IR 05000387/1985002
| ML17139D032 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/27/1985 |
| From: | Eugene Kelly, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17139D030 | List: |
| References | |
| 50-387-85-02, 50-387-85-2, NUDOCS 8504020352 | |
| Download: ML17139D032 (10) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-387/85-02 Docket No.
50-387 CAT C License No.
NPF-14 Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penns 1 vania 18101 Facility Name:
Sus uehanna Steam Electric Station Inspectors:
Approved by:
E.
Kel
,
Pro ct Engin r
. Strosnider, Chief, actor Projects Section 1C, DRP Inspection At:
Salem Townshi Penns lvania Inspection Conducted:
Januar 11-16 1985 cecAl i'ate Z7 /gaS-Date Ins ection Summar
- Ins ection on Januar 11-16 1985 Re ort No. 50-387/85-02
~A~~l* d:
A change packages (DCPs) for eight modifications to be installed at the first refueling outage, and DCP-82-174C associated with the addition of Safety Para-meter Display System (SPDS) interface circuits was conducted.
Plant Change Notices (PCNs)
issued against the above DCPs were categorized and compared with a similar critique conducted by PP5L's Resident Engineering Group.
Details and disposition of NCR 83-152 related to the upgrade of the Transient Monitoring System (TMS) were reviewed.
Results:
PCNs associated with eight DCPs to be implemented at the upcoming outage were found to be primarily generated to document conduit and cable routing, clarify installation instructions or editorial errors, correct toler-ances and interferences, and address material/procurement problems.
The modifications for SPDS and TMS contained evidence of discrepancies between as-built internal cabinet terminations and Class 2 connection/wiring diagrams.
Drawing E-503, Sheet 30 (Rev.
1, 11/29/83), for wiring and terminations within Unit 1 Operating Benchboard Cabinet 1C651, was found to not reflect as-built plant conditions.
Unresolved item 85-02-01 was initiated to address the extent and significance of as-built discrepancies with Class 2 internal panel wiring diagrams.
8504020352 850327 PDR ADOCK 05000387
DETAILS Princi al s Contacted C. Ballard, Senior Project Engineer -
NPE R. Byram, Technical Supervisor R. Saccone, Senior Project Engineer, Resident Engineering T. Delpiaz, Installation Engineering Supervisor R. Prego, NgA Operations Supervisor J.
Todd, Compliance Engineer
'A. Derckas, Senior guality Engineer NPE G. Butler, I@C Computer Supervisor Also, interviews and discussions were conducted with additional licensee personnel to obtain information pertinent to this inspection.
~Sco e
Ten design change packages (DCPs) to be implemented at the Unit 1 refueling outage beginning in February 1985 were reviewed with the responsible NPE (Allentown) engineer and a cognizant onsite Installation Engineering Group ( IEG) representative.
Work on packages for which installation has already been started (and accessible)
was observed in progress.
Each DCP was reviewed for completeness (conformance to NDI-15.2-1), techni-cal adequacy, thoroughness of the safety evaluation, and the number/type of design documents affected, Particular note was made of the number of Plant Change Notices (PCNs)
issued against those drawings affected by a design package.
When a
DCP is approved and issued by NPE to the field, each affected drawing has an associated Interim Drawing Change Notice (IDCN) which details the change(s).
The IDCN is a design output document, and it is not revised. If changes to the approved DCP are required, then PCNs are issued against the IDCNs.
PCNs in the nine packages reviewed were classified according to number and reason, and compared against the results of a March 7, 1984 study conducted by NPE Resident Engineering Group.
That review was in general agreement with the results of the NPE study.
This inspection then focused upon those PCNs generated,to correct as-built discrepancies between the physical plant configuration and the drawings.
Evidence was found that there exists configuration control problems with class 2 connection and wiring diagrams.
Also reviewed was the disposition and details associated with NCR 83-152 issued on February 28, 1983.
This NCR concerned the as-built documentation of the Transient Monitoring System, which monitors data utilized for Tech-nical Specification survei llances and post-scram evaluation.
Resident En ineerin Criti ue The results of a study conducted by NPE Resident Engineering after the inter-tie outage were documented in a March 7, 1984 memorandum (RE-921)
to the Manager - NPE.
Excluding work done on SPDS, a total of 599 PCNs (associated with 100 DCPs) were classified into 16 categories in order to assess the root cause behind each change.
The study concluded that no one major cause could be attributed to the number of PCNs issued, nor could any obvious corrective action be proposed.
The principle problem cited by the study was the delay experienced in pro-cessing PCNs this was expected to be corrected by changes to NPE proce-dures, as well as experience gained from the outage by Installation Engi-neering.
None of the 16 categories contained more than 12 percent of the total, except for drafting errors (14',%) which were attributed to the priority associated with updating drawings.
The category of minor design error s
.had 11% (66 PCNs) of the total and were judged to be minor and already adequately controlled by procedures.
More than half of the total were accounted for by:
administrative reasons or clarification (12%);
ease of construction (11',%); interferences (10%); materials or procurement constraints (7%); intentional documentation of field-routed conduit or cable (7%);
and minor details (5%).
As-built discrepancies were found to account for about 5% (32 PCNs) of the total and were encountered usually with internal cabinet terminations and/or non-g systems.
The Resident Engineering survey recommended some reduction in the number of PCNs by use of an advanced constructibi lity walkdown and other measures.
The number of PCNs for any particular DCP was a function of the type and complexity of the modification, and could not be correlated to any major trend or problem.
4.
Modifications 4. 1 DCP-82-0578 Scram Dischar e Volume This design change completed a partially-implemented package (DCP456. 1) to enhance the scram discharge instrument volume in accordance with IE Bulletin 80-17 by adding diverse and redundant level instrumentation (and alarms)
and vent/drain line isolation valves.
This modification affected over 150 design documents; 32 of these were Class 1 drawings and 96 were Class 2 drawings.
At the'time of this inspection (since installation is continui'ng), there were
PCNs issued against various affected drawings.
The majority of these (nine)
PCNs were associated with the Bill of Materials none were explicitly related to as-built di screpancies.
One PCN (84-5276)
was against a
GE wire list, drawing number Ml-H12-543, to depict a spare eighth contact not shown on the drawin IDCN-1 against drawing E503, Sheet 30, for wiring and terminations within the Unit 1 Operating Bench Board Cabinet 1C651, was found to depict a wiring condition that does not currently exist.
Cables 1C635 and 636 are shown to be terminated on strip TBSP( at contacts
through 60; yet, these connections have not been made, and the draw-ing is dated Revision 1,
November 29, 1983.
Further, this condition has been recognized for some time, since the Senior Design Review Board's May 30, 1984 review of DCP 82-0578 recommended that the installer confirm all existing wiring conditions prior to initiation of work.
The turnover of this partially-completed modification, from Bechtel to PP5L, had apparently included a
number of as-built draw-ings which would only be representative of the as-built wiring terminations upon implementation of the modification.
The extent and significance of Class 2 electrical wiring and termina-tion drawings of this type, indicative of configuration control problems, is unresolved (85-02-01).
4.2 DCP-82-761 Diesel Air Dr ers This design change provides two compressor air-receiver trains per emergency diesel generator set for long-term air start reliability by minimizing corrosion products in the starting air subsystem.
The modification is in response to an FSAR commitment and license condi-tion.
The modification affects approximately 100 design documents; however, the package is being installed as a non-g item. There were 30 PCN's issued against these drawings, none being related to as-built discre-pancies.
This installation was observed by the inspector, with no discrepancies noted.
4.3 DCP 83-267 RHR Heat Exchan er This design change installs temperature indicators in the main control room for RHR heat exchanger outlet temperature to fulfill a Regulatory Guide 1.97 commitment.
The modification affects 50 drawings and has 15 PCN's issued.
One PCN, affecting drawing E-502, Sheet 24, corrected a typographical error in control room panel 1C601.
None of the PCN's were found to represent configuration control problems, and installation details were observed to be accurately represented on design drawings.
The safety evaluation associated with this modification was clear and thorough, and the Safety Impact Item (SII) review was based on a
prior system walkdow.4 DCP 83-064 Reactor Vessel Level and Pressure This design change installs new wide range level and pressure instrumentation (and extended range level), including control room indicators and recorders (with computer input signals),
in accordance with Regulatory Guide 1.97 commitments.
The modification affects 194 drawings, 22 of which are Class 1.
There were approximately
PCNs issued against these drawings, most (37) of which relate to material availability constraints affecting the Bill of Materials.
The rest were indicative of welding/installa-tion details, conduit and support routing, interferences and conduit and penetration clarifications.
Two of those PCNs were written to correct nomenclature errors, but none were indicative of configura-tion control problems.
4.5 DCP 83-331A Dr well S ra Flow Indication This design change installs flow measuring instrumentation for dry-well and wetwell spray systems, in accordance with Regulatory Guide 1.97 commitments:
The modification affects 60 drawings, 10 of which are Class 1, with
PCNs issued to date.
None of those PCNs were indicative of con-figuration control problems.
Wiring details were observed at Upper &
Lower Rel'ay Room cabinets 1C661-A2 and Bl, and found to be in con-formance with their respective Class 2 termination drawings.
4.6 Other Desi n Packa es The following DCPs were reviewed, with particular note of drawings affected and PCNs issued.
No instances of configuration control problems were found:
DCP Title Drawings Affected PCNs83-187 83-266 82-648 New ARMs Containment Instrument Gas Pressure 125VDC Trouble Alarm
55
22
DCP 82-174C Safet Parameter Dis la S
Circuits stem SPDS Interface This design change is one of approximately 22 packages, originally begun in July 1982 by Bechtel, as part of the installation of SPDS.
DCP 82-174C effects the tie-in from existing field sensors to the SPDS cabinets in the Upper
& Lower Relay Rooms, of 108 analog points on each Unit (and
common points).
The package was completed and closed out on December 31, 198 The modification was extensive, affecting 250-300 drawings which were principally electrical loop schematics or connection diagrams.
Approximately 104 PCNs were issued against these drawings, and many (estimated to be at least 30) were indicative of discrepancies between wiring in the field and existing termination drawings.
These included:
3 or more wires on a terminal, spare terminals already found used, disagreement between wire list and computer points, and termination point discrepancies.
This modification has been completed, however, the agreement between as-built wiring conditions and affected termination drawings had not been ascertained as of this inspection.
The status of configuration control, with regard to this modification, will be followed as part of unresolved item. 85-02-01.
5.0 Nonconformance Re ort NCR No.83-152 This NCR was issued on February 28, 1983, for a procedural violation involving issuance of an Interim Drawing Change Notice (IDCN),
affecting the Transient Monitoring System (TMS), without an approved Plant Modification Record (PMR).
Plant modifications were being performed (i.e. drawing changes to reflect as-built),
using un-approved or incomplete IDCNs to wire the TMS. without having deve-loped the proper design package (PMR, DCP etc.).
The original disposition of this NCR was to prepare drawing change notices (OCNs) to rectify the as-built di screpancies.
However, this solution was revised by an April 26, 1984 NPE memorandum (PLI-32623)
which initiated a request for modification that became approved as PMR 85-3011 (Unit 1) and PMR 85-3013 (Unit 2).
These packages are still in development, and a walkdown of TMS is planned to update the as-built drawings and upgrade the TMS into a permanent plant system.
The TMS is not a safety-related system, but is used to monitor plant performance, including evaluating operating and shutdown transients, as well as for Technical Specification survei llances and post-scram evaluations.
A review of the documentation associated with this NCR indicated that a number of differences are recognized between the TMS panel internal wiring and plant drawings and, yet, are currently uncorrected.
The NCR contained an estimated 40 Class 1 drawings such as connection diagrams (E395),
schematic and block diagrams (E303),
and instrument location sketches.
Another estimated 25 Class 2 drawings were included as part of the NCR, these including wire routing (J72)
and connection diagrams (E345).
Class 1 drawings at Susquehanna are defined by NDI Procedure gA-15-2.4 (Revision 1) to be those required to support routine, abnormal, or emergency plant operations.
There are approximately 5,000 Class 1 drawings.
Class 2 drawings are those other than Class 1 ( listed in gA-15.2.4)
and are defined as necessary to perform maintenance or support plant modifications.
There are approximately 53,000 Class 2 drawings at Susquehann ~~
The status of this modification, particularly with respect to recognized as-built wiring discrepancies, will also be followed as part of unresolved item 85-02-01.
6.0 A/
C Interface The inspector reviewed the results of the licensee's NgA audit of the plant modification program on July 31 September 7,
1984.
Audit IA-84-13 was summarized in an October 26, 1984 memorandum (PLI-36100),
and detailed 15 findings (requiring corrective action)
and
recommendations.
The audit assessed General Office and plant modi-fication activities, including: (1) processing of RFM's; (2) control of design process by NPE; (3) installation in the field; and (4)
closeout of packages and drawing updates.
The audit found the
, current program to be well-defined and effectively implemented; however, the close-out process was found to be not timely in the updating (as-building) of design documents affected by modification, in that there existed, at that time, a backlog of 300 packages awaiting closeout.
Discussions with the licensee indicated that the backlog was as a result of: (1) recent turnover of drawings to PPAL from Bechtel; (2) large amount of design work during the February 1984 inter-t'ie outage; and (3) the priority applied to updating Class 1 drawings.
The NPE response to the audit findings was provided on December 4,
1984.
The audit had no findings related to configuration control programs, and the inspector had no further questions.
7.0 Mana ement Meetin The scope and findings of this inspection were discussed with licensee representatives at an exit interview conducted on January 16, 198 t