IR 05000352/1993008
| ML20035C288 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/26/1993 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035C287 | List: |
| References | |
| 50-352-93-08, 50-352-93-8, 50-353-93-08, 50-353-93-8, NUDOCS 9304070008 | |
| Download: ML20035C288 (36) | |
Text
{{#Wiki_filter:l.
- w t.
U.Sc NUCLEAR REGULATORY COMMISSION-
REGION I
l Report Nos.
93-08 93-08 Docket Nos.
50-352 50-353 ' License Nos.
NPF-39 NPF-85
Licensee: Philadelphia Electric Company , Correspondence Control Desk P.O. Box 195 - Wayne, Pa 19087-0195
Facility Name: Limerick Generating Station, Units 1 and 2 Inspection Period: February 22 - 26,1993 > Inspectors: N. S. Perry, Senior Resident Inspector,-Yankee Rowe, DRP~ ' W. H. Baunack, Senior Reactor Engineer, DRS: M. J. Buckley, Reactor Engineer, DRS (part-time) T. A. Easlick, Resident Inspector, Limerick, DRP (part-time) T. J. Kenny, Senior Resident Inspector, Limerick, DRP (part-time) l . )
. 3 46
Approved by: /- Clifford IJ.8Andgson, Chief Date Reactor Projects Section No. 2B ,
i i ! i 9304070000 930329 PDR ADOCK 05000352 G PDR i
, _ . __ -. . . _.
. -. . . I.
.% .i . t- ! ! EXECUTIVE SUMMARY Limerick Generating Station ! Report No. 93-08 & 93-08 q ' .[ i Preventive Maintenance j Controls for planned, preventive maintenance on systems requiring entry into an LCO, are f' adequate and maintenance is being completed as scheduled to meet established goals.
, Overall, system performance has been good, and the corrective maintenance backlog has [ decreased significantly over the past 7 months.
-} Procedure Adherence j During the inspection, procedure adherence was found to be good. Additionally, corrective-l actions for past procedure adherence problems were found adequate. Three NRC open , items, concerning procedure adherence are closed.
, Observations / Review of Maintenance in Procress Observed maintenance activities were adequately controlled and completed. The quality of written instructions and procedures used by the workers is in need of improvement, and is currently being addressed by management.
, . Control of Parts and Materials Used Durine the Performance of Maintenangg [ _ t Adequate controls have been established to assure that qualified parts and materials are used during the performance of maintenance. Corrective actions are being initiated for identified:
deficiencies.
t I
? e l.
f
!
- i i ! i
i ! . -
- . _. .. . s , (
. i TABLE OF CONTENTS EX EC UTI VE S U M M A RY...................................... i -{ i
1.0 PREVENTIVE M AINTENANCE.............................. 1 2.0 PROCEDURE ADHERENCE................................ 2 - ! 3.0 MAINTENANCE IN PROGRESS
> ............................. 3.1 High Pressure Coolant Injection Train 18 Month Inspection
.......... 3.2 Emergency Selvice Water Valves HV-Oll-047 and HV-Oll-077
Rework......................................... 4
' 3.3 Disassembly and Rework of HPCI Valve HV-055-2F001........... 5-3.4 Replacement of Leakoff Plugs and Retorque Packing for Residual Heat Removal Valve HV-051-2F048A.......................... 5 - 3.5 Control Rod Drive 0-ring Replacement...................... 5 3.6 Unit 2 Reactor Mode Switch Maintenance.................... 6.
! 3.7 Concl u sion s....................................... 7 i i 4.0 CONTROL OF PARTS AND MATERIALS USED DURING THE i PERFORMANCE OF MAINTENANCE
........................ 4.1 Planning of Maintenance Activities......................... 8 4.2 Bill of Materials....................................10
' 4.3 Environmental Qualification Requirements................... 10- '; 4.4 Repair of Q Components.............................. - 11 4.5 Repair of Equipment Subject to ASME Requirements
..... ...... 4.6 Conclu sion s......................................
- 5.0 MANAGEM ENT MEETINGS..............................
5.1 Exit Interviews...................................
, , . ,-
,. - - - . s DETAILS , 1.0 PREVENTIVE MAINTENANCE (62703)' The inspectors reviewed the controls over the removal of systems for planned, preventive maintenance, requiring entry into a Technical Specification Limiting Condition for Operation (LCO). Specifically, the inspectors reviewed the planning of system maintenance to determine if there is an improvement in the overall reliability of the systems. The NRC is concerned that this type of maintenance should not be done only to shorten a refueling outage, and the licensee should be able to justify an expectation of improved safety, by making equipment more reliable. If various equipment is out of service often, during plant operations, then the probability that some system will be unavailable during a plant transient could be high. NRC unresolved item 50-352/92-29-01 documented a significant amount of LCO preventive maintenance on a number of systems. PECo discussed their program to control LCO preventive maintenance activities during a meeting at the site on February 25, ' 1993. The meeting slides are provided as Attachment B to this report.
Limerick Generating Station procedure AG-43, Guideline for the Performance of System Outages, Revision 8, provides the guidance for the execution of system outages during power operations. The guideline provides instructions for establishing planned system work windows, for the planning process, for considering multi-train systems, and for unplanned system outages. Additional specific system guidelines are provided and a tracking mechanism for system Probabilistic Risk Assessment (PRA) anavailability is described. A system is "PRA unavailable" when it actually cannot perform its intended function. AG-43 relies on sound operating judgement and PRA insights, and groups systems important to safety by relative PRA impact. The procedure also stresses minimizing the time spent in a Technical Specification LCO. The program was patterned, in July 1992, after the on-line maintenance program at the Peach Bottom Atomic Station. PECo stated that system outage time was somewhat high through the second half of 1992 due to the programs recent inception. Plant management expects the amount of planned maintenance and time spent in LCOs to decrease over the next year as systems 1 :ome more reliable and the planning system becomes more efficient. System windowt 'ill be scheduled well in advance; however, expectations are that not all windows will need to be utilized as system reliability increases. Plant management also expects system forced outage time to decrease and overall system outage time to decrease in the future, although they have not established specific outage time goals. Licensee PRA calculations, based on the impact of all maintenance activities in 1992, showed that the estimated core damage frequency for both units was slightly better than the PECo goal of 6 E-6.
The ir.spectors reviewed AG-43, records of past system outages (planned and forced), and the planned system outage schedule through the end of 1993. Additionally, the inspectors reviewed the tracking of system PRA unavailability, the corrective maintenance backlog trend for the last 7 months, and system outage pedormance indicators. The planning of system 'The NRC Inspection Procedures used as guidance are listed parenthetically throughout this repor ; - > g
< outages was found to be consistent with the guidance provided in AG-43. Tracking of system PRA unavailability indicated good overall performance. For systems important to safety, the inspectors observed that the majority of the trends were below the established
goals. The total non-outage corrective maintenance backlog has decreased significantly over the past 7 months. System outage performance indicators showed good performance with a recent decrease in the ratio of tasks completed to tasks scheduled due to work postponed in i preparation for the Unit 2 refueling outage. The inspectors concluded that the controls for planned, preventive maintenance, for systems requiring entry into an LCO, are adequate and that the maintenance is being completed as scheduled to meet established goals. The inspectors will continue to monitor the planning and performance of preventive maintenance to ensure that it results in improved safety. Unresolved item 50-352/92-29-01 is closed.
2.0 PROCEDURE ADHERENCE (62703,92701) Past problems with procedure adherence at Limerick resulted in the following three NRC open items: 50-352/91-11-01 Violation of Technical Specification 6.8.1.D Requiring Procedures to be Implemented 50-352/92-03-01 Failure to Follow MOV Maintenance Procedures 50-352/92-27-01 Failure to Implement Corrective Actions - PECo provided an overview of their maintenance activities during the February 22,1993 entrance meeting for this inspection. A copy of the meeting slides is provided as , Attachment A.
This inspection of maintenance in progress and planning of maintenance, including spare
parts used and the observation of pre-planning meetings did not identify any new procedural issues. Additionally, recent observations by the resident inspectors of ongoing and completed work packages shows the workers are following procedures to completion with
complete reviews following the closure of the procedure.
The awareness of the working personnel toward procedure compliance was reviewed by a check of training records and interviews by the inspectors. The training records show that , all maintenance personnel have been retrained regarding procedure compliance with the emphasis on "if you don't understand the procedure stop and get help " This was part of the previously identified problems with procedure compliance. Also, intersiews with i maintenance personnel indicate that the message has reached the working personnel.
PECo supervisors and managers are conducting monthly meetings to continually place j emphasis on the self-assessment process and to focus on organizational learning. This l meeting uses an open forum of collaborative learning with section and station personnel to j i - - -. - - -. - - - - -
_ _ . j-c ? ~t j-G a
i discuss areas of concern and to track and trend ongoing activities. The process includes I discussions of underlying causal factors, missing or ineffective barriers and adequacy of , independent and self-assessment. The meetings held to date, as reviewed and attended by the resident inspector, shows a positive approach to procedural compliance problems as well [ as a reasonable approach to correcting long standing procedure issues. The inspectors
confirmed that the second meeting provided a discussion of solutions to some of the concerns ! raised at the earlier meeting. The resident inspectors will continue to monitor PECo's i progress toward procedural compliance issues.
! Based on this inspection and a review of training records, supervisors and management
memos to employees and recent meetings attended by the resident inspector, the following . items are closed: 50-352/91-11-01, 50-352/92-03-01, 50-352/92-27-01.
. ! 3.0 MAINTENANCE IN PROGRESS (62703,92701,93702) The inspectors observed and reviewed maintenance activities in progress to verify that they i were conducted in accordance with approved procedures and in compliance with regulations, . codes, and standards. Specific areas examined were: use of approved procedures, QA/QC l involvement, management oversight, personnel safety, and radiological controls for worker ' protection.
3.1 High Pressure Coolant Injection Train 18 Month Inspection j
During this inspection the work in progress on the Unit 2 High Pressure Coolant Injection (HPCI) system for the 18 month inspection was observed. Maintenance procedure PMQ-056-038, Preventive Maintenance Procedure for HPCI Turbine 18 Month Inspection, was present and being used. The inspectors verified that the laser optics alignment instrument, used to align the train, was within the calibration due date. However, when the alignment instrument failed the technician stopped work to acquire another instrument.
I The job leader informed the foreman that the inspection procedure was not written to realign
! the HPCI train in the desired way, after it was found outside the alignment acceptance criteria. An action request (AR) was generated so that the alignment could be performed, under other currently existing procedures. The turbine group supervisor indicated that the 18
month inspection procedure would be reviewed and revised before it is performed again on ! either the Unit I or Unit 2 HPCI train.
l Though discussions with maintenance personnel, the inspectors found the technicians
knowledgeable of procedural and technical requirements relating to the work. The technical ' workers believed a nonconformance report (NCR) would be written for the out of alignment - condition, but that it was not their responsibility to write it. Plant management briefed the - inspectors on management's expectations with regard to procedures A-C-901, Control of-
- !
I $
\\ ! .% .s
Nonconformances and A-26, Plant Maintenance Work Process, and concluded that in this r case an NCR was not necessary since the condition was corrected under the work order that identified the unacceptable condition.
Long term corrective action will be to monitor vibration during the quarterly HPCI Pump, Valve and Flow' testing for abnormalities and use the Equipment Failure Trending process to - review and trend this condition. The system manager is assigned oversight to evaluate this issue for generic or long term implications. The inspectors concluded that declaring the alignment instrument unreliable, during the HPCI Train 18 Month Inspection, when unrealistic readings were appearing was a positive initiative. Procedures A-C-901 and A-26 adequately define and control the process for' ' corrective actions regarding failures and nonconformances, and corrective actions for the out of alignment condition were handled properly.
l 3.2 Emergency Service Water Valves HV-Oll-047 and HV-Oll-077 Rework i This work consisted of cutting out the existing carbon steel wedge guides and instalhng new-
stainless steel wedges while maintaining clearance between the wedge and wedge guides.. An
observation of the operation of the freeze seal required for this work activity and a discussion with the attendant contractor determined that the seal was installed and being maintained ' within the temperature band as necessitated by the procedure. The Quality Verification (QV) technician performing a die penetrant nondestructive test on HV-Oll-047 seemed knowledgeable, but did not have a procedure, QV plan, or a print showing HV-Oll-047. _ , Quality Assurance has no requirement to have procedures, QV plans, or drawings at the job site when doing this type of inspection.
A review of the work procedure and discussions with the foreman assigned the work order.
' found that temporary changes had to be incorporated into the procedures to properly do the job. The inspector found that the procedure, PMQ-500-115, Prevendve Maintenance for Velan Bolted Bonnet Gate Valve Rework (Lapping), Revision 3, had to be changed so that - HV-Oll-077 was included as one of the valves applicable to the procedure and there was confusion over the steps to disassemble the velan valves with handwheels or motors because
this valve and HV-011-047 are air operated valves. A temporary change was also written for l the repacking procedure, PMQ-500-020, Preventive Maintenance Procedure of Q and Non-Q
Listed Valves, Revision 16, for these valves, to use an approved thread sealant.
! The performance of work activities and tests such as the die penetrant nondestructive testmg on HV-011-047 without a written instruction and relying on memory and plant knowledge to - identify correct components is considered a weakness. PECo has an outstanding corrective , action request (A0000004, February 6,1993) involving both maintenance and QV where measurements were taken on the wrong pipe for freeze seal preparation during performance of work order R0461884. The inspectors concluded that the identified weakness is bemg
adequately addressed.
. ! >
i % i o
l 3.3-Disassembly and Rework of IIPCI Valve HV-055-2F001
! -! While work was being performed on HV-055-2F001, using work order (WO) R0460639, the j inspectors observed the maintenance and discussed the process and procedure with the ! ! technicians. The procedure, PMQ-500-005, Preventive Maintenance Procedure for Anchor-Darling and Velan Bolted Bonnet and Pressure Seal Gate Valve Repair (Lapping), Revision , I.
5, was present and being followed. Temporary changes were incorporated into this procedure to add HV-055-2F001 to applicable valves, correct procedure reference numbers, correct typing errors, and solve a yoke fastener torquing problem. The work was performed in a contaminated area and the housekeeping methods allowed contaminated clothing and ' trash to encroach on the clean areas, especially the step off pad. The poor housekeeping , practices observed are considered a weakness in the control of contamination. Plant ! management indicated that the poor housekeeping practices would be addressed.
! 3.4 Replacement of Leakoff Plugs and Retorque Packing for Residual Heat Removal ' Valve HV-051-2IT48A , The inspector attended the pre-job briefing where information was provided so that the l people bvolved with the work activity understood what was to be accomplished and how it would be done. Maintenance technicians performed the work in accordance with the written instructions including the recording of the replacement plugs heat treat documentation. The
Quality Verification Plan (QVP) that was given to the quality control representative was , incorrect, in that it incorrectly required verification of torque on the installed plugs. This
was reported to the quality control supervisor and a revised QVP was issued. A check of the torque wrench calibration and setting was made by the QV representative and independently verified by the NRC inspector. All the signatures and steps required by this work order , were completed as required.
3.5 Control Rod Drive O-ring Replacement On Febmary 23,1993, the inspectors observed the replacement of a control rod drive (CRD) , o-ring. The replacement was necessary due to excessive leakage observed for the CRD.
' The work was performed using procedure M-C-747-011, Control Rod Drive Exchange Using NES Machine, Revision 3. In order to perform the work, two maintenance workers and one
health physics technician needed to be under the reactor vessel. Because of the potential for internal exposure, the workers wore respiratory protection. At one point, the workers j needed operators to complete actions in the control room. The workers were unable to _; coordinate the required task with operators due to a shift tumover taking place at that time.
In this instance, the three individuals waited for more than one half hour for operations l support. Although the personnel involved relocated to a low dose area, they remained in the i same general area under the vessel.
! ! !
- _.
. __ - _.
. _ -. - __ _ .- . _ , ! ! ' l
'
l ! Additionally, during performance of the procedure, the inspectors noted that various steps of the procedure were crossed out, without any supporting documentation, such as a Temporary l Change Control Form. Licensee management indicated that the practice of crossing out the ' procedure steps was not in accordance with practices at Limerick, but was in accordance with practices at Peach Bottom. Since the same workers do work at both Limerick and Peach Bottom, there was confusion in this instance due to a different way of doing business
' at the two plants. In order to track and correct this, a Quality Evaluation of a deviation was j initiated.
! i i During the maintenance, the inspectors found the workers to be knowledgeable, and observed. j good supervisory and management oversight of the activities, and good support and coverage l by health physics. However, the inspectors observed poor coordination of the activities with i operations personnel, which resulted in personnel receiving unnecessary dose, a poor 'l ALARA practice. The weakness identified regarding the crossing out of certain procedural , steps was found to be properly documented for corrective actions.
! i 3.6 Unit 2 Reactor Mode Switch Maintenance j , i ~ On January 3,1993, during the Unit 2 shutdown, the reactor operator experienced some
' difficulty operating the reactor mode switch when placing the switch in the shutdown position. The mode switch apparently was hard to turn. An AR was written and rework of [ the switch was scheduled for the Unit 2 refueling outage. On February 12, 1993, work was . conducted on the mode switch in accordance with a maintenance work instruction prepared using a General Electric (GE) Service Information Letter (SIL) issued in September 1989.
The GE SIL informed licensees of reported failures that involved incomplete transfers from ! one lock handle switch position to another. The failures were a result of one or both of the ' , screws that secure the handle lever casting to the lock cylinder, loosening inside the lock . ' cylinder, preventing the handle position transfer. To prevent this problem GE recommended removal of the screws from the rear of the lock cylinder / lever casting assembly and _ l application of a drop of Loctite 242 or an equivalent sealant to each screw's threads. The ! screws should then be reinstalled using 8.5 inch-pounds of torque. During the performance of this work instruction the technicians found that the rose / escutcheon plate (attached to the lock cylinder / lever assembly) appeared to be worn. While this did not hinder the operation of the switch, it was decided that the part should be replaced. The work instruction was completed and the work package was returned to planning to order the new'part.
t . Following the work performed on February 12, using work order (WO) C0139631, the ! operations department staff reviewed the maintenance work package and initiated a work . activity on February 16,1993, that required ST-6-097-300-2, Reactor Mode Switch l Functional Test, be performed following the replacement of the worn part on the escutcheon
plate. This functional test was to serve as the post maintenance test and was scheduled to be completed by March 3,1993 (in order to provide time for the new part to be installed).
, , However, on February 24,1993, the shift crew was performing the reactor mode switch ! functional test, in preparation for another surveillance test, when step 6.3.2 of the procedure i i I
!
. ... $
. . . __ . ... _ _ _ . _ , i ? . i ! . ! .
! ! (ST-6-097-300-2) directed the operator to place the mode switch to the shutdown position.
_ The operator could not turn the key, which prevented him from unlocking and turning the ! mode switch. The mode switch was disassembled to determine the problem with the lock assembly. The cause of the problem was that Loctite, which was used during the work on February 12, had seeped into the locking cylinder and caused the tumblers to bind up.' _The - tumblers were subsequently cleaned and lubricated, and the lock functioned properly. A-successful functional test was performed following reassembly of the mode switch.
.;
Although the mode switch was initially declared inoperable on February 24, Plant f management reviewed the event and concluded that the mode switch was operable during this - l t time. The operability requirements for the reactor mode switch in operations condition 5 are i given by Technical Specification 3.9.1, reactor mode switch. This limiting condition for operation requires that the reactor mode switch be locked in the refuel or shutdown positions
during Mode 5 and, if locked in refuel, the refuel posidon interlocks must be operable during l control rod withdrawal or core alterations. In addition, it requires that the reactor be ! maintained in Mode 5 with fuel in the vessel and the vessel head removed. Plant ! management concluded that, in this instance, the reactor mode switch was locked in the f refuel position and all required refuel position interlocks were operable. During the time that l the switch handle was removed for inspection and repair, the actual electrical switch - ! remained in the refuel position and all required interlocks remained operable. The condition of having the handle removed is equivalent to having the handle installed and locked since the switch is unable to be moved to any other position, and therefore, the mode switch was operable.
The inspector reviewed the work orders, the event investigation form, and the GE SIL, and [ discussed the event with the maintenance and operations personnel involved. As a corrective ! " action for this event the maintenance staff was cautioned about the use of Loctite in this
application, and the staff intends to contact GE and request an alternative recommendation to l prevent the mode switch problem, possibly discontinuing the use of Loctite. The inspector
had no further questions concerning this event.
3.7 Conclusions .l
The maintenance and quality personnel were adequately following procedures and written instruction, but the quality of the written instmetions and procedures was a concern. The , workers were identifying problems during preparatory review of the procedure or during the l work activity. Although no instances were identified of work improperly performed during ! this inspection, the number of problems found and the reliance on the workers as the last line ! of defense to guard against these problems is considered a weakness. Key maintenance
procedures for Q equipment are being rewritten and reviewed by craftsmen to implement the Quality to the Line program, with a goal of completing 233 procedures by January 1,1995.
Procedural errors and enhancements identified and corrected using the Temporary Change i process and the Procedure Problem Identification System are being tracked along with l incorporation into the procedures.
i .; ' i , - ,
- - . - - - .-. . . . _. - '. i m
! .j .-
j , 4.0 CONTROL OF PARTS AND MATERIALS USED DURING TIIE ' j PERFORMANCE OF MAINTENANCE (62700) i ! PECo's procedures, guidelines, and methods used to control the quality of spare parts and i ' materials used during the performance of maintenance were reviewed. - The planning actions. associated with materials specified in three maintenance activities being~ prepared during the' -inspection were examined in detail. The repair of Q-listed materials maintained as spares l was reviewed as was the maintenance of equipment environmental qualifications. The
storage. of spare parts and the repair and replacement of components subject to American
- i
. Society of Mechanical Engineers (ASME) requirements was also reviewed.
l 4.1 Planning of Maintenance Activities-
The identification and specification of spare parts to be used in three maintenance activities - l _ in the planning process during the inspection were reviewed. The maintenance activities j reviewed, as well as findings related to each are identified as follows: ! a.
Work Order (WO) C0140919, Rework 6" Dia. HBC-194-2 Line.
. This WO was for the replacement of a section of diesel generator cooling system pipe in
which corrosion had been idendfied during performance of nondestructive examinations.
! The following were among the attributes identified in the.WO which related to materials : j specified for the repair.
j t The repair was identified as subject to compliance'with ASME Section XI .l e requirements.
j l Fabrication / Construction and Repair / Replacement codes were identified.
j
j e Ultrasonic examinations were specified for the existing' pipe before cutting and as-l baseline for the replacement pipe.
j l Acceptable pipe wall thickness was identified.
i e ! Controlled copies of drawings and specifications were verified to be used to plan the
work.- l ! ' Welding requirements were specified.
! Bolt torque requirements were specified.
j e-l'
An ASME replacement evaluation was performed.
e - Replacement pipe materials were specified.
1 i ! ! I l
e . . >
, ,
Post-maintenance testing was specified.
j
Testing of the removed pipe was specified.
! . The plamiing for this repair provided adequate controls to assure controlled materials were used to complete the repair.
b.
Action Request (AR) A 0721203, written to correct a deficiency in the 2A reactor water cleanup system recirculation pump motor control center (MCC).
. ! ' At the time of the inspection, the planning effort for this task had just been started. In accordance with procedure AG-45.6, Maintenance Work Planning, a walkdown of the work , area was performed by the planner and the inspector. This walkdown identified a discrepancy between the Equipment Trouble Tag (ETT) attached to the MCC and the AR ! written to initiate the WO to perform the repair. The AR indicated the motor breaker was [ faulty while the ETF indicated the C phase overload heater was at fault. The ETF had the l fault identified in the wrong field. Planner investigation showed the AR was incorrect.
- Following the determination of the faulty part, the planner, using controlled drawings, a Bill of Materials (BOM), and an Inventory Parts Catalog selected the correct replacement part.
. The quality classification and Environmental Qualification (EQ) requirements were also l identified. The correct part was physically verifini in the storeroom. Spare parts in the storeroom were observed to be neatly stored and each had its quality assurance tag attached.
The problem of inadequate information on ETTs had been previously identified by PECo.
Corrective action was taken to assure complete information is provided on ETTs. A FYI (formal communication method) was issued to make personnel aware of the type of information that should be documented when initiating an ETT. In this instance, the ETT ' was prepared by a contractor, and the walkdown specified by procedure was adequate to identify the error.
c.
WO C0141015, Replace Relay and Recalibrate as required.
As in the previous activities, planner actions, using controlled documents and physical verification, were adequate to identify that the correct part was specified for the maintenance.
During the review of this activity, it was noted the spare relays needed for this repair, Amerace EGPD-003, were stored under two stock codes in three separate locations. Under one stock code, the relays were identified as EQ qualified,' while in the other, they were not.
In one location, they were identified as having a shelf life, while in another, they had none.
i Investigation by the Procurement Engineering Group (PEG) showed all relays had been purchased as environmentally qualified. Based on previous application evaluations, some l were evaluated as not needing EQ requirements. Likewise, relays purchased in 1989 were I
E _ ': q
evaluated as having a shelf life (10 years), while those purchased in 1990 reflected a new evaluation indicating no shelf life is required.
If not identified sooner, the shelf life discrepancy would be corrected through the shelf life monitoring program. Also, a new procedure issued January 18,1993, P-C-II, Development Validation and Maintaining of PIMS Bill of Material (BOM), has provisions for consolidating.
duplicate stock code numbers.
Procedures require that all parts in the storeroom have quality assurance (QA) tags attached.
These tags indicate the material qualification and shelflife. QA tags for parts used during maintenance are maintained with the WO. This control appears to be adequate to assure that the deficiencies identified, although undesirable, do not have the potential to place into [ service unqualified parts.
lq 4.2 Bill of Materials . During the inspection on numerous occasions and during discussions with planners, planning foreman, and the planning supervisor, it was noted that the Bill of Materials (bOM) in the Plant Information Management System (PIMS) contained numerous errors. Also, a sampling 3' review undertaken by PEG identified that only 47 out of 100 sampled BOMs were correct.
Because of these known errors, the BOM, although an important component of PIMS, is not
considered controlled and is used for information only as an aid. Procedure.AG-45.6, . Maintenance Work Planning Guideline, Revision 2, Step 7.4.3, specifically requires l . verification of pans / materials. Because spare part applications are verified prior to use, the !
! plant management stated that errors in the BOM do not create a safety concern.
The BOM input into PIMS was not developed by plant personnel and the controls used in its development were not reviewed by the inspector. Currently, planning is providing PEG, the j group responsible for maintaining the BOM, with identified deficiencies and desired changes to the BOM. Also, PEG nas issued a new procedure P-C-II, Development, Validation, and j Maintenance of PIMS Bill of Material (BOM) to provide a method for PEG to improve the ' BOM. Three additional engineers have been retained for the purpose of correcting BOM discrepancies.
4.3 Environmental Qualification Requirements
I PECo's method for assuring that EQ requirements are maintained during maintenance was ; [ reviewed. Planners indicate that the Component Record.Lis (CRL) on PIMS is a means of ! determining component EQ requirements. An EQ repon is a backup to the CRL and
identifies all component EQ requirements.
' PECo has identified incorrect EQ classifications in the CRL. Two nonconfonnance reports.
, (NCR) have been written, one on February 22,1993, and one on February 24,1993,' to
resolve these errors. Currently, the PECo's equipment qualification branch of Chesterbrook { t ,
. _ _ _ .
.- . _ . - - . .-
' ,. i l - .
i ! Engineering is conducting a verification of the CRL to the EQ report. A number of i additional errors have been identified. The resolution of the NCRs will assure that no t conditions adverse to quality have resulted from these errors. In the interim, until the CRL is verified correct, the use of the EQ report by planners will assure that EQ requirements are
maintained.
! An additional error associated with EQ requirements was identified by plant personnel and an l NCR written on February 23,1993. This NCR identified certain components which were non-EQ at the beginning of plant life and, subsequently, upgraded to EQ. This upgrade was , not reflected in certain plant documentation.
! A licensee audit of the equipment qualification program was performed between July and ! September 1992. Certain strengths and deficiencies were noted. The use of NCRs to
identify and evaluate EQ deficiencies, as well as audits of the program, indicates steps are i being taken to maintain EQ requirements.
l 4.4 Repair of Q Components j i PECo's control for the repair of equipment removed kom service (power supplies, j instrument modules, etc.) was reviewed. The reviev. was intended to verify that controlled
parts are used during the repair, prior to considering the equipment usable spares. Plant management indicated repair of Q equipment is not performed on site. Q equipment removed from service is either s~tt ;o an approved vendor for repair or discarded. The , ir~;:ctsi had no further questions in this area.
4.5 Repair of Equipment Subject to ASME Requirements PECo's controls for the repair of components, subject to ASME requirements, is specified in j procedure A-80.4, ASME Repair and Replacement, Revision 1. This procedure identifies j responsibilities, and describes the procedure and documentation required to perform repairs
to ASME components. The requirements of this procedure were verified to have been ! implemented during the planning of WO C0140919, Rework 6" Dia. HBC-194-2 line.
! ! l 4.6 Conclusions ! . PECo has established adequate controls to assure that qualified parts and materials are used i during the performance of maintenance. When deficiencies are identified, steps are taken to t initiate corrective actions.
!
J I
-I
l ,
. -. . . - - .,
. .
5.0 MANAGEMENT MEETINGS 5.1 Exit Interviews The NRC inspectors discussed the issues in this report with PECo representatives throughout the inspection period, and summarized the findings at an exit meeting with the Limerick Generating Station Vice President, Mr. D. Helwig, on February 26,1993. No written inspection material was provided to licensee representatives during the inspection period.
i .
} ! i > t ! ! f l
i L ! t >
[ f l i ' ! i .{ .
, , '; . . . - --
ATTACHMENT A ., FEBRUARY 22, 1993 MEETING HANDOUT ~
LIMERICK GENERATING STATION UNITS 1 AND 2
NRC INSPECTION OF THE MAINTENANCE PROGRAM - FEBRUARY 22-26,1993
' ENTRANCE MEETING PRESENTATION D. R. HELWIG - VICE PRESIDENT FEBRUARY 22,1993 . > -, ' o OVERALL STRATEGY
o MAINTENANCE STRATEGY o WORK ORDER STATUS o CONCLUSIONS r , I . b .. . . . - . - .
.. . LIMERICK GENERATING STATION UNITS 1 AND'2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION , o OVERALL STRATEGY OBJECTIVE Maximize the benefit of PECo's ' substantial investment in nuclear power plants Meeting this objective requires aggressive approaches to safety, reliability, and , cost-effectiveness . e-
. . . e LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION o OVERALL STRATEGY OPERATING STRATEGY 2 year cycles Refueling Outages < 60 days'- Capacity Factor > 80% Rerate units to 105% of full power IMPLICATIONS Advanced fuel / core design's Outage management Reliability enhancements j Safety consciousness - - -_- - - - _ - - _ - - - - _ _ _-
.. . -- - - - - -- - - - - - - -- -___ --_-_ . . . LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION o MAINTENANCE STRATEGY MAINTENANCE EFFECTIVENESS ! Ensures reliability Controls down time Reduces costs improves safety < TECHNIQUES l Skills improvement / training Maintenance Technician Program Task-based training Procedure compliance Rad-worker skills Common Nuclear Procedures (CNPs) Continuous improvement _ _ _ _ _ - - _ _ - - _ _ _ _ - _
.. ' . .
LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF ! MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION
! . o MAINTENANCE STRATEGY TECHNIQUES - continued < Predictive maintenance Reliability Centered Maintenance (RCM) Component failure analysis
On-line maintenance Safety-based planning - ' Performance monitoring Productivity ! Skills improvement Management attention and involvement ' Measurements j Streamlining of work orders and procedures " Quality to the Line" Materials management .
_.
. ..
LIMERICK GENERATING STATION UNITS 1 AND.2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION . o MAINTENANCE STRATEGY . TECHNIQUES - continued Supervisory Training and Development
Supervisor selection process Maintenance / Instrumentation and Controls (l&C) personnel were earliest Supervisor . Development Academy graduates EPRI Center at Eddystone Plant PREDICTIVE MAINTENANCE Vibration monitoring Oil analysis Thermography ,
i P
- - - - - - - - - - - - 4, . LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION o MAINTENANCE STRATEGY RELIABILITY CENTERED MAINTENANCE Pilot program in 1990 Approximately 10% of systems are complete EPRI Pro.iect Leader in BWR industry Reliability enhancements Safety consciousness ' Good position to implement Maintenance Rule ! , . .. .- _ - _ _ - - - _ _
- - -- . LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION o MAINTENANCE STRATEGY FAILURE ANALYSIS Nuclear Plant Reliability Data System (NPRDS)/ Component Failure Analysis Report (CFAR) " Materials" analysis ON-LINE MAINTENANCE Planned " windows" for system work i Work prioritization Maintains system condition Allows timely corrective action Facilitates orderly planning 2 year schedule developed ~
. .. . LIMERICK GENERATING STATION ' UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION ' o MAINTENANCE STRATEGY ' SAFETY-BASED PLANNING Probabilistic Risk Assessment (PRA)/ Individual Plant Examination (IPE) - insights considered l Overall impact assessed Priority systems identified Dependencies identified Administrative Guideline (AG)-43, " Guideline for the Performance of System Outages," developed for operational periods EPRI " Outage Risk Assessment and Manac8 ment" (ORAM) Program technology used for outage periods Positioned well for Shutdown Risk Management and Maintenance Rule , i e
e.
- . L LIMERICK GENERATING STATION
UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM
ENTRANCE MEETING PRESENTATION
o MAINTENANCE STRATEGY PERFORMANCE MONITORING INPO goals and Performance Indicators (Pis) System " window" Pls Grading of system performamce Periodic review of overall results . WORK ORDER STATUS Backlog declining Pre-planned work increasing Meaningful Pls in use i f
- - - - - - - - - - - - - - - - - - - - - - - - - - - _ _ - .. . LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ENTRANCE MEETING PRESENTATION o CONCLUSIONS PECo HAS WELL DEVELOPED MAINTENANCE STRATEGY BEING AGGRESSIVELY IMPLEMENTED INDUSTRY LEADERSHIP IN MANY AREAS PERFORMAMCE IMPROVING IN ALL AREAS STRIVING FOR CONTINUOUS IMPROVEMENT ' HIGH DEGREE OF MANAGEMENT ATTENTION ' AND INVOLVEMENT INVOLVED, MOTIVATED WORKFORCE
MEANINGFUL MEASURES OF PROGRAM STATUS l ' AND PERFORMANCE REALISTIC APPRAISAL OF COMPETENCY AND STATUS ~ -- - _ - _ _ _ _ _ _ - _ _ _ - _ _ - _
- ~ ~
ATTACHMEfff B GHtb0T d E LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF THE MAINTENANCE PROGRAM FEBRUARY 22-26,'1993 ON-LINE MAINTENANCE: PROGRAM PRESENTATION D. R. HELWIG - VICE PRESIDENT FEBRUARY 22' 1993 sc o BACKGROUND o ADMINISTRATIVE GUIDELINE o 2 YEAR SCHEDULE o PRA OVERVIEW o CONCLUSIONS -. ..
. , t... .
- .
i LIMERICK GENERATING STATION UNITS 1 AND.2
NRC?lNSPECTION OF MAINTENANCE PROGRAM
i ON-LINE MAINTENANCE PROGRAM
I ' o BACKGROUND
PEACH BOTTOM ATOMIC STATION (PBAPS) - P RE-SHUTDOWN Only "must do" corrective maintenance (CM) performed ~on-line Large maintenance backlog Outages lengthening Unit reliability low System reliability low a
- - - - - - s .. .
. LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ON-LINE MAINTENANCE PROGRAM o BACKGROUND ESTABLISHED 13-WEEK ROLLING SCHEDULE Based on quarterly Surveillance Test (ST) cycle t Assessed impact on Probabilistic Risk Assessment (PRA) ' Reviewed industry guidance PBAPS - POST SHUTDOWN Maintenance backlog reduced Unit reliability improving Operational challenges reduced Outage length reduced System " window" outages often not necessary - _ - _ -___--_--_
t . . .
. LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ON-LINE MAINTENANCE PROGRAM o BACKGROUND LIMERICK GENERATING STATION (LGS) PRE-JULY 1992 Plan existed on paper -- Limited implementation Large/ growing maintenance backlog Long outages LGS - POST-JULY 1992 2 year plan developed /implementad Maintenance backlog declining Outage length reduced Plant safety well managed
. . . . ___-____ LI ' - . . LIMERICK GENERATING STATION I UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM I ON-LINE MAINTENANCE PROGRAM o ADMINISTRATIVE GUIDANCE (AG)-43, " GUIDANCE FOR THE PERFORMANCE OF SYSTEM OUTAGES" BASIS FOR MANAGING ON-LINE WORK ATTRIBUTES Address system importance Time and frequency in Technical Specifications (TS) ACTIONS minimized
PRA/ individual Plant Examination (IPE) l insights captured Plant configuration control Addresses system inter-relationships . __ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _. _ - - _ _ _
i .. .
, ! - LIMERICK GENERATING STATION UNITS 1 AND 2 ! NRC INSPECTION OF . MAINTENANCE PROGRAM ON-LINE MAINTENANCE PROGRAM . I o 2 YEAR SCHEDULE . PRE-OUTAGE PREPARATION AND ASSESSMENT ! OF SYSTEMS ADDRESSED ! MORE ADVANCED VERSION OF 13 WEEK SCHEDULE OPTIMlZED SCHEDULING OF WORK
DRIVES STATION FOCUS
WORK WEEK MANAGEMENT !
I ,
i
t . . .
LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ON-LINE MAINTENANCE PROGRAM i ) o PRA OVERVIEW l
I RISK WELL CONTROLLED , ! BENEFITS ALREADY DEMONSTRATED EMERGENCY SERVICE WATER (ESW) j SYSTEM - A CHALLENGE J ( - _ _ - _ - _ - _ - _ _ _ _ - _ _ _ _ _ _ _ - _ - - _ - I
,
... Limerick PRA Maintenance Impact
Units 1 & 2 , CDF ................................ .............. .................................................. ................................................... ................................................... ................................................. ................................................... .................................... ........... . ................................................. NRC Proposed Safety Goal ................................................. ................................................... ................................................... D 1992 Planned & Forced .................................................. ................................................... O W/O ESW ..................................................~ ............... ................................ ............................................... 1 E-5 ................................ .............. ........................... ... .... .,..... ............................. e a r.. a n. _. o..... . ...... ............................. . .. . . .. .. . ... .....-.. ...................................... - - . .... s ' . -.. ...... / .......... .... ........... - ...... ..... . N,/ Nx [ ..... '
J . ...... y ............ . 5x i, kb M I 1 E-6 Unit 1 Unit 2 - . . . ... . ... . . . . . ... .. , _..., _.. _. _. - _. _ _ _...
. ... . Limerick Maintenance Effects on CDF
' Units 1 & 2 1992 ~ , CDF- (e-6) 6.64 ~ E Total 5.64 - -- - - - ----- - -- -
- -----
- - -
- 6 Planned .. .. v.
l!
- ...
Forced ll 5 Test 4.64 '- -- -- --- -- : ................
i S Optional -: a
' l
- -
..: ~ I
- ' :
- ^;
- W/O ESW ~
- ^ l 3.64
':v'/ - - -- --- ---- - -- -- -
- f i
L '"
/ F 3- -{ >S - " " 2.64 " Unit 1 Unit 2- > - . .. - - - -. - - - _... - - - -. - -
- , ... -. .. . & System Unavailability Ratios ! PRA Systems 1992 l PLANNED FORCED 3 2.55 2.5 -- --
- -- -
-- -- - - - - - - - --
- - -- ----- --- - - --- -- -- - - -- - l l 1.5 -- - - - - - - - - - - - 1.3 8 - - - - -- ---- ------- - ---
_ _. _ _. _. _ _ _. _ _ _. _ _ _ _____ . _ _ _. _ _ _. _ _ _. _ _ _. _ _ _ _ _____ _ _. _ .75
-- '44 -- - - - - ' O.5
-
-
C D F* HOURS ** CDF* HOURS * * PBAPS LGS
- Ratio of impact of Planned to Forced maintenance unavailabilities on CDF
- Ratio of Planned to Forced maintenance system unavailable hours
_ _ _ _ _
$. .. . . . LIMERICK GENERATING STATION UNITS 1 AND 2 NRC INSPECTION OF MAINTENANCE PROGRAM ON-LINE MAINTENANCE PROGRAM , o CONCLUSIONS PECO EXPERIENCE INDICATES THAT ON-LINE MAINTENANCE IMPROVES UNIT AVAILABILITY.
SAFETY, AND COST-EFFECTIVENESS LGS HAS A WELL-CONCEIVED AND DEVELOPED PLAN FOR THE PERFORMANCE OF ON-LINE MAINTENANCE THAT CONSIDERS: f System and equipment safety significance Relationship to other systems , Effective planning and prioritization of work Measurements of performance j ' HIGH DEGREE OF MANAGEMENT ATTENTION AND INVOLVEMENT , - . . . . }}