IR 05000352/1987025
| ML20236Q254 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/10/1987 |
| From: | Blumberg N, Prell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236Q232 | List: |
| References | |
| 50-352-87-25, NUDOCS 8711190269 | |
| Download: ML20236Q254 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No.
50-352/87-25
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Docket No.
50-352 License No.
NPF-39 Licensee:
Philadelphia Electric Company Philadelphia, Pennsylvania 19101
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Facility Name:
Limerick Generating Station, Unit 1 Inspection At:
Limerick, Pennsylvania Inspection Conducted:
September 28-October 2, 1987 Inspector:
huXd 8 M7 es Prell, Reactor Engineer, DRS date Approved by:
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Norman J./Blumberg, Chief //
date Operational Programs Sectron OB, DRS Inspection Summary:
Routine Unannounced Inspection On September 28-October 2, 1987 (Report No. 50-352/87-25)
Areas Inspected:
Routine unannounced inspection of Licensee's I&C Program, Maintenance Request Forms, Trending Program, Technical Specifications Related Calibrations, Maintenance Activities, Staffing, Measuring and Test Equipment Program, and QA/QC Interface.
Results: One violation was identified.
Failure to adequately implement the records retention program for maintenance activities.
See Paragraph 2.4 for further details.
8711190269 0711112, PDR ADOCK 05000352 G
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DETAILS 1.0 Persons Contacted Philadelphia Electric Company
- E. Callan, I&C Engineer J. Doering, Superintendent of Operations G. Edwards, Technical Engineer
- J. Grimes, Testing and Laboratories Branch Engineer
- C. Harmon, Quality Assurance (QA) Engineer
- R. Hennessey, Quality Control Engineer I
- J. Rubert, Quality Assurance Site Supervisor
- J. Spencer, Superintendent-Plant Services
- V. Warren, Test Engineer-Regulatory U.S. Nuclear Regulatory Commission
- G. Kelly, Senior Resident Inspector S. Kucharski, Resident Inspector The inspector also held discussions with other licensee personnel during the course of this inspection.
- Denotes those present at the exit meeting on October 2, 1987.
2.0 Instrumentation And Control (I&C)
2.1 References Technical Specifications, Limerick Generating Station, Unit No. 1
ANSI N45.2.6-1978, Qualification of Nuclear Power Plant
Inspection, Examination and Testing Personnel ANSI N18.7-1976/ANS3.2, Administrative Controls and Quality
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Assurance for the Operational Phase of Nuclear Power Plants Regulatory Guide 1.33, 1978, Quality Assurance Program Requirements
Final Safety Analyses Report, Limerick Generating Station,
Section 17, Quality Assurance 2.2 Program Review 2.2.1 Procedure Review The inspector reviewed I&C administrative and corrective (see Attachment A) and preventive maintenance procedures to verify the following:
Controls were in place for safely removing the component /
system from service and then returning it to service;
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A system existed to assure that the latest vendor manuals were available for use; A system was-in place which allowed the Quality Control
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Department'(QC) to review all proposed maintenance acti-vities and' provide independent verification of key'mainte--
nance activities;-
A program existed which helped assure that replacement
parts which were 'used were correct and properly classified; Provisions existed for assuring that Limiting. Conditions
.for Operation'(LCO) requirements were identified and satis-fi.ed during the maintenance activity; i
Provisions existed for assuring housekeeping activities-were maintained; Acceptance' criteria and values for assuring proper system -
operability existed which required verification signoffs to-help assure that the "as' left" system was within specifi-cation; and,
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ment identification numbers and calibrations dates.
2.2.2 Organization Overview The procedures listed in Attachment A were reviewed against the above criteria and regulatory requirements. The I&C department use an automated system called " CHAMPS" - Computerized History And Maintenance Planning System, to schedule all maintenance activities and track maintenance results. All Preventive Main-tenance (PM) and Corrective Maintenance (CM) is administrative 1y controlled through a computer generated " Maintenance Request Form" (MRF).
The I&C Department consists of two major groups; the Station's I&C Engineer group and the Testing and Laboratory (T&L) group.
l The.I&C Engineer group has overall control of all I&C activi-ties. They perform the administrative control oversight func-tions of I&C.
The T&L group administratively reports to PEC0 headquarters, but are permanently located on site. They are responsible for the actual performance of maintenance activi-ties. The T&L group use company wide T&L procedures to perform all on site maintenance activities, but they are subject to the administrative controls at Limerick. T&L procedures are re-viewed and approved by headquarters management.
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The I&C Engineer group and the T&L group interface well to-gether.
This is based on the following observations:
The I&C engireer and the T&L engineer work together in
analyzing equipment problems; The MRF requires coordination between the two groups.
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I&C Engineer group establishes the priority of work to be done and the T&L group determine who and when it will be done and what procedures are required; and, The I&C Engineer group and the T&L group share common
office space thereby facilitating easy communications.
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2.3 Program Implementation l
2.3.1 Trending Program Review
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The licensee is in the process of developing a trending program for monitoring the number of repeatable CM activities and the number of PM activities associated with a particular system.
The proposed system would use the CHAMPS data base to provide a listing, by system and equipment number, of all PM and CM activi-ties occurring with that system, the identified problem and its resolution, the date of the activity, and the MRF number under which the maintenance activity was performed (see Attachment B for listing MRFs reviewed).
Once every six months, the licensee will obtain and review a new listing to determine if any maintenance tre,ds are developing.
Another computerized program is being developed for tracking
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overdue PM activities.
This system will also use the CHAMPS
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data base.
2.3.2 Technical Specification Related Calibrations The licensee uses CHAMPS for scheduling Technical Specification (TS) related calibrations. A two year recalibration program is being implemented for instruments located in the Control Room and a three year recalibration program is being implemented for instru-ments in the plant.
Other instruments requiring more frequent PMs are currently being scheduled and worked off.
The inspector reviewed the summary PM printout dated September 22, 1987, and I
verified most PMs are being completed within orie month of the
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scheduled date.
The inspector identified the following instrumentation as being TS related and verified preventive maintenance had been performed j
within the past ten months:
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FT-055-1N008v HPCI flow transmitter FT-051-1N015A RHR flow transmitter FT-052-1N003A CSS flow transmitter CT-048-1N001 SLC level transmitter TIS-048-1R002 SLC Temperature indicating system TT-077-101G Drywell temperature transmitter 2.3.3 Corrective Maintenance
.The inspector witnessed two CM activities related to recalibra-tion of the gain adjustment for two Local Power Range Monitors (LPRMs) following a Transversing Incore Probe (TIP) pass.
Local power range readings were not being received by the computer from LPRM locations48-498 and 48-178.
CM activities were performed simultaneously under MRF numbers 8707031 and 8707032.
The inspector verified the following:
The technicians performing the work were experienced and
trained on nuclear instrumentation and computers; The MRF packages had received I&C supervisory and QC review
authorizing the work and all required procedures and data sheets were attached to the MRFs; The shift supervisor was well briefed on the proposed work
and approved the work activity; QC was notified and present during the entire CM activity;
The technicians displayed good knowledge of the systems
they were working on; Good housekeeping practices were in evidence; and,
All administrative controls and maintenance procedures
were observed and followed.
2.3.4 RHR Service Water Radiation Monitors The inspector reviewed problems the licensee was experienc-ing with their Residual Heat Removal (RHR) Service Water (SW)
Radiation Monitors.
Two basic problems were identified and were being addressed by the licensee:
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i (1) The four sampling lines used for transmitting RHR SW to the Radiation Monitors were found to be clogging thus preventing sufficient flow to the radiation monitors.
The clogging resulted from the way these pipes were routed as well as rust buildup.
The licensee was in the process of rerouting and replacing these pipe lines with stainless steel piping, f
(2) The licensee had made a commitment to the NRC to replace the RHR SW radiation monitors with seismically qualified monitors during their first outage.
Problems were experienced, however, during the installation of the seismically qualified monitors which could not be resolved prior to completion of the outage.
As a consequence, the licensee reinstalled the original radia-tion monitors and requested of NRC a delay of their commitment until the second refueling outage for the installation of the seismically qualified radiation monitors.
In a letter dated August 2, 1987, the NRC documented a safety evaluation on the
. licensee's request and authorized continued use of the non-seismically qualified monitors until the second refueling outage. The licensee continued working with the vendor to resolve the problems with the seismically qualified radiation
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monitors.
2.3.5 Staffing The inspector reviewed the staffing levels and training of the I&C department.
The I&C Engineer group for Unit 1 consists of four engineers with degrees and seven technical assistants who all have two year associate degrees.
Both the engineers and technical assistants receive an additional two years of training specific to Limerick systems and procedures.
The T&L group for Unit I consists of 54 technicians, approximately one half of which were contractor personnel, and eight supervisory personnel. All technicians must have, as a minimum, an associate degree or its equivalency.
In addition, technicians were required
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i to undergo 456 hours0.00528 days <br />0.127 hours <br />7.539683e-4 weeks <br />1.73508e-4 months <br /> of training over an 18 month period on plant
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systems and procedures.
This training program was in the process
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of receiving INP0 accreditation.
2.3.6 Measuring And Testing Equipment (M&TE) Program All M&TE used by I&C was stored and issued from the Instrument Issue Shop. A manual card system was used for signing out and in any equipment borrowed.
The licensee was developing, however, a computer system which eventually will use bar codes to log I
instruments in and out of the shop.
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All calibrations of M&TE were controlled from a central a
metrology laboratory located offsite, which also was-used by the t
other PECO power plants.
Each month a listing is sent out by the metrolcgy lab to the site which identifies equipment whose calibration due date is about to expire.
The Issue Shop sends all identified equipment to the Metrology Lab for recalibration.
Technicians list on the MRF all M&TE used to complete a mainte-nance activity.
This information is inputed into a computer tracking program along with the MRF number.
If the metrology lab discovers a returned M&TE out of calibration, the computer is used to identify those jobs the M&TE was used on.
I&C then performs a recalibration of the three most recent jobs the M&TE was used on.
If the three previous systems were found in calibration, I&C then assumes all calibration jobs performed prior to them, were also in calibration.
If recalibration was required, of any of these three systems, I&C then performs recalibrations of the older jobs where the M&TE was used.
The inspector toured the Instrument Issue Shop, reviewed the existing and proposed programs for issuing, docketing and returning M&TE, and reviewed the recalibration contrc' program.
2.3.7 Maintenance Request Forms (MRFs) Review The inspector reviewed the MRFs listed in Attachment B and verified, when applicable, that they contained the following types of information:
All required administrative approvals were obtained prior
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to initiating the maintenance activity.
Included in this were the Senior Reactor Operator's (SRO) signature indicat-ing he/she had been briefed on the proposed work; Approved T&L maintenance procedures were listed;
i Quality Control (QC) review, and required QC inspections
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were indicated; j
i All the Measuring and Test Equipment (MTE) used was listed
and the ccmpleted data sheets were attached; The maintenance problem and the corrective actions taken
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were clearly written; I
Housekeeping activities were signed off by the technicians;
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Maintenance trending information and lifted leads informa-
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tion were documented; and, Administrative approvals of the completed work activities
by Operations, I&C, and QC supervisory personnel were obtained.
2.4 Findings The MRF is divided into seven sections. As each section is completed it is logged into the CHAMPS computer to indicate completion of that section.
Upon completion of the work, the MRF package is reviewed by the QC Department and sent to the I&C Engineer. A26, " Procedure for Corrective Maintenance", Section 5.7.3.4 requires the I&C Engineer to review the MRF package for completeness and sign Section 7.
An entry showing completion of the MRF is then required to be entered into CHAMPS and the package forwarded to the Nuclear Records Management System Office for retention.
Technical Specifications, Limerick Generating Station, Unit No. 1, Section 6.10, " Records Retention" requires that records of maintenance activities be retained.
The inspector observed that the licensee failed to adequately maintain their I&C maintenance records in that: based on a review of the CHAMPS list of open MRFs dated September 28, 1987, forty out of 452 open MRFs were found where the work had been completed and accepted by the Operations Department more than six months previously but, where an. entry had not been made to CHAMPS indicating that section seven was signed off and the MRF completed.
Twenty-three of the forty MRFs were over one year old, four of which were over two years old.
A subsequent investigation by the licensee found that twenty-four MRFs had been signed off by the I&C Engineer and were in the Nuclear Records l
Management System office but were not entered into CHAMPS, five were on the I&C Engineers desk awaiting signature, eight were found in an old folder, and three of the original MRF package were not found.
Of the eight found in the old folder, one safety related MRF was missing its recalibration data sheet, but the rest of the package was complete and indicated that the technicians and QC had found the system in calibration. Of the three whose original MRF package could not be found, copies for two of these were found.
7'are was only one MRF package where no records could be found that the work had been completed.
This MRF, number 8502653, was over two years old, but was a non-safety related activity.
Based on the above, this is a violation of T.S. 6.10 in that the licensee did not adequately maintain some required records of safety related
maintenance (50-352/87-25-01).
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Subsequent to the inspection, the licensee informed the inspector
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that a tracking system was being established to track any MRF l
packages which were open more than three months after acceptance by the Operations Department.
3.0 Quality Assurance / Quality Control (QA/QC) Interface 3.1 Quality Control (QC) Department The inspector reviewed with the site's QC group their responsibi-lities relating to I&C maintenance activities.
Based on this review, the following was determined:
QC establishes very few hold points in the T&L procedures.
- Instead QC engineers provide 100% review of all proposed MRFs.
During this review QC verifies if the MRF package is properly classified as Q or Non-Q, verifies that the proper procedures were identified and identifies any procedural controls which should be addressed; Presently QC inspects all safety related maintenance act-ivities.
- All inspectors are Level II certified to ANSI N 45.2.6.
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are thirty QC inspectors and seven QC engineers; QC inspection reports (QCIRs) are prepared for each inspection
activity.
The NRC inspector reviewed the QCIRs listed in Attachment B; The QC Department has established an automated "QCIR Information
Retrieval Tracking System". The system was used by QC to cross reference QCIR numbers to the MRF number or equipment identifi-cation number. The inspector reviewed the listing dated September 22, 1987; and, The QC Department has established procedures and instructions
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for administering their program. The inspector reviewed the instructions listed in Attachment B.
3.2 Quality Assurance (QA) Department The inspector made a review of the QA Department's program as it relates to I&C activities. Prior to performing an audit, the auditor contacts a Nuclear Review Board member to get their input on the proposed audit.
Findings from audits are issued within thirty days as Nonconformance Reports (NCRs), significant NCRs, and deficien-cies. The audited organization must respond within sixty days.
Failure to respond within three months to any audit findings results in the organization getting a letter from the Vice President which produces effective results.
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The inspector reviewed the following audit reports:
AL85-70 MI, 10/30/87, LGS Maintenance of Instrumentation and j
Controls; AC86-80 MI, 11/4/86, Off-Site Calibration and Control of
Portable Measuring and Test Equipment.
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The audit reports clearly identified acceptable, as well as
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unacceptable, findings and the basis for them.
The audits appeared
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thorough and comprehensive.
4.0 Exit Interview An exit interview was held on October 2, 1987, and telephone calls were made on October 13 and October 22, 1987, to discuss the inspection scope and findings as detailed in this report.
(See paragrapt 1.0 for attendees).
At no time was written material given to the licensee.
The inspector determined that no proprietary information was utilized during this inspection.
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1 ATTACHMENT A
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Procedures Reviewed
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A25.1, Rev 2, Preventive Maintenance Program A26, Rev 12, Procedure For Corrective Maintenance A41.1, Rev 5, Troubleshooting Safety Related And Tech Spec Equipment A42, Rev 5, Procedure for Control of Temporary Circuit Alterations
(TCA)
A25, Rev 4, Preparation of Preventive Maintenance Procedures TL-11-00023, Rev 0, Preventive Maintenance Procedure For The Foxboro Model 130P-N4 Controller TL-11-00028, Rev 1, Preventive Maintenance Procedure For The Rosemount Model 1151 Pressure And Differential Pressure Transmitter TL-11-00037 Rev 0, Preventive Maintenance Procedure For Baily Type ACO 404 Pneumatic Control Drive RT-12-00111, Rev 1, Control Of Test Equipment Calibrated By Limerick Branch
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TL-11-00103, Rev 0, Calibration procedure For Mercord Pressure Switch RT-11-00302, Rev 0, Calibration of GE 555 And GE 556 Transmitters TL-11-00338, Rev 1, Testing Of Marotta Excess Flow Check Valves TL-11-00333, Rev 1, Calibration of Rosemount Trip / Calibration System Model 5100U With Bench Test Facility TL-11-50014, Rev 2, Control Of The Calibration Of Plant Instrumentation And Equipment TL-11-00484, Rev 1, Checkout, Maintenance And Troubleshooting Of:LPRM Detectors TL-11-00419, Calibration Of LPRM
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ATTACHMENT B Maintenance Request Forms Reviewed
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8781924 PASS Pressure Transmitter 8781917 PASS Perform Routine Calibration 8705467 Containment Atmosphere Control 8704965 Reactor Enclosure HVAC 8707031 Neutron Monitoring 8707032 Neutron Monitoring 8687273 Generator And Exciter 8587343 Drywell HVAC 8687254 Standby Liquid Control 8687202 Standby Liquid Control 8780797 Core Spray System 8780793 Residual Heat Removal 8687046 High Pressure Coolant Injection 8780901 High Pressure Coolant Injection 8780900 High Pressure Coolant Injection 8705350 Neutron Monitoring 8607337 Neutron Monitoring 8705802 Plant Process Rad Monitor 8701648 Control Enclosure Chiller Water 8704517 HPCI Quality Control Inspection Reports Reviewed BAF-87-5799 Analog Trip Module And Replacement PCG-87-5798 Preventive Maintenance 182V212-DR CRI-87-5787 Valve Blueing CRI-87-5782 HCU Rebuild CRI-87-5778 LPRM Installation GPH-87-5770 LPRM Installation ERP-87-5745 Installation Of Transition Tube CLE-87-6592 Final Review Of MRF 8705881 and PMQ MLH-87-5686 PM On Sample Pump Analyzer Package MLH-87-5684 Reterm Motor LGS-QCI-006-1 Revision 1, Instructions for Processing of Maintenance Request Forms (MRFs)-
l LGS-QCI-00C-2, Revision 0, Instruction For Conduct of MRF Activities; and, LGS-QCI-006-3, Revision 2, Instruction For Review of Completed MRF Packages.
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