IR 05000334/1989080
| ML20011F748 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/22/1990 |
| From: | Chaudhary S, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011F744 | List: |
| References | |
| 50-334-89-80, 50-412-89-80, NUDOCS 9003070368 | |
| Download: ML20011F748 (40) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-334/89-80 50-412/89-80 Docket Nos.
50-334 50-412
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License No.
DPR-66 NPF-73 Licensee:
Duquesne Light Company
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Post Office Box 4
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Shippinoport, Pennsylvania 15077 Facility Name:
Beaver Valley Power Station, Units 1 and 2 Inspection At:
Shippingport, Pennsylvania Inspection Dates: September 11 - 29, 1989 Inspectors:
b. M.
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d 2 2, / 9' 90
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S. K. Chaudhary, Senior Reacirfr Engineer, date
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MPS, EB, DRS, Region I, Team Leader l
Team Mcmbers: A Finkel, Senior Reactor Engineer, OPS, OB, DRS N. Kadambi, Senior Reactor Engineer, NRR, DOEA, DGCB
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R. Nimitz, Senior Radiation Specialist D. Tondi, Section Chief, NRR, DCST, SELB P. Wilson, Resident Inspector, Beaver Valley Power Station R. Winters, Reactor Engineer, MPS, EB, DRS
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2/tJ/90 Approved by:
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/J/' Strosnider, Chief, Materials & Processes date L/Section, Engineering Branch, DRS, RI Inspection Summary:
See Executive Summary.
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EXECUTIVE SUMMARY The NRC conducted a maintenance team inspection of the Beaver Valley Power Stations, Unit Nos. I and 2, during the period from September 11 through September 29, 1989. The inspection focused on the adequacy of the program procedures, material condition of the facility equipment, observation of maintenance work in progress, activities supporting maintenance, and on management oversight and support of the program.
Review of overall plant performance indicated that maintenance activities have been effective in supporting safe and reliable operation of both units.
Both units have a higher than average plant availability and a relatively low number of challenges to safety systems due to maintenance activities over the past 18 month period.
Housekeeping at both units was generally good.
The material condition of Unit 2 was excellent. There were some nonsafety related components in Unit I which were in a degraded condition.
Strong management support for maintenance was evident throughout the plant in programs affecting maintenance and the reliability of safety related systems.
It was determined that management regularly evaluates the need for improvement and provides training and equipment to enhance the effectiveness of the staff and program.
It was noted that you do not have an overall corporate guidance document that integrates the efforts of the individual organizational elements involved in the various aspects of maintenance. Development of such a document could improve the program and help to assure good performance in the future.
In the area of maintenance implementation, the team concluded that the organization had a well developed program for performing corrective and preventive maintenance. The main strength of the organization lies in its highly trained and competent staff. Careful selection for specific jobs and effective training programs assure ths.t plant maintenance and contractor personnel are well qualified to perform their jcbs. A summary of weaknesses identified by the inspection team is tabukted in the Attachtent 3 of tMs report.
The scope and methodology of the insptction were largely prescribed by the NRC Temporary Instruction for maintenance team inspections and the inspection tree included with the instruction, which are described in the body of this repor T
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l DETAILS 1.0 Introduction 1.1 Background The Nuclear Regulatory Commission considers the effective maintenance of equip-ment and components a major aspect of ensuring safe nuclear plant operations and has made this objective one of the NRC's highest priorities. To this end, the Commission issued a Policy Statement, dated March 23, 1988, that states,
"It is the objective of the Commission that all components, systems, and structures of nuclear power plants be maintained so that plant equipment will perform its intended function when required.
To accomplish this objective, each licensee should develop and implement a maintenance program which provides for the periodic evaluation, and prompt repair of plant components, systems, and structures to ensure their availability."
To ensure effective implementation of the Commission's maintenance policy, the NRC staff has undertaken a major program to inspect and evaluate the effectiveness of licensee maintenance activities.
This inspection was one of a series being performed by the NRC to evaluate the effectiveness of maintenance activities at licensed power reactors.
The inspection was conducted in accordance with the guidance provided in NRC Temporary Instruction 2515.97 and
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the NRC Maintenance Inspection Guidance.
The Temporary Instruction includes a
" Maintenance Inspection Tree" that identifies the major elements associated with effective plant maint cance.
1.2 Conduct of the Inspection On August 4, 1989, Duquesne Light Company (the licensee) was notified by a letter from NRC Region I of the planned inspection, and was requested to provide site specific information related to the maintenance activities et the plant. A copy of this letter and the enclosure requesting the information is attached with this report ( Attacnment 2). Bated on this request, comprehensive pre-inspection information was provided by the licensee to the NRC Region I inspection team.
The NRC inspection team spent from September 11 to September 15, 1989, reviewing this submittal, including evaluation of the adequacy of the established program and procedures, and preparing for onsite inspection of the maintenance program implementation.
The team performed the onsite inspection at Beaver Valley Power Station, Units 1&2 from September 18 to September 29, 1989. The onsite inspection focused on the observation of maintenance work in progress during the inspection period and on licensee activities supporting this work. The selection of maintenance activities for review and inspection by the inspection team was based on the scope of work in progress during the inspection period, recent failures of safety-related equipment, special interest items, and NRC inspection expervsnce.
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A presentation of the Beaver Valley Power Station Maintenance Program was given by the licensee on September 18, 1989, following the entrance meeting.
The following items were discussed during the presentation:
Organization & Staffing
Preventive and Predictive Maintenance
Surveillance
Corrective Maintenance
Equipment Upgrades
Deficiency _ Reporting
Post-Maintenance Testing Program
Daily meetings were held by the NRC team leader with plant management and maintenance supervision to summarize the inspection team findings and identify areas where additional information was required.
On September 28, 1989, a
meeting was held during which each NRC inspector presented the significant findings to Beaver Valley Power Station management. A summary of the inspection
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team findings, including a presentation of an evaluated maintenance inspection tree, was discussed with licensee representatives including management, super-visors and engineers at an onsite exit meeting on September 29,1989. (see Attachment 1 for attendees).
The inspection team's conclusions about the status of the plant's maintenance program are indicated by colors (green, yellow, or red) on the maintenance inspection tree (Figure 1),
For parts II and III of the tree, the upper left portion of each block indicates how well the topic of the block is described and documented in the plant maintenance program, including adequacy of procedures. The lower right pot tion of each block indicates the team's conclusion as to the effectiveness of implementation of the topic covered by that block. Green indicates that the program is well documented or that the program implementation is effective.
However, even for blocks shaded green, some areas for improvement may be indicated in the report.
Ye_Ilow indicates a marginal but acceptable condition and Led indicates the topic is missing or e
the intent of that portion of the tree is not being met by the maintenance activities.
Blue indicates the item was not evaluated or could not be properly evaluated due to recent changes.
The inspection team conclucied that the licensee has developed a maintenance program at the Beaver Valley Power Station, Units 1 & 2 that implements the significant attributes of the maintenance tree.
The team identified a number of strengths and weaknesses that are discussed in the report. Weakness %
L represent potential problems or conditions presented for the licensee enivation g
and corrective action as applicable. As weaknesses were identified by tae inspection team members, they were presented to licensee representatives for initial review and evaluation during the course of the inspection.
Individual weaknesses are discussed in the appropriate areas of the report and are summarized in Attachment 3 to this report.
The licensee is encouraged to conduct its own evaluation of maintenance related activities using the maintenance inspection tree with the objective of finding areas for improvement not identified by the previous self-assessment or this NRC team inspection.
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INSPECTION FINDINGS This report presents the inspection team's findings and conclusions regarding i
the Duquesne Light Company's (DLC), Beaver Valley Power Station, Units 1 and 2 site maintenance program and its implementation. The section numbers of this report correspond to the numbering sequence of the Maintenance Inspection Tree (Figure 1).
OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE 1.0 DIRECT MEASURES
, Scope The objective of the inspection in this area was to determine the effectiveness of the licensee's maintenance program to assure the safe and reliable operation of the Beaver Valley Nuclear Power Plant, Units 1 and 2.
The inspection consisted of reviews of historical data, extensive walkdown inspections in the plants to
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assess the current naterial condition of equipment and maintenance practices established by the licensee.
Plant performance indicators, previous Systematic Assessment of Licensee Performance reports, Licensee Event Reports, the NRC AE00 Gray Book, and recent NRC inspection reports along with historical and current operating data were reviewed to assess the impact of maintenance activities on the safety and reliability of the plants.
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Findings The above review disclosed that the maintenance program implemented by the licensee was generally effective in assuring safe and reliable operation of the plants. The availability of both units was good; the backlog of corrective and preventive maintenance work orders was small; and, there was only a small number of missed surveillances, indicating a well implemented and effective maintenance program.
Although the maintenance program was found to be generally effective, there were occasional lapses which adversely affected plant operations. The team noted that within the past 18 months, three challenges to safety systems (resulting in two forced outages) were attributed to inadequate maintenance activities. One inadvertent Engineered Safety Features (ESF) actuation and a reactor trip resulted from a failure to follow the applicable maintenance -
surveillance procedures; an emergency electrical bus was inadvertently deenergized due to inadequate review of electrical schematics; and, a personnel error delayed reenvery of Unit 2 from a refueling outage due to an unaccounted pressure seal ring on the Reactor Vessel Level Indicating System and the discovery of an incorrect flow orifice along with the lack of a required orifice in the Resistance Temperature Detector manifold rendering the system inoperable, i
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During the Unit 1 outage, the licensee maintained a separate Unit I equipment clearance group which prepared and implemented clearances on plant systems.
The clearance group was made up of licensed operators (including senior reactor operators) and auxiliary operators.
The inspector reviewed selected clearances to determine whether the clearances were adequate for their stated purpose, and verified that the associated clearance tags were properly attached. No deficiencies were identified.
The control room operators and the clearance group maintained several status boards in the control room depicting system status, boration flow paths, and active clearances.
Particularly noteworthy, were the piping and valve diagrams used for indicating active clearances on various plant systems.
The inspector reviewed these status boards against selected active clearances and found that the status of the clearances was accurately reflected.
The inspectors performed detailed walkdown inspections in both units to assess housekeeping and the material condition of the plant.
Housekeeping was found to be generally good at both units.
The material condition of Unit 2 was found to be excellent. There were, however, some areas that needed licensee attention.
For example, in Unit 2 the primary sample panel area and valve gallery had excessive dirt and debris, and in the boron recovery tank cubical, spilled boron from an apparent blowdown / overfill of the tank covered a portion of the floor. Otherwise, plant equipment has been well maintained since the unit began commercial operation in November 1987.
Although several material deficiencies were observed in nonsafety systems, the materiti condition of Unit I was adequate.
The refueling water storage tank cooling water heat exchangers, valves, and piping were heavily corrodtd with both pitting and general corrosion. There were aise. large quantities of boron crystal buildup on the components and on the floor. A Component Cooling Water (CCR) pipe support near valve TV1CCR-123-2 was complete *4y corroded through, and approximately nine chilled water valves appeared to be corroded beyond repair.
In the main steam valve room, degraded lagging (i.e., missing and torn) on the
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main steam and main feedwater pipes was found.
In addition, a body / bonnet leak
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was identified on a main steam line drain isolation valve, MOV-MS105. A hinge pin leak un the A feedwater line isolation valve, IMOV-FW156A, was also identified.
There 5.ere several other material deficiencies observed; but, the degradation was not as severe as those discussed above.
However, the majority of the material deficiencies observed by the inspectors had previously been identified by the licensee.
In June, 1989, the licensee g
implemented Site Administrative Procedure ($AP) 58, " Plant Inspection Program."
j SAP 58 requires site managers to periodically tour the site to identify material l
deficiencies, industrial safety hazards, and/or cleanliness, housekeeping, and
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radiological protection problems. The managers rotate through different pre-
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selected inspection zones es:h week and observed deficiencies are tracked in a computer data base.
Due to the program's recent implementation, corrective actions for the material deficiencies identified on nonsafety related components have not yet been initiated, d
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l The inspectors reviewed several Quality Control (QC) Deficiency Reports (DR)
generated during maintenance activities to determine the thoroughness and time-liness of the reports. Also, the DR management tracking system was reviewed.
The inspector found that the QC DRs were of high quality, clearly describing the observed deficiencies. The responses to the DRs were usually completed ahead of the required 14 day time limit.
The QC department has a computer tracking system for DRs and issues status reports to licensee senior management on a monthly basis.
Conclusion With only a few exceptions and within the areas inspected, maintenance activities were noted to be effective in supporting safe and reliable operation of both units. Both units have a higher than average plant availability which is commensurate with the relatively low number (three) of challenges to safety systems due to maintenance activities over the past 18 month period.
Housekeep-ing was generally good at both units. The material condition of Unit 2 was excellent; however, in Unit 1, there were several nonsafety related components which were in a degraded condition.
The extensive use of status boards in the control room, especially the piping and valve diagrams, is a noteworthy strength.
2.0 MANAGEMENT SUPPORT OF MAINTENANCE Scope This part of the inspection assessed plant and corporate support of maintenance activities in the plant with respect to the establishment, implementation and control of an effective maintenance program. The major areas evaluated were
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management's commitment to and involvement in the organization and administration,
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resource allocation, and technical support provided to the maintenance organi:a-
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tion. Discrete elements within these areas, such as a documented maintencnce plan, self assessment measures, resource allocation, definition of maintenance requirements, and accountability, were evaluated to provide a basis for the team's overall assessment.
Findings The team evaluated these elements through extensive discussions and interviews with plant and corporate staff; review of the licensee's planned, in progress,
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or completed activities with respect to INPO initiatives; industry event communi-cations; and the licensee's experience and analysis of plant performance data.
The corporate and plant management representatives interviewed indicated strong support and interest in the proper performance of plant maintenance. Their commitment to and support of improved maintenance was evident by the recent initiatives implemented in this are o,
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Major initiatives by the licensee to assess the effectiveness of the mainte-nance effort and the safety of selected plant systems consisted of an extensive self assessment of the maintenance program.
In the recent past, an audit was performed using the INPO maintenance guidelines as a guide in the preparation of the checklist to determine the effectiveness of the maintenance program.
In addition, the DLC Performance Analysis Unit performed an assessment of the main-tenance department.
The corporate goals and objectives were used as measures of the effectiveness of the maintenance organization.
In all, sixteen items were recommenced to improve the effectiveness of the program.
The licensee is in the process of developing a schedule to complete all of the corrective actions that have been planned in response to the audit findings.
The team noted that extensive use was made of the computer system in the main-tenance department.
Individuals were familiar with the system and comfortable in its use.
Licensee personnel demonstrated access to the DLC databases, e.g.,
Master Equipment List (MEL), and the material stock list. The MEL has approxi-mately 160,000 pieces or' equipment listed for both units and provides information such as the status (Safety related, environmental qualification, and electrical class), parts requirements for routine maintenance, and the manual number and location. The information is available to the user by entering the mark number and location of the desired item.
The system works by the computer searching each of several independently maintained databases and combining the information without additional requests from the user.
In the case of assemblies, such as a pump and motor combination, the system is designed to provide information on all of the components when any one of the components is specified, providing an extremely user friendly means of access to the files.
The licensee is working to expand the available information by including the document control informa-tion database in the system; thus, including maintenance procedures, and addi-tional information on the correct revisions to vendor technical information end recommendations.
At the inspector's request, the licensee demonstrated several reports that could be generated from the INPO database.
Such reports included information that varied in the amount of detail, but did include a contact in the originating organization that could provide additional details if necessary. These reports are used by the station staff in planning maintenance, parts procurement, and work control.
The licensee maintains an extensive training program for maintenance o rkers.
This program ranges from a basic course in tools and the proper use.5ereof, to specific courses in repairing complex equipment.
The courses are generally divided between classroom work given by the independent training department, g
and "on-the-job" training given by senior maintenance mechanics and maintenance supervision. The inspector observed that the courses were continuing in the training department during the present refueling outage indicating that a high value is placed on the training coursos by managemen *
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t Another database is being developed by the licensee to help prepare and track Maintenance Work Requests (MWR). This program is not yet to the point where it
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is used in writing MWRs; however, when the MWR is written the maintenance planner can enter the mark number and location of the equipment to be repaired, and
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information such as safety classification, quality control requirements, and normal materials requirements are provided by the database to reduce errors in preparing the MWRs.
In addition, after the completion of the work the system is used to identify equipment that indicates excessive maintenance needs; thus,
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drawing attention to responsible personnel to the equipment maintenance history
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of the need for a root cause analysis.
Conclusions The corporate and plant management strongly support and continually strive to
improve the plant performance by improving maintenance. The overall management t
support to maintenance is good.
3.0 MANAGEMENT ORGANIZATION AND ADMINISTRATION (CORPORATE AND PLANT)
Scope l
The objective in this area was to assess the effectiveness of the organization and administration of the maintenance functions and the maintenance program, respectively.
The specific areas inspected to provide a broader perspective of maintenance activities included:
the existence, availability, and scope of a forma 1' maintenance program; maintenance policy, goals, and objectives; allocatich
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of resources; identification and definition of maintenahce requirements; main-ten 6nce performance measurement; the docnent control s.ystem for maintenar.ce; and the maintenance decision process.
Finding
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Beaver Valley Nuclear Power Station (RVNPS) has a maintenance program that covers all the major programmatic elements.
It establishes requirements for mechanical,
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electrical, instrumentation and control, construction, and planning and scheduling maintenance functions.
The existing policy directives cover all the organizational elements and subelements that contribute to the maintenance function.
However, the BVNPS does not have a unified and comprehensive document that provides station wide guidance on the policy,-goals, objectives, structure, and constraints on the maintenance function. The guidance for most of these aspects are dispersed among various organizational elements, levels of management and g'
directives and procedures.
For example, the highest level guidance is provided by the Nuclear Group Directives and the Corporate Mimon Statement.
Not all managers had familiarity with and ready access to these documents. Also, it was not clear that the managers understood the hierarchy of implementing documents and procedures to obtain working guidance across organizational boundaries.
For example, the site administrative procedures (SAP) are intended to establish requirements on a station wide basis, superseding the departmental manual in case of conflicts or potential conflicts among departmental manuals.
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conflicts between the maintenance manual and I&C manual are resolved by complying with the SAP guidance.
It was found, however, during the inspection that a lack of consistency existed in interpreting " emergency" actions and the use of the maintenance work request (MWR) by various departments. The department level manuals contain somewhat differing definitions of an " emergency" action; and, c
with respect to MWRs, although the SAP requires all corrective maintenance to be conducted on the basis of a formal MWR, the I&C manual indicates that an MWR is optional.
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However, despite the above inconsistencies, implementation of maintenance was not adversely affected. Monthly performance indicators show that the maintenance backlog is appropriately prioritized and processed such that objectives are consistently achieved.
The inspector determined that good performance in main-tenance is due to the high level of management attention given to maintenance.
The personnel involved in maintenance at all levels have developed effective working relationships between departments such that performance objectives are consistently achieved.
However, documentation and formalization of the actual practice would strengthen the maintenance program by maintaining continuity in case of personnel changes,
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I Direct observation of maintenance activities, review of completed maintenance actions, and a review of selected performance indicators show that BVNPS manage-ment allocates sufficient resources for the maintenance functions, Personnel are a"ailable in sufficient numbers with satisfactory training and experience to implement an effective program. Although contractor supcort is used, the contractors are integrated into the licensee orgar.1zational e1wents uncter diret;t supervision by licensee personnel; thus, maintaining accountability with the
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licensee's own emp*m ees. The increase in the number of mechanics and electricians hes kept the amount of overtime at acceptable levels.
Interviews with personnel indicated that ncterial support, such as computers, is provided at an adequate level. Technical support for maintenance is available through the use of engintering p ooranda. The team determined that the g stem as currently used is satisfactory to provide adequate technical support to routine maintentnce
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activities.
The maintenance requirements are adequately defined in terms of corrective, preventive and predictive types of maintenance.
The planning and scheduling of preventive maintenance is effectively carried out.
If the nature of a maintenance task changes from preventive to corrective, the procedures define a traceable mechanism to allow appropriate handling.
The predictive maintenance efforts
are of recent origin, and the program is developing satisfactorily. The licensee
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has implemented the use of the state-of-the-art technology, such as vibration
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monitoring and infrared technology to develop the predictive maintenance program.
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The authority and responsibility to initiate maintenance actions has been given
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to all plant personnel.
The initiating document is the MWR form, and its use has been defined in SAP-30. The process of documenting and controlling the corrective maintenance activity using the MWR form has been adequately defined in SAP-3D. The process for changing maintenance requirements, after a task has
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been planned and implemented, has also been adequately addressed, Also, appropriate consideration has been given to participation by the quality control l
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organization, obtaining operational clearances, and post maintenance testing.
Further improvements in the planning for maintenance are being developed. After completion of the maintenance activity, appropriate provision has been made for closeout of the MWRs by the maintenance section and for retention of records.
The overall effectiveness of the maintenance program is measured and evaluated by audits and surveillances of the maintenance function by outside groups, such as quality assurance (QA) and the independent safety evaluation group (ISEG).
The QA unit has a wide latitude to conduct audits for assurance of quality.
In addition to meeting regulatory criteria, the audits appear to be directed toward meeting insurance requirements as well.
Based on the review of the guidelines for the audits and recently completed audits, the inspector determined that the degree of surveillance exercised by QA over the maintenance functions was adequate.
In closing out a MWR, the maintenance department at BVNPS attempts to perform a root cause analysis.
If unable to do so, the policy described in SAP-3D directs the employee to " Preparation of Incident Reports and Conduct of Critiques," SAP-13. Although, SAP-13 has broad applicability, it is primarily used for preparation of incident reports and critiques associated with relative-ly serious events.
Therefore, the main avenue for root cause determination of failures appears to be the use of the equipment f ailure trend report generated by quarterly meetihgs of representatives of mechanical maintenance, electrical maintenance, I&C, engineering, planning & outage management, and operations.
The trend report is based on consideration of four or more MWRs written against a component during the previous 32 months. Although a satisfactory root cause analysis is performed, and the action plan generates a good follow through, the program does not incorporate a graded response to failums to assure that & root cause analysis is performed before a potentially serious event or multiple failures occur in a component.
The document control system for maintenance is centrally controlled by the MWR process defined in SAP-30.
Although there are some ambiguities in it, the SAP is adequate to establish the requisite document control system.
Provision is made for establishment of responsibility, accountability, authority, lines of communication, and review and updating.
However, there was some indication of laxity in implementation (see section 5.0), but as described in section 5, (work control), the lack of attention to detail observed on some occasions did not result in significant problems. The MWR process at BVNPS would be strengthened if the rigor of implementation of the MWR process if improved.
I The maintenance decision process was inspected by observing ongoing activities
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and records of past activities.
It is evident that decisions regarding mainten-ance are made with participation by appropriate groups in regular meetings that occur several times a day during a major outage.
The meetings are well structured and provide an adequate means to resolve interface problems between organizational elements. The activities discussed in these meetings are appropriate for the level of the personnel present.
The presence of all support groups onsite facilitates involvement of all the groups at all levels of management in the ongoing activities.
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Conclusions Based on the above, the team concluded that the BVNPS program for maintenance activities has received the appropriate management attention and incorporates the major elements required for effective implementation.
The program has been staffed by qualified and experienced employees who work together well to achieve the organizational objectives. There is potential for improvement in the over611 program in the following areas:
(a) There appears to be a need for a unified and comprehensive policy guidance document that directs the efforts of the organizational elements that contribute to the various maintenance functions.
In the absence of such unified guidance, different groups have developed varying procedures to implement the policy as perceived by each group.
The existence of a coherent top level policy document on maintenance that establishes the scope of responsibility of departments that participate in maintenance,
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such as construction, engineering, and plant management would promote uniformity, accountability, and assessment of effectiveness of this program.
Such a policy document also would establish the extent of surveillance that must be exercised by organizational elements such as OA and ISEG.
(b) The formal process for root cause determination for equipment failures is Initiated only when '.he failure is of 4. relatively toerious nature, or when repeated failures occur.
A structured and graded response to failures l
could improve the program by instituting a root cause analysis in a more timely manner.
The structured analysis employed ty ISEG in specific cases is an acceptable model.
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(c) Currently, corrective maintenance is controlled by the MWR system, and the associeted policy guidance in SAP.'4.
It was noted that an occasional lack of rigor cxists in the use of the MWR forn.
The reliability of the maintenance program can be enhanced by ensuring that all the requirements of the MWR form are consistently rnet.
In summary, maintenance is effectively implemented at BVNPS through the com-petence and team work of the people involved in this effort. The documentation is generally traceable and auditable. The MWR process provides a mechanism to identify the need for corrective maintenance in a timely manner; to focus the support activities on each maintenance task; and to plan, execute, and finally closeout the action.
The strength of the program lies in the skill and dedication of the maintenance staff.
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4.0 TECHNICAL SUPPORT Scope The inspectors evaluated the technical support that the maintenance department receives from other parts of the organization, such as Engineering, Radiological Controls, Quality Assurance, Quality Control, Fire Protection, and Operations.
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The evaluation consisted of a review of the licensee's established policy, goals, and objectives, and an assessment of their effectivenest. The team selected maintenance related items from the generic PRA study, Licensee Event Reports-and generic issues identified by the NRC and other industry sources and evaluated how maintenance and other organizations interacted on these issues.
Internal / Corporate Communication Channels Scope The objective of this inspection element was to evaluate the licensee's organiza-tion and communication systems to assure that corporate policies for the mainten-ance organization had been incorporated into plant procedures, and a feedback system had been established so that maintenance concerns were identified to management for their attention and action as required.
Findings The station management's primary means of communicating short term and long term maintenance issues and concerns to appropriate personnel is through the regularly scheduled planning meetings.
These planning meetings are held three times per day during outages and once per week during non-outage periods.
Two of the meetings held daily during outage periods are attended by supervisors and managers involved in day-to-dsj maintenance and maintenance support activitics.
The third meeting held during outage periods is attended by managers to plan
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and review these 6ctivities at the imagement level. Minimal technical details are discussed at the managers meeting while technical details, necessary to understand the extent of problems or concerns, are discussed at the other two meetings. During non-outage periods, the once per week meetings are held to discuss upcoming activities, concerns, or issues.
Detailed schedules, covering upcoming maintenance activities, are updated at the meetings.
By attending the outage meetings, inspectors found them to be effective in presenting work status, establishing work priorities, and coordinating upcoming activities.
The licensee also has implemented a program to communicate goals for maintenance related areas.
These broad based goals are contained in the yearly Nuclear Group Mission Statement and Action Program Reports. The goals have been incorporated into the personnel performance appraisal system. The team considers this a good method to transmit corporate goals and initiatives to the working levels of the station organization.
Implementation of the goals is reviewed during performance appraisal reviews.
I Conclusions The licensee's organization exhibited strong communications in response to outage and non-outage maintenance related issues, The daily meetings were effectiv9 and productive.
The " goals" program was considered a good method to transmit corporate goals to the organization.
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Engineering Support Scope To evaluate the extent of the engineering department's involvement in the plant maintenance process, the team reviewed the licensee's administrative procedures,
engineering procedures, and engineering documents related to the corrective, preventive and predictive maintenance programs. This was accomplished by reviewing maintenance work orders, analysis of unusual events and equipment failures, and engineering's technical support to the maintenance program.
Findings The licensee's Nuclear Engineering Department (NED) is organized on the basis of engineering disciplines. The NED essentially coordinates its day-to-day
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involvement with maintenance on an as requested basis.
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In the area of engineering support to maintenance, the maintenance organization transmits concerns for review to the engineering department by means of the engineering memorandum (EM). This formalized program was considered effective in relaying maintenance concerns or problems to cr.gineering for resolution and feedbact..
NED has a core of pe"manent staff tnat prevides engineering services to the plants. This ataff is augmented on an ss needed basis for unanticipated work icees or foe worx requiring special expertise from outside contractors.
The contracted eng'reering personnel, however, perform their functions under the
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direct supervisior of DLC engineers and the engineering assurance program.
Failure analyses performed t>> NED appear to be thorough. These analyses are an integral part of NED's contributior, to the maintenance program.
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NED routinely establishes post maintenance test requirements, and reviews the test results to assess the adequacy and technical validity of specified tests in establishing the equipment operability criteria.
The post maintenance test also serves the purpose of validating the adequacy of the corrective maintenance process.
Conclusions Engineering support to maintenance has been well integrated.
The permanent engineering staff with additional technical support from contractors on an as g
needed basis provides satisfactory technical support to maintenance.
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Role of PRA in the Maintenance Process Scope The objective of this part of the inspection was to determine the extent that Probabilistic Risk Assessment (PRA) concepts are considered in the maintenance program and in such areas as planning, scheduling, and prioritization of work.
The inspector reviewed licensee activities related to the application of PRA to the maintenance program. This subject has been under active review within the NRC and has resulted in the issuance of Generic Letter 88-20.
Findings The licensee has no formal documented program or goals for the integration of PRA into the maintenance program, although the licensee is aware of those systems which present a major impact upon plant safety.
The Team found that the licensee was aggressively pursuing comoletion of a PRA study for Unit 2.
A contractor was being used to perfore the work with support from licensee personnel.
The licensee is planning a PRA study for Unit 3 by in house personnel. They have developed a draft Probabilistic Assessment Project Plan and a draft P'ebab111stic Risk Management P ocedure.
These documeats will provide the overall direction for use of PRA by the itcensee. Management has enigned dedicated persennei full time to the area of PRA.
Selected licensee personnel have receise:f formal tr61ning in PRA methodtlogy and are gaining experience by workfog witt the centractor f or the Unit 2 PRA studies.
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Licensee managen.er.t has not established an approved program, procedures, or goals
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for the use of PRA concepts in the maintenance area. Maintenance activities of selected PRA significant systems and components were -xamined, and the inspector found effective maintenance and technical support.
Role of Quality Control Scope The objective of this part of the inspection was to determine the extent of Quality Control (QC) involvement in the maintenance process.
The inspectors reviewed the licensee's procedures for implementing the QC inspection and surveillance programs. The process of analyzing and trending of QC findings
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was also reviewed. Discussions were held with QC personnel to assess the adequacy of implementation of the program.
Findings The scope and direction of QC inspections are established during the job planning stages by maintenance planners to meet the requirements of applicable procedures.
The QC Department, which is organizationally independent of the maintenance department, reviews and concurs with the planned inspection
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schedule, and establishes additional hold points, if necessary.
The QC department effectively plans and schedules inspections to support the on going maintenance work.
The inspector reviewed the inspection planning methods, and found it to be adequate.
The scheduling of inspection is largely dependent on and in response to the workload planned and scheduled by the maintenance depart-ment. The inspector did not find evidence of missed or inadequate inspections.
The inspectors reviewed several maintenance request packages, associated main-tenance procedures, QC instructions, and inspection reports to determine the adequacy of this process of inspection planning. The inspectors also review 9d deficiency reports (DR) to assess the effectiveness, thoroughness and timeliness of QC inspections, and the process of dispositioning findings.
The tracking system for DRs also was reviewed. The inspector determined that the responses to DRs were technically satisfactory and were usually completed ahead of the
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required due date.
The QC Department maintains a dual tracking system, one manual-hard copy and the other on a computer database.
The manual system is considered the official record.
The computer database is accessible to the maintenance department and others through the computer system in use on the site.
The insrectors further observed that the "stop work" authority (temporary work suspension) given to the QC inspectors is quite wide anu effectively supported by shn meagement.
Conclusicos The team an:1utied that planting and scheduling of inspectior s were adequate,
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and the QC insDE: tors do use their "stop work" 6uthority frequently dJring the'r inpronst inspections, and Nele temporary work ttuppages are rarmally reported as remarks on the QC iaspection reports.
Hovever, these d6ta ate not compiled and trenced to assess the quality of the preparation and execution of
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maintenance work as performed.
By eliminating this information from the analysis of maintenance department performance, the analysis is significantly biased to indicate better performance.
Presently, there is no structured method of tracking and reporting this information for inclusion in the analysis and management reports.
Integration of Radiological Controls into Maintenance Process Scope The objective of this part of the inspection was to determine the coordination and integration of radiological controls into the planning and performance of maintenance work.
I The inspection included a review of the "As Low As Reasonably Achievable" (ALARA) steps that were incorporated into work planning as well as ALARA practiced as work was performe _ _..-
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Findings The licensee has established policies and procedures to provide for the integra-tion of radiological and ALARA controls into the maintenance process.
The radiation work permit is the principle means of evaluating the need for radiological and ALARA controls.
All personnel who enter the radiological controlled area (RCA) to perform work, inspections, or tours must sign in on an radiation work permit (RWP).
Personnel wishing to perform any work in the RCA must complete an RWP request. The RWP request provides for completion of ALARA reviews by both job supervisors and ALARA coordinators.
The ALARA Coordinators review RWP requests and evaluate the need for job specific ALARA reviews and controls. The NRC inspector's reviews of work planning and on going work activities noted use of mock-ups and special training, specifically implemented to reduce exposure on work tasks.
For example, mock-ups and training x
were provided for steam generator and reactor coolant pump workerr., The licensee
has initiated ALARA tours to oversee on going work to enf ure work is being conducted in a manner that is consistent with initial ALARA planning.
Also, ALARA personnel were notrd to be in attendance at work planning and scherhling irretings and provided positive input to the meetings. Workers and supervisors were receptive to ALARA initiattves.
The inter-and intra-departmental coordination between the radiclogical controls ar.d raaintenance organizations was considered good. Observations by team mem%ers indicated adequate radiological support to the maintenance process. Although ALARA procedures did not specify minimum notification times when the ALARA group should be notified of upcoming work for the purpose of planning ALARA coordinators were noted to be involved in planning for work activities well before start of the work.
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The licensee tracks accumulated exposure for each RWP on a daily basis.
The accumulated exposures are compared to initial exposure estimates.
Reviews are initiated of work activities when accumulated exposures are within a certain fraction of the initial estimate. Although ALARA goals were established for appropriate work activities, the licensee was tracking performance relative to
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the initial estimates which did not consider ALARA initiatives which were incorporated after the work began.
This was considered a weakness in that the initial estimates were not considered challenging ALARA goals. Also, ALARA review forms required to be completed by job supervisors were not completed.
The integration of radiological controls into the maintenance process was
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generally conducted in accordance with policies and procedures.
Observations of work in progress by team members indicated that job coverage by radiological controls technicians (RCTs) was adequate, and that workers were sensitive to
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compliance with RWP requirements.
However, the RWP procedure, used to provide radiological controls for work was cumbersome in that it included numerous forms requiring completion by technicians when overseeing on going wor r
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Team member review of RWPs noted incomplete forms in the RWP package at work locations.
Forms that were incomplete or incorrectly completed included radiological controls requirements for the work and worker briefing forms.
This was considered a significant weakness. These observations indicated an apparent need for increased oversight of radiological work activities by the supervisors.
Specific weaknesses discussed above in the area of ALARA and RWP adequacy are documented in detail in the NRC Inspection Report No. 50-334/89-21, and 50-412/89-20.
Conclusions Raciological controls are adequately integrated into the maintenance program.
Overall ALARA controls for maintenance activities work were considered adequate.
However, tracking of work relative to ALARA goals needs improvement in that goals used were not challenging. Also the radiation work permit was cumbersome resulting in errors and lack of f:ompletion of RWP package forms. %ere is a need for increaud oversight of work 6ctivities by supervisors.
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!afety Review of Maintenance Activities
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The r,bjective of this ir.spectio1 eierent was to evaluate the extent t? which i
safety practices are incerporated into the mintenance process. The tvaltation l
inclued s review of we,k crors, procedures and case"vations of on going main-L tenance activities. The evaluatior covered hazardous materials, electrical safety, fire protection, confined space entry, control of heat stress, and standard industrial safety (e.g., use of safety belts when working at heights).
Findings The onsite safety program is incorporated into the maintenance process in several ways. The principal method is by formal training of personnel in safety concepts and practices. The training is provided via the general employee training program and through specialized modules incorporated into electrical, mechanical, and instrumentation and control (I&C) personnel tra;ning programs. This latter training is provided to personnel within the maintenance and I&C departments.
The licensee has two groups which provide safety oversight at the station. These were construction safety specialists in the nuclear construction group, and industrial safety engineers in the radiological controls group. These groups comunicate often on safety matters, h
The licensee has adopted the Safety Training Observation Program (STOP)
established by the DuPont Company. This training involves personnel filling out observation cards when noting a good safety practice or a deficient practice.
Personnel in the Nuclear Construction Group do receive the STOP training but not the specialty safety training provided to the maintenance
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and I&C Group. The team noted there was no comprehensive review of all safety
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training provided at the station by one group or individual to ensure training was uniform.
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The licensee has had in place a 50 person Safety Awareness Committee since 1982.
The committee is staffed by 25 workers and 25 supervisors who meet periodically to discuss safety issues.
The licensee is strongly supportive of safety at the station. The team noted numerous posters dealing with safety matters. Also, the licensee has instituted awards for the most STOP safety observations in a month.
The licensee tracks and trends safety parformance indicators. However, the trending is not uniform between grcups. The nuclear construction group tracks the performance indicators in a different mariner that is not compatible with the tracking performed by the industrial safety group in the radiological controls organization.
Consequently, the inspector was unable to determine overall station safety performance by reviewing performan:e indicators.
It did appear, however, that each groups' performance was improving.
This is an example of the consequences of not having an overall program coordinator as discussed above.
The licensee is currently developing a comprehensive safety manual fer use onsite. The licensee has proct:dures in place that provide guidance for safety; however, these were incorporated in verious orocedure programs. Al s?, t,he n:ai n-tenance work request did not incorporate provisier.s to refer appropriate work activities to the safety group for review.
Hnwever, the licensee is developing a checklist for use in job planning which will include provisions to notify the safety group when safety is a conterr. on a particular task.
NRC team member observations of on going work activities indicated generally adequate safety practices. However, some isolated instances of poor safety practices were noted.
For example, personnel were noted to be working at high elevations on scaffolding that did not have side rai'is to prevent falls. The licensee immediately initiated a review of this matter when it was brought to his attention.
Conclusion The team found that safety practices were adequately incorporated into work practices. However, improvements could be made in areas such as establishment of a comprehensive safety manual, improved trending of safety performance indicators, and implementation of some specific safety practices on the job.
Integration of Regulatory Documents in the Maintenance Process g
Scope The objective of this part of the inspection was to determine if the methods used to integrate regulatory documents into the maintenance process and to change these documents as a result of periodic reviews and updates was effective.
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Findings
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The licensee has established procedures and policies for processing regulatory and other documents into the maintenance program.
The procedures and policies i
identify the responsible groups or individuals for reviewing the documents.
All regulatory documents are processed by the licensing group.
The documents are entered into a computer tracking system and sent to the responsible individuals or groups for review.
A sampling of recently received regulatory documents shows that they were
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entered into the computer for tracking, and the responsibility for their review was clearly assigned.
Personnel were aware of assigned responsibilities and managemeat was aware of the status of each item.
Inspector review of previously closed items indicated a generally adequate level of review.
Corclusiens Overal.1 certrol of regulatory c'ocuments wss cont.idered effective.
Docuents were assigned fer-7eview thrtugh a forLalizeci process and trackea via computer, M*,1NTENANCE I G LEMENVATION 5.0 WORK CONTROL Scope The purpose of this inspection area was to evaluate the effectiveness of the maintenance work control process to assure that plant safety, operability, and reliability are maintained. The inspectors evaluated the following areas:
Review of work in progress
Control of work orders
Equipment maintenance records
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Job planning
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Work scheduling
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Post maintenance testing
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Completed work control documents
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Finding i
Review of Work in Progress
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The inspectors observed work in progress on the Unit 2 component cooling water
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IE bus; Unit I surveillance testing of the safety related batteries; and sur-veillance testing of Unit 2, 4160 volts safety related breakers. While witnessing the testing of the above electrical components and subsystems, the inspectors noted the maintenance and quality control procedures wera available, and were in use. Discussions with the electrical supervisors and lead technicians found them to be knowledgeable in the plant requirements as well as in the tests they were performing.
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In preparation for the surveillance test on the 4160 volt breakers and the preventive maintenance (PM) work on the component cooling AE bus electrical components, the maintenance and instrumentation and control personnel were given specific instructions by their respective supervisors. The inspectors noted that after receiving authorization from the control roem to work on the equipment, the as-found condition was identified and documented for each piece of equipment in the test procedure before work began.
The inspectors observed preventive maintenance (PM) being performed on the 4 kV feeder breaker, protective relaying; and, motor and pump associated with the component cooling water subsystem of the IE bus.
In reviewing the work packages, the intrectors noted that all parts, materials, and oils were approved and listed in the master equipment list (MEL) for the items identified above.
The procedures were specific for the work to be performed, and the inspectors verified that licenses personnel were performing the work in accordance with the approved instructions. At the completion of the work, each component was tested to its specific post maintenance test criteria. The subsystem testing of the 4 kV faccer breaker, protective relaying, and niotor and pump was performed by the control room operators after the components were released by the maintenance and I&C personnel. The inspectors witnessed the subsystem testing of these components, and verified that tne requirements of the test procedure were met.
The work packages required a final review by the licensee before the subsystem was finally accepted.
The inspectors also observed the battery charger load test on the Unit i battery system. The load profile of the batteries followed the procedure criteria and was well within the required tolerances for both time, voltage, and current.
The inspectors noted that the method of recording the cell voltage was more accurate than was required by the test procedure.
The licensee stated that the procedure step would be changed to reflect the actual method used by the I&C personnel. The method of testing battery cell voltages did not raise any safety concern, and the battery data taken to date was well within the system accuracy requirements.
Work Order Control The inspectors reviewed the licensee's method of work order control.
The vehicle used to control maintenance is the maintenance work request (MWR), described in chapter 3D of the site administrative procedures (SAPS).
The MWR form is comprehensive and has appropriate provisions to cover a wide range of circum-
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stances.
Each MWR bears a unique sequential number, and the initiator's name and date. Appropriate blocks are provided to guide the MWR through the review process, and adequate space is provided for necessary written descriptions.
The MWR is used to perform corrective maintenance, with provisions for the performance of emergency maintenance if appreved by the nuclear shift supervisor l
(NSS).
In addition, the nuclear shift supervisor is authorized to direct main-tenance without an accompanying MWR in an emergency.
In such cases, the MWR is l
to be generated quickly, either before, or immediately af ter completion of the
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maintenance work.
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The approved pol uy and procedures authorize any employee to initiate corrective
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maintenance through the use of the MWR, The MWR form provides for recording information, and for controlling the maintenance process. The Administrative Procedure, SAP-30, estab1h hes the general policy and implementation guidance for the use of the MWR form. The policy is implemented at individual group levels through the use of departmental procedures; for example, Section 1 of the maintenance manual applies to mechanical and electrical maintenance, Section 1 of the I&C administrative manual applies to I&C maintenance, and NCAP-3.4 applies to maintenance performed by the nuclear construction department.
These three groups were identified at the only groups executing maintenance.
In addition to formal department procedures, frequent personal communications and contacts are used to supplement the guidance in sap-3D.
This close and effective personal contact has, however, generated informai methods for accomrlishing work c!dectives.
Fo-example, a copy of most MWRs is routinely trantmli.ted to the control room af ter completing Section 1 of the fore.
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inspactor noted that the above practiet did create some confusion in the case cf one MWR, Observations mad? by the inspector regarding three specific MWRs are as follows:
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The MWR No. 893243 was initiated to perform a modification recommended by the vendor for a check valve, QS-P-1A.
The valvo is safety related (OA Category 1), and is located inside the containment.
The inspector noted that the applicable procedure for work performed in the MWR was incorrect, and this error was not identified by the internal department or QC reviews.
However, the procedure ustd by the maintenance personnel was the correct procedure, despite the error in the MWR, indicating a competent and knowledgeable work force, b.
MWR No. 890966 was initiated to perform a type "C" leak test on a cold leg sampling valve in the post accident sampling system located inside the containment. The inspector observed that the test had to be aborted because the copy of the MWR in the field work package did not contain relevant information.
The cause of this problem was that the control room had recorded the relevant information on the MWR copy informally transmitted
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to the control room. However, it was evident that the responsible individuals were fully cognizant of the information even though the information was not in the package, and the test was aborted on procedural grounds.
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MWRs generated for the Unit 2 component cooling water system during 1989 were inspected.
The records were maintained adequately to permit traceability and audibility.
Most of the records were found to be satisfactory, but in two cases (MWRs 895577 and 899199) the applicable corrective maintenance procedures were not referenced on ti.e MWRs, although they were included in the work packages.
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The conclusion crawn from these observations is that the MWR process works as
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intended to control and record maintenance activities. There appears to be an informality in its use that causes some inettention to detail.
However, because
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the personnel involved have sufficient skill and experience, the maintenance
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objectives are accomplished. Program improvement can be achieved ay paying better attention to detail without decreasing the effectiveness of the positive attributes.
In summary, the MWR format was adequate, and approvals for commencement of work (shift supervisor tag out approval), as well as quality reviews and nuclear i
plant reliability data systems (NPRDS) review, were addressed.
The inspectors
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reviewed all priority 1 MWRs from October 1, 1988, through September 21, 1989, and did not identify any emergency MWRs issued during that period.
Equipment Maintenance Records The inspectors reviewed completed MWRs using the MWR tracking report rystem.
The MWR tracking system provides equipment, part, and system status by using mark numbers, component I.D. er system number. Using the tracking system, the inspecturs were able to identify the status for each of the MWRs selected, and
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verified the status of the backlog by matchirg the MWR numbers with the problun description field of the MWR backlog status report.
Beaver Valley's " Master Equipment List" far exceeds the generally accepted industry standard for such programs.
The Master Equipment List (MEL) includes all safety related and environmentally qualified (EQ) plant equipment as a data
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base. This computerized data base is used by all levels of management at the
site. The inspectors were able to generate a complete MWR package by entering
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the work package number of the selected work witnessed by the inspectors.
The licensee is planning to further enhance the present MEL by the addition of an electronic parts program and the dedication parts program data.
The final step in maintenance request processing is the consideration for nuclear plant reliability data system (NPRDS) applicability.
The inspectors reviewed the licensee's NPRDS process and found it adequate, The licensee's yearly input to NPRDS regarding equipment failure is average for the industry; thus, indicating that the licensee meets the industry norm for NPRDS participation.
Job Plannin;)
The inspectors reviewed various aspects of job planning in use by the licensee.
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Of particular note was evidence of the use o' the MEL and appropriate technical manuals during nonroutine and normal maintenance activities.
The inspectors
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noted that the battery, breaker, and diesel vendor's technical manuals were used during the planning of the work on these items.
In the case of the diesel generator, the parts drawing from the vendor manual was used as part of the MWR work.
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MWR work items have a required walkdown review as part of the work controls.
The work control process is described in plant procedures, Section 1. Conduct cf Maintenance; Chapter 10, Planning and Outage Management Manual; and Section 1, I&C Administrative Manual). When possible, the procedure to be performed is walked through in its entirety.
This process assures that adjustments and tooling, staging, shielding are appropriate and available, and that the procedure is logical, and can be performed as described. When it is not possible to walk through or simulate the work to be performed (e.g., the work is in a high radiation area), experienced staff members review the MWR package and provide their comments on the intended plan.
Every attempt is made to make the walkdown process as complete and accurate as possible to assure an efficient and effective work performance.
However, there appeared to Lt a lack of planning and coordination of work on an area basis. Because the D hs are planned indepencently from ore another, several discrete jobs may be initiated in the same work area at the same time wtthout any overall coordination or hierar:hy of implementation.
This creates an over crowded situation at the work place. The area over crowding generally is an industrial safety concern, and potentially can af fect the quality of implementation. The inspector identified sucn a situation in the emergency diesel oenerator enciesure at Unit 2.
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Work Scheduling Scheduling of maintenance during plant operation is coordinated by the operations department.
Routine maintenance tasks are discussed, scheduled, and tracked by maintenance department foremen, and the shift supervision in the control room.
Larger, nonroutine, maintenance tasks that may stretch over several days or weeks are subjects of discussion at the weekly plant
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staff meeting. These major maintenance tasks thus receive the attention of
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operations, maintenance, and plant supervision.
The maintenance scheduling system used during outages is, by necessity, more sophisticated. During each refueling outage, the operations planning group assumes responsibility for tracking the myriad of maintenance requests associated with the outage. A computer program is used to arrange MWRs both by the system and by numerical order.
Tracking begins when the shift supervisor authorizes work to begin, and ends when post maintenance testing is satisfactorily completed and a " closeout" status entry is entered into the tracking system computer program.
The inspectors reviewed both scheduling systems (Unit 2 during operation and
g Unit I during the present outage) and found them adequate.
The computer tracking system provides flexibility and accuracy for management reviews and status, and is considered by the inspectors to be a strength for controlling
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maintenance programs.
The only area that needed to be strengthened was the area of responsibility
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control when multiple crafts are working different MWRs in the same area. The
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coordination and work controls need to be clearly defined as to who is respon-sible for assuring that the necessary controls are in place to prevent damage or degradation of equipment.
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Post Maintenance Testing The inspectors reviewed several maintenance work requests to determine the
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extent and technical adequacy of post maintenance testing (PMT). The review
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found that PMTs performed were described in Section 32 and documented in Section 46 of the MWRs reviewed and witnessed.
Interviews with the maintenance and operating staff revealed that PMT requirements may be invoked either by maintenance or by operations, as necessary, dependir.; on the work accomplished.
For example, maintenance on safety related motor operated
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valves (MOV) is followed by a manual and operational test (e.g., stroke timing
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and valve position). The process and criteria of PMT are prescribed in the
MOV maintenance procedure which is part of the MWR package.
If necessary, the i
maintent.n=e staff updates the PMT requirements to be more specific in the detailed instractions section of the procedures.
Such changes are considered a 5. trental, in tho licensee's maintenance program.
Review Of Completed Work Centrol Documents The licensee has formalized requirements for the review of completed Maintenance Work Requests (MWR).
The inspectors found that the backlog of MWRs requiring final review was not excessive.
The inspectors interviewed members of the maintenance, and Instrumentation and Controls staffs, and found that the engineers performing the final document reviews were performing detailed and complete reviews.
The reviews consisted of ensuring that the MWRs were complete, and all data taken and values recorded were appropriate; the maintenance and testing
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performed was correct for the problem described; and that the maintenance work package was complete.
Conclusions The licensee has developed a functional work control program.
Work is planned and scheduled in accordance with directives.
The licensee's strength appears to be in the professional attitude and attention to detail shown by the staff.
The staff and management are striving to improve the plant's reliability.
It was apparent that the staff and management recognize the role of effective maintenance (predictive, preventive, and corrective) in overall plant performance.
The strengths of the licensee work control program are in the integrated master equipment list (MEL), and the proceduralized requirement for post maintenance testing.
Especially, when combined with the improvements by the electronic parts program and the additional post maintenance guidance, the managements'
decision making capability and engineering knowledge are enhanced, h
The infrared thermography, and the equipment temperature monitoring program are examples of management initiatives to support and enhance the maintenance program.
The inspectors considered these programs te be licensee's strengths in assuring good performance in the future.
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i 6.0 MAINTENANCEORGANIZATION(PERFORMANCEOFWORK1
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6.1 Electrical, I&C, and Mechanical Maintenance
S_ cope The objective of this area of inspection was to determine the effectiveness and extent of control exercised by the Duquesne Light Company (DLC) maintenance organization for: maintenance activities, contract maintenance personnel, deficiency identification e.nd control, maintenance trending and root cause p
analysis, deficiency identification and control, and established interfaces, t
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Findings Coctrol of Plant Maintenance Activities The inspvctors observed work in progress in the mechanical, e',ectrical, and instrumentation and control (l&C) disciplineh and iaterviewed various staff members that were performing the work.
The team found that maintenance acti-vities follow the steps outlined in the licensee's plant maintenance procedures.
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All work performed by contractor personnel is closely monitored and supervised by the DLC maintenance personnel from site maintenance (Mechanical and Electri-cal) and I&C maintenance (Instrument and Control) organization.
The licensee's approved maintenance administrative procedures, as well as preventive maintenance and surveillance procedures, provide control over the implementation of maintenance work, and configuration control over mechanical, electrical and I&C systems.
Management is sensitive to the need of adequate training, hence, maintenance engineers, foremen, technicians and craft receive sufficient training to perform assigned tasks as well as to maintain their skill.
The maintenance work request (MWR) is used by the licensee to control corrective maintenance activities. The team reviewed, in depth, the MWR process and its effectiveness in assuring that repairs made were adequately documented, proper materials were used in repair, adequate post maintenance testing was conducted,
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and the integrity and safety of the plant was not compromised.
Preventive main-tenance and surveillance work is not conducted under the MWR work control system.
i However, it was determined that the computer generated preventive maintenance and surveillance work requests receive equal management oversight and procedural controls to ensure that the nuclear shif t supervisor (NSS) of operations is g
aware of all activities that might impact the availability of operating systems important to safety.
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materials and work processes, and the quality of workmanship and documentation, the inspectors witnessed wholly or in part the following maintenance work in progress:
4.16 kV ?TE breaker from bus AE, Unit 1
Protective relaying
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Battery charger load test
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Main station battery service discharge test
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Emergency diesel generator (EDG) maintenance and modification
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The " hands on" maintenance and surveillance of these components was performed, in some cases, by contractor personnel (NUS), DLC corporate relay personnel, and by the plant performance and test groups. The plant site maintenance engineer responsible for ongoing work in his assigned unit had a satisfactory program for controlling maintenance work by contractor personnel and others not reporting directly to site maintenance management.
The team also found that the licensee had an effective policy for controlling and updating vendor manuals, the plant technical manuals, and ultimately the plant maintenance procedures that were used in the performance of maintenance activities.
The review of maintenance documen+s used for these activities, in combination
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-with interviews of maintenanct onnel, supervisors, and contractors, indicated
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that administrative and spec'
'k controls were being effectively implemented.
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Maintenance personnel were knv igeable about work controls which applied to t
their activities, and were able w demonstrate how specific controls for which they had responsibility were being implemented.
The team noted that electrical and I&C. maintenance personnel geaerally had the opportunity to exercise judgement on-the methods and techniques for implementing work controls at a level appropriate for a specific activity.
The inspectors observed that the close involvement of supervisory and management personnel during maintenance work in progress provided
additional assurance that work controls were properly implemented, and that contractor personnel conformed to maintenance program requirements.
The inspectors-also noted that the work areas, tools, materials, and replacement parts were properly identified and were consistent with specifications in maintenance work documents.
The licensee is engaged in a major undertaking, especially for Unit 1, to acquire updated vendor information.
The process is intended to assure that vendor manuals, would be reviewed, marked up, as appropriate, and disseminated to the appropriate organizations to update design' drawing, specifications, maintenance procedures and test requirements. During the review the inspector was informed
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by the licensee that it was more difficult to acquire vendor documentation for
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equipment in Unit 1, due to the age of the Unit.
The licensee did have site administrative procedures to control the vendor information program and the procedure was modeled after tne INp0 good practices on the control of vendor documents.
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Control of Contracted Maintenance A significant portion of the maintenance work at Beaver Valley is performed by contractor personnel, especially during refueling outages.
In some cases, contractor personnel work directly under the supervision of the licensee's main-tenance staff. At other times, larger maintenance and modification jobs are conducted under direct supervision of Nuclear Construction Department.
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training, procedures, quality assurance and quality control. Acceptable
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interfaces of management and procedures exist between the plant maintenance and
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Nuclear Construction Organizations.
As presently organized, a great deal of the expertise provided by the Nuclear Construction group does not exist or is limited in numbers in the plant maintenance organization.
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i The inspector reviewed the content of the Nuclear Construction training program.
The program is well planned, and comprehensive training is provided for the work
expected to be performed by construction.
The training consists of classroom j
lectures and on-the-job training.
Recently, the licensee has used more mock-ups
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of actual plant equipment to allow employees to gain actual hands-on experience j
before they start work on equipment which may be located in radiation areas.
j It was also observed that often maintenance procedures contained a sign-off sheet to assure that assigned personnel understood the requirements of the
procedure, and the precautions that were necessary.
i All work performed by contracted personnel is controlled by the maintenance i
organization, whether tnrough the maintenance work request (MWR) form, or
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through the design change request (DCR) process.
.The licensee has provided site administrative procedures to ensure that the
. work performed by construction, including design modifications, is integrated completely into the licensee's comprehensive plant documentation system.
The
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site administrative procedures also assure that the integrity of systems and
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safety of the plant are controlled by the nuclear shift supervisor and the
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designated cognizant supporting maintenance engineer at the time work is l
performed.
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Deficiency Identification and Control i
The team determined that the licensee has a well established program for identifying equipment deficiencies in the plant.
Each deficiency identified is categorized to determine its priority, i.e., MWR work that can be accomplished i
with the plant in various operating modes, or be accomplished during an outage.
The licensee takes appropriate action to assign the deficiency via the MWR system
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to the appropriate maintenance groups for corrective actions.
Based on interviews with different elements of the organization and observations during plant walk throughs, the inspectors established that the required tagging procedures and organizational responsibilities and interactions were effectively implemented.
The inspectors were informed that anyone in the plant was permitted to report equipment deficiencies.
It was observed, however, that most of the equipment deficiencies were documented by operations personnel. Members of supervision j
also were assigned responsibility for oversight of specific areas (physical
plant areas) with regard to material condition with the intent that the assigned supervisory personnel would also identify and report observed equipment deficiencie p qy3
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The inspectors determined that adequate management emphasis has been maintained toward identification.of deficiencies; but, additiona' management attention is required for timely correction of deficiencies.
Examp as for these deficiencies
are discussed in Section 1.0 of this report regarding the material condition
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of some non safety equipment.
Maintenance Trending
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The site maintenance, test, and plant performance organizations have programs for systematic trending of equipment and system failures. The primary purposes of the programs are to (a) identify component / equipment common mode
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failure potentials (b) evaluate the need for increased (or decreased)
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maintenance and surveillance, and (c) to identify needed design changes.
Presently, the equipment failure trending program includes a " trigger" for trending of components that have experienced at least four (4) failures in a consecutive twelve (12) month period.
The licensee also has recently instituted a program to trend important emergency diesel generator (EDG) performance parameters that are monitored during periodic surveillance tests.
This program is in its infancy, and has been instituted in response to the Station Black Out Rule.
This program is expected to enhance Beaver Valley's EDG availability.
Also, the licensee has been trending safety and nonsafety station battery parameters for the past three years.
As a result of the failure trending programs, the licensee has taken several actions that will enhance equipment availability and overall plant safety.
Two examples of such actions are:
the modification of the EDG air start system; and, air operated valve diaphragm replacement program.
The EDG i
starting air piping is being replaced, air receivers have been pickled, and air driers have been installed to reduce EDG air start system failures. As a result of frequent air operated valve diaphragm failures, a valve maintenance
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program has been implemented to overhaul valve operators and change out approximately 25% of the safety related air operated valve diaphragm > during each refueling outage.
The failure trending program at Beaver Valley is also used to identify plant design weaknesses and component degradation due to environmental stress factors.
The equipment failure trend reports are reviewed quarterly by site management.
The. maintenance and the testing and plant performance group have identified and requested engineering design changes to improve equipment maintainability.
Because the licensee has its nuclear engineering group on site working closely with plant personnel, the plant maintenance organization along with the testing and plant performance group is able to identify maintenance problems and present them to the engineering group for quick resolutions.
The integration of these organizations has benefited the overall maintenance program at Beaver Valley.
However, in the area of root cause analysis, the inspectors found that a number of analyses established a series of contributing causes, rather than a
" root Cause."
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The inspectors determined that the licensee's trend analysis program'needs further. strengthening in the areas of root cause determination, and a timely and. comprehensive resolution to prevent repeated failures.
Because identifying a series of contributing factors instead of the root cause (primary factor),
masks the cause of the failure and makes an effective resolution difficult.
The identification of the root cause facilitates an immediate fix with a comprehensive long. term resolution.
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Support Interfaces
. Support and communications between the various departments was considered to be good.
For example, twice daily meetings were held to address ongoing work and
special problems. The meetings were well attended by members.of operations,
-site maintenance, I&C maintenance, nuclear construction, testing and plant
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performance, and other cognizant groups.
In addition, twice weekly higher level management meetings were held to discuss operations, maintenance, and other outage and planned constructfon activities. Work planning is effective.
The inspector determined that excellent interfaces exist between the appropriate groups.
It was also determined that site administrative procedures were
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effective in assuring close cooperations.
Mechanical Maintenance The inspector observed mechanical maintenance work in progress, examined documentation of completed work and interviewed cognizant plant personnel at various levels.
Emphasis was placed on corrective maintenance activities.
Additionally, programmatic aspects of preventive maintenance.were examined with specific attention to check valves.
- The check valve program at BVNPS was examined through interviews withlthe engineering and maintenance groups. Check valve maintenance has been a source of NRC concern as a result of events as indicated in the INPO SOER 86-03.
Subsequent to the events, recommendations were made by INPO and EPRI to improve check valve maintenance. No specific regulatory changes have been initiated by the NRC although several generic communications have addressed specific concerns.
The BVNPS check valve program has the objective of incorporating industry initiatives into the plant maintenance program.
It is at an early stage of development and does not involve implementing major changes to the current program.
PRA insights also have not yet been included in the program, and the g-major activity is one of data compilation.
Historical data have been developed
'for each unit involving selected valves.
This information is combined with the-
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results from ongoing surveillance tests to determine where specific actions may be indicated in light of the INPO and EpRI-recommendations.
The BVNPS check valve program does not represent an aggressive move to improve check valve performance.
However, the information base required for future actions is being developed. Currently, this approach is adequat e --
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Conclusion
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The inspectors concluded that the maintenance organization had a well
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developed program for performing corrective and preventive maintenance.
The
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main strength of the organization lies in its highly trained and competent staff. Careful selection for specific jobs and effective training programs assured that plant maintenance and contractor personnel were well qualified to perform their jobs.
The contracted work is supervised and monitored by the licensee in a satisfactory manner. Although the failure trending program is i
satisfactory and significantly contributes to the predictive maintenance
program, further strengthening is needed in the area of root cause analysis j
and timeliness of resolution.
Excellent interfaces exist amongst groups engaged in maintenance activities.
The inspectors found Beaver Valley to have l
a well functioning maintenance organization.
At the implementation ~ level, the mechanical maintenance, as conducted is satis-
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factory.
In the field, personnel appear to take advantage of their manifest
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skill and experience, to use informal communication channels effectively, and to generally adhere to broad policy guidelines in executing a satisfactory main-tenance program.
I The check valve program is in an early stage of development.
The licensee is
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proceeding cautiously in making changes to improve the reliability of check i
valves, j
7.0 MAINTENANCE FACILITIES, EQUlpMENT AND MATERIAL CONTROL l
Scope The objective of this part of the inspection was to assess the plants' mainte-t nance facilities and controls over maintenance equipment, tools and materials to determine how well these activities support maintenance work.
The following areas were evaluated during this inspection:
Provision of maintenance facility and equipment
Establishment of material controls
Establishment of maintenance tool and equipment controls
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Control and calibration of meter and test equipment
Findings Provision of Maintenance Facility and Equipment The inspectors conducted an extensive tour of maintenance facilities to assess the extent to which facility arrangement and layout were conducive to efficient l
maintenance operations. The inspectors noted that each unit had a clean
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mechanical, electrical and Instrumentation and Control (I&C) shop located l
adjacent to the respective units' turbine building. One hot mechanical main-l tenance shop was shared by both units. The hot shop was located adjacent, and
with direct access, to the Unit 1 Auxiliary building.
The licensee performs l
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the majority of the hot maintenance work at equipment locations; thus, the lack of a Unit 2 hot shop did not appear to have any significant impact on the efficiency of maintenance activities requiring hotwork. During the inspection, no hotwork was in progress in the Unit I hot shop. Activities were organized in the shops.
However, the inspectors found that there were no formal governing procedures to establish the shops' scope of work and material control.
With the exception of the Unit 2 clean maintenance _ shop, maintenance and I&C foremen, engineers and supervisors' offices were located directly adjacent to the shops. These locations facilitated the close supervision of plant and
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shop activities. Other support organizations with the exception of engineering and training were located within the Protected Area.
It was also noted that there were several other maintenance shops located on the site but not adjacent to the plants. These shops were under the responsibility of the licensee's Construction Department, and were used occasionally to support maint? nance activities.
These shops included a fabrications shop, welding shop, sandblasting and paintshop, and an insulation and lagging shop.
The space allotted for maintenance training at the training facility was limited; however, training mockups were found thrcughout the site.
Some of the training mockups observed were a reactor coolant pump seal, "Limitorque" valve, electrical breakers, steam generator (SG) manway, full scale SG Secondary s'de, and snubbers.
There were ample communication systems to facilitate maintenance and testing.
The "Gaitronics" five-channel phone pager system was heavily utilized by main-tenance personnel for short conversations.
For lor.ger communications, a private exchange telephone and sound powered phone networks were installed throughout the plant.
These systems provided more than adequate communications service for maintenance work in progress.
The inspectors also observed that suf ficient space had been allocated for staging and laydown areas.
The work area around the Unit I turbine generator had a fence erected around it, and access to the work area was controlled.
The licensee had also predesignated laydown areas for the temporary storage of contaminated components.
The inspectors observed scaffolding in use through out Unit 1.
Scaffolding used in potentially contaminated areas were of a different color and stored separately than scaffolding used in clean areas.
The wood boards used for scaffold platforms in potentially contaminated areas were wrapped in canvas to limit the amount of fixed contamination.
The inspectors observed that the scaffolding was generally erected in accordance with applicable industrial l
safety standards.
In one instance, however, the inspectors observed electricians working on scaffolding erected above the Unit 1 pressurizer without handrails, L
toe boards or safety belts.
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33-Establishment of Material Controls
.For material controls review, the inspectors examined the adequacy of administra-tive policies and procedures for implementing effective control of materials (components, spare parts, consumables, etc.) used in_ maintenance, beginning j
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with the material requisition and extending throughout material installation or
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use.
The inspectors observed that adequate guidelines have been established for identifying and assigning necessary material specifications, by site based
" user departments," for use in maintenance applications. Adequate controls have been implemented for identifying safety related materials and for specifying the necessary special controls over the procurement of safety class material.
The master equipment list (MEL) provides the necessary instructions to site groups who initiate material requisitions.
The inspectors observed the process of initial material requisition, through the purchasing function, QA review, purchase approval, and final ordering.
These procedures were adequately controlled and sufficiently well established to ensure that in most cases material requisitioned for maintenance activities are processed far enough in advance of use to be available in sufficient quantity for their intended purposes, No maintenance activities were observed to be
. delayed due to late requisition processing or purchasing, A delay developed
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with the implementation of the commercial grade dedication program on selected i
IC parts (i.e., parts procured commercially to be dedicated to safety class-use) prior to the Unit 1 outage. The dedication program was implemented in early September 1989 end caused a delay in releasing outage parts until the i
parts could be dedicated.
Based on the areas inspected, the parts and material dedication program described in procedures ES-M-001 Commercial Grade Evaluation, MMS 38.0 - Material Control Commercial Grade Dedication Function, and MSS-39 -
Classification of Spare Parts Identified for use in Safety Related Applications, appears adequate to support the intent of engineering standard ES-M-001.
l The inspectors noted that adequate guidelines have been-developed for ensuring that proper material certificates are provided with material that arrives on l
site.
The inspectors reviewed documentation of individual material history packages maintained on safety class items in receipt inspections. All packages reviewed contained complete information and certifications to support material identification through objective evidence obtained from approved suppiiers.
The approved suppliers' list was also reviewed by the inspectors and a discussion was held with the licensee's vendor audit group regarding the vendor audit program. The inspectors reviewed recent vendor audit reports conducted on several " approved vendors" currently providing contractor services during the outage. No unsatisfactory conditions were noted.
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The inspectors reviewed the computerized data base used for tracking the entire site storehouse inventory.
Minimum and maximum stocking levels are identified, as is current inventory on hand. Automatic reordering is initiated when inven-tory drops below minimum levels.
The inspectors noted that all material desig-nated for a specific application may not necessarily be entered into the warehouse inventory listing but may be temporarily stored in the warehouse. Observations of controls on the issuance of all material out of the warehouse indicates that inventoried material is released only after certifications are made which as-sociate specific work orders with specific material purchase orders.
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=The inspectors examined the warehouse stock areas to evaluate the adequacy of l
this facility in supporting the maintenance effort. This facility provides good physical security for all stored materials and provides a " Category A and B" storage environment for plant spare parts and consumable material. The
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inspectors observed the areas designed for flammable and explosive materials l-storage and determined that adequate controls were in effect.
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All material is identified by safety class in work packages and procurement-documents which are verified to be consistent before any material is released l
from the warehouse.
Nonconforming material is well segregated in the areas designated exclusively for receipt inspection. The inspectors observed that i
receipt inspection QC requirements were adequately implemented and that documentation of material history was maintained in a manner which provides complete traceability.
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Establishment of Maintenance Tool and Equipment Control In the areas of maintenance tool and equipment control, the inspectors toured
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issue points and jobsites to determine if adequate controls were being imple-
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mented.
The calibrated tools and equipment were issued from both mechanical maintenance clean shops and contaminated tools were issued from the Unit 1 mechanical maintenance hot shops.
The users were required to sign for each
tool checked out and were further required to return the tools at the end of the maintenance activity. The inspectors did not find tools outside the areas of ongoing maintenance.
I Control and Calibration of Measuring and Test Equipment
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The licensee's measuring and test equipment (M&TE) program had been recently I
inspected by the site's resident inspectors (see Inspection Report 50-334/89-13 and 50-412/89-14).
It was determined that the calibration of M&TE were being properly performed, however, there were several deficiencies identified in the control of M&TE. Some of the problems identified included the issuance of past due for calibration M&TE for safety related work, the failure to segregate calibrated and past due for calibration M&TE and failure to properly use the
" Daily Issue and Use Record Log."
The licensee corrective actions were in progress.
Conclusion s
At Beaver Valley, the various maintenance facilities were well arranged, equipped,
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and maintained in a manner which supports the efficient conduct of maintenance
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activities.
However, there were no formal governing procedures to establish
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the facilities' scope of work and control.
In the area of material control, the inspectors concluded that existing adminis-trative policies and procedures provided strong controls for specifying, procuring, receiving and storing materials utilized for n'aintenance work.
Safety related materials were properly procured, stored and issued for intended use. The material tracking system used in the warehouses was a strength, allowing close control m
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for maintaining minimum stock levels and for properly accounting for.all materials received,. stored and issued from the warehouse. The procurement program was
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observed to be well administered and implemented to ensure that materials used
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for maintenance activities are properly specified, obtained, and received in a-timely manner which supports maintenance work schedules.
In the area of tool and equipment control, inspectors concluded that tool and equipment identification, storage, and use were adequately controlled in-maintenance work.
The licensee has developed a maintenance work request (MWR) system that uses their master equipment list (MEL) for their preplanning outage program.
The MEL is a user friendly program that not only goes to the piece part level, but
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gives a complete history of the item including the procedures used to q' alify u
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the item. This is an excellent program.
The proposed electronic parts program and their new dedication parts program will provide data inputs to existing MEL'.
The maintenance engineers and planner were well versed in these programs and it was evident that their stable manpower force is a major reason for.the excellent-program they have in place.
Their self initiative programs in the use of infrared thermography surveillance
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and the temperature / seismic analysis of their plant equipment using the Westinghouse " Lifetime Monitor" system will provide data for root cause analysis and preventive maintenance.
8.0 -PERSONNEL CONTROL
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Scope The objective of this.part of the inspection.was to determine the extent to which personnel are trained and qualified to perform maintenance activities.
In addressing this topic, the inspectors examined the following areas:
staf f_ing control, training, testing and qualification, and current status.
The inspectors evaluation was based on interviews, direct observations of the training facility,
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field activities, and reviews of documents and records.
Findings Staffing Control The overall turnover rate for the maintenance department appears to be very high. However,--the maintenance department includes many of the positions for less skilled employees (e.g., House and Yard) that are basically entry level and subject to high turnover rates as more skilled positions become available.
In addition, this provides for mobility of personnel throughout all stations in
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the DLC system thus increasing the turnover at the Beaver Valley 3tations.
Also, shift coverage is kept to a minimum since any shift other than day shift is considered overtime. The licensee tries to minimize working on off shifts.
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_A minimum number of maintenance employees are scheduled for off shifts on a
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routine basis. However, the licensee reported that there was no problem with calling-in appropriate workers when required.
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l Personnel Training The-licensee.has developed a set of courses for minimum job training-requirements (MJTR) given to all new hires during the first 30 months of employment.
Each employee's progress through the MJTR is tracked by the training department to assure that all elements are covered.
In addition, selected portions of the MJTR are given to older employees where the need has been identified by plant supervision. The training department obtains the J
names of individuals from the corporate computer by position code thus
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assuring that all individuals are listed for training.
The listing can be sorted in a number of ways to assure that proper training is scheduled and
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_given.
The inspector reviewed the training records for the maintenance department and found training being completed as scheduled.
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The inspector reviewed training records, observed classes in session, and interviewed instructors in the licensee's training center.
Most of the courses given' have been accredited by INPO.
These courses vary in complexity from elementary use of hand and power tools to complex repairs of valves and electronic components. The inspector noted that classes were in session for maintenance
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personnel while the outage was in progress. This indicates a strong support by
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the maintenance department management and assurance that the courses are beneficial for improving the quality of maintenance work. Many of the courses were divided into classroom work given at the training center and relatively formal-on-the-job training given by higher level employees and supervisors.
On-the-job training is graded by supervisors or engineers.
This combination provides assurance that the classroom work is translated to hands on experience.
f In the electrical area, the training center has several " typical" panels that might be found in the plant.
These panels can be connected in a variety of ways to simulate plant conditions.
Current Status
The licensee has developed a Fitness for Duty Program to meet the requirements as published in the Federal Register, June 7,1989.
The program has been approved by-the licensee's management and currently training is in progress for implementation by December 1,.1989.
Interviews with medical personnel indicated that random drug testing would start December 1, 1989.
Personnel were familiar with the program and prepared for the testing.
Conclusions
'The licensee has an extensive training and qualification program for mainte-g-nance personnel.
The training center is well equipped for the training and has several mockups for use as training aids.
Tracking of individuals requiring training and the training these individuals have received is done through the corporate computer employee lists thus assuring none are missed.
On-the-job training is conducted on a relative formal basis thus assuring the quality of this trainin p
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ATTACHMENT 1 PERSONS CONTACTED Duouesne Light Company L. Arch, Principal Engineer a
- T. Burns, Director, Operations Training
- D. Blair,. Director, Radiation Health Services A. Booth, Maintenance Information Management Supervisor
- D. Canan, Senior Health Physics Specialist
- J. Crockett, General Manager, Corporate Nuclear Services
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R. Druga, Technical Services Manager
- S. Fenner, Manager, Quality Assurance J. Gazdacko, Material Management Director
- K. Grada, Manager Nuclear Safety C. Haney, Technical and Craft Training Director
- R. Hecht, Site Instrument and Control Director
- 'J.
Kasunick, Site Maintenance Director
- J. Keagan, Engineer W. Koecher, Senior Nuclear Maintenance Instructor J. Kosmal', Radiological Control Manager
- C. Kuhn, Senior Engineer
- W. Lacey, General Manager, Nuclear Operations Services
- S. Leung, Engineer V. Linnenbom,' Plant Chemistry Director
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- F. Lipchick, Senior Licensing Supervisor
- R. Martin, Director, Nuclear and Mechanical Engineering J. Matsko, Planning and Outage Manager T. McGhee, Plant Safety Review Director
- S. Nass, Supervising Engineer
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- T. Noonan,' General Manager, Nuclear Operations M. Orr, Site Maintenance Support Coordinator F. P1vlechko, Emergency Preparedness Planning Director
- M. Pergar,' Supervisor, Quality Control
- D. Rcman, Supervisor, Quality Assurance, Maintenance
- D. Schmitt, Director, Electrical Engineering
- C. Schultz, Principal Engineer
- B. Sepelak, Licensing Engineer
- J.-Sieber, Vice President, Nuclear Group l
D. Soerry, Nuclear Training Manager
- N. Tonet, Manager, Nuclear Engineering Department
- J. Vassello, Director, Licensing C..Wassel, Program Development Director D.- Weakland, Supervisor, Materials, Codes and Standards J. West, Specialist, Productior. Planning J. Winters, Senior Nuclear Maintenance Instructor
- R. Wittschen, Engineer
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Attachment 1-
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United States N'uclear Regulatory Commission
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'..*LJ. Beall, Senior Resident Inspector, Beaver Valley
- J. Durr, Acting Deputy Director, Division of Reactor Safety
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- 'A. Lopez, Reactor Engineer, Region I
- J. Trapp,_ Reactor Engineer, Region I.
- Attended the exit meeting-on September 29, 1989.
The inspectors also talked with other licensee personnel curing the inspection.
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ATTACHMENT 2-Q,g
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- UNITED STATES '
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i NUCLEAR REGULATORY COMMISSION
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REGION i
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476 ALLENDALE ROAD N
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'*****,o KING OF PRUSSIA, PENNSYLVANIA 19406 b@t
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Docket Nos. 50-334 b
50-412
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Duquesne Light Company.
ATTN; -Mr. J. D. Sieber
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Vice President
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Nuclear + Group Post Office' Box 4
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Shippingport, Pennsylvania 15077
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Gentlement t
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Sub,'ec t : MAINTENANCE PROGRAM TEAM: INSPECTION
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This. letter is to inform you that the NRC intends to perform a. team inspection-L
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of your maintenance program at Beaver Valley Units 1 and 2 on September 18, 1989,
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through September 29, 1989, and to request your assistance in accomplishing
.this task. The inspection will focus on the performance of maintenance and
whether components, systems and structures of your plant are adequately
maintained and properly repaired so that they are available to perform.their ititended' safety function.
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.In' order for us to properly prepare for the inspection and maximize the onsite
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time spent in observation of maintenance in progress, we request that you furnish the reference' material listed in-the enclosure of this letter.
The team leader will be. contacting you shortly regarding the information that will be needed prior to the start of the inspection and to arrange a-suitable date for a meeting to explain the inspection and assessment methodology.
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A copy of the draft NRC Temporary Instruction 2515/97 " Maintenance Inspection" is. enclosed for your~ information and to aid in the preparation-for the inspection.
Thank you for your cooperation in this matter.
If you have any questions regarding.this matter, please contact Suresh Chaudhary at (215)337-5335 or Jacque Durr at.(215)337-5282.
Sincerely, L-a2pne r. - w]ik4',
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f Bruce A. Boger, Acting Director Division of Reactor Safety n
Enclosure': As stated
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' AUG ' O 4 1989--
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.Duquesne LightLCompany'-
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cc w/ encl:
J 'J. Carey,' Executive Vice President, Operations
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JJ. 0. Crockett, General Manager, Corporate Nuclear Services
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W. S.= Lacey, General Manager, Nuclear Operations N. R.;Tonet, Manager,' Nuclear Engineering
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T. P.'Noonan, General' Manager, Nuclear Operations
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S. C. Fenner,.QA. Manager
.K'_D. Grada, Manager, Nuclear Safety
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H. R.'Caldwell, General Superintendent, Nuclear Operations
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- Public Document Room (PDR)
Local Public Document Room (LPDR)
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. Nuclear Safety Information Center (NSTC)-
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NRC Resident Inspector-Commonwealth of Pennsylvania bec w/ encl:
Region 1 Docket' Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
EL. Tripp, DRP-D. Limroth. DRP
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Tam, NRR
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PA0 (30) SALP Reports Only
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'J. Wiggins, DRP
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J, Dyer, EDO.
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ENCLOSURE
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- To aid us in preparation for the maintenance inspection please provide us with
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the following documents, procedures and information in accordance with the designated numbers.
If you do not have the requested dccument or information, it is not necessary to generate.it to comply with this request. We recognize (L that many of'the documents requested separately may be inclusive in a larger E
single document.
Please. provide three sets of the requested documents. A:
member of our staff will contact you regarding the best method of transmitting the documents to.us.
Please provide the information for each of the units, except if it is comon and applies to all units, then only one set with three copies is'needed.
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Section 1-Description of General Plant Maintenance Activities
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1-1 Maintenance administrative procedures which describe your corrective, preventive and predictive maintenance activities.
1-2 -Organization charts including the maintenance organization and plant wide organizations.
f 1-3 Procedures, charts and other documents which describe your Planning l
Department and its activities.
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1-4 Documents which describe maintenance planning and scheduling meetings and status of maintenance reports.
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1-5 Documents which describe the Maintenance and Operations interface (
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during planning, scheduling, work start, work closeout and post
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maintenance / functional testing.
1-6 Documents which describe your work control process:
how a work order-is started, planned; executed, completed, closed out and equipment returned to service. Where contractors are used, how are they integrated into the process and. controlled?
1-7 Documents which describe training and retraining of plant and contractor maintenance personnel including radiation protection c
specific training.
(For maintenance activities only, do not include GET.)
1-8-Documents which describe interfaces and communications among the technical support, engineering support and the maintenance /I&C Departments.
?-9 Documents which describe maintenance work procedure establishment and g-control: Criteria as to when a procedure is to be used; initial
writeup; reviews and approval; revisions; human factors reviews; QA reviews; reauirements for conduct of work; troubleshooting criteria; work closeout; post maintenance testing and restoration of systems.
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1-10 Description of methods by which maintenance performance is measured.
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Are performance indicators used? What are they? Who is informed of the results? Provide examples of periodic management raports that are used to assess maintenance performance.
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1-11 Description of process for comunications with vendors for technical services and latest technical information on equipment and systems installed at the plant, and interfaces with vendors or NSSS for training,' modifications and equipment replacement.
1-12 Documents which describe the preventive maintenance and predictive maintenance programs.
Which equipment is included?.
How is maintenance frequency determined?
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What is done with results of these maintenance actions, t
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1-13 Documents which describe management involvement in maintenance.
Are there goals-set for the maintenance and I&C Departments.
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t Are these goals used in the performance evaluation of managers and
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supervisors?
Are these goals communicated to first line supervisors and chiefs?
1-14 Documents which describe the Industrial Safety Policy and its
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E incorporation into the maintenance program (safety manual, safety y,
training, safety audits, accident reporting and investigations.)
1-15 Documents which describe the interfaces between Maintenance and
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of maintenance activities.
Health Physics in' work planning, scheduling and actual pqformance L'
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l 1-16 Indexes of department procedures.
l-l Section 2-Status of Plant and Contractor Personnel Who Perform Maintenance.
2-1 The number of craft personnel for_ electrical, mechanical and I&C maintenance organizations. Please include foremen and the foreman to craft ratio.
2-2 The average years of experience for each iridividual and the turnover
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rate.
2-3 Description of shift work and work assignments. How do licensee supervisors decide on which craft or contractor is to perform what p
type of work?
Section 3-Status of Plant Equipment and Plant Maintenance l.
3-1 What equipment failures occurred during the last year of operations?
L 3-2 What equipment failures have been found during shutdown of plant, L
since and including the last refueling outage?
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3-4 What component failures present greatest risk from a probabilistic s
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risk standpoint to the plant and how is this information utilized in establishing preventive and predictive maintenance?
3-5 What have been the areas of high maintenance activity on safety related and non-safety related equipment and components?
l 3-6-Provide the following status'concerning Maintenance Work Orders (MWO).
Current total listing and status of MW0s, number in planning, number in final sign-off, number on hold for lack of parts, number on hold for engineering assistance, number available to be worked on
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Projected number of corrective MW0s to be outstanding at start-up by priority
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Rate of completion of corrective MWO in terms of number
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completed / month and manhours expended (by craft)/ month for the past 12 months Current number of preventive maintenance work orders overdue Rate of completion of preventive MWO for the past 12 months Estimated manhours required to complete current preventive maintenance HW0s Number MW0s requiring rework over past 6 months ('T 3-7 (_/
Provide five corrective maintenance procedures for work that is scheduled for the upcoming outage (e.g., NOVs, PRVs, Solenoid Operated Valves,. Safety / Relief-Valves, ECS Pumps, Batteries, Switchgear,etc.).
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-3-8 Provide five preventive maintenance procedures that are scheduled for the upcoming outage.
3-9 Provide your overall outage schedule.
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ATTACHMENT 3
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-SUMMARY OF WEAKNESSES
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l Weakness - A potential problem or condition presented for licensee evaluation and corrective action as applicable and necessary.
Reference to Report Section 1.
' Lack' of a unified and comprehensive document that 3.0
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provides station wide guidance on the policy, objectives, structure, and constraints on the maintenance functions.
2.
Lack'of a graded response to failures to assure 3.0, 6.1 l
'that a root-cause analysis is performed before a potentially-serious event or multiple. failures occur in a component.
3.
Lack of rigor and consistency in the implementation 3.0 of MWR process.
4.
Insufficient supervisory oversight on radiological 4.0 work activities with cumbersome RWP package forms.
5.
Lack of formal procedures governing scope and material 7.0.a
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. control in maintenance shop.
6.
Incomplete coordination and work control in areas 7.0 where multiple craftsmen are working on different conclusions MWRs.
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