IR 05000369/1987040
| ML20236R521 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/17/1987 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236R509 | List: |
| References | |
| 50-369-87-40, 50-370-87-40, NUDOCS 8711230338 | |
| Download: ML20236R521 (12) | |
Text
_
.
..
.
..
....,..
-. - - - - -
.
.
I C
[# rouq'.
UNITED STATES -
--
o NUCLEAR HEGULATORY COMMISSION
"
-;@
REGION 11 n
.g
_j 101 MARIETTA STREET,N.W.
't ATLANT A, GEORGI A 30323
%
g/
- .+
Report Nos.: 50-369/87-40 and 50-370/87-40 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 C
- 0 tober 19-23, 1987 Inspector.
// /
7-
.G (rd~
Date Signed
.
Accompa yin e
n el:
R. Carrion Approved b.
// 7 7 JJ BTake, Chief Dhte Signed rials and Processes Section i ision of Reactor Safety SUMMARY.
Scope:
This routine, announced inspection was 'in' the areas lof previous enforcement matters, power operated relief valve modifications, maintenance,-
and inspector followup items.
,
Results: No violations or deviations were' identified.
'
,-
,
f
'd
1
/
Y
!bk A
O
'I a
J
'-
_
- -
- _
a
_
_
____,
.
,
,
i REPORT DETAILS 1.
Persons Contacted Licensee Employees j
- B. Travis, Operations Superintendent
- J. E. Snyder, Performance Engineer
'dB. H. Hamilton, Technica Services Superintendent l
- D. J.. Rains, Maintenance Superintendent-
- D. Stump, Mechanical Maintenance Technical Support
'*A. F. Batts Quality Assurance D. N. Smith, Performance Test Engineer
- R. Banner, Compliance G. A. Copp, Maintenance Engineer / Planning l
K. Reeca, Unit 1 General Supervisor Instrumentation and Electrical (IAE)
W. Diel,: Unit 2 IAE R. McCutchen, Environmental. Qualification Coordinator D. E. Simmons, Mechanical Maintenance Support Engineer T. Bumgarner, Production Specialist G. Halbrooks, Associate Engineer NRC Resident Inspectors W. T. Orders, Senior Resident Inspector
- S. Guenther, Resident Inspector
- D. J. Nelson, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on October 23, 1987,
-!
with 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 369, 370/87-40-01:
Maintenance Deficiencies, l
paragraph 6c.
j Inspector Followup ' tem.369, 370/87-40-02:
PORV Corrections, paragraph 3.
The licensee did not identify as proprietary any of the materials provided I
to or reviewed by the inspector during this inspection.
!
!
F1
..
-
r___-_.
_ - _
_ _ _ _ _ __-
.
3.
Licensee Action on Previous Enforcement Matters (0 pen) Unresolved Item (370/87-37-01):
Valve Failed to Operate.
This item identified the following concerns with regard to the valve stroke timing observed by the NRC inspector during NRC. Inspection 369, 370/87-37:
(a) Although valve 2RN-231 failed to indicate ine correct movement to open in its first actuation, the licensee considered that the valve performed acceptably.
The performance test engineer stated that this type of valve had a history of not tripping the second limit switch.
A work request (WR) was issued to check the valve within two weeks.
The NRC inspector questioned whether that long a delay in verifying correct valve operation was acceptable.
The Unit was operating in Mode 1 and the valve in question was the decay heat removal pump 2B cooler isolation valve.
i (b) When the computer measured stroke times to the nearest tenth of a second, the last digit was virtually always even.
This suggested a possible inaccuracy in the data generated.
This was
-
true for 55 of 57 recorded measurements and 11 of 11 observed
!
measurements (66 of 68 total).
Of less statistical significance, all five times measured by the NRC inspector using the licensee's stopwatch, ended with odd numbers.
.
(c) The stroke time obtained by the inspector for valve -2RN-279
differed from that measured by the licensee by 4.3 seconds. The i
error appeared too large to explain as manual timing errors.
l I
With regard to (a) above, the NRC inspector questioned the performance I
test engineer at the beginning of the inspection (October 19) as to
]
whether information supporting their decision to accept the valve performance was ready for NRC review. The inspector was informed that it i
was not.
On October 22, the inspector was provided a copy of the WR (#87851) which checked the performance of the valve following the failed valve test.
The WR did not indicate any check of the valve beyond additional stroking.
The WR record entry stated that the valve operated satisfactorily when operated five or six times.
The NRC inspector questioned whether the licensee had ' adequately verified the condition of the valve, The inspector was never provided any historical or other data j
supporting the licensee's contention that this valve had operated properly during the failed test.
With regard to (b), the licensee. explained that their computer determined i
stroke times through 1/5 second counts, such that computer measured times would always end in even tenths of a second.
The few odd digit stroke times observed by the inspector in the licensee's records were said to have probably been obtained through stopwatch measurements. The inspector accepted the licensee's explanation relative to (b).
_ _ - _ - _ _ - _ _ - _. --
_
. _ _
_
_ _ - _
_ _ _ - _ _ _ - _ - _ - _ - _ _ _.
_ _ _ _ _ _ _ _ _ _ _ _
.
With regard to (c), the inspector.was inf' ormed that the difference the inspector observed could be due to thel fact that the. computer may have
_
measured the end of the valve' stroke to a different limit switch than that used by the inspector (the inspector used the -indicator light on the licensee's control panel). The inspector noted that if'such differences-existed they should be accounted for in the. licensee's procedures..The inspector accepts the licensee's explanation for the stopwatch versus computer stroke time difference.
However, the licensee's procedures permit stopwatch timing (wh'en _the computer is not available) but do not.
provide for recognition of the differences in-times determined by stopwatch versus computer.
This apparent 1y' could result in inaccurate trending or determination of acceptable stroke time. The significance of this difference will be examined in a subsequent NRC inspection addressing this unresolved item.
This unresolved utem will remain open pending(further NRC inspection of the continued matters of concern relative to a) and (c),-'as. described above.
In reviewing the above items, the inspector noted that the licensee did not provide for periodic calibration of their stopwatches.
Licensee pe*sonnel stated that periodic. calibration was considered unnecessary in that a stopwatch which was at all operable would not have significant inaccuracy.
The inspector indicated that, while he intuitively believed that their contention with regard to stopwatch errors was correct, he would check further on the matter.
'
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.
An unresolved item identified during this inspection is discussed in paragraph 6.
5.
PowerOperatedReliefValve(PORV) Modifications (73756)
Changes which the licensee has made in the packing of their PORVs have I
resulted in increased stem friction during _ valve position changes.
The valves open slower, but acceptably, as a result of the packing changes, and appear to satisfactorily accomplish their opening safety functions.
The PORVs do not have any safety functions specified which require closure, however, it is clearly desirable that they close when no longer needed following actuation.
Closure force is provided by valve springs, air pressure and flow through the valves. The air pressure is provided by a non-seismic air system and it is the NRC inspector's understanding that the PORVs were intended to be capable of closure without the air pressure.
Recent tests performed by the licensee found that most of the PORVs would not close solely on spring force.
The test did not include flow and it was uncertain as to whether flow would have caused the valves to close.
Licensee personnel indicated that they were taking three actions to assure that the PORVs would close without the air system:
,
.
_ _ _ _ _. _
_ _ _ - _
.___________._____u_-
_ -. _ _ _ _ _ -
___-_a
-. -
_.2..a__.
m_
__ __
._,_m
____.__ _. _ _ _. _
__..,_o___
__
A
._.-_-_.i_.__mm..
_m_._ ;;
.
.
1 a.
A seismically designed nitrogen supply was being installed on
'
two of the three PORVs in each unit.
b.
Packing changes to reduce friction.
c.
A design check to determine if flow forces would be sufficient
,
(in addition to spring force) to assure closure, 'or.to determine:
if other changes are required.
The inspector. informed the' licensee that their corrections to! insure PORV
]
closure would be identified as Inspector Followup Item 369, 370/87-40-01, PORV Corrections.
6.
Maintenance
.
.
The NRC inspector began a review of the licensee's maintenance program'and
!
its implementation during NRC Inspection 369, 370/87-37. That review was continued in the -current inspection.
The review conducted during the current inspection and the inspector's findings are described below, a.
Prog' ram (62702)
The inspector reviewed aspects of the licensee's maintenance program.
to verify their conformance with technical specifications, regulatory requirements, licensee commitments and industry guides and standards.
The inspector's review is described below:
(1) The inspector reviewed maintenance program related requirements described in the following procedures:
Procedure No.
Revision Ti tle
'
MMP 4.0
Definition of Preventative Maintenance Program SD 3.11.0
Housekeeping and Cleanliness SD 3.11.1
Housekeeping and Material
'
Condition APM S 3.11
Housekeeping-1
<
Process Spec. L-900 18_
Post Weld Heat Treatment.
.q Process Spec. L-1000
Performance Qualification q
Control of Welding and Heat SD 3.3.1
-
Treatment
)
J
Equipment Qualification.
-
Reference Index i
- -
_ _ _ _
_ _ _ _ _ _ _ - -
._
_ - - _
. - - _
-_ ___--___- __ _ _
_,
, -
.
'5
<
(cont'd)
Procedure'No.
Revision Title CDB-8
Completion.of PQR Forms Quality' Control Procedures..
-
-
Manual (Current revisions'of procedures identified E-1, E-2, F-3 F-4,.G-1, G-3,-L-4, L-10, F-1 and F-5)
(2) PreventativeMaintenance(PM)
The inspector reviewed. the above listed procedures.to verify that a written PM program for. safety-related structures, systems, and components has been established to include:
.)
(a)
responsibility for the program (b) master schedule for'PM (c) documentation and review of completion of PM activities (d)
responsibilities and methods for establishing PM frequencies (e) responsibility for periodic upgrading based on system or component failures (f) methods for -incorporating revisions to TS into procedures and the master program (3) Special Processes The inspector reviewed the above listed procedures and discussed-j them with cognizant licensee personnel to:
J (a) Verify that administrative controls for special processes j
have been established as follows.
,
requirements that only qualified procedures will be;
-
used are specified
i requirements that only qualified. personnel. will be
-
used are specified requirements that a current file of special processes
-
will be maintained to include qualification records-of procedures and personnel are specified i
(b) Verify that responsibilities have been assigned to assure that the requirements identified in (a) will be accomplished.
___-__-_________:-_-__-
_
_ - _ _
_
_
__
_
'
.
(4) Cleanliness. Controls The inspector reviewed the procedures listed in (1) to:
(a) Verify that procedures have been developed for cleaning safety-related components and systems.
'
(b) Verify that procedures have been. established for maintaining the cleanliness of.'previously cleaned systems.
(c) Verify that the. cleanliness classifications of plant systems have been established.
Verify that res for. implementing the (d)
requirementsof(ponsibilitiesa) and (b)'have been established.
(5) Housekeeping Controls The inspector reviewed the. procedures listed in (1) to verify that administrative controls and responsibilities for general housekeeping have been established to include:
(a) defining housekeeping zones (b) controlling housekeeping during work activities b.
Program Implementation (62700)
The NRC inspector reviewed in-progress work and documentation associated with the licensee's implementation of their maintenance program to determine whether:
the program is implemented in accordance with regulatory requirements, the effectiveness of the program on important plant equipment, and the ability of the maintenance staff to conduct an effective maintenance program.
The inspector's review is described below.
(1) Records The inspector reviewed records associated.with - completed maintenance activities described on the following Work Requests.
(WRs):
Work Request Activity Specified 130510 Repair valve 1RN134 seat leak 67358 Remove operator from valve IRN134, rebuild operator, changing out and replacing grease, and perform bench test to verify torque output
_ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ - _ _ _ _ _ _ -
- -
- _ _ - - _ _
_
_
_
-.
-
_
_
_ _,
_
.
(cont'd)
Work Request Activity Specified-122216
' Investigate and' adjust valve stroke and/or travel on valve IRN134 87851 Investigate and repair cause of length of stroke time on valve 2RN231B'.
85917 Investigate and/or repair problem with
. limit switches on valve IND34 128865 Reduce packing leaks and adjust limit switches on valve 2ND34 NOTES:
1.
The NRC inspector requested that licensee _
personnel identify and provide examples of-their.
~
completed maintenance WRs for. each of the following categories:
safety-related equipment failure leading to
-
a plant shutdown nonsafety-related equipment. failure leading
-
to a plant shutdown equipment failure leading to reduced
-
capability of'a safety-related system-recurring safety-related equipment _ failure-
-
Licensee personnel did not provide any of the requested examples.
They indicated they were unable to' complete identification and retrieval of the indicated examples.
2.
WR 130510 was previously' reviewed during Inspection 369, 370/87-37 and was checked again during the current inspection.
The above records.were reviewed by the inspector to determine,.
as applicable to the work performed, whether:
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 adequate for the scope of the maintenance performed.-
_ _ _ _ - _ _ _ _ _ _
_ _ _ _ _ - - _
_ _ _ _
-.
'i
'
was controlled and kept up-to-date -(quipment under repair-The ' vendor technical manual for the e 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 procedures.
Periodic surveillance testing. associated with the selected i
failed equipment provided 'an indication of 4mpending failure.
Required admin'istrative: approvals were obtained.before -
initiating the work.
Limiting conditions for.' operation were met while the component or system was removed from service.
Approved procedures were~ used where the activity appeared to exceed the normal skills possessed by qualified maintenance personnel.
Inspections were made inaccordance with the licensee's requirements, and quality control records were complete.
Corrective and preventative maintenance records were assembled and stored as part of the maintenance history.
The measuring and test equipment (M&TE) used was identified and in calibration.
Parts and materials used were identified and at least met the specifications of the original equipment.
(2) Procedures The inspector reviewed.the licensee's preventative maintenance program to verify the following:
(a) A master schedule is available.
(b) A lubrication control system ' is available - and kept
up-to-date.
(3) Observation of Maintenance' Activity The inspector observed maintenance being performed on WR 67360
(maintenance replacement of grease on valve.1RN174 operator) to i
verify that:
l i
a
- -._ - __ -
~
.
(a) Maintenance personnel assigned understood the scope of the job.
(b) Applicable parts of items referred to in (1) above were satisfied for the work in progress.
(c) The technicians were qualified for their respective tasks.
(d) Supervisory oversight of the work was adequate.
(e) QC personnel assigned were knowledgeable of the task.
c.
NRC Inspector's Findings The following is a listing and description of apparent deficiencies that the inspector identified in the licensee's maintenance program and its implementation during Inspection 369, 370/87-37 and during the current inspection.
(1) The work did not appear to be well-planned.
Procedures specified for use and sequences of work specified were often not used or were changed in the course of work (e.g., in WR 85917, 87851, 130510 and 87550).
Testing requirements were not well described (e.g. 130510 leak check).
,
(2) The licensee's WR procedures (MMP 1.0 and 1.1) require that all
'
maintenance actions be described in Section V of the WP.,
The procedures do not require that individuals sign the entries they make.
This makes it difficult to obtain clarification of the
'
recorded information when the need arises.
For example, the inspector noted an entry on WR 128865 which required clarification as described in Inspector Followup Item 370/87-37-02.
Licensee personnel indicated that maintenance personnel have been instructed to sign and date their entries
l and acknowledged that some individuals were still not doing so.
The inspector commented that the appropriate place for such a requirement to be stated was in the MMPs 1.0 and 1.1.
In addition to WR 128865, the inspector observed unsigned, undated
'
entries on WRs 13150, 67358 and 122216.
(3) Maintenance personnel sometimes did not number WR pages or
,
I indicate what work sequence they were accomplishing in their WR entries. Examples were noted on WRs 67358 and 130510.
(4) The equipment failure or degradation requiring repair and its cause were not adequately described in the WR (e.g., WR130510).
(5) Some of the procedures used contained figures that were partly illegible (e.g., IP/0/A/3066/0/A).
,
u--_____________
_ _ _ _ _ _ _ _ _ _ _. _ _ _. _ _ _. _ _ _ _ _ _. _ _ _ _ _.. _ _ _ _ _ _ _. _ _ _. _ _ _. _. _ _._
_. _ _. _ _ _ _ _ _ _ _ __
-.J
--__
h
<
i" (6) Some of the procedures contained steps that appeared excessivel,"
complex and difficult to use from a human factors stand point (e.g.,IP/0/A/3066/0/A).
I (7) Procedure MP/0/A/7600/95 contained the following deficiencies:
l
-
Section 11.3.8 refers the user to a note on a drawing that
)
is not a part of the procedure.
The note is short and should be stated in 11.3.8.
Section 11.7.8 requires a seat leakage test but does not
-
provide or reference any criteria for test performance or
)
determining valve acceptability.
(8) The actual maintenance performed under WR 130510 was complex, involving many changes to the original item (e.g., different
>
valve body, body material repairs, seat replacement, gearbox modifications, etc.) and the WR entries describing the maintenance actions were difficult to understand.
Any future
review of equipment maintenance history for maintenance work or l
for failure evaluations relative to this valve would be
'
difficult due to inadequacies in the WR entries.
The licensee's WR procedures do not provide for any written summarizing of such work by cognizant technical personnel.
Further requirements for a review to assure that the maintenance actions are adequately recorded are not clearly specified in the l
WR procedures.
Individuals recording entries may not be proficient at completely and accurately recording a description of the maintenance performed and the entries may be made under l
schedule pressures which do not encourage adequate recording.
(9) Procedure MMP 1.0 requires the planned sequence of maintenance l
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 the skill designations listed in WR 130510 was not described in MMP 1.0.
This was skill MW, which the inspector was informed was maintenance welding.
The NRC inspector informed the licensee that the principal concerns relative to the above deficiencies were:
,
-
Maintenance work and findings were not being documented with I
sufficient accuracy and detail for use in understanding, trending and properly addressing equipment degradation and
'
l failures; or for evaluating and improving maintenance practices l
and procedures.
Causes of failures and excessive degradation were not adequately described and may not have been adequately l
investigated.
_
__.
.
E i
>
.
,
Procedures sometimes did not provide an adequate description of'
-
special test requirements, procedural steps appeared excessively long and complex (human factors) and figures were riot always fully legible.
Individuals who made significant entries of record information
-
on WRs could not always be identified (because of. failures to sign and date their entries).
Such reviews of WRs as were performed by the licensee did not
-
assure accurate, understandable records entries.
The inspector was informed that an Institute for Nuclear Power Operations (INPO) audit completed in April 1987 had identified two findings which were being responded to and would address most of the-inspector's concerns. The INP0 findings involved the adequacy of the licensee's specification of post-maintenance testing; their root cause analysis; and their identification, analysis and trending of maintenance problems.
l Cognizant licensee personnel informed the NRC inspector that their
'
corrective actions relative to the INP0 findings would be completed in January 1988.
The inspector stated that the licensee's actions would be examined to determine if they adequately address the above concerns and identified this matter as Unresolved Item 369, 370/87-40-01, Maintenance Deficiencies.
l Within the areas examined, no violations or deviations were identified.
7.
Inspector Followup Items (IFIs)
(Closed) IFI (370/87-37-02):
Work Request Question. This item expressed a concern regarding an entry made by licensee personnel on the WR 128865.
The entry, which was apparently made af ter the completion of corrective maintenance and acceptance testing of valve 2ND34, stated that " control l
room says valve won't close." The entry, which was unsigned and undated, suggested that the valve was not working acceptably.
During the current inspection, the NRC inspector was informed that the entry apparently was intended to indicate that the valve could not be closed at the time because flow through it was needed for the operating condition.
The inspector reviewed subsequently performed records of stroke time testing on the valve to verify its proper operation. The NRC inspector accepted the licensee's explanation for the Work Request entry and the matter is considered closed for this item.
Unresolved Item 369, 370/87-40-01, as described in paragraph 6 above, addresses concerns that WR entries are sometimes inaccurate and are not signed.
__ ____________