IR 05000482/1986015
| ML20214L412 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/12/1986 |
| From: | Boardman J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20214L410 | List: |
| References | |
| 50-482-86-15, NUDOCS 8609100139 | |
| Download: ML20214L412 (18) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-482/86-15 License:
NPF-42 Docket:
50-482 Licensee:
Kansas Gas and Electric Company (KG&E)
P. O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At: WCGS site in Coffey County, Kansas Inspection Conducted:
June 16-20, 1986 Inspector:
sh k 7//.2,/ F4 J. R. Boardman, Reactor Inspector, Operations Ddte '
Section, Reactor Safety Branch Accompanied by:
Luther Jones, KG&G Howard Stromberg, EG&G Dean Summers, EG&G Approved:
k M see:M 7//.t/8f D. M. Hunnicutt, Chief, Operations Section, Dite '
Reactor Safety Branch Inspection Summary Inspection Conducted June 16-20, 1986 (Report 50-482/86-15)
Areas Inspected:
Routine, unannounced inspection of the licensee's maintenance activities including:
the maintenance program, maintenance program implementation, electrical maintenance, and instrumentation and control (I&C) maintenance.
Results: Within the four areas inspected, no violations or deviations were identified.
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8609100139 860825 PDR ADOCK 05000482 G
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DETAILS
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-Persons Contacted
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- G. LJ.Koest'er, Vice President, Nuclear
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- W. M. Lindsay, Supervisor, Quality Systems, KG&E
- 0. L. Maynard, Manager, Licensing, KG&E
- A. A. Freitag, Manager, NPE-WC, KG&E
- G. D. Boyer, Department Plant Manager, KG&E
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- F. T. Rhodes, Plant Manager, KG&E
- J. A. Zell, Manager, Nuclear Training, KG&E
- R. M. Grant, Director, Quality, KG&E
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- C. E. Parry, Superintendent, Quality Systems Engineer.ing, KG&E
- A. L. Payne, Supervisor, Quality Engineering, KG&E
- W. L. Mutz, Manager, Nuclear Operations Support, KG&E
- C. M. Estes, Superintendent of Operations, KG&E
- K. R. Petersen, Lead Engineer, Licensing, KG&E
- M. H. Megehee, Compliance Engineering, KG&E
- G. J. Pendergrass, Licensing Engineer, KG&E
- J. Allen, ISEG, KG&E
- C. J. Hoch, QA Tech, KG&E L. F. Breshears, Supervisor, Health Physics V. Canales, Supervisor, Planning D. L. Chapman, Filming Analysis Operator B. L. Ernst, Supervisor, Safety J. Fletcher, Maintenance Engineer T. L. Foster, Supervisor, Plant Engineering D. Goodlove, Supervisor, Mechanical A. Mah, Superintendent of Training C. McCormick, Mechanic, Class IV B. T. McKinney, Supervisor, Technical Support C. L. Nobles, Supervisor, Electrical J. Overturf, Coordinator, Maintenance Training D. Parks, Lead Technical Support Training
- G. W. Reeves, Superintendent, Quality Control
- D. Rich, Superintendent, Maintenance C. D. Royce, Quality Branch Coordinator R. D. Stump, Supervisor, Material Control
- R. W. Wallum, I&C Coordinator
- D. L. Walsh, Supervisor, Maintenance Services
W. C. Wiseman, Engineer Specialist, PM
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C. A. Wudtke, Coordinator, QC Training
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Licensee Maintenance Program Data on maintenance activities were collected in five main areas:
organization and administration; facilities and equipment; technical procedures; personnel; and work control.
a.
Executive Summary (1) Maintenance Department Work Control - The organization of the Maintenance Department stressed planning and scheduling and detailed procedures for all maintenance tasks.
The maintenance engineers prepared and updated the maintenance procedures and the planners assembled the work packages. The procedures and work packages were thorough and up-to-date, simplifying the tasks of the maintenance supervision and mechanics.
Quality Control was well organized and staffed.
Inspection hold points were specified in the work packages by quality assurance and the work was well covered by the inspectors.
The ratio of i
inspector manhours to craftsman manhours was 1:4.
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Maintenance performance indicators were used, but the main emphasis was to improve the plant as a power generating unit.
Written goals and tightly controlled budgetary goals had not been emphasized.
The maintenance supervision and management appeared very effective in maintaining interfaces with other organizations.
(2) Facilities and Equipment - The WCGS physical plant was new, and appeared well designed, with maintenance staff and planning and scheduling close to the work areas.
If contaminated storage areas and contaminated work areas develop space problems later, management was aware of and planning solutions to such potential problems.
(3) Technical Procedures - The performance of the maintenance staff in preparation of detailed procedures with signoff by the craftsmen and hold points for the inspectors appeared very effective.
There are provisions for updating the procedures when vendor information, or field experience, requires it.
The craftsmen were trained to use the procedures and to work with the inspectors.
(4) Personnel - The I&C group reported to the superintendent of technical support.
Although in a separate organization from electricians and mechanics, the I&C group had adequate
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engineering and planning support for maintenance.
The Training Group was preparing for INP0 accreditation, with a target date of July 1987.
At this time, a strong training
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~n program appeared-to exist, with an average of 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per year spent per maintenance mechanic.
In addition, the on-the-job training program for apprentices was approximately 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> per
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There was a 3 year apprentice program established for all crafts.
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b.
Inspection' Findings (1) Organization and Administration (a) General Description The maintenance organization, headed by the superintendent of maintenance, consisted of three groups of craftsman; electrical, mechanical, and building services.
The support consisted of four organizations; communications, engineering, maintenance planning, and maintenance training.
The superintendent of maintenance reports to the plant manager.
The I&C organization was a part of the Technical Support organization.
The superintendent of technical support reported to the plant manager in parallel with the superintendent of maintenance.
There are four levels of supervision-from superintendent of maintenance to the craft leadmen, with each supervisor handling from 2 to 33 individuals.
A supervisory span of 33 persons appeared excessive.
However, if leadmen in the electrical, mechanical, or building maintenance crafts are considered supervisory, each supervisor handles a maximum of eight persons.
In most cases, two mechanics or
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electricians are required for each task for safety and/or for on-the-job training.
The specific responsibilities of each level of craftsman are defined in the procedures.
i (b) Specific Observations
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Coordination between operations and maintenance and assignment of priorities were routinely handled by the Outage Committee for outage planning.
Routine priority problems were handled by line management on a daily basis, with formal meetings held early each morning.
Corrective maintenance was defined in the plant procedures.
Maintenance goals in corrective maintenance were established informally since they have been in operation such a short time.
Plant goals were formally established and status in attainment of these goals was publishe p --
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-5-Predictive'and preventive maintenance were defined in the plant procedures.
No formal written goals have been established.
Emergency maintenance (Priority One Work Request) was permitted only during the operation of the reactor and has consisted of documenting maintenance performed during plant transient conditions.
Surveillance test requirements were determined in accordance with plant procedures. Approximately 99. percent of the emergency maintenance was required _by Technical Specifications, and 1 percent could be defined as discretionary testing.
The results of surveillance testing were used to a limited extent for equipment reliability trend analysis and predictive maintenance.
As~more operating experience is gained, the results of testing can be used much more extensively for modification of the preventive maintenance and corrective maintenance procedures and the scheduled
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frequency for work items.
WCGS loaded fuel in March 1985, and started commercial operation in September 1985.
Budget and actual expenditures on the various forms of maintenance have not been monitored for a sufficient time span to identify
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Mana'gement receives a monthly summary report which was based on computer data of work status.
The maintenance effort was reviewed by the licensing group to confirm that all regulatory requirements and commitments have been met.
'The plant manager makes an average of 4 or 5 plant tours each month.
The maintenance manager makes 10 to 15 tours per month.
Each of these managers visited the control room early~each morning to monitor reactor operation and ongoing work.
Both scheduled early morning meetings with their staffs to coordinate the day's activities, and to set the necessary priorities.
There was a limited number of contractor personnel on the site, managed by the KG&E construction staff.
QC for the construction performed by contractor personnel may be handled either by the contractor or by KG&E personnel.
During normal operation, lead responsibility for maintenance planning and scheduling was with the maintenance planning supervisor, who reported to the maintenance services supervisor.
All maintenance activities, whether for outages or normal operation, were monitored by the computerized work request
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y monitoring system.
Four indicators of maintenance
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performance were monitored and reported to management in a
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monthly report.
These are:
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corrective maintenance tasks awaiting parts delivery, 2)
preventive maintenance tasks more than 30 days past due, but less than 90 days past due, 3)
preventive maintenance tasks more than 90 days past due, and 4)
a summary of all outstanding work requests.
All NUMARC maintenance performance indicators were scheduled to be tracked and used to assess the effectiveness of the maintenance effort.
However, since only 9 months of commercial operation have been accumulated, the value of each indicator and changes needed to make it more meaningful cannot be assessed at this time.
The interface between QC and maintenance was defined in the policy manuals.
On outage planning and execution and day-to-day corrective and preventive maintenance, frequent planning meetings were held to discuss problems. QC coverage was by verification point or witness point in the maintenance procedure and these points cannot be waived.
Approximately 1 manhour of inspection was spent for every 4 manhours of maintenance performed.
Approximately 68 percent of the inspectors, and some of the QC staff, had previous experience in maintenance. The present staff was 25 people; 16 inspectors, 4 receiving inspection, and the remainder management and staff.
Experience level was from 3 to 20 years, with an average of 5 years.
The QC supervisor had 10 years experience, all at Wolf Creek, which included both construction and operating time.
Quality assurance interfaces with maintenance were defined in the policy manual and consisted mainly of audits.
QA had 10 auditors, who audited both maintenance and procurement.
The plant engineering interface with other organizations was well defined in the policy manuals and there was daily liaison with the other maintenance groups. The documentary interfaces included Non-conformance Reports, Plant Modification Requests, and Engineering Evaluation Requests.
Plant engineering interfaced actively with the INP0 NPRDS program.
The last input was May 30, 1986.
Plant
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engineering felt that NPRDS information was quite valuable i
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to 'the plant, but would be more valuable if additional
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The fire protection supervisor and safety supervisor
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interfaced with maintenance as defined by the policy manual
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and a' good relationship with the superintendent of r
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maintenance had been established.
There have been no lost
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time accidents since November 13, 1982.
The health physics supervisor's interface with maintenance was defined by the policy manual.
ALARA is the governing policy in radiation exposure and was addressed at training sessions, in job briefing, and in enforcement or regulations.
Feedback from maintenance on how to lower exposure was encouraged.
Both the electrical supervisor and the mechanical supervisor stated that communication within maintenance is gocd.
A formal meeting each morning with the maintenance superintendent assured close liaison. When problems arose on the job, they usually were passed through the chain-of-command rather than from craftsman to craftsman.
Good cooperation between maintenance groups existed and was encouraged.
Ten to fifteen percent of the jobs were directly supervised by persons above the first line supervisory level, indicating interest and involvement by management.
The mechanical, electrical, and I&C supervisors, when asked how much of their work was covered by QC, agreed remarkably well with the opinion of the QC supervisor.
The responses are shown in the table below.
QC Supv Elect Mech I&C Safety-Related
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100 Maintenance Balance of Plant (80P)
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100 Related Maintenance Surveillance
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- Assumed all surveillance was on safety related equipment.
Both maintenance supervisors agreed that the two-man rule was enforced rigidly on safety-related equipment maintenance and that their interface with engineering was close and satisfactory.
Both supervisors agreed that the
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-8-same people work safety-related and 80P jobs and that craftsman qualification for safety-related work was rigidly enforced.
Both supervisors estimated that 35 to 50 percent of each working shift was spent on " standing around time"; items that cannot be categorized as direct maintenance.
The I&C groups had its own planning, scheduling, and engineering group and these were large enough to support the maintenance effort. Within the limitation of qualification on safety-related jobs, the technicians worked both safety-related and B0P jobs.
When interfaces with other groups are required, the preferred method was through supervisory levels.
(2) Facilities and Equipment (a) General Description The WCGS plant, including the warehouse, craft shops, and offices, was clean and orderly. Workshops were of sufficient size, were equipped to handle the work load, and are located near the reactor building.
Maintenance
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planning, engineering, and management offices were in the same building.
Warehouse storage appeared to be sized appropriately and was well organized and clean.
The main warehouse was approximately 300 yards from the maintenance shop and inside the restricted area.
(b) Specific Observations The areas in square feet allotted to the various maintenance areas were as follows:
Machine Shop 6680 Electrical Shop 2500 Weld Shop 1024 Hot Machine Shop 1600 Hot Tool Crib 800 Cold Tool Crib 1500 In addition, a great deal of mechanical work was done on location, or in the hot machine shop.
Contaminated tools were stored in the hot tool crit which has a full time attendant.
Contaminated Measuring and Test Equipment (M&TE) are usually decontaminated before
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-recalibration.
The size and location of the contaminated
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In the containment, noise
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level,-air temperature, level.of contamination, and shortage of lay down areas may adversely affect maintenance
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Calibration of the measurement and test equipment was accomplished at the reactor site except for calibration of load cells for snubber testing.
M&TE and all other specialized tools were issued and controlled from the tool room by a tool crib attendant.
Contaminated tools were issued from the hot tool crib by an attendant.
The refueling outages were scheduled around the availability of the containment polar crane and the turbine building crane.
Except for these two items, there were no constraints in the plant hoisting and rigging.
Both telephone and Diatronics-are used for communication between work site and other areas.
It is generally a good system, but some areas with very high noise levels, may require modification.
The areas inside the containment were especially noisy.
Predictive maintenance now uses two systems for testing; oil analysis and vibration monitoring.
Infrared testing was being field tested.
The spare parts requirements and inventory levels were originally determined by review of the technical manuals.
This was supplemented by the maintenance engineers' review of work accomplished and outage planning.
Inventory management was automated and a list of items to be ordered was generated each day.
The current number of jobs awaiting parts was 170.
Sixty-six of these were on snubbers. WCGS has a cooperative spare parts program with Calloway and is in Plant Inventory Management System (PIMS)
with Westinghouse.
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All procurement must be approved by QA and engineering.
On nonsafety-related equipment, approved suppliers lists were used where practical.
Procurement document assembly was automated, using standard phrases and a word processor.
The draft procurement documents were controlled by QE engineers and procurement engineers.
The warehouse was manned around the clock, and entrance by other than warehouse personnel was strictly controlled.
Parts, including safety-related parts, were normally issued
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Accounting, inventory, and related processes used a total of 190 computer programs to handle the 47,000 items stored.
'The warehouse had a program for removing and replacing obsolete parts, which was dependent on notification by maintenance of replaced and obsolete stock items.
This program also covered those items with a limited shelf life.
To date the Ingersol-Rand instrument air compressors, weekly battery maintenance, and modifications to the limitorque valve operators have been high maintenance items.
Equipment identification was handled by a tagging system controlled by operations.
Where maintainability is deficient, design change requests
were issued to maintenance engineers, who perform design, analysis, and cost benefit studies.
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(3) Technical' Procedures
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.(a) ' General Description
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The, development, issue, and use of maintenance procedures was well' defined in the administrative and maintenance implem'nting procedures.
The original maintenance
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e procedures were derived from Vendor Technical Information (VTI), and they were continuously updated as the
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VTI was revised or operating experience dictates change.
(b) Specific Observations
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The procedures were developed and updated primarily by maintenance engineers.
During startup, the staff of
maintenance engineers was supplemented by consultants and
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contract personnel.
At present, the maintenance engineers develop and control the procedures.
No technical writers were used, although one of the maintenance engineers performed this function on all procedures and revisions.
Document Control was responsible for collecting and issuing all VTI updates and the maintenance engineer was responsible for updating procedures.
The finished procedures consist of approximately 50 percent vendor data and 50 percent maintenance engineer input.
All procedures and revisions to procedures were verified by an independent reviewer and validated by a maintenance engineer before approval of the procedure or revision was initiated.
Six signatures were required for approval.
The
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' Plant Safety Review Committee (PSRC) reviewed all procedures and revisions to assure compliance with all Technical Specifications and regulatory requirements.
Craftsmen were required to have the procedures with them on the job, if the work request specified a procedure. They must signoff the steps as they are performed.
The latest revision to the procedure (a green copy) always accompanied the work request.
Signoff on the individual steps was on a signoff sheet developed specifically for that procedere, which became a permanent record.
Inspector signoffs on the hold points were made on an inspection plan prepared by the quality engineers and is a permanent record.
If the procedure used in the field was defective and needed revision, the craftsman had been instructed to stop work and expedite a document change before proceeding.
Each change form must be signed by the maintenance engineering group supervisor.
Six additional signatures were required to approve the revised procedure.
Most requests for procedural changes originated with the craftsmen.
(4) Personnel (a) General Description The WCGS Maintenance Group consisted of 173 people.
Thirty-six were in maintenance services and one hundred thirty-five were in maintenance support.
The maintenance support group consisted of 38 electricians, 52 mechanics, 37 building services personnel, and the superintendent of maintenance support.
The maintenance training group consisted of one mechanical instructor and one electrical instructor, who reported to the superintendent of training. One training coordinator reported to the supervisor of maintenance services.
(b) Specific Observations The I&C technicians, who were in the Technical Support organization, furnished coverage with at least two men for each shift.
One of these two I&C technicians must be a journeyman.
On day shift, there were 35, of which 10 were helpers.
Average experience level was 5 years.
No contract personnel were used during outages.
The supervisor has a masters degree in electrical engineering and 12 years nuclear experienc,
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maintenance program and maintenance history was tracked by
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' computer,
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Average experience level was
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12 years.
The supervisor had 11 years Navy experience,
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6 years construction at Wolf Creek, and 5 years of
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maintenan,ce supervision at Wolf Creek.
The staff was
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supplemented by 40 contractor staff during outages, and 16 during normal operation.
Maintenance history on a11' mechanical and electrical
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equipment was available by computer.
The electrical maintenance group had 3 people on each shift and 29 on day shift.
Average experience level was 11 years.
The supervisor had 7 years general electrician experience, 5 years nuclear construction at Wolf Creek, and 5 years maintenance experience at Wolf Creek, including 3 as an electrical supervisor.
No contractor personnel were added for outages.
Training program requirements were under development by the following training group personnel:
(1) one contract person working on accreditation, (2) one reactor area person working with the mechanical and electrical personnel, and (3) one electrical and one mechanical training instructor recruited from the crafts.
The training program requirements were being continuously reviewed and updated, with the goal of INP0 accreditation in January 1987 in the areas of I&C, electrical and mechanical.
The basic training program for all three crafts was a 3 year apprentice program.
On-the-job training was a strong part of the program (1/3 of the apprentice's work
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l time) and was recorded manually and by computer, along with the classroom training.
Written lesson plans were developed for each subject.
Each
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included objectives of the lesson, suggested teaching activities, instructor, and trainee references, evaluation methods, and standards.
The training staff were carefully selected, given continuous formal training, and critiques of classroom performance.
The effort to obtain INP0 accreditation has resulted in continuous modification to the training program, which has resulted in more site specific material being taught.
The
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a u-13-courses included specific maintenance job training, as well
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as site specific material and general subject training.
I Annually, 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of classroom training was provided to each apprentice.
On-the-job training comprised 1/3 of an apprentice's work time (600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> per year).
Onsite vendor conducted training was used extensively and aggressively, and presently comprises 35 to 40 percent of the total training effort.
Offsite vendor conducted training was used to a lesser extent.
Training classrooms at the training facility included an I&C trainer (being developed), 10-12 classrooms and a studio containing cameras, recorders, and related equipment.
Incorporation of design changes was performed as on-the-job training.
A weekly training session was held to cover procedure changes, plant status, and latest plant modifications.
(5) Work Control (a) Work control during planning and scheduling, performance of maintenance, and documentation of the results was well defined both procedurally and conceptually.
Field inspections of work in progress indicated that the administrative and detailed maintenance procedures were being followed and that the work done was documented and controlled.
(b) Specific Observations All planning and scheduling of maintenance work in the electrical and mechanical disciplines, including corrective maintenance, preventive maintenance, and surveillance testing was performed by a nine-man group under the direction of the maintenance planning supervisor.
The maintenance planning supervisor reported to the maintenance services supervisor, who reported to the superintendent of maintenance.
The I&C organization was in a separate organization which reported to the superintendent of technical support, a position parallel to the superintendent of maintenance.
No violations or deviations were identifie <<
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' Maintenance' Program Implementation The'NRC.inspectorobEainedalistofworkrequestswhichwerescheduledto
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be worked during the' inspections.
He chose the.following two work requests for a review of safety-related mechanical maintenance program implementation:
a.
Preventive maintenance on 12 limitorque valve operators, and b.
Disassembly and replacement of lubricant on a limitorque valve operator.
Preventive maintenance on the 12 limitorque valve operators consisted of lubrication with a grease gun, using Exxon Nebula EP-1, and cleaning the exterior of the valve operators.
The work request number was 51376-86, dated May 27, 1986, titled " Annual Maintenance of EFHV-23, 24, 25, 26, 37, 38, 39, 40, 41, 42, 85, and 86."
Clearance from operations, quality assurance, and health physics was obtained prior to start of work and the mechanics were briefed by their foreman on the scope of work and location of the valve operators.
Attachments to the work request were adequate to define the job.
The work was performed without incident.
The NRC inspector obtained the vendor manual on the valve operator from the maintenance library and confirmed that the proper lubricant had been used and that the vendor manual was up-to-date (latest revision was September 27, 1984).
The rework of limitorque valve operator EN-HV015 consisted of removal, disassembly, cleaning, reassembly, and reinstallation. Work was performed by reference to a detailed procedure with signoff on critical steps.
A QC inspector was present at all times and signed off steps in the inspection plan.
The work request number was 07073-86, dated May 2, 1986, titled
" Rework Limitorque Operator and Perform Scheduled Maintenance."
A list of work requests which were completed and ready for document storage was obtained by the NRC inspector.
Five completed work requests were selected from the list and furnished by the planning coordinator.
A detailed review was performed to determine if the documents complied with ADM 01-057, Revision 9, dated March 13, 1986, titled " Work Requests" and subtier procedures.
The work requests were:
01144-86, dated March 13, 1986, "B Emergency Fuel Oil Transfer Pump PJE018" 50591-86, dated March 10, 1986, " Recycle Evaporator Feed Pump PHE01B" 09253-85, dated July 12, 1985, "RCDT Recirculating Line Relief Valve HBV 7160"
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01130-86, dated March 13, 1986, "Feedwater Chemical Addition to S/GA 040-EBB-1"
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.50743-86, dated March 21,1986, Annual Maintenance of EFHV-92 and
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98 and EFPDV-20C Gate Valve"
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No violations or deviations were identified during.the reviews.
I Five completed safety-related corrective maintenance work requests-(02214-86, 08814-86, 00669-86, 91731-86, and 00446-86) and four preventive
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maintenance (FM) work requests (11372-85, 00317-85,-50947-86, and
_50708-86) were reviewed.
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v 02821-86) in process were witnessed by the NRC inspector to determine if Three corrective maintenance work requests (02429-86, 01236-86, and
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t_he craft personnel were following. instructions, if instructions were i-adequate, and if all required procedures were at the work area.-
'All work requests requiring welding and the weld procedures, weld rod
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control slips, work requests and drawings were on the job site.
Where
required,'a fire' watch was on the job' site..All welders were certified.
-Weld procedure's, weld qualifications ~and training were reviewed and found
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Quality co,ntrol-and NDE personnel certifications were reviewed and found
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' to. be: neat and orderly.
A Quality Control Certification Matrix was
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.4,,maintaiped and updated monthly.
Quality procedures, instructions, and
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. acceptance criteria were ' reviewed and found adequate.
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. The. maintenance PM and surveillance test coordinators were interviewed.
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.They stated.that overtime was authorized rather than to allow safety related pr'eventive maintenance or surveillance testing to become
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delinquent.q The NRC inspector reviewed the computer printout on PM
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backlog to verify the above. Only nine safety-related items with late
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dates were included.
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The NRC inspecto'r~ reviewed the Procedure Qualification Record (PQR) 146,
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which,was being prepared for use during the repair of a pump.
This
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I package' contained an Engineering Evaluation Request EER-85-AE-37, and a letter dated August 29, 1985, which transmitted instructions for a weld repair from a pump manufacturer.
This PQR adequately covered the identified repair.
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During the course'of this inspection, the following programs were reviewed to check compliance with applicable codes and standards.
Administrative and lower tier procedures
.l Cleanliness and housekeeping
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-16-Technical Specification change implementation
Methods and responsibilities for tag out of equipment.
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No violations' or deviations were identified in this area.
4.
Review of Maintenance Hazardous Material Storage Program A review was performed to determine how hazardous maintenance materials
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(solvents, cleaners ~ oils, etc.) were stored and controlled. The inspector identified the following:
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a.
The licensee could ~not identify specific materials stored in storage
l areas by type or' quantity.
In addition, chemicals were stored in i
storage areas without apparent consideration being given to the (
chemical properties.
b.
Unmarked containers were stored in the flammable material storage locker (Chem Monitor Concentrated Buffer Solution).
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c.
There were hazardous materials in the plant which had not been approved.
The licensee had developed an approved hazardous materials
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acceptance list.
When the plant chemist was interviewed, he stated that in the past he had
tried to get materials not on the approved materials list removed, but had not been successful.
He indicated that there were probably materials in use that had not been approved. The extent of this concern was not determined by the NRC inspector.
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d.
Material safety data sheets may not have been obtained for materials on the hazardous materials acceptance list. The licensee was requested to provide a material safety data sheet for two materials (RYDLYME and Chem Monitor Concentrated Buffer Solution). By the
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close of the inspection, the requested information had not be located i
by the licensee.
l e.
No procedure had been issued for controlling hazardous material storage and use. -The licensee indicated that Procedure ADM 01-118 was being written but had not been issued. The current controlling documents were ADM 04-030 and ADM 13-102. These two procedures were
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reviewed and found to be not applicable to all materials in use.
Hazardous maintenance material storage and control will remain an unresolved item (50-482/8615-01) pending further review by an NRC
inspector during a subsequent inspection.
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5.
Instrumentation Maintenance, Observation of Work, Work Activities, and
Review of Quality Records The NRC inspector reviewed the maintenance program in the instrument and
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control area.
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-17-Maintenance history, calibration records, qualification records, procedures, work item tracking forms, and maintenance work request forms were reviewed.
I&C supervisors and technicians were interviewed to determine their areas of responsibility, function, and qualifications.
Three completed maintenance packages were reviewed; work request (WR)
No. 02877-86, WR No. 02716-86, and WR No. 02401-86. No concerns were identified.
Two work activities, Surveillance Procedures STS IC-917, Analog Channel Operational Test Essential Service Water to Air Compressor Isolation and STS 1C-243, Analog Channel Operational Test Nuclear Instrumentation System Power Range N43 Protection Set II), were witnessed to determine if technicians were following the appropriate maintenance procedures.
The NRC inspector determined that during performance of Surveillance Procedure STS IC-243, it was necessary for the technician to adjust a test signal potentiometer to 8.350 volts D.C.
In order to make this adjustment, it was necessary for the technician to reposition a milliamp range switch.
The procedure did not address the positioning of this switch. The technicians were interviewed and they indicated that voltage would be difficult to read unless the milliamp switch was repositioned. They also indicated that all technicians performing this procedure knew of the requirement. WCGS management was interviewed and they indicated that the procedure would be revised to reflect actual procedural steps. This will remain an open item (50-482/8615-02) pending further review by an NRC inspector during a subsequent inspection.
In addition to work activities, one additional item was reviewed.
Procedure ADM 08-85, Revision 2, Step 5.1.3, indicated that the relay calibration due date could be extended at the discretion of the I&C supervisor. The concern was that the safety grade relays could also be included. Therefore, safety grade calibrations would not be performed in accordance with requirements. The I&C supervisor was interviewed. He indicated that all safety grade relays were included in the surveillance test program. By being included in this program, control of calibration due dates came under Procedures ADM 02-300, Revision 7, and ADM 08-807, Revision 3.
The controlling procedures were reviewed and appeared to be adequate to control surveillance testing due dates. Therefore, as long as safety grade relays are included in the surveillance testing program, controls appear to be adequate to prevent mandatory due dates from being
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exceeded.
6.
Electrical Maintenance Observation of Work, Work Activities and Review of Quality Record The NRC inspector inspected the maintenance program in the electrical area. Maintenance history, work item tracking forms, maintenance work requests, qualification records, document control procedures, and replacement part records were reviewed. The following functional members
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-18-of the electrical maintenance organization were interviewed to determine their areas of responsibility, function, and qualifications: electrical supervisors and technicians.
Performance of one maintenance activity was witnessed, Procedure MGE-E00P-05, " Insulation Resistance Testing," on Emergency Diesel Fuel Oil Transfer Pumps, was observed. One concern was identified during work observations. Step 5.1 provided general guidance for insulation resistance measurement instruments. The procedure did not provide adequate guidance for selecting appropriate testers, particularly in cases where cable runs between the component and measurement point are long.
Five completed maintenance packages were reviewed (WR No. 01300-86, 02288-86, 02289-86, 02325-86, and 50903-86). No concerns were identified.
One area of concern was identified during preventive maintenance verification. The concern dealt with a qualification requirement for Agastat time delay relays.
In order to maintain qualification (safety-related or EQ usage), the manufacturer required that the relays be replaced every 10 years.
This is an open item (482/8615-03), pending further review by the NRC inspector during a subsequent inspection.
7.
Licensee Trending Program The NRC inspector reviewed the licensee's program of trending and management overview. The program did not include normalization for changes in activity level, did not use upper and lower control limits, and used primarily bar graphs, in lieu of cumulative line graphs.
It was, however, a well defined program that provided significant overview of a number of important management system functions. This program merits further review by NRC and could be developed into a program that could.be useful in providing performance indicators in such management system areas as maintenance, quality assurance, and procurement.
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Unresolved Item An unresolved item is one about which more information is required to determine whether the item is acceptable or is a violation. One unresolved item is discussed in this report as indicated below:
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Paragraph Subject L
Hazardous Maintenance Storage and Control 9.
Exit Interview The inspectors met with the licensee representatives on June 20, 1986, and l
l sumarized the scope and findings of the inspection activities. The SRI attended the exit interview.
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