IR 05000315/1993015
| ML17331A931 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/06/1993 |
| From: | Meena Khanna, Pegg W, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17331A929 | List: |
| References | |
| 50-315-93-15, 50-316-93-15, NUDOCS 9308120012 | |
| Download: ML17331A931 (10) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/93015; No. 50-316/93015(DRS)
Docket Nos. 50-315; 50-316 Licenses No. DPR-58; No.
DPR-74 Licensee:
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
Donald C.
Cook Nuclear Plant, Units
8
Inspection At:
Donald C.
Cook Plant, Stevensville, MI Inspection Conducted:
June 7-18, 1993 Inspectors:
. A.
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~n Approved By:
7 /: ~,~~ $i ons I, ie Maintenance and Outages Section Ins ection Summar
~/Pi S Ins ection on June 7-18 1993 Re orts No. 50-315 93015.
No. 50-316-93015 DRS Areas Ins ected:
Routine, announced inspection of maintenance activities using selected portions of NRC inspection module 62700 to ascertain whether maintenance was effectively accomplished and assessed by the licensee.
9308i200i2 930809 PDR ADOCK 050003i5 G
Inspection Summary Results:
Overall maintenance activities on the emergency diesel generators (EDGs)
and auxiliary feedwater (AFW) system were effectively implemented in meeting the safety objectives of the progr'am.
The EDGs and systems experienced a high degree of availability.
Other maintenance activities were satisfactory.
Plant housekeeping and plant material condition were good, except in the maintenance of required safe shutdown lighting.
gA audits and surveillances of maintenance activities were performance oriented and effective in identifying maintenance related problems; however, actions to correct the noted problems were not always taken or effective.
Corrective maintenance was usually effective in problem and root cause identification and, in most cases, appropriate actions were taken to prevent recurrence.
Weaknesses were noted in the control and implementation of preventive maintenance, correction of problems identified in gA audits, implementation of fire protection requirements, lack of formalized systems training for systems.
engineers, and control of and compliance with plant procedures.
A computerized system for maintenance history and scheduling had recently been implemented.
The system was functional, although limited maintenance history information was available and some problems with the system had not been resolved.
Violations were identified with inadequate procedures and procedure compliance (Section 2.4.3);
inadequate document control (Section 2.4.4);
and failure to adequately maintain safe shutdown lighting (Section 2.4.5).
DETAILS 1.0 Princi al Persons Contacted American Electric Power Com an
- H. Horvath, Site gA Superintendent Indiana Hichi an Power Com an
- A. Blind, Plant Hanager
- H. Ackerman, Safety and Assessment Inspection Coordinator
- K. Baker, Assistant Plant Hanager Production
- T. Beilman, Haintenance Superintendent
- R. Gillespie, Superintendent Scheduling
- G. Weber, Superintendent Plant Engineering
- J. Wiebe, Superintendent Safety and Assessment U.
S. Nuclear Re ulator Commission
- D. Hartland, Resident Inspector J.
Isom, Senior Resident Inspector
- Denotes those present at the exit meeting on June 18, 1993 Other persons were contacted as a matter of course during the inspection.
2.0 Evaluation and Assessment of Haintenance The purpose of the inspection was to evaluate/assess accomplishments and effectiveness of maintenance activities at the Donald C.
Cook Nuclear Plant.
The inspectors reviewed past operating experience, performed system walkdowns, reviewed corrective, preventive, and predictive maintenance activities, evaluated engineering and technical support and licensee assessments of maintenance activities, and reviewed licensee maintenance improvement programs.
Units 1 and 2 were in operation at the time of the inspection.
The inspectors concentrated on two systems, the emergency diesel generators (EDGs)
and the auxiliary feedwater (AFW) system.
The EDGs provide emergency electrical power to critical plant equipment in case of a failure of offsite electrical power.
The AFW system supplies
'feedwater to the steam generators in case of a reactor shutdown or a failure of the normal feedwater system.
Selection of licensee documents were based on component/equipment safety significance.
2.1 Past 0 eratin Ex erience No repetitive maintenance problems were identified on the Unit
and
EDGs and the Unit 1 and
AFW systems and system availability was good in both areas.
Downtime for the EDGs and the AFW systems 'included 'perfodic system
outages for planned and preventive maintenance as well as time to repair unscheduled equipment failures.
The EDGs availability during power operation for 1993 was very good at approximately 99 percent.
Availability for both units. exceeded the licensee's established availability goal of 97.5 percent.
Unit 1 and
AFW system availability during power operation was excellent for the past 12 months.
Availability for Unit 1 was approximately 100 percent and Unit 2 was approximately 97 percent.
The primary causes for the difference between the two unit's availability were bearing damage on Unit 2's east motor driven AFW pump (ENDAFP) and governor valve problems on the turbine driven AFW pump.
The EHDAFP outboard thrust bearings were found to be severely degraded during a routine oil change.
Previous in-service testing and vibration data did not indicate any bearing degradation.
Oil samples were taken and analyzed on the remaining pumps.
The oil and bearings that showed wear were replaced.
The root cause of the bearing damage was under investigation.
Programmatic changes to enhance bearing performance were being developed and implemented.
2.2 S stem Walkdowns The EOGs and AFW system components, as well as adjacent areas, were observed for proper identification, accessibility, installed scaffolding, radiological controls, housekeeping and unusual conditions.
Unusual conditions included, but were not limited to, water or oil or other liquids on the floor or equipment; equipment in need of repair or out-of-service; indications of leakage through the ceiling, walls, or floors; loose insulation; corrosion; excessive noise or vibration; and abnormal temperatures, ventilation or lighting.
The inspectors verified that job orders (JOs)
had been initiated for broken or defective equipment.
The licensee maintained the plant material condition at a level commensurate with the equipments'unction.
Host equipment in need of repair had been previously identified by the licensee.
Hone of the problems, with the possible exception of improper aiming of the safe shutdown lights, had an effect on plant operation.
2.2.1 EDG Walkdowns Housekeeping/material condition of the EDGs, supporting equipment, and adjacent areas was good.
The EDGs were operable and in the proper configuration.
Broken/defective equipment was identified and properly tagged.
The inspectors observed several small oil leaks and several improperly aimed safe shutdown lights in the EOG rooms.
The inspectors informed the licensee and corrective actions were initiated to resolve the identified problems.
2.2.2 AFW S stem Walkdowns Housekeeping/material condition of the AFW pump rooms, supporting equipment, and adjacent areas was excellent.
Equipment identification and labeling of equipment was good.
The AFW system was operable and in its proper configuration.
All valves that were required toe locked open/closed were
locked in the required position.
Pump oil reservoirs were full and the overspeed trip mechanisms were properly set.
The inspectors observed no water or oil leaks and broken/defective equipment was properly.identified and tagged.
Several safe shutdown lights in the AFW area were improperly aimed.
2.3.
Corrective Maintenance Activities The inspectors reviewed selected completed maintenance job order packages and maintenance records on the EDGs and the AFW system to determine if required maintenance was properly executed as specified in maintenance procedures and other requirements.
The documents were evaluated for completeness, accuracy, and technical content.
Some of the specific items reviewed were description and scope of the required work, adequacy of work instructions, evidence of engineering and technical support if needed, documentation of work performed, and post maintenance testing.
The inspectors reviewed 8 closed maintenance job order packages for the EDGs.
The packages reviewed were C0001433, C0004722, C0006035, C0007964, C0011405, C0015111, C0015955, and R0014217.
The inspectors reviewed 11 closed job order packages for the AFW system.
The packages reviewed were C0000987, C0005496, C0015079, C0015450, C0015758, C0015772, C0015882, C0015955, C0016191, R0003083 and R0003466,.
Observations were as follows:
~
work instructions or procedures were adequate for the work performed acceptance criteria was included when necessary engineering was involved when problems occurred and provided assistance as necessary post maintenance testing requirements were not always clear c
shift supervisor sign-offs for permission to perform the maintenance work were not evident
in some cases, the desci iption of the work to be done or work that was completed, was not clear.
The inspectors reviewed the condition report (CR) process.
The inspectors reviewed
CRs primarily from the EDG and AFW systems for initiation, investigation, adequacy of root cause analysis and efficacy of suggested preventive measures.
The threshold for initiation of CRs was generally low.
However, the inspectors identified conditions where CRs had not been initiated even though licensee personnel were aware of the problems.
Examples included problems with improper PN scheduling and safe shutdown lighting as described elsewhere in this repor The inspectors noted that the auality of the problem investigation and root cause analyses improved considerably after the CR process was revised in January 1993.
For the 1993 root cause analyses reviewed, the corrective actions and actions to prevent recurrence were appropriate.
2.4 Preventive Maintenance Activities The inspectors concluded that preventive maintenance (PH) program implementation and corrective actions were weak in some areas, as discussed below.
The inspectors assessed how well the overall PH program had been implemented on the selected systems.
Many PH problems were identified by the licensee in gA audit gA-93-02 dated March 25, 1993, and were also identified in a previous gA audit conducted in 1992.
None of the following PH weaknesses affected operability of.EDG or AFW equipment.
o in some cases, PH tasks were improperly deferred o
historical PH information was not easily retrievable o
PH tasks were automatically scheduled late due to computer software problems o
PH tasks of safe shutdown lighting were not performed o
out dated maintenance procedures were located at one procedure location.
2.4.1 PM Task Deferrals In some cases, PH tasks were improperly deferred, that is, without completion of the required PH task deferral request and obtaining the required approvals.
The inspectors noted that the deferral form did not contain the date the task was last performed, the period of the PH task, and the possible plant impact of the deferral.
Since a deferral form was not required for each PH task, a
deferral form could be used to defer multiple PM tasks.
The practice of deferrals without required approvals was documented in American Electric Power gA audit report number gA-93-02, issued March 25, 1993.
This audit report also noted that a majority of deferred PM tasks were deferred due to a lack of available manpower.
2.4.2 Com uterized Nuclear Plant Haintenance NPH S stem Historical PH information was not easily available for consideration in PH deferrals or other actions.
A computerized system for maintaining maintenance history records and tracking/scheduling of PM tasks had been recently implemented.
Complete computerized information on PH items was only available since January 1993.
Prior information had to be retrieved manually, which sometimes required several days.
The inspectors concluded that the NPH system had the potential for greatly improving the tracking, control, and history of both corrective and PH task The system should provide substantial improvement in PH task scheduling and history after the system has been operating for some time and system problems are eliminated.
2.4.'3 Im ro er Schedulin of PM Tasks After implementation of the NPM system in January 1993, all PM tasks were scheduled late.
The PH tasks were automatically scheduled late due to
.
computer software, that used the job order close out date rather than the date the PH task was actually performed for scheduling.
PH tasks were late by several days and in some cases, exceeded a year.
This problem involved safety and nonsafety related comj!onents including components from the two selected systems.
Licensee personnel were aware of this problem, but did not take prompt corrective action.
Paragraphs 4.13 and 6.3.2.A of Procedure HHI-5030,
"Preventive Maintenance Program",
Revision 13, with change sheets 1 through 5, required intervals for performing recurring preventive maintenance tasks be based on the date the task was last performed.
The failure to schedule PH tasks as required by this procedure is an example of a violation of Criterion V of 10 CFR 50, Appendix B (315/316/93015-01(DRS)).
2.4.4 Outdated Maintenance Procedures The inspectors noted that the methods used to control preventive maintenance described in procedure HHI-5030, "Preventive Haintenance Program," Revision 12, was not consistent with the current practices.
On June 16, 1993, the inspectors determined that Revision 12 of the procedure was not the current issue..
Licensee personnel determined that changes to this procedure, as well as other similar instructions, had not been distributed to the safety and assessment satellite library for some time.
Haintenance head instructions
"
(MHIs) located in the safety and assessment satellite library were deleted from the document control systemin 1990.
HHIs were administrative maintenance procedures that described overall control of many maintenance activities, including preventive maintenance.
The procedures were not'emoved from the library and were available for use by safety and assessment personnel, including gC, as well as the NRC and others.
Failure to properly control MHIs is a violation of Criterion VI of 10 CFR 50, Appendix B
(315/316/93015-02 (ORS)).
2.4.5 Safe Shutdown Li htin PH was deferred on EDG and AFW room safe shutdown equipment lighting.
As a
result, several emergency lights were not properly aimed for an extended period of time.
The safe shutdown equipment, which could have been required to mitigate an accident, did not have the required light intensity for target areas of 0.4 foot candles due to the misalignment of the lights.
Untimely corrective action for this condition contributed to the number of inoperable emergency lights.
This is a violation of 10 CFR 50, Appendix R,
.
Section III.J, which states that emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto (50-315/316-93015-3(DRS)).
The licensee issued a job order to verify and correct the position of all safe shutdown lights.
The job order included the relocation of the aiming target and adjustments of the lights.
The work to reposition the lamp for the emergency light and move the aiming spot was performed without an instruction or procedure.
As a result, no light meter readings were taken of the target for the new position of the emergency light to verify that the required light intensity of 0.4 foot candles was met.
This matter was discussed with licensee personnel.
'.5 Predictive Haintenance Activities Several types of predictive maintenance were used to assist in the evaluation of equipment condition.
Oil analysis and vibration analysis were routinely performed on plant equipment where appropriate.
Other predictive maintenance techniques were used to investigate plant problems.
No specific instances were noted where these methods had detected impending failures or significant problems on EDG or AFW components; however, the programs appeared to be good tools for the analysis of plant equipment conditions and the early detection of equipment problems.
2.6 En ineerin and Technical Su ort of Haintenance Activities Engineering and technical support of maintenance 'activities was acceptable.
The inspectors evaluated engineering and technical support of maintenance in the areas inspected.
This included systems engineering support for the EDGs and the AFW system as well as engineering department involvement in the resolution of maintenance related questions raised during the inspection.
2.6.1 S stem En ineerin Su ort Host engineering support of maintenance activities and problems was provided by system engineers.
The EDG and the AFW system engineers were actively involved in significant system problems, such as those documented in CRs, and provided guidance to maintenance as needed.
The engineers appeared to be knowledgeable of the assigned systems and indicated an awareness of system status during the walkdowns.
During the review of past work performed on the systems, the engineers also appeared to be aware of system history and past significant maintenance related problems.
However, the system engineers were not always knowledgeable of possible generic problems relating to the assigned system and issues.
During the walkdown of the AFW system, the inspectors noted that the fire doors on the two turbine driven AFW pump rooms had been rendered inoperable by placing concrete blocks in front of all four doors.
The system engineer was not aware of the reasons that required that the fire doors be blocked open.
System engineers had received general plant training, but no formalized systems training was required; most training was on-the-job.
Approximately
one third of the system engineers had received root cause analysis training, but neither EOG or AFW system engineer had received this training.
Lack of formalized training for system engineers appeared to be a weakness in providing adequate engineering support.
2.7 Licensee Assessment of Haintenance The inspectors reviewed several maintenance audit reports performed by the gA organization in 1992 and 1993.
A number of gA surveillance reports on maintenance activities were also reviewed.
The maintenance related gA audits performed in 1992 and 1993 included corrective maintenance, preventive maintenance and corrective actions.
The audits and surveillances were thorough and performance oriented, and problem reports or condition reports were written to identify items that required follow-up.
The effectiveness of the audits was limited, however, since the actions taken as a result of the findings were not always effective in eliminating or minimizing the noted problems.
This is evidenced by the recurring PH problems previously described above.
Audit follow up and verification activities were weak.
2.8 Haintenance Im rovement The licensee had established several self-improvement programs in maintenance and maintenance related activities.
Examples include, the Haintenance Improvement Program and Haintenance Procedures Upgrade Program.
A Haintenance Improvement Program was developed to address maintenance problems identified in a previous NRC inspection of maintenance.
The program addressed the upgrade of maintenance procedures, management monitoring of maintenance, and a formal rework program.
The corrective actions for these three items have been completed.
Completion of this program represented significant progress in the improvement of maintenance.
The licensee completed the maintenance procedure upgrade program, which consisted of completely revising all electrical and mechanical maintenance procedures.
Licensee personnel indicated that the revised procedures were much improved and were thorough, detailed, and easier to follow.
The program did not include an upgrade of instrument and control (-I&C) maintenance procedures.
Review and revision of these procedures was delayed due to the installation of new equipment.
Several special groups had been established for improvement of maintenance or maintenance related activities.
These included:
(1)
a task group to assess system and component availability data for the maintenance rule, (2)
a management committee on information management, which is responsible for the oversight of the continued efforts in computerizing plant data, and (3)
a motor operated valve task force.
Hanagement attention, as evidenced by the formation of these special groups, should result in. improvements in maintenance activities and a reduction in equipment problems.
Oue to time limitations, the inspectors did not review the results of these special group activitie ~
~
3.0 Conclusions Based on the results of the inspection activities described in this report, the inspectors concluded that maintenance on the EDG and AFW systems was effective and no significant safety issues were identified.
4.
E Exit discussions were held at the Donald C.
Cook Nuclear Plant on June 18, 1993, with the licensee representatives denoted in Section 1, to summarize the purpose, scope, and findings of the inspection.
. The inspectors discussed the likely informational content of,the inspection report with regard to documents and processes reviewed during the inspection.
The licensee did not identify any documents or processes as proprietary.
10