IR 05000237/1992030

Enforcement Conference Repts 50-237/92-30 & 50-249/92-30 on 921023.Areas Discussed:Apparent Violation & Areas of Concern During Insp & Corrective Actions Taken or Planned by Licensee

ML17179A585
Person / Time
Site:	Dresden
Issue date:	11/19/1992
From:	Darrin Butler, Gardner R, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17179A584	List: IR 05000237/1992030 ML17179A582
References
50-237-92-30-EC, 50-249-92-30, NUDOCS 9211240173
Download: ML17179A585 (27)

Text

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No.* * 50-237/92030(DRS); N ~249/92030(DRS)

Docket Nos. 50-237 ;* 50-249 Licehses No.. DPR-19; No. DPR-25 Licensee:

Commonwealth Edison Compan Opus West III 1400 opus Place.*

.Downers Grove, IL 6Q515

.Meeting Conducted:

Octobe.r 23, 1992 Mdeting At:

Region III Office, Glen Ellyn; Illinois Type of Meeting:

Enforcement *conference

. Inspection Conducted:

Onsite - July 20 through October 2, 1992 Inspe<?tors:

Reviewed By:.

Approved By:

D. s. Butler R. N. Gardner, Chief*

Plant Systems Section

~. A* Ring, Chief En'irieering Branch*

Meeting Summary Enforcement Conference on October 23, 1992 (Reports N * 50-237/92030CDRS); No. 50-249/92030CDRS))

/I /tc; /7;i_...

Date 11 J 11 fr,,-z, Date I; (r * i /:*; ;.-

Date*

Areas Discussed:* *A review of an apparent violation and areas of concern identified during the inspection, and corrective actions taken or planned by the license The enf.orcement options...

pertaining to*the apparent violation were.also.discussed with the license The-apparent violation was considered a deficiency in the corrective action program regarding the failure to rec6gnize and promptly address a situation where selected safety* relat_ed equipment would be inoperable under degraded voltage conditions.

9211240173 921119 PDR. ADOCK 05000237

PDR

• *

Persons Present at Conference Comm~nwealth Edison Company (CECo)

D. Galle, Vice President, BWR Operations L. DelGeorge, Vice President, Engineering and Construct.ion (ENC)

• *

K. Graesser, General Manager., BWR Operations G. Wagner, Manager, Nuclear Engineering Department (NED)

M. Reed, Super~interident, Electrical, Instrumentation and Control Design, NED B. Rybak, Superintendent, Mechanical and Structural Design, NED

.

.

.*

s. Berg, Technical Staff Supervisor,* Dresden R. Radtke, * Regulator*y Assurance Supervisor,. Dresden B. Viehl, NED Site Supervisor, Dresden D. Taylor, ENC Regulatory. Assurance Supervi~or P. Barnes, Compliance supervisor, NQclear Licensing Department (NLD)

J. G~tes~ Assistant Technical Staff Supervisor, Dresden J. Wethington, Assistant Technicai Staff Supervisor, Quad Citi~s

M. Tuckerr. Senior El~ctrical Design Engineer (NED)

• G. Eckert, Ceneral Engineer, Dresden K. Ramsden, R~actor Systems Engineer, Nuclear Fuels Services J. Bauer, Regulatory Assurance, ENC

.B.: Adams, RegUl~tory Assurance, ENC E. White, Regulatory Assurance, ENC, P. Piet, Nuclear Licensing Administrator, NL J. Watson, Nuclear Licensing, NLD s. Trubatch, Counselor,. Winston and Strawn ~organ, Station Partner, Dresden U~ S. Nuclear Regulatory Commission, Region III (RIII)

B. Davis, Regional Administrator, RIII

.H. Miller, Director; Division of Reactor Safety (DRS), RIII T. Martin, Deputy Director, DRS, RIII

. DeFayett~, Director, Enforcement and Investigation Codrdination Staff, RIII

• J. Lieberman, Directot) Office of Enforcement

• B. Siegel, Dresdert Project Manager, Office of Nuclea~

• Reactor Regulation

.

B. Clayton, Chief, Branch 1, Division of Reactor Projects (DRP), RIII R: Gardner, Chief, Plant systems Section, DRS, RIII R. Knop, Chief, Section lB, DRP, RIII

.

. M. Jorqan,.Operator Licensing Section 1, DRS, RIII P. Pelke, *Enforcement Specialist, RIII

z. Falevi ts, Reactor Inspector, * DRS, RIII w. Scott, Reactor Inspector,*oRS, RIII o. Butler, Reactor Inspector, DRS, RIII

.M~ Peck, Resident Inspector, Dresden Station

• Denotes those who participated v{a telephon Illinois Department of Nuclear Safety CIDNS)

o. Lyons, Nuclear Safety Engineer* Enforcement Conference An enforcement conference was *held in the N,RC Region III office on October 23, 199 This.conference was conducted as a result of the preliminary findings of the inspection conducted July 20 through October 2,* 1992, in. which an apparent violation of NRC regulations was identifie Inspection findings are documented in Inspection Reports No..

50-237/92021(DRS) and N ~249/92021(DRS), transmitted to the licensee by letter dated October 9, i99 A copy of th licensee's slid~ presentation is attached to this repor The purpose of this conference was to (1) discuss the apparerit violation, causes, and the licensee's corrective action&; (2) discuss several areas of concern; (3) detetmine if there were any escalating or mitigating circum~tances; and (4). obtain any information which would help determine the appropriate enforcement action*.

At *the conclusion of

• .the meeting,* the licensee was informed that they would be

• notified in the near future of the final enforcement actio During the enforcement conference, the licensee presented evidence that demonstrated their engineering staff responded

• in a reasonable manner when they reviewed the Dresden. ELMS-AC calculation. * The calculation identified the potential for 460 volt motors to be operated at less than 90% of* rated voltage during.certain offsite power contingencie This.

deviated from the NEMA motor standard which recommended that

. motors should not be operated below 90% of rated voltage.*

Additional information was presented that demonstrated a direct correlation did not exist between the ELMS-AC calculation resufts and its potential ef iect on th~

Technical Specification degraded*voltage setpoin The licensee's engineers recognized that less than 90% of rated voltage at a running motor's terminals could be a problem, but assumed adequate system protection would be provided by the degraded voltage relays.. The licensee stated there was nothing specifically in the ELMS-AC calculation that would call into question the degraded voltage setpoin Finally,

information was presented that reasonably demonstrated the original degraded voltage setpoint, which was set too low, had minimal safety impact on the safe operation of the Dresden Statio The licensee acknowledged, during tl)e*enforcement conference, that improvements could be made in engineering's ability to promptly identify and evaluate conditions adverse to qu~lit As part of the lic~nsee's corrective actions,*

Engineering and Nuclear Construction (ENC) was implementing an Integrated-Reporting Program (!RP) to formalize the identification, documentation, tracking, and resolution of potential conditions adverse to qualit Deviations or design concerns will be documented on Problem Identif i6~tion Forms *(PIFs).

The PIFs will be reviewed by the appropriate ENC design supervisor, screened for safety sigrtificartce, an transmitted to th* applicable st~tion along with planned *

corrective actions; If the cbgnizant supervisor determines the issu~ is an operability concern, Procedure ENC QE 40.l,

"Operability Evaluations," will be entered and an operability evaluation will be performed*

Actions required to resoive the PIF conc~rn will be tracked to completion using the Nuclear *Tracking syste The.NRC reviewed the information presented during. the enforcement conference and concluded the licensee had not.

violated 10 CFR.50, Appendix B, Criterion xVI, "Corrective*

Action. 1'

. This item (237 /92021-01 (DRS); 249/92021-01 (DRS))

is.considered close Attachment:

As stated

.. _ *.

OCTOBER 23, 1992.

DRESDEN STATION ENFORCEMENT CONFERENCE UNTIMELYCORRECTIVE ACTIONS REGARDING DEGRADED VOLTAG INTRODUCTION CHRONOLOGY/

. SAFETY SIGNIFICANCE

.AGENDA ACTIONS TAKEN AND PLANNED

• CLOSING

- 1 -

LO. DELGEORGE M.L. RE~D D.L. TAYLOR LO. DELGEORGE

..

.*

• 1NTRODUCTION. (Continued).

1. What analysis was performed upon receiving the S&L calculation to assure that the problem of degraded voltage did not adversely affect operability?*

ANSWER - On November 19, 1990, S&L transmitted

. to CECo corporate engineerinQ (NED) the Dresden Unit 3 BOP ELMS-AC calculation. S&L reported a few cases of bus voltage below allowable, and requested review of conservative assumptions that were thought to have produced the problem. NED*

concluded, based on a preliminary engineering

. review, that the calculation results were invalid *

because the assumptions made were inconsistent

. with known plant conditions. NED sponsored a meeting on December 5, 1990 with S&L, Dresden; and CECo System Planning technical personnel to discuss the BOP ELMS calculation and the *

.

preliminary conclusion concerning its validity.. At that meeting, it was confirmed that actual plant conditions*

were less severe than assumed by S&L. *

Actions were thereafter assigned to specific CECo reviewers, including NED and Station personnel, to conduct a formal review of the calculation, and to correct invalid input assumptions. That review is documented in correspondence between D~cember *

5, 1990 and May, 199 The adequacy of the second level undervoltage relay.

setpointwas questioned by the NRC team conducting*the Quad Cities EDSFI. At that time, CECo indicated it would complete a review of this

• issu Although documented as an unresolved item by the Quad Cities EDSFI team, the NRC did not question

. the CE Co completion sc~edule, pr~vided in response to the EDSFI Report, which would include

consideration of' new issues presented in Information Notice 91-29 (dated April 15, 1991, which

. *.

documented NRC's lessons learned from recent

• EDSFl's).

• - 3 -

'.

K.

• INTRODUCTION (Continued)

• -Response to Question 1 (Continued)

Although the documentary record of the CECo review from November 19 to December 5, 1990 is admittedly

_ superficial, and the period of the review appears

. untimely, the minimal significance attached to the calculation that raised the issue. justified its treatment

• * in the manner described. (See response to Question 2 concerning record requirements).

lA chronology and summary of the actions indicated

• m this response are discussed in the accompanying presentation on "Chronology *

..

.

.

2. * Why wasn't the potential degraded. condition tracked as a deficiency or potential condition adverse to quality requiring corrective ~ctions under the quality _.

assurance program?

ANSWER - The-CECo Program in November, 1990

-* required the identification reporting, and documentation of significant defjcj_encies or deviations. In addition, the NED operability

. procedure QE 40.1-introduced in October, 1990 required formal documentation only for valid

• concerns thou~ht, with reasonable assurance, _to impactoperab1lity and/or require reporting to the NR...

Because the initial CE Co review of the Dresden

• ELMS calculation in November, 1990 concluded that the calculation was invalid due to overly conservative *

assumptions, neither a significant deficiency nor an

.

operability concern was thought to exist.-. Therefore, formal documentation and tracking was not imposed...

However, as stated in response to Question 1, the issue was recorded contemporaneously.and these-non-proceduralized records demonstrate continuous*

progress toward resoluti~n of the issu *

_

The responses to Questions 3 and 4 discuss the continuous refinement that CECo's process for managing conditions adverse to quality has undergone since August, 199,

-. 4 -

. '.

INTRODUCTION (Continued).*

3. What steps will be taken to assure that other identified deviations from standards will be promptly evaluated for potential* impact on operability and

. *

resolved in a timely manner?.

ANSWER -As indicated in response to Questions 1

_

and 2, it is judged that the issue that is the subject of this enforcement action was treated adequately, though specific weaknesses in the timing of actions and of the records produced for actions taken are admitted. It should be noted, however, that significant improvements in the CECo process for * *

handling conditions adverse to quality were initiated *

in August, 1990 with the initial development of NED Procedure OE 40.1 "Operability Evaluations"..

.

. Subsequently, OE 40.1 procedure enhancements.

. and personnel training have enhanced the *

identification, reporting, and documentation of technical concerns that can effect equipment..

. operability~*

• In addition, a formal interface agreement has been developed and will, when fully implemented in November~ 1992, ensure timely and consistent notification of station management when such.**

• . conditions are identified. These processes are being.

integrated, as a result of actions begun ln June, 1992, into the formal CECo Integrated Reporting Program*

( IRP) which will be fully implemented by ENC at all.

six CECo stations and our corporate offices by

December 31, 199.

. *

.

.

..

[These developments are discussed fully in the

. accompanying presentation on "Actions Taken and

• Planned"].

• *

- 5 -

. -*

.*

INTRODUCTION (Continued)*.

4. At what point will NED notify a* station of a potential**.

condition adverse to qu~lity?. *

ANSWER -As indicated in response to Question 3, the ENC *

IRP program will be implemented by December 31, 199 As part of this program, identified deviations or design * *

concerns are documented.on Problem Identification Forms

• (PIFs). After appropriate ENC Supervisory Review, the

PIF, with planned actions for closure, is transmitted to the

• Station IRP Program for informatio * *

The response to Question 3 also cited the ENC/Station Interface Agreements which are being formalized to

• • establish points of contact for the communication of operability information. The following communications are

. expected to occur during an issue's review for operability:

~ During the supervisory review of PIFs, a judgement may *

be made that the issue in question has the potential to *

• *impact operability. At the discretion of the Supervisor, a

. courtesy call may b_e made to the Statio. *

. *

..

.

.

.

-

.

- A call notifying the Station that an* operability evaluation is

- being performed of an issue. *

. - A call notifying the Station of.the results of an operability evaluation.

- 6 -

...

CHRONOLOGY

• Late 1960's Original plant design did not include detailed power flow

• analysis.* Power flow analysis computer program tools had not been developed for distribution systems analysi *.

Engineers designed systems using generally accepted industry practices with hand calculations down to the 480 V switchgear level based on past design experienc L~e

.*

.*

1970's Degraded Grid Voltage identified as issue by the NRC. *

Early

• 1980's CECo provides NRC ~lectrical distributi?n system v~ltages *

down to the 480 V switchgear level, noting that bus voltage

. slightly less than 90°/o was adequate, based on assumed *

conservatisms in the voltage drop calculation..

.

.

.

.

.

.

NRC issues SER and Tech_ Spec amendm.ent for degraded voltage rel_ay setpoints.

• .

Ma. S&L developed Electrical Load Monitoring System

July

. (ELMS). The ELMS computer model was developed to establish an inteQ~ated data base of the 480V.and 4KV loads on the aux1hary power systems. ELMS 1s a tool used

. in controlling loads on switchgear and MCCs..

• 1988 ELMS model was created for the emergency diesel generator safety-related load *

No NRC SER and Tech Spec amendment issued for the 4 KV loss of voltage and degraded voltag~ relay *

March 1990

• S&L Load Study SL4544 concluded the normal running bus voltages were acceptable based on field.

.

measurement BOP ELMS created to model all safety and non-safety related loads. (See graphic on following page).

- 7 -

-**

cp X \\llNDIN *

~

SVGR 33

4. 16 KV

ELMS BOP

. ')..

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. )

.

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~

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4. 16 KV

~

ICC 38-7 ~)

480 v c KV 34SKV sv.

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~

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4-.16 KV

. 4. 16 KV

-~

.

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.

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~ c S\\IGR 31 ')

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.

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ICC~ I)

-~

ice :18-1,>

. 480 v 480 v 480 v KV

~-.

. ICC 311-1 ')

480 v

t **

~*******

.

.

CHRONOLOGY.(Continued)

. 11119/90. The Dresden Unit 3 ELMS-AC calculation was *

transmitted by S&L to CECo for review and* *

comment. S&L identified the following:

.

.

.

• *. "... calculation results also indicate that in a *

few cases, the* bus voltages are below.

.

• 90°/o... It is possible that the above results are - *

• due to conservatisms used in determining the loading calculations ~.. Assumptions... require verification."

11/19/90-

.

..

1 *2104/90 CECo began a review of the calculations and

• . arranged meetings with S&L to discuss the

. * concerns identified. The preliminary

.

engineering review indicated the calculation result to be invalid due to overconservatisms..

12105/90. Meeting to discuss ELMS~AC assumptions~ *

• CECo confirmed that the calculation results were invalid based on:

• - _Use of assumptions requiring owner verification.*

• . Transformer load was t15°/o of rated load *

- Calculated total al:ix power *1oad (at 100°/o

• * power operation) exceeded actual observed power by 40°/o. *

CEco* concluded that the results reflected overconservatisms and not actual design deficiencies. Actions were assigned to NED. *

and the station to verify assumption At this point there was no reason to qLJestion.

the adequacy of th~ approved second level*

undervC?ltage setpomt. *. *. *

.

- 8 -

...

CHRONOLOGY (Continued)

• * *

• . 02/06/91 Followup letter from BWR Projects Supervisor

to action parties (NED Departments and. *.

......

'

'

• . Station) requesting specific review and

. *comments on the ELMS-AC calculation.:

04/01 /91-.. *

• 05/10/91 * NRC EDSFI at' Quad Cities. NRC initial

. review of ELMS-AC calculation.. CE Co

. provided written information to the NRC o the overconservative assumptions and the

• ongoing review to provide more accurate dat In addition, the NRC team questioned the *

degraded voltage relay setpoint. CECo. *

committed to review the issue. The NRC *

documented an unresolved item pending further analysis by CEC,

04/29/91 CECo received IN 91-29 "Deficiencies During *

• Electrical Distribution Sy$tem Functional *

Inspections" which addressed the issue of 07/08/91-

• inadequate setpoints. The IN was distributed *

to the Electrical & Instrumental Control Department for review With a response date of

'8/27/9 /09/91 NRC EDSFI at Dresden. During the NRC's review.of the ELMS-AC calculation,.CECo cited the deficiencies in the calculation.

. The NRC requested CECo to provide the *

existing calculation supporting the second

. level undervoltage setpoin *

Because that calculation assumed a voltage drop of 3°/o from the bus to the device, the.

NRC requested CECo to perform a calculation showing the adequacy of the secondary undervoltage setpoin.

'

- 9 - '

'

~* :**--

__ :<--

_CHRONOLOGY (Continued)

07/31/91 _ By using a methodology differ~nt from BOP ELMS, CECo determined that the actual voltage drop from the bus to the device was 5-6°/o. Since 3°/o voltage drop had been

-

assumed in the 1982 setpoint calculation,

_

device terminal voltage is not assured at the relay setpoint. (See graphic on following page).

- 08101 /91 Compensatory measures were.promptly implemented following identification of the.

potential voltage degradatio '- -

- 10 -.

.*

DEGRADED VOLTAGE CALC~

i'

SIJGRJJ-1

• 4 '. 16 KV 4. 16 KV

~~~~*kV.

. ~%Z

• l,8.3. X/R

__.....,.~4_B_o_v __ s_w_1.1_c __

H_G_E_A_R_.., ______....

_"G-R3_a ____...... __ ')

.

')*

')*

I

• I

• I MCC 38-7 {

I I) 48*0V. MCC HCC 3B-~.) * *

I

..

l~SOV.MCC MOTOR Representative Equipment

J

'

.* '

SUMMARY 1. ELMS is a tool used in controlling loads on switchgear and MCC * : 2. The BOP ELMS-AC calculations.could not be relied*

upon because they were inconsistent with known*

_ *

plant loading. Reviews of the assumptions by CECo -.

engineering management reinforced the position that the calculation results reflected. overconservatisms

. and not actual design deficiencies..

..

.

3. The CE Co reviews initiated to evaluate the 11 /19/90 concerns would not likely have led CECo to the.

degraded voltage concern identified by the NR CECo had an SER and calculations which, we J;*

believed, verified the adequacy ~f the second level

, *

setpoints~.

• 4~ The calculated voltage drop from the MCC to the device was Qreater than that originally assumed and

. could result m equipment not functioning *under **

certain condition. Actions taken in response to the NRC *identified issues during the July 1991. EDSFI were promptly*.

addressed by CECo. Calculations were performed and appropriate compensatory measures were.

implemented..

The NRC recognized in it's Inspection Report that CECo "took corrective action promptly after the EDSFI team questioned the condition".

- 11 -.

...

.

.

.

.

.

CECo agrees with the NRC that the current licensing basis for the degraded voltage erotection system should include a LOCA and a single failure. With the degraded voltage setpoint originally established by CECo and

• .

approved by the NRC, this combination of events could

• result in the availability of only one core spray loop to

~itigate an acciden.

. *.

.......

.

.

We believe that this.condition p*resents minimal safety significance.for three reasons:

1. The probability of this condition is 4.1 E-08/Yea. A realistic anaJy~is shows that the Appendix K limit of.

2200 degrees F 1s not exceeded (BWR Owner's *.

Group Technical Specification Improvement

• *

• Methodology", NEDC-30936P-A dated December'

1988)...

3. The availability of offsite power leaves both feedwater and condensate systems available for mitigation which was not credited in the analysis.

. - t2 -

y

. *

..

'ACTIONS TAKEN AND PLANNED *..,.

Operability/Conditions Adverse to Quality Evaluation Development ENC has been improving operability and conditions adverse to quality (CAO) programs since mid-1990. Over time, several processes have *

been developed, enhanced, and will ultimately be Integrated into a single tr~cking program. The following chronology detailing those process 1mprove"'.'ents, shows a m~asured effort by CEC.o to *

implement programs to more effectively address operability and CA * 08/90 -

Guide,line issued to ENC personnel for evaluating and Informing

• *

appropriate levels of management of potential concerns brought to the attention of ENC personne *

.

.

10/90*-

ENC Guideline of 8/90 distributed to A/Es as interim guidance to be included in the A/E Guideboo *

10/90 -

ENC. Procedure QE 40.1 'Opgrability Evaluations' issued. It was *

developed in response to previous A/E identified concern /91 - * Part 21 Technical Issues Committee forme /91 -

Generic Letter 91-18 "Resolution of Degraded and Nonconforming Conditions" issue /92 -

ENC Procedure OE 40.'1, Revision 1 issued, formal training imple.mented. *

.

.

04/92 -

Operability Evaluation.Workshop at NRC Region I. NRC emphasized

.*

completion of operability evaluations in a time frame commensurate with safety significanc *

04/92 ;.. CECo opera~ility evaluation program status reviewed with NR /92 -

CECo operability evaluation program status reviewed with NRC Riii management.*

06/92 -

CECo operability ev~luation program statu~ reviewed with NRC DOT at Dresden..

.

.

..

.

.

.. 08/92 -

ENC developed draft Integrated Reporting Program (IRP) pro9edure and initiated pilot IRP progra *

• Developed draft E.NC/Station Operability Interface Agreemen /92 -

IRP and operability evaluation process reviewed with NRC Senior Resident Inspector at Byro * *

09/92 -

Obtained concurrence from six Station's Management on implementation *

of Interface Agreemen *

10/92 -

Completed IRP pilot progra /92 -

Operability Interface Agreement to ~*dbt~mented in.a ENC Memo of Understandin *

11/92 -

Training on ENC IR Full implementation of IRP by 12/31i92 *

- 13 -

• I

._,

. *

..

ACTIONS TAKEN AND PLANNED (Continued)

Conditions adverse-to quality have* historically been handled two ways within engineering (see graphic on

• following page). Some ENC Programs have a built in CAO process to address the identification, tracking, and resolution ofissues. Other identified issues are handled

• by an unp_roceduralized process which utilized. letters, meetings, and meeting notes for tracking their resolution. *

Jt is.our intent to integrate current unproceduralized processes along with the ENC Program processes for *

• operability evaluations (OE 40.. 1) and Part 21 issues into

_* IRP. The other ENC Programs will be evaluated for.

inclusion into the IR *

- 14 -

..

DISPOSITION OF CONDITIONS ADVER~E TO QUALITY *

Programmatic Resolutions.

(examples)

-bBD

- UFSAR-EQ

- Other Conditions

. Adverse to Quality (all issues)

QE40~1

.Operability

• Evaluations" Part 21 and Technical Issues Committe ~al~oo~

fu~ra~

existing programs

..

. Reporting.

for.potential

._ _ _..... _______ Program inclusion into IRP

_. (IRP).

will be performed

12-31-92 during 1993 Other Issues

'*

.

.

..

.

.

..

. ACTIONS TAKEN AND.PLANNED (Cont.in_ued) *

ENC Procedure OE. 40.1 'Operability Evaluations'

.

.

.

. October 1990 to January 1992.. *

Revision 0 of OE 40.1 was issued on October 3, *

1990 to define a structured, consistent, and timely

• methodology by which to disposition. operability concern A memo was issued to Nuclear Engineering *

.

Department personnel to alert them to the new.

.. process. No formal training was provided

. *

beyond typical new procedure trainin. An average of 3 evaluations were completed per mont ~-The concerns identified by S&L in November 1990 were not evaluated under this procedure *

. because engineering believed that, based on th conservatisms involved, operability was not

• • aff~cted..

- 15 -

'.

..

ACTIONS TAKEN AND PLANNED (Continued)

.

.

ENC Procedure OE 40.1 'Operability Evaluations'

• January 1992 to October 1992

• . Revision 1 of QE 40.1 was issued on January 3, 1992 incorporating lessons learned ~ver the first year

. of procedure use..

- Procedure was reformatted to be more user friendl *. - Appendices were added to specifically document*

_ necessary compensatory, followup, and corrective actions and their scheduled completion date. *

"'. Ah Appendix was added.to formally incorporate subsequent information into the original operability evaluation.

.. _Emphasis was placed on the need to perform an operability evaluation.when a calculation indicates a. '

potentialdeviation from design; and, that the evaluation must be performed in a time frame commensurate with the safety significance of the concer A 4 h_our training course was p*rovided for engineering personnel and select A/E personnel involved in operability evaluation An ave.rage of 7 evaluations have been compieted per mont *

- Program Effectiveness Reviews

• . OngoinQ review of *completed Operability

. Evaluations by ENC Regulatory Assurance

..

. *Planned Program reviews by Quality Verification.

and the Engineering Assurance Program. *

Current CECo performance of operability assessments shows a clear improvement with time and experience, and displays a distinct increase in our sensitivity to operability issue..;.

.\\I

.

.

• e:..

• .. ACTIONS TAKEN' AND PLANNED (Continued).

ENC Integrated Reporting Program (IBP) *

• 1n *June 1992, ENC made the decision to implement IRP *. *

to formalize the identification, documentation, tracking, and resolution of potential conditions adverse to qualit...

We have completed a pilot study involving the

. ENC Mechanical & Structural Groups and the

. Byron and Braidwood Desi~n Engineering Groups* and Byron* and Braidwood Stations to.*

• validate our proposed _process.. *

Lessons learned from the -pilot study are being incorporated into the ENC IRP Procedur Training of ENC personnel, will begin in November 199.

.

.

.

Implementation of IRP, is *scheduled to be completed by December 31, 199 Periodic effectiveness reviews will be

. performed beginni_ng shortly after IRP *

implementatio * *.. * *

..

.

Deviations or design concerns are documented on

. Problem Identification Forms (PIF).

The PIFs are reviewed.by the approeriate ENC Design. *.

Supervisor, screened for safety sigmficaf1ce, and then transmitted to the applicable stations for information along with planned actions for closure~ If the Supervisor determines that the issue is an operability concern,

• *

Procedure ENC OE 40.1 is entered and an operability evaluation performed. *

Actions required to resolve the *PIF concern will be

.

tracked to completion using the Nuclear Tracking System *

(NTS).

.

.

- 17 -

y

.

• ,

• ACTIONS TAKEN AND PLANNED (Continued)

ENC/Station lntertace Agree.mebts An operability evaluation Interlace Agreement is being.

formalized between ENC and the Stations and will be -

completed by 11 /30/92~ The agreement has two key features:

• *

1. A point of contact has been established at ENC *

• .. * *

• (BWR/PWR Design Superintendent or designee) and each Station (Technical Staff Supervisor). All *

.

operability evaluation communications will be made through these individual. *

..

.

2.. Earlier and more fre,quent ENC/Station -

.

.

• communication *and information sharing are promoted by the agreemen..

-* *.. * *

.

.

- 18 -.

.*.....

ENC Enginee CogniZant ENC.

notified of issue Supv /Supt notifies d initiates a 1---._...;.---1.,,*NED BWRJPWR IF/starts the

_Supv/Supt of the IRP proce$S *

issue Yes Cognizant Supv/Supt.

notifies PWR/BWR

. Is issue an operability

• concern?

• Supv /Supt of the operability concern Issue closed out

• per the IRP process END

N<JIB I Highlighted boxes indicate ENC/Station interfac *

ENC Engineer perfonns 4 **evaluation and notifies Supv or the* results*

ENC/ST A TION (QE-40~1)

INTERFACE FLOWCHART (Revision B 10~22~92)

.

_ _ ISSUE COURTESY

• cALL BWRJPWR Supv/Supt screens issue then notifies the Site Engr Supv and Station Contact Point OPERABILITY *

. EVALUATION INITIATION CALL

. BWR/PWR Supv/Supt notifies Station Contact Point that* a 4 *

• evaluation has started

• OPERABILITY EVALUATION RESULTS CALL

• BWR/PWRSupv/Supt *

• notifies Static>n Contact Point of the 40.1. results

• • '

..

1*

ACTIONS TAKEN AND PLANNED (Continued)

. The development, implementation, evaluation and. * *

success of OE 40.1,.the Interface Agreements, and IRP demonstrate CE Co's commitment to taking the steps necessary for the prompt.identification, tracking, and resolution of conditions adverse to quality.

- 19 -

_.-..

I,

_

INTEGRATED IRP I OPERABILITY EVALUATION I ENC-STATION INTERFACE

• PROCESS -

IRPPROCESS ENC Engineer infonned of an issue ENC Engineer writes PIF and

• initiates the IRP process_

-

Suprv r~views and signs PIF _

(Effective_ 12-31-92)

- OPERABILITY EVALUATION INTERFACE -

AGREEMENT PROCESS -

_ Suprv screens issue for

- -- operability sensitivity _

a,.;.... ________

..;,__-~ ISSUE COURTESY CALL Suprv detennines if issue is an immediate operability concern P Screening Committee screens PIP for safety significance - is issue an operability concern?................

PIF transmitted to affected -

Stations for inf onnation Cognizant-person(s) analyzes problem,: collects data, perfonns root cause analysis if

• appropriate - is issue an,

-

b'l'

?

_ opera 1 Ity concern...... ~..........

Corrective actions implemented M---...

and issue is resolved Senior Screening Committee performs periodic corrective ction *effectiveness review of P data base OPERABILITY_

EVALUATION PROCESS (QE~40.l)

Initiate QE-4 ENC_ Engineer perfonns -

operability-analysis Operability-determination completed Systems Design Suprv to _

, *station Tech Staff Suprv-ISSUE INFO CALL -

ENC Engineer to Tech Staff

_Engineer-OPERABILITY EV AL INITIATION CALL Systems Design Suprv to Station Tech Staff Supry

_ OPERABILITY EV AL INFORMATION CALL ENC Engineer fo Tech Staff Engineer _

-OPERABLITY RESULTS-CAIL Systems Design Suprv to Station Tech Staff Suprv