ML20132C199

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)

See also: IR 05000729/2008002

Text

DD080u UNITED STATES

o NUCLEAR REGULATORY COMMISSION

[' . / ,'n REGION ll

j

,j 101 MARIETTA STREET, N.W.

• f ATLANTA, GEORGI A 30323

%' o5

• ...

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

_ent_

N. Merr weather Y

L- _f Date

~ YSigned

W

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M. J. Davi s

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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

reliability.

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 9.

8509260482 850913

PDR ADOCK 05000269

G PDR

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REPORT *0ETAILS

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1. Persons Contacted

Licensee Employees

• J. Pope, Superintendent of Operations

• T. Owen, Superintendent of Maintenance

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

! *T. Glenn, I&E Support Engineer

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• 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

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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 personnel.

NRC Resident Inspectors

j *J. C. Bryant, Senior Resident Inspector

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• L. King, Resident Inspector.

j * Attended exit interview

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2. Exit Interview.

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

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

areas inspected and . discussed in detail the inspection x findings. 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 3. '

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 9.  ;

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

! to or reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters

f This subject was not addressed in the inspection.

, 4. Unresolved Items  ;

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$ No unresolved items were identified during this inspection.

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i 5. 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 3.

6. 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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response to GL 83-28 gives a description of the program and procedures

2 pertinent to performing post-trip reviews. 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

reviews. .

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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, " Investigation.

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-

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dent evaluation of the reactor trip event. These activities are

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

, an attachment to Performance Manual Chapter 4.7.

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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 condition.

Plant transient behavior did not identify unresolved problems that .

, could impact the ability of the unit to be safely restarted and operated.

Any malfunction or failures in equipment - or components subject to

Technical Specifications requirements are-evaluated and corrected prior

to restart.

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 decision.

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 Review.

A Sequence of Events describing all action taken and system / equipment

performance curing the event that materially affected the course of the

event.

An assessment of the plant transient behavior that identifies any

deviations from expected plant performance and that documents the

behavior of key plant parameters.

An assessment of the performance of protection and Engineered Safety

systems during the transient, identifying any malfunctions or failure

to perform as expected.

An assessment of other equipment failures that contributed to the

event.

An assessment of personnel performance and procedure adequacy relevant

to the event.

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A description of corrective actions taken or planned as a result of the

event.

Post-Trip Review packages are maintained in fire-resistant file cabinets in

'tne Performance Engineering Office.

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

events.

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 disk. ,

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 power.

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

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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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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 operation.

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

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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 replacement. 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 plant. 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

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

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

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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

response. 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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July 8,;1985

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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

components. Interviews with planning department personnel pointed out a

weakness with the piping drawings in identifying safety-related instruments.

The licensee acknowledged that the Q-Lists are to general and that they are

considering improving the Q-Lists with more detail. Section 4 of this

procedure also includes an instruction for making component classifications.

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

reviewed.

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 No. 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, 1985. The licensee

identified this WR as non-safety-related. Subsequent to this WR on July 20,

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1985, the licensee identified WR 23020B as safety-related QA condition 1.

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

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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 No. 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 drawings.

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 procedures. 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-related.

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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

section. 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-

tions.

8. 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 controlled.

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 activities.

-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 procedure. 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 report. 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 lubricant.  !

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

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

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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 50299A.

Information obtained during. reactor trip breaker performance is bcing

transmitted by. the licensee to the B&W Owners Group for tre'nding purposes.

The B&W Owners Group will provide recommendations resulting from evaluation

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of performance data received from other plants.

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

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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

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l. 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 manuals.

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 disassembling.

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-

2

in paragraph 9 and contribute to the violation.

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

,

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

'

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

4

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 paddle.

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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;

'

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 examined.  ;

-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 available.

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

4

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

Devices.

.

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 9.

9. 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 1.

The inspector reviewed Maintenance _ Procedure MP/0/A/2001/4, CRD Breaker

Inspection and Maintenance and observed the performance of this procedure on i

'

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

on the breakers was a regularly scheduled preventive - maintenance activity.

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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 job. 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 training. '

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

,

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:

.

a. 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 monitored. 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."

,

b. 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 temperature. Contrary -to this,

Section 11.17 of the licensee's procedure does not require this wait

q period or a check of coil temperature. Further, the writer of the

,

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

.

. electrically, whereas the electricians performing the work stated that

they had performed .the trip both ways: electrically, as well as

mechanically. Misinterpretation of requirements could result in

misadjustments and other malfunctions.

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c. Another incidence of misinterpretation between the intention of the

4

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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 measurement. 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 procedure. It also

indicates' a possible lack of communication between the different

departments in the licensee's organization. The inspector discussed

the importance of resolving misinterpretations prior to performing

maintenance activities and why QA/QC personnel should be more involved.

~

d. 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 procedure. 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.

'

e. 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 it.

'

.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

!

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 >

'

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

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

rence and use.

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

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80 msec. limit specified; however, the . inspectors could not find the

specified 80 msec. limit in the FSAR. Upon discussion with the

licensee-_and further inspection, the 80. msec. limit was .found. in the

i Technical Specifications.

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15

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

'

and ' Implementation of Procedure MP/0/A/2001/4, CRD Breaker. Inspection and

Maintenance. In summary, the inspectors concluded the following:

,

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 inspectors.

I

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The ~importance of . having clear understandable procedures without

misinterpretation and the importance of strictly adhering to procedures

appeared to be lacking.

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,

g. 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

!

documents for consistency in the data taken, completeness in the

records, the type of preventive or corrective measures required, and

evidence of post-maintenance testing. No problems were -identified

. during review of these WRs.

! h. 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

4

May 22, 1985

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Maintenance Directive III.D, Work . Request Completion', dated

May 14,-1984

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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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4

-Maintenance, dated May.31, 1985

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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

i. 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 No. Work-Description

23178B Relay Repair

23030B Power Range Calibration

55052A. E/S System Test

057948 Repair Pump Leak

4

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 area.

Reactor Trip System Reliability

'

10.

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

_

] 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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and.9. 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' breaker. Licensee

!

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

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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

4

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

{ program to help ensure reactor trip ~ system reliability.

2

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

,

CRD AC and DC breakers dated February 14, 1985.

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17

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, 1985.

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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