ML20135F365

Draft Connecticut Yankee Plant Design Change Task Group, Final Rept

ML20135F365
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/26/1985
From:	Cornelius G, Crandall R, Schmidt R CONNECTICUT YANKEE ATOMIC POWER CO.
To:
Shared Package
ML20135F361	List: B11646, Forwards Draft Connecticut Yankee Plant Design Change Task Group, Final Rept, Review of Design Change Process, Plant Design Change Evaluations & Screening of Plant Design Changes, Per NRC Request During 850801-02 Audit ML20135F365 ML20135F370 ML20135F374 ML20135F385
References
NUDOCS 8509170238
Download: ML20135F365 (81)

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CONNECTICUT YANKEE PLANT DESIGN CHANGE TASK GROUP FINAL REPORT SUBMITTED BY R. J. Schmidt, Chairman G. E. Cornelius - Member R. A. Crandall - Member D. G. Diedrick - Member M. S. Kai - Member B. A. Tuthill - Member DATE July 26,1985 8509170230 0 PDR P ADOCK O 213 pg L- i

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CONNECTICUT YANKEE PLANT DESIGN CHANGE TASK GROUP FINAL REPORT DE N H' EP -C S l

TABLE OF CONTENTS Section Pm Executive Summary 1

1.0 INTRODUCTION

6 2.0 CY PDCTG Review Method 8 2.1 Method - Discussion 8 2.2 Method - Plant Design Change Screening 8 2.3 Method - Plant Design Change Detailed Evaluations 11 2.4 Method - Plant Design Change Process Review 14 2.5 Method - Work Order / Permit Review 17 3.0 Results 20 3.1 Results of Plant Design Change Screening 20 3.2 Results of Plant Design Change Detailed Evaluations 20 3.3 Results and Specific Recommendations of the Plant 21 Design Change Process Review

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E'E' 4.0 Conclusions / Recommendations 38 4.1 Conclusions - Screening Review 33

4.2 Conclusions - Detailed Evaluations 39

4.3 Conclusion / Recommendations - Review of the ~43

- Plant Design Change Process 4.4 Conclusion / Recommendations - Work Permits / 45 Automated Work Orders 4.5 Conclusions / Recommendations - Summary 46 i

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O Ma 2,71 U2] yj INDEX - Figures, Tables, Appendices and Attachments

.: ,. Figures 3-1 Proposed Processing of Plant Design Changes 4-1 PDCRs Requiring Detailed Review - Categorization By Approval Date Tables

l. 2-1 Process Review Matrix

+3-1 Listing of Plant Design Change Requests 3-2 PDCRs Requiring Detailed Evaluation 3-3 Listing of Jumpers / Bypasses / Lifted Leads 3-4 Deficiencies in Specific Plant Design Changes 3-5 Design Change Process Recommendations 3-6 Procedure Deficiencies 4-1 Categorization of Concerns from the Screening Review APPENDICES

• A-1 CY PDCTG Procedure 1.01, Rev.1, Administration

• A-2 CY PDCTG Procedure 1.02, Rev. O, Plant Design Change Screening

'A-3 CY PDCTG Procedure

• l.03, Rev. 0.A, Review of the Plant Design Change Evaluations

'A-4 CY PDCTG Procedure /1.04, Rev. l.A, Review of the Plant Design ,

Change Process l

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• A-5 CY PDCTG Procedure 1.05, Rev. 0.A, Vendor Liaison

• A-6 Summaries of Detailed Evaluations of PDCRs

• A-7 Process Review - Comparison with INPO Good Practice

• A-8 Integrated Evaluation of PDCR Deficiencies

• A-9 Connecticut Yankee " Report on Work Permit / Order Review," July 1985, Impell Corporation, Volume 1.

A-10 CYPDCTG Disposition of Impell's Recommendations and Observations Attachments I

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• B-1 Volumes 2 thru 7 of Appendix A-9.

j *Not included with draf t version of final report.

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EXECUTIVE

SUMMARY

On December 13, 1984, the NRC issued an Order Modifying License to CYAPCo to Require,1) a review of plant design changes since January 1,1979, and; 2) an evaluation of the plant de' sign change process and recommendations for improvement. In January 19S5, the Connecticut Yankee Plant Design Change Task Group (CYPDCTG) was chartered to perform this review. The CYPDCTC completed the required evaluations in July 1985. This final report presents the methods, results and conclusions of the CYPDCTC.

The CYPDCTG first developed the review methodology necessary to ensure the intent of the order would be met. Five procedures were written to implement the review methodology. The CY PDCTG used these procedures to administer its work and review the following:

1. Plant Design Change Requests (PDCR's)

All 355 PDCR's approved during the period January 1, 1979 through December 31, 1984 and not subsequently cancelled were reviewed by the task group. The initial review phase consisted of screening all 355 PDCR's to determine those design changes which should be evaluated in detail, primarily because of their potential safety significance. Thirty five (35)

PDCR's were determined'to require a detailed evaluation and are listed in Table 3-2. Detailed evaluations were performed and 39 deficiencies requiring further evalua' tion or corrective action were identified. These deficiencies are summarized in Tabic. 3-4.

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2. Juropers, lif ted leads and bypasses.

There were 12 jumpers,lif ted leads or bypasses that were approved prior to January 1,1935 and were still in effect as of April 15,1985. All 12 were screened and none were determined to require a detal!ed review because of a lack of safety significance.

3. Work permits and Automated Work Orders Early in the project the Task Group determined that design changes were implemented via work permits / automated worked orders without corresponding PDCRs or safety reviews. Impell Corporation was contracted by the CY PDCTG to review the approximate 9100 work permits and 11,200 automated work orders approved during the period -1 E)w.J4 . .

79 through 1241 784. Impell identified 65 Work Permits / Orders which involved design changes of potential safety significance. Safety evaluations were completed by Impell on 56 of these and no deficiencies or safety concerns were identified. The CY PDCTG reviewed and approved the Impell evaluations. The remaining 9 require further evaluation by CYAPCo. An additional 24 potential design changes must be evaluated during the next refueling outage due to accessibility limitations during operation.

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4. Design Change Process The CYPDCTG evaluated the design change process by reviewing:

a) Causes for specific design deficiencies identified during detailed reviews, b) design change process concerns identified during screening and detailed reviews, c) the design change process itself as used in selected design changes, d) CYAPCo design change procedures, e) comparisons to other programs including INPO Good Practices and f) comments from Impell and the External Review Group. These reviews resulted in 18 recommendations for process corrections and improvements, which are summarized in Table 3-5.

In general, the CYPDCTG concludes that throughout the period of review, design changes have been made with concern for both quality and safety.

In several instances, the identified deficiency was not related to the change itself, but to the original design basis of the system being modified.

The most frequent source of identified deficiencies was the seismic qualification of equipment. The most significant deficiencies identified in the evaluation are: a) incomplete consideration of charging system outleakage in accident analyses and Technical Specifications, b) lack of seismic qualification of the service water system and portions of CVCS; c) potential degradation of containment isolation under certain conditions, and d) inability of the plant to achieve cold shutdown utilizing only seismically qualified equipment.

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. L. . ....', b ed d Also, the CYPDCTG concludes that existing procedural controls over the design change process are effective. Only a few deficiencies that occurred in past design changes have not been addressed adequately in current design change procedures. A significant improvement in PDCR packages with time has been noted.

The CYPDTG recommendations for improvements in the design change process are primarily in the areas of:

1. Control of design basis information.

2. Training of engineers on the design change process

3. The definition of " Plant Design Change"

4. The documentation of activities that may not been be controlled under PDCR's.

5. The need for a more integrated review process.

6. Specific procedure improvements for clarity and consistency.

The CYPDCTG performed its activities under the oversight of an External Review Group (ERG). The ERG has reviewed and concurred with this report. This report will be incorporated into the ERG's final report to the NRC. The order requires that within 2 months after the date of issuance of the ERG's Final Report, CYAPCo must submit a plan for improvements based on an evaluation of' the CYPDCTG findings and recommendations, as summarized in Tables'3-4 and 3-5.

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.- ' r. ! _, .;  ;;,, ,j In conclusion, the CYPDCTG has reviewed both design change and the design change process as ordered by the NRC. Although a number of deficiencies have been identified, the CYPDCTG found no reason to immediately modify plant operation or the controls for plant design changes. The CYPDCTG expects that its concerns will be resolved satisfactorily by the plan that is prescribed in the Order.

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- . . s. .: La, L M INTRODUCTION This report presents the findings of the Connecticut Yankee Plant Design Change Task Group (CYPDCTC). The CY'DCTG was chartered to review plant design changes in response to the NRC Order of December 13, 1984, modifying the license of the Connecticut Yankee plant.

Consistent with the Order and the Connecticut Yankee Atomic Power Company (CYAPCO) response to the Order, this review was conducted in three phases:

1. An initial review to identify the plant design changes with potential public safety significance. This review was termed " screening".

2. A detailed evaluation of those identified plant design changes to assess the significance of any deficiencies in the change. This included a review for unanalyzed failure modes.

3. A review of the process employed to implement plant design changes.

This phase involved the review of past deficiencies and current procedures, to produce recommendations on the correction and/or improvement of the current design change process.

This review addressed plant design changes that were approved from January 1, 1979 through December 31,1984. The activities that were reviewed within this time frame are 1) Plant Design Change Requests b) Jumpers, Lifted Leads and Bypasses and c) Work Permits and Automated Work Orders. The last item required a major effort and was assigned to a contractor.

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tw o , w M This report consists primarily of a compilation of the Milestone Reports issued during the course of the study. However, some minor changes or additions have been made to the findings and conclusions of the_ Milestone Reports. Therefore, the recommendations as presented in this final report should be used to develop follow-up action.

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-L d 2J CYPDCTG REVIEW METHOD 2.1 METHOD - DISCUSSION The activities of the CYPDCTG were performed in accordance with controlled procedures developed by the task group. These procedures addressed 1) administrative matters 2) screening 3) detailed evaluations 4) process review and 5) vendor liaison. CYPDCTG procedures were concurred with by the External Review Group and approved by the Vice President, Nuclear and Environmental Engineering. Appendices A-1 through A-5 contain copies of these procedures. The methods used for the three phases of Task Group activity are discussed in the following sections.

The method used to review work permits / orders is also discussed.

2.2 METHOD - PLANT DESIGN CHANGE SCREENING Screening of PDCR's and jumpers was perforraed through the use of CY PDCTC Procedure 1.02 (Appendix A- 1). The basic review logistics incorporated by this procedure included the following:

1. A lead screening reviewer was assigned from the group for each design change. The lead reviewer would obtain the design change package as well as any other material necessary to adequately evaluate the change. The lead reviewer would then 4 l

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cvaluate the change against the criteria established in the CYPDCTC procedure for determining safety significance and document his evaluation.

2. The lead screening reviewer's evaluation would then be routed to each individual in the PDCTG for independent evaluation.

This was an impertant step as it gave each individual the time to review the package in detail independently rather than just

, discussing the change in a group forum where one might have limited time to consider the change in detail. Any questions or comments an individual may have were . recorded on the form for discussion at a subsequent group meeting.

3. After each individual had reviewed the change, the Icad screening reviewer would present the change to the group for discussion and final determination. The group discussion was important since these discussions provided new insights and new questions which may have been overlooked during the independent reviews. Of ten, PDCR's were put - on hold to resolve outstanding concerns noted during the group meeting.

A subsequent group meeting _ would be held to make a final determination.

. 4. Concurrence of all 6 members was required for a "No Further Evaluation" determination. Any one niember could dictate a detailed review.

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Three screening criteria were established in the CYPDCTC procedure. However, these criteria were generally worded to avoid a regimented and perhaps limited thought process. The criteria required an evaluation of the design change against the following three general concerns:

1. Potential loss of a boundary designed to contain radioactivity (cladding, pressure boundary, containment). If the change itself, or a credible failure of the change could result in an increased probability of failure or a previously unanalyzed failure mode of a boundary, then the change would require detailed evaluation. Additionally, a change which could increase the consequences ui a previously analyzed failure required review. Secondary effects (e.g. flooding, falls, etc.)

were considered in this evaluation; and hence, even changes to non-safety-related systems could have an effect on safety systems or boundaries.

2. Thoroughness of the change package for safety related changes.

If the change affccted safety related equipment, but the package did not appear thorough (e.g. did not address seismic issues, involved 3 specific changes but only 2 were addressed in the design review and safety evaluations) then it would require a detailed evaluation.

3. Adequacy of the safety evaluation. The written safety evaluation. (and backup documentation) was reviewed against

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the complexity and safety significance of the change. If inadequate (e.g. safety significant change involving multi-disciplines but only the mechanical aspects were evaluated) the change may require detailed evaluation.

A form documenting the lead screening reviewers evaluation, independent review questions and comments, a summary of the group discussion, and the bases for the final determination was completed and filed with each design package. For those design changes which were determined to require additional review, the appropriate concerns which arose during the screening process were documented on the screening form to ensure' their resolution during the detailed evaluation.

Each potential process design deficiency noted during screening reviews were documented on Figure 7.2 of CYPDCTG Procedure 1.04 (APP A-4). This information was subsequently factored into the overall Process Design Review performed after the detailed t

evaluation phase.

2.3 METHOD - PLANT DESIGN CHANGE DETAILED EVALUATIONS Detailed evaluations of the 35 PDCRs selected from the screening process were conducted in accordance with CYPDCTG Procedure j

I 1.03 (Appendix A-3). The basic review process outlined by this  !

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1. A Scope Review was conducted to outline the areas requiring detailed evaluation and assign lead / support reviewers. One of the reviewers was designated as lead reviewer to write a final summary of the detailed evaluation. The Scope Review considered three primary phases for evaluation:

A. Impact on the Plant Design Basis.

B. Confirmation of Proper Implementation.

i C. Provisions for Continued Safe Operation.

2. Detailed evaluations were performed based on the concerns identified in the screening and scoping reviews and any additional facts which surfaced in the conduct of the detailed evaluation.

In performing the detailed evaluations the PDCTG members used the available documentation. Personnel involved or knowledgeable in the specific change, were of ten contacted for information. There new technical input was required, a discipline . liaison. was typically .

charged with producing this information.

i In a number of instances, on site inspections and walkdowns were conducted. These were used to assess the adequacy of the changes and to verify that the implernentation of the change is consistent with the available d6cumentation.

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assignment of an alternate evaluator with similar technical experience prior to the Scope Review.

4. All evaluations, with a Summary Evaluation, were routed to each member (or alternate) in the PDCTG for independent review. This provided each member an opportunity to review the package for completeness and accuracy. Questions or comments raised during independent review were recorded on the Summary Evaluation (Fig.

7.5 of Appendix A-3). A resolution was reached between the originator of the comment and the lead evaluator. The resolution l was also documented on the Summary Evaluation forms.

5. A PDCTG meeting was held to discuss the results of the evaluation.

The Lead Evaluator would present a summary of the detailed evaluation and a discussion of the resolution of comments.

Additional comments could be raised at this time.

6. If all six members concurred on the evaluation, the evaluation was approved and documented by signature.

7. Each deficiency noted in the evaluation was included as an input to the process review by using Figure 7.1 of Procedure 1.04 " Review of the Plant - Design ' Change Process". In addition, some process deficiencies were discovered in the detailed evaluation that did not result in a safety concern. These deficiencies were also factored into the process review using Figure 7.1 or Figure 7.2 as appropriate.

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~t u e tn.;; j'^-l 2.4 METHOD - PLANT DESIGN CHANGE PROCESS REVIEW The CYPDCTG performed this review in accordance with CYPDCTG Procedure 1.04, " Review of the Plant Design Change Process", which is included in this report as Appendix A-4. The effectiveness of this review depended heavily upon the CYPDCTG members' insight into the design change process, recognition of potential deficiencies, and follow through.

During the entire tenure of the CYPDCTC, members identified concerns or deficiencies in the design change process for follow-up.

There were generally three opportunities to identify such items:

1. During detailed evaluations of PDCRs. This phase required members to identify project deficiencies and any causative

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process deficiencies. Process deficiencies that did not result in project problems were also identified. A specific form (Figure 7.1 of Procedure 1.04) was used to evaluate deficiencies and to facilitate group dispositions.

2. By a structured review of the design change process. This structured review of selected design changes sought to assess the effectiveness of seven steps in the design change implementation process: 1) engineering 2) design 3) construction 4) inspection 5) preoperationai testing 6) turnover and 7) training. The effectiveness of interfaces between

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aspects was also evaluated. Again, specific forms (Figure 7.1 s-or 7.2 of Procedure 1.04) were employed when deficiencies were identified in the summaries of these reviews.

For this review, the CYPDCTC recognized that the PDCRs selected for detailed evaluations did not provide an optimum sample for an assessment of the design change process. Those PDCRs very often were selected to review a specific technical shortcoming. Many were of limited scope and/or performed under obsolete procedures, making them unlikely projects for a j r

review to reveal improvements in the process. Therefore, the CYPDCTG performed a structured review of a broader sample.

A matrix was developed (see Table 2-1) to produce the sample used. The collective judgment of the CYPDCTG was applied to this matrix to include projects with meaningful distributions of origin, age, and technical discipline.

3. Upon recognition at any time. When a concern was identified

-by an individual or in group discussion, a specific form (Figure

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7.2 of Procedure 1.04) was completed and entered in the file for later evaluation and group disposition. This method was most effective during the screening review, when all PDCRs were investigated. Additionally, it provided a means to document process concerns that resulted from interaction with the contracted consultant in Work Permits / Orders.

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In accordance with Procedure 1.04, all deficiencies identified by -

4 these approaches were reviewed and dispositions specified. All determinations received independent reviews and subsequent concurrence of all CYPDCTG members, through signature at group meetings. Deficiencies were further evaluated to identify areas of J

significant weakness in the process.

The CYPDCTG also reviewed other available documents to identify

. additional process improvements. These documents included design change procedures from two other utilities and References I and 2.

The External Review Group also identified areas of improvement.

When deficiencies or improvements were noted, the appropriate forms were initiated for furthe.r consideration.

The C'YPDCTG was not . chartered to assess the thoroughness of design change documentation from a quality assurance standpoint.

At times, however, a lack of -documentation meant that little evidence was available to -assess the performance . of a specific l aspect. In this case, discussions with key individuals in the process provided input. In some cases, the effectiveness of an aspect could be deduced. For instance, when hard-copy evidence of a turnover I package was lacking but the operations, maintenance and training groups had sufficierit information, it was concluded that a turnover process had occurred.

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The CYPDCTG was also not chartered to assess the adequacy of setpoint changes since setpoint changes are not design changes.

Setpoints are specified in calibration procedures and in some cases in Technical Specifications. The current proceuures provide for the appropriate evaluation of procedure and Technical Specification changes.

22 METHOD - WORK ORDER / PERMIT REVIEW Early in the project, the CYPDCTG identified the possibility of plant design changes being made using processes other than the PDCR process. The two other processes identified were the use of jumpel/ lifted keads/ bypasses, discussed in Section 2.2 and the use of work permits / orders. The CYPDCTG performed a quick survey to determine if plant design changes were made using work permits / orders. The survey identified several possible plant design changes. Based upon this finding, it was concluded that a review of all the work permits / orders performed between January 1979 and December 1984, was required.

Because of the number of documents involved, the PDCTG acquired the services of a contractor to perform this task. Impell Corporation was selected becadse of its technical expertise and its familiarity with the Haddam Neck Plant. The personnel assigned to this task by Impell Corporation had participated in the fire protection review of the CY design to meet Appendix R criteria.

l The CYPDCTG worked closely with Impell Corporation in developing, the procedures to perform the review of the work permits / orders. As much as possible, the methods used in evaluating PDCRs were used to review the WP/AWOs. It was recognized, that in order to review Ge 9100 work permits and 11,200 automated work orders, a streamlined process was necessary. However, no compromise was made on the evaluation of the impact on safety. The CYPDCTG reviewed and approved the Impell procedures prior to implementation.

During the screening of the work order / permits, the CYPDCTG performed audits of the work performed by Impell. The audits confirmed that the procedure was being applied properly. Following initial screening, Impell performed further investigations, including interviews with CY personnel and on-site inspections, to determine the changes that may have an impact on safety. During this period, frequent meetings were held between the CYPDCTC and . Impe!!

personnel for monitoring progress and factoring CYPDCTG input into the review.

The safety evaluations of the 65 work -permits / orders with safety significance were reviewed by the CYPDCTG. A meeting was held with the CYPDCTG and Impell, in which Impell presented a discussion of the change and the basis for the safety determination.

At that time, questions raised by CYPDCTC members were resolved.

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a each CYPCCTG member on each safety evaluation. The final report developed by Impell from this task has been incorporated into this final report as Attachment A-9.

3.0 RESULTS 3.1 RESULTS OF SCREENING REVIEW The PDCRs approved between January 1979 and December 1934 were evaluated under the screening process. There were 413 candidates, ranging from PDCR No. 282 through PDCR No. 694. Of these, 58 were cancelled or are still not PORC approved. Thus, 355 PDCRs were evaluated during screening. Of these, 35 were selected for detailed evaluation. This corresponds to 10% of the PDCR's evaluated in screening. A listing of the determination (Yes or No) for detailed evaluation for each PDCR is given in Table 3-1.

Table 3-2 provides a separate listing of the 35 selected for detailed review.

In addition, all jumpers / bypasses / lifted leads initiated prior to January 1,1935 and still in effect as of April 15, 1985 were screened for detailed evaluations.

The twelve items screened are shown in Table 3-3. No safety concerns were identified for these jumpers and none were identified for detailed evaluation.

3.2 RESULTS OF PLANT DESIGN CHANGE DETAILED EVALUATIONS Detailed evaluations were completed on the 35 PDCRs listed in Table 3-2.

Thirty-three (33) of the PDCRs were reviewed for " Impact on the Plant Design Basis", eleven (11) were reviewed for " Confirmation of Proper Implementation" and eighteen (18) were reviewed for " Provisions for Continued Safe Operation".

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. . n Eleven of the PDCRs reviewed resulted in no identified deficiencies. The remaining 24 PDCRs resulted in a total of 39 deficiencies requiring further evaluation or corrective action. Appendix A-6 provides a summary for each of the 35 PDCRs. Each summary gives a brief description of the change, the area (s) evaluated, the conclusions of the evaluation and a listing of the identified deficiencies. The deficiencies are listed in Table 3-4.

3.3 RESULTS AND SPECIFIC RECOMMENDATIONS OF THE PLANT DESIGN CHANGE PROCESS REVIEW 3.3.1 Introduction The CYPDCTG identified deficiencies in the design change process at Connecticut Yankee and then developed a disposition for each deficiency. The results of this effort are addressed in two aspects:

1. Process Corrections. When deficiencies in a. specific design change resulted from a shortcoming in the existing process, a process correction is warranted.

2. Process improvement. These recomraendations may not be the result of specific deficiencies or failures in the implementation of a design change. Typically,, they result from a recognized weakness in a particular phase of the process or the recognition of a more ef fective method,

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C . d ud v. . Q ;;, g To. assist fo!!ow-on actions, a summary listing of process-related recommendations is presented in Table 3-5.

3.3.2 Process Corrections Discussion To assess the effectiveness of the current design change process, the CYPDCTC evaluated 56 deficiencies that were identified on specific PDCR evaluations.

This review assessed the adequacy of the current CYAPCo plant design change procedures in light of past failures. The basic question asked here was "Would adherence to the current procedures prevent a recurrence of this deficiency?"

There the answer was negative, a process correction was deemed warranted.

The CYPDCTG debated the wisdom of modifying procedures for each deficiency in an attempt to prevent recurrence. While a procedure change could address each specific. instance of deficiency, this approach is not effective. Such procedure modifications would add to the length and complexity of procedures, with little likelihood of averting similar future deficiencies. This is particularly the case when a deficiency results from a lack of thoroughness in the design change process, such as faulty or incomplete engineering. A - number of deficiencies resulted from apparent non-compliance to procedures.

On this basis, most PDCR deficiencies were not resolved with recommendations to revise procedures. More fundamental reasons were sought by the CYPDCTG, and it was concluded that many such deficiencies could be avoided with improved

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reference documents and training. These reasons are summarized below:

1. In reviewing the PDCRs, the PDCTC has identified a number of short comings associated with the documentation of the current plant design and functional requirements for the system and its components. For example:

a. Drawings are not updated in a timely manner.

b. Boundaries between safety /non-safety equipment, QA, or pressure classifications (ASME class) are not clearly specified.

c. Design basis information is not collected into a sing!c controlled document. The FDSA has not been updated.

d. Normal valve positions are not clearly specified. The current P & ids are not an accurate source for this information.

e. Original specifications are not available for comparison when developing new specs.

f. While the valve list is used as a source for controlled documentation,it is not a controlled document.

These shortcomings hindered the deve.lopment of the PDCRs and contributed to the deficiencies identified in the detailed evaluations.

2. In reviewing the PDCR packages, a number of documentation deficiencies have been noted that appear to be the result of procedural non-compliance. Additionally, some deficiencies are the result of faulty or incomplete engineering. These deficiencies are correctable by improved training.

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3. Also, some deficiencies involved PDCR packages that were non-specific in their scope description, as is sometimes unavoidable when working in normally inaccessible areas. Other PDCRs were closed out without the completion of all work. These deficiencies warrant procedure changes.

In accordance with CYPDCTG Procedure 1.04, all deficiencies found in PDCRs were reviewed collec'tively to determine if programmatic deficiencies exist.

This review is summarized in Appendix A-3, with its recommendations incorporated into the body of this port.

Recommendations

1. Controlled documentation should be expanded to include the following as a minimum:

a. Current design basis analysis, including positions on current regulatory criteria, system / component design basis criteria, and licensing bases / commitments.

b. Seismic and QA classification (possibly in PMMS).

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c. Clear specification of boundaries between QA and safety.

classifications (possibly in P & ids and one line diagrams).

d. Normal and failure v'alve positions (current P & ids are not accurate).

e. Equipment history, including all specifications used to purchase the equipment (possibly in PMMS).

f. Valve list (possibly in PMMS).

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• Item (a) could be performed by the updating and controlling of the FDSA.

Consideration should be given to maintaining original plant specifications as contro!!cd documents, much like original plant drawings. For plant design changes, these specifications would be updated and revised, as necessary.

2. Controlled documentation, especially drawings should be updated in a timely manner. In particular, generation of verified "As Built" drawings should be performed as soon as possible and not delayed until the close out of the project. This is especially important for projects which extend beyond one refueling outage.

3. Training should be provided to give guidance for content and wording requirements in the PDCR package. This training should emphasize the need for thoroughness and technical excellence. The NEO procedure familiarization training course is too generalized for training in the desi6n change process. Detailed training is required on all NEO procedures.

Training should highlight some of the deficiencies identified by the CYPDCTG, such as a) the importance of seismic requirements, b) consideration of secondary effects, c) when a PDCR is required, and d) the need to avoid unsupported qualitative statements. To ensure uniformity in -

the process it is recommended that the training should be performed by the training department.

Management should work to improve on-the-job training through work assignments. To obtain training and avoid errors, new engineers should l

work more in support of experienced engineers, rather than assuming direct project responsibility.

4. For cases where a PDCR scope statement must be generalized, NEO 3.03 should require the PDCR package to be revised when the work scope is more specifically determined based upon field inspections, or define an alternate means of review and approval. NEO3.03 should also specify that if a PDCR is closed out without the completion of all work, the completed work must be identified, and the impact on the safety evaluation assessed.

5. The implementation of NEOS.04 " Safety Evaluation of Proposed Changes to

Station Procedures" should be expedited to ensure adequate technical review of proposed changes to safety related procedures.

6. The effectiveness of the Quality Assurance Program to ensure compliance with the design change process procedures should be evaluated. The number of deficiencies resulting from procedural non-compliance indicates

> a potential need to increase the QA involvement in this area.

3.3.3 Process Improvement in the process improvement area, identified deficiencies.were quite varied in type and scope. To permit a better assessment of the CYPDCTG findings in the design change process, .the following categories have been established:

1. Definition Deficiencies - deficiencies that result from a lack of a clear definition of work scope or requirements.

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2. Interface Deficiencies - deficiencies that result from inadequate interactions of groups or individuals.

> 3. Completeness Deficiencies - deficiencies that result from a lack of I thoroughness.

4. Process / Procedure Deficiencies - deficiencies that specifically relate to the overall process or specific procedures.

1 A number of the recommendations presented below deal with the concept of an integrated review. This concept consists of a detailed multi-discipline process where experienced discipline individuals with broad oversight evaluate the change to consider such things as safety significance, system interactions, technical requirements, special requirements, cumulative effects, location dependent issues, procedure requirements, etc. This type of review could occur at both the conceptual stage and the approval stage of a design change. It could be performed by a new group, a subcommittee of the NRB, or possibly through the current line organization. Appropriate procedure changes would be necessary to implement the preferred approach. -

The following presents the results of the CYPDCTG review by category.

3.3.3.1 Definition Deficiencies Summary -

In reviewing the PDCRs, Work Permits (WPs) and Automated Work Orders (AWOs,) a number. of deficiencies related to the definition of- plant design e <

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a. A number of activities were performed as maintenance that should have been processed as a PDCR.

b. In reviewing the PDCRs, a number of PDCRs have been identified in which the description of the change was not c'early provided.

Discussion

1. There are several contributing factors in the misuse of work permits / work orders to make plant design changes:

a. It is becoming difficult if not impossible to replace plant components with identical models . Some original equipment is no longer ,

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manufactured and is obsolete. Some changes were a result of an attempt to replace obsolete or unavailable equipment with comparable equipment.

b. Some changes are so minor and remote to safety that the PDCR process is not necessary.-

c. Some activities fall into a " gray" area between plant design change and maintenance activities (e.g., SG tube plugging and Fermaniting).

d. The current definition of a plant change in NEO Procedure 3.03'does not appear to be incompassing enough. The " design documents" mentioned in the definition are not clearly specified.

e. Sufficient training or guidance on the meaning of the definition has not occurred.

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2. Since the PDCR process is a lengthy and time consuming one,it is difficult to use the PDCR process for changes that require a tight schedule 10.is is a particular problem for changes that require a survey or walkdown prior to i

definition of the PDCR. By necessity, this has lead to approval of PDCRs with a genera! definition rather than a detailed definition of the change.

Another undesirable practice is the use of one PDCR to cover a number of seemingly unrelated changes (e.g., PDCR 461, Reactor Cavity Pool Seal and Neutron Shield). This practice appears to dilute the overall review of each change.'

1 Recommendations

1. A better definition of a plant design change should be developed. It is

! recognized that any definition is subject to interpretation, but the' currerit definition is too vague to conclude whether a PDCR is necessary for areas such as:

i

a. Heat exchanger (including steam generator) tube plugging.

b. Fermaniting.

c. Replacement with equivalent components.

d. Insignificant changes that are remote to safety (i.e., changing telephones, adding a'ir conditioners).

e. Modifications to vendor owned and maintained equipment.

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L _l The CYPDCTG recommends that the definition of a plant design change be plant changes that 1) require a change in design documents (the current definition) or 2) changes in the form, fit, material, or function of plant equipment.

2. To ensure that all work that results in a plant change is properly identified, it is recommended that a technical review of AWO's be performed to determine if a plant change is being proposed. AWO's that specify activities such as surveillance or calibration, need not be included in the technical review.

3. In order to reduce the time consuming reviews required for plant changes having no safety significance, a streamlined process is recommended for these types of changes (see Figure 3-1). A plant design change would be d{etermined to.be in one of three categories:

a. change requires a PDCR (i.e., the current PDCR process), or

b. change is " remote to safety" (requires only justification for this categorization), or

c. change is a replacement with an equivalent component (requires only justification for this categorization).

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The AWO can be used 'to identify the above category of work being performed.

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b b hd 5..<. ; J The documentation for a change " remote to safety" can be simply the following:

a. a description of the change, and

b. a conclusion that the change has no functional impact.

This documentation constitutes the safety evaluation.

The definition of a " functional change" given in NEO 5.11 can be supplemented as required to determine functional impact. That is, a change is." remote to safety"if it does not cause any of the following:

a. Alteration of mechanical or structural ~ integrity for safety related systems.

b. Alteration of seismic qualification.

c. Alteration of physical and electrical separation requirements for safety related systems.

, d. Alteration of intended electrical circuit design function for safety related systems,

e. Introduction of materials not specifically qualified for the given application or environment.

f. Alteration of the plant fire hazards analysis,

g. Alteration of the control, operation, performance, maintainability, or.

accessibility for test or inspection for safety related' systems.

h.- Alteration in plant flood protection.

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i. Generation of a missile, means, etc., of disabling or rendering inoperable a safety-related component, structure, electrical circuit, etc. (secondary effects).

j. Generation of a potential environmental impact.

k. Alteration of the plant security system.

4. The current PDCR process appears to be complex and time consuming. It is recommended that an evaluation be made to identify ways of streamlining the process. For example, if a system integration group is created, it may be possible to use such a group to allow a streamlined process by combir.ing technical reviews.

5. Revise NEO3.03 to prohibit a single PDCR being used to cover several unrelated changes. Instead, several PDCRs should be used, one for each change.

3.3.3.2 Interface Deficiencies Summary Several deficiencies have been noted in the selection of the disciplines involved in reviewing a given PDCR. Without proper selection of the disciplines involved, a complete safety review for. multi-discipline issues .and secondary effects cannot be accomplished.

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Discussion

l. The integrated safety evaluation performed by the Safety Analysis Branch is not a multi-discipline review. As such, the term " integrated safety evaluation" is a ' misnomer. The " integrated safety evaluation" is in fact a discipline evaluation where only the impact of the change on the accident analysis is assessed. It is only an integrated review in that the accident response is the result of the combination of effects of the various systems and components. The integrated safety evaluation requires as an input, the results of multi-discipline reviews. It is not a means of identifying secondary effects, multi-discipline issues or for replacing Failure Mode and Elfects Analyses (FMEAs).

2. The NRB is a multi-discipline review board that has the appropriate expertise and the means for performing multi-discipline reviews. However, the NRB has not performed the depth of review to identify system interaction and secondary effects in all instances. In addition, the NRB reviews usually occur af ter the PDCR process. This is very late for identifying safety concerns.

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3. Licensing has, in some instance,s, performed an integration function for coordination of changes to meet major licensing issues. However, this is the exception rather than~the rule.

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Recommendat' ions - -

1. An improvement is required in the performance of integrated multi-discipline reviews. The emphasis of these reviews is the identification of system interactior.s and secondary effects of changes. A possible way of improving the integrated reviews, for example, is to establish a system integration group responsible for these functions.

2. Guidance is required to assure that all of the appropriate disciplines are selected to be involved in the review and development o ~

PDCR documents. Training for project and plant engineers would improve the selection of disciplines.

3.3.3.3 Completeness Deficiencies Summary In reviewing the PDCRs, the PDCTG has identified a number of generic issues that do not always receive the depth of review that is required. For example:

a. The cumulative effect of a number of changes that have taken place

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over the years is not always addressed. While each' individual change may not be significant, the cumulative effect of many changes may have an impact.

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b. Secondary effects are not always completely addressed, especially in assessing the impact of already existing equipment in an area where new safety-related equipment is being added.

c. -. Qualification of equipment has not been performed on a consistent basis. In some instances, qualified equipment is added to existing non-qualified systems. Taking credit for the upgrade on a system basis is questionable.

These deficiencies point to a need for an improvement in the integrated approach in the development and review of plant changes.

Recommendations

1. An improvement is ' required in the review and coordination of multi-discipline and system interaction issues. A possible way of effecting an improvement is the establishment of a system integration group responsible for.these functions.

2. Some controlled documentation should be developed that can be used to determine the impact of location dependent issues (e.g., - fire protection, seismic, flooding, EEQ, etc.). The effects of new equipment on previously existing equipment in that location must be evaluated. Likewise the potential effects of previously existing equipment in the area on the new equipment being added must be addressed. This could be incorporated in an updated FDSA or a data base system.

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3. A method for ev_luation of the cumulative effect of a number of minor chan6es should be developed. For example, when core boring a structural wall, the effects of previous core boring on 'the same wall should be considered. Also, the cumulative effects of small components added to the Main Control Board may be important whereas individually they are qualitatively analyzed away.

3.3.3.4 Procedures Deficiencies Summary These comments address deficiencies in the current NEO and GEC procedures.

The actions required to correct these deficiencies fall into two categories:

a. Development of new NEO procedures.

bl Revision of current NEO procedures.

Recommendations

1. Most engineering and design functions occur under a project assignment.

The only NEO level procedure that controls activities under a project assignment is NE03.04. This is more of an administrative rather than a process control procedure. A specification of discipline functions performed under a plant design change is required to determine how the detailed design will proceed. A NEO procedure is required in this area.

Important areas for consideration are:

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a. Overall design requirements,

b. Conceptual design review.

c. Interface specifications.

d. Integration and multi-discipline requirements.

e. Design documentation requirements.

Current GE & C procedures may be adequate to address these concerns.

They should be elevated to the NEO level and integrated into the design process. One good candidate is GEC2.07, Project Description.

2. Specific procedure revisions have been identified as shown in Table 3-6.

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4.0 CONCLUSION

S / RECOMMENDATIONS

4.1 CONCLUSION

S - SCREENING REVIEWS In reviewing the PDCRs identified for detailed evaluations, some trends 4

have been noted. As expected, approximately half of these PDCR's were approved prior to 1981. This tends to confirm the-improvement in the PDCR packages as experience, training and improved procedures have been developed. This is shown in Figure 4.1. Nine PDCR's approved in 1984 have been selected for detailed evaluations. This does not represent a decline in the quality of the design process, but reflects the increase in the number of PDCR's processed. In addition, several of these PDCR's were selected because of questions on seismic classification, QA qualification and testing requirement's for systems already in place prior to the change and unaffected by the change itself. This is further supported by the increase in thoroughness of the PDCR packages for the changes approved in 1933 and 1984.

The questions raised about the PDCR's that lead to. the requirement for detailed review have been categorized as shown in Table 4-1. By far the most predominant issue to be addressed is seismic qualification of equipment, having been identified as a question on approximately half of the PDCR's. Some of them are simple issues such as the addition of a component to the main control board, whereas others involve the seismic design of an entire system such as service water or boric acid.

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o Of these questions raised during screening, none have been determined to require immediate corrective action. Identified concerns are addressed in the detailed evaluation section.

During the screening process a number of concerns related to the design process itself were also identified. The appropriate forms were completed to ensure these concerns are addressed during the CY PDCTC's review of the design process.

4.2 CONCLUSION

S - DETAILED EVALUATIONS The re' view of the PDCRs approved over the six year time frame has demonstrated that changes have been made with concern for both quality and safety. This is supported by the fact that deficiencies have been identified in only 24 PDCRs. This represents only 7% of the PDCRs reviewed in this project.

, In addition, in several instances, the identified deficiency is not related to the change itself, but related to the original design basis or components not changed by the PDCR. Some deficiencies have been identified through other programs already in place at NU such as the Integrated Safety Assessment Program. As such, some of the deficiencies ' identified by the CYPDCTG are not new or unknown within the NU organization.

Of the identified deficiencies,'one was deemed significant enough to _ warrant immediate action. The deficiency was associated with PDCR 330 "RC Pump Component Cooling _ Water and Seal Water Return Isolation Modification".

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, tj d?. / U '.d ; U r) b Charging system components may be used fer the post LOCA recirculation mode.

However, leakage from the charging system components is not accounted for in the Technical Specification or calculations. Since thyroid dose calculations show little margin to the 10CFR100 limits,'the addition of leakage from the charging system' components may be a serious problem. This concern was identified by

) the CYPDCTC to the Vice President of Nuclear and Environmental Engineering on July 2,1933. A copy of this letter is included in Appendix A-6.

It is important to note that this deficiency was not caused by the PDCR itself.

The use of charging pumps for post-LOCA recirculation is not directly related to removal of RC pump support systems from containment isolation. Ilowever, the deficiency was identified through an extension of the review to include the entire containment isolation system.

Another contributing factor to the deficiencies identified with this PDCR, is that this change was one of a number of immediate changes required after the TMI accident. The requirement for immediate implementation and the heavy 4 demand on manpower resources at the time, appear to have had an impact of the thoroughness of the review of the PDCR. Perhaps, too much reliance was placed on NRC guidance and generic reviews by the Industry Owr.:rs Groups.

1 While' not identified as an immediate concern, two major areas have been identified that may require extensive evaluation and corrective action.

1. An evaluation is necessary to clearly identify the components and system boundaries necessary ' to allow cold shutdown following a 1

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design basis earthquake. The evaluation must consider protection of i .the required equipment from the impact of non-seismically qualified equipment, the primary and secondary system water requirements and the cooldown capability. An evaluation of the seismic qualification of the service water system is required.

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! 2. An evaluation of the containment isolation system is required. A number of deficiencies have been identified with respect to the valves and piping in the isolation system. An integrated study of the-i isolation of the RC pump support systems is necessary to resolve the j conflict in requirements for the availability of RC pumps and i containment isolation.

i f The above discussion highlights the deficiencies that the CYPDCTG has deemed i

j as most important. All deficiencies from the detailed evaluations are shown in j Table 3-4. Process deficiencies have not been included in this table. The deficiencies have been collected into the following categories:

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a. Design - questions about the adequacy of the design of a system or f

component.

I b. Design / Seismic _- questions about the_ seismic qualification of system or component. While a design area, this aspect has been singled out due to the number of occurrences.

j c. Design / Safety Analysis - questions about the impact of the change on the design basis analysis and documentation.

d. ' Testing - questions about testing to confirm proper implementation of the change.

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e. Procedural . questions about implementation of the change into Station Procedures to assure continued safe operation.

The results of the categorization are shown below:

Number of Percentage of Classification Deficiencies Total Deficiencies Seismic 13 33?6 1

Procedural 8 21?6 Design 7 1895 Testing 5 13?6 Safety Analysis J 1595 39 100?5 The most common area of deficiency is in the engineering / design area and in particular seismic qualification of components. The three design categories, including seismic and safety analysis account for 66?6 of the deficiencies.

Table 3 4 also indicates deficiencies that had been identified through other programs currently in place -in the NU organization, such as the Integrated 1- Safety Assessment Program and the CY FDSA Chapter 10 Reanalysis Program.

Eleven of the 39 deficiencies fall into this category. Thus, only 28 of the deficiencies may require the establishment of new projects or studies. Current

, programs related to the eleven other deficiencies should consider CYPDCTG findings because additional considerations have been developed in some cases.

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4.3 CONCLUSION

S / RECOMMENDATIONS -

REVIEW OF THE DESIGN CHANGE PROCESS The conclusion of the CYPDCTG are assessments of the significance of the ,

results presented in the previous section. Our conclusions are:

1 i 1. The current plant design change process, as defined by plant, i Generation Engineering and Construction, and Nuclear Engineering and Operations procedures, is effective. The system has sufficient controls over the plant modification process.

This conclusion is firmly supported by the CYPDCTG review of the

! INPO Good Practice document (Reference 1). In that review, no 1

significant shortcomings in the CYAPCo process were identified.

Similarly, reviews of design change program's from two other utilities found the CYAPCo program to be strong. 'A com'parison of the INPO

Good Practice and the CY design change process is presented in i

Appendix A-7.

2. While the process framework is effective, compliance with the requirements either through ignorance or lack of' concern has been inadequate, at times. Staffing levels may be contributing to the degree of compliance. The task group found a correlation between i

the work load duririg the period just after TMI and the number of deficiencies. The company is now in a work force stabilization period with restrictions on new hiring. At the same time construction of Millstone Unit 3 has removed a significant number of experienced people from ' the operating units support organizations. These two

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forces have had a dramatic effect on some groups, causing significant increases in individual workloads. . , This ' inevitably affects the i

thoroughness of some projects. .

3. Recent revisions to the NEO Procedures have improved the controls

., on the design change process. The process, however, is cumbersome.

Some CYPDCTG recommendations intend to streamline the process, but their impact is probably small. Some of the procedures appear to be -disjointed, apparently due to parallel development and revision.

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Some modifications for consistency are needed.

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4. As stated in the recommendations, a number of deficiencies should be

, corrected in the process. These deficiencies do not have a significant adverse impact on the effectiveness of the entire program.

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5. Certain activities already in process within NU address some of the i

CYPDCTG recommendations. Specifically, a proposed configuration i

control program will establish an adequate compilation of updated

• j design information, if it meets its goals. The' CYPDCTG is i

concerned, however, about the timely completion of such a project.

i Additionally, the current effort to correct P&lDs is a n'ecessary activity.

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6. As stated in 'the recommendations, numerous improvements can be made to the plant design change process. A summary of all process

- recommendations is presented' in Table 3-5. A concerted -effort l'

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should be made to ensure all procedures interrelate effectively.

Confusion results when one procedure offsets the requirements of another procedure. Care must be taken during procedure revisions to eliminate such conflicts.

7. The numerous instances of "non-compliance" to procedural requirements can be reduced by more effective training. Training in specific procedures should be conducted by the Training Department and be mandatory for all project engineers, NUPOC engineers and supervisors.

4.4 CONCLUSION

S / RECOMMENDATIONS - WORK PERMITS / AUTOMATED WORK ORDERS The CYPDCTG concludes that Impell performed a very competent review of WPs and AWOs. Their review was thorough, probing and unbiased.

CYPDCTG audits of the Impell effort found that their work was complete and good judgment was exercised.

The Impell final report is provided in Appendix A-9. In that report, Impell made eleven (11) recommendations and observations. The CYPDCTG's disposition'of the Impell recommendations and observations is provided in Appendix A-10.

Although a few work permits / orders have been identified for further evaluation, no negative safety consequences or deficiencies have been identified to date.

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4.5 CONCLUSION

S / RECOMMENDATIONS -

SUMMARY

The reviews ordered by the NRC were completed by the CYPDCTG as required by its charter. As presented in the Executive Summary, the CYPDCTG review found that past plant design changes and the current design change process contain some deficiencies. As a whole, however, the CYPDCTG findings do not reflect any major problems in these areas.

The results of the CYPDCTG are summarized in two tables in the report:

1) Table 3-4 lists 39 deficiencies that were identified in past plant desgin changes. Deficiency 14 on that table has already been reported as an immediate safety concern.

2) Table 3-5 lists 18 recommendations for corrections or improvements in the current design change process.

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FIGURE 3 Propossd Processing of Plant Design Changes l WORK IDENTIFIED l

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NO DESIGN CHANGE? YES (i.e., DOES IT CHANGE FORM, FIT, MATERIAL OR FUNCTION OR f

EFFECT DESIGN DOCUMENTS?)

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0 COMPLETE COMPLETE EOUIVALENT i PDCR " REMOTE TO SAFETY" COMPONENT PACKAGE JUSTIFICATION EVALUATION w

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AUTOMATED WORK ORDER IDENTIFIES

/_7 NOT A PLANT DESIGN CHANGE

/_7 PDC REMOTE TO SAFETY *

/_7 . EQUIVALENT COMPONENT *

/_7 WORK APPROVED UNDER PDCR

• FOR AWO CLOSE0UT, DESIGN DOCUMENT UPDATE MUST BE SUBMITTED 9

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4 PDCR's Requiring Detailed Review Categorization by Approval Date

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• - Number of PDCR's Reviewed 125 " # - Number requiring detailed evaluation 113 6

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A M6WA WMA 'X U HA 79 80 ~81 82 83 84 YEAR 1 i

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, TABLE 2-1 i PROCESS REVIEW MATRIX 1

-s OBS FOCRNO TITLE LEAD' ENG DESIGN CONSTR INSP TEST TURNOVER TRAINING 1 290 REROUTE OF CHARGING PLR1P POWER SUPPLY GEC H H H H H H H I

2 294 RHR PURIFICATION FLON CONTROL VALVE GEC H H H H H H N I 3 330 DIESEL SEQUENCING TINERS BAT H H YES YES YES N N 4 306 CONTAlt#1ENT FAN FILTER tit 1ERS RAC N N N N N N N 5 314 VITAL AREA PROTECTION OF CONTROL R00ft DGO N N YES H H H H 6 326 FIRE SUPPRESSION SYS ADDITONS A t1005 NSK N N N N N N N 7 332 AUX FEEDPUNP BEARING OIL C00 Lits SYS NSK H H YES N N N N 8 . 333 C0t15USTIBLE GAS DETECTION SYSTEt1 RAC YES YES N N YES YES N 9 344. CONTAItR1ENT ISOLATION RESET N00 BAT YES YES YES YES YES^ YES YES 10 347 RCS VENTIts SYSTEtt RAC YES YES N N YES N YES

!! 368 'RCP SEAL HATER SUPPLY RAC H H H H N N N 12 371 H2O LEVEL /H2%/ PRESS IN CONT THI 2.1.8 RAC N N N N YES N YES 13 380 RCP CCW AND SEAL WATER RETRN ISOLATION RJS YES YES YES YES YES VES YES 14 384 AUTot1ATIC INITIATION AUX FEEDWATER t1SK YES YES H H YES H YES 15 388 PRIttARY VENTILATION STACK SPRAY RING GEC H H H H H H H 16 397 PAtt AUX HAIN CONTROL BOARO DGD H H YES N N YES N 17 401 SAFETY GRADE AUTO INITIATION AUX FM HSK H H H H H N N 18 406 BUILDING F100IFICATION PROJECT DGO N N N N N N N 4 19 418 PORV AND BLOCK VALVE LOGIC t100 TO 2/3 RAC H H H H H H H 20 436 UPGRADE OF SFB NORTH CRANE (CR-5-IAI GEC H H H H H H H 21 443 FLOOO PROTECTION t1005 DGO N N N N YES H N 22 459 REEVALUATION OF SAFETY RELATED PIPING GEC YES YES H H H H H 23 460 HACSS RJS YES YES YES YES H H H

! 24 461 NEN RX CAVITY POOL SEAL 4 NEUT SHIELD -RAC YES YES H H H H H

! 25 486 TERRY TURBINE STEAtt CONTROL VALVES HSK H- N YES YES YES YES YES j 26 513 BORIC ACIO LINE RELOCATION H H GEC H H N N N 27 592 CHARGING PUt1P MODIFICATIONS BAT YES YES YES YES YES YES YES j 28 604 HASTE GAS /H2-N2 SUPPLY BAT H H H H H H YES 1

!, 29 626 REPLACE FOXBORO 6130t1 FN FLON TRAN$t1IT RJS H H YES H H H H

j. 30 634 REPLACE FOXBORO PRESS TRANS PT403 4 404 t1SK N N N N N N N

+ 31 652 SG PRIt1ARY HANWAY COVER STUD TENSIONER DGO N N N N N N YES I

32 653 VITAL INVERTER CABINET VENTILATION RJS VES YES YES YES N N .N 33 660 SFP HEAT EXCHANGER RELIEF VALVE ALT H H H H H H H 34 671 STORAGE OF SPARE CRD'S IN CONT Sut1P GEC H H H H H H H 4

35 684 REPLACEt1ENT OF RCS LOOP RTO'S BAT H H H H YES N N j 36 422 INSTALL POST ACCIDENT SAMPLING SYSTEN RAC YES YES YES YES TES YES YES 37 544 TAta( HEATING SYSTEtt 1100IFICATION GEC YES YES YES YES YES YES YES 38 547 TANK HEATING SYSTEtt t100IFICATION GEC YES YES VES N YES N- 'N 39 622 CORE CCCLIHG USING PORV'S (FEED /BLEEDI RJS YES YES N N YES N N 40 597 RHR VALVES INTERLUCK HSK YES YES YES .YES YES YES YES 4

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o s TABLE.h-2 PDCRs REQUIRING DETAILED EVALUATION OBS POCRNO TITLE 1 290 REROUTE OF CHARGING PLHP POWER SUPPLY 2 294 RHR PUPIFICATION FLOW CONTROL VALVE 3 300 OIESEL SEQUENCIttG TIMERS 4 306 CONTAINMENT FAN FILTER TIMERS 5 314 VITAL AREA PROTECTION OF CONTROL ROOM 6 326 FIRE SUPPRESSICH SYS A00! TONS 4 MODS 7 332 AUX FEEOPUNP BEARING OIL COOLING SYS 8 333 COMBUSTIBLE GAS DETECTICH SYSTEM 9 344 CONTAINMENT ISOLATION RESET MOD 10 347 RCS VENTING SYSTEM 11 368 RCP SEAL WATER SUPPLY 12 371 H2O LEVEL /H2%/ PRESS IN CONT TMI 2.1.8 13 380 RCP CCW Aff0 SEAL WATER RETRN ISOLATION 14 384 AUTOMATIC INITIATION AUX FEE 0 WATER 15 388 PRIMARY VENTILATION STACK SPRAY RING 16 397 PAN AUX MAIN CONTPOL BOARO 17 401 SAFETY GRADE AUTO INITIATION AUX FW 18 406 BUILDING MODIFICATICH PROJECT 19 418 PORV AND BLOCK VALVE LOGIC MOD TO 2/3 j 20 436 UPGRADE OF SFB NORTH CRANE (CR-5-1Al 21 443 FLOOD PROTECTION M005 22 459 REEVALUATION OF SAFETY RELATED PIPING 23 460 HACSS 24 461 NEW RX CAVITY POOL SEAL 8 !!EUT SHIELD 25 486 TERRY TURBINE STEAM CCHTROL VALVES 26 513 EORIC ACIO LINE RELOCATION 27 592 CHARGING PUMP MODIFICATIONS 28 604 WASTE GAS /H2-H2 SUPPLY 29 626 REPLACE FOXBORO 613DM FW FLOW TPAHSMIT i 30 634 REPLACE FOXBORD PRESS TRANS PT403 8 404 31 652 SG PRIMARY MANWAY COVER STUD TENSIONER 32 653 VITAL INVERTER CABINET VENTILATION 33 660 SFP HEAT EXCHANGER RELIEF VALVE 34 671 STORAGE OF SPARE CRD'S IN CONT SUMP 35 684 REPLACEMENT OF RCS LOOP RTO'S i

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8 9 e o TABLE 3-3 LISTING OF JUMPERS / BYPASSES / LIFTED LEADS 085 JUttPHO APPRL SCREEN LEA 0 Fits TITLE 1 7 71084 42385 RAC H REMOVE RMS-23 2 8 71084 42385 RAC H ret 10VE RNS-23 3 35 103184 42685 RAC H RECORDER FOR PRT LEVEL 4 36 40883 42385 RAC H LIFTED LEAD - LOSS OF AC TEST 5 38 90983 42385 RAC N EG2A DIESEL Al#UI ALARN RELAT 6 40 122184 42685 RAC H ADJUST LEAD A LOG OF PN417 7 42 100184 42385 RAC H tJPS STATIC IPNERTER 8 43 118684 42685 RAC H Cot:8USTIBLE GAS DETECTORS 9 44 181684 42685 RAC H C0ftUSTIBLE GAS DETFCTORS 10 45 113684 42685 RAC H C0tfCUSTIBLE GAS OF;ECTCRS 11 113 90689 42685 RAC H OIL LEVEL ON AIR CottPRESSOR 12 116 81984 42385 RAC H OIL LEVEL CN Alf C0ttPRESSOR 4

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Table 3-4 DEFICIENCIES IN SPECIFIC PLANT DESIGN CHANGF3 (Consult Appendix A-6 and CYPDCTG Files for Details)

Eieficiency Number PDCR No. and Title Deficiency Category 1 294 Piping is not seismically qualified. Seismic

• RHR Purification Flow Valve Reach Rod 2 300 - Seismic Evaluation of the sequencing timers. Seismic Diesel Sequencing Timers 3 306 No procedure to ensure continued proper functioning of Procedural Containment Fan Filter the timers.

Timers 4 326 Seismic evaluation of fire suppression system located Seismic Fire Suppression System above safety related equipment.

5 Impact of fire suppression fluids sprayed on safety Design related equipment.

6 333 No procedures to establish maintenance and calibration Procedural

• Combustible Gas Detection of the system.

System 7 344 . inadequate training plan and procedures to adequately Procedural Containment Isolation identify all steps necessary to clear SI/HCP block.

Reset Modification 8 347 Uncertainty of ability of valves to function with water. Design Reactor Coolant System Venting System 9 Failure to test valves against full dif ferential pressure. Testing

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Deficiency ,

Number PDCR No. Deficiency Category 10 347 Failure of AOP 3.2-22 to utilize revised calculations Procedural on ventipg times.

11 347 Failure to verify actual plug movement in surveillance Procedural tests.

12 368 Uncertainty of seismic qualification of the RCP seal Seismic -

, RCP Seal Water Supply water system.

Valves 13 371 Inconsistent procedures as related to calculations. Procedural TMI 2.1.8 Additional Equipment to Follow Course Accidents 14 380 Inadequate dose analysis and Tech. Spec. treatment of Safety RCP Component Cooling _

charging system outleakage. Analysis Water and Seal Water Isolation Modification

. 15 380 Unevaluated impact of modification as related to Safety reduced containment integrity. Analysis 16 380 Inadequate procedures to assure prompt manual valve Procedural closure.

17 380 Seismic qualification of isolation valves and Seismic associated piping.

18 . 380 Faulty logic for activation of valve FCV-608. Design Potential release path from containment via seal Design

• 19 380 return line and relief valve CH-RV-332.

20 380 Resolution of CYPDCTG Report " Containment Piping Design

• Penetrations".

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Deficiency Number POCR No. and Title Deficiency Category 21 384/401 Automatic Questionable Design Basis Analysis of the AFW Safety

• Initiation of Aux. system. Analysis Feedwater 22 388 Evaluate the means of accomplishing cold reactor Seismic

• Primary Vent Stack shutdown following a seismic event utilizing only Ring seismically qualified and protected equipment.

23 418 Failure to seismically qualify relays and mounting. Seismic PORV and Block Valve Logic Mod.

24 436 Upgrade both fuel handling cranes equipment and QA Seismic

• Upgradeof Spent Fuel classifications and refueling manipulator to QA Building North Crane Category I.

CR $-1 A 25 443 Failure to test or verify adequacy of cooling of Testing Flood Protection service water pumps with flood protective covers in Modifications place.

26 459 Re-evaluate scope of project to ensure safe reactor Seismic

• Re-evaluation of shutdown to cold conditions following a seismic event.

Safety Related Piping 27 486 Inadequate consideration of operability with loss of Design Terry Turbine control air.

Steam Control 28 Incomplete consideration of error analysis in verifying Testing the capacity of the system.

29 592 Failure to assess impact of change of pump curve on Safety Charging Pump Design Basis Analysis Analysis f

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Deficiency number PDCR No. Deficiency Category ,

30 592 Failure to assess degraded voltage operability of main Design lube oil pump motor.

31 592 Failure to upgrade several procedures. Procedural 32 626 Failure to establish the uncertainty of flow Testing Replacement of Foxboro measurement.

Feedwater Flow Transmitters 33 626 Failure to determine seismic adequacy of the Hagen Seismic flow transmitters.

34 634 Failure to seismically qualify instrument tubing. Seismic Replacement of Foxboro Pressure Transmitters PT403 & PT404 35 634 Failure to clarify Reg. Guide 1.97 submittal. Safety Analysis 36 653 Failure to conduct seismic analysis on cabinets Seismic Vital Inverter with actual component locations.

Cabinet Ventilation 37 660 Failure to perform compit.te seismic analysis of Seismic ,

Relief Valve for service water system.

Spent Fuel Pool Heat Exchanger ,

38 684 Incomplete review of acceptance limits for the RTDs. Safety

• Replacement of RCS Analysis Loop RTDs 39 684 Failure to conduct response time tests. Testing

• O Identified as action items within the framework of current NU programs prior to CYPDCTG Review.

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g TABLE 3-5 DESIGN CHANGE PROCESS RECOMMENDATIONS Page Number Type Recommendation Reference 1 Corrective Expand scope of controlled documentation to include design bases, classifications, and other information.

2 Corrective Improve timeliness and quality of "as built" documentation updating.

3 Corrective Provide training on the plant modification process.

4 Corrective Revise NE03.03 to address PDCRs of general scope and PDCRs not completed.

5 Corrective Expedite the implementation of NEO3.04.

6 Corrective Evaluate the effectiveness of the QA program to ensure compliance with process procedures.

7 Definition Develop a more effective definition of " plant design change".

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Page Number Type Recommendation Reference 8 Definition Perform a technical review of specified categories of Automated Work Orders.

9 Definition Develop a simplified means to document plant design changes that are " remote to safety" or

" equivalent component".

10 Definition Attempt to streamline PDCR process.

11 Definition Revise NEO3.03 to prohibit unrelated changes on a single PDCR.

12 Interface Provide improved multi-discipline reviews and integration.

13 Interface Provide guidance / training on the interface needs/ reviews on technical documents.

14 Completeness improve incorporation of system interaction criteria and secondary effects in design changes.

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Page Number ' Type. Recommendation Reference 3

15 Completeness Develop controlled documentation for evaluating the impact of location dependent issues (e.g., seismic, fire protection, flooding, EEQ).

16 Completeness Develop means to evaluate the cumulative effects of a number of minor changes (e.g,

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core boring, control board additions).

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17 Procedures Develop an NEO-level procedure on project descriptions, perhaps elevating GEC Procedure 2.07. I I

18 Procedures Address the recommendationsin Table 3-6 on specific procedure changes. '

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TABLE 3 PROCEDURE DEFICIENCIES Procedure Deficiencies NEO7.01 Add requirement for the appropriate QC group and the Design group to be responsible for verification o: "As Builts".

NEOS.05 Design verification can be performed using independent review, alternate calculation or testing. The procedure should be revised to require a decision and indication of the method of design verification.

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NEO7.03 1. Revise to include review and approval of test 1

procedures.

2. Revise as necessary to include NUSCO managers / supervisors in the Instruction Section to reflect the Responsibility Section.

3.' Clarify the definitions for Retest, Pre-i

! Operation Test, Phase I Test and Phase il test to indicate the distinction between the i

terms.

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. o Procedure Deficiencies

4. Reorder as necessary the substeps in Step 6.3.

5. Clarify the term " ultimate acceptance".

NEO7.02/3.03 Step 6.2.2.2 of 7.02 specifies walkdown criteria be determined in the PDCR. However, this is not specified in NEO 3.03. Revise either 7.02 or 3.03 to be consistent.

NEO7.02 De fine the requirements for a pre-construction meeting that is shown in the flow chart.

NEO7.01 1. Resolve conflict between parallel review specified in step 6.16 and sequential review shown in the flow chart for OUES and QC.

4

2. Reword step 6.2.4 to clarify the timing of

inspection requirements. The wording implies that inspection is completed prior to approval of work order.

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A Procedure Deficiencies

3. Define Unit Engineer as indicated in step 6.4.

4. Step 6.16 is performed by the Job Supervisor w hile the flow chart shows that it is priormed by the originator. Resolve this conflict.

NEO7.01,7.02 and 7.03 Resolve conflicting definition of when turnover occurs.

NEOS.15 Develop and release in a timely manner.

NEO5.11 Add documentation indicating whether or not there is an impact on the safety or environment reviews on Figure 7.2.

NEOS.05 Some items do not seem appropriate for the checklist, Figure 7.1. For example, 31, and 32 appear to address questions raised after the document review has been completed. Review each item on the list for appropriateness and revise as necessary.

NEOS.05/3.03 Clarify the application of the design input documentation requirements. For example, refer to NEO5.05 in step 6.2.3.4 of NE03.03.

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1 TABLE 4-1 Categorization of Concerns from the Screening Review Category No. PDCR #

Seismic 17 290, 294, 306, 326, 332 368, 388, 406, 418, 436 459, 460, 461, 513, 634, 653, 660 Procedures / Testing 4 344, 347, 371, 652 l

l Fire protection / 4 314, 333, 604, 671 H2 Generation and Monitoring Aux Feedwater System 3 384,401,486 1

Design Basis Environmental Qualification 2 300, 626 Miscellaneous 5 380,397,443,392,684 Total 35

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Appendix A-10

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CYPDCTG Disposition of Impell's kW

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Recommendations and Observations *+0 f 0{h (- -

1. Safety Classification of Systems and Components it was observed that there was a lack of safety classification boundaries on the P&lDs. Although the Material, Equipment and Parts List (MEPL) provides a detailed description and listing of safety class equipment, it is extremely difficult to describe a drawing in words. The people who developed the MEPL worked off P&lDs to develop their equipment listing.

If P&lDs were marked-up with safety boundaries it would ensure that g required components .(except structures) and boundary valve are properly classified. This is especially true with components which interface with several dif ferent systems.

Impell Recommendation:

The P&lDs serve as the " basis" for determining component classification, and also serve as a permanent record. When design changes are being contemplated, the P&ID's should provide a reference for the safety classification. For this reason, Impell recommends that safety class boundaries be indicated on all P&lDs.

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CYPDCTG Disposition

f I The CYPDCTC concurs with Impe!! recommendation. Included in CYPDCTG Final Report in Section 2.3.2.

2. PMMS

!. t The Project Management Maintenance System is a useful system to plan i i and schedule equipment checks and preventive maintenance tasks. It is t extremely useful for those tasks which are repetitive in nature. j j

! Impell's only concerns with the system are:

4 a

! a. How the information needed by the system, such as safety class and j ,

QC requirements, are input and controlled; and, 1 1 i

! b. For non-repetive tasks, or tasks which deviate from the original

}; scope, does the PMMS tend to become a substitute for a PDCR7 -

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l Impell Recommendation:

i.

Concern a is further addressed in the AWP Nuclear Indicator, Paragraph r

5.4, while concern b is addressed in Paragraph 5.3, AWO versus PDCR.

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j CYPDCTG Disposition:

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a.- The CYPDCTG understands that appropriate control procedures are being developed by PMMS program to ensure accurate quality assurance data is inputted into PMMS. The PMMS computer program will be modified such that the QA data cannot be revised without specified controls.

b. The CYPDCTG recommends that PMMS AWD's be utilized in lieu of PDCR's for (a) surveillance and calibration activities and (b) modifications to components remote to satisfy. Criteria for (6) has been conceptualized by the CYPDCTG.

3. AWO Versus PDCR During our review of the AWOs, it was noted that Station Personnel have varying options of when work should be performed under an AWO or PDCR.

The confusion over what is or is not a maintenance item and what should be treated as a PDCR can be seen in the Maintenance Department. Many of the personnel in the Maintenance Department views the AWO as the authorization to per' form a task. In ef fect, any activity required to complete the task or correct the problem described is authorized by the AWO. The AWO may identify a task to be performed that can obviously be performed under an AWO'. However, when the work begins, complications may arise which require some modifications to complete the task. These modifications may have resulted in a . design change; however, possibic to stop work to issue a PDCR especially if the need for a PDCR is not

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. . . .. .. a perceived under an AWO, even though the AWO does not adequately address the safety and documentation requirements associated with design changes.

This variance supports the need for a " mini" engineering and station review of all design changes and procedures for documentation.

It is our understanding that the purpose of the PDCR is two fold. First, the

- PDCR serves to ensure that the modification to a system or component does not degrade the margins of safety of the station. Second,it serves to ensure station documents are kept in an up-to-date and as-built status.

This second function does not always require the use of a PDCR,if another means is available for this purpose, however, the PDCR does ensure that the documentation changes are prepared early, and receive an adequate review.

INPO Recommendation:

Impell recommends that a detailed procedure be developed to ensure the proper review of the actual work performed and documentation update expected. It should also describe what work can and cannot be performed under an AWO.

CYPDCTG Disposition:

l The CYPDCTG concurs with the Impell recommendation. Criteria for use

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of ATO's versus PDCR's has been outlined by the CYPDCTG in Section 3.3.3.1. Current NEO procedures provide the mechanism to keep design documentation current. -

4. AWO Nuclear Indicators The AWOs have a section which indicates whether the subject equipment is covered by various plant programs, inspection requirements, or quality assurance programs. There were several instances where Impell felt that the information provided by Nuclear Indicators was incorrect and could result in' improper or insufficient Quality Assurance or engineering coverage. These areas have been identified on documentation update sheets.

A more important issue is whether the Nuclear Indicators are msed as the basis for determining how a task is to be performed, (i.e. PDCR vs AWO),

and whether the information in the Nuclear Indicators is controlled and Correct.

Impell Recommendation:

Impell recommends that a review be performed to ensure that the information contained in the Nuclear Indicator Section is correct.

CYPDCTG Disposition:

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-i The CYPDCTG' concurs with the Impell recommendation. The CYPDCTG  !

understands that such a verification effort is in progress.

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5. PDCR Implementation i

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+ p j . The use of PDCRs as a method of ensuring that station modifications wil! I not degrade the safety of the station appears to be quite good. The only i j' problem that was noted was that a once - PDCR has been issued for J

construction, the process for documenting and providing feed-back of field  :

j changes to the original design is not always provided. The feed-back  ;

i

mechanism appears to be in place, but the mechanism or responsibility I to ensure feedback is not clear and/or not followed.

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1 Impell Recommendation:

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i Impell recommends that a review of the PDCR procedure be made to focus on the requirements for providing feed-back on field changes. This will ,

a become even more important as a result of recent concerns relating to ,

Appendix R, Environmental Qualification, and the P&lD Update Program.  !

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CYPDCTG Disposition: I t

i t

i This feedback is required by NEO 5.11, " Design Change Notices" and the t b

i CYPDCTG has recommended that this feedback mechanism also evaluate ,

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\ the impact of the change on the safety evaluation. (See Table 3-6). ,

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6. Equipment and/or Component Replacement Many Work Permits and Automated Work Orders concerns the maintenance or repair of equipment. Many of these repairs required total replacement or partial replacement of equipment. It was concluded, af ter investigation and discussion with plant maintenance personnel, that a clear guideline for replacement components is needed. This is most evident in those WPs and t AWOs which were written to replace components with non-identical ones.

In most cases, the reason for not using an identical item was that it was not in stock and that it could not be obtained in time, i

The replacement items are frequency selected based on the following criteria:

f

, a. Availability

b. Physical acceptability for the job. (Proper pressure / temperature i rating and can the item be installed with little or no modifications?)

c. Operational experiences. Has this item been reliabic? (This is based t

on direct and indirect experiences) L Some of the engineering concerns are given less review (i.e. seismic, environmental qualification etc). This may be quite reasonable under i unanticipated repair conditions, but is not acceptable from the viewpoint i

) of safe operation.

. - -- .,a .a An example of this concern is the safety class steam generator level instrumentation isolation valves. (Note that this information was obtained from the valve list and may not be up to date, but is indicative of the concern). All four valves serve an identical function, one per steam generator.

FW-V-148-1 is a 1" 300#,3y Vogt globe valve FW-V-143-2 is a !" 1500//,10200 llancock globe valve FW-V-143-3 is a 3/4" 600s,9100 llancock gate valve FW-V-148-4 is a 3/4" 300#,350 Vogt gate valve Impell !!ccommendation:

The ideal solution is to replace original components with identicai com ponents. This would require an extremely large and costly material inventory. Ilowever, component inventories are being expanded to meet equipment qualification requirements. Therefore, we recommend that a procedure be developed to identify to plant engineering when other components may be substituted for the existing components. This procedure should address qualification requirements and outline a review and reportin6 process. Commonly used components, such as welded bonnet valves which may be suitable for replacement of bolted bonnel valves should be qualified prior to their being needed.

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CYPDCTG Disposition:

The CYPDCTG concurs with the Impell recommendation. The CYPDCTG has recommended improved controlled documentation of C4 Design Data.

This will facilitate the identificstion of suitable replacement components.

7. Plant Drawing and Document Update During our review and subsequent physical inspections it became apparent that drawings and supporting documents were not correct and/or up to date.

Where we noticed discrepancies, these were recorded and have been turned over the NUSCO. It was noticed, particularly on non-Category I systems, that Work Permits /AWOs sometimes added components such as valves in the service air systems, which were not reficcted on the drawings.

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Impell Recommendations A procedure should be developed which will ensure that required documents are updated or as-built for all sources of design changes (AWO, PDCII, etc). This procedure should address both headquarters and station personnel and should establish the appropriate authority for changes or modifications. The procedure should also provide the method for reporting the change and a detailed description of those activities which must be considered a reportable change. Documents that should be covered under this procedure include station drawings, valve and line lists, the MEPL, and the environmental qualification master list.

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CYPDCTG Disposition:

The CYPDCTC concurs with the Impell recommendation. Current NEO procedures provide the means to update design documentation. The CYPDCTG has also recommended increased training to ensure procedure requirements are implemented.

3. Furmaniting Recommendation:

Although Furmaniting has been considered a Category I maintenance task, impell recommends that a formal technical review be done each time a safety class component is modified for Furmaniting. A review similar to that required by the Furmanite Quality Assurance Manual would be an adequate method. Once a valve has been analyzed for Furmaniting, re-Furmaniting would only require a second technical review if additional holes were drilled.

For items such as feedwater regulatory valves, a conservative analysis could be performed once and any cases within the bounds of the analysis

,. would only require a review which shows that the bounds are not exceeded.

All reviews should be documented.

CYPDCTG Disposition ,

The CYPDCTG concurs with the Impell observation. The CYPDCTG 9

,_4.

recommends the development of a procedure to cover furmaniting.

9. Component Cooling System Classification The Component Cooling (CC) System is not classified as a Category I system. Our review was based on this f act. Section 3.2.6 (page 2) of the MEPL indicates that the " cooling water and seal water systems or portions of these systems that are required for functioning of reactor coolant system components important to safety, such as reactor coolant pumps,"

are Category I. However, the detained system listing in the MEPL does not include the CC System.

The classification of the CC System becomes an issue if RCP seal injection is or becomes a requirement. The ability of the charging pumps to provide continuous seal injection must then be investigated, since the pumps would have to function at low flow conditions (to prevent the RCS from going solid), while recirculation flow cooling (provided by CC)is unavailable.

Impel! Recommendation:

Impell recommends that NUSCO review the requirements for seal injection and reactor coolant pump ccoling, and determine whether the CC System should be Category I.

Also NUSCO should review the In-Service Inspection Requirements on the CC system since In-Service Inspection Dwg. No. 16103-26045 indicates that y .

o .,

i major portions of the CC System are either Safety Class 2 or 3.

CYPDCTG Disposition:

The CYPDCTG concurs with the Impell recommendation. The CYPDCTC has recommended that a review of the component cooling water system t e performed in light of reactor coolant pump operation requirements.

10. Primary Water Classification The Primary Water (PW) System is not classified as a QA Category I system. Our review was based on this fact. The MEPL correctly classifies the auxiliary feedwater system, and demineralized water storage tank (DWST), as Category I. During the Systematic Evaluation Program, the NRC and their consultants performed cooldown calculations w hich indicated that the plant can be cooled down to the RHR initiation point before the minimum Technical Specification limit of 130,000 gallons of water in the DWST and primary water storage tank (PTST) is experded.

Note that PWST water is required to cool down.

Impell Recommendation:

Impell recommends that NUSCO review the design basis of that portion of the PW System which supplies suction to the Auxiliary Feedwater System.

CYPDCTG Disposition:

a 'c, The CYPDCTG concurs with the Impell recommendation. The CYPDCTC has recommended the performance ei such a review in Table 3-4, Deficiency 22.

11. Diesel Generator Heat Exchanger Tube Plugging There were several Work Permits which resulted in plugging diesel generator heat exchanger tubes. Although the diesels are tested to ensure that they operate satisfactorily af ter the tube plugging, it is impossible to determine the total number of tubes plugged.

Impell Recommendation:

Impell recommends that the diesel engine coolant heat exchangers be inspected to determine the plugged tube status. A procedure should be established to adequately control plugging tubes both of engine and lobe oil heat exchangers to ensure that the diesel Senerator meets its design basis.

CYPDCTG Disposition:

The CYPDCTC concurs with Impell recommendatior'. The CYPDCTG has recommended such inspection and procedure development in .

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._ . .; DI na REFERENCES

1. Good Practice TS-402, " Plant Modification Control Program", Institute of Nuclear Power Operations, May,1985.

2. Good Practice OP-202, " Temporary Modification Centrol", Institute of Nuclear Power Operations, May,1935.

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