IR 05000255/1991007
| ML18057A899 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/07/1991 |
| From: | Burgess S, Choules N, Jablonski F, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A898 | List: |
| References | |
| 50-255-91-07, 50-255-91-7, NUDOCS 9105150002 | |
| Download: ML18057A899 (11) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/91007(DRS)
Docket No. 50-255 License No. DPR-20 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Covert, Michigan Inspection Conducted:
April 2.2-26, 1991 Inspectors:
Sf-. Q. qrucy,Slf-s. rJ. Mrgess
!/),( ~
N. C. Choules 1-tZ~
Approved By: 7-'----~/----'* *~*~~~-'--G--'-1\\.~~-' * __
_ * Jablonski, Chief Mainten'ince and Outages Section Inspection Summary *
sb/91 I Da'te Inspection on April 22-26. 1991 (Report No. 50-255/91007(DRS)).
Areas Inspected; Routine, announced inspection of maintenance activities using selected portions of Inspection Module 62703 to ascertain whether maintenance was effectively accomplished and assessed by the license Results:
Based on the items inspected, overall performance in maintenance was considered goo Strengths relating to maintenance were the involvement of system engineers in the maintenance process, the System Performance Monitoring program, and the rework progra No significant weaknesses were noted. * No violations or open items were identifie ~888~55 PDR ADOCK PDR Q
- DETAILS Principal Persons Contacted Consumers Power Company
- G. B. Slade, General Manager, Palisades Plant
- R. B. Kasper, Maintenance Superintendent
- R. E. McCaleb, Quality Assurance Director
- R. D. Orosz, Engineering Manager
- J. C. Petro, Quality Engineering Supervisor
- L. J. Ross, Mechanical Maintenance Supervisor
- G. L. Smith, System Engineering, Performance & Component Supervisor
- D. G. Turner, Electrical/I&C Maintenance Supervisor U. S. Nuclear Regulatory Commission
- J. A. Isom, Senior Resident Inspector, D.C. Cook Plant
- Denotes those present at the exit meeting on April 26, 1991.
Other persons were contacted as a matter of course during the inspectio.0 Licensee Action on Previous Inspection Findings (Closed) Open Item (255/87027-04) - Inadequate post modification testin Procedure 5.19, "Post Maintenance Testing," Revision 0, was written and provided criteria for the selection and documentation of post maintenance testin Although targeted for maintenance, the procedure guidelines were used for testing modification The inspectors reviewed completed work orders (WO) and determined that the specified post maintenance testing for modifications and maintenance was appropriate, verified that the original deficiency had been corrected, and no new deficiency had been create This item is close (Closed) Open Item (255/87027-06) - No preventive maintenance was specified for a flex hose modification ort the electro-hydrualic control (EHC) syste Periodic and Predetermined Activity Control (PPAC)
activities were implemented to replace the EHC hoses every 18 month Review of the PM for the EHC system indicated that the scope was appropriate, and followed vendor recommendations and the system's work histor The inspectors also verified that PPAC activities were required to be evaluated when modifications were mad This item is close (Closed) Open Item (255/87027-07) - Lack of QC involvement in modifications of high reliability system The licensee revised procedure 9.03, "Facility Change" and specified that QC/QA may be required for modifications of this natur The inspector reviewed recently completed modifications on the feedwater heaters and the main condense Both modification procedures, I-FC-875.0l; "Replacement of
FW Heaters" and I-FC-875-02, "Replacement of Main Condenser E-10" had several QC hold point This item is close (Closed) Violation (255/87027-08) - Current procedural requirements were not met for work packages issued more than a year prior to starting wor The inspector reviewed licensee actions *taken to correct this problem including those described in the response letter dated January 28, 198 Op December l, 1987, Engineering and Maintenance Department Policy Memo 87-009 was issued and required a review of planned WOs more than 9 months old to ensure current requirements were include WOs older than 90 days were tracked and a report was issued and reviewed monthly to expedite work or provide additional planning as necessar Discussions with licensee personnel indicated that job planners were familiar with this requiremen WOs reviewed during this inspection were completed to current requirement This item is close (Closed) Violation (255/88020-0lA) - A 10 CFR 50.59 applicability evaluation was not performed on temporary modification 88-05 The inspector reviewed licensee actions taken to correct this problem inlcuding those described in the response letter dated February 17, 198 A safety review was completed for this modification as required by Administrative Procedure 9.31, "Temporary Modification Control".
Conclusions indicated no change to the facility was involve The inspector reviewed a sample of temporary modifications and noted that appropriate 10 CFR 50.59 evaluations had been complete This item is close (Closed) Violation (255/88020-0lB) - Instances where three conductors on one terminal point had not received required engineering approval The inspector reviewed licensee actions taken to correct this problem including those described in the response letter dated February 17, 198 The licensee performed configuration control walkdowns of cabinets and identified all terminals with three conductors and evaluated acceptabilit The inspector verified that all terminals with three conductors in Panel C-11-S had appropriate engineering evaluation This item is close (Closed) Violation (255/88020-0lC) - Required procedures were not at maintenance work sites or in the work order packages during modification wor The inspector reviewed licensee actions taken to correct this problem including those described in the response letter dated February 17, 198 Administrative Procedure 9.02, "Facility Change" was revised to address the control of field documentation use during modification Although no modification work was observed, the inspectors witnessed eight maintenance activities and noted that, in all cases, required procedures and work order packages were at the work sit This item is close (Closed) Violation (255/88020-0lD) - Work steps were not signed off when modification work was performed as require The inspector reviewed licensee actions taken to correct this problem including those described in the response letter dated February 17, 198 Procedure 8-2.13,
- .1
"Modification and Maintenance Work at Palisades" was revised to include the requirement for timely signoffs of procedµre step The inspectors observed eight maintenance activities and noted that required steps were signed as complete in a timely manne This item is close (Closed) Violation (255/88020-0lE) - Authorization was not obtained to perform work out of sequence during a facility chang The inspector reviewed licensee actions taken to correct this problem including those described in the response letter dated February 17, 198 The Engineering Design Change (EDC) process is now used for all changes in the sequencing of activities defined in the modification proces Although no modification work was observed, the inspectors witnessed eight maintenance activities with no instances of out of sequence work performe This item is close (Closed) Violation (255/88020-0lF) - All prerequisites for performance of work and work steps for completion of work were not accomplishe The inspector reviewed the licensee actions taken to correct this problem including those described in the response letter dated February 17, 198 The inspectors reviewed 20 completed WOs and witnessed eight maintenance activities in progres All had pre-job briefings and adequate turnover from ~revious shift This item is close Evaluation and Assessment of Maintenance The purpose of this inspection was to evaluate and assess the accomplishment and effectiveness of maintenance activities at Palisades Nuclear Generating Plan The inspection was performed while the plant was at powe The evaluation and assessment were accomplished by observations of material condition and maintenance work activities; review of the implementation of corrective maintenance (CM), preventive maintenance (PM), and predictive maintenance programs; review of
~ompleted CM and PM activities; and evaluation of maintenance backlog The inspectors also assessed the quality verification process related to maintenance, which was accomplished by review of audit and surveillance reports for implementation of corrective action, and review of documents such as discrepancy records and Licensee Event Reports (LERs) to verify that corrective action was implemente Results of the inspection are documented in the following sections:
Accomplishment of Maintenance The inspectors evaluated and assessed maintenance by observation of maintenance activities, assessment of the maintenance backlog, and review of the maintenance program, which included CM, PM, and preventive maintenanc. Observation of Maintenance Activities The inspectors observed ongoing work in electrical, instrument and control (I&C), and mechanical maintenance area These activities were selected from the weekly planner and through disc~ssions with individual foreme Where possible, safety significant activities were chosen.for follow u Maintenance act{vities were observed to determine if those activities were adequately performed and were in accordance with required administrative and technical requirement Work activities were assessed in the following areas as necessary:
work control and planning; management presence and involvement; quality control presence and involvement; procedure availability, adequacy, and use; personnel training and qualification; material availability; measuring and test equipment (M&TE) application and calibration; and post maintenance testing adequacy including proper acceptance criteri The inspectors observed portions of eight maintenance activities as described below:
WO 24100602 WO 24100937 WO 24101487 WO 24101573 WO 24102105 WO 24102189 Test Ml-SA Test MI-39 Calibrate control boards for the boric acid heater system Perform PM on switchyard breaker 29R8 air compressor Rebuild clean waste distillant pump, P-97A Replace packing on charging pump, P-55A Calibrate power range Exo Core drawers NI-5, 6, 7, and 8 Troubleshoot and repair boric acid heater system controller, TICA-0450B Perform surveillance MI-SA, "Containment High Pressure Test" Perform surveillance MI-39, "Auxiliary Feedwater Actuation System Logic" The inspectors concluded that the maintenance and surveillance activities in the areas inspected were adequate and were accomplished by skilled maintenance personne System engineers, especially in the mechanical maintenance area, were very involved with troubleshooting and repair activitie General concerns were noted with the reliance on I&C technicians to overcome procedure weaknesses as discussed belo WO 24102105 - Procedure NMS 1-7, "Dual Linear Power Channel Tilt Adjustment," Revision 11, referenced drawer test points that did
3.1. 2 3.1. 3
not correspond to the actual test point To compensate, numbers had been previously marked in the drawers to match the procedur Because of experienced technicians, the calibration was performed correctl The licensee was in the process of making the actual points and procedure correspon WO 24102189 - The WO provided no instructions on the instruments needed or how to connect the instrumentation to perform the calibratio The licensee relied on the skill of the technician to perform these task Although the calibration was performed correctly and without incident, the instrumentation connections were fairly complicated and warranted detail in the procedur Maintenance Backlog Assessment and Evaluation The inspectors reviewed the amount of work accomplished compared to the amount of work schedule The review emphasized w9rk that could affect the operability of safety related equipment or equipment important to safety, which included some balance of plant (BOP) component Overall, both CM and PM backlogs were controlled and within the capabilities of the maintenance staf The total backlog of non-outage CM WOs, based on a report dated April 15, 1991, was 649, which represented approximately 9 weeks of wor None of the backlog items appeared to affect the safe operation of the plant or have an adverse effect on plant availabilit There were 63 WOs on hold for parts, none of which appeared to be safety significant or have any adverse effect on critical equipmen Although some CM was occasionally rescheduled, the inspectors noted no significant CM wo~k that had been inappropriately delaye There were only three overdue PM items, which indicated that the program was well managed and controlled, with attention given to PM completio Both CM and PM backlogs were lower than normal since a substantial amount of maintenance was performed during the recent steam generator replacement outag All backlog information was tracked to provide management with maintenance performance indicators and allowed the detection of adverse trends in backlog level Review of Maintenance Program The inspectors reviewed specific equipment and systems to determine if electrical, mechanical, and I&C maintenance was accomplished as require This review included:
Review of completed maintenance
The extent that engineering organizations supported the maintenance proces The extent that RCM was factored into the maintenance process
3.1. The extent that vendor manual recommendations, NRG Bulletins, NRG Notices, and other outside information was utilized in the development, correction or upgrading of the maintenance process The extent that outside source information, maintenance histories, LERs, negative trends, 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 failure Review of Completed Maintenance The inspectors reviewed approximately 20 safety related/important to safety WOs for. completeness, accuracy, and technical conten Some of the specific areas evaluated were adequacy of work instructions, engineering and technical support in the resolution of concerns identified during the performance of the work, and documentation of work performe The inspectors concluded that the WOs were generally satisfactory in scope and conten The inspectors noted that work performed on safety related work was well documented and thoroug Post maintenance testing was completed and appropriat Concerns noted on the WO were.resolved or followed up with another W As discussed in Section 3.1.1, I&C maintenance relied more on the skill of the technician than on detailed work instruction.1. Engineering and Technical Support The licensee had established an effective system engineering departmen System engineers were involved in all aspects of the maintenance process including problem resolution, root cause analysis, PM determinations, and system performance monitoring._ This involvement resulted in a definite sense of system ownershi Communication between maintenance personnel and system engineers appeared goo Maintenance personnel did not hesitate to contact engineering for assistance or resolution of problem.1. Preventive Maintenance Program Preventive maintenance activities were managed under the Periodic and Predetermined Activity Control (PPAC) program and included safety and non-safety related equipmen PPACs were based on vendor recommendations, actual plant experience, and applicable codes and regulation The program was kept current by a periodic review of equipment maintenance history performed by engineering or the maintenance staf Any changes made to PPACs were technically justified and evaluated by the appropriate system enginee The inspectors concluded that the PPAC scope was appropriate and contributed to the continued reliable and safe operation 0£ equipmen Palisades implemented a pilot Reliability Centered Maintenance (RCM)
program for the diesel generators and the compressed air systems.
. 7
Failure modes effects analysis and fault tree analysis techniques determined critical component The licensee was in the process of comparing the recommendations of the RCM results and the current PM,.
surveillance, and predictive maintenance program Plant management was supportive of the RCM progra.1. Predictive Maintenance Predictive maintenance was satisfactorily implemented and provided good information for assessing the condition of plant equipment and initiating needed maintenance prior to equipment failur However, inaccuracies were noted in portions of the predictive maintenance program described in Procedure EM*30, "Plant Predictive Maintenance Program", Revision EM-30 required that vibration monitoring, lubricating oil analysis, and infrared thermography (when indications of problems were noted) be performed on selected plant pumps considered important to plant safety or operatio Good maintenance practice would require that vibration monitoring and lubricating oil analysis be performed on the entire motor or turbine pump assembly rather than just the pum The inspector noted, however, that vibration and lubricating oil analysis were performed on both the pump and pump motor rather than only the pump as specified in the procedur EM-30, Attachment 1, required an analysis of the charging pump lubricating oil at least semi-annuall Licensee personnel stated that this activity was discontinued due to excessive cos Instead, the oil was periodically changed, which was a satisfactory PM method; however, this was not as effective as the oil analysis for determining pump and motor conditio A procedure change was initiated during the inspection to remove the requirement for oil analysis of the charging pumps from the procedur EM-30, Section 5.3.1.p, referenced work instructions WI-EPS-E-01 and WI-SPS-E-01 for specific direction in performing infrared thermography; neither had been issued for us Also, no procedure or instruction was provided for performing vibration analysi Infrared thermography and vibration analysis were performed by trained personnel ut"ilizing. "skill of craft" technique Quarterly System Performance Monitoring Reports provided another predictive maintenance too These reports, performed on all systems, tracked system performance indicators such as system component*
availability, system contribution to lost generation, pump and valve packing life, leak rate trending, and other parameters unique to the syste All system performance indicators had a targeted goa On a yearly basis, corrective and preventive maintenance monitoring was performed to identify system components requiring significant or frequently recurring maintenance activitie The program was well 8...3 implemented and considered a strength in identifying adverse component trend Effectiveness of Maintenance The inspectors determined the effectiveness of maintenance by evaluating the material condition and housekeeping of the plant, the amount of rework performed, and reports such as LERs and deficiency reports related to maintenance activitie Material Condition/Housekeeping Overall plant housekeeping and material condition were considered goo Considerable housekeeping improvements were noted in the boric acid pump are Except as noted below, equipment problems identified by the inspectors had been identified by the licensee's work request (WR)
progra None of the problems noted appeared to have *safety significance or have a significant effect on the operation of the plan The material condition appeared to maintain operability of components at a level commensurate with the components' functio Service water pump P~7C had a significant packing lea The inspectors learned that biweekly packing inspections and adjustments were performed with an open W The pump was already scheduled to be inspected and adjusted, if required, later that da Four non-safety related pumps in the auxiliary building were not identifie The licensee was aware of a weakness in equipment identification and had an ongoing component identification improvement program in plac The licensee appropriately identified the pumps prior to completion of the inspectio Review of Maintenance Rework The licensee's rework program was considered a strengt A repair related to previous maintenance made to a component within a nine month period was considered rewor The program provided root cause analysis of rework/recurring maintenance work issue Because the rework program was viewed positively, the efforts improved department performance as well as minimized component/device/system failures, which improved plant performanc The total rework improved from less than five percent in 1989 to less than two percent in 199 This program, coupled with system performance monitoring, resulted in a comprehensive evaluation of a system's "health".
Licensee Assessment of Maintenance (Quality Verification)
The inspector reviewed audit reports and corrective action documents to evaluate the licensee's quality verification proces The documents were reviewed for root cause analysis, timely corrective action, technical assessments, and justification for close out of corrective
3..0 action document Review of Audits and Surveillances Maintenance audits and surveillances were perf~rmance oriented with an appropriate balance between observation of work and verification that quality program requirements were implemente Four QA audits and thirty-four surveillances were performed in 199 Corrective actions were adequate and responses generally timel Conclusions Based on inspection activities described in this report, the inspectors concluded that:
Maintenance and surveillance activities were adequate and were accomplished by skilled maintenance personne General concerns were noted with the reliance of I&C te*chnicians to overcome procedure weaknesse *
CM and PM backlogs appeared to be well controlled and were well within the capabilities of the maintenance staf None of the backlog items appeared to affect the safe operation of the plant or have an adverse effect on plant availabilit *
System engineers were involved in all aspects of the maintenance process, which resulted in a sense of system ownershi PM scope was appropriately based on vendor recommendations, actual plant experience, *and applicable codes and regulation System Performance Monitoring Reports coupled with the rework program resulted in a comprehensive evaluation of a syste.m' s
"health".
Both programs were effective.in identifying adverse component trend *
Overall plant housekeeping and material condition were considered goo Considerable housekeeping improvements were noted in the boric acid pump are Maintenance audits and surveillances were performance oriented with an appropriate balance between observation of work and verification that quality program requirements were implemente Exit Meeting The inspectors met at Palisades Nuclear Generating Plant with licensee representatives (denoted in Paragraph 1) on April 26, 1991, to summarize the purpose, scope, and findings of the inspectio The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the
inspectio The licensee did not identify any such documents or processes as proprietar