ML20154J322
| ML20154J322 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/09/1988 |
| From: | Capozzi A, Domonique Malone, Semore J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20154J320 | List: |
| References | |
| EA-OR-003-S, EA-OR-3-S, NUDOCS 8809220324 | |
| Download: ML20154J322 (48) | |
Text
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t Report Issue Date: Ssptember 9, 1988 P
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SUPPLEMENTAL ENGINEERING ASSURANCE
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OVERSIGHT REVIEW REPORT SEQUOYAH NUCLEAR PLANT - UNIT 1 DEstGN BASELINE AND VERIFICATION PROGRAM EA-OR403-5
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l 6A k 9 W J. W. Semo Date Team Lead NL.
D. L. Mafbnei Manager * ' ~
1Na bat'e Technical Audit and Surveillance Group A
Anthony P. Capo'tzt
' 64te Manager, Engineering Assurance I
Cw b 7 9 5 If c NCV l
Nicholas C. Katanas Vice Presi knt Date l
Nuclear QLality Assurance 8809220324 880919 DR ADOCK 05000327 PDC
SUPPLEMENTAL ENGINEERING ASSURANCE OVERSIGHT REVIEW REPORT TEAM MEMBER CONCURRENCE Nm Title Signatt.re Date T. G. Cha;rnan*
Lead Nuclear Engineer d
9 jgp J. W. Samore Lead Electrical Engineer K. F. Liao Electrical Engineer gp
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B. Levenson Lead !&C Engineer h,
gg T. G. Chapman
- Lead Nchanical Engineer 9/7 p
0.
. Bogaty Lead Civil Engineer q
B. Levenson*
Lead Operations Engineer g,
y D
rffhg TREND ANALYSIS Nane Signature Date A. K. Khosla f-7-gg a
' Assured duties and responsibilities after transfers and retirement of previous EA team mereers Note:
Only EA Team menters included that were involved In the resolution of restart concerns
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TABLE OF CONTENTS f.821
1.0 INTRODUCTION
1-1 1.1 Background.................................
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1.2 Report Content..........'.....................
1-1
2.0 CONCLUSION
S 2-1 3.0 Sul9tARY OF RESULT 5...............................
3-1 3.1 General..................................
3-1 3.2 Review and Assessment of the 084VP Results 3-2 3.2.1 Restart Test Activities.........................
3-2 3.2.2 Change Document Evaluations.......................
3-2 3.2.3 System Evaluations and C/A 3-3 3.2.4 Transitional Design Change Control / Permanent Design change control....
3-3 3.2.5 08VP Unit 1 Phase ! Report 3-4 3.3 Results of Trend Analysis for EA Action items...............
3-4 4.0 DETAILS SY DISCIPLINE 4-1 4.1 Nuclear..................................
4.1-1 4.2 Electrical.................................
4.2-1 4.3 Instrumentation and Controls........................
4.3-1 4.4 Mechanical.....................
4.4-1 4.5 Operations.....................
4.5-1 5.0 TRENO ANALYSIS OF RESTART EA TEAM FINDINGS...
5-i 5.1 Scope........................
5-1 5.2 Approach..................................
5-1 5.3 Updated Analysis of EA Team Action Items 5-1 5.4 Detailed Analysis.............................
5-4 5.5 Conclusion 5-6...............................
5-7 Appendix A - EA Action Items Evaluated in the Follow-up Effort (Tables A-1, A-2, and A-3)
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ABBREV!AT;ONS AND ACdONYMS AFW Auxiliary eedwate,'
AFWPT Auxiliary Feedwater Pung Turbine AG8T5 Auxiliar/ Building Gas Treatment System ANSI America 1 National Standards Institute AC Alternating Current ACA Auxiliary Control A!r ACR Auxiliary Cont *J1 Room Al Administrative Instruction A01 Abnonnel Operating Instruction AP Auxiller/ Power AP SYS Auxillary Power System AUO Assistant Unit Operator BBC Brown Bovert BIT BoroninjectionTank BI5!
Bypassed and Inoperable Status Indication 8/M B:11 of Material C/A Corrective Action C/R Conrnitment/ Requirement CACTAT Cable Average conductor Tenperature Analysis CAQ Condition Adverse to Quality CAQR Condition Adverse to Quality Report CAR Corrective Action Report CATS Cormittrent Action Tracking System CBI Chicago Bridge and Iron CCB Change Control Board CCO Configuration Control Drawing CCP Centrifugal Charging Pung CC615 Calculation Cross-Reference Irformation System CCS Corponent Cooling System CCW Conponent C:,oling Water CDA Cctrrnittrent Docunent Assigreent COES Change Docurant Evaluation Sheet CGC5 Contustible Gas Control System CEB Civil Engineering Branch c' :
Civil Lead Engineer CRAD Controi Rocan As-constructed Drawings C55 Containnent Spray System CVC5 Chemical and Volune Control System i
CWR Congleted Work Request 064VP Design Baseline and Verification Program 06A Design Basis Accident DC Olrect Current DES Olscipline Evaluation Supervisor DG 01esel Generator DGEPVF Diesel Generator and Electrical Panel Ventilation Fans 01 Discipline Instruction DNS&L Division of Nuclear Safety and Licensing DIQ Design input Pkeo ONC Olvision of Nuclear Construction lv
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DR Olscrepancy Report DRC Design Review Checklist DCR Design Change Request EA Engineering Assurance EC8 Engineering and Corputer Methods Branch ECN Engineering Change Notice EE8 Electrical Engineering Branch EGTS Emergency Gas Treatment System ElR Engineering Installation Requirew n' ELE Electrical Lead Engineer EPT Ethylene Propylene ierpo(nar ER Cngineering Report ERCW Essential Raw Cooling Water ER/50 Evaluation Review / Study Drawing E&T5 Engineering and Technical Services E5F Energency Safety Feature ESFAS Engineered Safety Features Actuation System EQ Envirorvrental Qualification EPVF Electrical Panel Vent Fans FCN Field Change Notice FCR Field Change Request FCV Flow Control Valve FSAR Final Safety Analysis Report FT Functional Tests (t/lb Foot / Pound GSP5 Generating Station Protective System GOC Geaeral Design Criterla hp Horsepower HMS Hydrogen Mitir,ation System HVAC Heating, Versilating, and Alr-Conditioning
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HX Heat Exchi.iger
!&C Instrv.entation and Controls IC5p Inst urentattoi and Control Systems Branch 101 Instrurent Maintenance Instruction IMPL
!rplemented i
L-0CR Local Design Change Request LC Loss of Charger LER Licensee Event Report LOCA Loss-of-Coolant Accident M&At Modifications and Additions Instruction MCR Main Control Rocyn PE8 Mechanical Engineering Branch MFIV Main Feedwater Isolation Valves
MI Maintenance Instruction MLE Mechanical Lead Engineer MOV Motor-operated Valves MR Maintenance Request MRT Management Review Team M55 Main Steam System NCR*
Nonconfr;rmance Report NE Nuclear Engineering NEB Nuclear Engineering Branch NEMA National Electrical Maufacturers Association NEP Nuclear Engineering Procedure NLE Nuclear Lead Engineer NPSH Net Positive Suction Head NQA Nuclear Quality Assurance NRC Nuclear Regulatory Conalssion NRR Nuclear Reactor Regulation NSD-TB Nuclear Service Olvision. Technical Bulletin (Westinghouse)
N555 Nuclear Steani supply system NUC PR Fonnerly the Olvision of Nuclear Power OBE Operating Basis Earthquake OEP Office of Engineering Procedure OES Operations Engineering Services O!E Office of Inspection and Enforcement (NRC)
OL Operating License O&MO Operations and Maintenance ONP Office of Nuclear Power OWIL Cutstanding Work Item List PAM Postaccident Monitoring PAS Project Achinistrative Staff PGCE Potential Generic Condition Evaltation P!R Problem identification Report PL Punchlist PLS Precautions, Limitations, and Setpoints PM Policy Puiorandum PMR5 Preliminary Modification Recorriendation Sheet PMT Postnodification Test PRO Potential Reportable Occurrence PS ProjectStaff psid Per square inch differential QA Quality Assurance QC Quality control QIR Quality Information Release QMOS Quellfication Maintenance Data Sheet RAH Rigorous Analysis Handbook RAP Responsible Action Party RC5 Reactor Coolant System ROBO Restart Design Basis Document RG Regulatory Guide cAlso may indicate Nonconforfaing Condition Report.
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P'Q Residual Heat Removal RIMS Records and Info m tion Management System RPS Reactor Prottetton System RTP Restart Tes'. /rogram RWST Refueling Water Storage Tank SCR Significant Condition Report SCV Steel Containment Vessel SDE Senior Olscipline Engineer SE System Engineer SER Safety Evaluation Report SG Steam Generator SG8 Steam Generator Blowdown SHON B0 Shutdown Board St Surveillance Instruction SIL Section Instruction Letter SIP Safety injection Pung 515 SafetyinjectionSystem 531 Special Maintenance Instruction 501 System Operating Instruction SOR Static-O-Ring SQEP*
SequoyahEngineeringPNject SQN Sequoyah Nuclear Plant STA Shift Technical Advisor SSE Safe Shutdown Earthquake STEP System Test Evaluation Package SWBIO System Walkdown Boundary Identification Drawing SYSTER System Evaluation Report TACF Tecporary Alterations Control Form TCY Teeperature Control Valve TOAF furbine-Oriven Auxillary Feedwater 70AFP Turbine-Oriven Auxillary Feedwater Pucps TDCC Transitional Design Change Control TI Technical Instruction TR0!
Tracking and Reporting of Open Items TVA Tennessee Valley Authority UHf UpperHeadInjection UdQO Unreviewed Safety Question Determination WP Vltal Power VP SYS Vital Control Power Systwn WBN Watts Bar Nuclear Plant WD5 Waste Disposal System WDP Walkdown Package WOG Westinghouse Owner's Group WP Workplan WR Work Request WCAP Westinghouse unique No. on Calculations
'Also used to mean Sequoyah Engineering Procedure, vli
1.0 INTRODUCTION
1.1 Backaround the results and conclusions of the EA Oversight Review team's effort for rhase I of the SQN Unit 1 Design Baseline and Verification Program (084VP) were presented in the ingineering Assurance Oversight Review Report, Sequoyah Nuclear Plant Unit 1, D84VP, EA-OR-003, issued
.)une 27, 1988. There were 106 action items issued to the DB&VP, of which, 57 were closed and 36 were determined to require project implementation of C/A and EA verification as part of Phase 11 of the DB&VP. The remaining 13 action items were considered by the EA Team to be Unit i restart issues requiring resolution, appropriate corrective action implementation and EA verification prior to the restart of Unit 1.
Because a noter of the restart action items related to design change control program, the EA Team could not conclude on the adequacy of the Inplementation of the transitional design change control program in the EA-OR-003 report.
This program was instituted as an interim system to correct the weaknesses of the past design control process.
The 13 restart action items were trackcd by the EA Team for resolution and closure and were identified to the DB&VP project as requiring additional action before final assessment was possible.
The follow-up effort of the EA Team locluded the review, the assessment, and the verification oftheproject'sactionstoresolvetherestartactionitems.
i 1.2 Report Content This supplernental report presents the results of the EA Team reviews and verification of C/A pertaining to the resolution, verification, and closure of the EA-generated restart action items for ccrrpletion of Phase 1 of the SQN DB&VP. Those action items designated as a postrestart issue in the EA-OR-003 report are not addressed in this supplemental report.
Section 1.0, Introduction, provides a brief description of the purpose and scope of this follow-up effort.
Section 2.0, Conclesions, includes the EA Team's conclusion on the 084VP Phase I effort and identifies any remaining actions regul'ed to be addressed in the Phase !! effort.
Section 3.0, Strmary of Results, quantifies the details with regard to restart action items addressed in this follow-up effort, the status of action items at the conclusion of this efforb a brief description by DB4VP activity of actions taken by the project and the EA Tean i
to address the action items, the EA Team's final assessinent of the adequacy of the 084VP l
project's result for each activity, and trending of the EA findings.
Section4.0,DetailsbyOlscipline,includesthedetailsoftheprojectactionstakenandthe EA Team's evaluation of project actions by action item nunters.
1 The overall conclusions of the j
adequacy of C34VP results are included for each discipline, j
Section 5.0, Trend Analysis of Remaining EA Team Findings, int:19 des an analysis of the l
associated with the action items and a carparison of these results with those reported in the EA-OR-003 report.
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Appendix A has been included to provide detailed supporting information relating to the final status of EA restart action items, and the informtion to support the additional trend ana'ysis.
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2.0 CONCLUSION
S Based on the results reported in EA-OR-003 and these additional results of the EA Team's evaluations and verifications for resolving the Phase I portions of the restart action items, the following conclusions are reached:
Iglementation of the 084VP procedures was coglete and adequate and met the objectives of theprogram;andtheactivitiesconductedbytheDB&VPprojectwerecorrect, adequate,and in accordance with program procedures.
TheDB&VPprojectdemonstratedthefunctionalandtechnicaladequacyofmodificatlonsby providing and/or identifying sufficient supporting documentation and justifications to establish that modifications reviewed by the DB4VP cogly with the restart design basis requirements.
The transitional design change control (TDCC) process is being iglemented in a satisfactory manner. Although there were occasional documentation errors noted in the iglementation of the TDCC procedures, the results were technically acceptable. Tighter projectmanagementcontrolsappeartobenecessarytoensurecontinuedprocedure cogliance. EA will continue to monitor this area as part of EA's continued oversight activities.
The results of the DB&VP actions, EA Team actions, and the trend analysis of the restart action items indicate there were no prograntnatic weaknesses rerMining to be addressed by the 06&YP as a result of the 106 findings reported in EA-OR-003 and the EA Team's follow-up work as 4
documented in this report. For Phase ! items, the extent of deficiencies was determined, the deficiencies were corrected or are in the process of being corrected, and appropriate preventive action was identified and implemented. In addition, the root cause assessment of the EA Team concerns indicate that continued project managerent attention to ensure the provision of thorough and appropriate procedures and adherence to those procedures will be necessary during Phase !! of the DB&VP. For Phase !! items, the EA Team required sufficient documentation be provided to verify the postrestart decision was correct.
Based upon EA verification of root cause determination by the DB&VP and adequate C/A Iglemer.
tation of the EA findings, the EA Team concluded that 11 action items of the prerestart phase u( the OB&VP have been fully and effectively addressed and 2 action items have been determined to be postrestart as a part of the Phase !! OB&VP effort. The EA verification of all Phase !!
OB&VP action items will be included as part of the EA oversight scope for Phase !! of the OB&VP. These Phase !! action itses are listed in Table A-3 of Appendix A.
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3.0 SumARf 0F PESULTS 3.1 General The EA Team issued a total of 106 action items to address findings against the SQN unit 1 DMVP activities. The EA Oversight Report, EA-OR-003, included the results of actions taken by the DB&VP and the EA Team on these findings. Of 106 action items issued, 57 were closed and 36 will require project iglementation of C/A and EA verification as part of Phase !!. Thirteen open action items were considered by the EA team to be restart issues requiring resolution and appropriate corrective action Iglementation prior to the restart of unit 1.
A list of the "Restart" action items is presented in Table A-1 of Appendix A.
This (celow-up report presents the results of the D84VP and the EA Team actions to resolve and close tb restart (Phase 1) portion of these action items.
Theprojectwasrequiredtoinvestigateanddocumentthecause, extent,andsignificanceas well as provide corrective and preventive actions for all of the valid action items. The EA Team approval and verification of these actions were required in all cases.
Of the 13 "Restart" action items, C/A for 4 of these had been agreed to by the EA Team at the time the EA-OR-003 report was issued and only required project iglementation of C/A and the '
Team verification. These 4 action items were re* sted to the restart test program, systwn evaluations, and the transitional design change costaol program. (See Table A-2 of Appendix A for distribution.) The EA Team's approval of the p*oject's investigation of cause, extent, significance, and definition of co* active / preventive actions was documented and reported in EA-OR-003. The EA Team verification of C/A was requi.**d in this follow-up effort for these 4 action items.
Fortheremaining9actionitems,theDB4VPprojectwasrequiredtoinvestigatecause, extent, and significance as well as defini'. ion of corrective and preventive actions. These 9 action items were related to the rettart test program, change document evaluations, the transitional design change control program, and the DB&VP Unit 1 Phase I report. (See Table A-2 of Appendix A for distribdion.)
The project deterfrined that some of the probitms in these action items were single occurrences i
and these were appropriately corrected. Inallcases,theEATeamrequiredtheprojectto document the rationale that was used to bound the problems. The EA Team verified the adequacy of this docunentation and judged t'.at the EA-identified problems were satisfactorily bounded.
The results of the trend analysis presented in the EA-OR-003 report were updated in section 5.0 of this report to reflect these additional DB&VP and EA Team actions.
The updated trending incorporated the Project and EA actions related to resolution and verification of open action items that were considered to bre Unit I restart issues. The same trending procedure, attribute codes, and conventions used for the EA-OR-003 report were applied to the update effort.
All of the problems identified in these 106 action items were either corrected and EA verifled or the EA Team agreed with and will verify DB&YP actions to be Ig lemented in Phase !!
(postrestart of Unit 1).
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l Details by discipline are presented in section 4.0.
Table A-3 of Appendix A presents the status of each "Restart" action item at the conclusion of the follow-up effort.
3.2 Review and Assessment of the DB&VP Results The EA Team evaluated the project's actions and verified applicable project's implemented C/A ^
fortheactionitemsrequiringPhaseIprojectaction. In addition, the EA Team has agreed with project's postrestart decision for all Phase !! actions.' The following is a brief description of the results of the reviews and assessments perfomed on the project actions by activity.
There were no EA Team restart action items on activities associated with the system boundarles determination, design criteria, and system walkdown. Therefore, the results and conclusions L
reported in EA-OR-003 for these activities were congleted and are unaffected by this follow-up effort.
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3.2.1 Restart Test Activities As shown in Table A-2 of Appendix A, there was one restart action item (01-007) in the resolved status and one restart action item (01-010) in the unresolved status agalnst this activity.
For the resolved action item (01-007), the project provided information Indicating that the C/A of making the FSAR and design criterla consistent for CAQR SQP871446 adequately addresses EA's concern. The project conmitted to conplete the CAQR SQP871446 C/A during Phase 11. The EA Team concurred with the project and will verify C/A for the CAQR during i
Phase 11.
Fortheunresolvedactionitem(01-010),theprojectrevisedtheSQEP-63,pages211and 212, Restart Test Package for System 63, to show the correct cold leg recirculation flow rate for the RHR purp runout condition is 5500 gpm. The EA Team verified the C/A by the projectwasadequateandclosedthisitem.
l Based on the results reported in EA-OR 003 and the resolution of the above concerns. EA I
supports the project's position to accept the results of the restart test program effort to satisfy any of its system /conponent functional requirement definition connitnents.
3.2.2 Chance Document Evaluations As shown in Table A-2 of Appendix A, there were two unresolved action items (El-007 N1-002) against this activity.
i For Action item El-007, a work request was initiated to install a caution tag for the alternate DC feeder to the AfWPi transfer switch to control its use. In addition, the project conmitted to revise the C/A of CAQR SQP871335 R3 to ref1Let the Unit 1 C/A work.
The project also reviewed additional CAQRs to verify the adequacy of the CAQR's C/A to i
correct Unit I concernt. This review identified no other CAQRs which did not address Unit I concerns. The EA Tearn verified C/A, reviewed the same six CAQRs, and judged the results of the CAQR review to be adequate. The EA Team also concurred li the postrestart decision to revise the C/A of CAQR SQP871335 R3 to address Unit 1.
The EA Team will verify C/A for the CAQR during Phase !!.
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For Action item N1-002, the project provided documentation to show that the loss of this equipment would not adversely affect the control room habitability; therefore, EA's concern with ECN L6180 is a postrestart issue. The EA Team concurred in the postrestart decision to provide C/A for PIR SQNEEB8824. Final resolution and closure of this item will be postrestart.
Based on the results reported in EA-OR-003, the EA verification of the project's C/A and EA's concurrence to provide C/A for PIR SQNEEB8824 ano revise C/A for CAQR SQP871335 R3 postrestart,theEATeamjudgedthattheDB&VPChangeDocumentEvaluationactivitieswere satisfactory.
3.2.3 System Eval ations and C/A t
There was one restart u tion item (E;-013) against this activity which was resolved but reeired verification of the C/A revision to PIR SQNE886108.
The project issued Revision 2 of PIR SQNMEB86108 dated July 28, 1988, which contains the revised C/A addressing the Unit I restart work for ECN L7185 to replace motor operators because of inadequate torque and/or excessive stroke time. The EA Team verifled that the project'sC/Awasimplementedandtheactionitemclosed.
Based on this EA verification and the results presented in the EA-OR-003 Report for sysicm evaluations and corrective actions, the EA Team judged the DB&VP's effort on the system evaluations and corrective actions to be satisfactory.
3.2.4 Transitional 0%lan Chance Control /Permanant Desian Chance control The Transillonal Design Change Control Process (TDCCP) was instituted as an interim system to correct the weaknesses of the past design control process and to prepare for the permanent i
design control program to be initiated at restart for Unit 2.
For Unit 1, work initiated after April 1,1988, was to be performed under the oermanent design change control process.
EA reviewed the design change control process to determirf; if the program was procedurally t
controlled and adequately implemented.
SQEP-13 was developed and issued to co@Iy with a SQN conmitment in tne Nuclear Perfortnance Plan Volume 2 that a transitional design change control process be in temented before restart to l@ rove the existing design control process and provide an effective transition to the
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perminent system. NEPs-6.2, 6.3, 6.4, and 6.6 were issued to procedurally control the permanent design change control process and the project issued SQEP.26 to l@lement these NEPs.
The EA-OR-003 report identified 13 open action itcms pertaining to potential technicel issues for the 10CC with a majority (7 of 13) of these considered restart issues. Further r: views by EA on tht transitional design control process were conducted to resolve these action items orverifyprojectactions.
For El-016 the project' issued a Safety Evaluation fonn and a revision to an ECN in
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addition to issuing an update to the bpdated Final Safety Analysis Report. EA reviewed these actions and concorred that this adequately addresses the concerns and considers this item closed.
For El-017, involving documentation inconsistencies, the project issued a revision to the calculation log and ccomitted to revise PM-86-02 (EES) postrestart. EA verified that this action adequately addresses the concern and is sufficient to resolve this action. Final
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l closure will be postrestart pending EA's verification.
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ForEl-018,involvingdocumentationinconsistencies,theprojectrevisedacalculation, l
i the modification criteria, and conmitted to revise another calculation postrestart. EA verified that this action adequately addresses the prerestart concern. Final closure will be postrestart pending EA's verification.
l For M1-008, involving room cooler performances, the project supplied a copy of the memo which revises the FSAR text in addition to a draft copy of the Plant Modification package which revises the ultimate heat sink temperature. A CAQR was supplied to note recurrence control as being a preventative maintenance program to maintain cooler flows and cleanliness. EA has reviewed these actions and verified that the prerestart concerns have been adequately addressed. This item is resolved with final verification of FSAR figure revision being postrestart.
Toresolve11-20theprojectissuedECNL7381toreplaceanigroperlysizedorificein the containment spray piping before restart. EA concurs with this action and closed item 11-20.
For 11-021 the project supplied infonnation addressing documentation errors to support deferring this concern to postrestart. The EA Team reevaluated and reclassified this concern as a postrestart issue because the documentation errors did not meet the SQN restart criteria on unit 1 operation. Final closure will be postrestart pending C/A approval and verification postrestart.
For 01-005 the project has updated the Control Room drawings. Only a few red lined drawings remain in use with controls in place to limit the use of red line drawings in the i
control room. EA has verified the project actions and closed this item.
Yo verify project improvement in the design change control process, EA perfonned an additional review (as a part of EA surveillance S88-23) of 11 ECNs/0CNS along with their supporting calculations that were issued between July 15, 1988 and August 31, 1988 under the transitional design change control process. These were considered to be exc@les of ECN5/DCNsissuedafterpublicationoftheEA-OR003reportandincludecertainproject enhancements that were to correct the types of deficiencies identifled in EA-OR-003. In addition, EA has had an Ungoing review of work In progress under the permanent design change control process.
EA found the types of concerns previously Identified in EA-OR-003 were corrected in the sagled ECNs/DCNs. This provided evidence to the EA Team that project C/A5 and modifications done under the permanent process have l@ roved design change control. However, the EA Te.vn i
identified documentation discrepancies in this additional review which were ir the area of the technical adequacy of the supporting calculations. These discrepancles, when corrected, wl11 not change the calculational results. Therefore, this issue will be addressed in the Unit 1 EA calculation assessment ($38-24) which is currently in progress.
Based on the results of this additional review in conjunction with the resolution of the prerestart portions of the seven action items and the ongoing review of SQEP-26 work, EA judged the impicmentatio'n of the Design Change Control Process to be acceptable. EA will continue to monitor this area as p4rt of EA's continued oversight activities.
3.2.5 OB&VP Unit 1 Phase ! Report There was one restart action itcm (01-011) Identliying a lack of cogonents being included on the CSSC list which was in unresolved status against the DB&VP Unit 1 Phase ! Report. The 3 -4
project responded that the SWBID-CSSC cagarlson was not a requirenent of the D64VP as defined by the Unit 1 Program Plan or the 084VP procedures. Inaddition,theproject indicated that TVA has connitted to develop a Q-list which will incorporate the existing CSSC list and the 084VP systems comonents. This is a postrestart connitment (4/89) and is being tracked in CCT5.
l The EA Team reviewed this response and found that the SQN Q-Ilst Iglementation plan adequately addressed this concern. Since this connitment is being adequately tracked by the CCTS system, the EA Team closed this item.
Based on the EA Team's concurrence with the project's response and the results reported in the EA-OR-003 report, the project's DB4VP Unit 1 Phase I Final Report was judged by the EA Team to be technically acceptable.
3.3 Results of Trend Analysis fo_r EA Action Items The updated trend results in section 5.0 indicate that the trends discussed in EA report EA-CR-003 have not changed. However, for the TDCC activity, a detailed analysis was performed in this report since the progrannatic aspect of the TOCC process was identified previously as an overall area of concern that required further Investigation. Based on actions taken by the projectandEATeaminsection3.2.4,theTDCCprocesshasbeenjudgedtobeacceptable.
However, EA will continue to tronitor this area and the effectiveness of the C/A programs as part of the EA oversight activities.
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4.0 DETAILS BY DISCIPLINE This section provides detailed information regarding the discipline review results by activities. A brief general description of the project actions and the EA review is included for each of the following activities:
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- Restart test activltles Change doceent evaluations System evaluations and corrective actions Transltional design change control 004VP unit 1 Phase ! Report I
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J 4.1 Nuclear 4.1.1 Backaround The Nuclear discipline of the EA Team evaluated project action and verified irrplemented C/As for an action item associated with the following activity:
- Change document evaluation (Action item N1-002 RI) 4.1.2 Details Ore Nuclear discipline action item was evaluated. At the time of issuance of the EA-OR-0C0 report,theactionitemwasinanunresolvedstatus;thatis,projectC/Awasnotagreedto by the EA Team.
4.1.2.1 Chance Docirent Evaluation Action Item N1-002 R1 The EA Nuclear review of change documentation had a restart concern unresolved on ECN L6180 for which the Project had issued PIR$QNEE88824. This PIR documents the concern about the effect of the engineering change of ECN L6100 on the Main Control Room Habitability Zone (MCRHZ). (
Reference:
Section6.5.1.1(ActionitemN1-002RI)ofEA-OR-003).
Project Action i
The Project submitted a response (Reference 1) surrnarlzleg two concerns with the unresolved Action Item N1-002 R1 on ECN L6180 to replace a tecporary alternation change forTn (TACF) as follows:
(1) Material ccrpatibility with the existing installation, in relation to the MCRHZ pressure boundary and (2) the effect on the MCRHZ if the tunporary installation should fall during an isolation event. For concern (1), the TACF as currently installed does not appear to conform to TVA Code Class C, thereby violating pressure boundary requirements for the MCRHZ. From a pressure boundary standpoint, if the terrporary installation should fall, plant safe operation is not adversely effected. Recent testing perforTred by $1-144.2 docurrents high pressurization levels provided by the Control Building Errergency Pressurization System. The sensing Ilne leading to the outside is less than I" diameter and therefore would be an insignificant outleakage path of pressurization air (i.e., an insignificant pressure loss). Thus, this concern does not pose any threat to safe plant operation at restart. For concern (2), if the tecporary installation should fall, the functional requirements of 0-POT-31A-14 could be adversely affected, causing the solenoid valve operation for the trodulating darrper FCO-31A-14 downstream of the Control Building Normal Pressurl24 tion Fans to malfunction, potentially over-pressurlzing the lower elevations of the Control Bellding with respect to the MCRHZ. If this over-pressurization were to occur, this condition would be in violation of design criteria SQN-0C-y-13.9.6, Section 3.7.g, allowing the potential infiltration of unfiltered outside air into the MCRHZ fran the lower floors of the Control Building. This condition cannot occur at restart because SQNP OCN X00051C (825 871008 506) authorized the locking out of the Control Building Normal Pressurl24 tion Fans and the locking open of modulating darpers FC0-31A-14 and -15.
This DCN action was taken because of a malfunction in the contMls fnalntaining the proper ressurization level. With this equip'ent out-of-service at restart, the potential for concern (2) does not erist for an event after plant startup i
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(i.e., cver-pressurization of the lower elevations with respect to the MCRHZ).
A ministrative controls are in place to assure this equipment is not returned to service before the system /equigrnent is repalted, detennined to operate safely, and meets all TVA design criteria requirements and specifications. Therefore, this concern also does not pose any threat to safe plant operation at restart.
Based on the above discussion, DB&VP huclear regards these concerns as nonrestart items. Although detalled corrective action has not been defined for these concerns, the problem as presented and rationall2ed in the PIR has been evaluated by the responsible personnel as being a nonrestart issue. Procedures and administrative controls are in place to assure these concerns are analyzed and handled correctly with respect to safe operation of the plant. TheprojectrequestedthatEAappropria/ely revise the restart category for N1-002R1 to postrestart.
Results of EA Evaluation EA Nuclear concurs with the Project that final resolution of action item N1-OG2R1 couldbedeferredto"Postrestart"providedadequatejustificationtoshowthatthe "Nonnal" Control Building Pressurl2ation fans are not safety related, and that their current status of "out-of-service" is an acceptable one. TheProjectsubsequently submitted additional docunentation (Reference 2) that EA Nuclear judged as adequate to supporttheProjectposition.
4.1.3 Conclusion EA Nuclear concurs t. hat Action item N1-002 R1 is Postrestart but recuins unresolved.
Closure of this action item requires an acceptable corrective action plan, irrpiecentation of corrective action, and verification by EA for PIR SQNEE88824.
4.1.4 References Reference Nunter Docueent and Revision Issuo Date Title and Description 1
Meco from A. P. Blanco to 8/1/88 SQN 08&VP EA Action item J. von Weisenstein N1-002 R1 - Reclassifica-tion of Restart category l
to Postrestart l
2 Meco frcrn A. P. Blanco to 8/4/88 SQN 054VP EA Action Item J. von Weisensteln N1-002 R1 - Additional Docurentation Supporting Postrestart Category Classification l
l I
l l
l I
l 4.i-2
4.2 Electrical 4.2.1 Backaround The Electrical discipline of the EA Team evaluated project actions and verified iglemented C/As for action items associated with the following activities:
Change document evaluations (Action item El-007)
System evaluations and C/A (Action item El-013)
Transitional design change control (Action Items El-016, 417, and -018) 4.2.2 Details A total of 5 Electrical discip11ne action items which were detennined to be restart issues were evaluated for this report. At the time of issuance of the EA-OR-003 report, one of the action items (El-013) was in a resolved status; that is, C/A was agreed to by the EA Team aM project Iglementation of C/A and EA verification of C/A were required. Two action items (El-007 and El-016) were in an unresolved status; that is, project C/A was not agreed to L the EA fee. No response was received by the EA Tem for the remaining 2 action items (El-017 and El-018).
4.2.2.1 Chance Docurent Evaluation Action item El-007 The EA Electrical's review of DB&VP change document ECN tS346 (Reference 1) resulted in Action item El-007 which involved verifying a Unit 1 C/A which was not addressed by CAQR SQP871335 R3. Additionally, EA questioned whether other CAQRs which the DBVP took credit for correcting Unit 1 problems also had the appropriate C/A defined to address Unit 1.
(Reference section 6.5.2.1.4.4 of EA-OR-003 Report). The Electrical discipline of the -
Team evaluated the adequacy of the Unit 1 C/A for CAQR SQP871335 R3 (Reference 2).
Project Actions:
1.
A work request WRB255922 (Reference 3) was initiated to install a caution tag for the alternate DC feeder to the AFWPI. The C/A of CAQR$QP871335 R3 will be revised postrestart to reflect the WR 8255922 which iglemented C/A for Unit 1.
2.
The project randcrnly selected and evaluated the following sis CAQs fran the Unit 2 punchlist which were reviewed by the DBVP for roll-over into the Unit 1 punch 11st:
CAQR$Q1870150, SCR5QNEE88742, SCR$QNEEB8743, SCR5QNEE88773, SCR$QNEE88777, and SCRSQNEEB8799 (References 4 through 9). This review did not identify any other breakdown in iglerentation of NEP 9.1 or the SQA-190 or SQA-203 procedures.
Therefore,theprojectconcludedthattheextentofthisconcernwasisolatedtothis single occurrence.
i 4.2-1
Result of EA Evaluation:
EA Electrical reviewed Work Request 8255922, the above six CAQs, the SQA203, Attactonents A dated Ma ch 21, 1988 and March 6,1988 (References 10 and 11) and & TROI Report dated August 14, 1988 (Reference 12). EAelectricalconcurredintheproject'sassessmentofthe concern and found the project's C/A and CAQR reviews to be adequate. In conclusion, EA Electrical considers the project's C/A adequately addresses the Unit I restart concern with only a documentation of a CAQR C/A rev!sion remaining for conpletion in Phase !!. This action item is resolved and will be closed pending EA Electrical's postrestart verification of the revision to the C/A for CAQR5QP871335R3 to include WR 8255922.
4.2.2.2 System Evaluations includino C/A and Restart Cateoorization Action item El-013 The EA Electrical's evaluation of the Auxillary Feedwater System Evaluation (System 38) resulted in Action item El-013 which was resolved but required varlfication of project's C/A revision of PIR SQNP'EB86108 (Reference 13). The Electrical dlScipline of the EA Tear-evaluated the adequacy of the revised C/A of PIR5QNMEB86108 to address Unit I restart war of replacing the motor operators of certain Unit I motor operated valvas for inadequate torque and/or excessive stroke time. (
Reference:
section 6.6.2.1.b of EA-OR-003 Report.)
Project Actions:
The project issued Revision 2 of PIR SQNME886108 which addressed the Unit I restart work of ECN L7185.
Result of EA Evaluation:
EA discipline reviewed PIR SQY'EB86108R2 dated July 28, 1988 and vertfled that the PIR C/A was revised to include the Unit I restart work of ECN L7185 and to indicate that the E must be field corplete pelor to the restart of Unit 1.
EAElectricalfoundtheprojects action accept 6ble and closed this action item.
4.2.2.3 Transitional Oeslan chance Control Action itses E l-016. -017. and -018 EA Electrical's review of the transitional design change control process resulted in 3 action items (El-016. El-017, and El-018). At the tirne of issuance of the EA-OR-003 deport, the project's response for Action item El-016 was being assessed for adequacy while project responses for Action Items El-017 and El-018 were not received.
The Electrical disciplineassessedtheproject'sresponsesfortheseactionItemstoensurethatthe concerns raised are adequately addressed. (
Reference:
section 6.7.2.1 of the EA-OR-003 Report.)
4.
Action item El-016 EA Electrical's review of ECN L7211 Identified several docunentation inconsiste the ECN package.
1 Project Actions:
l The project responsded to EA's concerns raised in Action item El-016 as follows:
i 4.2-2
(1) The Modification Criteria N2-7211-011, section 6.1 marked "Y," for Safety Analysis Report affected and data sheet required was not in conflict with the ECN cover sheet which Indicated that no Nuclear data sheet was required. Since the Electrical discipline was responsible for the affected Sections of the F5AR, Section 6.1 of the Modification Criteria indicates that an electrical data sheet is required per Section 8 of the cover sheet to handle the revision to the F5AR.
(2) The USQ 5creening Review Form dated July 21, 1987 for ECN L7211 (Refrence 14) was prepared using preliminary infoma*lon concerning potential effects on the FSAR and the diesel loading. The ECN package was loedvertently issued without being updated to the latest nodification criteria and completed Calculation SQN-EPS-010 (Reference 15). Subsequently, the discrepancles noted by EA were independently corrected by the project through the SQEP-13 process of cogoleting the modification. Revision C of ECN L7211 (Reference 16) was subsequently issued to include a Safety Evaluation Form (No. 2EE8040) and an update to the Updated Final Safety Analysis Report (UFSAR).
(3) Since the ECN cover sheet was not in error and the affects upon the F5AR and the diesel transient loading were addressed through the nomal SQEP-13 process, a review of the additional 7000 serles ECNs for similar problems to determine the extentoftheconcernisnotwarrantedbytheproject.
Results of EA Evaluation EA Electrical reviewed the Safety Evaluation Form dated June 2, 1988 and the update to the UFSAR contained in the revised ECN L7211C package and found them both technically acceptable. EAconcurswiththeprojectassessmentandclosedActionItemEl-016.
b.
Action item El-017RO Action item El-011 RO involved technical justification mecorandums for ECNs L7130 and L7129 which were issued in lleu of calculations and not tracked to ensure that the calculations were revised. Thisactionitemwasnotrespondedtobytheprojectat time the EA-OR-03 Report was issued (
Reference:
section 6.7.21 of EA-OR-003 Reporti.
Project Action:
In response to EA Action Item El-017RO, the CB&VP addressed the concerns as follows:
(1) A technical justification statecent was allowed to be used in lieu of a calculation per section 3.0 of NEP-3.1 (Reference 17). Although the two technical justifications (References 18 through 19) in question were not officially entered into the SQN EEB Calculation Tracking Log, their esistence was known. In addition, attachnent 1R3 dated July 18, 1988 of SQEP-09 for ECN L71300 (Reference
- 20) indicates that the FCRs associated with this ECN were reviewed by SQEP-EE8 according to the SQEP-09 (Reference 21) procedure, and no breakdown in conglying with this procedure was observed.
(2) TheDB4VP'sreviewIndicatedthatthree(3)technicaljustificationswere issued in lieu of calcu14tions: the 2 nentioned Above plus 1 recently issued (Reference 22). However, the latter is being tracked by the SQN EE8 Calculation Log.
4.2-3
(3) To correct EA's concern, the project issued Revision 5 of Calculation SQN-YD-VAC-2 (Reference 23)referencingthe2technicaljustificationsinthecalculation revision log to ensure that the major as-constructed calculation will be revised to reflect the as-constructed status of the workplan when nodlfication is corplete. As indicated above, the 3rd technical justification issued is being tracked in the SQN EEB Calculation Tracking Log.
(4) As an action to prevent recurrence, PM-85-01 (EEB) (Reference 24) will be revised post-restart to state: "Technicaljustificationspreparedandissuedinlieuof fonnal revisions to existing calculation shall be docurented as revision log revisions to the calculation affected by such justifications."
l Results of EA Evaluation:
EA Electrical reviewed the revision log of Calculation SQN-VD-VAC-2RS and Attac'enent 1 R3 of SQEP-09 (Change Review CheckIlst for Electrical C31culation) and found them acceptable. EAconcurredintheprojectsassessmentofthisconcern. Action item El-017 was resolved and will be closed pending Ea verification of the revision to PM-86-01(EEB)toaddresstechnicaljustifications. This documentation work will be verlfled in Phase !!.
c.
Action It m El-018R0 a tion Item El-018 R0 resulted frcri EA Electrical's review of ECN L73348 and pertains c
to a docrentation error and to certain limiting conditions of operation that were identified in electrical calculations but were not included in any output docrent. At the time of the issuance of the EA-OR-003 Report, this action item wJs not responded tc bytheproject(
Reference:
section 6.7.2.1 of the EA-OR-003 Report).
Project Action:
InresponsetoEA'sconcernspresentedinActionitemEl-018,theprojectprovidedan assesseent as follows:
(1) The apparent cause of the concerns appear to be: a) The ECN preparer failed to I
note in the USQO and modification criteria that the FSAR was affected by the ECN changes as a result of t*e FSAR ccrpliance review Included in calculation SQN-AL5-II (Reference 25). and b).
The limiting conditions outlined in calculation SQN-AL5-013R0 (Reference 26) were based on the diesel generator (0.G.)
loading Ilmits p ovided in O!M-5QN-0C-Y-II.4.1-9 dated March 27, 1988 (Reference 27). Subsequently, O!M-SQN-0C-V-II.4.1-10 dated April 27, 1988 (Reference 28) deleted the 0-3 min. 0.G. margin thus eliminating the limiting conditions for the 0.G. loading during this period. Also, further study revealed that the 75 hp main turbine turning gear oil purp and the 30 kw D.G. engine jacket water heaters which require manual tripping per calculation SQN-AL5-013R0 did not operate during the critical D.G. loading tire. Both of these problies seem to have resulted from an ineffective corriunication between electrical and mechanicel disciplines.
4.2-4
(2) The DB&VP considers the first concern (a documentation error) is limited to this oversight in the modification criteria and the USQO (for ECNs L73348 Unit I and L733SB Unit 2) since the EA Team, based on the results of their review of several 7000 series ECNs, identified no trend af negligence in properly revising the FSAR. For the second concern, the project detennined soon after calculation SQN-ALS-013R0 was issued that no limiting conditions existed. This calculation has since been revised to indicate that the 0.G. loading due to the ECN change is acceptable. No other instances of this nature were noted by the project in EA's report. EA-OR-003.
(3) ToalleviateEAconcerns,theprojectrevisedthemodificationcriteria N2-L-7335-01 (Reference 29) and the USQO support sheet for ECN L7335C (Reference 30) to agree with the FSAR conpliance review Included in the calculation SQN-ALS-11 and initiated Attachment 8 of SQEP-129R0 (Change Request to FSAR Fonn) dated August 18,1988 (Reference 31) to revise FSAR Table 8.3.1-8 (Reference 32). For ECN L7334 the project detennined that the modification criteria did not require revision. The F5AR Section 9.4.2.2.3 (Reference 33) revision is being handled via ECN L72420 (Reference 34). In addition, the project issued Revision 1 of Calculation SQN-ALS-013 (Reference 35), based on the latest revision (R8) of Calculation SQN-E3-002 (Reference 36), to show that no limiting conditions for the 0.G. loading exist.
(4) Since both problems appear to have resulted from a single instance of misecmmnication between electrical and mechanical disciplines, no action to prevent recurrence is deemed necessary because both parties involved are sufficiently aware that more care is needed in this area. The 084VP considers the concerns raised in this action item insignificant because the operability of the plant was never affected.
Results of EA Evaluation:
EA Electrical reviewed Modification Crlierla N2-L-7335-OlR2, USQO Support Sheet Revision C dated August 17, 1988 (for ECN L7335C), Change Request to FSAR Form dated August 18,1988, ECN L72420, Table 2 of Calculation SQN-E3-002R8 daled August 4,1988, and the revision log of Calctlation SQN-AL5-013R1 dated August 16, 1988, and found them technically acceptable. Action Item El 018 was resolved and will be closed pending EA verification of the revision to Calculation SQN-E3-002R8 to show the additional loads to the 0.G. due to ECNs L7334 and L7335. Since this is a documentation revision which l
will not affect the results of the calculation, this verification will be performd in Phase !!.
4.2.3 Conclusions EA Electrical has conpleted the verification of the Phase 1 (restart) portion of the restart action ltoms. The DB&VP objectives for change document evaluations, system evaluations, and the transitional des 1{,n, change control, were verifled to have been met. Based on the EA verification of Phase ! C/A for the "restart" actich ltoms reported in the EA OR-003 keport and for the preceding action items EA Electrical concluded that:
1 Documentation asstetled to support the engineering conclusions reached by the D34VP electrical discipline was technically adequate.
4.2-5
The system evaluations and C/As including restart dettminations and irrplementation of e
restart items were technically acceptable and confirm that the system's ability to perform its safety functions for the events described in Chapter 15 of the FSAR was not degraded by the changes made since OL.
In general, the transitional design change control program was adequate for the design changes reviewed by EA Electrical. Additionalprojectattentiontotheareaof coordination between disciplines is recommended to further reduce errors. Because this activity represents a major change from past TVA change control methods. EA will continue l
to fronitor this activity.
1 EA Electrical closed action items E1413 and El-016. Additional Phase !! C/A verification remains for action items El-007 El-017, ari.1 El-018. This will be accceplished and reported as part of the Phase !! effort.
4.2.4 References Reference N?ber Document and Revision issue Date Title / Description 1
ECN L5346 R0 02/2C/81 Increased inlet Air Area to the Turbine driven Auxiliary Feedwater Pucp Room and Replace DC Fan on Unit 1 (5QP 810226 509) 2 CAQR SQP871335R3 04/18/88 Auxillary Feedwater Pung Turbine Controls - Alternate Feeder (513 880418 803) 3 Work Request 8255922 08/05/88 Caution Tag For Alternate DC Feeder to AFWPT Transfer Switch 4
CAQR SQT870150R0 03/06/87 ECN L6500 - Irrelementatic of F1-Modifications Not Properly Docurrented (513 870309 842) 5 SCR SQNEE88742R0 01/17/87 Isolation criteria (825 870130 032) 6
$CR SQNEE88743R0 01/18/87 Calculation inadequacy For Instrument Adequacy (825 870209 010) 7 SCR SQNEE88773R0 (l/04/87 Failure To Follow The Intent of Design Criteria SQN-DC-Y-13.9R0 (825 870223 032) 8 SCR $QNEE88777R0 02/03/87 ECN 2909 - Wide Range Steen Generator Level Transmitters (625 810220 071) 9
$CR 5QNEE88799R0 02/18/87 SQN-0C-Y-12.2. IE Bulletin 80-06 (825 870407 134) 4.2 6
I gferenceNeter Document and Revision Issue date Title /Descriptier 10 Attactvnent A of SQA203 03/21/88 Unit 1 Restart Deter ination Fonn For SCR SQNEEBC743 11 Attactvnent A of SQA203 03/06/88 Unit 1 Restart Determination For For SCR $QNEEB8773 12 TR01 Report 08/14/88 Trar; king and Reporting of Open items 13 PlR 50 nae 886108 R2 07/29/88 Replace the 15 ft-1b motors on valves 1-FCV-1-15. -16, and -17 with 25 f t-lb r% tors tR82 880805 003) 14 ECN L7211 R0 06/17/88 Change power supplies to hydrogen analyzers, 2A-A and 28-8 frun 400-V Reactor Vent Board to Reactor MOV Board (825 880617 SR2) 15 DNE Calculations 07/31/88 Hydrogen Analyzers Power Supply (843 870803 903) 16 iCN L7211C 06/15/88 Change Power Supp11es To Hydrogen Analyzers 2A-A and 28-8 Frorn 400-V Reactor Vent Board to 480 V Reacto-Muv Board (825 880611582) 17 NEP 3.1 R1 09/27/e7 Calculation (805 870928 5C0) 18 Technical Justification 08/11/87 843 870813 903 19 itchnical Justitication 04/06/88 825 880414 004 20 R3, $QEP-09 07/18/83 Change Review Checklist For to ECN L71300 Electrical Calculations 21 SQEP-09R3 02/03/88 Change Review Checklist For Electrical Calculations (825 880203 029) 22 Technical Justification 09/04/88 825 880804 017 23 5')N -YD-V AC-2R5 08/11/87 DNE Calculation (825 880817 901) 24 PM-86-01R1 10/15/67 EE8 Procedure Method Engineering Judgment (843 871015 901) 4.2-7 i
Reference Nureer Document and Revision issue Date Title / Description 25 SQN-ALS-11R0 03/23/88 DNE Calculations (825 880323 304) i6 SQN-ALS-013R0 03/30/88 Calculation (825 880330 300) 27 O!M-5QN-DC-Y-11.4.1-9 03/27/88 Design Input Memo on Design Criteria SQN-0C-V-11.4.1 (825 840327 002) 28 O!M-5QN-DC-V-11.4.1-10 04/27/M Design input Memo en Design Criteria SQN-0C-V-11.4.1 (825 880427 015) 29 N2-L-1335-0lR2 Modification Criteria For ECN L7335C 30 AttacNwnt 1 of 08/17/88 05Q0 Support Sheet For ECN L7335C SQEP41-11RC 31 of 08/18/88 Change Request To Floal Safety SQEP-129 Analysis Report Fonn For ECN L7335C 32 FSAR lable 8.3.1-8 Unit 2 Power Train 8 Soard Loading 33 FSAR 5ecH on 9.4.2.2.3 Safety Feature Equipment Coolers 34 ECN L7242D 08/19/88 Revise ERCW Flows and/or Air Flow Requirements For Specified HVAC Coolers (B25 886820 582) 35 SQN-ALS-013R1 08/16/86 DNE Calculations (825 880817 900) 36 5QN-E3-002RB 08/08/88 DNE Calculations (825 800808 SC' s
4.2-8
4.3 Instrianentation and Controls 4.3.1 Backaround The Instrumentation and Controls (l&C) discipline of the EA Tem evaluated project actions and verified iglemented C/As for the action items associated with the following activltles:
- Transitional Design Change Control (Action Items11-020 and 11-021) 4.3.2 Details Two !&C discipline restart action items were evaluated. At the time of issuance of the EA4R-003 report, one action item 11-02C was in a resolveu status; that is. C/A was agreed to by the LA Tem and project iglenentation of C/A and EA verification of C/A was required.
- i The orie
., A ning Action item 11-021 was not responded to by the project. The results of the above Acti ltem evaluations are presented in the following sections.
4.3.2.1 Transttional Deslan Chaece Control l
EA l&C's review of DB&VPs transitional Design Change Control process resulted in two Actio.
Items (11-020 and 11-021) which were considered "Restart" items.
l Action item 11-020 was "resolved" but required EA I&C verification of project C/A.
Action item 11-021 was considered a "Restart" Item since the design modification could affecttheUpperHeadinjection(UHI)flowratetothereactorhead. In addition. 06&VP did not provide a response to the action item by the time of issuance of EA-OR-003 Report
(
Reference:
section 6.7 3.1 of EA-OR-003 Report).
a.
Action Item 11-020 EA 1&C provided Action Item 11-020 which ideatified 4 concerns as a result of reviewing ECN L7112 (Reference 1) for Unit 2.
DB&VP provided responses which resulted in closure of three concerns by EA 1&C prior b issue of the EA-OR-003 report. The remaining concern was resolved but open pending verificationofprojectC/A. The open concern identifleo an igrcper contalrenent spray piping orifice size for which the project issued CAQR SQP880081 (reference 2).
EA concurred with the approved C/A plan per CAQR SQP880001 to issue an ECN to install the proper orifice size before restart.
Project Action The project provided ECN L7381 (Peference 3) which was issued Apell 18, 1988 (825 880418 575) for Unit I to Iglement C/A for CAQH !QP880081. ECN L7381 provided for the modification of the orifices in the contairv'ent spray pirps IA-A and 18-8 distharge lines to the contairvnent spray ring headers for unit 1.
Results of EA Evaluation EA 1&C reviewed the Project action to address the remalr.ing concern of Action Item 11-020 and found the ECN L7381 design modification docue ntation ceceptable. EA 14C considers Action Item 11-020 closed.
4.3-1
b.
Action item 11-021 EA !&C provided Action item 11-021 to identify 10 potential concerns involving ECN L6859 as follows:
1.
UsQO Sheet 6 (Reference 4) incoreectly stated that the "modificttion" dees not affect water volune delivery through the valves whereas water volume delivered is a function of the UHI isolation valves closure time and therefore, the modification could affect the safety evaluation.
2.
The logic diagram 47W611-87-1 (Reference 5) for the UHI system is not SMsently shown in the FSAR (section 6.3).
3.
Value of minimum operating pressure shown in SQN-DC-V-27.7, Table 3.7-3 (Reference
- 6) does not agree with value shown in section 3.7-3 (should be section 3.7-1).
4.
FSAR fable 6.3.2-1 does not show max operating pressure of 1285 psig.
5.
ONE calculation 1-PT-87-21 (Reference 7) presently shows SPEe as not applicable where SPEe is the Zero error due to the effects of the static operating pressur EA reccmnends that the DNE calculation include a value for SPEo in the calculat-for determining the overall value of An, the normal accuracy. Standard industrial practice uses the following equation for calculating SPEe:
1 (0.25% VR + 0.25% SP)
(
Reference:
Rosecount and Gould) l 6.
SQEP-13, AttacN'ent 3 was ircluded in the ECN package as AttacNnent 5 without being corpleted. EA !&C believes that SQEP-A!-II, R4 (Reference 8) attachment should have been attached to the ECN and completed.
7.
\\
ECN Lb859 (Reference 9) modification was provided to change the setpoints for I
units 1 and 2, P15-87-21
-22, -23, and -24.
The control diagram 47W610-07-1 (Reference 10) did not show the instrunent IGentification tag numbers for these i
oressure indicating switches (P!55).
8.
The origin of PT Sensing Line was not clear. It is not apparent if the origin should be the hydraulle process line or accumulator?
9.
The root valves for the pressure transmitter (PT) presently shown normally closed (NC) should be nomally open (NO) on drawir.g 47W610-87-1.
10.
In design criteria SQN-0C-y-27.7, the table 3.5-3 values for PT-87-21, 22, 23, 24, should be 2970 psig per ECN L6859.
g ect Action P
Project provided a response which was as follows:
1.
This modification leproves the operability of the valve and does not alter its mechanical configuration. Therefore, flow throu @ the valve is not affected; the intent of the statenent in the USQO was in regard to flow through the valve.
4.3-2
2.
Control diagram 47W610-87-1 refererces flow diagram 47W811-2 (Reference 11) which in turn references logic diagram 47W611-87. The control and flow diagres are in the FSAR and adequately represent system operation and configuration.
3.
Section 3.7-3 of SQN-DC-Y-27.7 does not state minlinum operating pressure.
4 The pressure of 1285 psig is for the UHI accumulator tank. This pressure is correctly IIsted in Table 6.3.2-3 of the F5AR.
5.
A review of calculation 1-PT-87-21 detemined that the value for 5 pee is negligible. Hence, the NA designation. Furthemre, the equation nentioned for I
detemining SPEe is not valid for use on BLH electronics transducer.
l 6.
The contents of AttacPvnent 2 of SQEP-Al-11 are included in the SQEP-13 Attachment 3.
The SQEP-13 Attactv9ent 3 is adequate since it is more ccrprehensive.
The project response stated that concern items 7 through 10 are design documentation errors. The affected drawings will be corrected and the design criteria will be revised to show correct inforniticn for resolution of items 7 through 10.
Results of EA Eval"ation As a result of the project response, EA !&C reconsidered the restart detemination of Action It m 11-021. There are now only dacueentation errors nvolved in this action item, and they have been evaluated by EA !&C as not rnetting the SQN restart criteria.
Therefore, EA I&C has reclassified 11-021 as "postrestart" rather than restart.
EA!&Cdoesnotagreewiththeprojectresponsestoaddressthedocumentattori discrepancies on concerns 1 through 6, and therefore Action item 11-021 is partially unresolved and open. This is a part of the phase !! effort to resolve C/A, leplement, and EA to verify.
EA !&C does concur with project responses on concerns 7 through 10 as resolved but 07 -
pending verification of C/* *,o the affected docurentation "postrettart."
4.3.3 Conclusions EA 1&C concludes that Action Item 11-020 is closed.
In addition, EA !&C concludes for Action Item 11-021 that EA's concerns 1 to 10 were docunentation errors and did not reet the SQN restart criteria, and therefore Action item 11-021 was changed from "restart" to a "postrestart" it m.
EA !&C considers Action Item 11-021 partially resolved pending veri'ication of correction of the docurentation errors (items 7 to 10) and partially unresolved /open pending resolution of concerns (items 1 to 6).
4.3-3
4.3.4 References Reference issue Nunter Doctnent and Revision Date Title / Description 1
ECN L1112 R0 6-11-87 Replace or Modify Existing orifices in the C55 Pung Olscharge Lines (B25 870611 551) 2 CAQR $QP88008) 2-17-88 Orlflee Sizing Calculation (513 800127 407) 3 ECN L1381 4-18-88 Modify the Orlfices in the Contalmeent Spray Pungs Discharge Lines to the Spray Ring Headers - Pupps IA-A and 18-8 (B25 880418 575) 4 USQO Sheet 6 2-14-87 ECN L6859 (825 870214 506) 5 47W611-81-1 R8 9-22-87 Electrical Logic Diagr e - UHI System 6
$QN-DC-V-27.7 R2 7-22-87 Design Criteria - UH! System (845 870722 257) 7 l-PT-81-21 9-15-87 Demonstrated Accuracy calculation (843 860917 913) 8 SQEP-Al-11 R4 6-23-87 Handling of ECNs 9
ECN L6859 2 14-87 Change the Setpoints for 1 and 2 - P!5-07-21
-22, -23, and -24 (825 870214 506) 10 47W610-87-1 RIO 9-22-87 Mechanical Control Otagr a - UHI Syst e 11 47W811-2 R21 4-13-87 Flow Diagre - Mechanical 5!5 - Upper
- Injection
- 4. 3 -4
l I
4.4 Mechanical 4.4.1 Backaround The Mechanical discipline of the EA Team evaluated project actions and verified Iglomented C/As for an action item associattd with the following activity:
i Transitional Design Change Control 4.4.2 Details I
One Mechanical discipline action item was determined to be a restart issue and was evaluated. This action item was not responded to by the project.
4.4.2.1 Transitional Desion Chance control Action item M1-008 The EA Meenanical review of ECN L72428 for the Transitional Design Change Control (TDCC) resultedinActionItemM1-008beingissuedtothePrcjectonApril 28, 1988 identifying several concerns with safety-related room coolers. The action item was not responded to Sv theProjectbeforeEA-OR-003wasissued. EA-OR-003 Identified Action Item M1-008 as required for restart. (
Reference:
section 6.7.4.1 (Action item M1-008) of EA-OR-003.]
Project Action:
I t
Project's infomal response of August 11, 1988 supp11ed Action item M1-008 statements on cause, extent, action to correct, action to prevent recurrence, and significance. Also, the following specific information was included:
l 1.
Cooling water flow rates for several coolers were changed by ECN t12428 (Reference 1).
All cooling water flow rates changes are within the range of the instrwents. The irstrument rang 3 do not have to be revised. See Table I for flow elenents involved.
{
The table shows the old flow rates, new flow rates, and the flow range.
y 2.
Surveillance Instructicn $1479 (Reference 2) requires inspection and cleaning of l
coolers and heat exchangers supplied by ERCW. This maintenance would keep the i
i equippent in a condition which supports the use of the 0.0]) foullog factor for these equipment calculations.
)
j 3.
A copy of the FSAR revision memo for section 9.4.2.2.3 was attached, it changed the text to reference the FSAR figures for tair and water flows. These figures will be i
revised as part of the yearly FSAR update therefore FSAR figures with revised flows are i
not available. The changes to the envirorvnental drawings and the associated f 5AR j
sections for these ECNs is being incorporated in Plant Modification Package (PMP) i P00000). This PMP revises th6 ultimate heat sink tenverature to 84.5'F.
The PMP has l
not been issued yet, but a draft copy of the scope section was attached to show that j
portion of the scope.
l r
j 4.4-1
(
I
l 4.
Special Test ST!-122 (Reference 3) verified the air flow rates for all Unit I coolers.
It will document the acceptability of these coolers for restart. The most current available data from the test and the test instruction wre attached for review. There is no surveillance test that requires verification of air flows. This has been noted in the recurrence control of CAQR SQP871697 R1 (Reference 4). The recurrence control for this CAQR requires inclemntation of a preventive maintenance program to Nintain cooler air flows.
Workplan 12692 (Reference 5) contained documentation of the A-train IRCW flows. The 1A 1
header flows were in section ta of the workplan and 2A header flows are docunented in workplan 12572 (Reference 6) as indicated in the workplan signoffs. The air flows wre signed off as meeting the DCA requirements in the workplan but the specific flows measured are documented in the 571-122.
5.
The revised pages from the $1-566 (Reference 7) revision do not need to be included in the workplan because the flows were verlfled to the DCA requirenants from the ECN therefore the 5!-566 criteria is not required.
Results of EA Evaluation EAmechanicalreviewedtheProject'sInformalresponsedatedAugust 11, 1968, to Action t
~
ltem M1-008 and finds the response acceptable. EA has determined M1-006 is resolved and t
the Phase I portion is carplete but remalns open pending "Post-Restart" verification of tk revision of F5AR Section 9.4.2.2.3 and Figures 9.4.2-3 and 9.2.2-4 for the air and water flows.
I TheindividualitemsintheProjectrespons*Wasjudgedtobeacceptableforallfive concerns based on the following:
1.
The Project response satisfactorily pMvided all the tepperature and flow instrumentation data required for the HVAC coolers affected by the E*N.
2.51-679 provides the necessary yearly inspection and cleaning ac appropriate of the coolers which supports the use of the 0.001 foullng factor.
i l
l l
l 3.
FLAR revision nemo incit.ded in the ECN revtsion for section 9.4.2.2.3 provides the l
necessary changes for updating the FSAR.
l l
4.
Special Test, 5T1-122 verified the air flow rates for all Unit I coolers. Also, i
workplan 12692 provided documentation of the A Train ERCW flows. Workplan 12572 l
provided documentation of the 2A header flows. Tne air flows were properly signed off as netting the DCA requirements in the workplan. The specific flows were monitored and documented in STI-122.
5.51-566 criteria not required since the flows were vertfled to the CCA requirements from the ECN.
4 4.4.3 Conclusions l
EA concludes that the Phase 1 portion of Action Item M1-008 is corplete. EA also considers Action item M1-008 resolved but remains open pending postrestart verification of the FSAR revisions.
4.4-2
4.4,4 References Reference Nweer Doewnert and Revision Issue Date Title and Description 1
ECN L72428 10-9-87 Revised EACW flow and/or air flow requirements for HVAC coolers (825 871123 526) 2 Survelliance Instruction 6-25-48 ERCW Heat Enchangers51-479 R4 Inspection 3
Special Test Instruction 5-7-88 Unit 1 (quipment Cooler
$11-122 R0 Air Flow Test 4
CAQR SQP871697 R1 7-29-48 513 8800229 tot 5
Workt.lan 12692 for 10-9-87 Verify ERCW and/or air flow ECN L7242 requirements for HVAC coolers. Update affectM doceents with reelsed flow rates 6
Workplan 12572 for 9-12-87 Plping replacement flow ECN L7243 verification test 7
Survelliance Instruction 5-28-87 ERCW flow verification test
$1 556 Rif
(
1 l
1 l
4,4-3
TABLE 1 ECN L7242 ROOM COOLERS EVALUATED FOR UN171 Old New
(
Flow Flow Range Flow Element
$22.'.C G'M GPM GPM 1
1-f E47-177
$l$ Pep h CLR 14 14 0-30 1-FE47-183
$l$ Pep h CLR 14 14 0-3G 1-F E 47-189 RHR A Pwip h CLR 12 12 1-F E47-191 RHR 8 Pep h CLR 12 12 1-F E 47-163 RCS 4 FW Pep b C.RA
$0 53.1 0-90*
1-FE 47-165 CCS & FW Pro b.LR8 50 53.1 0-90*
1 -F E-47-214 CCS IB & $FP 25 26.2 0-30*
1-F E 47-216 CCS IB & $FP Pwp CLR 25 26.2 0-30*
1-F E47-185 CS Pwp h CLR A 9
9 0-30 1-F E 47-187 CS Pwp Fen CLR 8 9
9 0-30 1-FE47-347 Pent h CLR A1 EL 670 12 12 0 30 1-F E47-349 Pent h CLR 81 EL 670 12 12 0-30 1-F E 47-351 Pent h CLR A2 EL 670 7
7 0-30 1-F E 47-353 Pent h CLR R2 EL 690 7
7 0-30 1-F E 47-355 Pent b CLR A3 EL 714 7
15 0 30*
1-F E47-357 Pent h CLR 83 EL 714 7
15 0-30*
- Items which chang d Notes:
1.
Orlfice plates only. No permanent instrumentation.
2.
No items exceeded their maximwn range.
l l
4.4-4
I 4.5 Doerations 4.5.1 6.:horound The operations (OPS) discipline of the EA Team evaluated project actions and verlfled inplemented C/As for the action items associated with the following activities:
Restart Test Program (Action Items01-007 and 01-010)
Transitional Design Change Control (Action Item 01-005) 064VP Phase ! Program Final Report (Action Item 01-011) 4.5.2 Details A total of four OPS discipilne Restart Action Items were evaluated. At the time of Issuance of the EA-OR-003 report, two action items (01-005 and 01-007) were in a resolved status; that is, C/A was agreed to by the EA Teah, and project irrelementation of C/A and EA verification c' C/A were required. The two remaining action items (01-010 and 01-011) were in an unresolved status;thatis,projectC/AwasnotagreedtobytheEATeam. The results of the above action items evaluations are presented in the following sections.
4.5.2.1 Rettart Test Procram EA 0F5 review of DB&VPs Restart Test Program resulted in two action items (01-007 and 01-010) which were considered "Restart" items.
s.
Action item 01-001 Action item 01-007 pertains to discrepancies between the maximum a110%4ble stroke tire (MST) values in 51-166.6 test runs for valves tCV-62-135 and -136 and values shown to the FSAR Table 6.3.2-1.
EA OPS evaluated the adequacy of the revision to the C/A for CAQR SQP811446 (reference 1). (
Reference:
section 6.4.1.1 of the EA-OR-003 report.)
Project Action The Project provided a copy of CAQR SQP811446 which was previously written that recognized and Identified discrepancies between the MOV MST values shown in the F5AR Table 6.3.2-1,51-166, and in Design Criteria SQN-0C-V-21.3 Table 3.7-4 (reference 2).
This CAQR also identified other documentation discrepancies for MOVs which were outside the bounds of EA's problem idert'.fication.
infortration in the corrective action to the CAQR:The Project responded with toe following 1.
The $1-166 (re'erence 3) M57 acceptance values exceed the F5AR M57 values for tCV-62-135 and -13) but the actual measured M5T stroke times are within the design criteria values.
2.
In addition, the SI-166 MST acceptance values exceed the F5AR M57 values for FCV-63-12 and -73 but the actual measured M5T stroke tires are within the design criteria allowables.
The design c.1teria stroke time had been justified by Westinghouse in 1972 and is docurented in C/R data sheet No. SQNWESRJF1069 (reference 4).
4.5-1
3.
The $1-166 MAST acceptance values for LCV-62-135 and -136 and FCV-63-72 and -73 have already been rsvised to agree with the design criteria SQN-DC-y-27.3, Table 3.7-8.
I 4
The remaining corrective action is to revise the design critarla and F5AR to be in agreement as appropriate. TheprojectfurtherindicatedthatActionitem01-007 has no Igart on restart and can be a postrestart issue.
Results of EA Evaluation EA OPS reviewed the Project response concerning Action item 01-007 and found the information and carrective action acceptable. In addition, EA DPS verlfled that the j
5!-166 MAST values were revised.
Therefore, EA OPS concurs that C/A and verification of Action item 01-007 can be performed "Postrestart." In addition, EQ OPS considers Action Item 01-007 "Resolved" but remains "open" pending "Post-Restart" verification of the Iglementation of the corrective action to make the design criteria SQN-DC-V-27.3 (Table 3.1-8) and F5AR (Table 6.3.2-1) con.istent.
b.
Action item 01-010 Action item 01-010 identified a lack of calculation basis for specified mainsn RHR pure runout criteria for the 51 mode. EA CPS evaluated the project's follow-up response to determine if this concern was adequately addressed. (
Reference:
section 6.4.1.1 of the EA-OR-003 report).
Project Action Project responded that the Unit I and 2 SQEP-63 (reference 5) Restart Test Packages f' System 63, pages 21) and 212 were revised to state that the cold leg recirculation fic.
rate for the RHR puPp runout condition should be $500 gom in lieu sf 4679 gpm.
revision log for the Unit 1 package has been revised to reference the correct revision The level of the Unit 2 package.
Results of the Evaluation EA095reviewedtheProject'sresponseconcerningActionItem01-010andfoundthe response acceptable.
EA 0P5 verlfled that the Units 1 and 2 RHR pupp(s) runout flow rates were changed fran 4679 to 5500 gpm on System 63, SQEP-63, Attachment 2 (pages 21 and 212). Action Item 01-010 was closed.
4.5.2.2 Trantitional Desion Chance Control Action item 01-005 EA OPS review of 064VPs Transitional Design Change Control process resulted in one Action Itsm 01-005 which was considered a "Restart." item.
This action item involved the timeliness and the quantity of the backlog of red lined min room drawing updates.
evaluated the adequacy of the current control room drawing configuration status.
(
Reference:
section 6.7.6.1 of the EA-OR-003 report.)
f 4.5-2
l Project Action The Project responded that, Revision 28 of Al-19, Part !Y which was approved March 5,1988, better controls the red lining process and requires the revised drawing to be issued to the Control Rocen prior to declaring the system operable. They are currently working on the last three red line drawings to ccrplete the backlog of updating MCR drawings.
i l
Results of EA Evaluation EAOPSreviewedProjectresponsetoActionitem01-005sndfoundtheresponseacceptable.
EA also detemined that as part of a recent on-going DNQA audit SQA08-426, approalmately 75 Main Control Room drawings were reviewed. This audit by DNQA substantiated that very few red-Inne markings now appear on the Control Room drawings, and that the revision to Al-19, Part IV (reference 6) offers better controls than existed in the past. EA OPS concludes that the backlog of red line Maln Control Room drawings have adequately been incorporated into the primary drawings and that no further verification was deemed necessary. Action item 01-005 was closed.
4.5.2.3 DMVP Phase ! Proqram Final ReDort I
]
Action item 01-011 i
EA OPS review of DMVPs Phase 1 Program Final Report to verify completion of the DMVP program requirements resulted in or.e action item (01-011) which was considered an unresolvec
- Restart" item. This action item pertains to EA's request for a carparison of DB4VP's System Walkdown Boundary loentification Drawings (SWO!D) and safety related ccmponents with the SQN C55C list. A sanple evaluation by EA OPS had indicated t'at SWB10 corponents were not in the C55C list. EA OPS evaluated the project's follow-up response to detemine if EA's concern en tMs issue is adequately addressed. (
Reference:
section 6.8.6.1 of the EA-OR-003 report.)
Project Action The project responded that the Phase i DB4VP "system evaluation boundary (s)" was limited e
those systems and parts of systems reeded to mitigate Chapter 15 events. The DMVP boundary is defined by the SWBIDs. Theprojectstatedthatthis"scope"Isless corprehensive than the "safety-re',sted" C55C list and that carparison to or confirmation of the C55C list was not a requirement of the DB4VP as defined by the Unit 1 Program Plan or the 084VP procedures, in addit son, the project indicated that TVA has comitted to the hRC l
to oevelop a Q-list which will incorporate the existing C55C list and the DMVP Systans including cceponents on the flow, control, and schematic drawings of these systems. This j
is a postrestart comitment (4/89) at documented in TVA's letter to the NRC dated 2-29-48 (refarence 7) and is being tracked in CCTS as item NC0880035001.
Results of EA Evaluattor, EA OPS reviewed the P'oject response concerning TVA's cormitment to develop a Q-List by April,1989 and founq that the SQN Q-List inplementation plan will adequately address this Since thl4 comitment item is being adequ tely tracked by the CCTS system, EA OPS concern.
judgedthatnofurtherverificationwasdeemednecessary. Action item 01-011 was closed.
a t
I I
a 4.5 3 l
l
4.5.3 Conclusion EA OPS concludes that the Phase I portion of Action Item 01-007 is coglete. EA OPS considers Action its 01407 resolved but remains open pending "Postrestart" verification of the Iglemntation of the corrective action to make design criteria SQN-0C-V-27.3 and the F5AR cogatible.
Action items01-005, 01-010, and 01-011 were closed, 4.5.4 References Reference Nueer Document and Revision Issue Date Title /Descriptice, 1
CAQR SQP871446 9-15-87 513 871019 817 2
Design Criteria 7-24-06 Safety Injection Systen SQN-0C-V-27.3 R2 (845 870722 252) 3 survelliance Instruction 9-2-87 Sumary of valve Tests for Asaf
$1-116 R14 5ection II 4
SQNWE5RJF1069 5-8-86 C/R Data Sheet (845 060504 8t.
j 5
SQEP-63, System 63 R3 8-7-87 system Functional Requirements Package - System 63 6
Al-19, Part IV R22 Modifications after plant Ilcensing 1
TVA Letter to NRC 2-29-88 L44 880229 806 i
i r
)
i i
4.5-4 3
I
{
l 5.0 TREND ANALYSl5 0F RESTART EA TEAM FIN 0!NGS This section updates the surimary and trend analysis results presented in section 7.0 of the EA Oversight Review Report (EA-OR-003).
5.1 it22e ThisupdateispresentedtoincorporatetheProjectandEAactionsrelatedtoresolutionand verification of open action items that were considered to be Unit I restart issues in section 5.0 of EA Report (EA-OR-003).
5.2 Aporoach The Project and EA actions performed to resolve and/or close the action items were used as the basis for assigning trend codes for the unresolved /open items, and for confirming the trend codes assigned previously to the resolved but unverified action items. Thesame11 major categories and 83 subcategory codes used to trend the action items for EA Report EA-OR-003, were also applied to the updated action items.
5.3 UDdated Analysis of EA Icarn Action Item This section presents the results of the trend analysis of the restart items that were statused open in section 5.0 of EA Report EA4R-003. A list of these restart items is presented in Table A-1 of Appendia A.
5.3.1 Restart Action items Fra section 5.0 of EA Report EA-OR-003, there were 13 restart items that were statused open (i.e., resolved, unresolved, or no response). Theseitemswereclassifiedbythe11 major categories and then sorted by these categories using a data base program. The results of these sorts are presented below.
5.3.1.1 Activity Tvoes
{
Thiscategorydescribestheprojectactivityaffectedbytheactionitem. The sort on this category revealed the following distribution:
l Activity TvDe NW$er of action ite_ms Transitional Design Change Control *
?
Change Doc nent Evaluation 2
Restart Tess Program 2
System Evaluation 1
ObH P Final Report 1
'$se Detailed Analysis Section for further assessment of this activity.
5-1
l 5.3.1.2 Docewat Troe l
This category describes the docurrent(s) affected by the action item. The sort on this category revealed the following distribution:
Doc eent Troes Nureer of Action Items ECN/FCN/LDCR/iACF 7
Design criteria 2
't I
I Proge m Procedures (NEPs, SQEls) 2 Calculations 1
Drawings 1
l, 5.3.1.3 Element t
l This category descrlMs the type of problem addressed by the action item. ihe sort on this category reve.
following distribution:
j Elfment N d er of Action items 4
Documentation 4
- l Tet.hnical Adequacy 3
1, 1
Procedural 2
(
Design Consistency 2
i 4
a Review / Approval 2
I 5.3.1.4 Disciollne Affected 1
This category describes the discipline affected by the concern. The sort on this category j
revealed the following distribution:
l DisclD116e Affected NMer of action Itemg
(
l 5
l Electrical 5
Operations 3
IR 2
Mechanical 1
l Nuclear
)
j All (generic) 1 I
i l
I
}
52 i
_.,_-_-.,_._..l
i 5.3.1.5 conditions Adverse To Ovality (CA0)
This category identifies if a CAQR or a PIR was issued or revised as a result of an action item. The sort on this category revealed that one item resulted in the issuance of a CAQR, one other item resulted in the issuance of a PIR, two other items required revisions to existing CAQRs and one already had an existing CAQR. The action item and the CAQR/PIR nueers are ilsted below. (This list is based on the information provided to the EA Team ontheProjectresponses.)
Action item Nueer CAOR/PIR Nue er El-007 CAQR $QP871335 (Revise.rd to include Unit 1 C/As)
El-013 PIR SQ4MEB86100 (Revised to incluoe Unit 1 C/As)*
1 11-020 CAQR SQP880001 N1-002 PIR SQNEE88824'01-007 CAQR SQP880148 (Volded because of existing (CAQR SQP871446)
'Not considered a CAQ based on NEP 9.1 definition, i
5.3.1.6 validity This category describes the nurter of Action items that are valid concerns or coments.
4 The sort on this category revealed that all 13 restart items were considered walid.
i j
5.3.1.7 Extent Code i
l This category defines the extent of the concern. A sort on this category revealed the following distribution:
i Entent Nurter of Action Item Limited 11 Unique 2
i j
5.3.1.8 Cause code This category dest. rib (s the cause of the concern addressed by the action items. The sort on this category revealed the following distribution:
4 i
i cause Code Nuear of Action items i
inadequa*.e Review 9
Inadequate Procedures 2
4
\\
Inadequate !Polonentation 1
1 Lack of Interface Control 1
1 I
I l
5-3 l
= ~.
5.3.1.9 Inmact This category describes the type of changes that resulted from the action item. The sort on this category revealed the following distribution:
M Nw$er of Action Itag Technical Change 10 l
Progranmatic Change 3
5.3.1.10 Status This category is used to determine if the corrective action (s) will be verified pre-or postrestart. The sort of this category revealed the following distribution.
Status Nweer of Action items l
Postrestart 7
Prerestart' 6'
L
- These 6 restart items which required verification prerestart have been closed by the EA i
j Team.
5.3.1.11 Hardware l
I l
This category identifies the action items that required hardware charges as part of th*8-
[
C/A(s). The sort on this category revealed that 4 of the 13 open restart items invo~
}
4 hardware changes. The four action items involving hardware changes are:
i i
t l
l Action item Nweer grdware Chang
}
I El-007 Install caution tag 4
l l
El-013 Replace motor operators i
i 14-020 Replace /resl2e orifices l
k j
N1-002 Replace tenporary instrumentation J
]
5.4 Drlalled Analysis i
The summary evaluation of the 13 restart items revealed that seven (7) affected the Transitional Design Change Control (TDCC) activity. TOCC activit.v had a total of 14 action i
items isseed against it by the EA Team. Since 8 of the 14 total TDCC action items were l
unresolved in LA Report EA-OR-003, section 7.6.3, no conclusions could t'e drawn as to the nature, extent, cause, or impact of this activity. Since 12 of the 14 TDCC action items have now been resolved, this activity will t,e analy:e1 in detail in the following section to determine any overall areas of concern.
'.ne category code distribution of the action items related to this activity are presented in the next section.
1 5-4
5.4.1 Transitional Desion Chance control Fourteen (14) or 13.9 percent of the 101 valid action items involved problems wi h TDCC. The t
14 ltems are listed in Attachment 1.
These 14 ltems involved the following attributes:
5.4.1.1 Doceent 73oe - The doceent type affected by the 14 action items are distributed as shown below:
Doc eent free Nunber of Action items ECN/FCN/DCR/TACF 6
Drawl.3s 2
Calculations 2
Design Criteria 2
Procedural Progra (NEP, SQEP) 1 Aeninistrative Procedures 1
5.4.1.2 Etenent - The type of problems addressed by the 14 action items included 5 items with procedural problems, 4 items involving doctrentation deficiencies. 3 involving technical adequacy, and 2 with lack of design consistency.
5.4.1.3 Discioline - Of the problems addressed by the 14 action items, 3 each affected the Ele:trical and operation disciplines, 2 each affected the Civil, l&C and Nuclear disciplines. I affected the Mechanical oiscipline, and I affected all disciplines.
Note: Only the first four attributes for unresolved action items C1-004 and C1-009 could be coded, therefore, the remaining detall analysis of TDCC ul11 address the remaining 12 resolved action items.
5.4.1.4 LAQ. CAQR SQP900001 was issued to address the concerns in Action item 11-020. None of the other action items resulted in a CAQR or a PIR.
5.4.1.5 validity - All 12 of the action items were valid findings.
5.4.1.6 Estent Code. Ten (10) of the 12 action items were limited in entent to the affected discip11oe while the other two action items identified Isolated problems with the TDCC process.
5.4.1.7 Cause code - The cause of the 12 action items cont.lsted of 5 resulting from inadequate impleawntation of established procedures, 4 resu' ting from inadequate review, 2 frtun inadequate procedures, and 1 from lack of interface control.
5.4.1.8 Incoct - Seven (7) of the 12 items resulted in a technical change and the other 5 required a programatic change.
5-5
5.4.1.9 Status - Four (4) of the 12 action items have prerestart requircenents regarding the Iglementation of their corrective actior.s and the other 8 require post-restart verification of their corrective actions. All four of the prerestart action items have been closed by the EA Team.
5.4.1.10 Hardware Affectad - Only one (11-020) of the 12 action items in the TOCC activity resulted in hardware change. The hardware change for 11-020 was replaccenent/ resizing of orifices.
5.5 Con:lusi,on This section presents the overall areas of concern identified during the review of the detailed analysis section, 5.5.1 Transitional Desicn Chance control /Fermanent Deslan Change control j
The detailed analysis section 5.4.1 reveals that the problems identified by the EA Team review of the 10CC activity af fected all disciplines. The mjority of the problem involved l
ECN/FCN, TACf s, and LDCRs and were prinurily concerned with the procedural, docunentation, and technical adequacy of the affected documents. Themajorcauseoftheidentifledproblem was inadequate irnplementation of established procedures and leadequate review and the corrective actions primarily involved technical changes to the affected documents.
Several problems addressed by these action ittens included:
Inadequacies and inconsistencies in ECN packages.
Control room drawings not kept current.
Deficiene.les in the SQEP-13 process.
Based on the inforvation given above, the progranrutic adequacy of TDCC was an overall area of concern in EA report EA-OR-003.
The project has l@lemented the following C/A5 to address the problems:
Revised the ECN packages as required.
Updated control room drawings.
Revised SQEP-13 to clarify identified discrepancies.
Issued SQEP-26 to imlcment the pernunent design change control program described in NEPs-6.2, 6.3, 6.4, and 6.6.
To access effectiveness of the project's actions, EA performed an additional review of change documents issued af ter the issuance of the EA report EA-OR-003 and determined that the C/As iglementedbytheprojecthavel@rovedthedesignchangecontrolprocess. Based on im lementation of the C/As of the action itcms and the results of the additional review, the EA Team has judged the d4 sign change control process to be acceptable.
5.5.2 The other six restart items analyzed in this report did not show any significant imact on the trends discussed in EA report EA-OR-003.
5-6
- = _ - - -
.~
P.CTION ITEMS WITN ACTIVITY TYPE TRANSITIONAL DESIGN CMANGE CONTROL ACTION ITEM NO.
DETAIL DESCRIPTION OF ACTION ITEM l
l C1-S$8 ECN L7147 DATA SNEET IDENTIFIED INC6RRECT DATE OF ISSUANCE FOR THE REFERENCED DRANINGS
{
C1-009 CIVIL CALCULATIONS FOR ECNs a,7141 AND 7147 EINIBIT TECHNICAL INACCURACIES El-816 INADEQUATE EVAL OF ECN L7211 FOR FOTENTIAL EFFECTS ON DSGN DOCUMENTS AND SAFETY EVALUATION El-817 TECW JUSTIFICATION MEMOS FOR ECNs L7138 & L7129 CONTAIN UNVERIFIED ASSUMPTIONS & NOT TRACED TO ENSURE CALC El-018 OUTPUT DOCUMENTS NOT ISSUED FOR LIMITING CONDITIONS IDENTIFIED IN ELECTRICAL CALC CONTAINE3 IN ECM L7334 11-029 INADEQUATE TECM SPEC / SURVEILLANCE REQUESTS FOR CONTAINMENT SPRAY SYS FUMP3-UNIT 2 Il-921 INCONSISTENCIES IN SYSTEM 87 DESIGN DoctATENTS M1-90s. REVIEN OF ECN-7242 AND RELATED CALC MAS IDENTIFIED TECHNICAL CONCERNS INVOLVING ERCN AND NATER FLONRAT L*1-919 DISCREFANCT CONCERNING AIR FLON RATE TO THE PRESSURIZER ENCLOSURE BETNEEN FMT-195, QIR NE987297R2 AND SON-DC-V-13.9.5 NI-SI6 REVIEN IN ACCORDANCE NITN ATTACMMENT 3 CHECFLIST FOR ECN-6892 NAIVERED TO AI-11 NAS NOT FOUND IN THE ECM PACKAGE OI-CS)
FAILURE TO UPDATE PRIMARY CONTROL ROOM DRANINGS NITNIN 15 DAYS AS REQUIRED BY SOE?-2E 01-894 MODIFICATION NORRFLANS NOT DEING FREFARED, UTILIZED, OR COMPLETED IN ACCORDANCE NITH LATEST REVISIOst OF AI-19 (PART IV)01-895 RED-LINED FRIMARY CONTROL ROOM DRANING UPDATE BACREOG EXTENDS BACK TO 1986 Q1-901 RENUMBERING PROCESS FOR DCA IN SQEF-13 NET.DS CLARIFICATION AND REV LEVEL DISCREPANCIES FOR ECNs/DCNs NEED RE e
ve N
i l
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APPC WIX A Page 1 of 4 EA ACTION ITERS EVALUATED IN THE FOLLCW-UP EFFORT AlistoftherestartactionitemsthatrequireprojectactiontocogletetheUnit1 phase!effortto the DMVP is presented in Table A-1.
Table A-2 presents the status of each action item considered to be a restart concern at the time the EA-OR-003 report was issued. For the resolved action item, the project's iglementat on of C/A and the EA Team's verification were required to satisfactorily close the i
action item. For the unresolved action items, the EA Team's approval of C/A and agreement of Phase I or Phase 11 C/A iglementation status an EA verification of C/A were required. The status of restart action items at the conclusion of the EA follow-up effort is presented in Table A-3.
APPEN0!I A Page 2 of 4 TA8tE A-1 SQN DESIGN BASELINE AND VERIFICAi!ON PROGRAM - PHASE I. UNIT I EA ACTION RE51 ART ITEMS FROM THE EA-OR-0W REPORT ISSUED JUNE 27, 1988 Action item Nureer QtJs_cription El-007 Inadequate Unit 2 punch 11st evaluation for appilcability to Unit 1 ECN.
El-013 Inadequate evaluation of ECW 2774 for System Evaluation 38 Unit 1.
l El-016 Inadequate evaluation of ECN L-7211 for potential effects on design documents and j
safety evaluations.
El-017 Technical Justification Memos for EC4's L-7130 and L-7129 contain unverified assug tlons and not tracked to ensure calculations are revised.
l El-018 Output docuner.ts not issued for Ilmiting l
conditions ioentified in electrical l
3 calculation contained in ECN L-7334.
4 11-020 Inadequate Technical Specification or surveillance requests for contaltnent spray
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system pugs.
ll 11-021 Inconsistencies in System 87 design
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tocunents.
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M1-006 ERCli and water flow rates to HVAC coolers; I
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N1-002 Failure to use latest revision of SQN-0$G7-044 in change docwnent
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l categortration, j
1 01-005 Red-lined prim ry control room drawing update backlog catends back to 19M.
j 01-007
! groper iglementation of an NatC-approved
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technical specification change.01-010 Lack of a calculatten basis for 064VP i
specified malmum RHR pug runout criteria whileoperatinginsafetyinjectionmode cold recirculation line-up.
1 01-011 Cceparison evaluation needed in program final report (draft) between DB4VP safety boundary results and the SQN CSSC list.
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APPEN0!X A Page 3 of 4 TA8LE A-2 STATUS OF RESTART ACTION ITER 5 BY ACTIVITY REPORTED IN THE EA-OR-003 REPORT A5 0F JUNE 27, 1988 066VP Activity Resolvedl..
STATU53 UnresolvedZ No oes M System Boundary Detemination Design Criteria System Walkdowns Restart Test Program 01-007 01-010 i
Change Document Evaluations El-007, N1-002 1
System Evaluations and E l-013 l
corrective action?
Transitional Design 11-020 El-016 El-01) El-018, Change control 01-005 11-021, M1-008 084VP Unit ! Phase ! Peport 01-011 a
t NOTES:
1 1.
C/A was agreed to by EA but required either project C/A Iglementstion and/or EA verification, f
2.
ProjectC/AwasnotagreedtobyEA.
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3.
Thirty-six action items previously detemined to be postrestart issues in EA-0R-003 are not includ I
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APPEN0!X A
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Page 4 of 4 TABLE A-3 STATUS OF RESTART ACTION ITERS AT COMPLEiION OF PHASE I UN!T I FOLLOW-UP EFFORT A5 0F AUGUST 31, 1998 f
i Action item Restart Action item Status El-007 Resolved: Phase I cog lete Phase !!
verification required El-013 Closed El-016 Closed I
El-017 Resolve 1: Phase ! cog lete, Phase !!
verificN ion required 4
l El-018 Resolved: Phase I coglete, Phase !!
f verification required I
j 11-020 Closed i
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i 11-021 Evaluated to be a Phase !!
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l M1-004 Resolved: Phase I coglete. Phase !!
I verification required l
N1-002 Evaluated to be a Phase !!
j issue l
y 01-005 Closed l
l 01-007 Resolved: Phase I coglete Phase !!
verification required
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01-010 Closed
)01-011 Closed
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