IR 05000382/1993029
| ML20059E164 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/27/1993 |
| From: | Constable G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059E148 | List: |
| References | |
| 50-382-93-29, NUDOCS 9311030115 | |
| Download: ML20059E164 (19) | |
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i APPENDIX B
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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'P inspection Report:
50-382/93-29
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License: NPF-38
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Licensee:
Entergy_ Operations, Inc.
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P.O. Box B Killona, Louisiana Facility Name:
Waterford Steam Electric Station, Unit 3 (W3)
Inspection At: W3, Taft, Louisiana Inspection Conducted:
September 13-17 and September 27 through October 1, 1993 Inspectors:
M. E. Murphy, Reactor Inspector, Plant Support Section
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Division of Reactor Safety, Region IV
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D. J. Kelley, Reactor Inspector, Maintenance Section'
Division of Reactor Safety, Region IV J. E. Whittemore, Reactor Inspector, Plant Support Section Division of Reactor Safety, Region IV
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L. Smith, Senior Resident Inspector, Arkansas Nuclear One-Project Sectiqn_D, Division of Reactor Projects, Region IV
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/v/21/97 Approved:
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IC L-r Lonstable, Chief, Plant Support Section Date
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Division of Reactor Safety i
Inspection Summary Areas Inspected:
Routine, announced inspection of maintenance, procurement, receipt, storage, and handling of equipment and materials.
Results:
The corrective maintenance activities reviewed appeared to be well
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planned and coordinated (Section 1.1).
The work-packages reviewed were detailed and well documented (Section
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1.1).
9311030115 931028 PDR ADOCK 050003
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t-2-Evaluation of apparent degradations to Technical Specification Equipment
by Operations was not considered to be timely (Section 1.2).
The overall corrective maintenance backlog was small and well
prioritized (Section 1.3).
The lack of testing following a preventive maintenance' activity which
uncoupled the pump from its motor is considered a concern for follow up #
(Section 1.6).
Failure to have an adegaate procedure for initiating reportability
determination resulted in a violation of 10 CFR 50, Appendix B, Criterion V (Section 2.1.2).
A good training practice was observed, involving the display of manway
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gaskets with root causes and lessons learned from the event
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(Section 2.1.2),
The procurement organization and its interface with engineering
functioned to enhance safety related procurement (Section 2.2.2).
The improved Material Management Information System database was
considered to be a strength (Section 2.2.3).
Warehouse operation was considered a strength (Section 2.2.5).
- The lack of policies or requirements addressing the control of safety
related material after issue from the warehouse was considered to be a weakness (Section 2.2.6).
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The lack of control of the authorized signature lists for material
withdrawal was considered to be a weakness (Section 2.2.6).
Summar_y of Inspection Findings:
Inspection Followup Item 382/9329-01 was opened (Section 1.6).
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Violation 382/9329-02 was opened (Section 2.1.2).
Attachments:
Attachment 1 - Persons Contacted and Exit Meeting
Attachment 2 - Documents Reviewed
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l-3-l DETAILS
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1 MAINTENANCE OBSERVATION (62700)
The purpose of this part of the inspection was to determine that the licensee's corrective maintenance was being implemented in accordance with
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regulatory requirements and maintenance personnel were effectively controlling
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and performing corrective maintenance.
I 1.1 Discussion The inspectors selected 11 completed corrective maintenance work packages of work performed on safety related components (see Attachment 2). A detailed review of these packages was performed to determine if the maintenance activities contained the following control elements; The procedures and instructions included in the corrective maintenance
work packages were adequate and of sufficient detail for the work that was performed; The vendor maintenance recommendations, when used, were correctly
translated into or referenced by the maintenance procedures or work instructions included in the maintenance work packages; lhe required reviews and administrative approvals were obtained prior to
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commencing the work activities; Approved procedures or detailed work instructions were used where
maintenance activities were complex and appeared to exceed the normal skills of maintenance personnel; The causes of the failure of components were evaluated, and adequate
corrective action was taken to reduce the probability of recurrence; The records showed that equipment was properly tagged out when removed
from service and tagging was properly removed and verified when equipment was returned to service; Any measuring and test equipment used was properly identified and was in
calibration; Quality control points were included where required, and were signed or
initialed indicating that work was performed in accordance with the licensee's quality requirements; and Post-maintenance testing and operability testing, as necessary, were
completed before the equipment was returned to service.
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The work packages were thorough. The inspectors noted the work packages contained complete equipment identification, problem description, tagging
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requirements, drawing numbers, parts information, quality control points, post-maintenance and operability testing requirements as needed, work procedures or instructions, wire determination \\ termination check lists, torquing data, measurement and test equipment identification and restoration instructions. The inspectors noted that detailed procedures were provided for
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those evolutuns that were beyond "the skill of the craft."
Although there was no inspection of corrective maintenance procedures or program elements, the level of detail of the work packages indicated that a well founded system for the control and performance of corrective maintenance appeared to be in place. One minor observation was noted in that the failure cause section of the work package.could have been improved if more detail were provided.
For instance, one of several examples indicated "cause" to be a gasket failure.
It would have been helpful to understand the reasons for the gasket failure in order to determine whether the problem was with material or installation techniques.
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1.2 Prioritization of Emercent Work The inspectors attended plan of the day meetings, operations turnovers, and reviewed operating logs.
Emerging examples of degraded equipment were identified. The prioritizations of the work activities necessary to return the equipment to normal were evaluated. The majority of the items reviewed i
were appropriately dispositioned; however, two areas of concern were identified.
On September 10, 1993, the Low Pressure Safety Injection Pump A ~ Minimum Flow Recirc Valve SI-ISV1161 failed to meet the inservice testing stroke time of 2.0 seconds. The recorded stroke time was 2.7 seconds.
Condition Identification (CI) 287265 was initiated for engineering to evaluate this condition. The system was not determined'to be inoperable. The licensee stated the function of the valve is to close when the system is in the recirculation mode following an accident. The item was given a priority of T2, which means the item is Technical Specification related and should be resolved within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An equipment out-of-service checklist was generated to track the required retesting. On September 14, the limit switches were adjusted.
The stroke time was remeasured and determined to actually be.9 seconds. The inspectors reviewed the maintenance instruction for adjusting the limit switch and the associated vendor literature.
The limit switches were returned to their design configuration by the adjustment and, therefore, the second test result of.9 seconds was determined to be valid. However, the
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Teilure to resolve an apparent acceptance criteria failure for 4 days was considered to be a weakness.
Similarly, on September 13 Containment Spray Valve CS-125A was determined to be inoperable after failing to stroke open. A hydraulic lock was suspected.
The header was vented.
The valve was declared operable and a CI was written
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-5-for engineering to evaluate the failure of the valve to open against design differential pressure. The CI was given a priority of T4, which means the item is Technical Specification related and should be resolved within 7 days.
The valve was eventually determined to be inoperable on September 25.
Additional inspection of this event will be documented in NRC Inspection Report 50-382/93-33.
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1.3.Prioritization of the Corrective Maintenance Backloa The backlog of maintenance items over one year old was reviewed to assess plant material condition, imediate compensatory measures, and the priorities assigned to closure of the items. The size of the backlog was reasonable.
Appropriate compensatory measures had been taken for all items evaluated except Boric Acid Makeup Pump A (BAM A).
Subsequent review of the maintenance history of BAM A, however, determined that compensatory measures were not required. The BAM A motor had shown indications of apparent degradation during a routine in service vibration analysis inspection in 1989. The licensee's review of previous data did not indicate imminent failure and the corrective action was to increase the inspection frequency and procure a replacement motor. These inspections have not indicated any deterioration in the pump or motor and replacement was assigned a low priority. The licensee encountered problems in the procurement of a replacement motor because the specific component was no longer being manufactured. The licensee had recently completed writing a new set of purchase specifications for a replacement motor. The priority system was apparently effective.
1.4 Qperations Control of Maintenance Operations knowledge of ongoing maintenance activities was generally good.
The operators rely heavily on the published schedule; therefore, unscheduled tasks were not tracked as well. The control room supervisor was initially unable to identify an unscheduled task that was in progress when asked by the inspectors.
Control room annunciator control was also evaluated as a means to identify degraded equipment. The operators had a good command of why the annunciators were illuminated. Where appropriate, maintenance activities had been initiated.
One strength was icentified.
A maintenance individual requested to take one of the two emergency diesel generator air start systems out-of-service when the other system was out-of-service for an unrelated activity. The operator responsible for work control promptly said no, which demonstrated good understanding of his available equipment.
1.5 Plant Tours The inspectors toured the plant several times to assess the plant material condition and to ensure problem identification tracking systems were functioning appropriately. A large number of fire impairments were observed
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-6-to exist in the field. The licensee appeared to have them all tracked in the control room with appropriate fire watches established. During an interview, the licensee stated that long-term plans are in progress to repair the impairments during subsequent outages.
Overall plant condition was good.
Some tags were found in the field which had not been appropriately retrieved. No problems were identified that the
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licensee was not currently tracking.
l.6 In-process Test and Maintenance Activities The inspectors observed portions of several maintenance activities:
Replacement of an emergency feedwater pump relay,
Replacement of a charging pump breaker,
Emergency feedwater pump lubrication,
High pressure injection pump lubrication,
Component cooling water radiation monitor calibration,
Trending of emergency diesel generator cylinder pressure, and
Emergency diesel generator lube oil sampling.
- In all cases the craftsmen were knowledgeable. The level of detail in the instructions appeared to be commensurate with the craftsman's knowledge of the equipment. A concern was identified in the area of post-maintenance testing.
The routine inservice performance test for the Emergency feedwater Pump B was run a few days before the pump was taken out-of-service for routine preventive maintenance lubrication which involved decoupling the pump and motor. The licensee had determined that no post-maintenance testing was required following lubrication of the pump even though it involved disassembly of the pump to motor coupling. The failure to schedule the routine inservice test after the routine preventive maintenance was viewed as a weakness by both the inspectors and the licensee. The licensee believed however, that the maintenance task was sufficiently simple so that the associated risk of not testing again was outweighed by the increase in the wear of the pump. The licensee committed to perform a review of industry practice in the area of performing post-maintenance testing following any evolution that required the uncoupling of the pump from the motor to ensure that their practice is within industry norms and that appropriate testing was being performed. The followup inspection of this review will be tracked as Inspection Followup Item 50-382/9329-01.
Calibration., records associated with both measuring and test equipment and installed pv,ucess equipment were requested from the licensee and found to be
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-7-avail able. All equipment was found to be within its current calibration cycle.
Quality Control had not reviewed a revision to the work authorization package for the charging pump breaker replacement, WA 1100859. However, the licensee's procedures allow revisions to essentially repeat instructions without review by Quality Control. Therefore, the licensee's actions were
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determined to be appropriate.
The lube oil used to fill the emergency diesel generator governor system was traceable to the original procurement documents; however, the test requirements in place when the oil was purchased were not as stringent as those identified as critical elements in the current commercial upgrade program. Subsequent review by the inspectors, however, determined that the licensee had in place Maintenance Procedure, UNT-005-007, " Plant Lubrication
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Program," that required periodic random sampling and analysis of open drums of oil. The acceptance criteria for this analysis was to the critical elements in the current commercial upgrade program. Additionally, on the material issue ticket, there was a note that required sampling and analysis to the same i
criteria prior to the use of any of the oil in a safety related component.
1.7 Conclusions The reviewed records indicated that a comprehensive corrective maintenance system was in place and was working well. The documentation was good and management involvement was evident.
In a few cases, more detail should have
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been provided in the failure cause section of the work packages. The process for evaluating apparent degradations to Technical Specification equipment was not timely. The overall corrective maintenance backlog was small and well prioritized. The failure to schedule routine inservice tests after routine preventive maintenance was viewed as a weakness. The inspectors were also concerned about the lack of testing following maintenance activities that uncoupled the pump from the motor.
2 PROCUREMENT (38701)
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This part of the inspection was conducted to evaluate the licensee's response to the steam generator manway gasket event of February 1992, and the effectiveness of corrective actions taken as a result of the event. The inspection was also to determine if the licensee was in compliance with the requirements of the Quality Assurance program description and federal regulations for the procurement, storage and issue of safety-related parts, material and equipment.
2.1 Assessment of Procurement Related Event 2.1.1 Background On February 16, 1992, the Watarford 3 Unit was shutdown because of reactor coolant system leakage from Steam Generator (SG) No.1 cold leg manway cover.
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-8-The licensee had been monitoring the leak since it had been detected, early in January 1992.
Prior to shutdown, the leak rate did not exceed 0.6 GPM. Also, prior to the shutdown, the licensee determined that incorrect gaskets had been installed in all four (two per steam generator) primary manways. Through a procurement error, the licensee had obtained and installed spiral wound (Flexitallic) gaskets designed to seal against a system pressure of 150 psi.
The Waterford 3 reactor coolant system operates at a nominal pressure of 2250,
psi when the facility is at power and is designed for a pressure of 2500 psi.
The incorrect installations occurred during the previous refueling outage.
2.1.2 Details The inspectors reviewed licensee actions to initially assess the significance of the condition and planned short-and long-term corrective action.
Prior to discovery that the wrong gaskets had been installed in the SG manways, the licensee commenced an engineering evaluation in accordance with Site Directive W4.101, "Nonconformance/Indeterminance Analysis Process,"
Revision 0.
The inspectors noted that the effective date on this procedure was January 29, 1992, and the final report was dated February 4, 1992. The procurement issue was not discovered until February 3, 1992. The engineering evaluation made the following recommendations and determinations.
The installed gaskets were incorrect and did not meet original design
specifications.
System engineering recommended that all SG primary manway gaskets be replaced with gaskets of the proper design.
System engineering also recommended that the unit be shutdown in the
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near term because of the analysis on manway cover closure bolt wastage
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from leaking boric acid.
Design engineering determined that the gaskets did not perform a safety
function.
Design engineering recommended no short-term corrective action as there
was no unanalyzed condition.
it was postulated that other manways could potentially develop leaks as a result of the thermal hydraulic transient associated with shutdown and cooldown.
Design engineering recommended a root cause analysis be performed to
ascertain why the incorrect gaskets were installed.
The inspectors noted that this evaluation assessed the nuclear safety significance and the impact on continued operation.
According to the documentation, the condition was determined to be conforming. However, there was no apparent attempt to assess operability or reportability.
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-9-The licensee undertook the following efforts to determine the cause of and implement corrective action for the procurement errors that resulted in the degradation of the reactor coolant system pressure boundary.
An i.vestigation was performed to determine the root cause for the
installation of improper gaskets for the SG manway covers. The cause was identified as a lack of internal guidance for ordering replacement parts from vendors other than the original equipment manufacturer. This'
lack of guidance had resulted in the generation of a purchase order with inadequate specifications. The investigation report, RCI No.92-003 also identified numerous contributing causes and non-cauni factors related to the procurement process.
In response to the event, the Independent Site Engineering Group
conducted an assessment of selected areas related to procurement. The assessment results were issued in Report No. 054-92, and contained a total of ten recommendations within four procurement elements to improve the process for procurement of safety-related items. A response to the report indicated that nine of the recommendations had been implemented.
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On January 27-29, 1993, the licensee performed a team assessment of site
procurement activities. Criteria for the assessment were developed from industry group initiatives. The assessment identified three strengths and four areas for improvement.
Site procurement management initiated a response to the assessment by identifying several specific changes to be made within the procurement program. Changes were still being implemented at the time of the inspection.
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Quality Assurance issued Audit Report SA-92-007.1 on April 2, 1993,
which reported the results of an audit of the site procurement program.
This report identified four opportunities for improvement and was, in general, favorable to the procurement process.
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The licensee's effort appeared to address the procurement process problems that had caused the wrong gasket to be installed.
In addition, the licensee developed an innovative training display that contained examples of the 150 pound and 2500 pound gaskets and explained the root causes, impact on safety and the lessons learned from the event. This display is one of several in a training area frequented by the licensee's technical staff. All of the displays are museum-like presentations of interesting issues that have occurred at Waterford. This is viewed as a good training practice.
The inspectors looked further to determine why the event, which had resulted in a forced outage, had not been reported to the NRC. A review of 10 CFR Part 50.73 indicated that there was no clear requirement to report the event, and the regulatory requirements were subject to interpretation. The inspectors.
asked.to see the reportability determination documentation and were informed that none existed.
In several discussions with licensee personnel on event.
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reportability, it appeared that the licensee's position was that the event was
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-10-not reportable because gaskets and seals were not addressed by the ASME code.
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The inspectors reviewed Regulatory Guide 1.116, "QA Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems,"
which the licensee endorsed in the QA Program Description (FSAR Chapter 17).
Regulatory Guide 1.116 contained discussion about where to apply the requirements of Sections 11' and XI of the ASME boiler and pressure vessel code. A quote from this Seide stated, " Code-covered activities are primarily,
intended to assure the inttgrity of the pressure boundary of an item.
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activities of safety importance are covered by the code."
The inspectors reviewed the following licensee procedures:
Site Directive W4.101, "Nonconformance/Indeterminance Analysis Process,"
Revision 0.
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Procedure UNT 006-010, " Event Notification And Reporting," Revision 9.
- Procedure UNT 006-010 was intended to be used in determining if a potentially reportable event or condition was to be reported.
Prior to a recent change, this procedure was part of the corrective action program. The inspectors could not identify any clear implementation requirements for the procedure.
Within the procedure, the stated responsibility for implementing the procedure rested with the individual discovering the event or condition and there were no stated entry points from other procedures.
Site Directive W4.101 did not reference Procedure UNT 006-010.
Procedure W4.101 assigned responsibility for the reportability determination and its documentation to the Manager, Event Analysis Reporting and Response, in Sections 4.6.4 and 5,10.4.
The inspectors checked the current Waterford 3 organization and determined that this management position no longer existed.
Therefore, the procedure was inadequate and failed to comply with
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10 CFR Part 50, Appendix B, Criterion V, and will be tracked as Violation 382/9329-02.
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2.1.3 Conclusions
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Based upon the review of the documents above and interviews of personnel with procurement responsibilities, the inspectors concluded that sufficient corrective action had been implemented to significantly reduce the risk of a
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similar occurrence.
However, one of the licensee's procedures for corrective action, Procedure W4.101, was out-of-date and not sufficiently integrated with other procedures to result in consistent implementation of determination for reportability.
As a result, the inspectors believed that the licensee's
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threshold for reporting events or conditions was inconsistent and tended to be high. The training display that depicts the issues and lessons learned related to this event is considered a good practice.
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t 2.2 Procurement, Issue And Control Of Safety-Related Material
2.2.1 Procurement Through administrative procedure review and interviews with selected personnel, the inspectors determined that the licensee's procurement program provided for proper identification of equipment, supplies, consumables, and
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services. Technical requirements for inclusion in the purchase specifications were readily available from the material data bases.
These data bases were in
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the process of being improved and updated. An essential part of the improvement included a modernization program for the vendor equipment technical information program. The planned improvements: centralization of functions, elimination of non-technical material, improving the quality of the
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technical manuals, and providing a thorough and timely review of incoming information, appeared to provide for a stronger program.
The licensee's qualified suppliers list was available from and controlled by i
Entergy's corporate headquarters.
This means that the same approved list was
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available to the licensee's sister plants.
The inspectors reviewed the list, with the assistance of a licensee representative, from the computer database.
It was noted that one vendor, B&B Promotec, had been flagged as restricted, which meant no purchase orders could be issued to this-vendor.
Subsequent review determined that the restriction had been placed following a joint utility audit of the vendor that had identified three unsatisfactory conditions. The restriction could be removed after a satisfactory response
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and followup inspection. The control of the qualified suppliers list appeared
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to be acceptable. The licensee also has provisions for initiating an internal review of installed or in stock material provided by a restricted vendor, if there is indication of material defects. This review was handled through the licensee's licensing department.
i 2.2.2 Purchasing Specifications The inspectors obtained and reviewed the purchase orders for nine safety-related stock codes dating back to plant licensing.
These records indicated that there were earlier problems related to vendor exceptions identified by vendors in receipt of Waterford 3 requisitions. Within the purchase order packages, there was documentation to support that the licensee had identified incorrect specifications, and resolved the exceptions prior to receipt of the material.
The inspectors identified one case where a vendor exception was discovered by a vendor after receipt of the purchase order. The vendor
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communicated with the licensee and corrected the exception before shipment ~and the licensee received the correct item. On the subsequent reorder, 18 months later, the same vendor identified the same exception.
Ideally, the first occurrence should have resulted in a change to the onsite vendor technical information, which would have prevented.the second occurrence provided the next purchase order had been screened against the revised vendor technical information. 'The inspectors believed this to be an isolated occurrence and that the planned improvements in the vendor technical information program would eliminate this kind of problem.
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-12-There were also early problems of vendor exceptions identified by QA and procurement engineering after receipt of the material. These issues were sometimes resolved by determining that the wrong material had in fact been ordered and received, which caused delays and necessitated reorder. Although the licensee had experienced problems of ordering material to the wrong specifications, the inspectors concluded that material with improper specification was not installed in the plant. These occurrences had only
resulted in maintenance or repair delays.
The inspectors detected a trend of improving purchase orders, in that, less exceptions were being identified. This improvement was believed to result mainly from the procurement department reorganization and the improved condition of the Material Management Information System (HMIS) database, which is addressed later in this report.
The inspectors were also aware that greatly improved procurement procedures integrating the new organization and its interfaces with other organizations were major factors in the identified improving trend.
2.2.3 MMIS Database As previously stated, a major reason for recent improvement in the site procurement function was the licensee's effort toward improving the MMIS database. There had been improvement in the accuracy of content, system capability, and interface with other database systems. The following major tasks had been undertaken to improve the data base.
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The licensee had performed a wall-to-wall inventory to validate all
material onsite.
A second inventory in the form of a catalog walkdown was in progress to
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verify that material was identified with the correct specifications.
This effort was to be completed by January 1, 1994.
The database had been modified to provide for the generation of a
receipt inspection plan. This plan was filled out by the inspector to becom an inspection report and served to validate the material specifications.
The system had been modified to allow flagging a stock code where a
vendor exception had been identified. This feature assured that vendor technical information would be changed to reflect specification revisions.
The inspectors observed the performance of the catalog walkdown process.
During this observation, a warehouse operator, who was also a certified Level II procurement inspector, obtained from the supervisor a list of catalog-
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items to be validated.
Each item entry on the list contained all specifications, characteristics, and traceability information such as heat numbers, serial numbers, and lot numbers, that were currently in the database.
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-13-Each item was then located in the warehouse and validated to the extent possible. The operator was observed to count items, re-package items, and verify the obvious specifications and characteristics.
Some items such as fittings and fasteners were measured to verify correct size. The operator / inspector noted on the catalog sheet any information that could not be validated.
The inspectors were walked through the second part of the process which amounted to locating and evaluating various tracing documents.
Once all the information about an item was attained, the information was used,
to update the database.
If an item could not be validated to have the proper specifications and characteristics for use in a safety-related function, it was tagged and rejected. The inspectors believed that the completion of this process would result in an improved database and better control of inventory.
2.2.4 Material Staging
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Material required for maintenance or modifications could be issued from three warehouses, a fenced laydown area, and a secure hazardous material storage facility. The service warehouse was located inside the protected area in close proximity to the maintenance shops and was the source of most material issued to support day-to-day maintenance. Due to space considerations, larger items would be issued from the larger warehouses, located outside the protected area.
The inspectors asked the licensee to provide a list of the safety-related work packages scheduled for the current week and the unscheduled outage work list.
From these lists, a sample of stock codes was developed and the parts or
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material were located in the warehouses. Licensee procurement personnel were able to use the MMIS database and quickly locate the various items.
The inspectors verified that the material identification tag on the part or material agreed with the specifications in the MMIS.
These sampled stock codes were later referenced to purchase _ orders for the licensee's inspectors to check the pedigree of safety-related replacement items.
Most parts and material that were considered quick turnaround items were available in the service warehouse.
In order to gain efficiency, the licensee had initiated a program for pre-staging all items designated for the upcoming
scheduled and non-scheduled outages.
This material was staged at specific
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locations in the warehouses for quick location and issue. Only one-of the items sampled by the inspectors was not available at the service warehouse.
However, the inspectors verified that it was readily available in one of the
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larger warehouses outside of the protected area. All warehouse operators with j
which the inspectors interfaced were adept in using the MMIS database and
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quickly locating material. Within the sample, no discrepancies were i
identified between the database material description and the specified j
location and, the actual nomenclature and material location.
The warehouses were considered to be secure areas.
Consequently, the inspectors were not allowed inside without a licensee escort.
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-14-2.2.5 Warehouse Operations and Training H eerial management had been consolidated under one superintendent with four supervisors.
The organization consisted of an inventory control group and a warehouse group. The inspectors focused on the warehouse group to evaluate the effectiveness of warehouse operations.
In the past when procurement-related activities had been organized under one
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manager, the material management function was separated from the QA organization. This was accomplished by bringing two QA certified inspectors into the procurement organization and implementing an approved. training and certification program.
This program had been developed to certify material operators as Level I and II inspectors for receipt inspection of safety-related material. There were also positions for two lead material operators.
By creating the material operator / inspector and the lead material positions, the entire warehouse operation had been streamlined.
An additional benefit was the creation of promotion opportunities and a career path for warehouse personnel.
The inspectors verified that there were inspector certification records within the QA organization for currently certified personnel.
At the time of the inspection, the licensee was in the final process of developing a laboratory facility within the main warehouse. The lab would be staffed by at least two technicians and would have limited non-destructive examination capability. The inspectors noted that a hardness tester was operational and a spectrographic analyzer was nearly operational.
During the inspection, there was opportunity to interface with warehouse personnel including operator / inspectors, technicians, and supervisors. These personnel were observed to be courteous, cooperative, and professional.
Additionally, there appeared to be enthusiasm and high morale within the entire materials manageinent organization.
2.2.6 Post Issue Control of Safety-Related Material The inspectors evaluated the control of material after it was issued for installation. The responsibility for control of material at this stage rested with the organization designated for end use and not the procurement organization.
Site Support Procedure SSP-702, " Staging, Issuing & Returns,"
Revision 1, required the department head / supervisor to provide the warehouses with an up-to-date signature approval list. This list provided procurement warehouse personnel the authorized signatures that department heads had approved for the withdrawal of material. An authorized signature was required on the withdrawal documentation before warehouse personnel would release material.
The inspectors reviewed lists provided by planning and scheduling, electrical maintenance, and the instrument and control (I&C) shop.
The planning and scheduling list had last been updated on July 12, 1992. The I&C shop list was last updated on April 11, 1990.
There was no effective date on the electrical maintenance list. With a limited knowledge of personnel on the three lists,
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-15-it was possible for the inspectors to identify errors relating to position changes and employees who had terminated.
From discussions with licensee
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personnel, it was determined that there was not a site-wide requirement for keeping the lists current. Additionally, for terminating employees, there was no mechanism in place to remove them from the authorization list.
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personnel agreed with the inspectors that it was possible for an individual to terminate employment at Waterford 3 and return as a contractor fully approved to authorize the withdrawal of safety-related material from the warehouses.
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The inspectors reviewed the various methods the individual craft disciplines used to control material after it had been issued by the warehouses. tione of these methods were proceduralized but could be characterized as normal shop practices.
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The I&C shop supervisors had a unique arrangement with planning and scheduling to control material prior to field installation. A specific individual within the planning and scheduling organization would obtain all material from the warehouses prior to the scheduled work. This individual was able to utilize the MMIS database to verify the availability of material, generate the withdrawal documentation, and approve the withdrawal. After warehouse issue, the material was identified to support a specific task, staged in a locked area adjacent to the shop, and issued to the craftperson by the shop supervisor with the work package.
The electrical maintenance shop operated in much the same manner.
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one major difference in that the individual responsible for withdrawing and controlling the material was a dedicated craftperson. Material was pre-staged and kept secure until a craftperson brought the work package to the dedicated l
individual.
This responsibility for material pre-staging and control was
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rotated among shop personnel, normally about every 6 months.
The mechanical maintenance shop allowed craft personnel to obtain material directly from the warehouses.
Licensee personnel stated to the inspectors that it would be difficult to withdraw and control material like the other
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shops, because this material was often large and bulky. There was no apparent policy for control of material once it left the warehouse.
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During a tour of the mechanical maintenance shop and spaces with a licensee l
representative, the inspectors asked the individual to locate a maintenance i
package that had been originally issued the previous week and then delayed due -
i to plant conditions and other priorities. The individual located the package
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in an unlocked desk drawer. Also in the desk drawer, were safety related parts that were needed to perform the maintenance.
The inspectors asked what the policy was for temporarily storing or returning the material to the warehouse and were provided a copy of Maintenance Directive tio. 34, " Guidance for Conducting Pre-job Briefings." This directive did not address control of safety-related material in the custody of the end use organization.
The
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inspectors determined that a policy didn't exist.
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J During a subsequent meeting, Site Support managers and supervisors provided an informative presentation to the inspectors which capsuled recent history, problems, and improvements for the Waterford 3 procurement process. The inspectors asked what were management expectations regarding the control of safety-related material after it left the warehouse.
Responses from numerous licensee representatives indicated that there were no clear management expectations in this area. The lack of control for post. issue safety-related.
material in the mechanical area and the lack of effective control of the approved signature list for material withdrawal is considered a significant weakness.
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2.2.7 Conclusions As a result of the corrective actions implemented as a result of the SG manway gasket event, and subsequent audits and reviews, it appeared the licensee's
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procurement program has been significantly improved. Specifically, the consolidation of functions with the assumption of responsibility for QA
activities and the establishment of a good interface with both procurement engineering and design engineering appears to have strengthened the procurement organization.
The procurement organization had improved efficiency by pre-staging nearly 100 percent of the material needed to support outage tasks. There were no
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apparent occurrences of delay or incorrect materia 1' issued by warehouse operations. The inspectors determined that warehouse personnel were well trained and qualified to supply the correct material in support of the various
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maintenance groups. The inspectors concluded that warehouse operations at
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Waterford 3 were good.
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The I&C and electrical maintenance shops exercised good control of safety-
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related material after issue by the warehouses. A weakness was identified when the inspectors could not identify any requirements for control of safety-i related material in the mechanical area, once it was issued, or effective control of the authorized signature list for material withdrawal in the
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planning and scheduling, electrical maintenance and IAC areas.
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ATTACHMENT 1 1 PERSONS CONTACTED
1.1 Licensee Personnel
- R. Azzarello, Director, Design Engineering _
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- B. Baptist, Superintendent, Material Management C. Bordelon, Planner W. Brown, lead Material Operator / Inspector
- V. Burgard, Materials Technical Supervisor
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- R. Burski, Director, Nuclear Safety
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J. Cancienne, I&C Supervisor f A. Cilluffa, Maintenance Enginaering
- F. Drummond, Director, Site Su,. port
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- D. Gallodoro, Procurement Engineering Supervisor
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- T. Gaudet, Operational Licensing Supervisor
- J. Hoffpauir, Maintenance Superintendent
- J. Houghtaling, Manager, Technical Services
- J. Howard, Manager, Procurement / Programs Engineering
- J. Johnston, Senior Staff Engineer M. Knoebel, System Engineer
- R. Lailheugue, Manager, Materials, Purchasing, and Contracts S. Lavie, Electrician
- L. Laughlin, Manager, Licensing
- A. Lockhart, Manager, Quality Assurance
- D. Marpe, Mechanical Maintenance Supervisor T. Moore, Electrical Planning Supervisor
- D. Packer, General Manager, Plant Operations
- R. Peters, Electrical Maintenance Supervisor
- G. Pittman, I&C Maintenance Supervisor t
- G. Scott, Licensing Engineer 1.2 Gulf States Utilities Personnel
- R. Ludwig, Procurement Engineer, Gulf State Utilities t
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1.3 BC Personnel
- J. Dixon-Herrity, Resident Inspector In addition to the personnel listed above, the inspectors contacted other personnel during the inspection periods.
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- Denotes personnel attending the exit meeting held on September 17, 1993.
- Denotes personnel attending the exit meeting held on October 1,1993.
2 EXIT MEETING Exit meetings were conducted on September 17 and October 1, 1993. During these meetings, the inspectors reviewed the scope and findings of the report.
The licensee did not express a position on the inspection findings documented
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-2-in this report. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.
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ATTACHMENT 2 DOCUMENTS REVIEWED WORK PACKAGES
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WA 01109469 WA 01110276 WA 01107648 WA 01109432 WA 01104412 WA 01108749 WA 01111924 WA 01107647 WA 01104857
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WA 01106571 WA 01110413 WA computer index of completed work packages PROCEDURES N0ECP-153 Commercial Grade Item Dedication Evaluation, Revision 0 N0ECP-103 Equipment Classification in the Sims Component Database, Revision 0-1 UNT-005-007 Plant Lubrication Program, Revision 4 i
SSP-827 Materials Technical Shelf Life Determination and Extension Process, Revision 0 Quality Assurance Program Manual, Chapters 4, 7, 8, 13, 15, Revision 2.0 Final Report, Quality Action Team, Vendor Equipment Technical Information
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Program
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