IR 05000338/1990006
| ML20034A583 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/06/1990 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20034A579 | List: |
| References | |
| 50-338-90-06, 50-338-90-6, 50-339-90-06, 50-339-90-6, NUDOCS 9004230522 | |
| Download: ML20034A583 (10) | |
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. UNITED STATES.
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'o NUCLEAR REGULATORY COMMISSION.-
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ATLANTA, GEORGI A 30323 -
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- Report Nos.:
50-338/90-06 and 50-339/90-06 Licensee: Virginia Electric &_ Power Company 5000 Dominion Boulevard Glen Allen, VA 23060
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Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name: North Anna 1 and 2
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Inspection Conducted: March 19 - 23, 1990 Inspector: O Abd
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l E. H.
'rard Date Signed Approved by:
J. J B Re, Chief.
Date Signed Ma ri is and Processes Section
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E in ering Branch
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D vision of Reactor Safety-i
SUMMARY
Scope:
l This routine, unannounced inspection included initial review and followup of
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the 1989 NRC maintenance team inspection and examination of other NRC-identified.
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previous inspection findings related to maintenance.
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Results:
-1 To the extent examined in this initial review, it was determined that the
~l licensee had developed actions to correct =all of the' weaknesses identified by.-
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the maintenance team inspection. Some of these actions may take years to
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complete and the _ extent, timeliness and overall adequacy of the corrective:
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actions will be examined further in subsequent NRC inspections.
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- The licensee's action with regard to three previously identified NRC' inspection findings were found to be appropriate.
A fourth, identified and being followed
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by the NRC resident inspector, was reviewed primarily for information. This a
latter item involved apparent inadequacies in preventive maintenance and review-
. performed in the current inspection supported the NRC resident inspector's concerns regarding the involved procedures.
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Violations or deviations were not identified.
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REPORT DETAILS
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1.
Persons Contacted Li.censee Employees
- M. Bowling, Assistant Station Manager, Nuclear Safety and Licensing
- R. Enfinger, Assistant Station Manager, Operations and Maintenance
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G. Kane, Station Manager
- J. Leberstein, Senior Engineer, Licensing
- W. Matthews, Superintendent, Maintenance
- A. Parker, Jr., Supervisor, Maintenance Engineering
- J. Smith, Quality Assurance Manager R. Sturgill, Supervisor, Systems Engineering H. Whitlock, Supervis,or, Instrumentation and Controls -
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
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2.
Review and Followup of 1989 Maintenance Team Inspection (92701)
The inspector examined the maintenance-related weaknesses identified in a NRC maintenance team inspection (MTI) conducted by the NRC Office of Nuclear Reactor Regulation and documented in Inspection Report'
50-338/89-200 and 50-339/89-201, dated August 21, 1989. The current inspection was performed to.further define the weaknesses and to initiate an evaluation of actions taken by the licensee to address the weaknesses..
It was accomplished through review of the reported weaknesses, interviews with responsible licensee personnel, observation of materiel' conditions and review of documentation related to-licensee corrective actions. The
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documentation reviewed included the licensee's January 22, 1990, status report of their action plan for responding'to-MTI and other NRC findings; as-well-as examples of procedures, organization charts, a failure analysis and a root.cause evaluation - each reflecting licensee corrective actions in response to the MTI. Based on his review and evaluation, the inspector-concluded that the licensee had developed actions to address: all of the weaknesses identified by the MTI.. No detailed assessment of-the adequacy, of the licensee's corrective actions or their implementation and timeliness was performed.
This will be the subject of subsequent NRC inspection.
The weaknesses identified by the MTI and the inspector's findings for each in the current inspection are given below.
Page and line references (p., 1.) to the MTI report are given in parenthesis beside
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each weakness.
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a.
Weakness: Calibration stickers did not give correct due dates. The due dates had been extended for some instruments but revised calibration stickers had not been installed. The incorrect
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calibration sticker information could be confusing to operations
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p(ersonnel who rely on the instruments for proper system operation-
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p.-20, 1. 21).
l Findings: The inspector.was informed that recalibration program requirements were under review and that erroneous stickers were
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gradually being replaced.
The licensee did not feel-that the' stated concern was very-significant. They stated that they were beginning_
actions to address two other concerns regarding calibration. stickers:
(1) misunderstood dates;and-(2) dates that had faded or been wiped l
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off. The inspector was informed that date information entry l
j requirements had been revised to.make the original _ calibration and L
due dates clear and that new fade. resistant stickers were being used.
t in some locations.
In an extensive tour.of the-plant, the inspector observed several calibration stickers whose date entries were.
i illegible or. totally faded out but none of the new-stickers. No instruments that were overdue for' calibration were observed. The'
I Instrumentation-and Control Supervisor showed the inspector uninstalled examples of the new stickers..
b.
Weakness: There was little or no trending of equipment performance by maintenance engineers (p. 34, 1.'12 and p. A-13, 1. 13).
Findings: The maintenance superintendent-stated that equipment-trending was now being performed by both-corporate and site groups.
He indicated that on-site trending was done primarily-by the Maintenance Support group, though some-is performed by_ Maintenance-Engineering group personnel, c.
Weakness: Maintenance appeared to be inhibited by insufficient" staff.
The predictive maintenance staff was insufficient to implement the licensee's thermography program (p. 34, 1. 20). There was no Instrumentation and Control.(I&C) maintenance engineer.
(p. A-4, 1. 39).
Balance of plant equipment: performance monitoring was not being accomplished in accordance with ADM-20.47 because of
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insufficient manpower (e.g., there were insufficient I&C personnel to L
perform HVAC System preventive maintenance tasks) (p. 26 l.:4; p. 34, 1, 24 and p. A-4, 1. 35).
Health Physics (HP) 'could not provide timely Radiation Work Permits (RWPs) because of staff limitations (p. A-4, 1. 43). Operations did not provide timely tagouts of equipment for maintenance.due to a lack of staff (p.A-4,1.43).
The systems engineering group was only 50 percent staffed (p(.33,1.30). There appeared to be insufficient planning personnel p. A-4, 1. 28).
Findings: The Maintenance Superintendent _ indicated there had_been increases in. staff to address all of the concerns except those with regard to HP and Operations. He believed the perceived deficiencies for these organizations were due to poor planning and the uncommon stresses of the dual unit outage that was in progress at the time of the MTI. The inspector's review of the licensee's Action Plan for
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NRC findings from a Safety Systems Outage Modifications Inspection L
(which-had been conducted and reported together with the MTI)
revealed licensee actions taken to resolve the HP and Operations related concern.
It indicated that computerized preparation of RWPs
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and clearance tags had been initiated and that the HP procedure was
l revised to include a RWP preparation worksheet to help preparers..
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d.
Weakness: Vendor information was inadequately controlled (p.:A-6, 1. 3 and 7; p. 25, 1. 7 and 16; and p. 35, 1. 1).
Findings: Licensee personnel stated that their new vendor manual.
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update program would resolve the concerns in this matter.
Procedures-
ADM-6.18 and DCM-75 were said to have been revised to ensure that all communications from vendors would be reviewed by their licensing staff and placed on their commitment tracking system'to ensure proper action.
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Weakness: There had been inadequate corrective actions in response to previously identified maintenance-related findings. Examples included a lack of preventive maintenance for stored components identified in a licensee QA audit and their Maintenance Self-Assessment (p(. 27,1. 36 and p. 31, l. 48), inadequacies-in root cause evaluations p. A-12, 1. 51), and ineffectivel -
licensee Service Water Review Team recommendations (y addressed-p. 32, Findings: Licensee personnel indicated ~ actions that had been taken to address the individual examples cited. The cause appeared to be attributed to previous staff deficiencies which had-now been largely i
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It was_not clear to the inspector whether the cause had I
been fully identified and corrected, f.
Weakness: Engineering responsibilities and authorities.had not been adequately proceduralized (p. 20, 1. 49 and p. A-7, 1. 8).
Finding: The inspector was informed that adequate procedures had now been-implemented. The subject engineering functions had been newly organized at the time of the MTI.
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Weakness: Although a systems engineering function had been created, it had not yet been adequately implemented.
Lacking were both controlling procedures and sufficient staff (p. 20, 1. 52 and p. 21, 1. 8).
Findings: Based on his attendance at a system engineers meeting and on discussions with one of the licensee's two systems engineering s0pervisors, the inspector believes that significant progress has been made toward the implementation of systems engineering concepts at North Anna, but that full capabilities may not be attained for several years'. A total of 29 systems engineer positions have been_-
authorized. There are currently 17 permanent and 4 contract systems engineers on the licensee's staff. Training of the personnel ~was i
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L still in an early stage. The first quarterly reports for high-L priority systems are to be prepared this summer.
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Weakness:
Root cause analyses were found tosbe inadequate both in L
program and implementation. The controlling' procedures, training and L
actual performance were all determined-to be deficient. The MTI
specifically identified this matter:as Inspector' Followup Item 338/89-200-03 (p. 21,1. 44).
Findings:
The Maintenance Superintendent stated that-they had
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developed and implemented a program to address this concern that provided for two levels of analysis - limited scope failure analyses-and more detailed root cause evaluations (RCEs). The inspector-reviewed an example report of each of these.
The failure analysis
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covered a radiation monitor failure and was identified 90-004.
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RCE examined a Unit 1 reactor trip (RCE Report 89-116, EHC Event)
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that occurred on December 6, 1989.
Pressure transients associated with the turbine Electrohydraulic Control (EHC) System produced the trip. The inspector found that the reports adequately _ described the results and recommendations stemming from the associated investigations, but contained insufficient details of-the conduct of the investigations to assess their performance. The trip evaluation t
indicated inadequate procedural controls on EHC System maintenance.
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The MTI identified similar maintenance procedural deficiencies.
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Weakness:
There appeared to be inadequate controls on engineering I
calculations. Engineering studies.(conducted per_ procedures l
ADM-17.15'and 34.0) were routinely used-to perform calculations where.
l it appeared that better controlled formal calculations (per procedure
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ADM-17.15) would have been preferable.(p. 22, 1. 34).-
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Findings: The licensee's Action Plan of January 22,-1990, reported-that a new procedure (NAES-1.05) had bee'n issued to ensure the correct use of engineering studies and calculations..In addition. it'
indicated that a specific calculation error quoted by the MTI in
describing the concern -(erroneous calibration data discovered by the
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l licensee in Engineering Study 89-11), had been addressed by development of a specific procedure for that calculation.
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Weakness:
Equipment clearance tags h'ad not been hung per the approved tagout sequence resulting-in a concern that equipment damage or personnel injury could occur.
The deficient tagouts appeared-to apply only to modification work (p. 23, 1. 10).
Findings: The licensee's Action Plan indicated the following.
corrective actions to' address this concern which included changes to-the tagout procedural controls (revision of procedure ADM-14.0 and
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issuance of procedures VPAP 1402 and OPAP 10), training, and instituting a computerized tagging syste._.
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Weakness:
Preventive maintenance (PM)'was not being performed on stored items. Procedures requiring the PM were not being implemented.
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This had been identified by, licensee QA Audits (see e above)-
(p. 27, 1. 29).
I Findings:
The inspector toured the. licensee's warehouse and observed I
that the licensee had set aside.an area for stored parts that I
required PM. He was informed that the parts, principally motors, were receiving periodic PM and that this was documented on a card..
with each. The inspector verified such cards-by checking examples of valve motors. The cards found with the motors documented quarterly i
performance of PM.
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Weakness:
The bases for PMs was not documented by the licensee and some vendor recommendations were not followed (p. 27, 1. 20).
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Findings:
The Maintenance Superintendent stated-that there was an-item on their commitment tracking system to resolve this concern, but
that it was unclear whether it could be accomplished.
The licensee's Action Plan showed this concern would be addressed by performing-an s
evaluation of the difference between vendor recommended PMs and the already implemented program.
The evaluation was scheduled to have been completed in 1989 but was not.
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Weakness:
Various deficiencies were noted in procedures.
Maintenance implementing procedures and some maintenance administrative procedures appeared to lack sufficient detail (p. 28, 1. 24).
I&C used memoranda instead of administrative. procedures for many applications (p. 28,- 1. 48)..The administrative procedure on
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training did not give I&C training requirements (p. 29,1. 41).
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Procedure deviations, representing limited individual changes for a
't procedure, were accumulated with no control on-number permitted before all had to be incorporated through a procedure' revision-(nine were in effect on diesel generator maintenance procedure MMP-P-EG-4).
(p. 30, 1. 7).
Write-in procedure changes (approved only by the work superviscr) were made which altered the scope of the work, a violation of licensee requirements permitting such changes only when scope and purpose were not altered (p. 30, 1. 32).
Findings: The MTI reported that the licensee already had a procedure upgrade program in progress at the time of their inspection,. but that it had not progressed sufficiently to be assessed.
In the current
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inspection licensee personnel informed the inspector of actions to-address the procedural concerns which included - a continuation of the procedure upgrade program (to be completed in about five years),
development of a technical procedures writers guide, replacement of I&C memoranda with maintenance department Standing Orders, addition of I&C training requirements to the administrative procedure on training, resolution of the concern regarding procedure deviations
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through revision to the change process (in essence it permits only
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one change attachment), and 'only permitting use of' write-in steps on
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repairs with a checklist to be completed to ensure proper application, n.
Weakness:..The licensee performed an INP0 Maintenance Self-Assessment but it was cursory and some of the. deficiencies it identified were
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not corrected (p. 31,.1. 48).
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Findings: The inspector was informed that the Maintenance
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Self-Assessment had_been redone and that its 80 findings were being:
addressed as commitments entered on the licensee's Commitment:
Tracking System.
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Weakness: The licensee's scope of review in addressing manual-valve-concerns described in NRC report NUREG-1195 had been too limited.
Only Auxiliary Feedwater System valves had been considered -(p. 33,
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1. 40).
The MTI identified this matter as Inspector Followup Item 338/89-200-04.
Findings: The inspector found that the Action Plan addressed this as
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a response to NRC Information Notice 86-61 rather than NUREG-1195.
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It provided for a more, thorough assessment of manual valve.PM needs.-
Valve selection was determined from Emergency Operating Procedures
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(E0Ps). PMs are to be developed and scheduled for E0P manual valves
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not already in the PM program.
Scheduling of the new PMs is not specified to be completed until September 30,1990, p.
Weaknesses: Several weaknesses were identified by the MTI which:
appear relatively limited in scope and significance. These included materiel condition deficiencies (p. A-1, l. 47),:an instance in which
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a work request was improperly cancelled (p. A-9,_l. 34), and instances where not all individuals on maintenance crews received pre-job briefings (p. A-10,.1. 8).
Findings: The licensee's Action Plan gave actions undertaken to improve material condition concerns noted in the MTI. They included
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continued efforts to reduce contaminated area and formulation of
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plans for cleaning and-painting in the Service Water Pump House. The
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other two items appeared to have been addressed through various staff changes, reorganization, and changes to administrative controls.
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Action on Previous Inspection Findings (92701, 92702)
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(Closed) Violation, 339/89-13-01, Failure to Perform Weld Repair in Accordance ASME Code Section XI Requirements This violation involved a failure to_ follow the requirements of a welding technique selected for a weld repair.
The technique selected
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and used by the licensee was qualified with post weld heat treatment
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(PWHT) as an essential variable.
The licensee failed to recognize that PWHT was required for the particular application and did not-perform PWHT on the completed repair.
This would have been
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acceptable had the original welding ~ technique been qualified without
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PWHT.
The licensee's response to-this violation, dated July 6, 1989, was reviewed and determined acceptable by Region II. Their corrective i
actions for the occurrence and its cause-included PWHT of the repair,-
qualification of a welding technique for use without PWHT, and cautioning the responsible personnel' as to the correct' requirements.
The inspector verified completion of these corrective actions through-discussions-with responsible licensee personnel, review of PWHT
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records for the repair, and review of the-qualification record sheet for a welding technique qualified without PWHT, b.
(Closed) Violation 338,339/89-13-02, Failure to Establish Measures for the Control and Identification of ER-70S-2 Material to Prevent
Misapplication This violation involved the failure of the licensee to provide requirements for identification of heats of ER-70S-2 wel_ ding materials such that heats supplied with as-welded impact tested-qualified material could be differentiated from stress relieved impact tested
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qualified material.
The licensee's letter of response dated July 6,1989, disputed-this-violation.
Region 11 rejected the denial ~but agreed to reduce the-violation's severity level and accepted changes the licensee stated they would make to their procurement specification for the ER-70S-2 as corrective actions for.the violation.
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the inspector reviewed the procurement specification and verified that it had been revised as stated, c.
(Closed) Inspector Followup Item 338/88-17-01, Rework Governor Valves 2 and 3 and Associated Dump Valves This item was opened for inspector followup of actions to be taken by the licensee in corrective maintenance planned on valves in the Electrohydraulic Control System for Unit 1.
In the current inspection the NRC inspector reviewed a licensee database sumary and verified that the stated corrective maintenance had been performed.
Further, he found that the subject. system had experienced subsequent failure that appeared related, and that the. licensee had conducted a.
root cause evaluation (the RCE 89-116 referred to in 2.h-above)
resulting in identification and correction of various deficiencies in the maintenance performed. Licensee personnel stated that most of the corrective actions recommended from the RCE had been implemented for Unit I and that the EHC System appeared to be performing very well.
Corrections for Unit 2 were said to be planned for the next outage.
Based on his review, the inspector'has determined that this item may be' closed.
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(0 pen)UnresolvedItem 338, 339/90-01-01, Potential Violation of TS 6.8.4a for Failure to Implement an-Adequate'PM Program and Adequately Leak Check Contaminated Gas Systems Technical Specification (TS) 6.8.4a requires the licensee to
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establish and implement a program to limit leakage from-those l
portions of systems outside the containment that could contain highly.
radioactive gases or liquids.
It specifies that the leakage is to be
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as low as practical.
This Unresolved Item identified the NRC resident inspector's concerns that the licensee's program to meet this requirement was deficient.
The item was examined by the Region II based inspector-for information in the current inspection.
This. inspector reviewed two-of the procedures utilized by the licensee in meeting the requirement together with the associated piping drawings. They were the currently applicable revision of Periodic Test 1-PT-57.58, for. leak testing Safety Injection System piping; and the completed record for leak testing Boron Recovery Gas Stripper B, conducted in accordance with procedure 1-PT-57.8B on October 24, 1988. The inspector found that it was unclear why, in. both tests, the positions of some valves were required to be verified while others were not. -Also, for the completed test 1-PT-57.88, the inspector noted that the procedure called for pressuring the system and then ' checking for pressure decay -
(as an indication o.f leakage) before-the pressurizing source was required to be valved out by another procedure step.
The inspector
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concluded that this indicated poorly written procedures and agreed that the preventive. maintenance program required by this TS appeared deficient. The NRC resident was aware of the deficiencies observed-by the regional inspector. This item will remain.open pending completion of its assessment by the NRC resident.
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Exit Interview The inspection scope and findings were summarized on March 23, 1990, with those persons indicated in paragraph 1 above.
The only dissenting comment received from the licensee was with regard to the inspector's description of the procedural deficiency involving a failure to specify that the.
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pressure source should be valved out'before checking for pressure decay as an indication of leakage, described in paragraph 3.d..
The licensee was already aware of this concern from discussions with the resident inspector. They stated that the test personnel would clearly have recognized the need to close the valve and would have done so.
The inspector notes that the procedure did specifically require the subject valve to be closed after a pressure decay check was completed but not
before.
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-5; Acronyms and Initialisms American Society for. Mechanical Engineers.
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Electrohydraulic ~ Control EHC
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E0P-Emergency Operating Procedure-
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Health Physics.
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Heating-Ventilation and Air Conditioning-HVAC
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180 Instrumentation and Control.
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Institute for Nuclear Power Operations -
INP0'
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Maintenance Team Inspection-MTI
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Nuclear Regulatory Commission NRC
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Preventive Maintenance--
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Post Weld Heat Treatment-PWHT
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QA Quality Assurance
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RCE Root Cause Evaluation
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RWP Radiation Work Permit
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Technical Specification
.TS
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