ML20128L002

Insp Repts 50-324/85-14 & 50-325/85-14 on 850520-24.No Violation or Deviation Noted.Major Areas Inspected:Licensee Response to Generic Ltr 83-28,including post-trip Review, Equipment Classification & Vendor Interface

ML20128L002
Person / Time
Site:	Brunswick
Issue date:	06/19/1985
From:	Conlon T, Merriweather N, Pierson R, Whitcomb H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128K965	List: ML20128K960 ML20128L002
References
50-324-85-14, 50-325-85-14, GL-83-28, NUDOCS 8507110190
Download: ML20128L002 (16)

See also: IR 05000324/1985014

Text

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p rec UNITED STATES

oq'o NUCLEAR REGULATORY COMMISSION

[' o REGION 11

g j 101 MARIETTA STREET,N.W.

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c AT LANTA, GEOR GI A 30323

%...../ .

Report Nos.: 50-325/85-14 and 50-324/85-14

Licensee: Carolina Power and Light Company-

411 Fayetteville Street

Raleigh, NC 27602

Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62

Facility Name: Brunswick 1 and 2

Inspection Conducted: May 20-24, 1985

Inspectors: . p - d ~ /7 ' ff

N. Merriweather, Team Leader Date Signed

R. Pierson

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Date Signed

H. Whitcomb~

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Date Signed

Consultant: P. M. Chan, Lawrence Livermore National Laboratory

Accompanying Personnel: T. E. Conlon

Approved by: pp & d '/7' W

T. E. Conlon, Section Chief Date Signed

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This special, announced inspection entailed 130 inspector-hours on site

concerning licensee response to Generic Letter (GL) 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; surveillance and post-maintenance testing;

and reactor trip system reliability.

Results: No violations or deviations were identified.

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• E. A. Bishop, Assistant to General Manager

• J. W. Chase, Manager - Operations

• J. D. E. Jeffries, Manager - Corporate Nuclear Safety

• L. E. Boyer, Director - Administrative Support ,

• M. A. Jones, Acting Director - Onsite Nuclear Safety

• J. O'Sullivan, Manager - Maintenance

• D. E. Quidley, Instrumentation and Control (I&C) Maintenance Representative

• J. W. Moyer, I&C Maintenance Supervisor

• R. E. Helme, Director of Onsite Nuclear Safety

• B. E.-Hinkley, Manager - Technical Support

• M. Hogle, Engineering Supervisor - Technical Support

• M. Kesmodel, Document Control Supervisor

• K. E. Enzor, Director Regulatory Compliance

• J. Boone, Principal Engineer - Special Projects

• W. Leonard, Principal Engineer.- Operations

D. Fasnacht, Principal Engineer - Licensing

W. Murray, Senior Engineer - Onsite Licensing

G. Eagle, Projects Engineer - Computer

D. Savage, Shift Foreman

M. Robinson, Document Control

• L. Jones, Director - Quality Assurance / Quality Control (QA/QC)

• R. Creech, I&C Maintenance Supervisor

• R. M. Rogers, Engineer - QA

W. Martin, Onsite Nuclear Safety

D. Phipps, Performance Engineer

G. Locklear, Q-List Coordinator

B. Parks, Engineering Supervisor

T. Mills, Procurement Engineer

I. Fermyduval, I&C Planner

M. S. Haynes, I&C Foreman

R. Drew, I&C Maintenance Engineer

P. Musser, Senior Engineer

Other licensee employees contacted included engineers, technicians, opera-

tors, security force members, and office personnel.

Other Organizations

D. Musick, Engineer, General Electric Co.

W. Kassebaum, Engineering Consultant

.

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NRC Resident Inspector

L. Garner, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on May 24, 1985, with

those persons indicated in paragraph 1 above. The inspectors described the

areas inspected and discussed in detail the inspection findings. No dissent-

ing comments were received from the licensee. The following new item was

identified during this inspection:

Inspector Followup Item 325, 324/85-14-01, Q-List Program Changes,

paragraph 7.

The licensee did not identify as proprietary any of the materials 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 were not identified during this inspection.

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 (UTVA) 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-term actions to ensure reliability of the RTS. Actions to be

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

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

RTS reliability improvements. The licensee responded to Generic Letter 83-28 by correspondence dated November 7,1983. This inspection was per-

formed to review the licensee's current program, planned program improve-

ments, and implementation of present procedures associated with post-trip

review, equipment classification, vendor interface, post-maintenance test-

ing, and reactor trip system reliability for Brunswick Steam Electric Plant

(BSEP) Units 1and2.

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6. Post-Trip Review

The inspector reviewed the licensee's response to Ceneric Letter 83-28 which

described their program for post-trip review. Their implementation of these

guidelines was also evaluated. The post-trip review program is addressed

and implemented by Operating Instruction: 01-22, Plant Incident And Post-

trip Investigation.

The capability for assessing the sequence of events leading to a reactor

trip is provided by the process computer, a Honeywell 4010. The process

computer receives power from the uninterruptible power supply (UPS) system.

The UPS System consists of a vital bus, a power switching module, and two

power converter modules, each supplied by divisionalized emergency ac and de

sources. Each power converter module is capable of supplying the total UPS

load. Only one power converter module is in service, with the other module

in standby.

The process computer provides data points for two post-trip logs: (1)

Nuclear Steam Supply System (NSSS) log which includes data points for

Average Power Range Monitor, Generator Megawatts, Reactor Pressure, Core

Power Recirculation Flow, Feedwater Flow A, Feedwater Flow B, Reactor Level,

Steam Flow and Throttle Pressure and the (2) Balance of Plant (B0P) log

which includes approximately 30 additional data points. The functions of

the 80P programs are to monitor assigned B0P, to perform calculations, and

to log plant performance variables not directly associated with the Nuclear

Steam Supply System. The NSSS is set for one-second intervals for one

minute prior to the SCRAM to one minute following the SCRAM. The B0P values

are set for various intervals for approximately five minutes prior to the

SCRAM to five minutes following the SCRAM depending upon the set-time

interval. In addition, the computer provides for a sequence of events alarm

log printout and provides control rod drive position. Strip charts from

control room indicators are also utilized and are included in the Post-Trip

report as specified in Attachment 1 of 01-22.

Operating Instruction: 01-22 clearly specifies the requircments for review-

ing trip data. The qualifications, responsibilities and authority of the

personnel responsible for performing the review and analysis are clearly

delineated. Criteria for determining the acceptability of a plant restart

conform with the guidelines as described in Generic Letter 83-28, and 01-22

adequately describes the methods and criteria for comparing the event

information with known or expected plant behavior.

If the cause of the event is repetitive and requires more extensive action a

mechanism exists for providing for an independent assessment of the event

prior to conducting restart. If the cause of the trip cannot be determined,

if a potential safety concern exists or if a specified system did not

respond as required, reactor startup is prohibited until concurrence is

obtained from the Plant Nuclear Safety Committee.

,

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4

Interviews revealed that plant personnel preparing and/or reviewing the

post-trip documentation were familiar with plant systems, equipment, and

plant operation. Training had been performed and rescheduled periodically

and the training records were being maintained.

The inspector reviewed six reactor SCRAMS which included Unit No. 1 SCRAMS

on March 31, 1984, August 1, 1984 and January 24, 1985 and Unit No. 2 SCRAMS

on February 22, 1984, October 24, 1984 and November 27, 1984. The packages

appeared to be thorough and adequately documented the events. Documentation

of corrective action was also included in those instances where it had been

completed.

Site procedures provide for the identification of Plant Incident and Post-

Trip Invastigation reports and accompanying data as Quality Assurance (QA)

records and for storage of these records in the proper location. The plant

Incident and Post-Trip Investigation reports are placed in QA Documentation

storage following completion of any procedure changes and required plant

modifications and following completion of the senior plant management

review.

Several instances were found where these documents were not placed in

document control in a timely manner. For example, Post-Trip reviews of

February 22, 1984, October 24, 1984, November 27, 1984 and January 24, 1985

are still in the custody of the Operations Engineer since corrective action

has not been completed. However, following implementation of corrective

action (in most cases these were procedural changes or modifications requir-

ing a refueling outage) the package will be forwarded for QA Document

Storage. However, the long time span for which these documents are not

maintained under controlled storage conditions is potentially hazardous for

document retention. The licensee acknowledged this concern and informed the

inspectors that the procedure was being revised to have the reports reviewed

in a more timely manner.

Onsite Nuclear Safety has developed computer software to facilitate graphi-

cal display of the process computer data points; however, the data points

must still be manually inserted. This graphical analysis was performed by

Onsite Nuclear Safety during their review of the SCRAM. This program has

since been turned over to Operations to allow Operations to plot these

graphs. Operations utilizes this graphic capability only during instances

when the cause of the SCRAM is not immediately obvious or when subsequent

analysis is required. For reactor SCRAMS from apparently known, easily

diagnosed causes, graphing of the NSSS data points is not used. This

presents potential problems as some phenomena may not be readily recognized

unless graphical results are utilized. The licensee acknowledged this

concern and agreed to review this matter further. The NRC inspector agreed

with the licensee's approach and had no further concerns.

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

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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

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

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

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 informa-

tion handling systems used at the plant. The licensee's response to Sec-

tions 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

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

The inspector examined the following procedures and documents:

Maintenance Procedure MP-03, Calibration of Process Instruments,

Revision 021

Maintenance Procedure MP-04, General Maintenance Procedure,

Revision 011

Maintenance Procedure MP-10, Preventive Maintenance Program,

Revision 025

Maintenance Procedure MP-14, Corrective Maintenance, Revision 029

Maintenance Procedure MP-16, Writing Corrective Maintenance

Instructions

Volume XI, Book 2 Q-List, Revisions 26 and 27

Engineering Procedure ENP-3, Plant Modification Procedure

Engineering Procedure ENP-3.1, Direct Part Replacement,

Revision 000,

Engineering Procedure ENP-12, Engineering Evaluation Procedure,

Revision 009

Administrative Procedure AI-25, Procurement of Noncompany Labor and

Services, Revision 008

Maintenance Instruction MI-10-19, C71/C72-K14A-G and C71/C72-K15A-D

Relay Inspection, Revision 001

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Storekeeper Instruction SK-01, Material Requisition and Reorder

Procedures and Responsibilities, Revision 014

Brunswick Unit 2 Technical Specifications, Amendment 98

Work Requests and Authorizations Nos. 2-E-84-5771, 2-E-84-4926,

1-E-84-0082, 1-E-84-5751, 1-E-84-5755 and 1-E-84-5757

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,

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 or

nonsafety-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

components.

Other details of the inspection are discussed below:

9

Volume XI, Book 2 of the Plant Operating Manual is the procedure used by the

licensee to determine the safety classification of structures, systems and

components at Brunswick units 1 and 2. The Q-list identifies, in tables,

the portions of systems, the instruments, and the special components of

systems which are safety-related (Q-list). The licensee uses the Q-list

procedure to identify those activities (such as maintenance, design and

procurement) which are considered safety-related and governed by the re-

quirements of the corporate Quality Assurance Program. The procedure does

not identify all safety-related components and sub-components; however, it

delineates general criteria for the proper classification of all safety-

related components and sub-components.

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The Q-list is part of the Plant Operating Manual and is a controlled docu-

ment. It is the responsibility of the Q-List Group-Technical Support Unit

to maintain and revise the Q-List. Any revisions to the Q-List are required

to have a safety analysis, two-party technical and safety review and approv-

al by the Plant General Manager; however, in cases where an unreviewed

safety question exist, as defined in 10 CFR 50.59, approval is also required

by the Plant Nuclear Safety Committee prior to implementation. This is

delineated by Technical Specifications.

In addition to the Q-List procedure described above, the licensee is cur-

rently developing a computerized equipment data base (EDB) system that will

upgrade the Q-List. This EDB will be a detailed listing of components,

sub-components and parts. The licensee expects to have all safety-related

systems entered into the EDB by the end of July 1985 and all data fields

validated and classification determinations made on safety-related compo-

nents by December 1986.

The inspector discussed with cognizant licensee personnel their procedures

for processing work requests and authorizations, purchase requisitions,

purchase orders, and design modifications. Discussions with licensee

personnel in the Q-List Group revealed the following concerns:

a. The Q-List Group has been classifying as Q or Non-Q, piece parts of

major plant components and documenting the results of their evaluations

on three part memorandums. These evaluations are used by plant staff

in classifying as Q or non-Q replacement components on maintenance and

procurement requests; however, this evaluation is not procedurally

addressed by the licensee. The inspector informed the licensee that

the evaluations of piece parts could possibly effect the Q-List and

should be controlled by some procedure. The licensee acknowledged this

concern and committed to revise Volume XI, Book 2, Q-List to incorpo-

rate steps for processing component parts evaluations. The licensee

indicated that the procedure would require that each evaluation re-

ceives independent reviews and a safety evaluation prior to approval

and implementation.

b. Engineering procedure ENP-12 is the procedure used for upgrading parts

to Q-List. This procedure is also used to downgrade components identi-

fled in the Q-List. Procedure ENP-12 has a required distribution for

the completed evaluations. However, the completed Engineering Evalua-

tion Report is not routed to the Q-List Group who has responsibility

for revising the Q-List. The licensee indicated that although the

Q-List Group is not on the required distribution they have been receiv-

ing copies of Engineering Evaluation Reports. However, the licensee

indicated that procedure ENP-12 would be revised to include the Q-List

Group on the distribution list.

The above concerns were identified to the licensee as Inspector Followup

Item 325, 324/85-14-01, 0-List Program Changes.

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The inspector also reviewed records for six completed Work Requests and

Authorization Forms. The records were examined to verify that the work had

been properly classified per the Q-List, that all required reviews and

approvals were received prior to performing work, and that appropriate post

maintenance testing was conducted prior to returning the component back to

service.

The records reviewed are identified as follows:

WRAF System

2-E-84-5771 RPS

2-E-84-4926 RPS

1-E-84-0082 RPS

1-E-84-5751 CRD

1-E-84-5755 CRD

The records indicated that all reviews and approvals were received prior to

beginning work, forms were properly classified as Q-List, appropriate post

maintenance testing was conducted, and finally records were reviewed and

transferred to the storage facility.

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

8. Vendor Interface and Manual Control

The inspector reviewed the licensee's response which described their program

for vendor interface and control of vendor technical information. Their

response described the following program:

CP&L is supporting the INP0 Nuclear Utility Task Action Committee

(NUTAC) on NRC Generic Letter 83-28, which is currently focusing on

industry-wide vendor information programs for safety-related equipment

vendors other than NSSS vendors. We believe this program will provide,

when implemented, a practical industry-wide approach to assuring

safety-related equipment reliability.

BSEP has in place a vendor interface program which provides for the

evaluation of vendor information associated with safety-related compo-

-

nents and the subsequent incorporation into plant instructions and

procedures as appropriate. The vendor interface process, in combina-

tion with other plant and industry programs, provides assurance of the

reliability of safety-related components commensurate with the safety

functions.

Existing vendor interface process features include:

- Control of vendor manuals supplied with original plant equipment and

with equipment installed as a result of design changes (RMI-01: Capture

and Indexing of Correspondence and Plant Records; and RMI-03: Reproduc-

tion, Distribution, and Accountability of Plant Documents).

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-- Use of vendor information in developing self-sufficient approved and

controlled technical maintenance instructions (MP-16; Writing Correc-

tive Maintenance Instructions).

- Evaluation of vendor recommendations (PPP-02; Vendor Recommendation

Processing).

In summary, the licensee states that the vendor interface processes and the

regulatory and industry notifications, in combination with BSEP's commitment

to equipment preventive maintenance, surveillance testing, equipment correc-

tive maintenance, and the quality assurance program, provide assurance of

safety-related component reliability. This obviates the need for develop-

ment of additional formal programs of periodic vendor contact or acknowl-

edgement of feedback for other than the NSSS vendor. For safety-related

equipment vendors who have gone out of business or will not supply informa-

tion, such formal vendor contact programs would serve no purpose. Thus, the

licensee does not plan to implement additional formal programs for periodic

vendor contact or acknowledgement of feedback for other than the NSSS

vendor. The licensee further states that the BSEP program provides assur-

ance of safety-related equipment reliability and cost-effective safety

enhancement.

The inspector reviewed licensee procedures, vendor manuals and other docu-

mentation and activities concerning safety-related components to determine

if adequate controls have been developed and are being implemented as

required by Technical Specifications, industry guides and standards,

regulatory requirements and CP&Ls response (dated November 7,1983) to

Generic Letter 83-28. The review revealed that the procedures were consis-

tent with the licensee's submittal. The following documents were reviewed

during this inspection:

PPP-002, Vendor Recomendation Processing, Revision 3, dated 9/19/84

RMI-003, Reproduction, Distribution, and Accountability of Plant

Documents, Revision 20, dated 1/16/85

MP-10, Preventive Maintenance Program, Revision 25, dated August 29,

1984 >

MP-16, Writing Corrective Maintenance Instructions, Revision 10, dated

May 2, 1984

MP-43, Maintenance Subunit Action / Commitment Items Tracking System,

Revision 0, dated January 25, 1984

AI-02, Feedback of Operating Experience, Revision 21, dated May 19,

1983

AI-25, Procurement of Noncompany Labor and Services, Revision 8, dated

March 22, 1985

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AI-72, Control / Approval of Vendor Technical Manuals, Revision 0, dated

May 5, 1985

AP-01, Administrative Procedures, Revision 94, dated May 7, 1985

01-25, Operations Action Items Tracking System, Revision 0, dated

January 25, 1984

ENP-20, Engineering Work Request (EWR), Revision 3, dated August 17,

1984

1985 Annual Vendor Recommendation Status Report, dated March 18, 1985,

BSEP 85-0256

Vendor Recommendation Status Report, dated May 7, 1985 BSEP 85-0885

BSEP SIL Report, dated April 23, 1985

BSEP SAL Report, dated April 23, 1985

BSEP FDI Status Report, dated April 23, 1985

Engineering Work Request 84-385 For GE SIL-407, Preventing

Unauthorized Control Rod Patterns, closed out on April 4, 1985

Engineering Work Request 83-136 For GE SIL-390, Modification of

Invessel Rack Cable Assemblies, closed out on December 13, 1983

Quarterly Component Failure Report - Failures Through the Third Quarter

1984, dated January 18, 1985

Quarterly Component Failure Report - Failures Through the Fourth

Quarter 1984

Through examination of the above documents, interviews with plant personnel

and observation of activities in progress, the inspector concluded that

vendor interface comitments expressed in the licensee's response to Generic

Letter 83-28 were being implemented and appear to be progressing satisfacto-

rily. In their response, the licensee estimated that completion of its

commitments would occur in the December 1985 timeframe. Based on the

progress observed and through various discussions with personnel responsible

for vendor interface activities, delays in fully implementing all commit-

ments by this time are not anticipated. The licensee has already responded

to and resolved the majority of General Electric (NSSS vendor) Service

Information Letters (SILs), Service Advice Letters (SALs). Technical Infor-

mation Letters (TILs) and Field Disposition Information (FDIs). It is the

licensee's intent to review and implement as necessary all applicable vendor

recommendations or provide justification for not implementing such

recommendations.

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All incoming vendor manuals and correspondence is screened and controlled by

the plant document control. A program has been established which alerts the

affected organizations that the vendor manuals have been revised and that

revisions to plant procedures and documents may be required. Department

tracking systems have been established to track the progress of required

action.

The inspector reviewed several vendor recommendations and manual revisions

and determined that the program was being implemented in accordance with

established procedures and commitments.

The inspector also reviewed licensee's progress in incorporating vendor

recommendations into maintenance procedures to verify that the licensee

would meet the estimated completion dates specified in Appendix C to their

response.

The licensee contracted with General Electric (GE) Company to secure and

evaluate vendor recommendations regarding testing and maintenance of safety

related components at Brunswick. In October 1984 GE mailed about 150

letters to Q-List vendors and received about 120 responses. This resulted

in a GE transmittal of five vendor recommendations to the licensee's docu-

ment control. The five vendor recommendations were held at licensee's

document control for about six weeks for no practical reason. During this

inspection the licensee's document control unit began to get ready to

transmit the five vendor recommendations to the appropriate disciplines for

review and incorporation into the maintenance procedures. At the exit

interview, the licensee responded that the six weeks delay was due to

impending issuance of Administrative Instruction AI-72, " Control / Approval of

Vendor Technical Manuals." The inspector noted that Revision 000 of AI-72

was issued on May 5,1985 and the licensee was on target with meeting their

commitment as stated in their response to GL 83-28.

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

9. Surveillance and Post-Maintenance Testing

a. Licensee's Procedures and Documents Reviewed

(1) Maintenance Procedure: MP-10, Preventive Maintenance Program,

Rev 025

(2) Maintenance Procedures: MP-14, Corrective Maintenance, Rev. 029

(3) Administrative Instruction: AI-33, Surveillance Test Cross

Reference to the Technical Specifications

(4) Engineering Procedure: ENP-16, Procedure for Administrative

Control of Inservice Inspection Activities

(5) Maintenance Surveillance Test: 2MST-RPS 24M, RPS Reactor Vessel

Low Water Level (LL1) Trip Unit Channel Calibration

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(6) Maintenance Instruction: MI-10-19, C71/C72-K14A-G and

C71/C72-K15A-D Relay Inspection, Rev. 001

(7) General Maintenance Procedure: MP-04, Rev. 011

(8) Administrative Instruction: Al-02, Feedback of Operating

Experience, Rev. 021

(9) Maintenance Procedure: MP-26, Loop Calibrations, Rev. 006

(10) Administrative Instruction: AI-25, Procurement of Noncompany

Labor and Services, Rev. 008

(11) Periodic Test: PT-01.1.10-1, Reactor Protection Logic System

Functional Test, Rev. 0

(12) Regulatory Compliance Instruction: RCI-02.5, Surveillance Test

Cross Reference to Technical Specifications, Rev. 6

(13) Administrative Procedures, Vol. I, Book 1, pages 1 & 2

(14) Administrative Instruction: AI-72, Control / Approval of Vendor

Technical Manuals, Rev. 000, dated May 5, 1985

(15) Records Management Instruction: RMI-3, Reproduction, Distri

bution, and Accountability of Plant Documents, Rev. 021,

dated April 30, 1985

b. Surveillance Testing

The inspector observed the performance of Maintenance Surveillance Test

No. 2MST-RPS 24M, RPS Reactor Vessel Low Water Level (LL1) Trip Unit

Channel Calibration. This procedure is performed on each Brunswick

unit on a monthly basis. The entire procedure is performed by two I&C

technicians and takes about two hours. The test simulates a low water

level signal to the Primary Containment Isolation System (PCIS) and

provides a half-scram signal to the Reactor Protection System (RPS)

logic. This is done on each of the four channels A1, B1, A2, and B2.

The test verifies the operability of the reactor vessel low water level

trip function of the PCIS and the RPS. The inspector noted that the

I&C technicians performing the test followed the procedure carefully,

and performed all the steps correctly. The inspector noted, however,

that the procedure 2MST-RPS 24M (M for monthly) was specifically

written for Unit 2 and that a corresponding procedure IMST-RPS 24M

would be used for Unit 1. The inspector noted that the unit designator

on all the panel alarm windows throughout the entire procedure was

,

omitted. To illustrate as an example, the inspector noted that para-

l graph 7.2.2.1 of 2MST-RPS 24M calls for the test technician to verify a

!

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clear status on window (A-04 5-1). This would be Alarm Panel 04, row

5, column 1. However, the inspector noted that the actual designations

on the seven control room alarm panels themselves were different.

1

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4 - p a 4 4 , , a

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A comparison of the alarm panel designations is tabulated below:

On Panel On Procedure

Brunswick Unit 1 1-A-4 A-4

Brunswick Unit 2 2-A-4 A-04

There are two obvious inconsistencies:

(1) The unit designator "1" or "2" is shown in the panel version, but

it is not shown in the procedure version.

(2) Two digits are used to specify the Alarm Panel Number "04" in the

procedure version, whereas only one digit is used in the panel

version.

In the course of performing the entire MST procedure, the test techni-

cians went back and forth from the test area to the control room area

to verify the status of approximately 100 windows. The inspector

pointed out to the licensee that the discrepancies in the alarm panel

designations on the panel and in the procedure can lead to errors in

verification. This can be as a result of the large number of compari-

sons that have to be made.

The inspector conferred with the licensee's engineers responsible for

implementing the Maintenance Surveillance Test (MST) Procedure System.

The licensee's engineers' response was that they are in the process of

converting approximately 230 Periodic Test (pts) Procedures to approxi-

mately 400 MSTs. The plan is to delete most of the pts that were

written for Unit 0, which meant for both units 1 and 2. The MSTs would

be written for the same test: one for Unit 1 and the other for Unit 2.

On each page of the MST is printed the unit number. The lack of a unit

designator in the alarm panel designation was due to the decision to

follow the licensee's Writer's Guide for MST. Section 3.7.1, page

Al-12 of the Writer's Guide showed an example where the unit designa-

tors for valves were omitted in the procedure. This approach was

similarly applied to alarm panels on page Al-13. The end result was a

saving in having to repetitiously show the unit designator on all

equipment numbers.

c. Post-Maintenance Testing

(1) Review of Completed Work Packages

The inspector reviewed the licensee's maintenance and post-main-

tenance testing records. The inspector randomly selected six of

the licensee's Work Request and Authorization Forms (WRAF) and

reviewed all the infonnation and data in each work package. The

inspector found all the work packages complete, and all minor

discrepancies were adequately addressed by the licensec's person-

nel. The WRAFs audited by the inspector were as follows:

1

.. w

s

14

WRAF No. Description

(a) 2E-83-3709 MSL Rad Monitor D, Unit 2

No discrepancies were

identified.

(b) 1E-83-1334 RPS MG Set Output Breaker

No discrepancies were

identified.

(c) IM-83-1817 Core Spray System Valve Repack

No discrepancies were

identified.

(d) 1E-83-061 Replace Relay Coil

No discrepancies were

identified.

(e) 1E-82-3970 Electrical Support Work on

Valve Maintenance

The inspector noted that the Post Maintenance Testing Re-

quirement (PMTR) was signed off on 7-18-83 as satisfactory. ,

However, contradictory information was noted in the Job

Supplement Form of the WRAF. The Job Supplement Form stated

that the post maintenance test was unsatisfactory on the same

date: 7-18-83. The inspector questioned several licensee

personnel about this discrepancy and concluded that the entry

on the Job Supplement Fom, which stated that the -tests were

unsatisfactory, was made approximately four to five weeks

prior to the 7-18-83 date shown on the form. Apparently, the

valve in question was subjected to a series of test in early

June 1983 and the valve failed those tests. This led to

additional maintenance work and resulted in another series of

tests which culminated in the acceptance on 7-18-83. The

inspector pointed out to the licensee that the records

associated with this WRAF were not clear and can lead to

confusion unless time was spent fitting the pieces together.

'

(f) 2E-84-4365 Repair V120 Throttle Valve

The inspector noted that item #39 " Clearance Required" was

not checked off on the WRAF. The licensee responded that

this was an oversight, and submitted proof of adequate work

procedure on this WRAF.

(2) RPS Relay Inspection

The inspector participated in observing the licensee's I&C Group

performing a demonstration of RPS relay inspection using Mainte-

nance Instruction MI-10-19. The licensee's demonstration went

. .

15

well. However, there was an apparent typographical error in the

subject Maintenance Instruction MI-10-19. On page 1 of 5 in the

" References" section, the General Electric product information was

referred to as "GEH-2416C". A search of the licensee's Document

Control showed that the vault copy was a "GEH-2416B". Further

search by the licensee revealed that no revision "C" existed. The

licensee committed to have the error corrected in the next revi-

sion to Maintenance Instruction MI-10-19.

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

10. Surveillance Testing of the Diverse Reactor Trip Functions of the Reactor

Trip System

The licensee states in their response to GL 83-28 that on-line testing of

the Reactor Protection System is accomplished by periodic functional channel

tests, channel checks, and scram timing of control rods. The licensee also

states that on-line testing of the backup scram solenoid valves is not

possible without scramming the plant; however, testing of the backup scram

valves will be performed during each refueling outage. The inspector

confirred that the licensee's surveillance procedures PT-01.1.10-1/2 inde-

pendently test each backup scram solenoid valve once every 18 months while

the plant is shutdown.

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