ML20117F789
| ML20117F789 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 05/03/1985 |
| From: | Tucker H DUKE POWER CO. |
| To: | Adensam E, Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8505130321 | |
| Download: ML20117F789 (39) | |
Text
en f
DUKE POWER GOMIRNY P.O. HOX 03180 CliAHLOTTE, N.C. 28242 HAL B. TUCKER g
. r2.S"E"=
May 3, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Ms. E. G. Adensam, Chief Licensing Branch No. 4
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370
Dear Mr. Denton:
By letter dated March 1, 1985, NRC transmitted the Detailed Control Room Design Review Supplemental Safety Evaluation Report #2 for McGuire Nuclear Station, NRC requested that Duke address the implementation schedule and HED M-1-0152.
The detailed responses to both of these items are provided in the attached.
With respect to implementation schedule. Duke has provided a substantial dis-cussion of the factors utilized in developing the Duke HED implementation plan.
Consideration of such factors is essential to the development of an effective integrated operating plan and to facilitate the proper perspective of individual components of the plan.
If the discussions provided herein are insufficient to resolve this item, Duke would be pleased to host a visit by NRC staff (and con-sultants) to observe first hand the activities involved at Duke In the area of
- ' HED modification implementation. Duke initiated activities in the detailed Control Room Design Review effort one-year prior to NRC issuance of Generic Letter 82-33.
The summary report of the results of this review was submitted within approximately 14 months of the issuance of this Generic Letter. Throughout this entire effort, Duke has been aggressive in completing the identified gji.activitieswithinreasonabletimeperiods. To our knowledge, no other utility
' is as far along in completion of these activities as is Duke. Duke requests that NRC consider the total period of time from the initiation of the_ review to the completion of all HED modifications in evaluating the acceptability of the Duke implementation plan. We also request that NRC consider other plant modifi-cations already planned as well as the plant modification process itself. As indicated in the information provided in the attached, the modification process itself is an extremely complex process and bears heavily on the number of modificationn that can be processed prior to a refueling outage.
With respect to HED M-1-0152, additional information is provided in the attached.
Duke considers that the recommendation to leave the item "as-is" remains valid.
Unless the staff directs otherwise, Duke does not plan to implement any change in this instance.
[I 8505130321 850503 PDR ADOCK 05000369 E
PDR l
7 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation May 3, 1985 Page Very truly yours, C bb Hal B. Tucker RLG/mjf Attachments cc:
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 Mr. W. T. Orders NRC Resident Inspector McGuire Nuclear Station Mr. Darl Hood Division of Licensing Office of Nuclear Reactor Regulation U. S. Regulatory Commission Washington, D. C. 20555
j DUKE POWER COMPANY MCGUIRE NUCLEAR STATION i
Response to Control Room Design Review Supplemental SER #1 h.
NRC Letter Dated March 1, 1985 1.
INTRODUCTION The'following discussions are provided to NRC as additional information in
. support of the Duke plan for implementation of HED's identified during the detailed Control Room Design Review (CRDR). As a bit of history, Table 1 is provided to show the milestones that had been accomplished by Duke on McGuire in this effort.
It is noted that Duke efforts started well before NRC issued Generic Letter 82-33, Supplement I to NUREG-0737.
At present, there are two open items with respect to McGuire CRDR. The first is associated with HED M-1-0152; the second is associated with the Duke planned implementation schedule. Both of these will be discussed in later sections of this report. However, the following comments are provided regarding NRC suggested implementation schedule.
s 1
Following the TMI event in 1979, licensees were required to implement numerous plant modifications on expedited schedules to meet arbitrarily imposed deadlines. At the time, the impact of this was not appreciated.
However, by the time Generic Letter 82-33 was issued, NRC had recognized there was need to consider plant unique situations in establishing schedules. NRC states in the Generic Letter:
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4 Based on discussions with licensees, the staff has learned that many of the Commission approved schedules for emergency response facilities probably will not be met.
In-recognition of this fact and the difficulty of implementing generic deadlines, plant-specific schedules will be established which take into account the unique status of each plant.
With this statement, NRC had taken a major step away from establishing arbitrary completion dates and towards: realistic, flexible implementation schedules taking into account plant specific factors.
In the issue at hand, and contrary to the.above, NRC is reversing itself and essentially requiring the implementation of all HED modifications by the completion of the 1986 refueling outages of each McGuire unit.
Further, in order for Duke, or any licensee for that matter, to extend the implementation schedule beyond the NRC suggested completion date, rigorous justifications are required. It is noted that this requirement for extensive justification is derived from Standard Review Plan Section 18.1 which is beyond the original requirements of NUREG-0737, Supplement 1; is prepared solely as guidance to NRC staff; and was issued well after Duke provided the HED implementation schedule (March 1984) and initiated o
Control Room modifications on McGuire 1 (Feb-May 1984). Duke strongly feels that the NRC plan overestimates-the overall safety significance of f
each HED and underestimates the effort and flexibility needed by licensees to effect modifications on a timely basis. The Duke plan places both of these areas in proper perspective and is wholly responsive to the NRC statement in Generic Letter 82-33.
Additional detailed discussion of the implementation plan-is covered in Section 3 of this report.
i e
2.
DISCUSSION OF HED M-1-0152
.NRC staff does not agree with Duke's recommendation regarding HED-M-1-0152.
For convenience the complete concern is repeated as well as the Duke response.
TER, page 2, Item 2 HEDs Proposed to be left Uncorrected For the 10 HEDs that Duke Power has provided further justification or clarification-to leave uncorrected, we (NRC) conclude that Dake's justi-fications for the following nine HEDs are satisfactory:
HED N3.
-M-1-0028 M-1-0269B M-1-0038 M-1-0563 M-1-0118 M-1-0654 TER, pages 24-26 M-1-0159 M-1-0669 Section 3 M-1-0268 Duke's justification for leaving HED No. I M-1-0152 uncorrected is unsatisfactory for the following reasons:
HED no. M-1-0152: The justification for not correcting this HED is L
discussed in two places in the Duke Power Company response. Contradictory l
j
. justifications are presented for use of key-operated switches by Duke.
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The staff does not agree with the justification presented by Duke Power which leaves the Pressurizer PORV as a key-operated switch for the following reasons:
1.
The Westinghouse Owners Group generic studies show a time-dependent reliance on the pressurizer PORV to mitigate a SGTR.
In addition, 3
b
the pressurizer PORV which provides low temperature overpressure protection may be required on a timely basis in forced shutdown situations as documented in McGuire's FSAR and its Supplements.
2.
No protection is required for security reasons (See NUREG-0700, Guideline 6.4.4.3.a).
3.
Key-operated switches should not be used solely as a means of shape coding (See NUREG-0700, Guideline 6.4.4.3.1).
Duke Response:
HED M-1-0152 concerns several keylock switches which are being replaced by non-keylock switches. This KED resulted from the Operating Experience Review. Operators were concerned with the inconvenience of using keylock switches when these switches are under the Operator's direct control and no security is needed for protection from use by unauthorized personnel.
In solving this HED, the Review Team reviewed all keylock switches in the control room that are under the operator's direct control and proposed to replace all but three of these switches with non-keylock switches. This replacement is consistent with NUREG-0700 guidelines which state in 6.4.4.3a "if key-operated controls cannot be justified in terms of security, they are probably not necessary and should not be used".
Justification for the three switches proposed not to be replaced was included under Appendix C, HEDs Not Corrected,the Duke DCRDR response (page C.4, Section 3.4, Response to Supplement 1, NUREG-0737).
Justification 2 concerns the switch in question. This switch is the 4
mode selector switch for selecting the operating mode and setpoint for the Pressurizer Power Operated Relief Valves (PORV).
This switch is placed in the " low pressure" mode during plant startup and shutdown, and provides a low pressure setpoint, interlocked with reactor coolant temperature, to actuate the PORVs. The protection provided in the low pressure mode is for periods of water solid operation. The PORV low pressure setpoint is enabled by the operator as plant conditions dictate during startup and shutdown.
As RCS temperature approaches the temperature setpoint during plant cooldown but before collapse of the pressurizer steam bubble, an annunciator alerts the operator that plant conditions require low temperature overpressure protection. The operator places each key-lock switch to the LOW PRESSURE position to enable the PORV low pressure setpoint.
When system temperature rises above the temperature setpoint during plant heatup, the RCS Overpressure Protection System is automatically disarmed, and an annunciator alerts the operator that low temperature overpressure protection is no longer required. The operator then returns each key-lock awitch to the NORMAL position.
While the operation of this switch is dependent upon plant conditions, its use is not a time critical, fast response operation.
5
r The Pressurizer PORV control switches, as well as the Pressurizer PORV Block Valve control switches, are not keylock switches and are always immediately available'for operator use. These switches are used to mitigate an SGTR as shown in the Westinghouse Owners Group generic task analysis (tasks E30.3 and E40.3). There is no reliance upon the mode selector switch in this event.
The Review Team concluded that it was not cost-effective nor did it provide any particular benefit to replace this switch for the following reasons:
(1) the mode selector switch is not used in a time critical, fast response operation, nor is it used for emergency response (2) the PORV and PORV Block Valve control switches are available for operator response when required (3) while the keylock feature is noc required for security purposes, it does effectively shape. code this switch from the adjacent PORV and PORV Block Valve switches (4) while keylock switches should not be used solely for shape coding-(NUREG-0700, 6.4.4.3.a), in this instance the use of a keylock switch is a very minor HED and, in addition, with the key remaining in the switch (since there is no security requirement), the switch is effectively a non-key rotary switch.
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In consideration of the above, Duke believes that a change is neither desirable or essential.
3.
DISCUSSION OF DUKE HED IMPLEMENTATION PLAN
^
The HED ~ aplementation Plan is the last phase of an extensive Duke effort to conduct the McGuire CRDR. The staff has reviewed this entire effort.
and has found that all other requirements of NUREG-0737, Supplement 1 have
-been met with the schedule for HED corrective action being the one exception.
(Assuming ~HED M-1-0152 is adequately resolved by this submittal).
In developing the implementation plan, Duke utilized those personnel'with expertise that had been relied upon in the early phases of CRDR and which the staff.had stated met the requirements. Two broad areas were considered in development of the implementation plan.
The first broad area included factors associated with HED modifications themselves. Following the completion of Control Room Review (CRR) on November 1, 1983, work began immediately to implement modifications on McGuire Unit 1.
The design, equipment procurement, and implementation of 22 HEDs were completed as scheduled in the first refueling outage beginning February.26, 1984'--- 3% months after Control Room Review completion.
A t-These HED modifications included nameplates, mimic additions, meter scale F
revisions, switch modifications, and the re-arrangement of several control l
board panels. Factors considered in selecting these HEDs were CRR L
Priorization, design lead time, equipment procurement lead time, and r
integration with the work already scheduled for the outage 1 - 2 years in advance of the outage date.
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1
'After the complation of the first McGuire 1 outage, Duke began planning
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and' scheduling work for'the second outage =for Unit 1, identifying the work I
which could possibly be done on-line and providing those designs to the station as soon as reasonably possible. Physical modifications planned for the.second outage included meter scales, switch modifications, the addition of narrow range containment pressure indication, additional valve controls, removal of unnecessary controls from the control room, and the re-arrangement of devices on control boards IMC9, 10, 11, and 13.
- Again, factors. considered in selecting these modifications for improvement included CRR priorization, operating procedure revisions, training necessary to support the modifications, instrument calibration and IAE procedure changes, design and equipment lead-times, and the similar efforts proceeding in parallel on McGu' ire Unit 2.
Duke's commitment for the second Unit i refueling outage is 45 HED modi-fications. Presently 55 HED modifications have been designed and scheduled for implementation'.
It is our goal to install as many of these modifi-cations as possible and to exceed the commitment of 45 if possible.
However, it has been our experience that equipment deliveries, physical
-constraints to implementation, operating conditio.
.ich limit circuit r
modifications, or unscheduled equipment repairs may impact the number of modifications we are able to install during an outage.
If we are success-ful in meeting our goal of 55 HED modifications, Duke Power will have completed 51% of the total HEDs committed to be resolved in the time frame of one fuel cycle'.
This 51% includes over 90% of the Paint, Tape, Label (PTL) HED modifications.
8
The remaining HED modifications scheduled for the next two_ refueling outages include a large number of meter scale revisions (ranging from label enh'ancements to scale / range revisions), the addition of controls /
displays useful to the operator but not saf'ety significant, the rearrange-ments of IMC2 control board and the HVAC control board, minor re-arrange-ments to control: boards IMCI and IMC13, auxiliary shutdown panel modifi-cations, and the relocation of annunciator tiles. Again these modifica-tion are scheduled consistent with CRR priorization recommendations, planned for minimum impact to operating procedures and operator training, and scheduled with the best utilization of Duke Power design and construction resources. These modification schedules take into account prioritization of HED modifications versus other modifications and also take into account the fact that our manpower resources are distributed over seven nuclear power units.
Table 2 shows the HED modification plan for Unit 1.
The table lists the HEDs in ten categories:
nameplates, meter scales, switch modifications, recorder modifications, equipment additions, equipment deletions, control board component re-arrangements, auxiliary shutdown panel modifications, miscellaneous, and annunciator modifications. Explanations of these categories are contained as a footnote to Table 2.
With respect to McGuire Unit 2, the first outage commitment is 47 HEDs.
Our goal is to exceed the commitment unless hampered by unexpected problems as' discussed with Unit 1.
Comparing the Unit 2 first outage modification to the second outage of Unit 1, three points are noted:
9
1.
'Over 70% of the nameplate modifications are planned for completion by the end of the first outage; 2.
= Compared to the Unit-1 first refueling, a larger group of control board =re-arrangements are planned for Unit 2 in an effort to keep the modifications synchronized for the 2 units; and, 3.
Most of the Unit 2 HED modifications to resolve the minor differences between the two units are planned for the first Unit 2 refueling outage.
Work is proceeding to schedule remaining Unit 2 modifications over the next three outages to meet or exceed our NRC commitments and to keep Unit
-2 modifications in step with the Unit 1 progress. Table 3 shows the HED modification plan for Unit 2.
The table lists the HEDs in the same ten categories as provided for Unit 1.
As can be seen from the preceding, Duke has been aggressive in implementing identified HED improvements.
It is estimated that 350,000 man-hours will.be expended on this effort for McGuire alone.
It is also noted that several were implemented prior to the submittal of the Summary Report and many more designs completed and implementation started even before NRC issued its SER and Supplement.
Summarizing, HED modifications are scheduled for implementation-in a priorization order recommended by the CRR Team which was developed by a consensus of opinion representing human factors engineering, operating, and engineering disciplines. Their consensus of opinion considered the importance of each HED to plant operation, design lead time, equipment 10
.o lead time, limiting operating conditions during the outage, and the resources available during an outage to accomplish these modifications.
Of equal importance in the decision process was the objective to minimize the negative impact of these changes to the operator.
The Duke Power Control Room Review has demonstrated a strong commitment to strengthen-the man-machine interface in the control room. Our control room review found no HED so significant that it required immediate resolution or that it should cause a delay in plant operations. The implementation schedule proposed by the Control Room Review Team integrated with other improvements scheduled such as E0P Upgrade, SPDS, PAM, and other regulatory actions, is reasonable and allows for the proper flexibility to be achieved.
While the NRC would have each HED reviewed against four factors and supplied with a numerical estimate to be used to determine relative significance, Duke submits that such an effort is not supported by the perceived benefit as all outstanding HED modifications are of minimal significance, especially when compared to other planned plant modifica-tions. Such an effort would be of even less benefit when applied to the small number of HEDs expected to be installed following the 1986 refueling outages.
The second major area considered by Duke in the development of the HED implementation plan includes other plant modifications and the modifi-
-cation process itself.
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There is approximately a 1-2 year lead time requirol to perform all the necessary actions in order,to implement any'modificction in a plant.
Certain critical modifications can be made on an expedited basis but such is not the case here. The number of regulatory related modifications planned for current and future outages is substantial. The total scope of modifications for 1986 refue:Ing outages has already been fairly well set as have major activities. Table 4 summarizes the extent of planned modifications. Each modification must go through a rigorous process before it can be implemented.
Even apparently simple modifications must be thoroughly reviewed.
A copy of the modification-process flow chart is provided for information
-to assist in understanding the complexity of the modification process.
Also attached, for informational purposes only, is a copy of the implementation plan which must be developed for each NSM by its Accountable Engineer. Please note that this 11 page plan is but a small
.part of the modification process flow chart.
Based on the thorough understanding of the relevant factors presented above, Duke has concluded that the implementation plan presented is both reasonable and effective.
4.
CONCLUSIONS Duke has provided a firm commitment to complete all outstanding HED's on a reasonable schedule. This schedule is realistic, achievable and takes into-consideration many factors. Duke has also demonstrated the ability to meet and even exceed commitments made thus far. However, even in the 12
u best of plans, problems and delays can arise on individual' improvements without compromising the effectiveness of the overall plan. Licensees should be allowed the flexibility to accommodate potential delays, and not s
be required to comply with arbitrary generic deadlines, and explicit schedules.for. implementation of each HED. None of the outstanding HED's are of such a significance as to require a forced plant shutdown to implement or to require the extension of an outage to complete. Although from a regulatory perspective the establishment of an arbitrary completion date is effective, it is unrealistic in that it does not take into account the complexities of the modification process nor the relative insignificance of the effect of HED modifications yet to be installed.
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x Table 1 McGuire Control Room Design Review Milestone Schedule Steering Committee Appointment 11/81 Program Concept 01/82 Review Team Selected 02/82 Final Draft of Review Plan 05/82 Plan Presentation to NRC 05/82 Biotechnology Hired for Human Factor Assistance 06/82
' Final Duke /BTI Workplan 08/82 Commence Review Activities 09/82 Generic Letter 82-33, Supplement 1 to NUREG-0737 12/82 Duke Plan in-Response to GL 82-33 04/83 Complete Review Activities 05/83 Complete Assessment of Review Results 08/83 CRDR Summary Report to NRC 02/84 CRDR Implementation Schedule 03/84
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T1bla 2 g
_ Hec < t r* tin t e 1 x
First Refueling Outage _ (Completed HED*.9)
~ Nameplates Switch
' ^
Mtaic He?ar Modific
_ l.shels Scales I.at,els '
Recorder Equip.
Equip.
. CS Nods Add.
Deletions Aestrange ASP Mtse.
Ann.
415-075 001 407 564
/ /
129 492 104 016 486 139 493 107
!!4 2694 494 176 355
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672 512.
286
. 666
.Second Refueling Outare (Planned HED's) ---
066 121 020 616 219 580 700
' 064 714 184 054 077 108 681 610C 117 687 078 132 691
~096 337 656 141 695 097 3434 142 102 343C 149 103 344 3g3
- 106 359 -
\\
768c 127 513 172-491 114 189 565 5' 6 307 308
+
309 311 4
322 333 375 i
488 671 s
683 Third and Fourth Refueling Outates (Planned HED's) 111 '
070 699 003 ~
179 272 3 76 615 610d
' 004
- 430 138-152 292 40316 675 522 682 403C 018 177 354 678 190 105 689 652 679 198 363-0 34 517
-698 693-274 124 194 587 686 281 258 665
$20 688 282 331 664 188 694 283
. 361 482 657 703 285 s
676 -
217 288 I
192 313 324 327
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370 374 1
487
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489 609
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-w T:bla 3 McCairs Unit 2
_First Refueling Outage (Planned NED's)
Nameplates Switch
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Mimic
.. Meter Modific Recorder Equip.
Equip.
CB
__ Labels scales Labels th4s Add.
Deletions
' Rearrange ASP Misc.
Ann.
415
-075 001 407 020 616 129 2-222 610C 700 4 94 176 016 486 2 - 3 36 139 066 666 114 564 2694 068 714 356 077 672 184 078 337 56 5 0 96 132 2-325 097 102 149 103 268C 106 514 127 2-318
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2-319 172 2-322 189 M8 2-323 x
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311 322..
375 488 671 2-308 309 333 McCutre Unit 2 Gemaining Three Outages (Planned HED's) 6 Nameplates Switch.
Mimic Meter Modific Recorder Equip.
Equip.
CB
_ Labels Scales
_ Labels Mods
_ Add.
Deletions Rearrance ASP Misc.
Ann; 104 003 054 272 105 004
,107 124 292 128 675 108 681 6104 018 286 258 678 192-142 687 403C 679 30 7 121 331 2-314 656 183 691
' 652 070 337 179 513 695 693 1 38
}438
-403a 516 615 683 177 343C 190 376 682 111 198 344 0 34 512 689 4 30 274 359 1 94 517 281 361 665 587 686 282 491 664 520 688 233 699 482 188 6 94 285 152
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657 698 287 354 676 2-457 288 36 3 2-315 s
313 2-313 2 -330 324 2-311 327 I'I 170 374 i
487 489 6
609 o.
653 6 90 186 45 2 - 30 9
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Table 2 J
-Footactes t
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' Nameplates mimic labels: Nameplates, demarcation' lines, mimic lines, etc.;
i engraved plastic pieces attached to the' control' boards by screws.
.N' Meter scales: Modifications made to meter scales including changing the range which will require transmitter calibration, replacement or square root
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extractors-to linearize; changes to the scale graduations, numbers displayed,' ',
title of the parameter being measured (e.g., volts in lieu of V), addition of
-red abnormal range markings, changing Roman numerals to Arabic numerals indicating, channels, etc. All of the above changes require that the meter be v
removed from service, removed from the board and disassembled.
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- Switch modifications:
-Labels, changing switch lens (colors, abbreviations, e
arrangements), changing switch functions, changing the rotetion (i.e.,
t;.
auto-on-off to on-auto-off), changing the escutcheon around the switch j/ '
indicating switch function. All of the above changes require taking the switch out~of service, removal from the board,.in some cases disassembly, and in some cases wiring changes.
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4 Recorder modifications: Change pen functions, pen arrangement, pen colors, recorder-labels, paper type.
i Equipment additions: Add meters, switches', controllers, displays, recorders.
All involve cutting the board, painting, wiring.
e
r i-Equipment deletionsi' Delete' meters, switches, controllers, displays, recorders. All involve wiring, patching and painting the board.
Control board rearrangements: Range from swapping one device with another on the same board or changing devices from one board to another, to complete removal-of all devices from a board, patching the board, cutting new cut-outs,
-painting and rewiring the arrangement.
ASP: Changes to the auxiliary shutdown panel including nameplates, switch modifications, meter changes, device addition / deletion, and rearrangements.
Miscellaneous (Misc): Lighting, covering holes in the concrete, etc.
Annunciator (Ann): Changes to the annunciators and status lights including the rearrangement of files, addition and deletion of signals. This is a significant modification to'the Control Room involving new cables and wiring changes.
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- R-Table 4 McGuire Nuclear Station Modifications 65 CRDR NSM's were originally written for Unit 1.
71 CRDR NSM's were originally written for Unit 2.
The remaining CRDR NSM's constitute approximately 15% of the open NSM's on MNS.
Regulatory required NSM's constitute approximately 25% of the open NSM's on HNS.
<43 of 97 (44%) of the NSM's planned for Unit 2's 1985 refueling outage (EOC 1) are regulatory requirements.
23'of 76 (30%) of the NSM's planned for Unit l's 1985 refueling outage (EOC 2) are regulatory requirements.
36 of 69 (52%) of the NSM's planned for Unit 2's 1986 refueling outage (EOC 2) are regulatory requirements.
39 of 80 (49%) of the NSM's planned for Unit l's 1986 refueling outage (EOC 3) are regulatory requirements.
1986 Refueling Outage Major Modifications
. Control Room Design Review Hardware Modifications
. RG 1.97 Modifications
. Upgrade Incore T/C NSM = Nuclear Station Modification t
05/03/85 i
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eage 1 of 7 4.2.1 Process Flow Chart for Design Engineering Designed Modifications (using limited edition drawings)
Non-Station Work Station Work Group Design Engineering Group Identifies Identifies Problem Work Group Identifies Problem Problem I
si se si Non-Station Work Station Work Group Design Engineering Group Writes Prob-Writes Problem Work Group Writes lem Report Report Problem Report
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Problem Report Trans.
mitted to Station s
Projects
%/
Accountable Engineer consults DE or NPD G.0. and investigates al ternatives Modiff ation Return Problem Report Required with Recomendations I
to Originator or de-sign study requested.
Yes
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Accountable Engineer Writes NSM Request i/
Station Projects Detennines Design Organization and Implementing Organi-zation A
4.2-1 Rev. O
page 2 of 7 i
C0 Decision by Station Manacer No NSM Returned to s
NSM Accountable Approved Engineer and to 7
initiator of problem report Yes
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NSM Transmitted to Nucl.Maint/
Projects with NSM #
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Preliminary Project Schedule Made by Nucl.Maint./ Projects 1
Decision by NSM, Maint. Account f, and ucl.Maint./ Proj.
Schedule transmitted to PMD, g,
3 Misc. Proj. Coord. (xc to Is Cost Est.
G.O. Technical Group, Sta-Needed tion Projects and Implemen-
?
tingOrganization.)
Yes NSM Sent to PMD, Project Engineer NSM Sent to PMD, Misc. Project Coordinator with Cost Estimate Request and Schedule (On A List)
NSM formally transmitted to Lead Division NSM/ Cost Est. Request forwarded to PMD, Proj. Engr.- for formal transmittal to lead division C
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4.2-2 Rev. O
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page 3 of 7 1/
Lead division evaluates NSM and provides scope document to PMD (xc to SSD, NM/P and Accountable Engineer) 4 Cost Est. activities scheduled in Punch List u
Lead Division obtains Cost Est.
from all divisions, SSD and other departments and forwards to PMD, Prof. Engineer v
PMD, Proj. Engineer completes Cost Est. Sunenary and sends to G.O. - Nuclear Maint./ Projects (Off A List)
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j Cost Estimate Package trans-mitted to Station Projects by Nucl.Maint/ Projects (xc to G.O.
Technical Group) l V
Review by Accountable Engineer s
Station Decision N
Return to Nucl.Maint./
Is NSM Projects Acceptable
?
Yes Station Manager Approves D
4 4.2-3 Rev. 0
Attachment i page 4 of 7 C0 u
NSM transmitted to Nucl.Maint/
Projects sr Nucl.Maint./ Projects Prepares Regular WO and obtains approval i/
Nucl.Maint./ Projects Prepares Letter on Need for Project Agreement S/
Project Control Resolves Conflicts
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Project Agreement Written (IfRequired)
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Nucl.Maint./ Projects Adjusts Project Schedule S/
NSM, Accounting Information, and Schedule transmitted to PMD, Misc. Proj. Coord.
(xc to G.O. Technical Group Station) (On 8 List)
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NSM Sent to PMD, Proj. Engr.
l v
NSM formally transmitted to Lead Division E
4.2-4 Rev. 0
page 5 of 7 O
O
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Lead Division - Responsible Engineer (Lead Engineer) 1.
Reviews NSM & prepares scope document.
2.
Sends scope document to PMD for schedule P/L.
DE 3.
Transmits scope document & NSM copies to support divisions.
4.
Establishes date and personnel for inter-disciplinary review within D.E.D., if required (*)
Lead Divisions & Support Divisions Design activities to support Nuclear Production PMD sets agenda and writes minutes for inter-disciplinar meeting (NPD copied) y review Decision on design package content made by Lead Engr.,
Project Engr. & Station Accountable Engineer v
Design is complete and safety evalua-tion checklist is prepared. Limited Edition Dwgs.and Design Sumary Issued.
All materials are requis~itioned.
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[
PMO, Project Engineer Issues Document Sumary & notifies NPD all Design is released. (Off B List) (On C List) u Nucl. Maint./ Projects Adjusts Schedule using input from SSD. Also, scope re-viewed by NM/P for need to supplement work order.
v NSM at Station with Design & Material Ordered F
4.2-5 Rev. O
page 6 of 7 v
Implementation Procedures Written, As Required Non-Safety Related Safety Related (QA condition 1) v QA Review
\\/
SRC Review (MNS & CNS only) v Accountable Engineer Assures Ready for Implementation v
Accountable Engineer writes Work Request or has SSD write Shutdown Request or Work Request de Implementation Planning)(refer to Section 7.8 for details 6
Implementation and Verification V
Station Issues Revised Procedures, distributes interim drawings, and operational group accepts turnover System Returned to Service G
4.2-6 Rev. 0
Attachmsnt 1 page 7 of 7 C0 Station Projects Issues Notification of Completion to station groups, Nuclear Maint/ Projects, PMD and others
%f Station Projects provides PMD with appropriate red-marked drawings and other technical information needed to update drawings,.,(Off C List)-(On 0 List) u Nucl.Maint./ Projects closes work orders (ifrequired) t u
PMO transmits update package to lead divisions and copies all support divi-sions. Punchlist schedule for drawing update is an automatic 60 days.
v DE Release dwgs. to show "As-Built" Condition v
PMD prepares & transmits Document Summary and notifies Station Projects that all "As-Built" drawings are released (OffDList) 1 V
NSM File Closed l
4.2-7 Rev. O
Attachment ~ 2 NUCLEAR STATION HODIFICATION Page 1 of 11 IMPLEMENTATION ptAN
'l The following is an outline of the activities required o implement NSM HC-cctivities shall include all major field work and., testing requirements.
at McGuire Nuclear Station. The The responsible work group is listed for each activity and comments are included as needed NSM/SSD work requests.
NOTE:
The comments section may include work request numbers, step by step instructions and specific requirements as needed.
If additional space is necessary, sheets may be attached.
I.
Prerequisite System Conditions The following is a description of the steps that shall be taken in order to provide the proper system conditions for implementation of the NSM.
(Note:
These conditions include observations made by the accountable engineers in Health Physics, Planning, SSD Technical Support, etc., which normally occur of these conditions are:
Examples outage required or specific mode required, train A or B or both out of service, operability of other system (s) affected, Tech Spec requirements involved, and draining of piping systems would be beneficial to mark up drawings if possible, showing the affected portion (s) of system (s).
, etc.
It II.
Limits and Precautions The following are limits and precautions that shall be considered before and during the implementation of the NSN This shall include personnel and equipment safety requirements, with recommendations of preventive measures that c be taken.
The possibility that other adjacent or connecting systems may be affected shall be considered.
N N
ACTIVITY P:ge 2 of 11-RESPONSIBLE CROUP PROCEDURES COMMENTS III. Directions for Implementation A.
Electrical 1.
Install / modify electrical equipment (panelboards, transformers, switchgear, motor control centers, disconnects, breakers, switches, batteries, battery chargers, motors, generators, relays, cabinets, terminal boxes, fuse blocks)
DATE COMPLETE:
INITIAL:
2.
Pull or delete cables, lugging, terminations, bandling of spare conductors, penetration work, and cable separation.
s DATE COMPLETED:
INITIAL:
3.
Install / modify cable trays, conduit, electray, unistrut, required supports, and seismic mounting DATE COMPLETED:
ICITIAL:
Pcge 3 of 11 -
ACTIVITY RESPONSIBLE CROUP PROCEDURES 4.
Install / modify lighting and
~-COMMENTS lighting panelboards, switches, and any lighting panelboard load additions I
DATE COMPLETED:
INITIAL:
5.
Control board changes (mounting of controls, cut-outs, welding, control board wiring, nomenclature, and train separation)
DATE COMPLETED:
I;1TIAL:
l j
6.
Install / modify valve operators, including set-up of actuators and limit switches, and solenoid valves DATE COMPLETED:
j INITIAL:
1 7.
Miscellaneous wiring changes (Describe changes below) 1 1
DATE COMPLETED:
INITIAL:
ACTIVITY
,P2Re 4 of 11 RESPONSIBLE CROUP PROCEDURES 8.
Check out of electrical circuits COMMENTS.
or controls (voltage / current /re-sistance checks, functional test, scaling, equipment rotational check, calibration).
DATE COMPLETED:
INITIAL:
B.
Instrumentation 1.
Install / modify instrumentation (manifolds, root valves, panels, filter regulators, transmitters, sensors, parameter switches, gauges, orifices, cabinets, including mounting) i DATE COMPLETED:
INITIAL:
2.
Install / modify instrument tubing (bending, cutting, and welding of capillary, impulse and process lines, including all types of fittings, supports, and seismic mounting).
s'\\
DATE COMPLETED:
INITIAL:
t
Page 5 of 11 ACTIVITY RESPONSIBLE GROUP PROCEDURES COMMENTS 3.
Check-out instrument loops including calibration of instruments, controls, and setpoint changes.
f i
DATE COMPLETED:
INITIAL:
C.
Mechanical 1.
Install / modify piping, elbows, tees, fittings, and flanges.
Includes welding, cutting, and fitting.
4 DATE COMPLETED:
INITIAL:
2.
Install / modify valves (describe changes below)
DATE COMPLETED:
INITIAL:
i 3.
Install / modify mechanical equipment (pumps, heat exchangers, turbines, including alignment of equipment) i DATE COMPLETED:
INITIAL:
Attachment'2 ACTIVITY Page 6 of 11 RESPONSIBLE GROUP PROCEDURES 4.
Install / modify pipe supports CONNENTS (springs, snubbers, seismic, and rigid supports)
DATE COMPLETED:
INITIAL:
5.
Leak seals of valves, flanges (Furmanite, Leak Repair, etc.)
DATE COMPLETED:
INITIAL:
6.
Heat exchanger, condenser tube, and steam generator tube modification / replacement DATE COMPLETED:
INITIAL:
7.
Install / modify HVAC equipment (ventilation units, coolers, heat exchangers, ductwork, ductwork supports, dampers, actuators, controls, cabinets, panels filters, includes functional testing, and balancing of systems).
DATE COMPLETED:
INITIAL:
Att:chment-2 Page 7 of 11 ACTIVITY RESPONSIBLE CROUP PROCEDURES 8.
Planbing
~
COMMENTS DATE COMPLETED:
INITIAL:
9.
Insulation work (piping, HVAC, Equipment, Mirror, and Nukon)
DATE COMPLETED:
IIITIAL:
U.
Civil / Miscellaneous 1.
Masonry work (concrete pouring, rebar installation, rebar cutting, brickwork, blockwork, and grouting).
DATE COMPLETED:
INITIAL:
2.
Core drill, installation of penetrations and pipe sleeves, and concrete cutting DATE COMPLETED:
IIITIAL:
Att:chment 2 ACTIVITY p
g g RESPONSIBLE CROUP PROCEDifRES 3.
Installation of concrete anchors, C0fffENTS all types of baseplates, concrete embeds, and seismic mounting DATE COMPLETED:
ICITIAL:
4.
Structural Steel Work (steel installation / modification, rigging, platforms, ladders, frames, railing, decking, grating, toeplates, stairs, cranes, jib booms DATE COMPLETED:
INITIAL:
5.
Scaffolding DATE COMPLETED:
INITIAL:
f>.
Sandblasting and coating DATE COMPLETED:
IIITIAL:
Page 9 of 11 ACTIVITT RESPONSTRLE CROUP PROCEDURES CONNENTS 7.
Fire protection systems (sprinklers, barriers, halon, hose cabinets, etc.)
DATE COMPLETED:
IZITIAL:
8.
Excavation work, trenching, foundations, ditches, earthmoving DATE COMPLETED:
IZITIAL:
9.
Surveying DATE COMPLETED:
ICITIAL:
10.
All types of carpentry and building erection DATE COMPLETED:
ICITIAL:
II.
Installation of fencing and barriers f
DATE COMPLETED:
INITIAL:
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IV.
Work Sequence and Scheduling The following will outline a required work sequence if there is any part.icular order in which the work must. he done Also, the scheduled start and finish dates with any designated dates for progress reviews are identified.
SCHEDUED START:
SCHEDULED COMPLETE:
PROGRESS REVIEWS:
INITIAL INITIAL INITIAL INITIAL V.
Post Modification Testing (PMT)
The following station procedures and test procedures will be required for functional checks and retest after completion of implementation and before the control of affected systems and components is returned to the Operational Control Group.
The work request numbers for any Nuclear Production verification are listed also.
PROCEDURES _
WORK REQUESTS DATE COMPETED:
ICITIAL:
,..,