ML18096A960

Electrical Distribution Sys Functional Insp (Edsfi) Methodology & Plan.

ML18096A960
Person / Time
Site:	Salem
Issue date:	08/28/1992
From:	Public Service Enterprise Group
To:
Shared Package
ML18096A950	List: ML18096A949 ML18096A960
References
PROC-920828, NUDOCS 9209090233
Download: ML18096A960 (22)

Text

.

A'f'fACHMEN'f NLR*N92130 PUBLIC SUVICB BLJIC'lllC UD GU CODUY SALBll GBDD'!DIG SD'l'IO*

BLBC'!RZCAL DIS'!RIBU'l'IO* SYS'Dll .UC'!IODL I*8HCTIO*

(BDSI'!)

DTBODOLOG'I' DD Pr.all 9209090233 920828 PDR ADOCK 05000272 G PDR

TABLB 01' COllTBllTS Page No.

1.0 t

Purpose .......................... ... ...... 1 2.0 Objectives ..................................... 1 3.0 Background ........ ............................

~ 1 4.0 References ........... *.* ................*.....** 2 5.0 Organization and Responsibilities .............. 3 6.0 Jtlfl!.~tl.C>c:ic:>l.C>~ *******************.************** ~ 4 7.0 Inspection Requirements . .. ..................... 7 8.0 Inspection Guidance ... ...................... 8 9.0 Inspection Preparation ************************* 14 10.0 Meetings . . . . ...... ... . ... . .... ..... ............ 15 11.0 Schedule ............................*........... 16 12.0 EDSFI Documentation ... . . ....................... 16

13. 0 EDSFI Repo~ . . * . . . * * . . * . . . . . . . . . . * . * . * * . * * . * * *

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. -r 1.0 PURPOSB The purpose of this document is to describe the

• program methodology and plari Public Service Electric & Gas Company (PSE&G) will employ for conduct of the Electrical Distribution System Functional Inspection (EDSFI). This document provides guidance for performing a comprehensive team inspection focused primarily on the electrical distribution system (EDS) .

This review will provide reasonable assurance that systems required for safe plant operation are capable of performing their intended functions and are maintained in a state of operational readiness.

2.0 OBJBCTIVBS The primary objective of the inspection is to -assess. the capability of the EDS to perform its intended functions during all plant operating and accident conditions. A secondary objective is to assess the performance of the engineering organization in providing engineering and technical support (E&TS).

3.0 BACl:GROOND Previous NRC inspection teams have observed that the functional capability of certain safety-related systems was compromised due to a lack of proper E&TS. This resulted in, either initial design or subsequent modification activities,

-the introduction of deficiencies which had a direct impact on the electrical distribution system.* Examples of such deficiencies are as follows:

a. Load growth on Class lE emergency diesel generator ( EDG) supplied buses, Class lE batteries and Class lE inverters was not monitored and controlled. This resulted in the overloading of electrical equipment compromising the safe shutdown and accident mitigation functions* of certain safety-related systems. *

b. Engineering modifications to . the EDS were performed without detailed knowledge of the design basis or thorough consideration of system interactions or safety system functionality. (Functionality, as used in this plan, is the ability of the EDS to perform the ii:ttended design functions.)

c. -Temporary modifications have been installed in. the  !:: :~ s for extended periods of time without proper and ~ r required 10 CFR 50. 59 analysis to establish that they .j: J not create an unreviewed safety question.

1

d.

Ele_ctrical calculations were not technically adequate and did not reflect the current plant confiquration. This resulted in equipment beinq undersized, and a lack of coordination of protective devices between individual electrical loads, various plant buses and electrical load centers. *

• e~ Calculations to establish protective relay setpoints were not initially performed or were not updated to reflect setpoint chanqes and plant modifications.

f. Surveillance testinq and post-modification and post-maintenance testinq were not adequate to verify design assumptions and system functionality.

q. Commercial qrade or non-like-for-like components and parts were used without beinq subjected to a prope.r dedication process.

h. Fuse control has been lackinq. There have been numerous instances, because of a lac)t of such controls, where improperly sized fuses have been installed in safety equipment.

i. Electrical connections have not *been properly installed resulting in either a failure or an inadvertent operation of connected equipment.*

4.0 RBl'BRBHCES

a. NRC

• Inspection Manual, Chapter 2515, Temporary Instruction, "Electrical Distribution System Functional Inspection," Issue Date: October 19, 1990.

b. PSE&G Nuclear Department Action Tracking Program

-"Administrative Procedure (NC.NA-AP.ZZ-0057(Q)).

c. 10 CFR so, Appendix A, GDC 17.

d. 10 CFR so, Appendix A, GDC 18.

e. 10 CFR SO, Appendix B, Criterion III and XI.

f. "Prioritization of an Electrical Inspection," dated September 1989 (NUDOCS Accession No. 8910120077), Mr. w.

V. Johnston, Deputy Director, Division of Reactor Safety, Region I. *

g. NRC Branch Technical Position PSB-1, "Adequacy of Station Electrical Distribution Voltages." (Based on NRC Multiple Plant Action '(MPA) B-48.]

2

h.

Plant .Technical Specifications and FSAR.

i. NUREG-oaoo, standard Review Plan.

5.0 ORGAHIZATIOH AND RBSPOHSIBILITIBS The following describes the EDSFI team organization:

a. Project Manager The PSE&G Project Manager is responsible for coordination of all EDSFI activities and interfaces. The Project Manager will establish and maintain clear lines of communication and feedback to company management and will assure that management receives timely and accurate periodic assessments of EDSFI progress and findings.

b. Team Leader The team leader is responsible for the overall administration of EDSFI activities. The team leader will provide programmatic direction and coordinate the timely identification and evaluation of inspection findings through the conduct of routine debriefings and daily team meetings. He will assure that accurate and complete draft Action Requests (ARs) are provided to the Project Manager for disposition .and response. The team leader will be responsible for the preparation and presentation of the final EDSFI report.

c. Miscellaneous Duties The team leader will maintain documentation of EDSFI activities pertaining to identification, acquisition and dissemination of system design information. PSE&G

.administrative support will prepare the detailed tabulation of documents reviewed during the EDSFI which serves as the basis for determining system functionality ..

PSE&G administrative support will perform necessary clerical activities in support of the EDSFI. The team leader will maintain the draft AR and Documentation Sheet database or log.

d. EDSFI Team The EDSFI team members are responsible for conducting portions of the EDSFI as directed by the team leade~.

Team. members will perform inspection activities ~nd provide relevant functional area expertise to the team.

Team members will identify discrepancies, concerns 3~d unresolved questions and document the inspection results through the Document Sheets and ARs process.

3

The EDSFI team members will be assigned full-time to the EDSFl. This allows the team members to focus . their attention fully on the EDSFI, helping them perform their r~views more efficiently.

e .; .'

• PSE&G Points of Contact

• PSE&G Points of Contact will cooperate in reviewing, evaluating, validating~ and dispositioning draft ARs to the extent possible during the onsite review phase.

Draft ARs that remain.open will be included i~ the EDSFI report.

f. PSE&G Managers and Group Heads PSE&G Managers and Group Heads are responsible for assuring department and qroup awareness arid support of EDSFI activities via a designated point. of contact.

Managers and Group Heads will evaluate recommended corrective actions for scheduling and implementation via the Nuclear Department Action Tracking Program (NC.NA-AP.ZZ-0057 (Q)). .

6.0 XBTBODOLOGY The PSE&G EDS FI methodology is patterned after vertical audit techniques developed by the NRC for the performance of Electrical Distribution system Functional Inspections (EDSFis). The EDSFI will assess the operational readiness of the EDS and support systems by determining:

a. Validity of system design basis and the capability of performing the required functions.

b. Testing is adequate to demonstrate that the systems would perform all of the functions required.

c. System m~intenance is

• adequate to ensure system capability under postulated accident con~itions.

d. Operator and maintenance technician training is adequate to ensure proper operations and maintenance of the EDS.

e. Human factors considerations relating to the EDS and the supporting procedures are adequate to ensure proper system operation under normal and abnormal accident conditions. *

f. Manage~ent controls including procedures are adequate to ensure that the EDS will fulfill its functions required by the desiqn basis.

4

This methodoloqy utilizes a team of technical specialists inspecting multiple functional areas. The synergy developed within the

• team through creative questioning, open communication~ persistent follow-up, and mutual respect plays a.*vital role in the evaluation process. Potential concerns which may not seem significant to an individual member's functional area may become more significant when reviewed from an overall plant perspective.

The team develops leads which require individual and team .

effort to investigate. Team members have the flexibility to follow .leads as they develop and are not constrained by a mandatory set of requirements. The team leader is responsible for prioritizing leads and directing the team to pursue those leads wh~ch appear to pe most significant.

The overall intent of the EDSFI will be to evaluate critical design characteristics of the electrical distribution system (EDS) at the Salem Station. The inspection will be based on representative samples at each voltage level of the AC and DC safety related electrical dist~ibution system. The emergency diesel generators and select mechanical components will also be evaluated.

Examples of the types of issues the inspection will, as a minimum, include are as follows:

o Emergency Diesel* Generators (EOG)

Transient and steady state load calculations.

EOG capacity under dynamic conditions including analysis of in-rush .currents, tolerance of load sequence timing relays, etc.

Correlation of transient and steady state load values between Emergency Operating Procedures, EOG load calculations and stated USAR load values.

0 EOG protective relaying 0 EOG air start system Air Receiver capacity to meet EOG starting requirements.

Air Receiver relief valve testing.

Low starting air alarm setpoints.

0 EOG FUel Oil System Day tank and storage tank volume calculations to ensure design basis operational requirements are satisfied.

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_ Fuel_ oil transfer pump capacity

- Seismic considerations Periodic fuel oil testinq Calibration of fuel oil day tank/storaqe tank level switches/transmitters.

o EDG Ventilation System 0 EOG Lube Oil/Jacket Water Keepwarm Systems o DC and Vital AC Systems Voltaqe drop/short circuit calculations Cable sizinq calculations Breaker and fuse coordination/ratinqs Load profiles Battery Room ventilation (temperature and hydrogen pocketinq considerations) 0 480-VAC lE Systems 4160/480-VAC transformer sizinq 480 VAC switchgear short circuit ratinqs Ground fault protection

_Overload protection/Surge Protection Coordination 0 4160-VAC lE Systems Transformer sizinq Switchgear _short circuit ratings Ground fault protection overload protection/surqe protection Coordination Aside* from the design characteristics beinq captured within the scope of the inspection, operational, maintenance and testinq reviews will also occur. For example, the operati*ons and test team member will:

o Review the operatinq, emerqency, abnormal, and a 1 a rm response-procedures associated with the EDS to determine the adequacy, completeness and consistency with system desiqn requirements.

0 Evaluate surveillance test procedures includinq test configuration, acceptance criteria; and post-test restoration requirements.

6

The maintenance team member will:

o Evaluate the adequacy . of corrective and preventive maintenance procedures, including the incorporation of

. vendor recommendations.

o Assess the adequacy of instrument calibrations in assuring the accuracy of system instrumentation.

o Evaluate the adequacy of Post Maintenance Testing.

In addition to functional area reviews all team members during the inspection process will assess the conf iquration and material condition of the system and components through system walkdowns.

7.0 IHSPECTIOH RBQUIR.EXENTS The inspection will encompass a review of general activities as out.lined in this section for selected sample load path(s) at each voltage level of the ac and de electrical distribution system. The purpose beinq to determine conformance with desiqn requireme~ts. (A load path is defined as the electrical power flow path between the selected load circuit and all available power source(s).)

Inspection Activities Will:

a. Verify that the installed EDS is capable of providing quality power to engineered safety features (ESF) loads on demand. This includes a verification of the onsite and off-site power source capacity.

(Quality power is power which has specified acceptable

• *voltage, frequency and current such that connected loads will perform their design safety functions.)

b. Verify that the design of the EDS is in agreement with requlatory requirements, licensing commitments and applicable industry standards.

c. Verify that the ratings and setpoints have been correctly chosen and controlled for protective and control relays and circuit breakers to assure proper coordination, protection, required automatic action, and annunciation.

d. Verify that the EDS mechanical support systems such as HVAC, EOG fuel oil transfer system, EOG cooling water system and air-start system are adequate to support operation under design basis conditions.

7

e.

Verify that design modifications to the EDS, including electrical load growth, have been properly.controlled .

. f. Verify that the installed conf iquration of the EDS corresponds to the design requirements and is in agreement with the documents.

g. Verify that the surveillance and test procedures are adequate to demonstrate the functionality of the

. equipment or system being tested or the design assumptions being verified.

h. Verify that the scope, depth and frequency of maintenance, surveillance and testing (including post-modification testing)' of electrical components in the load path is adequate to verify functional performance.

i. Verify that desiqn assumptions, operational restrictions and other pertinent desiqn or vendor information are accurately and appropriately reflected in operating, maintenance, test, training, and surveillance procedures.

j. Verify that the* engineering organization provides adequate support to the station operating staff, maintenance and surveillance staff when required.

k. . Verify that definitive root cause analyses are accomplished for operational problems, and corrective actions are appropriate. Where necessary, verify that the engineering support staff participates .with t~e plant .

operating staff to accomplish definitive root cause analyses of operational events or to review nonconforming conditions or conditions adverse to quality.

1. Verify, on a sample basis, engineers and craftsmen who are responsible for installation and testing_of system and components have appropriate knowledge and skills.

a.o INSPECTION GUIDABCB The inspection will sample representative electrical attributes at each voltage level of the ac and de safety-related and non-safety-related electrical distribution s*ystein in load paths that power the ESF loads from all available power sources. such power sources would include the '.l nit generator, off-site power supply, onsite ac emergency pc*.*er supply, and station direct current (de) system including t!:.e Class. lE batteries, inverters and chargers.

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--=-~---i-

a. Bnqineerinq Inspeotion For the selected load path(s) the inspection team will perform an in-depth evaluation of engineerinq and desiqn aspects of tbs actual as-built confiqura.tion of the ac and de electrical distribution system and associated components. This review will include the inspection of modifications made to the station since receipt ot the operatinq license. The review will also address the adequacy of the oriqinal desiqn to the extent necessary to determine the adequacy of the existing as-built desiqn. The engineerinq inspection will selectively review the following desiqn attributes and considerations as applicable for equipment in each load path or for the modifications selected:

1) Requlatory requirements and licensinq commitments have been implemented and the EDS will perform its intended safety functions.

2) Adequacy of the size and .the ratinq of electrical equipment in the selected sample load path which may include motors, breakers, fuses, contactors, motor control centers (MCCs), load break switches, cables, buses, transformers, penetrations, EDGs, batteries,

• inverters, charqers, capacitors, resistors and thermal overload heaters.

3) Adequacy of the load study, voltaqe profiles, voltage drop calculations, motor startinq study, load sheddinq, ESF bus load sequencing and overload trip settings for ESF loads includinq consideration of steady state and accident transient loads, acceleration of the loads durinq degraded voltage conditions.

4) *Adequacy of the calculations for EOG loadinq and load sequencinq.

5) Adequacy of short circuit *calculations, design of protective relay loqic and relay settinq calculations, .1 qroundinq calculations and schemes, and protective device coordination studies.

6) Redundancy -and conformance with the single failure criterion, includinq the potential for "sneak circuits" that could compromise-sinqle failure capability *

. 7) Electrical separation of redundant Class lE electrical divisions and non-Class lE and Class lE loads, as applicable, includinq electrical isolation of associated circuits.

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a)

Proper control ioqic for system actuation and operation including interlocking and permissives for protection, indication, annunciation, and for correct manual and automatic operation of the safety. systems during normal and. abnormal conditions of the plant. Accurate translation of control and interlocking logic into electrical elementary diagrams using relays, solid state modules and proqrammable controllers.

9) Correctly chosen setpoints for overcurrent protective relays 1) to assure proper breaker coordination between different voltage levels; 2) to prevent exceeding the vendor specified thermal limits on motors, containment electrical penetrations and cable insulation systems; 3) to allow starting of electrical equipment under degraded voltage conditions; and 4) to provide adequate pre-trip alarms, when applicable.

10) Adequacy of setpoints and time delays for other protective relays for attributes such as under-voltage, tinder-frequency, reverse power, * *ground faults, differential current, thermal overload and phase.

synchronization to assure functionality of the EDS.*

11). Mechanical loads, such as pump horsepower, correspond to actual system operating points during normal and accident conditions and have been correctly translated to electrical loads and incorporated in the electrical load list as appropriate.

12) EDS supporting systems, such as the EOG air start, cooling water, fuel oil storage and transfer, and HVAC

. for electrical equipment rooms, are adequately designed

~o perform both normal and accident functions.

13) Adequacy of . switchyard desiqn

• and availability and adequacy of independent preferred power sources, including bus transfers, and independence between onsite and off-site distribution systems. *

14) The.accuracy of the electrical load list by reviewing several large electrical loads and evaluating* whether the actual steady state power requirements during .various normal operating and accident mitigation modes are adequate.

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15)

The

• adequacy of root cause analyses, associated corrective actions and 10 CFR 50. 59 evaluations by selecting several LERs, NCRs or corrective action requests and temporary modifications related to the EDS.

Assess the adequacy of the involvement of the engineering organization with the operating staff in problem solving and in the interpretation of surve_illance and test data.*

16) The involvement Of the engineering staff in the specification of post-modification testing and* the development of test acceptance criteria for- the modifications inspected.

17) Electrical load growth monitoring and control program.

18) Setpoint calculation and control programs.

19) Procurement specifications, environmental conditions, and other applicable design documents to assess FSAR compliance and other design commitments implementation~

In addition to the above desigri attributes, the following.

supplementary attributes may be reviewed as determined by the team leader and as time allows: *

20) Dedication of commercial grade components for use in safety-related applications and non-like-for-like replacements to assure that the appropriate critical vari~ble ranges have been preserved.

21) Adequate incorporation of the design bases and operating limitations in normal and emergency operating procedures and adequate training of the staff. -

22) *Provisions for indication of bypass and inoperable status, and requirements for annunciation and the operator actions following annunciation.

23) The functional requirements of EDS support systems and verification that these have been correctly translated to logic and elementary wiring diagrams.

24) Engineering .calculation performance and control progr.~m.

25) Self~assessment programs, including QA audits.

26) Design modifications and temporary modifications control programs.

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b *. *station Inspection To complement the engineering inspection efforts, a station inspection will be performed to determine the.adequacy and e~fectiveness of the following attributes: *

1) Field validation of the as-built configuration of the EDS to ensure consistency with station *drawings and documents

.such as the Q-list, setpoint list, and equipment location drawings. Verify that appropriate physical separation bas been maintained between redundant Class lE electrical divisions and that no obvious problems exist for internal plant hazards such as seismic II over I, seismic interactions, high and medium energy line breaks, and compartment flooding.

2) Material condition of electrical equipment~

3) Surveillance and testing were

• properly performed to validate key attributes and parameters such as, protective relay settings, setting of. timers, breaker trip settings, EOG load sequencing and starting logic, fuse and thermal overload sizes, and Class lE battery capacity. *

4) With respect to E&TS capability, the inspection team will review work orders, maintenance requests and temporary modifications~ Evaluate whether inadvertent design changes have been made through maintenance activities~

5) Post-modification testing is adequate to . verify functionality of the component' or system.

6) Engineering involvement (e.g., as indicated by

. documentation) . is adequate for station generated activities.such as surveillance, maintenance, temporary modifications, procurement efforts, field initiated

. design changes, setpoint control program, and generation and implementation of calibration* and surveillance procedures.

7) The effectiveness of self-assessment programs, including QA audits of engineering and EDS areas.

In addition to the above,

• the following supplementary attributes may be reviewed as determined by the team leader and as time allo~s:

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.. . Tl

- -~.:*,. ---*-~ - ~ *-***, .,.... - ..

8) Determine whether the station normal and emergency operatinq procedures include any design assumptions regardinq operator action and conversely whether prescribed operator actions with respect to the EDS- can put the plant outside its design* basis. *

9) The maintenance program is adequate to maintain the EDS equipment operable, and to maintain EQ status of the EDS equipment.

10) Temporary modifications to the safety systems are tracked and controlled and receive the required technical evaluation in a timely manner, including an appropriate 10 CFR 50.59 review. Review the temporary modification documentation and tracking system.

11) Controlled copies of the control room drawings and other operations and training related documents reflect the as-

• built configuration of plant systems.

12) Review the material history of selected load path equipment to determine if component reliability matches that assumed for design basis or for PRA. ,

13) Verify, on a sample basis, that engineers and craftsmen who are responsi:ple .for installation and testing have appropriate knowledge and skills.

c. Conclusion*

The results of the inspection will provide a reasonable basis for the team to draw overall conclusions regarding the ability of the EDS to perform its intended function and effectiveness of adequacy of E&TS involvement. Specific conclusions also will -be drawn reqarding: _

1) The ability of the as~built configuration of the EDS to provide quality power to ensure that the safe shutdoW'Tl and accident mitigation functions can be accomplished on demand.

2) The deqree to which diaqrams, specifications, calculations, "Q" lists, enqineerinq and plant p~ocedures, and drawings are complete, consistent, technically adequate, conservative with *adequate margins, reflect as-built configuration, are controlled, and provide an adequate basis for future des~~n modifications.

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3) The deqree to which the exi:stinq EDS confiquration is in

. compliance with requlatory requirements and licensing i commitments. . '

4 >*' The adequacy of sur'Veillance a'nd test procedures and their implementation for electrical components.

5) The effectiveness of self-assessment* programs in the areas*inspected.-

6) The effectiveness of traininq programs in the .areas inspected.

9.0 IBSPBCTJ:OB PRBPARAT-IOB In preparation for the inspection, the EDSFI team will review and become thoroughly familiar with the scope and goals of the EDSFI. Early in the EDSFI, the team will become familiar with the desiqn bases, design criteria and licensinq commitments, safety evaluation reports, and the electrical distribution scheme in general. The team members will prepare a list of documents for retrieval, such as calcula_tions, . analyses, drawinqs, procurement specifications, test reports, modification packages, and maintenance, surveillance and test procedures. The required documents will be made available or readily accessible for team-member use and* reference.

a. System design reviews will be performed from a functional perspective with emphasis on determining the operating*

conditions under which each active component will function according to design durinq an accident, abnormal condition, or operational mode.

b. System programmatic reviews will establish the current

• operation, maintenance, and testing requirements for the system.

c. Standards, requlations, codes. and quidelines will be reviewed to establish applicable regulatory basis and industry standards.

d. Previous NRC findings throughout the industry, with respect to the EDS, will be reviewed for consideration

- during the EDSFI. This includes the lessons learned from the Hope Creek_EDSFI.

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• _ Ii

e. Applicable industry events, includinq -NRC Bulletins, Circulars, *Information Notices and Generic Letters will b_a reviewed to establish relevant industry operating experience. Applicable INPO Operatinq Experience reports such as SOERs and SENs will also be factored into the EDSFI process.

10.0 KBBTIHGS

a. The effectiveness of the EDSFI is greatly enhanced and team synergy is established if team melilbers interact frequently to benefit from experience and efforts -of other team members.

1) The team leader will conduct* an initial meeting with the EDSFI team members to discuss administrative and technical details.

2) A morninq meeting will normally be conducted to address the planned daily activities of each team member. The meeting should confirm that resources are adequately focused on the most siqnif icant issues. The meeting will allow each team member to summarize the results of his daily activities, provide any information pertinent

• to _the inspection, and describe potentiai concerns and issues. Questions, interjections and comments from other team members from various perspectives are openly encouraged.

The PSE&G Project Manager, other managers and key staff personnel that interface with the team are encouraged to attend these meetings.

b. - . The team leader should meet with the PSE&G Project Manager, as appropriate, to discuss EDSFI proqre~s, team observations and requirements, and the dispo-sition of ARs.

c. Entrance Meeting An entrance meeting will be conducted with appropriate PSE&G_ management and staff prior to the start of the EDSFI to discuss the EDSFI objectives and scope, present the EDSFI plan, introduce the EDSFI team, discuss schedules and confirm lines of communication.

15

11 I

d. Exit Meeting An exit meeting will be conducted with appropriate PSE&G management and staff at the conclusion of the EDSFI to discuss the findings, results and recommendations from the EDSFI *.

11.0 SCBBDULB

• The EDSFI will be conducted over a six week period in accordance with the following schedule:

Week 1 - GET, Systems Training, and Preparation Week 2 to 5 - EDSFI Activities Week 6 - Finalize Concerns, Documentation,* and Draft Report Preparation Week 7 and 8 - PSE&G Revie~ Draft Rep9rt Week 9 - Review PSE&G Comments and Issue Final Report The EDSFI will commence on September 14 and conclude on October 23, 1992.

12.0 BDSPI DOCUXBJl'l'ATIOB Sufficient documentation of what was inspected and found will be maintained. Note taking must be clear, legible and logical. *Inspection activities will be documented on Document Sheets. All potential concerns, discrepancies or unresolved questions identified in th~ documentation of inspection activities will be identified on a draft AR following diligent research, evaluation and team discussion. Items closed out based only on the Document Sheet will be categorized at the conclusion of the inspection to assure that.no programmatic concerns ar-e evident. All documentation must be detailed and cpmplete to withstand the scrutiny of second party reviews.

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-. - - t

b. _Draft Action Requests Throughout the EDSFI, draft Action Requests (ARs) will be initiated for each major concern, discrepancy or unre_solved question identified.* The ARs will form the basis for the EDSFI findings.

1) Initiation An AR will be initiated for one or more of the *!

I following:

a) A potential technical concern b) A significant program aspect or practice which

-appears to be inadequate or incorrect.

c) Information which cannot be readily obtained and whose absence renders . an aspect of the system functionality indeterminate. _

d) Several minor

• discrepancies, when combined,

. indicate a potential technical or programmatic concern.

Each AR will be:

a) Initiated by the EDSFI team member *.

b) Approved by the team leader.

c) Entered into the AR trackinq*database or log book.

• d) Evaluated* for applicable requlatory ( 10 CFR 21, so. 72 and so. 73) and internal reporting requirements.

e) Discussed with PSE&G points of contact for disposition and response.

2) Disposition Discrepancies, concerns and unresolved questions identified in an final AR will be dispositioned and responded to in accordance with NC.NA-AP. ZZ-0057 (Q).

17

d** - *"J-** - .-... -*""'--' ,*,;;:..._..:..... .->_..:.._ ., ,_;. . .....:. .. ,:~-.~~~~*--~-""--"---'"'--

.... ,_,._.... :..... -~-*.> ** ..:1, * .,,..::.. ..... _.~~-..:-~..J*~~* -- -~---*- ----

EDSFI

• team members will research, evaluate and interface with enqineerinq and station orqanizations as required to determine the validity and disposition draft ARs as follows:

a) Invalid The draft AR is not believed to be valid and justification/do6umentation for this disposition is provided with the draft AR response for closeout.

b) Valid - Information is not Available Information necessary to determine functionality cannot be found and action is necessary to re-create, . recalculate, or re-analyze as necessary.

c) Valid - Corrective Action Required If corrective actions are required (procedure

• change, drawinq revision, modification, etc.),

the AR will be:

(1) Evaluated to determine the scope and extent of the required modification or revision.

( 2) Evaluated to determine which PSE&G department has responsibility for implementation.

(3)

• Entered into the PSE&G tracking system and assigned an implementation due date as provided in NC~NA-AP.ZZ-0057 (Q):

3) Closure Draft ARs will be closed only on approval of the team leader. Closure of final ARs remaining open at the end of. the EDSFI will be the responsibility of the responsible PSE&G department. ARs should be closed when one of the followinq occurs:

a) All requested information is provided and is satisfactory, or b) Justifications demonstrate that the potential concern is invalid, or 18

~~~~~~~~~~~~~ ~.~-

' .. ~*-.... -~-*--*- ..* **-"-:.-=-... .....,..,,.t__ _,__ ,~,..~ .. ;..;;...._,_.:.i. .... : * ._.... ~~ ..... -----::._._..,;,:: ** _.~.,_,_,;._,,_._l_.~--:..,-'..... ~--

• _ _ .....__,,_...._. __ ---~--** - --

• -~

c) Corrective actions have been - satisfactorily implemented 13.0 BDSPI RBPORT At:tthe completion of the EDSFI, a* final report will be p'repared, reviewed, and approved. A draft of the final EDSFI Report will be submitted for PSE'G review and concurrence within two weeks followinq completion of the EDSFI.

The final EDSFI Report, with comments incorporated, will be submitted to PSE&G within one week f ollowinq receipt Qf comments.*

The EQSFI Report will consist of the followinq:

Executive Summary - A qeneral summary of the EDSFI and its results

1.0 INTRODUCTION

2 *0 ELECTRICAL SYSTEMS-2.1 Class *1E 4160 Volt AC System 2.2 Class lE 480 Volt System 2.3 Class lE 125 Volt DC and 125 Volt AC System 2.x (Others as need~d)_

2.5 conclusions 3.0 MECHANICAL SYSTEMS 3.1 EOG Support Systems 3.2 HVAC Systems 3.x (Others.as needed) 3.3 conclusions

• 4.0 EDS EQUIPMENT 4.1 Equipment Walkdowns 4.2 Equipment Modifications 4.3 Equipment Testinq and Calibration 4.x (Others as needed) 4.4 conclusions 5.0 ENGINEERING AND TECHNICAL SUPPORT 5.1 Orqanization and Key Staff _

5.2 Root cause Analysis and corrective Actions 5.3 Enqineerinq Involvement in Operations 5.4 Self Assessment and Traininq 5.x (Others as needed) 5.5 Conclusions 19

6.0 GENERAL CONCLUSIONS Appendix A - Documents Reviewed

• Appendix B - Personnel Contacted Ap~endix c - List of EDSFI Team Members App'endix D - Status of Action Requests (ARs)

Appendix E - Draft Action Requests 20