ML20127G331

Insp Repts 50-348/85-17 & 50-364/85-17 on 850318-22. Violation Noted:Failure to Follow Procedure FNP-O-AP-52 on Maint Work Request 107514

ML20127G331
Person / Time
Site:	Farley
Issue date:	04/17/1985
From:	Bibb H, Conlon T, Foster L, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127G286	List: ML20127G284 ML20127G298 ML20127G331
References
50-348-85-17, 50-364-85-17, FL-83-28, GL-83-28, NUDOCS 8505210037
Download: ML20127G331 (18)

See also: IR 05000348/1985017

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UNITED STATES "

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' NUCLEAR REGULATORY COMMISSION

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g 'j^ 101 MARIETTA STREET, N.W.

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ATLANTA, GEORGI A 30323

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' Report Nos.: 50-348/85-17 and 50-364/85-17

Licensee:- Alabama-Power Company _ '

'600 North 18th Street

[,  : Birmingham AL 35291

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley 1 and 2'

Inspection Conducted: March 18-22, 1985

. Inspection at' Farley site near Dothan, Alabama

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Inspectors: -

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L. E. Foster Team Leader Date Signed

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N._Merriwe fier D8te Signed-

EW /??L /O/ 7-ff

H. Bibb

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Date Signed

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JConsultant: P.-M. Ch -Lawrence Livermore National Laboratory i

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Approved by /

~ T. E.' Conlon, SecTion Chief

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1. -#g Aft / YDate/ Signed.

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, . Engineering Branch

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Division of Reactor Safety

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SUMMARY

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

• ' site concerning licensee response to Generic. Letter 83-28 Required Actions Based

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on Generic Implications of- Salem Anticipated Transient without Scram (ATWS)-

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

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, ivendor~ interface and manual control; post-maintenance testing; and reactor trip

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system reliability.

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i Results: One violation was identified - Failure to-Follow Procedure FNP-0-AP-52

.i i on Maintenance Work Request No. 107514 - paragraph 8.c.

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'505210037 850423

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PDR ADOCK 05000348

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REPORT DETAILS

1.- Persons Contacted

Licensee Employees

• D. N. Morey, Assir tant Plant Manager - Operations

• W. B. Shipman, Assistant Plant Manager - Support

• B. R. Yance, Section Supervisor - Electrical

• W. G.. Ware, Safety Audit Engineering Review (SAER) Supervisor

• L. A. Ward, Maintenance Superintendent

L. Williams, Training Representative

L. Bradshaw, General Plant Technical Service (GPTS) Supervisor

• R. D. Hill, Operations Supervisor

K. Kendricks, General Plant Technical Service (GPTS) Technician

C. Nesbitt, Technical Superintendent

J. R. Gibson, Electrician Foreman

S. Taylor, Electrician

R. Rogers, Computer Services Supervisor

L. M. Stinson, Modification Supervisor

R. G. Berryhill, System Performance and Planning Superintendent

J. Hudspeth, Document Control Supervisor

J.. Luckie, Electrician

R. Cobb, Document Control

• P. W. Trotter, Systems Engineer

R. Morrow, Planner-

-D. Sherer, Planner

H. R. Garland, Mechanical Supervisor

T. W. Cherry, I&C Supervisor

• B. W. Vanlandingham, Unit 2 Supervisor

L. Enfinger, Materials Supervisor

R. Johnson, Systems Engineer

Other licensee employees contacted included engineers, technicians,

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

personnel.

NRC Resident Inspector

W. Bradford, Senior Resident Inspector

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• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March 22, 1985, with

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

areas inspected and discussed in detail the inspection findings listed

below. The licensee had dissenting comments which are discussed in

paragraph 8.c.

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Violatibn 348/85-17-02,. Failure to Follow .. Procedure FNP-AP-0-52 on

Maintenance Work Request No.~107514 - paragraph 8.c.

. Inspector' Followup Item 348, 364/85-17-01 Training Licensed Operators on

Interpretation of Printout Data - paragraph 5.

Inspector Followup Item 348, 364/85-17-03, Review of Vendor Manuals (DS-416

Breakers) To Determine Applicability to the As-Installed DS-416 Breakers -

paragraph 7._ 1

Inspector . Followup Item 348, 364/85-17-04, Review of . Vendor Manual

.No. U212498 and Revision Notices to Ensure Incorporation of Approved

Revisions - paragraph 7.

Inspector Followup Item. 348, 364/85-17_05 . Evaluate and Revise Procedure

MP-28.114 to Include all Vendor Recommended Measurements and Include

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Measuring Equipment List'in the Procedure - paragraph 8.

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

or reviewed _ by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. 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

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trip attachment (UVTA) located inside the breaker cubicle. Due to problems.

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L 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

j on immediate-term actions to ensure reliability of the RTS.- Actions to be '

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

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

RTS reliability improvements. . The -licensee responded to Generic Letter 83-28 by correspondence with the following dates: September 6 and

November 4,1983; and February 6, February 15, and June 25, 1984. This

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inspection was performed to review Alabama Power Company (APCOs) current

l _ program, planned program improvements, and implementation of present

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procedures associated with post trip review equipment classification, vendor

interface, post maintenance testing, and reactor trip system reliability for

.the Joseph M. Farley Nuclear Plant - Units 1 and 2.

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5. . Post-Trip Review

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The licensee was requested in_GL-83-28 to describe their program procedures

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. and _ data collection _ capbility- to assure that the causes for unscheduled

reactor shutdowns, as well;as the response of safety-related equipment, are '

fully understood prior to plant restart. The_ licensee's response to

GL 83-28 :gives' a detailed -description of the program - and procedures

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pertinentL to performing post-trip - reviews. The inspector reviewed their

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resp'onse. appropriate procedures, and interviewed responsible licensee

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personnel to assess. the adequacy of the licensee's program for post-trip

reviews. The result of this inspection are identified below:

The licensee has prepared and revised several procedures to more clearly

define responsibilities, authorities, methods of assessment, training, and

equipment needed to perform a timely technical post-trip review.

' Administrative Procedure FNP-0-AP-16,' Revision 13. " Conduct of Operations -

Operations Group," provides a clear and concise description of the actions

to .be taken by the shift supervisor subsequent to a reactor trip. These

actions include:

Ensure that the plant is placed in a safe condition (Reactor Trip

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Procedure FNP-1-E0P-5.0)

b. Notify the Emergency Director

c. Make other off-site notifications as required

'd. Direct a review of plant conditions prior to,_ during, and subsequent to

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the trip to detennine the cause and to verify proper operation' of all

systems

Administrative Procedure FNP-0-AP-30, Preparation and Processing of Incident

Reports, Plant Event Reports and Licensee Event Reports, specifies ,the

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requirements for the preparation and processing of reports. A Reactor. Trip ,

Report and Incident-Report must be completed upon a reactor trip and the

Emergency Director must give permission prior to returning the-reactor to a

critical state. If the review and analysis by the Shift Supervisor does not

positively determine the cause of the transient or verify proper operation

and response of the reactor and associated equipment systems, it will be the

responsibility of the on-call Emergency. Director to determine the need for,

and the. appropriate individuals or group for, independent assessment of the

trip.

The completed Reactor Trip . Report 'must be accompanied by the computer

post-trip printout, the alarm typewriter printout, the sequence of events,

and incident report. This package is prepared by the shift supervisor,

reviewed by the_ Operations Supervisor, Unit Supervisor and Technical Group

' Supervisor, and finally reviewed within 30 days by the Systems Performance

Supervisor.

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The.planIfor return to power includes (a) any corrective action required to

correct the cause of the trip, (b) any maintenance required and (c) any

surveillances required to change modes. Other plant procedures associated

with post-. trip review were examined and are listed below:

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FNP-1-E0P-5.0 Reactor Trip

FNP-1-E0P-15.0 Anticipated Transients Without Trip (ATWT)

FNP-0-AP-3 Plant Organization and Responsibility

FNP-0-AP-45 FNP Training Plan

-Plant personnel involved with the preparation or review of post trip review

documentation receive initial . and refresher training in post-trip review

- procedures through a formal program for licensed operators. FNP-0-AP-16

delineates the qualifications and training required for personnel

participating in the post-trip review process. Specific duties of key

individuals are identified in FNP-0-AP-3 and FNP-0-AP-16.

Discussions with the training department indicated that formalized training

has been conducted for the engineering staff in the systems performance

group on the interpretation of information available from the sequence of

events and post-trip printouts. Further discussions revealed that the above

formal training was not being given to the licensed operators. Until formal

training on the interpretation of information available from the Sequence of

Events and Post-Trip printouts is incorporated into licensed operator

training, this will be considered an Inspector Followup Item 348,

364/85-17-01, Training on Interpretation of Printout Data.

A review of training records revealed that records of initial and

requalification training were being maintained.

The sources of plant information necessary to conduct a review and analysis

of a transient causing an unscheduled reactor trip include:

a. The plant computer alarm typewriter printout,

b. The plant computer sequence of event report,

l c. The post-trip report,

j d. The main control board recorders,

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e. An interview of on-duty plant operators,

f. The plant operator's log,

g. The listing of any outstanding limiting condition of operation, and

h. The listing of any major maintenance currently in progress.

In the event that the plant computer alarms typewriter (sequence of events

j recorder)' is out of service, the computer will automatically dump its

information to the following printers in descending order of preference:

a. Trend typewriter

i b. Line printer

j c.. Auxiliary typewriter

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The licensee stated that the capability to gather and analyze post-trip data

and gain:more precise time separation between distinct occurrences will be

enhanced with the installation of the safety parameter display system, which

is expected to be installed in mid-1986.

The post-trip review package, after completion of review by the system

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performance group, ;is forwarded to document control for permanent retention

within 30 days of the trip. Additionally, a 1.icensee event report (LER) is~

< generated for~each reactor trip. The inspector reviewed 11 post-trip review

packages to- verify thoroughness of preparation and proper preservation of-

physical evidence needed to perform post-trip reviews. While it.was found

' that all necessary. data were preserved, it was noted that- the record keeping

' was - a bit fragmented and difficult to track down. A given-incident is.

. presently filed in' the-Quality Control (QC) vault by two different methods,-

'(a) by the incident report number and (b).by_the reactor-trip number. [The

supporting evidence is sometimes filed with (a) and other times with (b).

The disadvantage of not using a singular filing method was discussed with.

thelicensee.]

-The inspector inquired and found that incident reports, reactor-trip

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reports, and Licensee Event Reports (LERs) are routed through the training

department for possible incorporation into site specific simulator training

for new or.requalified licensed operators. The classic ATWS incidents are

also simulated for training purposes.

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

6. Equipment Classification

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

for equipment classification. Their response described the following:

The- program for identifying safety-related systems and components at Farley

is contained within plant procedures, design procedures, the- Operations

Quality Assurance Policy Manual, and Section 17.3 of the APC0 Final Safety

Analysis Report (FSAR). The systems utilized by the licensee to identify

safety-related components consists of the Q-list, safety-related

classification numbering, design documents, and prior procurement packages.

The inspector conducted a review of appropriate licensee procedures and

records 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 inspector confirmed that

. the licensee's program for equipment classification iceluded the following

-elements:

Plant and component controls for classification of structures, systems,

and components as safety-related were being implemented.

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' The-licensee has devel'oped a program-to assure that safety-related .or

non-safety-related maintenance activities are identified during the-

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planning stage.

The 'Q-Listing' is' reviewed by design personnel during the modification.

process .to' determine -if the; modification affects safety-related

structures, systems or components.

Personnel participating in: activities impacting safety-related

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

of QA controls.

i- Written directives. assigned principal responsibility for. satisfactory

- completion of procurement, maintenance, and modification activities

associated with safety-related structures, systems, and components.

' Repairs, - maintenance, or modifications to equiptient to correct

. failures, malfunctions, ' deficiencies, deviations, defective- material

and equipment, and nonconformances were performed, documented, and

reviewed to determine reliability of replacement components.

L The inspector examined the following procedures and docuaents:

Administrative Procedure FNP-0-AP-52, Equipment Status Control and

Maintenance Authorization

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- Administrative Procedure FNP-0-AP-8, Design Modification Control

Administrative Procedure FNP-0-AP-9, Procurement and Procurement

2 Document Control

Q-List, Section 17.3 of FSAR-

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l  : Maintenance Work Requests Nos.-101440, 101441, 101442,.101443, 35789,

K 37166, 24040,.19393, and 88454

Purchase Order Nos. 13627 and 35957~

Plant Change Notice PCN-B-83-2410

Maintenance Procedure FNP-0-NP-28.114, Inspection, Maintenance and

, Testing of Reactor-Trip Breakers

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L The information systems utilized at Farley Plant to identify safety-related

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- components are identified as follows:

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Safety-related Q-List contained in Section 17.3 of the FSAR

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Total Plant Numbering System Safety-Related Classification Numbering

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Prior _ Procurement Packages *

Design Documents

The FNP Q-List identifies safety-related systems, major components,

supports, and structures. The Q-List also . identifies categories of

safety-related components which are not explicitly identified within the

Q-List. Changes and additions to the Q-List are initiated by design changes

' to the . plant. .The Q-List is controlled and updated as part of the FSAR.

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- The Q-List is considered by the inspector to be very general ..in detail. The

-licensee acknowledged .the inspector's observations and stated that manage-

-ment was considering'developement of a more detailed Q-List.

The Total iPlant Numbering System ('TPNS) is another method used by the

licensee.~ for. identifying safety-related or nonsafety-related components.

EThe TPNS. classification numbering is assigned by the licensee's design

l organizations as part of the design process. The TPNS numbers consist of a-

"Q" or. "N" prefix followed by a unit designator (i.e, Unit 1 or 2), a

three-character code for identifying the system, and additional characters

which identify the component type and unique. component identification. The

TPNS numbers for safety-related components are identified with a "Q" prefix-

and nonsafety-related components are-identified with a "N" prefix. The TPNS

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classification numbering is given in design documents such as the electrical

equipment index,- instrument index, _ design drawings, and equipment

specifications.-

Discussions with the licensee-revealed that the reactor-trip breakers do not

have unique TPNS numbers. The TPNS numbers are assigned to each train of

the reactor trip switchgear. In addition, the TPNS numbers assigned to the

- reactor trip switch and full length ~ rod motion control switch have

non-safety; TPNS numbers._ The . inspector asked the licensee ~ if. these

nonsafety. TPNS . numbers would be upgraded to safety-related. The licensee

indicated that there were no plans to revise the TPNS numbers for these

components at this time.

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The licensee's Administrative Procedure FNP-0-AP-52 is the procedure used

for identifying, . controlling, scheduling, authorizing and documenting

maintenance. ~This procedure requires the TPNS number and equipment name be

~1dentified on the Maintenance Work Request (MWR)-Form.- The TPNS number is

used . by the licensee on the MWR form to identify safety-related or -

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nonsafety-related equipment. The TPNS number is the only safety

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_ classification given on the MWR fonn. The reviews and approvals required

for ' safety-related and nonsafety-related maintenance work requests are

p basically.the same. However, one distinguishing difference exists on the

handling of MWRs for safety-related equipment that cannot be functionally

tested following completion of, work due to plant conditions. The procedure

also identifies critical plant systems and the special pre and.

post-maintenance requirements.

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The. inspector'~ selected MWRs 101440, 101441, 101442 and 101443 - which

-described work to be done on the Undervoltage Trip Attachment (UVTA). These

MWRs' were examined to verify that the maintenw:e activities were performed -

and . documented in accordance with procedure FNP-0-AP-52. ~The above MWRs

.were issued to replace the UVTAs on the reactor trip breakers for Unit 2.

Replacement of the UVTAs . eliminated the requirement to cool the UVTAs with.

compressed N2fduring performance of surveillance procedures STP-33.2A and B

to lower the resistance of. the coil so that breaker closing could be

accomplished. All records were found to be documented and approved in

'accordance with the above procedure.

Administrative Procedure FNP-0-AP-9 is the procedure used by the licensee to

' administratively control the procurement of assemblies, parts, material,

supplies,'and services. This procedure applies to both safety-related and

. ~ nonsafety-related procurement of components and services. The procedure

t provides criteria- to determine the -QA review codes and the safety

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classification for assemblies, parts and services. The procedure identifies -

.the following QA code classes:

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Code A. Safety-Related or Nonsafety-Related .

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Code C, Nonsafety-Related

, Code D.-Nonsafety-Related  ;

The procedure references the Q-List, Westinghouse NSSS Spare Parts Report, ,

and ANSI N18.2-1973 as documents to use in making the QA Code determinations '

! and safety classifications. In addition, the procedure gives description of ,

categories of assemblies, sub-assemblies and parts that are considered

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. safety-related and QA Code A. Likewise, the procedure provides descriptions-

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.of the' components that are considered QA Codes Class C and D. The procedure

,. also provides controls .for the review, approval, revision 'and storage .of

procurement documentation. - The inspector reviewed the records associated

with purchase order Nos.13627 and.35957 to verify compliance with the above

procedure. Records examined were documented, reviewed and approved in

, accordance with procedures.

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

-7. 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:

-Licensee response dated February'15,1984, stated that the majority of the

.NSSS components were originally supplied by Westinghouse (W) and that

current -updates were supplied by W Technical Bulletins. l'he licensee

-acknowledges receipt of the information by written confirmation. All

technical information received from other vendors which has an impact on

,  ; plant design, maintenance, and safe operation is distributed to appropriate

i - . licensee organizations, Bechtel, and Southern Company Services for review

and action..

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Further-licensee f responses dated June 25,1984, stated that APC0 is an

active member of the Nuclear Utility Task Action Committee (NUTAC) which has

formulated the Vendor Equipment Technical Information Program (VETIP). This

program utilizes existing utility / vendor contact, the. Institute _of Nuclear

Power : Operations (INPO) managed Nuclear Plant Reliability Data. System

(NPRDS),' and Significant Event Evaluation and Information Network (SEE-IN)-

' Program.

The inspector reviewed licensee procedures relative to control of vendor ~

- technical information to determine if they were consistent with his

responses.- Results of examination of procedures 'and interviews with

personnel revealed the following:

a. The licensee had not contacted every vendor of safety-related equipment

to: determine if the vendor technical manuals on site contained the

latest technical information, but was using information from the INP0

administered NPRDs and SEE-IN Programs. Westinghouse was contacted and

.the licensee held extensive meetings concerning NSSS equipment. The

licensee had also contacted Colt Industries and General Electric

Company (GE) concerning equipment supplied _by them. The licensee had

developed some procedures to ensure adequate review of technical

infomation received, and the control and use of this information by

~p lant_ personnel,

b .~ - The licensee had developed Administrative Procedure FNP-0-AP-65, -FNP

Operating Experience Evaluation Program. The objective of this program

was to ensure that lessons learned from industry were used at FNP'and

that lessons learned at FNP were transmitted to other licensees.

Fomal vendor infomation programs have been established with W, GE and

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Colt Industries'. The licensee has a special group (NETS) that receives

technical information and transmits this information to the System

Performance Group for action. Other groups have. been assigned

responsibilities for reporting, reviewing, and ' utilizing technical

information from such as W Owners Group, INPO, NRC, and vendors.

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c._ FNP-0-AP-65, Revision 3 dated February 7,1985, assigns plant staff

responsibilities for assuring that vendor technical information is

properly evaluated and handled. This procedure also lists applicable

plant procedures which control and further describe the responsibili-

ties for receiving, distribution, transmittal, and use of vendor

technical information originating from vendors, INP0, other industry

sources, W. Owners Groups, and FNP sources. Paragraph 16 of the

procedure assigns the QC Supervisor the responsibility of perfoming a

program effectiveness review on an annual basis. The inspector

questioned why some technical manuals had not been reviewed per AP-65.

Discussions revealed that vendor manual review verification was only

being performed on new technical manuals and revisions to old manuals.

Based on review of this procedure, the licensee appears to have

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provided a means to effectively evaluate .and control current vendor'

technical information; however, the massive amount of old vendor.-

manuals, bulletins, etc., may present problems if not reviewed and

deemed applicable to installed equipment.

d. Administrative Procedure FNP-0-AP-4, Control of Plant Documents and

Records, . Revision 8, .was. presently undergoing review- by the plant

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staff. This procedure establishes controls to assure satisfactory -

receipt, processing, distribution, storage, and retention of documents

including vendor manuals and other correspondence related- to vendor

technical information. The procedure review request form from AP-1 and

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' the 10 CFR 50.59 evaluation for AP-4 were reviewed and found to be

satisfactory. AP-4 and AP-65 appear to ensure control of documents and

records. The inspectors examined selected technical manuals, plant

procedures, the control and use of these manuals,' and procedures to

-determine if the controls were adequate and being implemented. Two

Inspector Followup Items were identified and are discussed in the

following details.

e. Examination of Technical Manuals (Instruction Books) Associated with

the Low Voltage Switchgear (Type DS-416 Breakers) revealed the-

following:

-(1) The same manuals are filled under different "U" numbers thereby-

making it difficult to determine which manuals are- valid,

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up-to-date, and applicable to the installed equipment.

(2)- Measurements _to be taken during maintenance and testing of the

' breakers are not consistent in each instruction book (IB). An

example is that the measurement of the gap between the stationary

arcing contacts is not required in IB U260232A and IB U215471A but

is required in IB U185040.

(3) Two different Architect Engineers have reviewed and approved the

switchgear IBs without documented interfacing.

(4) -It is not apparent that the switchgear IBs (older IBs) have been

reviewed per AP-65. The licensee's statement that the plant

procedures reflect the current IB technical information was not

attached to the IBs.- Note: AP-65 only requires new IBs or

revisions to old IBs be reviewed.

(5) Instruction Books did not- contain a chronological list of

revisions or applicable changes implemented; therefore, a

. component history file was not readily available.

The licensee agreed to review the current instruction books being used

to determine if the IBs reflect the as-installed DS-416 breakers. This

is considered Inspector Followup Item 50-348/364-85-17-03, Review of

Vendor Manuals of D5-416 Breakers.

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f.- - Other technical manuals (Instruction Books), vendo'r correspondence, A/E

correspondence, and' review approval forms were reviewed in the Central

File Area are listed below:

IB No.'U185040, controlled copy No. 40

IB No. U276623

Volume

Services Letter dated 3, Book

January 314, T985W Instruments and Southern Company

IB No. U184699, Plant Lighting Switch' gear, Controlled Copy No. 2

IB No. U184789 and.260098, Indoor Low Voltage Metal Enclosed Switchgear

IB No. U185031, Switchgear Renewal Parts Data, Controlled Copy No. 003.

This manual had been updated by a supplement dated July 1981

. Technical Data Transmittal Sheets from Bechtel and Southern Company

Services concerning incorporation cf Plant Change Notices (PCNs) and

Plant Change Requests (PCRs) into technical manuals

Vendor Manual / Drawing Review forms confirming plant departments review

of manual Nos. U162880, 162888, 176697, 184852, 198768, and U214177

The Central File also maintains a computer list of who has checked out

a controlled manual and if the user has returned the copy within the

14-day requirement. Document transmittal form (AP-4, App. B) is used

to transmit documents and record receipts of documents. To further

assure manual control, the Document Control Supervisor issued a letter

dated March 20, 1985, to all supervisors requesting them to review and

verify that the manuals in their possession agree with the current

transmittal form.- Central Files keeps a file card (pink card) on each

manual ~ and keeps updated with the latest revision number and date

received. Central Files personnel were knowledgeable of procedures.

-retrieved documents in a timely manner, and demonstrated the appli-

cation of the document control program,

g. The inspector examined the documentation packet which contained-

information on the H Inner-Cooled Turbine Generator, W

Instruction Book (IB)ydrogen

20891 U No. 212498. Although this is a

nonsafety-related component, this examination was made to determine if

a typical document packet contained the latest information such as

revisions, approval forms, change notices, and vendor correspondence.

Results of examination revealed that the document packet contained

instruction books, three revision sheets, insert instructions, a list

of PCNs affecting the instruction book, status of PCNs (approved or

completed), review foms . signed by Bechtel and Southern Company

Services, and vendor a letter notifying licensee of a manual change.

Further examinations included a detailed check of the IB contents

against the approved revision changes to determine if the approved

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changes were being incorporated into the IBs. This review revealed-

that Revision 2.of the Hydrogen Wiring Diagram, No. 1124J51 Figure 1A,

' had been userted into the . IB .without technical justification for.

deleting Revision 1 and . inserting Revision 2.- The licensee agreed to

review the subject IBs and. plant procedures associated with the

Hydrogen System to assure that. technical data has been incorporated.

-This,is Inspector Followup Item 50-348,364/85-17-04, Review of Manual

.No. U212498 and Revisions.

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

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'8. . Post-Maintenance Testing

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

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and activities to verify that the commitments in the licensee's response to

. Generic Letter.83-28 were being implemented at Farley Nuclear Plant. -The i

-inspector examined procedures 'and completed maintenance records,

participated inLa complete maintenance and test of a DS-206 Westinghouse

circuit breaker, and interviewed pertinent licensee personnel to determine

the adequacy of the licensee's post-maintenance test program. The results

of the inspection are as follows:

a. Demonstration

Maintenance Procedure FNP-0-MP-28.114. was used to - demonstrate a

complete (walk-through) maintenance and test on a DS-206, 800A frame

circuit breaker. This type of Westinghouse breaker is similar to the

DS-416, 1600 A frame . breaker used in the reactor trip protection

system. The main differences were the DS-206. breaker used in the

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. demonstration did not have an undervoltage trip attachment and an

operations counter.

In the course of the inspection of the breaker contact. system, as -

delineated in paragraph 4.8.1 of MP-28.114, the inspector noted that

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the licensee's test engineer did not physically perform a measurement ,

of the gap " dimension A" as specified in paragraph 4.8.1. of the ,

procedure which stated that the gap must exceed 0.020 inches. The test  !

, engineer visually observed the gap dimension and determined that the

i gap exceeded 0.020 inches and recorded it. The inspector questioned

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the method of measuring and was advised that the gap in question was so ,

obviously over 20 mil that an actual measurement was unnecessary. The

iL inspector requested that -an appropriate gauge be used to confinn the

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dimension; however, a suitable feeler gauge could not be located until

[ the next day. Subsequent measurements by feeler gauges of six gaps

! revealed readings of 0.080, 0.071, 0.071, 0.049. 0.033, and 0.025 ,

! . inches. . It was noted by the inspector that the 0.033 and 0.025 inch l

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l measurements were not obviously over 0.020 inch as gauged by the human

eye. The inspector questioned the accuracy of the gap measurements

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taken on previously inspected breakers. Review of data and discussions

with supervisors revealed that previous gap measurements were performed

with a feeler gauge. and . the gap dimension exceeded 0.020 inch as

required. The' use of measuring equipment is discussed further in this

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report.

Also 'during' the demonstration of the maintenance and testing of the

DS 206 circuit. breaker, the inspector noted the electrician applied the

lubricant with his forefinger and smeared it around the levering device

arm. on the breaker. The licensee was advised that this was. poor

practice as the lubricant and mechanism becomes contaminated when

applied by the fingers. A review of the procedure revealed that the

application of lubricant and solvents is left to the technician's

judgment which is another poor practice.

Trending ~ of parameters from Maintenance Procedure FNP-0-MP-28.114 was

non-existent at the Farley Nuclear Plant. Although GL 83-28 specifi-

cally stated in paragraph 4.2 that the licensee's preventative mainte-

nance program shall include trending of parameters measured during

testing to forecast _ degradation of operability, the licensee only

trends failures and since at Farley there was no failure to date, no.

trending.had been done. The use and effectiveness of trending parame -

'ters (besides failures) were discussed with the licensee and they were

advised that their response did not adequately address trending;

however, the resolution of their response would be performance by NRC.

Nuclear Regulation Branch.

b. Procedure Review

Procedure FNP-0-MP-28.114, Inspection, Maintenance and Testin

Reactor Trip Breakers, Revision 5, was reviewed to determineif (1)g

theof

. procedure reflected vendor technical manual requirements and (2) if the

procedure, if implemented, would help assure reliability of operation.

Results of the procedure review revealed the following:

(1) Reference 2.2 in the procedure has a typographical error as the

Field Mounting Instruction should be W Drawing 588C785 instead of

588C784. This appears to be a minor error, but copld result in

problems if the referenced drawing were used.

(2) Paragraph 4.3 allows the technician to determine what solvent to

use and to determine if the solvent will damage the electrical

component. Approved solvent should be specified by engineering.

(3) Paragraph 4.8, Inspection of Contact System, nor Attachment 4

requires the dimension between the arcing contacts to be measured;

however, vendor Instruction Book U No. 185040 specifies that this

gap dimension be 0.42 1.080 inches. The vendor's instruction

books U260232A and U215471A do not require that the gap measure-

ments be taken.

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j (4) Paragraph ~4.8.1 does not specify. how. dimension "A" will be veri-

- fied that it exceeds'0.020 inches, nor how the 1/32" thickness of

the main. contacts will be. measured. No tools are specified in the

- text or in the data sheets. _ The technicians -did not have 'any

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measuring tools to demonstrate measuring or to confirm that the

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gap

dimension exceeded 0.020 inches.

(5) Paragraph 4.9.3.1 does not specify how the 0.030 inch dimension is

measured or..what type of instrument is needed. Also the statement

"theLgap should be 0.030 minimum" should be similar to the state-

- ment in paragraph 4.8.1, " Dimension A must exceed 0.020 inches."

-These statements could result in misinterpretation by the proce-

dure ~ users.

-(6) Paragraph 4.19 specifies:the type of lubricant to be used and some .

precautions; however, no caution is made concerning the contami-

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nation of lubricant if applied by. fingers.

! -(7) Some special tools (bent wire gages) are used but are not speci-

l - fied .in the procedure. The above items. were discussed with

l licensee personnel. Justification for not.specifying measuring

! tools and how to measure the required dimensions was presented to

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the inspectors; however, the licensee agreed to re-evaluate the

procedure in regard to the inspector's concerns and to revise the

procedure as necessary. Until the procedure is reevaluated, this

is Inspector Followup Item 50-348, 364/85-17-05, Evaluate and

Revise Procedure-FNP-0-MP-28.114.

Other procedures reviewed are listed below:

Administrative Procedure FNP-0-AP-1, Development, Review and

Approval of Plant Procedures, Revision 16.

Administrative Procedures FNP-0-AP-65, FNP Operating Experi-

ence Evaluation Program, Revision 3.

Surveillance Test Procedure FNP-1-STP-640, Containment Spray

Pump Discharge Check Valve (Q1E13V002A and B) Full Stroke

Test, Revision 1.

Maintenance Procedure FNP-1MP-49.0, Inspection and Repair of

Accumulation Discharge Check Valve Q1E21V032A, B or C,

Revision B.-

Instrument Maintenance Procedure FNP-0-IMP-438.3, Valve

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-Actuator and I/P Calibration-(Generic)3 9evision 0.

Instrument Maintenance Procedure FF-0 MP-206.9, RHR Bypass

Flow control Q2E11FT0605A, Revf a a 4.

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c. Review of Maintenance Work Request (MWR)

The' inspectors examined - several safety-related MWRs and associated

procedures to determine procedure . adequacy and implementation. One

-violation and several concerns associated with the processing and

implementation of MWRs were identified and are discussed below:

(1) ~ MWR 62891 - Repair of Check Valve - dated 1/21/83

(a) Check Valve Inspected TPNS Number was not entered on both

pages 1 and 2 of the completion sheets. The licensee ex-

plained this as an oversight and that the ' number would be

entered on both pages.

(b) On page 1 of the completion sheet, a signature was used to

sign off the line on the valve body cleaning. However, the

date was left out. The licensee explained this as an over-

sight and that the importance of dating documents signed

would be discussed with plant personnel.

(2) MWR 83484, Maintenance on Containment Spray Pump Check Valve,

dated 1/4/84

No problems were identified with this MWR,

-(3) MWR 107514, Main Feed Regulator Bypass Valve IC, dated 3/13/85

(a) Item No. 20, " Clearance for Work," was not checked off as

specified in Section 7.5.3 of FNP-0-AP-52. The fact that

such clearance information could have been incorporated into

Item No. 33 did not apply in this case. It was stated'in

Item No. 33 that no special plant conditions need be required

for the work. Clearance for work was not alluded to in Item

No. 33. The licensee explained at the exit meeting that this

was an oversight; however,'the inspectors feel that Item 33

means operating plant conditions and has no connection with

Item 20, clearance for work. The licensee agreed to review

the procedure and revise to eliminate misinterpretations.

(b) Item No. 23, " Work Sequence," originally referenced the

use of Procedure IMP-215.14. Upon review of the data pack-

age, the inspector noted that Procedure IMP-438.3, had been  !

used, instead of 215.14, without the MWR being revised and j

re-approved as required by Section 7.5.16.1 of FNP-0-AP-52. '

This is considered a violation. The licensee disagreed with

this violation and stated that the procedure was only a

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reference; therefore, the MWR did not have to be revised to ,

indicate the new procedure (IMP-438.3). The licensee also  !

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stated that NRC inspectors were misinterpreting their admin-

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istrative procedures; however, the licensee committed to

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revise Procedure FNP-AP-0-52 to clarify how references are to

be used when specified on Maintenance. Work Requests. The

inspectors acknowledged the licensee's comments and agreed-

that further clarification to the procedure'would be appropri-

ate. ! At the conclusion of the exit, this item was considered -

an Inspector Followup Item; however, subsequent in-office

review and evaluation of this matter concluded that the

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licensee violated Procedure FNP-AP-0-52, Revision 5.

The licensee was informed of this violation by telecon on

April 15,1985. This is identified as Violation 348/85-17-02,

Failure to Follow Procedure FNP-AP-0-52 on Maintenance Work

Request-No. 107514. In addition to the above, the. inspectors

, - had concerns on the adequacy of " adjust as needed" to

describe the work sequence as this instruction could lead to

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personnel-errors and mis-adjustment of equipment.

.(4) MWR 107679, RHR.HX Bypass. Flow Control, dated 3/11/85

(a) One page 2 of the data package, both " Table 1" and " Table 2"

are listed on :the same page, are directly adjacent to each

other thus making page 2 very congested. The licensee stated

that Table 2 would be deleted.

(b) The standard data package consists of 'nine pages which are

normally needed to complete a maintenance . test. Since this

MWR necessitates a limited amount of work on the equipment,

it appeared to warrant the use of a partial- data package

which consisted of four pages. It was nevertheless noted on

+ the front page that the data package contained nine pages;

however, only four pages could be found in the package. The

reasons for including all nine pages in the data package and

marking ' the sheets not needed as "NOT APPLICABLE" was dis-

cussed with the licensee.

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Surveillance Testing Of The Diverse Reactor Trip Functions of the Reactor

TripSwitchgear(RTS)

The inspector confirmed that the licenseeJs surveillance procedures require

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Ltesting of the shunt trip attachment and the licensee verifies the ability

, to manually' trip the RTS ' breakers by independent use of the undervoltage

trip attachment ^ or shunt trip device. The surveillance procedures are

. identified as follows:

Surveillance Test Procedure, STP-33.2A, Reactor Trip Breaker Train A

Operability Test

Surveillance Test Procedure, STP-33.2B, Reactor Trip Breaker Train B

Operability Test.

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- Discussion with the -licensee revealed that Plant Change Notices PCN -

83-1-1421,.PCN 83-2-2410 and PCN 84-2-2589 installed the automatic shunt

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trip actuation device on the reactor trip systems for Units 1 and 2. The

inspector reviewed data package PCN 83-2-2410 for Unit 2. The data package

. appeared to be adequate.

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

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