IR 05000369/1987037
| ML20236E971 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 10/23/1987 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236E966 | List: |
| References | |
| 50-369-87-37, 50-370-87-37, NUDOCS 8710300085 | |
| Download: ML20236E971 (15) | |
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p arcq UNITED STATES
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'o NUCLEAR REGULATORY COMMISSION
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REGION il
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o 101 MARIETTA STREET, N.W.
f ATLANTA, GEORGI A 30323 E'-
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Report Nos.:
50-369/87-37. and 50-370/87-37 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.:
50-369 and 50-370 License Nos.:
NPF-9 and NPF-17 Facility Name:
McGuire 1 and 2 Inspection ptember 28 - October 2, 1987 Inspecto :
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rd Date Signed 3[c7 Approv d b
/o J J B Gke, Chief Date Signed a rials and Processes Section l
Di ision of Reactor Safety SUMMARY
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Scope:
This routine, announced inspection was in the areas of previous enforcement matters, maintenance and inspector followup items.
Results:
No violations or deviations were identified.
8710300085 871027 PDR ADOCK 05000369 o
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- D. J. Rains, Superintendent of Maintenance
- B. H. Hamilton, Superintendent'of Technical Services
- H Sample, Superintendent of Integrated Scheduling
- D. Stamp, Mechanical Maintenance Technical Support - Production Specialist
- G. A. Copp, Maintenance Engineer / Planning
- D. N. Smith, Performance Test Engineer
- E. O. McCraw, Compliance Engineer
- N. Atherton, Compliance
- R. B White, Maintenance Engineer / Instrumentation and Electrical (IAE)
- R. W. Rider, Maintenance Engineer / Mechanical
- J. E. Snyder, Performance Engineer C. Green, Assistant Performance Technician K. Reece, Unit #1 General Supervisor, IAE
- D. M. Bartholomew, Mechanical Maintenance Technical Support D. Miller, Operations NRC Resident Inspectors
- W. T. Orders, Senior Resident Inspector
- S. Guenther, Resident Inspector D. J. Nelson, Resident Inspector
- Attended exit interview 2.
Exit Interview i
The inspection scope and findings were summarized on October 2, 1987, with
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those persons indicated in paragraph I above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The following new items were identified during this inspection:
Unresolved Item 370/87-37-01, Valve Failed to Operate, paragraph 5.c.
Inspector Followup Item 370/87-37-02:
Work Request Question, paragraph 5.b.
l The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
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Licensee Action on Previous Enforcement Mat'ters-a.
'(0 pen) Unresolved Item (369, 270/86-26-08):
Written Criteria for Evaluation of Erratic Valve Action o
'This item identified an inspector's concern that the licensee had no written criteria covering _their evaluation of_ valve test information for identification of. erratic valve action.
Although the licensee
'i maintains' and reviews valve test data (on a computer data base) to
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satisfy a code'(ASME Section XI) requirement for reporting erratic
valve action, they have no written instructions covering the l
responsibilities and criteria for this work.
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In the current inspection, the licensee's performance test engineer-
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informed the.NRC inspector that. procedure covering this is in
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preparation' and will be completed by the end of 1987.
The inspector
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stated that the matter would remain open pending verification that I
the procedure has been satisfactorily implemented.
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.(0 pen) Unresolved Item (369, 370/87-16-01):
IST Program Requirements
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.for PORVs and Block Valves l
This item Lidentified a concern that the ' licensee did not include their power. operated relief valves (PORVs) or block valves in their Code (ASME Section XI) program for inservice testing-(IST) pumps and-valves.
The licensee's program for McGuire.had been submitted to the
NRC Office ~of Nuclear Reactor Regulation (NRR) for evaluation but.'the l
evaluation had not been completed and the omission had not been
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discussed with the licensee.
The NRC inspector noted the omission
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during a routine NRC -inspection.
The inspector also noted that the licensee should have been aware of NRR's concern for the omission based on an NRC evaluation of the licensee's IST program for their Catawba plant.
j During the current inspection, the licensee's performance test engineer informed the NRC inspector that the PORVs and block valves would be added to the McGuire IST program by December 1, 1987.
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4.
Unresolved Items An Unresolved Item is a matter about which more information is required to determine whether it is ace
- able or may involve a violation or deviation.
An unresolved item identified during this inspection is
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discussed in paragraph 5.c.
5.
Maintenance a.
Maintenance Program (62702)
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The inspector reviewed the licensee's maintenance program to verify that it is in conformance with Technical Specifications, regulatory I
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requirements, licensee commitments, and industry guides and standards.
The inspector's review is described below:
(1) Procedures The inspector reviewed maintenance program related requirements described in the following procedures:
-Procedure No.
Revision Title SD 4.2.2
Independent Verification Requirements SD 4.7.0
Control of Maintenance Program MMP 1.0
Definition of Work Request MMP 1.1
Emergency Work Request
'SD 3.3.0
Determination of QA Condition 1, 2, 3 or 4 Structure Systems and Components MMP 1.3
Maintenance Activities Associated With the Functional Verification /
Retest Program SD 3.2.2
Identifying and Performing Plant Retesting APM S4.6
Administrative Instructions for l
Work Requests
SD 2.11.2
Fire Protection and Surveillance
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APM S4.2
Administrative Instructions for Permanent Station Procedures MP/0/8/7650/09 Chg 0-6 Ignition Sources (Cutting, g
Welding, Grinding and Open Flame
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Safety)
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Operability Determination SD 3.1.19
Safety Tags SD 3.1.5
Activities Affecting Station Operations or Operating Indications SD 4.2.1
Handling of Station Procedures
NPD/CMD 6/5/86 Maintenance Interface Manual j
OMP 2-5
Technical Specifications Action j
Items List j
OMP 2-17
Tagout/ Removal and Restoration Log J
MMP 4.0
Definition of Preventive i
Maintenance Program 2/9/87 McGuire Compliance Manual, Section 2. 7, Technical Specification Change / Licensee Amendments i
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4 (2) Corrective Maintenance The inspector reviewed the procedures described in (1) to verify that:
(a) Written procedures ~ have been established for initiating l
requests for routine and emergency maintenance.
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(b) Criteria and responsibilities have been established for review and approval of maintenance requests, including emergency maintenance requests.
(c) Criteria and responsibilities have been established that form the basis for designating their activitiy as safety-related or not safety-related.
(d) Criteria' and ' responsibilities have been designated for performance of inspections of maintenance activities.
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(e) Provisions and responsibilities have been established for the identification of appropriate inspection hold points related to maintenance activities.
(f) Methods and responsibilities have been designated for performing functional testing of structures, systems, or components following maintenance work and/or prior to their
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being returned to service.
(g) Administrative controls for maintenance activities required that he following records will be prepared, assembled, and reviewed for transfer to records storage:
approvals of maintenance requests
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identification of the personnel who performed the l
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maintenance task l
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identification of the personnel who inspected the l
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maintenance work i
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cause of the malfunction or failure which necessitated I
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the maintenance work, including generic implication of the failure description of the corrective action taken
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identification of the post-maintenance functional
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testing performed identification of personnel that performed the
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post-maintenance testing
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identification of replacement parts or materials used-
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identification'of test and measuring equipment used
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(h)~ Responsibility has been established to assemble and review
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the records' identified above.
(i) Requirements have been established for reviewing' completed corrective maintenance records to identify repetitive failures of parts and components, and to identify design deficiencies, i
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(,j) Responsibilities have been assigned to ensure implementation of records review identified in (h) above.
-(k) Work control procedures have been established to require special authorization for activities involving welding,-
open fla'ne, or other_ ignition sources and take cognizance -
of nearby flammable material, cable trays, or critical process equipment.
(1) Work control procedures have been established to require a firewatch, with capability for communication with the control room, if an activity identified in (k) above is to be performed in the proximity of flammable material, cable trays, or vital process equipment.
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(m) Revisions to Technical Specifications (TS) have been incorporated into procedures and included in the master program.
(3) Equipment Control The inspector reviewed the procedures listed above to verify that:
(a) Procedures have been established to specify that the operating staff grants permission to release equipment or systems for maintenance.
Before granting permission for removal of equipment for service, the operating staff is required to verify that the equipment or system can be released without violating TS requirements.
Additionally, they shall determine how long the equipment may be out of service.
Granting of such
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permission shall be documented.
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(b) Equipment that is environmentally qualified should be identified as such prior to maintenance and sufficient controls should exist to ensure it is returned to that status upon reassembly.
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(c) When testing of redundant components or systems is required by TS or 10 CFR 50, such testing shall be documented.
-(d) The status of equipment and systems will be clearly identified.
' (e) Procedures have been established and responsibility has been assigned for determining when independent verification has been implemented correctly.
(f) Procedures and responsibilities have been established for returning equipment to service.
(g) Revisions to TS have been incorporated into procedures and included in the master program.
(4) NRC Inspector's Findings
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Based on his review, the NRC inspector determined that (2)(d),
(2)e), (2)(f), (2)(i) and (3)(b) above' require further review in subse (2)(d)
and (quent routine inspection of the licensee's program.e) will be examine; incorporates inspection requirements in the Work Requests j
through means other than procedures.
An Institute for Nuclear i
Power Operations (INPO) audit identified deficiencies in the
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licensee's failure to provide detailed planning of functional l
testing and to assure review of maintenance to identify i
repetitive failure.
(2)(f) and (i) will receive further review j
relative to the licensee's corrective actions in response to j
these INP0 audit findings.
The corrective actions are to be completed in November 1987 and January 1988, respectively.
(3)(1) will be examined further by NRC Region II to determine j
how the licensee provides assurance of maintenance of equipment qualification.
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Maintenance Program Implementation (62700) (Unit 1)
j The inspector reviewed the licensee's implementation of the maintenance program, as described below, to determine:
whether the program is being implemented in accordance with regulatory
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requirements, the effectiveness of the program on importation plant i
equipment and the ability of the maintenance staff to conduct an effective maintenance program.
(1) Records j
The inspector reviewed in-process records associated with maintenance activities being conducted on Work Request (WR)
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M; 7-l 130510 (for-- repair' of the valve seat on Nuclear Service Water.
-l System Valve 134A)- during :a refueling ' outage ' to' determine
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' The cause of the failure was - evaluated and adequate corrective action was taken to reduce the probability _.of.
recurrence.
The procedures 'specified in the maintenance package. were
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adequate-for the scope of the maintenance performed.
The' vendor technical manual for the equipment under repair
was controlled - and. kept up-to-date (whether. or not the vendor manual was specified in the maintenance package).
Vendor maintenance recommendations, 'if used,' were correctly
translated into or referenced by the maintenance-
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procedures.
Required administrative approvals were 'obtained before initiating the work.
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j Limiting conditions for operation were' met while the
componentLor' system was removed from service.
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l Approved procedures were used where the activity appeared
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to - exceed the normal. skills possessed by qualified
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maintenance personnel.
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Corrective and preventive maintenance records were assembl-.
ed and stored as part of the maintenance history.
The measuring and test equipment (M&TE) used was identified and in calibration.
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Parts and ' materials used were identified and.at least
met.the specifications of the original equipment.
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l (2) The inspector reviewed the below listed examples of procedures
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included in Work Request 130510 to verify that:
The procedures conform to licensee's administrative requirements, including format, approval and control.
The post-maintenance testing is appropriate for the repairs made, f
The inspection and hold points are identified in the procedures or in a documented plan and are based on a set of established guidelines.
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Supplementary reference material such ' as'. drawings - and
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-technical manuals'is adequate and controlled, i
The. activity is described in-sufficient detail.
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Consideration ';is given to radiological, - ' temperature,
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circumstances.
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pressure, and; electrical' hazards,L as - appropriate-to the -
The = provisions for ' fire-protection, cleanliness, - 'and -
housekeep'ng are adequate.-
Appropriate : instructions. an'd-. quality control ' checks. are'
included to verify that environmentally qualified' equipment is properly 3 protected against moisture intrusion when-
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reassembled.
The provisions for obtaining approval from operations.as
well as methods 'for notifying operations when affected'
j systems are removed from service and ' ready to'be restored to normal service are present when needed.
Procedure No.
Revision Title
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Chg 0-2 Limitorque.
Valve IP/0/A/3066/01A Operator Corrective Maintenance
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MP/0/A/7600/95 Chg 0 BIF Model 658 Butterfly.
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Valve Corrective i
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Maintenance MP/0/B/7650/09 Chg 0-6 Ignition Sources (3) NRC Inspector's Findings p
r The inspector observed the following apparent deficiencies in L
the Work Plan and procedures reviewed:
(a) The work did not appear to be well-planned.
Several procedures listed for use in the WR planning were not used.
(b) The equipment failure or degradation requiring repair and its cause were not adequately described in the WR.
(c) Some of the procedures used contained figures that were partly illegible (e.g., IP/0/A/3066/0/A).
(d) Some of the procedures contained steps that appeared excessively complex and difficult to use from a human L
factors stand point (e.g., IP/0/A/3066/0/A).
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(e) Procedure MP/0/A/7600/95. contained the following-
deficiencies:
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Sec' ion 11.3.8 refers the user to a note on a drawing.
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that is not a part of the. procedure.
The note is f
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short and should be stated in 11.3.8.
j Section 11.7.8 requires a seat leakage test but does.
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not provide :or reference any: criteria for test L;
performance or' determining valve acceptability.
(f) The actual maintenance performed per WR 130510 was complex,-
involving many changes to the original item (e.g.,
valve body, body - material re seat gearbox modifications, etc.) pairs, difference and would be replacement,
. difficult to understand in any review of equipment maintenance history for future maintenance work or for failure evaluations.
.The licensee's. procedures.do not
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provide for any summarizing of the work or review and _
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additions to WR records after the work is complete. -to assure the records adequately describe the maintenance i
performed.
(g) Procedure MMP 1.0 requires the planned sequence..of maintenance work and the skill (craft) to perform each step of. the sequence ' be entered in WR ~ form,Section III.
MMP 1.0 lists skill letter designations to be used in making these entries.
The NRC inspector noted that one of I
the skill designations listed in.- WR 130510 was not
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described in MMP 1.0.
.This was skill MW, which the inspector was informed was maintenance welding.
(h) MMP 1.0 requires licensee personnel to document all maintenance actions taken in WR Section V.
The entries are required to include the sequence number for each major portion of work, the date the work performed and who performed the work.
The inspector found that in some instances work entries recorded in Section V of WR 130510 did not include sequence number, date, or the name of the
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individual who performed the work.
During the NRC inspection, licensee personnel took the following actions relative to apparent deficiencies described by the NRC inspector:
Licensee personnel prepared a summary description of the
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work performed on WR 130510 and added it to the records.
The inspector was informed that there had been previous
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problems with personnel not entering sequence numbers, signing WR entries and dating WR entries (WR Section V) and
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that personnel had been cautioned to make correct and l
complete entries.
Licensee supervisory personnel stated that the requirements would be re-emphasized to responsible
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personnel.
The inspector was informed that procedure MP/0/A/7600/95
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had been prepared _ in haste and that they recognized that it i
required corrections.
Licensee personnel stated that they had' contracted the aid of the manufacturer of the valve
repaired in WR 130510 and that the manufacturers
representative had been present to provide advise in the course _ of the work to assure satisfactory corrective maintenance.
Licensee personnel informed the inspector that the r.eed for
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improved maintenance procedures had been recognized by then i
and that their procedures were in the course of being upgraded.
They stated that the improvements were taking into account the need for simplification of procedural steps (human factors) and the need for' more legible i
figures.
The extent and significance of the apparent deficiencies noted in the licensee's implementation of maintenance requirements will be examined further by Region II in' routine inspection of this area.
Within the areas inspected, no violations or deviations were identified.
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InspectorFollowupItems(IFIs)(92701)
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IFI (369, 370/86-26-06):
Valve Position Indicator Verification at Auxiliary Locations.
This IFI identified a question as to whether the licensee verified proper position indication of valves at auxiliary control locations.
During the current inspection, the licensee's performance test engineer informed the inspector that their procedures specified position indication checks but did not indicate where the checks would be made.
He further stated that in response to the item,
proper position indication at auxiliary locations had been i
specifically verified and that procedures were being changed to assure that correct position indication was specifically performed
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and recorded for auxiliary locations.
The 4.ngineer stated that the l
procedure changes would be completed by December 1,1987.
The inspector informed the licensee, as their actions in this matter were
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incomplete the IFI would remain open, i
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(Closed)(IFI)(369,370/87-26-07):
Large Differences Between Stroke Times of Identical Air Actuated Valves.
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This item was opened to. followup on concerns that the disparity in stroke times between two apparently identical air operated valves appeared excessive. The NRC inspector discussed this matter with the
licensee's cognizant Performance Test Engineer and was informed that i
the matter had been checked and that it was documented on WR 129965.
The inspector reviewed WR 128865 and found that it consisted principally of corrective maintenance to reduce packing leaks for valve 2MND MV 0034 followed by adjusting limit switches and
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functional testing.
Although the MR indicated that the work was
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complete and that the functional tests on 5/31/87 indicated correct.
performance, the last page of the WR (dated 6/24/87) contains an undated, unsigned entry " control room says valve won't close."
The next step described on the MR is for removal of the scaffolding used to access the valve and this indicates that following maintenance the valve was left inoperative.
Licensee personnel informed the inspector that they believe the " valve won't close" entry was made before the testing conducted 5/31/87, however, the 6/24/87 date of the WR page (sheet 3) suggests otherwise.
The inspector verified that records of a routine quarterly stroke timing test conducted 8/5/87 indicate adequate valve operation.
Licensee personnel stated
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The inspector identified his concern relative to this WR entry as Inspector Followup Item 370/87-37-02, Work Request Question.
Concern expressed in IFI 87-26-07 will be resolved with this new item, c.
(0 pen) IFI (369, 370/87-16-03): Method of Stroke Timing, i
This item identified planned inspector followup to verify licensee implementation of procedural changes to require that valve stroke timing be measured from actuation to final position limit switch
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indication.
The licensee had previously stroke timed their valves l
primarily between initial and final limit switch actuations through a computer.
The computer has the capability of locating signals from
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individual valve limit switches from which it can, if instructed, l
start and stop timing.
In the stroke timing method initially used by the licensee, the test performed would indicate the locations of the time initiation and the time end limit switches to the computer and i
on valve actuation.
The computer would determine and print out the j
time between the two limits as the stroke time.
For the new method j
the test performer uses an electronic device to manually input a
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start signal in place of the initial limit switch location.
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signal is manually actuated at the same time as an operator actuates l
the valve switch.
The end of timing in the new method is the same as i
l the old - the computer stops the timing when it receives the l
electrical signal from the tripping of the final limit switch.
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Although the old method appears to be a more accurate method, it did not include the time between valve actuation and first limit switch
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. actuation, -a time which may be important in _ determining satisfactory valve. opera' tion.' -
In : the current ? inspection, th'e inspector _ was informed that the-
< licensee had -not completed. correctionof all of their procedures-.to require use-of.the.new. stroke timing method. The inspector informed
' the. licensee ~ that' the IFI: would remain.open pending completion = of their procedural changes.; 'As' interim followup. on this item, the NRC inspector reviewed, stroke time data maintained on a. licensee computer-data base for four -Unit I and four identically located Unit 2 valves'
and then observed performance of stroke time-tests on one. Unit I and-11. Unit 2-valves.. During; four of-the' tests, the inspector manually -
timed the valves.using a licensee stop watch for comparison with times measured by the licensee.
The recorded computer data base stroke times reviewed by ~the
- inspector are described in the listing below; which gives the' valve.
number (No.), measured' stroke time (seconds), and the number of any WR performed:
Valve Stroke Time Records
,U_ni,t 1 Unit 2 l
Valve Time LDate-WR Valve Time Date WR
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1NI-173A 7.2
.06/30/83 2NI-173A-- 8.6 08/19/84 (MOV-7.2-09/22/83-(M0V-;
8.62 02/20/85
. Gate)-
'7.4 03/27/84 Gate)
6.6 04/11/85 85926 7.4 11/29/84
'6.8 07/15/85
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7.2 04/22/85 6.8 12/16/85 6.6 06/18/86 92894 6.8 04/04/86 7.4 05/19/86 6.8 11/16/86 6.6 11/27/86 8.14 06/23/87 94726 IRN-134A 52.6 12/17/85 2RN-134A 56.0 02/14/86 (M0V-52.6 03/17/86 (MOV-56.0 04/22/86 Gate)
52.6 06/24/86 Gate)
56.0 07/23/86 j
52.6 10/14/86 56.4 10/23/86
52.6 12/19/86 56.0 01/14/87 52.8 03/16/87 56.2 04/07/87 53.5 06/08/87 58.34 06/25/87 ITL 66606 52.8 09/03/87 58.0 07/01/87
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1ND-34 6.4 10/29/85 2ND-34 28.4 02/02/87 i
(A0V-6.6 01/29/86 (A0V-22.2 03/02/87
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. Gate 6.4 05/01/86 Gate 22.0 04/02/87 l
6.4 08/19/86 24.8 05/14/87 j
6.6 11/24/86 28.25 05/14/87 ITL l
6.4 02/02/87 21.6 05/31/87 128865 l
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6.6 05/01/87
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17.34'
'08/05/87 ITL l
11.32 07/31/87 ITL-8.2 08/05/87
6.4 07/31/87 21.3 08/07/87 ITL
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8.4 08/07/87-l 1NI-185-25.12 03/24/81 2NI-185 25.77 07/06/83 (MOV-24.92-11/19/82 (MOV-25.73 03/06/85 L
Gate)
25.72-3/24/84 Gate)
26.55 04/18/86
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25.0 5/18/85
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25.6 07/04/87 ITL 94733
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-Abbreviations:
1 at the beginning of a valve number = Unit 1, 2 at-the.beginning of a valve number = Unit' 2, ITL-new stroke time'-
l-method, initiation (actuation) to limit (otherwise~ times are by old l2 method), NI-safety injection, RN = Nuclear Service' Water,- ND decay heat removal, MOV motor operated valve, A0V = are operated valve.
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The valves stroke times observed.by the NRC inspector on 10/1/87 were as follows:
Stroke Times Witnessed by NRC Inspector Unit'l
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ITL (Licensee)
Stop Watch NRC)
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Valve Time ITL (License) Previous Time Stop Watch (NRC)
2RN-124A 58.6 58.0
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2RN-137 53.6 54.4
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l 2RN-162B 7.4 7.6 8.7 2RN-174B 45.2 45.4 45.7 2RN-171B 35.4 35.6 37.1 2RN-215 1.0
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.9 2RN-227
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2RN-231 Failed *
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1-P. (2nd try)
2RN-43 41.8 43.6
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2RN-299 51.0 51.24
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2RN-279 50.0 44.0 54.3 l
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- When first actuated this valve changed to two lights on (first limit i
switch tripped) but failed to fully open (red light only) exceeding j
its specified maximum stroke time of 15 seconds.
When closed and
I actuated again the valve moved to full open.
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In reviewing the record and observed data, the.NRC inspector. noted
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(1) Although valve 2RN-231 failed to indicate the correct movement
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.to open in'its first actuation, the licensee considered that the
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.t valve performed acceptably.
The performance test -engineer stated that this type of valve had a history of not tripping the-second limit switch. 'A WR was issued to check the valve within two weeks.- The NRC inspector questioned whether :that long a
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delay was acceptable.
The Unit was operating in Mode 1 and the
valve in question is the decay heat removal pump 2B cooler l
isolation valve.
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(2) When the computer measure stroke times to the nearest tenth of a second the last digit was virtually always even suggesting a possible inaccuracy in the data generated.
This was true for 55 i
of 57 recorded measurements and 11 of 11' observed measurements (66 of 68 total).
Of 'less statistical significance, all five -
times obtained by the inspector using the licensee's stopwatch, ended with odd numbers.
'
(3) The stroke time obtained by the inspector for valve 2RN-279
!
differed from that measured by the licensee by 4.3 seconds. The
'
error appeared a little to large to explain as expected manual timing errors.
The inspector informed the licensee that the concerns described i
above would be reviewed further in subsequent NRC inspection.
'As the concern in (1) ' represents possible incorrect determination of acceptable valve operation, the matter i
,
represents a potential violation and was identified to the
licensee as Unresolved Item 370/87-37-01, Valve Failed to j
Operate. The concerns in (2) and (3) represent anomalies in the licensee's stroke timing and will be addressed in subsequent review of the original IFI.
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