ML20115D979
| ML20115D979 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/12/1996 |
| From: | James Fisicaro ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-96-0116, W3F1-96-116, NUDOCS 9607160043 | |
| Download: ML20115D979 (15) | |
Text
f Enti gy Operiti:ns,Inc.
Killona. LA 70006 Tel 504 739 6242 ames J. Fisicato et*?n*
W3F1-96-0116 A4.05 PR July 12,1996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 i
License No. NPF-38 Additional Information on the Engineering Self-Assessment Gentlemen:
In Waterford 3 letter number W3F1-96-0075, which was submitted to the NRC staff on May 14,1996, Waterford 3 proposed to conduct an engineering self-assessment as an alternative to a full scope engineering inspection. The NRC Staff requested additional information on the engineering self-assessment during a recent telephone conversation. This information is provided in the attachment to this letter.
We appreciate the opportunity to participate in the self-assessment program. Should you have any questions or require additional information, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours, h
ames J. Fisicaro Director Nuclear Safety JJF/RTK/tjs Attachment C0030
/
/ &I,/ f 9607160043 960712 PDR ADOCK 05000382 P
i
]
Additional Information on the Engineering Self-Assessment W3F1-96-0116 Page 2 July 12,1996 i
i cc:
L.J. Callan (NRC Region IV) i j
C.P. Patel (NRC-NRR) l R.B. McGehee l
N.S. Reynolds NRC Resident inspectors Office l
}
l l
WATERFORD 3 l
Engineering and Technical Support Self-Assessment July 22 - August 2,1996 1
VERTICAL EVALUATION Performance Objective 1: Design and Configuration Control The engineering design of the Emergency Diesel Generator System is in accordance with the system capabilities as described in the FSAR and the Technical Specification bases. Configuration changes made to the system include proper design, review, control and documentation.
The following Emergency Diesel Generator System capabilities will be evaluated:
l Fuel oil usage rate and storage capacity to meet the seven day e
operation requirement.
(The team leader and team will select a second design capability (electrical} at the initial team meeting.)
Additional EDG capabilities will be evaluated at the discretion of the team leader.
Criteria 1.
Evaluated EDG capabilities meet design / licensing basis requirements.
2.
Configuration changes made to the original system include proper design, review, control, and documentation and have been appropriately described in the FSAR and the Technical Specification bases.
The following Configuration Changes willbe reviewed:
(A sample of EDG design changes and/or other configuration change mechanisms will be selected for review at the initial team meeting.)
The initial selection willidentify the starting point of the assessment.
Additionalitems willbe reviewed at the discretion of the team / team leader.
l
1 WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 PERFORMANCE OBJECTIVE 1 CONTINUED 3.
Configuration change packages have included required changes to 2
support elements including maintenance requirements and procedures, operating procedures, training documentation and training programs, periodic testing, procurement documentation, and specifications.
)
4.
Drawing updates to reflect configuration changes were in accordance with the plant's cdawing update process. The drawings accurately reflected the configuration change.
5.
An adequate 10 CFR 50.59 review or safety evaluation was performed for each configuration change in accordance with the plant's process.
i Configuration changes reviewed did not introduce any unresolved safety questions.
6.
The modified system is capable of functioning as specified by the current design documents and licensing requirements for the faci!ity, and that 10CFR50.63 Station Blackout, Reg Guide 1.97, and SPDS have not been compromised.
I
WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 Performance Objective 2: Surveillance and Testing Surveillance, post maintenance, and other testing are adequate to ensure applicable requirements are met and to demonstrate continued operability of the equipment.
Criteria 1.
Selected surveillance test procedures comprehensively address required system responses, meet FSAR requirements, and adequately ensure that the system will operate as designed under postulated accident conditions.
2.
Surveillance test procedure acceptance criteria meet the requirements of the FSAR and Technical Specifications (including bases).
3.
The in-Service Test program for pumps and valves meets applicable requirements. Procedures are technically adequate. Results are trended and do not indicate recurrent failures. (sample) 4.
MOV Testing meets program requirements. (sample) 5.
Engineering personnel contribute to test procedure development and/or revision and review test results.
6.
NPRDS (and CFAR) is effectively used to monitor the EDG System component failures. Failure tre.nds are investigated and resolved.
7.
Maintenance history for selected components of the EDG system does not indicate a history of recurring equipment problems. There are no existing adverse trends.
i 8.
Post maintenance testing for maintenance activities were correctly scoped and implemented.
WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 Performance Objective 3: Resolution of Technical Problems identification and resolution of technical problems associated with the Emergency Diesel Generator System is adequate and timely.
(Issues / problems will be identified by review of CR's, LER's, NPRDS, Self-Assessments, QA Audits, NOV's, NRC Inspection Reports, Plant Problem Lists, Commitment tracking, Operator Work-around Lists, Equipment deficiencies requiring safety evaluation or operability determinations
{W4.101's), or other events orissues that required engineering participation)
Criteria The following items will be reviewed:
Selected open and/or closed Condition Reports since January 1995 EDG SpecialReports Specific items will be selected at the initial team meeting.
The initial selection willidentify the starting point of the assessment. Additional items will be reviewed at the discretion of the team / team leader.
1.
For the problems / issues selected, engineering participation was adequate and in accordance with plant processes, procedures, and policies.
a.
Initial identification was timely; initial characterization was appropriate.
b.
Proper priority was assigned; resolution was achieved at the proper management level.
c.
Root cause analysis was performed when required and/or appropriate.
d.
Item was evaluated to determine if an adverse trend existed.
e.
Operability /reportability was evaluated.
WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 i
PERFORMANCE OBJECTIVE 3 CONTINUED f.
Implementation of corrective action was timely and effective as evidenced by the lack of recurrence. Progress of action plans, corrective actions and commitments is monitored and tracked.
Commitment due dates were routinely met, g.
Scope of corrective actions appropriately includes applicable related systems, equipment, procedures, and personnel actions.
j 2.
Backlog of items on the EDG System is acceptable.
i 4
1 i
4
)
I
WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 Performance Objective 4: System Configuration and Materiel Condition Station activities are effectively managed to verify that the Emergency Diesel Generator (EDG) System configuration conforms to design requirements and design documents. The materiel condition of the EDG System supports safe and reliable plant operation.
(Accessible portions (may be sample} of the system will be evaluated with l
respect to maten'el condition and housekeeping.)
Criteria 1.
Documentation is maintained to reflect actual plant configuration and current design requirements.
2.
The actual EDG System configuration agrees with current design drawingsidocumentation. (Selectedportions of the system) 3.
The EDG System is rra..itained in good working order; examples of this include:
- a. Fluid system leaks are minimized.
- b. Equipment is appropriately protected from adverse environmental conditions.
- c. Instruments, controls, and associated indicators are calibrated and operational as required.
- d. Good lubrication practices are evident.
- e. Fasteners and supports are properly installed.
f.
Equipment, structures, and systems are properly preserved and insulated.
4.
Plant housekeeping and cleanliness standards are published and followed.
I l
I WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 HORIZONTAL EVALUATION Performance Objective 5: Design and Configuration Control Engineering activities are performed in a manner that enhances the safety and reliability of the plant.
Criteria 1.
Configuration changes made to plant systems include proper design, review, control, and documentation and have been appropriately described in the FSAR and the Technical Specification bases.
The following Configuration Changes willbe reviewed.
DC 3268 Fire Protection DC 3429 CC-641,710,713 DC 3311 Corrosion Rate Monitor CCW/ACCW DC 3430 CC-636 The above items are considered the starting point of the assessment.
Additionalitems will be reviewed at the discretion of the team / team leader.
2.
Configuration change packages have included required changes to support elements including maintenance requirements and procedures, operating procedures, training documentation and training programs, periodic testing, procurement documentation, and specifications.
3.
Drawing updates to reflect configuration changes were in accordance with the plant's drawing update process. The drawings accurately reflected the configuration change.
4.
An adequate 10 CFR 50.59 review or safety evaluation was performed for each configuration change in accordance with the plant's process.
Configuration changes reviewed did not introduce any unresolved safety questions.
5.
The modified system is capable of functioning as specified by the current design documents and licensing requirements for the facility, and
WATERFORD 3
' ~
Engineering and Technical Support Self-Assessment July 22 - August 2,1996 requirements of 10CFR50.63 Station Blackout, Reg Guide 1.97, and SPDS have not been compromised.
l l
E
WATERFORD 3
)
Engineering and Technical Support Self-Assessment July 22 - August 2,1996 Performance Objective 6: Resolution of Technical Problems identification and resolution of technical problems is adequate and timely.
(Issues / problems will be identified by review of CR's, LER's, NPRDS, Self-Assessments, QA Audits, NOV's, NRC Inspection Reports, Plant Problem Lists, Commitment tracking, Operator Work-around Lists, Equipment deficiencies requiring safety evaluation or operability determinations l
{W4.101's), or other events orissues that required engineering participation)
Criteria The following items will be reviewed:
Condition Reports 96-0729, 96-0791, 96-0543, 96-1019, 96-0893, 96-0928 The above items are considered the starting point of the assessment.
Additionalitems willbe reviewed at the discretion of the team / team leader.
1.
For the problems / issues selected, engineering participation was adequate and in accordance with plant processes, procedures, and policies.
a.
Initial identification was timely; initial characterization was appropriate.
b.
Proper priority was assigned; resolution was achieved at the proper management level.
c.
Root cause analyses were performed when required and/or appropriate.
d.
Items were evaluated to determine if an adverse trend existed, e.
Operability /reportability was evaluated.
f.
Implementation of corrective action was timely and effective as evidenced by the lack of recurrence. Progress of action plans, corrective actions and commitments is monitored and tracked.
Commitment due dates were routinely met.
WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 i
g.
Scope of corrective actions appropriately includes applicable related systems, equipment, procedures, and personnel actions.
I 2.
Backlog of items is acceptable.
WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 Performance Objective 7: Maintenance and Operations Support The engineering organizations provide effective support to operations and maintenance to enhance the safety, performance and reliability of plant systems and equipment.
Criteria 1.
Engineering participation in corrective and preventive maintenance has been adequate.
(The team will review selected corrective and preventive maintenance activities on safety significant components performed since January 1995. In addition, maintenance personnel will be interviewed to determine adequacy of engineering support.)
2.
A process is in place that ensures the operability of equipment for systems such as ATWS, SBO, SPDS and RG 1.97 instrumentation that are not covered by the Technical Specifications but are installed in accordance with commitments and are important to the safe operation of the plant.
3.
Probabilistic risk assessment is used when removing significant safety significant components from service for planned maintenance.
4.
Operations has been supported with timely and thorough reviews of technical problems. (This willbe reviewedin Objective 6.)
WATERFORD 3 Engineering and Tchnical Support Self-Assessment July 22 - August 2,1996 Performance Objective 8: ISEG Effectiveness i
ISEG activities are conducted in accordance with regulatory requirements; issues significant to improved plant safety and reliability are reviewed; and, appropriate corrective actions are initiated.
Criteria 1.
ISEG (or equivalent) activities meet regulatory requirements.
2.
ISEG issues reports on its independent review activities and provides recommended corrective actions, when applicable.
3.
ISEG report action items / recommendations are resolved in a timely nianner and are tracked to completion.
I J
J 4
l
's i
o WATERFORD 3 Engineering and Technical Support Self-Assessment July 22 - August 2,1996 4
Performance Objective 9: System Engineering System Engineering provides quality and timely support to plant organizations to enhance safety, performance, reliability and efficiency.
Criteria 1.
The role / responsibility of the system engineers is documented, understood, and implemented.
2.
System engineers are appropriately involved (per plant processes, procedures and policies) in system activities including; planned maintenance, modifications, surveillance testing and condition reports.
3.
A process is in place to monitor and trend the performance of plant systems.
a.
important parameters are monitored and trended as part of a proactive effort to correct problems before they affect safety and reliability.
b.
Selected surveillance test results are trended to detect and correct j
problems before they affect plant operation.
c.
A system history file and chronologicallog are maintained by the system engineer.
d.
Equipment failures are trended and engineers assist in root cause determinations and corrective action.
,