IR 05000324/1989001
| ML20246M514 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/03/1989 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20246M494 | List: |
| References | |
| 50-324-89-01, 50-324-89-1, 50-325-89-01, 50-325-89-1, NUDOCS 8905190164 | |
| Download: ML20246M514 (109) | |
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A E82% UNITED STATES'
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' NUCLEAR REGULATORY COMMISSION
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j REGION 11 101 MARIETTA STREET, '*- I C ATLANTA, GEORGI A 30323 s n h
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Report Nos.: 50-325/89-01 and 50-324/89-01 ,
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Licensee: Carolina. Power and Light Company P. 0.' Box 1551
- Raleigh, NC 27602 l:
l Docket Nos.: 50-325 and 50-324 . License Nos.: DPR-71 and DPR-62 l ' Facility Name: Brun 4ic 1 ff 2 I r Inspection Co u . [ ary 9-13, 23-27, 1989 Inspector: /N"" 7 6 /
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W P/'K7efnsorge, PE ep-tsader Date Signed Team Members: G. Hallst i M. Hy j gnatonis M. Lauer
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M ha o Approved by: ,
3 / . ake,-Chief Date Signed M er als and Processes Section gi, eering Branch tvision of Reactor Safety SUMMARY Scope:
This Special, announced inspection consisted of an indepth team inspection of the maintenance program and its implementation. Temporary Instruction 2515/97 issued November 3, 1988, was use Results:
Overall, the maintenance program was judged to be " Good" with " Satisfactory"
' implementatio Areas of strength and weakness are highlighted in the Executive . Summary with details provided in the report. Two violations were identifie Failure to Take Adequate and Timely Corrective Actions
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Failure to Establish Adequate Measures to Control the Storage of Components With Sensitive Surfaces One unresolved item was identified related to the 10 CFR 21 Evaluation of SLC Pump Failures
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SUMMARY l
Background !
The Nuclear Regulatory Commission (NRC) considers effective maintenance of equipment and components a major aspect of ensuring safe nuclear plant operation and has made this area one of the NRC's highest prioritie In this regard, the Commission issued a Policy Statement dated March 23, 1988, that states, "it is the objective of the Commission that all components, systems, and structures of nuclear power plants be maintained so that plant equipment will perform its intended function when required. To accomplish this objective, each licensee should develop and implement a maintenance program which provides for the periodic evaluation, and prompt repair of plant components, systems, and structures to ensure their availability."
To ensure effective implementation of the Commission's maintenance policy, the NRC staff is undertaking a major program to inspect and evaluate the effectiveness of licensee maintenance activities. As part of this inspection activity, the current inspection was performed in accordance with guidance provided in NRC Temporary Instruction (TI) 2515/97, Maintenance Inspection, dated November 3, 1988. The TI includes a " Maintenance Inspection Tree" that identifies the major elements associated with effective maintenance. The tree was designed to ensure that all factors related to maintenance are evaluate Conduct of Inspection The maintenance inspection at the Brunswick Nuclear Station was initiated with a site meeting on December 13-16, 1988, where the inspection scope, including the maintenance inspection tree, was discussed. At that meeting, the licensee presented to the inspection team leader an overview of the site maintenance program. In addition, a comprehensive package of material, as requested by NRC letter dated November 25, 1988, was provided for inspection preparatio The inspection was conducted by a team consisting of a team leader and six inspector The team spent two weeks, January 9-13 and January 23-27, 1989, on site conducting the inspection.
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The inspectior was performance based, directed toward evaluation of equipment conditions; ;bservation of in process maintenance activities; review of equipment his tories and records; and evaluation of performance indicators, maintenance centrol procedures and the overall maintenance progra Maintenance activities were selectea for detail review by the team using the following criteria:
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PRA information provided by NRR
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Known industry problems
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Review of LERs - site specific problems
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Review of NRC Bulletins and Notices
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Review of Nonconforming Item Report
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Inspector's experience U . _ _ _ _ - _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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Based on the above selection criteria, the following specific systems were selected for direct inspection effort:
Standby Liquid Control System (SLC) (2040)
Residual Heat Removal (RHR) (2044)
Service Water System (SW) (4060)
Diesel Generator System (DS) (5095)
4 KV AC Distribution System Instrument Air System (IA) (6135)
HVAC Reactor Building (8185)
HVAC Turbine Building (8260)
Results The inspection results are presented in Figure 1 as the completed inspection tree. As indicated in the tree, three major areas of the licensee's mainte-nance program were evaluated: (1) Overall Plant Performance Related to Maintenance, (2) Management Support of Maintenance, and (3) Maintenance Implementation. Under each major area, a number of elements were evaluated, rated, and colored in accordance with the legend at the bottom of Figure 1 using the following guidelines:
" GOOD" Performance (Green)
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Overall, better than adequate; shows more than minimal effort; can have a few minor areas that need improvement
" SATISFACTORY" Performance -
Adequate, Weaknesses may exist, could be (Yellow) strengthened
" POOR" Performance (Red) - Inadequate or missing (Blue) -
Not evaluated In general, the top half of the box (element) was rated depending on whether the element was in place and the bottom half was rated depending on how well the element was being implemented. As noted in the tree, overall, the Brunswick program for establishing and implementing an effective maintenance program was rated "G000." The Implementation of the program was rated
" SATISFACTOR For the three major areas; (1) Overall Plant Performance was rated " GOOD", (2) Management Support was rated " SATISFACTORY" for program and implementation, (3) Maintenance implementation was rated "G000" for program and " SATISFACTORY" for implementatio These ratings were based on specific strengths and weaknesses iQntified in the issues section of the report. The following are the more significant strengths and weaknesses identified (see report for details):
Strengths: -
Plant housekeeping is excellan Journeymen craft personnel are knowledgeable and well trained for their job assignments.
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Maintenance facilities are well organized and physically well layed out and conveniently situate The Automated Maintenance Management System (AMMS) is most impressive and efficient.
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The morale and atmosphere of teamwork displayed by the craft personnel is well above average and reflected an almost nil turnover rat Weaknesses: -
Repeated failures to provide effective and timely corrective actio An ineffective System Engineering Program, resulting from: an inadequate program; high turnover rate for system engineers; excessive large number of collateral duties for system engineers; inadequate training for system engineers; and ineffective direction for system engineer (It should be noted that the licensee recognized this weakness and stated that they are reorganizing the Engineering Department to address this specific matter.)
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Excessive time for procurement of spare parts combined with an excessive large percentage of "out-of-stock" item Communication breakdown between the Operations / Maintenance /
Engineering Department A number of Maintenance personnel voiced the perception that Operations personnel were reluctant to release safety system components for Maintenance on "their watch." !
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Shallow or incorrect root cause analysi No tracking system to control the deferral of preventative maintenance activitie Manufacturer's preventative maintenance recommendations are not always implemente Many of the weaknesses identified had been identified by the licensee prior to the inspectio >
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SECTION B EVALUATION 0F PLANT MAINTENANCE I
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EVALUATION OF PLANT MAINTENANCE I. Overall Plant Performance Related To Maintenance Rating: . GOOD 1.0 Direct Measures Rating: GOOD Scope:
Overall plant performance related to maintenance was evaluated based on the licensee's performance as indicated by key plant performance indicators, such as reactor trips, engineered safety features (ESF)
actuations, radiation exposure, technical specification violations, forced outages, percentage of maintenance rework, work order backlog, and SALP ratir.g In order to further assess the overall plant performance related to maintenance, plant tours and equipment walkdowns were performed to evaluate plant appearance and material conditio In addition, plant programs established to assure good general housekeeping, and deficiency reporting and resolution were evaluate Inspection:
The rating of this section was based on the findings of the team in the areas of historical data and walkdown inspections.
I Findings / Observations:
Review of direct measures revealed plant availability was found to be acceptable with an improving trend; safety system availability was 85.8% for Unit 1 and 91.5% for Unit 2, which shows a need for improvement; an acceptable number of unplanned automatic scrams (3 total both units); an acceptable number of unplanned safety system actuations (1 per unit); during 1988, 94% of plant employees participated in work groups that applied total quality fundamentals workshop principles (Total Quality Implementation Plan); and the site set a two unit record run of 180 day The various walkdown inspections found the plant to be in relatively good material condition. The following observations were made:
The service water building was noted to be in much improved condition from previous inspections; equipment appeared to be adequately maintained; and minor problems were noted in the deficiency reporting syste Housekeeping is discussed in Section C, Issue _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ .
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Conclusion:
The team noted the fact that the site had recently set a two-unit record run of 180 days and that both units were found to be in good material condition. Based on the. inspection above, the concensus of the team for this element: GOO _ - _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
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II. Management Support of Maintenance Rating: ;
Program: SATISFACTORY Implementation: SATISFACTORY Scope:
-Management support of maintenance was examined by reviewing and evaluating (2.0) management commitment to and involvement in maintenance; (3.0)
management organization and administration for both the corporate and plant level; and (4.0) technical support provided to the maintenance organizatio i l
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1 2.0 Management Commitment and' Involvement L Rating:
l Program: NOT EVALUATED Implementation: GOOD Scope:
Management commitment and involvement was evaluated based on established utility programs to apply industry initiatives and the- implementation of these programs. In addition, management vigor and example related to implementing an effective maintenance program was evaluate Inspection: , l The rating of this section was based on application of industry initiatives and management's commitment to improvemen The program was not directly inspected so was NOT EVALUATE Findings /0 observations:
Review of the licensee's application of industry initiatives indicates the following: INP0 SOERs were reviewed and appeared to be adequately. resolved; ONS uses the NPRDS for trending and equipment failure history; the site implemented NUMARC guidelines for maintenance performance indicators and goal Examination of management vigor and example verified the following:
management (plant manager and department management representatives)
perform systematic area inspections; performance indicators are used, goals are set, and if achieved can bring a financial gain to management; directives set requirements for first level management to be at job sites in the plant; a " systems engineering" program has not been fully implemented; management has committed resources to <
develop an excellent Automated Maintenance Management System (AMMS)
which also has excellent history retrieval and trending capabilities; and improvements were noted in the deficiency reporting program which centralizes the reporting responsibilities, making it less burdensome to report a deficiency. The AMMS is further discussed in Section C, Issue 1 Conclusion:
Due to the fact that management appeared to be committed to the l
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application of industry initiatives, as stated above, and by observing an excellent maintenance data base, the implementation of this section was rated "G000." The program section was not reviewed in sufficient detail and although no major implementation weaknesses were identified, it was rated "NOT EVALUATED."
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3.0 Management Organization and Administration Rating:
Program: GOOD Implementation: SATISFACTORY The purpose of this inspection was to evaluate the effectiveness of the plant's organization, its function and interface between various groups such as Maintenance and Technical Support, ana esource control for maintenance activities and processes. Areas evaluated by the inspectors were: (1) resource allocation; (2) maintenance requirements; (3) performance measurements; (4) document control system; and (5) maintenance decision proces Inspection:
Inspection in this area was accomplished by the review of procedures included in Appendix 3 of this report; interviews with all levels of management; sampling of selected systems and component Work Request /
Job Orders (WR/J0s); and observation of maintenance meetings and interface activities between Maintenance and Technical Support group The sampled WR/J0s are listed in Appendix 6 of this repor Findings /0 observations:
Maintenance staffing level appears adequate; although the amount of Maintenance overtime appeared to be relatively high, especially during unit outage and Priority 1 work, the licensee maintained effective control on overtime work in order to comply with admin-istrative guidelines. Overtime is discussed in detail in Section C, Issue 12 of this repor A substantial amount of technical support is provided by contractors in the parts evaluation program. The allocation of technical support resources should be improved; System Engineering Department appears to be understaffed, overextended with engineers being assigned collateral duties, and frequent turnover This matter is further discussed in Section C, Issue The foreman's workload appears to be hig Foreman's work load is further discussed in Section C, Issue 2 EQ, Preventive, Corrective, Emergency (i .e. , Priority 1), Predictive Surveillance Testing, ISI required, and Modification activities have been implemented in the maintersi..e process.
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h The - methodology for identifying required maintenance has been proceduralized. However, procedure differences were : noted in the wording of "should" versus "shall" for. Troubled Tag / Sticker progra Procedures include the latest vendor recommendations in most case Procedures received a biannual review and are revised accordingl Root cause . analysis was observed to. be shallow in some of the completed WR/J0 This matter is further discussed in- Section C, E Issues 5. and 1 The licensee trends ten Maintenance Performance Indicators and goals, .which are the INP0/NUMARC established indicators / goals, including maintenance rework, even though INPO is still developing an industry performance goal. The licensee's last corporate QA audit of plant maintenance performance was comprehensive and conducted on October 3-14, 1988. The Document Control System for Maintenance Work Orders has been established, proceduralized, and is ' continuously updated. Upper level management gets involved and is generally aware of the decisions made regarding maintenance activities: equipment upgrade,' replacement, corrective maintenance, and plant aging. With the exception of high capital expenditure tasks, the licensee usually ;
goes' with wholesale replacement of components rather than repairing aging equipment. Electrical equipment is being refurbished or replaced consistent with the EQ rula (10 CFR 50.49)'. Vendor recom-mendations that impact plant aging, are' factored into'the licensee's PM progra PMs are deferred without a system for tracking the defferal This matter is further discussed in Section C, Issue 6. The licensee's program for repetitive failure analysis is discussed in Section C, Issue 1 Conclusion:
Based on the inspection above, the consensus of the team for .this element: the program was rated GOOD and the implementation was rated SATISFACTOR I
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4.0 Technical Support Rating:
Program: SATISFACTORY Implementation: P00R Scope:
The purpose of this inspection was to evaluate the technical support received by the Maintenance organization from other plant organiza-tions such as Engineering, Health Physics, Quality Control, Regulatory Compliance, and Onsite Nuclear Safety. Also of interest ,
in this area was the level of communications between various organizations and the role of Probability Risk Assessment (pRA) in the maintenance proces Inspection:
Inspection in this area was accomplished by the review of procedures included in Appendix 3 of this report; interviews with supervisors and engineers in various Technical Support organizations; inspection of selected WR/J0s, Engineering Work Requests (EWRs), Engineering Evaluation Reports (EERs), and licensee followup of NRC Information Notices and Generic Letters; and observation of ongoing maintenance activitic Findings /0 observations:
The team noted that while the system engineers of the Technical Support (T/S) group have conducted good engineering reviews in some of the areas, a number of weaknesses were found in the resolution of other technical issues. They were: (1) T/S did not ensure that manufacturer's recommendations were implemented; (2) technical issues were not adequately addressed in a timely manner; (3) some T/S eval-uations lacked good engineering principles; (4) T/S to Maintenance regarding material substitution was not conducted in a timely manner; (5) some T/S system engineers were not aware of problems for their assigned systems; (6) problems are raised by T/S, but there does not appear to be a formal method of resolution; (7) T/S system engineers are not included in the initial problem solving process; and (8) some T/S system engineers are not adequately familiar with their assigned system. The adequacy and timeliness of corrective actions is further discussed in Section C, Issue 5.
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Interviews with various system engineers indicated the following:
T/S' appeared to have a cumbersome process for raising. issuesf to management; T/S System Engineer reassignments (to cover different systems) occur frequently, the upshot of which is System Engineers are not familiar enough with their systems to provide effective support; T/S' System Engineers appeared to have too many collateral duties; T/S personnel turnover appeared-to be high in recent months; average number of hours worked by T/S personnel was high, approaching 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> per week; T/S morale appeared to.be low; and T/S engineers appeared to be very competent, but lacked directio There is an apparent " bottleneck" of getting out timely evaluations from the Project Engineering Procurement group for spare parts procuremen Material substitution is not timel T/S System Engineers are located outside the plant's security access area, thereby reducing possible effectiveness of communications between the Maintenance and Operations Department A formal position description for a System Engineer was developed in November 1987, but to date it has not been implemente Due to procedural changes in T/S, the backlog and timeliness of processing EWRs has markedly improved over the past yea The Maintenance Engineering group within the Maintenance organi-zation was observed to be involved 'in day-to-day maintenance activities. They directly interface between the craft foremen, job planners, Operations engineers, and System Engineers to get the job done. When craft foremen need assistance on root cause analysis or problem solving, they go to the maintenance engineer EQ requirements are adequately addressed and effectively implemente The PRA role in the maintenance process received very limited appli-l cation. PRA is discussed further in Section C, Issue 21. There appears to be adequate QA/QC involvement in maintenance activitie Appropriate Hold / verification criteria are identified and used. A program for documenting, reporting and trending quality deficiencies was inplace. Quarterly and monthly Nonconformance Trend Reports are provided to management. The Brunswick FSAR, Technical Specifica-tions, and applicable Systems Description, performance test and Maintenance procedures were updated appropriately for the ATWS Rule implementation affecting the standby liquid control syste NRC i commitments are tracked and commitments / action items are prioritize ONS performs the review and feedback of incoming NRC Information Notices (IENs), Vendor Service Bulletins, and INP0 Operating Experience Report Some problems associated with the implementation of Generic Letter 88-14 are discussed in Part C, Issue 1 _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - _ . _
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Inspection findings involving the health physics activities associated with maintenance are included in Section C, Issue 1 I Conclusion: I l
Based on the inspection above, the consensus of the team for this l element: the program was rated SATISFACTORY and the implementation was rated POO l
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III. Maintenance Implementation Rating:
Program: GOOD Implementation: SATISFACTORY Scope:
The purpose of this part of the inspection was to determine the quality I of the established controls and, more importantly, the implementation of these controls. The controls established in four areas were evaluate These areas are (5.0) Work Control, (6.0) Plant Maintenance Organization, (7.0) Maintenance Facilities Equipment and Materials Controls, and (8.0) Personnel Control. The effectiveness ras determined through a review of completed work orders, procedures, and other documentation associated with maintenance and training of maintenance personnel; physical observation of work in progress, tools in stock, and spare parts; and discussions with all levels of personnel.
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l 14 l 5.0 Work Control Rating:
Program: GOOD Implementation: GOOD Scope:
The purpose of this area of inspection was to evaluate the effective-ness of the maintenance work control process to assure that plant safety, operability, and reliability are maintained. Areas evaluated by the inspectors were: (1) review of work in progress; (2) control of work orders; (3) equipment maintenance records; (4) job planning; (5) prioritization of work; (6) scheduling of work; (7) control of maintenance backlog; (8) maintenance protec'ures; (9) post-maintenance testing; and (10) completed documentatio Controlling procedures, methods of work preparation, work in progress, completed work packages and use of various computer programs were reviewe Inspection:
Inspection in this area was accomplished by review of procedures included in Appendix 3; observation of the mainter.ance activities in progress included in Appendix 4 and review of work orders included in Appendix Findings / Observations:
Review of work in progress in the field indicated that: foremen observe the work in progress; the welders were properly qualified; personnel appear competent and properly qualified; procedures were followed; and no major problems were identified during the observa-tion of work.
I Examination of the work order control system revealed: a program in place to identify discrepancies; the automated maintenance management system (AMMS) is an excellent tool for documenting maintenance activities. The AMMS is further discussed in Section C, Issue 1 Review of equipment and maintenance history records indicated that:
maintenance history is easily retrievable through AMMS; work history is updated at the completion (closure) of the WR/J0; the Equipment Data Base System (EDBS) is being updated and expanded; repair time is tracked for each WR/J0; root cause analysis cauld be improved; NPRDS '
is used, but information retrieval is cumbersome; and the WR/JO data form includes an input for NPRDS.
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work schedul By review of the licensee's maintenance work scheduling, it was determined that: the mairitenance backlog is being trended and .this backlog appears to be decreasing; personnel are reassigned- to compensate for work loads in the various areas; site work force control group determines the . schedule for maintenance to reduce-conflicts; and the AMMS provides for WR/JO trackin The licensee's establishment of backlog controls was reviewed and -
. it was determined that: Preventive Maintenance (PM) activities are sometimes deferred by the use of PM exception documents without a tracking system for the number of repeat deferments. PM deferment is discussed further in Section C, Issue An inspection of- the conduct of job planning revealed: the safety significance of an. . item to be repaired / replaced is the first consideration; LCO items are worked until completion; drawings /
technical manuals / procedures are included on the WR/J0; the planner coordinates work between disciplines on a WR/J0; spare parts are identified on the WR/J0, when possible; personnel requirements /
qualifications are determined by the foreman;. and program / procedures do not allow coordination with System Engineering / Technical Suppor Foreman's responsibilities are discussed further in Section C, Issue 2 Conclusions:
Based on the inspection above, the consensus of the team for this element: the program was rated GOOD and the implementation was rated GOO l
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6.0 Plant Maintenance Organization Rating:
Program: GOOD Implementation: SATISFAC10RY Scope:
l The purpose of the inspection in this area was to evaluate the maintenance organization relative to control of maintenance activi-ties, personnel, documentation and communication. Areas evaluated by the inspectors were: (1) control of plant maintenance activities; (2) deficiency identification and control system; (3) maintenance trending; and (4) support interfaces. The implementation of main-tenance objectives and response to problems and events were also reviewe Inspection:
Inspection in this area was accomplished by observation of licensee's plant maintenance organization and how it responds to unusual events, i'
how it supports maintenance activities; how it controls and imple-ments maintenance activities; how it controls personnel; how it establishes documentation; and how it develoos lines of communication between plant management and craft personnel. Inspection in this area included review of procedures included in Appendix 3 and review of work orders included in Appendix Findings / Observations:
The review of the control of mechanical, electrical, and instru- l mentation and control maintenance activities revealed: the trouble ticket (green tag) program needs improvement; the HPCI turbine oil contamination is an ongoing maintenance problem; configuration control of equipment could be enhanced by proper identification tags being installed on plant equipment; all plant instruments are not included in the formal calibration program; no 10 CFR Part 21 evaluation performed for SLC pump IB spring failure; CRD flow control valve C12-F002 not repaired due to inadequate root cause analysis; instrument air system is not in accordance with as-built drawing -
skid-mounted equipment not identified; the duties assigned to the maintenance foremen appear excessive and these duties are frequently delegated; the evaluation of root cause is frequently performed by the mechanics; the number of rework items has steadily declined over the past four months; and procedures used in a maintenance activity are verified as appropriate before work is starte The green tag system is discussed further in Section C, Issue _ _ _ _ _ - _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _
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HPCI turbine oil contamination is discussed further in Section C, Issue Configuration control is discussed further in Section C, Issue Instrument calibration is discussed further in Section C, Issue 11. SLC pump spring failure is discussed further in Section C, Issue 3. CRD root cause analysis is discussed further in Section C, Issue 13. Instrument air system conflicts with drawings are dis-cussed further in Section C, issue 8.B. The duties of foremen are discussed further in Section C, Issue 2 A review of the licensee's method of control of contracted mainte-nance revealed: the licensee has standing contracts with several vendors for various services: the contracts define the scope of work required, the QA/QC responsibilities and the responsibilities for control of tools; the training requirements are listed for personnel supplied by outside vendors; and this program appears to be a well controlled program that meets the licensee's QA/QC commitment The licensee's deficiency identification and control system was reviewed and the following was determined: trouble ticket control needs improvements; and the trouble ticket procedure appears cumbersome to use, The trouble ticket (green tag) system is discussed further in Section C, Issue The licensee's performance trending was examined and the determina-tions were: (1) root cause analysis is weak, and (2) performance indicators are trended and the majority of them were found to be above industry standards. These were in: overtime work, percentage of outstanding non-outage maintenance WR/J0s greater than three months old, the ratio of highest priority (priorities 1 and 2)
non-outage corrective maintenance WR/J0s to total non-outage WR/J0s and overdue PMs which fluctuated through 1988 at above and below the industry standards. Positive performance indicator trending showed up in maintaining the Unit I forced outage rate at or below the industry median, low number of unplanned automatic scrams traceable to maintenance, and low lost time accident rate. Root cause analysis is discussed further in Section C, Issues 5. and 1 The support interfaces were reviewed and noted to be weak, the findings are included in the discussions in Section C, Issue Conclusions:
Based on the inspection above, the consensus of the team for this element: the program was rated GOOD and the implementation was rated SATISFACTORY.
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7.0 Maintenance Facilities, Equipment and Materials Control Rating:
Program: GOOD Implementation: SATISFACTORY Scope:
The maintenance facilities, equipment, and materials control were
,, evaluated by an inspection of: (1) maintenance facilities and equipment, (2) material controls (3) maintenance tool and equipment control, and (4) control and calibration of test equipmen Inspection:
The inspection in this area was accomplished by general inspection within the maintenance shops, tool rooms, and training area A general inspection of warehouse storage conditions and specific-examination of details associated with problems in procurement of spare part Findings / Observations The team found the following: maintenance facilities were located as efficiently as possible; maintenance supervisors' offices were located close to the shops; maintenance shops appeared to have most tools required for the work performed; the " Hot" and " clean" machine shops were considered programmatic strengths; parts and tools storage and requisition was well organized and adequately stocked; metering and calibration labs were.well organized and calibration activities efficiently completed; staging and laydown areas were adequate; rigging and scaffolding were adequate; warehouse storage was well organized and adequate with exception of protection of flanged and weld preparation surfaces as discussed in Section C. , Issue 15.;
training and mockup facilities appeared inadequate with relation to ALARA goals; and there are ongoing problems associated with the availability of spare parts is further discussed in Section C, Issue The " hot" and " clean" machine shops are discussed further in Section C, Issue 1 Storage protection is discussed further in Section C, Issue 1 Conclusions:
The team consensus was that the program for this area was rated GOOD. However, the team felt that the weaknesses identified in the contrcl of spare parts were sufficient to justify only a rating of SATISFACTORY for implementation. The team considers inadequacies in the licensee's control of spare parts to be a principal deficiency in implementation of the maintenance progra _ - _ _ _ _ _ _ _ _ _ _ _ _ - _
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l 8.0 personnel Control Rating:
Program: NOT EVALUATED Implementation: GOOD Scope:
The purpose of this inspection area was to evaluate staffing controls, training, testing and qualification and to assess the current statu Inspection:
Inspection activities consisted of interviews with supervisors 7-1 craft personnel, observation of work activities in the field, and a review of some documents and record Findings / Observations Observation of in progress work and discussions with craft personnel indicated that the electrical, I&C, and mechanical journeymen were knowledgeable and well trained for their jobs. Training is discussed
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further in Section C, Issue Staffing for craft personnel was considered adequate. Overtime work was maintained in compliance with BSEP procedure requirements. The morale and atmosphere of teamwork displayed by craft personnel was considered above average and is reflected in the low turnover. This is discussed further in Section C, Issue Discussions with supervisors indicated that the maintenance training program was in accordance with INPO requirements. The licensee representative stated that craft journeymen personnel in the electri-cal, I&C, and mechanical disciplines had INPO accreditation. System engineer training is inadequat System Engineering staffing and training is discussed further in Section C, Issue Quarterly maintenance real-time training sessions were comprehensive, effective and covered a broad range of topics important to maintenance activi-ties. This area is discussed further in Section C, Issue There was no evidence of drug problems. Performance of work by unqualified craft personnel is controlled and prevented by supervisor and quali-fied craft personne Conclusion:
Based on the inspection above, the concensus of the team for this area was: the program was NOT RATED and the implementation was GOOD.
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SECTION C ISSUES
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ISSUE PROBLEMS WITH SPARE PARTS Several problems associated with spare parts were noted by the team during this inspection. Details are as follows: Specification Requirements Part of the input which initiates the ordering of parts is generated by Section 4.2, " Planning Action," of MMM-00 Corrective mainte-nance (Automated Maintenance Management System). The AMMS is crosstied to the master Equipment Data Base System (EDBS) which assures minimization of duplicate inventory since only one set of part numbers are used. ENP 33.2 ensures that pertinent tag numbers and Component Identification Numbers (CIDs) are cross-referenced to the EDB The NRC team agreed that the AMMS was a strength on the maintenance program and noted its positive affects toward identification of the need for parts in question as well as providing status checks on parts to complete a specific WR/J0. Parts required for a specified piece of equipment is provided in the EDBS and can be reserved (if on hand) for a specific WR/J0. If they are on hand and reserved for another WR/J0, the planner may reassign parts with concurrence of the planning engineer. WR/J0s which require parts are held by the planner until parts are availabl Examples of Parts Delays Even though the AMMS provides efficient identification and tracking of the need for spare parts, the team noted several instances where excessive times were required to obtain the parts involve A partial list of examples is given below:
WR/JO 88-AK1Q1 - CRD Relief valve 1-C11-F001A Leaking 1/2 gpm (over six months waiting on parts)
WR/JO 85-AJSUI - Connections (hold down clips) on EDG No. 2 4KV Frequency Relay Capacitor 1-E2-AG7-81D initiated October 2,1985 (parts not available until October 11, 1988). Now awaiting EDG No. 2 outag WR/JO 86-BZNN1 - Repair of EDG No. 4 Solenoid Valve 2-DG4-SV-6555-4 (awaiting parts since 198 Considered low priority since valve only leaks l by on standby position). l
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WR/JO 85-AGNL2 - Replacement of Pressure Regulator 2-IA-PCV-2879 (initiated February 19, 1986, and on hold awaiting parts).
WR/JO 87-BFDP1 Elapsed time meter broke on CRD pump 2B (three years to get part).
WR/JO 86-ATSX1 - RHR keep filled valve leaki ng, needs seats (parts problem)
C. Procurement Engineering Bottleneck The team discussed the outstanding reasons for continued problems with excessive lead times for spare parts with cognizant licensee personnel. The team reviewed statistical data for December 1988 from the Materials Management Reporting System (MMRS) which included out-of-stock item trending for 1987-8 In December 1988, this represented approximately 1.6 percent of total inventory (approxi-mately 46,446 stock line items) and was mostly composed of Q-list parts (657 items from 763 total). Cognizant licensee personnel noted that this 1.6 percent was over three times their Jesired goal of 0.5 percent and the trend had not improved over the last year. The inspectors further noted that nearly half of the out-of-stock Q-list items were on hold for technical support for order document revie Therefore, the most serious bottleneck appeared to be in procurement f engineering.
l The team held follow on discussions with 'm rocurement Engineering
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Project Engineer and reviewed data asp ted with procurement l engineering activities for 1988. The project engineer provided data regarding the present (January 25, 1989), procurement engineering
! backlog versus priorities (as assigned from information from the
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Stock Inventory System (SIS)). The latest 645-item backlog was distributed as follows:
Backlog Priorities Items - N To Support l Unit 1 outage 14 Current outage 1 Unit 2 outage 1 Future outage l Rush 30 Operating unit 1 66 Trouble tickets awaiting parts 2 241 Stock replenishment None 293 Stock replenishment The team noted that approximately 17 percent of the total backlog (111 items) were causing delays to present WR/J0s. This represents backlogs which are directly delaying high priority work. This is consistent with statements by other licensee personnel that approxi-mately 25 percent of all WR/J0s experience delays awaiting spare parts.
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The team reviewed the chart showing procurement engineering backlog per week for 1988. The chart shows a peak backlog of around 1100 items in early September, a dramatic drop to around 550 items in December and an approximate 18 percent increase- to the present level. The project engineer noted that the dramatic drop reflected completior of a learning curve together with overtime (48-55 hours / week) for his staff (mostly subcontract employevi). However, cutbacks on allowed hours together with the release of- three people is now reflected in increased backlo The inspectors noted that the dramatic decrease was not reflected in the out-of-stock monthly data which indicated that the improved procurement engineering backlogs had not been reduced to levels necessary to actually improve spare part availability. Further that procurement engineering backlogs were now trending upwar The team requested any further information which would add confidence that spare parts availability would improve. No further information was indicated as being availabl D. Conclusion The team consensus was that spare parts availability problems would probably continue since licensee corrective actions appear INADEQUATE.
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ISSUE OPERATIONS / MAINTENANCE / ENGINEERING COMMUNICATIONS A below par communicative effort between maintenance, operations, and engineer-ing by the responsible organization can and appears to be delaying completion of WR/Jos. The responsible organization is defined to be the organization that has the immediate action that will allow the orderly forward movement through the steps necessary to complete the required activities for closure of a WR/J Review of the communication interfaces revealed that WR/J0s are frequently halted / delayed due to poor communications and/or lack of commitment by the responsible organization. Some examples are listed below:
One WR/JO (88-KEG 171) was submitted six times for authorization to start (ATS) work signature before it was approved. Better communication and scheduling could have prevented this and the WR/JO could have been performed earlier if the responsible organization was more responsive to resolving its proble One WR/JO (84-ABJD1) indicated in the job interrupt status section that the job was postponed because of lack of manpower during an outag Since there were no other entries in the section, it appears from the job interrupt status on the WR/JO that the responsible organization made no effort to move this WR/JO forward af ter the initial scheduling and proble On January 16, 1988, WR/JO (88-ABLS1) was written by operations requesting that 2C RHR pump motor be checked for possible grounding after being wetted by leakage from the service water system. The team was informed that the motor was in operation at the time of the leakage. The WR/JO was written as a priority 3 non-LCO. The planner identified the WR/JO as an emergent work item (not outage scheduled).
The A-loop of RHR (pumps A and C) was placed under clearance on the morning of January 16, 1988, for outage maintenance. This was prior to 88-ABLS1 being writte This clearance (2-88-0153) remained in place until February 19, 198 At this time the unit was in the dual unit E-bus outag Operations ran periodic test 8.2.2C (RHR Loop-A Pump Operability Test)
satisfactorily prior to restart of the uni Maintenance submitted the WR/JO for permission to work on March 29, 1988, and May 6, 1988, and permission was denied on both attempt The motor was successfully meggered and bridged on June 6,1988, and the WR/JO processed as complet _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ -
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i A WR/JO (88-ASKB1) was issued on July 6, 1988, which identified a pressure differential transmitter 2-C12-PDT-N008 as not being rated for the system pressure in which it was installed. Trouble ticket 000508 was hung and the PDT was isolated from the system. It was found in this status at the time of the NRC inspectio When questioned by the team, the information furnished by responsible licensee personnel indicated that the PDT was, in fact, qualified for the service but no action had been taken to clear the documentation and place the PDT in service The PDT was placed in service during the latter stages of this inspectio In the above examples, it can be seen that communications between organizations could have resulted in better equipment availability and more efficient use of manpowe The " job interrupt status" on the WR/JO could be enhanced as a communicative tool that would provide the history of work delays and job progress. It could also provide some type of work performance accountability for the affected department (responsible organization).
The team reviewed data associated total non outage Q-list WR/J0s greater than three months old. These data are tallied monthly and were reviewed for January through December 1988. Some improvement was noted but outstanding WR/J0s totaled 836 as of December 1988. The team also reviewed data associated with interrupted WR/J0s from July through December 1988. These interrupted WR/J0s accounted for a substantial percentage (10 to 25 percent) of the WR/J0s over three months ol The team further reviewed data illustrating the interrupted WR/J0s by reason which had been collected for the months of August through December 1988. Various reasons listed included: SF/ SOS Denial OPS Eng. Denial SWFCG Denial E&RC Del / Denial Tech Sup Delay Parts Emerg Priorities Manpower Plant /Sys Con Othe The team noted that reasons A through C were listed for the majority of interruptions and that this indicated SWFCG internal coordination /
communications problem I This point was discussed with SWFCG representatives who agreed with the teams'
observations and noted that SWFCG was aware of some of these types of problems but had been unable to overcome them by the time of this inspection. The team concluded that communications / coordinations within SWFCG was an area of NRC concern.
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The team consensus is that the communication / interface within the various departments needs improvement. But more importantly, it would then enable the licensee's management to be informed as to where the weaknesses exist, and provide them with the information needed to determine if priorities are needed in areas of engineering, maintenance craftsmen and operating personnel or if
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there is a need for additional expenditures for material The concept of system engineering is being modified at this site to be more responsive to plant problems and maintenance requirement The system engineers should be provided the necessary information through a procedural means, to ensure that the information is made available, to enable the individual to know and understand the status of the assigned syste They could in turn pr. ovide the necessary information for replacement parts, modifications and system statu The system engineering concept is a good
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maintenance tool if made to function properl __-_-________-_- _ __-__-- _ _ __ _ __ _ ____ _ _ _ _ _
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26 l ISSUE TECHNICAL SUPPORT / SYSTEMS ENGINEERING INSPECTION OF MAINTENANCE WORK AND ASSOCIATED ENGINEERING REVIEWS The team reviewed the maintenance history of the Standby Liquid Control (SLC) system, selected Service Water system components, selected Emergency !
Diesel Generator (EDG) components, Reactor Vessel head vent valves, and ,
a sampling of Electrical, I&C, and Mechanical Q-List WR/J0s using the licensee's AMMS. Following this review, the team then selected and reviewed a sampling of completed work packages (i.e., WR/J0s) and associated engineering review For the SLC system WR/JO maintenance review, the team noted that WR/J0s were initiated on all SLC pumps (Units 1 and 2) in 1987 to replace pump suction and discharge valve springs and insure that the replacement springs have a minimum of six active coils. This work is designated by WR/J0s 87-BLRQ1, 87-BLRP1, 87-BLRN1, and 87-BLRM1. Primary reason for this replacement activity is to assure spring service for approximately 300,000 cycles or 13.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of pump operation. This action was prompted by the licensee's Metallurgy Unit's recommendations following an evaluation of premature spring failures dicovered in early 1987 on the IB SLC pump The broken springs were found during inspection / replacement of.the suction and discharge valves of the IB pump. It was disassembled for the purpose to correct plunger packing and head gasket leaks observed during the monthly surveillance test, PT-6.1. Repair was accomplished under WR/JO 86-BZZN1 and the failed springs were turned over to Engineering for evaluatio Based on the licensee's Metallurgy Unit reports a c.ondensed version of the history and probable cause of spring failures is provided belo In April 1987, the Metallurgy Unit received two suction valve fractured springs and one discharge valve damaged spring off the IB pump. The affected springs were determined to have undergone approximately 500,000 cycles or 22.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of pump operation. The fractured and damaged springs consisted of five active coils. Cause of failure (fracture) was primarily due to fatigue. (Reference: CP&L Metallurgy Unit memo MSL No. 12-74.)
Also, although not conclusively determined, the cause of elevated spring stress levels was firstly attributed to noncentrical loading of a spring by improper spring seating within the valve cup. The damaged discharge valve spring's seating cup was observed to have a casting flaw and if the fractured springs were to have been contained in a similar cup, then the springs would have been loaded nonconcentrically. The second possible cause of elevated stress was spring design (e.g., insufficient number of active coils, incorrect dimensions, etc.).
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In March 1988, the Metallurgy Unit received 12 springs from the Unit 2 SLC pumps. The springs removed from the 2B pump consited of five active coils whereas those from the 2A pump consisted of six active coils each. Six active coil springs should have been used on the 2B pump and on the previously discussed IB pump. Furthermore, the licensee's discussion with the vendor (Union Pump Corporation) established that the vendor representative was unaware of how the five coil springs had gotten into the pumps (Reference: Metallurgy Unit memo of August 9,1988). There were no fractured springs found on both Unit 2 . pumps;. howeve' , one deformed spring appeared to have similar type . of permanent ut as previously observed in the failure region of the two formerly examined IB pump fractured springs. Nonetheless, the licensee determined that use of
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five active coil springs instead of six active coils was not a contributor to the cause of premature spring failur A similar evaluation for the 1A SLC pump was. not obtained during this ,
inspection. Per discussion with the Systems Engineer, the 1A pump springs were removed during the current Unit 1 outage and sent to the Metallurgy Unit for evaluation. Apparently there was no indication of broken springs upon removal but one spring was deformed and the springs were of the five active coil desig Based on the above findings, the inspector inquired about 10CFR21 applicability and whether or not a 10CFR21 evaluation / notification has been performed per procedure 0-RCI-0 The licensee was knowledgeable of this problem but at the time of the inspection did not perform the subject evaluatio . Regulatory Compliance Instruction (RCI)-06.4, paragraph 2.1, requires the Regulatory Compliance group to screen and evaluate perceived failures and defects for 10 CFR 21 applicabilit Items not normally generated within or received by Regulatory Compliance shall be supplied to Regulatory Compliance by the originating or responsible organization / unit / subunit for uses in performing the 10 CFR 21 applicability screenin Technical Support (T/S) is the responsible organization for resolution of the SLC pump spring proble The licensee's rationale in not performing a 10 CFR 21 applicability screening / evaluation before and at the time of the inspection was that the Metallurgy Unit has' not completed their investigation on the cause of spring failure Once that is completed, a 10 CFR 21 applicability screening and evaluation review will be conducted by the licensee. The licensee expects their Metallurgy Unit to corelete the investigation by the end of March 198 Pending NRC review of the licensee's completed 10 CFR 21 applicability review this mat:er will be identified as Unresolved Item 50-325, 324/89-01-03: "10 CFR 21 Evaluation of SLC Pump Spring Failures."
Further discussions with the licensee on the subject of SLC pump spring failures indicate that there was not a good documentation trail on this concer Per Engineering Procedure ENP-20, an Engineering Work Request (EWR) should have been generated by Technical Support (T/S) when the I
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. problem was first identified. The EWR could have served as vehicle for the following: (1) proper classification of the component deficiency (i.e., fractured pump springs) to be either a Condition Adverse to Quality (CATQ) or a Significant Condition Adverse to Quality (SCATQ) or a Routine Deficiency; (2) possible generation of an Engineering Evaluation Report (EER) to determine significance, acceptability, and justification for continued operation of the remaining SLC pumps while Metallurgy Unit completes the investigation on the cause of spring failure; and (3) request Regulatory Compliance to initiate a 10 CFR 21 screening and evaluation review on the found broken and deformed pump springs. It is unknown whether such an EWR was written. The above example exhibits a weakness in written communications between Maintenance, Technical Support and Regulatory Complianc On the positive side, in reviewing completed WR/J0s associated with SLC pump discharge Relief Valves (R/Vs) C41-F029A,B which leaked and had a carbon steel plug installed, it was evident by the available documentation that Technical Support was involved for problem evaluation and resolutio EWR No. 06106A was generated to evaluate 10 CFR 21 concern of proper material in the SLC R/Vs. And, a 10 CFR 21 Evaluation / Notification report number 87-13 was generated on December 16, 1987. The vendor, J. E. Lonergan Co. , was contacted regarding material compatibility and stated that stainless steel trim should have been supplie J.E. Lonergan conducted research of manufacturing records to determine if any other material compatibility might exist in SLC R/Vs supslied to BSEP. Two valves supplied as spares were found to have carbon steel bonnet spacer Foremen Interviews and Causes of Q-list WR/JO Backlog The team interviewed Electrical, I&C, and Mechanical foremen in order to obtain a better understanding of their work function and interface with other organizations. In particular, the WR/JO Q-List backlog greater than three months old was reviewed to determine work status and reasons for 1 outstanding work. The WR/JO backlog was found to be relatively small
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assigned to the three foremen that were interviewed; there were less than 30 outstanding WR/J0s for each foreman. Major reasons for work delay were due to parts unavailability, unprocessed EWRs, and work held up by Operations. In the I&C area four out of eleven outstanding WR/JOS were not worked on due to unprocessed EWRs. Two of these WR/J0s have been open since 1986, and the third one since 1987. They are: (1) 86-ASIN2, Electrical Conduit Corrosion in the Unit 1 Reactor Building North Core Spray Room - Maintenance awaiting disposition of EWR No. 6113; (2)
86-BNQK1, Transmitters for 02-H2 analyzers cause bad readings - Main- i tenance awaiting disposition of EWR No. 06296; (3) 87-BFAN1, Unreliable CAD Tank Level Indication -
Maintenance awaiting disposition of EWR No. 05749; and (4) 88-AKQP1 [ initiated 04/17/88], Local Flow Indication for 1B SBGT Failed Downscale - Maintenance awaiting disposition of EWR No. 0669 _ _ _ _ _ _ _ _ - _ _ _ -
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l In the Mechanical area, of the 27 outstanding WR/J0s for Unit 12, three were held-up by Operations and four are awaiting EWR disposition. Work w;s also deferred on two other WR/J0s: 85-AINX1, Reactor Building Air Receiver Drain Valve 2-RNA-V171 Leaks by Seat when Fully Closed and 87-APGE1, Service Water Supply Valve 2-SW-V128 to 2A Core Spray Room Cooler needs to be Rebuilt (packing leak). Reasons for work deferment were that the former WR/JO needs to have a clearance boundary established, ,
and on the latter WR/JO the vital SW header needs to be shut so that the valve can be repaire In the Electrical area for Unit 1, five out of thirteen open WR/J0s were due to parts unavailabilit The above information indicates a weakness for Maintenance to obtain timely Technical Support in order to get the work don . Integration of Regulatory Documents The team interviewed various licensee staff members and reviewed documen-tation to determine how well the licensee integrates regulatory documents l into the maintenance proces Per RCI-05.1, Regulatory Compliance Commitment Tracking procedure, the NRC commitments are. tracked biweekly via the Facility Automated Computer Tracking System (FACTS). This includes licensee tracking of NRC Generic Letters, Bulletins, Inspection Reports, and INPO Operating Experience Feedback reports. Per kCI-05.2, Regulatory Compliance Action Item Assignment and Response procedure, the ;
action items are assigned to responsible organizations and item resolution is being tracked. The team reviewed the FACTS outputs for the period of 1 01/12/89 to 01/25/89 and for the period of 01/26/89 to 02/08/89. FACTS documentation was well organized providing prioritization of the commit- ;
ment, date entercd, due date, responsible organization / individual, and ;
commitment descriptio The documentation for the SLC system was reviewed to verify changes made in satisfying the ATWS rule 10 CFR 50.62. The BSEP Technical Specifications, I Amendment No.106, and FSAR Amendment No. 6 reflect increased SLC positive !
displacement pump flow capacity (86 gpm) and a change in pump discharge !
R/V setpoint (1450 psig). Applicable procedures and work orders were then checked to see if appropriate changes were made in those documents. The following documents were reviewed and were verified by the team, to incorporate appropriate revisions: (1) SD-05, Rev. 6, System Description:
Standby Liquid Control System, Volume II; (2) PT-06.1, Rev. 32, Standby {
Liquid Control System (SLC) Operability Test; (3) PT-06.2.1, Rev.12, SLC '
Relief Valve Test; (4) WR/JO 88-AFMW1 which required readjustment of !
Unit 2 RV-C41-F0298 relief setpoint per pressure test PT-06.2.1; and (5) '
Plant Modification No.86-036 which specified required relief setpoint for the R/V [1450+-50psig]. Based on the above review the team concluded that f the regulatory documents were satisfactorily integrated into procedures and work orders. This function is viewed as a strengt ,
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The On-site Nuclear Safety (ONS). group performs the review and feedback of incoming NRC Information Notices (IENs), Vendor Service Bulletins, and INPO Operating Experience Reports. Procedure 0NSI-1, Operating Experience Feedback provides instructions for that function. The team interviewed ONS personnel and reviewed a sampling of eigth processed IENs. They were IENs 88-12, 88-24, 88-42, 88-57, 88-60, 88-69, 88-82, and 88-8 The team concluded.that while some of the IENs were evaluated in an exemplary manner with feedback from Maintenance it was offset by the evaluated IEN'88-86, Operating with Multiple Grounds in Direct Current Distribution System The evaluation of IEN 88-86 was taken on by ONS only and not disseminated to other organizations - Maintenance in particula Recognizing.that Maintenance wants to limit the amount of documentation for them to review when they depend on other organizations, in the team's judgement this IEN should have gone to Maintenance and possibly Technical
. Support (T/S) for feedback. Thus, there is some indication that communications between Maintenance and T/S and ONS can be improve Technical Support by System Engineers Technical support received by Maintenance was evaluated through the review of procedures, sampling of ongoing and completed maintenance worki and iterviews with supervisors and engineer During the review of maintenance activities and required T/S for such systems as RHR, Instrument Air, SLC, HPCI, CRD, EDG Supporting systems, and Balance of Plant (BOP) equipment, the team identified a number of weaknesses in the resolution of technical issue Also, the Project Engineering Procurement group was not generating timely evaluations for spare parts procurement; thereby further delaying the receipt of parts for maintenance activities. T/S ' failed to follow through and implement all of the manufacturer's (G.E.) recommendations into the PM (Preventive Maintenance) for RHR and CS motors which were found to have cracked surg ring brackets. For example, the motor heaters were not checked and l
moggering was not conducted. Technical reviews were not conducted in a
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timely manner with effective corrective actions for the 2C RHR pump motor oil leak and the HPCI oil system entrained with water. See Section C, Issue 5. for more details. In another example, there was an apparent indication that System Engineer (s) had specified the wrong size impeller for the Demineralized Water Transfer pump which after installation and pump run showed signs of brass particles in the oil. Lastly, Instrument Air System (IAS) PMs were not fully developed. This was exemplified by having no PM for IAS filters (CH-D005A&B) to the CRD scram valves and the PM for EDG Starting Air System didn't incorporate manufacturer"s recommendations to blow down piping when condition: indicate presence of moisture, oil, or particulat Per interviews with T/S personnel, the team noted that there was a high turnover of System Engineers in recent months. The System Engineer reassignments (to cover different systems) appear to occur frequentl And, as a result some System Engineers are not familier enough with
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their systems to provide effective support. This was evident by examples where the: team noted that the engineer had not read the system descrip-tion, received no formal training, and was not familiar with current and
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past problems. System Engineers also appeared.to have too many collateral duties. In a number of situations they were involved with technical issues on unassigned systems and possibly outside their expertise. A formal Position Description for a System Engineer was developed in November 1987, but to date it was not implemented. The' average number of hours worked by T/S personnel was high, approaching 70' hours per wee T/S personnel appea*ed to have a cumbersome process for raising issues to
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managemen . System Engineers are not always included in the initial problem solving process, and when problems are raised there is no formal method for resolution. On the positive side, T/S engineers appeared to be very competent, but lacked directio T/S System Engineers are located outside the plant's security access are This type of separation has the potential of reducing communications effectiveness with the Maintenance department and Operations as well as reducing the frequency of the System Engineer touring the plant. It is the Maintenance Engineering group within the Maintenance Organization that was observed to effectively support their own department in getting the _
work accomplished. The. Maintenance Engineer > are involved in day to day maintenance activities. They directly interface with craft foremen, job planners, Operations engineers, and System Engineers to get the job don When craft foremen need assistance on Root Cause Analysis or problem solving they go to the Maintenance Engineers. This group may be viewed as a " backbone" of the Maintenance organization to solve short-term technical problems and complete maintenance work in a shorter time fram Conclusion The team consensus was that based on the documentation reviewed and interviews held with various licensee personnel, a lack of written and possibly oral communications exists between the Operations, Technical Support, and Maintenance Departments. This observation was supported by examples found in the PM program for RHR and CS motors and SLC pump spring failure evaluatio Major reasons for the sampled WR/JO Q-List item backlog greater than three months were due to parts unavailability, unprocessed EWRs, and work held up by either Operations or SWFCG. This indicates that Maintenance may be lacking adequate and timely technical support to get the work don j The licensee's system for integration of regulatory documents into i procedures and work orders including NRC commitment tracking was found to
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j be well organized and effective. This function was viewed as a strengt _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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Project Engineering Procurement group was not generating timely evalua-tions for spare parts procurement. This is a weaknes Other weaknesses identified were:
An ineffective system engineering program, resulting from: high turnover rate of system engineers; frequent reassignments; excessive collateral duties; high overtime wcrk; and lack of trainin On the positive side, the system engineers appeared to be very competent, but sometimes lacked direction by managemen :
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ISSUE PROBLEMS WITH GREEN TAGS (Troubled Tag / Stickers)
Several problems associated with troubled (Green) tags were noted by the team during this inspection. Details are as follows: Specification Requirements ("shall" versus "should" terminology) l MMM-003, Revision 0, Corrective Maintenance (Automated Maintenance Management System) Section 3.9.1 states:
"All plant employees are responsible to ensure a WR/JO is initiated upon discovery of a nonconforming condition to an operational system or when they need to document any other maintenance activity. Where possible, the employee should hang a " Troubled Tag" in accordance with the guidelines set forth in 01-39. WR/JO initiation should be accomplished by the employee or a data entry clerk within his unit, as designated by the unit manager."
01-39, Revision 10, Handling of Work Requests / Job Orders, Section 5.0, paragraph 5.1.2 uses "should" terminology as shown below:
"5. Operators should carry blank troubled tags on their inspection round When a problem is detected, the operator may complete a troubled tag as follows:"
This terminology makes the completion of troubled tags optiona Although it is not referenced by MMM-003, AI-79, Revision 2, The Administration of the Automated Maintenance Management Systems, also contains instructions for the use of troubled tags / sticker Paragraph 5.22 of this procedure uses shall terminology which requires responsible plant personnel to complete troubled tags when problems are encountere "5.2.2 Engineers, technicians, etc., will carry blank troubled tags on their inspection rounds. When a problem is detected, the necessary information will be recorded on the top form, which is a detachable noncarbon required paper."
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34 Weaknesses l
After examination of the procedures involved, inspection of field condi-tions and interviews with various licensee personnel, the team identified the following weaknesses: Confusion exists among licensee personnel as to whether troubled tags are " recommended" or " req ui red . " This problem is partially caused by the present differences in wording between the controlling specifications. The team considers this weakness .to influence both program and implementatio . Examples of inadequacies regarding troubled tags were noted in three different typical situations as follows: Discrepant conditions were noted without troubled tags attached and with no indication that the condition was previously identifie The licensee began immediate correction for the majority of these items by initiating a new WR/JO and/or modifying previously issued WR/J0 !
Five 1 1/2" holes parallel and directly across from the reactor building dampers in duct DUC-VA-HVAC-DUCTS-RB at the 117 feet elevation (WR/JD 89-AAUW1 initiated for repair).
Damaged grounding strap of standby gas treatment (SGT)
system filter Unit 28 (WR/JO 89-AATX1 initiated for repair).
Hole in vertical HVAC duct at northwest corner of Unit 2 reactor building and 110 feet elevation (WR/JO 89-ABDD1 initiated to repair).
Loose bolts on 4160/480 volt MCC panels FA8 and FA Missing cover bolt on Unit 1 turbine building vent radiation monitor sample detector IR-TB-31 (WR/JO 89-ABCD1 initiated to replace).
Hole in HVAC duct above RV6 on Unit 2 turbine building and 70 feet elevation (WR/JO 89-ABCB1 initiated to correct).
Loose conduit hanging by wire It is located above turbine building 2A HVAC chiller (WR/JO 89-AAUR1 initiated to repair).
Loose conduit hangit.g by wire It is located above '
turbine building 2B HVAC chiller (WR/JO 89-AAUQ1 initiated to repair).
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i Missing mounting / bolts 'on the. pumpdown compressor _ for the
~ turbine building HVAC 1A chiller (WR/JO 89-AAUS1 initiated .
to repair). .{
Missing mounting bolts on the pumpdown compressor' for the l turbine building' HVAC 2B chiller (WR/JO 89-AAUT1 initiated j to correct). l Misadjusted pipe and conduit supports on heater- bay roof between 2A and 2B HVAC chillers and above 2-CCW-V69 and 2-CCW-V70 (WR/JO 89-AAWR1 initiated to correct).
Wastage on vacuum release valve nut an'd flange (2-CW-V57 and next valve - over) (WR/JO to be initiated' for replace-ment). I Wastage on cable tray 68C/DA near Unit 2 separation (WR/J0 '
to be initiated for replacement).
RHR suction relief valve E11-F030C leakin (A body to bonnet leak on this valve had been repaired via WR/JO 87-ASRD1.) New WR/JO 88-AILR1 was.. initiated on March 23, 1988 due to leak at . upstream flang Work was not yet complet Lerking drain line and support wastage adjacent to conduit box-XOA (WR/J0 to be initiated for repair).
Missing locking devices on connecting pins in actuator arms for HVAC dampers 2-VA-2A-EF-RB,. 2-VA-28-EF-RB, 2-VA-2C-EF-RB, and 2-VA-2D-RB. (WR/J0s were initiated or supplemented for repairs as follows:
2-VA-2A-EF-RB WR/JO 88-AQCJ1 revised 2-VA-2B-EF-RB WR/JO 88-AQCH1 revised 2-VA-20-EF-RB WR/JO 88-AZYB1 revised 2-VA-2C-EF-RB WR/JO 89-AAUP1 initiate b. Original discrepant conditions were not now present and troubled' tags were not removed. Examples are:
WR/JO 89-ABFD! Regarding loss of green light indication on Tag No. 00283 panel 2DGB-DY4 of EDG No. 2 WR/JO 88-APXA-1 Regarding PI-2C12-R012 failed upscal NOTE: This WR/JO was voided and tag should H have been removed. WR/JO 85-AGNL1 was ;
initiated January 7, 1985, for overpressure on IAS PI-2C12-R012 and required adjustment !
of pressure regulator 2-IA-PCV-2879. During
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36 completion of WR/JO 85-AGNL1 leak-by of the regulator was determined and 85-AGNL2 was l initiated on February 19, 1986 to replace j 2-IA-PCV-287 WR/JO 85-AGNL2 remained on 4 hold awaiting parts and was incorrectly attributed to require a hold of 88-AIAFI which was written to correct loss of auto-matic function of CRD drive water control valve 2-C12 F002A. Neither PCV-2879 nor 2-C12-F002A was repaired. Troubled tag for-88-AIAF1 was attached but not tag for B5-AGNL Tag No. 000364 Regarding leaking (1 gpm) of Jacket water expansion drain valve 1-MUD-V100 of EDG number 1 (WR/JO voided).
Tag No. 001223 Regarding leaking of valve 2FP-V109 WR/JO 87-BDKD1 in number 2 EDG room (WR/JO voided). Discrepant conditions were noted with indications that they were previously identified (e.g., temporary drain lines attached to leaking valves, mop heads used to absorb leakage, etc.), and without troubled tags attached. Examples are:
Bonnet leak from valve 2-C12-F034 piped to drain (WR/JO 88-ARYB1). Review of WR/JO identified that leak was not repaired and troubled tag was inadvertently remove Control panel on number 2A turbine building HVAC chiller (located on top of turbine building) left open to the element Mechanical seal leakage of service water lube water pumps IB, 2A, and 2B WR/J0s initiated for repair were as follows:
Pump 113 - WR/JO 89-AATL1 Pump 2A - WR/JO 89-BHFR1 Pump 2B - WR/JO 89-ABGA1 C. Conclusion:
The team's conclusion was that the troubled tag / sticker program was inadequate and its implementation was also inadequat :
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ISSUE NO. 5 CORRECTIVE ACTION The following paragraphs discuss in detail various plant deficiencies / issues and what appeared to be the licensee's inadequate corrective actions in resolving the deficiencies / issue Surge Ring Brackets The licensee was notified by GE, on March 18, 1987, of a potential reportable condition (PRC), identified as PRC 87-01, ECCS pump motor bracket and felt blocking. The PRC identified a problem involving fatigue failure of the end-turn support brackets and cracking of the felt end-turn blocking which was found during an inspection of similar RHR and CS pump motor The end-turn brackets and blocking are part of the design configuration which support the stator winding end-turn The PRC stated motors with broken or cracked brackets / blocking do not represent a substantial safety hazard or represent an imminent failure potentia It did state that if broken brackets are found that it would be prudent to disassemble, completely inspect and restore the end-turn assemblies as soon as is practical . The PRC also stated that the GE qualification for these motors recommends a complete disassembly and inspection after ten years of operation regardless of bracket failur The motors have been in service for approximately 14 years and have not been inspected as recommended by G The PRC stated that the end-turn support brackets should be inspected on an annual basi s until favorable experience indicates otherwis On July 10, 1987, a vendor recommendation deviation form was approved and proposed that Maintenance perform the inspection on an 18-month interval in order to allow repairs to be made as necessary. To date, no repairs have been mad GE conducted a study and evaluation of Maintenance activities for the subject motors and reported their findings in GE Report EQDE-10-018 The report made the following recommendations: Monthly - verify space heater operation Quarterly 1) Measure insulation resistance i 2) Measure polarization index of motor and power leads from breaker.
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c. Ten years - Complete motor disassembly and inspectio The only resistance measurement taken at this time is an 18-month interval meggering. It did-not appear that any of the recommended preventative maintenance items had been implemented by the license The initial surge ring inspections were completed 'by October 1987 and identified cracked brackets in the following motors:
1A RHR 1B RHR 1C RHR 2A RHR 2C RHR 2D RHR 1B CS Two of the motors were found with all six surge ring brackets cracke The licensee continued to discuss the deficiencies with GE and in May 1988 issued a contract to GE to develop a test methodology in order to maintain / assure that the qualifi-cation basis of the motors is maintaine The special test report was received by the licensee and it provided the technical basis for dispositioning the ECCS motors with cracked end-turn surge ring bracket It stated that the ,
broken surge ring brackets reduce the amount of support provided '
to the end-turn portion of the coils and potentially could affect motor operability during accident conditions where high humidity and moisture are presen The justification to disposition the motor deficiencies was based on assuring that the underlying ground insulation was functional and showing that the motor is protected against the effects of high humidity and moistur The evaluation concluded that the motors would be adequately protected during LOCA accident conditions, provided the DC HiPOT test was successfully performed and provided that the internal space heaters were functioning to keep the coil temperature at least 20F above ambient. The evaluation stated that a system analysis should be completed to confirm that whe . ,ome motors are assumed to be inoperable, due to humidity, that the remaining motors have adequate capacity to maintain reactor water leve It also stated that the potential long-term effects of postulated insulation cracks, humidity and conductive dust have not been evaluated and that the conclusions reached were not considered valid for the long ter .. _ _ - _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
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. The special test report ' detailed the provisions necessary to justify motor acceptability and stated that the z following conditions must~be satisfied to maintain the motor acceptability
'with broken surge ring brackets for_ two fuel cycles or- three years after completion of the test i
.. 'Successfully complete the three insulation system tests after all other - TS surveillance .have been completed.
1 Verify operation of all space heaters, i . Measure motor stator temperatures and ensure they are greater than 20F above ambient room temperatur Review the plant arrangement and verify separation between the RHR pump rooms and 'any HPCI line break ;
locatio : Review the exist'ing safety analysis in the FSAP. fo HPCI accident scenario with a portion of the ECCS motors out of servic As of February 2,1989, no apparent action had been taken in -
response to this test repor During the inspection, the team observed that the space heater breakers were physically close It was noted that heater current readings had not been taken at this point and that current readings could have been easily obtainable. It was also
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found that the RTDs, which are embedded in the motor stator windings, were not connected to the plant process computer. The licensee is unable, at this time, to easily measure the stator winding temperature to ensure that it is 20F above ambient as o required by the special test repor The . team were informed that a new RHR motor and a new CS motor had been ordered and were due to arrive during the second quarter of 1989. Motor repairs were to commence at that time and were scheduled for completion within three year Prompt corrective actions should be taken to resolve potential safety-related issues. The licensee f ailed to take actions as recommended by PRC 87-01, EQ DE-10-0187 or a GE special test report. Many of the recommendations would have required few resources or little manpowe Due to the fact that continued reliability was based on successful completion of resistance
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testing and maintenance of motor stator temperature and the fact that the licensee had failed to take any action for five months
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after receiving this information, this item is considered to be an example of inadequate corrective action and is identified as an example of violation 89-01-01, Failure to take adequate and timely corrective actio RHR Motor 2C Oil Reservoir Leak On March 3,1986, WR/JO 86 AJZS1 was initiated to identify a discrepancy with RHR motor 2C, M-E11-C002C-M, in that oil was found seeping from the side of the motor. Apparently no action was taken on this work request until - April 14, 1987, and it was found at this time that the motor was oily from the top screen to the pump all the way aroun The motor was cleaned, left in a satisfactory condition and the. source of the leak was not determined at this tim On September 30, 1987, it was noted that oil was coming from three cracks located on the bottom of the upper bearing lube oil reservoi On the same date, a memo was received by Maintenance from Technical Support addressing the operability status. The memo made the following state-ments: The existing condition of the upper oil reservoir casing will not affect the operability of the pump moto The inspection program / lubrication program will detect any decreasing oil level and correct it accordingly, A repair program can be implemented to allow the orderly and timely repai The existing condition is the same as that which has existed for some time without degradation to the moto The memo was inadequate in that good engineering principles were not used to justify continued operabilit a. No basis was identified to show why the cracked reservoir would not affect operabilit b. The Maintenance PM Group, responsible for oil analysis, was not aware that they needed to monitor for decreasing oil level and therefore did not maintain records with adequate detail to determine the rate of leakage or to determine pump running versus idle leakag c. Because the existing condition has not caused degradation does not mean that future problems will not develop or that continued operation with the deficiency is acceptabl .
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_ _ On November 16, 1987, WR/JO 87BJH21 was initiated and stated that the casing crack on the oil reservoir has saturated the pump stator winding The motor was again cleaned externally and was inspected by Technical Support. It was found that pin hole leaks had developed in the bottom of the upper reservoir casing, not cracks as originally identifie Per a system ' engineer's memo dated January 13, 1988, it was noted that Technical Support contacted GE's Motor Division concerning the recommended action for dealing with the 2C RHR motor upper reservoir oil leak. GE was noted as having no concern regarding the immediate operability of the motor, but recommended an expeditious repair be pursued as the long-term effects of the oil on some internal insulation material was not know The system engineer also stated that no formal documentation exists concerning extended operation with existing conditions and emphasized that " expeditious repair was essential as no basis exists for continued operation indefinitely."
Prompt corrective actions should be taken to resolve potential safety-related issues. A work request was written and it appeared that Maintenance did not respond for over one year, engineer evaluations were not based on sound engineering practices, and a flag was raised by a system engineer stating that the repair was essential as no basis exists for continued operation. At this time, the oil leak on the 2C RHR motor upper oil reservoir still exists as it has for the last three year This concern is considered to be another example of irsdequate corrective action and is identified as part of violation 89-01-01, Failure to take adequate and timely corrective actio HPCI 011 Contamination The Licensee is continuing to experience a problem with water contamina-tion of the HPCI turbine lube oil sum This item was previously addressed in inspection report 88-38 and an unresolved item was identified
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(325/88-38-04 and 324/88-38-04).
It appeared that the water contamination problem did not surface until the type of oil was changed to a lighter weight oil in late 198 Interviews indicated that prior to 1987, water contamination had been found in the HPCI pumps. Due to the fact that the water and oil did not readily mix, the water was easily drained from the sumps prior to taking a sampl The sample therefore did not show the water contaminatio Apparently following the change of oil type to a lightweight oil the water mixed more readily with the oil and water contamination became a proble The problem was aggravated since the licensee began running the HPCI oil pumps which helped keep the water entrained in the oil. At this point when the pumps were sampled, the water could no longer be drawn off before
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a sample was taken. The water contamination levels began to increase and at various times from February 1987 through July 1988, water contamination levels were listed as "too much to count."
Unit 1 Micro gm/gm Micro gm/qm August 1987 -
300 April 1988 -
8370 September 1987 - 229 May 1988 -
25000 October 1987 -
1199 June 1988 -
TMTC November 1987 -
1125 July 1988 -
TMTC ,
December 1987 - 1087 August 1988 -
16260 '
January 1988 -
5880 September 1988 - 24490 February 1988 -
9200 October 1988 -
32300 1 March 1988 -
22720 Unit 2 Micro gm/gm Micro gm/gm February 1987 -
2600 June 1988 -
TMTC March 1987 -
31000 July 1988 -
TMTC April 1987 -
14000 August 1988 -
7600 April 1988 -
TMTC September 1988 - 3410 May 1988 -
25000 E&RC procedure 1145, Sampling and Analysis Schedule for Lubricating Oils, Revision 8, previously set the acceptance criteria for moisture at 5000 micro gm/gm. EWR 06897 was initiated and Technical Support, after discussion with the bearing vendor, established 10,000 micro gm/gm as the high limit and stated that 20,000 micro gm/gm was the point where potential bearing damage could occur. The Unit 2 HPCI oil water contami-nation levels increased by a factor of 10 in February 1987 and a factor of 100 in March 1987, above the previous normal levels of approximately 200-300 micro gm/gm. Following the increases, the licensee's preventative maintenance group failed to take any further samples between April 1987 and April 198 The April 1988 sample was found to be "too much to count." Discussions indicated that samples were not taken due to a clogged sample line and a misunderstanding that a proposed plant modifica-tion had resolved the contamination issu The Unit 1 HPCI oil water contamination levels began to increase in October 1987 and every sample from February 1988 through October 1988 exceeded the original 5,000 micro gm/gm limi For six months in 1988, the 20,000 micro gm/gm potential bearing damage limit was exceeded.
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Since this problem was discovered, the. licensee has taken steps to reduce the water concentration by filtering the oil, which has been successful ;
i .in reducing the amount of water contamination. Technical Support has evaluated the problem and has determined that the water inleakage is coming from steam condensate leakage from 1-E41-V8, HPSI turbine sto valve. Due to the original design problem which allowed condensate to leek down the shaf t and into the oil leakoff on the turbine stop valve, the proposed repairs may be appropriate only for short term. 'It was also
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noted that maintenance personnel did not consider the stop' valve to.be th only cause for the water contaminatio From discussions, it was found that the main turbine driven feedwater pumps experienced a similar water contamination when shut down. Maintenance personnel feel that the major contributor to the water contamination is condensation in the lube oil
' tank, which is aggravated by the high temperature and humidity of the HPCI pump -roo A different solution will be required if this is the root
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Caus The licensee's program for oil sampling was inadequate .in that water contamination of the HPC1 turoine oil was not adequately. addresse Water contamination levels remained high for an extended period of tim Samples were not taken for one year after initial indications of water contamination on Unit 2 HPCI pump. Unit 1 HPCI experienced water contamination and Unit 2 HPCI was not checked for a common proble Unit 1 HPCI remained at an elevated water contamination level for an extended period of tim The root cause for the source of the water contamination has not been determined. The licensee's inability to resolve this issue in a timely manner and the failure of the oil analysis program to adequately perform sampling are considered to be a violation of. NRC requirements and collectively are identified as violation 324/89-01-01 and 325/89-01-01, Failure to Take Adequate and Timely Corrective Actio The three examples cited above demonstrate that the licensee failed to take adequate or timely corrective actions for conditions adverse to quality on a number of occasion This failure is indicative of inadequate measures to assure conditions adverse to quality are promptly ,
identified and corrected. The preceding is a violation of Title Ten Code !
l~ of Federal Regulations Part 5010 CFR 50 Appendix B, Criterion XVI. This violation will be identified as 50-325, 324/89-01-01: Failure to Take ,
Adequate and Timely Corrective Actio ! A Pump Nitrogen Accumulator Leaks The team reviewed the maintenance history of SLC Nitrogen Accumulator leaks. The following Unit 2 WR/J0s were reviewed for problem description, i repair, and cause identification: 85-AJYG1, 86-BRDF1, 86-AMSA1, 87-AMAK1, i 88-ACAR1, 88-AJQH1, 88-AJQH2, 88-ANMX1, 88-ATMA 1, and 88-BBCH1. All of l the above WR/J0s applied to the 2A pump Nitrogen (N2) accumulator with the same problem of having a leak about the needle valve or stem are In l
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reviewing the maintenance records the same type of problem did not appear to have occurred at least on a repetitve basis on the IA, IB, and 2B N2 accumulators. On May 24, 1988, an EWR No. 06771 was written requesting engineering assistance to look into the matte This EWR was written after at least six repetitive failures of the 2A N2 accumulator over a 2-1/2 year perio Per EWR No. 06771, the primary cause of the problem was improper alignment or overtorque of the testing rig (recharging equipment and pressure gauges) when connected to the N2 accumulator during performance of PT EWR No. 06771 was dispositioned by recommending that the problem could be alleviated by using a testing rig and running a high pressure hose from the gauges to the accumulator. On August 22, 1988, the Engineering Review Board (ERB) learned that the recommendation was successfully applied during the last PT, and that the matter can be considered resolved. In using the AMMS, the team noted that another WR/JO 88-BBCH1 was written for SLC pump 2A N2 accumulator. The WR/JO was initiated on October 12, 1988, and is outstanding pending availability of parts; described trouble was that the charging valve on top of the accumulator has a slow leak detectable with soap solution. Cause of trouble will probably be deter-mined after the WR/JO is complete Based on the above described review, the team concluded that the licensee's root cause analysis of the N2 accumulator leaks was shallow, particularly prior to the issuance of EWR No. 0677 This led to repetitve N2 accumulator leaks. Also, several completed WR/J0s do not descibe the cause of trouble.
i E. Conventional Service Water (SW) Pump C Discharge Check Valve Rework The team reviewed maintenance history on the SW conventional pump C discharge check valve CHV-SW-V23. The following WR/J0s were inspected for problem desciption, repair, and cause identification:
WR/JO Number Initiation Date Trouble 88-AHAX1 03/08/88 Valve has approx. leak of 30dpm when pump is runnin AXWM1 08/26/88 Hinge pin bolt pin gasket leaks 88-AXWM2 09/10/88 Attempted tightening of pin bolt did not stop leak; rework required 88-BAZA1 10/10/88 Small amount of water on lower flange of valve indicates slight leak I
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For WR/JO 88-AHAX1 permission to start work received Operations approval on or about 8/26/88. Tightening of the hinge post bolts did not stop leakage and WR/JO 88-AXWM1 was written to replace the gasket. Apparent cause of problem was incorrect installation of gaske Work on WR/JO 88-AXWM1 was completed on 9/09/88, in which the valve was removed and replaced requiring QC sign-off for proper torque verification of fastened valve flange. Maintenance obtained QC sign-off during the night shift of 9/09/88. On 9/10/88, 12:02 a.m. , another WR/JO 88-AXWM2 was initiated to repair flange leak on the check valve's inlet side. Cause of trouble was that the lower flange studs were not torqued. Repairs were completed with QC sign-off and a PMT per PT-24.1- On 10/10/88, WR/JO 88-BAZA1 was initiated to repair a leak off the valve's lower flange. Cause of leak was due to improper number of gaskets used during the last installatio Based on the above, the teem concluded that the QC inspector did not adequately verify proper torque on the check valve flange studs for WR/JO 88-AXWM1, and that the craft's repair work (corrective action) on this particular valve was inadequat Conclusion:
The team's concensus is the licensee has clearly failed to provide effective timely corrective action.
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l ( 46 ISSUE NO. 6
PREVENTIVE MAINTENANCE PROGRAM WEAKNESSES A. Deferment of PMs by PM Exceptions is allowed by BSEP's program (Procedure i MMM-004, paragraph 5.8). The PM exception is a document that explains
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the reason for a PM exception. It is signed by the foreman, maintenance i supervisor, maintenance planning engineer, and a planner / analyst. Once a PM exception is issued, the WR/JO is annotated accordingly and the WR/JO is processed so that it is no longer outstanding. A new WR/JO is issued to reschedule the deferred PM. The new WR/JO does not indicate that it ,
was issued to replace a WR/JO for a deferred PM and if for some reason ;
this second WR/JO cannot be performed when due, it also can be deferred 1 (PM exception). A new third WR/JO would then be issued to replace the second, etc. Each such WR/JO provides no indications that it is replacing the first, second, third, etc. , deferred P In addition, the present program does not require escalation of management approval for any PM deferrals regardless of the number of times it has been deferre The following PM deferrals are examples of the above discussion: PM route No. IE B2192 for Procedure MI-11-25A for UV Relay (Tag number 1-El-AE7-27HS) on WR/J0s 870TT151, 880TT061, and 880TT35 . PM route No.1E B2193 for Procedure MI-11-25A for UV Relay (Tag number 1-El-AGS-27HS) on WR/J0s 87PNG151 and 88PGN06 . PM route No. IE B2 110 for Procedure MI-11-21 for Loss of Excitation Relay (Tag number 1-El-AE8-40) on WR/J0s 88MMM061 and 88MMM35 The licensee's representative indicated that a program change was being l considered and would possibly include the following items: New WR/J0s that are issued for deferred WR/J0s would indicate if it was first, second, etc., deferra . Management escalation for approval for second and subsequent deferral IAS PM Deficiencies URC's Gereric Letter (GL) 88-14 concerning instrument air problems had a requirement that licensees verify that PMs were being conducted (on equipment in this system) in accordance with manufacturer's recommenda-tions. A review of the licensee's procedures and manufacturer's recom-mendations showed two examples where this was not the cas j No PMs had been written for inspection, and cleaning, or replacing the scram valve, pilot air instrument filters C11-D005A and Procedure OPM-FLT 500 provides these instructions for filters C11-D006 A&B on a refueling basi However, the D006 filters are substantially different from the D005s. Cognizant licensee personnel informed the team that the required procedures were not yet complet _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . - - _ )
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Procedure MI-10-501M provides instructions for inspection and cleaning or replacement of EDG starting air fiiters, strainers and traps every 18 months. This procedure did not include manufacturer's
. recommendations to blow down piping if conditions were discovered which indicated moisture, oil, or particulate in the vestream piping. The licensee's response to this discrepancy was to treat the situation as a generic problem. Policy Notice (PN)89-001,.
Revision 0, was issued on January 24, 1989, to correct the proble The inspectors reviewed PN 89-001 and agreed that clear direction was established to accomplish the required corrective actions C. Conclusions After review of the above, the team consensus was, the licensee should to be commended regarding the response to GL 88-14 directives. However, the items identified, poor maintenance history, and lack of completion of all necessary corrective actions outweighed other considerations and the team agreed that the above exanples demonstrated a w rak'1ess on the PM program and its implementation.
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ISSUE NO. 7 HOUSEKEEPING During this inspection the team observed general housekeeping conditions-throughout the Unit I containment, Unit 1 and Unit 2 reactor buildings, turbine buildings, warehouses, shops and training facilities. Programmatic control of housekeeping is maintained by MP-12, Revision 12, General Cleanliness Procedur The team noted a general high level of cleanliness within all areas of the plant. The team consensus was that general plant housekeeping is a major strengt I
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ISSUE NO. 8 l
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CONFIGURATION CONTROL PROBLEMS i
Several examples of problems associated with configuration control were noted by the inspectors during this inspectio Details are as follows: EDG Air Start System l
The team noted that identification tags for installed EDG air start equip-ment do not agree with designators on the P& ids and as listed in the AMMS system. Examples of installed identifiers (Vendor Instrument Designators)
are listed below. Identifiers in parenthesis are AMMS system designators:
4-DG-PSH-3PS (2-DG4-PS-6524-4)
4-DG-PSH-4PS (2-DG4-PS-6523-4)
2-DG-PSH-3PS (2-DG2-PS-6524-2)
4-DG-PSH-202PS (2-DG4-PS-6525-4)
2-DG-PSH-4PS (2-DG2-PS-6523-2)
2-DG-PSH-204PS (2-DG2-PS-6521-2)
Similar conditions may exist for other systems and equipmen It was noted that the licensee does have a cross reference from the vendor designator to the AMMS designators for the above equipmen Further, color-coding for ID tags- of all installed S/R equipment is not uniform (i.e. , some identification tags are color-coded and some are not). Non-color-coded equipment ID tags and different numbers from P& ids and AMMS numbers are considered to be a weaknes Skid-Mounted HVAC Equipment The team noted several discrepancies between that latest "as-built" drawing of the Unit 2 control room essential control air compressors and the actual condition on the field. Discrepancies included configuration errors, i.e., omission of traps downstream of PV 1646, mis-location of PI 1635 (upstream rather than downstream of PV 1636), and omission of pressure gages upstream of RV-13 and RV-1 Additionally, the majority of the equipment were missing permanent identification tags. A partial list is as follows:
Valves Filters Gages RV-12 A-9 PI 1634 RV-13 A-10 PI upstream of RV-12 2-VA-V2 PI upstream of RV-13 2-VA-V1 PV 1636 PV 1637 RV-14
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-Followon discussions with cognizant licensee personnel' revealed that this system had been " skid-mounted" and this level of detail had not been historically included in "as-built" drawing However, the instrument calibration program was requiring that all such items now be properly identified with permanent tags. Further, that the design drawings for this equipment, drawing No. F.P. 04321, sheet 3 of 6, had been recently revised (Revision G dated January 11, 1989) and should not exhibit the discrepancies involve Review of the revision showcd that most discrepancies were not correcte Conclusion After review of the above circumstances, the team consensus was that configuration control was deficient with regard to proper permanent identification tags for installed plant equipment. Configuration control will be considered a weakness in the maintenance program.
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ISSUE NO. 9 CRAFT PERSONNEL AND TRAINING A. Strength: Unit 2 reactor building craft personnel appear well trained and knowledgeabl The team reviewed training records and conducted interviews with over half of the mechanical craft personnel assigned to the Unit 2 reactor buildin This crew includes two senior mechanics, seven first class mechanics and one second class mechanic. The ratio of senior to first class mechanics is typical of all mechanical crews as shown below:
Crew Senior Mechanics Mech 1/C Mech 2/C Unit 2 Rx 2 7 1 TB 2 6 1 PT 2 9 1 Auxiliary 2 7 0 Radwaste 3 8 0 Unit 1 Rx 2 8 0 TB 2 7 0 Fuel Handling 2 7 1 Outside 2 8 0 Approximately sixty-five percent of mechanical craftsmen are also quality as machinists and approximately twenty-four percent are also certified welder The mechanical craft personnel were asked specific questions related to methods to minimize and control hot particles (radioactive particulate)
during grinding, the use of HP survey instruments, troubleshooting and repair of centrifugal pumps, inspection and repair of valves (including seat lapping, troubleshooting and repair of MOVs). General questions were also asked, regarding the following procedures:
0-MMM-003, Corrective Maintenance ( Automated maintenance management system)
l MP-12, General Cleanliness Procedure l MP-36, Packing f
l MP-57, Limitorque Valve - Actuator Failure Analysis and Trouble-shooting Guide MP-60, Valve Failure Analysis Guide
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All questions were answered satisfactoril It is considered that these l craftsmen were well trained and demonstrated knowledge and enthusiasm regarding their work. The team considers this a strength.
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1 B. Strength: "No" craft turnove The team reviewed data regarding craft turnover during this inspectio Results of this review for all craft personnel for both units indicate that craft turnover is nearly zero. This, together with the apparent good
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display of team spirit, the strong craft training and good control of overtime is considared a strength by the NRC team.
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C. Strength: Real-Time Training The team reviewed the lesson plan and personnel attendance for Quarterly Maintenance Real-Time Training. This training is administered by Main-tenance group supervision and serves as the main vehicle for continuous trainin Contents of the fourth quarter 1988 lesson plan were found to be very comprehensive, containing such topics as: (1) INPO Significant Operating Experience Report (50ER) 88-1, Instrument Air Failures; (2) Operating Experience Report (0ER) 18-88, MOV Failure due to Missing /
Painted Over or Improperly Installed T-Drains; (3) NCR A-88-033, Rosemount Mounting Brackets not Seismically Qualified and NCR S-88-038, Use of Non-Q-List Item in a Safety Related Application; (4) Engineering Evalua-tion Reports including direction for Mechanics and I&C Technicians to completely remove existing Teflon tape when joints containing it are disconnected during routine maintenance; (5) Unit I refueling plant mods in progress; and (6) NRC SALP results in the maintenance are The training attendance records for the fourth quarter 1988 Maintenance Real-Time Training reflect high participation by various maintenance personnel disciplines (i .e. , electrical, I&C, mechanical). In addition, the team noted that similar maintenance training was provided on INP0 SOER 87-2, Inadvertent Draining of Reactor Vessel to Suppression Pool in the Third Quarter 1987 Real-Time Training session. Based on the above described review and findings, the team concluded that Maintenance person-nel receive comprehensive and effective Real-Time Trainin _ _ _ - _ _ _ _ - _ _ - _ - _ _ - - - _ _ _ _ _ _ _ _ -
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ISSUE 10 MACHINE SHOP FACILITIES l
A. Observations The team was able ta observe general conditions and specific activities during this inspection for both the clean and " Hot" machine shops. The shops are well laid out with adequate space, equipment, and partitioning to accomplish a variety of tasks-associated with machining, cutting and welding, troubleshooting and assembly / disassembly bench work. The clean machine shop also has adequate space and bench cabinetry for tool storage by individual mechani The hot machine shop has less space.and equipment than the clean machine shop, but the space appears adequate to a variety of " Hot" machining tasks due to good organization of the space involved. The atmosphere of the " Hot" shop is controlled, and radiation monitors, decontamin'ation equipment and health physics support appeared adequat B. Conclusion:
After review of the above, the team consensus was: the " Hot" and clean machine shop facilities were a strength in the maintenance program.
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ISSUE NO. 11 CALIBRATION A request for calibration records for selected installed instruments and meters, and the licensee's subsequent answer, showed that not all of the plant's installed meters are included in a formal periodic calibration progra Several voltmeters DG-VM-6561-1, 2, 3, and 4) and ammeter (1-El-AFI-AM) in local panels and switchgear compartments were last calibrated in 1973. The licensee's representative stated that these meters were not Tech-Spec related nor do they provide a safety function. These meters do provide local backup indication and therefore, the accuracy need for these meters are greatly reduced. It is considered by the team that all plant installed instruments, gages, and meters should be covered by some formal periodic calibration progra !
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ISSUE NO. 12 OVERTIME WORK BY MAINTENANCE PERSONNEL The amount of overtime worked by various groups of maintenance personnel range from approximately 15'; during plant operation (non-outage) to 80?J during unit outage. -This observation was based on licensee trending of overtime hours for Units 1 and 2 Maintenance crews over the calendar year 1988. Per the review of selected February, August, November, and December 1988 time sheets of 1&C and electrical craft, some personnel worked up to 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> per week. Authori-zation was granted to those who worked beyond the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven-day limit. Overtime hours were also reviewed by the inspectors for Priority 1 WR/J0s done between January 1, 1988, through June 30, 1988, and for Unit 1 Limitorque operator auxiliary contact replacement work, plus on other miscellaneous WR/J0s addressed in Appendix 6 of this report. The results show that for Priority 1 WR/J0s on such systems as emergency diesel generators, 125 VDC distribution system, nuclear monitoring system, and electro-hydraulic controls the overtime work ranged from approximately 27?; to 67? Of the more than forty WR/J0s examined, the inspectors detected two instances where the individuals exceeded the administrative limit of working no more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight. They were on job tickets WR/JO 88-AAN01 performed on January 7, 1988, and WR/JO 88-ALYK1 performed on April 30, 1988. The two individuals worked 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> each for the given days. The maintenance workers adhere to the same limits as for reactor operators, as described in Operating Manual, Administrative Procedure, Volume I, Revision 3, Section The licensee also trends the established INP0/NUMARC performance indicator on overtime work by Maintenance personnel. For 1988, the goal of Sis reduction in overtime per year was not me Although overtime work by Maintenance personnel for 1988 appeared to be relatively high especially during unit outages and on Priority I work, the licensee maintained effective compliance with the procedure on overtime wor Considering the large staff involved and many WR/J0s, the licensee's control of Maintenance overtime per procedure was viewed as a strength.
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ISSUE NO. 13 MULTIPLE WEAKNESSES ILLUSTRATED BY REPAIR OF CRD DRIVE WATER CONTROL VALVE Multiple weaknesses illustrated by repair of CRD drive water control valv The team identified several weaknesses during this inspection which were considered to be illustrated by details associated with the repair of CRD drive water control valve FCV-C12-F002 Details are as follows: Specification Requirements MMM-003, Revision 0, Corrective Maintenance (Automated Maintenance Management System) Sections 3.6 and 3.7 requires,in part:
"3.6 Maintenance Foreman
... The Maintenance Foreman may, in the absence of the Planner Analyst, complete any planning action, except for Section B of the Postmaintenance Test Requirements (PMTR) ...
3.7 Planner Analyst The Planner Analyst shall plan the maintenance activity. This difficult activity includes evaluating the probable problem and the parts / material necessary to conduct the corrective maintenance, research the specifications, order the correct type and quantity of materials, determine the postmaintenance test requirements, and provide accurate instructions and time estimates to execute the maintenance activity." WR/JO History WR/JO 88-AIAF1 was issued on March 19, 1988, due to loss of automatic function (ability to manipulate from control room) of Unit 2 train A CRD drive water control valve FCV-C12-F002A. WR/JO 88-AIF1 was incorrectly placed on hold awaiting completion of WR/JO 85-AGNL2 which was initiated February 19, 1986, to correct leaking of welded-in pressure regulator 2-IA-DCV-287 This leaking-by resulted in an overpressure of approxi-mately 45 psig rather than the required 30 psig and had been identified during completion of WR/JO 85-AGNL1 (to check a noted overpressure on gage 2-C12-PI-R012 initiated January 1,1985). Clarification:
The team received no explanation of the cause of the delay of approxi-mately one year from initiation of 85-AGNL1 until final determination of the cause of overpressure and issue of 85-AGNL i
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Further, the team noted that valve FCV-C12-F002A had apparently operated sati sf actorily under the overpressure condition from January 1, 1985, until March 19, 1988. The team requested clarification of the root cause l analysis which required elimination of the overpressure (completion of
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WR/JO 85-AGNL2) before repair of FCV-Cli F002 Cognizant licensee personnel responded that incompletion of 85-AGNL2 was another example of problems associated with spare parts but that this should not have affected completion of WR/JO 88-AIAF The hold status of 88-AIAFI was due to inadequate root cause analysis and would be scheduled as soon as possibl D. Conclusio-The team considers the above example to illustrate several weaknesses as follows: Inadequate root cause analysis relative to FCV-C12-F002 i Unacceptable length of time from observation of overpressure until determination of its cause, Another example of delay in securing spare parts which impacts repair of Q-class equipmen potential inadequate attention to non-LCO loss of redundant equipmen i l
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l ISSUE NO. 14 BAGGING AND TAGGING Several examples of problems associated with bagging and tagging were noted by the team during this inspectio Details are as follows: Specification Requirements MMM-001, Revision 6, Maintenance; Conduct of Operations, Section 5.6, Material Handling During Fabrication and Repair, provides specific requirements for the control of loose parts during maintenance activitie Weaknesses Af ter a review of the procedura requirements, inspection of field condi-tions and interviews with various licensee personnel, the team identified several examples of inadequate bagging and tagging of loose part The team considered these examples to demonstrate a weakness in implemen-tation of bagging and tagging requirement Details are as follows:
Control room A/C fan and guard were removed and left on top of an adjacent fan (the number 2 fan for the standby "not operational" unit). The parts should have been bagged and tagged for proper identification. NOTE: The job was interrupted due to lack of parts (waiting on a new fan motor).
Damaged, missing and removed thermal insulation associated with the IA, 2A and 2B turbine building HVAC chillers. (The insulation had been removed for maintenance which was delayed for an extended period of time. The removed insulation sections were not tagged and were stacked on an ad.bcent duct section. (The insulation is to be replaced by plant seriice requests Nos. 87-0835 for IA, 88-0279 for 2A, and 87-1738 and 88-0835 for 2 Cover missing from conduit box at foot of stairs next to rack 16A fire extinguisher and 14 of 16 bolts missing from cover on conduit box X0 NOTE: These conduit boxes remained an incomplete state pending completion of revised WR/JO 86-ATE 21, e.g., pull new cable JU4-X0A/ The supplemental instructions regarding JU4-X0A/1 were issued September 30, 1987, but the work had not yet occurre Conclusion The team concluded that the above examples indicated a weakness in the implementation of bagging and tagging requirements.
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ISSUE NO. 15 INADEQUATE PROTECTION OF WELD PREPS AND FLANGE FACES During this inspective the team completed a general tour of warehouse facilitie Storage layout warehouse organization and efficiency appeared adequate. Only one condition adverse to quality was identified, inadequate protection of components in storage. The team noted a number of examples whers caps and covers were missing from openings in valves and fittings, thereby not affording protection to sensitive internal surfaces and finished machined weld-end preparations and flange face The team also noted several piping expansion units without protection afforded to the bellows sectio These conditions were noted in various locations throughout an otherwise well controlled warehouse facility. The team discussed the above with a licensee representative who instituted immediate action to correct the discrepant condition It was evident that the licensee's program - for storage protection was commendable with the exception of protection of sensitive machined surface Clearly, the licensee had not established adequate measures to control the storage of components with sensitive machined surfaces. This is a violation of 10 CFR 50, Appendix B, Criterion XIII, and will be identified as Violation 50-325, 324/89-01-02: Failure to Establish Adequate Measures to Control the Storage of Components With Sensitive Surfaces.
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l ISSUE NO. 16 REPETITIVE FAILURES
The team reviewed. the licensee's program for repetitive failure analysis as described in procedure 50P-02.40, Rev. 2, Repetitive Failures. This program had been implemented since about November 1987 where the mainte-nance planners are responsible in identifying repetitive failures by using the AMMS of historical search for the WR/JO that they are plannin If any failures that t W similar in nature which occured in the past, they are flagged by the kt"wced repetitive on the WR/J0. Further, on a monthly basis a report of ,'c ot fied repetitive failures is issued and presented to the PNSC. The uau reviewed these reports dated from 07/14/88 through 01/12/89. These reports contain a listing of component failures as well as parts. The data shows that some components had a fairly high number of failures. This included reactor vessel head vent valve failures, SLC accumulator leaks, and SW lube water regulator valve failure In general, based on the resolution status of the component repeat failures indicated by EWR, EER, and plant modification numbers it was indicative that the licensee was taking appropriate action to correct the problems. However, since corrective actions have not yet been completed on a number of component failures, the performance and results of this program remains to be determined.
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ISSUE NO. 17 MULTIPLE WEAKNESSES ILLUSTRATED BY CA-7 VALVE The team examined licensee activities in response to NRC Generic Letter 88-1 The purpose of GL 88-14 is the request that each licensee review NUREG 1275, Volume 2 (Operating Experience Feedback Report - Air System Problems) and then perform a design and operations verification of their Instrument Air System (IAS). Verification was to include:
Verification by test that actual instrument air quality is consistent with the manufacturer's recommendations for individual components serve Verification that maintenance practices, emergency procedures, and training are adequate to ensure that safety-related equipment will function as intended on loss of instrument ai Verification that the design of the entire instrument air system including air or other pneumatic accumulators is in accordance with its intended function, including verification by test that air-operated safety-related components will perform as expected in accordance with all design basis events, including a loss of the normal instrument air system. , This design verification should include an analysis of current air-operated component failure positions to verify that they are correct for assuring required safety function A final requirement was to provide a discussion of the licensee's program for maintaining proper instrument air qualit Background During a 1984 modification (84-304), IAS was improperly downgraded from a noninterruptable supply for two types of loads, containment isolation dampers and Containment Atmospheric Control (CAC) valve These valves do have associated accumulators and check valves, but leakage after loss of normal supply will cause their eventual failure. The containment isolation dampers were incorrectly assumed to fail closed (they fail as-is). The CAC valves must close within 15 seconds after receiving an initiation signal from high drywell pressure RV low wate- level Rx building air exhaust, high radiatio Modification design calculations assume the CAC valves will be closed with air assist from the accumulators within 90 setends of the initiating event. The limit of leakage allowed from the associated accumulator check valve is 27.2 SCF _ - - _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ .
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However, no provisions were made to include testing of the accumu-lator check valves until the licensee experienced an event associated with failure of the isolation dampers and until the licensee's activities in response to GL 88-14 dictated that CAC accumulator /
checks be tested to ensure operability on loss of normal air suppl The team was aware of separate enforcement activities associated with the containment isolation dampers and limited their review of these specifics. However, the team did review corrective maintenance (no apparent PMS were necessary) on the dampers and ensured that adequate portable air compressor capacity is available to supply ,
Unit 2 dampers on LOCA plus loss of offsite power (i.e., loss of I normal air from turbine building compressors and taking no credit for containment standby compressors which are not EQ qualified).
However, the team noted that the portable compressor must be manually started by operator dispatch and would not be available for CAC valve
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support on the first 90 seconds of a similar accident scenari B. Documentation Review The team held discussions with cognizant licensee personnel and reviewed Jocumentatio~ associated with GL-88-14 activities as follows:
PT-20.8, Revision 1, Nitrogen Back-up System Operability Test (once 1 every 18 months)
SP-88-064, Revision 2, Generic Letter 88-14 Testing (Unit 1) (CAC Spring Only LLRT and Accumulator Check Valve Leak Tests; includes slow bleed LLRT of some valves)
Draft Report, " Instrument Air System Evaluation for the Brunswick Steam Electric Plant" NPM 89-001, Revision 0, Instrument and Control Air System Generic NRC Letter C. Conclusions The team noted that the licensee had completed incisive and compre-hensive activities in response to GL 88-14. Conversely, testing should have been in place to verify design assumptions from the 1984 modifications above those included in PT-2 The team also noted that the special tests in response to GL 88-14 l
(SP-88-064 and SP-78-070) had only been completed for unit 1. Also that one valve (CAC-V7) had not met the limiting leakage requirements of 27.2 SCFH, i.e., had failed its design basis accident require-ment Further that equivalent testing for MSIVs had not been incorporated in the SPs.
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l Cognizant licensee personnel held follow on discussions with the team regarding the potential impact on Unit 2 of testing not yet completed (CACs and MSIVs). Cognizant personnel were unable to commit to a definite course of action regarding MSIVs during this inspection, i.e. , whether to supplement present.Section XI testing of MSIV check valves or add backup nitrogen suppl The team que.stioned as to whether a' failure anal.ysis had been completed for the CAC V7 check valve. Cognizant licensee personnel responded that the check valve was replaced but that no attempt to pinpoint the failure mechanism had occurre The team informed cognizant licensee personnel that NRC concern relative to completion of Unit 2 testing would be identified as inspector Followup Item 50-324/83-01-04, Completion of CAC and MSIV 3L 88-14 testing for Brunswick Unit !
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ISSUE NO. 18 HEALTH PHYSICS A. The team determined that the HP group was included in the planning and scheduling of maintenance activities through representation at all daily planning and briefing meeting Interviews with maintenance and HP personnel indicated that good lines of communication existed between the groups. Historical data of reasons for WR/JO interruptions showed that very few job hold-ups or interruptions were caused by lack of HP suppor The team reviewed procedures and guidelines delineating the- health physics group's responsibilities and required radiation protection activities related to the support of maintenance work in radiation area These documents described controls adequate to ensure that the level of HP involvement and support was commensurate with the degree of radiological hazards incident to the job being performed. The team also noted examples of non-HP guidelines / procedures which contained statements that emphasized or required certain HP practice General employee training (GET) lesson plans were. found to contain appropriate radiation protection topics to provide maintenance workers with the knowledge and understanding of radiation hazards and radiation protection principles needed for work in a radiation environment. Discus-sions with workers in the field verified the existence of a good general HP knowledge bas In addition to classroom training, maintenance personnel stated that mock-ups of plant equipment are sometimes used for jobs planned in high radiation areas in order to decrease stay times and lower the possibility of rewor Personnel contamination reports written during 1988 and reviewed by the team involved few maintenance personnel. The team reviewed the plant i Dose Status Report dated December 23, 1988. This report is updated weekly during outages and contains individual cumulative current quarter and year dose totals grouped by work crews. For the maintenance work i crews reviewed, no abnormally high doses were observe The team selectively reviewed minutes of monthly Management Radiation Exposure Reduction Meetings held during 1988 and verified that a mainte-nance representative was consistently in attendance. It was observed that weekly ALARA Reports were disseminated during daily morning management i meetings. The information contained in these reports and the method by which it was presented allowed managers to easily identify specific jobs which were exceeding their dose estimate and goa B. The team inquired as to the frequency of management presence in the fiel Licensee representatives stated that the plant manager required a minimum number of plant visits per week for specified maintenance supervisory personnel. A review of security door access data showed an adequate number of vital area tours and protected area entries. However, a review of radiation control area entries as recorded by RWP sign-in logs
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indicated inf requent visits by some management personnel. The RWP review covered only selected Unit 1 I&C/ electrical and mechanical maintenance supervisors and foremen - from November 1,1988, through January 11, 1989.
General plant manager, acting maintenance manager, and selected mainte-nance principal engineer RCA entries were also reviewed for the same time period. The results indicated that some foreman level personnel entered sreas. that required an RWP an average of once per five day Some maintenance principal engineering management personnel entered an area requiring RWP sign-in once every twenty days or less, on the average. The general plant manager logged onto an RWP 68 times over the 70-day period.
Considering the high collective exposures at this plant, the extent of supervision of personnel on jobs which are covered by an RWP may be inadequate and should be reviewed by the licensee.
The team's consensus was that health physic training and control is a strength with the exception of supervision of personnel covered by RWP l I
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ISSUE NO. 19 AUTOMATED MAINTENANCE MANAGEMENT SYSTEM (AMMS)
All plant maintenance is controlled through the AMMS. The work order control system is'a strength in the overall maintenance program. The AMMS, in conjunction with the trouble tag system, provides for identification of equipment / components needing attention. The planner controls the activities need to complete the work request af ter the trouble ticket has been issue The planner determines the procedures required, the appropriate discipline, _
any special processes required as well as assigning a priorit The AMMS provides for man-hour accountability, spare parts accounting and contro Work requests are prepared by planners who can review the history of a deficiency to determine if there is repeatability or other causes that create recurring problems with a component or group of component The AMMS maintains a maintenance history which is easy to recall. The history can be called up by component, part or system. Input to NPRDS is going to be included in the WR/JO syste All maintenance work requests, except emergency repairs, are processed through SWFCG and are scheduled by priority. The AMMS provides for review of work that is backlogged for one reason or anothe Based on the review / examination / observations by the inspection team, the team observed that the AMMS is an excellent system for establishing, controlling and maintaining records for maintenance activities. The system is user friendly.
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ISSUE NO. 20 FOREMAN DUTIES The consensus of the team is that the responsibilities of the foremen are of a magnitude that appears extreme. In reviewing the duties assigned to a foreman, it was found that various duties of the foremen are being delegated to crafts-men. There does not appear to be a clear cut definition of which duties may be delegate One factor does stand out which is that the WR/J0s assigned to each foreman are reviewed and the individual is held accountable for the status of the work. This appears to be one of the performance rating factor The foreman is also responsible for assigning qualified people to complete the WR/J This would also include knowing that the individual assigned is qualified to use the test equipment required for the maintenance activit In order to perform the activity, the foreman is responsible for obtaining an operational clearance and ensuring that a RWP exists for the area being entere It is fully recognized that certain of these duties can be and are being delegated to certain craftsmen. However, the delegation of duties should be
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ISSUE NO. 21 PRA ROLE IN THE MAINTENANCE PROCESS In reviewing the role of PRA (Probability Risk Assessment) in the maintenance i process, the team determined that it has received very limited applicatio This judgement was primarily based on interviews held with the licensee. The licensee's On-Site Nuclear Safety (ONS) group maintains responsibility of the PRA analysis and its use for the Brunswick (BSEP) facilit ONS interfaces with Technical Support (T/S) and Maintenance organizations as well as Opera-tions, and on special requests has supported T/S with BSEP PRA information for maintenance activities. Examples of this type of effort included planning and prioritization of work for the replacement of MCC silicone bronze bolts and replacement of auxiliary contacts on General Electric motor starters. The licensee has also stated that they are currently using PRA information in the development of acceptable Technical Specifications LC0 (Limiting Condition for Operation) times out of service for certain equipmen The BSEP PRA mainly deals with contributing factors (system availability /
reliability) to core damage frequency (CDF). A listing of improvement in CDF with 100 percent improvement of a given system was developed for BSEP applica-tion. The dominant system for improvement in CDF is the reactor protection syste Operator error is also included in the analysis. The BSEP PRA model was based on 1981-1985 plant configuration. To determine a change in CDF with respect to a change in system reliability based on such factors as major plant system modifications or significant component / system failures that may have or takes place after 1985, the licensee has stated that they would use a sensi-tivity analysis rather than revise the PRA model and apply it. Also, for common mode failures, the licensee tends to rely on use of consultants to review these types of failures using NPRDS and LER data taken from the nuclear i ndu st ry . Thus, ONS does not pick up real-time equipment failures such as EDG building fan failures for PRA impact analysis. Instead, they will make assump .
tions on redundant equipment failures for PRA analysi To date, the Maintenance Department does not use PRA-supplied information in their planning, scheduling, and prioritization of wor ONS presented a Reliability Centered Maintenance program to T/S and Maintenance organizations about one year ago. This program described the application of fault trees which helps to identify the most important components / systems for safety or CDF improvemen The program was not implemente l l
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SECTION D EXIT INTERVIEW l
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_ _ _ _ _ _ _ _ _ _ _ -
70 Exit Interview A preliminary exit critique was conducted on January 27, 1989. A formal exit interview was conducted at the Brunswick site on February 27, 1989, with those persons indicated in Appendix The team leader described the areas inspected and discussed in detail the inspection results listed below. Although reviewed during this inspection, proprietary information is not contained in this repor Dissenting comments were not received from the license Violation 50-325,324/89-01-01: Failure to Take Adequate and Timely Corrective Action - Section C, Issue Violation 50-325,324/89-01-02: Failure to Establish Adequate Measures to Control Storage of Components With Sensitive Surfaces -
Section C, Issue 1 Unresolved Item 50-325,324/89-01-03: 10 CFR 21 Evaluation of SLC Pump Spring Failures - Section C, Issue Inspector Followup Item 50-325.324/89-01-04: Completion of CAC and MSIV GL 88-14 Testing for Brunswick Unit 2 - Section C, Issue 1 i
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APPENDIX 1 i
PERS0NS C0NTACTED i
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_ _ - _ - _ _ _ _ _ - _ _ -
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APPENDIX 1 i
PERSONS CONTACTED
- K. B. Altman, Principal Engineer Maintenance N. Batton, Unit 1 Electrical Foreman
- M. Biggs, Systems Engineering Supervisor - BOP J. Blackburn, Project Specialist
- C. F. Blackmon, Jr. , Manager, Operations M. Blinson, ISI Senior Specialist S. Bostic, PT/ Lube Foreman
- S. Boyce, Technical Support T. Brennick, Unit 2 Senior Mechanical Specialist - SWFCG T. L. Brown, Supervisor, Onsite Nuclear Safety
- A. J. Canterbury, Maintenance Supervisor, Mechanical E. Cathey, Procurement Project Engineer
- R. D. Creech, Maintenance Supervisor, Instrumentation and Calibration (I&C)
- A. G. Cheatham, Manager, Environmental and Radiological Control (E&RC)
- J. Dorman, Quality Assurance (QA) Supervisor M. English, Outage Management Representative
- J. Haywood, Plant Services (Maintenance)
- J. L. Harness, General Manager
- W. R. Hatcher, Security Supervisor
- R. E. Helme, Manager, Technical Support
- L. E. Jones, Director, Quality Assurance / Quality Control (QA/QC)
- T. M. Jones, Specialist, Regulatory Comp 1iance
- R. H. Kitchen, Maintenance Supervisor, Mechanical
- C. W. Martin, Onsite Nuclear Safety (ONS)
J. A. McKee, QC Supervisor
- R. Murry, Licensing
- P. D. Musser, Maintenance F. Norris, Unit 2 Electrical Foreman D. Norton, Systems Engineer - HVAC
- D. E. Novotny, Regulatory Compliance
- R. M. Paulk, Project Specialist, Regulatory Compliance
- R. V. Pederson, Corporate QA E. Quidley, Project Specialist Supervisor
- C. Schacker, Maintenance Project Engineer M. Sckulic, Systems Engineer - IAS
- T. L. Simon, Operations
- S. Smith, Maintenance Planning S. Smith, Planner / Analyst Manager
- R. B. Starkey, Plant General Manager i
- - - _ _ - - - - _ _ _ _ . _ _ _ _ _ _ _ _ _ _
- -. . _ _ - _ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ . . __ ____ ___ ___ _ ._ _ - _ _ ._ ._ - _ _ _ _ - - _ - -
Appendix 1 2
- C. V. Wagoner, Director, Long Range Planning
- H. N. Wheeler, Maintenance Supervisor, I&C
- D. C. Whitehead, Principal QA Specialist, Performance Evaluation Other Organizations CRESAP - Auditing Contractor
- D. McCarthy
- G. Skala
- D. Snaider NRC Personnel W. Levis, Resident Inspector (RI)
P. M. Madden, RI
- W. H. Ruland, Senior RI
- J. J. Blake, Chief, Materials and Processes Section
- C. A. Julian, Chief, Engineering Branch
- A. F. Gibson, Director, Division of Reactor Safety
- H. C. Dance, Chief, Reactor Projects Section IA
- E. Tourigny, NRR, Licensing Project Manager
- Attended Preliminary Critique January 27, 1989
- Attended Exit Interview February 27, 1989
- Attended both the Preliminary Critique and the Exit Intervie !
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O APPENDIX 2 ACR0NYMS AND INITIALISMS l
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Alternating Current A/C ' , Air Conditioning ADM -
Administrative ADS - Automatic Depressurization System AE -
Architect Engineer Administrative Instruction
'
, AI -
ALARA As low as Reasonably Achievabl AM -
Amp Meter
- AMMS -
Automated Maintenance Management System AP -
Administrative Procedure approx - approximately f
ASME -
American Society'of Mechanical Engineers ATS - Authorization to Start ATWS - Anticipated Transient With Scram BLDG- - Building BNP -c Brunswick Nuclear Plant B0P -
Balance of Plant BRG -
Bearing BSEP - Brunswick Steam Electric Plant BSP -
Brunswick Site Procedure BWR, - Boiling Water Reactor CAC -
Containment Atmospheric Control CAD -
Containment Atmospheric Dilution CCW -
' Component Cooling Water CDFL - Core Damage Frequency CFR -
Code _ of Federal Regulations CHV - Check Valve CID - Component Identification Number CQA
-
Corporate Quality Assurance CR0 -
Control Rod Drive CS -- Core Spray DCV
-
Direct Current Volts DG - Diesel Generator DGB - Diesel Generator Building dpm- -
disintegrations per minute DPR' -
Demonstration Power Reactor DS -
Diesel Generator System E&RC -
Environmental and Radiation Control Procedure ECCS -
Emergency Core Cooling Systems
. EDBS -
Equipment Data Dase System
- EDG
-
Emergency Diesel' Generators EER -
Engineering Evaluation Report Emerg -
Emergency .
ENP -
Engineering Procedure EQ . -
Environmental Qualification ERB -
Engineering Review Board r&RC - Environmental and Radiological-Control ESF -
Engineered Safety Feature ETA -
Estimated Time of Arrival EWR -
Engineering Work Request
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..L Appendix 2 2
' FACTS -
Facility Automated Computer Tracking System FCV -
Flow Control Valve .
FSAR -
Final Safety. Analysis Report G '
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General Electric
'
GET- -
General Employee Training gallons per minute
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gpm- -
GL -
Generic Letter l HiPOT -
High Potential
- . HP Health Physics
'HPCI -
High Pressure Coolant Injection HVAC -
Heating Ventilating and Air Conditioning IA- -
Instrument. Air IAS -
' Instrument' Air System
'
ID -
Identification IEN -
Inspection and Enforcement Notice INP0 -
Institute for Nuclear Power Operations I&C Instrumentation and Calibration ISI -
Inservice Inspection IST . Inservice Testing KV - Kilovolts LCO -
Limited Condition of Operation LER -
Licensee Event Report LLRT -
Local Leak Rate Test LOCA -
Loss of Coolant Accident LPCI - Low Pressure Coolant Injection LUB -
Lubrication MCC -
Motor Control Center Mech -
Mechanical Micro gm/gm . -
Microgram / gram MMM -
Maintenance Management Manual MMRS -
Material Management Reporting System MOV -
Motor-0perated Valve MP -
Maintenance Procedure MPN -
Maintenance Policy Notice MSIV- -
Main Steam Isolation Valve MSL -
Metallurgy Unit Memo N2- -
Nitrogen NCR -
Nonconformance Report NDE -
Nondestructive Testing NMS - . Neutron Monitoring System NNS -
Non-Nuclear Safety-Related NPRDS - Nuclear Plant Reliability Data System NRC -
Nuclear Regulatory Commission NRR -
Nuclear Reactor Regulation NUMARC - Nuclear Management and Resources Council NUREG -
Nuclear Regulatory Publication OER -
Operating Experience Report OI -
0perating Instructions-ONS -
Onsite Nuclear Safety OP Operations OQA
-
Operations QA/QC Procedures
_ _ _ _ - . ._ _ _ - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ .-
_ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____
Appendix 2 3 P
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Pressure PDT -
Pressure Differential Transmitter PE -
Professional Engineer PI -
Pressure Indicator P&ID -
Piping and Instrumentation Drawing PLP -
Plant Program Procedure PM -
Preventative Maintenance PMC - Procurement and Material Control PMI -
Preventative Maintenance Instruction PMT -
Post-Maintenance Testing PMTR -
Post-Maintenance Testing Report PN -
Plant Notice PNSC -
Plant Nuclear Safety Committee PPP - Plant Performance Procedure PRA -
Probabilistic Risk Assessment PRC -
Potential Reportable Condition PS -
Pressure Switch psig -
pounds per square inch gage PT - Performance Test PV -
Pressure Valve QA
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Quality Assurance QAA
-
Quality Assurance Audit QC
-
Quality Control QI -
Quality Instruction QIP -
Quality Improvement Program RB - Reactor Building RC -
Reactor Coolant RCI - Regulator Compliance Instruction REM -
Roentgen Equivalent Man Rev -
Revision RHR - Residual Heat Cemoval System RMP -
Records Management Procedures PTD -
Resistance Temperature Detection RV -
Reactor Vessel R/V -
Relief Valves RWCU - Reactor Water Cleanup RWP - Radiological Work Permit Rx -
Reactor SALP -
Systematic Appraisal of Licensee Performance SBGT -
Standby Gas Treatment SCFH - Standard Cubic Feet per Hour SER -
Safety Analysis Report SF/ SOS - Shift Foreaan/ Supervisor on Shift SGT -
Standby Gas Treatment SI - Safety Injection SIL - Service Information Letter SIS -
Stock Inventory System '
SK -
Storekeeping Instruction SLC - Standby Liquid Control SOER -
INPD Significant Operating Experience Report 50P -
Standard Operating Procedure
. _ _ _ _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - - - _ _ _ _ - _ _ _ _ _ - - - _ _ _ _ _ -
_ - _ _ - -
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Appendix ^ 4 SP . - Special Procedure SPP - Special Process Procedure SW -
Service Water SWFCG -
Site Work Force Control Guidelines Sys -
System TB -
Turbine Building l
Tech -
Technical TI
'
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Training Instruction TI -
Temporary Instruction TIP -
Travelling Incore Probe TMTC - Too Much to Count TS - Technical Specification T/S - Technical Support TVA - Tennessee Valley Authority ugm/gm - microgram per gram UV -
Under Voltage V -
Volts VDC - Volts Direct Current VM -
Under Voltage Vol -
Volume WLD -
Weld WR/JO - Work Request / Job Order XI -
Eleven
)
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l APPENDIX 3 PR0CEDURES REVIEWED
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!
APPENDIX 3
PROCEDURES REVIEWED Procedure N Title AI-53, Rev. O ALARA Project Evaluation'
AI-58, Rev. 25 Equipment Clearance Procedure AI-66, Rev. 2 Instructions for Safe Work Within Confined Spaces-AI-72,-Rev. 4 Control / Qualification of Vendor Technical Manuals-AI-79,'Rev. 2 The Administration of the Automated Maintenance Management System (AMMS)
Maintenance Management Manual (MMM)
-0-MMM-001, Rev. 5 Maintenance; Conduct of Operations 0-MMM-003, Rev. O Corrective Maintenance (Automated Maintenance Management System)
0-MMM-004, Rev. O Preventive Maintenance 0-MMM-012, Rev. 0- Maintenance Unit Training Program Maintenance Procedure (MP)
MP-01A, Rev. 7 Control of Measuring Devices for Mechanical Maintenance MP-01B, Rev. 8 Control of Measuring Devices and Test Equipment for I&C/ Electrical MP-12, Rev. 12 General Cleanliness Procedure MP-32, Rev. O Guidance for Equipment Torquing MP-36, Rev. 8 Packing MP-41, Rev. 1 Mechanical Maintenance Special Tool Control MP-50, Rev. O Guidance for Troubleshooting of Safety-Related Equipment
'MP-51, Rev. 4 Environmental Qualification Maintenance Program MP-52, Rev. 3 Standards for Preparing and Maintaining Maintenance I Procedures MP-57, Rev. 3 Limitorque Valve Actuator Failure Analysis and Troubleshooting Procedure MP-60, Rev. 1 Valve Failure Analysis Guide
_ _ _ _ . - -- - _ _ _ _ _ - _ - - - - _ _ _ _ _ _ _ - - - - _ _ _ - _ _ _ _ _ _ _ _ - _ _ -
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Appendix 3 2 1
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Plant Notice (PN) .
'
PN-24, Rev. 8 Safety Rules
PN-28, Rev. 0 Use of Ladders and Scaffolds
,
Engineering Procedure (ENP)
ENP-03.1, Rev. 8 Direct Replacement Procedure i ENP-03.2, Rev. 0 Equipment Decommission Procedure ENP-12, Rev. 21 Engineering Evaluation Procedure ENP-16, Rev. 26 Procedure for Administrative Control of Inservice Inspection Activities
>
EMP-17, Rev. 6 Pump and Valve Inservice Testing (IST) )
ENP-20, Rev. 9 Engineering Work Request (EWR) I
)
u ENP-22, Rev. 5 Equipment Failure Trending and Analysis
.
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'ENP-25, Rev. 5 Plant Drawing Correction Procedure ENP-33.2, Rev. 1 Development of Equipment Data Base System (E0BS) Tag i Numbers (TAG #s) and Component Identification Numbers ;
!
(CID #s) for the EDBS ENP-42.2, Rev. 2 Purchase Requisition and Data Base Review Procedure ENP-42.3, Rev. 2 Material Engineering Evaluation Procedure I ENP-45, Rev. O System Engineer Walkdown Procedure ENP-606, Rev. O System Engineer Training Plant Program Procedure (PLP)
PLP-02, Rev. 3 Program Document for Compliance With 10 CFR 50.49 (Environmental Qualification of Safety-Related ;
Electrical Equipment) .)
i PLP-04, Rev. O Corrective Ao ic- Program Brunswick Site Procedure (BSP)
BSP , Rev. 2 Brunswick Nuclear Project Radiation Exposure Budgeting I
_ _ - - _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ - _ _ - - - _ _ - _ _ _ _ _ _ _ - - _ - - _ _ _ _ - _ - -
_ _ _ _ - _ _ _ _ _ - - _ _ _ _ _ - _ - .
.;
Appendix-3 3
. BSP, Vol. 1, Administration Procedure 4.4 on Overtime Schedulin Book 1
. BSP-31, Rev. 0 Root Cause Analysis Policy
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Special Process Procedure (SPP)
0-SPP-WLD-500, Re .' -Qualification of Welders'and: Weld Procedure p Specifications t 0-SPP-WLD-600, Rev. 1 General Welding Procedure General Welding Procedure - Structural Steel
~
L 0-SPP-WLD-601, Rev. O Operating Instruction (01)
- 01-39, Rev. 10 -Handling of Work Request / Job Orders Environmental & Radiation Control' Procedure (E&RC)
E&RC-230, Rev. 16 Issue and Use of Radiation Work Permit E&RC-4100, Rev. 4 ALARA Program E&RC-4100.4, Rev. 3 ALARA Problem Reports Procurement and Materials Control (PMC)
PMC-01, Rev. 17 Material Requisition and Reorder Procedures and Responsibilities PMC-13,.Rev. 5 Data Base Update Procedures and Responsibilities PMC-03, Rev. 13 Storage PMC-12, Rev. 1 Training Storekeeping Instruction (SK)
SK-02, Rev. 13 Receiving SK-04, Rev. 17 Issuing of Materials and Tools SK-05, Rev. O Packaging of Q-List Items SK-06, Rev. I llandling SK-07, Rev. 3 Loading and Shipping SK-08, Rev. 3 Housekeeping and Access Control Procedures and Responsibilities
,
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__ .___-_ _ - . _ _ _ _ - _ - _ 'i r Appendixf3 4
'SK-09, Rev-. 2- Renting, Borrowing, and Loaning Equipment- and Materials SK-10,-Rev. 1 Meterials Control Complaint System SK-11, Rev.'2 Cycle Inventory SK-14, Rev. O Awoiting Parts Program Maintenance Policy Notice (MPN)
.86-018, Rev. 3 Control and Use of the Procedure Revision Status Log 1 6 88-007, Rev. O Maintenance Planner / Analyst Backlog Control and WR/JO Processing 89-001,~Rev. 0 Instrument and Control Air (Re Blowdown Requirements)
Standard Operating Practices (SOP)
SOP-02.11, Rev. 0 . Supervisor, Foremen, Specialist and Engineer Turnover Checklist SOP-02.12, Rev. 1 Control of Maintenance During Plant Operations
- SOP-02.19, Rev. O Maintenance Subunit Internal Audit Program SOP-02.21, Rev. 6 Maintenance Experience Report (MER)
SOP-02.28, Rev. 3 Maintenance Engineering Documentation SOP-02.29, Rev. 2 Forced Outage Maintenance Lessons
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SOP-02.39,-Rev. O Maintenance Documentation of ECCS Out-of-Service Time SOP-02.40, Rev. 2 Repetitive Failure SOP-02.43, Rev. 0 Identification of Interrupted Maintenance Activities 50P-03.8, Rev. O Maintenance Work Force Audits SOP-03.17, Rev. 1 Maintenance EQ/75-01B Audits
'
50P-03.18, Rev. O Trending Program for Large Pump Motors Operations QA/QC Procedures-(00A)
OQA-104, Rev. 3 Nonconformance Control 0QA-303, Rev. 1 Control of Special Processes
- 4
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Appendix 3 5 Corporate QA (CQA)
Administrative Procedure (AP)
AP-Vol 1, Rev. 117 Operating Manual for Procedure Review Records Management Procedure (RMP)
Site Work Force Control (SWFCG) Guidelines Guideline 3, Rev. 2 Scheduling of Work Guideline 4, Rev. O Preapproving WR/J0s/ Plant Modifications Guidelir.e 5, Rev. 1 Controlling Radiation Exposure and ALARA Documentation AMMS Users Manual, Rev. 2 Regulatory Compliance Instruction (RCI)
RCI-03.1, Rev. 5 10 CFR 50.59 Safety Evaluations RCI-05.1, Rev. 2 Regulatory Compliance Commitment Tracking RCI-05.2, Rev. 5 Regulatory Compliance Action Item Assignment and Response RCI-06.4, Rev. 4 10 CFR 21, Evaluation / Notification Training Instruction (TI)
TI-113, Rev. 7 Related Technical Training and On-The-Job Training for Selected Maintenance Classifications TI-606 System Engineer Training (ENG-606, Rev. 0)
Plant Performance Procedure (PPP)
P.oP-2, Vol. V, Re Vendor Recommendation Processing Onsite Nuclear Safety Instruction ONSI-1, Rev. 3 Operating Experience Feedback EngineeringWorkRequestsyWRs]
EWR 05183 Schedule and Implement Maintenance Inspection of RHR and CS Motors for Cracks in Felt End-Turn Blocking and End-Turn Support Brackets
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I
- Appendix 3- 6
' EWR 05810' Request. 'for Replacement' of' CAC (Containment Atmosphere ' Control) ~ TR-4426-1, 2 Recorders Used for -
Suppression Pool . Temperature Monitoring EWR 05749 Request for an EER and Scale Replacement for CAD (Tank Level Indication
- EWR'6771 Request for Resolution of Problem Regarding SLC Pump '
'
Accumulator Leaks EWR 06113 Request for. Specification Waiver ' to Reuse Conduit Supports for Replacement of Corroded Conduit in north core spray room ;
EWR'06106A Evaluate 10 CFR 21 Concern of Proper Material . in SLC Relief Valve Plugs Miscellaneous Reports / Procedures I- NCR 5-88-042 Service Water Check Valve 2-SW-V202 Returned to
'
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Service Without Proper Post-Maintenance Testing INP0 SOER 83-9 Valve.Inoperability Caused by Motor-Operator Failures INPO SOER 87-2 Inadvertent Drawing of Reactor Vessel to Suppression Pool at BWRs Lesson Plan for Real Time Training - Fourth Quarter 1988 OCM-VSR500, Rev.~2 Repair and Installation of Lonergan Relief Valves (Series D and DB)
OPM-LUB500, Rev. 4 Plant Equipment Lubrication Schedule
Performance Tests (PT)
PT-06.1, Rev. 32 Standby Liquid Control System (SLC) Operability Test PT-06.'2.1, Rev. 12 SLC Relief Valve Test PT-24.1-2, Rev. 4 Service Water Pu:rp and Discharge Valve Operability Test
,A/QC Q Trend Reports Brunswick Nuclear Plant (BNP) PNSC, April 1988, Iricluding 1987 Historical and 1988 First Quarter Reports
_
BNP PNSC Report for Second Quarter 1988 l
- _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ - _
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T Appendix 3 7-L:
ic BNP..QA/QC PNSC Quarterly Report, Third Quarter .1988 BNP Monthly PNSC' Report, December 1988
__
BNP Monthly PNSC Supplement Report, December.1988 BNP Q-1/1 BNP Second Quarter.Nonconformance Trend Report System Description (SD)
, .SD-05, Rev. 6 System Description: SD-05, Standby ' Liquid' Contro ".
" System,. Volume II QA'Au'dit Report
'QAA/0021-88-04 CP&L Audit Report- on . Brunswick Nuclear ~' Project conducted on October 3-14, 1988
,
BSEP Final Safety Analysis Report (FSAR)
FSAR, Amendment 6 Updated FSAR, Section 9.3.4, Standby Liquid Control System BSEP TS,-Amendment Brunswick Technical Specifications-
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APPENDIX 4 08SERVATION 0F WORK i
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APPENDIX 4 OBSERVATION OF WORK WR/JO N Work Activity I
88-AZDR1 Repair of 2B Demineralized Water Transfer Pump (NNS)
88-AZRJ1 Shop Welding of Spool Pieces for RWCU Zone (2-G31-NC11-Li ne)
Maintenance Surveillance Test - Low Steam Line Pres-sure Trip Unit Calibration 88-KEG 171 PM on 4160V Breaker 10-AD5 (Breaker for bus ID, incoming power from SAT) in accordance with procedure OPM-BKR001, "ITE 4KV Breaker and Compartment Checkout"
.
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APPENDIX 5 C0MP0NENTS EXAMINED
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APPENDIX 5 COMPONENTS EXAMINED The following'spbcific. areas and components were subject to inspection during plant tours and walkdown inspection:
-
DG Nos. 1, 2, 3 and 4 Areas including the following:
Air Start Compress on Motors Pre-Lube oil. Pumps Lube oil Strainers Generator Control Panels Engine Control Panels MCC Solenoid Valves Pressure Switches
-
Approximately 30% of all control room control cabinets in Unit 1
-
Cable Spreading Rooms
-
Unit 1 Battery Rooms
-
Service Air Compress, Standby Air Compress and Instrument Air Drier in -
Turbine Building No. 1
- 4160 V Distribution System Switchgear El, 2, 3, 4, 18, C, D, 2B, C, D, Common A and Common B Cubicles _ in Switchgear IB and D - 1-AB4, 1-AB2, 1-AA9, 1-AE2, 1-AD9, 1-AD5, 1-AD4, 1-AD3, and 1-AD2
-
SLC System With the assistance from licensee personnel, the team performed a walkdown of accessible portions of the Units 1 and 2 Standby Liquid Control Systems. The tean verified that equipment conditions were satisfactory-by observing the. following: hangers and supports are made up properly; the SLC heat trace system is operable and temperatures are being recorded; valves, pumps, tanks, piping, and N2 accumulators do not exhibit leakage; system components are properly labeled and match FSAR Figure 9.3.4-1; and that housekeeping with appropriate level of cleanliness was maintaine No discrepancies were identified; the equipment area for both units was very clea HPCI System partiai walkdowns were also performed- on Units 1 and 2 HPCI systems, hydraulic control unit control rod drive assemblies, emergency diesel generator ventilation systems, and 125 VDC safety-related batteries. No violations were identifie !
.
i m_._._____-__ _ _ ._ ..______________.m__-_um_._-________-___-_u___ ____.:__m_-_m._1_..____.m-._m ___m_-___m_-____ _ _ - -___m______- m
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Appendix 5 2 L
-
Skid-Mounted HVAC Equipment The team performed a walkdown of the Unit 2 control room essential control air compressors. Components were evaluated in detail. Discrepancies included configuration errors, i .e. , omission of traps - downstream of PSL 1646, mis-location of PI 1635 (upstream rather than downstream of PV 1636), and omission of pressure' gages upstream of RV-13 and RV-1 A partial list of equipment inspected is as follows:
Valves Filters Gages RV-12 A-9 PI 1634
, RV-13 A-10 PI upstream of RV-12
PI upstream of RV-13 2-VA-V2 2-VA-V1 PV 1636 PV 1637 RV-14'
-
HVAC Systems The team performed a walkdown inspection of the HVAC systems. The below listed components were examined in detail'to evaluate equipment condition and status of maintenance activities:
TAG NUMBER COMPONENT 2A-RM-TB 2A Turbine Building Chiller 2B-RM-TB 2B Turbine Builbing Chiller 1A-RM-TB- 1A Turbine Building Chiller 2A-CP-TB/2ECW-VI, V34, V17 2A Chill Water Pump and Isolation Valves 2B-CP-TB/2ECW-V2, V35, V18 2B Chill Water Pump and Isolation Valves 2C-CP-TB/2ECW-V3, V36, V19 2C Chill Water Pump and Isolation Valves 2C-CP-TB/2ECW-V4, V37, V20 2D Chill Water Pump and Isolation Valves 2-VA-2A-SF-TB 2A Turbine Building Supply Fan 2-VA-2B-SF-TB 2B Turbine Building Supply Fan 2-VA-2C-SF-TB 2C Turbine Building Supply Fan ,
2-VA-2D-SF-TB 2D Turbine Building Supply Fan
~
- . Control Building Ventilation Room Control Building Air Conditioning Unit 2A-SF-RB Reactor Building Supply Fan 2A 28-SF-RB Reactor Building Supply Fan 2B 2C-SF-RB' Reactor Building Supply Fan 2C 2D-S F-RB Reactor Building Supply Fan 2D
-_ _ _ - _ - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ - _
_ - . _ - _ __ . _
Appendix 5 3 2E-D-RB Reactor Building Exhaust Fan 2A i
Discharge Damper l: 2F-D-RB Reactor Building Exhaust Fan 2B
'
Discharge Damper Reactor. Building Exhaust Fan 2C
.
,
2G-D-RB L
Discharge Damper-l 2H-D-RB Reactor Building Exhaust Fan 2D Discharge Damper 2C-BFDV-RB Reactor Building Exhaust . Inboard Isolation Damper 2D-BFIV-RB Reactor Building Exhaust Outboard Isolation Damper Standby Gas Treatment (SBGT)
2C-BFV-RB 2A SBGT Supply Damper 2A-SBGT-EF-RB 2A SBGT Fan 2A-BFCV-RB 2A SBGT Discharge Damper 2G-BFV-RB 28 SBGT Supply Damper 28-SBGT-EF-RB 2B SBGT Fan 2B SBGT Discharge Damper
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28-BFCV-RB 2-VA-2A-PS-EF-RB 2A Drywell Purge Fan 2-VA-28-PS-EF-RB 28 Drywell Purge Fan 1A-SF-RB Reactor Building Supply Fan 1A 18-SF-RB Reactor Building Supply Fan IB IC-S F-RB Reactor Building Supply Fan 1C 10-SF-RB Reactor Building Supply Fan ID IE-D-RB 1A Reactor Building Exhaust Fan Discharge Damper IF-D-RB IB Reactor Building Exhaust Fan Discharge Damper IG-D-RB .1C Reactor Building Exhaust Fan Discharge Damper 1H-D-RB ID Reactor Building Exhaust Fan Discharge Damper IC-BFV-RB 1A SBGT Supply Damper IA-SBGT-EF-RB 1A SBGT Fan
'1A-BFCV-RB 1A SBGT Discharge Damper 1G-BFV-RB 18 SBGT Supply Damper 18-SBGT-EF-RB IB SBGT Fan IB-BFCV-RB 18 SBGT Discharge Damper 1-VA-1A-PS-EF-RB 1A Drywell Purge Fan 1-VA-18-PF-EF-kB 18 Drywell Purge Fan Instrumentation and controls for the self-cleaning strainers as each service water pump discharg Nuclear service water pumps 2A and 2B
' Conventional service water pumps 2A, 2B and 2C RHR pumps 2A, 28 and 2C 2C12 PDT N008-TR-778 (Remote Shutdown Panel's
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APPENDIX 6 WORK REQUESTS / JOB 0RDERS REVIEWED (WRS/J0S)
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APPENDIX 6
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WORK REQUESTS / JOB ORDERS REVIEWED (WRS/JDS)
WR/JO WORK DESCRIPTION 89-ABDA1 SLC Pump IB Discharge Check Valve Leaking by During PT 89-AFBD1 Loss of Green Light indication on panel 2DGB-PY4 of EDG No. 2 89-ABKX1 Repair of panel 2-XV-42 ASCR-X relay controls 1, 2, 3, and 4 for EDG No. 4 auto mode switch auxiliary relay 89-AALE1 Damper 2-VA-29-BF1V-RB, Air locks on damper 89-AAFH1 Damper 2-VA-2B-BF1V-RB, Assist Engineering on pressure drop test of accumulator 89-AALC1 Damper 2-VA-2A-BF1V-RB found bad check valve while repairing air leaks 89-AAFG1 Damper 2-VA-2A-BF1U-RB Assist Engineering in performing pressure drop test on accumulator 89-AAFIl Damper 2-VA-2C-BFW-RB Assist Engineering in performing pressure drop test on accumulator 89-AAMB1 Damper 2-VA-2D-BFIV-RB-A0 Repair air operator leaking past the piston 89-AAMB2 Damper 2-VA-20-BF1V-RB-A0 Repair air operator leaking past the piston 89-AAFN1 Damper 2-VA-2D-BFW-RB Assist Engineering in performing pressure drop test on accumulator 89-AASU1 RHR 2C suppression pool suction valve unistrut 89-AANN1 LT N008A RHR HX2ALVL XMTR not mounted 89-ABMV1 4KV Distribution system over/under voltage relay 89-ABDG1 4KV Distribution system breaker position decal 88-AELS1 RHR motor 2C wetting by Ar,t T1 4KV Distributdan system - Insulation damage on control wire in parel 88-ALRC1 4KV Distribution system - Shutter in compartment damaged 88-AEBM1 4KV Distribution system - Position indication lights 83-ACXC1 4KV Distribution system - Breaker operation
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Appendix 6 2 88-ANSIl 4KV Distribution system - Teleductor 88-AXWK1-- 4KV Distribution system - Elapsed time meter 88-ALQY1 4KV Distribution system - Ground fault meter
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88-AYLH1 4KV Distribution system - Charging motor brushes 88-AGMM1 4KV distribution system - Breaker labeling 88-AGMN1 4KV distribution system - Breaker labeling 88-AKKW1- F060A LPCI manual in valve galled stem 88-AILR1 RHR 2C suction relief valve leak L 88-AJKF1- Drywell spray valve F016A contacts 88-AJKF2 Drywell spray valve F016A contacts l 88-AJEE1 RHR SW BSTR pump 2D high Delta P 88-AJMJ1 RHR 2C high Delta P 88-AJKF1 F016A valve would not close i
88-AIZS1 F003A valve will not close 88-AIWG1 RHR pump 2C discharge check valve leakage 88-AKKwl LPCI injection valve galled stem 88-AUDQ2 RHR RX 2A LVL controller leaking by seat 88-AIWA1 Suppression pool spray isolation packing leak 88-AIUS2 Drywell spray inboard isolation packing leak 88-ATCG1 SIL 360 loose contact blocks 88-ATCHI SIL 360 loose contact blocks 88-AQPHI FT-N0158 square root converter calibration I
88-AQCTI LPCI valve damaged gears 4
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8bAQCT2 LPCI valve damaged gears 88-ATCGI RHR valve F016A loose contact blocks ,
l 88-ARQH1 HPCI 2 moisture in oil
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Appendix'6 3
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88-AULU1 HPCI 2 moisture in oil
'88-BEJAl' HPCI 2 moisture in oil-88-BFXG1 HPCI 2 moisture in oil
'88-AFMW1 SLC pump 28 discharge relief valve leaks 88-BCZA1 ~ Unit 2 SLC pump discharge pressure indicator pegged low'
88-AKIQ1 1A control rod d, . pump relief valve leaking at 1/2 gpm; repetitive' failure 88-AHAX1 SW pump C discharge check valve CHV-SW-V23 leaks 88-AXWM1 SW pump C discharge check valve CHV-SW-V23 leaks 88-AXWM2 SW-pump C discharge check valve CHV-SW-V23' leaks 88-BAZA1 SW pump C discharge check valve leaks 88-ACAR1 SLC pump 2A N2 accumulator stem broke off 88-AJQH2 SLC pump 2A N2 accumulator stem broke off 88-ANMX1 SLC pump 2A N2 accumulator stem broke off 88-ATMA 1 SLC pump 2A N2 accumulator stem broke off 88-BBCC1 Service water pump 2C motor cooling water inlet pressure regulator malfunctions SLC pump 28 discharge relief valve did not lift
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88-APAC1 88-AEDF1 SLC pump 1A discharge relief valve replacement; material compatibility concerns 88-AWZW1 Limitorque operator auxiliary contact replacement 88-AANC1 Priority 1 work on EDGs 88-AAIW1 Priority I work on EDGr
.88-ADNS1 Priority I work on 12S VDC distribution system j 88-AMLC1 Priority I work on EHC - turbine controls L
88-ALYK1 Priority I work on neutron monitoring system 88-ABMM1 Priority 1 work on heat tracing and freeze protection
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Appendix 6 4 88-BGJC1 Unit 2 NMS TIP inoperable 88-BGFX1 Unit 2 reactor building HVAC air flow compensator repair 88-APXA1 Regarding.PI-2C12-R012 failed upscale
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88-AIAF1' Repair loss of automatic function on CRD drive water control valve 2-C12-F002A 88-BEAR 1 ~ Repair of valve 2-B32-FC-3626
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88-BEATI Repair of valve 2-832-FC-3627 88-BHDS1 Damper 2-VA-2A-BFIV-RB fabricate mechanism to . operate since handwheel is removed and cannot be replaced due to interference with flex conduit (4 required)
88-BFLD1 Low oil : level on 2A SLC pump outboard bearing while pump is running 88-BHEP1 Defective. thermocouple in Unit 1 SLC heat tracing system 88-ABLP1 SLC heat tract temperature indicator points 14, 15, 18 not working; replace defective cable 88-BHEP1 SLC heat trace point 11 reads low 88-SNH472 Scram discharge diaphragm replacement; PM 88-BBCH1 SLC pump 2A N2 accumulator leak 88-BBCII SLC pump 2B-N2 accumulator leak 88-AJQH1 SLC pump 2A N2 accumulator stem broke off 88-BFPW1 Unit 2 control room area door repair 88-AXXP1 Unit 1 APRM channel A neutron detector repair 88-BEWL1 Unit 2 area radiation monitor has gone downscale 88-AWRW1 Automatic depressurization system (ADS) sonic detector rework
)_ 88-ADBIl Unit 2 outboard reactor head vent valve F004 won't stroke; stem bushing bima-N 0-ring melted 88eAIGp1 Unit 2 cetboard reactor head vent valve F004 leaking by badly 88-AKQP1 Local flow indication for IBSSGT failed downscale 88-BGJE1 Damper 1-VA-1A-BF1V-RB tubing leaks
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. Appendix 6 5 88-BGGL1 Damper 1-VA-1B-BFIV-RB air supply tubing leaks
'88-BHCT1 Damper 2-VA-2B-BFW-RB air leaks in tubing and accumulator tank 88-BGJG1 Damper 1-VA-1D-BF1V-RB tubing leaks 88-BHCS1 Damper 2-VA-2A-BF1V-RB repair tubing leaks 88-BHCS2 Damper 2-VA-2A-BF1V-RB repair tubing leaks 88-BEAQ1 Repair of valve 2-B32-144 88-BCJL1 Replace EDG No. 3 starting air filter (FLT-DSA-DG3-FLT-DRY)
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88-AKIQ1 Repair of . leaking CRD relief valve 1-C11-F001A
~88-ARYBI Repair of leaking CRD valve 2-C12-F034 88-AZRJ1 Shop fabrication of RWCU spool pieces 88-AZDR1 Repair of demineralized water transfer pump 2B 88-BABL2 4KV distribution system charging spring brush cap
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88-BHAG1 4KV distribution system ground fault relay 88-BBKL1 4KV distribution system spare conductor 88-BDYC1 4KV distribution system puffer piston broken 88-BHCU1 Damper 2-VA-2C-BF1V-RB repair tubing leaks 88-BHCW1 Damper 2-VA-2D-BF1V-RB repair air leaks 88-PNG061 4KV distribution system UV relay 88-MMM061 4KV distribution system loss of excitation relay 88-MMM351 4KV distribution system loss of excitation relay 88-0TT061 4KV distribution UV relay 88-0TT351 4KV distribution system UV relay l 87-AAZR1 RHR 28 oil sample failed particle test 87-AFSF1 RHR 2B motor damaged ventilation screening 87-AJYE1 HPCI 2 moisture in oil 87-AWJW1 HPCI 2 oil gauge problems
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Appendix'6 6
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87-AJTZ1 4KV distribution system ground protective relay 87-ALXK1 RHR 2B oil sample 87-BAAQ1 4KV distribution system - breaker indicator
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87-BLTA1 4KV distribution system - auxiliary relay 87-BBQA1 4KV distribution system - wattmeter 87-BGAJ1' 4KV distribution system - relays 87.-BFDPI 4KV distribution system - elapsed time meter
- 87-BKXAl- 4KV distribution system - elapsed time meter l'
87-BFGS1 RHR 2A motor surge ring brackets 87-BFGS2 RHR 2A motor surge ring brackets 87-BFGT1 RHR 2C motor surge ring brackets 87-BFGT2 RHR 2C motor surge ring brackets 87-BJJQ1 RHR 2C motor repair oil leak 87-BJKN1 RHR 2D motor surge ring brackets 87-BBHU1 RHR 2D motor surge ring brackets 87-BARIl RHR 2B motor lower BRG oil leak 87-BGMSI RV-V54 dirty radwaste line relief valve 87-BHZG1 RHR loop B charging water fill calibration 87-BHZG1 RHR PI-2676 found pegged high 87-BJHZ1 RHR motor 2C oil leak 87-BKAW1 RHR motor 60 spring pack preload 87-BKAW2- RHR motor 60 spring pack preload 87-BMQUI RHR cunip 2D seal cooler corrosion 87-BBIA1 Inspect IA RhR pump motor surge ring brackets per OPM-M502 87-BBIB1 Inspect 1B RHR pumn motor surge ring brackets per OPM-M502 ;
h 87-881C1 Ir,spect IC RHR pump rootor surge ring brackets per OPM-M502
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Appendix 6 7
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87-BBIDI Inspect 1D RHR pump motor surge ring brackets per OPM-M502 87-BDEL1 Inspect IA core spray rings " motor surge ring brackets" per OPM-M502 BDEN1 Inspect IB core spray rings " motor surge ring brackets" per OPM-M502 87-BBHK1 Inspect 2A RHR pump motor surge ring brackets per OPM-M502 87-BBHP1 Inspect 2B RHR pump motor surge ring brackets per OPM-M502 87-BBHQ1 Inspect 2C RHR pump motor surge ring brackets per OPM-M502 87-BDER1 Inspect 2A core spray pump motor surge ring brackets 87-BBHIl -Inspect 2B core spray pump motor surge ring brackets 87-AMAK1 SLC pump 2A N2 accumulator needle valve replacement 87-BLDH1 SLC pump 2B discharge relief valve replacement; contains carbon steel plug 87-BLRQ1 SLC pump 1A suction and discharge spring replacement 87-BLRP1 SLC pump 1B suction and discharge spring replacement 87-BLSD1 4KV distribution system auxiliary relay 87-BLSU1 4KV distribution system auxiliary relay 87-BLTB1 4KV distribution system auxiliary relay 87-BGKD1 Leaking of valve 2-FP-V109 in No. 2 EDG room 87-PNG151 4KV distribution system VV relay 87-0TT151 4KV distribution system UV reiay 87-BLRN1 SLC pump 2B suction and discharge spring replacement 87-BLRM1 SLC pump 2A suction and discharge spring replacement 87-BAYA1 ADS relief valve F013C removal and reinstallation following Wyle Laburatory testing 87-PLDQ1 EDG recirculation exhaust damper fails to open or close properly 87-BLDQ2 EDG recirculation exhaust damper fails to open er close properly 87-BFANI Unreliable CAP tank level indication
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Appendix 6 8 87-APGE1 SW supply valve 2-SW-V128 to 2A CS room cooler needs repair 87-BJKG1 Limitorque operator gasket leaks on CS pump 2B - suppression pool suction valve F001B 1 87-AFCEI Damper 1-VA-1B-BFIV-RB failed to close on radiation monitor ,
(D12-R605) downscale (cause sticking relay 3B-A in reactor I building vent monitor system) I 87-AFCF1 Damper 1-VA-AD-BF1V-RB failed to close when radiation monitor (D12-RG05) went downscale (caused by failure of relay 3B-A in reactor building vent monitor system)
86-AIWA1 Repair Unit 2 SLC inboard injection check valve 86-BKWR1 Replace Unit 2 SLC Squib valve upon completion of PT6. BKWR2 Replace Unit 2 SLC Squib valve upon completion of PT6. AMSA1 SLC pump 2A N2 accumulator stem leaks 86-BRDF1 SLC pump 2A N2 accumulator needle valve broke off 86-AJVQ1 Service water pump 2C motor cooling water inlet pressure regulator malfunction 86-BNAX1 Service water pump 2C motor cooling water inlet pressure regulator malfunction 86-BZNN1 Repair of EDG No. 4 solenoid valve 2-DG4-SV-6555-4 86-ATSX1 Replace seats on leaking RHR keep filled valve 86-AIFD1 Local red indication bulb and lenses cover missing from valve control box 86-AGR02 4KV distribution system door would not close in ID switchgear compartment 86-AJIU2 F060B LPIC manual injection velve packing leak 86-AJIU2 LPCI valve leaking 86-AJZS1 RHR motor 2C oil leak 86-APXW1 LPCI injection valve galled stem 86-ASRC1 DV-E11-V103 leaks by seat 86-ATSX1 RHR leaking relief valve RV-E11-F087
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Appendix 6 9 86-BSJZ1 RHR 2B oil sample failed particle test 86-BZZN1 SLC pump IB plunger packing and head gasket leak 86-BQMD1 Repack Unit 1 SLC inboard injection valve with graphite packing 86-BAUG1 Unit 2 SLC pump discharge pressure indicator pegged low 86-ARWE2 Reactor building HVAC 2A supply fan discharge damper fails to close 86-ASIN2 Electrical conduit corrosion on Unit I reactor building north core spray room 86-BNQK1 Transmitters for 02-H2 analyzers cause bad readings 85-AJYG1 SLC pump 2A N2 accumulator leaks 85-AGSQ1 Service water pump 2C motor cooling water inlet pressure regulator valve malfunctions 85-AINX1 Reactor building air receiver drain valve 2-RNA-V171 leaks by seat 85-AJSUI Repair of connections on EDG No. 2 4KV frequency relay capacitor 1-E2-AG7-810 85-AJQE1 Damper 1-VA-ID-BFIV-RB handwheel pulls loose from gearbox on attempted manual operation 85-AGNL1 Regarding overpressure on PI-2C12-R012 85-AGNL2 Regarding leak-by of regulator 2-IA-PCV-2879 85-ABHR1 LT N008A RHR HX2A LVL XMTR found isolated 85-AJSSI 4KV distribution system - electrical meters 85-AJSUI 4KV distribution system - DG-2 frequency relay capacitor connections 84-AADM1 LPCI valve shows dual indicat' ion
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