IR 05000395/1990032
| ML20029B031 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/08/1991 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20029B024 | List: |
| References | |
| 50-395-90-32, NUDOCS 9103050266 | |
| Download: ML20029B031 (56) | |
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Ceport No.:
50-395/90-32 i
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I.icenset:
South Carolina Electric and Gas Company P.O. Box 1551 Raleigh, N.C. 27602 Docket flo.:
50-395 License No.:
DPR-33 Focil'.y Name:
Summer Intpect,on Conducted: November 13-16 and 26-30 and December 10-14, 1990 NM O 7/
Inspectors:
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L. H. Girard, Team Leader Date Signed Team Members:
B. Crowley B. Wetzel B Desai F. Wright J. Knox R. Wright A
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Approved by:, J / J.jtlake, Chief Date Signed terials and Processes Section
.ngineering Branch Division of Reactor Safety SUMMARY Scope:
This special, announced inspection consisted of an indepth team inspection of the maintenance program and its implementation.
NRC Temporary Instruction 2515/97 issued September 22, 1989, was used as guidance for this inspection.
Results:
Overall, the maintenance program and its implementation were iudged to be GOOD.
The more significant artias of strength and weakness are highlighted in the Executive Summary, with details provided in the report.
No /iolations or deviations were identified, i
9103050266 910225 PDH ADOCK 0D000395 o
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EXECUTIVE SUVMARY
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This NRC maintenance inspection rated the Summer maintenance program and its implementatinn GOOD.
The GOOD rating indicates more than adequate development and implementation of the important elements of a maintenance program, with the areas of weakness being minor in comparison to strengths in other areas.
l The more significant weaknesses identified, those whose correction the team j udgec' would be of greatest benefit to the maintenance process, were the
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following:
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blakne nes:
Post maintenance testing requirements and performance were of ten
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not documented.
Requirements were poorly defined programatically.
This was considered the most significant weakness identified by the
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team.
(Report Section 3.b)
System eng neers lacked training and experience and had been
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deficient in developing status information on their systems.
(Report Section 3.c)
Backlog appeared inadequately assessed though it did not appear
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excessive.
(Report Section 3.d)
Risi factors were not formally assessed and utilized in determining
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mairtenance priorities.
(ReportSection3.f)
Root cause analysis administrative controls were deficient in some
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respects ar.d insuf ficient analyses were being completed.
(Report Section 3.g)
Administrative controls weie not well-defined for some maintenance
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and maintenance-related activities.
Particular examples included trending and utilization of predictive maintenance data (Report Section 3.h), derivation of preventive maintenance requirements from vendor data (Report Section 3.e),
and rescheduling of preventive maintenance activities scheduled for one outage and then deferred (Report Section 3.e).
f'erformance measurement appeared insuf ficiently utilized.
Examples
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included the inadequate assessment of backlog data referred to e taive,
failure to set goals for trended measures of craft performance, and f ailure to display craf t performance trends and goals (Report Section 3.d)
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Deficiencies were observed in some personnel safety practices, j
This included instances where hard hats were not used, motor i
control center fastener failure replacements were performed y
dangerously close to a live 480 Volt bus, and a poor practice
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during. breaker tra,11ng w(hich led to injury) to the individual perfonning the training.
Report Section 3.1 Although there were good written requirements for maintenance work
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request completion reviews, numerous minor entry deficiencies were found on the recoid copieb of completed work requests.
Examples ircladed inconsistancies in use of cause codes, absence of reference to documentation for tests to confirm operability and omissions of nortain planning and scheduling entries.
(Report Section 3.j)
The NkC team also noted other weaknesses that were mnsidered even less serious than those above but that still may require attention.
Examples are a lack of training and qualification requirements for planners, calibrated tools being issued without recording work use (contrary to - procedural requirements),
limited documented justification for exemption of many maintenance personnel from training and qualification requirements, minor instances of failures to properly identify deficiencies, etc. These ara enumerated in Section 4 of this report.
Some of the more significant areas of licensee strength identified were as follows:
Strengths:
Procurement (Report Section 3.a)
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Housekeeping and materiel conditions (Report Section 4.a(1))
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Radiological controls (Report Section 2.1)
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Well-qualified and capable maintenance staff (Report Section
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i 4.c(4))
The inspection was performed by a seven-man team during November and December
1990.
The maintenance performed while the team-was on site was limited in
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significance and complexity, encumbering direct assessment of work activities.
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The plant was in operation at the time and a refueling outage had been completed about five months earlier, in May 1990.
The inspection and the rating process were conducted in accordance with guidance provided in NRC Temporary Instruction 2515/97 A principal feature of this instruction is a -maintenance inspection logic _ tree used to collate and present the maintenance inspection findings. The tree prepared by the NRC from inspection of maintenance at Summer is presented as Appendix 3 to this report.
It depicts the ratings determined for individual maintenance elements and the overall GOOD rating.
The findings used in determining the ratings are summarized in report Section 4.
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v TABLE OF CONTENTS Page EXECUTIVE SUMMARY.....................................................
i 1.
INTRODUCTION....................................................
2.
INSPECTION DETAILS..............................................
I a.
Residual Heat Removal System..............................
b.
Component Cooling Water...................................
c.
Reactor Protection System.................................
d.
Electrical Distribution Systems...........................
e.
Service Water System......................................
f.
Miscellaneous Maintenance Work Observations...............
g.
Instrument Cal:Sration....................................
h.
Check Valves..............................................
1.
Radiological Controls.....................................
3.
ISSUESIDENTIFIED(MOSTSIGNIFICANTSTRENGTHSANDWEAKNESSES)...
STRENGTH
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a.
. Procurement.......................................,.......
WEAKNESSES b.
Post Maintenance Testing..................................
c.
System Engineering........................................
d.
B a c kl o g C o n t ro l...........................................
e.
Preventive Maintenance....................................
f.
Acknowledgement of Risk Significance in the Maintenance Process...................................................
g.
Root Cause Analysis.......................................
h.
Predictive Maintenance.....................................
1.
Personnel Safety Concerns
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j.
Work Request Entry Deficiencies...........................
4.
EVALUATION OF MAINTENANCE.......................................
3.
Overall Plant Performance Related to Maintenance..........
(1)
Di rec t Me a s u re s.....................................
b.
Management Support of Maintenance.........................
(1)
Management Cocmitment and Involvement...............
(2)
Management Organization and Administration.......... -33 (3)
Technical Support...................................
c.
Mai ntenance Impl emen ta ti on...............................
1)
Work Control........................................
2)
Pl ant Maintenance Organization......................
3)
Maintenance Facilities, Equipment, and Materials Control..............................................
(4)
Personnel Control....................................
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EXIT INTERVIEW...................................................
4 APPENDIX 1 - PERSONS CONTACTED.................:.......................
APPENDIX 2 - ACRONYMS AND INITIALISMS..................................
APPENDIX 3 - MAINTENANCE INSPECTION TREE j
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1.
INTRODUCTION This inspection was conducted to assess the effectiveness of maintenance at Summer utilizing guidance given in NRC Temporary Instruction 2515/97.
It was performed by an seven-man team during November and December 1990.
At the time Summer was operating after having completed a refueling outage May 1990.
During the inspection no particularly significant or complex maintenance was being undertaken.
The Summer plant is a 900 MWe (net) Westinghouse PWR.
It began commercial operation January 1, D 84.
It has been rated SALP Category I by the NRC in the maintenance or maintenance / surveillance areas for the last three appraisal periods.
The inspection findings and conclusions are described in report Sections 2 through 4.
Section 2,
Inspection Details, describes the conduct of the inspection and the majority of the findings obtained.
Section 3, Issues, highlights areas found to contain the more significant maintenance weaknesses plus-an outstanding area of strength noted in the inspection.
Section 4 Evaluation of Plant Maintenance, summarizes all of the findings md logic which culminate in the overall rating of maintenance effectiveness at Summer.
It includes some findings not described in Sections 2 and 3 findings which were either obtained as separate assessments (e. g., of historical data) or involved findings that were noted incidental to but outside the inspection described in l
Section 2.
l A special maintenance inspection logic tree developed for the NRC was utilized to aide in collating inspection findings, obtaining assessments for individual l
l elements of maintenance, and summing the individual element assessments into an overall rating of maintenance.
It is discussed in Section 4 and presented in
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Appendix 3.
The last section of the report, Section 5, summarizes the exit interview held with the licensee following the inspection.
2.
INSPECTION DETAILS This inspection was performance based and included:
Pl ar.t walkdowns to observe and assess materiel condition and
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housekeeping.
Detailed examination and assessment of the adequacy of maintenance
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and maintenance-related work performed on selected systems and components.
This was accomplished by observing the materiel
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condition of the systems and components, observing maintenance in progress, reviewing documentation and interviewing personnel.
Maintenance-related topics especially examined because of their
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importance to the-overall assessment (e.g.,
work control, post
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i maintenance testing, root-cause analysis, known industry problems, I
etc.).
These were typically examined as part of the system and component maintenance assessments, but in some instances they were
examined separately (e. g., historic data) and are only addressed in Section 4 of this report.
Miscellaneous in-progress maintenance work which was observed to
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increase the sample of direct maintenance observations, i
Radiological controls in their relation _to maintenance.
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The inspection findings for systems and components, rad.c'igical controls, instrument calibration and for miscellaneous maintenance.,ork observed are described below.
2.a Residual Heat Removal (RHR) System The team's inspection of the-RHR System included a walkdown of mechanical components and piping (both trains) outside the containment, detailed review of 15 completed Maintenance Work Requests (MWRs), and the preventive maintenance (PM) schedule.
System Walkdown In generel, materiel condition and housekeeping throughout the plant were very i
good.
Onij a small number of minor materiel deficiencies were noted, Most deficiencies were tagged with Maintenance Work Request (MWR) tags; however, the
following had not been tagged:
I Excessive boron buildups on three RHR/SI system valves (1-FCV-
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l 603A-RH, 1-FCV-605A-RH, and 1-8889-51) and at the
"B" RHR heat j
exchanger inlet flange.
_ Temperature Indicator TE 604A_with a broken flex conduit.
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-Pipe cap missing from Seal Vent for RHR Pump A.
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l Inaccurate position indicator scale on Valve 1-8729A-RH.
The i ;ensee took immediate action to initiate MWRs for these items.
Relative to the boron buildup on Valve 1-Ft V-605A-RH, the team noted that a catch bag had been installed underneath the valve.
This indicated that the condition had been recognized.
However, the valve had not been deficiency tagged and an MWR had not been initiated. The team questioned the licensee
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Maintenance management stated that all plant personnel are responsible for-identifying deficiencies and initiating corrective action.
Procedures SAP 601 and SAP 142 were provided as the applicable procedures for these requirements.
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a.
Although SAP 14T did indicate that deficient conditions were to be identified through the MWR. program, the procedures did not clearly specify that all personnel were responsible to both identify and initiate MWR5 to correct them.
This could account for the catch bag being installed on Valve 1-FCV-605A-RH without initiation of a MWR.
During the inspection, the licensee initiated a revision to procedure SAP-601 to clearly state that all personnel were responsible to identify deficiencies and initiate corrective action using the MWR process. Also, relative to the boron buildup (leakage), the licensee had a detailed program in place to pericuically assess leakage and either repair the leaking component or monitor the leakage if repair was not warranted.
The program appeared to be effective, based on the small nunber of leaks observed in the plant.
Review of Completed Work Requests A computer listing of all MWRs issued on the RHR system for the last 2 years was reviewed to evaluate the maintenance history and determine if the system or any component had experienced abnormal problems or trends.
No abnormal problems or trends were identified.
The team selected 15 completed MWRs from the list for retrieval and detailed
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review for completeness, the degree of detail provided, and compliance with the licensee's program.
The programmatic requirements, which were delineated in procedures SAP-601, ES-501, and RMP-103, specified extensive post work reviews for completion, closecut, and storage of completed maintenance records.
After completion and verification by maintenance, all completed MWRs were required to be routed to QC, Health Physics and System Engineering for review prior to closecut, in general, the team found that the records were readily retrievable l
and satisfactorily documented the work performed.
However, the following discrepancies were noted:
l Information 'and requirements' to be entered into MWR Section 11 l
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("PLANNINF AND SCHEDULING") for a number of the MWRs, had not been (.
completed examples: MWR 8901845, "H.P.
C0VERAGE" and "RWP. REQ."
i blocks not completed; MWR 890837,
"Q.
C.
Coverage" block not completed; MWR 8900479, " RETEST" block not completed; MWR 9000842,
" CODE CLASS", " SCAFFOLD REQ",
"Q.
C. C0VERAGE", and " HOUSEKEEPING" blocks not completed.
In all cases, from review of the records, it appeared that the required inspections, retests, etc.,
were accomplished-even though the MWR requirement entries-were not compl eted.
There was inconsistent use of "CAUSE DESCRIPTION" codes in that
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three separate codes were used on -dif ferent MWRs (e.
MWRs 8801923, 8801925, 8801926, 8901840, 8901837, and 89H0009)g.,
for the same problem (adjustment of valve packing).
This inconsistency brings to question the usefulness of the codes for trending equipment failures.
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MWRs typically did not indicate whether post maintenance testing
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was required or accomplished (as discussed in Section 3.b below).
Preventive Maintenance The team reviewed the PM schedule for the RHR system to determine if the number and schedule of PMs appeared to be appropriate.
In addition, the vendor manuals for the RHR Heat Exchanger and Pumps were reviewed to determine if vendor PM recommendations were included in the PM program, in general, it appeared that appropriate PMs were being performed on the system.
A weakness was noted in that the PM procedure did not clearly define the process for determining PM requirements.
Further details on this and other PM weaknesses are described in Section 3.e below.
2.b Component Cooling Water (CCW) System The team performed a CCW System walkdown inspection and r2 viewed records of past CCW System maintenance.
'he walkdown included the two essential CCW system loops and the Auxiliary Building loads outside the containment.
Components specifically examined included CCW pumps, heat exchangers, surge tank and chemical addition tank; the RHR pumps and heat exchangers (cooled by CCW); the seal water heat exchanger; the spent fuel heat exchangers; the recycle evaporator; and the waste gas compressors.
The maintenance records reviewed consisted of a sample of 17 completed MWRs (8902057, 9001432, 9001971, etc.) representing a cross-section of recently completed work.
Additionally, the team reviewed the electrical and mechanical' preventive maintenance histories for all CCW System components.
System Walkdown In the walkdown inspection the team observed that materiel and housekeeping conditions appeared good.
Equipment was found to be relatively clean -
i.e.,
free of debris, dust occumulation, and excessive oil or grease. All components (pumps, valves, motors, instrumentation, supports and snubbers)- were uniquely labeled and identified.
Sometimes two types of labels (tags) were present due to an upgrading of tagging _ system durability that was in progress.
Leakage MWR (deficiency)ps, drains, etc., was generally identified with orange colored from valves, pum tags and was being properly collected and controlled.
Some minor discrepancies were noted, however.
For example - Waste Gas Compressor A had leakage that wasl being collected in two drainage. funnels but the condition had not been deficiency tagged and no MWR - had been prepared to correct the problem (see 2.a above for a similar problem); CCW Surge Tank Check Valve 9562
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had half an orange tag (apparently an old deficiency tag) still attached, though there were no currently open MWRs on this item; and a sample valve (XVT 31808-SW) on CCW Heat Exchanger B was tagged with an equipment hold tag to identify that the associated drain should not be plugged, a misapplication of the hold tag.
Again, these conditions were minor exceptions to the overall good application of housekeeping and maintenance of equipment observed in the walkdown.
For the discrepancies identified by the NRC team, the licensee took appropriate corrective actions that were completed by the end of the inspection.
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During the walkdown, the team observed a portion of the maintenance performed in accordance with MWR 9001971 for replacement of a ruptured disc in the Recycle Evaporator (XEV0003).
Good health physics and QC support were supplied, the procedural requirements were follcwed, and the job was accomplished in a professional manner, Review of Completed Work Requests CCW System MWRs were reviewed by the team to ascertain whether planning and scheduling reviews were made and authorization approvals were obtained before initiating work; procedures specified were adequate; inspections were in accordance with-procedures and properly recorded; equipment maintenance work history was adequately described; and post maintenance and functional retesting were being performed as required.
Most (14 of the 17) of the MWRs checked were deficient in completion of entries of data required on Section !! (" PLANNING AND SCHEDULING") of the MWR form, such as Code Class, HP coverage, Retest, etc.
Similar discrepancies were found in reviewing RHR Sy(stem MWRs, as noted in 2.aof the above.
MWRs 8902057 and 9000726 were the only two identified retests as being required following maintenance to demonstrate Technical Specification Operability prior to use.
In the case of the former it was found that no retest had been performed and, in fact, none had been necessary for the-maintenance performed.
For the latter (9000726) the performance of a retest was verified from an attached QC form; however, retest data sheets were not attached to the MWR as required by procedure SAP-601, Section 7.5.8.
Further, there was no cross-reference to the data sheets and they could not be retreived during the team's inspection.
None of the CCW System MWRs reviewed indicated whether post maintenance testing was required or accomplished.
This is similar to findings referred to in 2.a above and discussed in greater detail in 3.b below.
The MWR form was considered to be a well-organized and informative document for controlling and recording maintenance work activities, The team's review found that it requested all vital information desired other than post maintenance testing.
To aid in assuring proper assignment of responsibilities and work completion, pre-and post-work reviews and verification signatures were specified for and performed by QC, Health Physics, Operations, and Engi ering personnel on the MWR.
Actual maintenace work performed appeared well-documented on the MWRs, work operations and scheduling appeared appropriately specified, approvals were recorded as required, and procedural data and signature entries appeared correct.
Preventive Maintenance Based on the team's experience, it appeared that the preventive maintenance activities (PMs) performed on the CCW System components were appropriate.
All of the PMs recorded were performed within their specified frequencies or valid reasons (such as component or system modi fice tion underway that would temporarily prevent or make the PM unnecessary) for extending the PM due date were evident.
A review of several instances of permanent changes to PM frequencies found that there was readily available documentation which supported the changes.
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2.c ReactorProtectionSystem(RPS)
The team's inspection of the RPS included a walkdown of RPS cabine+s in the relay room, a complete control room walkdown, observation of the performance of the Solid State Protection System Surveillance STP-345.074, review of 19 completed MWRs, and review of the root cause analysis for 7300 card failures.
The findings for each of these areas are described below:
System Walkdown The following RPS cabinets were opened and inspected in the relay room:
XPN 7003 (Process HC Rack Protection Set Ill)
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XFN 7020 (Solid State Protection System Train "B")
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XPN 7021 (Solid State Protection System Train "B")
XPN 7032 (Nuclear Steam Supply Auxiliary Relay Rack 2)
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XPN 6025 (Engineered Safety Features Load Sequence Panel Train "B")
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XPN 6010 (ATWS Mitigation System Actuation Circuitry)
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Materiel condition and housekeeping inside the cabinets was very good.
The cabinets were clean and free of debris.
Wires that were not terminated were properly marked for traceability.
Terminal points were clean and did not exceed the maximum number of wires permitted at each termination point.
A complete control room walkdown was performed with a few minor deficiencies noted.
Many of the reactor building smoke detectors were tagged out of service, which are part of a Technical Specification fire system. The licensee was performing compensatory actions by monitoring reactor building temperatures hourly.
The smoke detectors historically have been unreliable during power operation.
The licensee is planning to replace the smoke detectors under a modification (MRF20951)
in either Refuel Outage 6 or 7.
A recurring maintenance item in the control room was strip chart recorders.
Many o' the strip chart recorders for various systems throughout the control room were tagged with MWRs to replace the recorder scales.
The scales were stained with ink from operators marking the charts during shift changes.
In some cases, the scales were not readable due to the excessive ink stains; however, values could still be read directly off of the strip chart paper.
There was currently a modification in progress to replace and upgrade the recorders.
Another pervasive maintenance item in the control room dealt with standard control knobs found on numerous systems.
A fitting inside the knobs had been fracturing due to heat from the indicator lights and the knobs became disabled.
The licensee had been replacing the disabled control knobs with temporary fittings until permanent knobs could be installed.
The team counted twenty of the temporary knobs during the walkdown.
They were tagged with MWRL, some of which dated back to 1988 and 1989.
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One maintenance item in the control room was identified by the team during the walkdown that did not previously have a MWR written for it, i t dealt with two controller stations on the Feedwater System.
The indicator needles were sticking. on the bezel which covers the scale and operators apparently wedged folded paper into the controller to tighten the bezel and prevent the needle from sticking.
Operations and maintenance personnel did not know how long this problem existed.
I&C Maintenance immediately investigated it and identified a third controller with a similar problem.
MWRs were written to repair all three controllers.
Observation of Work The work observed involved the performance -of the bimonthly, Technical Specification required surveillance procedure STP 345.074, which is a
functional test of the complete Train B of the Solid State Protection System.
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I&C maintenance personnel performed the test properly and in a professional manner and received good support from operations personnel.
Review of Completed Work Requests The team reviewed 10 completed MWRs from the Nuclear instrumentation (NI)
System and 9 completed MWRs from the Safeguards (SG) System, which are both
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subsystems of RPS.
Several of the completed MWRs reviewed contained blanks in various blocks that should have been filled in by the planner or identified during the licensee's completed MWR review process.
Examples of blocks not filled in were the following:
QC Coverage, HP Coverage, Mode Restraint, Barrier Removal Required. RWP Required.
Based on discussions with the licensee, the team concluded that the work appeared to have been performed with the proper controls.
In many of the cases where blocks were left blank the work was high priority in which a MWR is often issued post maintenance.
Review of Root Cause Analysis
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The team performed a detailed review of the licensee's root cause analysis for 7300 process rack card failures.
The 7300 cards are printed circuit boards which are utilized -in both the SG system and in the Process Instrument racks which control numerouc systems throughout the plant.
The licensee had been experiencing a significantly higher failure rate.of 7300 cards than the
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industry average (according to the Nuclear Plant Reliability Data System (NPR05) data) and their failure rate, in general, had continued to increase.
The team found that the root cause analysis was very thorough.
The effort involved more than 200 failures spread over more than 900 components over the past 8 years.
The card failures were analyzed by location, repeat failures and card types.
The f ailure results and maintenance practices were compared with those of one plant that was identified as having a low failure rate and one plant that was previously identified as having a high failure rate, but reduced it by installing fans.
Systems and performance engineers also performed temperature monitoring in the process rack cabinets with infrared thermography equipment and identified hot spots, t
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The primary root cause was determined to be high temperatures in the process racks, which the licensee plans to correct by installing fans.
The analysis also found that the licensee's card failure reporting to NPRDS had been conservative in that often the " failed" cards were able to perform their intended function. but internal adjustments had to be made by the card repair lab.
NPRDS reportable failures, as described by SSP-3, "NPRDS Reporting,"
Rev.
O, are those where the component cannot satisfy its intended function.
More accurate reporting should bring the licensee's failure rate closer to the industry average.
This issue was being addressed by troubleshooting cards immediately upon removal and having - I&C maintenance supervision review for failure reportability.
The licensee also plans to upgrade some of the components which'the analysis determined to be less reliable on the cards. The team noted that there was approximately a two year backlog on the repair of the 7300 cards.
However, this had not had an adverse effect on plant operations because there was an ample supply of replacement cards.
The card repair lab had recently implemented a practice of l a s t-.i n first-out repairs, so that information pertaining to card failures and corrective actions would not be delayed by the backlog. An additional person was being temporarily assigned to assist with card repairs and new advanced technology equipment had been purchased to help in troubleshooting and repairing of cards.
-2.d Electrical Distribution Systems The team's inspection of electrical distribution systems included an extensive walkdown of the -systems; observation of preventive maintenance and review of the related procedures; and review of work requests for - completeness, legibility, capability of being retrieved, and post maintenance testing.
The team's findings for the areas inspected are described below:
System Walkdown The walkdown inspection included the distribution systems which supply electric power to - the 480 Volt System; the 480 Volt AC load centers, motor control centers, protective relay panels, and termination cabinets; the 125 Volt DC distribution panels, batteries, battery chargers, and inverters; and the 120 Volt AC distribution cabinets and termination cabinets.
The materiel condition and housekeeping were found to be excellent. Discrepant conditions identified were considered minoi and were limited to the following:
Cardboard insulators were loose in about 50 percent of the 480 Volt
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motor control centers inspected.
This represents a very minor personnel safety concern.
Four wires were not routed in raceways in termination cabinet XPN-
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7102 and protective relay panel XCX52010G.
The licensee corrected this condition during the team's inspection.
An incomplete maintenance item identification tag dated 7/22/87
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was found in termination cabinet XPN-7110.
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Two out of four light bulbs were not lit above motor control center
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Observation of Preventive Maintenance and Review of Related Procedures Examples of work observed and related procedures reviewed by the team were considered representive of good electrical maintenance, lhe team observed the initiation, approval, and implementation of electrical maintenance procedures EMP-405.002, ITE Air Circuit Breaker Maintenance; and EMP-280.004, Molded Case Circuit Breaker Testing.
EMP-405.002 was observed being performed in testing two non-safety-related Air Handling (System motor control center load breakers that power maintenance shop areas Work Orders P0138263 and P0138264); and EMP-280.004 was observed being performed in testing a safety-related SW System motor control center load breaker (Work Order P0130463).
The above procedures were found to be used for periodic testing of each plant safety-and non-safety-related breaker on a scheduled cycle not to exceed five years.
Based on their review, the team concluded that the procedures represented a complete and comprehensive preventative maintenance testing program for the type of breakers they covered.
Generally, the procedures were found to be well-performed and the persornel appeared knowledgable and qualified.
Problems encountered while performing work were properly resolved.
The rapport observed among electrical maintenance personnel, their supervision, and support personnel from QC, design engineering, and systems engineering was excellent during problem resolution.
Several maintenance-related deficiencies were noted by the team but were considered to be minor as compared to the overall good performance.
They were as follows:
The team found that the ctaft had not obtained the correct version
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of EMP-405.002 for perfcnntrcg the work.
The file copy of EMP-405.002 did not include the let change to the procedere and maintenance personnel incorrecth obtained Revision 11, Cnange A instead of the required Revision D, Change B.
The file <,lerk was at fault for not having replaced Change A with B and miintenance personnel were at f8 ult for not having verified that the procedure was the correct change.
The change added visual chicks to insure against deterioriation of breaker lubricant and ce: rent transformer encapsulant.
The procedure was obtained for non-safety-related work.
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During performance of CHP-405.002, two problems were identified by maintenance personnel.
First, the procedure incorrectly referenced a figure as being in enclosure 10.2 but it was actually in 10.3 -
this was an obvious typographical error and was easily corrected.
Second, a protective relay trip setting was found incorrectly set at 225 versus the specified 150 amperes.
In previous work, electrical maintenance supervision had initiated the change to accommodate increased loads on the non-safety-related system, but
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failed to follow the proper engineering approval process.
The licensee indicated that the breaker trip setting was changed without going through proper procedures because the system was not safety-related.
In performing procedure EMP-280.004, steps 7.2.5, 7.2.0, and
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7.3.8 F were missed as a result of inadequate attention to detail.
Step 7.2.5, through a change instituted in 1989, provided for measuring breaker contact resistance more accurately when resistance was small to improve recognition of any degradation.
Step 7.2.6 required manual exercising of the breaker trip mechanism to assure that it was functioning properly before a trip current a personnel safety precaution.
This step had no was applied
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specific sign-off on the data collection sheets, which may have centributed to the missed step.
Finally, step 7.3.8.F provided for verification that the breaker test trip was not caused by the thermal effect of the fault current but rather by the instantaneous current.
This step was not significant to the test actually observed by the team as the test had already identified a failure of the breaker to trip within its required limits in a previous step.
A deficiency in the procedure description of the "date code"
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location on newer breakers resulted in a delay of about three hours in testing a replacement breaker for the failure referred to above.
The date code is used in determining breaker test parameters.
The code location had been changed by the manufacturer.
Although the licensee had been informed of the correct location by the manufacturer six months earlier in correspondence related to a similar incident, the information had not ber incorporated into the procedure.
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A delay in completion of nainte.mce of about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> occurred when an identical replacement could not be located for an improperly crimped cable connection between the SW System motor control center and breaker.
The delay +ime was incurred while engineering (contacted the manufacturer to confirm that an alternateone cable per ph connection stock would suffice.
Review of MWRs Twenty-two MWRs associated with the electrical systems were reviewed for completeness, legibility, and capability of being retrieved.
They were found to be complete and legible, were easily retrieved, and no discrepant conditions were identified by the team.
Five of the MWRs were reviewed with respect to post maintenance testing.
The team found that the last procedural step for each of the MWRs provided adequate post maintenance testing.
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2.e Service Water (SW) System The team conducted a walkdown inspection of the majority of the system outside the containment and of associated biocide treatment equipment, reviewed the
. performance monitoring procedure for heat exchangers served by SW, performed a detailed review of 22 completed MWRs, and reviewed and assessed the root cause analysis of the failure of Service Water Pond Reactor Building Cooling Unit Return isolation Valve XVG-3107A-SW.
System Walkdown In general, materiel condition and housekeeping observed were good.
Portions of the system were compared with piping diagrams and configuration was found to be correct.
Piping was painted and no signs of rust were evident.
Components were properly identified and typically appeared well-maintained.
Biocide treatment - equipment had been installed and operated to aid in preventing biofouling and microbiologically induced corrosion of the piping.
The responsible system engineer assisted in the walkdown inspection and, considering that-he had not been assigned to this system for very long (six months), he appeared reasonably knowledgeable regarding the system and its condition, While examinining SW panels in the control room, operators were interviewed and were found to be familiar with system status.
While the overall state of the system appeared good, some adverse conditions were noted.
The SW pump / motor foundation was seen to have accumulated about one inch of water from the normal packing leakoff because the drain hose connected to the foundation was clogged.
Review of MWRs revealed this was a recurring problem, However, it had no significant effect on operation or maintenance and was considered a minor housekeeping deficiency.
A protective dike surrounding the biocide treatment equipment contained a large amount of water (estimated 100 gallons) interferring with access to a gage that was used to determine the quantity of biocide being pumped.
Heat Exchancer Performance Monitoring The procedure for SW system heat exchanger performance monitoring was reviewed.
This -procedure, used to calculate and trend the overall heat transfer coefficient of SW system heat exchangers, was considered to -provide an effective. method for verifying heat transfer capabilities of safety related heat exchangers cooled by SW.
Review of Completed MWRs Prior to review of completed work requests the team reviewed the controlling procedure for application, scheduling and handling of maintenance activities, SAP-601.- It appeared to be detailed and responsibilities were clearly stated.
Inadequacies concerning post maintenance activities were identified which are discussed in Section 3.b.
The team reviewed 22 completed work requests pertaining to SW system.
All work requests were judged by the team to be i
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correctly prioritized and were completed in a timely manner.
Appropriate QC and HP involvement was documented.
A minor weakness was identified in that certain blocks on the MWRs were not completed in some instances.
Examples were as follows:
Work Request Work Description - MWR Entry Deficiencies MWR 900050 Troubleshoot and repair SW Flow transmitter Code
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Class, QC coverage, HP coverage, and Housekeeping Requirements were not identified MWR 891317 Calibrate IFT04496 Retest Requirements were not
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identified MWR 891924 Troubleshoot and repair - HP coverage and Housekeeping Requirements were not specified Another item considered a minor weakness was that the MWR form did not provide for identifiying whether or not the work was Technical Specification related.
The team's review found that the MWR backlog on the SW system appeared low.
The outstanding items were not safety significant.
The team noted that there were a large number of work requests involving safety-related instrument line clogging and power supply circuit card failures.
In both cases it appeared that these conditions were being adequately addressed.
The instrument line clogging had been determined to be due to siltation and-was temporarily being corrected by backflushing or blowdown on an as-needed basis.
The system engineer informed the team that the previous system engineer had initiated a request for preventive maintenance to address -
the clogging and that provision for periodic testing for the condition was being added to the preventive maintenance program.
With regard to the power supply card failures, the team was informed that this had been identified as part of a larger card failure concern and that a root cause analysis had been undertaken.
The team verified and reviewed this analysis (No. 1007, 7300 Instrument Cards) as described in Section 2.c above.
Review of Root Cause Analysis The-team -reviewed licensee's root cause analysis (No.1005) for the failure of the SW pond Reactor Building Cooling Unit return isolation valve (XVG-3107A-
_The bronze worm gear in the valve Limitorque operator had failed,
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preventing closure of the valve.
The root cause analysis was initiated because of the wide applicability of Limitorque operators and potential generic concerns.
The most probable cause of the failure identified by the licensee's analysis was cyclic fatigue resulting from operator torque settings that produced loads in excess of vendor recommendations.
The licensee based this conclusion on the high torque settings found in examination of the operator
.following the failure.
The team considers that the analysis performed to reach
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to this conclusion was somewhat shallow. The particular valve is normally shut and is cycled only under emergency conditions and during performance tests.
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Whether this occasional cycling was sufficient for cyclic fatigue failure is in
question.
No metallurgical analysis of the bronze material was perforned.
Based on historical evidence, the probability of occurrence of this type of
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failure appeared to be low,
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2.f Miscellaneous Maintenance Work Observations The team observed 22 miscellaneous in-process maintenance activities:
Work Document Description MWR 9002193 Feedwater Isolation Valve Replace hydraulic
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oil in reservoir
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MWR 9001986 Condensate Return Unit Pump B - Replace shaf t seal MWR 9002055 Turbine Driven Emergency Feedwater Pump - Repair Oil leak at inboard bearing oil sight glass
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PMTS P0140662 Emergency Feedwater Pump Turbine - Perform lube PM PMTS P0138231 Emergency Feedwater Turbine Driven Pump -
Perform lube PM PMTS P0138453 Auxiliary Building-MCC Switchgear Air Handling Unit - Filter inspection / replace MWR 9002004 Demineralized Water Pump B - Adjust pump packing PMTS P0138674 Instrument Air Standby Compressor - Change oil filters PMTS P0127762 Instrument Air Standby Compressor - Bench test receiver relief valve PMTS P0140794 Instrument Air Standby Compressor - Change air filter PMTS P0138673 Instrument Air Standby Compressor - Lube PMTS P0138747 Diesel Driven Fire Service Pump - Lube-t
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MWR 9002069 Seal Injection Filter "A" Inlet Isolation Valve
- Adjust packing MWR 9001330 Auxiliary Building Charcoal Exhaust Filter Fan B
- Replace fan flexible duct PMTS P0138168 Turbine Driven Emergency Feedwater Pump -
Calibrate discharge pressure indicator PMTS P0138302 Turbine Driven Emergency Feedwater Pump Loop calibration Discharge Flow Transmitter
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MWR 9002023 Turbine Driven Emergency Feedwater Pump Calibrate flow Discharge Flow Transmitter
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transmitter PMTS P0138171 Charging / Safety injection Pump Room 3 Hi Temperature Alarm - Calibration PMTS P0138625 Emergency Feedwater Pump Air ilandling Unit B Filter - D/P calibration Sury. S0041533 Emergency Feedwater Pump Suction Header Pressure Transmitter - Operational test i
Surv. S0041625 Refueling Water Storage Tank Level Transmitter -
Operational test
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l Sury. S0041661 Reactor Building Contcinment Hydrogen Concentration Monitor Train B - Operational test These observations revealed that, in general: work was performed in a professional manner, craft and supervision were knowledgeable and conscientious about their tasks, there was a strong emphasis on following procedures, good use was made of vendor manuals and literature. QC was heavily involved in the maintenance process, HP support was good, verifications of correct materials and parts appeared good, and system engineers were involved in field maintenance activities.
A safety conscientiousness was evident in the plant.
During observation of MWR 9001986 on the Condensate Return Pump B, the team noted that the pump was disassembled and a number of internal parts were replaced.
The MWR did.not specify post maintenance test (PMT) requirements in-Section II of the MWR as required by paragraph 6.8.2.0 of procedure SAP-601.
Although not specified in Section II of the MWR, a PMT was performed and documented.
(These and other problems with the PMT program are discussed
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further in paragraph 3.b.)
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29 Instrument Calibration The team's inspection of instrument calibration included observation of eight jobs involving instrument calibration work, a tour of the metrology lab, and examination of measuring and test equipment controls.
Each cf the areas inspected, except for work observed, is discussed below.
Wrk observed is included in Section 2.f (last eight work documents listed).
Control of measuring and test equipment was good.
The team reviewed procedure SAP-141, Control and Calibration of Measuring and Test Equipment, Rev. 5, which outlines a good program. Maintenance personnel consistently recorded equipment identification numbers on p ocedures and verified that calibration dates were not past due.
The team reviewed a sampling of Defective Precision Instrument Reports (DPIR) and concluded that there were adequate controls to ensure that out-of-calibration and defective instruments were not being used to work on plant systems. All calibrations were traceable to national standards and had a 4 to 1 calibration standard.
The team noted that the metrology lab's filing system was very thorough.
It contained complete records for the life of any instrument, including jobs it was used on, calibrations performed, and any DPIRs with their resolutions.
2.h Check Valves The team inspected the licensee's Check Valve Program and its implementation to assess its adequacy as a response to industry check vaive failure experience.
Both the program and its implementation appeared good, though somewhat late in being initiated.
This conclusion was based on review of the program document and examples of inspection records, associated drawings, and vendor information for valves in the check valve program.
Program preparation and content, check valve inspection procedures, and inspection results were discussed with the cognizant licensee engineer.
The principal impetus for check valve programs such as the licensee's has been recommendations from INP0 steming from their SOER 86-3 and follow-up assessments of associated licensee responses in their periodic evaluations of nuclear plant maintenance.
In February 1986, the NRC contacted the four NSSS Owners Groups and urged them to address concerns stemming from several events involving check valve malfunctions.
In response, INPO issued SOER 86-3 to summarize check valve failure problems and recommend actions to reduce the
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likelihood of future failures.
Additionally, the Owners Groups initiated development of application guidelines and preventive maintenance for check valves. These guidelines were released informally in 1987 and then formally as EPRI Report NP-5479 in January 1988.
They were intended for use by licensee's in developing a response to SOER 86-3, which had identified check valve misapplication and inadequate preventive maintenance as the major causes of failures.
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The licensee's program in response to the industry check valve problems was reportedly developed in 1989 and was issued in January 1990.
The program issuance date was almost two years after release of the formal industry guidance provided in NP-5479.
The team considers this to be an untimely response to the overall industry check valve concerns that resulted in 50ER 86-3 and the guidance in report NP-5479.
NP-5479 provides guidance for determining if proper check valve selection and installation were made in the original plant design and for preventive maintenance actions and modifications to improve reliability.
In the team's experience, important aspects in development of a check valve program based on the guidance in NP-5479 include:
a oesign review to identify potentially unsatisfactory check valve
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applications a review of maintenance history to identify problem valves
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an engineering evaluation to select valves for inspection and
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monitoring based on the design and maintenance history reviews described above, valve importance to safety and plant operation, and industry experience (alternatively, design changes may be specified which reduce or eliuinate the need for inspection or monitoring)
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implementation of the above inspection and monitoring as-well-as such check valve modifications as are determined appropriate
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periodic updating of the check valve program based on subsequent internal and industry experience with check valves and on any design changes significantly effecting the functioning of the valves The team found that the licensee appeared to have prepared and implemented a check valve program appropriately responding to industry concerns and the i
guidance in NP-5479.
The program identified and categorized check valves for
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inspections and monitoring based on engineering design review, maintenance and surveillance history, importance to safety and plant operation, and industry experience.
The June 1990 update of the check valve program listed 127 valves important to plant safety and reliability and 29 other valves selected because they had a history of failure.
These valves were assigned inspection and monitoring priorities of 1 (highest), 2, or 3 using subjective ratings based on valve size, design, installation relative to flow disturbances, orientation, maintenance and test history, fluid velocity, and time in service.
The team's review of flow diagrams for four plant systems (Service Water Diagram
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302-222, Feedwater - Diagram 302-81, Emergency Feedwater - Diagram 302-85 and Main Steam - Diagram 302-011) and historical and design data for nine' valves in the systems (1013-EF,16058-FW, 2876A-MS, etc.) found that the valves from the
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I drawings had been properly selected for the program and, for the nine valve i
. examples, prioritizations were appropriate.
Records for program required inspections of two of the valves (28768-MS and 31358-SW) were reviewed and
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found to have proper inspection criteria, including provisions for checking and recording key dimensions (for evidence of wear) as recommended by NP-5479.
Most of the valves in the licensee's program have not yet received internal inspections for wear or degradation, which are a primary component of the intended preventive maintenance, in addition to prioritizing the check valves as described above, the program divides them into groups similar in design and service.
It states that it is intended that one valve from each of the groups will receive an internal inspection by the end of the seventh _ refueling outage.
At the completion of the fif th refueling outage in June 1990, 7 of the 16 priority 1 and 4 of the 12 priority ? groups had no valves that had received the internal inspections planned in tha program, The team does not consider this timely considering it is a response to a 1986 INPO SOER and to related industry guidance issued in January 1988, 2.1 Radiological Controls
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The team's scope for this element of the u sessment was to determine the extent to which radiological controls were integrated into the maintenance process.
Based on a review of radiation protection procedures, interviews with maintenance personnel, observation of work, and a review of maintenance related
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The inspectors also interviewed selected maintenance workers to assess their awareness and perception of the licensee's radiation protection activities.
The team determined that good lines of communication existed between groups.
The team interviewed 7 mechanical maintenance personnel and 4 I&C technicians and asked each a series of questions concerning the radiological protection program.
The interviews were made to evaluate communications between health physics and maintenance personnel and the workers impression of support provided by the site radiological protection program.
A summary of the interviews was discussed with the site Radiation Protection Manager.
The maintenance workers indicated that communications between the health physics and maintenance groups were good.
The maintenance workers reported that the health physics staff was responsive to individual questions reguarding radiological controls and that licensee management was strongly committed to radiological safety.
They stated that the health physics staff generally provided timely and sufficient radiological protection support for planned and unscheduled maintenance activities.
q The team reviewed radiation protection and maintenance personnel interfaces in maintenance work planning and preparation, radiological controls on specific iobs and plant areas, and licensee efforts in maintaining occupational radiation exposures as low as reasonably achievable (ALARA).
Through interviews with maintenance, planning, and radiation protection personnel the
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team determined that the radiation protection staff and ALARA technicians worked closely with the site maintenance planning group reviewing all maintenance work requests for operation and outage activities.
Radiation protection support for maintenance activities was good.
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The team reviewed procedures and guidelines delineating the heal;n physics group responsibilities and required radiation protection activities related to the support of maintenance work in radiation areas.
Those documents described controls adequate to ensure that the level of involvement and support were commensurate with the degree of radiological hazards incident to the job being performed.
The licensee's collective personnel dose of 23 person-rem in 1986 was among the lowest in the. country.
However the collective doses for 1987 and 1988 were approximate 1.5 times the national average for those years.
The collective dose increased significantly in those years due to radiation level increases in plant systems and considerable steam generator maintenance.
In 1989 the collective dose of 61 person-rem was again one of the lowest in the country.
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The 1990 collective dose, through the end of the inspection, was approximately 405 person-rem with most of the dose, 390 person-rem, occurring in a refueling outage.
The two major dose projects for the outage were the steam generator and Resistance Temperature Detection (RTD) nodifications, having 95 and 103 person-rem respectively.
Excluding the one time RTD modification, the licensee's collective dose for 1990 would be it the national dose averages for recent years.
The RTD modification removed 675 feet of piping and tubing of various sizes, two manifolds, nine valves, and numerous supports from containment, lhe modification replaced the 016 RTD system with well mounted RTDs that should result in reduced maintenance and radiation dose levels in the recirculation loop compartments during future outages.
The licensee improved maintenance efficiency on some high exposure jobs with the application of robotics and improved mock-up training.
The licensee recently implemented a new incentive program for the ALARA Suggestion program that awarded prizes for program improvements suggested by staf f personnel.
This stimulated staff interest.
Prior to the new program, the average number of suggestions submitted per year had been 4 or 5.
The licensee received 116 ALARA suggestions in 1990.
Interviewed maintenance workers also reported the incentive program indicated that management was strongly committed to reducing collective personnel exposure.
The team determined that maintenance managers established an annual collective personnel _ dose goal based upon the planned work and exposure history for those tasks.
The goals were submitted to the ALARA Connittee for approval and their status was posted at several locations throughout the facility.
During interviews with maintenance personnel and front line supervisors the team determined that the interviewed personnel were not aware of their department goals. The awareness of goals and participation of radiation workers and their front line supervisors in the ALARA program activities for identifying and-implementing dose savings is necessary for maximizing the effectiveness of the ALARA program.
The lack of awareness of maintenance personnel of maintenance dose goals is considered a program weakness in the licensee's program to minimize collective personnel dose.
In general, the licensee's ALARA program appears to be very accurate at estimating and tracking job and group exposures and effective at reducing personnel exposures on jobs that - have undergone thorough ALARA analysis.
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The team reviewed selected Radiation Work Permits (RWPs) written for routine snd special maintenance activities.
The RWPs were reviewed for appropriateness of the radiation protection requirements based on work scope, location and conditions.
During tours of the plant, the team reviewed the licensee's posting and control of radiation areas, high radiation areas, contaminated areas, radioactive material areas, and the labeling of radioactive material.
The team found areas were properly posted.
The team verified that posted high radiation areas were secured.
The team found the licensee's program to control contamination at its source to p
be excellent.
The area of the facility c o taminated during the inspection was very low at 0.05 percent of 157,000 square feet that included the auxiliary, intermediate, and fuel be'idings.
Maintenance workers reported that the housekeeping and cleanliness of the facility made many maintenance work activities more efficient.
The licensee provides Advanced Radiation Worker (ARW) training for some maintenance personnel.
The training program provided maintenance workers with classroom instruction and laboratory exercises to permit the worker to perform their own radiological surveillance within limited radiological conditions.
At s
the time of the inspection, the licensee had approximately 250 maintenance workers that had completed the training program.
Interviewed maintenance workers reported that the training had provided them with insight for application of radiation protection considerations and controls.
The workers
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reported that most of the radiation protection monitoring skills developed in ARW training were rarely used but very beneficial when needed.
The licensee's Radiation Protection staff with 22 Health Physics (HP)
technicians was one of the smallest in the country.
The licensee routinely utilized ten vendor HP personnel to supplement the staff in non-outage periods.
The team determined that some of the vendor HP personnel also fill shift lead positions.
The turnover rate for those vendor personnel has been very low.
The licensee had planned to add 5 permanent positions in 1991, but the plan was delayed when the positions were removed from the budget.
Vendor HP support in outages was ample. Maintenance personnel reported that the support from the HP staff during routine operations and outages was usually sufficient and timely.
The low turnover rate for radiation protection and maintenance workers was-another factor that increased - worker efficiency and decreased collective personnel exposures.
Overall, the licensee's radiation protection program is effective in supporting and protecting the health and safety of plant maintenance staffs and is a program strength.
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ISSUES AREA WITH MOST SIGNIFICANT STRENGTH 3.a Procurement
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l The team found that the licensee had a particularly good program for procurement of materials, parts, components, and services for safety-related i
applications. This finding was based on reviews of procedures, a vendor audit, and the records for one procurement; and on discussions with licensee personnel.
The procurement process as-well-as the methods used to upgrade (dedicate) commercial grade items (CGIs) for use in safety-related applications were examined.
The licensee's procurement process adequately provided for upgrading CGIs for use in safety-related applications.
Prior to the issuance of guidance in EPRI
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Report NP-5652 in March 1988, there were no guidelines in the nuclear industry for procurement and dedication of CGis for use where the requirements of 10CFR50, Appendix B and 10CFR21 were applicable.
NP-5652 was developed by the industry and its guidelines-for procurement and dedication of CGIs are generally (with a few exceptions) acceptable to the NRC.
In discussions with the Summer plant's Manager of Materials and Procurement and their Procurement Engineering Supervisor the team found that the licensee had been using concepts and principles similar to those specified in NP-5652 since early in the construction phase of the plant.
They were determined to have had a progressive program with dedication that has generally consisted of qualifying items to the most stringent end use requirements to Jtimize parts availability and stocking levels.
The licensee was one of the first to recognize that procurement was truly an engineering function and established a procurement engineering organization on site in 1984 This organization is currently authorized 49 positions and consists of 4 sections - Materials, Procurement Engineering, Procurement Quality (vendor audit group) anti..eceiving Inspection.
Procedures reviewed by the team reflected the adequacy of the program.
They included SAP-136, Materials System User Procedure; ES-321 Procurement of Materials - and Services; ES-322, On-Site Certifications; ES-326, Procurement, Management and Use of ASME Code Material;. and ES-361, Receiving Inspection.
Discussions with materials storeroom and receiving inspection personnel concerning the receiving inspection process and the return of unacceptable items disclosed that they were knowledgeable of the requirements of procedures SAP-136 and ES-361.
The-team traced the procurement and issuance of one example of parts used in a maintenance activity observed by the team (PhTS P0138302, as noted in Section 2.f above).
The parts were o rings for a lurbine Driven Feedwater Pump Flow Transmitter.
Documentation r:xami ned by tne team included the pertinent instrument control procedure (ICP-195.003), tne stores requisition for parts (No. 632934), the o-ring purchase request / order (371551/A541296), the receipt inspection requirements for the o-rings (which included dedication requirements), the requests for and results of independent laboratory testing utilized in the dedication process (Request for Test No.113 and Purchase Order A477895),
the receiving inspection report (M-7119),
and the conditional approval of the test lab as a vendor.
All documentation was found complete, properly traceable, and readily retrievable; and it demonstrated proper procurement and dedication.
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The team concluded that the licensee's evaluations of supplier quality
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performance provided proper assurance that items and services met specified requirements.
This conclusion was based on discussions with procurement engineers, vendor auditors and their superiisors; and on review of the licensee's vendor audit of the independent test lab mentioned above in regard to dedication testing of the 0-rings.
The laboratory had a documented QA program that committed to 10CFR50 Appendix B, ANSI N45.2, and the reporting requirements of 10CFR21.
However, the licensee's audit of the lab disclosed that the 0A program was not being fully implemented.
The NRC team found that, to assure the adequacy of work perforned for the Summer plant, the licensee j
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instituted cnntrols to limit the work the lab would be permitted to perform to activities where adequate controls had been implemented.
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Discussions with the licensee disclosed that they had been actively participating in industry groups developing information and standards to aid in obtaining appropriate quality and effectiveness in procurement for nuclear
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plants.
They were identified as members of the Nuclear issues Procurement Committee; the EPRI Joint Utility Task Group (provides training on performance
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based audits of large vendors); and the Industry Management, Purchasing, and Procurement Issues Committee.
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The NRC team found the licensee's procurement organization and process to be significantly better than that they have typically observed in the industry and considers it a strength.
AREAS WITH MOST SIGNIFICANT WEAKNESSES 3b Post Maintenance Testing (PNT)
The current PMT program is defined by the following procedures:
SAP 601, Revision 7, Application, Scheduling and Handling of Maintenance Activities GTP-703, revision 1,
General Guidelines for Post Maintenance Testing Based on observation of maintenance, review of completed MWRs, and review of the above procedures, the team identified the following deficiencies with regard to PMT:
The MWR form-does not provide a check of f block to indimte PMT
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requirements.
The " Retest" block on the MWR is used only for operabili t) retest to meet TS requirements and not for specifying PMT requirements.
In many cases " Retest" requirements will satisfy PMT needs.
Procedure SAP 601, paragraphs 6.6.2 and 6.8.2, requires that all MWRs be evaluated for PMT and that PMT requirements be entered by the planner in Section II of the MWR.
However, these are relatively new procedure requirements and have not been fully implemented vet.
Licensee personnel indicat:J that, in the past, most MWRs received some type of PMT, although not documented.
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for the completed RHR system MWRs reviewed, ncne documented PM'f
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requirements or performance, except for fS operebility retest requirements, which were performed as required.
For the in-process maintenance observed, most of the MWRs did not contein PMT requir?ments in Section II, although some MWRs (e.g., MWR 90001986)
documented PMT performance.
The PMT program, as detailed in procedure GTP-703, was not well-
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defined. - Rather than provide explicit requirements, the procedure eses terms such as,
...provides... post maintenance tests..for
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consideration" and " provide guidance".
Licinsee management stated that the weaknesses in the PMT program had been recognized and a new PMT procedure was in process prior to the start of the inspection.
During the -inspection, a draf t of the procedure, GTb 214, was prnvided to the team.
The draft procedure provides a PMT matrix for different types of equipment and dif ferent kinds of maintenance and a MT sheet which will become part of each MWR, As stated above, the. licensee indicated that PMT had been performed for most maintenance, although it was not not well-documented.
Since there is littie
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documentation, the level of PMT in the past cannot be evaluatad.
Therefore, based on the lack of documentation and the procedure weaknes:-
noted above, the team considers the program in placc at the time of the inspection to be weak.
However, the team did not identify eouipment problems related to poor PMT and it appears the new program in preparation will correct the program weaknesses identified above.
3.c System Engineering The team observed weaknesses in the licensee's system engineering.
Although the system engineering -program had been established for approximately two years, it was not yet fully implemented.
The licensee currently had 25 engineers assigned system engineering responsibilities-(18 of which were in the system engineering group, the remaining were desi assignments under the system engineering program)gn engineers who had systen The experience level of
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system engineers was quite low; about half of the engineers had been assigned their systems for less than one year.
Of the 25 total system engineers 12 were qualified on one system only.- The remaining had not yet qualified. -Most of-the system engineers had responsibility for several system, however after -
qualifying on one system there had been little ef fort made toward qualification on their subsequent systems.
The qualification process is described in procedure ES-102, Personnel Indoctrination and Training / Qualification.
It includes the requirement to deve10p a system file and a state of the systwn composition which details operational and material condition of the system. As a result of few systems with qualified engineers, system compositions and a complete system file did not exist for most systems, including many of the major plant systems.
There was some evidence that the work load among system engineers was not very evenly distributed with some engineers assigned a larger number of systems or groups of systems that require more work than others.
This is probably attributed to the fact that many system engineers were new and
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not yet able to handle a large work load.
The amount of computer equipment allocated for system engineering was less than adequate with only one personal computer shared among all of system engineering.
From a positive standpoint the system engineering program as described in ES-157, System Engineer, Revision 2, was good.
All completed MWRs were being
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reviewed and signed off by the system engineer, System engineers frequently performed system walkdowns and documented. deficiencies.
The system engineers were found to have a good working relationship with the maintenan:e personnel.
During the inspection, the licensee deveh ied a list of System Engineering Goals for 1991, which included goals tc.
qualifyin9 more system engineers.
3.d Backlog Control
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The team evaluated the licensee's contrel of maintenance backlog.
It was determined that there was no fornal written program for control of backlog.
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However, backlog statistics, in the form of a Corrective Maintenance MWR Backlog graph showing the total.open non-cutage corrective maintenance MWRs and the total open MWRs greater than 3 aonths old (broken down by discipline), were issued each ronth as part of the Maintenance Services Monthly Report.
The report for November 1990 showed a total backlog of 724 open, non-outage, corrective maintenance MWRs.
Of the 724, 403 were greattr than 3 months old.
Although quarterly data since mid-1986 indicated an apparently increasing long term trend, data for the last half of 1990 showed a significent decrease in the number of open, non-outage MWRs.
Neither the conditions observed by the team during walkdowns or review of
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s.aintenance records indicated the backlog was causing neglect of important maintenance.
The number of plant cnd equipment conditions needing corrective maintenance, obst: si during team walkdown inspections was considered relatively small and none appeared serious, The-team reviewed summary descriptions of all backlog MWRs greater than 3 months old for the systems covered in paragraphs 2.a through 2.e and f ailed to identify any for which delay appeared safety significart.
In addition, the summary descriptions were
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reviewed with maintenance personnel and, in general, the reasons for delay were justified.
in addition to not having a formal program for control of backlog, the following weaknesses were ioentified:
Backlog was only trended for the licensee's category 1 and 2 PMs
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(mandatory PMs and PMs required by regulatory committment t>r for
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nonconformance disposition). Numerous other overdue (past "End Date") PMs were not being tracked and trended making determination of PM backlog very di f ficul t.
See Section 3.e for further discussion.
Maintenance performance indicators and goals, including backlog,
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were not as well-defined or displayed as is typical in the
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2A indus try.
Goals for maintenance performance indicators had not been set in many cases.
During the course af the inspection, Maiatenance Services had a procedure in preparation, MSI-37, which is intended to improve tracking and trending of maintenance performance indicators and goals.
The licensee indicated that a plant wide trending program is being considered.
Also, some maintenance performance indicator goals were set during the inspection.
3.e Preventive Maintenance (PM)
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The following problems were identified with the PM program:
During review of the PM schedule for the RHR pumps, the team noted
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that the PM schedule specified lubrication (inspection / change)
annually for the pump bearings.
The vendor manual recommends a frequency of 6 months.
The team questioned the licensee relative to justific:, tion for the annual versus 6 month lubrication.
After
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review, the licensee found that the proper engineering justification for the change was documented in the Equipment Qualification (EQ) Manual, Further, review by the team revealed that the M proedure (SAP-143) and associated procedures did not
clearly define how and from what documents (vendor information, EQ manual, lubrication manual, etc.) PM requirements are derived.
Also, the-procedures did not clearly indicate that deviations from vendor PM requirements should be justitied.
Based on interviews with responsible personnel and review of sample records, it appeared that proper justification was used for deviations, even though procedure requirements were not clear. At the conclusion of the inspection, the licensee was revising SAP-143 to clearly specify requirements for deriving PM requirements and justifying deviations from vendor requirements.
Du ring review of backlog controls, the team found that overdue-
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licensee category 3, 4, and 5 (lower category) PMs were not being trended.
These categories include. significant preventive maintenance tasks - such as PMs required to comply with vendor warranty / service agreements (category 3), PMs recommended by the equipment manufacturer (category.4), and oil analyses (category 5).
In the absence of backlog data on these PMs, it could not be readily determined how many significant PMs were being deferre6.
Further, some PMs (e.g. those with a refueling outage frequency or a one time frequency) not performed by their "End Date" and deferred, are not automatically rescheduled, leaving it to someone remembering to re-schedule.
Also, procedures do not have any constraints on how long a PM can be deferred.
If a 5 year PM is not performed by its required "End Date" and deferred, it will not be re-issued for performance until 5 years later.
The licensee acknowledged these weaknesses and indicated improvements would be made.
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I Category 4 pMs exceeding their scheduled "End Date" can be i
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justifiet for deferral by the maintenance discipline supervisor if
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deferral is rot significant to the plant in mitigating a plant tiansient or trip.
The team questioned whether _ this decision i
(significance to plant in mitigating a plant transient or trip)
should be made at the maintenance supervisor level.
Licensee d
maintenance management agreed with this concern and at the conclusion of the inspection, procedures were being changed to
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require department manager approval for deferrels.
All category 1 and 2 deferrals require engineering review.
With exception of the above weaknesses, the licensee appeared to have a strong l
pH program.
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3.f Acknowledgement of Risk Significance in the Maintenance process i
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The team found the licensee had no formal precess to evaluate and consider risk
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ie the maintenance process.
Discussions with planning, maintenance, and engineering staffs revealed that risk was considered only in -the distinction between Technical Specification equipment versus non-Technical Specification equipment and safety-related equipment versus non-safety-related equipment, for prioritization of work, it should be noted that this distinction is primarily
for operability considerations.
These discussions further revealed that:
In response to Generic Letter (GL) 88-22, a Probablistic Risk i
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Assessment (pRA) is being prepared and Engineering anticipates the assessmer' will be cor.1 * ~ ed by September,1992, Engineering has also itiated a Reliability Centered Maintenance i
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(RCM) program.
The licensee anticipates that it will take 3 years to complete the program.
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The pRA and RCM results will be integrated into the maintenance program to
ivrove -the overall program and provide risk considerations in prioritizing ws.
3.g Rcot Cause Analysis The team determined that, while the licensee's program for roo't cause analysi's I
and its implemmentation were producing some good analyses, the program was i
still in an early stage of development and exhibited son.e weaknesses.
The program had not produced many analyses.
Although the analyses performed _ dated back to 1088, only 12 had been completed as of the start of the NRC maintenance team inspection (8 were in progress).
The associated adm_inistrative procedure
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and guidance document had only been recently issued (September 1990) and, while they generally contained sufficient details regarding performance of the analyses, they were lacking in some areas.
The threshhold for analysis initiatic,3 did not appear well-defined in the procedure or guidelines and there
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was no formal provision for monit +ri/19 or tracking important analysis-related I
details :,uch as timeliness of progress and sumary reports, completion of
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corrective actions, and aessment of corrective action offectiveness.
There was excessive use of permistive "shoulds" in both the admiMstrative procedure (SAP-900 Section 6.4) and the guidelines ( D,oot Cause Analysis Guidance, Section 6.8).
The licensee's formal program appears intended only for analysis L
of the causes of evtats of the highest importance and would benefit f re,u
provision for more frequent but less detailed analyses of equipment failures of lower importance.
The program would also benefit from the development of a hardware failure analysis library.
Three root cause analyses were reviewed by the team.
Two involved failures of components in systems specif Mally examined by the team and are discussed under their respective system headings in Sections 2.c and 2.e of this report (analyses Nos.
1007 7300 Instrument Cards and 1005 MOV Operations,
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respecti' fly).
The third, Nc. 1014, was a partially completed analysis involving the October 1990 failci*e of Reactor Coolant Drain Tank Pump Xp00510.
Two of the three analyses were considered well-performed (Nos. 1007 and 1014).
The other (No.1005, MOV Operations) appeared shallow in that it failed to adequately address uportant details of the failure, as described in Section 2.e of this report.
Positive aspects of the licensee's root cause program and its implementation included widespread training of persornel in root cause analysis (though details of the training were not assessed by the team); administrative
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provisions assigning initial responsibilities and requirements for gathering date and for standardized reporting of results, and the two analyses referred to above that appeared to be well-performed and documented (both of which were more recent products of tN program than the analysis referred to negatively above).
3.h'
PredictiveMaintenance(PDM)
'4 im evaluated the licensee's PDM and determined that its overall impact on i
ae maintenance was positive.
PDM data was being used effectively for pre icting some maintenance needs; however, the trending and utilization of the data obtained was inadequately prescribed procedurally and represented a weakness. The following summarizes the inspection findings:
Vibrational Analysis (governed by procedure EMP-295.005)
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The Vibrational Analysis program was administered by the Electrical Maintenance department.
Vibration measurements were being taken monthly on approximately 100 pieces of rotating equipment including safety related pumps and__ motors.
Electrical Maintenance performed some trending of the data.
However, the equipment in use was not state-of-the-art equipment and trending had _ to be accomplished manually. The administrative procedure was not definitive relative to how the data was to be trended and used for predictive purposes.
Oil Analysis (governed by procedure CP-400)
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The Oil Analysis program was administered by the Chemistry Department.
The program was very detailed and required sampling about 70 points on all different types of equipment, including safety-related pumps and motors.
Very detailed analyses were being performed.
Sophisticated equipment was available for analysis and trending and was beino used mostly to determine the timing for lubrication changes.
In addition, the results were being used to predict some equipment problems.
However, the procedure lacked details on what was to be trended and how the trended data was to be useu ~~r predictive purposes.
Thermography (governed by procedure EMP-300.008)
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The Thermography program was administered by the Electrical Maintenance Department.
The procedure included only a minimal number of pieces of equioment and lacked detail on what was to be trended -and how the data was to be used for predictive purposes.
The licensee had recently procured new state-of-the-art equipment and was starting to use the equipment with good results.
Although PDM tools were in place and being used to various degrees, the team considered PDM to be weak programmatically, based on lack of administrative details on what data was-to -be trended and how the data was to be usad for predictive purposes, in addition, the Vibrational Anals sis equipment being used was not state-of-the-art and could provide only limited analysis and trending data.
Planned progranrnatic improvements should correct these weaknesses.-
3.i Personnel Safety Concerns The following personnel safety concerns were identified:
An electrical supervisor conducting a training session on the
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operation of a 7.2LV circuit breaker accidentally caught his hand in the operating mechanism of the breaker.
The supervisor, in order to maintain-his orientation with respect to the circuit breaker while reading the procedure, used one hand to hold onto the breaker while using the other hand to operate the breaker release mechanism.
The breaker release mechanism when activated hit the supervisor's hand causing injury.
The team feels that an occurrence of this type is an indicator that an inadequate level of attention may have been given to the implementation of safe work habits in the maintenance process.
The safety of workers may have been inadequately considered in the
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frequent replacement of. clip fasteners in 480 Volt motor control centers.
These fasteners are located one to two inches from a normally energized uninsulated bus near the back of motor control centers.
The maintenance worker who inadvertently comes in contact with the energized bus during the replacement process is subject to
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injury or oossible death, personnel indicated to the team that
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there had been several incidents during the replacement process when rerious injuries nearly occurred.
The torque value for
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fastener installation was initially established by manufacturer recomended practice at 20 f t-lbs.
This torque caused a 75 percent
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failure rate.
To reduce the number of failures, the licensee requested a reevaluation of the initial 20 f t-lb recommendation and
i it was reduced to the currently used 15 to 20 f t-lb value.
This
lowered the failure rate of the original fasteners to an estimated
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25 percent.
Both maintenance personnel and the team agreed that the subject torque could have been decreased to 5 f t-lbs with it likely that the fastener failure rate and the personnel safety
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concern would have been eliminated without compromising the manufacturer's design, in response to continued failures and personnel safety concerns, the licensee developed tools and
techniques to improve personnel safety in the replacement process, in addition, the previous fasteners were reportedly being replaced when they failed with improved fasteners that were not experiencing failures.
It would appear then, that the personnel safety hazard
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could be wholly eliminated by deenergiring the butes during an
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outage and replacing the previous fasteners with the improved version.
In maintenance observed by the team and described previously in
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Section 2.d above, a worker failed to manually exercise a breaker as a personnel safety precaution specified by step 7.2.6 of procedure EMP.280.004
!&C and Electrical maintenance personnel were observed to
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habitually remove their hard hats at their job site, including iobs that are located in the Auxiliary Building which is a "Hard Hat Area."
This may have been appropriate from a pre tical standpoint for some, but not all, of the jobs involved.
Aside from the examples describe.d above, the personnel safety practices observed appeared good.
Rubber safety gloves were used while working on energized equipment.
In addition, safety glasses, hearing protection, safety l
shoes, and warning signs were ob;erved being used in the maintenance process.
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3.j Work Request Entry Deficiencies Although there were good written requirements for maintenance work request completion reviews, numerous entry deficiencies were found on the record copies.
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of completed work requests.
The deficiencies identified were minor, except with regard to post maintenance testing, and were as follows:
Various information and requirements were not recorded in the
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" Planning a 'id Scheduling" portion (Section II) of the MWRs.
Comonly occurring examples included entries indicating whether the equipment involved was code class, HP or QC coverage was necessary,
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4 and retesting was required to verify operability. Also absent were
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post maintenance testing criteria entries - required by a recent change to procedure SAP-601
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There was inconsistent use of "CAUSE DESCRIPTION" codes recorded in
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MWR Section Ill.
In an example observed, three different codes were used on different MWRs for the same type problem (adjustment of valve packing).
In-so-far as the team could determine, the entry deficiencies identified had not impacted the licensee's actual performance of maintenance.
4 EVALUATION OF MAINTENANCE i
Summary Rating of Maintenance Process:
Program:
GOOD Implementation: GOOD The evaluation completed by the NRC team rated the Summer maintenance program and its implementation GOOD.
This maintenance rating was obtained by collating and assessing the maintenance team inspection findings in a special maintenance inspection logic tree.
The tree completed for the Summer maintenance inspection is depicted in Appendix 3.
The tree divides maintenance evaluation into three " parts" (I, II, and 111).
The parts are divided into eight " areas" (1.0 throuch 8.0)- and -the areas into individual maintenance to or
" elements"(1,1,1.2,2.1,etc.).
Based on their inspection findings (picsnegative and positive),
the team established ratings for_ most of the elements.
Subsequently, area ratings were determined based on associated element ratings; part - ratings based on the associated area ratings; and, finally, a total maintenance rating was determined from the ratings for the parts.
The team did not weight all findings or ratings equally.
Four rating categories were used and a color was assigned to each to aide in displaying the ratings -on the naintenance inspection tree.
The rating categories were as follows:
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" Good" Performance (Gree-)
Overall. better than
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adequate, shows more than minimal effort; can have a few minor areas that need improvement
" Satisfactory" or " Adequate" Adequate, weaknesses
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Performance (Yellow)
approximately offset by strengths
" Poor" Performance (Red)
inadequate or missing
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(Blue)
Not evaluated or insufficient
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information to evaluate Each part, area and element, as well as overall maintenance, is represented by
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a block on the tree.
Most of the blocks are split into two parts with the upper portion representing program or process and the lower half representing implementation.
The exception is for the part I blocks which are not considered to have separate programs or implementation.
The parts and areas of
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the maintenance inspection tree are described below.
The inspection findings that contributed to the ratings are also given.
Individual element ratings are not described but are shown in Appendix 3, 4.a Overall Plant Performance Related to Maintenance (Tree Part 1)
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Rating:
GOOD This part of the tree is an overall assessment and rating of maintenance through direct measures:
Its rating was based on the rating determined for
" direct" measures below.
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4.a(1)
Direct Measures (Tree Area 1.0)
Rating:
GOOD
The direct measures used to assess this area are the examination of plant historic performance data (tree element 1.1) and observations of housekeeping and materfel conditions observed in walkdown inspections (element 1.2).
Historic data examined included availability, forced outage rate, engineered
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safety feature actuations, scrams, radiation exposure, maintenance backlog, and LERs.
The team's-walkdown inspections and detailed examples of their observations are described in report Sections 2.a through e above.
The historic data and walkdown findings considered by the team in determining the rating for this area were as follows:
Three year (1987-89)- data on availability, forced outage rate, ESF actuations, and scrams was-judged to indicate average to somewhat above average performance.
The availability and forced outage rate data was obtained from NRC NUREG Report-0020 and the ESF actuation scram data.from NUREG-1272.
A tabulation of the data is given below.
Data Type Summer All Plants
-- Availability -
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73%
- --69%
Forced Outage Rate 10%
12%
ESF Actuations 5.0 9.2
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Scram Rate 0.66 0.47 Review of licensee supplied availability and forced outage rate data for 1990 revealed a further improvement'in three year averages to 77.2 and 8.1 percent, respectively.
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31 Personnel collective radiation exposure data provided by the licensee showed 391 manrem attributed to their 1990 refueling outage and 11 manrem for the i
remainder of the year through October 1990.
The licensee stated that the principal contributors to the collective dose were steam generator and RTO work.
Their dose goal for 1990 is 410 manrem or less and it appears that this
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will be acheived.
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Overall, the maintenance backlog did not currently appear excessive to the team based on their experience.
However, an apparent adverse t_ rend of gradually increasing corrective maintenance backlog which may require attention was noted.
Important considerations reviewed by the team in reaching these conclusions were as follows:
The non-outage corrective maintenance backlog of MWRs was
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reportedly 762 as of the ens of Octobei 1990.
The last six months data showed a significant decrease in the
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i-non-outage MWRs; however, quarterly data covering the period since mid-1986 indicated an apparently increasing long term trend.
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About 60 percent of the MWR backlog was inore than three months old.
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The team did not assess the preventive maintenance backlog because
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the licensee only tracked part of this backlog, failure to meet schedule was trended only for the most important preventive maintenance items - those with no grace period, that are performed to meet a regulatory requirement, or that are performed to comply with the disposition for a noncompliance.
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Neither the conditions observed by the-team during walkdowns nor
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their review of maintenance records indicated the backlog was reaching a size that resulted in neglect of important maintenance.
The number of plant and equipment conditions observed to require corrective maintenance during team walkdown inspections was considered relatively small and none appeared serious. A review of
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examples of MWRs in the backlog failed to identify any for which delay appeared safety significant.
The licensee had 23 Licensee Event Reports (LERs) in 1989 and, as of the Maintenance Team Inspection,10 had been prepared in 1990.
Each was reviewed by the team.
No adverse trends in maintenance were noted, though 4 of the 10 generated in 1990 were appeared at least partly due to electrical maintenance (1 of the 4 was caused by an offsite organization).
The team determined that the licensee participated 'in the industry-wide p' ant performance indicator program conducted by the Institute for Nuclear Power Operations (INPO).
The licensee's data for the last three years was examined for a sample of seven of the indicators.
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l Strengthes Good housekeeping and materiel conditions throughout the plant with no major and only a few minor deficiencies noted.
(See Sections 2.a through e)
Histortcal data considered indicative of good maintenance with improvement during the past year.
Weaknesses Some minor deficiencies (leaks) recognized but not deficiency
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tagged and no Maintenance Work Requests written to correct the deficiencies.
The licensee's procedures did not make the
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responsibilities for tagging clear. (See Section 2.a)
4.b ManagementSupportofMaintenance(TreePart!!)
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Rating:
Program: GOOD 1mplementation: GOOD This part of the tree is an assessment and rating of areas of the tree which
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represent management's support of mai'itenance throagh their commitment and involvement, organization and adminitetration, and provision of technical
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support for the maintenance process.
l 4.b(1)
Management Commitment and Involvement (Tree Area 2.0)
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Rating:
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p Program:
GOOD Implementation: GOOD
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This area consists of upper management's direct encouragement and promotion of improvements in maintenance.
The rating of the program and implementation was l
based on the following findings:
Strengths Good support was provided for industry initiatives.
(The team
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examined licensee actions for about
industry experience documents, such as NRC Information Notice 89-01 and INP0 SOER 89-01 and determined they had been properly addressed - the only weakness l
was in the timeliness of the INP0 50ER 86-3 response as described in 3ection 2.h above.
The licensee was also found supportive of
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participation _in industry group and the industry sponsored Nuclear Plant Reliability Data System.
A maintentnce self-assessment was perforned utilizing ihn0 criteria and alnest all criteria were found to be net.)
Plant aging was being addressed.
(The team found th*t the licensee had a procedure for plant equipment aging, ES-604, and a system engineer was responsible for its implemtntation.
The procedure provides for a semi-annual review of survei!1ance test results, maintenance data and f oilure data of environmentally qualified equipment.
If repetitive age related problemn are found, the need for equipment replacenent or improved preventive maintenance is evaluated.)
Good databases had been provided.
(The team found that appropriate raintenance history data was readily sorted ano retreived, parts evailability and storage information was readily available, etc.)
Management was f requently observcd in the plant and expressed interest in maintenance activities.
Organization changes had been made following the 1990 ref ueling outage which appeared to provide better communications and control in support of the maintenance process -
e.g.,
incorporation of maintenance planning into the organization responsible for performance of nechanical ard electrical maintenance.
Weaknesses Performance measurement appeared insuf ficiently utilized.
Examples included the inadequate assessment of backlog data referred to above, failure to set goals for trended measures of craft performance, and f ailure to display craf t performance f rends and goals.
(Report Section 3.d)
The licensee was not timely in initiating a program to respond to industry check valve concerns.
(Report Section 2.h)
4.b(2)
Management Organization and Administration (Tree Area 3.0)
Rating:
Program:
r>00D Implementation:
GOOD This area consists of management's support of and involvement in the control of naintenance through developing and irplerrenting a niaintenance plan, setting goals and policies, allocating resources, defining maintenance requirements, monitoring performance, providing document control and determining the need for
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improvements to plant materiel condition.
The rating of program and implementation was based on the following findings:
Strengths Sufficient maintenance and support personnel had been provided and supervisor to worker ratio in the maintenance groups was low (about six to one in the Mechanical and I&C groups and three to one in Electrical).
A Reliability Centered Maintenance program has been established and j
funded.
The licensee anticipates that it will be completed in 3 years.
Important-maintenance activities, such as preventive and predictive maintenance _ and review and utilization of industry experience, had been incorporated in to the maintenance process.
- Parts and material availability were considered better than is
,
-typical of the industry.
System engineering had been imp 4mented, which should aid in-recognition and correction of maintenance problems.
'
Performance indicators and goals had been established to aide in assessing maintenance and maintenance-related performance.
A program to address plant equipment ~ aging had been established.
(ReportSection4.b(1),STRENGT}iS)
Virtually all personnel with nuclear plant related responsibilities had been located on site facilitating communications in making decisions.
Good radiological controls had been established. (See Section 2.j)
Weaknesses l
Administrative controls were not well-defined for some maintenance and maintenance-related activities.
Particular examples included trending and utilization of predictive maintenance data (Report Section 3.h), derivation of preventive maintenance requirements from vendor data (Report Section 3.e),
and rescheduling of preventive maintenance activities scheduled for one outage and_then deferred (Report Section 3.e).
Performance measurement appeared insufficiently utilized.
Examples included the inadequate assessment of backlog data referred to above, failure-to set goals for trended treasures of craft performance, and failure to display craft performance trends and-goals.
(Report Section 3.d)
_ _ _.,, _. _, _.....
_
-.
.-.
m
.
'
.
The licensee was not timely in initiating a progran to respond to industry check valve concerns.
(Report Section 2.h)
4 b(3)
TechnicalSupport(TreeArea4.0)
Rating:
program:
GOOD Implementation: GOOD This area encompasses the various t'-ments of technical support that are needed-for maintenance to function effectively (e.g..
engineering support, health physics, QC, risk assessment, etc.).
The ratO i of this area was based on the following findings, which collectivel; mintenance strengths end weaknesses.
Strengths There were good communications between craft and supeivision v
including upper management. (This was exemplified by the weekly team building meetings held in each thop, where craf t personnel discussed their problems and concerns with supervision.)
There wene also good communications and cooperatior between maintenance personnel and personnel from interfacing orranizations which provided support for maintenance.
(As noted in Report Sections 2.b. c, d, and i)
q The syste engineering program was good.
(D.eport Section 3.c)
A formal root cause analysis program had been instituted and recent analyses were well-performed and documented, though the program and its implementation exhibited some weaknesses.
(Report Section 3 9)
The radiological protection program provided ef fective support in minimizing dose during maintenance.
(ReportSection2.1)
The procurement organization and process were significantly better than observed in the industry.
(ReportSection3.a)
There was good QC involvement in the maintenance process.
(The team found that QC reviewed work requests prior to the performance as-well-as following completion. Their review includes determining the degree of QC involvement, screening for completeness of the work request form, and determining if the job is safety related.
Several maintenance activities requiring QC involvement were observed by the team and they found that QC coverage was good and that appropriate hold points and inspections were performed and
-
documented.
The team noted that the QC inspectors were knowledgeable, conscientious, and performed their assigned inspections correctly.)
l
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_ _. _._. _ - _._ _ _ _.. _ _ _. -
_ _.._.._ _ _ -
-. _ _ -.
_
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^
The licensee had a strong PM program except with regard to weaknesses in some of the administrative controls.
(ReportSection 3.e)
Weaknesses
'
!
Administrative controls were not well-defined for derivation of PM regl'irements from vendor data and rescheduling of PM activities scheduled for one outage and then deferred.
(Report Section 3.e)
>
System engineers lacked training and experience and had been deficient in developing statu'.
information on their systems.
'
(ReportSection3.c)
Risk factors were not formally assessed and utilized in determining maintenance priorities.
(Report Section 3.f)
'
Root cause analysis administrative controls were deficient in some respects and insufficient analyses were being completed.
(Report Section3.g)
{
Deficiencies were observed in some personnel safety practices.
This included instances where hard hats were not used, motor
.
l contrci center fastener failures replacements performed dangerously close to a live 480 Volt bus, and a poor practice during breaker
'
training which led to injury to the individual performing the training.
(ReportSection3.1)
-
4.c Maintenance Implementation (Tree Part !!!)
r Rating:
Program:
GOOD Implementation: GOOD This part of the tne is an assessment and rating of the work, organizational, hardware and personnel controls necessary to proper implementation of maintenance.-
4.c(1)
Work Control (Tree Area 5.0)
-
-
Rating:
Program:
GOOD Implementation:
GOOD i
l l
la.-.
.------....
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.. - _, -.. - - _ _ -. _ -,, -. - -.,... _ _ _.
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-
.
--
-
-
-
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d
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l This area encompasses assessment of important elements of work control through evaluation of maintenance in progress, work order control, planning,
!
1.
scheduling, prioritizing, etc.
Its rating was based on the following findings:
Strengths
!
Maintenance craf t and supervision observed and interviewed wero i
found to be qualified, knowledgeable and conscientious. (e.g., see
Report Sections 2.d and 2.f)
.
i Craft and supervision had a positive attitude about procedure
,
compliance. (Report Section 2.f)
a
'
,
Based on examples observed, maintenance was generally properly although several omissions of minor electrical performed
'
-
preventive maintenance procedural steps were noted. (Report Section
'
2.d)
Housekeeping and especially cleanliness were well-maintained in the work observed.
.
-
Maintenance history) and detailed recorc- <ere readily retrievable.
(Report Section 3.a
,
Failure histories were appropriately entered into and utilized from the industry sponsored Nuclear Plant Reliability Data System.
(As noted in Report Sections 2.c and 4.b(1))
The experience level of the planning and scheduling staff was high.
Reactor operators and HP personnel had been specifically assigned to aide in the planning function resulting in good coordination among these groups.
Maintenance work reviewed and observed was properly prioritized on the basis of importance as indicated by the Technical Specifications and FSAR.
Associated and same train equipment maintenance were scheduled to be performed together, minimizing out-of-service equipment time as-well-as Technical Specification LCOs.
i Based on the team's experience, maintenance backlog was not considered excessive.
(ReportSection3.d)
There were good written requirements for maintenance work request completion reviews.
(Report Section 3.j)
Some schedulars had been trained to perform as planners to assist when the planning work load was high.
_,_
_. _. _ _ _. _..,. _.. _.... _, _. _. _ _ _ _ _. - _. _ _ _ _ _ _ _ _ _. _. _ _ _
...
.
Problems encountered while performing work were properly resolved.
The rapport observed among maintenance personnel, their supervi-sion, and support personnel from QC, design engineering, and systems engineerin was excellent during problem resolution.
(Report Section 2.d)g Maintenance work performed was well-documented.
(Report Section 2.b)
Maintenance procedures were generally considered good though a number of weaknesses were identified.
These weaknesses, which are listed below, were judged minor in the team's overall assessment of their impact on maintenance.
Weaknesses Signatures verifying completion of steps in maintenance procedures were provided for on sheets at the end of the procedures rather than at the step within the procedure, increasing the risk of omitting steps.
Several procedure steps were missed during performance of electrical preventive maintenance.
(Report Section 2.d)
A deficiency in the procedure description of the "date code" location on newer breakers resulted in a delay of about three hours in performing maintenance.
The licensee had been informed of the corrtet location by the manuf acturer six months earlier in correspondence related to a simil6r incident but the information had not been incorporated into the procedure, (Report Section 2.d)
Risk factors were not formally assessed and utilized in determining maintenance priorities.
(Report Section 3.f)
Post maintenance testing requirements and performance were of ten not documented.
The requirements were not specified programatically.
This was considered the most significant weakness identified by the team.
(Report Section 3.b)
Backlog appeared inadequately assessed, though it did not appear excessive.
(Report Section 3.d)
- dministrative controls were not well-defined for some maintenance and maintenance-related activities.
Particular examples included trending and utilization of predictive maintenance data (Report Section 3.h), derivation of preventhe maintenance requirements from vendor data (Report Section 3.e),
and rescheduling of preventive maintenance activities scheduled for one outage and then deferred (Report Section 3.e).
_. - _. -. - _ __ _ -
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- -. -
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.
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!
Although there were good written requirements for maintenance work
'
,
request completion reviews, numerous minor entry deficiencies were found on the record copies of completed work requests.
Examples i
included inconsistancies in use of cause codes, absence of reference to documentation for test > to confirm operability and omissions of certain planning and scheduling entries.
(Report Section 3.j)
<
..
There was no formalized training and qualification of planners and l
schedulers.
!
4.c(2)
Plant Maintenance Organization (Tree Area 6.0)
Rating:
!-
Program:
GOOD
Implementation:
0000 This area encompasses the processes used by the maintenance organization to i
control, support and direct naintenance activities.
Its rating was based on i
the following findings which, assessed together, indicate apparent strengths
'
and weaknesses:
Strennths
<
Craft and supervision had a positive attitude about procedure compliance. (Report Section 2.f)
There was good cooperation between maintenance and cperations in controlling system configuration and tagouts.
There was proper control and use of vendor manuals and literature.
(ReportSection2.f)
Personnel were accountable for their work.
,
Materials and parts were properly controlled.
(Report Section 2.f)
,
'
Tools and measuring and test equipment were generally maintained
and controlled to assure they functioned prope ly in the conduct of maintenance, although some discrepancies are noted.
(This
,
strength is discussed in detail in Section 4.c(3).)
Most deficiencies were identified -and tagged, though minor deficiencies in deficiency tagging were noted.
(Report Section l-2.a)-
Trending of nonconformance notices and NPRDS data was well-performed and utilized.
(The team found the licensee
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_ _ _ _ _ _ _ _ -
_ __. _
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- - - -
-._-
-
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_ _. _ _ _
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!
t i
i regularly reviewed and trended nonconformance notices to detect any adverse conditions. The team reviewed the licensee's quality trend
report for the first half of 1990 and noted that the report
!
identified similar deficiencies to those they found in their review.
Team findings relative to the licensee's use of NPRDS in
,
identifying an adverse trend is mentioned in Report Section 2.c)
'
!
'
Trending was utilized effectively in predictive maintenance, though it was not well-prescribed procedurally.
(Report Section 3.h)
The procedurally defined requirements used to calculate and trend i
j the overall heat transfer coefficient of SW system heat exchangers provided an effective method for verifying the equipment's heat i
transfer capabili',,ies.
(Report Section 2.e)
Procedures appeared generally well controlled and technically adequate (an exception is noted below as a weakness).
There was strong emphasis by craf t and supervision for following procedures
,
and verifying the use of the correct procedure.
This verification was documented for each procedure use.
A program for a 2 year review and update was in place and being used.
(findings and conclusions based on the team's observation of work utilizing the procedures and on review of procedures relative to the work observed and reviewed through records.)
Maintenance craf t and supervision observed and interviewed were found to be qualified, knowleogeable and conscientious. (e.g., see Report Sections 2.d and 2.f)
,
Interfaces observed between maintenance and other organizations were considered good.
Weaknesses L
Maintenance performance indicators and goals, including backlog, were not as well-defined or displayed as is typical in the industry.
Goals for maintenance performance indicators had not been set in many cases.
(Report Section 3.d)
Administrative controls were not well-defined for trending and
,
utilization of predictive maintenance data.
(Report Section 3.h)
Backlog was only trended for the licensee's category 1 and 2 PMs
.
(mandatory PMs and PMs required by regulatory committment or for nonconformance disposition). Numerous other overdue (past "End Date", PMs were not being tracked and trended making determination of PM backlog very difficult.
(Report Section 3.e)
,
i.__ -,_,_-_ _
,_._,_,_-_ _,_~._.,__ _..
_ _ _ -.., _ - _ _ _ _ _. _ _ _. _ _
.
-
.
Predictive maintenance vibration analysis equipment in use was not state-of-the-art equipment and trending had to be accomplished manually.
(Report Section 3.h)
Some minor deficiencies (leaks) were recognized but not deficiency tagged and no Maintenance Work Requests were written to correct the deficiencies (leakage).
The licensee's procedures did not make the responsibilities for tagging clear.
(SeeSection2.a)
Incorrect version of electrical preventive maintenance procedure was obtained.
(ReportSection2.d)
Instance where protective relay trip setting had been changed on non-safety-related system without engineering authorization.
<
Report Section ?.d)
4.c(3)
Maintenance facilities, Equipment and Material Controls (Tree Area 7.0)
Rating:
,
Program:
GOOD Implementation:
GOOD This area encompasses the plant maintenance facilities, equipment and material controls with regard to the part they play in supporting the maintenance process.
The findings upon which the rating of this area was based are listed below.
Strengths l
Maintenance foreman of fices were located adjacent to shops aiding in effective communications, i
Shop areas were well-lighted, equipped and laid out.
Shops were located in close proximity to warehouse containing high v
' aire parts, materials and equipment, le procurement organization and process were significantly better than observed in the industry.
(Report Section 3.a)
.
Materials and parts controls observed by the team were appropriate and effective (receipt inspection, identification tagging, protection from damage, shelf life controls, preventive
,
_ _ _.
.
i
maintenance, environmental conditions, issue, traceability, return of unused items to stock, and adjustments to stock levels).
The licensee participated in industry groups addressing procurement problems.
(Report Section 3.a)
The shops were observed to generally have good facilities and equipment.
An example of good equip:nent observed by the team was a state-of-the-art circuit board tester.
The plant connunication system was found to be excellent.
Personnel throughout the plant could be easily contacted.
The chemistry lab end training facilities on site were judged to be excellent.
Tools and measuring and test equipment were generally maintained and controlled to assure they functioned properly in the conduct of maintenance, although some discrepancies were noted.
(The team's inspection of the tool room found all items checked were stored in an orderly manner, could be easily located, and were in good working condition.
Measuring and test equipment had current calibration stickers and restricted use tags if appropriate.
Removal of rigging and measuring and test equipment for calibration and testing was well-documented.
A review of records for eight measuring and test equipment items found that the items had appropriate calibrations performed at the proper frequencies.
Calibrated items were segrated from items in need of calibration or repair.
A review of several licensee assessments of out-of-equi conditions (Defective Precision Equipment calibration Reports (DPIRs) pment found the evaluations properly performed and completed in a timely manner.
Discrepancies were observed in recording ' item usage as described for the associated weakness listed directly below.
The team considered the discrepancies noted to be minor in comparison to the overall good maintenance and control in this area.)
The licensee had a good metrology lab on site and the team's examination of its controlling procedures and records indicated proper calibration and recall were being performed.
All calibrations were traceable to national standards and had a 4 to 1 calibration standard.
The lab's filing system was found to be very thorough.
It contained complete records fer the life of any instrument, including jobs it was used on, calibrations performed, and any DPIRs with their resolutions Weaknesses Deficiencies were obterved in logging calibrated tool usage and
'
issue and return dates.
(In reviewing entries for approximately
- _ _ _ -
__
.
,
,
,,
300 logs the team identified instances where calibrated tools, such as torque wrenches, had been issued without recording their intended use.
Instances were noted in both hot and non-contaminated tool room logs (e.g., entries TS 3396, 2509, 3643 and 3323, 333), 1184, respectively).
Additionally, a requirement (SAP-141, Section 6.2.1) that discipline supervisors with measuring and test eo', oment on extended loan keep a record of the
'
equipment's t se was not always n'et (e.g., for Leat Rate Monitor FS
!
2470 on April 13 and 27, 1990).
This was contrary to issuance requirements e,nd made identification of tool use difficult should it be necessaiy to assess the past uses of a tool found out of
'
calibration.
Tool use could be determined f rom calibrated tool entries on work records for the period of use but might well i
i require extensive and time-consuming review.
The team also found a few errors or omissions in in/out tool entries (e.g.,
FS 3643
.
logged out Torque Multiplier MTW-97._ which was subsequently verified to be in stock anJ FS 3383 logged a tool in that could not be located in stock).
.
There was no formal method of transferring control or identifying
'
traceability of tools to health physics personnel when contaminated
,
tools are confiscated.
4.c(4)
Personnel Control (Tree Area 8.0)
Rating:
Program: GOOD Implementation: GOOD staf fing ), controls (personnel policies, turnover This area encompasses minimization, shif t coverage, etc.
training, testing and qualification and the overall current status of personnel (actual turnover rate, extent of personnel trained and qualified, etc.).
The above rating was based on the following findings:
,
Strengths Training was INp0 accredited.
-
-
- Maintenance craf t and supervision observed and interviewed were found to be qualified, knowledgeable and conscientious. (e.g., see Report Sections 2.d and 2.f)
Sufficient maintenance and support personnel had been provided and supervisor to worker ratio in the maintenance groups was low (about six to one in the Mechanical and l&C groups and three to one in El ec trical-).
, _ _ _ _ _. -,. _ _. _. -. _ _ _
..
...
.
.
.
-.
.-
.
.-
,
Data provided by the licensee indicated that overtime was only high during outages and, considering the short duration of the licensee's most recent refueling outage, the overtime reported was not judged to be excessive.
Qualifications of craftsmen were readily traceable.
(The team's detailed review of qualification, education and training records for five maintenance personnel fouri them to be in accordance with the requirements of the licensee's program. A less detailed review of the records for all craf t personnel identified only a single isolated discrepancy in documentation of an exemption.
The team did not consider the discrepancy significant and it was corrected by the licensee prior to the end of the inspection.)
The turnover rate of maintenance personnel was not high (Based on
-:da ta rovided to the team by the licensee and discussions with the--
craft The licensee stated that no maintenance craf t have tested positive for drug habits in over two years.
The craf t training facility is on site and has good mockup (s and training devices with further improvements in progress e.g.,
addition of closed piping loop including operating examples of many plant equipment items).
Maintenance backshif t coverage is provided.
Weaknesses Licensee data indicated that the turnover rate for engineers was high in 1989.
Eleven engineers terminated that year, three of them system engineers.
The high turnover rate did not continue in 1990.
System engineers lacked training and experience.
(Report fection 3.c)
Extensive use of training exemptions with less documented justification than typically observed.
(The team's review of licensee training and qual _ification records found many craft personnel had been exempted from classroom training at the discretion of their - immediate supervisors.
This practice is commonly referred to as "grandf athering".
Percentage estimates of exemptions granted from training topics per maintenance discipline as of December 6, 1990, were mechanical - 39%, electrical - 39%,
1&C - 56% and HVAC - 66%.
The exemption process had been * hanged to require formal documentation of the reasons for the exemption (i.e., prior education, training, etc.) and apprnval by training management and the Coordinator of Maintenance Services.
However, this change did not apply to previously granted exemptions.
While
- -....----.--
_
- - - -. - -. -. -. - - -
- _ _ _ - _ -.--
-.
_
I
,
,
.!
>
there has been no formal connitment, training management indicated
i that there had been ongoing training of the exempted personnel which had reduced the percentages exempted.)
l 5.
Exit Interview
!
The inspection scope and results were sumarized on January 10, 1991, with those persons indicated in Appendix 1.
The team leader described the areas
inspected and discussed in detail the strengths and weaknesses identified in the report.
The licensee did not identify as proprietary any of the material
,
provided to or used by the inspectors during this inspection.
Dissenting connents were not received from the licensee.
i
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3 i-I APPENDIX 1
'
PERSONS CONTACTED Licensee Employees
'
W. Bacon, Associate Manager, Chemistry
- C. Bowman, Manager, Maintenance Services
R. Brenner System Engineer. Trending of Plant Aging R. Brown, Supervisor, Design Engineering
.
- M. Browne, Manager, Systems and Performance Engineering
- B. Christiansen, Manager, Technical Services
,
- M. Clonts, Ficility and Administration R. Collins Quality control Inspector T. Cromer, Procedure Coordinator, Planning and Scheduling J. Cumalander, Plant Electrician D. Daniel, Electrical Contractor J. Derrick, Supervisor, Primary Systems Engineering
- D. Dixon Executive Vice President, Operations
- H. Donnelly, Senior Engineer, Nuclear Licensing
- R. Fowlkes, Associate Manager Shift Engineering
M. Garrett, Associate Manager Quality Control
- G. Gibson, Manager Nuclear Protectien Services R. Grier, Electrical Contractor
- A. Koon, General Manager, Nuclear Safety (Acting)
- G. !.iu, ISEG Engineer W. McMillan, Supervisor, Electrical Maintenance D. McPherson _ Plant Electrician
- G. Moffatt, SROC
- D Moore, General Manager, Station Support B. Mullinax, Senior Engineer, PRA/IPE - Design Engineering.
J. Nesbitt, Instrumentation and Control Supervisor, Technical Services B. Norcutt, Plant Electrician H,- 0'Quinn, Maintenance Services Associate Manager
- C, Osier, Supervisor Secondary Systems Engineering A. Paglia, Senior Engineer, Projects / Performance Engineering
..
-*C, Price, Manager, Technical Oversight
- J. Proper, Acting Manager, Quality Systems W - Pruitt, Plant Electrician
- M. Quinton, General Manager, Engineering Services S. Riddle, Electrical Contractor T.<Sease, Quality Control Inspector D. Shue, Systems and Performance Engineer
- J. Skolds, Vice President Nuclear Operations R.
Slone, System Engineer, Electrical Distribution (Safety-related)
R. Smith, System Engineer, Electrical Distribution (Non-safety)
- G. Soult, General Manager, Nuclear Plant Operations A. Torres, NDE/ Welding Supervisor, Quality Control A. Turbeville, Mechanical Supervisor, Maintenance Services G. Walker, Supervisor, Planning and Schedulin; s
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_ _. _ _ _ _ _ _ _ -
. _ _ _ - - -
-. - -. _. -. _. _. _. _ _ _. _ _. _. _ _ _..
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,
!
,
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!
R. Waselus, Manager, Design and Engineering
- R. White, Nuclear Coordinator, Santee Cooper K. Wicker, Supervisor, huelear Records Management
- M Williams, General Manager, Administrative and Support Services
.
D. Willingham, Maintenance Supervisor R. Woodard, Maintenance Supervisor J. Yon, Maintenance Supervisor, Electrical Section
NRC Personnel
- E. - Adensam. Director, Project Directorate 11-1 NRC, NRR
- F. Cantrell. Section Chief. Division of Reactor Projects,. Region II
- R. Haag, NRC, Senior Resident inspector
- C. Julian, Branch Chief, Division of Reactor Safety, Region I:
.
- 0. Spalding, General Engineering - Intern NRC, NRR
- G. Wunder, Project Manager, Project Directorate 11-1, NRR
<
- Attended Exit Interview on January 10, 1991
,
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APPENDIX 2
,
ACRONYMS AND INITIALISMS ALARA As Low As Reasonably Achievable ANSI American National Standards Institute ARW Advanced Radiation Worker
'
.
ASME American Society of Mechinical Enoineers ATWS Anticipiated Transient Without a $ cram
'
CCW Component Cooling Water
,
CGI Commercial Grade item
'
DPIR Defective Precision Instrument Reports EMP Electrical Maintenance Procedure EPRI Electric Power Research Institute
'
.
Equipment Qualification
'
.
Engineering Services
..
i LSF Engineered Safety Feature FSAR Final Safety Analysis Report GL Generic Letter GTP General Test Procedure HP Health Physics HVAC Heating, Ventilation and Air Conditioning INPO Institute for Nuclear Power Operations 1&C Instrumentation and Controls LC0 Limiting Condition for Operation LER Licensee Event Report MCC Motor Control Center MOV Motor Operated Valve MSI-Maintenance Special Instruction-
<
MWe Megawatts Electric MWR Maintenance Work Request
!
NI Nuclear Instrumentation NPRDS-Nuclear Plant Reliability Data System NRC Nuclear Regulatory Commision NRR Office of Nuclear Reactor Regulation NSSS Nuclear Steam Supply System POM Predictive Maintenance PM Preventive Maintenance PMT Post Maintencnce Testing PMTS Preventive Maintenance Task Sheet PRA Probabilistic Risk Assessment PWR Pressurized Water Reactor-QA Quality Assurance QC Quality Control RCM Reliability Centered Maintenance rem Radiation Equivalent Man RHR Residual Heat Removal RPS Reactor Protection System RTO Resistence Temperature Detector RWP Radiation Work Permit I,
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Safeguards
- ,
gg Safety Injection SOER Significant Operating Event Report SW Service Water
"
TS Technical Specifications l
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