IR 05000155/1990010

Insp Rept 50-155/90-10 on 900723-27 & 0806-10.Violations Noted.Major Areas Inspected:Maint,Engineering,Support of Maint & Related Mgt Activities

ML20059N018
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/25/1990
From:	Choules N, Michael Kunowski, Mendez R, Tella T, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059N011	List: IR 05000155/1990010 ML20059N008 ML20059N012
References
50-155-90-10, NUDOCS 9010090034
Download: ML20059N018 (32)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report No. 50 155/90010(DRS)

Docket No. 50-155 License No. DPR-6 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: - Big Rock Point Nuclear Power Plant Inspection At:

Big Rock Point Plant, Charlevoix, Michigan Inspection Conducted:

July 23 through 27, and August 6 through 10, 1990 In pectors:

I 'Abal er, Team Leader fM.fdo

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/9.a k w d M. A. Kunowski 7[2 4/f 0 Date

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R. Mendez

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2.26 T, Tella 9/2 k'/o Date O

Approved By: h ). $)6[b b'NO

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F. gablpnski, Chief:

Dat'e Maintenance and Outage Section l

Insoection Summary Insoection on July 23 throuah 27 and Auous' i throuah 10. 1990 (Recort No; 50-

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155/90010fDRS)).

Areas inspected:

Special announced team inspection of maintenance, i

engineering, support of maintenance, and related management activities. The

inspection-was conducted utilizing Temporary Instruction 2515/97, the attached Maintenance Inspection Tree, and selected portions of Inspection Modules 62700, 62702, 62704, 62705, 64150, 64704, and 73755 to ascertain whether maintenance was effectively accomplished and assessed by the licensee.

Results: Based on the items inspected during the period that the inspection was conducted, overall performance ti. maintenance was considered satisfactory.

The most significant strengths of the maintenance organization were the long-term, highly skilled, and dedicated employees who were supported by a goopoo349oo9<g

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.I dedicated and knowledgeable supervisory staff', and close coordination of maintenance activities. The most significant weaknesses were the lack of-effective engineering support in several instances, untimely corrective action in the areas of audit' findings and controlling limited life materials, and instances where electrical components were not periodically tested because -

replacement parts were not available. A synopsis of the overall implementa-tion cf the maintenance program is.provided in'Section 3.0 of the report.

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There were two violations:

failure to. follow procedures in performing

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maintenance related activities in two instances, and failure to take adequate i

or timely corrective retion in two instances,

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CONTENTS

E Section Paae 1.0 Principl Persons Contacted........................... 3

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' 2.0-Introduction to the Evaluation and Assessment of Maintenance.........................................

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2.1 Performance Data and System - Selection................. 4

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2.1.1 Historic Data.........................................

l 2.1.2 Sy s t em Sel ec t i on...................................... 4

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2.2-Description of Maintenance Philosophy................. 4 2.3 Observation of Current Plant Conditions & Ongoing Work................................................

2.3.1 Current Material Condition............................ 5 2.3.2 Ongoing Work..........................................

2.3.2.1-Ongoing Electrical Maintenarce........................ 6

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2.'. 2. 2 Ongoing Mechanical Maintenance........................ 8 a

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2.3.2.3-Ongoing Instrument and Control Maintenance........... 10

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2.3.3 Rad i ol og i cal Control s................................ 10 2.3.4 Maintenance Facilities, Material Control, and Control of Tool s and Measuring Equipment................... 11 2.3.4.1 Maintenance Facilities...............................

• 2.3.4.2 Materi al Con t rol..................................... 12

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2.3.4.3 Control and Calibration of Measuring and Test Equipment..........................................

i 2.4 Review and Evaluation of Maintenance Accomplished....13 2.4.1 Backlog Assessment. and Evaluation.................... 13 2.4.1.1 Corrective Maintenance Backlog....................... 13 2.4.1.2-Preventive Maintenance Backlog....................... 14 2.4.2 Review and Evaluation of Completed Maintenance.......14 l-2.4.2.1 Past El ectrical Maintenar.ce.......................... 15

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2.4.2.2 Past Mechanical Maintenance.......................... 16

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2.4.2.3 Past Instrumentation and Control Maintenance.........19 l

2.5 Maintenance Work Control.............................

2.6 Engineering and Technical Support.................... 21 o

2.7 Maintenance and Support Personnel Control............ 23

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2.8 Review of Licensee's Assessment of Maintenance....... 23 2.8.1 Audit and Surveillance.............................. 23

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2.8.2 Maintenance' Sel f-Assessment.......................... 24

3.0-Synopsis.............................................

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3.1 Overall Pl ant Performance............................ 24

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3. I'.1 Historic Data........................................

3.1.2 Pl a n t Wal kd own s...................................... 2 5

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3.2 Management Support of Maintenance.................... 25 3.2.1 Managemeni; Commi tment and Invol vement................ 25

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3.2.2 Management Organization and Administration........... 25 3.2.3 Tc rhni cal Support.................................... 2 5 3.3 Implementation of Maintenance........................ 26 3.3.1 Work Control........................-.................

3.3.2 Pl ant Maintenance -Organization....................... 26 i

'3.3.3 Maintenance Facilities, Equipment and Material Control............................................

3.3.4 Personnel Control....................................

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4.0-Un re s ol ved I t em...................................... 2 7 5.0 -

Exit Meeting.........................................

Appendix A:

Acronyms...........................................

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DETAILS

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1.0 Principal Persons Contacted Consumers Power Company

• W.L. Beckman, Plant Manager

• J.L. Beer, Chemistry / Health Physics Superintendent

• P.M. Donnelly,'Probabilistic Risk Assessment Administrator

• H.M. Hoffman, Maintenance Superintendent

• D.E. Moeggenberg, Maintenance Engineering Supervisor

• L.F. Monshor, Quality Assurance Superintendent

• E.B. Mosely, Instrumentation and Controls Supervisor

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• J.J. Popa, Maintenance Engineer m-

• W.J. Trubilowicz, Operations Superintendent

• G.C. Withrow, Engineering Superintendent U. S. Nuclear Reaulatory Commission (U.S. NRC)

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• H.A. Ring, Chief, Engineering Branch

• R.W. DeFayette, Section Chief, Division of Reactor Projects

• A.S. Masciantonio, Licensing Project Manager

• R.C. Pierson, Director Project Directorate 111-1

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• E. A. Plettner, Senior Resident Inspector

• Denotes those present at the exit meeting on August 17, 1990.

Others persons were contacted as a matter of course during the inspection.

2.0 Introduction to the ' Evaluation and Assessment of Maintenance An announced NRC team inspection of maintenance and supporting activities was l

conducted at Big Rock Point Nuclear Power Plant during the period of July 23 through 27, and August 6 through 10, 1990.

The first week of tLa inspection was conducted during an unplanned outage for repair.of cooling system leaks; during the second wei.k the plant' was at power operation. The inspection was

conducted to address f t.ndamental issues in.the broad areas of maintenance, engineering, and techn1cel support where the team looked at plant performance, management support, and implementation. The team goal was to determine if maintenance had been effectively implemented to assure the safe operation and reliability of plant structures, systems,.and components to operate on demand.

This inspection was based on the guidance provided in NRC Temporary Instruc-tion 425767-C, " Maintenance Inspection," and Drawing 425767-C, " Maintenance Inspection Tree " The drawing, which is attached to this report, wat used as a visual aid during the exit meeting to depict the results of the inspection.

Acronyms.used.in this report are defined in Appendix A.

Results of this inspection were derived from data obtained by observation of current plant conditions and work in progress, by review of completed work, and by evaluation of the licensee's self assessment of maintenance and correction of weaknesses.

Major areas of interest included electrical, mechanical, instrument and control and the support areas of radiological

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control, engineering, quality control, training, procurement, and operations.-

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Problems identified by the inspectors were evaluated for effect on Technical-

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. Specification operability and technical or managerial weakness.

2.1-Performance Data and System Selection-

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'2.1.1 Historic Data u

l-The-inspectors considered the latest Systematic Assessment of Licensee i

s, Performance (SALP) report _ and completed NRC inspection reports. Priwily, the ins)ectors were sensitive to technical and managerial problems that appeared

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to se maintenance related.

The inspectors also reviewed plant operations historic data since January 1989, including Licensee Event; Reports (LERs).

Results of this review did not indicate any significant or pervasive problems

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j or weaknesses.

No maintenance related LERs were noted, j

.The plant equivalent availability for 1990 through July was 93.6% and for 1989

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was 79.0%. There was one unplanned reactor trip in 1989 and two in 1990..

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Only one of these trips could be attributed to maintenance problems.

There were no unplanned safety system actuations for 1989 and 1990; there was one

,L technical specification violation in 1989.and two ir 1990.

Radiation exposure:

for 1990 through July was 58 rem with 160 rem for 1989.

All the data appeared to be reasonable, were within established goals, and appeared to indicate good

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performance.

2.1.2 System Selection

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No specific systems were selected for emphasis during this inspection. Big

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i Rock Point has a reduced number of systems and components, and a review of-

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LERs and other documents failed to indicate gem eric-problem areas.

An overall review of important systems was performed with emphasis placed on the systems considered safety significant.

2.2 Descriotion of Maintenance Philosoohv The inspectors reviewed site policy statements, administrative procedures, organization charts, established goals, and documents that described j

improvement programs for the maintenance process. The licensee had a

. documented maintenance plan that included milestones and completion dates for

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improvement programs and goals.

Discussions by the inspectors with selected

managers indicated that those personnel were knowledgeable and aware-of

established performance goals and that the goals were being met.

L The inspectors determined that the maintenance program was balanced between corrective maintenance (CM) and preventive maintenance (PM). The licensee

addressed PM requirements for equipment.

In some cases, equipment was r

p overhauled or refurbished without being scheduled for or being called PM.

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L of' maintenance history to determine the need for PM was difficult-and no

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formal trend program existed.. Maintenance history consisted of personnel

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memory or a manual search'of Maintenance Orders (M0s), which was very time

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consuming and did not ensure trend of component failures.

In the area of

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predictive maintenance, the licensee used vibration analysis and thermography-

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for the analysis ~ of-some-plant parameters.

2.3 Observations of Cur?nt-Plant Conditions & Onaoina-Work

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2.3.1 Current Material Condition The inspectors performed general plant as well as selected system and

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component walkdowns to assess housekeeping,' the general and specific material condition of the plant, and to verify that maintenance orders (M0s) had been initiated-for identified equipment problems.

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Walkdowns included an assessment of the buildings, components, and systems for

proper identification and _ tagging, accessibility, fire and security door integrity, scaffolding, radiological controls, and any unusual conditions'.

'i Unusual conditions included but were not limited to water, oil or other liquids on the floor or equipment; indications of leakage through ceiling, walls or floors; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lighting. During the walkdowns the-plant was at full power.

Results follow:

The plant was extremely clean with few liquid or steam leaks.

• Electrical ~ components were well preserved and maintained, however; a-few

spare cables in the cable spreading room were cut but not tagged as required. 'The licensee agreed to tag tho' cables to comply with requirements.

A-drain line sight glass was shattered but no deficiency or maintenance

tag was noticed on the sight glass.

The licensee issued a maintenance order to comply with requirements, i

The inspector noticed a large pile of insulation, plastic sheets, and

rubber Goes lying on the pipe tunnel floor. The licensee stated that these were not cleaned earlier due to radiation and asbestos considerations.

The licensee issued a job order to have the debris i

removed.

The: plant material condition was considered very good to maintain operabilty of components at a level commensurate with the componentv function.

Housekeeping was very good in most areas.

None of the problems noted in this i

area appeared to have any safety significance.

2.3.2 Onacina-Work The inspectors observed ongoing work in ele u.

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controls (I&C), and mechanical maintenance areas. The inspectors selected these activities from the plan of the day listings, work assignments in individual maintenance shops and through discussions with individual foremen.

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Where possible, safety significant activities were chosen'for follow-up.

raintenance activities were witnessed / observed to determine if those

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activities were performed in accordance with required administrative and technical requirements. Work activities were assessed in the following areas:

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work control and planning; management presence, involvement, and knowledge; Quality Control (QC) presence and~ involvement; health physics ~ (HP) support and hazards; procedures available, adequate,- and used; personnel trained and

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qualified; materials available, adequate, and used; measuring &' test equipment

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(M&TE) and tools proper, calibrated, and used; and post maintenance testing

' performed and (PMT) acceptance criteria satisfied as specified.

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2.3.2.1 Onaoina Electrical Maintenance

The inspectors observed portions of six electrical maintenance activities as

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EOR-9007-Inspect diesel fire pump circuitry

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M090-EPS-0189 Perform surveillance of the reactor depressurization l.

system (RDS) uninterruptible power supply batteries -

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M090-EPS-0198 Troubleshoot emergency diesel generator (EDG) circuitry

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M090 PIS-0037 Troubleshoot motor operated valve M07071

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M090-SPS-0083 Doble test transformer and sample oil l

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M090-SPS-0087 Test the 2400V station system undervoltage pr'otection L,

system The _ inspectors concluded that electrical maintenance activities in the pertinent areas described in 2.3.2 were adequate and accomplished by skilled L

maintenance personnel.

The maintenance supervisor and craft appeared to be L

knowledgeable, dedicated and adequately trained. Work was completed in L

accordance with procedural requirements.

Test equipment used.was within h

correct calibration dates. Electrical maintenance personnel were L

knowledgeable, had extensive experience, and exhibited a sense of ownership in

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maintaining plant equipment.

Concerns were identified with drawing

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configuration, the'EDG-circuitry and improper root cause evaluation of MOV M07071 as described below:

E0R-9007 - As part of the followup corrective action to an EDG circuitry

and configuration problem discussed in following paragraphs under M090-

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EPS-0198, the licensee issued this Equipment Outage Request (EOR) to a

inspect the diesel fire pump cabinet. Several spare conductors were in-

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e the cabinet btit were not show1 on the drawing.

These were not

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significant; however, a possible problem with configuration control' was i

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As additional followup, the inspector verified the configtiration of a

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reactor protection system (RPS) control panel.

Terminations to two relays were~not in accordance with drawing 0740E30914, Sh 1, Rev K, however; the configuration had no affect on operability of the reactor protection system. As part of the long term corrective action to similar

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problems associated with LER 155/90004, a' program to update drawings'was being implemented by the licensee to show actual physical panel' wiring r d m %ent similar errors during modification and maintenance at - '..ies.-

M090-EPS-0198 - This maintenance order ano the associated reports were

issued-because of a potentially inoperable diesel unerator due to an error in the. control circuit logic.

The inspector observed connections to' diesel' generator overcurrent relays PJC 1 and PJC 2, which were different than the-PJC 3 relay (x, y, and z phases, respectively).

Wiring diagram 0740E30869, sheet 3, revision m, and schematic diagram 0740JG30kl869, Sheet 2, revision p, incorrectly designated' connections to pins 3 and 4 for each phase.

Neither diagram had been updated to reflect as-built conditions.

The inspector reviewed the diesel generator circuitry and identified a discrepancy between the required coincident logic and the connections-to.

pin 10 of relay PJC 1. The incorrect wire termination bypassed the PJC 1

relay overcurrent trip of the x phase and resulted in a single sensor x-z coincident logic. The diesel generator was required to trip on a phase to phase fault on overcurrent; however, the improper connection would have disabled the diesel generator on a single component failure, in this instance relay PJC 1.

Consequently, the incorrect termination, which existed since 1977, was not conservative because the generator q

would have' tripped if relay PJC 1 failed.

The licensee's Updated Final J

Hazards Summary Report, in Sections 8.3.4.3 and 9.5.5, and Branch

. Technical-Position (BTP) EICSB-17 required that the diesel generator relays provide coincident trip logic utilizing independent sensors to eliminate unwanted signals such as a single relay failure.

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The licensee determined that the circuitry error was caused by improper implementation of a modification described by Facility Change 401 in.

response to an NRC memorandum and an order dated May 26, 1976.

Plant procedure 77-EPS-202-13 dated August 2,1977, was used during installa-

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tion and testing of.the modification.

The licensee completed the modification on-September 13, 1977, which changed the trip logic to meet'

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The procedure provided correct information to test the

coincident x-y logic but did not provide correct information to test the

'l y-z or the x-z trip logic where the wiring error occurred. A subsequent i

review.of the procedure indicated that no record or documentation j

existed for the installation and testing of the modification.

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On wuly 28,.1990, the licensee notified the NRC of a potential event

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pursuant to 10 CFR 50.73 Licensee Event Report (LER) 155/90004.

j Concurrently, after troubleshooting the discrepancy, the wiring error

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was corrected and tested. The inspector reviewed the control panel and

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noted that the corrective action was properly implemented.

Criterion V of 10 CFR 50, Appendix B requires that-activities affecting i

quality be prescribed by documented instructions, procedures and drawings and that activities be accomplished in accordance with these

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instructions, procedures, and drawings.

The failures to perform work in

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accordance with procedures and updated drawings, to properly test

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implementation to the procedures, and to document implementation and testing of the procedure is considered a violation (155/900010-01A).

M090-PIS-0037 - On August 2,1990, during plant startup, the licenseeSeveral attempts attempted to open the backup core spray valve M0-7071.

• were made but the valve would not open against reactor differential Due to the motor-operated valve (MOV) f ailure and the associated Technical Specification operability requirements, the pressure.

licensee initiated a plant shutdown and declared an unusual event on Section ll.4.1.4. A of the Technical Specifications August 3,1990. required that valve MO-7071 be verified operable by remote each month during power operations. switch had been set to the maximum motor when the maximum torque was reached.

i On August 5, 1990, a torque switch set point change was initiated and the switch was set in the by-pass position, which would prevent the torque switch from removing power to the motor during the opening cycle.

The valve was successfully tested and ' reactor start-up was initiated.

The inspector reviewed the history of M0-7071 and found that the valve had failed to open a total of 4 times in the last 20 months (DecemberIn December 198 1988, March 1989, August 1989, and August 2, 1990).

the valve manufacturer calculated that 57 f t-lbs of torque would be required to open the valve under the full differential pressure of 1350 The manufacturer concluded that sufficient margin to open the valve existed since the calculated stall torque that would be developed psi.

The position of the torque at 80% of rated voltage was 106 ft-lbs.

switch (in the maximum setting) prior to the set point change, corresponded to a torque range of approximately 108 to 120 ft-lbs under During the 1989 refueling cutage the valve actual field conditions.

The licensee suspected disc was replaced to improve leak tightness.that the unseating forces v The to be stroked during plant startups.

89 that required the valvt subsequent failures occurred with the above noted torque switc settings.

The opening, as calculated by the manufacturer, was not conservative.

inspector was concerned that, even with the torque switch bypassed, the motor's ability to unseat the valve was questionable at reduced voltage The licensee agreed that the manufacturer's calculated torqueAs values required to unseat the valve may not have been conservative.

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part of the action to prevent recurrence, the licensee committed to conduct additional diagnostic testing to further understand the torque requirements for the valve. This matter is unresolved pending completion of this testing (155/90010-03(DRS)).

2.3.2.2 Oncoina Mechanical Maintenance The inspectors observed portions of five mechanical maintenance activities as

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M090-CRD-0091 Inspect CRD' selector valve A4

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J N090-CRD-0093 Inspect. and repair B5 selector. insert valve-lL W M090-CRD-0096 Repair selector valve A4 s

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M090 MSS-0017' Repair position indicating switch mounting M090-RDS-0039 Replace seal control valves

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The inspectors concluded that mechanical maintenance activities in the pertinent areas described in 2.3.2 were adequate and accomplished by skilled

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maintenance personnel. The maintenance personnel appeared to be conscientious =

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and knowledgeable of the work performed.

Health physics technicians.were available near the maintenance jobs in radioactive areas and a high Wel of cooperation was evident between maintenance and health physics personnel.

Maintenance supervisors were not always observed at the job site, but they were in constant touch with the technicians and aware of the progress of each l

maintenance job. A concern was identified with limited shelf life materials

as described below:

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M090-RDS-0039 - The inspector observed the two seals installed on the

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air cylinder piston of control valve CV-4182, which was part of the safety related reactor depressurization system (RDS).

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made of. Buna-N material, for which t'ie manufacturer suggested a five year shelf life.

The seals had been in the warehouse since March 29, 1984. To determine if the _ seals were acceptabl_e, the manufacturer suggested an acceptable naximum hardness of 80 to 90 units as measured

on the durometer "A" scale. The four seals in storage,.which were from the same batch used in the RDS repair, were tested. Three of the seals.

failed the acceptance criteria with average seal durometer readings of

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90.13, 90.38, and 92.63. All four seals were removed from stock.

The manufacturer subsequently stated that a hardness of 80 to 90 was

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-conservative-and that-there had been no record of seal-failures when the durometer reading was less than 95. The seals 'in the CV-4182 air-cylinder piston valve had been tested with air pressure and no problems were_ encountered.

In addition, the licensee stated that any seals that failed could be replaced during power operation.

Considering all the data, the licensee considered that the installed seals were acceptable.

Additional corrective action was taken that required part suppliers to provide. shelf, life information.

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The inspector reviewed an independently identified item found in 1986 i

regarding limited shelf life items. At that time'it was determined that

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a number of materials subject to degradation by aging were not included

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in the shelf-life program.

Examples were 0-rings, valve diaphragms, solenoid repair kits, and turbine oil seal gaskets.

In response to this item, the licensee apparently reviewed all "Q" items that had identified shelf lives and tracked the items with a shelf life computer program.

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'1988, it was noted that some "Q" listed items with limited shelf lives had not been added to the computer program.

Report 88-005 also included

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several exam)les of "Q" items that did not have shelf life data. The'

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-quality of tie items was questioned.because of _ time / aging concerns,. and i

because many of _these items were stored _in less than ideal conditions.

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This item was tracked by Action Item Request (AIR)=A-QB-88-02, which by

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the conclusion of this inspection, still remained open.

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The date for completion of corrective action for this item had been-extended five times.

The failure to properly identify the shelf-life of:

the parts used in a safety related system, and the failure to take

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timely and adequate corrective actions for previously identified findings for over seven-years is a violation of 10 CFR 50, Appendix B,

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Criterion XVI (155/90010-02A).

2.3.2.3 Onaoina Instrument and Control I&C Maintenance The inspectors observed portions of four I&C maintenance activities as discussed below, l

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M090-DMW-0071 Recalibrate makeup water conductivity recorder M090-PIS-0040 Calibrate pressure switches from stock M090-RIA-0014 Calibrate area vent radiation monitors i

M090-RSD-0003 Calibrate high reactor pressure annunciator sensor The inspectors concluded that I&C maintenance activities in the )ertinent areas described in Section 2.3.2 were adequate and accomplished )y skilled r

i maintenance personnel. The maintenance personnel appeared knowledgeable and well trained for work performed.

Some concerns were identified with lack of instructions for M&TE calibration and shift supervisor..signoff as described

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M090-RIA-0014 - The procedure required that-personnel obtain permission to calibrate the radiation monitor and inform the control room when the

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radioactive source was brought into the building. There was no signoff

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M090-RSD-0003 - The procedure did not provide any instructions for the hookup of calibrated equipment and the required valve lineup of the-

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system being calibrated.

Also, a voltmeter used during the calibration

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was not specified on~the procedure as required test equipment. The

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licensee agreed to revise.the procedure.

y There were no problems identified with the performanca of.the work due to the above concerns'. The shortcomings were overcome by outstanding.I&C technicians who were experienced and well trained.

There was good communication between the testing personnel, the shift supervisor, and control room operators.

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'2.3.3 Aadioloaical Controls

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-The inspectors observed the major support functions provided by radiation-

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protection (RP) personnel for maintenance.

These functions included-radiation work permit (RWP) preparation, as low as reasonably achievable (ALARA)

i reviews, 'and field support of on-going work. The inspectors also performed-independent reviews of documentation, made independent dose rate measurements, F

and discussed radiological controls with plant personnel, t

The inspectors observed good support of the maintenance staff by the radiation protection (RP) grom. Apparently, the small size of the plant and the low I

staff turnover had resulted in a plant staff that works well together.

In addition to daily, %ormal discussions between maintenance planners and RP i'

managers, a weekly r,mting was held to discuss radiological concerns' of upcoming work and assess the need for an RWP and an ALARA review, RP personnel responsible for preparing RWPs and ALARA reviews were experienced

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i and knowledgeable of plant systems. The RP technicians assigned to jobs that i

were reviewed by the inspectors were also knowledgeable and ensured that proper radiological controls were followed. The quality of RP documents to be used by maintenance was adequate, as was the knowledge of plant personnel regarding radiation protection matters. Maintenance personnel observed during the inspection generally followed good radiation worker practices.

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Several poor practices were observed during the inspection. These practices and concerns were promptly addressed by licensee management.

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On a job to repair a drain trap in the pipe tunnel, a rubber overshoe

was used to collect leaking, contaminated water. The shoe was filled to capacity and water dripped onto the floor at the time of the observation.

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For work in the recirculation pump room, a staging area was established

in a non-contaminated area of an adjacent room. Dose rate measurements indicated that the general area dose rate in this adjacent room was around 10 mrem / hour; whereas, in another adjacent room where the same

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function could be easily performed, the dose rate was only 1-2

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mrem / hour.

In addition, several concerns with posting were identified.

During this inspection, exposure estimates for several jobs were

significantly exceeded. Because of a maintenance error, additional repair was required on the CV-4050 valve in the liquid poison system.

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The additional work resulted in almost 2 person-rem additional dose.

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For work on repairing a pinhole leak in the reactor water cleanup system,. problems with weld quality resulted in approximately 10 person-

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rem additional dose.

Both jobs were performed in the recirculation pump

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room, where general area dose rates ranged from 300-1000 mrem / hour.

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. Inspection results showed that the maintenance group generally did well at L

meeting or not significantly exceeding established exposure and personal I

contamination goals.

RP support of maintenance during these jobs was good.

2.3.4-Maintenance Facilities. Material Control and Control of Tools' and L

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2.3.4.1-Maintenance Facilities

- The. Inspectors observed that the electrical and mechanical staffs were l

combined into one department.

Both the electrical / mechanical and I&C workshops were: satisfactory-but were generally cramped.

New maintenance

facilities were under construction.

The electrical / mechanical supervisors'

offices were adjacent to the shop. Tool storage,' issuance, and procurement of parts appeared sound and was controlled within the shop area. Items in tool boxes were in good condition and within calibration.

l 2.3.4.2 Material Control The inspectors reviewed the methods used by maintenance and supporting

organizations to control replacement parts and materials.

This review

included replacement parts and materials used during observed maintehance l

activities, and parts storage areas and methods of storage.

Replacement parts and equipment were stored in the main warehouse that

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included a parts receiving area and a parts issue area. A separate and

significantly smaller building was provided for flammable materials such as

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l paints, thinners,' and solvents.

The buildings were separated by approximately

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three feet of. air space. The main warehouse had a water fire suparession

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installed.

The close proximity of the building provided some ris< to the

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stored parts, some of which were difficult to replace, j

Safety-related and non safety-related parts were -stored in separate areas.-

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Safety-related parts were identified with both the respective

) art number-and purchase order number.

Physical control of access to the ware 1ouse facility was limited to authorized personnel, and cleanliness and housekeeping aspects

I l-were well maintained.- Controls for consumable materials such as solvents and

cleaners, thinners, paints, oil, grease and gasket materials could be improved.

Several cans of solvent and a drum of oil were located in the

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- warehouse and had not been moved to the established storage areas.

Warehouse

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personnel and the procedures that governed issuance of parts from the warehouse appeared adequate to prevent inappropriate parts issuance.

A computer system was used to control component procurement information.

-The computer data base also contained the quantity and location of stocked parts; however, the location of stored parts was not always accurate.

Errors

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were noted in the location of 3 of 14 components reviewed for location and j

quantity; only 1 discrepancy was noted in the quantity of the items reviewed.

i The.llcensee_was made aware of the problem and planned to review locations _as-parts were received to ensure that more accurate data were available.

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l The inspectors reviewed the licensee's shelf life program. A computer dat'a base listed items in the warehouse that were in the limited shelf life

3 pro. tram, Limited shelf life material was stored with'other stocked material but was appropriately-labeled. Material with expired shelf life was removed -

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from stock monthly when indicated by a computer report.

Based on this method

of control, the location proLlem previously noted has more significance since

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"[2.3.4.1-Maintenance Facilitjn

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U The inspectors observeo that the electrical and mechanicallstaffs were

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E combined into one department. Both the electrical / mechanical and I&C

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f workshops were satisfactory but were generally cramped.

New maintenance

facilities were under construction. The electrical / mechanical supervisors'

offices were adjacent to the shop. Tool storage, issuance, snd procurement of 3 arts appeared sound and was controlled within the shop area. Items-in tool aoxes were in good condition and within calibration.

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2.3.4.2 Material Control I

The inspectors reviewed the methods used by maintenance and supporting organizations to control replacement parts and materials.

This review

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included replacement parts and materials used during observed maintenance i

activities, and parts storage areas and methods of storage.

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Replacement parts and equipment were stored in the main warehouse that included a parts receiving area and a parts issue area.

A separate and significantly smaller building was provided for flammable materials such as paints,ithinners, and solvents. The buildings were separated by approximately three feet of air space. The main warehouse had a water fire suppression

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installed. The close proximity of the building provided some risk to the stored parts, some of which were difficult to replace.

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Safety-related and non safety-related parts were stored in separate areas.

Safety-related parts were identified with both the respective aart number and purchase order number.

Physical control of access to the ware 1ouse facility was limited to authorized personnel,_ and cleanliness and housekeeping aspects were well maintained. Controls for consumable materials such as solvents and cleaners, thinners, paints, oil, grease and gasket materials could be improved. Several cans of solvent and a drum of oil. were located. in the

warehouse and had not been moved to the established storage. areas. LWarehouse personnel and the procedures that governed issuance of parts from the warehouse appeared adequate to prevent inappropriate parts issuance.

A computer system was used to control component procurement information.

The computer data base also contained-the quantity and location of stocked

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parts;'however, the location of stored parts wa: not always accurate.

Errors were noted in the location of 3 of 14 components reviewed for location and

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L quantity; only 1 discrepancy was noted in the quantity of the items reviewed.

,9 The licensee was made aware of the problem and planned to review locations as parts were received to ensure that more accurate-data were available.

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The inspectors reviewed the licensee's shelf life program. A computer data base listed items in the warehouse that were in the limited shelf life

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i program.

Limited. shelf life material was. stored with other stocked material but was appropriately labeled. Material with expired shelf life was removed

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from stock monthly when indicated by a computer report.

Based on this method i

of control, the location problem previously noted has more significance since m

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material:might not be located.

.This program did not include many items that appearad to have limited shelf-life.: An inspector observed an item installed in tht: plant that was subsequently determined to have a limited shelf life, shich had been exceeded.

This matter is discussed further in Section 2.3.2.2 of dis report.

The inspectors reviewed a current printout of open, non-cutage M0s. A very low percentage of the M0s were identified as open due to parts that were not available.

None of the MOs on hold for parts were considered to have high-working priority or affect the ~ safe operation of the plant; however, as discussed in Paragraph 2.4.2.1 there were delays in performing some electrical

. PMs due to the unavailability of replacement parts.

= In general, established materials controls were good.

Evaluatiw: of replacement parts due to plant aging and vendor changes have played a signifi-cant and positive role in maintaining equipment at Big Rock Point.

2.3.4.3 Control and Calibration of Measurina and Test Eouioment (M&TE)

Control of M&TE was satisfactory for the small I&C department that included six technicians and a supervisor. Defective equipment was not segregated from-other equipment but was immediately sent out for repairs and calibration, usually to the corporate calibration laboratory. The laboratory maintained.

records and provided the plant with statements on the calibration records that the instruments were calibrated with instrumentation traceable to the National Bureau of Standards.

Controls of M&TE were stricter in the mechanical and electrical area than in the I&C area. -The mechanical and electrical shops had an M&TE and tool room, which was locked and only three people had keys.

Craftsmen were required to record the M0.n_ umber on an equioment list at the time the equipment was checked out.. Issuance of M&TE was based on the honor system in the I&c area.

Technicians. checked out equipment required for a M0 and documented the.

equipment number or the M0 on the attached procedure. 'The I&C supervisor then E

= documented the M0 numbers on an equipment list for the equipment used after-the~ MO was completed.

'2.4 Review and Evaluation of Maintenance Accomplished 2.4.1 Backloa Assessment and Evaluation The inspectors reviewed the amount of work accomplished. compared to the amount of work scheduled.

Emphasis was placed on work that could affect the o)erability of safety-related equipment or equipment important to safety, w11ch included some B0P components. Maintenance work item backlogs were evaluated for cause and impact on safety.

Both the corrective maintenance (CM) and preventive maintenance (PM) backlogs were assessed.

In evaluating the CM backlog, emphasis was placed on non-outage related work.

Overall, both CM and PM backlogs were very low and were well within the capabilities of the maintenance staff.

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Corrective Maintenance Backloa

~ The total backlog of non-outage CM was 41 including 13 electrical, 23-mechanical,- and 5 I&C. There were no outstanding items.that.affected the safe

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operation of the plant or had an adverse effect on plant availability. The l

amount of completed maintenance since January 1990 indicated an aggressive approach by the maintenance department to maintain a small overall backlog.

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The non-outage backlog could be eliminated in less than one week.

The number of M0s on hold for parts was very low.

The licensee did not have an engineering approved system for deferring cms; however, deferral or rescheduling required approval of the maintenance superintendent. The inspectors noted no significant cms which had been inappropriately deferred.

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2.4.1.2 Preventive Maintenance Backloa The' inspectors reviewed the backlog of both outage and non-outage PM items.

Results indicated a very low and well managed backlog in the mechanical and I

& C areas.

The licensee did not have an engineering approved PM deferral process.

If a-l FM needed to be. deferred, evaluation by the maintenance superintendent was the only requirement-for approval. As discussed in Paragraph 2.4.2.1 in the electrical area, PMs on molded case circuit breakers and 2.4 kV circuit breakers had been delayed and not scheduled because replacement parts could

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.not be obtained.

During the inspection, the past due PM items on the breakers l

were scheduled for the next refueling outage. Other PMs that were not.

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completed as scheduled had been rescheduled but were not listed as overdue on-the monthly report; however, none of the items had an impact on' plant system operability. Eroup supervisors were aware of the PM backlog; however, the backlog was not tracked. Management had not evaluated the backlog over

'3 previous months,- but because of the plant's small size and low number of backlogged PM items, this did 'not appear to be a significant problem. The work associated with the PM backlog was well within the capabilities of the current staff.

Although a few PM items were occassionally deferred, the inspectors noted that

' procedure PM 3.2.4, " Preventive Maintenance," Revision 2, did not describe the L

method or controls for deferral of PM.

The procedure was-silent on the l

methods used to control PM activites such as scheduling, adjusting schedule-

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periods, adding or deleting PM. items, and responsibilities for performing such

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In :ddition, the practice of delaying PM by as much as 25% was not addressed.

Except as noted in the previous paragraph, no hardware g

concerns were identified.

Licensee personnel agreed to revise the procedure to more securately describe the methods used to control PM.

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l 2.4.2.

Review and Evaluation of Completed Maintenance

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The purpose of this review was to determine if specified electrical,

. mechanical, and I&C maintenance on' selected systems / components was accomplished as required.

In'each maintenance discipline this review.

included one or more of the following:

Application of risk-based priority to the performance and intent of maintenance.

Evaluation _ of-the extent-that reliability centered maintenance (RCM) was factored into the established maintenance process.

Evaluation of the extent that vendor manual recommendations, NRC-Bulletins, (IEB), Part 21s, NRC Notices, Service Information Letters (SILs),:and other outside source information were utilized in the development and upgrading of the maintenance process.

Evaluation of the extent that outside source information, maintenance histories, LERs, negative trends, rework, extended time for outage,

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frequency of maintenance, or results of diagnostic examinations were analyzed for trends and root causes for modification of the PM process-to preclude recurrence of equipment or component failures.

Evaluation of completed CM and PM for use of qualified personnel,- proper prioritization, Quality Control (QC) involvement, quality _ of documentation for machir;ery history, description of-problems and resolutions, and post maicttnance testing.

Evaluation of work procedures for inclusion of vendor requirementt/

recommendaticns, QC hold points, acceptance criteria, ease of'use, engineering involvement / approval, and general conformance to NUREG/

CR-1369.

2.4.2.1 Past Electrical Maintenance The inspectors rev ewed seven completed electrical M0s.

.IFPS-8 - Test and inspect the diesel fire pump control panel-TR-62A-- Test RDS UPS "A" Battery Charger Capacity M085-SPS-0081 - Perform PM on bus tie breaker 52-OlA M087-CIS-0089 - Install new environmentally qualified (EQ) cable M087-EPS-0289 - Inspect and calibrate diesel generator relay M088-SPS-0052 - Calibrate 2.4 kV undervoltage relay M089-PIS-0001 Install heat shrink material on cable The M0s included a general description of the failure or problem and a rather detailed description of the work performed.

Post maintenance testing

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requirements =and criteria were s -

,ied on the M0s.

The licensee relied =

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heavily on " skill of the craft" t, accomplish effective maintenance.

Concerns

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identified with control of contractors and control of past due PMs are

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discussed below.

• M087-CIS-0089 - The licensee was unsure of the manufacturer's precautions and cable pull tension acceptance criteria or whether the maximum pull tensions were controlled or monitored. A review of vendor manuals indicated that the manufacturer had specific instructions to limit pull tensions for each size cable. However,-the licensee did not document the cable pull tensions or the arecautions required by the manufacturer. This was considered a wea(ness.

The inspector found that periodic tests were past due for 2 molded case

breakers since June 1988, and 16 tests were past-due sir.ce July 1989.

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The breakers were not shown as being past the scheduled due date because it is the licensee's practice to not write a M0 unless parts have been received or the outage backlog allows accomplishing the work.

Approximately 30 molded case breaker tests were scheduled to be

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performed during the upcoming outage. The licensee stated that because parts were not available and the molded case breakers may fail post maintenance testing (PMT), the M0s were not written.

There was no record that maintenance had ever been performed on the only

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2.4 kV circuit breaker (152-104). A PM schedule for.the 2.4 kV essential breaker was established in 1987; however, there was no record that any PM had been performed. The licensee stated that unavailability of parts caused the PM to be rescheduled several times.

Based on inspector concerns, the licensee agreed to perform the past due PMs on past due breakers during the upcoming refueling outage.

The licensee had not established PM for the four safety-related

inverters, which have been in service since 1977. A review of the

vendor manual indicated that periodic maintenance was recommended; but i

the manual did not specify a frequency.

Since 1983, the licensee has received information that dealt with the generic failure of inverters.

In particular, electrolytic capacitors have been singled out as a likely cause of inverter failures. The licensee contacted the manufacturer and was informed that the capacitors had a useful life of approximately ten years. There have been-no inverter failures at Big Rock; however, the licensee was reviewing this matter.

The inspectors reviewed the following four electrical maintenance procedures.

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PD-ll, " Test Procedure for Molded Case Circuit Breakers", Revision 8 PD-14, " Test Procedure for Types EC-1 and EC-2 Overcurrent Trip Device",

Revision 7 TR-84, " Emergency Diesel Generator Inspection and Repair", Revision 12 T90-09, " Core Spray Instrument Trip Test", Revision 13

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The procedures were generally satisfactory; however, the inspector noted that

i QC hold points were not-included in the procedures and vendor recommendations -

were not always-included or addressed.

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2'4'.2.2 Past Mechanical Maintenance

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The inspectors reviewed five completed mechanical M0s.

M089-CIS-0010 - Repair supply ventilation isolation check valve

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M089-CRD-0203 - Repair burst disc in D2 accumulator M089-CRD-0217 - Inspect CRD pump

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M089 CWS-0027 - Install propeller on No. 2 circulating water pump 9. -

M089-FWS-0051 - Repack No. 1 feed pump T180-01C - Local leak rate test (LLRT) of check valves In general, the inspectors noted that all the M0s reviewed were properly prioritized and completed in a timely manner. QC involvement was evident for corrective maintenance in safety related systems. However, concerns were identified with the quality of completed M0s.

Completed M0s did not require that complete work descriptions and

fa'. jure modes-be dccumented, particularly for non safety-related equipment. This hampered accumulation of good work history data.

Feedback on rework was weak, which hampered the determination of the

need.for training, more or different training, or revision of procedures.

The details of post maintenance testing were sketchy, which made it-

A difficult to determine what tests, if any, were done and:if acceptance criteria were met.

T180-01C - The inspector reviewed the local leak rate test-result of h

procedure T180-01C, " Personnel and Equipment Lock Powell-Check Valve Leak Rate," Revision 38, performed on-February 22,-1990.

The - scheduled 30 minute test was terminated after 6.5 minutes as specified in Section 5.1.of the procedure. The procedure required pressure readings to be taken every minute for 30 minutes or until 5 psig was reached. The local leak rate of 0.69 lbs./24 hrs appeared to be within the acceptance criteria of less than 2.0 lbs./24 hrs. These results were reviewed and accepted by the Operations Department on February 23, 1990.

The inspector reviewed the results and found that the licensee's method

.for. calculating the leak rate was based on the full 30 minutes and not the actual period of 6.5 minutes. The licensee recalculated the leak rate and found that the acceptance criteria was exceeded. The actual calculated leak rate was 3.18 lbs./24 hrs. The licensee repeated the

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t-LLRT on July 28, 1990, and the results were acceptable at 1.071bs./24

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hrs. - Although the second test was. acceptable, the review and controls

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to calculats and. accept the results of the LLRT were inadequate.

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Criterion.V of 10 CFR 50, Appendix B, requires that activities affecting s

quality be accomplished in accordance with instructions and procedures..

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Failure of the test originator and reviewing group to_ properly calculate

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and review the LLRT results is considered a violation (155/90010-01B)..

l The inspectors evaluated the extent that vendor recommendations, NRC Bulletins

and Notices, SILs, and other outside source information were utilized in the

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development of mechanical maintenance procedures. The folifWing procedures

were evaluated:

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MAP-26,

" Inspection and Repair of SMA-100 Single Torque Valve

Operators," Revision 0 MCRD-10, " Control Rnd Selector Valve Repair," Revision 13 MCRD-lf, " Prevent'ae Maintenance / Inspection of CRD Selector

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Valve CV NC19," Revision 9 MECS-9,

" Overhaul / Inspection of Emergency Condenser Inlet

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Va'ves," Revision 0 S

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" Inspection and Repair of Main Steam Isolation Valves" t

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MRDS-12, " Inspection and Repair of RDS Isolation Valves," Revision 0 The inspectors also reviewed vendor source documents.for selected mechanical

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components to determine if maintenance recommendations and requirements were

incorporated into maintenance documents. The vendor documents reviewed were:

l Anchor Da ling Valves - Swing Check Valves (ABC-V73-0), Revision 1973 Caterpillar Diesel Generator Engines (SEP-R507-01), Revision April

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1987

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Pacific Pumps - Feed Pumps (6LL-MS), Revision March 1986 l

Union Pumps - CRD Pumps-(IN-4100-1) Revision July 1961 l

Worthington Pumps - Service Water (2054-EI), Revision January 1960 l

j In general, the mechanical maintenance procedures were adequate, but some

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-provided inadequate details for maintenance. The licensee had initiated a

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procedure improvement program.and assigned the rasponsibility to a special

. group at the plant. Administrative Procedure 1.1.1, " Procedure Writer's Requirements and Guidelines," Revisica 1, was issued. The inspector reviewed

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a.-few maintenance procedures being revised in accordance with the-new

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n guidelines. lhe procedures were considerably improved in tecnnical content,

E inclusion of warnings / precautions, acceptance criteria, and data documenta-tion. The procedures included improved computer generated diagrams of the

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components being maintained.- Vendor manuals were properly controlled.

Some manuals, particularly those received several years ago, did not.have details about equipment maintenance. The maintenance procedures appeared to reference vendor manuals where appropriate.

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i Based on the review of completed M0s, Sacklog, work history of selected

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components, and maintenance procedures, the inspector concluded that past mechanical maintenance had been-accomplished in-a satisfactory manner.

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2.4.2.3 Past I&C Maintenance The inspectors reviewed seven I&C CM and PM M0s.

M089-JSM 0002 - Repair high range noble gas monitor M089-LPS-0033 - Troubleshoot liquid poison system problem M089-RPS-0021 - Calibrate reactor pressure sensors

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M090-LPM-0004 - Repair / Replace canal liquid process monitor l,

M090-MTE-0010 - Calibrate temperature and dew point cell M090.-PIS-0002 - Check calibration of containment sump level transmitters M090-PIS-0009 - Perform core spray instrument trip test

The instructions provided on I&C M0s were usually quite limited. The summaries-9f work performed were generally too brief to determine the root cause of the problem and provide adequate descriptions of the corrective actions: taken.

Post maintenance testing requirements, if required, were

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included in procedures referenced by the M0s; however, there was no reference

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on the M0 to the results of post maintenance tests.

The following seven I&C procedures were evaluated:

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ICRD-1, " Manual Reactor Control System Timing," Revision 8 ILPM-1, " Bench Calibration of Linear Meter," Revision 6-IMTE-8, " Bench Check and Calibration of Foxboro Temperature and Dew

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l Point Recorder," Revision 4 IRPS-1, " Calibration and Testing of Reactor Pressure Senwrs PS-RE0TDA, B, C, and D," Revision 10 IRVG-3, " Cleaning Nozzles on E/P-1A95 (Reactor Water I.evel)," Revision 4-TR-36, " Reactor Clean-up System High Temperature Pump Trip Test,"

Revision 10

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a Recorders," Revision 7

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The inspector identified a number of concerns with some of the I&C procedures

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as follows:

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IRPS-1 - The pr.cedure did not provide any instructions for the hcokup n

of calibration equipment and the required valve lineup of the system being calibrated. Also, the procedure required the back flushing of '

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sensing lines, but no instructions-were provided. However, the tasks described above were not complex and no' problems were identified that

. ere' attributed to lack of instructions. The licensee stated that these S

w actions were within the skill of the craft.

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IMTE-8 - The procedure required that temperature bulbs be placed in 32

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degrees F and 100 degrees F test baths, and that the temperature

readings be recorded but the test bath temperatures were not required-

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to be documented. A'so, there were no acceptance criteria specified for the bulb temperatures. The licensee agreed to revise the procedures to

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record the bath temperatures and~ provide acceptance criteria for the-bulb temperature readings.

l l-TR36 - Step 5.3 stated that the " Cleanup pump should tHp and alarm

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l annunciate when recorder cycles through Point No. 11."

There was no

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requirement to verify that the pump operated after being tripped-for

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testing.. The licensee agreed to revise the procedure accordingly.

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The : inspector reviewed selected vendor manuals for inclusion of PM recommendations in I&C maintenance procedures. Most of the vendor manuals

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L were old and did not contain PM recommendations. The following General L

- Electric (GE) vendor manuals were reviewed:

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p GEI Sr.31 - GE Power Switches

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GEI 56229 - GE Logic Units l

L GEI 56206 - Flux Amplifiers p

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In all cases the licensee either did.not have a procedure or the established

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procedure did not include steps to perform the maintenance-activities recommended by the vendor.. However, no problems'were identified because highly' skilled technicians performed the work.

L The inspector reviewed the current backlog of open I&C CM M0s. On August 6,

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- 1990, the CM nonoutage backlog was five with two awaiting parts.

No concerns-

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.were. identified with-the backlog.

The I&C department graphically trends as-found calibration data to provide

information on approximately 100 selected instruments in order to track instrument drift. The licensee used the information to determine the need to adjust instrument calibration periods. Many of these instruments have been-in l-the program since 1962.

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Based on the review of completed CM and PM backlogs, work history, procedures,

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IENs and observation of current activities, the inspectors concluded that I&C maintenance had been accomplished in a satisfactory manner.

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2.5 Maintenance Work Control The inspectors reviewed several maintenance activities to evaluate the

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effectiveness of the maintenance work control jrocess to assure that plant safety, operability, and reliability were maintained. Areas evaluated were

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enntrol of maintenane; work requests, equipment maintenance records, job i

planning, prioritiratdon and scheduling of work, control of maintenance

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backlog, maintenance procedores, past maintenance testing, completed docu-mentation, and review of work in progress.

The inspectors observed the daily morning meeting where plant operation and maintenance activities were reviewed by the plant manager and staff.

This meeting assured proper prioritization and availability of necessary resources

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for plant evolutions and major priority work. The inspectors concluded that this was an effective uthod of plant management oversight.

Administrative Procedure 3.2-1, * Maintenance Order Processing," Revision 10, was used to prepare, process, and implement a MO. This procedure contained the details for assignment of priorities, maintenance order review, and supervisory checks.

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Planning and scheduling of work in mechanical / electrical maintenance was done by any of the three supervisors in the department.

For non outage work, a three week schedule was prepared, discussed with all the other departments, and revised. weekly. A daily schedule was also prepared for ech week, which was updated daily.

For outage related maintenance tasks, adva.ce planning was made regarding availability of parts and personnel during the outeges, which lasted approximately 60 days every 13 months. A three week and daily work

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schedules were issued for outage related jobs too.

2.6 Enaineerino and Technical Support

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1he engineering department was dividea into five sections including l

electrical /I&C engineering, mechanical / civil engineering, special projects, plant performaace, and property protection.

The electrical /I&C section consisted of five engineers and a supervisor and the mechanica'/ civil section consisted of five engineers and a supervi:or. These two sections provided supprrt for engineering projects such as modifications, facilities changes, i

specification changes, and review of equipment failures.

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Some aspects of predictive maintenance had been initiated cuch as vibration analysis, pipe thinning analysis, infrared measurements of selected hot spots

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in electrical connectors in the substation and a limited oil analysis.

Vibration analysis was conducted on the emergency diesol generator and major pumps including circulating water and condensate pumps.

A probablistic risk nssessment (PRA) group was stationed on site but reported to the corporate general office.

The group consisted of a supervisor and

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three engineers.

This group was mainly involved in PRA studies for modifications but had not performed PRA studies for PM activities; however, this area could be included in the future.

Overall engineering support of maintenance appeared to be weak.

Examples of weaknes e were as follows:

The " system engineer" concept was not used. Those engineers involved in

interfacing with maintenance did not exhibit a sense of ownership.

Assignments to the technical staff, which involved engineering support of maintenance, appeared random.

The plant engineering staff did not conduct an overall survey of the

shelf life items in the warehouse. This contributed to the use of seals witt, expired shelf life to repair valves in the reactor depressurization system.

Results of vibration tests indicated that on some pumps the inboard

bearing vibration levels exceeded the first and second alarm levels, but i

no engineering invol' ement was noted.

In addition, the vendor was not contacted for advice to reduce the vibration levels.

The licensee did not adequately control electrial fuses.

Except for

recent design changes, most procedures and drawings did not contain.

information such as fuse ratings, types, proper sizes, or manufacturer type. Additionally, the licensee's corporate design office did not have the fuse size information either. Currently, fuses are changed *1ike for like" replacements. However, as previously stated, there was no information to determine the correct fuse size.

For example, the inspector observed twe different fuse sizes in the control circuits for the core spray valves, MO 7051, which had a 10 am) fuse, and M0-7061, which had a 6 amp fuse installed. According to tie schematic drawing,

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the control circuits for the valves were identical (the schematic showed one circuit for both valves). This was another example of a weak configuration management program.

Many of the system protection data setpoint sheets, which were

controlled dor.uments, had not been updated to reflect accurate component information.

For example, there were several insthces where the thermal overload size that was documented on the setpoint sheets did not reflect the actual size which was physically installed. The inspector found that for valves M0-7070 and M0 7071 the setpoint sheets were not updated to reflect the correct horsepower rating or thermal overload size, although the motors for these valves were changed about five years l

ago. The thermal overloads were bypassed during normal operation and as such the safety significance was low, however; the inspector's concern was the lack of accurate design information that did not reflect actual hardware conditions.

This was another example of weak configruation i

mangement.

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The inspector noted that the sensitivity to a de ground in the safety-

related statica battery system was significantly less than the ground

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detector for the auxiliary shutdown (ASD) batteries. The ASD batteries alarmed at 50,000 ohms but the station batteries alarmed at 6,000 ohms.

The inspector's concern was that the station batteries were not sensitive enough to pickup hard grounds on the order of about 20,000 ohms,and consequently'the potential for inoperable DC equipment existed.

m The issue of the sensitivity was previously raised by a staff engineer; however, the licensee has not taken followup action to attempt to resolve the engineer's concern.

The licensee did not trend individual component failures.

Corrective M0

his.ories were recorded on ecuipment history cards for plant systems.

Personal memories were reliec on to discern multiple component failures.

No action was taken on a 10 CFR 21 report issued by Limitorque on

November 3,1988, regarding common fa,ilure of melamine torque switches of specific Limitorque MOV model types and serial numbers. The cause of

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failure of the melamine torque switch was identified by the vendor as post mold shrinkage, which was caused by temperature and age. The licensee's representative stated that the report was not received from-the corporate office. The licensee requested and subsequently received a copy of the report and determinM that one MOV had such a torque switch installed. The valve was M0-7080, which is an alternate cooling water supply valve to the core spray heat exchanger. The licensee planned to replace the switch during the outage starting in September 1990. The valve had not failed its monthly operability test and since it was an alternate valve, continued operation until the outage was justified. However, failure to take timely corrective action to replace the torque switch after the 10 CFR 21 report was received in 1988, is an example of a violation of 10 CFR 50, Appendix B, Criterion XVI (155/90010-028).

2.7 Maintenance and Supoort Personne1 Jontrol The inspectors reviewed the licensee's staffing control and staffing needs.

Inspection activities included interviews with plant personnel, training facility observations, in plant observations and review of documentation.

The licensee had developed a compi-hansive plan for personnel control, which was procedurally implemented into ti,e aaintenance process and maintained by the training department. The organization chart was available; however, it was not always maintained up to date.

Selected personnel at various management levels were interviewed and were found to be knowledgeable of responsibilities and accountability. The staffing requirements for the maintenance department appeared to be adequate for non-outage work. The mechanical and electrical maintenance staff included 15 technicians and 3 supervisors.

The staff included one welder and two machinists.

Based on the very low backlog of work and low (10-15%) overtime used, the staff a>peared to be adequate. Management-labor relations ap) eared to be very good.

The ma'iatenance department was supplemented wit 1 contractor services during heavy work loads during outages.

Personnel training records showed that each plant employee, including

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contractor personnel, received site specific, security and radiological control training.

Refresher training in these areas was conducted on a regular basis.

The licensee also implemented specific task t'aining for contractors hired during outages.

2.8 Review of Licensee's Assessment of Maintenance 2.8.1 Audits and Surveillance The inspector reviewed reports of five quality assurance (QA) audits, nine surveillances, and four activity reports performed between March 1989 and July 1990.

For the QA audits and surveillances, there was a good mixture of

observation of performance of maintenance activities and verification that quality program requirements were being implemented. Qualified and experienced auditors were utilized to conduct audits and surveillances, l

Activity reports were issued for observation of activities, j

i The audits and surveillances identified a number of good findings and observations. An action item record was issued and used to followup on

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findings and observations.

The inspector reviewed some completed and j

partially completed action item records.

Generally, there appeared to be good response to findings and observations. However, one weakness was identified during this inspection regarding the inadequate documentation of work performed and what was found.

This was also identified by the licensee in audits since 1987, including QT-87-08, QT-88-04, QT-89 05, QT-90 03, QA 90 06, and in surveillance S-QB 90 06. Also audit QA-90-06 conducted in July 1990, noted weaknesses identified in the 1987 self-assessment that still required further enhancement. These items included work history, post maintenance testing, control of contaminated tools, planning and scheduling, and trending

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of root cause analysis. The slowness of correcting these audit findings was e

considered a weakness in management's attention to self identified problems.

2.8.2 Maintenance Self-Assessment.

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-The inspectors reviewed the report of the licensee's self-assessment of l

maintenance performed by a three member team from the Consumers Power Company general office. The team members had backgrounds in maintenance,

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organizational development, and QA. The assessment was performed in late 1987 and the raport was dated December 28, 1987.

The assessment included

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interviews, observation of activities on-going in the plant, and a review of policies, procedures, and other documentation. The assessment identified strengths and weaknesses.

Thirty-four weaknesses were identified.

Three of these that related to post-maintenance testing and procedures were still open. A tracking report for the status of improving the reaknesses is issued every six months.

It should be noted that post maintenance testing was identified as a weakness during this inspection.

3.0 Synoosis This synopsis highlights the inspection findings in terms that were meant to

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be representative of the presentation tree that is attached to this report. A-(+) means that the area is good or has the potential to be so; a (-) means l

that the area is weak or not fully developed.

3.1 Overall Plant Performance

3.1.1 Historic Data (+) Unplanned safety system actuations were zero for 1989 and 1990.

Safety system availability goals were reasonable, achieved and well within the plant i

goal s.

Plant availability goals were exceeded for 1989 and the first half of

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1990.

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l 3.1.2 Plant Walkdowns (+)

Plant management emphasized possible safety significance of hardware problems.

In many cases this resulted in a conservative approach to plant material condition.

Material condition was good, with most equipment well i

maintained and operational. High fluid system integrity was maintained as evidenced by the lack of liquid or steam leaks. Overall plant housekeeping was good, which was most noticeable inside containment and on.the turbine deck.

3.2 Manaaement Support of Maintenance 3.2.1 Manaaement Commitment and Involvement

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(+) Management addressed some repetitive component problems by using new and

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more reliable components. Management provided the funding and commitment for construction of a new maintenance building. The maintenance self assessment identified several significant performance related problems.

(-) Periodic maintenance was not performed on molded case circuit breakers and 2.4 kV circuit breakers because either spare breakers or part were not eva11able, and replacement of electrolytic capacitors in safety-related inverters was not properly addressed.

( -' ) Action was not taken to correct problems found in 1982 and again in 1988 with using items with expired shelf life; action was still pending to correct programmatic maintenance problems identified in 1987.

3.2.2 Manaaement Oraanization and Administration (+) A maintenance plan was developed which included milestones and complotion dates for improvement of program and goals.

3.2.3 Technical Support (+) Health physics personnel were involved in. maintenance planning and scheduling of maintenance activities, which enhanced aspects of Al. ARA.

Health physics personnel were experienced and very knowledgeable of work requirements.

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(+) A probabilistic risk assessment group had been established to determine the safety significance of systems or components as needed. QA audits of maintenance were performance oriented and resulted in the identification of

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significant maintenance problems.

Plant control of documents for maintenance l

appeared to be very good.

(-) Determination of components / equipment for inclusion in the PM program was not complete and the PM program procedure was silent about the deferral of PM

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items.

(-) Overall engineering support was weak in the areas of shelf life evaluations, bearing vibration analysis, control of fuses and setpoint data sheets, and communicating a 10 CFR 21 report to the site about possible torque i

switch problems in motor operated valve operators.

Calculations were improper for determining the acceptability of a LLRT test.

(-)

Electrical schematics and wiring diagrams for the diesel were not compatible; testing and documentation were inadequate for a EDG modification.

(-) Corrective action was untimely for findings identified during QA audits l

in selected instances.

(-) A spill occurred because maintenance drained potentially radioactive

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water into an inaapropriate container (plastic shoe); improper planning

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resulted in a wor ( area being established in a 10 mrem area when an adjacent 2 mrem area was available.

3.3 Implementation of Maintenance

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3.3.1 Work Control l

l (+) The work priority system appeared to be working well; none of the

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open maintenance orders appeared to be significant. The maintenance backlog

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was very low..

(+)

Electrical and mechanical craftsmen were well qualified in the area assigned.

The senior 1&C technicians were very knowledgeable and well i

qualified.

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(-) Design documents were not followed in the wiring of the diesel generator and electrical records do not reflect the actual wiring of the diesel generator.

No records or drawings were onsite for the back up diesel.

Periodic electrical tests and inspections of molded case breakers and 2.4 kV

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circuit breakers were not performed due to lack of replacement parts.

(-)

Procedures were not followed in evaluating LLRT data.

Inadequate documentation of work performed was noted in a number of work packages and the method for specifying post maintenance testing on M0s appeared weak.

(-)

Procedures were weak in the areas of controlling preventive maintenance, a post modification test of a diesel generator modification, and I&C procedures did not always contain adequate instructions.

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(-) The tracking system for PM backlog and maintenance reports did not

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accurately address past due PM items. Contractor control and involvement by plant personnel was limited in the area of cable pulls; plant personnel were i

not familiar with what the contractor did or how it was done.

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3.3.2 Plant Maintenance Oraanization (+) The experienced, highly skilled and dedicated maintenance staff was

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considered to be the most significant strength.

There appeared to be

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excellent coordination of maintenance activities between maintenance and supporting groups. Close coordination was maintained between operations and the I&C maintenance group in order to keep plant equipment operational.

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(+) ALARA was enhanced by use of a number of tool boards which had a wide selection of standard tools set up in contaminated areas to reduce or

' eliminate the necessity to leave the area for tools.

(+) Maintenance utilized some aspects of predictive traintenance such as vibration analysis and thermography to determine equipment deterioration.

I&C maintained calibration graphs of a significant number of installed plant instrut'ents to determine trends in instrument drift.

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(-) No inethod was in place to track and control rework and several maintenance jobs performed during the inspection were not satisfactorily repaired during the first attempt. Trending of repetitive failures is based on the memory of the maintenance superintendent.

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3.3.3 Maintenance Facilities. Eauipment. and ilaterial Control (+) Construction of new and enlarged maintenance facilities was nearing completion.

(-) All limited life materials were not included in the limited shelf life

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program.

The computerized system for material storage locations had errors; 3/14 reviewed were incorrect.

3.3.4 Personnel Control

(+) Turnover in plant personnel was very low; maintenance personnel were experienced, well qualified, and trained for the work performed.

This included craftsmen and supervisors.

4.0 Unresolved Items Unresolved items are matters about which more information is required in order to -ascertain whether they are acceptable items, violations, or deviations. An unreso Wed item disclosed during the inspection is discussed in Section 2.3.2.1 of this report.

5.0.

Exit Meetina

The inspectors met at the Big Rock Point Nuclear Power Plant with licensee

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representatives (denoted in Paragraph 1)'on August 17, 1990, to summarize the purpose, scope, and findings of the inspection. The inspectors discussed the likely infomational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee

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did not. identify any such documents or processes as proprietary, i

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APPENDIX &

ACRONYMS

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i AIR Action ltem Roquest ALARA As low As Reasonably Achievable i

BOP Balance of Plant l

CM Corrective Maintenance i

EDG Emergency Diesel Generator (System)

E0R Equipment Outage Request t

EQ Environmental Qualification

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HP Health Physics

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I&C Instrument & Control

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IL3 NRC Bulletins IEN NRC Information Notices i

KV Kilo Volt

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LER Licensee Event Reports

LLRT Local Leak Rate Test MCB Molded Case Breaker M&TE Measuring and Test Equipment l

M0 Maintenance Order MOV Motor Operated Valve NPRDS Nuclear Plant Reliability Data System NRC Nuclear Regulatory Commission PE Prevan',1ve Maintenance NT Post Maintenance Testing PRA Probabilistic Risk Assessment QA Quality Assurance QC Quality Control RCM Reliability Centered Maintenance RDS Reactor Depressurization System RP Radiation Protection

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RPS Reactor Protection System RWP Radiation Work Permit SALP Systematic Assessment of Licensee Performance i

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