IR 05000277/1988017
| ML20207L410 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/06/1988 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207L383 | List: |
| References | |
| 50-277-88-17, 50-278-88-17, NUDOCS 8810170287 | |
| Download: ML20207L410 (82) | |
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V. 5. NUCLEAR REGULATORY CCMMISSION REGION !
REPO.
NO. 50-277/SS-17 50-278/55-17 DOCKET NO.
50-277 50-278 LICENSE NO.
OPR-44
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LICENSEE:
Philadelphia Electric Company
2301 Market Street
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,l Philadelphia, Pennsylvania 19101 FACILITY NRME:
Peach Bottom Atemic Poner Station Units 2 and 3 iN5FECTION CCNDUCTED: July 11 - 22, 1983
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TEAM MEMBER:i:
W. H. Baunack, Project Engineer, CRP, Region I T. F. Dragoun, Senior Radiation Specialist, DRSS, Fegion 1 A. E. Finkel, Senior Reactor Engtreer, CRS, Region I E. H. Girard, Reactor Inspector, CR5, Regicn !!
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E, H. Gray, Senior Reactor Engineer, DRS, Region I, Team
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Leader J. P. Janko ich, Senior Operations Engineer, NRR
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G. Napuda, Senior Reactor Engineer, DRS, Region 1 5. A. Reynolds Reactor Ir.,pector, DRS, Region !!!
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R. J. Urban, Resident Inspector, Peach Ecttom Atomic Pc.er Station, CRP, Region I H. A. Walker, Reactor Inspector, CRS, Regicn !!!
AFPROVED BY:
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[f P. Curr, Engineering Eranch Chief (cate)
Division of Reactor Safety INSPECTICN:
Srecial announced Team Inspection on July 11-22, 1955 (~5fF277/e!-17; 50-27S/S5-17).
l AREA 5 INSFECTED:
A.i in-depth team inspection of the Feach Bottom raintenance program and its implementation was perforred.
The inspecters used the NRC raintenanca inspection guidance in Temporary Instruction 2515/97, dated Jane 1953.
RESULTS:
Overall, the raintenan:e program and its 1.mplementation were fcund te be adequate.
Areas of strengths and weaknesses were icentified and are discussed in the executive su-ary.
Four violations were noted,
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TABLE OF CONTENTS PAGE NO.
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E x e c u t i v e S umm a ry..................................................
Inspection Findings I.
Overall Plant Performance Related to Maintenance..............
1.0 D i re e t M e a s u r e s..........................................
II.
Management Support of Maintenance.............................
2.0 Management Com.mitment and Involvement....................
3.0 Management Organization and Administration............... 18 4.0 Technical Suppc......................................... 28
- II. Maintenance implementation................................... 38
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5.0 W o r k C o n t r o 1............................................. 3 8 6.0 Plant Maintenance Organization...........................
7.0 Maintenance Facilities, Equipment and Materials Control.......................................
8.0 Personnel Contro1........................................
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Appendix 1 - Pre Inspection Requested Information Appendix 2 - Persons Contacted Figure 1 - Maintenance Inspection Tree
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EXECUTIVE SUMMARY BACKGROUND The Nuclear Regulatory Commission considers effective maintenance of equipment and components a major aspect of ensuring safe nuclear plant operation and has made this area one of the NRC's highest priorities.
In this regard, the Commission issued a Policy Statement dated March 23, 1938 that states, "it is the objective of the Commission that all componer.ts, systems and structures of nuclear power plants be maintained so that plant equipment will perform its intended function when required.
To accomplish this objective, each licensee should develop and implement a maintenance program which provides for the periodic evaluation, and prompt repair of plant components, systems, and structures to ensure their availability."
To ensure effective implementation of the Commission's maintenance policy, the NRC staff is undertaking a major program to inspect and evaluate the effectiveness of licensee maintenance activities.
This inspection was one of three pilot inspections performed in accordance with newly developed guidance provided in NRC Temporary Instruction 2515/97, Maintenance Inspection Guidance, dated June 1988.
The temporary instruction includes a "Maintenance Inspection Tree" that identifies for inspection the major slements associated with effective maintenance.
CONDUCT OF INSPECTION The maintenance inspection at Peach Bottom was initiated with a site meeting on June 1, 1988, where the inspection scope including the maintenance inspection tree was discussed. At that time a list of requested site specific information was submitted to Philadelpnia Electric Company (PECo).
This information request is shown in Appendix 1 to this report. A comprehensive pre-inspection submittal of information based on this request was provided to the team by PEco on June 23, 1988.
The NRC inspection team spent the two weeks from Juae 27 to July 8, 1938 in the NRC office preparing for the inspection and examining the information submitted by the licensee.
Tha team conducted an onsite inspection at the Peach Bottom site from July 11 to July 22, 1988.
The inspection was directed toward observation of maintenance work in progress at the site and licensee activities support #ng this work including angineering, training ind management. Maintenance activ'tiet selected for detailed review included equipment identified by the plant ry sific probabilistic risk assess-ment (pRA) as having significant input to cc * damage accident sequences or to the reduction of the risk associated with plant operation.
Other components and maintenance activities were selected for inspection based on recent failures of safety related equipment, special interess items, and NRC inspector experience.
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Daily meetings were held by the NRC Team Leader with Plant Maintenance Supervision to summarize the inspection team findings and identify areas where additional information was required. On the af ternoon af July 21, 1988, a communication session was held for each NRC inspector to present significant findings to PECo management.
The summary of the inspection team findings including a presentation of an evaluated maintenance inspection tree, was discussed with licensee representatives including management, supervisors and engineers at the July 22, 1988 exit interview (see Appendix 2 for attendees).
RESULTS Figure 1 is the maintenance inspection tree completed by the inspection team for Peach Bottom Units 2 and 3.
As indicated in the figure, the inspection team evaluated three major areas:
(I) overall plant performance as affected by maintenance; (II) management support of. maintenance; and, (III) maintenance implementation. Under each of these major areas, elements considered important for proper function of the area were inspected.
For each element, the inspectors evaluated both the program and how effectively the program is implemented.
During the current shutdown, numerous changes have been made in licensee management and programs at Peach Bottom.
The plant organization and procedures affecting maintenance activities have and are continuing to undergo significant change. Where changes made were recent but not fully implemented, the inspectors evaluated the pre-change conditions and appraised the expected effects of the change.
OVERALL PLANT PERFORMANCE AS AFFECTED BY MAINTENANCE There were insufficient performance measurement data under the new m intenance organization and programs to effectively evaluate current overall plant perfor-mance as affected by maintenance.
However, the inspectors did determine that the licensee's program currently tracks, or will track in the future, appropriate performance indicators to allow an evaluation cf the ef fectiveness of mainte-nance activities.
The inspectors also concluded that the new management at Peach Bottom is fully dedicated to a strong maintenance program.
The effects of management and program changes will not be reflected in the performance indicators until approximately six months to a year of operation is accrued.
MANAGEMENT SUPPORT OF MAINTENANCE The maintenance organization receives adequate technical support from the other licensee organizations and it appears that a defined interf ace system has been established and is being monitored by management.
All levels of management were found to be committed to significantly improve maintenance activities, and improvements have recently been implemented, are in orogress or planned for the near future.
Several weaknesses were identified by the NRC during the inspection.
In addition, the licensee had identified other areas
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for improvement during a self assessment conducted prior to the NRC inspection.
This indicates continued involvement and strong commitment by management is necessary to achieve the desired performance level.
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The predictive maintenance status summary for vibration monitoring of rotating equipment, dated May 31, 1988 identified 22, Unit 2 and 15, Unit 3 components requiring evaluation and work to reduce the possibility of failure during the next year.
Resolution of the rotating equipment vibration monitoring results with appropriate maintenance or repairs is considered to be of significance for licensee completion.
The team noted work in this area to be in progress during the inspection.
MAINTENANCE IMPLEMENTATION The licensee has established an acceptable work control program.
Work is being prioritized and scheduled in accordance with system windows. Backlog controls have been established with review and approval for all deferred maintenance required. Adequate procedures have been provided and completed work packages are being reviewed.
Improvements in certain areas such as main-taining work history and equipment performance records as well as improved guidance for post maintenance testing are planned. A review of identified weaknesses indicated the need for maintenance work procedures and instructions
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used by the craft including maintenance technicians to continue to be improved.
Improvements to be made include showing numeric values (temperature, pressure, bolt torque requirements, etc.), indicating where specific sequences of work orerations are required and reducing unnecessary verbiage while providing the worker with the information necessary to perform the task properly commensurate with previous training and skill level.
The improvement of working procedures requires a continuation of feedback between those using the procedures and procedure writers with input from engineering.
An adequate maintenance organization has been established.
Certain maintenance activities such as the MOV rebuild program were noted as being well controlled. Work performed by large contractors was effectively controlled; however, a problem was identified in the control of a small contractor.
An adequate deficiency ident'fication system has been implemented.
A system of maintenance trendin ind evaluation has been established and support of mainte-nance by other organizations is functioning well.
The site has adequate facilities for the conduct of maintenance.
An increased spare parts inventory and added warehouse space as well as improvements in j
maintenance shops are being considered.
Overall the licensee's material controls program is acceptable although minor deficiencies associated with storage practices were identified.
Tool and equipment control is satisfactory, with only minor concerns noted.
Satisfactory control and calibration of metering and test equipment is being provided.
A considerable effort has been made to improve plant housekeeping and procedures are in place which require senior plant management to remain involved in the effort.
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The licent:e's staffing controls are generally well established with a low turnover rate being experienced.
The management policy is to not tolerate poor performance or the use of drugs.
Training programs and their implementa-tion are well established and documented, with a test and qualification process in place.
Added job descriptions are being prepared and an organizational streamlining is planned.
MAINTENANCE INSPECTION TREE One objective of the inspection was to indicate by colors (green, yellow, or red) on the maintenance inspection tree, the teams conclusion of the status of the plant maintenance for each block on the tree.
The upper left of each block indicates how well the topic of the block is included in the plant maintenance program including procedurer.
The lower right hand portion of each block indicates the team conclusion as to the effectiveness of implementation of the intent of the topic covered by that block.
Green indicates that the program is essentially complete or that the program implementation is effective.
However, even for blocks shaded green, some areas for improvement may be indicated in the report.
Yellow indicates a marginal but acceptable condition and red indicates the topic is missing or the intent of that portion of the tree is not being met by the maintenance activities.
Blua indicates the item was not evaluated or could not be properly evaluated due to recent changes.
The mainte-nance inspection tree as completed by the team is attached to this report as Figure 1.
The inspectior team conciuded that the Peach Bottom Plant has developed a maintenance program that implements the significant attributes of the mainte-nance tree.
The team identified a number of strengths ana weaknesses that are discussed in the report. Weaknesses are po'.ential problems or conditions presented for licensee evaluation and corrective action as applicable.
As weaknesses were identified by the inspection team n. embers, they were presented to licensee representatives for initial revies and evaluation during the course of the inspection.
Individual items of weakness are discussed in appropriate arets of the report.
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INSPECTION FINDINGS The inspection findings are presented to correspond with the inspection topic blocks on the maintenance inspection tree.
This portion of the report is intended to outline what wa examined, what was found in the site program and implementation, and the conclusion reached by the team relative to that topic.
Selected systems or components based on the Probabilistic Risk Assessment (PRA)
input for the plant were reviewed during the inspection.
I.
OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE (DIRECT MEASURES)
SCOPE Overall plant performance with respect to plant operability, availability, and reliability can be related directl.y to effective plant maintenance.
This area was assessed by reviewing performance indicators such as plant availability, plant operability, reliability, and radiation exposure to determine the impact of maintenance on plant operations.
The inspector interviewed the Plant Manager and the Planning, Scheduling and Reporting Superintendent.
The inspector also examined nuclear operations reports, performance indicator summaries, NRC systematic assessment of licensee performance (SALP) reports, licensee event reports (LERs), surveillance test analysis reports (STARS), outage reports, and NRC inspection reports.
The period used to assess the direct measures element was February 1,1936, to July 22, 1983.
Unit 2 was operational from February 1, 1986 until March 13, 1987, when it shut down for refueling.
Unit 3 was operational from March 3, 1986 until March 3?., 1987, when it was shut down by NRC order.
Both units have remained shutdown since March 1987, in accordance with the NRC order.
FINDINGS Progr_am The new Peach Bottom management has modified the program for tracking maintenance and plant performance indicators.
In the past, the licensee tracked plant availability factors and plant capacity factors in monthly nuclear operations reports.
These reports have been discontinued and replaced by a senior management report (SMR) and a quarterly management report (QMR).
These reports are styled after the INPO, "Performance and Other Indicator Guidelines " dated February 1988.
Plant reliability and radiation exposure performance indicators are tracked in the SMR and QPR.
Table I.1 presents a list of operations, maintenance, technical and radiation exposure indicators that are tracked
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as part of the licensee's program.
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Based on interviews conducted by the inspector, the new Peach Bottom manag? ment team strongly believes that maintenance directly affects plant operability.
Plant manage.nent acknowledges that ESF actuations, outages, violations, and equipment failures could be avoided by improved maintenance.
Current management philosophy is that a lack of preventive maintenance in the past has led to the current large backlog of maintenance work; therefore, management involvement in the maintenance process has been increased.
Implementation Table I.2 presents the performance indicators reviewed by the inspector.
The foo: notes to the Table indicate which indicators are currently included in the licensee's program and which indicators the licensee plan; to incitde in the future.
Tracking of the capacity factor was discontinued because it penalizes units for load following and reserve shutdown. In ics place, equivalent availability factor is currently tracked.
On demand failures and time critical in an LCO are not tracked by the licensee.
The man-tours tu reduce the maintenance backlog to zero is not currently tracked oy the licensee's performance indicator program, but a new revi-sion to the maintenance computer file will allow the licensee to better estimate the backlog.
Radiation exposure performance indicators are tracked by the licensee's p rog ram.
Plant management indicated their belief that a good maintenance program alone will not lead to lower radiation exposures but that it must be accompanied by good chemistry and ALARA practices.
The planning, scheduling and reporting group publishes the following documents on performance indicators:
Senior Management Report - Performance Indicator Summary, Quarterly Management Report - Performance Indicator Summary, publicized quarterly (first in March 88, second in June 88),
Monthly reports for site management, e g., Report on Deferred Preventive Maintenance MRFs, Weekly report on work order status / work order data -
(Weekly Update),
Special reports in response to management requests.
These reports display the indicators in terms of absolute values, as well as ir. relationship to industry averages, INPO goals, and station goals.
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CONCLUSION Because of the significant management and program changes recently made at Peach Bottom, it is difficult to evaluate the effectiveness of the plant maintenance program and its implementation based on performance measurements.
The performance measu>es gathered by the inspector may not accurately reflect either unit's performance under the new maintenance program and management.
However, the inspector did determine that the licensee's program currently tracks, or will track in the future, appropriate performance indicators to allow an evaluation of the effectiveness of maintenance activities.
The inspector also concluded that the new manage-ment at Peach Bottom is fully dedicated to a strong maintenance program.
The effects of management and program changes will not be reflected in the performance indicators until approximately six months to a year of opera-tion is accrue.
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TABLE I.1 PEACH BOTTCM PLANT AND RADIOLOGICAL PERFORMANCE INDICATORS A.
Operations Indicators Net Generation Equivalent Availability Factor
Automatic Scrams While Critical Safety System Performance-Emergency Core Cooling System (ECCS)
Safety System Performance-Emergency Diesel Generator (EGEN)
Unplanned Safety System Actuations
Forced Outage Rate Unplanned Automatic Scrams /1000 Hours Out-of-Service Control Room Instruments Surveillance Test Performance (TS Required)
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Maintenance Indicators
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MRF Priority Ratio Ratio of Preventive to Total Maintenance
Preventive Maintenance Items Overdue
Maintenance Accident Rate Maintenance Overtime Worked Maintenance Radiation Exposure Corrective Maintenance Backlog /3 Months +
Unplanned Maintenance Activity Scrams C.
Technical Indicators Thermal Performance
Fuel Reliability
Chemical Performance Indicator
Auxiliary tooling Water % of Time Out of Specification
Reactor Water Conductivity
Feedwater Dissolved Oxygen Condenser Air Inleakage/Off Gas Flow Temporary Circuit Alterations Status D.
Radiological Indicators Collective Radiation Exposure Total Skin and Clothing Contaminations Number of Positive Whole Body Counts Volume of Low Level Solid Radwastes
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Radioactive Effluents Surface Contamination Performance l
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i TABLE I.2 UNIT 2 UNIT _3 Availability Factor 2'8 2/86 to 3/87 81%
69%
2/86 to 7/88 38%
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Capacity Factor 2/86 to 3/87 78%
625 2/86 to 7/88 36%
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No. of Rx Trips due to Maintenance Activities None
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Emergency AC power)
Actuations due to Maintenance Activities
7 No. of Tech Spec Violations 5 Due to Maintenance Activities
None
No. of Forced Outages Due to Maintenance
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Percentage of Components Requiring Rework af ter Corrective Maintenance 7%
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No. of Failed Surveillance 8 Tests 1,323 of 16,204 251 of 4692 Estimated Manhours Required 8 to Eliminate Maintenance Backlog 226,000 hrs 480,000 hrs No. of Maintenance 5 7 Violations and 1 Deviation Related Violations Total for Both Units 2'
These items are tracked by the licensee.
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These items will be tracked by the licensee in the future.
Unit 2 has been shutdown since March 13, 1987 and Unit 3 has been shutdown sinc.e March 31, 1937.
The totals listed for both units included all ESF type actuation.
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II. MANAGEMENT SUPPORT OF MAINTENANCE
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The objective of this part of the inspection was to assess plant and
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corporate management support with respect to establishment, implementation and control of the maintenance program.
The major areas evaluated were (1) management commitment to and involvement in maintenance; (2) manage-ment organization and administration; and, (3) technical support provided to the mairitenenance organization.
Discrete elements within these three areas, such as the roles of PRA and Quality Control in the maintenance process, were evaluated to provide a basis for the overall assessment and are discussed under separate paragraph headings.
The sections in the report are numbered to correspond to the blocks en the maintenance tree.
II.2.0 MANAGEMENT COMMITMENT AND INVOLVEMENT This area of the inspection evaluated corporate and plant management's commitment to and involvement in assuring the adequacy of plant maintenance, as indicated by (1) their support for industry initiatives; and, (2) their interest and participa-tion in a continuing assessment and improvement of the mainte-nance program.
II.2.1 APPLICATION OF INDUSTRY INITIATIVES The inspector determined and rated the extent of management's
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support of industry initiatives by comparing stated, documented and observed activities to those specified in the initiatives.
The licensee's actions with regard to INP0 initiatives, industry
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generic communications, owners group and EPRI programs, and NUMARC initiative; were examined.
Licensee documents and work were inspectea for evidence of conformance with good practices and agreement with regulatory requirements.
FINDINGS Program The following findings are based on interviews with upper level managers (Superintendent-Maintenance /I&C and above)
aild several engineers:
(1) There is no written program describing upper level management's support for application of industry initiatives. However, there was clearly an unwritten policy (or program) for support of important industry initiatives.
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(2) Corporate management has withdrawn the utility from membership in the Electric Power Research Institute (EPRI)
based on financial considerations. They indicate that they will continue to support previously arranged obligations related to utility projects being managed by EPRI and they
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will pursue EPRI membership again when their financial
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situation permits.
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(3) Management was knowledgeable of at least the general content of many of the important initiatives covered in this inspection.
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Implementation (1) Based on interviews and review of correspondence, data, and procedures, the inspector determined that the licensee has actively participated in the Maintenance Assistance
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Review Team (MART) inspections, peer evaluations, training accreditation, plant performance indicators program, motor operated valve program, and the Human Performance Evalua-tion System (HPES) sponsored by INP0. With regard to the HPES only a few evaluations have been performed and the associated procedure was approved during the NRC inspec-tion.
Licensee personnel were unfamiliar with the INPO Equipment Improvement Prcgram and the inspector could not ascertain any licensee involvement in this program.
(2)
From interviews and a review of correspondence, the inspector found that the licensee has been an active participant in the BWR owners group.
(3) To assess the licensee's use of information from EPRI, the inspector selected two EPRI documents related to maintenance issues (one describing good bolting practices and another which provided a checklist for self assessment of maintain-
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l ability) and questioned licensee personnel as to whether either had been used at Peach Bottom.
The inspector was informed that they had not been utilized.
Licensee manage-ment informed the inspector that information such as good practices had previously been used by their Oregon Shops in development of the plant's maintenance procedures.
However, there is currently N projram requiring assessment of good practices to determine if such information should be factored into maintenance procedures or training.
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arviews with licensee management indicate previously i
limited but now increasing involvement with NUMARC
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(5) The licensee has participated in the Nuclear Plant Reliability Data System (NPRDS) for about 12 years (both obtaining information from and inputting to the system). Tha inspector noted that although useful information was obtained from NPRDS, in some instances unimportant information had been entered and in others there was insufficient information reported to assess some apparently important equipment failures.
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From interviews with licensee personnel and reviews of instructions and correspondence, the inspector found that prior to March 1938, the licensee's approach to cssessing and responding to operating experience information (INPO SERs and Significant Operating Event Reports (SOERs), NRC Bulletins and Notices, vendor bulletins and information letters, etc.) was handled in a fragmented manner such that some important concerns may not have been adequately ad-dressed.
The licensee has recently (June 1988) developed an Operating Events Assessment Program (0EAP) to assure proper dissemination and use of the various operating experience.
The program provides instructions to assure that current and future experience information is reviewed for appropriate action and elso that past experience
information has received consideration.
The inspector d
examined the OEAP processing for two examples, SOER 86-03
and NRC Information Notice (IN) 87-40.
He found that proper actions were being taken to resolve them through the OEAP, though the process wa: not yet complete.
The operat-ing experience concerns reported in these documents involve check valves and Motor Operated Valve (MOV) backseating, respectively.
The inspector also review the pre-0EAP actions taken by j
the licensee with regard to SOER 86-03 for the check valve concern, which was published in 1986.
There was no apparent licensee response until October 1987 following release of a draft EPRI publication providing guidelines for address-ing check valve problems.
The inspector was informed that the licensee is still developing their program to resolve the check valve concerns.
Pre-0EAP licensee methods had resulted in actions to address this concern even though these actions did not appear prompt.
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II.2.2 MANAGEMENT VIGOR AND EXAMPLE SCOPE
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The purpose of this area of inspection was to determine manage-ment's interest and participation in the continuing assessment I
and improvement of maintenance at their plant.
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The inspector evaluated these areas by examining management awareness of and involvement in the following matters:
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Self assessment using performance indicators
Training in maintenance
Periodic maintenance program review and updating
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Feedback to organizations involving maintenance
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Actions demonstrating top management's involvement in
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maintenance to all personnel levels
Development, implementatinn and er;forcement of maintenance policies
Databases used and their goals and ef fectiveness FINDINGS
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Program i
The following findings are based on interviews with managers, supervisors, engineering personnel, planners and craf t:
(1) There is no written program describing the extent to which olant management must be aware of and involved in the maintenance program.
However, the inspector found that the highest levels of management did have an unwritten practice of closely monitoring maintenance and directing evaluations to provide improvements in maintenance related activities. A specific example cited to the inspector by I
engineering and by planning personnel involved improvements in the computer programs used in planning and recording
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maintenance.
i (2) Most of the upper level managers who exercised responsibilities related to the maintenance program (Superintendent - Mainte-
j nance and I&C and above) had been in their present positions l
for less tnan two years.
Increased attention to monitoring i
and improving maintenance appeared to have taken place as a result of their efforts.
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Implementation (1) The inspector found that management was in the process of developing formal maintenance policies which are to be included in their maintenance manual.
Based on inter-views with varim s levels of personnel the inspector found that most ind'viduals were very aware that upper management had a strong interest in maintenance.
(2) Management interviewed by the inspector indicated strong support of and involvement in periodic reviews of maintenance and in upgrading of the maintenance program.
The inspector observed that there had been many reviews of maintenance including annual INPO evaluations, self assessment, Maintenance Assistance Review Team (MART) inspection, periodic reviews of performance indicators, etc.
The findings resulting from these reviews were being effectively addressed and tracked through Maintenance Upgrade Task Reports (MUTR).
(3) Performance indicators are.ncluded in reports to management and are reviewed bv management during various periodic meetings.
T,ese indicators include those recommended by INP0, with some additions and modifications.
Examples of performance indicators are shown on Table I.1.
(4) The inspector found that MUTRs contained tasks aimed at developing feedback to all levels of employees (Task No. 14.3.1), and that implementation was scheduled for August 1983.
ihe inspector also found that effective feedback was being provided to personnel through "all hands" seminars conducted by the licensee's Project Division.
(5) From interviews with personnel involved in the use of the maintenanc? related data bases, observation of the use of the dats bases and reviews of printouts provided at the inspector's request the inspector found that the licsnsee utilizes many data bases (mostly computerized) to support the maintenance process and that witt minor exceptions each appears satisfactory.
Specific items reviewed by the inspector included CHAMPS (Computerized History and Maintenance Planning System)
data for units 2 and 3 HPCI turbine steam supply valve maintenance and Unit 2 reactor feed pump 2A preventive maintenance data.
The inspector also reviewed data associated with the drywell chilled water system in the ADEPT system used for health physics planning.
The inspector also noted that the licensee had self identified I
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areas for improvement in the existing maintenance data
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bases and had received specific direction from the executive vice president to make such improvements.
(6) The inspector discussed training with responsible licensee training personnel and with managers and found that they indicated continuing management awareness and promotion of maintenance training.
The inspector was informed that the plant had an INP0 accredited training r
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program that had been in place for about two years.
(7) Based on interviews with upper level site managers and engineering personnel, the inspector found that managers had recently become aware of NRC interests in plant aging and that actions had been initiated to obtain information on the subject.
They intend to have appropriate personnel review this subject for future applicability to their plant.
11.2.3 CONCLUSION Peach Bottom does not currently nave a documented program for management participation in and application of industry initiatives even though managecent indicates it is their philosophy to support important industry activities. With regard to implementation of this philosophy, licensee management
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has generally supported participation in INPO activities and is increasingly active in NUMARC initiatives.
The licensee is not currently a member of EPRI. With regard to processing of generic correspondence, the licensee has implemented a new program that
should improve performance in this area.
l With regard to management vigor and example, Peach Bottom
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management appears to have effectively comnunicated the
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importance of effective maintenance to the plant staff.
This philosophy is currently being formalized in policy statements.
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Management has supported and participated in numerous self evaluation activities and systems are in place to effectively implement desired improvements.
In sunmary, licensee.tanagement is supporting and participating in continuing assessment and improvement of the maintenance l
program and its implementation.
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11.3.0 MANAGEMENT ORGANIZATION AND ADMINISTRATION (CORPORATE AND PLANT)
The objective of this area of the inspection was to evaluate how management supports the maintenance organization and administration of the maintenance program.
Specific areas
inspected included maintenance program coverage; maintenance policy, goals and objectives; allocation of resources; definition of maintenance requirements; conduct of performance measurements; maintenance document control system; and the
decision process for scheduling maintenance.
II.3.1 IDENTIFY PROGRAM COVERAGE FOR MAINTENANCE SCOPE
The purpose of this inspection area was to determine if a maintenance plan is issued, periodically reviewed and updated, and includes both a detailed program description and an organi-zational layout with identified responsibilities.
The inspector reviewed the Maintenance Administrative Manaal (MAM) and the Maintenance Upgrade Task Report.
FINDINGS - Program and Implementation PECo is in the process of developing a Corporate Maintenance Strategy (maintenance plan) and will develop a Peach Bottom specific Maintenance Strategy, after the corporate strategy is issued.
It was indicated that the strategies would most likely be three or five year plans that woula be reviewed nd updated annually.
The MAM, which was initiated in May 1938, addresses corporate and station policies that affect Maintenance and I&C j
and will be expanded and revised as new policies are issued and old policies are revised.
Currently, the MAM addresses
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organization, administration, and personnel policies.
The MAM
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includes the current organization chart and position descrip-tions for senior maintenance personnel, which together outlines the chain-of-command and personnel responsibilities.
However,
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the Maintenance and I&C organization is still in transition, due
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to review by PECo and a consultant, and further organizational l
changes are planned.
The Maintenance Upgrade Task Report lists several items or tasks that require action to improve overall maintenance at the site which were identified by the INPO evaluation of 1937 and the INP0 Maintenance Assist Review Team (MART) report of 1987.
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Completion of these tasks appears generally on schedule.
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CONCLUSION Corporate and PBAPS Maintenance Strategies need to be approved and issued in order to provide a clear written overall direction for the maintenance program. The Maintenance and I&C organization needs to be finalized to ensure all aspects of maintenance are effectively and efficiently addressed.
Effectiveness of the MAM should be evaluated in the near future, since the MAM is relatively new. Continued progress on implementation of items in the Maintenance Upgrade Task Report is necessary to continue improving maintenance at PBAPS.
11.3.2 ESTABLISH POLICY, GOALS AND OBJECTIVES FOR MAINTENANCE SCOPE The purpose of this inspection area was to determine if corporate and plant diree.tives for maintenance are documented.
L issued, approved, and periodically reviewed and updated; and to evaluate the effectiveness of the implementation. The inspector i
reviewed Nuclear Group Mission and Objectives, PBAPS Mission and Objectives, the Maintenance Administrative Manual (MAM) and l
position descriptions for Maintenance and I&C personnel at various levels.
FINDINGS - Program and_ Implementation A manual has been developed that contains directives, philosophy, and policies of the corporate Nuclea-Group, but the manual has yet to be distributed. Goals are set starting at the corporate level, then the station level, then at each organization within the station.
The MAM is being developed to address corporate and station policies that affect Maintenance and I&C.
The MAM currently addresses organization, administra-t tion, and personnel policies, which includes Objectives and
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Goals for 1938.
However, there is no formalized process that
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would periodically review and update corporate and station directives.
i Even though corporate and station directives have not been j
formally distributed to station personnel and the MAM is i
still being developed and expanded to address all directives related to Maintenance and I&C, it appears the work observed by the inspector generally reflected the intent of new philosophy and directives.
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CONCLUSION Corporate and station directives are documented, but are not distributed to all station personnel.
However, the general intent and philosophy of the directives was apparent in work performed.
II.3.3 ALLOCATE RESOURCES SCOPE The purpose of this inspection area was to determine how effectively managemtnt controls resources for maintenance including staffing levels, overtime, availability of tools and
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material, and technical support.
The inspector reviewed graphs, charts and tables of Maintenance Work Request (MRF) backlogs for Units 2 and 3, including outage and non-outage corrective main-tenance (CM) and outage and non-outage preventive maintenance (PM); reviewed the station 1988 budget details; reviewed daily and "5 day look ahead" work schedules from July 11 - 22, 1983; and on going work activities.
FINDINGS - Program and Implementation Based on observation of on going work activities, maintenance staffing levels appeared to be adequate; there were always a large number of craftsmen at the job site available to work.
During the present outage, craf tsmen are working approximately
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25*. overtime.
The maintenance staff, during the present outage, consists of approximately 140 PBAPS employees, approximately 200 PECo maintenance "floaters", and approximately 270 contract employees.
(These numbers do not include the contract employees for the Unit 3 recirculation pipe replacement work.)
Based on observation of on going work activities and work schedules, work does not appear to be delayed significantly due to unavailability of materials nor does work appear to be delayed due to inadequate technical support.
The number of preventive and corrective MRFs outstanding during the March -
July 1938 internal work noted to be decreasing for the Unit 2 and Unit 2 - Unit 3 common areas.
CONCLUSION Managemerit has allocated the resources necessary to provide an adequate maintenance staff with enough materials and technical support to accomplish maintenance.
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11.3.4 0FFINE MAINTENANCE REQUIREMENTS SCOPE The purposes of this inspection area were to (1) determine if a program is developed and implemented to identify required maintenance from applicable sources such as industry and vendor information, NRC commitments and information, plant history, QA/0C audits and inspections, and Technical Specifications; (2) determine if a program is developed and implemented to modify required maintenance when applicable information sources are modified; and, (3) determine if the various types of mainte-nance (Corrective, Predictive, Emergency, Preventive) are inplemented as defined.
The inspector observed ongoing work on the E-2 emergency diesel generator, the Emergency Cooling Water Pump, and
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several Unit 2 480V motor control centers (MCCs); reviewed several completed work packages; reviewed procedures for corrective and preventive maintenance; and briefly reviewed the Standby Liquid Control (SLC) System because of its PRA significance.
FINDINGS - Procram and Imolementation Based on the inspector's observations, corrective and preventive maintenance is generally implemented as defined in administra-tive procedures and where required, Environmental Qualification (EQ) requirements are included in the work packages.
Emergency work is handled in the same manner as corrective maintenance, only expedited.
Based on discussions with station personnel concerning the SLC system and maintenance in general, it appears that a complete formal program does not exist to identify maintenance require-a j
ments from all applica51e sources.
An interim corporate pro-cedure was approved July 18, 1938, to register, control, and
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distribute selected incoming and outgoing correspondence.
This
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l should provide a method to ensure that information such as NRC,
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vendor, and industry information applicable to Maintenance and i
I&C is distributed to Maintenance and I&C for actions in a i
controlled and documented fashion.
Currently, there is not a formal, comprehensive list of maintenance requirements for individual components or for complete systems.
However, a Master Equipment Index with a comprehensivG list of all applicable requirements for individual j
components is planned for the near future.
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The inspector selected a few NRC Information Notices and Industry Information Letters and verified that these had been reviewed by Maintenance and I&C and appropriately implemented.
CONCLUSION Currently, a method does not exist to identify and implement all maintenance requirements; however, the interim correspondence control procedure could prove to be an effective tool to aid in accomplishing this method. Additionally, there is not a list of all applicable maintenance requirements for individual components or systems.
II.3.5 CONDUCT PERFORMANCE MEASUREMENTS SCOPE The purpose of this inspection area was to determine the effectiveness of interface activities between maintenance and other organizations. Work sampling, system walkdowns, root cause analyses of problems, feedback methods, maintenance performance indicators, and OA audits were evaluated.
FINDINGS Program The inspector determined that the licensee's maintenance program includes documented requirements and methods for collecting and evaluating performance indicators; performing surveillances and walkdowns to monitor maintenance activities; performing root cause failure analysis; providing feedback and conducting QA audits.
As discussed in Part I of this report, a systematic and organized program is in place to collect, analyze and publish performance indicator data.
These performance indicators are compiled, analyzed, structured into a useable format and publisiied in a comprehensive Senior Management Report - Performance Indicator Summary on a monthly basis.
Surveillance of plant equipment is described in procedure A-43.
The master test schedule lists the equipment and frequency of calibrations, functional tests, inservice tests, etc., that are required by the Technical Specifications, appropriate ASME
"Code" sections and applicable commitments to the NRC.
The Plant Performance Monitoring Program Description, dated
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September 11, 1986, describes that effort by the plant system
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engineers to monitor the performance of equipment that could have a significant effect on plant performance. Also, the licensee is currently using vibration monitoring / analysis as a predictive maintenance tool.
Four types of walkdowns for monitoring the maintenance l
work process are addressed in established procedures. These are QC hold / witness points that are line items in procedures; the daily examination of work areas by cogni: ant group super-visors; a Management By Walking Around (MBWA) program that requires management members to spend at least four hours weekly i
in the field; and, the goals of individual foremen's job
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descriptions that include spending time at a job location.
The licensee has a formal cause failure analysis process that is intended to reduce or prevent equipment failures.
Recurring problems must be reported to the appropriate System Engineer and requires that action be taken to resolve the cause.
The various performance measurements discussed in this section i
of the report each incorporates a feedback mechanism within
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itself.
Examples are the Plant Performance Monitoring P*ogram that establishes the use of a Deficiency Log and the QA Program Manual, Volume III, that describes the formal Nonconformance
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Report system.
l The QA Program Manual, Volume III, describes the formal audit program and the details of implementation are contained in a series of QA Instructions.
Deselopement of checklists, scheduling and use of Non onformance Reports are examples of the details included in these instructions.
. Implementation The inspector observed active participation by licensee senior f
management in the review and evaluation of performance indicators.
i A nonthly o. site meeting is held to discuss matters pertaining l
l to the Se iior Management Report - Performance Indicator Summary.
The Executive Vice President Nuclear presides and attendees
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include the Vice President, p2APS, Plant manager, administrative and technical support managers, appropriate staff members for
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discussion items, and various other pctsonnel. An inspection team member attended the July 12, 1988, meeting and noted that decisions were made by the Exective Vice President and actions were assigned following round table type discussions during the meeting.
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The calibration, testing, etc. of installed plant equipment is being done in accordance with the established schedule (this effort is also discussed in other sections of this report).
Other types of monitoring / surveillance, such as random QA
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monitoring and PRA based walkdowns by plant personnel, are also being accomplished.
Inspectors observed licensee personnel performing team walkdowns of the residual heat removal system and motor operated valves.
They also insoected various maintenance work containing QC inspection hold and witness points.
The QC group had been notified prior to the start of work as required and QC intpec-tions were conducted on completed work.
Daily examinations were done and documented by group supervisors. Although not docu-mented, the presence of management in the field and foremen at job locations was noted.
The quality of these activities was found acceptable. Additionally, a PRA (Probabilistic Risk Assessment) Oriented System Walkdown program has been recently implemented.
Root cause analyses are being conducted and specific instances are discussed elsewhere in this report.
Currently the emphasis of this effort is directed at repetitive type problems.
Every performance measurement technique reviewed had its own or shared a eethod of feedback.
Examples are audit finding Nonconformance Reports; the plant Performance Monitoring Prugram's use of a Deficiency Log; and, the dei?y plant status meeting whare problems with equipment, procedures, etc. are discussed.
The QA Department has conducted a number of audits on several
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aspects and phases of the maintenance process.
These audits were conducted in accordance with the requirements of the QA Program (e.g., use of checklists) and corrective actions were effectively implemented.
CONCLUSION The licensee has formally documented programs for performance indicators, surveillances, root cause analysis, QA/QC audits and feedback from maintenance activities.
Some of these pro-grams are relatively new but appear to be ef fectively implemented at this time. Management and supervisor participation in monitoring maintenance performance is good.
Senior management participates in the review and evaluation of performance indicators.
Similarly, although specific written guidelines are
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not provided to maintenance supervisors, their presence in the plant, monitoring maintenance activities is apparent.
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11.3.6 DOCUME.',f CONTROL SYSTP1 FOR MAINTENANCE SCOPE This area of the inspection examined the method and operation of the system for documentation of both maintenance work orders and general administrative documents.
The inspection included attention to the processes of document generation, assignments of responsibilities and accountability, document reviews and updates, approval, tracking and traceability.
The organizations responsible for these functions were identified and their methods of operation examined.
FINDINGS Program The Procedure Control Group is responsible for the document control system.
The g oup's function includes initiation of procedure reviews, tracking of the review process (prioritization, routing, sign-offs) and closing out the reviews.
The document control system operates on the basis
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of a formalized, structured approach.
The basic document that describes the approach for performing periodic reviews is Administrative Procedure A-36, Rev. 9.
The procedure control group administers the procedure review through a computerized tracking system, formalized prioritiza-tion, and a series of regularly scheduled status reviews (daily ano weekly meetings, weekly status reports, and a status audit every three weeks).
There is a means to provido 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage for approval of revisions in cases where priority requires quick turn-around time.
Implementation l
Administrative Procedure A-36, Rev. 9, ef fective July 14, 1988,
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represents a significant change in the review cycle for proce-dures:
a two year review cycle was introduced for 15 categories of procedures, and a five year cycle for four categories.
The goal is to complete all reviews with a 2 year cycle by 12/31/53.
It must be noted that maintenance procedures are on a five year review basis and the current update of A-36, Rev. 9 does not reduce this review cycle to the industry practice of two years.
The Procedure Control Group is also involved in the control of drawings.
PEco has recently reviewed their drawing inventory:
the total inventory is approximately 75,000 drawings, and 4,000
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discrepancies (e.g., missing, superseded revisions) were found and corrected.
The review of the drawing inv6 itory resulted in the establishment of three locations where controlled drawings are issued and an increased emphasis on the use of controlled drawings in general.
CONCLUSION
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The document control process is formalized, organized and I
documented.
It has a formal method of operation (Administrative
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Procedure A-36, Rev. 9) with the Procedure Control Group as the responsible organization for implementation.
Recently, a two year review cycle was established for 15 categories of proce-i dures; however, maintenance procedures remain on a five year i
cycle.
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11.3.7 MAINTENANCE DECISION PROCESS i
l SCOPE The purpose of this area of inspection was to determine the awareness of and involvement in decisions regarding mainte-nance by both corporate and plant management.
The inspector reviewed the following activities with regard to this area:
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l Corrective and preventive maintenance
l Upgrading
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Replacement
Aging (e.g., end of life)
Work deferment FINDINGS i
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A formal, documented program for making decisions on corrective
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and preventive maintenance (CM and PM) does not exist.
Decisions l
in this area are made at various levels of plant management and supervision in accordance with the inherent responsibilities of the appropriate position. Other than ninor de:isions are usual-ly made by group consensus (e.g., foreman, maintenance engineer, systems engineer) and information inputs are frcm various sources such as the Plant Performance Monitoring Program.
The decisions are based on impact on Technical Specifications, station reliability and personnel safety; maintenance history; availability of parts; and, cost.
The decision to modify or replace (i.e., upgrade) a component is rade at the first line maintenance engineering supervisor
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level with higher approval required based on the expenditure
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amount.
The decision process is not formalized in a program, but technical and work activities associated with actual replace-ment or modification are conducted within the formally structured modification program.
Currently, plant aging is approached on a case by case basis using the informal process discussed above.
However, the
licensee has recently initiated an effort to establish a
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formalized program to address service life, and other aging considerations.
This effort can be characterized as being in the research phase with the developmental and
I implementation phases to follow.
The deferment of work scheduled to be completed during the current outage is formally structured with a documented approval process.
There is no such formalized system for the deferral of
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work during plant operations.
Established procedures minimally
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address work deferment during operations and the decision to defer major work is made at the plant senior engineering level.
The common but informal practice is to convene a group composed of appropriate personnel for pertinent decision process discussions.
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l Corporate management becomes aware of and is kept abreast of
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maintenance decisions through the monthly Station Review meeting attended by a wide range of technical and management i
personnel and chaired by the Executive Vice President.
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comprehensive report is issued for use at this meeting. Other
reports and communication channels also provide corporate managers with essential information.
Corporate management is i
therefore provided the )ppc** unity to become involved in issues
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as appropriate.
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C.ONCLU_SION The licensee's process for making decisions regarding
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corrective and preventive maintenance, equipment replacement or i
modification, deferral of maintenance work during operations and evaluation of component aging is not documented in a formal
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program.
However, the decision processes for these activities
appears to involve appropriate levels of management and to
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effer,tively utilize available relevant information.
The lack of a clearly described formal administrative process in written procedures is a weakness in an otherwise satisfactory program.
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II.4.0
_TEC_H!jlCAL SUPPORT SCOPE
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This area was directed at evaluation of the technical support the maintenance organization receives from other parts of the organization such as Engineering, Health Physics, Quality Assurance, Quality Control, Safety, Fire Protection and Operations.
The evaluation consisted of reviewing the licensee's established policy, goals, and objectives and assessing their
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effectiveness.
The inspector selected maintenance related
items from the PRA program, Licensee Event Reports and generic
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issues identified by the NRC and other industry sources and
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evaluated how the maintenance and other organizations interfaced on these issues.
l II.4.1 INTERNAL / CORP 0 RATE COMMUNICATION CHANNELS i
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i SCOPE I
The inspector reviewed the licensee's organization and communication systems to assure that corporate policies for
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the maintenance organization have been transcribed into plant procedures and that a feedback system has been established so that maintenance concerns are identified to j
management for th ir information and action as required, j
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FplDINGS P ggram t
The licensee has established a system that provides maintenance,
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engineering and other organizations with industry and NRC i
initiatives affecting the operation and maintenance of their I
plant equipment and systems.
A tracking system has been established that identifies assignments and maintains the status of activities in this area.
The licensee has revised mainte-l'
nance and site procedures to reflect the new tracking require-ments.
The Engineering Work Requests (EWRs) and Nonconformance
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Reporting procedures (NCRs) are examples of engineering and j
quality assurance procedure changes that have resulted in
increased support to the maintenance organization. Also, revi-i sions to tracking programs such as the Nuviear Engineering Task
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Tracking (NETT) and Nuclear Engineering Action Tracking (NEAT),
have been made to better identify end support maintenance
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,l problems.
These tracking programs totter address the status and identify EQ, design deficiencies, failure reporting and work order status.
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Implementation The above referenced programs and procedures were in place prior to the shutdown but have been revised to reflect t59 updated procedures and the new maintenance organizatice. As an example, the present nonconformance report (NCR) systee is being revised to reflect changes that were required to com? f with the f
revised maintenance and administrative procedures tnt have been
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issued. Also, the present Engineering Work Request (2WR) system is being revised to include NCR tracking status.
CONCLUSION
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The licensee has established systen.s to communicate between corporate and site maintenance management as well as between site maintenance and other site organizations.
In many instances the procedures are new or have been recently revised.
The
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adequacy of these revised and new procedures will have to be proven in use; however, the written intent of the procedures and the management overview appears to have made positive changes to the systems for managing and tracking the maintenance program.
11.4.2 ENGINEERINC SUPPORT SCOPE
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The object of this part of the inspection was to evaluate the extent to which engineering principles and evaluations are I
integrated into the maintenance process.
This was accomplished
by reviewing work orders, activities concerning unusual events, i
failure analyses and other maintenance activities to evaluate l
the effectiveness of engineering support.
FINDINGS - Program _and Implementation The technical support and systems engineer groups provide the major site engineering input to maintenance activities.
The technical support group includes reactor engineers, project engineers and test engineers.
The systems engineer group is organized to provide a knowledgeable engineer assigned to individual plant systems.
In addition to their specific system responsibility, the systems engineers interface with the maintenance organization through reviews of maintwnance work orders, I&C test reviews and surveil-lance test results.
Engineering reviews of component failure analysis reports and maintenance trending results are areas where engineering actions are being taken based on maintenance
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trends.
The interface with the engineering arganization and the maintenance organization during the early pionning stages of maintenance tasks appears to have made a positive effect on the maintenance work performed.
The engineering tracking programs
developed to track and identify trends for engineering use 4re new and have not been in place long enough to evaluate their effectiveness; however, the intent of these programs appear to be positive tools for the engineer to evaluate the maintenance trending results.
CONCLUSION Engineering reviews in the maintenance cycle for both planned and completed tasks have produced positive interactions between the organizations in the areas of work performed and the review of test results at both the component and surveillance test levels.
These engineering reviews of maintenance work orders and surveillance testing procedures have enFenced the system testing program.
Engineering tracking systems have been establist.ed to evaluate the effects of maintenance work at both the modification and system level; however, the effectiveness of these engineering programs has yet to be demonstrated.
These tracking systems appear to provide engineering a method of evaluating the results of maintenance work and their effect on the operation of the system.
The regular involvement of systems and technical support engineers in work with plant components provides for the incorporation of engineering principles and evaluations into the maintenance process.
Site ergineering involvement in maintenance is augmented with engineering guidance provided from the PECo corporate engineering staff.
II.4.3
_ ROLE OF PRA IN THE MAINTENANCE PROCESS S
SCOPE The objective of this part of the inspection was to determine the extent that Probabilistic Risk Assessment (PRA) concepts are considered in the maintenance program and in such areas as planning, scheduling, and prioritization of werk.
The inspector reviewed licensee activities related to probabilistic risk assessment (PRA) and the application of PRA to the maintenance program.
FINDINGS - Program and Implementation The licensee has updated their description of the initiating events status in NUREG/CR-4550/ Volume 4, titled "Analysis of Core Damage Frequency from Internal Events, Peach Bottom Unit 2, October 19S6." However, the licensee has not formally documented their program or goals for integration of PRA into the mainte-nance program.
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With regard to implementation, the licensee has been giving
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PRA training to various organizations at the site including the maintenance organization.
System engineering is performing what l
they refer to as PRA walkdowns of their systems using the t
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.nformation issued by the PRA engineer, CONCLUSION i
j Licensee management has not established specific goals for the
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use of PRA concepts in the m>intenance area; however, training
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is being given to site personnel and system walkdowns based on PRA concepts are being performed. Where the maintenance activites on selected PRA significant systems or components
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were examined, the inspector found the presence of effective
maintenance coverage with appropriate technical support; for example:
Extensive docu.entation exists on the history of corrective and l
preventive maintenance of the HPCI system.
The HPCI system e
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documentation and the assignment of a system engineer indicate
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I a well established PM program with a provision for continuous
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oversight, periodic review, and future improvement.
Record keeping and status review is eadily available for the system.
For the "A" instrument air compressor, the licensee has
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recognized the frequency of failures and implemented a number (
of preventive actions including testing, measurement of
temperature and air pressure and preventive maintenance.
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t The extensive motor operated valve rebuild program to improve MOV reliability is nearing completion.
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j A system engineer is responsible for the control rod drive
system.
The engineer's responsibility involves trending and
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tracking problems, failures, changeouts and rebuilds. A PM i
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program has been instituted to help cut down on the number of
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control rods drives that need to be rebuilt each refuel cycle.
The past refuel outage on Unit 2 required almost half of the
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drives to be rebuilt.
In the area of containment leak rate control, a test engineer
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is responsible for the local leak rate test program and is very knowledgeable of current and past history. The test
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engineer was placed on special assignment several months ago to write an administrative procedure covering the entfre local
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leak rate test program.
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II.4.4 ROLE OF QUALITY CONTROL
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J This part of the inspection was directed at determining the
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extent that quality control is involved in the maintenance l
process.
The inspector reviewed the quality assurance audit program; selected QC inspection plans and results for components
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selected from the PRA list in NUREG/CR-4550/ Volume 4; QC coverage i
of selected maintenance on EQ equipment, surveillance, and testing; trending; and the QC organizations method for identify-ing and resolving items from their corrective action tracking
j system.
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FINDINGS - Program ana Implementation The licensee's audit, trending, and nonconformance reporting
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systems were in the process of being revised and updated.
The
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revised audit and trending program were in the process of being presented to licensee management for review while the NCR system
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was still in the process of being rewritten.
In the revised
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l procedures reviewed by the inspector it was evident that not i
only will quality control improve their inspection criteria, but
management will have an improved documented tracking system in
place. An example of one of the improvements is the revised trending program.
This program in addition to trending status i
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will identify open items with due dates and responsibilities
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i assigned and tracked.
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CONCLUSION
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In general, the revised procedures and tracking programs reviewed
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i by the inspector indicate that the system improvements will
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enhance their existing programs, specifically in the areas of l
assigning and tracking open item due dates. Actual effective-i j
ness of implementation will have to be reviewed in the future, j
l 11.4.5 INTEGRATION OF RADIOLOGICAL CONTROLS INTO THE MAINTENANCE PROCESS i
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SCOPE i
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The scope of this element involves an inspection of the
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coordination and integration of radiological controls into the planning and performance of traintenance work.
The
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I inspection includes a review of the ALARA steps that are j
incorporated into the work planning as well as ALARA i
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The scope did not
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include major modifications such as the recirculation pipe replacement on Unit 3.
FINDINGS P 09Ea2 C
Station instruction and policies that ensure integration of
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radiological control into the maintenance process are very well documented. A sampling of job descriptions also indicates that personnel are held accountable for specific coordination acti-vities.
HP hold points and signoffs are included in the request for maintenance work and in the work performance procedure which require HP or ALARA concurrence prior to proceding.
Reasonably
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accurate schedules of work to be performed are published and
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widely distributed.
This documentation assists HP/ALARA super-
vision in assigning HP technicians for job coverage and for completion of radiation work permits (RWP).
The use of computer programs called CHAMPS and ADEPT provide detailed information about each job allowing specific radiological conditions to be evaluated and accurate radiation work p*rmits and ALARA reviews to be completed.
However, many of the policies and procedure I
that integrate radiological controls are new or recently upgraded.
J Further refinements and revisions have already been draf ted.
These major changes have caused some confusion and uncertainty
with various personnel.
Station personnel at all levels may l
require time to adapt to these changes until compliance becomes automatic.
j Implerrenta tion
i The integration of radiological controls into the maintenance process is generally conducted in accordance with station l
polices and procedures.
There are HP/ALARA coordinators
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stationed within the Maintenance Department and Modifications Department to implement the program.
These coordinators act as
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an interface in resolving questiens or problems and also
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expedite radiation work permits and ALARA reviews.
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Within the HP-Operations Department there is a subgroup consist-i j
ing of one senior level technical Advisor and three technicians I
who process and issue RWPs as requested on MRFs.
One of these personnel always attends the work status meetings.
It was noted
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that a single RWP may cover many separate MRF work packages.
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l For Example:
RWP No. 5072 covered 110 MRFs while RWP No. 6316 covered 25 MRFs Several HP technicians indicated that this is done to consolidate similar work onto one RWP to minimize the
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effort needed to generate several hundred RWPs.
However, this has created a complex situation where all groups concerned must rely on the CHAMPS computer program to link a MRF with an RWP.
HP supervision indicated that a change to issue one RWP for every MRF is being evaluated.
A high level of cooperation was noted between maintenance and HP/ALARA personnel at all levels.
These relationships are essential to the safe conduct of work in radiologically controlled areas.
Many formal and informal meetings are held with a good exchange of information.
On the job coverage by HP technicians is good.
Maintenance workers, both permanent and contractor, appeared to be sensitive
,
to compliance with requirements imposed by the RWP.
On the other hand, many workers did not exhibit the same level of sensitivity to minimizing exposure to achieve ALARA.
Instances of work inef ficiencies were noted.
CONCLUSION Relationships are in place to effectively integrate radiological controls into maintenance work.
Improved scheduling and coordi-nation have e'..minated delays and a owed additional time to process RWPs and ALARA reviews.
De.gite these positive observa-tions, as noted in other NRC inspections, overall site radiation exposures remains high.
Licensee management is aware of the need for more agressive ALARA goals.
In addition, several procedural improvements are very recent and have not been
"institutionali:ed."
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II.4.6 SAFETY REVIEW OF MAINTENANCE ACTIVITIES SCOPE l
This inspection area evaluated the extent that industrial safety and industrial hygiene are integrated into the planning and performance of maintenance work.
FINDINGS Program Until recently, the safety programs were administered separately by three major departments:
Maintenance, Testing Laboratories, and Construction.
Each department developed its own procedures and provided full time safety personnel.
Under the licensees
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restructuring plan these departments will report directly to
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site management. The transition of the safety progam has not j
formally occurred and is in the draft stage.
In the interim the
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individual safety programs continue to function autonomously.
There is no corporate safety organi:ation nor corporate safety manual; however, the safety programs administered by the safety representatives in the individual departments and by the large tradeforce contractors on site are well documented.
The program i
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in the Maintenance Department was particularly noteworthy.
This department has developed many specific procedures for dealing with various hazards (such as asbestos and PCB) called Standard Work Instructions (SWI) and Maintenance Administrative Guidelines (MAG).
The overall program is described in the
Supervisory Manual which is issued to all foremen.
These
>
j documents appeared to be of good quality.
The MRF procedure (A-26A) requires a review of certain safety
,
!
hazards in section 4 "Special Instruction." These are noise i
protection, fire hazards and confined space entry.
,
The philosophy adopted by the licensee is based on techniques developed by the Du Pont Company.
A key element is
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"management-by-wal king-around" (MEWA).
Supervision at all l
levels are encouraged to spend a large portion of time in the
work areas.
d
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i Inplementation
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Although the safety representatives administer the program the
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i responsibility for implementation is clearly assigned to the job foremen.
The foremen must ensure that all safety equipment
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is available and safety precautions are in place prior to the
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start of work. A tour of work areas confirmed that safety was being practiced as specified by the OSHA regulations and the licensee's safety procedures.
i A review of lost time accident statistics and minor injury reports indicates that site performance compares favorably with OSHA but not INPO guidelines. Accident investigations, foot cause analysis and corre:tive actions appear appropriate.
Safety performance is included in the annual appraisals of all
!.
supervisors and is double weighted.
l Although the major contractors on site (Catalytic, Bechtes, Chicago Bridge and Iron) have their own safety program, the licensee assigns a full time foreman to oversee the safety performance on each project. Coordination between organizations appears to be good.
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Safety training appears good.
All workers receive initial training and are provided with handbooks and policies.
Each week a short tool-box talk is conducted by the foreman to relay important safety information.
Each month the safety representative conducts a all-bands-meeting to provide detailed instruction to
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all workers.
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Safety equipment and supplies were readily available and being
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used.
Provisions for first aid and emergency medical treatment
,
are adequate although the licensee relies on contractor support i
]
for these services.
CONCLUSION
l A very practical and effective approach to safety has been
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plemented based on the DuPont model.
Program strengths were
'ted particularly in the Maintenance Department.
In this very L
'ive program, excellent participation, attitude, and morale
'a part of workers and foremen was nated.
,,owevs, licensee upper management has not taken decisive i
action to consolidate the various safety programs under one site organization.
In addition, the use of subcontractors to perform a large share of the labor intensive outage work is not accompanied by increased attention to contractor safety programs.
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11.4.7 INTEGRATION OF REGULATORY DOCUMENTS IN THE MAINTENANCE PROCESS
SCOPE This element involves an inspection of the methods used to j
integrate regulatory documents into the maintenance process.
This includes changes to the regulatory documents resulting i
j from periodic reviews and updates.
i
]
F_INDINGS I
Program Until recently, regulatory documents may have been processed by i
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any of three corporate groups:
Nuclear Engineering Department, l
Nrclear Support Department or the Regulatory Compliance Depart-rant.
Each department used its own internal procedures.
This was changed with the issuance in June 1983 of a new procedure i
for commitment tracking (N3AP-002 X).
This procedure consoli-
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i dates the tracking of all commitments under the Licensing and
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Regulatory Departennt.
Resolution of commitments is still I
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l carried out by the assigned department using internal proce-dures.
This applies primarily to FSAR changes, Technical Specification changes and specific NRC commitments. A site procedure to process assigned commitaents is not available but
is being developed.
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Also in June, the corporate procedure "Interim Nuclear Group
,
Administration Procedure for Operating Experience Assessment Program (OEAP)" was issued.
This procedure describes the processing and tracking of NRC Notices, Bulletins and Generic
Letters.
A draft procedure (AG-35) describes the processing of
OEAP type issues at the Peach Bottom site.
{
Implementation
Since the program is undergoing a major change, the licensee
,
did a detailed review in March 1988 and identified a total of
'
442 regulatory items in various stages of processing.
These I
were entered into a special tracking program with direction i
from upper management that they be resolved by year end. Any
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regulatory item that is new as of June 1988 will be processed
in accordance with the new corporate procedures and tracked in i
the Quality Assurance Trending and Tracking System (QATTS)
,
computer program.
License management also stated that these
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commitments will be handleo similar to a new plant approaching licersing, i.e., all safety issues will be resolved prior to startup.
A sampling of commitments shows that the responsibility for resolution is clearly assigned.
Personnel were aware of their responsibility and management was aware of the status of each item. A site regulatory group has been staffed and is
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l functioning at this time.
CONCLUSION The licensee is in transition to a significantly improved
program to integrate regulatory documents.
This change was
appropriately begun at the corporate level whare most of the l
regulatory documents are received.
However, th: site procedures still need so be developed and the effectiveness of the new pro-gram implementation will have to be evaluated in the future.
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i III. MAINTENANCE IMPLEMENTATION SCOPE
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The purpose of this part of the inspection was to determine the quality of the established controls and more importantly the implementation of these controls.
The controls established in four areas were evaluated. These areas are Work Control (Section III.5), Plant Maintenance Organization
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(Section III.6), Maintenance Facilities Equipment and Materials Controls (Section III.7), and Personnel Control (Section 111.8).
The effectiveness
was determined through a review of completed work orders, procedures, and other documentation associated with maintenance and training of mainte-nance personnel as well as physical observation of work in progress, tools in stock, spare parts, and discussions with all levels of personnel, t
111.5.0 WORK CONTROL SCOPE The purpose of this area is to evaluate the effectiveness of the maintenance work control process to assure that plant safety, operability, and reliability are maintained.
Areas evaluated by the inspectors were (1) control of work orders; (2) equipment maintenance records; (3) job planning; (4) priori-tization of work; (5) scheduling of work; (6) control of mainte-
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nance backlog; (7) maintenance procedures; (8) post maintenance testing; (9) completed documentation; and, (10) review of work in progress.
III.S.1 ESTA?.!SH WORK ORDER CONTROL SCOPE L
The purpose of this inspection area was to evaluate the methods for work identification and work order control. Work in progress was observed on the E-2 emergency diesel generator, Emergency Cooling Water (ECW) pump, and on 480V motor control centers; walkdowns of the plant were conducted to observe the material condition of both Units 2 and 3; and completed work packages and work control procedures were reviewed.
FINDINGS - Program and Implementation l
Work control procedure A-26-A allows anyone to identify a potential equipment problem by filling out equipment trouble tags (ETT), directly writing maintenance work requests j
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(MRFs), or filling out a money ticket (for non-safety related
,
and non-important to safety problems).
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The MRF document includes provisions to provide the necessary information to assure work is effectively accomplished, controlled, documented, and reviewed; however, Technical Specification requirements (LCO or time restraints) are not listed on the MRF.
A yes or no is shown to indicate whether there is a Technical Specification requirement for the component.
Emergency maintenance is controlled the same as normal maintenance, only that the procass is expedited and MRFs may be hand written instead of computer generated.
CONCLUSION
!
The MRF generally provides acceptable control of work.
Improvement is needed in identifying LCO time restraints, the safety significance of the work beir.g performed and in the prioritization of work (see III 5.4).
The MRF document and controlling procedure are weak in the above noted areas, however, licensee personnel indicated that the MRF document and controlling procedure are in the process of major revisions.
111.5.2 MAINTAIN EQUIPMENT RECORDS AND HISTORY SCOPE The purpose of this element was to evaluate the utilization and the effectiveness of equipment maintenance records including use of equipment history for trending. Completed work packages, methods of work preparation, work in progress (preventive mainte-nance), utilization of various computer programs, and controlling procedures were reviewed.
FINDINGS - Program and Implementation The 3 is no complete list of all equipment at PBAPS, instead there are over seven different equipment lists. The licensee's Nuclear Engineering Department has been assigned to create one official, complete Master Equipment List.
Work history is readily retrievable thru CHAMPS; however performance history is not available thru CHAMPS and is not integrated with work history.
MRFs are transferred from the active to history record of CHAMPS when work is completed and the MRF is closed-out.
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MRFs do not <nclude repair time, therefore, repair time is not included in work history.
However, the MRF is being revised i
to record repair time.
Repetitive failures of work on similar components cannot be readily identifiec' by using CHAMPS.
Two maintainance guidelines where recently issued to aid in the performance of component failure searchers to identify recurring problems and to aid in the perforrance of the failure report program.
NPRDS is l
generally used, when requested, for failure determination.
CONCLUSION
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Work history anc performance history is not integrated and repetitive failures of work on similar components cannot be
.
readily identified.
Therefore, root cause analysis and prompt
'
identification and correction of problems is not as effective as it could be.
111.5.3 CONDUCT JOB PLANNING l
SCOPE The purpose of this inspection area was to evaluate the extent that established procedural controls assure adequate job planning. Work in progress on 430V motor control centers (MCC),
Er.ergency Cooling Water (ECW) pump, and "E2" emergency diesel generator, completed work packages, and schedules for the two
week period from 7/11 to 7/22/88 were reviewed.
i FINDINGS - Program and leplementation Planning for the work observed appeared adequate.
Job planning i
j is generally ef fective in that the following was usually
<
i considered, documented, and included in the work packages.
- l Safety significance (if the component was safety related or
.
not, and if a technical specifications (TS) limiting condi-
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tion for operation (LCO) was associated with the component).
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Drawings, procedures, and special instructions necessary
to perform the work.
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Special tools necessary to perform the work.
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Estimate of number of perscarel required; however,
,
qualification requirements were not included.
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The radiation work permit (RWP) number is not listed on the MRF, just a "yes" or "no" to indicate that an RWP is required.
i Including an RWP number would provide better coordination and tracking of MRFs with RWPs.
CONCLUSION Job planning appears generally adequate.
Plans to upgrade
.
CHAMPS and the MRF include plans to strengthen the planning i
portion of the work process, which should increase effectiveness
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and efficiency.
111.5.4 PERFORM WORK PRIORITIZATION SCOPE The purpose of this inspection area was to evaluate the effective-ness of work prioritization considering safety significance,
!
probabilistic risk assesseent (PRA) criteria, and Balance of J
Plant (BOP) equipment effects on safety. Work schedules and
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l several completed work packages were reviewed.
FINDINGS - Program and Implementation Work during the current outage is prioritized and scheduled by system windows.
Each system is assigned a window (time period)
to complete all work on that system.
The system window concept is new for PBAPS and since the scope and extent of the current
,l outage has changed and broadened several times a conclusion of
j the complete effectiveness could not be reached.
,
The present non-outage work prioriti:ation process does not
i focus on the relative impact or potential impact on plant safety
or reliability.
For example: MRFs that have priorities to start immediately or correct within 2 days are often not started for several months.
However, changes are in progress to improve work prioritization to address the impact or potential impact
,
on plant safety and reliability.
CONCLUSION j
The system window concept for prioritization and scheduling for
outages appears to be an effective concept; however, an overall conclusion on implementation was not reached.
Non-outage work
'
prioritization is not effective, but changes are in progress for improvement.
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III.5.5 MAINTENANCE WORK SCHEDULING SCOPE The purpose of this element was to establish that maintenance work scheduling is controlled and that this control is effective in causing proptr maintenance to be accomplished on components important to safety and plant reliability.
Subjects reviewed /
inspected for this item included the scheduling of preventive, corrective and predictive maintenance, various programs and procedures associated with mair tenance scheduling, the assign-ment of work activities and the coordination of these activities, the prioritization and tracking of scheduled and completed work, the provisions for work deferral and the issuance of management reports by which the performance of maintenance is monitored.
FINDINGS Program An overall scheduling process has been established.
This process includes several computer generated programs.
These are (1) PREMIS, Project R> source Evaluation Management Information System and (2) CHAMPS, Computerized History and Maintenance Planning System.
PREMIS is a scheduling, work tracking, and forecasting tool while CHAMPS provides a system for administrative conteol of the Maintenance Request Forms (MRF) for all forms of maintenance.
In order to perform work and follow-up testing in an organized manner, system windows have been developed during which interrelated tasks and testing may be performed durir,; a specific time frame when specific equipment is available.
Administrative Procedures A-25, Preventive Maintenance Program and A-25.A. Instrument Preventive Maintenance Program define the responsibilities, performance and documentation of the PM program.
Predictive maintenance is now primarily vibration monitoring of certain equipment and sone limited oil analysis.
Administrative Procedure A-25, Preventive Maintenance Program provides for review of deferred PM tasks; also, a program for the deferral beyond restart of existing Unit 2 MRFs has been established.
Implementation Maintenance work scheduling is being accomplished through the use of both PREMIS and CHAMPS. All work groups receive
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daily, a schedule which identifies all activities assigned to them during the next eight days. The coordination of the
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schedule is accomplished through daily planning meetings.
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These meetings are an important aspect of the overall scheduling effort. Among the accomplishments of the meeting are resolution of schedule conflicts and the establishment of consistent direction to all work groups.
Work is scheduled and tasks are planned to include the
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number of man-hours required by each craft for specific portions o' each maintenance activity. Maintenance activities were verified to be scheduled in accordance with established outage windows.
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In the past both preventive and corrective maintenance had f
I bean deferred without benefit of any formal deferral
,
pre ess. A detailed review of previously deferred tasks was
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performed and MRFs written for work which was to be
,
accomplished.
To prevent a similar reoccurrence, steps have
'
i been taken to assure that deferred MRFs receive a detailed and documented review.
All FMs are scheduled to be performed prior to restart.
The mechanical and electrical j
PM procedure specifies all dQ maintenarre must be performed j
when due.
The I&C PM procedure is being revised and will i
include a similar provision.
The implementation of the Unit
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2 MRF deferral process was verified to be documented as j
required.
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It was noted the MRF priorities available for selection were inadequate to properly prioritize all work activities.
The
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licensee took immediate steps to improve the prioritization
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of outage and non-outage work. A draft MRF prioritization j
proposal was being circulated for comment at the close of j
the inspection, d
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CONCLUSION
!
i l
The team concluded that the PREMIS and CHAMPS computerized t
l systems as well as daily planning meetings provide good
tools for the scheduling of maintenance activities.
Controls needing improvement as a result of the reorganization
'
when identified appear to be addressed promptly. All safety related preventive maintenance will be completed prior to re-
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start. Other deferred maintenance is being thoroughly reviewed, i
Post maintenance testing requirements are being tracked to
assure their completion.
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111.5.6 ESTA_BLISH BACKLO3 CONTROLS SCOPE The purpose of this element was to establish if the mainte-nance backlog is being controlled, that deferred work is properly authorized and prioritized, an adequate maintenance staff has been provided, and no excessive work backlog exists.
FINDINGS Procram The licensee has establishad a Commitment to Excellence Task Force to review overdue PM5 ans1 previously deferred corrective maintenance for inclusion into the MRF process. A letter has been issued by the Superintendent - Outages, to address the review requirements for all Unit 2 MRFs.
The MRFs required for restart will be completed prior to restart and all other MRFs have a criteria for deferral established.
Balance of plant as well as safety related maintenance has been included.
Im g entation The licensee has reviewed past deferred raintenance and placed the work required to be completed into the work control system.
As of July 20, 1983, a total of 2075 Unit 2 MRFs remained to be completed prior to restart.
Unit 3 has a much higher number of MRFs to be corpleted since the emphasis has been on finishing Unit 2 first.
The average number of man-hours to complete a MRF has been 70.
A raintenince staff adequate to assure ccmpletion of necessary maintenance appears to have been established.
The recent reorgani:ation increased the staff by the addition of some contractors.
The maintenance staff is composed of approximately 75% PECo people and 25% contractors.
Formal status reports are being issued to provide management and the various groups associated with maintenance activities the current status of work.
CONCLUSION The licensee has reviewed the backlog of work which had been permitted to accumulate.
All work required to be performed has been entered into the work control program.
Numerous
,
performance indicators are available through computerized work controls, and formalized programs h3ve been established to defer work.
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III.S.7 PROVICE MAINTENANCE PROCEDURES
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SCOPE l
The purpose of this element is to establish the presence of i
l adequate development and control of maintenance procedures
as well as the implementation of these procedures.
Subjects
reviewed / inspected for this item included licensee Administra-
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tive Procedures dealing with; ti.e preparation of surveillance
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tests (A-47), Periodic Review of Procedures (A-36), Procedures
,
for Preparation and Distribution of Maintenance Procedures
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(A-19), and the preparation of instrument and control instruc-tions (A-48). Other documents reviewed in addition to selected maintenance procedures included a checklist for the review of
.
I upgraded I&C Surveillance Tests, Maintenance Administrative
Procedure (MA-17) for Generation Control and Revision of Standard Work Instructions (SWI), Maintenance Administrative
,
Procedure for Processing and Completion of a Maintenance Request
!
Form and associated Work Instructions (MA-21), Maintenance
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Department Writers Guides and Plant Operations Review Committee (PORC) Meeting minutes relating to Work Instructions and Mainte-nance Work Instructions.
i FINDINGS P.LO9LAR The licensee has provided instructions ind procedures for the development of maintenance procedures and other instructions related to the performance of maintenance.
A
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Maintenance Procedures Writers Guide is alsu available.
Maintenance (M) procedures are generated in accordance with Administrative Procedure A-19.
The "M" Procedures are the only PORC approved maintenance work control procedures.
Actual work is performed in accordance with (1) written instruc-tions on the MRF itself, (2) the PORC approved "M" procedures, (3) Maintenance Work Instructions (MWI), (4) Work Instructions i
(WI), and, (5) Standard Work Instructions (SWI).
In addition to these procedures, a large volume of Testing and Laboratory (T&L)
l Division procedures are also used by the I&C section.
The licensee's instructions for the preparation of procedures is being adhered to.
During the inspection the team did not identify any serious deficiencies associated with the content of maintenance procedures.
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Implementation Work to replace a bearing on the "2A" RHR pump motor did not include instructions or acceptance criteria as to the minimum diameter necessary for the bearing to fit the shaf t or the maximum temperature the bearing could safely be heated to without damage.
fhis situation was mitigated by prior craft training.
The licensee indicated that specific numaric limits on items like temperature will be included in future procedures rather than relying on memorization.
The detailed work instructions were in some cases noted to be lacking in providing specific numerical values or specific sequences of work where dependance on memory is not appropriate.
CONCLUSION Adequate guidance has been issued for the preparation of mainte-nance procedures.
Procedures were found to be prepared in accordance with this guidance, and were found to be adequate.
Several examples of failing to follow procedures were identified and i'rdicate a need for increased licensee attention in this area. Also, the licensee should evaluate the periodic review
,
requirements for plant maintenance procedures particularly in light of the generally accepted two year review specified for nuclear plant procedures.
!!I.5.8 CONDUCT POST MAINTENANCE TESTING SCOPE The purpose of this element was to verify that post-maintenance testing criteria have been established, documented, and implemented.
Subjects inspected in this area included Administrative Procedure A-26A, "Procedure for Corrective and Preventive Maintenance Using CHAMPS," licensee clarification of post-maintenance testing versus operational verification, licensee memoranda associated with post-maintenance testing, megger test results, completed MRFs, and completed Operational Verification Forms (0VF).
j FINDINGS i
Program The licensee's requirements associated with Post-Maintenance Testing (Operational Verification) are specified in Administrative Procedure A-26A, "Procedure for Corrective i
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and Preventive Maintenance Using CHAMPS." Operational verifi-cation is specified in section 2 of a MRF and the performance of the verification is controlled and documented in accordance with an Operation Verification Form (OVF), a part of the A-26A pro-cedure.
Surveillance Tests and Modification Acceptance Tests
,
(MAT) are PORC approved and specify the testing to be performed i
and tSe acceptance criteria.
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The requirements associated with post-maintenance testing
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specified in procedure A-26A are not as detailed as that i
which is reflected in various memoranda provided the i
inspector, nor does it make provisions for post maintenance testing and operational verification.
Licensee representatives indicated tne need for additional guidance relating to post-maintenance testing had been recognized and that a change to A-26A would be made and/or a specific l
post-maintenance testing procedure would be written.
Implementation The licensee considers post maintenance testing as functional testing of components affected by maintenance, prior to turnover to the station for operational verification; operational verification being performed to prove operability of the equipment within system parameters.
For the purpose of this inspection all testing af ter the performance of maintenance is considered to be pnst-maintenance testing.
Currently, post-maintenance testing is specified prior to the performance of the maintenance with a review before the opera-tional verification testing.
Specifying post-maintenance testing after the maintenance has been performed is being considered to assure that every disturbed component is
)
considered for testing, A large number of completed MRFs and OVFs were reviewed to verify compliance with procedural requirements.
In general, procedural requirements were found to be complied with.
Frequently a MAT or ST was specified as the operational verification method.
Instances were noted in which proper testing was not specified only general requirements such as
"verify proper operation"; also, in some instances the operational verification eethod was added during review and was not initially specified.
For one MRF duplicate, different
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OVFs were issued. Also, for MRFs inplementing PMs where megger testing was required, no acceptance criteria was specified.
The
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licensee stated appropriate acceptance criteria would be identi-fied for these FMs.
In no instance was an activity identified which would lead to an unsafe conditio =
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i CONCLUSION Generally, the licensee's program for post maintenance testing i
and the implementation of the program is acceptable.
However, to strengthen the program more detailed guidance should be provided relative to the performing of post-maintenance testing
,
to assure full implementation.
l 111.5.9 REVIEW OF COMPLETED WORK CONTROL DOCUMENTS
SCOPE
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This element involved an inspection of the method used to l
review and ensure completion of all documentation associated l
with MRF packages.
The timeliness and consistency of the
!
dpproaCh Was assessed.
FINDINGS Proaram
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The closure of PRFs that are intended to modify plant equipment
,
.J is handled by the Contruction Department.
Procedure A-14 (
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"Plant Modifications" has detailed instructions on closure requirements.
Any maintenance that resulted in a modification will also be transfered to the group for closure.
This ensures that the necessary procedure and drawing revisions are completed.
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When corrective or preventive maintenance is performed per
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procedure A26-A then closure is assigned to the responsible
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maintenance engineer who has been following the work, The
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l engineer completes a review using instructions in procedure i
MG-7.1-2 "Guideline for Control of MRF Closure Process" and fills in forms provided as attachment A and B to the procedure.
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I The completed MRF package with all documents and signed review
!
forms is then forwarded to the Nuclear Records department for l
storage.
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Closure of MRFs within the I&C Department is completed well i
but the process is not proceduralized.
However, some of the
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l informal controls are a strength.
For example, the I&C J
technician who signs MRF section 6 indicating completion of work
.
must be a level Il technician.
Completion is verified by an I&C l
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supervisor who also initials section 6 on the MRF.
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Implementation j
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j An NRC review of several recently completed MRFs found that the packages were complete and were reviewed in a timely fashion
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using the new procedure M3-7.1-2.
A minor problem involved i
unreadable signatures that prevent easy identification of the individual verifying completion of steps.
In the I&C department, there are three "coordinators" hired in March 1938 who function similarly to maintenance engineers.
The coordinators do a preliminary review and forward the completed i
package to the !&C Operations Engineer for final review.
However, there are no formal records to indicate that these final reviews were done.
In additiot,, the "Master Cal Sheet"
is pulled from the MRF package and the "Lifted Lead Log"
remains in the record.
There is no procedure that specifies I
which forms are to remain in the package sent to Nuclear
Records The I&C Engineer indicated that a procedure for
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closure will be issued soon.
Numerous completed or partially completed MRFs were reviewed to
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verify compliance with work tontrol procedures.
Completion of the MRFs was generally acceptable.
In some instances improvement would have been desirable particularly in the documentation of
work which was performed,
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The inspector noted that only certain supporting activities
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such as blocking permits and scaf folding are removed as MRF
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l section 6 15 completed, while others are not.
For example, no formal mechanism exists to cancel the R'a'P, close the ALARA package and cancel the confined space entry permit.
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CO_NCLUS_IO_N There are several redundant reviews of completed work r
documents. These reviews are well documented in the
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l Maintenance Department but need to be formalized in the I&C i
Department.
Some improvement is warranted regarding i
notification of HP, ALARA, and Safety personnel regarding i
completed work, a
j 111.5.10 REyIEW OF MAINTENANCE WORK IN PROGRESS
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SCOPE
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This element involved an assesseent of the extent to which maintenance is performed in accordance with maintenance
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procedures, administrative policies, and management goals and
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objectives.
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FINDINGS - Program _ and Implemntation
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The inspector observed work being performed in preparat'on for a hydrostatic test of the E-2 Emergency Diesel Generator
(CDG) Jacket coolant water system.
This work was being
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performed per MRF 8807276. The inspector reviewed this t
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work package and noted that no instructions were included
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in the work package for the removal of the heat shields and
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exhaust manifolds and for the repositioning of valve HV 052
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100408. When this was brought to the attention of licensee
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personnel, a revision was made to the MRF calling out the t
appropriate sections of procedure M52.2 for the hydro pre-
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paration work.
Part 5.1,6.1 of ANSI N18.7 which is invoked
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by the PBAPS Technical Specification requires maintenance to be performed in accordance with written procedures.
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j Contrary to this, no procedure was provided for performing
i the preparation work for the hydrostatic test of the E-2
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l EDG jacket coolant water system.
This is a violation as
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j noted in Appendix A (50-277/8S-17-02).
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The hydrostatic test of the E-2 EDG Jacket coolant water
system was performed using a permanently installed pressure gauge P1-0567B which is normally used to measure Jacket i
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coolant supply pressure.
There were no indications of calibration on the gauge and in response to questions, the
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licensee determined that the gauge was not in the calibra-
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tion system.
There was no evidence that the gauge had been i
calibrated since instcllation.
Licensee personnel stated
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that the jacket coolant supply pressure gauge was normally used in performing the EDG jacket coolant water system
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hydrostatic test.
This gauge (and the respective pressure gauges for the other diesels) had been previously used for jacket coolant, vater system hydrostatic testing not only
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for the E-2 diesel but, for the other three diesels as well.
Licensee personnel calibrated pressure gauge PI-0567
and found it to be within acceptable tolerances. The PBAPS Technical Specification invokes ANSI N18.7 which requires l
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that procedures be provided for periodic calibration of
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l safety related plant instrumentation.
The plant 0 list l
I identifies gauge pI-05678 as a passive Q component as it is part of the safety related pressure boundary.
The
indicating function of the gauge is not a safety related
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plant instrument during plant operation, however, its use l
l during water Jacket pressure testing causes it to have the
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j indicating function to be used for safety related purposes l
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during the pressure test.
This failure to provide the I
i required control and periodic calibration of pressure gauge
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PI-0567B is a violation (50-277/83-17-03).
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CONCLUSION
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I The inspectors identified several areas where additional l
attention should be given to procedural adherence.
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III.6,0 PLANT MAINTENANCE ORGANIZATION SCOPE
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The purpose of inspection in this area was to determine the l
extent of control of maintenance activities, personnel, l
documentation and cortmunication.
The implementation of maintenance objectives and response to problems and events
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were also reviewed.
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III.6.1 ESTABLISH CONTROL _OF PLANT MAINTENANCE ACTIVITIES
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SCOPE
r Inspection of this element was to determine the extent of established controls for performing maintenance activities
and to verify that these controls have been properly implemented in the mechanical, electrical, and instrument I
and concrol disciplines.
The review and inspection of the
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methods used for controlling maintenance activities included the following:
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Identification of the need for action
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Assuring plant and system integrity l
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Monitoring controls
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Rework and temporary repairs
Vendor technical manual control and updating
Control of personnel i
Control of procedures j
Control of material t
Control of tools and gauges l
Configuration control
Work performance accountability
III.6.1.1 MECHANICAL MAINTENANCE
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SCOPE
I Refer to paragraph III.6.1 above, j
The inspector reviewed mechanical maintenance work activities end procedures to determine the adequacy and extent of the program and its implementation as it pertains to mechanical maintenance.
Particular emphasis was placed on the motor operated valve (MOV) rebuild program.
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FINDINGS i
Program
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The inspector reviewed procedure A-26A, revision 7, "Procedure for Corrective and Preventive Maintenance Using CHAMP $."
This procedure described the method used to control maintenance
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I activities utilizing the maintenance request form (MRF).
Since
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vendor manual information is important to proper maintenance,
procedure A-92, revision 1. "Control of Vendor Manuals" was
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reviewed. This procedure described the methods presently in
place for control of vendor manuals.
Present methods of
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control did not appear to be adequate since no provisions were
made to limit access to or remove uncontrolled copies of vendor t
manuals from maintenance or other organizations. The inspector l
was informed that procedure A-92 was under revision to provide j
improvements in vendor manual control, j
t The program for the refurbishment of safety related and high priority MOV's (= 160 valves in Unit 2) is well defined in the
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MOV Rebuild Program Project Standard. Among the activities l
addressed in the standard are inspections, testing, j
refurbishment, procedure development, training, documentation
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of corrective actions, replacement parts, program organization,
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and quality control. Additionally, EWLs for modifications l
1915 and 2231 provided more specific direction regarding the l
work to be performed.
The actual work was accomplished in
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accordance with 15 field engineering procedures provided for i
the ~.4s6.
Implementati_on To verify proper implementation the inspector reviewed
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mechanical maintenance work in progress, maintenance related r
documents and records, and discussed maintenance activitics with
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licensee personnel.
The following observations were noted i
during these reviews and discussion.
- During the observation of the E-2 EDG water jacket hydro-static test, the inspectors noted an outdated uncontrolled
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copy of a vendor manual at the diesel.
This was determined
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to belong to one of tne licensee individuals working on the i
diesel, This is an indication the vendor manual control
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previously discussed is not working ef fectively.
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A number of manual valves located in the E-2 diesel room were noted to have dry stems. Although Zerk fittings
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were provided for stem lubrication there was no grease on
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the fitting or stem to indicate that the stems had ever (
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Licensee personnel stated that lubrica-
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tion of these valve stems would be included as a part of diesel maintenance in the future.
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a The inspector observed the removal and disassembly of the i
emergency cooling water (ECW) pump per MRF 6807300.
The l
shutoff discharge pressure for the ECW had low deadhead pressure during the performance of surveillance test
l ST 13.21. Physical inspection identified no cause for reduction in pump discharge pressure, i
The licensee subsequently determined by engineering evaluation j
that the Inservice Test (IST) criteria for the ECW pump did not j
isolate the Service Water System from the ECW system. Service Water System pressure is higher than the ECW pump shutoff dis-
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charge pressure.
The test performed on July 14, 1938 isolated service water for the first time since pre-operational testing and the correct ECW pump shutoff discharge pressure was recorded without the influence of service water.
However, the pressure recorded fell into the action range of the incorrectly established IST criteria and the test failed.
Based on this determination, it appeared that a valid ECW system test was never performed due to the improper valve lineup connecting the system to the service water system.
Licensee personnel stated that the event was being considered for reportability as a Licensee Event Report (LER).
In addition, the ECW surveillance test procedure ST 13.21 was to be revised.
The inspector reviewed six other mechanical MRFs.
No additional concerns were noted in the review of these docuttnts.
The valve refurbishtent program generally increased in scope as it was implemented. Overall the program was conducted in accordance with guidance provided in EWL's and the project standard.
The valve refurbishment program was audited by Bechtel and also included input frem arother utility. Detailed Safety evaluations were performed of the modification packages and significant PORC reviews were conducted.
Training was provided for personnel involved in the task.
A suitable work area was established, craftsmen were observed to be using procedures and checklists provided. Work was observed being performed in the presence of a vendor representative.
Engineer-ing support for the program was good.
Identified deficiencies were effectively resolved and feedback was provided to improve valve maintenance.
CONCLUSION The control of mechanical maintenance activi*.ies appeared to be acceptable, however, improvements can be made in so-e area _
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Specifically, improvements need to be made in providing adequate work instructions for maintenance activities. Also, controlled
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vendor manuals should ce made accessible to craft and support personnel. Uncontrolled manuals identified by the inspector
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during this inspection were placed under controls by supervision
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prior to the cotpletion of this inspection.
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!!!.6.1.2 ELECTRICAL MAINTENANCE j
SCOPE I
The inspector reviewed electrical maintenance procedures and (
work activities to determine the adequacy and extent of the i
program and its implementation as it pertains to electrical i
maintenance.
l FINDINGS Program
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l The progran for control of electrical maintenance is similar to l
the program for mechanical maintenance.
i Inplementation
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l To verify proper implementation the inspector revie,,ed electrical l
maintenance work in progress, maintenance related documents
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and records, and discussed maintenance activities with licensee l
personnel.
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The inspector reviewed the electrical aspects of six MRFs including those for the 2A RHR pump motor repair and E-2 E03
)
naintenance. No concerns were identified with regard to the j
electrical aspects of these jobs.
CONCLUSION The control of electrical maintenance activities was acceptable.
II 6.1.3 INSTRUMENT AND CCNTROL PAINTENANCE SCOPE Determine the method, controls, and accountability systems the licensee has estabitshed to maintain the work performed by the Instrumentation ard Control (!!C) maintenance organization on the plant safety-related components and systems.
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FINDINGS Program The inspector reviewed the I&C maintenance program as described in Testing and Laboratories Procedures TL-11-00100, TL-11-50014, TL-13-50009. TL-15-50015 and TL-11-2000.
These procedures describe the method that the I&C maintenance function follows to
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perform its task assignments In addition, to the above proce-dures, the inspector evaluated the !&C procedures for control of
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work, control of vendors' tecnnical manuals, personnel training, i
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tool control, jumpers and system blocking requirements and material consrol, f
Major procedure changes have occurred in the areas of vendor technical manuals, PRA training, and tracking system interfaces.
The existing vender technical manuals that were maintained by the I&C organi:ation have been turned over to a
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central organt:ation that will maintain and track the use of i
these cocuments.
It is also the responsibility of this
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central organi:ation to assure that only approved, updated i
copies are distributed to the maintenance 1&C technician.
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The quality organi:ation is revising their existing audit I
program to incluoe this vendor manual control function in their program audit schedule.
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Implementation The control of the I&C vendor technical manuals will be assumed by a central control organi:stion who in addition
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has a program for the control of all station vendor manuals.
l Administrative procedure A-92 revised on July 20, 1988, has l
4 program that includes a three month trial period that is i
scheduled to be completed by January 15, 1939.
The present
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!&C procedures, including revised copies, are in place and I
being imple'nented by the !&C technicians.
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Individual technicians interviewed by the inspector were l
knowledgeable of their procedure requirements and had a positive
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attitude about their work and supervision. x new tracking system designed to identify and track I&C concerns has been i
implemented. Also, a new trending program is another management control that has been developed to track the 11C program and identify problems.
C_ONCLUSION
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Control of plant I&C activities appears to be effectiv.
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!!!.6.2 CONTROL OF_ CONTRACTED MAINTENANCE SCOPE Inspection in this area was to verify that controls are in place to ensure that maintenance work performed by contractors is adequately performed and verified.
Procedures and guidelines for control of contractors were reviewed and records and other documentation for five contractors were reviewed.
FINDINGS P_r_og ram The inspectors reviewed administrative procedure MA-15, revision 3 "Maintenance Division Administrative Procedure for Use of Contractors for Work on Q-Listed Equipment." Guide-lines MAG-9, revision 2 "Maintenance Department Administrative Guideline for Venoor Control" and MAG-16, revision 0, "Mainte-nance Deportment Administrative Guideline for Bid Specification Generation and Vendor Coordination." The two guideline docu-
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ments (MAG-9 and MAG-16) address administrative controls of j
contractors rather than controls to ensure work meets regulatory l
requirements.
The procedure (MA-15), although brief, appears to i
be adequate for control of contracted maintenance of safety related equipment.
There did not appear to be a documented
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tregram to control contracted maintenance cf non-safety related i
equipment considered to be important to safety, j
l impleqentation
The inspectors observed maintenance work being performed by one of the larger site contractors.
The work was controlled in j
the same manner as work performed by licensee personnel and no
problems were noted. A review of documentation including the
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bic specification and record of audits performed for the contractor
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doing pipe replacement for Unit 3 indicated adequate t,ontrol.
Based on a review of work performed by small contractors the inspe: tor determined that maintenance and inspection were performed on Unit 2 and 3 drywell chillers by a contractor, Hull-Trane Company, Harrisburg, FA since 19S2 without MRFs.
Procedure A-26A, "Procedure for Corrective and Preventiv6 Maintenance Using CHAMPS," require.; a MRF to be initiat,ed for work on all
"Q" listed systems and equipment whose failure could result in a reduction of plant capacity.
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Emergency work was performed by the contractor at the request j
of the operations staff without direct knowledge of the mainte-
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nance department. Also, corrective and preventive maintenance and inspections were performed by the contractor when deemed i
l necessary by the contractor without direct knowledge or supervi-l sten of plant personnel.
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i Purc5ase orders PB271556 and PB306967AP required the contractor to cor. ply with the PECo QA Plan and with all PBAPS Administra-
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tive and work procedures, which includes procedure A-26A, The
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purchase order further requires that the contractor notify and
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work through the PEco Maintenance Department Field Representative; l
this was not done since no person was so designated.
i Failure to control contractor services as required by the l
purchase orders is a violation of 10 CFR 50, Appendix 8, t
Criterien VII as netto in Appendix A (50-277/83-17-04),
i Additionally, after the above problem was discussed with the I
licensee, the licensee identified a similar problem with work i
performed by a contractor, Johnson-Controls, on plant ventila-l tion controllers that were later established to not be safety
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related per EWR P-50316.
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CONCLUSION j
Maintenance of safety related equipment performed by large contractors appearad to be effectively controlled.
This represents the majority of contracted maintenance. Adequate i
program and implementation appe.ar to be lacking for contractor j
maintenance which is non-safety related but important to safety.
Control of work performed by small contractors is in need of attention to the degree required by applicable procedures.
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!!!.6,3 DEFICIENCY _ICENTIFICATION AND_ CONTROL SYSTEM j
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SCOPE Inspection of this element is to verify that a system has t41n
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established and properly implemented for prompt identification l
and control of plant ceficiencies and preblems. The inspection also verified that where applicable, the cause of t,he preblem is i
determined and action is t,aken to prevent recurrence.
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FINDINGS Program The licensee has several methods to identify cnd ensure cor ection of deficiencies.
In cases where individuals have direct access for inputting to the MRF computer system, a MRF can be initiated directly for correction of tha problem.
When problems with plant equipment are noted in tht plant by opera-
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tions and maintenance personnel an equipment trouble tag (ETT)
is used, t
The inspector reviewed procedure A-26A, revision 7, "Procedura for Corrective and Preventive Mainten=nce Using CHAMPS" which describes these methods.
The ETT s> cem requires the completion of an ETT tag when an equipment problem is noted; the hard copy
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of the tag is attached to the hardware and the soft copies are I
evaluated and used to initiate the Maintenance Request Form (MRF).
The MRF is then used by maintenance to document the problem, describe the planned repair, provide necessary repair instructions, document the work performed, describe required testing and to provide a record of all phases of the work.
Non-conformance reports (NCR) are used by the quality control and quality assurance organizations to identify nonconformances.
The inspector reviewed QADP-9.1, revision 2, "QC Procedure for Control of Nonconformances" which describes the methods for control of nonconformances.
The PPR, once initiated should result in the initiation of a MRF if the MRF is needed for correction of the deficiency.
Implementation During walk-throughs of the plant the itspector selected nine ETTs from equipment within several areas of the plant. MRFs had been written for eight of the nine.
The equipment for which the MRF had not been written was determined to be non safety related.
The MRF associated with one ETT had been closed and the ETT had not been removed from the equipment.
Since only one instance of this was found it appears to be an isolated case.
Most ETTs noted in the plant were recent and the oldest dated ETT noted was November 3, 1987.
CONCLUSION L
The methods used to identify and control deficiencies appeared I
to be adequate and effectively implemented.
No problems were noted in the program or its implementation.
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III.6.4 PERFORM MAINTENANCE TRENDING SCOPE Inspection of this area was to verify that methods have been established and implemented for detecting repetitive failures and adverse quality trends.
This includes a review of actions taken to correct adverse quality trends and the cause of repetitive failures.
FINDINGS - Program and Implementation The maintenance trending activities include the following two programs.
The Institute of Nuclear Power Operations (INPO) has established an industry wide parts information program called the Nuclear Plant Reliability Data System (NPRDS).
The licensee provides input into the NPRDS data base on components in those systems designated by INPO as having functions necessary for accident mitigation or which can initiate significant plant transients.
Information on these components can be retrieved for trending, failure analysis or other purposes.
The NPRDS system is standard throughout the industry and is described in INPO documents.
o The computerized history and maintenance planning system (CHAMPS) is used to maintain historical files of mainte-nance work as well as providing a method for tracking and controlling maintenance work.
The inspector reviewed MG-15.3 revision 0, "Guideline for Maintenance History Searches." This document provides the details and condi-tions for conducting historical searches on failed equip-ment using CHAMPS to determine if trends exist.
If repetitive failures have occurred then a request for root cause investigation and correction is issued.
For implementation of maintenance trending, the electrical /
mechanical and I&C areas have separate trending coordinators and perform separate trending.
Since the equipment is different in those areas, this does not pose a problem.
I&C also trends problems or failures encountered during I&C surveillance testing.
The inspector reviewed trending records in both I&C and electrical / mechanical areas.
Trends had been detected and reported.
CONCLUSION
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In the areas reviewed trending appeared to be acceptable, however, some improvements in trending could be mad O
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Trending was being performed for multiple occurrences within a year.
This trending period is short considering the timo between refuel outages is typically 18 months.
- The system does not readily detect repetitive occurrences of similar equipment problems.
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Present usa of NPRDS in trending is limited.
111.6.5 ESTABLISH SUPPORT INTERFACES SCOPE Inspection of this area was to verify that methods have been established and implemented to control interfaces between mainte-nance and support organizations.
This inspection included a review for adequate assignment of responsibility, communication, verification and reporting.
FINDINGS procram The inspector reviewed adure A-26A, revision 7, "Procedure for Corrective and Prevs - ve Maintenance Using CHAMPS." This procedure specified requirad actions by engineering, operations and QC.
Other organization interfaces and support are not addressed in this procedure.
Required supporting actions by health physics and procurement are covered in separate procedures which do not specifica' / address interfaces.
Implementation During observation of maintenance work the insp?ctors noted substantial involvement of supporting organizations.
During work on the 2A RHR pump motor, an individual from health physics was present during the motor disassembly to determine radiatior levels of components and to decontaminate components as they were removed.
Engineering support was noted on all three jobs observed. QC coverage was noted on two different occasions on E-2 diesel generator work.
Licensee personnel stated in discus-sions with the inspector that interface and support of mainte-nan:e by other organizations and groups was very good. An expeditor from the procurement organization is located within the maintenance organization to expedite parts needed by maintenance. Discussions with the expeditor and a review cf procurement tracking documents indicated that adequate tracking
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and status of items to be procured for maintenance was being maintained.
Interface with all supporting organizations and groups appeared to be adequat _
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CONCLUSION Although some areas for improvement exist in the formal program for organizational interfaces, support of the maintenance organization appears to be effective.
i III.7.0 MAINTENANCE FACILITIES, EQUIPMENT AND MATERIALS CONTROL SCOPE This area encompasses the plant maintenance facilities, equipment and materials control with regard to the part they play in supporting the maintenance process.
For NRC evaluation, this area was divided into five elements which were examined separately:
Maintenance facilities and equipment provided (Section III.7.1)
Materials controls (Section 111.7.2)
Maintenance totl and equipment controls (Section III.7.3)
Control and callbration af measuring and test equipment
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(Section III.7.1)
Plant condition ( extent of integration of facilities, equipment and material controls into the maintenance process) (Section III.7.5)
111.7.1 PROVIDE MAINTENANCE FACILITIES AND EQUIPMENT SCOPE The purpose of this element was to inspect the extent to which the plant facilities and equipment provided by the licensee enhance the maintenance process.
The NRC inspector evaluated this element through interviews with the Maintenance and !&C staff supervisor and various lower level supervisors and craft.
Tours of the plant, the maintenance personnel offices, shops, material and tool issue locations and warehouses were also conducted.
_F_INDINGS The inspector had the following findings in this area:
(1) Overall the facilities appear adequate for the conduct of maintanance.
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(2) The licensee plans to greatly increase their spare parts inventory and their current warehouse does not appear capable of supporting the increase.
Licensee personnel indicated there were plans to increase warehouse space.
(3) Although located close to the plant, the maintenance shops and personnel are in a separate building.
This requires personnel and components to proceed outdoors and through a security check point when moving between the shop / personnel locations and the plant.
Licensee personnel stated that possible changes to improve this situation were under review.
(4) Safety related and non-safety related items were observed stored together in the stagging cage located near the clean tool issue station. Also, there appeared to be insufficient space and organization within the stagging cage. However, items did appear properly identified such that safety and non-safety related items were not likely to be confused with one another.
CONCLUSION The licensee's facilities are adequate for performance of maintenance.
III.7.2 ESTABLISH MATERIALS CONTROLS SCOPE The purpose of this element was to rate the licensee's material controls in their support of the maintenance process.
The NRC inspector conducted examinations for this element by observing materials controls activities, interviewing involved personnel, verifying that material control activities were documented in proper procedures and records, and reviewing previously reported NRC inspections findings.
FINDI]jGS flesram The inspector had the following observations regarding the licensee's materials control programs:
The licenses does not have written guidelines for
handling emergency procurements.
However, unwritten expediting practices are in place.
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Administrative procedure A-27 (R20) describes site require-
ments and guidance for procurement, receipt and issuance of spare or replacement parts, material, and services for safety related equipment.
The licensee is in the process of developing a series of new procedures (designated A-129, 129.1, 129.2, etc.) which will replace A-27.
These pro-cedures will better reflect newly instituted organization and program changes aimed at improving nuclear plant activities.
Lower level Stores Division Administrative (SDA)
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procedures which address site materials controls activities need to be revised or replaced to reflect already implemented organizational changes and the new A-129 requirements.
Responsible site personnel recognize that these changes are needed and the changes are planned.
In response to NRC findings described in NRC Inspection
Reports 277, 278/87-23 the licensee has improved their program for procurement of commercial grade items for dedicated use in safety related applications.
Resolution of the NRC findings is described in NRC Inspection Report 277, 278/88-19.
Implementation The inspector had the following observations regarding implementation of the licensee's materials control program:
Based on observation of spare parts identification and
number control on computer anu review of records from procurement of welding rods (package order BW 219386) and Standby Liquid Control explosive valve repair kits (Purchase Order BW 385609), the inspector found the procurement processes to appear acceptably implemented.
Based on interviews with MOV Project and Procurement
Engineering Personnel, the inspector found that identification and specification of spare parts and consumables (e.g., lubricants) were satisfactory.
Based on discussions with stores personnel, observation
of stored parts and tagging and review of records, the inspector found that receipt inspection activities, traceability of document action and issuance were acceptable.
Numbers and locations of stored parts described in the
licensee's data base were found to be correct based on the inspector's observation of numerous stored item ~
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The following deficiencies were identified by the NRC
inspector relative to the licenser.'s storage:
As described in III.7.1(4) above, safety related and non-safety related items were stored together in the staging cage.
This is contrary to procedure SDA-5R6, Section 6.1.
The licensee has a shelf life log on computer which is used monthly to identify items whose shelf life is expiring such that evaluations for extension or replacement can be made to maintain minimum specified stocking levels.
The inspector selected three items; Standby Liquid Control (SLC) explosive Valve 115-73900, Repair kit for the SLC explosive valve and Limitorque declutch shift 0-ring 116-0128; and requested a check to see if their shelf lifes were in the computer.
A,though the inspector noted that the list contained many items, it contained none of the three that were checked.
Information with the Code 115-40315 valve repair kits in stock for Vendor Order No. 320-73186-380 ( f rom General Electric), states that the item has a one year storage life, a 3 year maximum inservice life and a 5 year total qualified life.
Storage beyond 2 years reduces the in service life. Contrary to this, the licensee specified a 5 year shelf life.
Procurement records for Standby Liquid Control valve repair kit code 115-40315, on purchase order BW 385609, contain the manufacturer's (Conax Corporation) Instal-lation and Maintenance Manual for the repair kits.
This manual recommends valve and/or kit storage at 70 20 F and states that temperatures as low as -65 F have not been shown to be harmful.
The lice.1see's valves and kits were stored in an uncooled area which was experiencing temperature exceeding the 90 F limit (possibly as high as 100 F).
The above deficiencies are a violation of 10 CFR 50 Appendix B criteria for compliance with procedural requirements (277, 278/88-17-05).
CONCLUSION The inspector determined that, overall, the licensee's materials controls were acceptable; however, several deficiencies as-sociated with correlating vendor recommendations with storage practices were identifie.
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III.7.3 ESTABLISH MAINTENANCE TOOL AND EQUIPMENT CONTROL SCOPE The purpose of this element was to determine the extent to which tool and equipment control had been documented and imple-mented and to assess its support of the maintenance process.
The NRC inspector conducted the insoection through interviews; observation of tool storage; and review of tool issue logs and tool control procedure.
FINDINGS Program Control requirements for calibrated tools are described in maintenance procedure MA-6(R7), "Calibration and Control of Maintenance Department Measuring and Test Equipment." MA-6 describes requirements for identification, storage control, maintenance, testing, calibration an,i issuance.
Issuance controls are manual.
s Rigging equipment, such as hoists and slings, are not issued as tools.
They are stored and issued from rigging rooms or cages.
There is no written procedure to describe their issuance or control prior to issuance.
They are identified, tested, inspected and certified in accordance with Standard Work Instructions (SWIs).
Handling lifting equioment is usea in accordance with Maintenance Administrative (MA) procedure MA-7 (R6-A1).
From a review of MA-7, SWIs and disc'Jssions with licensee personnel regarding the procedure, the inspector found that periodic documented inspections of slings in accordance with ANSI 1330.0-84 are not required to be performed.
Licensee personnel stated that they are committed to an earlier version that does not require the documented inspections but they perform visual inspection prior to use.
Implementation In a tour of the plant, the inspector observed that the licensee had at least four separate locations for issue of tools and rigging, plus additional locations (rooms and lockers) where tools are stcred.
This appeared to make control more di ficult f
although the tools may be more accessible.
Licensee personnel
stated that consolidation of some of these locations was under
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In the hot rigging storage cag6, which is often not manned, the inspector observed that a number of rigging items had been logged out weeks and months previously but never logged back in.
The inspector found that some items may actually have been i
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returned but never logged in due to the absence of personnel controlling the issue and return.
In addition, a search for several hoists revealed two that could not be located initially.
The inspector expressed concern that rigging did not appear to be wholly under proper control, however, the inspector established that rigging is safety checked prior to use.
t An NRC inspector observing pump maintenance (Emergency Cooling Tower Pump work performed on MRF 8807458) found that actual control and use of rigging for the job was well performed and documented.
The inspector observed that unsatisfactory or damaged tools were properly tagged and segregated from acceptable tools.
The NRC inspector reviewed work records of RHR valve 2-10-031A and identified four tools used in the work on that valve and verified that they had been properly controlled.
CONCLUSION The inspector concluded that the licensee's program for maintenance tool and equipment control and its implementation were adequate for support of the maintenance process but that some improvements could be made in the area of control and accountability for tool issuance and return.
III.7.4 PROVIDE CONTROL AND CALIBRATION OF METERING AND TEST EQUIPMENT SCOPE
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The purpose of this inspection area was to determine the extent to which test and metering equipment is properly controlled and calibrated.
The NRC inspector conducted the inspection / review needed to make this determination through interviews with in-volved personnel, observation of equipment for evidence of up-to-date calibration date stickers, and review of procedures and calibration records.
FINDINGS Program The on site requirements for control and calibration of test equipment are described in procedure MA-6, which was reviewed by the inspector.
The off site administrative procedure (TL-12-50008, R4) that provides for control and calibration was
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reviewed by the inspector and discussed with the responsible licensee personnel.
The inspector found that it together with the site procedure appear to be an adequate program.
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The off site facility has a computerized data base which tracks items for notification of the need for recalibration.
In this data base, specific individuals at the site are assigned responsi-bility for each item and those individuals are notified when recall is necessary.
The on-site system for issue and recall is cumbersome and time consuming but effective as compared to the offsite computerized systems.
The inspector was informed that installation of a plant specific system for Peach Bottom is planned.
Further, there are also plans to replace procedure T6-12-50008 with plant specific procedures though the corporate laboratory will still certify the site's measuring and test equipment.
Implementation The inspector observed or reviewed calibration and control on equipment as tabulated below:
Item Observed / Reviewed Breaker Test Equipment, Observed identification and Item 45-1140 sticker indicating date due and date calibrated
- Calibrated digital Reviewed record showing calibration thermometer for last check of weld electrode issue ovcns Gage blocks Item 4009 Observed identification, storage (a corporate lab item and reviewed traceability to used for calibration)
national standards Ultrasonic leak detector Observed identification and instrument, Item 24-0087 calibration sticker showing date due and date calibrated Standard sensor for Observeo identification and vibration test, calibration sticker showing date Item 34-1044 due and date calibrated In addition, the inspector interviewed calibration laboratory and issuance personnel regarding the practices used and observed the segregation of defective from good instruments and contami-nated from non-contaminated instruments.
The inspector did not identify any concerns in the licensee's implementation relative to this element other than the awkwardness of the manual issue control program described abov.
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CONCLUSION The inspector concluded that the licensee provides satisfactory control and calibration of metering and test equipment.
111.7.5 PERFORM PLANT CONDITION INSPECTION SCOPE The purpose of this inspection area was to determine the extent to which the licensee has integrated the facilities, equipment, and material cuntrol area inspections into the maintenance process.
The inspector reviewed administrative procedure A-30, Plant housekeeping controls; Plant Housekeeping Committee Meeting Minutes; selected completed housekeeping evaluation forms; and reports of open identified housekeeping deficiencies.
FINDINGS Program The licensee's program for the maintenance of plant cleanliness is contained in plant administrative procedure A-30, "Plant Housekeeping Controls." This is a detailed procedure which, assigns responsibilities for plant housekeeping, specifies plant
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housekeeping standards, establishes housekeeping zones, describes the responsibilities of the compliance coordinator, describes the use of "work incomplete tags," establishes requirements for management housekeeping walkdowns, provides for the establish-ment of a housekeeping committee, and specifies the documentation and the resolution of identified deficiencies.
Implementation During mid 1987 increased emphasis was placed on f acility housekeeping, and a housekeeping compliance committee, which meets monthly, was established.
The first committee meeting was conducted in June of 1987.
Formal meeting minutes have been published since September 1987 A Compliance Coordinator, who has three people working for him, was appointed in September 1987.
The compliance section established by A-30 conducts daily plant walkdowns, which basically cover the entire plant weekly.
Inspection results are documented.
At the time of the inspec-tion, 900 open housekeeping items were being tracked.
The compliance coordinator noted that operators, HPs, etc.,
frequently report housekeeping problems in accordance with facility policy. Management is kept informed of housekeeping activities by receiving Compliance Committee meeting minutes.
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Several tours of the facility were conducted to observe housekeeping conditions, areas toured included the reactor building, turbine building, condenser bay, water treatment plant and the diesel generator building.
The overall facility appearance was very good.
The procedurally required "Work Incomplete Tag" identifying items associated with work in progress was noted to be used where appropriate. Major portions of the plant had been recently painted.
Overall it is obvious a major effort has been taken to improve plant housekeeping.
In general the program established by A-30 appears to have been working as intended.
The compliance committee appears to be effective in bringing the development of deficiencies to manage-ments attention such that timely corrective action can be taken.
CONCLUSION The licensee has made a considerable effort to improve housekeeping throughout the plant.
A detailed housekeeping procedure is inplace and appears to be operating effectively.
III.8.0 PERSONNEL CONTROL SCOPE The personnel control area was broken down into four distinct elements consisting of staffing control, training, testing and quali-fication, and an assessment of current status.
Inspection activities consisted of interviews, training facility observations, field obser-vations, and document and record reviews.
III.8.I ESTABLISH STAFFING CONTROL SCOPE The purpose of this inspection area was to determine the extent to which personnel control is proceduralized and implemented in the maintenance process.
Subjects inspected for the staffing control element consisted of the following:
hire, fire and promotion policies; organizational charts; turnover minimization policy; shift coverage control and ecergency coverage control; job descriptions; manpower levels; and disciplinary actions.
FINDINGS Program The licensee's program for hiring, promoting and firing personr.el is detailed and documented.
Maintenance craft (
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personnel must be at least a high school graduate while I&C technicians must have a two year associates degree in electronics or have nuclear Navy electronics experience.
Applicants must pass an entrance exam to demonstrate minimum aptitude and are also interviewed to determine suitability for employment.
Promotions are based on training success and performance appraisals.
The company disciplinary policy is delineated in "You and Your Company," and provides a gradutted approach to enforcement.
Organization charts are stressed by the new Executive Vice President, Nuclear. A single group on site has responsibility for the organizational charts.
Single group control ensures that only one set of charts is circulated throughout the site.
However, the inspector determined that a formal program or policy was not yet in effect to periodically update the organization charts.
The company does not have a turnover minimization policy in effect.
However, turnover rates are tracked and a policy exists to notify appropriate management personnel if turnover rates increase.
A new job description program was instituted about April 1988.
Job descriptions. e standardized by using a job description
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writers guide.
However, there were no instructions in the writers guide that specified an update interval for job descriptions.
Maintenance and I&C manpower is tracked by computer management programs and organizational charts.
Provisions for addition or reduction in craft levels is determined well in advance by planning and scheduling personnel.
Shift coverage control and emergency coverage control are determined by oral meetings, emergency call-out procedures, work schedules, craf t breakdown charts and overtime procedure policies.
Implementation The hiring and promotion policy is being implemented as stated by the licensee's program.
Termination of employment of person-nel in accordance with the disciplinary policy had been applied
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infrequently.
However, the new management team at Peach Bottom now effectively utilizes disciplinary action as evidenced by recent firings of maintenance personnel for illegal drug involve-
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ment.
The maintenance and I&C superintendent and assistant superintendent recalled, four or five additional instances of disciplinary actions
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against workers. These incidents were generally minor in nature (failure to follow procedures, absenteeism) and the worst case received a several day suspension.
Radiological Occurrence Reports written during the last three months against maintenance and I&C personnel were minimal in number and minor in significance.
The inspector found the organization charts to be available, up-to-date, and detailed.
The supervisor to worker ratio was determined to be approximately one to ten. Although no formal program or policy exists to update the organizational charts, the inspector determined that the responsible work group keeps their computer up-to-date weekly.
PECo does not have a turnover minimization policy established, although turnover rates are tracked by corporate headquarters.
Supervisory personnel stated that high turnover rates would be noticed and brought to appropriate management attention for action.
The turnover rate in the maintenance and I&C section is well below I?4 per year.
The low turnover rate was confirmed through discussions with maintenance and I&C supervision as well as workers.
Revised job descriptions were in place for management and supervisory personnel down through the senior engineer level.
However, worker level job descriptions were over ten years old and outdated.
Personnel manpower levels are tracked and documented according to the program.
The mobile maintenance group of about 250 personnel is tapped for maintenance craft workers during peak conditions such as refueling outages.
Personnel from Limerick, including I&C technicians, are also used during peak periods and contractor assistance is used as needed.
However, according to recent organization charts, there are numerous vacancies noted in the entry level craft and I&C positions at Peach Bottom.
Shift coverage control and emergency coverage control function according to the program.
The four maintenance and I&C personnel interviewed, stated that shift coverage was smcoth and emergency call-outs were infrequent.
CONCLUSION The inspector concluded that programs covering the various subjects were generally well established.
Two minor shortcomings noted were the lack of a program or policy to periodically
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The inspector concluded that implementation of the programs for staffing control is adequate.
An upcoming organizational streamlining process and a new mobile maintenar.ce group policy will allow Peach Bottom to abolish current entry level vacancies.
Inconsistent use of the disciplinary policy in the past, outdated worker level job descriptions, and numerous vacancies in entry level craft and I&C positions were noted deficiencies. However, the new management team is more aggressive on disciplinary issues, and remaining job descriptions are being updated.
III.8.2 PROVIDE PERSONNEL TRAINING SCOPE The purpose of this inspection area was to determine the extent to which training is implemented and documented in the mainte-nance process.
Subjacts reviewed / inspected for the personnel training element consisted of the following:
INPO accreditation of the training and qualification (T&Q) program; general train-ing; specific training; safety related training; and special training.
FINDINGS Program The licensee's training and qualification program is currently INPO accredited in the three areas of interest:
Instrumenta-tion / Controls; electrical maintenance and mechanical maintenance.
General training is well documented and detailed and is provided to new employees.
Specific training is provided to workers that advance beyond the core training program and niaintenance helper training program.
The methods and lesson plans are well documented and detailed.
Safety related training is part of the entire training process.
In addition, the Nuclear Professional Training (NUPRO) Plan is a systems oriented course that provides interrelations between plant systems and components and stresses their safety related aspects.
Special training is carried out by the continuing training program. A formal program a.1d lesson plan is established for the I&C workforce.
A formal program is not established for the maintenance craft.
However, continuing training for craf t workers is identified by supervision, and then is developed, implemented and documented according to established procedures; this special training is provided on an as needed basis,
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Maintenance craft training is provided at the Barbadoes Maintenance Training Facility located in Norristown, Pennsylvania.
The facility is specifically geared-up to provide nuclear related training.
Implementation During gene-al new hire training, both I&C and craft workers are oriented to procedures, plant systems and radiation protection.
All employees are required to take a one week General Employee Training (GET) course before entering Peach Bottom.
Entry level I&C personnel are required to enter a core training program that lasts approximately 18 months.
During this period, the individual receives classroom, laboratory, and on-the-job training.
Craft workers are required to enter the helper training program conducted at the Barbadoes Maintenance Training Center (BMTC).
For 24 months, the maintenance craft worker receives classroom and laboratory training at BMTC, as well as on-the-job training at Peach Bottom.
Comprehensive exams are given throughout the period for both I&C and maintenance trainees.
Specific training is provided to I&C and craft personnel as they advance beyond the core training and helper training programs.
I&C personnel receive training through the use of lesson plans, laboratory exercises, on-the-job training self study guides, and modules.
Comprehensive examinations are given throughout the process and the program takes a minimum of 42 months to complete.
The craf t worker receives training through the use of classroom lectures, laboratory instruction, and on-the-job training.
Advancement through the training program is based on passing three different qualifying examinations.
The program takes a minimum of 15 months.
Maintenance craft continuing training is carried out on a as needed basis when special procedures or modifications are necessary.
During the past year, approximately forty specialized training classes were held either on site or at Barbadoes.
Examples include Raychem splices and motor operated valve analysis testing.
I&C and craft workers are exposed to safety related training throughout their respective training program. Only experienced workers are allowed to work on safety related components; trainees may only assist more experienced workers.
The NUPRO program is given to workers that have advanced to more responsible positions and usually occurs after three years.
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The Barbadoes training facility is a retired fossil plant that is being used for maintenance craft training.
The inspector toured the facility on June 30, 1988.
The inspector noted that Barbadoes has acquired special tools and machinery specifically
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used at nuclear power plants.
The training department has added personnel experienced in radiological controls to work with the craft while in training.
Mock-ups were evident and dressing out in anti-C's is part of maintenance training tasks performed.
Some mock-ups noted by the inspector were:
an under vessel model to practice pulling control rod drive mechanisms; a control rod drive; hydraulic control units; a main steam isola-tion valve; a Limitorque motor operated valve; snubbers; a turbine generator; and a reactor coolant pump seal. While performing maintenance activities on these mock-ups, the craft workers actually use the latest revision of the Peach Bottom procedures.
The inspector also noted the use of excellent video tapes for refuel floor training activities.
CONCLUSION The inspector concluded that the training program and its implementation were well established and documented.
The maintenance group does not have a formal continuing training program in place for the craf t.
This was identified by the licensee during their preparation phase for this team inspection and the licensee is currently working an establishing a formal program.
111.8.3 ESTABLISH TEST AND QUALIFICATION PROCESS SCOPE
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The purpose of this area of inspection was to determine the extent to which testing and qualification of maintenance personnel is integrated into the maintenance process.
Subjects inspected in this area consisted of the qualification process, documentation of personnel qualifications, and traceability of personnel qualifications.
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FINDINGS Program The testing and qualification program is well documented and established for both the maintenance and I&C groups.
Mainte-nance craf t workers are trained and tested under a very stringent program.
Craft workers take a certain number of courses prior to taking a qualifying examination to reach the next higher plateau.
The testing and qualification program for I&C techni-cians is not as stringent.
A specific curriculum is not speri-fied to be completed prior to an I&C technician advancing to a
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higher qualification level.
However, by the time an I&C technician has completed 42 months of training, all required courses have been completed.
The current in place training plan and procedures reflect the old PECo organization.
The I&C training plan and procedures at Peach Bottom are still Testing j
and Laboratory Division procedures from the Engineering and Research Department. Maintenance training plans and procedures
also reflect the old Electric Production Department.
There currently is a major effort in place to update and standardize these plans and procedures.
Personnel qualification records are documented and traceable although these records could exist in as many as eight different data bases.
The licensee is currently
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examining options to place these records into one data base, Implementation Although the training plans and procedures reflect the old PECo structure, they are adequate and well implemented.
The inspector examined testing and qualification records of four maintenance and I&C workers.
However, records for maintenance and I&C personnel are presently stored in eight different data bases.
Five of these are computer data bases and three are hard copy files.
If the training status of any PECo maintenance or I&C employee needs to be determined, it would be necessary to review different sources.
In addition, no single person has access to all the files.
The licensee is currently investigating methods so that all training records can be condensed into one data base.
CONCLUSION The test and qualification process is in place and being implemented.
However, the program does not reflect the new organization.
The licensee is currently working to standardize the qualification plans and procedures and make them consistent with the new organization. With regard to qualification records, a centralized system would greatly enhance the process.
111.8.4 ASSESS CURRENT STATUS SCOPE The purpose of this element was to inspect and rate the current status of personnel control.
Subjects inspected in this area included the licensee's fitness for duty program and work performance by unqualified personnel.
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FINDINGS Program A new, comprehensive drug policy went into effect on July 1, 1988.
The policy provides for random testing of all executives and employees granted unescor'ed access to Peach Bcttom, and requires the mandatory terminatiori of anyone found selling, distributing, buying or using drugs.
The performance of work by unqualified personnel is prevented by the licensee's training program, testing and qualification program, and overall staffing control program.
Implementation The new drug policy is being aggressively implemented. A recent example was the firing of maintenance personnel for illegal drug involvement.
Random drug testing of personnel granted unescorted access into Peach Bottom is scheduled to begin August 1, 1988.
Maintenance sub-foremen, and I&C supervisors, engineers and technicians have informatien at their disposal to determine worker training status.
First and second level I&C technicians and first level craft workers can work on safety related equip-ment. Other, lesser qualified individuals can only assist top level workers on safety related jobs.
CONCLUSION The licensee has a comprehensive drug program to ensure worker fitness for duty and is implementing the policy aggressively.
The qualification program for maintenance personnel is adequate and appears to be effectively implemente. _ _ _ _ _
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PRE INSPECTION INFORMATION REQUEST
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FOR PBAPS-U2, U3 To help in the preparation of the site survey, we ask you to provide us with the following documents:
- Administrative Procedure: Maintenance and Predictive and preventive Maintenance activities.
- Organization Chart (with names) for maintenance organization and plant-wide organization,
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- Composition of craft personnel fort tiectrical.14C Mechanical (Foreman to craft ratio, etc.).
- Description of Planning Department / Activity.
- Description of daily meetings for maintenance planning, scheduling, status reports, etc.
- Description of Maintenance / Operation Interface durins planning, scheduling, work close-out, and post esintenance/ functional testing.
- Description of Work Centrol Process:
1.e.. how 'thrk order is started, p~ anned, executed, completed, closed out and equipment is returned to swrvice.
Provide procedure.
- Description of Post-Maintenance / Modification testing and requrements.
- Description of craft training and retraining requirements.
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Average years of experience for each craft discipline. Turnover rate by craft
- Description of interface /connunication between Technical / Engineering support staff / Plant Modifications /QA-QC/ Maintenance Department
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- Description of procedure controle initial write-up, validation, revision or upgrade. Technical review and human factors review criteria.
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Requirements for conduct of maintenance work troubleshooting work closed out, post maintenance / functional testing, anI retsening of equ,ipment/ system to normal 11ne-up.
- Description of methods in which the performance of the maintenance department is measured, e.g., are indicators used, how frequently, who is informed?
- Description of process on communicatten with vendor for technical services and latest technical information on equipment and systems installed at i
Plant site.
Interface with vendor /N555 for training, modification and replacement.
- Provide five Maintenance procedures (randomly selected Mt MOVs. PRYs.
Containment Pump / Motor Sattery. Switchgea,r. etc.).
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APPENDIX 1
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- provide five Corcleted Nafntenance Work Order packages (randomly selected).
- Nscription of shift work and work assignment (e.g., how foreman decides on which craf t to perform what type of work).
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' Complete description of the oreventive maintenance program:
- How equipment is to be ingluded
- How frequency is detersined
- How execution is planned
- How it is going to be updated
- Complete description of oredictive maintenance program:
- Which equipment is included
- What methods used: oil analy. vibr. therzography etc.
- Methods of record keeping
- Is it going to be updated
- Concerning annagement:
- Are there goals set for the maint. dept.
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- What schedule?
- What n.ilestones?
- Are goals in performance evaluation of managers and supervisor 27
- Are goals connunicated to first line supervisors and crafts?
- MaintenanceWorkOrders(MWO)
- Cerrent number of non-outage corrective MWO by priority
- Definition of priorities
- projected number of corrective W0s to be outstanding at start up by l
orlority
- Current number of preventive maintenance work orders over due
- Rate of completion of corrective WO in terms of number completed / month and aanhours expended-Estleatedaanhoursrequ(6ycraft)/monthforthepast4 months ired to complete W0s both current and projected at start-up broken down by craft
- Rate of completion of preventive WO in terms.Af number completed / month and manhours expended on pM MWO/ month foF the phst 4 months
- Estimated aanhours required to complete current overdue PM MW0s
- Status of current W0s (e.g. lack of parts, number on hold for, number in planning, number in final sign off, number on hold for d
I engineering assistance, number available to be worked on)
- Number MW0s requiring rework over past 6 months.
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APPENDIX 1-3-MAINTENANCE QUESTIONS - PEACH BOTTOM 1.
What equipment failures occurred during the last year of operation?
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What equipment failures have been found during shutdown of plant?
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Describe maintenance and testing for diesel generators and electrical equipmant including switchgear that would be required in case of loss of offsite power?
4.
What controls separate Unit 2 from Unit 3 for maintenance and post maintenance testing?
5.
What is maintenance work schedule for 7/11 - 7/22/88 including 2nd and 3rd shifts. What components and tasks are planned for work?
6.
What component failures present greatest risk to plant?
7.
What have been the areas of high maintenance activity on safety related and non safety related equipment and components.
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e ADPENDIX 2 PERSONS CONTACTED Philadelphia Electric Company (PECo)
- H. R. Abdendroth, Atlantic Electric Company
- Charles Anderson, Staff Engineer (Under Technical Superintendent)
- Dave Pertocchi, Technical Assistant - Corpliance Group Howard Birch, Staff Assistant for Superintendent of Administration
- D. G. Brown, Materials Superintendent Dennis Burgard, Senior I&C Technical Assistant (Unit 2)
John Carolan, I&C Supervisor
- B. L. Clark, Superintendent Administration Jim Cook, Maintenance Supervisor
"T. F. Cribbe, Regulatory Engineer
- G. F. Daebeler, Superintendent Technical
- John Davenport Engineer-in-Charge Maintenance !&C
- Tony Donell, Assistant Suparintendent - Operations / Audit (QC)
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- John Franz, Plant Manager
- Al Fulvio, Department Head, Systems Engineering Hossein Ghodrat. Document Control / Procedure Control Supervisor
- Andy Hegedus, Assistant Engineer to Project Manager Tom Heyer, Assistant Maintenance Engineer John Hufnagel, Coordination Engineer Doug Keene, I&C Operations Engineer
- Frank Lear, Licensing Section Engineer (Licensing)
Don Lee, Dutage Planning Engineer
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George Lengyel, Area 1 Maintenance Support Engineer
- D. P. LeQuia, Superintendent Plant Services
- John McElwain, Maintenance Engineer
- C. A. McNeill, Jr., Executive Vice President-Nuclear
- Terry Netzer, Superintendent Planning, Scheduling and Reporting Group
- D. P. Potocik, Senior Health Physicist
- Mike Pratt, Quality Manager Jack Purcell, HP Supervisor
- Gerry Rainey, Maintenance and 1&C Superintendent John Regenmuser, Maintenance Engineering Group Joe Sample, f.enior Instructor, 1&C
- D. Smith, Vice Presicent, Nuclear J. Stankievicz, Director, Barbadoes Training Section Michael Walk, Staff Assistant for Superintendent of Administration
- Jim Wilson, Dutage Superintendent Ernie Tills, Superintendent of Training Others Tom Magette, Power Plant Siting, Nuclear Evaluations, State of Maryland Stan Maingi, Pennsylvania DER indicates presence at the July 22, 1928 exit meeting.
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