IR 05000483/1990017
| ML20024F863 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/14/1990 |
| From: | Burgess S, Gainty C, Gody A, Grant W, Holmes J, Mendez R, Neisler J, Tella T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024F850 | List: |
| References | |
| 50-483-90-17, NUDOCS 9012270057 | |
| Download: ML20024F863 (33) | |
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i U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No:
50-483/90017
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Docket No:
50-483 License No:
NPF-30 Licensee:
Union Electric Company Post Office Box 149 Mail Code 400 St. Louis, MO 63166 Facility Name:
Callaway Nuclear Power Plant inspection At:
Callaway Nuclear Power Plant, Steedman, M0 Inspection-Conducted:
October 22 through.26, and November 5 through 9, 1990 Inspectors:
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J. Neisler, Team Leade
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Approved By:
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S'. ~0. Burg'ess, Chief Date Maintenance and OutagesSection I
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l InJpfction Summary inspection on October 22-26 and November 5-9. 1990 (Report No. 50 483/90017).
Areas Inspected:
Special announced team inspection of maintenance; management support, technical support, fire protection, and related maintenance
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activities.
l'he inspection was performed utilizing NRC Temporary Instruction i
2515/97, the attached Maintenance Tree, and selected portions of NRC Inspecticn Procedures 62700, 62702, 62704, 62705, 64150, 64704, and 73755 to ascertain whether maintenance was effectively accomplished and assessed by the licensee.
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Based on the items inspected, the overall performance in maintenance was considered good. A synopsis of the overall implementation of the maintenance program is provided in Section 4.0 of this report.
There was one violation for failure to adequately implement a maintenance program for emergency lights.
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CONTENTS EttliaD Pace 1.0 Principal Persons Contacted................................
2.0 Licensee Action on Previous inspection Items...............
3.0 Introduction to the Evaluation and Assessment of Maintenance..............................................
3.1 Performance Data and System Selection......................
3.1.)
Historic Data................
............................. 2 3.1.2 Sy s t em S el e c t i o n........................................... 2 3.2 Description of Maintenance Philosophy...................... 2 3.3 Observation of Current Plant Conditions and Ongoing Work Activities..................................
3.3.1 Current Material Condition.................................
3.3.2 Ongoing Work Maintenance...................................
3.3.2.1 Ongoing Electrical Maintenance............................. 5 3.3.2.?
Ongoing Mechanical Activi ties.............................. 6 3.3.2.3 Ongoing Instrument and Control Maintenance................. 7 3.3.3 Rad i ol ogic al Cont rol s...................................... 8 3.3.4 Maintenance f acilities, Material Control, and Control of Tool s and Measuring Equ ipment............................ 9 3.3.4.1 Maintenance Facilities.....................................
3.3.4.2 Material, Equipment and Tool Control......................
3.3.4.3 Control and Calibration of Measuring and Test Equipment... 11 3.4 Review and Evaluation of Previous Maintenance............. 12 3.4.!
Backlog Assessment and Evaluation......................... 12 3.4.1.1 Corrective Maintenance Backlog............................
3.4.1.2 Preventive Maintenance Backlog............................ 12 3.4.2 Review and Evaluation of Completed Maintenance............13 3.4.2.1 Past El ectri cal Main tenance............................... 13 3.4.2.2 Past Mechanical Maintenance...............................
3.4.2.3 Past Instrument and Control Maintenance...................
3.4.2.4 Past Fire Protection Activities...........................
3.5 F i re Prot ect i on Cont rol s.................................. 18 3.6 Maintenance Work Control..................................
3.7 Engineering Support of Maintenance........................
3.7.1 System Engineering........................................
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3.7.2 Maintenance Engineering.................................. 22 x
3.8 Maintenance and Support Personnel Control.................
3.8.1 Training and Quali fications............................... 22 3.8.2 Contractor Contro1........................................
3.9 Review of Licensee's Assessment of Maintenance............ 23
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3.9.1 Audits and Survei11ances..................................
3.9.2 S el f A s s e s sme n t........................................... 2 3 3.9.3 Qu al i ty Cont rol Support.................................. 24 4.0 Synopsis..................................................
4.1 Overal l Pl an t Per formance................................. 2 5 4.1.1 H i s t o r i c al D a t a.......................................... 2 5 4.1.2 Pl a n t W a 1 kd own s.......................................... 2 5 4.2 Management Support of Maintenance.........................
4.2.1 Management Commitment and Involvement
................... 25 4.2.2 Management Organization and Administration................ 25 4.2.3 Tech n i c al Su ppo r t........................................ 2 5 4.3 Implementation o f Maintenance............................. 26 4.3.1 Work Contro1..............................................
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4'3.2 Pl ant Maintenance Organization............................ 26
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4.3.3 Maintenance f acilities, Equipment and Material Control.... 26 4.3.4 Personnel Control.........................................
5.0 Exit Meeting..............................................
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Appendix A: Acronyms
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DETAllj 1.0 Principal Persons Contact _qd Union Electr.fc Company
- D.
f. Schnell, Senior Vice President - Nuclear
- G. N. Belchik, Assistant Superintendent, Maintenance
- J. D. Blosser, Manager, Callaway Plant
- H. D. Bono, Supervising Engineer Quality Assurance
- J. J. Cassmeyer, Quality Assurance Engineer
- G. J. Czeschin, Superintendent, Planning and Scheduling
- J. F. Hogg, Superintendent Maintenance
- G. L. Randolph, General Manager - Nuclear Operations
- T. L. Shaw, Quality Control Supervisor
- T. W. Stotlar, Supervising Engineer Quality Assurance M.S. Nuclear Renulatory Commission (NRC)
- B. L. Bartlett, Senior Resident inspector C. H. Brown, Resident inspector
- D. R. Calhoun, Project inspector
- M. A. Ring, Chief. Engineering Branch
- Denotes those persons attending exit interview on November 20, 1990.
Othcr persons were contacted as a matter of course during the inspection.
2.0 Licensee Action on Previous insp1ction items 2.1 LClosed) Unresolved item 483/88016-01 Inadequate or missing post-maintenance testing indicated on work requests (WRs).
Licensee action to address this issue was described in a letter, UOMP 88-227, dated November 7, 1988.
Post-maintenance testing requirements were specified in procedure PDP-ZZ-000ll, " Retest Development," Revision 0.
A noted strength in the procedure was guidance provided for post-maintenance testing applicable to maintenance repairs.
The maintenance inspection team reviewed completed and ongoing WRs and ascertained that appropriate post-maintenance testing requirements were specified and, when applicable, performed. This item is closed.
3.0 Lqtroduction to the Evaluation and k,sessment of Maintenance An announced NRC team inspection of maintenance was performed during the 1990 refueling and maintenance outage at the Callaway Nuclear Plant during the period October 22 through 26 and November 5 through 9, 1990.
The inspection was performed to evaluate the extent to which a maintenance program had been developed and implemented.
Three major areas were evaluated:
(1) overall plant performance as affected by maintenance; (2) management support of maintenance; and (3) maintenance implementation.
This inspection was based on guidance provided in NRC Temporary Instruction 2515/97, " Maintenance Inspection" and Drawing 425767-C, " Maintenance Inspection Tree." The drawing, l
which is attached to this report, was used as a visual aid during the exit I
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meeting to depict the results of the inspection.
Acronyms used in this report are defined in Appendix A.
Results of this inspection were derived from data obtained by observation of current plant conditions and work in progress, by review of completed work, and by evaluation of the licensee's self-assessment of maintenance and correction of weaknesses. Major areas of interest included electrical, inechanical, instrument and control, and the support areas of radiological control, fire protection, engineering, training, procurement and operations.
Problems identified by the team were evaluated for effect on technical specification operability and technical or managerial weakness.
3.1 Performance Da_tjtand System Selection 3.1.1 Historic Data The team considered the latest Systematic Assessment of Licensee Performance l
(SALP) report and previous NRC inspection reports.
Primarily the team was sensitive to technical and managerial problems that appeared to be maintenance related.
Results of these reviews did not indicate any potential weaknesses in the maintenance area.
The team reviewed plant operations data for 1989 and available data for 1990.
The plant had a capacity factor of 83% in 1989 and 94% for the first three quarters of 1990.
forced cutage rates were 1% for 1989 and 1.5% for 1990.
The licensee's established goal for LERs was less than 15; actual LERs recorded were 14 for 1989 and 10 for 1990.
The average non-outage maintenance work request backlog was within established goals. Overdue preventive maintenance work requests averaged one percent, the goal was three percent.
The cumulative radiation dose for the last complete year on record was 282 man-rem, which was below the goal of 285 man-rem.
In addition, the licensee had met the goals set for reactor trips, engineered safety features actuation system (ESFAS) actuations, and control room annunciator / instrument inoperability.
3.1.2 System Selection The-systems and components selected for this inspection were based on the probability risk assessment (PRA) study furnished to the team by the Reliability Applications Branch of the Office of Nuclear Reactor Regulation
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information and discussions with the NRC resident inspection staff.
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systems selected were the component cooling water (CCW) system; high pressure safety injection system; control building heating, ventilation, and air l
conditioning (HVAC) system; and the 4160 volt power system.
3.2 Description of Maintenance Philosophy The inspectors reviewed plant policy statements, administrative procedures, organization charts, established goals and documents that described
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improvement programs for the maintenance process.
The licensee had a documented comprehensive maintenance plan that included milestones and completion dates for improvement programs and goals.
Discussions by the inspectors with selected managers and others indicated that those personnel were knowledgeable and aware of established performance goals.
Management also had a policy of rotating assignments, which promoted cooperation between departments, reduced departmental friction and contributed to maintenance
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effectiveness.
The team determined that the licensee's maintenance program was adequately balanced between corrective maintenance (CM) and preventive maintenance (PM).
Performance monitoring in the areas of vibration analysis, lubricating oil sampling, and pipe erosion / corrosion monitoring were well established.
A thermography program had been initiated for use in the electrical area.
The licensee's philosophy of maintenance included the principles of reliability centered maintenance (RCM). The licensee completed fault tree analyses on 35 plant systems to determine methods to improve system reliability and had implemented other " state of the art" upgrade programs such as improved motor operated valve (MOV) maintenance and testing techniques.
In the area of predictive maintenance, the I&C maintenance program was at a level commensurate with typical industry programs.
The inspectors reviewed the status of both formal and informal I&C equipment trending and predictive maintenance practices.
Formal trending per procedure 1DP-ZZ-00013, " Trending of Instrument Drift and failure," Revision 2, was not being followed; however, trending appeared to be adequate. The requirement to perform a formal evaluation of surveillance task sheets twice during an 18 month period was not performed. The last documented trending evaluation required by IDP-ZZ-00013 for the 7300 plant instrumentation system was performed in February 1989.
However other informal means were used to maintain and trend component failures.
The licensee's informal Quarterly Trending of Plant Instrumentation report was a strength in the 1&C department predictive maintenance program.
The report provided plant management with a historical channel comparison plot of specific plant parameters. A drifting channel could be easily identified, tracked and scheduled for maintenance before a predicted failure.
Other trending programs such as component level trending by system engineers and review of instrument repair program logs were considered strengths.
3.3 Observations of Current Plant Conditions and Onooina Work Activities 3.3.1 Current Material Condition The-inspectors performed walkdowns of the general plant and selected systems and components to assess housekeeping, the material condition of the plant, and to verify that WRs had been initiated for identified equipment problems.
The selected systems and components are identified in Section 3.1.2 of this report.
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Walkdowns included an assessment of structures, systems and components for proper identification and tagging, accessibility, fire and security door integrity, scaffolding, radiological controls, and any unusual conditions.
Unusual conditions included, but were not limited to, water, oil or other liquids on floor or equipment; indications of leakage through ceilings, walls or floors; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lighting. During the walkdowns, the plant was in a refueling outage and this factor was considered in the evaluation of plant material condition and housekeeping.
Results were as follows:
A water leak from a CCW pump room cooler was noted; however, the leak
had been previously identified by the licensee and a WR had been initiated.
Containment cleanliness was adequate considering the amount of work in
progress, however, an excessive number of full contaminated waste bags had been allowed to accur. alate.
MOVs appeared to be well maintained as evidenced by newly lubricated
stems and gear case grease fittings.
No weepage of grease was noted from the gear cases.
Oil leaks were observed from one (Phase A) main transformer and from the
essential service transformer.
Generally, electrical components were well preserved and maintained.
- However, bird nests were observed in the cable trays near the essential service transformer.
The licensee had long term plans to reduce the bird problems.
Several small tools, a welding mask, and goggles were scattered in a
wide area near the CCW heat exchanger "B".
No work was being performed in the area at the time.
Two ground wires on battery No. NR-13 were not properly attached and
could possibly swing and touch battery terminals during a seismic event.
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The licensee properly clamped the ground wires.
Several instances of defective or broken plant equipment that had not
been previously identified were noted during the inspection.
Examples included damaged instrument tubing, broken flexible conduit, a transformer twisted at the base, a missing valve manifold handwheel, a cooler drain pipe misaligned with a floor drain, and a missing termination box cover bolt.
The licensee initiated WRs to correct the deficiencies.
Generally, equipment problems identified by the inspectors during plant and system walkdowns had already been identified by the licensee's WR program.
The material condition of the plant was considered very good to maintain the operability of components at a level commensurate with the components'
function.
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3.3.2 Onaoina Work Activities The inspectors observed ongoing work in electrical, mechanical, and !&C maintenance areas. The inspectors selected these activities from the plan of the day (POD) listings, work assignments in individual maintenance shops, and through discussions with individual foremen. Where possible, safety significant activities were chosen for direct observation.
Maintenance activities were observed to determine if those activities were performed in accordance with required administrative and technical requirements.
Work activities were assessed in the following areas: work control and planning; management presence, involvement, and knowledge; quality control (QC) presence and involvement; health physics (HP) support and hazards; procedure availability, adequacy, use and general conformance to i1VREG/CR-1369; personnel training and qualifications; material availability, adequacy, and use; measuring and test equipment (M&TE) application and calibration; and post maintenance testing adequacy, including proper acceptance criteria.
3.3.2.1 Onacina Electrical Mainten0.DE The inspectors observed portions of eleven electrical maintenance activities as described below:
P456019 Clean, inspect, and lubricate breaker P457521 Perform maintenance of cooling tower bypass valve P477851 Check plunger interlock gap W129356 Replace main power transformer neutral bushing W130928 Clean, inspect, and lubricate GE 480V breaker W134646 Repair damaged Conax connectors W137037 Troubleshoot auxiliary feedwater (AFW) valve-RC006 W138579 Replace conduit and terminate cable W455712 Take megger readings W485370 Clean, inspect, and lubricate breaker W485371 Clean and inspect breaker in cubicle P130306 The inspectors concluded that the electrical maintenance activities in the areas inspected were good and were accomplished by skilled maintenance personnel.
The maintenance supervisors and craft were knowledgeable and adequately trained and there was close and effective coordination between organizations in completing maintenance.
QC involvement in electrical activities was considered above average. A thermography program was in place
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i that included both safety related and balance of plant -(80P) electrical components. A strength was identified with the transformer bushing replacement as discussed below:
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W129356 - The replacement of the neutral bushing on the main power transformer was initiated because recent power factor tests had
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indicated a downward trend. The inspector reviewed oil analysis tests and combustible gas analysis tests and found all predictive maintenance on the transformer to be performed adequately and on a timely basis.
The licensee's PM program for the power transformers was considered
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above average.
A concern was identified with an improper tool used to set the plunger interlock gap.
- P477851 - This WR was issued, in part, due to an improper tool (test link) used to set the 4kV breaker plunger interlock gap between the operating rod and plunger. The test link previously used was offset by approximately 3/16".- The offset caused the operating rod and 31unger distances to be incorrectly set causing the interlock clip to )end.
Eventually, the interlock clip would bend to a point where the auxiliary-contacts would not make up. This condition resulted in improper operation of the load sequencer for the diesel generator in September 1990.
The licensee stated that only three= breaker failures, one of which was also a diesel generator sequencer failure in 1987, could be-attributed to bending of the interlock clip since the plant became operational.
On November 1,1990, the vendor of the test link issued a 10 CFR 21 report notifying licensees of'the auxiliary switch failure caused _ by the use of.the wrong tool during maintenance. -The licensee's subsequent corrective action to replace all plunger interlock clips was considered to be acceptable.
3.3.2.2 Onaoina Mechanical Maintenance The inspectors observed portions of six mechanical maintenance activities as
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C483639 Replace eroded extraction steam piping L
P408587 Inspect auxiliary feed pump turbine (5 year inspection)
S455927-Perform control building pressure test W125919 Disassemble main steam safety relief valve, ABV0047 i
W136017 Repack feedwater isolation valve live-loaded packing, AEFV0042 W483280 Replace body to bonnet gasket' and inspect valve internals on main feedwater regulator valve, AEFCV0540
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The inspectors concluded that the mechanical activities in the pertinent areas
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described in Section 3.3.2 were adequate and accomplished by skilled maintenance personnel. Maintenance personnel appeared to be knowledgeable and adequately trained in the work performed.
However, concerns were identified with performing job tasks without the WR at the job site, maintenance personnel working past QC objections, and conflicting torque guidance in the work package as described below:
C483639 - This activity was performed by contractor personnel who were grinding out parts of a weld after the radiographic test (RT) revealed some indications where the weld was incomplete.
The mechanic was working by direction of the engineer in charge of the job.
The WR was not at the job site, but was in transit and arrived shortly thereafter.
- W136017 - An incorrect work package resulted in confusion and delay in the replacement of live-loaded packing in valves AEFV0042 and AEFV0039.
QC was present and the WR was at the work site; however, an incorrect valve survey sheet in the work package indicated that the live-loaded packing had an 8-series Belleville spring washer assembly while the as-found condition of the valve actually had a 6-series Belleville washer assembly.
Because of the discrepancy, the QC inspector refused to sign the inspection point that required verification of general arrangement.
The maintenance supervisor directed the mechanics to keep working with the as-found number of spring washers and torque the packing gland nuts to the torque value specified on the valve survey sheet. When the job was complete, QC again refused to sign an inspection point because the fasteners did not meet the minimum thread engagement specified in the Operations Quality Control Manual (0QCH).
The maintenance supervisor located the correct valve survey sheet (which specified the use of a 6-series washer assembly) and a request for resolution (RFR) evaluated by engineering in 1987 that found the existing thread engagement to be acceptable.
Based on this additional information, QC signed the inspection points.
- W483280 - Although work was ongoing, the WR was not at the job site when the inspectors arrived.
The WR was obtained when the inspectors asked to see the work package.
The work package contained conflicting information regarding torquing requirements.
The procedure stated that all nuts were to be torqued to 1650 +/- 75 ft-lbs, loosened one at a time, and retorqued to 1330 +/- 75 ft-lbs.
The WR instructions merely stated to torque all nuts to 1330 +/- 75 ft-lbs.
The licensee resolved the inconsistency by using the guidelines establisned in Callaway's torquing procedure. A torque of 1500 +/- 75 ft-lbs was used with concurrence of the valve manufacturer.
Failure to have WRs at the job site appeared to be pervasive in light of the fact that this condition was identified twice during this inspection and three times by the resident inspector.
3.3.2.3 Onaoina Instrument and Control Maintenance The inspectors observed portions of seven I&C maintenance activities as
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A480788A Perform continuity check, insulation megger test, and install resistance temperature detectors (RTDs) in RCS loop
"A" P454070 Calibrate seal water heat exchanger CCW outlet flow transmitter R480615B Perform RTD self heating and response time test S483103 Calibrate ESW flow to air compressor "B" S483106 Calibrate containment atmosphere radiation detector W136039 Replace elbow on instrument piping for pressurizer level instrument W485153 Replace power supply PS-3, SA036 "C"-ESFAS The inspectors concluded that the I&C maintenance activities in the pertinent areas described in Section 3.3.2 were adequate and accomplished by skilled maintenance personnel. The maintenance personnel appeared knowledgeable and adequately trained for the work performed. Concerns were identified with confusing steps in a procedure and a missing QC holdpoint as described below:
S483106 - While performing procedure ISF-GT-00R31, " Containment Atmosphere Radiation Detector Calibration," Revision 11, on component number GTRT0031, I&C technicians were confused about the expected light indication.
The I&C technicians indicated that this had happened before and that the system engineer would know how to correct the problem.
The system engineer immediately identified the problem as a lack of understanding of the RM 23 system by the 1&C technicians and explained the indications that should be expected. The inspectors concluded that the procedure should have included a description of the normal RM 23 indications expected for each step taken during the procedure.
- W485153 - While I&C technicians were performing corrective maintenance on the ESFAS SA036 "C" power supply PS-3 replacement, the inspectors noted a QC hold point missing from the work package.
The licensee's 0QCM section E.2.3 was not included in the work package to ensure solder verification by a QC inspector.
The QC inspector subsequently added this hold point.
The inspectors identified control room supervision as a strength in the area of ongoing I&C maintenance. Control room attention to current plant conditions, Technical Specification Action Statements, precautions and limitations, and general control room communication was noted to be excellent.
3.3.3 Radiolosical Controls Maintenance work was observed in containment / radiation areas, including the
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movement of tools and equipment to and from these areas.
Also observed were the interaction of workers with radiological control personnel.
No problems were noted with radiation protection support of ongoing work or with As low As Reasonably Achievable (ALARA) review of specific tasks.
Radiological controls, posting, and labeling were good.
From a radiological standpoint, cleanliness and housekeeping appeared good considering the outage conditions.
Through the observation of work in progress and discussions with licensee personnel, the inspectors verified that radiological controls were integrated into the maintenance process as follows:
An experienced radiological controls person attended the POD meetings,
reviewed maintenance work packages and engineering design work modifications that involve dose producing jobs, determined shielding requirements, conducts pre-and post-job surveys, and wrote the Radiation Work Permits (RWP).
There appeared to be sufficient lead time to perform adequate ALARA reviews.
Proposed facility changes were reviewed by a member of the ALARA staff.
Persons performing ALARA reviews and oversite appeared to implement a very effective program.
There is good management support for the program.
Communications and working relationships between station and contractor
maintenance and radiological control personnel appeared to be good.
QA audits of the radiological control program, including ALARA, were performed and findings were addressed.
Radiological surveys in support of RWP issuance, RWP job coverage, and issuance and use of dosimetry appeared to be very good.
Weaknesses in this area were also identified as follows:
Periodically, there were not enough. radiation protection technicians to
support maintenance activities, usually on the backshift.
Occasionally, radiation protection personnel were not involved in the
outage planning early enough to prevent scheduling conflicts between work planned in adjacent areas at the same time involving different degrees of radiological protection.
3.3.4 Maintenance Facilities. Material Control, and Control of Tools and Measurina Eouipment 3.3.4.1 Maintenance Facilities The maintenance shops were located in the service building separate from the power block.
The licensee had improved the maintenance facilities in April 1990.
Improvements included:
individualized work areas, a conference room, a reference room with controlled vendor manuals, and a breaker test area.
The maintenance superintendent, assistant superintendent, maintenance superv40rs, and maintenance engineers were located in a professional office environment
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adjacent to the shops.
All of the areas contained adequate space to perform necessary work.
The centralization and proximity of maintenance supervision and engineering promoted prompt resolution of emergent problems.
In the 1&C level
"A" storage and repair facilities, general equipment condition, lighting, and storage of printed circuit cards were adequate.
Also, test equipment, test leads, connectors, circuit board extenders and test stand apparatus were in calibration and in good condition.
3.3.4.2 Material. Eauipment and Tool Contrql The licensea had two large warehouses to store spare parts required for the plant.
One warehouse, outside the controlled area housed the larger equipment such as pressure vessel o-rings, reactor vessel internals and shafts.
The other warehouse was located inside the licensee controlled area and included space for receipt inspection, an area for holding parts and expired shelf life items and a level
"A" storage area, with humidity and temperature controls.
The warehouse had a specific area assigned for issuance of bar coded parts.
The label attached to each of the parts indicated safety class, description, stock code number, purchase order, receipt date, shelf life expiration date, and location in the warehouse.
The inspector verified the computer data for several items in the warehouse.
The control of materials and parts during the receipt, storage and issue was very good.
The inspector noted that even though the licensee allocated specific bins for storage of safety related parts, they were randomly mixed with non-safety related parts.
However, no problems were identified in the proper issue of safety related parts.
A lube oil storage area was located in the turbine building at the 2000'
elevation. All oil and lubrication needed to perform maintenance and operation tasks were disiensed in this area and the use was controlled by procedure MDP-ZZ-L0001., Lubrication Program," Revision 8.
Lubricants obtained from the storeroom were labeled and expiration dates were specified.
All lubricant barreis, pails, and grease guns were identified with the type of lubrication contained.
The area was orderly and appeared to be functioning effectively.
The licensee conducted extensive studies on the extension of life for limited shelf life items made of rubber, silicone, ethylene, polyester and other non-metallic items.
The licensee extended the shelf life of several items based on the Electric Power Research Institute (EPRI) audit guidelines issued in June 1990.
The shelf life items were controlled with procedure WDP-ZZ-00010
" Identification, Control, Storage, and Disposition of Shelf Life Items,"
Revision 7.
The licensee had a good facility for storage and issue of non-contaminated tools.
The inspector reviewed a few calibrated tools in the tool room.
The tools were in calibration. The tool descriptions and locations matched the ones on the computer.
The issue of tools and the work orders on which they were used were easily traced.
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a 3.3.4.3 Control and Calibration of Measurino and Test Eagloment The inspectors reviewed the control and use of measuring and test equipment (M&TE). All defective or " calibration due" instruments were stored separately from those that were in calibration and acceptable for use.
Computerized checkout schemes utilizing bar codes were used for the issue, return, and recall of all M&TE. The WR number was included in the checkout procedure so that, if a piece of test equipment was later found to be out of tolerance, a
'
printout of WRs utilizing that piece of test equipment could be generated quickly from the database to allow for evaluation.
Technicians were trained on the proper use of the instruments, however, they were inconsistent with instrument calibration status logging in the surveillance, work, and PM packages.
The inspectors verified the calibration of selected M&TE items and found no discrepancies.
Calibration status was maintained in a database utilizing the equipment identification number on the bar code discussed above.
The I&C planning and scheduling department regularly scheduled the calibration of M&TE several days before the calibration due date.
Calibrations were traceable to national standards.
The inspectors reviewed the out of tolerance reporting process for selected calibration standard equipment found to be out of tolerance.
The M&TE affected by the out of tolerance standard was identified and a database search was performed to identify WRs which utilized the out of calibration M&TE.
The licensee performed an adequate engineering evaluation to resolve the out of tolerance report.
The inspector observed the calibration of a magnehelic gage.
The technician performed the calibration with the wall mounted standard incline manometer.
While performing the calibration, the technician noted that the calibration standard was providing inconsistent results.
An as-found calibration check was performed on the standard and found it to be out _of calibration. An out of tolerance report was issued immediately and root cause analysis was performed. The licensee repaired and calibrated the standard incline manometer. All actions taken to resolve the potential out of tolerance condition of M&TE calibrated with the standard incline manometer were adequate.
One instance was noted, in the mechanical M&TE shop, where a calibration
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sticker indicated that a pressure test gauge calibration was overdue by
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approximately one month.
The gauge's use history indicated that the gauge was last used before the calibration due date.
Before issuance, the gauge would be logged in a computer along with the user's name and WR number.
In trying to issue this gauge, a warning stated that the gauge was-past the calibration due date and should not be issued. A check of other M&TE indicated that this was an isolated finding.
The licensee maintained a state of the art metrology lab, part of which was shielded from extraneous magnetic fields. The inspectors reviewed the calibrations of a few M&TE items, and noted that they were in calibration and were traceable to National Bureau of Standards.
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3.4 Review and Evaluation of Previous Maintengnce The inspectors reviewed maintenance donc previously.
The corrective maintenance dono during the 18 months from January 1, 1989 consisted of 7,361
,
work requests. The licensee performed 5,166 preventive maintenance (PM) tasks in the same period.
3.4.1 Backloa Assessment and Evaluation The inspectors reviewed the amount of work accomplished compared to the amount of work scheduled.
Emphasis was placed on work that could affect the operability of safety-related equipment or equipment important to safety,
which included some B0P components. Maintenance WR backlogs were evaluated
for cause and impact on safety.
_
Both CM and PM backlogs were assessed.
The maintenance backlogs were tracked by the planning and schedulir) c oup. This information provided management with indicators of performance in maintenance and allowed management to maintain oversight of backlom. and to detect trends in backlog levels, Overall, both CM and PM backlogs appeared to be well controlled and were well t
{
within the capabilities f the maintenance staff.
3.4.1.1 Corrective Maintenance Backloo in evaluating the CM backlog, emphasis was placed on non-outage related work.
The total non-outage CM backlog at the beginning of the refueling outage was 718 WRs. This backlog increased to 937 WRs at the end of the outage.
The CM work requests, held for parts as of November 8, 1990, were 107. Of these, 72 were held for more than 90 days.
The WRs held for parts included 33 safety related jobs and did not appear to have an adverse effect on the plant safety.
The licensee appeared to adequately control the non-outage CM backlog, as it amounted to approximately five weeks of work with the existing staff levels.
Although some CM work requests were rescheduled, the inspectors identified no
,4 significant CM that had been inappropriately deferred.
3.4.1.2 Preventive Maintenaace Backloa T' 9 non-outage PM backlog at the beginning of the outage was 8 WRs in the eiectrical and 1&C areas.
An additional 12 PMs were in the backlog at the end of the outage.
The PM backlog was extremely low and did not appear to have any significant effect on the safety of the plant.
The initial PM program was based on vendor recommendations.
The licensee initiated a RCM study in August 1988. The study included a description of the system and maintenance events / failures on the equipment.
An RCM package for each system was developed and included any recommended PM program and frequency changes.
For instance, in the CCW system, PMs were reduced from 84 to 51 tasks based on results of the RCM analysis.
The licensee completed the RCM studies for 35 systems, of which about 50 percent were safety related systems.
Even though the PM reduction was considerable, the licensee intended to
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maintain the RCH as a live program, with inputs from all concerned personnel.
The licensee also planned to review the PM program every three years, based on the industry experience in this area.
While the licensee's RCM program was generally very good, the inspectors noticed that this program did not include the 1&C maintenance area.
3.4.2 Review and Evaluation of Completed Maintenance The inspectors selected equipment and systems identified in Section 3.1.2 of this report for further review.
The purpose of this review was to determine if specified electrical, mechanical, and I&C maintenance on the selected systems / components was accomplished as required.
In each maintenance discipline, this review included one or more of the following:
Evaluation of work procedures for completeness, adequacy of work instructions, acceptance criteria, inclusion of vendor requirements and recommendations, QC hold points, ease of use, necessary approvals, and general conformance to NUREG/CR-1369.
Evaluation of completed CM and PM for use of qualified personnel, proper prioritization (based on risk), QC involvement, quality of documentation for machinery history, description of problems and resolutions, and post-maintenance testing.
Evaluation of the extent that vendor manual recommendations, NRC Bulletins, NRC Notices, and other out;ide source information were utilized in the development, correction or upgrading of the maintenance process.
Evaluation of the extent that maintenance histories, LERs, negative trends, rework, extended time for outage, frequency of maintenance, or results of diagnostic examinations were analyzed for trends and root causes for modification of the PM process to preclude recurrence of equipment or component failures.
3.4.2.1 Past Electrical Maintenance The inspectors reviewed 12 completed electrical WRs for the attributes included in Section 3.4.2.
P408012 Calibrate auxiliary feedwater (AFW) to steam generator flow transmitter P436514 Perform motor megger in accordance with procedure MTI-22-QN003 P449298 Calibrate undervoltage and over current relays P449963 Clean, inspect and test breaker NG0304 P450259 Calibrate protective relays
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P452875 Calibrate NB01 bus relays
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P455399 Test breaker NG0307
P455400 Clean, inspect and test breaker NG0306 P456019 Clean and inspect breaker to motor control center (MCC)
S471492 Perform molded case breaker functional test
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$479804 Calibrate potential transformer bistables
$484977 Perform weekly surveillance of 125V DC battery The WRs. included a description of the failure or problem and the work l
performed.- Post maintenance test requirements and criteria were specified on the WR.
Prioritization was proper and QC involvement was excellent.
Necessary procedures and the calibration status of M&TE were included in the work packages.
Documentation of corrective action was sufficiently detailed
- for proper trend identification and root cause analysis.
The licensee was conservative when changing out parts or components that were near the end of useful life.
Rather than extend the life of the components 11 harsh and mild environments by evaluations, parts were replaced.
This was considered a
- strength.
Concerns were identified with a lack of a trend program for polarization index and megger data and inadequate test equipment for testing load center 480V breakers.
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P428353'- The licensee did not always document insulation class or trend _
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b polarization index and megger data.
The procedure required that the polarization index for. equipment 4160 volts and higher be determined.
A review of several WRs associated with procedure MTE ZZ-QN003 indicated
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that all the motors tested met the acceptance criteria.
However, the procedure established one set _of criteria for Class A insulation and a higher value for Class B, F and H ins 11ations.
The inspector reviewed
- several WRs that measured the aclarization index and found'that the
insulation class required by tie procedure was not always filled in.
L addition, the licensee did not trend the polarization index or'the
. In
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megger data derived from procedure MTE ZZ-QN003 or other procedures
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whero the megger readings were taken as part of a PM.
W136288 -1This WR involved the testing of the load center 480V breaker
with an inadequate test set.
Section 5.29.7.1 of Procedure MPE-ZZ.
Q5002, " Cleaning, Inspection and Lubrication of G.E. 480V Breakers,"
-Revision-9, required that'the ground fault relay be tested with a test..
- current of 1.6 amps and a time delay between O' 065-0.150 seconds.
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-However, the test set used had a maximum output of 1.505 amps and the
- timer was accurate to only one half second.
The licensee stated that this-issue was previously identified in audit report AP-89-005. The audit report also-suggested that the ground = fault relay test-be deleted since the_ operability of the breakers could be determined from other time delay testing.
However, since August 1989, the licensee continued
- to test the 480V breakers using the same test set.
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The inspectors reviewed the following electrical maintenance procedures:
ISL-NF-NB02A
" Loop Miscellaneous:
NB021 Degraded and Undervoltage to Load Sequences," Revision 8 ISP-SA 2413B
" Diesel Generator and Sequencer Testing," Revision 5 MPE-ZZ-QS002
" Cleaning, Inspection and Lubrication of GE 480V Breakers," Revision 9 MPE-ZZ-QS009
" Testing of Molded Case Breakers, Starters and Ground Fault Relaying," Revision 6 MPE-ZZ-QYlll
" Operational Testing of 4.16kV Diesel Generator NE01 Air Current Breaker 153NB0ll)," Revision 3 The procedures contained QC hold points, vendor recommendations, and PM frequencies, and in general, were found to be satisfactory.
The licensee's PM program had net included molded case breakers (MCB) except in circuits that penetrated containment.
Consequently, many MCBs were not tested since plant start-up. However, as a result of a set point change initiated by Engineering Change Notice (ECN) 88-1023, the licensee discovered that many MCBs would not trip during testing when subjected to fault currents.
The licensee determined that the failure rate was approximately four times the industry average.
The licensee was investigating the possibility of changing all molded case breakers with a different model and including the MCBs in the PM program.
3.4.2.2 Past Mechanical Maintenance The inspectors reviewed nine WRs:
S458015 Inspect emergency diesel generator W103349 Install live-loaded packing, main steam valve, ABHV0014
l W103641 Install live-loaded packing, steam generator blowdown valve, BMHV0004 W120266 Change safety injection pump A oil filter head gasket W121157 Inspect torque switch for melamine material on valve EMHV8801A0 W124473 Tighten body to bonnet bolting on valve EGHV0053 W124474 Disassemble and inspect valve EGHV0053 W127877 Change out actuator spring compensator housing on valve EMHV8801A0
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W130656 Repair leak on CCW pump inboard bearing In general, the WRs were found to be satisfactory and documented QC involvement.
The inspectors paid particular attention to the post maintenance testing requirements specified on the WRs.
Testing appeared appropriate and complete.
One weakness noted was in the lack of documentation of as-found conditions and work performed.
Short, inconclusive summaries were often given with no details on as found conditions or troubleshooting performed that could be beneficial in performing root cause analysis.
For example, a report
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initiated to review corrective actions on recurring problems associated with the condensate chemical addition pumps stated that because of incomplete or limited scope documentation, potentially, not all of the troubleshooting results were considered.
Fortunately, because of the pervasiveness of the problem, enough detail was provided to identify root cause.
One concern was noted with regard to the handling of completed WRs and documentation as discussed below:
W103349 and W103641 - The inspectors reviewed the completed WR for the original installation of the live-loaded packing for two valves performed in 1987.
In each case, the completed WR contained the incorrect valve survey sheet that identified the incorrect number of Belleville spring washers used in the installation of the live-loaded packing.
There appeared to be loose control with regard to the handling of these valve survey sheets, which could affect future work activities.
The inspectors reviewed the following procedures for adequacy of work instructions, acceptance criteria and inclusion of QC hold points.
MPM-FC-QK002
" Auxiliary feedwater Pump Turbine five Year internal Inspection," Revision 4 MPM ZZ-QA001
"Limitorque Operator Inspection and Lubrication,"
Revision 16 MSM-KJ-QK001
" Emergency Diesel Generator inspection," Revision 12 MTM ZZ-QA006
"Limitorque Actuator Limit Switch and Torque Switch Adjustment," Revision 17 MIT-ZZ-00010
" Motor Operator Valves," Revision 2 OSP-GK-00002
" Control Building Pressure Test," Revision 3 The inspectors verified that the vendor recommended or required actions were included or adequately addressed in the appropriate maintenance procedures and that adequate evaluations for deviations had been made.
One strength was noted in the identification of QC hold and inspection points and is discussed l
in Section 3.9.3.
3.4.2.3 D st instrument and Control Mq.intenance
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The inspectors reviewed ten completed WRs:
P453947 Calibrate Bourdon tube pressure indicator on safety injection test line P453979 Calibrate safety injection system test line flow indicator S453367 Perform loop calibration of safety injection accumulator tank "A" pressure transmitter S453503 Loop calibration of S/G "C" main steam outlet upstream protection
$454021 Calibrate containment protection channel
"B" high range area radiation detector S454463 Calibrate containment atmospheric pressure protection set 3 5482650 Perform functional test on radiation waste building CCW supply protection channel
"B" flow transmitter S483104 Perform functional test on control room HVAC radiation transmitter Wl34180 Calibrate ultimate heat sink pond temperature recorder W135582 Install containment protection channel "B" high range area radiation detector The WRs were satisfactory in scope and content.
Prioritization was proper and QC involvement generally adequate.
Documentation of corrective action was sufficiently detailed for trend identification and root cause analysis when combined with other historical plant data.
Post maintenance testing was properly identified and was satisfactory in scope.
In a significant number of instances, the inspectors noted that even though calibrated M&TE was logged, the M&TE calibration check off block on the WR cover sheet was not marked.
The following procedures were reviewed:
"I&C Functional Test Surveillance Procedure for Control Building Supply Air Radiation Detector,"
Revision 9 ISL-EP-0P961
- 1&C Loop Calibration Surveillance on Accumulator Tank
"A" Pressure," Revision 3 ISL-GN-0P935
"I&C Loop Calibration Surveillance Procedure for Containment Pressure Protection," Revision 4 ISL-GT-00R60
"I&C Loop Calibration Surveillance Procedure for Containment High Range Area Radiation Monitor,"
Revision 7
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"l&C Generic Procedure for Calibrating Bourdon-Tube Pressure Indicators," Revision 2 The procedures were well written and consistent with vendor instruction manuals.
Acceptance criteria were adequate and provided actions to be taken if not met. A review of selected vendor manuals indicated that the vendor recommendations on preventive maintenance and calibration were generally included in the licensee's procedures.
Based on the review of completed corrective and preventive maintenance, backlog, and procedures, the inspectors concluded that past performed maintenance had been accomplished in a satisfactory manner.
3.4.2.4 Past Fire Protection Activities The inspectors reviewed selected portions of the following completed surveillances for the attributes included in Section 3.4.2:
MSE-KC-FW001
" Fire Detection functional and Supervisory Operability Test," Revision 13 OSP-KC-00003
" Fire Suppression Water System Valve Cycling,"
Revision 2 OSP KC-00004
" Fire Suppression Water System functional Test,"
Revision 2 OSP KC 00007
" Fire Hose Station Visual Inspection," Revision 9 The completed surveillances and corrective actions were found acceptable.
3.5 Fire Protection Controls The inspector reviewed the qualifications of the fire protection engineer, which were appropriate for the position. The inspectors reviewed fire protection audits and observed that management involvement was evident by the adequate resolution of the items identified by the audits.
No discrepancies were identified in this area.
The inspector reviewed the administrative controls regarding the storage of transient combustibles, flammable / combustible liquids, and flammable gases as described in APA ZZ 00741, " Control and Transportation of Combustible Material." Revision 9.
The inspector also reviewed the administrative controls regarding cutting and welding as described in APA-ZZ 00742, " Control of Ignition Sources," Revision 8. The inspector determined that-the procedure-was adequate to limit the amount of. combustibles and flammable / combustible liquids and control cutting and welding activities in safety related areas of the plant. The inspector reviewed self contained breathing apparatus (SCBA)
procedure HTP-ZZ-08300, "MSA Respirator, Supplied Air Hood, and SCBA Inspection and Storage," Revision 12, for the inspection of the SCBA equipment used for fire fighting.
In addition, the inspector observed the licensee perform an inspection of one SCBA.
No unacceptable conditions were observed.
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The inspectors observed approximately 20 emergency lights of which
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twelve were noted to have deficiencies.
One emergency light (QD 084)
did not function when tested.
The electrolyte level in four emergency lights (00 086, 00 088,00-293 and 00 294) was halfway between the add line and the bottom of the battery, in addition, the electrolyte level in six other emergency lights (Q0 054, QD 072, QD 083, 0D-302, 00 340
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and 00-341) was approximately one inch below the add line.
One
. emergency light battery (QD-298) had corrosion around the vent cap.
~ The licensee conducted a yearly inspection of the emergency light batteries. This inspection consisted of the manufacturer's recommended monthly proceduro that included (but was not limited to) verifying adequate electrolyte level and checking battery terminals for corrosion.
The licensee concurred with the inspector that.the present maintenance schedule was inadequate.
The inspector also indicated that.the manufacturer recommended an annual eight hour. discharge test that
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ensured emergency lights would function when needed.
The licensee's failure to establish an adequate maintenance
>
schedule for the-emergency lights as required by Section-10.5 of the Supplemental Quality Assurance Program for fire protection to assure acceptable-conditions for emergency lights is considered a violation-'(483/90017-Ol(DRS)).
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The licensee did not perform a drop test on fire dampers.
Visual
inspections were performed to determine operability =of the fire dampers. The licensee informed the inspector that a sample of fire dampers would be dropped tested during 1991.
Based on review
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l of fire damper concerns and the results of this test,. the licensee I
would evaluate the need to conduct periodic fire damper drop i
testing'to insure-operability of-the fire damper.
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3 '. 6 Maintenance 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 L
control of maintenance work orders, equipment maintenance records, job it planning, prioritization and scheduling of work, control of maintenance l
backlog, maintenance procedures, past maintenance-testing, completed documentation, and review of work in progress.
L
' The inspectors observed the daily outage planning. meeting where the plan of
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the day and maintenance activities were discussed by plant management.
This
- meeting-.provided a means for prioritization of work, resolution'of problems
- and: scheduling--of necessary resources to-expedite critical work.
The inspectors concluded that this was an effective method of plant management oversight.
The maintenance schedule was based on a rotating 12 week schedule. A detailed one week schedule was also issued and was updated daily, based-on the daily-
-meetings.
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The planning group reviewed the WRs, walked down the plant, prepared work packages and interfaced with the work groups.
The planners reviewed applicable sections of vendor manuals and verified parts availability and tools required.
The planners also listed procedures and drawings applicable to the work on hand and, based on established guidelines, included the QC hold and witness points.
After work was completed, the signed off work package was reviewed for NPRDS reportability and sent to the documentation center for filing. The work packages generally included space for comments from the work crew / foreman for commenting on any special problems encountered, lhe planning and scheduling groups appeared to be knowledgeable and competent.
A special feature at the plant was rotating a shift supervisor as the scheduling supervisor on a periodic basis.
This arrangement appeared to help the scheduling group process work smoothly with operations.
Trending of WRs was performed in the planning and scheduling department using the Repeat Maintenance Status Report.
Before a WR was planned, work history for the past 12 months was reviewed.
If similar failures were noted, the planner submitted a Repeat Maintenance Form to the appropriate system enginea for information and review.
A bi-annual report was issued to plant management in the form of a Repeat Maintenance Status Report. This report listed all of the repeat maintenance items on a sliding 12 month window.
Component problems were divided into four resolu+1on categories:
(1) design change request, (2)
improved repair method / material implemented or planned, (3) problem not resolved - review continuing, and (4) low plant impact, low repair tenhours, or apparent isolated problem.
The most recent report indicatd (nat 1.2%,
(67) of the WRs completed between July 1, 1989 and June 30, 1990 were repeat maintenance.
Eleven trended failures resulted in a design change or improved repair methods.
The repeat maintenance program appeared to be effective in identifying problems that would not have been flagged by other means.
Another effective trending program was governed by procedure EDP-ZZ-04012,
" Equipment Failure Trending and Analysis," Revision 7.
Under this program WRs, NPRDS items, and Nonconforming Material Reports (NMR) were tracked and trended.
An annual compilation was performed and reported to plant management.
Because Callaway had an extensive equipment identification system,. failure reports could be compiled based on system, component type, manufacture type, specific component identification, or NPRDS failure code.
The trending program was considered a strength because of the diverse reporting options.
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3.7 Enaineerina Suonort of Maintenance
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l Although overall engineering support was considered a strength, the licensee L
did not have a program or method for systematically tracking electrical load growth to the diesel generator and the station batteries.
The inspector reviewed the electrical loads added since the plant became operational and determined that the additions did not challenge the design basis calculations.
Examples of strengths were as follows:
Predictive maintenance programs such as thermography and transformer oil
analysis, which included both safety related and 80P electrical
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IO components, were in place.
Configuration control was considered above average.
- The licensee nad a good vendor manual control program.
The licensee had about 2,100 vendor manuals on file, of which approximately 400 were for safety related equipment.
A vendor equipment technical information program (VETIP)
coordinator was appointed in October 1990 and assigned responsibility to review and update vendor information in response to NRC Generic Letter 90-03.
The inspectors reviewed the activities of the engineering organizations maintenance support.
The organizations involved were System Engineering and Maintenance Engineering.
3.7.1 System Enaineerina The system engineering concept had been implemented since the startup phase of operation.
Responsibilities included review of PM requirements and frequencies, surveillance testing, predictive maintenance results and trends, stock spare part inventories, and root cause failure analysis using system performance trending.
Several root cause analyses were examined and found to be detailed and thorough.
System engineers also coordinated and directed system outages and major outage related activities that involved vendor expertise. The inspectors found the system engineers cognizant of ongoing work and/or problems on assigned systems.
Because of an effort to develop expertise within the staff, many engineers were dedicated to special programs such as MOVs/M0 VATS, IST, and check valve performance.
Experience was noted in the department, in that, engineers' average nuclear experience was eleven years and average Callaway experience was four years performing engineering duties. Many had previously held Shift Technical Advisor (STA) positions at the station.
All engineers exhibited technical and administrative knowledge consistent with prior plant experience and length of system assignment.
In addition, system engineer involvement in the maintenance p.mcess was evident.
One weakness noted was in the large backlog of RFR documents.
Although none of the backlogged RFRs appeared to be of significance, the inspectors were concerned that this backlog was increasing.
The licensee had previously identified this as a concern and had taken appropriate measures to resolve and reduce the backlog. A 1991 goal will be implemented and will require a six month time clock between initiation and resolution.
The inspectors identified a significant strength in the 7300 process system engineer's informal component trending process.
The 7300 system engineer maintained a log of all component failures within the 7300 process cabinet in the system notebook.
The informal component trending, while identified as a strength, contained some innerent disadvantages with respect to administrative control of the review process, however, the system engineer appeared to maintain good control of this review.
Overall, the inspectors concluded that the licensee had a good system
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Overall, the. inspectors concluded that the licensee had a good system engineering program and that engineers performed in a manner compatible with safe and reliable plant operation.
3.7.2 Maintenance Enaineerino Callaway utilized four maintenance engineers, one electrical and three mechanical, with primary responsibility for maintenance field work.
Large maintenance jobs that involved Callaway personnel were managed by a maintenance engineer.
Responsibilities also included certain dispositions of NMRs and maint,ance procedure development and revision.
Although there appeared to be a fine line between the responsibilities of a system engineer and a maintenance engineer, the difference was clearly understood and followed by both departments.
During this inspection, maintenance engineer involvement was evident.
Problems or questions were discussed with system engineers, when appropriate. The biggest strength noted was the excellent rapport between the maintenance staff and tne maintenance engineer.
All of the maintenance engineers had at least six years experience at Union Electric in engineering type positions.
The engineers received much of the same training that the craft received and each had an area of expertise.
3.8 Maintenance and Support Personnel Control Training and qualification records were reviewed for maintenance personnel that participated in maintenance activities witnessed by the inspectors.
The inspectors determined that personnel were trained and qualified to perform the assigned maintenance activities.
3.8.1 Trainino and Oualifications The licensee's new training facility consisted of three laboratories for electrical, mechanical and I&C areas.
It also included a machine shop and a health physics laboratory, in addition to several class rooms and offices for the teaching staff. The training facility had mock ups and equipment for training purposes, but most of the equipment would be installed in the new location after the refueling outage.
The training staff included four senior training supervisors and 29 training supervisors.
Some of these training personnel were drawn from I&C, health physics, operations and maintenance disciplines, and appeared to be qualified
.to the training jobs.
The training department met with plant management twice a year to assess the training needs of the different departments.
Training was provided in Human Performance Evaluation System (HPES) to plant -
personnel.
The plant had a procedure on root cause analysis, but the training department had not commenced training-in this area.
The inspectors reviewed the training program and lesson plans and concluded that the licensee's training program for the maintenance and supporting personnel was very good.
3.8.2 Contractor Control The licensee's contractor control appeared to be weak.
Problems noted were
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inadequate communications between the supplier quality group in the corporate office and the engineering staff at the site and inadequate verification of contractor personnel qualifications, as required by the licensee's procedures No. APA 22-00407, " Control of On-Site Contractors," Revision 4.
An unqualified welder was used for code related welding on the RTD bypass modification work during October 1990.
The contractor QC inspector signed off that the welder was qualified for the weld procedures, without actually virifying the welder's qualifications.
This welder was used on six different wolds. All the welds were inspected and were found acceptable.
The licensee issued suggestion occurrence solution (SOS) No. SLSP 1132 on October 30, 1990, identifying this occurrence.
The welder was tested on November 1, 1990, and was qualified to the weld procedure.
Although the welds were accepted as satisfactory, the root cause for the unqualified welder, and the failure to identify this problem prior to the actual welding on 6 occasions was still being investigated at the conclusion of this inspection.
3.9 Review of Licensee's Assessment of Maintenance The inspectors evaluated the licensee's quality verification process in the maintenance area by the review of audit reports, surveillance reports, and QC inspections. The documents were reviewed to assess technical adequacy, root cause analysis, and timeliness of corrective action.
The quality assurance (QA) organization at the plant included one superintendent, five supervising engineers, and 28 other QA engineers /
scientists.
The staff turnover rate of five QA engineers per year appeared to be somewhat higher than in the other areas of the Callaway plant.
Based on interviews and audit findings, the QA engineers were experienced and appeared to be knowledgeable.
3.9.1 Audits and Surveillances The licensee's Quality Assurance Department conducted approximately 35 audits per year of which two were in the area of maintenance.
In addition, about 200 surveillances were conducted each year, of which about 30 were in maintenance related areas.
The inspector reviewed 8 audit reports and 10 surveillance reports conducted during the last two years.
Audits were performance based and included observation and verification of work where appropriate.
The audit reports documented both strengths and weaknesses noticed during the audits /surveillances. Where deficiencies were noticed, Requests for Corrective Action (RCAs) were issued and tracked for completion of adequate corrective actions.
3.9.2 Self Assessment
'
The inspectors reviewed the report of the licensee's self assessment of
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maintenance, conducted in January, 1988.
The assessment evaluated eight of the maintenance evolutions described in INP0 guidelines for conduct of maintenance at nuclear power plants. The team observed that the self assessment was primarily performance based and that each action item was identified by number and tracked to a satisfactory conclusion.
Based on the review of the licensee's self assessment report and the results of this inspection, the team concluded that the licensee's self 'ssessment was effective.
in addition to the QA audits and surveillances, a Joint Utility Management Asses: ment (JUMA) conducted a detailed review of plant maintenance.
The JUMA report included several recommendations for improvement of plant maintenance.
The Safety System Functional Assessment (SSFA) conducted for the RHR system during June,1990 reviewed maintenance of this system and made recommendations for enhancement of maintenance.
The findings of these large team inspections, which encompassed all departments, were personally followed up by the manager of Callaway Plant. The completion of corrective actions to the findings and recommendations of these important team inspections was also tracked.
3.9.3 Ouality Control Sunnort The plant quality control organization consisted of one QC supervisor, three assistant QC supervisors and 14 QC inspectors.
Even though the staff level was modest, it appeared to be adequate and well utilized.
The QC inspectors always covered the QC hold points and most of the witness points.
Interviews with maintenance personnel indicated that QC was very supportive of maintenance and was available on backshifts.
The QC inspectors and supervisors appeared to be knowledgeable and conversant with the codes and procedures applicable to their work.
The inspector reviewed the 00CM, which gave detailed guidance in the QC inspection requirements, inspection assignments and for the inspection performance.
These instructions were very detailed and helped both the work planners and the QC inspectors in planning inspections.
The team noted that a WR, which required QC activity, typically included a copy of the 00CM pages that were applicable for the work performed.
This was considered a strength by the team. Another strength identified by the team was the licensee's " Quarterly QC Inspection Tracking Reports."
The QC department maintained a test laboratory in the main warehouse with equipment capable of comparing different steels, testing for hardness, analysis of metals, and determination of base compounds in elastomers, oils and greases.
This equipment was useful in testing bolts, nuts, springs, o-rings, gaskets, seal rings, and was also useful in upgrading commercial grade items.
4.0 Synopsis This synopsis highlights the inspection findings in terms that are meant to be representative of the inspection tree that is attached to this report.
A (+)
indicates that the area is good or has potential to be so; a (-) indicates that the area is weak, needs improvement, or is not fully developed.
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4.1:
Overall Plant Performance (Direct Measures)
'4.1.1 Historical Data l
(+)
The forced outage rate was less than half the established goal.
Plant capacity factor was exceeded and LERs were less than established goals.
4.1.2 Elant Walkdowns (+)
Motor operated valves appeared to be well maintained as evidenced by
'
newly lubricated stems and gear case grease fittings.
.,
(-)
Several instances of broken or defective plant equipment was (.bserved;
'
broken flexible conduit, bent instrument tubing, missing valve hand
- wheels and misaligned drain pipe.
l t
' (-)
Bird nests on cable trays near essential service transformer.
j (-)
Tools unattended in containment.
(-)
T:.
loose ground wires on. battery NK-13 with a possibility of touching-
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-
bt.ttery terminals.
4.2'
Manaaement Suncort of Maintenance
4.2.1.
Manaaement Commitment and Involvement (+)
Management's policy of rotating personnel assignments promoted i
cooperation between departments, reduced departmental friction and
'
- contributed to maintenance effectiveness.
l (+)
Quar.terly Quality Control tracking report provided an excellent method l
of reoorting repetitive quality control problems in the Inir.tenance area to management.
'
4.2.2 Manaaement Oraanization and Administration I
(+)
Extensive QC _ lab for assessment of materials and for upgrading i
_
commercial grade items.
'
(+).'~ maintenance effectiveness and component suitability, Repeat Maintenance Statut Report-.was an excellent too1~for evaluating.
,
i
- 4.2.3
' Technical Support
'(s '
An experienced radiological controls person attended planning meetings, reviewed maintenance work packages and modifications that involved-dose
.
producing jobs'and proposed facilities changes for ALARA requirements.
'
(+)
Callaway.had an extensive predictive measures program that included j
vibration and lubricating oil analyses, thermography, acoustic
- monitoring of valves, erosion / corrosion measurements and thermal h
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_ performance monitoring administered by-system engineering.
(+)
.Well qualified and experienced engineering staff.
System engineers averaged-eleven years nuclear experience and four years at Callaway and
=3intenance engineers averaged six years engineering experience on site.
(+)
Experienced and qualified QA staff.
(+)
Additional maintenance assessments were conducted using a Joint Utility Management Assessment and a Safety System Functional Assessment.
Correcti_ve actions were followed up by the plant manager.
'(+)-
QC coverage was very supportive of maintenance and available for all
= hifts.
s
'
_(+)
Operations Quality Control Manual (00CF.) provided detailed instructions for inspecting various maintenance activities, which assured uniform quality for each inspection _activily.
.
4.3 Imnlementation of Maintenance 4.3.1 Work ~ Control-
.
(+)
The trending program for NMRs, WRs and NPR0s was' considered a strength.
(+)
Backlog of non-outage ccrrective maintenance work requests was low, about five weeks.
Preventive maintenance backlog was very low, only eight work requests at the beginning-of the 1990 outage.
-(+).
'Use of LRCM methodology to evaluate PM. requirements for 35 systems
'
reduced PMr considerably' in some systems.
j
- (+)
-shift supervisor;used for leading scheduling work improved an already
'
competent _ pl anni _ng. group.
L(-)
Inadequate maintenance of emergency lighting resulting in one failed light' and ten _ lights with low battery-electrolyte levels.
( -_ ) ' Inadequate work package controls.
The team observed two work crews performing maintenance vithout WRs at the job. site.
The resideni, inspection staff' identified three work crews without WRs at job site, i
4.3.2-Plant Maintenance Oraanization (+)
-Well equipped parts -dedication '. laboratory for upgrading' commercial grade parts and components for _ safety related application.
.
,
4.3.3'
Maintenance Facilities. Eauioment and Material' Control-(+)_
New and_-remodeled maintenance facilities had improved productivity and
- bility_ of shops to more adequately support plant operability goals.
a
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(+)
Large warehouse facilities enhanced receipt inspection, issuance of bar coded parts, good segregation of parts on hold, tool control and the shelf life program.
(-)
Safety and non-safety related items stored on the same shelves.
4.3.4 Personnel Control
(+)
Interviews and observations of work indicated that personnel were
,j e
knowledgeable of their responsibilities and were accountable for their per'Ormance.
Staffing appeared to be appropriate to maintain Callaway in an operablo condition.
(+)
Training of maintenance personnel was appropriately balanced between formal training, self study and on-the-job training.
(+)
The new training facility labs, class rooms and offices should enhance the training of the maintenance department.
(-)
Training in root cause analysis not yet initiated.
(-)
Contractor control was weak as evidenced by the use of an unqualified welder on the RTD bypass work.
(-)
Poor communications between the supplier quality group in the corporate office and plant personnel.
5.0 Exit Meetina The team leader met with licensce representatives (denoted in Section 1.0)
on November 20, 1990 and summarized the scope and findings of the inspection.
The team leader discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the team during the inspection. The licensee did not identify any such documents or processes as proprietary,
\\
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APPENDIX A ACRONYMS AFW Auxiliary Feedwater ALARA As Low As Reasonably Achievable B0P Balance of Plant CCW Component Cooling Water System CM Corrective Maintenance DCR Design Change Request ECN Engineering Change Notice EDG Emergency Diesel Generator EPRI Electric Power Research Institute ESFAS Engineered Safety Features Actuation System ESW Essential Service Water HP Health Physics HPES Human Performance Evaluation System I&C Instrument and Control INP0 Institute of Nuclear Power Operations IST Inservice Testing KV Kilo Volt KW Kilo Watt JUMA Joint Utility Management Assessment LER Licensee Event Report M&TE Measuring and Test Equipment MCB
' Molded Case Breaker MCC Motor Control Center M0V Motor Operated Valve MOVATS Motor Operated Valve Analysis and Testing System NMR Nonconforming Material Report NPRDS Nuclear Plant Reliability Data System NRC Nuclear Regulatory Commission 0QCM Operations Quality Control Manual PM Preventive Maintenance PMT Post Maintenance Test POD P1an of the Day QA Quality Assurance QC Quality Control RCA Request for Corrective Action RCM Reliability Centered Maintenance RFR Request for Resolution
,
RHR Residual Heat Removal RT Radiographic Test RTD Resistance Temperature Detector RWP-Radiation Work Permits SALP-Systematic Assessment of Licensee Performance SCBA Self Contained Breathing Apparatus SOS Suggestion Occurrence Solution SSFA Safety System Functional Assessment STA Shift Technical Advisor VETIP Vendor Equipment Technical Information Program WR Work Request
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