IR 05000327/1990025
| ML20062H557 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/01/1990 |
| From: | Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20062H545 | List: |
| References | |
| 50-327-90-25, 50-328-90-25, NUDOCS 9012050094 | |
| Download: ML20062H557 (84) | |
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[ptain UNITED STATES o NUCLEAR REGULATORY COMMISSION ~ [" REolONil n
j-101 MARIETTA STREET, N.W.
- I t ATLANT A, GEORol A 30323
'+4.....,h Report Nos.: 50-327/90-25 and 50-328/90-25 Licensee: _ Tennessee Valley Authority 6N38 A Lookout Place
1101 Market Street Chattanooga, TN 374022801
Docket Nos.: 50-327 and 50-328 i Licenst Nos.: DPR-77 and DPR-79 l Facility Name: Sequoyah 1 and 2 j } Inspection Conoucted: July 23-27, August 6-10, and August 20-24, and
F September 14, 1990 j ! // / TO Inspectors: . B. R. Crowley, Team Leader Datd Signed j ' Team Members: J. Coley: R . N'. Economos P. Fillion 'B, Martin i D.- Schultz -! R. Shortridge
' / } Approved by: / ' // / 90~ - J.
lake, Chief Dite' Signed ' . '.Egi[ralsandProcessesSection-f M e a eering Branch-Division of Reactor Safety
SUMMARY , Scope:. t i , This special, announced inspection consisted 'of an indepth team inspection of J-the maintenance program and its: implementation.. NRC = Temporary Instruction 1! 2515/97: issued September 22, 1989, was.used as guidance for this inspection.
i! i 'Results: - I Overall; 'the maintenance program was judged to be GOOD with SATISFACTORY implementation.. The more significant areas of strength and weakness are - highlighted:in the Executive Summary, with details provided in the report. One
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I ~ ~ ) . . iii SUMMARY This NRC maintenance team inspection rated the Sequoyah mairtenance program good and its implementation satisfactory. A good rating indicates better than adequate development and implementation of the important eiements of the maintenance program w4th a few minor areas that need improvement.
A satis-factory rating indicates adequate development and implementation of the important elements of a maintenance program, with the areas of weakness being approximately offset by strengths.
i he inspection was conducted by a seven-man team using inspection guidance provided in NRC Temporary Instruction 2515/97. A principal feature of this instruction is a maintenance inspection logic tree used to collate and present the maintenance inspection findings.
The tree prepared from inspection of Sequoyah maintenance is presented as Appendix 3 to this report.
It depicts the ratings determined for individual maintenance elements and the overall good program with sati sf actory implementation rating.
The ratings were based on specific strengths and weaknesses and are discussed in report Paragraph 4.
. The following are the more significant strengths and weaknesses identified: Strengths Strong maintenance management and strong plant management support of - maintenance were avident.
A good, well staffed corporate maintenance organization was involved in - site maintenanca activities and programs.
Craf ts and su;ervision were generally well qualified and performed task. in - a professional manner, using good work practices and required procedures.
Good work control and work prioritization programs were in use.
- PRA Concepts and Reliability Centered Maintenance (RCM) studies were being - used in the maintenance process.
Goals and performance indicators were in good use to improve the - maintenance process.
A strong instrument (Technical Specifications, Regulatory and Other) - calibration program was in place and implemented.
A detailed post maintenance testing (PMT) Program had been implemented.
- A system engineer program was in place and system engineers were - enthusiastic and knowledgeable about their systems
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_QA/QC involvement in maintenance was good.
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Overall, general housekeeping and material condition were good.
- ! Weaknesses-Poor housekeeping conditions were identified inside: low-voltage - distribution boards, panels, and cabinets; racks of process-instrumentation and protection instrumentation in. auxiliary instrument rooms; Appendix R backup control room panels; Unit 1 pipe chase; and new make-up water treatment plant.
- ' Examples of poor material conditions were noted as follows: Poor soldering < , L technique, missing washers, and missing nuts, in low voltage distribution boards, panels, and cabinets; vital batteries nut. found in cell, - corroded -cell connectors, top of cells wet; vital battery rooms-severely degraded coatings on cinder block walls; a small number of loose or-broken flex conduits in various systems; a small number of missing or loose ' valve ~ , handwheelinuts; Conduit box cover missing and loose, improperly _ terminated cable banging out of junction box at SI valves _1-63-6 and 7; a number of ' missing covers on temperature transmitters; and a large number of burned i ' cut; indicator lamps on.480 and 6900 volt boards.
' The following preventive maintenance (PM) weaknesses were : identified: PM
-- deferrals 'not aiell controlled and justification for deferrals of ten not , ~ adequate; -schedule does not < show deferred or canceled PMs making a ~ determination of last-performance. very di f ficult; past PM program for safety-related 6.9_ KV breakers not, well implemented allowing 13 years - between PM performance for some. breakers; annual PM for desiccant change-out -on cauxiliary control. air dryers not performed since 1986 for one-dryer;- no1PM issued to accomplish 1 procedure for setpoint verification on ' moisture;elementsiin: auxiliary control air system; many PMs cut across units,ssystemsnand-trains -covering too many atasks, to be practical to' - perform: as lonet package = -' example PM - 00860300;. and megger-testingEof , uswitchgear'at a voltage too_ low to: provide meaningful results.
- 10nlyl a tiimited predictive maintenance program had been implemented: oprogram.did not include. thermography, and vibration and oil analyses had- , been implemented on a. limited bases only.
Engineering program _for analysis of' equipment failure trend data provided-j i-- > > dby maintenance was-in its infancy-and little trending was being performed, l p RecognitionLof trends, and initiation of corrective action was sometimes ' ~ - , slow - example, masoneilan valve failures (285 same type valves with s'ame.
failure' mechanism).
Corrective action has also been slow in correcting less complex annunciator; problems.
JRadiation; Protection Program weaknesses were identified as responsible for - - lhigh collective dose. During removal of resistance temperature detectors i _(RTDs), contributing 1 factors to high collective dose were: inadequate a . m m , _
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< , p e mockup training, less-than optimal planning :and path scheduling, poorly.
- trairied/ inexperienced workers, and failure to use realistic collective idose. goals as a management too1 to control dose (see NRC Report 90-23).
- Also, an adverse trend was identified in that, personnel did-not always wear dosimetry into.the radiologically controlled area of the plant.
Weaknesses in the procedure validation program were-identified -in - that - procedures could not be performed'as written.
On'e violation-was identified during the inspection.
It involved failure to f . control cleanliness in low-voltage vital equipment.
- Two-- unresolved items were ' identified..One involved questions relative to~ . compliance with commitments to GL 88-14 (instrument air) and the other a - pertained'to the descr,iption of the fifth vital battery in the FSAR.
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INTRODUCTION This inspection was conducted to assess the effectiveness of maintenance at Sequoyah Nuclear Plant utilizing guidance given in NRC Temporary Instruction 2515/97. It was performed by a seven-man team during July and August 1990.
The inspection findings and conclusions are described in report Sections 2 , through 4.
Section 2, Inspection Details, describes the conduct of the inspection and the findings obtained in examining maintenance for selected systems, miscellaneous maintenance work in progress, health physics and selected areas of interest.
Section 3, Issues, describes the more outstanding issues identified by the inspection. Section 4, Evaluation of Plant Maintenance, summarizes all of the findings and logic which . culminates in the overall rating of maintenance effectiveness at Sequoyah.
' A special maintenance inspection logic tree developed for the NRC was utilized to collate findings for the rating process.
It is discussed in Section 4 and presented in Appendix 3.
The last section of the report documents the exit interview held with the - licensee on. September 14, 1990, following the inspection.
2.
INSPECTION DETAILS This inspection was performance based and included: 1) General plant walk' downs performed to observe and assess material condition and housekeeping.
-2) Detailed examinations and assessments of maintenance and maintenance-related work performed on selected systems.
i 3) Work performance, procedure compliance,: proper documentation, cleanliness and housekeeping, material _ control, system control (tag-out, LCO, ~ etc.), tool control', post maintenance testing (PMT) requirements, _and - personnel qualification, as applicable to the specific work, q ! 4) Maintenance work histories for the selected systems were examined by'
reviewing a brief-description of the 1989 and 1990 completed WRs.
5) Examination of health physics involvement and support to maintenance.
6) Assessment of facilities and organizations _ supporting maintenance.
The inspection. findings for systems, health physics and for miscellaneous-maintenance work observed are described below. Findings important to 'the evaluation are included in Section 4.
. - - -
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h ' 2.a.-Safety Injection System ' The function of the safety injection (SI) system is to provide adequate . emergency cooling to the reactor core in the event of a LOCA or high ! energy line break.
Depending on the accident scenario, this is accomplished with the passive accumulators, the SI pumps, the charging pumps, the refueling water storage tanks (RWSTs), which are the major source of borated water, and associated piping and valves.
, INSPECTION The inspection included 'valkdowns of the majority of both the Unit 1 and 2 SI systems outside of containments and the examination of twenty-four recently completed work requests (WRs) related to the SI system.
Durin the inspection period, no in pro:ess maintenance activities were performed on the SI system.
However, tne team was able to assess the general maintenance of the SI system based on. the results of the walkdown , inspection, the review.of completed documentation, and the observation of ! both corrective and preventative maintenance on other plant systems. (The j details related to the observation of maintenance on other systems are l covered in paragraph 2.f. of this report).
FINDINGS I Walkdown f ! In general, equipment, visible system conditions, work instructions, and . housekeeping were very good, however, some '3olated exceptions were noted.
! In the Unit 1 pipe chase (Elevation 690)-c,oron buildup was identified on i ' nine-.SI valves at the stem and packing gland. (Minor leakage was observed on relief valve 1-RV-63-535 and a.'small puddle of water was standing on the flooM.
Review of open WRs _ for the SI system revealed' that five of - l the nine ;;1ves with -discrepant conditions - identi fied by the-team
(including relief. valve - 1-RV-63-535) had open requests to cover their
repair.
Deficiency - tags had not been placed on the. valves because of J radiological considerations.-. The SI system engineer initiated WRs-for the i . remaining.four valves.
The team also noted that wool-like insulation on.
heat trace piping for the boron injection tank (BIT) was infa deteriorated a condition.
(A plant modification had eliminated the baron storage l function of the tank and heat tracing was no longer needed for the pipe).
!
The insulation was noted on;the floor beneath the tank and hanging loosely ] c from~ associated piping. The condition coupled with valve leakagespresent h in the pipe chase represented a potential radiologically unsatisfactory
' condition not typical of other radiologically controlled areas.
The.
systems engineer stated that he would have the wool insulation removed and ! the-area cleaned up, The team also noted a hanger (attached to a.2" pipe above valve 1-FCV-77-245 that was not attached to anything_on the other-end. _ The embed plate for its attachment to the containment wall appeared-to be missing.
WR-C008963 was issued and the licensee's-evaluation' ,
..
6 concluded that the hanger had been attached to the pipe for alignment during construction and had never been removed. The team also noted that valve 1-VLV-63-566 was missing the required valve identification tag. The system engineer issued WR-T012118 to correct this discrepancy.
During the walkdown inspection of the Unit 1 pipe chase on the 669 elevation, the team observed that a conduit tee box which included , electrical cables for the motor operators on valves 1-63-7 and 1-63-6 was missing its cover plate and two cables had been drawn through the inspection port and left hanging out of the tee box as if abandoned.
However, the cables were not tagged abandoned and the conductors were not terminated in accordance with maintenance procedure no. M&Al-7.
The system engineer issued WR-C013994 and the resulting investigation revealed that the cables were abandoned during construction.
The licensee issued - CAQR SQP900346 to correct the conditions noted by the team. Boron buildup was observed on two SI valves at the stem and packing gland. The system engineer issued WRs C013469 and C013468 on this condition. In addition to the above, a flow indicator cover and gage cage was observed missing on - 1FI-63-2 and WR C013467 was issued for repairs.
The team's inspection of the Unit 2, elevation 690, pipe chase revealed that eleven valves. had boron buildup. indicating minor. leakage. One valve (2FCV-63-153) had visible leakage... However, ten of the above valves had existing WRs issued-on them to correct :he leakage problem during the September 1990 outage.
The system engineer issued WR C013457.to insure
that all eleven valves' would be re-worked during the upcoming outage.
Other discrepancies noted in this ' location included: a handwheel nut ' missing l from valve 2-FCV-538, valve identification tag was missing from valve 2-FCV-63-8, flexible conduit loose from the stuffing boxes on motor operators for valves 2-FCV-63-22 and 2-FCV-63-11, and-a copper tube. ' y~ , supplying air' to valve 2-FCV-77-19 was crimped possibly restricting air ' flow. The system engineer issued WRs-on each of the above items.
' Inspection. of the IAA Safety Injection Pump - Room revealed two safety , injection valves. (1-FCV-63-4 and 1-FCV-63-525) with slight' boron buildup.
around 'the stem packing gland. WR C013464 and WR C013463 were issued. In the 2AA Safety. Injection Pump Room, oilcleakage was noted on the pump foundation J near the inboard seal. The system. engineer stated he would p ' write a service request to: have the area cleaned up so that' he could determine the rate of' coupling leakage, but he felt. it was very minor.
Valve '2-FCV-63-4 also had evidence of slight leakage' at the packing gland-and stem.
The systems engineer issued WR C013465.
. In. tFe 188 Safety Injection Pump. Room slight boron buildup was noted on ._ valves. 1-63-527 and 1-FCV-48. WRs C01:462 and C013458 were issued to have these valves cleaned and repaired if =necessary.
Valve 1-VLV-70-712B had slight leakage at the' stem and valve 1-67-15498 had slight leakage at an E adjoining fitting. WRs C013461 and C013459 were issued to correct the.
_ conditions noted.
In addition to the above, the SI pump foundation was. ~ noted to have flaking paint, due to previous leakage, which presented a ,
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. trap for potentially contaminated water at the inboard pump seal.
The licensee issued WR C007165 to clean and paint the base of the pump foundation.
The team observed that the outboard seal for the 1AA - centrifugal charging pumo was leaking approximately 20 drops per minute.
Further investigation revealed that WR C006211 had been written prior to the teams inspection to replace the mechanical seal during the next-refueling outage or sooner if required.
Valve handwheel nuts were observed missing on valves 1-70-709A and 1-70-707A.
WRs C013115 and C013116 were initiated to correct this problem.
Boron buildup was noted on valve 1-HCV-62-526 and WR C013114 was initiated to correct the' problem however, no degradation of bolting or piping existed.
During the inspection of the Units 1 and 2 RWSTs, the team noted water standing in the tank moat area. Four, broad-range,. level indicators were located in the moat area and could become submerged in the event of a heavy rain.
Investigation into this item revealed that this had been a . problem and the subject of Licensee Event Report SQRO-50-327/89001 dated January 3,1989. The licensee's long term corrective action has not been-completed to date.
However, Design Change Notices M03069A (Unit 1) and M03070A (Unit 2) are nearing completion that will providt for a structural " skirt" to be = constructed around the RWST to divert rainwater from the moat surrounding the base of the RWST. This modification is scheduled to-be accomplished in fiscal year 1991. Discussions with management revealed that.each plant modification has been assigned a plant priority and allocation of resources rank each modification according to its overall importance in plant upgrade programs. The RWST moat had a reasonably high priority.
In the interim the ongoing procedure of relying on shift surveillance and having the. rain water. pumped out (after_ contamination isampling) will continue.
Although, several valves were noted with mincr boron buildup during the team's walkdown inspections described above,. the licensee had previously identified most valves identified by the team.
The _ licensee program.for-the -evaluation of borated water leaks was in accordance with NRC Generic Letter _88-05 andlwalkdowns were - regularly scheduled per PM 4014 (Unit 1)- -and PM 4085 (Unit 2). All boron buildups observed on valves were of minor nature. The licensee actions and the general condition of the_ borated water systems = were considered to be a, strong point in the licensee's maintenance program. The system engineering-organization also appeared to be : well qualified, int;mately involved in the maintenance process, and.
familiar with their. systen.:; a definite strengt1 for the maintenance . program.
Review of Completed Work Orders " Review of-twenty-four recently completed work orders. for the SI system T revealed,.in general, that instructions for performing work were ' detailed and-responsibilities were -well defined. Exceptions were noted during the review of two completed work packages: (1) WR C001537, page 5, entitled " Actual Work _ Performed" noted that the valve diaphragm ordered for the refurbishment of valve 1-FCV-63-66 was the wrong size. However, there was
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. . no post-work critique check form filled out to address this material problem as requi red by procedures SQN-PMSP-6.2.2 and SQN-PMSP-6.2.5.
Therefore, planning and engineering remained uninformed of their mistake in referencing the wrong drawing /part number and the mistake would have been repeated on future WRs because the Equipment Information System had been updated to include the incorrect entry.
(2) WR-263299 identified flow control valve 2-FCV-63-68 as leaking past its seat as a result of performing Technical. Instruction (TI) 118.
The valve was refurbished, however, no. post maintenance test (PMT) requirements were listed on the Maintenance Request Form (Part 1). Discussions with the licensee revealed that' valve 2-FCV-63-68 was a test valve that could not be isolated for reverification of seat leakage. The test used to verify whether the valve had been corrected satisfactorily was performed during start-up as part of an integrated test. The two exceptions noted above were not considered to represent weaknesses in the program because of the following: (1) The use of critique sheets.to allow the craft to feed information to planning and ! engineering was a new initiative started by the licensee and its implementation was not complete'during the inspection, and (2) Page 9 of- -the Sequoyah Nuclear Plant Standard Practice SQN-SQM66 for PMT states that "it is the intent of this program to eventually include all references to specific post maintenance testing in Appendix B, Part 1."
However,- present testing of some valves in unique piping configurations is accomplished by other plant documents and the test requirements were not within. the boundary of, this work order.
L 2.b. Essential Raw Cooling Water (ERCW) and Raw Cooling Water (RCW) Systems The ERCW System is designed to supply cooling water to various heat loads in-both the primary and secondary portions of each unit. Provisions are made to ensure a continuous flow.of cooling water to those systems and o components necessary for plant safety leither during normal operation or under accident conditions. Sufficient redundancy of piping and components ' is provided to ensure that cooling is maintained to vital loads at all times.
, The ERCW system consists of eight pumps, four. traveling water screens, 'four screen wash pumps, four strainers' located within the ERCW pumping station and, associated. piping and valves.
, INSPECTION The team performed a walkdown inspection of the;ERCW and RCW systems in such areas as the turbine building, auxiliary building, cump station and t the emergency diesel building. Specific components selected for a detail op inspection included control rod drive, equipment room, air conditioning . units; containmentLventilation system water chillers;: shi.tdown board room-chillers; emergency diesel generators; air compressors; raw cooling water booster pumps'A.and B; and all equipment located in the pump house, i.e., pumps, traveling water screen units, and screen wash pumps and strainer. i , = .
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A selecta; = ample of (30) completed WRs representing a cros.s-section of all components within the ERCW system were reviewed.
FINDINGS Walkdown As a result of the walkdown inspection, the team determined that most of the areas inspected exhibited relatively good housekeeping conditions.
Equipment was relatively clean, i.e., free of debris, dust accumulation and excessive oil / grease either on the equipment or trays. Exceptions to prevailing conditions were as follows: in the upper head injection (UHI) equipmer,t room, the team observed a residue (determined by the licensee to be dry borax, which had been stored near glycol mixing tank) on the floor grating, on equipment and on UHI piping located at floor level; some thermal well and pressure tap identification tags were missing; some caps were missing from vent taps; and a pressure indicator associated with RCW booster pumps A and B was in service in spite of a severely bent pointer.
Also, a temperature transmitter was found without a cover and another exhibited a WR, dated October 19, 1989, for maintenance because it could not be calibrated.
These conditions were identified to the licensee who took appropriate corrective action which was completed prior to the end of
this inspection.
Review of Completed Work Orders _ Completed maintenance work order. records. were reviewed to ascertain whether administrative' approvals were obtained before initiating work; - acceptance criteria were met; procedures. were approved and adequate; inspections were in accordance with procedures and records were complete; PMT and functional testing as applicable was being performed as required.
During = the review of completed WRs, records of completed preventive > maintenance (PM) work performed on ERCW pumps and traveling water screens,
covering La -period of two years, were reviewed for-the attributes stated - above. Within these areas, the team noted that, in the case of ERCW pumps, certain mandatory PMs were deferred for some date later than that indicated on -the: PM Forms.
These deferrals were justified with a ' statement that, "PM deferral would not: cause - adverse conditions to the ' pump." The statement had been signed-by the cognizant section supervisor.
A review of the controlling procedure, 'SQM157.0, ' disclosed that such . _, + deferrals required a technical justification to be approved by engineering _ management.
Io subsequent discussions with the licensee, the' team stated-that the aforementioned statement did not qualify as a technical justification but rather as a conclusion. to such' a justification.
The > licensee agreed with the team's position and stated that a new controlling procedure, identified as Site Standard Practice SSP-6.3, Preventive
- Maintenance, would correct this problem with more restrictive language and
. more specific guidelines. The licensee had recognized weaknesses in the.
-- , L PM program and was in the process of improving the program, i ,
. , ,
Trending Programmatic requirements for trending are addressed in various licensee approved documents including the following.
STD-10.3.406, Rev. O, Maintenance History and Trending Requirements SSP-6.1, Rev. O, Conduct of Maintenance SQM 58, Rev,1, Maintenance History and Trending Following a review of these procedures and the above noted completed maintenance work order records for the ERCW system, the team interviewed the system engineer to determine whether equipment f ailures had been evaluated for root cause, common failures, etc., and whether any trending of f ailures had been establ10P.d for maintenance purposes.
Discussion revealed th6t, while historical maintenance records on system equipment were readily retrievable, no formal trending process had been establisheo at the system engineer level, For example, the team found that while in some instances, system engineers generated trend data on certain components because of repeated f ailures, there was no evidence that tren, ding of equipment f ailures was being accomplished consistently by all system engineers.
Prior to the inspection, the licensee had initiated plans to improve this area of the maintenance process, 2.c Control Air and Auxiliary Control Air Systems The Compressed Air (CA) System is divided into two subsystems, Station Control and Service Air (SCSA), and Aur!liary Control Air ( ACA), Four motor-driven, 2 stage, reciprocating air compressors (AC) and one rotary screw AC supply adequate air pressure for general services, instrumentation, testing and control functions.
Two redundant headers feed two air receivers, which in turn supply 3 redundant control air stations with pre-filters, dryers, and af ter filters.
Service air is piped through a back pressure valve which protects the SCSA System by isolating the Service Air from the SCSA System if Service Air pressure drops to 88 psig. The ACA system is supplied by two motor-driven single stage reciprocating air compressors each with receivers, dryers, and after filters ' supplying CA to an independent train.
The ACA compressors ' automatically start upon loss of SCSA air at 75,5 psig decreasing and isolate the SCSA System when system pressure drops below 68 psig. The ACA System will then supply CA to all vital instrumentation and controls. All CA for. vital equipment passes through the ACA dryers.
INSPECTION The team performed a walkdown inspection of the SCSA and ACA systems including most major components and some end-use devices throughout the plant.
The team also examined Preventive Maintenance (PM) Tasks, completed Work Request (WRs) (approximately 20), vendor manuals, and selected maintenance records to determine the extent of maintenance work . .
i . .
. performed on the systems.
In addition, the licensee's response to NRC Generic Letter (GL) 88-14 " Instrument Air System Supply Problems Affecting , Safety-Related Equipment" 8 August 1988, was reviewed.
Licensee's corrective maintenance backlog controls were also reviewed.
j FINDINGS i Walkdown The System Engineer (SE), who regularly walks down the CA system recording
pressures, temperatures, and other parameters for use in system trending, accompanied the team on the walkdown of the SCSA and ACA systems and took prompt action to correct the discrepancies found by the team. During the
walkdown inspection, the team found the general material condition was satisfactory with few exceptions. ' A flex conduit on low oil level switch 0-LS-32-90 B-B ACA compressor was found loose, and Oil accumulation was found above the scraper ring stuffing box of B-B ACA compressor.
WRs were written and tags hung for subsequent repairs. A gray, dust-like substance was found on the concrete mounting pad for B-B ACA compressor - adjacent to the ACA dryer B-B vent muf fler. While working WR C001641 on dryer A-A, the licensee collect:d a samole of. similar dust for analysis ' and found the dust to contain desiccant from the dryers. As noted below, the PMs to change out the desiccant had 60t been accomplished for a number of years.
See paragraph 3.c for further # scussion of this problem.
Preventive Maintenance I During the review of Sequoyah's System 32 (compressed air) PM's, the team l found annual PM check 1450 " Inspection for Auxiliary Control Air Dryer - A-A" had not been ' accomplished since. February 1986. This was considered
.significant by the team and is discussed further in paragraph 3.c. below.
. The team also found inaccuracies in TVA response letters of February 23,
1989, and February 14, 1990 to NRC GL 88-14.
These are also' discussed , further_in paragraph 3.c. below.
. F Review of Completed Work = Requests . During the team's review of. completed Work Packages for the Control Air r System,'the following discrepancies were noted: WR B279138: Equipment identifier was incorrectly ' loaded to the - , computer and:in Maintenance History. 0-ME-032-0034 should have been ' 0-ME-032-0084. The-licensee's Maintenance Planning Group submitted a QA change form to revise the Maintenance History data base.
WR B271620:. Auxiliary air compressor "A" tripped on hw eil level - , during performance of SI-689, but did not annunciate locally or in > the main control room.
Oil was added and this WR was written to ,
. .
repair the annunciation circuit. Wires were lifted from the switch
and tested to the control room, with no problem found. Actual work performed and maintenance sheets did not indir. ate if the switch was tested.
The licensee stated that the same level switch trips the motor and operates the annunciator equipment, therefore, lif ting the wire verified that a low oil level will trip the motor and will ' annunciate in the Control Room.
WR B797924: The Maintenance History entry in the computer does not - reflect the actual work preformed or the problem found.
Failure description and cause of failure sections were left blank.
The licensee responded by having Maintenance Planning rewrite the maintenance history summary ant mbmitted a QA record change form for this WR.
The team's review of other completed work requests found similar discrepancies with maintenance history computer input in that " Failure . Description" and "Cause of Failure" sections were also left blank.
The
team's impression is that, with implementation of the new Site Standard Practice SSP-6.5, " Equipment Maintenance History, Trending and Nuclear Piant - Reliability Data System (NPRDS)", these inadequacies would be addressed.
Vendor Manual Review Vendor Manual SQN-VTD-P050-0029 " Installation, Operation and Maintenance Instructions for Heat-Less Dryer and Filter Assembly" was reviewed.
, > Inconsistencies were found regarding the frequencies that desiccant should be replaced.
Requirements listed on page 12 1 the vendor manual state " Annually inspect and replace (the desiccant) if it is badly broken up or contaminated with oil".
Page-13 states Active Alumina (type of desiccant used at Sequoyah) replacement is to be scheduled every 6 months. An > additional note states "The amount of dust produced by the dryers is g basically dependent on the type of desiccant used within the dryer".
_ ! Licensee personnel indicated requirements listed on page 12 of the vendor manual are for the air dryers annual inspection of desiccant.
Page 13 refers to replacement of the After Filter every.six months when the Active Alumina is used in the air dryer.' PM-1488 and 1489 replaces all Af ter Filters every six months.
When reviewing MI-10.36 " Auxiliary Control Air Compressor Rebuild",
Revision 7 of 2/24/88, the following concerns were'noted: Section 2.3.3 lists vendor " Instructions and Parts List on Packaged Four-Inch ESV-NL Portplate Type Compressor " Form 3690.
The team could not find vendor l instructions Form 3690 at the vendor controlled copy storage area.
The control copy of.the vendor manual for the ACA compressor was listed as SQN-VTD-IO75-0020, " Instructions-and Parts List for Packaged Four-Inch ESV-Non Lubrication Portplate Type Compressor".. Form 3690-A May 1975 s supersedes Form 3690.
Further reviews of MI-10.36 revealed inconsistent-format with Appendix A and B which is used for inlet and discharge valve-i rebuilding, and the main _ test of the MI. The use of call out numbers with reference to Figures 4 and 5 was omitted in the Appendices. In addition,
_ _ _.. . > .
-. w Figures 4 and 5 of the MI do not match vendor manual, SON-VTD-IO75-0140 " Instruction and Parts List" Form A-3904-VN of April 1968 (Sections 2, 3 . _ _ and 4 of MI) Figures 4 and 5 from which the MI figures were taken. It was the team's opinion that these discrepancies make the procedure confusing and difficult to use and could lend to errors.
The licensee stated that the procedure would be evaluated for improvement.
2.d. 6900 and 480 Volt Distribution Systems and large Motors The purpose of the 6900 and 480 volt distribution systems is to distribute i electrical power to plant auxiliary equipment. Portions of these systems are safety-related.
Motors provide mechanical power to pumps, fans and valves in the various plant systems.
Switchgear is utilized to control large motors and is fairly complex from the maintenance viewpoint. Motor maintenance must also be an important part of any good maintenance
program.
Therefore, the inspection focused on switchgear and motor maintenance.
The 6900 volt switchgear is model 7.5HK500 manufactured by ITE Corporation.
The 480 volt switchgear is D5-206 and 05-416 type manu-factured by Westinghouse Electric Corporation.
Switchgear is located in ' the turbine building and the control building, with some outdoor 6900 volt _ switchgear. Motor Control Centers (MCCs), which control smaller motors, - were manuf actured by Arrow-Hart Company.
Some MCCs have a control power , bus and others have control transformers at the starters.
MCC field wiring terminations are at the individual compartments. Large motors are -- generally drip-proof, fan cooled design, either horizontal or vertical, directly coupled to the load.
INSPECTION Inspection effort for the switchgear and motor maintenance programs -- consisted of the following activities: The NRC team walked down nearly all switchgear and MCC areas of both ' - units.
Selected compartment doors were opened and bolted panels removed to allow inspection of wire bundles, wiring terminations, cleanliness; and labeling of devices, wires and cables. The internal inspection was performed on five 6900 volt, two 480 volt, four MCCs and two sequencer compartments. Areas surrounding the switchgear and MCCs were inspected for housekeeping, lighting, communication equipment, cable and raceway work, scaffolding, etc.
Procedures for carrying out preventive maintenance work on the 6900 - and 480 volt switchgear were reviewed in detail.
A program review, i.e.
frequency of performing the preventive - maintenance (PM) on the switchgear was conducted. Also a review of - documentation (i.e., records of PM work) was made to confirm that the specified program was actually carried out.
a __
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The NRC team conducted a review of the corrective maintenance history - on the 6900 and 480 volt switchgear.
For example, a computer printout summary of all corrective maintenance work requests initiated or closed during 1989 or 1990 was reviewed. A copy of each completed work request package for any problem that involved a breaker failure or potential breaker failure, was reviewed to ascertain any adverse trends.
Failure rates were compared to those in IEEE Std 493-1980, Recommended Practice for Design of Reliable Industrial and Commercial Power Systems.
. ! A work request, initiated in 1988, to perform PM on three spare - safety related 6900 volt circuit breakers was worked during the inspection so that the NRC team could observe the work in progress.
The training and qualification process in relation to switchgear work - was reviewed.
The incorporation of special _ vendor recommendations and operating - experience into the maintenance program for the 6900 and 480 volt distribution systems was addressed.
The NRC team compared the licensee's motor maintenance program to an - , objective published standard to form a basis for evaluation.
The standard chosen was the " Work-in-Progress Report on Maintenance Good ' Practices for Motors in Nuclear Power Generating Stations - Parts 1 and 2," which was developed and published by the IEEE.
The IEEE reports were not considered a requirement; but were a useful yardstick with which to measure an actual program. The team selected , three safety-related motors for the inspection effort: Two that run approximately 50 percent of operating time - the 6900 vnit ERCW pump i R-A and the 480 volt component cooling water pump 2A-A; Jand one standby load - the 6900 volt auxiliary feedwater pump.
Inspection effort included a walkdown of these motors and a review of the vendor ' manuals.
e The NRC team held interviews with the cognizant system engineers, the.
-
Electrical Maintenance Superintendent, procedure writers, the Corporate Maintenance Field Support Manager, Supervisor of - ; Reliability Centered Maintenance and others.
FINDINGS L - Walkdowns Based on the waikdown inspection, the switchgear, MCCs and electrical equipment areas appeared to be well maintained.
A few broken-. flexible conduit fittings, and missing connection box covers were observed. Work , requests were initiated to correct these minor deficiencies.
Four _ instances of missing labels were noted.
~ l , 9 - nsa- - --~ m.. a-
_ _ _ _ _. _ _ _ _ - _ _. _........... ' _ =
Temporary labels were hung so that permanent labels could be affixed in accordance with the licensee's labeling program. There was obviously a __ general problem with burnout of (or failure to replace) breaker status indicating lamps at switchgear and MCCs.
This is not a significant - problem, but warrants attention.
it was assigned to Technical Support for resolution.
During the inspection period, the System Engineer cetermined -- that the lamps being used on MCCs (which is an A.C. circuit) had a . relatively short average lamp life, especially since the lamps are " operated at voltages above their rating.
He selected a lamp which would [ have a longer lamp life, and it was tested in the field for intensity. A Design Change Notice was approved which is the first step in the plant modification process.
The System Engineer will also study the switchgear indicating lamps (which are in 125 and 250 VDC circuits) to determine if an application problem exists.
Procedure Review . The primary procedure for preventive maintenance on 6900 volt switchgear i s MI-10.4, Rev.11, Maintenance Instruction 6900V Breaker Inspection.
This procedure had strengths and weaknesses.
The general clarity and format were excellent.
It included nearly all the steps recognized by utilities as being beneficial for PM work on this type of equipment.
In addition M1-10.4 called for about 38 independent verification of steps by E craf t persons, foremen and quality control personnel. Another plus for this procedure, and other similar procedures, is that it invoked a special procedure, EMSL-A36, aimed at reducing the potential for common mode failures caused by maintenance work. However, MI 10.4 had omissions of a few steps considered standard industry practice.
For example, the procedure did not nention the anti pump circuit, space heaters, blow out coil, _ and potentiai transformer compartments. There were problems with the tools and supplies list, such as incorrect TIIC numbers.
Breaker _ lubrication was not clearly addressed in the procedure. The scope section implied that the breaker timing test was only performed at each 1000 operations, but the intent (and actual practice) was to perform the breaker timing test each time the PM is performed.
Additional problems with the procedure became apparent during conduct of the procedure, and are discussed in paragraph (e) below.
The insulation resistance test specified in the procedute was poor because it used a 500 volt megger and the acceptance criteria was 1 megohm.
During the inspection, the licensee agreed to revise the test.
Future tests will use a 2500 volt - megger and have an acceptance criteria of 8.5 megohms, which is more in , line with industry practice.
The NRC team's comments on MI 10.4 were discussed with the appropricte personnel, The licensee responded indicating that the comments were valid and either would be incorporated or evaluated for incorporation.
The primary procedure for preventive maintenance on 480 volt switchgear is MI 10.5, Rev. 14, Maintenance Instruction 480-V Vital Switchgear Inspection.
This procedure was also reviewed in d;teil.
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t - , l
i It had the same strengths as MI 10.4, and there were only a few minor comments.
The procedure covering insulation resistance, winding resistance and high potential testing of motors and feeder cables, 0-MI-EPM-317-102.0, ' was reviewed by the NRC team, and found to be good.
PM Program _ Review ' Procedure MI 10.4, for the 6900 volt switchgear has undergone many revisions.
Although early 'evisions had much less detail than the ' present version and requirec. little, if any, verification, MI 10.4 '; that was in ' effect in 1980 d'd call for a contact compression check , and a contact resistance test, which would provide useful information - ' about the condition of the circuit breaker.
The PM program for 6900 volt switchgear had not been well_ implemented over the years. Relatively long time intervals elapsed between PM work on many of the circuit breakers. The safety-related switchgear..last received ' a PM (per MI 10.4, Rev. 4) during July 1980.
The record for ~ the
nonsafety-related switchgear is actually better.
Two nonsafety-related , breakers selected at random (one for each unit) received PMs during , November 1986.
Records also show that the outdoor switchgear, or start ' buses, received a PM during May 1983, per MI 10.4, Rev. 7.
,
Besides. the regular PM described i MI 10.4, the 6900 volt switchgear received periodic visual inspectic., and cleaning.- For example, the safety-related 1A-A lineup -was - inspected, cleaned and touch-up painted under PM-02407, an annual.PM, during December,1987; March,1989; and , January, 1990.
Those PM's covered the. cable - compartment, control j compartment and exterior.
Another procedure, PM-02301, called for a-l quarterly inspection and cleaning of the cable compartment only. Records show that PM-02301~ was performed fairly regular on the. 6900 volt bus 1A-A, i.e., ~ actually ' performed eight times versus the planned twelve times .between October 1987 and the time'of this inspection..However, PMs 02407 r and 02301 in no way substitute-for MI 10.4 t < Similar to the 6900 volt-switchgear, the PM program.for the 480 volt j switchgear has not been well' implemented since plant startup. However, at: , leatc L for the safety-related switchgear PM performance on the ~480 volt ' ' equipment has.been better than for_the 6900. volt safety-related equipment.. J ' -NRC: Bulletin No. 88-01 required inspection ' of pole-'shaf ts in circuit - breakers used in safety-related or reactor trip breaker applications.
Since the pole shaf t inspection _ required tear down of the breaker, _the
' licensee took that' opportunity to perform PMsLper MI 10.5 concomitant with.
.l ' ~ the; bulletin work.
As a. result, all safety-related 480 volt circuit L breakers received a PM within the last' two years, except' for the feeder ! D breakers which will be discussed.later.
In addition',:one half of all 480 volt switchgear breakers received a PM during the last refueling outage on-Unit 1.
On the other hand, some 480 volt:nonsafety-related breakers may.
never have received the MI 10.5 PM nor anything similar, , Ie T
_ _ _______-_-
t . .
! . The program for preventive maintenance on 6900 volt and 480 voit ' switchgear, as now defined, is as follows.
Each circuit breaker will receive a PM every third refueling outage.
In other words, one-third - of all breakers will be PM'd at each refueling outage according to the programmatic list.
The 6900 voit work starts next outage, and the 480 volt work started last outage on Unit 1.
Corrective Maintenance History Review , Switchgear failures found during the corrective maintenance history review are summarized below. A failure was defined as a failure to operate on demand, a spurious trip or discovery of a condition that could have caused a failure to operate on demand.
Parameter 6900 Volt 480 Volt ' S/R failures
2 Non S/R failures
-3 Failures per unit year 0.02 0.0122 Industry wide failures 0.0036 0'.0027 per unit year from IEEE Standard 493-1980 While the failure rate of both the 6900 voit and 480 voit circuit breakers, for the period studied, is about five times the industry average, this is not considered statistically significant, and does not indicate a-definite adverse trend.
However, the program should require system engineers to trend the breaker - f ailure rate as a check' on the adequacy of the maintenance program.
Observation of Work in Progress , During the second week of the inspection the NRC team observed' two " qualified" workers.and a helper performing MI 10.4 on a spare 6900 volt circuit breaker in the switchgear room.
The work was witnessed-from the . oeginning.
Observations and findings made by the team were as follows.. Test equipment and supp1,ies were readily available, and controlled according to good' practice, The crew moved through the first 19 steps . i smoothly.
They noticed ' that the are chute housing on one phase was broken. Then, step 6.3.20 called for removal of the main toggle. link-pin.
-for inspection. However, the crew was uncertain as-to the. location'of thc' a . main: toggle" link pin.
Temporarily terminating ' the work -in a proper ' manner, the crew proceeded to the electrical shop to study the vendor manual.
They found that the vendor manual did not contain any diagram I showing - the main toggle link pin.
At that point, a. craft person responsible for on-the-job training described the location of the pin.
-.The job was resumed.
Shortly thereafter, a second problem was
encountered, this time at step.6.4.5. The spring blocking device was; 'not .i properly. inserted into the holes in the spring guide shaft.
It was
! i
-. _ -. .- ) ' a
18 i j inserted in a vertical plane when it should have been inserted in a horizontal plane.
Then, when the manual closing latch was operated, the blocking device was locked in the wrong position, preventing insertion of the manual charging handle.
The breaker was in a partially closed position, and could not be opened or closed by any normal means. Work on the procedure was stopped, and it was ultimately decided that the breaker would be disassembled for use as spare parts.
A new work request (C002708) was initiated to perform MI 10.4 on another spare circuit breaker.
During the third week of the inspection, the NRC team witnessed the performance of MI 10.4 from step 6.4.5 to the end. The . same craftsmen who did the prior work successfully completed the i , procedure. Adjustments to the main and arcing contacts were needed, and easily made, j Performance and witnessing of the work revealed several problems with ' i the procedure itself. For example, in at least two cases the sequence of.
steps needed revision.
Step 6 3.19, " Tilt circuit breaker to upright position," should be moved to af ter the steps dealing with the main toggle link pin (6.3.20 - 6.3.25) becauie the pin can only be reached when the . breaker is on its side. Step 6.3.32, " Inspect grounding stab for abnormal damage," should be moved to when the breaker is on its side because the ! . grounding stab is under the circui; breaker. Step 6.5.7, which is the key step.in the puffer test, should read "0 PEN breaker while observing cloth on each puffer," rather than CLOSE breaker.
Step 6.3.29(c) should be deleted because it calls for inspecting the adjustment nut set screw on the stationary main' contacts 'and arcing contacts, but the stationary.
contacts do not have adjustment nuts.
Problems of a similar nature-to those just described. were identified with other. individual steps.
The problems led the NRC team to the conclusion.that procedure MI 10.4 had not been -properly verified and validated.
The team also noted that the procedure had gone past its required biennial review.
The procedure's last effective date was January, 1988. The licensee was-in the process ~of.
reviewing the procedure and finding numerous problems.
} Other preventive maintenance work witnessed by the NRC. team was: Surveillance of fire detection equipment- - 011 leak check of the governor on one diesel generator - Check of the " Fail-to-run-relay"' and associated annunciator on one - diesel generator
p - This work went smoothly according to plans and procedures, no problems ' owerel identified.
! Trainino and' Qualification ! Problems observed during the conduct of MI 10.4, described in (e) above, I indicate a possible problem with the training and qualification process.
- The two individuals performing the PM held qualification cards for the ! } i
. .
work they were performing.
They were qualified bv " wavering" in June, 1987, and had not worked the PM since that time r(equalification was, and is, not required to maintain the qualification ard in question. The fact that the craf tsmen were not f amiliar with new steps in the procedure (6.3.20-6.3.25) and had forgotten how to perf um one step (6.4.5) indicates that either some form of requalification or refresher training may be needed, or that procedures should be more descriptive.
Industry-wide Operatino Experience SQN's program for review of industry and in-house operating experience is delineated in Nuclear Power Standard, STD-1.3.1 (SQA-26), Managing the Nuclear Experience Review Program.
The NRC team concluded that this program was effective, because operating experience information has, in most cases, been properly reviewed and incorporated into the maintenance program when appropriate.
This conclusion is supported by the following specific facts: Early in plant life, failures of a part in the 6900 volt circuit - breakers were experienced at SQN.
This part is called the main toggle link pin, and PM procedures were revised to include an inspection of the pin.
If the inspection revealed cracks, the pin was replaced thus avoiding probable failure in service.
Special Maintenance Instruction - SMI-0-201-2, Westinghouse Type - DS Breaker Inspection, issued March 30, 1990, provides detailed steps, inspection criteria and corrective actions necessary to ensure the subject circuit breakers are free of improper control wiring connector crimps and spring release device binding. SQN became aware of these - potential problems through INPO, NRC and Westinghouse Electric Corporation correspondence.
They planned to perform the special inspections in conjunction with MI 10.5. At the time of this inspection (90-25), about 45 such special inspections have been made.
The recommendations in NRC Information Notice 87-61 dealing with - W-2 cell switches used in SQN's 480 volt switchgear were incorporated into the PM procedure.
The problem of ferroresonance in high-voltage. transformers described - in NRC Information Notice 88-50 was correctly addressed by the reviewers.
Design problems discussed in Condition Adverse to Quality Report - BFP 880394 (Browns Ferry plant) was correctly evaluated for applicability to SQN. This problem involved the defeating of diesel generator breaker cont ol logic and operation of the anti pump circuit.
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_ _ _ _ - . . _ _ - _ _ _ _ ___ . .
, One nuclear power plant reported the widespread failure of silicon - bronze bolts used to splice bus bars in motor control centers manuf actured by General Electric Company.
The cause was identified as stress corrosion cracking (refer to NRC Information Notice 88-11 and INPO Significant Event Report 88-12).
In response to thi s information, SQN carried out a sampling type inspection plan to inspect its MCCs and 480 volt switchgear. It was found that silicon bronze bolts were not used in this equipment, and therefore, the problem does not exist.
INPO Significant Event Report 87-14 describes documented cases that - occurred at opet ating nuclear power plants where ITE SHK switchgear failed due to loose mounting bolts on the charging motors. Review of the files at SON by the NRC team revealed that this item was closed at, the time of initial screening, because the maintenance procedures already had a step to check the chuging motor mounting bolts. The revision of MI 10.4 reviewed by the NRC team did have this step.
On July 31, 1990, Baltimore Gas 'and Electric Company notified the - NRC, pursuant to 10 CFR Part 21, regarding defective wire lugs (size 4/0 AWG) which were distributed by Thomas and Betts Company.
INPO Operating Experience Report (GER) 90-4089 discusses the same subject.
SQN.had the OER in-its Nuclear Experience Review Program files.
Response actions are ~ on hold pending issuance of further details by the NRC.
Motor Maintenance The Motor Preventive / Predictive Maintenance Summary Sheet (Table 2.d.1) summarizes-the. maintenance program for-three safety-related motors., The program is almost identical for the three motors, and would be typical of any large' safety-related motor at SQN.
Individual program elements were verified by'the NRC team by confirming that procedures and scheduling were in place:, 'For-the high potential test, historical records were reviewed to' confirm that the program was carried out.
l Some of the. PM items = listed on the summary sheet are very basic to any maintenance c program, such as oil level check, oil change.and-insulation resistance test. Winding and, bearing - temperature monitoring, sophisti.- cated ' vibration-analysis on a routine' basis and trending ' of ; measured-variables have become quite common practice in the nuclear industry.
Other items, while. recommended, are not so widely employed.
Fallingfinl this' third category would-be current monitoring, oil: analysis, thermo-graphy, high-potential testing, and winding resistance check.. Inspection and cleaning and space heater check would appear to be basic, but are not o.- done by many utilities today, I i
. .
The motor maintenance program at SQN includes the basic maintenance items.
Insulation resistance test is done by the polari:ation index method.
SQN lags behind the nuclear industry (at least in Region II) in vibration analysis and variable trending. They have the equipment and expertise to do vibration monitoring, and have done it when problems were suspected.
Winding and temperature monitoring have not been done in the past on the ERCW pump motor. On the positive side, their oil analysis, high potential j testing and winding resistance check are beyond what most utilities are doing. Their oil analysis comprises: color, neutralization, viscosity at 100 F and, water and sediment.
SQN performs the high potential test of motor and cable insulation using the step method to 13kV.
The lack of periodic inspection and cleaning and absence of space heater checks are considered weaknesses.
The NRC teams overall assessment of the motor
maintenance program was that the program was satisfactory with room for j improvement.
Interviews ' In the course of discussion with licensee personnel, the NRC team obtained the. following information.
A portion of the maintenance records for preventive maintenance work may be difficult to retrieve or may not have been maintained.
Corrective maintenance records are easily retrievable because they are filed by Work Request Number, equipment unique identifier a and system code.
To remove ~a. safety-related 6900 volt or 480 volt bus'from service requires i entry into' as Technical Specification Limiting Condition for Operation
Action Statement even if the associated unit is in Shutdown Mode. Due to ) ' this limitation, there has been a reluctance to do PM's on incoming main circuit breakers.
The System.- Engineer for the 480 volt Distribution System-stated that he has initiated action to-ensure that all 480 volt safety-related incoming. circuit - breakers (both normal and. emergency i source) will receive a PM by the end of the Unit 2 refueling outage ' scheduled to begin during September 1990.
A large percentage of the 6900 volt circuit breakers have not received a , full PM since 1980., According to.the new program of working one-third of ' . - the breakers 'each-refueling, some circuit breakers on Unit 2 would not receive another PM until September 1993. The NRC team made the point that: 13 years between PM work on a circuit breaker is; a very non-cons'ervative _ interval.. In' response to this comment,-the Maintenance Manager stated that all of the safety-related circuit. breakers (6900, volt) on Unit 2 will receive a = PM; during the next ou g e.. A similar situation exists-on-Unit 1, and. those breakers wilI be worked during. the next outage or before.
Summary of the Maintenance Program for the 6900 and 480 volt Distribution-j Systems and Large Motors i l i , 1^ a ,
____ _ _ _ _ _ _ _ _ - _. _ _____________ _ _ _ _ _ _ _ _ __ . j ' . . .
+ . Condition of equipment observed in extensive walkdowns was good. Based on - a detailed review of preventive maintenance (PM) procedures used for switchgear, the electrical PM procedures have strengths and weaknesses.
I Strengths.were complete scope, extensive verification of steps during performance and common. mode failure prevention concepts employed.
Problems revealed during observation of work indicated that procedures did not receive adequate validation.
Also the' problem with the insulation resistance test steps should have been corrected in the technical review i cycle. The program, in terms of actually performing PM work, has been
poorly: implemented in the past,- especially on 6900 volt switchgear.
A-corrective maintenance record review revealed a slightly higher than average failure rate for the circuit breakers, but no definite adverse trend.. The ' training and qualification process for craftsmen was satisfactory.. To require requalification for craf tsmen or to create a . system for helping foremen know'when a craftsman needs refresher training on 'a ' particular. qualification card could improve the process.
.The Nuclear Experience' Review Program was judged to be effective based'on spot checks and other observations. Motor maintenance is.satisf actory although~ the NRC : team ' identified definite = areas for improvement.
Engineers and managers were well trained, experienced and aggressive.
Tha.overall' , l program.is_ improving'due to management attention and aggressivene:s.
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. \\ Table 2.d.1 ! MOTOR PREVENTIVE / PREDICTIVE MAINTENANCE SUMMARY SHEET ' Component Cooling Wtr.
Essential Raw Cool Wtr.
Auxiliary Feedwater . Motor Data ' Horsepower 350 700 500 Voltage 460 V 6600 V 6600 V Running time ~50% ~50% Standby - Stator RTD/TC's (2) T/C per phase (2) T/C per phase No Shaft bearing Split sleeve sleeve guide split sleeve
Opp. bearing split. sleeve Kingsbury-thrust split sleeve ' Bearing T/C s yes yes Local temp
Recommended 011 290-310 SSU upper 300 SSU 140-160 SSU , @ 100'F lower 150 ' c EQ List No . No No 011.Used 290-355 SSU upper 290-355 SSU-180-240 SSU lower 140-180 SSU (due to higher t running temp) Program
Current monitoring . No- . No No Winding Temp Continuous (alarm) DCR approved to No monitoring make operable ,. ' readout Bearing Temp.
Continuous (alarm) .Same as winding-Logged'by system monitoring engineer ' ' Insulation-Each 18 mo's Each~18 mo's .Each 18 mo's'
- resistance
Vibration No No .No monitoring Have baseline only.
Have baseline on: .on some-one' motor-a / 10il. level check Once per shift Once per shift Once per :.hift 011 enange.. Annual.
Biennial Each R/0 10il' analysis Annual.
' Annual.
Annual-Inspection / cleaning No No-No- - Winding' Each 18 mo's Each 18 mo's Each 18 no's.
p' . resistance
Space l heater ck.
No No N/A.
' . Thermography No . No. ~ Each 18 mo's .; Hi pot Test Each 18'mo'; Each 18'mo's . No ' Var.iable Trending No.
No-No Vendor manual.on Yes .Yes- 'Yes- . file , NOTE 1 - All SSU values at 100'F t i I ' t l.
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l - ! 2.e. 120 Volt AC and 125 Volt DC Systems The function of the 120 voit AC and 125 volt DC power distritd ion systems is to provide reliable, uninterruptable vital power to instrumentation and control systems and components during all modes of plant operation. Each i system. consists of two independent trains of distribution panels and ' associated cabling.
Two independent, vital station batteries for each Unit provide emergency power to the vital AC busses through four ' uninterruptable power supply static devices on loss of normal AC distribution. Battery chargers keep the vital batteries at a high state of charge at all times. A fifth vital battery and charger is available as a substitute for any of the four emergency batteries.
~ INSPECTION The team performed a walkdown inspection of many of the Units 1 and 2 vital AC and DC distribution system and panels -and the station vital batteries.
Process instrumentation racks and panels -were inspected during the observation of in-progress maintenance.
Modifications and _ Additions ' Inst;uction M&Al-7 (Rev.13), Cable Terminations, Splicing, and Repairing of. Damaged Cables, wu used as guidance for performing the walk-down inspection.
The team observed many maintenance activities related to the AC and DC distribution systems, observed selected work activities of the I & C.
craft, and reviewed approximately 25 completed work orders for accuracy and completeness as detailed below.
In thel process of evaluation of the 120 volt AC and 125 volt DC systems, " the. team also evaluated the following general maintenance areas: large number of control room annunciators actuated, I&C control of ' plant maintenance activities, control and calibration of measuring and. test equipment, and. vital DC ground systems.
FINDINGS ( . Walkdown c .The'following deficient' material =and housekeeping-conditions were noted as- - . a result:of system-walkdowns. These conditions were perceived by the team as Levidence of. poor, craf t workmanship, poor. craf t supervision and work f ol l ow'-up, and' poor quality control. Where 'possible, debris was removed .during the-. inspection, , C Vital' Battery Charger 1-S iacked three. of four captive nuts and washers.on the door mounted, Voltage Control. Board. The wiring loom attached toL the board was improperly soldered on the terminals - insulation was burned back, and not all wire strands were mechani-cally secured to the terminals.
Resister R-5 center tap was not properly soldered - not mechanically. attached, and solder flow was c '. . , d
1 poor. The charger input and output power cables did not have uniform hardware attachment methods, i.e., some cable lugs used washers while l
others did not.
' Vital Battery Charger I, AC Failure Alarm Relay did not have all wire - strands captured on its terminals, and insulation was burned back on many of the terminals due to excessive soldering heat when the relay was last replaced.
The wiring loom attached to the board was improperly soldered on the terminals - insulation was burned back,
and not all wire strands were mechanically secured to the terminals.. Terminal point 11 had strands of wire nearly touching (1/32") the i adjacent terminal.
Resistor R-5 center tap wire insulation was cut / burned back approximately 1/2" on AWG 16 wire (3/16" required by M&Al-7).
The charger input and output power cables did not have " uniform hardware attachment methods, i.e., some cables used washers while others did not.
-Vital-Battery Charger III, AC Failure Alarm Relay did not have all > - wire strands captured on its terminals, and insulation was burned '? back on many of the terminals due to excessive soldering heat when the relay was last replaced. Resistor R-5 center tap wire. insulation was. cut / burned back excessively on AWG 16 wire.
The charger input 1 and output power cables did not have uniform hardware attachment methods, i.e., some cables used washers while others did not. Loose " ' hardware (sheet' metal screw) was found in the charger on an elevated- ' cabinet " shelf".
Some vendor supplied lugs were improperly soldered in that the wire was through the lug barrel to the lug terminal. Two abandoned power output cable lugs were installed in the charger (from , a temporary jumper previously_ used), but no tracking mechanism for the " temporary alteration" was employed to assure their eventual removal.
. Vital Battery Charger V had residue of'a recent repair (wire end 1.5" - long and solder droppings) on top of the unit transformer,
The team was advised by the licensee that based on tne large numbers of soldering deficiencies that the licensee had detected during ~ inspections and surveillances-that significant changes in craf t performance were ' required. to turn the condition around.
In late 1989, - the licensee-prepared a-new -Standard Practice ssp-6.13~, Field Soldering. for ' Electrical / Electronic Components, and schooled (classroom and laboratory) ' electrical and I&C ' craft in proper soldering techniques according to the procedure.
The procedure included a Manual Soldering Data Sheet s ( Attachment' 2) that' listed acceptance criteria -for-solder joints.
The team ' inspected a _ Work Request (B773859),. performed after the above- ' corrective - actions, that replaced indicator lamp sockets (including-soldered terminals) on emergency diesel-generator board 2A-A.
The solder joints did notidisplay any of the adverse characteristics noted in the vital battery chargers (which had been performed before the new reocedure and school were-implemented).
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26 L , Distribution panels exhibited the following unacceptable conditions: Vital Battery Distribution Board I, Panel 1, contained significant - copper shavings in the board on the hori:ontal surfaces, on fuses, and on the floor.
Discarded fuses, tie wraps, and a conduit plug were also found in the panel.
Fuse clip bolts did not have thread ' engagement adequate to engage the nylon in the locking nut (common to all bolts, all DC boards).
Vital Battery Distribution Board I, Panel 4, contained similar trash L - ! in the bottom of the board.
Wire chase covers were missing, and hardware for chase covers were loose and/or missing. Improper thread > engagement was noted on the chase rails at column C/D.
One attachment nut (of about ten, between column A/B)) was missing from one field cable frame in the panel cabinet.
A pull rope had been left discarded in a conduit entering the top of the panel.
Vital Battery Distribution Board IV, Panel 3, contained significant - copper shavings in the board on the horizontal surfaces, on fuses, ! ' and on? the floor.
Discarded fuses were also found in the panel interior.. At least one cable entering the top of the panel was noted to be in significant tension across a chafing edge.
Terminal block.
covers were not properly secured, i.e., fastening screws out and/or loose.
Vital Battery Distribution Board IV, Panel 4, contained significant - -amounts of trash in.the bottom of the panel, including discarded name plates, tie wraps, and fuses.
Several terminal board covers were missing captive hardware.
120 Volt AC Vital Instrument Power Board 3-II, contained significant - amounts of trash in the bottom of the board, including screws, discarded cut off tie wraps, and tape ends i Breaker bus bars had not been properly insulated (tape wrapped) following breaker replacement
'in several.-places.
120 Volt AC ' Vital Instrument Power Board 2-II, contained significant
amounts of trash in-the bottom of the board, including - a conduit plug, discarded conduit insulation, discarded cut off' tie wraps, cut off wire ends, and tape ends.
Terminal board covers were not - properly secured. 120 volt AC interior lighting cables (X,Y cable at TB2) were not labeled, q 120 Volt' AC Vital. Instrument - Power Board 1-III, contained large ' - amounts of trash in the bottom of the board,-including conduit plugs, i discarded conduit insulation, discarded cut off tie wraps, cut off-I wire ends (long enough to short across terminals of a transformer in the; bottom of the board), discarded lugs, and -tape ends.- Although not. a safety hazard, 'it was noted that many cut tie wraps were lef t . in place around wire runs, and that tie wraps with several inches.of _ ! ! l l ! ,
r ' ..
< , excess cinch material were also left in the board.
In all AC boards (significant problem) and several DC boards (lesser degree), field wire was not stripped of its outer jacket once inside the board, thus wire chases were filled to " overflowing", and chase covers were - discarded in the board or missing altogether. Terminai board covers were not properly secured.
Cable 2M3499, SNN 0001;l had an improperly installed Raychem splice.
A large step laoier, not in t use, was found unsecured (but tagged) adjacent to the vital ! L switchgear.
During.the walk down inspection, 'the team noted that metal grinding i ' - operations were being conducted on the floor immediately adjacent to (vital AC/DC) Inverter I-3.
Sparks _ and grinding grit were being discharged.directly under the inverter -into the upward flowing, cooling air stream.
The licensee initiated an event investigation (Report # 11-90-085), and concluded that no systems, structures, or
components were adversely affected by the incident.
t 120 Vnit AC Vital Instrument Power Board 2-III, contained trash i ~ -- similar to that described _above.
In addition, it. was noted that . auxiliary ' contact leads were lifted off breaker 017 to prevent undesirable control room alarms.
The 'same conditions existed on .. '" breakers 006, 012, 045, and 046,in Panel 1-III. Breaker 017 provided power _ to Panel 2-M-10, the Post Accident Sampling Solenoid Valves; , the. other breakers were labeled as spares.
This condition was ' implemented under AI-58 (Rev. 16) - Maintaining Cognizance of l Operation ' Status - Configuration Status Control.- The breaker 017 leads and 3 of 4 of the spare breaker leads were not ' tagged nor insulated. 'Al-58 was silent on the_ subject of tagging or insulating < 1such leads, which the team perceived as a program weakness.
"g ' Instrument Power Distribution panel -2B, also-contained trash'in the - bottom similar to that. described above, A 15' length of cable pull rope was found in-a conduit at the top of the panel,'and a discarded s . h cigarette. butt was found - on top of' the ' panel.
Electrical . ' discrepancies-included a breaker cavity covered _only by high pressure , tape and termination problems'as follows: !
Breaker 17-feeder cable wire strands were ' splayed with one strand of about six not properly. captured..
Breaker 14< feeder' cable insulation cut back too far,- approximately _5/16" for AWG 10 wire - ["3/16" (+ 1/16") Maximum'- Distance" permissible by M&AI - 7).
l Wires splayed and-not all captured under terminal. screws on the terminal boards at-the panel top (terminals 6 and 24).
' Insulation cut back too far (1/4",' AWG 20 wire) on terminal 24 (same requirements as above).
- r { l
. -_ - , ,
Vital battery and battery room conditions were not optimal for their > function as follows:
Batt;.y Room I contained a temporary space heater on the floor
imrediately adjacent to the battery rack.
The space heater was
socured to an adjacent stanchion by a loop of chain of approximate 20' length, presumably to provide seismic restraint, but f ailing the - , function totally due to the chain length.
Numerous cell jars, including 28, 29, 30, 31, and 32 had significant amounts of dirt and trash on their tops (wood chips, tarpaulin thread fines, etc.). Cell 51 had heavy verdigris growth on terminal connectors.
- Battery Room 11 had numerous temperature probe caps that had been
knocked off the jar ports by workers erecting scaffolding in the room.
The flash arrestor (" pre-vent") cover on cell 46 was totally deteriorated.
Numerous cells were excessively wetted on the jar surface.
- Battery -Room III - (and Room V) contained a sink that was not
seismically mounted like the sinks in rooms I, II, and IV.
Heavy ' verdigris was noted on cells 13, 19, 29, 30, and 39.
A metallic " nut" of approximate 1" diameter was found submerged in - the
electrolyte (on, top of the cell plates) of cell 60. Heavy corrosion was noted on the intercell cables at cell 11 and at 51.
The vendor supplied: cables appeared to have. no oxidation preventive paste, and the cable insulation had relaxed such that as much as approximately 5/8" of' exposed cable _ was observable at the terminal lug (M&Al-7 required a " Maximum Distance (of) 3/8" (+ 1/8")").
- !
_ Battery. Room IV flash arrestor pre-vent covers were totally ' deteriorated on. several cells, including 33, 37, 43, etc. Cells 30 and 33 had significant verdigris growth.
Cell tops 17, 31, and 34 were very wet.-
- Battery Room V had significant amounts of paraphernalia unsecured in i
'
- the room. including buckets, chemicals. and a drop cord. The walls of
.the room were' extremely. paint _ blistered, and the paint was
accumulating in piles on the floor (could possibly plug floor drain).
, For the above discrepancies, the system engineer accompanying the craft and inspection team took prompt corrective action by preparation of work
- requests.. The effective support to the craft, detailed system - knowledge
, and expertise, and high motivation of the system' engineer was perceived by- ' t !the team to be a licensee strength.
1 _The inspection team observed the performance of Surveillance Instruction, 1-1MI-ICC-092-N35.1, Gamma-Metrics Channel I' Full Power Alignment'(see paragraph 2.f below). The team noted that the area under and surrounding
the Appendix' R-(Safe Shutdown -Panel in the' back-up control room) Signal-l Processor XI-92-5 drawer was extremely trashy with the residue of the !
L , .
. plant modification (ECN L6186, Work Plan 6186-03) to install the drawer.
b.
Conducting material such as metal saw shavings, nuts, bolts, washers, lugs, and a 1/8" X 1/8" X 4" cut piece of panel were noted.
Abandoned cables, including four foot long signal and ground cables, were not restrained or secured in the cabinet.
Non-conducting material such as tape ends and cut tie wraps were also in the Appendix R panel.
l The Gamma-Metrics Wide Range Amplifier, Assembly.XM-92-5001A, (small cabinet separate from the Appendix R panel) contained small amounts of paint and metal chips on most horizontal surfaces, residue from drilling holes for cable penetrations.
Other process instrumentation and protection panels observed by the team had similar problems,- but to a much lesser cegree.
Unit 2 Solid State o Protection System (SSPS) cabinets were noted to contain dust sufficient to make small " balls", cut-off tie wraps, tape ends,'and conducting material such as cut wires and lugs (noted during the performance of SI 90.82, Reactor Trip Instrumentation Monthly Functional Test (SSPS)). Process Control System, Control Group 1, Rack 14, contained dust sufficient to be rolled into " balls," a rubber glove, and metal shavings, probably f rom drilling performed during conduit installation above the panel. A reddish oil, probably thread cutting,1ubricant, had. formed a small pool on a module in.the cabinet, after dripping through ventilating screen at the top of. the cabinet (these conditions were noted during performance of $1-269 Channel Functional Test of ESF Instrumentation for. Automatic Switchover to Containment Sump (monthly)). .The craf t/ supervision initiated appropriate corrective actions to clean '~ ffected panels.
a The team was concerned about the material conditions of the low voltage panels as discussed above.~ As a. result of the magnitude of the problems, g the licensee initiated a. Condition Adverse.to Quality Report (CAQR I
- SQP900326).
This problem is discussed further in-paragraph 3.a below.
. Review of Completed Work Request o - The. team reviewed the series--of maintenance management system -standard ~ . practices,(SQN-PMSP-6.2 X) prior to their review of closed and active work requests..The team found.the procedures to be detailed in nature, with specific assignments of responsibilities 1.n all areas'related to the work request process.
Approximately 25 completed. work requests for the 120 volt AC and 125 volt .DC systems were reviewed. During the reviews, only minor discrepancies in
4 the work order ' process were detected.
In general, the up-front planning was '- good with' adequate references and work instructions.
There was evidence 'that. the craft provided good documentation of actual work accomplished, and M&TE and materials used.
Post maintenance testing was ! j
~ l e ' p L i . ., L I h
V , ! found to be adequate in the WRs reviewed. Close-out reviews were timely h-and substantive.
Representative examples of the types of discrepancies found in closed WRs included the following.
. !. WR B758944 repaired the N-31 NIS Soure2 Range Monitor.
Step 9. of - the work instructions disconnected the energized high voltage power i supply from the high voltage cable connector (after testing for proper monitor response) before removing the instrument power fuses, t Step 7 had properly ordered the steps by connecting the high voltage
cable before reinstalling instrument power fuses.
No cautions were included _ in the work instructions concerning working with energized equipment.
To the credit of the licensee, a WR post maintenance reviewer - detected the replacement of a circuit card in.the monitor drawer as outside the scope of the originally authorized work. Additional Post- , L Maintenance Testing was prescribed as a result of the scope change.
< ' . WR B795167' reversed the action of auxiliary contacts 15 and 16 on a i - . reactor trip bypass breaker (BY-4), i.s...as received from the vendor o l af ter. overhaul;;the contacts were configured as "A" contacts, but , were' supposed to be "B" contacts. There was no evidence in the WR of b notification to the vendor or initiation of failure analysis.
The.WR Work Order Form would f requently not have all appropriate i - blocks checked, e.g., B250382 did not indicate whether Solid State Protection System (SSPS) repairs were LCO related by checking the F proper Yes/No block.
Vital DC System Grounds-The team reviewed the licensee's evaluation of NRC Information Notice No.
' a' 88-86, Operating With Multiple Grounds in Direct Current Distribution- -
- Systems,..the installed ground system, and the response actions to detected
. grounds.
[ The' installed system imposed a 10,000 ohm resistance (TVA Contract 7C02-c " 75134, drawing 001490) in series with a D' Arsonval meter movement from i , both. positive and negative legs to ground. The imposed grounds were large.
< .enough,=1.c., greater than about 5,000. ohms,.such that sufficient ground .t loop current.was not available to permit inadvertent actuation of sol.enoid.
operated control valves, the subject of the Information Notice. Thus no i specific action was required or taken by Sequoyah Nuclear Plant (not already planned) in response to the Notice.
The team also noted in its review of the ground detection circuitry that the Ground Indication Relay was set to actuate at ",...normally 60 percent-, of the end scale voltage."
The "end. scale voltage" for the vital DC . !
I [.
i . <
'.
T system was 150 volts DC, thus the control room alarm activated at ! ,, approximately 90 volts (9 milli-amperes of ground loop current), well J below expected solenoid actuation currents.
On receipt of the alarm, or
when noted-by meter reading at values' lower than the alarm set point (e.g., 50 volts), work requests were generated to begin " chasing grounds".
The alarm relay and ground indication meter was included in the station's periodic calibration program at an 18 month' frequency.
l o Based on the above. findings, the team concluded that the licensee had i performed an adequate review and response to the -information notice, and i had an-effective method _ of managing and responding to DC grounds on the
station vital batteries.
. _ L - i . 2.f. Miscellaneous Maintenance Work Observations p INSPECTION
The team' observed the below indicated maintenance work activities related
to1other systems:' , J Maintenance-Work '
[_ Document 10-Description of Activity Observed ' ' WR C011684 ' Plugging of condenser tube , Leaks during power (12).
PM 03051-1-000 Centrifugal Charging Pump 1AA ERCW Gear DRV 011 Cooler. Examined for blockage due to corrosion products, r I PM 030'53-1-001 Centrifugal Charging Pump 1AA J-ERCW GearLDRV 011 Cooler. Examined for , , blockage due to corrosion products.
.WR B75312' 2C Screen Wash Pump: (Condensate ' System) Pump Impeller adjusted to i develop adequate' pressure to allow
- filtering screen _to_run'
- -0verhaul'of Service Air 1 Compressor "A" + ~ " Walkdown of the emergency diesel - . generator. building Walkdown of New Make-up Water Treatment: - Plant (NMWTP) C'000837 Seal replacement and realignment of
Neutralization Tank Pump #43 - 0-PMP-928-43 , ,. i t s I
._ _ __-________ _. ., , . s .
. l
l . C 001879
- 3 Heater Drain Tank level control
' valve replacement 1-LCV-6-106B i C 002760
- 3 Heater Drain Tank level control i
valve replacement 1-LCV-6-106A
SI 1-MI-ICC-092-N35.1 Gamma-Metrics Channel I full power
alignment FINDINGS ! WRs'C011684 and B75312; PMs 03051-1-000 and 03053-1-001 During the observation of these WRs And pMs, the team noted that - , maintenance supervisors coordinated and supervised the work activities very effectively. Work instructions were clearly written and ef fectively performed by certified personnel, system engineers and engineering aids also monitored work activities.
Operations, chemistry, metallurgy, and , NDE fexaminer personnel were part of. the " maintenance team" t o perform ' specific work instructions and all were very knowledgeable of their
specific responsibilities when interviewed by the team.
Safety: precautions were effectively considered and carried out, however, one !
- human er discrepancy was noted by the team during -the examination of
, the posted list of safety precautions to be taken prior to entering the~ 2C
water boxfof the condenser. The team observed that the' list required use ( of a safety belt when standing on any supports inside.the' water box. An engineering aid was already in the box and standing on the support when the team observed this requirement. The job was immediately stopped until safety. belts were obtained,. It was later determined that the height of
- .
the, support was insufficient to require a safety belt. The staging craft' was notified and the posted requirement deleted.. The team was-concerned, however, that even though extensive safety requirements had been' invoked
the. personnel directly concerned had not reviewed the posted requirements . prior to entry.
Another safety concern noted. by the team was the apparent disregard of-a ' sign on the entry point door to the auxiliary building notifying entering l x personnel that safety. glasses were required. 'Approximately 1/3 of the people observed by the team were not wearing' safety glasses when entering.
Plant; management acknowledged the problem stating that the posting ' of ' _ control areas 1for safety glasses was a new' requirement that has not been " ef fectively enforced to date.
The team also noted a lax attitude about wearing other safety equipment, e.g., hearing ~ protection and hard hats.
Discussions revealed that-the safety staff has been reduced significantly L - and many responsibilities transferred to the maintenance ' department.
Further review of the safety records revealed an' adverse trend for the , maintenance department' for recordable injuries.
Fer 1988, there were 11 ! injuries, for 1989 there were 26, and at the time of the inspection there I l were:already 26 injuries for 1990.
i
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p -
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, F [ i Overhaul of Service Air Compressor "A" ' The team observed maintenance work in progress on the non-CSSC Control and . Service Air compressor "A", This compressor had blown a head gasket and !. because of this problem was undergoing a complete overhaul.
The work observed included disassembly, inspection of as found and replacement parts, and reassembly.
By observation and discussions the team i ascertained that the craf t were suf ficiently trained to perform their j: assigned-tasks.
. Supervision was following work progress and provided jt guidance as - required. Work instructions were provided through the work package and the vendor's manual which was located at the work station.
'
Replacement parts retrieved from stores matched those in the parts list of the vendor manual. Data sheets with signoffs for specific milestones were initialed as required.
Upon work completion, the compressor was F functionally tested and returned to service.
As a followup to this " activity, the team reviewed the following PMs performed from 1988 to the present.
PjM Title Frequency L: 2367-70 Proventive Maintenance on Weekly but e Compressors.
Reference NRC, performed daily.
-Generic Letter 88-14 .0171 Change Intercooler Filters Bimonthly 0155.
Change Intake Air Filters Semiannually ic F 0310* Preventive Maintenance Annually [ Performance = l
- This.PM was used for the overhaul.of-Compressor "A".
, [ E The maintenance records wert found to be in order and indicated that the required maintenance work was performed in a timely manner.
!
Emergency Diesel = Generators-The inspectors observed that on. the eight Emergency Diesel Generator " Engines, the oil sample clines 'are 1 1/2"' pipe by 48" long to the sample .- ." valve,. and the sample: size is one4 liter. -The licensee was questioned as to whether the current methodology provides a representative sample. The 11censee's reply 'was that the pipe will be flushed by drawing off sne- ~ ' ,' liter and a second liter will-be taken and sent off for analysis. SI-102 M/M will be revised to reflect this method.- ,
,- .
34 ,, New Make no Water Treatment Plant .
The team's walkdown of the New Make-up Water Treatment Plant (NMWTP), lower level, found scaffolds still intact at the job site after work was complete. Permit Nos. MS 3281 and 3506 indicated that the scaffold permit had expired. The licensee responded by removing the scaffolding.
Furthermore, on the lower level of the NMWTP, the following discrepancies
were found: , 0-PMP-928-0009 - Ground strap disconnected 0-PMP-928-0011 - Pumo casing leak , 0-PMP-92P 0013 - Excessive leak at gland seal ' . 0-PMP-928-0044 - Seal leak , The team observed that work request tags were not attached to any of these pumps.
When questioned by the team, -the licensee's response was the discrepancies noted were already known and WRs for these items were written, in planning, or in progress.
They did not know why the pumps were not tagged.
At - the time of observation, the Neutralization Tank Pump ' 0-PMP-928-43 j
rep 61r. was in its second cycle of rework of mechanical seal leakage repair, When the seal was first replaced, it leaked down the pump shaft, requiring the pump to be disassembled two more times before the source of-the leak was identified.
It was discovered that seal flush / cooling piping was not connected at the correct location on the seal housing. The team a believes attention to detail was lacking in. performance of this .'_ maintenance action.
In addition._ the craft mechanic was not task " . h ' qualified to replace the pump mechanical seal or perform coupling and shatt alignment as per Nuclear Employee Training - Periodic (NETP).1 The j " licensee stated that the mechanical maintenance machinist foreman was at ' u the job the entire time work w:.s being performed. The foreman. was task matrix qualified; therefore, the mechanic was being adequately supervised ,
? in the performance of the task.
i
- 3 Heater Orain Tank Level Control Valve
- , The team observed various portions of #3 Heater Drain Tank Level Control Valve repair / replacement 1-LCV-6-106 A&B.
This WR. was written by the
System Engineer on 7/11/90 when the stem assembly on "3" valve had-rotated in the coupling block.- On or about 5 August 1990, the valve plug - separated _from the stem.
The valve was subsequently removed and a new' valve was procured.- The valve was calibrated by' the Instrument Maintenance - Department and the vendor representative was' on hand for..
technical assistance.
The system engineer and craft foreman' supervised all' stages of: set up and installation of the new "B" valve.
"A" valve was removed and a new valve' installed in like manner. During the observation . of this task the inspectors noticed that the craft practiced good work - habits, work procedures were available and followed, and housekeeping -'and-
t
. .
. + cleanliness were well maintained. The completed work package was reviewed and appeared correct and complete.
Surveillance Instruction 1-MI-ICC-092-N35.1 (Gamma-Metrics Channel 1 Full i pnwer Alignment) ', The team observed the 1&C craf t performance of Surveillance Instruction 1-Ml-ICC-092-N35.1 (Rev.0), Gamma-Metrics Channel I Full Power Alignment.
' The equipment was recently installed as a major plant modification, and the effective date of the procedure was 27 May 1990. During performance - ' of the procedure, several procedural inadequacies were noted that led the team to.the conclusion that _ validation efforts in the ' procedure enhancement program needed to be improved. Notwithstanding the errors in , the procedure, the technical accuracy and content were adequate; the errors were a result of inadequate procedure validation.
The following examples high-light this conclusion: Paragraph 4.3, Tools, Measuring and Test Equipment (M&TE), Parts and - Supplies listed only a Digital Multimeter. Step 6.2.2 (17] required i the use of an-extender board for circuit card A2 -which the technicians forgot to bring.to the job site.
The alignment was.
stopped while another technician was contacted who brought the card ' to-the job site.
Paragraph 4.4 [3] installed " orange stickers" (status indicators of ' - the instrument - under test) on indicators, status lights, and i >;. annunciators at the panel under test, in the control room, and in the . backup = ( Appendix R) control room.
The groupings of the sticker ,
installation listed in the - procedure was not in a logical or t efficient order of moving from board to board, iL Paragraph 6.2.4 ~ [4]- placed the Operation Selector switch in various - ' positions dictated by a procedure ' data sheet, and recorded vo1tages , at the required position. Upon completion'of switch positioning, the- ' ' selector should have been placed in;the Normal position. This latter . step was. omitted from,the procedure at the. appropriate. place;. the - step was vaguely covered at the end of the -procedure during ' final 'o restoration checks.in-. paragraph 7.2 [5] where the-technician was ' directed to " Ensure".the Operation Selector switch'was in the Normal.
position.
Paragraph 7.1. [2] ~ required a verification that.four' indicator lamps.
- + and annunciators were : "NOT LIT" during restoration from the ' alignment.
The not lit condition -was-appropriate only if the power.
. ! level was below 25% for two of the' four lights, and below-20% for one of.the four _- lights.
During the alignment', the plant was at high.
power; thus it was appropriate for the lights to be ' lit.
The
. .-. , I ' , i j a
i procedure had to be stopped at this point in order to effect a procedure change to permit the testing to complete.
g.
Four other changes had to be made by the licensee in the succeeding - restoration steps as a result of performing a substantive review precipitated by the required changes described above.
I The team reviewed the procedure for " preparation of procedures", AI-4 <' a' (Rev. 82), Preparation, Review, Approval and Use of Site Procedures / l Instructions, and noted at paragraph 9.6.3 the following guidance, "To ! ' ensure mis are clear, workable, and not cumbersome in their use, a validation or verification (V&V) of each new instruction will be performed - ,. as determined by the responsible secticn supervisor.... Validation and ' verification being defined as follows: e Verification " Walk-Through" or Simulation of Procedural Steps conducted-prior to approval. (C 8) ,_ , Validation - Actual Plant Performance or " Staged Performance" (Use of
- -
" Mock-up".or " Backup" Equipment) conducted after approval. (C.8)" The team noted the following guidance from NUREG-0899, Guidelines for the e Preparation ~ of Emergency Operating Procedures, and NUREG-1358, Lessons > Learned From. the Special -Inspection Program for - Emergency Operating Procedures,.to be applicable to this case.
Section 3.3 of NUREG-1358 stated, " Verification is the process of checking that the procedures are technically correct, that there is.a correspondence between the procedures ' ' and the hardware, and that the procedures accurately adhere to the guidance found= inithe writer's guide, Validation. is the process of T" exercising procedures to ensure they are usable, that' the language and " A> level of information is-appropriatefor the people for whom they are intended,' and that the procedures will function as. intended." ~ The NUREG w, also provides guidance in accomplishing the objectives of a "V&V" program.
~ ' - . B . The ' teamL found that NUREG-1358 and AI-4 requirements are not consistent.
'e , and 'the-guidance,of when to perform V&V. was. discretionary.
Similar. i . program-problems were-noted with Surveillance Instruction SI-1 (Rev 27), ' Surveillance Program'.. t ,,7' , . Based upon the above' findings and similar findings in'the. area of breaker PMs-(see paragraph 2.d ~above), the team concluded that the. program for
' writing procedures and.for initiating procedure changes. required ' , strengthening-through; improvements in the verification. and'. validation program, and improvements.in implementation of the program to correct the.
, ~ bserved weaknesses.' o q Another area of concern to.the team thatiwas identified. incident-to the above required changes-concerned the changes themselves. To the credit of the' technicians, testing was stopped because 'they could not comply with the procedure as written.
In each of the changes required, it was clear.
- t . what the problem was, what the change should be, and that the change was < ,
. . e .
j .
"non-intent".
Notwithstanding, a significant delay (approximately 36 hours) was incurred in executing the interim change because on-shif t personnel did not have authority to execute non-intent changes to procedures. The licensee had recognized this restriction and was in the ! process of changing STD-4.4.7 (Rev.1), Acministration of Site Procedures, to permit non-intent changes to be more readily executed.
2,g. Work Order Control, Scheduling, and Prioritization The team reviewed the activities of the planning and Work Control Group (WCG) organizations to determine the effectiveness of their contribution to the maintenance effort.
The WCG was established in early 1988 to coordinate maintenance work and testing activities to minimize the administrative scheduling burden on discipline supervisors.
The WCG reported to the Operations' Superintendent; its two primary sub groups of discipline schedulers and system evaluators _were maintenance and operations background personnel respectively, thus bringing together the-two major functions to properly schedule maintenance activities.. The major functions performed by the WCG were: Review of'all new Work Requests,
Monitoring and control of backlog,
>
Resolution of schedule conflicts that challenged schedule performance, Schedule and coordinate planned and forced outages, ' Communicate current and ' emergent plant activities.to plant management, and .
Minimize impact of day-to-day activities'on control room staff.
- During the review of new WRs, the operability assessment was performed-to determine theLimpact 'on the plant, the priority assignment was made,- and the potential for radiological permits (RWPs) was determined.
Based upon the1 priority, work grouping related to train availability, a tentative schedule date was assigned and passed to the planning group for completion of their responsibilities. 'At the output end from the planning effort, WCG prepared the clearance request rms, adjusted schedules - based on actual planning and 'craf t resourcc liability, and provided ready to work. packages to thel craf t prior. t< ae start _ schedule.: Schedulina for corrective maintenance was a 28 day. rolling schedule based on the "tra n i week" concept and the annual surveillance and PM schedule.
Three day look-ahead schedules "f roze" : the daily schedule, with provision.for emergent priority work s to, be ~ case-basis approved.
The effectiveness:of = ' the.above program was - noted by the. team in statistics provided by the L licensee. ' Percentage completion of the daily work list of WRs,. sis,- and PMs averaged overall - 75% completer on schedule.
This value ~was-up substantially from the approximate-34% prior to implementation of the WCG Lfunction..The team also noted the positive effect on control room.
, I - operations - operators were literally waiting on the craf t to "show up" l' for--the scheduled activity.
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Although the licensee had not completed Individual Plant Examination (IPE) requirements, the results of a site-specific, preliminary risk assessment study along wi' other station PRA results such as Brown's Ferry were being used in t. assignment of work priorities.
The team's review of active WRs indicated no inappropriate assignment of priorities.
Planning efforts were prioriti:ed by the WCG, with assigned schedule dates for completion of the planning effort.
The team noted during its review of active and closed WRs that this type of scheduling contributed to work packages being available to the craf t when other resources were ready.
Planners were normally assigned by promotion from craf t foreman level, thus their-site-specific experience was high.
The team noted that Administrative Instruction AI-14 (Rev. 41), Sequoyah Site Training Program, governed the maintenance production planner training curriculum (paragraph II.J.5.). The listed curriculum was outdated in that the operative procedures had changed significantly from tho.e listed.
Planning staff had changed very little, thus new procedures had been evolving for the most part with existing staff. The stable planning staff was perceived by the team tc be a strength.
Preventive Maintenance activities were of concern to the team. Planners recently were assigned the responsibility of the PM program coordination and implementation. The team's review of several PM activities noted the description'to be very sketchy (problem with the evolution of the PMs).
For example, the " Detailed Work Instructions" for PM 0626, Test Capacitors on Vital Inverters, stated, " Instructions 2-INVB-250-QM-T 2-INVB-250-QP-T 2-INVB-250-QS-T 2-INVB-250-QU-T Test Capacitors for capacitance'and leakage. Replace any capacitors which are more than 10%.from the nameplate data."
This' level of detail was considered inadequate.
Based upon the current-level of detail requiiements for work plans issued to the craf t, most PMs were having to be completely researched (planned) and re-written prior to - issuance to the craft as a work activity. ~ This increased work load had been offset by an increase in staff of only-about five people, thus most planners 'were working considerable = overtime to keep backlog manageable.
Lack.af cdequate staff impacted training and annual leave. The team noted that the licensee had recognized the weaknesses in the PM program and was' in the process,of improving the program.
Based upon the above review and review of completed work request (see paragraph 2.e above), the team concluded that, overall, the licensee had a good program with good implementatiun in the area of work pian preparation, use, and documentation.
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. 2.h.
Technical Support ( o ' During the -inspection, the team had several cpportunities to observe the j knowledge and nerformance of the system engineers, and other technical ' support functions.
SQN Standard Practice SQA16S (Rev. 3), Conduct of Technical. Support, outlined the broad - areas of support responsibilities - assigned to the system engineers. System engineers were expected to be a single point contact of expertise in-all matters affecting their assigned systems, normally one to four systems. Based upon interviews with craf t i and.the experience of the team during the inspection, the system engineers maintained a high visibility in. the field, were very knowledgeable- -concerning their systems, and provided a high degree of expert support to ' maintenance - personnel. .The -team learned that several of the system engineers had attended factory school training with the craft on recent , protection system and nuclear instrumentation modifications.
The team ! . reviewed several industry and regulatory initiatives and noted in all samples that the engineering evaluation was thorough and thoughtful.
< Twoo areas of' concern : to the team manifested themselves during the- ., ' inspection.
System _ engineering:-involvement in preventive maintenance ! (particularly technical justification for deferment) and trending / failure s , f1 analysis could have been more.strongly implemented.
, , Relativeito trending and failure analysis, SQA168 inE paragraph 5.3.4, l " Technical Support Engineers Duties," required.the following of engineers, " Trending important - system' parameters; such as, flow rates, electrical . _'
_ voltages,- and so forth to identify deteriorating. system performance," and - .in. 5.3.30, " Failure. evaluation and NPRDS ' Trends," covered the gamut' f rom , ' ~ cnothing, to plots of representative intercell resistances as a function,of '! time-for. the cvital' batteries.
The team also learned that although the-
- maintenance-departmentthad been regularly producing r'eports of component b
- failures in accordance with SQM58, ; Rev.
7, Maintenance History and , ' Trending (NPRDS every six months for one year window,.EQIS every year), ' } ' . theEreports were ' terminated in" late 1989 because of non-use by system-a ' engineers.
'Thesteam reviewed 1989 NPRDS failure data', andL noted several adverse , , . failure frequencies; including Limitorque operators and Masoneilan i International. valves.
The team was particularly concerned that a 'CAQR.
a . (Condition - Adverse > ton Quality -Report, SQP900122) report had _ just been m irecently prepared in March 1990 that detailed scores of -Masoneilan valve- '! [/ failures that had been.~occurrir,g over the past nine years.
A safety injection system : flow ccontrol valve (2-FCV-63-64) failed to indicate- ~ - proper position-(1:.e., Lit was--indicating both open and closed) in February! - ' , _ ,1990.
The failure twasidue to stem: rotation, which allowed the contact - ~ < > ' ' arm, mounted on'the' stem, to miss the'. limit switch. A maintenance history $ search detected that twelve WRs had been previously prepared for the same Lfailure on thel same valve.
A further history search ecross four systems - (Main Steam, Main / Auxiliary Feed, Chemical and Volume Control, and Safety > l d i -
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Injection Systems) for Masoneilan valves with stem rotation problems , identified'a total of'284 records.
Thel generic problem had made its way to the surface in the form of a y Design Change. Request in May 1988 (DCR 2609), but the DCR was not approved-6 and substantive corrective action lapsed notwithstancing several more ! ,i, failures. during the past two years.
CAQR-SQP900122 was prepared in
p accordance with requirements of-Standard practice SQA186 (Rev. 6), Root - e ~~ Cause Assessment for Adverse Actions / Conditions, to initiate (again) more - [ substantive action.
Root cause analysis codes listed in the CAQR e y were FH. (Equipment repeated failure previous corrective action - inadequate),.and FJ (Design or procedure improvement identified but not yet implemented)p indicating proper use of the codes.
Staffing and procedural : changes were being made by the licensee at the time of the ~ ' inspection to. prevent" recurrence of this type of problem.
The team - concluded: that aif the~ licensee implemented the provisions-of the establishediprograms thatL engineering support in this area would be adequate.
' J 2.~i. Heal.th Physics ('HP) The" team; determined fthat radiological controls were satisfactorily integrated _into 'the. maintenance process.
However, some weaknesses were: . g identified te:the licensee-involving training;for, and maintaining, worker ( collective ~ dosemas'., low 'as reasonably ' achievable' ( ALARA).
Inspection-findings identified in an inspection' of the health physics l program thei , ' 'prec_eding l month areLincluded -in this report where pertinent, and are ' . denoted by the?; report. number.(90-23) in the discussion'. + INSPECTION - , OTeami' members 1 reviewed radiological control. and maintenance data, ' - , interviewed ?licen'seel management, supervisors, and craf t s personne'l,1 and s observed work in : progress'.. , 'HP) training andL qualificationsf of maintenance.and support' personnel were ' ' freviewed. :The: findings _ are 'results of reviews of training records for - .: selected = personnel, supervisory ar.d ~ craf ts interviews, 'and - management- ' interviews ( , ' ' ~ " The team assessed-the-licensee external-and internal exposure controls of , -maintenance; workers.
, J The licensee'sLprogram for. control' of radiation materials, contamination,. -surveys and monitoring"was-reviewed.
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Team members reviewed licensee data and post refueling outage reports > regarding source term reduction, establishment of ALARA goals, and scheduling of maintenance work.
FINDINGS a J Maintenance personnel and HP worked well in the planning and preparation '. of maintenance work.
A review of pre-job and post job work and ALARA reviews -revealed that the majority of work included appropriate radiological ALARA controls and. was frequently performed under the i projected dose for the job. Several former HP personnel were transferred to the maintenance department to coordinate radiological support.
T_he , ' license stated that the use of ' coordinators with former HP experience > resulted in a smooth interface, better quality radiation work permits and si.
radiological surveys, and better informed maintenance personnel.
In interv.iews, maintenance-personnel stated that ~ing the' previous outage, work areas were often crowded which resul in more restrictive radiological controls than if the crowding dit et exist. Specifically, the - use of respiratory protection equipment ar.
the several sots of-protective clothing were - identified as problems - that decreased their i [g efficiency., HP had previously identified these issues in a post-outage. , , ' report and was; planning engineered controls to reduce the levels of loose: x
surface and airborne contamination during the upcoming refueling outage.
, l 4ii HP Trainino and Qualification of Maintenance and Support personnel % w - , j , Team members idetermined -that maintenance and support personnel had. ! - received general employee training (GET),-however, during interviews with' . maintenance personnel,wteam members learned that some personnel had not , . received-continuing annual training during some years. ~ Licensee personnel' T , from training also stated that 'the work ~ 1oad at the plant'- precluded some personnel Jfrom attending scheduled training.
.A review of records showed-that this'was > a problem and' the licensee wasi revising _ traininghinto weekly- ', ! blocks to 'better ensure all maintenance personnel.1were, scheduledito receive : 40: hours of non-technical training a'nd 40 hours of technical straining each year. ' Team-members discussed with licensee personnel' the J - importance of maintenance personnel maintaining their skills;up to'date.
, During a~ prev.ious inspection (90-23),_it was' learned _that the licensee had1 eliminated advanced' radiation-worker-training (ARW)'from the program. ARW , training was supplemental training, that enabled maintenance personnel, to.
y perform 'some ' radiological. functions' ' independently. and provided- '
instructions in how to maintain radiation dose.ALARA. ALARA training"was W targeted for 600 maintenance. personnel but was eliminated after 82 (13%), .' -
- had. completed the-course. Both maintenance and training - personnel stated.
that1they assessed the.ARW program and considered that~this training _could- <
- be better. performed during regular plant' duties. Team members inquired:as i
to what comprised this training and how was the quality and retention of personnel-~ receiving' the training measured.
Maintenance personnel ~ stated- = that-they ~ observed radiological maintenance performance indicators but
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. .as agreed with the team that qualitative measurement was impossible. Team members reviewed' plant training correspondence and learned that ARW
development. started in 1987 to be consistent with many utilities and to provide.-maintenance workers with additional practical training in contamination control devices, equipment for reducing dose, methods to minimize radwaste-volumes, and mockup training.
Reasons for needing the course were: 1) workers - (primarily maintenance employees) were not receiving sufficient radiological safety training necessary for them to work confidently and safely in radiation areas.
(The direct observation made by plant personnel cited worker performance parameters-such as station. exposures, personnel contamination reports, radiological incident _ reports, employee comments, suggestions, and ' concerns, as indicating the need),- 2) -continual poor radiation worker practices indicated need for change, and 3) ARW training addresses lower personne1' dose, improved contamination control, improved worker productivity in radiation' ar'eas, and minimizing radwaste volumes.
The; team reviewed a Maintenance Training Audit performed by the Site Quality Audit' Group dated August 18, 1989. An audit finding identified ' that maintenance planners had not completed the 1 formal. training-program , , ~and were not_ participating in continuing training.
In discussions with , plant personnel,- team members were told. that after large _ cutbacks in the + training. staff that the training center could not support -individual . training sessions. Upon further review, the team discovered that recently
- - hired maintenance planners had not received initial planner training
(basic ace'redited courses) in'the past-year and, that the course was being-developed by'the maintenance planning group;with help from the training center.: : Licensee ~ personnel - stated that courses 'were being developed in-accordance' with the accredited program but would _not-be ready until1 some - , time in'1991.
' Radiation. dose during the previous Unit 1,- Cycle 4_ refueling outage was. high ' and.this was partly -attributed to _ replacement - of the1 Resistancet Temperature Detectors.
The removal. of this syste'm ? and replacement with e one of ' a ' newer -design that - prevents buildup of radiation. hot' spots', in
- itself, is a:long term dose-reduction-initiative. However, problems.were.
Lexperienced during the outage to which the increased collective dose can-be attributed; 1The original method of cutting the RTD piping using saws - was Jdiscovered to be too-_ dose' ' intensive.
The licensee. stopped the -
operation. Plasma are hand' held torches-replaced the.old method,.and pipe: ' cutters, who :had received : no ~ mockup t training _ in plasma arc cutting- , , t immediately experienced : problems.
The change -in direction did not allow- - ' . time for implementation of_ suf f_icient engineered controis -to contain high - levels :of contamination associated with plasma-arc cutting.
Thus, the operationi resulted.in-higher than anticipated collective dose; In - discussion with plant-personnel they stated that had the cutting' operation- 'been1 performed on a. mockup many of the problems experienced could have been identified and resolved-before performing the work.in very high'
- radiation areas.
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The team members determined that the higher than projected collective radiation dose for the year was partially attributed to these weaknesses in the licensee training program.
External and Internal Exposure Goals By observing work the team found that, overall, the licensee provided adequate external and internal exposure controls. Personnel were observed to wear proper dosimetry when in radiologically controlled areas and the areas were properly posted.
As previously discussed, the high levels of contamination were responsible for the large use of respiratory equipment.
The team reviewed Radiological Awareness Reports (RARs) for 1990 and identified that, since the start of the year, 11 separate events had been documented where personnel (maintenance and modifications personnel were involved in seven events) had f ailed to wear assigned dosimetry when entering radiologically controlled areas of the plant.
No significant exposures to radiation occurred as a result of the events.
This was-identified to plant management as an a verse trend that required immediate attention. The licensee stated that-a Condition Adverse to Quality Report would be initiated and appropriate corrective actions taken.
Control' of Radiation Materials, Contamination, Surveys and Monitoring During 'the inspection the team noted that contaminated areas in the RCA were being decontaminated. The licensee had reduced the contaminated area of the plant in the past month f rom 30,612 square feet (ft ) (13.4
percent) to 24,595 ft2 (10.7 percent) of the 228, 940 ft2 radiologically controlled ~ area (RCA).
Source Term Reduction, ALARA Goals, and Scheduling of Work A sufficient amount _ of work was not observed during the inspection _to assess worker awareness and -involvement in the ALARA program however, worker's, when interviewed, appeared familiar-with ALARA concepts.
During the previous inspection (Report No. 90-23, dated June 25-29,'1990), a weakness was identified in establishing the annua' collective station dose' goal.
HP estimated that 912 person-rem would ae needed for fiscal-year (FY) 1990.
Management reduced the goal to 685 person-rem. _At the time of the inspection ~, station. collective dose was 1,075 person-rem and expected to be twice the established. goal at the end of FY 90.
Investi-gation into the reason for higher than projected dose was determined _to'be the-reduction of the annual collective dose goal beyond the design basis.
The higher than anticipas9d collective dose was in part attributed to the lack of managements' leadt rship in controlling collective dose by using the goal process as a managcment tool.
In addition, Inspection Report No. 90-23 documented that a significant - amount of collective dose was incurred unnecessarily.due to the following: (a)' non-critical path work was performed in containment when the reactor
. _ , -- , y; c. f
44 t , t . coolant system (RCS) was drained to allow RTD replacement, the loss of water shielding resulted in an increase in radiation levels of '200-300 3-percent (postulated dose incurred unnecessarily was 46 person-rem); (b) minimal amounts of temporary lead shielding were used on some jobs due to l unavailability, delays, schedule, and seismic restraints (dose cost 15 ! person rem); (c) poorly trained or inexperienced workers (dose cost 11 person-rem); and (d) over crowding in work areas and the large use of respiratory protection equipment due to high levels of loose surface contamination (dose cost unquantifiable).
During the inspection, team members observed that the licensee was developing corrective action plans for approval, that, when implemented for the next outage, should result in reducing collective dose.
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f ' During a review of work in progress, a team member observed that the licensee was-performing work in the annulus,.while at power, to reduce the r work. scope and personnel needed during the outage. Although the work on , the Post Accident Monitoring System (PAMS) was being performed in a low-t radiation-dose rate area (2 - mR/hr average), N-16-' gamma radiatio _n was present in higher levels in the area.
HP stated that workers were
prohibited from entering most high dose rate areas and a review of ' collective dose confirmed this. However, due to large numbers of people, ! ' the collective dose for. personnel _ working in Unit 2 was double what it y , would have been.had: this work been ' performed during the refueling. outage.
"In July, PAMS = work comprised 20 ?ercent of the 10 person.-rem acquired...and i t in' the first 9 days of August,1.6 of the 2.4 person _-rem or 66 percent of q W total' Unit 2 dose was acquired on PAMS work. The team expressed a concern-to licensee management that it app $ared~ that unnecessary collective' dose i ' ly" wasLbeing acquired.
Licensee management informed the team leader that a ' cost versus person-rem: benefit ' analysis had been performed..and :that the' .a result-showed'ituto'be beneficial to peiform the work while at; power.
In ' m% an attempt to Jreview the cost versus, person-rem ' benefit, analysis to j confirm the licensee's finding, the team discovered that the~ analysis had
not'_been _ performed for the work in Unit 2. 'The licensee stated that one q 'hadLbeen performed for PAMS work in Unit 11 and clearly showed a-benefit for/ performing the work at power. The licensee' performed;the analysis for- >
' Unit 2 that showed the'same result.
El Inspection Report No,' 90-23 documented that the primary effort for source- < , , termireduction at Sequoyah was being performed'at Watts Bar=and was in.the m l development stages. -The licensee has taken corrective:actionsl to assemble- 'j a! task committee to? develop a formal source term reduction program at - 'Sequoyah,
=2.J.-Evaluation of QA/QC Inv'olvement in Maintenance 'In ~ general, _QA/QC was adequately integrated into the main _tenance. process as established by review of' completed work orders and review of the two-most recent audits, SQA89913 -dated August 18, 1989-and SQA88815 dated February 3, 1989.
The audit's were very detailed and the findings 'were . comprehensive.
It was - noted that while the program requires biennial ' '
p .: o c .
s ! audits in the maintenance area, at least partial audits are accomplished " 'on a more frequent basis.
In addition to the above, the Quality Engineering. (QE) Branch performs plant surveillance of maintenance activities on a continuous basis.
The team's review of QA surveillance reports revealed that surveillances overall were very effectively run and-the findings were appropriate. However, one surveillance area appeared to D be weak based on the team's findings of poor housekeeping and general material discrepancies. discovered during the inspection of low-voltage , vital electrical panels (see paragraphs 2.e. and 3.a. - for details) and the failure of QE electrical surveillances to have previously identified problems in this area.
However, the team concluded that QA/QC _ organiz.ational structure, level of manning, certification and experience
level :of QC inspectors and auditors, implementation of hold points, ' content and effectiveness of audits, frequency and content of- ! surveillances inspections, timeliness and ef fectiven'ess of corrective actions taken.in response to open items, and trending of results provided-are.a substantial strength in the licensee's maintenance program, . 2~k, Maintenance Facilities and. Equipment . Maintenance facilities - and equipment were inspected by -the team to . determine ' the adequacy of space, arrangement, accessibility to the work, . tool storage and requisition, etc. The team concluded that the facilities provided were adequate and well equipped and arranged for 2 insuring effective-support -of the maintenance process.
Guidelines for material
controls were< reviewed and found to be excellent. -Warehouse storage, receipt inspection,-and housekeeping were_very good. Material review for , T procurementiwas performed by. a staff of 13 engineers. This_ large staf f was apparentlyL necessitated by the lack of a completed master equipment-m - li st.- ; Discussion"with management concerning this issue-myealed that
, funding to study the' implementation of a master equipment list prugiet has ' - - , been included in'the'1991. budget. 'In.the interim, the methods used by the.
~ 1icenseesi for ' material review appeared to be workingf effectively even though) cumbersome.
lhe: team. also observed tool room activities-and selectively. sampled tool issue. documentation.
The 'l i cen see'- has established tool ' issue. and > ' inventory control utilizing'aicomputer data base; equipped withLa bar code ~ reader.' Equipment ready.for issue was orderly stored,J and_ in good workings e - / condition.. Weld rods :and consumables were also controlled -correctly and issued only to. qualified personnel. Wire ropes used?for rigging could: ' ' L only be issued by too1J room personnel who had beenJcertified to do so.
' The team concluded that_ the licensees facilities', control Lof materials and control of tools _and= equipment are' strengths,to the maintenance-program.
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2.1.-Predictive Maintenance 'The licensee's Predictive Maintenance (PCM), program is addressed-in' SSP- ,6.1, Rev. O, Conduct of Maintenance, and more specifically in procedure.
- SQM 57 5, - Predictive Maintenance program.
The documents describe the - p 4.
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't . - _ predictive monitoring activities performed on plant's process equipment or systems - and ancillary equipmer'. These activities included vibration analysis, lube oil analysis, acoustic monitoring and thermography.
Vibration Monitoring - , Through discussions with cognizant personnel and by data review, the ' team ascertained that the licensee is conducting vibration monitoring '! on a very limited basis and that it 'is directed mostly towards t balance of plant equipment having the potential to cause load-l ~ reduction, shutdowns or outage extensions. Work is,pr:loritized in ' , that -outage and support work presently occupies 80 percent -of PDM ' , employee -time.
Equipment monitored under. ASME Section XI o , requirements are checked usually upon request. The system presently
w ' used for' data acquisition is, TEC's Model11325 Smart Meter. - Data is - ' ' obtained manually with the aid of a hand held probe. Vibration data which is the primary IX amplitude and phase component is analyzed and . stored.on.the computer for trending purposes.
' -- Lube 011. Analysis- , The: 111censee's lube oil analysis program is: controlled through procedure-SQM; 57 6, Rev. 0, Lubrication.
According to.this-- . . . procedure, the lube oil program consists of :three main elements, ~1.e.,:. sampling, analysis, and tracking / trending.
Oil samples. are , , obtained, routinely. through the PM program; The predictive maintenance ' < specialist / engineer, who.isiin charge of. this program, reviews the- , < analysis reports' for major changes from-previous samples. Theidata- ]
- is: subsequently documented and trended'to: predict potential equipment
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Jproblems.
Oili sampling can be coordinated with a vibration analysis - ,tolaid in equipment evalua' tion, i. Plant equipment _in the' lube coil , program ; i ncl uded -: al'1 EQ motors, ~ auxiliary building ' chillers, Emain t iturbine-emergency diesel generators, main-feed pumps, and the main-
transformers.' ' i , i 'Through. this review and. discussions, the ' team -found ' that implemen- .tation of this program lacks strength in that the licensee does not' , ';, ihaveL adequately ' trained personnel on ' hand to : implement: the - program y ' " w . and - conduct detailed :L oil analysis in _ ' order s to --maximize - the , L feffectiveness'of this diagnostic tool'. ! ,
- Acoustic 1 Monitoring.
- Acoustic. monitoring is: employed: as a -diagnostic tool.for' the.
, ,' detection of valve = leakage and' loose ' parts. Acoustic monitoring. is i not a proceduralized program and-asi such, the technique (s) used to ! gather and interpret deta is heavily-dependent on the expertise of the specialist; performing a 4/or in charge of.the examination.
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Present PDM acoustic activities include, monitoring the reactor head vent valves to verify main control room indications nrior to mode 2 entry, monitoring the main feedwater long cycle valves for leakage during normal plant operation, monitoring the MFW regulating valves and bypass valves for leakage during plant start-up, and monitoring individual valves for leakage on an "as requested" basis.
Equipment and areas have also been acoustically monitored and analyzed to determine the source of objectionable noise.
Thermography - Thermography is discussed in the licensee's predictive maintenance program, however, this technique is not currently used at Sequoyah.
Conclusion In conclusion, ~ the team found the predictive maintenance engineer in charge, to be very knowledgeable and highly motivated. Data on equipment was well organized, easily retrievable with some trending information available. The team identified two weaknesses of significance.
One is that predictive maintenance has only been implemented on a limited bases since the licensee has not dedicated sufficient resources to adequately - m staff and support this program.
Although efforts are underway-to secure the services of qualified personnel, at present, the program is heavily dependent on only.one PDM specialist / engineer for direction and . implementation of thist program.
Because of these shortages, vibration ' trending is limited to about ' 50 machines.
Oil analysis has been implemented on a very limited bases' and thermography has not been implemented at all.
The other weakness was related to the lack of a regularly scheduled' vibration monitoring program for ASME Section XI pumps and motors.
The team.Lindicated that such a program could provide early . warning signals of - potential equipment problems that.are not readily identifiable under the ASME Section XI program. ' The. licensee =- had recognized the weaknesses ~ in the predictive. maintenance program and issued a two year plan for improvement in the program.
2.m. Post. Maintenance Testing (PMT) The requirements, methods - and responsibilities for cost-maintenance.
testing are_ addressed in Standard Practice SQN-SQN66, Rev 4, Maintenance Management System Pre .or Post-Maintenance -Testing.
This document.
requires PMT evaluations to be performed for all maintenance activities that could affect plant ~ equipment or operability of plant equipment. The onshift. Senior' Reactor Operator.(SR0) is responsible for ensuring that PMT-requirements are completed prior to declaring the component (s) operable.
He may specify additional PMT requirements at. his discretion.
PMT requirements are based on maintenance performed and are specified on the - work order by the Planner who is also responsible for listing the group-responsible for PMT.
Completed work orders which were reviewed by the team and discussed under paragraph 2.b. of this report were checked to
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y i I ascertain whether post-mai_ntenance-testing had been conducted as required.
i The' team. found that post-maintenance testing, when required,- had been .{ . performed with a concurrence verifying that previously established
acceptance. criteria had been met.
The team considered PMT to be a ! strength, both in program and implementation.
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2.n. Vendor Manuals ' Control of vendor manuals is implemented through Interim Standard STO-l 0.1.56, Rev. O.
This document addresses vendor manuals (or portions ! f thereof), their revisions and addenda, vendor pamphlets, and catalogs supplied by equipment manufacturers that address _ design, installation, inspection', operation, or maintenance of-critical systems, structures, and- 'I ' components-(CSSC) equi.pment.
To evaluate.the licensee's adherence to STD-0.1.56, the team retrieved five vendor _ manuals'. involving valves,-traveling screens, strainers, pumps and -compressors.
The team verified. that the manuals 'were being
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controlledL that they. had been updated, and that they were being,used in ' j the conduct of PMs.
2.o.' Check Valves l ' Administrative controls for maintenance and tr.ending of check v'alves (CV), j is-established through ' procedure SQM 72, Rev 0. Minimizing Check Valve i Degradation. -This document addresses recommendations of-INPO, SOER 86-03, l t " Check Valve Failures or Degradation," and references EPRI Report NP-5479, j " Application; Guidelines for Check Valves ' in Nuclear Power Plants.- The
licenseeLuses-the subject EPRI-reportsas a gui.de for CV design: review.
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Assessment' of check -valve maintenance was omade th. rough walkdown / ' inspections; interviews-with engineer and craf tsmen;iand a ; review of.
j procedures,1 maintenance and surveillance records, : and s other~' related! O documents, i.e., design change' notices-(DCN)= ? issued in ; response toLNRC ' j ' Bullet'in 89-02, and Generic Letter 87-06. As: a sresul_ti of thisL nspection- ! i _ , l ' effort the team noted the following: ' s l _1" ~ 565,.?568. and 571 ] ?-- Thermal barrier Ebooster pump: check valves, - + _.. ' A through'0,Ein? the essential raw cooling water / system of Units 1 - > -P and 2 were inspected and the internalsLwere found;to.b'; degraded.due 'l e 'to: erosion. corrosion.
Following an ; engineering Ljustificationi i . l] -(DCN-M02673A/M1200),. which - showed that these three (3")Linch check valves were. ~not necessary for: safe Lsystem operation, the_. licensee ' - . removed the internals and left-the valve bodies in place.
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w . Check valves 70-676A and B in the component cooling system of Units 1
'-- and 2 were - found to cause turbulenti flow conditions because of- ! location and valve design. These-findings were based on engineering i . justi fication. DCN-M0 1204.
The subject valves were identified as_ - .; m three. inch (3")- Anchor-Darling swing. check valves.
Because of the .; ' , ..
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long lead time for new design replacements, the licensee proceeded . with a short and long term fix plan.
The short term fix involved replacement of worn out internals with like design parts.
This effort was performed under DCR-3085 and has been completed in both units.
For the long term fix, the licensee plans to replace the existing swing check design with piston / lift type check valves. This design change will be implemented for Unit 2 during the upcoming September 1990 out. age and for Unit I during the December 1991 refueling outage.
. Main steam line check valve 623 was one of those valves selected for - inspection in response to SOER 86-03.
Because upon inspection the valve _showed degradation, the licensee expanded the sample to include the remaining three similar check valves in Unit 1 and determined that three out of the four valves required repair i.e., parts ' rep'lacement. The subject valves were 32" swing check valves made by Atwood Morrill. Subsequently, the above valves were repaired by addition of weld. buildups.
The three repaired valves were- - discovered to have failed in October 1990, apparently due in large-part to the stresses induced by the welding.
The work in Unit 1 was performed under PM 95014-1-6 MR0-002. During the upcoming Unit 2 refueling outage, the licensee plans to inspect and perform all necessary repairs on the corresponding valves in this . unit.
Also,. through discussions with the cognizant engineer, the team ascertained that, in response-to SOER 86-03, the licensee has evaluated the check valves in the chemical and volume control system that is outside- , the Section XI program.
Twenty-two check valves,-i.e., eleven per unit, .were ' analyzed by engineering to the guidelines of EPRI NP-5479 to-
- determine if-they were the proper size, type, orientation and location '
' -and, whether they were justified by system requirements. Design Nuclear - - Engineering calculation EPM-RSR-101189,- determined that all twenty-two.
1 check valves were deficient in at least one category. However, since most of these valves see low flow conditions and are located in relatively high dosage, areas of ' the plant, TVA ~is ' currently investigating nonintrusive inspection techniques, i.e., acoustic monitoring, to monitor; conditions.
inside the subject valves.
The team concluded that the licensee has a relatively strong check valve y
program.
However, programmatic '. support and implementation could be strengthened.
The team found no evidence to verify that system walkdowns as recommended by SOER 86-03 were being performed and documented on a regular basis.
Also, there was-no evidence of trending check valve failures in a manner discussed in'the program. Therefore, it appears that o-additional resources are needed to strengthen this area of the program.
..
. .
. 2.p. Corrective Maintenance (CM) Backlog The team found that tracking and control of ma'intenance backlog was addressed by the licensee on a routine basis.
Reduction of the CM backlog is a highly visible issue since it is one of the maintenance department's goals and the maintenance management and supervision annual appraisals are tied to their goals.
As part of the effort to reduce the backlog, the Work Control Group holds regular meetings to review open statJs work requests of a specific age.
At the July 1990 meet ing, WRs in the open status of over a hundred days were reviewed.
Persons attending the July meeting from the Work Control Group consisted of Work Control Managers, - System Evaluators, and Discipline Schedulers; also in attendance were Maintenance Planners, General Foreman and Managers. WRs were reviewed for impact on the plant, validity of the problem, and for possible combining with other WRs. The estimated man-hour duration, priorities, status, and' other pertinent data was addressed. Each WR was assigned to a responsible-person for a particular action. Special backlog coding was developed and implemented to allow better electronic tracking of the. WRs. The prime computer generates a report showing discipline responsible for delay, reasons, and status so as to reduce backlog numbers.
The team believes the backlog review program will enhance the licensee's effort in working off the backlog in the most rapid and efficient manner, and considers'it a strength.
In contrast to most utilities who consider the CM backlog to consist of WRs greater than 90 days old, the licensee considers all WRs backlog status until completed.
-The team - evaluated the CM non-outage backlog and reviewed a summary listing of backlog of non-outage CM WRs in excess of 90 oays,. At the time of the inspection,_the non-outage CM backlog consisted of-1217 active WRs.
Forty-(40)~ percent were in excess of 90 days old. Only three of the-WRs greater than 90 days old were Priority 3 (potential to degrade station operation .should start within seven days), all in non-safety related systems, The remainder were Priority 4 (should start within 21 days - can wait for a schedu' led outage), Fifty-three (53) percent of +he over 90 day , WRs were available, waiting scheduling,
percent waiting - tools / materials,15 percent in planning, and 3 percant waiting testing.
The teams review indicated that none of the greraer than 90 day old WRs represented significant problems.
The team found tha'. the non-outage CM-WR backlog was plot +.ed on graphs _for-each ~ mat tenance group; electrical, instrument, mechanical, maintenar.ce support and modifications..The status of available WRs, planning WRs, testing, and tools / materials was listed in fifteen day increments for up to ninety days.
Additionally, the backlog of total open WRs _ was also graphically plotted ior each generating unit; 0, 1 and 2, showing bi-weekly status for a 12 month period.
Non-outage CM WRs submitted and completed, compared with total WRs submitted and completed was graphically-plotted showing semi-monthly for 12 month. . ... . 51- , The team noted that Sequoyah's non-outage CM WR goal was 600 open WRs by
the end of~ September 1990, versus the current number of 1217.
A large
- number of open WRs were found to be made up of Priority 4 " Power Reduction
~ - WRs" that can only be accomplished at lower power levels.
Both units 1 and 2 were operating Lat full power.
Furthermore, with the-sita's - " Attention to Detail" initiative, a greater than normal number of WRs had been generated. The team noted that, in acent months, little_ progress r ' has been made in attaining the September goal.
12 q Control Room Annunciators ! l During plant walk-downs and observations of maintenance in progress, the team became aware of'an extraordinary number of Work Requests (WRs) posted on various' Main Control-Room (MCR) status indicators, annunciators, and alarms.
In particular, approximately thirty such WRs were posted on Component Cooling Water System (CCS, System 70) indications. A review of the active WRs indicated that the required action-to correct _the' reported problem took:several_different forms as-the following examples 1,llustrate: . WR C011807 for U-0 Aux Waste Evaporator Package Outlet Flow (EQIS c . , 0-FS '070-112), The equipment was never used, thus CCS flow to-the ' unit was always isolated, causing the low flow alarm; i.e., abandoned ' or unused equipment.
There were several;of tnese conditions.
> WR C011566 for U-1 #2 Reactor Coolant Pump (RCP) Lower Oil Cooler Outlet-Flow (1-FS-070-108)._ ; The alarm may require a set point change or calibration, or a flow balance may have to be perfo~rmed to assure a ystem. flow; :i.e.,- may.'be -a valid alarm condition proper s
- (temperatures were normal).
There were several of these conditions.
,
- WRfC011578 forLU-1. RHR' Heat Exchanger A Outlet Flow-(1-FS-070-158).
. - This ! alarm should.-be = enabled ' through alarm circuitry ; 1ogic that - ~ senses operation? of tthe associated RHR pump -(primary _ water flow on the1 other" side Lof athe heat exchanger);: 1.e., a: design change was
required,iof-which several?similarLeonditions existed.
, ' WRo C011805 i fortlet'down Heat ; Exchanger-Outlet Flok (1-FS-373-190).
! Normal. operation ~ flow: was-apprbximately 400 GPM, but alarm setpoint: - , L(for : reasons unknown): wasL100PJPM.' '_The ale rm :should hive a-- setpoint !
- change ;to, bet consistent w'.th : normal flows; severall of; these
' conditions existed.
' ~ WRs C011570 and C011818 - for.Containmenti Spray Pumps -1BB' and l2AAf - > ,~Mechanica Seal-Heat Exchanger Outlet Flow (1-FS-070-149, 2-FS-070.50).
Design cha.scs (DCNs X000300' andiM00602A); reduced' ,; - , flow requirements +s 5.3GPM, wnile the unchanged alarm setpoint;was.
-! .lef t at 5GPM; ~ i.e., -a type of design change ' problem. _ Several-of ] these cc.1diticas existed.
-a .. h . )
m-
,
, . .Many of_the"above. types of problems were identified during the conduct of the Detailed Control Room Design Review (DCRDR) several years ago.
In response to human factors concerns, the licensee committed to " Upgrade / Replace the Plant Annunciator System" (PCN #0604).
A " Major Project
Scoping Document" (Rev. O, dated 06/28/90) was provided to the team that indicated.that initial price considerations were underway just prior to-a the maintenance inspection, and that the modifications will be completed ! during Cycle VI.
The team was concerned that only approximately 50% of i the alarms were of _the type that would be corrected by activities under the major annunciator upgrade, e.g., installing enabling logic in RHR , , ' alarms. The balance of the indication problems could have been corrected-(i.e., correction was po,ssible without the upgrade project) by performance of flow balance tests, proper - scoping of other ' design modifications < already accomplished, corrective or calibration type maintenance, or , set point changes.
The team concluded that the licensee has tended to " lump" many annunciator and. indicator problems into the category of the g" " Annunciator Upgrade Program" rather than taking aggressive action to correct-adverse conditions on a case basis. The team was of the opinion-that> the licensee should commit greater current resources to - correct ' adverse, distracting, MCR indications that are outside the scope of the.
1" annunciator upgrade program".
- ' - 2.r. I & C Control'of Plant Maintenance Activities The team' observed ' maintenance activities of the craft persons and interviewed 1 numerous craf t and supervisory persons in the Instrument and
- Controls shop.
Observations :and -interviews: were used to determine if policios - goals, and objectives were being -implemented, how work was ' accomplished, and whetherLit. was in accordance with-administrative and- ,' J regulatoryf requi rements. Thel I&C techdicians :were-found.to be. a dedicated group of tech' icians of n
- good experienceflevels.
All = technicians ? were qual.ified to journeyman ' status, andiaveraged approximately ten years of experience,: f Most of-the technicians had completedE their apprentice cprograms at-Sequoyah station,. 'so their experience-base was, predominately site specific.
The I&C-group 'was the only craf t to 'have had a complete apprentice program atithe ~ station.. Continuing. education rand qualification requirements in.new. ' equipment.was anticipated by. shop management such-that people were trained- . on new equipment before its installation.
The.small ratio 'of' craft to . supervisors (foreman and general foreman) permitted very'close contactuand E
- -
- direct supervision of Lthe craft.
Good benefits and, good working . conditions; permitted :a very. low turn-over, i
- The. team observed the-performance of numerous calibrations, functional ~
l - tests, land 1surveillances. during which several licensee strengths were noted.
Procedures that would cause any change.in control room indication (change in status) included a-listing of each of the affected indicators, and a' requirement for the technicians to distinctively mark the indicator with a small orange ~ stick-on " ball".
The stick-on devices were marked i
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with the procedure number and date of the procedure being performed; control room personnel advised the team that this aid ass,i sted them immeasurably in maintaining status of the plant.
On each occasion of performing calibration checks of instrumentation and controls, if readings obtained deviated from the optimum value by more than. about 50 percent of the permissible band, the team -observed the technicians contacting their direct foreman who came to the job site and reviewed the data obtained.
Discussions and decisions were made concerning whether to perform adjustments to bring the instrument back to optimum values, even without the instrument approaching limits.
This , pre-empting activity had the effect of preventing instruments from ~ exceeding permissible calibration limits.
Since the technicians were grouped into specialized groups, such as nuclear instruments, radiation monitoring, etc., they were able to readily track any changes made, and developing trends.
, Procedure control, procedure adherence, and command and control of multiple units of a team were noted as strengths. Document packages were prepared by document control personnel for a day's activities of
surveillances, calibrations, and function tests.
Prior to issue 'to the ' craft, the packages were checked and verified (independent verification) as beinf the latest issue of the procedure, and tracked for'a fourteen' day window by document control personnel for its use in the field-If . changes were issued affecting the procedures in use, the craft was notified-t report to document control to obtain the latest revision. This acted prevent improper procedures fiom being used-in the field. The reader - worker method was used in _ the performance of procedures; verbatim compliance was an accepted norm. -On occasions 'of multiple' teams being _ " ' fielded (e.g., reactor trip breaker functional testing, i.e., two persons in the-control room, two-persons at the breaker, and two persons at the ' . controlling instrument), each group had. its own uniquely structured procedure that - dictated actions - to be performed by tne ' group.- Also annotated were the actions that would be performed by the (two) other groups.
The Test Leader (at the pre-dominant station) read all steps alouci over the phone circuit connecting all stations, thus controlling all' activities, with everybodyt understanding the. step before proceeding. This type command'and control methodology maintained absolute control over the-activity, ar.J was a significant contributor in maintaining' an enviable record of not initiating plant trips /actuations due to personnel _ errors.
I&C_ technicians. appeared especially cognizant of M&TE-equipment ~ " requirements, absolutely assuring two way traceability was maintained.for any. equipment. in usei in the field.. Test data clearly indicated what instruments had been used in the performance of the activity. Absolute configuration control _ was maintained in accordance with SQN-PMSP-6.2.4 < (Rev.1),. Maintenance Management System Configuration _ Control Log, which' recorded each lead. lif t and landing, with the attendant verification.
Although no maintenance was observed that resulted in the consumption of .!
,y
..
. spare parts or consumables, interviews with the craf t indicated their clear understanding of special requirements attendant to material usage.
, Based upon the above findings, the team concluded that the licensee had at l well implemented program for control of the-1 & C maintenance organization , and its activities.
, 2.si Control and Calibration of Measuring and Test Equipment (M&TE) J Administrative Instruction AI-31 (Rev.11), Control of Measuring and Test . Equipment, established the facility M&TE program. The procedure detailed , ^ the issue,' storage, and segregation of special, limited-use, or out-of-calibration M&TE, The procedure also provided -instructions for placing damaged equipment out-of-service, and for resolution = of. out-of-tolerance equipment that had ?been used in the field.
Nearly 100 percent of calibration services were provided by a TVA system-wide laboratory located' in tne area of Sequoyah plant.
Each piece of equipment was assigned -a unique TVA identifier number by.
.which the equipment's; calibration and use history was tracked, ' Tracking ~ was performed under computer data base control with a bar code. reader-device..Two_ way treceability was maintained by. tagging the equipment during its use :in the. field and 11 sting of the ' equipment used :in the applicable work instructions. M&TE check-out facilities were segregated; .from tool issue points, and wereclocated both in and outside the RCA.
. ' Calibration dataL included all required attributes.
A licensee strength' Lwas noted. in the 'M&TE standard master flist in that the accuracy of the.
'
- instrument.was listed: or the source document where such -accuraciesicould:
be f_ound if lengthy -in: nature. Thus1the' accuracies of test equipment.were - readily available to the craft if-the-procedures did-not-specifically. call
, out.;theitestlequipment:to-be used.
This ^ information availability ?could ' havet been ;more effectively employed for< the situation: of the:" enhanced" , (up graded) procedures: specifically1 requiring a piece ~ of M&TE. >If the' o , words " equivalent 4 or' better accuracy"L were. employed in s the : procedure, " ' P ' rather ?.than listing lonly one1 specific piecevof equipment, then Lthe . , ' -infrequent; occasions-of' stopping Lthe entire maintenance, process 'because :ofL
'non-availability ofEthe, specific M&TE could!be' avoided.'
Y . Anoiber ' licensee : strength in_ the M&TE program was the 'impiementation of- ' - " checking"_.(either calibration or comparison):'all instruments after return.
! ofromEfieldi use in the : range that; thec instrument ~ had been used.
Thi si ~ ' o f reduced Lthe numbercof evaluations. required' for out-of-calibration M&TE to gm a-very low (value. Thisieffort, however, did:have'the down-side effect of- .) ~ 3- . frequently omaking.M&TE unavailable on demand due' to its1 absence for a '
- check that could.not be performedon-the station.
i , An area of concern to the team was recall.
Computer run-off li5ts were used-as= the tickler for determining ' M&TE coming' due for calibratien.
- Recall,'however, was literally that'- i.e., attempt to place a phone call ,
< J
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to the individual last in possession of the piece of M&TE to recover the equipment prior.to its becoming due.
Al-31 addressed the subject at paragraph 7,6,6 as follows, "This schedule (M&TE/ standard master schedule)- shall be used to recall M&TE and standards for calibration or maintenance ! , ~ -. prior to the due date."
No further guidance on documented recall was provided in the procedure. Phone cal'is infrequently met with no success, which permitted M&TE.to remain in the field past its calibration due date.
Although no instances were noted by the team of past' due M&TE being used in the field,- the. team learned by review of the currently open file of adverse quality-reports that a PRD (Problem Reporting Document, 500 . 900201P) had been prepared in April 1990 detailing the presence of M&TE in ! the plant beyond its calibration due date. Therefore, it was the opinion j p of the team that the licensee should formalize the recall program into two ! steps:
i ~~ Documented notification of the cognizant craf t supervisor of M&TE - , falling due for calibration, j . Documented notification of the - cognizant craf t supervisor of M&TE l - past. due for calibration, and the necessity for segregating the' ' equipment.
=AI-31, paragraph 2.2. " Exceptions" listed generic exceptions to-requirements for calibration such as paragraph 2.2.1, " Permanently , installed plant instrumentation," and 2,2,4, " Cases in which the accuracy { - !in calibration. is not required. -(An example of this is the use of a ] . inon-calibrated power supply 'with its output monitored by a calibrated j piece'of M&TE)." Several devices were noted in use by the team that were ! . ~ not ; labeled, such as pressure ' regulators. and power supplies.
Since j , , interpretation of the generic guidance was not always easy to.makeLby the j ' craft, it"was~the= team's opinion that such devices should be labeled with-a "No' Calibration Required" sticker-to clearly convey-the permissible use: ] "g ' ' of the instrum'ent or device, . The team noted that although manufacturer's recommendationc,1for specific j > i Ltypes-of torque wrenches, concerning exercising of the -wrench prior,to~ j , m , ruse, = and relaxation,of ~ the f wrench to a ' low value priori to stsrage, -i ' ,af fected types of wrenches used by the licensee, none of these" s'pecifics ! ' ihad beeniincorporated inl procedures governing' operation of the-tool room,- 'in t torqueiwrench c calibration procedures, lnor posted in conspicuous f ' { &
- locations where' wrenches were stored. As a matter of practice, M&TE issue.
j
- point attendants were. setting all torque rwrenches. -to low values oni g
, T .stcrage, but were not exercising the wrenches prior to use or issue.
It-l Lwas.the team'sfopinion that;these considerations should be included.in the l ~ 7' M&TE program.
g - - Based cupon the above-findings, the team concluded that although the .y .overall program for M&TE.was adequate,. some program and -implementation I ?
- improvements could be made, j
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56 , . 3.0.-ISSUES IDENTIFIED- ' [st 3.a Inadequate Cleanness in Vital, Low Voltage Panels ^' v The inspection team found adverse cleanliness conditions in all vital, 120 Volt AC and 125 Volt DC panels observed.
During its review of contributing conditions, the team noted that SQA 66, Plant Housekeeping , oh (Rev. 18), should have prevented the problem.
Paragraph 5.3.1 stated, " - " Maintenance Instructions, Modification Instructions, and work plans shall ' -,$ include adequate housekeeping instructions to comply with this procedure."
i Paragraph 5.3.1- (c) required, "Af ter work is. completed, there shall be , provisions included' in. the work-initiating document for a final housekeeping signof f.
A housekeeping checklist shall be included with each work initiating document and should include specific items such as , ' those-identified in Attachment 1."
Attachment I listed numerous items to be considered. As a specific example of recently accomplished work where 4; inadequate cleanness was maintained, the team reviewed the modification work package-for installation of the Gamma-Metrics Nuclear Instrumentation , s SP - System ' (ECN _ L6186,1WR 6186-03) in. the' Appendix R safe shutdown panel N (backup : control room) and found that the only reference to SQA66 L- . housekeeping requirements was included in the work package under General y,,, ' Work' Instructions,- step 14.0, " Foreman to perform-periodic housekeeping-as - ',. per ' SQA-66". No other. provisions were included in the work plan for . ~ " final ' housekeeping signoff", although the work plan was a multi part 'l
, CL' ' document ifor1 multiple - pieces of equipment at multiple. locations, No j checklists were noted in.the work documents. Paragraph 2.e 'above details
' 'the: very poor mate' rial / cleanliness _ condition of the~ panels found during y the inspection, j; , Theiteam-also noted in its review of numerous other work packages that
o compl,iance 'with l the requirements 'of: SQA66' varied f rom no ; compliance _to-d ! partial compliance as Lfollows: q-(1)' Work' Order No. 8252779 (dtd ?11/27/89)c cleaned and replaced an SSPS
Separation-Relay;due;to contamination 'by cable pulling lubricant. No' j~ ~
- mention offhousekeeping.was made in the> Work Instructions, nor'was anytSQA66 checklist included in the pa'kage'- no compliance q
c o 1 Work OrderiNo.. B283063 (dtd 4/1/89)'. replaced ~ the ' capacitor: bank in' -i , JVital Inverter 2r-EIV.
No mention 1of housekeeping /was made in the
- WorkH In struction s, nor was any SQA661 checklist included in the:
package;- no comp 1.iance . "' na lN L(2) Work Order Ncr. :B260431 (dtd 3/26/90) repaired <various Rod; Position: j ~ j ' Indication _' (RPI) cables with split ' outer 1 Jackets.
The Work- - Instructions' did not ' require a housekeeping. inspection :(many _ ]j references were listed in the Pre-Job Reference & Requirements,_ including SQA66), but the workers performed a Final Housekeeping , ' Inspection partial compliance.
d 1--s --
' ,.s . ' ,,:
The. team noted that in response to findings of NRC Inspection 50-327/88-06 and 50-328/88-06, -violation 327, 328/88-06-03, "An inspection of all IE electrical panels was completed. on 16 January 1988,' and all loose materials were removed.
The importance of strictly maintaining
housekeeping requirements was stressed to Maintenance and Modifications employees by management.".Although this inspection had focused on the subject of loose fuses in high voltage panels, the licensee had found a large amount of other conductive material and miscellaneous debris in , numerous safety related panels.during their walkdown inspection precipitated by the NRC inspection.
Based on the extent of the current problem, the inspection team concluded that licensee actions in response to the previous violation-were ineffectual and inadequate.
Discussions with' the licensee indicated that loose material within the ' safety-related electrical panels most probably resulted from a com'ination o of, maintenance and modification activities, with emphasis on the latter.
The team concluded that the discrepancies did not appear to be isolated .; , cases due ' toi the large number of occurrences in numerous dif ferent ' electrical boards, panels and devices.
The discrepancies indicate inadequate control of cleanliness during electrical maintenance and-j -modifications on safety-related equipment and systems, and were considered
- a repetitive 1 violation'of 10 CFR 50, Appendix B Criterion V,-for: failure
, to control activities affecting quality,.and failure to-follow procedure, - and are f designated as J violation ' 327,328/90-25-01, Failure to Control
, Cleanliness in Low-Voltage Vital Equipment 3;b. FSAR. Update tol Reflect 5th Vital: Battery
In1 preparation for ' system walkdowns? :he team noted during its review of , reference-information.concerning low-vcitage distribution systems that the _Sequoyah -Updated Final Safety _ ) nalysis-Report L (FSAR) contained 'no o ^
- information_in section 8.3;2 (section-that describes DC power sysstems and~
cthe* vital batteries) Lon the fif th vital battery, which had been added by , < ECN L5599 pr.ior to the: August: 19851 shutdown.
The. team 1 questioned : the-
" f blicense'e since it.. appeared' that the requirements. of SQA180 -(Rev' 4)', ' 1 Amending the Sequoyah Updated Final Safety Analysis Report'(FSAR) had not- ' ' been met. (Paragraph 5.'l-of.SQA180 states, "This requirescthat1 subsequent revisions to the FSAR shall'be filed no less frequently-than annually and' . shall reflect:all changes'up to a maximum of six. months prior to the date
~ '
lofc filing. :.... TVA' policy-. i sl nottto' include a change;in a. scheduled FSAR-
revision 1unless' the modification is complete 1(i;e, ECN/DCN/PMP is field - ' .
- compl e te)'.'"
Since the fif th battery was operational' (and1had been for' a- ! ' ' long period: of. time),7 the team was. concerned: that FSAR updates were-not % being e processed 1.n' _a -timely 1 manner. in 'accordance - with' 10 CFR' 50 -
req ui re.;.ents ; ba>ad ~on questions raised by the inspection team, the.
licensee. initiated a. complete ' investigation.into_ the circumstances swith t CAQR SQP900314, the results.of which are detailed below.
. , . . < Ls _ U
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L ' , 'e , _.
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Engineering Change Notice (ECN) L5599, initiated in 1982, installed the 125 Volt Fifth Vital Battery System prior to the August 1985 shutdown, and was-intended to serve as a temporary replacement for any of the four , , primary 125 Volt DC vital batteries if they should be removed from service , for any reason, such as testing, maintenance, etc. The fifth battery and
its distribution -board was designed to Class IE criteria and was a Critical Safety System or Component (CSSC) system, i.e., Quality Class 1.
' The battery installation was declared operable (in the Technical j . Specification sense) because it was essentially field complete in May
' 1988; However, some small segments of the Post Modification Testing Work Plan-(PMT-31) for the battery were not " signed off" until December 1989 and the ECN was not " closed out" and officially declared field complete until 25 -January 1990.
" Field complete" status would normally trigger > -making appropriate changes to the FSAR under current procedures, thus this ~ ECN would nave been in a FSAR change published 15 April 1991 for all plant-modifications field complete as of 15 October 1990. Since this particular.
ECN had not been declared " field complete". at the time it was declared , " operable", it. appeared that no change had been initiated in the FSAR.
l The. team was of the opinion that when the battery was declared operable
(i.e...May 1988),.the. licensee became responsible for a " timely reporting" -(Reg. Guide. ~1.70) of the plant modification..Accordingly, the FSAR - . revision submitted on or about 15 April 1989 that included modifications up to 15 October 1988, should have included the information on the fif th' vital battery. The team also noted that 3QA180 was silent on the subject.
' of FSAR ' revisions ' for partially ' complete modifications (e.g., the fifth vital battery), which were. operable; this was perceived as.a programmatic > weakness.
Subsequent to'the close of the. inspection, the licenste-found that the 5th - vital; battery had: been discussed in 'ammendment 6 of the. FSAR. However, ' theJdiscussion. was in section-8.3.1.4.2, Cable Routirg ' and Separation. . s - Criteria under Alternating Current Power System, not it. paragraph > 8.3.2 - ~ ' where the' vital DC' equipment including the' other 14 batteries is '
- described, iBased upon the-above findings,;it is.not clear that the 5th vital battery was properly included in the FSAR. Also, there is a-question relative to
- 'FSAR-revisions for partially completed modifications where -the ' equipment , hastbeen declared operable.
Pending further : inspection, this ' matter is i . considered unresolved and isoidentified as item number 327,328/90-25-02,. E , f 1 Addition of'Fifth Vital Battery to the.FSAR.
! c3.c.: Auxiliary Control Air System Preventive Maintenance
. The ' team reeiewed the licensee's backlog of' PM's and found Annual PM.1450 -
, " Inspection of Auxiliary -Control Air Dryer ;A-A" was delinquent.'.The " scheduled start date for this PM was 2/5/90, due completion date 5/4/90.
Annual.PM 1451 for B-B ACA Dryer was also delinquent with scheduled start
~ date 1/2/90, due completion date 3/31/90.
Upon checking the PM history i
. , i
file, PM 1450 and PM 1451 were last performed 3/27/86 and 8/28/88 respectfully.
The detailed work instructions for the PM's were: 1.
Inspect and replace desiccant, if degraded (two chambers).
2.
Inspect, clean and repair as necessary the four pilot operated valves and four check valves.
PM 1450 and PM 1451 are classified Critical Structures, Systems and Components (CSSC).
Upon checking the history records for PM 1450, discrepancies were seen.
In May 1987 the PM was canceled due to "PM being revised, and no effect on equipment."
November 1988 cancellation stated, " Cancellation does not have a detrimental effect on operation of equipment.
PM will be rescheduled for U2C3 outage and every outage thereafter.
Technical specification interpretation Log 3 requires LCO action for modes 1-4."
Hi story records for - 1989 were not found to indicate if the PM was accomplished during the Unit 2, Cycle 3 outage.
When questioned, the licensee submitted that " Routine maintenance on the Auxiliary Air Systems was suspended in 1987 due to technical specification operability questions.
Literal interpretation of the technical specifications causes two trains of Auxiliary Feedwater to be declared inoperable when either train of Auxiliary Air was removed from service.
This condition requires entry into Limiting Condition of Operation (LCO) 3.03 which requires' restoration of the system in one hour or shut down in the subsequent six ' hours. - Entry into this LC0 is not an acceptable practice for routine plant maintenance which would likely result in forced- ! shutdown of both operating units. On March 23, 1990, an amendment to the Technical. Specification Bases was -obtained. - This amendment allows the ,a removal of. one train of Auxiliary. Air under the LCO for removal of one ~ train of Auxi.liary Feedwater, This LCO allows 72 hours for restoration of-
an inoperable train of Auxiliary Feedwater.
This. amendment allowed for t U the removal of one train of Auxiliary Air _ for scheduled maintenance. PM: y 1450 on Auxiliary Air Dryer A-A was subsequently issued to Maintenance Planning in preparation: for work.
A review of maintenance-history.
i revealed the probable need'for replacement parts for the valves maintained , on this PM. These parts have been ordered and the PM is on hold until the ! needed parts are available" $ The ' failure to perform annual PMs for four years inoicates problems with t y* 'the program for deferral of PMs and-the PM program. The justification for
- !
deferral of the PMs given by the licensee was LC0 considerations. This problem was complicated by the fact that the PM covered not only replacement of the desiccant (GL commitment), but also refurbishment of g valves.
Had the desiccant changeout been separated from the valve.
refurbishment,.'LCO considerations should not have been a problem to meet the GL commitments to change desiccant.
With regard to desiccant replacement the inspectors observed various parts of WR C001641. The description of problem read " Purge pressure and. dryer pressure gauges en ACA Dryer A-A are tracking each other during dryer purge cycle. Thi, indicates a possible restriction in the purge discharge ,
, o
. line, the muffler is suspected, investigate and repair". The discovery date was 5/10/90. The muffler was removed and found to be plugged with debris. The SE collected a sample for evaluation, which was found to be desiccant dust. Power stores did not have a replacement muffler in stock, so the old muffler was flushed with approved cleaning solvent, blown out and reinstalled as directed by the SE.
Post maintenance test was - conducted when _ the air dryer was placed back into service, but not recorded on the work closure form. _ Furthermore, in the WR package the ' Maintenance History sheet was marked N/A in the Failure Description and Cause Of Failure areas. The Work Closure form listed Cause Of Failure as " suspected muffler was stopped".
These entries indicate a weakness in.
providing adequate failure descriptions to support trending. Also, the inspectors surmised that if PM 1450 had been performed as scheduled, the .. need for this WR to clean the muffler could have been avoided.
The licensee's response letter of February 23, 1989 to NRC GL 88-14 was reviewed.
The team had the following concerns: Under discussion of their program for maintaining proper instrument air - quality, page 5 of their response states that ACA system filters are replaced semi-a'nnually under PMs 1488, 1489, 1516, and 1477.
The team could.not find any record of existing PMs 1516 and 1477. The licensee's response was that the. requirements for PMs 1516 and 1477 were incorporated in PMs 1488 and 1489.
Additionally, page 6 states that PMs 1450 and ~1451 are performed on ACA - dryers.A-A and B-B to replace the desiccant. The dryers are inspected at
-this time,-- and any abnormal conditions are reported to the cognizant
- engineer for evaluation.
Dryer maintenance is performed with the system " still _ serviced by operable dryers. _ As discovered and stated above, PM 1450 and!1451 have not been performed.since-February 86 and August 88 respectively. -After the team departed the site, the licensee responded _to the team's concerns on PMs 1450 and -1451 and stated that "WRs 2716 ' , 1' and 2717 ' have been issued to replace the desiccant in the ACA Dryers.
- Additionally, ' PMs 1450 and-1451 will be categorized as _ " Regulatory" PMs.
because 'of NRC GL 88-14.
It is important to note that even though - desiccant was not. replaced for an caended period, air quality testing indicated no moisture problems.
In addition to tFe above actions, SQN Technical Sepport-is reev A ating the implementition of GL 88-14 commitments / corrective actions."
In-TVA's response letter of February.14, 1990 to GL 88-14', the team had-concerns with the-following: In the summary of commitment No. 2,' the licensee responded that plant - . procedures will be revised to require routine set point verification of moisture elements in the ACA and SCSA systems by July 31, 1989 - Completed August 28, 1989.
The team. found that Maintenance Instruction (MI) 0-MI.IDC-000-147.0 " Calibration. of Hygrodyanic Model 15-3205 Moisture Switch, Rev. O, of 7-28-89 had been written, but not accomplished.- The . . . . .
> , s
licensee acknowledged that no PM exists to implement periodicity and i scheduling of the MI.
Furthermore, under commitment No. 3, the licensee stated that routine air - quality testing would be implemented by August 28, 1989. - Completed ! September-12, 1989. The inspectors found two Periodic Instructions (PIs) -l were written for this item; 0-PI-SXX-032-001.0 " Turbine Building control ' ' Air Quality Test" Rev 0 of 9/7/89 and 0-PI-SXX-032-002.0 " Auxiliary Building Control Air Quality Test" Rev 0 of _ 9/7/89.
The PI's were ! semiannual and scheduled to be accomplished November 1989.
Based on.
l information provided by'TVA during the inspection, the PI for the turbine j building-was started November 1989 and completed June 1990. The PI for ' the Auxiliary Building had not been started.
The licensee did not know why the PI,for the Auxiliary Building had not yet been started. The long j duration for accomplishment of the turbine building PI was due to first time implementation problems.
!
The, team received additional -response to the above concerns after-l . departure from the site. The licensee stated that air quality' testing for
, both-the Turbine and Auxiliary buildings had been initiated on 9/12/89 and j 9/18/89, respectively, The initial test results indicated s'everal failed.
' pointss for ' particulate and dew point.
Conditions Adverse to Quality . Report f(CAQR)iSQP890529 was written and corrective actions developed..A retest - of the initial f ailed points was _ completed in November 1989 and
nine points failed again. Following the retest, a temporary air line was =j _ The temporary line was
i;, found to be' the source of the; moisture problem.
,~ isolated (and later removed)- and. the entire control air system-was < blown ! , down. LAlsecond retest was conducted in March 1990 with all points. passing i on--dew, point,. but three points tailing: on' particulate.
The system was ! - again ' blown down in June 1990, and'the remaining points passed.
' ]j ' Based' upon the Linformation above, it iappears -that TVA has.not: met their
' commitmentsof letters of February 1989:and.1990_in' response to GL 88-14.
- However,- based upon: conflicting information L provided: at the site versus I ' that : provided _ af ter the conclusion: of. the ' inspection, the degreef.of l
- compliance -- i s notL clear.
Pending further review.during a future y inspection to. determine the extent-to which commitments:have not:been met, . this matter is considered unresolved' and is L identified as item number.
j r '327,328/90-25-03, -Compliance with GL 88-14 (Instrument Air) -Commitments.
E!
4.- ' EVALUATION OF. MAINTENANCE q
< . . . . i Summary Rating:of Maintenance Process .i ' . Wrograni: GOOD
W f Implementation: SATISFACTORY l L Thetteam rated the Sequoyah maintenance program GOOD and its implementation
. SATISFACTORY.
l '
, <,c < , b
.
-l ' 'The rating was obtained by collating and assessing the maintenance team inspection findings in a special maintenance inspection logic tree, The tree completed _for Sequoyah maintenance inspection is depicted in Appendix 3.
The tree divides maintenance evaluation into three " parts" (I, II, and III). The -, = parts are divided into eight " areas" (1.0 turough 8.0) and the areas into ' individual maintenance topics or " elements" (1,1,1.2, 2.1, etc.). Based on their inspection findings (negative and positive), the team established ratings '! . forLmost of the elements. Subsequently, area ratings were determined based on associated element ratings; part ratings based on the associated area ratings; -and, finally, a total maintenance' rating was determined from the ratings for t h_e pa r t s.' The team did not weight all.. findings or ratings equally.. Four-rating categories were-used and a color was assigned to each to aide in - displaying the ratings on-the - maintenance inspection tree.
The rating categories were as follows: " Good" Performance (Green) - Overall, better than adequate, shows more than 'few minor areas that need improvement " Satisfactory" or " Adequate" Adequate, weaknesses - . Performance (Yellow) =approximately offset by. strengths "Poo_r" Performance (Red) Inadequate or missing, - ' (Blue) -Not evaluated or Insufficient -
Iriformation to Evaluate Each part, area andLelement, as-well as'overall maintenance, is-represented by-a block" on the J tree.
Most of th_e blocks: are split into two parts with the > q Jupper portion: representing program or'. process and the lower. half representing ' --.i mpl ementa ti on. - The exception '. is'- for. the'. part JIL blocks 4 which Tare not'. considered.to have separate programs or implementation.
., LThe/ parts and areas' of the mairitenance inspectionL tree-' are described below.
'
- The' more 1 significant. inspection-findings. (strengths ' and weaknesses) that
' including -' strengths 'and Jweaknesses' are : detailed throughout the. report. _ i ! contributed -to' the ratings are ~ l_so given, Other inspection findi.ngs, a , - l Individual element ratings are not-described but'are shown in-Appendix 3.
A
- 4.a. -OverallLPlant Performance Related.to Maintenance (Tree Part I)
Rating: ISATISFACTORY u x This part of the ' tree is an overall~ assessment and rating _ of maintenance = . Jthrogh - direct measures: Its ' rating was based ~ on the SATISFACTORY rating determir.ad for " direct"_ measures below.
,
i l ' t
l ) 4.a(1) Direct Measures (Tree Area'1.0) Rating: SATISFACTORY The direct measures normally used to assess this area are the plant historic data (tree element 1.1) on the performance of the operating units and I observations of housekeeping and material conditions observed in wal kdown ! inspections (element 1.2).
The rating of satisfactory in this area is based on the following strengths and
weaknesses. Although most historical data indicators were good or improving, the collective radiation exposure for the last three years was slightly below the industry median for pressurized water reactors. However, the collective dose for the last 12 months was 1102, due mostly to the unit 1 cycle 4 outage, compared to an industry median of 640.
Unplanned automatic scrams have been high, but have recently improved to near the industry "Best Quartile".
Although, in-general, cleanliness and material condition of the plar t was good, significant poor housekeeping and material conditions were identilied in low l voltage vital equipment.
STRENGTHS q
Forced outage rate for Unit 1 has dropped significantly from 24% (FY89) to ] - 2.8% (1990 FYTD) and 6.8% (FY89) to 0.6% (1990 FYTO) for Unit 2.
The a industry median is 4.6%.
Unit 1 availability trend has improved over the past 18 months and is - slightly above the_ industry median of 69% despite the Mar - June-Refueling ' outage. Unit 2 availability factor has improved from 64.8% at the end of FY 89 to 97.8%.1990 FYTO'versus'a industry median of 69%. Overall cleanliness and general material condition of the plant was good.
- I WEAKNESSES a J Collec. ave Radiation Exposure was well above the industry median, due - mostly to Unit 1 Cycle 4 outage and management of collective dose.
Most low voltage distribution boards and panels, and some instrumentation ! - and. process panels contained general debris including conducting and non-conducting material. In addition, there were a number of examples of poor work practices.
Other examples of. poor' housekeeping / general material condition included f - is the Unit 1 pipe chase, the New Make-up Water Treatment Plant, and the ' vital batteries / rooms.
T .. L
{ l > , e2 ! E I
7, ,. p
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= ,
] y . 4.b Management Support of Maintenance (Tree Part II) j , Rating: Program: GOOD l Implementation: SATISFACTORY
. y ! , ' 'I E This part of the-tree is an assessment and rating of areas of the tree which
represent management's' support of maintenance through their commitment' and .l - involvement, - organization and administration, and provision of technical p-support for the maintenance process.
j
h 4.b(1) . Management Commitment and Involvement (Tree ! i Area.
2.0) j Riting: Program: G005 , J..,. Impl'emente cion : SATISFACTORY
, -. .
- !
LThis' area consists 1of, upper management's direct e'ncouragement andLpromotion of ?! .,- improvement s M i n : mai ntenance, The rating of implementation wast based on the.
-1 ,' following findings of strengths and weak 1 esses: q s ] p ' STRENGTHS' (System engineersLinitiative implemented - system engineers motivated and . - " -knowledgeable about their system.
,' Responded we'll; to INP0's - SOER 86-03.'and EPRI Report NP-5479 ' for ch'eck J = o J. valves, NRCLINL88-86-(battery ground detectors), and NRC bulletin 89-02.
j - . . . ] e !. Nuclear Experien'ce: Review Program.in' place and<functioni.ng well,: -:
< ' , MaintenanceLself assessment completed in; August l1989.- - ' ).MIC detection; program: e' tab.lished providesJ measuresi.for detection, -/ s
- control Jand investigation forcroot'cause of the/ phenomena.
! '~ ! 4' ' Special. one-time:.programe ongoing tos improve.overall! expertiseiof- - electrical: craftsmen, l ' , n, -Good corporate. maintenance staff involved in site maintenance activities, in - , Q g . Reliability-Centered Maintenance:(RCM) program: funded and in process
- WEAKNESSESi L
' Poor implementation of' commitments to GL' 88-14 (instrument air.). ! -- .
- 4
' Poor ~ response'to NRC. Bulletin 88-04 (RHR pump deadheading)-(see NRC report '! - 90-01)..NRC. Information' Notice 87-61, Supplement 1 and 88-75 not fully . - o; ' addressed f <
.- !
u , . .
o , , - - ,
.
Management aggressiveness could have been impreved relative to recognizing - problem and initiating corrective action for Masoneilian valve problems, ' improving predictive maintenance, and correcting annunciator problems.
4 b(2) Management Organization and Administration , (Tree Area 3.0)
Rating: Program: GOOD , Implementation: SATISFACTORY i This area consists of management's support of and involvement in the control of n-maintenance through developing and implementing a maintenance plan setting . goals and~ policies, allocating resources, defining maintenance requirements, monitoring performance, providing document. control and ' determining the need for . improvements to plart material condition.
The rating was based on.the ,' .following findings of strengths.and weaknesses: ' y STRENGTHS;
'Detai. led ~ system of corporate and site goals in place - 3 tier system - t - as
- 1st tier; corporate;'2nd tier site, 3rd tier maintenance department, Goals
! c' , posted conspicuously around the ~ plant and used to. improve " maintenance
' process - y ' ' ire 11 ability Centered Maintenance (RCM) program staffed and budgeted for 7 - people.
Program has been implemented -and -is: being.used-;to modifyi the (" existing-preventive-maintenance program.
-; ~ , l Each : p1l ant imodificatio_nf has -b'een Jassigned? a 'planti priority nbmber ' and.
[ - H ranked according t1 its'overallimportanceintheplantLupgradefprograms.
g - . i II&Ciphilosophycof performing calibration /re-alignment at approxim'a'tely 50: ~ c - 1 percent of tolerar.ce : band prevents ' entry intoiTech _ Spec; limited : instrument - - , -. condi ti on s, - j -
F ~
- -
.A111 expected-irstruments-and controls _ subjected to periodic-calibration.
q < ~ Good', program for., check 1 valve maintenance in > accordance withtINPO. SOER
-
jy
- 86-03timplemented w'ith' adequate; technical support:and resources;
~
'a.. L ' 1 Surveillance. test - packages prepared on a recurring 1 basis by. document. - control personnel.and verified :for. currency prior. to.issuelto the craf t- , Lfor'the. day's testingLactivities - all disciplines.
~ , Strong program for use of. correct procedures.
.i 4- , "1 - 1 Corporate involvementin the maintenance process appeared to be~ strong.
' ' Detailed-PM' program in place.
- - , i ' y '. pf , i
.__ _ _ _ _ _. _ . - _ _ - _ _ _ _ _ __ -___ _ _ _ _ _ _ _ _ - _ _ _ _ _ _. _ _ _ _ _ - _ _ _ _ _ S i ,
- ..
.,
I . < i . i Dbsolete equi .nt committee in place and working.
- Records readily retrievable, good vendor manual control.
l - , WEAKNESSES
Initiation of significant corrective action plans and program improvements - occasionally slow, e.g., less complex annunciator problems. Masoneilan e valve prnblem, predict.ve maintenance program, overtime control.
l PMs not always technically adequate, not always performed when necessary, - net always technically justified for deferral, and often cover too large a scope to accomplish in a reasonable time and effort. PM schedules did not readily show deferred or canceled PMs. Poor implementation of PMs for GL SB-14 (instrument air). Past PM program for 6.9 KV breakers weak in that current program allows too long between PMs.
. Predictive maintenance program - limited staff with limited scope, used - , mostly as diagnostic. tool rather than program to predict when maintenance
should occur.
Check valve Predictive Maintenance through system walkdown i by system engineers not being fully enforced.
! , , No programmatic requirement for management observation of craft work.
-
~-' Areas of weakness identified in PM program and implementation for 6.9KV and 480 VAC distribution system and large motors-
4.b(3) Technical Support (Tree Area 4.0) !
. Rating: Program: GOOD ? Implementation:' SATISFACTORY [ . This area. encompasses the various elements of technical support that are needed ! ~ ..for maintenance to function effectively,(e.g..- engineering support,- health ~ , physics,10C,Lrisk assessment, etc.). The rating of this area was' based on the following strengths and weaknesses observed by the team: .
- STRENGTHS System Engineer concept in place and appeared to be working well - system
- . engineers; knowledgeable.in their systems.
Good-liaison and cooperation the. norm 'between the craf t and system
- -~
engineer.
Daily meetings enhanced the communications between Operations, - Maintenance,'and technical support organizations, i ! @ a
' ,
. Good Corporate support and involvement in site maintenance activities - - good communications with site.
QA/QC appeared to be well staf fed and qualified and was involved in the - maintenance process.
Work control group used PRA principles and risk assessment in prioriti:ing - mairtenance even though Sequouah does not yet have i approved PRA.
WEAKNESSES Trending program not well defined or implemented - in general, equipment - failure trunding data provided by maintenance to engineering not being analyzed - trending of system parameters, equipment failures etc.
inconsistent, dependent on individual system engineer motivation.
Electrical QC and QC surveillances appeared to be weak based on magnitude - of problems with electrical board cleanness and some craft work practices (e.g. poor soldering) problems were not identified by QC/QCE surveillance inspectors, Unit 1 outage resulted in very high total dose (mostly result f rom RTD - replacement) due to inadequate mock-up training, less than optimal planning and path scheduling, poorly trained or inexperienced workers, and inadequate management of collective dose (see NRC Report 90-23), High incidence of maintenance and modifications personnel not wearing assigned dosimetry.
Steffing in safety department recently reduced significantly; adverse trend - noted ' in reportable and lost time accidents; general disregard for wearing of safety protective devices such as hard hats, safety glasses, and ear plegs; poor (unenforceable) signs for ear protection warnings; and accident reports generally late from maintenance.
- 4,c Maintenance Implementation (Tree Part Ill) Rating: Program: GOOD Implementation: SATISFACTORY This part of the tree is an assessment and rating of the work, organi:ational, hardware and personnel controls necessary for proper implementation of maintenanc _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. . .
. 4.c(1) Work Control (Tree Area 5.0) Rating: Program: GOOD Implementation: SATISFACTORY This area encompasses assessment of important elements of work control through evaluation of maintenance in progress, work order control, planning, scheduling, prioritizing, etc.
Its rating was based on the following findings which represent strengths and weaknesses identified by the NRC team: , STRENGTHS Procedural adherence, command and control by most crafts noted to be strong.
- Equipment: status control during testing (and. Operations knowledge of - , status) through use of control room-indicators good.
Initiation of work identification and request was readily accessible and- - - . o sy to use for any_ site' personnel.
Work Orders provided for multiple, appropriate levels of review. and - gTi _ approval, including QA.
Work Order format addressed every conceivable attribute - - ' Records were readily retrieval.
- ' ' Reference material in-detailed work' instructions was the norm. Planners utilized experience gained from previous work plans : to e. hance the current: product.
+ Maintenance organization used two former HPs to enhance the planning process.
- ' RADCON reviews every WR for-potential requirements for RWP and ALARA pre- - l planning prior to_any. planning effort, indicating requirements for samezon , the WR.
-; Prioritization scheme considered safety of personnel and plant,- LCO limitations, risk assessment, 'and requirements for outage (including limited) in assignment'of priorities by the Work Control Group'(WCG) - an.
~ ! Operations (SRO) based organization, Review of. al1~ outstanding ' backlog work items for the craf ts indicated ~no - L-o improperly prioritized work: item.
Strong daily scheduling meetings appeared to, work _well.
- Large QC involvement.and extensive verifications in enhanced. electrical PM.
-- .. procedures on switchgear.-
- Good PMT program in place.
-
1-
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r
WEAKNESSES Mechanical craft performance poor in correcting excessive leakage on - system 928 seal water supply to make-up water pump.
Some Work Plans did not include instructions and sign-off for housekeeping - as required by 50A66.
Electrical expertise in breaker overhaul poor when staged for the NRC - - - combination of poor procedure and lack of practice on tasks.
Information listed in the History Data Base was not always listed with , . - the correct Equipment Identification System (EQlS) number, therefore history not always accessible.
Some maintenance planners have not received necessary training.
Not all procedures. received adequate verification and validation prior to - implementation in the field (Gamma-Metrics Surveillance a.1d 6.9 KV breaker PM).
Electrical PM procedures. had some weaknesses - e.g., megger testing - procedure did not provide meaningful results.
Job-site cleanliness / post job' housekeeping in low voltage distribution - equipment was-not. adequately monitored by craft, supervisory ' or QC personnel, and'thus was left in poor' condition.
Many minor work plan errors detected by the team in review of closed work- - ' plans that'were not detected by the reviewers.
Some station deficiencies were noted by-inspection team that should have - ~ beenLidentified and tagged as a work item,. but were not.
Planners recently' ass'gned responsibility. of planning all PMs as though - - - they were a CM work plan (due to. poor quality of previous: PMs).
Very { small increaselin staffing to accommodate large increase in work load.
c Little results in decreasing corrective maintenance backlog.
- 4.c(2)i Plant Maintenance Organization + , (Tree Area 6.0) Rating: Program: GOOD-Implementation: GOOD ,
, '
i f =
g-
8
- , l This area encompasses the processes used by the maintenance organization to ' control, support and direct maintenance activities.
Its rating was based on the following findings or strengths and weaknesses: > STRENGTHS Configuration controls on jumpers, lif ted leads were strong.
- Daily. POD annotation of responsible group and foreman enhanced - accountability.
Craf t work groups were well structured, had generally good procedures, - followed procedures, appeared to be well informed end wait trained.
> Mechanical. shop, (in, addition to the planning efforts) strong on having - required materials _ set aside for forthcoming outage and forecasting craft - requirements.
, - ~ Good use'and control of vendor manuals.
I&C philosophy of performing calibration /re-alignment at approximately 50 -
percent of' tolerance band prevented. entry _i nto Tech Spec limited r . instrument conditions.
Not uncommonly were instrument-function check result: reviews performedson the spot by supervision to make determinations d' about' instrument adjustment. I&C craft used concept of semi-dedicated work groups for different work areas.
Supervision actively pursuing. increased craft expertise through schools, - _. qualifications.. ' - ' ' Job site supervision very visible - appeared to be the normal way_of doing business.
- - Surveillance test packages were prepared on. a recurring basis by document control personnel,and verified for currency pr.iorito issue to the craft - for the day's testing activities - all disciplines.
Good, easy to use. program, for: identification Land work initiation of J ~ + deficiencies.
' , Good' support -interfaces between maintenance 'and support organizations,. - -includir.g corporate.- ,< . WEAKNESSES '
Megg'er/ insulation resistance testing of switchgear as conducted'in the i - past did not provide meaningful results.
- ' Switchgear PMs poorly implemented '- last tested 1980, some not tested . - again until mid-1993.according to current schedule.
9.
, _ _ _
. _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ !; . ' .. . . i
i Some material deficiencies were noted in the plant that should have'been - identified as work requests.
, , Maintenance trending of system / component failures not uniformly - implemented by engineering.
Safety practices related to maintenance was perceived as poor due to the - adverse trends of reportable and lost time accidents, general lack of use of safety equipment, poor signs for hearing protection warnings,- and past , due accident reports.
' ' , Motor maintenance - limited predictive maintenance and lack of periodic - L inspection.and. cleaning, and lack of space heaters.
, , s 4.c(3) Maintenance Facilities, Equipment and Material Controls (Tree Area 7.0) , Rating: Program: GOOD < Implementation:- GOOD This area e'ncompasses the plant maintenance facilities,-equipment and material controls with regard - to the part they play in supporting the ' maintenance , !E process. The findings upon which the rating of.this area was based are listed ' below.
STRENGTHS- , Shop fsupervision. was co-located with the' craf t.
' Craft shops were -
immediately adjacent to normal working areas.
F . Shop areas in general well equipped and well laid out.
- . SQN strongly inter-active. with industry in material. control, 'and --
pro-active in the area of obsolete equipment.
- ! $ Material ~ review for procurement performed by 13 engineers' (partially . ' necessitated by lack of Q List).
r Excellent-storage facility, housekeeping good, staffing good, supervision - centrally /co-located staff.
--- . Hot shop tool control strong . total-inventory control, adequately' - supplied, wellLorganized ~ Mechanical shop strong on forecasting tool requirements, for major jobs.
- Each piece of M&TE under inventory control by computer data base (bar' code l - reader), - inventory has been established and' modified as a result of.
' consideration of installed and newly changing equipment, e .!
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _. _
, e-
WEAKNESSES Not all vendor requirements included in M&TE procedures. Ef fective M4TE - recall procedures have not been implemented.
MATE 'ssue personnel not formally trained in their duties and responsibilities.
Post-use functional check for M&TE (strong point) sent off-site has caused significant number of M&TE check-out demands to go unfulfilled at the time of the request-due to absence of the equipment.
Material control could be strengthened with master equipment list.
- Manual inventory control system.
- 4.c(4) Personnel Control (Tree Area 8.0) Rating: Program: GOOD - Implementation: SATISFACTORY This area encompasses staffing controls (personnel _ policies,. turnover- , minimization,, shift coverage, etc.), training, testing and qualification and the overall current status of personnel (actual turnover rate, extent of-personnel trained and qualified, drug problems ~, etc.), The above rating was based on.-.the.following findings: STRENGTHS: Turnover rate 'very low due to' competitive salary benefits, education -- enhanceme'nt programs, and overtime availability.. - High supervisor.to craft ratio.
- Range; and span of ~ control for first and second level supervision at the: - craft level very good.
" IManagersandsupervisorshadwrittenjobdescriptionsforallpositions.
- -Procedures covering counseling / disciplinary actions were in place,: seldom - 'requi. red use at'the disciplinary level.
Shop Training Council-quarterly meeting.at the craf t level provide gonc' - feedback from. craf t level. as to adequacy of' all craf t training, and-obtain9d management attention;to training difficulties.
Substance abuse program in active use, accepted by staff.
-1 Equipment specific training for engineers on new equipment (Eagle'21 and - Gamma-Metrics).
- .
l~ ) o
. - _ _, . .' ~
. WEAKNESSES Overtime excessive - Violation issued Spring '90 (Rpt 90-22) - Training program for Transmission and Customer Service personnel had not - been reviewed for compatibility with SON requirements.
Technical training for craf tsmen will only average-about 56 hrs per - craftsman per annum (on-site plus vendor supplied training).
, .Speciali:ed training could be improved for: Planners, M&TE shop, tool- - issue, ALARA.
. ' No apprenticeship program, and weak basic core training for electrical and - mechanical craftsmen.
.. ' No re-qualification.-or refresher requirements.where certain tasks are - ' " infrequently performed.
.5.0 Exit-Interview
The inspection L scope and results were summarized on September 14,1990, with those persons. indicated. in Appendix 1,- The team leader described -- & the areas inspected ~and discussed in detail the inspection results listed below.
. Proprietary 'information is not ' contained' in. this report.
Dissenting; comments were not received from the licensee.
I .( Open) - Violation 327,328/90-25 - Failure to control cleanliness in-x; < . low-voltage; vital l equipment - paragraph 3.a.
- .y-
, .b. (0 pen)'~ Unresolved Item - Addition. of - f,1f th vital battery to FSAR -
' paragraph 3.b.- ' (0 pen) Onresolved, Item-Compliance with GL 88-14 ' (instrument air)
3 commitments paragraph 3.c.
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___ __ _- - -___ ___ ________.
j c . , i , '
. APPENDIX 1 r I Persons Contacted , J. Alexander, Maintenance Support Group Manager
T. Arney, Supervisor, Quality Control S. Bargerstock Manager, Procurement Engineering T. Basham, Planner, Mechanical Systems
- R. Beecken, Maintenance Manager
. D. Branham, Work Control' Group Supervisor - .A. Brooks, M&TE Foreman- ]
- L. Bryant, Work' Control Superintendent
! L. Bush, Assistant Maintenance Superintendent ! J. Bynum, Interim Site Director W. Byrd, Manager, Allocation of Resources ! D. Conner, Manager, Maintenance Training
- M. Cooper, Compliance Licensing Supervisor
> .P.- Crabtree, Unit Manager, Operations - D. Craven, Supervisor, Electrical /I&C, Technial Support ! F. Cuzzort, System Engineer l I. DiBiase, Group Leader, Reliability Centered Maintenance .' ' -*E. Ditto, Engineer, Corporate Maintenance-R. Drake, Modifications Supervisor i D. Elsea, Supervisor, Mechanical Maintenance S. Emert, Manager, Electrical Planning
- T. F11ppo, Manager, Quality Assurance and Engineering M. Frye, Instrument Maintenance Group Manager-
_ LW. Gamble,. General Foreman, Instrument Maintenance Group j . W. Hall, System Engineer. i .
- R. Harris,-Manager, Maintenance Training J. Hatcher,' Engineer, Nuclear Experience Review Program
! . . D.EJeralds,. Superintendent, Electrical Maintenance
~*N. Kazanas,-Vice President, Nuclear.0perations Services
- J. Klein, Maintenance Programs Engineer J. Kleine, Scheduling System Supervision
. J. Long, System Engineer . ' D. Love, Maintenance Planning'and Technical Manager
' , T. Massey, System Engineer J.: Miller, Supervisor, Programs and. Procedures B. Mims,' Risk Assessment Staff Manager R. 0' Bannon, Supervisor, Predictive Maintenance Program- -
- G. Pitzl, Field Support Manager, Corporate Maintenance
'
- R. Pierce; Mechanical Maintenance. Group Manager-R.- Poole, Project Coordinator, Electrical) Maintenance-
- Re Proffitt, Licensing Engineer.
- R. Rogers, Program Manager, Technical Support J. Shirley, Supervisor, Mechanical Maintenance
- - e R. Smith, Modifications Engineer, Electrical . k ,. I .I '
_ _ _ _ _ _ _ _.. ..... _ r p . . Appendix 1
= b ' S. Spencer, Licensing ,
- M. Sullivan, Radcon Manager b.
N. Thomas, Systems Engineer
- R. Thompson, Compliance Licensing C. Vondra, Plant Manager G. Wade, Supervisor, Inservice Inspection
'J Walker, Maintenance Program Manager D. Winchester, E.ectrical Foreman M. Williams, Foreman, Tool Issue Controi - J. Willis, Supervisor, Failure Analysis, Technical Support
B. Wilson, System Engineer
"W. Wright, Mechanical Maintenance Group Manager (Acting) .
- B. York, Corporate Maintenance Manager
_
- Attended Exit Interview
_.
E-v M - m - ". . - M P EE-a-------.----____.- - _ _ - - _ _ _ - _ - - - - -. - - - -. - - -.. - _ - - - - - - - - - _ _, -. - - - - - - - - -. - _ _ - - _ _. _ - - - - - -. - - - - - - - - - - _ _ - - - _ - _ _ _ _ - _ _ - - - - _ _ _. _ _ _ _ - - --.-__ - -- - A
_ _ _ _ - _ _ _... _ _ _ _ _ _ _______ . c - ,. s . APPENDIX 2 ) ACRONYMS and INITIALISMS ALARA As Low As Reasonably Achievable ' AC Air Compressor ' AC Alternating Current { ACA Auxiliary Control Air ASME American Society of Mechanical Engineers BIT.
Boron Injection Tank CA
- Compressed Air CAQR Condition Adverse to Quality Report
.I > CFR Code of Federal Regulations i CM~ -Corrective Maintenance CSSC Critical Structures. Systems and Components 'CV Check Valve DC Direct Current DCN.
- Design Change Notice-
'DCR Design Change Request DCRDR Detailed Control Room. Design Review ECN-Engineering Change Notice EPRI-Electric Power Research-Institute ' EQIS.
Equipment Identification System' ERCW' Essential Raw Cooling Water System FCR . Field Change Request FCV.
-Flow Control Valve FI: Flow Indicatir ' GL.
lNRC Generic,.etter FSAR.
Final Safety Analysis Review . HP Health Physics 5, ID Identification I&C Instrumentation and Controls INPO-Institute for Nuclear Power Operation.
IPE; Individual Plant Evaluation ' t .LCO.
Limiting Condition _ for Operation ~ LOC . Loss of. Coolant LS L. Limit Switch-LVC Level: Control Valve.- MIC.
' Microbiological 1yLInfluencedCorrosion ' ' MCR Main Control-Room ! M&TE . Measuring'and Test Equipment ME.
Moisture Element = MI. Maintenance Instruction 'NER Nuclear. Experience Review { NIC' Nuclear. Industry = Check -Valve Group ' NDE Nondestructive Examination-sNETP' Nuclear Employee Training ~ Periodic , NMWTPt New Make-up Water Treatment Plant .. ,
' l-a b
- ' ' - ' " APPENDIX 3 Sequoyah MaTntenance Team Insnectinn , , Report Nos. 50-327, 328/90-25 Of TREE g , ,. _,,, m eos on. x nu.w ,
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