ML20199E169

Insp Rept 50-298/98-22 on 981116-1208.Violations Noted.Major Areas Inspected:Licensee Performance in Completing Engineering Strategy Action Item 3.2.e

ML20199E169
Person / Time
Site:	Cooper
Issue date:	01/07/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199E157	List: IR 05000298/1996004 ML20199E152 ML20199E169
References
50-298-98-22, NUDOCS 9901200342
Download: ML20199E169 (31)

See also: IR 05000298/1998022

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ENCLOSURE 2

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

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Docket No.:

50-298

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License No.:

DPR 46

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Report No.:

50-298/98-22

Licensee:

Nebraska Public Power District

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Facility:

Cooper Nuclear Station

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Location:

P.O. Box 98

Brownville, Nebraska

Dates:

November 16 through December 8,1998

Inspectors:

David P. Loveless, Sr. Project Engineer

William M. McNeill, Reactor Engineer

James F. Melfi, Project Engineer

Approved By:

Charles S. Marschall, Chief

Project Branch C

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Division of Reactor Projects

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ATTACHMENTS:

Attachment 1

Supplemental Information

Attachment 2

Work Item Sample Selections Reviewed

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Attachment 3

Documents Reviewed

Attachment 4

Unauthorized Modification Review Program

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9901200342 990107

PDR

ADOCK 05000298

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EXECUTIVE SUMMARY

Cooper Nuclear Station

NRC Inspection Report 50-298/98-22

This focus inspection was conducted to evaluate the licensee's performance in completing

Engineering Strategy Action item 3.2.e," Complete the Unauthorized Modification Review," as

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documented in the Cooper Nuclear Station Strategy for Achieving Engineering Excellence,

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Revision 2. This program had been created to correct deficiencies identified in previous

escalated enforcement. This focus inspection was the first inspection of a completed

engineering improvement strategy item. The team identified that the program had not identified

all unauthorized modifications, nor had all identified unauthorized modifications been properly

evaluated and dispositioned. The specific safety significance of items identified by the team

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was considered to be relatively low. However, the findings indicated a lack of adequate

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management oversight of the program. Corrective actions to prevent recurrence of

unauthorized modifications via the maintenance work order process were effective.

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Maintenance

The licensee's changes made to their procedures and processes for handling

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maintenance work requests (MWRs) effectively precluded unauthorized modifications.

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The work planners and maintenance craftsmen were sensitive to potential configuration

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changes, and a review of recently completed MWRs did not identify any unauthorized

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modifications (Section M3.1).

The existence of 318 items identified by the licensee as potential unauthorized

modifications, that had not been identified through MWR review, indicated that past

weaknesses in other licensee programs may have also resulted in unauthorized

modifications (Section M3.1).

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Enaineerina

Licensee personnel had failed to identify seven unauthorized modifications identified by

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the team. This failure was the first example of a violation for the failure to take adequate

corrective actions to the problem identified as Violation 50-298/9604-1013. The safety

significance of the items identified by the team was low. However, the findings indicated

a lack of program oversight (Section E1.1).

Licensee engineers failed to properly evaluate all of the conditions adverse to quality

identified by the unauthorized modification review program. This failure was an

additional example of a violation for the failure to take adequate corrective actions

regarding Violation 50-298/9604-1013. The safety significance of items identified by the

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team was low (Section E1.2).

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Licensee management oversight for the unauthorized modification review program was

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insufficient to identify and correct problems identified by the team. Licensee engineers

failed to utilize their design control process in resolving a majority of the unauthorized

modifications documented. This failure resulted in one example of a violation. Also,

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program coordinators made a decision to leave the backlog items open without a

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complete understanding of the scope and potentialimpact of each item

(Sections E1.1, E1.2, and E7.1).

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Report Details

ll. Maintenance

M3

Maintenance Procedures and Documentation

M3.1 Maintenance Proaram Chanaes to Prevent Unauthorized Modifications

a.

Inspection Scope (62702)

The team reviewed the changes made to maintenance procedures and processes to

assess if these changes should preclude future unauthorized modifications. Interviews

were conducted with maintenance department working level personnel. The team

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evaluated a random sample of MWRs completed after corrective actions were

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implemented to determine if they contained unauthorized modifications.

Backaround

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On November 8,1995, the NRC team identified that the main steam tunnel blowout

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panel sections did not appear to be consistent with diagrams in applicable design

calculations. A structurally significant coating had been placed on the secondary

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containment side of the panel sections, potentially altering their material characteristics

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and strengthening the blowout panel . sections. Increased structural strength would have

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been nonconservative for the blowout panel's design basis function. In addition, the

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design configuration of the panel sections had not been maintained in associated

documents and drawings. An apparent violation was identified for the failure of the

licensee to pedorm an evaluation in accordance with 10 CFR 50.59 on this modification

to the steam tunnel blowout panel sections. The resulting enforcement action issued

Notice of Violation 96004-01013.

The licensee's response dated May 17,1996, committed to review MWRs according to

a sampling plan. The review would detect modifications installed without performance of

safety evaluations. The sample size initially consisted of 10 percent of a se!ecteo

population of MWRs from 1974 to 1996. The review of this sample of 2090 MWRs

resulted in the identification of 128 unauthorized modifications.

As a result of these findings, the licensee expanded the scope of their sampling to

include all of the remaining MWRs from 1973 - 1996. In an effort to identify all

unauthorized modifications in the plant, the licensee established a population of

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95,736 MWRs written since initial licensing until June 12,1996. June 12,1996, was the

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date of implementation of the corrective actions to eliminate the possibility of making an

unauthorized modification by means of the MWR process. The licensee divided these

MWRs into two groups. One group of 22,834 MWRs written before 1980 were available

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on microfilm. A second group of 72,902 MWRs written after 1980 were available on

microfilm copy and documented in an electronic data base. The electronic data base

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allowed the licensee to do a " key word' search of those MWRs written after 1980. From

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the keyword search, the 72,902 MWRs were reduced by 51,994 MWRs to

20,908 MWRs.

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Licensee personnel screened 14,740 of the 20,908 MWRs by evaluating whether the

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documents contained changes that may have been unauthorized modifications. This

was referred to as the first screening criteria. Approximately 5,712 MWRs were

screened, utilizing the same criteria, by contract personnel. Of the 20,908 MWRs

screened,2,956 were considered to be potential unauthorized modifications.

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In addition to the MWR review, the licensee also evaluated past problem identification

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reports (PIRs) to determine if any documented potential unauthorized modifications. An

additional 318 items were considered to be examples of potential unauthorized

modifications. However, it was not determined if these were associated with MWRs.

The team considered the existence of 318 items considered potential unauthorized

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modifications to be a serious question of the logic used by the licensee. It was originally

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assumed by the licensee that all unauthorized modifications were associated with

weaknesses in the MWR process. Therefore, an exhaustive review of MWRs should

have revealed all unauthorized modifications. Licensee management committed to

further review and evaluate the cause of the unauthorized modifications documented in

these 318 PIRs.

In accordance with the licensee's program, all potential unauthorized modifications were

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given a second, more detailed screening. Of the 3,274 potential unauthorized

modifications (2,956 MWRs and 318 PIRs), project personnel concluded that 1,023 did

not document unauthorized modifications. This resulted in a final tally of 2,251

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unauthorized modifications identified by the project and requiring disposition. The team

documented an accounting of the screening process discussed above in Attachment 4.

b.

Observations and Findinas

As corrective action to prevent recurrence of the unauthorized modification problem,

licensee personnel combined the requirements of several procedures. Maintenance

personnel deleted Procedures 7.0.1.3," Maintenance Work Request Planning -

Documentation of Work," and 7.0.1.6, " Maintenance Work Request - Minor

Maintenance." For unauthorized modifications, the licensee changed Administrative

Procedure 0.40, " Work Control Program," combining these requirements into this

procedure. The licensee also added instructions into Maintenance Procedure 7.0.4,

" Conduct of Maintenance," to obtain an engineering evaluation for configuration control

changes.

The maintenance craftsmen interviewed were cognizant of the unauthorized

modification issues and the need to verify that replacement components were exactly

the same. If the components were different, the maintenance craft would obtain an

engineering evaluation for the change.

The team observed portions of the work planning process to verify that an unauthorized

modification would not occur. The work planners properly evaluated potential

configuration changes and used a planners' desk guide to prescreen MWRs for those

requiring an engineering review. The team also observed the planners' discussion at a

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routine meeting to review emergent work. The personnel at the meeting were sensitive

to the potential for unauthorized configuration changes and the need for engineering

review of these changes.

To verify that these procedure changes were effective and the knowledge of the workers

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was adequate, the team reviewed a random sample of 60 MWRs completed after these

procedure changes were implemented. A listing of the MWRs is included in

Attachment 2. The team did not identify any unauthorized modifications documented

within this sample.

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Coriciusions

The team concluded that the changes made to licensee procedures and processes for

MWRs effectively precluded unauthorized modifications. The work planners and

maintenance craft were sensitive to potential configuration changes, and a review of

recent MWRs did not identify any unauthorized modifications. However, the team found

that the existence of 318 items identified by the licensee as potential unauthorized

modifications, that had not been identified through MWR review, indicated that past

weaknesses in other licensee programs may have resulted in unauthorized

modifications.

Ill. Engineering

E1

Conduct of Engineering

E1.1

Review of MWRs for Unauthorized Modifications

a.

Inspection Scope (37551)

The team assessed the scope and quality of the licensee's efforts involving the

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unauthorized modification review program as defined in "CNS Strategy for Achieving

Engineering Excellence," Revision 2, dated July 8,1998. Samples of MWRs were

ovaluated to determine if they contained unauthorized modifications not identified by the

licensee's efforts. The team also conducted interviews with key personnel and

management involved in the review,

b.

Observations and Findinos

The team selected statistically significant samples from each of five populations

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according to the method utilized by licensee personnelin determining if unauthorized

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modifications existed. The populations are described end the specific examples listed in

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Attachment 2 to this inspection report. The following are the findings of the team related

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to each sample:

1.

The team drew a sample (Sample 1) of 60 MWRs from the population of

22,834 MWRs worked prior to mid 1980 to verify proper sorting of the MWRs.

The goal of the team was to review only those MWRs determined by the licensee

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not to include unauthorized modifications (rejected). However, the total

population of 22,834 MWRs was sampled because the project coordinators had

not tracked the exact number of MWRs rejected from this population. The team

sampled the entire population, and the 3 MWRs previously identified by licensee

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personnel to document unauthorized modifications were verified to be included

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on the list of 2,251 unauthorized modifications identified by the licensee.

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The team identified one MWR from Sample 1 that represented an

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unauthorized modification. Based on the team's sampling method, the

identification of one MWR documenting an unauthorized modification that

had not been identified by the licensee's process was statistically

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significant. The MWR identified was worked on May 11,1978. At that

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time, craftsmen manufactured and installed a guard over the fire system

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flushing pump ventilation openings to prevent recurrence of bird's nests.

Licensee personnel concurred with the team's findings and issued

PIR 3-40350 to document the failure to identify and correct this specific

unauthorized modification.

2.

The team drew a sample (Sample 2) of 60 MWRs from the population of

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51,994 MWRs. These MWRs represented the population of MWRs that were

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screened by computer searching techniques and determined not to be

unauthorized modifications. Licensee personnel had utilized a keyword search

to identify MWRs that were likely to have involved changes to the facility, while

ruling out those that were properly authorized by appropriate design change

documents. No unauthorized modifications were identified by the team from

Sample 2.

The team used a statistical tolerance sampling plan with a minium sample size

that would give a high degree of assurance that the licensee's screening process

was effective. The lack of identified unauthorized modifications from Sample 2

indicated a 95 percent confidence that 95 percent of the population did not

contain unauthorized modifications.

3.

The team drew two samples (Samples 3 and 4, respectively) from the population

of 20,462 MWRs. These represented the MWRs from 1980 through 1996 that

had not been rejected via computer screening techniques, but were not

considered potential unauthorized modifications by the licensee staff making the

reviews. These items had been rejected using the licensee's first screening

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criteria as defined in Section M3.1.b of this inspection report. Sample 3

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consisted of 60 MWRs selected from those screened by permanent plant

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personnel. Sample 4 consisted of 60 MWRs selected from those screened by

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the licensce's contractor. No unauthorized modifications were identified by the

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team from Sample 3.

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4.

The team identified four MWRs from Sample 4 that represented unauthorized

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modifications. Based on the team's sampling method, the identification of four

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MWRs documenting unauthorized modifications that had not been identified by

the licensee's process was statistically significant. The following represents the

unauthorized modifications identified by the team:

MWR 94-4167 documented an unauthorized modification to computer

consoles in the main control room. On January 10,1992, craftsmen

installed a 9% foot section of 1-inch square tube steelin the center of the

main control room. The tube steel was installed as a protective barrier to

existing power cables. Licansee personnel concurred with the team's

findings and issued PIR 4-00022 to document the failure to identify and

correct this specific unauthorized modification.

MWR 90-2588 documented an unauthorized modification to an indicator

isolation valve in the auxiliary steam system. On May 23,1990,

craftsmen replaced a leaking auxiliary steam petcock with a needle valve.

The MWR documented that a different type of valve was used and that

the equipment data file needed to be updated. After NRC identification,

licensee review found that they failed to update the equipment data file.

The valve installed was similarly rated for system pressure and the

system was not safety related. Licensee personnel concurred with the

team's findings and issued PIR 3-40341 to document the failure to

identify and correct this specific unauthorized modification.

MWR 86-2979 documented an unauthorized modification to a pump

instrument rack in the spent fuel pool cooling system. On August 7,

1986, craftsmen installed two pipe clamps to fix vibrating instrument and

controls piping. Licensee personnel concurred with the team's findings

and issued PIR 3-40338 to document the failure to identify and correct

this specific unauthorized modification.

MWR 91-4738 documented an unauthorized modification to a steam

tunnel fire protection suppression piping hanger. On August 23,1994,

craftsmen reinstalled a pipe hanger utilizing instructions provided by the

planner. The component was modified by relocating the hanger,

enlarging the support plate holes, drilling holes in the steam tunnel wall,

and using larger anchor bolts. Licensee personnel concurred with the

team's findings and issued PIR 3-40351 to document the failure to

identify and correct this specific unauthorized modification.

5.

The licensee's program prompted engineers to perform a second screening of

the potential unauthorized modifications identified by the first screening utilizing

different criteria. During the second screening, engineers reviewed the

3,274 items identified as potential unauthorized modifications, reducing the total

to 2,251 considered by the licensee as documenting unauthorized modifications.

The team sampled 60 MWRs (Sample 5) from the 1,023 MWRs rejected to verify

the effectiveness of the second screening process. The team identified two

MWRs from Sample 4 that represented unauthorized modifications. Based on

the team's sampling method, the identification of two MWRs documenting

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unauthorized modifications that had not been identified by the licensee's process

was statistically significant. The following represents the unauthorized

modifications identified by the team:

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MWR 76-3-71 documented an unauthorized modification to the drywell

high pressure annunciator associated with the drywell pump-around

system. Setpoints for the system air compressor automatic function and

the associated annunciator were changed. This system has been

abandoned in place except for testing purposes. Licensee personnel

disagreed with the team's findings because the changing of setpoints on

an abandoned system was not considered to constitute an unauthorized

modification under the licensee's review process. However, the team

determined that the setpoint changes had been made without appropriate

design controls. PIR 3-53069 was issued to document the team's finding

and to further evaluate the concern.

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MWR 79-5-51 documented an unauthorized modification to the reactor

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high water level turbine trip circuitry. On May 18,1979, craftsmen

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installed a capacitor in parallel with a reactor feedwater pump control

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circuit. The capacitor was installed to reduce noite in the control

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circuitry. The engineers performing tha second level screening had

decided that this was not an unauthorized modification because they

thought that the capacitor had been removed in accordance with an

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approved design modification. However, in response to the team's

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questions, engineers performed additional visual inspections, revealing

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that a capacitor had been installed and remained in the circuitry.

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Licensee personnel disagreed with the team's findings because the item

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had been addressed by the " white paper." However, the team noted that

the item was clearly documented in the " white paper" as not being an

unauthorized modification when the addition of a capacitor to the circuit

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met the definition of an unauthorized modification. Licensee engineers

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documented the team's findings on PIR 3-40352 to further evaluate the

concern.

During the review of Samples 1 through 5, the team identified seven unauthorized

modifications that had not been identified by the licensee's review process. These

seven were identified from three populations with a sample of 60 MWRs from each

population. This represented an error rate greater than 2 percent from the total

300 MWRs reviewed by the team members. The evaluation of MWRs in Samples 2 and

3 produced no unauthorized modifications not previously identified by the licensee. This

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indicated a high level of confidence in the computerized screening process and in those

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initially screened directly by licensee personnel. To the contrary, the team identified

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seven MWRs from Samples 1,4, and 5 that represented unauthorized modifications.

Based on the team's sampling method, the identification of these seven MWRs

documenting unauthorized modifications that had not been identified by the licensee's

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process was statistically significant. The safety significance of the seven unauthorized

modifications identified by the team was low. However, the findings indicated a lack of

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program oversight.

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The team concluded that the failure of the licensee's program to identify these seven

unauthorized modifications constituted inadequate corrective action taken as a result of

Violation 50-298/9604-1013. This failure to take adequate corrective action is the first

example of a violation (50-298/9822-01). This violation is being cited because it was

identified by the inspectors and, th 3refore, does not meet the criteria for discretion as

documented in the NRC Enforcement Criteria. A response is required for this violation

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because the issue was not entered into the licensee's corrective action program until

after the inspection was complete. Additionally, the licensee's corrective actions will be

reviewed for applicability to the closure of other engineering strategy items.

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c.

Conclusions

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The team identified seven unauthorized modifications from three populations with

samples of 60 MWRs from each population. This represented a greater than 2 percent

hit rate from the total 300 MWRs the team members reviewed. The failure of licensee

personnel to identify these unauthorized modifications during their review was the first

example of a violation for the failure to take adequate corrective actions for the problem

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identified as Violation 50-298/9604-1013. The safety significance of the items identified

by the team was low. However, the findings indicated a lack of program oversight.

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E1.2

Evaluation of Identified Unauthorized Modifications

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a.

Inspection Scope (37551,37001)

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The team reviewed samples of items identified by the licensee as being unauthorized

modifications. Th9 adequacy of the licensee's evaluation and corrective actions for

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these identified una Jthorized modifications were assessed. Team members reviewed

documentation and ,mocedures, performed visual inspections of plant components, and

interviewed person iel t<> assess the adequacy of the licensee's review.

b.

Observations and Findinas

The team selected statistically significant samples from each of three populations

according to the method utilized by licensee personnel in evaluating and dispositioning

the identified unauthorized modifications. The three populations were categorized as:

(1) unauthorized modifications dispositioned by the licensee's generic " white paper;"

(2) items dispositioned by generic engineering evaluations addressing multiple

unauthorized modifications; and (3) unauthorized modifications dispositioned by item

specific evaluations or reviews. The team described the populations and listed the

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specific examples in Attachment 2. The following are the findings of the team related to

each sample:

1.

The team drew a sample of 60 MWRs (Sample 6) from the population of 1,107

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unauthorized modifications that were dispositioned by the " white paper."

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Program coordinators had grouped potential unauthorized modifications into one

of seven categories. Each category was then resolved on a generic basis.

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While reviewing Sample 6, the team identified three examples of inadequate

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resolution of design documentation errors that resulted from the unauthorized

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modification. These represented examples of unauthorized modifications

identified by the licensee that were not properly dispositioned.

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Also, during the team's review of Sample 6, the licensee staff issued

PIR 3-40349 to identify that the " white paper" was not a controlled design

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document nor were the dispositions of all MWRs associated with the " white

paper" resolved in accordance with the design process. The failure to use an

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approved design process to make or accept design modifications was in violation

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of 10 CFR Part 50 Appendix B, Criterion Ill. However, the specific examples

identified by the team were cited in the Notice of Violation as a failure to take

adequate corrective action. The following documents the specific issues

identified by the team:

MWR 76-4-108 documented an unauthorized modification of an offgas

control room ventilation system solenoid. On April 30,1976, craftsmen

installed two snubbers on the cooling water lines. This was identified by

the licensee as an unauthorized modification. However, the current

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drawings were not updated to reflect the change. Engineers had

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determined, as documented in the " white paper," that no documentation

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changes were required. The licensee agreed that this condition was

improperly evaluated and issued PIR 3-40353 to document and correct it.

MWR 76-6-13 documented an unauthorized modification of a

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temperature control valve temperature element in the main generator

exciter. On October 15,1976, craftsmen relocated a temperature

element in the main generator exciter to improve the sensing capability of

the element. However, the current drawings still do not reflect the

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change. The expert panel had determined that no documentation

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changes were required. The licensee agreed that this condition was

improperly evaluated and issued PlR 4-00020 to document and correct

the condition.

MWR 77-3-158 documented an unauthorized modification of the air wash

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systems for various plant ventilation systems. On March 28,1977,

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craftsmen removed from the reactor building, turbine, and other buildings'

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ventilation systems an air wash subsystem that did not work. These

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subsystems were designed to remove particulate from the air supply.

This was identified by the licensee as an unauthorized modification.

However, the associated drawings have not been consistently updated.

Currently, this is a configuration control problem, but the disposition

stated that no configuration documents required updates. The licensee

agreed that this condition was improperly evaluated and issued PIR 4-

00068 to document and correct the condition.

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2.

The team drew a sample of 88 MWRs (Sample 7) from the population of

approximately 545 unauthorized modifications that were dispositioned by generic

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engineering evaluations. The team determined that these MWRs were

associated with the 15 engineering evaluations documented in Table S-7.1 in

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Attachment 2. The team reviewed the engineering evaluations for adequacy and

assessed the adequacy of these evMuations to address the unauthorized

modifications documented in the ar,s:)ciated MWRs. The team identified one

problem with the adequacy of assumptions used in an engineering evaluation in

Sample 7. This was an additional example of an unauthorized modification

identified by the licensee that was not properly dispositioned. The following

documents the specific issue identified by the team:

item E97-0244 documented a visualinspection of plant anchor bolt

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installations that had been conducted by licensee engineers. One of

these anchor bolt installations was the mounting for a reactor building

room partition that was not part of the original design. This had been

identified by the licensee as an unauthorized modification. Engineering

Evaluation 98-048 concluded that Calculation NEDC 97-093 was

adequate to address and resolve this unauthorized modification.

Calculation NEDC 97-093 addressed the partition and determined that it

was acceptable for a use-as-is disposition. This acceptance was despite

the indication that the anchor bolts in the partition were inadequate

because an assumption was made that the partition would not hit any

safety-related equipment should it fall over. A team visual inspection

revealed that the 7-foot tall partition was less than 5 feet from a hydrogen

analyzer. The licensee has agreed that this condition was improperly

evaluated and initiated PIR 3-40342.

3.

The team drew a sample of 60 MWRs (Sample 8) from the population of an

estimated 599 unauthorized modifications that were dispositioned by item-

specific evaluations and assessments. Three problems were identified in

Sample 8 associated with the licensee's proper identification of the design basis.

These were additional examples of unauthonzcd modifications identified by the

licenseo that were not properly dispositioned. The fo!!owing documents the

specific issues identified by the team:

item E97-0101 documented an unauthorized modification to multiple

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plant components consisting of the attachment of drip pans. Licensee

engineers had reviewed multiple installations of drip pans attached

directly to plant process components. A calculation had been prepared

for the resolution of pans attached to nonsafety-related equipment.

However, the subject closure package stated that the calculation was

also applicable to the resolution of safety-related penetrations. The team

noted that the calculation only addressed Seismic Category 11 component

interactions as opposed to the more stringent requirements of Seismic

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Category I applied to safety-related components. The licensee agreed

that the results were inconclusive and that specific locations were not

evaluated, and PIR 4-00029 was issued to further review the problem.

MWR 75-4-228 documented an unauthorized modification to the residual

heat removal system pump seal water lines. Craftsmen had fabricated

and installed two stiffener brackets. Although the licensee identified this

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as an unauthorized modification, they determined that no additional

corrective action was required solely because the resolution was

addressed in a General Electric service information letter. The closure

documentation stated that the expert panel determined the service

information letter to be the design basis. The licensee has concurred that

vendor information does not become part of the design basis without an

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appropriate review and safety evaluation. The licensee planned to

address this as a generic problem with their process for handling service

information letters. They documented the concern in PIR 4-00041.

MWR 77-11-68 documented an unauthorized modification to the refueling

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machine fuel handling grapple. Craftsmen had modified the fuel grapple

by removing the support spring and replacing several other components.

Although the licensee identified this as an unauthorized modification, they

determined that no additional corrective action was required solely

because the resolution was addressed in a General Electric service

information letter. The closure documentation stated that the expert

panel determined the service letter to be the design basis. The licensee

concurred that vendor information does not become part of the design

basis without an appropriate review and safety evaluation. This concern

was documented in PIR 4-00041. As stated previously, the licensee

planned to address a generic problem with the handling of service

information letters.

During the review of MWRs and associated items included in Samples 6,7, and 8, the

team identified seven items that the licensee had not properly evaluated once they

identified that an unauthorized modification existed. The team identified problems with

items in each sample, indicating a lack of confidence in each of the statistically

significant samples. The team found that the safety significance of inadequate

evaluation of these seven items was low. However, the findings indicated a lack of

program oversight.

The team concluded that the failure of the licensee to properly evaluate and resolve

j

these seven unauthorized modifications constituted inadequate corrective actions taken

'

as a result of the problem identified as Violation 50-298/9604-1013. This failure to take

adequate corrective action is a second example of a violation (50-298/9822-02).

Additionally, the team reviewed the licensee's backlog of items to be completed

following closure of the unauthorized modification review program. The team evaluated

those unauthorized modifications from Sample 6 that contained backlog items, as

!

documented in Table S-6 of Attachment 2. The program coordinators had characterized

the backlog as requiring only minor procedural or drawing updates. However, the team

found that many items required visual inspection to fully assess the scope of the

problem and that the coordinators required contractor support to better explain the open

issues. The team concluded that the licensee's decision to leave the backlog open was

made without a complete understanding of the scope and potentialimpact of each item.

The program coordinators initiated PIR 3-40348 to document this issue and evaluate the

_ . _ _ _ _ - _

_ ___-

_ ._-

___

- . _ . _ . _

_ _ _ _ . _ _ _

. _ . .

.

-

-11-

i

need for corrective action, including properly identifying the scope of work remaining to

l

close each action.

l

c.

Conclusions

l

The team identified seven MWRs that were not properly evaluated once the licensee

determined that they documented unauthorized modifications. The engineers' failure to

l

properly evaluate and correct the conditions adverse to quality identified by the

l

unauthorized modification review program was an additional example of a violation for

l

the failure to take adequate corrective actions for the problems identified as

)

l

Violation 50-298/9604-1013. The safety significance of items identified by the team was

low. However, the findings indicated a lack of program oversight. The lack of proper

design control for the issues resolved by the " white paper" and the licensee's decision to

leave the backlog items open having been made without a complete understanding of

the scope and potentialimpact of each item were considered additional examples of a

lack of program oversight.

E7

Quality Assurance in Engineering Activities

E7.1

Oversiaht of the Unauthorized Modification Review Proaram and the Enaineerina

Strateav

a.

Inspection Scope (37551)

The team reviewed and evaluated documented licensee assessments of the

unauthorized modification review program. Line management involved in the oversight

and closure review of the process were interviewed. Additionally, the team observed

routine engineering strategy review meetings.

b.

Observations and Findinas

Following NRC identification of an unauthorized modification associated with the steam

tunnel blowout panel and other related problems, the quality assurance organization

conducted a special audit to determine the nature and scope of the problems. This

special audit resulted in a review of MWRs for potential unauthorized modifications. The

team reviewed those quality assurance audits and surveillances documented in

Attachment 3 to this inspection report. Additionally, the team summarized the scope

and findings of each review as documented in Attachment 3.

Licensee personnel had conducted quality assurance audits and performed

management oversight of the unauthorized modification review program. Problems with

the first-level screening of MWRs conducted by the contractor were identified during one

surveillance and corrective actions were proposed. A followup surveillance activity,

performed about 6 weeks later, conc;uded that the problems had been corrected. No

other significant items were noted in the audits or surveillances. However, quality

i

l

assurance auditors did not further evaluate the effectiveness of corrective actions

!

-_-

k

_ - _____________ _ ___-__

-12-

throughout the process. The team noted that the final quality assurance audit of the

program completion had not been performed at the time of the onsite inspection.

A required part of the team's sample selection process, documented in Soctions E1.1

and E1.2 of this inspection report, was to fully understand and characterize the

populations of MWRs and the screening, processing, or evaluation techniques used for

each. It took program coordinators, working with contract personnel several days to

fully charactenze the disposition and size of each population listed in Attachment 4 to

this inspection report. The team also noted problems in characterizing the extent of the

backlog and the proper design control of unauthorized modifications dispositioned in the

" white paper." The team concluded that oversight of the program End the contractor's

activities associated with the unauthorized modification review program was weak.

To better understand the oversight provided for the unauthorized modification review

program, the team observed a routine engineering strategy review meeting. The status,

preparation, schedule, and support needed for the implementation of each item was

discussed by the strategy owner. This discussion and the feedback from other strategy

item owners indicated a questioning attitude and a continuous evaluation of

implementation.

Through interviews, the team evaluated the reviews conducted by the task owner,

strategy owner, and independent reviewer on the unauthorized modification review

program, Engineering Strategy Action item 3.2.e. The task owner and strategy owner

reviews were both probing supervisory-level reviews of the package contents. The

independent reviewer had not been directly involved in the program and conaucted a

review of the closure package, including an evaluation of the appropriateness of actions

conducted. However, no independent evaluation of the process, input, or data of the

issue were conducted. The team found it positive, based on the issues identified during

this inspection, that the program closure package had not made it through the senior

engineering manager's closure process.

c.

Conclusions

The team concluded that licensee management had provided some level of oversight

over the unauthorized modification review program. However, the team identified

several problems, in addition to two examples of a violation, that indicated insufficient

program oversight.

E8

Miscellaneous Engineering issues

E8.1

Evaluation of Special Test Procedures (37001)

10 CFR 50.59 allows licensees to make changes to their plants without prior NRC

approval, provided certain conditions are satisfied such as an evaluation to establish

that an unreviewed safety question does not exist. The unauthorized modifications

review reviewed MWRs to identify modifications made to the plant that were not

authorized and not reviewed in accordance with 10 CFR 50.59. During this inspection,

f

---

____ _

b

_-

_ _ _ _ _ _ _ _ _ _ _ _ _

?

-13-

the team selected and reviewed a sample of 30 procedure changes and 30 special test

procedures previously performed that had required evaluation in accordance with

10 CFR 50.59. The team identified that eight of the special test procedures did not have

a record of a 10 CFR 50.59 safety evaluation. These procedures had been performed

prior to 1979, indicating that the programmatic problems were not current. The

procedures reviewed were documented in Attachment 3 to this inspection report.

Licensee staff issued PIR 3-40340 to document the problem of not being able to provide

evidence that 10 CFR 50.59 safety evaluations were performed for these eight

procedures. The failure to conduct and document safety evaluations for these tests is

considered unresolved (50-298/9822-02).

V. Management Meetings

X1

Exit Meeting Summary

The team presented the interim inspection results to members of licensee management

at an exit meeting on November 20,1998. A final exit meeting was conducted via

telecon on December 8 to discuss the findings contained in the report and additional

issues identified in the interim.

The team asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

X3

Focus Meeting Summary

On December 17,1998, a focus meeting was conducted between members of licensee

management and the NRC staff to discuss the status of the licensee's engineering

improvement strategy. During that meeting, licensee management discussed the

findings of this inspection and their preliminary conclusions. The exchange of

information during the meeting was candid and informative.

_ _ _ _ _ _ _ _

_ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ - _

.

.

ATTACHMENT 1

PARTIAL LIST OF PERSONS CONTACTED

Licensee

• P. Adelung, Senior Civil / Structural Engineer

• K. Billesbach, Quality Assurance Assessment Auditor i

M. Boyce, Plant Engineering Manager

• P. Caudill, General Manager, Technical Services

J. Dykstra, Senior Quality Assurance Engineer

• T. Gifford, Design Engineering Manager

• B. Houston, Nuclear Licensing and Safety Manager

M. Kaul, Shift Supervisor / Operations

D. Kunsemiller, Consultant, Licensing

J. Long, Nuclear Projects Manager

• D. Mangan, Licensing Engineer

R. Pearson, Lead Project Controls Engineer, Enercon

• B. Rash, Senior Manager of Engineering

• N. Sanjanwala, Acting Civil Design Engineering Supervisor

B. Toline, Quality Assurance Auditor Supervisor

NRC

C. Marschall, Chief, Project Branch C, Region IV

V. Gaddy, Senior Resident inspector, Acting

C. Skinner, Resident inspector

• Indicates persons attending both the November 20 and December 8 meetings.

INSPECTION PROCEDURES USED

IP 37551: Onsite Engineering

IP 37001: 10 CFR 50.59 Evaluations

IP 62702: Maintenance Observation

IP 92903: Followup - Engineering

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50-298/9822-01

VIO

Inadequate corrective action regarding the implementation of the

unauthorized modification review program (Sections E1.1 and

E1.2)

50-298/9822 02

URI

Performance of special tests without a documented safety

evaluation (Section E8.1)

.

.

ATTACHMENT 2

.

WORK ITEM SAMPLE SELECTIONS REVIEWED

Table S-1

Maintenance Work Orders

Samole 1:

Population: 22,834 MWRs written prior to mid 1980.

Sample Size: 60

73-12-170

75-4-58

76-12 86

78-2-189

74-2-37

75-7-3

76-12-103

78-3-161

74-3-36

75-9-33

77-1-102

78-4-107

74-4-180

75-10-173

77-1-189

78-5-122

74-5-248

75-11-129

77-5-259

78-6-25

74-6-114

75-12-47

77-8-3

78-6-38

74-6-294

75-12-283

77-8-49

78-9-147

74-8-292

76-1-141

77-8-250

N79-1 63

74-9-125

76-1-184

77-9-172

79-1-141

74-9-153

76-2-48

77-10-1

79-1-148

74-9-188

76-3-165

77-10-35

79-4-148

74-11-64

76-5-166

77-10-215

N79-9-30

75-1-47

76-6-197

77-10-359

79-9-147

75-1-106

76-8-61

77-12-193

80-9 13

75-3-229

76-8-184

78-1-127

N80-10-9

. . . _ .

. - . .

.

. ~ . .

-

. -

. .

. _ -

- . - - - . . _ - . _ - - . . .

_ - .

2-

Table S-2

Maintenance Work Orders

Samole 2:

Population: 51,994 MWRs rejected by computer search.

',

Sample Size: 60

80-0040

86-0502

90-1136

94-2522

81-1184

86-2921

90-2344

94-0711

82-0857

86-4081

90-3472

94-5585

83-0611

86-5257

91-0033

94-1031

83-2070

87-0744

91-1255

95-1023

84-0233

87-0611

91-2519

95-0204

84-1377

87-3111

91-3669

95-1665

'

84-2506

88-1547

92-0538

95-0525

l

85-0266

88-2810

92-2139

95-2406

85-1437

88-3954

92-3307

95-0901

85-2593

89-0045

93-0683

95-3821

85-3690

89-1265

93-1927

95-4239

86-0064

89-2504

93-0820

96-0432

l

86-0226

89-3609

93-4276

96-1024

!

'

86-0231

89-4638

94-1131

96-0700

l'

i

!

I

,

.

,

t

1

i

<

>

i

_

. .

.

-

..

._

,.

._ __

__ - ._ .

_ . _ _ _ . . . - _ - . .

_ _ _ . _ . _ _ _ . _ . _ . . _ . _ _ _ _ _ _ . _ . _ _ . _ _ _

,

'

o

4

-3-

1

Table S-3

,

Maintenance Work Orders

'

Samole 3:

Population: 14,750 MWRs rejected from first screening by NPPD

Sample Size: 70

i

0-09155

86-1135

89-2328

92-2833

I

1-24148

86-2172

89-3194

92-3496

l

81-0244

86-3201

89-3998

93-0468

i

81-1869

86-4211

90-0075

93-1095

82-0695

86-5033

90-0825

93-1759

82-2260

87-0492

90-1706

93-2303

,

4

83-1068

87-1390

90-2593

93-2925

83-1996

87-2318

90-3397

93-3591

84-0085

87-3184

90-4295

93-4169

1

84-1071

88-0180

91-0606

94-0120

84-2070

"20986

91-1334

94-0722

84-2976

88-1713

91-2076

94-1294

'

85-0509

88-2476

91-2896

94-1937

85-1367

88 3311

91-3671

94-2525

85 2249

88-4185

92-0179

94-3155

85-3097

88-5015

92-0910

94-3839

85-4077

89-0641

92-1543

l

,

86-0337

89-1521

92-2284

l

i

?

.

.-

.

,

_-

.o

.

-4-

Table S-4

Maintenance Work Orders

Samole 4:

Population: =5,712 MWRs rejected from first screening by Enercon

Sample Size: 63

0-07309

92-1936

94-6534

95-2100

82-0691

92-3234

94-6713

95-2334

84-2058

93-0649

94-6897

95-2606

85-1303

93-2691

94-6967

95-2832

85-4074

94-4089

94-7040

95-2875

86-1134

94-4267

95-0041

95-3003

86-2979

94-4548

95-0255

95-3183

88-2456

94-4738

95-0460

95-3396

89-0639

94 4914

95-0700

95-3545

90-0720

94-5104

95-0904

95-3724

90-2588

94-5312

95-1099

95-3988

90-3054

94-5551

95-1305

95-4299

91-3288

94-5643

95-1317

95-4570

91-3670

94-5792

95-1480

96-0017

91-4167

94-6062

95-1642

96-0267

92-0699

94-6269

95-1882

96-0755

1

,

f

. - . -

. - --.-_

.-

..=...--- - -- -...-..

.. - - - -

- -- - --

-

o

.

a

.

5

i

i

Table S-5

Maintenance Work Orders

,

,

Samole 5:

. Population: 1,023 MWRs rejected from second level screening

!

Sample Size: 60

i

74-2-142

75 8-123

76-3-141

78-9-148

74-2-211

75-8-216

76-3-260

79-5-51

74-6-314

75-9-23

77-2-10

N79-10-98

74-8-292

75-9-152

77-3-161

80-4-4

75-1-139

75-9-318

77-4-343

N80-245

l

75-3-36

75-10-14

77-6-54

83-1735

l

l

75-3-126

75-10-60

77-6-121

84-0562

i

.

L

75-4-224

75-10-68

77-6-214

84-1805

75-4-247

75-10-132

77-12-101

89-1538

<

l.

75-6-13

75-10-323

78-1-158

89-1658

!

75-6-215

75-12-92

78-3-34

91-0311

75-7-56

76-1-285

78-4-251

91-2256

75-7-263

76-1-353

78-5-149

91-4099

75-7-328

76-2-187

78-5-178

92-1660

75-8-15

76-3-71

78-7-196

93-2773

i

r

!. '

r

).

• i

?

l

,

i

'

.

- - -

,

-

.-

c

. - ~ . . . -

,

- - , ,

y--

-

r.

_

-w

. _. _.

_..

. . . _ . - . . _ . _ _ _ . _ _ _ .

. . . . . _ _ . _ . _ . _ .. _ _ .. _ . _ _ _ . _ _ .. _ - _ _ _ _ ... ._

-

O

, .

-6-

!

Table S-6

'

Unauthorized Modifications

Samole 6:

Population: 1,107 ltems resolved by the White Paper

Sample Size: 60

.

74-1-235

76-6-13

N79-7-41

91-0249*

74-1-87

76-9-44

N80-3-58

91-0911

'

74-12-317

76-10-30

N80-6-111

92-0667

74-2-100

76-11-239'

N80-9-161

92-2295

74-4-424

77-3 158

81-1816

93-0140

74-4-546

77-4-70

82-1223*

93-3758

74-6-226

77-6-212*

83-1044

94-2353

I

74-7-406

77-7-134

83-2677

95-0027

i

L

74-8-66*

77-10-327

84-0629

97-0017*

i

!

l

74-9-127*

77-12-103

84-3244

E97-0072

.

75-3-280

78-3-49

85-3126

E97-0174*

I

75-6-30

78-4-208'

86-3044

E97-0279*

75-9-46

78-8-147

89-3910

E97-0300*

l

75-10-294

78-10-170

90-1916*

E97-0371

!

76-4-108

79-4-94

90-2425

E97-0378*

• Items with open issues, " Backlog'

l

t

i

!

,

(

.

4

i

i

!

<

---

-.

-

e

-

. - - . - - . . .

-

- _ - . .

.

- _ ._ -

_

- ... -.. - - -. - --

_

l

-7-

Table S-7

Unauthorized Modifications

'

l

i

Samole 7:

Population: 545 Items resolved by generic engineering evaluations

Sample Size: 88

74-2-67

78-5-42

82-1604

92-0131

74-2-360

78-6-167

83-0355

92-3034

74-3-23

78-9-119

83-0918

94-0957

74-9-204

78-10-133

83-1689

94-4396

75-5-149

, N79-1-6

83-2214

94-4919

75-7-184

79-4-61

83-2561

95-0774

75-10-85

79-5-5

84-0844

95-1347

76-11-253

N79-5-195

84-2181

E97-0028

76-2-259

79-12-33

84-2794

E97-0093

76-5-176

79-12-39

85-0524

E97-0082

76-6-118

80-3-3

85-3169

E97-0106

77-1-151

80-3-49

86-1603

E97-0113

77-4-121

N80-3-90

86-5330

E97-0117

77-5-117

80-5-7

87-2933

E97-0171

77 6-4

80-0180

88-2041

E97-0182

77-8-352

80-0340

88-3648

E97-0200

77-8 357

81-0176

89-4464

E97-0224

77-12-104

81-0668

89-4486

E97-0242

78-2-76

81-1372

90-1258

E97-0244

78-2-104

81-1898

90-1941

E97-0255

78-3-168

81-2407

90-2885

E97-0356

78-4-236

82-1005

91-2573

E97-0364

l

l

!

!

,.

,

.

.. . -..

. -- _

_ _ . - . - - - . - -

- -

. . -

. - . .--

..

.o

+

8-

Table S-7.1

Enaineerino Evaluations

.a

.

Generic engineering evaluations associated with Sample 7 MWRs

l

Sample Size: 15

Engineering

Title / Description:

Evaluation:

98-136

Evaluation of Miscellaneous Essential Electrical and I&C Unauthorized

'

Modifications

i

98-132

Evaluation of Miscellaneous Essential Mechanical Unauthorized

Modifications98-098

Packing Replacements98-032

Adding Load to Motor Control Centers MCC-LX & MCC-TX

98-010

Qualify Existing 1/4" Tubing Betv'een Valves DW-V-147 and HPCI-V-284.98-009

Evaluation of Miscellaneous Essent;al Civil Unauthorized Modifications97-265

Nonseismic Bracing for 5 Hydraulic Control Units97-256

Nonessential Unauthorized Mechanical Modifications97-253

Various Self-Contained Breathing Apparatus installations in the Plant

97-217

Chain Welded to Valve RF-V-29

97-210

Temperature Indicators Mounted in the 125/250 VDC Battery Rooms

i

97-173

Rework of Hoist to the Main Lubricating Oil piping above the Reservoir

97-094

Evaluation of Locked High Radiation Area Gates97-093

Unauthorized Concrete Anchor Installations

i

97-071

Toxic Gas Filtration Temperature Switch TGF-TS-26HFT Replacement

i

_

_

-.- . . . -

- - . - . - - -

- _

_ - . - - - -

_ . - -

. . . . - .

.

. . _

o

i

b9

-8-

1

Table S-7.1

Enaineerina Evaluations

i

i

i

Generic engineering evaluations associated with Sarnple 7 MWRs

i

Sample Size: 15

)

Engineering

Title / Description:

'

Evaluation:

>

i

98-136

Evaluation of Miscellaneous Essential Electrical and l&C Unauthorized

Modifications98-132

Evaluation of Miscellaneous Essential Mechanical Unauthorized

Modifications98-098

Packing Replacements98-032

Adding Load to Motor Control Centers MCC-LX & MCC-TX

98-010

Qualify Existing 1/4" Tubing Between Valves DW-V-147 and HPCI-V-284.98-009

Evaluation of Miscellaneous Essential Civil Unauthorized Modifications

l

97-265

Nonseismic Bracing for 5 Hydraulic Control Units

j

97-256

Nonessential Unauthorized Mechanical Modifications97-253

Various Self-Contained Breathing Apparatus installations in the Plant

97-217

Chain Welded to Valve RF-V-29

97-210

Temperature Indicators Mounted in the 125/250 VDC Battery Rooms97-173

Rework of Hoist to the Main Lubricating Oil piping above the Reservoir

97-094

Evaluation of Locked High Radiation Area Gates97-093

Unauthorized Concrete Anchor installations97-071

Toxic Gas Filtration Temperature Switch TGF-TS-26HFT Replacement

. _ _

_ __._._ _

._

. . _ . _ . _ . - .

. . . . - _ _ . _ . _ . - _

___ ._ . _ _

_ _ . _ . - .

-

!

.g.

Table S-8

Unauthorized Modifications

.

!

Samole 8:

>

Population: 599 Items with item-specific resolutions

Sample Size: 57

i

!

73-12-137

76-9-248

85-1753

E97-0101

,

74-11-138

77-11-68

85-2363

E97-0119

i

74-3 198

77-3-42

86-4123

E97-0178

74-3-391

77-8-253

88-0192

E97-0214

74-5-185

77-9-269

89-1595

E97-0216

74-7-301

78-3-160

90-1226

E97-0263

)

I

i

74-8-176.

78-4-149

92-0285

E97-0360

75-11-218

78-7-88

92-1759

E97-0381

75-3-127

78-9-76

93-0512

N79-5-156

75-4-228

79-7-2

94-0107

N79-5-75

l

75-8-230

80-0598

95-1305

N80-9-23

l

75-8-231

80-8-18

CR96-0020

TR80-0499

76-12-154

81-1557

E97-0026

76-5-300

83-1735

E97-0054

!

76-8-178

83-2370

E97-0068

L

$

$

'

.

. . . . _ - . _ .

. - - - . ,

,

,

,

-

_

,,

--

.. .

-

-

. .

- - . . _

_

. . _ -

- - -

. - - _ . - . . -

- - .- . -

_ -

..-

p

a

0

-10-

Table S-9

Maintenance Work Reauests

Samole 9:

Population: 4,071 Corrective ma'ntenance MWRs worked following corrective actions

Sample Size: 60

96-1030

96-2062

97-0622

97-2840

96-1105

96-2129

97-0731

97-2913

96-1433

96-2197

97-0872

97-3011

97-0157

96-2264

97-0939

98-0134

96-1300

96-2331

97-0972

98-0448

l

96-1384

96-2400

97-1175

98-0677

96-1426

96-2465

97-1132

98-0636

96-1635

97-0341

97-0824

98-0998

!

96-1574

97-0136

97-2015

98-1344

96-1626

97-0294

97-1433

98-1535

i

>

'

96-1921

97-0301

97-1509

98-1792

96-1715

97-0388

97-2251

98-1990

96-1832

97-1111

97-3057

98-2382

'

96-1977

97-0522

97-2638

98-2868

96-1969

97-1256

97-2739

98-3171

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.

. . _ _ .

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.....m.

. - . . _ .

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ATTACHMENT 3

DOCUMENTS REVIEWED

SPECIAL TEST PROCEDURES

l

'

NUMBER

DESCRIPTION

REVISION

l

73-2

" Diesel Generator Reliability Testing Program,"

December 1,1973

L

75-8

" Test Procedure for Lifting Adapter Assembly,"

March 16,1982

76-1

" Drywall to Torus Leak Rate,"

February 27,1976

,

76-14

" Testing for Stuck Reed Relays in ARM Averaging cards September 16,1976

i

,

'

in the Neutron Monitoring System,"

77-17

"Taking Transformer Loss Compensator Out of Service," February 11,1982

77-28

• Recirculation Pump Start Without Bypass Valves,"

Date unknown

77-4

"HPCI Run Test,"

January 28,1977

78-1

"RHR-MO-25 Valve Operability,"

January 20,1978

QUALITY ASSURANCE AUDITS AND SURVEILLANCES

DATE

AUDIT / SURVEILLANCE

GENERAL FINDINGS / COMMENTS

.

4/30/96

96-07a, Unauthorized

Special audit of unauthorized modifications, resulting

Modifications

in 3 significant findings at the beginning of

unauthorized modification review program

7/17/96

97-07, Design Control

Part of audit was to resolve design controlissues and

Updated Safety Analysis Report inaccuracies.

9/4/97

S301-9701,

Surveillance to assess the status of the unauthorized

Unauthorized

modification project. Identified several MWRs that

Modifications

were not properly screened.

10/15/97

E301-9701

Emergent Surveillance on Unauthorized

Modifications, to assess problems identified in

Surveillance S301-9701.

10/22/97

97-15," Design Control"

Encouragement to complete screening on remaining

.

MWRs.

9/10/98

98-14, " Engineering /

Status of unauthorized modification project. Note

Special Programs

that an audit will be done later to evaluate

effectiveness.

I

,.

. - . - . .

__

- ... -..

_ - . -.~ -- - -_._--- . -

. . . . _ - - .

. . . . .

- . . - .

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2

)

MAINTENANCE PROCEDURES REVIEWED

l

PROCEDURE NUMBER

PROCEDURE TITLE

REVISION

.

i

1

'

1

Procedure 0.40

Work Control Program

Revision 15

,

i

!

Procedure 7.0.4

Conduct of Maintenance

Revision 12

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!

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!

!

!.

- - ,

.

, _ .

. _ - -

, - _

_ _

_ . .

~

,

.-

_. __-._.._____.._ _ _ _ _

__-..._

. _ . . . _ . _ . _ . _._-

ATTACllMENT 4

Unauthorized Modification Review Program

Accounting of Maintenance Work Requests (MWRs):

MWRs from 1973 - 1980

22,834'

1

MWRs from 1980 - 1996

72,902

i

Total Population:

95,736

]

l

Screened via Keyword Search: (51,994)*

Exclude MDC, DC

Total Documents Reviewed:

43,742

Pre 1980 = 22,834

Post 1980 = 20,908

Initial Screening (1st) Criteria: (40,786)

i

NPPD:

(14,750)*

Enercon:

(~5,712)*

Pre-1980

(20,324)

!

,

Problem Identification Reports Added:

318

!

l

Potential Unauthorized Modifications:

3,274

Enercon:

2,828

NPPD:

128

i

PIR (Non-MWR)

318

j

l

Non-safety significant (2nd) Criteria:

(1,023)*

Unauthorized Modification Population:

2 2_51

White Paper Resolved:

1,107'

(Sample included verification of backlog)

Engineering Evaluation Resolved:

545'

Other Resolution:

599*

!

Total MWR Population 6/12/96 - Present:

4,071*

(Corrective Maintenance Completed)

• Samples selected from these populations as documented in Attachment 2 to this inspection

report.

l

1

4