ML16342D301
| ML16342D301 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/14/1996 |
| From: | Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D302 | List: |
| References | |
| 50-275-96-03, 50-275-96-3, 50-323-96-03, 50-323-96-3, NUDOCS 9605280121 | |
| Download: ML16342D301 (36) | |
See also: IR 05000275/1996003
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-275/96-03
50-323/96-03
Licenses:
DPR-82
Licensee:
Pacific Gas
and Electric Company
77 Beale Street.
Room 1451
P.O.
Box 77Uu00
San Francisco,
Il
Facility Name:
Diablo Canyon Nuclear
Power Plant.
Units
1 and
2
Inspection At:
San Luis Obispo,
Cali fornia
Inspection
Conducted:
February
26 through March
1 and April 8-12.
1996
Inspectors:
Paul
C.
Gage.
Reactor
Inspector.
Engineering
Branchy
Division of Reactor Safety
William M. McNeill, Reactor
Inspector.
Engineering
Branch.
Division of Reactor Satety
Approved:
rts ..
an
en urg
.
engineering
rane
Division of Reactor Safe
5-lQb
Ins ection
Summar
A~I
t d:
R
tt
.
d
1
1 tt
1 tt
11
11
assessment
of the engineering
and corrective action programs.
Results:
En ineerin
~
The inspectors
concluded that implementation of the plan and management
of the assessors'inding
was very good.
The licensee's
self-assessment
team displayed excellent synergism regarding multiple discipline
interaction in team meetings.
The licensee's
"team work" skills was
considered
a strength
(Section 2.3).
9605280121
960521
ADOCK 05000275
8
-2-
The inspectors
determined that
a qualified team had conducted
an
independent
and objective assessment
of engineering activities
(Section 1.1).
The inspectors
found the scope
and depth into assessment
areas
to be
ambitious
and satisfied all the inspection
requirements of NRC
Inspection
Procedure
37550 (Sections
2. 1 and 2.2).
The inspectors
concurred with the problems identified by the licensee's
team and the: disposition of the problems.
No operability concerns
were
identified by the licensee's
team (Section 2.4).
The engineering
self-assessment
team found that engineering
was
generally effective,
and programmatic controls
met regulatory standards.
Engineering
was producing
many effective designs.
analysis
and other
products
(Section 2.4.2).
The engineering
self-assessment
team found strengths
in regard to the
system in the pro-active trending of pump
performance.
and the timely and te"hnically sound resolution of flow
issues.
Weaknesses
found by the licensee's
team were in the translation
of design basis
requirements
into test requirements
for pump speed.
differential pressure,
and acceptance criteria.
Weaknesses
were also
found in configuration control of changes.
such
as valve stroke time and
the current design not fully reflected in the design basis
documents
(Section 2.4.2).
A noncited violation was identified in that the licensee's
team found
that the minimum flow requirements
had changed
in the surveillance
procedure
and Technical Specifications
(AR QE-AFR 0011838):
however,
the
safety analysis report
and the design basis
document
had not changed.
The licensee's
procedures
required that the design basis
document
be
changed
before the procedure
was changed
(Section 2.4.2).
A none ted violation was identified in that the licensee's
team found
a
calculation
had been
done in support of the steam generator
tube rupture
analysis without the proper review and approval
(Technical Specification
AR QE-AFR 0011839).
An assumption
on the amount of back pressure
changed
and.
as
a result.
the effect on the overfill margin was
calculated.
However. this calculation did not receive the review and
approval
required
by design control procedures
(Section 2.4.2).
The licensee's
team identified
a strength in system engineering
performance
regarding
knowledge.
ownership.
problem identification,
problem documentation.
surveillance test development.
and providing
0
-3-
support of the conduct of surveillance tests.
The self-assessment
team
identified weaknesses
involving untimeliness
in providing responses
to
Technical Specification interpretations
and updates
to design basis
documents
(Section 2.4.2).
A noncited violation was identified in that the licensee's
team
identified several
changes
to emergency diesel
generator
Design
Basis
Document
OCM S-21,
which had not been incorporated into the
design basis
document over the past
3 years,
in spite of the required
annual
update.
The team subsequently
performed
a review of additional
design basis
documents
and found similar problems
as in Design Basis
Document
DCM S-21.
The team concluded that the usability of a number
of design basis
documents
have
been adversely
impacted
as
a result of
several
changes
not being incorporated
as required
by procedure
(Section 2.4.2)
The licensee's
team found system engineering
strong in knowledge/
ownership of their systems.
problem identification. "tai lboards" (prejob
briefings)
~
and communication.
The team also
found that system
engineering
was weak in the issuance of quarterly reports
and use of
checklists
in performance of walkdowns (Section 2.4.2).
The licensee's
team reviewed design
change
packages
not associated
with
the vertical
sample of systems.
It was found that design
change
ackages
were technically adequate
and sound.
Strengths
noted by the
icensee's
team were the analytical capability. trending of marginal
pump performance.
and the desire to recapture
some the
pumps performance
margin.
Meaknesses
noted by the licensee's
team were
a lack of
attention to detail
and errors in transferring of design basis
information into surveillance
tests
(Section 2.4.2).
The licensee's
team found that system engineering
was
a strength in
support of operations
in response
to conditions that challenged
continued plant operation.
In addition. it was noted
by the licensee's
team that engineering
was well prepared
and effective on complex tasks.
The licensee's
team also
found that engineering
was not consistent
in
its high quality effort in support of routine work. such
as procedure
writing. addressing
operator
"work around"s
(or compensatory
measures),
and other items.
The licensee's
team concluded
the use of probabi 1'-+ic
risk assessment
information was good (Section 2.4.2).
The licensee's
team concluded that engineering
support of maintenance
was effective.
The team reflected concerns
by technical
maintenance
related to the amount of the engineering
backlog (Section 2.4.2).
The licensee's
team found the erosion/corrosion
program to be
a strength
(Section 2.4.2).
0
The team concluded that engineering
had effectively communicated,
tracked.
and implemented setpoint changes'nd
that design basis
setpoints
have
been properly transmitted via design
and scaling
calculations.
The team observed
a weakness
regarding
a lack of timely
setpoint
updates
in the plant information management
system
and that
nondesign
basis setpoints
are not comprehensively
incorporated into the
plant information management
system (Section 2.4.2).
The licensee's
team found the independent
safety engineering
group to be
highly effective in conducting performance-based
assessments.
Two
strengths
identified by the licensee's
team were independent
safety
engineering's
performance of comprehensive.
thorough'nd
the in-depth
reviews of industry events.
In addition the independent
safety
engineering's
recommendations
and justification of recommended
actions
in response
to industry events
was viewed as
a strength.
One weakness
was the lack of formal review of licensee
.event reports
(Section 2.4.2).
~
The team concluded that engineering
backlog was not effectively managed
and was considered
a serious
weakness.
The team identified current
indicators which reflect
a reduction or stable workload.
when actual
routine workload was increasing
and manpower
was decreasing.
The self-
assessment
team recognized effective management
of backlog in two
distinct areas:
overdue
nonconformance
reports
and design
change
drawings.
The team noted that both of these
areas
were identified as
needing
improvement
by outside entities to engineering
in the past year
(Section 2.4.2).
~
The licensee's
team found
a strength in the high priority given problem
resolution in that most problems
were resolved
in a technically correct
and comprehensive
manner.
One weakness
the licensee's
team identified
was one problem they discovered that was not fully pursed to resolution
(Section 2.4.2).
~
The licensee's
team found no strengths
or weaknesses
in the areas of
minor modifications
and safety evaluations
(Sec.ion 2.4.2).
~
The inspectors
concluded that the licensee activities were satisfactory
in the areas of post-maintenance
testing
and the safety evaluation
screening
process
(Sections
3. 1 and 3.2).
~
The inspectors
found the inservice testing
program for two types of
components
met the regulatory requirements
(Section 3.3).
Summar
of Ins ection findin s:
~
Three noncited violations were identified (Section 2.4).
Attachment:
~
Attachment
- Persons
Contacted
and Exit Meeting
0
-5-
DETAILS
1
TEAN COHPOSITION
(40501)
1. 1
ua 1 ificati ons
Ob ecti vit
and
Inde endence
1.1.1
Inspection
Scope
The purpose of this inspection
was to determine the qualification.
objectivity. and independence
of the licensee's
self-assessment
team in
accordance
with NRC Inspection
Procedure
40501,
""Licensee Self Assessments
Related to Team Inspections."
0 "egion IV NRC team inspection
was planned to
accomplish the core inspection
program requirements of NRC Inspection
Procedure
37550.
"Engineering"
and 40500 'Effectiveness
of Licensee Controls
in Identifying. Resolving.
and Preventing
Problems."
The option of permitting
licensees
to conduct
a self assessment
in lieu of an
NRC team inspection is an
NRC program aimed at minimizing regulatory
impact, and utilizing NRC resources
more efficiently.
In a letter dated January
24.
1996.
the licensee
proposed
to perform
a self assessment
of engineering activities using the guidance of
NRC Inspection
Procedure
37550
and relevant sections of NRC Inspection
Procedure
40500.
1. 1.2
Observations
and Findings
In a letter dated January
24 '996.
the licensee
provided the
NRC the
engineering
self-assessment
plan that included
an outline of the
qualifications of the team members.
The inspectors
compared
the
submitted inspection
plan against
the requirements
of NRC Inspection
Procedure
37550
and determined that the licensee's
assessment
plan included
all the key elements listed in the inspection
procedure.
The inspectors
reviewed the qualifications of the team members
and found they exhibited
a
wide scope of engineering disciplines: with each
member possessing
significant
engineering
experience.
The inspectors
noted that extensive preparation
was conducted
by the licensee
to enhance
the team members qualification regarding
the self-assessment
effort
with the focus
on the auxiliary feedwater
system
and the emergency diesel
generator
system.
The specific areas
as
documented
during the preparation
phase for the team
members
included reviews of nonconformance
reports. quality
evaluations'esign
change packages'nd
system walkdowns.
The inspectors
noted that presentations
regarding probabilistic risk assessments'essons
learned
from prior self assessments
. and performance-based
training were
provided to the licensee's
team members.
The inspectors
confirmed that the licensee's
team was
composed primarily of
Pacific Gas
and Electric personnel
from the quality and engineering
organizations.
The inspectors
noted that the team members
were assigned to
various
sub
teams
based
on their technical
areas of expertise,
but were
excluded
from participation in specific sub teams
where the possibility of
0
-6-
reviewing their own work might have existed.
The licensee's
team composition
was supplemented
with a peer reviewer from the Grand Gulf Nuclear Generating
Station.
!n a letter dated February
14.
1996.
the
NRC accepted
the proposed timing.
scope of effort. credentials.
and experience of the licensee's
self
assessment.
Two inspectors
reviewed the licensee's
self-assessment
effort
from February
26 through March
1 and April 8-12.
1996. in accordance
with NRC
Inspection
Procedure
40501.
"Licensee Self Assessments
Related to Team
Inspections."
2
LICENSEE SELF-ASSESSMENT
PROCESS
2.1
~Sco
e
2.1.1
Inspection
Scope
The inspectors
observed
the licensee's
engineering
self-assessment
team
activities in implementing the submitted plan.
This included interviews with
the licensee staff and observation of the detailed planing of sub tasks.
2. 1.2
Observations
and Findings
The inspectors
found that the submitted plan was
a combination of vertical
and
horizontal
reviews.
The vertical reviews were of two systems,
auxiliary
and emergency diesel
generator systems'hat
were selected
because
of the probabi listic risk analysis significance
and narrow design margins
associated
with these
systems.
Mithin these
systems.
the licensee
reviewed
engineering
products.
such
as design
changes.
minor modifications.
temporary
modifications.
selected
design issues.
surveillance
and post modification
testing.
The licensee's
horizontal review was of selected
topical areas
such
as system
engineering.
erosion/corrosion,
independent
safety engineering,
design
changes.
minor modifications. safety evaluations.
setpoint controls,
engineering
support of operations
and maintenance.
engineering
workload
management,
and problem resolution.
Mithin the topical area of design
changes.
the licensee
addressed
several
subjects that recently emerged
from
plant experience.
The self-assessment
team selected
the safety injection pump
replacement.
white light (Regulatory Guide 1.97).
and low temperature
and over
pressure
protection setpoint modifications
as the emergent activities.
Prior assessments
identified corrective action. training and qualification.
and the accuracy
and consistency of the safety analysis
report
as topics in
need of management
attention.
The licensee did not address
these topics in
this self assessment.
-7-
2.2
~0e th
2.2.1
Inspection
Scope
The inspectors
observed
the licensee's
engineering
self-assessment
team in
performance of system walkdowns.
interviews.
and team meetings.
as well as
reviewed the assessor's
notes.
2.2.Z
Observations
and Findings
The licensee's
team divided each of the topics into sub tasks
and for each
sub
task
a detailed plan was developed of interview questions.
documents.
and
subjects
to be reviewed.
The self-assessment
team conducted interviews with
both closed
and open
ended questions.
The inspectors
found the detailed
planning of the licensee's
team to be
a strength.
The inspectors
based this
finding on the quantity of material,
e.g.
~ the number of minor modifications
reviewed.
and the extent of review, e.g.
~ the number of very minor procedure
errors identified by the licensee's
team in the area of minor modifications.
The details of design that were addressed
by the licensee's
team also
showed
depth into the areas
reviewed.
For example,
the verification by the team that
flow changes
did not affect the analysis of a steam
generator
tube rupture.
2.3
Plan
and
Im lementation
2.3. 1
Inspection
Scope
The inspectors
reviewed the final report.
assessor's
notes.
and the licensee's
nonconformance/corrective
action documents
called action'requests.
2.3.2
Observations
and Findings
The licensee's
management of findings followed the process of an assessor
to
first identify a concern
as
an "issue."
Issues
became
in'formation requests
or
open items.
When it became clear that
some evaluation
was necessary.
then
an
action request
was issued.
Action requests
had seven levels of significance.
The AT-EVAI -type of request
was
an issue which was not
a formal quality
problem.
but did require resolution.
An A-type was the next higher levels
but
still a low significance quality problem.
An AT-QAAF-type request
was
similar. but the significance
rose to the level of requiring the quality
organization
review and concurrence
in order to close the report.
A QE was
a
higher level of significance that normally required root-cause
analysis,
generic review,
and corrective actions.
A QE-AFR was similar, but of greater
significance
and required root cause.
generic
review.
and corrective actions.
The highest level was
an
ACR, which also required root cause.
generic review,
corrective actions.
and quality review and approval for close out of the
report.
0
-8-
In the licensee's
team meetings.
the inspectors
observed
the team's
good work
skills.
For example.
when one team
member
was working on an issue of the use
of setpoint information in the plant information management
system,
others
on
the team suggested
areas
to be explored
and assisted
in the inspection.
The
team meetings
were of a reasonable
length of time.
even with the large size of
the team.
The team meetings
were policed by the team members,
when
someone
got off the subject
they were reminded
by other
team members.
2.4
Results of the Licensee's
Self Assessment
2.4. 1
Inspection Objectives
The inspectors
performed
a detailed review of the final licensee's
engineering
self-assessment
report.
the assessor's
notes.
and action requests
generated
from the self assessment.
2.4.2
Observations
and Findings
The engineering
self-assessment
team found that engineering
was generally
effective.
and programmatic controls
meet regulatory standards.
Engineering
was producirg
many effective designs.
analysis
and other products.
~
System
The engineering
self-assessment
team found strengths
in the pro-active
trending of pump performance,
and the timely and technically sound
resolution of flow issues.
Weaknesses
found by the licensee's
team were
in the translation of design basis
requirements
into test requirements
for pump speed. differential prcssure'nd
acceptance criteria.
Weaknesses
were also found in configuration control of changes.
such
as
valve stroke time and the current design not fully reflected in the
design basis
documents.
These observations
were based
on the licensee's
team walk down of the system,
review of design changes'esign
basis
issues.
surveillance test acceptance criteria.
and observation of
surveillance testing.
Two more significant findings were in the areas
of minimum flow and calculations.
The licensee's
team found that the engineering staff had changed
the
minimum flow requirements
in a surveillance
procedure after receiving
NRC approval of a Technical Specification
(AR QE-AFR 0011838)
change.
However. the safety analysis
report and the design basis
document
had
not been
changed prior to the change in the surveillance
procedure.
The
licensee's
administrative
procedure
required that the design basis
documents
be changed
before implementing changes
to the surveillance
procedures.
Nine months after the surveillance
procedure
change.
engineering
proposed
a design
change which updated
the design basis
document
and the safety analysis
report.
-9-
Criterion
V of 10 CFR 50. Appendix B. requires that procedures
be
implemented.
Procedure
CF3,
"Design Control
and Plant Technical
Specification Requirements".
Revision
1. requires that acceptance
criteria be based
on the design basis
documents.
The inspectors
noted
that the fai lure to revise the surveillance
procedure
based
on the
design basis
document could result in the loss of design control
information.
Corrective actions
were to change
the design basis
document.
At the time of this inspection.
the root cause
and generic
corrective actions
were to be established
(due December
31.
1996).
This
licensee-identified
and corrected violation is being treated
as
~
noncited violation. :onsistent with Section VII.B.1 of the
NRC
The licensee's
team also found that
a calculation
had been
done in
support of the steam generator
tube rupture analysis without the proper
review and approval
(Technical Specification
An
assumption
on the amount of back pressure
changed
and,
as
a result.
the
effect on the overfill margin was calculated.
However. this calculation
did not receive the review and approval
required
by design control
procedures.
Criterion
V of 10 CFR 50. Appendix B. requires that procedures
be
implemented.
Procedure
CF3. ID4, "Design Calculations."
Revision 0,
requires that design calculations
be reviewed
and approved.
The
inspectors
noted that the failure to have this calculation
reviewed
and
approved
was
a noncited violation.
Corrective actions
were to have the
proper review done
and obtain the proper approval.
At the time of this
inspection.
the root cause
and generic corrective actions
were to be
established
(due July 1.
1996).
This licensee-identified
and corrected
violation is being treated
as
a noncited violation. consistent with
Section VII.B.l of the
The inspectors
reviewed design basis
issues
in the areas of
environmental qualification of the auxiliary feedwater
components.
station blackout design.
and remote hot shutdown panel design.
The
inspectors
reviewed the turbine speed
acceptance criteria in detail
and
concurred with the disposition of the problem as documented
in an action
request.
Emergency
Diesel Generator
System
The licensee's
team identified a strength in system engineering
performance
regarding
knowledge,
ownerships
problem identification.
problem documentation.
surveillance
test =development.
and providing
support of the conduct of surveillance tests.
The self-assessment
team
-10-
identified weaknesses
involving untimeliness
in providing responses
to
Technical Specification interpretations
and updates
to design basis
documents.
These observations
were based
on the licensee's
review of a
modification to improve radiator air flow. which included design
calculations.
design criteria. surveillance testing.
and temporary
modifications for the emergency diesel
generator.
The team evaluated
the implementation of Design
Change
Packages
DCP H-
47760
and
DCP H-50203 related to the emergency
diesel
generator
radiator
air flow modi+'cation project.
The team's activities followed the
evaluation of the problem identification, operability evaluation,
root-
cause
determinations
problem resolution
and corrective action
implementation.
including the design
changes
and their associated
calculations.
The team concluded the design
change
packages
were
properly prepared
and adequately
addressed
the design issues.
The licensee's
team identified several
changes
to emergency diesel
generator
Design Basis
Document
DCM S-21. which had not been
incorporated into the design basis
document over the past
3 years,
in
spite of the required
annual
update.
The team subsequently
performed
a
review of additional
design basis
documents
and found similar problems
as in Design Basis
Document
DCM S-21.
The team concluded that the
usability of a number of design basis
documents
have
been adversely
impacted
as
a result of several
changes
not being incorporated
as
required
by Procedure
CF3.NE2.
"Development
and Maintenance of Design
Criteria Memoranda".
Revision 0, paragraph
5.7.2.A.
The corrective
actions
addressed
the need to verify and update
design basis
documents.
The team stated that the root cause
and subsequent
long-term corrective
actions will be established
and implemented
by
a target date of
August l. 1996.
Criterion V of 10 CFR 50. Appendix B. requires that
activities affecting quality shall
be accomplished
in accordance
with
procedures.
The inspectors
noted that the failure to update the design
basis
documents
constitutes
a licensee identified violation which is
being treated
as
a noncited violation. consistent with Section VII.B.1
of the
The self-assessment
team evaluated
the emergency diesel
generator
surveillance test procedure for technical
adequacy
by reviewing
a sample
of associated
open action requests.
evaluations'nd
nonconformance
reports.
including surveillance test procedures
against the Technical
Specifications
and the Updated Final Safety Analysis Report.
The
licensee's
team identified. through their review of action
requests'hat
some of the action requests
were not being responded to within the
assigned
due dates.
One example involved
a Technical Specification
interpretation
requested
on May 24 '995.
by Action Request
A0341640
~
which addressed
the ramifications of paralleling
an emergency diesel
generator to startup
power during Modes
1. 2, 3, or 4.
In this
condition. both second
level under voltage relays
were defeated,
which
subsequently
placed the plant in a condition not specifically identified
by Technical Specification 3.3.2.
Table 3.3-3
~
Item 7.B. 1.
The
-11-
inspectors
noted that due to the diligence of the licensee's
self-
assessment
team.
the Technical Specification interpretation,
as well as
other untimely responses
by regulatory services,
documented
in Action
Requests
A0325313.
A0334971.
A0341374.
and A0345025 were discussed
by
the surveillance
engineering
group, regulatory services.
and engineering
management.
The team documented
the untimely response
regarding
Technical Specifications
and changes
in surveillance test procedure
program with Non-Conformance
Report
N0001972.
The inspectors
viewed
these short-term actions
as appropriate.
System Engineering
The licensee's
team found system engineering
strong in
knowledge/ownership of their systems,
problem identification,
"tailboards" (prejob briefings).
and communication.
The team also found
that system engineering
was weak in the issuance of quarterly reports
and use of checklists in performance of walkdowns.
The inspectors
were concerned
about the number of system engineers
(4)
interviewed as being sufficient to support the conclusions
drawn by the
licensee's
team.
The assessor's
notes
were revised to document
interviews with an additional eight system engineers.
Other Design
Change
Packages
The licensee's
team reviewed design
change
packages
not associated
with
the vertical
sample of systems.
It was found that design
change
packages
were technically adequate
and sound.
Strengths
noted
by the
licensee's
team were the analytical capability, trending of marginal
pump performance.
and the desire to recapture
some the
pumps performance
margin.
Meaknesses
noted
by the licensee's
team were
a lack of
attention to detail
and errors in transferring of design basis
information into surveillance tests.
These observations
were based
on
review of three emergent
work areas:
a safety injection pump
replacement.
low temperature
over pressure
protection setpoints.
and
white lights (Regulatory Guide 1.97) modification.
Hinor Hodifications
The licensee's
team did not identify any weaknesses
or strengths
in this
area.
The licensee's
team concluded the minor modification process
was
a good system to make plant changes.
Some minor procedural
adherence
~
~
roblems
on approval.
revision
~
and verification were identified by the
icensee's
team.
Some minor problems
were noted by the licensee's
team
on configuration management of drawings.
databases.
and design
documents.
Some suggestions
were
made for improvement
by the licensee's
-team.
Approximately 30 minor modifications were reviewed by the
licensee's
team.
-12-
Engineering
Support of Operations
The licensee's
team found that system engineering
was
a strength in
support of operations
in response
to conditions that challenged
continued plant operation.
In addition. it was noted by the licensee's
team that engineering
was well prepared
and effective on complex tasks.
The licensee's
team also found that engineering
was not consistent
in
its high quality effort in support of routine work. such
as procedure
writing. addressing
operator
"work around"s
(or compensatory
measures).
and other items.
The licensee's
team concluded the use of probabi listic
risk assessment
information was good.
Engineering Support of Maintenance
The licensee's
team observed
maintenance activities. including a
calibration.
a freeze
seals
a heat exchanger
cleaning,
and also
conducted
several
interviews with maintenance
and engineering
personnel
in both field and office locations.
The licensee's
team reported that
the maintenance craft personnel,
planners'oremen'nd
the director of
mechanical
maintenance
stated that engineering
support of maintenance
was good.'he
licensee's
team reported that mechanical
maintenance
personnel
agreed that it required
more effort to locate the responsible
engineer
since the reorganization that reassigned
their maintenance
engineers
to engineering
sections:
however
. they still indicated that
the support received
was good.
The team reflected concerns
by technical
maintenance
related to the amount of the engineering
backlog.
The
licensee's
team concluded that engineering
support of maintenance
was
effective.
Erosion/Corrosion
Program
The licensee's
team found this program to be
a strength.
This was based
on the licensee's
team review of the program
and observation of emergent
repair
work on
a small bore unisolable
leak in the Unit 1 high pressure
turbine exhaust
socket weld.
The inspectors
were concerned that the licensee's
team review had
focused
more on personnel
safety than plant safety.
For example,
the
inspectors
noted that erosion/corrosion
programs typically focused
on
potential
breaks of carbon steel
piping in the secondary
steam
system
and that few of the components
in the program are safety-related
components.
Nevertheless
there are safety- elated
components
in the
program.
The inspectors
noted that the only repair activity observed
by
the team
was limited to a nonsafety-related
component.
The licensee's
team indicated that they would extrapolate their observations
from the
nonsafety-related
components
to safety-related
components.
However.
when the assessors
found the radiography
performed
as part of the repair
was of poor quality. the inspectors
questioned
why the repair work was
not radiographed
again.
The inspectors
were informed that the
radiography
was acceptable
because
the component
was nonsafety-related,
c~~.
-13-
but the
same radiography
on
a safety-related
component
would not be
acceptable.
The licensee's
team concluded
the erosion/corrosion
program
to be
a strength
based
on observation of nonsafety-related
activities
under the assumption that safety-related
and nonsafety-related
were
treated
the
same.
The inspectors
found the assessor's
logic in review
of the erosionicorrosion
program and the associated
conclusions to be
faulted.
The inspectors
considered this to be
a minor weakness of the
engineering self assessment.
Setpoint Control Program
The self-assessment
team examined the implementation of mechanical,
electrical'nd
instrumentation
and control setpoints
in accordance
with
current setpoint control procedures,
The team conducted setpoint
checks
against electrical
drawings. plant information management
system,
and
plant configuration
as appropriate.
The team concluded that engineering
had effectively communicated.
tracked.
and implemented setpoint
changes'nd
that design basis setpoints
have been properly transmitted via
design
and scaling calculations.
The team verified that the design basis setpoints
have
been
updated in
the plant information management
system
and properly utilized in the
field.
The team observed
a weakness
regarding
a lack of timely setpoint
updates
in the plant information management
system
and that nondesign
basis setpoints
are not comprehensively
incorporated into the plant
information management
system,
even though,
Procedure
CF6. IOl "Setpoint
Control Program",
Revision 0. states'n
part
~ that setpoint data
should
be centralized
in the plant, information management
system
as
a common
data
base.
The team verified that mechanical
and instrumentation
and
control setpoints
are in the plant information management
system.
but
electrical
setpoints
were still shown in the electrical
device list
Orawings
050024
and 050011.
The self-assessment
team concluded that the formation of the continuous
improvement
team, consisting of key representatives
of various plant
departments'ill
enhance
the setpoint control program.
The self-
assessment
team observed that the continuous
improvement
team had
initiated
a prioritization of relevant
issues
and generated
a draft
revision to the setpoint control
program procedure.
The self-assessment
team determined.
due to the preliminary stage of the self'-initiated
continuous
improvement
team. that it was premature to assess
the
effectiveness
and impact on the setpoint control program,
but felt that
continued
management
support in allocated
resources
for improvement
was
warranted.
Independent
Safety Engineering
The licensee's
team found the independent
safety engineering
group to be
highly effective in conducting performance-based
assessments.
Two
strengths
identified by the licensee's
team were independent
safety
-14-
engineering's
performance of comprehensive,
thorough'nd
the in-depth
reviews of industry events.
In addition the independent
safety
engineering's
recommendations
and justification of recommended
actions
in response
to industry events
was viewed as
a strength.
One weakness
was the lack of formal review of licensee
event reports.
Three
recommendations
were also
made
by the licensee's
team as items of
improvement.
These observations
were based
on interviews of independent
safety engineers
and review of their activities by the licensee's
team.
The inspectors
reviewed in detail the problem on the lack of review c~
licensee
event reports
and concurred with the disposition of the issue
in an action request.
Engineering
Backlog
The team documented
the definition of the term "backlog" as work not
actively performed this month and excludes
the upcoming outage work.
which was scheduled.
The team concluded that engineering
backlog was
not effectively managed
and was considered
a serious
weakness.
The team
identified current indicators which reflect
a reduction or stable
workload.
when actual routine workload was increasing
and manpower
was
decreasing.
The self-assessment
team observed that routine workload was not being
measured
in an integrated
manner within the two engineering
departments'ngineering
services
and regulatory
and design services.
The self-
assessment
team recognized effective management
of backlog in two
distinct areas.
overdue
nonconformance
reports
backlog
and design
change
package
drawing backlog. noting.
however. that both of these
areas
were
identified by outside entities to engineering
in the past year.
The
team observed that engineering
had been responsive
to the external
findings and
as
a results
had substantially
reduced
the backlog in these
areas.
The licensee's
team noted
a concern of a possible outstanding safety-
related
issue within the engineering workload.
The team examined
a
sample of backlog of engineering
work and found no safety significant
issues.
The self-assessment
team encouraged
engineering to perform
a
review of the open workload to prioritize the outstanding
work by safety
significance.
The licensee's
team observed that engineering did not
have effective methods for cancelling unnecessary
work.
The team noted
that cancellation criteria. in draft form. had
been developed
as
a tool.
which incorporated
key elements of safety
and management
checks
and
balances.
Problem Resolution
The licensee's
team found
a strength
in the emphasis
placed
on problem
resolution.
in that most problems were resolved in a technically correct
and comprehensive
manner.
One weakness, the licensee's
team identified
-15-
was one problem they discovered that was not fully pursed to resolution.
The licensee's
team observations
were based
on th ir detailed
review of
five areas.
There were three problem areas
on the. auxiliary feedwater
system:
flow issues.
operational problems'nd
steam trap problems.
The
remaining problem areas
were:
diesel
priming pump timer and
a
nonconservative
low temperature
over pressure
setpoint.
The inspectors
reviewed the licensee's
team efforts and concurred with
the licensee's
team conclusions
and disposition of problems in action
requests.
Safety Evaluations
The licensee's
team found no strengths
or weaknesses
in this area.
This
was based
on the team's
in-depth review of five safety evaluations.
The inspectors
reviewed the licensee's
team efforts and concurred with
the licensee's
team conclusions
and disposition.
3
INDEPENDENT NRC INSPECTION
3. 1
Post-Hodification Testin
3. 1. 1
Inspection Objectives
The inspectors
reviewed
a sample of three design
change
packages
and one minor
modification which had been performed
on motor operated
valves
and limited to
stroke time changes.
The packages
reviewed were:
~
DCP J-47193.
Change
gear ratio in valve HS-1-FCV-95.
~
DCP J-47277.
Change
stems
and gears
on 20 valves.
DCP J-48193.
Change
stems
and <ears
on
11 valves.
and
~
AT HH A0366534.
Valve actuator modification on 4 valves.
3. 1.2
Observations
and Findings
The inspectors
found that
~ in the past.
the licensee
had not performed post-
modification testing with the acceptance criteria based
on
a new calculated
'troke
time.
Presently.
the licensee
did have
a programmatic'equirement
to
perform diagnostic testing of valves
when the operator
was overhauled
or
replaced.
This testing would cause
an evaluation of the
new stroke time as
part of post-modification testing.
0
-16-
3.2
Safet
Evaluations
Screenin
s
3.2. 1
Inspection Objectives
The inspectors
reviewed the
10 CFR 50.59 screenings
associated
with five minor
modifications.
The screenings
were performed
by the licensee to determine if
a safety evaluation
was necessary.
The minor modifications were those
identified in the engineering
self-assessment
report
as having "split scope."
The minor modifications were:
A0368806.
fuse replacement.
A0372961
~ spent fuel bridge crane modification,
A0373444.
spent fuel bridge crane modification,
A0390686.
replacement of pressure
indicator isolation valves'nd
A0392219.
replacement
of centrifugal charging
pump bypass
valve.
3.2.2
Observations
and Findings
Minor modifications by proce"ure definition should not have
a safety
evaluation.
but should
have only a screening.
The screening
information was
documented within the minor modification packages.
The licensee
had
a
procedure
which allowed changes
to safety analysis
report figures without a
safety evaluation. if the safety analysis
report text was not changed.
A
drawing change
was initiated. but neither
a safety analysis
report change
nor
a safety evaluation
was initiated.
The licensee
also
had
a procedure in place
that caused
an annual
review of all drawings
used
as figures in the safety
analysis report
and
an update of the safety analysis
report figures
on an
annual
basis
when the drawings were revised.
3.3
Inservice Testin
of Valves
3.3. 1
Inspection Objectives
The inspectors
reviewed the inservice testing of two types of components,
namely the auxiliary feedwater turbine driven
pump steam traps
and the
emergency diesel
generator starting air receiver
3.3.2
Observations
and Findings
The inspectors
found that the licensee
had never
placed
these
components
in
the inservice testing program.
although operability of both components
were
necessary
for the auxiliary feedwater
and emergency
diesel
generator
systems
to be operable.
These
components
were not identified in the safety analysis
report
as
ASME Code components.
These
components
had been designed
and built
to United States
of America Standard
831 series of codes.
As
a results
the
only parts of the diesel
system that was considered
to be within the
ASME Code
boundaries
and subjected to inservice testing
was the water jacket.
-17-
In 1993. the
NRC issued
"Guidelines for Inservice Testing at
Nuclear Power Plants,"
recommending
the air check valves should
be in a
inservice testing
program.
The inspectors
were aware that
some licensees
have
put these
valves in their inservice testing
program.
Although there
was not
a
clear requirement
when the check valves are not within the
ASHE Code
boundaries.
the inspectors
judged it prudent to have these
check valves in an
'nservice
testing program.
Having the valves in an inservice testing program
would give the
maximum assurance
of their operability and.
thereby.
the
operability of the diesel
generators.
The inspectors
noted that
~he licensee
tested
the check valves every
18 months in accordance with Surveillance
Procedure
STP V-302,
"Exercising Valves
DEG-214.
225.
236.
247.
258,
and 269, Diesel Starting Air
Compressor
Discharge
Check." Revision 6.
steam traps
were tested
every year in accordance
with the preventive maintenance
program
by Maintenance
Procedure
HP E-102.A. "Acoustic Leak Detection Program."
Revision l.
After discussions
with personnel
representing
the
NRC Office of
Nuclear Reactor
Regulations
Mechanical
Engineering
Branch,
the inspectors
confirmed that
non-ASME Code components
that are adequately
tested
on
a
periodic basis
(such
as surveillance or preventive maintenance).
need not be
included in the inservice testing program.
The inspectors
had no further
concerns
in this area.
4
REVIEW OF UPDATED FINAL SAFETY ANALYSIS REPORT
COHHITHENTS
A recent discovery of a licensee
operating their facility in a manner contrary
to the Updated Final Safety Analysis Report description highlighted the need
for
a special
focused review that compares
plant practices,
procedures
andior
parameters
to the Updated Final Safety Analysis Report descriptions.
While
performing the inspections
discussed
in this reports
the inspectors
reviewed
the applicable portions of the Updated Final Safety. Analysis Report that
related to the areas
inspected.
The inspectors verified that the Updated
Final Safety Analysis Report wording was consistent with the observed plant
practices.
procedures
and/or
parameters.
The licensee
had previously found
problems with the accuracy
and consistency of the safety analysis report and
had taken corrective actions in regard to this problem.
0
ATTACHMENT
1
PERSONS'CONTACTED
1. 1
Licensee
Personnel
J. Alviso Engineering Assistant.
Regulatory Services
M. Angus.
Manager.
Regulatory
and Design Services
D. Brosnan.
Supervisor.
Licensing and Design Basis
Management
K. Bych. Supervisor.
Independent
Safety Engineering
Group
W. Crockett'anager.
Nuclear Quality Services
T. Fetterman.
Director. Electrical
and Instrumentation
8 Control. System
Engineering
T. Grebel, Director, Regulatory Services
C. Groff, Director, Secondary
Systems
Engineering
C.
Harbors
NRC Interface,
Regulatory Services
R.
Hess.
Senior Project Engineer.
Support Engineering
S. Ketelsen.
Senior Engineer.
Nuclear Quality Services
D. Miklush. Manager.
Engineering Services
G.
Rueger.
Senior
Vice President.
Nuclear
Power Generation
J.
Shoulders.
Director. Support Engineering
D. Taggart.
Director. Nuclear Safety Engineering
J.
Tomkins. Director. Licensing and Design Basis
Management
R. Waltos. Director, Balance of Plant Systems
Engineering
R.
Webb. Director. Special
Projects
and Technical
Support
D. Vosburg
~ Director. Nuclear
Steam Supply System
J.
Young. Director, Quality Assurance
1.2
NRC Personnel
S.
Boynton. Resident
Inspector
The personnel
listed above attended
the exit meeting.
In addition to the
personnel
listed above.
the inspectors
contacted
other
personnel
during this
inspection period.
2
EXIT MEETING
An exit meeting
was conducted
on April 12.
1996.
During this meeting,
the
inspectors
reviewed the scope
and findings of the report.
The licensee did
not express
a positior. on the inspection findings documented
in this report.
The licensee did not identify as proprietary
any information provided to. or
reviewed by. the inspectors.