IR 05000266/1998015

Insp Repts 50-266/98-15 & 50-301/98-15 on 980720-31.No Violations Noted.Major Areas Inspected:Adequacy of Licensee Programs,Procedures,Training & Supporting Documentation to Ensure TS Required Surveillance Testing

ML20151Y315
Person / Time
Site:	Point Beach
Issue date:	09/11/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151Y256	List: IR 05000266/1998015 ML20151Y252
References
50-266-98-15, 50-301-98-15, NUDOCS 9809180193
Download: ML20151Y315 (19)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlil Docket Nos: 50-266;50-301 License Nos: DPR-24; DPR-27 Report Nos:

50-266/98015(DRS); 50-301/98015(DRS)

Licensee:

Wisconsin Electric Power Company Facility:

Point Beach Nuclear Power Plant, Units 1 & 2 Location:

6610 Nuclear Road Two Rivers, WI 54241 Dates: July 20-31,1998 Inspectors:

David Butler, Team Leader, Rill Evangelos Marinos, NRR, Headquarters Instrument and Controls Branch (HICB)

Hukam Garg, NRR, HICB Alvin Bryant, NRR, HICB Approved by Ronald N. Gardner, Chief, Engineering Specialist Branch 2 Division of Reactor Safety I

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9809180193 980911 PDR ADCCK 05000266 O PDR

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli l

Docket Nos: 50-266; 50-301  !

License Nos: DPR-24; DPR-27  !

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Report Nos: 50-266/98015(DRS); 50-301/98015(DRS)

i Licensee: Wisconsin Electric Power Company i

l Facility: Point Beach Nuclear Power Plant, Units 1 & 2 l Location: 6610 Nuclear Road

. Two Rivers, WI 54241 Dates: July 20-31,1998 Inspectors: David Butler, Team Leader, Rill Evangelos Marinos, NRR, Headquarters Instrument and {

Controls Branch (HICB)

Hukam Garg, NRR, HICB  !

Alvin Bryant, NRR, HICB l l

Approved by Ronald N. Gardner, Chief, Engineering Specialist Branch 2 Division of Reactor Safety l

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EXECUTIVE SUMMARY Point Beach Nuclear Power Plant (PBNP), Units 1 and 2 NRC Inspection Report Nos. 50-266/98015; 50-301/98015 -

The inspection assessed the adequacy of licensee programs, procedures, training, and l

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supporting documentation to ensure Technical Specification required surveillance testing of safety related logic circuits was being performed in an acceptable manne .

Enaineerina

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

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. The inspectors concluded that the licensee was identifying and controlling changes to systems containing logic circuits in an acceptable manner to ensure that required logic testing was being performed (Section E2.1).

. The inspectors concluded that the Technical Specifications related logic circuit functions reviewed during the inspection were tested in an acceptabis manr.er (Section E3.1).

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. The inspectors concluded that the licensee's reviews regarding the applicability of logic testing concerns described in NRC Inforrnation Notices were adequately addressed

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(Section E3.2).

. The inspectors concluded that the Quality Assurance (QA) organization effectively reviewed the GL 96-01 project resulting in positive changes to the project that led to improved management oversight and direction (Section E7.1).

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{ Report Details The inspectors used NRC Temporary Instruction (TI) 2515/139, " Inspection of Licensee's .i

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Implementation of Generic Letter 96-01, Testing of Safety Related Logic Circuits," to assess the -

adequacy of licensee programs, procedures, training, and supporting documentation to ensure i Technical Specification required surveillance testing of safety related logic circuits was being i E performed in an acceptable manne '

111. Engineering '!

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E1 Conduct of Engineering l

E GL 96-01 Imolementation Revigg

Inspection Scope i

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The inspectors reviewed the licensee's program guidelines for implementing actions l i

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requested in GL 96-01. In addition, the inspectors reviewed Position Papers developed

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I following documents were reviewed:

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" Guidelines for the Performance of Technical Specification Surveillance Reviews . l

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for NRC Generic Letter 96-01, " Testing of Safety-Related Logic Circuits,"

Revision 0, dated March 23,199 . Position Papers (PPs), PP-00 thru PP-08 l

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Design Basis Document (DBD) No. 24, Revision 0, "ESF Actuation System" 8 Observation and Findinos The inspectors reviewed the guidelines used for GL 96-01 implementation and determined that the guidelines provided a good vehicle to evaluate safety related logic l groups, to compare drawings and diagrams against surveillance procedures to ensure 1 4-Technical Specification requirements were met, and to ensure procedure changes were

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appropriately made. In addition, the guidelines described the review methodology, assumptions, exceptions, discrepancy identification, documentation, and corrective action process. The following observations were made:

. The inspectors noted that the licensee's GL 96-01 review efforts performed before the guidelines were issued may not have followed the same review methodology contained in the guidelines. The licensee stated that even though the guidelines were not formally documented early in the review process, the review outline was consistent with the current guidelines. The licensee was able

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to provide appropriate documentation that demonstrated that their early review efforts were in accordance with the guidelines.

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. The inspectors noted that the guidelines did not identify the specific systems that >

were included in the review scope. The licensee provided Attachment D of DB No. 24, which defined the Engineered Safety Features Actuation System ,

actuated equipment and identified the systems included in the review. However, ,

this document did not identify other support systems that could be within the  !

generic letter scope of review but not specifically discussed in the generic lette !

The inspectors specifically requested the licensee to demonstrate that the control .

room emergency filtration system had been considered in the GL 96-01 revie l The licensee was able to demonstrate that the control room emergency filtration l automatic initiation logics had been reviewed under the containment isolation  ;

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logic reviews and that these logics were tested each refueling outag . The inspectors noted that the licensee's GL 96-01 review guidelines did not have a specific line item to address industry identified testing deficiencies, other utility ;

licensee event reports, and service bulletins issued by the vendors for the PBN ;

in response, the licensee provided procedure NP 5.3.2, " Industry Operating '

Experience Procedure." The Quality Assurance (QA) organization indicated that future audits and self-assessments would be evaluating the industry operating experience program. In addition, this issue will be further reviewed by the Horizon issues group which was chaired by the Corrective Action / Operating Experience program manager and attended by representatives from quality

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assurance (intemal audits and supplier assessments), licensing, and other Point Beach organizations that perform self-assessments. The purpose of this group j was to perform a global review of intemal and extemal operating experience, and vendor technical information. The review results will be used to adjust QA's j audit schedu'e and content to ensure lessons learned throughout the industry -

were integrated in Point Beach operations. The first meeting of this group was held on July 24,1998, to discuss how the various organizations could best contribute to this goal. Future meetings will be held monthly until the group can establish an acceptable meeting interval to ensure continued success of the industry operating experience progra !

During the implementation of its GL-96-01 reviews, the licensee identified 437 testing l issues which resulted in 59 Action items,32 Condition Reports, three Licensee Event Reports, and the revision of 22 procedures. Subsequent testing did not identify any logic failures. During the inspection, the inspectors observed safeguards testing. The instrument and control technicians performed the test in an acceptable manner, maintained contact with the control room operator and were knowledgeable of the recently revised procedure steps. The testing activities were satisfactorily complete ConclusiDDR The inspectors concluded that the licensee's GL 96-01 guidelines were appropriate for reviewing the issues identified in the generic letter, that the licensee was addressing industry operating experience in an acceptable manner, and that the GL 96-01 program was appropriately identifying and resolving issue '

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E1.2 Point Beach Soecific Position Paoers l

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Appendix D to the guidelines contained position papers used to document the technical ,

bases for exempting certain logic circuits from GL 96-01 testing requirements. The l following documents were reviewed: j

. Nuclear Power Business Unit Procedure (NP) No.1.1.3, Revision 9, " Procedure '!

Creation, Revision, Review, and Approval"  ;

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. PP-00, " Background document for developing position papers," dated May 15, l 1998  !

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. PP-01, " Testing exemption for parallel circuits paths in energize to actuate l protection logic trains," dated June 16,1998 j

. PP-02, " Testing exemption for parallel Reactor Trip Relay Contacts," dated !'

May 15,1998

. PP-03, " Testing exemption for 4160 VAC Bus Lockout Relays," dated May 15, ;

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. PP-04, " Testing exemption for Parallel P-10 Permissive Relay Contacts," dated May 20,1998

. PP-05, " Testing exemption for Parallel P-7, P-8, and P-9 Permissive Relay Contacts," dated May 20,1998

. PP-06, " Testing exemption for Series-Connected Blocking Contacts," dated May 20,1998

. PP-07, " Testing exemption for Parallel RC [ Reactor Coolant] Low Flow Relay contacts," dated May 15,1998

. PP-08, " Testing exemption for Parallel SR [ Source Range], IR [ Intermediate Range], and PR [ Power Range] Block Relay Contacts," dated May 15,1998 Observations and Findinos l

The inspectors reviewed the position papers and agreed with the licensee's positions with the following clarifications: j

. The licensee took credit for testing performed by procedures other than surveillance procedures, such as, routine maintenance procedures (RMP). The

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inspectors questioned the level of attention given to these procedures in regard to maintaining the testing interval and controlling procedure change '

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! In response, the licensee stated that the testing interval was maintained by the l Computer l zed History And Maintenance Planning System (CHAMPS) database ;

, for required surveillance testing and procedure changes were controlled by the l l procedure review and approval process. In addition, procedure NP 1.1.3 and the I writers' guide identified that licensee commitments should be reviewed to ensure !

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. The inspectors noted that the parallel contact configurations described in the l position papers may also be required for current carrying capability and should i

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l have been evaluated for adequate capacity. The licensee provided two letters ;

from Westinghouse ( WEP-519, dated June 10,1996, and WEP-539, dated  ;

September 30,1996) which stated, in part, that parallel contacts in relay !

protection systems were provided for reliability and had no other design functio The letters further stated that this was a low current application. The inspectors noted that the relay contacts were rated for 5 amperes and that the contacts l passed 4 KV breaker trip coil operating current. The inspectors were concemed that a single contact passing this current could become unreliable since the trip -

coil was rated at 5 ampere ;

in response, the licensee initiated CR 98-1009 to evaluate whether a single contact was appropriate for a 4 KV breaker trip circuit. In addition, the licensee ,

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indicated that relay contact current carrying capability would be addressed in the appropriate position papers. This was acceptable to the inspector . It was the inspectors opinion that even though some parallel contacts were only !

used to lower the probability of spurious reactor trips, and did not perform a l redundant and independent safety function, that testing enhancements may be appropriate for contacts addressed by the position paper In response, the licensee stated that they had initiated CR 97-3525 to evaluate the feasibility of testing parallel reactor trip contacts in current surveillance procedures. In addition, the licensee was also investigating the feasibility of testing parallel contacts used in other applications covered by the position papers. This was acceptable to the inspectors, Conclusions The inspectors concluded that the licensee was appropriately addressing uncommon logic design configuration E1.3 Conclusions on Conduct of Enaineerina Based on the review of the licensee's GL 96-01 guidelines and position papers, the l inspectors concluded that the licensee's logic testing program and supporting

! documentation was good and met the intent of GL 96-0 .

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E.2.1 Modification Process Insoection Scoce l i

The inspectors reviewed the modification process to ensure that modifications to logic systems would be properly controlled. The following documents were reviewed:

. Procedure No. NP 7.2.1, Revision 3," Modification Requests"

. Modification Request (MR) No.97-087, "A-Train Reactor Protection GL 96-01 Push-button Modification"

. Installation Work Plan (lWP) No. 97-087-01, "MR 97-087 A-Train Reactor Protection GL 96-01 Push-button Modification Unit 1"

. Safety Evaluation (SE) No.98-013, " Generic Letter 96-01 Push-button Modification" Observation and Findinas The inspectors reviewed procedure NP 7.2.1. This procedure required the responsible I engineer to complete checklist PBF-1606, Revision 5, with each modification reques This checklist required the responsible engineer to identify any changes to the Technical Specifications, CHAMPS database, and testing requirements. The inspectors determined that the checklist provided sufficient controls to ensure that future modifications would properly test changes to logic systems, j l Modification MR 97-087 added a new push-button test switch to the P-10 permissive i logic circuits in the Unit i reactor protection system Train A and B logic test cabinet The purpose of the switch was to de-energize the P-10 permissive relays to enable the melear instrumentation trip-block logics during post refueling testing. The test switch and jacks were similar to other test switches and jacks that had been qualified for this applicatio The inspectors reviewed the modification package including the safety evaluation, post modification testing and schematic diagram Nos. WEST 617F354, Sheets 4A2,6A2 and 10A2. The safety evaluation was thorough and provided sufficient information to '

determine that the push-button switch installation did not create an unreviewed safety question. In addition, the installation instructions appropriately detailed the work to be performed, and the post modification testing ensured that all portions of the modified logic circuits were properly tested.

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! Conclusions The inspectors concluded that the licensee was identifying and controlling changes to systems containing logic circuits in an acceptable manner to ensure that required logic testing was being performe E2.2 Service Water Pumos Insoection Scone The inspectors reviewed licensee documentation used to establish the required number of service water pumps needed for accident mitigation. The following documents were reviewed:

. Calculation No. N-90-006, Revision 1, " Service Water Flow Balance to Meet l Emergency Loads" (assumptions and conclusion statement)

. Calculation No. 97-0054, Revision 2 " Service Water System Limiting Conditions l

for Operation - Injection Phase" (assumptions and conclusion statement)

I . Calculation No. 97-0126, Revision 2, " Service Water System Limiting Conditions l for Operation - Recirculation Phase" (assumptions and conclusion statement)

. License Amendment Nos.174 and 178, July 9,1997," POINT BEACH l NUCLEAR PLANT, UNIT NOS.1 AND 2 -ISSUANCE OF AMENDMENTS RE:

l TECHNICAL SPECIFICATION CHANGES FOR REVISED SYSTEM l REQUIREMENTS TO ENSURE POST - ACCIDENT CONTAINMENT COOLING CAPABILITY"

. Emergency Operating Procedure (EOP) No. EOP-0, Unit 1, Revision 27,

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" Reactor Trip or Safety injection" l l

. EOP-1.3, Unit 1, Revision 18, " Transfer to Containment Sump Recirculation"

. EOP-0, Unit 2, Revision 27, " Reactor Trip or Safety injection" l

l . EOP-1.3, Unit 2, Revision 18, " Transfer to Containment Sump Recirculation"

. Licensee Event Report (LER) No.96-004, Unit 1. " Operation of Service Water System Outside the Design Basis" l

. Condition Report (CR) No. CR 96-491, " Service Water System Design Basis l During Accidents Operational Limitations" l

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. CR 98-1533," Procedure and Calculation Assumptions Do Not Match"

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The service water system (SW) design basis was described in the Final Safety Analysis :

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Report (FSAR), Section 6.2, " Safety injection System." The FSAR stated, in part, that I l three of the six service water pumps are required to operate during the recirculation i

phase to cool the recirculation fluid and containment atmosphere in the unit suffering the ;

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accident and provide the necessary cooling for the other unit. The licensee had

! identified (CR 96-491) that the units may not have always met this requirement due to i i the Technical Specifications not recognizing train restrictions when considering the single failure of an emergency diesel generator (EDG) and the number of SW pumps l

that would be required to be operable. The original SW Technical Specifications ,

I required four pumps to be operable. However, the Limiting Conditions for Operation  :

statement did not address the removal of a train specific SW pump along with a [

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l postulated EDG failure (three SW pumps would be lost). This could leave only two SW pumps available for accident mitigatio l The licensee re-analyzed the SW thermal-hydraulic calculations and concluded that the i SW design basis had always been three pumps. Seventeen CRs were initiated during  !

the re-analysis. Calculation discrepancies, such as, factoring in maximum - minimum l

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lake levels, as-built valve and pipe elbow differences, and system alignment i

assumptions, were identified and resolved, in addition, the licensee identified (CR 98-1533) that EOP procedure actions may not match calculation assumptions. The calculations assumed that non-essential SW loads would be isolated by the EOPs prior

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to transferring from injection to the containment recirculation sump. This was based on

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four SW pump operation. The EOPs assumed that the non-essentialloads did not have

to be isolated if four pumps were available. However, these assumptions did not recognize the potential to have only two SW pumps availabl Recognizing that the Technical Specifications wera inadequate, the licensee submitted and received from the NRC a Technical Specifications amendment for both units that made the SW Limiting Conditions for Operation consistent with the design basis. In addition, the inspectors reviewed the applicable EOPs and determined that the revised procedure steps met the calculation assumptions, met the SW design basis, and were

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consistent with the Technical Specifications.

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The inspectors concluded that the licensee had reconfirmed the required number or SW

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pumps required for accident mitigation in an acceptable manner and appropriately revised the EOPs to reflect the SW design basi l E2.3 Containment Accident Fans Insoection Scone

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The inspectors reviewed licensee documenta'.lon associated with containment accident j fan power requirements to ensure that the EDG loading analysis bounded actual fan  !

l power usage during accident conditions. The following documents were reviewed:

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. Technical Specification Test (TS) No. TS 34, Revision 20, " Containment j Accident Recirculation Fan-Cooler Units (Monthly)"

. Routine Maintenance Procedure (RMP) No. RMP 31, Revision 7. " Measurement l of Air Flow Rates for Containment Accioent Fans W1 A1, W181, W1C1, W1D1" '

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. Operations Refueling Test (ORT) No. ORT 17, Revision 1, " Containment l Integrated Leak Rate Test Unit 1" >

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= ORT 17A, Revision 0, " Containment integrated Leak Rate Test With Core Off-Loaded Unit 2" (Containment Accident Fans 2W-1 A1,2W-1B1,2W-1C1, and ,

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2W-1D1)

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l * Calculation No. N-91-016, Revision 2, "PBNP Diesel Generator Loading i l Analysis"  ;

. CR 96-1680,"EDG Loading Analysis Calculation Changed Without Proper Justification Being Identified"

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.- CR 98-2950," Containment Accident Fan Acceptance Criteria inconsistencies"

. b. Observations and Findings i

The licensee had initiated CR 96-1680 to address EDG loading effects if the

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containment accident fan blade pitch was changed. The fans were constant volume units that were designed to deliver the same volume during changing density condition t Calculation N-91-016 projected the containment accident fan power flow to be 120 K '

This was based on a Westinghouse power factor of 0.877 and a motor efficiency of 0.927. The measured Unit i fan motor power factor averaged 0.85. Even though the measured value was loner than the value assumed in the EDG loading analysis, this l change had a minimal effect on the calculation conclusion.

! Monthly fan testing (RMP 31) vias performed during normal operating conditions. The

monitored current (about 80 amperes) would be less than the value seen during accident conditions. The licensee used a window of opportunity to determine accident motor running currents during containment integrated leak rate testing. This created a density environment similar to accident conditions. The following average values were derived:

MDjl Procedure Current (amoeres) Power (kilowatts)

1 ORT 17 143 105 2 ORT 17A 154 112 The inspectors determined that the current blade pitch adjustments were bounded by

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the EDG loading analysis.

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RMP 31 contained a step to calculate the accident current based on a density correction !

factor, normal running current and degraded voltage conditions. This calculation was used to determine if an accident fan would trip at it's minimum design voltage (414 j volts). However, the' licensee was unable to provide the basis for the acceptance value (s 210 amperes). In addition, procedure TS 34 had a fan motor acceptance current of s .

, 110 amperes without having an engineering basis for the value. The licensee initiated i CR 98-2950 to correct and document the bases for determining accident fan motor :

current acceptance values. The inspectors reviewed fan testing performed since April - l 1996 and determined that the monthly Unit 1 fan motors current averaged s 80 amperes i per test. This fulfilled the Technical Specification requirement that the accident fans be started and their running current verifie t Conclusions  !

The inspectors conclude. ' Hat slight variances in the power factor design input to - !

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calculation N-91-016 did not...ar the calculation conclusions. Sufficient calculation .;

- design margin existed to bound such variances. In addition, the licensee was  ;

addressing a means to verify that fan blade pitch adjustments affecting power  !

consumption would be bounded by the EDG loading analysis. This was acceptable to :

the inspector E2.4 Main Control Board Wiring Seoaration Insoection Scone  !

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The inspectors reviewed the licensee's efforts to resolve main control board separation issues. The following documents were reviewed:  ;

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. LER No. 96-007-00, " Redundant Safety Related Circuits in the same Control ;

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Board Raceway Point Beach Plant, Units i and 2"

. Letter No. NPL 97-0100, dated April 16,1997, " Main Control Board Wiring Separation Operability Determination and Restoration Plan Point Beach Nuclear Plant, Units 1 and 2"

. Design and Installation Guideline No. DG-E07, Revision 1, " Separation of Electrical Circuits"

. CR 96-385, " Potential Failure of Redundant Safety Related Circuits within the Main Control Board" i t Observations and Findings The licensee had identified several instances (LER 96-007-00) where physical separation of redundant safety related circuits inside the main control boards were not provided.' Following circuit reviews,270 work packages were created for Unit 1 to

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improve main control board wiring separation. This work has been completed. Unit 2

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separation modifications were tentatively scheduled to be completed during the December 1998 outage. In addition, the licensee was looking at nonsafety, cross-train cable routings inside the main control boards. The licensee was not sure, at this time, if ,

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this would be a problem. Current field wiring practices do not allow cross-train, ;

nonsafety cable routings.

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The inspectors reviewed design guideline DG-E07. This guideline provided physical !

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separation wiring requirements for the main control boards. The guideline stated, in :

part, that all A-Train wiring shall be separated from all B-Train wiring including any wires !

? which can be associated with either train; wires requiring separation shall be routed ;

through separate wireways; wireways in the main control boards have been identified i with their train association; only wires of the appropriate train and nonsafety related wires shall be installed in a wireway; wires which require separation from each other j shall not be bundled together; and devices (switches for example) having connecting !

wiring requiring separation shall have wiring separately bundled and routed to obtain physical separation immediately upon leaving the device terminals. The inspectors !

determined that appropriate wiring separation design guidance was provided in the

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guideline to ensure nonsafety wiring will not affect redundant safety train wiring and device > Conclusions The inspectors concluded that the licensee was appropriately addressing safety related main control board wiring separation issues and had acceptable controls in place to address the routing of nonsafety wire !

E3 Engineering Procedures and Documentation E3.1 Safetv-Related Loalc circuit review

, Insoection Scone The inspectors reviewed several logic group diagrams and electrical schematics against applicable test procedures, Technical Specifications, and other documents related to logic circuits. The review verified the testing of parallel logics, interlocks, permissives, bypasses and inhibit circuits required by Technical Specifications for EDG starting, auxiliary feedwater, steam generator level, pressurizer level and pressurizer pressure actuation circuits, Observations and Findinas The inspectors checked the testing of a given logic circuit by comparing individual circuit elements (contacts) to specific steps in corresponding surveillance procedure . The inspectors found that the licensee adequately documented discrepancies and tracked those instances that required procedure revisions as Nuclear Tracking System (NUTRK)

action items. The inspectors noted that the procedural steps reviewed had been appropriately revise !

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The licensee's approach to the GL 96-01 logic circuit review involved the comparison of l logic circuits against a master drawing list to ensure that all safety related logic groups i were covered in their review. The documentation was compiled into logic group review l packages. The packages contained highlighted circuit drawings and logic diagrams, a ;

list of corresponding procedures, and a list of related Technical Specifications for each !

safety related logic function. In addition, a logic report database was included which ;

identified associated equipment, logic elements, related Technical Specification . !

requirements, and applicable procedural steps that test each circuit element. - Testing l

. discrepancies, licensee recommendations, and corresponding issue resolutions were l

reflected in the database. This approach allowed the inspectors to directly correlate i Technical Specification requirements to test procedures and to verify individual logic !

element testin ;

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The inspectors concluded that the Technical Specifications related logic circuit functions j reviewed during the inspection were tested in an acceptable manner,

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E3.2 NRC Information Notice Review Inspection Scope

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The inspectors reviewed the licensee's documentation related to the following NRC i information Notices: IN 88-83, " inadequate testing of 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 i injection and Reactor Trip Switches;" IN 93-38," Inadequate Testing of Engineered Safety Features Actuation Systems;" and IN 95-15," inadequate Logic Testing of Safety-Related Contacts." Observations and Findinos The inspectors reviewed the Action item Status Reports which documented the licensee's evaluations of NRC Information Notices identified in GL 96-01. Overall, the licensee's evaluations addressed the concems raised in the information Notice However, the inspectors noted that four of the six original IN evaluations had been re-reviewed just prior to this inspection. The inspectors questioned the licensee conceming their failure to detect two testing discrepancies during the original IN review The licensee acknowledged that their staff's questioning attitude increased as the GL 96-01 review process was develope Subsequently, the two discrepancies were determined to be outside the scope of GL 96-

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01. The re-evaluation of IN 91-13, completed July 21,1998, concluded that EDG independent start air bank test procedures, RMP 9043 series, should be revised to isolate the starting air control power to each start circuit to provide a more complete test, in addition, the re-evaluation of IN 93-38, completed July 17,1998, resulted in the 13 _ , _ -

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revision of several Instrument and Control, ICP 2.1 series, procedures to verify test i switch contact continuity. The contacts in question were part of the containment spray . l analog channel circuits. The licensee determined that the existing contact testing did !

not fulfill Technical Specification requirements and initiated CR 98-2688. The licensee issued a supplement to LER 266/98-010, " inadequate Technical Specifications l Surveillance of Containment Spray Logic," on August 3,199 l l Conclusions  !

i The inspectors concluded the licensee's reviews regarding the applicability of logic j testing concems described in NRC Information Notices were adequately addresse i l

E7 Quality Assurance in Engineering Activities' i

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E7,1 Onditv Amenrance GL 96-01 Reviews .

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! Insoection Scone  ;

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The inspectors reviewed the following QA surveillance reports:

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S-P-97-14,' dated December 17,1997, " Technical Specification Line item Surveillance" i'

S-P-98-02, dated June 5,1998, " Technical Specification Line item, GL 96-01"

' Observations and Findinas l

Surveillance report S-P-97-14 identified that the resolution of the reactor protection system permissive logic issues described in NUTRK GL 96-01, Action items 25 and 26,

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may not have been dispositioned properly when CR 96-365, " Testing Requirements of GL 96-01 Net Being Met," was closed. The CR had concluded that the permissive logic testing satisfied the Technical Specification requirements. However, the QA surveillance team questioned this disposition and was informed by the GL 96-01 team ,

that the permissive issue was being re-evaluated as part of the independent self-assessment. Subsequently, CR 97-3786," Missed Surveillance Test of NIS Logic Relay Contacts," was initiated by site engineering and documented in LER 97-043 on December 15,1997. The Unit 1 power range neutron flux permissive (P-10) logics were successfully tested in November 1997 and the Unit 2 logics were successfully tested in January - February 199 ,

Surveillance report S-P-98-02 was conducted during the weeks of March 16-27 and May 11-19,1998. The surveillance team identified that the GL 96-01 effort was conducted without a written procedure or work instruction. In addition, the surveillance team concluded that the project appeared to lack a clear sense of direction with organizational responsibilities and ownership not well established between Milwaukee and site engineering. This was considered a significant QA finding and Quality Condition Report (QCR) 98-0113, "GL 96-01 Review Performed without a Written Procedure or Instruction," was initiated to evaluate the GL 96-01 project. In response, site

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engineering assumed ownership of the GL 96-01 project, a root cause evaluation was initiated, and a 100 percent verification of the GL 96-01 effort was starte .i Conclusions The inspectors concluded that the QA organization effectively reviewed the GL 96-01 ,

project resulting in positive changes to the project that led to improved management l oversight and directio E7.2 . Condition Report Process Insoection Scone The inspectors evaluated the licensee's threshold for issuing condition reports during engineering document reviews. The following documents were reviewed:

. CR 98-1824, " Evaluate issues identified during the Chapter 14, Accident

- Analysis Review"

.- Procedure No. NP 5.3.1, Revision 7, " Condition Reporting System" c

- ' Procedure No. NP 5.3.1, Revision 8, " Condition Reporting System"

. Procedure No. NP 5.3.9, Revision 2 " Corrective Action Program"

.- Procedure No. NP 5.4.1, Revision 4 "Open item Tracking Systems"

. Nuclear Energy Consultants, Inc., Program Standard No. NEC-PBNP-001, Revision 0," Surveillance implementation Adequacy Review Program"

. Nuclear Energy Consultants, Inc., Program Standard No. NEC-PBNP-GP-001, Revision 1," Surveillance implementation Adequacy Review Program"  !

. Point Beach Nuclear Plant, Guidelines for the Performance of Technical l Specification Surveillance Reviews for NRC Generic Letter 96-01, " Testing of Sa'* Related Logic Circuits," Revision 0 Observations mi.d Findinas During a review (CR 98-1824) of the replacement steam generators analyses, twenty ,

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questions were raised by a contractor regarding potential impact on the Final Safety

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Analysis Report. The inspectors reviewed the questions to determine, if warranted, that they had been properly captured by the condition reporting system. Eleven of the i questions were analyzed by the CR. The remaining questions were basically requests for additional information and did not appear to warrant a condition report evaluatio i i

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The inspectors reviewed the process for identifying testing discrepancies during the GL 96-01 review. Several NEC contractors were used to perform an independent review of the project. The contractors used an NEC developed review standard that had been approved for use by the licensee. Identified discrepancies were documented on an .

Issue Resolution (IR) form. Issues were reviewed with the NEC project lead and the *

Point Beach subject matter expert (usually the system engineer) to determine if a condition report was required. Procedure NP 5.3.1 was followed for dispositioning any 1 issue requiring a CR. If an issue was indeterminate as to its effect on quality, the review process defaulted to plant procedures (NP 5.3.1 and NP 5.3.9) to initiate a C ,

The inspectors interviewed several system engineers, a contract engineer and an engineering manager to determine if the individuals understood the condition reporting process and managements expectations for writing CRs. In all cases, the individuals properly acknowledged the purpose for the condition reporting system and indicated .

their willingness to write CRs for conditions adverse to quality. In addition, the

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licensee's general employee training and employee concerns program re-enforced the identification of non-compliances or safety concerns (conditions adverse to quality).

This included the following:

. notify your supervision of the problem, '

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. Initiate a Condition Report,

. contact the Employee Concerns Program,

. contact the site vice-president, the Chief Nuclear Officer (CNO), or Corporate Secretary, or

. notify the NRC The training materials stated, in part, that any employee, contractor, or subcontractor could write a CR and that there was no threshold for initiating CRs.

During the course of this inspection, the inspectors did not identify any instances were

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CRs had not been written for an issue that appeared to be a condition adverse to quality.

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, Conclusions l

l The inspectors concluded that onsite personnel had an acceptable understanding of the CR process and were initiating CRs for identified conditions adverse to quality.

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V. Management Meeting i

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X1 Exit Meeting Summary -

The inspectors presented the inspection results to members of licensee matlagement on July

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31,1998. The licensee acknowledged the findings presented. The inspectors asked the i licensee whether any materia's examined during the inspection should be considered i proprietary. No proprietary Wormation was identifie )

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PARTIAL LIST OF PERSONS CONTACTED Licensee G. Boldt, Quality Assurance Section Manager S. Bowe, General Supervisor, Maintenance M, Conry, Sr. Project Engineer, Nuclear Engineering F. Flentje, Senior Regulation & Compliance Specialist J. Gadzala, Senior Regulation & Compliance Specialist W. Hennig, Senior Engineer, Electrical Systems Engineering

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J. Henriksen, Project Manager, GL 96-01 R. Homak, Project Engineer, Systems Engineering T. Jessessky, Senior Project Engineer, Electrical Systems Engineering V. Kaminskas, Regulatory Services & Licensing Manager R. Mende, Operations Manager S. Pfaff, General Supervisor, Corrective Actions M, Reddemann, Plant Manager J. Schweitzer, Systems Engineering Manager J.Thorgersen,' Quality Verification Manager NBC M. Kunowski, Project Engineer, Rlli INSPECTION PROCEDURES USED IP 37551 *Onsite Engineering Tl 2515/139 " Inspection of Licensee's implementation of Generic Letter 96-01, Testing of Safety Related Logic Circuits" LIST OF ITEMS OPENED AND CLOSED No items were opened or closed

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LIST OF ACRONYMS USED IN POINT BEACH REPORTS AC Alternating Current AFW Auxiliary Feedwater l CFR Code of Federal Regulations CHAMPS Computerized Data Base CR Condition Report DBD- Design Basis Document l DRP- Division of Reactor Projects URS Division of Reactor Safety DSS Duty Shift Superintendent ECCS Emergency Core Cooling System

.EDG Emergency Diesel Generator .

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EOP Emergency Operating Procedure ,

'F degree - Fahrenheit l FSAR Final Safety Analysis Report i GL Genenc Leuer

- ICP instrument and Control Procedure  ;

IN information Notice f IP inspection Procedure i IR issue Resolution Form IWP Installation Work Plan i LCO Limiting Condition for Operation LER Licensee Event Report '

NCV Non-Cited Violation -  ;

NOV Notice of Violation l

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NP Nuclear Power Business Unit Procedure NRC Nuclear Regulatory Commission l NUTRK- Nuclear Tracking System i OD Operability Determination ORT Operations Refueling Test PBNP' Point Beach Nuclear Plant POD Prompt Operability Determination PBTP Point Beach Test Procedure PP Position Paper QA Quality Assurance QCR Quality Condition Report RMP Routine Maintenance Procedure RO Reactor Operator RWST Refueling Water Storage Tank SE Safety Evaluation  ;

SI Safety injection SRO- Senior Reactor Operator SW Service Water TDAFW Turbine Driven Auxiliary Feedwater Tl Temporary Instruction TS Technical Specification Test j WEP Wisconsin Electric Power j

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