ML20127N640

Insp Repts 50-338/85-11 & 50-339/85-11 on 850408-12. Violations Noted:Inadequate Review of Reactor Trip Maint Procedures & Failure to Follow Procedure During Performance of Work Order 9344

ML20127N640
Person / Time
Site:	North Anna
Issue date:	05/06/1985
From:	Conlon T, Marlone Davis, Foster L, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127N627	List: ML20127N623 ML20127N632 ML20127N640
References
RTR-NUREG-0737, RTR-NUREG-737 50-338-85-11, 50-339-85-11, GL-83-28, NUDOCS 8507020051
Download: ML20127N640 (21)

See also: IR 05000338/1985011

Text

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UNITED STATES

[ARito ' o,'n NUCLEAR REGULATORY COMMISSION

y REGION 11

4 j 101 MARIETTA STREET, N.W.

• '. * ATLANTA, GEORGt A 30323

'+,.....go

Report Nos.: 50-338/85-11 and 50-339/85-11

Licensee: Virginia Electric and Power Company

Richmond, VA 23261

Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7

Facility Name: North Anna 1 and 2

Inspection Conducted: April 8 - 12,1985

Inspectors:

L. E. Foster, Team Leader

fM/8I

Date Signed

N'.

,

Merriweather

/s .WJW C/3 /W

Date Signed

M. J. Davis

Am, 4 / hf ~

6 fT.5

Date Signed

Consultant: P. M. han, wren 'e -L ermore National Laboratory

Approved by: -

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/v 5-4-85

T. E. Conlon, Sec on ief ' y' Date Signed

Engineering Branch F

Division of Reactor Safety

SUMMARY

Scope: This routine, announced inspection entailed 135 inspector-hours at the

site concerning licensee response to Generic Letter 83-28, Required Actions Based

on Generic Implications of Salem Anticipated Transient Without Scram (ATWS)

Events. Areas inspected included: post-trip review; equipment classification;

vendor interface and manual control; post-maintenance testing; and reactor trip

system reliability.

Results: Two violations were identified - Inadequate Review of Procedures for

. Reactor Trip Maintenance, paragraph 9.a; Failure to Follow Procedure During

Performance of Work Order No. 9344, paragraph 10.a.

8507020051 850513

PDR

0 ADOCK 05000338

PDR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• E. W. Harrell, Station Manager

• M. L. Bowling, Assistant Station Manager

G. Bridges, Station Records

R. P. Beger, Electrical Foreman

R. A. Bergquist, Instrument Maintenance Supervisor

S. Bennan, Senior Buyer

K. Cununings, Purchasing Supervisor

E. Creech, Outage Planner

• S. B. Eisenhart, Licensing Coordinator

K. Epperson, Performance Engineer

A. Gibson, Station Records

• J. R. Harper, Supervisor, Maintenance

• R. T. Johnson, Supervisor Quality Assurance

P. Knutsen, Engineering Coordinator

P. B. Perrine, Senior Computer Technician

• J. Rauth, Supervisor, Records Management

J. Roth, Engineer

J. A. Stall, Superintendent of Technical Services

B. Starr, Operations Coordinator

• R. Sidle, Supervisor, Maintenance Services

L. Silman, Staff Engineer

F. Sowards, Mechanical Supervisor

B. Sturgill, Supervisor, Safety Engineering

• F. T. Tenninella, Supervisor, Quality Control

R. S. Thomas, Shift Technical Advisor

J. A. Weim, Senior QC Inspector

V. C. West, Planning Supervisor

Other licensee employees contacted included foremen, engineers,

technicians, operators, mechanics, electricians, security force members, and

office personnel.

NRC Resident Inspectors

M. Branch, Senior Resident Inspector

J. Luehman, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on April 12, 1985, with

those persons indicated in paragraph I above. The inspector described the

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areas inspected and discussed in detail the inspection findings listed

below. No dissenting comments were received from the licensee.

Violation 338, 339/85-11-01, Inadequate Review of Procedures for

Reactor Trip Breaker Maintenance - paragraph 9.a.

Violaticn 338/85-11-02, Failure to Follow Procedure During Performance

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of Work Order 9344 - paragraph 10.b.

Unresolved Item 338,339/85-11-03, Review Licensee Methods for Revising

Purchase Requisitions - paragraph 7.a.

Unresolved Item 338, 339/85-11-04, Retrieval of Maintenance Work Order

Package No. 8736 - paragraph 10.a.

Inspector Followup Item 338, 339/85-11-05, Work Order Processing -

paragraph 7.b.

Inspector Followup Item 338, 339/85-11-06, Review Changes in Proce-

dure ADM 16.5 for Processing Emergency Work Orders - paragraph 7.c.

Inspector Followup Item 338, 339/85-11-07, Clarification of QA/QC

Responsibilities in Procedures -paragraph 8.e.(7).

The licensee did not identify as proprietary any of the material provided to

or reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Unresolved Items

Unresolved Items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations.

Two new unresolved items identified during this inspection are discussed in

paragraphs 7 and 10.

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 22 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 Actions Based on Generic Implications of Salem ATWS

Events, dated July 8, 1983. This letter required the licensees to respond

on immediate-tem actions to ensure reliability of the RTS. Actions to be

perfomed included development of programs to provide for post-trip review,

classification of equipment, vendor interface, post-maintenance testing, and

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RTS reliability improvements. The licensee responded to Generic Letter 83-28 by correspondence dated November 4,1983, February 8,1985, March 29,

1985 and April 1,1985. This inspection was performed to review the

license?'s current program, planned program improvements, and implementation

of present procedures associated with post-trip review, equipment classifi-

cation, vendor interface, post-maintenance testing, and reactor trip system

reliability for North Anna Units 1 and 2.

6. Post-Trip Review

The licensee was requested in Generic Letter 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 detailed description of the program and

procedures pertinent to performing post-trip reviews. The inspectors

reviewed their responses, appropriate procedures, and interviewed

responsible licensee personnel to assess the adequacy of the licensee's

program for post-trip reviews. The results of this inspection are discussed

below:

The post-trip review program is addressed and implemented by North Anna

Power Station Administrative Procedure ADM-19.18, Post Trip Review.

The Shift Supervisor is responsible for determining the cause of any reactor

trip. He documents his findings on the " Reactor Shutdown and Trip Report

Form" (Attachment A to ADM-19.18).

The Shift Technical Advisor (STA) is responsible for conducting an indepen-

dent evaluation of the reactor-trip event. His activities are documented by

the completion of the " Post-Trip Review Report" (Attachment B to ADM-19.18).

Any unplanned manual or automatic reactor trip will require a full post-trip

review report and the assembly of an associated data package which includes

control room strip charts, sequence of events recorder printout, the P-250

Alarm typewriter printout, and the P-250 Post-Trip review printout.

Reactor trip events are classified in two categories. In a Class I reactor

trip the cause of the trip is clearly understood and corrected and no

significant malfunctions of safety-related or important equipment occurred.

The Superintendent of Operations is authorized to make the restart decision

for Class I reactor trips. A Class II reactor trip event is one where the

cause of the trip is not clearly known, or safety related and/or other

important equipment functioned in an abnormal or degraded manner during or

following the trip. Following a Class 11 reactor trip event the restart

decision is made by the Station Manager or Assistant Manager, with

concurrence of the Statior Nuclear Safety and Operating Comittee (SNSOC)

and the Superintendent of Operations.

The Post-Trip Review Report is presented to SNSOC for review within 30 days

of the event. Within seven days of the final SNSOC review, the post-trip ,

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review data package is sent to the Safety Evaluation and Control (SEC) staff

for an independent review of the adequacy of the trip review and corrective

actions. The post-trip review data package is retained in Station Records

for the life of the plant.

The inspector reviewed the post-trip review data packages generated for

twelve reactor trips that occurred in 1984. The packages were thorough and

adequately documented the events.

The inspector conducted a review of licensee procedures and verified that

procedures were consistent with licensee responses to GL 83-28. The

procedures listed below were reviewed:

ADM 1.2, Safety Engineering Staff, dated May 24, 1984

ADM 1.0, Station Organization and Responsibility, dated April 18, 1984

ADM 2.14, Reactor Operator License Training, dated March 31, 1983

ADM 2.15, Senior Reactor Operator License Training, dated

March 31, 1983

ADM 2.16, Shift Technical Advisor Training, dated March 31, 1983

ADM 5.3, Review of Procedure, dated October 25, 1984

ADM 19.18, Post-Trip Review, dated January 10, 1985

ADM 19.19, Return to Power Following a Trip, dated March 31, 1983

Each unit at North Anna has a Westinghouse P-250 process and alarm computer,

which contains a sequence of events (S0E) program. The SOE program monitors

the status of selected reactor trip signals and initiates the recording and

print subroutines when a change in the status of the monitored parameters is

detected. The SOE program prints out on the utility typewriter in the

control room. Following a reactor trip on December 31, 1984, when part of

the SOE data was lost due to a typewriter ribbon malfunction, a change to

the computer software was initiated to provide storage of SOE program data

on disc in addition to the hard copy provided to the typewriter. Part of

the STA's daily turnover is to ensure that the computer is set up to

automatically store 50E data should a reactor trip occur. The power source

for the plant computer is an inverter fed from one of the station's Class 1E

batteries or via a transformer from a 4160 VAC emergency bus.

Each unit at North Anna also has an independent Hathaway Sequential Events

Recorder (SER), which monitors selected reactor trip, turbine trip,

Engineered Safety Features (ESF), generator, and miscellaneous control

system alarms. The SOE information is automatically printed on a paper tape

by a teletype printer. The power source for the SER is from a Class 1E

vital bus.

The licensee is in the process of installing the Safety Parameter Display

System (SPDS) data collection and processing system associated with the

l NUREG-0737 upgrade of Emergency Response Facilities. This system should

enhance data collection capabilities.

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The current data and information collection systems appear to be adequate

l for the evaluation of unplanned reactor trips. The licensee is considering

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! replacing both the Westinghouse P-250 computer system and the Hathaway SOE

recorder system with more modern equipment to further enhance data and

infonnation collection capabilities.

i The inspector reviewed a report prepared by the licensee's Safety

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Engineering Staff entitled, "An Introductory Report of the North Anna

Reactor Trip Data Base 1981-1984." The report sorted and graphed the

reactor trip data base in an effort to identify primary and secondary causal

factors. It is part of the management effort to reduce the number of

reactor trips per year. The report also provides information useful in

performance of ADM-19.18, Post-Trip Review, in comparing reactor trip events

with previous similar events.

l Interviews with licensee personnel revealed that plant personnel preparing

i and/or reviewing the post-trip documentation were familiar with plant

systems, equipment, and plant operation. Training had been performed and

rescheduled periodically and training records were being maintained.

Procedure review revealed that the procedures provide for review of

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information from the trip and requires comparison with information derived

from normal or expected operations and previous shutdowns from similar

situations. Procedures also require the identification of Post-Trip Review

reports and accompanying data as Quality Assurance (QA) records and for

their storage in Station Records.

Within the areas examined, no violations or deviations were identified.

4 7. Equipment Classification

The licensee was requested in GL 83-28 to confirm that all components of the

reactor trip system whose function is required to trip the reactor are

identified as safety-related on documents, procedures, and information

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handling systems used in the plant to control safety-related activities,

including maintenance, work orders, and parts replacement. In addition, the

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licensee was requested to describe their program for ensuring that all

components of other safety-related systems necessary for accomplishing

required safety functions are also identified as safety-related on

information handling systems used at the plant. The licensee's response to

Sections 2.1 and 2.2 of GL 83-28 gives a detailed description of the program

and procedures for safety-related equipment classification. The inspector

reviewed their response, appropriate procedures, and interviewed responsible

licensee personnel to confirm that the licensee's program for equipment

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classification was adequate and consistent with their response to GL 83-28.

The inspector examined the following procedures and documents:

Administrative Procedure 2.1, Classification of Systems, Components and

Structures, Revision 11-29-84

< Administrative Procedure 4.0, Procurement Document Control, Revision

i 1-10-85

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Administrative Procedure 4.1, Purchase Requisition /0rder Procedures,

Revision 1-18-85

Administrative Procedure 16.4, Maintenance Program, Revision 12-14-83

Administrative Procedure 16.5, Work Requests, Revision 12-11-84

Administrative Procedure 16.6, Marking of Equipment Requiring Mainte-

nance, Revision 12-14-83

Administrative Procedure 16.7, Maintenance Reports, Revision 10-4-84

Administrative Procedure 16.8, Use of Procedures During Maintenance

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Administrative Procedure 16.16, Safety-Related Equipment Failure

Analysis Program, Revision 4-9-85

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VEPC0 Power Station Quality Assurance Manual (P5QAM), Appendix A

Work Orders 019374, 019543, 019561, 019562, 019563 and 019565

Repeat Purchase Requisition No. 0341028

Standard No. STD-GN-0011, Guidelines for Procurement Document Reviews

The inspector concluded through discussions with licensee personnel and by

review of the above procedures and documents that the licensee's program for

equipment classification included the following elements:

Plant and component control for classification of structures, systems,

i and components as safety-related were being implemented.

<

The licensee has developed a program to assure that safety-related or

nonsafety-related maintenance activities are identified during the

planning stage.

Personnel participating in activities impacting safety-related

structures, systems, and components were aware of the appropriate level

of QA controls.

Written directives assigned principal responsibility for satisfactory

completion of procurement and maintenance activities associated with

safety-related structures, systems and components.

Personnel performing activities impacting equipment on the safety

listing have received indoctrination and training.

Repairs to equipment to correct failures, malfunctions, deficiencies,

deviations, defective material, and nonconformances were performed,

documented, and reviewed to determine reliability of replacement

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Other details of the inspection are discussed below:

Administrative Procedure ADM-2.1 is the procedure used by the licensee to

determine the safety classification of structures, systems and components at

North Anna. The procedure in conjunction with the PSQAM forms the basis for

the licensee's program for equipment classification as described in their

response to GL 83-28. The licensee uses the procedure in completing work

requests, maintenance work orders, purchase requisitions, purchase orders,

etc., to classify components as safety-related or non-safety related prior

to performing work. The procedure does not identify all safety-related

components and sub-components; however, it delineates criteria for the

proper classification of all safety-related components and sub-components.

The inspector observed that the licensee has established additional

classifications in the procedure for structures, systems, or components

which are not safety-related by the definition of GL 83-28 or 10 CFR 100 but

for management reasons require administrative controls. These classifica-

tions are identified as Administrative Al and A2.

Administrative Procedure ADM-2.1 is reviewed and approved by the SNSOC in

accordance with Administrative Procedure No. 5.4. Additional changes to the

procedure require the same level of review and approval. The procedure

also provides for evaluations to be performed by the STA to reclassify plant

systems, as safety-related or nonsafety-related. The evaluations are

documented on Equipment Classification Requests and are reviewed by both the

Superintendent of Operations and SNSOC. Upon approval by SNSOC the equip-

ment classification requests will be incorporated into the procedure as a

procedure revision.

The inspector reviewed Administrative Procedure ADM-2.1 and verified that

the reactor trip breakers and bypass breakers of the reactor-trip system

were included in the classification list as safety-related.

The inspector also determined that the licensee stamps corrective mainte-

nance, surveillance, and calibration procedures as safety-related or

nonsafety-related.

During the entrance meeting, the licensee informed the inspectors that a more

detailed listing of safety-related components will be developed and that the

schedule for completion of the safety list will be submitted to NRC by

July 1, 1985. This schedule is in accordance with the licensee's response

to GL 83-28, dated February 8, 1985.

The inspector discussed with the licensee their procedures for processing

work requests, work orders, purchase requisitions, engineering work

requests, purchase orders, and trending reports. Samples of documents were

also examined to verify that documents were properly classified and approved

as required by procedures. Several deficiencies were identified and are

discussed below:

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j a. Purchase Requisition Development and Processing

i* Discussions with the licensee concerning the processing of Repeat

Purchase Requisition No. 0341028 revealed that the part number on the

purchase requisition was revised based on a verbal conversation with

i the vendor. The part number was originally identified as P/N-KRP11DG

and the vendor states that the new part number is P/N-@PA11DG. The

4 licensee indicated that their procedures require the vendor to submit

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all - technical information on components they are quoted in the bid

which are different than what is identified in the request for bid. In

3 this case the vendor failed to provide this information; therefore, a

telecon between the licensee and the vendor was held to determine if

this change affected the equipment. The vendor at this time infonned

the licensee that the change was only internal to the vendor's organi-

zation. Subsequently, the Purchase Requisition was revised and

reapproved by both Site Engineering and Quality Control (QC). The ,

inspector informed the licensee that the purchase requisition should

not have been revised until appropriate documented evidence had been

received from the vendor. The licensee committed to incorporate in

Purchase Order No. P.O. NS12523 a requirement that the vendor must

provide documentation certifying that the part number change is only a

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change in the vendor's organization and not a change in manufacturing

or design. This matter is unresolved until documentation is provided

by the vendor to attest to the reasons for the change in part numbers.

This item is identified as Unresolved Item 338, 339/85-11-03, Review

Licensee Methods for Revising Purchase Requisitions.

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b. Work Requests and Work Order Processing

L -The licensee is developing extensive changes to Administrative

i Procedures 16.5 and 16.7. These procedures control the identification,

planning, approving, and documenting of maintenance work activities.

The licensee recently converted to a computerized Work Planning and

, Tracking System (WPTS) for processing work orders. In reviewing these

procedures and document packages associated with these procedures, the

inspector observed that Work Order (WO) records were annotated with

procedures different than what was originally specified on the Work

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Order Form by ' the planner. In addition, the Work Order Form had a

column titled " procedure used" indicate by circling Y or N. This

column was not addressed in the procedure. The licensee indicated that

, the Work Order System is new and the procedures may require some

! revising to clarify some items identified on the WO Forms. However,

! the licensee indicated it is not a procedure requirement that the craft

must use the procedure referenced on the WO. The inspector acknow-

ledged the licensee's comments and informed the licensee that to

eliminate confusion -on how the WO is to be implemented that Proce-

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dure 16.7 should be revised indicating how the WO is to be used. The

licensee indicated that this concern would be reviewed and appropriate

i procedure revisions will be made. An additional concern was identified

to the licensee regarding WO processing. On W0s that cannot be worked

due to lack of parts or plant configuration the WO packages are

i retrieved from the craft foreman and stored in a holding file in the

Planning Department until the maintenance can be rescheduled. The

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inspector informed the licensee that this flow path for W0s is not

discussed in Administrative Procedure 16.7 and may result in work being

performed to a superseded procedure which is contained as part of the

original WO package in the file. These concerns were identified to the

licensee as Inspector Followup Item 338, 339/85-11-05, Work Order

Processing.

c. Trending of Safety-Related Failures

The licensee has developed a program to trend failures of safety-

related equipment. The procedure that controls this activity is

Administrative Procedure ADM-16.16, Safety-Related Equipment Failure

Analysis Program. This procedure was first issued on January 31, 1985,

as a result of an NRC violation. Administrative Procedure 16.16 states

that the trending evaluations will be performed by Safety Evaluation

Staff (SES) and findings will be reported to management. The inspector

discussed the trending program with SES and Planning personnel.

Discussions revealed that no failure trends have been identified to

date. However, this program is new and the trending file is still

being developed.

To verify that the licensee was implementing the requirements of the

above procedure the inspector examined trending data submitted to SES

by the Planning Department. One minor discrepancy was identified while

examining the Equipment History Reports. Administrative Procedure

ADM-16.16, paragraph 4.3, requires the Planning Supervisor to search

the WPTS monthly for safety-related component maintenance and send the

results to SES, along with corresponding copies of Equipment History

Forms. In reviewing the monthly printouts, the inspector selected Work

Order No. 019409 for examination to determine if all the appropriate

information required by Administrative Procedure 16.16 had been sent to

SES by the Planning Department. Discussions revealed that an Equipment

History Form was not prepared for Work Order No. 019409 because the

Work Order was processed as an Emergency Work Order in accordance with

Procedure ADM-16.5, Work Requests (Revision 12-11-84), paragraph 3.4,

which does not require that an Equipment History Form be generated.

The licensee indicated that this was an oversight and had been

identified on the proposed revision to Procedure ADM-16.5. The

inspector reviewed the procedure mark-up prepared by the Planning

Supervisor and confirmed that requirements would be added to the

procedure for initiating an Equipment History Record when processing

Emergency Work Orders. The licensee committed to have the procedure

revised by April 30, 1985. This item was identified to the licensee as

Inspector Followup Item 338, 339/85-11-06, Review Changes In Procedure

ADM-16.5 for Processing Emergency Work Orders.

Within the areas examined, no violations or deviations were identified.

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8. Vendor Interface and Manual Control

The inspector reviewed the licensee responses to GL 83-28 which described

their program for vendor interface and control of vendor and other industry

technical information. Their responses and pertinent information on vendor

interface activities are discussed below.

The licensee's response dated November 4,1983, stated that the licensee was

reviewing thair evisting vandor pengram pencodures and were revisina as

necessary. The licensee also stated that a comprehensive program would be

developed to ensure that vendor information is current, complete and

controlled at North Anna 1 and 2. A subsequent licensee response dated

February 8,1985, presented an update on the vendor interface activities.

Schedules showing the status of vendor interface and manual control were

also presented. The licensee's letter dated April 1, 1985, stated that they

had obtained from Westinghouse (W) (vendor for the DB-50 shunt trip attach-

ments) the Equipment Qualification Data Test Reports for the DB-50 shunt

trip attachment and shunt trip panels and that the equipment met IEEE-323-

1974 and IEEE-344-1975 as specified in WCAP-8587. Additional information

concerning recommendations from the Westinghouse Owners Group (WOG) on the

periodic maintenance activities on the reactor trip breakers had been

evaluated and a response submitted to NRC by letter dated March 29, 1985.

Applicable maintenance and inspection activities recommended by WOG had been

incorporated into the periodic maintenance procedures. Based on the above,

the licensee is contacting the vendor supplying the reactor trip system

equipment, is evaluating the vendor recommendations, and is utilizing

applicable technical data in plant procedures.

The inspector reviewed the licensee's procedures, vendor technical manuals,

vendor correspondence, licensee inter-departmental correspondence, and other

documents associated with vendor interface and control. This included

technical information received from vendors, other licensees, industry

sources, NRC, and the Institute of Nuclear Power Operations (INP0). The

review revealed that the procedures were consistent with the licensee

submittals. The procedures established controls to help assure that vendor

and other technical information were obtained, kept current, distributed,

evaluated, and utilized in plant operations, maintenance, and testing

activities. Documents reviewed are discussed in the following paragraphs.

a. Administrative Procedure 6.18, Control of Vendor Manuals, Vendor Files

and Interface, dated October 25, 1984. This procedure described the

methods used to control vendor interface and vendor technical documents

pertaining to safety-related equipment, materials, and services. The

procedure also assigned responsibilities to certain groups and

individuals for monitoring industry wide reports, receiving and

tracking technical information, resolution of technical problems, and

controlling the distribution, changes to, and filing of vendor and

industry technical informa tion. Examination of documents and

discussions with cognizant personnel verified that these activities

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were being performed as specified in the procedure. Supporting

documents examined are listed below:

Index of Controlled Vendor Manuals which cross indexes vendor,

manual number, equipment specification, and if safety-related.

The index consists of two books, one includes W Vendor Manuals and

the other includes all other vendor manuals which are listed by

vendor name.

Standard licensee letter to vendors requesting latest technical

information on equipment purchased for North Anna. Discussions

revealed that vendor response was about 40%; therefore, other

followup will be initiated.

Response from Harris Instruments, Inc. to licensee dated March 5,

1985

Card Indexing System that keeps track of the latest vendor manuals

and who a copy has been distributed to.

W Technical Bulletin (TB) 84-06, Reduced Auxiliary Feedwater Flow

Rate, dated July 19, 1984

)[ TB 84-08, Inverter Capacity Connections, dated March 19, 1985

W TB 84-10, Internal Short in Barton Equipment, dated February 27,

T985

W tbs 84-11 and 85-01 thru 06 concerning Static Inverter and

Reactor Coolant Pumps

)[ TB 84-09,-Seal Table Leaks, dated October 19, 1984

Licensee's Evaluation, Changes to MMP-C-RC-9, and QC Comments on

Procedure Change resulting from )[ TB 84-09.

W Instruction Book 24-Y-8645 dated December 1972 for Reactor Trip

Twitchgear. This book also contained: Revisions dated June 1981

and February 1984; DCP 84-05; W TB 83-03; NRC Bulletin 83-01;

letters from W; W TB 83-02; and other current information. This

examination v'eriTied that the vendor manual was being kept

current.

WOG Maintenance Program (WOG 83-296) for 08-50 Breakers

Manual 9002-VLM-001, Reactor Vessel Level Monitor, Volume 2, which

included the manufacturer's descriptive literature for assemblies

used in the Vessel Level Monitoring System

WCAP - 8330, )[ ATWS Analysis

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Instruction Manual for W Control Valves

b. Document Control Manual (DCM) Procedure DCM-75, Procedure for Vendor

Manuals and Files dated January 3,1985. This procedure established

guidelines for processing and distribution of vendor manuals and files.

This procedure provides for the control of new manuals received on

site, technical manuals received at schools, revisions to old manuals,

assignment of manuals and responsibilities for updating, stamping as

safety-related, upgrading manual index books. and recording of

information on the Document Record Cards. DCM-75 also has several

attachments which are used to transmit information and to further

control the review, revision, and use of the manuals and files.

Attachment 6, Safety-Related Equipment List, to DCM-75 includes a

listing of all plant safety-related systems, associated components,

plant identification number (Mark No.), manufacturer's name, equipment

specification number, NPRDS ID number, and individual manual identifi-

cation number. Review of associated documents and observation of

ongoing activities in the Station Records area revealed that vendor

manuals and other technical information are being processed and

controlled as specified in DCM-75. The Station Records Group plans to

perform a bi-monthly audit of manual control activities. Several of

these audits have been done on W manuals and the licensee stated that

the audit of other vendor manuals will begin soon. Discussions were

held concerning the merits of DCM-75, particularly Attachment 6, which

provides an excellent reference check sheet for the safety-related

technical manuals, and the advantages of including a cross reference to

plant proceduresapplicable to each technical manual.

Other licensee ongoing activities related to vendor interface and

manual control are discussed below:

Vendor History Files have not yet been established. Station

Records is following this program and stated that vendor files

would be generated, where manuals were not available, to include

technical information.

Licensee has obtained a technical manual index from W and is in

the process of checking W_ index against the Station Records Index.

Licensee is presently evaluating Nuclear Utility Task Action

Committee (NUTAC) program and expects to have their procedures

reviewed by July 1985.

North Anna is participating in the INP0 SEE-IN and NPRDS programs.

c. Administrative Procedure ADM-16.14, Commitment Tracking System (CTS)

Program, dated October 25, 1984. This procedure established a method

to help assure that all vendor technical manuals, vendor recommenda-

tions, and other technical information from other sources (NRC, INP0,

vendors. WOG) are properly distributed, reviewed, documented, and

corrective actions incorporated into applicable plant procedures and/or

_. ._. . . _ _

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activities. This procedure assigns the overall responsibilities for

the administration of the procedure to the Site Licensing Coordinator.

The Licensing Coordinator assigns a CTS outstanding item (0I) number to

each document and assigns responsibilities for resolving the out-

standing item. These data are entered on an 0I Form and also into the

computer for tracking. Computer printouts listing OIs are sent to each

department bi-weekly, and a listing of delinquent items or near

completion dates are issued daily. Corrective actions are reviewed by

the Licensing Coordinator and all documents are treated as QA records.

Implementation of the above verifies the commitment made in the

licensee's response to GL 83-28 to strengthen his record keeping and

commitment tracking system.

d. Licensee Audit Activities on GL 83-28

Discussions were held with QA personnel concerning their activities

associated with GL 83-28 and applicable audit reports were reviewed.

Results of the above revealed that QA has been active in the majority

of the activities concerning the reactor trip breakers. They had  ;

attended meetings at the corporate level concerning the periodic

testing and preventative maintenance program for the 08-50 breakers.

Other activities performed by the QA/QC Department included the

following:

(1) Review of WOG Breaker Report No. WOG 83-296

(2) Review of EMP-P-EP-8 and 8A, Reactor Trip Breaker Maintenance

(3) Review of October 1,1984, letter on development of Nuclear System

"Q" List

(4) Developed RTS audit checklist in conjunction with Surry Plant

(5) Performed Audit No. N-83-39 dated September 19, 1983, on ATWS

activities

(6) QC Group performs surveillances on testing and maintenance

operations

(7) Performed Audit No. N 84-20, Station Records, dated July 30, 1984

(8) Reviews changes to technical manuals

(9) Reviews technical bulletins and responses

(10) Performed a comparison of field copies of manuals against Station l

Record's master copies

(11) Audit of Technical Specification requirements

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The inspector noted that the QA Department had not been active in

reviewing Post-Trip Review Data prior to restart, nor in the review of

Administrative Procedure 19.18, Post Trip Review, dated January 10,

1985. Licensee personnel stated that QC (a part of the QA department)

reviewed the procedures. Also, the QA Department has not performed an

audit of RTS modification done on Unit 2. Licensee personnel stated

that they are planning to perform a complete audit of work performed on

both units after all of the modifications are complete.

The QA Group has not audited Post-Trip Review Data Packages to deter-

mine if all procedures and activities associated with Post-Trip Review

were implemented. There is no regulatory or licensee procedure

requirement that requires QA to audit data packages.

The QA Group does not audit electrical maintenance-procedure completed

data packages; however, QC signs off on Hold Points.

The QA staff does not review completed data sheets for reactor-trip

breaker test data. The licensee stated that the QC sign offs are the

same as QA. The inspectors disagreed with this concept, even though

both QA and QC personnel report to the QA Manager. For further

discussion, see paragraph 8.e.(7).

e. Other Documents Reviewed

Other documents reviewed to determine if vendor manuals and other

technical information and recommendations were being incorporated into

plant procedures are listed below:

(1) PT-36.6, Reactor Protection Response Time Testing - U.V. Coil,

Breakers, and Gripper Coil, Rev.1, dated May 8,1981. This

procedure had referenced TS, W, and S&W Drawings.

(2) EMP-P-EP-8 dated May 22, 1984, Reactor-Trip Breaker Preventative

Maintenance for Breaker 1-RT-A. This procedure referenced Vendor

Manual I.B. 24-Y-8645, Reactor Trip Switchgear Maintenance

Program (10/14/83)

(3) EMP-P-EP-8A dated March 25, 1985, for Breaker No. RTA Serial

No. 124Y8646B

(4) Licensee intra-office correspondence (June 22 and July 13,1984)

concerning review of WOG recommendations on RTS tests and

maintenance activities

(5) Bi-monthly audit of vendor manuals by Station Records dated

March 25, 1985

(6) Administrative Procedure ADM-5.3, Review of Procedures, dated

October 25, 1984

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(7) Administrative Procedure ADM-5.4, Processing New and Revised

Procedures, and Deletion of Procedures, dated March 14, 1985.

This procedure establishes guidelines for processing and approval

of procedures. Paragraph 2.4 of the procedure specifies that QA

will review; however, Attachments 1 and 3 to the procedure specify

" Review by Supervisor of Quality Control". Due to some of the

problems found during procedure and data review, the inspectors

discussed the above discrepancies with licensee management. As QA

review and siepoff is specified in several paragraphs (3.2.8 and

3.2.9 are examples) of this procedure, the inspector requested

that the procedure be reviewed, definitions of QA and QC be

stated, and that QA and QC responsibilities associated with

procedure and Performance Test (PT) data review be specified.

This is Inspector Followup Item 338, 339/85-11-07, Clarification

of QA/QC Responsibilities in Procedures.

Within the area examined, no violations or deviations were identified.

9. Post-MaintenanceTesting(Reactor-TripSystemComponents)

The inspector reviewed the licensee's post-maintenance testing procedures

and ' activities to determine if the licensee's response to GL 83-28 were

being implemented at North Anna Power Station. The inspector examined

procedures, examined completed maintenance work orders, reviewed test

procedures and observed equipment used in the maintenance and testing of the

Reactor Trip Breakers (RTBs) to detennine the adequacy of the licensee's

post-maintenance test program. The inspector interviewed pertinent licensee

personnel to determine their knowledge and implementation of the program.

The findings of the inspection are as follows:

a. The licensee followed Electrical Maintenance Procedure EMP-P-EP-8,

" Reactor Trip Breaker," Revision 6, in the maintenance of the reactor

trip breakers RTA and RTB, and the bypass breakers BYA and BYB. The

maintenance per this procedure was performed during fuel load on an

18-month cycle. To meet the requirements of GL 83-28, the licensee

initiated Electrical Maintenance Procedure EMP-P-EP-8A, " Reactor Trip

Breaker 6 Month Maintenance," Revision 0, dated March 25, 1985. This

new maintenance procedure was developed to facilitate testing every six

months while the unit was on line; however, the original procedure.

EMP-E-EP-8, was retained for the 18-month maintenance performed during

fuel load.

These two procedures outlined a complete maintenance of the RTBs. They

list the references for use during maintenance; they note the prerequi-

sites of the system prior to start of maintenance work; they describe

the tools and special equipment needed, and they state the initial

conditions of the power plant itself. The procedures cover a step-by-

step maintenance of the RTB. Sign off spaces are provided to the left

of each paragraph for the person performing the maintenance to place

his initials. QC hold points are similarly signed off to the left of

each paragraph. Each of the procedures has three attachments:

- Attachment I has figures and a table

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- Attachment 2 has a data package to record the measurements

taken in the maintenance

- Attachment 3 has more figures / tables.

Although the procedures appeared to be technically adequate, a

detailed review revealed several shortcomings and discrepancies which

have the potential for misinterpretation and inadequate implementation.

A further revis of VEPC0's QA Program revealed that VEPC0's Quality

Assurance Program requires that procedures, instructions, and drawings

be reviewed to assure they are adequate and contain quality require-

ments. Administrative Procedures 16.8, 5.3, and 5.4 were established

to implement the above requirements; however, as mentioned above and

stated below, the review of Electrical Maintenance Procedures

EMP-P-EP-8 and 8A by the licensee was administratively inadequate. This

constitutes Violation No. 50-338, 339/85-11-01, Inadequate Review of

Procedures for Reactor Trip Breaker Maintenance. Examples of procedure

inadequacies are listed below:

(1) The title on the cover sheet of EMP-P-EP-8 was not complete. It

did not identify the procedure for use as either the six-month-

maintenance or the 18-month maintenance. An examination of the

companion procedure EMP-P-EP-8A clearly identified it as the

procedure to follow in the six-month maintenance.

(2) The sketches in the procedure were of a poor quality and they were

hard to read.

(3) The sketches did not match the written text. For example,

paragraph 7.3.4 called for checking the main contact pressure, gap

"G", as per Figure 1, Attachment 1. A search for the subject

Figure in the procedure was made. Figure 1 could not be found

anywhere in the entire procedure. There was, however, a Figure 3

on Page 1 of Attachment 1, showing the gap "G" in question.

Numerous other examples of mislabeling of figures, or of non-

labeling of figures were found throughout the entire procedure.

(4) The table on page 7 of Attachment 1 was misleading. It lacked a

title describing the table as a list of retaining rings. The

second item on the list occupied two different lines, which could

lead to the erroneous conclusion that it, in fact, represented two

different items.

(5) Several typographical errors exist in both EMP-P-EP-8 and

EMP-P-EP-8A.

(6) The inspector noted that paragraph 7.3.2 of both procedures stated

that an electrician was to hold back the Undervoltage Trip Attach-

ment (UVTA) reset lever by means of a wire; however, the practice

at North Anna was to hold the reset lever back by tying the wire

to a stud in the vicinity of the UVTA. It was noted that no

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deviation form was initiated on this step in the data taken in

May 1984 and March 1985 and the procedures have not been changed

to reflect the method used to restrain tha reset lever.

The above violation is similar to Violation 336/94-37-03 dated

November 13, 1984; therefore, it appears that the licenzee's corrective

actions as stated in VEPC0 response dated December 12, 1964, did not

assure that all current procedures were adequately reviewed.

b. Periodic Test (PT) Procedures 1-PT-36.12.1 (six-month schedule) and

1-PT-36.12.2 (18-month schedule). These procedures were the

controlling documents for the reactor-trip breakers maintenance. In

each of these procedures, the corresponding EMP was slated to be

performed as part of the Periodic Test. The data generated in the

Electrical Maintenance Procedure (EMP) were incorporated on a summary

sheet in the pts and trended. The trending of parameters from

reactor-trip breaker maintenance was started at North Anna with the

availability of data collected during the May 1984 maintenance. The

following five parameters are being trended at North Anna.

1) Pre-cleaning Breaker Insulation Resistance (6 month)

Post-cleaning Breaker Insulation Resistance (6 month)

Trip Force (6 month)

UVTA Dropout Voltage (6 month)

5) Breaker Response Time (18 month)

The trending program appears adequate.

c. A typographical error was also identified in the data package for

Performance Test 1-PT-36.12.1 dated March 31, 1985. The inspector

observed that the serial number shown for Reactor Trip Breaker A was

wrong. The incorrect number was given as 1224Y8646B. The correct

number is 124Y86468. The licensee was informed of this discrepancy and

committed to have the discrepancy corrected.

10. Post-Maintenance Testing (All Other Safety-Related Components)

a. Inability to Retrieve Work Package

The inspector requested five maintenance work order packages on

safety-related components from the licensee; however, the licensee

could only retrieve four of the five work orders requested. The

licensee searched for the missing package (No. 8736, Mark 02-QS-P-2A)

for four days, but was unsuccessful in tracking down the document. The

licensee's inability to retrieve Maintenance Work Order No. 8736 in a

timely manner constitutes Unresolved Item 50-339/85-11-04, Retrieval of

Maintenance Work Order No. 8736.

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b. Failure to Follow Procedures

The four work order packages retrieved by the licensee were examined by

the inspector to determine if the work had been performed and

documented as required by procedures. Three of the work packages were

found acceptable. Examination of Work Order Package No. 5901009344,

Repair and Testing of Containment Isolation Check Valve, dated July 17,

1984, revealed that all requirements of Mechanical Maintenance Procedure

MMP-C-GV-1.2 were not properly signed off as required by Administrative

Procedure 16.8, Use of Procedures During Maintenance, dated July 28,

1984. This procedure specifies requirements for the preparation and use

of maintenance procedures. Paragraph 3.5 specifies that all maintenance

procedures shall be provided with signoff blocks. Paragraph 5 of this

procedure specifies that the master copy shall be kept up-to-date and

shall be fully initialed. Contrary to the above, signoff steps 3.1,

6.2 and 9.1 in Mechanical Maintenance Procedure MMP-C-GV-1.2 were not

properly initialed. These three procedural steps are discussed below:

(1) Step 3.1 of MMP-C-GV-1.2 required the person performing the work

to initiate a work order. The inspector noted that at that point

in the test procedure, the work order had already been initiated.

It had also been routed through Planning and Scheduling, the shop

foreman, and the shift supervisor, and it had been placed in the

hands of the performing tradesmen. However, the person performing

the work signed this step off, and in so doing he attested that he

had initiated a work order as directed.

(2) Step 6.2 of MMP-C-GV-1.2 required the person performing the work

to verify the isolation of the valve, the presence of tags, and

that the system was in proper condition. This step was not signed

off; therefore, it is not known whether the requirements were

completed.

(3) Step 9.1 in the acceptance section of MMP-C-GV-1.2 was not signed

off by the person performing the work. Signing this statement

attested to the fact that all problems had been satisfactorily

corrected and that post maintenance checkout had been performed.

Another concern was that the work order package had been accepted

by three subsequent levels of review: the foreman, the operations

department, and QA. The procedures are not explicit on what these

three reviews are to accomplish.

The failure to properly signoff work as completed constitutes Violation

50-338/85-11-02, Failure to Follow Procedure During Performance of Work

Order No. 9344.

11. Surveillance Testing

The inspector reviewed Periodic Test No. 2-PT-36.1, " Reactor Protection and

ESF Logic Test," for Unit 2. This unit had been retrofitted with a Reactor

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Trip Breaker Shunt Trip Attachment (Unit 1 modification is planned for late

1985). This surveillance test was performed on a 31-day rotating basis to

each RTS system. The test took about 90 minutes to perform and it was

conducted by a team of three to four instrument technicians (including a

leader) and supported by an operator and an electrician. The test was

conducted while the unit was on line.

The inspector found that the test procedure was detailed and appeared to be

a comprehensive test of tha Raartor Trip Breaker (PTB) system and its

associated logic. Interviews revealed that the instrument technician was

knowledgeable of the test procedure and examination of test data revealed

that the test met the requirements of GL 83-28 in the area of reliability of

the Automatic Actuation of Shunt Trip.

Other procedures and documents reviewed are listed below:

Electrical Maintenance Procedure EMP-P-EP-8, " Reactor Trip Breaker,"

Revision 6.

Electrical Maintenance Procedure EMP-P-EP-8A, " Reactor Trip Breaker 6

Month Maintenance."

Periodic Test No. 1-PT-36.6, " Reactor Protection Response Time Testing

- U.V. Coil, Breakers and Gripper Coil," Revision 2.

Periodic Test No. 1-PT-36.12.2, " Reactor Trip Breaker and Bypass

Breaker Refueling Inspection and P.M."

Periodic Test No. 1-PT-36.12.1, " Reactor Trip Breaker and Bypass

Breaker Maintenance."

Periodic Test No.1-PT-36.1, " Reactor Protection and ESF Logic Test,"

Revision 20.

Electrical Maintenance Procedure EMP-C-TSR-1, " Troubleshooting and

Repair of Electrical Circuits," Revision 2.

Temporary Procedure TEMP-C-M0V-1, " Adjustment of Torque Switches on

M0Vs," expires January 1, 1985.

Mechanical Maintenance Procedure MMP-C-GV-1.2, " Check Valves in

General," Revision 1.

Periodic Test No. 2-PT-36.2, " Reactor Protection and ESF Logic Test,"

Revision 15.

Periodic Test No. 2-PT-36.6, " Reactor Protection Response Time Testing

- U.V. Coil, Breakers, and Gripper Coil, " Revision 3.

Electrical Maintenance Procedure EMP-C-MOV-1, " Troubleshooting and

Repair of Motor Operated Valves," Revision 1.

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Administrative Procedure ADM-16.7, " Maintenance Reports," dated

October 4, 1984.

Administrative Procedure ADM-5.4, " Processing New and Revised

Procedures, Deletion of Procedures," dated March 14, 1985.

Work Order No. 5901013671, " Reset Torque Switch", dated August 31, 1984

Work Order No. 5001017746, "Arijust Pecking on Valves," dated

December 18, 1984

Work Order No. 5901014394, " Clean Contacts on K611 Relay," dated

September 13, 1984

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