ML20132C881

STP Engineering Self Assessment Final Rept

ML20132C881
Person / Time
Site:	South Texas
Issue date:	10/24/1996
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20132C879	List: ML20132C881 ST-HL-AE-5535, Forwards South Tx Project Engineering Self-Assessment Final Rept 961014-24
References
NUDOCS 9612190052
Download: ML20132C881 (45)

Text

___ ___ _ __-___ -

l %6 8U W f

- O+ '

1 e

c\ 4 l

u - -

@ O-i e e I

O

(

l .

gE l

- _i':

, n.

ye3 -

4 ) r.

_ , ,.#'y:J

L. .-:..

7=- ---

. , \

_._ f', nW ""%/__ 'n (.

~

,], , 3 . 1 *__ L. ,. )U 'Q kr~ ._-

~'

~ ---~=;l ___

l . = w_ _ s - -- __.= -

- ~ - y

_ ._ _. ~~~..___

1

~._._ em a

.=

l ,

a lju. gh-wfB9i ..

9 n.,

u! r g

1 I

SOUTH TEXAS PROJECT ENGINEERING SELF ASSESSMENT

[

Final Report

[ October 14 - 24,1996 DR ADO 050hO98 P PDR ,,

- i

ENGINEERING SELF-ASSESSMENT EXECUTIVE

SUMMARY

An Engineering Self-Assessment was conducted October 14 - 24,1996. He self-assessment i evaluated Engineering activities in accordance with the guidance provided in NRC Inspection Procedure 37550," Engineering", the objective of which states," Evaluate the licensee's engineering activities, particularly the effectiveness of the Engineering organization to perform routine and reactive site activities, including the identification and resolution of technical issues and problems".

I The Self-Assessment Team was comprised of 14 senior level STP personnel from Engineering, Quality Assurance, Licensing, Operations, and Maintenance and two industry peers (a Design Engineering Supervisor from Palo Verde, and an Engineering Programs Supervisor from Diablo Canyon) both with recent experience in performing similar assessments.

He assessment team was divided into two sub-teams to support using both a horizontal and vertical approach.

The horizontal approach evaluated the effectiveness of Engineering support, processes and programs in the following areas:

. Operations Support e Maintenance Support e Systems Engineering I e Design Engineering

= Engineering Programs

• Industry Events Analysis The vertical approach evaluated the quality of selected Engineering activities and products through a review of the following systems:

• Class IE 125 VDC Power System

. Essential Chilled Water System

. Condensate System (including Condensate Polishing)

! Problems or issues identified during the assessment were addressed using the station Corrective Action Program (CAP). A total of 68 Condition Reports were written throughout the assessment.

No significant conditions adverse to quality (SCAQ) were identified during the assessment. Four were identified as station level conditions adverse to quality (CAQ-S),26 department level

[ conditions adverse to quality (CAQ-D), and 38 conditions not adverse to quality (CNAQ). No concerns were identified which adversely affected equipment operability.

( Re assessment team concluded that the Engineering organization is effective at performing routine and emergent work activities, identifying and resolving technical issues and problems in support of safe plant operation.

%e following is a summary of the strengths:

Interviews with on-shift Operations personnel, Maintenance and Planning personnel, and Operations management indicate Engineering support, particularly for emergent c

6 Y

1 l

work, is excellent.

A strong Engineering managem:nt team that is sensitive to plant needs is viewed as a strength.

• Effective communication with and support of plant operations are excellent.

• Engineering's support of corrective and preventive maintenance activities, system / material condition, and communications with Maintenance personnel is excellent.

Engineering support is a key element contributing to successful outage planning, scheduling, and execution.

He Temporary Modification Program is characterized by high quality products that are effectively implemented and managed.

The following is a summary of the more significant areas for improvement:

e ne quality of the Systems Engineering walkdowns and the use of walkdown reports y could be enhanced by Operations and Maintenance personnel participating in the j

System Engineering walkdowns; using the walkdown reports as a tool to provide management focus on system material condition issues; and increased sensitivity by the System Engineers to potent'al Operator impacts.

He effectiveness of the Systems Engineering Health Reports could be improved by issuing the reports more frequently; and using the health reports as a tool to provide j increased visibility and management focus on system material condition issues and t Engineering recommendations.

e A review of documents and databases within the Configuration Management Program identified incorrect Setpoint Index values, inaccuracies and incompleteness of setpoint basis references in the Electrical Setpoint Databases, and overly restrictive tolerances in the Instrument Setpoint Document.

Management's expectations on the use of the Design Basis Documents as a reference or source document were unclear and require improvement.

Several Design Basis Documents do not reflect the current plant design or configuration and have a number of unincorporated amendments.

e f ne modification process could be improved by establishing guidance and reinforcing management expectations with respect to the level of detail contained in design change / modification packages, the criteria for minor changes, and work package closure.

Condition Report 96-15668 has been generated to track the above summary results and their associated action plans. Condidon Report 96-15668 also tracks the recommended enhancements which are identified within the text of this assessment.

ENGINEERING SELF-ASSESSMENT TABLE OF CONTENTS INTRODUCTION

. O bj ec ti ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 2 e App roach and S cope.. .. ............ . . .... .............................Page 2 e Proces s O vervie w. . ............. . ... . .. .. ............... ... . ............Page 4 e Te a m M e mbe rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Pag e 4 RESULTS

• O p e ra t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 5 Mai nte n ance. . . .. . . . . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . .. . . . . . . . . . . .. . . . .. . . .. . .Page 1 1 S yste ms Enginee ring... .... .. .... . ............. ...................... . Page 13 D e sig n Engineerin g.. .. .. . . .. ...... . .. .... . . . .. ... ..... ... . ..... .......Page 19 Engineering Programs................................................Page 28 ATTACHMENTS a Engineering Self-assessment Condition Reports

ENGINEERING SELF-ASSESSMENT INTRODUCTION OBJECTIVES The purpose of the self-assessment was to evaluate Engineering activities at the South Texas Project (STP) in accordance with the guidance provided in NRC Inspection Procedure 37550,

" Engineering". The objectives of the self-assessment were:

Evaluate the effectiveness of Engineering programs and activities; Identify strengths and areas for improvement; Develop corrective actions, as required; Enhance Engineering self-assessment capabilities.

APPROACII AND SCOPE

/

The Engineering Self-Assessment was conducted October 14 - 24,1996. The Self-Assessmert Team was comprised of 14 senior level STP personnel from Engineering, Quality Assurance, Licensing, Operations, and Maintenance and two industry peers, a Design Engineering Supervisor from Palo Verde, and an Engineering Programs Supervisor from Diablo Canyon both with experience in performing similar assessments. The assessment used a horizontal and vertical approach and the team was divided into two sub-teams to support this approach.

The horizontal approach evaluated the effectiveness of Engineering support, processes and programs in the following areas:

. Operations Support e Maintenance Support e Systems Engineering

• Design Engineering e Engineering Programs e Industry Events Analysis The horizontal team reviewed these functional areas for effective performance of the following:

. Customer Support

. Emergent Work Support

• Weekly Maintenance Schedule Support e Permanent / Temporary Modifications e Walkdown / System Health Reports e Configuration Management

. Engineering Workload Management

. Use of Industry and In-house Operating Experience e Preventative Maintenance Program

. Maintenance Rule

• Probabilistic Risk Assessment Page 2

{ l o

The vertical approach evaluated the quality of selected Engineering activities and products through an in-depth review of the following systems:

. Class IE 125 VDC Power System

. Essential Chilled Water System

. Condensate System (including Condensate Polishing)

The systems were selected by Engineering management based on one or more of the following criteria:

. Safety related e Designed by the architect / engineer with licensee involvement

. Significance to probabilistic sr.fety assessment No previous or recent Safety System Functional Assessment-type review e Input from Plant Operations personnel l The Design Basis Documents (DBDs) were used to establish the minimum boundaries of the vertical review systems. An exception to this was the addition of the 120 VAC Class IE Vital System to the review of the 125 VDC Class IE System due to previous issues with the inverters.

He vertical team reviewed the systems for effective implementation in the following areas:

• Design Basis Design Criteria / Design Bases Documents UFSAR and Commitments Technical Specifications Design Changes Safety Evaluations

. Operational Readiness Operability Assessments System i otaterial Condition Operator impach System Performance Corrective / Preventive Maintenance Maintenance and Surveillance Testing Performance Monitoring Problem Identification / Issue Resolution Operating Experiences Engineering Evaluations System Trends e Communications Management !nvolvement Timeliness / Frequency of Communications with Operations and Maintenance System Health Reports Page 3

"I l 1

PROCESS OVERVIEW The following provides a summary of the self assessment process steps:

• Perform horizontal and vertical reviews e Integrate the results of both reviews

• Identify strengths, deficiencies, and areas for impro,ement

• Document deficiencies and areas for improvement utilizing the station Corrective

, Action Program, Condition Report process e

Develop corrective actions in accordance with the Corrective Action Program TEAM MEMBERS f To perform an effective self. assessment, an assessment team made up of highly qualified 1 individuals was established. The participants consisted of STP employees and other industry personnel who have taken part in self-assessment projects of a similar nature. Collectively, these individuals possess significant engineering experience, knowledge of the self-assessment process, and an integral knowledge of the systems and processes at STP.

The following is a listing of the assessment team members and the team they were assigned to:

John M. Gruber - Team Leader Horizontal Team Mark E. Kanavos - Asst. Team Leader Vertical Team Kenneth R. Cope (Design Engineering) Vertical Team William M. Dowdy, Jr. (Operations) Horizontal Team Stanley J. Eldridge (Quality Assurance) Horizontal Team Duane E. Gore (Nuclear Fuel & Analysis) Vertical Team Albon W. Harrison, Jr. (Licensing) Vertical Team Gary A. Hunt. Sr. (Systems Engineering) Vertical Team Mike Momsen (Systems Engineering) VerticalTeam Craig A. Murry (Technical Support Engineering) Vertical Team Anil P. Pathak (Systems Engineering) Horizontal Team Richard L. Prater (Quality Assurance) Vertical Team Lee B. Taylor (Maintenance) Horizontal Team William G. Wellborn (Design Engineering) Vertical Team Karen Holland - Admin. Assistance Vertical Team Sandra Meyerdirk - Admin. Assistance Ho-izontal Team Don Shelley - Diablo Canyon Power Plant Horizontal Team Michael Hodge - Palo Verde Power Plant Vertical Team Page 4

l OPERATIONS

1. Operations Support Engineering support of plant operations and communications with Operations personnel is a strength. Interviews with on-shift Operations personnel, Maintenance and Planning personnel, and Operations management indicate Engineering support, particularly for emergent work, is excellent.

His strength is characterized by:

• Technical Support Engineering attendance at Operations Shift Turnovers System Engineers' presence in the field including discussions of System Walkdown Status Reports with on-shift Control Room personnel. A Shift Supervisor noted the System Engineer provided him with good feedback of his system and noted there appeared to be more Engineers in the plant walking down systems. An Operations Manager indicated Operations normally sees engineers in the plant performing walkdowns and other activities.

A strong Engineering management team that is sensitive to plant needs. Effective communication, responsiveness, and support received from both Systems Engineering and Design Engineering as noted by:

Support provided by the Reactor Coolant System engineer in response to identification and repair of a Reactor Coolant System leak in Unit 2. (Condition Report 96-12608 documents the specific material failure.)

Engineering's support of long-term initiatives is also good and the ,ols in place such as the Plant Change Committee, the Two and Five Year Modification Plan, the Equipment Issues List, and other presentations provided in the Daily Communication & Teamwork Meeting help to keep long-term items in focus.

Support provided by the Main Steam System engineer to resolve ongoing problem with the Steam Dump Valves.

Engineering's support of significut issues or emergent work has shown significant improvement. Systems Engineering's up-front involvement with the Shift Supervisors and Maintenance is viewed as a plus.

Interviews with Operations Support personnel identified Engineering support and communications has improved. The Engineering backlog for Operations Support corrective actions is reviewed every two weeks for items that will be due within the next 30 days. Rese reviews identified that Engineering is seldom late and rarely extends actions through the Condition Review Group (CRG).

While communications and support of operations has been identified as a strength, some enhancements were identified. Consideration should be given to improving expectations and communications in the following areas:

Improve the communications of Operability / Reportability Reviews. Consider providing updates to Operations throughout the Operability / Reportability Review evaluation as part of the Daily Communication & Teamwork Meeting.

I l

Page 5

e Provide written briefings to expand communications and continuity to the various operating crews when implementing action plans or providing problem resolutions.

{ Operations personnel indicated action plans and issue resolution are not always effectively communicated from one shift to another. This was a general comment not

( directed specifically to Engineering. The example provided was the resolution of the

(- failed fuse on the Unit 2. Class IE inverter, documented on Condition Report 96-12744.

f Support opportunities for operators to interface more with engineers to develop a better appreciation and working relationship with Engineering. Recently, a Unit 1 Reactor Operator " shadowed" some engineers during his Operations requal skip j training week as part of an initiative to educate Operations personnel on Engineering I duties. The operator indicated this experience proved quite valuable, and he learned a considerable amount about what Engineering does "behind the scenes". He would recommend it to other operators as well as offering engineers the same opportunity with Operations.

I 2. Operability / Reportability Reviews Operability / Reportability Reviews were evaluated. Interviews with Operations personnel identified the quality of Engineering products as high. Several Condition Repons (CRs) were reviewed to evaluate the quality of Engineering products. He documents reviewed included:

• CR 96-9710 Operability Review - Reactor Containment Fan Coolers and Essential Cooling Water Systems will maintain the pressure boundary integrity and continue to perform their design functions following a LOOP.

• CR 95-11250 Reportability Review - Main Steam Safety Valve Lift Point found out of tolerance during testing.

e f CR 95-10224 Reportability Review - Wiring associated with BlHEFIC9585 being less than 6" from non-class cable within Main Control Panel 22.

CR 95-13376 Reportability Review - Control Room Envelope Cleanup Filter water intrusion.

The documentation was technically thorough and used conservative assumptions. De resulting conclusions were appropriate.

f i

Page 6

3. Engineering Evaluations Several Condition Report Engineering Evaluations (CREES) were reviewed to evaluate Engineering involvement in the resolution of technical issues and the quality of Engineering products. The documents reviewed included:

• CR 95-11962 Engineering Evaluation - Generic Implications of Pressurizer Safety Valve PSV 3452 found out of tolerance during 2RE04

• CR 96-4223-2 Engineering Evaluation - Potential need to modify Main Turbine Governor Valve Test Light Circuitry and Indications based on valve drift anomaly following testing.

. CR 96-10009-3 Engineering Evaluation - Acceptability of minimum separation from combustible loading associated with temporary laundry facility trailers.

• CR 96-3327 Engineering Evaluation - Terry turbine droop feedback linkage thread engagement (10CFR Part 21 issues).

. CR 96-6757-2 Engineering Evaluation - Provide basis for 1-CC-0332 throttle positions.

. CR 96-4520-3 Engineering Evaluation - Deleting thrust bearing wear test trip from OPOP07-TM-0003.

• CR 96-6663-3 Engineering Evaluation - Associated with fast (dead-bus) transfer of 480 volt load centers.

• CR 95-10553 Engineering Evaluation - Demonstrated Train C operability with only the 150 ton chiller available during seal maintenance on the 300 ton chiller.

. CR 95-8788 Engineering Evaluation - The addition of the condensate fill lines to eliminate the water hammer problem in the Condensate System.

CR 96-1847-2 Engineering Evaluation - Evaluated the downward drift of battery charger output voltage.

• CR 95-10698 Engineering Evaluation - Evaluated the increase in battery electrolyte level found in two new batteries.

• CR 96-5155-1 Engineering Evaluation - Provided justification for the deviation in the method used to measure resistance between battery cells and the description of acceptance criteria in the Technical Specification.

The documentation was technically thorough, and the conclusions were appropriate.

Page 7

4. Temporary Modifications

'Ihe Temporary Modification Program is a strength, and the quality of temporary modifications meets station needs. Reports are provided by Technical Support Engineering that list all outstanding temporary modifications and temporary leak repairs. Actions and due dates to eliminate the T-Mod are discussed weekly in the Daily Communication & Teamwork Meeting.

Reviews of the Control Room Temporary Modification Logs revealed up to date logs, accurate information, and the modifications directly support Operations and Maintenance. Several temporary modifications were reviewed to evaluate the quality of Engineering products. The temporary modifications reviewed included:

. Temporary Modification TI-CD-96-0003 provides an enclosure around leaking valve CD-0799. (This temporary modification is more of a tracking device since the Engineering Evaluation contained in CREE 96-789 is required.)

e Temporary Modification TI-CT-94-001 provides temporary demineralizer flow paths to conserve demineralized water.

• Temporary Modification T-2-DJ-89-021 jumpers Cell 46 of Battery E2B il until the cell can be replaced.

. Temporary Modification TI-96-2285-3 energizes Battery Charger (IE 125 VDC) 3E231EBC047F by lifting leads and landing a temporary cable. Operations requires the battery charger to be energized while B Train is down for maintenance.

Temporary Modification T2-96-10424-2 energizes Battery Charger (IE 125 VDC) 3E232EBC047F by lifting leads and landing a temporary cable. Operations requires the Battery Charger to be energized while B Train is down for maintenance.

e Temtcrary Modification T2-95-2159-3 provides a supplementary battery supply for 125 VDC non Class IE Batteries while they are removed for cell replacement.

. Temporary Modifications T2-CH-94-0052. T2-CH-95-036, and T2-CH-96-298-4 provide temporary nitrogen connections to Essential Chilled Water expansion tanks.

While the descriptions, instructions, and modifications were technically adequate, an improvement to the Temporary Modification Procedure, OPGP03-ZO-0003, was identified. The current procedure does not provide guidance for performing a fire hazards review. Temporary Modifications TI-96-2285-3 and TI-96-10424-2 both landed temporary cabling which added fire loading. The technical review / justification and the 50.59 screening did not mention a fire hazards review. Condition Report 96-13542 was generated for this condition.

l l Fage 8 l

5. Operator Impacts The Daily Communication & Teamwork Meeting provides increased visibility to the evaluation, tracking, and resolution of operator impacts. tIngineering items are resolved in a timely manner; however, the system reviews and walkdowns performed as part of this assessment identified the following items which indicate the need for the System Engineers to be more sensitive to infrequent or off-normal operator impact conditions:

. The Unit 2 Condensate Polishing sump light is mounted to a plate attached to the sump grating and is "hard wired". This requires a breaker tag out and de-termination of wires to remove the grating for sump entry or installation of portable sump pumps.

[ Portable sump pumps are currently required any time there is a plant trip. Current

[ configuration creates a " response time delay" for installation of the portable pump due to the installed lighting interference. Normally, this would not present a concern if the installed pumps were able to keep up with received drains. However, due to the existing design, the installed pumps can not be operated in parallel. This is viewed as a system design weakness, with minor or limited (non safety related) plant impact.

Condition Report 95-3349 was previously issued and is addressing poor Condensate Polishing sump pump discharge line !aterface to improve the installed pumping capability. Condition Report 96-13348 was initiated during the Engineering Self Assessment to address the design / installation of Condensate Polishing sump light in Unit 2, which has the potential to delay operator actions during recovery from plant trips.

• Condensate Seal Water System has experienced several problems over the last few months with pump seal water check valves sticking (both open and closed or leaking by). This created some concerns over system performance and created operator impacts. This should be evaluated by the System Engineer for system impact and potential need for long term corrective actions. Condition Report 96-15672 was generated for this condition.

Several Service Request tags were observed on the Unit I Condensate Polishing control board recorders. The impact of recorder availability was discussed with the operator present at Condensate Polishing control panel. He indicated the unavailable recorders had negligible impact on regeneration since manual samples could be trk n

( for those points that were out of service. Service Request tags 350839 and 3197:.3

( were observed.

6. Outage Planning and Scheduling Engineering support of outage planning and scheduling is considered a strength. This strength is characterized by:

Senior Engineering Management participation in the Outage Management Team Engineering involvement in scope development, work performance, testing and inspection evaluation activities

=

} 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day coverage provided by Technical Support Engineers during outages The ownership and implementation of low power physics testing by Nuclear Fuel &

Analysis Engineering 4

Page 9

\

. The establishment of the Engineering Duty Manager (EDM) as the point-of-contact for Engineering support.

[

}

h f

I L

Page 10

1 MAINTENANCE

1. Maintenance Activity / Material Condition Support Engineering support of maintenance activities and system / material condition and communications with Maintenance personnel are strengths. Interviews with Maintenance personnel and Maintenance management indicate that Engineering support, particularly for emergent work,is excellent. This strength is characterized by:

e Engineering support of the Unit 2, A Train, Elgar Inverter Rectifier failure. Power was supplied through the battery charger and the still functioning inverter. (An LCO was not required as long as DC power was available.) Repair of the inverter was categorized as a Priority 2 work activity. The Engineering Duty Manager was informed of the problem shortly after 1:00 PM by the Unit Manager. The Technical Support Engineer was participating by 1:15 PM. Systems Engineers were in the Maintenance Shop before 2:00 PM actively working with Maintenance to develop a troubleshooting plan. Design Engineering was prepared to support commercial-grade dedication efforts should replacement parts be required. The rectifier failure was attributed to a faulty fuse. Systems and Technical Support Engineers were actively involved in the resolution of this problem. Although the observed Maintenance crews were very knowledgeable about the Elgar Inverter, Engineering input was well received. The Engineering and Maintenance team effectively and efficiently resolved the problem.

Engineering support of the Unit 2, Emergency Diesel Generator (21) connecting rod inspection. System Engineers were at the jobsite as well as consultants from Cooper (engine manufacturer) and Beta (engine analysis equipment manufacturer). 'Ihe inspection was an emergent activity conducted during the regularly scheduled diesel generator work window as a result of anomalies observed in the engine analysis traces.

Evaluation of the traces indicated a potentialloose connecting rod. Physical inspection of the connecting rod bolting identified no problems. Maintenance indicated that Engineering demonstrated ownership by readily supporting action plan development and implementation. The results of this inspection are documented in CR 96-12221.

System Engineering support of the Unit 1. A Train Chilled Water flow problem which rendered the 150 ton chiller inoperable (flow is normally split between the 150 and 300 ton chillers). An action plan was developed and implemented. A gasket located at the divider plate was found displaced and was repaired.

System Engineering ownership of material condition as identified by plant walkdowns and the lower number of significant items being identified. Examples are the improved condition of the Unit I and 2 Essential Chillers and the overall condition of the Unit 2 Condensate Polishing (CP) System. Both are attributed to the increased ownership shown by the System Engineers. Operations commented that the material condition of CP System has improved significantly. The System Engineer has been actively supporting increased on-line maintenance of CP System.

Technical Support Engineers are the primary point-of-contact for Maintenance Planning and provide excellent support. Their customer focus and close proximity to the planners is a strength.

Page11

While communications and support of Maintenance is a strength, the following enhancements were identified:

. Involve Maintenance personnelin system walkdowns and in the development of a(1) to a(2) action plans related to the Maintenance Rule as a method to improve communict.tions. Additional information is contained in the Systems Engineering Section of this report.

• Require System Engineers to carry pagers. Some System Engineers are difficult to contact because they are not issued pagers.

Condition Report 96-15668 has been generated to evaluate these enhancements.

2. Maintenance Schedule Support Engineering support of corrective and preventive maintenance activities has improved.

Engineering's use of a single point-of-contact for scheduling provides effective and efficient communication for the identification and resolution of work activity restraints and maintenance schedule development. This improvement is characterized by:

• Work Control personnel indicated Engineering's support of the Maintenance schedule is good and improving. Previous problems with Engineering rolling items from one work week or work window to the next have been resolved and currently there is very little movement in the schedule. Engineering meets their target dates and if not, it is due to a higher priority item.

The Engineering Work Management (Schedule) Coordinator position is working very well. This position serves as a scheduling single point-of-contact and facilitates effective communication between planning, scheduling, and engineering personnel.

This individual is responsible for reviewing the Unit I and 2 maintenance schedule to identify activities restrained by Engineering and requiring support. This individual attends the scheduling meetings, identifies Engineering restraints in the Work Order Database, and interfaces directly with the engineers to resolve problems.

While Engincering support of corrective and preventive maintenance activitica has improved, the following area for improvement was identified:

• Reinforce the expectation for the System Engineer to be involved in the Work Control scheduling process. Work Control assumes that the scope of work for a given week is correct; however, feedback from the System Engineer on the scope and schedule would be helpful.

Condition Report 96-15668 has been generated to evaluate this area for improvement.

Page 12

I SYSTEMS ENGINEERING

1. Walkdowns / Walkdown Reports ne quality of the Systems Engineering walkdowns and the associated reports were reviewed. He Walkdown Reports met the requirements provided in the Systems Engineering Guidelines. Many of the System Walkdown Reports reviewed document discussions with Operations and Maintenance personnel and identify items of concern.

%e Essential Chilled Water, Class IE 125VDC, and Condensate / Condensate Polishing were walked down as part of the self-assessment. A summary of the results of those walkdowns is provided:

Essential Chilled Water System A walkdown of the Unit 2, Essential Chilled Water System (CH) was performed. His walkdown identified the following items:

. The drain nipples associated with valves 2-CH-0592 and 2-CH-0908 have stainless steel pipe caps installed. This condition does not meet the design criteria spccified in plant procedure SL019PS004 "WA Spec." for the Chilled Water System. Condition Report 96-12729 was generated for this condition.

Valve 2-CH-0899 is missing its description identification (TPNS/DESC) tag.

Condition Report 96-12730 was generated for this condition.

. The six inch flange connection on the Essential Chiller 21 A ECW Return Line was found to have an insulating washer installed backwards. Condition Report 96-12740 was generated for this condition.

= A walkdown of the outlet throttle valves for Essential Chillers 22A,22B, and 22C was performed for the following attributes:

1) Valve position for compliance with OPOP02-CH-0001.

2) Material condition.

3) Compliance with current design documents.

4) Proper plant labeling.

The results of this inspection indicate the valves were properly positioned, appeared physically sound, and met current vendor and site configuration documents. It was noted that valve 2-CH-0598 failed to exhibit the red placard as found on the other trains that stated " NOTIFY SHIIT SUPERVISOR PRIOR TO OPERATING THIS VALVE". Condition Report 96-12738 was generated for this condition.

Page 13

l Class IE 125VDC / Class IE 120VAC Vital Systems A walkdown of the Unit I and Unit 2 Class IE 125VDC (DJ)/ Class IE 120VAC Vital (VA) Systems was performed. The material condition of the systems was satisfactory; however, the following conditions were identified:

. During conversations with the Unit I and Unit 2 Control Room staffs,it was determined that the Class IE Battery Charger Voltage Gauges on Control Panel (CP) 003 were used for information only and not for Technical Specification compliance. There is not a common expectation to dispatch an operator to the battery charger rooms to take local readings when the instruments on CP003 indicate less than the Technical Specification minimum of 129VDC. For example, the gauge for Battery Charger ElB11 on CP003 in Unit I read 128VDC at 0820 on October 17,1996. The local digital gauge read 130.4VDC. Operators review battery charger output voltage locally from this digital gauge each shift and the Technical Specification surveillance is performed every seven days. However, since the Control Room staff does not take Technical Specification action below 129VDC as indicated on CP003, the voltage may drop below this minimum voltage, thus violating the Technical Specification minimum (and still be above the switchboard undervoltage relay alarm setpoint of 124VDC) without the operators' knowledge. Condition Report 96-12945 was generated for this condition.

The Unit 1 Walkdown Report for September 3,1996 notes a concern for Class 1E 125 VDC System voltage to drop below the Technical Specification limit of 129VDC without being detected. Currently, there are no alarms /

annunciators available to alert the Control Room Operators of this condition.

Condition Reports 95 14210 and 96-1281 were previously generated for this condition.

During a walkdown of the Class IE 125VDC System and the instruments on Control Panel (CP) 003 in the Control Room, the following conditions were identified:

The Class IE 125VDC Battery Charger voltage output gauges were color banded with the yellow band beginning (and decreasing) at 129VDC (Unit 1) and 118VDC (Unit 2). The Technical Specification minimum voltage is 129VDC. Having green bands for instruments in ranges that violate Technical Specification minimums is a potential human factors issue. Condition Report 96-12943 was generated for this condition.

The vertical gauges which measure Class IE battery current on cit 03 on the main control board are scaled 1-1000 amperes (in 100 amp intervals) and there is no indication on the gauges whether the batteries are charging or discharging. The normal switchboard current draw is less than 100 amperes per channel. Consideration should be given to adding charge / discharge indication to the gauges. Condition Report 96-12943 was generated for this condition.

Page 14

Condensate / Condensate Polishing Systems A walkdown of the Unit 1 Condensate (CD) / Condensate Polishing (CP) Systems was performed. The walkdown focused on the following areas: 1) 29' CP Operator Control Room; 2) 29' Condensate Polishing Pit including the Resin Regen and Storage Tanks; 3) 29' Cation and Mixed Bed Polisher Pits; 4) Condensate Pumps; and 5) the 55' Condenser Area.

The results of this inspection showed that the general housekeeping in these areas met station standards. De equipment showed little degradation due to environmental conditions. Those items found leaking had compensatory actions by Operations (i.e. drip funnels or shields) to mitigate damage to adjacent equipment. The CP Sump showed extremely low levels of water intrusion due to inventory loss from the CP System. His would indicate that I low levels of fluid are being sent to the Low Total Dissolved Solids Tank which is a significant cost savings to the site.

During the walkdown of the CP Resin Regen and Storage Tank Pit,it was noted that numerous components located near the floor or adjacent to sampling points were showing evidence of corrosion. This concern was expressed to the System Engineer who indicated that Condition Report 96-I 4982 had already addressed this issue and is scheduled for work in 1997.

The walkdown of the TGB-55' around the Main Condenser showed excellent I housekeeping with material ceridition issues properly identified.

e The walkdown of the Condensate Pumps was performed. Pumps 11 and 13 I were in service and 12 was in standby. During the walkdown, it was noted that a packing leak was present on Pump 13. Condition Report 96-13165 was generated for this condition. Additionally, it was discovered that the Closed Loop Cooling piping to the upper bearing oil reservoir for Pump 12 I was improperly supported. Both the supply and return cooling lines had pipe support clamps attached to the pipe without any evidence of the remaining hardware. Condition Report 96-13130 was generated for this condition.

The overall results of the walkdown for both the CD and CP Systems identified that system condition has significantly improved over the past two years and many deficiencies have been corrected. This is attributed to the I increased level of effort by Maintenance, Operations, and Systems Engineering to assure the reliability of these systems. In October, a CP

" Regeneration" was performed in the automatic mode for the first time in I several years. This is indicative of the overall improvement in the system.

While the quality of the Systems Engineering walkdowns and the associated reports met the p requirements of the System Engineering Guideline, consideration should be given to the following L enhancements:

Assemble teams to assist in periodic System Engineering walkdowns. Currently, the

( same engineer performs the walkdown and becomes familiar with the system material condition and operational characteristics. This may lead the engineer to develop

" tunnel vision" and a tendency to overlook minor hardware deficiencies similar to those discovered during this self-assessment. A team with Operations and Maintenance personnel led by the Systems Engineer may improve the quality of the Page 15

walkdown by offering different perspectives and increase the communication between Engineering, Maintenance, and Operations on a routine basis.

Expand the use of the walkdown reports. Currently, the walkdown reports are provided to the System Engineer's supervisor and manager and are normally discussed with on-shift Operations personnel. These reports could be a more effective tool to provide management focus on system material condition issues if their distribution included Operations, Maintenance, and Work Control. Consideration should be given to making these reports available on the computer (LAN) similar to the Engineering Quarterly Report.

Reinforce management's expectation for participating in System Engineering walkdowns. Supervisors are expected to do walkdowns with System Engineers on a weekly basis. Division Managers are expected to do monthly walkdowns with System Engineers. Some supervisors do not always meet the expectation for performing walkdowns.

2. System Health Reports Several System Health Reports were reviewed. System Health Reports are produced once a year and are a snapshot of the system with information about the past year's activities. 'Ihe reports are not updated and may not represent the current system condition. However, based on a review of condition reports, work orders, walkdown reports and system health reports from various systems, the System Engineers appear to be proactive in championing System Health. The following is a summary of the reviews:

Discussed System Health Report for Essential Chilled Water System with the System Engineer. The current issue is from December,1995. The next health report is due in December,1996, and will be published January,1997. It was observed that the System Health Report identified the need to replace the oil heaters on 150 ton Chillers to prevent overheating of oil. The System Walkdown Inspection Report dated September 24,1996 indicated all heaters had been replaced. It was also identified through the System Health Report and Walkdown Inspection Reports that the Chillers should be operated on a rotating basis (equalize the run time between the chillers to increase their reliability). The System Engineer stated that a rotation schedule was developed; however, it has not yet been implemented.

The System Health Reports for Class IE 125VDC / Class IE 120VAC Vital Systems were reviewed. These reports were prepared in the standard format and were well written, concise, and accurate.

The System Health Reports for the Condensate / Condensate Polishing Systems were i

reviewed. The reports accurately reflected the system condition at the time the reports were generated. Both systems were classified as " Good"; however, no clear definition p of" Good" was found. Condition Report 96-15668 was generated for this condition.

[ Also, both reports reviewed were written prior to implementation of the Maintenance Rule. System Health Reports written after July,1996 should contain references to system status relative to Maintenance Rule Performance Criteria or Goals. The

( inclusion of Maintenance Rule information will insure objectivity and provide precise definition as to what constitutes a system in acceptable condition.

Page 16

While the quality of the Systems Engineering Health Reports met the requirements of the System l Engineering Guideline, the following areas for improvement have been identified:

I

• Expand the use of the System Health Reports. Currently, the health reports are provided to the System Engineer's supervisor and managers and are discussed in the Daily Communication & Teamwork meeting on a weekly basis. %ese reports could be a more effective tool to provide management focus on system material condition I issues if their distribution included Operations, Maintenance, and Work Control.

Since the report is a useful tool for communicating system health, consideration should be given to providing the reports more frequently (i.e. quarterly vice annually)

I and making these reports available on the computer (LAN) similar to the Engineering Monthly Report.

e Increased management attention and follow through for improvement activities I identified in the health reports. For example, the Essential Chilled Water System Engineer identified the need to operate the chillers on a rotating basis to improve their reliability (seals dry out when not operating allowing air in leakage which causes I problems during startup).Though a rotation schedule was developed by the System Engineer, it has not yet been implemented.

Condition Report 96-15668 has been generated to evaluate the above enhancements.

3. System Performance Trending The Systems Engineering Performance Trending Program is a strength. His strength is characterized by:

• System Engineer review of Inservice Test Data on CH Pump 1I A discovered as-found vibration data above alert range. Use of trend information enabled the System Engineer to identify an error on a previously performed Inservice Test resulting in an Licensing Event Report (Reference Condition Report 96-5146 & LER l-96-002).

• Trending Condensate Polishing System performance includes maintenance trends and steam generator blowdown conductivity. Trending Condensate System performance I includes pump oil sample analysis, pump vibration analysis, and maintenance trends.

System Engineer review of maintenance trends, in conjunction with equipment history, identified a history of failures associated with the controllers for the Steam Generator Feed Pumps. This prompted an evaluation of digital controllers to replace the current I analog controllers.

The System Engineer for the Class IE 125VDC System trends parameters in I accordance with the vendor recommendations and IEEE-450. In addition, the System Monitoring Program already meets the proposed guidelines being developed by EPRI.

Trending information includes data obtained from performance tests, individual cell voltages, connection resistance, and specific gravity, r

L While the Trending Program is a strength, the following enhancement should be considered:

Consider combining the trend data for similar safety and non-safety related

( components as a method to identify common mode failures. For example, a review identified I i open Service Requests on chillers related to lube oil pressure trips. Of the il lobe oil pressure trips,10 were on similar units. Three were on safety related chillers and seven were on non-safety related chillers. Similar to industry operating Page 17

experience, this is additional in-house operating experience that is readily available.

Condition Report 96-15668 has been generated to evaluate the above enhancements.

4. System Expert Program The System Expert Prcgram focuses on increasing the System Engineer's skill and background through specialized training such as root cause seminars, industry seminars, participation on special committees, and by participating in assistance visits to other nuclear facilities. While the System Expert Plans provide standards for levels of knowledge and expertise of the Systems Engineers, areas for improvement were identified. The areas for improvement are:

Clarify management expectations with respect to completing the System Expert Plans.

Interviews with System Engineers indicated some confusion on when individual plans need to be completed and how the plans will be closed out (report, presentation, or oral boards). Plan completion dates varied from 1996 through 1999. One Engineer stated that all of the actions for his 1996 System Expert Plan have been completed, but

_ are not signed off. Ile added that the presentation at the end of plan was awaiting management decision.

Clarify management expectations with respect to the System Expert Plans self-study goal. The System Expert Plans require the System Engineer spend four hours of self-7 study per week. Several System Engineers indicated that due to time and workload constraints, it is difficult to spend four hours per week on qualification duties as expected by management. A Systems Engineering Supervisor; however, indicated the four hours per week self-study should not be difficult to rneet since meetings frequently provide the intended self-study of training. In addition, seminars and other off-site participation should also be counted as training against the individual's plan.

Condition Report 96-13194 was generated for these conditions.

5. Systems Engineering Work Load Management Engineering work management has improved. Workload is managed by using the Corrective Action Program (CAP) database in conjunction with Schedule Publisher to assign, track, and schedule work. The work is prioritized depending upon its significance (i.e. SCAQ or CAQ-S versus CNAQ). In addition, supervisors and managers monitor their workload by using a series of plots, trending open items and closure performance on a regular basis. Sometimes the workload is shared with other sections to maintain stability. This allows Systems Engineering to manage their workload by shifting resources. The Nuclear Steam Supply System section has been heavily loaded with recent plant issues, so the Balance Of Plant section was assigned the review of out-of-tolerance notices for Technical Specification instrumentation.

Page 18 l

i

[

DESIGN ENGINEERING

1. Configuration Management The Configuration Management Program is an area for improvement. Discrepancies were identified in setpoint control, scaling, calculations, Design Basis Documents, the UFSAR, and the Master Equipment Database. The following is a summary of discrepancies:

Instrument Setpoint Index Reviews of the Essential Chilled Water, Class IE 125VDC, and Condensate / Condensate Polishing Instrument and Electrical Setpoint Indexes were performed as part of the self-assessment. These reviews identified incorrect setpoint values in the Setpoint Index, inaccuracies and incompleteness of setpoint basis references in the Electrical Setpoint Databases, and overly restrictive tolerances in the Instrument Setpoint Document. He following is a summary of those reviews:

A sample of 15 Essential Chilled Water System instruments, with safety related and non.

safety related setpoints, was selected and the individual instrument scaling documents were reviewed against the setpoint list. The following discrepancies were identified:

AICil-PSL-9474A - Setpoint List specifies a required reset value. He Unit I scaling document specifies "N/A" The Unit 2 scaling document specifies the correct reset value. Condition Report 96-12799 was generated for this condition.

B 1Cil-TSL-9510 - Setpoint Index lists 30* F (decreasing) as the setpoint.

The scaling document for this switch requires a 32.5" F setpoint. Condition Report 96-12796 was generated for this condition.

N ICII-PSII-9612 (2)- Setpoint Index lists 24 PSIG (decreasing) setpoint.

The scaling document requires a setpoint of 30 PSIG. Condition Report 96-12801 was generated for this condition.

As a result of the discrepancies identified during the self-assessment, Design Engineering is conducting a review of the Scaling Program. Condition Report 96-13152 was generated for this condition.

Electrical Setpoint Index A review of the Electrical Setpoint Index for setpoints applicable for the Class IE 125VDC (DJ) System was performed against the design requirements contained in Electrical Calculation EC-5033, Class 1E 125V, Non-Class IE 48V,125V & 250VDC Breaker & Relay Settings. This review identified the Electrical Setpoint Index database does not list or reference Setpoint Basis Calculation EC-5033 or any of the calculation inputs containing setpoint bases for the following setpoints:

DC Undervoltage Switchboard Relay Switchboard Time Delay Relay Charger #1 AC Undervoltage Relay Charger #1 Ground Sensor Charger #1 DC Undervoltage Relay Page 19

{

Charger #1 Charger Failure Relay

( Charger #1 DC Overvoltage Relay DC Overvoltage Switchboard Relay

( All of the above listed setpoint values were in agreement with Electrical Calculation EC-

[ 5033; however, the following discrepancies were also identified:

The review associated with the two DC Overvoltage Relay setpoints also f identified the notes section is punctuated differently for the same note associated with each setpoint. This lends to confusion as to whether the Design Basis Document (DBD)is referenced as a setpoint basis or as a

[ reference for Measuring and Test Equipment (M&TE) accuracy. In either i case, the DBD does not contain setpoint values or M&TE accuracy values associated with these setpoints. Condition Report 96-13347 was generated for these conditions.

The maximum tolerance listed in the Electrical Setpoint Index for battery charger #1 DC Undervoltage Relay is listed as 118.7V. The value should be 118.17V for a ll7V optimum setpoint +/- 1%. This same condition was also discovered earlier by the System Engineer and is documented on Condition Report 96-13014.

f The Electrical Setpoint Index Database has improved. Interviews with Maintenance personnel indicate including more of the non-safety related setpoints and software enhancements would provide additional benefit to the station. These enhancements are identified in Condition Reports 95-9433,96-1632, and 96-1633.

f Scaling The Scaling Program provides an accurate translation of plant system parameters into calibration data. Interviews with Work Control personnelindicate the Scaling Database has improved. It was noted the database is for single instruments and hard co; y data sheets are required for loop scaling.

A review of six CD System scaling sheets with setpoints, and a comparison of the scaling to the Instrument Setpoint Index requirements, found no discrepancies. The scaling correctly implemented installation correction factors. A review of the associated computer generated calibration data sheets and the required min / max data, identified

} these documents contained the correct values for the assigned scaling tolerances. 'Ihree CD System loop scaling packages were reviewed and all of these packages were in accordance with the Station's prescribed loop scaling guidelines. The following issues were identified during the scaling reviews:

=

The current practice for Air Operated Valve scaling data sheets is to specify actual valve performance data for benchset values rather than the manufacturer's specification. This results in database update each time a field adjustment is made. Design Engineering continually revises the values listed in scaling after maintenance is performed to accommodate the Maintenance Department valve calibration accuracy requirements. Design Engineering should list the manufacturer specified data in the scaling documents and Maintenance should have to adjust their calibration program requirements accordingly. These revisions occur quite frequently and are Page 20

i resource intensive. It also appears that many scaling sheets specify benchset requirements when they are not necessary or supplied by the manufacturer.

Switch NICD-LSL-7004 provides a computer and Control Room annunciator alarm for Low Condenser Hotwell Level. His switch was correctly scaled per the Setpoint Index requirements with a required setpoint I tolerance of +/ .6% which equated to a field setting tolerance per the scaling sheet of +/- 0.161 inches. Considering the size of the liotwell, the tolerance prescribed by the Serpoint Index appears to be overly restrictive.

Re tight tolerance issues associated with NICD-LSL-7004 prompted a review of the Preventive Maintenance (PM) requirements for this switch to maintain the required accuracy. Preventive maintenance task 95002436 I provides the maintenance requirements for the level switch and requires a functional test every three years, but no calibration. The functional test actuates the switch with a simulated process and provides a very thorough inspection, however, considering the accuracy requirements described in the I setpoint index, a functional test every three years does not appear adequate to maintain a mechanical switch accuracy of +/ .161 inches. Condition Report 96-13209 was generated for this condition.

Calculations Reviews of the Essential Chilled Water and the Class IE 125VDC System design calculations were performed. While these reviews did not identify programmatic problems, the following discrepancies were identified:

Mechanical Calculation MC-6429 (page 35) provides the conclusion that minimum ECW temperature is 40* F. This is predicated on one unit operating and " maximum effort to add load to the ECP." Procedures I OPOP02-Cil-0001, Essential Chilled Water System; OPOP02-EW-0001, Essential Cooling Water Operations; OPOP01-ZO-00% Extreme Cold Weather Guidelines; and OPGP03-ZV-0001, Severe Weather Plan; do not I address this requirement. Condition Report 96-12860 was generated for this condition.

A process is currently in place to help prevent a reoccurrence of this I situation. The Engineering Calculation Procedure, OEP-3.07Q, Revision 4, Change Notice 2, requires that assumptions involving new, assumed, operator actions be approved by the Manager, Operations Support, and documented.

I The date of this procedure change is after the revision of this calculation.

e Mechanical Calculation MC-6412 (page 15) nnolies that a 30 minute operator action is required to shut down one train of Essential Chilled Water I is required post-LOCA. This requirement is reflected in the Essential Chilled Water Operating Procedure, OPOP02-CH-0001. This requirement is not included in the Emergency Operating Procedure. Condition Report 96-12792 I was generated for this condition.

Mecharical Calculation MC-6429 (page 36) paragraph "F" states that it is unlikely a LOCA would require resetting chiller flow. This seems to contradict the above condition concerning operator actions post-LOCA.

Condition Report 96-12860 was generated for this condition.

Page 21

~

e Mechanical Calculation MC-5233 Essential Chilled Water System Network Analysis (page 4) Data Input #1 states all flow requirements used in the Network Analysis were from MC-5232. Mechanical Calculation MC-5232 was superseded by MC-6412 in January of 1994. It does not appear that i

MC-5233 was revised to identify any impacts as a result of MC-6412.

Condition Report 96-12996 was generated for this condition.

• Mechanical Calculation MC-6412 (page 114) states "ESF pump room coolers [should] not exceed the 62.5 gpm design flow" The 62.5 gpm flow I was for the sensitivity analysis. The calculation concluded that the flow should be restricted to 37-43 gpm. 'Ihese values were included in Modifications 93(M9 and 93050 (see note on page 10 of calculation) and I were inadvertently deleted in Revision 1 of MC-6412. Condition Report 96-12858 was generated for this condition.

e During a review of the closure documentation for Quality Assurance Safety I System Functional Assessment,93-03, r. Essentia! CWiled Water, it was noted that Mechanical Calculations MC-5232, MC-5274, and MC-5275 should have been superseded. A review of the closing document, Station i Problem Report 930910, and the calculations indicate these calculations have not been superseded. Condition Report 96-12763 was generated for this condition.

Mechanical Calculation MC-6412 was reviewed for its relationship to earlier, still active, Mechanical Calculations MC-6429 and MC-5233. Mechanical Calculation MC-6429, Cold Weather Operation, is still valid. Mechanical I Calculation MC-5233, the Essential Chilled Water Network Analysis used to size the pumps and motors is also still valid; however, it was last revised in May of 1986. The design basis of Essential Chilled Water appears to be spread through several calculations and several scenarios in those I calculations. Consideration should be given to consolidating the design basis calculation for Essential Chilled Water into one document for ease of understanding. Condition Report 96-12858 was generated for this condition.

. Electrical Calculation EC-5008 (Class lE Battery, Battery Charger, and Inverter Sizing) provides a detailed description of how the calculation results I are translated to the values in UFSAR Table 8.3-6. However, the Channe! I data presented in DCN 96-2365 written against EC-5008 for Channel I does not appear to agree with the results presented on Table 8.3-6 in CN-1961.

Condition Report 96-12922 was generated for this condition.

I ,

I I

Page 22 a

)

Design liasis Documents The Design Basis Documents (DBDs) are a useful tool and a valuable source of information. However, discrepancies were identified in management's expectations on the use of DBDs. Some DBDs are not reflective of current design, and some DBDs have a significant number of unincorporated amendments. He following is a summary of discrepancies:

Management's expectations on the use of the Design Basis Documents as a reference or source document are unclear.

Management expects the DBDs be used as references or roadmaps and the engineer to use the source documents to determine actual design requirements. Interviews with engineers indicated this expectation was unclear. Some engineers indicated values could be used directly from the l

DBDs while others understood it was a reference or historical document to help locate design information.

e in addition, the Design Basis Documents supersede the Design Criteria and System Design Descriptions (SDD); however, the Design Criteria and SDDs I have not been clearly designated as being superseded. Condition Report 96-13043 was generated for this condition.

I Some Design Basis Documents do not reflect the current plant design or configuration.

For example:

Re Electrical Auxiliary Building HVAC DBD contains 11 outstanding I change documents. Two of the change documents were for upgrading to the Digital Toxic Gas Monitors. The Toxic Gas Monitors have been removed from the plant, yet no change document is posted against the DBD to I document the removal. Condition Report 96-15668 was generated for this condition.

I The Essential Chilled Water DBD indicates the system can be operated from the Auxiliary Shutdown Panel. The system cannot be operated from the Auxiliary Shutdown Panel. Condition Report 96-12668 was generated for this condition.

Some Design Basis Documents have a significant number of unincorporated amendments.

For example:

The Emergency Diesel Generator DBD has forty-five outstanding change documents posted against it.

Re Condensate DBD has eight outstanding change documents posted against it.

I

• The Component Cooling Water DBD contains Revision 1, dated 1991, which is still not incorporated into the DBD itself. It is kept separate as Rev.1 in front of the DBD book.

Condition Report 96-13013 v.as genciated for these conditions, Page 23

[

UFSAR Review A review of the UFSAR was performed for the Essential Chilled Water, Class IE 125VDC, and Condensate / Condensate Polishing Systems. It is important to note that

[ only minor discrepancies between the UFSAR and operating procedures were identified.

1 The following discrepancies were identified:

• Review of Operating Procedure OPOP02-CH-0001 for Essential Chill Water

{ for conformance with UFSAR. Procedure steps 4.25 - 4.31 appear to impose actions in response to accident conditions. The POP 02 normal operating procedures will be relatively low priority during an accident and the actions may not be taken. Condition Report 96-12792 was generated for this I condition.

The UFSAR indicates the Essential Chilled Water System can be operated f from the Auxiliary Shutdown Panel. The system cannot be operated from the Auxiliary Shutdown Panel. Condition Report 96-12688 was generated for this condition.

A comparison of the UFSAR to Plant Operating Procedures for Class 1E 125VDC and Class IE 120VAC Systems was made. Editorial errors were identified in UFSAR Sections 8.3.2.1.1 and 10A.2.4 on page 10A-8 for the Class IE 125V System. Both state the Class 1E 125V Battery Buses are energized by bojh chargers. This statement is contrary to actual plant operation and the remainder of the UFSAR. Also, Section 1.2.2.7.2 states the f Class !E 125VDC Systems consist of an inverter, battery, and battery chargers. Channels 1 & IV have two inverters each. Condition Report 96-12998 was generated for this condition. In addition, UFSAR question

430.37N's response is incorrect and doesn't fully answer the question. The I first statement in the response states the Class lE Power System Battery Chargers are not capable of supplying power to DC loads unless connected to a battery. The charger is capable of supplying the DC loads with the battery breaker open. The remainder of the response does not fully answer the question. Condition Report 96-13003 was generated for this condition, e

A comparison of the UFSAR to Plant Operating and Plant Chemical Procedures for Condensate and Condensate Polishing Procedures including operation and chemicalinjection was made. No discrepancies were noted.

The ongoing Systems Engineering review of the UFSAR had already identified discrepancies in Tables 7.3-5 and 9.4 5.1, and Sections 9.2.6.1 and

9. ;.3.2 for Essential Chilled Water. Condition Report 96-8787 is tracking this action.

Page 24

L

[

Master Equipment Database / Master Parts List The condition of the Master Equipment Database / Master Parts List (MED/MPL) database has significantly improved. Design Er.gineering has been proactive in efforts to maintain the database current. Due to problems in being notified of field changes, Design Engineering implemented an automated system to update the MED/MPL in late June 1996. Master Parts List data changes are electronically transmitted via Automated Change Requests. This is done when Systems Engineering reviews the completed work package for equipment history and parts used before forwarding to Records Management.

While the addition of the automated updates is a significant improvement, additional enhancements with respect to the automated update process were identified:

a Consider establishing a threshold with regard to number of cpen MED/MPL items and length of time these items may be kept open. Performance should be monitored against these goals to avoid a backlog situation in the future.

Provide communication to the Maintenance Planners on the initiative to add parts information to the Master Parts List. Interviews with Planning personnel indicated some Planners were unaware of the automated update initiative.

Consider allowing Design Engineers access to the Master Equipment Database. Currently, access is restricted to those responsible for maintaining the MED. Design Engineers, particularly the Technical Support Engineers, must use the electronic change request process or generate a Design Change l Package to update the MED.

Condition Report 96-13343 was generated for these conditions.

2. Design Change Program The Design Change Program is effective. Positive aspects of the Design Change Program and modification process are:

The Plant Change Committee provides excellent program management oversight and positive feedback to engineers.

Modifications are effectively planned, budgeted, and implemented through the two and five year plans. Visibility of the program is provided through the Daily Communication & Teamwork Meetings.

The modification process is sound. Design Change Procedures OPGPO4-ZE-0309, Design Change Package; OPGPN-ZE-0310, Plant Modifications; OPGP%ZE-0311, Design Change Functional Test Implementation; and OPGPO4-ZE-0312, Design Change Implementation, provide a comprehensive, detailed process for implementing design changes.

Plant Modifications & Project Implementation (PMPI) personnel indicated that Design Engineering personnel are very supportive of the implementation effort and in some cases go on shift to support field work. Design problems are quickly addressed, i

Page 25

f

, While the modification process is effective, the following inconsistencies were identified:

. The level of detail contained in Design Change Packages (DCPs) or modification packages is not always suitable for all users. Interviews with PMPI personnel indicate Engineering products provide sufficient detail to support planning. In contrast, Maintenance Planning personnel indicate the Engineering products do not contain the level of detail necessary to support planning. For example, the RCP Bearing Oil Lift Pump wiring change, DCP 96-965-3, did not provide a layout of the conduit runs, the grounding details were not shown, and the post-modification test was listed only as a functional test. PMPI utilizes Field Engineers to plan their MOD installation packages. Rese Field Engineers are construction-type individuals familiar with the generic design implementation specification requirements (construction specifications) used to plan and install MODS. Maintenance Planners are preventive and corrective maintenance work order instruction writers who are less familiar with the use of construction specifications. Maintenance Planners attend the same technical training as the craft supervisors. Some internal training on the installation of anchor bolts, conduits and supports, etc. has been done, but Maintenance Planners don't normally plan modification packages so it is difficult for them to maintain their proficiency. In addition, the PMP1 Engineers work with the Design Engineers throughout the design phase whereas the Maintenance Planners often start " cold" with the package (that is, when the design is complete). Condition Report 96-13190 was generated for this condition.

• The criteria for minor changes provided in procedure, OPGPO4-ZA-0002, Condition Report Engineering Evaluation Program, has not always been complied with.

Examples of problems are:

i A Con <Jition Report Engineering Evaluation was used to implement programmable logic controllers within the Condensate Polishing System. De design screening did not formally identify required operational procedure changes or operator training requirements.

Contrary to the minor change program guidelines and criteria, minor changes have been implemented w hich require special resources or budget allocation, and have changed the plant configuration which requires upgrades to the simulator.

In some cases, design change packages have been implemented (field work

( complee), but identified changes to operating procedures or ECO dctabases

/ took se veral months to complete or are still outstanding.

These problems were discussed at the October 22,1996 Plant Change Committee meeting. De Plant Change Committee requested a presentation by Design Engineering concerning the minor change process. Condition Report 96-13216 was generated for these conditions.

Station Management expectations for work package closure following field work completion are not clear. Inconsistencies in driving work packages to Status "65" w hich triggers changes to the design documents and operating procedures have resulted in systems returned to service without the appropriate documents updated.

For example, the Unit 1 installation of DCP 95-3483 is complete, the system returned to service, and Design Documents have been updated to reflect the modification. In Unit 2 the installation is also complete and the system returned to service; however, the work package i still in closure (less than status 65) so the design documents and operating proceduru have not been updated. The System Engineer verified the Key l

l

Page 26 l

l

Drawings in the Control Room have been " Red Lined" per the procedure. Condition Report 9613220 was generated for this condition.

3. Safety Evaluations The Safety Evaluation (50.59) Program is sound. Increased attention to detail in the following areas would improve the quality of the 50.59 products:

The use of a procedural allowance for a " trivial" change is not clearly understood by some engineers. For example, Modification 91-051 to add a refrigerant clean up kit was determined to be a trivial change. Since the change is being done to safety related equipment, this change does not meet the definition of trivial. Condition Report 96-12921 was generated for this condition.

Increased anention to detail in the following areas would improve the quality of the 50.59 products. Some 50.59 screening forms are inadequate as stand alone documents, indicate incorrect revisions, and providejustifications which are inadequate or con:radictory. For example, the Preliminary and Final Screening Forms for MOD 87030 were reviewed. The Description of Change on Preliminary Screening states the change is to " Replace the transformers in Class-lE Channel I and IV battery chargers" The Technical Justification on the Final Screening states " Installing the upgraded transformers in the Channels I and IV battery chargers will provide capability to operate with only one charger connected to each of Channels I and IV".

Two later revisions to the Screening Form were identified. The first revision, still marked as Rev. 0, was associated with MDCNs 87030-21 through 26 and a revised Design Summary Seuion. This revision did not revise the Change Description. He second revision, marked N/A, is associated with MDCN 87030-27 which changes the Modification Design Summary. This revision to the Screening Form provides

( justification for approval based on the original 50.59 and the MOD Package, which

[ when reviewed, clearly excluded the intent of MDCN 87030-27. In addition, the original and first revision has question (1) checked "yes" which identifies a Technical Specification change is required; however, neither 50.59 identifies what Technical Specification change is required. Condition Report 96-13039 was generated for these conditions.

4. Design Engineering Work Load Management De Design Engineering Department Work Management Program has improved. Workload is managed by using the Corrective Action Program (CAP) database in conjunction with Schedule Publisher to assign and schedule work. The methodology of using the CAP database and Schedule Publisher to track individual and group workload is an effective tool and well received by the engineers. The work is prioritized depending upon its level (i.e. SCAQ or CAQ-S versus CNAQ).

Supervisors run a report at least once or twice a week to ascertain their workload. The Supervisors review trends (graphs) on a weekly basis. These are open actions, open conditions, actions / tasks received versus action / tasks closed, Condition Report extensions, etc. This provides a summary of the overall workload as well as an indication if any kind of backlog may be developing.

Managing the work in this manner has enabled Design Engineering to focus on long-term issues and improved management of the Engineering backlog. Tools in place such as the Plant Change

[ Committee, the Two and Five Year Modification Plan, the Significant Issues List, and other

( presentations provided in the Daily Communication & Teamwork Meeting help to balance Engineering's support.

Page 27

ENGINEERING PROGRAMS l

1. Use of Industry and In-house Operating Experience The evaluation and use of industry and in-house operating experience was reviewed. This review identified that the Industry Events Analysis (IEA) Group effectively screens, evaluates, and I disseminates industry events. Positive aspects of the program are:

e Well executed programmatic controls. Procedure OPGP03-ZX-0013," Industry I Events Analysis", provides a comprehensive process for the initial screening of new source documents, evaluating those applicable to S'IP, and follow-up for any corrective actions required. A Condition Report tracks each item through the whole process. The group's goals for the review process is to have all items screened in 7 I days, evaluated in 55 days with less than 5% overdue orrective actions. A review of the open Plant Impact Evaluations (PIE) and Industry Events Analysis (IEA) action list indicates a reasonable backlog of open items. Three PIES are still open with I source documents dated back to 1992 and earlier, but good reasons exist for each of these open PIES. All other open PIES are evaluating source documents from 1995 to present.

I =

Good communication with other STP groups. Feedback from several System Engineers indicated they were getting the necessary industry operating experience.

They stated they regularly received operating experience information from the IEA I group or other members of plant management and have provided input into various evaluations.

Timely and thorough responses to industry issues. For example, the response to Generic Letter 96-06. " Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Conditions"; Westinghouse NSAL 96-03,

" Containment Fan Cooler Operation During a Design Basis Accident"; and I Information Notice 96-49,' Thermally Induced Pressurization of Nuclear Power l

Facility Piping"is being developed. The waterhammer issue associated with the Reactor Containment Fan Coolers and Component Cooling Water System has been l analyzed and is not a problem at STP. The second issue related to thermally induced overpressurization of the isolated water filled piping sections (primarily piping)is presently being analyzed. Condition Report Engineering Evaluation 96 9710-7 was lf written to address the operability issue. In addition, the evaluation pc.iarmed by the IEA group of Information Notice 96-46,"Zine Plating of Hardened Metal Parts and Removal of Protective Coatings In Refurbished Circuit Breakers" was more than adequate to address this Notice. No required actions resulted from this evaluation.

System Engineer knowledge and use of in-house and industry operating experiences is good. Knowledge of in-house operating experience was demonstrated in discussions with various System Engineers about their system. For example, the CCW System Engineer was very knowledgeable about the above noted issue though he was not directly involved in the response. The HVAC System Engineer showed good awareness ofindustry issues, specifically an Operating Experience Report on airside performance testing of air cooling units, Generic Letter 96-06, and HVAC Utility Group (HUG) meetings.

Page 28

l e

The IEA Group Self Assessment performed in 1996 is a strength. Nine recommendations for improvement were made. He self assessment action items are identified in Condition Report 96-4008.

While the Industry and In-House Operating Experience Program is effective, the following enhancement was identified:

Consider summarizing key industry issues daily and forwarding to appropriate station personnel. He IF.A group currently disseminates INPO Nuclear Network information daily via a download to the Bulletin Board for use by all station personnel. A recent survey indicated limited use of the Bulletin Board by station personnel. Condition Report 96-15668 was generated for this condition.

2. Probabilistic Safety Assessment Program he Probabilistic Safety Assessment (PSA) Program was reviewed. The PSA is used to perform On-line Maintenance Risk profiles, Outage Shutdown Risk Management, justification for License Amendment Requests and Continued Operation, and signincane. : valuation of LERs. While the basic program is sound, s:veral enhancements were identified:

e Values from the Design Basis Documents (DBDs) have been used throughout the PSA as the design basis. Engineering / Risk and Reliability Analysis should evaluate the acceptability of using the DBD information without confirmation. (Ref. Condition Report 96-13013) e Procedure OPGPM-ZA-06N, Probabilistic Safety Assessment (PSA) Program, does not provide guidance for the review of basic assumptions or success criteria used in the PS A analysis by groups other than the Risk and Reliability Analysis group, such as Engineering or Operations. For example, the following discrepancies were identified with respect to the Essential Chilled Water PSA Package:

Section 5.0 of the PSA Package utilizes Design Engineering Mechanical Calculation MC-6412 as the basis; however, this was not formally reviewed by Design Engineering. Condition Report 96-13214 was generated for this condition.

The PSA Package does not account for operator actions to regulate flow to the Essential Chillers during cold weather operation. Condition Report 96-12919 was generated for this condition.

Procedure OPSP03-CH-0004, Section 11.2 states that Essential Cooling Water flow through the air handling units will not affect availability. However, steps 5.3.7 and 5.3.8 of OPSP03-CH-0004 do affect flow through air handling units.

Condition Report 96-12918 was generated for this condition.

Page 29

L l

e Procedure OPGP04-ZA-06N, Probabilistic Safety Assessment (PSA) Program, requires the Risk and Reliability Analysis group to identify all PSA changes once an operating cycle, after the Unit I refueling outages. Changes could be made during a Unit 2 outage to either plant, or its procedures which would make the PSA non-conservative for that unit. Consideration should be given to more formally account for

f. potential differences between the units. Condition Report 96-13214 was generated for this condition.

Procedure OPGPN-ZA-0604, Probabilistic Safety Assessmem (PS A) Program, does not address significant temporary changes, such as temporary modifications, in either the PSA or the on.line maintenance tool, RASCAL. Consider establishing a process for addressing temporary conditions, such temporary modifications in the PSA model.

Condition Report 96-13214 was generated for this condition.

3. Preventive Maintenance The Preventive Maintenance (PM) Program is sound. Ris review identified the PM Optimization (consolidation) Program was effective at reducing the number of PM tasks and streamlining PM implementation. The PMs reviewed included:

e Preventive Maintenance task 96000644 is a consolidated PM to perform multi-f discipline maintenance on the Unit 2, Train B (22B) Essential Chiller. This PM consolidated a number of other PMs into one activity. The scope includes

[ calibrations, electrical device inspections including wiring, component cleaning, oil I system maintenance, inspection and cleaning of MOV's, testing of valves and oil heaters, and allows for minor parts rework or replacement. The PM includes the source of the recommendations such as vendor recommendations, operating f experience, engineering judgment, QA findings, and design changes. The PM also lists commitments and justifications.

. Reviewed PMs 93002770,93002774,94004512,94004543,94004544, and 94004546 for comments concerning the appropriate Technical Specification applicability. All comments contained the proper Technical Specification and source document references. I

• A review of PM 93002770 was performed for the 125 VAC VitalInverter. This review included Station Problem Report (SPR) 910252 which identified commitments f to test Class IE Inverter Automatic Shutdown Functions based on the findings of the NRC Inspection Team of 1991. Plant Procedure OPEP07-VA-0002 and PM 93002770 were generated. Doth of these documents were concise and fully bound the

[ testing methodology established in SPR 910252. During the performance of PM i

93002770 in May of 1996, the DC Low Voltage Set Alarm was found out-of-tolerance. Systems Engineering evaluated this condition per CREE 96-6674-1 as acceptable smce the shutdown setpoint was much lower than the alarm setpoint. He analysis was well explained and properly justified.

Page 30

nis review also identified increased attention to detail would improve the qtality of the program.

For example:

Preventive Maintenance task 95002436 is an optimized PM and provides a very good analysis of the instrument function, captures industry recommendations and station

[ operating history, and provides documented justification for the PM requirements.

However, level switch NICD-LSL-7004 is listed in OPGP-ZM-0016 which

" .. delineates programmatic controls for the calibration and status verification / notification of installed permanent plant instrumentation to ensure accuracies are maintained"(the instruments listed in OPGP03-ZM-0016 have calibration frequency requirements according to classification which for NICL-LSL-7004 would be every 156 weeks). The PM group considered the prescribed functional test met the ZM-0016 requirement for calibration. A functional test does not appear to demonstrate the r aintenance of accuracy. Condition Report 96-13209 was generated for this condition.

• Engineering iesponse to PM feedback requests. Preventive Maintenance feedbacks are used to identify problems or enhancements to PM tasks. Maintenance Planning identified approximately 180 [ Condensate Polishing] PMa have been awaiting Engineering response for approximately six months. These PMs are with Engineering to be deleted. The priority of deleting these PMs is being evaluated by Engineering.

Scope statements of some of the optimized PMs were incorrect. For example, the scope of the Waste Monitoring Systet= Gould Pumps included coupling lubrication, yet the pumps use a c< upling that is not designed to be lubricated. This problem was identified on a Ph fu Jback.

4. Predictive Maintenance The Predictive Maintenance Program is a strength. This strength is characterized by:

Thermography Testing performed by Reliability Engineering is an excellent example of Predictive Maintenance. This testing program identified material degradation in l class and non-class components prior to the point of equipment faihires. Examples L are:

CR 96-69 Hot Spot on Terminal Connection discovered with Thermography CR 96-5203 Hot Spot on Fuse FU-4 discovered with Thermography CR 96-6475 Lugs at Cell 19 show Hot Spots with Thermography Additional examples of Engineering taking a proactive approach to facilitate improved system I reliability and increased maintenance efficiency are:

CR 96-10461 was generated to i.. 3dgate and develop a comprehensive listing of parts in inventory for all class and non-class inverters on site. This proactive initiative will reduce the time required for maintenance on these critical pieces of equipment.

Page 31 l

i

l e

CR 96-12116 was generated for engineering to evaluate the 20 year life of the NCX Class IE 125 VDC Cell Batteries. This evaluation will perform an in-depth analysis for extending the 20 year life and analyze the replacement batteries for end-of-life.

e CR 96-10383 was generated for engineering to evaluate current Technical I Specifications Limiting Condition for Operation requirements associated with the 125 VDC Inverters. The results of this investigation are still pending, but this is an example of Engineering challenging current requirements to contribute to a higher level of efliciency.

I 5. Maintenance Rule The Maintenance Rule Program for the Essential Chilled Water, Class IE 125VDC, and i Condensate / Condensate Polishing Systems is well structured. Positive aspects of the Maintenance Rule Program are:

e I Systems are appropriately scoped into the Maintenance Rule Program. For example, Condensate Polishing System is not in the Maintenance Rule Program; however, the Condensate System is in the program. The rationales provided by the Maintenance Rule Project Team were sound.

Maintenance Rule Functional Failure (MRFF) criteria is conservatively applied to equipment prcFems. For example, on the Essential Chilled Water (CH) System, it I was noted th e u ne of the MRFFs did not meet the Functional Failure criteria of preventing the system from performing as designed. MRFFs are conservatively classified at the component level.

System classification within the Maintenance Rule Program is rigorous. For example, the Essential Chilled Water (CH) System is currently classified as (a)(2). Performance l Criteria are established and utilize PSA calculations at the Train and Unit level.

l Condition Reports were reviewed to verify the appropriateness of the (a)(2) classification. The couw of potential MRFFs listed in the Condition Reports supports the current classification.

The Maintenance Rule Program integrates well other existing plant programs such as Equipment History, Condition Reporting, and Equipment Reliability. These programs are utilized to suppo,t the Maintenance Rule Program.

The following enhancements to the Maintenance Rule Program were identified:

Clarify the requirements for system action plans. Several System Engineers were unclear as to the timeliness and requirements for developing and implementing action plans to return their systems from (a)(1) status to (a)(2). In addition, it as noted that I none of the Plans of Action involved the Maintenance Dep rtment craftsmen and supervisors. Interviews with Maintenance personnel indicaad their desis to be involved and contribute to component or system improvements plans.

I Page 32 f - - - - -

e Provide additional training on the purpose, requirements, and terminology of the Maintenance Rule Program. Interviews indicate some System Engineers do not fully understand the program requirements or terminology.

6. Performance Indicators The performance indicators used by Engineering were reviewed. Each of the departments has performance indicators which correspond to the Corrective Action Program database and are used exv - ively for work management. Engineering also maintains upper tier performance indicators.

Tu yper tier indicators could be er.hanced. For example:

j e Some performance indicators have annual goals which were exceeded early in 1996.

l As a result, these indicators have appeared " RED"(Needs Improvement) each month, despite satisfactory monthly performance. Indicators in this category include:

The goal for LERs due to human performance errors in Design and Systems Engineering was zero. This goal was exceeded in May of this year.

The Forced / Refueling Outage Overtime goal for Systems Engineering was I 20%. This goal was exceeded following IRE 06.

Some areas do not have performance indicators or goals, or the indica: ors do not include all of the appropriate data sources. For example:

There is no goal or performance indicator for issuing outage modifications prior to 2RE05 similar to the goal used for IRE 06.

There is no performa~ e indicator for tracking System Expert Qualification l status.

k An indicator tracking backlog of open MED revision is statused as " GREEN" although a backlog of 700 auto-generated changes exists. The current indicator does not account for auto-generated change requests.

Consider establishing a multi tier performance measure system similar to Maintenance.

The Maintenance Department Four-tier Performance Measure System of station, department, division, and work group or crew, provides measures which are closely tied to business plan goals and developmental appraisals. This system provides feedback to supervisor and workers on their performance compared to that of their peers. Condition Report 96-15658 was generated to evaluate these recommendations.

l 7.

l Engineering Assessments / Self Assessments and the ISEG Function i A review of the Engineering self-assessment guidance was performed. This review identified that

{ the Systems Engineering Guidelines and the Design Engineering Guidelines provide each division with an annual plan for the areas to be assessed, gives responsibilities, and guidance on how to conduct, report, and monitor the effectiveness of corrective actions following the assessment. This document is well written and mcorporates the guidance of INPO 90-15 Performance Objectives Page 33 I

for Operating Plants and SOER 92-1, Reducing Occurrences of Plant Events and Improving lluman Performance.

He Nuclear Safety Evaluation (NSE) group within the Quality Assurance Department is responsible for both the ISEG function and assessment of engineering activities. The following NSE assessments performed ir.1996 were reviewed:

Testability Evaluation (NSE 96-01) - Evaluated use ofjumper / lifted leads in testing e

Shutdown Risk Assessment and PRA (NSE 96-02)

SED Actions To Address Maintenance Rule Issues

. Station Troubleshooting Process Evaluation (NSE 96-03) e 10CFR50.59 Reviews (NSE 96-04) he NSE group has been effective in conducting performance-based assessment of the Engineering organization and other plant activities. De NSE Engineers, who are experienced, technically competent and familiar with nuclear plant operation, have demonstrated the ability to conduct independent, through and in-depth assessments. The evaluations listed above along with numerous other evaluations and surveillances meet the Technical Specification requirements for the ISEG functions. Also reviewed the monthly letters to the Nuclear Safety Evaluation Board and found to provide a good summary of the fm' dings of the NSE Group.

8. Training A limited review of the Engineering Training and Qualification Program was performed. The Engineering Administrative Services section maintains a database of the qualification cards for all active Engineers. This review identified that, with the exception of three individuals, the Systems, Design, and Nuclear Fuels & Analysis Engineers Qualifications, including General Employee Training (GET) and Engineering Support Program (ESP) training, were complete and current. He problems with the three individuals are:

One individual was overdue for completing his qualification card. This condition was previously identified by the Nuclear Fuels & Analysis department on Condition Report 96-2363.

Two individuals have not had any card assigned or otherwise noted as requiring a card (Note: These individuals were previously supervisors who are now in non-supervisory positions). Condition Report 96-13141 was generated for this condition.

I Additional information on Engineering Training Support Program is available in Condition Report 96-14492 which documents items identified during the Engineering Support Program l Accreditation Self Evaluation.

I I

L Pase 34 1

I

{

ATTACHMENT Condition Reports From The Engineering Self Assessment

I ) E E E E E E E E E" 4.

12/11/96 13:59:45 ALL CR'o FROM THE ENGINEERDC SELF ASSESSMENT CR NO. DESCRIPTION 1 96-12688 UFSAR SECTIONS 1.3-10 AND 7.5.6.1 AND THE ESSENTIAL CHILLED WATER DBD (5V369VB0120) 2.A.1.1.5 AND 3.A.1.1.5 ERRONEOUSLY INDICATE ABILITY 'It CONTROL ESSENTIAL CHILLED WATER FROM THE AUXILIARY SMITTDOW'8 PANEL. IN ADDITION, THE DBD 2. A.1.1.5 StJOGESTS THAT CH CAN BE OPERATED I4CALLYp HOWEVER, THERE ARE NO LOCAL CONTROLS FOR THE PUMP.

2 96 a2716 UPSTREAM 1* LINES OF VALVES CH-1443 (DRAIN VALVE OFF THE 2C ESSENTIAL CHILLED WATER PUMP SUCTION LINE) AND CH-0909 (DRAIN VALVE OFF THE 6* EAB AMU HEADER) HAVE MISSING / DAMAGE INSULATION. RE-INSULATED THE LINES. (DISCOVERED DURING ENG. SELF ASSESSMDfr - MOMSEN) 3 96-12729 THE DRAIN NIPPLE ASSOCIATED WITH VALVES 2-CH-0592 AND 2-CH-0908 HAVE STAINLESS STEEL PIPE CAPS INSTALLED WHICH IS NOT CONSISITANT WITH PLANT SPECIFICATION 5LO19PS604.

4 96-12730 VEVE 2-CH-0899 IS MISSING THE TPNS/ DESCRIPTION TAG.

5 96-12736 THE CASING VENF LINES AND VALV".S FOR THE RCB CHILL WATER MJMPS 21A, 218. AND 21C ARE NOT PER DESIGN. THE VENT VALVES ARE INCONSISTANT IN DESIGN AND NOT ACCURATE TO THE MEC.

6 96-12737 EVIDENCE OF SAGGING WAS DISCOVERED IN THE INSULATION ON ESSENTIAL CHILLER 21A. THE SAGGING APPEARS TO BE ENTRAPPED WATER DUE TO CONDENSATION. THIS CONDITION COULD CAUSE ACCELERATED CORROSION. THIS IDLVIICAL CONDITION WAS DISCOVERED ON ESSENTIAL CHILLERS 21B AND 21C (REF. CR'S 96-3558 & 96-3559) 7 96-12738 VALVE 2-CH-0598 FAILS TO EXHIBIT THE SHIFT SUPERVISOR CAtTTION TM AS DEMONSTRATED IN THE O'IMER TRAINS.

4 96-12740 THE imuuhTING WASHER FOR THE 6" ECW RETURN LINE TO ESSDf?IAI, CHILLER 21A FLANGE CONNECTION IS INSTALLED BACKWARDS.

9 91-12763 DURING A REVIEW OF THE CICSE-OUT DOCUMENTATION FOR THE QUALITY ASSURANCE ESSD4TIAL CHILLED WATER SAFETY SYSTEM FUNCTIONAL ASSESSMENT 93-03, IT WAS IDENTIFIED THAT CALCULATIONS MC-5232, MC-5274, AND MC-5275 WUULD BE SUPERSEDED. THIS ACTIO4 WAS TRACKED LY SPR 930910.

SFR930910 WAS CLOSED IN NOVEMBER 1993 AND THE ABOVE REFERDICED CAlfULATIONS ARE STILL NOT SUTIRSEDED.

10 96-12792 GPOPO2-CH-0001 (ESSENTIAL CHILLED WATER SYSTEM OPERATING PROCEDURE) STEPS 4.25 THROUGH 4.31 CONTAIN ACTIONS REQUIRED DURING A SAFETY INJECTION OR IOSS OF OFFSI*,'E POWER.

ARE THESE ACTIONS REQUIRED SO THAT THE CHILL WATER SYSTEM CAN PERFORM ITS SAFETY WNCTION7 IF SO, THE STEPS SHOULD BE INSERTED INTO THE APPROPRIATE OPOPOS EMERGENCY OPERATING PROCEDURE TO DISURE TIMELY COMPLETION OF THE ACTIONS UNDER ACCIDDFF CONDITIONS.

11 96-12796 THE SETPOINF INDEX LISTS 30 DEG F DECREASE SETPOINF FOR B2CH-TSL-9510 EVAP REFRIG LOW TEMP ALM SHUTDOWN (TRIPS CHILLER). THE SCALING vvCumdi FOR THIS SWITCH REQUIRES A 32.5 DEA F SETPOINF.

12 96-12799 THE SETPOINT INDEX LISTS A REQUIRED MAXIMUM RESET VALUE OF 13.3 INCHES HG ABS FOR THIS TRIP SWITCH (REFRIG LOW PRESSURE). THE SCALING DOCUMEMP REQUIRES NO MAXIMUM RE"ET.

13 96-12801 THE SETPOINT INDEXX LISTS 24 PSIG DEC SETPOINT FOR NICH-PSH-9612(2) SWITCH TO INITIATE *REFIGERANT HIGH PRESSURE" LIGHT ON ZLP-615.

THE SCALING DOCffMEMP FOR THIS SetITCH SETPOINT REQUIRES A 30 PSIG SETPOINT.

14 96-12814 DURING A REVIEW OF CR 95-11341 AND "HE ASSOCIATED CREE 95-11341-5 IT WAS NOTED THAT CALCULATION MC-5234 AJSUMED A MAXIMUM PEAK CH PRESSURE OF 154 PSI DUE TO WATER HAMMER DURING A IDSS OF NITROGEN PRESSURE ON THE TRAIN *C" CH EXPANSION TANK. CREE 95-11341-5 ACCEPTS THIS CONDITION BASED ON THE PIPING COMPONDTP DESIGN PRESSURE OF 150 PSIG. THIS EVALUATION OVERLOOKED THE FACT THAT THE CH EXPANSION TANK HAS A DESIGNPRESSURE OF 50 PSI AND A PSV SET POINT OF 40 PSI. DURING A IASS OF NITROGEN PRESSURE. "C* TRAIN CH MAY BE IMANALYZED DUE TO OVERPRESSURIZATION OF THE EXPANSION TANK AND/OR ESSENTIAL CHILLER 14W FLOW TRIPS TO TO THE CH PUMP CAVITATION DUE TO A I4SS OF CH INVDTTC.tY. BASED ON CREE 95-11341-5, VALVES CH0945, CH0957, AND CH0969 HAVE BEDI REMOVED FROM THE IST BASES DOCUMDTP ON SUPPLEMENT 96-07. IF IT IS DETERMINED THAT NITROCEN PRESSURE IS REQUIRED TO MAINTAIN SYSTEM OPERABILITY, THESE VALVES MAY NEED TO BE INCLUDED IN THE IST PROGRAM.

15 96-12815 NUCLEAR ENGINECRING SELF ASSESSMENT: THE INTEGRATD12 FACTOR OF 2.6 FOR THE 180 DAY DOSES IN NC-9002 APPEARS UNREASONABLE. THIS NEEDS TO BE REVIEWED AND CONFIRMED AS CORRECT.

16 96-12858 N"JCLEAR ENGINEERING SELF ASSESSMENT ITEM: CALC MC-6412 SHOULD BE REVISED FOR CLARIFICATION PURPOSPS AND ITS REQUIREMDTTS IMPLEMDfrED INTO THE CH DBD.

17 96-12860 PUCLEAR ENGINEERING SELF ASSESSMDrf. ITEM: CAIC MC-6429 SHOULD BE REVISED TO CLARIFY THE DESIGN BASIS OF THE ESSDfrIAL CHILLED WATER SYSTEM FOR COLD FEATHER CONDITIONS.

18 96-12883 DURING THE REVIEW OF PM EM-1-VA-93002770 PERFORMED ON 5/27/96, AS A PART OF THE DJGINEERING SELF ASSESSMDfF, IT WAS DISCOVERED THAT THE PANEL METER CALIBRATION DATA SHEEP FOR M3 HAS A MININUM CARDINAL POINT AT 200 OF 32.5 RECORDED. THIS DfTRY IS INCORRECT AND SHOULD HAVE BEDI 22.5 . THE AS FOUND INPUT OF 25.51 IS ACCEPTABLE AND DOES NOT RENDER THE EQUIPMENT INDETERMINATE.

19 96-12886 DURING ENGINEERING SELF ASSESSMDif IDENTIFIED THAT CREDIT WAS TAKEN FOR COMPLETION OF SURVEILLANCE OPSP03-CH-0001 (REV 2) UNDER ST:91 (WAN 89207) AND ST:86000605 (89%2) BY COMPLETION OF SURVEILLANCE PROCEDURE,OPSP03-CH-0004 (REV 2) UNDER ST:86000608 (WAN 88689) ON 18-JUL-96. THIS IS A POTDfrIAL MISSED SURVEILLANCE REQUIREMENT SINCE OPSP03-CH-0004 (REV 2) DID NOT REQUIRE COLLECTICN OF VIBRATION DATA AT POINrS 4V & 4H WHILE OPSP03-CH-0001 (REV 2) DID. INVESTICATE AND RESOLVE POTDTffAL MISSED SURVEILLANCE REQUIREMDfr.

. . ~ .

b . - -

_. . .. _ _ _ _ _ _ m. _ __ . .=. __ -- -m __ _ .m. . .m . _ _ ..

12/11/96 13:59:45 ALL CR's FROM THE ENCINEERING SELF ASIESSMENF CR . DE-= m-l 20 96-12887 VIBRATION AT POINT 4H DOCUh2NTED IN EXCESS OF ALERT LIMIT ON SURVEILLANCE 91/92 (WAN'S 89208 6 89875 RESPECTIVELY) DURING PERFORMANCE OF OPSP03-CH-0001 ON 15-AUG-96. THIS POINT WAS PREVIOUSLY DOC"MDf?ED IN EXCESS OF ALERT LIMITS UNDER CR 96-5146 WHICH ALSO RESULTED IN A LER FOR A MISSED INCREASED FREQUENCY SURVEILLANCE REQUIREMENT. THIS CR IS 10 DOCUl*DrP EXCEEDING THE ALERT LIMIT AT POINT 4H ON 15-AUG-96. ALSO, A DISCRFPANCY EXISTS BETWEDI DATES FOR WHICH CREDIT IS TAKEN FOR THESE SURVEILLANCES IN IMPACT. ST:91 (WAN 89208) IS DOCUMDITED AS COMPLETED 15-AUG-96 WHILE ST:92 (WAN 89875) IS EOCUMENTED COMPLETE 18-AUG-96. THE SURVEILLANCE PROCEDURE ITSELF IS SICED OFF COMPLETE 15-AUG-96 IN AGREEMDFT WITH ST 91 (WAN 89208).  ;

21 96-12915 DURING THE REVIEW OF TFE ESSDJTIAL CCLLED WATER PSA PACKArE FOR THE ENGINEERING SELF ASSCSSMENT, IT WAS DETERMINED THAT THERE IS NO ESTABLISHED PROCESS FOR TEMPORARY CONDITIONS SUCH AS TEMPORARY MODIFICATIONS TO BE ACCO' offed FOR IN THE PSA MODELS.

22 96-12917 OPGP04-ZA-0604, 'PROBABILISTIC SA~ TTY ASSESSMDfr PROGRAM

• HAS NO GUIDANCE FJR WHEN THE PSA SECTIONS SHOULD BE REVIEWED BY OTHER ENGINEERING ORGANIZATIONS. IN ADDITION THE CAP DOCUMDIT LIST DOES NOT RECOGNIZE THIS PROCEDURE NUMBER, SO THIS FINDING COULD NOT ,

BE ENTERED AS A FEEDBACK.

23 96-12918 IN THE ESSDrrIAL CHILLED WATER PSA PACKAGE, SECTION 11.2 (P.19), OPSP03-CH-0004 IS SAID NOT TO AFFECT AVAILABILITY. OPSP03-CH-007 HOWEVER, IS NOTED TO AFFECT ECH FLOW THROUGH THE AIR HANDLING UNITS. CH004 ALSO AFFECTS THE FIDW THROUGH THE AIR HANDLU*G UNITS, SO IT APPEARS THAT IT Sh0ULD BE DISCUSSED SIMILAR TO Titt OTHER SURVEILLANCE PROCEDURES. THIS OBSERVATION PROBABLY ALSO APFLIES TO THE (7FHER FIVE PROCEDURES MEffrIONED IN THE SECTION. FOUND DURING THE ENGINEERING SELF ASSESSMENT.

24 96-12919 THE PSA DOES NOT ACCOUNT FOR THE REQUIRED OPERATOR ACT7Nt TC REGULATE FIDW TO THE ESSDITIAL CHILLERS DURING COLD WEATHER OPERATION.

REVIEW OF ISSUE SHOULD ADDRESS THE ADEQUACY OF THE INFIAFACES REQUIRED TO PROVIDE INPUT TO THE PSA MODELS. IDENTIFIED DURING THE ENGINEERnD SELF ASSESSMENT 25 96-12920 SV369VB0120 (CH SYSTEM DBD) 4A.2.6 AND OPDG ITEM OI-CH-28 BOTH NOTE THAT THERE IS A PLANNED CHANrt TO THE CH TECH SPECS. NO CHANGE TO THE TECH SPEC IS PLANNED SINCE THE TECH SPECS DO NOT SPECIFY WHICH CHILLER (S) IN A TRAIN ARE ROQUIRED FOR OPERABILITY. THE DBD SHOULD BE CORRECTED. IDENTIFIED DURING THE DIGINEERING SELF ASSESSMENT 26 96-12921 MOD 91-051 TO ADD REFRIGERANT CLEAN UP KIT WAS DETERMINED TO BE A TRIVIAL CHANGE. SINCE THE CHANGE IS BEING DONE TO SAFETY RELATED EQUIPMEffP, "IIS CHAPE DOES NOT MEFT THE PRESDrP DEFINITION OF

• TRIVIAL' IDENTIFIED DURING THE ENGINEERING SELF ASSESSMENT 27 96-12922 THE CHANNEL I DATA PRESDrrED IN DCN 96-2365 WRITTEN AGAINST EC-5008 REV 10.. FOR CHANNEL I DOES NOT APPEAR TO AGREE WITH THE R2SULTS PRESENTED ON UFSAR TABLE B.3-6 IN CN-1961. THE DATA IN THIS UFSAR TABLE SHOULD BE CONFIRMED AGAINST THIS CALC, AND REVISED IF NECESSARY. NUCLEAR DIGINEERING SELF ASSESSMENT ITEM.

28 96-12923 MOD 91-051 FOR REFRIGERANT CLEAN UP KITS WAS EVALUATED IN THE MOD PACKAGE AS BEING REQUIRED FOR A STATE OR FEDERAL PERMIT (COMPLIAN"E WITH THE CLEAN AIR ACT) . HOWEVER, IT IS STILL NOT INSTALLED IN BOTH UNITS. DETERMINE IF THIS MOD IS ACTUALLY A COMPLIANCE REQUIREMEfft. IDDrfIFIED DURING DIGINEERING SELF ASSESSMDfP i 29 96-12930 THERE IS NO ESTABLISHED METHODOLOGY TO PERIODICALLY ROTATE THE 125VDC BATTERY CHARGERS. IT IS POSSIBLE THAT COMPONENT RELIABLITY MAY BE IMPROVED THROUGH C,tEATER SERVICE TIME. PLEASE EVALUATE-SED ELEC.

30 96-12938 IN THE STP RESPONSE TO NOV 9226-0I, A COf;MITMDfT WAS MADE (REGARDING THE 125VDC BATTERY BUS VOLTAGE) SUCH THAT *THE ALARM SETPOINT WILL BE REVISED (FROM 117VDC) TO INDICATE THAT BATTERY BUS VOLTAGE IS BELOW THE TECHNICAL SPECIFICATION MINIMUM VALUE(129VDC) . THIS i WILL BE COMPLETED BY MARCH 31, 1993 IN BOTH UNITS.* SPR 932309 WAS WRITTEN TO ASSESS WHETHER THIS COMMITMENT WAS MET. THE REPORTABILITY REVIEW (ST-MS-HS-25717 08/04/94) FOR THIS EVDIT CONCLUDED THAT THE

• LETTER OF THE COMMITMDrP WAS SATISFIED ALTHOUGH THE e INTDrF WAS NOT* AND CONCLUDED THAT THE CONDITION WAS NOT REPORTABLE UNDER 10CFR50.73. IT ALSG STATES THAT *IT IS CLEAR THAT THE INTDrF OF THE COMMITMENT WAS TO PROVIDE THE OPERATOR WITH AN ANTICIIATORY ALARM PRIOR TO EXCEEDING THE TECHNICAL SPECIFICATION LIMIT.* THE REPORTABILITY REVIEW ALSO RECOMMENDED THAT *AN EXTENSION OF THE COMMITMENT DUE DATE SHOULD BE OBTAINED AND/OR THE i COMMITMENT SHOULD BE CHANGED ..." A REVIEW OF THE ASSOCIATED DOCUMDrrATION OF THIS EVENT INDICATES THAT NEITHER THE DUE DATE NOR THE ,

COMMITMENT TO THE NRC WERE CHANGED BY NUCLEAR LICENSING. STP IS CURRENTLY OPERATING WITH THE 125 VDC BATTERY BUS UNDERVOLTAGE RELAY SET A 124 VDC.

21 95-12940 INTERVIEW WITH SHIFT SUPERVISOR DURING THE ENGINEERING SELF ASSESSMDrP IDENTIFIED THE FOLICWING THREE OBSERVATIONS: 1. THE RESOLUTION OF SOME ISSUES ARE NOT ALWAYS E"FECTIVELY COMMUNICATED TO THE CREWS ON THE OTHER SHIFTS WHO WERE NOT INVOLVED IN THE ISSUE RESOLtrfION. (THIS IS A GENERAL OBSERVATION THAT WAS NOT SPECIFICALLY DIRECTED AT ENGINEERING.) 2. SYSTEM HEALTH REPORTS COULD BE MORE WIDELY SHARED WITH THE SHIFT SUPERVISORS, PARTICULARLY THOSE REPORTS FOR SYSTEMS TUAT ARE CETTING ATTENTION IN THE DAILY COMMUNICATIONS AND TEAMWORK MEETING. 3. UNIT 1 TENDS TO BE A FILTER FOR ATTENTION TO UNIT 2. BECAUSE OF THE MORE DISTANP LOCATION OF UNIT 2, VISITORS TEND TO STOP AT UNIT 1 FOR WALKDOWNS, ETC.

nedsacr.brw Pace 2

! A M M M M M M M M '

12/.1/96 13:59:46 ALL CR*G FROM TME DIGINEERING SELF ASSESSMENT CR NO. DESCRIPTION 32 96-12943 DURING A WALKDOW4 OF THE 125VDC SYSTEM AND THE INSTRUMENTS ON CP003 IN THE MAIN COtrTROI, ROOM, THE FOLICWING CONDITIONS WERE NOTED:

• (1) THE 125VDC 1R BATTERY CHARGER VOLTAGE OUTPUT CAUGES WERE COIDR BANDED WITH THE YELIEW BAND BEGINNING(AND DECREASING) AT 129VDC(UNIT 1) AND 118VDC(UNIT 2). THE TECHNICAL SPECIFICATION MINIMUM VOLTAGE IN 129VDC. HAVING CREDI BANDS FOR INSWMENTS IN RANGES THAT VIOLATE TECHNICAL SPECIFICATION MINIMUMS IS POTENTIALLY A HUMAN FACTORS ISSUE. (2)THE VERTICAL CAUGES WHICH MEASURE 1E BATTERY CURRDrf ON CPOO3 ON THE MAIN CONTROL BOARD ARE SCALED 1-1000 AMPS (AT 100 AMP IlfrERVALS) AND THERE IS NO INDICATION ON THE GAUGES (+ OR -) WHETHER THE BATTERIES ARE CHARGING OR DISCHARGI?C. THE NORMAL SWITCHBOARD CURRDTT DRAW IS LESS THAN 100 AMPS PER CHANNEL. CONSIDERATION SHOULD BE GIVEN TO RESCALE THE INSTRUMDrFS IF THEY ARE USED AND TO ADD CHARGE / DISCHARGE ARROWS NEXT TO THE GAUGES.

33 96-12944 DURING A REVIEW OF CR 96-5203 THE CAP DATA BASE INDICATES THAT REPORTABILITY AND OPERABILITY ARE

• INDETERMINATE

• PER PLA?TT PROCEDURE OPGP03-EX-0002

• CONDITION REPORTING PROCESS *, THE SHIFT SUPERVISOR /ONE STOP SHOP SHALL DTTER THE JUSTIFICATION IN THE

• MAINTAIN ACTION INFORMATION* OR* MAIffrAIN OPERABILITY ASSESSMENT

• AS *YES* OR *NO*, WHICHEVER IS DEEMED APPROPIATE. NEITHER OF THESE DrrRIES WERE MADE FOR TilIS INDETERMINATE CONDITION. THE UNIT-1 SHIFT SUPERVISOR WAS CONTACTED ON 10/18/96, 1400 HRS TO NOTIFY HIM OF THIS CONDITION.

34 96-12945 DURING CONVERSATIONS WITH THE UNIT 1 AND UNIT 2 ivnh0L ROOM STAFFS, IT WAS DETERMINED THAT THE 1E BATTERY CHARGER VOLTAGE CAUGES ON CP003 WERE USED FOR INPVRMATION ONLY AND NOT FOR TECHNICAL SPECIFICATION CREDIT. THERE IS NOT A COMMON EXPECTATION TO DISPATCH AN OPERATOR TO THE BATTERY CHARGER ROOMS TO TAKE IOCAL READINGS WHEN THE INSTRUMENTS ON CP003 INDICATE LESS THAN THE TECH SPEC MINIMUM OF 129VDC. NOTE: OPERATORS REVIEW BATTERY CHARGER OUTPtTP VOLTAGE IDCALLY FROM A DIGITAL GAUGE EACH SHIFT AND THE TECH SPEC SURVEILIANCE IS PERFORMED EVERY 7 DAYS. EXAMPLE: THE GAUGE FOR ElB11 ON CP003 IN UNIT 1 READ *128VDC* AT 0820 ON 10/17/96. THE LOCAL DIGITAL GAUGE READ *130.4* CONDITIONING THE CONTROL ROOMSTAFF TO NOT TAKE ACTION BELOW THE TECH SPEC MINIMUM OF 129VDC MAY RESULT IN A VIOLATION IN A VIOLATION (2 HR ICO) WHEREBY VOLTAGE MAY DROP BEIDW THE TECH SPEC MINIMUM OF 129 VDC AND STILL BE ABOVE THE SWITCH 30ARD UNDERVOLTAGE RELAY ALARM SETPOItt? OF 124 VDC. REQUEST THAT OPERATIONS MANAGEMENT DEVELOP EXPECTATIONS REGARDING THIS COFFTROL ROOM INDICATION OF TECH SPEC EQUIPMENT. THIS ISSUE HAS BEEN DISCUSSED WITH BOTH UNITS' ASST. OPERATIONS MANAGERS.

35 96-12947 TECH SPEC 4.8.2.1.A.2 REQUIRES THAT THE 125VDC 1E BATTERY CHARGERS MAINTAIN A MINIMUM VOLTAGE OF 129VDC OR WITHIN 2 HOURS, BEGIN A PALNT SHUTDOWN. THE SURVEILLANCE FOR THIS TECH SPEC REQUIRES A VERIFICATION OF VCLTAGE OUTPUT EVERY 7 DAYS. OPERATIONS CURRENTLY VERIFIES VOLTAGE LOCALLY EACH SHIFT AND THERE IS INSTRUMENTATION THAT IS AVAILABLE TO MONITOR VOLTAGE IN THE MAIN CONTROL ROOM, HOWEVER, ITS USE IS FOR INFORMATION ONLY AND ACTIONS, BASED ON THIS INSTRUMEffrATION, IS INCONSISTDTT BETWEEN CREWS (REF; CRf 96-12943, 96-12945). ON APRIL 4, 1996, THE PCC APPROVED A MINOR CHANGE (CR95-14210-6) TO CREATE AN ERFDADS ALSRM AT 127VDC WHEN THE IMPROVED TECH SPECS ARE IMPLDIDrrED(THE NEW TECH SPEC VALUE WILL BE 127VDC) . CIVEN THE CURRENT UNDERVOLTAGE DETECTION SCHEME (124VDC ALARM POI?rr) , OPERATIONS' MONITORING OF 1E BATTERY CHARGER VOLTAGE AND THE POTDTTIAL THAT AN NRC COMMITMENT MAY NOT HAVE BEDI MET (REF:

CR096-12938), THE DECISION TO DEFER IMPLEMD? RING THIS MINOR CHANGE IN LATE 1997 SHOULD BE REVISITED. REQUEST THAT DED-ELECTRICAL /IEC EVALUATE THE FEASIBILITY OF DEVEI4 PING THE MINOR CHANGE TO PROVIDE AN ERFDADS ALARM WHDI VOLTAGE DECREASES BELOW THE CURRDTP TECH SPEC MINIMUM OF 129VDC.

36 96-12996 MC-5233 SHOULD BE REVISED TO REFLECT THE CHANGE OF THE REFERENCE DOUmr.si- FOR THE F14W DATA AND TO ADDRESS THE IMPACTS, IF ANY. OF THE CHANGE IN THE FIDW DATA ITSELF. CALC MC-5233 REV 3: PAGE 4: DATA INPtTT 91: ALL CPM REQUIREMDfrS WERE FROM MC-5232. YET, MC-5232 WAS SUPERSEDED BY MC-6412 (1/94). IT DOES NOT APPEAR THAT MC-5233 WAS REVISED TO STATE THE IMPACT, IF ANY, OF THE RESULTS OF MC-6412 ON MC-5233. NUCLEAR ENGINEERING SELF ASSESSMENT ITDI 37 96-12998 CN-2103: EDITORIAL ERRORS IN THE FSAR. SECTIONS 8.3.2.1.1 AND 19A.2.4 ON PAGE 10A-8 BOTH STATE THAT THE CLASS 1E 125V BATTERY BUSES ARE ENERGIZED BY BOTH CHARGERS. THIS STATEMDff IS CONTRARY TO ACTUAL PLAttr OPERATION AND THE REMAINDER OF THE FSAR. ALSO, SECTION 1.2.2.7.2 STATES THAT THE CLASS 1E 125 VDC SYSTEM CONSISTS OF THE BATTERY, BATTERY CHARGERS AND AN INVERTER. IN FACT, CHANNELS I AND IV HAVE TWO INVERTERS EACH.

38 96-13003 CN-2104: FSAR QUESTIOh 630.37N RESPONSE IS INCORRECT AND DOESN'T FULLY ANSWER THE QUESTION. THE FIRST STATEMDTT IN THE RESPONSE STATES THAT THE CLASS 1E POWER SYSTEM BATTERY CHARGERS ARE NOT CAPABLE OF SUPPLYING POWER TO DC I4 ADS UNLESS CONNECTED TO A BATTERY.

ACTUALLY, THE CHARGERS CAN SUPPLY THE DC I4 ADS WITH THE BATTERY BREAKER OPEN. THE REMAINDER OF THE RESPONSE DOES NOT FULLY ANSWER THE QUESTION.

nedsacr.brw Pace 3 1

1 M M M M M M M ~-

t 12/11/96 13:59:46 ALL CR'c FROM THE ENGINEERING SELF ASSESSMENT CR NO. DESCRIPTION 3 96-13013 DURING THE ENGINEERING SELF ASSESSMENT, A REVIEW OF THE " DESIGN BASIS DOCUMENF* PROCESS REVEALED THE FOLIJDWING PROBLEMS. 1. THERE IS A SIGNIFICANT DIFFERENCE IN THE APPLICATION OF AND THE INTERPRETATION OF WHAT THE DESIGN BASIS DOCUMENT IS. THIS INFORMATION WAS GATHERED FROM INTERVIEWS OF ENGINEERING PERSONNEL. 2. THERE ARE DESIGN BASIS DOCUMDTTS THAT DO NOT HAVE ALL OF THE DESIGN CHANCES POSTED AGAINST THEM. EXAMPLE: THE DELETION OF THE TOXIC GAS ANALYIZERS IS NUF POSTED AGAINST THE EAB HVAC DBD. 3. THERE ARE DOCUMDTfS THAT HAVE A SIGNIFICANT NUMBER OF ADMENDMENTS AND OPEN ITEMS. EXAMPLE THE DIESEL CENERATOR DBD HAS 45 ADMENDMENTS UNINCORPERATED. THE PROCEDURE REQUIRES REVISION OF THE DBD AFTER 15. 4. ONE CREE, 96-12546-1, USED THE DBD AS A SOURCE FOR A VALUE IN THE CREE. THIS IS NOT IN LINE WITH THE EXPECTATIONS OF ENGINEERING MANAGEMDTf. 5. TME PROCRAM PLAN HAS NOT BEEN REVISED SINCE 3/90 AND DOES NOT REFLECT THE CURRDTP MANAGEMDrP EXPECTATIONS.

40 96-13039 50.59 SCREENING FORMS ATTACHED TO MOD 87030 CONTAIN INADEQUATE INFORMATIOh TO DESCRIBE CHANGE BEING EVALUATED, INCORRECT REVISION INDICATED FOR REVISIONS TO SCREENING, AND JUSTIFICATIONS PROVIDED ARE INADEQUATE OR COffrRIDICTORY. APPEARS TO BE DOCUMDrfION DISCREPANCY ONLY. EXAMPLES: 1) DESCRIPTION STATES " REPLACE THE TRANSFORMERS IN CLASS-1E CHANNEL I AND IV BATTERY CHARGERS,* WHEN THE MODIFICATION INCLUDES

• REMOVING THE REQUIREMDrf THAT BOTH BATTERY CHARGERS BE OPERATING AND CONNECTED TO THE SWITCHCEAR BUS IN EACH OF CHANNEL I AND CHANNEL IV*, 2) TWO REV *0* AND THEN A REV *N/A*, 3) TECHNICAL JUSTIFICATION ON ORIGINAL SCREDTING FORM STATES THAT

• INSTALLING THE UPGRADED TRANSFORMERS IN THE CHANNELS I AND IV BATTERY CHARGERS WILL PROVIDE CAPABILITY TO OPERATE WITH ONLY ONE CHARGER CONNECTED TO EACH OF CHANNELS I AND IV*, BUT THE JUSTIFICATION ON THE SCREDTING FOR MDCN 87030-27 WHICH DEFERS TRANSFORMER REPLACEMDTTS, STATES THAT THE

• ORIGINAL DOCUMENT DID NOT REQUIRE THE BATTERY CHARGER TRANSFORMERS BE CHANGED TO IMPLEMENT SINGLE CHARGER OPERATION

• 41 96-13042 IT IS NOT CLEAR "' HAT CRACKED BATTERY TERMINAL POST CONDITIONS ACCEPTED BY ENGINEERING HAVE BEEN THOROUGHLY DOCUMENTED AND CLEARLY COMMUNICATED SO THAT A UNIFORM RESOLtTTION OF THE ISSUE IS PIANNED AND UNDERSTOOD.

42 96-13043 DESIGN BASIS DOCUMDITS SUPERSEDE THE DESIGN CRITERIA AND THE SYSTEM DESIGN DESCRIPTIONS, HOWEVER, THE DESIGN CRITERIA AND THE SDDS HAVE NOP BEEN C'.EARLY DESIGNATED AS BEING SUPERSEDED.

43 96-13049 THE NOTES SECTION OF THE ELECTRICAL SETPOINT INDEX COMPtJTER DATABASE FOR THE SWITCHBOARD DC *0V* RELAYS LIST DBD 4ES29EB1111 AS THE SETPOINT REFERENCE RATHER THAN LISTING A CAICUIATION OR A VDTDOR MANUAL. ALSO, THE COMPUTER DATABASE FOR THE DC "UV" RELAYS DOES NOT LIST CAIrUIATION EC-5033 WHICH IS THE SETPOINT BASIS.

44 96-13052 IDENTIFIED DURING ENGINEERING SELF ASSESSMDrF REVIEW OF *IAI* SYSTEM, *IkI" SYSTEM WALKDOWN REPORTS AND APPLICABLE TMOD LISTS. REQUEST ENGINEERING MANAGEMENT EVALUATION OF TMOD PROCESS TO CONFIRM SYSTEM ENGINEER EXPECTATIONS WITH RESPECT TO INVOLVEMENT OR CONCURRENCE WITH TMOD INSTALLATION ON ASSIGNED SYSTEMS. TMOD INSTALIATION CAN CURRENTLY BE PERFORMED ON ANY SYSTEM WITHOUT DIRECT SYSTEM ENGINEER INVOLVEMENT OR CONCURRENCE (REF OPGP03-ZO-0003) . THIS DOES NOT APPEAR TO BE CONSISTDIT WITH ENGINEERING MANAGEMErrr EXPECTATIONS FOR THE SYSTEM ENGINEER TO BE THE

• ENGINEERING SYSTEM EXPERT *. WITHOtTP PROCEDURAL REQUIREMENT FOR DIRECT SYSTEMS ENGINEER INVOLVEMENT OR CONCURRENCE (OPGP03-ZO-0003) WITH TMOS INSTALLATIONS, WITH THE CURRDIT TMOD PROCE!X7RE AND PRACTICES, THE SYSTDt3 ENGINEERS SYSTEM EXPERT STATUS WITH RESPECT TO TMOD'S IS REDUCED TO

• LIST MONITORING

• AND AFTER THE FACT

• REVERSE TMOD SYSTEMS ENGINEERING

• 45 96-13054 IDDrrIFIED DURING ENGINEERING SELF ASSESSMDr?. E1C11 CELI, 9 26 IDENTIFTED TO HAVE DRIED ELECTROLYTE UNDER THE CELL UNDER

• DEFICIENCIES

• IN THE SEPTEMBER 3,1996 *DJ* WALKDOWN REPORT. NOTE MADE TMAT SUSPECTED OVERFIDW DUE TO PREVIOUS EQUALIZE CHARGE. CELL 9 26 NAD NOTE PREVIOUSLY BEEN NOTED TO BE ONE OF THE HIGH ELECTROLYTE LEVEL CELLS. WHY DO WE SUSPECT CELL IS OVERFLOWING DURING EQUALIZING CHARGE? MONITOR DURING NEXT EQUALIZING CHARGE TO DETERMINE IF THIS IS ACMIAL CAUSE.

46 96-13057 IDDrrIFIED DURING ENGINEERING SELF ASSESSMENT DURING OPm SR AND SYSTEM TREND REVIEWS WITH SYSTEM ENGINEERS. IDDFFIFICATION OF SOME MAINTENANCE RULE FTJNCTIONAL FAILURES APPEARS TO BE AT A SELF IMPOSED LOW THRESHOLD AND CONTRARY TO OTHER PROGRAMATIC CONTROLS. *VA" SYSTEM ENGINEER EVEN IDDTTIFIED THAT A RECENT MRFF WAS ASSIGNED TO A FAILURE IDDrrIFIED DURING A PNP (?) . REQUEST ENGINEERING MANAGEMENT REVIEW OF THE PHILOSOPHY USED TO DETERMINE MRFF'S AT THE STP. HOW DOES DEVELOPED CRITERIA FOR MRFF'S AT THE STP COMPARE TO THE ACTUAL REQUIREMENTS OF THE RULE (10 CFR 50.65, REG GUIDE 1.160 t, NUMARC 93-01) AND THE REST OF THE NUCLEAR INDUSTRY. HAS THE

• WATERING IXNN* EFFECT OF *TOO LOW A THRESHOLD

• BEEN EVALUATED WITH RESPECT TO CURRENT MAINTENANCE RULE IMPLEMD!TATION AT THE STP? IF SO, WHAT WERE THE RESULTS OF THAT ASSESSMDir? BCffTOM LINE CONCERN MAIN CONCERN OF THIS REVIEWER IS THAT THE VOLUME OF ISSUES GENERATED FROM TOO LOW A THRESHOLD WILL TEND TO DIVERT ATTDFTION AND DILITTE THE EFFECTIVENESS OF THE MAINTENANCE RULE. IF THIS OBSERVATION IS VALID, THERE IS MORE RISK FOR POTDrfIALLY CRITICAL CONCERNS AND ISSUES TO GET

• PUSHED BELDW THE SURFACE AND OUT OF FOCUS

• MIXED IN WITH ALL THE OTHER " LOW THRESHOLD MRFF ITEMS *AND IASE ATTENTION AND PRIORITY AS A REF'.*LT.

47 96-13130 DURING A WALKDOWN OF THE CONDENSATE SYSTDt PER THE ENGINEERING SELF ASSESSMENT THE FOLIDWING CONDITION WAS DISCOVERED WITH RESPECT TO THE CIESED LOOP MOTOR COOLING LINES TO CONDENSATE PUMP MOTOR 813 (8S121MPA0316): 1) THE CLOSED IDOP COOLING LINE TO PUMP MOTOR fil IS NOT PROPERLY SUPPORT WHICH IS CREATING EXCESSIVE LOADING ON THE CONNECTION TO THE MOTOR HOUSING.

• " TAG HUNG"*

. a..-- s-y emeo a

~~~

12/11/98 13:59:46 ALL CR's FROM THE DCINEERING SELF ASSESSMEtrF CR NO. DESCRIPTION 48 96-13141 A REVIEW OF THE ENGINEERING TRAINING RECORDS, AS A PART OF THE ENGINEERING SELFASSESSMDTr REVEALED THE FOLLOWING DESCREPANCIES: 1.

CONTRARY TO THE REQUIREMDFFS OF PARAGRAPH 4.2.2.2 OF PROCEDURE OPGPO4-ZA-0010. ONE INDIVIDUAL HAS NOT COMPLETED HIS QUALIFICATION RECORDS AS ASSIGNED WITHIN THE 1HO YEAR SPECIFIED TIME DrrERVAL. 2. AT LEAST TWO INDIVILUALS HAVE BEDI MOVED FROM SUPERVISORY TO NON-SUPERVISIORY ROLES WITHIN ENGINEERING AND QUALIFICATIONS AND DUE DATES HAVE NOT BEDT ASSIGNED. OPGPO4-ZA-0010. STEP 4.2.2.1 REQUIRES THE3E ACTIONS WITHIN SEVEN DAYS OF

• ASSUMING THE POSITION *. 3. THE PROCEDURE IPE$ NOT ADEQUATELY ADDRESS THE QUALIFICATIONS OF SUPERVISIORY PERSONNEL, ESPECIALLY IF RE-ASSIGNED TO IDWER POSITIONS. ENGINEERING SHOULD EVALUATE THE WORK ASSIGNMDrrS OF THESE PERSONNEL AGAINST THE COMPLETED TASK ON THE QUALIFICATION CARDF. VERIFICATION OF SAFETY RELATED WORK SHOULD BE THE HIGHER PRIORITY.

49 96-13157 THE MIXED BED REGEN RINSE IN EFFLUDrr SODIUM ANALYZER IS NOT IABELED IN BOTH UNIT 1 AND 2. PLEASE LABEL. THESE ANALYZERS ARE INSIDE THE CP CONTROL ROOM, NORTH OF THE MAIN CONTROL PANEL AGAINST THE EAST WALL IN BOTH UNITS.

50 96-13163 COAT THE INSIDE OF THE CP SUMP IN UNIT 2. THERE IS NOTICABLE ETCHING OF THE CONCRETE WALLS AND FLOORS. THIS SUMP IS IN THE DRAINS SYSTEM (DR). 96-4982 HAS BEEN WRITTEN TO PERFORM THIS WORK IN LHIT 1.

51 96-13164 THE EQUIPMDrr IN THE AREA OF THE CP MIKED BED PEGENERATION TANKS IN THE TGB 29' EL. NEEDS TO BE CLEANED OF RUST AND PAINTED.

52 96-13165 #13 CONDENSATE PUMP HAS AN EXCESSIVE PACKING GIAND LEAK-OFF. THERE IS WATER SPILLDC OUT OF THE DRAINED PACKING AREA OF THE PUMP AND Orrro THE FLOOR OF THE PUMP PIT. THE 1* PACKING AREA DRAIN LINE CANNOT KEEP UP WITH THE LEAK-OFF. TICHTDI THE PACKING.

53 96-13182 SED MANAGEMDrr HAS NOT CLEARLY CONVEYED ITS EXPECTATIONS OF HOW QUICKLY AFTER A SYSTEM DOES TO (A)(1) STATUS UNDER THE MAINTENANCE RULE, SHOULD A CR DE GENERATED. NO EXPECTATION HAS BEDI GIVEN AS TO A TIME FRAME FOR DEVELOPING A PLAN OF ACTION TG MOVE THE SYSTEM BACK INTO AN (A)(2) STATUS.

54 96-13190 DirERVIEWS WITH WORK CONTROL (MAntrENANCE) PLAPNERS, DURING THE ENGINEERING SELF ASSESSMD37, IDENTIFIED THAT THE LEVEL OF DETAIL PROVIDED IN MODIFICATION PACKAGES MAY BE INSUFFICIENT TO DEVEIDP INSTALLATION INSTRUCTIONS WITHOUT ADDITIONAL INPUT FROM THE DESIGN ENGINEER OR TECHNICAL SUPPORT DCINEERING. EXAMPLE: TRANSFERING THE POWER SUPPLIES FOR THE REACTOR COOLANT PUMP OIL LIFT PUMPS DCP 96-965-3 WAS REVIEWSD WITH A PLANNER AND IDDFFIFIED THAT THE CONDUIT LAYOUTS WERE NCTF PROVIDED, POST MODIFICATION TESTING WAS ONLY IDD?rIFIED AS A FUNCTIONAL CHECK, CONDUIT GROUNDING WAS NOT PROVIDED, AND THE TEXT OF THE NEW NAME PLATES WAS NOT PROVIDED.

UfrERVIEWS WITH THE PMPI PERSONNEL INDICATE THAT THE LEVEL OF DETAIL IS ADEQUATE FOR THEIR GROUP BECAUSE CF THE FAMILIARITY WITH CONSTRUCTION REQUIREMDrrS AND par." **PERIENCE WITH THE MODIFICATION PACKAGES. THE SELF ASSESSMENT TEAM REQUEST "_"NGINEERING PERFORM AN EVALUATION OF THE LEVELS OF DEATAIL IN THE PACKAGES BASED ON THE KNOWLEDGE AND EXPERIENCE OF THE INSTALLING GROUP.

55 96-13194 DrrERVIEWS WITH SYSTEMS ENGINEERS. DURING THE ENGINEERING SELF ASSESSMDTF, IDENTIFIED PROBLEM" IN MEETING TWO ASPECTS OF THE SYSTEM EKPERT PLANS. THE PLAN REQUIRES THE ENGINEERS TO SPEND FOUR HOURS PER WEEK PERFORMING SELF STUDY ON HIS SYSTEM AND THE TEAMS DrrERVIEWS INDICATE THAT THIS CREATES A PROBLEM MEETING THE REQUIREMDrr DUE TO OTHER WORKLOAD TASK WITH HIGH PRIORITIES. THE RESULT IS THAT THE STUDY IS NOT COMPLETED. THE PLAN ALSO PROVIDES A SCOPE AND SCHEDULE OF ACTIVITIES REQUIRED TO BE PERFORMED TO ACHIEVE SYSTEM EXPERT STATUS. SOME DCINEERS WERE UNCLEAR AS TO HOW TO COMPLETE SOME ACTIVITIES WITHIN THE PLAN AS WELL AS THE TIMELINESS OF THE PLAN ITSELF. THE DURATIONS OF THE PLANS VARIED FROM ONE TO THREE YEARS. THE SELF ASSESSMDir TEAM REQUEST AN ENGINEERING EVALUATION OF THE CONTENT AND SCHEDULE OF THE PIANS AND CLEARLY DEFINE THE DELIVERABLES OF THE PIAN.

56 96-13209 NICD-LSL-7004 IS LISTED IN OPGP03-ZM-0016 AS A CONTROL AND INDICATION FUNCTION USED BY OPERATIONS. THE SWITCH FUNCTION IS TO ALARM 14W CONDENSOR HOT WELL LEVEI,. PER "PM* 95002436 A FUNCTIONAL TEST ONLY IS PERFORMED RATHER THAN A CALIBRATION WHICH IS REQUIRED PER OPGPO3-ZM-0016.

57 96-13214 COPTFROL AND UPDATING OF THE PSA, A LICENSING BASIS ANALYSIS TOOL, NEEDS IMPROVEMENT IN THE FOLI4 WING AREAS: 1. VALUES FROM THE DBD HAVE USED BEEN THROUGHOUT THE PSA AS A DESIGN BASIS REFERENCE. SINCE THE DBD IS A REFERENCE AND NOT ITSELF A DESIGN BASIS DOCUMDrr, ENGINEERING /RRA SHOULD EVALUATE THE ACCEPTABILITY OF USING THE DBD INFORMATION WITHOITF CONFIRMATION. (REF. CR 96-13013) 2. THERE IS NO REVIEW OF THE PSA PACKAGES BY GROUPS OUTSIDE THE RRA GROUP. CONSIDERATION SHOULD BE GIVDI TO DCINEERING AND OPERATIONS REVIEW OF THE BASIC ASSLHPTIONS USED IN THE PSA AS DOCLHDFFED IN THE PACKAGES AND THE SUCCESS CRITERIA USED IN THE ANALYSIS. 3. PHOCEDURE OPGPO4-ZA-0604 REQUIRES THE RRA GROUP TO IDDTTIFY ALL PSA CHANGES ONCE A CYCLE, AFTER THE UNIT 1 REFUELING OUTAGES. SIMILAR TO THE UFSAR, CHANGES TO PLAffr OR ITS PROCEDURES THAT COULD IMPACT THE PSA SHOULD BE IDDTTIFIED BY THE INDIVIDUAL RESPONSIBLE FOR THE CHANGE WHEN THE CHANGE IS MADE. CONSIDERATION SHOULD BE GIVEN TO D3HANCING ENGINEERING /RRA PROCEDURES TO ESTABLISH A MORE FORMAL STRUCTURE, INCLUDUC ROLES AND RESPONSIBILITIES, TO ASSURE APPROPRIATE AND TIMELY CONFIGURATON CO!rrROL OF THE PSA. 4. THE PSA MODELS AND PACKAGES ARE NORMALLY ONLY UPDATED AFTER THE UNIT 1 REFUELING OUTAGE. CHANGES COULD BE MADE DURING A UNIT 2 OUTAGE WHICH WOULD MAKE THE PSA NON-CONSERVATIVE FOR THAT UNIT. CONSIDERATION SHOULD BE GIVEN TO MORE FORMALLY ACCOLHTING FOR POTDfrIAL DIFFERENCES BETWEEN THE W O UNITS. 5. THERE APPEARS TO BE NO METHOD TO ACCOUtTT FOR SIGNIFICAffr TEMPORARY CHANGES, SUCH AS T-MODS IN EITHER THE PSA OR THE ON-LINE MAIffrDIA!!CE TOOL, and==-r.brw Pace 5

12/11/96 13:59:46 ALL CR's FROM THE ENGINEERING SELF ASSESSMENT l CR NO. DESCRIPTION 58 96-13218 IDDCIFIED EXJRING ENGINEERING SELF ASSESSMDC. CORRECT MINOR DRAWING AS-BUILT DISCREPANCIES IDDITIFIED BY REACTOR OPERATIONS DURING WALKDOWNS TO SUPPORT PROCEDURE UPGRADES ON THE CP SYSTD(. THESE INCLUDED ITEMS SUCH AS: DHG 95219F20013. REV 16: VALVE CP-1359 SHOWN ON DRAWING DOES NOT EXIST. ALSO, FLOW INDICATORS FI-5806 H, I, J, K. L. M. N & FI-5812 ARE NO IANGER INSTALLED. DWG 9S219F20014 REV 18: VALVE XCP-1171 IS SHOWN IN THE PROCESS LINE INSTEAD OF AS AN INSTRUMENT ROOT VALVE. ALSO, VALVE 1320 ' GRAB SAMPLE VALVE

• DOES NOT EXIST IN FIELD. SIMILAR DISCREPANCIES IDDCIFIED DURING THE UNIT 2 WALKDOWN. SEE APPLICABLE MARKED UP WALKDOWN DRAWINGS.

59 96-13220 IDDCIFIED DURING ENGINEERING SELF ASSESSMDC. UNIT 2 CP SYSTEM LTDS & HTDS TANES WERE RETURNED TO 3ERVICE BY PLANT OPERATIONS OVER A MOPCM AGO WITHOUT THE LEVEL INSTRUMDCATION MOD (ECNP-91-J-0023, C'* 95-3483) RETURN TO SERVICE COMPLETED BY THE IMPLEMDCATION ENGINEER. DRAWINGS WERE NOT UPDATED OR RED LINED TO REFLECT THE CHANGE AND IT IS UNCERTAIN IF PMT'S WERE COMPLETE SINCE STATUS IS

'61* - PNF ON HOLD FOR PIAfC CONDITIONS (?) . THIS IDENTIFIES 'IMO POTD7TIAL WEAKNESSES IN THE CHANGE / MOD PROCESS PRIMARILY ASSOCIATED WITH NON SAFETY RELATED SYSTEMS: 1) WITH CHANGES /MD'S ON NON SAFETY RELATED SYSTEMS NOTHIfC TRACKS OR FORCES PACKAGE CLOSURE AFTER PHYSICAL COMPLETION WITH RELEASE OFTHE CLEARANCE TAGS AND THE SYSTEM LINED UP FOR SERVICE. SINCE THERE IS NO OTL/LCO ENTRY TO TRACK ACTUAL PACKAGE COMPLETION THROUGH STATUS "65*

• FIELD h0RK COMPLETE" (ACCEPTED BY OPERATIONS WORK AUTHORITY). 2) THE IDDCY OF THE IMPLEMENTAION ENGINEER IS NOT ALWAYS CLEAR, ESPECIALLY ON MINOR CHANGES. 3) THE POIrrr AT WHICH THE CHANGE / MOD SHOULD HAVE A RETUPli TO SERVICE

• FORM-2* COMPLETED UNDER OPGP04-ZE-0312 IS NOT ALWAYS CIJ:AR TO THE IMPLEMENTATION DCINEER. IN THIS CASE THE PACKAGE IS STILL OPEN TO ALIAW COMPLETION OF INSUIATION & PAINTING. HOWEVER, THE SYSTEM HAS BEEN IN OPERATION SINCE COMPLETION OF THE PHYSICAL TANK CONNECTIONS AND INSTRUMENT INSTALLATION PORTION OF THE MOD OVER A MONTH AGO. THE CURRENT CONTROLLED DRAWINGS IN THE CONTROL ROOM DO NOT REFLECT THE CHANC.E.

60 96-13226 NUMEROUS REPAIRS OF THE LINER HAVE BED 3 MADE TO THE CATION AND MIXED BED VESSELS FOR THE *CP" SYSTEM. THESE ACTIONS HAVE BEEN EVALUATED ON A CASE BY CASE BASIS BY ENCINEERING. THIS CR IS FOR ENGINEERING TO EVALUATE REVISING THE VENDOR MANUAL TO ADD A DCN ALLOWING THIS REPAIR METHODOLOGY WITHOtTP AQUIRING ENGINEERING APPROVAL.

61 96-13244 NUCLEAR ENGINEERING SELF ASSESSMENT ITEM: OPGP03-ZO-0041', REV. 2,

• ACTION FOR MONITORING PRIMARY-TO-SECONDARY LEAKAGE *, STATES THAT A JCO SHOULD BE WRITTDI IF LEAKAGE EXCEEDS 15GPD (SECTION 7.2.9) . HOWEVER, OPGP05-ZN-0005. REV 1, 'JUFTIFICATION FOR CONTINUED OPERATION *, STATES THAT A JCO IS REQUIRED ONLY WHEN THE PLAFC IS IN A CONDITION OUTSIDE THE LICENSIPC BASIS AND CONSTITUTES A USQ (SEE SECTIONS 2.0 AND 3.4 FOR EXACT VERBAGE). A PRIMARY-TO-SECONDARY LEAK RATE OF 15GPD (-0.01GPM) DOES NOT EXCEED THE DESIGN BASIS.

OPGP03-ZO-0041 SHOULD BE REVISED TO PROVIDE FOR AN ALTERNATE MEANS OF ASSESSING WHETHER CONTINUED OPERATION IS DESIRABLE AND TO REFLECT THE CORRECT USAGE OF THE JCO PROCEDURE.

62 96-13343 EURING A REVIEW OF THE MED/MPL PROCESS AS PART OF THE ENGINEERING SELF ASSESSME!C THE FOLLOWING CONDITIONS WERE DISCOVERED AS POTENTIAL PROCESS IMPRO7EMENTS. THIS CR IS BEING GENERATED FOR THE CONFIGURATION ENGINEERING SUPERVISOR TO EVALUATE THESE OBSERVATIONS AND DETERMINE THEIR VALIDITY. 1) CONSIDER ESTABLISHING A PROGRAMATICAL THRESHOLD REGUARDIPC THE NUMBER OF MED/MPL OPEN ITD(S AND THE LENGTH OF TIME THAT THESE MAY BE KEPT OPEN. THIS WILL ESTABLISH PERFORMANCE GOALS AND METHOD FOR MONITORING THESE GOALS. 2) CURRENTLY COGNIZA!C DESIGN DCINEERS ARE REQUIRED TO NOTIFY CONFIGURATION ENGINEERING FOR UPDATES / CHANGES TO THE MED/MPL EITHER BY USING THE ELECTRONIC CHANGE PROCESS OR BY A DCP. THIS PROCESS IS IADOR INTENSIVE AND NOT NECESSARY FOR MINOR UPDATES.

COGNIZANT DESIGN ENGINEERS SHOULD BE TRAINED AND GIVE THE NESSARY ACCESS TO PERFORM THESE CHANGES TO THE REFERENCED DOCUMDCS.

63 96-13347 A FURTHER REVIEW OF CLECTRICAL SETPOINT INDEX DATABASE FOR SETPOIICS APPLICABLE TO THE DJ SYSTEM IDENTIFIED THAT THE DATABASE DOES NOT REFERENCE ELECTRICAL CALCULATION EC-5033 WHICH PROVIDES THE SETPOINT BASES AND REFERENCES FOR THE FOLLOWDC REVIEWED SETPOINTS:

DC UV SWITCHBOARD RELAY, SWITCHBOARD TIME DELAY RELAY, CHARGER #1 AC UV RELAY, CHARGER 91 GROUND SENSOR. CHARGER 41 DC UV REIAY, CHARGER #1 CHARGER FAILURE RELAY, CHARGER #1 DC OV RELAY, AND DC OV SWITCHBOARD RELAY. IN ADDITION A FURTHER REVIEW OF THE DATABASE FOR THE TWO (2) DC OV RELAY SETPOINTS (ADDITIONAL PROBLEMS IDENTIFIED IN CR96-13049) IDENTIFIED THAT THE NOTES SECTION IS PUNCTUATED DIFFERENTLY FOR THE SA!'E NOTE CAUSING CONWSSION AS TO WETHER THE DBD IS REFERENCED AS A SETPOINT BASIS OR AS A REFERENCE FOR M&TE ACCURACY WMDI TESTING THE SETPOINT. IN EITHER CASE THE DBD DOES NOT CONTAIN SETPOINT VALUES FOR M&TE ACCURACY VALUES ASSOCIATED WITH THESE SETPOITCS.

64 96-13348 IDD3TIFIED DURING ENGINEERING SELF ASSESSMENT. CURRD3T "CP' SUMP LIGHT IS BOLTED TO THE SUMP GRATING AND HARD WIRED INTO THE SYSTEM.

THIS REQUIRES A TAG OUT AND DETERMING TO ALIDW SUMP GRATING REMOVAL TO SUPPORT D1TRIES OR SUBMESSIBLE SUMP PUMP INSTALLATION. THIS IS OFEN THE CAUSE OF OPERATOR WORK AROUNDS AND IS INCCNSISTENT WITH GOOD DESIGN PRACTICES.

65 96-135(2 THE T MOD PROCEDURE DOES NOT LIST THE FIRE HAZARDS EVALUATION IN THE BODY OF THE PROCEDURE (AS PART OF THE TECHNICAL REVIEW QUESTIONS) BUT LISTS IT IN THE REFERENCES. THIS MAY LEAD TO FIRE HAZARD EVALUATIONS BEING MISSED ON T-MODS.

66 96-15668 AS A RESULT OF THE OCTOBER 14 -24 ENGINEERING SELF ASSESSMDC, THIS CR IS BEING GENERATED TO TRACK THE RESULTING REPORT

SUMMARY

AS FOLLOWS: (1) AREAS FOR IMPROVEMDC AND (2) RECOMMENDED ENHANCEMDCS.

nedsacr.brw Pace 6

-- s ,

- -- - -- - g w-12/11/96 13:59:46 ALL CR'O FROM THE ENGINEERINC SELF ASSFiSMENT CR HO. DESCRIPTIost 67 96-15672 CD SEAL WATER SYSTEM HAS EXPERIENCED SEVERAL PROBLEMS OVER THE IAST FEW MONTHS WITH PUMP SEAL WATER CHECK VALVES STICKING (BOTH OPEN AND CIASED OR LEAKING BY) . THIS CREATED SOME CONCERNS OVER SYSTEM PERFOR. M AND CREATED OPERATOR WORK AROUNDS. THIS SHOULD BY EVALUATED BY THE SYSTEM ENGINEER FOR SYSTEM IMPACT AND POTENTIAL NEED FOR LONG TERN COPJtECTIVE ACTIONS. (THIS CONCERN ORIGINATED FROM THE ENGINEERING SELF-ASSESSMENT CONDUCTED OCTOBER 14-24, 1996) 68 96-5155 THIS CR WAS INITIATED TO PROVIDE A CLARIFICATION OF THE TECHNICAL SPECIFICATION REQUIREMINTS FOR INTERRELL CONNECTION RESISTANCE TESTING (T/S 4.8.2.1.(C).3). DURING THE PREPARATION OF THE IMPROVED TECH. SPEC. . A QUESTION CAME UP WHETHER THE CABLE RESISTANCE SHOULD ALSO BE INCLUDED INF HE CONNECTION RESISTANCE MFASUREMENP FOR INTER-TIER AND INTER-RACK CONNECTIONS. AN ENGINEERING REPORT WAS REQUESTED TO ADRESS THIS QUESTION AND TO CLARIFY THE INTENT OF THE SURVEILLANCE REQUIREMENTS FOR CONNECTION RESISTANCE TESTING.

ENGINEERING SELF ASSESSMENT REOPENED THIS CR FOR LICENSING REVIEW I

)

l I

nedsser.brw Pace 7

_.