IR 05000293/1986043

Insp Rept 50-293/86-43 on 861215-19.No Violations Noted. Major Areas Inspected:Maint Program,Including Contractors & Actions on Program Deficiencies Noted in Insp Rept 50-293/86-06

ML20212Q638
Person / Time
Site:	Pilgrim
Issue date:	01/15/1987
From:	Blumberg N, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212Q606	List: IR 05000293/1986043 ML20212Q603
References
50-293-86-43, NUDOCS 8702020320
Download: ML20212Q638 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-43 Docket N License N DPR-35 Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station d

Inspection At: Plymouth, Massachusetts

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Inspection Conducted: December 15-19, 1986 Inspectors y' Mffbx N. Blumberg, Lead Reactor Engineer

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/ date Approved by: A * '

l J. Johnson, Chief, Operational Programs date

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Section, OPB, DRS i

i Inspection Summary: Routine, unannounced Inspection on December 15-19, 1986

, Report No. 50-293/86-4 Arcas Inspected: Routine unannounced inspection of maintenance program with

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emphasis on use of contractors in maintenance activities and licensee action

,i on program deficiencies identified in Inspection Report 86-0 Results: No violations were identified.

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8702020320 870121

, PDR ADOCK 05000293 i G PDR

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DETAILS Persons Contacted

• N. Brosee, Maintenance Section Manager F. Famulari, QC Group Leader J. Gaedtke, Senior Planning Engineer P. Hamilton, Compliance Engineer C. Holteen, Senior Construction Engineer M. Jackimowicz, Acting Group Leader-Construction Management Group G. Johnston, ECCS Project Manager-General Electric C M. McGuire, Electrical Engineer P. Moraitees, Assistant Chief Maintenance Engineer

• A. Morisi, Assistant Director Outage Management A. Pederson, Station Manager R. Pietzak, ECCS Project QA Supervisor-General Electric C *J. Quinn, Compliance Engineer

• J. Seery, Acting Station Manager R. Sherry, Chief Maintenance Engineer D. Sukanek, Station Service Group Leader J. Vender, Mechanical Engineer

• Denotes those attending the exit intervie . Licensee Action on Previous Inspection Findings Inspection Report No. 50-293/86-06 issued for an inspection conducted from February 18, 1986 to March 7, 1986, in part, identified deficiencies or need for improvement in several aspects of the maintenance progra Certain of these items and the licensee's progress in taking corrective actions are discussed below:

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(86-06, Paragraph 5.1, Maintenance Program): A Maintenance Planning Scheduling Group and a Procurement Support Group were being forme The Planning and Scheduling Group has been functioning since April, -

1986. It has gradually assumed more responsibilities and is now preparing total work packages. The group is currently staffed with a supervisor and three planners. For the outage three additional contract personnel have also been added to the Planning Sectio The inspector noted that the section appeared to be understaffe The licensee stated that an increase in manning of three additional permanent personnel was under consideratio Maintenance program procedures and procedures for the Maintenance Planning and Scheduling Section have not yet been issued. Pro-cedures have been written and are under review. The licensee stated that procedures would be issued during January 198 !

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• 3 The licensee stated that the Procurement Support Section is functional; however, this activity was not reviewed during this inspectio (86-06, Paragraph 5.2, Maintenance Requests (MRs)):

A large backlog of MRs existed and many MRs were apparently " lost".

The Planning Section stated that all maintenance group MRs have been

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located and are under their control. All outstanding MRs are being tracked on a computer. MRs up to 1982 have been validated and dis-positione In many cases the work had already been done and the MR was closed. Planners are walking down systems to see if problems still exist. MRs from 1982 to current are presently being validate The licensee is gradually working off MRs for which the problem still exist A change to the MR procedure (1.5.3) in July 1986 has added a flow chart for processing MRs but this only applies to MRs processed by the Maintenance Group and not to other groups in the plant. Other groups such as Operations and Construction Management Group also process MRs and only portions of the 1.5.3 flow chart is applicable. The current procedure does not take into account the multicolored NCR paper used in processing MRs. The inspector informed the licensee that the new MR procedure must reflect all groups using the system and not just Maintenance Grou In general control of MRs appears to be much improved. The Main-tenance Planning Section has a record of all MRs processed by Maintenance Grou (86-06, Paragraph 5.4, Maintenance Staffing):

Shortages in maintenance staffing were observed particularly at the supervisory level. Shortages still exist. Two of three electrical supervisor positions are filled with the open slot being interviewed; two of four I&C supervisor slots are open but personnel have been hired to fill the open slots; and two of four mechanical supervisory slots are open, however, personnel have been selected to fill the Additional I&C engineer, electrical engineer and mechanical engineer positions have been added to supplement the three current position These positions will be used to relieve the burden on the current position for evaluation and implementation of regulatory and industry issues (i.e. to reduce the external paperwork burden on the current engine-ering positions). These positions have been created but have not yet been fille '

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The maintenance planning and scheduling group while fully staffed does not appear to have enough personnel at its current staffing level. The licensee is evaluating an increase in staffin Currently three additional contract personnel are being used. The licensee is starting an apprentice program in January which will add slots over and above the craft slots in us . Maintenance Program

- Scope The maintenance program was reviewed for the use of outside (con-tract) maintenance personnel performing work at Pilgrim Station. In addition to the permanent maintenance staff, much maintenance and modification work is done by contract personnel. These contract personnel are procured in three different ways by the licensee:

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Contractor workers hired directly (or through vendor organiza-tions) to work directly in the licensee's maintenance grou The Bechtel Company which is the principal contractor for the licensee and maintains a permanent staff on the sit Contract organizations hired as a team for specific jobs such as refuelings, repair or modification of large components such as the recirculation piping replacement and repair of RHR pump The Bechtel organization and contract staffs work under their own QA programs which have been reviewed and accepted by the licensee, i This inspection reviewed the program for contract personnel working directly with the licensee and the GE organization's repair of the core spray and other RHR pump .2 Area Inspected The licensee's maintenance program was reviewed for conformance to the following ANSI standards:

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ANSI N18.7-1976 "... Quality Assurance for the Op ational Phase of Nuclear Power Plants"

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ANSI N18.1-1978 "... Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plant Personnel".

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ANSI N45.2.6-1978 " Qualifications of Inspection, Examination, !

and Testing Personnel for Nuclear Power Plants". i l

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The following criteria were considered: 1

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Contract maintenance personnel had appropriate skills for the .

jobs performe '

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Contract personnel were certified and qualified for the work j performe i

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Appropriate site sp9cific training was given to contract personne Appropriate procedures were used for repair of RHR pump "A".

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Modification to RHR Pump "A" received appropriate safety evaluation The following documents were reviewed:

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Resume's and qualification certifications of maintenance and quality control inspector contract personne !

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Site specific training records for Maintenance and QA contract !

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Procedures and documents listed in Attachment "A".

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Licensee tests of QC contract personne .3 Findings 3.31 The Bechtel Company is principal contractor for the license It has a permanent staff onsite and its own licensee approved QA progra Bechtel provides its own QA and QC coverage and has its own warehouse and supply system. The licensee performs periodic QA surveillance of Bechtel activities. Bechtel  !

performs principally modifications and some maintenance work as assigned by the licensee's Chief Maintenance Enginee Construction Management Group oversees Bechtel wor Special jobs may be contracted for by the license For instance maintenance on the core spray and RHR pumps was per-formed entirely by a team from the General Electric Company .

using its own QA program. GE used the licensee's MR system and l Its procedures were approved by the licensee. Craft personnel were hired locally by GE and supervised by members of the GE team staff, i

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! During outages and for special jobs the licensee hires contract craftsman to directly support their maintenance staff. Approxi-

mately fifty electricians and mechanics were onsite at the time i of this inspection to support outage maintenance. In addition, contractor supervisors are also hired to supervise the contract j personnel. These persons are hired through Combustion En-j gineering and other companies. Resume's and certifications are j sent to the licensee. The licensee then selects the most j qualified personnel out of a group of resume's present. In j addition, some craftsman are selected based on past successful l work at the site. The inspector reviewed a sampling of

resume's of personnel currently working at the site and found i them to be acceptable and within the criteria of ANSI N18.1.

i In addition, electrical craftsman were. certified as Level II electrical technicians per the criteria of ANSI N45. This was done to allow them to perform electrical testing where required.

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Contract workers are given General Employee training. Those

workers who will maintain plant equipment are given additional l

training in plant administrative procedure !

l The inspector reviewed documentation on a sampling basis that i verified that contract workers were required to read " Rules of j

i Practice" and " Maintenance" administrative controls. Contract supervisors are given " Maintenance Contractor M-1 Indoctrina-l tion" by the Training Department. This training is given by an j instructor and documented.

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! Training records indicate that the training given contract

! supervisors is sufficient to have them function effectively in i the plant. They are expected to progress the job and its paper-

! work and to provide " hands-on" supervision of each job. Li-l censee staff supervisors are available to resolve problem areas.

j The inspector reviewed MRs and associated documentation for both

Q and non-Q jobs (see Attachment 3) and the repair / modifications 1 of RHR pump "A" (see paragraph 3.3.2). For non-Q maintenance

! considerable latitude is given crafts personnel for affecting l the repair. Procedures are used as guidelines and'much work is e

performed using verbal guidelines. Q work requires considerably i nore control. Procedures must be adhered to and there is QA

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and QC oversigh '

i The inspector observed that there were no programmatic procedures governing the use of contractors performing maintenance on plant

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equipment. There was no assurance that contractors have the t

same skills and knowledge level as their own maintenance people.

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. 7 There were no programmatic procedures and policies for the use of contractors, dealing with procurement, training and management and control of contractors while onsit The licensee acknow-ledged the inspector comments and stated that these procedures would be prepared in addition to other maintenance program procedures already in progress. This item is unresolved pending completion of licensee action to develop procedures (50-P93/86-43-01).

3.3.2 As stated previously, a GE team was present to overhaul core spray and RHR pumps. This work has been completed and the team was finishing up paperwork. The inspector interviewed the lead engineer for the team and the teams QA supervisor. The in-spector also reviewed procedures, MRs and other records asso-ciated with the repair of RHR pump "A". Documentation reviewed is listed in Attachment "A" to this repor The work was found to be acceptable. All work was done in accordance with detailed procedures approved by the license Appropriate safety evaluations were done for the modification of RHR Pump "A" and no deficiencies were identifie .3.3 The licensee has had a problem with the availability of previously contaminated tools. Tools were not being promptly decontaminated and made available for new work. This problem was caused, in part, by the fact that the labor force which performed this work was no longer employed by the license In addition, decontamination facilities were antiquate A decontamination trailer staffed by contract group, Hydro-Nuclear Corporation, is currently onsite. The licensee stated that the use of this trailer had increased the availability of contaminated tools. This area will be the subject of further review during future inspectio . QA/QC Interfaces QC must review and sign all MRs for Q, fire protection (FQ) and environment qualification (EQ) work. The inspector discussed QA interfaces with the QC Group leader and two QC supervisors and also reviewed Q maintenance documentatio Currently QC has thirteen permanent staff and ten contractors for the~

outage work. The inspector reviewed the resume's and certifications of the contract QC inspectors and found them to be acceptabl Discussions with QC inspectors and review of documentation confirms that QC coverage is provided for Q work only. Inspectors look at most critical aspects of Q work, and inspection hold points were observed in procedure Conversely, there is no QC involvement in non-Q job O

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5. Management Meetings Licensee management was informed of the scope and purpose of the inspection at an entrance interview conducted on December 15, 1986. The findings of the inspection were periodically discussed with licensee rep-resentatives during the course of the inspection. An exit interview was conducted on December 19, 1986 (see Paragraph I for attendees) at which time the findings of the inspection were presente At no time during this inspection was written material concerning inspection findings provided to the licensee by the inspecto l

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ATTACHMENT A

DOCUMENTS REVIEWED

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i Procedures

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1.3.20, Control and Utilization of Contractor Personnel and Contractor

Supplied Material, Revision 2, March 25, 198 !

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1.5.3, Maintenance Requests, Revision 17, July 30, 198 ;

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Temporary Procedure (TP)86-160, Loop "A" RHR Pump Repair, Revision j] 2, November 21, 1986

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Nuclear Operations Procedure (NDP) 83A6, Modification Management,

.. . July 31,198 . Miscellaneous Documents

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BECO Memorandum, dated October 30, 1986, Disposition of NCR 86-82, j "A" RHR Pump Casing Repair.

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Safety Analysis 2012~, Revision 0, October 28, 1986, Repair of "A ,

RHR Pump Casing - Component Failures and Consequence Analysi i

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General Electric letter, dated October 30, 1986, Repair Evaluation for Pilgrim Loop "A" RHR Pump Casing.

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BECO Nuclear Organization, Section 1.0, General Requirements.

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BECO, Pilgrim Nuclear Power Station, Bid Specification - Maintenance

, Supplemental Outage Manpowe .

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BECO, Pilgrim Nuclear Power Station, Bid Specification - Main Steam

} Isolation Valves Repair Program.

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BECO, Pilgrim Station No. 600, Unit 1, Turbine-Generator.

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BECO, Pilgrim Nuclear Power Station, Bid Specification - Control Rod l Drive Replacement Program - RF0 #7.

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General Electric, Nuclear Energy Business Operation, Nuclear Field-j Services Department Eastern Territory, Quality Assurance Manual for l Modification, Maintenance, Repair or Replacement Projects, PQ-M-001, Revision 3.

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l 2 Maintenance Requests

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86-31-3, K110 Air Compressor after Cooling Leakin , Reactor Water Cleanup FV 14A and 15A, Remove override switche , K111, Air Compressor Oil Coolcr Leaking 01 , CRD Suction Reducing Stations, PI 3349 Needs Re-calibratio , Adjust CRD Slow Controller

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86-13-7, Blow down high side of sensing line on RHR flow controlle , Kill TBCCW Union after cooler rupture - replace union and reconnect . Also replace air compressor moto , Repair Steam and Yoke, MOV-1400-4A, Core Spray

-- 86-487, Repack MOV-1400-4 , Repair 62A Outboard Feedwater Check Valv , Repair 58B Inboard Feedwater Check Valv , Repair 62B Outboard Feedwater Check Valv , Repair 58A Inboard Feedwater Check Valv RHR Motor / Pump "A" Removal, Inspection, Refurbishment and Reinstallation with GE Traveler M i

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