ML20205E758

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QA Sys Engineering Evaluation QASE-R-004-85, Procedure Adequacy/Effectiveness
ML20205E758
Person / Time
Site: Oyster Creek, Three Mile Island, 05000000
Issue date: 03/06/1986
From: Fornicola J
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20205E603 List:
References
FOIA-86-293 QASE-R-004-85, QASE-R-4-85, NUDOCS 8608180481
Download: ML20205E758 (29)
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THREE MILE ISIAND NUCLEAR STATION QUALITY ASSURANCE SYSTEMS ENGINEERING EVALUATION i QASE-R-004-85 SITE LOCATION: Three Mile Island / Oyster Creek Procedure Adequacy / Effectiveness T(PE EVALUATION:

REQUESTED BY: C.R. Tracy - Director, Engineering Assurance PURPOSE OF EVALUATION: An administrative review to determine the effectiveness and efficiency of TMI's and Oyster Creek's Environmental Qualification procedure program for maintenance and surveillance activities.

DATE COMPLEED: >; r h 6, ,1 86 SUBMITTED BY:

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APPROVED BY:

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L 4h CONCURRED BY: bEbk DISTRIBUTION: H.D. Hakill, Jr. D.M. Shovlin R.L. Long B.E. Ballard, Sr.

P.B. Fiedler R.F. Fenti R.F. Wilson C.R. Tracy N.C. Kazanas J.J. Colitz R.J. Toole W. Smith J.L. Sullivan, Jr. G.J. Troffer E. Scheyder 81 1 860807 WEISS90-293 PDR A

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TABLE OF CONTENTS I.agg SYNOPSIS 1-2 REFERENCES 3 OBSERVATIONS / RECOMMENDATIONS 4 - 12 13 EVALUATION BENEFIT ANALYSIS r

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- QASE-R-004-85

  • Pcg2 1 cf 13 Evaluation of the Adequacy of the Environmental Qualification Program Procedures at Three Mile Island and Oyster Creek SYNOPSIS j The purpose of this evaluation was to assess the adequacy and effectiveness of the TMI and OC Environmental Qualification (EQ) Program Procedures in controlling EQ activities at the respective sites. The scope of this evaluation was limited to EQ Procedures EQ 105.3, AP 1054, and MP 1407-2 and how well they control the site EQ programs. The techniques used to perform this evaluation included documentation checks and personnel i

interviews. Specific questions addressed during this evaluation included:

Are the Environmental Qualification (EQ) Programs at TMI and 4

1)

Oyster Creek for maintenance and surveillance being controlled and coordinated effectively through the existing EQ procedures?

2) Do the EQ procedures provide adequate guidance for the replacement of equipment upon the end of qualified life?
3) Does the program effectively control the use of piece parts, e.g., reference to EQ parts book, guidance to request approval from EQ group for deviations, notifying EQ group of changes implemented by maintenance, either temporary or permanent?
4) Does the Environmental Qualification Trend Report deficiency guide ef fectively reflect failure frequency and/or surveillance t

findings?

Documentation checks consisted of reviewing and comparing the Oyster Creek EQ program procedure EQ 105.3 and the TMI EQ program procedures AP 1054 and MP 1407-2 to determine whether or not each one provides i adequate controls and which one is more effective. The interviews included personnel at both OC and TMI involved in the implementation of the EQ program. Th se personnel included individuals from Plant Engineering, Plant Maintenance, Maintenance Construction and Faci 1Leies, and Quality Assurance. The interviev questions were designed to help determine the effectiveness of the s'te procedures in controlling, coordinating, and guiding the EQ program.

! As supported by the details of this evaluation, both site programs adequately control the EQ programs, however, the OC program appears to be more effective. Although both programs are effective, both could i be improved and several recommendations are offered. These recommendations includes providing more specific information on the SSCEW sheets for 0.C., incorporating recently identified changes into the OC EQ procedure, setting up an 0.C. TF EQ group, initiating the SSCEW sheet program at TMI, combining the two TMI EQ procedures, including revising the 1407.2 enclosures, providing instructions on the SSCEW sheets when implemented and reference to the EQ parts book and deviation approval from TF EQ group.

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QASE-R-004-85

  • Pega 2 of 13 The details of this evaluation are contained in the observation / recommendation section of the report. The four questions listed above are addressed in depth including observations, conclusions, and recommendations. Although there has been an attempt to minimize the subjectiveness of this evaluation, the conclusions reached are the writer's interpretations of the personnel interviews and review of listed documentation. This report is for i your information and assistance and does not require reporting of actions which may be taken by you in this area. However, recommendations should I

be addressed and documented to file as a minimum in accordance with company policy.

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. QASE-R-004-85 Pega 3 of 13 REFERENCES.

1) EQ 105.3 (Maintenance of Oyster Creek Environmental Qualified Equipment)
2) AP 1054 (Control of Environmentally Qualified Safety Related Electrical Equipment)
3) MP 1407-1 (Unit 1 General Corrective Maintenance Procedure)
4) MP 1407-2 (Maintenance of Environmentally Qualified Safety Related Electrical Equipment)
5) Electrical Equipment Environmental Qualification Master List
6) TMI-1 Systems Component Evaluation Worksheet (SCEW)
7) TMINS Unit 1 Plant Engineering Procedure PEP-6, EQ Parts Books J

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- .. QASE-R-004-85 Pcgo 4 of 13 ,

QUESTION #1 Are the Environmental Qualification (EQ) Programs at TMI and Oyster Creek for maintenance and surveillance being controlled and cocedinated effectively through the existing EQ procedures?

OBSERVATION #1 In order to determine if the EQ procedures were effectively coordinating This and controlling the EQ programs a two phase approach was used.

approach consisted of reviewing and comparing the procedures and interviewing personnel involved in the implementation of the EQ program.

Oyster Creek Procedure 105.3, Rev. O, Maintenance of Oyster Creek Environm l

Qualified (EQ) Equipment provides the coordination and control requirements for the EQ program at 0.C. The responsibility section describes the functions of the various organizations responsible for implementing the EQ program at 0.C. These groups include: Plant Engineering, Tech Functions EQ, Maintenance Construction and Facilities Planning andUse of EQ ma Production, Plant Mat'erial, and QA Mod / Ops.

parts, and substitutes, along with qualified life and training arethe use of and completion covered in the requirements section. In addition,Thorough instructions of the SSCEW sheets is covered in this section. however, there are are provided on how to complete the SSCEW sheet, no instructions addressing what happens to the form after it is completed ,t nor are the e instructions for Tech FunctionsFinally, EQ review of the completed the procedure includes SSCEW sheets after the work is completed.

a section titled, " Guidelines for specific Components", when, in fact, these are generic guidelines that can pertain to almost any job / component.

The guidelines are a good set of workmanship practices and the associated checklist appears to be thorough and, if used, can help ensure the job is done properly.

informed that a meeting During my interviews with 0.C. personnel. I was had been recently held between the T.F. EQ group and the O.C. organizations involved in the EQ program to discuss problems with and proposed changes to the EQ procedure 105.3. All interviewees in felt this one procedure controlling and coordinating was much better than two or more proceduresthat one coordinating procedure helped re the EQ program. They felt administrative problems, specifically the In need for multiple revisions addition, all interviewees and the possibility of inconsistencies. it had only been in felt that the 105.3 procedure, considering thatfully developed and needed effect for about four months, was not yet improvement to be truly effective. They all felt that in improved the proposed procedure controls.

changes, if implemented, would resultto help improve / resolve the problems Some of the problems and changes with the procedure as seen by the interviewees include:

The generic guidelines are a mix of EQ requirements and goodA engineering practices.is not always clear whether the problem equipment occur, it Some problems are actually is actually an EQ deviation or not. really EQ problems.

lack of good engineering practices and not

  • QASE-R-004-85 Pcgs 5 of 13

- SCEW sheets should provide the minimum EQ requirements while the generic checklist should provide the good engineering practices.

This would help to eliminate some of the misinterpretation over EQ problems.

- Although the procedure pretty well describes the program responsibilities some areas are felt to be undefined and continue to cause confusion over responsibility. One such area is that of responsibility j l

for age related trending.

- Direction on what to do with completed supplemeetal SCEW sheets is needed. l

- Provisions for T.F. EQ group review of the supplemental SCEU sheets is needed.

- The procedure should provide for minor repairs, part replacement, and documentation of work performed.

- The Generic Cuidelines checklist is a mix of EQ requirements and good engineering practices. The list should be revised to include only good engineering practices. The SCEW sheets should provide all the specific EQ requirements.

In addition to the problem and resolutions presented previously to help improve the procedure / program, the interviewees presented the following:

- Improve the provisions for documenting all data taken during activities performed on EQ components, i.e. what was found and what was performed during surveillances, calibration, maintenance, replacement-in-kind, etc.

- Develop clear EQ boundaries, i.e., what is, is not EQ, harsh environments, etc. Lack of clear boundaries results in the writing of EQ deviation reports on n.on EQ problems. In addition to the clarification of boundaries and specification of EQ requirements on SCEW sheets personnel should be trained so that the proper requirements are applied to EQ equipment / components.

- Improve the processing of EQ related documentation. Slow processing of documentation could result in something being declared inoperable because of the time necessary to process the EQ related paperwork.

A possible solution could be the ad/icion of an on-site T.F.

EQ group to provide quicker turnar;an, of paperwerk and immediate resolution of EQ related prob'Am s Tech Functions EQ was aware of the hablema essociated with 105.3 and prior to the completion of this evaluation they completed incorporation of the comments and issued Rev. 2 to 105.3, effective date 3/9/86. This revision appears to incorporate the concerns identified above.

TMI has two procedures which provide responsibilities and controls for the EQ program at TMI. These procedures are Plant Administrative Procedure AP 1054, Control of Environmentally Qualified Safety Related Electrical Equipment, Rev. 2 and Maintenance Procedure 1407-2, Maintenance Rev.

of Environmentally Qualified Safety Related Electrical Equipment, 2.

-* QASE-R-004-85 Peg 2 6 of 13 The procedures are very similar and contain, in many cases, identical information. The purpose of the two procedures is nearly the same.

Subparagraphs in the scope sections and in the responsibilities section are similar. In addition, the responsibilities section in AP 1054 does not cover all of the groups that get involved in EQ activities such as MC&F, T.F. EQ and QA. The requirements section of the procedure

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again contains similarities but there are also some differences which result in covering the variety of aspects assoc ated i with EQ.

1407-2 contains 14 enclosures which address specific and generic requirements for 14 types of EQ components / equipment. Again, there is much duplication associated with these enclosures. Items 1 and 2 are similar or partially similar for ten enclosures, housekeeping is addressed in ten enclosures and several other items are addressed similarly on various enclosures.

In addition to the noted redundancies these enclosures are a mixture of EQ requirements and good engineering practice.

In general, those TMI personnel interviewed felt that the present TMI EQ related procedures AP 1054 and 1407-2, provide sufficient guidance and control for the EQ program at TMI. The interviewees did point out that since 1407-2 is the implementing procedure, it is almost exclusively used and little reference is made of AP 1054. In addition, the interviewees identified several problem areas with the procedures and provided some recommendations for procedure improvements. These

- problem areas and recommendations are as follows:

- Redundancy exists between the two procedures. Some of the sections are similar in wording and the enclosures include many similar requirements and good workmanship guidelines. Two of the seven interviewees felt that the two procedures, AP 1054 and 1407-2, could be combined into one procedure.

- Specific EQ requirements should be removed from the 1407-2 enclosures and all specific EQ requirements should be included on the SSCEW sheets when implemented at TMI.

- The 1407-2 enclosures should be combined and, if possible, one set of good workmanship practices should be retained as guidelines to be used in the performance of work on these components.

- Some of the enclosures require action that cannot be accomplished:

- Tightening of covers on limitorques to create a moisture proof seal. The representatives at limitorque have indicated that they (limitorques) are not intended to be moisture proof.

- Enclosures require that conduit be installed to provide a moisture proof seal but does not specify how to verify this seal. QC frequently marks N/A on their PIR's for items on the checklist due to the plants inability to perform some of the enclosure requirements.

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. QASE-R-004-85 Pcg2 7 of 13 In addition to problems with the procedure, the following problems and recommendations were made relative to other elements of the EQ program

- It s'ppears as though requirements associated with the " host component" are satisfactorily specified on the SCEW sheets but related parts such as connection / connectors, junction boxes, cables, etc. are not sufficiently specified. These related components / parts should be addressed on the appropriate EQ document.

- The majority of plant EQ components are not marked as such. Having the EQ components identified could be helpful in ensuring that the proper component controls are applied.

- Replacing parts each time a component is opened, such as cover gaskets, appears to be a waste of time and money. The evaluation of parts for re-use should be reviewed.

- In attempting to train or familiarize someone on the EQ program, there is no one document or set of documents put together as a program description to provide this training. Such a set of documents could be very helpful in training new personnel on the EQ program.

On the questions of the need for an on-site EQ group, TMI, unlike O.C.,

in general indicated no need for such a group.

CONCLUSION #1

a. The recently revised 0.C. EQ procedure, 105.3, appears to be adequate in controlling and coordinating the EQ program at 0.C.

The recent proposed procedure changes, revisions, and additions to the SSCEW sheets, development of clear EQ boundaries, and the establishment of an on-site T.F. EQ group appear to be improvements that could enhance the effectiveness and efficiency of the EQ procedure and program at 0.C.

b. The TMI EQ procedures, AP 1054 and 1407-2, appear to provide adequate control and coordination of'the EQ program at TMI. However, these procedures and the program at TMI could also be improved i to provide more effective and efficient control of the program. I As a result of many similar and redundant requirements / paragraphs, the lack of use of AP 1054 by those involved in the implementation of the program, and redundancies and potentially inappropriate requirements in the enclosurss, the procedures should be reviewed, revised and combined to provide one coordinating / controlling procedure for EQ at TMI. In addition, improved specificity on the SCEW and SSCEW sheets, development of a document or set of documents describing the EQ program, reviewing / evaluating the re-use of some EQ related parts and the marking of EQ components in the field would help improve the effectiveness and efficiency of the EQ program at TMI.  ;

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QASE-R-004-85 Peg 2 8 of 13 The improvement of some program elements at one site may also provide

  • benefit to the other site and all the proposed improvements should be reviewed for the applicability at each site.

RECOMMENDATION #1

a. Oyster Creek
1. Review the SSCEW sheets and provide for more improved documentation of all data associated with all activities on EQ components.

It should be noted that this does not infer that T.F. EQ should specify normal / typical maintenance requirements, i.e., T.F. EQ does not establish torquing requirements.

Recommendation Party: T.F. EQ

2. Develop a clear set of EQ boundaries at 0.C. so that it is obvious what is included as EQ in a string of components, i.e., is the conduit part of the EQ boundary. Alternatively, component marking may provide the same benefit. (See c.3.

below)

Recommendation Party: T.F. EQ

3. Consider establishing an on-site T.F. EQ group at 0.C.

Recommendation Party: T.F. EQ

b. TMI
1. TMI procedures AP 1054 and 1407-2 should be reviewed, revised, and combined into one procedure. This combined procedure or revision to one of the other procedures should include instructions on the use and completion of SSCEW sheets when they are implemented at TMI. This action would help reduce any confusion and difficulties associated with having to look through two procedures to understand the EQ program implementation at TMI. It could help reduce the administrative burden associated with biennial revisws and procedure changes / revisions and it would be consistent with the company approach on paperwork reduction. (The newly revised O.C. procedure 105.3 could be used as a reference)

Recommendation Party: TMI-l Division

2. The 1407-2 enclosures should be reviewed and revised to reduce the redundancy associated with their requirements.

Specific EQ requirements should be removed, when the SSCEW sheets are implemented and begin reflecting more specific EQ requirements, requirements that'cannot be implemented should be eliminated and the sheer number of enclosures should then be reduced to one or a few.

Recommendation Party: TMI-l Division f

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. QASE-R-004-85 Pcg3 9 cf 13

3. TMI shuuld review the re-use of various parts, such as cover gaskets with T.F. EQ and determine where they can employ this concept. 0.C. procedure 105.3 para. 7.1.3 allows the re-use of cover gaskets.

Recommendation Party: TMI-1 Division and T.F. EQ l

c. Both TMI & 0.C. )
1. Ensure that when the SSCEW sheets are issued, sufficient research has been performed to ensure they contain all the specific requirements tasociated with their related EQ components.

Recommendation Party: T.F. EQ

2. Establish one or a set of documents which act as a program description for the EQ program to aid in training and to be a ready reference for questions on EQ.

Recommendation Party: T.F. EQ

3. Plant EQ components should be marked as such either by a distinctive color, stenciling or other form of marking. This will help provide a ready reference of EQ components in the field. This marking should be independently verified and the marking should not be solely counted on as the identification of EQ components, the master list should continue to be referenced.

Recommendation Party: 0.C. Division, TMI-1 Division and T.F. EQ

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  • - QASE-R-004-85 Pogs 10 of 13 l

l QUESTION #2

. Do the EQ procedures provide adequate guidance for the replacement of equipment upon the and of qualified life?

OBSERVATION #2 Oyster Creek Station Procedure, 105.3 addresses replacement of equipment with installed lifetimes of less than 40 years in paragraph 4.5 In addition, 105.3 provides instructions for including equipment and component qualified life requirements on the SSCEW sheets, paragraph 1.3.3 and 6.1.34 respectively.

TMI Administrative Procedure AP 1054, addresses replacement of equipment with installed lifetimes of less than 40 years in paragraph 3.5. AP 1054 does not however, provide instructions for including equipment and component qualified life requirements on the SSCEW sheets because they have not yet been fully implemented at TMI.

CONCLUSION #2 Both O.C.'s and TMI's procedures adequately address the replacement of equipment upon the end of qualified life. However, it is the subjective opinion of this writer that TMI's procedure should include instructions on the use of and completion of SSCEW sheets including qualified life requirements when the SSCEW sheet program is implemented at TMI.

RECOMMENDATION #2

1. See recommendation 1.h.1 c

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QASE-R-004-85 Peg 2 11 of 13 QUESTION #3 Does the program effectively control the use of piece parts, e.g.,

reference to the EQ parts book, guidance to request approval from EQ group for deviations, notifying EQ group of changes implemented by maintenance, either temporary or permanent?

OBSERVATION #3 0.C. Station Procedure 105.3, addresses the use of piece parts in paragraphs 4.3 and 4.4. Paragraph 4.3 references the EQ spare parts book for replacements on spcre parts and it addresses notifying the T.F. EQ of changes. Paragraph 4.4 address T.F. EQ group approval of changes in equipment or material type.

TMI procedures AP 1054 and 1407-2 both address notifying T.F. EQ group of part replacement in paragraphs 3.4 and 3.3 respectively. The EQ parts books are covered in TMI-1 Plant Engineering Procedure PEP-6.

The cover sheet in the actual EQ parts book addresses deviation approvals.

Neither the EQ parts book or deviation approvals are covered in AP 1054 or 1407-2.

CONCLUSION #3 The programs at TMI and 0.C. address the use of piece parts. However.

l the program at TMI is somewhat piece meal and would require the review through several documents to obtain this information.

RECOMMENDATION #3 When TMI procedure 1407-2 is revised or when the TMI procedures AP 1054 and 1407-2 are combined to form a new or revised procedure, the

- revision should include reference to the EQ parts book and deviation approval from T.F. EQ group.

Recommendation Party: TMI-1 Divisiion l

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QASE-R-004-85 Pego 12 cf 13 QUESTION #4

  • Does the Environmental Qualification Trend Report deficiency guide effectively reflect failure frequency and/or surveillance findings?

I OBSERVATION #4 The initial intest of this report was that 0.C. would put it together and submit it to T.F. EQ. As a result of discussions between 0.C. ,

and T.F. EQ, it has been decided that 0.C. will no longer be required to prepare and issue such a report.

Since T.F. EQ has more expertise in this area, O.C. will send their SSCEW to T.F. EQ for age related activity review. T.F. EQ review will be documented and feedback to O.C. For TMI.T.F. EQ will continue to review the quarterly report submitted by Plant Engineering concerning material / equipment problems. T.F. EQ will provide specific guidance to TMI so that more pertinent age related information can be included in the quarterly report.

T.F. EQ is currently in the process of developing the guidelines on this process and should have them completed in the near future.

CONCLUSIONS #4 ,

None RECOMMENDATIONS #4 None

QASE-R-004-85

  • Peg 2 13 of 13 EVALUATION / BENEFIT ANALYSIS The conclusions and recommendations of this evaluation are somewhat subjective based on the opinions of the author and to a lesser degree those of the interviewees. This evaluation does, however, provide T.F. EQ, O.C., and TMI management involved in EO, a review and comparison of their EQ procedures effectiveness in implementing the EQ programs at the sites. If the recommendations are implemented, they should result in strengthening the existing procedures and program by providing better direction, reducing redundancy and unnecessary requirements and providing more specific requirements associated with work on EQ components.

If you have any questions or comments concerning this evaluation, please contact me on ext. 8614 at TMI.

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}LGO A-J. . ornicola hASystemsEngineeringManager l

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4 TABLE OF CONTENTS fagg SYNOPSIS 12 REFERENCES 3 OBSERVATIONS / RECOMMENDATIONS 4 - 12 EVALUATION BENEFIT ANALYSIS 13

  • QASE-R-004-85 f Pcg2 1 of 13 Evaluation of the Adequacy of the Environmental Qualification Program Procedures at Three Mile Island and Oyster Creek SYNOPSIS The purpose of this evaluation was to assess the adequacy and effectiveness of the TMI and OC Environmental Qualification (EQ) Program Procedures in controlling EQ activities at the respective sites. The scope of this evaluation was limited to EQ Procedures EQ 105.3, AP 1054, and MP 1407-2 and how well they control the site EQ programs. The techniques used to perform this evaluation included documentation checks and personnel interviews. Specific questions addressed during this evaluation included:
1) Are the Environmental Qualification (EQ) Programs at TMI and Oyster Creek for maintenance and surveillance being controlled and coordinated effectively through the existing EQ procedures?
2) Do the EQ procedures provide adequate guidance for the replacement of equipment upon the end of qualified life?
3) Does the program effectively control the use of piece parts, e.g., reference to EQ parts book, guidance to request approval .

from EQ group for deviations, notifying EQ group of changes implemented by maintenance, either temporary or permanent?

4) Does the Environmental Qualification Trend Report deficiency guide effectively reflect failure frequency and/or surveillance findings?

Documentation checks consisted of reviewing and comparing the Oyster Creek EQ program procedure EQ 105.3 and the TMI EQ program procedures AP 1054 and MP 1407-2 to determine whether or not each one provides adequate controls and which one is more effective. The interviews included personnel at both OC and TMI involved in the implementation of the EQ program. These personnel included individuals from Plant Engineering, Plant Maintenance, Maintenance Construction and Facilities, i and Quality Assurance. The interview questions were designed to help determine the effectiveness of the site procedures in controlling, coordinating, and guiding the EQ program.

As supported by the details of this evaluation, both site programs adequately control the EQ programs, however, the OC program appears to be more effective. Although both programs are effective, both could be improved and several recommendations are offered. These recommendations includes providing more specific information on the SSCEW sheets for 0.C., incorporating recently identified changes into the OC EQ procedure, setting up an 0.C. TF EQ group, initiating the SSCEW sheet program l

at TMI, combining the two TMI EQ procedures, including revising the l 1407.2 enclosures, providing instrtetions on the SSCEW sheets when implemented and reference to the EQ parts book and deviation approval i

from TF EQ group, i

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QASE-R-004-85 Pego 2 of 13 The details of this evaluation are contained in the observation / recommendation section of the report. The four questions listed above are addressed in depth including observations, conclusions, and recommendations. Although there has been an attempt to minimize the subjectiveness of this evaluation, the conclusions reached are the writer's interpretations of the personnel interviews and review of listed documentation. This report is for your information and assistance and does not require reporting of actions which may be taken by you in this area. However, recommendations should be addressed and documented to file as a minimum in accordance with company policy.

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QASE-R-004-85 Pcg2 3 ef 13 REFERENCES

1) EQ 105.3 (Maintenance of Oyster Creek Environmental Qualified Equipment)
2) AP 1054 (Control of Environmentally Qualified Safety Related Electrical Equipment)
3) MP 1407-1 (Unit 1 General Corrective Maintenance Procedure)
4) MP 1407-2 (Maintenance of Environmentally Qualified Safety Related Electrical Equipment)
5) Electrical Equipment Environmental Qualification Master List
6) TMI-1 Systems Component Evaluation Worksheet (SCEW)
7) TMINS Unit 1 Plant Engineering Procedure PEP-6, EQ Parts Books s

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QASE-R-004-85 Pcan 4 of 13 QUESfl0N (1 TMI and Oyster Are the Environmental Qualification (EQ) Programs atlled and coordinated Creek f,or maintenance and surveillance d  ? being contro .

l effectively through the existing EQ proce ures

. i OBSERVATION #1 were effectively coordinating This In order to determine if the EQ procedures pproach was used. a and controlling the EQ programs a two phase i a the procedures and interviewing l approach consisted of reviewing and compar f the EQng program.

personnel involved in the implementation o f Oyster Creek Environmental l requirements i

Oyster Creek Procedure 105.3, Rev. O, Maintenance o Qualified (EQ) Equipment provides the coordination implementing and controThe r for the EQ programThese at 0.C. groupsfunctions include: of thePlanning various organizations respo and the EQ program at 0.C.

i Functions EQ Maintenance Construction anddFacilitiesUse training are of EQ material, re

! Production, Plant Material, and QA Mod / Ops.

! parts, and substitutes, along with qualified Thoroughlife anIn addition, the use of a instructions covered in the requirements section. i 4

of the SSCEW sheets is covered CEW insheet, this however, sect on. there are are provided on how to complete the SS form after it is completed ,: '

iew of the completed -

j no instructions addressing what happens to thenor are SSCEW sheets after the work is completed. f Components", when, in fact, a section titled, " Guidelines for speci ic i to almost any job / component.

these are generic guidelines that can perta n i nd the associated The guidelines are a good set of workmanship pract ces ahelp ensure the checklist appears to be thorough and, if used, can job is done properly. informed that a meeting During my interviews with O.C. personnel, I wasd the O.C. organizations had been recently held between the T.F. EQ group ani h and proposed chang l involved in the EQ program to discuss problems w t this one procedure to the EQ procedure 105.3. All interviewees feltin controlling and coordinating

! dc I was much better than Theytwo or that felt moreone procedures coordinating procedure helped re u e l the EQ program. specifically the need for multiple revisionsIn addi l administrative problems, it had only been in i

and felt the possibility of inconsistencies.that the 105.3 procedure, effect for about four months, was not yetThey all felt that the proposed in improved procedure controls.

! improvement to be truly effective. the problems l changes, if implemented, would result l Some of the problems and changes toinclude: help improve /reso ve with the procedure as seen by the interviouses d good i

- The generic guidelines are a mix of EQ requirements anAs a engineering practices.

equipment occur, it is not always clear whether the problemSome p l is actually an EQ deviation or not. lack of good enginee i

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QASE-R-004-85 Pcga 5 cf 13

- SCEW sheets should provide the minimum EQ requirements while

  • the generic checklist should provide the good engineering practices.

This would help to eliminate some of the misinterpretation over EQ problems.

- Although the procedure pretty well describes the program responsibilities some areas are felt to be undefined and continue to cause confusion over responsibility. One such area is that of responsibility for age related trending.

- Direction on what to do with completed supplemental SCEW sheets is needed.

- Provisions for T.F. EQ group review of the supplemental SCEW sheets is needed.

- The procedure should provide for minor repairs, part replacement, and documentation of work performed.

- The Generic Guidelines checklist is a mix of EQ requirements and good engineering practices. The list should be revised to include only good engineering practices. The SCEW sheets should provide all the specific EQ requirements.

In addition to the problem and resolutions presented previously to help improve the procedure / program, the interviewees presented the following:

- Improve the provisions for documenting all data taken during activities performed on EQ components, i.e. what was found and what was pet formed during surveillances, calibration, maintenance, replacement-in-kind, etc. .

- Develop clear EQ boundaries, i.e., wnst is, is not EQ, harsh environments, etc. Lack of clear boundaries results in the writing of EQ deviation reports on non EQ problems. In addition to the clarification of boundaries and specification of EQ requirements on SCEV sheets personnel should be trained so that the proper requirements are applied to EQ equipment / components.

- Improve the processing of EQ related documentation. Slow processing of documentation could result in something being declared inoperable because of the time necessary to process the EQ related paperwork.

A possible solution could be the addition of an on site T.F.

EQ group to provide quicker turnaround of paperwork and immediate resolution of EQ related problems.

Tech Functions EQ was aware of the problems associated with 105.3 and prior to the completion of this evaluation they completed incorporation of the comments and issued Rev. 2 to 105.3, effective date 3/9/86. This revision appears to incorporate the concerns identified above.

TMI has two procedures which provide responsibilities and controls for the EQ program at TMI. These procedures are Plant Administrative Procedure AP 1054, Control of Environmentally Qualified Safety Related Electrical Equipment, Rev. 2 and Maintenance Procedure 1407-2, Maintenance of Environmentally Qualified Safety Related Electrical Equipment, Rev.

2.

  • Q'ASE-R-004-85 Pcg3 6 of 13 The procedures are very similar and contain, in many cases, identical -

information. The purpose of the two procedures is nearly the same.

Subparagraphs in the scope sections and in the responsibilities section are similar. In addition, the responsibilities section in AP 1054 does not cover all of the groups that get involved in EQ activities such as MC&F, T.F. EQ and QA. The requirements section of the procedure again contains similarities but there are also some differences which result in covering the variety of aspects associated with EQ.

1407-2 contains 14 enclosures which address specific and generic requirements for 14 types of EQ components / equipment. Again, there is much duplication associated with these enclosures. Items 1 and 2 are similar or partially similar for ten enclosures, housekeeping is addressed in ten enclosures and several other items are addressed similarly on various enclosures.

In addition to the noted redundancies these enclosures are a mixture of EQ requirements and good engineering practice.

In general, those TMI personnel interviewed felt that the present TMI EQ related procedures AP 1054 and 1407-2, provide sufficient guidance and control for the EQ program at TMI. The interviewees did point out that since 1407-2 is the implementing procedure, it is almost exclusively used and little reference is made of AP 1054. In addition, the interviewees identified several problem areas with the procedures -

and provided some recommendations for procedure improvements. These problem areas and recommendations are as follows:

- Redundancy exists between the two procedures. Some of the sections are similar in wording and the enclosures include many similar requirements and g3od workmanship guidelines. Two of the seven interviewees felt that the two procedures, AP 1054 and 1407-2, could be combined into one procedure.

- Specific EQ requirements should be removed from the 1407-2 enclosures and all specific EQ requirements should be included on the SSCEW sheets when implemented at TMI.

- The 1407-2 enclosures should be combined and, if possible, one set of good workmanship practices should be retained as guidelines to be used in.the performance of work on these components.

- Some of the enclosures require action that cannot be accomplished:

- Tightening of covers on limitorques to create a moisture proof seal. The representatives at limitorque have indicated that they (limitorques) are not intended to be moisture proof.

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- Enclosures require that conduit be installed to provide a moisture proof seal but does not specify how to verify this l

seal. QC frequently marks N/A on their PIR's for items on I

the checklist due to the plants inability to perform some of the enclosure requirements.

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. QASE-R-004-85 Pega 7 of 13 In addition to problems with the procedure, the following problems and recommendations were made relative to other elements of the EQ program:

- It appears as though requirements associated with the " host component" are satisfactorily specified on the SCEW sheets but related parts such as connection / connectors, junction boxes, cables, etc. are not sufficiently specified. These related components / parts should be addressed on the appropriate EQ document.

- The majority of plant EQ components are not marked as such. Having the EQ components identified could be helpful in ensuring that the proper component controls are applied.

- Replacing parts each time a component is opened, such as cover gaskets, appears to be a waste of time and money. The evaluation of parts for re-use should be reviewed.

- In attempting to train or familiarize someone on the EQ program, there is no one document or set of documents put together as a program description to provide this training. Such a set of documents could be very helpful in training new personnel on the EQ program.

On the questions of the need for an on site EQ group TMI, unlike O.C.,

in general indicated no need for such a group.

CONCLUSION #1

a. The recently revised O.C. EQ procedure, 105.3, appears to be adequate in controlling and coordinating the EQ program at 0.C.

The recent proposed procedure changes, revisions, and additions to the SSCEW sheets, development of clear EQ boundaries, and the establishment of an on-site T.F. EQ group appear to be improvements that could enhance the effectiveness and efficiency of the EQ procedure and program at 0.C.

b. The TMI EQ procedures, AP 1054 and 1407-2, appear to provide adequate control and coordination of the EQ program at TMI. However, these procedures and the program at TMI could also be improved to provide more effective and efficient control of the program.

i As a result of many similar and redundant requirements / paragraphs, the lack of use of AP 1054 by those involved in the implementation of the program, and redundancies and potentially inappropriate requirements in the enclosures, the procedures should be reviewed, revised and combined to provide one coordinating / controlling procedure for EQ at TMI. In addition, improved specificitf on the SCEW and SSCEW sheets, development of a document or set of documents describing the EQ program, reviewing / evaluating the re-use of some EQ related parts and the marking of EQ components in the field would help improve the ef fectiveness and efficiency of the EQ program at TMI.

-m- ,-- - -. _,--- - .-- _ , - _. _ _ - . __ _ _ _ - - - _ _ - . - - - . _ . _ _ - - - - - - - -

4 QASE-R-004-85 Pcg3 8 cf 13 The improvement of some program elements at one site may also provide benefit to the other site and all the proposed improvements should be reviewed for the applicability at each site.

RECOMMENDATION #1

a. Oyster Creek
1. Review the SSCEW sheets and provide for more improved documentation of all data associated with all activities on EQ components.

It should be noted that this does not infer that T.F. EQ should specify normal / typical maintenance requirements, i.e., T.F. EQ does not establish torquing requirements.

Recommendation Party: T.F. EQ

2. Develop a clear set of EQ boundaries at 0.C. so that it is obvious what is included as EQ in a string of components, i.e., is the conduit part of the EQ boundary. Alternatively, component marking may provide the same benefit. (See c.3.

below)

Recommendation Party: T.F. EQ

3. Consider establishing an on site T.F. EQ group at 0.C.

Recommendation Party: T.F. EQ

b. TMI
1. TMI procedures AP 1054 and 1407-2 should be reviewed, revised, and combined into one procedure. This combined procedure or revision to one of the other procedures should include instructions on the use and completion of SSCEW sheets when they are implemented at TMI. This action would help reduce any confusion and difficulties associated with having to look through two procedures to understand the EQ program implementation at TMI. It could help reduce the administrative burden associated with biennial reviews and procedure changes / revisions and it would be consistent with the company approach on paperwork reduction. (The newly revised O.C. procedure 105.3 could be used as a reference)

Recommendation Party: TMI-1 Division

2. The 1407-2 enclosures should be reviewed and revised to reduce the redundancy associated with their requirements.

Specific EQ requirements should be removed, when the SSCEW sheets are implemented and begin reflecting more specific EQ requirements, requirements that cannot be implemented should be eliminated and the sheer number of enclosures should then be reduced to one or a few.

Recommendation Party: TMI-1 Division

- QASE-R-004-85 Pcg3 9 of 13

3. TMI should review the re-use of various parts, such as cover gaskets with T.F EQ and determine where they can employ this concept. 0.C. procedure 105.3 para. 7.1.3 allows the re-use of cover gaskets.

Recommendation Party: TMI-1 Division and T.F. EQ

c. Both TMI & 0.C.
1. Ensure that when the SSCEW sheets are issued, sufficient research has been performed to ensure they contain all the

' specific requirements associated with their related EQ components.

Recommendation Party: T.F. EQ

2. Establish one or a set of documents which act as a program description for the EQ program to aid in training and to be a ready reference for questions on EQ.

Recommendation Party: T.F. EQ

3. Plant EQ components should be marked as such either by a distinctive color, stenciling or other form of marking. This will help provide a ready reference of EQ components in the field. This marking should be independently verified and the marking should not be solely counted on as the identification of EQ components, the master list should continue to be referenced.

Recommendation Party: 0.C. Division, TMI-1 Division and T.F. EQ r

l 1

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QASE-R-004-85 Pega 10 of 13 QUESTION #2 Do the EQ procedures provide adequate guidance for the replacement of equipment upon the end of qualified life?

OBSERVATION #2 Oyster Creek Station Procedura, 105.3 addresses replacement of equipment with installed lifetimes of less than 40 years in paragraph 4.5 In addition, 105.3 provides instructions for including equipment and component qualified life requirements on the SSCEW sheets, paragraph 1.3.3 and 6.1.34 respectively.

TMI Administrative Procedure AP 1054, addresses replacement of equipment with installed lifetimes of less than 40 years in paragraph 3.5. AP 1054 does not however, provide instructions for including equipment and component qualified life requirements on the SSCEW sheets because they have not yet been fully implemented at TMI.

CONCLUSION #2 Both O.C.'s and TMI's proced2res adequately address the replacement of equipment upon the end of qualified life. However, it is the subjective opinion of this writer that TMI's procedure should include instructions -

on the use of and completion of SSCEW sheets including qualified life requirements when the SSCEW sheet program is implemented at TMI.

RECOMMENDATION #2

1. See recommendation 1.b.1 1

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QASE-R-004-85 Pcg2 11 cf 13 QUESTION #3 Does the program effectively control the use of piece parts, e.g.,

reference to the IQ parts book, guidance to request approval from EQ group for deviations, notifying EQ group of changes implemented by maintenance, either temporary or permanent?

OBSERVATION #3 0.C. Station Procedure 105.3, addresses the use of piece parts in paragraphs 4.3 and 4.4. Paragraph 4.3 references the EQ spare parts book for replacements on spara parts and it addresses notifying the T.F. EQ of changes. Paragraph 4.4 address T.F. EQ group approval of changes in equipment or material type.

TMI procedures AP 1054 and 1407-2 both address notifying T.F. EQ group of part replacement in paragraphs 3.4 and 3.3 respectively. The EQ parts books are covered in TMI-1 Plant Engineering Procedure PEP-6.

The cover sheet in the actual EQ parts book addresses deviation approvals.

Neither the EQ parts book or deviation approvals are covered in AP 1054 or 1407-2.

CONCLUSION #3 .

The programs at TMI and 0.C. address the use of piece parts. However, the program at TMI is somewhat piece meal and would require the review through several documents to obtain this information.

RECOMMENDATION #3 When TMI procedure 1407-2 is revised or when the TMI procedures AP 1054 and 1407-2 are combined to form a new or revised procedure, the revision should include reference to the EQ parts book and deviation approval from T.F. EQ group.

Recommendation Party: TMI-1 Divisifon i

l QASE-R-004-85

' Peg 2 12 of 13 QUESTION #4 Does the Environmental Qualification Trend Report deficiency guide effectively reflect failure frequency and/or surveillance findings? ,

OBSERVATION #4 The initial intent of this report was that 0.C. would put it together and submit it to T.F. EQ. As a result of discussions between 0.C.

and T.F. EQ, it has been decided that 0.C. will no longer be required to prepara and issue such a report.

Since T.F. EQ has more expertise in this area, O.C. will send their SSCEW to T.F. EQ for age related activity review. T.F. EQ review will be documented and feedback to 0.C. For TMI.T.F. EQ will continue to review the quarterly report submitted by Plant Engineering concerning material / equipment problems. T.F. EQ will provide specific guidance to TMI so that more pertinent age related information can be included in the quarterly report.

T.F. EQ is currently in the process of developing the guidelines on this process and should have them completed in the near future.

CONCLUSIONS #4 ,

None RECOMMENDATIONS #4 None r

c .

' - QASE-R-004-85

' Pcg3 13 ef 13 EVALUATION / BENEFIT ANALYSIS The conclusions and recommendaticns of this evaluation are somewhat subjective based on the opinions of the author and to a lesser degree those of the interviewees. This evaluation does, however, provide T.F. EQ O.C., and TMI managenett involved in EO, a review and comparison of their EQ procedures effectiveness in implementing the EQ programs at the sites. If the recommendations are implemented, they should result in strengthening the existing procedures and program by providing better direction, reducing redundancy and unnecessary requirements and providing more specific requirements associated with work on EQ components.

If you have any questions or comments concerning this evaluation, please contact me on ext. 8614 at TMI.

. W

f. . ornicola hASystemsEngineeringManager 1

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