ML20236J707
| ML20236J707 | |
| 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: |
| References | |
| PROC-870715-01, NUDOCS 8708060257 | |
| Download: ML20236J707 (77) | |
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I EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGRAM (EASRTP)
EVALUATION PLAN j
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'" ' "EXPANCED AUGMENTED SYSTEM AND TEST PROGRAM (EASRTP) EVALUATION PLAN.
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TABLE'0F CONTENTS.
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$?k Page Number I. Introduction' i 1.0 Purpose 1 2.0 Scope and Approach 1 <
2.1 General 1 2.2 ~ Systems 2 2.3 Program Organization 3 2.3.1 Evaluation Organization 3 2.3.2 ' Support Organization 5 2.4 Scope and Approach by Subject Area 5 2.4.1 Engineering and Design 5 2.4.2 System Engineer 5 2.4.3 Operations -
6 2.4.4 Maintenance .
7 2.4.5 Quality Department 8 3.0 Schedule 8 4.0 Preparation 8 4.1 Preliminary Preparation 8 4.2 Team Preparation 11 5.0 Conduct 11 ,
6.0 Reporting 13 7.0 Resolutions of Concerns 13
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( m ,, + , ~ .. - n - - n. . s.n.+ . , . w -n ~.. n s.r This document'provides the plan for evaluating > selected plant' systems similar to the recently conducted NRC Augmented System Review and Test Program (ASRTP) Inspection. The evaluation will combine ~ techniques used' during NRC Safety System Functional Inspections, NRC. Performance Appraisal Team Inspections, NRC ASRTPs, INPO evaluations, and SMUD Quality Department Vertical Audits. The plan will inco oorate elements associated with each of'these types of inspections and is consequently named the Expanded Augmented System Review and Test Program (EASRTP).
. The primary objective of the' program is to assess adequacy of activities and systems'in support of restart and to evaluate the effectiveness of programs establis ud to ensure safety during plant operations It will!
also assess the adequacy of activities proposed to resolve identified problems with respect to restart, and the thoroughness of system testing recommendations. The completion of this program,- including performance.
of any. required corrective. actions, in conjunction'with related on-going
'rteview and verification programs and activities, will provide added assurance of the operationa~1 readiness of Rancho Seco. The primary method of documenting the evaluation results will be with a final report and Requests For Information FormsJAttachment 1).
EASRTP evaluations examine many of the on-going review and verification.
programs / activities. Examples of these programs are listed below. More detail is provided in Attachment 2.
- Technical Specification Compliance Verification Program Design Calculation Review Program
- B&W Evaluation of' System Configuration and Restart Test Program
- Maintenance-Trending
- Preventive Maintenance (PM) Upgrade
- QCI-12 Tracking System (QTS)/ Systems Status Report (SSR) True Up
- Review of Open Work Requests (WRs)
- Review of Open Engineering Change Notice (ECNs)
- Review of Open Nonconforming Reports (NCRs)
- Review of. Davis-Besse SRTP
- Conduct System Walkdowns ;
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- Review of Open Abnormal Tags.
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- System Functional Testing I "'
- Review of Licensing.Open Items - Licensing Conduct Surveillance Procedure Technical Review l
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- EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGR
'1'.0 'PURPOSEc '
(; w I The purpose of this' evaluation-is to provide assurance that plant-systems important to safe and reliable operation are capable of
' performing required functions. The resuits of this evaluation-will-l provide additional ' assurance of operational readiness.
i 2.0 SCOPE AND APPROACH 2.1 GENERAL During the evaluation, the EASRTP team will evaluate numerous
' programs from a variety of perspectives. The following is a list of- typical areas and attributes:
The resolution to system problems identified in the SSR are complete and technically adequate.
ECNs implementing SSR resolutions are consistent with the resolution.
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Testing described in SSRs will demonstrate component and -
system functional requirements.
System modifications (as reflected in ECN packages and ,
referenced documents) are in conformance with applicable f
. codes, standards and licensing requirements.
Technically adequate analyses are available to design . features and requirements of system modifications.
Technical Specifications (or proposed assendments) reflect the system design and the SSR and identify the periodic testing requirements and acceptance criteria to demonstrate system / component function / operability where appropriate.
Special, Test Procedures (STPs) reflect the SSR and the test ,
J requirements and acceptance criteria will demonstrate system / component function.
Operating procedures are consistent with system design and function and clearly address all system operating modes.
Maintenance procedures are implemented that address vendor requirements, equipment qualification requirements and industry standards.
Training plans and the depth of training is consistent with complexity of applicable tasks.
EASRTP teams will conduct the evaluation utilizing the information provided in the EASRPT METHODOLOGY GUIDELINES.
1 Evaluation Plan Page 1 {
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. ,,,.37 u w, va 2.2 Systems, g The following systems are included in the program:. .j
. i g-Power Systems: Acronym 1
- Emergency Diesel Generator Syst m EGS
- 125 Volt DC Vital Power System 125V
- 120' Volt AC Vital Power System 120V 1
- 480 Volt AC Distribution System' 480V' -l
- 4160 Volt AC Distribution System 4160V and the 6900 Volt AC Distribution System 6900V ,
Steam Plant Systems: ,
- Auxiliary Feeds ter System AFW
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- Auxiliary Steam System ASC '
- Main Steam System MSS
-Control Systems:
- Emergency Feedwater. Initiation EFIC and Control System
- Integrated Control System ICS
- Non-Nuclear Instrumentation NNI
- Reactor Protection System RPS
- Safety. Features Actuation System SFS Reactor Plant Systems: l
- Decay Heat Removal System DHS l
- Purification and Letdown System PLS l'
- Reactor Coolant System and RCS Once Through Steam Generators OTSGS
- Seal Injection and Makeup System SIM
- Reactor Sampling System RSS Auxiliary Systems:
- Component Cooling Water CCW
- Fire Protection System FPS
- Instrument Air System / Service Air System IAS/SAS
- Nuclear Service Raw Water System NRW
- Nuclear Service Cooling Water System NSW Heating, Ventilating, and Air Conditioning (HVAC) Systems:
- Control Room / Technical Support Center CR/TSC HVAC System
- Nuclear Service Electrical Building NSEB Essential HVAC System
- Reactor Building Atmospheric System RHYS
- Radiation Monitoring System RDM
- Hydrogen Recombiners None Evaluation Plan Page 2
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y3 y g,,zy .,..,+.ygy,'(. g y 2;3 Program Organization 2.3.1 Evaluation Organization EASRTP will be under the overall direction and cognizance of the Director of Technical Services.
The evaluation project will be comprised of six teams under the
. supervision of a Program Manager (See Figure 2.1). Each team will be under the guidance of a Team Leader. Each team will be assigned a group of systems to be evaluated consistent with the above' identified groupings.
9 Typical Evaluation Team:
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. Team Leader-Mechanical Engineer * ,
IaC Engineer
- Electrical Engineer
- Operations Representative Maintenance Representative System Engineer (For the system evaluation)
Quality Department Representative (Limited basis)
- ' Discipline engineers on the team are dependent on the system being l evaluated. Each fluid system will have at least an electrical and mechanical design engineer.
The Team Leader is responsible for the overall guidance of the team -to ensure consistency of approach and conformance to the Evaluation Plan.
Engineering representation on the team is primarily responsible for evaluating the engineering and design aspects of the system as outlined 2.4.1.
The System Engineer will assist other team members and will provide information regarding system status. He is primarily responsible for reviewing testing activities as discussed in 2.4.2.
The Operations representative on.the team is primarily responsible for the operation and testing activities as discussed in 2.4.3.
Maintenance representation on the team is primarily responsible for evaluating those areas outlined in 2.4.4.
Evaluation Plan Page 3 L n- __
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TM The alit Department'will-' provide a group of approximately three indi idual ~ to aid each Team 1.eader by providing Quality Department-
- @_ information with respect to its responsibilities on the selectmi' system. . The Quality Department members will report to the. Program Manager and the_ Quality Manager.
Administrative aides will be assigned to the project to assist in retrieving documents and maintaining a. computerized tracking system of information requests / identified concerns.
2.3.2 Support Organization Each department'will assign a coordinator to serve'as the key interface for EASRTP. team members. Functions of the coordinator will ir.clude directing team members to appropriate points of contacts for specific questions, providing requested information, arranging ' interviews, and tracking Requests For?Information (RIs). . All team members will-coordinate their ectivities throuah the respective department coordinator. The coordinator will also be responsible for keeping his direct supervisor informed of the EASRTP impact.
2.4 h ope and Approach by Subject ~ Area 2.4.1 Engineering & Design
.The engineering".and design review portion will assess the-technical adequacy of the design and numerous design modifications ,
associated with each of the selected systems. The review will concentrate on functionality but will also consider items such as components and material selections and design conditions and transients.
The team members evaluating this area should also consider during l their review of design basis documents (including calculations):
- Electrical and mechanical equipment qualification.
- Class IE controls and electrical system and electrical system analysis, i
l 2.4.2 , System Engineer The systems engineer and operations evaluator will check that the testing performed on the selected safety system demonstrates that the system will perform its function under an appropriate range of conditions.
Evaluation Plan Page 5
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The testing evaluation will be performed by reviewing selected.
test procedures. The test procedures and data will be compared to g the fuactional requirements of the system. A comparison should be a,; made to' determine if:
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The system function is ~ demonstrated by testing, by normal operation, or by a combination of operation _ and. testing.
The combination of inservice and surveillance testing veriffes that system components required to meet their safety-related functions are . tested.under an appropriate range of conditions.
Test measurements correlate to the accuracy required to ensure j that functional design requirements.are verified. -
Test acceptance criteria are consistent with design i requirements and _ test procedure steps are sufficient to show -l
.that the tested system or ccaponent will meet acceptance j criteria.
' The system is restored to a fully operational mode upon test completion ~or test results are evaluated for any later changes.
2.4.3 Operations-The operations team member will assess if operators can perform the necessary activities to ensure the system fulfills its safety functions. This determination will be made by sampling the adequacy of the instructions available to the operators, the training material, and the availability of system status information, such as instrumentation and alarms and documents, at the time operator action is required.
'The assessment of the operating instructions will consist I primarily of a review of the system operating "A" procedures, alarm response procedures and standing orders which affect the system. The procedures should be checked for adequacy, completeness, and consistency with system design values, l.imits and precautions will be evaluated by the System Engineer. The review should also assess the impact'of applicable modifications on operators ability to perform required functions. The operator training program lesson plant and course materials will be i reviewed for the selected sr., tem. The review will examine the level of detail the operators are provided in the system design, safety functions and operation methods.
The evaluation will also assess the availability of essential system status information to the operator. This status information includes system flows, pressures, temperatures, alarms, etc., which are required for initiation of operator responses, actions and decisions. This assessment will be accomplished by reviewing design documents, inspecting the control room area and interviewing operating personnel. Particular attention will be given to the availability of the system status information at the time when the system safety function will be required. The review will also similarly include the Remote Shutdown Panel.
Evaluation Plan Page 6 l - __---- ----___ _ -- _ _
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In addition to the above review, modification and post maintenance
' testing will be reviewed to determine if appropriate testing
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&7 2.4.4 Maintenance The objective of the maintenance team member is to check that the maintenance performed on the system is adequate to ensure the system ftnctions on demand.-
The evaluation will check the performance of maintenance as it relates to maintaining the functional capability of the system. ,
Additionally, the plant material deficiency identification and ,
work control system will be checked by the maintenance evaluator.
However, the team members will contribute input. Team members will assess physical conditions observed during system walkdowns, review of applicable documents and through interviews with selected personnel.
Physical conditions will be determined through observation and '
should be supported by the review of documentation such as machinery history records, failure reports and maintenance work I requests.- This effort will provide information associated with the adequacy level of system / equipment maintenance. The _
system / equipment observation considered in the assessment include, but are not lin.ited to the following:
- Leakage / general conditions
- Cleanliness / labeling
- Accessibility for operation
- Accessibility for maintenance
- Environmental conditions where equipment is located Calibration Documents will be assessed through review of maintenance procedures and guidelines which affect selected components within the system. Examples ;
include: 1 1
Preventive Maintenance Corrective Maintenance i
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Maintenance Procedures Maintenance Training Maintenance History Maintaining Equipment Qualification .
Evaluation Plan Page 7 I
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As 'in all areas,' interviews with's' elected peEsonnel will be conduct &to"*
check that instructions are adequately understood an<. consistently implemented.
E 2.4.5 Quality Department The Quality Department Manager will periodically have a review conducted of the EASRTP to:
' Monitor the effort for conformance to the Evaluation Plan Review completeness of documented results 3.0 SCHEDULE' The overall schedule for performance of the program is depicted on Figure 3.1. The schedule and sequence for performing the evaluations is i shown on Figure 5.1.
As indicated on Figure 3.1 and Figure 5.1, six systems.will be evaluated concurrently as a set. Each team will prepare and issue a report after the first set of six systems have been reviewed.
"After completion of review of the second set of six systems has been completed and a report prepared, the Director of Technical Services and the Project Manager will evaluate: the results to date, progress, and the effectiveness of the evaluation process . Based on this evaluation, the Evaluation Plan, scope, approach, conduct, and schedule will be modified if appropriate. ,
L 4.0 PREPARATION .,
4.1 Preliminary Preparation Action items included:
Finalize team members
- Provide work areas for Project
- Issue Evaluation Plan
- Develop Team Methodology Guidelines j
- Accumulate Design Baseline' Information and Other Key Documents EXAMPLES:
- Bechtel System Descriptions / System Specs.
Evaluation Plan Page 8
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- Updated Safety Analysis Report (USAR)
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- Technical Specifications
- Applicable Bechtel and B&W Technical Procedures
- Listings of ECNs sorted by System
- Material Equipment List (MEL) f
- Test Program Administrative Procedures & QCI-12 Surveillance Procedures (SPs)
'* Maintenance Test Procedures Maintenance Procedures
- Nuclear Engineering Procedures (NEPs)
- Other pertinent Administrative Procedures
- Test Outlines, Special Test Procedures
- Training Material (lesson plans, etc. for operators and maintenance technicians)
- Assemble "As-Built" Documentation: (System Engineer)
- Drawings Diagrams
- Concerns developed from NRC ASRTP (Attachments 3 and 4)
- Quality Department Vertical Audit concerns (Attachment 5)
Unincorporated DCNs
- Establish computer tracking system for RIs
- Arrange for badging, HP Training, etc.
- Familiarization review of key documents Evaluation Plan Page 10
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- - Identify and.obtain' additional material needed 'for .
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Identify and request material needed during conduct of evaluation
- Develop any modifications to Evaluation Plan i
- Review and approve final Evaluation Plan and methodology 4.2 Team Preparation
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Indoctrination and orientation of. team members included: (When possible and as needed)
- Purpose, scope, approach, conduct, preparation, documentation, communication, reporting 1
- Requirements of administrative, safety, security procedures
- Overview of organization and applicable procedures, l
. including hierarchy 1
- Plant familiarization walkdown ,
- ASRTP Process Training -
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- Review and understani the verification and review programs and '
activities ongoing at Rancho Seco as outlined in Attachment 2.
- Review and understand the type of concerns identified as a result of the NRC ASRTP Inspection, NRC SSFIs and the Rancho Seco Quality Department Vertical Audit (See attachments 3, 4 and 5).
l 5.0 CONDUCT 1
The review of systems will follow the sequence and schedule shown 4
on Figure 5.1.
During the evaluation, team members will identify the documents reviewed and document, in detail, the results of the review. Any supporting documentation and notes will be included.
The team will inform the affected organization of potential concerns using Request for Information (RI) forms as per Attachment 1. RIs are primarily used by the team members to express potential concerns or to cbtain information not readily available. The affected organizations are expected to either respond with the requested information or with information either agreeing or disagreeing with the concern.
Evaluation Plan Page 11
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The de artment coordinator is responsible for receivin and tracki g RIs for his department. An RI Data System wi 1 be f
maintained by EASRTP for the Quality Department to track and I
account for all written communications. The Team Leader must
' initial each RI prior to it being sent to coordinators. All l
returned RIs must be reviewed by the Team Leader.
6.0 REPORTING The report will describe the purpose, scope, approach and results of the evaluation. The report will also identify the resolution status of each concern identified with an RI. The team does not judge the adequacy of corrective actions with respect to acknowledged concerns.
The report will generally follow the outline below:
- 1. Introduction
- 2. Purpose
- 3. Scope
- 4. Overall Results and Conclusions i 5. Detailed Observations l 6. Status of RIs (open, acknowledged, closed) 7.0 RESOLUTION OF CONCERNS The RIs generated during the evaluation will also be used as a tracking tool for the resolution of concerns. The RI will be closed if requested information is provided or information is provided that convinces the team leader the concern is not valid.
The RI will remain "open" unless corrective action is completed or ,
until the concern and defined corrective action is entered by the responsible department into a formal tracking mechanism (tracking number assigned) such as QTS or CCTS and assigned a priority / completion date consistent with the significance of the concern.
Evaluation Plan Page 13 w__ _ ___ __ ___-__ _____-_____ ._.______ _ __ ____ _ _____ _
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ATTACHMENT NO. 1 l To Evaluation Plan ,
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HANDLING OF REQUESTS FOR INFORMATION (RIs)
I Generation of RIs (
j concerns or to request An RI can be generated to identifyAn RI should be initiated for one more of the information.
following cases:
- 1. To identify a potential technical concern.
or
- 2. To' identify a significant program aspect or practice that is, appears to be, incorrect or inadequate.
3.
Information has been verbally requested but cannot be readily obtained.
l 4.
When it is deemed appropriate to document the proposed actions to correct discrepancies and prevent recurrence.
It is generally not necessary.to generate an RI if'a. minor >
discrepancy is observed and the discrepancy appears if deemed necessary to be to )
random. (An RI could be used, however, track correction of the discrepancy)., Several minor l discrepancies could warrant issue of an RI. !
NOTE: The Team Leader or program Manager will make the final decision of when an RI is to be processed.
PROCESSING OF RIs
- 1. Team member completes (except for date and serial number) first page of RI form (the serial number and date will be added after team leader review and just prior to issue).
provide RI to Team Leader for reiew. The Team Leader 2.
will initial the RI to indicate that RI is ready for issue.
- 3. The RI will be entered into the RI Data System and numbered.
- 4. Reproduce two copies of the RI. The original is to be l supplied to the appropriate department coordinator of the RIvia the appropriate System Engineer. TheOne second copy is to copy is l l
to be filed in the RI binders.
be provided to the originating team member. The issue l date will be logged in the RI Data System by EASRTP clerke.
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- 5. . Originating team member, Quality Department Team j"', Member, and Team Leade.r will evaluate the response and i
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document the. evaluation.on the response evaluation portion _of the original'RI inLthe.RI binder. The '
results;of the evaluation will be entered into'the RI Data System..
- 6. If the response does not provide adequate.information-or disagrees with.the concerns, a follow-up RI may be-initiated by the team member.
7..' Revised or supplemental.. responses'ae to be handled as ,
'in 6 above..
'8. .An RI'becomes closed when the information. requested is j provided, Lor if supplied information alleviates the. <
stated concern. 1 9.. Open'RI's'are enteredonto'the' Restart Scope list:
(RSL) Data' Entry Forms-and.provided'to the RSL Project Manager. ;
- 10. RIs shall.be retained as part.of the supporting documentation to the' evaluation.
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,' Provide any specific information requested or any information that J'J could alleviate a potential concern.
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.*. RESPONSE. Use supplemental sheets as necessary.
i If a valid concern / discrepancy exists, indicate proposed corrective. {
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,' N OPERATIONAL READINESS VERIFICATION AND REVIEW PROGRAM 5 Technical Specification Compliance Verification Program The purpose of this program is to verify, prior. to restart, and on a continuing basis aftsr restart, that procedures' are in place to implement all requirements of the Technical Specifications. The tool
.used in this program is a data base that cross-references each requirement of the Technical Specification to the implementing procedure (s). Approximately 985 of the requirements of the Technical i Specifications have been reviewed since the program started in February, j 1987. Several procedural deficiencies have been identified by this progran and are in'the process of correction.
Design Calculation Review Program A comprehensive formal program was established in March, 1987 covering the review of existing calculations.
The technical programmatic concerns with calculations identified in the NRC ASTRP Inspection are considered in tl.e review. The program also addresses the determination of the av.ilchility of calculations to support design aspects reflected h plant modifications.
The program concentrates on calculations and design aspects associated !
with recent design activities most critical to plant restart. However, earlier calculations are included in the review when the calculation (s) o is usad as the basis of reference in recent calculations or'to verify that the earlier calculation was c.orrectly revised to reflect a recent modification.
The review portion of the ' program is essentially complete. Corrective action plans are now being established to resolve the observations resulting from the review.
B&W Evaluation of System Configuration and Restart Test Program The purpose of the B&W Evaluation is to determine:
- System functions defined in SSR are consistent with design basis documents.
- The as-built, maintained and operated system is capable of performing each required function.
- The test program as planned, inicuding 5"P, SP, PM, PMTs, MOVATS is adequate to confirm the ability of each system to perform the defined function.
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' OPERATIONAL READINESS VERIFICATION AND REVIEW PROGRAM i
- Check valves which if inoperative or malfunctioning could
-cause water hanner, steam binding or overpressurization, or those with possible partial open operating position or high energy closure. This identification is for inspection / maintenance prior .to restart.
Systems in Scope: AFW, ICS, PLS, MFW, NNI RCS, MSS, RPS, SIM, OTSG SFAS, EFIC, DHS.
MAINTENANCE TRENDING Currently the trending program for the Maintenance combines both failure trending and data trending. This is accomplished through the implementation of MAP 0009, " Preventative Maintenance Program" which replaces AP.650. Within this procedure, failure trending is performed quarterly by the PM Supervisors utilizing NUCLEIS in which equipment exhibiting the greatest amount of correctivo maintenance activity are !
analyzed for special attention and program changes. Data trending is also reviewed quartely by the PM Supervisors. Specific vibration trending is perfonned and tracked in all category rotating equipment and represented graphically in accordance with M-159 " Vibration Monitoring Manual".
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Page 3 of 6-
, OPERATIONAL READINESS VERIFICATION AND REVIEW PROGRAM PREVENTATIVE MAINTENANCE (PM) UPCRADE.
PM upgrade will involve looking at all Category 1 & 2 equipment.
identified in MAP 0009 for the 33 systems. These identified pieces of equpment should then be matched against the following: !
- Existing PM tasks performed since 12/85 l
- Corrective or Planned maintenance performed since 12/85
- Surveillance Performed
- Special test of Systems test performed In each case where an activity has been performed its results should be
. measured against the standard called for in MAP 0009 for adequacy.
If no activity has been performed, it should be balanced against scheduled activities and determined if action before restart is adequate.
As a parallel activity the requirements for each activity either existing or planned will be measured against vendor recommendations whera appitcable. This will result in program updates and procedural revisions where required.
These activites will than be evaluated for criticality prior to restart and then scheduled for performance. As a priority, category 1 equipment will be evaluated first.
One other parallel task will be the inputt,ing of all preventive and corrective maintenance activities performed since 12/85 from MIMS into NUCLEIS.
STS/SSRTRUE-UP Reveiw assigned QTS items (C0Y-10 Report) for consistency with corresponding SSR/SSR statements. Correct both,. if necessary, to provide direct correspondence as well as a clear problem state.wnt and resolution which is precise and unambiguous.
REVIEW OF .0 PEN WORK REQUESTS See AP.93, 6.2.2, and QCI-12, 6.2.4. Review shall ensure that open items do not restrain system operability.
REVIEW 0F OPEN ECNs l
See AP.93, 6.2.3. ECN review should follow the same criteria as for open Work Roquest reviews. Review shall ensure that open items do not restrain system operability.
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OPERATIONAL READINESS' VERIFICATION AND REVIEW PROGRAM REVIEW 0F ODEN NCRs NCR review will be performed to determine.if completed or ongoing Work
~ Requests or ECNs are affected. .If no further physical changes are
- requried to close the' NCR, no further action is necessary as part' of this review. If changes' are required, the affected ECN or1WR becomes an .
l open item against system completion and readiness for ' operation.
Review shall ensure that open items do not restrain system operability. I
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REVIEW 0F DAVIS-BESSE SRTP See AP.93, 6.2.6. Problems.resulting from this review w'll i be processed in accordance with QCI-12 ar.d AP.93.
CONDUCT SYSTEM WALXDOWNS See AP.93, 6. 2.8. Note: Ap.97 does not exist.: Refer to SYSTEM WALKDOWN GUIDELINE. Review shall ensure that open items do not restrain system operability.-
REVIEW 0F OPEN ABNORMA. TAGS See AP.93, 6.2.5, and AP.26, 5.6 (requires monthly review by group supervisors of abnormal tag reports for each shop.). Abnormal Tags will
.be converted to ECNs or NCRs as appropriate.-
i SYSTEM FUNCTIONAL TESTING System Functional Testing will be performed to verify select system performance. Acceptance Crtieria will be derived from system status report functions described in accordance with AP.93, 6.3.
f REVIEW 0F LILENSING OPEN ITEMS - LICENSING Review open items (CCTS) to determine the following:
- a. Has work commenced to satisfy an outstanding commitment? Is it scheduled?
- b. Has an outstanding commitment been assigned to an implementing organization?
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OPERATIONAL READINESS VERIFICATION AND REVIEW PROGRAM l
- c. If completed, has an open item been documented for closure?'
-d. Does any remtining open item restrain system operability?
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l CONDUCT SURVEILLANCE PROCEDURE TECHNICAL REVIEW Ths review h performed in accordance with the multidiscipline review in i AP.2 via the Test Working Group (AP.96). All restart SPs will be l reviewed regardless c5 status.
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, 0PERATIONAL READINESS VERIFICATION AND REVIEW PROGRAM ;
L CONDUCT SYSTEM WALKDOWNS A. Walkdowns will be performed in accordance with AP.73 (System, Print, Valve Lineup Verification Program). !
1 B. System walkdowns will compare P & ids, actual plant configuration !
and procedure valve lineups. l C. Check and doc' a nt complete proper component labeling. The guidelines in AP.23 will be followed.
i D. Review and document systems / component accessibility problems.
SUPPORT THE REVIEW OF OPERATOR TRAINING l A. Work with the Training Department to verify completeness of Operator Modification Training, Program. l B. Work with the Training Department to verify the completion of i required Operator Training as a result of the December 26. 1985 >
incident.(i.e.) Operator Training on special valve operations.
CONDUCT OPERATING PROCEDURE REVIEW A. Complete a procedure walkdown of each identified system. This will include the following types of procedures:
- 1) Operating procedures
- 2) Surveillance procedures :
- 3) Annunciator procedures B. The above walkdown will verify the procedure works and the enclosure reflect current plant configuration.
C. This. verification will not include values provided in limit and '
precautions (should be performed by the System Engineer).
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J h' ASRTP Inspection Response Scope l ASRTP IR Item i Associated QTS f I (ASRTP Report Reference) Sumary Item Description ' (QCI-12 Priority) j i
Item 86-41-01 Resolve P-318 motor overspeed concerns 26.1069 (Section 3.1.1(1)) (AFW SSR Problem f61), (1 ) .
Item 86-41-01 Perform appropriate testing to - 26.0608 -
(Section 3.1.1(2)) evaluate need for procedural caution. (1) against quick restarting of AFWPT (AFW SSR Problem #31).
- 26.0957 !
Item 86-41-02 Install flow limiting verturis to (Section 3.1.1(3)) prev 6nt excessive AFW flow to OTSGs (1)
(AFW SSR Problem #54, ECN f R-1672/,).
Itan 86-41-03 Modify AFW Full Flow Test Line to
- 26.0120 (Section 3.1.1(4)) provide for accurate surveillance (1) testing (AFW SSR Problem 3, ECH f R-1188).
Item 86-41-04 Evaluate AFW Pump Runout effects due 15.0282 (Section 3.1.1(5)) 12/26/85 event (AFW SSR Problem #43). (1)
Item 86-41-04 Evaluate the effects of cumulativa 26.1064 (Section 3.1.1(5)) AFW Pump runout (AFW SSR Problem #56). (2R)
)
Item 86-41-04 Evaluate the potential for AFW Pump 26.1081 l (Section 3.1.1(5)) runout following installation of EFIC (2R) I and flow limiting venturis (AFW SSR Problem f66).
Item 86-41-05 Verify accuracy of AFW Pump Per- 26.1084 (Section 3.1.1(6)) fomance Calculation 2-FWS-M2081 (1)
(AFW SSR Problem (55).
Item 86-41-06 Assure adequate overpressure pro- 26.1087 (Section 3.1.2(1)) tection for main and startup feed- (2R) wrter control valve actuators.
Item 86-41-06 Document seismic qualification of 26.1088 (Section 3.1.2(2)) safety related valves in backup air (1) supplies for EFIC modifications.
Item 86-41-06 Replace excess flow check valves in 26.1089 (Section 3.1.2(3aab)) backup air supplies. (1)
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.ASRTP IR Item # Associated QTS f (QCI-12 Priority)
'(ASRTP Report Reference) Sumary Itan Description
-Item 86-41-06 Establish operating procedures to moni- 26.1090 l
-(Section 3.1.2(3c)) tor backup bottle _ pressure and initiate' (2R) l appropdate actions if leakage is indi-cated.
Item 86-41-06 Establish periodic test procedures to 26.1091 (Section '3.1.2(3d)) functionally. verify the bottle backup (2R) air systems.
Item 86-41-06 Resolve concerns that pressure control 26.1092 i (Section 3.1.2(4)) valves for EFIC backup air system may (2R)- {
not be appropriate design application. 1 Itam 86-41-06. Verify accuracy of fabrication drawings- 26.1093 (Section 3.1.2(5)) for EFIC backup air ' supplies. (1 ) -
Item 86-41-07 Resolve FWS SSR Problem #6 relating to 20.0043 (Section 3.1.3)- faulty WP Lovejoy Control Response' (2R)
(Implement ECN #R-0717).
Item 86-41-07 Resolv'e FWS SSR Problem #9 relating to. 20.0143 (Section 3.1.3) sticking of WW Startup Control Valves. (3)'
Item 86-41-07 Resolve FWS SSR Problem #12 relating to 20.0188 (Section 3.1.3) MFW control valve positioning during (2k) transients.
l Item 86-41-07 Resolve FWS SSR Problem #18 relating to 22.0330 (Section 3.1.3) Casualty Procedure C.26 enhancements. (2R)
Item 86-41-07 Resolve FWS SSR Problem fl9 relating to 22.0453
'(Section 3.1.3) Casualty Procedure C.10 enhancements. (2R)
Item 86-41-07 Resolve FWS SSR Problem #22 updating 22.0688 (Section 3.1.3) Pa!D M-580, Sheet 1. (2R)
Item 86-41-07 Resolve FWS SSR Problem #31 relating to 26.0132 (Section 3.1.3) WP control transfer circuitry. (3) l Item 86-41-07 Resolve FWS SSR Problem #45 relating to 26.0518 (Section 3.1.3) WP governor resrese (Implement ECN (2R)
R-0717).
- Committed to in 2/12/87 ASRTP Inspection Exit Interview
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(MMTP Report Reference) Summary Item Description- . (QCI-12 Priority)
Itan 86-41-08 Document environmental qualification of. 26.1086 (Section 3.1.4(1)) excess flow check valves installed in (1).
EFIC sensing lines.
Itea 86-41-09 Revise and resubmit EFIC Safety Analysis. 25.1061 (Section 3.1.4(2)) to more clearly reflect EFIC sensing : (1):
line design.
Itan 86-41 Document evaluation of acceptability of-~ 26.1085-(Section 3.1.4(2)) operational procedures and training for (2R) response to EFIC sensing -line failures.
Item 86-41 Incorporate appropriate provisions to 26.1098 .i (Section 3.1.4(3)) fully test the EFIC maintenance bypass (1) feature.
Item 86-41-11 Resolve 125 VDC System SSR Problem #8
- 26.0218 ,
(Section 3.1.5(1)) relating to Procedure A.61 enhancements. (2R) j Item 86-41-11 Resolve 125 VDC System SSR Problem #9
- 26.0219
. (Section 3.1.5(2)) . relating to maintaining battery room (2R) temperatures within design temperature limits.
Item 86-41-11' Resolve 125 VDC System SSR Problem #20
- 26.0987 (Section 3.1.5(3)) relating to refurbishment of six AB (2R) battery chargers.
Its 86-41-11 Resolve 125 VDC Systen SSR Problem #22
- 26.0989 (Section 3.1.5(4)) relating to open NCRs on deformed (2R) battery terminal posts.
Item 86-41-12 Resolve 120 VAC System SSR Problem #7
- 26.0353 (Section 3.1.6(1)) updating the IEB 79-27 study to include (1) all changes to the 120 VAC vital buses. ;
Implement the reconimendations of the IEB 79-27 study.
Item 86-41-12 Address 120 VAC System SSR Problem #2
- 22.0384 (Section 3.1.6(1)) relating to rR annunciation of feeder (3R) breaker trips. An overview study will be done to provide a resolution of identified concerns.
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- Committed to in 2/12/87 ASRTP Inspection Exit Interview f
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ASRTP IR Item i Associated QTS f (ASRTP Report Reference) Summary item Description (QCI-12 Priority)
Item 86-41-12 Resolve 120 VAC System SSR Problem f 5
- 26.0266 (Section 3.1.6(1)) relating to casualty procedures for (2R) !
loss of 120 VAC vital buses. ;
Item 86-41-12 Resolve 120 VAC System SSR Problem f6
- 22.0345 (Section 3.1.6(2)) relating to Operating Procedure A.62 (2R)-
enhancements.
Item 86-41-12 Address 120 VAC System SSR Problem #12
- 26.0356 (Section 3.1.6(3)) relating to local indication of 120 VAC (2R) i breaker status. An overview study will be done to provide a resolution of identified concerns.
Item 86-41-13 Address 480 VAC System SSR Problem #10
- 22.0037 (Section 3.1.7(1)) relating to study of need for alarming (2R) loss of power at the MCC level. An overview study will be done to provide a resolution of identified concerns.
Item 86-41-13 Resolve 480 YAC System SSR Problem #11
- 26.0298 (Section 3.1.7(2)) relating to casualty procedures (2R) enhancements. 1 Item 86-41-13 Address 480 VAC System SSR Problem #16
- 26.0300 (Section 3.1.7(3)) relating to poor local indication of (2R) certain Westinghouse MCCs. An over-view study will be done to provide a resolution of identified concerns.
Item 86-41-13 Resolve 480 VAC System SSR Problems #25,
- 26.0520 (Section 3.1.7(4)) 33 and 34 relating to Operating Pro- /2) cedure A.59 enhancements.
- 26.0526 (2)
- 26.0477 (2)
Item 86-41-13 Resolve 480 VAC Syctem SSR Problem #46
- 22.0700 (Section 3.1.7(5)) relating to a discrepancy identified in (2R) drawing E-108, Sheet 30.
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- Committed to in 2f12/87 ASRTP Inspection Exit Interview
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Item 66-41-13 Address 480 VAC System SSR Problem #26
- 26.0521 (Section 3.1.7(6)) providing local indication monitoring (3R) control power on all applicable 480 V switchgear breakers. An overview study will be done to provide a resolution of identified concerns.
Item 86-41-13 Address 480 VAC System SSR Problem fl9
- 26.0338 (Section 3.1.7(7)) relating to review and documentation of (2R) {
480 VAC System breaker annunciation. j An overview study will be done to pro- l vide a resolution of identified concerns.
Item 86-41-14 Resolve 4160 VAC System SSR Problem #8
- 21.0248 (Section 3.1.8(1)) relating to slotting of protective (2R) relays in the switchgear.
Item 86-41-14 Resolve 4160 VAC System SSR Problem #25
- 22.0387 (Section 3.1.8(2)) relating to procedural enhancements for (2R) monitoring DC control power to switchgear breakers.
Item 86 41-14 Resolve 4160 VAC System SSR Problem f32
- 26.0965 (Section 3.1.8(3)) relating to Operating Procedure A 54 (2R) enhancements.
Item 86-41-14 Resolve 4160 VAC System SSR Problem f33
- 26.0966 (Section 3.1.8(4)) relating to Casualty Procedure C.143 (2R) enhancements.
Item 86-41-15 Document usurance that CST relief valve 26.1083 l (Section 3.2.1(2a)) setpoints are appropriate to maintain (1) the structural integrity of the tank
( AFW SSR Problem #68).
Item 86-41-15 Document assurance that CST vacuum 26.1065 (Saction 3.2.1(2b)) breaker protection is appropriate to (1) maintain the structural integrity of the tank (AFW SSR Problem f57).
- Committed to in 2/12/87 ASRTP Inspection Exit Interview
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ASRTP Inspection Response Scope i ASRTP IR Item # Associated QTS f 4 (ASRTP Report Reference) Summary Item Description (QCI-12 Priority)_ l Iten 86-41-16 Revise de short circuit calculation 26.1099 (Section 3.2.2(1)) Z-DCS-E0612 to provide accurate (1) references for the short circuit capability of the new, auxiliary building batteries.
It s 86-41-17 Revise NSEB battery sizing calculation 26.1100 (Section 3.2.2(2)) Z-DCS-E0636 to address identified con- (1) cerns.
Revise voltage regulation calculation 26.1103 Item 86-41-18 .j (Section 3.2.2(3)) Z-EDS-E0076 to address identified (1) concerns.-
Item 86-41-19 Revise short circuit calculation 26.1102 (Section 3.2.2(4)) Z-EDS-E0120 to address identified (1)
Concerns.
Document etapliance to USAR Section 26.1101 Item 86-41-20 (Section 3.2.2(5)) 8.2.2.11.H.11 for power cable between (2R) battery charger H4B.AC and de Bus SOA.
Item 86-41-21 Provide appropriate IDADS alarming of 26.1057 (Section 3.2.2(6a)) the 125 VDC system. (2)
Provide appropriate IDADS alarming of 25.0179 Iten 86-41-21 ,
AFW pump runout. (2R) !
(Section 3.2.2(6b))
Evaluate the need for thermal overload 25.0183 Item 86-41 (Section 3.2.2(7)) protection or overload alarms for (3) safety-related motor operated valves.
Issue revised procedure governing the 25.0162 j Item 86-41-23 performance of safety evaluations. (2R) l (Section 3.3.2)
I Issue revised procedures for site 25.0163 Item 86-41-24 drawing control. (1)
(Section 3.3.3)
Conduct QA audit of SDC activities to 25.0164 Itsa 86-41-24 (2R)
(Section 3.3.3) assure compliance with approved procedures.
- Committed to ir. 2/12/87 ASRTP Inspection Exit Interview
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ASRTP Inspection Response Scope ASRTP IR Item i Associated QTS f (ASRTP Report Reference) Summary Item Descrips. ion (QCI-12 Priority)_
Iten' 86-41-25 Submit to an evaluation of engineering 25.0092 (Section 3.3.4) calculation practices by an independent (2R) calculation review team.
Item 86-41-25 Review study files to assure formal 25.0093 (Section 3.3.4) . calculations have been prepared where (1) appropriat( .
Item 86-41-25 Remove obsolete engineering calculations. 25.0094 (Section 3.3.4) (3)
Item 86-41-25 Correct identified calculational 25.0095 (Section 3.3.4) deficiencies. (2)
Item 86-41-25 Develop Good Practices Document for 25.0096 (Section 3.3.4) preparation of engineering calculations. (2)
Item 86-41-25 Implement improved ECN closure process. 25.0098 (Section 3.3.4) (2)
J Item 86-41-25 Evaluate need for " Preliminary Calcu- 25.0111 (Section 3.3.4) lation" designation. (3)
Item 86-41-26 Submit revised IST program for NRC 25.0119 (Section 3.4.1(1)) approval. (1)
I Item 86-41-27 Implement trending program for pump 25.0116 (Section 3.4.1(2)) and valve test data. (2)
Iten 86-41-28 Document basis for AFW minimum recircu-
- 26.1095 (Section 3.4.2(la)) latiort flow valve of 50 gpm. (1)
Item 86-41-28 Establish procedure for calibration of 26.1082 (Section 3.4.2(1b)) CST level instrument LIT 35803. (1)
Item 86-41-29 Reestablish acceptable criteria for 26.1080 (Section 3.4.2(2)) strokt. times of AFW control valves in (2R) accordance with ASME Section XI Article IWV requirements.
Item 86-41-30 Revise SP 210.01A to check the backseat 26.1079 .
(Section 3.4.2(3a)) of AFW pump discharge check valve (1)
FWS-048 ( AFW SSR Problem f64).
- Committed to in 2/12/87 ASRTP Inspection Exit Interview
-7 -
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i 1
'ASRTP Inspection' Response Scope ASRTP IR Item f- Associated QTS #
. (ASRTP Report Reference): Summary Item Description (QCI-12 Priority)
Item.86-41 Revise SP 210.01A and 210.01B 26.1097
-(Section 3.4.2(3b)) to .specify fixed locations for. '(1) bearing temperature measurements of
-the AFW pumps.
..1 Itan'86-41-30 Revise Surveillance Procedures to- '25.0180
- (Section '3.4.2(3c)) specify ALERT and ACTION ranges for (2R) differential pressures and pump flows.
-Item 86-41-31 Evaluate adequacy of ventilation design 25.0106 .
(Section 3.4.4(1)) to maintain NSEB and AB batteries within (2R) l the required design temperature ranges.
Item 86-41-31 Revise battery surveillance procedures 25.0130 (Section 3.4.4(2)) to adequately address electrolyte level, (1) specific gravity and room ambient temperature.
Item 86-41-31' Review adequacy of electrical maintenance 25.0134 (Section 3.4.4(3)) surveillance procedures. (2)
_ Item 86-41-32 . Implement policy emphasizing operator 25.0165 .
. (Section 3.5.1) attention to detail. (2R) !
Item 86-41-33 Provide appropriate procedural response- 25.0178 ,
for P-318 turbine overspeed alarm.
(Section 3.5.2(1)) (2R)-
Item 86-41-33 Establish AFW pump motor start time 26.0067 (Section 3.5.2(2)) limitations (AFW SSR Problem #20). (1)
Item 86-41o34 Evaluate the adequacy of operator 26.1066 (Section 3.5.3) procedures and training for AFL' (2R) pump runout alarm response. ;
Item 86-41-35 Establish and implement program to 25.0167 (Section 3.5.4(1)) control system training manuals. (2)
Item 86-41-35 Establish policy statement that 25.0166 (Section 3.5.4(2)) endorses proper training for major (2)
' revisions to critical Operating Procedures.
Item 86-41-36 Issue Procedure M.115 for Dings brake 25.0132 (Section 3.6.2(1)) maintenance. (1)'
- Committed to in 2/12/87 ASRTP Inspection Exit Interview
-8 -
. m u.w m., . - su - ,. ., n, _, - . , . , . a , ,, , . .:. , ,,4 1 ASRTP Inspection Response Scope ASRTP'IR" Item i Associated QTS f (ASRTP Report Reference) Summary Item Description (QCI-12 Priority)' ;
Item 86-41-36 Establish Procedures for Air Operated 25.0131 (Section 3.6.2(2)) Valve Maintenance. (1)
Item 86-41-37. Implement trending analysis program 25.0168 '
(Section 3.6.3(1)) for preventative maintenance data. (3)
Item 86-41-38 Implement procedural changes in the 25.0169 (Section 3.7.1) QA Audit Program to: address identified (2)
. Concerns.
Item-86-41-39 Implement procedural changes in the QA. 25.0170-(Section 3.7.'2) Surveillance Program to address identi- (2) fied concerns.
Item 86-41-40 Issue procedure for compliance with 25.0138 j (Section 3.7.3(1)) 10 CFR 50, Appendix B, Criterion XVI.
(1) a
. Item 86-41-40 Implement procedural improvements in 25.0171 i (Section 3.7.3(2)) the QA trending program to address (2) identified concerns.
Item 86-41-40 Enhance NRC Commitment Tracking per- 25.0008 (Section 3.7.3(3)) 'formance (See Action Plan Section (2R) 48.11, Commiteent Management).
Item 86-41-41 Evaluate integration of LRS Management 25.0172 (Section 3.8.1(1)) Appraisal Report items into QCI-12 (2R) process. l Item 86-41-42 Document measures to revalidate the 25.0173 (Section 3.8.1(2)) adequacy of QCI-12 reviews. (2R)-
Itan 86-41-43 Establish controlling procedures for 25.0174 (Section 3.8.1(3)) SSR documents. Verify acceptability (2R) with NRC.
Item 86 41-44 Implement final nuclear organization 25.0175 (Section 3.8.4(1)L(2)) and fill management position vacancies (1) with District employees.
Item 86-41-44 Develop plan for replacing contractor 25.0176 (Section 3.8.4(3)) personnel with SMUD employees. (2)
- Committed to in 2/12/87 ASRTP Inspection Exit Interview
-9 -
o _ _ _ _ _ _
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ATTACHMENT 4 0 .
PAGE 1 0F 4 ATTACHMENT 4 6- ' GENERAL AREAS OF CONCERN IDENTIFIED BY'NRC IN SAFETY. .
SYSTEM FUNCTIONAL INSPECTIONS (SSFIs).
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ATTACHMENT 5 PAGE 1 0F 33 I
ATTACHMENT 5 i l
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CONCERNS IDENTIFIED AS A RESULT OF QUALITY DEPARTMENT VERTICAL AUDIT j
(NOTE: Findings attached are unedited, rough drafts. Post-audit conference has not yet been held.)
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. ,.w..,~ ,,,. ,4 Q Z ol 01 No: c3}-020-001
,- SACRAMENfD MUNICIPAL UTILITY DISTRICT QUALITY DEP('.RTMENT Page 1 of 1
.OPEN ITEM
==========,=n=========================================================
Subject / Activity-Audited: Safety Analysis - EFIC/AFW ! l Audit Date: 4/22/87 - 6/26/87: Auditor (s): Al Ostenso l Persons Representing Audited' Organization: J. Williams / H.I.Deebo - Engineering i Required-Reply Dates __________ Action Assigned to: _________ ________ -
===========e======================================e========u=.=m==n=n==
l Description of Condition (s): The safety analysis and f ailure analysis does not . include consider-ation'of all aspects of EFIC/AFW configuration at Rancho Seco: DEIG16el The impact of the change in shutdown bypass permissive from low pres-sure in both SG's .to low pressure in either,,,SG was not evaluatpd (RI-016). The capability of EFIC to operate as . required fer a loss of- main f eedwater caused by an EFIC f ailure plus a second EFICthat f ailure was not there are evaluated. The-DBR and SAR for ECN A5415 Major state failures in EFIC that can cause a MFW isolation. IEEE-279 requires that EFIC cperate as required with a second f ailure. (RI-010) , i 1evel The SAR for ECN A5415 Major does not address failures in the SG ! I instrument lines or leaks in the instrument linen that are less than the excess flow check valve setpoint. Instrument line breaks and the l l expected operator action are discussed in the DBR for A54158 (RI-010, RI-054).
A Hee /o#o W S Q Jef y) L' OI No.: 03-020-002 L . ,cs SACRAncNTO MUNICIPAL UTILITY DISTRICT I- QUALITY DEPARTMENT Page 1 of 1 p OPEN ITEM ! um maammmmmmmmmmmmmmmmmmecommmmmmmmmmmmmmmmmmmmmmmmumu
' Subject / Activity Audited: Technical Specification Amendment Audit Date: 4/22/87 - 6/26/87 Audi tor (s) : Al Ostenso Persons Representing Audited. Organization: R. Colombo - Licensing
}
i Required Reply Date: __________ Action Assigned to: __________________ mummmmmmmmemmmmmmmmmmmmmmmmmmmmme========m=======mqm====m========mumma
~
Description of Conditions: all fea-
'The technical specification amendment did not include checks of tures required to assure EFIC/AFW operability.
DEIBILEt A test for the integrity of the controller settings are not included Proportional gain, reset in The settings (i . e. the test specification. etc. ); totablish the system rate,' rate limited load follower settings, and prevent overcooling when SG 1evel is response system stability, that under automatic control of EFIC. The response to RI-101 indicates be added to the technical specifications. The entent of this type condition, root cause, and action to prevent recur'rence this item will still l needs to be identified. (RI-101) The EFIC vendor instruction manual CRef A70] indicates that the system are the functions that logic testing is not exhaustive but does not list not checked. Therefore, there may be other significant functions that arc-(RI-042, RI-101). not covered by the current surveillance testing (CST) level No surveillance requirements for the Condensate Storage Tank These instruments are needed to assure adequate instruments are included. CST inventcry and are used by the operator for managing the transfer of (RI-101) AFW suction between the CST and the SRS. The statement on page 16 of the Tech Spec Amendment "The EFICcontrollers the actuated device system can be tested from its input terminals toin key locked maintenance bypass" does not the channel without placing The EFIC vendor instruction manual requires that apply to all functions. E channel be placed in maintenance bypass bef ore exercising the control module self test.
s (- p
** 'A- '11, ff Yo$3$
2 01 No.: 31-020-003
, ,.o SACRAMENTO MUNICIPAL UTILITY DISTRICT DUALITY LEPARTMENT Page i of 1 OPEN ITEM
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Calculations and Ana lysis - EFIC Subject / Activity Audited: Audit Date: 4/22/87 - 6/26/87 Auditors: Al Ostenso / R. Januu Persons Representing Audited Organization: H.I.Beebe / U.Witte - Engineering Action Assigned to: __________________ Required Reply Date: __________
,===================
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Description of Conditions: There is no evidence of a positive mechanism to assure required calcu-
'1ations are finali:ed and updated price to start up.
QEIBILEt i Only informal calculations to establish AFW immunity to fligh Energy for leaks Line Break and the pressure drop in the instrument lines There was no less then the excess flow check valve were ave 11able. were tracking system identified to assure that these' calcul ations formali=ed prior to start up. (RI-008, RI-054) Rev. O states on page 34 "... pipe Pipe stress calculation Z-FWS-M1976, qualifica-support loads have been transmitted to the civil group f or the existing pipe rack. Approval of the new loads will was be tion of No mechanism documented in a subsequent revision to this calc." identified to flag and track calculations that are known to require updating. (RI-105)
Ar%Gef=ont'*j Q To / 33 01 No.: 87-020-004 SACRAMENTO MUNICIPAL UTILITY DISTRICT l QUALITY DEPARTMENT Page 1 of 2 OPEN ITEM
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Sub!ect/ Activity Audited: Cal cul ati ons Jones Audit Date: 4/22/87 - 6/26/87 Auditors: Al Ostenso / R. Persons Representing Audited Organization: H.I.Deebe / P. Johnson / J . v'i l l i ams / U.Witte Engineering Required Reply Date: __________ Action Assigned to: __________________
===========,=================================e ==em============n======
Description of Conditions: and Calculations contain assumptions without sufficient Sources of input are not identi- justification methodole.]y that is inappropriate. fied in all instances. DEI 81LSI Calculation Z-FWS-IO127 [Ref A36]: assumptions th'dt were not
" hidden" Justified.
The calculation contained the tima i t takes to Also, the calculation contains essertionsand. regardingrelationship between achieve the same pressure in both SG'swithout the providing a basis f or the indicated level and pressure and j assertions. (RI-036) t f Calcul ation Z-222-10132 [Ref C943: valve used in the instrument Qualification of the excess include flow check of type test data and consideration the effectu lines, does not l (RI-055). of transverse motion on the valves Cal cul ati on Z-RCS-IO124: density
- 1. Does not provide a source or basis for the reference fluid used in the calculations (RI-096).
- 2. Does not indicate the information source for instrument line eleva-tions and length of the uninsulated portion of the line used in the cal ~
culation. (RI-110)
- 3. Does not appropriately include the error in the level transmitter du a The calculation states that over pressure will not to over pressure.
occur until the static pressure limit of the transmitter it exceeded. on the However, over pressure will occur if the differential pressure (RI-110). instrument encaeds the measurement range of the transmitter.
- 4. A clear definition of the basis for the calculation in secticn V.A is relation-not given in the calculation. The calculation alludes to the ship between the insulated and uninsulated portions of the reference end the measurement legs in the same region, but does not clearly define basis and purpose of the calculation. (RI-110) building
- 5. The calculation uses the bulk air temperature in the reactor for various calculations, rather than the temperature at the location uf the equipment being analy:ed. (RI-057)
.a .- . ~ _ . - _ _ . .. _ _ _ . . . --
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3 d e /JJ
.,- SACRAMENTO MUNICIPAL UTILITY DISTRICT DI No.: 07-020-004
~~ 4 QUALITY DEPARTMENT Page 2 of 0 OPEN ITEM
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The response to RI-110 gives a satisfactory technical basis for items 2 and 4. Thu response to item 3 does not address the potential for over pressure during instrument calibration.. Also, the response does not provide a corrective action to prevent reoccurrence. The analysis provided to justif y routing fiber optic cables from dif f er ' . ent EFIC channels in the same raceway does not address the potential for j events (e.g. Fires, missiles, etc.) that.may cause., loss of . fiber optic
~ cables from more then one EFIC channel (RI-UO9). ~
There is no analysis in DBR R-0380 to demonstrate that the structure used for supporting the instrument 12ne insulation will withstand a seismic event. The insulation is required to assure satisfactory oper-ation of SG and hot leg level sensors under~ accident conditiot:s. Calculation 2-RCS-10059 uses 120 DegF as the initial instrument line temperature. This temperature is the bulk reactor building air tempera-ture and is based on satisfactory- operation of -the reactor ' bui l.d i ng HVAC. The calculation does not indicate that thi~s HVAC system is redun-dant class i. If it is not, then the initial instrument line temperature must .be based on th'e temperature reached while the HVAC is not bperat-ing. Also, the initial temperature must be based on the temperature in the vicit.ity of the instrument lines, not on the containment bulk air temperature.( RI-050)
)
1 (
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.)
OI No.: 84-020-005 SACRAMENTO MUNICIPAL UTILITY DISTRICT
,' QUALITY DEPARTMENT Page 1 of 1 OPEN ITEM
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==========================
Subject / Activity Audited: Design Bases Audit Date: 4/22/87 - 6/26/87 Auditor (s): Al Ostensa Persons Representing Audited Organization: H.I.Beebe - Engineering Required Reply Date: __________ Action Assigned to: __________________
====================
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Description of Conditions: The design does not include adequate consideration of all design ele-ments. DEIBILEt in the OTSG No basis for the setpoint of the excess flow check is provided in the system design.. valve Two 1evel senser instrument lines for the set-DCN's (I-1195, sheets 1 & 3, CRef C207,C2003) use;;3 LPM points of instrument li,nc excess flow check Furthermore, valves with no ansource appendi:. or basis for the values identified on the[Ref drawing.A363 contains test data which demor.- to cal cul ati on Z-FWS-IO127 setpoints is 4.6 LPH (RI-066, strates that the minimum achievable RI-054). EFIC DBR's do not include, or give the basisestablish for, the signal ranges The calibration and accuracy requirements that are needed to (RI-033). procedures for the analog loops : 1 for selection of the EFIC time delay justification was provided The module settings from one of two possible values f or each time delay. No DBR provides for A5415AF while provides an analysis to establish the calculation Z-FWS-IO127 provides values maximum that permissible delays, will provide acceptable EFIC performance. (RI-036) The DBR for R-03BO indicates that the insulation applied toZ-RCS-ICOS9 the instru-ment lines is two inches of f oam plass but the calculation is based on one inch of calcium ilicate. The only justification;given f in the DBR is that the thermal properties of the two types of insulation are similar. The justification does not include a consideration of all l properties of the insulation. (RI-050) instrument lines to remain The DBR f or R-0080 allows portions of the uninsulated if the reference and varitble leg runs are adjacent the uninsu-to each other. The analysis provided in the DER to demonstrate that lated portion of the reference line will not flash is based on an eleva-tion head of approximately 50 feet. the If the elevation head is in error by anal ysi s is invalid. This is en only 4 feet, the conclusion of information. insufficient margin for a calculation based on approximate (RI-109)
4 % 4 s ad '*
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OI No.:.07-020-006 SACRAMENTO MUNICIPAL ~ UTILITY DISTRICT QUALITY DEPARTMENT Page i of'2 OPEN ITEM i
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=========t.================================Documentation Subject / Activity Audited: Review of Design Audit Date: 4/22/B7 -6/26/87 Auditors: A1 Ostenso / R. Jones Persons Representing Audited Organization: H.I.Beebe - Engineering Required Reply Date: __________ Action Assigned to: __________________
====================
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Description of Conditions: Adequate review of design documentation is not always evident. DEIBILSI plant procedures do not provide a mechanism for documenting the The revi ew and verification process. the resolution of comments made in (RI-106) . ... the The' DVR's that were examined did not provide an adequate listing of NEP 4109 requires the reviewer documents that were covered by the DVR. were reviewed by number and revision identify .the documents that be a to level.'Many of the DVR's simply listed " series Numbers" which can hundred documents. None of the DVR's provided the grouping of several proper listing of revision level of the documents reviewed. Without if the a appropriate documents were documents .it cannot be determined reviewed. (RI-044). A5415J , one The list of documents reviewed for the two DVR's for ECN include only 23 of the 84 draw-mechanical / electrical and one civil, ings/DCN's given in the Drawing Change Transmittal. There is no inf orma-tion in the ECN package to demonstrate that the design can be considered (RI-088) l adequately verified without reviewing the unlisted documents. adequately The checklists and procedures for design verification do not For exaspple. l address all items to be considered inF,the review W andprocess. AG are incomplete. with l the DVR checklists for ECN's A5415E, J, separation. The response to l equipment qualification and regards to give adequate con-RI-032 indicates that thedesign experienced aspects. reviewer will the procedures do not However, sideration to these of reviewers. ! include guidelines for establishing the qualifications
'(RI-032)
There is no evidence that the EFIC system design description was inde-design. basis for the EF1C j pendently reviewed. This document is the (RI-004) the DDR for A5415 Major was independently There is no evidence that This document provides the basis for the modifications made to which incorporate EFIC. AS415 Major defers verification to the suo-ECN's, reviewed. ; l is allowed by plant procedures.
4 & o ( = e. / '#4 (r fo #"?) l 01 No.: 97-020-006 SACRAMENTO MUNICIPAL UTILITY DISTRICT QUALITY DEPARTMENT Page 2 of 2 ; OPEN ITEM
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A5415 Major is use as the basis for the design and verification
==========================d However.
of the ab-ECN's. Therefore, there i s no evidence that A5415Ma or or the sub-ECN's have been adequatuly verified. E&W, and this verification is The basic EFIC to bedesign was verified byThe Verification of the DBR for A5415 Major.may adequate. j assumed therefore be restricted to: Applicability of EFIC to Rancho Seco Adequacy of EFIC modifications made by SMUD ~~ Adequacy of changes made to AFW ! Confermance of the Rancho Seco EFIC to the B&W design Completeness of the design as it relates to Rancho Seco (RI-005) independently , There is no evidence that the DDR for AC660 Major has been items but ; reviewed. A review of A-3660Z was performed on the closing Evidence of e.n nothing was submitted on the major portion of the ECN. independent review was. lacking. (RI-100) :- Many DCN's contain N/A in the design engineer and/or the cognizant engi-neer signature blocks. There are no criteria in the plant procedures (RI-022). to indicate when review by these individuals is_ not required, 1 l l l
A Mnr{co?$ Q/ec/]} SACRAMENTO MUNICIPAL UTILITY DISTRICT OI No.: O&-020-007 QUALITY DEPARTMENT.
'OPEN ITEM Page 1 of 1
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Subject / Activity Audited: Electrical- Separation Audit Date: '4/22/87 - 6/26/87 Auditors: Al Ostenso / R. Jones Persons Representing . Audited Organization: H.I.Beebe - Engineering Required Reply Date: __________ Action Assigned to: ____________,,_____
.===================u============================ww.====c=======:=====n ~
Description of Conditions: ! Electrical separation guidelines are inadequate. i QEIBILEi A Procedure Change Notice to allow the installation.of now cables in existing enclosures where it is not possible to' achieve' the ceparation requirements of design guide NEP 5204.44 does not provide any guidance or criteria to be applied for determining the acc'ptability e of an encep-tion. Procedure Change Notice (PCN) Rev.1 dated 4/7/97 to NEP 52044.44 Rev.O (Ref.C23) gives the reason for the change: "To allow the installation of new cables in existing enclosuras where it is not possible to achieve the separation requirements of this design guide. " Since there no con-comitant requirements, it appears that the intent was ':o exempt naw-electrical installations from any separation requirements. 1 I i I
. . AHsYwJ Yf W $$
.. SACRAMENTO-MUNICIPAL UTILITY DISTRICT OI No.: Ob-020-008 QUALITY DEPARTMENT ,
4 OPEN ITEM Page 1 of 1
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Subject / Activity _ Audited: Non Conformance Reports l Audit Date: 4/22/87 - 6/26/87 Auditors: Al - Ostensa Persons Representing ; Audited Organization: S. Knight - QA l J Required Reply Da.te: __________ Action Assigned to __________________
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Description of Conditions: The action to prevent reoccurrence of NCR's is inadequate because they do not always address the root cause and there is not always evidence that corrective action was completed. DEIBILEi In NCR 6102 the action to prevent recurrence ( i . e,.. modifying some draw-ings ) does not address the root cause (i . e. . separation cri teria not established in site procedures) (RI-073). NCR's S-4485 & S-4486 do not provide any indication of the completion of the action to prevent recurrence. (RI-073) , I i
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(t /J o&~f ] SACRAMENTO MUNICIPAL UTILITY DISTRICT 01 No.: G}-020-009 QUALITY DEPARTMENT OPEN ITEM Page 1 of 2
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Sub ject /Ac tivity Audi ted: Design Configuration Control / Document Control Audit Date. 4/22/07 - 6/26/07 Auditors: Al Ostenso / R. Janus Persons Representing Audited Organization: W. Wells / S. Wood - Engineering i Required Reply Date: __________ Action Assigned to: __________________ I l
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Description of Conditions: The contral of design information, design documents, and reccede is not always adequate. Dele 1LHL Vendor instruction manuals are not routinely upda.ted to reflect the as installed system configuration so all documents in the techaical library have the potential for providing misleading information about all sy s-tems installed at Rancho Seco (RI-113). DDR A5415 Major contains references to many Babcock & Wilcox (D&W) docu-ments that form the basis of the EFIC/AFW design. There i s no mechani s-min place to retrieve a document given the B&W number. For the case of by EFIC this deficiency in site documentation control was alleviatad ; including the reference documents in the ECN package. However, t5e l documents were stored in a cardboard bo:: in SDC until late in the audit and could not be retrieved unles the right question of the right persen. f This does not constitute adequate document control. No site muchanisms are in place to assure adequate control of documents of this type. (RI-013, RI-021) The Major DBR relies on the system description for much of its i nf orma - tion and makes reference to it for specific information in several cases. The system description is undated, unnumbered, and unsigned. (RI-004) Several drawings in Sub-ECN A5415E contained a note that references e letter as part of the design basis. The letter is not retrievable from the reference given on the drawing. Note that the informationAS415 contained Major. in the letter is also contained in the DBR and SAR for
,RI-027)
( Several DCN's that are currently active were based on revisions of draw-ings that are out of date. DCNs are prepared in accordance with NEAF 4112. It is the responsibility of the engineer to identify all out- l standing ECNs issued on the drawing under study. Since a DCN is issued to the then current revision of the drawing in cuestion, there may be many active DCNs on different revisions of a drawing. The engineer calls Dccument Control to obtain a list of DCNs and/or checks all draw-ings c'f that number in the " pink" file. 1 ____________u
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, o.m 01 No.: 04-020-009 SACRAMENTO MUNICIPAL UTILITY DISTRICT QUALITY DEPARTMENT Pa e 2 of-2 OPEN ITEM
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engineers- concerned the e:tisting and
=====================the=============================ith After checking _with' w
i the current revision of the drawing has the DCNnece changer. affected DCNs, added. After ssar y i added to it and the DCN identification block appr oval s , the drawing is issued as a " pink" crawing the results- for construction. should be f If all steps are carried out with no oversights,given the time and attention the en 1 as desired. to(RI-111) this However, process and the complexity ofIn theaddition system, a large must devote conflicts exists. there is no ., probability for errors or DCNs on a given drawing or to establish a ! method to limit the number of One time limit after which DCNs should be incorporated'on the original. ag ains t it. of the reviewed reviewed drawings had 20 outstanding DLN's (RI-111) include all of the new EFIC tag numbers,. The MEL is not updated to designation in the ENVIRONQ field. This rusul ts in a including the "H" loss of configuration control for EQ equipment being installed because in MEL. MIMS will not accept tag numbers'for following workhave problems requests been which are not identified: Lack of EQ As a recult, the individual review,: Loss of traceability, Loss of work histor7 (RI-052). for each tag number and loss of some QA/QE/QC activities I
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JOI No.: 07-020-010 l
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SACRAMENTO MUNICIPAL UTILITY DISTRICT .. l
- ( . QUALITY DEPARTMENT. Page 1 of ,1 DPEN ITEM-
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Subject / Activity Audited:l Control of Licensing Documentation J i
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Audito-s: M. Horhota / R. Jonen Audit Date:.4/22/07 - 6/26/87 1
-Persons Representing Audited Organization: R. Colombo Licensing Required Reply Date: __________ Action Assigned to: __________________
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Description of Conditions:
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j 1 Inadequate controls to assure production and tracking of the updating ot
-licensing documents.to reflect plant modifications.
I DEIGILHi and There was no documentation provided'to initiate changes to the USAR Technical Specifications to address modifications made by. ECN A3660, Rer/
- 2. It appears that the present practice is to use tiosed ECN's to initi-ate. USAR updates. This is not consistent . with NEP 4301. (RI-002.
RI-060) to Plant procedures do not contain a requirement-for any organization i maintain- accountability f or the 50.59 SAR reports while they are in the review / approval cycle. (RI-102)
l .. (f /f* f 13. OI No.:07-020-011 L ' SACRAMENTO MUNICIPAL UTILITY DISTRICT QUALITY DEPARTMENT Page-1 of'1 OPEN ITEM
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Subject / Activity Audited:- Operator Training. Audit Date: 4/22/87 - 6/26/87 Auditor (s): A1 Ostenso L Persons Representing T. Hunter - Training Audited Organization: Required Reply Date: __________ Action Assigned to:
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Description of Conditions: the In some cases, operator training lesson plans are inconsistent with system design, incomplete and unclear. DEI 81651 Lesson Plan OD 24 K 1000 ERef A593 does not include a scenario that sim-ulates a failure in e.n SG 1evel' instrument line. failures uf this nature and the required operator action are discussed..in the SAR for AS415F. and high level- indications Failures in the ref erence leg will cause Failures in the variable log will-spurious ' Main Feedwater isolation. cause low level indications and spurious actuation of EFIC.-F1-077) as a El 21 P 1400 CRef manualincludes A563 does the EFIC vendor instruction manual not reflect the Rancho Seco EFIC configure-reference. The tion, so.the use of the manual could lead to 'misinf ormation and inappro-priate maintenance actions. (RI-085) a_. . _ _ _ _ _ _ _ _ _ _ _ _ _ _
4"/fnelere 4 l Jt /Tef*)) SACRAMENTO MUNICIPAL UTILITY DISTRICT OI No.:07-020-012 QUALITY DEFARTMENT Page 1 of 1 l OPEN ITEM l
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Subject / Activity Audited: Procedures Inconsistent with System Design Audit Date:6-26-87 Audi tor (s) : Al Ostenso Persons Representing Audited Organization: D. Tipton - Operations i Required Reply Date: __________ Action Assigned to: __________________
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Description of Conditions: incomplete, conflicting and inconsistent with Plant procedures are system design. DEIGILEt Operating procedure A.52, Rev 3 requires a voltage to be checked to assure that it is within 1% of 120 VAC and the frequency is within 1% uf 60 H:. The procedure dces not identify the',( action to take if the measurements are outside of the limits. (RI-095). Section 3.0 of procedure A51 ERef A593 is, confusing and conf l i ct i r.g . Taken literally, this section would indicate that an AFW pumo motor could never be restarted if it ever ran for less then 4 hcurs. (RI-084) Section 3.9 and 7.8 of procedure A51 ERef A593 are in conflict. Section 3.9 allcws only one AFW pump to be in operation when the 3RG is supply-operation before ing AFW. Section 7.8 requires both pumps to be in transferring AFW suction to SRS, followed by securing pump P-318. There is no basis in the plant documentation for these restrictions. flow Section 4.2.12 of procedure A51 ERef A593 requires placing the AFW control valves in automatic and open but the step should be to verify the position of the valves. (RI-OO4) Section 6.2 of procedure A51 [Ref A593 should be labeled EFIC System Shutdown bypass, not EFIC system shutdown. (RI-004) Section 7.3.4 of procedure A51 ERef A593 does not prov.de sufficient removing i procedural steps to assure that AFW is not requirard bef ore from service. The procedure requires assuring that SG 1evel is under required control, but doer sc provide steps to assure that AFW is not to control level. (RI-084). Section 7.4 of procedure A51 [Ref A59] is written inintroductory a manner thatphrases could steps use lead to hesitation and confusion. The ' such as "may be, etc" rather than imperatives. (RI-084) Procedure A51 ERef A59] does not provide the steps for placing AFW in automatic. (RI-084)
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k Selauf 9 n.,y i 01 No.: 87-020-01; SACRAMENTO MUNICIPAL UTILITY DISTRICT DUALITY DEPARTMENT Page i of 1 OPEN ITEM
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Subject / Activity Audited: Mild Environmental EQ Program ___________ Auditor (s): R. Jones Audit Date: 4/22/87 - 6/26/87 Persons Representing Audited Organization: R. Wise - Equipment Qualification Group Required Reply Date: __________ Action Assigned to: __________________ Description of Conditions: There is no objective evidence of an adequate Mild environment ecuipment qualification program. DEI 61 LEI The mild environment equipment qualification program must be based on The Rancho Seco program the normal operating environment of equipment. uses an arbitrary set of environmental conditions *:ta establish the deft-nition of a mild environment and in some cases this was interpreted as an exempticn from qualification. (RI-024, RI-117) qualification records f er SFAS Control There are no envirenuental Modules- H45D2A & H45D2B because they are located in a mild environment. an ex emp - This is a case where the mild environment wasenvironmental interpreted asqualification { { tion. However, the modules do require together with substantiating documentation. (RI-088) i i An example where the equipment was purchased to the actual environmental conditions is as follows. Paragraph F of the DBR for ECN A-3660 definus the new Nuclear Servi e Electrical the environmental Building. conditions forthe conditions specified would fall within the Even though the DBR includes the statement SMUD definition1 ofelectrical a mild environment, distribution equipment is qualified for these "New class (IE the actual) conditions". i It is not clear what organi:ation is responsible to assure the Class electrical distribution equipmer.t is actually qualified as committed. Considering the factors given in page 3, paragraph 4 of the NRC Generic the periodic sur-Letter No. 82-09 (attached), it is not apparent how veillance, testing and maintenance program is accomplished. A mild equipment qualification program is needed to assure that equip-ment important to safety will meet, on a continuing basis, the perfor-mance requirements determined to be necessary for achieving the system requirements. This is part of the commitment needed to meet the intent of ANSI /IEEE Std. 279-1971.
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J OI No.:87-020-014
- SACRAMENTO. MUNICIPAL UTILITY DISTRICT ;
QUALITY DEPARTMENT. Page l' of 1 OPEN ITEM 1
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Subject / Activity Audited: Dedicating Safety Related Equipment l Audit Date: 4/22/07 - 6/26/87 Auditors: A1 Ostenso l 1
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Persons Representing Audited Organization: U. Witte - Engineering l Required Reply Date: __________ Action Assigned to: __________________ <l l
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a program to dedicate' saf ety . related There is no evidence- of equipment purchased as commercial grade. 25I81L21 For SMUD procures some safety.related equipment as commercial grade. example, CCN A5415E indicates that the required wire and LED's are to be purchased as commercial grade. . Commercial grade I,tems must be dedicated before they can be used in. safety related systems. tRI-019. RI-091)
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#7 /7 /33 SACRAMENTO MUNICIPAL UTILITY DISTRICT OI No.: G7-020-O!5 QUALITY DEPARTMENT Page 1 of 1 OPEN ITEM
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Subject / Activity Audited: Seismic Qualification Records Audit Date: 4/22/87 - 6/26/07 Auditors: R. Jones Persons Representing Audited Organization: M. Kermani - Seismic Qualification Group Required Reply Date: __________ Action Assigned to: __________________
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Description of Conditions: No evidence for seismic qualification of some components. DEIGILSI were not Qualification records for SFAS control modules H45DOA & H43D2B located. These modules were apparently qualified as part of the entire A cabinet but the tag numbers are not the same as those bciag used. cross ref erence wi th a similarity justification should be provided. The complete. cabinet qualification record Sec.2.1 does not aphear to be b&c E::amples are, item 3, no lab mounting detc.ils available, item 4 a, are listed as unknown and item 8 lists program". theapparent These " Method of verification: discrepancies Pub-have not lic domain computer been justified (RI-088). (File R fit . l'5. in )
A>ffwe$ses/f _+ 4n.n y 01 No.: 87-020-016
. SACRAMENTO MUNICIPAL UTILITY DISTRICT
' OUALITY DCPARTMENT Fage 1 af I OPEN ITEM
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. Subject / Activity Audited: Post Installation Testing Audit Date: 4/22/G7 - 6/26/87 Auditor (s): A1.Ostenso Persons Representing
. Audited Organizations D.Tipton - Operations Required Reply Date: __________
Action Assigned tos ____ ______________
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Description of Conditions: l adequate post installation testing of some There is no evidence for equipment. , 25I8165L The disposition of NCR S-6171 CRef A793, which addressed the repair. of two fiber optic cables and re-labeling them as spares, but indicated that would be the cables would not be retested as part of the ,.; repair tested if the need arose to use them as active cables.they No mechanism were used. wasas given to assure that they would be retested when active cables. (RI-051) There is no evidence that all'of the breakers in panel 51A2-1 received post installation testing. (RI-063) Work Request (WR) 69415, which addresses testing of the breakers 4 in panel 51A2-1, does not include any evidence that breaktars l l A2125, and A2126 were tested. The WR identified breakurs A2101 and A2127 as defective and the defects were documented via NCR 3239. WR 78145 installs a replacement for breaker A2127 as part of the the testing of disposition of NCR 3239. The WR does not include replacement breaker. WR 77651 calls for moving spare breaker A2102 to position A2101. ! The test records accompanying the WR indicate that breaker #2' was l tested. This number is not in accordance withAlso, the panel so i t E108. drawing cen- l not be determined which breaker was tested. sht 12, Rev 7, (DCN 49), shows position A2102 to be an acti/e breaker. i
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Mh,c/w. t"$ V/ of JJ SACRAMENTO MUNICIPAL UTILITY DISTRICT OI No.: 87-020-017 QUALITY DEPARTMENT Page 1 of 2 OPEN ITEM
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Subject / Activity Audited: Training Audit Date: 4/22/87 - 6/26/87 Auditors: D. Logan Persons Representing Audited Organization: W. Keephe, J. Dawson - QC Required Reply Date: __________ Action Assigned to: __________________ i
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Description of Conditions: Training Records to demonstrate that inspection personnel have received all required training are not adequate. Refresher training is in need of improvement, training material is out of date, certification records quali-for inspectors (2) are not on file to indicate that they were fied/ certified for the type inspections they had performed. DEIGILS The training records on file for Mechanical R teiving Inspectors SSN 248-06-8668 and 534-58-6981 do not provide documentary evidence of their having received initial training to applicable Quality Ascurance Proce-dures (Either by assigned reading lists or training attendance records) as required by QAP Policy Section II, Para. 5.10 and QAIP 18, Section 6.0. 5.5.1 requires inspectors to be given refresher f QAIP 18, Para. training in revised procedures and programs. Contrary to thi s requirc-ment, it was noted that QAP 17, Rev. 5 "Nonconf orming Material Control" was revised on 3/16/87. However, refresher training had not been pro - vided to all inspectors until after the condition was brcught to Quality Controls attention (e.g. For Inspector SSN 534-58-6981). The extent of this condition must be evaluated to determine if additional refresher training need be provided to inspectors on revisions of other proce-dures. SMUD at present has two training sessions on Video Tape entitled. OCLP-1 " Orientation and Document Control Procedures" and OCLP-2
" Receiving Inspection, Storage and Administrative Procedurus" which are. presented to inspection personnel. However, these Video Training sessions are not representative of all the current requirements. For example, the Video's indicate that GCI-7 is the procedure that defines Quality Control Inspector Training and Qualification Requirements. This procedure was cancelled on 2/6/87 and QAIP 18, which was in place an of that date. and is still in effect, delineates these requiren.ents as well as others that were not in QCI-7. Additionally, the QCLP's indicate that MIDRs and CIDRs are to be used for documenting inspection results.
These documents have been deleted frem the program with the e::cep ti on of , those that still may be open (Ref. QAP 6 Rev.3). (File D_T I'.OI)
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SACRAMENTO MUNICIPAL UTILITY DISTRICT OI No.: D{-020-017
-- QUALITY DEPARTMENT Page 2 of 2 GFEN ITEM
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Contrary to ANSI N45.2.6 and QAli la requirements it was noted that RIDR No.913 (Contract No. 8257) reflected sign-off by an Inspector , was qualified who has no certifications on file inspections to demonstrate required by the RIDR.that Thehetypen of inupec-to perform the tions/ acceptance criteria required by RIDR No. 1498-2 (Contract No. 8939), must be signed off by a certified. level II mechanical inspec-tor, but were signed off by a certified Level II electrical inspector. The extent of this condition requires further investigation to I determine if these inspectors as well as 5thers have performed inspections for which they were or are not qualified / certified to perform and action as appropriate should be implemented. \ l l (Fil e D_T _ ! 7.OI)
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j 4 M c/,.re, d Q >J fH . SACRAMENTO MUNICIPAL UTILITY DISTRICT 01 No.: 37-020-010 QUALITY DEPARTMENT OPEN ITEM PaQe 1 of 2
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Subject / Activity Audited: Vendor Audits Audit'Date: 4/22/87-- 6/26/87 Auditor (s): D. Logan Persons Representing Audited Organization: J. Sullivan / J. Meyer 0A Required Reply Date: __________ Action Assigned to: __________________ i ammmmmmmmmm=mmmmmmmmmmmmm=ammmmmmmmmmmmmmmmmmmmmmganammman=amanaz===== Description of Conditions: Vendor audits have not been performed by SMUD to determine if vendor s are effectively implementing their approved QA Programs.' QEIBILE Section 12, " Audit of Procurement Program", contained in ANSI N45.2.13 (1976 Edition), " Quality Assurance Requirements for Control of Pr ocur e-ment of Items and Services for Nuclear Power Plaqts," requires, in part,
" Periodic or Random Audits shall be performed to verify compliance with l
Procurement Activities---- ".
)
Section 7.6, " Reporting," additionally requires, msasures shalltobeygrily estal . inhed to provide for the reporting of activities 'perf ormed conformance to requirements of procurement documents. These measures f shall include reporting of audits---- . NRC Inspection Notice 86.21 " Recognition of American Society of Mechani-cal Engineers Accreditation . Program for N Stamp Holders". addressed to all -Nuclear Power Facilities--- , delineates the NRC's post-tion / recognition of the American Society of Mechanical Engineers (ASME) Accreditation Program for holders of N,NPT, NA, and NV Stamps and Certi-ficates of Authorization. Page 20F2 of this inspection notice states in part, licensees and when assessing whether a potential supplier their subcontractor, has an acceptable documented QA Program, may rely on the fact that ASME has surveyed the supplier and issued a certificate of authori- l zation of appropriate scope and for the desired location without performing any additional evaluation of the supplier's QA program. However, it further indicates that the "NRCs Recognition of the ASME Accreditation Program applies only to the programmatic j aspects, licensees --- are still responsible for ensuring that the i supplier is effectively implementing the approved QA Program." l
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SACRAMENTO MUNICIPAL UTILITY DISTRICT OI No.: 07-020-010 i OUALITY DEPCRTMENT Page=2 of 2 OPEN ITEM
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l the vendors (e.g. During' the ' audit of the Procurement Process, l Target Rock Corp., Tioga- Piping Supply) that supplied QA Claus 1, ASME Code Class components and materials ~to SMUD for the au:-:ili a; y feed water system- were noted to be on SMUD's Approved Suppliers. they hold a List (ASL) based on desk audits and .the fact that However, the desk audit Quality System Certificate issued by ASME. consists only of a revtew of the Suppliers Manual and to date SMUD these suppliers-facilities to has not performed a formal audit fat approved QA program. verify they are effectively iggigG20 t igg their This' is contrary to the aforementioned 'requi'rements and the NRC'3 recognition / position of the ASME Accreditation Program. The Vendor Audit Group Supervisor. indicated that, "they .were in the process of being staffed, a complete rewritejoined of the Vendor Approval' CASE and NSCAC Procedures was in progress,.the District has has been completely vendors, the ASL for ' Joint utility audits of reviewed, rewritten and most vendors on it reevaluated." However,
.as of this date there is'no indication that these vendors have been the vendor abdit group supervisor scheduled to be audited, althcagh Certificate would be sche-did indicate vendor.s holding an ASME compliance.-to their duled for audit in the near future to determine approved program.
v~ - - - - _ _ - _ _ A M ao{,,,o J & Q Mo/)} DI No.: 07-8.CO-017 SACRAMENTO MUNICIPAL UTILITY DISTRICT OUALITY DEPARTMENT Pave 1 of i OPEN ITEM
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==========u===============================Material Control Subject / Activity Audited: Procurement and Auditor (s): D. Logan Audit Date: 4/22/87 - 6/26/07 Persons Representing -
Myer - 0A Audited Organization: L. Rouen / S. Sallee / J. : ( Required Reply Date: __________ Action Assigned to: ________,,_________
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Description of Conditions: I Criterion XVI, "Correctivce Action" of 10CFR50 Appendi:: B requireu in conditions adverse l part, "Messures shall be established todeviatione, assure thatdefective material and to quality such ns.... deficiencies identified and corrected. equipment and nonconformances are promptly Corrective action taken shall be documented and reporned to appropriate levels of management." DEIBILS Contrary to the above requirement the following was noted: (Reference The Elgt.r Source Inspection Report for the 25 KVA inverters ! that SMUD J Contract No. 8257) on Microfilm Cartridge No. 451 indicates and inspectors found " Lots of discrepancies between SMUD spec F O.02.1 proce-Elgars Tect Procedures etc; that Elgar was not adhering to their i dures." There is no indication on record in this documentation pacLaye ! to show that discrepancies noted by SMUD were resolved. i 4 atten-Further investigation concerning this matter was brought to the ) tion of the vendor audit supervisor and it was indicated at that as a the Elgar I result of the source inspection, an audit was performed Facility (Audit No. O-474). 1 audit report was reviewed and it identified several programmatic l This However, there is ro l deficiencies as wellprovide as hardware deficiencies. evidence tha: corrective action was perf ormec' documentation to and ar e on the open items. The inverters were subsequently received installed. SMUD, based on removing Elgar from the Approved criteria Suppliers XVI, List, closed the audit report. This condition violates corrective action, of 10CFR50, Appendix B. 4
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SACRAMENTO MUNICIPAL UTILITY DISTRICT DI No.: 87-020-020 ( QUALITY DEPARTMENT Page 1 of 5 1 OPEN ITEM
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= = = = = /=Activity Subject = = = = =Audited:
= = = = =Procurement
= = = = = = = =and = = = = = = = = = = = = = = = = = = = =i a ll
= = =Mater Audit Date: 4/22/87 - 6/26/87 Auditor (s): D. Logan Persons Representing Audited Or ganization: L. Rouen / J. Meyer / S. Sallee QA j i
Required Reply Date: __________ Action Assigned to: __________________
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Description of Conditions: Receiving Inspection Data Reports (RIDRs) have not been generated as required by QAP VI, "QC Inspection." RIDR instructions, delineated in the OC deck instructions entitled " Receiving Inspection" and on the RIDR cover sheet do not appear to be adequate. Entries on RIDRs ar a being high lighted with yellow highlighted which is contrary RIDRs to the do requirements of OAP 18, " Quality Assurance Records." Some not uniquely identify what was inspected. Ve,ndor documentation is j Not all copies of P.O.s and Specifications j missing or inadequate. are on file / microfilm. A documentation package on microfilm for cer- j for other tain items was noted to be combined with documentation j l items. DEIBILS A-640/ Specification M22.35.2 required Pacific Valve Lo A. Contract remove existing AC operators from District supplied valves SFV 205778 and SFV-20578B (originally procured from Pacific Valve via contract 125VDC motor operators and
#8939) and furnish two (2)supplied The valves new class by1E the District are now identified as actuators. the auxiliary HV-20581 and HV-20582 which are presently installed in feed water system.
A review of the hard copies of documentation on file for this contract revealed: Receiving Inspection Data Reports are not on file to substantiate acceptance of the valves and operators by Quality Control as required by GAP VI. "OC Inspection." Quality Control indicated that the valves i were not received with the actuatoru. However, it should by be noted I that some of the documentation for the valves as required spec. For M22.35.2 was filed with the RIDR for the actuators (RIDR 3633). example. Pacific Valve f urnished a partial (first page) of an enended NPV-1 code data form for valve HV-20582, which was required by page 9-7 of the Spec. The data form states, " valve HV-20582 was returned by customer for replacement of the operator; valve retested on 12/18/86." The second page of this NPV-1 is missing. Hydrostatic test reports for this valve are contained in this package also. There is no NPV-1 for the other valve, nor any hydrostatic test reports.
4 H uel m M .S f} 2 7.$)] SACRAMENTO MUNICIPAL UTILITY DISTRICT 01 No.: 87-020-020 QUALITY DEPARTMENT OPEN ITEM Page 2 of 5
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It appearc that receipt inspection was performed on only one of the Actuators received from Pacific Valve as RIDR No. 3633, inoicated " motor actuator, full shipment final." The RIDR does not specifically indicate both actuators were inspected, nor does it reference serial numbers / mar k numbers. Additionally, what further indicates that inspection was. pos-sibly performed. on only one actuator is the f act that the inspector annotated on the Certificate of Conformance, " received on partial 1." In essence, it is not readily apparent that both.. ~ actuators were receip t inspected. Page 4 of 4 of this RIDR required maintenance manuals, special hand-ling / storage instructions, warranty requirements, and long term preven-tive maintenance procedures. The inspector indicated in the applicable box on the RIDR that these items were not received, but neglected Lc indicate that this was acceptable or unacceptable as required by the instructions on the RIDR cover sheet. Page 9-7 of Spec M22.35.2 requires in p ar t, all wiring for the motor actuators shall meet the requirements of IEEE 383-1974, the documentation package does not indicate IEEE 383-1974 r equi r c -- ments have been met and the RIDR (43633) does not allude to whether ur not this was required. NOTE: This particular package has not been microfilmed as yet. I B. The original documentation package on microfilm cartridge No. 415 i for valves HV-20581 and HV-20582 (originally mar k Nos. SFV-205778 ar.d i SFV-20578B) was reviewed to determine compliance to contract 8939/ spec M22.31 (e.g., tests, NDE, etc. were performed as required; CMTRs, C of Cs were on file etc.). Results of this review revealed that the microfilming of the hard ccpies of these procurement records is in dis-array. For e:: ampl e, the RIDRs l (1498-1 and 1498-2) on film indicate that Spec. M22.31 is applicable to I these valves; frames 415 through 430 refer to M22.31 and frame 427 spe-cifically indicates that the valves shall be in accordance with Section l 9 of M22.31; PR No. 02599, on frame 506 references M22.01. However. Section 9 on frame 431 references Spec M22.30, not M22.01. Addition-ally, frames 152 through 369 contain documentation that is not pertinent : to these valves, but documentation for Diesel Generator Radiators, Spec l No. M17.06. Frames 370 through 554 continue with documentation app 11-cable to contract 8939. It appears that all vendor documentation i required by Spec M22.31 is on film as it refers to M22.31 requirements. l l However, an in depth review should be performed at the time the documen-tation is put in a better semblance of order. NOTE: The hard copy of this package, according to Records Man-agement, has been destroyed. l I 1 l l
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Q.28ef33 01 No.: 87-020-020 SACRAMENTO MUNICIPAL UTILITY DISTRICT QUALITY DEPARTMENT Page 3 of 5 OPEN ITEM
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C. Dabcock and Wilcox (B&W) Specification 08-1139706-01, Line 12.7.1.11 C for two (2) 4" Solenoid Flow Control required Valves, aMark cleanliness C of and FV-20532 from Target Rock (Ref SMUD P.C. Nos. FV020531 j GRS-46160, Spec M22.38, and B&W P.O. 044131LU). the C- of i Review of the documentation package on microfilm revealed No. 1491, indicates that the incpector veriiied that C was missing. RIDR required a " Test that it was received. Line 12.7.1 of the B&W Sppe Certification," which was in the document % tion package, but the Water the documenta-RIDR did not require this to be verified. Additionally, tion package only contains change orders to the above D&W P.D.: the whole P.O. is not on microfilm. No. 451 D. Review of the documentation package on Microfilm Cartridge j j for four (4) class 1E 25 KVA Inverters, Contract No. 8257, revealed the ] following: k Nonconformance j A receiving inspection' memo date'd 2-9-83 indicate,s that { Report (NCR) S-2640 was closed out. Review of the NCR Revis2 revealec another { that it was closed 7-9-83. However it was also noted there 1-12-83. Addi- l copy of this NCR Rev 2 which reflects it being closedto NCR S-0640 f tionally, review of Work Request No. 6970, that (applicab'le items deficient were completec Rev 2) found that it indicates 1-19-83. Furthermore, the Work Request in this package indicates that , item eight (8) of the deficient items noted on the NCR is questionabic. satisf actorily resolved. l item was It could not be verified that this on RIDR No. 913. which is applicable to this packege. required Item 10 approval of the completed the inspector to obtain Quality Assurance RIDR. This was not performed. Several sections of Bid Specification EB.02.1 which is the governing or file (e.g., Appendix 9H). Spec f orEngineering this contract are not on Document film (NEDC) was contacted in crder that Control Nuclear determine if requirements to the Spec could be obtained and utilizedNEDC did not have it on file. The { imposed on the vendor had been met. This cond tion was also Spec was subsequently obtained from purchasing.it was indicated that NEDC t discussed with the QA Records It Coordinator was f urtherand indicated by the QA Recor ds should have had the Spec. should not be microfilmed, but at least Coordinator that Bid Specs. consistent with the retained on file by Records Management which is This list requires Bid j
" Records Type List" held by Records Management. be l twenty years. Whether or not they should to Specs to be retained forcould not be verified and warrants further investigation microfilmed l
be performed by QA. E. RIDRs 2958 and 2959 generated for inspection of items purchased vi a 1184 revealed that P.O. 86020 were reviewed on microfilm cartridge No.not reproduce very inspectors are using yellow highlighted which does clearly.
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SACRAMENTO MUNICIPAL UTILITY DISTRICT 01 No.: 07-020-020 QUALITY DEPARThENT OPEN ITEM Page 4 of 5
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This appears to be allowed per DC Desk instruction entitled "QC Offi_c Procedure for Receiving Inspection, Rev 4." As a result some of the 1 F re informat en (e.g., heat numbers of items inspected) is not icgible. requirement in the desk instruction also appears to be in conflict with paragraph 5.3.2 of OAP 18, Quality Assurance Recordu, which inf ers that-high lighters shall not be used. A review of these RIDRs (2958 and 2959) was perf ormed also ta ascertain if all items on the P.O. were actually redeived anc incpected as required by the P.O. and governing upucification. This was rather cum-bersome because of the method used by the inspector to identify what was inspected, in addition to the use of yellow highlighted. For e:: amp l e. on RIDR 2959 the inspector indicated that the items required by the P.O. had all been received, by indicating on the front page, " Full Shipment." The RIDR attachments (P.O. displays) referenced the heat No. of items actually received and inspected which were required by theTherefore, P.O. How-ever, this is not required by the DC dusk instructions. the instructions f or completing RIDRs appear to be cdbtrary to current prac-tice of documenting inspection results. The QC desk instruction requires the inspector to: " verify quantities received per P.O. Line item. When the supplied quantity does not equal the line item amount, write in the quantity received and highlight it in yellow. For partial receipts, retain the yellow-lined P.O. for future inspection. action and reference." The instructions on the cover sheet of the RIDRs require the inspector to: "if the inspection involves a complete shipment, the inspector shall check the full box on the f rcnl. page of the RIDR; if the inspection involves an incomplete shipment tMe inspector shall check the partial box on the RIDR and indicate the par - tial number; any supporting documentation shall be attached to the RIDR." Both of these instructions do not appear to be adequate as they do not specifically require the inspector to uniquely identify on the RIDRs or on attachments (P.O. displays), items that have been actually inspectec. Also, these copies of the P.O. displays make reference to the P.O. No. but don't reference the RIDR No. If these copies had been misplaced. this could have presented a problem when trying to reconstruct the docu-mentation, as several RIDRs can be generated for each P.O. There are five copies of RIDR 2958 on micro film which were utili:ud to document five separate inspections of partial shipments of items for this P.O. The RIDR for partial shipment No. 5, consisting of pages 1 through 4, does not indicate what items were inspected. The front page of this RIDR under the component name block indicates only. " stainless steel pipe and fittings."
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4 Hue $ctsYb ryJ u JJ OI No.: 97-020-020 SACRAMENTO t1UNICIFAL UTILITY DISTRICT (' QUALITY DEPARTMENT Page 5 of 5 OPEN ITEM
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of specifica-- F. P.O.'GR-92305' requires that documents in section 9.7 with the items supplied. Section 9.7 shipped tion M22.35.3 shall be(Limitorque) to furnish certified written e v i -- requires the contractor dance that the proposed type motor operator has been successfully tested in accordance with IEEE standard 382-1980. indicates The- Certificate of Compliance from Limitorque for this order that the Motors are certified to IEEE 382-1972.. change RIDR No. 3508 Rev. or order to the P.O. 1 references IEEE 382-1972. There is no amendment to the spec to indicate that IEEE 382-1972 is ecceptable in lieu of the 1980 edition. 1972 ' edition, but The engineer did sign off on the RIDR accepting the still this is contrary to the spec requirement. The records coordinator f or Quality Assurance (OA) was agnin-cen-G._ to determine
- tacted to discuss the abovea documentation deficiencies and procedure delineating the requirements,for QA had established 5.4 transmitting completed records to storage as required by paragraph if of QAP 10 " Quality Assurance Records." It was revealed that a procedure has been was in the review process and subsequent to this discussion issued (6-20-86). Open Item No. 21 provides further details, concerning the adequacy of transmitting records to Records Management.
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& M f)3 SACRAMENTO MUNICIPAL UTILITY DISTRICT DI No.: 87-020-021
- ' OUALITY DEPARTMENT I
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Subject / Activity Audited: Procurement and Material Control Audit Date: 4/22/87 - 6/26/87 Auditor (s): D. Logan Persons Representing Audited Organization: J. Parman / J. Meyer / S. Sallen - 0A Required Reply Date: __________ Action Assigned to: __________________
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Description of Conditions: Records submitted to Records Management for storagu of Quality Assurance are not being adequctely identified (by Quali ty Assur-ance) on the transmittal sheet as required by Paragraph 5.0.6 of QAP 18, Rev. 3, " Quality Assurance Records." Details Paragraph 4.5 and 4.6 of QC Office Procedur*h, " Receiving Inspec-tion" Rev. 4 requires in part, "Acceptacle full shipments, par-tial shipments...shall be transmitted to GA/CE with a SMUD Docu-ment Transmittal Sheet... All title information on the transmit-tal sheet will be done in long hand. The table of contents section will indicate the number of -pages for gggb__ggeti gggysly group of data required to complete or support the Dymbgtgd completien of the RIDR, i.e., RIDR, CMTRs, qualifications tests, POs and etc." During this audit it was noted that QC Receiving Inupection Per-sonnel are presently completing transmittal sheets as required by the above Receiving Inspection Procedure and which satisfies the intent of QAP 18. However, at present, after the transmittal forms are forwarded to the QA/QE there appears to be a break down as the transmittals which are ultimately sent to Records Management do not contain the number of pages for each continuously numbered group of data required to support the completion of the RIDR. The current practice for transmitting documents to Records Man-agement af ter they are transmitted to the OA/QE is as f ollows: The QA/CE clerk makes up a new transmittal form (No. 1451) and indi-cates RIDFs in the subject section and under the table of contents section, lists only the RIDR No.s. There is no mention of the number of pages for each continuously numbered group of data etc. as is required by the GC instruction.
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SACRAMENTO MUNICIPAL UTILITY DISTRICT DI No.: 87-020-021 i
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QUALITY DEPARTMENT OPEN ITEM Page 2 of 2
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- These . transmittals with RIDRs, C of Cs and.CMTRs attached are.then forwarded to another section of the QA. Department for RIDR Data entr y.
The individual .who does the data entry then makes out Transmittal (s)' . Form No.'1351, " Records Transfer Form" and indicates only. the Record ! Type number (for filing / microfilming) and the Reccrd Type namo in the applicable section of the Form, and forwards same to Records Manage-ment. . Consequently, the final transmittal forms to Records Management do not adequately' identify the records being transmitted as required
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by GAP 18. . Additionally, it should be noted that QA in . order to ccmply wi th Paragraph 5.4 of QAP 18 (which requires each department to eutab-lish a procedure for transmitting records to storage etc.) and to help remedy this problem have generated QAIP 19, Rev. O, " Interim Storage of Quality Records." . This procedure requires in part, the transmittal shall indicate the member of pages of ;each docu-ment. The implication of this .aquirement appears to be th e.t which is presently ' required by the DC In'str uct i on . Therefore individuals who are responsible for the transmittal of records to. Records Management should at the earliest date, implement- the-above requirements. -Also, Management- should consider utilizing one transmittal form for the transmittal of- records to. Records Management. This form could be designed to accommodate all of the required 'information that is. presently covered on the two transmittal forms presently being used. (e.g., provide different for all the recipients, sendees, record type number and name, number of pages, recei pt acknowledgement from Record 4 Management etc.) i l 5 r
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