ML20115J189
| ML20115J189 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/31/1992 |
| From: | Coulombe R, Decker A, Galen Smith POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20115J176 | List: |
| References | |
| PROC-920831, NUDOCS 9210280074 | |
| Download: ML20115J189 (121) | |
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-..-_.---~-.,e UNC1,0SURE 2 AUGUST 1992 STARTUP READINESS EVALUATION (SURE)
FOR THE JAhES A. FITZPATRICK NT1 CLEAR POWER PLAhT l
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i TABLE OF CONTENIT i
1.
INTRODUCTION II.
BACKGROUND III.
DISCUSSION IV.
EXECUTIVE SUMhiARY
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V.
CONCLUSIONS VI.
TABULATION OF CONCLUSIONS APPENDIX i:
ISSUE ANALYSIS SHEETS APPENDIX II:
SORE ACTION PLAN 4.-
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i STARTUP READINESS EVALUATION (SURE) REPORT L
Introduction As part of the integrated action plan to assure the successful return to senice of the James A. FitzPatrick Nuclear Power Plant (JAF), the New York Power Authority has performed a Startup Readiness Evaluation (SURE). He purpose of thh evaluath, is to reasonably ensure that those issues identified by the Nuclear Leadership Team (NLT) as critical to the startup of JAF han been resolved or that resolution is proceeding in a technically correct manner and in accordance vith the startup schedule. This nylew encompassed twenty two stadup issues identified by the NLT, in the ar ns of Engineering, Operations and Support. The basis of this selection was the ULT's nuniliarization with the issues identified in the DET l
evaluation and the RIP program, and a desin by the NLT to include a l
representative cross-section of issues considered important to the startup process.
'lhe details of the analyses of these issues are included as Appendix I to this repod.
IL Dachermail "le Startup Readiness Evaluation (SURE) is a New York Power Authority initiative, o% w ken with the purpose of determining whether the JAF plant is nady to a
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to service following the current outage. By conducting a comprehensive m% of the tr nty two startup issues identified by the NLT, a determination can N re; de as to *chether the technical approach to the nsolution of these issues is apm riate and in accordance with the startup schedule.
III.
Dt,cassion he Vice President-Nuclear Operations appointed a SURE team consisting of NYPA managers and staff, augmented by outside consultants, to conduct the startup evaluation for JAF. The scope of the evaluation was limited to the twenty two issues identified by the NLT as being critical for stadup. The SURE team developed a l
Startup Readiness Evaluation Action Plan which specified the team composition, the methodology to be used in the evaluation, and the format for the issue evaluations and recommendations. This document is included as Appendix II to this nport.
The SURE team, through a com'oh.ution of laterviews, document reviews and field verifications, completed its review of each of the issues and, based upon those l
reviews, made a determination if an issue was being addressed in a technically appropriate manner and if it could negatively affect the prescribed startup date of September 26,1992.Section V of this report presents the conclusions of this review, with items of major concern elaborated upon for prompt action.
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r APPENDIX II 9
START-UP READINESS EVALUATION 050RFJ ACTION PLAN August 24,1992 I
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START-UP RFADEESS EVALUATION (SURE) ACTION PLAN This action plan sets forth the steps that the New York Power Authority (NYPA) will take to nssess the James A. MtzPatrick Nuclear Power Plant's GAF's) readiness for stad-up. It establishes the purpose and scope of the review, the approach to the project, and the schedule for its completion. By preparing this plan, !be Start-Up Readiness Evaluation (SURE) team alms to conduct a comprehensive review of start-up issues while minimizing the interruption of activities at JAF.
PURPOSE The purpose of this review is to reasonably ensure that those issues identified by the Nuclear 12adership Team (NLT) as being critical to the start-up of JAF have been resolved or that resolution is proceeding h1 accordance with the start-up schedule.
SCOPE The scope of this assessment includes the twenty-two start-up issues identified by the NLT. The purpon of this review is to determine whether the issues are appropriately resolved, or, if not, whether JAF is taking appropriate steps to resolve the issue prior to startup. New issues, defined as issues not included on the list developed by the NLT, will not be identified or developed except to the extent that such issues emerge as a result of the investigation into the initial issues list.
APPROACH The NLT appointed a SURE team made up of NYPA managers and staff, as well as outside consultants, to conduct a start-up readiness evaluation for JAF. The NLT defined the issues determined to be essential to the safe start-up and operation of JAF. The SURE team reports through the Team leader to the Nuclear Leadership Team (NLT),
which has the responsibility for the Readiness for Restart Self-Assessment.
The followir g steps are required to complete the SURE process:
Step One: Orient the SURE Team o
Step Two: Rea ide Issues Step Three: Amiyze Issues S'ep Four: Document the Results Each of these steps requires the completion of_ specific e.sks on the part of the SURE teams.
Step One: Select and Orient the SURE Teams The twenty-two start-up issues identified by the NLT have been organized into three related groups, and team members have been organized into three groups to effectively address the issues, in addition, there will be a SURE Team leader, who provides oversight and guidance to each of the teams as they review activities and issues at JAF.
Groups will be organized into the following categories:
o Engineering group, responsible for the seven issues related to design engineering and technical support including modifications o
Operations group, responsible for nine issues concennng operations, maintenance and training o
Support program group, responsible for six issues dealing with licensing, prior assessment and audit findingr, and material conditions.
Potential exists for duplication of team efforts and these overlapping issues are discussed in Exhibit 1.
T:wn members will be oriented in the purpose and scope of the SURE project, as well as the approach outlined in this document.
Step Two: Review Issues Team members will review the issues selected by the NLT, in order to denlop familiarity with the issues and the analysis required to determine progress.
Preliminary work plans for each of the issues are provided in Appendix A of this document. These work plans provide guidance and direction regarding the criteria to be,
applied, and analytical steps to be taken, for each of these issues. As the analysis progresses, these work plans may be changed after such changes are reviewed by the team leader.
As part of the issue review process, the team will coordinate issues to prevent duplication or overlap in the analysis phase. As shown in Exhibit 1, some issaes - such as
" Technical Issues Resolution" and " Modifications" - are quite extensive and include portions of other, more specific issues (such as Diesel Generator Oprability). Initially, as well as on an ongoing basis throughout the review, the teams willidentify which items represent possible duplication and ensure that responsibility for analyzing that item is clearly defined.
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As part of the issue review process, preliminary objectives and a general approach for conducting the assessment will be prepared to minimize team preparation time. 'Ihis preliminary work will be reviewed and amended as necessary by the responsible groups as part of this step in the assessment.
Step Three: Analyze Issues Team members will prioritize issues, based upon the importance of the issus to start-up and the complexity of analyzing the issue. High priority issues will receive the greatest attention at the earliest point in the process. The prioritization process will recognize the need to provide senior management at JAF with daily briefings regarding the findings of the SURE review, and will emphasize the need to yield both short-term observations as well as long-term results.
For each issue, a specific team and team member has been assigned lead responsibility.
The lead responsibility includes refining the preliminary objectives of the issue assessment, and organizing team assignments to conduct the hivestigative and analytical portion of the review.
The lead assessor for each issue is responsible for briefing the team leader daily during the review, so that the plant manager can be apprised of progress and concerns during the investigative phase. The lead assessor is responsible for documenting the assessment as defined in Step Four.
The questions to be addressed for each issue in the SURE review process are:
Is the issue closed?
If not, will the current level of planned activity result in a resolution of that issue in time for the planned September 26,1992 start-up date for JAF7 If not, are there additional actions that can be taken that will resolve the issue in time for stan-up?
If not, what is a realistic schedule for the resolution of this issus?
e The teams may rely upon reviews of operations at JAF, interviews with JAF personnel, review of documents, and field verification to assess the issues, and will be able, as a result, to determine whether the steps taken by JAF to resolve issues - and the rate of progress being made on that issue - appear reasonable.
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Step Four: Document the Results At the conclusion of the SURE team effort, a Readiness Restart for Self Assessment report will be prepared that will document the results of the SURE team effort. The report will consist of:
An executive summary, highlighting the key findings and conclusions of the SURE team An issue-by-issue analysis of each of the, start-up issues identified by the NLT An example of the fcmiat for the issue-by-issue analysis is presented in Exhibit 2. As the exhibit illustrates, this analysis will consist of:
A statement of the issue and identification of the source A descriptian of the objective of the SURE team's analysis The approach taken by the SURE team to assess the issue The SURE team's conclusion regarding whether the issue will be resolved in time for start-up Justifications or-recommendations of the SURE teara regarding the issue.
Li addition to this documentation, the SURE teams will provide field notes of observations, interviews, and document reviews that will be contained in separate file folders unique to each issue. These file folde.N will be retained by the Director, Nuclear Operations in White Plains.
SCHEDULE SURE team members will conduct analysis of the issues on-site at JAF during the week of August 24 to 28,1992. Prepuation of the SURE report will begin during the week of August 31, with any identified follow-up work to be conducted during the early part of that week.
The final report will be developed and presented to the NLT by September 9,1992.
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EXHIBIT 1 SURE TEAM ORGANIZATION' AND ISSUE ASSIGNMENTS Team leader - Ken Chapple CROUP 1 - SURE ENGINEERING ISSUES Group leader: Glenroy Smith Group Members: Rich Chau, George Stranovsky, Ham Fish (E4 only) c:
VPA Corporation Member: Don Karner Issue A=1g= na=#c:
e E1: Modification cornpletion including training and-t-
procedurt changes u
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E2: HPCI model system progress 1
E3: Emergency service water issues (including issue S3-16, e
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-ESW SSFI followup actions) e
. E4:' ATIS relay issues (including issue S3-10,' AT13 related concerns)
E5: Diesel generator operability (including issue S3-18, EDG
- ground issues)-
' E6:' Appendix-R issues,: combustible control. and the
-e protection (including issues 1. S3-2, fire : protection-program issues - and - -S3-3, Appendix -R modifications / compensatory actions)
' Ibis should also be coordinated-with issues S-1, compensatory measmus including ALARA review, and S-2, Lie *=dag.
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- E7:: Outstanding temporary modifications 6-
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1 GROUP 2 - SURE OPERATIONAL ISSUES
- Group I.eader: Ray Coulombe Group Memben:
Bob Dolansky, Rich Iauman (09), Buddy Decker (O7 and O8
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l only)i Ham Fish (O2 only)
I VPA Corporation Member: Jim Hickel Issue Assignments:
01:
Operating experience review backlog and quality of past reviews (including issues S3-5, operating experience review) -
e O2-MEL reclassification (including issues S3-6, MEL reclassification operability assessment and S3-29, safety-related functional assessment)
This should also be coordinated with issue S3-12, GL 83-28 audit resolution.
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Work nquest backlog (specifically HPCURHR) 04:
Preventive maintenance backlog and scope -
e 05:
Stadup milestone schedule program and stadup list status / control (including issue S3-7, NYPA Readiness for Restad Review) e 06:
Control room deficiencies (including Issue 3-17, control room :
annunciaton) 07:
Operator training 08: Trabdng for other plant personnel e-09: Staffing (operations)'
This should be coordinated with issue 05, startup milestone schedule program and startup list.
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- GROUP 3 - SURE SUPPORT PROGRAM ISSUES Group Inder: Joe Iafferty Group Members: Bruce Shepard, Bob Ramstad, Joe Simplicio (S1 and S6 only),
llam Msh (S2 and SS), Art Smith (S4)
VPA Corporatica Member: John Palombi Issue Assignments:
e S1:
Compensatory measuns including ALARA nelews n
'Ihis snould-be coordinated with-Issue-S3-3, Appendix R-modifications and compensatory actions, and issue E6, control room deficiencies.
E S2:
Licensing - technical-specification utvisions and updates (including-S3-8, nsolution of RPV head NDE) e S3:
Technical issues nsolution; responsible for coordinating
~ investigation and nporting of the following issues:-
S3-1 Selected DEO's--
S3-2 Fuv Protection Program Issues S3-3 Appendix R Modifications -
S3-5 Operstlug Experience Review S3-6 MEL Reclassification S3-7 NYPA Readiness for Restart S3-8 ~
Resolution of RPV Head NDE S3-10 ATTS Related Concuns S3-12 GL 83-28 Audit Resolution -
-S3-16 ESW SSFI Follow-Up Actions
.S3 Control Room Annunciators :
S3-18 EDG Ground Issues S3-29 Safety-Related Functional Assessment 8
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GROUP 3 - SURE SUPPORT PROGRAM ISSUES (Continued)
Full responsibility for the following issues:
S3-4 Foxboro Cabinet Seismic Qualifications S3-9 IIPCI/RCIC Containment Isolai!on Valves S3-11 Safety Pump Room Ventilation S3-13 TotusTemperature RTD - Operability Impact -
S3-14 ESW/EDG Return Line - Operability Impact S3-15
_ LPCI MOV Invertor EQ Issue Resolution S3-19 Secondary Containment S3-20 ACCU's S3-21 Recirculation System Pipe Supports S3-22 ISI Pressure Test AQCRs S3-23 Dual Function CIV's S3-24 10CFR50, Appendix J Review S3-25 NRC Information Notice 92-35 S3-26 SBM Switch - Operability Impact S3-27 IIGA Relay - Operability Impact S3-28 Reactor Water Level Instnunentation S3-30 MOV's S4:
Q A effectiveness / audit finding status (hicluding' issue S3-12, GIJ3-28 audit resolution)
S5:
DEOs (including issue S3-1, selected DEOs)
S6i Material condition / housekeeping nadiness 9
IV.
Executive Summary Ilased upon the review conducted by the SURE team, it is the determination of the team that the twenty two issues identified, in general, are being addressed in a technically appropriate manner. A stadup date of September 26,1992 appears to be an overly optimistic target, due to the large volume of work remaining and the need for continued or increased vigilance to resolve a number of the items identified as startup issues. The major issues contributing to this detennination am presented in Section V. The following observations should be noted, however, in assessing the efforts of the plant staff to return to service:
- 1) The volume of work accomplished during this outage is far greater than originally planned, including a significant number of modifications not initially in the outage work plan.
2 A positive, self-critical attitude is evident among the plant staff, which manifests itself in a dissatisfaction with the " status quo" and a desire for excellence. Such an attitude partly explains the large backlog in work requests and engineering, as many more discrepancies are being identified.
- 3) In general, the rpproaches being taken to resolve the issues reviewed by the SURE team are appropriate. In some cases, adjustments in emphasis should be made, and these are addressed in the Issue Analyses of Appendix I.
Implementing the recommendations presented in Section V will do much to resolve the concerns expressed in this report. Mitigation of these items will allow the staff to complete a plan and a comprehensive schedule that will ensure that the issues are properly addressed and should result in the ability to determine an outage completion date which can be met with confidence.
V.
Conclusions Of the 22 issues identified by the NLT as critical to JAF startup, 20 have appropriate management controls, procedures and/or programs in place to ensure that they will be properly resolved and appear to have n reasonable chance for resolution before the planned startup date of September 26,1992. However, many of these issues requim continued or additional management initiative and vigilance to achieve resolution in a timely manner. 'Ibose issues and reconunendations are discussed in Appendix 1. A quick-reference Summary table of all issues followsSection V of this report.
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%e SUIU team identified two issues that need additional management attention and have a high potential for (ausmg an adverse effect on the startup date. These issues are:
1)
Modification Completion 2)
Startup List Control Because of the significance of these issues, a brief discussion of each issue is provided in this section of the rrport. Grrater detall and elaboration art presented in Appendix 1. Selected members of the current SURE team will reevaluate these two issues at an appropriate thne agreed upon between the JAF Resident Manager and the Vice President-Nuclear Operations. The SURE team also recommends that all issues identified in the Sunmtary Table with a SURE status of 3 also be reevaluated.
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Issue E 1 (Modification Comnletion) represents the most critical issue in terms of the potential for delaying the startup date from the current outage.
%ere is no doubt that an aggressive program for the completion of -
modifications is in place and is bcIng adhered to by plant and engineering personnel. IIowever, as detailed in the Issue Analysis for Issue E-I, the SURE team was unable to obtain an Sfficial" list of those modifications actually required for startup. Site and engineering staff is working to aevalop a better understand 1ra of the requirements in terms of modifications which must be donc prior to startup.
In the case of the Emergent Modification List, 7 of the 73 modifications listed are' anticipated to be completed after the published s'.artup date. In many cases the completion depends upon actions outside the control of the Authority (e.g., lead time on parts). Other related issues, such as the preparation of control documents which reflect the modified plant configuration are similarly affected by modification completion dates, and thus have the potential to further delay the startup date.
RECOMMENDATIONS 1)
Plant and Engineering Management must review all incomplete modifications and make a final determination as to those which are deemed essential for startup.
2)
Resourtes should be applied in engineering, expediting of parts, installation and training for those modifications identified in the final startup list in order to accelerate the modification completion date as much as reasonably achievable.
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A single individual should be assigned responsibility for the disposition and tracking of all modif: cations required for startup of the plant.
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All work activities, including post-work testing, training and document closcout needed for modification completloa should be included in the startup schedule.
2.
Issue O-5 (Star 1un List Control) deals with ensuring that all of the items necessary for startup are identified and understood by the appropriate staff, so that sufficient attention is devoted to the timely completion of those items, the SURE team has deterinined that there are a number of lists in existence, each identifying various startup actions and issr s, but none containing all of the items necessary for startup. Examples of this include the ACTS list and the Outage Work List. Neither is all-Inclusive, and each has items that are not essential for startup. In addition, some modifications, PMs, and STs are not on either list.
IECOMMENDATIvNS 1)
An official startup list must be created or defined, such that all activities requhtd to be completed prior to startup art clearly identified.
In conjunction with this, a single Individual in the organization should be tasked with maintalning the startup list and tracking the progress of the activities on the list.
2)
Strong efforts must be made to reduce the scope of work to be donc prior to startup. There are more items on both the ACTS startup list and Outage Work List than are essential for startup.
PSO-64 establishes guidelines to determine which items are designated as startup items. These guidelines should be clarified and then used to develop a Italistic official startup list.
3)
JAF should ensure that the Startup Plan is well-communicated throughout all levels of the organization.
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StTRE IB*:UE
SUMMARY
TABLE Number Issue
- SURE Comments Renssess Status E-1 Modification Completion 4
This issue has the potential to impact start-up Yes activities. Four specific recommendations are included in the summary report.
E-2 IIPCI Model System 3
Increased attention is recommended in relation to Yes the completion of IIFCI Model System work.
E-3 Emergency Service Water Issues 2
None No E-4 ATTS Relay Issues 3
GE SILs and TII;; not reviewed for service life Yes data.
I E-5 Diesel Generator Operability 1
None No E-6 Appendix R Issues 4
Six fire protection mods are expected to be Yes completed after the published start-up date.
Increased attention to their complction is warranted.
E-7 Temporary Modifications 3
Recommendations addmss a more aggress *ve Yes program to reduce the amount of Temporary Modifications.
O-1 Operating Experience Review Bacidog 2
Appropriate attention is being given to this issue.
No
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0-2 MEL Reclassification 3
'Ihis issue has the potential to identify new Yes operability issues. An Incmased level of attention should be devoted to this effort. See recommendations in Append!x !.
SURE ISBUE
SUMMARY
TABLE Number Issue
'SURE Comments Reassess Status O-3 Work Request Backlog (IIPCI/RIIR) 2 Due to the large nt;mber of items in the Work No Request backlog, continued attention to this issue Is warranted.
0-4 Preventive hiaintenance Backlog and 3
Additional attention should be given to the backlog Yes 1
Scope of hiaintenance Phis.
O-5 Start-up List Control 4
This issue h of significance to the successful Yes completion of the outage. See Appendix I for recommendations.
g 0-6 Control Room Deficiencies 3
Prioritization of control room deficiencies is Yes necessary.
O-7 Operator Training 2
None No 0-8 Training for Other Plant Personnel 2
None No 0-9 Staffing (Operations) 3 Four recommendations noted in the Issue Analysis Yes Sheet.
S-1 Compensatory hicasures (including 2
Continued attention to this item is warranted.
No ALARA review)
S-2 Licensing - Tech. Specs.
2 None No S-3 Technical Issues Resolution 1/2/3/4 The remaining technical Issues are in varying stages Yes of resolution. Refer to the Issue Analysis Shacts of Appendix I for details.
S-4 QA Effectiveness / Audit Finding Status 2
Recommendations noted in Issue Analysis Sheet.
No S-5 DEOs 3
Process for resolving DEOs is in place and Yes effective. Additional attention is rcquired for DEOs noted in Issue Analysis Sheet.
SURE ISSUE
SUMMARY
TABLE I Number Issue
- SURE Comments Reassess Status S-6 Material Conditicn and IIousekeeping 3
Increased attention to housekeeping and material Yes Readiness condition is warranted.
SGl_E Status Codes I - Issue Is resolved. No further action arquired.
2 - Issue is open, but appropriate actions are being taken in a timely manner.
Minor recommendations may apply.
3 - Issue is open, and some additional actions are required to successfully resolve this issue.
4 - Issue Is open, and significant actions are required to successfully resolve this issue.
APPENDIX I ISSUE ANALYSIS SHEETS 4
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t ESUES E-1 THRU E-7 4
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ISSUE ANALYSIS ISSUE NUMBER: El ISSUE STATEMENT:
Modification Completion, Including Training and Procedure Changes. We need to verify that modifications which have been committed for startup are completed. In addition, we should verify that procedures which require changes as a result of those mods are in fact changed, and PORC's if required. We should also determine that training has taken place l
when mods and procedurts dictate that training. We should also review a sample of post-work testing.
OIUECTIVES OF THE ANALYSIS:
To ensure that modifications which have been committed for completion pr/cr to startup (startup modifications) have been identified, and that startup modifications are completed, tested satisfactorily, and revisions to procedures and/or training necessitated by the modifications are complete.
APPROACII:
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Obtain lists of planned and emergent modifications for this outage and responsible engineers for each, o
Interview Planning Manager, Site Engineering Manager, and selected responsible engineers, o
Determine if definitive criteria exist for inclusion of modifications to be completed prior to startup.
o Determine if the outage schedule effecti ety-controls the status of these-modifications, including scheduling, work start, causes for delay / rescheduling, work completion, post-work testing, and necessary procedure revisions or retraining.
o Review selected modification packages (coordinate with Issues E-5 and E-6).
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. CONCLUSION:
The issue has been nsolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or befon September 26,1992.
Additional actions should be taken to ensun that the issue is appropriately resolved on or before September 26,1992.
X Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICN
,N/ RECOMMENDATION (S)
In order to obtain an understandink of the status of outage modifications, both pre-piawled (original 1992 refueling outage mods) and emergent modifications wen examined. He number, scope and status of outage modifications was initially determined by reviewing four lists of modifications:
Site Engineering Electrical and Mechanical / Civil 1992 Refueling Outage Modification Status o.
Project Engineering 1992 Refuel Outage Modification Status 1992 Construction Services Modification Package Status e
1992 Refuel Outage Emergent Modification Engineering and Planning Status e
In addition to these modification status lists, ACIT w* ftdtied for modification package '
nferences. Only the ACTS lirt sd dg 1992 Refuel Outage Emergent Modification Engineering and PlanM Status wen currently updated.
The total number of modifications being worked was not nadily available. However, a searth of the MV30 Plant Modification database identlfled 242 refueling outage modifications fcr 1992.
No single list of modifications defining the outage work secpc could be found. The lack of this list was confinned through interviews. Without a single list of outage modifications required for startup, tracking and status of the outage related modifications is very difficult and thne consuming. AdditionaUy, the lack of a single list contributes to uncertainty concerning criteria for requiring modification completion prior to stanup and to the actual list of startup mquired modifications. For example, five modifications were found listed on AC1S which were not incorporated into any of the modification lists. Three of these modifications are complete and awaiting post-work testing. Modification M1-88-070 has portions which will not be complete prior to startup and may not truly be required prior to sartup. In addition, Modification M1-92-039 has not been assigned to a responsible engineer. Without criteria for inclusion of a modification list, effective control of start-up required modifications is lacking.
Interviews with the responsible engineers for modifications on the Site Engineering Electrical and Mechanical / Civil 1992 Refuel Outage Modification Status list, and the Project Engineering 1992 Refue: Outage Modification Status list, mvealed that installation for most of the modifications listed wen complete and awaiting post-work testing. Much of the post-work testing is tied to surveillance testing required pre-stadup. Howem, no hard logic scheduling or resource analysis of required surveillance testing has been performed, placing in question the adequacy of the ten day schedule allowance for surveillance testing. As operations will be a critical resoune during the surveillance testing evolution, the existence of a large " unknown" body of post work testing in addition to the normal survelliance tests may have a substantialimpact on schedule during the surveillance testing period. This situation is further aggravated by the completion of most emergent modifications late in the outage such that post-work testing for these modifications will also be required when operations resounes are already strained.
'Ibe status of emergent modifications ms assessed through interviews with responsible engineers and modifications package reviews. The status was detennined to be as follows:
Total Number Of Emergent Modincations Scheduled 73 Modifications Installation Complete & Post-Work Testing Successful 08 Modifications Installation Complete & Awaiting Post-Work Testing 18 Modifications i
Installation Anticipated To Be Complete Before 9/26/92 40 Modifications In;tallation Anticipated To Be Complete After 9/26/92 07 Modifications l
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4 The seven modifications anticipated to be complete after 9/26/92 an as follows:.
e F1-92-078; MSIV and ADS Electric Isolation M1-92-244; Remote Reactor Level Gauge e
M1-92-257; Availability of MCC In Fim Zone e
F1-92-272; Emergency Lighting e
F1-92-269; Emergency Lighting e
M1-92-273; Air Conditioning Chiller Unit Enclosure e
e - M1-92-214; CS Valve Isolation I.agic,14MOV-11A/B For some of these modifications, the modification package'has yet to be completed. For -
othen lastallation and/or long lead time parts are a nstraint.
De status of 13 working modifications packages was nylewcd to assess the validity of the 1992 Refuel Outage Emergent Modification F23:r+:fng and Planning Status and to see if the mod control process was followed. While the s:stus was found Ls be valid, thne modifications were found for which the Design Verification, Design Input Checklist'was missing a final signatun. He eng'af.sg package for these modifications were prepared by contractors. Once this was identifled to the responsible'penonnel, the dime.ncies were rapidly corrected.
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ISSUE ANALYSIS ISSUE NUMBER: E2 ISSUE STATEMENT:
Progress on the Illgh Pressure Coolant Injection (ILPCI) Model System. An IIPCI model system document has been created which identifies the problems, solutions and efforts that have to be completed to improve the IIPCI system.' Some of those should be done prior to s:artup. We should look particularly at those mods which improve the availability of IIPCI, and that those mods do, in fact, improve the overall system.
OBJECITVES OF TIIE ANALYSIS:
To identify IIPCI knprovement plans from the IIPCI model system document, assess the reasonableness of the criteria used for selecting improvement actions to be completed prior to startup, and assess completion status.
APPROACII:
o Review the IIPCI model system implementation plan and the HPCI model system document.
o Determine what actions were selected for completion prior to startup.
o Interview the IIPCI Coordinator and Site Engineering Manager to assess the reasonableness of the criteria used for startup requirement designation of activities and to ascertain the status of the startup actions.
o Verify status of selected work requests and modn1 cations selected.
o Coordinate this review with SURE team members responsible for Issue No. 0-3.
CONCLUSION:
The issue has been resolved.
I Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
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Additional actions should be taken to ensure ' that the issue is-l appropriately resolved on or before September 26,1992.
1 Resolution of this iscue before September 26,1992 is unlikely, i
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, JUSTIFICATION /RECOhfMENDATION(S):
The 11PCI Model System Plan and the IIPCI Model System Implementing Plan wem reviewed to determine the items identified for resolution prior to startup. The IIPCI Afodel System Plan documents the process used to deterinine work activities required on the IIPCI system both before and after startup. The process was one ofjudgement by knowledgeable personnel listing known work issues impacting system reliability. As the number ofissues identified was significant, this 'fust order' review is considered adequate for identifying requimd work. Future excmination of the IIPCI system could be refined by using available industry and INPO data oc equipment failures and system problems. The concerns with IIPCI reliability would appear to dictate a higher priority for resolution of all potential enhancements of the IIPCI System The Imi ementing Plan identifies huprovements and modifications required to be complete d
prior tu startup. For the improvements identified in the Implementing Plan Section 3 (requhed prior to startup), significant work has been completed or is in progress on all but one of the items. Item 3.5, consists of two tasks, placing local instrumentation on a gage board and moving the turbine governor (EGM) and control (RGSC) panel 23TU-2 off the IIPCI skid. Relocating the EGM and RGSC panel shall be evaluated and performed in cordunction with replacement of those components which were identified in Item 5.1.7.
Fifteen of the 17 modifications identified in the Implementing Plan Section 5 as requhrd prior to startup an working toward completion before startup.
Hve of the 17 modifications are complete. Eight modifications are in progress with reasonable probability of completion before startup. Two modifications currently with engineering, (M1-87-026 Replace Limit Switches and M1-92-242 Install Vent and Drain) are expected to be released for installation to support the startup schedule. Two modifications (F1-82-060 Install Moor Drains and D1-92-226 Update EGM and RGSC) have been deferred until after startup, i
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ISSUE ANALYSIS ISSUE NUMBER: E3 ISSUE STATEMENT:
Emergency Service Water Issues. As a nsult of the ESW SSFI and the NRC 9ET inspection, approximately 200 issues have been identified as associated with ESW. Of those,75 are stad-up issues. Suppoding documentation for this issue includes the NRC DET, NRC SSFI of ESW No. 92-81 and any responses, stanup actions (such as flow linkage control, flow testing, heat exchange thennal testing, and inspections), FAP mstad ilst, ant issue S3-16.
OBJECTIVES OF THE ANALYSIS:
To ensure that action plans have been identified for restart items and am completed or progressing satisfactorily, or contingency arrangements for pending restad items can meet the September 26,1992 restad date.
APPROACII:
o Interview msponsible engineers and ESW Engineering Coordinator to ascedain status of action plans and reasonability of startup designation criteria in mlation to NRC findings.
o Verify two items shown as complete on pre-startup action status, o
Detennine what contingency plans are pnpand to compensate for startup issues which are currently unnso'ved and have a high degne of uncedainty.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate msolution of this issue on or befom September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
l
I i
2-JUSTIFICATION / RECOMMENDATION (S):
In discussions with the Responsible Engineers and ESW Engineering Coordinator a total of 210 ESW issues were identified for close out. Currently 72 of these items are being tracked for resolution prior to start-up. Ilowever, only 70 of these items wen identified in ACTS with a " required for startup" designation.
From the interview with the Responsible Engineer and ESW Engineering Coordinator it was fudher determined that 30 of the 72 start-up items are currently closed. Work on the remaining 42 start-up items is progressing towards a 9/26 close out date.
The status of seven procedures (ST-8Q, ST-19C, H, G, ST-8E, ST-8N, and A OP-43) to be revised and require PORC review was examined as pan of the SURE analysis. All are being worked on and are in various stages of completion. Revision to mdor procedum ST-8Q is complete and is scheduled for PORC the week of August 31,1992.
ESW system operability is dependent on successful completion of ST-8Q and thermal testing of the crescent coolers. 'Ihese tests and other related ESW surveillance testing is currently scheduled for the week of September 14,1992.
- 1
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i ISSUE ANALYSIS ISSUE NUMBER: E4-ISSUE STATEMENT:
'ATTS Relay Issues ' ' Ibis is ue deals with the commitme ts made at the ATIS Enfortement s
n Conference, among which are response time testing and service life evaluations.
OBJECTIVES OF THE ANALYSIS:
To ensure that commitments made at the ATIS Enfortement Conferene are identified,:
tracked, _and' for selected commitments, completed prior to startu;. when such a commitment was made to the NRC.
- APPROACH:-
o Reviewed the NRC Enforcement Conference letter dated April 17, 1992 to identify commitments made at the ATIS Enforcement Conference in response to Inspection Report 91-22.
o Reviewed the ATIS Project Monthly Report dated July 14,1992 to match action items with the NRC letter of April 17 and to ensure that all issues.
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had been identified.
o Nmined Issue 10 of the M4or Technical Tasks Requiring Resolution Prior to Startup as a source document for issues and to ensure that all i
issues had been identifled.
o Interviewed the ATIS Project Manager to identify documentation of the status of commitment items.-
o Interviewed the Preventive Maintenance Engineering Manager to clarify the details of the performance of the service life study of Category _ I components located in mild enviromaents.
' o-Interviewed contractors responsible for the OER program to detennine the connection, if any, between the review of past OERs and the PME service life study.
o Reviewed the ATTS monthly report items to match the ACTS list record
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3 2-CONCLUSION:
De issue has been resolved.
Actions taken to date and planned for the future will maud in the appropdate nsolution of this issue on or before September 26,1992.
X Additional actions should be 'taken to ensure that the -Issue is appropriately neolved on or before September 26,1992.
Resolution of this issue befon September 26,1992 is unlikely.
JUS'ITFICATION/ RECOMMENDATION (S):
3
%e NRC enfortement conference letter of Apdl 17,1992 states:
"In addhlon to the cornetire actkas outlined in its summary, NYPA committed to four items in response to concerns raised by the NRC staff during the conference."
r-Two of the four items indicate that completion is required prior to startup.
De Summary of Cornetire Actions contained in NYPA's,,.1 ^=ti-to the NRC-contained 14 ltems. Seven of those items were indicated for completion pdor to startup.
Or.e of those sereis items overlaps one of the two startup concern identitled by the NRC la its ' Apdf 17 letter. - Derefon, them is a list of eight items which am identitled below,.
whic' require nsolution pdor to startup and are being reviewed as part of une SURE team ernmination of this issue.
(Eight other items wen identified in the Smnmary of Cornetive Actions of the NRC letter as being in progress, continuous, or to be perfonned within 12 to 18 months. Because they were not identified as being required for startup, these items s ist not reviewed in detall
- as part of SURE Issue E-4.)
1.
A sempitag rulew of closed ; -.4., events nport analyses wlB be *d prior to unit restart and the resnits wlB be assemed to detennine if a sense {
i M rulew Is wannated. (Prem the Apdl 17 NRC letter, thint paragraph.) Revisit previously dispositioned operating %h (Fnna the NYPA Samanary.)
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3 He requirement for a sampling review prior to startup has been met, and was rtported as complete in the August 24 status report for issue 10 of the hiajor Tecimical Tasks Requiring Resolution Prior to Startup.
Slightly over ten percent of the total number of closed items were sampled. The OER group scanned approximately 6200 items in the data base going back to 1984 and identined 653 items as significant according to review criteria. During the initial sample of 97 items, two potential operahllity concerns and 15 programmatic failurts indicated that a more comprthensive review was warran;ed. During the extended sample, 73 of 556 Items ludicated program or operability failures. Contractor personnel responsible & the OER program stated that 100 percent of the closed items identified as signincant had been included in the two reviews. nts fact, coupled with an analysis of the nature of the failures, led to a detennination by contractor and site management that further review of the rtmaining items was unnecessary. (See SURE 1ssue O-1, Operating Experience Review Backlog, for a further dhcussion of this issue.)
2.
Revised and knproved problem identlGcation and resolution pmgrams wiB be in place prior to restart. (From the AprU 17 NRC netter, third paragraph.)
Establish a formal process for managing and resolving importanUnrgent issues.
(From the NYPA Summary.)
Two new administrative procedures
" Deviation and Event Reponing," AP-03.02, and " Deviation and Event Analysis," AP-03.03 - have been writien and apprvved by PORC. These procedures provide a formal and thorough process to address the issue. Ilowever, because significant training is required priot to implementation, the plant manager has withheld approval until after plant startup is complete and the training program has been huplemented. Accordingly, the plant manager has decided to rely upon WACP 10.1.30, " Integrated Causal and Corrective Action Program,"
approved July 1,1992, to fulfill this commitment prior to startup.
3.
Replace the Amerace GP Series Relays in ATIS. (From the NYPA Sm===ry.)
Replacement of the rtlays was completed via Work Request No. 109256.
4.
Update Technten! Specifications to meet the l'mning basis. (From the NYPA Summary.)
Authority letter JPN-92-030 transmitted trie application for a license amendment to the NRC on June 22,1992. The NRC requested additional engineer' y explanations
4
. August 26, 1992. Approval by the NRC is expected during the first week of September.
5.
Develop and huplement respense time tests to meet revised technical specifications. (Frum the NYPA Summary.)
Ten surveillance tests are required. Eight have been written and approved by PORC and four of these have been performed. Two tests (ISP 108 and 109) are being written, hey are expected to be approved by PORC by September 16, 1992.
Perfmutance of these two tests, along with four of the tests previously approved by PORC, is expNted to be completed :>rlor to September 26,1992.
6.
Evaluate the md for additional response time tests and implemen*. as necessary.
(Fran the NYPA Smimiary.)
A binder in the book case cf the Technical Services department systems engineer supervisor for instrummtation provides full documentation of the DChi 11 review of the vendor study of ins'ruments which require response time testing.
7 Establish replacement intervals for Amerace GP-series relay. (From the NYPA Summary.)
This m is closed by memorandmn JPhi 92-051, dated August 26, 1992. The inforr ation was delivered to the I&C Department on Septeraber 4,1992 by a SURE team member.
8.
Evaluate specific QA category I equipment in mild environments for available service life data. (Fran the NYPA Summary.)
Preventive Afaintenance Evaluation PhfFA120 was performed and transmitted by mem idur iPhi 02-046 dated July 1,1992. His evaluation, however, did not incluwe a renew of applicable GE SILs and TII2, which may contain service life information.
Twenty-t ight components wm identified as not currently in the Ph! program.
Nineteen had expired service life and ne<d replacement. Two have been replaced, eleven art waiting for parts, and six art waiting to be worked.
Based on its review of this issue, the SURE Team recommends that a complete review of vendor SIIe and TII2 should be performed before this item is considered to be closed.
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ISSUE ANALYSIS ISSUE NUMIIER: E5 ISSUE STATFAIENT:
Diesel Generater Operability: We are limiting our review of this issue to the post-work testing on Mod No. M1-92-210.
OItJECTIVES OF TIIE ANALYSIS:
To verify the adequacy and completion of post work testing performed for Modification No.
M1-92 210.
APPROACII:
o Review Modification No. M192-210 for familiarity and to identify post work testing requirements.
Interview Site Engineering Manager and systan engineers to ascertain the o
significance of this modification and their acuptance of the post work testing.
o Review the post work test to ensure that testing adequately verified operability of the 'EDG (four units).
Walkdown selected portions of the modification and testing packages to o
verify their completion (including procedures and training).
Coordinate this rtview with personnel assigned to Issues Nos. E1 & w.18 o
to ensure compatibility of conclusions.
CONCLUSION:
X The issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before Septeraber 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or befon September 26,1992.
Resolution of this issue tjefore September 26,1992 is unlikely.
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2-J USTillCATION/It ECOMht LWD AT10N(S):
h!odincation hil.92-120 involves the isolation of the 125VDC power supply to the generator control system. 'nie 125 VDC sysicm supplies power to the emergency diesel generator control system, through a 200 ohm dropping resistor, to provide a 48 VDC supply.
Grounds on the 125 VDC system have caused nuctuations in the 48 VDC supply causing variations in the signal to the hydraulle actuator and oscillation in the emerrancy diesel generator output. The modification placed an isolated power supply in the 125 VDC system to provide the 48 VDC to the emeq:enev diesel generator. The power supply isolates the 48 VDC emergency diesel generator peu er from any disturbances on the 125 VDC bus. The post work testing for this modincation, controlled by STP-93M, innleted grounds on the 125 VDC sys1em while the diesel generator operated under load. The testing verifled that no disturbance uas subsequently generated in the emergency diesel generator output. This test procedure was found to be adequate to verify the operation of the modified 48 VDC power supply. A walkdown of the installation verified that the modification Installation was complete.
Additionally, review of the Summary Of hiodification Post-Work Test Requirements for Modificetion h11-92 210 connrmed that testing had been completed.
Finally, a review of the Modincation Operability Readiness Checidist revealed that no procedure changes or training were required for operability of this modification.
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ISSUE ANALYSIS ISSUE NUMBER: 55 ISSUE STATEMENT:
l Appendix R Issues, Combustible Control and Mrs Protection: Dere are a total of 33
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modifications required to be approved prior to startup. His review is limited to nylew of and accounting for the 33 Identified modifications.
OBJECTIVES OF TIIE ANALYSIS:
To ensure that those modifications required ? re et y Wa t ^ s closed by September 26, 1992, and that appropriate exemptions have c*.m gw/ 4, APPROACII:
o Coordinate / combine activities for namination of this issuo for those of Issue No. S3 3 (Appendix R Modifications) and issues S1 (Modifications),
S2 (IIPCI), and S3-2 (Fire Protection Program lasues).
Obtain the list of Appendix R mods nquired to 'be complets.' prior to o
startup and obtain status of those modifications.
o Review the 1992 Emergent Modification Refueling Outage Status Report to verify. laclusion of modification status o
Review JPN 92-032 for exemptions requests for fire prdection
- modifications and determine frorn Licensing the status -of - those' exemptions.
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- Independently verify the status of selected:non-exempt modifications through interviews, document nyiews,-and field verification (including procedures and training).-
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Detennine plans or status of related fire brigade training..
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2-CONCLUSION:
'Ihe issue has been resolved.
Actions taken to date and planned for the future wul neult in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be 'taken to ensure that the issue is appropriately resolved on or before September 26,1992.
X Resolution of this issue before September 26,1992 is unlikely.
JUSTIMCATION/ RECOMMENDATION (S):
r Thldy-four fire protection modifications are being tracked for completion pdor to stadup.
Seven of these modifications were reviewed to determine their actual status as compared to the status shown on the 1992 Emergent Modification Refueling Outage Status Repod.
Currently six of these modificatlons have a scheduled completion date beyond 9/26/92 (see Issue E-1). Dey are being tracked on a different schedule and am meelv!ng substantial i
attention to pull them back to a 9/26/92 completion. De runalning 27 modifications reviewed were all progressing with status as mpoded on the 1992 Emergent Modification Refueling Outage Status Repon generally accurate and a high probability of completion prior to stadup..
Interviews with licensing personnel indicate that the NRC is currently mvlewing the mquested exemptions from Appendix R. An NRC raponse is anticipated by 9/4/92. No additional exemption aquests are anticipated to be requimd.
De Training Supped Supervisor was interviewed to determine the status of fin brigade
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training for the 34 fire protection modifications. It was deterinined that the Training Support Supervisor mvlews each approved modification for mquired talning. His includes the fire protection modifiestions mquimd pdor to startup. F1m Bdgade tmining mquiswd by these modifications has not been significant. More significant fin bdgade training is required as a neult of revisions to the fire pm-plan. His training is curnetly underway and scheduled for completion by 9/28/92. De trsining involves both IW (not shift supervisors) and non-licensed operaton which will be cdtleal resonree in the two 3
weeks paceding plant startup.
ISSUE ANALYSIS ISSUE NUh!IIER: E7 ISSUE STATEMITNT:
Outstanding Temporary Modifications Oumpers). WACP 10.1.3 addresses control of temporary ruods, jumpers and lifted leads. We should provide an overview cf the JAF effort to satisfy the requirements of WACP 10.1.3.
OI1JECTIVES OF TIIE ANALYSIS:
To overview the Temporary Modifications to determine whether WACP 10.1.3 (Control of Junipers, Lifted Leads, and Temporary Modifications) meets the requirements for start up, whether the requirtrnents of WACP 10.1.3 have been satisfled by subsequent JAF action, and whether additional actions are required to satisfactorily control Temporary Modification use.
APPROACII:
o Review the requirements of WACP 10.1.3.
Interview Operations Manager, System Engineering Supervisor, and Site o
Engineering Manager to determine the history of WACP 10.1.3, status of the draft revision of this proceduty, and recommendations for improvement of this process, o
Determine actions taken to date to nicet the requirements of WACP 10.1.3 and to meet twommendations made for improvement of the Temporary Modification process.
Review the Jumper, Lifted Ixad, and Temporary Modification Log to o
verify compliance with procedures and reconunendations for huprovement.
CONCLUSION:
'nie issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
X Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
-2 J USTII1 CATION /RECOhihiEND AT10N(S):
Procedure WACP 10.13 states that "It is Intended that jumpers, lifted leads and Temporary hiodifications be minor in scope, or short duration, and few in number...". A review of the Temporary hiodincation log revealed that 138 open Temporary hiodifications exist with the following aging:
01 Greater than 4 years old 01 Between 3 and 4 years old 13 Between 2 and 3 years old 50 Between 1 and 2 years old 73 less than 1 year old A review of the history of Jumper, Lifted Lead and Temporary hiodification concerns revealed the following:
o 12 ACTS action items assigned and closed from 1985 through 1991.
o 4 luP related ACTS action items cuntntly open.
o 6 ACTS action items (non RIP related) currently open with due dates extending to as late as 3/1/93.
The closed ACTS Items show a long history of concern with both control and backlog of Tempora 7 hiodlucations. For example, during the INPO 1988 Plant Evaluation concern was expressed that the number of Temporary hiodifications (then 96) was too gitat.
Recently, LER-92-021-000 resulted from lack of proper Temporary hiodification control.
Additionally, the NRC DET noted a specific instance of installation of a Temporary hiodification without progr authorization. In response to these events the following actions are currently under way:
o Technical Services was assigned to conduct a review of active work requests and to walk down safety related systems to identify any unauthorized Temporary biodifications. These efforts are being tracked as AUss Action Items 4684 and 4685, with completion scheduled for 9/18/92 (pre-startup).
o Technical Services was assigned to revis: procedure WACP 10.1.3 to reflect current INPO guidance and in house-experience. 'Ihis is a m: dor revision and is currently scheduled for completion 12/31/92.
- Tecimical Services was assigned action (in response to RIP) to develop a o
program to reduce the number of Temporary Modifications.
'nds program ls due to be developed by 12/31/92, i
Planning, ALIntenance, and Operations personnel were assigned to review f
o treent Temporary Modification controlissues with their persoimel. Rese J
nettons are tracked by ACIS action items *628,4629 and 4637 due 8/15/?2 (pre-startup).
Concern for the large number of Temporary Modifications rrsulted in a recent investigatica of the backlog by the Systems Engineering Supervisor. In a June 25,1992 memorancam that resulted from this review of outstanding Temporary Modifications it was concluded that 'In sununary, current plant use of WACP-10.1.3 is largely inconsistent with its latent as stated in Section 2.1 that they "be minor in scope, or short in duration, and few in number" and that they "shall only be used when their use is essential for testing, checklng or repairing of plant system equipment / components, or to provide operation of essential funellons if a system or component has failed." As a rtsult, a large emergent workload is being hnposed on an engineering organization that is 111 ululpped to handle this work in conjunction with other urgent plant needs."
We issue of control of Temporary Modifications appears to be adequately addressed by the actions planned as noted above. IIowever, the thnellness of latroduction of the revised rawWACP-10.1.3 is not consistent with the history of problems nor with a sense of urgency to trsolve Temporary Modificat*on control issues. Revision of WACP-10.1.3 should be accelerated. Training of personnel required by ACTS Items 4628,4629 and 4637 should be on the new procedure with an emphasis by senior management on the hnportance of conformance with the revised procedure.
he large and long lived backlog of Temporary Modifications should be addressed more aggressively than is currently scheduled with ACTS action item 3181 (plan due 12/31/92).
Concurrently senior management should set clear goals on acceptable levels of Temporary Modificatlans for return from outage and for operation. Finally, sufficient resources should be apgiled to ensurr that the current backlog of modifications is reduced (see issue E 1) such that modifications can be processed in a reasonable time period mhitmhing the need for long 11 red Temporary Modifications.
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ISSUE ANALYSIS ISSUE NUMilDt: 01 ISSUE STATEMENT:
Operating Experience Review Backlog and Quality of Past Reviews. We should review the follow-through of the bacidog reduction plan, and sample the
- quality" of two current open ODts.
01UECTIVES OF TIIE ANALYSIS:
To ensure that the ODt bacidog reduction plan is on schedule and is not jeopardizing start-up, and to ensure that rational criteria were employed to identify past operability failures, estabihh sample sizes for reviews of past ODt work and detenninntion of potential operability review concerns.
APPROAC11:
o Reviewed the following documents:
PSO-28, Industry Operating Experience and Vendor Technical Infonnation Assessments PSO-28X, Industry Operating Experience and Vendor Technical Information Bacidog Ethnination Program Industry Operating Experience and Vendor TechalcalInfonnation Evalm.tlon Program Plan, June 18.1992 Industry Operating Experience Pm-Startup Sampb Review Process Plan, hiay 20,1992 Interviewed the following people to confirm program scope, resource commitments, o
program schedules and current status:
System Engineering Supervisor Backlog Elimination Project hianager 11acklog Elimination Team Leader
4 2-Selected and reviewed three current OER packages to assess the quality of nylews o
OE/VI No. 850402 (SIL 430s OE/VI No. 920268 (SER 92-08)
OE/VI No. 920458 (Rosemount 920630)
CONCLUSION:
De issue has been molved.
X Actions taken to date and planned for the future will nsult in the appropriate nsolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue 'Is-appropriately resolved on or befon September 26, ~1992.
Resolution of this issue befon September 26,1992 is'unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Recent activities in the OER Program have been directed toward four major goals:
1.
Review of Pmiously Dispositioned OER liens One of the actions newiting irom the ATIS Relay Enfortement Conference (NRCI-91-22) was that a review of pnviously dispositioned OERs was perfonned (ACTS 4492). De purpose.of this review was to identify any potential operability concerns and to determine the effectiveness of pmious OER evaluations.
Fmm a total database of approxhnately 6200 previously LWoned OERs (dating _
to 1984),653 items wert. Identified as significant. A significant OER was defined as any SOER, Cat 1 SIL,10CFR21 notification, or pdodty 1 OER._ An initini random sample of 97 of these significant OERs mealed 15 program miew failures and 2 potential operability concerns. Dese fauuns triggered an expanded scope miew of an additional 556 items, which was all of the remaining significant OERs.- he expanded nylew yielded another-74 program fallums and one mort-potential operability concern.
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3 He process of identifying potential operability concems and program review fanures is described in the Industry Operating Experience Pm-Startup Sample Review Process Plan, dated 20 May 1992. Basically, a potential operability concern is any issue that affects the operability (as denned by NRC Generic Letter 91-18 and Standard Tech Specs) of one or more systems / components required by Tech Specs for each operating mode. A program review failure is any other discrepancy associated with an OER lssue, including, but not Ihnited to, insufficient documentation, inappropriate corr (ctive action, and failure to address all concerns of an issue.
Although the program failure rate appears to be signliicant (approximately 15%),
further expansion of the sample rtvlew scope is not planned for the following reasons. First,100% of the previously dispositioned OERs that wert identified as
.significant have been reviewed. Second, the potential operability failure rate was very low - three concerns out of 653 previously dispositioned OERs. 'Ihlrd,11 was felt that the limited resources dedicated to the OER program would be better spent reviewing and reducing the current backlog of OERs, rather than revisiting any mort previously dispositioned OERs that are known to be of lesser significance.
Lastly, the current OER review process requires scanning all related OERs in the database (including previously dispositioned ones) when addressing a new OER.
Of the three potential operability issues that were identifled through tids process, two have already been resolved and the third (SBM switches) has an action plan approved and in progress. (Potential operability concerns associated with the SBM switch issue are further discussed in Issue S3-26.) Thert art no further startup l
commitments associated with this issue.
2.
Identification and Review of Illgh Priority OER Issues In order to establish a reasonable level of confidence that potential operability concerns in the current OER backlog are addressed prior to startup, two commitments were made. One was to scan the current backlog of unrtviewed OERs (approximately 510 items) and identify all priority 2 and 3 OERs that had a Idgh probability of causing an operability concern (ACTS 4827). Seventeen such items were identified. Two have already been closed. Seven issues have been reviewed by the Backlog Ethnination Team and the proposed actions are being reviewed by l
various plant departments. The remaining eight issues are still undergoing initial review by the Backlog Elimination Team. A review of the resources dedicated to this effort (four full-time reviewers) and the nature of the potential operability issues l
Indicates that these items will all be itsolved prior to startup.
4 A second comnutment was made to ensure that all priority 1 OERs in the current backlog have been reviewed within 30 days of recclpt (ACTS 3992). H ere are currently only five or six priority 1 ODts awaiting review, although this number can change daily. A review of approved procedures and current practices in the ODI group indicates that this cornndtment will be met prior to startup.
3.
OER Progntmmatic Improvements ne need for OER programmatic improvements was identified in recent audits and inspections, including QA Audit 763, DET Findings,1988 INPO Inspection Report, and NRC Inspection Report 90-01. To address some of the identified concerns, an OER program plan was approved on May 18,1992 and is in progress. One of the major elements of this plan was to revise PSO-28 to improve OER program assessments and to provide standards for OE reviews (ACTS 4485). To date, four of eight PSO 28 sub-procedures have been PORC-approved. De remaining four sub procedures have been written and are in the rtview cycle. It is anticipated that they will be PORC-approved by Septeinber 26,1992, in order to assess the quality of recent OERs, thtre random OER packagt:s were riviewed. One of the packages (OER No. 850402) appeared to have an incomplete initial review. However, this shortcom!ag was identified prior to final closcout and the OER was returned to the backlog for further review. (This was a priority 3 OER.) Two other priority 1 OER packages (GER Nos. 920268 and 920458) were found to be complete and thorough. He proposed corrective actions seemed appropriate and those packages were either being reviewed by plant staff or awaiting final approval.
- 4. Backlog Reduction The current backlog of unreviewed OERs is approximately 510 items. A backlog climination program has been approved and is in progress. However, most of the resources of the Backlog Elimination Team are presently working on procedure development and/or resolution of the seventeen high priority OERs. As such, the backing level is not anticipated to decrease until after startup. De present plan is to continue backlogging incoming OERs (except for priority 1 OERs) until two weeks after startup. At that time, the backlog will be closed to new OERs. Backlog ethninntion will then continue in accortlance with PSO-28X, and is expected to last 12 to 18 months, with a staff of six dedicated to the effort. New OERs will be handled independently in accordance with the rnised PSO-28. There art no startup commitments associated with backlog reduction, other than those already discussed.
ISSUE ANALYSIS ISSUE NUMBER: 02 ISSUE STATFMENT:
Master Equipment List (MEL) Reclassification. 'Ihis issue deals with the adequacy of QA classification upgrades. We should review the actions in progress prior to stadup, with a considention for operability of nelassified items.
OIUECITVES OF T11E ANALYSIS:
To assess the processes in use to validate the adequacy of QA classifications in the MEL, j
l determine how/lf the JAF commitments for GL 83-28 mm met by the MEL, and aseedain l
operability concerns ercated by MEL metassified items and potential for stadup impact.
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APPROACH:
l Reviewed background documentation (Ilsted in the issue statement above) o concerning J AF mponse to NRC GL 83-28 and the QA clasification process for items in the MEL including SURE lasues S3-C, S312, S3-26, S3-27 and S3-29, GL 83-28 and related mini-audit project plan npods, QA Audit Repod 92-07, MCM-6A EDP-31, JPN-89-066, J15 92-0626, JTS-92-0790, and JTS-92-0551, PSO-53, SWEC LTR J.O.02268.5026 of August 5,1992, WACP 10.1.18, and NRC Inspection 91-20/FAP ltem No. 6.
Interviewed the Technical Services Manager, Systems Engineedag Supervist o
Project Managen for the Component Classification Upgrade Evaluation (CCUm.i Project and the Safety-Related 1%nctional Analysis (SRFA), and h=8%
Information Supervisor to detennine what controls am in place to validate the adequacy of the MEL's QA classif6tions and what plans am in place to control and nsolve reclassifte.ation operability concerns.
- r Assessed the progress on component evaluations and nylews of operability _
o concerns for upgraded components and the ability to complete this work satisfactorily by September 26,1992, or justify delays until post stadup.
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2-CONCLUSION:
De issue has been msolved.
.i Actions taken to date and planned for the future will nsult in the appmpriate nsolution of this issue on or befon Sejdember 26,1992.
X Additional actions should be 'tden to ensure that the lasue is appropriately resolved on or before September 26,1992.
Resolution of this issue befort September 26,1992 is unlikely.
JUSTIMCATION/ RECOMMENDATION (S):
Here are two independent efforts relating to the classification of components: the i
Component Classification Upgrade Evaluation (CCUE) pmject and the Safety-Related Fbuctional Analysis (SRFA). Both are proceeding on schedule, and are scheduled to be completed prior to September 26,1992.
Over 30 potential issues of operability have been identitled. All but five have been evaluated with no operability problems identified. De nunalning five are being miewed in more depth. Some of these evaluat'nns may nquin new work (such as modifications) i for nsolution, but this is not presently known.
MEL Adegnacy Instances of relay and switch omissions from the MEL database wen discovend dudag the Investigations of Technical Issues 26 (SBM Switches) and 27 (HGA relays). Both of these Issues were generated as a result of nopening previously closed OERs (1976 GE SIL and 1983 NRC Bulletin). Or.;y 172 c. the 739 SBM switches were identitled in the MEL, and the mtale switches identified from walkdowns and pmicus work ortler history do not have effective QA category classifications. Similarly, the_ MEL identified only eight HGA -
nisys, whlie the walkdown found over 200. - Again, the QA category clasifications an unevaluated in the MEL.
t De New York Power Authodty's nsponse to NRC GL g3-28 speelfled that 'MEL is the
- single, concise, and unambiguous sourre for identification of safety-related components at the FitzPatrick plant." However, NYPA also acknowledged that many components were unlisted in MEL because they were not within the scope of the original MEL development.
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3 nese components included, among other things, relays and switches. Because these, and other, components mnaln unlisted in hiEL, a nvised response to GL 83 28 is warranted.
De Director Lleensing BWR is preparing an updated response to GL 83 28.
He hfEL database contains over 47,000 components and is controlled administratively by WACP 10.1.18. %e QA category classification which is au lategral part of the hiEL component database is developed through h1 Chi-6A, which progresses through multiple system safety functions to ensure correct safety classification of components.
De engineering evaluations for QA category classification changes and upgrades are controlled through EDP-31, which includes a process for evaluating operability based on the impact of procurement, maintenance, and histallation/ modification. Approxhnately 7500 items art identified for evaluation by Technical Services / Engineering. De Action Plan identified 1805 upgrade evaluations for completion prior to startup.
He acce'pted definition of a comprment, QA classifP 'lons of those components, and the identification needs for procurement and rnalntenance changed during fhe life of the hiEL.
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His bas contributed to the confusion. he current revision of WACP 10.1.18 does not address the philosophy of what items should be included or excluded from the hfEL. At this thne the hiEL procedurt (WACP 10.1.18) is the only programmalle guidance generally available, although a hiEUconfiguration management education program is bting considered. He hiEL procedure places responsibility for identifying new component / item entries or changes for h!EL with the plant department manage's and operating personnel.
Adequacy of QA Classification Re two independent efforts related to the classification of components at JAF am he Component Classification Upgrade Evaluation (CCUE) project, o
and he Safety-Related Rmetional Analysis (SRFA) review for QA a
classification changes.
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CCUE resulted from the JAF commitment to conduct EDP-31 QA classifleation/ operability j
evaluations on 1800 of 7500 items sud has been completed. Dere are approximately 20 items which are being reviewed further and which may require corrective actions to ensure operability.
In the first phase of the SRFA review,11 of 26 FSAR accidents and operational transients were used to trace through rtquhtd plant systems and components to identify / verify the i
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4-regulml QA classification needs. Aher startup it is planned to complete the SRFA review of the maalning 15 events. His effort has identified 25 potential opersbility heues. One of these 25 (D.C. load center feeding safety.: elated components) was_ reviewed and detennined to requht a new plant modification.
%ese reviews are being conducted to validate the process in use at JAF (now and previously) to develop or modify QA classifleations for plant components. In both cases, the process verification is based on a sample, and justification is doemuented for the use of these samples in the CCUE Prvject Plan and the SRFA Project Plan. De gristast concern is that seve:31 potential operability lasues are still being ennusted or rney yet be uncovemi, and any one of these could generate additional wort needed before startup.
Recommendations l
Based on the foregoing analysis, the SURE team recommendations ave I
o he revised response to GL 33 28 should Indicate that NYPA/JAF ricognize the probkms in the MEL, coenmit to a plan for impsweement and show some prettiss toward this plan. 'Ibe plan should encompass both the engineering effort addressing the validation of QA classification process and the steps to improve the adequacy of the MEL database.
o Dert should be a plan to complete the Component Classification Upgrude Evaluation (CCUE) project for the QA classification of remaining itsens identitled as omitted from the MEL. De plan should also' include p Sylsions for handling this analysis on an ongolag basis henceforth.
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ISSUE ANALYSIS ISSUE NUMBER: 03 ISSUE STATEMENT:
Work Request Backlog, specifically IIPCURIIR. We should review the bacidog to make sure it is adequately managed, and ensure that thert are no operability concerns, i
OI1JECTIVES OF TIIE ANALYSIS:
To ensure that the work request backlog is udequately managed and that there are no operability concerns.
APPROACII:
Reviewed documentation of the work request backlog status and L_d reports o
Interviewed the following personnel regarding backlog trends and prioritization of o
the outage work requests:
General Manager, Maintenance Planning Manager Work Control Center Supervisor 4
Interviewed the following personnel regarding the potentialimpact on startup of the o
current IIPCURIUt work request backlog:
Maintenance Manager I&C Manager IIPCI System Engineer RIIR System Engineer CONCLUSION:
'Ihe issue has beca res31 red.
X Actions taken to date and planned for the future will result in the appropriate resoludon of this issue on or before September 26,1992.
Additional actiou :,hould be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is until:ely.
2 JUSTIFICATION /RECOMMENDA'l ?N(S):
1 he prhuary focus of this analysis is on the IIPCURIIR work request backlog. Ilowever, this issue must be addressed in the routext of the total backlog of work requests.
Accordingly, this discussion provides information ont (I) the IIPCURIIR work request backlog, and (2) the total work trquest backlog.
IIPCURIIR Work Request Itacklog The work request backlog for IIPCURIIR, in itself, appears manageable. As of August 24, 1992, there were 106 open IIPCI work requests, of which 38 were identifled as outage work. Wirteen of these work requests were being actively worked, and none of the remainder appeared to pose any operability concerns prior to startup. There wert 129 open RIIR work trquests, of which 42 were classlued as outage work. Wirty of those RIIR work orders were being actively worked, with no outstanding operability concerns.
It should be noted that there were some outstanding commitments associated with the IIPCI system that might not be completed by September 26,1992. Those concerns have been addressed in Issue E-2, IIPCI Model System.
Total Work Request liacklog he total work request backlog is currently in excess of 3100 items, and the trtad has been relatively stable for the past six months. A subset of this backlog is a list called " outage work," and it is composed of the following:
o All Priority I work requests o
Any work requests associated with a control room dellclency o
Certain Priority 2, Priority S (special work orders that have specific deadlines) and Priority M (modincation) work requests that have been identified for this outage.
There are approxhnately 950 items on the outage work rquest list.
Of these, approxhnately 350 work requests air actively being worked, leaving another 600 work requests pending. It is generally agreed that not all of the work ttquests on the outage work list are required for plant startup. The list of work trquests necessary to satisfy startup commitments, and to ensure system operability,is much smaller. Given the limited thne remaining befort the target startup date of September 26,1992, it is mntial that the outage work list be prioritized. The Planning Department needs to kuw which work requests are actually required for startup so that they can plan and schedule accordingly.
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ISSUE ANALYSIS ISSUE NUMItER: 04 ISSUE STATEMENT:
We should look at the innd data on Phis.
OBJECTIVES OF TIIE ANALYSIS:
To determine the scope of the JAF PM Program and assess the adequacy of component coverage for stanup purposes, and to determine the tnnds of PM/ Chi ratios and FM bacidogs and whether any PM hacidog/ exemptions could jeopardize the startup dav APPROACII:
o Reviewed PM Program documentation to verify the scope, administative controls and responsibilities of that program are clearly defined.
o Interviewed the General Manager Maintenance, Maintenance Manager, Performance Engineering Supervisor, PM Engineering hinnager, Warehouse General Supervisor,1&C PM Supervisor and Maintenance PM Coordinator to ascenain adequacy of equipment covenge, PM exemptions or backlog necessitated by the outage schedule, and to verify cohesive effod between the departments on site involved in the PM program.
o Verified that NPRDS and OER inputs an used in developing the JAF PM Program, and systems or equipment identifled as availability outilerr. by INPO reporting am flagged.
o Investigated the PM/CM retto, PM backlog and PM tnnds, o
Reviewed specific corrective actions taken to improve the PM Program in response to the DET and recent enfonement actions.
o Investigated whether any apparent FM issues (exemptions, backlog, commitments) would jeopardize the stanup date.
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I 2-l CONCLUSION:
ne issue has been nsolved.
Actions taken to date and planned for the future will result la the appropriate resolution of this issue on or befort September 26,1992.
X Additional actions should be taken to ensun that the issue is appropriately resclved on or before September 26,1992.
Resolution of this issue befort September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
here bahe been significant isnprovements in the FM Progna in response to the DET and ncent enforcement actions. The improvements are the nsult of increased management attention, additional resourte allocation, and an increased Awarenen, plant-wide of what the PM Ihsi.m is and why it is important. Some of the most significant heprovements the program has undergone are discussed below.
i I&C One of the most important improvements is the inclusion of the PM engineering group in the development of the I&C program. De involvement of PM engineering assuns that there is a conelefant approach in program development between I&C and Malatan==ca-This also allows those responsible for ad=Inletering and controlling the program to devote
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more attention to those portions of the program.
Additionally, I&C has committed a sustained level of eachntel== manpower to the PM
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program. Computer equipment has also been purchased which will be used to tnad PM '
data.
Maintenamw De maintenance department has neently acquired four additional =;'r-n and reorganized to a component-based PM==*1== wing group. De new q's are currently undergoing training. ' Ibis will distribute the wortland more effectively and allow a more detallad and thorough review of equipment failures, CM and PM tands, and adequacy of '
the program on a day-by-day basis.
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Warehouse A review was conducted on the Storage PM Program admhilstered by the Material Control Manager. The program was found to be comprehensive and the cognizant personnel were very knowledgeable.
PM Trends 1
Trending data for the PM Program is tracked monthly in the Management Perfonnance Indicators Report. The FM backlog as of July 1992 for Malatenance is 86 tasks overdue and for I&C is zero tasks overdue. He PM/CM ratio as of July 1992 is 76% for maintenance and 47% for I&C. The trending since January 1992 shows maintenance has-a high PM/CM ratio but also has a high PM backlog while I&C has a low PM/CM ratio
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and zero PM backlog. The PM backlog la malutenance includes many outage PMs which must be worked during an outage. At the end of August 1992, the maintenance PM.
backlog had increased to 150 tasks. Additional attention is required to ensure none of the PMs jeopardize the startup date.
Recommendation Additional attenoon should be given to the maintenance PM backlog. Dere are a substantial number,0f outage PMs which still must be completed in order to assure the planned startup date of September 26,1992 is not jeopardized.
l Bert has been a marked increase in the PM Program visibility. De PM Program is treated as an important part of the overall plant' equipment program. All interviewees understood that the PM Program places : high premium on proactive maintenance. here is good communication and interface between those responsible for huplementing the PM program and those who provide feedback to the PM process._
5 Overall the PM Ngram is comprehensive and there is good communication and interface between mainte.pe, I&C, PM engineering, and performance engineering. His ensuris g
l an effective flow of information and assures that as equipment parameters change, the l
Information is transmitted to the personnel responsible for implementing the PM program.
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ISSUE ANALYSIS ISSUE NUnillER: 05 ISSUE STATEhU'NI':
Startup Milestone Schedule Program and Startup List Status / Control.
We should determine that the stadup is well organized and review the startup plan and the sub-elements of it.
OIUECITVES OF TIIE ANALYSIS:
To ensure that the stadup is well organized and that controls over the startup process are appropriate.
DEFINITIONS:
1.
BarturtPhu: A formalized management review process necessary to ensurt a safe and organized return to service.
2.
Startun Checklist (PSO-64. $0utnee_ Closcout - Readiness for Starntp_ Checklist":
A formalized checklist used to ensure outage work is completed and the plant preparrd to conunence startup.
3.
ACTS Startuo List: A list of actions necessary prior to coramencing startup. This list is controlled by the General hincager.
4.
Work Reauest nVR) Database: The plant database for tracking Wrs.
5.
XPM Ontane Schedule:
The outage schedule contains work items to be accomplished prior to plant startup. Examples ofitems contained in the schedule are: WRs, PMs, MODS. surveillance test, post work tests and milestones.
APPROACTI:.
Enlisted the support of all SURE team members in providing observations o
regarding the restart program and the results of that program, Surveyed the majority of employees interviewed for the SURE review regarding the o
startup process, Reviewed PSO41, Readiness for Startup Che<.klist, and the Startup Plan to ensuit o
that the plans ectablish a reasonable approach w muaging startup,
__ o Reviewed the following documents to ensure that key action items were incorporated into the relevant startup lists:
Major Technical Tasks Requiring Resolution Prior To Startup, JTS-92-0770.
'Ihe SURE list of 22 issues.
Records of other activities at JAF, such as preventive tunintenance and surveillance testing requhrd for startup, o
Interviewed the Assistant to the Resident Manager to review the current status of cc mmitments identified as startup issues in the Action / Commitment Tracking System (ACTS).
o Interviewed the Manager of Planning to review th? current status of the work request list and outage schedule.
o Interviewed JAF personnel such as the Resident Manager, General Managers, Department. Managers, and other JAF personnel identified as having key responsibilities for startup to (a) assess understanding of roles and responsibilities including oversight, (b) deterinine whether the startup plan is well managed and communicated, (c) assess the scope of the plan and the ability to lategrate new concerns, and (d) determine their progress against the startup plan.
CONCLUSION:
The issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992 X
Resolution of this issue before September 26,1992 is unlikely.
3 J USTIFICATION/lusCOhih1END ATION(S):
JAF has taken hnportant and necessary steps to prepart for startup. The Startup Plan and Startup Checklists provide reasonable guidelines for key JAF personnel to manage and control the startup process. Employees throughout the plant appear focused on preparing the plant for startup.
Ilowever, the SUIUs team has identified several areas of the startup process which might benefit from additional attention:
o J AF should create or define a single omclal startup list JAF should reduce the scope of work to be done prior to startup o
JdF should ensure that the Startup Plan is well<ormnunicated throughout all levels o
of the organization Era.h of these reconunendations is discussed in more detall below.
JAF should create or define a single omclal startup lht ne key startup lists omit some actions necessary for startup. Activities required for startup should be contained in at least one of two existing lists:
(1) the ACTS list (specifically, those ACTS Items identified for startup with an "s"), and (2) the Outage Work list. Cenain startup activ!tles are not included on either of these lists:
Certain preventive maintenance and survelBance testing activities o
Work requests for preventive maintenance and surveillance testing are not generated until the work is required. h!oreover, Phis and STs performed 1sy the I&C department art accomplished largely outside of the work request system. As a result, Phis and STs are not fully incorporated into either the Outage Work list or ACTS list.
In addition, the schedule provides relatively short windows for surveillance testing l
prior to startup.
The timeframes are historically based on the workload requirements during past outages. De typleal two week interval for survelliance l
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4-testing has been reduced to ten days for this autage, due to the fact that some of the nquired surveillance testing is being done ahead of schedule. However, after this
- extended outage, mote than the usual amount of time might be nquind for surveillance testing.
l o Cedain modifications Spot checks of the Emergent Modifications 11st and the AC15 list Indicata that some modifications cannot be readily identified as ACTS hems. For example, of the 73 mods appearing on the 1992 Refue! Outage Emergent Modification W=i ri;; and i
Planning Status Report, only 10 an explicitly listed in AC13. Some modifications may be covered by a single ACTS item that nquires an evaluation or nsponse to a general issue or concern. See SURE Issue E 1, Modification Completion, for mon on this subject.
t o Major Techalcal Issues
'Ibe three general managers at JAF reviewed all of the items on the startup checklist to ensure that they were included on the ACTS list and coded with an "s" to indicate startup. However, that inillat nylew did not include the Major Tach =hl Issues list.
With the support of the Assistant to the Resident Manager; members of the SURE.
team spot-checked selected iteens from the Major Tach =le=1 Issues list to verify that each item had an associated ACIS ltem. No disempancies were noted. However, -
l a coruprehensive review of all of the Major Technical Issues should be undertaken to ensun that all of the issues an, in fact, included le ACIS.,
Accordingly, JAF should create or define an official startup list that incorporates all of the many and diverse actions that are esquired to_ be accompInsbed' prior to startup.
Ibsthetmore, a single individuat in the organization should be tasked with maintainlag that ~
Iht. _'Ihat person would be responsible for updating the list as actions are completed, ensuring that due dates an met, and nporting overall status on a regular basis.
- JAF should reduce the scope of work to be done prior to startup L
s Management of the Outage Work L,
. act consistent with the effective management of the tartup process.- In the. Wort aquest/ Equipment Deficiency (WRED) system, work-requests are prioritized as either ou*. age (O) or nonautage (N).- However, of the 959 WRs L-
- on the Outage Work list dated 20- August 1992, 303 WRs were coded as nonoutage.
Interviews confirmed that.WRs exist that, while not requhed for startup, are still on the L
Outage Work list.
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3 rurthemore, the review processes for the startup items on the ACTS list and the items on the Ov. age Work list are inconsistent. The review process for adding and deleting startup nicans :;n the ACTS list is managed at the resident manager / general manager level. On the other hand, management of the Outage Work list is performed largely at the supervisor level nrJ reviewed at the department manager leve, (Newly-added work requests ara reviewed by the resident manager at the Three Day Platalng Meeting, but this is done after the items are already added.) As a result, the addition of WRs to the Outage Work list may not always be consistent with the priorities set by senior management.
Given the la:te amount of outage work that has been identified, and the limited amount of time and resources left in the outage, it. is essential that the scope of outage work be reduced as soon as possible.
PSO-64 establishes guidelines to help determine which activities sould be designated as startup items. IIcwever, these guidellacs are not always specific enough to be useful. For example, aggregate items having high backlogs (such as jumpers or Wrs) are considered startup items, but there is no definition of what constitutes a "high backlog. Similarly, items that have significant economic benefit are considered startup items, but there is no definition of "significant."
Therefore, it is recommended that the guidelines of PSO-64 be reviewed and clarified as necessary. Then, tiiese guidelhrs should be e m vly applied to both the Outage Work list and the ACTS list to identify only those activius. hat are essential to startup. In this way, the planning department can realistically plan and schedule activities and resourrn in the Ihnited time remaining in the outage.
J AF should ensure that the Statup Plan is well-communicated throughout all levels of the organization.
Of25 i :rsonnel surveyed during the SURE process,14 could not identify or did not have a copy of the Startup Plan. Although many of these people were at non-management levels, some were managers who were reporting that they did not have copies of the Startup Plan.
This was confinned in interviews and through questionnaires. Because the Startup Plan delinentes specific responsibilities all the way down to the supervisor level, it should be more widely distributed and publicized.
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ISSUE ANALYSIS ISSUE NUMBER: 06 ISSUE STATEMENT:
Control Room Deficiencies: We should trend the completion of die se items, and vuolne if any are operability concerns.
OlUIXTIVES OF THE ANALYSIS:
To deterinine if the number of control room denciencies is trending down and if any existing control room deficiencies are operability concerns and potential start-up impacts.
APPROACll:
Obtained a listing of open control room deficiencies from the work control center o
o Reviewed the denciency list using the criteria of GL 91-18 for operability determinations o
Discussed the listing of open control room deficiencies with the Work Control Center I
Supervisor i
CONCLUSION:
The issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolut!on of this issue on or before September 26,1992.
X Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
The number of control room deficiencies is tracked on a weekly basis. The work control center supervisor is aware of the control room deficiencies that are operability concerns.-
The work control center supervisor is also aware of the control room deficiencies that must be repaired prior to startup. Ilowever, the station is currently working toward repairing all control room deficiencies. There has not been a prioritization of what control room
- deficiencies are requimd pdor to start-up. On April 10,1992, the number' of open work-nquests on contml room deficiencies was 82 and as of August 22,-1992 there wem still 66 open work nquests on control room deficiencies.
To most effectively manage the limited mources as the startup date_appmaches, it is -
- important that then be a prioritized list of open work requests involving control room deficiencies. Accordingly, the SURE team neommendations an:
o Priodtize 'the control room t@'encies list based on what 5 required to be:
performed prior to startup.
Ensure appropdate resources are allocated to complete, as a minimmu, all control 0
room deficiencies work requests which an required pdor to startup.
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ISSUE ANALYSIS ISSUE NUMBER: S-6 ISSUE STATEMENT:
Material Condition / Housekeeping Readiness: The readiness for startup should include the material condition of the plant. PSO-58 and WACP 10.1.7 provide the guidelines and the mechanism for assuring cleanliness conditions which lead themselves to an orderly start-up and at atmosphere for continued safe operation and maintenance of equipment. We should confirm evidence of adherence to these two documents and make personal observations as to plant material condition and housekeeping.
OIUECTIVES OF TIIE ANALYSIS:
o To ensure that mechanisms exist to assure cleanliness and effective material condition which lend themselves to an orderly stadup and an atmosphere for continued safe operation and maintenance of equipment.
o To ensure that JAF meets the requirements for PSO-58 (Management Observer Program) end WACP 10.1.7.
APPROACII:
Reviewed JAF plant procedures / standing orders WACP 10.1.7 and PSO-58 and o
the quaderly observation schedules for accuracy and completeness Reviewed all available startup lists to determine areas of potential concern o
Interviewed plant staff and other SURE team members to obtain observations o
regarding plant conditions.
CONCLUSION:
The issue has been resolved.
Actim taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
X Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIMCATION/ RECOMMENDATION (S):
Overall, the Deld observations of team members on site expressed a general concern for the amount of disarray throughout the plant and on site. Some areas of concern included:
The East and West Crescent areas need a major cleanup prior to startup.
o Most of this clutter is t result of the large amount of work in progres, and some cleanup is evident by comparing current material condition from that of the past few 7eeks, but a major effort is needed in this area.
Cleanups in this area should be coordinated to minimize overall radiation exposure due to high radiation levels.
In the East Pipe Tunnel, the housekeeping aspects of the work in progress o
was much better but a large amount of work is still needed, The outside areas of the plant in general are in better shape. One area of o
concern is the posting of trailers used for storage of radioactive material.
One trailer is posted only on two of the four sides, and is not locked.
Postings contain no infomiation as to the contents of the trailer or when the survey was taken, Liquid waste drums located on a pad on the northwest side of the plant o
are labeled, but the tags are deteriorating and should be replaced, or else the drums should be stored under a roof or some form of covering to prevent this, Scaffolding clamps are stored in 55 gallon drums; these drums should be o
covered to prevent rain water from collecting in the drums.
Damaged drums should be marked and placed in metal trash dumpster for o
disposal.
ISSUE ANALYSIS ISSUE NUMllER: 07 ISSUE STATEMENT:
Operator Training: We should verify with the Training department that all licensed penonnel are up to date on their training, both classroom and simulator, and that all training required as a nsult of outage evolutions (mods, commitments, etc.) is completed and documented.
OBJECTIVES OF TIIE ANALYSIS:
To determine that licensed operaton an up to date with training, both classroom and simulator, and that all training requind as a result of outage evolutions (modifications, conunitments) is completed and documented.
APPROACII:
o Interviewed the Training Manager regarding the overall plan to address training requirements prior to startup.
Interviewed Operations Training Supervisor regarding the specific talning o
evolutions necessary for licensed operaton prior to startup, o
Reviewed training documentation for licensed operator mqualification curnney.
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o Verified completion of startup evolutions in the simulator, including reactivity manipulations, Reviewed lesson plans for licensed operaton in the area of modification training and o
other pre-startup commitments.
o Interviewed simulator manager to determine simulator curnney for pre-startup training.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the-appropriate resolution of this issue on or before September 26,1992.
i Additional actions should be taken to ensun that the issue is appropriately resolved on or before September 26,1992 i
. Resolution of this issue before September 26,1992 is unlikely.-
JUSTIFICATION / RECOMMENDATION (S):
De training staff has continued to provide requalification t:31ning thnughout the outage.
In addition, there has been specific simulator training pawrided to th*=asvi operators in stanup activities, including nectivity manipulations. A program exists _on the AS-400 computer which tracks the training evolutions of Ile*=d operaton. Hus, the current status of all training activities is easily accessible for all lleennad pena==al he operations training supervisor reviews this status report on a ngular basis. Hertfort, the operator training program appears to be appropriately managed, and will provide each licensed operator with the training requind for startup in a timely manner.
Licensed operators are tralned on mods completed during the outage in 'he same manner as other personnel. Dis training is continuing, and is dependent upon the. training department receiving the mods as they an signed off as completed. ~ his apresents a potential concern if mod paperwork is ncelved late in the outage. ' Of gianticular concern at this time is a commitment to train operators on two specific AOP's that an related to fin protection. AOP-43, shutdown from outside the cc itrol room, and AOP-28, operation during plant fires, are both still in the pr=H'=I==-y stages of development, and are going through the review process. Given the size and complexity of those procedures (AOP-28, for example, is approximately 188 pages in length), that nylew process and the nafimate -
PORC approval could occur very late in the outage, thestby requiring prk,.uy attention =
to the required training. He training staff is await of this concern, and is following this-g issue closely. (See the draft copy of AOP-48 as it relates to this lame.)
Documentation of operator training is tracked by computer. He process is well daelened, well-executed, and adequately tracks the training activities of Ile*==d personnel.
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.l ISSUE ANALYSIS ISSUE NUMBER: 08 ISSUE STATEMENT:
Training for other plant personnel (where "other" is defined as those personnel who art not licensed operators). Verify with the Training department that all other plant personnel are current in their requhtd training (non-licensed operators, fim brigade) and that training is given to appropriate personnel on any new equipment, procedures or plant evolutions that came about as a result of outage work.
OBJECTIVES OF TIIE ANALYSIS:
To determine that non-operator personnel are current in the required training (such as non-licensed operators and fire brigade), and that training is given to appropriate personnel on any new equipment, procedures, or plant evolutions that came about as a result of outage work.
APPROACII:
Interviewed the Training Manager regarding the overall plan to address training o
requirements prior to startup.
Interviewed the Training Support Supervisor regarding the training of rare brigade o
personnel.
Interviewed the Technical Training Supervisor regarding the training of technical o
personnel in mods completed during the outage.
Reviewed the schedule for training of fire brigade personnel to ensure coverage of o
all fire pre-plans prior to startup, Reviewed a sample lesson plan for fire pre-plans intendea to famillarize fire brigade o
personnel with the concept of fire pre-plans, Reviewed a modification work package with training department program revision o
action fonn to understand the process by which a mod is reviewed, evaluated for program inclusion / revision, and included in the training curriculum for selected training programs.
Reviewed training records to determine currency of training for non-licensed o
personnel where applicable.
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' CONCLUSION:-
Tne issue has been nsolved.
X
' Actions taken to date and planned for the futum will result la the appropriate resolution of thh issue on or befon September 26,1992.
Additional actions should be taken to ensurt -that'the issue is appropriately nsolved on or befort September 26,-1992.
Resolution of this issue befon September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
He training staff developed lesson plans, schedules and contingency plans to ensure that '
fim brigade personnel receive apprcpriate training.- Fire pre-plan training is continuing at the pnsent, and has actually commenced two weeks earlier than odginally scheduled.
Beginning September 1,1992, training personnel will train fin brigade members on-shin, to ensure that all appropdate personnel receive this training prior to startup. Training on the 'use of new fire protection equipment has been conducted as deemed=====ry by training staff. An example of this is the use of a new type Scott Air Pack, which is now -
in pla:+ in designated areas of the plant.
Modifications have been part of the training cycle for non 1W plant personnel. ~ A process is in place by which mods are evaluated for training impact, and the training staff, with the==Ictam of the departmental training coordinators, detennine the best way to -
present applicable material. Training staff has been proactive in the timely scheduling of:
training when alerted by _ departmental training coordinators or other dei;-wtal '
supervisors of future needs, and currency of training has been verified where applicable.
Ihe training department uses the ACIS list to determine if any training issues deal with operability concerns for startup. -
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i JSSUE ANALYSIS ISSUE NUMBER: 09 ISSUE STATEMFET:
' Staffing (Operations): Review the staffing plans for the startup evolution. Ensure that appropriate personnel are available and that the startup schedule does not violate any work hour commitments for personnel involved in the startup.
OBJECTIVES OF TIIE ANALYSIS:
To ensure that appropriate personnel art available and that the startup schedule does not violate any work beitr commitments for personnel involved in the startup APPROACH:
Met with the General Manager of Operations to discuss operations staffing and o
the startup plan.
Discussed Operations staffing for startup with Assistant Operations o
Superintendent (Operations Manager on vacation).
Discussed the availability of a detailed startup schedule with Outage o
Coordinator and obtained available startup schedule. (A detailed schedule from rod pull to 100% power including the planned hold points as described in the startup plan).
CONCLUSION:
The issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is X
appropriately resolved on or befort September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
2-JUSTIFICATION / RECOMMENDATION (S):
The conclusion is based on the fact that there are two options available to the operations department to ensure greater than mhdmum staffing during the startup process, he two options are to shift from a six shift to a five shift rotation which allows an increase to each shift from the sixth shift's compilation. The second option available Is a delay in operator training which would provide for the training shift to support startup. The General Manager of Operations provided assurance that the operations department will not violate the work hour guidelines outlined in technical specifications.
Recommendations for the resolution of this item include:
Complete a detailed startup schedule that includes all hold points o
identified in the startup plan.
he Operations Department should review the schedule and then provide o
a plan for greater than minimum staffing for complex startup evolutions and an overall plan for coverage of plant startup.
o Provide for a review of this item at a date closer to the startup of the plant to assure that this item is addressed satisfactorily.
De section of contingency plan development of the startup plan should be o
more tightly controlled and better defined.
ISSUES S-1 THRU S-6
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ISSUE ANALYSIS -
ISSUE NUMBER: S-1
- ISSUE STATEMENT:
Compensatory measures Including ALARA reviews. -
See item on-~ Appendix; R Modifications, Item 6 in Engineering related issues (Issue E 6) and tech spec submittals as indicated in Item 2, below (Issue S-2).
- ORJECTIVES OF TIIE ANALYSIS:
- t Review Appendix R-related compensatory measures in effect to detennine if the measures taken will adequately ensure that the Fut Protection Program complies with Appendix R ;
and approvals of exemption request will be received by the September 26 startup date.
APPROACH:
Review the license relief request for appendix R and tech spec revisions in progress.
o-Lo. Review common issues with team members for -issues E-6, S-3-3, and S-2.-
Incorporate pertinent data into final response.
Discuss impact and accounting for compensatory measures on the startup plan with o
the Mre Protection Manager.
Review actions of support staff to detennine contingency plans in the event of delays o
or denials from the NRC, or if other potential problems exist.
CONCLUSION:
'Ibe issue has been resolved.
X
- Actions taken to date'and planned for the future will result in the-appropriate resolution of this issue on or before September 26,1992.
Additional actions should be - taken to ensure that the-issue is
- appropriately itsolved on or befort September 26,1992.
Resolution of this issue befort September 26,1992 is unlike!y.
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m m-1 JUSTIFICATION / RECOMMENDATION (S):
Reviewed documentation and discussed with Licensing personnel the three exemption request submitted to the NRC for interim relief to certain requirements of the Appendix R Program to assess if approval to these requests will be received prior to the September 26 startup date. Exemption requests have been submitted for the following three issues:
Cable Tunnel Suppression System o ESW Pmnp Room Vent 11ation
- Three-hour rated nre bar r penetration seals These temporary exemption requesti ere submitted in July and favorable environmental impact statements have been receivea from the NRC, It is expected that the NRC will approve these exemptions prior to the September 26,1992 startup date.
Discussed with the Fur Protection Manager the methodology for determining what compensatory action should be taken to resolve deficiencies in the nre protection system.
Detennined the decisions made and actions taken were comprehensive and conservative.
Discussed schedules with project engineers responsible for perfonning the modifications which will end the compensatory actions, Connrmed that compensatory actions will stay in place until modifications are implemented and deficiencies are declared operable.
Discussed with ALARA Department to determine if compensatory measures _ taken considemd appropriate action to minim 17e Man-Rem exposure. RES Supervisor confirmed adequate evaluation was performed when implementing fire watches to maintain low Man-Rem exposure. A relief request to make use of electronic equipment to satisfy technical specification rtquirements for posting a fht watch was prudent. 'Ihe NRC has already approved this relief request.
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ISSUE ANALYSIS ISSUE NUMBER: S-2 ISSUE STATEMENT:
Licensing Technical Specification Revisions including obtaining NRC approval for the following ite.ns:
ATI'S Response Time Tech Specs Appendix R Relief Requests IST Relief Request Reactor Vessel Head Inspection Results IGSCC Inspection Results CIV 9 (Table 3.7-1) Deletion f. om Tech Spec RIIR Shutdown Flowrate Tech Spec IIPCI/RCIC OperabEity Tech Spec RPV Ilead Spray Tech Spec Submitting the following items to the NRC (approval not requhrd):
Off Gas Flow Rate Tech Spec RWCU Ieak Detection Tech Spec Core Spray Flow Rate Tech Spec OBJECTIVES OF TIIE ANALYSIS:
To ensure that all submittals to the NRC and all of the approvals by the NRC, that are required for startup, have been obtained.
APPROACII:
o Reviewed the documentation listed above to determine the status of the activity and to identify JAF/NYPA personnel associated with the activity.
o Coordinated with the SURE team member responsible for E-2 (HPCI-Model System Progress) to consolidate and combine approaches to aramining HPCI/RCIC Operability Tech Spec.
Interviewed key JAF/WPO personnel to verify and update the status of each task or o
activity and to confinn the current status of each activity through field observations or additional interviews.
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d CONCLUSION:
ne issue has been nsolved.
X Actions taken to date and planned for the future will usuk in'the appropriate nsolution of this issue on or befort September 26,1992.
Additional actions should be taken to ensure that the issue ~ is appropriately nsolved on or befort Sep*=hae 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Discussed the status of licensing actions nquired for plant stanup with the Dinctor of Licensing, staff members and the PORC Chairpenon and PORC secntary. Also reviewed
' documentation submitted to the NRC and Safety evaluations and nsponses inn the NRC
- giving the AUTHORITY approval on certain nquests.
He licensing actions nquired for startup. consist of.two categodes:
- a) nose items required to'be submitted to the NRC for approval prier to stadup _and b) those items required to be submitted prior to startup.
All but two listed in the first category (Items submitted to the NRC for approval pdor to startup) have been approved by the NRC. Two items, the ATIS Response Dne and the-Appendix R (Fire Protection) relief nquest, art er:=e**d to be approved by the fint reek in September. Licensing stafT members m supplying the techntesi information requested by the NRC to support this schedule.
Two of the three items in the second category (submittal to the NRC nquind prior.to i
startup) are still pending final PORC approval and are at vadous stages in the process. -
NYPA should continue with the review of the Fue Protection (Battery Room Corridors only) and the Core Spray Flow Rate Reduction tech spec submittals..
= Status of the two incomplete issues are addnssed below:
- 1.
He Safety Evaluation for supporting the Fut Protection issue was apprsved on 8/26/92.
I 2.
The Safety Evaluation for Core Spray issue has not been approved as of 8/28/92.
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ISSUE ANALYSIS ISSUE NUMBER: S3-1 ISSUE STATEMENT:
The NRC Diagnostic Team identified a number of observations (DEOs), some of which are considered to be potentially significant items.
OIUECTIVES OF TIIE ANALYSIS:
To ensure that actions necessary to resolve the subset of NRC team observations that am coded in ACTS as required for start-up are completed by September 26,1992.
APPROACII:
This issue was assessed as part of Issue S-5.
CONCLUSION:
The issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
X Additional actions should be taken to ensum.that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1997. Is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Refer to Issue S-5.
ISSUE ANALYSIS ISSUE NUhfBER: S3-2 ISSUE STATEMENT:
The following Hrt Protection Program issues (enforcement pending) were identified in NRC Inspection Report 92-80: (1) Program Inspections, (2) Combustible Controls, (3) Ignition Source Control, (4) Firewatch Training and Implementation, (5) Mre Brigade Program, (6)
Hre Pre-Plans.
OBJECTIVES OF TIIE ANALYSIS:
Assess the effectiveness of actions taken to resolve the above issue prior to startup.
APPROACII:
Coordinate activities for examining this issue with those of Issue E-6 o
Interviewed Fire Protection Supervisor, Training Manager, and Program o
hinnager to determine the status of fire program documentation, hTC comments from the August 1992 inspection visit, and program controls.
CONCLUSION:
'Ihe issue has been resolved.
X Actions taken to date and planned for the future wil! trsuit in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,-1992 is unlikely.
JUSTIFICATION /RECOhiMENDATION(S):
Many activities have been undertaken to improve the Fire Protection Program at JAF.
Some of these include the modifications work discussed in Issue Fe6, the addition of trained fire protection inspectors and fire protection engineering personnel for on-site assistance, replacement of worn equipment, revision of fire pre-plans and the issuance of new procedures for combustible controls and ignition source controls (hot work permits), and a considerable upgrade of the fire protection training program.
The recent NRC Fire Inspection visit (August 17 to 28,1992) reviewed the progress being made on Appendix R-related work, but determined that the work to date wns insufficient to close any of the findings from the NRC 92-80 inspection report. In that inspection report, concerns were :alsed regarding identification of safety-stlated components in the nre pre-plans and procedures. JAF has prioritized the fire pre-plan work to concentrate efforts on 29 fire pre-plans designated as necessary for startup. 'Ihe remainder of tht fire pre-plans are scheduled for completion after startup. Some idraining was also needed to support procedure changes (WACP 10.1.3, ITP 2.4, and WACP 10.1.10) in progress.
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ISSUE ANALYSIS ISSUE NUMBER: S3-3 ISSUE STATFRIWT:
Appendix R modifications or compensatory actions requind to be completed to bring JAF Into compilance with Appendix R.
These modifications or compensatory actions an nquired to be installed or approved prior to plant startup.
OBJECTIVES OF TIIE AN..JJSIS:
Assess actions necessary to complete engineering and htstall all identified modifications required to have JAF in compliance with Appendix R, and submittal and receipt of NRC approval of exemption requests for all items when the schedule will not allow timely installation of the modification, or where a permanent exemption from Appendix R requirements is being requested or revised.
APPROACII:
The portions of this issue dealing with modifications were discussed in Issue E6 and compensatory actions for Appendix R were discussed in Issue S-1. The portion of this issue dealing with licensing actions was included in the assessment of Issue S-2.
CONCLUSION:
De issue has been resolved.
Licensing X
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26, 1992.
Additional actions should be taken to ensure that-the issue is appropriately resolved on or before September 26,1992 -
Mods X
Resolution of this issue before September 26,1992 is unlikely.
- JUSTIFICATION / RECOMMENDATION (S):
Refer to Issues S-2 (for licensing), E-6 (for modifications), and S-1 for compensatory measures.
ISSUE ANALYSIS ISSUE NUMBER S3-4 ISSUE STATEMENT:
NYPA review for NRC Information Notice 91-70 identitled safety-related Foxboro instrument cabinets were not ins *alled per the seismic qualification configuration (Reference LER #92-002).
OBJECTIVES OF TIIE ANALYSIS:
ConRrm inspection of Foxboro instrumentation cabinets and restoratloa of them to the proper seismically quallued conDguration.
APPROACH:
Interview I & C personnel to review scope of work performed and indicated retest.
CONCLUSION:
X The issue ha been resolved.
Actions taken to date and planned for the future will result in the appropriate resolutlen of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATIONS:
Work Package closed out, indication that work performed was performed satisfactorily.
Retest will take credit for pre-start survelliance testing of components.
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ISSUE ANALYSIS ISSUE NUMllER: S3-5 ISSUE STATEMENT:
DET report and QA audit indicate prograrmnatic deficien& i L U;wrnting Experience Review Program (OERP) in the areas of timely huplementation of corrective action, quality of previous reviews, and excessive backlog of unreviewed items.
OBJECITVES OF TIIE ANALYSIS:
To assess the adequacy of plans to establish, to a reasonable degree of confidence, all high priority OER ltems have been adequately reviewed (prior to startup) and develop a bacalog elimination plan in cordunction with hnplementation of programmatic improvements.
APPROACII:
o This issue was assessed as part of Issue O-1.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the ksue Ls appropriately resolved on or before September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Refer to Issue 01.
ISSUE ANALYSIS ISSUE NUMBER: S3-6 ISSUE STATEMENT:
Twenty-two DCARs not msolved since August 1988. DCARs related to components whose QA classification was upgraded during MEL development. Items upgraded subsequent to
" finalization" of MEL also being addressed. Key issue is to differentiate MEL completeness :
questions from the original QA classification issues and assess operability concerns for upgraded components.
l OIUECTIVES OF TIIE ANALYSIS:
Evaluate the adequacy of MEL relative to our Generic Letter 83-28 commitments as it deals with QA classification upgrades.
APPROACII:
o This issue was assessed as part of Issue 02.
CONCLUSION:
The issue has been resolved..
Actions taken to date and planned for the future will msult in the appropriate resolution of this issue on or before September 26,1992.
X Additional actions should be taken to ensum that the issue' is appropriately resolved on or befom September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
1 JUSTIFICATION / RECOMMENDATION (S):
Refer to Issue 02.
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-1 ISSUE ANALYSIS.
ISSUE NUMBER: S3-7 ISSUC STATEMENT:-
. Review adequacy of NYPA readiness for restart self-assessment.
ORIECr1VES OF THE ANALYSIS:
To determine whether various_ tasks as presented to the NRC at public meeting June 12, 1992 are being appropriately undertaken..
APPROACII:-
o Reviewed the action plan for the Startup Readiness Evaluation (SURE).
o Participated in the SURE process.
CONCLUSION:
X The issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions -should be taken to ensure that the-issue is--
appropriately resolved on or befort September 2ti,1992.
Resolution of this issue before September 26,199? Is unlikely..
JUSTIFICATION / RECOMMENDATION (S):
~
This report represents the final document in the Readiness for Restart Self Aa*==ent.-
For important additional observations and conclusions regarding restart, see Issue 05,.
.Startup Milestone Schedule and Start-Up List.'
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ISSUE ANALYSIS ISSUE NUMBER: S3-8 ISSUE STATEMENT:
Indication of possible flaws in the Reactor Pressum Vessel (RPV) head were found during routine in-service cutage inspections during the 1990 refueling cutage. The ASME code requires reexamination during the next three refueling outages.
01UECTIVES OF TIIE ANALYSIS:
To determine if the results of the RPV NED evalu:efon were provided to the h%C staff for review prior to resuming reactor operation from t;>L refueling outa~ es.
API'ROACII:
TLis issue was assessed as part of Issue S-2.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
l Additional actions should be taken to ensum that the issue is appropriately msolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTII7 CATION /RECOhmiENDATION(S):
Refer to Issue S-2.
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ISSUE ANALYSIS ISSUE NUMBER: S3-9 ISSUE STATEMENT:
Resolution ofIIPCI and RCIC vacuum breaker containment isolation valve issue.
OIUECTIVES OF TIIE ANALYSIS:
Review the acceptability of the IIPCI and RCIC vacuum bmak ilne configuration.
APPROACII:
Interviewed Performance Engineering Supervisor and Plant Enghiecr to o
ascertain the punose and significance of this modification and their acceptance of work in process Detennine plan and status of RCIC whip restraint and final issue of o
SWEC report.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate msolution of this issue on or before September 26,1992.
Additional actions should be taken to ensum that the issue is appropriately msolved on or before September 26,1992.
Resolution of this issue befon September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Material is reported, by Plant Engineer, to be on site and is scheduled to be installed by September 4,1992; work will take only one day to install and will not hold up start-up.
SWEC's revised report of technleal justification which includes J AF's Ilcensing, site, and NED comments is expected on August 28, 1992 per conversation with Engineering Supervisor.
ISSUE ANALYSIS ISSUE NUMI1ER: S3-10 ISSUE STATEMENT:
Numerous technical issues addressed and commitments made at ATTS Enforcement Conference. Primary technical concerns relate to response time of selected channels, operating experience programmatic deficiencies, modification process programmatic deficiencies, and service life evaluations for non-EQ equipment.
011JECTIVES OF TIIE ANALYSIS:
To ensure that technical commitments made at the ATTS Enfonement Conference are identified, tracked and that those specified as pm-startup are completed prior to September 26,1992.
APPROACII:
This issue was evaluated as part of Issue E4.
CONCLUSION:
The issue has been resolved.
X Acticus taken to date and planned for the future will result in the appropriate msolution of this issue on or befom September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or befom September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Refer to issue E4.
ISSUL ANALYSIS ISSUE NUMBER: S3-11 ISSUE STATEMENT:
Safety Pump Rcom - Finalize QA Classification operabliity requirements for ventilation.
ORJECTIVES OF THE ANALYSIS:
To determine a) whether the status of the issue has changed, and M whether the projected completion dates appear rtasonable and am appropriate for stattap.
APPROACII:
Interviewed Technical Services Engineer and NED Engineer to determine status, o
scope and expected follow-up items.
o Reviewed June 26,1992 exemption request to NRC.
Interviewed Engineer from CCUE project and reviewed documents being o
prepared for component upgrade evaluation in accordance with EDP-31.
Reviewed list of system components being evaluated, to confhm all system o
components are included.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Exemption request submitted to the NRC UTM-92-032) on June 26,199211sts compensatory actions to be taken until final changes are implemented.
2-2 NED will provide fan operability now requirernents to Tech Services by Se,,ternber 11, 1992. Systen Engineer ludicates awareness that Surveillance Test is required to be prepared once now infortuation is available. Change from CAT 11/U1 to CAT 1 ev4uation is in prognss, and is exlx4
- to be cornpleted by Septernber 26,1992. (UE00005, UE004?
and UE00340) llic completion of Surveillance Test and Evaluation should be tracked.
CCUE group has been lufonned that fans for the servenwell area are to be reviewed for possible upgrade to CAT !. 'Ihis Itern is being listed and tracked by the CCUE group, but they are not being r.ddressed as part of this itern.
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ISSUE ANALYSIS ISSUE NUMilER: S3-12 (GL83-28 Audit Resolution)
ISSUE STATI211NT:
QA Audit Report Indicates numerous deficiencies in our disposition of Generic Letter 83 28.
OIUECTIVES OF TIIE ANALYSIS:
To assess the scope of the review process and the methods planned to identify and resolve potential startup problems stenuning from this issue.
APPROACII:
o Reviewed background documentation concerning JAF response to NRC GL 83 28, JPN-89-066, other SURE issues related to the QA classification process and the master equipment list (MEL), QA aud!t report 92-07, PSO 53, PSO 46, and the September 1,1992 draft mini audit " Assessment of the Implementation of JAF commitments to NRC Generic LeMer 83-28."
o Interviewed Director Licensing. BF7., J AF Technical Services Efanager, Systems Engineering Supervisor, Project Marugers assigned to the GL 83-28 mini-audit and the CCUE and SRFA projects, and other engineers and contractors involved in the review of the GL 83-28, to determine the extent of the reviews in process and the plans and actions being taken or developed to resolve this issue.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will rtsuit in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately itsolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
ne draft mini audit assessment reviewed the full scope of reconunendations from GL 83-28 and identified actions necessary for each of the four areas of concern:
1 i
2 Post Trip Reviews identIDed denciencies in PSO 53 assigmnent of responsibilities and authorization and o
implementation weaknesses in Root Cause Analysts and the use of Scram Review Assist Teams o
Identined the overload and data It,ss problems in the EPIC system, and the pending roodification to this computer system (rninor mods in process to add new SOE and post trip log signals and the system upgrade scheduled for 1993)
Fgilpment Clawincation and Vendor Interface Identified implementation weaknesses in PSO 46 (Control of Vendor Manuals) o particularly in I&C o
Identified the MEIJQA classlucation problems identified and reviewed in SURE issue 0-2 Post-Maintenance Testing o
Identined inconsistencies in the process for specifying PMT and testing all sa.ety actions affected by maintenance o
Identified a need for consistent addressing of repeated failures Reactor Trip System Reliability o
Identified conunitment to fix Tech Specs to include testing of back up scram valves (ST29E)
Eight of the corrective actions identitled and two additional recommendations, which addnss notifications to the NRC concerning the JAF response to GL 83-28, have been recommended as startup requirements. Comments on this draft are being reviewed by selected JAF and WPO manarement and a meeting with project personnel, licensing, and the Vice Pnsident of Nuclear Support is scheduled to finalize an action plan and assign responsibilities.
It is enticipated that upon resolution of comments, actions planned as a result of this report will result in appropriate resolution of this issue on or before September 26,1992.
ISSUE ANALYSIS ISSUE NUMilER: S3-13 ISSUE STATEMENT:
Determ!ne how many RTL auf be out of service for Toms Temperature Monitoring System before the system must be decland inoperable.
OIUlrI1VES OF TIIE ANALYSIS:
To ensure system operability thnits have been defined and modifications have becu completed.
APPROACII:
Interview responsible engineers, J AF 'culor I&C engineer and WPO Senior I&C o
engineer for verification of calcutation.
Verify suppression pool temperature alarm setpoint evaluation.
o o
Verify if design basis was reviewed by manufacturer.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result hi the appropriate resolution of this issue on or befort Septenf '26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resoluticn of this issue befort September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
In normal operating condition, none of the 16 resistance thermal devices (RTD's) are expected to be out of conunission.
l JAF Torus Temperature Monitoring System bulk pool temperature based on the Monticello l
NPP in-plant SRV test pool temperature data with and without pool circulation. It was I-determined some error is introduced by a non-uniform temperature distribution during SRV discharge of steam into the suppression pool with and without pool circulation.
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2 Meral Electric's analysis, DRF-T234681, determined Torus pool temperature error bued on the number of RTD's operable and pool thermal stratification. Results of this analysis art listed below:
Error in Bulk Torus Temperature ("F)
Case 1 Case 2 Case 3 Maximum Error ('F)
(No Pool Circulation) 0 RTD's Failed Neg.
4 6
6 1 RTD Failed 2
6 6
6 2 RTD's Failed 14 16 15 16 3 RTD's Failed 18 19 16 19 Error in Bulk Torus Temgmture (*F)
Case 1 Case 2 Case 3 Marimum Error ('F)
(With Pool Circulation) 0 RTD's Falled Neg.
Neg.
Neg.
Neg.
1 RTD Failed 1
0 Neg.
1 2 RTD's Failed 3
1 Neg.
3 3 RTD's Failed 5
2 5
5 NED/I&C has genersted a calculation based on the Genen! Electric data. Calculation JAF-CALC-PC-00379, Revision 1, has determined that a maximum of two RTD failurts per channel can be tolerated.
Currently, ST-40D Daily Surveillance and Instrument check, is a daily surveillance for SRV tallpipe temperature, while Torus bulk temperature surveillance fatquency is once a shift.
The increased surveillance of the SRV tallpipe temperature is a proactive measure by JAF to better monitor any uncontrolled heat additions which could exceed Tech Spec thnits.
., -, - -,, - - -.. - ~.,
ISSUE ANALYSIS ISSUE NUMllER S.%14 ISSUE STATEMENT:
'Ihe Emergency Service Water (ESW) now to the Energency Diesel Generators (EDG) cools the EDG engine jackets and is discharged to ESW pump bay A.
Ilecause of this recirculation of heated water to the ESW pump bay, the ESW supply temperature to the EDG's and the minimum safeguards equipment will be higher than the lake temperaturr.
OIUECI'IVES OF'IIIE ANALYSIS:
Verify completion of the modification to reroute the Emergency Diesel Generator (EDG)
Jacket cooling water common return lines 46 8"-WES-151 10 and 46-12"-WES-151-9 such that its now does not mix with the water in the Duergency Service Water (ESW) pump suction.
API'ROACll:
SURE Engineering Team reviewed this in detall as part of task E1, Modification completion.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
As part of SURE Engineering Issue El, this modification was reviewed in detall. Initial retest of the completed modification resulted in the identification of a need for orifices.
This modification is complete except for work epecified in ECN F192-068 022, which requires new resized orifices. These were scheduled for recclpt 8/26/92.
A retest is planned after completion of other Service Water modifications. At this time now balancing will be verined.
ISSUE ANALYSIS ISSUE NUMItER: S3-15 ISSUE STATF31ENT:
A design modification is required to enable operators, from the Control Room, to operate fhe independent power supplies and connect a maintenance bypass from another safety.
related emergency MCC in the same safety division to the LPCI trdect8er valve bus.
OlUIXT. IVES OF TIIE ANALYSIS:
To ensure that the modification has been installed and tested satisfactorily.
APPROACII:
o Interview Senior Engineer to determine the status of the action plan, o
Review background documentation and implementation plan.
e Review modification F1-92-305 package for famillarity.
CONCLUSION:
The issue has been resolved.
_ X.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriataly resolved ou or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
A review of Modification F191-305 LCPI Alternate Power Supply records showed the package to be complete for JAF Plant Review and JAF PORC rtriew. In addition, an installation package was issued and all material requisitioned bas been received on site.
Total work on 11-Side has been complete and 90% of all work bas been completed on the A-Side. The A-Side shall be totally complete when power is restored and a surveillance test '
to demonstrate operability is performed. Senior Supervising Engineering stated that MOD-91-305 is not required by Technical Specifications for startup. The same engineer expressed confidence that remaining testing will be completed without any problems prior to September 26,1992.
l i
ISSUE ANALYSIS ISSUE NUMllER: S316
]
l ISSUE STATEMINT:
As a result of the ESW SSFI and NRC DET inspection, approxhnately 200 issues have been identified as associated with ESW. Seventy-five (75) Issues are now identified as stanup.
He most significant are associated with ESW flow tt-sting, cooler thermal performance testing and inspection of plant intake piping. Several commitments to the NRC wem made which must be resolved prior to restan of the unit.
2 OltJECTIVPS OF111E ANALYSIS:
To ensure that action plans have been Identified for restart items and am progressing satisfactorily to meet a September 26,1992 startup.
APPROACII:
This issue was evaluated as part of Issue E 3.
o CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the futum will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this Lssue before September 26,1992 is unlikely.
JUSTIFICATION /RECOPSiENDATION(S):
Refer to issue E 3.
l
ISSUE ANALYSIS ISSUE NUMllER: S3 17 ISSUE STAT 131ENT:
Investigate various technical issues related to Control Room annunciator power cupply configurations.
OIUECTIVES OF TIIE ANALYSIS:
To determine whether the program to verify the annunciator system as a reliable operator aid is proceeding as scheduled.
APPROACII:
o Reviewed the issue status as described in JTS-92 0770, Tasks I through 5.
o Intervit:wed the NED electrical engineer responsible for this issue.
o (This issue was reviewed in conjunction with issue O-6, Control Room Deficiencies).
CONCLUSION:
1he issue has been resolved.
X Actions taken to date and planned for the futury will result in the appropriate resolution of this issue on or before September 26,1992.
Adriitional act'ons should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
This issue appears to be progrtssing well with no major problems and only a minor risk of affecting startup. Task I will be completed by September 23,1992. Task 2 will be completed by September 21,1991. Tasks 3 and 4 art completed. The review tvguired in Task 5 is approxhnately 50 percent complete and should be finished by September 11,1992.
There is a slight possibility, however, that an issue could arise, stemming from the remainder of the review, that would require a modification. At this time this appears unlikely, and no further issues are foreseen or expected. The status of this issue should be reviewed prior to startup to ensure that the remaining evaluation is completed and any emergent work is scheduled for completion by the startup date.
ISSUE ANALYSIS ISSUE NUMHER: S3 18 ISSUE STATEMENT:
Determine the EDG operability in the presence of a ground on the DC system. It was deterTnined that the EDG controls are ground sensitive.
Perfortn a review of the IIPCI/HCIC control circuits to detennine if a similar rituation exists.
OIUECTIVES OF TIIE A.NALYSLS:
Assess the effectiveness of actions taken to casure EDG, IIPCI, and RCIC operability is unaffected by DC system grounds.
APPROACII:
Discussed this issue with the design engineering department to ascertain if a o
proper evaluation was ' 2rfonned to determine the need for installing speed controllers in the IIPCI/RCIC DC power systems.
Discussed with the Project Engineer the status of the modification to detennine o
if the modl(1 cation which will install speed controllers will be completed by the September 26th startup date.
The portion of this issue concerning EDG operability was covered by Issue E5.
o CONCLUSION:
ne issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or befort September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992 Resolution of this issue befort September 26,1992 is unlikely.
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1 J USTII1CA110N/ RECOMMEND ATION(S):
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1he EDG operability issue was discussed in the engineering section, lasue E5.
Justification of the IIPCI/RCIC issue is as follows:
Discussed the evaluation and testing process for determining the vulnerubility of the RCIC and IIPCI speed control to ground faults with the supervisor of electrical design and concluded the determination to Install speed regulators is conservative.
Discussed with.the project engineer the status of safety evaluation and lastallation procedure. Althcagh neither have been issued to date the modification (MI 92-253) i is expected to be completed by September 26,1992.
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ISSUE A.NALYSIS ISSUE NUMllER: S3 19 ISSUE STATEMENT:
Secondary Contalmnent is rrquired to be analntained following a selsude event. There are nornelunic lines, e.g. the service water piping and temporary drywell cooling which penetrate secondary contalmuent without isolation provisions.
OIUECTIVES OF TIIE ANALYSIS:
Establish licensing basis requirrments for maintaining secondary containment. Secondary containment is required to perinit the operation of the Stand Ily Gas Treatment system to perform its design function.
API'ROACII:
Interview personnel associated with this issue to ascertain if the licensing basis requirements are ratisfied by documentation addressing this issue. Review docmnentation associated with thir issue to determine if the issue of se:ondary centainment design criteria has been adequately addressed. Determlue if there is any further action required on the issue.
CONCLUSION:
X The issue has been :tsolved.
Actions taken to date and planned for the future will result ha the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or beft,re September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFlCATION/ RECOMMENDATION (S):
Reviewed documentation written by the WPO licensing department which concluded that the fundamental design of secondary containment was adequately considerrd by the original design agents. Reviewed the meeting minutes between GE (NSSS Supplier) Stone and Webster Engineering Corp. (SWEC), the JAF Architect Engineer, and various NYPA
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-?-
r engineering personnel brought together to additse the resolution of this issue. Based on the review of these sninutes concluded that the issue was closed. Discussed the status of this issue with Vice President of Nuclear Support and confinned that this issue was resolved by the discussions held at the above snecting. Discussed the !ssue with JAF system supervisor and he concurred this issue was resolved at the aforernentioned meeting.
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i ISSUE ANALYSIS t
ISSUE NUMilER: S3-20 ISSUE STATEMENT:
Evaluation of ACCUs has concluded existing equipment is inoperable.
OBJECTIVES OF'I1IE ANALYSIS:
Determine if program plan referenced below has demonstrated operability of equipment to
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support sta: Tup.
APPROACII:
o Review program plan listed in JSEM 92-037.
I o
Interview SED Plant Engineer, Senior Nuclear Project Engineer and other personnel as applicable, Using plant wide computer system review status of action items (ACTS). -
o Interykw Operations Department procedure writar.
o CONCLUSION:
'Ihe issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriah resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue 'Is appropriately resolved on or bef.sre September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
JUST1F1 CATION / RECOMMENDATION (S):
Justification to remove LPCI invetiers from the EQ I>rogram was performed in accordance with EDP-20 per SED Plant Engineer. Interviewed Operation Depar' ment IYocedure writer.
and was assured that OP-43C and other applicable ops will be updated to meet the startup date. Modification F1-92-273 will remove enviror wental enclosures and associated ACCUs from plant. -
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ISSUE ANALYSIS ISSUE NUMilER: S3-21 ISSUE STATEMI'NT:
Impections that were performed under the JAF Pipe Support Program on the Recirculation System supports deterTalned that a load bearine snacer olate may have been overstressed.
Stone and Webster Engineering Corp. (SWEC) performed operability evaluations for the supports and determined that 12 supports (8 spring hangers and 4 snubber supports) were potentially inoperable and 6 supports (spring bangers) were operable, but not acceptable to meet the design code requirements.
OBJECTIVES OF TIIE ANALYSIS:
Access the effectiveness of plans and actions to restore the Recirculation System pipe supports to acceptability by operability meeting all appilcable design code requirements.
All modification work will be performed in accordance with the requirements of plant modification F1-84-091 (Pipe Support Program).
APPROACII:
o Review documentation n'mlated with the modification package. ' nits includes review of the Installation procedures and modification design drawings. This also hicludes a review of the original GE Recirculation System design drawings ta ensure no other supports use the load bearing spacer plate design.
CONCLUSION:
The issue has I" en resolved.
X Actions taken to date and plarmed for the future will result hi the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or befort September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
l An L 'erview was performed with the responsible engineer for this modification and the WPO contact with GE. Both persons agreed on the status described below.
2-o A total of 18 pipe supports twiuirrd modification based on SWEC analysis. All inopenible spring hangers (IIA-3,113 3, IIA-7, IIIb7, IIA-5,1111-5, IIA-6 and lilL6) are to be restored to acceptability of meeting the plant unique design criteria. Eight hangers were field modified (4 snubbers and 4 spring hangers) and are complete and QC accepted. Four remaining spring hangers have been deterrnined to be both operable and acceptable and arr within code design requirrments as evaluated by General Electric. General Electric will supply a technical report supporting this conclusion by the second week in September,
'Ihe six supports (18 minus 12) determined to be operable but not meeting design code o
requirements are undergoing further analysis by GE. SWEC has issued engineering work packages for these supports, however work is being postponed until GE final analysis is complete. We expect GE will find these six supports acceptable without further hardwa.c modification, o
Interviewed the site responsible engineers and the WPO design engineers to ascertain the status of the modification and likelihood of meeting the designated startup date.
o Interview the ISI engineer to determine the impact of this modification and ascertain the status of action required by this raodilication.
o All expected hardwart changes on the recirculation system (8 pipe supports) are
- complete, o
'Ihe final engineering package from GE should be on site by September 15,1992.
o Drawing updates reflecting the new support /csigns will be performed within the permitted 60-day schedule.
o Review of all GE load bearing spacer plate designs has been completed.
o
'Ihe ISI engineer will have the rechtulation system pipe stresses re-analyzed including the weight affects of weld overlay repairs. This activity will be performed with in the i
90 days of startup as perinitted by the hTC.
At this time it appears that the planned action items will resolve this issue by o
September 26,1992 however the responsible engineer should confinn that the General Electric analysis which supposis the operability of unchanged pipe hangers is acceptable. In addition the ISI engineer is required to accept the final Rechrulation System pipe stress reanalysis.
I 1
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ISSUE ANALYSIS I
ISSUE NUMilER: S3-22 ISSUE STATI31ENT:
Undefined responsib111tles for the ISI test program have led to some pressure tests not belog perfonned.
OIUECTIVES OF TIIE ANALYSIS:
Assess the effectiveness of actions taken to develop an Action Plan to implement a formal ISI pressure test program prior to startup. Implernent pressure tests for SLC and CRD system per RAP-92-161 prior to startup.
APPROACII:
o Review documentation associated with the pressure test program root causes and proposed solution to detennine the adequacy of the action plan.
Interview personnel associated with developing and implementing the action o
plan to determine if the methodology used in developing the plan was correct, and if the plan's corrective action will be perfonned by the September 26 startup date.
o Interview the ISI engineer and the Maintenance Department NDE speci.nlist to discuss the methodology used to develop solutions for the action plan.
o Interview Operations' personnel responsible for performing system surveillance tests and implementing the solutions to the action plan.
o Interview QA to determine if the corrective action presented in the action plan is acceptable.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned foi the future will result in the appropriate resolution of this issue on or befort September 26, 1992.
Additional actions should be taken to ensure that the issue is l
L appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
I l
2 JUSTil1 CATION ECOMMITDATION(S):
Discusslotts with the ISI engineer ascertained that the PSO-3111, which defined the administrative controls for the PTPs, will be completed prior to startup. The only outstanding issue with this procedure is the plant has yet to identify the site ISI engineer who will be responsible for signing off on pressure tests. This open issue is expected to be resolved prior to startup.
Discussion with ISI engineer and NDE specialist demonstrated a pnadent approach to determining what additional sections of systems requiring pressure tests wert missed.
'Ihc 1S1-131 drawings (system pressure boundary drawing) were compared against the ISI Section XI pressure boundary drawings. The ISI I%is were then forwarded to Operations for cornparison against existing survelliance test pressure boundarles. 'nds audit should ensure all areas requiring pressure test are captured.
They also explained the process of updating these control drawings, which scents to be an acceptable rnethod of efficiently rnaking changes and updating drawings.
Discussed with the Operations Department's Testing Coordinator the methodology for updating control red-line drawings and confirmed the process put in place is acceptable.
Discussed with Operations Department Prccedure Writer Specialist the status of the Operations Department Standing Order (ODSO) to control the tasks and responsibilities assigned to the Operations Department. Operations is scheduled to cornplete this ODSO by November,1992.
QA was interviewed to ensure their agreement with the action plan to identify programmatic responsibility for the PTP.
Required pressure tests w!d be perfortned prior to startup in accordance with the
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tranmtittal letter RAP-Site dated August 27,1992.
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ISSUE ANALYSIS ISSUE NUhfIlER: S3 23 ISSUE STA'ITMlWT:
Assessment of dual function prhnary containment isolation valves per JSEM 92 010.
hiod10 cation of IIPCI and RCIC torus suction valves trquired prior to startup.
hiodilication to the ECCS outboard injection isolation valve circuitry which permits rtmote manual operation is required prior to startup.
OBJECI1VES OF TIIE ANALYSIS:
Assess actions taken to ensure the operation of all affected valves comply with the original design basis rrquirements prior to startup.
APPROACIL o
Reviewed the documentation which discussed the selection of dual function isolation valves which may not comply with the requirement of remote manual operation to detennine if an adequate review was performed.
o Discussed with the System Engineers the basis for determining which containment isolation valves will require chruitry modification to pennit remote manual isolation.
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Discussions were held with the hianager of Project Engineering to determine the status of modifications required to change valve operating logic to comply with regulatory requirements for containment isolation.
o Discusslous were held with Site Planners to assess if the proposed modifications l
will be Installed prior to the September 26 startup date.
CONCLUSION:
The issue has been resolved.
l X
Actions taken to c'ete and planned for the future will result in the l
appropriate resolutlor. of this issue on or before September 26,1992, t
Additional actions should be taken to ensure that the issue is appmpriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely, i
2-J USTIFICATION/RECOMhiENDATION(S)r Technical Services Engineering hiemorandum JSEhi.92-061 requested changes to the motor-operated valves in the ECCS Systems (ResidualIIcat Removal, Core Spray, IIPCI) and the RCIC systerns.
These changes would permit remote manual operation of containment isolation valves.
Reviewed System Engineering documentation which performed the programmatic assessment of all containment isolation valves to detennine which valves did not comply with regulatory requirements for remote operation.
Detemilned their trview was comprehensive because it assessed every containment isolation valve listed in 7.31 in the IEAR.
Discussed with the hianager of Project Engineering the status of modifications knplemented to have valves, identified by System Engineers, modified to penuit remote manual operations. 'Ihe status of modifications arv as followst 1) legic to the R11R LPCI hdection valves was corrected by un Appendix l' modlucation which added a bypass switch to the
(.ontrol room cirruits which will permit valve closure with an ECCS signal present. hiodlucation F192-111 is complete.
2) hiodifications to the IIPCI and RCIC torus suction valves are in progress hil-92-214. 'Ihe Installation Procedure was approved by PORC on September 11,1992 and completion of this modification should meet the September 26 startup date.
3) hiodification h11-92-214, Rev.1, will change the Core Spray outboard containment isolatlea valve to permit closing the valve during the ECCS signal. A bypass switch will be added to each contahunent spray outboard IqJection valve control chruit which can bypass the ECCS signal if required.
The lastallation procedures and safety evaluation have not been issued to PORC as of September 14,1992.
Discussed this issue (M1-92-214 RI) with the Director of Licensing to determine if performing this modification was an operability or startup issue. Ihnsing concluded that the currrnt containment valve configuration satisfies the lleensbig basis for the plant without modincation. Ilowever work is continuing on modification M1-92-224 R1 but there is a high probability that this modification will not be completed prior to Sepember 26, 1992.
3 It is recogninended that a decision be inade soon to either expedite activities necessary to complete the modification by September 26 or postpone further work on this ruodification until the next outage. If work is postponed, a safety evaluation will be required to change the 15 AR to exclude the abillty to remotely shut the subject isolation valve during an ECCS signal.
ISSUE ANALYSIS ISSUE NUMilER S3 24 ISSUE STATEMIWT:
A through review of contalument penetrations has not been perfonned since 1974, there is a possibility that some penetrations that regulres testing have not been tested properly.
011JECFIVES OF TIIE ANALYSIS:
To detennine lf primary containment has met the requirements of Appendix J.
API'ROACils o
Interview lead Performance Engineer of Technical Services Department.
o Review performance engineering memorandum - Special-Appendix J List.
o Review AC'IS list to account for referenced ACT ltems.
o Review status of DEM.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be takeu to ensure that the Issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 b unlikely.
JUSTIFICATION / RECOMMENDATION (S):
'Dirce different Operating Experience Review (OER) pointed out the need to perform containment penetration walkdowns to verify the J AF containment testing program listed in 10CFR50 Appendix J. Action Item (ACTS) 4133 (completed) was issued to complete walkdown prior to startup.
Modification Dl.92-261 Seal Welding and Threaded Connections was issued August 25, 1992, to seal weld pipe plugs to maintain containment integrity as reported by Tecimical Services Department senior project engineer.
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ACTS Itern 4831 Valve and Cap Position verification has been assigned to Tedinical Services to develop u list by July 31,1992. PerTonnance Engineering hiemorandum JPEM-92-025 was trJected as being too encompassing and has been rrwritten. ACRS Item 4832 is assigned to the Operations Department to incorporate Valve and Cap Position Verification, identified by Technical Services perfonnance engineering group to applicable OP procedures. For Valve and Cap positions that cannot be identified to a particular OP, it has been reconunended by Technical Services Lead Perfonnance Engineer that they be added to the appropriate surveillance test procedure.
Modification Dl 92-261 Seal Welding and Cap position verification arr in progress and are not expected to linpact scheduled startup.
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ISSUE ANALYSIS ISSUE NUMilER: S3-15 ISSUE STATF31ENT:
NRCN 92-35 Identined an erosion / corrosion concern at Susquchanna la their feedwater piping that has generic implications to JAF.
OlUECTIVES OF TIIE ANALYSIS:
Detennine applicability to JAF and review action taken on NRCN 92-35.
APPROACII:
Interview ISI Engineer to determine what actions were completed.
Review OER 92030 for resolution of referenced NRCN 92-35.
CONCLUSION:
X
'Ihe issue has been resolved.
Actions taken to date and planned for the futurt will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately rrsolved on or before September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Received from Plant Engineer OER 92030, memorandum RAP-92-167, meeting no'es/ agenda Susquenhanna/NRC hiny 28,1992.
Memo RAP-92-167 from Senior Nuclear Engineer recommends that a inspection be performed on Feedwater nozzle during the next scheduled refueling outage. JAPs Planning Department will add the activity to the refuel outage activity list per OER 92030.
l
ISSUE ANALYSIS ISSUE NUMBER: S3-26 ISSUE STATEh!ENT:
Potential operability problem due to possible failures of SBM switches itsulting from fracture in LEXAN cam follower. The cam follower failure can in turn causejamming of the switch mechanism, or failure of switch contracts to open and/or close. This issue surfaced during the closed Operating F2perience liem review regarding GE SIL 155 (1976) and its two supplements. In addition, JAF found two faulty SBM switches with broken cam followers during huplementation of a recent circulating water system modification.
OBJECTIVES OF TIIE ANALYSIS:
Confirm that plant personnel have ascertained the number, application, location and condition of SBM switches at JAF and determined whether replacement will be necessary.
It is known that the switches are used extensively in all safety-related systems as well as in other major systems (e.g. Chr. Water) throughout the plant.
APPROACil:
Interview Technical Services personnel. Review the documentation including hispections, reports and proposed plans.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
The physical inspection Inforination has been gathered to allow evaluation and selection of two switches for cycle testing to assess degradation to date.
Documentation of Inspected switches was sent to NED. Technical Services has requested NED to perform classification and documentation of number of switches for each configuration. NED has determined manpower and thne to complete the initial part of this task and has scheduled personnel to suppcrt the task.
Only three nplacement switches have been ordend.
Existing Action Plan calls for replacement of two switches for testing and one switch for cornetive action. Testing j
proceduns are being written, and post nplacement testing will be required.
Evaluation plan says:
$1f any of the two switches falls the cycle testing TilEN laspect and nplace all cracked QA Cat I and M switches lastalled at JAF. " (Post Startup)-
Ordering of additional replacement switches cannot start until manufacturer ID numbers and classifications for replacement switches art detertained.
l Inspection of received switches at the warehouse on 8/27/92 indicated a discrepancy in at least one switch (single stage instead of two stage as installed in pla 4). '1his ladicates a potential' configuration /part number problem which has to be nsolved. Problem identlEas a need to nquire pre-testing of each switch prior to installation la panels,~ to confirm proper configuration.
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ISSUE ANALYSIS ISSUE NUMIIER:
S3-27 ISSUE STATEMENT:
Potential Operability problem due to misinstallation ofIIGA relay covers was discovered during OER Backlog Elhnination (Issue S3-5), which could cause bluding of the relay arulature and prevent perforniance of safety related Category I functions.
OllJECTIVES OF TIIE ANALYSIS:
Verify relays have been located and inspceted for proper cover orientation, covers marked to ladicate proper orientation and inspections complete. Covers will be reoriented if required.
APPROACII:
Contacted Technical Services personnel which discovered OER backlog item and tracked r-solution.
Contacted Technical Services and I & C personnel to confinn review of Inspection work and results. Reviewed documentation of Inspections performed.
Reviewed letter from Fred Welnert justifying lack of covers on 20 relays located within seismic enclosures. Reviewed updated list of all relays to be turned over from I & C to Technical Services for entry into MEL and classification.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or befort September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately res9lved on or before September 26,1992 Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
WR for identifying relays was completed by Technical Services. I&C WR #10949 for luspection, marking, and reorientation of covers, where required, was reviewed and is la process of being signed out, as complete. Determination of need for retest will be made during sign-off.
I ISSUE ANALYSIS ISSUE NUMBER: S3-28 ISSUE STATEMENT:
Reactor Water 12: vel Instrumentation susceptibility to depressurization events and potential inaccuracy (high readings).
OlUECHVES OF ANALYSIS:
Determine:
a) whether status of issue shown in J13-92-0770 has changed, and b) whether the projected completion dates appear reasonable and art appropriate for startup.
APMtOAC11:
Interviewed J AF Systems Engineer to determine work scope and status of Individualitems as shown in Major Technical Task list, issue No. 28.
Reviewed System Engineer wparts JSEM 92-070 and draft JSEM-92-074. Reviewed hanger and piping changes with Isugineering. Reviewed NRC Information Notice and NRC Generic Le'ter 92-04.
CONCLUSION:
The issue has bet.n resolved.
_X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
NRC GI 92-04 requires a response by 9/27/92, and determination of potentialshort-terin and long-term actions.
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i 2-The IlWROG o nmittee fonned for this issue is meeting during September to discuss this issue. It could result in additional changes which would be required prior to stadup. Site Engineering has been told of the need to evaluate the discrepancies and initiate modifications for changes required prior to startup, in accordance with draft JSEM-92-074.
Engineering has started the changes required for piping hanger modifications. Engineering believes material is available and hstallation would not impact September 26,1992 startup date.
Engineering has started investigating po'ent'al piping changes. Engineering indicates piping changes would impact the proposed stadup date.
Final issue and interpretation of EPRI testing itsults will determine the rnagnitude of work required.to be perfonned. Assessment cannot be made until testing and evaluation is complete.
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.a ISSUE ANALYSIS.
- ISSUE NUMBli': S3-29.
ISSUE STATEMENT:-
De MEL Q-List was incornet ngarding the QA classiflestion of Safety Pump Room ventilation fam. NRC Inspection 91-20 stated concerns rLJ.ing the adequacy of the GE -
Safety-Related Functional Assessment used to generate,the procedures (MELP-9 and,'
subsequently MCM-6A) that are used to classify components at JAF. _ [ Refer to Issued No.
11.]
OBJECTIVES OF'IIIE ANALYSIS:
Evaluate the adequacy of the process used to validate the SRFA and the documents used to establish the JAF MEL Q-List.
APPROACH:
%1s issue was evaluated as part of Issue 02.
CONCLUSION:.
He issue has been resolved.
Actions taken to 'date and planned for the futum will recalt in the -
appropriate msolution of this issue on or befon September 26,1992.
X Additional actions'should bet taken <to ensum that the issue is appropriately resolved on or before September 26,1992~-
Resolution of this issue befon Septest.Ler 26,1992 is unlikely.
JUSTIFICATION / RECOMMENDATION (S):
Refer to Issue 02.
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ISSUE ANALYSIS ISSUE NUMBI2: S3-30 ISSUE STATEMENT:
Recent blowdown testing performed on a 6" Anchor / Darling (A/D) double disc gate Indicates that valve friction factors at flow isolation (friction factor) are greater than used for MOV design at FitzPatrick (0.37. from test results vs. 0.2 from A/D design documents).
This means that A/D double disc gate valves which are required to close under high energy line break (HELB) 110w may not fully close. NYPA lettar JPN-92-035 committed to " assess" effect of thme test results. NRC letter of July 30, 1992 expects NYPA to resolve the
., a valve disc friction factors prior to startup. Operability under design conch bas's lic.d ins of the following MOV's may be effected: 12MOV-15,12MOV-18, T
OV F
-15.
br 4 THE ANALYSIS:
Dett ase of action to co-rct/ assure operability of above MOV's under design basis II:n flow conditions will ensure completion by 9/26/92.
APPROACII:
Intenlew of Technical Services personnel to determine present status of proposed changes.
Interview of Maintenance personnel to determine status of changes and other proposed actions. Review of documents, including NRC letter of 7/30/92,12/12/90 Safety Assessment of Isolation function of various MOV's and 8/21/92 memo from Rad Converse.
Intervie.nd Licensing personnel to verify their concurrence with plans and actions related to this issue.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future v'ill result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the Lssue is appropriately resolved on or before September 26,1992.
Resolution of this issue x September 26,1992 is unlikely.
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- JUSTIFICATION / RECOMMENDATIONS:
Maintenance Indicated material was not available on-site to perform an upgrade of alllisted MOV's. NRC letter of 7/30/92 requires resolution of item prior to startup from 1992 refueling outage.
Sluce not all four valves listed have been completely upgraded, a revision to the safety assessment will be prepared by the Maintenence Department.
If the revised safety assessment (operability assessment) is not satisfactory, Site Engineering will have to evaluate a potential modification (torque switch bypass). The valve manufacturer must be contacted for determination of valve disc stress limit capability.
Site Engineering must be informed of potential modification required, and need to contact valve manufacturer for technical input and analysis. Licensing should be contacted for concurrence with the planned Safety Assessment to satisfy NRC requirement.
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2-JUSTIFICATION / RECOMMENDATION (S): -
1.
There are 57 QA findings identified by AQCR# on the ACTS stanup list. A sampling of approximately 70% of all identified QA findings on the stadup list was assessed to determine their status. This review shows that the QA findings reviewed are cu Tently in various stages of implementation. The schedole for resolving these findings shows that these items have a completion date before the September 26, 1992 startup date.
2.
Additional QA findings have been " identified" by this assessment that should undergo closer scrutiny as to their startup significance. The criteria of G.L. 91-18 were employed to develop this list. These items are listed below:
AOCR #
AOCR #
WPO Findines92-073 92-036 9147-02 92-174 92-106 90-06-02 90-095 91-002 92-185 88-031 92-203 92-268 92-221 92-269 92-102 92-150 91-004 3.
Criteria should be established for the evaluation of startup operability isnies related to component, system, and related systems.
NOTE: A follow-up review of this issue was undertaken by the JAF staff.
This follow-up review resulted in one AQCR (91-1t16) being added to the list for further review.
All others have or are being satisfactorily addressed.
ISSUE ANALYSIS
-ISSUE NUMBER: S-4 ISSUE STATEMENT:
' QA Effectiveness / Audit Finding Status: A review of ottanding QA audit findings should be undedaken to determine which ones could potentially affect stadup activities.
OBJECTIVE OF TIIE ANALYSIS:
To identify open QA audit findings which could impact startup activities or dates, and assess the effectiveness of the QA audit process.
APPROACH:
o Review a sampling of unresolved /open QA audit findings.
o Review GL 91-18 criteria for operability determinations and use these criteria to review 1991-1992 QA audit findings to identify potential operability concerns.
o Identify QA findings with potential startup implications.
o Interview QA Manager, General Manager-Adminktration, and the Maintenance Manager to detennine the process used for prioritizing, communicating and assigning actions on QA findings.
o Determine whether QA audit findings are integrated into the ACTS system and the -
JAF startup list.
CONCLUSION:
The issue has been resolved.
X Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is appropriately-resolved on or befort September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
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JUSTIFICATION / RECOMMENDATION (S):
The review of the process being used to reconunend and afHrm closure of the sttrtup DEOs provided a high degree of assurance that those issues are being track.ed carefuty and that necessary actions have been completed prior to accepting closure. The sample of the closed packages further confirmed this. Although written criteria for closu' am not specified, the closure process requires joint review by the PLT and consensus f closure.
Interviews with several department managers indicated the importance they had placed on completing all actions necessary to close their assigned DEOs and that effective plans were in place to address the nmaining items. As of August 26,1992,14 startup DEOs had been closed by the PLT, nine more were scheduled to be closed by the PLT at the August 27 meeting, six additional DEOs had recently been agreed to be closed by the NRC which were being added to the August 27 meeting for closure. Fourteen of the remaining 17 startup DEOs are in the process of completing documentation and being forwarded for closum.
The remaining issues art being actively pursued and are scheduled to be completed prior to September 26,1992; however, the following issues need more attention:
ACTS 3831 (OPS Procedure Upgrade): Has a request pending to extend the due date for a portion of this reautrement ACTS 3829 (Nulsance Alarm Logging): The planned change to the EPIC system will not be donc prior to startup, so we are now contemplating closure based on reduction of control room deficiencies (the same basis is planned for closing ACTS 4668)
ACTS 3828 (Improved IIousekeeping): Needs work ACTS 4657 (Parts Stored Outside): No change ACTS 3838 (Decrease Large Work Order Backlog): Large amounts of work were completed, but emergent work has kept the backlog high.
The DEOs submitted for closure require follow-up to ensure that any rejections by the PLT for additional infonnation are carried out in a timely manner.
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ISSUE ANALYSIS ISSUE NUMBER: S-5 ISSUE STATEMENT:
DEOs: There are 46 open DEOs tracked as startup issues, of which 35 are still open as of July 20,1992. 'niey encompass numerous site groups. Supporting documentation for this isnies includes FAP No.1.
OBJECI'IVES OF TIIE ANALYSIS:
To ensure that actions necessary to satisfactorily close the DEOs selected by the NRC as required for startup are completed by September 26,1992 APPROACII:
o Interviewed Manager of ORG/ Licensing to verify that the startup DEOs were mutually identified by both the NRC and JAF, actions are tracked, criteria for closure are defined, and that the startup DEOs are segregated within the ACTS system o
Reviewed the startup DEO list (46) and assessed the adequacy of closure documentation. This assessment consisted of a detalled review of a s uple of the closure packages. Four packages (ACTS Items 3869,3846,3864 which closed via 2449, and 4661) were randomly selected from the 14 closed item packages.
One attempted closure that was rejected and resubmitted after ad iressing related activities recommended by the Plant Leadership Team (PLT) was also reviewed.
o Interviews were conducted with managers (or designees) of Maintenance, Technical Services, and Operations to further assess the effectiveness of their plans to close tnose startup DEOs which were still in process CONCLUSION:
The issue has been resolved.
Actions taken to date and planned for the future will result in the appropriate resolution of this issue on or before September 26,1992.
Additional actions should be taken to ensure that the issue is X
appropriately resolved on or before September 26,1992.
Resolution of this issue before September 26,1992 is unlikely.
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