ML20236J484
| ML20236J484 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/1987 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236J477 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8711060138 | |
| Download: ML20236J484 (25) | |
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ORGANIZATION: BABC0CK & WILCOX LYNCHBURG, VIRGINIA t
l REPORT INSPECTION INSPECTION NO.: 99900400/87-01 DATE! 09/2 R-10/01/ A7 nN.stTr unlice.
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1 CORRESPONDENCE ADDRESS: Babcock & Wilcox Company l
Post Office Box 10935
.i Lynchburg, Virginia 24506-0935 i
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NUCLEAR INDUSTRY ACTIVITY: Design and engineering services for Babcock and I
Wilcox designed Nuclear Steam Supply Systera.
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ASSIGNED INSPECTOR:
"SEE NEXT PAGE" Date OTHERINSPECTOR(S):
E. Hagen, ORNL, Consultant
/0[30[7 APPROVE.0 BY:
r F.Stolz,NRR/p14 Date INSPECTION BASES AND SCOPE:
A.
BASES: Special inspection of the B&W Owners Group Safety and Performance Improvement Program, report BAW-1919, Rev. 5, dated July 1987.
B.
SCOPE: The purpose of this inspection was to determine if the recom-mendations developed under the Safety and Performance Improvement Program were being adequately tracked and accounted for during the review and dis-i position process.
PLANT SITE APPLICABILITY: ANO-1 (50-313); Bellefonte 1/2 (50-438/439)-
Crystal River 3 (50-302); Davis-Besse (50-346); Oconee 1/2/3(50-269/270/287);
RanchoSeco(50-312);TM1-1(50-289).
4 8711060138071102 PDR OA999 EMVD PDR 99900400
l ORGANIZATION: BABC0CK & WILC0X j
j LYNCHBURG, VIRGINIA q
REPORT INSPECTION N0.: 99900400/87-01 RESULTS:
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. ASSIGNED INSPECTORS: M
/gr h/ c.n
/0/28/S/
R. LW Ferguson, NRR/PD14 '
Dhte Der kl cm
/0/28/8 B. Si el, NRR/PD32 Da~te rs 4 M :r m w s
/dee E. Tgininson, NRR/PD4.
Date 0.
WZ[f/?
J.C/ Stone, Team Leader, NRR/VIB
_~Dite k
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ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900400/87-01 RESULTS:
PAGE 3 of 23 I.
SUMMARY
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A.
Results 1
During the period of September 28 through OctoberJ6,1987, a team of five NRC inspectors and one consultant conducted an inspection of 9
the Safety and Performance Improvement Program (SPIP) developed by the B&W Owners Group (B&WOG). The scope of the inspection was limited to the disposition of recommendations developed by the various i
comittees and task groups that participated in SPIP. The inspection I
did not include the recommendation development process within the various comittees and task groups. Also, the implementation of the recommendations issued by the B&WOG to the utilities will be included in a future inspection.
The inspection team reviewed the disposition of all recommendations contained in 13 out of 19 reports that are included as appendices to BAW-1919, "B&W Owners Group Safety and Performance Improvement Program, Revision 5, dated July 1987. The total number of recommendations generated by the committees as of September 30, 1987 was 375. Of these, 207 were accepted, entered into the Recommendation Tracking System (RTS) and issued for implementation by the utilities; 39 were returned for rework and entered into the Action Item Tracking (AIT) system;76werefoundtobeduplicatesofotherrecommendations; 32 are still awaiting Steering Committee action; and 21 were I
rejected. During this inspection the disposition of 290 recommenda-tions was reviewed. For each of the rejected recommendations, the documented basis for rejection was reviewed.
In each instance there was a documented basis but in two cases the basis did not adequately support the rejection. Discussions with representatives of the appropriate committee provided additional information. Based on the verbal information the inspection team concluded that there existed a. reasonable basis for rejection, but it had not been adequately documented.
l The system used to track and maintain the status of the recomenda-tions was reviewed. The system did not have a single location that S
provided the status of each recommendation.
In order to determine i
the status it was necessary to review all the elements of the recommendation disposition path:
(1) the task comittees reports; 1
(2) letters from the SPIP Chairman to the Steering Committee; (3) i the Steering Committee minutes that directed recommendations to the RTS for implementation, returned recommendations to the SPIP committecs for rework as documented in the AIT system, and rejected recommendations; and (4) letters back to the individual committees.
ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900400/87-01 RESULTS:
PAGE 4 of 23 An informal compilation from Steering Committee minutes of Steering Committee actions on the recommendations provided a " road map" to direct the inspectors to the applicable documentation to determine the disposition. Without that listing-the task would have been more
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difficult. Although the team was able to track all recommendations that were included in the reports that were reviewed to current disposition, the formal documentati6n process required considerable support from SPIP informal documentation and SPIP personnel.
i In addition to the documentation audit, eight SPIP personnel who had I
active roles in the development of SPIP recommendations were inter-viewed, three by telephone. None of those interviewed expressed I
any concerns about the processing of recommendations from the committees through final disposition.
On September 10, 1987, the SPIP Management Team was dissolved.
Those functions will now be handled by the Transient Response Trip ReductionCommittee(TRTrip).
B.
Areas Inspected The following reports were reviewed during the inspection. The Appendix listing refers to the appendix in BAW-1919, Revision 5:
1.
Main Feedwater Pump Trip Reduction Program - Final Report, B&W Document 47-1159449-00.
(Appendix B-4) 2.
Final Report on Re-Evaluation of ICS Design Features, B&W Document 47-1163861-00.
(Appendix C) 3.
Improvement of.ICS Response to Input Failure, S&W Document 47-1164108-00.
(Appendix 0)
- 4.
Charters Of The Independent Advisory Board And The SPIP Management Team.
(Appendix F) 5.
Results Of Operator Support Committee's Review Of Procedures Related to Loss Of ICS/NNI, B&W Document 47-1164196-00.
(Appendix G) s 6.
1154 Task Force Report-B&WOG Review Of The June 9,1985 Davis-Besse Loss Of Feedwater Transient.
(Appendix H)
T E.
ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900400/87-01 RESULTS:
PAGE 5 of 23 7.
Review Of Category "B" And "C" Evente At The B&WOG Plants 1980-1985, B&W Document 47-1165733-00.
(AppendixI)
- 8.
Reconinendation Tracking System Report - SPIP-Related Recommendations.
(Aopendixd) 9.
Safety And Performance Improvement Program Operator /Maintenace j
Personnel Interview Project Recommendations and Action Items, B&W Document 47-1165970-00.
(Appendix K) 10.
Instrument Air System Review Report, B&W Document 47-1165965-00.
(Appendix M)
- 11. Main Steam Pressure Control Review Final Report, B&W Document l
47-1167122-00.
(Appendix N)
- 12.
B&W Owners Group Safety Performance Improvement Program Prioriti-zation Process.
(Appendix 0) i
.13.
A Comparative Study Of The Sensitivity Of B&W Reactor Plants;
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Volumes I & II.
(Appendix P)
- 14. Auxiliary / Emergency Feedwater System Review Final Report, B&W Document 47-1168159-00.
(Appendix Q) 15.
ICS/NNI Evaluation Report.
(Appendix R) l l
'16.
Operator Burden Project, B&W Doct. ment 47-1168190-00.
l (Appendix S) 1
- 17.
Safety And Performance Recommendation Integration Group (SPRIG),
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B&W Document 47-1168543-00.
(Appendix T) l i
- Did not generate reconinendations.
1 II.
DETAILS A.
Background
j Early in 1986, the B&W Owners Group (B&WOG), as a result of NRC initiatives began a major effort in reassessing the design of B&W plants focusing on reducing the complexity of transients and l
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1 ORGANIZATION: BABC0CK &'WILC0X LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900400/87-01 RESULTS:
PAGE 6 of 23 frequency.of reactor trips on B&WOG member's plants. Although some work was already in progress on trip reduction, a new program was established within the existing framework of the B&WOG to emphasize improvements in safety associated with transient complexity and trip reduction. The program was named the Safety and Performance Improvement Program (SPIP). Figura 1 shows the relationship of the SPIP to the other B&WOG Comittee and Task Forces. Using resources from the B&WOG the SPIP conducted various studies and evaluations that resulted in recommendations being made to reduce the' trip frequency and transient complexity. The results of those studies are documented in "B&W Owners Group Safety and Performance Improve-
-ment Program," BAW-1919, Revision 05, July 1987. All recomenda-tions that were made by the various committees and task forces are contained in Appendicies B through T of BAW-1919.
B.
Disposition Process for Recommendations Used by B&WOG Fourteen diverse projects that generated 19 reports were used to review or study specific areas and develop recommendations for safety and performance improvements. All the recommendations developed by the individual committees or groups overseeing the various projects are included in the reports issued by the individual committee or grcups.
After the recommendations were developed, they were sent to the SPIP Chairman for review and coment. The SPIP Chairman sent all recom-mendations to the B&WOG Steering Comittee for final disposition.
The SPIP Chairman included in the transmittal to the Steering Committee coments and recommended disposition for each recommen-dation. The Steering Comittee had five options it could take:
accept and place it in the Recommendation Tracking System (RTS);
combine with other similar recommendation (s) and place it in RTS; Action Item Tracking (AIT) g group for rework and place it in the return it to the originatin system; return it to a group other than the originating group for rework and place it in the AIT system; or reject and document the reasons for the rejection in the Steering Committee minutes. Once a recommendation was accepted and placed 9
in the RTS it_was sent to the B&WOG member utilities for evaluation for possible implementation.
Figure 2 shows the path taken for the dispositioning of recommendations.
.Since the October 28-29, 1986 Steering Comittee meeting, a letter has been sent to the originating group's chairman providing the disposition of each recommendation by the Steering Comittee. This provided the originating group an opportunity to appeal the decision by the Steering Comittee. Before that time the originating group's
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~ ORGANIZATION: BABC0CK & WILCOX LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900400/87-01 RESUL1S:
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chairman was not notified by separate letter. However, copies of the Steering Comittee minutes and copies of the periodic updates of the AIT and RTS were provided, and are'still being provided, to the. chairmen of the various groups.
This procedure was used for all recommendations except those developed by the ad hoc committees on Instrument Air and Emergency Feedwater. These recommendations were submitted by the ad' hoc committee chairman directly to the Steering Committee for~ disposition 4
because these functions had not been included in the B&WOG standing committees. Following submission of the recommendations the ad hoc committees were dissolved.
Two other groups were formed by the B&WOG Executive Comittee to round out the review and disposition process, the Independent Advisory
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Board '(IAB) and the Safety anq Performance Recommendation Integration Group (SPRIG). The IAB was established in June, 1986 to overview the reassessment effort from an objective perspective. The IAB members were: Mr. W. H. Layman, EPRI, Chairman; Professor N. E. Todreas, MIT; Mr. R. S. Brodsky, BETA Corp.; and Mr. S. Levy, Levy Associates.
Seven' meetings during a period of one year were held, by the IAB to review the SPIP. Among other things, their assessmer,t concluded that the SPIP had been effective in identifying areas that needed improve-ment and they generally concurred with the process and basis employed
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in-prioritizing recommendations.
In. June, 1987, following the j
presentation of their final assessment to the B&WOG Executive Comittee, the IAB was dissolved.
SPRIG was formed in March,1987 for the purpose of integrating and prioritizing the recommendations generated by the various comittees.
and groups. The SPRIG met three times over a period of two months and produced a report containing 20 recommendations on prioritizing of the recommendations developed by the SPIP. Following issuance of the report, SPRIG was dissolved.
In addition to the documentation, the inspection team interviewed eight SPIP personnel who had active roles in the development of k
the SPIP recommendations. The purpose of the interviews was to determine if any of the SPIP participants had any concerns over the management of recommendations. generated in the comittee reports through final disposition by the Steering Committee. The inspection team discussed the following subjects in its interviews with the li:1ted representatives of the selected comittees:
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ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900400/87-01 RESULTS:
PAGE 8 of 23 1.
Feedback process.
2.
Appeal of rejected recomendationc.
3.
General satisfaction / dissatisfaction of the disposition process t
(i.e., recommendations being " watered down" or rejected without basis).
The following individuals were interviewed:
BobWilliamson,JohnConcklin,andEricSwansonfromth[ Availability Comittee (Main Steam Pressure Control).
Eric Swanson from the ad hoc committee on Instrument Air.
Stuart Rose of Duke Power (by telephone) from the task group that oversaw the comparative study of the sensitivity of B&W Reactor Plants.
Larry Reed of Duke Power (by telephone) from the ad hoc comittee on Emergency.Feedwater.
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Ron Dorman from the Instrument and Control comittee (ICS/NNI recom-mendations).
R.SkillmanofGPUNuclear(bytelephone),ChairmanoftheSPIP.
Feedback to the standing committees has taken place since October, 1986. This mechanism appears to be satisfactory for informing them of the actions taken on their recommendations.
In the case of ad hoc committees, these comittees were not formally notified of the Steering Committee actions. However, they knew what actions had been taken and were able to provide additional details of the rationale for rejection, except for the Instrument Air.
In the case of the Instrument Air report, the chairman could not provide any additional detail. This lack of providing feedback to the ad hoc committees is viewed as a weakness by the inspection team.
All persons contacted felt that if they disagreed with the action taken by the Steering Comittee they could appeal the decision. The Chairman of the I&C comittee stated that they had successfully appealed a Steering Comittee decision. The Chairman of the SPIP also l
stated that if committee chairmen disagreed with the coments made in the transmittal letter to the Steering Comittee they would contact him and he would convey their concern to the Steering Committee.
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u ORGANIZATION: BABC0CK & WILCOX LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900400/87-01 RESULTS:
PAGE 9 uf 23 All contacted persons stated that they were satisfied with the j
process usad for the disposition of the recommendations.
- Further, they knew of no one on the comittees who were dissatisfied with the dispositions of the recommendations.
The inspection team feels the process used for dispositioning the
'1 recommendations was appropriate with adequate feedback to the originators of the action taken by the Steering Comittee, with the exception of the weakness in not fonnally providing the ad hoc committees the results of the Steering Comittee actions.
C.
Areas Reviewed 1.
Main Feedwater System - NFW The recommendations for the main feedwater system as set forth in " Main Feedwater Pump Trip Reduction Prograr Final Report,"
B&W Document No. 47-1159449-00, undated, and included as Appendix B-4, BAW-1919, were reviewed to determine their disposition. This report contained five recommendations. All five were accepted by the Steering Committee and placed in the RTS.
Thirty recommendations came from the report "B&W Owners Group Review of the June 9,1985 Davis Besse Loss of Feedwater Transient," B&W Owners Group 1154 Task rorce, August 1986.
Tnese are reviewed in Section II.C.2 of this report.
Five recommendations came from operating experience reports.
Two recommendations were redundant to existing recommendations J
in the RTS. The other three were placed in the RTS by the Steering Comittee.
Based on this review, the inspection team has concluded that 1
the recommendations concerning main feedwater are accurately
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reflected as final recommendations in the RTS and that the process by which this was done is adequately documented.
2.
Review of June 9, 1985, Davis Besse Loss of Feedwater Event (1154 Task Force).
The recommendations resulting from the B&W Owners Group 1154 Task Force review of the June 9, 1985 Davis Besse loss of
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,s feedwater event as set forth in Appendix H of BAW-1919 Safety and Performance Improvement Program, Revision 5 dated July, 1987, have been reviewed to determine their disposition.
'l The 1154 Task Force documented 64 recommendations. Of these, 56 were accepted by the Steering Committee and entered unchanged into the RTS. Five of the recommendations were
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considered by the Steering Committee to be duplicates of l
recommendations already in the RTS -The inspector agrees with 1
this disposition'of these five recommendations. Three l
additional recommendations were retained for further review, I
one by the Steering Committee and two by the I&C Committee.-
No reconnendations were rejected.
The documents used in this review included: BAW-1919, Appendix H. Minutes of Steering Committee Meeting - 9/3-4/86, BAW-1919, 3
Appendix J, and Action Item Tracking Report.
I Based on the above review, the inspection team has concluded that-the recommendations of the 1154 Task Force are accurately reflected as final recommendations in the RTS and that the process by which this was done is adequately documented.
3.
Review of Category "B" and Category "C" Events at B&WOG Plants (1980-1985)
The recommendations resulting from the B&W Owners Group Transient Assessment Committee study of Category "B" and "C" events that occurred at B&WOG plants between 1980 and 1985 as set forth in Appendix I of BAW-1919, Safety and Performance Program, Revision l
5, dated July 1, 1987 have been reviewed to determine their disposition.
The documents used in this review included: BAW-1919, Appendix I, Action Item Tracking system report, July 1987, Recommendation Tracking System July 1987, Informal Listing of Steering Committee actions on recommendations, and Letter from 1
R. W. Ganthner to B&WOG Steering Comittee, October 15, 1987.
The Transient Assessment (TA) Committee documented 31 recomen-dations.
Four of the recommendations were identified by the l
TA Committee as duplicates leaving 27 recommendations to be dispositioned by the Steering Comittee. Of these 10 were accepted by the Steering Committee and entered into the RTS.
Nine recommendations were sent back to the committee for further 1
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1 ORGANIZATION: BABC0CK & WILCOX LYNCHBURG, VIRGINIA REPORT' INSPECTION NO.: 99900400/87-01 RESULTS:
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I action and entered into the AIT system. The Steering Committee
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identified three recommendations that were duplicates of
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recommendations already in RTS. One recommendation was combined with another recommendation and entered into the RTS. One recommendation was addressed by the 1154 Task Force. Three c
recommendations were rejected.
1 The NRC inspection team concludes that all the recommendations contained in the review of Category "B" and Category "C" event
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report have been accounted for and that no substantive differences exist between the recommendations contained in the report and those that have been approved by the Steering l
Committee and incorporated into the Recommendation Tracking
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System or those that are in the Action Tracking System. For i
the recommendations rejected an adequate bases for rejection i
has been provided and for those recommendations that were 1
identified as duplicates or combined with other recommendations j
no substantive change in scope or content of the recommendations 1
was observed.
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4.
Operator / Maintenance Personnel Interviews j
i The recommendations resulting from the B&W Owners Group,
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Operator Support Comittee interview of operator / maintenance a
personnel as set forth in Appendix K of BAW-1919, Safety and 1
Performance Improvement Program, Revision 5, dated July, 1987, have been reviewed to determine their disposition.
The Operator Support Comittee documented 11 recommendations.
Of these, 9 were accepted by the Steering Comittee and entered i
unchanged into the RTS. The remaining 2 recoianendations were retained for further review by the Operator Support Committee.
No recommendations were rejected.
J The documents used in this review included: BAW-1919, Appendix K, Minutes of Steering Comittee meeting 1/14-15/87,BAW-1919 Appendix J & Action item Tracking Report.
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Based on the above review, the inspection team has concluded that the recommendations of the Operator Support Comittee are j
accurately reflected as final recommendations in the RTS and that the process by which this is done is adequately documented.
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ORGANIZATION: BABC0CK & WILCOX LYNCHBURG, VIRGINIA REPORT' INSPECTION N0.: 99900400/87-01 RESULTS:
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5.'
Instrument Air System Review Report The recommendations resulting from the ad hoc group review of
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instrument air systems as set forth in Appendix M of BAW-1919, Safety and Performance. Improvement Program, Revision 5, dated j
July,1987, have'been reviewed to determine their disposition.
The ad hoc group documented 60 recommendations. The Steering' s
Committee determined that there was redundancy in 30'of the 60 recommendations such that these 30 could be placed in 8 groups of 2 to 6 recommendations in each group. The recommendations in each group were sumarized, and the summary entered into the RTS.
The inspection team has reviewed the process of consolidating q
recommendations and have concluded that the subject of each individual recommendation in the 8 groups is accurately reflected in the single RTS entry for each group respectively. Of the remaining 30 recommendations, 27 were entered into the RTS. The Steering Comittee determined that one recommendation was a duplicate of a recommendation already in the RTS. The inspection team agrees with the disposition of this one recommendation.
The documents used in this review included: BAW-1919, Appendix M, minutes of Steering Comittee meeting January 14-15, 1987, BAW-1919, Appendix J. SPIP recommendations rejected by the Steering Committee, & Action Item Tracking Report.
The Steering Comittee rejected recommendations 5.2.7 and 5.2.9.
The inspector determined that the basis for rejection has not been adequately documented by the Steering Comittee. During verbal discussions with B&W Owners Group representatives, a valid basis was presented for rejection of these recommendations, but that basis was not included in the documentation reviewed by the inspector. The Steering Committee should reconsider these rejected recommendations with a view towards providing better documentation of the rationale for the rejection. The ad hoc group should consider reviewing the basis for rejection.
Based on the above review, the inspection team has concluded that with the exception of 2.5.7 and 2.5.9, all of the ad hoc group recommendations in Appendix M of BAW-1919, are accurately reflected in the RTS. The inspection team further concludes that the process for recommendation disposition is adequately documented except for the basis for the rejected recommendations noted above.
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6.
Main Steam Pressure Control Review I
The recommendations resulting from the B&W Owners Group Availability Committee review of main steam pressure control as set forth in Appendix N of BAW-1919 Safety and Performance c
Improvement Program, Revision 5, dated July, 1987, have been reviewed to determine their disposition.-
l The Availability Comittee documented nine recommendations, two of which have a total of five sub-parts. The Steering Comittee determined that four complete recommendations and one recommenda-tion sub-part were duplicates of recommendations already in the i
RTS. The inspection team agrees with the disposition of these recommendations. Three complete recommendations and one recommendation sub-part were er,tered unchanged into the RTS.
One complete recommendation (consisting of three sub-parts) was rejected by the Steering Committee. The inspection team agrees with the rationale presented for this rejection.
The documents used in this review included: BAW-1919, Appendix N, minutes of Steering Comittee meeting 1/14-15/87,BAW-1919 Appendix J. Ltr. - R. P. W1 chert to G. R. Skillman dated November 25,1986(w/ attachments). Ltr. - G. R. Skillman to Steering Comittee dated December 18, 1986, & SPIP recommenda-tions rejected by the Steering Comittee.
Based on the above review, the inspection team has concluded that the recommendations of the Availability Comittee are accurately reflected as final recommendations in Appendix J of BAW-1919, or that an adequate basis for not including recommendations has been ptovided.
The process by which the recommendations of the Availability Committee became final recommendations is not, however, well documented. The recommendations set forth in Appendix N do not correspond directly to the recommendations forwarded from the Availability Committee to the Steering Comittee (Ltr. - Wichert to Skillman November 25,1986). Therefore, in order to track the Appendix N recommendations, a reviewer must review the subject matter in the disposition of Availability Comittee recommendations by the Steering Committee to determine if the Appendix N recommendations are covered. At best, this is a subjective review. The inspection team has conducted such a review and concluded, to the extent possible, that Appendix N recommendations are covered by final recommendations in the RTS.
A ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900400/87-01 RESULTS:
PAGE 14 of 23 The transition from Appendix N wording of recommend'ations to what was finally submitted to the Steering Committee via the SPIP Committee Chairman is not documented. Handling of recommenda-tions from the SPIP Committee Chairman through the Steering Committee and into the RTS is however adequately documented..
j 7.
Audit of Independent Sensitivity Study Recommendations These recommendations were prepared by MPR Associates Inc.,
Washington, D.C. under contract to the B&WOG with oversight management conducted by peer review personnel assigned from the B&WOG. The results of the study are contained in Appendix P to BAW-1919, Revision 5 - Volume II, Conclusions, Recommendations and Discussion of Results (Section B: Recommendations).
Five recommendation areas noted herein, containing specific recommendations within each area, were sent without comment to the Steering Committee by the SPIP Chairman, Recommendation 1 - Modifications to the Integrated Control System (ICS) to reduce the probability of the complex transients generated by failures in the ICS and particularly to reduce the probability of feedwater upsets generated by such failures.
There are 12 specific recommendations within this area plus an endorsement of four other measures already recommended by the B&WOG Instrument and Control (IC) Committee for utility action at the time the sensitivity study was in progress.
The Steering Committee referred Recommendation No.1 area to the I&C Connittee as an action item described in AIT No. T-039.
The 180 Committee's ICS/NNI Evaluation Final Report Recommendations in Section VII of Appendix R to BAW-1919, Revision 5, incorporated the Sensitivity Study recommendations along with those derived from three other distinct sources -
e the ICS/NNI Evaluation Matrix / Problems List; Failure Modes and Effects Analyses; and studies performed by other committees.
The I&C Committee report however did not separately identify the sources of the listed recommendations. Therefore, there was no way to readily verify the disposition of the Sensitivity Study recommendations except by sifting through the I&C report and comparing the recommendations listed to those from the Sensitivity Study. Based on this type of screening six l
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Sensitivity Study recommendations were not listed in Appendix R, (e(1), e(2), and f(1) through f(4)). The I&C Comittee currently has a draft report under review which will address its specific responses to the Sensitivity Study recommendations.
An audit of the draft report indicates that the six missing j
recommendations noted will be addressed.
AlthoughtheB&WOGindicatesthatrecommendationse(1)ande(2) are included in the RTS as items TR-104-ICS and TR-153-IAS respectively, it is not clear'that the details described in these recommendations are included within the broad scope of l
TR-104 and TR-153. The recommendations f(1) through f(4) recomend that any reconfiguration of ICS retain some of the key features described in f(1) through f(4), which are already in the existing ICS for B&W plants. This point needs to be documented'to close out the issues.
In any event, the burden I
of clearly (documenting the disposition of recommendations e(1).
e(2) and f 1) through f(4) will be placed on the forthcoming 1
I&C report on the independent Sensitivity Study.
The six remaining recommendations from the Sensitivity Study (listed within Ib, le and Id) were included in Appendix R.
These are categorized as Level 11 recommendations in Appendix R, a classification which means that major modifications are needed to existing equipment or extensive evaluation is required. The merits of implementing the Level II recommendations are still under consideration by the I&C committee as discussed in Section VII C of Appendix R.
Recommendation 2 - Enhancement of Main Feedwater (MFW) relia-bility so that, if two feed pumps are in operation, the single failure of an active element will not lead to a total loss of feedwater, r
There are 16 specific recommendations made for this area listed within 2a through 2d described in Section 8 of Appendix P.
This recommendation area was referred by the Steering Comittee to the SPIP Management Team as an action item in AIT No. T-040.
The action was completed by SPIP. All recommendations were found to be duplicates of other recommendations entered into the RTS, except two, 2b(7) and 2c(1) (Letters SPIP Chairnan to Steering Committee dated 5/27/87 and 6/17/87). The two recommen-
,l dations were subsequently combined and entered into the RTS as 1
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been updated to reflect the TR-179 entry i,the AIT report had'not TR-179..At the time of this inspection, nto the RTS. TR-l?9 covers MFW and condensate reliability improvements and prdienting single failures which is sufficiently broad to cover the issues raisedin2b(7)and2c(1).
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Recommendation 3 - Reducing susceptibility to overcooling.by' emergency feedwater.
There are specific flow control alternatives-described:. specific flow control changes' listed in recommendation'Sa; or recommenda-h tion 3b which proposed an analysis in Tieu of the 3a recomen-dation.
s Recommendation 3a was entered into the PTS as TR-155; an' o recommendation '3b was not justified since 3a was adopted.
a Recommendation 4 - Elimination of the a' anticipatory reactor trip #
(ART) on turbine trip to reduce the possibility of. overcooling.
/'l Subsets of this recommendation deal with considerations of enhancement of capab111ty)to withstand turWne trips and load rejections, i.e., 2e 4c(1, increasing hig Wreactor pressure i
2 trips'ettingto2400 psi,and4c(2),increasingflowcapacity and swiftness of control valve response for pressurizer spray.
'This recommendation was considered by the Steering Committee to
{
be a duplicate of RTS item TR-030 which recomended raising the ART or turbine trip arming point from its current rating of 20 e
7 percent power to a higher level (Section 5 of BAW-1893). How-r ever,1R-030 does not address disposition of the considerations' raised in 4c(1) and 4c(2). This issue is to be addressed in the j
forthcoming Transient Assessment Comittee report per discussions with B&WOG representatives.
Recommendation 5 - Enhancement of steam flow control follow'ing '
)
reactor trips T6ptional recommendation) is offered primarily'as j
I a means to reduce challenges to and hence maintenance of, steam safety valves.
There are three specific recommendations described in Sa, anL 5b.'
The Steering Committee referred this recommendation to the Valve Task Force as action item T-041. The action is still pending.
)
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ORGANIZATION BABC0CK & WILCOX LYNCH 8URG, VIRGINIA
.t
.; REPORT '
INSPECTION
'j'NO.: 99900100/87-01'
.RESULTS:
PAGE 17 of 23 1
1 l,
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8.
l The recommendations for the emergency feedwater (EFW) system as 7
set forth in " Auxiliary / Emergency Feedwater System Review Final a
i O :
l t
Report", B&W Document Number 4?-1168159-00 May 1987, and i
included.as Appendix Q of BAW-1919 were reviewed to determine 9
their disposition. This report contains fifteen recommendations:
ten of these were accepted; two were rejected d one was revised 3 -L by the Steer;ing' Comittee and two require further action by the 7
yJ+
Steerips ta pittee.
- 4. ~
i Recomhenpation 2.1.7 concerned an R&D4rogram to determine if l
,4 i
more reliable controls are available and an information exchange program to provide each owner with the results of future changes.
- g The recommendation regarding the R&D program was rejected by the j
,, Steering Comittee as not necessary because the operating history
. "of present controls has been good and considering the work done pveviously by the 1154 Task Force, Arkans'as Fower & Light. and
' Toledo Edison. The recommendation regarding information exchange j
was rejected as unnecessary, because of the ongoing information f
l M., exchange program that currently exists within the B&WOG.
r y
/I j.
6 i s
j Recommendation 2.2.5 concerned training of plant personnel 7
specifically in areas where repetitive problems have occurred.
l This recommendation was rejected by the Steering Comittee,
)
because other training initiatives had already addressed this ConCQVD.
Recommendation 2.1.6 concerned modification to the EFW Control 4
System to provide continuous smooth flow control. The Steering.
i Comittee revised the recommendation in an attempt tto clarify I
that the EFW Control System should control the flow such that it is always appropriate for existing conditionsf and that on-off or single valve continuous flows are not acceptable.
The revised recommendation (TR-162-EFW) requires additional
- clarification, to clearly state the desired objective.
4 Recommendation 2.1".1' and 2.2.1, are still under review by the Steering Comittee: T-046 and T-047 are related to how exchange of information should be made for these recommendation, l
9.
ICpfjylEtaluation y
The B&W Owners Group I&C Comittee has completed an investi-gation into the design and operation of the ICS/NNI at B&WOG
]
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<4 ORGANIZATION: BABC0CK & WILC0X-
)
LYNCHCMG, VIRGINIA
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,'3 INSPECTION REPORT
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N0.: 999004bO/87-01,
,j M10LTS:
PAGE 18 of 23 A
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plant 3 741s investigation was intended to identify problems and W icate solutions and improvements which which may reduce 1
l f; - ',
plant % trips and/or reduc'etthe severity of plant transients j
f ', h~ /[.
l associated with the ICS/NN1'. Appendix R of BAW-1919 Rev.5 is 1
(
the repository for all recuaendations formalized to date that
/
pertain to ICS/NNI. As such 11 also includes these recommen-i dations developed ir, AppeMSces C,D, and G to BAW-1919.
% M' Recommendations 4n 'ASet. dices-C,D, and G are covered before
, s those in AppendoQ s
>c s o, s3,
- I.
h Appendix C, " Final Mport[on Ne-Evaluation of ICS Design j }'
/
i Features", B&WOG Traisiant. Assessment Committee, B&W Report
[
jO 47-:,163861, June 196d was i, pre-SPIP project. However, the d
. \\results of Ae 'itLd,rJwere reviewed by the SPIP. This task
-)
evaluated cratafn design features of the ICS design via plant 3
operating experience.
From this study changes were developed 7
I to those features wxich could reduce certain reactor trips.
s3s There were four spedfic and six ancillary concerns identified.
I jd 4
/
These ten concerns were consolidated into four general recommend-5
'ations. The Steer %g Committee approved and entered the four
'(sf general reconr"endations into the RTS.
4,
'N Appendix 0, "Irriovement of ICS Response to Input Failures,"
]
B&WOG Transient Asnessment Committee, B&W Report 47-1164108,
- ne 1986 was a pre-SPIP project. However the results of the
@tudy was revit:4ed byithe SPIP. This document describes and i
sunarizes thc4engtne sing analysic performed in the evalu-4' iations of sJpeted W4 inputs and presents the conclusions 7
e s drawn from tMs arMyth. Seven recommendations were developed j
and later approved by@e Steering Comittee. Two recommend-p'g
,s
/ d,,
aticns have since top (superseded. The disposition of these s.N '
% recommendations wg fdud to be adequate.
i h
[
nppendix G,"
Results of Operator Support Committee's Review of t
Procedures Related td Lbss of ICS/NNI," B&WOG Operator Support yl
,t
>6 3 c l' s Cormitte6;'B&W Report 47-1164196-00, May 1986 documents the
/
results of'a review :nf plant specific emergency operating f
procedures, B&WOG emergency operating procedures, technical bh M / document ard operator training.
Its purpose was to evtivate the adequacy of those documents for handling a
, traidient involving a loss ICS and/or NNI power. The five reconrnendations made were to strengthen weak areas in the
'9 episting procedures reviewed. These recommendations did not
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p through the Steering Committee because they were developed 2'
befre the formation of the SPIP team. The inspection team i
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4 ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA
'i REPORT INSPECTION-N0.: 99900400/87-01 RESULTS:
PAGE 19 of 23 was able to identify that the intent of the recommendations was included'in recommendations that are in the RTS. However l
Appendi:: G was not referenced as a' source document.
Consideration should be given to including Appendix G as a source document in the appropriate RTS. recommendation.
d Appendix R, "ICS/NNI Evaluation Final Report" contains the recommendations developed by the I&C Committee for improvement in the ICS/NNI system. The recommendations are categorized as Level 1,. Level II or Level III.
i Level I recommendations were those that were deemed to provide immediate improvements to the operation, availability and reliability of the ICS/NNI. The I&C Comittee submitted 59 Level I recommendation to the Steering Committee. 28 were approved by the Steering Committee and placed in the RTS for implementation. The other 31 are awaiting Steering Committee action.
Level II recommendations potentially involved major modific-
.ations to the existing equipment. Their disposition is to be
. decided following evaluation of their operational benefits and practicality with respect to both economics and implementation.
Ten recommendations'are categorized as Level II, including the recommendation from the Sensitivity Study (Appendix P) that i
pertain to the ICS/NNI system. These have been entered in the AIT system and returned to the 18C Committee for further k
consideration. A report is in preparation by the I&C Comittee that will elaborate on these Level II recommendations.
Level III consists of those recommendations concerned with replacement of the existing ICS/NNI system with a new system based on modern digital control technology. There are six recommendations listed. The B&WOG plan to pursue, as a follow-on activity to the ICS/NNI evaluation, the development of an Advanced Control System concept that will incorporate these six recommendations.
Implementation will be in keeping 1
with the state-of-the-art technology.
The NRC inspection team concludes that there is suitable j
accountability and traceability for all ICS/NNI recommendations submitted.by the I&C Comittee to the Steering Comittee and from the Steering Committee through to the final disposition of the recommendations for system improvements. However, a majority of the ICS/NNI recommendations are still in a
3 a
4
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p l0 ORGANIZATION:- BABC0CK & WILC0X i
-LYNCHBURG, VIRGINIA
{
REPORT INSPECTION N0.: 99900400/87-01 RESULTS:
PAGE.20 of 23 j
processing stage within the 18C Comittee. Of those sent to
-l the Steering Comittee only 47% of them have been approved and
'l placed into the Recommendation Tracking System. The reminder are awaiting Steering Comittee action. The Steering Comittee j
has not rejected any.ICS/NNI recommendations. The issue of categorizing recommendations as Level I, II, or III will be-included in the technical review of the ICS/NNI report.
- 10. Operator Burden Review The recommendations resulting from the B&W Owner Group Operator Support Committee study of operator burden as set forth in j
Appendix S of BAW-1919, Safety and Performance Improvement:
l Program, Rev. 5, dated July 1,1987, have been reviewed to i
determine their disposition. The document used in this review included: BAW-1919, Appendix S, Action Item Tracking Report, i
July 1987, Recommendation Tracking System Report, July,1987, j
Informal listing of Steering Committee actions on recommendation and letter from R.W. Ganthner to B&WOG Steering Comittee, April 23, 1987.
i The Operator Support Comittee documented 13 recommendations.
Of these six were accepted by the Steering Committee and entered into the'RTS. Five recommendations were sent back to the committee for further action and entered into the AIT system.
Two recommendations were not sent to the Steering Comittee.
One recommendation related to managing of backlog work and its impact on operator burden was not released because the Operator Support Committee made a longer term commitment to address this issue and develop specific recommendations. The other recommendation is related to the implementation of routine ~
forums for information exchanges such as Owners Group meetings.
Because this recommendation is redundant to the charter of the C&WOG, the committee decided not to release it to the SPIP Chairman.
Included in Appendix S, the Operator Burden Report, are the results of the review of the eight SPIP project reports, contained in the Appendices to BAW-1919, prepared from an
]
operator burden perspective. Section 2.2.4 contains general comments developed during the review of these reports and Tables 1, 2 and 3 list the recommendations from the eight reports to which the general comments apply.
In addition l-Appendix B of Operator Burden Project Report provides specific comments to specific recommendations made in each of the eight i
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L' ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA a.:
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' REPORT INSPECTION NO.: 99900400/87-.01 RESULTS:
PAGE 21 of 23 k
SPIP' project reports. These have been classified a' comments s
by the Operator Support Comittee, because they were rieemed
-not significant enough to be considered recommendations.
Section 4.5.3 of the Safety and Performance Recommendation g
Integration Group (SPRIG) report (Appendix T of BAW-1919, i
Rev. 5) on operator burden states that the Operator Burden Report should be reviewed by each utility prior to implementing i
the identified SPIP recommendations and that SPRIG considers this report very useful from the stand point of reducing g
operator action and burden. However, the recommendations contained in the RTS and identified in the Operator Burden report as important from an operator standpoint do not reference the Operator Burden report for review before implementation by 1
the utilities.
j The NRC inspection team concludes that all the recommendations j
contained in the Operator Burden Project Report have been a
accounted for and that there are no substantive differences i
bei! ween the recommendations contained in the report and those that have been approved by the Steering Comittee and incorporated into the Recommendation Tracking System or those that are in the Action Item Tracking System.
It is the opinion of the inspection team that the general and specific comments related to operator burden for the applicable recommendations i
identified in the Operator Burden report are not adequately referenced by the applicable recommendations so there is no reasonable assurance that operator burden will be addressed at the appropriate time during implementation of the recommen-dations by the utilities. During the inspection the B&WOG J
representatives acknowledged this as a potential problem and stated that corrective action is under consideration.
- 11. Owner Group Program There are four programs under the B&WOG (see Figure 1), the Economic Benefit Program, the Regulatory Commitment Program, the Availability Improvement Program and the SPIP. Generally the program under which a recommendation is placed is determined by the Steering Comittee at the time the recommendation is submitted to the Steering Committee for approval by the committees and task forces. Although the purpose of this inspection was to review the SPIP recommendations, the inspection team also reviewed the other three programs to detennine if any of the recommendations evolving from these programs had trip u__-
n 3
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l ORGANIZATION: BABC0CK & WILC0X LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900400/87-01 RESULTS:
P. AGE 22 of 23 reduction benefits that should be included in the SPIP. The Recommendation Tracking System Report (July,1987) and Action Item Tracking System Report (July,1987) were utilized in this
~
review.
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a.
Av_ailability Improvement Program l
There were 31 valid recommendations approved under this i
program and four potential recommendations in the Action Item Tracking System. Of the 35 recommendations and i
pntential recommendations only two were determined to have I
direct trip reduction benefits. Recommendation AV-019-ADM, 4
which is in the area of plant administration, recommended i
factoring the following into current procedures and practices, personnel training and administrative controls:
i 1
the review of existing equipment and panel labels for consistency with procedures, providing additional labeling of critical switches and valves on panels and equipment, applying enhancement principles used in control room l
design reviews, and providing warning signs in area l
containing equipment sensitive to normal operation.
Recommendation AV-020-ADM which is also in the area of plant administration recommends factoring the following I
into current prt,cedures and practices, personnel training
]
and administrative controls:
the establishment of a feed a
back mechanism similar to that required for reviewing
]
plant operating events to identify training and procedural deficiencies, recommend changes and then provide actual training.
These two. recommendations were approved in May 1986, at a time when the SPIP was in its initial stages of development.
At that time it was decided to retain these recommendations within the Availability Program where they had originated.
The B&WOG has stated that the recommendations from all programs are approved by the Steering Committee, entered into the RTS and receive the same attention from the i
utilities with regard to evaluation and implementation.
l This was verified by the inspection team review of the implementation status for all the recommendations contained in the RTS.
It is the inspection team's opinion that retaining these two trip reduction recommendations under the Availability j
i Program is acceptable.
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ORGANIZATION: BABC0CK & WILC0x LYNCHBURG VIRGINIA j
1 REPORT INSPECTION NO.: 99900400/87-01 RESULTS:
PAGE 23 of 23 l
b.
Economic Benefits Program J
l There has been one Economic Benefit recommendation approved j
under this program and four potential recommendations in H
the Action Item Tracking system currently under consider-I ation. Neither this recommendation nor the potential recommendations appear to have trip reduction benefits, c.
Safety and Regulatory Commitment Program
'f There has been one Safety and Regulatory Comitment 'recom-
]
mendation approved under this program and four potential 3
recommendations in the Action Item Tracking System currently j
under consideration. None of these recommendations or potential recommendations appear to have trip reduction i
benefits.
J In conclusion, the inspection team has determined that only two of the recommendations under these programs have any trip reduction benefits and it is acceptable for these two recommendations to remain under the existing program.
- 12. Personnel Contacted j
j
- R. Black B&W
- R.
Rogers Duke Power Co.
1 l
J. Bohart B&W E. Swanson' B&W B. Brooks B&W
)
R. Dorman B&W
- 0. Downtain B&W
- R. Ganthner B&W
)
J. Kelly B&W
- D. Mars B&W
- A. Mercado B&W
- Attended exit meeting.
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