ML16152A841
| ML16152A841 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/28/1989 |
| From: | Wiens L Office of Nuclear Reactor Regulation |
| To: | Tucker H DUKE POWER CO. |
| References | |
| TAC-68202, TAC-68203, TAC-68204, NUDOCS 8909060222 | |
| Download: ML16152A841 (22) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 August 28, 1989 Docket Nos. 50-269, 50-270 50-287 Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte, North Carolina 28242
Dear Mr. Tucker:
SUBJECT:
PROGRAMMATIC AUDIT OF THE SAFETY AND PERFORMANCE IMPROVEMENT PROGRAM (SPIP) AT OCONEE (TACs 68202/68203/68204)
Enclosed is an evaluation report on the Oconee Nuclear Station's implemnntation of the Babcock & Wilcox Owners' Group's safety and performance improvement program (SPIP). This evaluation is based on a staff audit at the Duke Power Company headquarters in Charlotte, North Carolina, during the week of March 27, 1989.
The staff audit of SPIP implementation is planned for two phases: (1) a programmatic audit to evaluate the commitment and involvement of corporate management and the site organization in the SPIP, and the process for disposition of SPIP technical recommendations (TRs), and (2) an implementation audit to perform more detailed review of the implementation and disposition of individual SPIP TRs. We have completed the programmatic audit and will schedule the implementation audit for a future date.
Although it appeared that the involvement of the Duke corporate management and site organization in the SPIP implementation are adequate and that the SPIP TR dispositions are generally systematic and timely, our audit identified several weaknesses. Duke Power Company had not established a formal and proceduralized SPIP process to control disposition of the TRs at Oconee, had not established and maintained official TR files, and had not established special priorities or allocated special funds for the SPIP program. This resulted in inadequate documentation in the TR packages and, sometimes, inadequate TR disposition.
These weaknesses were discussed at the exit meeting on March 31, 1989. At the next implementation audit, we intend to perform a more detailed followup evaluation of the effects of these weaknesses and decide if any additional action is necessary.
It is recommended that you make the following improvements to the Oconee SPIP program:
(1) Establish a formal SPIP TR file with proper documentation.
Documentation to support evaluation conclusions was not always contained in the package, not always easily retrievable, and, in some cases, was riot available at all.
-: 09060222 890828 PDR ADOCK 0500026-9 P
PDC1
Mr. H. B. Tucker
-2 (2) Establish a formal, proceduralized TR disposition process. The current TR disposition process has no provisions or requirements to allow for peer review to verify the adequacy of the interpretation of the TR intent and the evaluation or decisions on TR applicability or implementation. This resulted in inadequate scope of evaluation which, in some cases, led to improper interpretation of TR intent, unsupported conclusions on TR disposition, and a limited scope of required actions for TR closure which may not fully meet the intent of the SPIP recommendation.
We recognize that SPIP was a voluntary program. However, as noted in the SPIP safety evaluation report, improved performance of the B&W plants and acceptable safety margins in the long term can only be achieved if Duke Power provides appropriate management commitment and resources to aggressively and properly implement the SPIP recommendations.
Si erely, eonard A. Wiens, Project Manager Project Directorate 11-3 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/encl:
See next page DISTRIBUTION
<Docket File
)
NRC PDR Local PDR PDII-3 Reading S. Varga 14-E-4 G. Lainas 14-H-3 D. Matthews 14-H-25 M. Rood 14-H-25 L. Wiens 14-H-25 D. Crutchfield 17-D-24 M. W. Hodges 8-E-23 C. Harbuck 13-D-18 Y. Hsii 8-E-23 OGC (For inform. Only) 15-B-18 E. Jordan MNBB-3302 B. Grimes 9-A-2 ACRS (10)
P-315
[Oconee Plant File]
[TUCKER LTR 8/8]
- See previous concurrence PDII-3*
PDII-3*
PDII-3*
MRood LWiens:cb DMatthews 08/11/89 08/14/89 08/23/89
Mr. H. B. Tucker
-2 (2) Establish a formal, proceduralized TR disposition process. The current TR disposition process has no provisions or requirements to allow for peer review to verify the adequacy of the interpretation of the TR intent and the evaluation or decisions on TR applicability or implementation. This resulted in inadequate scope of evaluation which, in some cases, led to improper interpretation of TR intent, unsupported conclusions on TR disposition, and a limited scope of required actions for TR closure which may not fully meet the intent of the SPIP recommendation.
We recognize that SPIP was a voluntary program.
However, as noted in the SPIP safety evaluation report, improved performance of the B&W plants and acceptable safety margins in the long term can only be achieved if Duke Power provides appropriate management commitment and resources to aggressively'and properly implement the SPIP recommendations.
Si
- erely, eonard A. Wiens, Project Manager Project Directorate 11-3 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/encl:
See next page DISTRIBUTION Docket File NRC PDR Local PDR PDII-3 Reading S. Varga 14-E-4 G. Lainas 14-H-3 D. Matthews 14-H-25 M. Rood 14-H-25 L. Wiens 14-H-25 D. Crutchfield 7-D-24 M. W. Hodges 8-E-23 C. Harbuck 13-D-18 Y. Hsii 8-E-23 OGC (For inform. Only) 15-B-18 E. Jordan MNBB-3302 B. Grimes 9-A-2 ACRS (10)
P-315
[Oconee Plant File]
[TUCKER LTR 8/8]
- See previous concurrence PDII-3*
PDII-3*
PDII-3*
MRood LWiens:cb DMatthews 08/11/89 08/14/89 08/23/89
Mr. H. B. Tucker
- 2 (2) Establish a formal, proceduralized TR disposition process. The current TR disposition process has no provisions or requirements to allow for peer review to verify the adequacy of the interpretation of the TR intent and the evaluation or decisions on TR applicability or implementation. This resulted in inadequate scope of evaluation which, in some cases, led to improper interpretation of TR intent, unsupported conclusions on TR disposition, and a limited scope of required actions for TR closure which may not fully meet the intent of the SPIP recommendation.
We recognize that SPIP was a voluntary program. However, as noted in the SPIP safety evaluation report, improved performance of the B&W plants and acceptable safety margins in the long term can only be achieved if Duke Power provides appropriate management commitment and resources to aggressively and properly implement the SPIP recommendations.
Sincerely, conard A. Wiens, Project Manager Project Directorate 11-3 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/encl:
See next page
Mr. H. B. Tucker Oconee Nuclear Station Duke Power Company Units Nos. 1, 2 and 3 cc:
Mr. A. V. Carr, Esq.
Mr. Paul Guill Duke Power Company Duke Power Company P. 0. Box 33189 Post Office Box 33189 422 South Church Street 422 South Church Street Charlotte, North Carolina.28242 Charlotte, North Carolina 28242 J. Michael McGarry, III, Esq.
Bishop, Cook, Purcell & Reynolds Mr. Alan R. Herdt, Chief 1400 L Street, N.W.
Project Branch #3 Washington, D.C. 20005 U.S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Mr. Robert B. Borsum Atlanta, Georgia 30323 Babcock & Wilcox Nuclear Power Division Ms. Karen E. Long Suite 525 Assistant Attorney General 1700 Rockville Pike It C. Department of Justice Rockville, Maryland 20852 P.O. Box 629 Raleigh, North Carolina 27602 Manager, LIS NUS Corporation 2536 Countryside Boulevard Clearwater, Florida 34623-1693 Senior Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, South Carolina 29678 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 Mr. Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Office of Intergovernmental Relations 116 West Jones Street Raleigh, North Carolina 27603 County Supervisor of Oconee County Walhalla, South Carolina 29621
t~fkRE G(,0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 ENCLOSURE 1 SAFETY AND PERFORMANCE IMPROVEMENT PROGRAM PROGRAMMATIC AUDIT DUKE POWER COMPANY OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 1.0 SAFETY AND PERFORMANCE IMPROVEMENT PROGRAM AUDIT 1.1 Introduction During the week of March 27-31, 1989, the Nuclear Regulatory Commission (N1RC) staff conducted a programmatic audit of Duke Power Company's (DPC's)
Safety and Performance Improvement Program (SPIP) for its Oconee Nuclear Station (ONS)
Units 1, 2, and 3.
The Babcock and Wilcox Owners' Group (BWOG) developed the SPIP program in order to reduce both the frequency of reactor trips and the complexity of post-trip responses. The purpose of this audit was to evaluate the DPC SPIP program for ONS, Units 1, 2, and 3.
1.2 Background
After the accident at Three Mile Island, Unit 2 (TMI-2), nuclear power plant owners made a number of improvements to their nuclear facilities. Despite these improvements, the U.S. Nuclear Regulatory Commission (NRC) staff was concerned that the number and complexity of events at Babcock & Wilcox (B&W) designeo nuclear plants had not decreased as expected. This concern was reinforced by the total-loss-of-feedwater event at Davis-Besse Nuclear Power Station on June.9, 1985, and the overcooling transient at Rancho Seco Nuclear Generating Station on December 26, 1985.
By letter dated January, 24, 1986, the Executive Director for Operations (EDO) informed the Chairman of the BWOG that a number of recent events at B&W-designed reactors should be reexamined. In its February 13, 1986, response to the EDO's letter, the BWOG committed to lead an effort to define concerns relative to reducing frequency of reactor trip and the complexity of post-trip response in B&W plants. The BWOG submitted a description of the B&W program entitled "Safety and Performance Improvement Program" (BAW-1919) on May 15, 1986.
Five revisions to BAW-1919 were also submitted. Included in BAW-1919 were specific tasks to be completed by each utility under a SPIP.
The NRC staff reviewed BAW-1919 and its five revisions and presented its evaluation in NUREG-1231, dated November 1987, and in Supplement No. 1 to the NUREG, dated March 1988.
The NRC staff has already performed an audit of the BWOG's disposition-of the technical recommendations (TRs) that were developed by various BWCG committees and task groups. The results of that audit, which
-2 were favorable, were reported in NRC Inspection Report 99900400/87/01. However, the staff determined that an NRC audit program to ensure the quality of each utility's program is necessary since the majority of the recommendations developed by the BWOG did not provide specific design details.
Based on the above, and in order to ensure quality and verify proper implementation of the BWOG SPIP program and its associated TRs, the NRC staff decided to implement an audit program to evaluate each utility's program to control the disposition and implementation of TRs. The first phase is a programmatic audit to evaluate the adequacy of the SPIP programmatic process and TR disposition.
This would be followed by an implementation audit to evaluate the adequacy of the TR implementation process.
The scope of the SPIP programmatic audit includes an evaluation of (1) the.
commitment and involvement of corporate management in the SPIP process (2) the commitment and involvement of the site organization in the SPIP process, and (3) the SPIP process for disposition of TRs. The SPIP programmatic audit also included a review of the disposition of 35 selected TRs to determine the acceptability of the decisions regarding TR applicability and the evaluation for TR implementation. The acceptability of the TR implementation will be evaluated later during the SPIP implementation audit.
1.3 BWOG Recommendation Categories All BWOG recommendations are to be tracked through closure. The following categories have been selected as the "bins" to be used by the utility when assigning tracking status. These categories, as well as the explanatory notes, are addressed in the BWOG Recommendation Tracking System (RTS), in BAW-1919, and in NUREG-1231.
Evaluating for Applicability (E/A)
The recommendation is being evaluated by the utility for applicability to their particular plant. The evaluation may conclude that the recommendation (a) is riot applicable, (b) was implemented previously and is operable, or (c) if applicable, requires further evaluation to determine if it should be implemented.
Evaluating for Implementation (E/I)
An evaluation of the recommendation for applicability has been completed, and the recommendation is now being evaluated to determine if it should be implemented.
Implementing (I)
Utility evaluation is complete and the need for software/hardware changes to meet the intent of the recommendation has been identified.
-3 Software changes have been assigned to appropriate organization and are scheduled and budgeted. Hardware changes have been assigned to appropriate organization for implementation, funding is approved, and change is included in corporate plan for implementation.
Additional comments on implementation status or method of implementation are appropriate.
Closed/Operable (C/O)
Utility meets the intent of the recommendation, and implementation is complete.
Review of existing plant software or hardware results in conclusion that intent of recommendation is already met. If software changes were required, new/revised procedures, training plans, etc. are approved and issued. Personnel are trained and procedures issued.
Closed/Not Applicable (C/NA)
Utility evaluation determines that the recommendation does not apply to plant specific configuration; no past experience of underlying problems has occurred.
Software/hardware of concern does not exist, and existing software/hardware is such that a similar problem could not develop at their plant.
Additional comments on why it is not applicable are required.
Closed/Rejected (C/R)
Utility evaluation determines software/hardware changes meeting the intent of the recommendation are unacceptable and will not be implemented.
Recormmendations may be unacceptable because:
(1) Implementation would not result in an overall improvement in plant safety or perfurmance.
(2) Implementation of recommendation as described would not effectively resolve problem of concern.
(3) Resources required for implementation are excessive for expected plant improvement or benefit.
Additional comments on why it is rejected are required.
2.0 DUKE POWER COMPANY SPIP TECHNICAL RECOMMENDATION DISPOSITION AND IMPLEMENTATION PROCESS Duke Power Company does not have a formal, proceduralized SPIP TR disposition process and does not maintain official TR records. Consequently, the description of the informal process used at Duke Power Company is based on
-4 the verbal information provided to the audit team. This information is shown schematically in Figures 1 through 3, which are included as Appendix A to this report. These figures were prepared by the audit team and verified correct by DPC. The processes corresponding to the flowchart descriptions are summarized in the following sections.
2.1 Assignment of Organizations to Perform Evaluations for Applicability The evaluation for applicability (E/A) process outlined for the Audit Team at the General Offices (G.O.) is shown schematically in Figure 1. As shown in this figure, each SPIP TR is first screened by the Nuclear Relations Manager (NRM) at the G.O. Based on this initial review, the NRM assigns the task of determining applicability of the TR to one of the G.O. organizations or to the Compliance Department, which is located onsite at ONS. The process used to make this determination is based upon the extensive experience of the NRM, rather than on formal criteria.
2.2 Evaluations for Applicability (General Offices)
The process by which a TR proceeds through the E/A process at the G.O. is shown in Figure 1. When the E/A is to be performed at the G.O., the NRM interfaces directly with the manager of the reviewing organization. This manager is given the overall responsibility for ensuring adequate review of the TR.
The assigned organization performs the E/A using existing analyses and the experience base of DPC personnel. Documentation supporting the conclusions is maintained only when necessary to support other tasks requiring more formal documentation prccedUres. For exdmple, an analysis to justify a new setpoint on a pressurizer safety valve would fall within the criteria of the DPC Nuclear Production Department (NPD) Administrative Procedures Manual. Documentation would, therefore, be maintained within the guidelines of the applicable NPD procedures. On the other hand, the documentation of an analysis justifying a new stroke time on a valve that is not part of a safety-grade system and did not fall within the criteria of the Administrative Procedures Manual would not be maintained with the same level of control.
The manager of the organization conducting the E/A reviews the results of the analysis, and upon approval, submits a recommendation to the NRM to change the TR status to either C/NA or E/I.
The NRM reviews this recommendation for the TR status change. If the NRM requires more information, the TR is returned to the organization for additional justification of the concl sions. This process continues until the NRM is satisfied with the E/A conclusions. The NRM then changes the TR status to either C/NA or E/I.
If the TR implementation plan must be changed at a later time because of revisions to the original TR or subsequent to plant experience, the NRM can authorize reopening the TR for a new E/I.
-5 If the TR is not applicable to ONS, the TR package is closed, and no further work is performed. If the TR is applicable to the plant, the NRM forwards the TR package to the appropriate organization for a determination of the feasibility of implementing the TR.
2.3 Evaluations for Applicability (Oconee Nuclear Station)
Some evaluations for applicability must be conducted at ONS. This process is schematically summarized in Figure 1. As shown in the figure, the NRM forwards the TR to the ONS Compliance Department Manager (CDM), who is responsible for the disposition of all TRs processed by station personnel. The CDM reviews the TR and selects the ONS organization that will have primary responsibility for the E/A phase.
Following review by the responsible organization, a summary of the results of the evaluation is sent to the CDM for approval.
When the CDM has approved the evaluation, the TR package is forwarded to the NRM for concurrence.
The NRM reviews the summary of the findings and either concurs with the conclusions or discusses the findings with the CDM. When the results of the E/A phase are approved by the NRM, the TR Recommendation Tracking System (RTS) status is changed to either C/NA or E/I.
If the TR is not applicable to ONS, processing stops; otherwise, the TR package is forwarded to the appropriate organization for the E/I phase.
2.4 Evaluations for Implementation (General Offices)
A summary of the E/I process performed in the G.O. is shown in Figure 2.
Although the assigned organization in the G.O. is responsible for performing the evaluation for implementation, as part of the E/I process, the G.O. and ONS work together to develop the TR implementation plan. The implementation plan recommendation could be to reject implementation of the TR, or the plan could recommend implementation and define the measures necessary to address the intent of the TR with respect to ONS.
Following evaluation, a summary of the proposed implementation plan is transmitted to the NRM for review and approval. If the NRM does not approve the proposed-implementation plan, the NRM requests additional evaluation from the organization responsible for the original review or assigns the evaluation to another organization.
If the NRM approves the proposed implementation plan and the TR is to be implemented, the responsible organization is directed to furnish a schedule for implementation. The details of the schedule are reviewed, and if necessary, negotiated during periodic Group meetings. The last step in this process is to change the TR status to Implementing (I).
If the approved evaluation for implementation indicates that the TR should be rejected, the NRM changes the TR status on the RTS to Closed/Rejected (C/R),
and closes out the TR package.
-6 2.5 Evaluations for Implementation (Oconee Station)
The process by which evaluations for implementation are performed at ONS is summarized in Figure 2. If the NRM determines that the evaluation for implementation should be performed at ONS, the package is forwarded to the CDM for further disposition. The CDM then assigns the development of an implementation plan to the appropriate organization(s). The details of the implementation plan are coordinated with the G.O. to avoid conflicts in work scheduling.
Following the evaluation by the responsible organization, the CDM reviews the completed implementation plan and either forwards the plan to the NRM for final approval or requests additional information. When the plan has been forwarded to the NRM, the implementation process is the same as that described in section (d) above and shown in Figure 2.
2.6 Technical Recommendation Implementation The TR implementation process for both the G.O. and ONS is summarized in Figure
- 3. As shown in the figure, the implementation process is nearly identical in both organizations. However,one additional level of approval is required when the TR is implemented by an ONS organization. As with the other phases, the NRM has final approval authority for this phase.
If the TR is to be implemented at ONS, it is processed using the Nuclear Systems Modification procedures. These procedures control the review and implementation process for all modifications performed at the plant, but do not control software modifications that are performed at the G.O. All modifications to be processed in accordance with these procedures are then grouped according to safety, balance of plant, and office/administrative.
Approximately. 400 modifications are identified on the list at all times. When modifications are completed, new priority itemsare placed on the list. ONS attempts to follow a first-on/first-off procedure, with an overall goal of completing approximately 150 modifications per year. All modifications are assigned a priority number of 1 through 9.
Number 1 priority is safety grade and number 6 through 9 are office/administrative.
The SPIP modifications are prioritized between 2 and 5. The CDM is responsible for the administration of these modification procedures.
Following completion of the modification process, a cover letter describing the implementation and the modification process is forwarded to the NRM for approval. The NRM can either approve the implementation or request that additional work be performed. When approval is granted, the NRM changes the TR status on the RTS to Closed/Operable (C/O), concluding the process.
3.0 REVIEW OF SELECTED RECOMMENDATIONS 3.1 Selection Criteria In order to have an in-depth understanding of DPC's SPIP TR disposition process the staff reviewed 35 TR packages (see Appendix B) and evaluated the timeliness and acceptability of TR disposition. These TRs were selected based on NUREG-1231,
-7 "Safety Evaluation Report Related to Babcock and Wilcox Owners Group Plant Reassessment Program," and the most recent BWOG Recommendation Tracking System (RTS) report. A broad spectrum of TRs was selected so that representative TRs from the following categories were reviewed: 1) TRs designated "Key" by the BWOG and also TRs which were considered high priority by the NRC although not designated key; 2) TRs associated with each of the plant systems (see Appendix B) having a bearing on the SPIP goal of reducing the number of reactor trips and the complexity of post-trip responses; 3) TRs at each point in the disposition process (i.e., C/0, C/R, C/NA, E/A, E/I, and I). It should be noted that the TR packages were not formally maintained using ONS procedures and lacked adequate documentation to support conclusions in some cases. Therefore, much of the information obtained by the audit team was through interviews with DPC and ONS personnel.
3.2 Results of Staff Review The staff found evidence of adequate corporate and plant management commitment and involvement in the SPIP program. The staff also found that DPC used an informal and sparsely documented process to evaluate SPIP TRs for disposition.
This process appeared to be systematic. In addition, the staff found that the DPC and ONS personnel involved in the SPIP process appeared to be knowledgable with respect to the duties and responsibilities associated with the TR disposition process. It also appeared that good communication channels existed among personnel involved in the SPIP process. Based on personnel interviews and the documenitation that was available in most TR packages, the conclusions regarding applicability or rejection were generally acceptable. Also, based on the current status of these TRs (see Appendix B) it appeared that TR disposition and implementation were being accomplished in a timely manner.
However, the staff identified several weaknesses in the DPC and ONS SPIP program which resulted from not having established a formal, proceduralized process to control TR disposition and not having established special priorities for handling the SPIP TRs. In addition, no special funds were allocated for TR disposition, implementation, or in some cases plant modification. Therefore, the staff concluded that the following weaknesses resulted.
o Inadequate TR Package Documentation - The staff found that the documentation in some of the TR packages did not include a complete basis for rejection or applicability, or contain complete or retrievable information on cost-benefit analyses and engineering studies. Traceable documentation of TR disposition could not be reconstructed on the basis of available records. Some TR packages contained incomplete and/or inaccurate disposition documentation.
Inadequate or Limited Scope of E/A and E/I Review -
The staff found that the scope of the E/A and E/I reviews and/or actions taken were sometimes limited. For some TRs it appeared that DPC's interpretation of TR intent did not always fully consider the bases for the TR as discussed in the RTS
-8 report and associated source documents. Also, there were no provisions or requirements in the SPIP process to allow for a peer or independent group review to verify the adequacy of decisions regarding TR scope and intent.
And, if a specific problem or failure had not occurred to date at ONS, DPC often concluded the TR did not apply to ONS.
The TR packages that exhibited these weaknesses are discussed in detail in the following paragraphs. Those packages that exhibit evidence of inadequate/limited scope are addressed first.
TR-071-MFW recommends installation of valve-position indication for the startup and main feedwater regulating valves. The basis for this TR was that feedwater (FW) conditions are indicated by feed pump speed, main FW flow, FW control valve position, and steam generator level at most plants. It can be difficult to diagnose a problem in FW control during startup and upsets, when these parameters fluctuate. This is particularly true if one of the instruments listed above is lost or if the integrated control system (ICS) was sending an erroneous signal to the pumps or valves. True valve-position indication would eliminate confusion and allow faster operator response during upsets. To address this TR, DPC proposed to install indication of open and shut valve position, only. That proposal does not fully meet the intent of the TR.
TR-201-MTS recommends that each utility review electrohydraulic control (EHC) circuits and the circuits for the control and intercept valves to determine why they are inadvertently actuated and how recurrence of inadvertent actuation can be prevented. The basis for this TR was that seven reactor trips had occurred due to inadvertent actuation of the EHC control circuits for turbine overspeed and for fast closure of control and intercept valves. The ONS data base revealed no previous problems in this area, therefore, this TR was rejected.
However, neither an engineering analysis nor a failure modes and effects analysis was performed to assure a potential for EHC problems and possible trips at ONS did not exist.
TR-158-OPS recommends that annunciator design be reevaluated and restructured as necessary to ensure that key alarms do not go unnoticed. Implementation of this recommendation would involve grouping alarms into as few categories as possible, while allowing for quick followup to determine the root alarm. The basis for this TR was that some transients result in so many alarms that operators tend to ignore them all, thus defeating the purpose of the alarm system. Alarms that are related to degraded capability of providing adequate core cooling should be easily discernible from alarms on systems and equipment unrelated to core cooling.
DPC proposed categorizing this TR as Closed/Operable without making any changes. This proposal was based on the premise that operating experience had shown that (1) the existing arrangement of the annunciator system was adequate; (2) a concern for potential operator error existed if the rearrangement is implemented. In addition, DPC referenced an Electric Power Research Institute
-9 study (Research Project - RP 2011). This study found that, in general, the difference in operator performance between an annunciator system in which alarms were generally grouped with their respective system controls and one in which alarms were grouped strictly by system/function with additional demarcation was "not statistically significant." Thus, DPC stated that plant annunciators would not be restructured. DPC had reduced the scope of changes in annunciators, following the Detailed Control Room Design Review, and accepted only three of the review's four recommendations:
(1) Add a turbine/generator "first out" panel.
(2) Revise audible alarms to group individual panels to a specific horn for the purpose of differentiation between alarms.
(3) Revise the annunciator logic so all tiles are dark, etc.
DPC rejected the fourth recommendation from the Detailed Control Room Design Review which addressed the intent of TR-158-OPS and required a rearrangement of annunciator system windows to functionally group all alarms.
TR-105-ICS recommends that each utility (1) perform a field verification of ICS/NNI (Integrated Control System/Nonnuclear Instrumentation) drawings and that all drawings be updated based on the verification; (2) update drawings for legibility and to indicate NNI output functions, signal input ranges, interlock functions, power supply dependence (NNI X or Y); (3) coordinate references regarding relay-contact location. DPC stated that all drawings were being officially upgraded. However, no field verification would be performed to verify drawing accuracy to as-built ICS/NNI configurations.
TR-107-ICS recommends that ICS/NNI system and/or subsystem tuning be performed in accordance with vendor recommendations at least every other refueling outage. This TR also recommends that the utility investigate improved ICS maintenance and tuning methods to correct post-trip MFW control system problems and develop a periodic surveillance/tuning program. TR-038-ICS recommends that the utility develop and implement a recommended preventative maintenance program for ICS/NNI.
The actions required by TR-107-ICS and TR-038-ICS were combined during the disposition process at ONS. The procedure provided to the staff during the audit addressed only the intent and concerns of TR-107-ICS (fine tuning,}.
The intent and concerns of TR-038-ICS (improved ICS maintenance, including maintenance of electrical connections, lug tightness, overall cleanliness, resistance, and ground checks, etc.) were not addressed.
TR-99-OPS recommends that each utility ensure that guidance from Chapter IV of the Abnormal Transient Operator Guideline Technical Basis document (e.g.,
"Excessive MFW," "Throttling AFW," and "Throttling HPI Flow") is reflected in plant-specific procedures. TR-159-OPS recommends that the utility evaluate secondary system controls and consider the necessary modifications to achieve the following capabilities:
100 10 (1) Remote manual control in the Main Control Room (MCR) of all post-trip steam flow paths, including turbine bypass valves (TBVs), atmospheric dump valves, auxiliary steam, steam supplies to all feed pump turbines (including EFWPTs) and any other lines that could result in steam leaks.
(2) Remote manual control in the MCR of all pumps and valves for both MFW and EFW (all possible injection flowpaths) sufficient to both control flow and isolate all paths.
(3) Sufficiently redundant capability to provide a high reliability of isolating a failed path to terminate excessive steam or feed flow from the MCR (e.g., capability to operate both control and isolation valves, TBVs and block valves, etc.)
TRs 099-OPS and 159-OPS were categorized as.C/0 until the January 1989 over cooling event at ONS. Following this event, the Tns were re-opened and placed in the E/A bin to allow for a more detailed review in order to fully determine the impact of thene TRs on plant operation. This followup effort on closed TRs showed good commitment and involvement by DPC and ONS personnel. However, if the initial review had included peer checks or independent quality input to the disposition process decisions, the above concerns might have been adequately addressed, and the potential for overcooling might have been removed.
The following TR packages exhibit evidence of inadequate documentation.
TR-066-MFW recommends that the utility check all main feedwater and condensate system protective circuits, interlocks, motors, and other necessary electrical equipment or system operation to ensure that a single electrical failure, e.g.,
loss of a motor control center, would not cause a loss of both feedwater trains. The TR also recommends eliminating the potential for a single electrical failure causing a loss of both feedwater trains, wherever possible.
TR-179-MFW recommends that the utility perform an evaluation to identify areas for enhancing the reliability of the MFW and condensate systems and controls, with attention given to preventing failure of an active component from causing a loss of all feedwater. The recommendation stated that the changes identified in this evaluation should be made "as practical."
TR-066-MFW was categorized as C/R, and portions of TR-179-MFW were being rejected based on a DPC conclusion that these recommendations were not economically feasible.
The documentation necessary to support the conclusion that a TR should be rejected based on economic feasibility was not available for review. The staff found no evidence of a formal process used to analyze cost feasibility, relate cost to safety impact, and present a conclusion on cost-effectiveness for these modifications. Apparently, a "not economically feasible" conclusion was arrived at during informal discussions among lower tier groups, then, discussed with management and approved. However, documentation to support the actual cost analysis was never prepared.
TR-153-IAS recommends that a plant-specific evaluation of air-system failure be made to ensure that certain failures would not affect the ability to control the plant during an air outage. Documentation to support the review of the
11 Instrument Air System probabilistic risk assessment (PRA), (i.e., the review criteria and the conclusion that the PRA recommendations met the intent of TR-153-IAS) was not available. In addition, specific PRA review criteria were never established. However, the PRA was reviewed by one member of management, and TR-153-IAS was categorized as C/o.
4.0 CONCLUSION
S A formal, proceduralized, well-documented SPIP process to control TR disposition was not established at DPC for its ONS. However, based on additional information received during interviews with DPC and ONS personnel, the staff found evidence of adequate corporate and plant management involvement in the SPIP process and noted that ONS had an evaluation process to disposition TRs.
This process appears to be systematic.
The staff also found that DPC and ONS personnel involved in the SPIP process appeared to be knowledgable with respect to the duties and responsibilities associated with the TR disposition process. In addition, it appeared that good communication channels existed among personnel involved in the SPIP process.
The staff reviewed the disposition of 35 technical recommendations to determine the acceptability of the decisions regarding TR applicability and the evaluation for TR implementation. Based on the below information, the staff determined that DPC and ONS were addressing the SPIP TRs in a timely-manner.
Closed Operable......
17 Closed Rejected.....
3 Closed Not Applicable...............
3 Evaluating for Implementation...........
8 Implementing 4
However, the staff also determined that because DPC and ONS had not 1) established a formal, proceduralized SPIP process; 2) established and maintained official TR files; 3) established special priorities for handling the SPIP TRs; or 4) allocated special funds to support the SPIP program, the following weaknesses resulted.
Inadequate TR Package Documentation - The TR package documentation was sometimes incomplete (i.e., engineering study documentation to support conclusions on applicability, rejection, or cost feasibility was not always contained in the files, was not always easily retrievable and in some cases, was not available at all). In some cases, documentation appeared to be inaccurate. Additionally, due to the lack of documentation in the TR packages, much of the information provided to the audit team was via interviews with DPC and ONS personnel. This could result in future problems as key personnel involved in the SPIP process leave DPC and ONS.
12 Inadequate or Limited Scope of E/A and E/I Reviews - There was indication of limited scope during the TR review process, the TR modification proposals process, and the TR closure process (i.e., in some cases, all available information concerning each process was not taken into consideration before a decision was reached). Also, there were no provisions or requirements in the SPIP process to allow for peer or independent group review to verify the adequacy of SPIP decisions regarding TR applicability or interpretation of TR intent, (i.e., in some cases, TRs were improperly dispositioned as TR intent was not fully understood).
Based on the above information and despite the weaknesses identified in this report, the staff determined that the SPIP process used to disposition TRs appeared to be adequate, and corporate and plant management involvement in the SPIP process was satisfactory.
However, the staff recommends that DPC upgrade their existing SPIP process and strengthen the weak areas mentioned above by (1) establishing a more formal process to control TR disposition, (2) providing for a backup means to verify the adequacy of decisions on-TR applicability and/or interpretation of TR intent, and (3) maintaining more complete support documentation in the TR packages.
The weaknesses were discussed at the exit meeting on March 31, 1989. DPC acknowledged the staff's concerns but did not agree that specific action to strengthen their SPIP program was warranted. Therefore, a more detailed follow up audit to evaluate the effects of these weaknesses may be required.
0endix A Spip Tec nical Ree:- enca Ins Nuclear Relations
- 7t 7R sZtr s Manager (NRM4) set
s assigns Org to pe-f Evaluation for Apolicability General Offices enz t: ^:7-:014ace (G.O.)
perform E/A a: :NS f:r E/A ass';ns NRM reviaws E'A No
- 'e s
AArve Yes C:-;.e reviews No Yes No Yes NRM updates RTS TR NRM uDdates RtS 7R NO;~v status to C/NA status to E/:
7; CLOSE-D, Recrrmenattcn Not To Ap:1icaole Fig 2 Figure.
Duke Power Company SPIP TR Evaluation for Applicability process.
FNRM as gs Org to perfor E/1
.~eC:mroliance assigns G.C.pe-erm I NS Or; to :eo0rm are deve cEs clan w NS CS ;e -.
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_N:a s ;7zL T; TR CILTSED
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Figure2...uk Power. Company SPTP TR Evaluation' for Implementation processS.
assgns tz Or; f:m olenentati on
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jONS 3.0. ee s *RC~m liance ass4igns TR to CNS Or; for
-evcews 7;CSDe 1eet ee tat'taonc<
V C:v:liance reviews T::
TRrimeentat'on Yes NRM u;cates RTS TR Yes status to C/C Ap TCLCSE)
Fee -Iena:np Figue 3. Duke Power Ccmnany SPIP TR Imoplementationl process.
Appendix B PLANT SYSTEMS LISTING OF.TRs REVIEWED, TR STATUS, AND
GENERAL COMMENT
S Instrumentation and Control System (ICS)
Administrative (ADM)
Main Steam System (MSS)
Operations (OPS)
Plant Electrical System (PES).
Instrument Air System (IAS)
Primary Relief Valves (PRV)
Main Turbine System (MTS)
TR Status Comments and/or Description of Disposition 3/22/89 001-ICS C/0 (1) 008-ICS I (12/89) 501 complete (1) 013-ICS C/NA 014-MFW C/R Should be C/0 with one part rejected (1) 015-MFW C/o Existing system was adequate (1) 020-MFW C/Acceptable (minimal documentation) 034-ADM C/0 Acceptable (training specified in another document)
- 038-ICS E/I (4/89)
Documentation does not support conclusions; TR intent not met; inadequate review (See TR-107-ICS)
- 066-MFW C/R Documentation does not support the cost-benefit basis for rejection; no formal analysis availabfle 067-MFW
.C/0 (1)
- 071-MFW I (1/90)
TR intent not met; limited scope during rev1Cw and modification proposal 096-MSS C/0 Acceptable (minimal documentation)
- 099-OPS E/I Re-opened following the Jan. 89 overcooling event; procedure upgrading needed 104-ICS C/o (1)
- 105-ICS I (1/90)
TR intent is not fully met; limited scope for required actions; no field verification of as built ICS is proposed 107-ICS I (4/89)
CCmbined with TR-038-ICS (1) for TR-107.-ICS 119-PES C/0 (1) 122-IAS I
(1) 128-IAS C/o (1) 144-IAS C/NA (1) 153-IAS C/O File does not exist; PRA performed; no documentation to support ONS review of PRA 157-OPS C/0 Acceptable; file very disorganized
- 158-0PS E/I (4/89)
Documentation does not support conclusions; scope of review limited; TR intent not met
- 159-0PS C/0 (?)
Re-opened following Jan. 89 event 163-EFW C/0 (1) 154-EFW I
(1) 174-MSS C/R Acceptable documentation not in the file; documentation was provided 175-PRV C/0 (1) 178-ICS I
Currently in final closeout review (1)
- 179-MFW E/I Documentation does not support cost benefit basis for partial rejection; no formal analysis available 181-OPS C/o (1) 190-ICS C/NA (1)
- 200-MTS E/I Limited scope of required actions based on operating experience
- 201-MTS C/0 TR intent not met.
203-PES C/0 (1)
(1) Documentation is adequate to support the existing status.
Selected for review during the SPIP implementation audit (additional TRs may be added to this list prior to or during the audit).