IR 05000295/1990009

Insp Repts 50-295/90-09 & 50-304/90-10 on 900430-0504.No Violations Noted.Major Areas Inspected:Followup to Evaluate Progress Made to Resolve Problems Identified During Maint Team Insp

ML20043G552
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/12/1990
From:	Choules N, Falevits Z, Jablonski F, Tella T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20043G550	List: IR 05000295/1990009 ML20043G549
References
50-295-90-09, 50-295-90-9, 50-304-90-09, 50-304-90-10, 50-304-90-9, NUDOCS 9006200419
Download: ML20043G552 (14)

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U.S. NUCLEAR REGULATORY COMMISSION REGION 111

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. Reports No. 50-295/90009(DRS);50-304/90010(DRS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48

Licensee: Coninonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Zion Nuclear Generating Station - Units 1 and 2 Inspection At: Zion lllinois'

Inspection Conducted: April 30 through May 4, 1990

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Inspectors:

O b"/2 - N

Z. E41evits, Team Feader Date r

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[- /2 - 90

N.CyChoules

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Date

'?.Q t- /2-90 T. Tella Date Accompanied By:

T. Staker Office for Analysis end Evaluation

of Operational Data dlw b* /2 - 90 Approved By:

J. Jptflonski, Chief Date MainYenance and Outages Section

- Inspection Summary f

Inspection on April 30 through May 4,1990 (Reports flo. 50-295/90009(DRS)

50-304/90010(DRS)).

Areas Inspected:

Routine announced followup-inspection to evaluate the progress

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made to resolve problems identified during the maintenance team inspection (MTI)

documented in Inspection Reports 50-295/89018(DRS)and 50-304/89017(DRS).

6200419 900614 Q

ADOCK 03000295 PDC

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Results: During: the MTI in early 1989, the-areas of managementLinvolvement -

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,and support--of-maintenance,' post maintenance testing and technical support-

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vere identifiedsas most needing improvements. The team noted increased

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management involvement in' upgrading the maintenance process, especially the-efforts with the maintenance-improvement programs.

Some improvements were.

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.noted in programs to upgrade the areas of post maintenance testing and systems engineers. However, additional problems were noted in post maintenance test instructions and criteria, and system engineers' lack of-involvement in-problem analysis data' sheets, root Cause analysis, and the reliability Centered 4:

maintenance process.'.The team determined that it was too soon to assess the effectiveness.of the maintenance improvement programs.

It would be expected to-take considerable. time before measurable improvements and results could be observed. -No violations were identified.

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DETAILS-i

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Persons Contacted

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Commonwealth Edison Company Lt

• K Graesser, General' Manager, Pressurized Water Reactor Operations

• T. Beguhn, Total Job ~ Management Coordinator

• E. Campbell, Master Electrical Mechanic

-*D. Cook, Master Maintenance Mechanic

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• K. Depperschmidt, Master Instrument Mechanic

• P.~ Fay, Maintenance Coordinator

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L*R. Johnson, Assistant Superintendent, Maintenance

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• T. Joyce, Station Manager y

-*G. Schulte, Nuclear Engineering Department, Maintenance Station Support

• T. VanDeVoort,. Quality Assurance Superintendent

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U. S. Nuclear Regulatory Commission l

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• H. Farber, Section Chief, Division of Reactor Projects-

• A. M. Bongiovanni, Resident Inspector

• R. Leemon, Resident inspector

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'* Denotes.those present at the exit meeting on May 10, 1990,

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2.0-Licensee Action on Previous Inspection Findings i

2.1 (Closed) Violation'295/86026-2A The corrective actions to this violation were described in the licensee's-letter dated March 20, 1987, and supplemented by an NRC letter dated April 14, a

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1987.

Failure to observe QC " hold points" in 13. instances where work proceeded _

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_past QC." hold points" without signoffs orLappropriate: releases.: The licensee-tracked the number of bypassed hold points.:

1n 1989, four hold; points-were-

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missed. The inspector noted that as-of May 10,1990, -no hold points had :been

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. missed. -An interview with a"QC supervisor indicated that there were improved

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, communications with maintenance, which helped to eliminate the bypassing of QC hold points. JThis item is closed, i

12.2 (Closed) Violation 295/89018-01A; 304/89017-01A (The corrective actions to the violations cited in reports 50-295/89018(DRS)

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and 50-304/89017(DRS) were documented in the licensee's response to the NRC dated December 12, 1989. The licensee's first submittal in response to the violations, dated September 29, 1989, wasunacceptable).

. Failure to take timely corrective action to ensure that adequate work c

instructions were provided in work requests. The licensee added ten additional work analysts and had issued and implemented a work package checklist as indicated in the response to the violations. The inspectors reviewed approximately 40 completed work requests and verified that adequate work

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instructions were provided. This iter and a previous violation (295/86026-1A)

for inadequate work instructions are closed.

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(0 pen) Violation 295/89018-01Bt 304/89017-01B Failure to take timely action to correct de battery to bus circuit breaker _

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failures. The problem of, reliably closing the breakers on the first attempt-has continued since October 1987. LThe licensee stated that the General Electric Company was developing suitable breakers for. replacement, which will be procured late in'1990. The licensee was also considering a. modification to facilitate

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easy removal of the breakers; which are currently bolted in place, for maintenance.

Pending further review of the licensee's corrective actions, this

item remains open, t

2.4 (0 pen) Violation 295/89018-01C; 304/89017-01C

Failure to provide timely corrective action on known problems in post maintenance testing (PMT), temporary modifications, and work control. In the area of post-

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. maintenance testing, Maintenance Memo 31 was revised and issued as ZAP 13-15-12,.

" Post Maintenance Testing", on April 4, 1990.

The licensee was still developing-i a detailed matrix for PMT. A review of approximately 40 work requests-indicated that the instructions for PMT had improved; however, the inspectors noted t

incomplete instructions and lack of acceptance criteria in work requests

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Z-80992, Z-89846, Z-91222 and Z-91984.

In-the area of. temporary modifications (TMs), an individual was assigned to -

track the status of TMs and to issue a monthly status report.

Some progress F

was made to reduce the' number of outstanding TMs. The goal was to have no.more

than 30 TMs outstanding and none older than six months.

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.No. of TMs Greater No. of TMs Greater Date than 2 years Old than 18 Months Old Total 09/01/89

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05/01/90

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The licensee made progress in the area of work control. The instructions-

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for work; requests had improved. Two maintenance memoranda were issued for the documentation.of-' work histories; Memo 37, " Maintenance Work History", and' Memo 42, " Electrical Maintenance History". The licensee was developing a new work u

control procedure that will incorporate most of the maintenance memoranda-o issued. This item remains open pending further implementation of the programs in the above areas.

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2.5 (0 pen) Violation 295/89018-01D; 304/89017-01D Failure to take timely and adequate corrective actions to correct the problems

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with overspeed trip mechanisms for the auxiliary feedwater pump turbines.

The overspeed trip devices for both Units 1 and 2 turbines were tested during February 1990. Unit I was being started af ter a refueling outage and Unit 2 was' shut down for other maintenance at the time uf these tests.

Both turbines had to be manually tripped'because the overspeed trip mechanisms failed-to operate,as designed. -On Unit 1, the tappet and spring assemblies were replaced-l and adjusted. On Unit 2, the overspeed trip did not work, even after the

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overspeed' tappet and spring assembly were adjusted and the seating surface for the' tappet head was macnined. The overspeed spring was found_to be one-eighth-inch too long'and was replaced. The manufacturer stated that the spring e

removed from the turbine did not have any color coding, which is the manufacturer's practice. The licensee stated thattthe spring may have been replaced during-construction, for which the licensee had no records. Work history records did not exist for-the overspeed mechanisms on either Unit 1 or

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Both AFW turbines successfully passed three overspeed trip tests = However,

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!the overspeed trip mechanism of Unit 2 malfunctioned again in March 1990, when it tripped _at a lower than designed overspeed setting. The root cause of this e

event was being investigated. This item remains open.

2.6 (Closed) Violation 295/89018-02A; 304/89017-02A Failure to verify the level of station battery 212 as required by surveillance procedure PT-30. The procedure is being revised to include a note to notify the technical staff sngineer in charge of the de system in case the cell: level

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is found or was, accidentally filled beyond one-quarter inch below the full line.

'The battery vendor had assured -the -licensee that the battery level. could be filled.to the full-line without any effect on battery performance. The inspector noted that the battery levels were satisfactorily monitored on-a quarterly basis. = This -item is closed.

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2.7 (Closed) Violation 295/89018-02C; 304/89017-02C Failure to provide adequate instructions in a procedure to prevent miswiring of the torque switch.

Procedure E022-1, Revision 10, included instructions-

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to properly wire the torque switch. The inspector noted that the revised

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procedure was currently used by the licensee. This item is closed.

2.8-(Closed) Violation 295/89018-02D; 304/89017-020 l

Failure of maintenance personnel to. document-the lifting and landing of-

electricalSleads.--Procedure IMTS-3, " Troubleshooting Procedure" was issued-

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fon February 23, 1990, -to require such documentation'. The electrical maintenance department issued procedure EG-002, which also required documentation of lifted

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A and. landed leads. The inspector reviewed selected work requests to confirm'

that-procedures were~ implemented. This item is closed, j

3.0 Followup to Maintenance Team Inspection

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This inspection was conducted to evaluate the progress that the licensee had

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made in the-area of maintenance since the NRC maintenance team inspection (MTI)

l in mid 1989, which was documented in Inspection Reports No.- 50-295/89018(DRS)

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and_No. 50-304/89017(DRS). The inspectors reviewed historic data and various

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improvement programs. Areas evaluated were planning, system engineering

and root cause analysis, vendor manual control and-incorporation of vendor

-requirements into procedures, completed work requests, preventive maintenance, l

surveillances, and control of materials. At the beginning of the inspection,

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d Walkdown of the plant was conducted to observe material conditions and upkeep d

of plant equipment and systems.

Both units were shut down:

Unit 1 for repair

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of diesel generator and main steam isolation valve problems; and Unit 2 for a i

refueling outage.

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p Since the MTI, significant resources and effort were devoted.to upgrade the-maintenance process. Improvements were most notable in the areas of:

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control packages and work practices programs; procedure improvement programs;.

general = management-involvement; engineering involvement; initiation of a reliability centered maintenance (RCM) program to result in a more effective PM program; corporate overview and support of maintenance; some improvements _in

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the post maintenance'. testing program; QA audits and surveillances in the maintenance area;. motor operated valve testing. methodology; housekeeping,

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material condition,-and improved plant maintenance facilities..

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Although progress was made, the team noted some deficiencies in the adequacy of post maintenance testing instructions and content, the effectiveness.of monitoring the implementation process, and integration of the various Performance-Improvement Plan (PIP) maintenance action plans.

Progress was slow in the areas of procedure upgrades-(mainly mechanical), vendor manual control review

.and incorporation into procedures, planning of work activities, system engineering involvement in problem analysis data sheets (PADS),, root cause analysis, and RCM.

Improvement and continued management attention is needed to affect overall improvement in the areas noted above.

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3.1 Histnric Data and Maintenance Philosophy _

i The team reviewed the latest available plant operations historic data from January 1,1989, to March 31, 1990.

Zion Plant Status Reports were reviewed to assess the effectiveness of ongoing maintenance-and improvement programs.:

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' Based on plant performance for 1989, the majority of set goals relating to maintenance such as unplanned reactor trips, safety system actuation, forced outage rate, and derating were met or were close to being met. However, plant

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performance during the first quarter of 1990.had declined due to maintenance related problems such as the diesel generator operability problems, the

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duXiliary feedWater pump turbine overspeed problems, the main steam isolation j

valve (MSIV) shaft problems, and the leaking residual. heat removal (RHR) valves

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in the containment. The non-outage corrective backlog remained high; however, this was projected by senior _ management when maintenance work activities were

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slowed down in order to reduce' human errors and to implement the new maintenance

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improvement programs. The backlog had been decreasing and was expected to meet the goal by June 1991.

Continued management involvement and team effort are

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needed to implement the maintenance improvement programs and improve plant l

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performance in the maintenance area.

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3.2 PerformanceImprovementProgram(PIP)

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In response to identified concerns and in support of the goal to improve overall plant performance,'the PIP was initiated in July 1989. ;The team

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reviewed the action plans that related to maintenance and support areas. The-licensee aggressively pursued identification of maintenance related problem.

areas that were incorporated into the PIP.

However, the team noted that action

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. plans which pertained to the some issue were not well consolidated to adequately

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address and track overall progress and status.

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3.3

Management Involvement in Maintenance Activities

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This area was noted as a concern in the MTl report.

During-this inspection, the team noted increased plant and corporate involvement in the= maintenance

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process. Several PIP action items and Maintenance Memo 36, Revision 0,-provided

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guidance and required that senior management perform plant walkdowns to observe maintenance in progress, housekeeping, and adherence to procedures.

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management was: responsible for maintenance-related PIP action plans. Also, meetings'were held to~ discuss major issues that resulted from senior management walkdowns.

A good example of management involvement in the maintenance process was the

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formation of work package and work practice teams, which consisted of selected groups.of first line supervisors,' work analysts, procedure writers, training

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personnel, and bargaining unit members. The teams were set up to determine.the-t root cause of problems in these areas. As a result, a much improved format for

writing work requests was in the final stages of being issued.

Another example i

of management initiative to improve the maintenance process was by encouraging j.

craft personnel involvement.in improving maintenance practices in the "There's

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Got to be a'Better Way!" program.

Craft personnel can express concerns / ideas to management for review and consideration in upgrading maintenance at Zion.

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'Another program, "The Plant Idea.xchange" (PIE), encourages employees to share i

ideas and knowledge on ways that iill improve plant performance.- Employee-J awards are an integral part of this program.

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Corporate management has also increased its presence and involvement to upgrade l

the maintenance process.

For example, corporate assessed implementation of the-

maintenance programs, assisted in the resolution and root cause determination

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of-problems associated with the diesel generators, and provided personnel for

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.the ongoing RCH pro' ject ~.

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Review of Maintenance Related Corrective Actions 4.1 Observation af Material Conditions and Housekeeping The. inspectors observed areas of the plant to assess-housekeeping and material condition. The plant appeared to:be generally well kept and equipment deficiencies'were tagged.

Specific plant areas were ass'igned to individual managers / supervisors, who were.directly accountable for cleanliness and material condition of the-assigned areas. The licensee initiated a Foreign Material Exclusion program to prevent foreign material.from entering equipment undergoing r

maintenance. The inspectors verified the effectiveness of this program by observing'the maintenance. activities in the diesel-generator area.

Equipment was properly covered and protected.

• 4.2

_ Stem Packing Leaks on Pressurizer Spray Valves

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Pressurizer spray valve packing leaked on several occasions on both units.

A Unit 1 pressurizer spray valve was rebuilt in accordance with the original equipment manufacturer recommendations in the spring of 1989 and this valve had performed satisfactorily since that time. However, the licensee has elected to incorporate the latest recommendations of the Electric Power Research Institute

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(EPRI);on Unit 2, ' including shortening the active packing length to conform to

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EPRI recommendations by.using;a carbon spacer in the lower packing-space, using

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center and end= packing rings of: graphite, and using " Live Loading" on packing.

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L The licensee was sufficiently convinced of the value of this method-that'this

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' system would' be expected to be used in the Unit 1 pressurizer spray valve when repacking is necessary.

Performing the investigation necessary to evaluate

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this system and implementing the modification when evidence existed that the.

current practice was marginally acceptable is considered a strength. This is

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considered a plan for-long term reliability rather than short time economy.

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t 4.3 Completed Work Packages and Work Histories-

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The inspectors reviewed eight' completed work packages to determine

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if maintenance was accomplished and documented.

One problem was identified with " rework".

Workrequest(WR) 291877, w'as issued to troubleshoot a problem with a I

reactor. coolant pump seal leakoff annunciator. _The post maintenance test

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erroneously required the craft personnel to " verify window operation at input terminal block" rather than at a point' upstream of-the relay card.

Subsequently, another WR was issued because the original problem was not t

repaired. The-original WR failed to state that the annunciator window did

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not operate properly. This work was not identified by the licensee as

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" rework" because no provision existed-to note and track rework. The inspectors noted that the required problem analysis data (PAD) sheet was-

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not issued for a WR that required rework.

The licensee concluded that

' Maintenance Memo 07, " Analysis of Maintenance Problems", Revision 5, was

ambiguous and had conflicting requirements. The memo was corrected, and marked up for revision, and a PAD was in the process of being generated.

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4.4 Ongoing-Maintenance The inspectors observed ongoing work in electrical, mechanical, and I&C areas.

Where possible -. safety significant' activities were chosen for the review to.

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determine if' required administrative approval was obtained; if work instructions

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were adequate, if replacement parts were acceptable, and if personnel were experienced and knowledgeable.

4.4.1 Ongoing Electrical Maintenance

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'The. inspector observed portions of the activities associated with the'

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following-work requests.

i-Z 83264.- Maintenance on Limitorque operator of valve 2MOV MS0173

?Z 85998'

Diagnostic tests of valve 2M0V CS0008 (

Z 92169 - Troubleshoot valve 250V-PR260

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The inspectors concluded that electrical maintenance activities were accomplished by' skilled maintenance personnel'. The inspectors noted that the work requests.

-were approved and that maintenance personnel used approved procedures and drawings. The foremen and QC inspectors were present at the job sites, as necessary.

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Ongoing Mechanical Maintenance

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-The inspector _ observed portions of the activities associated with the following y

. work requests:>

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2 81382 - Overhaul PCVs RC455C and RC456 2 85037 - Overhaul-service water pumps and install.new bushings

2 90513:- Overhaul Unit 2 turbine oil cooler transfer valve-The= inspector concluded that mechanical maintenance activities were accomplished by. skilled maintenance personnel. The inspectors noted that the work requests:

were opproved and that maintenance personnel used approved procedures and drawings. The foremen and QC inspectors were.present-at the. job sites, as a

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necessary. Areas for working on. contaminated equipment were clean, well~

lighted, and contained necessary-equipment to support the work in _ accessible

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positions. Work performed in some radiation areas was monitored by closed

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circuit television to minimize exposure of personnel whose presence was not

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required at the work area.

4.4.3.

Ongoing Instrument and Control Maintenance i

The-inspector observed portions of the activities associated with the following work requests.

Z 88738 - Repair and-cal _ibrate control room recorder

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l Z 92195 - Troubleshoot' liquid radiation monitor

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Functional checks,0f pressurizer level and steam generator level transmitters-The inspector concluded that 1&C maintenance activities were accomplished by-_

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skilled maintenanceipersonnel who appeared knowledgeable of the work performed.

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_0ne minor concern was? identified with procedure 2F-PP19, " Mechanical Penetration Pressure Flow Zone 1", Revision 4.

Step 6.16 allowed the. technician to' defeat-

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the' annunciator alarm. -However, there was 4 requirement within Step _6.16 to

verify the annunciator. horn and light which could not be performed because both

.j-had'been bypassed. The inspector identified the_ problem and the licensee-

appropriately corrected the procedure. A review of other calibrations showed j

that the annunciator defeat switch was maintained in its normal position so-q that:the problems described above were not encountered.

4.5 Backlog of Maintenance

'4.5.1 Corrective Maintenance Backlog j

i The MTI had.previously identified a weakness in the prioritization of B1 'and B2

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'WRs which resulted in a large backlog of B1 and B2 WRs that were not initiated within-the desired 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and five days, respectively.

The licensee revised i

.the.WR prioritization process to agree with the Conduct of Maintenance and as a result, the majority of the WRs were prioritized as 63.

During the MTI, 61.5%

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<l offthe non-outage l corrective maintenance backlog was prioritized as B2 and 10%

p as Bl.,0n May 2, 1990,=18% of the backlog was classified as B2 and 2.5%- as

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L Bl. The. licensee held daily planning meetings that were attended by operati_ons,

- maintenance, and technical staff personnel to prioritize newly initiated WRs.

The inspectors reviewed approximately 40 WRs which had been properly prioritized.

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The MTl identified a weakness in documenting WR couse codes. To correct.this, h

the Total Job Management coordinator checks the WR.

If the cause code is not

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documented,-the WR is returned to the maintenance department.

The-inspector reviewed the' backlog of corrective non-outage WRs since the MTI.

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The backlog increased from about 900 in July 1989 to about 1,600 in December pf

"1989, but had decreased to about 1,200 by March 1990. The backlog on May 3,

1990, was 1,269. The licensee had projected that the backlog would increase p

'and stay between 1,500 and 1,600 until October 1990 and then decrease to the goal'of 925 by June of 1991. The licensee's reasons.for the increased backlog u

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were: -an improved PM/CM program that used new procedures; workers were instructed to carefully perform maintenance work using the new procedures to avoid personnel errors, which required more time; and plant outages.

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though the current backlog was less than projected, the licensee agreed that it

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was greater than other Commonwealth Edison Company nuclear plants.

s 4.6-Post Maintenance Testing (PMT)

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The MTl identified instances of failures to specify post maintenance testing in-

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'both safety-related and B0P components. The inspectors reviewed the licensee's

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program for post maintenance testing and its implementation.

.4.6.1 Post Maintenance Testing of Motor Operated Valves (General)

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The setting and testing of motor operated; valve (MOV) switches-to the

,9 requirements'of HRC Bulletin 85-03 was reported to have been. performed at full-

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d flow'and-pressure differential without the.use of operating analysis equipment such as "M0 VATS" or "V0TES". The subsequent requirements for MOV testing, now required by'NRC Generic Letter (GL) 89-10, indicate'the benefits for-performing i

an MOV operational analysis when it is impractical to perform a full flow l

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differential pressure test. To accomplish this, the licensee has chosen the l

VOTES system for use on a corporate wide basis. The licensee is working in

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conjunction with the corporate MOV coordinator to assimilate the V0TES.

l technology while utilizing the services of a contractor to apply the technology j

to currently required MOV testing.- Current' plans are'to gradually integrate

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-licensee personnel into the-testing of MOVs after completing.a V0TES training.

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Currently, insufficient work has been completed to justify an objective

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analysis of progress.

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i Zion is behind other plants in MOV analysis. The licensee recognized the problem and has taken steps to resolve it.

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'4.6.2 Post Maintenance Testing of MOVs (Specific)

iWR 280992 was written to add a seal-in feature to the control circuit of valves 1M0V-ES0005, 0008 and 0011, which were not safety-related. The PMT requirements lin.TSSP-08-89, Revision 0, stated that the test would verify that the seal-in was installed and operated as-intended.

However, the test was scoped for partial travel of the valve to close (approximately 10-20 seconds) at.which

point the power to the valve was interrupted by manually tripping the circuit breaker. This was done to prevent the valve from fully closing (approximately

2 minutes) and affecting plant heatup rate during Mode'l operation.

The inspectors were concerned about the adequacy of the instruction and test-methodology because the valve did not travel to the full closed position,

+herefore, operability of the "close" torque switch was not tested. The

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licensee informed the inspector that safety-related valves were not tested by--

this' method.

4;7 Maintenance Procedures The team noted that electrical procedures had been rewritten and improved. lA procedure coordinator was assigned to each maintenance department. A procedure writers guide was issued.and more procedure writers have-been hired. The team

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determined that the mechanical procedures needed most of the improvements. Also,_

J recent audits identified problems with procedure control, adequacy, and adherence, f

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.4.8 Technical Support

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I The MTI identified inadequate engineering support and involvment in maintenance.

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The' inspectors reviewed the technical support for the maintenance activities at-the station.-

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-System Engineers The MTl identified that system engineers were not involved in equipment failure analysis. There were a total-of 67 engineers on the technical staff, including 12' supervisors, 39 systems engineers, and 16 program engineers. The technical staff supervisor; stated that an additional 8-10 engineers were to.be hired.

In addition, there were 17 contractors working'as engineers.

The number of engineers appeared adequate.

However, the concept of' system " ownership" a

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appeared to be lagging.

Guidelines were issued on maintaining system and

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. program notebooks, but only a few engineers maintained the system notebooks, i

which were all expected to be completed by June 1, 1990,

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Technical staff-position descriptions were issued that defined the i

responsibilities for system engineers.

This was a problem area identified during the MTI. The inspector interviewed several system engineers. Although knowledgeable, the involvement of systun engineers in failure and root cause

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analysis-appeared to be minimal.- None of the 65 problem analysis data sheets

(PADS)~were initiated by the technical staff engineers.

(More information j

about PADS is included in Section 4.8.3 of this report.) A program was initiated

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to train the technical staff engineers in root cause analysis, which included i

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Management Oversite and Risk Tree (MORT) and Human Performance Enhancement'

System (HPES) attributes. The licensee ha.d made-a good effort to improve the-effectiveness of the system engineering concept.

?8 4.8 Engineering Support in the Area of Predictive Maintenance

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4.8.2.1

~ Vibration Analysis e

The current vibration analysis program included several, pieces of large rotating

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equipment both in safety-related and balance-of-plant areas.

Initial vibration

data =were collected by the operations or technical staff personnel, and were

= L analyzed by a vibration coordinator, who maintained.the_ data. The system-engineer is notified when any equipment exceeds the alert / action limit.

._As a result of a MTl concern, the licensee initiated a change to the station Lprocedure for reporting problems with vibration. The auxiliary feedwater

.j turbine bearing alert and action limits on vibration-levels were reduced to R

comply with the limits specified in the-vendor manual.

The licensee was currently upgrading the vibration program-, Vibration limits were being reviewed.

Vibration analysis will be extended to most applicable rotating equipment including large fans. This program is expected;to be-

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implemented by-November-1990.

4.8.2.2 Thermography During the MT1, the licensee indicated that a thermography device would be-

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obtained to detect loose electrical connections. The thermographic device was j

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received and the program is being formalized. Maintenance engineers already j

have used thermography.in a limited scope to: detect-loose terminations-in d

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electrical installations.

Full implementation of the program should result in

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improved'and more effective predictive maintenance.

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4'.8.2.3'

Erosion / Corrosion Monitoring

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The licensee initiated an erosion / corrosion program in response to NRC Generic

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Letter 89-08. Company wide guidelines were issued for implementation of.the l

program. Pipe wall thicknesses were measured in several systems. Repairs were

made by weld overlay or replacement when the wall thickness was less than

dCCeptable limits.

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4.8.2.4-Inservice Testing (IST) Program r

The NRC inspector reviewed the IST program and confirmed that essential elements wereLin; place for implementation.

Some evidence of trending'in IST was noted, j

The ISTLcoordinator indicated that a commercially available sof tware program

for-controlling'IST and manipulating data nad been selected and would soon be

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integrated into the system.-The magnitude of data associated with this process precludes rapid integration. This area will be reviewed during a separate

inspection.

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'4.8.3 Problem Analysis and Data Sheet (PADS) Program p

The licensee had initiated a generic program for the-identification and W

resolution of maintenance problems by use of PADS.

PADS are ustd to evaluate

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root cause and corrective action if-safety-related equipment _ failed a l

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surveillance or post maintenance operability test, was declared inoperable, M

demonstrated a set number of failures over a specific time period, or exceeded a-predetermined number of manhours to repair._ A PADS _ coordinator was appointed in early 1990. At the conclusion of this inspection, a total of 65 PADS were

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issued and 15 were. closed. Another 25 PADS were reviewed but not closed, and

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25.were still under review. All of the PADS were initiated by maintenance-i personnel, and 52 were in the mechanica'i maintenance area. The active

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PADS were monitored by _the PADS coordinator, who issued periodic status reports b _

to station management. As described in Section 4.8.1, the inspectors were concerned about the lack of system engineer involvement in-the PADS process,.

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especially root cause analysis.

4.8.4 Vendor Manual Control and Incorporation of Vendor Recommendations-into Maintenance Procedures

1 The MTl identified a: lack of-aggressive review and implementation-of vendor-i recommended preventive maintenance. The licensee has 9,252-vendor manuals, of

which 3,825'were assigned numbers and tracked.

However, only 176 vendor

manuals have been reviewed for identification of equipment to which the manuals

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applied. Procedure ZAP 6-52-5, " Zion Station Vendor Equipment Technical.

Information Program"., Revision 9, was issued for_ control of vendor manuals.

The licensee estimated that after elimination of duplicates and-revisions, a-total of.about 4,500 vendor documents will-need to be reviewed. The licensee also estimated that based on the current scope of _ the Vendor. Equipment Technical

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Information_ Program (VETIP), approximately 400 vendor documents-could be i

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reviewed annually. -At this rate, it would take more than 10 years to complete-

the: detailed review of the existing vendor manuals. However, the review would'

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be prioritized based on the significance of the equipment. The. number of L

safety-related equipment covered by the 176 vendor manuals reviewed so f ar,

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could not.be provided by the licensee. Management.was nut aggressive in the'

j review and implementation of vendor recommendations?in the area of equipment

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-maintenance. This is a generic problem that requires significant involvement j

from corporate management.

4. 9

.QA/QC Involvement in Maintenance

The inspectors reviewed the audits and surveillances-in the maintenance area j

performed since August 1989.

Eight audits and numerous surveillances had been'

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completed. The audits and surveillances were performance based. Most of the-

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audit findings related to procedure problems including control, issuance,.

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adequacy or adherence. Corrective action to the audit and surveillance findings

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wds in progress.

The MTI identified a lack of QC involvement in maintenance activities. QC insi.ectors now document each activity observed on an inspection report-form.

I The inspector determined that about 650 reports were issued since January 1990.

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It appeared that QC involvement in maintenance activities had improved.

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During the MT1, the inspectors determined that operators were not marking individual items on diesel generator logs.

The inspector reviewed diesel generator logs completed since February 2,1990, and determined that items were now checked. it was apparent that management hed taken action in this area.

5.0 Exit Meeting The inspectors met with licensee representatives (denoted in paragraph 1) on May 10, 1990, at the Zion Station and summarized the purpose, scope, and findings of the inspection. The inspectors discussed the likely informotional content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietary.

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