IR 05000269/1985021

Insp Repts 50-269/85-21,50-270/85-21 & 50-287/85-21 on 850729-0802.Violation Noted:Failure to Follow Procedure During Classification of Work Request & Inadequacies in Development & Implementation of Procedure MP/0/A/2001/4

ML20132C199
Person / Time
Site:	Oconee
Issue date:	09/04/1985
From:	Conlon T, Marlone Davis, Foster L, Marriweather N, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132C177	List: IR 05000269/1985021 ML20132C173 ML20132C185
References
50-269-85-21, 50-270-85-21, 50-287-85-21, GL-83-28, NUDOCS 8509260482
Download: ML20132C199 (18)

Text

DD080u UNITED STATES o NUCLEAR REGULATORY COMMISSION

[' . / ,'n REGION ll j

,j 101 MARIETTA STREET, *f ATLANTA, GEORGI A 30323

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Report Nos.: 50-269/85-21, 50-270/85-21, and 50-287/85-21 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-269, 50-270, and.50-287 License Nas.- DPR-38, DPR-47, and DPR-55 Facility Name: Oconee 1, 2, and 3 Inspection Conducted: July 29 - August 2, 1985 Inspectors: N38 L. E. Foster, Team Leader 'Date Signed

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N. Merr weather Y L- _f Date

~ YSigned W

k M. J. Davi s

& ')ff .3/ff Date Signed Consultant: P. M. Chan, Lawrence Livermore National Laboratory Approved by a; 7 d/-P(

T. E. Conlon, Section Chief Date Signed Division of Reactor Safety SUMMARY Scope: This special, announced inspection entailed 124 inspector-hours on site concerning _liccusee response to Generic Letter 83-28, Required Actions Based on

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Generic Implications of Salem Anticipated Transient Without Scram (ATWS) Events.

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Areas inspected included: post-trip review; equipraent classification; vendor interface and manual control; post-maintenance testing; and reactor trip system reliabilit Results: Two violations were identified: Failure to Follow Procedure During Classification of Work Request, paragraph 7 and Inadequacies in Development and .

Implementation of Procedure MP/0/A?2001/4, CRD _ Breaker Inspection. and Maintenance, paragraph PDR ADOCK 05000269 G PDR

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I REPORT *0ETAILS I

, Persons Contacted Licensee Employees

• J. Pope, Superintendent of Operations

• T. Owen, Superintendent of Maintenance

• McAlister, Instrumentation and Electrical (I&E) Engineer

! *T. Glenn, I&E Support Engineer

• T. Matthew, Compliance Technical Specialist D. Clardy, Planning and Scheduling Supervisor.

, *R. Bond, Compliance Engineer D. Phillips, Electrical Foreman D. Gibson, Vendor Manual Group Clerk

• G..Edens, Support Engineer .

i G. Davenport, Performance Engineer _

j B. McKinney, Electrician >

L. Evans, Electrician

T.-Graham, I&E Specialist S.-Henderson, Document. Control R. Murrell, I&E Specialist ,

M. Roach, Administrative Supervisor B. Loftis, I&E Engineer D. Larson, Planning'& Scheduling

! C. Phouletter, Planner and Scheduler i

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A. Green, Planner and Scheduler L

• P. Waltman, Quality Assurance

• F. Siurua, I&E Associate Engineer

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C. Parsons, Performance' Engineer .

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L. Staggers, Document Control Clerk-

! Other -licensee employees contacted included engineers, technicians,

! operators, mechanics, security force members, and office personne NRC Resident Inspectors j *J. C. Bryant, Senior Resident Inspector

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• L. King, Resident Inspector.

j * Attended exit interview

' Exit Interview.

l The inspection scope and fin' dings were summarized on August 2,1985, with j

those persons. indicated-in paragraph 1 above. . The inspector described the

areas inspected and . discussed in detail the inspection x finding No

dissenting comments were received from the licensee.

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Violation 50-269/85-21-01, Failure to Follow Procedure During Classifi-cation of Work Requests, paragraph 7.

I- Inspector Followup Item 50-269,270,287/85-21-02, Review of Purchase Orders for Undervoltage Devices, paragraph '

Violation 50-269,270,287/85-21-03, Inadequacies in Development and .

Implementation of Procedure MP/0/A/2001/4, CR0 Breaker Inspection and Maintenance, paragraph ;

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The licensee did not identify as proprietary any of the materials provided

! to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters f This subject was not addressed in the inspection.

, Unresolved Items  ;

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$ No unresolved items were identified during this inspection.

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i Background

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In February'1983, the Sal'em' Nuclear Power Station experienced two failures of the reactor trip system upon the receipt of trip signals. These failures

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were attributed to Westinghcuse - Type DB-50 reactor . trip system (RTS)

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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

! of -the circuit breakers at Salem and 'at othar plants, NRC issued Generic

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Letter 83-28, Required Actions Based on Generic Implications of . Salem

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ATWS Events, dated July 8, 1983. This letter required the . licensees to respond on immediate-term actions to ensure reliability of the RTS. Actions

to be performed included development of programs to provide for post-trip review, classification of equipment, vendor interface, post-maintenance

.' testing, and RTS reliability improvement. The licensee responded to Generic

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Letter 83-28 by correspondence with the following dates: November 4,1983; i December 30, '1983, January 17, . 1984; February 2, 1984; July 5, 1984; ,

! August 10,1984; March 20,1985; March 29,1985; and April 25, 1985. This  !

! inspection was performed to review :the licensee's current program, planned i program improvements, and implementation of present . procedures associated with post-trip review, equipment - classi fication, vendor interface, post-main.tenance testing, and reactor- trip system reliability' for Oconee Unit Nos. 1,-2, and . Post-Trip Review The : licensee was requested in {GL 83-28 to describe .their program, proce-

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dures,- and data collection capability to assure -that the causes for unscheduled- reactor shutdowns, as' well as the . response of safety-related i equipment, are fully understood prior to. plant re s ta rt'. The licensee's.

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4 response to GL 83-28 gives a description of the program and procedures 2 pertinent to performing post-trip review The inspector reviewed their

response, appropriate procedures, and interviewed r.esponsible licensee

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

review .

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The' licensee has prepared and revised procedures to define responsibilities, authorities, methods of assessment, training, and equipment needed to perform a timely technical post trip review. Their program and implementa-tion observed are discussed below:

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The Oconee post-trip review program is addressed and implemented by

Performance Manual Chapte'r 4.7, " Support of Reactor Trips -

Performance" and by Operations Management Procedure 1-8, " Investigatio

of Reactor Trips".

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'The Shift Supervisor, Operations Unit Engineer, and Operations Duty Engineer are responsible for' determining the cause of any reactor trip.

j The Performance Duty Eng.neer is responsible for conducting an indepen-i dent evaluation of the reactor trip even These activities are

documented by the completion of the " Post-Trip Review Report", which is

, an attachment to Performance Manual Chapter i

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ny unplanned manual or automatic trip will require a full post trip review report and the assembly of plant data which may include events .

j recorder printout, alarm typer printout, Transient Monitor Computer

. output in graph or table form, strip charts, operator interviews, and logbooks.

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! Prior to restart of the unit,-operations personnel must ensure that:

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The immediate cause of the reactor trip is known or has been iavestigated to the fullest extent possible while remaining in the '

shutdown conditio Plant transient behavior did not identify unresolved problems that .

, could impact the ability of the unit to be safely restarted and operate Any malfunction or failures in equipment - or components subject to Technical Specifications requirements are-evaluated and corrected prior to restar Operations shall ensure that 'the Reactor Engineer's recommendations are resolved prior to restart and shall obtain his/her concurrence with restart-as indicated by . the Reactor Engineer's signature on the trip recoveiy

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operating - procedure or documented in the SR0 log. The Station' Manager, or his designee, is required to resolve disagreements between Operations. and the Reactor Engineer regarding necessary corrective action.

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If the immediate cause of the reactor trip cannot be determined, or if any unresolved safety issues exist, or if compliance with licensing requirements is in question, then an independent review is performed by a group of knowledgeable individuals identified by the Station -Manager. This group makes a recommendation on restart to the Station Manager, or his designee, who then resolves the restart decisio Each reactor trip is subsequently evaluated by the Compliance Section in accordance with Compliance Manual Section 5.1, "Non-Routine ~ Events Reporting". An incident investigation report is prepared that includes the following:

Information and data collected during the Post-Trip Revie A Sequence of Events describing all action taken and system / equipment performance curing the event that materially affected the course of the even An assessment of the plant transient behavior that identifies any deviations from expected plant performance and that documents the behavior of key plant parameter An assessment of the performance of protection and Engineered Safety systems during the transient, identifying any malfunctions or failure to perform as expecte An assessment of other equipment failures that contributed to the even An assessment of personnel performance and procedure adequacy relevant to the even i

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A description of corrective actions taken or planned as a result of the even Post-Trip Review packages are maintained in fire-resistant file cabinets in

'tne Performance Engineering Offic The inspector reviewed post-trip data review packages generated for eight reactor trips that occurred in 1985 and and seven reactor trips that occurred in 1984. The packages were thorough and adequately documented the event The inspector conducted p review of licensee procedures to verify that they were consistent with licensee responses to GL 83-28. The following proce-dures were reviewed:

Compliance Manual Section 5.1, Non-Routine Events Reporting, 11/9/84 Operations Management Procedure 2-1, Duties of the Reactor Operators on the Control Board, the SRO in the Control Room, and the STA, 4/17/85

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Operations Management Procedure 1-8, Investigation of Reactor Trips, 11/1/84 Performance Manual Section 4-7, Support of Reactor Trips - Performance, 9/21/84 Operations Management Procedure 1-3, Operations Duty Engineer, 3/13/85 ,

Operations Management Procedure 1-1, Administration of Operations Management Procedures, 12/3/84 Performance Manual Section 3.1, Procedures - Performance, 3/26/85 -

Operations Management Procedure 3-1, Operations Training, 11/1/84 c Station Directive 4.5.1, Non-Routine Events Reporting, 12/1/84 The licensee is preparing to replace the General Electric (GE) PAC 4020

plant computer systems with the Honeywell 45000 computer systems over the j next three years. The alarm typer output device is associated .with the plant computer. Digital alarms and change of status indications of safety-

{ related pumps, valves, and motors are printed on the typer to the nearest secon,d . This device is powered by. a non-class IE, non-interruptible AC

source.

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The Transient Manitor System is a dedicated computer system. Data is received .via hardwired inputs one per second and stored on a hard dis ,

Data output can be in either graph or table form. The parameters recorAd by the transient monitor document the pre-trip and post-trip behavior of the

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primary system, secondary system, important Balance of Plant (BOP) systems, and safety systems. The transient monitor is powered by a non-class IE AC source which is interruptible but will automatically transfer to the onsite

AC backup on loss of powe The' Events Recorder is a dedicated computer system which monitors equipment and components pertinent to reactor trip investigations. Output is on a paper tape and the time of each event is recorded, with' discrimination down

to one-millisecond, along with the parameter number. This de'vice is powered by a non-class IE AC source which is interruptible but will automatically-transfer to the onsite AC backup on loss of power. Additionally, 'a safety-

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related non-interruptible DC backup power supply is provided.

, The licensee is -i_n the process ~ of installing the Safety Parameter Display System (SPDS) ~ data collection and processing system associated with the NUREG 0737. upgrade of Emergency Response-facilities. Although, the current

. data. and information collection . systems are adequate for the evaluation of unplannedr ' eactor trips, the new system should enhance the plants' data colledtion capabilities.

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< t Interviews revealed that plant personnel preparing and/or reviewing the

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, post-trip documentation were familiar with plant systems, equipment, and plant operatio Within the areas examined, no violations or deviations were identified.

7. Equipment Classification

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-The licensee was requested in Sections 2.1 and 2.2 of GL 83-28 to confirm that all components of the reactor trip system whose function is required to trip the reactor are identified as safety-related. This identification was i to be on documents,-procedures, and information handling systems used in the i plant to control safety-related activities including maintenance, work  !

, orders, and parts replacemen In addition, the licensee was requested to i

describe their program for ensuring that all components of otSer safety-i related systems necessary for accomplishing required safety functions are also identified as safety related on informa' tion handling systems used at '

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the plan The licensee's response to Sections 2.1 and 2.2 of GL 83-28

. gives a detailed description of the program and procedures for safety-

. related equipment classificatio.n. The licensee makes the following state-ments in-their respon:e dated November 4, 1983:

i " Station specific documents provide the mechanism for the determination i

of whether or not a given station structure, system, or component is i

safety-related. This document is provided to appropriate station and

general office personnel and is entitled, "0conee Nuclear Station Safety-Related Structures, Systems, and Components Manual".

The ' inspector reviewed their response, appropriate procedures, and inter-

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viewed responsible licen'see personnel to verify if the licensee's program i for equipment classification was adequate and consistent with the above respons During this inspection, the inspector- reviewed the following'

i procedures and documents listed below:

Oconee Nuclear Station Maintenance Directive III.8, Work Request Planning, Revision dated April 16, 1984

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Oconee Nuclear Station Directive 3.2.1, Work Request,. Revision dated

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Quality Standards fer Structures, Systems, and Components Oconee Nuclear - Station Directive 4.5.4, QA Condition Det'erminations,

Revision dated December 1, 1984 Technical Specification 6.'4, Station Operating Procedures

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Duke Power Company Steam Production Department Administrative Policy l Manual for Nuclear-Stations- '

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As stated above, the licensee has developed the Quality Standards Manual for Structures, Systems, and Components which identifies safety-related components. The intent of this procedure is to identify both mechanical and electrical safety-related components. The inspector reviewed the procedure and found it to be somewhat general in identifying safety-related component Interviews with planning department personnel pointed out a weakness with the piping drawings in identifying safety-related instrument The licensee acknowledged that the Q-Lists are to general and that they are considering improving the Q-Lists with more detai Section 4 of this procedure also includes an instruction for making component classification The inspectar reviewed four equipment classification evaluations for the following plant components:

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Inlet and Outlet Thermometers on SSF AC Unit

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Valve 250-325

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3MS - 140

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Filters on SSF HVAC Equipment No concerns were identified with the equipment classification evaluations reviewe The inspector randomly selected several work requests (WRs) for examination to verify that work activities were being properly, classified as safety-related or non-safety-related as required by the above procedures. The work requests reviewed and associated classifications assigned are identified below:

Work Request N Classification 225188 Nonsafety 56263 Safety-Related 56890 Safety-Related

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56888 Safety-Related 22840B Nonsafety 83761B Nonsafety 22790B Nonsafety 22549B Nonsafety 51724D Nonsafety 23178B Safety-Related 23030B Safety-Related 22827B Nonsafety 22843B Nonsafety 50197C Nonsafety 50196C Nonsafety 23070B Nonsafety 228388 Nonsafety 23071B Nonsafety 230698 Nonsafety 23068B Nonsafety 54666C Safety-Related'

23108C Nonsafety

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!~ In reviewing the above WRs, the inspector identified a discrepancy in the way the licensee was classifying the calibration of the power range instru-mentation channels 5, 6, 7 and 8 (channels A, B, C, and D respectively af

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Reactor Protection) on WR 22790B, dated July 17, 198 The licensee identified this WR as non-safety-related. Subsequent to this WR on July 20, J

1985, the licensee identified WR 23020B as safety-related QA condition Tne inspector reviewed the Quality Standards' Manual for Structures, Systems, and Components and determined that the power. range nuclear instrumentation

! is classified as safety-related. The work required by the work sequence on ' '

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both work requests required the calibration of the NIs using Instrument Procedure IP/0/A/301/3T, Reactor Protective System ?ower Range Calibration '

at Power. This procedure is con'sidered to be safety-related; however, the reviews required prior to performing a non-safety WR are not the same reviews required for a safety-related work request. QA condition WRs are require'd by Station Maintenance Directive III.E to be reviewed by the

Station QA Section. The licensee was informed of the above discrepancy with the safety classification of WR 227908. The licensee considered this to be

, an isolated case of failing to properly classify 'a safety-related WR for l nuclear instrument (NI) calibrations. At-the request of the inspector, the licensee ran a computer sort of the work history for power ~ range nuclear instruments for calendar years 84 and 85 to determine if this wa s ' an j

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isolated case. The results of this computer . sort indicated that the .

licensee had misclassified five (5) work requests as non-safety. The five WRs which were misclassified are~ identified below:

WR N Date Work Description 020835B 04/28/85 Perform NI Calibration

. 018401B 01/19/85 Please Calibrate NIs s

~0227908 07/17/85 Calibrate NIs as Required on Power Escalation 10/30/84 Perform.NI Calibration

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016545B-020141B 03/29/85' Reset RPS Channels #A, B, C, D to-Hi Pwr Trip

10 CFR 50, Appendix B', Criterion V requires activities affecting quali~ty to

' be performed in accordance with instructions, procedures, or drawing Station Directive 2.2.1 implements the requirements of 10 CFR 50, Appendix B, Criterion V as it requires activities to be. conducted in accordance~with the provisions of the applicable procedure.

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Station Of rective 5.4.5 defines how to use the Quality Standards Manual for Structures, Systems, and Components (QSMSSC) in the determination of QA condition classifications on Maintenance . Work Requests (MWRs), material requisitions, and procedure This directive states that "the Quality Standards Manual for Structures, . Systems, and Components shall be used to

' determine QA condition level." The _ QSMSSC identi.fies power range nuclear instruments as safety-relate l

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Contrary to the above, WR 22790B was improperly classified as non-safety-related. Consequently, the WR had not been reviewed by the station QA sectio This constitutes Violation 50-269/85-21-01, Failure to Follow Procedure on Classification of Work Requests. This problem may be generic to safety-related components at Oconee since the Q-List is very gener al .

Therefore, the licensee should consider auditing other WRs to verify that they have been properly classified. In addition, the licensee should review the training provided plant personnel responsible for classifying safety-related work activities to ensure that personnel perform correct classifica-tion . Vendor Interface and Manual Control The inspector reviewed the licensee's response to GL 83-28 which described their program for vendor interface and control of vendor technical informa-tion. Their response described the following program:

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 an impact on plant design, maintenance, and safe operation is distri-buted to appropriate ' licensee organizations for review, approval, and incorporation into plant procedures as applicable. The licensee has procedures to assure that vendor information is controlle Procedure OEMA/IM-1, Receipt and Distribution of Operating Experience Information, describes how technical information will be properly received, screened, and distributed to licensee personnel. Review of this procedure confirmed that the licensee has a method to receive and use operating experience information and, if properly imp ~lemented, will be an asset to plant operation and maintenance activitie The licensee's procedure, Nuclear Steam Supply System (NSSS) Vendor Informa-tion Letters, identifies responsibilities, describes the activities, and summarizes the process used for attaining resolution to vendor information letters. The procedure also states that revisions to station procedures and vendor manuals will be implemented through the station procedure change process and through the vendor manual change process. The Nuclear Technical Services Group is responsible for assessing the applicability of tFa vendor information letters and implementing necessary corrective actions. The inspector could not find, nor did the licensee identify, a list, log, or status report of vendor information letters received and resultant review aad implementation actions being performed by the different Duke departments as described in the procedur The reactor trip breaker maintenance procedure did not contain all recommendations specified in GE Advisory Letters TAB 175-9.3 and 175-9.3S, nor did ~the licensee provide justification why the recommendations were not included in the licensee's procedure. The failure to include vendor recommendations in procedures or justification for not including is discussed further in paragraph 9 of this repor The

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licensee has completed some modifications and i s in the process of completing the modifications concerning the shunt trip, undervoltage device, ,

and replacement of bearings with ones that contain Mobil 28 lubrican !

Licensee's response dated March 29, 1985, specified that their preventative

maintenance program had been structured to be .in ' accordance with GE i

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Maintenance Instruction GEI-50299EI; however, Revision E was not referenced in the procedure and was n'ot in document control. Licensee referenced GEI-50299A and the Master Copy'was 50299A instead of 50299EI. The inspector loaned the technical support group his copy 'of GEI-50299E so they could compare it with 50299 Information obtained during. reactor trip breaker performance is bcing transmitted by. the licensee to the B&W Owners Group for tre'nding purpose The B&W Owners Group will provide recommendations resulting from evaluation

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of performance data received from other plant The licensee has started a program to review all vendor manuals associated with safety-related equipment. The licensee has a special Vendor Manual j Group assigned full time to review onsite vendor manuals and to prepare a j Master Copy of each manual. The Master Copy will include all up-to-date

technical information. .After completion of the update, controlled copies of J" the manuals are being redistributed to approved satellite files per inter-station memo which require recipients to transmit an ' acknowledgement receipt. The licensee also utilizes a formal form (18527) for transmittal

of documents to the Master File. A Record of Verification Form (02665 of 3-83) is being used by the Vendor Manual Group to verify that the manuals

' have been proofread and corrections have been included. The use of this form wea discussed with the Administrative Supervisor. Other forms such as Insertion Control Form (01045) and Design Engineering Transmittal Form (01190) are also being used to control vendor information. 'The Vendor Manual Group maintains a " Station Backfit Log" which lists' the documents reviewed, corrective action needed, and date. of final review. A monthly

audit '(status) report is being continually updated to show-'the number of manuals updated and discrepancies resolved. The inspector discussed the program with licensee personnel, observed the verification in process and

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examined manuals in the' Document. Control Area. The licensee has several-procedures to help assure that- technical information is properly received, reviewed, and controlled. The licensee appears f to be extending an all out effort on . updating and controlling vendor manual The inspector reviewed the licensee's Procedure MP/0/A/2001/4 dated June 6, 1985, CRD Breaker Inspection and Maintenance. The procedure review revealed the following concerns: GE Technical Manuals were incorrectly referenced; GE Advisory Letters were not referenced; approved cleaning solvents were not

- specified; repair..as necessary statement does not provide for control of work or require maintenance personnel to document findings; engineering was not required to evaluate damage and evaluate causative factors; item 11.4

} does not specify the trip method (electrical or mechanical); item 11.5 does not reference where the 50 and 80 msec. c< '

-rom; cautions on ~ using cleaning agents are not specified; pressur '

compressed air is not

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specified; how to replace or repair arc chutes was not specified or i . referenced; paragraph 11.8 allows equivalent lube to be used, although the type of lubricant previously used was partly the cause of poor operation; the latest tests by the. vendor requires Mobil 28 lubricant for the bearing, therefore, it is presumed the breakers are qualified if Mobil 28 is used,

, yet the procedure allows an equilivant lube to be used; paragraph 11.15 does

not specify that a special tool is required to manually trip the breaker; l' paragraph 11.16 does not follow GE recommendations as GE recommends that the

. pickup voltage be checked three quick times, however, the procedure only specifies one time; QA/QC personnel have minimal involvement throughout.the repair and maintenance activity, except for verifying certain hold points; the caution note on Mobil 28 should be located prior to paragraph 11.14; the ,

text of the procedure does not require the recording of as-found informa-tion, however, Enclosures ~13.3a and 3b (Reliability Data Sheets) have spaces

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for as-found and as-left data; paragraph 11.16 requirds the UV device be

! near room temperature prior ' to testing, however, the procedure does not specify a minimum or maximum room temperature; the procedure does not .

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specify disassembly of UV devices, however, the licensee was disassemblin the UV devices, inspecting, and reassembling; GE Service Advice Letters Nos. 175-9.20, 175-9.3, and 9.3S were not referenced, although some informa-' i tion from these was used. The above comments on the procedure were discuss- t ed with licensee personnel. Some of-the above comments are further discussed-

in paragraph 9 and contribute to the violatio Discussions with personnel and observation of maintenance activities reveal-ed that during the preventative maintenance (PM) on a reactor trip breaker, the licensee has been disassembling the undervoltage trip device and examin-ing the parts for damage as previously reported. The licensee informed the

inspector that the following discrepancies were found: sharp burrs existed on the edges of the armature (where measurements are made) that contact the

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rivet; indentation of the area of the armature that contacts with the rivet; sharp edges where the armature pivoted against the magnet; rubbing between the armature trip paddle and the heads of the two screws that attach the trip device to the. mechanism frame; plus some wearing of the paint coatings around the bearing area of the armature. The licensee has issued several letters to the NRC (February 14, 1985, April 22, 1985, August 17, 1984, and

August 27, 1984) concerning problems found with Oconee breaker front frame

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assemblies. These problems were also reported to 'the vendor. The basic

, problem appeared to be with the trip shaft bearing lubrication which is being corrected by installing . bearings which have been lubricated with

Mobil ~28 lubricant. The licensee is in the process of replacing all the front frames of Oconee RTS ' breakers.

The- licensee reported on July 22, 1985 that during o'n-line testing of a

- reactor trip breaker (CB-1 on Channel C), the breaker took 1738 milliseconds to open instead of the 80 milliseconds allowed. The licensee replaced the breaker with a ~ spare and examined the faulty breaker. They suspected interference between .the heads' of the UV mounting screws and the armature trip paddl i

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f The inspector examined a UV trip device to determine if the armature trip paddle could interfere with the heads of the two attachment screws.. A minimum clearance of approximately~ 0.025 ' inches was obtained with the armature in its worst position. The licensee stated that this UV device was an "old" one and that one of the two "new" ones (replacement for old UV devices) actually had a rubbing condition and they had filed approximately 1/32 inch off the side of the screw heads to eliminate the rubbing condi-tion. The licensee stated that the breaker passed its test prior to his filing the screw heads. No detail drawings were available for review;

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therefore, it could not be determined if the rubbing could be the result of design deficiencies.

The inspector examined another UV device which the licensee stated was an

"old" device. The inspector .noted that the location of the armature trip paddle in relation to the attaching screw heads was different (had more clearance) than the UV device previously examine ;

-The. licensee stated that they had recently installed two new undervoltage devices. Upon questioning whether these two new devices' were the same part number as the old.UV devices, the licensee was unsure and could not confirm

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as the purchase order and receiving information was not readily availabl The . licensee stated that they would contact GE and resolve the part number 1 discrepancy .and the possible rubbing problem. . The purchase order and

] receiving information for 18 reactor trip breaker front frames were not readily available for the inspectors' review; however, this information on the front frames was reviewed by the NRC Resident Inspector on August 5, 1985 and was satisfactory. Until the licensee obtains information on the UV

device-part numbers at the site, this is considered Inspector Followup Item 50-269, 270, 287/85-21-02, Review of Purchase Orders for Undervoltage Device .

Within the area . examined, no violations or' deviations were iden'ti fied; however, some of the findings contribute to the violation discussed in l paragraph . Post Maintenance Testing (Reactor Trip System Components)

i The Oconee Nuclear Station (ONS), Units 1, 2, and 3, have a total of 18 GE' ,

AK-2 low voltage power circuit breakers' (and 'four spares) in the Reactor

- Trip System (RTS). There are two AC breakers and four DC breakers in each -

Oconee unit. Since Units 2 and 3 were wired differently from Unit-1, two of- !

the. spare breakers (one AC and one DC) are for. Units 2 and 3, and the other 1 two spare breakers (one AC and one DC) are for Unit The inspector reviewed Maintenance _ Procedure MP/0/A/2001/4, CRD Breaker Inspection and Maintenance and observed the performance of this procedure on i

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breaker Nos. U2 & 3-DC-9 and U2 & 3-AC-1. The maintenance being performed !

on the breakers was a regularly scheduled preventive - maintenance activit ~

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'It involved checking out the two sp'ar'e breakers for Units 2 and 3 and <

! preparing them for replacing two Control Rod Drive (CRD) breakers that were

scheduled to be removed from service for preventive maintenance.

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The work was performed by electricians trained on the jo Duke Power Company (DPC), the licensee, maintains and renovates' circuit breakers, including CRD breakers, with the -licensee's own staff. There is no formal

< training. program for electricians assigned to CRD breaker maintenance. _. The electrical foreman leading the maintenance work on the CRD breakers stated that "new" electricians with less ,than three years' experience are not allowed -to do- CRD breaker maintenance work on their own. They work along-

- side electricians with more experience while receiving on-the-job trainin '

Duke Power Company, the licensee, responded in their letter, dated April 25,

, 1985, st,ating that the requirement of GL 83-28, Section 3.1.2, had been completely met by March 31, 1985. The inspector reviewed 'the licensee's effort in meeting this GL 83-28 requirement and noted that the licensee had i issued a revision to their maintenance procedure Mp/0/A/2001/4 for the maintenance of'RTS circuit breakers. The inspector checked to see if the

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vendor' s recommendation.(in this case, GE's) were properly incorporated into the licensee's maintenance procedure. GE had previously ' issued Service Advice Tab 175, No. 9.3, and also a supplement No. 9.3S, dated April 15, 1983, which augmented and clarified some of the areas in the maintenance check of the RTS breakers. The inspector noted that there were differences in the licensee's maintenance manual when compared with the GE Service Advisories. These items were discussed with the licensee's personnel and '

are enumerated below:

. The inspector observed'that the licensee personnel were performing the maintenance and calibration-work on the RTS circuit breakers in a room

, adjacent to the hot and humid turbine generator high bay area. The electrician's room was small and crowded, and the room temperature was not being monitore This is contrary to the licensee's procedure where Section 11.16 required some assurance be made that the UV device was near~ room temperature. It is contrary to the GE service advisory which stated that, " Calibration should be. done at . room temperature (approximately 20-25 C) after the device has been de-energized for about one (1) hour."

, GE Service Advisory 9.3S stated that after the electricians administer the three quick test trips, they should wait one hour-for-the UV device to stabilize back to. room temperature' prior to recording additional i pick-up and drop-out voltages. ' The GE advisory also states that . care

should be taken on calibration checks to ensure that the coil temper-ature remains close to room temperatur Contrary -to this, Section 11.17 of the licensee's procedure does not require this wait q period or a check of coil temperatur Further, the writer of the

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licensee's procedure: stated that he -intended the trip tests be done

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. electrically, whereas the electricians performing the work stated that they had performed .the trip both ways: electrically, as well as mechanicall Misinterpretation of requirements could result in misadjustments and other malfunctions.

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14 Another incidence of misinterpretation between the intention of the

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procedure writer and the practice of the electricians occurred during performance of Section 1~1.17a. The procedure writer intended that the -

UV pick-up voltage be measured again in that section. However, the-inspector noted that the electricians did not re perform the pick-up

voltage measuremen Instead, the electrician recorded the pick-up voltage that was set in the calibration process in previous Section No. 11.16. Misinterpretations of this nature are exemplary lof the looseness allowed during the implementation of this procedur It also indicates' a possible lack of communication between the different departments in the licensee's organizatio The inspector discussed the importance of resolving misinterpretations prior to performing maintenance activities and why QA/QC personnel should be more involve ~ The inspector noted that Section 9.0, Acceptance Requirements, contains l- the limits and criteria for acceptance of all the parameters except the -

UV coil drop-out voltage. A review of the GE service ' advisory showed that the manufacturer's recommendation for drop-out voltage is 30-60%

of nominal ' voltage. Inasmuch as the UV drop-out voltage was measured and recorded as per procedure, there was no specified acceptance criteria listed in the procedur This is contrary to Criterion V of 10 CFR 50, Appendix B, which. requires that procedures contain accep-tance criteria. However, examination of previous tests revealed that the drop-out voltage was within the vendors recommendation of 30-60% of

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nominal voltage.

' The inspector noted that in the performance of Section No. 11.12 of the procedure, the electricians removed the UV- device and completely

, disassembled it, thoroughly examined it,~ and carefully reassembled i '

.However, Section No.11.12 of the procedure does not direct the elec -

! tricians to disassemble the UV device in the first place. The licensee

! responded that the practice of ' disassembling the UV device was under-taken in the current cycle of RTS circuit breaker maintenance and that

. they intended to stop the practice once all 22 RTS circuit breakers in the licensee's possession have received this.one-time scrutiny on their

, UV devices. The - inspector pointed out that procedures were developed

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to control activities and any deviation from procedure be documented in the form of_a temporary procedure change with-all the additional steps included in the proper sequence and that inspection results be record-

-ed. Station Directive 2.2.1 (TS) dated December 1, 1984, describes the >

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licensee's methods to ' prepare, change, reissue, and de.lete procedure '

, The. directive also provides guidance in the areas .of procedural adhe- ,

rence and us ~

Section 11.5 of the procedure referenced the FSAR for selection of the

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, msec. limit specified; however, the . inspectors could not find the specified 80 msec. limit in the FSA Upon discussion with the licensee-_and further inspection, the 80. msec. limit was .found. in the i Technical Specifications.

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The above findings, plus the additional items discussed in paragraph 8 i i

constitute Violation 50-269,270,287/85-21-03, Inadequacies in Development

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and ' Implementation of Procedure MP/0/A/2001/4, CRD Breaker. Inspection and Maintenanc In summary, the inspectors concluded the following:

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The procedure did not include vendor recommendations as specified . in advisory letters, and all were not referenced The technical review.of this procedure appeared to be lacking due to the number of discrepancies found by the inspector I i

The ~importance of . having clear understandable procedures without misinterpretation and the importance of strictly adhering to procedures

appeared to be lackin :

Auditing of RTS maintenance activities, including observation of work, to assure -that all activities are performed in a quality manner and according to procedure was not apparent.

i The requirement to. perform post-maintenance testing and on-line sur-veillance testing will help assure that ' equipment will function when and required; however, ' procedures properly prepared, technically rev.iewed, approved, , and properly implemented further assures that equipment will function when needed, To further evaluate the licensee's program, the inspector reviewed the latest complete set of MWRs associated with work on the 22 RTS circuit ,

breakers. The WR numbers reviewed were: 54318C, 54315C, 56776,.56774, 56597, 56598, 56771, .56772, and 56773. The inspector examined the

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documents for consistency in the data taken, completeness in the records, the type of preventive or corrective measures required, and evidence of post-maintenance testin No problems were -identified

. during review of these WRs.

! The following licensee procedures and documents were reviewed:

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Station Directive 3.2.1, Work Request, dated July 8,' 1985  !

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Instrument Procedure IP/2/A/305/3D, Instrument Procedure Data 1 Package for RPS Channel "D" Calibration and Functional. Test,; dated

May 22, 1985

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Maintenance Directive III.D, Work . Request Completion', dated May 14,-1984 i -

Maintenance Directive - III.8, . Work Request -Planning,. dated April 16, 1985-Maintenance Procedure MP/0/A/2001/4, CRD Breaker Inspection and

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-Maintenance, dated May.31, 1985 i

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Instrument Procedure IP/0/B/330/9, CRD System Check of CRD System i Before Test Tripping of CRD Breakers

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Instrument Procedure IP/2/A/305/3, Nuclear Instrument and Reactor

, Protection System RP Channel Calibration,and Functional Test The inspector also reviewed completed WRs on other safety-related components to determine if post-maintenance testing was being im-plemented. Seven WRs were selected for inspection . and are listed below:

Work Request N Work-Description 23178B Relay Repair 23030B Power Range Calibration 55052 E/S System Test 057948 Repair Pump Leak

90153C Valve Repair i

50277C Valve-Repair

29055A1 Valve Repair Except' for the findings discussed in items a-thru f, no other violations or deviations were identified in this are Reactor Trip System Reliability

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1 The. licensee stated in their responses to GL 83-28 that on-line functional surveillance testing of individual Reactor Protection System Channelsw ' ill be performed once per month. The licensee also stated that diverse. ' trip features, including the breaker undervoltage'and shunt trip features will be tested on a regular basis and that vendor recommendations would be evaluated

and used where deemed applicable. - The~ licensee-had ordered and .had install-

ed some new reactor trip- breaker front frties which contained bearings

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] lubricated with Mobil 28 lubricant. Shunt trip ~and undervoltage devices were being installed and tested,'plus preventive maintenance and testing of

the-reactor trip-breakers was being implemented as discussed in paragraphs 8

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an Data taken during' surveillance testing 'and maintenance inspection are being transmitted to B&W Owners Group for trending purposes. The l'- inspector observed the on-line testing of a reactor trip' breake Licensee

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. personnel . performed the operations as required by procedure. The inspector I

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verified that the periodic maintenance program to ensure reliability describ-ed in their. March 29, 1985 response was being implemented. Based on review

of procedures and observation of work, -the licensee is implementing a

{ program to help ensure reactor trip ~ system reliability.

The following documents were reviewed:

PT/0/A/305/01, Reactor Manual Trip Test, approved October 11, 1984 Documentation Package for WR 972108, Addition of Shunt Trip Feature on

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CRD AC and DC breakers dated February 14, 198 ,_ _

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Procedure TN/2/A/2288, Ad'dition of Shunt Trip Feature, Revision 0 Document Package for Purchase Order No. K13589-76 for 22 Front Frames for GE breakers dated March 6, 1984 (included receipt inspection reports and certificates of conformance). Reviewed by Resident Inspector on August 5, 1985 and in Region II office on August 16, 198 Purchase Order J20388-70 for Coil, Shunt Trip Devices dated April 26, 1983 Various Purchase Orders to B&W for Reactor Trip System Equipment and Parts Within the areas inspected, no violations or deviations were identified.

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