IR 05000029/1990081
| ML20059N486 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 09/28/1990 |
| From: | Bessette D, Caphton D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059N485 | List: |
| References | |
| 50-029-90-81, 50-29-90-81, NUDOCS 9010160032 | |
| Download: ML20059N486 (65) | |
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[ p ~ U.S. NUCLEAR REGULATORY COMMISSION , '
REGION I
m ~ Report No.: 50-029/90-81' ~ License No.:- DPR-3' '
Licensee: Yankee Atomic Electric Company > 580 Main Street Bolton, Massachusetts 01740-1398-J Facility: Yankee Nuclear Power Station ~ Inspection at: Rowe, Massachusetts ' Inspection conducted: July 9 - July 20, 1990 and August 6-10. 1990
, Inspectors: R. Barkley, Project Engineer J. Dixon,-Reactor Engineer '! . M.. Good, Consultant .l D. Moy, Reactor Engineer i S. Rhow, Electrical Engineer b R. Winters, Reactor Engineer j P. O'Connell, Radiation Specialist .. u / ff C .! Reviewed by: o D. Caphton, Team Leader, DRS
Date j
Approved by: M*/ OM '//h/ 9 D. Bessette, Chief, Operational Programs Date Section,.-Division of Reactor Safety i Inspection Summary: A special, announced maintenance team inspection was performed at.the Yankee Nuclear Power Station from July 9 to July 20, 1990, and
.. August 6 to' August 10, 1990 (50-029/90-81), el ! Areas Inspected: An in-depth team inspection of the Yankee Nuclear Power ~j Station maintenance program and its implementation was performed. The inspect-ion included review of maintenance documents, interviews with cognizant personnel, and observations of maintenance work in progress.
The inspectors '! used the NRC Maintenance Inspection Guidance, dated September 1988, and Temp- ! orary Instruction 2515/97 dated September 22, 1989.
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\\ i 3'. 4 , ~ Resultsil Overall,.the maintenance program' for the Yankee Nuclear Power Station - - 'was: functioning well. LAreas'of strengths were identified along with minor-
- weaknesses and
- areidiscussed in the Executive Summary and in detail in this
_ , report. : Appendix J provides'a list.of:the individuals contacted and attendees-l , . 'at the' exit me'etings;' Appendix 2 tis' a summary of the ' weaknesses. identified;- f; Appendix l-3,is.afsummary of the unresolved.. items identified; Appendix.4 is a- < i list 'of; the documents land work in. progress' reviewed; and Appendix.5 eis a list [ ' '
- f of4 acronyms"used.
- i No violations.and:one unresolved item were identified, ~ t i
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{[];: m , , ~. L a . .,. , h, ! SUMMARY Background
i The Nuclear Regclatory Commission (NRC) considers effective maintenance of
equipment and components a major aspect of ensuring safe nuclear plant opera- . tions and has made this objective one of its highest priorities. On March 23,
~ 1988, the Commission issued a policy statement that states, "It is the object-ive of the Commission that all components, systems., and structures of nuclear power plants be' maintained so that plant equipment will perform its intended function when required.
To accomplish this objective, each licensee should develop and implement a maintenance program which provides for the periodic evaluation and prompt repair of plant components, systems, and structures to- , ensure their availability."
' To ensure effective implementation of the Commission's maintenance policy, the-NRC staff is undertaking a major program to inspect and evaluate the effective-ness of licensee maintenance activities. This inspection was one of this i program of inspections to evaluate effectiveness of maintenance activities.
The inspection was conducted in accordance with guidance provided in NRC Temp-orary Instruction.2515/97' dated September 22, 1989, and the NRC Maintenance Guidance, Volumes 1 and 2, dated September 1988.
The temporary instruction includes a " maintenance inspection tree" that identifies for inspection the major elements associated with effective maintenance.
Scope of Inspection- - The inspection team evaluated three major areas: (1) overall plant performance as affected by maintenance; (2) management support of maintenance; and (3) , maintenance implementation. Under each of these major areas, elements consi-dered important for proper functioning of the area were inspected.
For each element, the inspectors evaluated both the program and the effectiveness of program implementation.
h The inspection at the Yankee Nuclear Power Station (YNPS) was initiated with a site meeting on June 19, 1990, where the scope of the inspection, including the maintenance-inspection tree, was discussed with licensee management.
A list of - requested ' site specific information was provided previously to the licensee by letter dated May 30, 1990. A comprehensive pre-inspection submittal of
- information based on this request was provided to the team leader by the YNPS management following the June 19, 1990 meeting, uy
'The NRC inspection team spent June 25 to July 6,1990, at the NRC office preparing for the inspection and examining the information submitted by the licensee. The team conducted an onsite inspection at the YNPS from July 9 to
- July 20, 1990.
The team leader conducted an onsite open item closecut inspec-tion from August 6 to 10, 1990.
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YNPS was in a planned refueling outage during-the course of the entire inspec-tion. Thelinspection was directed at observation of maintenance work in-progress and licensee activities supporting this work, including engineering, c training,:and management. Maintenance activities selected for detailed review included equipment. identified by application of the Probabilistic Safety Study (1.e., probabilistic risk assessment (PRA)) as having the potential for contri-buting significantly:to core damage accident sequences or reduction of the risk ' ~ associated with plant operation. Other components and maintenance activities twere selected for inspection based an work in progress during the inspection, recent. malfunctions of safety related equipment, special interest items, and - NRC' inspection experience.
Daily meetings were held by the NRC team leader with plant management to . summarize the inspection team-findings and to identify areas where additional information was required.
The team members also apprised the maintenance staff of their findings daily. On July 19, 1990, a meeting was held with cognizant licensee management for each NRC inspector to present significant findings.
The summary of the inspection team findings, including the team's evaluated maintenance inspection tree, was discussed during an exit meeting with licensee representatives from management, supervisory, and engineering staff on July 20,- 1990. A-final meeting was held on August 10, 1990 (see Appendix-I for attend-r-ees).
Results The= inspection results for each of the major areas evaluated are summarized in the following paragraphs. Weaknesses are listed in Appendix 2.
I. OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE YNPS availability was 84.5 percent during 1988 and 91.1 percer t during 1989 . suggesting that the maintenance process is functioning well. The team found the overall= material condition of the plant to be well maintained, although the , -team's walkdown inspections identified some exceptions.
To further enhance the-material and equipment condition, greater attention to detail is warranted during management's housekeeping and configuration control inspection _ [ a; a n i ,
i . II. MANAGEMENT SUPPORT OF MAINTENANCE The team concluded that management support of maintenance was functioning well, Licensee plant.and corporate management are actively involved in the mainten-ance process.' Corporate managers displayed strong-support of maintenance activities including active onsite presence. The plant is the lead pressurized water reactor for plant life extension and license renewal (PLR), Management has committed resources to this initiative and is, through the PLR, actively _ assessing the plant's material condition and state of the plant's maintenance.
The relatively small organization'and few layers of managers _from plant super-visory level to corporate chief executive make for effective communications and is a strength ' Based on the small maintenance work backlog and the relatively low overtime, the plant staffing for support of maintenance was acceptable.
One weakness was absence of a formal program for self assessment of maintenance - l other than OA audits. Another weakness was the lack of a formal backlog program.
- Training of the maintenance staff was accredited by the Institute of Nuclear [ Power Operations (INPO). The plant has been slow in utilizing computers in { some areas, for. example, maintenance scheduling and work orders were manually i processed.
Still, the system was found to be generally effective.
Technical
support of the maintenance process was effective and engineers were integrated . into the maintenance department to assure such support. YNPS " engineer of the ! week" program assigns engineers weekly from the corporate department to' the-l plant'_s maintenance department. This was viewed as a strength.
The plant is d ' developing a root cause analysis procedure; however,. failure to have this procedure in place was viewed as a weakness.
The quality verification processes were functioning adequately; however, the. team identified a number of deficiencies that indicated a need for improvement in the licensee's approach } to assuring quality.
Both radiological and ALARA controls were incorporated ! appropriately into the maintenance process.
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III. MAINTENANCE IMPLEMENTATION
The licensee has a work' control program that-functions well. The team observed I that work was scheduled appropriately and was performed by qualified mainten-ance personnel.
Radiological and ALARA controls were implemented effectively.
Meetings to plan, coordinate, and schedule tasks ensured good communication and ! cooperation among work groups.
l The licensee's maintenance organization was functioning well, with a highly trained and qualified staff. Training programs for the maintenance staff were h exemplary.
Backlogs of work orders and rework were small.
Deficiencies found during walkdown inspections reflect some inattention to j detail'during licensee inspections and indicated that the deficiency identi- . fication process was not functioning as well as other processes.
The licen- . see's' trending program was in the process of being upgraded and was not yet .) described adequately.
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The Instrument and Control (I&C) department's measuring and test equipment , (M&TE) program was functioning well; however, the mechanical M&TE program was had some deficiencies.
YNPS management took prompt corrective action to revise and reissue the mechanical M&TE procedure before the end of the Maintenance
Team Inspection (MTI).
Overall the team concluded that the maintenance process implementat'ionNas described adequately and was implemented well. The relatively small plant staf f was ef fective, with good cooperation and communications.
The Maintenance-Inspection Tree .
-The inspection team's: conclusions on the maintenance program are indicated by j colors (green, yellow, red or blue) on the Maintenance Inspection Tree (Figure 'l 1).
For parts II and III of the tree, the upper-left portion of each block .
indicates how well the topic of the block is described and documented, includ- ' ] "" ' ing the adequacy of procedures.
The lower-right portion of each block indi-l cates the effectiveness of... implementation. Green indicates that the program is j well documented or that the program implementation is effective.
Even for-s blocks shaded green,. however, some areas for improvement.may be indicated, j Yellow indicates adequacy, but the element could be strengthened, and red j indicates the topic.is missing or the intent is not being met.
Blue indicates q the item was not -or could not be evaluated because of insufficient data,
Overall Conclusions Maintenance is performing well at the YNPS. The significant attributes of maintenance were well established and implemented.
The team identified a number of ' strengths and a few weaknesses.
As weaknesses were identified by the inspection team members, they were presented to licensee representatives for , initial: review and evaluation during'the course of the inspection.
Individual i . weaknesses are discussed in the appropriate areas of the report and are summar-ized:in Appendix 2.
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INSPECTION FINDINGS 1. OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE . - . . , 1.0 Direct Measures- $ ' Scope
. 'This part of the inspection reviewed availability, operability, and material t ' condition of the plant relativesto effective maintenance.
Plant equipment e,1d
-systems were inspected to determine the general plant condition, deficienc', x identification, safety precautions, and tagouts of' equipment,'as well as other , observations of maintenance activities whenever team members entered tF.e plant.
, The-team reviewed historic data that would reflect thelpossible effect that-maint'enance.was having-on plant operation.
The data examined covered plant.
! availability,cnumber of reactor trips'due to maintenance, equipment forced outage rates per 1000 critical hours, and Licensee Event Reports (LERs) attri-buted to maintenance for'the years 1988 and-1989.
. Findings ! 1.1'. Historic Data YNPS plant availability was 84.5 percent for 1988 and 91.1 percent for 1989.
Availability.. increased frbm 1988 to 1989 primarily due to a refueling which began 11n' November 1988, and lasted until the middle of January 1989.
YNPS had ~three reactor trips and a turbine trip during 1988 and three reactor trips during 1989. One trip in 1988.was attributed to maintenance. -The equipment . = forced o' tage rate for YNPS'was 0.35 per 1000 critical hours (greater than 15 u percent power) in 1988-and 0.50 per 1000 critical hours (greater than 15 ~
- percent: power) in.1989.
Six LERs'were attributed to maintenance in 1988 and 4 in 1989..The-data' indicate good plant performance. The decrease in the , number of reactor trips due to maintenance and the decrease-in the number of LERs attributed to maintenance are suggestive of improvement in maintenance.
Personnel exposures at the station have been relatively stable and low.
Personnel. exposures during refueling years have been between 200 and 230 ' person-rem. YNPS set a 1990 "As Low As Reasonably Achievable" (ALARA) personnel exposure goal of 242 person rem, which is relatively low. A signi- ' -ficant portion of'the.1990 personnel exposures are projected to result from a , ~ one1 time upgrade of seismic supports.
1.2 Plant Walkdown Inspection . The following are examples of deficiencies noted during walkdown inspections: Missing bolts in electrical panels and cable and junction boxes through-
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' air intake bo'x to blower adapter. Also, missing hanger on the engine j control circuit; ' Missing one of five bolts on both EDG No. 3 air intake boxes to blower
adapters; ,
.J . Loose (not torqued) cover on an environmentally qualified (EQ) transmitter d
(MC-PT-300); )l No, 3 Battery Room intercell connector cable bend radius less than j
recommended by manufacturer; -[ Safety injection flow transmitter (SI-FT)-1,. -2 and -3 flow transmitter to- } + mounting bracket each missing a screw; -j i Containment electrical oenetration blister box gaskets in poor repair and f + several openings in boxes being sealed with duct seal.
Industrial safety items: Instances of workers without hard hats and/or ! =+ ear plugs.
i l y The'abov~e observations were reported during the inspection and corrective
. actions were initiated prior to the team. leaving the site.
Items corrected { before the con'clusion of the inspection on August 10, 1990, are discussed in the report. The number of deficient items identified led the team to conclude that.an increased level of attention to detail including management oversight i was needed in'the licensee's deficiency identification processes.
The team'noted that the area around both the old and new Safety' Injection (SI) j Tank was maintained in an orderly manner.
Trench work-to install a new water i , , - line was maintained as a potentially contaminated area, and appropriate ! , controls were in olace.
Construction debris was minimized, and the non-conta- !
minated walkway was marked appropriately and had. adequate handrails. The area j of the previous SI tank was free of-trash and marked as contaminated.
The new l SI tank and the immediately surrounding area was clean (physically and radio-i logically).
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The turbine deck was congested since the turbine and the generator were b'eing serviced at the same time.
Turbine parts were identified and stored in an organized manner. The generator work was performed in a fenced area to prevent unauthorized access. While congested, this area was well maintained within the restraints imposed by the space available and the large volume of work.
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" [The~ overflow' pipe..on#'demineralizedwatertankNo.71wasleaking.. On reporting-j ' .,
! this to-cognizant YNPS:. personnel, theiteam was' informed.that this: leak had been- 'l
. " identified previously land'the; method 'of ' repair ~was being evaluated; ;No radio- . r " activity'.or environmental considerations.~were' involved.since the;leakag'e was.
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g < y . Conclusions-; -: ,.. , , . . Plant performance 1has been good.--The. plant'sLhigh avail' ability'and excellent ~ "! n operating >recordfreflect.well on;the maintenance. process.
The material.condi-
e tion of Lthe plant was adequate,' except for minor deficiencies'which should havei 7j ,. .been identified and corrected _during prior maintenance and/or from YNPS walk- ~ +' downs.. The threshold-for.. identifying Ldeficient-conditions was apparently tool lh,. s Thigho Given th_e.;numberfof maintenance. outage activities at the: time,:the - plant'.s condition was' adequate.. Industrial; safety was' generally adequate.- ! i ' ' ' , , .r .i i
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. II. MANAGEMENT SUPPORT OF MAINTENANCE , This part of the~ inspection determined the degree of management support of the maintenance process, including application of industry initiatives and parti-1cipation of management.
2.
Management Commitment and Involvement-Scope-This inspection area determined management involvement in industry initiatives and in providing leadership in maintenance training, self-evaluation and use of historical plant data.
Findings - 2.1-Application of Industry Initiatives . ' The team interviewed cognizant individuals and discussed licensee methods for application of industry standards.
Procedure AP-0055, Revision 6, Plant Commitment Tracking System, describes this process and provides for establish-ing priorities. -Industry information is -processed by the Technical Services' Department, which logs the information into the Project Commitment Tracking and Responsibility System (PROCTR), a computer tracking system, to assure that the - 'information 'is tracked until final disposition. After logging,-the information-is routed' to a designated Shift Technical Advisor (STA) for. applicability screening. The STA sends the information to cognizant individual (s), normally within two to three days.
During the outage,:an alternate individual was designated to review the information since the STA had more pressing outage functions.
Yankee Atomic Electric Company (YAEC) is~ represented on committees for most major industry code and standards groups such as the American Society of Mech-anical Engineers, American Nuclear Society, American Society of Non-destructive Testing,-ant Electric Power Research Institute. -YAEC expends in excess of 2 1/2 man year 3 for this representation.
Input to and retrieval from the Nuclear Plant Record Cata System (NPRDS) is through the corporate office; however, YNPS does not. participate directly.
2.2 Management Vigor and Example LThe YNpS is the lead pressurized water reactor plant for license renewal. The licensee has formed an engineering Plant License Renewal (PLR) group to deter- - mine wr.at must be accomplished to extend the plant licensed life. The PLR project is jointly funded by the Electric power Research Institute (EPRI), the U.S. Department of Energy (DOE), and the licensee. Approximately 18 licensee engineers with a like number of contracted engineers work on this project', which is centered at the Bolton, Massachusetts office.
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g , s .. x t . 13- ' w The licensee has no formal program for self-assessment and relies on routine ~ audits by,the corporate Quality Assurance (QA) organization.
Self-assessment is also covered. in normal problem solving and efforts to eliminate recurring problems.
The licensee has identified several areas for maintenance process improvement, and these have been incorporated into the one and five year main-i-tenance plans.
These program areas include vibration monitoring, lubricating ' oil analysis, thermography, and preventive / predictive maintenance. ' Otrer, long range goals include revising the maintenance request system, increased storage l for spare and replacement parts, and improvements in root cause analysis.
l YNPS staffing is approximately 215 employees including management.
Staffing appeared to be adequate as determined from discussions with management personnel and from reviewing overtime records.
Prior to the outage, average e overtime was approximately 2 hours a week during the first half of the year.
.{ During this same period, there were no significant increase of non outage-related maintenance requests.
The team did observe, however, that key managers ~ ' appeared to be spending excessively long hours at the plant during the time the team was onsite,-attributable in part to impact of the inspection, j Maintenance. training is INPO accredited and applies to all levels of manage - ment, staff, and craft workers.
In addition, specialized training is provided j as needed.
For example, two. individuals were sent for training in trending and-trend analyses, and three supervisors were given training on Limitorque main-tenance in the Bolton office.- Feedback to the plant management was fast and accurate, in a large part, because there are few layers of management.
For example, there is only one manager between the first line foremen and the plant manager.
The plant manager was often in the. plant and re vily available for consultation by j individuals at all organizational levels.
Ti Conclusions' Licensee management is highly visible and involved in operations. The rela-tively small size of the' organization affords close communications in the plant d and with the corporate office.
Training and qualification programs are in i place, and their staffing is appropriate.
The PLR program is staffed and , active in studying various facets of the license renewal process including the condition of~ systems, structures, and components.
Training is accredited by INP0 and the licensee participates in many industry organizations. Management has.no formalized self-assessment program for the maintenance process, which is . viewed as a weakness.
3.0. Nanagement Organization and Administration (Corporate and Plant)
Scope This inspection area assessed the effectiveness of the organization and admi-I nistration of the maintenance functions and the maintenance program. To provide a broad' perspective of maintenance activities, the inspection included:
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, the existence, availability and scope of'a formal maintenance program; main- - tenance policy, goals and objectives; allocation of resources; identification and definition of maintenance requirements; maintenance performance measure-ments;.the documentation control system for maintenance; and the maintenance ' decision process . Findings , 3.1 Program Coverage for Maintenance-The' maintenance plan is d' escribed in the 1990 Yankee Performance Goals, Docu-ment No. YAEC 1728, and the Maintenance Group, Five Year Goals. The former = describes'immediate (1 year) goals while the latter describes longer range plans. Near term predictive maintenance goals include implementation of expanded vibration monitoring, lubricating oil, and thermography programs.
Longer term goals include the facility preventive' maintenance program, includ-t ing high voltage surge comparison for motors and cables and an equipment trending program. Other long term projects for maintenance management systems include revisions to the spare parts purchasing, a maintenance surveillance program, and a computerized maintenance history system. As part of the PLR ' program, a computer based program for record storage is being considered.
The- ' team determined that program coverage was adequate but could be more defini- - - tive.
Implementation was functioning well and was focused noticeably or, plant reliability and safety.
3.2 Policy, Goals, and Objectives l
Corporate goals and objectives are described in the YAEC 1990 Yankee Perform-ance Goals, document No. YAEC 1728.
There are-no formal directives.
The acting-Manager of Operations, who reports to the President of YAEC, maintains an office in the YNPS,.thus having close contact with'the plant and assuring ~ direct communications with the corporate offices.
The close communications provide direct feedback to the corporate management.
Responsibility and authority is delineated clearly through organization charts and job descript- ' 1ons, which are updated as changes are made.
Organizational conflicts are
resolved in meetings among the plant management personnel. Management appeared
to be' meeting their objectives.
3.3 Resources Allocation , Maintenance staffing appeared adequate from a review of the overtime records during the first part of 1990 (prior to the outage). Maintenance personnel i overtime was low, approximately two hours per week on average; however, during-the inspection, management overtime was very high with 12 to 14 hour days the norm' -During operating periods, contractors are not used except for special . tasks, such as asbestos removal and work in the switchyard (a power system . function ' performed by the New England Power Company).
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, , b One objective for 1990 was to initiate maintenance work requests three months prior to outage to assure completion of scheduling and to allow purchases of needed materials.
This effort was successful as work was proceeding orderly, and the outage was two days ahead of schedule when the inspection started.
Technical support was excellent.
Engineers from Bolton were performing engi- .neering and supervisory functions to supplement'the plant staff in several
' areas such as: directing the steam generator and inservice inspection work; installing the new safety injection tank; and motor operated valve testing.
3.4 Maintenance Requirements (Corporate and Plant) ' YNPS's maintenance program is established through a series of administrative procedures that include-the requirements for corrective and preventive main-tenance (AP-5002, Revision 12, Maintenance Department Corrective and Preventive ' Maintenance Program), corrective action (AP-0227, Revision 6, Corrective , Action), surveillance ( AP-0220, Revision 16, Surveillance Tests and Records), and post-maintenance testing (AP-0230, Revision 1, Post-Maintenance Testing).
Operational procedures (the OP-45XX and OP-46XX series) contain specific surveillance procedures.for plant equipment.
Environmental requirements are described in AP-0100, Revision 2, Environmental Qualification Program. This area was functioning well.
Maintenance-procedures and all Maintenance Requests (MRs) are reviewed and approved prior to implementation, including review by the Quality Services Division (QSD).
Regulatory requirements, codes and standards, and post-main-i tenance testing of completed work are included as applicable. QSD may esta-blish mandatory notification points for the work.
Reviews of MRs assure that.
regulatory requirements,and post-maintenance testing are specified as required.
During maintenance, QSD is notified as required by the MR. QSD has the option to witness selected work evolutions. The team did not find any MRs that had missing or erroneous requirements.
3.5-Performance Measurements .The Maintenance Manager is involved in the day-to-day operation of the main-tenance department. Many decisions made at lower levels at larger utilities are made at YNPS by individuals normally considered " upper management." At YNPS, there_are only two levels between the maintenance manager and.the company president. As a result, management is actively involved in all phases of the maintenance activity. Work sampling is often performed since the YNPS managers supervise many of the larger project' and are frequently in the plant.
Formal walkdown inspections are performed in accordance with procedure AP-0040, Revi-sion 10, Plant Inspection' Program. TLis procedure covers cleanliness and housekeeping, industrial safety, general plant and material conditions, and radiological controls.
As discussed above (paragraph 1.0), the licensee's attention to physical condition of the plant during walkdown inspections lacked attention to detail.
Management stated their commitment to improve this weakness and stated that ! a -
e' ,, l ... >16: . the relevant procedure (Ap-0040) is scheduled for revision to strengthen its requirements.
Currently, the timeliness of completing these inspections includ-ing acceptability of corrective actions to resolve inspection findings are not being trended.
A human performance analysis coordinator was added to the staff.
Root cause analysis has not been a formal program. However, the licensee is currently developing a formal procedure.
The team concluded that YNPS-needed to formal-ize the use of root cause analysis, including when it is used.
The Technical 1 Services group tracks INPO performance indicators to assure these data are reported to INPO and the corporate engineering organization.
The team did not-find evidence that the INPO information was being widely used by management. QSD also tracks and trends nonconformances, corrective actions, and other quality related information. The team concluded that the trending program was adequate, but could be strengthened.
3.6 Document Control System YNPS maintains a manual system for equipment maintenance history. The system-is a card file that contains the maintenance history of major equipment. With the exception of a 4 - 5 year period during the late 1960's, the records sampled were complete and provide a reliable history of the equipment.
The MR form provides for equipment history cards to be updated as part of closing the maintenance file when work is completed. A computer-based program is being ' considered as part of the PLR program.
The document control system is described in procedure AP-0221, Revision 12, -Plant Record Management.
During the inspection, the documents requested from the control center were found and retrieved in a timely manner, indicating that the system was functioning well.
3.7-Maintenance Decision Process The decision making process to maintain, upgrade, replace, or defer work for plant equipment was not described formally.
However, actions other than routine maintenance are discussed with plant management prior to committing plant resources.
Large expenditures require corporate approval. This system .was functioning well.
Conclusions Corporate and plant management and administration were functioning well to support maintenance.
The small size of the organization permits less formal-ization of programs.
Lines of communications are short. The absence of layers of management between the lowest supervisor and top management is a strength, as is corporate management's involvement in plant activit'ies and decision processes.
Program descriptions generally do not have or require the amount of detail generally found in a large plant. Management goals and policies are frequently implemented by management's direct involvement in maintenance.
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license renewal program also assesses the state of maintenance.
Schedules were being met, and acceptable work products were resulting from the resources available with a reasonable work backlog, indicating good resource allocation.
Document control was functioning well.
The team noted two areas where improve-ments were warranted: (1) publishing a root cause analysis program including establishing criteria for initiation; and (2) broadening management us( of performance indicators.
" 4.0 Technical Support Scope This inspection area evaluated the extent of technical support, including quality control, probabilistic risk assessment and radiological control.
The following areas were reviewed: ,, Internal / corporate communications;
Engineering support;
Role of orobabilistic risk assessment in maintenance process;
Role of quality control;
Integration of radiological controls into the maintenance process;
Safety review of maintenance process; and
Interpretation of regulatory documents into the maintenance process.
- 4.1 Internal / Corporate Communication Channels S c.o_p.e This part of the inspection determined the extent to which each department has established channels of communication between the corporate and maintenance organizations.
Findings Communications are not formalized to the degree found in larger organizations.
Plant procedures that reflect broad corporate and plant goals are used to control activities of the maintenance department.
Plant management is involved in maintenance.
Daily meetings are held to review maintenance requests and work ir, progress and are attended by department representatives, including corporate representatives as required.
Plant outage activities are discussed, and planning and scheduling are coordinated.
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,. . Plant management considers the corporate office an extension of the plant ' staff.. Corporate'tachnical' support was observed commonly during the inspec-tion. Several engineers from.the corporate office were on site to assist in resolving the team's issues.
Team interviews included engineers and manage-ment from'the corporate office who were active in directing maintenance and support activities and in supporting-supervision of contractors.
!' Conclusions [ . Communications.within:the plant and between the plant and the corporate office-functions well. Methods of. communication were not formalized; however, the- - daily plant meetings were effective in communicating plant status and - activities.
4.2 Engineering-Support + - Scope ! Integration of engineering principles and evaluations into the maintenance process was evaluated,by reviewing work orders, preventive maintenance, failure.
analyses, and other maintenance activities.
, Findings Routine maintenance activities'are handled by maintenance support engineers y ' within the maintenance department, with corporate support as needed.
To evalu- > ate. corporate! support the team reviewed plant component modifications, tech-nical specification changes, 10 CFR 50.59 reviews, and design change requests.
Good corporate engineering support is provided for maintenance activities.
' .However : the team noted that no formal program exists'for performing failure and root cause' analysis.
" YtiPS has an " engineer of the week" program, whereby corporate engineers are assigned to the plant maintenance department for a week at a time.
Depending on needs, effort is made to select from a different discipline (electrical, mechanical, instrument and control, etc.) each week.
The plant maintenance manager _and.the engineering manager determine the assignments.
Some examples - of the activities performed by these engineers are: Development of critical component system list;
' Identification of critical component failure modes;
Troubleshooting analysis for maintenance problems;
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Improvements in maintenance practices and procedures; and - *- Review maintenance procedures to assure that components are being main-
tained within their design basis.
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. I Conclusions
i.
Engineering support to the maintenance process has been well integrated; how- ' ever, the absence of a formal root cause analysis program is considered a weakness.
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4.3 Role of Probabilistic Risk Assessment in the Maintenance Proce'ss * !- Scope This part of the inspection determined the extent that probabilistic risk i assessment (PRA) concepts (including common mode failure, single failure ' criteria, safety system and component significance) are considered in the
p _ maintenance process in areas such as planning, scheduling, and prioritization.
The team reviewed activities related to the applicatinn of PRA in the mainten- ' .i
'" t, ance program.
' l Findings l.
The licensee'has performed a detailed system level PRA which was in NUREG f CR-4589, Review of Selected Areas of YNPS Probabilistic Safety Study.
The PRA includes consideration of common mode failures, single failures, and safety system significance. The PRA has been upgraded and used in emergency operating ' procedures, design changes, training, backfit determination and procedures, i Systems which contributed significantly to the overall risk of core melt are.
ranked and listed by importance in Table 2 of EGG-SSRE-8257, May 1990, Risk-
Based Inspection Guide for the YNPS.
' , The plant PRA is not used directly in the maintenance process; however, risk is ! currently embodied in the planning and prioritization of maintenance activities , _ by use of the Technical Specifications.
The highest priority is assigned to ! work to prevent or mitigate the consequences of an accident, and to prevent the release of radioactive' material. The PRA is also used in the plant engineering and modifications.
> Conclusions ,
Management has not established a formal program for the use of PRA in the m ! maintenance process; however, maintenance management was aware of the risk importance of various plant components and systems.
The team concluded that adequate consideration of risk was included in maintenance planning and implementation.
' 4.4 Quality Control in the Maintenance Process , Scope This part of the inspection determined the extent of quality control (QC) involvement in maintenance.
The team reviewed the licensee's procedures for implementing the QC surveillance program and trending of findings.
The team , .
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[ . t held dis'cussions;with QC personnel and reviewed work packages. Quality Assur- [ .ance (QA) audits, and QC inspection plans for appropriate hold and inspection
points., Findings The Quality Services Department (QSD) conducts QA/QC activities at YNPS.
All , 'MRs on safety-related equipment requires QSD involvement..During initial-MR.
. review, QSD establishes hold and/or surveillance points. When work has . progressed to the surveillance point, a QSD inspector may inspect the work to' ' predetermine acceptance criteria.
For hold points, the inspector must perform-l the inspection.
Results are documented.in.a Quality Control Inspection Report.
(QCIR). Deficiencies'are reported by either a quality control deficiency ' observation report-(DDR) or a non-conformance report (NCR) to the group responsible.for resolution.
- . Annual-' audits of maintenance are required, except for corrective action and
station blackout _(10 CFR 50, Appendix R) which are performed biannually and one ! per refueling outage, respectively.
The team reviewed the following audits of the maintenance department which were performed during 1989 and 1990, and the o responses to the audit findings.
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Audit Report No. Y-89-03: -Radiation Protection.
l Audit Report No. Y-90-6A: Maintenance.
, Audit Report No. Y-90-07: Modifications.
, Audit Report No. Y-90-15: Technical Specification.
- Audit Report No. Y-90-16:. Corrective Action.
. > - The team concluded that the audits were thorough and the audit program was '" adequate. -QC deficiency and observation reports were being written and responded to and Non-Conformance Reports (NCRs) were being issued for signi-ficant issues.
The_ team observed QSD involvement in the following activities: .* MR 90-363, Inspect Internals and Backseat of NRV No, 1 ' MR 90-364,-Inspect Internals and Backseat of NRV No. 2
MR 90-1156, Maintenance and Rebuilding of SI-MOV-518
, MR 89-257, Repacking of SI-V-674
, QSD publishes an annuaI trend / performance evaluation report analyzing indi-i .'vidual verification activities such as QA audits, QA surveillances, QC inspec- ' - tions,. NRC inspection and self identified conditions (such as Licensee Event ? h
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, ! t Reports' and NCRs).- During 1989, 180 findings were noted, of which 44 related
L to maintenance / surveillance and 65 to engineering technical support. There ' were no_significant adverse _ trends effecting nuclear safety or quality.
The team found the annual report to be adequate.
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, Conclusions g i ! Program documentation, as well as inspections themselves, was good. However, I as discussed in Section 6.3, several deficiencies were identified that the team
considers symptomatic of the need for better QC coverage.
T,- i 4.5 Integration of Radiological Controls into the Maintenance Process , , t ' $ Cope L
' Integration of radiological controls into the maintenance process was
inspected.
The team reviewed corporate procedures to determine the extent of f corporate involvement in reviewing plant modifications for ALARA considerations ' - and the method YNPS uses to conduct ALARA reviews of maintenance tasks.
' Findings t Engineering instructions WE-101, Revision 10 Plant Design Change Request, and WE-100, Revision 19, Engineering Design Change Request, specify review of Engineering' Design Change Requests (EDCRs) and Plant Design Change Requests
' (PDCRs).
These documents give specific criteria for the level of ALARA review r of plant modifications and effectively document the corporate ALARA review.
The team reviewed several completed EDCRs and PDCRs and noted that appropriate . ALARA recommendations had been incorporated._ Radiation protection (RP) is
active in planning and preparing for maintenance work by their review of i planned modifications prior to the outage.
Licensee procedure OP-8020, Implementation and Documentation of ALARA Job- [ Reviews, specifies the criteria for those jobs requiring an ALARA review ' including: work with estimated exposure greater tnan 1 person-rem; work in an area where the exposure rate is greater than 5 R/hr; or work in an area with ' ' contamination levels greater than 500,000 dpm/100 cm. The procedure also specifies a higher level of review, i_.e., review by the Plant ALARA Committee < (PAC), for those tasks with a total exposure estimate greater than 10' person- , rem.
Review of several completed ALARA work packages showed that the licensee ' . estimated the person-rem effectively, Estimated exposures for the entire station, developed prior to the start of the outage, were close to actual.
YNPS was effectively estimating and tracking personnel exposures and was esta- . " blishing ALARA goals.
RP supervisors were actively involved and attended daily i planning and scheduling meetings.
' By reviewing the RP general employee training lesson plans, observing worker practices'inside the radiation controlled area, and talking with several work-ers,'the team determined that YNPS was instructing workers effectively on methods to minimize personnel exposures.
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Training on mockups _is used to help reduce personnel exposures.
Examples are: primary side steam generator for practicing eddy current testing and steam , generator tube plugging; stud tensioner to loosen or tighten the studs on the steam generator manway hatches; and a feed and bleed heat exchanger. Also a i new device is used to lower and lift remotely the manway hatches to the steam generators. Discussions with personnel, review of exposure estimates and ' actual exposures for tasks involving mockup training indicated that this train-ing is effective.
Use of closed circuit television (CCTV) inside the vapor containment (VC) appeared to be effective in minimizing numbers of observers, thereby reducing personnel exposure.
Th'el team-observed RP coverage for several work activities including work on
.' eddy current testing equipment inside the steam generator platform tent.
The RP technicians providing job coverage were knowledgeable of the task, the radiological conditions, and YNPS procedures.
The team considered RP coverage
good for the work witnessed.
J YNPS.used ammonia addition to the primary system during' coast down tri reduce - radiation levels within the VC.
Preliminary results indicated decreased . general' area dose _ rates in various areas within the VC, including the brass drain box area where rates were reduced from 18-20 mR/hr to 9-10 mR/hr. Also, dose rates inside the number four steam generator were approximately one half-r those of the last shut down.
YNPS is still evaluating the possibility of j replacing components which contain stellite with non-cobalt bearing materials.
~ While touring the brass drain box area, one case was observed where individuals were waiting under an overhead line posted as a " Hot Spot." They were unaware of the posting because it was above the line of sight.
RP identified the _ problem and promptly initiated corrective actions which included adding tempo-rary shielding to the line and posting the area more visibly.
The licensee
stated that other " Hot Spots" would be reviewed to ensure that postings were- . clearly visible.
,Concl usion s YNPS was effectively estimating and tracking personnel exposures.' -YNPS was , adequately instructing and emphasizing to workers the need to minimize personnel exposures.
YNPS made effective use of mockup equipment and training te-minimize personnel exposures.
The corporate office is involved in planning and preparation to support maintenance by reviewing plant modifications for-ALARA' considerations prior to the start of the outage.
The team concluded that' ' radiological controls were well integrated into the maintenance process.
' ' 4.6 - Safety Review of Maintenance Activities ~ Scope
, The extent that industrial safety was integrated into the maintenance process was evaluated, p ! j l , -- y
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. Findings The maintenance department safety program is implemented in accordance with the "YNPS Safety Standards," a manual which provides reasonably comprehensive instructions for workers and managers to follow for a safe working environ-ment. Management is responsible for implementation of site safety policies.
Quarterly safety inspections are conducted to ensurb i@lementation of the safety. aspects of operating and maintenance procedures. Monthly safety meet-ings are used to communicate issues and concerns to employees.
The Health and Safety Supervisor (H&SS) is responsible for the safety program, the Fitness for Duty program, and is the registered nurse for the site.
The recent development and addition of the fitness for duty program has limited the H&SS's time available for tracking safety deficiencies. The team noted weak-nesses in implementation of plant inspections, e.g., missed inspections and/or not completed on schedule, as well as a lack of performance trending"and corrective actions follow-up.
The team found that safe industrial practices were generally being employed.
H&SS was in the process of initiating a new safety initiative, the DuPont Stop Program, to involve the plant's staff in identifying unsafe conditions.
How-ever, on two occasions compressed gas containers were found in the deminerali-zer room that were not secured from falling (Safety Standards 5.1. 4.3).
The licensee was notified and appropriate action was taken immediately. A chain fall was noted to be at the end of a monorail without an installed stop or other restraint to preclude it from falling.
This monorail was located in an
aisle and presented a considerable potential hazard.
Supervision was notified; however, no immediate corrective action was taken. Workers were also observed in the emergency diesel generator room (a high noise area) without required ear protection while a diesel was operating.
Personnel were observed to not have the required protective head covering under the VC while equipment was being lifted in the radiological space.
The H&SS corrected this problem when notified.
Conclusions Overall, practical and ef fective industrial safety measures have been imple-mented. The licensee is enhancing the safety program, and an excellent safety manual is in place. A few exceptions were observed, indicating there is still room for for improvement.
4.7. Integration of Regulatory Documents in Maintenance Scope This section determined how the YNP5 integrates regulatory documents into the maintenance process through review of procedures recently establishe A T. mi. r - . q , 7 m 7,>. r , , ter ,e t ' d( , Ag_ "il i , ig 24-
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! , Findings- ! . . . !, =The document control l system for.YNPS was defined by. procedures AP-0020, Revi- ' - sion 9; Industry Operating Experience Program, and AP-0055 Revision.6, Plant
CommitmenttTracking' System.
Procedure AP-0055 incorporates a computer tracking.
! system called. Project Commitment Tracking and Responsibility System (PROCTR).
- This is a strength. Upon. receipt of a regulatory document, a copy is sent to< ' ' ' the Technical Services DepartmentLwhere it is entered in the tracking system, which follows the document throughtscreening, approvals,;and implementation.
" .The-team reviewed documents currently being tracked _and determined that the ' s " system was. functioning well..Ano.her positive aspect.of this system is that 'one person oversees the entire optration. This helps ensure corrective actions , are initiated for deficiencies. Along with a list of open items, which is . .! - published every two weeks,_ the pro:edure for incorporating regulatory documents s - , into the maintenance program has bten-effective.
,i \\ Conclusions-J Integration of regulatory documents into 'the maintenance process was well I , g proceduralized and implemented.
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c 25- ,. ! . III. MAINTENANCE IMPLEMENTATION This part of the inspection determined the effectiveness of maintenance controls and, more importantly, the quality of the work performed.
Four areas ,. were evaluated: work control; the. plant maintenance organization; maintenance p: facilities, equipment, and material controls; and personnel control, p 5.0 Work Control Scope ! Controls in.the following areas were evaluated: review of maintenance activi-l' ties in progress,' work order control, equipment records and history, job plann-ing, work priorities, work scheduling, backlog controls, maintenance proce-dures, post-maintenance testing, and review of completed work documents (see l Appendix'4 for listing).
The team observed MRs in progress, reviewed completed MRs, reviewed administrative procedures for control of maintenance and post-e . haintenance testing, evaluated maintenance procedures, observed material control, and talked with various levels.of maintenance personnel.
, , 5.1 Maintenance in Progress scope The review of maintenance in progress was evaluated in: (1) mechanical,=and - (2) elect'rical and I&C, The electrical and !&C areas were combined since the work performed by these two groups is related closely in training, procedure application, and-theory.
' Mechanical Maintenance Findings LpSI Check Valves The team witnessed portions of an~. inspection on the No. 1 Low Pressure Safety injection (LPSI) pump discharge check valve - The inspection was being . i'
- conducted according to MR 88-1863 by Atlantic Valve Company to verify correct material on ~ interior bolts Mechanical maintenance and QSD personnel were at the job site performing quality assurance surveillance.
The team discussed the job with. Atlantic personnel. They were knowledgeable of the job and the-procedure, which was at the job site.
Each procedural step was ng being , signed as it was being completed (i.e. each step has space beside the step for' ! -initials).
The team discussed the deficiency with personnel at the job site and later turned the deficiency over to the QSD supervisor for resolution. One additional observation concerning the torquing procedure used during the conduct of this MR is discussed in Section 6.0, Control of Contracted Maintenance.
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i i i i Motor-Operated Valve Acceptance Testing (MOVATS) ' t ! The team witnessed preparations for MOVATS of SI-MOV-518 and SI-MOV-01 by the MOVATS company. -The MOVATS employees were found to be knowledgeable _of motor-operated valve operation and design, and maintained good communications with j YNPS. engineering personnel. The MOVATS testing procedure incorporated relevant i NRC information on problem areas and was well written and illustrated. The ,' planned' inspections and testing this. outage were extensive, reflecting the licensee's initiative to maintain these valves in a reliable condition using a predictive maintenance process.
No deficiencies or concerns were identified, t .. Steam Generator Examination , b ! . . ! The licensee elected to inspect 100*4 of the tubes in steam generator No. 4 from i tube end to tube end using a bobbin coil eddy current technique at four frequ- .} i-encies.- Steam generator number four was last inspected in April 1984.
Prior to this outage, 80 tubes.had been plugged.
In addition to the bobbin coil
inspection, YNPS inspected eight selected tubes using a three coil rotating probe in the cold side-at the top of the tubesheet (1 3 inches) to better , identify suspected defects.
In addition, approximately 185 tubes were selected . randomly for inspection of the top of the tubesheet (13 inches) hot side to determine if there were any cracks as had been found in other facilities.
This
inspection significantly exceeded the Technical Specifications requirements,
l demonstrating thoroughness.
! L Seven tubes were identified as defective (i.e., greater than 40% through-wall).
' ' . Of these, defects identified previously in six grew by more than 10?4 and the i seventh grew by less than 10's, which placed the steam generator in Technical Specification Category C-2.
No further. testing was required since the initial , sample included all active tubes.
In addition to the defective tubes, 22 tubes were identified as degraded (20?4 - 39?4 through wall defects) and three tubes J were found with.less than 20*4 through wall defects. YNPS elected to plug six t degraded tubes in addition to the seven defective tubes, bringing the number of > plugged tubes to 93 (5.7%), i The eddy current data was reviewed by two independent certified Level II analysts.
If there was a difference of more than 10*4 in the size of a defect as analyzed by these individuals, the contractor (Zetec) Level III analyst resolved the difference.
In addition, the licensee's certified Level III t reviewed the data from all defective tubes. A tube evaluated as defective by i one analyst could not be reduced to degraded by the contractor Level III analyst without concurrence of the licensee's Level III analyst.
t No deficiencies or concerns were noted.
Inservice Inspection The. licensee was on schedule for completing the required ISI testing of the third inspection interval.
Changes were in progress to add the additional requirements of the 1986 Code, since the fourth interval will require the use
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of the 1986 Edition with no addenda. These changes were expected to be ! completed prior to the initiation of the new ISI program in'1991.
No concerns ' were identified, f Safety Injection Tank YNPS inspected the new 304L stainless steel safety injection.(SI) tank by using ? a vacuum box and soap solution on all of the tank welds except the fillet weld between the bottom and the side wall.. No defects were observed.
The team o witnessed the static water testing of the tank, which consisted of filling the , tank with demineralized water and visually inspecting for leaks after a,four ! hour holding period.
The tank had a very small leak in the fillet weld between the tank side wall and the bottom. Due to the location and small size of the t leak,. an accurate leak rate could not be established. Also, when the tank was filled, some water weeped from vents in the+ tank's foundation.
The design of this tank included a sand bed below the tank bottom to provide uniform support.
During fabrication, this sand bed was open to the elements and had become l saturated by rainwater, and-this was the suspected source of seapage from the
vents.
The tank.was drained, and the welding defect was ground out on both the inside f .and outside welds and repaired.
A vacuum box test of all welds in the tank , bottom was then re performed.
In addition, a specially designed vacuum box was ! fabricated to test the fillet weld between the side wall and the tank bottom.
. No leaks were' observed.
In the absence of any leaks identified by both vacuum
tests of the tank bottom welds, YNPS concluded that the water coming from the - tank foundation vent holes was from compression of the saturated sand and that the SI tank was acceptable.
l , Main Condenser Inspection The contractor (Cramer and Lindell) inspecting the main condensers recommended > plugging approximately 90 tubes after eddy current examination, based on the . licensee's following plugging criteria: 75% through wall defect from ammonia grooving;
50% through wall for general wastage; and
40% through wall for steam erosion.
- YNPS' was-considering reducing the acceptance criteria-for ammonia grooving as a l
conservative approach to reduce condenser leakage.
YNPS has also applied for ,an Environmental Protection Agency permit to use Morpholine in the secondary system to reduce ammonia grooving and steam erosion.
Erorion - Corrosion Program The team reviewed the erosion-corrosion program procedure (AP-0911, Revision 0, Erosion / Corrosion Monitoring Program) and determined the program met both r i -- ,
_ _ _ _ - ... - o ! . -
l ' the. intent and requirements of Generic Letter 89-08, Erosion / Corrosion Induced ' Pipe Wall Thinning. The program was initiated in 1987. The procedure includes attachments from previous wall thinning inspections to provide ready history and trending data of all components in the program. Approximately 60 compo-i , nents were selected for examination by the Corporate Engineering group in conjunction with plant personnel to assure that experience, as well as engi-neering considerations were incorporated.
High energy single and t'wo Ehase i systems such as extraction steam, heater drains, condensate, feedwater, auxi-11ary steam, and steam. generator blowdown. lines were included. At the time of - the inspection, examination of the components had not been. completed; however,
approximately six components had been identified for further evaluation due to i wall thinning, including single phase and two phase regions in drain and ' extraction steam lines.
One steam line elbow had a different marking pattern.
The grid had been e ked~ t in a previous inspection and re-used during tFe current inspection. The lice r ~ ' -see agreed that this obsolete pattern should te brought up the present confi-
guration to avoid confusion.
Re-marking and re-testing of this elbow was sche-
duled for this outege.
Conclusions Observed mechanical maintenance work was conducted in.mcardance with procedure and quality.
The work was documented adequately and requ: red forms and author-izations were present in the work packages. Work packages un lerwent thorough ALARA review prior to conduct. Maintenance personnel performing the work were ' well qualified and experienced.
, The examination of steam generator No. 4 was thorough and in excess of regu-latory requirements, indicating conservativism. The ISI program is on schedule to be completed within the appropriate time frane for the third 10 year inter-val.
Inspection of the new SI tank and subsequent repair of a leak was adequ- ' ate.
The erosion-corrosion. program met both the intent and letter of the regulations.. In addition, the inspecticn procedire provided ready information' .' from past inspections.
Electrical / Instrumentation & Control Maintenance in Progress ' Findings , The team observed portions of main generator exciter relay testing by the relay . test group on the 2400 volt switchgear in the switchgear room.
This was an 18 month surveillance conducted under procedure OP-5762, Revision 9, Checking and Setting Plant Protective Relaying. The surveillance consisted of using a test current device and verifying the long-time and short-time over-current settings of the relay.
Personnel appeared knowledgeable in the performance of the test; however, the procedure was not at the job site. A preventive maintenance card with previous values was at the job site. The team discussed the surveillance with electrical personnel and obtained a copy of the surveillance procedure.
, The licensee stated the relay group personnel test relays at both nuclear and 'T I u-
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r F j fossil plants:and were well experienced; still, the procedure should have been at the job site. ' As the job was not safety-related, the item was turned over to plant' electrical personnel for resolution.
The. team witnessed replacement and testing of No. 1 LPSI pump breaker everload ' under maintenance-request 90-1362.
The breaker was being replaced because its overload setting could not be adjusted satisfactorily during an ear'liei' breaker
inspection.
The team discussed the job with the electrical craft and reviewed the procedure and noted the following: e Although having failed the previous test, procedure OP-4506, Revision 12,
Inspection ECCS Circuit Breaker No. AK-25, page 4 step 10 was signed indicating the acceptance testing was acceptable.
The team discussed the
F discrepancy with the electrical craft and later informed the Quality Service Group supervisor who initiated Deficiency Observation Report'(DDR) No.'90-12.
The team considered the corrective action appropriate.
'
, Torque wrench (YAEC 4092) and digital voltmeter (YAEC 3483) each had 2
calibration stickers.
Section 7.0 of this report discusses M&TE.
One electrician was leaning against the metal workbench used for breaker,-
testing while operating a multi-amp tester. Also, the breaker test area did not have non-conducting workbench surfaces and rubber floor mats to provide protection for workers.
The licensee ordered rubber. matting to protect the floor area and cover the work bench.
A spare breaker marked class 1E lay on the floor of the switchgear room.
- The breaker was intended for use on balance of plant (BOP) components, but was not marked clearly to preclude inadvertent use in a safety-related application.
The! licensee removed the breaker and returned it to the non-safety storeroom.
Minor l wiring deficiencies were observed in several panels.
Pressurizer
heater breaker No. 3 had broken strands on one auxiliary contact wire and a strand was-not engaged with the capture clamp on another wire.
The . Post-Accident Hydrogen Control system breaker FN 18-1 had one broken strand on the-starter coil.
Several strands on the wires were intact and- 'the broken and loose strands posed no shorting problem. The deficiencies were turned over to the maintenance manager for resolution.
The team witnessed portions of a fuse inspection behind the control room panels and in the switch gear room on the 2400 volt switchgear.
No deficiencies were l. noted. On the 2400 volt panel, section 3, cubicle 20, a fuse for the potential transformer was inserted in the holder such that one end was in contact with-only about 50% of the holder fingers. The licensee initiated maintenance request 90-1522 to correct the condition.
The team also found missing screws
on a cable tray cover retainer on a 2400 volt vertical tray above the 2400 volt ' switchgear, section 3, cubicle 22.
This deficiency was referred to YNPS management for resolution,
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. Portions of the battery charger #1 service test was witnessed in which Proce-dure OP-4526, Revision 8,- Battery Charger Service-Test, was used.
Electrical personnel were knowledgeable and familiar with the test procedure, and no deficiencies were noted.
The team observed: calibration of primary coolant system pressure transmitter; checks of voltage relays for-the diesel generators; checks of differential ' . relays on -the main transformer; 125 golt battery discharge test; and work on nuclear ~ instrumentation. Maintenance and. quality control check points'were specified procedurally and were being used.
Interviews with electrical and I&C supervisors and technicians found them knowledgeable of plant requirements, as well_as the tests they were performing.
1&C personnel thoroughly reviewed appropriate procedures and were given specific instructions by their supervi-sors.
Instruments and tools were examined before performing work, and the "as-found" _ conditions were identified and documented for each item of equipment and instruments referenced,in the procecure. Personnel followed their proce-- dures and: instructions. At.the completion of the work, each component was tested to predetermined post-maintenance test criteria. The procedure had a final _ independent review to verify that the components tested met procedural requirements and were returned to the required configuration.
The I&C technicians demonstrated a high level of understanding of their
assigned tasks within their responsibility area and I&C supervisors were aware ! of_the capability and qualification of each technician they supervised.
' Supervisors were observed monitoring ongoing work.
[ Conclusions Personnel performing surveillance and maintenance work were knowledgeable and exhibited a good attitude toward their assignments.
Maintenance procedures and ' instructions were'well organized and specific.
Excellent communications existed among personnel and a well-organized training program is a strength. A low frequency of rework was noted.
Both the documentation and functioning of-the I&C maintenance process are good.
Strengths in the I&C program were in the - high level of management review devoted to the maintenance process, ALARA reviews of work packages prior to their conduct, and high level of staff
experience and dedication.
5.2 Work Order Control Scope , iThe' objective was to evaluate the effectiveness of the MR control process.
The team reviewed the Administrative Procedures (AP) for issuance and control of MRs,L reviewed authorizations received from operations and other cognizant departments,'and observed work in the field.
The team reviewed AP-0205 which details the' administrative controls for work requests, as'well as the standard l MR form.
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Findings l The MR form is comprehensive and requires high level of canagement review by cognizant departments. This review level is made possible by the small size of i _ the YNPS. staff and plant and was_ viewed as a strength. A log is maintained by ! the Operations department to track open MRs, as well as the department's reviews and authorizations.
No problems were noted with the design or control of'the MR program, although no major strengths or weaknesses were evident.
' Work >in_the field was well-controlled, authorized in advance, and conducted with the cognizance of the Operations department. However, as described in i section 6.0, some material deficiencies should have been identified and ' corrected by previous MRs.
' ' Review of AP-0204, Revision 10, Safety Classification of. Systems, Components ' and Structures,.and the Safety Classification of Systems Manual (SCSM) showed-it to be comprehensive in scope and-used properly by plant personnel. Although - the' SCSM does not.have a great deal of detail the team determined the descrip- - tions;were adequate.
Conclusions . , Documentation to support the MR process is adequate, with na identified t strengths or weaknesses.in the program.
The program implementation was func-tioning well with much management involvement in the day-to day conduct of maintenance.
, 5. 3 Equipment Records and History r .Scgpe l This inspection area assessed equipment maintenance history.
Plant history . records, failure-analysis reports, and classification lists for safety-related components were considered for the following safety-related equipment: , HPSI Pump No. 1
_LPSI Pump No. 2
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- HPSI-Pump No. 3
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MC-MOV-301, 302, 309, 310, 318, 319, 325, 326- '
. Findings i Maintenance history records existed for all of the equipment from the date of installation (some dating back to 1960), except little attention was apparently paid to updating these records during 1964 - 1972 in cont'rast to before and after that time.
In addition, the history record cards were maintained in one-individual's office and referenced MR numbers (and often only dates) on micro-fiche at another location, so retrievability was cumberscre.
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! i i The failure analysis program used by the YNPS maintenance department is well
established (in effect since early 1984), controlled and administered by the mechanical maintenance supervisor. The team reviewed documentation and ! recommendations made by this program and found them adequate; however, no criteria exist for establishing which equipment failures receive a failure
analysis.
Rather, it is lef t to maintenance department management.
Further, . no formal mechanism existed to ensure that failure analysis recommendations ! which involve departments outside the maintenance department are actually
reviewed, undertaken, and completed.
Lack of root cause analysis is discussed
in paragraphs 3.5 of this report.
The I&C Department has an effective policy for controlling instrument surveill-ance records and history. The procedure DP-6001, Revision 11, I&C Department ' Equipment History Card / Loop Folder System, maintains corrective maintenance history, calibration records, and any information concerning the particular-instrument. The team reviewed the history card / loop folder-for the Main Cool- ' ant System pressure transmitters, pressurizer pressure'and water level trans-mitters, steam generator water level transmitters, and containment pressure-
transmitters.
This program provides the necessary information to determine ! whether the instrument or' equipment is exhibiting unreliable performance, so that preventative maintenance can be performed.
YNPS does not use or input to the NPRDS system due to the plant's unique design and inapplicability of much of the information in the system to YNPS compo-t nents. However, YNPS employs many components similar to those used by other nuclear plants. -YAEC engineers have access to NPRDS, if needed.
YNPS does use . .the Nuclear Network systems, as well as other communications channels acquire - information-from other utilities on relevant hardware-related issues.
No deficiencies were noted attributable to lack of industry information on equip-ment failures.
Conclusions ' The YNPS system for maintaining equipment history records is adequate, but record retrievability could be strengthened, as well as adding historical records not in equipment history cards, and formalization of the failure analysis program. Many of-these areas have been identified by the Plant License Renewal (PLR) program personnel and improvements are underway.
5.4 Conduct of Job Planni~ng i S.coge .The team observed maintenance activities to determine the adequacy of the planning function in providing MR implementation guidance in the areas of safety, coordination of activities, completeness of work packages, work sche-duling, special instructions, and radiation exposure controls.
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j Findings . Job plan _ning is done largely by the maintenance' job foreman, No special planning group exists in the maintenance department; however, during the out-t age, an outage coordinator is assigned to assist the entire YNPS staff in planning. The job foreman arranges for Radiation Work Permits (RWPs), parts l procurement, craf t personnel assignments and engineering support.
Observations-of job planning indicate that the process works well, with no evidence of poor ! [ planning on any maintenance jobs.
The ALARA reviews of MR packages were a j strength.
' YNPS recently implemented a program to control vendor technical information in ? response to Generic Letter 83-28 and NRC concerns in this ares.
The program,
[' which appears to be. unique to YNPS, incorporates relevant vendor. technical information directly into maintenance procedures.
Only those manuals which involve key safety related equipment are controlled.
Most vendor technical , manuals are uncontrolled at four satellite locations in the plant, with ! requirements for supervisory approval prior to their use. While no instances I of uncontrolled manuals in the field were noted, the adequacy of this system in ! the long-term should be confirmed.
Since this is still under review by the NRC- ! resident inspectors, the team did not pursue the issue further.
Conclusions Job planning.is documented adequately in MR work packages and procedures and is conducted very well. 'The team questioned tne technical manual controls program; however, no perform 6nce deficiencies were noted.
- 5.5 Work Prioritization . Scope t-This inspection area evaluated the maintenance work prioritization methods and criteria.
E Findings i YNPS maintenance management prioritizes work on the basis'of safety signifi- > cance (particularly Technical Specification controlled equipment) regulatory ! requirements, and plant availability.
Review of backlog indicated that main- .tenance management had devoted considerable effort prioritizing tasks based on . safety significance.
However, the only documentation of the prioritization . process _ that the team could identify was the list of outstanding MRs, a vague statement in AP-0205, Revision 14. Maintenance Request regarding the review.of MRs for impact of plant systems, and a prioritization system used to track and schedule the completion of Engineering Service Requests.
The maintenance manager stated that AP-0205 would be revised to strengthen this area.
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! ! . Conclusions { The work prioritization process works well, largely because of excellent . interdepartmental communications and cooperation, as well as ev1dence of a good safety perspective.
Documentation of_the program was minimal.
Formalization of this program may be useful should key management personnel leave or the volume of MRs. outstanding grow significantly.
5.6. Maintenance Work Scheduling
Scope This inspection area determineo if the maintenance scheduling system is esta- > L blished and functioning to ensure that work is performed in a safe and orderly [ manner,-consistent with importance to plant safety.
,,,, Findings-YNPS used a three day rolling schedule during the outage formulated by the plant maintenance department in conjunction with the outage coordinator. This ' was in addition to an overall -schedule prepared prior to the outage which- ~ detailed all significant. activities planned.- This roll'ng schedule was reviewed by all plant organizational groups and discussed during twice daily meetings with representatives of each department. The team often attended these meetings and found them.to be informative and evidence of strong inter-departmental cooperation.
However, the system appeared strained by the work-load in progress.
In addition, given the format of the schedule provided,-it was difficult for'the team to. determine what activities were ongoing at any given time and which jobs were of most significance without attending the-scheduling meeting.
The performance of the work scheduling system in the field appeared to be good.
' Schedule conflicts were either avoided by excellent interdepartmental communi-cations or readily resolved when they occurred. The Operations department did-a_ good job of keeping track of work and communicated to the field when concerns about system status arose. ALARA defined in the work package were effectively implemented in the field, and the HP department was noted to support the on-going activities.
YNPS daily outage work schedules provided a listing of work ~ to be done, but were not bar charted or controlled using a computer program.
- Conclusions The program for scheduling work activities was considered adequate, based largely on personnel performance and excellent interdepartmental communica-tions.
However improvements to tne work scheduling process and work schedules could make the system more functional to the user and to allow the system to l, handle the increasing number ~of MRs.
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Fs , o > h.& -5.7 Backlog Controls.
i , E Scope i1
This inspection area determined effectiveness of backlog controls and whether . the bases for deferrals of maintenance was adequate.
i .-. [ Findings t < ! , v.
The team found no evidence of a formal program to control the size of the i h maintenance work backlog or to document the bases for deferral of outstanding O MRs.
There were no formal administrative controls to. track and trend perform ~ l Lance in managing the work backlog. Management.did periodically' review the . , outstanding MRs. The only other method identified was a datasheet submitted .L to INP0 quarterly which details the number of outstanding work requests and the l L number open for less than three months.- This information did not appear to be ! E used by maintenance management, t is , i To evaluate maintenance management's performance the team reviewed the list of !
MRs outstanding, the data provided to INPO, and a sample of backlogged MRs' l l ' , [ having possible safety significance.
The. team noted that, while the backlog of ! MRs was increasing, it was not disproportionate to the number of MRs performed, o the size of-the maintenance staff. nor the increasing number of MRs being . written every year. Moreover, the percentage of MRs less than three months old " .is the same as it was at the start of the last. refueling-outage, indicating ' that the MR backlog is not, increasing in ' average age. - Of the backlogged MRs, p . all appeared to be prioritized properly by maintenance management.
No safety [ ~ significant maintenance work was lingering.
^ < , ., . Conclusions' t L i The' maintenance work backlog was being controlled, prioritized and was manage- , able inLsize. - Control's were not procedurialized and documented.
In addition, ! an" existing source of information regarding maintenance backlog performance was . not used.. Other backlog administrative controls seen elsewhere were absent.
l , h YNPS has a goal of establishing monitoring techniques for key aspects of the i ~ maintenance / program, such as backlog controls, in response to industry efforts
,. to improve maintenance performance. The team viewed this to be a positive ' . initiative.
' 5.8 Maintenance procedures p Scope . g . p
- This inspection. area assessed the development and approval process, technical
' content,= method of control, and the periodic review process for maintenance-procedures.
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, i Findings.
The_ team reviewed a random sample of maintenance procedures, as vell as those used on work ectivities observed. The procedures were found adequate for the task, technically correct, properly developed, authorized and controlled,
reviewed and updated in a timely manner, and contained appropriate cautions and ' warnings.
The team noted that the quality and layout of the most receMtly reviewed procedures was significantly better than that of older procedu;'es.
YNPS has a' goal to improve procedure quality and format and is using a new - procedure writers guide. The team viewed the format, technical content ! enhancements,'and human factors in the new procedures to be much improved.
> c Plant administrative procedures (APs) provide the framework for control.
Procedure AP-0205, Revision 14, Maintenance Request, is the principal procedure for identifying and conducting of maintenance activities. Modifications are separate.from maintenance and are controlled by AP-222, Revision 10, Job ' * . Orders.
The job order-procedure is used for Engineering Design Change Requests ' ' (EDCRs). AP-0040, Revision 10, Plant Inspection Program, AP-209, Revision 11, Inspections, and AP-216, Revision 5, Plant Housekeeping Program,-are used to identify housekeeping' deficiencies and maintenance related items. AP-17, Revision 16, Switching and_ Tagging, AP-207, Revision 8, Equipment Control, and AP-18 Revision 17 Temporary Change Control, control configuration and tempo-rary changes. -Testing is controlled by AP-218, Revision 11, Test Control, and AP-213 Revision 1. Post-Maintenance Testing. Administrative procedure AP-206, Revision 10, Non-conformance Report, is used to identify deficiencies during any phase of operation, maintenance, or modification activities. The maintenance (electrical and mechanical) and the I&C departments have additional procedures / instructions for surveillance schedules and preventative and corrective maintenance, j i Work activities in the field were adequately controlled and described in the maintenance procedures' observed, No noteworthy strengths were identified.
- Section.5.0 discusses several findings by the team relating to procedures.
' Conclusions Maintenance procedure development and control were adequate, as was implemen-tation of maintenance procedures.
' 5.9 Post-Maintenance Testing Scope' This inspection area determined the effectiveness of the post-maintenance testing program and whether testing criteria were established, documented, and implemented.' l L
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Findings The post-maintenance testing program is controlled by AP-0230.
Implementation of the program is the responsibility of maintenance department. AP-0230 delineates the post-maintenance test required.
Specific requirements outside this procedure are developed by maintenance support engineers.
If a piece of equipment fails a post-maintenance test and requires rework, a new MR is written using the existing MR number suffixed with the letter -A.
All reworks are reviewed by the maintenance manager and the total number is reported quarterly to senior management. The team noted that the rate of rework on MRs is significantly less than 1 percent, a very low value.
All post-mainten-ance' tests required by Operations, including satisfactory completion of the post-maintenance test, are delineated on the MR form and retained by the department until system conditions permit testing.
The method of tracking open post-maintenance tests by Operations is informal, but no deficiencies in the system were noted.
The team reviewed at least 10 post-maintenance testing requests for thorough-ness. All were found to be acceptable, although acceptance criteria were often limited and vague.
On August 8, 1990, the team witnessed a post-maintenance load test on the No. 3 EDG. The EDG failed by approximately 27 kw to meet the required 400 kw acceptance criteria for load.
YNPS and YAEC engineering were involved in the attempt to correct the deficiency which had not been resolved at the conclusion of the MTI inspection on August 10, 1990.
This issue is described further in Inspection Report 50-029/90-14.
Conclusions The post-maintenance testing program is documented adequately and is compre-hensive in scope.
Improvements could be made in the level of detail provided in the acceptance criteria.
Implementation of the program was good largely due to excellent interdepartmental communication and the high level of management attention devoted to the maintenance process.
5.10 Review of Completed Work Control Documents Scope This inspection area assessed the process for maintenance review of work documents, general completeness of work documents, and feedback from review of the maintenance process.
Findings The team reviewed the following closed work packages for completeness: 90-21, 90-36, 90-137, 90-523, 90-596, and 90-630.
All documentation was in order.
The work packages were reviewed by QSD, as required, prio'r to microfilming and storage.
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r , , YNPS did not have an effective program for walkdown inspections of completed - F work to ensure quality.
Section 6.0, identifies several deficiencies that should have been 1dentified by quality verification processes.
In addition, no ! formal mechanism exists for providing feedback to-work groups on completed ' documentation; however, communication between departments of problems.is good.
! j Conclusions L Documentation of completed work activities was adequate in all cases noted.- i e L Implementation of the documentation control program for maintenance work. i requests was functioning well, due to personnel performance and a high level of p ' management attention to closeout of MRs.
, t 6.0 Plant Maintenance Organization .; . Scope " .i This portion of the inspection determined the effectiveness and extent of
control exercised by the maintenance organization for: (a) maintenance acti- ! < vities; (b) contract maintenance personnel; (c) deficiency identification and l l control; (d) maintenance trending; and (e) support interfaces. The assessment
included review of maintenance controls (procedures and programs) and the ', implementation cf those. controls.
Inspectors observed maintenance in progress and reviewed documentation. The interface of plant and organizational depart-ments such as QA/QC and engineering with maintenance is discussed in the ' appropriate sections.
Findings , The Job Description and Plant Organization Manual, contains the Maintenance l Department organization chart and provides job descriptions for positions ' within the. department.
The Maintenance Manager reports to the Plant Superin-tendent.and is on the same. organizational level as the Administrative Manager,
Plant Operations Manager, and the Technical Director.
The Maintenance Manager , is supported by: the Maintenance Supervisor for electrical and mechanical
maintenance; the Supervisor for instrumentation and controls; and the Mainten-
- ance Support Supervisor for engineering maintenance support.
Control was . ' established properly and resulted in effective implementation of maintenance activities.
The material condition of the plant and equiprent, less the identified deficiencies, and the low incidence of equipment unavailability
support this finding. Programmatic guidance for control of maintenance was adequate.
The administrative procedure system controled maintenance identi-fication, maintenance requests, tagging, inspection, and housekeeping. The . procedure. system also included appropriate guidance for system and component safety classification, equipment control, and post-maintenance testing.
' Temporary change control procedures addressed controls for changes to proce- ' dures and equipment.
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Conclusions . The plant maintenance organization had adequate programmatic controls and was functioning well.
Lack of detail in some program areas was compensated for by the small experienced staff with few layers between workers and upper management.
, , 6.1 Cnntrol of Plant Maintenance Activities Scope The inspection objective was to assess control by mechanical, electrical, and I&C disciplines for performing maintenance.
6.1.1 Mechanical Maintenance .- ' Findings The tagout procedure for configuring plant systems prior to work was conducted deliberately and safely, with good material and monitoring controls.
Inde-pendent verification of completion of tagout work and initial line up and return to service of key plant systems was performed well.
No significant weaknesses were noted in documentation. Work performance was good, primarily due to the high level of experience and dedication of the crafts and good communication between the maintenance and operations depart-ments.
The quality of the work was reflected in the maintenance department's low (approximately 0.2%) rate of rework.
Material and configuration controls were good, with no discrepancies identified on drawings.
Conclusions Control of mechanical maintenance activities was acceptable with no identified strengths or weaknesses.
Implementation of the program was functioning well, primarily due to good interdepartmental communications and the quality of maintenance department personnel.
6.1.2 Electrical Maintenance Review of the open MR listing for this refueling outage indicated that MR classification as either " safety" or "non-safety" was conducted appropriately and met the requirements of the Safety Classification Manual and AP-0204, Revision 10, Safety Classification of Systems, Components and Structures.
The reactor operating mode for completion of the maintenance requests was deter-mined properly. The large number of work requests written on relatively minor work items provided evidence that the plant's practice was to require work requests down to a low level of significance for both safety and non-safety equipment.
The team identified as a strength that few blanket maintenance requests were used and that most maintenance requests were specific to an individual job.
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, Review of procedure OP-4506, Revision 12, Inspection of ECCS Circuit Breaker, identified a programmatic concern relating to supervisory oversight and
personnel control requirements for work on energized or potentially energized equipment..The procedure did not have a caution for connecting the Multi-amp L tester to the 480 volt panel. Although it was done correctly and a Safety i? Supervisor was present, the procedure did not specify when a safety supervisor
must' be present when working on electrical equipment.
The " Rules Governing
In-Plant Tagging Procedures - Local Control Rules," were very specific on F duties of the Safety Supervisor, but stated that, "When the nature of the work H requires it, a Safety Supervisor may be appointed by the man in charge of F work."~ AP-I7, Switching and Tagging of Plant Equipment, had provisions for [f writing in a name when a Safety Supervisor was assigned, but was silent on requirements.
The team talked with the Local Control Authority (LCA) and' [ training department personnel and reviewed the Safety Standards Manual, AP-207, Revision 8. Equipment Control, and electrical lesson plans and found no additional controls. QSD issued a D0R to resolve this concern.
' * , Conclusions Adequate program controls were_in place and implementation by the experienced electrical craft was good. Corrective meintenance requirements for electrics) equipment af ter a long full power run were minimal. and consisted mostly of routine surveillances and preventative maintenance. Non-availability of important electrical equipment was minimal as indicated by the last five , h quarterly reports to;INPO.
, 6.1. 3 _ Instrumentation and Controls The I&C Department is responsible for surveillance and maintenance' programs for instrumentation.. The surveillance program and its implementation is controlled primarily by specific,arocedures.
The maintenance program is con'. rolled by AP-6003, Revision 13, I&C Department Maintenance Program. All equipment and instruments maintained by the I&C Department are. listed in the I&C Department instrument identification log.
The team reviewed these procedt res to determine -.if the surveillance program is adequate and meets NRC requirements and licensee commitments.
Surveillance tests are established to meet Technical Specifications, Final h Safety Analysis Report (FSAR) and other commitments.
Observation of I&C main-tenance and surveillance activities indicated that I&C personnel are highly _ motivated, experienced, and disciplined.
The. team reviewed surveillance tests to ensure that calibration and functional tests on sensor channels and transmitters were performed properly, followed procedures, and documented adequately, and that post-maintenance testing was conducted. The procedures were specific for individual work to be performed, and work was performed by qualified and stable staffs that had good morale.
Multimeters (testers) were verified within set points traceable to national standards prior to performing calibrations.
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The team found a deficiency in the Instrument and Control (I&C) corrective program. AP-6007, Revision 7, I&C Department Corrective Maintenance, would allow I&C supervision to write'a corrective action procedure which could by-pass, jumper, remove terminal block plugs, or change switches on safety func-tions without requiring a.10 CFR 50.59 safety review or submission of the procedure to the Plant Operation Review Committee within 14 days for final-review. AP-6007 Prerequisites, step 6 stated that if jumpers or b'ypalising_ was , ! required, AP-0018, " Temporary Change Request," must be used. A footnote to the
step stated that AP-0018 was not required if APF-6007.1 (a corrective main-tenance form) was u ed.
The footnote exception circumvented the use of AP-0018'and its provision for a safety evaluation.
The Shift Supervisor did have ' a signature block on APF-6007.1, but the block was for acknowledging that he.
had been briefed on the work and the possibility of rendering safety. channels inoperative and not for a safety review.
During subsequent discussions, QSD personnel indicated that the-form and exception provision caused a required !,' safety review to be missed. QSD personnel cited an instance where a calibrated '" ' M&TE was substituted for a control room instrument to perform a surveillance . test. The licensee committed to revise the procedure and remove the note by j' October 31, 1990.
The team reviewed vendor technical manual controls and technical information updates.
Plant administrative procedures control the vendor technical informa-tion as required by Generic Letter 83-28, Item 2.2.2, Reactor Trip System (RTS)- Vendor Interface Program, which provides for transmittals of technical informa-tion to the plant.
Inspection indicated that vendor technical information was reviewed for effects on the plant maintenance and operations and acted upon in a timely manner to ensure proper maintenance. Where vendors have gone out of business or will not provide' requested information, sufficient attention is giving to equipment maintenance, replacement and repair history, to compensate.
I&C management personnel were involved closely during maintenance work to assure that work controls were implemented and that contractor personnel were adhering to-maintenance program requirements, Work areas, test equipment, tools, materials, and replacement parts were identified and arranged in accord- . ance with procedures.
Conclusions L The I&C maintenance organization had a well-developed and implemented program.
A strength of the organization is its highly trained and competent staff.
Careful selection'for specific personnel work assignments and good training programs assure plant I&C personnel are well qualified for performing their assignments.
Excellent dialogue existed between the I&C supervisor and the workers.
Effective leadership by supervisory personnel also contributed to . accomplishing maintenance goals.
The equipment history card program was also ' good.
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V , 6.2 Control'of Contracted Maintenance ' i Scope
, i This section assess,ed controls and implementation of controls for contractors.
, Findings.
Control of contracted services is exercised through procedures AP-0211, Revi- .i sion 17, Material.and Service Procurement Program, and AP-0212, Revision 17, l ' Control of Purchased Material, Equipment, and Services.
The methods of ' contracted service acceptance are through: technical verification of data; ^
inspection, surveillance, or audit; or review of objective evidence for l , conformance to procurement specifications.
Services are.normally procured from manufacturers or suppliers on the approved vendors list.
Procurements from i non-approved vendors require vendor audits,. surveys, surveillances or receipt , r inspection as determined by the QSD. The procedures also provide for the - acceptance of_ material or services through post-installation testing if necess-i ary.
For contracted services, the Material and Service Purchase Request provides engineering and technical specifications, drawings, codes,-regula- . ! tions, QA requirements, procedures, testing, inspection, and acceptance C requirements, y The team observed contractor controls on several jobs including steam-genera-tor eddy current testing by Zetec, inservice testing by Conam, check valve ' disassembly by Atlantic Valve Company, and fabrication of a new safety injec-l tion tank by Fisher.
The plant staff was involved closely with day to day
~~ direction, inspection, and oversight of contractor activities.
Contractor job; status was discussed during the planning and scheduling meetings.
Specific ' details-of contractor maintenance and isolated deficiencies are discussed in i l Section 5.0.
Atlantic Valve Company personnel were performing a disassembly and inspection _; of the LPSI check valves for material identification on interior bolts under i " maintenance request 88-1863.
AP-5010, Revision 8, Maintenance Department
Corrective Action, referenced the use of OP-5118, Revision 2 Threaded Fastener Torquing Procedure. Atlantic Valve Company personnel used a different, but technically adequate, torquing sequence for the eight bolt cap.
The procedure ' addressed a: standard symmetrical'eight bolt cap and did not address the "Velan"
- type bolting configuration. The licensee committed to a procedure revision to
! address nonstandard configurations by December 31, 1990.
Conclusions ,
- The-team concluded that both the program for contractor control and the actual implementation of the program to control contractors was functioning well.
Although the program did not contain detailed information'on how the mainten- , ance department interfaced with contractors; the small staff, station size, and good communications contributed to effective control.
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6.3 Deficiency Identification and Control System Scope The inspection assessed the deficiency identification process and its imple-mentation by plant personnel. The scope included both the station program and oversight by management and QSD.
The assessment was influenced strongly by the team's plant walkdowns and observation of maintenance in the field.
Findings Implementation of the deficiency. identification program was not adequate.
YNPS had several procedures to identify and correct deficiencies, including: AP-20, Revision 9, Industry Operating Experience; AP-40, Revision 10, Plant Inspection Program; AP-42, Revision 4, Housekeeping for Maintenance and Modifications; AP 205, Revision 14, Maintenance Request; AP-206, Revision 10, Non-conformance Report; AP-209, Revision 11, Inspections; and AP-216, Revision 5, Plant Housekeeping Program.
Procedures AP-205 and AP-206, did not provide controls for timely notification to the Shift Supervisor of a deficiency or nonconformance for the Shift Super-visor to perform an evaluation of operability and reportability.
Once deficiencies were identified (the maintenance work request written), the program control and implementation resulted in satisfactory completion and closeout. A majority of the following deficiencies should have had multiple opportunities for identification and correction during operation, maintenance, QSD involvement, and plant inspections and walkdowns.
The No. 1 emergency boiler feed pump (EBFP) motor had two out of four
bolts loose or bottomed in their holes such that there was 1/16 to 1/8 inch gaps between the bolt heads and motor feet.
The two deficient bolts were on the same side of the motor.
The pump and motor were installed by EDCR 79-16. Drawing D-1B113-1, " Auxiliary Feed Pump," did not indicate an attachment method between the motor and skid; however, the bolt type and sizing appeared adequate for the intended use.
The maintenance staff indicated that vibration readings had been normal and that the discrepancy was probably from the original installation.
The li'ensee initiated MR c 90-1527 and committed to correct the deficiency prior to plant startup.
Reinspection on August 7, 1990, found that new anchor bolts had been installed, thus, correcting the deficienc [t ~ , I !
, I h a-The bend diameter on one battery No. 3 intercell connector was 4.5 inches,
rather than the minimum of 5.75 inches required for the Okonite Company L ~4/0 UW-1 600 volt wire. This was identified previously by the Senior NRC ! resident inspector,_and the licensee had initiated MR 90-960 to correct a the_ deficiency. The licensee committed to complete MR 90-060 prior to startup.
!. The team identified several deficiencies with safety-related equipment in
L the containment including: misaligned Unistrut nuts on the junction box for FW-LT-1203; a mounting. bolt missing on SI-FT-3 and a misaligned Un-e istrut nut on its junction box; a _ mounting bolt missing on SI-FT-2 trans- > mitter to bracket and a mounting bolt missing.on the transmitter mounting plate-to wall _Vnistrut; and a pulled out Sealtite conduit and loose mineral insulated cable connection on CS-MOV-537.
The licensee initiated MRs to correct the deficiencies; however, on August 9, 1990, reinspection determined the MR had overlooked the SI-FT-2 missing mounting bolt for the bracket to transmitter. Missing bolts were then found on two other flow transmitters, highlighting a need to improve deficiency identification and quality verification processes, including training. A new MR was written to correct these conditions.
One of five bolts was missing on one air intake box to blower attachment-
on No. 1 EDG. One of five bolts was missing on both air intake boxes to blower attachments on No. 3 EDG.
EDG No. I was missing a lateral hanger on the conduit carrying all control power to the diesel. Junction boxes ' . for the circulating oil heating pumps were missing screws on all three diesels.
(Diesel maintenance is performed by a contractor).
The licensee initiated MRs 90-1474, 90-1475, and 90-1529.
Reinspection on August 7, 1990, verified that these deficiencies had been corrected.
MC-PT-300 in the vapor containment had a loose Rosemont cap.
The trans-
mitter is classified as safety _related and is environmentally qualified.
The licensee initiated a reportability review in accordance with AP-0008, Revision 4 Event Reportability Evaluation Process, and found the deft-ciency to be non-reportable.
Nonconformance report 90-020 was issued to verify that_ all covers are torqued prior to startup.
The "0" ring had been replaced and the cover torqued without a MR. A new MR was issued immediately to rework and document the maintenance action.
The team considered the action an isolated case in view of the licensee's practice of writing work requests for even minor non-safety-related work.
Re-inspection on August 7, 1990, found that a MR was issued to verify the torque of all transmitter covers before restart.
One bearing water line flange on the No. I high pressure safety injection
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(HPSI) pump was misaligned (offset) by about 1/8 of one inch.
In addi-tion, gasket material on similar HPSI pump flanges were of three different thicknesses. The licensee initiated MR 90-1523. On' August 9, 1990, the maintenance manager stated that corrective action was being studied and the_ final solution was pending.
The team considered the action i appropriate.
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y-C: > < ' Several examples of bare cut leads and terminals were identified behind
the main control room panels.
The licensee initiated MR 90-1510.to
fnspect the panels and correct the deficiencies.
, I Other materia 1' deficiencies of lesser significance were turned over to the
licensee for evaluation and correction including: missing screws in power lighting and power panel covers, broken strands on multi-strand wire, and packing leaks, j s Blister (penetration) terminal enclosure 7E was found to have several defici- ' encies. The enclosures housing safety-related environmentally qualified - terminal boards were not treated-as important to safety resulting in a lack of
'... -configuration control. The right hand terminal board in the enclosure below . the conduit IT-462 showed corrosion stains.
The cable from conduit IT-462 had ! ' evidence of liquid running down the cable and dripping onto the Weidmuller , , L terminal blocks..One. unused conduit entry into the top of the enclosure was ' plugged with duct seal.
The enclosure had holes drilled through one side panel.
Cables were run through the bottom of the enclosure without cable ! protectors and sealed with duct seal. The enclosure showed evidence of degraded sealing surfaces between the covers and panel.
Duct seal had been
used to seal covers on the panel.
The maintenance staff indicated that duct , seal was added because moisture intrusion was a continuing problem and that
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other penetration enclosures had similar problems.
Subsequent inspection on - August 9,1990, found that the blister enclosures inside the VC had been re-
worked and the duct seal removed.
The blister enclosures outside the VC re- ' ' mained to be reworked.
The duct seal used on the cable penetrations and in the > conduit hole had no engineering approval for acceptability for this applica-tion. The maintenance manager stated that YAEC engineering was preparing , information on use of duct seal material.
The terminal blocks had minor mineral deposits from the cable and conduit run.
.The lack of. sealing combined with the lack of periodic inspection requirements for dust, foreign matter, damage, and adequacy of terminations could allow the condition of the enclosed terminal block to degrade over time.- Reinspection in_ ' the VC on August 9, 1990, showed that the 7E blister box terminal block had , been cleaned; however, lumber had been stacked within several inches of its terminal strips creating a potential for damage.
. The management stated that ths ! recognized the problems with the blister boxes and planned to repair th-asket sealing surfaces and possibly modify the covers to convert them to hinged covers.
The conditions, however, were , apparently not documented using formal methods such as a maintenance request, modification request, or non-conformance report. Also, YNPS does not have a periodic inspection program for blister box terminals. The licensee issued maintenance requests to correct the blister enclosures which contain EQ cabling and terminal blocks prior to plant startup and to revise the design drawings to reflect specifications for gaskets and the as built configuration.
This is identified as. Unresolved Item 50-029/90-81-01, Inadequate Configuration Control of Vapor Containment Penetration Enclosures, b !
t _ .
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, Conclusions.
Deficiency identification and control was not adequate to identify and correct
- all deficiencies important to safety.
Programmatic guidance was in place and
implementation.should have resulted in multiple opportunities to identify and _ ' correct a majority of the deficiencies.
Supervisors and managers spent a-lot of time in the plant; but, the threshold level for deficiency identification was apparently too high, and the attention given to details was too low.
The
YNPS quality verification processes were not performing at a broad enough or '
detailed enough threshold to identify all deficiencies.
6.4. Maintenance Trending.
Scope
c This section inspected selected repeat failures and the trending perfor:1ed and.. documented.
Findings
The maintenance trending program.was in the process of being upgraded and documented.. YAEC performance goals included a maintenance department goal to improve the predictive maintenance program by formalizing the vibration moni-a 'toring program (June 1990), formalizing the lubricating oil analysis program (November 1990), and developing a-thermography program (1991).
Trending was , *' . being performed on battery intercell resistances, diesel oil, station voltage-re.gulators, erosion / corrosion, and thermography in addition to the documented ! -Intervice Testing (IST) program.
Failure analysis was performed on selected components;.however, no formal program was in place to describe the activity.
The station had a draf t. root cause analysis procedure (AP-232) planned .. for implementation in September or October '1990.
Root cause analysis, except i for selected failure analyses, had been informal.
Conclusions
The maintenance trending program was not described adequately (a currert weak-ness); however, adequate trending was being conducted using informal methods.
6.5 Support Interfaces Scope Th.is section, observed relationships between the maintenance organization and support organizations.
Findings Interdepartment cooperation and support function well, attributable to the
.small size of the organization and the low personnel turnover rate.
The organization works as a team and most plant meetings involve representatives - , -um-m m
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'from all departments.
The Maintenance Support Department (MSD)-does ~not have a , formalEprogram to describe their interface with the Maintenance Department.
Additionally, the program did not describe the ' responsibility / interface between the Maintenance Support department and corporate engineering, The~1ack of a formal program did not appear to hamper effective communication and support.
Conclusions
' Support interfaces functioned well to support maintenance activities, though interface responsibilities for the Maintenance Support Department were not defined formally.
, ' 7.0 Maintenance Facilities, Equipment and Materials Controls-Scope ....
, This inspection assessed the maintenance facilities and controls over mainten-ance equipment through plant walkdowns, document reviews, and interviews conducted with supervisors and personnel in the following areas: nuclear-maintenance (mechanical, electrical and instrument and controls); planning and.
-support; design engineering; nuclear training; and quality assurance. Observa-tions of plant operations and interviews with the craft personnel were i conducted. The following areas were evaluated: t Maintenance Facilities and Equipment;
Materials Controls;
. Maintenance Tool.and Equipment Control; and=
Control and Calibration of Meter and Test Equipment;
' Findings The buildings are relatively compact, which enhances communications between the departments; but, in turn, limits expansion. One long term goal is to provide an improved, centralized area for.the maintenance department. A second level was added.in the clean maintenance shop.
Even so, the space available for shops, laydown, and maintenance was cramped. Control of procurement, storage l and issuance of spare parts, and equipment and' material was both well proce-
- duralized and implemented.
Purchase requests were reviewed at four levels prior to being sent out and equipment was subject to a thorough receipt inspection.
The maintenance department does not have a tool control procedure.
There is a requirement for tool control in zone III work areas in procedure AP-0042, Housekeeping for Maintenance and Modifications.
Procedures require annual l inspection of slings, hoists, safety belts, and other tools related to safety.
Inventories are performed annually for hand and power tools.
In both cases, if ' the tool couldn't be found, it was simply replaced.
' l i - - - - - - -
w.. U c s E o ,$ 48.
,
Control of M&TE is delegated to the different departments, The Instrument-and Controls'(I&C) section had an effective procedure and review of the cabinets' ' and records indicated effective I&C equipment control. The mechanical main-tenance M&TE program procedure did not cover many actual or required practices.
.Use of equipment following expiration of the calibration period indicated that .the mechanical maintenance section did not always control its equipment properly.
Conclusions Progress is being made to provide more space in the maintenance shop; however, the-shops were cramped, with little space for laydown.
Material control to the point of issuance was-functioning well.
YNPS did not have a procedure for a
tool control; program and the program to control tools is limited.
The control of the mechanical section M&TE was found to be inadequate in contrast to the effective control of I&C M&TE.
YNPS took responsive, corrective action to - revise and issue an improved mechanical maintenance section M&TE procedure , before the conclusion of the inspection.
7.1 Maintenance Facilities and Equipment [ Scope' ., Through interviews with personnel and tours of the plant, offices and shops, this element determined the extent ~to which the plant facilities and equipment ' enhance the maintenance process.
Findings Maintenance equipment appeared to be adequate for the job and suitably main-tained. No strengths or deficiencies in this area were noted.
Separate facilities are provided for the I&C section and mechanical and elec-- trical.(maintenance)'section shops and work spaces.
Addition of the second floor in the mechanical.maintenace area has allowed the separating of welding from~the lathes and power tools, separate documentation and M&TE rooms on the lower floor, a large tool crib, and workbenches and a work area away from the machinery and welding.
The maintenance section hot shop was spacious compared to the clean shop. The space was not adequate for all jobs as a large area outside of the shop's garage door was roped.off as a radiation area to provide more room to work.
i Hot shop housekeeping was-poor, based upon inspection on two different days.
. There was trash and metal filings on the floor around and under tool boxes and machinery and'the lathe wells had not-been cleaned out.
Large tools and parts were left on the floor.
The shop was unmanned during both inspections, although personnel started cleaning during the second ins'ection.
p Neither mechanical shop provides a large work area to move in large equipment for laydown or maintenance.
The loading dock in the turbine building and the a
' - y ..: g (:. . L F14-
yard outside the pump house were being used for the laydown and maintenance of large pumps and other equipment.
I All organizations in the plant are in close proximity to each other.
The ~ storeroom, warehouse, health physics, and the control point are located down .the hall from the clean maintenance shop. The hot shop is two doors down from " the control point with a decontamination room in between with a window to pass through tools in need of decontamination.
The Maintenance Manager, Maintenance Supervisor and Health and Safety Supervisor are located on.the second floor over the storeroom. With the second floor addition, the mechanical and elec-trical foremen were relocated to a trailer just outside of the clean mainten-t ante shop. All of I&C and Quality Services are located in a building next door. Technical Services is located on site.in a trailer.
The close proximity of the different departments promoted communications.
. Training for maintenance-in progress is available and appears to work well.
Mockup training was scheduled for plugging tubes in the steam generator the day before the actual plugging took place. Mockup training helps the job run more smoothly and minimizes exposure to radiation.
The facility owns a limited . number.of mockups, but has access to mockups at other Yankee sites.
The i planned control room simulator has the potential to be a valuable mockup for the I&C' department.
Conclusions ' Even with the addition'of a second floor in the clean maintenance shop, the [ . maintenance shops were cramped with little space for laydown.
This modifica-I tion:also moved the foreman out of the shop where he.could directly observe l maintenance:and into a trailer. Management and the different support organi-
zations are located in close proximity to the shops.
j
7.2 Material Controls l f-Scope ! .This element rated material controls and support of the maintenance process.
Areas inspected included warehouse activities and material storage areas in the l plant, as well as procedures which govern these activities.
i <
Findings l t . Policies and Procedures have been established for procurement, storage, and ' issuance of materials.
The procurement process was revised recently to include a revised Material and Service Purchase-Request, which has helped to shorten i the procurement process, h f An-inventory of safety-related parts is maintained in a computer database, During normal operations, safety-related parts and materials issued through ! i stores are uploaded into the database, and a printout of items in short supply is run weekly.
Entries are made and printouts are run daily during an outage.
i ! > -
, .,;
- ,;
, i _@-
, Purchase Requests are researched and generated for all items identified as being in shirt supply.
The.YAEC ' Approved Vendor List and 1990 Vendor Commer-. , cial Grade Audit Reports are used to identify qualified manufacturers. Draft-
requests are sent to the maintenance department and then to the Quality Assur- .ance and engineering departments.in Bolton, MA for review and approval. These reviews assure that materials and parts are acceptable for safety related application before the. purchase requisition is sent out.
The computer' database also provides information on items with a shelf life.
The department's goal is to, expedite preventive maintenance on equipment in storage by programming the s computer to provide a listing of the maintenance needed by date.
Incoming parts are marked with a hold tag and subjected to detailed receipt i inspection to insure the parts were not damaged in shipment and that require-ments on the purchase request were fulfilled.
Safety-related equipment and
parts are then referred to the' cognizant department to complete the technical
and documentation portions of the inspection.
Both the procurement process and' '" ' -the' receipt inspection process are well documented. The team reviewed two folders. independently and reviewed a third together with the receipt team.
No problems were found; the three files sampled were neat and traceable.
All stores, spare parts, and excess material (old parts, unused furniture, etc.) are stored in the storeroom or warehouse.
Interviews with the supervisor
of= stores determined that:both the number of personnel _in the stores department . and the amount of warehouse space have grown significantly with demand in the ! - past few years,.but space still appeared tight during this outage. A cage is
set aside'to separate material and equipment awaiting receipt inspection from j equipment ready for issue.
However, larger equipment and-boxes will not fit in
the designated space and are stored in the warehouse separated from other i materials.
Safety and non-safety-related equipment are segregated by storage on separate sides of the room. Aisles and shelves containing the equipment are well marked and roped off to control access. A separate safety-related equip-ment cage is maintained for pump and other equipment. spares.
-The storage system facilitated finding equipment for both storekeepers and mechanics.
Maintenance personnel were provided a training course on how to use i the stores inventory system to prevent delays due to mislabeling of an item in , stock or different terminology.. Control of the space is maintained using a locking access door and a service window.
All other entrances are locked or watched and the warehouse is manned.
Conclusions Material controls effectively support the maintenance process by insuring that the waiting period for parts is as short as possible, that quality safety-related parts are ordered, and that each safety-related part is inspected prior to issuance. The computerized inventory program is a valuable aid. Major strengths include reviews by-stores, maintenance, engineering, and QA before a purchase request goes out, detailed receipt inspection, and cooperation and communication between departments.
,
" ... I f i,
7.3 ' Establishment of Maintenance Tool and Equipment Control Scope-This element determined the extent to which tool and equipment control has-been documented and implemented and to assess its support of the maintenance process. This area was evaluated through interviews with personnel', review of-documentation, and observation of work and storage areas.
Findings , There is no single program covering tool control.
Procedure AP-0042, Revision 4, Housekeeping for Maintenance and Modifications, establishes tool control in zone III work areas. A July 1990 revision of AP-0042 modified the procedure . to include a sign in for all tools entering zone III areas.
Prior to this - change, a final inspection of the area was used to insure that all tools were ~' ' removed. One of the maintenance department's goals is to include the ident-ification of tools and materials in at least fifty percent of the department procedures in 1990. There are separate procedures to control the inspection of some tools, but none for others.
The mechanics and technicians maintain their own tool boxes for hand tools.
Larger tools are stored in a tool crib in the clean maintenance shop that is manned during outages. A log is used to allow tracking of tools during normal and outage operations. Tool-boxes and the tool crib are inventoried once a year to identify missing or damaged tools.
No log or tool crib is maintained in the hot maintenance shop.
- Electric hand tools, slings, and hoists are inspected / inventoried annually and safety belts, quarterly. The procedures requiring annual inspections for hoists and slings, DP-5950, Revision 9, Periodic Inspection of Slings, and DP-4508, Revision 8, Annual Hoist Inspection and Load Test, were reviewed.
Load tests are not' required by either of the procedures, despite the title of the latter. The team examined the most recent inspection sheets for hand tools, slings and hoists. Two recent hoist inspections were approximately seventeen months apart and a number of slings were not included in the past two inspections.
Items identified to be deleted -in a 1989 inspection were never
- deleted from the tool list and were lef t blank (uninspected) in the-1990
._i n specti on. An interview with a licensee representative indicated that these inspections were not given high priority.
The uninspected hoists and slings 'could have been in an unidentified location, been disposed of, or removed by contractors.
The team observed that the licensee had performed magnetic particle inspec-tions on the crane hooks both in the plant and on the mobile cranes used throughout the site according to procedure YA-CH-1, Revision 1, Examination of Crane Hooks and Other lif ting Fixtures.
The inspections were performed prior to the outage.
The lifting fixture for the reactor pressure vessel head was magnetic particle inspected in accordance with procedure YA-MP-111, Revision 2, Procedure for Magnetic Particle Examination of the Reactor Vessel Fixture.
l .
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~52
i-Conclusions > s m YNPS has ailimited tool control program. Generally, items such as slings, . straps and other lifting devices were listed on a log and some effort was made + s to test-these-items annually.
Not all items were tested as required, and those that were tested were done as time permitted.
Items not readily located were . left on the~ log, but with no indication of their status.
Larger, specialized equipment, such as crane hooks and the reactor pressure vessel lif ting fixture, are inspected before use (prior to a refueling outage) in conformance with good safety practices. Adequate tools and equipment were available to support the maintenance process at YNPS.
7.4 Control and Calibration of Measuring and Test Equipment (M&TE) Scope - This inspection determined, through discussions with personnel, inspection of instruments and instrument storage area, and.a review of records, the extent to which M&TE is controlled and calibrated. . Findings The team reviewed procedures: AP-0215,. Control of M&TE; AP-5004, Control of Maintenance Department M&TE; and AP-6002, Control of Instrument and Control (I&C) Department M&TE.
Procedure AP-5004 was not in accordance with AP-0215 as ' it did not address several areas required by AP-0215 or actual practices.
For L example, AP-5004 does not provide for changing the specified interval of cali-bration as required by AP-0215, section II, part D, paragraph 3.
Procedure AP-5004. states that calibration outside the plant will be according to the manufacturer's specifications; however, the manufacturer recommended biannual calibration-of YAEC No. 3488 was changed to annual, without supporting-evaluation.
The I&C section's M&TE program was found to be effective.
The I&C procedure covers all areas required by AP-0215 and reflects actual practices. The team found two pieces of equipment with out of date calibration stickers; however, documentation supported a change in frequency for lack of use. All records for the equipment.were easily traceable, and a computer program was used to ident-ify equipment due for calibration. The equipment is stored in cabinets in the room where the technicians work and must be logged out before use.
The cabi-nets are unlocked while the space is manned and locked during other times.
' Deficiencies were found in the maintenance section's M&TE program.
The M&TE room is locked and the key is controlled according to a list of people author-ized to check out the key and equipment. A read and sign sheet was written before the -outage to familiarize those with access of the requirements for using M&TE equipment.
The M&TE room has a ground floor w' indow that was stand-ing open, providing potential for unauthorized access to the M&TE room. When-informed, the licensee permanently secured the window.
- - . -. . -
m
_, iw .
A log is maintained to track tools that are signed out. 'The team found six ~ tools (YAEC Nos. 3488, 549D, 533, 4020, 2203, and 2177) with expired calibra-tion stickers.
The log indicated that two of these tools (YAEC Nos. 3488 and i 4020) had been checked out and used on six safety-related jobs after the cali-bration period expired. QC Deficiency Report No. 90-01 indicated that a simi- .lar situation was found in February 1990, when M&TE was checked out without .i verifying that it was in calibration.
When inform'd, YNPS investig'ated the six jobs and found that, while the jobs were safety-related, the tasks for which the tools were used were not.
The next day, the tools had new calibration tags i in accordance with the practice of allowing extension of the calibration inter-val for tools with little use during the initial calibration period. One tool , ,six months past its calibration date was said to be lost, but appeared later in the same day with a new sticker extending the calibration.
The practice of granting temporary extensions to the calibration interval is
.not covered by procedure and consists of reviewing the usage log, granting an '" ' extension due to lack of use, and changing the calibration sticker.
The basis 'I for extending the intervals in these cases, and more generally, was not evi-- dent. Also, the authority to replace the calibration tags was with the MT&E supervisor.
When a tool is found out of calibration, the procedure (AP-0215) requires that each work-order affected should be redone or a determination made to ensure that the tool did not effect the equipment and to document the outcome. There was no documentation-indicating that this was done.
The log sheet for the affected M&TE equipment was inserted into the recordbook with a statement that all systems or equipment listed on the log for the out-of-calibration M&TE were examined and.found to be functioning correctly.
The above findinos were discussed with the. Maintenance Manager, who committed to resolve these findings and revise the procedure by the eid of October 1990.
The team reinspected the mechanical maintenance M&TE progra'n from August 6-10, 1990, and found that the revised procedure was issued on Atgust 7, 1990, with a number of. improvements. The data base was completely reaone and included provisions to track history. A monthly review of equipment is now required.
The equipment log was revised to require that the calibration due date be listed. Training is being given on the-revised program to improve user under - u " standing of the purpose of documenting M&TE usage.
The licensee's representa- .tive stated that the revised log and training should preclude personnel check-
ing out M&TE equipment overdue for calibration.
Monthly, instead of quarterly, review of equipment should insure calibration at the specified frequency. A file was set up on each piece of equipment as required by AP-5004, and the new ' log was in place and being followed.
Conclusions Control of mechanical M&TE was found to have several deficiencies in contrast to the I&C M&TE, which was controlled well.
Prompt corrective action already taken to revise-the mechanical M&TE procedure AP-5004, Revision 9, should t !
p 6..: " g D w (
' i provide acceptable future control-for mechanical M&TE.
The mechanical main- ' tenance; department has initiated implementation of the-revised program includ- .ing training of users.
8.0 _ Personnel Control Scope - - Tne inspection' determined the extent to which personnel are trained and quali-fied to-perform maintenance activities.
The team examined the current status of the.following four areas: staffing control, training, testing and=quali = fication, and current status.
Evaluations are based on interviews, direct observations at the training facilities, observation of field activities, and reviews of documents and records.
Findings Organization charts were readily available an'd up-to-date.
The hiring and ' promotion policy is implemented as stated by the licensee's program. The-personnel' turnover rate is extremely low (one percent).
Two shifts per day are used to_ cover the refueling outage, and the departments revert to day shift p when normal operations resume.
There is not a large backlog of work and_the ( average yearly overtime'per person is approximately 50 hours. The team-concluded that the maintenance department is well staffed.
~ c
, The training program is INPO accredited. Maintenance training has greatly , i . improved in the last four years.
Prior to 1987, a formal program did not i _ exist.
Yearly training includes General Employee Training and a minimum of two- ] weeks of: classroom training.
In addition, manufacturer training on different.
equipment and offsite schools-are provided. On-the-job training (0JT) is run by'the maintenance program:and takes place as needed.
Documentation of train-
- !
, ing.is: thorough. -Qualification of personnel is completed through a documented
testing program and satisfactory observation of job performance.
-l < l Conclusions .The maintenance department.is well staffed with qualified people. The turnover i rate is extremely low, reflecting a stable environment. The-training is INPO accredited, is effective, and uses a variety of training methods.
8.1 Staffing Control ! > g Scope.
i This element evaluated, through interviews with personnel and observation in the' field, the extent that personnel control is proceduralized and implemented a into_the maintenance process. !, , y - p e V ~
,; , Findings Management in the maintenance department was recently expanued to add three more foremen to improve the work load distribution.
The-small size of the - maintenance. department involves all of management in planning and completion of day to_ day work.
The maintenance department's around-the-clock coverage during outages-is coordinated closely through the daily planning and scheduling meetings. - All maintenance workers are-on call for emergency maintenance when - off shift.
The different craf ts (mechanical, electrical and I&C) are defined and work well together.
This was observed at numerous daily meetings held by e the Plant Maintenance Manager, plant management, and by field observations by the team.
Communication between the different departments was very good.
A' turnover minimization policy is not presently required.
Conclusions - Staffing control for the maintenance department is working well due to its small size, good' communications between the work groups and management's close involvement in day to-day planning and operations.
Organization charts and job , descriptions define the organization and responsibilities.
The limited backlog of work and minimumal overtime indicate good staffing.
Shifts are well covered and well controlled.
8.2 Provide Personnel Training.
' Scope This inspection area determined the extent that training is implemented and documented, including effectiveness feedback in-the maintenance process.
Findings ' Training for maintenance department personnel prior to 1987 consisted of modified operations department systems lectures and General Employee Training-(GET). A formal. program commenced in 1987.
GET and Plant Systems training are , the first courses required. After these are completed, lectures are given as " requested by maintenance department management to introduce new equipment or revised procedures or as the need.is seen by the instructor. Offsite training at different manufacturers for pumps and valves, manufacturer training onsite ! and the use of video cameras in the plant are some examples.
, On-the-job training for maintenance was divided into three sections (initial, continuing and outage on-the-job certification guides). Qualification sheets were created to identify-qualified people for jobs or people in need of train-ing, and a training program was devised for more experienced personnel to train the unqualified.
i The feedback program in the training department was functioning well.
Not only did. students supply feedback at the conclusion of courses, but at anytime in any form. All feedback is tracked, reviewed by management and a written reply r.
-.
- , - {_ /w-p: ;3 !
1 ~ -is forwarded to-the initiator to indicate what action was or will be taken.
Instructors-spend a minimum of one month per year in the plant assisting the maintenance department and observing maintenance to improve lectures.
The instructors also evaluate on-the-job training to insure that the program is- ' functioning effectively.
Conclusion The training program is complete, well documented, and well implemented.
The on-the-job training program, the feedback program, and the instructor's' time in-the plant are several of the strengths.
< 8.3' Establish Test and Qualification process ' Scope - This element evaluated, through interviews with personnel, tour of the training facility, and review of procedures and documentation, the extent to which , testing and qualification of maintenance personnel is integrated into the , maintenance process.
Findings The test format is being changed-to resemble the format approved by-the NRC.
All test questions are based on objectives in the lesson plans. A test question bank exists and is being expanded constantly.
The on-the-job training program is used to qualify personnel in the field.
The .j tra_ining program instructs new personnel in General Employee Training (GET) and ~ plant-systems to qualify them to be in the plant. and qualifies trainers for , -on-the-job' training.
Further qualification of personnel through on-the-job ' training is.the responsibility of the maintenance department.
The training department does' assign people to evaluate on-the-job training to provide input to future-on-the-job training lectures and to the maintenance department.
The training history for personnel is well documented in a computer database.
These records identify all classes an employee attends and the grade received.
The completion of on-the-job training is documented by the maintenance department.- - - Conclusions- ' The test and qualification process is well documented and implemented.
The testing format is similar to that approved by the NRC.
personnel qualifica-tions are documented and traceable.through computer records and the maintenance department-on-the-job training record k,
57 '
, 8.4-Assess the Current Personnel Control Status Scope-This element inspected and rated personnel status in the areas of testing and j qualification, drug problems, work performance by unqualified personnel, and q ~ turnover rate. This area was evaluated through interviews with per'sonnel and a ' review of procedures-and documentation.
Findings i Responsibilities for implementation of the policy on Fitness for Duty is clearly defined.
Disciplinary e.ction for violation of the policy is based on ! severity and can ' lead to termination of employment. Both contractors and new i employees are given drug screening prior to being granted unescorted access:to l the site. Access is not granted (escorted or unescorted) if the person is not i "" ' willing to complete the screening.
! -
- l The plant employee turnover rate for the last year was one percent.
Since l 1988,-the maintenance department turnover is about sixteen percent; three-j personnel transferred within Yankee, one retired and one left the company.
l Personnel have an average of 9.2 years of experience-in trade and 6.2. years at i YNPS.
i i The newly revised on-the-job training program prevents work from being l completed by unqualified personnel. A list of all tasks personnel are quali - j fied to perform is available to the foremen to aid in scheduling work.
1 Conclusions , s The licensee has a stable experienced maintenance work force. 'The turnover . rate is quite low and includes personnel transferred within the company.
The i licensee has implemented a successfully fitness for duty program.
l ! ! !
i ! J
(. RJ ; c ' c . ? , , s '! APPENDIX l' . INDIVIDUALS CONTACTED ! Yankee Atomic Electric Company i .- u a-G. Babineau, Radiation Protection Manager E. Begiebing, Maintenance Manager
E. Bolognani, Engineering Assistant j . a L. Bozek, Quality Assurance Supervisor i J. Chapman, Safety Assessment Manager ' ab C. Clark, Manager, Training
B.~ Darcy, Instrument and Control Supervisor R. Dobosz, Stores Supervisor J. Falconieri, Maintenance Engineer N. Fetherston, Maintenance Engineer S. Fournier, Lead Systems Engineer i K. Ghahramani, Senior Engineer ! R. Grove, Instrument and Control Foreman i M. Hedges, Chemistry Supervisor
ab 'T. Henderson, Acting Plant Super;ntendent W K. Howe, Electrical Maintenance Foreman .l S.' Hudson,iEngineering Assistant-C. Johnson, Senior Instrument and Control Foreman a W. Jones, Engineering Manager, YNPS D. Joyce,' Shift Supervisor l ab =K. Jurentkuff, Plant Operations Manager ll ab.
J. Kay, Technical Services Manager y C, Keating, Senior Maintenance Foreman
D.' King, Supervisor Technical Support i C. Larson, Nondestructive Examiner, Level III-l .S. Litchfield, Health and Safety-Supervisor S R', Mayhugh, Maintenance Engineer ~ ' J. McCumber,-Engineering Manager.
a' -G. Mcdonald, Quality Assurance Manager H. McKenney, Shift Technical Advisor i ab R. Mellor, Technical Director i ab: R. Mitchell, Maintenance Manager i K. Prilipp, Technical Assistant
J. Pruitt, Instrument and Control Instructor j ab N. St. Laurent, Acting Manager of Operations M. Schaefer, Quality Control Inspector ab T. Smith, Maintenance and Technical Training Supervisor ! 'a J. Thayer, Project G aye.- YNSD
S. Valk, Nondestructive Exai3ner, Level III S. Warner, Administrative Supervisor
.. J. Williams, Training Instructor a-B. Wood, Administration Manager ' t.
D. Yorke,-Electrical Foreman A..Zander, Mechanical Instructor s.,. - m c..,wy 7 mer; , , ... , ,, , , ,.,, Mmjn ' x '+ > .ls pps3 p*u; _ s:- - > , , , , y, -47 . 1- . i s m .>e Jd s t.
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a': 4Atte'n' ed Exit Meeting held on: July ~ 20,_:1990' ! d i.b J ' Attended Final 1 Exit.Meetingnheid.on. August:10, 1990' l
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_ -APPENDIX 2 SUMMARY OF WEAKNESSES Weakness - A potential problem or condition presented to.the licensee for evaluation.and corrective action as' appropriate.
' ~ .A2.1 - There was no formal program for self assessment of the maintenance process other than periodic type QA audits.
Reference paragraph 2.2 A2.2 -- There was no formal backlog program. Reference paragraph 5.7-A2.3 - The plant is developing a root cause analysis procedure, however, ,. . failure to have this procedure in place was viewed as a weakness.
'- Reference paragraphs 3.5 and 5.3 "" , A2.4 -- The licensee's deficiency identification process was functioning less than adequately.
Reference paragraph 6.3 l 'A2.5 - The team found that the licensee's trending program was in the process of being upgraded, however, at the time it was not adequately-described.
Reference paragraph 6.4 .] A2.6 - YNPS walkdown inspections lacked attention to facility and equipment
' detail.
Reference paragraph 1.2 and 6.3 l A2.7 - Several observations of deficiencies by the team indicated that I deficiency identification and reporting by the Quality Services-Department was weak.
Reference paragraphs 4.4 and 6.3 A2.8 - The team noted that while the YNPS-system of maintaining equipment-history cards was adequate this method could be strengthened by
improving retrievability, and including the historical records which ' are not on the cards.
Reference paragraph 5.3 -!' A2.9 - .The mechanical maintenance and test equipment had deficiencies in-control of equipment. While a new procedure is already issued, some i time will be required to assess implementation.
Reference paragraph
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. . .. i > < SUMMARY OF-UNRESOLVED ITEMS-- - > ' ..,- , ru , , ,,
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-:. ';jl ' . /U'nresolved, items are matters about'which more information' is required inf order / , , s4
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- Unresolved itemslidentified during: this _ inspection-are listed -below:.
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- Item No.-150-029/90-81-01~
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- Th'e.licenseeicommitted to revise:the design drawings to reflect; specifications:
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~ ' ._ -enclosures that'contain environmentally qualified cables-and_ terminal blocks, ! > > . _. > . , < s, - LReference--Section 6.0 mi.
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,... , M' ..- ' , ' APPENDIX 4 DOCUMENTS AND WORK IN-PROGRESS REVIEWED , -AP-0004', Revision 10, Plant Information Reports . AP-0008, Revision 4, Event Reportability Evaluation Process
AP-0017, Revision 16, Switching and_ Tagging of_ Plant Equipment AP-0018, Revision 17, Temporary Change-Control , - AP-0020, Revision 9, Industry Operating Experience Program ' AP-0040, Revision 10, Plant Inspection Program AP-0042, Revision 4,, Housekeeping for Maintenance and Modifications AP-0055, Revision 6, Plant Commitment Tracking System , AP-0075, Revision 3, Vendor Equipment Technical Information Program AP-0100, Revision 2, Environmental Qualification Program AP-0204, Revision 10, Safety Classification of Systems, Components and Structures.
' AP-0205, Revision-14, Maintenance Request AP-0206, Revision 10, Nonconformance Report AP-0207, Revision 8, Equipment Control
AP-0209, Revision 11, Inspections . AP-0211, Revision 17, Material _& Service Procurement Program AP-0212, Revision 17, Control of Purchased Material, Equipment and Services AP-0214, Revision 11', Maintenance and Change of Safety Classified Systems, Components, or Structures c AP-0216, Revision 5, Plant Housekeeping Program AP-0218, Revision 11, Test Control i AP-0220, Revision 16, Surveillance Tests and Records .AP_-0222, Revision 10, Job Orders AP-0227, Revision 6,. Corrective Action AP-0230, Revision 1, Post Maintenance Testing AP-5002, Revision 12, Maintenance Department Corrective and Preventative Maintanance Program AP-5004, Revision 8, Control of Maintenance Department Measuring and Test Equipment .AP-5004, Revision 9, Control of Maintenance Department Measuring and Test Equipment (Note: This procedure was revised during the MTI) AP-5010, Revision 8, Maintenance Department Corrective Maintenance AP-6002, Revision 12, Control of I&C Department Measuring and Test Equipment I 'AP-6003, Revision 13, I&C Department Maintenance Program i
- AP-6007, Revision 7, I&C Department Corrective Maintenance
> -DP-5000, Revision 17, Maintenance Department Surveillance Schedule
- 0P-5001, Revision 5, Vibration Monitoring Program
~0P-4506, Revision 12, Inspection of ECCS Circuit Breaker No.
OP-4524, Revision 8, Battery Charger Service Test OP-4659, Revision 13, Main Coolant System Channel Functional Test, Performed . on 2/18/90 OP-4628, Revision 18, Main Coolant System Pressure Channel (MC-r-100, 200, & 300) Calibration
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WC ' i w , .. ... . p; * 10P-5118, Revision:2,7 Threaded Fastener Torquing Procedure -- , K.;, > OP-5762, Revision 9,1 Checking and Setting: Plant' Protective: Relaying
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- QDR 5435'-104-0968'JEnvironmental Qualification.. Package'for Penetration Terminal-
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p, Blocks b; MR_89-257,ERepacking of_SI-V-674_ , JR MR_90-363, Inspect _ Internals and Backseat of NRV No' 1 i , N MR 90-364,finspect-Internals and Backs ~at of NRV No. 2-e ' A MRL90-725, Replace Swing Check Mounting Bolts'in Response'to NRC Bulletin 89-02 d
MR.90-1106,- Inspection of. Sta _Kon Terminals on NRVs 405'. A-D' t m 'MR:90-1156, Maintenance-and Repair of SI-MOV-518
%' - MR: 90-1362, replacing #1;LPSI breaker-overload _ _ _ x
, "f ; MR 89-1864,-pumping the safety injection. tank to the' low pressu.re storage' tank
y MR 88-1863, LPSI check valve: inspection ~ [ YAEC-1163, 10/6/78,' Recommendation:For Wire and-Cable Installation and" Handling: ,o-, s Quarterly reports to'INPO-for 89-1, 89-2, 89-3, 89-4 and 90-1: ! , t , B YAEC, Revision-8, Rules Governing In-Plant Tagging Procedures-- Local Control " Rules- . , i b ~ ' ' * . _ _ i EGG-SSRE-8257,rMay.1990 Risk-Based Inspection Guide For The Yank-Nucleart d y Power-Station Final Report , b . . . . t YAEC Quality. Assurance Manual t , $ l00A-X-1,6 Revision--13,cQualityAssuranceSurveillances -
- 0QA-X-5,=Re'ision.4, Quality-Control' Inspections, M
v > QCII-3,jRevision 0, Mandatory Inspections- 'I En M . QCII-E6, Revision 0, Installation of Electrical Cable j QCII-E9,L Revision 0, Raychem Nuclear Connection -Kit Installation < ",3g , j$' LTechnical Specifications to . ' _Yankeei1990, Performance Goals y ' ;,
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, APPENDIX 5 ACRONYMS AP Administrative Procedures ' ALARA As Low As Reasonably Achievable BOP Balance of Plant 'CCTV Closed Circuit Television DOE Department of Energy ' 'EDCR-Engineering Design Change Request ~ EDG. Em.ergency Diesel Generators . EPRI Electric Power Research Institute EQ- - Environmentally Qualified d.
- H&SS . Health and Safety Supervisor HPSI High Pressure Safety Injection I&C.
Instrument and Controls ISI Inservice. Inspection . LER Licensee Event Report
- M&TE Measuring and Test. Equipment j MEL-Master Equipment List MPSR Material and Services Purchase Request MR Maintenance Request
- NCR-Nonconformance Report NPRDS Nuclear Plant. Records Data System NRC Nuclear. Regulatory Commission PAC Plant ALARA Committee
- PDCR Plant. Design Change Request- - !- PLR Plant License Renewal PM Pre'ventive Maintenance PRA Probabilistic Risk Assessment PROCTF.
Project Commitment. Tracking and Responsibility System QA Quality Assurance-
QC Quality Control.
. QCIR Quality Control Inspection Report QSD-Quality Services Department RPL Radiation Protection 'RWP. Radiation Work Permit , SCSM- . Safety Classification of Systems Manual
SI Safety Injection l STA-Shift-Technical Advisor
- VC Vapor Containment
YAEC Yankee Atomic Electric Company YNPS: Yankee Nuclear Power Station
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