IR 05000155/1988012

Insp Rept 50-155/88-12 on 880523-27 & 0609.Violations Noted. Major Areas Inspected:Maint Activities Using Selected Portions of Insp Modules 62700,62702,62704 & 62705

ML20196C329
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/27/1988
From:	Eick S, Jablonski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196C320	List: IR 05000155/1988012 ML20196C314 ML20196C324
References
50-155-88-12, NUDOCS 8807010067
Download: ML20196C329 (8)

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i U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report No. 50-155/88012(DRS)

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Docket No. 50-155 License No. DPR-6 ,

I Licensee: Consumers Power Company

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212 West Michigan Avenue Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant c

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Inspection At: Charlevoix, Michigan Inspection Conducted: May 23-27 and June 9, 1988 Inspector: S. D. Eick O "' 1 6/27/68 Date

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Approved By: Frank J. Jablonski, Chief 4./)V/d__ !

Maintenance and Outages Section Da'te

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Inspection Sununary -

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Inspection on May 23-27 and June 9, 1988 (Report No. 50-155/88012(DRS))  !

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Areas Inspected: Routine, announced inspection of maintenance activities

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using selected portions of Inspection Modules 62700, 62702, 62704 and 6270 I Results:

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Mafntenance was accomplished, effective, and self-assessed; however, management involvement is needed to assure that maintenance procedures

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are reviewed and evaluated for technical adequacy.

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Maintenance procedures need to be used for activities perfonned on a l regular interval for performance consistenc :

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_ Corrective maintenance procedures need to provide detailed step by step instructions especially during tasks requiring disassembly and assembly of equipment, t

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The threshold for placing equipment problems on maintenance work requests ;

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was sufficient to maintain the material condition of the plant at an !

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acceptable level.

l, Training conducted before the installation of the new intermediate

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range neutron channels was considered a strength in preparing i maintenance personnel for op1 rating and maintaining the new equipment, j _ The QA Department audits and surveillances evaluated maintenance processes

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for technical adequacy and provided input to upgrade and track the PM progra '

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Two examples of one violation were identified and are discussed in

] Paragraphs 3.1.2.1 and 3.2,2,

8807010067 880627 PDR ADOCK 05000155 Q DCD

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DETAILS

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I Persons Contacted

, Consumers Power Company l

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• T. W. Elward, Plant Manager

• R. J. Alexander, Technical Engineer ,

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D. O. Herboldsheimer, PM Coordinator

• L. F. Monshor, QA Superintendent

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• E. B. Mosley, I&C Supervisor .

• E. W. Raciborski, Maintenance General Supervisor  !

l +*G. C. Withrow, Engineering and Maintenance Superintendent t j * Denotes those present at the exit meeting on May 27, 1988.

+ Denotes those contacted by telephone June 9, 198 .

Other licensee personnel were contacted as a matter of routine during this inspectio ' Evaluation and Assessment ( Maintenance The purpose of this inspection was to evaluate and assess the i accomplishment and effectiveness of maintenance activities at  !

Big Rock Point. The inspect.on coincided with a planned outag !

The evaluation and assessment were accomplished by: j

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Review of the Preventive Maintenance Program;

Evaluation of Maintenance backlog; I

Review of completed maintenance orders; i

Evaluations of maintenance rework; i

Observation of maintenance activities;

1 Walkdown of plant systems;

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Review of training records.

! This inspection also assessed the quality verification process related

to maintenance, which was accomplished by

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, Review of audit and surveillance reports;  !

Review of corrective action documents such as discrepancy records l and Licensee Event Reports (LERs). l l

j In preparation for this inspection, the inspector reviewed a number I

! of 1987 maintenance related LERs. Most of the LERs were associated with l

the Intermediate Range Neutron Monitoring Channel l

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j Results of the inspection are documented in the following sections: I l

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i 3.1 Accomplishment of Maintenance

3. Maintenance Backlog

! The inspector reviewed the licensee's system for monitoring the f

, backlogofcorrectivemaintenance(CM)maintenanceorders(MO)- i

and preventive maintenance (PM) M0 Eighty non-outage CM and

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minor modification M0s were open at the end of the first quarter of 1988 with 230 completed. The plant's backlog goal of less

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' than 200 cms was accomplished. The CM backlog greater than l

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, three months old was 53% which was below the plant's goal of .

60%.

Open non-outage PM M0s that were overdue was ten with 151 PMs ,

completed during the first quarter of 1988. The plant's overdue PM goal of below 10% was accomplished with 3.7% overdu The inspector did not identify any reasons that would preclude continued reduction of the backlogs, nor were there ,

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any backlogged items which would significantly impact system '

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3. Review of Completed Maintenance Orders

, The inspector-reviewed approximately 20 maintenance orders for_

completeness, accuracy and technical content. Some of the ,

specific areas evaluated were:  :

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l Adequacy of work instructions;

Post maintenance testing;

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Identification of root causes; i

Resolution of concerns identified during i the perfonnance of the wor ;

l 3.1. Work Instructions j

The inspector determined that there were insufficient details i

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! in the M0s work packages. M0s for specific maintenance tasks i lacked either assembly and disassembly details, a corrective

). maintenance procedure or reference to the vendor's manual that ,

! included such information. During the observation of work '

! activities described in Section 3.2.2, the inspector reviewed -

j maintenance procedure MPG-14 "Disassembly and Assembly of SMA-0 i

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j through SMA-4 Limitorques", Revision 3. This procedure was

used during the perfonnance of maintenance activity M0-88-PCS-009 The inspector determined that there were no instructions in the :

procedure for limit switch disassembly and the proper limit switch lubricant was not specifie !

l The above example of failing to have appropriate steps for j disassembly of the limit switch of safety-related valves is i a violation of 10 CFR 50, Appendix B, Criterion V (155/88012-01A).

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Corrective actions concerning the incorrect procedure had been initiated by the licensee durirg the inspection perio Procedure MGP-14 was revised to include steps for disassembly and assembly of the limit switch and specified the use of

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Mobil 28 in the limit switch' compartmen Limitorque recommends the use of Beacon 325 or Mobil 28 lubricant "

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in the limit switch compartment; however, Nebula EPO was the -

i lubricant referenced in the procedure and acknowledged by the

- repairman for use. Maintenance supervision indicated that

- Nebula EPO was probably in the limit switch compartments of most of the motor-operated valves (safety and non safety) in the plant. The licensee discussed the lubricant issue with '

Limitorque and both agreed that Nebula EPO, although acceptable, is not the lubricant that best suits the applicatio ,

I The licensee performed a 100% inspection of EQ valves and determined that three did not use Mobil 28 as a limit switch lubricant. These three were changed out to Mobil. 28 'during

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the inspection. The Q-Listed valves will be changed out to Mobil 28 during an existing PM inspection or v; hen corrective maintenance is performe One third of the MOs reviewed pertained to valve packing

. adjustments or replacements. Although two maintenance procedures

on pecking adjustments / replacements existed onsite, these .

procedures were not referenced in the MOs for use by maintenance l

, personnel. Valve packing leakage in general had been identified j as a continuing maintenance rework item and the procedures were ;

written as corrective action to this proble The licensee '

stated that the packing procedures would in the future, be used ;

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in the M0 to provide consistent direction in packing adjustment ,

l 3.1.2.2 Post Maintenance Testing i

Post maintenance test requirements were not specified on the

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M0 form; however, any post maintenance testing that was done was specified on an Equipment Outage Request (EOR). The EOR was designed for Operations' test requirements such as Technical Specification (TS) considerations. The inspector suggested that i post maintenance tests be specified in a block on the M0 form i for equipment repairs not needing TS testing. No concerns or

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problems were identified in the revie .1.2.3 Root Causes and Resolution of Concerns The inspector concluded that the M0s reviewed appeared to ,

adequately address identification of root causes and the l

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resolution of concerns identified during the performance

of the M0 wor l

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3. Summary of Maintenance Accomplishment

Backlogs of PM/CM M0s were within realistic plant ' goal *

Maintenance orders need to provide more detail ~

Corrective maintenance procedure 3 nee'd to provide !

step by step instructiuns for tasks requiring !

disassembly and assembly of equipmen One example of a violation was identifie .2 Effectiveness of Maintenance

3. Review of Maintenance Rework To evaluate effectiveness of maintenance the inspector reviewed the method utilized for monitoring maintenance rework. ,

maintenance rework analysis was done yearly in each maintenance !

department (EM, MM,180) based on a component's corrective i maintenance history within a specified time period of one or two years. Although no formalized computer rework program exists, I the current system used appeared to be adequate due to the size l and experience of the maintenance organization. All of the j items on the rework list were being tracked and corrective :

engineering projects were ongoing to alleviate the problem l 3. Observation of Work Activities The inspector observed portions of approximately eight electrical ;

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and mechanical maintenance activities to determine if those activities were performed in accordance with required ;

administrative and technical requirements. Activities ;

witnessed by the inspector included safety and non-safety !

equipment. Except for one initance the inspector concluded t that maintenance activities were effectively accomplished i based on the following-  !

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Administrative approvals were obtained; Equipment was properly tagged;

Replacement parts were acceptable and certified; i

Approved procedures were available and properly I implemented;

Work was accomplished by experienced and knowledgeable personnel; and

Radiological controls were establishe While witnessingSMA Valve V0P-IA76A (maintenance activity M0-88-PCS-0045 000), the inspector observed that on ;

procedure MGP-14 "Disassembly and Assembly of SMA-0 through j SPA-4 Limitorques," Revision 3, and prints used for the valve i operator disassembly were not applicable for SMA 000 and 00 S

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model operators. MGP-14 was the only procedure available on site for disassembly of both safety and non safety Limitorque *

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valves. No procedure existeri for SMA 000 and 00 models even

.though similar models had been disassembled previousl The above example of failure to have an appropriate procedure- ,

for the disassembly and assembly of Limitorque SMA 000 and 00 ;

operators is a violation of 10 CFR 50, Appendix B, Criterion V !

(155/88012-01B).  !

3. Plant Observations and System Walkdowns l'

To assess the material condition of the plant, the inspector j made general observations of the plant and conducted walkdowns -

of various systems. The inspector evaluated equipment condition t

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and verified that M0s had been written and,.when needed, tags <

hung on components needing repair. The inspector did not identify any item for repair or maintenance that had not already i been noted-by station personnel. MOV stems were observed to be '

i lubricated and various pump lubricants appeared clean with oil i levels within acceptable sightgit,ss rang . Training '

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Training and qualification records were reviewed for  ;

six maintenance personnel that participated in maintenance 1

activities witnessed by the intpector. Traiair.g files were I readily available and documented all training received sin I the employees were hired by the licensee. The inspector i

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determined from review of the'six training records that :

personnel were qualified to perfonn the assigned maintenance I activities.

During the follow-up of LER 37-012 (Failure of Intennediate i Range Neutron Monitoring Chtnnel), the inspector was informed l that the intermediate range neutron channels were replaced i with the new General Electric "NUMAC" line during this outage, i Training on the new components were held by GE during last j outage and in December 1987. This training was considered ,

i a strength in preparing maintenance and operations personnel l

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for operating and maintaining the new equipment before

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installatio . Suninary of Maintenance Effectiveness i

Maintenance procedures used in the disassembly and )

1 assembly of Limitorque operators were considered i technically inadequat i I

Management attention is needed in assuring that maintenance

procedures are reviewed and evaluated for technical l adequacy.

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Maintenance activities observed during the inspection j were generally accomplished in an effective manner with- *

knowledgeable and professional personne :

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The material condition and housekeeping of the plant were !

good considering the ongoing outag ;

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Training conducted before the installation of the new l l intermediate range neutron channels was considered a  !

l strength in preparing maintenance personnel for operating :

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! One example of a violation was identifie !

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3.3 Licensee Assessment of Maintenance (Quality Verification) l l

The inspector reviewed audit reports and corrective action documents ;

to evaluate the licensee's quality verification process. The  ;

! documents were reviewed for root cause analysis, timely corrective :

l action, technical assessments, and justification for close out of _

corrective action-document ;

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3. Review of Audits and Surveillances  !

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The inspector reviewed maintenance audits conducted in 1987 and

198 The audit reports pertained to activities performed by l l electrical and mechanical maintenance departments. The audits

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evaluated the adequacy of the PM program on selected components

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and determined if any CM activities indicated any adverse trend ;

The scope also included the adequacy of component testing,

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maintenance instructions / procedures, as well as verification j of compliance to procedure !

1l j The surveillances reviewed provided maintenance PM suggestions, i

. contained thorough follow-up on corrective action items and  !

verified the adequacy of the design, installation and l implementation of engineering / maintenance modification ;

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l 3. Summary of Licensee's Assessment (Quality Verification) {

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of Maintenance j

Audits and surveillances evaluated maintenance processes i for technical adequacy and provided input to upgrade and I track the PM progra , No violations were identified, l Conclusions J

Based on inspection activities described in this report, the inspector concluded that:

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Maintenance was accomplished, effective, and self-assessed; however, management involvement is needed to assure that maintenance procedures are reviewed and evaluated for technical adequacy. Also, maintenance procedures need to be used for activities done on a regular interval for performance consistenc Co'rrective maintenance procedures need to provide detailed step by step instructions especially during tasks requiring disassembly and assembly of equipmen *

The threshold for placing equipment problems on maintenance work requests was sufficient to mair.tain the material condition of the plant at an acceptable leve *

Training conducted before the installation of the new intermediate range neutron channels was considered a strength in preparing maintenance personnel for operating and maintaining the new equipmen * The QA Department audits and surveillances evaluated maintenance

processes for technical adequacy and provided input to upgrade and track the PM progra Two examples of one violation were identifie . Exit Interview The inspector tret with licensee representatives (denoted in Paragraph 1)

on May 27, 1988, and contacted by telephone on June 9,1988, and sumarized the purpose and findings of the inspection. The inspector discussed the likely content of the inspection report with regard to documents or processes reviewed by inspector during the inspectio The licensee did not identify any such documents or processes as proprietary, i

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