ML20236A989

Expanded Augmented Sys Review & Test Program (Expanded Asrtp) Evaluation of Safety Features Actuation Sys

ML20236A989
Person / Time
Site:	Rancho Seco
Issue date:	10/07/1987
From:	Croley B, Humenansky D, Moyer R SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20236A981	List: ML20236A978 ML20236A989 ML20236A992 ML20236A998 ML20236B002 ML20236B005 ML20236B010
References
NUDOCS 8710230283
Download: ML20236A989 (22)

Text

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4-~ .r Ja EXPANDED AUGMENTED SYSTEM REVIEH AND TEST PROGRAM (EXPANDED ASRTP) l EVALUATION i

0F THE  !

SAFETY FEATURES ACTUATION SYSTEM

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SUBMITTED BY: 4 w DATE: /d-O/,-87 RICHARD HQYER /

TEAM LEADER CONCURRENCE: AbMN DATE: lo4 G7

[DAVIDHUMENANSKYEXPANDEDASRTPPROGRA(M) MA CONCURRENCE: DATE: ~'

/0/7//7

/ BOB CROLEY / '

DIRECTOR, NUCLfAR TECHNICAL SERVICES

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< ; S >l p 'l TABLE OF CONTENTS Paae Number 3 i

.l .0 INTRODUCTION 3

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i 2.0- PURPOSE 4 3.0 SCOPE 5 l

4.0 OVERALL RESULTS AND CONCLUSIONS 6 l i

5.0 SPECIFIC CONCERNS 7  !

5.1 Acknowledged (Valid) Concerns 7  !

5.2 Open (Potential) Concerns 7 6.0 ATTACHMENTS 8 6.1 List of Documents Reviewed 9 6.2 Status of RIs 15 6.3 Detailed Observations - Request for Information 16 o_ __ __ _ _ o

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- EXPANDED AUGMENTED SYSTEM REVIEH AND TEST PROGRAM'

. EVALUATION OF-THE SAFETY FEATURES ACTUATION SYSTEM i

'l.0 INTRODUCTION -

..The Rancho Seco Exparded Augmented System Review and Test Program (ASRTP] Devaluation effort. involves an assessment of the:

effectiveness of the System Review and Test Program (SRTP] and.an

. analysis of.the adequacy of ongoing programs to ensure'that. systems will continue.to function properly after restart. The Expanded'

, ASRTP is a detailed system by system review of the SRTP'as

, implemented on 33 selected systems and'an in-depth review'of the engineering,' modification,' maintenance, operations, surveillance, inservice. testing, and quality programs. It also conducts a review, on a sampling basis,'of many of the numerous ongoing verification and review programs at Rancho Seco.

Six- multi-disciplined teams' composed.of knowledgeable and .

experienced personnel'are tasked with performing the. Expanded ASRTP. Each multi-disciplined team consists of dedicated personnel '

with appropriate backgrounds to evaluate the operations, maintenance, engineering, and design functional' areas.

Independence, perspective, and industry standards provided by team members with consultants, architect engineer and vendor backgrounds are joined with the specific plant knowledge of SMUD team members.

Each team performs'an. evaluation on a selected system using the same fundamental evaluation techniques employed by the NRC in the ASRTP inspection. _ System Status Reports are used as the primary source of leads for the teams. They are augmented with references to available source and design bases documents as needed. Team synergism and communication is emphasized during the process in order to enhance the evaluation. Each team prepares a report for each completed selected system evaluated. This report is for the Safety Features Actuation System.

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-- 2.0 PURPOSE

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- The objectives of the Expanded ASRTP evaluation are to (1) assess the adequacy.of-activities and systems.in' support of. restart and (2)

' evaluate the effectiveness of established programs for ensuring safety during plant operation after restart.

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-3.0: SCOPE To accomplish-the first objective, the Control Systems team evaluated the Safety Features Actuation System'to determine whether:

1. 'The system was capable"of performing the safety functions raquired by its design _ bases.

2. -Testing was adequate to demonstrate that the system would perform all of.the safety functions required;

'3. . System maintenance was. adequate'to. ensure system, operability under postulated accident conditions.

4. Operator.and. maintenance. technician training was.

adequate to ensure ~~ proper operations and maintenance.of ,

the system.

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5.- Human factors relative to the system and the system's supporting procedures were adequate'to ensure proper system operations under normal and accident conditions. .

To accomplish the second objective, the team reviewed the~ programs. -

as implemented for the system-in the following functional areas:

1. Systems Design and Change Control

2. Maintenance

3. Operations and Training

4. Surveillance and Inservice Testing

5. Quality Assurance

6. Engineering Programs )

.The team reviewed a number of documents in preparation for and

~during the Expanded ASRTP evaluation. This list of documents is  ;

found in' Attachment 6.1. '

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The primary source of leads for the team were the problems  !

identified in.the Safety Features Actuation System System Status l L Report. Various source documents such as the USAR and Technical Specifications and available design bases documents were reviewed as needed to augment the information needed by the team.

The evaluation of the Safety Features Actuation System included a review of pertinent portions of support systems that must be functional in order for the Safety Features Actuation System to meet its design objectives.

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. , 4.01 0VERALL RESULTS AND CONCLUSIONS

.The more'significant issues identified pertaining to the adequacy of I the SRTP and the effectiveness of programs to ensure continued safe {

operations after restart are sumnarized below.. The summary fccuses 1 on the weaknesses identified during the evaluation. Attachment 6.3 I provides' detailed findings by providing the Request _for Information i (RI) forms that are 'used by the. Expanded ASRTP teams to identify .

potential concerns during the evaluation. . Section 5.0 lists:the' specific concerns identified by, the teams. The numbers in' brackets after each individual summary or concern refer to the corresponding j' RIs in Attachment 6.3.

4.1 Operations 4.1.1 .The team found that Administrative Procedures are not consistently followed for completion and approval of Operations. Department Rounds Sheets. Areas of concern included abnormal readings not identified and explained; readings not taken and no explanation'or approval provided; i and Rounds Sheets not approved by the Assistant Shift '

c Supervisor. From the sample of Rounds Sheets. reviewed, it appeared that the majority of the discrepancies were i attributable to a particular. shift or crew in the periods .

reviewed. [RI 284]

4.2 Maintenance 4.2.'1 Deficiency stickers remain affixed to devices in the Control ,

Room even though'the respective Hork Requests have been, i completed. During the team walkdown of the SFAS Control "

Room panels, it was noted that several devices appeared to have unusually long deficiency periods. A review of the l respective Work Requests revealed that all were either I closed or voided. Procedure RSAP-0803 requires the craftsman to remove the deficiency sticker upon completion of the work and attach it to the Work Request, and further requires the foreman, system engineer, or field engineer,' as applicable, to verify that this has been done. The team was concerned that this practice could provide misleading /

inaccurate status of available indications to operators.

[RI 281) 4.3 Training 4.3.1 Licensed Operator training materials for the Safety Features ]

Actuation System were found to contain incorrect and ,

incomplete information. The major concerns included a lack '

of discussion of the Reactor Building Spray actuation five minute time delay and a large number of setpoint discrepancies when compared with the limits in the Technical {

Specifications. Since the Senior Reactor Operator SFAS i Training Program is based on the same materials, the same i concerns also apply to this training. [RI 278]  ;

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', s; 5.0 SPECIFIC CONCERNS-

'A list of the specific concerns the Expanded ASRTP. team believes are new concerns not previously identified for resoittion follows:

5.1 Acknowledged (Valid) Concerns-5.1.1 Compliance with the requirements of Regulatory Guide 1.97 for the position indication of containment isolation valves in the Control Room may be incomplete. [RI 255] j 5.1.2 Licensed Operator training materials contain incorrect /

incomplete information. [RI 278]

5.1.3 The procedure for removing deficiency tags / stickers after completion of Work Requests is not~always followed in the Contro1' Room. [RI 2811 5.1.4 Operations Department Rounds Sheets are not consistently completed or approved in accordance with Administrative Procedures. ~[RI 284]

5.2 Open (Potential) Concerns None I

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. 6.0 '::' ATTACHMENTS '-

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6.1 . List of Documents Reviewed i -

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.6.2. . Status of RIs i- ', 6.3 Dstalled Observations - Requests for Information l

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LIST OF DOCUMENTS REVIEHED 1

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1. SSFIs j i

A. ANO I B. Oconee l C. . Palisades 1 D. Pilgrim E.- Rancho Seco F. H.R. Robinson G. Three Mile Island 1 i

'H. Trojan I. -Turkey Point .

2. System Status Reports A. Safety Features Actuation System, Rev. 1 3.- SMUD Vendor Technical Manuals SFAS

4. Drawings Drawina # Sheet # Rev. #

M521 -

19 M521 2 15

. M522 1 33 M543 1 7 M543 4 13 M543 4 15 46820 -

5 46065 - 2 46820 -

1 46822 -

11 46064 -

8 21001 Series -

21005 Series -

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-E3621 Series -

23635 Series -

I-203 15 2 I-203 16 2 l E-203 86A 3 l

E-203 878 3 E-203 87C 5 N.23.01 47 4 N.23.01 48 3 ATTACHMENT 6.1 l - - - - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _

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.s LIST OF DOCUMENTS REVIEHED (Continued). <

r 4. Drawings (Continued) l: J

.Drawina #' Sheet # Rev. #

E-728 3 2 l E-758 6 1 J

E-758 4 1

'E-739 1 25 l i

E-739 4 0 l I-1184 1 0  !

I-1160 2 0 I-1158- 3 4 I-1185 1 0 I-1198 3 3 i E-342 58 6.  ;

E-203 48 15 E-203 48B 2 E-203 480- 2 j E-203 50 16 i E-203 50A 5 E-203 508 7 .

E-203 50C 5  !

E-203 50E 2 i E-203 50F 4 I E-203 50G 4 E-203 50H 3 1 E-203 50J 2 l E-203 50K 3  !

E-203 50L 2 i E-203 SOM 1  !

E-203 50N 2 l E-203- 50P 3 E-203 52 10 E-203 52A 2 E-203 528 1 E-203 54 16 i E-203 55 8 E-203 55A 1 L 203 56 13 E-203 85 6 E-203 85A 5 E-203 86 5 E-203 868 2 E-203 86C 1 E-203 87 9 E-203 87A 2 E-203 888 3

M-520 2 14 ATTACHMENT 6.1 1

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LIST OF DOCUMENTS REVIEHED- (Continued)

5. Updated Safety Analysis Report, Amendment 4 Addendum 1

6. Rancho Seco Technical- Specifications complete through Amendment Letter TSM-76

7. Nonconforming Reports l

A. S-4736, Rev. O B. S-5736 C. S-5371, Rev. 2 D. S-3950, Rev. 1 E. S-3966

8. Nuclear Engineering Procedures I A. NEP-5504 B. NEP-5204.44 C. NEP-5204.22 D. NEP-5104.6 E. NEP-6310 F.

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NEP-5304.8 NEP-5304.8C l!

H. NEP-5204.43 ,

9. SFAS Testing Documents (

l A. STP.1110, Rev. 0 B. STP.783, Rev. O l 1

10. Procedures A. Administrative (1) AP.2.02, Rev. 1 (2) AP.2.26, Rev. 0 (3) AP.303, Rev. 12 ,

(4) MAP-009 1

__ (5) AP.23.03 & PTCN-02 (6) AP.23.04 (7) AP.23 (Superseded)

(8) AP.8, Rev. 3 (9) AP.100 Series (Process Standards)

8. Rancho Seco Administrative Procedures  !

(1) RSAP-0803 (2) RSAP-0601, Rev. O i

ATTACHMENT 6.1 l.

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f-LIST OF DOCUMENTS REVIEWED (Continued)

10. C. Operating Procedures l >

(1) C.41, Rev. 1 (2) Annunciator Procedure (3) C.37' (4) C.34 f D. Maintenance Procedures (1) I.105 (2) I.201 (3) 1.200-E. Surveillance Procedures (1) SP.41A/B Draft I (2) SP.200.09, Rev. 4 (3) SP.200.13, Rev. 4 i (4) SP.200.11, Rev. 7 (5) SP.203.01A/B, Rev. 14/15 (6) SP.203.04A/B i (7) SP.204.01A/B (8) SP.214.03, Rev. - ,

(9) SP.605, Rev. 2 including PICN-01 and PTCN-01 & 03 3

11. Engineering Changes (ECNs, DBRs)

R-0584, Rev. O and NCR S-5375 R-0585, Rev. I and NCR S-5371 R-0595, Rev. 1 and NCR S-5378  :

A-2654, Rev. - and Rev. I k A-3651H, Rev. - and Rev. 1 i A-4786 Rev. 2 A-5415  !

12. Proposed Technical Specification Amendments No.152 and 164

13. Licensed Operator SFAS Training Program Materials A. 00 21 I 1100 B. 00 21 I 1101 i C. 00 21 I 1103 D. 00 21 I 1104 E. 0D 22 I 0900 F. 00 21 J 2100 l

ATTACHMENT 6.1

,o-l LIST OF DOCUMENTS REVIEHED (Continued)

14. Regulations, Guidelines, Standards, etc. l A. Reg. Guide 1.97 B. Title 10 CFR C. IEEE 279, 1971

15. B&W Documents A. SFAS Design Bases, drafted 07-17-87  ;

B. No. BAH 10003A, Rev. 4 C. No. BAH 1134042 dated 04-20-87

16. Operational Deficiency Reports i-A. ODR 86-459 B. ODR 86-534 C. 00R 85-138  !

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17. Maintenance / Receiving Inspection Data Reports l-i A. MIDR EM-137 B. MIDR EM-221 C. MIDR IC-134 D. RIDR QA-1748, Rev. 1

18. Work Requests A. HR 111781 B. HR 114072 C. HR 121023 D. HR 114073 E. HR 91031 F. HR 91032 G. HR 101075 H. HR 129754 I. HR 125954 <

J. HR 127967 K. _,

HR 111423

19. QA Audits A. 87-03 B, 785 C. 646 D. 734 E. 515 ATTACHMENT 6.1

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LIST OF DOCUMENTS REVIEHED (Continued). ,

20. Calculations A. 'Z-ZZZ-IDO53, Rev. O B. Z-ZZZ-IDOS6, Rev.'O '

C. Z-ZZZ-10057, Rev. O D. Z-ZZZ-IOO69, Rev. O E. Z-ZZZ-IOO75, Rev. O F. Z-ZZZ-IOO76, Rev. 0 l G. Z-ZZZ-I0077, Rev. 0 l-

21. Other l-A. LER 87-17, Rev.;l B. LER 87-21, Rev. 2 C. PM Task 05763 D. PRC Review Packages No. 164'and 165 E. Contract C9831/ Spec. M19.115A F. SMUD Vendor File No. M19.115A-5,6,13,14,8 G. EAR IC 87-101 H. Master Equipment List I. CRDR Criteria and Summary Report J. Root Cause Report - Item 2.a. Rev. 1 K. Action Item Closure Report 10a,b,c,d L. SPDS Functional Description I

ATTACUMENT 6.1

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,; ;a STATUS OF RIs ,

!' Attachment 6.2 provides RI status as of this report date. An RI is l considered closed if the Team Leader was convinced a potential concern was not valid or not significant enough to be an RI. An RI would also be L closed if. requested information was provided. All other RIs are open.

Acknowledged RIs are open RIs that have been accepted as valid by the responsible organization and have been stated as concerns in Section 5.0.

l RI NUMBER STATUS' 255 ACKNOWLEDGED 278 ACKNOWLEDGED 281 ACKNOWLEDGED 284 ACKN0HLEDGED ATTACHMENT 6.2 f(/ N OF .

- DETAILED OBSERVATIONS'- RE00EST FOR INFORMATION

. During an evaluation, all~ potential concerns are documented on Request

-for,Information sheets (RIs) that are sent to the responsible organization'to receive their input concerning the potential concern.

RIs are also used to' request information that the-EASRTP team is having difficulty obtaining.

These RIs are considered-drafts throughout the entire evaluation until they become part of the report. Responsible organizations can accept the potential concern as valid or they may disagree with the potential

1. ' concern. -If they disagree;'they can' submit information that' convinces the EASRTP team members'that the potential concern.is not. valid, or they may redirect the EASRTP-members to better focus the concern. 'RIs developed during the system evaluation comprise this section of the report.

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, a u REQUEST FOR INFORMATION (RI)

RI NO:- 255 SYSTEM CODE: SFAS ISSUE DATE: 09-23-87

SUBJECT:

POSITION INDICATION FOR CONTAINMENT ISOLATION VALVES DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR: T. TELFORD/3849 TEAM LEADER: R. H0YER/3850 POTENTIAL CONCERN /0UESTION:

Compliance with the requirements of RG 1.97 for the position indication of Containment Isolation Valves (CIVs) in the Control Room may be incomplete.

. NRC submittal for RG 1.97 and USAR Tabit 7.4-2, Parameters Monitored by SPDS, IDADS and DRMS, refers to USAR Table 5.2-2 for the identification of CIVs which requires QA Class 1 position indication with the exception.of check valves (Ref. RG 1.97) and seal closed.

manual and remote valves (Ref. RG 1.141, C-2). RG 1.141, Section C-2 states "since the CIVs are components of the containment isolation system, which is an engineered-safety-feature system, all oower coerated valves should have position indication in the control room." At least one oower coerated valve (SFV-23616, RCP seal water supply) which is listed in USAR Table 5.2-2, Reactor Building Isolation Valve Arrangement, does not have position indication displayed in the SPDS. Currently, the SPDS Functional Description does not include SFV-23616 for its position indication.

. Based on the documentation reviewed (USAR, NRC submittal and RG 1.97 file), the criteria establishing the requirements of position indication for CIVs is not adequately described.

. No consolidated list of CIVs exists for which the plant is required to have position indication displayed in the Control Room per the requirements of RG 1.97.

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REQUEST FOR INFORMATION (RI)

RI NO: 278 SYSTEM CODE: SFAS ISSUE DATE: 09-28-87

SUBJECT:

- LICENSED OPERATOR TRAINING .

DEPARTMENT: TRAINING C0ORDINATOR: F. THOMPSON /4115 TEAM LEADER: R. M0YER/3850 l

POTENTIAL CONCERN /0UESTION:  !

Licensed Operator training materials contain incorrect / incomplete  ;

-information concerning the Safety Features' Actuation System. '

.' Training materials do not address the purpose of the RB Spray j Actuation 5 minute time delay.

• SFAS Preparation Guide OD-21-I-1100.Page 11-37 Tables, and the- l corresponding section of. Trainee Handout 00-21-I-1100 contain "

inaccurate information when compared with document BAH 10003A Rev. 4,. Qualification Testing of Protection System Instrumentation.

During a spot check of the training materials, the following- l discrepancies were found:

' Parameter Training BAH 10003A  !

Listed Materials V31y.g Rev. 4 Value j

-l A. RB Press.  : 5% 0.5 %

transmitter accuracy l

B. Buffer Amp 0.6 sec 60 msec Response Time Logic Buffer

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C. 10 msec 10 msec for i Response Time Subsystem Trip, l Module Interlock Trip and Test Trip D. Contact Buffer 20 msec 40 msec energize  :

Response Time 100 msec deenergize -  :

E. Unit Control Module 20 msec 50 msec Response Time i

. Preparation Guide page 11-43 lists the BYP HPI alarm annunciating at 1975 psig. The Annunciator Procedure lists this alarm as 1 annunciating at 1850 psig.

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e REQUEST FOR INFORMATION (RI)

RI'NO: 278 (Continued)

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-. Preparation Guide page 11-62: Last paragraph states " Reactor Building Emergency Cooling 11s part of'the containment structure."

. Setpoints provided in training materials are incorrect:

Tech Specs ,

Document. Parameter Yalug Value Prep Guide LPI Actuation- <1600 psi RB Press 14 psig Page 11-47 <1600 psi RCS Press 11600 psig HPI~ Actuation >4 psig RB Press 14 psig.

<1600 psig RCS Press 21600 psig Prep Guide RB Spray Pumps & >30 psig 130 psig Pages'TN Valves Actuation 49 & 11-49 BYP HPI Alarm 1850 : 12 psig

• BYP HPI Alarm <1975 psig Prep Guide Trip Bypass <1600 psig >1600 11850 Page 11-9 Limits psig Trainee RCS Pressure 11600 psig 11600 psig Handout Actuation Page 11-6 RB Pressure 14 psig 14 psig Actuation RB Spray 130 psig 130 psig Actuation Lesson Plan RB Pressure -4 psig 14 psig Page 6 Setpoint Lesson Plan RB Pressure 30 psig 130 psig Page 7

• Annunciator Procedure lists setpoint as 1850 psig.

. Lesson Plan 00-21-I-1104 does not discuss a recovery from a SFAS actuation.

. Training materials reference the FSAR instead of the applicable USAR sections.

. The Preparation Guide section on Tech Specs does not have applicable SFAS items in italics as specified on page 11-67.

. A review of the Senior Reactor Operator SFAS training program resulted in the same concerns as identified above.

ATTACHMENT 6.3 I

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[ REQUEST FOR INFORMATION (RI) l RI NO: 281 SYSTEM CODE: GENERIC ISSUE DATE: 09-29-87 4

SUBJECT:

HORK REOUEST CLOSURE / REMOVAL OF DEFICIENCY TAGS DEPARTMENT: MAINTENANCE COORDINATOR: J. DARKE/4817 TEAM LEADER: R. M0YER/3850 i

POTENTIAL CONCERN /00ESTION: .

Procedure for removing deficiency tags / stickers after completion of Work Requests is not always followed in the Control Room, thus providing misleading / inaccurate status of available indications to operators.

1. During system walkdown of SFAS panels in the Control Room, several devices on SFAS and adjacent panels were noted as being deficient for periods of approximately nine months to two years as noted by the dates on the deficiency stickers.

2. Subsequent check of the Hork Requests involved showed all were  !

either closed or voided as noted below:

HR-101075 initiated 08-12-85; closed 10-14-85.

HR-129754 initiated 02-10-86; closed 06-25-87.

HR-125954 initiated 12-18-86; voided 07-10-87. '

HR-127967 initiated 01-15-87; closed 06-07-87.

3. Procedure RSAP-0803 requires the craftsman to remove the deficiency tag / sticker upon completion of work and attach it to the Work Request.

4. Procedure RSAP-0803 requires the foreman, system engineer, or field engineer, as applicable, to verify the deficiency tag / sticker has been removed and attached to the Work Request.

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. REQUEST FOR INFORMATION (RI)

RI NO: -284 SYSTEM CODE: GENERIC ISSUE DATE: 09-30-87

SUBJECT:

~- OPERATIONS DEPARTMENT ROUNDS SHEETS

!- DEPARTHENT: OPERATIONS COORDINATOR:- R. MACIAS/4589 l.

! - TEAM LEADER: R. M0YER/3850 1

POTENTIAL' CONCERN /0UESTION:

l l Operations Department Rounds Sheets are not consistently completed or ,

, approved in accordance with Administrative Procedures AP.23.03 and  !

l' AP.23.04.

. Turbine / Auxiliary Building Equipment Rounds Sheets for the period of September 1, 1987, to September 17, 1987, were reviewed and the following discrepancies were identified:

A. Abnormal readings were not circled in red, marked with an

' identifier or explained.as required by AP.23.03.

B. Many instances were found-where readings were nottaken and the Rounds Sheets did not contain an explanation or approval as required by AP.23.03. Round Sheets were also found with the notation that readings were waived. However, a reason

.for not taking readings was not provided.

C. Many Rounds Sheets were not approved by the Assistant Shift Supervisor as required by AP.23.04. Several Rounds Sheets were'found that had not been reviewed for two consecutive shifts. The 09-14-87 Rounds Sheet was found to be approved 4 by the Assistant Shift Supervisor even though the 20-24 ,

readings were blank.

l D. Many cases were noted where shutdown equipment was marked "Sec" (Secured) or "00S" (Out of Service) even through certain parameters should be. checked. Examples of this type

- . - . include equipment oil levels, oil temperatures, etc.

E. It was noted that approximately one half of the crews are causing nearly all the discrepancies identified. One crew was tracked an entire week (7 days) and no discrepancies were found. Another crew was tracked for a week and discrepancies were found in every set (twice/ shift) of log entries.

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f. . REQUEST FOR INFORMATION (RI)

RI NO: 284 (Continued)

. Turbine / Auxiliary Building Equipment Rounds Sheets were also reviewed for the month of January 1987 and from June 1 through

' August 31, 1987, and the same types of discrepancies identified above were noted.

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ATTACHMENT 6.3 l i

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