ML20137D360

Engineering Self-Assessment Rept

ML20137D360
Person / Time
Site:	Comanche Peak
Issue date:	03/20/1997
From:	Ahmad I, Cockrel R, Ellis S TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20137D351	List: ML20137D349 ML20137D360
References
NUDOCS 9703260145
Download: ML20137D360 (38)

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ENGINEERING SELF-ASSESSMENT REPORT SELF-ASSESSMENT TEAM:

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ENGINEERING DEPARTMENTSELF-ASSESSMENT REPOR T I

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Executive Summary.........................................................................................................................Page4 Self-Assessment Performance Objective Summary 1.0 In trodu crion............................................................................................... Page 6 2.0 Seope..........................................................................................................Page6 3.0 Approach................................................................................................... Page 6 4.0 System Reviews (NRC 1P 3 7550).............................................................. Page 7 4.1 Station Service WaterSystem 4.1.1 System Funcrion and Design Bas 1s.................................... Page 8 4.1. 2 Design R: views.................................................................... Page 8 4.1.3 Operationai Readiness........................................................ Page 9 4.2 Emergency Diesel Generation System 4.2.1 System Funcrion and Design Basis.................................... Page 10

4. 2.2 Design Reviews.................................................................... Page 11 4.2.3 Operational Readiness........................................................ Page 12 4.3 InstrumentAirSystem 4.3.1 System Function and Design Basis.................................... Page 13 4.3. 2 Design Re views.................................................................... Page 13 4.3.3 Operational Readiness........................................................ Page 14 4.4 SwitchyardSystem 4.4.1 System Funcrion and Design Basis.................................... Page 15

4. 4. 2 Design Reriews.................................................................... Page 15 4.4.3 Operational Readiness........................................................ Page 16 4.5 System Review Concluslons......................................................... Page 17 5.0 Engineering Administratton and Work Management............................ Page 17 6.0 Corrective Acrion Followup andIssue Resolutton................................

Page 21 7.0 Operations and Maintenance Support Activities...................................

Page 22 8.0 System HeaIth Program........................................................................... Page 24 9.0 Temporary Modifications and Maintenance AIterations....................... Page 26 10.0 Inservice Testing ofPumos and Vaires................................................... Page 28 Attachment A - Summa;y ofFindings (ONE Forms and Improvement Items)............. Page 30 I

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i ENGINEERING DEPAR TMENT SELF.: ASSESSMENT REPOR T EXECUTIVE

SUMMARY

During the period January 27 through February 7,1997. Engineering performed a self-assessment of Engineering activities, processes, and products with a focus on effectiveness of the organization in supporting safe and reliable station operations. This self-assessment was accom-plished by performing both horizontal evaluations of the organization and selected processes and vertical evaluations of four station systems supported by the Engineering processes.

SYSTEM REVIEWS The vertical slice review of four systems determined that the FSAR, Design Basis Documents, and procedures (operations, maintenance, testing) are generally consistent. System performance and reliability are generally consistent with design requirements and probabilistic safety assessment assumptions. System configuration is generally consistent with the design basis, and material condition is good. The assessment team concluded that all four systems are capable of performing intended safety and power generation functions. Strengths included knowledge and 1

experience of the System Engineers; working relationships among Engineering, Transmission, and System Protection groups; and the System Health Program. This system review resulted in the generation of 13 One Forms which can be categorized into the following areas: maintaining design basis documentation; providing calculations to support performance descriptions and i

configuration differences; and use of unchecked and unverified calculations in station procedures. Management of switchyard configuration needs improvement.

ENGINEERING ADMINISTRATION / WORK MANAGEMENT Engineering functions effectively to effect improvements in the reliability of the station.

Reliability enablers and mechanisms in place include the System Health Program, the Modification Team, and the Joint Engineering Team. Regulatory requirements and commitments are being satisfied by programs and procedures in place. Customer satisfaction is improving, and confidence is generally good. The Commitment Tracking System as an identifier of regulatory obligations, and partnering agreements and general services agreements which provide ready access to technical resources were identified as strengths. Areas identified where improvement can be made include communication ofissues to customer organizations, institutionalizing and reinforcing the roles and responsibilities of the JET, better integration of the PROMPT Team engineers with Engineering, backlog trending and work prioritization, and development of performance indicators. There were a number of observations made that indicated some vulnerabilities to the organization may exist. Commitment tracking utility is decreasing because of inconsistencies in database maintenance. The Engineering organization was changed in advance of the procedures. As a result, some work process problems are occurring, and informal work arounds may emerge that may be inconsistent with long term needs. Finally, the reorganization may create a void in discipline-type design basis knowledge, and such knowledge and system-specific knowledge may decline over time as resources shrink.

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5 Engineering Management has requested the self-assessment team to reconvene within approximately six months and evaluate the Engineering organization at that point in time and the

, effectiveness of actions taken. This request is a strength in a self-assessment program.

CORRECTIVE ACTION FOLLOWUP AND ISSUE RESOLUTION Evaluations of technical issues display a clear understanding of the safety implications and exhibit conservatism. Approaches to problem resolution and corrective actions demonstrate technical soundness and thoroughness. Increased attention is warranted in evaluating effectiveness of corrective actions and the approaches taken to documenting deficient and nonconforming conditions.

OPERATIONS AND MAINTENANCE SUPPORT ACTIVITIES Engineering resources effectively support operational and maintenance issues. The perspective of timeliness and quality of the support varies among station organizations. Engineering should continue to improve upon communication channels to station organizations and develop a better understanding of their expectations.

P SYSTEM HEALTH PROGRAM The System Health Program is considered a strength. The program is capturing key ele-ments of system performance, identifying performance enhancement needs, and prioritizing those needs. There are a number of areas where further improvements can be realized, including intersystem prioritization, communication of management expectations on participation in the program, and report content. A vulnerability exists in that confidence in the program could be compromised if emergent issues bypass the program.

TEMPORARY MODIFICATIONS AND MAINTENANCE ALTERATIONS Both processes are considered to be good for their intended purposes. Additional controls or guidance on the Maintenance Alteration Program may be warranted to ensure that changes are not inadvertently made which require a licensing basis or a design basis change or a 10 CFR 50.59 and/or 10 CFR 50.54 evaluation.

INSERVICE TESTING OF PUMPS AND VALVES i

The IST Program is a strong program with regard to implementation of regulatory requirements and tracking of equipment performance. The working relationships between the IST Coordinator and the System Engineers and the knowledge of the IST Coordinator are strengths.

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ENGINEERING DEPA R TMENT SELF-ASSESSMENT SELF-ASSESSMENT PERFORMANCE OBJECTIVE SUMMAR Y -

1.0 INTRODUCTION

Nuclear Engineering performed a self-assessment of engineering activities, processes, and products during the period January 27 through February 7,1997. The objective of the assessment l

was to evaluate the effectiveness of the Engineering organization, particularly effectiveness in l

performing routine and emergent activities, including the identification and resolution of J.

technical issues and problems. This self-assessment used the guidance of Nuclear Regulatory Commission Inspection Procedure 37550," Engineering," and was accomplished by performing both horizontal reviews of processes and programs and vertical reviews of four station systems.

2.0 SCOPE The horizontal review portion of this self-assessment included such engineering processes and l

programs as work management, system health, support of operations and maintenance activities, configuration management, and inservice testing. The vertical review portion of this self-assessment evaluated the quality of engineering activities and products through an in-depth i

review of four systems, two safety-related and two nonsafety-related risk significant systems.

Assessment efforts focused on operational readiness and the capability of the systems to perform intended functions. The assessment team used NRC IP 37550 in accordance with the guidance j

provided in NRC IP 40501, " Licensee Self-Assessments Related to Team Inspections," and INPO 90-015, " Performance Objectives and Criteria for Operating and Near-term Operating Licensee Plants." Guidance from these documents was used to develop the Nuclear Engineering Department Self-Assessment Guide. Other NRC inspection procedures were used as appropriate for applicable scope items of the assessment.

3.0 APPROACII

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The assessment was accomplished by performing both a vertical slice of plant systems and a horizontal slice of engineering processes. This approach provided the objective evidence necessary to determine the overall effectiveness of the Engineering organization. Detailed checklists were used as guidance during the self assessment and provided documentation of the objective evidence collected. Specific details that support overall summary details and conclusions contained herein are available.

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l The term " horizontal slice" refers-to the evaluation of single attributes over many examples. The horizontal approach included a review of recent operations-related issues and maintenance-related issues that required engineering assistance; system health and performance; routine Reactor Engineering testing; temporary modification and^ maintenance alteration processes; l

inservice testing; followup to corrective actions; and, engineering administration.

l The term " vertical slice" refers to the in-depth review of the four selected systems in multiple functional areas, including design bases and operational readiness. The four systems selected for this self-assessment (Station Service Water, Emergency Diesel Generator, Instrument Air, Switchyard) were selected based on a combination of the following criteria: probabilistic risk assessment significance, maintenance rule category, recent modification activities, recent level of engineering attention, and the number of recent internal and external inspection hours spent on the system.

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4.0 SYSTEM REVIEWS (NRC IP 37550)

The objectives ofthe system vertical reviews were asfollows:

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Determine ifthe selectedsystem is capable ofperforming its safety andpower generationfunctions as established in the FSAR, Design Basis Documents (DBDs) and commitments, both internal and external. The Safety Analysis Report compliance review included an assessment ofthe descriptive phrases regarding tests and calibrations, configuration descriptions, operating limits, and descrip-tivefunctionalperformance statements.

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Determine whether system performance is consistent with the assumptions ofthe plant - specific probabilistic safety assessment (IPE), and iftesting is adequate to demonstrate that the system wouldperform its design basesfunctions.

3.

Determine whether Engineering activities relative to systemperformance have been appropriatelyperformed and system configuration has been maintained.

Assessment activities included a review ofthe system description and accident analysis sections ofthe FSAR and the commitment tracking system to identify systemfunctions, sigmficant system operatingparameters, andsystem classifications. Appropriate documentation such as design basis documents, systemprocedures, configuration management systems, and quahfication packages were reviewed to determine iflicensing basis information was correctly translated into implementing documents. At least one system design modificationfor each system was reviewed ifavailable. Routine testing results were examinedandsystem walkdowns wereperformed.

i System Health results were reviewedalong withperformance monitoring results. Disposition of nonconforming conditions was evaluated and application ofIndustry Operating Experience was examined. Additionally, the System Engineer and. Ifavailable, the backup to the System l

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Engineer were interviewedfor each system:

4.1 STATION SERVICE WATER SYSTEM 4.1.1 System Function and Design Basis The Station Service Water (SSW) System removes heat from the Component Cooling Water (CCW) system heat exchangers and from the emergency diesel generators. It supplies cooling water to the safety injection and centrifugal charging pump lube oil coolers and the containment spray pump bearing oil coolers. In conjunction with the CCW System, the SSW system supplies cooling water to meet the plant cooling requirements during normal operation, shutdown, and during or after a postulated loss-of-coolant accident (LOCA) on either unit. The required cooling water is taken from the Safe Shutdown Impoundment (SSI), which is the ultimate heat sink. The SSW also acts as a backup water supply for the Auxiliary feedwater System if the normal supply is unavailable.

The SSI is required to contain a water supply for a minimum of 30 days of reactor decay heat removal without outside makeup. The SSW system is designed to properly operate with water in the SSI at the lowest level during this period of time.

The SSW system is designed to Seismic Category I requirements. One system for each unit is provided. The SSW system is designed on the basis that flow is continuously delivered to one of the two emergency diesel generators of each unit and flow is continuously delivered to one of two lube oil coolers per unit for the safety injection and centrifugal charging pumps and two of four containment spray pump bearing oil coolers.

Normal cooldown on one unit is accomplished with two SSW pumps delivering water to two CCW heat exchangers to cool the reactor coolant system from 350 F to 140 F. An orderly shutdown can be achieved with one SSW pump and one CCW heat exchanger.

One SSW pump in conjunction with one CCW heat exchanger provides one unit with enough cooling capacity for safe recovery after a LOCA.

The SSW system is vital to plant safety and is provided with redundant components so that no single faihire denies cooling to equipment required for safe shutdown. Equipment necessary for shutdown is supplied with emergency diesel generator power if normal and offsite power sources fail.

4.1.2 Design and FSAR Review The FSAR, DBD-ME-0233, and the physical equipment are fundamentally consistent.

Safety Analysis Report descriptive phrases regarding tests and calibrations, configuration descriptions, operating limits, and descriptive functional performance statements reflect actual practices, configuration, and station documents. A few exceptions were identified 8

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. and are described herein. The system is operating within its design parameters and routine testing results have demonstrated system operability. Walkdowns found that the system's material condition is good, and the configuration is consistent with licensing and design basis requirements.

The self-assessment team considered the DBD to be user friendly and understandable, with few outstanding design change documents (e.g., DCNs). Information was readily retrievable and well organized. The assessment team found some discrepancies in the DBD relative to the CCW heat exchanger flow and the extreme low SSI level. As these discrepancies had no impact on technical or operational decisions, they were provided to the System Engineer for followup.

The design basis established for the SSW system provides a low temperature limitation of 40 degrees F. This limit does not appear in the FSAR and does not appear to be captured in any implementing documents. No alarms or procedures were found that would alert operators to a low temperature condition or direct any compensatory actions. This limitation translates to minimum CCW temperature which may have an impact on lube oil cooler condensation. This condition was documented as a result of this self-assessment on ONE Form 97-106.

Calculations were easy to follow, and changes were clearly delineated. With one exception, design calculations used appropriate assumptions and conclusions were j

correct. Calculation 16345-ME-(B)-088 used an incorrect assumption about the screen wash pump supply line; that is, the calculation provided inadequate justification to I

support a code class break across normally open valves. As a result of this self-assessment, this condition was documented on ONE Form 97-094.

An error in determining CCW heat exchanger fouling due to RTD change out had been identified by the line organization on ONE Form 97-056 and is currently under evaluation by Engineering. Interviews with responsible individuals lead to the conclusion that all concerns were being adequately addressed.

4.1.3 Operational Readiness Engineering activities reviewed by the self-assessment team in the area of operational readiness included System Engineer walkdowns, calculations, design assumptions, and trend reviews. Operating procedures specify the appropriate system alignments required l

for the system to mitigate design basis accidents. Detailed reviews of operating i

procedures (normal and abnormal) and alarm response procedures confirmed appropriate direction to the operator for system operations and anticipated system malfunctions, including direction to cross-connect units or trains as needed. Procedure SOP-501B differs from the DBD relative to actions required prior to placing the circulating water 9

bypass system into service. As these differences relate to administrative notification

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actions, no-deficiency document was issued. Trend reviews revealed a repetitive maintenance item on SSW pump 2-02 packing. It was repacked twice in the past year, and during walkdowns the self-assessment team found the pump to be leaking excessively. The team brought these items to the attention of the System Engineer.

ONE Forms reviewed during this assessment appropriately addressed issues of operability, reportability, cause determination, and generic implications. Dispositions were found to be technically adequate. Industry experience and lessons learned had been appropriately applied to the system. During this review, the team identified an apparent loss of work scope when ONE Form 94-1567 was closed to two minor modifications.

Subsequently, the two minor modifications were canceled with the subject work scope to be captured in the System Health report for the SSW system. The scope of work identified in these minor modifications was not fully captured in the System Health report. This condition was identified on ONE Form 97-118.

The Maintenance Rule and Equipment Performance Monitoring Programs are effectively used to reflect system performance and are capable ofidentifying adverse trends and i

equipment performance problems. The system is performing consistently with assumptions contained in the probabilistic safety assessment.. The Limiting Condition of Operation Action Requirement entry records for the system were reviewed and compared with the IPE assumptions for SSW components. The largest system unavailability for the last two years was Unit 1 Train A SSW pump 1-01 with 53.74 unavailable hours compared to the assumed IPE unavailability of 110.38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />.

The overall conclusion reached by the self-assessment team regarding the SSW system j

was that engineering activities have maintained the system in an operationally ready state capable of performing its intended safety and power generation functions.

4.2 EMERGENCY DIESEL GENERATOR SYSTEM 4.2.1 System Function and Design Basis Each Emergency Diesel Generator (EDG) provides reliable power to one safeguards train of electrical distribution when the preferred and alternate power sources are not available.

In order to fulfill this function, the EDGs must automatically start and be available to receive electrical loads within 10 seconds. This self-assessment focused on three support systems required for proper diesel generator operation: Fuel oil Storage and Transfer System; Starting Air System; and the Jacket Water System of the EDG Cooling Water System.

The Fuel Oil Storage and Transfer System ensures a supply of fuel oil is available for diesel engine operation. The fuel oil storage provided for each diesel allows for seven 10

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days of operation at rated load with 15 percent margin. System components are designed to Seismic Category I requirements and are protected from missiles. The Starting Air System ensures a motive force to start the diesel generator independent of the unavailability of AC power. Each starting air receiver is sized to contain enough air for five starts. A Jacket Water System provides heat and circulates jacket water to the engine while not in operation. This system keeps the water system and engine in a warmed, ready to start state. It also provides for cylinder cooling with the engine in operation.

4.2.2 Design and FSAR Review Relative to the support systems evaluated during this self-assessment, the FSAR, DBDs, Technical Specifications, and the installed equipment are consistent. Safety Analysis Report descriptive phrases regarding tests and calibrations, configuration descriptions, operating limits, and descriptive functional performance statements generally reflect actual practices, configuration, and station documents. The DBDs have adequately captured system parameters from regulatory requirements and industry standards which meet the requirements oflicensing and design basis documents. Functional requirements are in conformance with the FSAR and commitments and are adequate to assure system performance requirements are maintained.

The DBD for the Fuel Oil Storage and Transfer system (DBD-ME-215) has one open item for review and only one outstanding change. This good maintenance practice resulted in a document with excellent utility. The DBD for the Starting Air system (DBD-ME-0011) still has 13 open items which should be resolved and closed. Six design l

change documents are outstanding against DBD-ME-0011, and the document references l

some superseded materials, such as calculations, but the DBD is useable. The Jacket Water system DBD (DBD-ME-0011) was found to not identify four flowpath boundary active valves which are tested under the Inservice Testing Program. Further, Procedure SOP-609A provides a limitation on operability (i.e., the function and reset of slow start l

switches on Train A) that is not provided in DBD-ME-0011. These DBD discrepancies were documented on ONE Form 97-0141. The DBD text for the Woodward governors does not accurately reflect the fact that the electronic governor is installed on only one EDG. Unit differences are not identified in the DBD as required by Procedure ECE 5.01-01. This condition was documented on ONE Form 97-0110.

The assessment team considered calculation inputs valid and assumptions reasonable.

System calculations were found to 've technically correct and to adequately support the design basis. The EDGs are adequately sized to meet their load demands for emergency and blackout loads. The philosophy and assumptions ofloading calculations are logical, user friendly, and maintained current.

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Walkdowns deterinined that the system's material condition was good and that l

configuration control was adequate. Routine test results have demonstrated system l

operability. Based on this information, the assessment team concluded that the system is capable of performing its intended safety function. The assessment team noted that the i

experience and performance of the System Engineer is a strength.

The team identified several inconsistencies and discrepancies during design and configuration reviews. During the walkdowns, the evaluator observed wooden covers over the EDG vent air intake louvers (for winter weather protection) and lube oil leaks under the crankcase vent fan. Further investigation by the assessment team found that no documented evaluation of the wooden covers had been performed to determine impact.

As such, cold weather louvers are not captured in the design bases. This condition was documented on ONE Form 97-00109 as a result of this self-assessment. Relative to the lube oil leaks, the assessment team found that the system engineer had been closely following this issue. The vendor is working on a new gasket design for the cam and crankcase.

Another area found deficient concerns fuel oil storage requirements during Modes 5 and

6. DBD-ME-215 had incorporated a change for relaxed fuel oil storage requirements in Modes 5 and 6 in anticipation of NRC approval of a corresponding Technical Specification change (LDCR-TS-92-037). The change has yet to be approved. As a result of this self-assessment, ONE Form 97-00092 was written to document this condition. The assessment team also found that an FSAR statement about Jacket Water system makeup availability and alarm levels had no supporting calculations. This condition was documented on ONE Form 97-0142.

4.2.3 Operational Readmess Testing procedures (OPTS) and system operating procedures (SOPS) were reviewed and determined to adequately incorporate system design criteria. Operating procedures generally specify the appropriate system alignments required for the system to mitigate i

design basis accidents and provide appropriate direction to the operators for system operations and anticipated system malfunctions. One discrepancy was identified by the assessment team. Procedure SOP-609A, " Diesel Generator System," is inconsistent with the calculations and DBD-ME-302A regarding the liraiting temperature for when diesel generator room exhaust fans are required to be operating. Further, the calculation does not i

address availability requirements for two or three fan configurations. Another issue was identified regarding whether unchecked and unverified calculations may be used directly in procedures. These conditions were documented on ONE Form 97-0124.

ONE Forms reviewed during this system assessment appropriately addressed issues of operability, reportability, cause determination, and generic implications. Dispositions were determined to be technically adequate. Industry experience and lessons learned had 12

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been appropriately applied to the system.

The Maintenance Rule and Equipment Performance Monitoring Programs are effectively used to reflect system performance and are capable ofidentifying adverse trends and performance problems. The System Health Program for the EDG subsystems evaluated during this assessment has been a positive for overall performance and accurately characterizes system performance and status. System performance is r msistent with probabilistic safety assessment assumptions. Overall unavailability due :o corrective and preventive maintenance is somewhat higher than PSA assumptions but Engineering has started initiatives to address the gap. Initiatives include PSA database updatos, System Health, PSA awareness, and efforts to improve maintenance efficiency. The unavailability trend is also showing improvements in implementation of Maintenance Rule initiatives.

While some configuration control inconsistencies were identified during this assessment, the assessment team concluded that engineering activities relative to system performance are appropriate and in accordance with station programs. The overall conclusion reached by the self-assessment team regarding the EDG systems examined was that Engineering activities have maintained the systems in an operationally ready state capable of performing their intended safety and power generation functions. System configuration and functionality have been maintained.

4.3 INSTRUMENT AIR SYSTEM 4.3.1 System Function and Design Basis The Instrument Air System (IAS) is designed to provide a reliable supply of clean, dry, oil-free air to operate pneumatic instruments and controls and pneumatically operated valves. Although the IAS is not required for safe shutdown of the plant, it supplies air to components important to safety. The availability of air facilitates plant recovery following an emergency. Instrument air regulates 80 to 120 psig nominal pressure; air dewpoint meets requirements ofindustry standards; quality and quantity of air supports breathing air use while simultaneously supporting equipment and maintenance tool use.

4.3.2 Design and FSAR Review The FSAR, DBDs and physical equipment are generally in agreement. Licensing basis documents and design basis documents adequately capture the design and regulatory bases for the system. These bases have been correctly translated into operating procedures and design documents. Commitments have been appropriately incorporated into station programs and are adequately implemented. Safety Analysis Report descriptive phrases regarding tests and calibrations, configuration descriptions, operating limits, and 13

descriptive functional performance statements generally reflect actual practices, configuration, and station documents. The system is operating within its design parameters. Based on this information, the assessment team concluded that the system is capable of performing its intended functions.

Four concerns were identified in this review. First, relative to test results for system air quality, the assessment team found a long history of unsatisfactory results. Air samples are sent to a vendor for analysis of heavy metals, particulate, and total hydrocarbons, and results, which have been satisfactory, are factored into the System Engineer's conclusion that the IAS provides clean, quality air. This issue is identified in the System Health Program and actions will be taken to address the validity of acceptance criteria. Second, the calculation referenced in DBD-ME-218 as the basis for air consumption is not reflective of current instrument air utilization rates. The assessment team recommends an update to the calculations and DBD, as appropriate, to reflect current rates. Third, the DBD contains a substantial amount of change paper which makes it difficult to use (i.e.,

the DBD is only 54 pages long and has seven outstanding DCNs posted against it, which represent significant changes to system design). Fourth, the review to verify setpoints identified a nonconservative discrepancy for a low pressure alarm. The DBD and associated DCN established a setpoint of 84 psig 11 psig. The drawing, alarm procedure, and calibration cards use the value of 80 psig 1 psig. ONE Form 97-131 was issued as a result of this self-assessment to document this condition.

433 Operational Readiness The System Health Program has been successfully implemented on the IAS. The System Health report describes the issues and conditions of the IAS. None of the issues identified represent changes to the facility as described in the FSAR. Based on the results of System Health activities and system walkdown reports, the assessment team concludes that the system is operating consistent with the assumptions of the probabilistic safety assessment. System efforts continue to ensure system performance is consistent with the probabilistic safety assessment assumptions and that the system is operationally ready. A review of the walkdown logs identified no adverse trends. There have been no functional failures or reported unavailability for the IAS for the past three quarters.

The experience and performance of the System Engineer are positives for the system. It is evident that the System Engineer has taken ownership for this system which is readily acknowledged by castomer organizations. Engineering activities relative to system performance are in accordance with station programs and have maintained the system m an operationally ready condition. While some improvement is warranted in the design basis area, operating procedures specify appropriate system alignments and provide appropriate direction for system operations.

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operability, reportability, cause determination, and generic implications. Dispositions' were found to be technically adequate. Industry experience and lessons leamed have been applied to the system.

4.4 SWITCIIYARD SYSTEM 4.4.1 System Function and Design Basis The switchyard provides the electrical connection point between the TU Electric transmission system (i.e., grid) and Comanche Peak. This connection to the grid provides power for station loads when the station is shutdown and provides TU Electric with the means to deliver the output of the Comanche Peak generators to several substations within the TU Electric transmission network. Separate connections to the 138 -kV switchyard and the 345-kV switchyard provide independent and reliable offsite power sources to the class 1E systems of each unit. Offsite power sources are not obtained from a common switchyard; there are no interconnections between the 138-kV and the 345-kV switchyards. The offsite power systems are capable of providing reliable sources of power to the class 1E systems of each unit in compliance with requirements.

4.4.2 Design and FSAR Review The FS AR, DBD, Technical Specifications, and physical equipment are substantially in agreement. Safety Analysis Report descriptive phrases regarding tests and calibrations, configuration descriptions, operating limits, and descriptive functional performance statements generally reflect actual practices, configuration, and station documents. A few exceptions were identified and are identified herein. The system is operating within its design parameters. Based on this information, the assessment team concludes that the system is capable of performing its intended functions.

Three discrepancies were identified relative to licensing and design basis documents, including two instances where the FSAR was not up to date. One was an editorial error relative to references in the text. The other error was in maintaining the figures in the FSAR. The single line drawings for the 345-kV switchyard do not match the plant configuration or plant drawings. Updated drawings are available but have not been incorporated into the FSAR. ONE Form 97-0128 was issued as a result of this self-assessment to document this condition. The third discrepancy involved Design Basis Document DBD-EE-038. It did not reflect a minimum switchyard voltage of 335-kV.

ONE Form 97-0087 was issued as a result of this self-assessment to document this l

condition.

Design Modification 93-010 was reviewed as part of the assessment. This modification was determined to be technically adequate and had been successfully implemented. Two 15 l

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l weaknesses were identified regarding implemen'tation of this design modification. The first involved update of switchyard drawings and the second involved update of the Master Parts List. Switchyard drawings maintained by the Dallas / Fort Worth Transmission groups were not updated to reflect the changes made by this modification.

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The drawings in the switchyard relay house also do not reflect the changes made by this Design Modification. The Master Parts List was not updated to identify parts stocked in the warehouse for the applications created by this modification. Updates to switchyard drawings and updating of the Master Parts List for modifications arejudged as areas requiring management attention. ONE Form 97-0120 was generated as part of this self-assessment to document these conditions.

4.4.3 Operational Readiness The System Health and Equipment Performance Monitoring Programs have been implemented on the switchyard successfully. In discussions with Transmission and Distribution, no reliability problems inconsistent with probabilistic safety assessment assumptions were identified. Monitoring the switchyard through walkdowns, routine tests, system health, and equipment performance monitoring appear to be successfully identifying equipment condition and focusing the Engineering support for resolving equipment vulnerabilities. This area is considered a strength for system performance.

These efforts continue to ensure that system performance is consistent with the PSA assumptions and that the system is operationally ready.

ONE Forms reviewed during this system assessment appropriately addressed issues of operability, reportability, cause determination, and generic imphcations. Dispositions were found to be technically adequate. Industry experience and lessons learned have been applied to the system and concluded to be effectively implemented with respect to the switchyard equipment / systems.

The evaluator found excellent communication between CPSES Engineering, Glen Rose Transmission, and Fort Worth System Protection. The assignment of responsibilities is clearly defined. Other work groups who have responsibilities for the switchyards are knowledgeable and sensitive to the unique needs of CPSES. Despite this strength, two problems were identified. First, there has been a shortcoming in the updating of electrical drawings for the switchyard. This was apparent in the failure to update drawings for the installation of the generator breaker sync check relay and lack of the most current switchyard drawings in the CPSES drawing system. (This problem was discussed above.)

Prompt action was taken by the responsible Engineering groups to correct this problem and to work out changes in procedures and practices that will prevent this condition from recurring. The second area of concern is the current method for reviewing and approving design changes to switchyard equipment without documenting a safety screen or evaluation. Although the current process does consider the effect of the changes on the facility as described in the FSAR, review of design changes that do not impact the facility 16

as describ'ed in the FSAR are not documented on a safety screen. Safety screens are documented only in conjunction with a safety evaluation for changes that are determined 4

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to affect details in the FSAR and that require an LDCR. This practice and the site procedures require a review to ensure that the current practice meets licensing requirements. ONE Form 97-0098 was issued as a result of this self-assessment to document this condition.

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. System Review Conclusions With a few exceptions, the FSAR, Design Basis Documents, procedures (operations, maintenance, and testing), and equipment configuration are consistent for the four systems reviewed during this assessment. System configuration is generally consistent with design documents, and material condition is good. The assessment team concluded that all four systems are capable of performing intended safety and power generation functions.

The knowledge and experience of the System Engineers and the System Health Program are strong elements for ensuring good system performance, which the assessment team considers as strengths. The relationship between CPSES Engineering, Glen Rose Transmission, and Fort Worth System Protection groups relative to the switchyard is a strength.

This system review resulted in the issuance of 13 ONE Forms. Several of these deficiencies represent failures to update design basis documentation in a timely manner when changes are made. An area for improvement is in maintaining the technical correctness and quality levels of the DBDs (Nuclear Overview has planned a followup evaluation to examine in more depth the adequacy and acceptability of DBDs.) Another condition represented by these deficiencies is the unavailability of supporting calculations for certain functional performance descriptions or configuration differences. An issue that should be addressed is whether unchecked and unverified calculations may be used directly in procedures. Management of switchyard configuration and changes thereto needs improvement. The Switchyard represents a potential problem from both a licensing basis compliance and configuration management perspective.

5.0 ENGINEERING ADMINISTRATION AND WORK MANAGEMENT The objectives ofthis assessment were to determine: (1) ifthe current Engineering organization satisfies the requirements ofLicensing Basis Documents (LBDs); (2) ifEngineeringfunctional i

requirements described in LBDs are prescribed in procedures; (3) ifprogram responsibilities and work activities have been appropriately reassigned in the new organi:ation; (4) ifcustomer organi:ations have been sufficiently indoctrinated in the distribution ofresponsibilities and 17 i

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points ofcontact in the new engineering organization; and, (5) ifmeasures are in place to facilitate the organi:ational transitions. The self-assessment team evaluated the current outstanding volume ofwork, prioriti:ation ofwork relative to long range plans andgoals, and adequacy ofprojected resources to accomplish the work.

The self-assessment in the area ofEngineering Administration and Work Management was conducted by comparing the existing Engineering organi:ations with the descriptionsfrom the licensing basis documents and thefunctions as portrayed inprocedures. Interrelationships between the various Engineering organizations were examined as were the prioritization and i

tracking ofwork loads. Disposition ofan emerging industry concern was examined to assess the i

responsiveness ofthe Engineering organization to such issues and how the organi:ation interfaced with its customers. Finally, training requirements were examined This self-assessment was performed shortly after a major reorganization occurred in Engineering and a number of significant management changes were made. Consequently, the organization was found to be in a state of flux. Changes to the organization were made prior to making changes to the governing procedures.

Based on a review of selected commitments originating from various licensing basis documents (LBDs), it was determined the intent of Engineering functional requirements contained in the LBDs are being met. In large measure, the requirements are being met because of the procedures in place coupled with the extensive Commitment Tracking System (CTS) ano the low threshold at which commitments were identified. Actual functional roles, relationships, and responsibilities are not in strict compliance with the organizational structure described in the FSAR. A Licensing Document Change Request (LDCR) and associated safety evaluation had not been performed in support of the reorganization at the time of the self-assessment; consequently, the self-assessment team initiated ONE Form 97-0128 to document the discrepancy. Engineering initiated LDCR SA-97-011 to correct the FSAR.

With regard to the CTS, the assessment team found that while the system captured many commitments at a very low threshold, maintenance of the system showed signs of neglect.

Specifically, a number ofinstances were identified where active commitments were no longer tied to the correct implementing document. As procedures are revised to accommodate the new Engineering organization, the potential exists to overlook previously incorporated commitments.

The team notes that the forthcoming procedure revisions offer a unique opportunity for Engineering to reexamire existing commitments with an objective of assuring that they correctly reflect current needs and obligations.

Based on interviews with managers in the new Engineering organization it appears that a good transfer of the specific key work activities and program responsibilities was achieved during the reorganization. Notwithstanding, the fact that the organization is not consistent with governing procedures is contributing to some work flow problems (i.e., not knowing where to go for functional responsibility). Efforts are in progress to better assimilate some of these program 18 l

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N responsibilitics and the associated work backlogs into the new groups and to institutionalize their roles; however, some of these efforts may need to be accelerated. The Joint Engineering Team (JET) is on example. Engineering management is placing a lot of emphasis on the key role JET will play as the " triage" organization in Engineering; however, the JET is a new organization and is not captured in procedures. Consequently, there is confusion in Engineering and in other organizations regarding the role of JET. Another similar example not tied specifically to the reorganization is the PROMPT Team. The PROMPT Team is an on shift Maintenance organization with an assigned engineer. The assessment team found that the PROMPT Team engineers are often not included in Engineering correspondence and that minimal efforts are made to ensure these people remain current on their Engineering duties, authorities, and responsibilities. The reorganization is exacerbating this situation.

The backlog of Engineering work was found to be reasonable; however the degree to which the backlog is fully understood, prioritized, and being managed was found to vary among the various organizations. Clearly, System Health is a positive process for managing workloads.

Notwithstanding, System Engineering, the chief sponsor of System Health, continues to grapple with the new workload it assumed when Maintenance Engineering was assimilated. Similarly, Technical Support, a new organization, is trying to better understand its backlog and how that fits with its emerging role.

Backlog trending appears, to be lacking. This along with a general lack of performance indicators is making it difficult for the organizations to measure whether they are achieving successes or if the projected benefits from the new organization are being realized. The Engineering organization has recognized the need for performance indicators and has developed a schedule for their development. This will be examined during the followup self-assessment.

Engineering has established agreements with a number of outside organizations to assist for variations in work load and backlog, as well as to provide ready access to technical resources for special needs. These agreements have included provisions for alignment of the vendor's objectives with station objectives. This arrangement is viewed as a strength.

Efforts are underway to change the prior practices relative to responsibilities and points of contact. The main customers of Engineering (i.e., Operations and Maintenance) have been given indoctrination in the distribution of roles and responsibilities and points of contact. Numerous training sessions and meetings have discussed the functional roles and the business case for the reorganization. Time has been scheduled in upcoming operator requalification cycles to discuss the new Engineering organization. Additionally, the Technical Support Manager and JET Supervisor have taken the initiative to meet with customer organization management to explain what they are attemptirig to do and to solicit feedback on ways to facilitate transition. Phone number laminated cards, " hot lines," and regular interface meeting facilitate and maintain communications.

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In an effort to measure directly how the organization was functioning, the assessment team 19

e examined the handling of an emergent industry concern regarding the actuation logic for auxiliary feedwater systems. The issue was taken from a daily NRC Plant Status Report on December 13,1996. Ownership of the issue was quickly accepted by the Safety Analysis group in Reactor Engineering. This is viewed as a strength. Shift Operations and the System Engineer were not informed there was a potentially impactive issue under evaluation, however, until January 24,1997, when ONE Form 97-004 was issued. This left little time to include those organizations in the development of a response strategy or plan and compromised the opportunity to solicit input from the affected organizations.

The final area evaluated during this part of the assessment was System Engineer training. At the outset, the assessment team found the System Engineers very knowledgeable of their systems.

The team determined that this knowledge was the result of a number of factors, including experience gained with the system as System Engineering matured, previous experience with the system or similar systems during startup testing or at other facilities, specialized equipment training either in-house or from vendors, attendance at system training either as part of the plant certification course or operator licensing courses, or teaching courses on the system. Otherwise, i

no structured approach was evident that ensured system-specific training for System Engineers.

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A similar situation exists for discipline-specific training. The assessment team points this condition out as an area for improvement.

In conclusion, Engineering continues to function effectively to maintain the configuration of the station consistent with the design basis. Engineering continues to take actions to effect substantial improvements in the reliability of the station. Enablers and mechanisms are in place, including the System Health Program, the Modification Team, and the JET. Regulatory requirements and commitments are being satisfied by the programs and procedures in place. The Conunitment Tracking System is a strength as an identifier of regulatory obligations. The relationship that TU Electric has developed with GSA contractors and the partnering agreements to provide ready access to technical resources is a strength. Areas for improvement include timely communication of technical issues to customer organizations; institutionalizing and reinforcing the roles and responsibilities of the JET, both inside and outside of Engineering; integration of the PROMPT Team engineers with Engineering; backlog trending; work prioritization; and, development of performance indicators. The assessment team identified some vulnerabilities. Commitment Tracking System utility is decreasing because ofinadequate maintenance. Ties between commitments and incorporating documents are inconsistently maintained. The organization is out in front of the procedures and as a result some work process problems are occurring. Informal work arounds may emerge to keep the work going that may be inconsistent with longer term needs and expectations. The reorganization to a process-based organization may create a void in discipline-type design basis knowledge for systems. The existing knowledge level resident in the organization may decay over time. System-specific training for System Engineers needs re-emphasis. In a shrinking organization, it will become l

more difficult to find suitable experienced people who require no training.

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6.0 CORRECTIVE ACTION FOLLOW UP AND ISSUE RESOLUTION The objective ofthis part ofthe assessment was to evaluate the appropriateness and timeliness of identification, resolution andfollow up ofconditions affecting quality.

Evaluation activities consisted ofreviews of1995/1996 Engineering Self-Assessment Reports, NRC inspection reports, NOD evaluation reports, and selected ONE Forms and interviews.

Assessment results indicated a positive culture within Engineering. Engineers have been empowered to resolve problems, including the generic aspects of the problems. Such empowerment ensures ownership and positive Engineering involvement in problem resolution, including operability determinations for technical issues; however, Interviewees provided inconsistent responses for determining what conditions are considered to be ONE Form conditions. All interviewees stated that safety-related conditions are documented on ONE Forms. Relative to equipment malfunction, damage, oc degradation, the majority ofinterviewees noted that if the situations can be remedied by routine maintenance they would initiate a work request. Only managerlent/ supervision responded that if such malfunctions, damage, or degradation were unanticipated a ONE Form needs to be initiated. The majority ofinterviewees maintained that if the problem is nonsafety-related, STA-421 excludes documenting the condition via the ONE Form system. Procedure STA-421 does not identify nonsafety-related items as exceptions that do not require initiation of a ONE form. Inconsistent application of the corrective action process impacts important subparts of the corrective action system, including trending, lessons to be learned, and determinations as to why something happened so recurrence can be prevented. Engineering management should establish consistent expectations for determining when issues /concems/ problems are to be documented on ONE Forms.

Engineering appears to be timely in responding to and resolving ONE Forms assigned to them, although the backlog of ONE Forms assigned to Engineering for disposition trended upward in 1996. The self-assessment team recognizes that the reorganization process has impacted the disposition efforts and that efforts are underway to arrest backlog growth in this area. No additional assessment was conducted in this area as Nuclear Overview Evaluation NOE-EVAL-96-200, " Corrective Action," evaluated this condition in more detail during the time period of this self-assessment.

In order to assure that conditions adverse to quality have been appropriately addressed, each manager is responsible for assessing the effectiveness of corrective actions for which he or she is responsible (reference NP Policy No. 202). An effectiveness evaluation is different than a review to ensure that actions were implemented. Engineering management demonstrates adequate review to ensure that actions are implemented as committed but the self-assessment team found that Engineering does not routinely perform follow up assessments to determine the effectiveness of corrective actions. Lack of effectiveness assessments is a weakness in the corrective action cycle.

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Relative to self-assessment actions, this assessment team elected to review the Engineering Self-Assessment performed in 1996 to determine iflessons learned from the 1995 Self-Assessment -

improvement recommendations had been incorporated and to assess adequacy of actions taken in response to the 1996 Self-Assessment. No report was available. Further investigation revealed incomplete traceability of assessment results. Unusual circumstances in Engineering occurred in the time frame of completing the 1996 Self-Assessment that were exacerbated by personnel reassignments and a departmental reorganization. These combined results revealed a weakness in the Engineering self-assessment process. Engineering has assigned responsibility for the self-assessment process to the Executive Assistant. They committed to revising the Engineering Department Self-Assessment Guide and to gathering available information from the 1996 Self-Assessment in order to summarize and distribute results. Estimated completion date is April 18, 1997.

In conclusion, evaluation of technical issues displays a clear understanding of the safety implications of the issue and exhibits conservatism. Approaches to problem resolution and corrective actions demonstrate technical soundness, comprehensiveness and thoroughness. (Refer to Section 4.0," System Reviews," of this report for supporting material.) Engineering management should increase attention to evaluating the effectiveness ofimplemented corrective actions and the approaches taken to documenting deficient and nonconforming conditions that may be at a level inconsistent with a sound corrective action program. Additionally, the backlog of ONE Forms waiting disposition in Engineering should be monitored to determine if l

established actions to address the backlog have been effective.

1 7.0 OPERATIONS AND MAINTENANCE SUPPORT ACTIVITIES The objectives ofthis assessment were to determine: (1) ifEngineering resources effectively supported resolution ofoperational and maintenance issues; (2) ifoperational and maintenance issues requiring Engineering support were appropriately documented; and, (3) ifoperational and maintenance issues requiring Engineering support were appropriately reflected in the System Health Program, evaluatedfor impact in accordance with the Maintenance Rule Program, andreviewedfor generic implications.

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A number ofdifferent activities were conducted to support this portion ofthe assessment.

Included among these activities were an examination ofa number ofrecent operational and maintenance eventsfor which Engineering support was requested, an examination ofsome ofthe l

activities ofReactor Engineering, including routine coreperformance surveillance tests, and an l

examination oftwo recent emergent issues. In addition to these activities, the assessor spent at least one day each with the JETand the PROMPT Team to examinefirst hand the Engineering activitiesperformed by those organi:ations and their interface with customers.

The assessment team determined Engineering resources have generally supported resolution of operational and maintenance issues. The perception of effectiveness of Engineering varies among 22

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departments, however. Maintenance perceives Engineering as very effective in supporting timely resolution of maintenance issues, such as the Unit 2 FWIV hydraulic pump cycling, the Unit 2 feedwater control valve control card failure, the Unit I feedwater pump turbine shaft work, and l

the Unit 2 heater drain pump performance problems. System Engineering provided suppor'in the majority of these jobs. System Engineers were perceived as available and effective in resolving issues. The JET is seen as a strength to Maintenance, providing personnel to assist the Maintenance Department in a timely fashion.

While Operations perceives Engineering as basically effective, timeliness is perceived as an area for improvement. For example, the Unit 2 feedwater control valve control card failures were originally misdiagnosed. This slowed the overall problem resolution process. System j

Engineering is still the typical point of contact for Engineering support for Operations. While the JET is capable of assisting Operations in activities, insufficient experience in working with JET combined with continued successful interactions with System Engineering has prevented more active utilization of the JET.

j To further investigate the effectiveness of Engineering in resolving operational issues, the self-assessment team evaluated the interaction between the Modification Team and Reactor Engineering in resolving HELB/MELB issues associated with installation of the Unit 1 inverter modification. The effectiveness of this interaction was reviewed by interviews with Modification Team members and Reactor Engineering personnel. The Field Change Packages, the modification safety evaluation, and the modification implementation work orders were reviewed.

A field walkdown of the modification was also performed. This interaction was determined to be effective. The two groups worked together in developing a detailed implementation plan that adequately addressed breaches in equipment qualification barriers. Plans for accommodating HELB/MELB issues during modification implementation exhibited sound technicaljustification and good technical quality. A single time limit was imposed in the plan which was very conservative. Implementing documents adequately incorporated the plans. An assessment team walkdown confirmed that the environmental barriers were properly restored upon completion of the work.

The self-assessment team evaluated routine Reactor Engineering testing activities to determine the effectiveness of monitoring reactor core performance. A review of control rod worth measurements, moderator temperature coefficient determinations, and mutdown margin calculations determined that acceptance and review criteria had been met. Measurements and calculations were correctly performed and verified to be accurate. Test results reviewed during this self-assessment satisfied Technical Specification requirements, including Special Test Exceptions. Reactor Engineering effectively monitors core performance in accordance with regulatory commitments, and successful test results obtained demonstrated the quality of core design activities.

l A recently identified NRC technical issue (cold leg recirculation procedure and FSAR consistency) was assessed relative to effectiveness of Engineering's response and technical 23 l

adequacy of evaluations. This assessment consisted of review of the ONE Form and safety evaluation, and interviews with the responsible engineer, Licensing, and Operations personnel.

This issue had been appropriately assigned an'd pursued aggressively. Interdisciplinary involvement was evident through initial operability and safety evaluation completion; beyond these tasks, however, communications with customer organizations declined significantly.

(Refer to Section 5.0 of this report for more discussion on communication to customer organizations.) The ONE Form Committee downgraded the priority for this issue from a Priority 2 to a Priority 3 following the initial operability and reportability determination, but Engineering did not establish an estimated completion date. The self-assessment team concluded that a sound technical approach is being taken to resolve this issue. Use of the simulator to validate operator actions and success paths is viewed as a strength; however, not establishing a clear estimated completion date for such a highly visible issue is viewed as a weakness.

Several operational and maintenance issues were assessed by interviews with the responsible engineers and interviews with Operations and Maintenance personnel. Documentation on these issues was reviewed such as ONE Forms, Technical Evaluations, work orders, and procedure changes.

Operational and maintenance issues reviewed during this self-assessment, including the problems and their resolutions, had been appropriately documented on ONE Forms and work orders, and had been appropriately entered into the System Health Program. Related work orders had been evaluated for impact in accordance with the Maintenance Rule Program. Engineering reviews of these issues had adequately addressed generic implications.

In conclusion, Engineering resources support operational and maintenance issues in a generally effective manner. Perceptions of timeliness and quality of the suppoi vary among station organizations. An area for improvement is communication channels to the various station groups supported by Engineering resources and to accommodate their expectttions relative to that support. The conclusion of Section 5.0 contains specific recommended.*mprovements.

8.0 SYSTEM IIEALTII PROGRAM The objectives ofthis assessment were to determine: (1) Ifthe System Health Program appropriately characteri:es system performance andprioriti:es improvement activities; (2) Ifthe program serves as an efective toolfor communicating andfacilitating the resolution ofplant reliabilityproblems and improvement items across organization boundaries; and, (3) ifsystem health activities are conducted in accordance with governing documents.

Assessment activities included numerous interviews with engineers, Engineering Managers, and individualsfrom customer organi:ations. The governing documentsfor the System Health Program were examined. Four System Health Reports were examinedfor comparison to governing document requirements, implementation practices, and characteri:ation ofissues.

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Additionally, a quarterly System Health meeting was attended.

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The governing document for System Health is the System Engineering Handbook. The Handbook provides management expectations for System Engineers, System Health Report' guidelines, and the role of system performance teams. Activities are generally being conducted in accordance with the Handbook. The self-assessment team and a survey conducted by System Engineering identified an area for improvement. The System Engineering Handbook is not widely distributed or used outside System Engineering. Some vehicle should be established to communicate its contents relative to System Health to organizations other than System i

Engineering. Whether this is a procedure or some other form of written guidance, promulgating the expectations would ensure a better understanding of the purpose and limitations of the program and would facilitate better preparation for the periodic meetings.

The System Health Program is one of the most positive station initiatives to emerge recently. It is an effective communication tool for resolving issues across organizational boundaries.

Operations and Maintenance personnel interviewed during this self-assessment thought the program was a good, integrated plan for system problem resolution. Some viewed the program as more of a long range plan than a living real-time management of system status, but realized this was appropriate.

System Health reports appear to be an effective way of characterizing system performance and communicating system issues by use of performance definitions. Fourth quarter System Health Reports for the Station Service Water System, Radiation Monitoring System, Diesel Generator Fuel Oil System, and the Heater Drain System were reviewed and found to appropriately capture and communicate system performance. Personnel interviewed during the self-assessment expressed no concerns about the characterization of system performance.

Consistent prioritization ofissues has been difficult within the System Health process. The System Health ranking system stands alone and does not match the site-wide priority system.

The System Health rankings are appropriate if site-wide priorities maintain appropriate due dates.

To evaluate the effectiveness of the ranking process, a sample of operations work priority items was reviewed against System Health reports. Priorities were found to be appropriate for these items. To ensure continuing support of Operations, however, responsible engineers should regularly review the activities and update the notepad in the PR-ISM database. During the System Health meeting for the Radwaste Group, rank code development was used effectively by the System Engineering Supervisor to resolve different opinions about issue priorities. The process of determining overall work schedules depends on when the change can be implemented and the overall process contains elements of subjectivity. Currently, overall prioritization is determined within Engineering with concurrence by individual System Health teams for their issues relative to one another and then plant management. Both Operatior s and Maintenance management indicated they should participate more actively in the intersystem prioritization process.

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Over the course of the assessment a humber of opportunities to enhance the System-Health l

Program were identified. First, there is strong support for System Engineering to have more frequent but less formal discussions on system performance between quarterly meetings.

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Walkdowns with Operations and Maintenance would be particularly beneficial. Different groups are preparing for System Health meetings differently. Some consistency in preparations would make the meetings more efficient. Opinions regarding System Health reports varied.

Solicitation of customer feedback may allow production of a report which will see greater use.

In conclusion, the System Health Program is considered a strength. The program is capturing key elements of system performance, identifying performance enhancement needs, and prioritizing those need; with input from appropriate stakeholders. Combining the results of this review with results of other reviews in this assessment, the assessment team identified the following areas for improvement: Collegial assignment ofintersystem priorities in the System Health Program; communication of management expectations on participation in System Health; and, report content. A vulnerability exists that may compromise confidence in the process when emergent issues bypass the System Health Program.

The self-assessment team concludes that two enablers will ensure the continuing success of the System Health Program. The first enabler is the Design Modification Group. Unlike the past, the output of System Health has a single place to go for development and can go there with a clear and unambiguous set of priorities with no competition. The second enabler is the JET. As JET matures and becomes the " triage" organization of Engineering, System Engineering will be able to back out of the "firefighting" mode and move into the system management mode. Until this happens, the time of the System Engineers will be split with correspondingly less attention paid to overall system performance.

9.0 TEMPORARY MODIFICATIONS AND MAINTENANCE ALTERATIONS The objectives ofthis assessment were to determine iftemporary modifications and maintenance alterations made to plant systems and components: (1) comply with requirements and station commitments and (2) have been appropriately reviewedpursuant to 10CFR50.59for creation of unreviewed safety questions andfor impacts to plant operations, maintenance and testing activities.

Temporary Modifications (TMs) and Maintenance Alterations (mas) were reviewedfor adequacy, and the programs (i.e., STA-602 and ECE 5.01-07, respectively) were reviewedfor both adequacy and compliance with regulatory requirements and station commitments.

Individuals involved with the programs were interviewed to assess their understanding ofthe programs and their level ofcomfort implementing the programs. A temporary modification and maintenance alterations were examinedfor compliance with governing requirements.

As written, both programs comply with established requirements and commitments. Interviewees considered Procedure STA-602 for temporary modificaticr.s cumbersome to use. The TM 26

~ Coordinator has recognized this problem andis currently revising the procedure to clarify and streamline the process. He will also be obtaining input from Operations and Work Control and ~

suggestions for improvement by benchmarking other plants.

The ability to determine when mas are acceptable in lieu of a modification is a strong function of experience with procedure ECE 5.01-07. Engineering should issue written expectations and guidance on the appropriate use of maintenance alterations. The drafl Engineering Report on engineering change optimization should also be issued to provide more specific direction. More training may be warranted. A desktop instruction for Procedure ECE 5.01-07 has been written but must be maintained current with the station procedures as they are revised if such instruction is to continue to provide appropriate guidance. (Nuclear Overview is further evaluating the effectiveness of the Maintenance Alteration Program in NOE-EVAL-97-00030.)

The current number of open TMs is low which the team considers to be a positive indication of good management involvement. The TM reviewed was found to be appropriate for the application and to have been appropriately reviewed pursuant to 10CFR50.59 and for impacts to plant operations, maintenance and testing activities. The team noted that recent changes to the PR-ISM database for the statusing of temporary modifications should help prevent repeat problems of the type encountered in 1996 where failure to update PRI-SM resulted in the Control Room TM log not being current.

This review identified a TM (i.e., TM 2-96-0008) with two outstanding revisions. It was not procedurally clear which revision was active. Procedure STA-602 should clarify which revision of a TM is active when installation of a revision is in progress.

An INPO evaluation noted that transient equipment placed in the plant may not have received consistent Engineering reviews. Temporary changes, such as temporary equipment placed in the plant that are not considered to be TMs, are currently in the Engineering evaluation process.

Related programs and procedures have been targeted for evaluation by Engineering to ensure configuration control. Safety evaluations, fire protection reviews, radiological evaluations, non-radiological evaluations, and other applicable reviews will be performed, as well as identifying tracking and tagging requirements of the equipment. These actions represent good followup to an externally identified issue.

The mas reviewed were found to be appropriate for the applications. During the review of selected alterations, the assessment team found one case of failure to follow the procedure concerning issuance of a clearance release prior to the DCN issuance to document control. ONE Form 97-00130 was issued to document this condition.

A potential shortcoming in the MA process was identified by the assessment team. Maintenance alternations are only allowed if the alteration does not tequire a 10CFR50.59 safety evaluation.

Maintenance alterations performed via Work Orders or Technical Evaluations alone may not have the necessary documentation (i.e.,10CFR50.59 screen) to ensure that performance of the 27

change does not require a 10CFR50.59 evaluation. Section 6.2.2 of procedure ECE 5.01-07 establishes criteria similar to a 10CFR50.59 screen, and Section 6.3.3 requiresjustification that l

criteria are satisfied; however, no clear obligation is established to perform a safety screen. The l

10CFR50.59 interface with ECE S.01-07 is an open ISEG recommendation assigned to l

Regulatory Affairs and was, therefore, not evaluated further during this self-asse'ssment.

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In conclusion, the current maintenance alteration procedure (reference ECE 5.01-07) does not always require performance of a safety screen. The assessment team noted how the structure of the process could possibly lead to potential abuse of maintenance alterations as design change vehicles. When combined with the lack of promulgated guidance on the appropriate use of maintenance alterations and decisions by less experienced engineers on when maintenance alterations are appropriate, additional controls on the program are warranted. These controls should assure that changes are not inadvertently made which may require a licensing basis or a design basis change or a 10 CFR 50.59 and/or 10 CFR 50.54 evaluation. With the exceptions noted above, both processes are considered to be good for intended purposes.

10.0 INSERVICE TESTING OF PUMPS AND VALVES The purpose ofthe assessment ofthe Inservice Testing (IST) Program was to determine: (1) If appropriate requirements and commitments are met; (2) adequacy oftest resultsfor the Station Service Water System and the Emergency Diesel Generator System; (3) how IST results are

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factored into system /componentperformance monitoring; and, (4) adcquacy ofresponsibility assignments. This assessment area used the guidance ofNRC Inspection Procedure 73756,

" Inservice Testing ofPumps and Valves. "

For this effort the self-assessment team reviewed the FSAR, Technical Specifications, the IST Plan, and the related commitments to verify the scope and the criteria usedfor ISTofpumps and valves. The team interviewed the IST coordinator, his supervisor, System Engineers, and Operationspersonnel to assess the approach and control ofthe program. In addition, the team observed a s urveillance test and reviewed test work orders and technicaljustificationsprovided to evaluate and accept test results.

The self-assessment team determined that the IST plan and program procedures STA-702 and STA-711 appropriately capture regulatory requirements and station commitments. Careful scheduling and monitoring of the program assures that testing is completed as required.

The FSAR active valve list and IST plan scope were compared and found to adequately capture applicable pumps and valves. Test plans, implementing procedures and test records were reviewed for 11 components in the subject systems. Each document adequately identified reference values, acceptance criteria, test methodology and frequency which were consistent with Code requirements and system performance parameters.

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-ea Three relief requests and the bases for relief were reviewed. Definition and justification were

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appropriate and clear, and sound technical rationale was used. Similarly, testing deferred to cold shutdown or refueling outages was supported by appropriate technicaljustifications.

During observation of a surveillance test (OPT-223), the evaluator noted that data used in the vibration monitoring equipment gave erroneous test indications. Test personnel quickly identified and responded to the error. Investigation revealed that the driver on the computer had been changed which altered the values fed into the instrument. ONE Form 97-0080 was initiated as a result of this self-assessment to document the condition. The evaluator also noted boron crystal deposits and oil leaks around the pump being tested. The system engineer was notified.

An area for Worovement was identified relative to DBDs. The FSAR and IST Program lists of active compo.. nts are more complete than the active component lists in the DBDs. DBD maintenance practices need enhancement.

Postwork surveillance tests following component maintenance, replacement, or modification were reviewed. Reference values had been appropriately reverified or established. Test results that exceeded acceptance criteria (i.e., the ' alert" range) had been appropriately evalumed for operability impact and documented on ONE Forms. The self-assessment team determined that established program controls contributed to the success of the IST Program.

The team reviewed the System Health reports for the last quarter of 1996 for the Auxiliary Feedwater, Spent Fuel and Chilled Water Systems. These three systems had componers categorized in the alert range. While the System Health report for the Auxiliary Feedw ater System specifically identified components in the alert range, the Spent Fuel System Health Report did not identify this condition. Appropriate information was added to the Spent Fuel System Report when identified by the evaluator. (For additional discussion on System Health reports and suggestions for improvement refer to Section 8.0 of this report.) Overall, System Engineers are sensitive to IST results and components in the alert range. They routinely use results and trending data for system performance evaluations.

l Responsibilities for maintenance of the IST Program, including procedures, identification ofIST requirements for modified systems or replacement components, and IST scheduling have been assigned organizationally and individually. The IST coordinator is very experienced, and the Engineering reorganization has benefitted the IST program because he now is able to direct his full attention to the program and its implementation. A close working relationship exists between the IST Cc>ordinatar and the System Engineers. This relationship combined with the coordinator's knowledge is considered a strength in the program.

In conclusion, the IST Program is solid with regard to implementation of regulatory requirements and tracking of equipment performance. The working relationships between the IST Coordinator and the System Engineers combined with the knowledge of the IST Coordinator are strengths in 4

the program.

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ATTACHMENT A t

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SUMMARY

OF FINDINGS r

(ONE FORMS AND IMPROVEMENT ITEMS) e 30

l' 1997 ENGINEERING SELF ASSESShENT l

SUMMARY

OF FINDINGS

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l Section 4.1 Station Senice Water System l

Item Issue RM/RE*

l 1

Discrepancies in the DBD relative RF/BC l

to component water heat l

exchanger flow and the extreme low SSIlevel i

2 ONE Form 97-106 OPS /DG 3

ONE Form 97-94 FWM/DR 4

ONE Form 97-56 FWM/DR 5

Procedure SOP-501B differs from.

RF/BC the DBD 6

Repetitive Maintenance Item RF/BC 1

SSWP 2-02 7

ONE Form 97-118 DLW/CM 5

I Responsible Mant;.;er/ Responsible Engineer

l' I.

1997 ENGINEERING SELF ASSESSMENT i

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SUMMARY

OF FINDINGS

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Section 4.2 Emergency Diesel Generator System

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Item Issue RM/RE*

1 DBD-ME-011 has 13 open items, RF/GY references superseded materials, such as cales.

2 ONE Form 97-141 FWM/TB 3

ONE Form 97-110 FWM/TB i

4 ONE Fonn 97-109 FWM/TB 5

Lube Oil Leaks under Crankcase RF/GY Vent Fan 6

ONE Form 97-92 DJR/LW 7

ONE Form 97-142 FWM/DR 8

ONE Form 97-124 FWM/TB i

)

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l

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l Responsible Manager / Responsible Engineer

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1997 ENGINEERING SELF ASSESSMENT

SUMMARY

OF FINDINGS Section 4.3 Instrument Air System j

i Item Issue RM/RE*

1 Relative to test results for system RF air quality, assessment team found a 7

long history of unsatisfactory results.

2 This calculation referenced in DLW DBD-ME-218 as the basis for air consumption is not reflective of current instrument air utilization rates.

3 DBD-ME-218 contains a DLW substantial amount of change paper.

4 ONE Form 97-131 RF/JA 6

i Responsible Managt.r/ Responsible Engineer

1997 ENGINEERING SELF ASSESSMENT 7

SUMMARY

OF FINDINGS Section 4.4 Switchyard System Item Issue RM/RE*

1 FSAR discrepancies. Editorial RF error resulting from the numbered 4

references.

a 1

2 ONE Form 97-128 FWM/TB i

I 3

ONE Form 97-87 FWM/IA

i 4

Switchyard drawings maintained by DLW Dallas /Ft. Worth Transmission did not reflect DM 93-010 4

5 ONE Form 97-120 FWM/EW 6

Updating of electrical drawings for RF/TE i

the switchyard and lack of the most current switchyard drawings in the CPSES drawing system.

7 ONE Form 97-98 FWM/IA j

1 Responsible Manager / Responsible Engineer

1997 ENGINEERING SELF ASSESSMENT

~

SUMMARY

OF FINDINGS i

Section 4.5 System Review Conclusions Item Issue RM/RE*

1 An area for improvement is in RDC maintaining the technical correctiveness and quality levels for DBDs.

2 An issue that should be addressed is MRK/ LAW whether unchecked and unverified calculations may be used directly in procedures.

l 1

i Responsible Manager / Responsible Engineer

1997 ENGINEERING SELF ASSESSMENT

SUMMARY

OF FINDINGS Section 5.0 Engineering Administration and Work Management Item Issue RM/RE*

1 ONE Form 97-128 FWM/fB 2

Commitment database issues.

RDC 3

Notwithstanding the fact that the DJR/DC organization is not consistent with governing procedures is contributing to some work flow problems (i.e.,

not knowing where to go for functional responsibility).

4 Engineering management should FWM/DR ensure that PROMPT team engineers are included in Engineering correspondence and ensure these people remain current on engineering duties, authorities and responsibilities.

5 Backlog trending appears to be RDC/All lacking. PerformanceIndicators Managers developinent is varied. Work Prioritization needs improvement.

6 Shift Operations and the System FWM Engineer were not informed there was a potentially impactive issue under evaluation until January 24, 1997, when ONE Form 97-004 was issues.

7 Need system-specific training and All discipline specific training.

Managers 8

Areas for improvement include FWM institutionalizing and reinforcing the roles and responsibilities of the JET, both inside and outside of Engineering.

i Responsible Manager / Responsible Engineer

1997 ENGINEERING SELF ASSESSMENT

SUMMARY

OF FINDINGS

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Section 6.0 Corrective Action Follow-up and Issue Resolution Item Issue RM/RE*

1 Engineering management should DJR establish consistent expectations for determining when issues / concerns /

problems are to be documented on ONE Forms.

2 Engineering does not routinely RDC perform follow-up assessments to determine effectiveness of corrective actions.

3 Revise Engineering Department RDC i

2 Self Assessment Guide.

4 Gather information form 1996 Self FWM/JM Assessment in order to summarize and distribute results.

i A*

Responsible Manager / Responsible Engineer

~

1997 ENGINEERING SELF ASSESSMENT i

SUMMARY

OF FINDINGS

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f Section 7.0 Operations and Maintenance Support Activities

~

Item Issue RM/RE*

1 While Operations perceives FWM/DR Engineering as basically effective, timeliness ofresponse is perceived as an area for improvement.

2 Cold Leg Recirc Issue.

FWM Communications with customer organizations declined significantly and no ECD to assure completion of issue.

i

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l 1

Responsible Manager / Responsible Engineer

1997 ENGINEERING SELF ASSESSMENT

SUMMARY

OF FINDINGS Section 8.0 System Health Program Item Issue RM/RE*

1 System Engineering Handbook is RF not distributed outside System Engineering. Establish way to communicate its contents relative to system health to other organizations.

2 Responsible Engineers should RF regularly review Operations work activities and update the notepad in the PR-ISM database.

3 Operations and Maintenance RF management indicated they would like to participate more actively in the prioritization process.

l 4

There is strong support to have RF i

more frequent but less formal discussions on system performance between quarterly meetings.

Walkdowns with Operations and Maintenance would be particularly beneficial.

5 Solicitation of customer feedback RF may allow production of a report which will see greater use.

6-

'I'he assessment team identified the RF following areas for improvement:

collegial assignment of inter-system priorities in the System Health Program; communication of management expectations on participation in System Health; and, report content.

Responsible Manager / Responsible Engineer

1997 ENGINEERING SELF ASSESSMENT

SUMMARY

OF FINDINGS Section 9.0 Temporary Modifications and Maintenaned Alterations 1

Item Issue RM/RE*

1 Procedure STA-602 should clarify RF which revision of a TM is active I

when installation of a revision is in progress. STA-602 is cumbersome to use.

i 2

ONE Form 97-130 FWM/DR 3.

ECE 5.01-07 does not require FWM performance of a safety screen prior to deciding whether a maintenance alteration is the appropriate vehicle for making a change. this is an open ISEG recommendation assigned to Reulatory Affairs.

l 4

Engineering should issue written FWM expecations and guidance on the appropriate use of maintenance alteration. The draft engineering report on engineering change optimization should also be issued to provide more specific direction.

l Responsible Manager / Responsible Engineer