IR 05000352/1986020
| ML20215D407 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/02/1986 |
| From: | Bissett P, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20215D391 | List: |
| References | |
| 50-352-86-20, NUDOCS 8610140121 | |
| Download: ML20215D407 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-352/86-20 Docket No.
50-352 License No. NPF-39 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station, Unit 1 Inspection At:
Limerick, Pennsylvania Inspection Conducted: September 8-12, 1986 Inspectors:
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'P' Bissett, Reactor Engineer
' date Approved by:
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J. ' Johnson, Ck ef, Operational date Programs Section, Operations Branch, DRS Inspection Summary:
Inspection on September 8-12, 1986 (Report No. 50-352/
86-20)
Areas Inspected: A routine, unannounced inspection by one region-based inspector of the licensee's maintenance program and associated activities including QA/QC involvement.
Results: No violations or deviations were identified.
8610140121 861002~
PDR ADOCK 05000352 G
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DETAILS 1.
Persons Contacted Philadelphia Electric Company R. Costagliola, Supervising Engineer, Maintenance Division
- S~. DiMauro, Lead Auditor, EPQA
- J. Doering, Superintendent - Operations
- C. Endriss, Regulatory Engineer
- J. O'Mara, Supervisor - Maintenance Division
- J. Spencer, Superintendent - Plant Services W. Texter, General Supervisor - Quality Control
- C. Wyler, Engineer - Maintenance U.S. Nuclear Regulatory Commission
- E. Kelly, Senior Resident Inspector S. Kucharski, Resident Inspector The inspector also held discussions with other licensee employees (inclu-ding engineers, foremen, and QA/QC personnel) during the course of the inspection.
- Denotes those present at the exit meeting on September 12, 1986.
2.
Action on Previous Inspection Findings (Closed) Unresolved Item (352/85-30-02) Revise A-40, " Procedure For Work-ing Hours Restrictions," and MA-23, " Maintenance Division Administrative Procedure for Controlling Work Hours For Nuclear Plants," accordingly to provide further clarification in regard to station overtime policy. The inspector performed a review of the following areas to verify that ade-quate corrective action had been taken to resolve any concerns involving station overtime:
Most recent revision of A-40, dated April 30, 1986 which included clarification as to when a Deviation Form is required;
Health Physics memorandum to HP personnel further clarifying the intent of A-40;
Most recent revision of MA-23 to ensure consistency with A-40;
Proposed Technical Specification change involving further clarification as to what organizational groups are specifically affected by overtime restrictions when performing safety-related work; and,
QA audit reports verifying appropriate action had been take.
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based upon the inspector's review of the above, this item is closed.
3.
Maintenance Organization The maintenance organization at the Limerick Generating Station comprises a maintenance group and a maintenance division. The Maintenance Group reports to the Limerick station management.
The Maintenance Division, although organizationally separate from the Maintenance Group, ultimately reports to the same vice president as does the Limerick station manage-ment. The Maintenance Group essentially performs all the planning and scheduling for upcoming maintenance activities. The Maintenance Division in turn performs the actual work.
The Maintenance Division is comprised of supervisors, a technical engin-eering group, foremen, assistant foremen, sub-foremen and tradesmen and administrative personnel. Organizational 1y, it is broken down into four sections: mechanical, electrical, auxiliary, and piping. Approximately 117 maintenance personnel are stationed permanently at the site with an additional 20 mobile personnel during normal operations.
The Maintenance Group, headed by' the Engineer and Assistant Engineer-Maintenance has several supporting sections covering such areas as spare parts, machinery history, procedures, engineering, and housekeeping. The Maintenance Group consists of approximately 25 engineers, technical assistants (TA) and junior TAs.
4.
Maintenance Program Review / Implementation Administrative controls were reviewed to evaluate the licensee's program for implementing requirements associated with preventive and corrective safety-related maintenance activities.
The objectives were to assure that the licensee's programs were consistent with the Technical Specifications, Regulatory Guide 1.33, and ANSI N18.7-1976, " Administrative and Quality Assurance Requirements for the Operational Phase of Nuclear Power Plants."
Documents reviewed are listed in Attachment 1.
The inspector held several discussions with maintenance supervisory personnel to evaluate those controls in place used to identify, schedule, track, perform and document maintenance activities via the Maintenance Request Form (MRF).
The MRF helps provide the administrative control for identifying, initiating, planning, tracking and reporting of all mainten-ance.
The licensee utilizes a Computerized History and Maintenance Planning System (CHAMPS) to provide administrative control of all maintenance activities.
Through the use of CHAMPS, all planning, review and approval (Sections 1 through 3 of the MRF) are performed on the computer, with no paper copy, up to the point of equipment release (Section 4 of the MRF).
Subsequently, the paoer copy of the MRF is produced, and together with appropriate permits and approvals; Operations personnel forward them to
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the appropriate work group thus enabling work to begin. Maintenance work and related information is documented in Section 5 of the MRF by the responsible work group. Upon completion of the work activity, the MRF is returned to Operations, whereby any applicable post-maintenance testing is performed.
Post-maintenance testing is accomplished through the use of an Operation Verification Form (OVF) and is noted as such in Section 6 of the MRF.
The Maintenance Request Form provides the necessary interface mechanism between various organizations (ie., operations, maintenance, health physics, QC, engineering) needed to control the conduct of work activi-ties.
Quite often, an Equipment Trouble Tag (ETT) is utilized to initially identify any equipment problems. The ETT information is then transferred to Section 1 of the MRF.
(It should be noted that a MRF may be generated without the issuance of an ETT). Problems in the past have shown that ETTs were being left in place, even though corrective maintenance had already been completed. To ensure that the process is working, the licensee initiated a surveillance test that is periodically performed to verify the validity of ETTs that are still outstanding. Also, an entry in Section 5 of the MRF is used to denote whether an ETT was removed follow-ing completion of the job. The inspector noted during his reviews that these controls providing for ETT removal are being effectively utilized.
Following successful completion of work, including associated post-mainten-ance testing, the completed work package is forwarded to QC and the Main-tenance Group for final review, pridr to forwarding to plant records.
Discussions were held with both maintenance and QC personnel to ascertain the purpose and extent of this review.
QC's review encompasses primarily an administrative review and the reference of any associated QC Inspection reports. Maintenance's review verifies that all documentation relating to the work activity has been included with the work package and that Section 5 of the MRF has been properly completed.
The inspector noted that additional internal specific guidelines have been written by the Maintenance Group to ensure the completeness of the work package and associated MRF. These guidelines are also used to ensure the accuracy and completeness of information that will eventually be entered into the following programs:
CHAMPS;
PM Baseline;
Serial. No. Tracking; and
Equipment Failure Trend Analysis.
All of the above programs along with the appropriate procedures were discussed with various maintenance supervisory personnel throughout-the inspection.
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During the inspection, the inspector followed three maintenance activities that were performed during the week. These activities were controlled under MRF #'s 8604584, 8604767, and 8605531.
In conjunction with this followup, the inspector held discussions with both an STA (responsible for identifying post-maintenance testing requirements) and the Permit Coor-dinator (responsible for providing the appropriate permits which includes the blocking of necessary equipment). The three work activities followed included 1) the repacking of a valve, 2) the replacement of a defective valve handwheel switch, and 3) the installation of a new 1" vent line.
The inspector's review of these work activities verified.the following:
Required administrative approvals were obtained prior to initiation of work;
Appropriate approved procedures, instructions, and/or drawings were used; Hold points were appropriately identified and completed;
Properly specified parts and materials were identified;
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Acceptance criteria were specified and met; and,
Appropriate radiological precautions were taken.
Prior to commencement of work on MRF # 8605531 (valve packing leak), the licensee conducted a walk-through of how the work was to be accomplished. This walk-through was conducted utilizing Unit 2, which is presently under construction. The actual location and surrounding obstructions in which the work was to be performed are very similar for
both units. However, in Unit 2 the workers would not be subject to any l
radiation fields. Thus, this walk-through enabled the licensee to accomplish the following:
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Identify the correct tools needed to complete the job;
Identify the best position in which to remove the old packing and install the new; l
l Familiarize the workers as to where the radiation levels were the
highest and conversely, the lowest; Identify any obstruction near the valve that might interfere with
the workers; and Provide the opportunity for all involved parties (ie., maintenance,
engineering, H.P.) to participate and present any additional questions and precautions that may not have been previously identified.
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The actual repacking of the valve was later accomplished in an expeditious manner with a minimal amount of radiation exposure.
Licensee representatives stated that, if warranted, they intend ca utilizing Unit 2 in a similar capacity for future maintenance werk activities. The inspector had no further questions.
5.
Measuring and Test Equipment Discussions were held with two toolroom attendants who maintain control over measuring and test equipment (M&TE) utilized by maintenance per-sonnel. Adequate controls were found to be implemented during a review of the equipment sign-out log, completed work packages and a tour of the the toolroom.
All M&TE within the toolroom, was located within locked storage cabinets. A physically separate area, was utilized for the storage of out-of-calibration instruments.
Discussions with the Engineer-Supervisor indicated that plans are being made to provide the toolroom with calibration standards, thus providing additional assurance of the accuracy of M&TE prior to its' issuance.
The licensee is attempting to minimize the number of instances where M&TE would be issued but not determined to be out-of-cal until its' next scheduled recalibration check. The inspector had no further questions.
6.
Training The inspector toured the licensee's maintenance training facility at Barbadoes Island, in Norristown, Pennsylvania. The facility is a decommissioned fossil plant that is located approximately 20 miles f~ om r
the Limerick site. Discussions with the Training and Testing Group Foreman indicated that the distance between the two locations provides the added assurance that an individual will be dedicated to training during his assignment.
A Nuclear Instructor (NI) permanently stationed onsite, provides the necessary interface between the site and the training department. How-ever, his time and effort is presently divided between Peach Bottom and Limerick. The inspector was informed that a Nuclear Instructor position had been recently authorized for both sites. An example of his inter-facing importance was presented to the inspector by the Training and Testing Group Foreman. Apparently, a Health Physics concern had just recently been identified at the Peach Bottom site and the NI had immedi-ately identified the problem to the Training Department, thus suggesting that additional training be given to maintenance personnel in this area.
A tour of the facility indicated that equipment is provided for hands-on-training in addition to formalized classroom instruction. Most classes comprise a maximum of 4 students. This provides for excellent interfacing between the instructor and the student.
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A random sample of training records for three individuals verified that records are maintained and kept current.
The inspector had no further questions.
7.
Administrative Controls 7.1 Interfaces On a daily basis, three scheduled meetings are held which maintenance regularly attends. These meetings are held at 8:00 a.m., 11:00 a.m.,
and 1:00 p.m., lasting approximately 20-25 minutes. The inspector attended each of the above three meetings at least once and found all three to being informative and concise.
Interaction between the various disciplines, was found to be excellent.
Current status and any changes to the previous day's activities involving maintenance were presented to all parties involved. Detailed status sheets are also distributed during the 11:00 a.m. and 1:00 p.m. meetings.
7.2 Work Hour Control The inspector reviewed administrative controls in place for control-ling work hours for both the Maintenance Division and Maintenance Group personnel. Discussions were also held with the respective supervisory personnel in regards to these controls. On a daily basis, one is able to determine the total of all hours worked by maintenance personnel.
Equal distribution of overtime is attempted throughout the work force in an effort to minimize the number of instances in which procedural and Technical Specification guideline limits are approached.
If these guidelines are exceeded, authori-zation must have been given and noted on the appropriate Overtime Deviation Report.
The inspector reviewed Overtime Deviation Reports generated for the past 4 months and determined that the deviations were appropriately justified and not used unnecessarily or excessively.
8.
Machinery History The inspector reviewed documentation detailing equipment maintenance (both preventive and corrective) that had been performed during the past 12 months. Discussions were also held with the Preventive Maintenance (PM)
Engineer and the CHAMPS Coordinator for further details associated with the PM program implementation and subsequent documentation.
The PM master schedule was presented and briefly reviewed, along with various preventive maintenance procedures. The licensee currently maintains over 500 PM procedures that are utilized during the conduct of PM.
The PM program is continually under evaluation, especially since it is relatively new. Vendor recommendations, NPRDS evaluations, NRC notices, etc. are being reviewed for applicability and subsequent changes to the PM program. Trends identified as a result of input to the CHAMPS system are planned to be included in the development of the PM program.
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Findings No violations were identified, however, the inspector expressed some concern in the following areas.
- During the inspectors review of Overtime Deviation Reports, it was determined that rarely were dates entered authorizing overtime in excess of guidelines set forth in MA-23. When dates were found to be entered, they normally were 7-10 days after the event.
The inspector verified that adequate controls and reviews had taken place by appropriate personnel prior to granting this authorization.
During the performance of work controlled under MRF # 8604584, the Local Permit # under Section 4 of the MRF had not been entered. This was brought to the attention of the licensee primarily because the licensee had assured the inspector that work could not commence unless a MRF and applicable permits were issued to the work group.
The licensee provided the necessary information which documented that a local permit had indeed been issued. Appropriate plant personnel
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were subsequently informed of the oversight both orally and in
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writing.
Licensee's corrective actions were found to be adequate and there were no further questions.
- During the inspector's review of equipment history data sheets, the inspector noted that frequently the failure /cause section extracted from Section 5 of the MRF was blank.
The licensee reviewed the internal guidelines that had just recently been written to provide added assurance that detailed information would be included in Section 5 of the MRF. Technical Assistants (TA), Junior TAs, and responsible system engineers now utilize a MRF closure checkoff sheet when reviewing a work package.
If they are not fully satisfied with the "cause of the failure" section, the entire work package is returned to the work group for further explanation / clarification.
The inspector had no further questions.
- The inspector noted considerable delay in forwarding completed work packages to records for storage following completion of the work activity. Although this problem has been previously identified by other groups, the inspector felt it warranted continued attention.
The maintenance personnel had been notified of this problem via a memorandum. The licensee acknowledged that it was a problem area and
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that efforts would continue towards decreasing the time, however, not at the expense of the quality of the work package. The inspector agreed. There were no further questions.
10. Quality Assurance / Quality Control Interface (QA/QC)
QA/QC has onsite QA and QC personnel who independently monitor daily station activities. Discussions were held with supervisors and engineers of both groups in order to determine the extent of their involvement with maintenance activities.
QA routinely schedules and performs both audits and surveillances. The inspector reviewed those audits /surveillances conducted within the last 12 months that dealt with the area of maintenance. QA coverage in this area included:
Diesel generator maintenance;
Post modification / maintenance test control;
Cor: trol of heavy loads;
Reactor recirculation pump seal repair and replacement; and
Electrical maintenance administrative controls.
All findings are being tracked and followed up by QA personnel. No major findings during these audits were noted by the inspector.
QC personnel perform reviews of safety-related MRFs prior to and following the conduct of a maintenance activity. They also perform planned " hold point" inspections and random monitoring of maintenance activities. A monthly inspection and monitoring report is also provided to keep key management personnel informed of QC's involvement in daily station activ-ities. This summary report was found to be quite informative and included narratives, statistics, and graphs of the results of the past inspections and monitorings and their status to-date.
11.
Exit Meeting The inspector met with the licensee representatives (denoted in paragraph 1) on September 12, 1986 to summarize the scope and findings of the inspection.
At no time during the inspection was written material provided to the licensee.