ML20239A034
| ML20239A034 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/18/1987 |
| From: | Croley B, Humenansky D, Moyer R SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML20238F564 | List: |
| References | |
| NUDOCS 8709170035 | |
| Download: ML20239A034 (30) | |
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EXPANDED AUGMENTED SYSTEM REVIDi'AND TEST PROGRAM l
(EXPANDED AStTP) l I
l EVALUATION
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IhTEGATED CONTROL i
SYSTEM l
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l SUBMITTED BY: _,g.-
OATE-8'/ 7J'?
RICHARD H0YER
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,{
TEA'M LEADER CONCURRENCE.:
A u.d hm DAIE:
Y-0 -T7
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[ DAVIG HUMENANSKY FXPMDED ASRTP PROGRAM MNAGER I
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/t+[A' CAIEi "/ / /u-/N' l
l CONCURRENCE:
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B08 CROLEi
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DIRECTOR, NUCLEAR'TECMICAL SERVICES l
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8709170035 07j90ji2 i
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I TABLE OF CONTENTS 1
I Pace Number i
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1.0 INTRODUCTION
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2.0 ' PURPOSE 4
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3.0 ' SCOPE 5
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4.0 OVERALL RESULTS AND CONCLUSIONS 6
1 5.0 SPECIFIC CONCERNS 8
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5.1 Acknowledged (Valid) Concerns I
i 5.2 Open (Potential) Concerns i
i 6.0 ATTACHMENTS 9
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1 6.1 List of Documents Reviewed 6.2 Status of RIs 6.3 Detailed Observations - Requests for Information 2
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r EXPANDED AUGMENTED SYSTEM REVIEW AND TEST PROGRAM EVALUATION OF THE INTEGRATED CONTROL SY3 TEM
1.0 INTRODUCTION
The Rancho Seco Expanded Augmented System Review and Test Program
[ASRTP] evaluation effort involves an assessment of the effectiveness of the System Review and Test Program (SRTP] and an analysis of the adequacy of ongoing programs to ensure that systems 1
will continue to function properly after restart.
The Expanded ASRTP is a detailed system by system review of the SRTP as implemented on 33 selected systems and an in-depth review of the engineering, modification, maintenance, operations, surveillance, inservice testing, and quality programs.
It also conducts a review, en a sampling basis, of many of the numerous ongoing verification and review programs at Rancho Seco.
Six multi-disciplined teams composed of knowledgeable and experienced personnel are tasked with performing the Expanded ASRTP.
Each multi-disciplined team consists of dedicated personnel with appropriate backgrounds to evaluate the operations, maintenance, engineering, and design functional areas.
Independence, perspective, and industry standards provided by team members with consultants, architect engineer and vendor backgrounds are joined with the specific plant knowledge of SMUD te.am members.
Each team performs an evaluation on a selected system using the same fundamental evaluation techniques employed by the NRC in the ASRTP inspection.
System Status Reports are used as the primary source of leads for the teams. They are augmented with references to available source and design bases documents as needed.
Team synergism and communication is empnasizea during :ne process in order to enhance the evaluation.
Each team prepares a report for each completed selected system evaluated.
This report is for the Integrated Control System (ICS).
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2.0 PURPOSE The objectives of the Expanded ASRTP evaluation are to (1) assess the adequacy of activities and systems in support of restart and (2) evaluate the effectiveness of established programs for ensuring
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safety during plant operation after restart.
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3.0 SCOPE To accomplish the first objective, the Control Systems team evaluated the Integrated Control System to determine whether:
1.
The system was capable of performing the functions required by its design bases.
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2.
Testing was adequate to demonstrate that the system I
would perform all of the functions required.
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System maintenance was adequate to ensure system operability under postulated accident conditions.
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Operator and maintenance technician training was adequate to ensure proper operations and maintenance of j
the system.
5.
Human factors relative to the system and the system's I
supporting procedures were adequate to ensure proper system operations under normal and accident conditions.
To accomplish the second objective, the Control Systems team l
reviewed the programs as implemented for the Integrated Control i
System in the following functional areas:
1.
Systems Design and Change Control 2.
Maintenance 1
3.
Operations and Training 4.
Surveillance and Inservice Testing l
5.
Quality Assurance
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Engineering Programs l
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i The Control Systerns team reviewed a number of documents in preparation for and during the Expanded ASRTP evaluation.
This list of documents is found in Attachment 6.1.
i The primary source of leads for the team were the problems j
identified in the ICS System Status Report.
Various source i
j documents such as the USAR and Technical Specifications and l
available design bases documents were reviewed as needed to augment l
the information needed by the team.
I The evaluation of the Integrated Control System included a review of l
pertinent portions of support systems that must be functional in order for the Integrated Control System to meet its design objectives.
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l 4.0 OVERALL RESULTS AND CONCLUSIONS l
The more significant issues identified pertaining to the adequacy of the SRTP and the effectiveness of programs to ensure continued safe 4
operations after restart are summarized below.
The summary focuses en the weaknesses identified during the evaluation. Attachment 6.3 provides detailed find'ngs by providing the Request for Information (RI) forms that are used by the Expanded ASRTP teams to identify potential concerns during the evaluation.
Section 5.0 lists the specific concerns identified by the team.
The numbers in brackets l
after each individual summary or concern refer to the corresponding l
RIs in Attachment 6.3.
4.1 Engineering Design 4.1.1 ICS devices may be calibrated to incorrect setpoints.
ICS devices are presently set using information from calibration records which are not controlled documents. The calibration records provide no source for their setpoint content and no mechanism exists in design modification procedures to ensure setpoint changes are documented and incorporated into the plant design.
Incorrect setpoint actuations could result in unexpected plant control or prevent actuations from occurring at their required design values.
(RI-036) 4.1.2 The intended r quential operation of Turbine Bypass Valves (TBVs), Atmospheric Dump Valves (ADVs) and Main Steam Relief Valves (MSRVs) may not be achievable due to possible overlapping of the actuation setpoints as a result of setpoint tolerances. Of particular concern is the possible opening of ADVs prior to the TBVs in the event of tube rupture which could cause unnecessary atmospheric releases.
Compounding the problem is a large number of discrepancies i
in the setcoints and their tolerances due to a lack of a single setpoint source document (Ref: Item 4.1.1) ano j
calculations which lack consistency in approach and cross referencing of source information.
(RI-028) 4.1.3 Inadequate design analysis and documentation exists for determination of adequate sizing of Integrated Control System (ICS) breakers 1J04 and 1C07.
ICS System Status Report Problem No.18 discussed discrepancies in the two breaker sizes (30 amp vs 40 amp) and provided a resolution of analysis to determi.ne the correct breaker capacity.
However, the conclusion of the resulting analysis did not support the replacement of the 30 amp breaker with a 40 amp breaker and did not determine actual loads in reaching the conclusion. This may reduce plant availability / reliability and may damage equipment if the breaker is oversized.
(RI-096) 6 L
OVERALL RESULTS AND CONCLUSIONS (Continued) 4.2 Programmatic Concerns 4.2.1 Some Engineering Change Notices (ECNs) are being closed without all modifications being performed, which could lead operators to take inappropriate or ineffective actions.
ICS System Status Report Problem #46 identified the necessity of i
I replacing shunt trip switch labels for ICS and NNI.
The ECN incorporating the modification was closed without the labels for NNI being replaced.
(RI-039) 4.2.2 No program exists to recali or void active work requests for Preventive Maintenance (PM) tasks when a new or modified PM task is entered into the system.
PM tasks are not identified by revision, and the potential exists for the earlier work request based on the superseded PM task to be worked after the revised PM task work request wh' a could I
cause incorrect maintenance to be performed.
(RI-074)
I 4.3 Testing 4.3.1 The ICS functional test appears inadequate to verify errors in the system which may have resulted due to the massive rework of terminations resulting from an identified cause of the December 26, 1985 trip as noted in ICS System Status Report Problem #10. Quality Control inspection was requested and performed on the quality of the terminations only.
Recent documented findings show that some terminations were not made to their correct locations.
This is of particular concern since the team noted that a plant trip after restart resulted at Davis-Besse from an ICS wiring discrepancy which was undisclosed during ICS functional testing. (RI-080) i i
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5.0 SPECIFIC CONCERNS A list of the specific concerns the Expanded ASRTP team believes are new concerns not previously identified for resolution follow:
5.1 Acknowledged (Valid) Concerns 5.1.1 The intended steam bypass system operation to open Turbine Bypass Valves (TBVs), Atmospheric Dump Valves (ADVs), and Main Steam Relief Valves (MSRVs) sequentially may not be achievable due to overlap of setpoints when the setpoint tolerances are taken into consideration.
(RI-028) 5.1.2 Integrated Control System devices may be calibrated to incorrect setpoints.
(RI-036) a)
ICS setpoints are not in Process Standards and the plant could not produce another controlled setpoint document.
b)
Procedures do not address impact of modifications on instrumentation setpoints.
5.1.3 Some Engineering Change Notices are being closed without all modifications being performed.
(RI-039) 5.1.4 Superseded Preventive Maintenance (PM) tasks may be worked ev'en though the respective new or modified PM tasks have been entered into the system.
(RI-074) 5.1.5 The ICS functional test appears inadequate to detect errors resulting from termination rework.
(RI-080) 5.1.6 The Automatic Bus Transfer (ABT) is desigr.ed such that a situation could exist where ICS AC loads are lost but ICS DC loads remain energized causing uncertainty in ICS control.
(RI-081) 5.1.7 No procedures exist for I&C maintenance to ensure calibration data sheets are microfilmed in accordance with Records Management requirements.
(RI-095) 5.1.8 The ICS breakers lJ04 and 1C07 may not be sized properly due to inadequate analysis.
(RI-096) 5.2 Open (Potential) Concerns None 8
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6.0 ATTACHMENTS 6.1 List of Documents Reviewed 6.2 Status of RIs 6.3 Detailed Observations - Requests for Information i
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L____________-_________
l LIST OF DOCUMENTS REVIEWED 1.
SSFIs j
A.
ANO B.
Oconee
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C.
Palisades D.
Pilgrim E.
Rancho Seco F.
H.R. Robinson G.
Three Mile Island 1 H.
Trojan I.
Turkey Point 2.
System Status Reports A.
Integrated Control System (revision 1) 8.
Main Steam System (revision 1)
C.
Main Feedwater (revision 1)
D.
Non-Nuclear Instrumentation (revision 1) 3.
SMUD Vendor Technical Manuals A.
N21.01-il6 (ICS Volume 18)
C.
D.
N21.01-112 (ICS Volume 2)
E.
E32.09-IM01 (Automatic Buss Transfer Devices) 4.
Drawings A.
N21.01 series (ICS Schematics) 8.
E203 shts 99(r2), 100, 101 C.
M-530 snts i (r13), 2 (rl2), 2A (r3), 3 (r!7)
O.
H-532 shts 2 (r6), 3 (r6)
E.
Pink Drawings in N21.01 series for ECNs:
(1) A-4058 (2) A-5415W,Y,Z (3) R-0823 (4)
R-0824 (5)
R-0825 (6)
R-0826 (7)
R-0861 (8)
R-0878 (9)
R-0927 (10 R-1217 ATTACHMENT 6.1 10 l
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LIST OF DOCUMENTS RE'!IEWED 5.
Updated Safety Analysis Report Chapter 7 (ICS) 6.
Nonconforming Reports A.
S-5263 B.
S-6603 C.
S-6867 7.
Licensee Event Report 1
A.
86-10 8.
85-16 t
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Quality Control Instrumentation 12 (QCI-12), r2 9.
Nuclear Engineering Procedures A.
NEP-5435 ICS System Design Bases, r1 B.
NEP-5100 Series Construction Specs C.
NEP-4109 Configuration Control, r5 D.
NEP-6118 E.
NEP-5444 MSS System Design Bases, r0 10.
ICS Testing Documents A.
System Test Matrix B.
Test Outlines for:
(2) STP.564 r0 (Loss of ICS, NNI)
(3) STP.778 r0 (ICS function Test) j i
C.
Test Procedures for:
(1) STP.660 r0 (2)
STP.778 r0 11.
Procedures A.
Administrative Procedures (1) AP.4A, Safe Clearance Procedure, r5 (2) AP.44, Plant Modification, r11 (3) AP.100 series (Process Standards), r11 ATTACHMENT 6.1 (Continued) 11 l
LIST OF DOCUMENTS REVIEHED B.
Rancho Seco Administrative Procedures (1) RSAP.601 (2)
RSAP.803 C.
Operating Procedures (1) A.71 ICS Operating Procedure, r9 (2) 8.2, r38 (3) 8.3, r29 (4)
B.4, r40 D.
Casualty Procedures l
(1) C.13A, r6 (2) C.138, r4 l
l (3) C.40 Loss of ICS Power, r2 draft 1
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Annunciator Response Procedure (1) ARP.H2PSB, r15 F.
Modification Procedures and Inspection Standards 302 12.
Engineering Changes (ECNs, DBRs) l A.
R-0357A,B B.
R-0359A, B C.
R-0459 0.
R-0472 l
E.
R-0477 l
F.
R-0580 G.
R-0822 l
H.
R-0823 I.
R-0826 l
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R-0828 K.
R-0861 L.
R-0878 M.
R-0918 N.
R-0927 0.
R-0442 P.
R-0469 13.
Field Problem Reports A.
R-0927 FPR1-FPR26 B.
R-0861 FPR1aFPR25 ATTACHMENT 6.1 (Continued) 12 9
LIST OF DOCUMENTS REVIEWED 14.
Task 04145 B.
Task 05355 C.
Task 05378 D.
Task 05389 E.
Task 05602 F.
Task 05608 G.
Task 05745 H.
Task 05746 I.
Task 05749 J.
Task 05750 15.
I&C Calibration Records for ICS
- 16. Work Request History for ICS
- 17. Occurrence Description Reports A.
4/7/86 (Marty Ehlinger, MFW RPM) 18.
Standard ANSI Nk45.2.11 1974 19.
Engineering Reports A.
ERPT-10010 (SAIC Report)
B.
ERPT-E0208 (Fuses for 118 VAC) 21.
Draft Rancho Seco System Configuration and Test Program Review (ICS l
cone by B&W) l l
22.
CRTS letter GCA 87-090 dated 7/21/87 l
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BAW-1919 Draft, BWOG I&C Committee, ICS/NNI Evaluation, Appendix R 24.
Engineering Calculations l
A.
Z-ICS-E0640 l
B.
Z-ICS-E0598 i
C.
Z-EFI-IO146 0.
Z-EFI-IO159 l
E.
Z-EFI-IO158 l
F.
Z-EFI-I0l63 ATTACHMENT 6.1 (Continued) 13 9
LIST OF DOCUMENTS REVIEHED 25.
Training Materials A.
Nuclear Training Department Course Catalog (TTM07, 7/16/87) 8.
Lesson Plan, ICS (00 21 I 4900 rl) l l
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t ATTACHMENT 6.1 (Continued) e 14
STATUS OF RIs.2 provides RI status as of this report date. An RI is considered closed if the Team Leader was convinced a potential concern was not valid or not significant enough to be an RI.
An RI would also be closed if requested information was provided. All other RIs are open.
Acknowledged RIs are open RIs that have been accepted as valid by the responsible organization and have been stated as concerns in Section 5.0.
RI NUMBER STATUS 028 Acknowledged 036 Acknowledged 039 Acknowledged l
043 Closed 073 Closed 074 Acknowledged 1
080 Acknowledged 081 Acknowledged 093 Closed 094 Closed 095 Acknowledged 096 Acknowledged I
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ATTACHMENT 6.2 15 l
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DETAILED OBSERVATIONS REOUESTS FOR INFORMATION During an evaluation, all potential concerns are documented on Request for Information sheets (RIs) that are sent to the responsible organization to receive their input concerning the potential concern.
RIs are also used to request information that the EASRTP team is having difficulty obtaining.
These RIs are considered drafts throughout the entire evaluation until they become part of the report.
Responsible organizations can accept the i
I potential concern as valid or they may disagree with the potential concern.
If they disagree, they can submit information that convinces the EASRTP team members that the potential concern is not valid, or they may redirect the EASRTP members to better focus the concern.
RIs developed during the system evaluation comprise this section of the report.
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l ATTACHMENT 6.3 16 i
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l REQUEST FOR INFORMATION (RI) i RI NO: _Q21 SYSTEM CODE:
_ICS_
ISSUE DATE:
7-23-87
SUBJECT:
SETPOINTS FOR THE STEAM BYPASS SYSTEM DEPARTMENT:
NUCLEAR ENGINEERING COORDINATOR:
RON LAWRENCE TEAM LEADER:
RICH H0YER POTENTIAL CONCERN /0UESTION:
The intended steam bypass system operation according to the Main Steam System (HSS) design bases document is to open Turbine Bypass Valves (TBVs), Atmospheric Dump Valves (ADVs) and Main Steam Relief Valve (MSRV) sequentially in this order which may not be achievable due to tne overlap of set points (S.P.) for these valves when the set point tolerances are taken into consideration.
The overlapping of the set points could cause ADVs to open prior to opening TBVs which could release unnecessary radioactivity to the atmosphere in the event of tube rupture.
The plant personnel were unable to provide the documents supporting the selection of the setpoints for the TBVs and ADVs for review.
Several discrepancies were noted among the documents for the setpoint values and the setpoints are not controlled through any established method or procedure within the organization.
OVERLAP OF THE SETPOINTS FOR TBVs. ADVs AND MSRVs:
'TBVs S.P. (psig)
ADV's S.P. (psig)
First MSRV S.P. (psig) l Nominal
- Min
- Nominal
- Max
- Min Nominal
- Max 1000
- 990
- 1020 *1050
- 1035
- 1050
- 1050
- 'ICS SDB P. 13 Calculation #
Process standards
- Table 3 Z-EFI-IO146 p. 6 AP-150 p. 16 DISCREPANCIES IN ADVs SEPTOINT LOOP ERRORS:
After reviewing the calculations Z-EFI-IO146 Rev. O and Z-EFI-IO157 Rev. O, Process Standards AP-150 Rev. 14 and System Design Bases (SDB) for ICS Rev. I draft, the following concern is noted:
Calc Z-EFI-IO146 Pages 6 & 43 1020.117 psig 30.05 psig Calc Z-EFI-IO157 Page 2 1020 psig 25 psig 17 i
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1 POTENTIAL CONCERN /OUESTION:
After reviewing ICS SSR Rev. 1, System design basis for ICS Rev. 1 draft and MSS Rev.1 draft, System Description N21.01-112 Vol. 2 and Plant Operating Procedures B.2 Rev. 38, Engineering Change Notice (ECN) A-5415 Rev.1, the following discrepancies were noted:
D_SCREPANCIES IN SETPOINT FOR THE TBVs CONTROL ON REACTOR TRIP:
I ICS SSR p. 2-7 para 2.2.2.d 1015 psig i
ICS SDB p. 13 Table 3 1000 psig MSS SDB p. 5 para 2.2 125 psi above normal S.P. of 885 psig-1010 psig B & H ICS final documentation 125 psi above normal s.p.
Sheet IC 5 of 8 System description p. 3.4 115 psi above normal S.P. of 885 psig-1000 psig ICS Schematic Diagram N21.01-72 Rev. 6 115 psi above normal S.P.
ICS Calibration record pp. 129 & 130 115 psi above normal S.P.
DISCREPANCIES IN SETPOINT FOR THE TBVs CONTROL ON TURBINE TRIP:
MSS SDB p. 5 para 2.2 pressure control point biased by 1m01 amount ICS SDB p. 13 Table 3 setpoint changes from 935 psig to 885 psig DISCREPANCIES IN SETPOINT FOR THE TBVs CONTROL DURING NORMAL OPERATIOM:
ICS SOB p. 13 Table 3 935 psig MSS SDB p. 5 para 2.2 885 psig Plant Operating Procedure B.2 Rev. 38 p. 29 935 psig (885+50) l i
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l POTENTIAL CONCERN /00ESTION:
ADV CONTR_OL:
MSS SDB pp. 30 & 31 para 6.2.1 ICS Controls ADVs ICS SDB p. 13 Table 3 ICS Controls ADVs ECN A-5415 Rev. 1 Emergency Feedwater Initiation and Controls (EFIC) Controls ADVs TBVs OVERRIDE:
ICS SDB p. 13 Table 3 1035 psig Calibration Records 1050 psig After reviewing calculations Z-EFI-10146 Rev. O and Z-EFI-IO157 Rev. O, the following discrepancies were noted:
ADV Setpoint is 1020.117" Z-EFI-IO146 o. 6 item 3.a Max. error in ADV control loop pp. 35 & 43 30.45 psig vs 230.05 psig EADVL=1200 x 2.51-30.05 psig
- p. 43 f.1. j Error direction (+ or -) not
- p. 36 & 39 called out consistently.
Assumption for the error is'2%
I-EFI-IO157 c. 22 of Upper 9ange Limit (URL) but calculation'uses 2% of calibrated span.
Assumption for the errors in Buffer and Control Module is not considered.
Reference for the nominal value of setpoint is not called out.
Error direction (+ or -) not called out consistently.
ADV CONTROL LOOP ERROR INCONSISTENT:
Total loop error 230.05 psig Z-EFI-IO146 pp. 35 & 43 Z-EFI-IO157 pp. 2 & 22 Total loop error 25 psig The calculations are not cross-referenced (in Z-EFI-10157) 19
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REQUEST FOR INFORMATION (RI)
RI NO: _f16 SYSTEM CODE:
_1CL ISSUE DATE:
7-27-87
SUBJECT:
CONTROL SETPOINTS DOCUMENTATION DEPARTMENT:
NUCLEAR ENGINEERING C0ORDINATOR:
RON LAWRENCE TEAM LEADER:
RICH H0YER POTENTIAL CONCERN /0UESTION:
j Integrated Control System devices may be calibrated to incorrect setpoints.
1.
ICS setpoints are not in process standards and the plant could not produce another controlled setpoint document.
I&C shop calibration records appear to have complete electronic hardware settings and are archived but not controlled.
2.
Programmatic control of implementing new or modified setpoints is 4
unclear.
Review of procedures for generation, implementation and turnover of modification packages (NEP-4109, RSAP-803 and AP44) revealed no directions for addressing setpoints.
There is no guidance on analyzing, documenting and transmitting design setpoints and tolerances.
There is no flow chart for implementing design setpoints and disseminating setpoints to setpoint documents and training.
3.
Plant was unable to provide cross reference to, or assurance of existence of loop error analysis for setpoints and/or indication, providing uncertainty in meeting USAR, Technical Specifications, Requiatory and functional requirements for ICS and other plant systems.
4 No controlled. documentation cf module functions exists.
Maintenance and modifications recuire detailed knowledge of signal functions including engineering units.
5.
Process Standards is a partial setpoint document of selected instruments.
It does not reference support documents and does not provide signal to engineering unit conversions.
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REQ' JEST FOR INFORMATION (RI)
RI NO: _.032 SYSTEM CODE:
ICS.
ISSUE DATE: 7-27-87 SNJECT:
LABELING OF NNI SHUNT TRIP SWIiCHES-ECN CLOSURE DEPARTMENT:
NUCLEAR ENGINEERING COORDINATOR:
RON LAWRENCE TEAM LEADER:
RICH H0YER l
POTENTIAL CONCERN /00ESTION:
Engineering Change Notices (ECNs) are being closed without all modifications being performed, which could lead operators to take inappropriate or ineffective actions.
According to the ICS System Status Report Problem #46, $1 and S2 Shunt Trip Switches were not labeled to provide positive indication that the switches vere in a tripped condition.
According to the ICS System Status Report, "ECN R-0472 relabeled j
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breakers S1 and 52 on the ICS and NNI so that positive indication of j
these breakers being open can be determined without question."
l ECN R-0472 Rev. O specified relabeling 51 and 52 on the ICS alone.
(ECN is closed)
ECN R-0580 Rev. O specified relabeling Si and S2 on the NNI.
The Design Basis Report states:
"In addition labels will be added to S1 and 52 in the X and Y power distributions to aid the operator in l
determining switch position." (ECN is closed)
The plant could not produce another ECN that labels NNIs Si and S2.
A walkdown of the NNI verified that labels have not been added to NNIs S1 and S2.
Work Request 114092 included replacing NNI S1 and $2 labols but was l
closed without the work being performed.
There is a potential that the operator, attempting to find the cause of an NNI loss of power may not be able to identify that the Si and 52 switches are tripped. This happened on identical switches in the ICS on December 26, 1985.
ECN R-OS80 was released to operations witnout all work specified in the ECN completed.
This does not meet the intent of AP44 Plant Modification procedure whii;h states prior to ECN release l
installation, testing, and design of the modification must be l
complete.
Contributing to this concern is that a work request had been written to cover the work in question and was signed as j
completed, but the total werk was not performed.
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REQUEST FOR INFORMATION (RI)
RI NO: _Q41 SYSTEM CODE:
ICS ISSUE DATE:
7-24-87
SUBJECT:
ICS SHUNT TRIP SWITCHES $1 AND S2 PERFORMANCE LIFE EXPIRES PRIOR TO REPLACEMENT DEPARTMENT:
MAINTENANCE COORDINATOR:
JIH DARKE TEAM LEADER:
RICH HOYER 1
POTENTIAL CONCERN /00ESTION:
l ICS shunt trip switches (S1 and 52) may not be functional, prior to scheduled replacement because the Preventative Maintenance (PM) Task does j
not account for shelf life.
1 The manufacturer of the switches stated that they would not guarantee the switches for longer than five years after the switch leaves the factory-(per-Engineering Report (ERPT I-0010)
The PM Task (0560S) for replacement of the switches has a performance interval of 1825 days (five years) and does not account for shelf life.
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Therefore, since shelf life is not considered, a period will exist when the switch is installed in the field and is no longer guaranteed by the manufacturer.
Failure of these switches could mean a spurious loss of ICS power or a failure to trip ICS power.
RI closed.
EAR issued for resolution.
EASRTP will follow-up as a potential generic issue regarding shelf life.
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REQUEST FOR INFORMATION (RI)
RI NO: _023 SYSTEM CODE:
IC^
ISSJE DATE:
7-29-87
SUBJECT:
USAR DESCRIPTION OF ICS DEPARTMENT:
LICENSING COORDINATOR:
J. DELEZINSKI TEAM LEADER:
RICH HOYER POTENTIAL CONCERN /OUESTION:
USAR description of functioning of ICS control stations on loss of power is incorrect.
USAR, including amendment 5 revisions, section 7.2.3.3.1, is incorrect in stating " Loss of electrical power to automatic control stations reverts the control system to Manual."
The Bailey 720 design such as Oconee and TMI operate in this manner, but the Bailey 820 design used at Rancho Seco has both automatic and manual control being powered from the same DC source.
RI closed.
EAR issued for resolution.
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1 REQUEST FOR INFORMATION (RI)
RI NO: 074 SYSTEM CODE:
.ICS.
ISSUE DATE:
7-29-87 1
SUBJECT:
REVISIONS TO PM TASKS DEPARTMENT:
MAINTENANCE COORDINATOR:
J. DARKE TEAM LEADER:
RICH H0YER POTENTIAL CONCERN /0UESTION:
Superseded Preventive Maintenance (PM) tasks may be worked even though the respective new or modified PM tasks have been entered into the system.
No procedures (ref. AP650) exist to recall active work requests written by PM tasks when a new or modified PM task for the respective device is entered into the PM system.
PM tasks are not identified by revision number.
As a result work requests incorporating old directions may get worked after the revised modifications work request, causing l
incorrect maintenance to be performed.
l 24
l REQUEST FOR INFORMATION (RI) l RI NO: _DHD SYSTEM CODE:
... ICS _
ISSUE DATE:
7-29-87
SUBJECT:
TESTING OF WIREWRAP REWORK IN THE ICS DEPARTMENT:
SYSTEM ENGINEERING COORDINATOR:
JOHN ITTNER TEAM LEADER:
RICH MOYER POTENTIAL CONCERN /00ESTION:
The ICS functional test appears inadequate to detec't errors resulting from termination rework; errors which could lead to a plant trip or to making a plant trip more complex.
Due to an identified cause of the December 26, 1985 trip, a bad lug in the ICS, a significant number (thousands) of terminations and wirewrap connections in the-ICS were inspected and reworked.
(ICS System Status Report Problem 10)
Quality Control inspection was requested and performed on the quality of the terminations only. Recent findings (Nonconformance Reports S-6603, S-6867) indicate some terminations were not returned to their proper location.
A discussion with an I&C Maintenance Engineer indicated that maintenance is relying on the ICS Functional Test (Special Test Procedure STP.778) to find any discrepancies.
Although the ICS Function Test (STP.778) tests the functions of the ICS, the test does not verify that every wire in the ICS is landed at the procer terminal.
A review of a section of the ICS Function Test (Section 6.4, Feedwater) showed that only approximately 80% of the wiring in the subsystem will be tested.
The B&W ICS Engineer who was involved in the Davis-Besse restart stated that a plant trip after restart at Davis-Besse was attributed directly to a wiring discrepancy which was missed during function testing.
25 j
REQUEST FOR INFORMATION (RI)
RI NO:,JfL1 SYSTEM CODE:
ICS ISSUE DATE:
7-30-87
SUBJECT:
ICS/NNI ABT OPERATION DEPARTHENT:
OPERATIONS COORDINATOR:
R. MACIAS TEAM LEADER:
RICH H0YER POTENTIAL CONCERN /00ESTION:
The Automatic Bus Transfer (ABT) is designed such that a situation could exist where ICS AC loads are lost but ICS DC loads remain energized causing uncertainty in ICS control.
Review of drawing E203 Sht 99 Rev. 2 showed ICS ABT performs l
automatic bus transfer from primary AC power alignment to alternate AC power alignment; but will nat perform automatic bus transfer from alternate to primary.
The operator must manually push the reset button located on the ABT enclosure, after primary AC power is restored, to realign the ABT to primary AC power.
Plant could not provide a design basis requiring use of a unidirectional versus a bidirectional power seeking ABT.
ABT alignment to alternate AC power is annunciated. Annunciator Response Procedure (ARP) H2PSB addresses the need to reset the ABT to primary AC power alignment.
Plant conditions may not allow immediate/near term realignment to primary /.C power.
Plausibly the ABT :ould be aligned to alternate AC power, the ABT primary AC source would be restored and prior to the time the operators reset the ABT to primary AC power alignment the alternate AC power could be lost.
This would de-energize all ICS AC loads while all ICS DC loads would still be energized.
Operators interviewed knew that the ABT was unidirectional power seeking. Operators were not aware that there was a possibility that ICS AC loads could be lost while ICS DC loads remained energized.
This condition would cause loss of MFH pumps while ICS controllers remained energized and ICS control actions would become unpredictable.
The plant could r.ot provide an analysis of ICS with AC loads lost and DC loads energized.
26 d
l REQUEST FOR INFORMATION (RI)
RI NO: _ Dol SYSTEM CODE:
...I CS..
ISSUE DATE:
7-30-87
SUBJECT:
LABklING OF AUXILIARY STEAM STATION FOR LOSS OF ICS POWER DEPARTMENT:
SYSTEM ENGINEERING COORDINATOR:
JOHN ITTNER TEAM LEADER:
RICH MOYER POTENTIAL CONCERNiOUESTION:
On a loss of ICS power, operators may not be aware that Control Room control of Auxiliary Steam is not functional.
ICS System Status Report (SSR) Problem 22 identified that all Control Room instrumentation and controls which are powered from ICS should be labeled. A portion of the Auxiliary Steam Reducing Station in the Control Room is powered from ICS.
There is no label in the Control Room indicating that the station is powered from ICS.
During the ICS Equipment Investigation (Action List Item. Number 3A),
upon loss of ICS power, it was noted that the Auxiliary Steam Reducing Station lost power unexpectedly.
In the resolution of ICS SSR Problem 22. ICS Bailey dand/ Auto (H/A)
Stations did not require labeling.
The ICS Bailey Hand / Auto stations are grouped together on panel H1RI and, being ICS stations, do not require labeling indicating that they are ICS powered.
The Auxiliary Steam Station, at one time a Bailey station, is not located among the rest of the H/A stations and is no longer clearly identified as being powered by ICS (ECN R-0878).
A walkdown of the Control Room confirmed that there is no purple label signifying that this controller is affected by a loss of ICS j
power.
RI closed.
EAR issued for resolution.
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t REQUEST FOR INFORMATION (RI)
RI NO: _014 SYSTEM CODE:
ICS ISSUE DATE:
7-30-87
.I
SUBJECT:
EFFECTIVENESS OF_ QlGyEERING REGARDING ECN WORK PACKAGEL_
DEPARTHENT:
NUCLEAR ENGINEERING COORDINATOR:
RON LAWRENCE TEAM LEADER:
RICH MOYS POTENTIAL CONCERN /00ESTION:
Engineering design walkdowns and verifications for design modifications as found in NEP 4109 are not being performed adequately.
Review of Engineering Change Notice (ECN) work packages (R-0861 and R-0927) in progress showed a large number (25 and 26 respectively) of Field Problem Reports (FPRs) being generated.
The majority of FPRs appeared to be of technical nature requiring design correction.
There is a concern that design errors th1t affect functionality of the system may avoid detection by installation personnel and modification testing.
Review of FPRs for ECN R-0861 revealed several instances where the original design called for instrument cables to be routed in trays that I
the field determined was unacceptable.
Field engineering then recommended the cables be routed in trays which were power trays.
Engineering corrected thb error in the FPR before responding, but this scenario reflects the necessity for engineering walkdowns to be performed initially per the procedures.
Engineering's initial response to this concern stated that drawing details were difficult to read or lacking in detail, which also emphasizes the need to perform walkdowns and verifications before completing the design.
RI closed.
Further evaluation, by EASRTP determined that, due to the nature of the FPR descriptions, it is difficult to determine whether inacecuate design resulting from lack of walkdowns <as the cause of the large number of FPRs. The modification concerns were eventually resolved thru the FPR process.
EASRTP will follow-up this issue on subsequent system reviews to determine if additional concerns are appropriate.
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REQUEST FOR INFORMATION (RI)
RI NO: _Q15 SYSTEM CODE:
_lf3_
ISSUE'DATE:
7-?0-87
SUBJECT:
CALIBRATION RECORDS CONTROL DEPARTHENT:
MAINTENANCE COORDINATOR:
J. DARKE TEAM LEADER:
RICH MOYER POTENTIAL CONCERN /0UESTION:
No procedures exist for I&C maintenance to ensure calibration data sheets are microfilmed in accordance with Records Management requirements, j
1 In Response to NRC open item 86-22 calibration data sheets were brought into compliance of permanent plant records by microfilming I
in early 1987.
i Interview with I&C shop supervisor indicated that new data sheets are collected and periodically microfilmed by records management to l
maintain permanent plant record status, by arrangement with Records j
management.
Review of Maintenance Procedures 1011 Rev.3 and I]l4 Rev. 2 did not I
show programmatic control of this process of micro filming all new calibration data. No occurrences of calibration data sheets not i
being microfilmed or calibration data sheets 'being lost were found.
i However, there is a potential for these occurrences with no i
procedural control of this activity at the shop level under the l
RSAP-0601 guidelines.
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-__J
REQUEST FOR INFORMATION (RI)
\\
l RI NO: _Qld SYSTEM CODE:
ICS.
ISSUE DATE:
7-30-87
SUBJECT:
ICS BREAKERS FOR 118VAC POWER SUPPLIES l
l DEPARTMENT:
NUCLEAR ENGINEERING COORDINATOR:
RON LAWRENCE TEAM LEADER:
RICH H0YER POTENTIAL CONCERN /OUESTION:
4 The ICS breakers IJ04 and IC07 may not be sized properly.
This could j
cause unnecessary / frequent tripping of the breakers or could cause damage to the equipment if the breakers are oversized, thereby reducing plant a!ailability and reliability.
The plant is unable to provide a document showing all the loads to support the sizing and selection of breakers.
The loads may be l
shown on several drawings but it is very difficult to verify the l
loads due to several modifications being made to ICS.
The engineering report ERPT-E0208 Rev. O still shows various loads which have been removed from ICS.
It appears from this report that the breaker loads do not get re-analyzed or updated, Drawings E-lC11 Sh. 110-2 and Sh. 115A indicate the " total load" of 25 Amos for the breakers but the individual loads are not called out on this drawing.
Discussions with engineers revealed that the
" total load" of 23.15 Amps is identified in the instruction manual for ICS. However, the instruction manual never gets updated for the revised loads.
In addition, it was stated that it is good engineering cractice to select a breaker of 125% cacacity of full I
loaa.
The 30 Amp creaker 1004 has ceen replaceo with a 40 Amp breaker under Engineering Change Notice (ECN) R-0469 Rev. O.
The calculation #Z-ICS-E0640 Rev. I was done for the coordination of breakers and fuses of Il8VAC circuits.
It was concluoed ftem this calculation that fuses in 118 VAC circuits coordinate properly with 40 Amp and 30 Amp breakers for all fault currents available from the inverter or from the regulating transformer.
This conclusion did not support the replacement of 30 Amps breaker under ECN #R-0469 Rev. O.
30
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