IR 05000220/1991022
| ML17056B544 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/15/1991 |
| From: | Baunack W, Blumberg N, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056B543 | List: |
| References | |
| 50-220-91-22, 50-410-91-21, NUDOCS 9112030134 | |
| Download: ML17056B544 (24) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220/91-22 50-410/91-21 Docket No.
50-220 50-410 License No.
Licensee:
Facility Name:
Inspection At:
DPR-63 NPF-69 Nia ara Mohawk Power Cor oration 301 Plainfield Road S racuse New York 13212 Nine Mile Point Units 1 and
Scriba New York Inspection Conducted:
October 7-11 1991 Inspectors:
ib... ) Ce'Ol ~x~
W. Baunack, Sr.
Reactor Engineer Performance Programs. Section Operations Branch, DRS
// jcj da e
A. Finkel, Sr.
Reactor Engineer Performance Programs Section Operations Branch, DRS date Approved by:
Norman Blum erg, Chief Performance Programs Section Operations Branch, DRS date Ins ection Summar
Inspection from October 7-11, 1991 ( Inspection Report Nos.
50-220/91-22 and 50-,410/91-21.
to review the status of maintenance program weaknesses identified during the Maintenance Team Inspection, Report Nos.
50-22/88-80 and 50-410/88-80.
9112030134 911120 PDR ADQCK 05000220
Results:
The licensee's tracking of items resulting from the Maintenance Team Inspection (MTI) made it difficult to determine the actions which were taken to resolve identified weaknesses.
However, for the limited number of items which were reviewed, adequate actions appear to have been taken to improve these areas.
The MTI identified 23 weaknesses.
Three weaknesses had previously been closed; nine were reviewed and closed during this inspection, and one was reviewed and remained open.
A total of ll MTI identified weaknesses remain ope DETAILS 1.0 Persons Contacted 2.0 Attachment 1 provides a listing of. persons contacted during the inspection.
~Back round A Maintenance Team Inspection (MTI) was conducted at Nine Mile Point from November 28, 1988, to December 9,
1988.
As a result of that inspection, three unresolved items, twenty-three weaknesses, and certain observations were identified in the MTI Report.
The licensee responded to four of the 23 weaknesses by letter dated March 11, 1989.
The three unresolved items and three of the weaknesses were closed during routine resident inspections.
During this inspection, the inspectors intended to review the licensee's actions relating to the remaining twenty weaknesses and the observations described in the MTI Report.
The inspectors also intended to follow-up in certain areas in which the licensee was in the process of making improvements, during the MTI, which the team had considered in making their findings.
An effort was made by the licensee to identify the actions which licensee management considered appropriate to close out the weaknesses identified
.
i,n the MTI Report.
During this effort, it was noted that the licensee's tracking system used in 1989 made it difficult to identify these corrective actions.
Nevertheless, the licensee made a serious effort to search the tracking system and/or reconstruct actions taken to r'esolve the weaknesses.
Due to the length of time the'se efforts took, only ten weaknesses were reviewed during this inspection.
The documentation reviewed to verify items described in this report are listed in Attachment 2.
3.0 Licensee Trackin S stems As a result of difficulties experienced by the licensee to determine actions which had been taken to resolve weaknesses and observations identified during the MTI, the procedures the licensee currently has in place to process events or conditions which require tracking were reviewed.
No effort was made by the inspectors to identify the reason for the tracking
.
system difficulties which originated in 1989.
The licensee had two current procedures (identified in Attachment 2) for the tracking of commitments, events or conditions.
Both of these procedures had recently undergone major rewrites as an effort to improve the tracking process and as a result of a reorganization.
These revisions were dated March 1991 for the Nuclear Commitment Tracking System and July 1991 for the Deviation Event Report Procedur A review of these procedures indicated that the current method appeared to adequately document and track to completion both regulatory and nonregulatory matters which require tracking.
Since these procedures were recent, the licensee will have to make a determination of their effectiveness based on experience with their use.
The inspectors had no further questions relating to this matter.
4.0 Maintenance Team Ins ection Weaknesses A weakness was defined as a potential problem or condition presented for licensee evaluation and corrective action as applicable.
The weakness numbers were those assigned in the MTI Report, Appendix 3, Summary of Weaknesses, and refer to the paragraph and page number in the MTI report in which the weakness was discussed.
4.1 Weakness I
P
"Paint Flakin with Pieces U
to 3" Dimension on 'the Reactor Vessel Pedestal and Pi in in the Lower Level of the Or well.
What Corrective Actions and Anal sis are Re uired to Assure that Core and Containment S ra S stems Will Work as Desi nated?"
The licensee responded to this item by letter dated March 11, 1989.
This inspection verified that the actions described in the letter had been
, taken.
The licensee performed an inspection of the drywell
~
As a result of this inspection, the licensee decided to recoat the drywell dome, interior of the reactor pedestal area, and pedestal floor with an epoxy coating.
The work request, MWR 00658, which accomplished this task, was reviewed.
Also reviewed were the safety evaluation for the task, the 50.59 review, and gA surveillance reports performed during the coating installation.
Based on this review, the inspectors determined that the portions of the drywell stated in the response letter have been recoated.
The MWR which accomplished this task was completed on January 29, 1990.
The licensee also committed to change the Drywell Closeout Inspection Surveillance Procedure to include inspections of drywell paint by May 1, 1989.
This commitment date was missed due to the tracking problems discussed above.
However, Procedure NI-MSP-GEN-R024, "Drywell Accessible Interior Surfaces Inspection" was completely revised to include an internal surfaces inspection on December 7,
1989.
Based on the above, this weakness is considered close.2 Weakness II. 3.0 P
"No Written U
er Mana ement Polic or Directive on Conduct of Plant Maintenance" Weakness II. 2.0 P13 Mana ement Su ort of Maintenance:
Controls to Initiate Actions are Not Well Defined.
The Decision-Makin Process to Define What Needs to be Done is Missin Si nificant Items Includin Pro er Evaluation of Information from Outside NMPC Nine Mile Point Cor oration The MTI noted that,
"The licensee's program for station maintenance is currently addressed in various administrative and department procedures and instructions.
Organizational layout, personnel responsibilities, duties, and accountability are described in various maintenance department documents including flow charts and matrices.
However, no formal corporate directive defining a maintenance policy has been established."
To more clearly define the maintenance policies, Nuclear Division Directive (NDD-MAI), "Maintenance,"
was issued in April 1991.
This procedure had defined the requirements for development and execution of a maintenance program and had assigned responsibility for implementing the requirements.
In reviewing the guidance for preventive and corrective maintenance;,
use of maintenance procedures, maintenance documentation and history; and use of the nuclear plant reliability data system (NPRDS).
The inspectors determined that the directions in NDD-MAI were incorporated into these lower tier documents.
The inspector verified that additional implementing documents to support the NDD-MAI procedure were entered and tracked in the Nuclear Division Procedure Matrix.
Based on the above, this weakness is considered closed.
Weakness II. 3.0 and II. 4.7 P15
"Evaluate the Number of 0 erational Events Assessment OEA 0 en Items.
'he MTI noted that,
"The licensee has established methods for reviewing, tracking and implementing information from NRC Bulletins, Information Notices and Generic Letters; INPO SOERs and SER documents; and vendor information letters.
The Operating Events Assessment (OEA) group within Technical Support is responsible for proper dissemination of information and development of appropriate corrective action.
However, the OEA files indicated substantial delay in closing out the items and as a result a
considerable backlog has developed."
Also, "With recent organization changes, the regulatory documentation responsibilities of licensing has been transferred to the newly created Nuclear Regulatory Compliance Group (NRCG).
This group maintains the Nuclear Tracking System (NCTS) used to track internal and external commitments...,
implementing procedures for the Regulatory Compliance Group are still in the draft form.
Incoming documents such as Information Notices ( IN's), Significant Events Reports (SER's),
and Service Information Letters (SIL's) are processed by the Operating Assessment (OEA) Group utilizing a separate tracking system.
Implementing procedures for the OEA group are currently in draft form."
Implementing procedures have now been developed.
Administrative procedure AP-3.4.2 Revision 05,-"Operating Experience Assessment,"
had been approved by Unit 1 and 2 Plant Managers o'n January 31; 1991.
This AP established the responsibilities and controls to evaluate lessons learned from both external and internal operating experiences and this AP also directed the Quality Assurance organization to implement the program for facilitating the assessment of operating experiences, verifying the adequacy of corrective actions, and monitoring actions to improve the stations administration, operations, and maintenance.
To implement the Quality Assurance Program, Quality Assurance Procedure (QAP) 15.02,
"Assessment of Operating Experience,"
Revision 2, was issued July 23, 1991.
Procedure QAP 15.02 defines the responsibilities and procedures to be used in performing the operating experience assessment program.
The inspectors reviewed the, operating experience (QE) reports QA91-Ul-413 for Unit I and QA91-U2-533 for Unit 2.
These monthly reports did comply with the procedure requirements defined in AP-3.4.2 and QAP 15.02 for assessing operating experience information.
Based on the above information, this weakness is considered closed.
Weakness II.4.5 P 20
"For ALARA Im lementation A
Generic Set of Maximum Tem orar Shieldin Loads for Various Pi e
Sizes and Pi e
Su ort Locations is Not in Use.
4.5 The MTI Report indicated the licensee intended to evaluate the feasibility of providing generic guidelines to the Radiation Protection Group for the placement and use of temporary shielding.
This item was correctly tracked in the tracking system as "Establish Temporary Shielding Guidelines, Item No. 4.5 (P 20), Inspection 88-80."
The item was closed by the licensee based on Procedure No. S-AIP-1,
"Temporary Shielding" having been issued'
review of this procedure showed Attachment 10.4 of the procedure
"Pre-approved Installation Guidelines" identified as
"To Be Issued Later."
In this instance, the item was correctly tracked but was closed out without the action having been 'completed.
This was another example of problems experienced with the tracking system discussed in paragraph 3.0 which existed in 1989.
Currently, Site Engineering is tasked with the development of Generic Temporary Shielding Guidelines.'ased on the fact that this task has been assigned to engineering, this weakness is closed.
Weakness 11.4.6 P 23
"Root Cause Anal sis and Ste s to Reduce Relativel Hi h Industrial Safet OSHA Accident Rate Rate Re ui re Follow-u
.
'uring the MTI, the site lost time accident rate was five times the industry average.
DuPont's Safety Training Observation Program (STOP)
had been provided to management a'nd first line supervisors.
In response to the trend of increasing lost time accidents, a problem analysis was conducted in December 1988 using Kepner-Tregoe Methodology.
This analysis identified certain probable causes for the increase in lost time accidents and provided management with various recommendations.
Following the completion of the analysis, the principles of the STOP Program were disseminated to workers at manager and worker safety meetings conducted to
stress safety.
Also, Administrative Procedure AP-3.2 "Industrial Health and Safety" has been issued and provided direction for a General Safety Committee, the Conduct of Safety Meetings, Safety Training, and Safety Inspections.
Since the MTI, the overall trend in lost time accidents has i'mproved to just slightly above industry average.
Based on the above, this weakness is considered closed.
4.6 Weakness II. 4.6 P 23
"In the Area of Industrial Safety, No Listin is Available to Identif Confined S ace Locations and These Areas are Not Clearl Identified in the Plant."
The MTI noted that control of confined space entries had not been formally addressed in that procedures for confined space entries were only in draft form and a list of confined space locations was not available.
To address this issue, the licensee had,issued Administrative Procedure AP-3.2.2,
"Confined Space Entry Program."
The purpose of this procedure was to establish minimum requirements and standards for the health and safety of personnel involved in confined space entry.
To facilitate implementation of this procedure, the Occupational Safety and Health (OSH)
Department provided the maintenance planners training in the use of this procedure.
One of the requirements of this procedure was that the OSH Department maintain and regularly publish the Confined Space Entry List.
This list had not been published.
In place of this list, a log was being maintained which identified every confined space entry permit which had been issued.
It was intended that the required Confined Space Entry List be prepared from this log.
,Management, upon being made aware that the list was not being published regularly as required, initiated a Deviation/
Event Report to correct the condition.
Management determined that the identification of confirmed spaces in the plant was not needed.
The licensee had taken action to resolve this matter; therefore, this weakness was considered closed.
Weakness III.5.0 P 27 and III.7.0 P 39
"Trackin S stem for Calbrated Mechanical Tools is Not as Com lete as That'or Calibrated Electric Tools.'he MTI noted that, "During a field walkdown and inspection of the mechanical tool storage area, the inspector observed that the mechanical tool log appeared to be informal.
The inspector also observed that tools in the log were signed out past the return due date.
In addition, there were a limited, number of tools in the field which were not in compliance with the applicable condition procedures (i.e., lifting cables, grinders, slings).
It was also observed that there was no recall program for mechanical tools being signed out for use in maintenance activities."
To improve this area, the licensee issued administrative procedure AP-5,3. 1, "Control and Calibration of Measuring and Test Equipment,"
and maintenance instruction procedure. S-MAI-5.3.005, "Identification and Location of Special Tools."
These documents described the controls and methods to be used for issuance and control of test equipment.
The inspectors verified that the tool room personnel established a tool/device index system for maintaining tracking of their assigned items.
Also, training was given to the 'personnel on the requirements of their procedures.
, In addition to the above procedure, AP 3.3.6,
"Control of Contaminated Tools," was iss'ued to provide guidance on establishing segregation of contaminated/noncontaminated and restricted area tools.
The licensee also established permanent tool custodian positions to address the requirements of procedures AP 5.3. 1 and AP 3.3.6.
Based on the above findings, this weakness is considered closed.
4.9 Weakness III 5.0 P 31
"Number of Work Re uests Bein Held for "Other Reasons."
Identif Cause For. Dela and Correct The MTI noted that,
"As of December 2,
1988, there were 1104 WRs open for maintenance work, and an additional 501 WRs on hold for post maintenance testing (PMT).
Of the 1104 open WRs, 155 WRs are on hold because of a lack of parts and 222 WRs are being held for other reasons."
The licensee developed a backlog measuring program that lists'the backlog status for each department on a weekly basis.
In addition, the weekly report listed the reason the item was on the backlog list and the subject code describing the present status.
As an example, code NC indicated that the nuclear chemistry group was holding up the item.
Similar codes were developed for other Unit 1 and Unit 2 organizations.
In addition to listing *the codes for each item on the backlog list, the charts indicated the total number of late PMs and the number of late safety-related PMs.
The date and age of the safety-related PMs was also listed in this weekly backlog status report.
The inspectors verified that both managers and supervisors use the data 'of this report in planning their daily work loads.
The backlog has been reduced to a controlled level with each item on the list identified with a code key.-
Based on the above information, this weakness was considered adequately resolved.
Weakness III.6.0 P 36
"The S stem En ineerin A
roach as Su ort to Maintenance Im lementation Has Not Been During the MTI, the team noted that the formation of a system engineering organization was planned and that this should help'-to improve the interface between off-site engineering and the site organizations.
The inspectors found that the licensee has put into place a'system engineers group at both Unit 1 and Unit 2.
Implementing procedures for both groups were issued.
In addition, a site engineering group was established at each unit; this was stated to have greatly improved communications between the on-site and off-'site engineering organizations.
For Unit 1 the existence
of a system engineers responsibility matrix was verified. 'This matrix was available to the control room personnel.
Additionally, discussions with I[nit 1 control room personnel showed that the system engineers concept.was working well.
This item is considered closed.
5.0 Conclusion Although the.tracking system in place in 1989 failed to adequately track the items identified during the NTI,'t appeared that actions had been taken to resolve each of the 'issues.
Due to the difficulty experienced in determining the actions taken by the licensee to resolve each of the issues, only some implementation of their actions could be verified.
Overall, based on the limited review, it appears the actions taken have been adequate to resolve the issues.
Licensee management was informed of the scope and purpose of the inspection at the entrance meeting conducted on October 7, 1991.
The findings of the inspection were discussed periodically with licensee representatives during the course of the inspection.
An exit was conducted on October 11, 1991, at which time the findings of the inspectors were presented.
Attachments:
1.
Persons Contacted 2.
Documents Reviewed
0-
'
10-ATTACHMENT 1 PERSONS CONTACTED Nia ara Mohawk Power Cor oration
~ K. Dahlberg, Manager Unit I
- M. Goldych, Site Licensing T. Hogan, Supervisor ALARA
- M. McCormick Jr.,
Manager Unit 2
- J.
Pavel, Engineer Licensing T. Picciott, General Supervisor System Engineers NMP-1
~ K. Sweet, Maintenance Manager NMP-1 E. Todd, Industrial Hygienist
- R. Watson, General Supervisor Maintenance Support NMP-2 J. Weagraff, Supervisor Industrial Safety United States Nuclear Re ulator Commission
- R. Laura, Resident Inspector
- W. Schmidt, Senior Resident Inspector
- R.
Temps, Resident Inspector During the course of this inspection, the inspectors contacted other members of the licensee's technical and administrative staffs'
Denotes those present at the exit meeting held on October 11, 199 e ATTACHMENT 2 DOCUMENTS REVIEWED Administrative Procedures AP-3.2, AP-3.2.2, AP-3.3.6, AP-3.4.2, AP-5.F 1, Industrial Health and Safety, Rev.
05, April 15, 1991.
Confirmed Space Entry Program, Rev.
01, April 29, 1991.
Control of Contaminated Tools.
Operating Experience Assessment,,
Rev.
5, January 1991.
Control and Calibration of Measuring and Test Equipment, Rev.
March 1991.
Nuclear Division Directives NDD-MAI, Maintenance, Rev.
00, April 1991.
Nuclear Division Procedure Matrix Tracking System, Report for October 9, 1991.
ualit Assurance Procedure QAP 15.02, Assessment of Operating Experience, Rev.
2, July 1991.
e Maintenance Instructon Procedure S-MAI-5.3.005, Identification and Location of Special Tools, Rev.
00, December 1989.
Maintenance Surveillance Procedure NI-MSP-Gen-R024, Drywell Accessible Interior Surface Inspection, Rev.
01, December 7,
1989.
Mana ement Re orts Quality Experience Assessment Reports, Unit 1, QA91-Ul-413 for October 1991.
Unit 2, QA91-U2-533 for October 1991.
NCTS Commitments 503376-02, April 1991 File Code NMP 77579.
Unit 1 Weekly Backlog Report, October 4, 1991.
Unit 2 Weekly Backlog Report, October 7, 1991.
ALARA Im lementin Procedure S-AIP-1, Temporary Shielding, Rev.
1, January 23, 1990.
Nuclear Division Interfacin Procedure NIP-ECA-01, Deviation Event Report, Rev.
3, August 12, 199 Nuclear En ineerin and Licensin Procedure NE2-501, Nuclear Commitment Tracking System, Rev.
2, March 1991.
Technical Su ort Instruction N2-TSI-1.0, System Engineering Program, Rev.=0, March 30, 1991.
Technical De artment Instruction Nl-TDI-4, System Engineering Program, Rev.
2, April 15, 1991.
System Engineers Responsibility Matri ~ i