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- C January 6, 1987 7 j,\\',1 N NSSP-NV-701 Mr. N. Merriweather U. S. Nuclear Regulatory Commission Region 11 Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323
Dear Mr. Merrtweather:
SUBJECT:
V0GTLE ELECTRIC GENERATING PLANT, UNIT 1 (DRAFT)
INPUT FOR NRC INSPECTION REPORTS NUMBERS86-135 AND 86-062 Enclosed is the LLNL input for the Vogtle Electric Generating Plant, Unit 1, NRC Inspection Reports Nos.86-135 and 86-082 for the December 15 through 19, 1986 period.
Any changen you may want or need, let me know and I will try to accomodate them.
Sincerely, Paul M. Chan 702-295-2411 (comm.)
575-2411 (FTS)
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V0GTLE ELECTRIC GENERATING PLANT, UNIT 1
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ATWS INSPECTION REPORT <
JANUARY 6, 1987 I.
APPLICANT'S PERSONNEL CONTACTED (404) 724-8114 t
M. Bennett, Electrical Foreman X-3218 C. Lee, Test Supevisor X-3268 D. Wright, Secretary X-3492 D. Hudson, Compliance X-3772 P. Kochery, Engineer X-3132 H. Davis, Maintenance Engineer X-3465 R. Hendrix, Preventive Maintenance Development Group X-3441 s
R. Wyne, Preventive Maintenance Coordinator X-4300 W. Pannell, Electrician X-3477 D. Hutchins, Electrician X-3477 B. Hall, Electrician X-3447 C. Coursey, Electrical Supervisor X-3476 M. Ray, QC Inspector X-3207 H. Jayne, Maintenance Supervisor X-3177 i
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II.
APPLICANT'S PROCEDURES AND DOCUMENTS REVIEWED A.
Vogtle Electric Generating Plant Nuclear Operations Procedure No. 27765-C, " Westinghouse Type DS-416 Circuit Breaker Maintenance,"
Revision 5, April 18, 1986.
B.
Vogtle Electric Generating Plant Nuclear Operations Procedure No. 27731-C, "450 Volt Switchgear Cubicle / Transformer Maintenance,"
Revision 1, November 8, 1986.
C.
Vogtle Electric Generating Plant Nuclear Operations Procedure No. 27767-C, " Reactor Trip Breaker Switchgear Inspection and Maintenance," Revision 0, December 2, 1985.
D.
Vogtle Electric Generating Plant Nuclear Operations Procedure No. 00052-C, " Temporary Changes to Procedures," Revision 3, November 4, 1986.
E.
Vogtle Electric Generating Plant Nuclear Operations Procedure No. SUM-14, " Release to Operations," Revision 3, November 24, 1986.
c III. POST-MAINTENANCE TESTING: REACTOR TRIP CIRCUIT BREAKER The Vogtle Electric Generating Plant, Unit 1, is a Westinghouse pressurized water reactor.
Its daal train redundant reactor trip circuit breakers RTA and RTB, backed-up by bypass circuit breakers BYA and BYB, are Westinghouse DS-416 type circuit breakers. The applicant, Georgia Power Company, has responded on November 8, 1983, to Generic Letter 83-28.
In that and subsequent responses the applicant has committed themselves to the development and implemen-tation of procedures to assume the safe and reliable operability of the reactor trip circuit breaker thrcugh a program of maintenance and post-maintenance testing.
- The inspector verified the applicant's progress by (a) reviewing the applicant's procedures on maintenance and post-maintenance testing, (b) reviewing the applicant's procedures verses vendor's technical manuals, (c) reviewing complete work packages of reactor trip circuit breaker "11titenance taken during the Construction Acceptance Test (CAT),
and (d) observing the performance of the reactor trip circuit breaker maintenance procedure in the field.
l A.
Review of Procedure The inspector reviewed the applicant's procedure on the reactor trip circuit breaker maintenance:
Procedure No. 27665-C, " West-inghouse Type DS-416 Circuit Breaker Maintenance," Revision 5, dated April 18, 1986. The inspector was informed that in April 1986 the applicant performed this procedure for the first time as part of the Construction Acceptance Test on the reactor trip circuit breaker. However, as of the date of the ATWS inspection in December 1986, these reactor trip circuit breakers have not yet been turned over from Test to Operations. The status of these breakers placed them in limbo in a category which does not get regularly scheduled preventive maintenance until they get transferred to Operations.
The inspector noted that:
1.
The procedure has numerous typographical errors, as well as errors of greater gravity, eg., in Section 4.10.3. 125VDC is directed to be applied to the breaker control circuit at terminals 3 and 8.
This was recognized as an error during the CAT performance of this procedure. The correct terminal points for the application of the 125VDC control voltage are terminals 4 and 7.
Several of these errors had been documented in a Temporary Change to Procedure Form during the CAT performance of this procedure. However, the applicant's Procedure No. 00052-C, 1
which governs the generation of the Temporary Change to Procedure Form allows the effectiveness of the temporary changes to lapse after a period of 30 days.
In the case in hand, the changes recorded in the Temporary Change to Procedure Form was recommended for permanent incorporation into the procedure.
This was not accomplished in the 30 days prior to the expiration of the Temporary Change. The inspector followed the modus operandi of the applicant in this matter:
the reasoning that after 30 days the Temporary Change ceased to be effective --
which implied (perhaps incorrectly) that the Temporary Change cannot be used after 30 days.
It was not obvious whether the
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r Temporary Change was not incorporated into the permanent procedure due to its expiration after 30 days, or due to the lack of a review process on the part of the applicant for subject matters that need not have an expiration date.
2.
Ine drawings and diagrams in the procedure are not legible.
Some reproduction of vendor's sketches and diagrams turned out extremely dark, and some reproductions of the vendor's sketches, drawings, and wording turned out with portions or parts missing.
3 Steps in the procedure are out of sequence.
For example, in Section 4.20 the arc chutes and front panel was installed back on the breaker. However, subsequently several measurements of the breaker's UVTA trip force had to be made. These measure-ments cannot be made without removal of the arc chutes and front panel, and there was no step in the procedure calling for their removal prior to these measurements.
4.
Figure 9 in Manual Copy f16 located in the maintenance section was found to be missing. This same Figure 9 was, however, found properly in place in Manual Copy #12. These manuals are controlled sets of procedure and they shall all be kept up-to-date and identical.
B.
Review of Applicant's Procedures Verses Vendor's Technical Manuals The applicant's procedures reference Section 6.0 is not complete and up-to-date.
The inspector noted that the vendor's maintenance manual for the DS-416 Reactor Trip Breaker, Revision 0, dated October 1984, as well as other vendor's technical bulletins, on.o L
e Reactor Trip Circuit Breakers is not listed as a reference in the applicant's procedure. This is not construed to indicate that the applicant has not reviewed or incorporated the subject vendor bulletins into the Reactor Trip Circuit Breaker Maintenance Procedure. The inspector noted, on the other hand, the Reactor Trip Circuit Breaker Maintenance Procedure includes the elements stated in the applicant's response, dated August 1, 1985, in which the applicant agreed to abide by an NRC follow-up letter to GL 83-28.
Although the NRC follow-up letter mentioned the vendor's manual and the elements recommended for incorporation in the Reactor Trip Circuit Breaker Maintenance Procedure, the applicant's response of August 1, 1985 did not mention the vendor's manual, but nevertheless includes all the elements recommended for incorporation to the maintenance manual.
In response to the inspector's questions, the applicant stated that its personnel had received the subject vendor manual but it did not get formally processed into the document control system.
An item by item check of the applicant's procedure versus the commitments made in the applicant's response of August 1, 1985, showed that they agree in all areas of concern.
In this regard the inspector considered the applicant's procedure not lacking in vendor referenced information but only lacking in quality of rcrmat, and lacking in a well thought out sequence of performing the steps in the procedure.
C.
Review of Complete Work Packages (CAT Data)
The applicant performed the procedure on Reactor Trip Circuit Breaker Maintenance for the first time in April 1986. The inspector was informed that the Construction Acceptance Test Group chose to __
use the procedure on Reactor Trip Circuit Breaker Maintenance instead of writing a procedure for the CAT's purpose. A review of the test data showed that several steps such as Sections 4.28.4b, 4.27.3d, 4.26.2, and 4.26.3 were marked "not applicable".
No reasons were given for not performing these steps. The inspector therefore considered the CAT data incomplete and the CAT performance of the reactor trip circuit breaker inadequate.
D.
Observation of Reactor Trip Circuit Breaker Maintenance The inspector observed a demonstration by the applicant's main-tenance personnel of the reactor trip circuit breaker maintenance.
RTA was selected arbitrarily. As the breaker was racked out the inspector noted that it was dusty. In the shop, under a well lighted high bay, the inspector noted that the dust was thick and appeared to cover the entire base plate.
A review of the tools and measuration equipments showed that they were adequate. The applicant can benefit from having special go-no-go gauges made for the specific gap measurements instead of relying on stubby shim gauges.
The applicant's electricians and QC inspector showed great interest and initiation in the task. Although some of the personnel had participated in the CAT performance of this procedure, the group as a whole experienced extensive uncertainties in the performance of this procedure.
It appeared to the inspector that the applicant does not have knowledgeable and/or experienced personnel in the technique of Reactor Trip Circuit Breaker Maintenance. The inspector recommended an immediate and thorough performance of the
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C entire procedure on all the reactor trip circuit breakers in the plant as well as the two spare circuit breakers that would arrive on site in 1987. The applicant stated at the exit meeting that it would be performed by initial criticality. This was left as an Inspector Follow-up Item.
The inspector discussed the trendir.g of parameters with the applicant. Due to lack of time this was left as an Inspector Follow-up Item.
The inspector also requested for an opportunity to review and evaluate other safety-related items for maintenance and post-maintenance testing. The applicant ran out of time to provide the inspector with any meaningful item in this area for review and evaluation. The applicant did provide the inspector an opportunity to observe the alignment on a safety-related pump. This opportunity was not pursued by the inspector for several reasons:
the inspector was posed this opportunity at a time when the activity on the reactor trip circuit breaker maintenance was going on; the inspector felt that trading the observation on the circuit breaker for something that may not be better set up could not be advisable.
CONCLUSION The inspector concluded that the maintenance procedure on Reactor Trip Circuit Breakers at the Vogtle Electric Generating Plant is inadequate and its review was also inadequate. Further the applicant failed to incorporate the lessons learnt at the first performance of this procedure into refining this procedure. The inspector noted that the breakers themselves were dirty which has the potential of violating the storage requirements of safety-related equipment.
This could have for reaching generic implications. Lacking a crew that is experienced and knowledgeable in the maintenance and post-maintenance testing of these reactor trip circuit breakers the inspector concluded that it is important for the applicant to begin a series of complete maintenance and train a dedicated crew to the maintenance and post-maintenance testing of these reactor trip circuit breakers.
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Mr. N. Merriweather U. S. Nuclear Regulatory Commission Region II 1
Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 I
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