IR 05000416/1987021

Insp Repts 50-416/87-21 & 50-417/87-03 on 870824-26.No Violations or Deviations Noted.Major Areas Inspected:Maint Activities

ML20235F687
Person / Time
Site:	Grand Gulf
Issue date:	09/23/1987
From:	Blake J, Robert Carrion, Hallstrom G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20235F670	List: IR 05000416/1987021 ML20235F667
References
50-416-87-21, 50-417-87-03, 50-417-87-3, NUDOCS 8709290278
Download: ML20235F687 (12)

Text

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1. N(c UNITED STATES oq^o, NUCLEAR REGULATORY COMMISslON

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' ,[ . REGION 18 101 MARIETTA STREET, * t ATLANTA, G EORGI A 30323-g k . . . ' ',e -

i-Report Nos.:- 50-416/87-21 and 50-417/87-03 -

Licensee: System Energy Resources, In Jackson, MS 39205

. Docket Nos.: 50-416 and 50-417~ License Nos.: NPF-29 and CPPR-119 Facility Name: Grand Gulf

' Inspection Conducte : August. 24-26, 1987 Inspectors: MM - -

P-28 -8 7 G. A. Hallstrom .Date Signed

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R..P. Carrion Date Signed Approved by: .

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J. J. Bitkt, Chief Date Signed Materials and Processes Section-Division of Reactor Safety

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SUMMARY Scope:. This routine, unannounced inspection was in the areas of maintenance activities (Units 1 and 2).

Results: No violations or deviations were identifie k[

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REPORT DETAILS Persons Contacted Licensee Employees

• C. R. Hutchinson, General Manager

^J. P. Dimmette, Jr., Plant Maintenance Manager

• V. Moomaw, Plant Maintenance Technical Assistant  !

• J. H. Mueller, Mechanical Superintendent B. F. Oglesby, Maintenance Planner

• M. J. Wright, Plant Support Manager

• L. F. Daughtery, Compliance Supervisor

• J. D. Bailey, Compliance Coordinator

• B. C. Lee, Quality Services Manager

• Koestler, Construction Assistant I W. Finch, Construction Superintendent P. L. Hayes, Training Support Supervisor S. F. Tanner, Quality Services Manager Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne NRC Resident Inspectors R. C. Butcher, Senior Resident Inspector J. L. Mathis, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on August 28, 1987, with those persons indicated in paragraph 1 above. The ins 3ector described the areas inspected and discussed in detail the inspect'on finding No dissenting comments were received from the license The following new item was identified during this inspectio Unresolved Item 416/87-21-01, Adequacy of Maintenance Documentation, paragraph. The licensee did not identify as proprietary any of the materials provided i to or reviewed by the inspectors during this inspectio ! Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio _ _ _ _ _

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2 Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. One unresolved item identified during this inspection is discussed in paragraph . Maintenance Program (62702) (Unit 1)

The inspectors reviewed the licensee's maintenance program to verify that it is in . compliance with Technical Specifications, Regulatory Requirements, commitments in the application, and industry guides or '

standard The review is described below: ' Procedures  ;

The inspectors reviewed maintenance program related requirements in the following procedures:

Procedure Revision Title 01-5-03-1 9 GGNS Quality Program 01-S-03-2 15 Quality Deficiency Reports (QDRs)

01-S-03-3 20 Material Nonconformance Reports (MNCRs)

01-S-03-7 0 Discrepant Material Reports (DMRs) )

01-S-04-14 13 Training Records '

01-S-04-17 10 Mechanical Maintenance Training Program 01-S-06-1 20 Protective Tagging System 01-5-06-3 21 Control of Temporary Alterations 01-S-07-1 18 Control of Work on Plant Equipment ,

and Facilities 01-S-07-2 9 Test and Retest Control 01-S-07-3 10 Calibration and Control of Measuring and Test Equipment 01-S-07-5 7 Control of Special Processes 01-S-07-9 10 Housekeeping 01-S-07-13 8 Cleaning Processes 01-S-07-15 2 Preventive Maintenance Program 07-5-01-227 1 Equipment Qualification 07-S-14-338 0 Valve Repacking for Graphite Tape Packing (GTP)

06-0P-IE51-Q-0002, RCIC System Quarterly Valve Rev. 27 Operability Test Corrective Maintenance The inspectors reviewed the procedures described in 5.a. to verify that:

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Written procedures have been established for initiating requests for routine and emergency maintenanc Criteria and responsibilities have been established for review and approval of maintenance requests including emergency maintenance request Criteria and responsibilities have been established that form the basis for designating the activity as safety-related or not safety-relate *

Provisions and responsibilities have been established for the identification of appropriate inspection hold points related to maintenance activitie *

Methods and responsibilities have been designated for performing functional testing of structures, . systems, or components following maintenance work and/or prior to their being returned to servic Administrative controls of maintenance activities require that the following records will be prepared, assembled, and reviewed for transfer to records storage:

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approvals of maintenance requests

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identification of the personnel who performed the maintenance task

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identification of the personnel who inspected the maintenance work

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cause of the malfunction or failure which necessitated the maintenance work, including generic implications of the failure

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description of the corrective action taken

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identification of the post-maintenance functional testing performed

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identification of personnel that performed the post-maintenance testing

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identification of replacement parts or materials used

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identification of test and measuring equipment used i

l Responsibility has been established to assemble and review the records identified above.

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Requirements have been established for reviewing completed l corrective maintenance records to identify repetitive failures of parts and components, and to identify design deficiencie *

Responsibilities have been assigned to ensure implementation of records review identified abov *

Work control procedures have been established to require special authorization for activities involving welding, open flame, or other ignition sources and take cognizance of nearby flammable material, cable trays, or critical process equipmen Work control procedures have- been established to require a firewatch, with capability for communication with the control'

room, if an activity identified above is to be' performed in the proximity of flammable material, cable trays, or vital process equipmen Revisions to Technical Specifications (TS) have been incorporated into procedures and included in the master progra c. Equipment Control The inspectors reviewed the procedures listed in 5.a. to verify that:

Procedures have been established to specify that the operating staff grants permission to release equipment or systems for maintenanc "

Before granting permission for removal of equipment for service, the operating staff is required to verify that the equipment or system can be released without violating TS requirement Additionally, they shall determ ua how long the equipment may be out of servic Granting of such permission shall be documente Equipment that is environmentally qualified should be identified as such prior to maintenance and sufficient controls should exist to ensure it is returned to that status upon reassembl When testing of redundant components or systems is required by TS or 10 CFR 50, such testing shall be documente *

The status of equipment and systems will be clearly identifie *

Procedures have been established and responsibility has been assigned for determining when independent verification has been implemented correctl "

Procedures and responsibility have been established for returning equipment to servic _ _

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Revisions to TS have been incorporated into procedures and included in the master progra d. Preventive Maintenance The inspectors reviewed the procedures listed in 5.a. to verify that a written Preventive Maintenance (PM) program for safety-related structures, systems, and components has been established to include:

responsibility for the program

master schedule for preventive maintenance documentation and review of completion of preventive maintenance activities responsibilities and methods for establishing PM frequencies responsibility for periodic upgrading based on system or-component failures methods for incorporating revisions to TS into procedures and the master program e. Special Processes The inspectors reviewed the procedures listed in 5.a. to:

Verify that administrative controls for special processes have been established as follows:

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a requirement that only qualified procedures will be used

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a requirement that only -qualified personnel will be used

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a requirement that a current file of special processes will be maintained to include qualification records of procedures and personnel

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criteria to establish when the use of mock-ups or other special training will be required Verify that responsibilities have been assigned to assure that the requirements identified herein 5.e will be accomplishe f. Cleanliness Controls The inspectors reviewed the procedures listed in 5.a. to:

Verify that procedures have been developed for cleaning safety-related coraponents and system _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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.-Verify that procedures have.been established.for maintaining the cleanliness of.previously cleaned system Verify thatith'e cleanliness classifications of plant systems have been establishe ;

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Verify that responsibilities for implementing the requirements of this section have been establishe Housekeeping; Controls-The inspectors reviewed.the procedures listed in 5.a. to verify that administrative controls and responsibilities for general housekeeping have been established to include:

defining housekeeping zones

controlling housekeeping during work activities Maintenance Program Implementation (62700) (Unit 1)

The' inspectors reviewed the licensee's implementation of the maintenance program to determine: whether. the program is being in.plemented in ',

accordance with regulatory requirements, the effectiveness of the program on important plant equipment and the ability of the maintenance staff to conduct an effective maintenance progra Records The ins 3ectors reviewed the below listed records of maintenance activit'es on containment isolation valves to determine whether:

The procedures specified in the maintenance package were adequate for the scope of the maintenance performe The vendor technical manual for the equipment under repair was controlled and kept up to date (whether or not the vendor manual was specified in'the maintenance package).

Vendor maintenance recommendations, if used, were correctly translated into or referenced by the maintenance procedure *

Required administrative approvals were obtained before initiating the wor *

Limiting conditions for operation were met while the component or system was removed from servic *

Approval procedures were used where the activity appeared to exceed the normal skills possessed by qualified maintenance personne _ _ _ _ _ .

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Inspections were made in accordance with the licensee's requirements, and quality control records are complet Functional testing and calibrations, as necessary, were completed before returning the equipment to servic The personnel who performed the tests were properly qualifie Corrective and preventive maintenance records were assembled and stored as part of the maintenance histor *

The measuring and test equipment (M&TE) used was identified and in calibratio *

Parts and materials used were identified and at least met the specifications of the original equipmen Special processes were controlled and documente System lineups were made and verified prior to return to servic Maintenance Work Authority to Order (MWO) N Start (ATS) Date System Valve N /04/85 Reactor E51 F076 Core Isolation Cooling (RCIC)

57494 10/30/85 RCIC E51 F076 58286 03/25/86 RCIC E51 F076 54610 08/03/85 High E22 F004 Pressure '

Core Spray (HPCS)

54506 04/14/86 HPCS E22 F005 66336 09/27/86 HPCS E22 F005 57747 11/09/85 Residual E12 F041C Heat Removal (RHR)

65539 Cancelled RHR E12 F041C 67699 11/09/86 RHR E12 F009 67397 11/04/86 RHR E12 F0538 51965 03/27/85 RHR E12 F050A 70131 Cancelled RHR E12 F053A

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During J the above examination, the inspectors noted several discrepancies as follows:

MWO 53549 indicated potential for an LC0 in Modes 1, 2 and 3 and that an' LCO. was required (LC0 Report No.85-484). LCO Report-No.85-484 covers a broken accident monitoring level indicator pe The MWO 53549 Retest Control Form indicates that the RCIC System Quarterly Operability Valve. Test-(06-0P-1E51-Q-002) was completed on June 5,1985. .'However, .the actual ; test data form was not included 'in the MWO data package provided..to the-inspectors so that actual plant status during the test was not verifie Note . Section 1.1 .of the impact statement for 06-0P-1E51-Q-002. states that "The performance of this procedure will cycle valves in the RCIC system with M0 thermal overloads in service under an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> LCO."

'MWO No. 58286 indicates no LC0 condition required to adjust packing or replace packing on valve E51F026. However,. test 06-0P-1E51-Q-002 was performed on the same ATS date (March 25, 1986) and indicates the plant to be on Mode. *

MWO 54506 does not indicate whether or not an LC0 is require Administrative Procedure 01-S-07-1, . Attachment II, requires .the operations shift superintendent to'make these entries ne later than when the ATS is sigt.e The HPCS valve test (06-0P-1E22-C-003) was perfomed on October 12, 1986 with the plant in Mode 5. However, the MWO anticipated a valve-repack and ATS was dated September 14, 198 Further, the MW0 indicates potential for LC0 in all plant mode .MWO 54610 indicated potential for an LCO in Modes 1, 2 and 3 and did not indicate whether or not an LC0 was require However, the HPCS quarterly valve test (06-0P-1E22-Q-002) was performed on August 3,1985 (same date as the ATS) with the plant in Mode MWO 51965 indicated potential for an LC0 in all plant modes and did not indicate whether or not an LC0 was required. ATS was dated March 27, 1985 and an impact statement in the MW0 package dated March 26, 1985 states that RHR loop A will be out of servic MWO 67699 indicated potential for an LC0 in Modes 1, 2 and 3 and did not indicate whether or not an LC0 was required. The impact statement dated November 6.1986 states that RHR suction valve E12 F009 will be out of service and isolated. ATS was signed on November 9, 1986.

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l MWO 57747 indicated potential for an LC0 in Modes 1, 2 and.3 and

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did not indicate whether or not an LC0 was require Cognizant licensee personnel were unable to explain the above discrepancies to the inspectors within the available time during this inspection. The inspector informed cognizant licensee personnel that NRC concern existed as to the adequacy of maintenance documentation and the potential for operations staff failure to properly identify limiting conditions of operatio Pending further NRC review, this -

item will be identified as unresolved item 50-416/87-21-01, Adequacy of Maintenance Documentatio b. Maintenance Procedures The inspectors also reviewed the maintenance procedures identified in 5.a. to assure that:

The . procedures conform to licensee's administrative requirements, including format, approval and contro The post-maintenance testing is appropriate for the repairs mad The inspection and hold points are identified in the procedures or in a documented plan and are based on a set of established guideline Supplementary reference material such as drawings and technical manuals is adequate and controlle '

The activity is described in sufficient detai Consideration is given to radiological, temperature, pressure, and electrical hazards, as appropriate to the circumstance The provisions for fire protection, cleanliness, and housekeeping are adequat Appropriate instructions and quality control checks are included to verify that environmentally qualified equipment is properly protected against moisture intrusion when reassemble The provisions for obtaining approval from operations as well as methods for notifying operations when affected systems are j removed from service and ready to be restored to normal service are presen l

c. In-Process Maintenance Activities The inspectors witnessed the below listed maintenance activities in progress to verify:

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Maintenance personnel assigned understand the scope of the jo *

Applicable parts of item 5.b. are satisfied for the work in progres The technicians are qualified for their respective task *

Supervisory oversight of the. work is adequat QC personnel assigned are knowledgeable of the tas MWO TASK M73910 Remove and replace 1-1/2" 0 spool piece from chiller unit Q1T518007B M74346 Remove and replace pump of Radiation Monitoring Panel NID17P015 Qualifications of Maintenance Staff The inspectors reviewed the Qualifications and Training Records of the below listed maintenance staff associated with the activities listed in 6.c. to verify:

initial qualification and training periodic retraining

the control of job assignments to new and inexperienced personnel Employee Designation Title EH Maintenance Supervisor RP Mechanic RED Maintenance Supervisor GC Mechanic Preventive Maintenance (62700) (Unit 2)

The inspectors reviewed the below listed procedures and conducted a general inspection of Unit 2 reactor vessel and various safety-related equipment to verify the:

responsibility for the program

master schedule for preventive maintenance

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documentation and review of completion of preventive maintenance

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activities responsibilities and methods for establishing PM frequencies Procedure N Title WP/P-14 Rev. 8 Material Control WP/P-15 Rev. 5 Maintenance of. Materials and Equipment While in Storage The inspectors noted that Unit 2 preventive maintenance appeared adequate to minimize degradation of installed equipmen No violations or deviations were identifie i i

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