IR 05000373/1985032

Insp Repts 50-373/85-32 & 50-374/85-33 on 851001-1219.No Violation or Deviation Noted.Major Areas inspected:in-depth Assessment of Maint Activities

ML20136D488
Person / Time
Site:	LaSalle
Issue date:	12/30/1985
From:	Choules N, Hawkins F, Thomas Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136D483	List: IR 05000373/1985032 ML20136D478
References
50-373-85-32, 50-374-85-33, NUDOCS 8601060183
Download: ML20136D488 (9)

Text

t e e y U.S. NUCLEAR REGULATORY COMMISSION

REGION III

3D Reports'No. 50-373/85032(DRS);50-374/85033(DRS)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Commonwealth Edison Company P. O. Box 767

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Chicago IL 60690 Facility Name: LaSalle County Station, Units 1 and 2 Inspection At: LaSalle Site, Marseilles, IL

. Inspection Conducted: October 1-4, 17-18, 22-24, 29-31, November 1, 18-22, and December 5 and 19, 1985 Inspectors: h l1- 3 QM Date

. %wa T. E. Taylor

\W it-30 c4F

Date

'i ins,CAlef(4 n - % o,9p Approved By: i Quality Assurance Programs Section Date Inspection Summary Inspection on October 1-4, 17-18, 22-24, 29-31, November 1, 18-22 and

December 5 and 19, 1985 (Reports No. 50-373/85032(DRS); 50-374/85033(DRS))

Areas Inspected: Special, announced in-depth assessment by two regional inspectors of maintenance activities. The assessment involved 206 inspector-hours onsit Results: No violations or deviations were identifie B601060183'B5123113 DR ADOCK 05(

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DETAILS

] Persons Contacted Commonwealth Edison Personnel CECO

• G. Diederich, Station Manager

• C. Sargent, Production Superintendent

• R. Bishop, Services Superintendent

• L. William, Quality Control Coordinator W. Huntington, Assistant Operating Superintendent

• W. Sheldon, Assistant Maintenance Superintendent

- J. Kodrick, Maintenance Staff

• J. Williams, Master Mechar,ic

• M. Santic, Master Instrument Mechanic

• H. Mulderink, Master Electrician

• R. Morley, Electrical Foreman

• D. Berkman, Assistant Superintendent Technical Services

• L. Rainey, Supervisor, Office of Nuclear Safety R. Jeisy, Station Quality Assurance Supervisor

• R. Clark, Quality Control Supervisor

• R. Vincer, Maintenance Training

• C. Stanford, Assistant Storekeeper P. Manning, Technical Staff Supervisor US NRC

• L. Reyes, Chief, Operations Branch

• F. Hawkins, Chief, Quality Assurance Programs Section M. Jordan, Senior Resident Inspector

• J. Bjorgen, Resident Inspector

• R. Kopriva, Resident Inspector Other personnel were contacted as a matter of routine during the inspectio * Denotes those attending the exit interview on Deceraber 5,1985 Maintenance Assessment Inspection Methodology The purpose of this inspection was to provide an in-depth assessment of the licensee's maintenance program and its implementation. This inspection was prompted by the importance of maintenance activities in maintaining plant integrity and the indication of potential weaknesses in maintenance activities at LaSalle as evidenced by an increasing number of maintenance related problems identified i LicenseeEventReports(LERs),DeviationReports(DVRs),andNRC

Inspection Reports.

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The inspection consisted of approximately 60 interviews with Maintenance, Operations, Quality Control, Quality Assurance, Training, and Technical Staff personnel; observation of in progress work activities; attendance at planning meetings, and training sessions; and review of work requests, procedures, LERs, and other records associated with maintenance, b. Observations (1) Personnel Training and Experience (a) Interviews and review of maintenance personnel training records indicated that training received by maintenance personnel appeared to be marginal. For example, union maintenance employees receive basic generic training cn instrumentation, mechanical, and electrical devices, at Commonwealth Edison's Production Training Center (PTC).

The PTC training does not address specific plant equipment installed at LaSalle, and retraining is very limite (b) In general, the' average experience level of maintenance mechanics, electricians, and instrument technicians appeared to be relatively low: they typically had an associates degree with two to six years of working experienc One specific example was noted where plant personnel expressed reservation regarding new assignments because of their relative inexperience and minimal training relating to the responsibilities of their new position. Some Control System Technicians (CSTs) and "A" level instrument mechanics expressed concern with the qualification process through which an "A" level instrument mechanic becomes a CST. At LaSalle, CSTs work on instrumentation that has the potential to scram the reactor. The "A" instrument mechanics receive some training on this instrumentation prior to=becoming CSTs, however, personnel indicated that this traiqing did i not adequately _ familiarize them with the instrumentation and that a more comprehensive program of " hands on" equipment familiarization was needed prior to becoming a l CST.

I The relative inexperience of the maintenance personnel

! may in part be contributing to the observed maintenance errors at LaSalle. More extensive training and increased l

supervision may reduce these occurrence (c) Interviews and review of training records revealed that some maintenance foremen were performing their duties l

! without the benefit of basic general naintenance PTC training. As a rule, the background of these foremen was l

not plant maintenance oriented and their effectiveness could be compromised through their limited maintenance l

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knowledge. Training of this type would provide all maintenance personnel, including foreman, a common ground from which tc work and comunicat i

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(d) Through interviews, the inspectors determined that union maintenance personnel received limited training regarding the DVR system, the work request system end the functional role of the quality assurance department. An increased awareness is essential to ensure an appropriate appreciation for these processe (e) The licensee is revising the training program for INP0 accreditation. The new training program will include training on specific LaSalle plant equipment. The licensee has assessed the training needs of all maintenance personnel relative to their assigned tasks, and plans to conduct training relative to their needs. The INP0 accreditation should greatly improve the training received by maintenance personne (2) Comunication (a) Several maintenance personnel stated that communication, both within and between departments at LaSalle, was not always satisfactory. Specifically, personnel indicated that communication between foreman and technicians was good, but that communication was relatively poor between foreman and higher levels of supervision. The breaker malfunction associated with the Diesel Generator No. 2B cooling pump, documented in NRC Inspection Reports No. 50-373/85033, 50-374/85034, appears to be indicative of problems which could be precluded through better communicatio (b) During interviews, several personnel commented that maintenance supervisory personnel above the foreman level were seldom seen in the field. It was the individual's consensus of opinion that better accessibility of supervisory personnel, such as the master mechanic and assistant superintendent of maintenance would promote

better comunication by fostering a more open exchange of information and improve the supervisors' awareness of maintenance personnel work practices. The assistant (

i superintendent of maintenance acknowledged the importance of increased visibility in the field and indicated that he was attempting to accomplish it.

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(3) fiaintenance Support Groups

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l (a) Based on personnel interviews, it appeared that the Radiation Protection groups support of maintenance activities could be more efficient. Many licensee personnel indicated delays in both the conduct of radiation surveys, and the issuance of radiation work permits and dosimetry. While touring the plant the NRC inspectors also encountered a delay for receipt of a pocket dosimeter while they were being zerced. Contractor

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personnel indicated this to be a particularly common occurrence at the beginning of the work shift. The licensee is taking measures to improve radiation protection services. Better preplanning of work activities and enlargement of the area for issuance of dosimetry have resulted in some improvemen (b) A review of LER's, DRs, and maintenance activities indicates that the plant technical staff, departmental management, corporate nuclear engineering department, and the architech/ engineer all contribute in part to maintenance errors by making improper decisions, and providing inaccurate procedures and other documents. The following are examples: (1) fabrication and installation of a component for one of the scram discharge volume vent valves without proper engineering evaluation; (2) technical staff direction of maintenance involving a jumper installation resulting in shut down cooling isolation while the plant was shut down ; (3) interviews and observations of the diesel generator pre-lube modification activity indicated a lack of adequate pre-planning for the modification which resulted in several changes to the modificatio (4) Maintenance Programs (a) With the exception of the preventive maintenance (PM),

work request (WR), maintenance history, and lubrication control programs, the majority of the licensee's maintenance programs contained the essential technical and administrative element (b) The present scope of the PM program does not ensure that

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all equipment required for safe reliable plant operation is systematically inspected, cleaned, lubricated, tested, and adjusted as necessary. The PM program is not well defined, in that it is segmented into several program PM scheduling is presently performed by each maintenance discipline rather than having one individual responsible *

for scheduling of all PM activities. Appointing one l

responsible individual would provide a cohesive element to t the program and improve its administratio The licensee's maintenance program is essentially corrective in nature. This approach leads to a reduced plant reliability because, as a rule, equipment is not effectively serviced except when it fails. Even though some aspects of

the present program predict equipment failures, systematic l

redirection of the present corrective maintenance philosophy to a more predictive preventive maintenance approach would provide improved plant reliability.

I (c) At the time of this inspection, there were approximately l

' 2800 outstanding WR's at LaSalle. This number of WR's

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when compared to other nuclear facilities appeared excessiv Further review indicated that not all WR's had been categorized in relation to their relative importance to plant operation. Licensee personnel acknowledged this concern and stated that they intend to review and more effectively categorize the WR backlo ~

(d) The licensee is in the process of developing a good maintenance history program. The present program now has the ability to recall WR information by equipment identification number for history and trending purpose The trending program is currently structured to identify trends based on individual component failures within specific plant systems. This type of trending does not identify failures of specific equipment types which are common to several plant systems. The licensee is in the process of addressing this issue. This item is considered open pending further review (373/85032-01; 374/85033-01).

(e) Review of the lubricant control program identified a need for better identification of lubricants in the storeroom.

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Also, it appeared that better access control to the operations lubricant storage area was warranted. The licensee indicated the measures will be taken to improve these items. This is considered an open item (373/85032-02; 374/85033-02).

(5) Procedures (a) Interviews with personnel indicated that instrument department procedures could be more explicit. Also, operations personnel indicated that the electrical department surveillance procedures could be improved to provide more consistently accurate detail. Several of these procedures are currently being revised by the

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license (b) Review of procedure indexes indicated that more attention should be focused en issuance of additional routine maintenance procedures. Some of the routine maintenance activity instructions are written and attached to work requests on a " Figure 9" document. The " Figure 9" is a docunent for temporary instructions which must be approved prior to each use. Conversion of these instructions into routine procedures, which are not approved before each use, would reduce delays and confusio i

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(6) Control of Maintenance Activities Interviews with operations personnel indicated that control room personnel are not always informed of the status of work activities which continue beyond one shift. An example of this was when the inspectors observed a portion of a reactor protection system relay logic work activity in progress in the control room back panel area. The next day the inspectors inquired abcut the status of this work activity. Neither the shift control room engineer (SCRE) nor the shift supervisor could give the current status of the activity. Further inquiry determined that some testing remained to be complete It should be noted that the plant was shut down at this tim Effective communication between the control room and personnel involved in maintenance activities is an essential element for proper control of plant operation (7) Observation of Maintenance Activities _

(a) The inspectors performed several plant tours during which they observed a number of work activities. These included the hydrogen recombiner modification, test of the standby liquid control (SBLC) relief valves, reactor protection system relay logic modification, a diesel generator pre-lube modification, LLRT on various RHR valves, and operability test for reactor recirculation (RR) motor generator (MG) set 1B breaker 2 In general, the radiation protection controls appeared adequate, and procedures and work requests for the activities were of sufficient detail and being used at the work site. With the exception of the MG set work, the individuals directing the work activities were knowledgeable of the equipment involved and the work to be accomplishe While working on the RR MG set, licensee personnel encountered a problem when attempting to put the breaker in the test position. During resolution of the problem, it became evident that the "A" electrician performing the test was not familiar with the specific breaker. While the appropriate level of knowledge of breaker's operation required to perform the testing is somewhat subjective, the inspectors feel that this instance may be indicative of shortcomings in the licensee's present program to familize maintenance personnel with specific plant equipmen (b) The inspectors also noted several examples of poor housekeeping and work practices: (1) In ccntainment, several broken flexible conduits and crcshed pipe insulation were observed (Reference NRC Inspection Report No. 373/85034, 374/85035); (2) A standby liquid control l

(SBLC) line opening was not covered when a relief valve was removed for testing; (3) The housekeeping in the

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I demineralizer waste caustic area was very poor; (4)

Several instances of yellow plastic bags and tape on the floor were observed in many non-work areas; and (5) An instrument rack area where several pieces of metal tubing, rubber tubing, tube fittings, and debris covered the floor. As a rule, while housekeeping practices do not have direct impact on safe operation of the plant, poor practices in this area are indicative of management effectiveness to ensure personnel are motivated and take pride in their wor (c) Interviews with maintenance management personnel indicated that worker productivity was somewhat low. While on tours of the maintenance shop areas, it appeared in several instances that maintenance personnel were not productively working. LaSalle presently has a very large maintenance workload. With more effective supervision and planning, the productivity of maintenance personnel could be enhance (d) The inspectors also noted that maintenance work activities were not always effectively scheduled. The licensee has revised the manner in which activities are scheduled, and improvements are being made in this are (e) During the observation of work activities, the inspectors asked to review the operability test data for the diesel generator cooling pump breaker associated with WR 5256 Licensee personnel were unable to locate the data which verified the breaker's 1600 amperage trip poin On December 19, 1985, the NRC inspector observed the licensee's actions to resolve this issue. The licensee's work resulted in the installation of a satisfactorily calibrated breaker. Specific details regarding their actions are documented in NRC Inspection Report No. 50-85038, 50-85039.

, Conclusions and Recommendations

The inspectors concluded that although the licensee has identified many of the maintenance problems and is taking corrective action, further corrective measures are required to expeditiously reduce the work request backlog, further improve the PM program, and fully develop the maintenance history program. In addition, the inspectors have concluded through discussions with the licensee personnel, observation of work activities, and review of related documentation that the experience level of personnel, engineering and maintenance management support, and the maintenance training program have contributed significantly to the observed maintenance problems at the LaSalle Station. Consideration should be given to the following recommendations.

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! Perform an evaluation to asses the effectiveness of management activities relative to the engineering support organization (plant technical staff, station nuclear engineering department, and the architect / engineer), radiation protection organization, and the maintenance department to ensure that maintenance personnel receive correct information, appropriate support and guidance to perform their assigned dutie Expedite the statusing and reduction of the work request backlo Evaluate the effectiveness of the PM program. Increase the scope of the program, consolidate program responsibilities, and effect changes to the scheduling syste Provide adequate resources to implement a comprehensive training program to ensure all maintenance personnel receive adequate technical and administrative training required to perform their activitie Improve communications between union maintenance employees and maintenance management, between maintenance and operations, and between maintenance groups within the maintenance organization.

j Provide more effective supervision and planning to improve personnel i

motivation and productivit Continue to improve the scheduling of work activities. Review frequently used Figure 9 documents, and prepare and approve routine maintenance procedures as applicabl Expedite implementation of an effective maintenance history and trending progra . Review, evaluate and revise as necessary instrument and electrical department surveillance procedures to ensure appropriate accuracy and detail.

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4. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or both. Two open items were disclosed

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during this' inspectio . Exit Interview The inspectors met with licensee representatives listed in Paragraph 1, on December 5, 1985, and summarized the purpose, scope and findings of

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! the assessment. The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the assessment. The licensee did not identify any such documents or processes as proprietar !

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