ML20236J692

Expanded Augmented Sys Review & Test Program Methodology Guidelines

ML20236J692
Person / Time
Site:	Rancho Seco
Issue date:	07/15/1987
From:	Croley R, Humenansky D, Knight S SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20236J688	List: ML20236J685 ML20236J692 ML20236J707
References
PROC-870715, NUDOCS 8708060253
Download: ML20236J692 (21)

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- av . ammweaM a m m w:$m ,~www. <bb EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGRAM EVALUATION (EASRTP):

h.. METHODOLOGY GUIDELINES PURPOSE AND SCOPE THE PURPOSE OF THIS DOCUMENT IS TO PROVIDE AN OVERVIEW OF THE EASRTP PROCESS AND TO PROVIDE TEAM MEMBERS HITH GUIDELINES THAT WILL BE USEFUL IN THE CONDUCT OF THE EASRTP EVALUATIONS.

THIS PROCESS IS MODELED AFTER THE NRC AUGMENTED SYSTEM REVIEN AND TEST .

PROGRAM (ASRTP), THE NRC PERFORMANCE APPRAISAL TEAM AND THE SAFETY SYSTEM FUNCTIONAL INSPECTION (SSFI). TEAM TECHNIQUES. THE SYNERGY DEVELOPED HITHIN EACH TEAM FROM CREATIVE QUESTIONING, OPEN CO MjNICATION, PERSISTENT FOLLOW-UP, AND MUTUAL RESPECT PLAYS A VITAL ROLE IN THE EVALUATION PROCESS. EACH TEAM HILL DEVELOP LEADS REQUIRING INDIVIDUAL AND TEAM EFFORT TO INVESTIGATE. TEAM LEADERS HILL PRIORITIZE LEADS AND DIRECT THE TEAM TO PURSUE THOSE LEADS THAT APPEAR TO BE MOST SIGNIFICANT.

H0HEVER,-TEAM MEMBERS HAVE THE FLEXIBILITY TO FOLLOW LEADS AS.THEY DEVELOP AND HILL NOT BE CONSTRAINED BY A MANDATORY SET OF. REQUIREMENTS. THEREFORE, THERE IS ONLY AN EVALUATION PLAN. THERE ARE NOT ANY OTHER EASRTP PROCEDURES OR REQUIRED CHECKLISTS BECAUSE THEY TEND TO DETRACT FROM THE PROCESS BY REQUIRING TEAM MEMBERS TO PERFORM ACTIONS THAT MAY NOT CONTRIBUTE TO THE TEAM'S EFFECTIVENESS. INSTEAD, GUIDELINES ARE PROVIDED TO ESTABLISH A COMMON FOUNDATION FOR ALL THE TEAMS AND TO GIVE INSIGHT INTO THE GENERAL METHODOLOGY.

THESE GUIDELINES HILL ADDRESS THE TYPICAL EASRTP ROUTINE, GENERAL GUIDELINES, THE NORMAL EXPECTATIONS AND FEATURES OF THE PREPARATION, CONDUCT, AND REPORT PHASES OF THE PROCESS. THE GUIDELINES HILL FIRST COMPARE THE EASRTP EVALUATION TO THE-  :

ASRTP AND SSFI PROCESS. j COMPARISON OF EASRTPs TO NRC " FUNCTIONAL" INSPECTIONS i

THE NRC SSFI IS NORMALLY A 4 WEEK INSPECTION THAT CAN BE DIVIDED INTO THE FOLLONING ELEMENTS:

1. A ONE HEEK ENGINEERING INSPECTION CONDUCTED BY DESIGN ENGINEERS THAT IS OFTEN AT THE CORPORATE OFFICE.

2. A TWO HEEK ON-SITE INSPECTION WITH THE FULL TEAM.

3. A FOURTH AND ANY ADDITIONAL HEEKS NEEDED TO PREPARE THE REPORT. j I

AN NRC TEAM IS USUALLY COMPRISED OF A TEAM LEADER AND INSPECTORS HHO ARE l i

ASSIGNED TO THE FOLLONING AREAS:

1. MECHANICAL DESIGN

2. ELECTRICAL DESIGN l

3. OPERATIONS

4. MAINTENANCE

5. TESTING

6. - TRAINING

7. SYSTEM HALKDOMN

8. QUALITY ASSURANCE (LIMITED PARTICIPATION) 1 i

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%, ,e m.m , , .m ,,, # w _ ,gmg TilI' NRC PLACES HEAVY RELIAhCE ON TEAM MEETINGS AND THE SYNERGISH CREATED

^ DUN NG THFSE MEETINGS. THE TEAM LEADER AKD THE ENTIRE TEAM SPEND CONSIDEliABLE TIME IN1ERVIEHING PLANT fERSONNEL, OBSERVING PLANT ACTIVITIES, REVIEHING DOCUMENTATION, AND FOLLOHING-UP LEADS. ANOTHER IMPORTANT ELEMENT OF THE TEAM IS THAT IT CONDUCTS DAILY DEBRIEFINGS TO THE LICENSEE. THIS HELPS TO CLEAit UP MISCONCEPTIONS, ALERTS MANAGEMENT TO PROVIDE EMPHASIS ON SIGNIFICANT ISSUES, AND ALLOWS LICENSEES TO TAKE CORRECTIVE ACTIONS.

THE NRC SSFI AND ASRTP ARE INNOVATIVE INSPECTION APPROACHES THAT CCi40INE PROGRAMMATIC AND TECHNICAL EXPERT!SE. THEY HAVE PROVEN EFFECTIVE FOR IDENTIF7ING PROBLEMS THAT CAN DEGRADE THE OPERATIONAL READINESS OF SAFETY SYSTEllS. THFY ARE A MIXTURE OF PERFORMANCE APPRAI9 L TEAM METHODS AND A DESIGN BASED TECHNICAL REVIEH.

THEY ARE DYNAMIC INTERACTIONS THAT HAVE NOT BEEN PROCEDURALIZED 9EYOND STATING OBSECTIVES AND GIVING EXAMPLES OF QUESTIONS TO ASK AND TO CONSINR DURING THE INSPECTION. THESE OBJECTIVES AND QUESTIONS ARE PROVIDED IN APPENDIX C OF THE NRC ItsE INSPECTION MANUAL. THIS IS INCLUDED AS ATTACHMENT 1 TO THESE GUIDELINES.

THE EASRTP EVALUATION HILL INCLUDE MOST OF THE ASPECTS HENTIONED AB0VE. MORE DETAIL ON EACH OF THESE IS PROVIDED IN THE FOLLOHING SECTIONS.

TYPICAL EASRTP TEAM _ ROUTINE THE COMPOSITION OF EACH EASRTP TEAM IS OUTLINED IN THE EASRTP EVALUATION PLAN. TEAM COMPOSITION IS SIMILAR TO THE NRC ASRTP TEAM COMPOSITION. THE AREA 0F TRAINING HILL BE EVALUATED BY THE ENTIRE TEAM AND NOT BY A SPECIFIC TEAM MEMBER.

THE EASRTP EVALUATION IS COMPOSED OF THREE PHASES: PREPARATION, CONDUCT, AND P.EPORT. THE TEAM SCHEDULE PROVIDES APPR0XIMATELY 2 CALENDAR DAYS FOR PREPARATION, 14 FOR THE EVALUATION, AND 3 TO HRITE A REPORT. THIS TOTALS 19 DAYS PER SYSTEM.

THE ACTUAL ON SITE AUDIT TIME IS SIMILAR TO THE TYPICAL HRC ASRTP ON-SITE INSPECTION TIME.

THE FIRST HEEK OF THE NORMAL NRC SSFI ROUTINE IS OMITTED FROM THE ASRTP AUDIT PROCESS DUE TO THE RECOGNIZED EFFECTIVE EFFORT ALREADY PUT INTO THE PROBLEM IDENTIFICATION PROCRAM (QCI-12) AT RANCHO SECO. INSTEAD OF HAVING DESIGN ENGINEERS SPEND A HEEK REVIEHING DESIGN DOCUMENTS IN ORDER TO PROVIDE INITIAL LEADS TO THE FULL TEAM, THE NRC TEAM TOOK ADVANTAGE OF THE FROBLEMS ALREADY IDENTIFIED IN THE SYSTEM STATUS REPORT AND USED THEM AS THEIR INITIAL SOURCE OF LEADS. THE EASRTP 1EAM HILL 00 LIKEHISE. 'IT IS EXPECTED THAT THE EASRTP DESIGN ENGINEERS HILL HAVE TO l

RETURN FREQUENTLY TO THE DESIGN BASES AND SOURCE DOCUMENTS TO FOLLOH-UP LEADS. THIS CORRELATES TO THE METHOD AND LOGIC EMPLOYED BY THE NRC ASRTP CONDUCTED AT RANCHO SECO BETHEEN DECEMBER 1986 AND FESRUARY 1987.

EACH TEAM LEADER SHOULD HOLD TH0 TEAM MEETINGS PER DAY - ONE IN THE MORNING AND ONE IN THE EVENING. THE MORNING HEETING SHOULD BE NO LONGER THAN 30 MINUTES.

ITS OBJECTIVE IS TO ALLOH ALL TEAM MEMBERS TO BECOME FAMILIAR HITH HHAT EACH INDIVIDUAL TEAh MEMBER HAS PLANNED FOR THAT DAY'S ACTIVITIES. IT ALSO ALLOHS THE TEAM LEADER TO CONFIRM THAT HIS TEAM IS FOCUSING ITS R? SOURCES ON THE MOST PROMISING ISSUES. THE EVENING MEETING SHOULD BE APPR0XIMATELY 60 TO 90 MINUTES. DURING THIS MEETING, EACH TEAM MEMBER SHOULD INFORM THE REST OF THE TEAM 0F THE RESULTS OF HIS DAILY ACTIVITIES. HE SHOULD BRIEFLY DESCRIBE INFORMATION PERTINENT TO THE ENTIRE TEAM AND INDICATE THOSE AREAS HHERE HE IS DEVELOPING CONCERNS OR ISSUES. EACH TEAM MEMBER SHOULD ALSO ASK FOR ADDITIONAL SUFPORT FROM OTHER TEAM MEMBERS HHEN NEEDED.

IT IS ANTICIPATED THAT THESE TEAM HEETINGS HILL INVOLVE DISCUSSIONS AND QUESTIONS FROM VARIOUS PERSPECTIVES. THESE TEAM MEETINGS HILL OFTEN BE SUPPLEMENTED 2

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HITH ADDITIONAL PERSONNEL IN ORDER TO ADD TO THE SYNERGY OF THE MEETINGS.

EXAMPLE, THE QA REPRESENTATIVES SHOULD ATTEND MOST TEAM HEETINGS, AND MEMBERS,0F/THE (n '

VARIOUS ON-SITE. VERIFICATION AND REVIEN GROUPS MAY ATTEND. TEAM MEMBER $'SHOULD CO MUNICATE FREQUENTLY HITH DEPARTMENT EASRTP COORDINATORS AND DEPARTMENT HEADS WHEN CONCERNS ARE DEVELOPED THEY SHOULD BE CO MUNICATED TO THE APPROPRIATE ORGANIZATION AND DOCUMENTED SHORTLY THEREAFTER HITH A REQUEST FOR INFORMATION (R {

j FORM AS DESCRIBED IN THE EASRTP EVALUATION PLAN.

i TEAM MEMBERS ARE EXPECTED TO REVIEN THEIR DAILY NOTES, AND DOCUMENT THEIR ACTIVITIES IN A LEGIBLE, LOGICAL FORMAT EACH EVENING. THEY SHOULD ALSO DETERMINE HHAT CONCERNS REQUIRE ADDITIONAL FOLLOH-UP AND PLAN THE NEXT DAY'S ACTIVITIES ACCORDINGLY.

IT IS SUSPECTED THAT EACH TEAM MEMBER HILL SPEND APPROXIMATELY' SIXTY HOURS PER HEEK ON THE EVALUATION. THE TEAM LEADER HILL HAVE THE FLEXIBILITY TO DETERMINE T,iE TEAMS SHOULD i HHICH DAYS AND H0H LONG THE TEAM SHOULD REMAIN ON SITE EACH HEEK. '

NOT HAVE TO N0kK ON SUNDAYS. H0HEVER, SOME HORK ON SATURDAYS HILL PROBABLY BE' NECESSARY. TEAM LEADERS MAY ALSO DECIDE TO CONDUCT ONE-ON-ONE SESSIONS WITH THEIR TEAM MEMBERS INSTEAD OF CONDUCTING ONE OF THE DAILY TEAM MEETINGS.

EASRTP GENERAL GUIDELINES THERE ARE SOME GENERAL GUIDELINES THAT SHOULD BE FOLLOWED IN ANY INSPECTION AS A MATTER OF GOOD PRACTICE. A LIST OF.SOME OF THOSE FOLLOH:

1. TAKE THOROUGH NOTES. SOMETIMFS, SEEMINGLY IRRELEVANT INFORMATICH BECOMES QUITE MEANINGFUL HHEN ANALYZING AND SU WARIZING YOUR ACTIVITIE

2. NOTES SHOULD INCLUDE DETAILS. FOR EXAMPLE, PROCEDURE NUMBERS, STEP DETAILS, REFERENCE INFORMATION, EQUIPMENT BASE PLATE INFORMATION, EXACT LOCATIONS OF COMPONENTS OR DEFICIENCIES, AND SPECIFIC MATERIAL DEFICIENCIES. TAKING DETAILED NOTES HILL SAVE TIME LATER HHEN HRITING A REPORT.

3. AFTER REVIEHING DOCUMENTS OR OBSERVING AN ACTIVITY, DEVELOP QUESTIONS AND ITEMS TO FOLLOH-UP SO YOU DON'T FORGET THEM.  !

4. ALMAYS DOCUMENT LEADS PASSED ON TO OTHER TEAM MEMBERS SO THAT THEY DON'T FORGET THE SOURCE AND MEANING OF LEADS.

5. TEAM MEMBERS MUST HAVE A QUESTIONING MIND. A PROBING INTELLECT AND A CREATIVE CURIOSITY. THEY HAVE TO BECOME CREATIVELY INQUISITIVE.

6. -TEAM MEMBERS MUST CONCENTRATE ON SEEING BEYOND THE SYSTEM THEY ARE EVALUATING. THEY MUST BE ABLE TO LOOK AT SPECIFIC FACTS ASSOCIATED WITH A SYSTEM AND DETERMINE IF HAVE ANY GENERIC IMPLICATIONS FOR AN ENTIRE PLANT PROGRAM. FOR EXAMPLE, NUMEROUS MATERIAL DEFICIENCIES IN THE INSTRUMENT AIR SYSTEM MAY BE POINTING TO AN OVERALL PROBLEM IN THE BALANCE OF PLANT MAINTENANCE PROGRAM.

7. EACH TEAM MEMBER HILL HAVE AN IMPACT ON PLANT OPERATIONS.SINCE THERE ARE SIX TEAMS CONDUCTING SIX SEPARATE AUDITS IN PARALLEL, THE IMPACT I

HILL BE SIGNIFICANT. TEAM MEMBERS MUST BE SENSITIVE TO THESE EFFECTS.

8. FOLLOH-UP IS A VITAL PART OF THE EVALUATION. DURING FOLLOH-UP A TEAM MEMBER CONFIRMS THE ACCURACY OF HIS CONCERN, DETERMINES THE FUNDAMENTAL PROBLEM OR NEEDED IMPROVEMENT, DETERMINES THE EXTENT OF THE PROBLEM OR {

NEEDED IMPROVEMENT, AND DETERMINES BASIC CAUSES. l l

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9. TEAM MEMBERS MUST KEEP IN MIND THAT WHAT THEY FIND OFTEN HILL BE ONLY INDICATURS POINTING TO A PROBLEM - RATHERzTHAN THE PROBLEM:ITSELF.

EASRTP_ PREPARATION _PHFI DURING THE PREPARATION PHASE, EACH TEAM MUST REVIEN A NUMBER OF DOCUMENTS RELATED TO THE SYSTEM TO_BE EVALUATED. A SAMPLE LIST OF DOCUMENTS THAT THE TEAM SHOULD HAVE AVAILABLE IS GIVEN IN THE EASRTP EVALUATION PLAN. THESE DOCUMENTS SHOULD BE'REVIEHED IN ORDER TO BECOME KNOWLEDGEABLE OF THE SYSTEM DESIGN, ARRANGEMENT, AnD FUNCTIONS, THE REVIEW SHOULD BE FROM A FUNCTIONAL PERSPECTIVE AND AN EMPHASIS PLACED ON DETERMINING THE OPERATING CONDITIONS UNDER HHICH EACH ACTIVE i

COMPONENT HILL FUNCTION DURING AN ACCIDENT OR DURING ABNORMAL CONDITIONS. TEAM HEMBERS SHOULD @ ESTION IF EACH COMPONENT'IS INSTALLED AS DESIGNED, BEEN TESTED TO VERIFY IT HILL FUNCTION AS DESIGNED, AND DETERMINE IF.THE DESIGN BASES IS THE CORRECT ONE. IT IS RECOMMENDED THAT THE INSPECTION OBJECTIVES IN ATTACHMENT 1 BE

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REVIEHED FREQUENTLY DURING ALL PHASES OF THE EVALUATION. POTENTIAL QUESTIONS TO ASK AND' AREAS TO CHECK FOR SPECIFIC TEAM MEMBERS ARE PROVIDED LATER. l

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AS PART OF THE PREPARATION PHASE, TEAM HEMBERS SHOULD BECOME FAMILIAR WITH I PREVIOUS NRC SSFI FINDINGS THROUGHOUT THE INDUSTRY HITH RESPECT TO THE SYSTEM BEING l 1

AUDITED AS HELL AS TO THE-GENERIC FINDINGS DEVELOPED BY THE NRC.ASRTP COMPLETED IN I

FEBRUARY 1987. MOST OF THIS INFORMATION HILL BE PROVIDED TO THE TEAMS DURING INITIAL TRAINING ON THE EASRTP PROCESS. IN ADDITION, EACH TEAM LEADER HILL HAVE A l COPY OF THE LESSON PLAN AND THE ACTUAL NRC SSFI INSPECTION REPORT FOR EACH i INSPECTION REPORT COVERED IN TRAINING. '{

THE VALUE OF THE PREPARATION PHASE CANNOT BE OVEREMPHASIZED. DURING THIS PHASE APPROPRIATE STANDARDS, REGULATIONS, CODES, AND GUIDES MUST BE CONSIDERED IN ORDER TO ACCURATELY MEASURE THE ABILITY OF THE SYSTEM TO FUNCTION. IN ADDITION, STANDARDS OF EXCELLENCE AND INDUSTRY STANDARDS SHOULD BE REVIEHED BECAUSE THEY FORM A BENCHMARK FOR EVERY SYSTEM THAT IS REVIEHED. THE TEAM RETAINS THE FLEXIBILITY TO INDICATE THAT ALTHOUGH MINIMUM STANDARDS ARE BEING MET, CONCERNS MAY ARISE DUE TO NOT MEETING EXPECTEC OR DESIRED INDUSTRY STANDARDS.

EASRTP C0hDUCT HITH RESPECT TO EASRTP'S, THERE ARE SPECIFIC AREAS THAT THE TEAM MEMBERS SHOULD EVALUATE AND SPECIFIC QUESTIONS THAT SHOULD BE CONSIDERED. ATTACHMENT 1 LISTS SOME QUESTIONS THAT HOULD APPLY TO VALVES, PUMPS, INSTRUMENTS AND SENSORS.

THESE QUESTIONS ARE ONLY EXAMPLES AND ARE PROVIDED TO ACQUAINT THE TEAM MEMBER HITH THE TYPE, DEPTH, AND NATURE OF AN EASRTP. IN ADDITION, ATTACHMENT 1 PROVIDES GUIDELINE EXAMPLES FOR REVIEN OF MAINTENANCE AND TEST RECORDS, DESIGN DOCUMENTS, HALKDOWNS, AND PROCEDURES. AGAIN, THESE EXAMPLES ARE NOT ALL INCLUSIVE. ADDITIONAL GUIDELINES FOR EACH SPECIFIC AREA PROVIDED BELOH AND IN ATTACHMENT 2.

TEAM MEMBERS SHOULD KEEP IN MIND THAT THE EASRTP CCACENTRATES ON A SYSTEM.

CONSEQUENTLY, NHEN THE NORK CONTROL SYSTEM OR CALIBRATION SYSTEM IS REVIEHED, THE TEAM SHOULD DETERMINE THE EFFECTIVENESS OF THOSE PROGRAMS HITH RESPECT ONLY TO THE SELECTED SYSTEM EVALUATED. IN A SIMILAR FASHION, TEAM MEMBERS SHOULD DETERMINE HHAT PLANT ACTIVITIES ARE PLANNED ASSOCIATED HITH THE SELECTED SYSTEMS. IF A SURVEILLANCE IS PLANNED TO BE CONDUCTED OR MAINTENANCE PERFORMED THEN CONSIDERATION SHOULD BE GIVEN TO OBSERVING IT. IN ADDITION TO THE OBSERVATIONS, TEAM MEMBERS HILL CONDUCT NUMEROUS INTERVIENS AND REVIENS TO BETTER UNDERSTAND FACTS AND FOLLOH-UP LEADS.

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$4%bdgb.aa:um4gesma- as..mm.sw uuu m_, u.a aggag EACH PLANT DEPARTMENT WILL HAVE AN EASRTP COORDINATOR HHOSE ROLE IS DEFINED p'

IN THE EASRTP EVALUATION PLAN. ALL TEAM MEMSERS SHOULD SCHEDULE MEETINGS AND.

REQUEST INFORMATION THROUGH THE COORDINATOR, EVEN IF HE KNONS SOMEONE HHO CAN PROVIDE THE SPECIFIC NEEDED INFORMATION. IT IS IMPORTANT FOR THE COORDINATOR TO i UNDERSTAND THE EASRTP IMPACT OR HIS DEPARTMENT IN ORDER TO ACCOMPLISH HIS OTHER DEPARTMENT TASKS AND RESPONSIBILITIES.

SOME DESIGN ISSUES AT THE PLANT HAVE BEEN IDENTIFIED AS POTENTIAL GENERIC CONCERNS. THESE ISSUES ARE LISTED IN ATTACHMENT 3. TEAM MEMBERS SHOULD CHECK THESE ISSUES TO DETERMINE IF THESE PROBLEMS ARE IN THE SYSTEM BEING EVALUATED.

DISIGN REVIEW THE DESIGN EMGINEERS SHOULD REVIEW SELECTED MODIFICATIONS, PERFORM A DETAILED REVIEW OF SELECTED CALCULATIONS, AND INTERFACE HITH THE NUCLEAR ENGINEERING DEPARTMENT ENGINEERS. POTENTIAL PROBLEM AREAS SUCH AS PUMP RUN00TS MOTOR OVERSPEEDS, IMPROPER AMPACITY, INADEQUATE NET POSITIVE SUCTION HEAD, AND TANK OVERPRESSURE PROTECTION SHOULD BE REVIEHED.

SYSTEM ENGINEERS FUNCTIONALITY AS OPPOSED TO "0PERABILITY" IN ALL POSSIBLE MODES OF OPERATION MUST BE CONSIDERED. THIS INVOLVES NEARLY A 1007. REVIEW AT THE COMPONENT LEVEL. CHECK VALVES SHOULD BE REVIEHED TO DETERMINE IF THEY HAVE BEEN ADEQUATELY TESTED AND SURVEILLANCE REVIEHED TO DETERMINE IF ACCEPTANCE CRITERIA ARE APPROPRIATE TO DEMONSTRATE FUNCTIONALITY. THROTTLE VALVE POSITIONS SHOULD BE COMPARED TO THE POSITICNS DETERMINED BY FLON BALANCE TESTS.

1 MAINTENANCE f THE TEAM MEMBER SHOULD REVIEW CORRECTIVE MAINTENANCE ON THE SELECTED SYSTEM DURING AT LEAST THE LAST 12 MONTHS OF PLANT OPERATION, REVIEM ALL APPLICABLE MAINTENANCE PROCEDURES, REVIEW THE PREVENTIVE MAINTENANCE PROGRAM, AND CONDUCT PLANT TOURS TO REVIEW THE ACTUAL MATERIAL CONDITION OF THE SYSTEM.

OPERATIONS SYSTEM MALKDOHNS AND OPERATING PROCEDURE REVIEWS (EMERGENCY, ABNORMAL AND NORMAL) SHOULD BE CONDUCTED. SETPOINTS SHOULD BE REVIENED TO DETERMINE THEIR ADEQUACY. PART OF THIS REVIEW HOULD BE TO FOCUS ON THOSE INDICATIONS THAT ARE NOT AVAILABLE BUT SHOULD BE. TRAINING PLANS SHOULD BE COMPARED TO AS-BUILT PLANT CONDITIONS AND THE OPERATING PROCEDURES TO DETERMINE THE ACCURACY AND QUALITY OF THE TRAINING PROGRAM FOR THE SELECTED SYSTEM.

OUALITY ASSURANCE ARE SYSTEMS BEING AUDITED TO ENSURE COMPLIANCE WITH APPROPRIATE NRC REGULATIONS? ARE CORRECTIVE ACTIONS APPROPRIATE FOR THE IDENTIFIED PROBLEM AND ARE THE CORRECTIVE ACTIONS EFFECTIVE? ARE THE AUDITS CONDUCTED COMPREHENSIVE AND DETAILED EN0UCH TO FULFILL THEIR INTENDED PURPOSE?

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'4 AT THE END OF EACH EASRTP AUDIT, A FORMAL REPORT HILL BE HRITTEM AND SUBMITTED TO THE PROGRAM MANAGER. ALL TEAM MEMBERS ARE FNCOURAGED TO DEVELOP i

HRITTEN CONCERNS THROUGHOUT THE EVALUATION IN ORDER TO MINIMIZE THE TIME NECESSARY TO HRITE THE REPORT. THIS PRACTICE HILL HELP TO ENSURE EN0'JGH FOLLOH-UP HAS BEEN CONDUCTED TO SUPPORT THE TEAM MEMBER'S CONCERUS. THESE CONCERNS HILL BE DOCUMENTED ON A RI.

ADDITIONALLY, EASRTP TEAM MEMBERS MUST BE CONSISTENTLY AHARE OF THE FACT THAT THEIR NOTES MUST BE CLEAR, LEGIBLE AND LOGICAL. SUFFICIENT DOCUMENTATION STATING HHAT HAS CHECKED AND FOUND MUST BE MAINTAINED. ATTACHMENT 4 IS INCLUDED AS A SUGGESTED FORMAT. TEAM LEADERS ARE RESPONSIBLE FOR ENSURING ADEQUATE DOCUMENTATION OF THEIR TEAM'S EFFORTS IS MAINTAINED. l:

DETAILS CONCERNING REPORT FORMAT AND RIs ARE PROVIDED IN THE EASRTP EVALUATION PLAN.

TEAM MEETINGS SHOULD BE HELD TO DISCUSS DRAFT REPORTS SO THAT ALL TEAM MEMBERS ARE AMARE OF ANY MAJOR FINDINGS AND TO ENSURE THAT TEAM HEMBERS SUPPORT THE FINDINGS.

APPROXIMATELY 4 DAYS HAVE BEEN ALLOCATED TO HRITE AND SUBMIT A FINAL REPORT.

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APPENDIX C SAFETY SYSTEM FUNCTIONAL INSPECTION I. LINSPECTION OBJECTIVE A. The objective of a Safety System Functional Inspection (SSf!) is to : assess the operational readiness- of selected 'sefety systems  ;

by determining whether:

1. The systems are. capable of performing the safety functions required by their design bt.ses..

2. Testing is adequate to demonstrate.that the systems would perform all of the safety functions required.

- 3. System maintenance (with emphasis 'on. Dumps 'and' valves) is adequate to ensure system operability under pcs.tulated ac-

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cident' conditions.

rN 4. Operator and maintenance technician training is adequate to ensure proper operations and maintenance of ~ the system.

5. Human factors considerations relating to the selected sys-tems (e.g. , accessibility and labelling of valves)'and the supporting procedures for those systems are adequate to en-

- sure proper system operation under normal and accident con-ditions.-

6. Management controls including procedures are adequate to ensure that the- safety systems will fulfill the safety functions required by their design bases.

II. INSPECTION METHODOLOGY A. Review the desion-basis requirements for the selected system (s) and determine the opercting conditions under which each' active component will function during accident or abnormal conditions.

This review should determine if the design basis is met by the installed, tested component and if the design basis is the correct one.

1. For valves: What permissive intericcks are involved? What dif ferential pressures will exist when the va.1ve strokes?

- Will the valve be repositioned during the course of the -

event? What is the source of control /indicpon power?

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2. For pumps: What are the flow paths the puap will- experi- "

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.h ence 'during accident scenatios? ' Co the ficy paths change?

What permissive interlock / control logic apply? -How is the pump controlled during accident cenditions? What manual actions are requirad to back up and restore a degraded function? What suction / discharge pressures can the pump be expected to experience during accident conditions? What is the motive power for the pump during all conditions?

3. For instrumentation and sensces: What plant parameters are l t

used as inputs to the initiation and control systems? Is operator intervention required in certain scenarios? Are the range and acci.ncy of instrumentation adequate? What is the extent of 1::rveillance and/or calibration of such instrumentatfor.?

B. Review the design of the selected system (s) as installed in the plant.

1. Determine if the as-built design and inta11ation matches the current design / licensing basis requirements for that partic. lar facility.

For example, are fuses and thermal overloads properly sized; are current de loads within the

- capacity of the station batteries; and is the instruments-tion adequate in range and accessibility for operations to control the system under normal and abnormal conditions?

2. Determine if system modifications implemented since initial licensing have introduced any unreviewed safety questions.

For s'xample, have modified structures surrounding safety-related equipment, components, or structures been evaluated

- for seismic 2-over-1 considerations, and have modified equipment components falling under the scope of 10 CFR 50.49 been thoroughly evaluated for environmental equipment qualification considerations such as temperature, radia-tion, humidity?

3. Evaluate the licensee's drawing control program, the cesntrol and use of design input information, and the adequacy of , design calculations from the perspective of modifications made to she selected safety system.

C. Review the maintenance and test records for the selected system (s).

1. Determine if the system components have been adequately tested to demonstrate that they can perform their safety function under all conditions they might experience in an accident situation. Determination of adequate testing may require consideration of removing all actuator power, including both electrical and pneumatic,.Gr fail-safe valves (see IE Information Notice No. 85-84, " Inadequate )

In-service Testing of Main Steam Isolation Valves").

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.J maintained .to - ensure their operability under. all accident

! conditions. For: example, ue limit and torqueeswitch. set-~

tings proper; is the instruments airr systantadequately-h!Q maintained to ensure the reliability; of pnecmatic valves; are fuse and thermal overload sizes correct; and are pipe supports, seismic restraints and 1 shielding being main-tained?.

3. ~ DetermineL the adequacy of the licensee's preventive main '

~tenance program for the system. As a part of- this '

assessment, refer ~to the appropriate vendor technical manuals. .

. - 4. Support system and plant modifications should be evaluated to the extent'possible to ensure that system design.capabi-lity as demonstrated by preoperational-testing has not been compromised. For instance, the addition of a fire barrier in an ECCS pump room may compromise room cooling capabili- i, ties by altering air flow paths.

D. Perform walkdown of selected systems.

1. Determine if components are labeled and accessible. For' example, can the components be operated locally / manually if required by the licensing basis, and is there HP/ security interference?

2.. Determine if MOV operators and check valves (particularly lift-type) are installed in the orientation required by.the manufacturer. Additionally, a human factors assessment of component orientation (such as the direction of handwheel

- rotation for valves installed upside down) should be made.

'l

3. Determine if system lineup is consistent with design /licen-sing basis requirements. This lineup inspection should include considerations of the normal and ' backup power supplies, control circuitry, indication 'and annunciation status, and sensing lines for instrumentation.

E. Review abnormal, emergency, and normal operating procedures; maintenance procedures; and surveillance procedures for the selected system (s).

1. Assess the technical adequacy of the procedures.

2. Determine if the procedural steps will achieve required -)

system performance for normal, abnormol, and emergency  !

ccr.ditions. This should include consideration of operator actions to compensate for shortcomings in design.

3. Determine if operations and maintenance personnel receive adequate training pertaining to the selected system (s) and if the degree of' training provided is consistent with the aldount of technical detail included in proce6iares. In

( particular, verify that operators are trained on system 25'.3 C-3 Issue Dtte: 11/12/S6

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uwa+ ,uusaasuawmMaa:vmpawumagggw(req;u;mwwummannenwesum response, failure modesr and uired actions- involved-tMeme 4 all credible scenarios in which the system is required to functinn. i N-+

4. Determine if ' surveillance test procedures comprehensively address required system responses. For example, does the j

tested lineup duplicate 'the accident response ' lineup; are check valves tested to prevent reverse flow; and does the 3 test establish any artificial' initial conditions? l F. Review ' the operational experience of. the selected system (s).

This would include LERs, NPRDS,10 CFR 50.72 reports, enforce-ment actions, nonconformance reports, and maintenance work requests. -

1. Ceterniine the historical reliability of the system and its (

components based on the review and analysis of the opera-tional experience.

2. D2termine if the licensee has aggressively pursued, identified, and corrected root causes of failures.

3. Determine the extent of the maintenance backlog and ascer- 4 tain if the licensee has a program to identify, prioritize  !

and perform timely safety-related maintenance activities. )

Is there a backlog of safety-related maintenance? j III. INSPECTION GUIDANCE l!

A. Plant' Specific Probabilistic Risk Assessment should be reviewed ^l as part of the system selection methodology, if available. 'd Studies conducted. by AE00 also can provide useful data for determining which system to select.

B. Past experience with SSFIs has demonstrated that. identifying the detailed cesign-basis requirements for the selected safety systems can be quite difficult and time consuming for the inspection team as well as for the licenseo. The difficulty in clearly identifying design-basis requirements at older plants is related to the fact that the information often has never been asseinbled before and is typically scattered among the records at the stored atengineer',s architect the plant atoffices the licensee's corporate and at the offices,ffices.

NSSS vendor's o ,

Consequently, en effort shouh be made to proviae the licensee l with adequate advanced notice regarding the safety systems to be inspccted to allow the licensee time to begin coTlecting the i needed documentation. The inspector should compare the original i FSAR system design descri) tion to that contained in the USAR as I part of the effort to icentify detailed design-basis require-  !

ments.

C. The design review portica of the inspection should bb performed J by inspectors with extensive nuclear plant design experience, j preferably comparable to the e.yperience gained through, previous '

employment with an architect engineering firm. Itus important also that the inspectors performing the design review have a l, i

1

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testing, and quality assurance so that~ they are able to~ rela'te" taeir findings to the' other functional areas being inspected.

O D. When performia; the review of maintenance and test records. sit .

) is essential for the inspector to focus on the technical details of how the activities were performed. For example, were the closing limit switches set with the motor-operated valve fully shut or four turns cff the shut seat? The review of test  !

records should go beyond a review of the in-service testing and 4 surveillance programs for Technical Specifications. The inspector should seek the answer to the fundamental question of '

whether or not the safety systems and all included components have been tested to demonstrate that they will perform their intended safety functions as defined in the design basis.

E. As part of the system walkdown, the intpector should analyze the adequacy of the systcm lineup, accessibility, indications, relative to the most limiting design-basis conditions (e.g. ,

degraded power and lighting, single failure, loss of non-safety-rclated indications, and harsh environments).

F. As was the case for the review of maintenance and test records (discussed in III.C), it is essential for the inspectar to focus

.. on the technical details of- the operating, maintenance, and

. surveillance procedures reviewed. The inyector should verify that the emergency and abnormal operating procedt.res are ade-quate to handle the most limiting design-basir events. Where it is not reasonable for procedures to predde detaled guidance, O the inspector should verify that the licensee's training program ensures that the operators are knowledgeable in the areas of Concern. l G. The effectiveness of the SSFI methodology is greatly enhanced if the various inspection team nembers are able to benefit fecm each other's inspection efforts. Accordingly, frequent., even  !

daily, tean meetings are encouraged to allcw the team me1bers to ,

share their findings. 'It has been the experience of the head-quarters-based SSFI effort that many of the more significant findings originate from team meeting discussions that allow related inspection findings "a different functional areas to be pieced together.

IV. INSDELTION APPROACH A. Team Composition An inspector should be assigned to each of ths following areas:

electrical de. sign, mechanical design, maintenance, surveillance and testing, operations, and training. The detailed system walkduwn can be done by an additional inspector participating

~

for only part of the onsite activities, or this aspect can be covered by the operations inspector. -

A full-time team leader without any specific area assignments should have the primary responsibility to provide guidance and 2515 C-5  :: 3 Cate: 11/12/55

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resident' inspector for , the site being, inspected should not, be ,

assigned; as a participung. team member;- however,s his/her i a involvement in the inspection process shouldbe encouragedf to f h' tion of Work, Work Activities, . and Review of Quality Records

..71707 - Operational Safety Verification 71710 - ESF System Walk Down 72701 - Modification Testing 73051 --Inservice Inspection - Review of Program -c l

. 73755 - Inservice Inspection - Data Review and Evaluation {

END i

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2515 C-7 Issue Date: 11/12/85

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'" :r.pic: Calculations - assumptions:

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Are they realistic?

Aretheyjustifiable? l Are they specific or too broad? l' (example: using an average fluid density value without regard for actual temperatures)-

Calculations - Methodology. ,

Is,it the appropriate methodology to.use? 1 Are conversion factors correct? l Are SU transformer impedances in calcs?

Consideration of.MOV starting currents as part of initial discharge loads.

Check cales for engineering judgements

.s Check cales to determine their accuracy in reflecting as-is plant.

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Topic: Check Valves - Have they been checked for tightness?

Are they tested?

Are they in t' en PM program?

' Are they adequate for their use (excess flow check valves)

Are flow check valves' used properly?

Are valves adequately sized?

How will SLB affect the system?  ;

Topic: Battery':

i Are temperatures considered in the design process? )

Are rooe temperatures above min design specified?  !

Are the batteries sized correctly?

Maintained per vendor recommendations?

N' Equalizing and test discharge tests conducted correctly?

Specific gravities properly taken and corrected?

Reserve capacity?

Loading?

Are batteries sized correctly?

Effect on inverters reviewed'?

Mhat is the maint. history on battery?

4 ATTACHMENT 2 PAGE 1 0F 4

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f Topict Electrical Distribution:' ~l Are components within their period of:useful life?

(e.g. power filter capacitors)

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Nhat are the electrical load schedules?

What alarms when loads are lost? (e.g. 480 VAC load) '

Voltage.available at the component.

Cable sizing Ampacity considerations adequate Continuous and short circuit duty Consideration of test type data

' Check breaker sizes for adequacy Overload protection

~ Overload' alarms?

Feeder cable voltage drops?

Thermal insulation adequate?

Inverters and inverter loads?

Justifications for reduction of safety related loads. j Are EQ records available?

DC system power distribution correct?- {

Do data sheets point out'special entries? {

Leads and jumpers properly placed? l Hill the EDG provide power under DBA and survail test?

How are breaker positions verified?

Are protective relays in calibration program?

Check etlibration procedures. . .

Does control room have one-lines and diesel eleG/h drawings? -

Check load shedding surveillance?'

Check auto sequencing on EDG (all loads).

Does EDG diff. relay have leaking capacitor?

Observe EDG operation (all team members). 1 Check fuse control.

Check overall electrical coordination.

Check room temps (min. & max.) in EDG & critical areas?

Check general maintenance of electrical systems Is there a breaker load list?

Check Governor fluid change out frequency.

Topic: Mechanical:

Are relief valves adequately tested and sized?

Are component pressure ratings (pipes, bottles, tanks pumps) within design specifications.

Can components be exposed to overpressure situations?

Vacuum breakers sized and installed correctly?

Valve stroka times trended and corrective actions taken per ASME7 Are seismic 2 over I considerations made effects of transverse motion on valves?

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Combining valves for multiple spatial components for;an.

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90 Installation of air cyclinders;in backup air supply.

'Do flow test actually mimic functional situation?

On what systems does the. safety system rely for support?

Is piping adequately sized for flow, pressure and temp-conditions?

Have-HOVs been tested at system pressure?

Topic: Pumps:

Susceptible to run-out?- 1 NPSH adequately considered and correct? l Are flow testing methods adequate?  !

-Are the. test measurements accurate enough to conduct i the test?

Are overspeed trips of Turbine-Driven pumps and motor-driven pumps adequate?

Are any special. precautions needed.to' start or stop the pump (e.g. time between successive starts, having to

. secure one before starting the other, etc)?

Puse packing procedures Protection for pump motors On steam driven pumps; flow, pressure and temp in spec?

What are the ramifications of long-ters operation of pumps?

What is the maintenance history of pump?. I Topic: Setpoints:

~ Are throttle valves correctly set?

Are computer setpoints cor ect? 3 Are alarm setpoints justifiable? l Are they adequate?

Topic: Measurements Insuiatea eersus uninsulated instrument lines and their effects on operation.-

Signal' accuracy and range requirements meet to ensure valid calibration?

l Topic: Nitrogen System i.

Is backup safety related?

Is there sufficient capacity to meet cycling needs?

Is pressure properly set?

Has the system been fully tested?

ATTACHMENT 2 PAGE 3 0F 4

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+-m*"-" m Topic: Moi:or Operated Valves:- ~ -N~ * * ~ " 'i Are. torque switch set' tings specified.and set. correctly?

0 sg Are limit switch settings correct?

- (g"- Maintenance of MOVs poor due to dirt, . missing and caps, etc?

Proper power source?. ,

Proper maintenance procedure per tech manual? i What is the OP history of MOVs

. Topic: Other:-

Is'there evidence of independent design reviews?-

Are procedure references current anft available (specially for design)? .

Are all positions of a switch tested?

Sensing line single failure impacts?

Comparison of Fabrication drawings to installation?

Potential . leakage paths in air systems? i Check controlled drawings,for accuracy (incorrect valve i positions and locked positions). -)

^

Coordination of post-mod and sury. tests.

Instrument index contained errors / omissions.

Isolation of Control Room Isolation Remote Shut-down Instrument..

Is there a good preventive maintenance program in place?

What is Physical Appearance of system components?

Have personnel been properly traine( to procedures?

Have 50.59 evaluations covered all safety' questions?

How are safety classifications determined?

Have IE, INP0 & LER bulletins been reviewd?

Check communication practices!

Check vendor requirements for component PM and surveillance. i' Check human factors! -

Check alare procedures for LOP and blown fuse.

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POTENTIAL GENERIC ISSUES The following are potential generic issues:

DESIGN CONTROL PROCEDURES INADEQUATE (I.E., NO CHECKING RQD. BY PROC.)

1. Loss of design control with potential to violate plant licensing commitments:

Approve design packages prior tr completion of supporting calls. -

j o

o Temporary modifications affecting licensing commitments o No evidence to assure that required design changes j completed / approved prior to plant mode requiring change o Cales. not performed in accordance with procedures A. Incorrect methods B. Inadequate / missing assumptions C. Inadequate / missing references D. Inadequate / missing Acceptance Criteria o Design drawings / calculations do not reflect as-built condition i

o No evidence of valve throttling, or set point documentation

2. Design process' fails to address all licensing requirements (General  !

l Design Criteria) o App. R I o HELB o Flooding, missiles o Seismic qualification o Environmental qualification o Separation (safety /non-safety) o Single failure o Appropriate transient modes for class I pipe stress o Pipe classification' boundaries on P& ids ATTACHMiHT 3

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3. Failure to' analyze all potential modes' of operation, including transients

["h o Inadequate NPSH for all modes o Failure to consider pump shutoff in calculating system pressures o Failure to consider componentlsystem capability o Failure to consider run out conditions o Failure to consider. turbine overspeed o Failure to provide adequate pump protection (i.e., mini-flow l recirc.) j o Inadequate relief valve setting / sizing

- (

I o Inadequate sys. capacities o Failure to address loss of offsite power o Inadequate 42 backup system sizing o Inadequate over current protection

'o Inability of system to supply required flow for all operating modes o Inability of system to perform in required time frame I

4. Use of commercial components in safety related systems without upgrade or suitable design review. -

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ITEM CHECKED:. ,

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Source of Information: (Document, Interview, Observation)

I Results:

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l. ATTACHMENT 4

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