design or vendor calculations. NEP-3.1 !
-revised the calculation cover sheet to require indication of- l whether or not the calculation contains unverified assumptions that-must be later verified; to identify the calculation as safety-related or not; and to instruct RIMS on disposition of calculations after microfilming. The new procedure also revised the calculation log form to document l the existence of unverified assumptions and provide s V ce for ,
the RIMS accession number for record retrieval purposes.. -
Another new procedure, NEP-1.3, " Records Control," replaces
- OEP-16 and contains several minor changes, such as a requirement to stamp calculations as QA records before they are sent to~the DNE Master File (RIMS).
9.3 EVALUATION OF PROCEDURES AND PRACTICES During the early 1970s, TVA's procedural requirements for the !
storage and filming.of calculations evolved, therefore, from a rather stringent requirement-(carried in early EN DES EPs) to one which lacked clear definition (in OEPs) regarding when ;
and which approved calculations were to be filmed.- !
Engineering practice reflected this situation. Initial calculations were performed in " job books," that is, ,
notebooks or binders kept by individual engineers in which I l=
support calculations were recorded. Common practice at TVA l- in the early.1970s was for individual engineers to file, store, and maintain'those calculations for which they were personally responsible. Their records were often taken by engineers when transferred to another project assignment.
Many calculations from this period would appear not to have been microfilmed as a part of the permanent plant record system, as discussed in Sequoyah Element Report 205.1.
t.
l A key element in discussing the storage of design
- calculations as quality records is the question when do calculations become quality records. ANSI N45.2.9-1979, Paragraph 1.4, " Definitions," provides the following response
- "A document is considered a quality assurance record when the document has been completed (see paragraph 3.2.1)." The referenced paragraph states, in part, that 1 04770 (02/12/87) 1
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" Documents shall be considered _ valid records only if stamped, or initialed,_or-signed and dated by authorized personnel or otherwise authenticated." Common industry practice considers a calculation document approved and issued once the .
calculation has been checked and reviewed and all j signatures / initials are obtained and all comments resolved, '
and the cover sheet is signed in the approval box by the authorized manager. Prior to signed approval, the document.
is , considered a working-level, preliminary' document. After-approval, however, design calculations are quality records and should be processed, stored, and retained in accordance with regulatory requirements and standards and internal TVA procedures.
Regulatory requirements (10CFR50 Appendix B and ANSI N45.2.91 '
for the f.iling, storage, and retention of design support
. documentation such as calculations are generic in nature and define "what" is required. These requirements, however, need additional directions on "how" best to accomplish these -!
objectives and are usually spelled out in department procedures. Procedures relating to calculation records would f be expected to address such topics as the definition of a-final. calculation; project group calculations filing requirements for storing approved calculations, with a
. defined system for checking out documents for revision; a method of logging calculations that includes information such as title, approval date, revision level, description, etc.;
instructions on handling computer calculations; directions ,
for processing superseded calculations; microfilming '
requirements, including filming frequency; and hard copy original and microfilm storage and indexing requirements.
TVA's engineering department procedures have lacked a i definition of " final" calculations. Common practice at TVA, beginning with the early SQN-QAP-III-1.2 procedure, was to gather final calculations into volumes as final design was completed for a plant system, component, or feature. In a modern nuclear plant, however, iterative revisions to a design are not unusual during the design-construction phase of the plant. Calculations to support each design change are required, and each revision is generally considered to be
" final."
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-Industry practice today is to consider as. final a calculation
'which forms the' basis of drawings,' final specifications,'or 1 other. documents used to-construct the plant _or to obtain authorization to operate the plant. Even though a calculation may be revised later because of changes in criteria, methods, or other reasons, the fact that it forms the basis of design input or output documents at the time of approval makes _it a final calculation and, consequently, a ,
quality record,that is subject to specific filing'and storage- '
requirements.-
1 In reviewing the issue of TVA management awareness of. l requirements to retain design calculations as permanent plant !
records, the evaluation team found that: consistent procedural direction was given to engineering personnel for the transfer and storage of final calculations to a central records ..
processing section. Quality Assurance Procedure SQH-QAP-III-1.3, which was issued in March 1970, was the earliest such procedure reviewed. The' Division of '
Engineering Design procedure, EP 1.14, " Engineering Records -
- , Retention and Storage," issued 09/17/74, references sections
't of. ANSI N45.2.9 which had been issued only three months previously on June 6, :1974. This procedure and EP 3.03,
" Design Calculations, R0," issued 08/22/74, clearly call for the storage and retention of final calculations as permanent !
records. These early procedures'and successive ones lend strong support for the conclusion that TVA management has been aware of retention requirements for design calculations.
-Although retention requirements were reflected in department ,
procedures, the absence of some calculations and difficulties in retrieving many calculations point to a problem in implementing an effective records program. Since a similar I problem does not appear to have occurred with design output !
documents such as drawings, the evaluation team believes that calculation records retention problems resulted from a lack of clear procedures, especially a definition of " final" calculations, and management attention to these issues, i rather than from ignorance of ANSI N45.2.9 requirements.
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SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 15 0F 21 1
9.4 NEW TVA CALCULATION-RELATED PROGRAMS l 1
TVA established an electrical calculations program in 1985 to correct and resolve deficiencies found in electrical calculations at the four nuclear plants ( App. A, 5.y). This program is designed to identify those calculations. required to support safety systems used for safe shutdown (essential calculations) and others needed to support plant reliability and availability (desirable calculations). After identification, the essential calculations are to be located and updated or superseded; if not available they must be generated. In March 1986, the Director of Engineering Technical. Services made this effort a requirement for the Mechanical, Nuclear, and Civil engineering branches as well, and a Sequoyah Unit 2 restart item (App. A, 5.z).
In April 1986, a Design Basis Program was developed to address the lack of design criteria for each nuclear plant
-(App. A, 5.aa). The program requires the development of a Design Basis Document (DBD) that compiles all commitments for each plant that are found in the FSAR, design criteria,-NRC commitments, etc. Verification that calculations exist to i b- support the DBD are an essential part of this program. TVA is committed to develop design basis documents for Sequoyah.
A Design Baseline and Verification Program (DBVP) was also established in May 1986 to assess the adequacy of past modifications at Sequoyah ( App. A, 5.bb). The DBVP requires a review and evaluation of modifications since operating license issuarice for those portions of safety-related systems necessary to mitigate FSAR Chapter 15 design basis accidents, safely shut down the plant, and maintain it in a safe shutdown condition. Also included is verification that calculations exist to support the changes. This phase of the program is .also scheduled for completion prior to restart.
Findinas:
- a. INP0 evaluations at Bellefonte in March 1984 ( App. A, 5.s) and at Watts Bar in May 1985 ( App. A, 5.t) found that some electrical calculations were not available. This same deficiency was confirmed at Sequoyah where calculations could not be retrieved to support voltage levels, cable lengths, and diesel generator loads. In the transcript of the NRC investigative interview, the concerned individual discussed the informal preparation and lack of a quality records storage program for calculations prior to the mid-1970s (App. A, 5.x). The Sargent & Lundy SQN electrical
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SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 16 0F 21 i
calculation program assessment report in April 1986 (App. A, 3 5.u) also concluded that "the majority of calculations, excluding those necessary to support restart, were prepared informally by TVA during the design period and were not l maintained in a manner, as required by today's standards, that would allow easy retrieval over the life of the plant." ]
The NRC inspection of Sequoyah's design control practices in February 1986 identified the lack of some calculations to ,
support original design ( App. A, 5.v). The Sequoyah i mechanical group identified missing calculations for a number 4 of plant systems as part of the program to identify essential calculations. Also, some Civil calculations were not available for review by evaluation team members for issues ,
related to Sequoyah Elements 215.6, 215.9, 218.4, 220.3, 222.3, 222.5, and 222.6.
- b. In August 1974.TVA committed to Regulatory Guide 1.88, R0, ;
which endorses ANSI N45.2.9-1974. The earliest version of the Engineering Records procedure (EP 1.14, RO) referenced provisions of the standard in September 1974. Thus, TVA management was indeed aware of the requirements ANSI N45-2.9.
Conclusions:
9
- a. The documents and reports reviewed by the evaluation team substantiate the issue that some design calculations were not !
stored as quality records. While some calculations may not, >
in f act, have been performed, the majority of Sequoyah design calculations prepared in the late 1960s and early 1970s followed general industry practice at a period when less stringent documentation standards and procedures were followed in the U.S. nuclear program. Therefore, the issue is valid. '
Design calculations prepared between September 1976, when MEDS was initiated, and the granting of the OL in June 1981 ,
were generally stored as quality records but are often difficult to retrieve because of record indexing weaknesses.
Calculations prepared since OL were subject to stricter ;
records management systems and control dnd are generally retrievable and available. Completion of the electrical calculation review effort will provide assurance that essential calculations exist and are retrievable to support the desip basis for safety-related systems.
_q . ..
04770 (02/12/87)
4 , ,
' TVA EMPLOYEE CONCERNS , REPORT NUMBER: 205.3(B) ;
6 SPECIAL PROGRAM t REVISION NUMBER: O c
, PAGE 17 0F 21
- b. TheissueofTVdmanagement'sawarenessoftherequirements
'of ANSI' N45i2.9 for retention of design calculations as permanent plant records is not valid.- In August 1974 TVA committed to R'egulatory Guide 1.88, R0, which endorses ANSI N45. 2.9-1974. The earliest version of the Engineering Records procedure (EP 1.14, R0) referenced provisions of the standard in-Ssptember 1974. These items demonstrate TVA' management's awsreness of records management requirements for engineering documents, including design calculations.
Recurring problems in accessing design calculation records, however, indicate that there has been a gap between '
management awareness of ANSI N45.2.9 requirements and the i incorporation of these requirements into clearly understood and implemented procedures. When more adequate procedures i are prepared and effectively implemented, and the essential i calculation program'compl'eted, these' issues should be resolved.
s' l t.
) T 04770 (02/12/87)
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.3(B)
SPECIAL PROGRAM !
t REVISION NUMBER: 0 PAGE 18 0F 21 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:_
- a. 10CFR50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," Criterion XVII
- b. ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants"
- c. Regulatory Guide 1.88, " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records," R0, (08/74)
- d. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants" R,2, (06/76)
- e. ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants" I
r
- f. TVA Topical Report, TVA-TR75-1 A, " Quality Assurance Program i Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," R8, (04/09/85) 9 Sequoyah Nuclear Plant Quality Assurance Manual (SQN QAM)
SQN-QAP-III-1.3, " Preparation, Review and Records of Design Computations," R0 (03/08/70)
- h. EN DES-EP 1.14, " Engineering Records - Retention and Storage," R0 through R10, (05/13/83)
- 1. EN DES-EP 3.03, " Design Calculations," R0 through R8, <
1 (04/24/84)
- j. EN DES-EP-3.10 " Design Verification Methods and Performance of Design Verification," R7, (04/25/85)
- k. OEP-07," Calculations,"R0,(04/26/85) l
- 1. OEP-16, " Design Records Control," R0, (04/26/85)
- m. NEP-1.3, " Records Control," R0, (07/01/86)
- n. NEP-3.1, " Calculations," R0, (07/01/86)
- o. TVA memo from J. F. Weinhold to W. S. Raughley and D. W.
- Wilson, " Office of Engineering (0E) Engineering Assurance A Audit 86 Electrical Design Project (SQEP),"
(805 860428 005), (04/28/86) 04770 (02/12/87)
- p. .. ..
TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.3(B)
'SPECIAL PROGRAM REVISION NUMBER: 0 i
PAGE 19 0F 21 i
APPENDIX A (cont'd)
- p. TVA memo from J. F. Weinhold to D. W. Wilson, " Division of Nuclear Engineering (DNE) Engineering Assurance Audit 86 Sequoyah Electrical Calculation Restart Issue," .'
(B05 860916 001), (09/16/86)
- q. TVA Records Description Handbook, 1985
- r. Records. Schedule of the Office of Engineering Design and Construction, the Nuclear Safety Review Sta#f, and Office of Quality Assurance, (Draft) (R12030.10)
- s. Letter from D. G. Smith, INP0, to J. A. Coffey, TVA,
. transmitting INPO Evaluation of Bellefonte Construction Project,(06/05/84) ,
- t. ' Letter from 2. T. Pate, INP0, to H. G. Parris, TVA, transmitting INPO Evaluation of the Watts Bar Nuclear Plant Construction Project, (09/19/85) i u. Sargent and Lun'dy Final Report, "Sequoyah Nuclear Plant, Nuclear Plant Electrical Calculation Program Assessment,"
(04/08/86)
- v. Letter from J. M. Taylor, NRC, to 5. A. White, TVA, "NRC Report Nos. 60-327/86-27 and 50-328/86-27," (L44860506 542), (04/22/86)
- w. Letter #. ' J. M. Taylor, NRC, to S. A. White, TVA, "SQN Units 1 and 2, 6 ccurement Inspection, September 15-19, 1986, September 29-October 3, i996," ( A02 961023 019), (10/21/86)
- x. Letter from B. J. Youngblood, NRC, to S. A. White, TVA (B45 860714 832), with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee B 1k Building in Knoxville, TN (06/23/86)
- y. TVA memo from Beasley to Chandler, (805 851107 003) " Audit Deviation Report D51-A-84-0006-D01, Inadequate System to Ensure Calculations Are Updated to Support Design Changes Made After ,
Plant Operation," (11/07/85) {
l
- z. TVA memo from J. A. Kirkebo to Those Listed, (805 860307 006),
- " Design Calculations," (03/07/86) aa. TVA memo from W. C. Drotleff to Those Listed, (B44 860402 007),
" Design Basis Program for TVA Nuclear Plants," (04/08/86)
(
bb. Sequoyah Nuclear Plant Design Baseline and Verification i Program, R0, (05/01/86) 04770 (02/12/87)
C __
i TVA EMPLOYEE CONCERNS REPORT NUMBER: 205.3(B)
SPECIAL PROGRAM REVISION NUMBER: 0
'I PAGE 20 0F 21
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN 1HIS AREA?
- a. 10CFR50,_ Appendix B, Criterion XVII
- b. ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants"
- c. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- d. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
- e. Regulatory Guide 1.88, " Collection, and Maintenance of Nuclear Power Plant Quality Assurance Records," R0, (08/74) ,
l
- f. TVA Topical Report, TVA-TR75-1 A, " Quality Assurance Program
- Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," R8
- g. NEP-1.3, " Records Control," R0, (07/01/86)
- h. NEP-3.1, " Calculations," R0, (07/01/86)
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- b. Report of meetings in Knoxville and SQN site, August 27-29, 1986, BLT-043 (09/16/86)
- e. TTB-203 (01/14/87), (Response to RFI-768) j
- f. Teleconference between Clift, et al., TVA, and Dowd, Bechtel, (IOM441),(12/04/86)
- g. TTB-170 (12/11/86), (Response to RFI-752) 1 04770 (02/12/87)
'e : & '; ,._
', ; ,a
, iVAEMPLOYEECONCERNS REPORT NUMBER:- 205.3(B).'
SPECIAL PROGRAM-REVISION NUMBER: 'O.
<1
,f~
-l
~
PAGE 21 0F 21 1
i
< CATD LIST- .
The following CATD forms are included as part of this report::
205.03 -SQN 01 205.03.SQN.02-l 4 ,
h' b*
t 0477D (02/12/87)
=_ - _ _ -
- .. f.. ,
ECTG C.3 11 Attachment A J Page 1 of 1 !
Revision ? - A l 4, 1 ECSP COttECTIVE-Action Tractint Document (C&TD)
INITIATION
- 1. Imediate . corrective Action Required: O Yes a No
- 2. Stop Wort. Recomended: 'O Yes B No J
/
- 3. CATD No. 2093 SQM O/ 4 INITIATION DATE *E/ B7'
- 5. RESPONSIBLE. ORGANIZATION: D A/ E '
/
- 6. !
PROBLEM DESCRIPTION:'E QR -Q NJR Alub %&m M /-w (NEPs ) A%7 M !
Muwt so,c n 2. a & % W % v.24 M -" w % : '
&.nG.JA & A Jx.< A WMM&@m W '
m k %~}.& mmb A4nA m46_ - % e-f wal 4%W '
, t W% &C M A DME. .I '
- / F4 I O ATTACHF.ENTS
- 7. PREPARED BY: N A.". E . h A A-*rz/EfW WJ DATE: az/N/E7
- 8. CONCURRENCE: CEG-H VhL YlNM l/ _ _ _ . DATE: - 1.
. ' e.-F7
- 9. APPROVAL: ECTG PROGRAM MGR0 DATE:
I COR*ECTIVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
l i D ATTACHMENTS ,,,,
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
. 12. CONCURRENCE: CEG-H: t DATE:
SRP: DATE: ECTG PROGRAM MGR: DATE: _ VERIrtex;Iey App etOSEOUT
- 23. Approved corrective actions have been verified as satisfactorily inpIemented.
SIGNATURE TITLE DAIE
,__n_----.-._-_.--.--.a.
4 ECTG C 3 Attachment A I Page 1 of 1 g Revision 2 - A ECSP CORRECTIVE Action Tract. int Do c ume n_t, t (CATD) INITIATION
- 1. Immediate Corrective Action Required: O Tes B No
- 2. Stop Wort Recommended: O Tes E Wo
- 3. CATD No. e20f, 03 SQM C2. 4 INITIATION DATE' 8%/ 4/f7 //
- 5. RESPONSIBLE ORGANIZATION: 3) ale '
- 6. PROBLEM DESCRIPTION: 8 QR O NQR 7K % w. s+/Aa m M 7-e .mh &Tw M i; W@ .h M & d e- Mn
.fme_ "
& NGA & d"- % & & -a f
o N O ATTACMME/iT$
- 7. PREPARED BY: NAME MA# W W/ DATE: 02//a/p1
- 8. CONCURRENCE: CEG-H hE Id.N M HN DATE: 147-W
- 9. APFROVAL: ECTG PROGRAM MGR. " V DATE: _
( '- CORRECTIV! ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR: DATE:
- 12. CONCURRENCE: CEG-H:
DATE: _ SRP: DATE: ECTG PROGRAM MGR: DATE: VERIFICATI0*i AND CLOSE0VT
- 13. Approved corrective actions have been verified as satisfactorily
( implemented.
c c / .? i 870731 escra, erm:s a,vens.m:xr T . 2' 5 841 M can o rdu d am 'fENNESSEE VMEY d'rHOHn'Y TO : H. L. Abercrombie, Site Director, Seguoyah Nuclear Plant ONP FROM : W. R. Brown, Jr., Program Manager.-Employee Concerns Task Group. Watts Bar Nuclear Plant ONP DATE : ) Jul 3.119E
SUBJECT:
'SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS: TASK GROUP (ECTG)
ELEMENT REPORTS - ENGINEERING CATEGORY - CONCURRENCE WITH CORRECTIVE
. ACTION PLAN (CAP)'
Reference:
Memorandum from W. R. Brown, Jr.. to H. L. Abercrombie, dated July 30, 1987 (T25 870730 807), In referenced memo an error was made in CATD numbers listed. The ') numbers transmitted should have been: CATD 205.03-SQN-01 CATD 205.03-SQN-02 R1 . Please correct this in your files. f
. . , . . s 1 l
$/$$W'. R. Brown, Jr. .
GRM:KDH Attachments cc-(Attachments): ) RIMS, MR 4N 72A-C l J. L. McAnally, ONP, Watts Bar G. R.-McNuttr ECTG Blda, ONP, Watts Bar , R. C. Denney, DSC-P, Sequoyah .
]
l 1 l t, 6087T h a
m- !. - :) fy ., .' : ,
- f. i n..
, ihI p , 1. ;
- t.$CNT T25 S70730 807 M cm o ra n d itUl TENNESSEE VALLEY AUTilORITY l
d TO. : H. L.-Abe'rcremble.' Site Director, Sequoyah' Nuclear Plant ONP
'FROM . : W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, Watts Bar Nuclear Plant ONP DATE' :
.gg{ 3 g jgg7
SUBJECT:
.SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) i
' ELEMENT REPORTS - ENGINEERING CATEGORY - CONCURRENCE VITH CORRECTIVE ACTION PLAN-(CAP) J We have reviewed your response (CAP) to the following Corrective Action Tracking ~ Documents (CATD) and find them acceptable.
CATD=205.03-SQN-01 , CATD205.03-SQN-gel This CATD was revised in accordance with your, memorandum to me dated. July 10,.1987 (S03 870709 852). Please inform me when your corrective action is complete and you are ready for me to close out the CATD. j 4
# /*W." R. Brown, Jr..
GRM: RIM
\
g Attachments \ ' cc (Attachments): \ ; RIMS,-MR 4N 72A-C J. L. McAnally, ONP, Watts Bar G. R. McNutt, ECTG Bldg, ONP, Watts Bar R. C. Denney, DSC-P, Sequoyah i 4 6028T p i
~
n.
,~-
8ioygy U I O, 99, ; BechteLWestern Power Corporation
' E s.tpim',,- brCruC; ort fihy beate Street - ,2 _
l San Francisco. Cauom.a Mad Acoress PO boa 3955.1.an Francxc CA 94nk ~ July 23, 1987 BLT-310 p-Mr. George R. McNutt , l L Engineering.CEB-H Tennessee Valley; Authority i Knoxville, Tennessee 37902 l . . , l' .
Subject:
Watts Bar Nuclear Plant Employee Concerns Evaluat. ion Program
. Tennessee Valley Authority Job No. 16985-026 . ;;
-CATD 205~03 SON 01, 205 03 SON 02
Dear Mr. McNutt:
- In the CAP for CATD 205 03 SQN 01, as transmitted by TCAB-085 dated 04/02/87, TVA has committed to writing a lower tier procedure to supplement the . Nuclear
- Engineering Procedures (NEP) that control calculation records. This procedure i
will be a Sequoyah Engineering Project (SQEP) Administrative Instruction (AI) L that will address the following topics in more detail. . p
- 1. Collection, filing and storage requirements for. completed or approved calculations
- 2. Schedule requirements for. the routine microfilming of approved calculations i
- 3. Definition of -a final calculation.
This CAP for CATD 205-03-SQN 01 is acceptable as written. Also included in TCAB-085 is a-CAP for CATD 205 03 SQN 02. This CAP for CATD 205 03.SQN 02 is not acceptable to the Evaluation tegm. Subsequently, TCAB-099 dated 07/14/87 transmitted a revised CAP for CATD 205 03 SQN 02. The CAP places additional management emphasis on the implementation of the engineering discipline's calculation program by the following: .
- 1. The audits performed by Engineering Assurance (EA) of calculations
- 2. Training in accordance with Nuclear Engineering Procedure (NEP) 1.2,
" Training,"
i-----._..__.--.--.-.
+ ,
Mr. G. R. McNutt July 23, 1937 Page 2
- 3. Implementation of Sequoyah Engineering Procedure (SQEP)
Administrative Instruction (A1) 10, " Processing and Control of Calculations," as the means to enforcement of requirements for the retention, storage, and retrieval of design calculations. The aforementioned CAP for CATD 205 03 SQN 01 as transmitted by TCAB-085 and the CAP for CATD 205 03 SQN 02 as transmitted by TCAB-099 are acceptable to the Evaluation Team and will be incorporated into the subcategory report. Very truly yours,
\
M G. L. Parkinson Project Manager
\^
\ GLP/wo Attachment (s)
Written Response Req. 7 /27 / 87--GRM:RMW cc: RIMS, MR 4N 72A-C ' D. T. Clift, 9-162 SB-K km e G 3130D-R0
7% a 64 (05+45) (OMSS 85)
.estn:o cna covtn:o:csr T41 870330 g,3 TENNESSEE VALLEY AUTHORITY
) # em O 7dn d MTR l
TO : W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, Watts Bar Nuclear Plant ONP FROM : James L. McAnally, Corrective Action Program Manager, Watts Bar Nuclear Plant,0NP DATE : 3-y_g]
SUBJECT:
WATTS BAR NUCLEAR PLANT (WBN) - TRANSMITTAL OF ECSP CORRECTIVE ACTION TRACKING DOCUMENT (S) (CATO) 4 ECSP Fact Sheet Number: JOTO3 ECSP CATD(s) Numbers : #c sm 3 3 0 A/ O/ J nsn* SC/U O2 The above listed, completed CATD(s) are being returned according to your instructions. _ l
, (
James L. McAnally JLMc:NLC Attachments cc (Attachments): RIMS, MR 42 72A-C, p,gcgggp MAR 31'87 / Etto!cyc7 0:ncems Task G*oup WBN pecne!aten Rev
- i. 4YRb 4 tms >m WBEP-2286d r"# '
2/6/87 N.
.m
- 4CO
' 'MC l t t
. (?
VW 4 i
. t:4 iOA
- >EN
(,s : ,.
, . . x, , ,
p 990* 6 { p 1246 i i N- 3 I I f y 8 C !
' 54 "
. :: ... .si /
2 _-. _ - _ _ _ _ . _ _ _ _ . .
s
,y.........., SOS 870827'811 k
TNrTr:n .TATns Govt:l:NMUNT l
-M em oran d um TExxEsses vatter Aurnon1Tv J. L. McAnally, Corrective Action Program Manager, OhP, A108 108, To .
Watts Bar Nuclear Plant- j PROM : H. L. Abercrombie, Site Director OLPS-4 Sequoyah Nuclear Plant- ) 1 DATE :- March 27. 1987 SUDJECT: SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROU REPORT 205.03 SQN - ENGINEERING CATEGORY -' CORRECTIVE ACTION PL
Reference:
W. .. R Brown, Jr.'s memorandum to you dated February 19, 1987,
" Report 205.3(B) (Draft) and Non-Restart Justification Summary" (T25 870219 993)
I-acknowledge receipt of ECTG's element report and in:accordance with their request (see reference), Element Report 205.03 SQN has been reviewed for applicable corrective action. , By way of this memorandum I am endorsing the site line organization CAP, returning Corrective Action Tracking Document Nos. 205.03 SQN 01, and 205.03 SQN 02, and attaching the CAP for review / concurrence. This CAP is not a restart requirement. I If you agree with the proposed CAP, please hav'e ECTG sign the ECTG concurrence space below item 9 on the CAP tracking checklist and return the CAP tracking checklist.
/ h '
H. L. A ercrombie f RCD:JDS:JB:TC '~ Attachments cc: RIMS, MR AN 72A-C (B25 '870324 007) W. R. Brown, Jr. , ONP, Watts Bar (Attachments) 0587T l L.
.ke d' 'N, s ', .
L- q. EC G C.3 Attac hment' A Pate 1 of 1 1 Invision 2 - A ECOP CORREC"!VE Actie T: ac tint Document (CATO)
'INITIAT!ON
~
- 1. Ic=ediate Corrective Action Required: D Yes ~ G .No
- 2. Stop Wort Reconnended: 0-Yes G No -/
- 3. CAID No. 2.o fo3 50d 'o/- 4 INITIATION DATE of //t. 87 b ^/ E 1
- 5. RESPONSIBLE ORGANIZATION: '-/
- 6. PROBLEM DESCRIPTION:.Q QR O MpR h)A %Lm 1%. 4 j (NEPs) W m
. 4. . p = nm ~J,. a a 4 ~ ~ cG, p K e-.f.e a-m m:
et.C>[ A & M h MM /* M - j n & L.te.. t -- - h %. jim w m A *cG iM M ~
~
e" wnL AM
- s. D:4 4 -~/ L. M A M == l I ne, i O AT ACHMENTS W
- 7. PREPARED E!: NA?.E FC A M & DATE: ot //r/?7
- 8. CONCURRENCE: CEG-H Vb L YlMM ll DATE: t-vi-5'1
- 9. APPROVAL: ECTG PROGFa MGR0 -frash< w ' W. DATE: 2-/9-97 CDP.?EC IVE ACTION
- 10. PROPOSED CORRECTIVE ACTION PLAN: #M WF' b ""//I/M // TIM G t' /df/fuVA!P&i - 6~2C 9*? o ?,24 00~7 - i l
i 3 .
, O A- ACMMEN 5
- 11. PROPOSED BY: DIRECTOR /M R: #4 4A /,C DATE: ?-1 >- M
- 12. CONCURRENCE: CIG-H: /2A We#" DATE: 7- 2.'7 -F'? =
SRP: #A// 4 , DATE: l EC G PROG?.AM MGR: #/MM. BATE: "'/ M /8 l
/ // 1 V E ? ! T I C ATIO$l ASO f.LOS EOL*- l
. l
- 13. Ap reved corrective actions have been verified as satisfactorily )
implemented. l
.- 1 1
5:GNATURE IIILE DAII
e i s .c. . , , >
. j v
x ,1 l ECTG C.3 1 Attacraent.A-Page 1.cf 1 Revision 2 - A-s ECSP COEREC"!VE' Aetlee Trac tinr_ Document (CATD)-
.1 INITIATION 4 i
- 1. Imediate Corrective Action Required: D 'Tes B N o -- .
'2. Stop Wort Recomendec: O Tes a No _
/
- 3. CATD No. ~ dof. 03 SDM O1 4 . INITIATION DATE- **E //f f 7
- 5. RESPONSIBLE ORGANIZATION: 'M Al E (
- 6. ' PROBLEM DESCRIPTION: E QR O NQR j 7 _ u w w ,- ~, - ]
pg, - - ;;f wm A _ . n m. Q7- ;j W~~ # *
' M zir_ n ~ n ~
Ay Q_ MQ ' 0 &c w ' e ? ' ^ - 5= i o n ,, ' O A~~1CF.MEJiTS >l
- 7. PREPARED SY: NAS.E PA 9. W W e - DATE ~ o:/4./r?
- 8. CONCURRENCE: CEG-H ht rd M M UA/ DATE:' t 47 -T'?
9., APPROVAL: ECTG PROGPa MGR,6 (16'e-seeo# V % DATE: _ #-/ 9-# 7 CORREC~ VE ACTION
- 10. PROPOSED CORRECTIVE ACTION PIM: TE2= r7s F meme ;
- AW ,JfTM.'.coubt'M & 2T67 0 3 Ut/ 0 O *9 !
, ..j l
O A~TACHw.ENTS 4*' /# /X A / 4 DATE: 3'-JJ ,A 7
- 11. PROPOSED EY: /
DIP.ECTOR/.GR:
- 12. gl' CONCURRENCE: CEG-H: M Nfh r/?sf' ' DATE: 7/27/f7 SRP: 'N/ /J- , ,/ DATE: / ,
g ECTO PROGPM MGR: // //f'd'io /e's DATE: 7/ J- 7/6 7. V A.5 N4/'N d by 503 8' 7 0 7c.s 9 g.t 2, (Jg /4,,4J VERIFICATION AliD CLO!!OUT
- . 13. Approved corrective actices have been verified as satisfactorily i.::pl erne n t e c . .
I*GNATURE IITLE DA!E
l; -i
,..;c y I Standard Practice Page 8 l SQA166 i Revi::icn B
[ (y'
' Attachment A j Page 1 of 2 i CorrectiveActionPlanofEmplohee.ConcernInvestigation Tracking Checklist ECTG Report /CATD Humber_2 FI 0 3 N M A*D # M*I'0 3 SN T
~ Lead Organization Responsible for Corrective Action Plan DNF l Initiation Date I', "Z o - 5' ~7 j
CCRRECTIVE ACTICN PLAN (CAP)
- 1. Does this report require corrective action? Yes [ No (If yes, describe corrective action to be taken, if 'no, provide justification)!
SMA /n'YAdH//?Mt' f- - l , . l
- 2. Identify a imilar item / instances and corrective action taken. !
t (' ( 3. Will corrective action preclude recurrence of findings? Yes _ # No
- 4. Does this report contain findings that are conditions adverse to quality (CAQ)l as defined by AI-12 or HIP 9.17 YES Uc /
- 5. IP a CAQ ion exists, what CAQ document was initiated?
- 6. Which site sec ' n/organi:3 tion is responsible for corrective action?
/) $ frJAV AbstwjfX4/79W 4A-/Jos )
- 7. Is corfectivp' action required for restart? Yes No / !
(This determination is to be made using Attachment C of SQA166.)
- 8. P2 :ene number for restart corrective action? Zone
- 9. Estimate completien date or correcti q action. lu g O/ /93-/
Completed By - ( & \ M Date 47 4/87 -l Approved By ~rAA Y.Wfdk.d/fx , Date S!24 V89 k g:CTGConcurrenee // p w ; fe'A T W Date % 27.- P 7 ] h5 YW d< ~50.9 970.f C9 f3 2 $$Y l I 0206S/mit l
. . w, h; , ; .
y p, s ATTACHMENT 1 CORRECTIVE ACTION PLAN FOR CATD No. 205.03-SQN -01 L - A lowerLtier procedure vill be written to supplement i;he Nuclear: i i Engineering Procedures (NEP) that control. calculation records. 'This-procedure will be. a ' Sequoyah Engineering ~ Project (SQEP) Administrative Instruction .(AI). that will address the' f ollowing topics in more detail. . i
- 1. . Collection f11ing and' storage requirements for completed .or - approved ;
calculations -
- 2. Schedule' requirements for. the routine microfilming of approved calculations ,- . ,
1 i
- 3. Definition of a_ final calculation
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CORRECTIVE ACTION PLAN FOR CATD NO. 205.03-SQN-02 ' l _ _
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The'SQEP Al addressed in the corrective action plan of CATD I g. No. 205.03-SQN-01 will'" resolve this problem. ww-4 t. t l ' DE02;KC7 002. 01 SQ EP - Mar. ~ 24, 19 87 1
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CN I'l 1:D STATl;S GOVI;HNN1:NT g;g g . , ,. , M c22202ciild uaii TENNESSEE Al[EY NIOlilTY 4
'D Program ManaSce,' Employee Concerns Task' Croup, ONP, W. R. Brown. Jr.
Watts Bar Nuclear Plant FHUM H. Li Abercrombie, Site Director, O&PS-4, Sequoyah Nuclear Plant l -- DATc : July 10, 1987 SenJECT: SEQUOYAH NUCLEAR PLANT (SQN) -. EMPLOYEE CONCERNS TASK GROUP (ECTC) ELEMENT REPORT 205.03 SQN - ENGINEERING CATEGORY - CORRECTIVE ACTION PLAN (CAP) REVISION-Roference: My memo to J. L. McAnally dated March 27, 1987 "Sequoyah Nuclear Plant (SQN) - Employee Concerns Task Group (ECTG) Element Report 205.03 SQN - Engineering Category - Corrective Action Plan.(CAP)" (SO3 870327 811) I ! " Attached is my revised CAP for Element Report 205.03 SQN, Corrective ~
' Action Tracking Document No. 205.03-SQN-02, for your review / concurrence.
L This revised CAP supersedes the CAP previously transmitted to you (see reference) and is not a restart requirement. If you agree with the proposed CAP, please sign the ECTG concurrence space below item 9 on the CAP tracking checklist previously provided and
- return the CAP tracking checklist.
Yhk 4 H. L. Abercrombie RCD:JDS:JB:VMC Attachment ec: (Attachment) RIMS, MR AN 72A-C (RE: B25 870629 013) i c ^Er.,'ED J. L. McAnnally, A108 IOB, Watts Bar JA 1.. 'U';7. / 0902T F,7 p;,;: . .:n:, . :.. ~w<
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' REVISED CORRECTIVE ACTION PLAN FOR CATD. NO. 205.03-SQN-02 There is direct evidence that suf ficient management attention has been placed on engineering practices and to enf orcement..of requirements for the -
retention, storage,' and retrieval of design calculations. This evidence can be witnessed by the emphasis placed on the implementation of the engineering discipline's calculation program, by the audits performed.by Engineering Assurance (EA) of calculations, by training in accordance.with Nuclear Engineering Procedure '_(NEP) 1.2, "Iraining " and by the implementation of Sequoyah Engineering Procedure'(SQEP) Administrative Instructica (AI) 10. " Processing and Control of Calculations."- 1 L 1 l i l t i l i 1 ~ ! (. l 1 I i l t. l-1 + 1 DE02;VL7163.01 l SQEP June 15, 1987 1
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}Mcmorand ton TENNESSEE VALLEY AUTHORITY R To : W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant H. L.~Abercrombie, Site Director ONP,'OrmPS-4= Sequoyah Nuclear Plant' FROM i DATE: : December'19, 1986-SUDJECT: SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) -
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' ENGINEERING CATEGORY REPORTS - NONRESTART JUSTIFICATION CONCURRENCE ;. r
- ~~7oferences: 1. Your memorandum to me dated December 4, 1986, " Watts Bar'
- RECEIV ED ' Nuclear Plant - Employee Concerns Task Group -
Engineering Category Concerns'- Review of Elements to 1
.DEC1 f 8,D Determine if They are Restart Items" (T25 861204 942) i 1
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Emo% g 2. Your memorandum to me. dated December 5, 1986,'" Watts Bar
'_ g ggi .- . --as Nuclear Plant - EmployeeLConcerns Task Group -
,_ - ite A-.on t Sesv- Engineering Category Concerns - Review of Elements to 1' gg;--- -- Determine if-They are Restart Items" (T25 861205 954) l Your memorandum to me dated December 8'1986, " Watts Bar- I
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Nuclear Plant'- Employee Concerns Task Group - .I
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Engineering Category Concerns - Review of Elements to-h-]'.
,b y ',- -~~ Determine if They are Res. tart Items" (T25 861208 970)-
__ 4. Your memorandum to'me da'ted December 8, 1986, " Watts Bar Nuclear Plant - Employee Concerns Task Group - g'c -I --- Engineering Category. Concerns - Review of Element's' to Determine if They are Restart Items" (T25 861208 972) l. is
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Iny @ Ac., m it-In response to your requests (see above references), the following element report nonrestart justifications have been reviewed. I concur that these reports are not required for restart: 241.3 204.2 204.5 204.8 201.6 R1 207.3 R1 232.9 204.3 204.6 204.9. 203.2 R2 207.4 R1 < 204.1 204.4 204.7 204.11 205.3 R1 229.5 R3
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%-H.L.Abercrombie RCD:JDS:JB:CS cc:- RIMS, MR 4N 72A-C (B25 '861211 001, B25861211 004, B25 '861215 020, B25 '861215 021, B25 '861215 025, B25 '861216 021) ]
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