IR 05000461/1989003
| ML20247A097 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/10/1989 |
| From: | Eick S, Falevits Z, Grant W, Hare S, Jablonski F, Neisler J, Tella T, Walker H, Wasenius G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247A079 | List: |
| References | |
| 50-461-89-03, 50-461-89-3, NUDOCS 8905230041 | |
| Download: ML20247A097 (43) | |
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U.S. NUCLEAR REGULATORY COMMISSIDN
REGION III
Report No. 50-461/89003 Docket No. 50-461 License No. NPF-62 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton, Illinois 61727 Inspection Conducted: January 23-26, February 27-28 and March 13 to April 7,198 Y*0.WLLI6, Inspectors: H. A. Walker 6- lo - F 9 Team Leader Date S. D. Eick
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Date Z. Falevits 6-10- 0 9 A h]g Date W. B. Grant 8'h 1
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~ juR4" S. M. Hare 5-/0 's 9
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5 st-Y9 Date 9 . h - (L T. Tella F- /#- 8 7 Date Contractors: H. S. Snowden 5 - to - M i Date h -]asenius f(bM(Gs."L l 3 .
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Approved By: F. J. Jablonski, Chief Maintenance and Outage Section ,Date 6'/0 bf j,[2$bok .b Q
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Inspection Summary
Inspection on January 23-26, February 27-28, and March 13 to April 7, 1989 (Report No. 50-461/89003(DRS))
Areas Inspected: Special announced team inspection of maintenance, 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, and 62705 to ascertain whether maintenance was effectively accomplished and assessed by the license Results: Overall, implementation of the licensee's maintenance program was determined to be satisfactory. Areas of strengths and weaknesses were identified as discussed in the Executive Summary. One violation was identified: failure to follow procedure __ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ - - _ _ - _ _ _ . _ _ _ . ____ _
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. DETAIL ,
1$0.PersonsContacted q
~Clinton Power Station-(CPS)
- C. Gertsner, Executive Vice President- '
- T. J. Camilleri, Director'of Maintenance-
'*R. E. Campbell, Manager, Quality Assurance
- R. D. Freeman, Manager, Nuclear Station Engineering Department'
- D. P. Hall, Vice President
- D. L. Holesinger, Assistant Plant Manager
- D. L. Holtzscher, Manager, Licensing and. Safety
- J.-A. Miller, Manager, Scheduling'and Outage Management'
- J. S. Perry, Assistant Vice. President
- S. E. Rasor, Project Manager, Maintenance Department
-*R. A. Schultz, Director, Planning and Programming
- J. W. W1lson, Plant Manager U.S. Nuclear Regulatory Commission
- H.- Miller, Director, Division of Reactor Safety, RIII
- P. Hiland, Senior Resident Inspector, Clinton
- F. Jablonski,' Chief, Maintenance and Outage Section, RIII
- Ring, Chief, Project-Section-3B, RIII
- Denotes those present at the exit meeting on April 7, 1989.
Other licensee personnel were contacted as a matter of routine during the inspectio .0 Introduction'to the Evaluation and Assessment of Maintenance This inspection was conducted to evaluate the extent that a maintenance program had been developed and implemented at the Clinton Power Station. Three major areas were evaluated: (1) overall plant performance as affected by maintenance; (2) management support of maintenance; and (3) maintenance implementatio The goals of this inspection were to evaluate maintenance activities to determine if maintenance was accomplished, effective, and assessed by the licensee to assure the preservation or restoration of the availability and reH ability of plant structures, systems, and components to o)erate on deman The systems and components selected for this inspection were )ased on a generic Boiling Water Reactor (BWR) Probabilistic Risk Assessment (PRA) study furnished to the team by the Reliability Applications Section of the Office of Nuclear Reactor Regulation. The systems / components selected in the electrical, mechanical, control and instrumentation areas were:
Diesel Generator (DG)
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Shutdown Service Water (SX)
Switchgear Heat Removal (VX)
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The inspectors reviewed work already accomplished, observed current plant conditions and work in progress, and evaluated the licensee's self assessment and correction of weaknesses. Major areas of interest included maintenance associated with electrical, mechanical, control and instrumention (C&I) and th'e support areas of radiological control, engineering, quality control, training, procurement, scheduling and planning, and operations. . Problems identified by the NRC inspectors were evaluated for effect on Technical Specification (TS),
operability and technical or managerial weaknes This inspection was based on the guidance provided in NRC Temporary Instruction 2515/97, " Maintenance. Inspection," and Drawing 425767-C,
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" Maintenance Inspection Tree." The drawing, which is attached to this report, was used as a visual aid during the exit meeting to depict the results of the inspectio .1 Historical Data The inspectors prepared for this inspection by review of data that described'
the Clinton Power Station operating history in terms of availability, operability, reliability, and radiation exposure. Included were Licensee Event Reports (LERs), the latest Systematic Assessment of Licensee Performance (SALP)
report, completed NRC inspection reports, and other~ industry data. Primarily, the inspectors were sensitive to technical and managerial problems that appeared to be maintenance relate The inspectors reviewed plant operations history since January 1, 1988, to assess the licensee's performance in meeting a number of established goals as well as industry averages in these areas. In most cases, established goals were better than industry averages. Results were:
Two unplanned reactor trips in 1988; the goal was zero and the industry average was One safety system actuation in 1988; the goal was zero and the industry average was Forced outage rate for 1988 was better than the 5% goal except for November and December when the rate was approximately 7%; there was no industry goal or averag Cumulative availability from November 1987 to the end of 1988 was 78.9%;
the 1989 availability goal was 73%.
Personnel radiation exposure was very close to established goals throughout 198 Although overall performance in these areas did not always meet the established goals, performance was considered good. Plant availability was exceptional considering that Clinton is a new plant and has been operating for a short period of time. These performance indicators provide evidence that maintenance was effectiv .2 Description of Maintenance Philosophy
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The inspectors reviewed site policy statements, administrative procedures, organization charts, established goals, and other documents that described programs for implementation and control of maintenance. The performance indicators described in 2.1 were reviewed as well as otners associated with plant power generatio The licensee utilized a number of specific ma'ntenance related performance indicators and goals to determine if maintenance was accomplished, including corrective maintenance backlog and late PM items. However, the licensee had not established goals for measuring the effectiveness of maintenance such as by the amount of rework, number of limiting conditions for o;.erations (l.COs), and-the number of power reductions due to equipment problem Overall, the licensee's philosophy was consistent with other licensee's in the areas of Preventive Maintenance (PM), including predictive maintenance such as vibration analysis, lube oil analysis, thermography and computerized systems for wc control and scheduling. Management emphasis and involvement was evident, especially in the PM area, where substantial problems had been identified by the NRC in 1987. Most of this. improvement was attributed to aggressive management involvement and the attitude of maintenance personne .3 Review and Evaluation of Maintenance Accomplished 2. Maintenance Backlog Assessment and Evaluation l The inspectors reviewed the amount of work accomplished compared to the amount of work scheduled. The area of interest was work that could affect operability of safety-related equipment or equipment considered important to safety, such as some balance of plant components. Maintenance work item backlogs were evaluated for safety impact of deferrals, and causes such as lack of trained / qualified personnel, lack of parts or engineering suppor The number of maintenance work requests (MWRs) currently backlogged was reviewed to determine if effective priorities were established for maintenance work, the safety impact of deferred work, and causes of excessive backlog. The backlog of both preventive and corrective maintenance was tracked by licensee maintenance personnel utilizing a computerized system. Both outage and non-outage related backlogs were tracked as well as non-outage MWRs, which were open more than three months. Backlog information was included in the " Monthly Performance Monitoring Management Report;" however, if needed, the information i could be obtained from the computer at anytime. The current backlog, as well as l
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the previous 12 month backlog was included on a graph in the monthly report so that changing trends were readily apparen .3. Corrective Maintenance Backlog j The inspectors determined that on February 28, 1989, there was 3 backlog of 789 non-outage related MWRs. This number had slowly increased since January, which was normal for an extended outage. During the last four months of plant operation, September - December 1988, a monthly average of 116 non-outage related MWRs was completed. Based on this completion rate, approximately 3 1/2 months would be required to complete the current backlo _ _ - _ _ - - - _ _ - _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .-- _ - _ _ _ - _ __ _ _ _____-_______ _ a
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L Du' ring the review of open MWRs, observation of work and other portions of the inspection, no work on equipment affecting the operability of the plant or safety systems was noted to be inappropriately delayed. The setting of-priorities for maintenance work was reviewed and appeared to be good. Although the number of non-outage related MWRs was slightly high, this was not a concern since the setting of priorities and the scheduling of work appeared to be adequately controlle Of the 789 backlogged MWRs, 116 were on hold for replacement parts. This number did not appear to be excessive since no delays in the repair of important equipment, due to a lack of parts, were noted during the inspectio No MWRs with operability impact were noted to be on hold for part .3. Preventive Maintenance Backlog The PM backlog was tracked by a computer system but was not reported in the monthly report. . Tha number of late PM items was reported in the monthly report. At the end of both January and February 1989 there were no late PM items reported. A review of past data indicated a very low number of late PM items since July of 1988. PMs that were deferred were not counted as." late,"
therefore, the inspector reviewed a portion of deferred PMs and concluded that approximately 78% were deferred within the grace period and would not have impacted the late schedule. The inspectors determined that the remaining deferred PMs did not have an impact on equipment operability. Rescheduled or deferred PMs appeared to be adequately evaluated for operational imaact and the control of PM backlog was considered to be excellent. Management p111osophy and involvement in meeting the goal of zero " late" PMs was evident and considered effectiv Only three PMs were on hold for replacement parts. Approximately 44% of the time expended on maintenance was used for PM. This was better than the industry average of 42% but did not meet the Institute of Nuclear Power Operations (INP0) goal of 60%. Some items that should have been included in the PM program were not, which is discussed further in another section of this repor . Review and Evaluation of Completed Maintenance The inspectors selected the equipment and systems identified in Section 2.0 of this report for further review. The purpose of this review was to determine if specified electrical, mechanical, and C&I maintenance on those selected systems / components was accomplished as required. This review included:
Evaluation of completed MWRs for adequacy of work instructions, use by qualified personnel, Quality Control (QC) involvement, proper description of equipment repaired, documentation of work performed, identified problems and resolution, and post maintenance testing (PMT).
Evaluation of the extent that reliability centered maintenance (RCM) was factored into the established maintenance proces * Evaluation of the extent that vendor manual recommendations, outside source information and Regulatory documents such as IE Bulletins and Notices was utilize ___-__-_--_____-_ __-___ _ - _ _ - _ _ a
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I Evaluation of the extent that maintenance histories, Nuclear Plant Reliability Data System (NPRDS) information, LERs, negative trends, rework, extended time for outage, frequency of maintenance, and results of diagnostic examinations were analyzed for trends and root-causes for modification of the PM process to preclude recurrence of equipment or component failure Evaluation of work procedures for inclusion of adequate work instructions, acceptance criteria, QC hold points and ease of us .3. Review and Evaluation of Completed Electrical Maintenance Electrical maintenance activities were generally balanced between corrective and preventive, which was based mainly on previous work history and/or vendor recommendations. The electrical maintenance philosophy addressed some aspects of RCM, including predictive maintenance such as vibration analysis, motor oil samples, and thermography to detect loose electrical termination The inspectors reviewed completed maintenance documentation for 480V motor control centers (MCCs); 480V switchgear; 4.16kV and 6.9kV switchgear and breakers; 345kV switchyard breakers; hydromotors; electrical penetrations; inverters and battery chargers. The inspectors reviewed 18 source documents to determine if recommendations specified in the vendor documents were incorporated into appropriate maintenance documents and implemented. The following problems were identifie Based on licensee records, the inspectors determined that in 1985, several plants including Clinton, experienced an excessive number of failures of 345kV switchyard type GH0 SF6 breakers, manufactured by Siemens Allis, Inc. (SAI). Although not safety-related, these breakers provide offsite electrical power required by 10 CFR 50, Appendix A, Criterion 1 ,
Licensee management requested SAI's involvement in 1985 to determine the '
root cause and recommend corrective actions to alleviate further problem In a letter dated May 22, 1985, SAI recommended implementation of a four-phase PM program and a routine maintenance inspection schedule. The recommendations included checking all breaker adjustments, monitoring performance and periodically providing feedback data to the vendor for review and evaluatio In addition, Section 320 of SAI manual K2972-001, Revision 2, recommended routine annual maintenance to assure normal equipment operatio Phase 1 of the plan was executed in 1985; however, there was no documented evidence that the other phases, and the routine maintenance, had been accomplished until March 1989 when breakers 4506 and 4510 were overhauled. The inspector determined that in 1988 problems were identified with operation of the 4502 and 4518 breakers due to excessive compressor operating time, which indicated SF6 gas leaks. Breakers 4502 and 4518 had been scheduled for inspection and maintenance during the current RF-1 outage but were deferred to June 1989. The PM inspection in March 1989 showed that several components, including numerous blast valves and moving main contacts, had failed to operate and required replacement. Also, various adjustments were made to meet vendor acceptance criteri _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . . _ _ _ - _ _
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Even though the licensee aggressively contacted the vendor for technical advice and direction, the inspector was concerned about the lack of management initiative in incorporating vendor recommended maintenance on the breakers for i
four years, which appeared to have contributed to the failed and misadjusted components noted by the licensee during the recent PM inspections.
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I In a related issue, on August 11, 1987, a SAI service bulletin identified an industry problem with 345kV trip coil circuits on LP0 type breakers. A resistor in the trip coil had failed during trip operation due to slow opening of the auxiliary contacts. SAI recommended that the trip circuit be energized and checked. Nuclear Station Engineering Department (NSED)
letter Y-87030, dated January 14, 1988, requested that the electrical maintenance department include this item in the PM schedule. A Preventive Maintenance Work Request (PMWR) was issued in March 1989 to complete this activity during the current outage but was deferred to June 1989. The inspectors determined that PM had never been performed on LP0 breaker 4522, which supplied offsite power. This breaker was only recently added to the PM schedul *
INP0 Operation and Maintenance Reminder (0&MR) No. 300 dated May 2, 1986, documented a fault on a 6.9kV auxiliary bus at another nuclear plant. The root cause of the fault appeared to be a loose bolted connection on the bus bars. As a result, INP0 recommended that vendor supplied torque values be periodically verified for bolted connections on 480V, 4.16kV, and 6.9kV bus connections and that this activity be included in the existing PM program. In April 1987, a contractor had been hired to periodically check bolted connections of 4.16kV and 6.9kV buses by use of an infrared temperature monitoring technique. Recently, the licensee used thermography to detect loose connections in the 345kV switchyard; however, the inspectors were informed that the licensee's target date for implementation of the pilot thermography program on the 4.16kV and 6.9kV components was September 1989. The inspector was concerned about the untimeliness of corrective action taken to address 0&MR 30 The inspector noted 11 hydromotor actuators, lying in the electrical shop work area which were used in safety-related Heating, Ventilating and Air Condition (HVAC) system Some MWR tags attached to the hydromotor actuators were dated 1986 and indicated tnat most had failed during operation and needed to be rebuilt and/or overhauled. Electrical maintenance personnel used parts from the failed hydromotors to repair other hydromotors even though a root cause analysis had not been performed to determine which components had failed. The licensee indicated that repaired hydromotors are tested prior to reinstallatio The inspectors also observed seven hydromotor pump assemblies in the electrical shop work area. Three of the seven hydromotors did not have material tags and the licensee could not determine their condition. In addition, the inspectors noted that other electrical components such as a molded case circuit breaker, a limit switch, and an amplifier did not have material tags, which are normally used for material control and traceability. Procedure 1500.02, " Control of Material," Revision 4, required that, as of January 25, 1989, utilization of used parts be authorized by an individual at the Director level or above. At the conclusion of this inspection the licensee informed the inspectors that all untagged parts had been removed from the electrical shop area, and the
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t hydromotors/ pump assemblies would be rebuilt or sent to the vendor for overhaul by the end of April 1989. The inspector determined that approximately 200 type 95 hydromotors are installed at Clinton. Two spares were available in the
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warehouse and 11 needed to be rebuilt. Supervision was weak in the area of l controlling the utilization of used parts and craftsmen were not disciplined in closely following procedural requirements. This issue is further discussed in other sections of this repor The inspectors reviewed the component failure history for the electrical components and systems selected in Section 2.0. The review disclosed that numerous MWRs had been issued because of equipment problems with hydromotor actuators. The most significant failures. appeared to be excessive cycling, improper operation due to shaft misalignment, miscalibration of the pressure differential switch and leaking hydraulic oil. Field observation and a review of MWR 002669, dated December 8, 1988, indicated that the hydromotor for Division 1 switchgear HVAC unit 1SX025A had been running continuously for an :
extended period of time. The inspector determined that it had been running t continuously for two years. Further review indicated that in 1986 and 1987 l MWRs had been issued to address the same problems. The MWRs were closed i because the licensee concluded that the hydromotor was designed to run continuously. However, based on this review, the inspectors concluded that the I motor should not run continuously and that the real root cause of this problem l had not been identified. This subject is discussed further in Section 2.3.3 of j this repor ;
The inspectors reviewed 28 completed MWRs and noted that most of the MWRs were prioritized as' Level 3. Level 3 was defined as those activities which, if unaccomplished, could degrade plant cperation by reducing availability. Most of the MWRs were completed in a timely manner. QC involvement, such as ,
required Hold and Witness points, was evident on most of the MWRs; PMT !
requirements were not always specified. For example, the shift supervisor would only initial and date the testing requirement block which made it ,
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difficult to determine what tests, if any, were performed.. MWR and PM work instructions appeared to be detailed and comprehensive; however, the format used for PM and CM WRs was very cumbersome and many spaces were not complete The following maintenance procedures were reviewe Clinton Power Station (CPS) Administrative Procedure No. 1014.05, " Preparation of Post Mainter.ance Testing," Revision CPS Administrative Procedure No. 1508.02, " Control of Materials," Revision CPS Maintenance Procedure No. 8410.02, "480 Volt Power Circuit Breaker, Generic Procedure for," Revision CPS Maintenance Procedure No. 8452.01, "Hydromotor Actuator Maintenance,"
Revision CPS Maintenance Procedure No. 8452.02, "Hydromotor Removal Installation, Adjustment, Calibration, and Preventive Maintenance," Revision CPS Procedure No. 8564.03, " Switchyard Breaker Maintenance," Revision _ _ _ _ _ _ _ - - - _ - - __
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CPS NSED Procedure R.0, " Equipment Failure Maintenance Work Request Trending and Evaluation," Revision Most procedures provided detailed step by step instructions for corrective maintenance activities and included checklists, precautions, prerequisites, QC hold points, warnings / cautions, required tests and equipment, references, vendor bulletin recommendations, and lessons learned. Generally procedures were easy to use. _No concerns were identifie The inspectors selected various safety-related and Balance of Plant (B0P)
l electrical components for review to ascertain whether the components were included in the PM program and whether the required PMs had been accomplishe No concerns were identified other than the 345kV breakers as discussed in this report. There were no electrical PMs outside the grace period and deferred PMs had adequate justification. There was a backlog of electrical MWRs; however, the MWRs did not have an impact on operabilit Based on the review of completed WRs, backlog, work history, maintenance procedures, and the licensee's actions on source documents, the inspectors concluded that electrical maintenance had been satisfactorily accomplishe .3. Review and Evaluation of Completed Mechanical Maintenance The inspectors determined that the mechanical maintenance philosophy did include some aspects of RCM. An RCM analysis was completed for the entire Reactor Recirculation system in December 1988, which included the hydraulic control units (HCU). Results of the analysis included an addition of five PM tasks and provided the basis for deviating from the vendor manua In February 1988, the licensee established a motor-operated valve (MOV)
Reliability and Improvement progrr neluding performance of diagnostic tests in the form of the Motor Operated n ive Analysis and Testing System (MOVATS).
All classes of MOVs were tested to establish base line data to detect future valve degradation. In addition, primary responsibility for MOV work was assigned to the electrical department, and an MOV committee was establishe The committee had a manager and members from engineering, electrical maintenance, and operations, and was supported by quality assurance, planning, and training. The committee was responsible for effective coordination of all MOV activities including program development, proper assessment and corrective action for field problems and industry concern The inspectors reviewed the following completed mechanical work packages associated with the following MWR B 11970 - Recirculation pump seal repair C 35329 - RHR pump seal cooler control valve leak C 37384 - Hydraulic power pump C 37550 - Shutdown service water pump shaft packing leak C 43778 - Switchgear heat removal fan coupling failure
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C 48547 - RHR heat exchanger bypass valve repair C 50973 - Diesel generator air start piping rework D'02603.- Station service water system isolation valve repair D 02999 - Diesel generator governor work
'D 05075 - Hydraulic power unit repair
, D 05242 - Diesel generator heat exchanger relief valve repair
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i .In general, the work-was correctly prioritized and completed in a timely l manner. QC involvement was evident and post maintenance tests were conducted
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as appropriate. Release for work and work instructions were adequate.
l- However, the licensee demonstrated questionable technical and supervisory support of maintenance practices in some areas. For. example:
A number of completed MWRs documented the completion of tasks by use of .
used. parts. For example, the mechanic working on MWR D05075 used the old 0-rings to reassemble a hydraulic power unit. Another example was that the mechanic assigned to complete MWR C037384 questioned supervision about which 0-ring to use and was told to . . . " draw from stores the ones that were close to the same." The mechanic also questioned the work steps of the procedure, which deleted the need for a coupling alignment check after replacing the hydraulic power unit pump with a new unit. Subsequently, the licensee committed to review the adequacy of the installed configuratio A Recirculation System pump motor shaft was improperly modified. In reference to MWR B 19970, the mechanic noted that a portion of the motor shaft protruded beyond the face of the coupling hub. NSED engineering directed the mechanic to remove the protrusion; however, the technical aspects to support this decision were not included in the work packag Measurements included in the work package supported the inspector's conclusion that the hub was probably cocked on the shaft, which would invalidate the engineering decision. This was considered a weak engineering decision but there was no apparent safety concer The inspectors reviewed the following maintenance procedure CPS No. 8110.02, " Maintenance of Model 3405 Gould Pumps," Revision CPS No. 8207.02, " Emergency Diesel Maintenance," Revision CPS No. 8216.11 " Main Steam Isolation Valves Maintenance," Revision CPS No. 8451.01, " Preventive Maintenance for Motor Operated Valves," Revision 1 CPS No. 8451.05, " Corrective Maintenance for Limitorque SMB-000 and SMB-00 Operators," Revision i
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CPS No. 8507.01, " Maintenance Procedure for Division I and II Diesel !
Generators," Revision 1 ]I CPS No. 9281.10, " Emergency Diesel Engine Inspection," Revision 2 In general, the procedures were detailed, and included required tools, acceptance criteria, and QC hold point !
Based on the above review, except as noted, the inspectors concluded that past ,
maintenance on mechanical components and systems was generally adequate to maintain system operabilit .3. Review and Evaluation of Completed Control and Instrument Maintenance The inspectors evaluated the extent that vendor recommendations and other ,
outside source information was utilized by the licensee's C&I maintenance staff. The components selected were Rosemont Transmitters and Pacific dampers and actuators. The inspectors reviewed the following documents:
Vendor Manual 4388, "Model 1153 Series D Alphaline Pressure Transmitters for l Nuclear Service," Revision Vendor Manual K2903-0001, " Pacific Air Projects" and butterfly damper and actuators " Operating and Maintenance Instructions." j Preventive Maintenance Work Request PEMVGM161, " Replace actuator 0-Rings every 36 months."
Maintenance Procedure CPS-8801.04, "Rosemont Services 1153 Pressure Transmitter Maintenance," Revision 3 j Rosemont 10 CFR Part 21 Notification dated February 9, 198 I The Rosemont maintenance procedure adequately addressed vendor recommendations, which included environmental qualification (EQ) requirements. The inspectors verified that the maintenance was performed and scheduled to meet all EQ l requirements as defined in the procedure and associated checklist. In addition, licensee resolution of a Part 21 notification on Rosemont transmitters was being aggressively pursued as evidenced by the extensive research and documentation already performed to resolve the issu MWR PEMVGM161 dealt with the replacement of the actuator 0-rings for valve 1VG17YB because of EQ considerations. The Pacific Air manual specified three additional PM activities for the valve / damper itself. These activities had been addressed by the licensee through the PM Task Evaluation Process as documented on PM evaluation sheets. One PM, which addressed the lubrication of the damper's bearings, had been cancelled based solely on the infrequent operation of the valve. The manufacturer's recommended lubrication interval l was based solely on radiation exposure and time. A second PM, which addressed the lubrication and cleanliness of the dampers' linkage system, was addressed by a separate PM evaluation sheet that deferred the activity to the associated actuator PM. This actuator PM, which is the subject MWR, failed to contain any data associated with the lubrication or cleanliness of the damper as implied by the PM evaluation sheet. In addition, the actuator PM had been cancelled since
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the existing Buna-N 0-rings would be replaced with Viton which have an EQ' life expectancy of 40 years. Based on these problems the evaluation appeared to be inadequate. -The third PM evaluation sheet was adequate. The licensee did not exercise' sufficient control over the evaluation of vendor recommendations with regard to PM of Pacific Air Dampers actuator The inspectors reviewed the component failure history for the systems selected-in Section 2.0 to determine whether methods had been established and implemented for detecting repetitive failures and adverse quality trends, and whether appropriate corrective action had been taken to address adverse trend The inspectors also utilized NPRDS and LERs in the review to ascertain the effectiveness of the licensee's analysis of trends and root-causes. No adverse trends were identifie The inspectors reviewed four recently completed IM MWRs. The MWRs were reviewed for proper approvals,. adequacy of work instruction, resolution.of concerns, QC involvement, quality of documentation for work history, and understanding of: post maintenance testing. Maintenance was adequately performed; the appropriate review and opproval was generally evident; concerns .
and MWR deficiencies were well tracked And resolved prior to returning equipment to service; QC involvement wrs satisfactory; work performed was well documented; and post maintenance testing was specified.
l The. inspectors reviewed the following completed surveillance procedures for inclusion of QC hold points, worker qualifications, acceptance criteria, correct measuring and test equipment (M&TE), and user friendliness:
CPS 1512.01 Calibration and Control'of M&TE, Revision 10 CPS 9431.15 RPS Logic System Functional Test
IRM Channel Calibration
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CPS 9431.14 CPS 9532.51 Drywell Channel Functional Test The inspectors reviewed Surveillance 9431.14 after noting a potential problem with a limited calibration sticker. The licensee failed to document or demonstrate compliance with a limited calibration sticker for the Mean Square Analog Test Fixture (MSATF) (E P/N 136B1815Gl) EIN SG1015 used for Surveillance 9431.14, IRM Calibration, as discussed in Section 2.4.2. Personnel failed to record the use of the MSATF in two of six other work packages and surveillance revealed no other discrepancies involving the use of limited calibration sticker The inspector reviewed LERs for the previous two years. The incorrect use of impact matrices and lead lifting procedures contributed to several events. To evaluate the use of impact matrices and lead lifting procedures, completed MWRs, including 39 MWRs from the DG, SX, and SW systems, were reviewe Impact matrices and lead lifting forms were appropriately ir.corporated, and no problems were note The MWRs reviewed contained adequate acceptance criteria, and QC hold point The workers were also listed as qualified on the qualification matrix. M&TE
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accuracy requirements were delineated in the procedures. The completed. remarks
. sections were generally outstanding and clearly documented the work performe Based on the review of completed MWRs, backlog and work history of PRA selected .
components, maintenance procedures, and the licensee's actions on source I documents, the inspectors concluded that the completed C&I maintenance.had been' .) '
accomplished in a satisfactory manne . Engineering and Technical Support zThe inspectors evaluated the extent-to which engineering principles and evaluations were integrated into the maintenance process. This was accomplished by review of maintenance work orders, activities associated with failure analyses, trending and other maintenance activities to evaluate the effectiveness of engineering support. Areas reviewed were engineering support to PM, material qualifications, compliance with codes and regulations, system engineering concepts,. industry initiatives, and PM Maintenance was supported by NSED, QA, Scheduling and Outage management, Nuclear Planning and Support, Clinton Power Station Technical, Operations and Radiation Protection staffs.
l Procedure No. A.4, " Nuclear Station Engineering Department Organization,"~
Revision 3, delineated the major functions of NSED engineering, which consisted of five groups, three of which were directly involved with maintenance suppor These groups appeared to be properly functioning and were generally supportive l of maintenance.
, The Design and Analysis engineering group was supportive of the maintenance effort; however, one instance of inadequate updating of Control Rod Drive (CRD) vendor manuals was identified by the inspector *
The " System Engineer" concept was recently implemented. Each system engineer was assigned specific plant systems and some system engineers handled several systems, depending on the safety significance and workload. The system engineers developed a ' System Note Book' for each system; however, not all books had been completed. The format for the notebooks was standardized and the notebook development was proceduralized. When completed, these books will contain all relevant system information. The inspector determined through discussions with systems engineers, maintenance, and other personnel, and review of engineering documents that the system engineer concept was not currently
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functioning well. In many cases, system engineers were not knowledgeable of the status and function of assigned systems. For example, the system engineer for the CRD was not always informed and aware of problems in the CRD system. The system engineer did not know the reason for replacing only 10 of the 15 CRDs recommended for replacement during this outag The inspector noted that the CRD timing test results and other CRD problems were maintained by the station nuclear group but were not transmitted to the CRD system enginee In add' tion, the inspectors discussed the hydromotor problem issues with the VX system engineer. The system engineer was not aware of the planner's request in MWR D02669 for his involvement in resolving a repetitive hydromotor problem,
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nor was the system engineer aware of several other MWRs open since 1986. The inspector also determined that the VX system engineer was not involved in root cause analysis. This lack of involvement limited the engineer's knowledge of the real problems associated with the VX syste The inspectors concluded that system engineers' involvement was weak in the MWR process, root cause analysis, field system and component walkdowns, and interaction with planners, maintenance and operations personnel. In addition, system engineers did not receive all completed MWRs for updating system records-and were not fully aware of MWR status, specifically MWRs open for an extended period of time. The lack of information flow to the system engineers was considered a weaknes The ' Reliability Engineering" concept was implemented at Clinton in early 1987. Reliability engineer duties and functional responsibilities were outlined in Policy Geidance Letter Y90257, dated December 20, 198 Each reliability project engineer was assigned responsibility for several of the following six functional areas: PM Program Improvement, Plant Performance Monitoring, Predictive Maintenance, Maintenance Trending and Analysis, Scram Frequency Reduction, and Special Studies and Support. In addition, Reliability Engineering was assigned responsibility for administering the Material Condition Management Program (MCMP), which was established by Clinton management to evaluate the material condition of the plant and to implement corrective actions where necessar Maintenance trending analysis, to identify and evaluate adverse maintenance trends and hardware related deficiencies, was performed by reliability engineers in accordance with NSED Procedure R.0. " Equipment Failure Maintenance Work Request Trending and Evaluation," Revision 3, and Procedure R.1, " Condition Report Trending and Evaluation for Hardware Related Deficiencies," Revision During the review of completed MWRs, the inspectors noted that the cause code of failure was given as 32,
" Plant Aging," whenever no root cause could be easily determined. That code was used extensively for safety-related MWRs; 312 times in the last two years. During the review of a computerized listing of MWRs for failure Code 32, dated May 3, 1989, the inspectors noted the following listed hardware failures: blown fuses; leaks (air, water steam, oil);
valve failures (open/close); valve leaks (packing, flanges, bonnets, Appendix J); drive belt failures (worn, frayed, fell off), pump failures (noise, below ca missing, eroded)pacity,
. None ofno theflow);
Failurecomponents Code 32 MWRs (broken seemed damaged, to be age clogged related. There was no formal method to assess the corrective action for these types of failures to determine the extent that the operability of other identical components could have been subjected to common mode " Plant Aging" failure. This practice was considered a weakness because trending, rework identification, and root cause analysis could be hindere The inspectors noted that the Reliability Engineering Section started vibration analysis, lube oil analysis, and recently the thermography program, to help in predictive maintenance. This was considered a strengt The inspector reviewed Potential Equipment Failure Trend Analysis Reports, dated March 20, 1987, and Ncvember 14, 1988. The 1987 report evaluated 5300 MWRs closed during the period of June 1, 1986, to December 31, 1986. The report identified 35 potential adverse equipment failure trends, which were
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assigned to NSED and Plant Staff Maintenance for followup and recommendation of corrective action. The inspector noted that one of the potential significant items was repair of hydromotors (25 MWRs). The 1988 report evaluated 3004 MWR entries closed between November 1, 1987, and July 31, 1988, and yielded 40 potential trend items of which 15 were determined to warrant further investigation and corrective action. One of the 15 items identified was
"hydromotor cycling," which was assigned to NSED-HVAC design engineering for further investigation and proposed corrective action. The inspectors determined that several failure trend analyses of excessive hydromotor actuators cycling had been performed. Engineering recommendations included replacement, introduction of a new flexible coupling, and revisions to applicable maintenance procedures to include vendor information and experience
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at other plants. Although these recommendations were implemented, the most current failure trend analysis, 89-02-11, indicated an adverse trend and that more aggressive action was required to reverse the trend. Generally, the trending program appeared to function well. However, the current nine month
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period used for trend analysis should be expanded to enable the identification of longer term trend At the request of the inspector and as required by the commitments made in the Clinton Updated Safety Analysis Report, Section 1.8, the licensee conducted a study of the PMs recommended in the Division I/II, and III diesel / generator vendor manuals. The study determined that a substantial percentage of the recommended electrical (47%) and mechanical (30%) PMs had not been included in the established PM program for the diesel generators. Subsequently, the licensee performed an engineering evaluation of the possible effects on operability if the additional PM tasks were'not completed. The licensee determined that 14 additional PMs should be completed on the Division I/II, and III diesel engines prior to startup. Examples of the 14 PM tasks were:
annual overspeed trip tests, inspection / cleaning of air start solenoid valves and air start lubricators. The inspector also noted that the air start motors had not been properly maintained as recommended by the vendor. The required maintenance on the diesel generators and on the air start motors was completed during this outag In response to a NRC concern in early 1987 that the total number of PM tasks appeared to be low, licensee management initiated a PM review program divided into two Phases. " Phase I," involved use of a contractor to evaluate existing PM " Phase II," was assigned to Reliability Engineering to review all components without existing PM The Phase I review was completed in the fall of 1987, and results were still being reviewed by Plant Maintenance and NSED for incorporation into the PM progra As of March 1989, the Phase 11 review had been completed on 8 of the 10 selected systems. The inspector examined the results of the Phase II review of the RR Syste Significant differences were noted by engineering between existing surveillance / preventive maintenance requirements and those listed in the vendor manual for the recirculating flow control valve hydraulic actuator Reliability Engineering conducted an abbreviated RCM analysis of the hydraulic system. The analysis indicated that many of the vendor recommendations were excessive but that some key tasks, that were not done, should be performe The results of the RCM analysis recommended use of predictive maintenance
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(vibration and oil analysis), changes to operator rounds sheets, trending of
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surveillance data, additional PMs to replace the critical full flow filter element, and an additional C&I and an expanded electrical PM. Functional failure modes were considered in the RCH analysis and specific PM task recommendations were listed to prevent the noted failure modes. However, the study of PM requirements for some systems did not include the PMs required in the C&I area The inspectors determined that the licensee was slow to expedite impl'ementation of the PM recommendations that resulted from the Phase I and II efforts. It appeared that a more effective corrective action by NSED was needed to reverse the noted adverse trends. For example, trend reports in the last two years identified generic problems with hydromotors. Reliability engineering trend analysis 88-09-12, dated October 19, 1988, identified that seven MURs were issued to repair hydromotors. Trend analysis report 89-02-11, dated March 10, 1989, identified that 21 MWRs had been written to repair hydromotor Investigation of 88-09-12 was assigned to NSED-HVAC design engineering to be completed by March 30, 1989; however, as of this inspection, the investigation had not been accomplishe Quality Engineering and Verification directly interacted with Maintenanc The inspector reviewed completed MWRs and observed work in progres Quality Engineering personnel reviewed MWRs, Condition Reports and Maintenance Procedures. Quality Engineering prepared monthly performance summary reports for management. These reports provided valuable information on different maintenance related parameter The Quality Verification group provided inspection services as needed. Plant QC inspectors were supplemented by contract inspectors during the outage. On shift coverage was provided when needed. Based on observations, the inspector concluded that quality verification coverage for maintenance activities was very goo Based on a review of completed MWRs, observation of work and discussions with several plant personnel, the inspectors concluded that the engineering / technical support to maintenance at Clinton was generally adequate, except in some areas of systems engineerin . Work Control The inspectors reviewed several maintenance activities to evaluate the effectiveness of the maintenance work control process to assure that plant safety, operability, and reliability were maintained. Areas evaluated were control of maintenance work orders, equipment maintenance records, job planning, prioritization and scheduling of work, control of maintenance backlog, maintenance procedures, post maintenance testing, completed documentation, and review of work in progres Maintenance Planners report to the Director of Plant Maintenance via the Supervisor - Maintenance Planing. Responsibilities included screening of maintenance requests, preparation of work packages, process of revisions for MWRs, and closecut of MWRs. Several maintenance activities were selected and assessed by the inspector _ _ _ _ _ - - _ - _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ - - _ _ _ - _ _ - _ _ - _ _ - - _
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s Work instructions were developed and appropriate procedures were referenced; detailed requirements and job steps were provided in the MWR. The planners obtained the EQ status and quality class from the Master Equipment List (MEL).
l Planners also specified the parts required for the repair, determined parts availability, and ordered parts if necessary. The licensee planned'to l implement a job staging program that would allow all parts needed for an MWR to be gathered, accepted by QC if necessary, and be ready when maintenance personnel were able to start the MWR. PMT requirements were generally i specified by Operations, although planners occasionally referenced the PMT if l the original work request stated specific generic checks. The inspectors reviewed work packages which indicated a lack of specific PMT requirements. A majority of MWRs reviewed had only a general step for the shift supervisor to, ,
" EVALUATE AND DETERMINE PMT REQUIREMENTS. VERIFY NO FURTHER PMT IS REQUIRED."
Maintenance planners did not always have the specific system expertise necessary to determine required PMT. The licensee relied on the general overall knowledge of the shift supervisors in determining PMT requirements based on Technical Specifications. Engineering was not normally involved in the determination and specification of PMT requirements. The inspectors perceived this as a weakness and concluded that the post maintenance testing specified by Operations was generally an operational test rather than a specific generic test that focused on the maintenance work performe The inspectors reviewed the method used by the licensee to schedule and prioritize maintenance work. The inspectors discussed the matter with work scheduling personnel and reviewed information used in this area. MWRs were routed to a Work Coordinator who established work priorities, which indicated to both Planning and Scheduling the urgency of the work. The Work Coordinator, a Senior Reactor Operator, acted as a direct communicator between the maintenance shops and Operations. To provide better communications, for coordination purposes, the Work Coordinator held a meeting every afternoon with maintenance shop supervisors to discuss problems and possible solutions encountered during the performance of maintenance for that day and the wee The inspectors concluded that the addition of a Work Coordinator improved the communication and efficiency of maintenance activitie A 13 week rolling maintenance schedule was utilized. Each week a single division and approximately 19 systeu were taken out of service for maintenance. The 13 week rolling cycle allowed the opportunity for maintenance on all systems regardless of safety classification. It also provided an out of service routine for Operations and allowed scheduling ease of surveillanc The schedule appeared to be effective. This Clinton 13 week rolling cycle was used by other nuclear power plants as a model in effective schedulin Scheduling for the outage began approximately eight weeks in advance and was 80% resource source loaded; therefore, 20% of the manpower resources were available for urgent work. One week before the work began for the next week, Scheduling held meetings with maintenance shops and operations to adjust the schedule based on availability of components, systems, or manpower. The schedule was available on the computer one week in advance to QC and HP for inspector technician availability and scheduling purpose In 1986, the licensee had classified MWR C08120 and C14805 as priority Level 5 (can be completed only during an outage). These items were still open at the end of this inspection. MWR C08120 identified damaged disconnect cluster
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fingerssin~the 6.9kV switchgear and MWR C14805 identified requirements for
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meggering and cleaning of the 4.16 kV main bus. Although the licensee informed the_ inspectors that' deferral of the above MWRs to the next refueling outage should not affect operability-the inspectors were concerned that these activities were not included or accomplished in the recent RF- The licensee's methodology to address vendor outside source information was reviewed. Vendor service information and advisory' letters (SILs and SALs), -
INP0 Operational' Maintenance Reminders (0&MRs) and Significant Event Reports (SERs), Regulatory Bulletins, Notices and Generic Letters and other correspondence that could impact the safe operation of the CPS were included in this review. Licensing and Safety (L&S) Procedures I.1 and L.1 provided instructions and assigned responsibility for the processing and review of external industry operating experience documents pertinent to plant safet ,
The inspector reviewed the following outside source documents being addressed
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by the licensee:
INP0 0&MR 300 - Failure of 6900 Volt Bu INP0 SER 24-87 - Failure of 4kV Breakers to Transfer
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on Deman INP0 SER 33-88 - Failure of Relays Operated at greater than Rated Voltag IE IN 88-98 - Electrical Relay Degradation Caused by 0xidation (Clinton LER 88-017).
GE SIL-332 - Relay and Switch Contact Clearin GE SIL-448 - Maintenance and Lubricants for GE Type AK Circuit Breake The inspector determined that the licensee had established a systematic process; however, outside source documents were arbitrarily designated Priority 4, that is Routine - those activities which will not directly impact plant operations adversely, without a prioritization review and consideratio Also, it appeared that engineering response due dates were easily extende This practice could delay implementation of corrective action activities when require Overall scheduling and prioritization of maintenance work appeared to be acceptable and effective. Appropriate emphasis was given to those items of safety significance. The licensee's work control appeared to be adequat . Personnel Control The inspectors reviewed the licensee's control of staffing related to maintenanc Inspection activities included interviews with plant personnel, observation of training facilities, in plant observations, and review of documentatio The licensee had developed a comprehensive plan for personnel control and integrated it into the mainten6nce process. The personnel chart was available
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and up-to-date. Selected personnel at various management levels were interviewed and found to be knowledgeable of responsibilities for mechanical, electrical, and control and instrumentation. Contractor services supplemented these departments during the heavy workloads encountered during outage Personnel training records indicated that each employee, including contractor personnel, received site specific, security and radiological training before site access was granted. Refresher training was available and presented as
, needed. The licensee developed task specific training for all tasks necessary to support any particular MW The use of mock-ups in the training facility greatly enhanced students'
comprehension of Limitorque valves, MOVATS, main steam isolation valves, snubbers, reactor recirculation pump seals, split casing pumps, and terminal board lead lifting and landin The individual employees training qualification / certification tracking system was reviewed and found to have a potential for error. Upon the successful completion of a specific task training session, the employee was listed as qualified on the craft qualification / certification matrix. The supervisor, for the particular craft, then either accepted the qualification as sufficient and certified the employee or required further testing through demonstratio If the employee successfully completed this demonstration, the employee was certified. Once the employee became certified, the supervisor notified the training department and the employee's training record and the department training matrix was updateJ accordingly. However, if the supervisor neglected to inform the training department, the employee was qualified to perform a task, but not certified. Although qualified, an employee was not authorized to perform a task individually until certifie . . -
During observations of maintenance activities, the inspectors requested that the licensee verify the qualifications of two contractor electricians assigned to perform the task being observed. The review indicated that although the two individuals were certified to perform the assigned activity, their names were omitted from the current qualification and certification matri The qualification / certification tracking program was being integrated into a computer tracking system that will enhance the ability of the particular craft supervisor to maintain current data on each employee assigned to a particular craf Close coordination between the craft supervisor and the training department would have precluded the above inaccurate documentation of qualificatio The maintenance training program was recently accredited by INP0. The emphasis management placed on maintenance and maintenance training was evident by the decision to seek INP0 accreditation in maintenance before operation The Quality Engineering and Quality Verification staffs appeared to be adequate. Some contractor inspectors were used during the outage. The plant staff were able to cover the swing and night shift maintenance tasks when required. The staff appeared to be knowledgeable and qualifie .4 Observation of Current Plant Conditions and Ongoing Work Activities
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2. Observation of Material Condition The inspectors performed walk-downs of the selected systems to assess the l general and specific material condition of the plant to verify that MWRs had been initiated for identified equipment problems, and to evaluate housekeepin The selected systems and components were identified in Section 2.0 of this repor Walk-downs included an assessment of the components and systems for proper identification and tagging, accessibility,. fire and security door integrity, scaffolding, radiological controls and any unusual condition. Unusual conditions included but were not limited to water oil and other liquid leaks; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lighting. However, since CPS was in a refuel outage at the time of the inspection, many of the systems were not subject to normal operating conditions. Therefore, the inspectors could not fully assess the material condition. Results follow:
The inspectors observed a lack of general valve maintenanc Indication of excessive steam leakage was observed from Reactor Feed Pump (RFP) 1B Suction Strainer Instrument Root Valve 100020B. The lagging on the valve was destroyed. Stains on the lagging indicated a steam plume of 10 f The scheduled work start date for 10B020B under MWR C43976 was the following refueling outage. Licensee data indicated 60 steam leaks in the CB, DC, FW, and MS systems at the start of the refueling outage. Fifty percent of these leaks were repaired during RF-1. Seven of the remaining open MWRs (C53850, D01313, D02629, C54056, C57004, C58142, C43976) for steam leak repair indicated leaks which were, " steady stream,"
"significant," " excessive" or steam plumes form six inches to five fee These leaks could affect electrical and electronic equipment, contribute to inaccurate gauge readings, and increase plant airborne radiation and contamination levels. Licensee data at the end of the inspection indicated that three of the noted leaks were repaired awaiting for PMT or engineering review, two were being worked, and one was waiting for part The inspectors noticed that several alignment jacking bolts were tightened against the frame of equipment subject to heat growth. The heat growth of equipment, against the tight jacking bolts, could cause expansion in a direction other than that designed. The licensee took corrective action and backed off the jacking bolts from the equipment frame. This resolved the problem. A Commitment Tracking Form (CCT 50466) was initiated to revise CPS 8170.02 to include a statement that, " Jacking Bolts should be backed off upon completion of alignment." This change will be included in the task specific lesson pla The inspectors noted several instances of water and oil leaks that were not identified by a deficiency tag. Maintenance work was done on a valve near the service water strainer in the intake structure, but no maintenance tag was hung near the disconnected power cables. Tag C53637 was hung later during the inspectio The inspectors noted that the cabinet doors to the Hydraulic Power Unit in the Turbine Building were open. There was spilled oil, nuts, bolts, and miste11aneous small items lying on the floor within the dike around the skid;
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.there was oil with tools lying in it. There were two new untagged filters, and Procedure CPS 3105.05, which was outdated lying in a parts tub. A~ review of the MWR showed this work had been stopped on several occasions because of higher priority work and was left in an uncontrolled condition for a period of
, 10 days. Proper interface between Operations and Maintenance could have l prevented the long delay between the start of this job and its completio *
Housekeeping and material condition appeared to be substandard in some area Hand tools were lying around in the Emergency Diesel Generator Rooms, and intake structur The tools did not require calibratio Hard hats and five blue material control tags were noticed on the floor in the SX pump room in the intake structure. The material control tags were for spare parts used for maintenance activities in that are *
Leaking equipment or valves and considerable water was observed on the floor in the intake structure near service water strainers. Also, a MWR tag was not eviden *
A pool of water was observed on the floor near the auxiliary boiler, which '
was subsequently mopped u A non-radioactive water spill was noted on the 707' elevation floor near the RHR Pump 1A room in the auxiliary buildin Oil leakage was observed from the lube oil lines of all three Emergency Diesel-Generators. No deficiency tag was evident in response to the oil leak on the Division III Diesel-Generator. A MWR tag was subsequently attache The inspectors observed weaknesses with the identification of components associated with the 125 Vdc battery and the RHR systems. The 125 Vdc Div. III battery charger, RHR Pump 1A and its associated motor were not identified. These discrepancies were brought to the licensee's attentio Based on other observations throughout the plant it appeared that these problems were isolated to these two systems. After bringing these problems to the licensee's attention, the licensee took actions to identify the battery charger; however, at the conclusion of the inspection, the RHR components remained unidentified as required by Sargent and Lundy specification No. K2999. The inspectors were concerned about future maintenance and/or operability problems. This is considered to be an example of a violation of 10 CFR 50, Appendix B, Criterion V (461/89003-01F(DRS))
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The data were obliterated on the chart paper of portable radiation cam recorder 1RR-PR029, located inside the containmen *
MWR C45232, dated January 29, 1988, requested that the float potentiometer on battery charger be cleaned. The inspectors determined that the actual number should have been MWR C45732 and that more effective system walkdowns would have identified this deficienc _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ . - _
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The inspectors observed that nitrogen pressure was not being maintained on electrical penetrations. This pressurization feature provided for penetration leak detection during leak rate tests. Pressurization of the penetration was not a condition for equipment qualification, nor was pressurization an assumption used in the containment analysis. The Clinton Updated Safety Analysis Report (USAR), Section 6.2.6.2, " Containment Penetration Leak Rate Test," Subsection d, states: " Electrical penetrations are provided with a permanently installed leakage surveillance system. Included are provisions for pressurization between the double 0-rings which seal the closure plate and the weld-neck flange which is welded to the containment (penetration) nozzle. Each electrical penetration is also provided with a pressure switch which monitors the test pressure and initiates an alarm on low pressure to signify leakage." Never is it stated that the leakage surveillance system would be permanently pressurized, only permanently installed. During a subsequent telephone conversation on April 19, 1989, between the licensee and NRC personnel, a licensee representative stated that the USAR was incorrect in that each electrical penetration does not have a pressure switch that initiates an alarm on low pressure to signify leakage. The licensee has not submitted a change to the USAR; however, there is no affect on safety or Tech Spec operabilit Discussions with licensee personnel and review of available documentation indicated that nitrogen seal pressure had not been maintained on the penetrations since late 1986 or early 1987. Nonconforming Material Report (NCMR) No. 2-1010 identified brass fittings on stainless steel tubing on December 5, 1986. Based on telephone conversations with a manufacturer's representative, and Field Problem Report (FPR) No. 201408 dated February 25, 1987, the licensee opted to not maintain pressure on the penetration seals. The engineering disposition for FPR No. 201408 states, "There is no requirement in the FSAR or Technical Specification to maintain pressure in the penetrations during plant operations." The licensee performed a 10 CFR 50.59 safety evaluation on January 9, 1987 to justify the deferment of the replacement of brass fittings on stainless steel nitrogen supply tubing until the first refueling outag In conclusion, except as noted, equipment problems identified by the inspector during plant and system walkdowns had been identified by the licensee's MWR process or were otherwise corrected. Overall, the material condition was considered satisfactory to maintain operability of components at a level commensurate with the component's functio . Observation of Ongoing Work Activities The inspectors observed maintenance work in the electrical, mechanical, and control and instrumentation areas. The " Daily Activity Schedule" and the "RF-1 Outage Discipline Worklist" were reviewed to assist in the selection of work for observation. Selection also involved daily coordination with maintenance management and supervision and a review of work assignments in the individual maintenance shops. Where possible, safety significant activities on components or equipment on the selected systems were chosen for observation and revie Work activities were assessed in the following areas: administrative approval prior to start of work, equipment properly tagged, adequate work instructions included, approved and current procedures available and properly implemented, work accomplished by experienced and knowledgeable personnel, replacement parts
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correc,t and acceptable, quality control coverage or involvement as necessary, appropriate post maintenance testing included and conducted, work package steps followed and appropriately signe .4. Electrical Maintenance The inspectors observed portions of the folicwing electrical maintenance '
activities: !
MWR C08793 - Add three new instrument *
MWR C40317 - Install Remote Shutdown switc!-
MWR C40318 - Replace cable tray cover '
MWR C55635 - Verify torque on inverter Silicon Control Rectifier (SCR).
- MWR C56314 - Install Conax Electrical Connector Seal Assembly (ECSA) on !
solenoid valv :
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MWR D02668 - Inverter loss of synes lamp li *
MWR D05382 - Replace bearings on stator cooling water pump moto PEMSY053 - PM of 345kV breaker No. 450 l
PEMSYM054 - PM of 345kV breaker No. 451 *
PMWR PEMAPM6547 - Clean and inspect feeder breake ;
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Concerns were identified during the observations of the following activities:
The inspectors .> served that hydraulic fluid from the oaerating mechanisms in the cabinets on 345kV breakers 4506 and 4510 was lea <ing onto cables in the bottom of the cabinets. Loose bolts and/or dirt were observed at-breakers 4502, 4518, and 4522. The operator's weekly surveillance, as directed by procedure CPS 3800.02C003, did not require the operator to '
inspect the breaker cabinets interiors for leaks, dirt, or debris. In addition, the work packages for MWRs D02668, PEMSY053 and PEMSYM054 contained outdated maintenance procedures as follows: -
D02668 package contained mocedure CPS 8801.16 stamped as " valid thru 12/23/88."
PEMSYO53 work package contains t ' maintenance procedures stamped as " valid thru 12/14/88."
PEMSYO54 work package contained six maintenance procedures stamped as " valid thru 12/14/88."
There was no objective evidence that reviews had been performed by the maintenance supervisor as required by procedure CPS 1029.01 " Preparation and ,
Routing of Maintenance Work Requests," Revision 23, to ascertain tb- correct ! __________ _ __ _ _____-__ _ _ _ -
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revision, nor had the procedures been reverified after 14 days as required by procedure CPS NP&S 2.51 " Document Control Procedure," Revision Failure to follow procedures is considered to be an example of violation of Criterion V of 10 CFR 50, Appendix B (461/89003-01A(DRS)).
During observation of work performed per MWR C56314 the inspectors noted that the Stone and Webster Engineering Corporation (SWEC) electrician did
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not appear to be adequately trained with the cable splicing technique and was continuously counseled by the QC inspecto *
While observing PM activities on B0P 480V switchgear breaker OVQO2CC, the inspector noted that both the electrician who removed the leads and the second electrician who double verified the determination of the electrical leads signed Form 8801.16F001 even though the "As Found" and "As Left" documented terminations were not the same. The work was performed using procedure CPS 8410.02, Section 8.9.3.2, which required that the lifted leads be under constant physical control until relanded. In addition, Material Control la;1s were not used as required by CPS Procedure 1508.02, Revision *
During observation of work done per MWR C56314, the inspector noted that the craftsman obtained the wrong size splice barrel lugs for the Conax Seal Assembly splice. In addition, the posted change documents on MWR drawing E05-1200, Revision C, were not reviewed for impact on ongoing field activities. The drawing was stamp dated March 14, 1989, and since Revision C was not changed on the drawing from the time the planners issued the MWR to the field in September 1988, a review of posted change documents was not performed. The only procedural requirements available required review for latest drawings only in the MWR package. No procedural requirements were found requiring review of posted change documents to drawings issued for work. The licensee promptly issued letter JMG-89-006, dated March 27, 1989, to address this problem. The QC inspectors covering this activity also identified several deficiencies with the revision level of the MWR used, and the type of Conax Seal Assembly obtained. The QC inspectors promptly stopped the work activity and contacted engineering for assistance. The QC inspectors appeared to be prepared for the activity and knowledgeable of the requirement The inspator used the applicable schematic and connection diagrams to verify the design and field installation of VX system Temporary Modification Nos.88-081 and 89-024. The installation conformed to the applicable design drawings. No concerns were identified. The inspector noted major improvements in this area, since the licensee had had major problems with as built configurations in 198 >
The inspectors concluded that generally the performance of electrical maintenance activities was effectively accomplished by skilled maintenance personnel. The CPS personnel appeared conscientious and knowledgeable in the work performe .4. Mechanical Maintenance 25 ,
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Observation of mechanical work included a review of the work package, review of applicable procedures, discussions with personnel, materials verification, and a check of personnel qualifications. The inspectors witnessed portions of the following mechanical maintenance activities:
MWRs Bil970 and B11971 - replace pump seals for the reactor recirculation pump 1 MWR C10189 - Rework feedwater control isolation valv *
MWRs C40382, C40384, and C40385 replace safety relief valve assemblie MWR C51469 - Reinstall mechanical snubber on RHR lin MWR C57418 - Emergency Diesel (Division III) maintenanc MWR D03275 - Preventive maintenance of RCIC valv MWR D03695 - Remove stud from SRV inlet and outlet flange *
MWR D05013 - Replace expansion joint on circulating water discharge pip MWR D05168 - Diagnostic MOVATS test of feedwater valv MWR D06483 - Torque switch changeout of Containment Building valv MWR D06484 - Diagnostic M0 VATS test of Off-gas HVAC valv *
MWR D06545 - Remove and repair stuck poppet from "C" inboard MSI MWR PCIT SM005 - Inspect and replace main turbine vibration detectc The following specific observations were mad MWR B11970 for the modification of 1A RR pump seals required PMT for abnormal noise and/or abnormal leakage when the pump was started. At the time the pump was started, MWR B11970 was still open awaiting PMT and no personnel were assigned to check for abnormal noise and/or abnormal leakage. Operation of major equipment without completion of required PMT was considered a significant weakness. Failure to follow procedural instructions is considered to be an example of a violation of Criterion V l of 10 CFR 50, Appendix B (461/89003-OlB(DRS).
During the review, the inspectors also noted that Procedure CPS 8225.01,
" Reactor Recirculation Pump Seal Removal, Installation, and Maintenance,"
Revision 3, was referenced by MWR Bil971 and was included in the package; however, the current revision was Revision 4. The package had been reviewed by licensee personnel several times since Revision 4 was issued, but this discrepancy was not noted. In later discussions with the licensee, the inspectors were told that Revision 4 changes had been reviewed and had no impact on the work performed. Licensee personnel also indicated that this discrepancy posed no problem since completed packages were checked to verify that work was performed to current documents. If problems were noted, appropriate rework would be performed at that time. The inspectors considered
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the control of documents in the MWR package to be weak; furthermore, the inspectors determined that greater management attention is needed to improve control of field design documents.
l The inspectors noted that the maintenance work package for MWR D05013 l included a vendor requirement that the bolts on the retaining ring l segments be torqued to 16,000 in-lbs, which was correctly noted on the MWR as 1,333 ft-lbs. However, maintenance technicians stated the bolts were torqued to 1,250 ft-lbs. using a four inch wrench extension which would ,
achieve the required torque of 1,333 ft-lbs. The work planner for this job did not indicate in the work package the need for an extension to the torque wrench or the actual torque to be observed in the field. The licensee's team leader did not document the use of the extension tool and the actual torque value indicated on the torque wrench. Such documentation could have helped in proper planning for subsequent maintenance work on replacement of these large expansion joint The inspectors also noted that the work package included vendor manual No. K2874-001. Even though the cover page of this document indicated that the i current revision was Revision 3, the work package included Revision 1. The work planner, however, did not include a statement that Revisions 2 and 3 of this document were not applicable for the maintenance task on han Based on the above, the insaectors determined that greater management attention should be given to ensure tlat correct design documents revisions are included in the MWR packages used to perform maintenance activitie The inspectors reviewed work per MWR D06545 to remove a stuck poppet on i
"C" inboard MSIV. Since this was an unusual failure, the cause was investigated by maintenance, engineering, and management as well as a i vendor representative. The incident was determined to have been caused by excessive dry stroking of the valve. After rework and prior to testing the valve was stroked approximately five times without water or steam in the pipe. Excessive dry stroking was considered to be a contributing factor for the valve's failure. The actual binding of the poppet was caused by galling of metal believed to be part of the bottom guide ri i The guide rib was replaced by a weld build up and machined to specified toleranccs. Areas of galling on the poppet and the internal valve surface were repaired by grinding smooth and performing nondestructive testing for i surface cracks. The work that determined the cause of failure and I repaired the valve appeared to be a well coordinated effort by involved individuals. After repair, the valve operated properly and passed the required local leak rate tes l The inspectors concluded that the performance of mechanical maintenance activities was effectively accomplished by skilled maintenance personnel who 4 I
appeared conscientious and knowledgeable of the work performed. Maintenance foremen were present at the work sites observed. QC personnel involved in witnessing MOV work appeared to be very knowledgeabl )'
2.4. Review of Control and Instrument Maintenance The inspectors witnessed portions of the following control and instrumentation maintenance activities:
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MWR'!C53713- Recalibrates and refurbish Low Pressure
'Feedwater Heater Level Controller MWR D02951 Troubleshoot annuncutor panel ground fault
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. PEM VGM161 Replace actuator 0-Ring for valv CPS 8630.30 NSPS l'atested Island Calibration on Time Delay Cards I CPS 9431.14 Intermediate Range Monitor (IRM)
calibration CPS 9431.15 Test RPS Logic System Function CPS 9532.51 Test Drywell Pressure Channel Function CPS 9840.01 End of Cycle Trip for Reactor-Recirculat on Pump 1A The inspectors noted that the C&I ::ontractor personnel efficiently performed work on the level controller Work on valve 1VG17YB per'PMWR PEM VGM161, was to replace 3 year qualified life
- Actuator 0-Rings with ones qualified for 40 years. All material used for the job was documented on the WR and controlled. QC involvement was evident, all QC hold points were adhered to and the work was performed wel .
During the performance of an " Untested Islar test on cards PCISPM209, 210, 211, and 212, card PCISPM211 failed the test. The inspector verified that the test personnel correctly documented the failure and took the appropriate corrective action Surveillance 9431.14, IRM Calibration, required the use of the MSATF. This MSATF had a limited calibration sticker, which required input line voltage to be maintained at 122-124 Vac. No device was present at the work location and no method was used to monitor or maintain the line voltage within requirement The procedure did not require additional equipment to adjust or check line voltage prior to the use of the MSATF. During the inspection, on separate days, two spot-checks of line voltage in the area of the IRM cabinets indicated 119 and 120 volts. The licensee indicated that the MSATF was a unique piece of equipment specifically for IRM calibrations and all IRM calibrations had already been accomplished with the MSATF; however, the technicians performing the calibration had not maintained line voltage in the band required by the limited calibration sticker. The licensee stated that one technician had checked the voltage at the start of the procedure; however, no checks were made to ensure the voltage remained in the calibrated ban Another technician had relied on an undocumented survey which indicated that control room voltage could be assumed to be within 122-124 volts. The licensee failed to document or demonstrate compliance with the limited calibration procedure in that the MSATF was possibly used outside the range of line voltage indicated on the limited calibration sticker for the equipmen Procedure CPS 1512.01, " Calibration and Control of M-intenance and Test Equipment," Revision 10, requires that limited calibration instructions be
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I followed. Failure to follow the procedure during calibration of IRMs is considered to be an example of a violation of Criterion V of 10 CFR 50, Appendix B (461/89003-01D(DRS)).
At the conclusion of this inspection, the licensee informed the inspectors that an evaluation by General Electric (GE) of the effect of not using 122-124 volts .
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concluded that the process of calibration was conservative and that it did not affect operabilit The Reactor Protection System (RPS) Logic System Functional Test, as documented on CPS 9431.15, was performed for the first time in its present form, which ,
covered only one half of the RPS each refueling outage. Individuals performing the test were very knowledgeable of the procedure and followed the procedure well, noting procedure deficiencies and testing deficiencies as appropriat During the performance of the test, a deficiency was noted where one of the monitoring lights used in the test had burned out and the data obtained using the monitoring light came into question. The test personnel made the required notifications and reperformed all affected steps in the procedure. The inspec+ ors verified that the test personnel had correctly identified all the affectd step ,
The M&TE used for the Drywell Pressure Channel Functional Test (CPS 9532.51)
was verified to be correct, calibrated, and within the range as required for M&TE by the procedure. The inspectors verified this information back in the M&TE calibration lab and found that the Fluke used for the job had been found '
in a previous calibration to be outside of the required range and had not received a use history analysis as required. Subsequently, the licensee performed the required analysis and no other instances of this problem were note The inspectors observed Surveillance 9840.01, End of Cycle Trip for RR pump 1 Step 8.7.1 required that the RR pump oil be checked prior to operation of the pump. The test engineer requested that operations perform the required oil check. The assistant shift supervisor, based on the turnover from the previous shift, informed the test engineer that the oil had been checked; however, when the test engineer requested that the assistant shift supervisor initial for the oil check, the shift supervisor declined. The test engineer initialed the check point and the pump was started. No signature or formal documentation existed from the previous shift for the pump oil level at the time of the pump start. The procedures, however, include appropriate qualitative / quantitative acceptance criteria to determine that important activities have bee accomplished. Failure to follow recirculation Pump 1A surveillance procedure requirements is considered to be an example of a violation of Criterion V of 10 CFR 50, Appendix B (461/89003-OlC(DRS)). l l 1
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During the review of ongoing work, the inspectors witnessed the day to day interactions between the C&I Supervisor, Planner, Foreman, and the worker The supervisor in the C&I department was very knowledgeable of the details of the jobs being performed in addition to the jobs that were planned. The inspectors witnessed a monthly briefing given by the C&I Supervisor which not ;
only kept the workers well informed but also offered encouragement and camaraderie while discussing the accomplishments and problems encountered at the plan _ _ _ _ _ _ _ - _ _ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _
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2. Radiological Controls Maintenance work was observed in contamination /high radiation areas; as were movements of tools / equipment to and from these areas, and interactio"s of workers with radiological control personnel. No apparent problems were noted with health physics support of ongoing work or with As Low As Reasonably Achievable (ALARA) review of specific task Radiological controls, posting and labeling were good. From a radiological standpoint, cleanliness and housekeeping appeared generally good for the extensive outage condition Through observation of work in progress and discussion with licensee personnel, the inspector determined that radiological controls were integrated into the maintenance process as followr:
An experienced radiation protection (RP) engineer-ALARA planner provided input to maintenance plaaning to assure that good RP practices were incorporated into work practices as early as possible, measures were identified such as shielding, ventilation, contamination control, which were prerequisites to be completed prior to commencement of work, and previous work packages were reviewed to factor lessons learned into the planning proces Job history files and videotapes of selected jobs had been developed as ALARA tool Monitoring to support RWP issuance, RWP job coverage, and use of dosimetry '
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appeared goo QA audits of the Radiation Protection Program including ALARA were performed and findings were addresse *
A formal ALARA committee had been formed. An ALARA emphasis program including an ALARA improvement recommendation system had been established for workers who wish to express ALARA concern Station and work groups dose goals were establishe The inspector noted weaknesses in Maintenance / Radiological Control interface including:
Information provided to Radiation Protection in MWRs requiring an RWP was often insufficient to accurately specify protective requirements and accurately calculate a man-rem estimate for a given job. For example, a MWR/RWP request stated " valve rework" for 40 man-hours and did not specify scaffolding needs to be erected and then torn down, insulation removal and replacement and MOVAT requirements. A detailed task analysis, which is initiated by the maintenance planner and completed by the job supervisor after field walkdowns, did not accompany all MWR/RWP request . Maintenance Facilities, Material Control, and lontrol of Tools and Measuring and Test Equipment
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The inspectors reviewed the licensee's activities in the areas of facility, equipment, and material control to assess support given to the maintenanc proces Interviews were conducted with various maintenance management and craft personnel to determine the policies, goals, and objectives; and followup observations were performed to determine the extent to which the plant practices, procedures, equipment, and layout supported the maintenance proces The three maintenance groups had separate workshop area .4. Facilities The mechanical maintenance facilities appeared to be adequate except for the hot shop facility. The current space for this shop was smal The electrical maintenance facility, although small, appeared to be adequate for the activities performed at the sho The C&I shop area appeared to be adequate and supervisor's offices were located adjacent to the work area .4. Material Control The storage. facilities included three warehouses outside the protected area and one warehouse in the Unit 2 radioactive waste treatment building. Physical control of access to all four warehouses was good. Environmental controls, cleanliness and housekeeping were good in the radioactive waste treatment warehouse and in two of the warehouses outside the protected area. The third warehouse (blue warehouse) was not at the same level of cleanliness nor were environmental controls as effective as in the other warehouses. There was no segregation of safety-related and non-safety related parts; heavy boxes were stacked on boxes marked as containing delicate instruments and open boxes and bags contained electrical relays and switches which were covered with heavy coats of dirt and dust. One reason for the condition of the " blue" warehouse was that the licensee had recently converted another warehouse to office space and moved the contents of that warehouse into the " blue" warehouse. The licensee has established a program to improve the condition of the " blue" 1 warehouse. According to information provided, the implementation of the program will begin after the current refueling outag Two deficiencies were identified with the licensee's MMIS computer stores computer. The stockroom location for circuit cards used for MWR D02951, was incorrect which resulted in several hours work delay. In addition, relay driver cards were also checked and while they were in the correct location, the number of cards specified by the computer was two more than was actually in .
stock. Since the MMIS automatic spare parts ordering system initiates a l reorder when the stock level is depleted to two, the actual stock level would have depleted to zero prior to a reorde The inspector selected 16 additional parts used during the performance of maintenance work for use in evaluating the material control process. Material controls were very good; each part had been evaluated by engineering, procured from an approved supplier and was traceable from the manufacturer to the storage bin in the warehouse and to the point of installatio ..
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The establishment of shelf life for parts was conservative. The licensee used either the manufacturer's recommendation or, if not available from the manufacturer, shelf life was based on the appropriate military standard. Shelf life was controlled with tags on the item and by a weekly computer printout that alerted the warehouse section to impending shelf life expiration {
The Clean Tool Room (CTR) was clean and organized. Checkout procedures were followed in the CTR. Lifting gear was in compliance with ANSI B30.9-197 Of 20 electrical items spot-checked, three were not in compliance with CPS Safety Standard 19. Two of 10 electrical items being returned from use in the plant to the CTR were at least 87 days overdue for electrical safety check The Hot Tool Room (HTR) was disorganize Unlike the CTR, tools were not stored in clearly labeled assigned locations. The HTR was not secure and permitted free access to contaminated tool .4. Control of Tools and Measuring and Test Equipment (M&TE)
Defective, " calibration due," and calibrated instruments were segregated and the calibration room was clean and organized. No out of calibration equipment was discovered in the plant. Procedures were in place and were being used effectively for the control of M&TE. All M&TE was identified by an M&TE number with a separate label identifying the equipment with a calibration date and a date when the next calibration was due. Files were kept in the lab for each piece of M&TE which contained the calibration data for every calibration performed on the M&TE in addition to a record of every job in which that piece of M&TE had been use The M&TE calibration facility had continuous temperature and humidity recorders to ensure that these parameters were closely monitored as changes in either could affect the calibration of sensitive M&TE. No deficient M&TE calibrations were identified due to temperature or humidity change The inspectors verified calibration information in the M&TE calibration lab and found that the Fluke used for the Drywell Pressure Channel Functional Test had been found in a previous calibration as being outside of the range and had not had a use history analysis completed as required by Procedure 1512.01. As a result of this deficiency identified by the inspectors, the licensee issued Condition Report (CR) No. 1-89-03-082. The inspectors chose other M&TE used in other witnessed maintenance activities and found nu other instances where a use history was not performed. Therefore, this deficiency appeared to be an isolated inciden The calibration procedure used by the licensee for the MSATF was not in agreement with the vendor manual. The vendor manual indicated the equipment would operate from any 120 Vac standard wall outlet and did not specify a limit on line voltage of 122 - 124 Vac as the licensee required on the limited calibration sticker for the equipment. To evaluate the extent that vendor recommendations and other outside source information were utilized in equipment calibration, six M&TE items were selected for review. Vendor manuals for all the selected equipment were available in the calibration lab and the licensee's calibration procedure was found to be in agreement with all available source The calibrated M&TE appeared to be properly controlled during the maintenance wor _- _ _-___ _ _____ - _ -
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The licensee's documentation governing tool control was disorganized, particularly in the area of contaminated tools. Maintenance Standing Order MS0-030, effective April, 1987, was the current governing document and superseded Procedure 1512.03, " Control of Tools and Maintenance," which had not been canceled even though it was no longer applicable. Additional information for tool control was noted in Procedure 1501.02, " Conduct of Maintenance."
This procedure references Procedure 1907.30, " Control of Radioactive Material;"
however, it was not in effect and had been incorporated into Procedure 1024.30,
" Radioactive Material Control." The licensee was aware of these inconsistencie The inspector determined that non contaminated tools in the CTR were not properly color coded in accordance with M50-030. Of 23 tools spot-checked in the HTR 7 were not color coded as contaminated. An improperly trained CPS employee issued a contaminated tool to an unidentified contractor without documentation. The licensee had not provided formal training on the procedures for contaminated tool control. Tool inventories were not available at the tool issue rooms. Electrical and contaminated tool control was considered unsatisfactory. Failure to follow procedure requirements for contaminated tools is considered to be an example of a violation of Criterion V of 10 CFR 50, Appendix B (461/89003-01E(DRS)).
The inspectors also noticed that several small non-calibrated hand tools were lying around in the DG room and the intake structure. The licensee's control of the issue and return of hand tools was wea .5 Licensee's Assessment of Maintenance (Quality Verification)
The inspector evaluated the licensee's quality verification of maintenance activities by review of audit records, corrective action documents, and licensee maintenance related self assessments. The documents were reviewed to assess technical adequacy, timeliness of corrective acti.n, and justification for closecut of finding . Review of QA Audits and Surveillance (Quality Verification)
During 1988, two audits and 34 surveillance were performed of maintenance activitie In addition, one audit of maintenance was being performed at the time of the inspection and another was completed in the later part of 198 The inspector reviewed the available records for the four audits and four selected surveillance. Records indicated that both the audits and surveillance involved the observation of work and eppeared to be performance based. Audits performed during the 1988 maintenance outage as well as the 1989 refueling outage failed to identify several problems found by the NRC inspectors during the current inspection. For example, verification of whether several MWR packages were current was not identified by the licensee even though checklists required that the auditor verify this requirement. Audit records indicated this verification was made but no problems were note . Review of Corr tive Action Seven findings were issued on Audits Q38 - 87 - 47, Q38 - 88 - 05, and Q38 - 88 - 19. Audit Q38 - 89 - 08 was in progress at the time of the inspection and the records were incomplete. Appropriate action had been taken
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on the seven findings and the findings were closed. Management appeared to give adequate attention to closing audit findings and verification of corrective action.
- In addition, the licensee had recently implemented a new procedure for the writing and processing of Condition Reports (CRs). The inspectors noted i several instances during the inspection where CRs were written and in each instance, they were classified and dispositioned correctly. To ensure that CRs
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are not misplaced or lost in the system, the licensee regularly issues letters
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to department heads listing those CRs that are overdue and require respons . Review of Maintenance Self Assessments During the last two years the licensee conducted several self assessments of maintenance and supporting organizations. Three assessments of maintenance and one of engineering support were performed in 1987 and 1988. The first was a two day maintenance assessment conducted in July, 1987; the second was a four day maintenance assessment conducted in November, 1987, and the third was an extensive maintenance self assessment, utilizing INP0 guidelines, conducted in November and December 198 In addition, a self assessment of engineering support, which included maintenance support, was conducted in 1988. The inspector reviewed the self assessment reports. The engineering self assessment was conducted by a contractor and did not appear to be performance based. This assessment consisted primarily of personal interviews and a review of procedures and records. The individuals interviewed were supervisory and management personnel with no working level individuals involve The INP0 self assessment appeared to be an in depth review that resulted in a significant number of findings and recommendations. These items were evaluated with appropriate dispositions and many have resulted in improved maintenanc Based on reviews of the licensee's assessment of maintenance, the inspectors concluded that maintenance was being adequately assessed. Management attention and emphasis in this area was evident as indicated by the four recent self assessments conducted ir, maintenance and supporting areas. The maintenance audits appeared to be performance oriented and included the witnessing of wor Decisions to conduct maintenance audits during planned outages was considered a strengt .6 Overall Plant Performance Related to Maintenance Overall plant performance related to maintenance appeared to be satisfactor The plant operated well during the past year with only two unplanned reactor trips. Plant availability was very good since Clinton had been in operation for only a short period of tim . Performance Indicators The inspectors reviewed the methods used by the licensee to track and use historical data such as plant performance indicators. This included unplanned reactor trips, safety systems actuations, forced outage rates, and plant availability as well as specific maintenance information such as the backlog of maintenance work requests. These performance indicators were tracked, compared to industry standards and reported monthly. Clinton performance in 1988 was
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4, considered good'for a new plant and in most. cases, was better than the industry averag '
2.6.2' Plant Walkdowns The material condition of the plant was satisfactory and no condition was noted-that would.have adverse impact on operability of the plant or equipment. The following strength was identified in this are
Housekeeping appeared to be very good in most areas.
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-The following weaknesses were also not'ed:
- " Blue" warehouse was extremely dust Water and oil leaks, and clutter were noted in some isolated area *
Equipment identification'did not appear to be adequate in a few isolated Case .7 Management Support of Maintenance Management support and involvement.in maintenance appeared to be good and commitment to improve maintenance was evidenced by significant improvements in-some area '2. Management Commitment and Involvement Management was committed to improve maintenance and management involvement in:
maintenance was evident. Continued _ involvement and strong commitment by
~ management is necessary to address weaknesses identified during the inspectio '
The following strengths were noted:
Motor operated valve preventive maintenance and testing appeared to be well implemented and controlle Preventive maintenance.in general appeared to be well. implemented and controlle *
Management had implemented a 13 week rolling schedule to assist in and expedite maintenanc *
Management recently implemented the " systems engineer" concept at Clinto !
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A significant number of the assigned systems engineers had less than adequate knowledge of the assigned system Supervision of maintenance activities and technical reviews of maintenance tasks in some areas needed improvemen l 2. Management Organization and Administration
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Management appeared to be committed.to and involved in maintenance, which resulted in_ excellent resolution of sone significant maintenance problems noted j in previous NRC inspections. In addition, management was very supportive of this inspection which resulted in excellent coordination and prompt responses to inspector questions and concern . Technical Support Technical support appeared to be mixed. Significant strengths were noted in some areas while significant weaknesses were noted in others. Strengths noted were as follows:
QC inspectors appeared to be above average in knowledge and effectivenes Interfaces between purchasing, engineering and receipt inspection for material control were goo Use of Reliability Centered Maintenance in the preventive maintenance proces
There appeared to be a good tracking system for vendor, INP0 and regulatory information such as bulletins, information notices and generic letter QA audits of maintenance were scheduled to coincide with planned plant outage The following weaknesses were also noted:
Although a review of vendor recommendations for inclusion in the PM program was completed for some systems, the licensee was slow to complete the engineering evaluatio Root cause analysis of some equipment problems was untimely or nonexisten A Probalistic Risk Assessment had not been performed for Clinto .8 Maintenance Implementation The maintenance program appeared to be adequately implemented. Specific observations noted in implementation review were as follow . Work Control Overall work control activities were satisfactory. The inspectors identified the following strengths:
The 13 week rolling maintenance schedule provided an excellent opportunity to perform both preventive and corrective maintenance with a minimum impact on operabilit I Motor operated valves were included in the preventive maintenance program and the Motor Operated Valves Electrical Test System testing program was
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l l essentially complete. Significant problems had been noted in this area in 198 No preventive maintenance maintenance work requests were overdue. A review of deferred preventive maintenance indicated the majority were deferred within the grace period. Significant problems had been noted in this area in 198 Maintenance Work Request and preventive maintenance job steps were detailed and comprehensiv In most cases, licensee maintenance planners and craftsmen appe'ared to have better than average knowledge and experienc Documentation of work performed in the Maintenance Work Requests was very detailed and descriptiv A Senior Reactor Operator work coordinator had been assigned in Operations to coordinate maintenance work and assign prioritie The following weaknesses were also identified:
Problems were evident in the use of maintenance and material control tag Maintenance Work Request and preventive maintenance forms appeared to be cumbersome and were difficult to follo Repair and use of failed components in storag Post maintenance test requirements for maintenance work were not always specified by planners. In many cases, post maintenance test requirements were added by Operations after maintenance work was complete Engineering and planning involvement was absent or insufficient in these case The Power Plant Maintenance Planning System was limited in the history of closed Maintenance Work Requests. Only those Maintenance Work Requests closed in the past year were immediately available on the syste Numerous instances of failure co follow procedures were note Vendor recommended maintenance was not accomplished in several area . Plant Maintenance Organization Performance in this area was good. Examples of strengths were as follows:
Trending appeared to be working well and a significant number of generic trends had been identifie Control of vendor manuals had been recently centralized and appeared to be goo _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - -
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' Maintenance and supervision in Control & Instrumentation appeared to be above average in work knowledge and competence.
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The following weaknesses were also noted:
Contract craftsmen in the electrical maintenance department appeared to b inadequately trained for some assigned wor The trending program only covered a nine month period for conponents an equipmen . 8. 3 - Maintenance Facilities, Equipment, and Material Centrol Performance in this area was satisfactor The following strengths were-identifie Shelf life periods and coverage for limited life material was considered to be very conservativ Interfaces between purchasing, engineering and receipt inspection for material control were very goo The following weakness was identified:
Safety-related and non safety-related material were stored in the warehouse together. Although the items were properly identified the potential for mixing materials existe .8.4- Personnel Control Personne1~at various management levels were interviewed and were knowledgeable of duties and responsibilities. The str.ffing in all maintenance areas appeared to be adequate. The mechanical and electrical departments, as well as QC, were supplemented during the outage with contractors. -The following strengths were identifie Training appeared to be good and utilized mockups when appropriat A personnel qualifications matrix had been developed and was in use to assist in the assignment of qualified personne The following weaknesses were 741so noted:
A significant number of assigned systems engineers appeared not to be knowledgeable in the assigned system Electrical contract craftsmen appeared to be inadequately trained for some assigned wor .0 Exit Meeting The inspectors met with licensee representatives (denoted in Paragraph 1) on April 7, 1989, at the Clinton Plant and summarized the purpose, scope, and findings of the inspection. The inspectors discussed the likely informational
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h content of the inspection ~ report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any
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l APPENDIX A ALARA' As Low as Reasonable' Achievable BOP: Balance of Plant-
.BWR . Boiling Water Reactor b C&I Contrcl and Instrumentation k CPS Clinton Power Station l' CR . . Condition Report
- CRD- Control Rod Drive CTR' Clean Tool Room-DG Diesel Generator ECSA Electrical Control Seal Assembly EIN Equipment Identification Number EQ Environmental Qualification FPR Field Problem Report GE General Electric HCU Hydraulic Control Unit t
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hTR Hot Tool Room-HVAC Heating Ventilation and Air Conditioning IEB IE Bulletin IEN IE Notice INP0 Institute for Nuclear Power Operations IPCo Illinc?s Power Company IRM Intermediate Range Monitor
.K ' Kil LCO Limiting Condition for Operation LE Licensee Event Report L&S Licensing and Safety MCC Motor Control Center MCMP Material Condition Management Program MEL Master Equipment List M0V Motor Operated Valve MOVATS Motor Operated Valve Analysis and Testing System MSATF Mean Square Analog Test fixture M&TE Measuring and Test Equipment MWR Maintenance Work Request NCMR Nonconforming Material Report NPRDS Nuclear Power Reliability Data System NRC Nuclear Regulatory Commission NSED Nuclear Station Engineering Department 0&MR Operation and Maintenance Reminder PM Preventive Maintenance PMT Post Maintenance Test PMWR Preventive Maintenance Work Request PPMPS Power Plant Maintenance Planning System PRA Probability Risk Assessment QA Quality Assurance QC Quality Control RCM Reliability Centered Maintenance RFl Refueling Outage No. 1 RFP Reactor Feed Pump
. RP Radiation Protection
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RPS Reactor Protection System RR Reactor Recirculation RWP Radiation Work Permit SAI Siemens, Allis, In SALP Systematic Assessment of Licensee Performance SCR Silicon Control Rectifier SER Significant Event Report SIL Service Information Letter 4
.SWEC Stone and Webster Engineering Cooperation SX Shutdown Service Water TS Techr.ical Specification USAR Updated Safety Analysis Report VX Switchgear Heat Removal WR Work Request I'
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PRESENTATION TREZ
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