ML20239A030
| ML20239A030 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 09/03/1987 |
| From: | SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML20238F564 | List: |
| References | |
| NUDOCS 8709170031 | |
| Download: ML20239A030 (36) | |
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TWELVE SYSTEM ASSESSMENT OF THE EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGRAM (EASRTD)
REPC?.T Prepared by:
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%j .u w e 1 Date: 9-3 O gRTPPrdgramMgr Reviewed by: _f Date: / 3[
Director,Nuclearg Technical Services Reviewed by. ' C[J% Date: k3!O rectorjQuality ssu rance Reviewed by: 'J'[l / I([L L' ._.
, Date: 7' S- P
'- ssistant General Manager Technical & Administrative Services
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12 SYSTEM EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGRAM ASSESSMENT
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TABLE OF CONTENTS Page EXECUTIVE
SUMMARY
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1.0 INTRODUCTION
3 2.0 TEAM COMPOSITION 8
3.0 EASRTP SCHEDULE 12 4.0 PROCESS AND METHODOLOGY 14 l 5.0 IDENTIFIED CONCERNS I
17 6.0 GENERIC CONCERNS l i
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7.0 CONCLUSION
S 23 l 8.0 ATTACHMENTS i
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r 12_ SYSTEM EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGRAM
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ASSESSMENT EXECUTIVE
SUMMARY
Twelve of the 33 selected system evaluations in the Expanded Augmented System Review and Test Program (Expanded ASRTP) have been completed.
These twelve systems are:
-Decay Heat Removal -Integrated Control System
-Seal Injection and Makeup -Non-Nuclear Instrumentation
-Emergency Diesel Generator . -Main Steam
-120 VAC -Main Feedwater
-Control Room / Technical Support -Radiation Monitoring Center Essential Heating. -Nuclear Service Cooling Water Ventilation and Air Conditioning -Nuclear Service Raw Water This report examines the effectiveness of the Expanded ASRTP and describes lessons learned with respect to the team composition, schedule, process and methodology. The Expanded ASRTP concerns are compared to the NRC ASRTP findings as an aid in measuring the effectiveness of the program. Lastly, potential generic issues identified by the Director, Nuclear Technical Services, the Expanded ASRTP Program Manager, and Expanded ASRTP Team Leaders are presented.
The overall conclusion is that the District is meeting its commitment to the NRC to conduct ASRTP-type evaluations of the selected systems. The nature, depth, and type of Expanded ASRTP concerns are similar to those findings made during the NRC ASRTP.
Additionally, the Expanded ASRTP has been effective in identifying valid new concerns. Therefore the District remains committed to complete all 33 selected systems prior to restart. After the selected systems are completed, the majority of all remaining plant systems will be scheduled to undergo similar evaluations over a period of approximately two years.
Several lessons learned during the first twelve evaluations and the associated corrective actions implemented to improve the program are presented in Sections 2.0, 3.0, and 4.0. The entire Expanded ASRTP has been reviewed by the Technical Oversight Committee and the Nuclear Advisory Committee, who have stated that the program is well organized and meeting its objectives.
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The Expanded A5RTP teams have identified a total of 91 valid concerns in the twelve system reports. Fifty-one of these have been designated as requiring resolution and/or corrective action prior to restart. The remaining concerns will be corrected on a schedule consistent with their priority. In addition to the concerns stated in each system evaluation report, six potential generic concerns are identified in this assessment. The District will also address these concerns in an appropriate manner.
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1.0 If4TRODUCTION l 1.1 Background l
The Nuclear Regulatory Commission (NRC) conducted an Augmented System Review and Test Program ( ASRTP) inspection between December 1986 and February 1987 on the Auxiliary Feedwater System, the 125 VDC system, and their supporting systems. This safety system functional type inspection identified deficiencies not previously identified by the District in its problem identification program. In the NRC ASRTP report, the NRC noted that although the problem identification program at the District was generally effective, some of the problems identified in the System Status-Reports lacked sufficient engineering and operational review.
The District agreed with the overall NRC conclusions and l
committed to conduct a similar ASRTP inspection on all 33 j selected systems important to the safe operation of Rancho l Seco. The Expanded ASRTP would provide senior management an I
additional measure of the operational readiness of Rancho Seco.
1.2 Organization To conduct the 33 system evaluations, six teams were formed under a Program Manager who reported to the Director, Nuclear Technical Services. Eacn team would cover a functional area such as Reactor Plant Systems, Auxiliary Plant Systems, Electrical Power Systems, Instrument and Control Systems, Steam Plant Systems, and Heating, Ventilation and Air Conditioning Systems. Each of the functional areas contained approximately five systems to be evaluated. For example, within the Reactor Plant Systems functional area there is the Decay Heat System, the Seal Injection and Makeup System, the Purification and Letdowr. System, the Once-Through-Steam Generator and Reactor Coolant System, and Reactor Sampling System. Each team would >
evaluate a system within their functional area in parallel with other team evaluations. Consequently, six evaluations would be conducted at the same time. The evaluations began in July and are scheduled to be be completed by the end of October.
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l.3 Planning l
Significant pre-planning occurred in order to implement the June decision to conduct the Expanded ASRTP by mid-July. Planning and ;
organization were important to minimize the substantial impact six l evaluation teams would have on site activities and resources.
Consultants were selected, District personnel were dedicated as Team Members and Department Coordinators, the evaluation plan and methodology were written and approved, training for all members and coordinators was accomplished, and logistics were determined and implemented. Complete sets of the controlled documents were delivered to the team member locations, administrative services were l made available, and total plant-wide support was given to the 1 Expanded ASRTP. As a result, the Expanded ASRTP started on schedule l with minimal impact on plant activities.
1.4 Purpose Twelve of the 33 selected systems have been completed. The I purpose of this report is to assess the effectiveness of the Expanded ASRTP and to describe the lessons learned with respect to
( the team composition, schedule, process, and methodology based on the results of the completed evaluations. The Exparded ASRTP concerns are compared to the NRC ASRTP findings as an aid in measuring the effectiveness of the program. Lastly, potential generic concerns identified by the Expanded ASRTP teams are i presented.
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2.0 TEAM COMPOSITION 2.1 Initial Team Composition An integrated, multi-disciplined team approach consisting of District employees and consultants was adopted to benefit from the numerous advantages associated with this type of team composition. The Expanded ASRTP Program Manager and Team Leaders were selected fron independent sources along with some indepenrient design engineers to supplement the Auxiliary System, 1 Steam Plant, and Reactor Plant functio'nal areas. Most other team members were District employees who where selected based on their years of nuclear experience and backgrounds with either NSSS, A/E, consultant, construction, or other nuclear power plants. Employees from Nuclear Operations, Nuclear Maintenance, and Nuclear Engineering were assigned to each team as fixed, permanent members. Three Quality Assurance personnel were designated as team members to support all six teams. j I
The System Engineer from the System Review and Test Program j (SRTP) would rotate into the team when his system was evaluated. The area of training would be reviewed by the entire team.
2.2 Integrated (mixed) Teams By combining the plant specific knowledge of systems, programs, procedures, personnel, and information sources of the District Team Members with the consultants' knowledge of design l verification and evaluation techniques, the time needed for each team to prepare has been significantly reduced. The impact of all six teams on plant personnel has also been minimized since l the teams generally know where and how to gain access to needed l infomation. Team Leaders and design engineers add independence l to the effort, and the diverse backgrounds of all Team Members introduce and address varied perspectives and standards.
Another advantage to the mixed tean approach is that Rancho Seco will retain the evaluation expertise, developed skills, and detailed' system knowledge. This information will also be useful for detemining the effectiveness of resolutions and corrective actions at a later date.
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The mixed team approach presents an objectivity challenge to Program Managers, Team Leaders, and Team fienbers. With mixed teans, District employees are tasked with evaluating District systems, programs, procedures, reviews, etc. Consequently, the possibility exists that some potential concerns could be overlooked because the District employee may not examine an area thoroughly for any combination of reasons such as frier.dships, familiarity, personal standards, and perspective. To face this challenge, all Team Members and Team Leaders have been trained on these challenges and on ways to overcome them. The District senior management has given full support to the Expanded ASRTP and has communicated the importance of the project to each Team Membe r. Team Members have been freed of all other responsi-bilities so they will devote their entire attention to the Expanded ASRTP. Lastly, the aggressive questioning process and information exchange that exists at team neetings assist in overcoming these possibilities. With the exception of the system engineer, which is discussed in Section 2.4.2, the teams appear to have effectively met this challenge.
2.3 Fixed Teams l Using fixed teams reduces the amount of retraining that must be conducted, eliminates the start-up time needed for new members to learn the evaluation techniques, increases the synergy developed among the team, and strengthens the team's working relationships. It also retains all the knowledge gained in a functional area in one group. This allows the scope of potential generic issues to be reviewed in both a present and l
future evaluation, as well as determining if the issue existed in a system previously evaluated. These advantages have been -
l utilized in identifying the potential generic concerns in l Section 6.0.
2.4 Partially Fixed Teams 2.4.1 Quality Assurance Department Personnel Three . people from the Quality Assurance Department were assigned to the Expanded ASRTP instead of six for a number of reasons. The major reason was to ensure that the individual from 0A serving as a Team Member remained fully tasked throughout the evaluation.
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This has been accomplished by assigning one QA Team Member l
to two specific teams. This member is required to attend both sets of team meetings and in the process provide a daily mechanism for 1r.troducing intra-team communications.
This member also is utilized to replace other team members who must be absent to meet other commitments such as vacation and simulator training. Discussions with these three Team Members held at the end of the second round of evaluations indicated they felt three people were adequate to support the six team effort.
2.4.2 System Engineers The System Engineer was to be rotated, so that the engineer from SRTP with primary responsibility for the system would be a team memoer. His expertise would be available to the teain from both a historical and plant coordination perspective. The advantages of providing this insight to the team as thought to outweigh the disadvantages associated with frequently having to train a new individual.
During the filst several days of the first set of evaluations, it was noted that the System Engineer had difficulty conducting .an Expanded ASRTP evaluation on his own system. Some of nhe system engineers were too familiar with the system and were not always as objective as they could be. '
i As a result of this Abs.ervation, all members from SRTP serving on the teams are now permanent team members. Most of these individuals were the initial set of assi,;ned System Engineers. All Ei;gineers were assigned pemanently and all received foniial training prior to the start of the second round of evaluations, hst'ortthe System Engineers are the alternate engineers for other systems and understand the SRTP organization. They'have quick access to the primary System Engineer and infor.utton. This action appears to have been effective in eliminating the problems encountered with having the primary System ,
Eng.ineer as a Tearn Nember.
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l 2.4.3 Team Meeting Attendance
, Lastly, the team composition is supplemented by I
" guest" appearances at team meetings. For example, if an in-depth procedure review associated with a particular system was ongoing during the Expanded ASRTP evaluation, the key members of that review would be asked to attend the af ternoon team meetings so both the team and the reviewer would benefit from each other's insight and work. This has j proved to be particularly productive with respect to the B&W System Review effort.
2.5 Other Observations 2.5.1 System Walkdowns Although Team Members conducted tours of their system assessing items such as housekeeping, material condition, use of lead shielding, and control of temporary modifications, the tours only resulted in a good perspective of the system as a whole. The team composition did not allow time for any particular member to conduct a full system walkdown.
As a result, a four man team has been chartered to perfonn 100f, hand-over-hand walkdowns of the Reactor Diant, Auxiliary System, and Steam Plant Systems associded with the Expanded ASRTP. The walkdowns commenced in the middle of the second round of evaluations, and 6re planned to be conducted in parallel with the remaining Expanded ASRTP evaluations.
The objectives of the personnel conducting the walkdowns are to:
- 1) Identify discrepancies between the P&ID and
, associated ECNs with actual plant configuration, l \
- 2) Verify the Operations procedure valve lineup lists 1
- against the P&ID,
- 3) Verify items such as valves, components, and instruments on the Master Equipment List,
- 4) Generate work requests or Engineering Action !
Requests for identified deficiencies and,
- 5) Participate in the daily af ternoon Expanded ASRTP meetings.
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Although the walkdowns enhance the team's information base, all-Team Members still conduct tours of the systems.
The walkdowns are also intended to satisfy NRC commitments i to perform walkdowns prior to restart by the Operations !
Department and SRTP.
2.5.2 Team Stability ,
During the first set of evaluations, team stability '
was effected by operators having to meet NRC simulator and I
training requirements, reassignments of some initial team mobers, vacation and previous personal comitments.
To provide team stability in the operations area, the team members from QA fulfilled the role of evaluating the l Operations area when a specific operator had to meet other I commitments. In addition,'the SRO qualified Operations Coordinator could be called out to assist the team. Team i Leaders also assisted to ensure this area was adequately l evaluated.
Other actions taken were to reschedule vacations and personal comitments where possible, and to replace other team members who could not devote adequate time to the ]
project. All teams, with the exception of the Power l Systems Team, currently have at least two consultants as team members. The Power Systems team did not have stability problems. All new Team Members were formally trained prior to starting the second set of evaluations.
Stability problems were minimal during the second set.
- 2. 5.3 Summa ry In general, the decision to fom mixed and partially fixed teams has proven to be effective. The varied experience and discipline backgrounds of all the members have created an active questioning synergism withiu each team. The training conductec on evaluation techniques and interview techniques appears to have equipped the Team Members with the proper tools necessary to perform the evaluation. One vital factor contributing to this success was the support received from all departments to relieve the District Team Member from all other responsibilities other than the Expanded ASRTP.
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l 3.0 EXPANDED ASRTP SCHEDULE 1
3.1 Initial Schedule The initial schedule provided two days for evaluation preparation,14 days for the evaluation, and three days for preparing the report for a total of 19 calendar days. Systems within each functional area were prioritized using two general guidelines:
(1) Those systems already evaluated during the NRC ASRTP would be evaluated last by the Expanded ASRTP to allow sufficient time for the plant to respond to the concerns identified by the NRC and (2) Those systems thought to be most prone to areas needing improvement would be evaluated first.
In order to meet schedule and provide sufficient documentation on the process, several mechanisms were established including: use of Requests for Information (RIs) to document potential concerns, Document Sheets to record field notes, creation of Department Coordinators to expedite validation of concerns, and local access to sets of controlled documents for Team Member use to minimize loss of time due to record retrieval. Additionally, the Expanded ASRTP teams were organized to be independent of the problen resolutions, allowing Team Members to focus on the next system for evaluation. As a result, as soon as the expanded ASRTP system evaluation report was issued, Team Member involvement essentially ended.
3.2 Requests for Information (RIs) 1 Since potential concerns are continually discussed on a daily basis between Team Members and plant personne'1, they are constantly undergoing revision based on the information obtained. Nonetheless, RIs were instituted as a written mechanism to document the potential concerns in an effort to aid Team Members to meet schedule. Although RIs are considered draf ts until.the evaluation report is issued, because they l always lag the verbal communication process, they were established to: l
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- l. Force the Team Member to focus on a potential concern by writing it down,
- 2. Make it easier for the Department Coordinator to l
understand and validate the potential concern,
- 3. Place potential concerns in a format conducive for inclusion into the report and, l
l 4. Provide an additional source of information for auditing the Expanded ASRTP process.
However, at the end of the first evaluation report, the najority of RI's had not been " acknowledged" as valid by plar.t personnel and consequently had an "open" status.
Several causes were ider*.ified as contributors to this problem
- 1. Department Coordinators did not fully understand what to do with RIs once they received them.
- 2. Department Coordinators spent significant time attempting to identify enrrective action instead of just validating the concern.
- 3. Departnent Coordinators were not provided guidance on how to coordinate potential concerns that crossed departments.
- 4. There was not an assigned coordinator to receive RIs concerning overall plant programs such as material dedication.
- 5. Instructions on the RI forms were misleading.
- 6. RIs were not initially well written. Instead of clearly stating the concern, it was often buried within the RI. All the f acts and background information supporting the potential concern was not always provided; and,
- 7. There were a large number of RIs issued at the end of the evaluation. Although it is normal for more RIs to be generated at the end of an evaluation, the magnitude at the end of the first round was abnormally high. This is attributed to the time it took for Team Members to learn and apply the evaluation techniques.
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The following actions were taken to address the causes leading to the large number of open RIs:
- 1. Two additional Department Coordinator meetings were held, and a lessons learned document was distrib;ted to all Department Coordinators. Additional emphasis .]
4 was placed on their responsibility to validate the l concern.
- 2. A Lead Department Coordinator was established to I resolve coordination problems across departments )
- 3. An Administrative Coordinator was assigned to receive overall plant program RIs j
- 4. The RI forms were revised to provide a clearer format ; and,
- 5. RIs were rewritten and RI lessons learned were distributed to all Team Members and Team Leaders.
Training was conducted on the lessons learned in l writing RIs. Additional emphasis was placed on {
distributing RIs as early as possible during the j evaluation.
3.3 Docunent Sheets ;
i Docum'nt Sheets were instituted to provide a format '
for Team Mubers to record field notes. Their purpose is to provide a sense of the various items checked and the perspective from which they were checked. They have also J proven useful as a source of information for supporting 1 potential generic issues.
3.4 Reports Use of RIs, Department Coordinators, and local acces:
to controlled documents were aids to expedite the validation of concerns and prepare the team members as much as possible for writing the report. However, the large number of RI's open at the end of the first set of systems presented a problem. ]
A significant amount of time would have to be devoted to validate the identified Expanded ASRTP potential concerns. Since the Expanded ASRTP Team Member involvement ended with publication of the report, another group would have to determine if the responses provided by Department Coordinators adequately addressed a concern. The group assigned to perform this function would not be as i knowledgeable of the concern as the actual Expanded ASRTP team.
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Consequently, ten additional days were provided af ter issuance of the report for the first set of evaluations to allow sufficient time for Departnent Coordinators to reach agreement with Team Members on the validity of the concerns, As a result, all concerns except one were acknowledged as valid. At the end of this period, the l report was reissued using a slightly different format ir.
' order to make it easier to focus on the specific concern.
1 Ten days, however, were more than adequate and have been reduced to three days for the second set of systens.
Consequently, the overall schedule has been modified to allow sufficient time to reach agreement of concern validity. The schedule now is two days for preparation,14 days for the evaluation, three days for the draf t report, and an additional three days to validate the concerns. The evaluation report will then be issued as soon as possible.
During the additional three days added to allow time for Department Coordinators to validate the concern, the Team Members prepared to start the next system evaluation as ,
stated on the initial schedule.
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i 4.0 EXPANDED ASRTP PROCESS AND METHODOLOGY 4.1 Initial Plan The organization, schedule, and roles and responsibilities of individuals associated with the Expanded ASRTP were approved and issued in the Expanded ASRTP Evaluation Plan. The Expanded ASRTP Methodology, providing guidelines on how to conduct the evaluation and what items to check, was also approved, issued, and trained on prior to commencing the first round of .
evaluations.
4.2 Revisions l The Expanded ASRTP Evaluation Plan and Methodology have proven to be generally effective in providing guidance to Team Members. Two revisions have been needed to:
- 1. Clarify the roles of Department Coordinators, i
- 2. Revise the RI and Document Sheet formats to be more {
useful to the Team Members and Department Coordinators,
- 3. Clarify the role Team Members fulfilled in determining the scope of potential generic concerns,
- 4. Revise the report format; and,
- 5. Clarify the purpose of the twelve system assessment.
In order to ensure adequate distribution of the revisions, I the Expanded ASRTP Evaluation Plan and Methodology were made controlled documents.
4.3 R1 Tracking Systems All concerns identified by the Expanded ASRTP were to be entered into an established plant tracking system for resolution.
The in.itial plan stated the RIs would be tracked on their own RI data base system. This decision was revisited during the first round of evaluations and a new decision was made to track the RIs as concerns on the Restart Scope List tracking system after the evaluation reports were issued.
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I The RSL process was modified to send all Expanded ASRTP identified concerns to the Plant Advisory Group (PAG)for
) preliminary prioritization prior to determination of corrective actions by Department Coordinators. Priority 1, 2R and 3R (i.e.
restart items) concerns will be routed for identification of resolution and corrective actions. The other RIs would be entered into the RSL process and corrective actions would be determined on a time scale appropriate for its priority. ,
l Of the 47 concerns presented to the PAG from the first set of evaluated systems, about 47% were prioritized as Priority 1 or 2R. Of the 44 concerns in the second set of evaluated ;
systems, about 65% were judged restart items by the PAG. !
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5.0 IDENTIFIED CONCERNS .
5.1 Introduction 1
This Section attempts to compare the results of the Expanded ASRTP concerns with the NRC ASRTP findings as an aid towards measuring the effectiveness of the Expanded ASRTP. The type, depth, and nature of the findings and concerns are compared.
l 5.2 Type and Depth of Findings and Concerns There is a strong similarity between the findings and concerns. For example, the ASRTP inspection addressed the
! adequacy of testing to demonstrate requirements. In particular, it was noted that past testing of the AFW pumps did not demonstrate that they were capable of providing the flow required by Technical Specifications. During the Expanded ASRTP similar concerns were identified. For example, the existing NSRW system design does not provide instrumentation for determining the flow rates through system components. Another concern noted the NSCW flow rate through the shell side of the decay heat removal coolers may have exceeded the maximum recommended value.
Additionally, the Expanded ASRTP identified there has not been a test to determine if the pressurizer can be cooled down using pressurizer auxiliary spray from the decay heat pump.
The Expanded ASRTP teams also discovered that some of the SSR resolutions lacked sufficient engineering and operational perspective. For example, the SSR solutions posed for some of the Radiation Monitoring System problems may not have included all the pertinent operational infomation in procedures.
Additionally, testing of NNI power supply capacity and shunt switch coordination did not thoroughly test the functions.
Another example is that the designed test for the Main Steam System backup air bottles for the Atmospheric Dump Valves would not prove the valves would work under operating conditions.
Similar examles can be provided addressing the areas of adequacy of design considerations, design calculations, ASME Section XI compliance, and USAR commitments 5.3 Nature of the Findings and Concerns l Since the corrective actions and resolutions have not been identified for all the Expanded ASRTP concerns, it is not ,
possible to divide the concerns into categories such as i hardware, people, procedures, etc. j I
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I An attempt, however, was made to arrive at an independent and knowledgeable conoarison of the approximate numbers of concerns and findings that were the responsibility of Specific depa rtments . The results were very comarable as indicated below:
Responsible- NRC Expanded Department 171P TSR Tf' Engineering 45% 50%
(design)
Surveillance / 20% 15%
SRTP Operations / 10% 10%
Training System / 10% 10%
Change Control Maintenance 5% 10%
1 QA/QC 10% 5%
5.4 Other Observations 1
The NRC ACRTP inspection appears to have had more tindings !
in the areas of quality assurance, organi.zation and management, ,
and prioritization of problem resolutions. Unless the priority I of a SSR resolution appeared to be wrong, the Expanded ASRTP Progran did not address the priority assigned to a SSR reso lution.
Although the Expanded ASRTP has not identified specific concerns mentioning Quality Assurance, there have been concerns that reflect upon Quality. The generic concern of commercial grade material dedication and a concern addressing the inadequate closecut of open QA audit items for inverters
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purchased from a non-approved vendor are examples.
Additionally, generic concerns with respect to vendor manuals and the motor operated valve refurbisinent program provide additional indications. Nonetheless, the observation remains valid and the Expanded ASRTP teams will give more attention.on the Quality Assurance area.
Another observation was that the Expanded ASRTP teams placed more enphasis on reliability issues and were more specific in the areas of operations procedures and training than the NRC ASRTP. Examples include the long term layup of the Main Feedwater System and the excessive tripping of the heater drain l pumps due to excessive tube plugging in the high pressure feedwater heaters. The potential water hammer concern in the Decay Heat System and the structural support of the decay hest cooler bypass line concern are other exanples.
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6.0 POTENTI AL GENERIC ISSUES 6.1 Initial Identification of Generic Concerns When a potential generic issue is identified, it is added to a list that is distributed to Team Leaders. As they arise, potential generic concerns are discussed at daily and special Team Leader meetings. Team Members are made ware of the potential for a generic concern and are asked to determine if I the concern exists in the system under evaluation. The potential generic concerns can be identified from a number of sources including the Progran Manager, Team Leaders, Team Members and the Engineering Response Team. In addition, the Nuclear Engineering Department has provided a list (Attachment 3 of the Expanded ASRTP Methodology) of issues each team reviews during an evaluation to determine the applicability of the
' potential concern to the system.
Few potential generic concerns were issued during the first twelve evaluations because the Expanded ASRTP Program Manager required Team Leaders to substantiate that the potential concern was generic.
Unless objective f acts could be provided indicating '.he concern existed in other systems, the Team Leader was required to limit the potential concern to the system under evaluation.
For example, the Control Systems team generally felt that the plant had an inadequate setpoint control program. During the evaluation of the ICS system, however, the tean only had facts associated with the ICS system. Consequently, the concern issued in the ICS evaluation report was confined to ICS setpoints.
However, the Control Systems Tean found a similar setpoints concern in the NNI evaluation. Additionally, other teams j identified facts indicative of setpoint control problems in l other systems. As a result, the plant setpoint control program has been identified by Expanded ASRTP as a generic concern in this report.
l The~ method used to identify a generic concern is an upper l l management oversight review of the RIs, Document Sheets, and l l reports. The review is conducted by the Team Leader, Program l Manager and the Director of Nuclear Technical Services. Results of that review for the first twelve systems are contained in this section of the report. Attachment 2 provides the RIs documenting the concerns.
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6.2 Generic ,oncerns A list of the specific potential generic concerns is provided below with the applicable RI number indicated in parentheses after the stated concern.
6.2.1 Portions of the Updated Safety Analysis Report are not current and contain inconsistencies. (RI # 172) 6.2.2 Neither the Preventive Maintenance nor the Environntental Qualification program ensures the periodic replacement of component parts is always accomplished per vendor recommendations. (RI # 173) j 6.2.3 Numerous documents such as Engineering Change Notices, Work Requests, Non-Confonnance Reports and procedures contain references that are out-of-date, inaccurate, or missing. (RI # 174)
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6.2.4 Numerous calculations contain errors in assumptions, l methods, and math. Most were indicative of inattention to detail that did not affect the design purpose of the calculation. (RI 175) 6.2.5 Numerous discrepancies were identified with respect to the quality of drawings. (RI # 176) 6.2.6 There is not an adequate program to document. l justify, or control system setpoints. (R1 # 171) 6.3 Potential Nuclear Engineering Department Issues j 1
The Expanded ASRTP committed to review a selected set of items for the Nuclear Engineering Department to aid in determining the generic applicability of some items previously identified by the NRC. The list of items the Expanded ASRTP agreed to evaluate for every applicable system reviewed is shown on Attachment 3 of the Expanded ASRTP Methodology. Results of this review are stated below.
6.3.l Of the approximately 31 specific issues listed on Attachment 3, 21 were not identified by the Expanded ASRTP teams as recurring issues.
6.3.2 Abcut seven of the NED issues were found in many of the systems evaluated. Problems were found with calculation methods, assumptions, references, and acceptance criteria. Similarly, numerous design drawing errors were noted that did not reflect as-built conditions. Lastly, there was a setpoint control program concern. All these were identified as generic concerns in Section 6.2.
Other generic concerns were expressed witnin -
individual system evaluation reports if the particular team had sufficient justification to determine the concern was generic. For example, the Seal Injection and Makeup report identifies generic concerns with vendor manuals, i
dedication of commercial grade parts, and the motor l operated valve refurbishment program.
Consequently, the Expanded ASRTP teams feel that the Nuclear Engineering Department should consider each of these issues as broad programmatic concerns.
6.3.3 Some of the Nuclear Engineering Department issues were found to a moderate degree but not of sufficient quantity for the Expanded ASRTP teams to justify identifying them as generic cencerns. These issues will be evaluated during the remaining sets of evaluations to determine if identifying them as generic concerns is justified. The specific issues are listed below:
- 1. There were some instances noted of design packages that were approved without completion of Operations and Maintenance pre-walkdowns.
- 2. Some Engineering Change Notices were closed out prior to complete implementation of required work.
- 3. Some difficulty was experienced determining classification of P&ID pipe boundaries.
- 4. Some instances were noted where design analyses performed for transients did not consider all component or system capabilities.
- 5. Some of the system evaluations determined that the system may not have the ability to supply required flow for all operating modes; and,
- 6. Mild environment qualification questions arose which have not yet been fully answered.
6.3.4 Other issues were identified by the Expanded ASRTP for future follow-up to determine if the issue may be generic. Examples of these issues follow:
- 1. Accuracy of the Special Test Procedures to fully test the stated functions in the System Status Reports,
- 2. Use of teflon tape on tubing installations,
- 3. Hunan Factors issues, and
- 4. Fuse Control.
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7.0 CONCLUSION
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7.1 Overall conclusions The overall effectiveness of the Expanded ASRTP is evident in the nature, number, and variety of its results. The Expanded ASRTP teams are finding concerns that are similar to the finding made by the NRC ASRTP with respect to type, depth, and scope.
Additionally, the independent Technical Oversight Committee and the independent Nuclear Advisory Committee have both reviewed the expanded ASRTP and have separately reported to the Chief Executive Officer Nuclear that they feel the program is meeting its objectives. The District agrees with these determinations and feels that it is meeting its commitment to the NRC to conduct ASRTP-type inspections.
The District also believes the program has been beneficial and commits to complete the remaining selected systems prior to restart. No other plant in the country has conducted as many of these evaluations as Rancho Seco already has conducted. Rancho Seco will be the first plant in the country to have a safety system functional evaluation on all its systems important te safe operation of the plant.
j The District intends to remain the leader in this area by also conducting a long range post restart Expanded ASRTP on the majority of all plant systems.
Finally, the District believes the Expanded ASRTP provides an inportant input into the management decision regarding i operational readiness and safety of Rancho Seco, After appropriate corrective actions are identified, prioritized, and implemented, the District can feel confident about the functional ability of its systems to meet their design safety requirements.
7.2 Specific Conclusions The teams found that many review and verification type programs have been conducted and completed. Most of these are studies that, in the teams' opinion, have been well done and l
provide additional insight into the plant's operational readiness. Examples include the Deterministic Failure Analysis, the Precursor Review, the B&W Safety Performance Improvement Program, and QA vertical audits.
Many programs and procedures were and are undergoing revision during the Expanded ASRTP. Consequently, the teams .
used the latest revision of controlled documents as the " anchor" l point for the evaluations. When draf ts were, utilized, such as ;
many of the Design Bases Documents, team members noted tnis on l the RIs. i 1
The effectiveness and success of the Expanded ASRTP teams are the result of total plant support. No one person or group can be credited for the progress made during the effort, it has been the result of a positive plant-wide attitude to cooperate with and support the project.
12 SYSTEM EASRTP ASSESSMENT j
8.0 ATTACHMENTS I
l 8.1 Status of Generic Concerns l l
8.2 Generic Concern Requests for Information i
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STATUS OF GENERIC CONCERNS RT flumber Status 1 71 Closed 172 Acknowledged 173 Acknowledged 174 Acknowledged 176 Acknowledged 176 Acknowledged ATTACHMENT 1 4
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REQUEST FOR INFORMATION(RI)
RI NO: 171 SYSTEM CODE: GENERIC ISSUE DATE: 08-27-87
SUBJECT:
CONTROL OF CALIBRATION SETPOINTS DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR / EXT: T. TELFORD/3849 TEAM LEADER / EXT: D_. HUMENANSKY/3995 POTENTIAL CONCERN / QUESTION There is not an established program to document, justify, or control system setpoints.
- 1. it! 028 on ICS setpoints for steam bypass system valves 9ADVs, TBVs, and MSRVs). Documents supporting selection of the overlapping setpoints could not be produced.
Additionally, several discrepancies were noted among the documents for the setpoint values and the setpoints are not controlled.
- 2. RI 036 on ICS control of setpoints documentation.
Modification program does not address effects of modifications on setpoints. Setpoint Loop Error Analysis for setpoints unavailable. A module function document does not exist.
- 3. RI 036 on NNI concerns inadequate setpoints documentation similar to the ICS concerns. Numerous conflicts between l various documents such as Design Bases Reports and Process Standards listed.
- 4. Microfilm copies for ICS calibration records are incomplete in that setpoint infonnation is ambiguous and pages are missing.
S. RI 108 discusses lack of sufficient information to verify the MFW high pressure trip, time delay and alarm setpoint.
- 6. RI 112 written to address lack of setpoint bases in the MFW system.-
- 7. A.50, Rev.19, pg. 8, item 4.3.4 states "PV-30702 is set to control steam pressure up to approximately 40% power..."
but process standards do not address and the PM work request (04800) does not list a specific setpoint.
- 8. RI 138 addresses setooint issues identified in the VBS evaluation with respect to inverter low and high voltage alarms.
Attachment 2 l I
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- 9. During the review of the DHS and SIM systems, setpoint related bases documents and calculations could not be located for Process Standards.
- 10. RI 098 addresses the Spray Pond Levels indicate that the wrong tetpoint was determined due to use of incorrect calculations.
The PAG recently addressed this as a generic concern and
' prioritized development of a program and verification of Tech.
Spec. related setpoints a restart item.
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REQUEST FOR INFORMATION(RI)
RI NO: 172 SYSTEM CODE: GENERIC ISSUE DATE: 08-27-87
SUBJECT:
INCONSISTENCIES WITH USAR DEPARTMENT: LICENSING COORDINATOR / EXT: J. DELEZINSKI/3909 TEAM LEADER / EXT: D. HUMENANSKY/3995 POTENTIAL CONCERN / QUESTION i Portions of the USAR are not current and contain inconsistencies.
Almost every system evaluated by the EASRTP found inconsistencies in the USAR. Some statement in the USAR did not reflect as built plant conditions, some did not correspond to Techncial Specifications or the Design Bases Documents, and others contained inaccuracies. Some examples are provided below:
- 1. Para. 7.3.2.1. item C lists " Primary and secondary shielding" as being within the definition of safety related instrumentation and wiring required to function during and subsequent to a LOCA or steam line break. This classification should be deleted since it does not apply to instrumentation.
- 2. Sect. 7.2.3.3.1. incorrectly states that ICS controllers go to manual on loss of power.
- 3. RI 15 addresses the inconsistencies in assumptions used in the Main Steam Line Break Analysis.
- 4. RI-ll8 addresses actual operation of SFAS valve closure or opening to USAR description. Modification has been in existence for many years.
- 6. USAR Section 8.2.2.7. does not describe a modification made to odd .120 VAC distribution panels and 25KVA inverters in 1983.
Licensing has several actions planned to address this concern Attachment 2 l
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REQUEST FOR INFORMATION(RI)
RI N0: 173 SYSTEM CODE: GENERIC _ ISSUE DATE: 08-27-87
SUBJECT:
SHELF LIFE _
DEPARTMENT: MAINTENANCE COORDINATOR / EXT: J. DARKE/4727 TEAM LEADER / EXT: D. HUMENANSKY/3995 POTENTIAL CONCERN / QUESTION Neither the preventive maintenance nor the environmental qualification program ensures the periodic replacement of component l
parts is always accomplished per vendor recommendations. .
Some parts reconwnended by the vendor to be replaced on a periodic basis are not addressed at all in the plant PM program. Other parts are addressed but the schedule does not adequately ensure the parts are replaced at the prescribed intervals. Examples are provided below:
- 1. PM tasks for replacement of NNI Si and S2 does not address shelf life. Issued as RI 152.
- 2. PM task 05608 for ICS replaces $1 and S2 every 5 years. No mechanism is in place to check actual expiration date of installed device and date device leaves the factory is not monitored to detennine remaining life for which the device is qualified.
- 3. H9-54727 LS1 & LS2 requires gaskets replaced every 1.32 years. The only PM addressing replacement of these parts in the CR/TSC HVS is a solenoid replacement of 1460 days.
4 RI 075 noted differences in the replacement periods specified in MIMS and MARSS.
- 5. Elgar 120VAC inverter shelf life considerations not in the PM program (RI 146).
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I REQUEST FOR INFORMATION(RI) ,
RI NO: 174 SYSTEM CODE: GENERIC ISSUE DATE: 08-27-87
SUBJECT:
PROCEDURES REFERENCE OUT-0F-DATE, WRONG OR NON EXISTING
~~UT)CUMENTS DEP ARTMENT: NUCLEAR ENGINEERING COORDINATOR / EXT: T. TELFORD/3849 TEAM LEADER / EXT: D. HOKENANSKY/3995 POTENTIAL CONCERN /0VESTION Numerous documents contain references that are out of date, inaccurate, or deleted.
- 1. Some documents are deleted without reference to the document that supercedes. Examples are AP # and RSAP 803; and NEP 6118 Rev. 3 and RSAP 305. This causes concern when documents such as work requests and FPRs reference the superceded document.
- a. AP 650 superceded by MAP 09 is another example
- 2. Procedure C.34 Rev. 3 " Temporary ADV Nitrogen sytem:, C.37 Rev. 1, "ADV manual Loading Station Operation", and C.36 Rev. 2
" Emergency Repair of ADV Air Hoses Af ter a Fire", need to be deleted. Equipment has been removed.
- 3. RI 063 addresses referencing non-existing design criteria.
Total number of references 54 Documents found void 13 Documents found wrong 2 Documents found closed 19 Documents not located 14 Of 54 documents referenced, 34 no longer apply (63%) and 14 were 'not located in either of the plant document centers, open or closed (26%). Thnus 48 of 54 documents (89%)
could not be located.
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i REQUEST FOR INFORMATION(RI)
RI NO: 175 SYSTEM CODE: GENERIC ISSUE DATE: 08-27-87 )
SUBJECT:
CALCULATIONS APPEAR TO CONTAIN PROBLEMS DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR / EXT: T. TELFORD/3849 TEAM LEADER / EXT: D. HUMENANSKY/3995 POTENTIAL C0NCERN/0VESTION Numerous calculations contain errors in assumptions, methods and math.
- 1. Calc Z-ICS-E0640 envelopes Calc Z-ICS-E0598 but are not cross-ref erenced. Calc 0640 uses old infomation for the breakers. ECN R-0469 was closed approximately 5 months before cale was initiated. As a result Calc 0640 does not j support replacing the breakers, neither does Calc 0598. RI i 096 on ICS breakers for 118 VAC power supplies was issued in ICS report.
- 2. RI 028 on Setpoints for the Main Steam System Valves discusses discrepancies with Cales. Z-EFI-10157, and
-10146,
- 3. RIO37 addresses the backup air supply for ADV calc.
- 4. Calc Z-FWS-M1778 has a mathematical error.
- 5. Calcs Z-SIM-M-0188 had some incorrect assumptions.
- 6. Calc Z-PLS-M0184 does not reflect the most limiting conditions. Calc also indicates there would be insufficient NPSH under worst case conditions.
- 7. Calc Z-SIM-0321 uses a questionable safety factor.
- 8. RI 032 & 034 addressed calculation concerns with respect not considering all loads in the NRW system.
- 9. Calc Z-NRW-M0245 has level inconsistencies with respect to Calc Z-NRW-M0258.
- 10. Calc Z-NRW-M0157 does not have a filtration unit design basis.
- 11. RI 064 addresses calculations concerning heat loads for NRW.
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Attachment 2
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REQUEST FOR INFORMATION(RI)
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RI NO: 176__ SYSTEM CODE: GENERIC ISSUE DATE: 08-27-87
SUBJECT:
DRAWING DISCREPANCIES I DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR / EXT: T. TELFORD/3849 TEAM LEADER / EXT: D. HUMENANSKY/3995 i POTENTIAL CONCERN /0VESTION There are numerous discrepancies in the drawing control program.
A few examples follow:
- 1. Schematic N15.07-57 on NNI ABT operation is incorrect in that it shows pressure switches connected to tne wrong l
buses.
- 2. Review of Schematics N15.07-62 Rev.7, -63 Rev.1 -67 Rev. l 3, and -68 Rev. 7 on NNI revealed:
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- a. Non-standard designators for relay coils are used, i
- b. Coils are designated similar to indicator lights
- c. Designators do not agree with Legends :
- d. Inability to follow some circuits on the Reactor !
Controlling Average Temperature for Automatic selection of controlling signal for ICS
- 3. NNI drawing shows PSH 21092 module 4-4-7 labeled as decay heat interlock. It is, instead, the Pzr Emergency MOV Relief Interlock. .
4 Isometric Drawing 30802-6-EA is for a steam pipe on the MSS that supplies K-308 AFW pump terry turbine. The drawing incorrectly lists the line number as on the DHR system.
- 5. Drawing E-108, Sh 11 Rev. 6 one line 125 VDC and 120VADC l
distribution system shows SIGA-1 and SIGB-1 energized from inverters vice their respective power sources from DC pane.ls_A,B,C,0 and E.
- 6. Safety class breaks are not clearly shown on M-532 Rev. 10
" Flow diagram of Steam Generator System" on line 32124-20-0B. Discrepancies also noted with this drawing and the isometric of the system (#32134-20-DB Rev.2) that lists PDTs as 2036BA and 20368B and M532 lists them as 20568A and 205688.
- 7. RI 060 references a drawing inaccurancy opn E-368 Sh 7A.
- 8. RI 035 addresses problems with fuse infomation provided on drawings l
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v s in the plant not indicated as .
cked on c P&ID
- 10. Drawing control problems have been previously identified in several other reports such as INP0 evaluations, QA Vertical Audits and NRC inspections.
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Att.achment 2
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