ML17262A133

Responds to Violations & Several Unresolved Items Noted in SSFI Rept 50-244/89-81.Update of Appropriate Unresolved Items Encl.Specific Actions Re All NRC Unresolved Items Being Tracked to Completion

ML17262A133
Person / Time
Site:	Ginna
Issue date:	09/11/1990
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9009200182
Download: ML17262A133 (2)

Text

k'L ROCHESTER GAS AND ELECTRIC CORPORATION ROBERT C htECREDY Vi<e hetident Cinne t4uclee<Ptoduction

/'.tone>t*te~89 EAST AVENUE, ROCHESTER N.Y.14649-0001 TELEPHONE AREA CODE 71B 546 2700 September 11, 1990 Mr.Thomas T.Martin Regional Administrator U.S.Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406'ubject:

120-day Response to Inspection Report 50-244/89-81 Safety System Functional Inspection on the RHR System R.E.Ginna Nuclear Power Plant Docket No.50-244

Reference:

(a)NRC Inspection Report 50-244/89-81, dated May 9, 1990(b)RG&E letter from R.C.Mecredy-to NRC, T.T.Martin, dated June 8, 1990

Dear Mr.Martin:

Reference (a)requested a response to two Notices of Violation and several unresolved items within 30 days and a written evaluation of the deficiencies identified in Section 2.1 of the Inspection Report within 120 days.In our 30-day response to two Notices of Violation, Ref.(b), we summarized our proposed resolution or schedule for resolution for the unresolved items 89-81-01 through 10.The NRC unresolved item description and our proposed resolution of each of these was discussed in enclosures C and E of Ref.(b).An update of the appropriate unresolved items is provided as Attachment A to this response.Specific actions regarding all NRC unresolved items are being tracked to completion by RG&E.~U~cIQ et\A oo 1'Q~C3 oP o+The identified weaknesses in Section 2.1 of the Inspection Report collectively raised an NRC concern as to the effectiveness of RG&E's current practices to establish engineering assurance.

This was identified as unresolved item 89-81-11 and is the focus of this response.RG&E recognizes that unresolved item 89-81-11, engineering assurance, is characterized by broad programmatic issues.RG&E has completed an evaluation of the deficiencies and concerns raised in the Inspection Report by performing an internal assessment of the underlying issues identified in Section 2.1 and the examples discussed in Section 2.2.Our assessment has been documented in an g Q~o//(]

Cl internal report entitled"Systematic Assessments of Engineering Assurance Issues'and RHR SSFI Concerns" dated 9/11/90.RG&E believes that the underlying concerns necessitate both interim.and long term activities to resolve.Our approach in performing the-internal assessment and a summary of the high priority actions are presented in Attachment B.This attachment is a summary of the considerable efforts of an RG&E SSFI Assessment Team composed of a group of experienced RG&E staff and management personnel.

The primary task of'the RG&E SSFI Assessment Team was to prepare a report to RG&E's management which recommended the most effective interim actions needed to begin the process of strengthening the engineering processes and.controls.The RG&E SSFI Assessment Team was composed of nine senior engineers and staff.The team met to re-examine the inspection report and categorize the deficiencies by topical areas.The team also evaluated a report prepared by an RG&E consultant who independently identified the programmatic concerns.The assessment consisted of individual evaluations by team members as well as working sessions as a group.The RG&E Assessment Team grouped the NRC identified deficiencies into the following topical areas:~Improved~Improved~Improved~Improved~Improved~Improved Method of Identifying and.Assessing Safety Concerns Design Control and Reviews Design Interface Control Documentation Associated with Design Bases Documentation Associated with Modifications Engineering/Plant Communications The team then established interim actions and long term corrective actions for each topical area.The team prioritized the interim actions and established a proposed schedule.The interim actions were recommended based upon achieving a fundamental improvement on the engineering process.Interim actions are those actions which can be implemented immediately or within a period.of up to a year.Long-term corrective actions were also recommended,.

Many of the longer term recommendations are already embodied in two major programs: Configuration Management (CM)and the Engineering Procedures Upgrade Program.A report on the Configuration Management program descriptions and schedule was presented to members of Region I and NRR on March 6 and March 27, 1990, respectively.(Individual projects within the CM program may be examined within the enclosure to Inspection Report 90-03, dated April 18, 1990).The Engineering Procedures Upgrade program has been initiated and will include an external assessment of our current procedures by an independent consultant.

It is expected that this assessment will be complete by year-end.The results of RG&E's internal SSFI Assessment will become an input to the Engineering Procedures Upgrade and the Configuration Management Programs.Attachment B is a summary report of the Assessment Team activities and recommendations.

RG&E believes that many of the deficiencies noted under the engineering assurance unresolved item 89-81-11 had been recognized prior to the RHR SSFI and have been enveloped under the various Configuration Management Projects, such as the Setpoint Verification Program and Design Basis Documentation Projects.We have recognized that interim actions are necessary to sufficiently strengthen the engineering processes, procedures and documentation of information to bridge the gap to these longer term programs.We have begun the process to implement these actions and plan to examine their effectiveness, during 1991.We believe that the interim actions planned are the most effective measures for RG&E to provide adequate resolution of the identified deficiencies while we are implementing the long term Configuration Management Programs.The NRC Inspection Report identified the Engineering A'ssurance deficiencies in sections 2.2.1.1, 2.2.1.2, 2.2.3.2, and 2.2.3.3.The RG&E assessment concentrated on the root causes of these deficiencies and not just the examples themselves.

Nevertheless, the specific analyses, reports, and drawings that require revisions or corrections as described in these sections are being revised or updated as necessary, including for example, the calculations discussed in section 2.2.1.2 and the drawings identified in section 2.2.3.3(B).

, Our specific evaluations relative to the examples found in these four sections are contained in the Assessment Team report.We believe that the systematic assessment discussed in Attachment B is a thorough and appropriate response to unresolved item 89-81-11.Please notify us if you believe we have not interpreted the NRC report correctly.

Very truly yours, GAHK118 Atta'chment Robert C.Mecredy xc: U.S.Nuclear Regulatory Commission (original)

Document Control Desk Washington, D.C.20555 Allen R.Johnson (Mail Stop 14Dl)Project Directorate I-3 Washington, D.C.20555 Ginna Senior Resident Inspector

Attachment A UPDATE OF UNRESOLVED ITEMS FROM RG&E's ENCLOSURE E OF, JUNE 8, 1990 URI 89-81-02 (Section 2.2.1.4)Resolution of Safety Concerns June 8, 1990: An interim process for handling safety concerns is under development and will be discussed in our 120 day response.Update: RG&E has developed a formal process in Procedure QE-1603, Documenting and Reporting of Conditions Adverse to Quality, for handling potential safety concerns identified by Nuclear Engineering Services personnel.

These among the conditions-which would be reported, are: nonconformances, deviations, deficiencies, failures, malfunctions, defective material and equipment, vendor technical reports, design basis documentation, and the material condition of the plant structures, systems or components.

The procedure requires that potential safety concerns be documented and tracked by Nuclear Engineering Services personnel.

The process provides for: ensuring that a preliminary safety evaluation is performed by Nuclear Safety and Licensing; transmitting information concerning conditions that involve a safety concern to the Technical Manager, Ginna Station;disposition of safety concerns through the appropriate process such as a nonconformance report (NCR), and.identified deficiency report (IDR);reviewing the condition and preliminary safety evaluation by Ginna Station Technical Section against the criteria for reporting events (A-25.1);dispositioning the condition through the appropriate process such as corrective action reports (CAR), procedure change notice (PCN)and work request/trouble request (WR/TR);providing the initiator with the feedback on the disposition.

Potential conditions adverse to quality that are discovered by Ginna Station personnel are dispositioned by one of the current processes under the Maintenance Work Request and Trouble Report (A-1603), Corrective Action Report (A-1601), and Reporting of Unusual Plant Conditions (A-25).Interim and long term corrective actions recommended as part of the RG&E SSFI Assessment are described in Attachment B under the general topical area Improved Process for Reporting and Assessing Safety Concerns.A-1

URI, 89-81-05 (Section 2.2.2.2)Electrical Load Growth Program June 8, 1990: We are taking actions to integrate this process into the appropriate Engineering (QE)procedures., We anticipate completion of these actions by the date of our 120 day response.Update: RG&E issued a change to engineering procedure QE-301 Rev.11 with issuance of PDR 0609 dated 7/9/90.This change requires that our design process ensure that the effects of all load changes on the station batteries or diesel-generators shall be addressed, including the requirement that these be evaluated and shown to be within the margin allowed by the current loading analysis.During the RG&E SSFI Review Team Assessment it was noted that other examples were identified which could be placed within the issue of establishing a mechanism to evaluate the cumulative effects of modifications.

Interim and long term corrective actions are described within Attachment B under the general topical area Improved Documentation Associated with Modifications.

URI 89-81-07 (Section 2.2.4.4.a., b., and d.)Control Room P&ID's June 8, 1990: An interim process for enhancing the update process for control room information.is currently under review and will be discussed in the 120 day response.Update: This concern was manifested in two areas, drawing change requests (DCRs)and training material.DCR Process: The timeliness of processing drawing changes has been enhanced through implementation of Revision 3 of A-606, Drawing Change Requests procedure.

This upgrade directs the timely upgrading of drawings used in the Control Room and Technical Support Center.Posting of drawing changes is required within 2 working days from their receipt by Central Records.(General practice has been same day posting).The approval and tracking of the DCR process is currently assigned to the Technical Section at Ginna Station.Plans are being made to transfer data entry, control of the database and distribution to the Document Control department.

Another enhancement includes a monthly DCR status report that is distributed to management.

The DCR process has been given increased emphasis through procedural contr'ols.

With its present method, RG&E believes that timely posting and effective tracking and trending of the DCR system will be achieved..

A-2 4

Trainin Material: RG&E is committed to ensuring that all training material available to Licensed operators is as correct and current as possible.During the inspection we agreed that the Lesson Text RG&E-25 contained an invalid value for the time available to isolate a 50 gpm seal leak to prevent RHR pump motor flooding.Other information relative to plant modifications on valve:numbers (EWR 4761)and piping modification (EWR 4675)also had not yet been incorporated into the Lesson Text because the Training Change Request had not yet been implemented.

After the discrepancy on the isolation time was identified to RG&E, the Lesson Text was immediately corrected.

For clarity, the Lesson Texts have been renamed TRAINING SYSTEMS DESCRIPTIONS.

However, these are not defined as Controlled Configuration material.These documents are not meant to take the place of approved plant procedures, engineering design documents, plant drawings or vendor technical manuals.They are used as reference material, arranged by system, that contain a conceptual overview of.that system designed to be used.as a job and.training aid.We understand the NRC's concern over the fact that this material is available for use in the control room, may be frequently used, and is not designated as being potentially out of date.We believe the primary concern is the timeliness of updating this material to reflect the plant configuration, not over the control over these documents.

Therefore, strict control has been placed over these documents.

There is a master copy controlled b'y the Training Department and all changes are controlled by procedure TR 5.9 (Training Change Request/Notice).

Records are kept of controlled copy holders of controlled copies.Placement of this material in the control room is controlled by the Training Department.

This is the norm, not the exception, in the utility industry.We understand and recognize the underlying concern identified over the timeliness of providing current and controlled material to those who may use it.Procedures TR 5.5.1 (Tracking Plant Changes)is currently the process that has been developed and implemented to identify and track plant changes and include those changes in training material where appropriate.

We have taken additional steps in order to provide training material that is as current as possible and to better define the purpose of this material.1.Place a copy of the"Information Letter" in all Training System Descriptions that are affected by a plant modification.

This action has been implemented and will be controlled by Configuration A-3 2.Management Training Guidelines, CMTG-3.0, Preparation and Use of Information Letters.The information letter provides current information on a modification.

The letter will remain part of the system description until the system description has been revised.to incorporate the new modification.

I The first page of each Training System Description will be stamped TRAINING INFORMATION ONLY.This action has been initiated..

3.Include the date of revision for each page of the Training System Description.

This action has been implemented.

There were no additional interim remedial actions recommended as part of the RG&E SSFI Review Team Assessment other than those above.Long term corrective actions are described in Attachment B under general topical area Plant Design Information/Design Bases.URI 89-81-06 (Section 2.2.2.3)Molded Case Circuit Breaker June 8, 1990: The industry is currently examining the need for, and benefits of, molded case circuit breakers testing.RG&E will continue to work closely with the industry and EPRI to determine the appropriate test methods and requirements.

Update: During August RG&E personnel from Engineering and Plant Maintenance visited the Diablo Canyon Power Plant to inspect the equipment and procedures for periodic testing of molded case circuit breakers used by PG&E.Results of the first cycle of testing by the Diablo Canyon staff were also discussed.

A similar program for Ginna Station appears to be technically feasible, subject to additional evaluation and procurement of test equipment, development of procedures, and performance of a trial test program.It is anticipated that a trial program can be initiated within the next year.It is estimated that the first cycle of a test program would require four or more years to complete following the successful completion of a trial test.A-4 Attachment B SYSTEMATIC ASSESSMENT OF ENGINEERING ASSURANCE ISSUES AND RHR SSFI CONCERNS This attachment is a summary of the SSFI Assessment Team approach and recommended actions extracted.

from the RG&E report with the same name.

Systematic Assessment of Engineering Assurance Issues and RHR SSFI Concerns TABLE OF CONTENTS

1.0 INTRODUCTION

1.1~pur ose 1.3 Sco e of Review and Recommendations 1.4 Review Team 2.0 SYSTEMATIC ASSESSMENT

'I 3.0 ISSUES AND CONCERNS ADDRESSED 4.0

SUMMARY

OF RECOMMENDATIONS APPENDICES:

Appendix A, Programmatic Concerns Listing Page i 0

Systematic Assessment of Engineering Assurance Issues and RHR SSFI Concerns

1.0 INTRODUCTION

1e2~Pur ose This document provides the results of a systematic assessment of issues and concerns raised by the NRC',s Safety System Functional Inspection (SSFI)conducted during November and December, 1989, which focused on the Ginna Station Residual Heat Removal (RHR)System.This summary report also presents interim remedial actions and long-term corrective actions.Other steps toward improvements, already in progress, are also listed..Back round A safety System Functional Inspection (SSFI)was performed by an NRC team from November 6 to December 8, 1989, at RG&E facilities (Ginna Station and the corporate offices), and is documented in a letter from the NRC dated May 9, 1990.The objective of the SSFI was to assess the capability of the Ginna Residual Heat Removal (RHR)system to perform its design basis safety functions.

The NRC inspection team evaluated the adequacy of operational procedures, test practices, ,and maintenance policies as they contribute to RHR system reliability.

The NRC team also addressed the quality of engineering support activities.

The NRC team did not identify any conditions that would prohibit the RHR system from performing its intended functions under normal and design basis accident conditions.

However, it was stated by the NRC that complete verification of system reliability was not possible since the design basis calculations for the RHR system were not readily available.

The NRC SSFI team did have one immediate concern and, as a result, RG&E was requested to promptly resolve a discrepancy regarding the potential flooding of the RHR pump room.Our actions taken to resolve this were documented in Enclosure E to our June 8, 1990 response (URI 89-81-10).

In addition it appeared to the NRC inspection team that two activities were not conducted in full compliance with NRC requirements, as described in the Notice of Violation (NOV)enclosed as Appendix A to the NRC SSFI Inspection Report.B-1 The RG&E response to the NOV included a schedule for resolving the unresolved items (exclusive of 89-81-11 discussed above)identified in the NRC SSFI report.The RHR SSFI Inspection Report also cited, a number of concerns which could be associated with broader programmatic issues.The NRC inspection team concluded that weaknesses exist in engineering support and plant modification activities.

These weaknesses were listed in Section 2.1, and were discussed in Section 2.2, of the NRC SSFI Inspection Report, and have been assigned unresolved item number 89-81-11.The SSFI Inspection Report required'G&E to"provide their evaluation of those weaknesses within 120 days".The identified weaknesses were placed under the broad category of"engineering assurance" by the NRC.RG&E committed'n the June 8, 1990 30-day response to conduct a review of its engineering process using a systematic approach.RG&E elected to perform its evaluation of the"engineering assurance" issues by utilizing a review team approach.The results of the review team approach was intended to provide the basis toward.resolution of NRC SSFI Inspection unresolved item 89-81-11.1.3 Sco e.of the Review and'Recommendations The scope of the SSFI review was established by RG&E Management prior to the initiation of the review team effort.RG&E Management provided general guidance for conduct of the review'team effort as well as specific guidance on the scope of potential recommendations.

To ensure that a thorough evaluation was conducted, the review team examined the material found in the following documents:

a~NRC SSFI Report no.50-244/89-81, dated, May 9, 1990 b.RG&E's 30-day response letter to the NRC dated June 8, 1990 c~Commitment and Action Tracking System (CATS)commitments established by the NRC inspection report and RG&E's June 8, 1990 letter.d.e.INPO Good Practices,"Guidance for the Conduct of Design Engineering" (INPO 88-016)December, 1988 Grove Engineering Review Report dated July 10, 1990 Applicable sections of the RG&E Configuration Management (CM)Plan.B-2 0

g, NRC Safety System Functional Inspection Guidelines, Appendix C (issued 11/12/86).

h.EPRI, Nuclear Safety Analysis Center Document, NSAC/121,"Guidelines for Performing Safety System Functional Inspections (November 1988).NQA-1"Quality Assurance Program Requirements for Nuclear Power Plants" (1979)j.ANSI N45.2.11,"Quality Assurance Requirements for the Design of Nuclear Power Plants" (1974)k.NRC'egulatory Guide 1.64,"Quality Assurance Requirements for the Design of Nuclear Power Plants" l.QE-series Engineering Procedures m.A-series Ginna Station Administrative Procedures With this reference material as background information the review team members proceeded to evaluate the NRC concerns and make recommendations for corrective action to RG&E Management through the Department Manager, Nuclear Engineering Services.The following is'summary of the guidance provided by RG&E Management:

a.Issues addressed were to focus on, but not, limited to, those contained in the NRC SSFI Report (IR 89-81).b.c~Concerns cited by the NRC were to be accepted as valid.No effort was to be expended on questioning either the cited concerns or the examples used in the NRC SSFI Report.Recommendations were to take the form of interim actions and long-term corrective actions.d.Recommendations for interim actions were to be limited to the following items: i.Changes to~existin Engineering and Ginna Station Procedures.

ii.Creation of a limited number of new Engineering QE or Administrative Procedures and/or Ginna Administrative Procedures.

iii.Issuance of policy statements (at discipline, department or corporate level.)B-3 e.iv.Development of discipline-specific implementing documents (such as design guides, standards, etc.).v.Reassignment of duties to personnel within specific disciplines.

Recommendations were'o be achievable utilizing staff levels that are currently authorized.

1.4 Review Team RG&E Management selected a review team to act on their behalf consisting of a group of nine experienced personnel representing the following areas: Mechanical Engineering, Electrical Engineering, Structural and Construction Engineering, Nuclear Safety and Licensing, Configuration Management, Document Control/Records Man'agement, Ginna Technical Section, and Nuclear Engineering Services Department staff.2.0 SYSTEMATIC ASSESSMENT The multi-discipline RG&E SSPI Review Team performed an assessment of the issues and concerns generated by the NRC RHR SSFI.The team began by establishing the following definition of"Engineering Assurance":

En ineerin Assurance:

The planned and systematic actions necessary to provide adequate confidence that engineering activities are performed in a consistent manner with adherence to plant licensing basis, applicable procedures, regulations and accepted industry standards.

The review team members formed."focus groups" which were assigned individual detail items from the programmatic concerns listing established in the initial breakdown of issues (appendix A).Individual assessments were made and the issues grouped and documented as part of RG&Es"Systematic Assessment of Engineering Assurance and RHR SSPI Concern Report." The review was based on the review team's own assessment as well as on detailed information obtained through discussions with other cognizant engineering and, plant personnel.

3.0 ISSUES AND CONCERNS ADDRESSED The review team regrouped all issues and programmatic concerns into six topical areas, as listed below: s-4 3.1 To ical Area 1: "Improved Process for Reporting and Assessing Safety Concerns" a: "Process for Handling Safety Concerns Outside the EWR Process" 3.2 To ical Area 2:."Improved Design Control and Reviews" a~b.c d.e.f."Engineering Management""Engineering Assurance""Timeliness of DCR Processing""Design Reviews""PAID Upgrade Program""Design Control" 3.3 To ical Area 3: "Improved Design Interface Control" a."Procedural Inconsistency" 3.4 To ical Area 4: "Improved Design Documentation/Design Bases" a~b.c d.e.f.g,"Interdisciplinary Review of Non-Mods""Calculations""Deletion of Information from PGIDs""Valve Identification Differences""Design Basis Information" Controlled Instrument List Training Material 3.5 To ical Area 5: Modifications" 1"Improved Documentation Associated with a."Invalid Information in UFSAR" b."Assessment of Cumulative Effects of Modifications" c."Issuance of Design Outputs" d."Control of EWRs" 3.6 To ical Area 6: "Improved Engineering/Plant Communications" a."Engineering/Plant Interface" b."Acceptance Criteria" c."Adequacy of SRV Test Acceptance Criteria" 4.0 Summar of Recommendations The following is a general summary of the most significant interim actions and long term corrective actions.4.1 RG&E's management has ensured close control and quality engineering services through their interaction and review of design, but written procedures do not make that control sufficiently-explicit.

B-5 As interim actions, a single procedure will be developed that outlines the entire scope of the design process.Discipline design guides for generation of design criteria, design analyses and design verification documents will be initiated.

Also, the integrated.

assessment process will be separately

" proceduralized.

Applicable procedures will be revised to establish the requirements for review,'a'pproval, and issuance of vendor documents.

In, the longer term, we plan to complete the upgrade of engineering procedures and processes to reflect industry standards of good practice, efficiency and rapid response.4.2 4.3 4.4 Engineering procedures contain a strong bias to modification design.This has proved to be well suited toward major stand alone design projects but is not as effectively used to aggressively support all of the engineering activities associated with a well-maintained.

operating plant.Close-out EWR documentation can be protracted, because the scope of a modification may be in'creased over time, causing design documents to remain open.As interim actions, we plan to limit the practice of increasing the scope of a design modification during the interval between turnover of the modification in the plant and records close-out.

We will begin to transmit EWR Design Packages to Document Control concurrent with the issuance of the construction package.In this way, the list of applicable design documents will also be established for the modification to be installed..

The UFSAR change process will be proceduralized and integrated with the above turnover process.Interim activities are needed to begin to capture, retain, provide access to, and organize design basis information as part of the normal ongoing engineering activities.

RG&E has incorporated a design basis documentation project under the Configuration Management Program.This program will be implemented over the next several years focusing on the safety systems.Efforts will be made to identify the types of materi'al and documents that contain design basis information and to begin to index and organize it in Document Control.In the longer term, the Design Basis Documentation project will develop Design Basis Documents for the major plant systems and equipment.

Because of the major modification bias used in the development of QE procedures and the major upgrade programs that have taken place over the years, the engineering department is not formatted on a system basis.B-6 li 1 i The Configuration Management Program is being developed on a systems basis.The Q-List has defined system boundaries that will be useful as we index design.documents in Document Control and develop Design Basis Documents.

4.5 Many of the underlying

'concerns and long term corrective actions are currently part of the existing or planned programs within Configuration'anagement and Engineering Procedures Upgrade Programs.The Design Basis Documentation, Setpoint Verification, Q-List, Document Control Enhancement, and.Engineering Controlled Configuration Drawing Upgrade Programs are individual parts of this program.The specific actions recommended by the SSFI Assessment team will be reviewed by the RG&E personnel responsible for the CM projects together with management to make any needed revisions to the scope of these projects.4.6 Engineering activities are performed by Nuclear, Engineering Services (NES)and station technical staff.The design process must ensure consistency between these activities.

As interim actions, we plan to increase the controls over setpoint changes and reporting of safety concerns.A process will be developed to ensure that proposed setpoint changes are given the appropriate review prior to their issuance.The PCAQ process (Potential Condition Adverse to Quality)has been implemented in QE-1603 for Nuclear Engineering Services personnel to provide identification and disposition of potential safety concerns and provide a vehicle to improve the interface with technical personnel at the plant.We also plan to develop a streamlined approval process for technical support projects not involving modifications.

In the long term we will examine establishing a single process for all Nuclear Division personnel to report specific concerns which may have safety significance.

Processes will be developed to ensure commonality of procedures between NES and the Technical Section at Ginna.B-7 0 0 0 SYSTEMATIC ASSESSMENT OF ENGINEERING ASSURANCE ISSUES AND RHR SSFI CONCERNS APPENDIX A Cl0 Pro rammatic Concerns Areas Involvin Si ificant Identified Weaknesses Res onse Sco e Listin ENGINEERING MANAGEMENT Weakness in managerial and administrative controls Management relies on engineer's experience instead of formal controls Engineering management has not provided clear guidance and procedural controls over design change process Lack of Engineering Assurance Practices Organizational Interfaces w~Control of documentation, engineering design interfaces, and engineering communications with external organizations is poor.Lack of criteria for.determining when engineering concurrence is needed DCR's not processed in a timely manner Design output not properly distributed UFSAR contains invalid information No process for handling safety concerns identified outside the engineering process P&ID change did not result in an UFSAR change as appropriate Engineering Discipline Interfaces Each discipline has its own interpretation of engineering procedure requirements.

Engineering Management has a different perception than the engineering staff P&ID changes occurred without an interdisciplinary review CONFIGURATION MANAGEMENT Plant Baseline Configuration Lack of complete and consistent nomenclature between P&IDs and procedures, UFSAR and QA Manual Deletion of information from P&IDs Design Bases r~Design Basis Calculation not available or do not exist~Lack of documented design basis is a generic weakness~UFSAR contains invalid information without a supporting design basis~No calculation list or formalized overall listing

~Operating procedures, emergency procedures, and operator training.,material do not reflect the limiting design basis of the system Design Modifications RG&E does not have a mechanism for accounting for synergistic effects of modifications (electrical calcs, pipe stress calcs)Numerous weaknesses exist in engineering support and plant modification activities Document Control ,~UFSAR contains invalid information Lack of comprehensive controlled instrument list Weakness in management control system to assure complete and consistent design output is issued and distributed PSIDs issued have removed and revised information.

Team concerned how RG6E maintains traceability of this information Informational inconsistencies exist between documents DCR processing is not timely EWRs remain in personal control of responsible engineer EWRs lack index Completed EWRs are not processed into the document control system in a timely manner Uncontrolled training material ENGINEERING PROCEDURES Design Reviews Review process lacks depth Review and verification does not strictly follow ANSI N45.F 11 Inadequate Review Independent Verification not done in accordance with engineering procedures Calculations-Generic weakness in review and approval of calculations Calculational control program (ANSI N45.2.11)is weak No list of calculations, no way to track past calculations Setpoints~Instrument loop setpoints may not account for loop inaccuracies

~Acceptance criteria not established in test procedure for setpointof undervoltage alarm relays Other Lack of formal control of engineering and design documents RG&E design control measures do not compare favorably with accepted industry practices UFSAR contains invalid information Lack of interface control with internal and external organizations SRV testing procedures contain general and minimal information SAFETY CONCERNS Inability to properly identify safety concerns (battery load profile deficiencies not discovered)

Inability to assess safety concerns (poor root cause analysis)No mechanism to disposition safety concerns identified outside of the normal engineering process (PIC-629 EWR did not reflect any action taken on identified concern TESTING DC undervoltage test inadequate SRV testing inadequate MCCBs not tested periodically SPECIFIC DESIGN CONCERNS SW Single Failure Inadequate RHR NPSH Jumper cable exceeded minimum allowed bend radius Battery rack do not have a grounding cable RHR pump seal failure (Eg)RHR pump seal failure causing loss of both RHR pumps (single failure)