IR 05000354/1989080
| ML20006E170 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/31/1990 |
| From: | Cheung L, Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20006E166 | List: |
| References | |
| 50-354-89-80, NUDOCS 9002220222 | |
| Download: ML20006E170 (47) | |
Text
,
,
.
,,
.,
-
.
F j
<
g
.
l}
h' +
.U.S. N'UCLEAR REGULATORY COMMISSION l
REGION I
l
'
'
Report No.
50-354/89-80 Docket:No.. 50-354
. License No.- NPF-57 Licensee:
Public Service Electric and Gas Company 80' Park Plaza - 17C Newark. New Jersey
,
. Facility.Name: Hope Creek Generating Station f
,.
.?
-
Inspection Conducted: October 2 - October 13, 1989-
.
Inspectors:
d(A4 k O
.reonard Cheunf, Senior Rpa cto'r Engineer, I
crat'e
,
Plant' Systems Section, @ DRS, Team Leader
!
W. Baunack, Senior Reactor Engineer, DRS-R. Fuhrmeister,' Limerick 2 Resident Inspector
!
.T. McLellan,. Material Engineer, NRR
C. Woodard, Reactor Engineer, DRS T. Fredette, Project Engineer, American System Engineer 1 :g Corporation
'
l/3/! D Approved by:
-
-
,
.
Jacque P. Durr, Chibf, Engineering Branch date Division of Reactor Safety l
.
[
,
,
Inspection Summary:
See Executive Summary
.
-
P
9002220222 900202 PDR ADOCK 05000354 G
PNU w
,,
"M*
W m
-
,m e
,
,
,
,
..,,,,
.
!
<
!
!
!
SUMMARY An in depth-team inspection of Hope Creek maintenance program and its implementation was performed on October 2-13, 1989. The inspection included a review of maintenance documents and observations of maintenance work in progress.
NRC Maintenance Inspection Guidance, dated September 1988, and Temporary Instruction 2515/97, dated September 22, 1989 were used for this inspection.
The inspection team evaluated three major areas:
(1) maintenance implementation; (2) management support of maintenance; and (3) overall plant performance as affected by maintenance. For each element, the inspectors evaluated both the
,
program and its effective implementation. The inspection results for each area
'
are summarized in the following paragraphs and are discussed in detail in Sections 3.0, 4.0, and 5.0 in the body of the report.
One weakness (insufficient resources to provide parts for day-to-day maintenance activities in a timely manner) and three unresolved items (improper method of diesel generator lubrication oil sampling, missing stud on diesel generator fuel tank vent piping flange and unsealed cable entries to diesel generator control panel) are listed in Appendixes 3 and.4, respectively.
In addition, a violation with 8 examples for failure to follow procedures was identified.
Other major observations from
'
this inspection are summarized below:
,
1.1 Maintenance implementation
'
'
The maintenance organization uses a well developed program for performing
.
corrective and preventive maintenance. The main strength of the organization
,
lies in its stable and well-trained staff, good supervision who take pride in their work and proven maintenance procedures.
Management is making provisions for increased around the clock maintenance coverage.
Further, the licensee initiated in 1987 a comprehensive modular training program. Additional work is required to fully implement the program, such as training aids.
Training for management and supervisors is also provided.
Well defined qualification criteria
,
and a qualification tracking program are in place.
Personnel are assigned only
"
tasks for which they are qualified. The licensee has established an effective control for contracted maintenance personnel using the Contractor Control Sheet to track contractor personnel and their training, indoctrination and qualification.
The licensee controls maintenance activities using a computer-based data management system.
Maintenance facilities were generally well controlled, eouipped and
'
maintained. The layout and utilization of these facilities are well planned, organized, and controlled throughout the plant to accommodate the maintenance activities and the movement of materials and equipment.
The administrative controls over procurement, receipt inspection, storage, and issuance of materials were adequate for ensuring that maintenance materials are available when needed and are issued properly for their intended use, with the exception of the weakness discussed above.
l
[
-,
w
.
.
i The licensee has a clear policy relating to fitness for duty. This policy has been promulgated to employee:. and contractors, and measures have been established to implement the policy.
Supervisors have received training in
>
the implementation of the program.
Employees are encouraged to participate in an assistance program if they suspect a drug or alcohol problem.
1.2 Management support of maintenance
,
Although plant management support for maintenance appeared strong and effect-ive, the. team could find no formal or documented policy or program directive, at the corporate or plant level which specifies management policies regarding the maintenance program and industry initiatives for improving the program, a
Nevertheless, the licensee's routine management oversight and feedback system is working well to assure safe and reliable plant operations. Worthy of particular note as a strength of the existing program is the Managed Maintenance Information
System (MMIS), which not on'ly has a wide variety of information, but is widely used by. plant personnel, is easily accessible, and can be easily manipulated.
However, there appears to be insufficient resources allocated for the procurement t
department and for parts support for day-to-day performance of routine maintenance, t
Over.72% of the backlog of routine ' maintenance is on hold, waiting for parts.
<
Over 39% of all routine maintenance activities scheduled are on hold waiting
.for parts.
Requisition of parts is slow, with some extreme cases taking as
'
long as 10 months. This is considered a weakness in the maintenance program.
'
Hope Creek has adequate engineering support to conduct maintenance activities'.
'
..
The onsite system engineering provides engineering dispositions for degraded
.
components, maintenance trending, maintenance procedure generation and revision.
!
Additional assistance is available from the corporate engineering adjacent to
.the Hope Creek site.
However, engineering support is needed to reduce the large
,
backlog of overdue maintenance procedures. The licensee management has made a commitment to eliminate this backlog by June 30, 1990,
1 1.3 Overall plant performance related to maintenance l
l.
The overall plant performance related to maintenance has been good and has an
'
improving. trend.
Plant availability has been high.
Numerous performance L
indicators are available for management to assess the status and effectiveness i
of maintenance. Management is committed to establishing a housekeeping program l-to ensure facility cleanliness.
Procedures have been developed to achieve this goal. The multiple examples of failure to follow procedures individually do
.
not pose a significant safety concern; however, collectively they represent a
!
possible attitudinal problem which warrants management's attention. Management's threshold for acceptability of housekeeping matters should be more clearly identified to station personnel.
In summary, with the exception of the violation, weaknesses and unresolved items, the licensee's maintenance program is being implemented adequately with reasonable management overview to achieve good plant availability.
.
-
- - - - -
m i
(.
- ~
,
l
!
L
- -
2.0 INTRODUCTION r
2.1 Background
!
The Nuclear Regulatory Commission considers the effective maintenance of equipment and components a major aspect of ensuring safe nuclear plant (
operations and has made this objective one of the NRC's highest priorities.
L To this end, the Commission issued a Policy Statement dated March 23, 1988, that states, "It is the objective of the Commission that all components,
,
systems, and structures of nuclear power plants be maintained so that plant l
equipment will perform its intended function when required.
To accomplish
'
this objective, each licensee should develop and implement a maintenance l
program which provides for the periodic evaluation, and prompt repair of plant components, systems, and structures to ensure their availability".
,
i
'
To ensure effective implementation of the Commission's maintenance policy, the i
NRC staff has undertaken a major program to inspect and evaluate the effective-
!
ness of licensee maintenance activities.
This inspection was one of a series
!
,
being performed by the NRC to evaluate the effectiveness of maintenance activities at licensed power reactors.
The inspection was conducted in accordance with
,
the guidance previded in NRC Temporary Instruction 2515/97 and the NRC Ma;ntenance
Inspection Guidance.
The temporary instruction includes a,," Maintenance Inspection
'
Tree" that identifies for inspection the major elements associated with effective l
plant maintenance.
!
2.2 Scope of Inspection l
The maintenance inspection at the Hope Creek Generating Station (HCGS) was initiated with a telephone conversation between the teau leader and the licensee's maintenance representative on September 6, 1989. During that i
telephone conversation, the scope of this inspection, including the function
,
of the mainunance inspection tree, was discussed. A list of requested
site-specific information was provided by the licensee in response to a letter dated August 22, 1989. A copy of the attachment to the August 22, 1989, letter l
1s included in this report as Appendix 1.
Public Service Electric and Gas
'
Company provided the requested information on September 12, 1989.
HCGS was shut down for a refueling outage in mid September 1989 and remained shutdown i
during this inspection.
From September 18 to September 29, 1989, the team reviewed the information submitted by the licensee.
The team conducted the onsite inspection at Hope i
Creek from October 2 to October 13, 1989, t
The onsite inspection focused on the observation of maintenance work in progress at the site and on licensee activities supporting this work,
.
including support provided by the engineering, training, and management i
organizations.
Maintenance activities selected for detailed review included equipment identified in the probabilistic risk assessment (PRA) for a similar plant as having the potential for contributing significantly to core damage
~
.
-..
--
-
_
,
.
.
accident sequences or to the reduction of the risk associated with plant operations. Other maintenance activities were selected for inspection based on the scope of work in progress during the inspection, recent failures of safety-related equipment, special interest items, and NRC inspection experience.
Daily meetings were held by the NRC team leader with plant management and maintenance supervision to summarize the inspection team findings and identify areas where additional information was required. On October 12, 1989, a special meeting was held to discuss the team's preliminary findings and the coloring of the inspection tree with the licensee's management. A summary of the inspection team's findings, including a presentation of an evaluated maintenance inspection tree, was discussed with licensee representatives including management, supervisors and engineers at the exit meeting on October 13, 1989 (see Appendix 2 for attendees).
2.3 The Maintenance Inspection Tree The inspection team's conclusions about the status of the plant's maintenance program are indicated by colors (green, yellow, red or blue) on the Maintenance Inspection Tree (Figure 1).
For parts 11 and III of the treo, the upper left portion of each block indicates how well the topic of the block is described and documented in the plant maintenance program, including adequscy of procedures. The lower right portion of each block indicates the team's ceelvsion as to the effectiveness of implementation of the topic covered by,
,
that Mod. Green indicates that the program is well documented or that the
,
program implementation is effective. However, even for blocks shaded green, some areas for improvement may be indicated in the report.
Yellow indicates a marginal but acceptable condition and re_d indicates the topic is missing or the intent of that portion of the tree is not being met by maintenance activities.
Blue indicates the item was not evaluated or could not be properly evaluated due to recent changes.
2.4 Inspection Findings The inspection team's findings and conclusions regarding the Hope Creek Generating Station site maintenance prograra and its traplementation are documented in Sections 3.0, 4.0 and 5.0 of this report.
(Note, the section numbers of this report do not correspond to the numbering sequence of the Maintenance InspectionTree).
The weaknesses and unresolved items are listed in Appendixes 3 and 4 respectively.
In addition, a violation with 8 examples for failure to follow procedures was identified and is discussed in paragraphs 3.2.2, 5.1.2.3, 5.1.2.6, 5.2.2.1 and 5.2.2.4 of thi s report.
I
j
,
o
3.0 OVERALL PLANT PERFORMANCE RELATED TO MAINTENANCE (Direct Measures)
3.1 Scope The objective of the inspection in this area was to assess overall plant
'
performance as related to maintenance by conducting plant system walkdowns, and direct inspections of completed work and maintenance activities in progress.
The overall level of personnel knowledge and management involvement in the final work product were also assessed by these direct measures.
3.2 Findinos 3.2.1 ilistorical Data The inspectors reviewed the historical data which reflects the effect of main-tenance on plant operation.
The data reviewed by the inspectors indicate that plant availability has been good with a year to date availability of 85.7% and a lifetime availability of 78.7%.
Reactor trips and forced outages attributed to maintenance have been low. A significant improvement in the number of Engineering Safety Feature (ESF) actuations which were attributed to maintenance was noted.
In 1986, the first year of operation, 22 ESF actuations were attributed to maintenance; in 1987, ten; in 1988, four; anf, in 1989 only two.
-
,
The licensee develops and maintains a variety of performance indicators to inform senior management about developing trends in maintenance activities. These indicators are readily available and posted at several locations throughout the facility. None of the indicators identified that maintenance had a significant
continuing negative impact on the facility's operation.
3.2.2 Plant Walkdown Inspection Detailed walkdowns were performed of various elevations of the reactor, turbine, and auxiliary buildings. The reactor building and service building were noted to be very clean and well maintained.
Other areas in the turbine building,
)
screen house and asphalt boiler house appeared not to receive the same level of attention as these areas.
Certain isolated deficiencies were noted such as poorly cleaned work areas, an inoperable PA speaker and several speakers with rags in them, a broken emergency light, cigarette butts in a non-smoking area, an instrument valve wheel missing, and a chain fall resting on wires in a cable
,
tray. The most frequently observed deficiency was damaged piping insulation lagging. Management should provide clear guidance for the care of insulation lagging, and the cleanliness of work areas while working or during breaks
.
between work.
During a tour of the facility, the inspectors observed that scaffolding in storage area 22 (102' elev. south side of the reactor) was leaning against a run of 3/8" stainless steel instrument tubing.
Further investigation revealed that this instrument tubing is the impulse lines of the "B" channel instruments for the Reactor Protection System and Nuclear Steam Supply Shutoff System.
This is in contrary to paragraph 5.8.1.2 of Station Procedure SA-AP.ZZ-023(Q)
.,
.
entitled scaffolding program, which requires the storage locations for dismantled scaffold components to be designated areas where no safety related equipment is imparted. This failure to follow the procedure is a violation of Technical Specifications, paragraph 6.8.1 which requires implementation of procedures (50-345/89-80-01).
When apprised of this finding, licensee personnel immediately removed the scaffolding from contact with the tubing run, and reverified the boundary of the storage area.
Station Procedure SA-AP.ZZ-031(Q), paragraph 5.4 specifies that weekly team housekeeping inspections be performed on a portion of the plant. This inspection team is to consist of representatives from operations, maintenance, technical, and ra:'ation protection / chemistry departments. A bargaining unit person should als oe assigned to the weekly inspection team.
However, the
.
inspectors identtiied that generally this weekly inspection has been performed by only a single individual rather than by a team as specified by the procedure.
The licensee indicated that the procedure would be revised to clearly reflect the manner in which the management desired to have weekly housekeeping inspections performed. The inspector has no further questions.
During a walkdown inspection of the Emergency Diesel Generator (EDG) units and their supporting systems, the inspectors observed that the vent /6verflow pipe on the top of the "B" EDG fuel oil storage tank was missing one of the bolting studs from the tank vent flanged connection.
The stud was laying on top of the.
From the degraded, corroded condition of the stud, it appeared that
.
the stud was not installed initially during construction.
Observation of the upper and lower flange mate-up indicated some misalignment in the bolting stud holes which may account for the fact that the stud had not been installed. The inspector determined that there is no immediate safety concern for this item because: 1) only 1 out of about 12 bolting studs is missing, and 2) the connection is for vent pipe which is a low pressure system. The licensee initiated an investigation and corrective action. However, this deficiency had noi been corrected at the conclusion of this inspection. This item is unresolved pending NRC review of the licensee's corrective action (50-354/89-80-03).
On October 3,1989, during a walkdown inspection, the inspectors observed a puddle of lubricating oil beside the skid of the "C" EDG unit. There was a tag on the E03 unit indicating that the oil leak had been identified before.
This oil leakage was not cleaned until several days after identified by the NRC.
This is contrary to licensee Station Procedure SA-AP.ZZ-031, paragraph 5.1.3.2 which requires any oil leak to be cleaned up immediately after identification.
This failure to follow a station procedure is a violation of Hope Creek Technical Specifications, paragraph 6.8.1 (50-354/89-80-04).
As part of the work control process, the licensee has in place an Equipment Malfunction Identification System (EMIS). The purpose of this system is to identify and tag malfunctioning equipment in the plant in order to:
(1) notify other plant personnel that a deficiency has been identified and that corrective action has been initiated and (2) eliminate the initiation of multiple work
......,
e e
t i
l L
f requests on the same malfunction.
During the inspection, an obviously damaged Limitorque valve motor was noted.
This damaged motor had been identified and a
work order had been written. However, no EHIS tag was attached as required by a station procedure. This is contrary to Administrative Procedure NA-AP.AA-0009(Q), " Work Control Process", paragraph 5.14 which specifies that an EMIS tag is to be attached to malfunctioning equipment to identify to others that the equipment has been identified for corrective action to be taken.
This failure to implement the requirements of a station procedure is in violation of l
the Hope Creek Technical Specifications, paragraph 6.8.1 (50-354/89-80-05).
During the facility walkdown a number of floor drains were noted which were partially plugged with dirt.
Additionally, on the 54 foot elevation of the turbine building a number of floor drains were identified which had expandable plugs installed.
Some of these plugs had " danger" tags attached, others did not. Also, a plug was noted to be laying loose on the floor.
The licensee's station procedure SA-AP ZZ-013(Q), " Control of Temporary Modifications" prescribes the method of controlling the installation of temporary modifications.
Paragraph 5.2 of this procedure specifies that a temporary modification request (TMR) be prepared prior to the installation of a temporary modification. The TMR is used to assure appropriate review and control of the temporary modifications.
The inspectors identified that no TMR had been prepared for these floor drain plugs.
This failure to follow the requirements of a station procedure is in violation of Hope Creek Technical Specifications paragraph 6.8.I'.'
(50-354/89-80-06).
'
'
3.3 Conclusion
.
The overall plant performance related to maintenance has been good and has an
I improving trend.
Plant availability has been high. Numerous performance I
indicators are available for management to assess the status and effectiveness of maintenance. Management is committed to establishing a housekeeping program
,
l to ensure facility cleanliness.
Procedures have been developed to achieve this goal. The multiple examples of failure to follow procedures individually do
not pose a significant safety concern; however, collectively they represent a possible attitudinal problem which warrants management's attention, Management's l
threshold for acceptability of housekeeping matters should be more clearly identified to station personnel.
l l
l
,
-
-.
-.
-
-
_ _ _
- -.. _,. _
.
l 4.0 MANAGEMENT SUPPORT OF MA1NTENANCE The objective of this part of the inspection was to assess plant and corporate management support of maintenance activities in the plant with respect to the establishment, implementation, and control of an effective maintenance program.
The major areas evaluated by the team were management's commitment to and involvement in the organization and administration, resource allocation, and technical support provided to the maintenance organization. The team evaluated the documented maintenance plan, self-assessment measures, resource allocation, i
definition of maintenance requirements, and accountability to provide a basis for its overall assessment.
4.1 Management Commitment and Involvement 4.1.1 Scope The objective of the inspection in this area was to evaluate corporate and plant management's commitment to and involvement in ensuring the adequacy of plant maintenance as indicated by (1) management's interest and participation in the assessment and improvement of the maintenance program, and (2)
manage ant's support and application of industry initiatives.
4.1.2 Findings The team evaluated these elements through discussions with plant staff, revia,ws.
of planned, in progress, and completed activities associated with the conduct
.
of plant maintenance; industry event communications; and the licensee's experience and data analysis of plant performance.
The licensee participates in the Nuclear Plant Reliability Data System (NPRDS),
which is an industry-wide system for tracking the performance of selected systems and components at nuclear power plants. The NPRDS maintains two types of data on plant systems and components:
engineering records and failure reports. The maintenance department has assigned a senior staff engineer to ensure that NPRDS data reporting requirements are satisfied for the HCGS.
Periodic reports are obtained from NPRDS comparing failure data for HCGS with that of the industry average. Any components which have a failure rate greater than a " significance factor" based on the industry average receive a detailed failure analysis to determine if some unique set of circumstances at Hope Creek are contributors.
In addition, the data is periodically reviewed to ensure that it is properly reported and characterized. An example of this is the change of the Bailey logic card reporting from " bistable" to " relay" category to more accurately reflect the actual plant conditions.
The licensee has conducted three self-assessments of maintenance using industry guidelines, and a fourth self-assessment based on the NRC maintenance working tree.
In each case, these assessments were conducted shortly before a formal third party assessment, as a tool to ensure the readiness of the plant for the assessment.
.. _ _ _ _ _
., -
.
Il The maintenance training program has recently been split up into a module based series of courses.
Each module or sub-module corresponds to a particular skill or set of skills necessary to perform a work activity. The program was fully accredited by INPO in February 1988. Station management participates in the planning and scheduling by input to the annual training schedule.
In addition, periodic reviews are performed by a maintenance training review group which includes the maintenance manager and/or maintenance engineer, and by a nuclear training oversight committee, which includes the general managers of both the Salem and Hope Creek plants. Training and qualification documentation has been incorporated into a computerized data base to aid the work group supervisors in the selection and assignment of personnel to perform work in the shops and the field.
Hard copy backup is maintained by the nuclear training department. A report on training is generated and submitted to the Vice President-Nuclear Operations every six months. The maintenance training review group identified a need for site management personnel to improve the frequency of their class-room visits, and worked out a plan to accomplish that goal.
The instructors at the nuclear training center periodically participate in plant maintenance activities (as supervisors during outages) to help remain current on the training needs and skill levels of plant personnel.
The maintenance data base currently resides on a main-frame computer at the corporate headquarterc in Newark.
It consists of a compilation of the plant systems, equipment manufacturer's recommendations, plant experierice and surveil-lances required by technical specifications. Work orders for periodic recurring tasks, such as preventive maintenance, are automatically generated and printe,d.
out by the computer. The data base also includes information on the tools,
.
parts and procedures necessary to perform the work which prints out on the work order.
Plant personnel have access to the data base and can select a number of different formats for data display. The system also keeps information from past work activities, which allows for quick reference to measurements and data taken, corrective maintenance performed and the results achieved. The information in the system is safeguarded by passwords and access codes, which restrict the ability to change information. This database, called the Managed Maintenance Information System (MMIS) also has the ability to interface with the parts (
control and radiation protection data bases.
The system is taken off-line every week to allow the memory to be transferred to magnetic tape for backup in the event of system problems. A further extension of the database includes the See-View system, and the plant model, which will be covered in more detail under the discussion of radiation protection initiatives.
This data base is being
" timed" and refined almost daily, based upon feedback from the technicians
,
l performing the actual maintenance work in the field.
Selected maintenance personnel have participated in several INP0 peer evaluations i
of maintenance at other facilities, as well as being members of a number of IEEE, NUMARC, and ASME Code working committees. The licensee is also participating in the BWR owner's group, the Nuclear Materials Management Exchange (addressing qualified parts availability issues), the Reactor Water Cleanup Pump Seal owner's
!
group (addressing longevity problems with those seals), and the MSIV owner's group (addressing local leek rate testing failure problems).
By and large, the management assessment of maintenance results from the weekly review of maintenance performance indicators. This review concentrates on the performance of the equipment in the plant.
The effectiveness of this process can be judged by the extremely small number of components exhibiting repetitive failures.
.-. - -
- - -
-
-.
>
.*
C
.
i
!
Plant aging issues have not been fully addressed at Hope Creek.
Currently, the main thrust of component aging work is centered on the resolution of equipment
,
i qualification questions. Upon the implementation of the reliability centered L
maintenance (RCM) program (expected to be completed in approximately 2 years),
plant aging issues will be accounted for in routine maintenance.
The licensee has instituted a process for evaluation of component replacement due to obsolesence.
This process includes engineering analysis, safety reviews, and designation of the replacement as either equipment specific, or generically applicable throughout the plant.
4.1.3 Conclusion Although plant management support for maintenance appeared strong and effect-ive, the team could find no formal or documented policy or program directive,
'
at the corporate or plant level which specifies management policies regarding the maintenance program and industry initiatives for improving the program.
-
Nevertheless, the licensee's routine management oversight and feedback system is working well to assure safe and reliable plant operations. Worthy of particular note as a strength of the existing program is the MMIS, which not only has a wide variety of information, but is widely used by plant personnel, is easily accessible, and can be easily manipulated.
,
4.2 Management Organization and Administrative (Corporate and Plant)
'
4.2.1 Scope The inspection objective in this area was to assess the effectiveness of the organization and administration of the maintenance department and the main-tenance program, respectively.
The specific areas inspected to provide a
,
broader perspective of maintenance activities included:
the existence, avail-ability, and scope of a formal maintenance program; maintenance policy, goals, and objectives; allocation of resources; and identification and definition of maintenance requirements.
4.2.2 Findings Station administrative procedure, SA-AP.ZZ-002, " Station Organization and Operating Practices", specifies the functional makeup of the maintenance depart-ment.
This procedure, in an attachment, also delineates the accountability, responsibilities, and qualification requirements of assigned personnel. The objectives of the maintenance program and maintenance department are laid out in a mainten.ince department administrative procedure, MD-AP.ZZ-002, " Maintenance Department Organization and Responsibilities".
This procedure also defines the
)
responsibilities of the functional groups within the department.
Station procedure SA-AP.ZZ-010. " Station Preventive Maintenance Program", defines the criteria to be used for determining preventive maintenance requirements and makes requirements mandatory for systems designated as Q (nuclear safety related), F (fire protection)
and R (containing radioactive fluids). This procedure also implements the
'
recurring task function of the MMIS, which will automatically schedule periodic preventive maintenance, print out work orders, and provide lists of overdue PM tasks to station management.
Corrective maintenance is conducted in accordance
.
.
t
!
[
t
i with nuclear department administrative procedure NA-AP.ZZ-009, " Work Control Process", and maintenance department administrative procedure MD-AP.ZZ-009,
" Control of Station Maintenance". The maintenance staff is tasked with the
!
responsibility to prepare reports for management to allow for evaluation of the
,
maintenance backlog and trends. The parameters for trending are identified by i
the maintenance engineer, who also reviews reports of work status to evaluate
adequacy of personnel and resources. The maintenance engineer has approval
'
authority for deferral of work if constrained by plant conditions or manpower
'
availability. Allocation of personnel to specific work activities is the
!
responsibility of the first-line supervisors. Among the indicators tracked for
'
evaluation by management is the backlog of work orders which have been delayed
for work for more than 90 days. At the time of the inspection, the most recent status report showed 108 work orders in this category, of which 78 were not available for work due to lack of parts.
The team reviewed the printout of
.
routine (non-outage) work orders scheduled to have started but not currently
[
in progress, and determined that of 229 in that category, 90 are waiting for
parts. The lack of parts support for routine maintenance activities is a weakness in the licensee's maintenance program.
From this same computer l
generated printout, the team found that purchase orders to obtain needed parts i
were, in several cases, not issued for 10 months after the need for the parts i
was identified.
!
Plant management meets daily to discuss issues related to the operation of the f
~
unit. The prearranged agenda varies from day to day during a week, but remains
,
consistent from week to week.
Included in these discussions are maintenance i
performance indicators and work status.
At this time, senior plant managers have the opportunity to review overdue work, reerder priorities, assess
effectiveness of the program, and identify work which can only be performed
,
during an outage of the system or plant.
These meetings appear to be effective and provide for timely identification and resolution of adverse trends except i
for the parts availability discussed above.
The licensee has developed a process for the evaluation of replacement components.
e l
The process was guided, at the time of the inspection, by system engineering procedures DE-Ap.ZZ-0027, " Determination of Equivalent Replacement", and
t SE-Ap.ZZ-100, " Component Changeout Design Change Process".
This process can be initiated by a number of factors, including: nonavailability of parts due to obsolescence, vendor letters recommending equipment not be used in particular applications, 10 CFR 21 reports and poor operating history / experience.
- l An assessment is performed by procurement engineering to determine the original design conditions, alternate sources of supply, and alternate com-ponents for use.
If an equivalent item can be found, a recommendation for
'
change will be made.
If an equivalent can not be found, the technical depart-i
.
ment will be notified and requested to investigate a design change.
If a
"
l replacement can be found which is the same in form, fit and function, the process is relatively simple, requiring a safety evaluation and a determination if the replacement is usable across-the-board on a generic basis, and if not, what limits and constraints must be placed on the replacement.
i l
i
.
-
e
.
If drawing changes are required, procedure SE-AP.ZZ-008, " Minor Design Change",
governs. This process was scheduled to be superseded shortly after the conclusion of the inspection by a new nuclear department key procedure, ND-AP.ZZ-0008,
" Administrative Control of Design Configuration Change". This procedure will implement a similar process for both Hope Creek and Salem plants. The new process, however, breaks the changes down into several discrete types.
Since the required change documents are specific to each type, several workbooks have been assembled which contain all required forms and instructions for completion.
A flow-chart is provided in the procedure to guide personnel in the selection of the appropriate workbook.
The reliability centered maintenance program has been formulated for Hope Creek, although, it has not yet been implemented. When implemented, it will provide more formal means of addressing plant aging issues, and the decision processes relating to maintaining, upgrading, or replacing equipment.
The reliability centered maintenance program is more fully addressed in section 4.3.2.2.
4.2.3 Conclusions The organization and administrative procedures of the maintenance departm6nt provide good control and documentation of maintenance work.
The apparent lack of corporate directives and policy does not seem to adversly affect the conduct of work in the plant.
The MMIS was particularly noteworthy as a" strength at Hope Creek.
It is a collection of well interfaced databases, widely used by station personnel to provide effective planning, scheduling, and coordinatioq
.
of work activities, and provides an excellent base for parts support.
The
.
planners and schedulers do an excellent job of assembling necessary documents for work packages and coordinating support functions. Management oversight and review of maintenance activities are timely and effective.
The identification of maintenance requirements and changes, thereto, are well documented and effectively implemented with the following exception.
Over 72% of the backlog of routine maintenance is on hold, waiting for parts.
Over 39% of all routine maintenance activities scheduled are on hold waiting for parts.
Requisition of parts is slow, with some extreme cases taking as long as 10 months. This is considered a weakness in the maintenance program.
4.3 Technical Support 4.3.1 Scope The objective of this inspection area was to evaluate the extent of technical support, including quality assurance (QA) and radiological control. The following areas were reviewed.
Engineering support
The role of pRA in the maintenance process
The role of quality control
!
.i (
o l
l I
l
I l
t
Integration of radiological conh ols into the maintenance process i
i Safety review of maintenance activities
i Integration of regulatory documents into the maintenance process
'
4.3.2 Findings 4.3.2.1 Engineerino Support
!
!
The licensee has two separate engineering organizations to provide support to plant maintenance and plant modifications, the onsite systems and the offsite i
corporate engineering groups. Systems engineering consists of six groups:
the reactor & plant performance, electrical engineering, instrumentation and control, i
nuclear steam supply systems, balance of plant system, and administration and j
planning. Their responsibilities in the maintenancs area include:
engineering dispositions for degraded components, root cause analyses, determination of corrective actions, maintenance trending, preparati.on and periodic review of j
maintenance procedures, and maintaining a master surveillance program for
'
technical speelfication surveillances.
Corpor, ate engineering is responsible for major plant modificatiens, including 10 CFR 50 39 reviews.
In addition, an equipment qualification (EQ) engineer permanently stationed at the Hope Creek site is provided by corporate engineering to coordinate all EQ rElated require-
'
ments into the plant maintenance activities.
This is accomplished through the EQ maintenance and surveillance information sheets (EQMSIS) prepared by corpo, rate engineering.
.
4.3.2.2 Role of pRA in the Maintenance Process i
At this time, the PRA for HCGS has not been completed. Completion of the
)
Level I PRA is scheduled for late December 1989.
l The risk concept is currently embodied in the planning and prioritization of maintenance work by use of the station technical specifications. The highest priority for work orders is assigned to work performed to prevent or mitigate
'
,
the consequences of an accident, prevent the release of radioactive material to the environment, or to protect human life and/or property.
The reliability centered maintenance program is currently being developed for I
HCGS and full implementation is expected in approximately 2 years. This program-will prioritize work based on a weighting factor which will include core damage frequency of plant functions the component affects.
Personnel ar? currently onsite, as a part of engineering, working on the development of equ1pn.ent significance factors.
The licensee has developed a reliability centered maintenance (RCM) method-ology. The goal of RCM is to set a required reliability target for a specific function and associated components, and then adjust maintenance tasks and frequencies to achieve that reliability goal.
Plant life extension will also
!
be used as an input for the selection of preventive maintenance tasks.
System tests and performance tests will be used to verify the ability to perform an accident prevention or mitigation function.
.
.
-
-
-.
i l
!
,
o I
p,
l
!
l i
Preliminary prioritization efforts have resulted in categorizing components
!
into 3 groups:
group 1 - safety systems and non-safety systems which could
!
-
affect safety systems; group 2 power production systems; and group 3 - systems
.
.
for wh!ch commitments have been made, even though no direct effects may accrue (
(IEEE or ASME Codes, ANSI standards, vendor warranties, etc.). The RCM database i
,
will include the historical sequence of design changes in order to allow evaluation of their effects.
l
!
4.3.2.3 Role of Quality control Quality Control has established requirements for the inspection of maintenance
!
u activities including the establishment of hold points, documentation of findings
'
and the certification of inspectors.
l In order to increase inspections where they are of the most benefit, the licensee
-
has removed many inspection hold points from station maintenance procedures and
!
increased the number of hold points in design change packages, which are primarily
implemented by contractors. QA surveillance of maintenance activities is
!
controlled by a procedure which specifies the planning, scheduling, performance, l
and documentation of surveillance activities. The inspectors reviewed logs of completed inspection hold points and surveillance activities to verify compliance with QA procedure requirements. An audit of maintenance activities is required
,
to be performed once each 24 month period.
The inspector reviewsd the results
'
of an audit of the maintenance department performed during June 1989, and the
'
responses to the audit findings; no defictiencies were identified.
,
,
.
QA procedures specify the documentation and resolution of identified quality
'
deficiencies.
Resolutions to identified deficiencies were verified to have
!
been accomplished.
l Station QA publishes a semi-annual trend report of QA surveillance reports.
I l
During the period from January to June 1989, a total of 230 surveillances were performed on Hope Creek plant activities, 85.2% were satisfactory and 14.8%
unsatisfactory. The deficient areas were identified by cause code. The most
,
common cause (39.2 percent) of unsatisfactory surveillances was " procedure not
followed".
Sixty-eight of the 230 surveillances were performed on the maintenance department with 96.8% being satisfactory.
4.3.2.4 Integration of Radiological Control into the Maintenance Process l
A radiation protection supervisor has been assigned to the planning section for several years.
This individual coordinates the assignment of radiation work
,
l permits (RWPs) to work orders and any necessary ALARA reviews. A radiation protection technician has recently been assigned to the planning section to assist. These personnel report to the radiation protection management, not i
the planning section, and are integrated into the information flow in planning.
They share desk and work space with the planners in order to be readily
'
.
available.
The radiation protection planner monitors work order status and I
performs daily review of work orders which require an RWP.
>
--
..
o
,
.
In order to aid in the correct characterization of work orders, the radiation protection planner has provided all planning section personnel with system lists highlighted to show those which contain contaminated fluids. When work order planning is completed and a work order number has been assigned, the radiation protection planner calls it up for review. The radiation protection planner will consult survey maps of the area to determine radiological conditions, protective clothing requirements, and 4.1y special hazards or needs.
!
To aid this review, the radiation protection and chemistry department acquired I
the plant model, and a computer controlled video-disc system known as "See-View".
'
The plant model allows both planners and workers to lucate components within i
the plant before going out into the radiation areas.
This will aid in deter-mining working space, ease of access, and need for scaffolding, as well as
'
placement of shielding if needed for the job.
The "See-View" system consists of a series of color slides taken throughout the plant which are coded by room, location within the room, and direction of view.
This allows planners and
!
workers to look at components in radiation areas and high radiation areas
'
without making an entry. The computer control system includes a graphics package permitting symbols and labels to be superimposed on the video image, i
This enables workers to positively identify components, reducing the need to search for them, and thus time spent in radiation areas is minimized. A video
-
processor / printer connected to the system permits printing a picture of the
'
video display, complete with markers and labels.
There is work in progress to upgrade this system with more photographs and a color printer.
'
The radiation protection planner has access to both the MMIS and the personne'l
.
radiological exposure monitoring system (PREMS).
Data can be readily exchanged
'
between the two systems, allowing easy assignment of work orders to existing RWPs if appropriate, or generation of a new RWP when required. Appropriate protective clothing requirements are entered and an estimated dose is entered, based upon work area radiation levels and expected work time in the area.
Additional radiation protection work standards are included if deemed appro-i priate.
If the dose estimate exceeds 1 person-rem, a pre-job ALARA review is
,
performed.
In addition, the radiation protection planner can code the RWP to i
require an ALARA review below these levels if it is felt that a dose savings
'
can be achieved.
If the dose estimate exceeds 10 person-rems a pre-job review meeting must be conducted and a pre-job briefing checklist is generated and submitted to the radiation protection managtr for review.
- RWPs requiring pre-job briefings by ALARA supervisor are placed in blue folders to aid control point personnel in identifying requirements.
As personnel enter and exit the RCA, they are tracked in the PREMS computer system and accumulated dose is automatically updated.
The self reading dosimeters used are electronic
,
units with digital readouts and alarms, which the computer sets upon entry. On exit, the computer reads the dosimeter, rezeroes it, and updates the individuals dose history. Daily printouts of active RWPs, their estimated nanhours, estimated
dose, actual manhours, actual accumulated dose and percentage dose to percentage manhour ratio are obtained and reviewed by the ALARA supervisor.
If the actual dose or actual manhours exceed 125% of estimated, a review is initiated to determine why. Also, if the ratio of percentage dose to percentage manhours falls outside the range of 0.5 to 2.0, a review is initiated to determine why, since time and dose should be proportional.
.
--
- - - --
-
--
o e
During the current outage, personnel contaminations have been in excess of those anticipated. As a result, a personnel contamination recovery plan has been developed and implemented. Action > taken include radiation protection personnel monitoring of protective clothing removal, muslin wiping / mopping of clean areas at the beginning of each shift, with resurveys performed of any area where the muslin becomes contaminated.
In addition, each contaminated individual is interviewed to determine work area, route to and from, and those areas are rechecked to attempt to identify the source.
Personnel contaminations are tracked by RWP and work group.
Radiation protection personnel perform the heat stress evaluations at Hope Creek. The new wet bulb globe temperature machines recently purchased can be programmed with the type of protective clothing being used and will adjust the calculated stay times accordingly.
Radiation protection personnel periodically monitor all work in progress to ensure that appropriate protective clothing is being used by workers.
In the " hot" machine shop, plexiglass enclosures are erected around the machines to prevent the uncontrolled spread of chips and reduce the area requiring cleanup.
4.3.2.5 Safety Review of Maintenan'ce Activities The nuclear department safety program is implemented in accordance with the
" Safety Program Management Manual", Rev. O, " Safety Manual, Rev. 5 and specific procedures, e.g., SA-Ap.ZZ-025(Q), Rev. 6, " Station Fire Protection Program". Management safety activities are stressed in the development of the licensee's safety program because per the " Safety Program Management Manual" the fundamental principle is that safety is an integrated function of line management. Three examples of first-line supervisors' responsibilities are as follows:
(1) checks at the start of each shift for changes in operating procedures, practices and conditions noting facts related to safety which occurred during the last shift worked; (2) makes a daily inspection of assigned work area and takes innediate steps to correct unsafe or unsatisfactory conditions; and (3) conducts safety meetings for employees who report to him.
In addition to the managers of the nuclear department, certain industrial safety and health responsibilities have been delegated to an industrial safety and health staff. A sample of specific cctivities performed by the safety staff includes the following: (1) provide assistance to line management in interpretation of industrial safety and health requirements; (2) coordinate and provide specialized assistance to line management in their industrial safety and health training programs; and (3) perform independent program appraisals, inspection audits and observations to determine individual organizational and integrated program effectiveness.
The maintenance department meets monthly to discuss safety which includes past incidents within the industry, lessons learned and specific educational topics.
The training is coordinated to allow attendance by all shifts.
The inspectors attended a maintenance department safety training class in which the subject was fire safety and was conducted by one of the first-line supervisors.
It was well organized and attended by maintenance personnel, both craft and supervisor )
m x
e
!
l l
i
The inspectors toured the plant and found that safe industrial practices were
,
L generally being employed. However, during the walkdown, the inspectors observed a person performing a maintenance activity in a battery room without a full face shield (see paragraph 5.2.2.1 for more detail).
Also, a maintenance person i
was observed during installation of a synchro-check relay in an "A" diesel
)
generator control room panel performing drilling without proper eye protection
,
and the same person was observed not taking proper precautions for working in i
an energized panel.
4.3.2.6 Integration Of Regulatory Documents in the Maintenance Process Regulatory documents are processed in accordance with procedure SA-AP.ZZ-030(Q),
Rev. 2 " Station Response and Commitment Control Program".
Commitment control involves a three step process:
(1) the identification of items requiring formal
responses; (2) the preparation and approval of those responses; ar.d (3) the
tracking and closeout of commitments associated with the responses.
The identification of items requiring formal response is achieved through various administrative programs.
Examples of these items are NRC audit fin.iings, INPO audit findings and licensing issues.
In addition, other documents can be i
identified by department managers to be included in the formal evaluation process.
.
For regulatory documents, the station licensing representative reviews the i
documents and notifies the applicable department manager /designes of the required actions. Also, the representative enters the commitment into a J
database called " Action Tracking Task", which is part of the MMIS. When an
.
,
item is closed out, it is assigned a closing document (CD) number and this
.
.
'
number appears in the lef t-hand column of an administrative or maintenance l
procedure to indicate that the particular procedure step is necessary because l
of a requirement such as a regulatory document.
The inspectors requested status information with regards to NRC generic letter I
(GL) 88-01, "NRC Position on IGSCC in BWR Austentic Stainless Steel Piping".
The information provided by the database indicated that the licensee had
'
,
l responded to GL-88-01 and subsequent request for additional information.
In
.
l addition, the inspector reviewed the data for NRC Bulletin 89-02, " Stress l
Corrosion Cracking Of High-Hardness Type 410 Stainless Steel Internal Preloaded l
Bolting In Anchor Darling Model S350W Swing Check Valves Or Valves Of Similar l'
Design" and found that the bulletin is currently under review, and that it should be closed by approximately January 1992 (the bulletin close out date depends on the next refueling schedule and/or if the licensee has the type of valves described in the bulletin). The inspector also reviewed the licensee's
,
,
data on a letter from NUMARC, dated May 22, 1989, with an attached report by
,
i Babcock and Wilcox (B&W) on " Stress Corrosion Cracking of Type 410 Stainless Steel" and found, per the database, the B&W report is listed and is under review by the licensee.
-
,
-
.
a
.
!
to 4.3.3 Conclusion Hope Creek has adequate engineering support to conduct maintenance activities.
The onsite system engineering provides engineering dispositions for degraded components, maintenance trending, maintenance procedure generation and revision.
Additional assistance is available from the corporate engineering adjacent to the Hope Creek site. The area requiring improvement in engineering support is the reduction of the large backlog of overdue biannual reviews of maintenance procedures.
The licensee is completing the risk assessment (PRA) data which is being incorporated into the prioritization of maintenance activities.
Quality assurance activities are being conducted in accordance with established procedures.
Findings are being trended and provided to management for corrective actions.
Radiation protection measures are well integrated into the planning process for maintenance. The easy access to MMIS, and exchange of data between MMIS and PREMS is a significant contributor to the good working relationship between the radiation protection planner and the maintenance planning section. The integration of radiation protection personnel into the planning proces) ensures that proper health physics support is available in a timely fashion, This is a strength in the maintenance program.
The industrial safety review of maintenance activities is well documented and is strengthened by involvement of management from the Vice President-Nuclear through the first-line supervisors. Although two deficiencies of personnel safety practices were observed by the inspectors, the Hope Creek industrial safety program is adequately implemented.
The overall control of regulatory documents was considered to be effective.
The level of review was adequate and sufficient information was routinely provided to document the scope and level of review performed to close open items.
In addition, the use of a CD number to indicate a requirement as to why a particular step is required in a procedure is an excellent method to indicate the NRC regulatory documents are continually implemented as required.
!
,
i
.
.
i 5.0 MAINTENANCE IMPLEMENTATION i
The purpose of this part of the inspection was to determine the effectiveness i
of the established maintenance controls and, more importantly, the quality of
'
work performed.
The controls established in four areas were evaluated: work control (Section 5.1), plant maintenance organization (Section 5.2), maintenance
<
facilities equipment and materials controls (Section 5.3), and personnel control i
(Section 5.4).
The team evaluated the effectiveness through observation of work in progress and a review of completed work orders, procedures, and other
,
documentation associated with maintenance and training of maintenance personnel,
'
work in progress, tools in stock, spare parts, and held discussions with all i
levels of personnel.
i 5.1 Work Control 5.1.1 Scope The inspectors' objective in this area was to evaluate the effectiveness of
the maintenance work control process to ensure that plant safety, operability
.
and reliability are maintained.
The following areas were evaluated:
Observations and Review of Maintenance in Progress
)
Work Order Control
.
,
Equipment Records History
.
Work Planning and Scheduling
Work Prioritization and Backlog Control i
Maintenance Procedures
Review of Completed Work and Post-Maintenance Testing
5.1.2 Findings 5.1.2.1 Observations / Review of Maintenance in Progress The inspector observed work in progress on emergency diesel generator (EDG) "A" with regards to the 18 month surveillance and preventive maintenance (PM) and diesel engine overhaul (top overhaul of the cylinders). Maintenance procedures were in evidence and were being used. The inspector also checked the torque wrenches in use to insure that they were within the the calibration due date, lifting devices had a current inspection date, scaffolding was properly tagged and the fire doors had the proper documentation to allow them to remain open during maintenance activities.
,
e
.
The inspector also noted that although the work on the EDGs was contracted to the manufacturer, Colt Industries, the maintenance activities were conducted with the licensse procedures, the contractor's measuring and test equipment were calibrated by the licensee, the contractor was directly supervised by the licensee and the licensee's representative was visible in the EDG maintenance area.
In discussions with the licensee's and contractor's maintenance personnel, the inspector found them to be knowledgeable of procedural cnd technical requirements.
The inspectors also observed the replacement of the service water intake pump, IAP502.
The maintenance procedure was being used by the maintenance crew.
In addition, the inspectors checked the scaffolding for proper tagging, electrical devices for proper quarterly color coding, and lif ting devices for current inspection tags. All attributes inspected were within the licensee's procedures.
Discussions with the pump maintenance supervisor found him to be knowledgeable of procedural and technical requirements.
In addition, the inspectors also observed the following maintenance activities in the I&C and electrical areas:
Source Range Channel "B" Calibration
Rosemount Transmitter Calibration (Channel "A" Reactor Press, Main Steam
Flow)
'
'
Rosemount Transmitter Model 1153 Replacement
.
"A" Diesel Generator Instrument Preventive Maintenance
Installation of Design Change 282
"A" DG Control Modification
Recirculation Pump Trip 4170V Circuit Breakers 18 Month Preventive
Maintenance
Screen House 4160V Circuit Breaker 54 Month Preventive Maintenance A well organized work order package was in evidence for each activity and all support documentation (including drawings) was current.
Supervisor oversight of maintenance activities was excellent and there appeared to be a good working relationship between supervisors and technicians.
The technicians were well-trained and aware of equipment with known industry
" problems".
For example, there was immediate recognition of the need to replace the channel "A" reactor pressure Rosemount model 1153 pressure transmitter following a failed sensor calibration check. This transmitter exhibited classic symptoms of degraded response and calibration point drift.
The technicians are trained to recognize this ongoing industry problem with the Rosemount model 1153 device. The replacement of this device allowed many facets of the main-tenance process to be observed by the inspectors - EQ considerations, logistics, installation and retest, including time-response testing.
The evolution was well-coordinated and was undertaken to allow bench calibration of the new transmitter while the EQ data package portion of the work order was being assemble j a
o t
i
!
Throughout the review of maintenance activities only two concerns were
[
identified.
i
!
1)
While performing a bench calibration check of "A" EDG fuel filter pressure i
gauge, the technician was observed to be " mechanically agitating" the
!
gauge casing with a crescent wrench (for hysterisis considerations).
!
When brought to the attention of the supervisor and maintenance engineer, t
both agreed that this technique was incorrect and they would counsel i
.
technicians to use the preferred technique of tapping the gauge face
!
plate gently, f
2.) A personnel safety violation was observed during installation of "A" EDG
,
control panel synchro-check relay. Details of this concern are in t
section 4.3.2.5 of this report.
i 5.1.2.2 Work Order Control t
The licensee's method of work order control was reviewed and found to be effective.
Administrative procedure, NA-AP.ZZ-0009(Q) " Work Control process", is in place
'
to govern the entire work control process, including work identification and l
tagging, work package processing, appropriate documentation and review, work
'
performaace and close-out.
,,
Initiation of a work order (WO) is accomplished by any plant staff or management pe tonnel with a nuclear department work request (WR) and corresponding equipment
'
malfunction identification system (EMIS) tags.
The WR form was found to contain appropriate review blocks and adequate space for necessary written descriptions, as well as unique sequencing number.
The nuclear shift supervisor has written authority to initiate WO for emergency maintenance activities when WR processing cannot be accomplished.
Normal WR processing is done by the station planning department using the managed maintenance information system (MMIS) to generate work activity documents that comprise a WO.
The work activity sheets control i
each aspect of any maintenance evolution, including troubleshooting, repair and l
testing. All work activity sheets contain appropriate equipment information t
and classification, and identify the type of maintenance being performed. The
>
work activity sheets also contain spaces for work description, measuring and testing equipment used and cause of equipment failure.
The inspector determined that the work activity sheets were comprehensive and contained the necessary review blocks, and that the system was effective for processing and planning maintenance activities.
5.1.2.3 Equipment Records and History
-
,
The inspectors reviewed the method for maintaining equipment records.
The managed maintenance information system (MMIS), an on-line computer-based program that i
integrates the station master equipment list, equipment history, logistics support and work status for all equipment is the primary means of me,intaining equipment records and history.
This system is used by all plant personnel and is found to be very versatile as well as user-friendly.
This makes retrieval of completed work order summaries easy.
For example, the inspector requested a summary for
.
t
.
-
-
- -.
- - - - - -
. -
- - - - -
.
. -
....
.
- _ -
i
,
.
'
i
24
WO #890313168 (reset of channel "A" reactor pressure vessel high level).
The WO summary was printed out and examined and found to contain all pertinent data for the equipment. The summary printout was found to contain the maintenance
repair time that matched the WO hard-copy repair time.
The summary also included
)
all component information and classifications.
'
The MMIS is also used by system engineers in reviewing failure events at the component level. The system engineers analyze completed corrective maintenance j
work summaries to determine any action requirements and inputs to the station j
performance trending / monitoring program.
In reviewing completed work orders, one concern was identified, The work activity sheet requires a "cause of failure"
'
or "cause code" to be entered as part of the maintenance documentation, in i
accordance with NA-AP.AA-0009(Q), paragraph 5.4.8(g).
The inspector reviewed i
fifteen corrective maintenance work orders that had been completed and closed l
and found none that had a "cause code" entered.
This non-compliance with the procedure constitutes a violation of paragraph 6.8.1 of the technical specifi-cations which requires written procedures to be established and implemented for various plant activities (50-354/89-80-07).
I 5.1.2.4 Work planning and Schedulino
The inspectors reviewed various aspects of the work plannt,ng and scheduling
'
process in use by the licensee. The maintenance planning department is a key
component in the overall station maintenance process.
Station planners from I
each maintenance discipline process all non-emergency WRs to generate work j
order packages. A formal procedure, PL-WP.ZZ-001 " Planning and Scheduling of j
Work Orders", requires extensive research to be done for each work item.
This
!
research is accomplished through a " field verification" of the work area to determine required procedures, permits (including radiation work permits),
special equipment and material / parts to be used. The planner coordinates with various departments to clarify job requirements.
For example, the inspector observed first-hand interaction between the lead electrical planner and the system engineer during the development of work packages for the installation of modifications to provide temporary lighting during the plant outage.
Planners
also verify that a work order package contains up-to-date support documentation.
i MMIS is used to automatically obtain repair parts and generate the component i
data for the work order.
Each maintenance department discipline provides personnel to the planning
,
department to coordinate and update maintenance schedules.
Schedulers dist-ribute work activities among the maintenance supervisors and interface with the work control center (operations) to track work in progress.
Procedure PL-DD.ZZ-006 outlines and identifies related maintenance on major components
,
and systems to enchance the planning / scheduling department capability to
,
coordinate many activities around a single equipment or system outage. A schedule of " forced outage" activities is maintained during normal operation, and all planning / scheduling implementation is overseen by the station planning l
l-and scheduling engineer with emphasis on backlog control, attention to major maintenance evolutions and coordination with a separate " outage" manager to i
l ensure that maje. tasks receive appropriate attention from plant supervision.
.
,
o
>
,
5.1.2.5 Work Prioritization and Backing Control The licensee's prioritization process was reviewed and found to be adequate.
For operating cycle maintenance, a two level (A or B) priority system is used for emergency and technical specifications related maintenance activities. A four level priority system is used for all other corrective maintenance.
The licensee also addresses outage condition priorities and these are based on technical specifications requirements and the magnitude of the problem.
Priority determinations other than "A" or "B" are based on the judgement of operations supervision, planning and management discretion.
There did not appear to be a systematic approach to evaluations to determine which components or systems should be assigned a particular priority. Most corrective maintenance priorities are subject to change (downgrt.de or upgrade) based on the planners' and/or management's review.
The reasons for these priority change > are not documented and the implementation of priority changes is not uniform throughout the plant. As a consequence, there is no traceability in work order priorities.
Determination of actual priorities for maintenance activities is based on EQ, technical specifications and safety significence (both for NS$$ and BOP equipment).
Station planners are generally unaware of the impact that the plant probability risk assessments (PRA), which are currently in development, will have on the maintenance priority process.
The inclusion of PRA consideratio6s will also have a significant impact on the current priority system.
'
'
The licensee's backlog control and monitoring system was reviewed.
The
.
station planning / scheduling engineer is responsible for identifying and taking action on excessive backlog problems. During plant outages, a deferral system is established to control the number of open work items, categorize them based on operational impact, initial priority and safety / reliability considerations.
Essential activities deferred for logistics reasons were given an upgraded priority.
A review of the licensee's backlog measurements system revealed that only limited backlog data is maintained. The number of backlog manhours, emergency to non-emergency activity ratio or safety to non-safety related activity ratio are not accounted for. An accounting system for tracking predictive maintenance activities is being developed.
The backlog control system, with the exception of the backlog due to spare parts, appears to be adequate.
5.1.2.6 Maintenance Procedures The inspector reviewed the process for maintenance procedure development and implementation in use by the licensee. All maintenance procedures are written, reviewed and issued by the station system engineering staff utilizing procedural guidelines for both maintenance department and I&C department procedures.
The procedure writers in system engineering are augmented by contractors.
An effort is currently underway to consolidate procedure formats so that all maintenance
o
.
department procedures contain identical procedural headings (i.e., prerequisites, precautions, equipment required, etc.). A review of several procedures revealed that they were concise and documented essential requirements, including personnel qualifications, reference documents, equipment, and acceptance criteria.
Inspection hold points also are included in most procedures.
Guidelines for the preparation of maintenance procedures also contain instructions for the review and approval process for maintenance engineers, system engineers and the maintenance staff.
In addition, system engineers are consulted concerning equipment calibration setpoints.
The control of maintenance procedures is the responsibility of the technical document room (TDR).
Issuance of " working copies" from the TDR includes a control stamp instructing the user to verify the procedure's currency every seven days and to confirm its validity before use. Maintenance engineers (mechanical and control) keep the master copy of each maintenance procedure, which are not for use.
The inspectors examined the station procedure review process.
In accordance with procedure SA-AP.ZZ-032(Q) " Review and Approval of Station Procedures and Procedure Revisions", all Q, F and R type procedures are to be reviewed within a 24 month interval.
The examination disclosed that about,50% of approximately 300 mechanical maintenance procedures and 40% of the I&C and electrical main-tenance procedures were overdue for this biannual review, many by as much as ten months.
This constitutes a violation of paragraph 6.8.1 of the technical specifications which requires written procedures to be established, implemented, and maintained for various plant activities (50-354/89-80-08).
The inspectors determined that the change over in the procedure development process and the fact that most procedures became due for review at the same time contributed to the high backlog problem.
The licensee stated that they were in the process of hiring additional procedure writers, and that management has made a commitment to reduce this backlog to zero before the end of June, 1990.
5.1.2.7 Review of Completed Work and Post-Maintenance Testing The inspectors reviewed the work order closecut process utilized by the licensee.
The system for closeout is proceduralized and establishes requirements for superviso'ry review of work order packages before the packages are returned to the planning department.
Station planners enter the work order into plant history using the MMIS system and the work order data becomes easily retrievable.
Work order cover sheets and any maintenance procedure data sheets that are part of the package are segregated and kept as "hard-copy" in the maintenance department microfiche system.
The inspector reviewed several work order packages at random. The results indicated that all appropriate work order authorizations and system / equipment data are complete. Work performed was documented and in many cases referenced an enclosed procedure.
!
,
.
Post-maintenance testing, called retest by the licensee, is the responsibility of the maintenance planner in conjunction with system engineering and maintenance personnel using a procedural guideline, SA-AP.ZZ-050 " Retest Program".
For the work orders reviewed, post-maintenance testing was adequately documented, and the enclosed retest procedures in the work order package satisfied the post-maintenance testing requirements.
5.1.3 Conclusion The licensee has developed a functional work control program. The MMIS contributes immensely to the management and implementation process. The ability of station planners and schedulers to skillfully manipulate this system is considered a strength in the licensee's maintenance program.
Two deficiencies were identified in the work control area:
1) large backlog of maintenance procedures that were overdue for biannual review, and 2) "causes of failures" were not entered in the completed work package as required by the administrative procedure.
5.2 Plant Maintenance Organization 5.2.1 Scope
.
The inspection objective was to determine the effectiveness and extent of control exercised by the maintenance organization for: (a) maintenance activities, (b)
contract maintenance personnel, (c) deficiency identification and control, (d)
maintenance trending, and e) support interfaces.
5.2.2 Findings 5.2.2.1 Control of Plant Maintenance Activities The inspectors reviewed the licensee's plant maintenance organization, the maintenance and plant management administrative procedures which are used to direct and control maintenance, selected station maintenance procedures and work orders for the equipment inspected.
The inspectors found the maintenance organization'to be adequately staffed with experienced personnel and with the maintenance managers position directly reporting to the general manager. The procedures reviewed to control and implement maintenance were detailed, easily understood, and deemed to be adequate.
In addition, the inspectors observed work in progress in the mechanical, electrical, and instrumentation and control disciplines including interviews with various licensee staff and contractor personnel who were performing the maintenance activities. The team found that the maintenance activities closely followed the maintenance procedure steps.
Personnel conducting maintenance, when questior,ed, responded in a manner reflecting a good working knowledge of the mainterance being performed, the equipment and the procedure,
.
I
,
iU For mechanical maintenance, the inspectors observed the implementation of work 0;
procedures for the following activities:
Emergency diesel generator "A" diesel engine top overhaul of the
cylinders, and 18 month surveillance and PM.
Service water intake pump replacement.
- The inspectors review of maintenance documents used for these activities, in l
combination with interviews of maintenance personnel supervisors and contractors, indicates that administrative and work procedures are effectively implemented.
Maintenance personnel were knowledgeable about work procedures which applied to their activities and were able to demonstrate how specific procedures for which they had responsibility were being implemented.
The inspectors noted that mechanical maintenance personnel have the opportunity to exercise judgement on methods and techniques for implementing work procedures at a level appropriate for a specific activity. The inspectors observed the involvement of supervisory and management personnel during maintenance activities in progress which provided additional assurance that work procedures were properly implemented and that contractors were closely adhering to the maintenance program requirements. The inspectors also noted that the work crew tools, material and replacement parts were properly identified and consistent with specifications-in maintenance work documents.
'
In the electrical maintenance area, the inspectors observed maintenance work'
.
being performed on the following components:
Meggering of medium voltage (4160 Vac) switchgear for the "A" emergency
diesel generator Recirculation pump trip 4160V circuit breaker 18 month preventive
maintenance Screen house 4160V circuit breaker 54 month preventive maintenance
250 volt battery (200431)
Neutrel grounding transformer for "A" diesel generator (IAG400)
Generator end of "A" diesel generator
The maintenance on these electrical components was performed by the Hope Creek electrical maintenance staff. The inspectors observed the work as it progressed and interviewed the craftsmen and their supervisors. The work orders in use on the jobs were reviewed and discussed with both the crafts and supervisory personnel.
In all cases, the personnel on the job had a good working knowledge of the work and procedures. The completed portions of the work had been appropriately approved by the job supervisors.
Sampling inspection of completion work indicated the correct maintenance was performed in a professional manner, j
,
.
..
During a walkdown inspection of the EDG systems and equipment, a significant difference was observed in the electrical cable entries into the top of the EDG-control panels. The cable entries from the overhead cable trays into the top of the EDG control panels for DG units "B" and "C" were sealed whereas those for DG Units "A" and "D" were open. This was found to be contrary to the Bechtel Construction Specification E-1406-0, which requires that cable entries into control equipment be installed to provide for plugging or capping to avoid the entrance of water, concrete, or debris. The inspector confirmed that there is no overhead source of water or concrete to enter into the panels
- only dust and debris. The plant manager committed to the correction of this discrepancy.
This item is unresolved pending NRC review of the corrective action (50-354/89-80-09).
On October 11, 1989, the inspectors observed that a temporary differential pressure gage installed across the lube oil filter of the
'B' EDG for trouble-shooting which was completed on October 6, 1989, was still inplace.
No temporsry modification was administered for this gage. This it, contrary to Station Procedure SA-AP.ZZ-013(Q), " Control of Temporary Modifications", paragraph 5.1.2, which requires that modifications be made in accordance with an approved procedure and shall have administrative control transferred to this procedure if it must remain at the completion of the work activity, or if the work activity is stopr d e
for more than two shif ts (16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />).
This is a violation of Technical Specifi-cations, paragraph 6.8.1, which requires written procedures to be established; implemented and maintained for various plant activities (50-354/89-80-10).
'
The team examined the predictive maintenance program for the emergency diesel'
.
generator oil sampling and analysis.
Emergency diesel generator oil sampling /
analysis can provide meaningful predictive maintenance information by the detection and trending of oil contaminants and engine metal wear.
However, to be most meaningful, the oil samples must be taken from a running engine before any filtration. The inspectors determined that the licensee was performing EDG oli sampling for use in predictive maintenance by taking samples from a stopped DG downstream of the oil filters. The licensee concurred in the need to revise the oil sample point location and sampling procedures accordingly.
This is an unresolved item pending NRC review of the corrective actions (50-354/89-80-11).
The inspectors observed personnel performing weekly surveillance tests on battery 100431 in accordance with MD-SL.PJ-001, "250 Volt Weekly Battery Surveillance" This procedure checks the mechanical condition of the racks, connections, and cells, and checks specific gravities of the pilot cells, as well as pilot cell voltages, battery terminal voltage and charging current. The technicians were noted to be wearing safety glasses and rubber gloves while measuring pilot cell specific gravity and electrolyte temperature.
However, subsequent review of the procedure revealed a requirement for wearing a full face shield and acid-proof gloves while working with battery electrolyte.
This concern was identified to maintenance supervision, who took immediate corrective action to counsel the individuals involved on the 'importance of following precautions and utilizing specified safety equipment. This issue was discussed at the morning meeting in the shop the following day, and added to the required periodic training material.
All other activities associated with this work were conducted safely and properly as directed by the procedure.
.____-_ -__-_____- _ _ - _ -
-
,
.
The inspector observed portions of the preventive maintenance work conducted under work order 900124007, on the grounding transformer for the "A" CDG This PM involved insulation and winding resistance tests on the transformer. The technicians were using procedures MD-Gp.ZZ-012, " Electrical Component Megger Testing" and MD-PM.ZZ-008, " Preventive Maintenance Dry-Type Transformers" for instructions to perform the work. The technicians were also using the Bechtel construction drawings to determine primary and secondary connections, voltage ratings, and leads to be lifted for testing.
The inspector noted the presence of the first-line supervisor periodically checking on progress of the work, results of measurements taken, and their acceptability.
The inspectors also observed portions of the preventive maintenance performed on the generator end of the "A" EDG under work order 89030137. The PM involved checking the condition of the coils, rotor-stator air gap, collector rings, brush rigging, insulation resistance, and pedestal bearing insulation resistance.
Access to the work area was controlled per HC.MD-GP.ZZ-009, " Tool and Miscellaneous Items Accountability and Control", to prevent the introduction of potentially deleterious foreign objects into the generator. All work observed was conducted properly and in accordence with the appropriate procedures.
The inspectors reviewed the I&C maintenance process with rega.d to procedures, technical manual control, training, equipment control and plant configuration control. The inspector observed work performed by I&C techniciaris and conducted interviews with technicians, supervisors and the I&C maintenance engineer.
Technicians were knowledgeable of the procedure requirements and equipment.
.
.
Special programs have been implemented to address certain industry initiatives
.
such as Rosemount transmitter performance monitoring.
Supervisors appeared to have a good working relationship with maintenance personnel, are attentive to problems and recognize areas needing maintenance process improvement.
Evident throughout the review of I&C activities was the attention to procedures, use of vendor technical manuals and control of test equipment and qualified repair /
replacement parts. Accountability of equipment on all maintenance procedures, including surveillances, was excellent. Training is emphasized for all new personnel and supervisors are lobbying for an evaluation system to account for technicians' past I&C experience. Configuration control was done by maintenance procedures themselves.
Supervisor and QA hold points are integrated into all I&C procedures as well as independent verification checkoff points.
The needs for maintenance at Hope Creek are identified from either the planned and scheduled preventive maintenance programs which are based upon experience, vendor recommendations, industry experience and the unplanned corrective main-tenance which is based upon need. The ratio of Hope Creek preventive maintenance to corrective maintenance for the six months ending June 30, 1989 was approximately 50%.
.
,
.
,
,
>
5.2.2.2 Control of Contracted Maintenance
!
The team reviewed the licensee's method for controlling the maintenance activities accomplished by outside contractors.
During the second refueling outage, a large portion of the maintenance work was performed by outside contractors.
To accommodate this, the maintenance department undergoes an organizational restructuring so that all contractor organizations become extensions of the in place maintenance department, all contractor activities come under the ultimate cognizance of the station maintenance supervisors.
Selection of contractors is done by careful review of resumes.
In most cases, contractors are selected based on station experience and expertise with the
'
specific maintenance activity or equipment.
The control of contractor activities and indoctrination are accomplished by use of a contractor control sheet which
>
tracks the contractor employee's time onsite and the completion of various stages
'
of training and site indoctrination.
,
The contractor control sheet documents the qualification of each employee in accordance with ANSI 3.1, 1981 and procedure NA-AP.ZZ-0014(Q), " Training, Qualification and Certification".
In addition, tracking is done as the centractor employee completes station general employee training (GET), the contractor reading list (key need-to-know procedures and d,jrectives), job
,
specific indoctrination; and a station general manager's briefing on safety, attention to detail and accountability responsibilities.
Great care is taken to ensure that all contractors are aware of the station's commitment to good work practices and performance.
The contractor control sheet also provides status as to whether the contractor employees are governed by station procedures and station QA programs. During
the refueling outage, only one contractor was using their own authorized quality assurance procedures and QA program. All other contractors were subject to the station quality assurance (QA) and station maintenance procedures and associated
,
controls.
In any case, all contractor activities are subject to station QA
wrveillance monitoring.
I Quality assurance oversight of contractors was effective.
For example, two I
cases of contractors inadvertently bypassing QA hold points or procedures was
.
I detected and appropriately dispositioned by QA through the use of a deficiency l
report.
l 5.2.2.3 Deficiency Identification and Control The inspector reviewed the licensee's method of identifying, controlling, dispositioning and correcting deficiencies. A station "Nonconformance Program" is in place to oversee the processing of all deficiencies.
Plant personnel and contractors are made aware of the program and are monitored by station QA and system engineering in the reporting process. The deficiency reporting process incorporates various departmental and individual responsibilities, procedures for dispositioning and resolution, as well as
-
testing and inspections. ' A dedicated QA engineer was assigned during the outage to track and report all deficiency reports and their status for the outage duration, for ease of identification and resolution.
This ensured efficient and careful review prior to closeout of any deficiency reports.
.
- -.
.
-
.... -
- -
.
-
n
> a
.
l 5.2.2.4 Maintenance Trending Each of the plant systems is assigned to a system engineer whose functions include performance monitoring of the systems in accordance with Procedure SE-AP.ZZ-048(Z), entitled, " System Engineering Station Performance Monitoring".
The monitoring includes the routine periodic accumulation of the operational parameters for the systems and their equipments.
The data are recorded and compared to an established normal bandwidth for this data.
This is done as an aid in establishing predictive maintenance and maintenance trends.
The inspec'. ors reviewed the maintenance trending for the emergency diesel generators and the diesel fuel oil storage and transfer systems.
Each component and subsystem had its set of parameters to be monitored along with acceptance criteria. The trending data thus accumulated during the past year was reviewed including its means of presentation in the form of curves, graphs and charts which provided excellent visibility of the data and trends.
The inspectors determined that the licensee had made effective use of the trend data obtained on occasions including the identification of the need to replace the EDG oil filter differential pressure gage with a more accurate gage.
The gage was found to be inaccurate primarily due to lack of repeatability from run to run because of high hysterisis. This type of inaccuracy initially led to undue concerns of oil filter blockage.
The licensee has recently implemented a component trending and dsta analysis program for Rosemount model 1153 instrument transmitters in response to industry initiatives for problems identified in this transmitter model. The trending,
.
program is governed by procedure SE-PR.ZZ.001(Q) "Rosemount 1153 Transmitter
.
Trending and Data Analysis Program" and procedure IC-DD.ZZ-020(Q) "Rosemount j
1153 Transmitter Monitoring Program" and includes calibration data and noise
'
'
l analysis by a system engineer responsible for the implementation of this program.
Procedure IC-DD.ZZ-020(Q) paragraph 4.2 requires that the system engineer generate periodic status reports from transmitter test results. Contrary to i
the requirements of this procedure, no status reports had been generated. This is in violation of Hope Creek Technical Specifications, paragraph 6.8.1, which requires written procedures be established and implemented for various plant activities (50-354/89-80-02).
5.2.2.5 Support Interfaces The inspectors examined and reviewed the licensee's interfacing network between
,
the maintenance department and various support organizations.
Through the
,
l observation of in process maintenance activities, the inspectors determined
'
that several provisions were integrated into the overall maintenance program
,
that ensure inter-departmental communication.
l As the key implementation tool for the station maintenance department to
'
accomplish work, the work request to work order process provides a mechanism for information transfer among maintenance, operations, engineering and QA personnel. The maintenance planning department and MMIS system remain the focal point of these departments' input to specific maintenance activities.
The planning department provides liaison between maintenance and operations for scheduling and tracking of work activities; between engineering, QA and maintenance for post-maintenance testing activities using the station Retest Program; and between radiation protection and maintenance for the dispositioning of normal work orders.
l l
i
. -
-. - - -
- - -
..
-
.
'
i
,,
L In addition, the station ~nonconformance program provides a vehicle for resolving maintenance problems and ensures that maintenance, operations, engineering and J
QA war.k together for efficient resolution and closeout to any maintenance deficiencies.
5.2.3 Conclusions The maintenance organization had a well developed program for performing corrective and preventive maintenance. The main strength of the organization j
lies in its stable and well trained staff and in proven maintenance procedures.
The contracted work is supervised and monitored by the licensee in a satisfactory manner. The failure trending program under development is well conceived and should contribute significantly to the improvement in the predictive maintenance program.
The_ inspectors found Hope C.'eek to have a well functioning maintenance organization.
The licensee's interfacing network is adequately proceduralized as a result of the work process guidelines.
Personnel among the various departments exhibited
,
high morale, excellent activity coordination capability and efficient use of inter-departmental procedures. The'overall cooperative attitude of the various department pers:nnel in the interface network is considered a contributing strength in the licensee's maintenance organization.
5.3 Maintenance Facilities, Equipment and Materials Controls
'
'
5.3.1 Scope
.
The inspection objective was to assess the plant's maintenance facilities and controls over maintenance equipment, tools and materials to determine how well these activities support maintenance work. The following areas were evaluated during-this inspection:
Provision of Maintenance Facility and Equipment
Establishment of Materials Controls
Establishment of Maintenance Tool and Equipment Controls
Control and Calibration of Meter and Test Equipment
5.3.2 Findings 5. 3. 2.1'
Maintenance Facility and Equipment The inspectors conducted an extensive tour of the mainter.ance facilities to assess the extent to which the facility arrangement, layout and accessibility were conducive to efficient and effective maintenance operations. The inspectors noted the locations of the I&C, electrical and mechanical (hot and cold)
facilities wM ch included the machining and fabrication shops, tool room, and temporary shcps which are physically adjoined to and clustered around the reactor and turbine buildings in a manner that provides ready accesses to these facilities.
-
-
-
-
.- - -
-
-
.
_ _ _ _ _.
-.- - -
4.,
,
The mciatenance facilities are located to provide access tt the passage of personnel and material from the outside doors obviating trai. sport through the plant. The flow of personnel and material throughout the plant is well accommodated by efficient traffic patterns and the location of entrance and exit points to maintenance facilities.
The inspectors noted that the mechanical facility has its own controlled access point that is located between the hot and cold shops allowing both craft and supervisors ease of passage between the two shops.
This access' point is for maintenance personnel only and they must check in and out through the main radiation control access point at the beginning and end of the shift. The supervisors' offices are located between the two shops where work in progress can be observed through windows on three sides of the offices.
The inspectors walked through the reactor, diesel generator and turbine buildings to observe the temporary maintenance areas established to provide local support for specific maintenance and modification projects. The inspectors noted that the ample space allocated to all in plant maintenance areas permitted efficient work and avoided congestion.
The support organization (e.g., QA, HP, and fire protection) work areas were nearby or readily available by telephone or page system.
For example, fire protection is immediately available by phoning number 3333 or on line 5 of the page system which was set aside for emergency use only.
.
Training and mock-up facilities are available and well-equipped and meet the licensee's training goals and objectives. These facilities are used for both formal classroom, practical, and crew training. The majority of the " hands-on" or practical training and mock-ups are done with surplus equipment from the licensee's cancelled Hope Creek, Unit 2.
The licensee ut111zes the cancelled Hope Creek, Unit 2 areas for storage and laydown of equipment, thus, staging and laydown areas are more than sufficient in space and number.
Scaffolding is readily available and is installed by licensee crews. Also, the scaffolding is tagged to indicate whether it is safe to use and if safety belts are required.
Communications systems are available and arranged such that maintenance activities can be conducted without interfering with plant operations. " Earmark" radios for line of sight work come in head sets or belt packs with throat mikes as an option.
In addition, the crews use the plant's five line page system to communicate, and a telephone system is in the process of being installed in opposite stair wells at each elevation of the plant.
5.3.2.2 Establishment of Materials Controls For materials controls review, the inspectors reviewed the adequacy of administra-tive policies and procedures for implementing effective control of material (components, spare parts, consumables, etc.) used in maintenance, beginning with the material requisition and extending throughout the material installation or use process. The inspectors observed that adequate guidelines have been established for identifying and assigning necessary material specifications for use in maintenance applications. Adequate controls have been implemented for
_........ _ _
_ _ _ _.
'
,
.
r
(
identifying safety-related materials and for specifying the necessary special controls over procurement of safety-class material. The " Station Materials Procurement and Control Program" provides the necessary guideline to site groups who initiate material requisitions. The inspectors reviewed and/or observed the process of initial material requisition, through the corporate purchasing function, QA review, purchase approval, and final ordering. These procedures were adequately controlled and sufficiently well established to ensure that, in i
most cases, materials requisitioned for maintenance activities are processed L
far enough in advance of use to be available for their intended purposes.
However, a weakness was identified relating to a lack of parts support for
"
maintenance activities as noted in paragraph 4.2.2.
The inspectors noted that adequate guidelines have been developed for ensuring that proper material certificates are provided with material that arrives at the central receiving aree. The inspectors reviewed documentation of individual
[.
material history packages maintained on safety class items in receipt inspections.
All packages reviewed contained complete information and certifications to support material identification. The approved suppliers' list was also reviewed by the
.
inspectors.
The inspectors reviewed the computerized data base and spare parts data in the MMIS for tracking and site inventory. Minimum and maximum stocking levels are identified as well as current inventory on hand. Automatic reordering is initiated by the computer system when inventory levels become low. The MMIS system automatically prints an order request which is sent to purchasing and a
.
__
purchase order is then generated by purchasing. Observations of controls on the issuance of some material out of the stores indicate that inventoried material is released only to a specific work order number.
The inspectors examined the site storehouse stock areas and the offsite receiving area to evaluate the adequacy of these facilities in supporting the maintenance
_
effort. These facilities provide good physical security for all stored materials and a " Level B" storage environment for plant spare parts and consumable materials.
The inspectors observed the areas designated for flammable and explosive materials storage and determined that adequate controls were in effect to keep these materials segregated from the normal stock. The inspectors noted that positive controls have been implemented in the storage areas to maintain " qualified"
-
material physically separated from "non qualified" material by providing bin separators.
In addition, " qualified" material is adequately marked and physically identified by green tags. All material is identified by safety class in work packages and procurement documents which are verified to be consistent before any material is released from the storehouse. Nonconforming material is well segregated in the areas designated exclusively for receipt inspection. The inspectors examined the areas to ensure that receipt inspection QA requirements were adequately implemented and that documentation of the material history was maintained in a manner which provides complete traceability.
__
.,
-(_m Y
_ _.. _ _ _ _ _
g
-
r j
.c
,
5.3.7.3 Maintenance Tool and Equipment Control In the areas of maintenance tool and equipment control, the inspector toured plant areas to observe tools and equipment in use for various maintenance activities. Work procedures in use for the EDG "A" and a service water intake pump replacement were checked to ensure that the tools and equipment specified by.the procedure were in use.
The inspectors also verified that finished work was properly documented so that exact tool usage could be retraced at a later time if necessary.
In the case of the'EDG "A", the inspectors found that in Procedure HC.MD-CM.KJ-001(Q), Rev. 4, " Diesel Engine Overhaul" the " Equipment Required" section did not list torque wrenches as tools required for the activity.
The inspector also found that the torque wrench data (e.g., serial number, calibration due date and date calibrated) for steps 5.14.7 and 5.14.10 were not recorded until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after these steps were completed. However, the procedure does not specify the time sequence in which the mechanic records a torque wrench's, j
data in Attachment 1 of the procedure.
The inspectors discussed this concern
with the mechanical-maintenance supervisor and he stated that the procedure will be reviewed and revised as appropriate for these items. The inspectors i
had no further questions regarding this matter.
l The inspector also reviewed the procedure for " General Rigging Inspection and
'
Testing and toured the storage and equipment areas.
The lifting cables, straps i
and hoist are given periodic inspections for material condition." The inspection results are recorded on a check / data sheet and kept by Nuclear Site Services.
Also, the lifting equipment is tagged to maicate the inspection due date.
T,he.
craft personnel are required to perform a visual inspection of the lifting
'
.
equipment prior to making a lift. All unsafe rigging is placed in a " Removed i
From Service" storage area for disposition. Thus, unsafe rigging is segregated from the inservice rigging.
During plant walkdowns the inspector did not j
,
l identify any rigging that was out of its inspection period or any unsafe lifting devices.
'
l 5.3.2.4 Control and Calibration of Measuring and Test Equipment (M&TE)
{
!
The inspector toured the tool room areas where the mechanical, I&C, electrical, I
and site services M&TE equipment is stored and calibrated. Storage lockers and L
areas were well organized and suitable for protection of calibrated equipment.
l The M&TE issuance system is self-service, except for site services where the L
M&TE equipment is issued by a tool coordinator.
The inspector reviewed the mechanical maintenance's " Calibrated Tools and Instruments" to compare equipment l
specifications with equipment identified on the tool log, and found the tools 1-to be accounted for.
In discussions with the licensee, there is a proposed I
plan under review that would have the site services group assume responsibility for the issuance of all M&TE equipment.
l l
5.3.3 Conclusion The inspectors concluded that the maintenance facilities are well arranged, I
equipped, and maintained in a manner which supports tH efficient conduct of I
maintenance activities at Hope Creek.
Facility layout and space utilization l
l l
p
!
,<.
i
l for maintenance work were well planned and controlled, with the exception of
'
the seismic storage area at the 102 foot elevation in the reactor building, as L
discussed in paragraph 3.2.2.
The layout of the maintenance facilities promoted
,
'
the flow of personnel and equipment throughout the plant complex.
In the area of material control, the inspectors concluded that existing administrative policies and procedures provide adequate controls for specifying,
'
procuring, receipt inspection, and storing materials and equipment utilized for maintenance. Safety-related materials are adequately identified and controlled to ensure that such material is properly procured, stored, and issued for the i
intended use. The material tracking system in use is adequate for maintaining minimum stock levels and for properly accounting for all material received, stored and issued from the storehouse. However, a weakness was identified which resulted in a lack of parts support for maintenance activities noted in
!
paragraph 4.2.2.
The procurement program was observed to be adequately administered and implemented, with the foregoing exception, to ensure that materials used for maintenance activities are properly specified, obtained, and received to support maintenance work schedules.
In the area of tool and equipment control, the team concluded that tool and equipment identification, storage, and use were adequately contr511ed in maintenance activities although the issuance system is mainly self-service.
'
'
5.4 Personnel Control l
.
5.4.1 Scope The inspection objective in this area was to determine the extent to which personnel are trained and qualified to perform maintenance activities.
The team evaluated the following areas: a) staffing control, b) training, c)
testing and qualification, and d) current status. The team's evaluation was based on interviews, direct observations of the training facility and field activities, and reviews of documents and records.
'
5.4.2 Findings 5.4.2.1 Staffing Control l
Station procedures have been issued which describe the station organization, departmental responsibilities, overtime guidelines, the NRC enforcement policy and fitness for duty program. Up-to-date organization charts were available.
A separate chart has been prepared describing the supervisory responsibilities for major outage maintenance tasks.
Procedures contain position descriptions for management, supervisory, and professional-technical positions.
Craft job descriptions are contained in the union contract.
l
..
.........
','s d
A very low turnover rate is experienced by the maintenance department. Most personnel lost are due to promotions within the company. The low turnover is attributed to high morale, competitive salaries, benefits, and promotion policies.
New hires are carefully screened and personnel selected are generally from within
.the tri-state area. The need for disciplinary action is very low.
Radiological infractions are generally resolved by counseling and training.
The supervisor to worker ratio is approximately 5 to 1 for the mechanical maintenance group personnel and approximately 7 to 1 for the control maintenance group personnel.
One electrician and one instrument and control technician are on each back shift, and mechanical maintenance personnel are on call during off hours. During outages the work force is supplemented by contractor personnel.
Every effort is made to provide supervision for these workers by company personnel or on occasion by contractors with site experience whose capabilities are known.
Personnel have been hired to provide around the clock mechanical and control group coverage.
Following the completion of appropriate training, this around the clock coverage will be initiated.
Discussions with and observations of maintenance craft and supervisory personnel indicate work is being performed by competent, conscientious workers with a high morale and pride in their work.
5.4.2.2-Personnel Training
,
,
.
The licensee has an INP0 fully accredited training program. A large training facility has been constructed remote from the site, and includes both the Hope Creek and Salem simulators.
Station procedures have been developed which define the training responsibilities of managers, training requirements, the initiation of training, and the maintenance of training records. A maintenance department procedure defines the requirements and methods of implementing the maintenance department training.
The contents of the maintenance department training records are also specified.
In addition to the general employee training provided to all station personnel, a comprehensive modular training program for the maintenance department personnel has been established. There are several modules common to both the mechanical and controls group, and also specific modules for only the mechanical and controls groups.
Each module has a number of submodules associated with it, and personnel are qualified to the individual submodules. Modules pertaining to plant systems, the safety manual and other basics are taught to both groups. Most modules are specific to one group or the other, and qualify persunnel to individual procedures.
Modules provide training, starting with basic principles and progressing to extremely advanced activities. The procedures require that personnel are assigned only to work for which they are qualified.
..... _. _ _ _ _. _
<
.
- )
Q 4*
}
Training consists of both classroom and hands-on-work utilizing many training
. aids.
'In order to maintain a high level of management and supervisory skills, management training is provided in the Technical Management Development Program, Technical Supervisory Skills Program, Technical Staff Training Program, and Management Continuing Training Program.
Instructors receive the technical supervisory skills. program course plus three weeks instructor qualification.
5.4.2.3 Test and Qualification Process We11' defined qualification criteria and qualification tracking is defined in the station procedures.
A training folder is established for each member of the maintenance department.
Personnel transferring to the Hope Creek maintenance group from other PSE&G departments or station facilities have their training records evaluated by the nuclear training deoartment.
Personnel records are i
updated each time a person completes a qualification. Training records were
verif.ied to be maintained and available to supervisors in both the mechanical and controls Groups.
Station policy specifies that workers be ass gned only work for which they are qualified / certified. QA audits were noted to have been performed, to verify that personnel performing tasks have been formally qualified in those tasks.
Also, provisions have been established for the disqualification of individuals in the event a supervisor determines an individuals capabilities are not in
,
,
accordance with the qualifications required to perform the work or task.
,
Qualification and verification of qualification requirements for vendor personnel performing services are identified as QA in the procurement and documentation requirements of the nuclear department purchase request.
Company and contractor welder certification are done in accordance with the nuclear department repair program manual.
>
Each time an individual successfully completes a training module or submodule, his or her qualification record is updated. These records are available to
-
supervisors to be used in assigning tasks to workers.
Discussions with supervisors indicate serious efforts are made to assign personnel only to tasks for which they are qualified.
5.4.2.4 Access Current Status The licensee has a Vice President-Nuclear procedure which describes the f
responsibilities and requirements for a nuclear department fitness-for-duty (FFD) program. The procedure describes the company policy which requires that all individuals granted access to its nuclear facilities must be mentally and physically capable of performing their duties.
Procedural requirements include establishment of a FFD program, programs for medical and psychological screening, programs for initial and periodic renewal of unescorted access clearance, train-ing for supervisors for aberrant behavior identification, and a drug testing program.
L
.
..
..
_. _
_ _ _ _ _...
_ _ _ _ _
,:(
,
Fitness for duty' training (FFD) is provided to both employees and contractors.
This training includes the companies FFD policy and methods used to implement this policy.
It includes the hazards associated with the abuse of drugs, alcohol, and prescription drugs.
It also includes the. role of the medical review officer, the company employee assistance program and programs provided by contractors and the union, what is expected of badged individuals, and the consequences which may result from lack of adherence to these policies.
A training program for supervisors is also provided. This program defines the-role and responsibilities for supervisors in implementing the FFD program; the employee assistance program; techniques for recognizing drugs and indications of their use, sale or possession; behavior observations, techniques for detecting degradation in performance; and procedures for initiating appropriate corrective action.
.An employee assistance program is available for employees with drug or alcohol problems. The availability of this program is widely publicized, and participa-tion in the program is voluntary and confidential.
Voluntary participation in a drug rehabilitation program usually will not involve disciplinary action by the company.
5.4.3 Conclusion
,
.The maintenance department is composed of a stable, competent, well trained work force with good supervision.
The' licensee' initiated a comprehensive modular training. program in 1987 which is incomplete. Well defined qualification criteria and a qualification tracking program are in place.
The company has a clear policy and an established program to deal with drug and alcohol abuse. This policy has been promulgated to employees and contractors, and supervisors have been trained in the implementation of the program. Employees are encouraged to participate in the program if they have a drug or alcohol problem.
!
._
...... _ _ _ _.
i l el ' %
'o
,
t'
i
,
APPENDIX 1
'
Appendix 1 is a copy of the attachment to the August 22, 1989 letter to the licensee requesting site specific information.
PRE INSPECTION REQUESTED INFORMATION To aid us in preparation for the maintenance inspection please provide us with
the following documents, procedures and information in accordance with the designated numbers.
If you do not have the requested document or information, it is not necessary to generate it to comply with this request. We recognize that many of the documents requested separately may be inclusive in a larger
'
single document.
Please provide five sets of the requested documents. A member of our staff will contact you regarding the best method of transmitting the documents to us.
-
<
.
"
'Section 1 - Description of General Plant Maintenance Activities 1-1 Maintenance administrative procedures which describe your corrective, preventive and predictive maintenance ~ activities.
1-2 ' Organization charts including the maintenance orjanization and plant wide organizations.
,
1-3 Procedures, charts and other documents which describe your Planning Department and its activities.
-
1-4 Documents which describe maintenance planning and scheduling meetings and status of maintenance reports.
1-5 Documents which describe the Maintenance and Operations interface during planning, scheduling, work start, work closecut and post l
maintenance / functional testing.
1-6 Documents which describe your work control process:
How a work
'
order is started, planned, executed, closed out and equipment returned to service.
1-7 Documents which describe training and retraining of plant and
,
l contractor maintenance personnel.
(For maintenance activities only, do not include GET.)
1-9 Documents which describe maintenance work procedure establishment and control:
Criteria as to when a procedure is
to be used; initial writeup; reviews and approval; revisions;
'
human factors review; QA reviews; requirements for conduct of l
work; troubleshooting criteria; work closecut; post maintenance i
testing and restoration of systems.
l
!
!
.
,
t
,
cvi i
f Appendix 1
j
!
1-10 Description of methods by which maintenance performance is measured. Are performance indicators used? What are they? Who
is informed of the results?
L 1-11 Description of process for communications with vendors for
'
technical services and latest technical irformation on equipment and systems installed at the plant, and interfaces with vendors of NSSS for training, modifications and equipment gg
. replacement.
1-12 Documents which describe the preventive maintenance and predictive maintenance programs.
Which equipment is included?
How is maintenance frequency determined?
'
What is done with results of these maintenance actions?
1-13 Documents which describe management involvement in maintenance.
.
Are there goals set for the maintenance and I&C l
Departments?
r Are these goals sued in the performance evaluation of
managers and supervisors?
'
Are these goals communicated to first line supervisors and I
- -
chiefs?
'
'
.
.
.
Section 2 - Status nf Plant and Contractor Personnel Who Perform Maintenance.
~2-1 The number of craft personnel for electrical,. mechanical and I&C maintenance organizations.
Please include foremen and foreman to craft ratio.
'
I
>
l 2-2 The average years of experience for each individual and the turnover
,
rate.
. l l
2-3 Description of shift work and work assignments.
How do foremen decide on which craft is to perform what type of work?
1.
'Section 3 - Status of Plant Equipment and Plant Maintenance 3-1 What equipment failures occurred during the last year of operations?
l-3-2 What equipment failures have been found during shutdown of plant?
I
3-3 Describe maintenance and testing for diesel generators and L
electrical equipment including switchgear that would be required in l'
case of loss of offsite power.
1'
l h
1,
.
i
.
-
-
.
-
.
- -
.
iv
-
uso b :a
,
- - '
Appendix 1
1
3-4 What component failures present greatest risk from a probabilistic
,
risk standpoint to the plant?
'
,
.3-5 What have been the areas of high maintenance activity on safety related and'non-safety related equipment and components?
3-6 Provide the following status concerning Maintenance Work Orders (MWO)
Current total listing and status of MW0s, number in planning ~,
- number in final sign-off, number on hold for lack of. parts,
'
number on hold for engineering assistance, number available to be' worked on.
Projected number of corrective MW0s to be outstanding at
.
start-up by priority.
Rate of completion of corrective MWO in terms of number
,
completed / month and manhours expended (by craft)/ month for the past 12 months.
,
Current number of preventive maintenance work orders overdue.
- Rate of completion of preventive MWO for the past 12 months.
- Estimated manhours required to complete current preventive
maintenance MW0s.
Number MW0s requiring rework over past 6 months.
3-7 Provide five corrective' maintenance procedures for work that is scheduleri for the upcoming outage.
MOVs, PRVs, ECS Pumps, Batteries,
'
Switchgear, etc.
3-8 Provide five preventive maintenance procedures that are scheduled for the upcoming outage.
3-9 Provide your overall outage schedule.
,-
j
.
,
.
--
-
-
- -
-
-
-. _....
_ _ _
-
' k.
~
,-
c; 4 pg
.',
.r v
APPENDIX 2 PERSONS CONTACTED Public Service Electric and Gas Company
,
. R. Beckwith,, Station Licensing-Engineer o
y
- W. Bacon, Principal Training supervisor J.,Clancy, Radiation Protection / Chemistry Manager D. Cooley, Onsite Safety Review Engineer G. Daves~, Maintenance Engineer, I&C
.a
- E. Devoy, Mechanical. System Engineer
- R. Edmonds, Assistand Manager, Maintenance & QC Training
,
.S.'.Funsten, Maintenance' Manager
,
R. Griffith, Sr. Station QA Manager.
J. Hagan, General Manage', Hope Creek r
B. Hall, Manager, Reliability and assessment
. ' '
' *D. Hanson, Manager, Nuclear Training
.
- J. Hart, Material Coordinator
- R. Hovey, Operation Manager D. Jagt, Manager,' Hope Creek Projects E.~Karpe, Sr.' Radiation Protection Supervisor P. Kudiess, Manager, Site
- Services
.
W. Meyer, Principal Training Supervisor W. Mokoid, Maintenance Engineer, Mechanical J. NIchols,' Technical Manager B. Preston, Manager, Licensing and Regulation-E.' Rush, Sr.. Maintenance Supervisor
- )L Schell, Technical Staff Engineer
.
C. Smith, Principal Engineer,. Plan & Schedule
- L. Wa11 ender, Radiation Protection Supervisor
- General Electric Company M. Farschon, Hope' Creek Site Representative U. S. Nuclear Regulatory Commission D. Allsopp, Resident Inspector
.
J. Durr, Chief,. Engineering Branch W. Hodges,' Director, Division of Reactor Safety
- T. Johnson, Sr. Resident Inspector, Peach Bottom
- P. Swetland, Chief, Reactor Project Section 2A
- Denotes'those not present at the exit meeting at the Hope Creek site on
.
October 13, 1989
.
.. -..... _ _ _ - - - -
_.., _.. _. _.....
__ _
,[
'
m a
c
+
>
-
>
oy i
APPENDIX 3
,
,
SUMMARY OF WEAKNESS
' Weakness'- A' potential. problem or condition presented for.-
Reference to
- licensee evaluation and corrective action as applicable.
Report section Lack of effective parts support for routine 4.2.2
- maintenance activities.
,
,
.
,
APPENDIX 4
,
SUMMARY OF UNRESOLVED ITEMS LUnresolved items are matters.about which more information Js required in order
'to determine whether they are acceptable items, deviations or violations.
Unresolved' items identified during this inspection are listed below:
Reference to-Item No.
Description Report-Section 50-354/89-80-11 Lubrication oil samples for 5.2.2.1 the diesel generators 50-354/89-80-03 Diesel generator fuel tank vent 3.2.2 pipe missing one flanged connection stud.
'
50-354/89-80-09 Cable entry to diesel generator 5.2.2.1
.
control panel not sealed.
'
.
/<
a e
= - -
[
f
.
+ y v ~ ~b,
WORKING TRE 9d JPM "vTt AToaS_
MAINTENANCE INSPECTI
-
i..
i,.
,
.,
-
L i
. m,i....
mmi
...
.
.
......
I
'
-_ _ _ _ _ _ _ ~. _.
+
_ _ _ _ _
_._em_
+
i i
gm 7dm pr u
i
,,
..
!i5Eo"
'$',*'
"
-.
- N'" %
.......
- ;; =./,:a,=
=
. m, i
....,,,,..
- n"'
- :',* w
~ '
- =
- =
,
.... ma
,
....
..-
.-
....,,,
.
. = =
..=.a
.
.
.,
- ;=,,,,
..
-
.
,,
- * * " =
.c.,.,,,,.x,.,
- gT,,=
a
,.
. ii..u -
.
~q w~
. ~,., u a,
_
. u.cs.n.i.".n.
.
-
s e.
,
.,,.a
.
m,., c,
...wi,.i
. m..
. o, m..-
-
-
.-
.,,
..,,,,..,,,,,,
.
. mn
..
,
,.
,
..,,r1 tv.a, gylMa,1
.n
<-
.
,,
,,,,,,,,,
E1
.
I
.t.#-. 31 4.,$ pg.sg t.
&
..
.
- * *i.',;
..
,=,.,a::==
-'
'=='~
g'.
o
..
.
..
i,,,,,,,
i
- =g.= -.*
-
,
.
,,,
'. maaa
.., _
.
r..
.
,
,,
-W-
..
w.
...
.
. a-..
- L':='A o
- ".', =. ' a =
."O:"'
.
. < =
.
- gg== ===
.
.,,,,
- "",.
- Ann'.
- ,,,,,=0=
- * ae
="
l llll"lllllll ll*llllll:'".1Jn*
,,
...uo, i wi e.
1S
-
-
i. -..
'
-
- f#*".="
..
". '.
- lll=
.
.
_.
. c,, n
..
.
.
.
.
.4A 00.h.i.tC.Ch
.I
' IEAEE OAIE00 l
.
0.ER.
.
.
u.s
!
'
[~-
- ?T.'".:: "
a.,i
.U
"
. - urm.m
.
..n.cQ
,,.
' 'P'U'AM M
.Ag
..uRD
..
gg
.
.,,.o c
.
..
a i.n,n to.s.ea 4we.s-c..nt+a 4nin4.nm e.ntibc.
.n N nWe,.0 5744
- J
"*
.
- ""' "rtmi
.
- ~
,
_ _ _ _ _ _. _ _ _ _ _. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
s
_
_ _ _.. _..
.
.
TREE t me t.w e,an m I 064.A PDF nsa pheansk Figure 1 m.
NRC Maintenance Inspection
[
- "g",'"' g*, "9 )
Hope Creek Generating Station 1989 stas /
'It
. - - - - _._
= - -
- -. _,
I l'
I
ii ti ei j
..
WL
'
seeURL a.f@ 8edMOR e
- unstaamskaft
. Gass 2A B 098f e
!
e tamaTT Measemastaf 4 4;CLsmauw
, gg gggPham M4SSE 4 50S*W8 64GL
$fMBEILLARDEh4 EAff ES
, tvet a arft
. istMB f. EDIE G.b51CatWh
,
,
IG
-
, gaggg g pt9EhdfB 93 500 $14mb4AD e halgh $1510t$
, ggy,ygg gag ggggggb o 8.GMD CMWU4P*eoval gi,
, garf CDdESAE CUdj Q 8W3
-. y7
'
- DIEBOLECT CGeS98ut
- *=="*
>.
.u o
"
h. 3 --'".i I
- '
I pec,eskE.31. C o.,..
.
.i =A
.
-
.
4'
_
'
"
I p # 5 17 g.,..'p
.
e pm pen epistp
e mA4246 4 Paf ft.ECEPT 4 WTtetsi l
900 nf RAGA I e
- EJGRAL
'
gpagg g gepgw i.F..XF
.D e St Ag
-,
- M C.o.s.hA,t_on
.o....i n'1%H8E-f,==
e
-
,_.a,.
.
, A.A.
-.
-
- = = -
e
.
... mo...,
.
I g"E 10.t.k.a. eft.A.veAJ.a.u.f.v 4.sALf1 Catch (11t mesignmG
~
i e e
,
..
=
.
==..>A
_
...
...
.
4D.
.
.
,
-A
.
ii C..-.
,.
a.
,,.m M.
-M,,,,,,
C,,.,&,.,.,
.
.=. C A
.
- .-
,
C.o AI3L.,R rURE
.
o,
.A C.A
..
-
r a
.
A,
,
o
. -.,
.
.
.
==
C A
.,
L,a. R13, o1
.
.A
.
a.
a.c,
.
u a am. A,
,s q
Cu v
.
saa aAa='s m w
-
. e.n.iviC.A
.
-.== u.a.:
C A
a,==
Also Available On
-
.m Ma'.AC, Aperture Card
.
, _ m,,,
E
.
f..
..a,,
- 0====Da
.
n,.
.
'
'IIl3E**E 8 ODtitputhfi.nPoedwk 8 0CER,.,,,g ggg.
""se4JD PD10hNQ'
e CGsW Jo e
,,gygg gg,,g MOest4Af C NLst.CUhtse t
.
10msevt3 aAm
.
& M16 caun' * *aa==5
-
LEGEND
=Cuat
- e Comm&ID gyggt Ecitus i (LDatfl
. 8tWest aMD and peng GEDe-IWCamest eEla fluat. fWClasso masaltLt
-
- CUI1FICARGe M
fvascimens mact&A1l gag. asA eof fvau#Aful.11
- MPettes a 14ame ertfficupt GAIA e CGIEEC11'4 acilmi
-
i
- MM MM8
_l
', __ _. _
Da.#AE mass 1DemsG 9402B ELlaEN! MG4ACT l[WDe-EDEk? EL 000askO-j. feeGR.aa:RD
.
mE4 41a.0s-EADENT S acub41ELv actsE1ED
.
4ED-f.Infat 6 uf53s4 -
M
,
M-n/A IIOT DaueAll&.enacte# Alt
,E
Gr9sFft-N1 SAIA g
,'
I D4.It umm 4DeG 880CE.35 ILDIDit trWMfmfAtes g
,
,
1ffDA-ftK3 se MJFX Pd3 e
CEDo-FWCHGed &
' 800' M *4 '38 f
- eA' j f'b e,+ sua gut COLAB E., m,Au, g,,,
11u1sedDIED 101===f.<
aormaamm ancAnas
exN'-----
-
, => i,,fg,,mv,ana, ensis, um maa mean tvann
-
.
p.
o pg,g,
,
SAED. aP'4ath fttmGS ASb. A RAGG f. LAOi CBIMBA GDelyt
,
" " "
e#AUTT.
034/01
,
e
.lBAfl ORAsus aAAImp
L, 425767-C
'
.
.
__.
.
.
80019 Ro aaa - o r
,