IR 05000440/1990012
| ML20058H659 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/13/1990 |
| From: | Charles Brown, Burgess S, Choules N, Gainty C, Holmes J, Michael Kunowski, Slover W, Tella T, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058H653 | List: |
| References | |
| 50-440-90-12, NUDOCS 9011210120 | |
| Download: ML20058H659 (40) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-440/90012(DRS)
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Docket No. 50 440 License No. NPF-58 Licensee:
The Cleveland Electric Illuminating Company 10 Conter Road Perry, OH 44081 Facility Name:
Perry Nuclear Power Plant inspection At:
Perry Nucioar Power Plant, Perry, Ohio Inspection Conducted:
September 1/ through il, and October 1 through 5, 1990 Inspec rs:
p
'. Wa ker, Team Leader
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Approved By: e k"'~~
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3/D. Burgess, Chief Date Maintenance and Outage Section l
9011210120 901134 PDR
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Inspection Summary
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Inspection on September 17 throuah 21. and October 1 throuah 5. 1990 (Recor_t No. 50-440/90012f0RS)).
A_reas Insoected:
Special announced team inspection of maintenance, engineering, support of maintenance, and related management activities.
The inspection was conducted utilizing Temporary Instruction 2515/97, the attached Maintenance Inspection Tree, and selected portions of Inspection Modules 62700, 62702, 62704, 62705, 64150, 64704, and 73755 to ascertain whether maintenance was effectively accomplished and assessed by the licensee.
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Based on the items inspected, overall performance in maintenance was considered satisfactory. Three violations were identified which included the following:
two examples of inadequate procedures or failure to follow procedures, one example of inadequate control of nonconforming material, and three examples of inadequate testing of plant fire pumps.
In addition, a number of strengths and weaknesses were identified.
The most significant strengths relating to maintenance were management commitment to maintenance, dedicated and experienced maintenance personnel, review and tracking of maintenance performance, and a good reliability centered maintenance program.
The most significant weaknesses were the failure to have methods in place to effectively identify and correct poor hou.Meeping and defective plant cauipment, inadequate control of nonconfor ;ng material, inadequate planning for some work, procedure inadequacies, the use of alternate methods and controls to expedite work and several instances of failure to follow procedures in performing maintenance activities.
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DETAlls
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1.0 Princioal Persons Contacted The Cleveland Electric illuminatina Company
- M. Lyster, Vice President Nuclear
- M. Cohen, Manager Plant Maintenance Secticn
- W. Coleman, Manager Nuclear Assurance Department
- W. Kanda, Manager Instrument and Controls Section
- S. Kensicki, Director Nuclear Engineering Department
- E. Riley, Director Nuclear Assurance Department
- A. Silakoski, Manager Independent Safety Engineering Group
- F. Stead, Director Nuclear Support Department R. Stratman, General Manager Nuclear Power Plant Department
- P. Volza, Manager Radiation Protection p. S. Nuclear Reaulatory Commission (U.S. NRC)
- H. A. Ring - Chief, Engineering Branch - DRS
- G. O'Dwyer - Resident Inspector, Perry P. L.
Hiland - Senior Resident inspector
- Denotes those present at the exit meeting on October 12, 1990.
Other persons were contacted as a matter of course during the inspection.
2.0 Licensee Action on Previous inspection items The inspectors compared the inspection results with problems noted on the previous maintenance in nection conducted in January, 1988.
All items from the1988inspectionhadbeenclosedpriortothisinspection. A problem with the identification of defective equipment was noted on the current inspection and it was previously r.oted in inspection 440/87025.
Although the item had been previously closed, the condition still existed and, therefore, had not been properly corrected or had recurred.
3.0 Introduction to the Evaluation and Assessment of Maintenance An announced NRC team inspection of maintenance and supporting activities was conducted at Perry Nuclear Power Plant during the period of September 17
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through 21, and October 1 through 5, 1990.
The inspection was conducted during the second refueling outage to assess fundamental issues in the broad areas of maintenance, fire protection, engineering, and technical support where the team looked at plant performance, management support, and implementation. The team goal was to determine if maintenance had been effectively implemented to assure the safe operation and reliability of plant structures, systems, and components to operate on demand.
This inspection was based on the guidance provided in NRC Temporary InstNetion 2515/97,
" Maintenance Inspection," and Drawing 425767-C, " Maintenance Inspection Tree."
The drawing, which is attached to this report, was used as a visual aid during
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'the exit meeting to depict the results of the inspection.
Acronyms used in
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this report are defined in Appendix A.
Results of this inspection were derived from data obtained by observation of current plant conditions and work in progress, by review of completed work, and by evaluation of the licensee's self assessment of maintenance and correction of weaknesses. Major areas of interest included electrical, mechanical, and instrument and control; and the support areas of radiological iMntrol, engineering, fire protection, quality control, training, procurement, ani operations.
Problems identified by the inspectors were evaluated for eff$ct on Technical Specification operability and technical or managerial weakness.
3.1 Performance Data and System Selection 3.1.1 Historic Data The inspectors reviewed the latest Systematic Assessment of Licensee Performance (SALP) report and completed NRC inspection reports.
Primarily, the inspectors were sensitive to technical and managerial problems that appeared to be maintenance related.
The inspectors also reviewed plant operations historic data since January 1989, including Licensee Event Reports (LERs). Thirty two LERs were issued in 1989 and twenty LERs were issued through August of 1990.
Tne industry average of LERs issued for Boiling Water Reactors (BWRs) in 1989 was 33.
Results of this review were used in the selection of the systems for emphasis as noted in Section 3.1.2 of this report.
The plant equivalent availability for 1989 was b4%; although this was well below the goal of 70% for 1989, this appeared to be due to extension of the planned fuel outage to perform additional maintenance. The plant equivalent availability through August of 1990 was 93.2% which was well above the goal of 70% established for 1990.
Due to the 1990 refueling outage, the established goal for 1990 might not be met; however, the plant was on line from January through August of 1990 and established a record of 220 days for length of operation for domestic BWRs in the second fuel cycle. There were no unplanned
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reactor scrams while critical in 1989 and only one in 1990.
This exceeded the goal in this area for both years.
Forced outage rates for 1989 and 1990 were
0.8% and 1.3% respectively.
Both were under established goals.
There was one unplanned safety system actuation in 1989 and ot.e for 1990, which was better
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than the goal for both years; there was one techaical specification violation in 1989 and two in 1990.
Radiation exposure for 1989 was 767 rem which i
exceeded the established goal of 730; radiation exposure through August of l
1990 was 103 as compared to the established goal of 95 rem.
Although some of the established goals were not met, the plant appeared to perform well with long runs in both 1989 and 1990.
The extended runs could partially be attributed tu the extended outage in 1989 (which resulted in less availability and additional radiation exposure) to perform additional maintenance.
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the measurements appeared to indicate good performance.
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'3.1.2 System Selection
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The selection of systems and components for emphasis during this inspection was based on a review of data from LERs, latest SALP information, the Nuclear Power Plant Reliability Data System (NPRDS), the Probabilistic Risk Assessment (PRA) study furnished to 'he team by the Reliability Applications Section of the Office of Nuclear Rei.ctor Regulation, and discussions with cognizant personnel.
The systems selected were specific electrical, mechanical, and instrumentation equipment and components of the main feedwater system, the residual heat removal (RHR) system, and the control room heating, ventilation, and air conditioning (CRHVAC) system.
in addition, activities and documentation involving other systems and components were reviewed during the inspection, with consideration given to the systems considered most safety significant.
3.2 Descrintion of Maintenance Philosophy The inspectors reviewed site solicy statements, administrative procedures, organization charts, establis1ed goals, and documents that described improvement programs for the maintenance process.
The 1 consee had a documented maintenance plan that included milestones and completion dates for improvement programs and goals.
Discussions by the inspectors 4th selected managers indicated that those personnel were knowledgeable and aware of established performance goals and that the goals were being met.
The inspectors determined that the maintenance program was balanced between corrective maintenance (CH) and preventive maintenance (PM).
The licensee addressed appropriate PM requirements for equipment.
Raliability centered maintenance (RCM) was addressed in a program entitled,
" Systematic Maintenance Optimization." The program was not formally documented in procedures; however, the methods described in informal guidelines and in discussions with licensee personnel appeared to describe an excellent method of equipment and component evaluation for reliability centered maintenance.
A Systematic Maintenance Optimization information form was used to determine the importance of a selected component.
This was a sean page form that appeared to be very thorough.
Instructions for completing this form were contained in a document entitled, "SMO Desk Guide";
however, there was no document that described how this information was utilized.
The reliability centered maintenance program had been implemented for 3 systems and implementation was scheduled for 25 additional systems before the end of 1991, 3.3 Observations of Current Plant Conditions & Onacina Work 3.3.1 Current Material Condition The inspectors performed general plant as well as selected system and component walkdowns to assess housekeeping, the general and specific material condition of the plant, and ;o verify that work orders (W0s) had been initiated for identified equipment problems.
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' Walkdowns included an assessment of the buildings, components, and systems for
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proper identification and tagging, accessibility, fire and security door integrity, scaffolding, radiological controls, and any unusual conditions.
Unusual conditions included but were not limited to water, oil or other liquids on the floor or equipment; indications of leakage through ceiling, walls or floors; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lighting.
During the walkdowns the plant was in a refueling outage and this factor was considered in the evaluation of plant material condition and housekeeping.
Results follow:
Identification of plant r.omponents and equipment was generally good
with appropriate identirication located on or adjacent to the equipment.
Thirteen incidents of defective or broken plant equipment which had not
been previously identified were noted during the inspection.
Individually none of these appeared to have safety significance; however, collectively they represent poor identification of equipment problems.
These items were identified to licensee personnel and W0s were issued for repair of the affected equipment.
Examples involved oil and water leaks, broken handles on motor control centers (MCCs), bent piping, damaged insulation and ungrouted concrete footings at switch yard structures.
Evidence of smoking was noted in some no smoking areas and fire
extinguishers had not been checked monthly as required.
Several previously unidentified personnel hazards were noted during the
inspection.
Examples included personnel working without safety harnesses, failure to use ear plugs and safety glasses and an uncovered pipe opening.
Housekeeping was bad in several areas.
Examples included oil soaked
paper, leaves and rags near several transformers.
Several areas throughout the plant including piping, equipment, walls,
floors and ceilings needed painting.
Some water piping inside containment was badly rusted and pipe flange bolts could not be easily removed.
Overall plant housekeeping and material condition were considered satisfactory, however, improvements were needed in both housekeeping and identification of items requiring maintenance.
The material condition appeared to maintain operability of components at a level commensurate with the components' function.
Housekeeping was good in some areas but was very poor in others.
Most of the poor housekeeping appeared to be in non-safety related areas.
Painting was poor or non existent in some areas with some i
piping and components severely rusted.
A number of defective components or j
equipment, which had not b2en previously identified, were noted.
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problems noted appeared to have safety significance or have a significant i
effect on the operation of the plant.
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3.3.2 Onacina Wor _k
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Maintenance activities were observed to determine if those activities were adequately performed, were in accordance with required administrative and technical recuirements, and were consistent with the effect on the safe operation anc reliability of the licensee's facility. Work activities were assessed in the following areas: work control and planning; management presence, invMvement, and knowledge; quality control (QC) presence and involvement. W Oth physics (HP) support and hazards; procedure availability, adequacy, u-c 1 general conformance to NVREG/CR-1369; personnel training and qualificatio'n;' material availability, adequacy, and use; measuring & test equipment (M&TE) application and calibration; post maintenance testing adequacy including proper acceptance criteria. The inspectors observed ongoing work in elecvical, mechanical, and instrumentation and controls (I&C)
maintenance areas.
The inspectors selected these activities from the plan of the day listings, work assignments in individual maintenance shops and through discussions with individual foremen.
Where possible, safety significant activities were chosen for direct observation.
3.3.2.1 Onooina Electrical Maintenance The inspectors observed portions of 12 electrical maintenance activities as discussed below:
WO880009303 Replacement of Fuse Blocks WO880009305 Replacement of Fuse Blocks WO890002055 Testing of 4 KV Breaker WO900000ll5 Replacement of a Blown Capacitor on Panel IE22 WO900002318 Replacement of Aluminum Bus Bars WO900002321 Replacement of Aluminum Bus Bars WO900004356 Replacement of Cable for Unit 1 Division 1 Diesel Generator Jacket Water Heater Egnetitive Tasks R85-3705 General Maintenance of MCCs l
l R86-2020 General Relay Maintenance R86-5716 Testing of Ground Fault Relay for Circulating Water Pump Motor IB R86-13779 Maintenance of Breaker for Circulating Water Pump Motor IA R87-3113 Testing of Undervoltage Relays on Panel EH 1202
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-* During the observation of electrical work, the following were noted:
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The quality control coverage was generally good for the electrical jobs
observed.
However, in case of the Repetitive Task No. R85 3705, the QC inspector was called and waited for maintenance personnel for about one-half hour; for work order No. 890002055, the electrical technicians had i
to wait for the QC inspector for over an hour prior to commencing the work.
During the observation of work for repetitive task No. R87-3113, the
electricians had to determinate and reconnect the time delay relays.
The technicians, when questioned regarding the polarity of the i
terminals, could not identify the polarity.
Even though several
drawings were mentioned in the test )rocedure, the technicians did not have them at the work site.
The wor ( was suspended for more than half an hour before the drawings were obtained prior to determination. This
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was an isolated instance noted by the inspector. The work packages for j
more complicated work did include the required drawings, t
it appeared that the planning section which reviewed the work packages, did not review the drawing requirements for smaller jobs such as repetitive tasks.
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The inspectors concluded that except as noted above, observed electrical maintenance activities in the pertinent areas described in 3.3.2 were adequate i
and accomplished by skilled maintenance personnel.
The maintenance supervisor
and craft appeared to be knowledgeable and adequately trained. Work was com)1eted in accordance with procedural requirements.
Test equipment used was wit 11n correct calibration dates.
Electrical maintenance personnel were knowledgeable, had extensive experience, and exhibited a sense of ownership in maintaining plant equipment.
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3.3.2.2 Onaoina Mechanical Maintenance The insaectors observed portions of 12 mechanical maintenance activities as listed aelow:
WO890004117 Installation of a spring pack in PL lE12F0037B on the containment pool cooling isolation B loop of the Residual Heat Removal (RHR) system i
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WO890005227 Overhaul of a N 95 valve hydramotor for the plant radiation system WO890005481 Seat lapping of condenser air removal gate valve l
WO890006470 Five year inspection of turbine building chilled water chiller i
WO890006472 Five year inspection of control comple x chilled water chiller "B"
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i WO890007005 MSIV disassembly repair and reassembly of valve "C"
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WO890007007 MSIV disassembly repair and reassembly of valve A WO900000382 Ins)ection and eddy current testing of "B" RHR heat exc1 anger WO900000639 Snubber Testing WO900000810 Rebuilding of a Target Rock Relief Valve from the Emergency Water System t
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WO900004130 Motor driven feedwater pump repairs WO900003544 Five year inspection of Division 2 Emergency Diesel i
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l Repetitive Task 86-14291 Change oil, megger motor, and visually inspect l
circulation water pump "C."
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During the observation of work, the following were noted:
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WO890004117 - The inspectors observed two workers having difficulty installing the spring pack in valve IE12F00378, a Motor Operated Valve
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(MOV) on the containment pool isolation B loop RHR system.
They did not have a )rocedure or a copy of the work order while performing this work.
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The wor <ers indicated that the cause of the difficulty was mis.lignment
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I of the tripping fingers and the spring pack. The worI( was being performed by contractor personnel.
- WO890005227 - Procedure PMI-0061 " Overhaul of N-95 Hydramotors," was used to perform this WO.
Section 5.2.7 described the removal of two i
parts from the hydramotor.
The procedure was intended to provide j
instructions to refurbish the two parts and reinstall the parts.
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However, the way the section was written, only one part was specified to i
be installed and the part was incorrectly identified.
The licensee I
changed the procedure to make it clear to refurbish and reinstall the
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two parts.
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The inspector concluded that, except as noted above, observed mechanical
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maintenance activities in the pertinent areas described in 3.3.2 were adequate and accomplished by skilled maintenance personnel.
The maintenance personnel aapeared to be expericy.ed and knowledgeable of the work performed. Health i
p1ysics technicians were available near the maintenance jobs in radiologically controlled areas and a high level of cooperation was evident between maintenance and health physics personnel. Maintenance supervisors were not always observed at the je5 site, but they were in constant touch with the technicians and aware of the progress of the maintenance jobs discussed.
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3.3.2.3 Onaoino Instrument and Control Maintenance
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The inspectors observed portions of five 11C maintenance activities as discussed below.
Revision numbers are followed by temporary change notice i
numbers in parenthesis when applicable.
J ICl A2-19 Calibration of Fluke 6910 Digital Multimeter, Revision 0 l
ICl A8 1 Calibration of Model 1040 Digital Calibrator, J
Revision 3(5)
ICI A25 7 Calibration of Dial Calipers, Revision 1(1)
ICl-C R43 3 DG Pneumatic Logic Board Functional Check, Revision 0 SVI.071 T0256 Turbine Control Valve fast Closure Response Time, RevisionO(8)
During the observation of work, concerns were identified relating to procedure
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technical review as described below:
ICl C-R43 The technical review of this procedure was poor.
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purpose of the procedure was to verify the pro)er operation of the diesel pneumatic logic board and was accomplis 1ed in the !&C workshop.
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The procedure was being used for the first time. The I&C technicians could not meet the acceptance criteria for steps 5.2.3.3 and 5.2.3.8 and contacted the WO planner.
The planner determined that the procedure had
been written assuming the logic board was installed.
This deficiency would have been easy to detect during a proper technical review.
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inspector confirmed that subsequent testing verified operability and
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concluded that there was not a safety concern.
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SVI-C71-T0256 - The technical review of this surveillance was poor and
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feedback of a procedural deficiency was lacking. The purpose of the surveillance was to measure the turbine contro) Yalve fast closure and end-of-cycle response time for turbine control Ghe channels A, B, C,
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and D.
The inspector observed that the technin ans could not perform l
step 5.1.1.16.c which stated, "At P680, request Operations to reset Condenser Vacuum Low (Turbine Trip)....(N/A if Main Turbine is already reset.)." Performance of the step was not possibic because there was no
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reset switch at P680 or anywhere else. The step should have stated
" verify reset." A proper technical review should have identified this error.
The step was added in January 1988 to ensure that the main turbine could be reset. The surveillance had been performed two times l
subsequent to the change.
The technician apparently interpreted the step correctly (* verify reset") but failed to stop performance or notify management.
Temporary Change Notice (TCN) 9 was issued on September 20, 1990 to correct the error.
The inspector evaluated the effect of the
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error and determined that no safety concern existed.
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The licensee issued TCN 6 to SVI-C71-T0256 on February contained the identical typo raphical errors in steps 5.1.2.17.c, 24, 1989.
It 5.1.3.17.c, 5.1.4.17.c, and
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criteria from 0.07 seconds maximum to 0.7 seconds maximum.The errors cha surveillance was performed subsequently using the nonconservative The criteria.
The licensee evaluated the test results at that tim startup.
correct acceptance criteria and found the results acceptable.
inspector confirmed this finding.
The failure to perform a proper technical reviewThe inspector was concerned that the criteria values, could have resulted in opera, ting the plant with aespecially of ac safety system partially inoperable.
The inspectors noted that the licensee had develo point and of tie lead falling off after attachment.
permanently installed at pre identified terminal points used for testingStandar test leads consisted of two pieces with a male / female retractable sheath The
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connector in the middle and terminated at each end with a spring loaded hook (mini grabber) instead of the normal alligator clip.
the technician disconnected the lead at the connector and then attached the mini-grabbers to the small hole on each solder lug. A second technician co lead halves were reconnected,then have clear access to perform an indepe in addition, since the solder lugs were only placed where testing was periodically performed, the chances of selecti wrong terminal was reduced.
The retractable sheath connector was used to prevent inadvertent grounding before connection.
jumpers was considered a significant strength.
This method of installing activities in the pertinent areas described in Section accomplished by skilled maintenance acrsonnel.
identified with the performance of tie work due to the above concernsThere we Overall, I&C personnel appeared knowledgeable and well trained for the wo
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performed.
3.3.2.4 Main Steam Isolation Valves (MSIV) Failure to Close 3.3.2.4.1 Synoosts of Event On September 7 commenced in pr,eparation for the second refueling outage.1990 maintain control of the reactor cooldown rate.cooldown, operators During the On Setember 7 1990 was slow close,d succ,essfully.at0626,1821F028B(outboardMSIV,BMainSteamLine)
closed position and the valve drifted open.The control switch was then placed in the close the valve unsuccessfully.
Operators then attempted to fast The control switch was left in the closed position and the valve subsequently closed on its own on September 7, 1990 0640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br />. At 0625 hours0.00723 days <br />0.174 hours <br />0.00103 weeks <br />2.378125e-4 months <br />, operators s
, at Main Steam Line) successfully; however, low closed IB21 F022C (inboard MSIV, C when the control switch was pl Ned in
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'the closed position, the valve also drifted open. Operators attempted to fast
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close the valve but were unsuccessful.
The control switch was left in the closed position and the valve closed on its own on September 8,1990, sometime between 1500 and 1913 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.278965e-4 months <br />. The last time these valves were satisfactorily fast closed was for surveillance activities on January 8, 1990. The licensee quarantined all eight MSIVs to preserve "as found" conditions and prepared a troubleshooting plan.
3.3.2.4.2 Onaoina MSIV Maintenance /Troubleshootina The inspectors observed sortions of two I&C/ Mechanical maintenance work activities as discussed )elow:
i WO900004182 Troubleshoot the failure of MSIV IB21-F022C to close WO900004183 Troubleshoot the failure of MSIV IB21 F028B to close
The inspectors concluded that the 1&C portions of the maintenance activities in the pertinent areas described in 3.3.2 wire adequate and accomplished by skilled maintenance personnel.
The maintenance personnel appeared knowledgeable and conscientious of the work performed.
However, concerns were identified with the experience of the mechanical craftsman and proper work planning /, reparation as described oelow:
WO900004182 - To determine the cause of the MSIV closure failure, the
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air pack actuators from IB21-F022C and IB21-F028B were removed, bench tested, and disassembled.
The licensee quarantined all eight MSIVs in an attempt to retain the "as-found" condition of the valves.
Bofore the disassembly of IB21-F0220, the inspectors noted that the air pack arrived at the I&C hot shop in a condition different than the condition noted by the inspectors the day before.
Hold down bolts on the Norgren 4-way, 3-way, and 2-way valves were loose.
It was later determined that a " junior" worker removed the air pack on September 18, 1990, and had inadvertently loosened these bolts. The WO used was not prescriptive enough for tht experience level of the worker, especially since the worker had never worked on the MSIVs before. The inspectors werc
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concerned with the licensee's use of a worker, with limited MSIV experience, for this important maintenance task.
Criterion V of 10 CFR 50, Appendix B requires instructions or procedures of a type appropriate to the circumstances be provided for safety
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related activities.
Appropriate instructions were not provided for
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removal of the MSIV air pack. This is a violation of 10 C'R 50 Appendix B, Criterion V (440/90012-OlA).
Because the root cause of the valve failure was unknown, the "as-found" condition and subsequent testing would be used in determining root l
cause.
The air pack was functionally tested with the bolts loose and
failed to operate.
The bolts u re then retorqued and the air pack performed properly.
The licensee prevented recurrence of disturbed
l quarantined conditions by supervising the removal of the air pack on 1821 F0288.
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To bench test the air pack, the control unit was mounted on a test rig
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and connected to a regulated 90 psig nitrogen supply and a test box.
Although the licensee had approximately ten days to plan this evolution, a test fitting took over twelve hours to obtain.
Because the same test was performed by the licensee in 1987, the inspectors envisioned better planning and preparation for the troubleshooting.
Functional testing, visual inspection, and electrical testing of the air packs and air pack components revealed no obvious cause of the failure of the two MSIVs to fail to fast close. Through discunions with the appropriate
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vendors, the licensee concluded that there are two probable scenarios that could allow both MSIVs to remain in their original position following operation of the closing switch.
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Failure of either or both of the dual coil Automatic Switch Company (ASCO) solenoids to de-energize or shift from their energized positions, 2.-
Failure of the Model 8323 valve to shift positions following de-energizatior of the ASCO solenoids.
s Based on these failure %echanisms, an analysis plan was finalized using the 1987 investigation of similar problems and discussions with appropriate vendors. The approrriate parts from the air packs were segregated and packaged for delivsry to Ricerca Lab for analysis.
An electrical analysis was also performed ar.d determined that the failures were not the result of electrical malfunctions of the. solenoids.
During disassembly, no foreign materials were found in the valve internals.
Body gaskets showed no evidence of high temperature exposure. There was no evidence of moisture intrusion in the solenoid coils.
The Viton disc on the solenoid operated disc holder was observed to be somewhat deformed in that, an annular dimple was observed on the Viton disc of the disc holder. This was caused from the disc holder being l
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aushed against the raised (cone like) exhaust orifice of the solenoid valve sody causing the orifice to cut into the seat material. This appeared to result in part of the seat material being extruded into the exhaust orifice.
This dimple indicated that the disc holder could be held in an energized position even though the solenoid had been de energized, and would prevent the control air from being exhausted to atmosphere and therefore prevent the MSIV
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Analysis results from Ricerca Lab and final root cause had not yet been determined at the conclusion of this inspection.
Engineering and EQ personnel were pursuing potential design modifications to the air packs, based on discussions with Other utilities and with the air pack component vendors.
With the exception of the initial quarantined maintenance performed on the IB21-F0220 air pack, the licensee was performing a thorough, in-depth failure I
analysis.
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3.3.2.4.3 Past MSIV Maintenance History l
Perry experienced similar problems with the MSIVs failing to close in 1987.
The root cause of these previous failures was attributed to deterioration and degradation of the Ethylene Propylene Diene Monomer (EPDM) discs in the ASCO l
dual solenoid valve due to exposure to a high temperature environment.
To preclude similar failures, the licensee rebuilt all ASCO dual solenoid valves
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temperatures, in addition to this, the ASCO dual solenoids were placed on an 18 month replacement cycle.
On July 10, 1989, all of the ASCO solenoids on the MSIVs were replaced from EPDM-type to Viton-type.
The solenoids were scheduled for replacement again during this outage.
As a result of previous failures in 1987, the licensee committed to the installation of temporary temperature elements in the vicinity of the ASCO dual solenoids and on the solenoids and the valve bodies themselves in both the steam tunnel and the drywell. Historical readings of the permanent steam
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tunnel and drywell temperature elements in the vicinity of the MSIVs were also evaluated. A monthly ASCO dual solenoid operability test and a quarterly fast closure time test was also performed. The temporary temperature monitoring and special testing was discontinued in March 1989 based on results obtained
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from a thermal endurance test program and to prevent unnecessary wear of the MSIV valve poppet and seating surface.
The inspectors evaluated the temporary temperature monitoring and the s)ecial testing and noted no elevated temperature trends or valve stro(e failures.
Approximately 20 W0s were reviewed to determine maintenance history on the MSIVs for the past two years.
No anomalies were identified that could be considered as contributing to the MSIV closure function failure.
3.3.3 Radioloaical Controls The inspectors observed the major support functions arovided by radiation protection (RP) and HP personnel for maintenance. T1ese functions included radiation work permit (RWP) preparation, as low as reasonably achievable (ALARA) reviews, and field support of on going work.
The inspectors also performed independent reviews of documentation, made independent dose rete measurements, and discussed radiological controls with plant personnel.
Overall, the licensee's program for providing RP support was good.
Some implementation probicms were identified, however, during observations in the plant. Details of the findings are discussed below.
RWPs and ALARA work packages, including ALARA reviews of jobs in-progress, were generally well written.
An extensive pre-outage planning document was l
developed by the HP group detailing ALARA measures for numerous work orders.
I HP activities, such as installation and removal of temporary shielding and area decontamination, were incorporated into the outage schedule along with the typical outage maintenance work.
Extensive use was made of mock-ups to improve wcrker efficiency for high-dose job', such as control rod drive removal and recirculation pump replacemt and a video-disc plant tour system was used by the maintenance group to -a' other jobs.
The licensee made good use of Unit 2 equipmer,t for planning / eork in Unit I and training of individuals. HP supervisors respon. ae for the drywell and the refueling floor were knowledgeable of mainte o ce activities in these areas.
Observations by the inspectors of ongoing jobs identified no prob' ems with HP support of maintenance activities or with the radiological practices of maintenance workers.
However, several problems were identified at the
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containment 599' elevation access control point, where workers signed RWPs for
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containment and drywell work and HP technicians provided RWP briefings as needed. At the beginning of the inspection, the HP accest control point was located just inside containment.
The inspectors observed, at the beginning of several work shif ts, a large number of workers lined up at and crowded around the control point waiting to sign RWPs.
In addition, the area was very noisy because of operating plant systems.
The inspectors raised a concern with plant management that the press of the crowd and the high noise could result in inadeamte communications between HP personnel at the desk and workers.
This concern was also expressed to the inspectors by several HP technicians.
Several licensee representatives also indicated that around the start of the outage, the P group had requested that work groups stagger their start times to prevent credding, but that was not done because of union constraints.
Subsequently, the contrni point was moved to just outside the containment hatch.
The added spaca in this area relieved the crowding somewhat, but, the noise level continued to be high.
Near the end of the inspection, the licensee had installed sound deadening material in the area to reduce the noise and moved the access control point to a nearby 1&C shop. During this time, the licensee a' a initiated a review of containment and drywell RWPs and identified several instances wnere workers signed the wrong RWP. At the start of the day shift on September 28, 1990, to ensure the problem was not widespread, the HP group stopped all work in the containment and drywell and began an investigation. The licensee determined that the problem was not widespread, and the area was released for work near the end of the shift.
The results of the investigation will be reviewed by NRC regional radiation specialists during a future inspection.
In addition to these probl *ms, the inspectors observed a relatively large number of workers at the drywell hatch step off pad area, contrary to a posted sign directing workers not to loiter in the area because of dose rates.
This matter was promptly addressed by the licensee.
3.3.4 Maintenance Facilities. Material Control and Control of Tools and
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Measurina Eaui'ad l
l 3.3.4.1 Maintenance Facilities
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The inspectors observed that the electrical and mechanical staffs were
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combined into one department with I & C in a separate department.
The I&C maintenance workshop area was located in the auxiliary building near the
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control room and was considered small for 45 technicians.
The general i
supervisor and all unit supervisors offices were immediately adjacent to the workshop.
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The licensee had recently completed a new facility for mechanical and electrical staffs.
The facility provided large work areas for the maintenance crews.
The facility included a tool room, a welder qualification area, supervisor's offices, and an area to assemble parts for W0s. The licensee proviced pumps, valves, circuit breakers, and other equipment for training maintenance personnel.
The licensee also had a large hot shop for mechanical and electrical maintenance located in the service building.
The hot shop was
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the former mechanical and electrical machine shop.
The licensee had very good
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facilities for mechanical and electrical maintenance personnel.
3.3.4.2 Material Control The inspectors reviewed the methods used by maintenance and s1pport organizations to control replacement parts and materials.
This review included replacement parts and materials used during observed maintenance activities, parts storage areas, and methods of storage.
Replacement parts and equipment were stored in the main warehouse that included a parts receiving area and a parts issue area. Warehouses and material storage areas were clean and well kept with controlled access.
The licensee had an area of the wsrehouse for receiving materials. Within the receiving area was a fenced off " Procurement Quality Hold Area".
The licensee had a separate mezzanine area in the warehouse in which safety related parts were stored.
Some safety related and non-safety related bolts and fuses were stored in the same drawers in a cabinet in the warehouset however, nictv related bolts and fuses were tegged as safety related.
Flammable matcri'al:
were stored in special cabinets in the warehouse.
Limited life ite ns weie stored with appropriate identification and limited life expiration,lates The inspector noted a couple of items with expired shelf life tags.
In"estigation by the licensee determined that the items had been evaluated and tht shelf lives extended but the items had not been re-tagged.
The licensee had an area within the warehouse which had temperature,ind humidity controls and qualified as a Level A storage area.
Safety related and non safety related parts were stored within this area.
Safety related parts were tagged as being safety related.
The licensee had two small separate warehouscs for oil storage and dispensation of oil.
A computerized system existed for parts inventory and location. Also a computerized system existed for ordering parts.
The licensee had a system to return spare parts to the warehouse that were not used after being withdrawn.
Control of most replacement parts and matet ial appeared to be good; however, a problem with the control of fuses was identified.
The review of licensees practices for storage and usage of fuses in the plant is discussed below.
The inspectors reviewed fuse control by operations personnel at the satellite fuse storage location in the operations support room.
Fuses of different sizes were stored in the same bins, with inadequate identification on the bins.
The inspector reviewed seven Condition Reports (CRs) issued by the station, which dealt with installing incorrect fuses. Of these, three were for 1986, and one each for 1987, 1988, 1989, and 1990. The licensee conducted a QA surveillance in the operations satellite fuse storage area after the inspectors concerns and concluded that:
Material control practices were lacking in that supporting documentation
was not organized or retrievable.
The documentation requirements for the fuse installation / replacement
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procedure PAP 0201 were not consistently implemented.
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The satellite fuse bins were not well maintained.
- The licensee issued QA Action Requests to correct these problems. As an immediate corrective action, the licensee suspended issuance of fuses from the operations satellite fuse bin.
The licensee also stated that these fuse problems had not resulted in a wrong fuse being installed in the plar.t.
The inspectors also reviewed the fuse storage areas in the maintenance warehouse and the main warehouse. The fuse control in the maintenance warehouse was good. All bins were properly identified and contained the fuses as per the fuse control program. However, the ins)ectors identified problems with the fuse storage and control in the main warelouse as follows:
The inspector noticed that boxes of fuses of several different sizes
were stored in a bin bearing only one stock code number; however, individuci fuse boxes were identified with the proper stock code. The inspectors also noticed that several fuses of different sizes were stored loosely in a bin without boxes or bags, in one case, two different sized fuses wera found in the same cardboard box.
The licensee stated that compartment dividers will be used to prevent mixing of fuse types and lots.
The inspector did not identify any instances where a wrong size fuse was t. sed from these bins.
The inspector on October 2, 1990, while reviewing the main warehouse
fuse storage area, identified that ir, the fuse cabinet WI FUSE 07, drawer 6, two groups of fuse boxes (10 boxes) with the same stock code number 9539602 were stored in the same bin. The fuses were made by the same manufacturer (Gould Shawmut) and were of the same size and type (600 volt, 200 amps). However, one group of 10 boxes was on hold per NR No. 90WSO40, since February 2, 1990. A loose hold tag was lying on top of these boxes but was not attached.
The licensee's QA plan required that nonconforming materials where practical be segregated from other material and positively identified.
Contrary to the requirements of the above procedure, the nonconforming fuses were stored in the same bin as acceptable fuses.
In addition, positive identification as nonconforming material was not attached. The failure to adequately control nonconforming material is a violation of 10 CFR 50, Appendix B, Criterion XV (50 440/9012-02).
3.3.4.3 Control and Caliteration of Measurina and Test Eauioment The inspectors reviewed the control and use of M&TE.
All defective or
" calibration due" instruments were stored separately from those that were in calibration and acceptable for use.
Procedure PAP-1201, " Control of Measurirg and Test Equipment," Revision 4, was used for the issue, return, and recall of M&TE. Technicians were trained on the proper use of the instruments and verified that test instrument calibrations were not past due. Test equipment
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l use traceability was accomplished by recording the equipment unique
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identification number on form PNPP No 5002, " Request for M&TE" The user recorded all calibrations and te:ts on the form.
The form was returned when the test equipment use was complete. The form was kept on file until calibration of the tost equipment was performed.
If the M&TE was later found to be out of tolerance, lost, or damaged, the file could be searched for all W0s affected and evaluations could be perfor.ned as appropriate. Management monitored resolution of "M&TE Out of Calibration Reports" to ensure that resolution of reports was completed in a timely manner.
Calibration of M&TE was controlled by procedure PAP 1202, " Calibration of Measuring and Test Equipment," Revision 4.
The inspectors varified the calibration of selected M&TE items and found no discrepancies.
Calibration status was maintained on the M&TE Computer Tracking System using the uniqN identification number mentioned above. Calibrations were traceable to national standards.
3.4 Review and Evaluation of Maintenance Accomplished 3.4.1 Backloa Assessment and Evaluation The inspectors reviewed the amount of work accomplished compared to the amount of work scheduled.
Emphasis was placed on work that could affect the o)erability of safety-related equipment or equipment important to safety, w11ch included some balance of plant (BOP) conponents. Maintenance WO backlogs were evaluated for cause and impact oa safety.
Both the CM and PM WO backlogs were assessed.
in discussing the WO backlog with licensee personnel, the inspectors noted there appeared to be a difference between the definitions of corrective and preventive maintenance as used by the NRC and the licensee. What was normally considered PM by the NRC was called repetitive tasks by the licensee. Work called PM by the licensee was normally considered CM by the NRC.
For the purpose of comparison, the NRC definitions are used in this evaluation of maintenance backlog.
Maintenance and I & C management were tracking several categories of CM and PM backlogs. This information provided managem W with indicators of performance in maintenance and allowed management to maintain oversight of backlogs and to detect trends in backlog levels.
Overall, both CM and PM backlogs appeared to be well controlled and were well within the capabilities of the maintenance staff.
3.4.1.1 Corrective Maintenance Backloa in evaluating the CM backlog, emphasis was placed on non outage related work.
The total backlog of non outage CM work orders as indicated on the licensee records was 172.
In addition, 618 additional W0s were noted on a list classified as non outage PMs.
This provided a total of 790 non-outage CM W0s.
The inspectors did not note any outstanding items that appeared to affect the safe operation of the plant or had an adverse effect on plant availability.
The non outage backlog could be eliminated in two to three months if no other work were performed.
The number of W0s on hold for parts was very low and did
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- not appear to contain W0s for equipment considered to be safety significant.
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Although some corrective maintenance was rescheduled, the inspectors noted no significant cms which had been inappropriately deferred.
3.4.1.2 prevent.ive Maintenance Backloa The inspectors reviewed the backlog of both outage and non-outage PM items.
Based on the Perry definition this was defined as repetitive tasks. The scope of the program appeared to be good with more than 18,000 items in the program.
Results indicated a well managed backlog in the maintenance and I&C area:.
The licensee had an evaluation and approval process for deferral of repetitive tasks items.
The evaluation process appearad to be adequate and the repetitive task deferral evaluations reviewed by the inspector appeared to be adequate.
Rescheduled repetitive tasks did not show as over due; however, since adequate evaluations appeared to be performed prior to rescheduling, this did not appear to be a significant problem.
None of the open repetitive items reviewed appeared to have a significant impact on plant system operability.
3.4.2 Review and Evaluation of Comoleted Maintenance The inspectors selected equipment and systems identified in Section 3.1.2 of this report for further review.
The purpose of this review was to determine if specified electrical, mechanical, and 1&C maintenance on the selected systems / components was accomplished as required.
In each maintenance discipline this review included one or more of the following:
Evaluation of work procedures for completeness, adequacy of. work instructions, acceptance criteria, inclusion of vendor requirements and recommendations, QC hold points, case of use, necessary approvals, and general conformance to NUREG/CR-1369.
Evaluation of completed CM and PM for use of qualified personnel, proper prioritization (based on risk), QC involvement, quality of documentation for machinery history, acceptance criteria, description of problems and resolutions, and post maintenance testing.
Evaluation of the extent that vendor manual recommendations, NRC Bulletins (NRCB), NRC Notices (NRCN), Service Information Letters (Sils), Significant Operating Experience Reports (SOERs), and other outside source information were utilized in the development, correction or upgrading of the maintenance preress.
Evaluation of the extent that outside source information, maintenance histories, LERs, negative trends, rework, extended time for outage, frequency of maintenance, or results of diagnostic examinatic,,s were analyzed for trends and root causes for modification of the PM process to preclude recurrence of equipment or component failures, 3.4.2.1 Past Electrical Maintenance
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Change fuse sizes on Feedwater Systea valve operator
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W0880006517 Motor operator maintenance in RHR System WO880006526 -
EQ configuration inspection and limitorque maintenance WO890000142 -
Feedwater pump motor bearing inspection
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Replacement' of RHR valve operator motor WO890002113
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Inspection of 1.imitorque operator L
Replacement of HPCS pump motor
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' Replacement of burnt feedwater pump motor
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Power control circuit 1E12 design changes l
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Replacement of relays on the control ro,m HVAC supply.
fan
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' The work packages reviewed were generally adequate. The description of work
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done contained details of procedures used and the pon maintenance testing
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~The following comment applies:
The werk package stated that F. wrctg grease was A
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ordered -(EPI instead of.EFO) for the job ~. This, 9ared to be a lapsc
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ofgjot t'anning. This was correcud.
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F The inspectors reviewed the following five maintenance procedures.
L GEI-006,.
" General Maintenance of Motor' Control Centers," Revision.2
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GEI-029,
"Testir.g of molded case circuit' breakers and overload heater (
L relays," Revision 1
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gel-0124,
" Solid state trip: testing and calibration," Revision 2 1* I
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HAP-0203,
" Conduct of Maintenance,". Revision 3 f
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MAP-0902,
" Protective Relay Program,"-Revision 2
'The procedures were satisfactory.
The procedures were reviewed-for technical
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. adequacy once every two-years. When necessary, temporary changes were issued a
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in accordance with PAP-0522, " Temporary Changes to Instructions," Revision 4.
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'3.4.2.2 Past Mechanical Maintr;cance
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The inspectors reviewed 14 completed mechanical W0s.
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WO8800002:7 -
Repair motor operated valve on feedwater system WO880003244 -
Main feedwater pump "B" thermocouple replacement
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Replace feedwater globe valve WO88006934
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Replace feedwater seal injection pump bearing
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Main feedwater pump "B" uncouple pump froh, turbine o'
Repair feedwater booster pump "lB" W0890000460 -
Design change on Limitorque valve operator for i'
l residual heat removal valve WO890000509 -
Main feedwater pump'"B" repairs for increased vibration i
WO890006524%
Rework / Replace the air starting distributor for the
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Division 1 Olesel Generatcr L
. Repair control room heating, ventilation, and air conditioning (HVAC) damper curtains-
Perform repetitive task on' RHR Limitoi.,oe valve
Repack Valve -(IE51F0026). in the Reactor Core
~ Isolation Cooling System
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Remove, Test, and Reinstall. Snubber IN27H0222 on the.
feedwater system
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Repair the control room HVAC outside air isolation damper
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The instructions provided on tl'e W0s were usually very detailed.
The
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summaries of work performed were detailed so the root cause could be
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determined and provided good descriptions'of theicorrective actions taken.
L Post maintenance testing, if required, was included in the W0s. cThe quality of mechanical W0s was very good, a
The;following 9 mechanical procedures were evaluated:
t OM9B:GMI-0015, " Repair of the Safety Relief Valves", Revision 1 i
OM9B:GMI-0021, " General Torquing," Revision 2 r
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. 0M9B:GHI-0042.. " Reactor Core Isolation Pump D!sassembly and Repair,"
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Revision 1 OM9B:GMI-0050, " Disassembly and Repair of the Vert P.al RHR Pump,"
Revision 1 OM98:GMI-0063, " Installation and Removal of the Reactor Head,"
Revision 2
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. OM9B:GMI-0068, " Instruction for the Installation and Removal of the Shroud Head / Separator," '.evision 4 OM9B:GMI-0096, "MSIV Disassembly, Repair, and 3eassembly ~ Instructions,"
Gevision 2
'l-0M1A: PAP-0205, " Operability of Plant Systems," Revision 6
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OMlH: PAP-1108, " Vibration Monitoring Program," Revision 2 The procedures provided detailed instructions. Any pod ion of the procedures which fulfilled a commitment was identified by a. code at the end of.that
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pcrtion..This_ code referred to the source of the commitment and its
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identifying number. This had been very helpful when the licensee was revising
. procedures.i A concern was identified with one procedure.
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GMI-0042'- The procedure had=an Attachment 8 which was to be used to, document measurements-and list equipment numbers.
There was no
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reference to Attachment 8 in the body of the procedure.
The licensee agreed to revise the procedure to reference Attachment 8.-
'i (The-inspectors reviewed the.following vendor ~ documents for: selected mechanical components to determine if PM recommendations were incorporated in mechanical.
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g maintenance: procedures.
Valve Operator _. ' International Telephone and Telegraph: Manual for A #95'
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Hydramotor Actuator
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Chilled Water Chiller - Carrier Instruction Manual, " Operating
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' Instruction for. Carrier Centrifugal Refrigeration Machines" j
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Motor for Motor Driven Feedwater Pump - Allis Chambers Instruction book'for 5000 HP Induction Motors
. Motor' Driven feedwater Pump - Transamerica Delaval' Instruction for Motor
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Driven Feedwater Pump
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-Appropriate vendor recommendations from the above documents had been
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incorporated into Repetitive Tasks.
The inspectors evaluated the extent that the licensee's review of external l
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operating experience reports was factored into the maintenance program. The s,
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inspectors concluded that the internal reviews and evaluations included
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applicable items in the maintenance program for the following reports:
Limitorque 10 CFR Part 21 report dated November 3, 1988, regarding
Melamine torque switches
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IEN 89-07, Failure of small diameter. tubing (air, fuel, oil) on emergency. diesel generators (EDG) resulting in inoperable diesels
IEN 89-76, Bio-fouling-Zebra mussels
IEN 90-11, Maintenance deficiencies associated with solenoid operated i
valves.
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IEN 90-37, Sheared pinion gear-to-shaft keys on Limitoque motor actuator
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IEN 90-32, Retention of broken charpy specimens
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Based on the review of completed W0s, backlog, work history of selected components,:and maintenance procedures, the inspector-concluded that past
' mechanical maintenance =had been accomplished in a satisfactory manner.
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3.4.~2.3 Past Instrumentation and Control Maintenance b
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L The inspectors reviewed 12 completed I&C W0s.
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860014684 Revise Div=I wiring per DCP 860805..
880008274 Troubleshoot loss of trip indicator light' on feedwater p
system.
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'880008324. Implement portions of DCP-880082.
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LV 890003019 Troubleshoot monitor indicating' upscale.
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890004002 Troubieshoot chlorine monitor flow light out.
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890005271 Torque shut valve.lE12-F008.
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l 890005539 Troubleshoot dual position indication on damper.
890005748 -Troubleshoot RHR instrument flow loop.
fg 890006575 Standing WO for chlorine monitors.
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Q 890006842 Troubleshoot damper ciosure circuit.
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900001971-Troubleshoot fan trip and inability to restart.
900003164 Troubleshoot cause of damper not closing properly, r
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The W0s were satisfactory in scope and content.
Prioritization was proper and
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QC involvement adequate.
Documentation of corrective action was sufficiently detailed for trend identification and root cause analysis when combined with
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other historical plant data.
Post maintenance testing was identified properly and was satisfactory in scope. However, concerns were identified relating to troubleshooting without a W0 and improper troubleshooting methods.
W0s 890003019, 890005271, 900003164 - Troubleshooting for these W0s
began before the WO was issued and approved.
Procedure PAP-0905, " Work Order Process," Rev. 10, paragraph 6.11.1 permitted the Unit Supervisor to initiate troubleshooting when _"immediate" corrective action was required.
PAP-0902, " Work Request System," Rev. 5, stated that priorities were assigned by the Unit Supervisor and defined Priority 1 as " repair immediately." However all of these W0s except 890005271 were classified Priority 2 which was defined as " repair within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />."
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addition, nochanical WO 890005271 was classified Priority 3 which was
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defined to "be completed as soon as possible." The inspector confirmed that the priority assignment was proper for these W0s and therefore
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immediate corrective action was not required. Hence, the.need to begin troubleshooting before the WO was issued and approved, apparently did
.not meet-the intent of PAP-0905.
- _890005539.- Troubleshooting for this procedure was poor.
The problem was " dual position indicatior, present for 0M25F110A with damper verified
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cl osed. " The damper was approximately 20 feet above the floor.
The i
technician initially examined the " limit switch actuator for loose locknuts, excessive play, etc. and noted no abnormal conditions." The damper was stroked several more times without a problem.
The technician concluded that the: problem was corrected. However, one day later the technician.was required to troubleshoot the sa'e problem and noted that the " conduit feeding the LSC (limit switch) had been tie-wrapped to the actuator... which prevented the actuator from pivoting."- The tie-wraps were cut off to allow the actuator to pivot freely as designed. The binding created by'the tie-wraps was the cause of the dus1 indication.
The inspector was concerned that the technician did not recognize the-cause during-the initial examination when it was clearly visible.
~ 900003164 -' Troubleshooting for this arocedure was poor.
Based on
troubleshooting results, the responsi)1e System Engineer directed the technician to replace a relay and a solenoid valve.
The technicians did not review the electrical drawings before beginning work.
During the-attempt to' replace the rei unexpected CRHVAC damper actuation
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occurred. Work was stop;_
control room (CR) personnel.. After reviewing elementary electrhal drawings, CR personnel permitted resumption of work.
However, elementary drawings did not show actual
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physical connections. These connections were shown on interconnection wiring diagrams (IWD) but the IWDs were not referenced on the W0. Only one " lead" was shown connected to the relay on the elementary drawing.
The IWD showed two leads. One was the neutral current path to the rela).
The other was a continuation of the neutral current path to the chlorine monitors.
When the leads were lifted, the neutral pati. to the
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u nitors was broken, and the monitors failed safe and initiated a CRHVAC
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Emt.rgency Recirculation Mode signal.
A Licensee Event Report was prepared. The inspector was concerned with several weaknesses.
First, the technicians failed to review drawings before beginning work.
Second, the technicians did not use IWDs when reviewing the damper
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actuation problem with CR personnel even though dam)er actuation had been unexpected. Third, the WO did not reference tie IWDs.
Fourth, the technicians failed to recognize the obvious difference between the
" connections" shown on the elementary drawing and.the actual physical
connections in the field when work was restarted.
The inspector
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reviewed the actions taken by the licensee including management involvement and continuing training and concluded that these concerns had been addressed adequately.
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.The following five )rocedures were reviewed for the attributes in section 3.4.2.
The TCN num)er is shown in parenthesis.
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" Plant Instrumentation Calibration and Maintenance,"
Revision 3(0)
SVI-Cd4-T5373
"FW/ Main Turbine Trip-Reactor Water Level.High,"
Revision O(9)
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L SVI-C71-T0256
" Turbine Control Valve Fast Closure Response Time,"
L RevisionO(8)
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SVI-E12-T0146
"ECCS/LPCI Pump A Delay Relay Calibration,"-
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Revision 1(10)
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.SVI-E12-T0358C
" Containment Pressure High Calibration,"
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s Revision 1(10)
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pt-The-procedures were generally well written and consistent with vendor.
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instruction manuals. Acce)tance criteria were adequate and provided actions
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to be taken if not met. T1e high number of TCNs to_the surveillance-fm'
istructions (SVI) was considered to be a weakness.
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The' number of TCNs seemed unusually high. A! detailed review showed that
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there were -46 SVIs with 10 or. more TCNs' issued since the'last revision..
N PAP-0522, " Temporary Changes to Instructions,." Rev.4, defined a temporary change as a change made to an app.'oved instruction prior to-E the next revision. TCNs received technicalcand 10 CFR 50.59
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. applicability reviews.- Some of the TCNs.. simply consolidated previous R
TCNs and appeared to be,lin fact, revisions.' 'TCNs were preferred over
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the revision process because TCNs were easier-to accomplish. The review lu of.a TCN was limited to just the pages affected while a revision required the entire procedure to be reviewed at the same~ time.
Tho' -
h inspectors were concerned that a significant: number of changes had not.
E, been: subjected to' the multi-discipline revision review process which
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L would ensure that the previous changes were consistent and had not i
inadvertently eliminated neces..io steps.
In addition,'many of the TCNs.
.had been in place for severa' n rs.
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' The inspectors reviewed actions taken in response to the loss of fill fluid
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defect identified by the Rosemount 10 CFR Part 21 notification of February 7, 1989.
The licensee had identified 277 Rosemount transmitters within the scope of the notification.
Individual computerized trend records were esthblished showing the results of all calibrations including as-found and as-left data.
The data was anal / zed and evaluated as recommended by the vendor.
Only three
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failures were detected due to loss of oil.
The licensee was an active participant in the BWR owners group on Rosemount failures.
Plant operators
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had been trained on transmitter failure symtoms. The inspector concluded that actions taken in response to the Part 21 defect notification were excellent.
Based on the review of completed CJs and PMs, backlog, and procedures, the L
inspectors concluded that past performed maintenance had been accomplished in a satisfactory manner.
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3.5 Fire Protection The inspector reviewed the qualifications of the fire protection engineer, ftre protection systems engineer and fire brigade training instructor. The irdividuals' qualifications appeared appropriate for their positions. The f
inspector ruviewed fire protection audits and observed that management involvement was evident by the adequate resolution of the items identified by the audit.
No discrepancies were observed in this area.
Strengths observed consisted of the development of the Fire Permit Administration System which consisted of monitoring the amount of transient combustibles (including flammable and combustible liquids), burn permits (cutting and welding
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permits), and impairments to fire walls and fire protection systems in any given safety related area of the plant. Another strength noted was the improvement of the pre-fire plans that were presented on 11"x17" paper encased in plastic. These pre-fire plans are updated and located in several key areas
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of the plant. The pre-fire plans are utilized during fire drills and their use is considered a key critique objective.
PAP-1913, " Control of Transient Combustibles," Revision 3 and PAP-1912, " Burn Permits for Ignition Sources," Revision 3 were adequate to limit the amount of
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combustibles and flammable / combustible liquids, and control cutting and'
welding activities in safety related areas of the plant.
However, the inspector observed that the cutting and welding procedure was not adhered to in that the responsible supervisor signed the burn permit prior to the F
firewatch verifying th.. all notifications, precautions, limitations and
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inspections were performed as required by the Burn Permit (PAP-191E).
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Technical Specification 6.8, entitled " Procedures / Instructions" requires that written procedures be established, implemented and maintained for the Fire
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Protection Program.
The failure to follow procedures is considered a g
violation of 10 CFR 50, Appendix B, Criterion V (440/90012-01B(DRS)).
3.5.1 Fire Protection Activities An unannounced fire drill was conducted to determine whether fire brigade personnel were properly trained and ready for fire suppression activities, and if adequate fire fighting equipment was available.
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' The driil simulated a fire / explosion hazard that occurred due to lightning
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-strike on the "A" Phase of the Main Transformer. The scenario postulated a transformer fire and damage to the side of the turbine building. The inspector observed the fire fighting actions taken by shift personnel during the postulated fire incident and determined overall effectiveness of the shift personnel during the fire drill.
The inspector observed the fire brigade leader's direction of fire fighting efforts, donning of protective equipment clothing, use of hose stream (actual flow), use of portable radio communication equipment, brigade timeliness, and fire brigade leader interaction with the control room.
The inspector concluded that the fire brigade performed satisfactorily.
During the critique, the scenario and actions taken by the brigade were discussed. Alternatives and improvements in fire fighting were also discussed.
No unacceptable items were identified during the critique.
3.5.2 Onaoino Fire Protection Maintenance Activities The inspector witnessed the deluge systea test for the Unit 1 main generator
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transformer phase "A", Unit 1 main generator transformer phase "B", and Unit 1
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auxiliary transformer.
Problems identified during the testing of the deluge
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system were of a minor importar.ce and work reauest were written to address these problems.
No
- eptable iteme were ibeerved.
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3.5.3 Past Fire' Protection Maintenance Activities The inspector reviewed the following completed surveillances:
-PTI-P54-P0014,
" Water Spray, Preaction Sprinkler and Spray System Functional Test," Revision 2
'PTI-P54-P0016,
" Carbon Dioxide Storage Tank Pressure and Capacity Verification," Revision 3 PTI-54-P0018,
" Carbon Dioxide Hose Reel. Puff Test," Revision 2 PTI-54-P0021,
" Carbon Dioxide System Operability Test For Unit 1 Control Room," Revision 1 PTI-54-P0024,
" Diesel Fire Pump Weekly Battery Checkout,"
Revision 2 PTI-P54-P0025,
" Water Spray System Flow Test-for Unit 1 Hydrogen
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Seal Oil Unit," Revision 2
' P0026,
" Diesel Driven Fire Pump Battery inspection,"
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Revision 1 PT W P0027,
" Diesel Fire Pump Battery Specific Gravity Check,"
Revision 1 PTI-P54-P0034,
" Unit 1 Diesel Generator Carbon Dioxide System Detection /0perability Test" PTI-P54-P0036,
" Diesel and Electric Fire Pumps Flow Data and Control Panel Functional Test," Revisions 2 and 3.
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' PTI-P54-P0046,
" Unit 1 Fire Detection Functional for Deluge
Control Panels (lH51 P209, lH51-P210) Heat Detectors,"
Revision 2 The completed surveillances and corrective actions were found acceptable with the exception of PTI-P54 P0036, Revision 2 where the following items were
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identified:
1.
The electric driven fire pump and the diesel driven fire pump were not tested at shut-off pressure (all tests).
2.
The electric driven fire pump test conducted on 9/2/87,3/12/89 and 9/9/90 indicated a significant pressure reduction of (30%, 33%
and 35% respectively).
3.
The diesel driven fire pump test conducted on 9/2/87, 3/12/89 and 9/9/90 did not consider engine or pump speed at overcapacity.
4.
The electric driven fire pump test results for tests conducted on 9/2/87, 3/12/89 and 9/9/90 and the diesel driven fire pump test results for tests conducted on 3/12/89 did not demonstrate that the largest flow demand of a single pump (3750 gallons per minute at.85 pounds per square inch) could be developed by any single pump.
During the-9/9/90 fire pump test, thc licensee identified that the flow meter readings were in error and that the fire pump test procedure needed to be revised. The licensee indicated that no credit was.given for the 9/9/90 test and that the revised procedure and test would be required to be completed-within its permissible late surveillance date of 1/21/01.-
The Facility Operating' License NPF-58 requires that the licensee adhere to the-
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approved fire protection program as approved in the Safety Evaluation Report
. dated May 1982 and Supplements Nos. I through 10.
The licensee's approved fire protection program requires that the licensee conform to National Fire
- Protection Association Standard Number 20 which requires that the fire pumps L
be tested at peak loads and that any significant reduction in the operating characteristics of the fire pump be corrected immediately. Although, the
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licensee _ identified.the inadequate testing of the fire pumps during the 9/9/90 pump test, the pumps were tested on at least two other occasions where the inadequate testing of the fire pumps should have been identified. The lack of
. testing the fire pump.at shut-off, lack of identifying and correcting i'
significant reduction in the' operating characteristics of the fire pumps and finally, not meeting the largest flow demand for each pump is considered a l-violation of the Facility Operating License NPF-58, Section 2.C(6)
(440/90012 03A, B, C(DRS)).
The licensee subsequently tested _ the fire pumps
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with more acurate test instruments and reported the results to the inspator,
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which indicated the pumps were operable.
l 3.6 Maintenance Work Control 1'
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.The inspectors reviewed several maintenance activities to evaluate the
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' effectiveness of the maintenance work control process to assure that plant
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safety, operability, and reliability were maintained. Areas evaluated were control of maintenance work orders, equipment maintenance records, job
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planning, prioritization and scheduling of work, control of maintenance
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backlog, maintenance procedures, past maintenance testing, completed docu-mentation, and review of work in progress.
The inspectors observed the daily outage planning meeting where the plan of the day and maintenance activities were discussed by plant management. This meeting provided a means for prioritization of work, resolution of problems and scheduling of necessary resources to expedite critical work.
The inspectors concluded that this was an effective method of plant management oversight.
During the review of maintenance on the MSIVs that failed to close the inspectors noted several instances where adnquate control of the maintenance process was not evident.
These incidences are discussed in detail in Section 3.3.2.4 of this report.
During the review of completed maintenance work orders, the inspectors noted that work for four W0s was started prior to approval and issuance of the work order package. These W0s were not classified as errargency W0s and the work
prior to approval of the package did not provide good work control.
This item is discussed further in Section 3.4.2.3 of this report.
The maintenance schedule was built on a 13 week time period in which all equipment groups (An equipment " group" is a group of equipment and/or systems
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that are taken out of-service simultaneously, or may be taken out of service,
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when any element is taken out of service) are scheduled.
This 13 week schedule was repeated 4 times a year. Any maintenance (nonemergency) was
scheduled during a week along.with surveillances and repetitive tasks. This was considered a strength as equipment ~ operation was minimized. The safety related equipment out-of-service time was also minimized.
It appeared to facilitate scheduling of manpower requirements. The scheduling function
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removed essentially all job duplication. The planning function received o
requests from scheduling for work packages approximately 5 weeks before the task was scheduled.
Scheduling also notified.the warehouse of required parts.
This allowed the maintenance group to assemble-the work package with parts and
schedule manpower with a minimum amount of changes. Work waiting on delivery-of parts was found to be quite small. Meetings with scheduling, planning, L
maintenance, system engineering, and operations groups were routinely held on the subject of maintenance scheduling that had alleviated most of the routine scheduling conflicts.
The Work Request (WR) was the' document that usually initiated a WO, there were only.a few other type of documents that may take the place of a WR. One type
.is a reviewed and acceptable design change.
The'WO was required for.almost all work at the facility, and the exceptions were called out in the procedure
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(PAP-0905) on W0s. The planner had the responsibility of writing up the WO, developing the work package (Job Traveler (JT)),.and. ordering parts.
He also coordinated with work organizations as required, incorporating Al. ARA considerations and closing the W0 and the package after they were complete.
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- The JT maintained the controls on the job work at work commenced and
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processed. _The JT also stated how the package was to be closed out. The JT itself was very tightly controlled. After the package was signed to allow work to start, any change required the JT to be returned to the planner and the package was revised to incorporate the change and sent out to be initiated once more. The inspectors reviewed 35 completed work packages to evaluate the
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E effectiveness of the controls the licensee had in place. The results showed the licensee generally maintained good centrol on the work in progress with the JT developed per the procedure.
With the exceptions noted above, maintenance work appeared to be well implemented and controlled.
3.7 Enaineerina and Technical Suonort The inspectors reviewed the activities of the engineering organizations related to the field activities of modification installation and testing, maintenance support, and material qualification.
Support was provided by the L
Nuclear Power Plant Department I&C Section and the Nuclear Engineering L
Department (NED).
3.7.1 System Enaineerino The I&CS and NED System Engineering Section (SCS) provided system engineering I
support. Not having all System Engineers (SE) within a single organization was not typical but did not appear to affect the effectiveness of support.
System engineer responsibilities were defined by I&C System Engineer Desk Guide ICS-004 and Plant Engineering Guideline PEG-004.
The SE ' ; responsible for monitoring system performance, initiating corrective actions, acting as test directors for special tests, specifying post maintenance-testing, investigating causes of deviations, and other duties associated with the usual responsibilities of a plant engineer.
The shif'. technical advisor was part of the SES and provided immediate SE response to,iant operating problems as well as_ liaison to the SE during backshift.
Trending was not an explicit
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responsibility of the SE in either 1C5-004 or PEG-004, or in PAP-0101, " Perry Operations Manual," Rev. 5.
Trending support was assigned to the NED Performance Engineering Section as discussed in Section 3.8,4.
System assignments considered the complexity and importance of the system to safe, reliable operation of the plant appropriate to the level of experience of the individual.
The inspectors reviewed the implementation of the system engineer function through observation of SE interaction with selected systems and the quality of technical staff responses to issues raised during the inspection.
Most
' engineers understood their duties and exhibited technical knowledge consistent with prior ~ plant experience and length of system assignment.
System engineers were encouraged to participate in industry group committees formed to solve generic problems.
For example, one SE had served as Vice Chairman of the BWR Owners Group on Rosemount transmitter failures. Another had organized a BWR Class 5/6 meeting on problems with recirculation flow' control valves.
The inspectors concluded that the licensee had implemented the concept of
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performing in a manner compatible with safe and reliable plant operation.
3.7.2 Nuclear Enaineerina Department NED was a completely on-site organization reporting to the site vice president.
The engineering group provided support in the areas of plant modification and problem solution outside the capabilities of the SE.
The inspect us observed that NED generally provided correct and timely responses to plant problems and concluded that support was consistent with safe and reliable plant operation.
However a weakness was identified in incorporating design changes in response to needed lifted leads and jumpers (LLJ).
Thr number and duration of LLJs was considered excessive.
As of
September 1, 1990, 154 LLJs were installed.
Twenty seven were over two years old.
LLJs were installed in accordance with PAP-1402, " Control of Lifted Leads, Jumpers, Temporary Electrical Devices and Mechanical Foreign Items," Rev. 7.
All LLJ installations required a technical review and 10 CFR 50.59 applicability review.
The SE normally performed the technical review and reviewed the jumper on a monthly basis.
The inspectors were concerned that a significant number of the LLJs were design changes and had not been subjected to the multi-discipline design change process which would ensure that the all systems and components would perform as designed.
It appeared that LLJs were being used to accomplish design changes because it was easier than the formal engineering design change request process.
Senior plant management issued a memorandum on August 29, 1990, clarifying the use of LLJs.
System Engineering Manager approval was required to implement a LLJ. A goal was to permit no LLJ to remain outstanding longer than one operating cycie.
An experienced senior electrical engineer was assigned to coordinate this effort and to provide senior plant management with monthly reports.
The inspectors reviewed these actions and considered them adequate in the near term.
3.8 Review of Licensee's Assessment of Maintenance 3.8.1 Audits and Surveillance _ Reports The inspector reviewed reports of five quality assurance (QA) audits and 122 surveillances performed between January 1989 and September 1990. There was a
. good mixtur cf observation of performance of maintenance activities and
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verification that the quality progcam requirements were being implemented.
Qualified and experienced auditors were utilized to conduct audits and surveillances.
The audits and surveillances identified a number of good findings and observations, s
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Action requests were issued and used to follow up on findings and
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observations. The inspector reviewed some completed and partially completed action requests.
Generally, there appeared to be a good response to findings and observations.
The inspector noted that QA did not always accept the first response and requested additional response. Also QA did not completely close an audit finding until they followed up on the implementation of the proposed corrective action. The follow up on implementation is considered to be a strength.
3.8.2 '
Maintenance Self-Assessment The inspector reviewed the report of the licensee's self-assessment of
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maintenance performed by a 13 member team from the Davis-Besse plant, Advanced Technology Engineering Incorporated, Perry Plant, and a Cleveland Electric coal fired plant.
The team members had backgrounds in maintenance, organizational development, engineering, health physics, and QA.
Seventy five action items (weaknesses)
were identified and tracked. All action items were closed as of October 1989.
3.8.3 Ouality Control Suooort-The plant quality control organization consisted of one QC manager, three supervisors, and 34 qudity control' inspectors.
In addition, 14 contractors were also employed for the outage.
Even though the QC staff had been reduced by 40% during the last two years, the current staff appeared to be adequate.
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inspectors noticed CC coverage whenever required )y a hold point or wt less point.
The ir.spectors interviewed members of the QC staff.
All appeared to be knowledgeable and had the necessary acceptance criteria with them while t
inspecting. The-inspectors also noticed a good working relationship between Maintenance and the QC staff. The witness points waived by QC, whir' were in
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the range of 1.4 to 6.6%, were not excessive. The hold points were.mt waived.
The QC procedures were adequate and were reviewed for adequacy once every 18 months.
. The inspect. rt'iiewed the position descriptions and qualification statements for the positions of the QC manager and the three supervisors in the QC area.-
The Director, Nuclear Assurance Department, stated that the QA organization had undergone a large reorganization as a result of a. management audit.
This reorganization eliminated one section.- The Nuclear Assurance Director stated
.that, as a result of these changes, the QC job descriptions needed changes.
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lie provided the resumes of the persons holding these offices and brief qualification requirements for the QC manager and the supervisors.
These appeared to be adequate.
3.8.4 Trend Analysis The inspectors evaluated the extent that maintenance histories, NPROS information, LERs, negative trends, rework. adeded time for outage, y
frequency of maintenance, and results of otagnost:c examinations were
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' analyzed for trends and root causes for modification of the PM prot s or
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design changes to preclude recurrence of equipment or component fai'
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Equipment failure analysis was initiated primarily by the Conditio(i Report (CR) in accordance with PAP-0606, " Condition Reports and Immediate Notifications," Rev. 6.
All CRs were assigned to plant staff to perform an investigation.
The responsibilities of the investigator were clearly defined.
For equipment related failures, the investigator reviewed historical records, reports, and test results to detect adverse trends and/or previous unsuccessful solutions. NED Performance Engineering Section provided failure root cause analysis expertise and access to the Reliability Information Tracking System (RITS) and the Nuclear Plant Reliability Data System.
Investigations were requirad to be completed in 30 days. CRs were assigned cause codes in four areas.
Cause trend reports were reported to senior plant management on a monthly basis.
Beginning March, 1990, the plant began issuing the RITS Most Frequent Failures 91 Report (RMFFR).
RITS was a data base which extracted component level data from the plant equipment data base and combined it with failure information from corrective and planned maintenance recorded in the plant maintenance information system. The RMFFR identified the top ten components with the highest failure frequencies.
4.0 Synopsis This synopsis highlights the inspection findings in terms that were meant to be representative of the presentation tree that is attached to this report. A (+) means that the area is good or has the potential to be so; a (-) means that the area is weak or not fully developed.
4.1 Overall Plant Performance 4.1.1 Historic Data (+) The plant was on line for 220 consecutive days from January to September 1990 which was a record for domestic BWRs in the second fuel cycle.
(+). Unplanned reactor scrams and safety system actuations were zero for 1989 and one for 1990 which was better than the established licensee goals for both-years.
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Plant availability goals were not met for 1989.
Discussions indicated (that this was due to decisions to keep the plant down to perform additional maintenance.
4.1.2 Plant Walkdowns
'(+)
Plant management emphasized possible safety significance of hardware problems in planning fcr corrective maintenance.
(-)
Plant material condition was acceptable; however, a number of defective or broken items which had not been previously identified were noted in several areas of the plant.
None of the items appeared to be safety significant.
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'(-)
Excessive liquid leaks and poor housekeeping were noted in some areas,
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especially non safety rell'3d areas (-)
Several concrete f>otings of switchyard structures had not been grouted as required by design.
(-)
Lack of painting was evident in some areas which resulted in rusting of plant components and hardware.
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4.2 Manaaement Suonort of Maintenance 4.2.1-Manaaement Commitment and involvement (+) Management addressed some repetitive component problems by using new and more reliable components.
Management provided the funding and commitment for construction of a new maintenance building.
(+) Review and 1. racking of maintenance performance was tracked and controlled by graphing of many performance indicators.
(+) Maintenance staffing allowed adequate staffing for performing required imaintenance work as well as maintaining status and performance reports and other maintenance-support activities.
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. (4) The reliability centered maintenance program provided a systematic method L
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for evaluation of components and equipment for safety significance in order to
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more effectively utilize maintenance personnel and equipment.
h ( -)
Only three systems had been evaluated and included in the reliability centered. maintenance program.
l-4.2.2 buuLqament Oraanization and Administration
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(+)' Maintenanw management used tracking of many maintenance performance
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indicators to' determine status and maintain control of maintenance work.
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Rework was tracked and reports were prepared weekly to determine if
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maintenance activities were effective.
l 4~2.3 Technical Suonort
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(+).ALARA was enhanced by the use of a surrogate tour system which consisted
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of a computerized system of plant' pictures which allowed licensee personnel to j
view pictures of equipment locations in limited access areas of the plant.
L;J (+)
Radiation exposure was-minimized by use of unit two equipment (where
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. installed) for planning of work and training of individuals.
(+) Health physics personnel were very knowledgeable of. maintenance work being performed.
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' (+) Action was taken to verify that adequate and effective corrective action
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was taken to correct audit findings prior to closing the findings.
(+)
Fire protection engineers were very knowledgeable and the fire protection plan was exceptionally good.
(-)
Personnel safety measures were not strictly enforced.
Examples included some cases of not using safety harnesses and not wearing eye and ear
protection as required.
(-)
Excessive crowding at containment access control points could result in inadequate health physics briefing.
4.3 Imclementation of Maintenance 4.3.1 WorkContm_1 (+) The work priority systrm appeared to be working well; none of the open work ordurs appeared to be safety significant.
(+) Electrical and mechanical craf'c :.,en and I&C technicians were knowledgeable and well qualified.
(+). A special designed jumper was used, when jumpers were needed, to allow verification of. jumper location prior to _ complete make up of the jumper.
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(+) Designators were used in procedures to indicate those portions which were in place is meet regulatory requirements or commitments.
(+)
Parts removed from equipment during maintenance were carefully bagged and
. identified.
l (+) A thirteen week rolling system outage schedule had been developed for mnintenance of equipment..
(-)
Plant fire pumps were not tested per requirements.
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In sevu il cases, non emergency work was started prior to preparation and issue of the approved maintenance work order.
(-) A large number of work orders were voided after initial processing.
(-) Alternate methods and controls were sometimes used to control work rather than.using the more complete and extensive normal methods and controls. This-included beginning maintenance activities prior to the normal approval and release of the work order package, excessive use of lifted leads and jumpers for long periods of time rather than using modification controls, and the excessive use of temporary change notices to change procedures rather than the normal revision process.
(-)
Inadequate planning of some work. An example is the delay in testing and disassembly of a MSIV air pack due to-lack of a wrench and a fitting.
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- (-) The failure to effectively implement the methods for identifying poor
housekeeping and defective plant equipment.
(-) A number of maintenance procedures were noted to be inadequate or poorly written.
For example fire pump test procedures did not specify required fire pump testing.
(-) Many I&C >rocedures contained a large number of temporary change notices, many of which 1ad been outstanding for several years.
(-)
In a number of cases procedures were not followed in performing
-maintenance work.
(-). Planning and preparation for the testing and disassembly of the MSIV air pack for MSIV IB21F022C were poor.
(-) Unauthorized work was performed on a MSIV air pack, which was quarantined
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for troubleshooting, prior to NRC notification.
(-) Two workers were having difficulty installing a spring pack in the valve
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operator of RHR valve IE'12F00378 without instructions or the werk order.
(-)
In some cases there was poor job planning for repetitive tasks.
For example,-in one case, necessary drawings were not included in the package prior to gotag to the field to work.
4.3.2 Plant Maintenance Oraanization (+) The size and experience of the maintenance and support staff were considered to be a strength.
)
_(+)
Maintenance utilized some aspects of predictive maintenance such as vibration analy:is and thermography to monitor equipment deterioration.
4.3.3 Maintenance Facilities. Eouioment. and Material Control (+)- A new enlarged electrical and mechanical maintenance facility had been recently completed.
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(+) An exceptionally large hot' shop wrs available inside the plant for disassembly, handling.and storage of ra.ioactive components.
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(-)
. Nonconforming fuses were mixed in a storage drawer in the warehouse with acceptable fuses.
4.3.4 Personnel Control (+) Staffing levels in maintenance and maintenance support appeared to be adequate.
Turnover in plant personnel was very low; maintenance personnel were experienced, qualified, and trained for the work performed.
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included craftsmen and supervisors.
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1(+) Mockups xf unit two equipment were used as considered necessary to train
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plant maintr.<
_ersonnel.
(-) Unqualtreed personnel were assigned to remove a MSIV air pack from the
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valve which'resulted'in the partial disassembly of the air pack prior to testing for troubleshooting.
5.0 Exit Meetina The inspectors met at the Perry Nuclear Power Plant with licensee representatives (denoted in Paragraph 1) on October 12, 1990, to sum.trize the purpose, scope, and findings of the inspection. The inspectors discussed the '
likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not-identify any such~ documents or processes as proprietary.
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APPENDIX a
ACRONYMS ALARA As low As Reasonably Achievable
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ASCO Automatic Switch Company
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B0P Balance of Plant BWR Boiling Water Reactors CM Corrective Maintenance CR Control Room CRs Condition Reports CRHVAC Control Room Heating, Ventilation, and Air Conditioning EQ Environmental Qualification HP Health Physics I&C Instrument & Control ICWP Individual Control Room Drawing-IEN NRC Information Notices IWD-Interconnection Wiring Diagrams JT'
Job Traveler t
LER Licensee Event Reports LLJ Lifted Leads and Jumpers LSC Limit Switch
MCC-Motor Control Center M&TE Measuring and Test Equipment MOV Motor Operated Valve MSIV Main Steam Isolation Valve NED Nuclear Engineering Department NFDA
' National Fire Protection As;ociation NPRDS Nuclear Plant Reliability Data System NRC.
Nuclear Regulatory Commission.
i-PAP'
Perry Administrative Procedure l'
PM.
Preventive Maintenance
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PMT Post Maintenance Testing PRA Probabilistic Risk Assessment
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QA Quality Assurance I
l QC-Quality Control RCH Reliability Centered Maintenance i
RHR'
Residual' Heat Removal
.RITS Reliability 'Information Tracking System I
RMFFR RITS Host Frequent Failures 91 Report RP Radiation. Protection RWP-Radiation Work Permit SALP.
. Systematic Assessment of Licensee Performance,
SE System Engineer SES
' System Engineering Section SVI Surveillance Instructions TCN'
' Tem)orary Change Notices WO Wor ( Order
.WR Work Request
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