ML20127G770

Insp Rept 50-302/85-07 on 850211-15.Violation Noted: Inadequate Procedure for Retention of Records Required by Tech Specs

ML20127G770
Person / Time
Site:	Crystal River
Issue date:	04/03/1985
From:	Brewer D, Foster L, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127G747	List: ML20127G743 ML20127G759 ML20127G770
References
50-302-85-07, 50-302-85-7, GL-83-28, NUDOCS 8505210140
Download: ML20127G770 (20)

See also: IR 05000302/1985007

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UNITED STATES . .

i . , ~ [>R EEIoqfo_ NUCLEAR REGULATORY COMMISSION

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'g j 1d1 MARIETTA STREET.N.W.

• 2 ' ATLANTA, GEORGIA 30323

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Report No.: 50-302/85-07

. Licensee: ' Florida Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733 -

Docket No.: 50-302 License flo.: DPR-72 .

Facility Name: Crystal River 3

L Inspection' Conducted: February 11-15, 1985

Inspectors: e

N. Merriweather, Team Leader

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D&te Sig ed

D. Brewer

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L. Foster'

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Date Signed

-Accompanying Personnel:

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W. M. Hill, Region II; P. Moore, Region II _,

Consultant: R. L. Whi e, Lawrence Live more National Laboratory

Approved b .- Mr N Y f>

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W._M. Hill, Technical Assistant ( Dite Signed

Division of Reactor Safety .

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SUMMARY ,

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Scope: This routine, announced' inspection involved 138 inspector-hours on site

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

Generic : Implications of. Salem AnticipatedTransientWithout Scram (ATWS) s

Events.

Areas inspected included: post-trip review, equipment classification, vendor

-interface and manual control, post-maintenance testing and modifications, and

reactor tr_ip system reliability.

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Results: One violation was identified - (Inadequate Procedure for Retention of

Records Required by Technical Specifications, paragraph 6.e.).

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8505210140 850400

PDR ADOCM 05000302 *

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REPORT DETAILS

1. . Persons Contacted

Licensee Employees

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• P. F. McKee, Nuclear Plant Manager

• H. Gelston, Nuclear Electrical / Instrumentation and Control Engineering

Supervisor

• R. E. Carbiener, Nuclear Compliance Supervisor-

• W. S. Rossfeld, Site Nuclear Compliance Manager

• S. B. Lyon, Chief, Nuclear Technical Support Technician

• W. J. Nielson, Senior I&C Supervisor

• J. -Lander, Nuclear Outage and Modifications Manager

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• J.'Alberdi, Manager Site Nuclear Operations Technical Services

• J. Cooper, Modification Testing Manager

• B. J. Hickle,~ Assistant Operations Manager

• T. A. Kamann, Nuclear Operations Records Manager

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• K. F.' Lancaster, Manager Site Nuclear Quality Assurance

• L. B. Tiscione, Supervisor Procurement Section, Site Nuclear Engineering

• W. K. Bandhauer, Nuclear Safety Supervisor

,' *R. A.- Brown, Electrical / Instrumentation and Control Supervisor

• V. R. Roppel,. Nuclear Plant Engineering and Technical Services Manager

• H..Koon, Assistant Nuclear Maintenance Superintendent

• D. Terrill, Nuclear Licensing Engineer  !

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K..N. Smith, Nuclear Chief Electrician

L.-Santilli, QC Insrector

R. Vigene QC Inspector

T. Oldfield,' QC Instector

S. B. Sullens, Acting Senior Nuclear I&C/ Electrical Supervisor

-F. Sullivan, Project Engineer

, L. C. Kelley, Nuclear Modifications Supervisor

J R. M. Jones, Engineering Aide

% D. Beach, Project Engineer

'<# F. Zimmanck, Modification Testing Supervisor

F. Fusick, Supervisor Engineering Section, Site Nuclear Engineering

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,P; N. Holliday, Nuclear Planning Coordinator

Other licensee employees contacted included engineers, technicians, opera-

{yp . tors, mechanics, security office members, and office personnel.

NRC Resident-Inspectors

(3 *T. F. Stetka, Senior Resident Inspector

i *J. E. Tedrow, Resident Inspector

• Attendede$1tinterview

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2. Exit Interview

The inspection scope and findings were summarized on February 14 and 15,

1985, with those persons indicated in paragraph 1 above. The inspectors

described the areas inspected and discussed in detail the inspection find-

ings listed below. No dissenting comments were received from the licensee.

Unresolved Item 50-302/85-07-01, Post-Trip Review Procedure Comments,

paragraph 6.d.

Violation 50-302/85-07-02, Inadequate Procedure for Retention of

Records Required by Technical Specifications, paragraph 6.e.

Inspector Followup Item 50-302/85-07-03, Revision to PCOR Program,

paragraph 8.

Inspector Followup Item 50-302/85-07-04, Discrepancies In the Licensee

Program for Reactor Trip Breaker Maintenance, paragraph 9.

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The licensee stated that proprietary information was provided to the inspec-

tors during the inspection; however, this information was not used in

writing this report.

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 devia-

tions. One new unresolved item was identified during this inspection and is

discussed in paragraph 6.d. ,

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 D8-50 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 Action Based on Generic Implementations 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

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RTS ' reliability improvements.

83-28 by. correspondence with .the Thefollowing

. licenseedates:

' responded

March.to Generic

4 and 21, Letter l

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September 2, October 6, and November 4,: 1983; and January 31, ' March 16,

April S, May 30, June 19, and July 31, 1984. This inspection was performed

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to review the licensee's current program, planned. program improvements, and

implementation of . present . procedures associated with . post-trip ? review,

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, equipment classification, . vendor interface, post-maintenance testing, and *

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reactor trip ' system reliability for Crystal River Ur.it 3.

- 6. = Post-Trip Review -

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

for post-trip review.. Their response ~ described the-following program:

Florida Power Corporation (FPC) maintains a program to ensure that unplanned

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reactor shutdowns are analyzed and to ensure that a. determination .is made ,

that the plant can be safely restarted. The restart will be authorized if

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and ~only Lif safety: systems respond as. designed and the overall plant re-

sponse was as designed. The post-trip review form is jointly filled out by

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the Shift Operations Technical. Advisor (SOTA) and the Man-On-Call (MOC). >

JThe MOC is a superintendent level manager who has a Senior Reactor Operator  ;

-license or equivalent experience and is designated by the Nuclear Plant

Manager. Authorization to restart the reactor must come from the MOC.or the

Nuclear Plant Manager.

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The SOTA~and the MOC use the following plant information sources in analyz-

i ing and reconstructing the event:

- Reactor Protection System Cabinets-

- Annunciator Event Printouts

Computer Alarm Printouts

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Post -Trip Summary l

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, Recall System  !

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a. Procedure Review

' The inspector conducted a review lof licensee procedures and confirmed

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.. - the licensee's procedures were consistent with the above. described

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licensee response. The.following procedures were reviewed:

Operations Section Implementation Manual (OSIM) Enclosure 16

- Unplanned Operating Event Reports

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Nuclear; Safety Group Policy No. 1

SOTA Training Qualification Card-

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Operating Procedure-210, Reactor Startup

Administrative Instruction'1100,= Retention of Plant

' Operating Records ~

Administrative Instruction 702, Conduct of Nuclear Safety

and Reliability _

Policy Memorandum, On-Call

- TransientfAssessment Program (TAP)

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Procedures were written, approved and in use; and equipment was

operating which was needed to conduct a post trip review.

The post-trip review procedure is a one page document entitled " Restart

After Protection System Actuation" and is enclosure 16 to the Opera-

tions Section Implementation Manual (OSIM). The OSIM is an approved

document. The post-trip review procedure requires that the following

items be identified:

Safety function causing the reactor shutdown

Faulted system

Affected component in the faulted system

Time of protective system actuation

Possible causes of the event

Required troubleshooting

Most probable cause of the event

The post-trip review procedure requires the M0C to determine if the

. safety system and the plant responded as designed by checking the

appropriate box either "yes" or "no". The M0C or the Nuclear Plant

Manager must signify if plant restart is authorized in a similar

manner.

Post-trip review reports were prepared by the SOTA and reviewed _ and

approved by the M0C or the Nuclear Plant Manager prior to approval of

plant restart.

The procedures clearly specify who will conduct the post-trip review,

fill in enclosure 16 to the OSIM, perform the analysis of the event,

and approve the report.

Plant personnel preparing and/or reviewing the post-trip documentation

were familiar with plant, system and equipment operation. On the job

training had been performed by each qualifying SOTA. Records of the on

the job training were retained.

Site procedures provide for the identification and retention of the

post-trip reviews (enclosure 16 of the OSIM) as quality assurance

records. Five procedures were verified to be stored as required by

quality procedures.

b. Equipment Utilized in Post Trip Review

Equipment used to complete the post trip review procedure consists

primarily of the RECALL system, the computer alarm system and annun-

ciator events printout. In addition, lights and relays in the reactor

protection system cabinets provide informagion as to the affected

protection channels.

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The RECALL system is a magnetic tape data acquisition and storage

system which monitors approximately 200 parameters. During a transient

event it saves and records up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of information without

operator action. Hard copy playback is available in the Control Room,

Technical Support Center, and the Emergency Operations Center.

Transient response is updated for all monitored parameters at one-

second intervals. The RECALL system is considered to be the primary

method of transient analysis.

The plant computer contains a post-trip review subfunction which

monitors 40 analog parameters at a 15-second scan frequency. When the

reactor trips, the past 15 minutes of data are stored and an additional

15 minutes of data are collected and stored. A hard copy printout is

available on demand.

The annunciator event recorder system scans 2100 contact points every

4.2 milliseconds. It monitors all annunciated parameters displayed in

the control room. The system is subject to frequent overload due to

its small buffer capacity. The system is only capable of continuously

updating 32 simultaneous inputs. Additional input is stored without a

time tag and the printout of the data may not reflect the actual

sequence of events. The system occasionally overloads before the

initial alarming annunciators are stored. While the short time inter-

val update rate greatly enhances the ability to reconstruct the initi-

ating event, the system will not always provide the desired information

as the transient progresses.

All three computer data collection systems are powered from vital

busses. During a review of the previous three reactor trips, the

inspector determined that the combined use of all three computer

systems provided reasonable information with which to reconstruct the

sequence of events. The licensee is considering a modification to

. expand the buffer capacity of the annunciator alarm system. Changes

are not planned in the near future.

c. Reactor Trip Data Review

The inspector conducted a review of the three reactor trips which

occurred since the licensee responded to Generic Letter 83-28,

" Required Actions Based on Generic Implications of Salem ATWS Events".

Each post-trip review was inspected to determine conformance with the

licensee's response to the generic letter. In each instance the

restart of the reactor was determined to be acceptable. Reconstruction

and evaluation of the events could not be performed based solely on

enclosure 16 to.the OSIM. Lack of detailed procedural guidance and the

brevity of the post-trip review forms resulted in much of the

licensee's efforts going undocumented at the time the reactor was

restarted.

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The inspector determined, based on the review of each transient's

Unplanned Operating Event Report (U0ER) and interviews with licensee

personnel, that an adequate post-trip review had been performed. The

inspector discussed the desirability of including additional guidance

and documentation in the post-trip review procedure,

d. Post Trip Review Program

The NRC inspector reviewed the post-trip review reports, procedures,

and implementing documents and made the following observations:

Although a safety assessment was performed as part of the post

trip review, the criterion upon which to base the assessment was

not itemized in either the post-trip review procedure or its

implementing manual, the OSIM. Other than to evaluate the results

of the three computer system data, the SOTA and the MOC are

provided with no administrative guidelines as to how to evaluate

the transient.

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Operating Procedure (0P) 210, Reactor Startup, does not require that

the post-trip review be completed prior to reactor startup.

The post-trip review procedures do not specify the following:

(1) Positively identify the exact cause of the trip even when the

exact cause has been determined.

(2) Require that anomalies observed concerning the performance of

safety-related equipment be documented and investigated during the

review.

(3) Require that the cause of the trip be corrected prior to reactor

restart.

(4) Require that the transient response be compared to previous known

transient responses to verify proper system performance.

(5) Require periodic review by the Plant Review Committee to determine

if any area of the procedure needs upgrading.

(6) Contain a written summary of the transient event.

(7) Require the trip data be collected as soon as possible after the

transient.

(8) Require independent assessment of the transient event by a safety

review group when the cause- of the trip cannot be identified or

when unresolved safety issues exist.

(9) Identify strip charts and operator interviews as data which should

be considered during the review.

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(10) Require an on-shift Senior Reactor Operator to review the

completed procedure.

SOTAs do not receive initial specific training or retraining in how to

perform the post-trip review procedure. They do receive on the job

training in the area of U0ERs.

Guidelines have not been established for the preservation of operating

records associated with reactor trips.

The inspector expressed his concern to the licensee and asked the

itcensee to review their procedures relative to the above comments.

They acknowledged the inspector's concern and stated that they would

review their procedures relative to the inspector's concerns. This

item is unresolved and is identified as Unresolved Item

50-302/85-07-01, Post-Trip Review Procedure Comments.

e. Record Identification and Retention

During the review of the information compiled as a result of the

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previous three reactor trips, the inspector determined that 'the

licensee had not referred some data to the Records Management

Department for storage in an approved storage facility. The data were-

available for review but since it was not considered to constitute a

quality assurance record its storage was not controlled. The inspector

informed the licensee that relevant portions of computer printout data

which were analyzed and used to determine the acceptability of reactor

restart constituted operating records and were required to be retained

for five years -in accordance with Technical Specification (TS)

6.10.1.a.

A review was made of the Florida Power Corporation Quality Program,

Section 1.7.1.17. This section defines " Quality Assurance Records" and

includes as a quality assurance record those records required to be

-retained by the TSs.

A review was made of Administrative Instruction (AI) 1100, " Retention

of Plant Operating Records", .which implements Section 1.7.1.17 of the

l FPC Quality Program. This instruction agreed with the definition of

quality assurance records found in FPC Quality Program Section 1.7.1.17

except that it deleted references to training records and records

required by the TSs as quality assurance records.

Consequently, personnel using AI 1100 were not aware of the requirement

to treat records required by TSs as quality assurance records.

The failure of Procedure AI-1100, Retention of Plant Operating

Records, to require retention of records required by Technical

Specifications (TSs) constitutes Violation 50-302/85-07-02, Inadequate

i Procedure for Retention of Records Required by TSs.

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. 7. ' Equipment Classification

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

for equipment classification. Their response described the following

program:

FPC uses a controlled " Safety Listing" to identify safety-related or

non-safety related components. Cognizant plant- personnel use the

" Safety Listing" to determine if an activity is safety-related during

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the . activity planning stage. Revisions to the " Safety Listing" are

developed by the Nuclear Engineering Department in accordance with

Safety Related Engineering Procedure No. 1.

The inspector reviewed appropriate licensee documents and interviewed

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

equipment classification was adequate and consistent with their response to

Generic Letter 83-28. The following procedures and documents were reviewed:

Safety-Related Engineering Procedure No. 1, Revision 7, Safety

Identification and Design Input Requirements

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Compliance Procedure No. 113, Revision 39, Handling and Controlling

Work Requests.and Work Packages

Safety Listing Volumes 1 and 2, Revision 18

The inspector confirmed that the licensee's program for equipment classifi-

cation included the following elements:

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Plant and component controls for classification of structures, systems,

and components as safety-related were being implemented.

The licensee utilizes the " Safety Listing" to identify safety-related

structures, syste;ns, and components. The Safety Listing is contained

in two volumes. Volume 1 is made up of the following seven sections:

Introduction

Electrical Section

HVAC Section

I&C Section

Mechanical Section

Structural Section

Consumable Section

The licensee in their - response to GL 83-28 indicated that Volume 2

consisted of two sections, Tab A and Tab B. Tab A contained copies of

-completed safety classification review forms prior to incorporation

into Volume 1. Tab B contained copies of the index for the classifica-

tion of items forms, which recorded the results of the Nuciear

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Engineering review of individual piece parts. The licensee has revised

Volume 2 by deleting Tab B. The index is now being maintained by the

Procurement Section, Site Nuclear Engineering.

Nuclear Engineering is responsible- for revising the Safety Listing by

completing Safety Classification Review Forms. These reviews must be

processed in accordance with Engineering Procedure SREP-1. Volume 1 of

the Safety Listing is revised on an annual basis to . incorporate the

classification review forms that' were processed during the 12-month

period.

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

non-safety-related maintenance activities are identified during the

planning stage. Plant Operating Quality Assurance Manual Compliance

Procedure CP-113 requires maintenance planners to identify on all Work

Requests whether- the activity involves safety-related or non-safety

related components by checking the appropriate box. The procedure also

states . that the Safety Listing shall be used in making this

determination.

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The Safety Listing is reviewed by design personnel during the modifica-

tion process to determine if the modification affects safety-related

structures, systems er components. This: review is documented on a

Design Data Sheet For v =nd incorporated into the modification package.

Personnel participating in activities impacting safety-related struc-

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

QA controls.

Written directives assigned principal responsibility for satisfactory

completion of procurement, maintenance, and modification activities

associated with safety-related structures, systems and components.

Personnel performing activities impacting equipment on the Safety

Listing have received indoctrination and training.

The inspector reviewed the attendance sheet for the training provided

the maintenance planners on how to use the-Safety Listing.

Repairs, maintenance, or modifications to equipment to correct fail-

ures, malfunctions, deficiencies, deviations, defective material and

equipment, and nonconformartes were performed, documented, and reviewed

to determine reliability rf replacement components.

The inspector further confirmed the above items by interviewing site and

corporate personnel and by reviewing procedures and other appropriate

documents.

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Discussions with . Procurement Engineering personnel revealed that all pro-

curement ' documents for safety-related equipment receives three reviews.

Purchase orders associated.with _ safety-related equipment were reviewed to

determine- if procedures were -available and being implemented to ensure

continual vendoriinvolvement and classification of equipment. The following

idocuments were reviewed:

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Section 6 of the Nuclear Procurement and. Storage Manual-(NPSM) for

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. safety-related procurement.

CR 3 Safety Listing, Volumes 1 and 2.

Purchase Requisition 723-7081 dated January 30, 1985

Purchase Order F90246520, Thermocable Extension Cable

WUt 80-05-14-03 dated January 30, 1985, concerning Engineered

Safeguard Motor Control Center and Switchgear System Modifications

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-Catalog Evaluation for PR 930-3509K, Renewal Parts for GE Cabinets

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Specification.065,600 Volt- Armored Power Cable

Procedure No. SREP 24, Qualification Report Review, Rev. 1.

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

' 8. Vendor Interface and Manual Control

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

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-for; vendor interface and control of vendor technical information. : Their

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response described the following program:

l Licensee response ~ dated November 4,-1983, stated that' the Reactor Trip

System components were originally supplied by: Babcock and Wilcox-(B&W)

';, and that current; updates to this equipment were being supplied by the

B&W Owners Group. .The licensee acknowledges receipt of the information

by, written confirmation. All technical information received which has

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an impact on plant design, maintenance, and safe operation is distrib-

.uted to appropriate licensee organizations for review, approval, and

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. incorporation into plant procedures as applicable.

Subsequent licensee response' dated July 31, 1984, stated thet the 3&W Owners.

E . Group activities also included the contacting of vendors to abtain applica-

ble1 current information concerning equipment in systems which makeup the

Reactor Trip -System (RTS). These sub-systems are the Pod Control Drive

' System, Reactor Protection System, Nuclear Instrumentation, and Non-Nuclear

LInstrumentation Systems. A list of RTS components had been developed from

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the above systems. Due to the large number of safety-related components I

involved outside of the RTS, the B&W Owners Group contacted Institute of

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Nuclear Power Operations (INPO) for assistance. A Nuclear Utility Task

Action Committee (NUTAC) was formed to develop a -program for vendor inter-

face and manual control. The licensee along with the B&W Owners Group

actively participated in the NUTAC program. Subsequent response to GL 83-28

was submitted by the licensee on July 31, 1984. This response referenced

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the NUTAC Final Report dated March 23, 1984, which presented steps to be

taken to obtain and control vendor information for safety-related non-RTS

components. Examination of the NUTAC Report and the licensee's procedures

revealed that they are following the recommendations of the NUTAC Report

during the development of their procedures. The licensee expects to be in

full implementation and have vendor manuals and plant procedures and in-

structions reviewed by March 31, 1986.

The inspector reviewed the following licensee procedures relative to vendor

interface and control of vendor technical information to confirm that the

procedures were consistent with the licensee's submittal and that they had

established, implemented, and maintained a continuing program to assure that

vendor information is complete, current, and controlled throughout the life

o,f the plant:

SREP-5, Document Approval and Control, Revision 4

FPC Nuclear Quality Assurance Plan

AI-400, Plant Operating Quality Assurance Manual, Revision 54

AI-401, Origination of and Revision to P0QAM Procedures, Revision 6

AI-404, Review of Technical Information, Revision 1

DC/RM-365, Control of Vendor Manuals, Revision 1

DC/RM-375, Routing and Processing Incoming Technical Information,

Revision 0-

N00-06, Technical Information Program, Revision 0

Nuclear Procurement and Storage Manual, Section 2, Classification of

Items and Services

Paragraph 4.27 of AI-401, describes the proper use of technical manuals.

Appropriate srctions of maintenance-related vendor manuals, equipment

operating inscructions, maintenance instructions, and test acceptance

criteria may be duplicated and used, referenced in plant procedures, or be

included in plant procedures. Approval of manuals, procedures, and instruc-

tions is required prior to use. The inspector examined SP-113, Revision 28,

and determined that vendor information per Crystal River 3 Manual 206,

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Volume 1, BM Co. NI/RPS Instruction Book was used as a reference.

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Procedure - AI-404 _ establishes a method to ensure a consistent, thorough,

documented review of vendor manuals, . B&W correspondence, _'INPO documents,

vendor : manual changes, and _ vendor technical information letters. This

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P procedure _also . establishes responsibilities for transmitting, . reviewing,

tracking,; approving, -and document control . The procedure contains a cross-

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. reference . list of RTS Components which includes component descriptions,- tag

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numbers, manufacturer, model numbers, technical. manual numbers, manufactur-

er's instruction book numbers, and the associated plant procedures' (docu-

- ments). pertinent-to each component.

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Procedure DC/RM-365 describes the licensee's program for the use, distribu-

tion, control, maintenance, and revision of vendor manuals. The inspector

' discussed this procedure with licensee personnel and confirmed the implemen-

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tation by physically examining RTS technical manuals, review, and approval

, documents . located in the Document Control area. - Inspection . revealed - that

t the. manuals were stamped as " Controlled Manuals" and each manual had a

unique control number .and ' a stamped statement on the front. cover which

specified whether the manual addressed safety-related or_ non-safety-related

. components. Other documents such as review and approval forms- data trans = ,

, ' mittal sheets, and applicable revisions were attached' to the manuals. The?

inspector noted that Book 282-2, Documentation on .Rockwell International

. Valves, had " VOID'? marked across the front cover but no justification or

approval to " VOID" this manual could-be'found. A' review of the manual index

showed that several other manuals and instructions had been voided. 'Some

had justification and some did not.

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The inspector advised the licensee that the method. used to " VOID" manuals

and instructions should be controlled similar.to the approval method.-

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< Document Control transmits documents to cognizant departments via;a comput-  ;

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erized method which specifies the document number, revision number, recipi-

ent, and manual copy ' number. The computer form 'also gives review

instructions to the recipients and requires- the recipients to acknowledge

review, etc. , by signing and - returning to Document Control. Document

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Control keeps a current index (computerized) which-depicts vendor, title of

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document, and location within.' the ' plant. The latest printout dated

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Manuals examined are listed below:

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' 'GEI-50299 for type AK-15/25 Breaker

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GEI-7303 for type AK-50/75/100 Breakers

Instruction Manual 1172, Volume 1, Automation Industries-

Ingersoll Rand, Book 171-2

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The inspector reviewed the following technical manuals.for RTS equipment and

other components which had been classified as safety-related:

Foxboro Manual No. 1278

Diamond Power Co. No. 135, Volumes 1, 2, and 3, Control Rod Drive

Mechanism

Diamond Power Co. Instruction Book'No. 620-0007, B&W Reactor Vessel

Insulation

Westinghouse Installation and Handling Procedure WL-23682/23682 A,

Source Range Detector (Book No. 280)

Book 282-2, Rockwell . International Valves (Book Marked " Void")

Document control personnel were very knowledgeable of their responsibilities

and procedures. Manuals and other information requested by the inspectors

were produced in a timely manner. A comparison of the Document Index

Listing with controlled document numbers and location index was made and

f,ound to match.

Modifications to equipment based on vendor recommendations has been imple -

mented by the licensee. ~ The Babcock and Wilcox Owners Group (BWOG) has been

active in evaluating long-term improvements in breaker . performance and to

improve reliability. The licensee utilizes GE Service Advisories (after B&W

concurrence) for the GE breakers. Based on vendor recommendations and BWOG

recommendations, the licensee has evaluated and changed preventative mainte-

nance procedures, as applicable, to incorporate these changes. - Procedures,

vendor changes, and licensee actions reviewed were as follows:

PM-118, AC and DC Breakers, Revisions 8 through 11

GE Service Advisory Nos. 9.20, 9.3, and 9.3S concerning type AK

Breaker Maintenance and Modifications

Technical Review Coversheet for Book 434 and changes concerning

ordering of parts

Letter from Smith Industrial Sales concerning interpretation of

Technical Bulletin BK-4613

Electrical Engineering Item (from computer) 82323N concerning the

evaluation of Colt's recommendation on diesel generators

Data Transmittal Sheet (DTS) for MDA Scientific Manual No. 504' dated

January 16, 1985

DTS for Validyne Variable Reluctance Pressure Transducers, Book

No. 1188 is to be voided as information is in Instruction Manual

No. 546

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Revisions to SP-110, RTS Functional Testing, and PM-118, AC and DC

Breaker. These referenced Instruction Manual No. 135

The review of the above documents confirmed that the licensee has been

evaluating vendor information and utilizing this information in their

. procedures and instructions.

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To further verify that management controls were being implemented and to

determine if site QA had audited activities cffecting GL 83-28, the inspec-

tor examined the QA department' audit schedule, discussed training, examined

audit activities, and reviewed documentation.

The licensee's audit schedule for 1984 (Rev. 4, October 1,1984) included 19

planned audits and covered activities ranging from review of preventive and

corrective maintenance to management and technical review programs. The

schedule appears to address all areas necessary for a comprehensive QA

program.

. The inspector's concern was noted during his review of the Quality Assurance

Plan Manual in that it did not address Criterion 6 of 10 CFR 50, Appendix B.

Criterion 6 refers to document control; however, the program called Document

Control (DOCC); only addressed QA department records and not 'the drawings,

procedures, instructions, etc., of the licensee's departments other than QA.

A discussion with the Supervisor of Qual + ty Audits, revealed'that document

control Lfor all other departments is contained in the Procedure Control and

Document Retention Program (PCDR). This program, however did not reference

Criterion 6, nor did it specify technical manuals as controlled documents.

The licensee acknowledged the inspectors concerns that these two items

should be specified in the program and stated that they will be added to the

forthcoming revision of the PCDR program. This item is identified as

Inspector Followup Item 50-302/85-07-03, Revision to PCDR Program.

The licensee has two audits scheduled in 1985 that will cover areas of

concern from GL 83-28. First is Document and Record Control and Retention

Audit. The scope of this audit will address the control and retention of

technical manuals and updated information on plant components and systems.

Second is an audit on Modification Control. The scope of this audit will be

the reactor trip breaker modifications.

The following audit reports were examined by the inspector for scope,

completeness, and response timeliness.

QPA-250, Preventive and Corrective Maintenance dated April 11, 1984.

(Audit disclosed 16 findings; all were responded to and closed out in a

reasonable amount of time.)

QPA-236, Procedure Control and Document Retention dated June 24, 1983.

(Audit disclosed five findings; all were responded to and closed out in

a reasonable amount of time.)

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-QPA-258, Personnel Training and Qualification, dated November 16, 1984.

(Audit disclosed 17 findings; all were responded to and closed out in a

reasonable amount of time.)

QPA-262, Management and Technical Review dated December 21,'1984.

(Audit was in good order and responses were timely. Audit addressed,

as a concern, that the Plant Review Committee did not delineate clearly

whether or not - considered ' items constituted unreviewed safety ques-

tions. Since this is a TS (6.5.1.7.6) requirement, the inspector

questioned why this was addressed as only a concern, which does not

require a response or action, versus a finding which does. Subsequent

interviews with the audit team leader, and the head of the Plant Review

Committee, revealed reasons why the item was a concern and not a

finding, and also indicated that corrective actions were being taken by

-the Plant Review Committee.)

QPA-263, Routine Operations Requirements, dated January 9,1985. (Audit

disclosed four findings; all were responded to and closed out in a

reasonable amount of time. This audit addressed Post-Trip-Review.)

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QPA-255, Non-conforming Item Control and Corrective Actions

QPA-253, Procurement Activities

QPA-267, Instrumentation Procurement, Documents and Record Control

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

9. ' Post Maintenance Testing and Modification

The inspector reviewed the licensee's post-maintenance testing program to

ensure- the requirements of. GL 83-28 were being met and that- the licensee's

responses were being implemented. The inspector examined procedures,

completed maintenance records, and interviewed responsible personnel to

determine the adequacy of the licensee's post maintenance testing program.

Their response describes the following program:

The licensee stated in their response that post maintenance testing is

performed on safety-related components once maintenance is complete.

Compliance Procedure -CP-113 delineates the FPC requirements for per-

forming. post-maintenance testing. Additionally, existing maintenance

procedures have a requirement to address specific post-maintenance

testing. The licensee also states maintenance procedures which affect

safety-related . components will be reviewed to ensure that the post-

maintenance test section adequately demonstrates that the equipment is

. capable of performing its safety function before being returned to

service. The dates for completion of the reviews and for revising or

developing procedures are given in the licensee's response to GL 83-28,

dated July 31, 1984.

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The inspector reviewed the following procedures and documents to confirm

that the -licensee's program provided for adequate Post-Maintenance and Post-

Modification Testing and. that their procedures were consistent with their

response to GL 83-28. The documents reviewed are listed below: '

Compliance Procedure CP-113, Handling and Controlling Work Requests and

Work Packages, Revision 39.

Compliance Procedure CP-114,' Procedure for Handling Permanent Modifica-

tions, Temporary Modifications, Modification Revision, Field Change

Notices, and Advanced Field Change Notices, Revision 41.

Compliance Procedure CP-115, In-Plant Equipment Clearance and Switching

Orders, Revision 49.

Outage and Modification Procedure, Manual M0P-502, Filing and Distribu-

tion of MAR Documents, Revision 2.

. Safety-Related Engineering Procedure No. 1 (SREP 1), Safety Identifica-

tion and 9esign Input Requirements, Revision 7.

-Safety-Related Engineering Procedure No. 6 (SREP 6), Preparation and

Control of a Modification Approval Record (MAR), Revision 7.

Preventive Maintenance Procedure PM-126, Electrical Checks of CRD Power

Train, Revision 11.

Preventive Maintenance Procedure PM-118, AC and DC Breakers, Control

Rod Drive System, Revision 11.

Surveillance Procedure SP-333, Control Rod Exercises, Revision 12.

The inspector confirmed that the licensee's program for Post-Maintenance and

Post-Modification Testing included the following elements:

Documents which relate to maintenance and modification activities

describe or reference the necessary testing prior to returning the

structure, system or component to an operable status. The documents

require a signature indicating satisfactory completion of

post-maintenance or post-modification testing prior to returning the

structure, system or component to an operable status. The documents

require a signature indicating satisfactory completion of

post-maintenance or post-modification testing before the document may

be . filed as a record. Criteria exist and responsibilities are delin-

eated_for review and approval of maintenance and subsequent maintenance

testing. This criteria is described in Compliance Procedure CP-113.

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Criteria exist and responsibilities are delineated for review and

approval of modifications and subsequent- testing. At present, this

responsibility is assigned to the project engineer in charge of each

modification. As a large volume of modifications are planned for the

upcoming outage, the project engineer is assisted by a post-modifica-

tion testing group which writes the procedures for post-modification

testing and the permanent surveillance procedures which will follow the

completion af the modification.

Criteria exist and responsibilities are delineated for inspection and

data verification of the testing by QA, QC, maintenance, engineering,

or other responsible and knowledgeable personnel. The inspection data

are routed back to the project engineer who has the responsibility for

acceptance of the data. In many cases, the project. engineer observes

the post-modification testing personally although procedures allow this

function to be assigned to other knowledgeable personnel.

Administrative controls exist for the preparation, documentation,

reviews, approval of results, transfer and retention of safety-related

maintenance and modification records in the records storage facility.

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The controls provide for the review of the modification or maintenance

. package, and identification of the personnel who were required to

inspect the work.

The inspector selected in process work request Nos. 61855, 61858, 61862 and

61865 for examination to verify that the work requests were documented,

reviewed and approved in accordance with Compliance Procedure CP-113. In

addition, these work requests were reviewed to verify that appropriate post-

maintenance testing had been specified when applicable. The above work

requests were found documented in accordance with procedure CP-113.

The inspector also observed preventive maintenance on a GE Type AK-25 AC

Control Rod Drive System reactor trip breaker. The maintenance was per-

' formed using preventative maintenance procedure PM-118, AC and DC Breakers.

The inspector observed that the electricians were knowledgeable of the

maintenance procedures and the AK-25 type breakers. The procedure contained

steps to verify the operation of the shunt and undervoltage trip attach-

ments. The procedure also required time response testing of the under-

voltage trip attachment; required breaker trip force measurements; provides

for additional testing of the breaker; and provides for lubrication of the

breaker. The inspector concluded that the craft performed the maintenance

in accordance with the procedure.

The inspector reviewed preventive maintenance procedure PM-118 to verify

that the procedure incorporated the latest GE and B&W recommendations. To

perform this review the following documents were reviewed:

Preventive Maintenance Procedure PM-118, AC and DC Breakers in the

Control Rod Drive System

Diamond Power Instruction Manual No. 135, Volumes 1 and 2

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General Electric Service Advisory dated March 21, 1984 (TAB 175,

No. 9.20)

General Electric Service Advisory dated April 2, 1979 (TAB 175,

No. 9.3)

General Electric Service Advisory dated April 15, 1983 (TAB 175,

No. 9.3 Supplement)

The inspector reviewed the above documents and identified the following

concerns:

' Preventive Maintenance Procedure PM-118 step number 7.4.3 incorrectly

references procedure step 7.4.6. The correct reference appears to be

procedure step 7.4.4. Procedure step 7.4.4 provides for verification

of undervoltage device operation and trip shaft torque measurements.

This information is important in establishing a trending program of the

breaker operation. The-inspector informed the licensee of this concern

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and the licensee immediately issued a temporary change to the procedure

correcting this procedure step. The temporary change is valid for 14

. days. The licensee has committed to have the procedure corrected

during the next revision.

Diamond Power Manual No.135, Volume II, is the manual at the site ,

which incorporates all the breaker maintenance requirements. The

inspector examined this manual and determined that the GE Service

Letter No. 9.20 has not been incorporated into this manual. However,

this GE Service Letter was used to develop procedure PM-118. The

inspector questioned the licensee.regarding this matter. The licensee

' informed the inspector that before this information can be tacorporated

into the technical manual for the breakers, it has to provided by B&W.

Diamond Power Manual No.135, Volume II, Control Rod Drive Control

System, Service Tip No. 3-79 requires a 15-second interval after

opening the breaker before reclosing of the breaker. This requirement

is in accordance with ANSI C37.13-73. The inspector questioned the

licensee regarding this matter to determine if this requirement has

been properly addressed in site maintenance and test procedures. The

licensee is still investigating this mhtter to determine if this

requirement is appropriate for the reactor trip breaker.

The above concerns were identified to the licensee as Inspector Followup

Item 50-302/85-07-04, Discrepancies In the Licensee's Program For Reactor

. Trip Breaker Maintenance.

The inspector reviewed the documentation for several modification approval

-records and their related functional test precedures. The test procedures

are controlled by a Procedure Review Record (PRR) and a 10 CFR 50.59 check

list. The PRR provides a description of the change, reasons and references

for the change, a safety evaluation, and a listing of the procedure approv-

als required.

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The PRR and the functional test procedures are guided by Compliance Proce-

dure CP-134. The following MARS and their test procedures were reviewed:

Procedure 80-11-40-1, MAR Functional Test Procedure for NNI/Y Back-Up

Power Supplies.

Procedure MAR 83-08-29, Revision TP1', MAR Functional Test CRD Breaker

ShJrt Trip Addition.

Procedure 80-10-66, Emergency Feedwater Initiation and Control.

Procedures MAR 83-08-29 and MAR 80-10-66 were still in the working stage

and, as such, the procedure approvals were still not complete. However, in

- discussions with the project engineers and through a review of the proce-

dures, it was noted that CP-134 was being interpreted differently by differ-

ent oroject engineers. Specifically, some engineers followed the methods

outlined in CP-134 verbatim, while other project engineers used it more

loosely as a guide. This different interpretation appeared to be caused by

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the use of the words " MAR Writers' Guidelines." The guidelines, howeve.~,

were procedures using the word "shall" for instruction in writing proce-

dures. The problem of interpretation was discussed with the supervisor of

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the project engineers and also mentioned in the exit interview. The super-

visor of the project engineers stated that CP-134 would be reviewed and the

ambiguity clarified. This concern will be examined by the resident inspec-

tor during future inspections.

The inspector _ reviewed several completed MAR packages in the document room.

These MARS were reviewed for testing procedures, procedure approval signa-

tures, and for proper compliance with procedures. The following MARS were

reviewed:

MAR 84-05-05-01, Alternate Gasket Material for RWV-34 thru 38.

MAR 83-05-21-01, Emergency Diesel IB.

MAR 82-07-09-01, Moving Check Valves in the High Pressure Injection

Lines 5 Inches Upstream from the HPI Nozzle.

MAR 84-07-07-01, Hurricane Protection Watertight Gates - 8A and 8B

Modification.

No deviations were identified in the review of these completed MARS.

The inspector reviewed the Control Rod Drive (CRD) breaker shunt trip

addition modification package to confirm that the vendor post-modification

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. testing was incorporated into procedures. The test procedures were provided

in Babcock and Wilcox letter from M. R. Stephens to R. A. Webb, dated

June 26, 1984. These procedures were used by the project engineer in

establishing the reactor trip breaker post-modification test procedures and

- the surveillance procedures.

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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 inspector confirmed that the licensee's surveillance procedures require

on-line functional testing of the undervoltage trip feature and the silicone

controlled rectifier (SCR) circuitry. The procedures reviewed are identi-

fied as follows:

Preventive Maintenance Procedure PM-118, AC and DC Breakers Control Rod

Drive System, Revision 11

Preventive Maintenance Procedure PM-126, Electrical Checks of CRD Power

Train, Revision 11

Surveillance Procedure SP-110, Reactor Protection System Functional

Testing, Revision 56

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Surveillance Procedure SP-112, Calibration of the Reactor Protection

System

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In addition to the above, the licensee has scheduled the shunt modification

to be -installed during the upcoming refueling outage. The shant modifica-

tion will provide for. independent testing of the shunt and undervoltage trip

attachments, as well as testing the SCR circuitry.

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

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