ML17262A133
| 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) | |
See also: IR 05000244/1989081
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)