IR 05000259/1984050
| ML18029A412 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/14/1985 |
| From: | Marlone Davis, Foster L, Hill W, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18029A411 | List: |
| References | |
| 50-259-84-50, 50-260-84-50, 50-296-84-50, GL-83-28, NUDOCS 8503070349 | |
| Download: ML18029A412 (20) | |
Text
%hhhioul (4 Tp UNITEo STATES NUCI.EAR REGULATORY COMMISSlON 1IEOION II 101 MAIIIETTASTAEET, N.W.
ATLANTA,GEORGIA30303 Report Nos.:
50"259j84-50, 50-260!84-50, and 50"296/84-50 Licensee:
Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Docket Nos.:
50-259, 50-260 and 50-296 License Nos.:
OPR-33, OPR-52, and OPR-68 Facility Name:
Browns Ferry 1, 2, and
Inspect, <on Conducted:
December 10-14, 1984 Inspectors:.
L. E. Foster, Team Leader
'7~
7" N.
erriweather Accompanying Personnel:
W.
M. Hill Consultant:
P.
N. Chan, Lawrence Livermore National Laboratory Approved by:
I't. xi'i 44~
W. N. Hill, Technical Assistant Division of Reactor Safety i/rg/5'~
Date Signed
~/i P/8'5 Date Signed ate Signed Date Signed SUHNARY Scope:
This special, announced inspection involved 160 inspector-hours on site concern1ng licensee response to Generic Letter 83-28, Required Actions Based on Gener1c Implications of Salem ATWS Events.
Areas insoected included:
post trip review; equipment classification; vendor interface and manual control; post maintenance test.ing and modifications; and reactor trip system reliability.
.Results:
Of the five areas inspected, no violations or deviations were 1dentif1ed.
8503070349 8501 16 PDR ADOCK 05000259
REPORT DETAILS 1.
Persons Contacted Licensee Employees Contacted
- J. A. Coffey, Site Director
"G. T. Jones, Plant Manager
'W. R..Swindell, Plant Superintendent, Operations an
- J. 8. Walker, Compliance R.
E. Burns, Instrument Maintenance Super visor
'T. D. Cosby, Electrical Maintenance Supervisor S. Bailey, Information System Analyst D. Thompson, Engineering Unit Supervisor, Electrica B. Irby, Instrument Engineering Supervisor D.
R. Bucci, Post Modification Tests Supervisor J. Carlson, Quality Assurance Manager
'W. J. Pattison, Jr.,
Supe"visor Drawing Control K. Montgomery, Instrumen'.
Cngineer
"H. HcGuire, Quality Analy'-
H. King, Post Hodificaticn Tests Engineer J.
W. Burton, III, Post Viodification Tests Engineer C. Elledge, Acting Supervisor, QA Surveillance
'D. C. Mims, Engineering Group Supervisor J.
Boyd, Electrical Maintenance Planner R. McLemore, Electrical Haintenance General Foreman B. York., Electrical Maintenance General Foreman J.. D. Wolcott, Reactor Engineer R. Steele, Electrical Engineer L.
W. Jones, QA'Supervisor S.
Logan, Safety Engineering
,
H. Page, Quality Assurance R. HcPherson, Engineering Test-Unit Supervisor W. Williamson, Shift Technical Advisor B. Porter, Mechanical Engineer R. Perry, Senior QA Engineer d Engineering 1 Maintenance Other licensee employees contacted included engineers, inspectors, technicians, operators, mechanics, electricians, security force members, and office personnel.
NRC Resident Inspectors
'G. Paulk, Senior Resident Inspector
- C. Patterson, Resident Inspector
'Attended exit interview
2.
Exit Interview The inspection scope and findings were summarized on December 14, 1984, with those persons indicated in paragraph 1 above.
The licensee was informed of the inspection findings listed below.
The licensee acknowledged the inspection findings with no dissenting comments.
Inspector Followup Item 296/84"50"01, Auditing Alarm Points Inspector Followup Item 259/260/296/84-50-02, Review Program for Revising Manuals and Instruction Inspector Followup Item 250/260/296/84-50-03, Update and Control of All Vendors Equipment Manuals 3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved items were not identified during this'nspection.
5.
Background In February 1983, the Salem Nuclear Power Station experienced two failures of the-reactor trip system upon the receipt of trip signals.
These failures were attributed to Westinghouse
" Type DB-50 reactor trip system (RTS)
circuit breakers.
The failures at Salem on February
and 25, 1983, were believed to have been caused by a binding action within the undervoltage trip attachment (UVTA) located inside the breaker cubicle.
Due to problems of the circuit breakers at Salem and at other plants, NRC issued Generic Letter 83-28, Required Action Based on Generic Implications of Salem ATWS Events, dated July 8, 1983.
This letter required the licensees to respond on immediate-term actions to ensure reliability of the RTS.
Actions to be performed included development of programs to provide for post trip review, classification of equipment-,
vendor interface, Post maintenance testing, and RTS reliability improvements.
The licensee responded to Generic Letter 83-28 by correspondence with the following dates:
September 6, October 31, and November 9, 1983; and, February 21, March 15, and September 17, 1984.
This inspection was performed to review the licensee's current program, planned program improvements, and implementation of present procedures associated with post trip review, equipment classification, vendor inter-face, post maintenance testing, and reactor trip system reliability.
,6.
Documents Reviewed The following is a partial list of Browns Ferry Nuclear Plant (BFNP)
documents that were reviewed and used by the inspectors for performance of this inspection.
Other particular documents reviewed are discussed in the report detail sections:
TVA Response to IE Inspection Report Ho. 84-23 for BFHP dated November 13, 1984 Procedure No. 1707.03.04 (Draft), Vendor Manual Program ID"QAP 6.2, Vendor Manual Control. Revision
Standard Practice Ho.
BF 2. 16, Vendor Manual Control Program, dated August 14, 1984 BF-EMI-15, Time Delay Relay Set Point Check, dated March 4, 1974 BF-EMI-23, Replacement of Switches and Relay, dated October 26, 1983 BF-EM1-18, Limit and Torque Switch Adjustment for CSSC Motor Operated-Valves, dated April 7, 1983-Procedure Ho.
1104.01,"
Test Staff Program Manual-Preoperational Test Program, dated October 24, 1984 Procedure Ho.
N-OQAM, Part II, Section 5.4, Quality Assurance Surveys, dated October 12, 1984 Procedure Ho. IL-1, R5, Post-Modification Test Program, (Not issued for implementation)
BFNP, Unit 1 Technical Specifications, Section 3. 1/4.2 Section 7.2, FSAR, BFNP, Reactor Protection System Section 8.4, FSAR, BFHP, Normal Auxiliary Power Systems Standard Practice Ho.
BF 1. 11, CSSC and Hon-CSSC Listing, dated March 21, 1984 Standard Practice Ho.
BF 2.14, Revie~ of Plant Instructions, dated March 14, 1984 Standard Practice Ho.
BF 3. 11.
Second-Person Verification,
. dated September 25, 1984 Standard Practice'o.
BF 3.2, QC Inspection Program, dated October 23, 1984 Standard Practice Ho.
BF 3.9, Quality Assurance Compliance Determination, dated October 23, 1984 t
Standard Practice'o..BF 6. 1, Performance of Maintenance, dated June 15, 1983
Standard Practice Ho, BF 6.16, Relay and Switch Contact Cleaning, dated June 2, 1983 Standard Practice Ho.
BF 6.18, Failure Investigations of Safety-Related Items, dated July 13, 1983 Standard Practice No.
BF 6.5, Common-Mode Failure, dated August 31, 1983 Standard Practice No.
BF 7.6, Maintenance Request and Tracking, dated September ll, 1984 Standard Practice No.
BF 8.3, Plant Modifications, dated December 4,
1984 Standard Practice No.
BF 10.9, Handling of Test Deficiencies, dated August 10, 1983 Standard Practice Ho.
BF 13. 1, Format for Maintenance Instructions, dated. April 13, 1984 Maintenance Request Hos. 3-FCY-71-40 and 2-FLY-73-003 Standard Practice Ho.
BF 21.17,.Review, Reporting, and Feedback of Operating Experience Items, dated May 29, 1984 7.
Post Trip Review The licensee was requested in GL 83-28:
to describe their program, procedures, and data collection capability to assure that the causes for unscheduled reactor shutdowns, as well as the response of safety-related equipment, are fully understood prior to plant restart.
The licensee's response to GL 83-28 gives a description of the program and procedures pertinent to performing post trip reviews.
The inspector reviewed their response, appropriate procedur'es, and interviewed responsible licensee personnel to assess the adequacy of the licensee's program for post trip reviews.
This inspection "revealed the following:
The licensee has prepared and revised procedures to define responsibilities, authorities, methods of assessment, training, and equipment needed to perform a timely, technical, post trip review.
Standard Practice BF 12.8, Unit Trip and Reactor Transient Analysis, provides a
page Scram Report Form (Form BF-58).
The Scram Report Form
'rovides a
systematit'.
method for determining the causes of reactor trips, evaluating the proper functioning of safety-related equipment, and making the decision whether the plant.can be safely restarted.
Tech'nical Instruc-tion BF TI"74, Post Trip Review and Analysis, provides guidelines for the Shift Technical Advisor (STA) in the preparation of the Preliminary Scram Evaluation.
The Preliminary Scram Evaluation is required to be completed
within eight hours of the scram or transient by the STA and must be com-pleted before the unit is restarted.
In order to recommend unit restart, the cause of the reactor scram, including the initiating failure, must be identified and understood; and the response of safety related systems or equipment must be understood and acceptable.
B"ed on findings of the Preliminary Scram Evaluation, the Shift Engineer (SE)
and STA make recom-mendations to the Plant Superintendent regarding restart of the unit. If startup delay is recommended or if the STA and SE cannot agree on the advisab1lity of restart, the Plant Superintendent will convene appropriate members of the scram committee to investigate.
The committee findings are reported to the Plant-Operations Review Committee (PORC)
which makes a
recommendat'ion on unit restart to 'the Plant Superintendent.
Several problems with post. trip reviews have been documented in NRC Inspection Reports.
Reports 259/260/296/82-13, 82-24, 83-09, and 84-26 concerned errors or 1naccuracies in post trip review reports.
Reports 259/260/296/83-43, 83"46, and 83-58 concerned a civil penalty regarding a
violat1on for hav1ng an inoperable level switch on a Unit 2 west scram discharge instrument volume.
It was noted that this information was available from four previous scrams that indicated the level transmitter was inoperable.
The post trip reviews performed on these previous scrams failed to identify this problem with the level transmitters; however, the unit was restarted.
As a result of these problems, post trip review and analysis procedures were rewritten in Oecember 1983, to provide more detailed instructions for systematically evaluating reactor trips and plant parameters.
Improvements have been noted 1n the detail and accuracy of the post trip repo~ ts generated in 1984.
The reports are thorough and adequately document the events.
Plant personnel appear knowledgeable in post trip review procedures.
The licensee did not have any formal program to perform trend analyses on reactor trips, The licensee is considering INPO direction toward the establishment of a formal trend analysis program.
Post trip reports are considered quality assurance records with a lifetime retention period.
Section III of the BFNP Oocument Control Unit Information Hanagement Hanual (BF OCU IHH) allows storage of single source QA records in storage vaults or in f1re rated cabinets.
The licensee's post trip reports are filed in a one"hour fire rated cabinet in the Eng1neering Test Group Office.
BF OCU IHH Section III also requires a worst case fire-load analysis to be per formed when fire"rated file cabinets are used for QA record storage purposes.
The analysis is to verify that the fire rating of the cabinets is sufficient to provide adequate protection against a complete burnout of the area 'in which the records are located.
Annual fire surveys
~
to ensure that changes in fire loading have not invalidated the fire load analysis are also required.
A 'licensee QA audit in July 1984, QA'-2-QAS-84-306, identified the fact that annual fire load surveys had not been performed on the remote (satellite)
records storage file cabinets.
A fire load analysis of these record storage areas was subsequently conducted in October and
November 1984.
Based on these analyses, the ratings of file cabinets were satf sfactory.
The licensee utilizes the GE-PAC 4020 process computer system to monitor significant plant process parameters.
A single computer serves Units 1 and 2 and a second computer serves Unit 3.
The power source for these computers fs from the 120V AC plant preferred bus which fs a non-Class IE power sovrce.
The post log provided by the computer can be used to determine the values of certain analog points for several mfnutes prior to and following a plant trip.
The record alarm event recorder, as well as strip charts and logs, are used to monitor principle plant parameters.
The existing systems
.
appear to provide adequate information for the conduct of a comprehensive and thorovgh post-trip review.
Discussions
'-with personnel revealed that fn an effort to vpgrade equipment
'capability, the licensee is planning to replace the GE PAC'020 process compvters with Digital Equipment Corporation VAX ll/750 process computers.
This computer replacement project fs scheduled for completion in 1986.
replacement of the record alarm events recorder with the Drantz model 2211-MC and 2210B-MPT was completed during the last outages-on Units 1 and 3.
This system can monitor a maximum of 1024 points and can scan them fn
'one mflfsecond.
Alarmed points are printed out on a control 'room printer fn the'nglish language instead of numerical format.
Based on the revfew of documents, interviews with personnel,
'and observation of activities, the exfstfng and proposed new systems provide adequate information which fs being used to conduct comprehensive and thorough post-trip reviews.
Mfthfn the areas examined, no violations or deviations were identified.
The inspectors also performed a follow-up inspection and review of licensee activities concerning the Unit
scram that occurred on December 9,
1984.
This review was to verify that.
NRC requirements have been met, causes for the event had been fdentf'fied and understood; to ensure that no vnrevfewed safety questions were involved; and, activities were in compliance with Technical Specifications; The inspectors interviewed responsible licensee personnel, attended the PORC meeting, examined as-built electrical wiring diagrams, and reviewed sequence of events printouts.
A summary of events leading to the scrams and subsequent licensee action is discussed below:
The event occurred when Unit 3 was operating at 36 percent of rated
, power.
The
"A" condensate pump motor experienced a
phase to ground fault.
The cfrcuft breaker providing power to the condensate pump motor failed to trip (open),
thus not isolating the faulted motor.
The overcurrent relays protecting 4KV Unit Board 3A sensed an overcurrent condition and isolated the normal power svpply from the Unit Station Service Transformer (USST) to the board and locked out the alternate power supply.
This resulted fn loss of voltage on the safety-related 4KV shutdown boards '(3EA/3EB), the 480V shutdown boards, and associated
loads.
The loss of voltage caused the 4KV shutdown boards (3EA/3EB) to automatically transfer to the 4KV Bus Tie Board (this transfer is an automatic delayed transfer, and it took about 4 seconds to complete).
However, before the 4KV shutdown boards transferred to the alternate power supply, the 480V Motor Generator Set A of RPS channel A tripped due to under-frequency causing a half scram on the RPS logic.
The operator received several alarms and took action to scram the reactor.
It was noted that both diesels started and came up to speed but did not have to supply power because the 4KV Shutdown Boards had transferred to the 4KV Bus Tie Board.
The licensee had completed a preliminary revie~
of this. event and made the following determinations:
The "A" condensate pump motor had experienced a ground fault.
The trip coil in "A" Condensate Pump Motor circuit breaker tripping
'echanism had failed open causing 4KV Unit Board 3A to isolate on overcurrent.
The protective relays funct1oned as designed."
The diesels started, came up to speed, and were ready to load electrically as designed.
-During the review and evaluation of scram data, an error was noted on the Sequence of Events (SOE)
alarm dis'play printout.
An alarm for the'ast
~Discharge Volume High Water L'evel printed detector.'B'hen it should have
'printed detecto~
'C'.
'This appears to be a
software problem which has ex1sted for some time.
Based on the above, the inspectors quest1oned the accuracy of other items on the printout..
The licensee was requested to perform a
QA audit (sampling alarm po1nts) to verify that the alarm points narc indeed accurate.
The 1'icen'see agreed to perform such an audit.
This is identified as Inspector Followup Item ( IFI) (50-296/84-50-01),
Auditing Alarm Points.
The licensee is still investigating the failure of the "A" condensate pump motor and the circuit breaker trip coil failure.
It appears that all safety"related systems functioned as designed.
The inspectors concluded the licensee understood the cause of the event and their corrective act1ons appeared appropriate.
Within the areas examined, no violations or deviations were identified.
8.
Equipment Classification The licensee's response to GL 83-28, gives a detailed description of the criteria for identifying critical structures, systems and components (CSSC)
and the methods in which this information is maintained.
The inspector reviewed licensee response, appropriate procedures, 'nd interviewed responsible licensee personnel to assess the adequacy of the licensee's program and procedures.
The review was to ensure that components of safety-related systems are 1dentified as such on documents, procedures, and h
information handl ing systems ut 1 1 1 zed to control sa fe ty-re l a ted work activities.
The results of the inspection revealed the following:
The licensee has developed a Critical Structures, Systems, and Components (CSSC) List for Brown: Ferry I, 2, and 3.
This CSSC list is contained in the Corporate Operational Qual1ty Assurance Manual (OQAM)
as Appendix A,
CSSC and Non-CSSC Listing.
This CSSC list (OQAH, Appendix A)
was incorporated into Browns Ferry Site Procedure BF I.II, Appendix A, CSSC and Non-CSSC Listing.
The CSSC List identifies safety-related systems structures and components and was developed using the criteria outlined in their response to GL 83"28 dated September 6, 1983.. It also identifies boundaries between safety and non-safety mechanical pipi~g.systems.
In addition, the CSSC 1!st contains a listing of the safety-related reactor trip instrumentation.':.
licensee has also develnoed a
non-CSSC list which identifies those non: -itical structures and ei
. oment which are not con-sidered safety-related.
Both lists form a. T.~rt of Procedure BF l.ll, Appendix A.
The CSSC/Non-CSSC List is not considered a stand alone. document.
Additional methods.and procedures are used to help assure.that safety-related systems, equipment, and structures are designated as such on procurement documents, modifications, and maintenance work packages.
The licensee assigns a system number to each system in the plant.
This number 1s shown 1n other plant procedures and drawings 'which depicts the particular system.
So by utilizing. the system descriptions in the CSSC.List and.the unique number for the system (including components, instrumentation, and structures),
the licensee can determine 1f an item is safety-related.
This procedure appears to be acceptable.
One minor discrepancy was identif1ed with Plant Procedure BF I.ll, Appendix A, Attachment l, and OQAH, Appendix A.
The CSSC List does not incorporate the new Control Rod Drive (CRD)
Scram Discharge Level Instrumentation identified as East Level Switches LS-85-45 E,
F, G and H.,
The licensee was informed of this discrepancy and committed to 1mplement appropriate documentation changes to have Attachment I revised.
The discrepancy is considered minor since the Control Rod Drive and Hydraulic Control Systems are identified in the procedure as being CSSC.
In addition, the level instruments are ident1fied on drawings as being part of system
which is the CRD system which is identified as safety-related (CSSC)
in Procedure BF l.II and OQAH, Appendix A.
The licensee informed the inspector that they were work1ng on developing a
more comprehensive CSSC List or Q-List.
Plant personnel are working with design groups to develop specifications for the Q-List.
After completion of the specifications, a Q-List will be developed.
However, the licensee could not give the inspector the expected completion date for this project.
g.
Vendo~ Interface and Manual Control The licensees response to GL 83"?8 stated that TVAs (Browns Ferry)
vendor interface program hinges around the Nuclear Steam Supply System (NSSS)
supplier, General Electric Company (GE) who supplied all of the reactor trip
system components.
Information received from GE is forwarded to cognizant sections (groups)
per TYA procedures for review and utilization where applicable.
This information is tracked by the Operating Experience Review Group. to ensure incorporation of information into plant procedures and instructions.
TVA is actively participating in the NUTAC program and are presently developing procedures and instructions to conform to the recommendations of the.HUTAC Report.
The licensee's response also stated that.they participate 9n the IRPO SEE-IN Program and NPROS Program.
Service Information Letters (SILs)-
Westinghouse Technical Bulletins, and other major NSSS vendor information received is confirmed by returning a receipt to the vendor.
Licensee personnel stated that service contracts with other vendors will be reviewed to assure continuous notification of technical problems and recommendat/ons on equipment modifications or testing.
Browns Ferry has a
special vendor manual task force, on site.
They are presently reviewing the Browns Ferry program, revising procedures, naving manuals reviewed by cognizant sections, and putting manuals and instructions u'nder a controlled system.
General Electric suppl,ied manuals are being processed first and other.manuals will ~e incorporated into the overall program.
The inspector discussed the program with task force members, examined-.procedures, and observed some implementation which is discussed below.;-
Standard. Practice BF 2.16 is an interim instruction being used to establish the Brogans Ferry Vendor Manual Control Program.
This instruction also establishes how to identify, review, approve, and enter the initial manuals into the. controlled program.
Standard Practice BF 2. 16 specifies. the following:
A search is to be made of existing plant instructions to determine which vendor manuals are referenced in these instructions.
Initial search program shall include manuals identified by PORC meeting No.. 5113.
Location and holder of each manual to be identified.
Manuals obtained from each holder and file copy should be compared to ensure that they're consistent, have latest information, and any inconsistencies will be evaluated by the cognizant sections.
Each manual t. be controlled will be designated as Revision A and will have a yellow colored control sticker attached to the front cover.
cover sheet indicating, that the manual has been approved by the cognizant section and that the manual is in the controlled program will be attached to the front cove The manuals will be distributed by the Drawing Control Center.
The inspectors questioned how Browns Ferry was going to assure that modifications to equipment fn Unit I would be incorporated into Unit I manual and not made fn Unit 2 and Unit 3 manuals ff not applicable.
With three units, more strict control may be reqv1red to assure that manvals are initially identified for Units I, 2, or 3 and that changes to plant instructions and procedures reference the proper unit manual.
Licensee representative agreed to discuss the above with the Document Control Commfttee.
Instruction BF 2. 16 included a flow chart depicting the responsibilities and
- process pattern to be followed fn fdentffyfng, approving, reviewing against plant instruct1ons, and controlling of the manvals.
In order to further control the above, the Drawing Control Sect. <on issues a memorandum, Vendor Hanoal Control Program, to each supervisor requesting they review as required by BF 2. 16 to determine ff the manual has current information, whether the manual fs approved, and to.review referenced plant instructions
'against.
the manual.
This memorandum also has a return receipt which includes
"Approved for Use" and "Hot Approved for Use" blocks.
The cognf-zant.supervfsor checks the appropriate block, signs, and returns the receipt to'the Drawing Control Supervisor.
The purpose of this memorandum fs to ensuie that the manuals are revfewed for current information, to ensvre that
- technical information fn plant instructions matches the information fn the approved vendors manual, and that the instructions are valid for vse.
- To verify that the initial vendor manua>
control program was being imple-mented, the inspector reviewed procedures, examined vendo~ manuals, reviewed memorandum return receipts from cognizant supervisors, and reviewed the computer prfntouts used by the Information System Analyst to track manual review and approval.
Five vendor manuals were randomly selected from the computer printout for examination by the inspector.
These manuals had gone t.hrough the process of review and approval; therefore, were placed fn the controlled manual program.
Examination of manuals showed that the Yellow control sticker was affixed and the cover sheet specifying approval by cognizant section was attached per procedure.
Plant instructions referenced by the manuals and vice versa were compared (number matching}
by the inspector and found satisfactory; however, a detailed comparison of Instruction IHI-157 with
'.Hanual GEK-34538, Rod Worth Hinfmizer, revealed that an incorrect manual (GEK-34338)
was specified for the detailed funct.ional test and that manual GEK-26970C be used instead of the latest Revision GEK-269200.
Revision C
had been superceded by Revision D fn 1976.
Due to the above findings, the inspector questioned the validity of the
'approval memorandum concerning all manuals and instructions.
Upon
'discussions with cognizant supervisor, ft, was revealed that the subject.
manuals and instructions were not being reviewed and compared for technical adequacy but only to determine ff the manual should be controlled and ff the
correct manual number was referenced in the instructions (a number check only),- Further discussions revealed that the instruction on the Memoranda from Drawing Control to Cognizant Supervisors was not being interpreted as intended by the initiator; therefore, the approval block checked did not ensure that the referenced plant instructions and procedures were techni-cally compatible with each other or with the vendor manual.
The licensee representatives agreed to review and revise as needed proce-dures, 1nstructions, and memorandums to ensure that tney are understandable to. all parties involved, to require explanations if manuals are to be deleted or if instructions are to be revised.
Also, the manuals and instructions previously approved for use by memorandum receipt will be reviewed to ensure correctness.
Until the above 1s implemented, th1s is Inspector Followup Item ( IFI) 50-259/260/296/84-50-02, Review. Program 'vr Revising Manuals and Instructions.
Discussions with the HRC Resident Inspector revealed that a similar type problem associated with vendor manual control was 1dentified as a violation in IE Inspection Report 84-23.
Licensee response to the above violation is expected. by January 25, 1985 and will be followed by the Resident Inspector.
Other vendor manuals, plant iastructions, and design change requests covering vendor interface, manual revisions, and procedural revisions examined were:
GEK-39460 GEK-801E
... ; IN.Procedure 90.1 (associated with GEK"8riIE)
SF-SCI 201.3 SIMI-80, Maintenance and Calibration Procedure GEK-779 GEK-198453K30"711 SIMI-84 DCR 3016.
3017 and 3018 concerning SIMI-84 changes
'GEK-34538 and Instruction IMI-l57 VPF-32276 VPF"2635
'CR-1998 for changing out Control Room Recorders The above listed manuals, procedures, and instructions are in the licensees Controlled Manual Program.
As of this inspection,
vendor manuals have been reviewed and the Yellow Control Sticker attached, 80 manuals are in the review process and are expected tr
~e finished (approved)
by April 1985.
The 11censee stated that over 400 manuals w1ll be in the controlled program.
Site personnel are presently being trained by corporate personnel, who are presently on site setting up the program (3 on site),
to be vendor manual coordinators.
The inspector could not verify-by document review or by discussions with licensee personnel that provisions are being made to formally contact vendors (other than GE)
and obtain confirmation that the site manuals are current and applicable; or how the licensee is going to handle manual updates on equipment where the vendor 1s no longer in business or refuses to submit current technical information.
Until provisions are made to assure
12'ontinuous update and control of all vendor manuals, this is Inspector Followup Item ( IFI) 50-259/260/296~/S-50-03.
Update and Control of All Vendors Equipment Manuals.
The inspector reviewed document, ation concerning workplan No. 2049-84, Changeout of Control Room Recorders, Procurement.
and Replacement of GE Hultipoint Recorders with Leeds and Northrup (LN)
Speedomax 250 series multipoint recorders.
This replacemen.
was being done due to the inability of obtaining spare parts and services as the original GE recorders were no longer being manufactured.
Documents examined involved Workplan Specification
{ Form BF-63),
Workplan Control Form (BF-62),
ECN P0623.
DCR 1998, Permanent Instruction'hange Information (Form BF-S),
Instruction BF SCI 201.3 (Calibration of LN Hultipoint Recorder Model 257),
and Table 8.1.B of SIHI
( Inst'rument References'nd Set Points).
The above documents covered the classification of equipment, requirements for vendor technical manual.s, updat,e of dJ awings, and revisions to plant instructions and procedures as required bp'tandard Practice BF 8.3.
The inspector reviewed the Site QA Staff Honthly Report No.
119 for November 1984 to verify that the QA staff was performing reviews of workplans, procurement documents, modification packages, plant instructions and surveillance testing.
Special Survey Nos.
332, 359, 360, 366, 543, 394, and 395 performed'y the QA Survey Group were also examined.
These surveys covered maintenance work permits, mechanical
,maintenance,
.instrument
,maintenance, and measuring and test equipment.
Discussions revealed that starting on December 17, 1984.,
this survey group was going to perform a
special survey on BF Document Control Program.
Within the areas examined, no violations or deviations were identified.
10.
Post Haintenance Testing and Hodification The inspector reviewed the licensee's post maintenance testing procedures and activities to ensure the requirements of Generic Letter 83-28 were being met and that the licensee's response were being implemented.
The inspector examined procedures, completed maintenance records, and interviewed responsible licensee personnel to determine the adequacy of the licensee post maintenance program.
The results of the inspection are as fo)lows:
Standard Practice BF 7.6, Maintenance Request and Tracking, is the procedure used to describe the processing of maintenance requests (MRsj.
The procedure is applicable,to all plant personnel.
It requires maintenance requests to be documented on maintenance request forms (MRs).
The maintenance request form gives work instructions, post maintenance testing requirements, and equipment classification.
The procedure requires all MRs on CSSC equipment to be reviewed by QA.
The procedure also requires approval from operations prior to starting work.
After the work is completed and all
'esting is performed the MR form is reviewed for accept, ability by the appropriate maintenance section and/or operation Standard Practice BF 6. 1, Performance of Maintenanc~,
is the procedure that describes the methods by which maintenance will be
- performed.
It requires maintenance of safety-related equipment to be performed in accordance with an approved PORC procedure or standard reference
.mat,erial when the activi-ties fall outside the normal skills of the craft.
In those cases
~here ma1ntenance falls within the skills of the craft (such as troubleshooting electrical circuits, gasket or packing replacement, etc.) it will be so indicated on a
maintenance request.
The procedure also specifies requirements for personnel safety, housekeeping, post maint.enance testing, and final acceptance of completed maintenance work.
The inspectors reviewed six recently completed main:enance work records.
The records were found to be completed in accordance with Procedure BF 7.6, reviewed by QA, and properly reviewed and accepted by maintenance and operations..
The inspector reviewed the area of post modification'esting activities at Browns Ferry.
The inspector reviewed Design Change Request package for DCR 2201, Modification of the Scram Volume Discharge Instrument System.
The inspector noted that the package did not contain the Post Modification Transmittal Memorandum which transmits the post modification test results to design services.
The inspector questioned why the transmittal sheet was missing and was informed at the exit that the transmittal had been completed and that the confirmation would be mailed to him.
Subsequently, on January 27, the inspector received a
copy of the transmittal which was dated September 24, 1984.
The inspectors also reviewed DCR 2242, Modification of the Diesel Generators Speed Sensing Panels.
The inspector reviewed the package and noted that the modification work wa; completed, the.test plan proposal was completed, the test data were completed, but the transmittal memo was not completed and placed in t.he package as specified by Section
of BF 8.3, Plant Modifications.
The license stated in the exit t.hat the test was not complete; therefore, the transmittal was not required at. this t1me.
The Resident Inspectors will examine the package for OCR 2242 upon completion of the test,s to ver1fy that the Post Modification Transmittal Memorandum has been completed.
within.the areas examined, no violations or deviations were identified.
11.
Reactor Trip System (RTS) Reliability The inspectors participated in the review of a miswir e in the RPS scram trip system switches.
The miswire involved two switches, Nos.
LS-85"45-E and LS-85-45-F in Unit 1.
The switches were miswired in such a
manner that Level Switch LS"85-45-E actuated RPS Channel Bl instead of its designated
%PS Channel Al.
Likewise, Level Switch LS-85"45-F was miswired to actuate RPS Channel Bl.
The wiring to the level switches was simply reversed.
Both sw1tches perform the same function and have the same set points.
Therefore, plant safety was not affected, The miswire was discovered during the performance of Surveillance Instruction No. SI"4. 1.A"8 on December 3,
1984.
Since Unit 1 was in full operation it was deemed inadvisable to physically
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14 correct the miswire.
A Maintenance Request (MR) was initiated instead, to verify the miswire, and to temporarily re-label the switches.
Prior to relabeling, the licensee performed a,safety evalua.ion to ensure that an unreviewed safety question did no't exist.
Another problem was identified with the programming of the Sequential Events Recorder for the East Scram Discharge Level. I Instrumentation (LS"85"45-E,F,G and H) for Units I and 3.
The sequential everts recorders were incorrectly programmed to identify the above East Scram Oischarge Level Switches as LS-85-45 A, B, 0, and 0 on the printout, instead of E, F,
G, and H.
The licensee stated that the recorder for both units (1 and 3) will be reprogrammed to correct the printouts.
This problem is being followed by the Resident Inspectors and other RII per sonnel.
Within the areas examined, no violations or deviations were identified.