IR 05000400/1989030
| ML18005B160 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/21/1989 |
| From: | Breslau B, Kellogg P, Mellen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005B159 | List: |
| References | |
| 50-400-89-30, NUDOCS 8912070117 | |
| Download: ML18005B160 (9) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-400/89-30 Licensee:
Carolina Power Company P.O.
Box 1551 Raleigh, NC 27602 Docket No.: 50-400 Facility Name:
Shearon Harris Inspection Conducted:
November 13 - 17, 1989 Inspec'tors:
B. Breslau, Reactor Engineer e l 1 en Reactor Engr neer Approved by:
d k~ ~
P.
l,log, Operationa1 rograms S ction Div'ision of eactor Safety License Nos.:
NPF-63 Date Signed
~/
Da Signed
~~/f Date Signed SUMMARY Scope:
This announced inspection was conducted as a follow-up to the Operational Safety
. Team Inspection (OSTI) conducted September 19 - October 7, 1988, Inspection Report No. 50-400/88-34.
The scope of this inspection included review of two Violations and one unresolved (UNR) item and one inspector follow-up item (IFI)
as well as those items identified in the OSTI as program weaknesses or concerns.
Results:
Prompt management attention was evidenced by the adequate corrective actions to correct the items noted in inspection report 88-34.
There are two items which remain open, paragraph 2. d is considered as an inspector follow-up item to review opening stroke time test results for the pressurizer PORVs.
Paragraph 2.e will remain open, the maintenance procedure revision program has not been in place long enough to obtain quantifiable results.
No violations or deviations were noted within the areas inspected.
8912O70117
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REPORT DETAILS 1.
Persons Contacted Licensee employees A.. Buie,Tech-l, Operations, Nuclear
- K. Ensor, Manager, Corporate Nuclear Maintenance
"J. Bradley, Supervisor, Operations Support
- G. Forehand, Manager, gA/gC
"C. Gibson, Director, Programs 8 Procedures
- J.
Hammond, Manager, Onsite Nuclear Safety
"C. Hinnant, Plant General Manager
"D. McCarthy, Principle Engineer, Nuclear Engineering Design
- T. Morton, Manager, Maintenance
- R. Richey, Manager Harris Project
~J.
Sipp, Manager, E 5 RC
- D. Tibbits, Director, Regulatory Compliance
- R.
Van Metre, Manager, Technical Support.
L. Veeder, Maintenance Procedure Coordinator
"M. Wallace, Senior Specialist, Regulatory Compliance M. Westmoreland, Senior Engineer
- L. Woods, Engineering Supervisor, Nuclear Other Licensee employees contacted included instructors, engineers, technicians, operators, and office personnel.
NRC Representatives
- J. Tedrow, Senior Resident Inspector
- M. Shannon, Resident Inspector
"Attended exit interview Acronyms used throughout this report are listed in the last paragraph.
2.
Actions on Previous Inspection Findings (92701)
a.
(Closed)
IFI 400/87-04-05, Provide valve numbers for instrument air system and revise procedures.
The licensee has completed the walk down of the IA system and had identified the IA valve numbers to be added to the Auxiliary Feedwater procedure.
The inspector reviewed OP-137 Rev.
4, dated September 6,
1989, which included the valve numbers and physically verified the numbers included in the procedure were the correct IA valve numbers.
b.
(Closed)
Violation 400/88-34-.01, Failure to document that monthly caution tag audits had been conducted between the dates of May 29, 1988 and August 31, 198 The licensee has placed the requirement for conducting tag audits in procedure OMM-014, Operations
- Operation of the 'Clearance Center, Revision l.
A review of the scheduling program reflects an adequate comprehensive system is in place.
The inspector's interviews coupled with reviews of audit documentation indicated that this requirement is being adequately conducted as specified in the subject procedure.
(Closed)
Violation 400/88-34-02, Failure to obtain authorization from the Plant Manager for maintenance personnel to exceed TS overtime guidelines.
A review of r evi sed procedure MMM-001, Maintenance Conduct of Operation, Revision 3 indicates specific controls are in place for administering maintenance overtime.
Further review of maintenance documentation covering hours worked from July 1989 to September 1989 revealed several occasions where maintenance personnel exceeded the specified hours annotated in MMM-001; in each case documentation was available to indicate that prior approval was obtained before the hours were exceeded.
Control of maintenance overtime appears to be adequate.
(Closed)
Unresolved Item 50-400/88-34-03, The pressurizer PORVs were stroked in the open direction when the licensee performed the surveillance test which measured the PORVs closing time.
However, the time for the opening of the PORVs was not determined.
The inspectors indicated that it appeared appropriate to include the PORVs'pening time in the tests because it would assure that
CFR 50 Appendix G limits were not exceeded.
The inspectors reviewed the corrective actions as delineated in CAP Action Item 88H1324, which initiated a modification to procedures OST-1503 and OST-1805.
The CAP was completed and approved on January 18, 1989.
The inspectors subsequently evaluated the current revision of both procedures (OST-1503 Revision 1,
and OST-1805 Revision 2,
change 1).
The changes that had been incorporated into these revisions included appropriate criteria for measuring the pressurizer PORVs stroke time in the opening direction.
The inspectors verified that the appropriate revisions of these procedures were in document control.
The licensee has not performed these revised procedures.
The first performance is scheduled for the end of current refueling outage.
The results of the stroke times will be reviewed after the completion of the current outage.
This item will be tracked as inspector follow-up item 50-400/89-30-01, Opening Stroke Time Test Results for the Pressurizer PORVs.
(Open)
Inspector Follow-up Item 50-400/88-34-04, the licensee will develop a plan to deal with the backlog of overdue maintenance procedure revisions and the large number of pen and ink changes to the maintenance procedures.
The licensee expanded the scope of their plan to included:
"l.
2.
Large number of temporary changes.
Large number of procedure's (sic) with a large number of handwritten advance changes.
Large number of procedure's (sic) that were identified, on the two year review, as needing to be revised."
The inspectors reviewed the licensee's plan to improve this area.
The plan was divided into three areas which were as follows:
2)
3)
Initiate advance changes to incorporate the temporary changes.
Reduce'he number of procedures that had a large number of handwritten advanced changes.
Eliminate the backlog of overdue procedure revisions and reduce the number of handwritten advanced changes as much as practical.
The program has not been in place long enough to obtain quantifiable results.
This Inspector foll'ow-up item will remain open until the results of the Maintenance Procedure Change Improvement Program has been fully implemented and the results of the program are reviewed.
f.
(Closed)
IFI 400-50/88-34-05, Plans and schedules for implementing additional predictive maintenance will be developed.
This paragraph also addresses the observed lack of predictive maintenance as referenced in NRC inspection report 50-400/88-34.
In NRC inspection report 88-34 it was observed that the only regularly scheduled predictive maintenance programs were vibration analysis and Technical Specification required oil sampling
.
The inspectors discussed the predictive maintenance program with members of the technical supervision and the engineering support staff.
The current program, although not completely implemented, includes:
1)
2)
3)
4)
5)
6)
7)
8)
Vibration Thermography Lube Oil Large Motor Monitoring Bearing Temperatur'e In-leakage Detection Performance Monitoring ASME Section XI Pump and Valve Program The inclusion of this type of data in the licensee's predictive and preventive maintenance appears to have decreased the number of repetitive failures.
This observation is further bolstered by the management tracking information presented to the inspectors which
"indicated that the percentage of repetitive failure has been maintained well below the management goal of 15 percent.
The trend of repetitive fai1ures and rework has been below the management target since April 198 Another important consideration in the reduction of repeat failures appeared to be the system engineers.
They have the responsibility of analyzing all pertinent data applicable to their particular systems.
Their analysis appears to have contributed to the reduced number of failures and has augmented both the predictive and preventative maintenance programs.
The licensee appears to have addressed these items satisfactorily.
g.
In addition to the above items, a number of weaknesses and concerns were identified in Inspection Report No. 400/88-34 and are addressed below:
1)
Paragraph 4. a.
noted qualification or training requir ements for maintenance planners as an area which the licensee may want to strengthen.
The inspectors noted continuing training for planners was started in January 1989.
The licensee has developed a
Maintenance Planning-Training Plan to provide consistent and accurate planning to work requests and to enhance planner accountability by providing realistic and quantitative guidelines.
The'se guidelines were further supplemented by the issuance of a
memo containing
'a Planner/Analyst Checklist to be used as a
desk-top guide to assist in planning, thus providing steps necessary to ensure consistent and accurate planning of maintenance work requests.
These actions are considered to be an enhancement and this area of'oncern is considered adequately addressed.
2)
Paragraph 4.b.
The maintenance department had no formalized goals for controlling the amount of maintenance work backlog.
The Inspectors reviewed the established goals for the Maintenance Unit.
There were twelve items being tracked, although all of the items did not have established goals.
These items included:
a)
Ratio of Preventative Maintenance to Total Maintenance b)
Main and Radwaste Control Board Deficiency Tags c)
Planning Backlog d)
Overdue PMs e)
Outstanding WRM's (sic) by WCC f)
Outstanding WR8A's (sic) by Priority g)
Work Requests
>90 days old and
>
1 year old h)
Maintenance Violations i)
Maintenance NCRs and Deficiencies j)
Safety Meeting Attendance k)
Rework Trend (Repetitive Failures)
1)
Maintenance Overtime Hours
At the time of this inspection the establishment of Maintenance Unit goals appears to have had an inconsequential effect on the actual work performance. of the Maintenance Unit 'ith the exception of the significant downward trend in the amount of required rework.
Maintenance Management was actively evaluating the material that is provide by the trended information although they have yet to establish a definitive action plan.
This area of concern appears to have been adequately addressed and the implementation of this program will be addressed in future maintenance inspections.
Paragraph 4.g.
Maintenance procedures and changes are adequately controlled, but the large number of "pen and ink" advance changes could degrade the readability of procedure copies.
This item is discussed in item 2.e.
above.
Paragraph 4. h.
Priori tization and management of maintenance feedback request program, plans to be computerized by June 1989.
The inspectors examined the licensee's methodology for the computerization of the maintenance feedback request program and the repetitive failure program.
The addition of the information to the computerized tracking system data base has been completed.
The computer system has the capability of generating a variety of reports, but the licensee has not determined which reports will be routinely generated.
Additionally, the system has not been in service long enough to make a definitive evaluation of its effectiveness.
~
The establishment of the maintenance feedback data base addresses the concerns delineated in NRC inspection report 88-34.
The implementation of this program will be reviewed during future maintenance inspections.
Paragraph 4.i.
Repetitive failure analysis program lacked specific guidance on determining repetitive failures, inter-system repetitive failures identification, open B/RfIRs not included in monthly status report, -low priority PCRs not being resolved.
The licensee has recently reorganized.
The engineering support group handles both the repetitive fai lure analysis and predictive maintenance issues.
As previously noted above, the engineers are maintaining historical data on repetitive failures as one of the tools to aid in determining needed predictive maintenance.
This item appears to be adequate.
'I
6)
Paragraph 4. 1.
The lack of predictive vibration analysis and TS required oil as an area of weakness.
This area is above.
This item is discussed in item maintenance, other than sampling, was considered discussed in item 2.f.
2.f. above.
No violations or deviations were noted within the areas inspected.
Required Reading During the follow-up to the violation concerning caution tag audits, the inspector noted the October 1989, scheduling calendar, which lists the audits required for that month did not have the activities annotated as complete for the fourth,'eventh and the 21.
These activities required an audit be conducted of the required reading book and the audits were to be completed by the SF.
Further review of the required reading book indicated that two SFs, who's responsibilities include ensuring that their crew reviews the contents of the required reading book, were delinquent in that they had not reviewed the material and one of these SFs had been assigned the task of conducting the audit.
Additionally, the inspector noted that a total of eight personnel had failed to review the required reading in the allotted time period.
The inspector determined from discussions with the licensee and passed documentation that crisp management attention has been applied to this area in the past.
Based on the fact that these reviews are only two weeks passed due and no additional discrepancies were noted, this instance is considered an isolated incident.
No violations or deviations wer e noted within the areas inspected S
Exit Inter view An exit interview was conducted on November 17, 1989, with those persons indicated in paragraph
above.
The inspectors described the areas inspected and discussed in detail the inspection results.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Item Number 400/89-30-01 Status Open Description/Reference Paragraph Review test results for opening stroke time test for PORVs Acronyms AEOD B/RFIR E8 RC CAP IA IFI Office for Analysis and Evaluation of Operational Data Breakdown/Repetitive Failure Investigative Report Envi ronmenta1 8 Radi ol ogi cal Control Corrective Action Program Instrument Air Inspector Follow-up Item
LTOP MMM NRC OMM OSTI PCR PM PORV QA/QC RO SRO TS UNR Low Temperature Overpressure Protection Maintenance Management Manual Nuclear Regulatory Commission Operations Management Manual Operational Safety Team Inspection Plant Change Request Planned Maintenance Power Operated Relief Valve Quality Assurance/Quality Control Reactor Operator Senior Reactor Operator Technical Specification Unresolved Items