IR 05000277/1993014

Insp Repts 50-277/93-14 & 50-278/93-14 on 930621-25.No Violations Noted.Major Areas Inspected:Administrative Procedures,Control of Minor Maint & Troubleshooting Activities & Performance of Maint Activities

ML20046C450
Person / Time
Site:	Peach Bottom
Issue date:	07/12/1993
From:	Blumberg N, Fred Bower NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20046C444	List: IR 05000277/1993014 ML20046C443
References
50-277-93-14, 50-278-93-14, NUDOCS 9308110037
Download: ML20046C450 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REPORT NOS:

50-277/93-14 50-278/93-14 DOCKET NOS:

50-277; 50-278 LICENSE NOS:

DPR-44; DPR-56 LICENSEE:

Philadelphia Eic;iric Company Nuclear Group Headquarters Correspondence Control Desk P. O. Box 195 Wayne, Pennsylvania 19087-0195 FACILITY NAME:

Peach Bottom Units Nos. 2 and 3 P

INSPECTION AT:

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Delta, Pennsylvania INSPECTION CONDUCTED:

June 21 - 25,1993 INSPECTOR:

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d F. [. Bo'wer, Reactor Enginee D6te /

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Performance Programs Section Operations Branch, DRS

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APPROVED BY:

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orman J.18umberg, Chief f Date

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Performance Programs Section Operations Branch, DRS

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9308110037 930713 PDR ADOCK 05000277 G

PDR

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Jnsnection Summnrv: Inspection on June 21 - 25,1993 (Inspection Report Nos. 50-277/93-14 and 50-278/93-14)

Areas Insnected: An announced inspection was performed to review areas important to the health and safety of the public and to determine if the licensee had adequately implemented

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their maintenance program in accordance with regulatory requirements in the areas of:

j administrative procedures; control of minor maintenance and troubleshooting activities; performance of maintenance activities; maintenance records; and personnel qualifications.

Results: The implementation of the maintenance program areas reviewed was found to be acceptable. The administrative procedures for the control of Minor Maintenance activities i

were found to contain limited details but were adequate. Good administrative controls are provided for the Troubleshooting, Minor Rework, and Testing Support (TMT) process.

After reviewing a TMT activity related to the failure of the HPCI testable check valve to stroke when tested, the adequacy and consistency of the documentation of the troubleshooting activities performed was questioned. A review of other completed TMT records identified additional examples where the documentation of TMT activities was inconsistent in that: (1)

l the documentation of the as-found conditions was incomplete; (2) documentation of the repair methods and the activities performed were incomplete; (3) measuring and test equipment used during TMT activities was not consistently documented; and (4) documentation of all work performers was incomplete. As a result, licensee management initiated a formal evaluation to develop corrective actions to address this concern. The development of troubleshooting training is an excellent initiative and the draft lesson plans were found to be of good quality.

The minor maintenance activities observed were conducted in a generally safe manner.

J Maintenance technicians were observed changing the state of a breaker, working on a de-energized breaker that was not tagged, and taking measurements inside an energized breaker

without an established safety boundary was in accordance with plant procedures including the l

" Clearance and Tagging Manual" (CTM). It appears that the CTM does not provide clear l

guidance to identify what are valid reasons for not having a clearance to de-energize a power supply or breach a system for maintenance activities. Additionally, no precautions or limitations are proceduralized for performing maintenance without a clearance. A related concern was previously identified in Region I Inspection Report Nos. 50-277 & 278/93-08.

Licensee management committed to review and evaluate this concern and the possible need for changes to the CTM or the minor maintenance administrative procedures. The licensee's commitment was verified at the exit meeting.

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t DETAILS 1.0 PERSONS CONTACTED Attachment I provides a listing of persons contacted during the inspection.

2.0 MAINTENANCE PROGRAM IMPLEMENTATION (62700)'

2.1 Scope

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Proper maintenance is important to the safe operation of the facility. To verify plant safety, an inspection was conducted to determine if the licensee had adequately implemented their

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maintenance program in accordance with regulatory requirements in the areas of administrative procedures,. control of minor maintenance and troubleshooting activities, l

performance of maintenance activities, maintenance records, and personnel qualifications.

Attachment 2 provides a list of documentation reviewed during this inspection.

2.2 Review of Procedures Associated with the Control of Maintenance Activities Procedures pertaining to the control of maintenance have been prepared by the licensee.

Portions of the procedures that relate directly to the control of maintenance activities were reviewed by the inspector during this inspection and are listed in Attachment 2. The scope of the inspection did not include a detailed review of each of the listed procedures.

However, the review performed identified that a system has been established for the

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administrative control of maintenance and to provide instructions for the documentation of

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work activities. The system consists of Administrative Procedures that provide policy and identify many related commitments, and Administrative Guidelines that provide detailed process instructions and a few commitments that are related to specific process steps. The number of procedures and overlapping between procedures contributes to the complexity of the system. In spite of the complexity, the procedures appeared to be effectively used and i

i adequately maintained. In general, the procedures were found to be adequate and no

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significant concerns were identified. Some of these procedures are reviewed in more detail in the following sections.

2.3 Control of Minor Maintenance Activities Administrative procedure A-26 provides the administrative controls for minor maintenance.

Minor maintenance is a mechanism that the licensee uses to perform maintenance activities that do not require a work order or a clearance (blocking and tagging), and require minimal

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This identifies the inspection procedure number used during the conduct of this

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inspection.

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instructions. Minor maintenance tasks may or may not require the use of a procedure.

l Minor Maintenance is defined, by A-26, as actions for deficiencies on station components or parts where the following conditions are met:

1) the component is not Q (safety-related), Augmented Q, EQ (environmentally qualified), ASME XI, Tech Spec. or seismic or, if it is, the portion'or part being worked does not perform or affect a Q (safety-related), Augmented Q, EQ (environmentally qualified), ASME XI, Tech Spec. or seismic function; 2) welding is not performed on these structures systems or components; 3) detailed planning is not required;

4) detailed post-maintenance testing is not required; and 5) shift management (operations) is notified and approves work prior to its start.

For guidance an administrative guideline, AG-26.ll, associated with procedure A-26

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provides some examples of what is and what is not Minor Maintenance. In accordance with administrative guideline AG-26.ll, minor maintenance activities are planned, controlled, authorized and documented through the use of the licensee's deficiency reporting system, the Action Request (A/R) process, in the Plant Information Management System (PIMS). Using the A/R process for minor maintenance activities, in lieu of the W/O process, eliminates

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some of the administrative controls and burdens that the licensee believes accompanies the W/O process.

i Discussions with licensee personnel indicate that the use of the A/R process for performing minor maintenance precludes the use of a clearance for blocking and tagging to perform the minor maintenance. Therefore, minor maintenance is not performed where a clearance is required. Licensee personnel also indicated that minor maintenance does not typically apply

to activities that would take longer than a shift. The inspector noted that these conditions are not proceduralized in A-26 or AG-26.ll. It was also noted that the procedures level of detail of the guidance, precautions, and limitations associated with accomplishment of minor maintenance was limited. In general, these procedures were found to be adequate.

2.4 Observation of Minor Maintenance Activities

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During this inspection, portions of two minor maintenance activities were observed.

The first activity involved the replacement and recalibration of a circuit card in the 2C

condensate pump vibration detection equipment in accordance with A/R A0714302. The A/R identified a calibration procedure IC-11-00001 and a lifted lead documentation procedure IC-11-00100 to be used for this minor maintenance. Preparation for performing the work,

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including obtaining test equipment, reviewing applicable procedures and technical manuals, P

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and obtaining the operations shift supervision approval was observed. During the performance of the work, the I&C technicians were observed to control properly and document the replaced card and lifted leads in accordance with procedure IC-11-00100.

Periodic supervisory oversight was evident. No concerns were identified by the inspector.

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I The second minor maintenance activity involved the replacement of the "B" drywell area unit cooler fan motor thermal overloads in breaker 2BV026B ir accordance with A/R A0759223

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to meet new design specifications. Work was initiated, at the site of the breaker, by requesting the control room operator to secure the fan from the control room. Then the 480V AC breaker was turned offlocally, was opened, and was verified de-energized with a

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meter by the technicians performing the work. The overloads were replaced and verified to be properly installed by both of the technicians. The breaker was then reenergized by the technicians locally. After the control room restarted the fan the maintenance technicians changed the fan speed locally as required to obtain ampere readings from inside the energized breaker cabinet.

The inspector noted that this minor maintenance activity was conducted without a procedure

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in a generally safe manner, but the maintenance technicians were questioned as to whether the maintenance technicians changing the state of the breaker, working on a de-energized breaker that was not tagged, and taking measurements inside an energized breaker without an established safety boundary was in accordance with plant procedures including the

" Clearance and Tagging Manual" (CTM). The technicians indicated that these actions are typical of those performed during minor maintenance activities. This issue is discussed further in the next section.

2.5 Review of Completed Minor Maintenance Records

The inspector reviewed a PIMS database listing of approximately 1500 minor maintenance i

A/Rs. It was noted that the majority of'these items (approximately 77%) were non-Q (nonsafety-related). From this listing a sample of approximately 75 minor maintenance records from the PIMS system were selected for review. The sample included items from each of the quality classes. It appeared that all of the items reviewed met the criteria for being worked as minor maintenance. In general, it appeared that the items reviewed were controlled, performed and documented in accordance with the licensee's procedures.

' However, the inspector questioned whether several of the items that involved de-energizing

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electrical equipment and breaching systems should have been performed with a clearance for blocking and tagging to protect personnel from the potential energy source. The inspector reviewed the Clearance and Tagging Manual (CTM) and discussed this concern with licensee personnel including managers from the operations and maintenance departments.

• I Several examples of minor maintenance A/Rs concerning work performed that required breaching a system or de-energizing a power supply were reviewed with licensee personnel.

Of the examples reviewed none appeared to involve a nuclear safety issue; however, the

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inspector questioned how personnel safety was maintained. Review of the A/Rs with

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licensee persor indicated that, in general, the work performed was adjacent or in close proximity to ' ; valve isolating the pressure source or the de-energized breaker. It was also stated that fc. those instances where the work was out of the line of sight of the isolating valve or breaker that an individual would be stationed to ensure that the state of the

equipment would not be changed. Licensee management stated that it is left to the experience, judgement and training of the individuals proposing to do the work and the operations shift supervision authorizing the work at to whether a clearance is required to perform work that removes equipment from service, breaches a system, or de-energizes a power supply.

The CTM defines " clearance" as the isolation and de-enerization of plant equipment to ensure the protection of personnel and equipment while maintenance and modifications are being performed. The scope of the CTM states that it applies to all plant equipment or that equipment at the site directly associated with plant operations. The clearance standards / general practices section of the CTM states, in part, "A clearance SIIOULD be issued when the work to be done necessitates the removal of equipment from service, a system breach, or de-energizing a power supply. The CTM definition of "should" states that it denotes a recommendation and it is expected that the activity will be performed in the recommended manner unless the user has a valid reason for deviation.

The inspector expressed concern that the CTM does not provide clear guidance on valid reasons for not having a clearance to de-energize a power supply or breach a system for maintenance. Additionally, no precautions or limitations are proceduralized for these conditions. Licensee management committed to review and evaluate the inspector's concern and the possible need for changes to the CTM or the minor maintenance administrative control procedures. The inspector verified this commitment at the exit meeting. A similar concern was previously identified in Region I Inspection Report Nos 50-277 & 278/93-08.

The report identified examples of work performed under the Troubleshooting, Minor Rework, and Testing Support (TMT) process that relied on human boundaries for personnel safety at the job site. The report noted that this appeared to be contrary to the intent of the CTM. The licensee's evaluation cf this concern is scheduled for completion by September 30,1993. The Operations Support Manager has provided stand-up training to Operations personnel relative to management expectations concerning the clearance and tagging process and personnel safety.

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While reviewing the CTM, the inspector observed that it states that a work ordg SIIALL be used te document all work in accordance with A-26. The inspector identified that licensee performs minor maintenance in accordance with A-26 that is documented on an Action Request and a work order is not used. Licensee management stated that this is an editorial

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error that would be corrected and the CTM would be reviewed to ensure that this error does not occur elsewhere in the manual.

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2.6 Control of Troubleshooting Activities Acindnistrative procedure A-42.1 provides the administrative controls for the Troubleshooting, Minor Rework, and Testing Support (TMT) process. TMT forms are processed and maintained as hard copies. The TMT process may be used as necessary for all activities and components at the plant that meet the following criteria: (1) to change the plant configuration so that troubleshooting and problem diagnosis can be performed; (2) to facilitate the communication and control'of work activities authorized by Action Requests (A/Rs) or Work Orders (W/Os); (3) to communicate and control testing not covered by procedures; and (4) to perform minor maintenance if a degraded condition / parameter is identified during the performance of a TMT.

The inspector found that A-42.1 provides good administrative controls for the TMT process.

The procedure itself provides adequate controls and guidance for the process. Excellent exhibits are attached to the procedure to aid the users of the process. These exhibits include flow charts to: (1) guide the initiator, the plant management reviewer, and shift management during the processing of the TMT; (2) to aid the plant management staff reviewer during the technical and operability reviews; and (3) aid the operations shift supervision in the review and authorization of the TMT. A " Precautions, Guidance, and Examples" exhibit is provided to assist plant personnel in the evaluation and completion of the TMT process and

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form. This exhibit includes step-by-step instructions for:

Description of the problem;

Describing the special plant or equipment conditions required for the activity;

Identifying the activity objective;~

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Identifying boundaries for the TMT activity;

Listing plant responses, including alarms, instrument indications, and auto actions,

expected to occur during all phases of the activity; Step-by-step instructions and restoration;

Level of verification;

Special requirements;

Applicable Tech Specs, Operability impact,50.59 requirements;

Specific communication requirements; and

Post-Activity notification, documentation, and review.

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In general, the inspector found that the instructions and guidelines had an appropriate level of detail. However, during the inspector's review it was noted that very little guidance was provided, which describes the information that is required to be documented in the " List of Results of Actisity" section, or to be transferred and documented on an A/R in the PIM l

system. The ac: urate documentation of as-found conditions and the activities performed is very important to the establishment of machinery history and the trending of equipment failures. Since the TMT is documented on a hard copy record, the information transferred to A/Ra in the computerized plant information management system becomes the computer stored machinery history; therefore; it is very important. This is discussed further in Section 2.8.

2.7 Observation of Troubleshooting Activities During this inspection, the inspector reviewed two TMTs for troubleshooting activities related to the failure of the High Pressure Coolant hijection (HPCI) testable check valve to

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stroke open during surveillance testing, The problem, failure to receive expected open indication during valve stroke testing, was clearly documented on deficiency reporting form, A/R A0758142. The A/R A0758142 also documented that TMT 93-480 was performed to verify powar available and continuity to the solenoid for the air operator. The A/R documentation had an appropriate level of detail that included the panel number that the readings were taken and that the resistance reading values taken on the Units 2 and 3 solenoids were the same. The completed TMT 93-480 record was also reviewed. The instructions appeared to provide an appropriate level of detail including the panel and terminal numbers to take the required readings. In general, the TMT record was completed in accordance with the A-42.1 instructions except that the measuring and test equipment number and calibration due date were not recorded. Additionally, the inspector noted that at the time of the completion of this inspection that A/R A0758142 had not been updated to reflect the following additional troubleshooting and corrective maintenance activities performed.

Portions of the planning, preparations and performance of a second troubleshooting effort in accordance with TMT 93-483 were observed. TMT 93-483 involved h:ving maintenance and health physics personnel enter the outboard main steam isolation valve room to inspect and observe the HPCI testable check valve while attempts were made to open the valve from the control room. This area was a contaminated, high radiation, high temperature area.

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This evolution was appropriately prepared for by conducting pre-job and ALARA briefs between maintenance, technical, operations and health physics personnel prior to the conduct of the TMT activities.

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During the performance of the TMT 93-483 troubleshooting activities, maintenance personnel verified that the check valve would not stroke in response to the open signal. Additionally, a tubing fitting was loosened upstream of the air regulator for the operator to verify that air was being supplied to the regulator. Subsequently, the completed TMT was reviewed. The inspector found that the troubleshooting instructions could have been improved by listing the

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speci6c inspection / observation attributes that the pre-job brief had identified. It was noted that the activities to loosen the air fittings to verify pressure were outside of the original TMT instructions. Normally, this would require revision to the TMT instructions prior to performing the additional activities. Operations shift management and technical personnel were on hand to authorize these additional activities, but the inspector was concerned that these additional activities were never documented by TMT 93-483 or A/R A0758142. No signincant safety concerns were identified during the performance of the troubleshooting activities.

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The inspector also concluded that the documentation in the results section of the TMT could be improved. The TMT merely stated that a failed regulator was suspected and corrective maintenance would be performed. At the time of the completion of this inspection, observations such as the gage on the regulator was damaged and reading zero, the top of the regulator was damaged, etc. were not recorded on the TMT or documented on an A/R A0758142. Further discussion of the consistency and adequacy of the documentation for

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TMTs and the licensee's corrective actions is discussed in the next section.

2.8 Review of Completed Troubleshooting Records Approximately 35 TMTs completed during June 1993, were reviewed by the inspector. The results of this review indicate that the TMTs were generally completed in accordance with the administrative requirements. However, it was found that the activities completed were inconsistently documented. The inspector noted several examples where: (1) the documentation of the as-found conditions was incomplete; (2) documentation of the repair methods and the activities performed was incomplete on the TMT and was not documented on an A/R; (3) documentation of the measuring and test equipment used during TMT activities was inconsistent; and (4) documentation of all work performers was incomplete.

i This issue was discussed with members of the plant management staff who agreed that this issue should be evaluated further. As a result, Reportability Evaluation / Event Investigation Form (REIF) Number 2-93-268 was initiated and proposed to: (1) review the last three

months of TMTs to identify generic issues; (2) identify corrective actions; (3) develop periodic assessment and performance indicators for the TMT process; and (4) use the results of the assessments to improve performance. The inspector considered this to be a prompt

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and appropriate corrective action plan.

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2.9 Personnel Qualification and Troubleshooting Training f

The quali6 cations of the maintenance craftsman performing the troubleshooting activities for TMT 93-483 were reviewed and veri 6ed. In addition to the appropriate mechanical maintenance training, the craftsman had received training on the TMT administrative i

procedure, A-42.1. Records of personnel qualifications are maintained in the PIM database

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t for each individual. This information is available to the maintenance supervisors. A training matrix is being developed to make it easier to determine the qualifications of maintenance

personnel.

Troubleshooting training provided to engineering personnel was discussed with a technical staff manager responsible for developing this training. Lesson plans for five days of elective troubleshooting training in the areas of troubleshooting philosophy, electrical faults, DC l

circuit analysis and troubleshooting, and MOV circuit analysis are currently being developed.

l It is planned that this training will be initially given and validated in August 1993. Once this training was finalized for use by engineering personnel, it would be evaluated for

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modification and applicability to operations, I&C, and maintenance personnel. The inspector

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reviewed the draft lesson plans and concluded that they were of good quality and that the development of this training is an excellent initiative by the licensee.

3.0 MANAGEMENT MEETINGS Licensee management was informed of the scope and purpose of the inspection at an entrance meeting conducted on June 21,1993.

l The findings of the inspection were discussed periodically with licensee representatives during the course of the inspection. The inspectors met with licensee representatives at the

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conclusion of the inspection, on June 25,1993, at Peach Bottom. The inspection scope,

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findings and observations were summarized and discussed at that time. A personnel safety l

issue associated with Minor Maintenance was identified. Minor Maintenance may be i

performed downstream of a potential energy source that has been isolated by methods that

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are not proceduralized. The Clearance and Tagging Manual does not provide clear guidance and precautions for these circumstances that may reduce personnel safety. Management personnel at the meeting committed to review of this concern. The details for this item are l

contained in section 2.5 of the enclosed report. A second concern was identified relative to

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examples where the documentation of TMT activities was inconsistent in that: (1) the documentation of the as-found conditions was incomplete; (2) documentation of the repair

methods and the activities performed was incomplete; (3) measuring and test equipment used i

during TMT activities was not consistently documented; and (4) documentation of all work

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performers was incomplete. As a result, licensee management initiated a formal evaluation i

to develop corrective actions to address this concern. This action was also confirmed during the meeting.

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Attachments-1. Persons Contacted l

2. Documentation Review

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ATI'ACIIMENT 1 PERSONS CONTACTED Persons Contacted Philadelohla Electric Comoany

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• W. Bowers, ISEG J. Guzejko, Nuclear Quality Assurance

• M. Hammond, Engineering

• S. Mannix, Operations Support Manager

• R. Smith, Regulatory

• A. Trapuzzano, Nuclear Quality Assurance

• L. Vernacchio, Manager / Maintenance Planning

• T. Wasong, Manager / Experience Assessment Commonwealth of Pennsylvania

• S. Maingi, BRP United States Nuclear Reculatory Commission

• B. Norris, Senior Resident Inspector -

F. Bonnett, Resident Inspector R. Lorson, Resident Inspector

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• Denotes those present at the Exit Meeting on June 25,1993.

During the course of this inspection, the inspector contacted other managers, supervisors and other licensee employees, including maintenance, operations, technical, quality assurance and administrative personnel.

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ATTACIIMENT 2

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DOCUMENTATION REVIEW Procciates

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A-26, " Plant Work Process," Rev. 31, July 1,1992

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AG-26.1, " Equipment Trouble Tag (ETT) Initiation and Processing," Rev.1,

June 30,1992 AG-26.11, " Corrective Maintenance Action Requests," June 4,1993

AG-26.12, "PIM Work Order Processing," June 4,1993

AG-26.13, " Work Package Planning," March 22, 1993

AG-26.14, " Work Performance Using PIM," June 4,1993

A-41, " Control of Safety-Related Equipment," June 2,1992

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A-42.1, " Troubleshooting, Minor Rework, and Testing Support Process."

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August 1,1992 Clearance and Tagging Manual (CTM), Revision 4, September 1992,

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IC-11-00001, " Calibration of Plant Instrumentation and Equipment,"

February 12, 1993 IC-11-00100, " Documentation of Temporary Lifted leads, Jumpers and Wiring

Modifications," March 24, 1993.

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