IR 05000271/1987018

Insp Rept 50-271/87-18 on 870824-28.No Violations or Deviations Noted.Major Areas Inspected:Maint Program & Implementation,Including Administrative & Maint Procedures, Trending Program,Records & Preventive Maint Program

ML20235Z522
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	10/05/1987
From:	Blumberg N, Prell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235Z518	List: IR 05000271/1987018 ML20235Z515
References
50-271-87-18, NUDOCS 8710210183
Download: ML20235Z522 (10)

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'U.S. NUCLEAR REGULATORY' COMMISSION

REGION I

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Report No.

50-271/87-1.8 i

~ Docket N'o.

50-271 License No. pPR-28 I

Licenzee:

Vermont Yankee Nuclear Power Corporation Brattleboro, Vermont 05301

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Facility Name: Vermont Yankee Inspection At:

Vernon, Vermont Inspection Conducted: August 24 - 28, 1987

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Inspectors:

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f Jame* Prell, ReactoF ' Engineer, ddAe /

Approved by:

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Norman Blumberg, Chief

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date Operational Programs Section, 08, DRS Inspection Summary: ' Routine Unannounced Inspection on August 24-28, 1987, (Report No. 50-271/87-18)

Areay Inspected:

Routine unannounced inspection of licensee's maintenance l

program and implementation, including administrative and

maintenance procedures, maintenance trending program, maintenance records, preventive maintenance program, maintenance experience levels, and Quality Assurance program interface.

Results:

No violations or deviations were identified.

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8710210183 871009 PDR ADOCK 0000

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Persons Contacted Vermont Yankee

H. Atkins, Assistant Maintenance Foreman

• P. Donnelly, Maintenance Superintendent W. Finnel, Maintenance Foreman J. Golonko, Maintenance Technician

• R. Grippardi, Quality Assurance Supervisor

• S. Jefferson, Assistant to Plant Manager

• R. Lopriore, Maintenance Supervisor

• J. Pelletier, Plant Manager C. Rose, Plant Mechanic

• R. Wanczyk, Operations Superintendent The inspector also held discussions with other licensee personnel during the course of this inspection.

• Denotes those present at the exit meeting on August 28, 1987.

Nuclear Regulatory Commission Bill Raymend Senio-P.esident Inspector, Millstone 2.

Maintenance Program 2.1 References The following references were used:

ANSI N45.2-1971, Quality Assurance Program Requirements for

Nuclear Power Plants, Section II4 ANSI N18.7--1976, Administrative Controls and Quality Assurance

for the Operational Phase of Nuclear Power Plants, Section 5.2.17.

ANSI N45.2.6-1973, Qualifications of Inspection, Examination

and Testing Personnel For Nuclear Power Plants.

10 CFR Part 50 Appendix B, Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants, i

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2.2 Program Review

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A review of the licensee's administrative procedures, maintenance procedures, maintenance requests, completed maintenance work files and "Visi-card" system was made to verify the following:

That the maintenance program was being implemented in

accordance with regulatory requirements; That the maintenance program being implemented was effective;

That the capabilities of the staff were sufficient to conduct

an effective maintenance program.

The procedures listed in Attachment A and the maintenance equests (MRs) listed in Attachment B were reviewed.

2.3 Program Implementatig 2.3.1 Procedures

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A review of the procedures listed in Attachment A verified that the licensee has established:

A program for initiating requests for preventive

maintenance (PM) and corrective maintenance (CM)

activities; A program for review and approval of all maintenance

requests (MRs);

Criteria and responsibilities for designating

maintenance activities as safety related or non-safety related; Criteria and responsibilities for the performance of

inspections of maintenance activities;

Provisions for identifying and controlling inspections

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of maintenance activities; Methods and responsibilities for functionally testing

equipment receiving maintenance prior to returning it to service-t

A program for reviewing completed maintenance

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activities to determine any further component post j

maintenance testing requirements;

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A program for controlling special work' activities

• related to maintenance such as welding, jumper / lifted

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leads'or, shielding / scaffolding. requirements; A program for placing equipment in.or out of service.

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prior to'(or following) maintenance activities-

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l A program for controlling.PM: activities of j

i safety related and non-safety related equipment; l

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i A program for general housekeeping which includes

. defining housekeeping-zones and controlling-housekeeping during maintenan'ce activities';

A review of the Maintenance Department's program for controlling' vendor manuals was made.. Current vendor manuals are labeled with.a sticker and filed in filing cabinets. New drawings or vendor manuals are-reviewed by the maintenance engineer and when applicable, are i

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substitued _for existing vendor information., The inspector

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verified that maintenance procedures-reference the

' appropriate manuals and drawings and that all current vendor manuals were properly filed and identified with stickers.

2.3.2 Trending Program The licensee.in 1985 established a~ trending program of CM activities related to major systems. Annually, a. report is prepared identifying those systems whose CM activities exceeded a statistically. established limit. The inspector reviewed the annual reports'for 1985 and 1986.

In addition,:a review of the maintenance history records was made to verify the identified trends and that few repeat CM activities were required.

The inspector expressed concern that the trending program did not identify increased failures / maintenance of major subsystems or.

components.

The licensee had recognized.this and,~ prior to this outage, established increased maintenance data requirements which must be included in each work package file.

It is expected that this data will provide -

sufficient information to establish maintenance trends of subsystem components.

The inspector reviewed the work packages listed in Attachment 8 and verified the new trending data was included.

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2.3.3 Records The inspector, while reviewing the work packages listed in Attachment B, also verified they contained the following types of information:

Housekeeping considerations;

Closeout inspection information;

Environmental qualification information and data

sheets; Equipment failure and probable cause summary sheets;

Material issue forms; and,

Independent inspection information.

• 2.3.4 Preventive Maintenance (PM) Program The PM program was reviewed. The inspector determined that the iicensee had a master schedule for identifying all required PM activities and a tracking system for identify-ing overdue PM activities. All overdue PMs are listed and sent to the Maintenance Foreman on a monthly basis.

The Foreman however, has no formal program for final disposition of these overdue PM activities. A review of the previous month's list indicated that approximately 95%

of the overdue PMs had already been properly dispositioned.

The inspector witnessed PM maintenance activities related to the motor operated valve analysis tests (M0 VATS) of valve V13-39, MR87-1959.

This valve is one of two valves located on the suction side of the Reactor Cooling Isolation Cooling (RCIC) system pump.

It was verified that:

Approved procedures were used;

Maintenance personnel were knowledgeable and

experienced; Required administrative approvals had been obtained;

Limiting conditions for operation were met;

Maintenance records were assembled;

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Measuring and test equipment was identified and in

Calibration; System lineups were made and verified prior to

initiating maintenance activities; and, General housekeeping practices were observed.

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2.3.5 Experience Levels

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The experience level of maintenance personnel was reviewed.

l Maintenance management personnel, assistant foreman and l

higher, have between 10 to 15 years experience with the i

company. At the mechanic level, all mechanics have had three to five years experience in their field prior to joining the licensee.

Most mechanics had between three to ten years with the licensee.

2.4 Findings In implementing the independent inspection program, the Maintenance Department was found not to be in full compliance with AP6025.

AP6025 states that activities are classified according to their complexity and significance as either major or minor.

AP6025 also states that independent inspections are required for all safety related work classified as major.

For activities classified as minor, independent inspections are required at a frequency determined by the Plant Manager.

However, the Maintenance Department does not classify their activities into major or minor categories.

Instead, they review all proposed maintenance activities and select for independent inspections a percentage of those activities which appear more significant.

During this outage, the frequency was about 22%.

This percentage will drop when the plant resumes normal operations.

The licensee informed the inspector that they were having problems implementing this portion of AP6025 and that it was now under revision to remove the major and minor categorization requirements.

The failure to classify major or minor maintenance activities in accordance with procedure AP 6025 is considered a violation of 10 CFR 50 Appendix B and ANSI N18.7.

However, since this deficiency was identified by the licensee and corrective action was in progress, this is considered a self identified violation which meets the criteria of 10 CFR 2, Appendix C.

This item is considered unresolved pending completion of licensee corrective actions and subsequent NRC review of revised AP 6025 and its implementation to verify that sufficient and appropriate independent inspections of safety related maintenance activities are being performed (UNR 50-271/87-18-01).

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3.0 Quality Assurance / Quality Control (QA/QC) Interface Program 3.1 QC Inspections A review of the licensee's recently implemented " independent inspection" program was conducted.

This program is designed to have co-workers perform QC type of inspections for work activities performed by their department. The program for assuring that these

" independent" or " peer" inspectors have independence from direct supervisory controls is defined in AP-6025, " Quality Control /

Independent Inspection."

The inspector reviewed the QC Inspection Log and determined that approximately 22% of all safety related maintenance activities occurring during this outage were independently inspected - 79 out of 362.

It was also verified that those which were inspected were those activities having more safety significance. Due to manpower constraints during outages, the licensee uses ANSI N45.2.6-1971 Level II contractor certified QC inspectors to perform certain independent inspections. A review of the resumes of five of these inspectors verified that they were properly certified and qualified.

During normal operations, the licensee plans on reducing the number of independent inspections to 5%.

Independent QC inspectors then will be chosen from rnaintenance workers outside the group responsible for performing the maintenance activity.

The inspector reviewed the following inspection reports:

M87-039 - MSSV Replacement;

M87-041 - Reactor Vessel;

M87-051 - MSIV Inspect Guide Rods;

M87-076 - RHR SW, P8-1C; and,

M86-155 - Rebuild of CRD SN #A6935.

• Discussions were held with maintenance management concerning the independent inspection program and management's involvement.

Based on this review, it was determined that management is reviewing and taking appropriate action on all findings identified by the independent inspectors.

3.2 QA Surve111ances The QA surveillance program, as related to the maintenance programs was also reviewed.

This program is implemented by a Yankee Atomic Electric Company Quality Assurance Group located on site.

Discussions were held with the QA Supervisor and Vermont Yankee plant I

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personnel._ QA Surveillance reports 87-2, "RHR Pump Inspection and Repair", and 87-60, " Review of Maintenance Program in Accordance with

.AP0200", were reviewed. Although not reviewed during this

inspection, it was noted that surveillance had also been performed concerning AP 6025 activities.

Based upon the above, the following observations are made:

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Good communications seem to exist between the various plant

departments and the YAEC QA group.

This is evidenced by the

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fact that the various departments are requesting QA's assistance in looking into specific areas of their program ar.d the monthly meetings being held between the QA group and each department.

The QA surveillance chechlists are much more detailed than in

past years and provide the auditor with more flexibility by providing the regulatory basis for the item and what the auditor should look for.

The auditor in turn provides a detailed paragraph on what he looked at rather than a simple yes or no response. As a consequence, surveillance are more in depth and more significant findirgs are being identified than in past years.

During a QA surveillance of the Reactor Engineering Group, QA

noted a deficiency in the implementation of AP 6025.

Corrective for this deficiency was implemented for all groups using AP 6025.

Performing the corrective action led to the Maintenance Group identifying the violation of AP 6025 which is detailed in paragraph 2.4 concerning lack of categorization of majer or minor work categories.

No violations or other deficiencies were identified.

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Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violations.

An unresolved item was identified during this inspection and is detailed in paragraph 2.4.

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Exit Interview The inspector met with licensee representatives on August 28, 1987, to summarize the scope and findings of this inspection.

At no time during this inspection was written material provided to the licensee by the inspector.

The licensee did not indicate that any proprietary information was contained within the scope of this inspectio A.

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ATTACHMENT A

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VERMONT YANKEE PROCEDURES REVIEWED

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AP0200, Rev. 10, Maintenance Program

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.AP6025, Rev. 1, Quality Control / Independent Inspection a.

0P5203, Rev. 12, Inspection and Testing of Shock Suppressors

OP5201, Rev. 3, Safety System Valves

OP5220, Rev. 8, Limitorque Operator Inspection

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OP5223., Rev. 6, Emergency Diesel Generator Maintenance I

AP0021,.Rev. 15, Maintenance Requests

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Genaric Procedure for Baseline Testing Limitorque MOVs Using the

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MOVATS 2100 or 2150 System, 4/21/87 (Rev. 1)

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ATTACHMENT B MAINTENANCEREQUESTS(MRs)WORKPACKAGESREVIEWED MR87-0308 Inspect Containment Air Valve C4-898/or Corrosion - OP5201.

MR86-2062 10" Flange' Leak Upstream from MGLO-27-A Below MGLO-901A.

MR87-0088-

. Moisture Separator B Level Column Isolation Valve V-66-201B, has a steam packing leak.

MR87-0352 Perform Removal, Functional Test and Reinstallation of Snubber RHR-H183 per OP5203.

MR87-0353 Perform Removal, Functional Test and Deinsulation of Snubber RHR-H193 per OP 5203.

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MR87-1279 RHR SW, P8-16.

MR87-1390 MSIV Inspect Guide Rods.

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OP4201 MSSV Replacement.

MR87-1959 Perform M0 VATS Test, Set Limits and Thrust as specified by Engineering.

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