IR 05000254/1999008

Insp Repts 50-254/99-08 & 50-265/99-08 on 990419-23.No Violations Noted.Major Areas Inspected:Adequacy of Licensee Programs,Procedures,Training & Supporting Documentation

ML20206N990
Person / Time
Site:	Quad Cities
Issue date:	05/11/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206N966	List: IR 05000254/1999008 ML20206N962
References
50-254-99-08, 50-254-99-8, 50-265-99-08, 50-265-99-8, NUDOCS 9905180116
Download: ML20206N990 (12)

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i U.S. NUCLEAR REGULATORY COMMISSION l REGIONlli l l

l Docket Nos: 50-254;50-265 License Nos: DPR-29; DPR-30 Report No: 50-254/99008(DRS); 50-265/99008(DRS)

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Licensee: Commonwealth Edison Company (Comed)

Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: 22710 206* Avenue North l Cordova, IL 61242 Dates: April 19 - 23,1999

Inspectors: David Butler, Lead Inspector, Rlli Hukam Garg, NRR, HICB Alvin Bryant, NRR, HICB Approved by: Ronald N. Gardner, Chief, Electrical Engineering Branch

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Division of Reactor Safety 9905180116 990511 PDR ADOCK 05000254 G pop

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EXECUTIVE SUMMARY Quad Cities Nuclear Power Station, Units 1 and 2 NRC Inspection Report 50-254/99008(DRS); 50 265/99008(DRS)

The inspection assessed the adequacy of licensee programs, procedures, training, and supporting documentation to ensure Technical Specification required surveillance testing of safety related logic circuits was performed in an acceptable manne Enaineerina

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The inspectors concluded that the licensee's logic testing program and supporting documentation met the intent of GL 96-01 (All Sections).

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The inspectors concluded that the licensee's design control process was controlling changes to systems containing logic circuits in an acceptable manner and was ensuring i that required logic testing was performed (Section E2.1).

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The inspectors concluded that the licensee was controlling changes to documents affecting logic circuits in an acceptable manner to ensure that required logic testing was performed (Section E3.1).

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The inspectors concluded that the Technical Specifications related logic circuit functions reviewed during the inspection were tested in an acceptable manner (Section E3.2).

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Beport Details l The inspectors used NRC Temporary Instruction (TI) 2515/139, " Inspection of Licensee's Implementation of Generic Letter (GL) 96-01, Testing of Safety Related Logic Circuits," to assess the adequacy of licensee programs, procedures, training, and supporting documentation to ensure Technical Specification (TS) required surveillance testing of safety-related logic circuits was performed in an acceptable manne l Ill. Enaineerina E1 Conduct of Engineering E Generic Letter 96-01 Proaram Review Insoection Scope The inspectors reviewed the licensee's program guidelines for implementing actions requested in GL 96-01. The following documents were reviewed:

Guideline No. 6200-008-121, Revision 0," Identification of Safety Related System Functions" Guideline No. 6200-008-122, Revision 0, " Identification and Classification of Contacts" Guideline No. 6200-008-123, Revi.sion 0, " Surveillance Testing Adequacy" Guideline No. 6200-008-124, Revision 0, " Project Deliverables *

Guideline No. 6200-008-100, Revision 0," Project Quality Assurance Plan for Safety Related Contact Testing Adequacy Reviews" l Nuclear Oversight Assessment, NOA-04-99-028, dated April 16,1999 Corrective Action Program Process Manual of Common Work Practice Instructions No. CWPI-NSP-AP-1-10, Revision 0, " Operating Experience (OPEX)"

NSWP-A-15, Revision 1," Comed Nuclear Division Integrated Reporting Program" NSP-AP-4004, Revision 0," Corrective Action Program Procedure" Quad Cities Operational Surveillance (QCOS) No. 1400-11, Revision 2, "Sesquiannual l Core Spray Logic Functional Test" QCOS 6500-09, Revision 1, "Sesquiannual Functional Test of Unit 1 Second Level Undervoltage" NRC Information Notice (IN) 88-83, " Inadequate testing o' Relay Contacts in Safety-Related Logic Circuits" IN 91-13," inadequate Testing of Emergency Diesel Generators (EDG)"

IN 92-40," inadequate Testing of Emergency Bus Undervoltage Logic Circuitry" IN 93-15," Failure to Verify the Continuity of Shunt Trip Attachment Contacts in Manual Safety injection and Reactor Trip Switches" IN 93-38," inadequate Testing of Engineered Safety Features Actuation Systems" IN 95-15, " inadequate Logic Testing of Safety-Related Contacts" PlF Q1997-00081 - Review Main Yankee Confirmatory Action Letter Concerning Generic Letter 96-01

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b. Observations and Findinos  !

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The inspectors determined that the GL 96-01 implementation guidlines established an l

acceptable foundation for (1) evaluating safety-related logic circuits, (2) comparing schematic drawings against surveillance procedures to ensure technical specification i requirements were met, and (3) for ensuring appropriate surveillance procedure revisions were identifie In accordance with guideline No. 6200-008-121, contact functions were divided into the following categories: (1) Category I contacts associated with TS required functions; (2) Category 11 contacts associated with Updated Final Safety Analysis Report identified design functions; and (3) Category ill contacts associated with additional logic functions identified on schematic diagrams. Based on the inspectors' review, the following observations were made:

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The inspectors determined that the licensee's GL 96-01 program did not include a clear position as to what level of EOG subsystem component, such as time delay relays, should be included v rJM the GL scope of review. The inspectors were concerned that contacts, sue. os start permissives, which could affect EDG operation were not teste In response, the licensee provided information that demonstrated other EDG subsystem components had been tested. The review encompassed EDG electrical schematic diagrams that included EDG start permissives and interlocks. The inspectors determined that an appropriated level of review had been performed by the license The inspectors noted that the licensee had not completed the Category ll and lli contact reviews. During the inspection,1145 out of 2149 Category 11 contacts and 106 out of 272 Category ill contacts had been verified to meet their appropriate testing requirements. The inspectors were concerned that Category 11 and lll contacts may be required to support Category I functions, such as a Category ll contact in series with a Category I contac I In response, the licensee agreed to prioritize those Category 11 and ill contacts whose failure could affect Category I functions. This review item was added to the Action Tracking system with a completion date of December 20,1999. This was acceptable to the inspector * The inspectors noted that many Category I contacts had been categorized as not adequately tested on the GL 96-01 System Contact Summary sheets without Problem Identification Forms (PlFs) being issue ]

In response, the licensee researched the GL database and determined that usually these contacts were tested in their actuation position, but not verified to i return to their normal position. The licensee concluded that this i

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met the intent of the TSs and did not require a PlF. To improve testing, the licensee was enhancing test procedures to demonstrate that a contact returned to the normal position. This was acceptable to the inspector During this review, the inspectors noted one instance where a PlF had not been generated for a missed contact verification. Although a PIF had not been initiated, the GL program did, ensure that appropriate corrective actions had been taken. Loss of offsite power auxiliary relay No. 127-813-1X1 seal-in contact 11/12 was not verified to seal-in and reset during testing. The licensee had revised surveillance procedure No. OCOS 6500-09 to verify contact seal-in and reset. Past testing did verify that the relay functioned properly. This was demonstrated by successful EDG load shedding and sequence testing. The licensee initiated PlF Q1999-01497 to determine if other contacts should have had a PIF initiated for missed contact testing verification. The licensee informed the inspectors that this occurred during the initial GL review process performed in 1996. Since then, the licensee indicated that the threshold for issuing PIFs was lowered and that the current PIF program would have identified that a PlF was I required. During the GL validation review, Quad Cities engineering personnel l identified nine (9) additional contacts missed during the initial review. This information was provided to the NRC in a letter (SVP-98-039) dated February 12,

-1998. The nine (9) contacts were satisfactorily tested. The inspectors reviewed ]

additional System Contact Summary sheets and confirmed that recently identified testing deficiencies resulted in a PlF being initiated. This adequately addressed

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the inspectors' observation.

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The inspectors determined that support systems, such as EDG cooling water, i were not explicitly identified to be within the scope of the GL 96-01 review. The l only support system identified in the scope was the control room heating and '

cooling syste In response, the licensee provided additional information which showed support systems required for safety system operations were reviewed in accordance with GL 96-01. Since the EDG was supported by many systems, these support systems were typically numbered the same as their associated system, such as service water. The EDG support systems were reviewed along with other system reviews. The inspectors confirmed that EDG support systems had been appropriately reviewed in accordance with the G During the implementation of the GL-96-01 reviews, the licensee identified 1169 Category I testing issues that resulted in 56 Action Tracking items,29 PIFs, and the revision of 42 procedures. Subsequent testing did not identify any logic contact failures. The inspectors observed logic testing during the inspection. The test was performed in an acceptable manne l i

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_ Conclusions The inspectors concluded that the licensee's GL 96-01 guidelines were appropriate for reviewing the issues identified in the generic letter, and that the GL 96-01 program was appropriately identifying and resolving issue Engineering Support of Facilities and Equipment E2.1 Desian Chanae Process Insoection Scope l The inspectors reviewed the modification process to ensure that modifications to logic systems would be properly controlled. The following documents were reviewed:

NEP-04-00, Revision 4 "Roadmap to Configuration Changes" NEP-04-01, Revision 6, " Plant Modifications"

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NEP-04-05, Revision 0," Design Change Acceptance Testing Criteria" . Observations and Findinas l Procedure No. NEP-04-01 provided post modification testing (PMT) controls. The !

procedure required the cognizant or system engineer to ensure that the PMT did not l affect any associated logic systems. In addition, procedure No. NEP-04-05 provided amplifying information for developing testing requirements and acceptance criteri Electrical circuit logic tests were described as a testing attribute that should be considered during PM c. Conclusions The inspectors concluded that the licensee's design contrcl process was controlling l changes to systems containing logic circuits in an acceptable manner and was ensuring [

that required logic testing was performe ;

i E3 Engineering Procedures and Documentation j l

E3.1 Documents Affectina Loaic Circuits l l Insoection Scooe The inspectors reviewed the methods used by the licensee to ensure changes to documents affecting logic circuits would be appropriately evaluated,if revised. The i following document was reviewed:

QCAP 1100-04, Revision 26," Procedure Revision, Review and Approval" j I

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l 6 Observations and Findinas The licensee incorporated a procedure review matrix into QCAP 1100-04. The matrix was an electronic database maintained by the Office Support group that was responsible for the procedure review and approval process. Procedures, such as logic tests, were identified on this matrix. If a logic test was revised, the matrix would identify that the procedure required an independent technical review. This typically invclved a cross-discipline review of potential impacts on personal safety, plant operation, design, and system interaction. Twenty-seven (27) HPCI and EDG test procedures were provided to the inspectors for review during this inspection. The inspectors verified that each of these procedures was included on the matrix. In addition, the licensee completed an electrical schematic diagram review to identify all drawings that contained logic contact These diagrams were referenced in the Electronic Work Control System (EWCS) to identify to maintenance planners the drawings that contained logic circuits. This will help the planners in preparing post maintenance test instructions to ensure logic contacts will be appropriately teste Conclusions The inspectors concluded that the licensee was controlling documents affecting logic circuits in an acceptable manner.

E3.2 Safetv-Related Loaic Circuit Reviews Insoection Scooe l The inspectors reviewed several logic group diagrams and electrical schematics against j applicable test procedures, Technical Specifications, and other documents related to logic circuits. The reviews verified the testing of parallel logics, interlocks, permissives, bypasses and inhibit circuits required by Technical Specifications for EDG starting, EDG sequencing, High Pressure Coolant Injoction (HPCI) actuation and isolation circuits. The following documents were reviewed:

QCOS 2300-29, Revision 1,"HPCI System Logic Functional Test" QCOS 2300-06, Revision 14," Quarterly HPCI System Power Operated Valve Test" QCOS 2300-11, Revision 12. "CCST (Contaminated Condensate Storage Tank]/ TORUS Level Switch Monthly Functional Test" QC Instrument Surveillance (OCIS) 2300-02, Revision 5, "HPCI Reactor low Pressure Analog Trip System Calibration and Functional Test" QCIS 0200-06, Revision 15, " Low-Low Reactor Water Level Calibration and Functional Test" QCOS 6600-38, Revision 2," Unit One Emergency Core Cooling System Simulated Automatic Actuation and Diesel Generators Auto-Start Surveillance" QOS 6500-01, Revision 31,"4 KV Bus 13-1 Undervoltage Functional Test" QCIPM 6600-03, Revision 0," Unit % Diesel Generator Trip and Alarm Switches Calibration, Protective - Trip Bypass and Functional Test" Schematic Diagram Nos. 4E-1527 - High Pressure Coolant Injection System Sensors &

Auxiliary Relays: Sheet 1, Revision N; Sheet 2, Revision G; and Sheet 3, Revision L Schematic Diagram Nos. 4E-1528 - High Pressure Coolant injection System Valves &

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L Turbine Auxiliaries: Sheet 1. Revision AN; and Sheet 2, Revision AH Schematic Diagram Nos. 4E-1430, Core Spray System I & ll: Sheet 1, Revision AY; and

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Schematic Diagram Nos. 4E-1345,4160 Bus 13-1 Standby Diesel % Feed Breaker:

Sheet 1, Revision BH; Sheet 2, Revision BA; and Sheet 3, Revision BB Schematic Diagram Nos. 4E-1351 A, Engine Control & Generator Excitation Standby Diesel Generator %: Sheet 1, Revision AL; and Sheet 2, Revision AG Schematic Diagram Nos. 4E-13518, Diesel Generator % Auxiliaries & Start Relays:

l Sheet 1, Revision R; and Sheet 2, Revision T Observations and findinas l

The following HPCI contacts and surveillance procedures were reviewed to confirm that TS required testing was properly performed:

Device ID Contact N Procedure ID SMg 1-2330-100B 11/12 QCOS 2300-29 H.1 QCOS 2300-06 H.12 1-2330-110 5/6 QCOS 2300-29 H39. QCOS 2300-06 H.2.h.4.a; H.3.p. /6 QCOS 2300-29 H.3 QCOS 2300-06 H.2.h.4.a; H.3.q. D M1/T1 QCOS 2300-29 H.123.a; H.125.b

1-2330-144 1/7 QCIS 0200-06 H.41; H39 l 1-2330-150 1/2 QCOS 2300-29 H.8 l H.6.a; H. '

, QCOS 2300-11 1-2330-151 1/2 QCOS 2300-29 H.8 l QCOS 2300-11 H.6 a; H. '

1-2391-10A - M2/T2 QCIS 2300-02 H.10.f.2; H.10. '

1-2391-10B M1/T1 QCIS 2300-02 H.10.f.2, H.10. '

.1-2391-10C M2fr2 QCIS 2300-02 H.10.f.2; H.10.c.2 l 1-2391-10D M1/T1 QCIS 2300-02 H.10.f.2; H.10. LS-2301-35 2/2c QCOS 2300-29 H.83.d; H.36 a

1-LS-2301-36 2/2c QCOS 2300-29 H.83.d; H.39.a.1 i

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l The inspectors verified that individual contacts were properly tested in their open and l closed direction and that the database correctly reflected the corresponding procedure step. During the review, two instances were identified where the database reference did not reflect the correct procedure step. Device 1-2330-144, contact 1/7, was verified l closed in procedure step H.49 rather than in the database identified step H.41, and device 1-2330-151, contact 1/2, was verified open in step H.8.a rather than in step H. These contacts were properly tested in their associated surveillance test. The licensee indicated that these omissions were isolated cases and occurred during data entr Other database omissions will be corrected during the GL re-review process. The licensee planned to maintain the database up to date since it was a valuable tool when revising logic tests and would benefit work planners preparing maintenance work instructions.

l Conclusion The inspectors concluded that the Technical Specifications related logic circuit functions reviewed during the inspection were tested in an acceptable manne E5 Engineering Staff Knowledge and Qualification E5.1 Enaineerina Staff Knowledae l Inspection Scoce  !

l The inspectors evaluated training provided to engineering personnel regarding testing activities. The following documents were reviewed: i Attachment M - Engineering Support General Training Guide NTA2 - Instrument Setpoint/ Scaling Certification Guide NTA3 - Configuration Management Certification Guide NTA4 - Modifications Certification Guide l

NTE6 - Schematic, Wiring Drawings

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Continuing Training Lesson Plan - Post Modification Testing Nuclear Engineering and Technology Services No. TID-DS-04, Revision 1, " Post Modification Acceptance Testing" Observations and Findinas The engineering staff initial training program required the staff to complete a modification !

checklist for testing and to schedule and coordinate a modification test. The checklist l required trainees to verify that the test adequately demonstrated program compliance for l components being modified. Also, the training stressed that testing must overlap into i l unmodified portions of the circuit being changed. The inspectors reviewed the training certifications for several individuals involved with the GL 96-01 program and determined i that the individuals were qualifie j

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l Conclusions l l

l The inspectors concluded that engineering personnel involved with the GL 96-01 l program were qualified to perform the review E7 Quality Assurance in Engineering Activities l

E Nuclear Oversiaht Review Insoection Scooe The inspectors reviewed Nuclear Oversight Assessment No. NOA-04-99-028, j l " Implementation of Generic Letter 96-01," dated April 16,1999.

I Observations and Findinas l

The original safety-related contact testing adequacy (SRCTA) review program was l initiated in 1994. This review was performed in accordance with an approved quality assurance program. The SRCTA information was reviewed (1997) by the licensee to l ensure the results met the intent of the GL. Subsequently, the licensee has initiated an l engineering personnel re-review effort (January 1999) to validate the information contained in the GL database. The database was being updated to reflect the current test procedure revision and to ensure that the database reflected the correct procedure

! contact testing step. The April 16,1999, Nuclear Oversight Assessment identified that design changes implemented since the GL review was completed in July 1997 had not been reviewed to ensure the modifications did not affect safety-related logic circuit testing. In response, the licensee added recent modifications to the engineering staff re- i

! review scope (Action Request No. 6272-05) to ensure that these later modifications l would not affect past logic system reviews. This was acceptable to the inspector Conclusions The inspectors concluded that satisfactory quality assurance organization oversight had been applied to the GL 96-01 projec l

! V. Manaaement Meetina l

l' X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management on April 22,1999. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie l-

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PARTIAL LIST OF PERSONS CONTACTED l Licensee G. Bames, Acting Station Manager l W. Beck, Regu!atory Assurance Manager l l R. Chrzanowski, Nuclear Oversite S. Darin, Engineering l

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T. Fuhs, Regulatory Assurance M. McDowell, Operations Manager D. Peters, Nuclear Oversite J. Purkis, System Engineering Manager J. Randich, Acting Work Control Manager C. Schumacher, Engineering l J. Weaver, Training Department D. Wozniak, Engineering Manager INSPECTION PROCEDURES USED l

Temporary Instruction 2515/139: " Inspection of Licensee's implementation of Generic Letter 96-01, Testing of Safety Related Logic Circuits" LIST OF ITEMS OPENED AND CLOSED Opened None l Closed None Discussed None i

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l LIST OF ACRONYMS USED IN POINT BEACH REPORTS CCST Contaminated Condensate Storage Tank CFR Code of Federal Regulations EDG Emergency Diesel Generator EWCS Electronic Work Control System GL Generic Letter EDG Emergency Diesel Generator HPCI High Pressure Coolant Injection IDNS lilinois Department of Nuclear Safety i IFl Inspection Follow-up Item LER Licensee Event Report NOA Nuclear Oversight Assessment PDR Public Document Room PlF Problem Identification Form PMT Pos.t Modification Test QCIS Quad Cities Instrument Surveillance Procedure QCOS Quad Cities Operating Surveillance Procedure SRCTA Safety Related Contact Testing Adequacey TI Temporary Instruction l TS Technical Specification URI Unresolved item l VIO Violation I WR Work Request l

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