ML20086C424

Design Engineering Program Assessment Executive Summary

ML20086C424
Person / Time
Site:	Waterford
Issue date:	09/05/1991
From:	Azzarello R, Bass L, Brennan T ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20086C416	List: ML20086C424
References
NUDOCS 9111220173
Download: ML20086C424 (63)

Text

{{#Wiki_filter:. . ~ . . - . - - . _ - - _ - . . . . - - _ . . . - - - . . . - . . . _ - _ _ - . . - . . . , i i e i WATERFORD 3 DESIGN ENGINEERING PROGRAM ASSESSMENT +

                                                                         . EXECUTIVE 

SUMMARY

h i t i l l PREPARED BY: S.. - */ /f'/ g f L.L. Bass Date'-

                                                               '   /                                  't k - /r'
                                                                                                      -/,,

PREPARED BY: _ Y W: 2% Date T.P. Brennan

                                                                          - '        'O                    I APPROVED BY:

R.G.-Azzarelld' Date , 9111220173 911118 _ PDR = -. ADDCX 05000302 pyn

   'P
   - .. c . _u,.-.-.._.__,        _ . _ ._ . , _ ;,, , _

WATERFORD 3 DESIGN ENGINEERING PROGRAM ASSESSMENT EXECUTIVE

SUMMARY

1. INTRODUCTION II.

SUMMARY

OF PROGRAM ASSESSMENT RESULTS A) Major Recommendations B) Prioritization III. RESULTS OF .NDIVIDUAL AREAS ASSESSED A) Scope B) Enhancements C) Observations D) Strengths i i i l l DEASSM/ZERINGJ PAGE 2 of 41 SEPTEMBER 4, 1991

INDEX INDIVIDUAL AREAS ASSESSED AREAS ASSESSED PAGE A) Mechanical Systems (NSSS, BOP, HVAC) 10 B) Inservice Inspection 11 C) Motor and Air Operated Valves 12 D) Relief Valve Setpoints/ Capacity 15 E) Nuclear Engineering / Safety Analysis 16 F) Piping / Supports 18

                                                                                                ^

G) I&C Design and Setpoints 21 H) Equipment Qualification (EQ) 24 I) Civil / Structural 25 J) Appendix R/ Fire Protection 27 K) Reg. Guide 1.75/ Electrical Penetrations 28 L) Drafting /As Built Drawings- 29 M) Design Change Process 30 N) Design and System Engineering Interface 32 l

0) Calculations. 34 i

l P) Software Control 37 Q) Procurement 39 l PAGE 3 of 41 SEPTEMBER 4, 1991 DEASSM/ZERINGJ

P l

                                                                                                                                    \

I. INTRODUCTION During June and July, 1991 Entergy Operations conducted an assessment of the Design Engineering Program at Waterford

3. This assessment had two major objectives.  ;

The first cbjective was to identify any Waterford 3 Design i Er.gineering program areas needing enhancing or improvement. Early in 1991 the NRC completed an Electrical Distribution System Functions 1 Inspection at Waterford 3. This inspection identified the need to  ; accelerate design documentation upgrade programs in the electrical area. To ensure that the upgrade programs were consistent throughout Design Engineering, Entergy Operations decided to assess major design engineering programs.  ! The second objective was to use the assessment as an opportunity to bring together design engineering personnel from each of the Entergy Operations sites. This approach takes advantage of the significant technical expertise within the system, as well as encourages closer ties and better communication within Entergy operations. Peer Group Teams were established consisting of over fifty representatives from the three plants and the corporate office. These teams were assigned responsibility for the assessment of seventeen major functional areas within Design Engineering. The assessments did not identify any major programmatic deficiencies. Several program enhancements were identified for the future upgrade of Waterford 3's design engineering programs. In addition, there were a number of observations which will be considered for incorporation at a later date. Section II contains a summary of assessment results and l Section III lists the enhancements, observations and strengths identified by each peer group. The assessment results contain both enhancements and observations, An enhancement is considered to be a program improvement which is considered necessary'to bring the program to a new higher level based on todays industry and requiatory expectations. Observations are considered optional. These items are suggestions or potential good-ideas which. require further evaluation to determine if and to what extent a change L should be made. Implementation and status of all - observations will not be formally tracked. DEASSM/ZERINGJ PAGE 4 of 41 SEPTEMBER 4, 1991 l

   . -.                               B)     Design Guids

1. A Design Guide will be prepared tor use within the Mechanical / Civil discipline to help the user in reviewing and assessing an existing calculation for format and completeness to todays' standards. (This will be a Mechanical / Civil Design Guide since other programs have been established in the other disciplines and greater than ninety percent of calculations are the responsibility of the Mechanical / Civil discipline.) This Design Guide i will be prepared by October 31, 1991.

2. A Design Guide will be prepared for use within the Mechanical / Civil discipline to describe to the user how to evaluate piping systems in esses where no formal calculation currently exists, i.e., in cases where the " Chart Method" was applied. This Design Guide will be prepared by December 31, 1991.

3. A Design Guide will be prepared for use within the Mechanical / Civil discipline to describe to the user how to do an operability assessment of piping systems and associated pipe supports.

This Design Guide will be prepared by December 31, 1991.

4. A Design Guide will be prepared to establish the review guidelines for nozzle evaluations contained in existing Waterford 3 calculations.

The guidelines will then be applied to determine + if or when additional evaluations and/or calculations may be required. This Design Guide will be prepared by December 31,.1991. C) Design Basis Documentation

1. Safety Analysis Documentation - The Safety &

Eng.'neering Anslysis Group will continue to develop detailed documentation of the design basis accident analyses. A detailed specification has'been written and is being used l to develop the Safety Analysis Design Basis Documentation (SADBD). The three events l currently being analyzed are the " Pre-trip" Main ! Steam Line Break, Post-trip" Main Steam Line Break, and Large Break-LOCA. In 1992, at least 6 additional events are planned to be completed. It is anticipated that by doing at least 6 events per year, the major design basis accident analyses for Waterford 3 can be documented by 1995. PAGE 7 of 41 SEPTEMBER 4, 1991 DEASSM/ZERINGJ I

         + r.,,e-m , , , , - -- - - -  -,<,w  <,+,,,-,.--g,      nyen,   -ry        .,vg   , ,    - - - , -          e :- r-  y ,- ,e

2. Fire Protection Program Design Basis Documents -

Developing a DBD would consolidate Fire i Protection documentation that is now difficult  ! to retrieve from the document control system. A Fire trotection Program DBD is scheduled for completion by December 31, 1993.

3. In order to ensure that the standard installation details of cable tray and conduit supports contained in the " Cable and Conduit List" LOU 1564-B-288 have an adequate design basis, a review of the supporting calculations will be completed by December 31, 1991.

4. In order to ensure that the standard tubing installation details contained in the

                            " Instrument Installation Details" LOU 1564-B-430 have an adequate design basis, a review will be performed and supporting calculations will be prepared as necessary. This effort is forecast for completion by December 31, 1992.
 ~

5. A detailed review of seismic qualification documentation will be done (with a summary prepared) to determine that every safety-related component has a qualification document on file.

This summary report, will contain such information as equipment description, qualification report number, basis for qualification, etc. This is expected to be a long term task with a completion by December 31, 1994. D) Procurement Engineering

1. The NUMARC Comprehensive Procurement Initiatives review and assessment looked at 15 specific areas in the procurement process. The improvements idsntified for engineering were in the areas of:

• Engineering involvement in Performance Based Supplier Audits (PBSA).
• Systematic technical evaluations for replacement items.

Providing necessary engineering and technical resources to assure technical performance capability of procured items. DEASSM/ZEttINGJ PAGE 8 of 41 SEPTEMBER 4, 1991

Reorganization changes and the transfer of routine procurement functions will allow i i Procurement Engineering to take responsibility for technical evaluations of replacement items., development of procurement specifications, assisting in FBSAs and other procurement engineering functions. This will assure compliance with the NUMARC initiatises by July 1, 1992. E) De_ sign _ Contro.1/Configur_ation Managernent;

1. Waterford 3 Design Engineering Procedure NOECP-318 is currently being developed in order to proceduralize the screening and trackina of design changes that introduce any new materials into the Reactor Containment Building (RCB) for materials that could contribute to the generation of hydrogen gas post LOCA, and for changes in containment net free volume and passive heat sinks as well, lasue of the procedure is expected to be completed by December 31, 1991, with training of personnel to be completed by March 31, 1992.

2. Maintenance of Fire Hazards Analysis (FHA)

(Combustible Loading) - Waterford 3 does not have a procedure in place to update the FHA yearly. The recommended approach in to implement a procedure to perform the FHA and provide annual updating. The FHA is

                     .         currently scheduled to be updated by December 31, 1991. The procedure which will specify requirements for future updates will be in place by December 31, 1992.

3. Waterford's 3 proposed software cch?.rol procedure NOECP-015 " Software Preparation, certification, Control, and Retirement" will enhance the computer software control program that is presently being used. This procedure will provide the overall coordination of the Design Engineering Program requirements for software control. This procedure is expected to be completed by December 31, 1991.

DEASSM/ZERINGJ PAGE 9 of 41 SEPTEMBER 4, 1991

                                                                                      $th

                !!I. RESULTS OF INDIVIDUAL AREAS ASSESSMENTS A)  Ma c_h_a n i c a_1 S y s t e m s ___( N S S S_ ,_ B o P , H V A C_1

1. Scoce The mechanical systems peer group discussed ,

their respective organizational structure, staff composition and reporting lines. The following six subject areas were reviewed: Design Changes Problem Evaluation /Information Request Design Basis Documents Document Revision Notices Calculations Nonconformance Condition Identification

2. Enhancementa Waterford 3 Design Engineering Procedure NOECP-318 is currently being developed in ordet to proceduralize the screening and tracking of desion changes that introduce any new materials into the Reactor Containment Building (RCB) for materials that could contribute to the generation of hydrogen gas post LOCA, and for changes in containment net free volume and passive heat sinks as well. Issue of the procedure is expected to be completed by December 31, 1991, with training of personnel to be completed by March 31, 1992.

3. Observationa None

4. Strenoths A single procedure and forms are being used for the revision of numerous types of documents as opposed to a different procedure for each t/pe.

The Waterford 3 procedure (NOECP-306) allows the use of a Document Revision Notice (DRN) to initiate changes to drawings, technical manuals, DBDs, DCPs and specifice.tions using the same DRN process and form. At other plants, changes to each of these controlled document types occurs under a different procedure for each type. The use of_a single procedure, process and form at Waterford 3 greatly simplifies procedural requirements and increases ussr familiarity. DEASSM/ZERINGJ PAGE 10 of 41 SEPTEMBER 4, 1991

B) Inservice __!nspection

1. Scope This peer group performed an assessment of the following ISI program areas:

Administrative procedures Ten Year Program & Summary Report Formats Section XI repair / replacement interface with Ten Year Program Processing /Handijng of unacceptable flaws identified during Inservice Inspection Process for controlling changes / revisions to the Ten Year Program

• Logic used for determining " Additional Examinationt" due to unacceptable exam results

2. Enhancements As a result of an NRC open item, a need was identified to develop a formal means to A nplement changes to the Waterford 3 Section XI Te? Year Program outside the normal revision process. This will require a revision to NOECP-251 which will be completed prior to the next refueling outage.

3. Qbservatiqna c) Desien Engineering should consider moditsing the review and identification process used for " reportable indications" detected by volumetric / surface inspection during a refueling outage.

b) Design Engineering should consider evaluating Section XI activities ano how t responsibility for managing these activities is assigned on site. It appears thet one group should have overall responsibility for Section XI activities. c) Design Engineering should consider increasing the degres of involvement which they should have with the day-to-day functions of the Section XI Repair / Replacement process. SEASSM/ZERINCJ PAGE 11 of 41 SEPTEMBER 4, 1991

i 1

4. Strenoths a) Waterford 3's Directive entitled "ASME Section XI Responsibilities" describes section XI responsibilities wherever they apply, Plant or Design Engineering. This is considered te be a strength, b) The Ten Year Inservice Inspection P,ogram was considered to be a strength. Thi format, as well as the information presented, is very straight forward and thorough. Waterford's program content and format was initially developed by the present Inservice Inspection Group. One specific strength of Waterford's program '

was that all components are distributed and completion is calculated by code itcm in lieu of code cz6tegory. Although this is a very exhaustive way of calculating

                                                             . comp { L on, it definitely provides for a
          ~

more4 thorough distribution of exams over the interval, which in turn provides a high4r assurance of structural reliability. c) The ' process of program expansion" when comp)nents fail to meet acceptance criteria was thought to be a strength. Waterford has in place a " predetermined" scope for expanding when components fail to meet acceptance criteria. Waterford looks at each Code class 1, 2, or 3 lines and determines which lines would require examination in accordance with ASME Section XI, if a comporient on that line was to fail. Although this was a considerable effort, it was done during a non-cutage timeframe f.n lieu of trying to do this on a  ; case-by-case basis during refuelings. C) Motor and Air Operated Valvss_

1. Scoce c This peer group discussed the following subject armas:

a) MOV Program: Design Support organization

• Review of each plant's generic letter 89-10 commitments Point by-point review of generic letter 89-10 and supplements Design basis review progress (generic letter 89-10)

PAGE 12 of 41 SEPTEMBER 4, 1991 DEASSM/ZERINGJ

• Production of MOV setpoint calculations Interface between Design and Maintenance Encineering Setpoint calculation methodology
• Setpoint control and documentation Approach to differential pressure testing Control of data in databases
• Resource allocation to MOV Program Coot savings gained by system-wide approach to MOVs b) AOV Programs Design support organization Generic letter 88-14 responses Waterford 3 AOV program current status
• Waterford 3 Design Engineering ret.conse to IE Notice 88-94 Waterford 3 Design Basis Docuraent Topical Report on Q AOVs Discussion of proper design engineering support for AOV program Future plans for continuation or formation of AOV programs at GGNS and ANO Cost savings gained by system-wide approach to AOVs

2. Enhancements MOV Programs a) The Maximum Estimated Differential Pressure (MEDP) and setpoint calculat ens for RF1 and RF2 should be formalized to provide good documentation.for the MOVs tested during those two refueling outages. This activity is forecast to be completed by March 1, 1992, b) The completion of the design basis review, namely the seismic qualification and electrical reviews, should be documented as soon as possible to allow sufficient response time to address any problems which may be discovered. This activity is forecast to be completed by March 1, 1992.

l l l

     .DEASSM/ZGINGJ             PAGE 13 of 41                                 SEPTENBER'4, 1991 l

c) A document which encompasses all inputs and affected groups in the MOV program and describes the dynamic testing approach should be prepared. This would serve both as a roadmap document for review by others and make all parties aware of their responsibilities and potential NRC inspection exposure. This would especially help secondary groups such as IST, Training, Industry Events Analyses, etc. This document is forecast to be completed by March 1, 1992. AOV Program: None.

3. Observations MOV Programs a) It is understood that in many cases the MEDP will not be able to be achieved due to postulated worst case scenarios within the MEDP calculations. For each valve, the maximum pressure which is expected to be achieved during testing could be determined with actual plant parameters. A formril industry wide resolution of the difference in these two values is needed to satisfy the concerns that the valve will function properly at the higher differential pressure.

b) While the Waterford 3 MOV setpoint calculations are complete, revisions will likely be required as the program progresses. Failure to have engineering standards which document the approach taken in the preparation of these and other program analyses will make the transition of new personnel into roles of responsibility more difficult. Significant turnover of experienced personnel will have little impact on program support if calculation guidelines are prepared. c) Although the manual operation of MOVs is not specifically discussed in Generic Letter 89-10, a review of the meenanical advantage within the handwheel gearing may demonstrate that some valves can be over stressed and possibly damaged with l excessive handwheel torque. Design Engineering should consider calculating l j equivalent rim pull forces to provide i Operations and Maintenance personnel limitations for manual valve operation. DEASSM/ZERINGJ PAGE 14 of 41 SEPTEMBER 4, 1991 l

d) The establishment and verification of test equipment accuracy has been the subject of much attention. MOV7.TS and VOTES both were issued a Notice of Non-Conformance en May 24, 1991, in which the published accuracy of their respective test equipment was questioned. A statement of and justification for the accuracy being used by the MOV program at Waterford 3 is neces1ary however it is uncertain at this time to what extent the Notice of Non-Conformance will affect Waterford 3. Further evaluation will be needed when the NRC and vendors resolve the Non-Conformance. AOV Program: Waterford Design Engineering should formulate setpoint calculations and procedures based on the existing MOV Program methods in order to be in a position to support the Maintenance Engineering group in their testing of AOVs when this program is upgraded in the future.

4. Strengths AOV Program:

The Design Engineering group at Waterford has produced a topical Design Basis Document for all the "Q" AOVs The group has also prepared sizing calcu' .tions for all "Q" AOV accumulators which take i ;o account normal systen. leakage as well as air gage during the operation of the AOV. These A.,cuments provide an excel lent design basis kpurce for future documer.tation, modifications;f f and evaluations for incorporation into an AOV De: sign Basis Document. D) Relief Valve Satooints/ Capacity System Pressure / Temperature Ratings

1. Esppg i

This Peer Group's assessment addressed selected areas of the Mechanical design discipline. Subject areas reviewed included: Existing relief valve setpoint/ capacity program Location of setpoint information

• Basis and verification of setpoints System line lists Pressure / temperature calculations DEASSM/ZERINGJ PAGE 15 of 41 SEPTEMBER 4, 1991

i

2. Enhancements Valve and line list system pressure / temperature '

problems have been identified in the industry. Therefer', Waterford 3 will develop guidelines for the .eview of cciculations to substantiate system pressures / temperatures, including updating the line list as necessary. The ' guidelines for this review will be provided in the Design Guide identified in Section II B.1. This Design Guide is expected to be prepared by , October 31, 1991.

3. Qkservations Censider developing a single controlled and verified listing of relief valvo pressure setpoint/ capacity ratings to alleviate having to reference multiple controlled sources.

4. dtrengths None E) Nuclemy. Engineering i / Safety Ana11s_i_s

1. $.A221 The assessment team for Nuclear Engineering / Safety Analysis met to discuss the specific areas of analysis tools, NSSS Design Interface,. Safety Analysis Design Basis Documentation, and Reload Analyses. Particular strengths at each of the sites were discussed.

24 Enhancements a) The Safety & Engineering Analysis Group will continue to develop detailed

                                       ' documentation of the design basis accident analyses. A detailed specification has been written and is being used to develop the Safety Analysis Design Basis Documentation (SADBD). Three events are being done currently and will be completed by the end of 1991. These events are the
                                        " Pre-trip"' Main Steam Line Break,
                                        " Post-trip"' Main Steam Line Break, and Large Break LOCA.      In 1992, at least 6-additional events are planned to be completed. It is anticipated that by doing    ,

at least 6 events per year, the major design basis accident analyses for l Waterford 3 can be documented by 1995.

                ,                                                                        3 l

i. l DEASSM/ZERINGJ PAGE 16 of 41 SEPTEMBER 4, 1991 L. _

l b) NSSS Design Interface Design change procedures will be revised by i December 31, 1991 to incorporate a review, as warranted, of conceptual design packages and final design changes by the Safety l Engineering Analysis (SEA) group. This review would focus on the impact of the change on safety analyses, the Probabilistic. Risk Assessment model, and . the 10CFR50.59 safety evaluation. It would not be a detailed review of all aspects of - the design change. This would increase the awareness and involvement of the analysis group in the design change process.

3. Observations a) Analysis Tools Waterford 3 should consider obtaining i sof tware packages through the flational Software Development Center that are in the public domain. This would help to quickly  ;

address specific issues in a more detailed manner. Waterford 3 should consider enhancing (in a cost effective manner) the capability to  ; perform more detailed scoping or best t estimate transient analyses. Computer codes such as a PC version of RETRAN, RETACT, or CENTS could be used for a variety of different accidents to help i resolve problems or evaluate design changes. The ability to. address a broader range of events should greatly increase the capabilities of the SEA group, b) Reload . More emphasis should be placed on review-of the reload "groundrules package" within i Design-Engineering and other plant departments. Esis will improve their f knowledge and understanding of the j p parameters and systems that have.an impact - L on safety. analysis. . It will also lead-to a more comprehensive review of the reload safety analysis groundrules.

4. Strengths None L

PAGE 17 of 41 SEPTEMBER 4, 1991 DEASSM/ZERINGJ 1

F) Piping / Supports

1. Scope This Peer Group's assessment included the following specific subject areas: l

• No=zle Load Design System Design Interface I&C Tubing Design
• Piping Design
• Pipe Support Design Fatique Monitoring Program Conduit Support Design Erosion / Corrosion

                                            .2.       Enhancements a)       A Design Guide will be prepared for use within the Mechanical / Civil discipline to describe to the user how to evaluate piping systems in cases where no formal-dedicated calculation currently exists, i.e., in                                                                 ;

cases where the " Chart Method" was applied. This Design Guide will be prepared by e- December 31, 1991. b) A Design Guide will be prepared for use within'the Mechanical / Civil discipline to 4 describe to the user how to do an operability assessment of piping systems and associated pipe supports. This Design Guide will be prepared by December 31, r 1991. , c) A Design' Guide _will be_ prepared to establish the review guidelines for nozzle evaluations. contained in existing Waterford' ' 3 calculations. . The guidelines will then i be applied to determine if or when additional evaluations and/or calculations may be required. This Design Guide will be  ; prepared-by December 31, 1991, d) In order to enhance our documentation.on nozzle loading, an initial review-will be performed on safety related nozzle loading calculations by December-31, 1991. If required, it is expected that the

• calculations / analysis will be redone by December 31,-1992.

l l ll PAGE 18 of 41 SEPTEMBER _4, 1991 DEASSM/ZERINCJ. l s,_.. _. a ._ _.. n ,___ - _ _ _ __ _ _ . ,_, _ . - - . - . _ - . . _ , , . . . , , _ - . - - .-

e) In order to ensure that the standard installation details of cable tray and conduit supports contained in the " Cable and Conduit List" LOU 1564-B-288 have an adequate design basis, a review of the supporting calculations will be completed by December 31, 1991, f) The piping strees design guide will be revised to require the transfer of new calculated piping movements to the Design Engineering I&C group when applicable. This will ensure that tubing movement is adequately addressed in new designs. This revision will be completed by December 31, 1991. g) In order to enhance the weld traceability program, Waterford 3 will conduct a review of safety related work authorizations and create a computerized data base to identify welding related work performed on safety related components. The data base will provide information such as reference drawing number, component number, weld number and type, work authorization number, date work was performed, welder ID and welding material data. It is expected that this database will be completed and engineers trained in its use by March 1, 1992, h) In order to ensure that the standard tubing installation details contained in the " Instrument Installation Details" LOU 1564-B-430 have an adequate design basis, a review will be performed and supporting calculations will be prepared as necessary. l This effort is forecast for completion by December 31, 1992.

1) In order to address recent industry issues in the Mechanical / Civil area, position papers will be established in specific areas of pipe stress analysis and pipe support design to define the Waterford 3 design criteria on the following subjects:

Flange load qualification Effect of pure torsion / warping torsion Line list information and operating modes Two bolt anchor plates l These position papers will be prepared by mid 1992. Oc.ASSM/ZERINGJ PAGE 19 of 41 SEPTEMBER 4, 1991

3. Observations a) Consider providing, in a Design Guide, direction and/or guidance to the stress engineer to ensure that plant operating modes are properly considered in the piping analysis.

b) Consideration should be given for l transferring the control of the l B430 tubing specification to the piping group, c) Consider re-evaluation of the present procedure guidelines to System Engineering on lead shielding additions to the plant to require the need for a more detailed review by the piping group. d) Design Engineering should consider expanding the existing fatigue monitoring program to cover additional components. e) Consider development of a communication form for requesting Design Engineering Civil approval for unique conduit supports. This would enable Design Engineering Electrical to better track unique supports. f) Consideration should be given to transferring the control of the B-288 conduit support drawings to the Design Engineering Civil group. g) Consider using available computer software in the industry to provide trending capabilities for erosion / corrosion component replacement and life expectancy. h) Consider referencing jet impingement drawings in the Design Engineering Design Guide along with guidance provided to l evaluate the effects of jet impingement.

1) E"aluate the need for reanalyzing impingement break criteria for possible elimination of intermediate arbitrary breaks.

4. Strengths a) Line list is maintained and controlled.

b) Line list changes are reviewed by the Design Engineering Mechanical Piping group. l DEASSM/ZERINGJ PAGE 20 of 41 SEPTEMBER 4, 1991 l

c) pipe stress design guide is available and easy to use. d) Design Engineering support for the erosion / corrosion program is very positive. This includes preparing for the inspections and resolution of concerns. G) I&C_Desi_gn and Setpoints

1. Sccce The PEER Group for the ISC engineering discipline conducted an assessment of the following subject areas:

a) The Setpoint Control program - administrative procedures, and organizational responsibilities. b) Setpoint/ loop accuracy calculations - comparison of W-3, ANO, and GGNS content, format, and best practices, c) Control loop diagram and Logic Diagrams - Review of types of drawings available at Waterford 3 SES, and comparison with the drawings used by ANO and GONS. d) General discussions of how Design Engineering functions are accomplished among the three plant locations relative to the above discussion areas.

2. Enhancements In order to bring our instrument setpoint program up to todays' standards, Waterford 3 has committed to a Instrumentation Setpoint Calculations / Design Basis Program. Fifty critical loop calculations are expected to be completed by the end of 1991. The program is being accelerated such that the balance of the complex safety related calculations (approximately seventy five) are expected to be completed by December 31, 1992. It is anticipated that the balance of this effort will be completed by December 31, 1994.

DEASSM/ZERINGJ PAGE 21 of 41 SEPTEMBER 4, 1991

    ~                     .      -     -                    ._                   __

3. Obsgrvattana a) A controlled methodology and process for performing scaling (calibration) calculations should be considered, to ensure that the engineering units values for a setpoint are correctly converted to control system signal values (volts, milliamps, psi), during instrument field cal.brations, Waterford Design Engineering I&C should consider developing a scalina procedure for controlling the process and assuring consistent calculations methodology. However, Industry practice should be investigated by the I&C Peer Group to survey best practices as to which plant organizations abould have responsibility for performing instrument scaling calculations.

b) Waterford 3 should consider incorporation of MOV torque switches, electrical relays, relief valves settings, and circuit breakers into the statien setpoint control and documentation program. The original Instrumentation Setpoint and Design Basis Program Implementation Plan for Waterford 3 should be expanded to include the additional setpoint types in the setpoint controls / documentation program, c) Waterford 3's Setpoint Calculation packages' formats are satisfactory, with no major recommendations resulting from the peer team reviews. It was recommended that, where intemaediate calculations are L necessary to determine an input to an error i calculation, we include these intermediate calculations in the main body of the l setpoint calculation. Also, Waterford 3's review of the setpoint calculations to date L indicates that the re.!erances section should_be expanded to include all of the drawings and other tecnnical references that are actually unec in performing the calculation. This would greatly aid in design verification of the calculation, d) The Design Engineering I&C Peer Group should consider invectigating industry practice relative to the inclusion of the inaccuracies associated with the operator's reading of control panel instruments for Isch-Spec surveillance tests, EOP's, etc., in instrument setpojnt calculations. DEAESM/ZERINGJ PAGE 22 of 41 SEPTEMBER 4, 1991

   .    .-     .     -      . - .  . - . - , - ~ - -                       - - .   - . . . - - . .              .
     ,     -,-                          e)   _

Instrument Loop Diagrams - ANO,.GGNSe and ' Waterford-3 all have controi loop / schematic diagrams.(CLD's) of_similar formats which show the field instruments, control system panels, readout devices,.and the associated ' wiring. A number'of control loops:at_ , Waterford 3 are not covered by theseLtype drawings. An evaluation should be_ l considered to identify those. additional-loops where-CLD'n-would enhance plant operations and ns. atenance, and recomnendations and cost estimates prepared-for the proposed new drawings. . f) Investigate development ef P&ID's as

                                                     " overlays" to existing plant flow diagrams,    _

as part of the Waterford 3 Computer Aided Drafting (CAD) program for Waterford 3 drawings. The scope would-_ include approximately 60 plant flow diagrams plus some equipment vendor skid systems-(number to be determined). g) Waterford 3 does.not have "and/or" logic diagrems_for the'Ebasco designed electrical relayJcontrol circuits, and has only elcctrical elementary drawings for a limited number:of the control wiring diagrams. Waterford 3 should consider identifying those logic diagrams needed for safety-significant-plant systems first, and propose _ development of logic diagrams for these-systems. Plant-training, Systems. Engineeriny- Operations, Maintenance and Design Engineering -would :be consulter 1 for inputsto determine needs and-priorities. 4, Strencths-Waterford 3=has a v7r'-~agLrelationship and information interchrng, interface between Design Engineeringj GC and Plant Maintenance I&C that

                                                                                 ~                                  '

is a: considered strength. -The_ good cooperation and'mutualieffert expended between these two organizations to generateiand~ review the setpoint calculations and prccedures is of - particular note. This:has served to enhancetthe overall' effectiveness and usefulness of the setpointLprogramLat Waterford-3. - PAGE 23 of 41 SEPTEMBER 4, 1991 DEASSM/ZERINGJ

 .     .-. . =.        -    .            . = =           -   .-   . , ,

 *

• H) Equipment Qualifiention (EQ1

1. Scope The EQ Peer Assessment Group discussed areas of EQ responsibility and coordination with Design Engineering. The major assessed areas were:

Program responsibilities and procedures Determination of environmental parameters

• Design change package review Purchase requisition review Part substitute evaluations Maintenance of EQ documentation EQ maintenance inputs

2. Enhancements None

3. Observations a) Consider developing a system based

                                    " System Function Diagram" which is primarily a logic block diagram indicating the required system component functional status to initiate a required safety or design basis function. This logic diagram would allow the user to quickly evaluate a plant system component to determine if its failure will result in the inability of that system to perform its' intended safety related function.

b) Consider creating an Environmental Specification Data Sheet. This approach of identifying the plant rooms, environmental parameters, applicable EQ equipment and most importantly, the references to environmental parameter calculations, provides a useful tool for traceability and auditability. I 1 l PAGE 24 of 41 SEPTEMBER 4, l'e 91 l DEASSM/ZERINGJ 1

 .((
        ~

4. Strengths a) Waterford 3 is presently adding environmental qualification test report

                                                 . summaries into the Additional Information Screen of the SIMS database. This summary includes the' test sequence,_ values obtained and results of the qualification testing.

Presently this is not an approach which-is widely used in the industry Lut it.does provide plant wide access (and in this situation, system wide access) to qualification information. The information provided is equal to or exceeds that required by the NRC for the NUREG-0586 reports._This provides the information required for any potential future NUREG-0588 type report submittals to the NRC.- b) Waterford 3 maintains a comprehensive temperature monitoring program using RTDs located inside containment which are relocated during each refuel._ The monthly average temperatures are included in the plant quarterly trend-report and are also part.of the permanent plant records for future access.- This process is advantageous for providing sufficient justification pertaining to extending qualified lives, re-evaluating qualified lives.for EQ equipment located in hot spots and for potential Plant-Life Extension (PLEX) activities, c) _ Waterford 3-is-presently conducting an EQ File upgrade project. The-purpose of this effort is to! conduct a review of the j existing EQ:sssessments to update file-E infctmation considering completeness of. i assassment information and focal areas of regulatory interest. This effort can be categorized as the implementation of , " lessons learned" since the last EQ File update. I) Civil / Structural

1. Scone.

The Peer Group met to perform an assessment of-their functional area. The specific topics addressed included: Comparison of areas of_ responsibility Seismic qualification reports DEASSM/ZERINGJ PAGE 2? of 41 SEPTEMBER 4, 1991 L-

• Computer software for structural analysis Masonry block walls
• Component support load reconciliation on the structure

2. Enhancements a) A Design Guide will be prepared for use within the Mechanical / Civil discipline to help the user in reviewing and assessing an existing calculation for format and completeness. (This will be a Mechanical / Civil Design Guide since other programs have been established in the other disciplines and greater than ninaty percent of calculations are the responsibility of the Mechanical / Civil discipline.) This Design Guide will be prepared by October 31, 1991.

b) A detailed review of seismic geslification documentation will be done ( w.' .t a summary prepared) to determins that evwry safety-related component has a qualification document on file. This summary report, will contain such information as equipment description, qualification report number, basis for qualification, etc. This is expected to be a long term task with a completion by December 31, 1994.

3. Observations a) A new record system is being considered to control seismic qualification documents at Waterford 3 which would address, as a minimum, the following:

The control of new qualification documents at W-3

                                  -   the review and acceptance process
                                  -   the filing / retrieval process The control of existing documents
                                  -   the revision / update process
                                  -   the retrieval process b)    Input qualification summary report developed in I) 2.b) above should be considered for incorporation into the Station Management Information System.

DEASSM/ZERINGJ PAGE 26 of 41 EEPTEMBER 4, 1991 I

c) Since few formal design guides or design I criteria exist for Civil / structural design at Waterford 3, it is difficult for the engineers to obtain the necessary design criteria for all of the different types of designs required without a significant investment of time. Consideration should be given to the development of generic design criteria manual which would provide the approach to be used by the engineers for the most of the different types of designs.

4. Strengths The control of containment design parameters at Waterford 3 is considered to be a Strength, especially the control over protective coatings and addition of aluminum and quantity of steel for passive heat sink that effects peak pressure analysis.

_ J) Appendix R/ Fire Protecti_on

1. Scoce This PEER group discussed Design Engineering Fire Protection responsibilities and current Fire Protection Programs.

2. Enhancements a) Maintenance of Fire Hazards Analysis (FRA)

(Combustible Loading) - Waterford 3 does not have a procedure in place to update the FHA yearly. The recommended approach is to implement a procedure to perform the FHA and provide annual updating. The FHA is currently scheduled to be updated by December 31, 1991. The procedure which will specify requirements for future updates will be in place by December 31, 1992. b) Fire Protection Program Design Basis Documents - Developing a DBD would consolidate Fire Protection documentation that is now difficult to retrieve from the document control system. A Fire Protection Program DBD is scheduled for completion by December 31, 1993. l DEASSM/ZERINGJ PAGE 27 of 41 SEPTEMBER 4, 1991 -

1 1

3. observations a) Waterford 3 presently uses the Nuclear Penetration List to control the Penetration Seal Program. The recommended approach is to control penetration seals in a Design Engineering "living" documents file. These living documents would include d2 tails, test results and each penetration seal's history in a convenient file, b) Consider developing Piping &

Instrumentation Drawings (P& ids) or equivalent design guidelines related to Safe Shutdown. P& ids provide more information and are easier to follow than flow charts.

4. Strengths Presently, Waterford 3 uses maintenance contracts for fire protection systems that are located outside the Plant Controlled Area (PCA).

Waterford 3, ANO, and CGNS Fire Protection Engineers agree that negotiable maintenance contracts with local licensed fire protection contractors for systems outside the PCA is a good practice. This practice insures qualified maintenance and testing at a significant cost savings to the plant. K) 3eo. Guide 1.75/ Electrical Penetrations

1. Scope The PEER group covered the following areas during their assessment:

Electrical Penetrations Lightning Protection Design Change Package Process Reg. Guide 1.75 This assessment did not address electrical calculations since a commitment was made to the NRC to revise the safety related electrical design calculations as a result of the recent NRC EDSFI audit. (See item II.A.1 of this report).

2. Enhancements None

3. Observations None DEASSM/ZERINGJ PAGE 28 of 41 SEPTEMBER 4, 1991

4. Strengths Waterford 3 Design Engineering Electrical /I&C explicitly provide sustain fault analysis and overload protection for electrical penetrations.

L) D. rafting /As-built Drawings

1. Scoce The Drafting /As-built PEER group addressed the following specific subject areas: Document Revision Notices (DRNs), new' drawings, drawing revisions, use of sketches, vendor manuals, procedures NOECP-306 (DRN) and NOECP-315 (drawings), reports and "beancounts", FSAR figures, notification for instellation completion and document update, illegible d r as; i n g s , equipment and environment, facilities, organization, career development, drafter functions, clerical support, construction as-building, and CAD.

2. Enhancements Construction As-building: The " Redlines" program at Waterford 3 has been in process since late 1987 to control construction-era as-built information, and incorporate it into the affected design documents. The controlled originals of the affected documents were stamped to alert users of existing marked-up redline copies, available for reference in the Records Administration vault. Of the twenty-six initially identified categories of affected documents, twenty-two were prioritized to be scoped into the Redlines program. To date, the major work of nineteen categories has been accomplished, and it is anticipated to complete the Redline program by December 31, 1993.

3. Observations a) Consider elimination of the Document Update Jnitiation Request (DUIR): The Engineering Coordination Group's (ECG) Document Update database report, sorted by due date, should suffice for notification to the Drafting unit to initiate document update. For those cases 2dentified as prompt revision not required, engineers (at the proper time) could notify the ECG by returning a marked up printout to initiate document update. Form elimination would simplify the DRN/PDD control process, and save clerical processing time.

DEASSM/ZERINGJ PACE 29 of 41 SEPTEMBER 4, 1991

b) DRN "Before" Views: It is recommended to consider deleting the requirement to provide a "before" view as part of a DRN. Controlled drawing users already have this information. Time, paper and storage requirements for DRNs' preparation and handling would be reduced. The problem would be relieved of "on-hold" DRNs having ou dated information when the affected document has been updated for other changes. The disadvantsge is that DRN teviewers and approvers would not have the "before" information to compare with the proposed changes.

4. Strengths a) An established Illegible Drawing Program identifies problems from site-wide drawing users, determines if the problem is one of reoroduction or origins 1 quality, corrects illegibility problems, and provides feedback to the problem originator, b) Possessing a document scanner for CAD allows both fast and quality entering of a drawing into the system. Scanning original documents-rather than aperture cards yields much better quclity, and therefore less cleanup time is required. The ability to j scan in a document on demand allows CAD l

capability for a given new project on a moments' notice, l M) Desian Chanse Process

1. Scope The Design Change Process Peer group addressed the following specific subject areas: the DC process, a minor change process, design definitions, design reviews, QA interface, specifications, calculations, sketches, Bill of Materials, abandoned / spared equipment, acceptance testing, design package format, construction interface, DCP revisions (criteria and administration), expedited field changes, change trending, design inputs and design verification.

2. Enhancements None DEASSM/ZERINGJ PAGE 30 of 41 SEPTEMBER 4, 1991

3. Observations a) Abandoned / Spared Equipment: Dispositioning or tampering with abandoned or spared equipment is a larger concern than just Design Engineering developing Design Changes; anyone on site has the potential to impact abandoned / spared equipment while either developing configuration control documents other than Design Changes, or simply by performing maintenance or other duties in the plant. Therefore, instructions governing abandoned / spared equipment should be considered to be included in a site-wide visible document to decree accountability for this configuration control aspect upon all personnel. NOP-018, Configuration Control should include these instructions.

b) DE Internal Interface Form: No formalized process (other than a PEIR) is used _ effectively for an engineering discipline to request work by another discipline. A form documenting the specific request, with supervisory concurrence, could provide a trackable means to coordinate interdisciplinary activities and enhance the understanding of the request. Waterford 3 Design Engineering could better utilize the existing PILE program to suffice for this observation. The guidelines for the PILE program could be updated to include priorities and the activity tracking form. Also, some l guidelines could be established to help ! recognize the need to request other disciplines' expertise for support in

                              " engineering hazards" areas such as jet i                              impingement, Appendix R, internal flooding, 2-over-1, EQ, seismic, tornado, etc.

c) Specification Procedure: Design Engineering should consider the development of a design specification procedure. d) Calculatien Page Changes: Consider l establishing the process to allow making minor changes to approved calculations without immediately processing a fall revision. A page change process similar to procedures administration would suffice. DEASSM/ZERINGJ PAGE 31 of 41 SEPTEMBER 4, 1991

e) Modify the Bill-of-Materials: Consider changing the requirements for Design Engineering to provide the significant items rather than an all-inclusive list. Allow field engineering to compile the remainder. Engineers would interface with the materials coordinator and the warehouse to use stock materials as practicable. Design Engineering would give tolerances as applicable, and specify when substitutions may be allowed. f) Waterford 3 should consider trending and categorizinc causes for chances to approved and issued design packages. Such a program would be a valuable aid for noting program deficiencies, performance problems, or procedures' needs. g) DE involvement for Changes to Design: It is recommended to consider a broad-base terminology change for Waterford 3 to call

 .                                 " Design Changes" - all those (NOP-018)

Configuration Control processes that change design (e.g., DCs, SPEERs, SPDCs, NCIs, etc.). Each of these processes similarly accomplish required elements of the regulated Design Change process. It is further recommended to consider Design Engineering's review and/or involvement in developing these design change documents before their implementation.

4. Strengths The instructions presented in procedure NOEOP-303, Design Changes, for handling abandoned / spared equipment are good and comprehensive. This is a topic witn real potential impact on a plant's configuration and design control.

N) Design and System Encineering Interface

1. Scoce The assessment team reviewed engineering and

                            -plant procedures, as well as past responses to Problem Evaluation Information Request (PEIRs),

Spare Parts Equivalency Evaluation Report (SPEERs), and Temporary Alteration Request (TARS). DEASSM/ZERINGJ PAGE 32 of 41 SEPTEMBER 4, 1991

Design Basis Document (DBDs) and Setpoint

 ,                       Control Documents (SPDC) were also reviewed.

The Peer group met with and interviewed personnel within both Plant System Engineering and Design Engineering. .,

2. Enhancements None.

3. Observations a) Waterford 3 should consider a specific and formal training program addressing the

_ design engineering process including the Design / System Engineering interface. This training would be particularly helpful to all the engineers on site since at Waterford 3 System Engineering and Maintenance Engineering perform engineering evaluations for various programs that affect overall design and configuration control, b) In examining selected TAR's it was noted that the engineers were not consistent in performing engineering evaluations. Some had the understanding that a 10CFR50.59 was sufficient, some had performed calculations, etc. The Peer group felt that each evaluation should consider various aspects of the design parameters and make specific determinations of whether the aspects are applicable (e.g., there was not guidance to perform seismic or EQ evaluations). The engineering evaluation should also be documented consistently. I c) Consideration should be given to having a ! Duty Design Engineering Manager instead of L a duty engineer on shift during refueling I outages. d) Design and Systems Engineering have their i responsibilities in separate procedures. However, they are not integrated to have the division of responsibility clearly defined. A document distinguishing the responsibility would be helpful. l l DEASSM/ZERINGJ PAGE 33 of 41 SEPTEMBER 4, 1991

                                                                                                                                 .. l e)     :The Peer group felt that although the DE 4
    -                                                           organization had a_ procedure on how engineering _ calculations should be done, there were no. plant procedures to_give guidance'to System and Maintenance Engineers. - Consideration should be given to ensure that.any engineer' 1 organization that performs calculations ave a procedure                         ,

that delineates requirements, guidance, ~l approvals, design inputs, etc.  ! l f) A competent work management system (currently.beinn implemented at Waterford 3 l thru the integration of all Design Engineering activities into the Project 2 scheduling program) will assist in the Design / Systems Engineering interface by , ensuring that both organizations agree on i the priority of work items. The development of the Work Management System

                                            ,                    at Waterford 3 should be continued.

g) Evaluate the need for the establishment of one organization responsible for vendor manual updates and changes to avoid conflicting information and errors.

4. Strengths a) The Waterford 3 Design Change. Process (DCP) procedure (NOECP-303), especially the ,

guidance on. spare / abandoned equipment, is set-up-well, b) !T he Waterford 3 practice-of having Design Engineering perform _the-document close-out for plant modifications is good. O)- Calculations i: 1. Scone The' Design Engineering Program Assessment Calculation Review Team discussed the total-calculation process from identification of'the need forca calculation through the permanent filing process-for each. The.following basic program affecting qualities were established to be discussed:

                                                            '    Big picture description of the calculation-programs

• Define controlling procedures and guidance documents PAGE 34 of 41 SEPTEMBER 4, 1991

          . DEASSM/ZERINGJ

Define individual personnel responsibilities Identify the process of controlling calculation numbers, i.e., a calculation index Define training requirements and programs Define historic and/or current program issues and problems Define the current status of any on-going or planned enhancement initiatives Discuss calculations and the modification process Discuss calculations and the as-built process Discuss regulatory and industry expectations and perspectives Discuss the process and control of use of computer codes for calculations Discuss the technical review and verification process Each of the areas identified above were _ discussed, many of them in minute detail. The level of detail varied depending on the relative differenca between the three nuclear sites or the level of difficulty encountered at any of the three sites.

2. Enhancements a) A Design Guide will be prepared for use within the Mechanical / Civil discipline to help the user in reviewing and assessing an existing calculation for format and completeness to todays' standards. (This will be a Mechanical / Civil Design Guide since other programs have been established in the other disciplines and greater than ninety percent of calculations are the responsibility of the Mechanical / Civil discipline.) This Design Guide will be prepared by October 31, 1991.

b) Waterford 3 should establish procedures for computer software control to include - recording which calculations use which software. This could be included in a field in the plant record system data base. i l l DEASSM/ZERINGJ PAGE 35 of 41 SEPTEMBER 4, 1991

     .          .          -.                    -..   -      . . . - - - - - - -         . -   -        - .~
                                                                                                               }

+ . This recommendation will be accomplished by a revision to the existing Waterford 3 calculation procedure NOECP-312. With the continued use of many and various computer programs in the nuclear industry, it has become imperative to keep track of which , calculation used which computer program. Since errors in computer programs are- > routinely found (out rarely are serious) it is often necessary to review every calculation which used a specific revision of a computer program to assess the potential impact.. Adding this information to the record system data base, as documented and. input from the calculation ' coversheet, will facilitate the retrieval process. A revision to procedure-NOECP-312 is forecast for completion by December 31, 1991. c) Waterford 3 will develop a process to allow small/ interim revisions to calculations which must be rolled into the

                                               " mother" calculation within a specified time limit.

This will be' accomplished by a revicion to the-existing Waterford 3 calculation procedure, NOECP-312. Waterford J currently does not employ a method to perform smal) scope. changes to calculations which would later be " rolled-up" to-a new revision of the existing calculation at , some-future time. It is believed the process of " Temporary Calculation Revisions", or " Dash-Revisions" which must be rolled-up=into the mother calculation

                                              =within ninety daystor prior to.DCP close out, will facilitate the calculation-process during refueling outages. 1This would especially be true in the area of piping calculations. A revision to procedure NOECP-312 is forecast for completion by December 31, 1991.

3. Observations a) Waterford 3 should consider making use of an alpha-numeric revision. system to easily recognize which calculations-represent installed plant syntems versus design changes which have yet to be '

implemented. DEASSM/ZERINGJ PAGE 36 of 41 SEPTEMBER 4, 1991

b) Waterford 3 should consider formalizing the requirement to document a review of calculations completed by outside contractors, including review and approval signatures, c) Waterford 3 should consider including a

                                                                                                                                                                                    " List of Effective Pages" sheet to facilitate calculation revisions, d)    Waterford 3 should consider revising the calculation coversheet to include all information required by the plant records clerk to facilitate complete and accurate plant record data base entries.

4. Strengths a) Waterford 3 documents an engineering review or a design verification for each calculation consistent with written procedures.

This item is considered a strength since there are well established written procedures for calculation reviews and calculation design verification. Both the calculation procedure and the review procedure relate to provide guidelines to accomplish a formal technical review of calculations by experienced staff. b) Waterford 3 retains all calculations in the plant record system with the calculation logged into the plant record data base. This is seen as an obvious strength as compared to practices across the industry. Waterford 3 calculations are retained locally only during the time of preparation. Once a calculation is approved it is provided to plant records for permanent storage and retrieval. With the calculations logged in the plant record data base, they are not lost or misplaced and can be more easily retrieved. P) Software Control

1. Scope This Peer group reviewed the computer software control programs for each of the three sites. A comparison was performed in nineteen different areas (i.e., qualification, training, verification, level of software, etc.).

DEASSM/ZERINGJ PAGE 37 of 41 SEPTEMBER 4, 1991 ;

2. Enhancements Waterford's 3 proposed software control procedure NOECP-015 " Software Preparation.

Certification, Control, and Retirement" will enhance tne computer software :ontrol program that is presently being used. This procedure will provide the overall coordination of the Design Engineering Program requirements for software control. This procedure is exoected to on completed by December 31, 1991.

3. Observations a) NOECI-303 was to have been written to cover the process for retiring software after its useful life is over; but during sur Peer group meeting it was determined that safety related software may never be completely retired. It must be kept semi-active in order to track all error noticas that are issued against the software. All errors will have to be investigated to determine if any calculation that was made in a safety related system is affected.

Therefore the software should be considered being kept in a retrievable storage area no that this investigation using the software can take place. b) It is recommended to establish a proceduralized time period for periodic verification and validation of software. It is further recommended to include an 18-month time period for re-verification and validation of safety related software. c) It has been determined through experience that including the date and version of the progran on each page of output is helpful; it is recommended that this additional information be included on each page of the output. d) Consideration should be given to having Waterford 3 procedures include instructions for inserting job control language information into the input of each program. Some information that could be included are veraien, charge number, title anc other information about the computer analysis. DEASSM/ZERINGJ PAGE 38 of 41 SEPTD1BER 4, 1991

e) There is presently no training program for software control at Waterford 3. When computer software control procedures are completed and apptoved, consideration should be given to initiating a training program to teach the concepts and procedures to Design Engineering personnel.

4. Strengths a) Waterford 3 has developed a total software life cycle plan which addresses software controi from requirements specification to retirement of the software, b) Waterford 3 has addressed the problem of software used in the plant for process control.

Q. Procurement

1. Eq.qR2 The Procurement Engineering Assessment Team performed an assessment of certain areas of Waterford 3's Procurement Engineering program.

The assessment focused on commercial grade dedication, procurement specifications, and substitution evaluations. The procurement area has already been the subj";t of task force reviews and action team rsviews, This assessment looked at more of the details of the Procurement Engineering programs such as lower level procedures and engineering documents than previous reviews. In addition to this assessment, Waterford 3 Procurement Engineering personnel completed an extensive review of

                              -existing programs against the quidance contained L                               in EPRI documents, as committed to in the NUMARC L                               Comprehensive Procurement Initiatives.

l I

2. Enhancements a) Engineering procedures and instructions t

covering procurement evaluations utilize l preprinted forms and checklists which could l f limit the thought process and possibly result in responses with insufficient bases. These documents will be strengthened to ensure adequate documentation and justification for evaluation responses. Specifically the following changes will be mader DEASSM/ZERINGJ PAGE 39 of 41 SEPTEMBER 4, 1991

Allow a consistently formatted and justified, but customized, evaluation document to take the place of the proprinted forms and checklists. The format, certain instructions, and checklists will be in the instructions and standards governing the preparation of the evaluation. This will be in place by December 31, 1991. Require a technical review of evaluations when design affected decisions are being made. This will be in place by December 31, 1991. b) The NUMARC Comprehensive Procurement Initiatives review and assessment looked at 15 specific areas in the procurement process. The improvements identified for engineering were in the area of: Engineering involvement in Performance Based Supplier Audits (PBSA). Systematic technical evaluations for replacement items. Providing necessary engineering and technical resources to assure technical performance capability of procured items. Reorganization changes and the transfer of routine procurement functions will allow Procurement Engineering to take responsibility for technical evaluations of replacement itens., development of-procurement specifications, assisting in PBSAs and other procurement engineering functions. This will assure compliance with the NUMARC initiatives by July 1, 1992.

3. Obse,rvations a) Evaluate the need for an instruction which will provide guidance on how to process vendor documents. This will provide consistency in the level of engineering review and approval required as part of the procurement process.

j b) Evaluate the need for the establishment of one organization responsible for vendor manual updates and changes to avoid conflicting information and errors. l l DEASSM/ZERINGJ PAGE 40 of 41 SEPTEMBER 4, 1991

_ ~ , _ _ . . _ _ . ____. _ _._.. _ . . _ .

        ~'  *

4. Strencths a) :At Waterford.3, manufacturer data is taken'from parts at-receipt 1 inspection and documented on the receiving report when purchased through another supplier. This' allows consideration to be given-to other suppliers 1 including the manufr.cturer on future' orders, b) At Waterford 3, all technical information received-by anyone on site is submitted to the

                                            -records center for tracking through the_ Vendor
                                                                              ~

Equipment Technical Information Process (VETIP). This central receipt process prcmotes better .

                                            . control and utilization of the process.

c) At Waterford 3 a Procurement Engineering Desktop Guide is used by each procurement engineer. The guide contains procedures, instructions. standards,_quidelines, reports,_and-flowcharts needed_on a daily basis. It is organized with taba in a-counter-rack for easy use by the engineers. Most of-the sections are able to be updated on'the spot when new'information, such oas new negative; commitments, is. received.. i 3 I-l 1

              -DEASSM/ZERINCJ                      PAGE 41 of 41                                          SEPTEMBER 4, 1991

_ = - . - - . _ , . _ _ . . _ -~ ,, . - - ., -._ ,. , , - . . , - ,

DESIGN ENGINEERING PROGRAM ASSESSMENT OVERVIEW BACKGROUND

• ELECTRICAL SSFl
• ENTERGY OPERATIONS RESPONSE DESIGN ENGINEERING PROGRAM ASSESSMENT
• APPROACH
• PEER GROUPS FROM ANO/ GRAND GULF /

WATERFORD 3

        +   17 TEAMS

• OBJECTIVES OUTCOME l
• VERY SUCCESSFUL *
• NO MAJOR PROGRAM HOLES

!

• ENHANCEMENT AREAS IDENTIFIED

'

• SCHEDULE

                      ,  -,,  ,   -     ..-v-..--

l l DESIGN ENGINEERING ' PROGRAM ASSESSMENT

       . REVISE ELECTRICAL CALCULATION PER EDSFI NRC COMMITMENTS.                   ,

ECD MID 1993

       . INSTRUMENT SETPOINT CALCULATIONS DESIGN BASIS PROGRAM l

50 CALCULATIONS BY END OF 1991 l H 75 CALCULATIONS PER YEAR STARTING  ! 1992 l COMPLETE EF JRT BY END OF 1994

• SAFETY ANALYSIS DESIGN BASIS DOCUMENTATION THREE EVENTS CURRENTLY BEING

,- ANALYZED IN 1991

           - -SIX- EVENTS TO BE - ANALYZED PER YEAR AFTER EXPECT THAT MAJOR DESIGN BASIS ACCIDENT ANALYSES TO BE DOCUMENTED BY 1995 l

l

        . FIRE PROTECTION PROGRAM DESIGN BASIS l           DOCUMENT ECD END OF 1993 l

DESIGN ENGINEERING PROGRAM ASSESSMENT

• REORGANIZATION OF PROCUREMENT ENGINEERING ENGINEERING INVOLVEMENT IN PERFORMANCE BASED SUPPLIER AUDITS SYSTEMATIC TEC'HNICAL EVALUATION FOR REPLACEMENT ITEM PROVIDING NECESSARY ENGINEERING AND TECHNICAL RESOURCES TO ASSURE TECHNICAL PERFORMANCE CAPABILITY OF PROCURED ITEM COMPLIANCE WITH NUMARC INITIATIVE BY JULY 1992
• PROCEDURALIZE THE SCREENING AND TRACKING OF DESIGN CHANGES THAT INTRODUCE NEW MATERIALS INTO THE REACTOR CONTAINMENT BUILDING THAT COULD AFFECT GENERATION OF H2 GAS POST LOCA CONTAINMENT NET FREE VOLUME PASSIVE HEAT SINK ECD END OF'1991 FOR PROCEDURE AND TRAINING BY END OF MARCH 1992

DESIGN ENGINEERING PROGRAM ASSESSMENT

   . FIRE HAZARDS ANALYSIS (FHA) - UPDATED AND PROCEDURZLIE THE UPDATE OF THE FIRE HAZARD ANALYSES (FHA) CALCULATION UPDATE THE FHA BY END OF 1991 HAVE PROCEDURE IN PLACE TO SUPPORT FUTURE UPDATES DUE BY END OF 1992

• DEVELOP OVEt4ALL SOFTWARE PREPARATION.

CERTIFICATION, CONTROL AND RETIREMENT PROCEDURE BY END OF 1991

   . EQ FILE UPGRADE PROJECT IMPLEMENTATION OF

• LESSONS LEARNED" SINCE' LAST EO FILE UPDATE

         . ~.  ._  _    _        . . _ . _ - .

DESIGN ENGINEERING PROGRAM ASSESSMENT

  = DESIGN GUIDE PREPARATION

• EQUIPMENT NOZZLE LOAD REVIEWS

  = CABLE AND CONDUlT SUPPORT TYPICALS

• INSTRUMENT INSTALLATION DETAILS
• MOTOR- OPERATED VALVE MEDP

    -                        -  -     -      .    .=  .. .

DESIGN ENGINEERING PROGRAM ASSESSMENT e MECHANICAL / CIVIL- CALCULATION REVIEW DESIGN

         -GUIDE EACH CALCULATION TOUCHED IN DAY-TO-DAY BUSINESS REVIEW PERFORMED- BY ENGINEERING STAFF CONCLUSIONS ESTABLISHED WITH SUPERVISORY OVERSIGHT -

L - CALCULATION REVIEW CHECKLIST FOR EACH CALCULATION ( .

          -~ FORMAT, LEGIBLE, REPRODUCIBLE NUMERICAL SOLUTIONS EVALUATED
          -  ASSESSMENT IS MADE ON ASSUMPTIONS, METHODS, E'. C.

DESIGN ENGINEERING PROGRAM ASSESSMENT

• MECHANICAL / CIVIL CALCULATION DESIGN REVIEW (CONT'D)

CALCULATION REVIEW CHECKLIST SENT TO FILE ECD OCTOBER 31, 1991

• SIMPLIFIED PIPING ANALYSIS 1 DESIGN GUIDE PROVIDES INSTRUCTION WHERE " CHART" METHOD WAS USED-TYPICALLY COLD AND SMALL BORE PIPING GUIDELINES TO ASSESS BOUNDARY CONDITIONS GUIDELINES TO DETERMINE SUPPORT INTERACTIONS

      - ECD DECEMBER 31, 1991 i

DESIGN ENGINEERING PROGRAM ASSESSMENT 1

         . PIPING OPERABILITY ASSESSMENT DESIGN GUIDE L

l-i - SUPPLEMENTS THE PIPE STRESS AND PIPE SUPPORT DESIGN GUIDES GUIDANCE ON OPERABILITY VS. CODE- VS DESIGN GUIDANCE ON MATERIALS IN USE VS. GENERIC l. GUIDANCE ON USE OF SAFETY MARGINS j GUIDANCE ON USE OF NON-TYPICAL ANALYSIS l-TECHNIQUES l-

              -  ECD DECEMBER 31, 1991 l

DESIGN ENGINEERING , PROGRAM ASSESSMENT .

• NOZZLE EVALUATION DESIGN GUIDE P

DESCRIBES STEP-BY-STEP APPROACH FOR REVIEW IDENTIFIES CREATION OF A DATABASE FOR TRACKING

                       -             ECD DECEMBER 31, 1991 1

i l l

             - - _..                      ,  __.,__.-,__m - - . , , , . .-.._

F DESIGN ENGINEERhG

PROGRAM ASSESSMENT l-

• EQUlPMENT NOZZLE LOAD REVIEWS TABULATION OF ALL EQUIPMENT NOZZLES lDENTIFY LOADING ON ALL EQUIPMENT NOZZLES <

CONFIRM VENDOR ALLOWABLES ARE MET IDENTIFY WHERE GENERIC ALLOWABLES WERE USED lDENTIFY OUTLIERS ASSESS PIPING / SUPPORT CONFIGURATION REANALYSIS WHERE NECESSARY

             -     ECD DECEMBER 31, 1992 l -.

l

at 1 DESIGN ENGINEERING , PROGRAM ASSESSMENT  : l

• CABLE AND CONDUlT SUPPORT TYPICALS (B-288)

REVf':W SUPPORTING DOCUMENTATION ASSESS DOCUMENTATION COMPLETENES3 ECD DECEMBER 51, 1991

• INSTRUMENT INSTALLATION DETAILS (B-430) >

r REVIEW SUPPORTING DOCUMENTATION ASSESS DOCUMENTATION COMPLETENESS PREPARE SUPPORTING CALCULATIONS WHERE NECESSARY

                                               -              ECD DECEMBER 31, 1992

• MOTOR OPERATED VALVE MEDP

                                               - -MEDP, MAXIMUM -ESTIMATED DIFFERENTIAL PRESSURE
                                               -- VALVES TESTED DUR!NG -REFUEL -1 AND 2 ECD MARCH 1,1992
 ..~
     . .    -.- . _ . . - - . - - - . _ . - . . . _ , _ . - - - . _ _ _ - - _ . - - _ - - . . . . ~ . . - ~ . . - , _ . , - - . . - . . . _ - . . . . . - . _ . . . -.. -

I /. . l NO ICE OF VIOLATION l t

    -*  EXAMPLE 1a - DEGRADED GRID RELAY SETPOINT CALCULATIONS DID NOT ANALYZE UNDERVOLTAGE
       -CONDITION AT- 120V AC BUSSES

RESO_UTION METHOD e EXISTING CALCUL ATION WITH MAXIMUM THEORETICAL LOADING INDICATED POTENTIAL UNDERVOLTAGE CONDITIONS AT 120V BUSSES

• WATERFORD 3 PERSONNEL MEASURED VOLTAGE AND CURRENT LEVELS AT VARIOUS BUSSES FOR SEVERAL WEEKS
• PERFORMED VOLTAGE DROP STUDIES USING ACTUAL PLANT READINGS PLUS A 25%

ADDED CONSERVATISM

• CONSIDERED TWO WORST CASES FOR ANALYSIS 100% LOAD REJECTION AT DEGRADED VOLTAGE CONDITIONS LOCA WITH DEGRADED VOLTAGE l

l

I CO NCLL SIO N  :

• REPLACE EXISTING ELECTROMECHANICAL RELAYS WITH NEW SOLID STATE ITE RELAYS DRIFT LESS THAN 0.01 PERCENT ACCURACY WITHIN 0.01 PERCENT
• RAISE TRIP SETPOINT FROM 87.5% TO APPROXIMATELY 93% (RELATED TO GRID AT APPROXIMATELY 222 KV OR 96.5%)
• LOAD SHED HEATER DRAIN PUMPS (800 HP) NORMALLY TRIPPED ON LOW LEVEL AFTER TURBINE TRIP l
• OPTIMISE 480/120V TRANSFORMER TAP SETTINGS 1
• VOLTAGE PROFILE IS SATISFACTORY

EMERGENCY DIESEL GENERATOR (EDG) AIR START SYSTEM

• AIR RECEIVER SIZING
• EDG AIR COMPRESSOR START SETPOINT
• AIR RECEIVER LOW PRESSURE ALARM ,

f

,w        ,n.-, ,   -,--n- ~ + , , -  . - - - . , -  . - - _ . . ,,n. ,. - - . , , , - . , , ., - . . , , ~ - , ,e---

EMERGENCY DIESEL GENERATOR (EDG) . AIR START SYSTEM

         .                   EDG AIR COMPRESSORS & RECEIVERS TWO PER EDG CROSS CONNECTED NOMINAL PRESSURE 250 PSIG START 240 STOP 250 PSIG SIZED TO STORE ENOUGH AIR TO CRANK AND START THE ENGINE 5 TIMES DESIGNED TO START THE DIESEL IN A MAXIMUM OF 10 SECONDS DURING EMERGENCY STARTING OPERTION ENGINE CRANKING WILL CONTINUE                                                                       ,

UNTIL ENGINE STARTS OR AIR SUPPLY IS EXHAUSTED

         -*                     FSAR- DEFINES A GENERAL SIZING CRITERIA f
            . , - - . . - , - , - , ,       ..n..- -   s ,,                 w-      - , , - -, - - - - - - , . , - - , - , -  r

i EMERGENCY DIESEL GENERATOR (EDG)  : AIR START SYSTEM

• PRESERVICE TESTING - AIR RECEIVERS 5 STARTS AVAILABLE 245 -

255 PSIG 6 STARTS AVAILABLE AT 255 PSIG 4 STARTS WERE ALWAYS AVAILABLE AT 175 PSIG j

• COMPRESSOR SETPOINTS 240 + 10 - 5 PSIG SETPOINT 10 PSIG DEAD BAND 239 PSIG - 253 PSIG ACTUAL- RANGE
• AIR RECEIVER LOW. PRESSURE ALARM 175 PSIG NO INADVERTANT ALARMS ON NORMAL CYCLING ADEQUATE AIR CAPACITY

                  -TIME FOR OPERATOR ACTION i

2

    -a.                                ,_._....._,._....--_,_,-.-..v,.

Waterford 3 Fuse Task Force Presentation _ 1 Feb 1991 Fuse Task Force established. 7 Feb 1991 First task force rnesting; fuse group sampling concept originated. 19 Feb 1991 Conference call with NRC (T..McKemon). NRC informed that a fuse task force had been formed. NRC also informed that no completion date had been established due to complexity of the process. 28 Feb 1991 Second task force meeting; the use of SIMS and the first group of sample fuses (Containrnent Penetration) were discussed. 1 \ . _m __ ___ _ -_ _ _ . _ _ ____.___ _ _ _ ____..__ _ __-____. ._... __ . _ ___

l 9E 1 EEE BR 18 Mar 1991 Third task force meeting; discussed PAC fuse failures and the first fuse sampling group was l

established - Coritainment Penetrations. The sample consisted of 101 fuses from a total group size of 156 fuses.

5 Jun 1991 Fourth task force meeting; WA# 01076452 was used to field verify the first sample group. There were four discrepancies noted, but one of these was not a failure. Three NCI's were written to correct the remaining documentation concems. 25 June 1991 Conference call with NRC (S. Butler) to extend fuse procedure due date from 30 Jun 1991 to 15 Aug 1991. w ____m -

i EE BBB . BB 26 Jun 1991 Three remaining fuse discrepancies from sample

group number one were shown not to have coordination problems. Due to documentation i problems, we will perform 100% sample of this group.

12 Jul 1991 Fifth task force meeting; trending of fuse

failures and fuse acceptance criteria for the i fuse sample was discussed and reviewed.

l 30 Jul 1991 Sixth task force meeting; the fuse procedure l was discussed and the " actuation" fuse l philosophy was introduced. i

i  ; ilt n i o g t n c i t e m r o r f o p r r e p e k a m e s o r b r n t a f t h i o h n t i t a t e w t r s m s e e p n s i m e u u e p f q l e e b t s o n o d p r e h e m t t a n n e r l e i o i a t a r y- a t n S t , i n o c E fen dr S aio o r o U st c o f F t n nu c n N ef e i o v s t O en u c e I T r g a t pi A s c o r U de l d p I ud l u e C os't r o r r A wi o c o a e EB *

• BBB BB . O

BB BBB BB Specifically, ACTUATION FUSES are:

• Control fuses in 4160,480, and 120 VAC, or 125 VDC circuits

                      ~

for safety-related equipment, . e Technical Specification required containment penetration 1 fuses, I

• Fuses in control circuits at supply breakers for safety-related' busses.

d a

OO EEE 3W 2 Aug 1991 Fuse procedure was approved with effective . 3 implementation date of 1 Oct 1991. \' 8 Aug 1991 Seventh task force meeting; personnel training on fuse procedure to be coviip' ted by 1 Oct 199i. The remaining 55 fuses in sample group #1 are in typing for field verification. Fuse sample group #2 (Switchgear) is be~mg developed. l ! ij 25 Sep 1991 Eighth task force meeting; fuse precedure training complete for 52 of 74 ma~mterance !j personnel. Fuse sample group #2 is in typing. The remaining 55 fuses of group #1 are awaiting l verification. NRC IN 91-51 (inadequate Fuse Control Programs) is being reviewed by the l task force.

                                                                                                                                                          .I i

I n .

i [m] J

- EEE WATERFORD 3 FUSE POPULATION BR e Groupsamplad  !; e Fuse data reviewed by Engineering  !! O Fuse data incorporated into SIMS dainhme 4 Fuses replaced IAW fuse procedure UNT-005-025 .! I 4 Fuse procedure replacementform ensures correctfuse installed  ;: ! i ' ! e l .. .-. .-.....

                                                                                                                                                                                                                       -n-
                                                                                                                                                                                                       .:: .    :      me 1                                       .
                                                                                                                                                                            *IO... :.. . O-Fuses l
                                                    -:. ::: : .: ~:^: ::: ....:.O:               -
                                                                                                                                                      .- .::i:i:-:i.::
                                                                                                                                                              . . *             ' -! . .*;-:.:-i%
                                                                                                                                                                                                ~ -  

D& wJ:3 ..iAlli.OtheWnsdWii-i:.ii::iii:ii:i

? i:

35:

                                                                                         -- -~                                             ~:' *.                                           . - :

h YUE -:* . * .  :  : -:

                                                                                               -. :.-.:......:.. -.....-.         ... ..'..                     :':'.:..+:.-:..-    : : '---       :      :.-   -::::':' .':

Q3[ih[c w f a M .difi L

                                         /4
                                                                                       --:-:'..~.:-::':                                                       ..'.:.
                                                                                                                                                                                     ... .. ~   :::-        .

mg w ,

• y fr. <

                                       .. w. m e.4-. m.,,3,      i :;7 t . . , m%

c.. . .

                                                                               -c
                                     +                                       #+4 2                              ..    .                                       . .

• , ;r -

                                     %           u.'         .

w%wu.se..sp.,...e E. ... .:: . . . . .:-. ....-i:: .- + . . .e.m .m.qom%-

                                        . ~.c.h%mm.;j.                                   . : :- v. . .. :..~..::. .- ..--: -
                                                                                                                                            ~

• n* er - y q; * -

(if fl t y n ,tr c ..

• m*=*

                                        +

wgN ----* q_ _ _ , _ m w+ -: . y Ne-{;  ::.::. .- # =% nng _p_=== . r m l ,.,9 . .. . : i r

                                                                                                    ~
                                                                                                     .:                                                       e Fuse data revemed by Engineering                                        i
                                                         ' Ei :-

e Fuse data incorporated ~mto SIMS database { i. A s < ,!

                                                                                                                                                                                                                                    /

e 4}}