ML17329A658
| ML17329A658 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/04/1992 |
| From: | Burgess B, Langstaff R, Nejfelt G, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A657 | List: |
| References | |
| 50-315-92-15, 50-316-92-15, NUDOCS 9211100032 | |
| Download: ML17329A658 (20) | |
See also: IR 05000315/1992015
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports
No. 50-315/92015(DRS);
50-316/92015(DRS)
Docket Nos.
50-315;
50-316
Licenses
No. DPR-58;
Licensee:
Company
1 Riverside Plaza
Columbus,
OH
43216
Facility Name:
D.
C.
Cook Nuclear Power Plant, Units
1 and
2
Inspection At:
D. C.
Cook Site
Bridgman, Michigan
Inspection
Conducted:
August 31 through October 9,
1992
Inspectors:
Rona
A.
ang
aff
cY'.
Dat
reg M.
eg felt
(f
<
~/Z
Date
Peggy
R~< es
eske
Date
Approved By: /r rmc-
Bruce L. Burgess
Chief
Operational
Programs
Section
Da e
Ins ection
Summar
Ins ection on Au ust 31 throu h October
9
1992
Re orts
No. 50-315
92015
No. 50-316
92015
Areas Ins ected:
Routine,
announced safety inspection of the
engineering
and technical support. program including design
changes
(IP 37700)..
Results:
Five previously identified violations were closed.
No
violations or issues requiring further
NRC review were identified
as
a result of this inspection.
9211100032,921104
ADOCK 05000315
8
Problems Reports involving engineering
were effective in
identifying, evaluating,
and resolving plant deficiencies.
The
design
change
program was effective in controlling the
modification process
and satisfied regulatory requirements.
Improvement in corporate design
change
program was effective in
controlling the modification process
and satisfied regulatory
requirements.
Improvement in corporate design engineering
involvement in post-modification testing was noted.
System
engineering
appeared to be effective in their technical support
and -system oversight role.
Safety assessment
and quality
verification activities were adequate in scope
and effective in
identifying deficiencies.
DETAILS
1.
Persons
Contacted
American Electric Power Service
Com an
- E
E'DE
- p,
T %
R.
p.
R.
C.
L.
M.
Fitzpatrick, Vice President
Nuclear Operations
Koenig, Nuclear Maintenance
Support Section
Malin, Manager,
Nuclear Licensing
Monk, Nuclear Engineering Department
Postlewait,
Manager, .Site Engineering Support
Russell,
Project Engineer
Schoepf,.Superintendent,
Project Engineering
Simms, Site Quality Assurance
Swenson,
Nuclear Engineering
Van Ginhoven,
Superintendent,
Site Design
Wilken, Nuclear Licensing Section
Indiana Michi an Power
Com an
A. Blind, Plant Manager
T. Anderson, Training
K. Baker, Assistant Plant Manager
Production
P. Carteaux,
Training Superintendent
T. Hart, Electrical System Engineer
R. Hennen,
Supervisor,
System Engineering
F. Pisarksy,,
Supervisor,
Maintenance
Engineering
J. Rutkowski, Assistant Plant manager
Technical Support
J.
Wiebe, Superintendent,
Safety
& Assessment
U.S. Nuclear
Re ulator
Commission
Re ion III
B.. Burgess,
Chief, Operational
Programs
Section
J.
Isom, Senior Resident Inspector
G. Wright, Chief, Operations
Branch
Everyone listed above participated in the exit meeting held
on October 9,
1992.
Individuals indicated by an asterisk
participated via teleconference.
Other individuals,
including the licensee's -engineering staff, were .contacted
during the inspection.
2 ~
Action on Previousl
Identified Items
a ~
The following violations are considered
closed
based
on
this inspection.
The violations were identified by the
essential
(ESW) safety system functional
inspection
(SSFI)
conducted in June
and July of 1990
and were transmitted to the licensee
by a separate
letter dated
November 9,
1990.
(1)
Closed
Violation
315
316 90201-10
Inadequate
design control for replacement
of a valve in a
component cooling water
(CCW) heat exchanger.
(2)
Closed
Violation
315
316 90291-11
Lack of
procedural
adequacy
and adherence
for design
verification, maintenance,
and surveillance
~
~
~
actlvlt1es
~
(3)
Closed
Violation
315 316 90201-12
Inadequate
document control for plant drawings.
I
b.
(4)
Closed
Violation
315 316 90201-13
Lack of an
adequate test program for battery surveillance
testing.
Closed
Violation
315 316 91006-01
Design control
and interface deficiencies.
This violation was
identified in a previous modification inspection
conducted in March,
1991.
Based
on the results of this
inspection, this violation is considered
closed.
3 ~
Ins ection Overview
a.
Back round Information
This inspection
assessed
the quality and effectiveness
of engineering
involvement in plant activities.
Engineering activities for the D.C.
Cook plant were
performed
by several
licensee organizations
including
Nuclear Engineering,
Site Engineering,
Plant
Engineering,
and Maintenance
Engineering.
Nuclear
Engineering
Department
and Site Engineering are under
the corporate organization structure.
Nuclear
Columbus,
Ohio, provided design expertise for technical
issues
and design
changes.
Site
En ineerin
, located
at the plant, provided limited design expertise
(Site
Design)
and support for performing modifications,
(Project Engineering).
Plant
En ineerin
provided
system engineering,
test engineering,
and other plant
engineering
support.
Maintenance
En ineerin
provided
technical support for maintenance activities.
The
licensee infrequently used consultants
or contractors
.for engineering
work.
Problem reports were reviewed to evaluate the
effectiveness
of engineering
involvement incorrective
action.
Modifications were reviewed to assess
the
technical quality of individual modifications and the
modification process in general.
System engineering
involvement in plant activities was assessed
because
of
their overview and technical support role.
Safety
assessment
and quality verification activities
pertinent to engineering
were also reviewed.
c ~
Results
No violations or issues requiring further
NRC review
were identified as
a result of this inspection.
Problem Reports involving engineering
were effective in
identifying, evaluating,
and resolving deficiencies.
The appropriate technical expertise
was involved in the
resolution of problems.
As a result,
problems were
generally evaluated in a thorough manner
and
appropriate corrective action was taken.
The design
change 'program was effective'n controlling the design
change
process
and satisfied regulatory requirements.
Improvements in design engineering
involvement in post
modification testing
was noted.
The interface between
engineering organizations,
such as system,
maintenance,
and corporate design engineering
was evident
and
considered effective.
System engineering
appeared to
be effective in their technical support
and system,
oversight role.
Safety assessment
and quality
verification activities were adequate
in scope
and
effective in identifying deficiencies.
4 ~
Problems
Re orts
Based
on a review of problem reports
(PRs), the licensee's
corrective action program was considered effective in
identifying, evaluating,
and resolving deficiencies.
Problem reports where. engineering
involvement was evident
were selected'for
review.
The licensee's
corrective action program was described in
Procedure
PMI-7030, "Condition Reports
and Plant Reporting,"
Revision 18.
After, initial operability reviews,
PRs were
assigned to the appropriate
departments,
such
as Maintenance
or Plant Engineering, for evaluation.
Although the
preparers
of PR evaluations
often were not engineers,
the
proper .technical expertise,
such as maintenance
or system
engineering,
were involved in the evaluations.
Cooperation
and effective communication
between disciplines involved in
problem resolution
was evident.
In general,
PR evaluations
.thoroughly addressed
the problem and identified appropriate
corrective actions.
In some cases,
the corrective action
went beyond the identified problem to prevent recurrence
of
similar problems.
There were sufficient reviews and
approvals with management
involvement to ensure effective
resolution.
The following examples
were representative
of
the
PRs reviewed and the results obtained.
a.
Problem
Re ort 92-038:
This PR documented
the
inability to shut down the
1AB emergency diesel
generator
(EDG) by normal means during surveillance
testing in January
1992.
This event was due to the
failure of control air system solenoid valve SV-5.
SV-5's failure allowed pilot operated valve POV-4 to
admit air to the system.
The failures root cause
was
age related degradation of the solenoid internals.
As
a corrective action,
SV-5 was rebuilt.
The licensee's
investigation revealed that the seven solenoid valves
the system
had not been placed in a preventive
maintenance
program.
As part of the Emergency Diesel
Generator Air System Action Plan,
these valves were
placed in a preventive maintenance, program,
along with
other
EDG pneumatic
components.
In addition,
a minor
modification was proposed to replace the obsolete
b.
Problem
Re ort 92-117
LER 92-02
Unit 1
This
PR and
subsequent
Licensee
Event Report
(LER) documented that
EDG 1AB was declared
inoperable following an overspeed
trip in February
1992.
The cause of the event was the
combination of several unrelated conditions.
The
supply damper
had been de-energized
in the open
position
(due to the problems with the damper).
The
open damper allowed cold (outside) air to enter the
EDG room, which blew directly on the governor warming
line.
The low room temperature
alarm did not sense
this localized cold air,
and the governor warming line
was not insulted.
The root cause of the event was the
unawareness
that the governor warming line was not
providing adequate
flow to the governor oil heat
exchanger.
Adequate
compensatory
measures
were taken
until the warming line. was insulated.
The event
and
circumstances
surrounding the event (e.g.,
problem, locations of the
EDG room temperature
sensors)
were thoroughly investigated
and evaluated
by the
licensee.
System engineering
was effectively involved
in the investigation,
supported
by corporate
design
engineering.
Problem
Re ort 92-203:
This PR documented residual
heat'emoval
(RHR) socket weld failures caused
by flow
induced vibrations in February,
1992.
As part of the
evaluation,
previous
RHR system leaks
(such as those
identified in the Pr-92-193)
were .reviewed.
Due to
recurrence
system leaks,
a task force was created to
investigate design
change history, corrective
maintenance history, industry experiences,
and
system chemistry control practices.
About 80 Unit 2
RHR system branch pipe socket welds were thoroughly
inspected
using liquid penetrant tests.
Although no
surface flaws were noted,
a similar inspection
was
planned for the Unit 1 RHR system.
The licensee
was
also investigating the through-weld crack corrosion
mechanism associated
with the weld failures.
This
PR
was an example of effective coordination between
several
engineering organizations
(e.g.,
system
engineering
and design engineering),
and where the
scope of the evaluation went beyond the specific
identified problem
(i.e., the single weld failure).
Problem
Re ort 92-297
LER 92-004
Unit 2
This
PR
and subsequent
LER documented
EDG inoperability and
slow start attempts.
This problems occurred following
- installation of a minor modification.
Minor
modification 12-MM-253, replaced the
EDG pilot
operated
valves during the fourth quarter of 1991.
Previous
PRs had documented similar problems.
The
apparent
adverse trend was reviewed in March 1992,
documented in this PR,
and determined to be reportable.
The LER documented that
EDG 2AB was considered
due to exceeding the
10 second technical
specification
(TS) limit for EDG start time.
The
initial root cause evaluation inappropriately
identified vendor information as
a contributing cause.
'ubsequent
reviews identified an error in verifying the
suitability of the new pilot operated
valves for the
intended application,
and not aggressively
challenging
vendor information.
The review and approval process
was effective in identifying the weaknesses
in the
initial root cause evaluation,
and the problem report
evaluation
was revised.
Problem
Re ort 92-441
LER 91-011
Unit 1
This
PR
and subsequent
LER documented that
EDG 1AB was not
placed
on increased
surveillance
frequency
when
required by TS.
This event was discovered in April
1992, while the diesel generator
system engineer
was
reviewing the previous
100 start
demands to develop
a
data
base for the
EDG Reliability Program initiative.
The review identified a 1990 condition report
documenting
a start failure that had not been properly
logged.
This valid start failure with an incomplete
start in 1991, required the surveillance
frequency to
be increased.
However, since the-operations
log had
not documented
the
1990 incomplete start, this
requirement
was missed.
This was one of several
examples in which the licensee identified a problem as
a result of- an initiative or self-, assessment
type of
activity.
f; 'roblem
Re ort" 92-899:
This PR documented the lifting
of
CCW safety relief valve 2-SV-51 at 275 psig below
the
600 psig setpoint in June,
1992.
Although the
valve was outside of the in'-service test
(IST) program
boundary,
the licensee took actions to add this safety
relief valve and another
141 safety-related relief
valves to a preventive maintenance
program.
These
actions
were taken even though the valves were not due
to be incorporated into the licensee's
IST program for
another four years.
This PR is an example of where the
corrective action went beyond the scope of the
original'roblem.
Desi
n Chan
es
Based
on the review of several modifications, the design
change
program and its implementation
was considered.
effective.
The licensee's
program for design
changes
was
outlined in procedure
PMI-5040, "Design Change Control
Program," Revision 14.
The licensee
used four types of
modifications for design
.changes.
Re uest for Chan
es
(RFCs)
were used for major safety-related
modifications and
were controlled under procedure
for Change," Revision 5.
Minor'Modifications
(MMs) were
used for minor safety-related
modifications and were
controlled under procedure
Modification Process,"
Revision 7.,
Plant Modifications
(PMs) were used for nonsafety-related
modifications with no
safety interface
and were controlled under
"Plant Modifications," Revision 5.
Tem orar
Modifications
(TMs) were controlled under procedure
"Temporary Modifications," Revision 4.
In general,
permanent modification activities were
coordinated
by Project Engineering located
on site.
The
inspectors
considered
the project engineering role
beneficial as it relieved other engineering organizations,
such as system, engineering,
from the administrative burden
of processing modifications.
Conceptual
designs for the modifications were generally
sound
and conservative.
The 10 CFR Part 50.59 safety
.evaluations for modifications were adequate.
Because of
effective communication between plant and corporate design
engineering,
major installation and operation problems were
avoided.
Quality .assurance
(QA) involvement was evident in
the installation activities.
In general,
post-modification
testing
was evident.
Although expected,
such involvement
was recognized
as an improvement from that identified in
previous inspections.
Several modifications were the result
of the licensee
being proactive in replacing components
before they failed or because
replacement parts
had become
obsolete.
The following modifications and aspect's
of -the modification
process
were reviewed.
a.
Modification RFC-DC-12-3043:
This design
change
modified the minimum flow lines from the motor driven
feed
pumps to return to a common 3-inch test line
instead of using
a 1-inch return line.
The
modification had been installed
on Unit 2 during the
1992 refueling outage.
Unit 2 during the
1992
refueling outage.
Unit 1 installation was in progress
at the time of this inspection.
The design
change
was
made in response
to a 1989 problem report to prevent
dead heading
one of the pumps
when both pumps were in
operation under flow conditions.
The inspectors
considered
the overall design to be sound.
The
10 CFR Part 50.59 safety evaluation
was adequate.
Post-modification testing specified by design
engineering
demonstrated
the effectiveness
of the
design.
The test results
were reviewed
and approved
by
design engineering before the modification was released
~ to operations.
Although the test results
were
informally documented
by copies of electronic. mail, the
documentation
was considered
adequate.
The lack of
appropriate
documentation for this modification
appeared to be an isolated
case.
b.
Modification RFC-DC-12-3070:
This modification
eliminated bleed
down of the pressurizer
power operated
relief valve
(PORV) backup air bottles by providing a
positive shutoff when normal air header pressure
was
available.
The modification had teen installed
on
Unit 2 during the
1992 refueling outage.
Unit 1
installation was in progress at the time of this
inspection.
This modification, identified by a control
room task force, minimized bottle replacement
and
nuisance
alarms.
System engineering
was consulted
during the design process to ensure compatibility.
Appropriate quality control involvement was evident.
Post-modification testing
was considered
appropriate
and effective.
Modifications 12-MM-253 AND 12-MM-268:
Modification
12-MM-253 replaced
4-way pilot operated 'valves
POV-1
and,POV-23
on the
EDG starting'ir valves,
and the
3-way.pilot operated valve POV-3 on the
EDG slow start
control circuit, due to lack of spare parts.
Because
the original valves were not longer available,
replacement
valves were procured commercial grade
and
dedicated for safety-related
application.
The
modification was installed during the fourth quarter of
1991, with dedication
(including bench testing)
and
'unctional/operability testing apparently performed
successfully.
Problems with EDG performance
(e.g.,
slow or failed starts)
were first noted during routine
surveillance
and operability testing apparently
performed successfully.
Problems with EDG performance
(e.g.,
slow or failed starts)
were first noted during
routine surveillance
and operability testing in
December
1991,
and continued into January
1992.
On
December
19, .POV-2 on the
EDG 2AB was replaced with a
new spare,
because
component failure was considered to
be the cause of the slow operation
on the
EDG 2AB.
After another
slow start of the
EDG 2AB on January
13,
POV-2 was bench tested.
The required pilot =pressure
provided by the system.
Published vendor information
stated that the required pilot pressure
was
35 psig;
however, it was determined this information was only
valid in applications in which the valve was operated
continuously.
The
EDG application normally only cycles
the
POVs 1-2 times per.month.
The room cause of the
event
was that the replacement
valves dedication plan
(No. HP-0062) failed to consider response
time as'
critical characteristic,
and did not adequately
challenge
vendor information.
The valves should, have
been tested
under actual starting and operating
conditions.
As a result of the problems with the
EDG 2AB, the licensee re-installed the original POV-1
and
POV-2 on the
EDG 2AB.
A failed start of the
1DC on January
26,
1992,
convinced the licensee to
re-install the original POVs on the remaining three
EDGs.
Re-installation of the
POVs was performed under
modification 12-MM-268, and included verifying the
condition of the original valves.
10
d.
Modification 2-MM-321:
This modification replaced the
stainless
steel seal rings on RHR discharge
heat
exchanger
flow control valves 2-IRV-310, 2-IRV-311, and
2-IRV-320 with seal rings of a teflon base material;
The seal rings were replaced during the
1992 Unit 2
refueling outage to stop leakage past the control
valves
as an interim measure until a permanent repair
could be determined.
The evaluation by the vendor only-
supported the satisfactory
use of. the seal ring for one
fuel cycle.
The inspectors
considered this
modification acceptable
as
a interim repair measure.
e.
Modification 12-MM-325:
This modification, completed
in May 1992, replaced the eight safety valves in the
EDG starting air system,
due to the valves failing
in-service inspection testing.
Because
the valves were
obsolete,
the replacement
valves were procured
and dedicated, for safety-related
application.
The inspectors
noted that the initial
dedication plan (i.e., receipt inspection)
rather than
in the design verification.
The dedication plan was
corrected,
and the modification was installed and
tested successfully.
Blanket
A
roved Valve Modification Process:
In late
1988, the licensee
developed
a process
by which safety-
related
and nonsafety-related
valves
and valve
components
could be replaced
(with'a component
different than the original) under blanket approved
design changes,
12-MM-22 and 12-OPM-740.
The process
was developed primarily for replacements
due to
corrective maintenance
or changes, in valve suppliers.
The advantages
of this process
included timely valve
change-outs
by eliminating much of the paperwork
associated
with a design change.
Further within the
limitations of the blanket approval, certain reviews
were not necessary,
and no procedure revisions or
operator training were required.
The program had not
been formalized (or addressed
in the procedures
controlling plant design changes),
but rather,
consisted
of the blanket design
change proposal
and
safety classification, with blanket modification
approvals
and review checklists,
and several
guidance
and clarification documents.
For each replacement,
certain documentation
was required to be completed
and
reviewed,
such as,
a suitability worksheet
(which
.-
included seismic considerations),
a safety evaluation,
and
a job order.
According to the licensee,
this
process
was generally working, with exceptions related
to documentation.
11
Based
on the inspectors'eview
of available
documentation
and discussions
with the cognizant
licensee staff, the blanket approved design
change
process
appeared to satisfy applicable regulatory
requirements.
However, formal licensee control of the
process
was lacking in that no program existed to
clearly delineate limitations, requirements,
responsibilities
and authorities to ensure that
expectations
were consistently met,
and quality of the
documentation
was at an acceptable
level.
The licensee
planned to revise the process in the near future.
According to the licensee,
changes
would include
additional limitations and restrictions,
such
as
replacement
of safety relief valves or operator-type
valves (e.g., air or motor operated)
would not be
allowed under the program.
The licensee
was also
considering additional program controls.
Commercial
Grade Dedication:
The inspectors
conducted
a limited review of the licensee's
program for
and reviewed the dedication
plans for two minor modifications,
12-MM-253 and
12-MM-325.
The program was controlled by general
procedure
(GP) 3.5, "Dedication of Commercial Grade
Items for use in Nuclear Safety-Related Applications,"
Revision 5.
The results of the review indicated that
the program met applicable requirements
and industry
standards.
The inspectors
noted minor errors in both.
dedication plans reviewed which had not been identified
by the licensee's
normal review and approval of the
design documentation.
These errors appeared to be due
to a lack of attention to detail rather than
a
programmatic
weakness.
Tem orar
Modifications:
The inspectors
considered
the
two temporary modifications reviewed to be adequately
controlled with the appropriate level of engineering
involvement.
Details'were
as follows:
(1)
Tem orar
Modification 2-92-003:
This
modification installed
a clamp (i.e., strongback)
upstream of charging system valve 2-CS-354 in
February
1992 to stop
a minor leak from a weld
until permanent repairs could be made during the
1992 Unit 2 outage.
The additional seismic
loading created
by the strongback
on the Class
1
piping had been adequately
evaluated
by the,
licensee.
12
(2)
Tem orar
Modification 2-92-017
and Leak Sealin
of Pressurizer
S ra
Valve:
This modification and
associated
leak sealing
was performed in July 1992
to stop leakage in the gasket
area of pressurizer
spray valve 2-NRV-164.
Longer studs
on the
body'o
bonnet flange were substituted to allow
addition of adapters
used to inject liquid sealant
into the gasket seating
area of the flange.
Because the sealant
was injected into a non-
pressure
boundary area,
no NRC approval
was
required.
Appropriate engineering
involvement was
noted in that the sealant
had been checked for
material compatibility, the additional weight was
evaluated for seismic loading,
and
a evaluation
had been performed to show that the loading on the
studs
was within design margin.
S stem
En ineerin
System engineering
appeared to be effective in their
technical support
and system oversight role.
The inspectors
based this conclusion
on review of PR evaluations,
plant
design
changes,
and system related initiatives in addition
to interviews held with licensee representatives.
System engineering at the D.C.
Cook plant functioned
primarily in an oversight role.
As such,
the system
engineers
were not directly involved in the modification
process,
testing,
and routine maintenance.
In their
oversight role, the system engineers
maintained cognizant of
their assigned
systems
and significant system activities by
reviewing surveillance'est
results,
and by performing
walkdowns on their systems.
The system engineers routinely
reviewed industry and
NRC information for applicability and
were often involved in evaluating
PRs.
System engineers
were'lso responsible for summarizing activities affecting
their assigned
systems in'the System Engineering Monthly
Reports.
In addition to providing an excellent source of
information to licensee
management
and others,
the reports
promoted
system ownership.
System engineers
were recognized
as system experts
by both
management
and staff because
of the quality of technical
support provided to other licensee organizations.
Management
support
was evident. in that sufficient
flexibilitywas provided to the engineers for adjusting
priorities due to emergent
work or plant outage activities.
Because
the system engineering
program was relatively new,
licensee
management
considered
the program still evolving
from a system troubleshooting
and repair mode to one which
will be mainly predictive.
The licensee
planned to increase
the staff to reduce the current workload on individual
13
system engineers,
and to allow .more efficient management
and
oversight of systems.
In their overview function, system engineering
was effective
in identifying deficiencies during routine system walkdowns,
review of industry events,
and review of equipment
histories.
For example,
system engineering identified that
two check valves in a potential post-LOCA leak path (through
the volume control tank)
were not included in the in-service
testing program from a review of an LER from another
utility.
In another
example,
system engineering identified
discrepancies
which resulted in issuing an LER documenting
missed
EDG Technical Specification,surveillances
from review
of EDG start histories.
System engineering actively participated in system-related
initiatives.
For example,
the diesel generation
system
engineer
was the cognizant individual for the
EDG Air System
Action .Plan.
In this role,
system engineering
was working
with plant maintenance
and corporate design engineering to,
improve the quality and reliability of the air system.
Short term goals,
developed
as part of the action plan,
included refurbishment of the control air system
and
incorporating additional tasks into the preventive
maintenance
program.
Long term plans included
a design
change to simplify the diesel starting air circuitry which
would improve diesel reliability and reduce start times.
In
another
example,
the emergency
core cooling system engineer
was actively involved in the
resolve problems associated
with leaks from system welds.
As
part of the task force recommendations,
a non-destructive
testing
(NDT) schedule for these
and similar welds was
planned,
along with installation of additional structural
support to the branch pipes.
Safet
Assessment
and
ualit Verification
Based
on the inspectors'eview
of selected
licensee self-
assessment
activities; the licensee
appeared to be effective
in identifying and resolving engineering related problems.
The following summarizes
the results of this review.
a 0
Safet
Assessments
The licensee
conducted
SSFIs to provide independent
assessment
of engineering activities and plant systems.
SSFIs were scheduled
annually using independent
consultants
and were modeled after the SSFIs
conducted'y
the
NRC using similar techniques.
The licensee
conducted
a containment
spray system
SSFI in 1992.
The
SSFI was
a three-week on-site effort by a team of seven
contractors.
The SSFI confirmed the effectiveness
of
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the licensee's
system engineering
program.
The
licensee
also conducted
an electrical distribution
system functional inspection
(EDSFI) Readiness
Review
in 1991.
The readiness
review was an expanded
performed in preparation for the
NRC EDSFI..
The use of
independent
consultants
probably contributed to the,
effectiveness
of the review as evidenced
by two issues
identified which resulted in LERs.
For example,
LER
91-005 for Unit 1 reported that the
1CD was
declared
due to a circuit problem as
a
result of a November
1990 modification.
Another
example
was
LER 91-005 for Unit 1 which reported that
EDG ventilation and exhaust ductwork,
components,
and
structures
did not have the necessary
documentation to
demonstrate
the capability to withstand
a postulated
tornado.
b.
ualit Verification
The quality verification activities performed by the
licensee's
QA organizations
appeared
to be effective in
identifying deficiencies.
This conclusion
was based
on
the inspectors limited review of a number of QA audits
and surveillances
which concerned
engineering
and the
modification process.
The
QA audits
and surveillance
were appropriate in scope in that all phases
of the
design
change process,
from procurement to installation
and testing,
were assessed.
Based
on the
QA findings
'dentified, the inspectors
also concluded that the
audits
and surveillances
were of sufficient depth and
were performance-based.
The corrective actions taken
to resolve
QA findings were considered
appropriate.
In
addition to the modification process,
the licensee
also
conducted audits in specialized
areas
such as station
blackout and service water
Exit Meetin
The inspectors
met with licensee representatives
(denoted in
Paragraph
1)
on October 9,
1992.
The inspectors
summarized
the purpose,
scope,
and findings of the inspection,
and the
likely informational content of the inspection report.
The
licensee
acknowledged this information and did not identify
any information as proprietary.
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