IR 05000498/1993053
| ML20059F728 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/06/1994 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059F712 | List: |
| References | |
| 50-498-93-53, 50-499-93-53, NUDOCS 9401140131 | |
| Download: ML20059F728 (19) | |
Text
.- . - . .. . . _ . - ..
.
APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV j
NRC Inspection Report Nos.: 50-498/93-53 50-499/93-53 Licenses: NPF-76 NPF-80 Licensee: Houston Lighting & Power Company
-
P.O. Box 1700 Houston, Texas 77251 Facility Name: South Texas Project Electric Generating Station (STPEGS),.
Units 1 and 2 ;
Inspection At: Matagorda County, Texas ,
Inspection Conducted: November 29 to December 10, 1993 Inspectors: M. A. Satorius, Project Engineer, Project Section A, Division of Reactor Projects M. F. Runyan, Reactor Inspector, Engineering Section, Division of
'
Reactor Safety (DRS) .
L. D. Gilbert, Reactor Inspector, Maintenance Section, DRS i Approved: \ All A b 7 ProjEcf SEET1on A Date :
W. D Johrs inspection n Summary
.
Areas Inspected: Routine, announced inspection to determine the effectiveness of the licensee's efforts to reduce and maintain the maintenance backlo i Results:
- No violations or deviations of NRC requirements were identifie ,
. The licensee had made notable progress in reducing the service request (SR) backlog and the material condition of the station had !
'
improved significantly during the past 6 months. However, the inspectors considered that the achievement of the licensee's goal of less than 1000 Common and Unit 1 SRs and the subsequent management of that maintenance backlog, given the planned shift of maintenance resources to Unit 2, was a significant challenge (Section 2.1).
.
9401140133 940106 gDR ADOCK 05000498- -
. , . . . - - .
. . - . . - - - . -
. _ - - - -- -= .- ._
.
'l
'
!
-2- ;
!
- Licensee activities to repair station automatic functions and main control board deficiencies was viewed as a positive initiative (Section 2.1.3). .
.
- Although well behind schedule, the maintenance procedure upgrade program should improve the quality of maintenance procedures (Section 2.2).
- The Operations Work Control Group had been effective in reducing the l administrative burden on control room operators (Section 2.3.2.1). ,
- The Maintenance Rover Work Program was considered a good initiative,.and !
that program's success was regarded as pivotal in the licensee's efforts to improve maintenance activity efficiency and reach and maintain the SR '
backlog goal (Section 2.3.2.1).
- The licensee's walkdowns conducted as a part of their system ;
certification and acceptance programs were generally effective in ;
problem identification; however, the inspectors noted several examples of poor resolution of identified deficiencies and inconsistencies in ,
identification of deficient conditions (Section 2.4). !
- The planned maintenance (PM) deferral rate was less than one percent and i had trended at that level for the past 6 months (Section 2.5).
l
- With the exception of two deferred SRs that constituted operator work-arounds and several relatively minor coding errors, the licensee's deferral process was effective (Section 3.1). ;
- SRs voided to PMs were being appropriately tracked to ensure that deficient conditions were not being removed from the SR backlog prior to =
being corrected (Section 3.1).
- Nonsystem certification and acceptance systems were being effectively monitored for deferral of maintenance activities (Section 3.2). ,
Summarv cf Inspection Findings:
<
- Inspection Followup Item (IFI) 498;499/9331-07 was statused concernin the SR issues and remained open (Section 4.1). .
- IFI 498;499/9331-08 was statused and remained open (Section 4.2). .
i
- IFI 498;499/9331-09 was statused and remained open (Section 4.3).
- IFI 498;499/9331-79 was statused and remained open (Section 4.4).
- IFI 498;499/9331-37 was statused and remained open (Section 4.5).
- IFl 498;499/9331-38 was statused and remained open (Section 4.6). ,
i
,
,~e ...w...,_ p ,
7,y . _ , ,
- . . . . .- .- - .. .- -. .. . . .. - - . - . ..
I
.
-3-I e IFl 498;499/9331-39 was statused and remained open (Section 4.7). .l
- IFI 498;499/9331-47 was statused and remained open pending the '
licensee's initiative to repair all inoperable automatic functions prior to the restart of Unit 1 (Section 4.8). * IFI 498;499/9331-49 was statused and remained open (Section 4.9).
- IFI 498;499/9331-62 was statused and remained open (Section 4.10).
. IFI 498:499/9306-07 was statused and remained open (Section 4.11).
= IFI 498;499/9331-02 was closed (Section 5.1).
!
- IFI 498;499/9331-03 was closed (Section 5.2).
- IFl 498:499/9331-80 was closed (Section 5.3).
- IFl 498;499/9331-29 was closed (Section 5.4).
. IFI 498;499/9331-62 (fourth bullet) was closed (Section 5.5).
Attachment:
- Attachment 1 - Persons Contacted and Exit Meetin9
l
I i
>
f I
l
! ,_ ,_ _ _ . . . -._ - _
.
h
_4_
'
DETAILS
!
1 BACKGROUND Both units at STPEGS were shut down in early February 1993 and remain shutdown as a result of numerous broad scope problems identified by the NRC and the ;
license .
NRC Inspection Report 50-498/93-31; 50-499/93-31, issued on October 15, 1993, identified 16 restart issues that required resolution prior to the restart of Unit 1. In addition to these restart issues, a number of items related to these restart issues were identified. The purpose of this inspection was to determine the licensee's effectiveness in resolving Restart Issue No. 3, ,
" Service Request (SR) Backlog, Including Reduction Accomplished During the l
!
Current Outages and the Licensee's Review of Outstanding SRs for Issues Affecting Equipment Operability, Safe Plant Operation, and Operator 1 Work-arounds," and to establish a basis for concluding that this Restart Issue l had been adequately resolved by the license ACTIVITIES ASSOCIATED WITH MAINTENANCE BACKLOG REDUCTION (92720) ,
t 2.1 SR Backloo Reduction Achievements and Challenges The inspectors reviewed various licensee SR backlog documents in order to assess their progress in reducing backlog numbers and managing the conduct of work activitie I 2. Current SR Backlog As of December 7,1993, there were no Priority 1 SRs and only 65 of the !
approximately 1200 open SRs for Unit 1 and Common were assigned a Priority 2 1 by the Operations Work Control Group (0WCG). Most of these SRs had been !
generated in the last 6 months and were assigned a Priority 2 ranking because )
of known scheduling and work restraints. The projected completion dates for i the Priority 2 SRs were consistent with the date scheduled for completion of l the current outag The status of the open SR backlog was documented in the daily report of the plan-of-the-day meeting conducted by plant management. At these meetings, t status of the oldest 10 SRs for each maintenance department (electrical, mechanical, and instrument and control (I&C)) and the associated restraints were discussed with management. The SR backlog reduction trend was also included in the plan-of-the-day report for management consideration and tracking of the goal to reduce the SRs to less than 1000 prior to resumption of power operation of Unit The licensee had significantly reduced the Unit I and Common SR backlog for both corrective and preventive SRs from approximately 3000 at the beginning of 1993, to approximately 1200 currently in the power block and support system l This reduct4on has been accomplished with a sustained SR generation rate of j
!
, . - _ , _ _-_
. _
.- -
. . - - -- -. . . .. - - - . .
t
{
i
.
I-5-
,
approximately 25 SRs per day and a net reduction of approximately 5 SRs per ;
day, or approximately 25 SRs per week. The inspectors determined that, based t on solely on current projections and consistent management attention, the goal -
of reducing the SRs in the power block and support systems to less tha >
1000 SRs (corrective and preventative) prior to resumption of power operation l was achievabl . SR Backlog Challenges [
!
'
During the review of the SR backlog, the inspectors determined that there were several external challenges to the positive workoff trend which confronted the ;
licensee. The. first challenge consisted of the artificiality of the ,
maintenance resources available for Unit 1. Since the licensee had begun ,
actively addressing the maintenance backlog, station maintenance personnel had i been concentrated on Unit 1, in order to reduce the backlog in Unit 1 in support of restart. As the backlog was reduced, it was the licensee's plan to shif t resources to Unit 2, in order to work off that unit's backlog in support i
. of its eventual restart. Current plans by the licensee had 116 maintenance l craf tsmen being moved from Unit I to Unit 2 by January 3,1994. According to i the licensee's latest and best information, the average manhours required to i work off an average SR was approximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per job. The inspectors :
'
'
concluded that based on the number of maintenance personnel being moved and the average manhours required per SR, the trend in backlog reduction could be !
impacte >
The second challenge to the licensee's efforts to reduce the backlog consisted )
of their commitment to completely work off the system certification and acceptance program walkdown punch lists (refer to Section 2.4 for a discussion ,
i of the system certification and acceptance program walkdown punch lists).
Although the items on these punch lists were typically minor, generally not
,
safety-related, and could be worked with minimal planning, they nevertheless constituted work activities that required maintenance resource The third challenge to the backlog reduction effort involved the anticipation I of a relatively large influx of new work as Unit I changes modes and restores j equipment that has been out of service for an extended period of tim j
.
As a result of a review of the current SR backlog and in view of the challenges to continuation of the workoff rate, the inspectors concluded that '
it may be difficult for the licensee to reach and maintain their committed goal of less than 1000 Unit 1 and Common SRs. More important than the numerical goal is the potential impact of deferred maintenance items on equipment reliability and operators performance. -This will be reviewed during a future inspectio . Automatic and Main Control Board Function Backlog Activities The inspectors reviewed the status of all SRs involving automatic functions to determine if necessary work was performed to ensure that no significant impact on system operability or operator burden existe l
. - - -
-. ..
. -, - - - - . . . . - - -
. ,
.
-6-
,
At the time of this inspection, there were 16 automatic functions in Unit I and common that were inoperable. Of these, 11 were scheduled for repair prior to entry into Mode 4, and 4 were scheduled for completion before Mode 3. The repair of one automatic function was not scheduled, but the licensee stated that all automatic functions would be made. operable during the startup of the :
'
units. The licensee stated that all engineering work necessary for closure of the Unit I functions had been complete ,
The inspectors considered the licensee's commitment to resolve all discrepancies associated with automatic functions to be appropriat The inspectors reviewed a summary of the outstanding inoperable automatic functions in Unit I and noted that most of the functions involved nonsafety-related equipmen At the time of this inspection, the licensee's status report indicated that 43 discrepancies affecting the main control board of Unit 1 (and common)
remained open. The licensee stated that all of these problems would be corrected at some time during the startup of Unit 1. According to the status report, 26 items would be completed prior to Mode 4, 3 by Mode 3, l'by Mode 1, and 7 by 100 percent power. The remaining six items were not attached to a mode restraint but would be worked at some point during the startup, according:
to the licensee. The mode restraints were generally tied to the conditions needed to perform postmaintenance testin The inspectors considered the licensee's intention to address all Unit I and common control' board discrepancies during startup to be appropriate. The inspectors reviewed a summary of the open issues and identified no concerns 4 related to the completion schedule for each specific item. In particular, l those items delayed until 100 percent power appeared to be justifiably l scheduled, either by plant conditions needed for the work or because the item i was of minor significanc .2 Maintenance Procedure Upgrades ,
Previous NRC inspections revealed that work procedures occasionally were ,
cumbersome and were sometimes not properly used during performance of the work. Additionally, work procedures were found to contain numerous errors that required the performance of time-consuming revisions before the work ,
<
could be complete To address these deficiencies, the licensee took two actions; one designed to improve the quality of newly written procedures and the other to revise the existing procedures to meet a desired level of succinctness, clarity, and precision. The licensee revised the' planners guide, which became effective on October 1, 1993, as Revision 0. This document was revised to provide improved guidance on developing work instructions and preventive maintenance tasks with a focus on eliminating unnecessary information. The inspectors reviewed the revised planners guide and noted that while being very brief on detail it
- . . -- - .. - .- -
_-. _
.
l
.
t-7-
contained some useful guidelines for preparing efficient, accurate, and i
'
user-friendly procedures. It was not possible at the time of the _ inspection i
l to evaluate the effect the new guide will have on future procedure The project to upgrade existing procedures was contracted to a vendor:
specializing in procedure writing. Out of a total population of approximately 700 maintenance procedures, categorized in the three areas of mechanical, I electrical, and I&C maintenance, the licensee selected 275 of the most safety -
l sensitive for review. At the time of the inspection, the project was well l behind schedule. Despite several contingency actions taken by the contractor, the licensee was not confident that the originally proposed completion date of
'
April 1994 would be met. A similar project to upgrade surveillance procedures was in the initial phase of implementation. This project, which will involve a complete rewrite of approximately 1120 surveillance procedures, was under contract negotiation and had a completion target date of December 199 l The licensee performed an assessment of the maintenance procedure upgrade project, issuing a report dated November 19, 1993. The assessment emphasized the fact that the project was behind schedule but indicated that the initial :
feedback from the craft upon review of the new procedures had been positiv ;
The inspectors reviewed several of the newly revised maintenance procedures and compared them to the previous procedures they replaced. Several '
improvements were noted including the provision of a table of contents, new and more clarified figures that were placed next to the relevant procedural step instead of at the back of the procedure, additional initial blocks for attesting completion of procedural steps, and better clarity in the overall presentatio .3 OWCG Activities The licensee established an OWCG, which was an operations department organization, on May 25, 1993, as an initiative to remove administrative burdens from the control room staff and to improve the work control proces In addition to removing administrative burdens on the control room staff, the 0WCG was created to screen, validate, and prioritize SRs at the time of initiation; review and authorize ready-to-work maintenance activities; review completed work; coordinate postmaintenance tests; and make recommendations to the shift supervisor concerning the return to service of systems and components following maintenanc . OWCG Staffing Although presently augmented with additional personnel, the 0WCG was chartered to consist of the following staff:
. .. ._ _ _ _ . _ _ .
.
-8- ,
Position Qualifications Supervisor Licensed Senior Reactor Operator
,
Work Start Coordinator Licensed Senior Reactor Operator Equipment Clearance Order Licensed Reactor Operator Coordinator Work Screening and Closure Licensed Senior Reactor Operator Coordinator Scheduling Interface Maintenance Department Experienced Planners (2) Experienced Planners Walkdown/ Discipline Specialists Experienced First Line Supervisors (3 - One per Discipline)
The licensee had intentionally staffed the 0WCG with many of their more experienced licensed operators and maintenance discipline specialists. The licensed operators who were chosen to staff the 0WCG were all relatively senior licensee personnel, with significant station experience. In addition, the maintenance discipline specialists had previously served as maintenance first line supervisors and possessed extensive maintenance training certifications. The inspectors viewed the licensee's 0WCG staffing selections as a positive management initiativ .
2.3.2 OWCG Administrative Activities The inspectors reviewed OWCG activities and interviewed members of the 0WCG 3 staff in order to determine the level of performance of the group with respect to improvement of the work control process and in removing administrative burdens from the control room operator .3. OWCG Interface With the Control Room Staff The inspectors determined that OWCG activities had removed significant administrative burdens from the control room staff. Equipment clearance order preparations, an administrative activity formerly conducted by the control .
room staff, had been moved to a responsibility of the 0WCG. This move had resulted in less administrative requirements placed on the control room operators, which permitted them to focus more on the operation of plant '
equipment. In addition, the work screen, start, and closure responsibilities '
had been shifted from the control room staff to the 0WCG. This shift of responsibility had also reduced the administrative burdens on the control room staff by a significant degree. The inspectors concluded that the licensee's actions to reduce the administrative burdens on the control room staff had been effectiv ,
b
-
e
.
'
i
_g_
2.3.2.2 OWCG Effectiveness in Improving the Work Control Process The 0WCG Management Guide, a written but nonproceduralized guide for the operation of the OWCG, provided direction to the 0WCG staff in the performance of their activities. The management guide designated the 0WCG supervisor as i the responsible individual for. implementation of work management. From a t strictly work control process perspective, the 0WCG supervisor oversaw the validation and accuracy of identified material problems, in order to establish ,
the urgency and appropriateness of the licensee's corrective action respons This effort was to particularly ensure that issues that required immediate or short-term actions were worked expeditiously, and those of lesser importance were worked at a lower, but suitable, priority such that the work control '
process productivity was improve The licensee had previously committed to develop a new methodology to properly characterize the existing backlog and newly generated SRs. The new !
classification system was placed in Revision 7 to Procedure OPGP03-ZA-0090, !
" Work Process Program," and consisted of categorizing SRs by work type, system ,
'
type, and priorit Five priority levels, six work type codes, and five system type codes were provided. During July and August of 1993, the licensee performed a review of Unit I and common SRs, resulting in several changes in priority and work type code j The inspectors reviewed a randomly-selected sample of SRs and found that the new codes were being applied in what appeared to be a consistent manner. The !
inspectors did not identify any concerns with the revised SR categorization codes. The screening, validation, and prioritization of SRs by the 0WCG staff, at the time of initiation, reduced the administrative burden on the control room staff and resulted in more consistent and appropriate characterization of SRs. The inspectors concluded that the licensee had satisfactorily addressed the NRC's concerns related to the characterization of SR The 0WCG Management Guide required that upon receiving an SR and following the initial screening by the 0WCG supervisor, the appropriate 0WCG discipline specialist would conduct a walkdown of the identified deficiency, ensuring that the discrepant condition described in the SR was valid and was adequately documented in the S Following the physical walkdown, the SR was assigned a priority and entered into the licensee's work management system databas After database entry the SR was either voided to a PM activity or a previousl,y identified SR and assigned an " awaiting to be voided" status; assigned to the maintenance planners for planning action; or voided to the Maintenance Rover Work Progra The Maintenance Rover Work Program was initiated to improve the timely resolution of low priority SRs that did not require detailed work planning and consequently improve maintenance productivit The program identified a specific individual in each of the three craft disciplines who was designated as that maintenance discipline's rover. After SRs were received by the 0WCG and walked down by the applicable 0WCG discipline specialist, those minor
.. . . . . -. -
,
._ ,
i
-10-I maintenance activities that were considered by the 0WCG discipline specialist to be within the abilities of skill of the craft were planned by the 0WCG '
planner and issued to the appropriate maintenance discipline's rover for wor These SRs were required to be worked within the shift that the SR was submitted to the 0WCG, and typically required less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to complete; a significant resource saver for the licensee which consistently required approximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> to formally plan and work an average SR. The inspectors considered that the successful implementation of this Maintenance Rover Work Program was critical in the licensee's efforts to reach and maintain the SR backlog less than the 1000 Common and Unit 1 SR In addition to the inspector's conclusion concerning the Maintenance Rover Work Program, the inspectors also concluded that the 0WCG was pivotal in the licensee's efforts to successfully manage the SR backlog and maintain the '
backlog size within their goals and at a level that would preserve system reliabilit .4 System Certification and Acceptance Process A detailed review of the licensee's system certification and acceptance programs was conducted by the resident inspector staff and documented in NRC Inspection Report 50-498/93-45; 50-499/93-4 . System Walkdowns A portion of the system acceptance program involved a physical walkdown by the ,
system engineer and a licensed operator from the operations department. As of this inspection, the walkdowns had been completed on 9 of the 63 systems in the system acceptance program. During this walkdown, punchlists of ;
discrepancies were generated. Of the 9 systems that had completed the _
,
walkdown, a total of 186 punchlist items had been generated. These identified discrepant conditions were not entered into the work management system as SRs, and varied in significance. Examples included damaged insulation, boric acid -
buildup on valve stems and bodies, damaged or degraded paint and preservation, station problem reports that required resolution, and material conditions that would require a significant expenditure of resources to correct. In addition, station management stated that these punchlist items would be 100 percent ,
'
complete prior to the restart of_ Unit 1, or SRs would be generated for any remaining unfinished punchlist item The inspectors pointed out that many of the items included on the punchlists !
were maintenance backlog items that were being tracked under a separate system and effectively masking the actual SR backlog size. The inspectors' basis for ,
this observation was that although much of the work was minor and was capable ,
of being accomplished under the Maintenance Rover Work Program, it nonetheless ;
constituted maintenance activities that would require resources to complet l The licensee stated that it was not their intent to mask the SR backlog by '
implementing the system punchlists and further stated that they did not consider the workoff of the punchlist items to diminish their effectiveness in
,
e , -
. _ _ __ _ ._ _
.
i
'
.
-11-
\
reducing the SR backlog. The inspectors concluded that the licensee's commitment to complete all punchlist items or to generate SRs for any incomplete items prior to Unit I startup was acceptabl . Systen Walkdown Effectiveness 3 The inspectors reviewed the punchlist for the chemical and volume control system, a system that had been one of the first to undergo the system acceptance walkdown and one of the systems furthest advanced in the acceptance process. The chemical and volume control system system walkdown had resulted in a total of 32 punchlist items being identified. The inspector's review indicated that 10 of these items remained open with 22 having been worked and subsequently reported closed. In order to assess the licensee's effectiveness in working and closing the punchlist items, the inspectors performed a walkdown to verify that the corrective action taken to address the items was adequate. Of the 22 closed punchlist items,10 items were located in contaminated or high radiation areas and were not inspected during the wal kdown. The inspectors checked the remaining 12 items for thoroughness of completion and discovered that in 4 of the items that the licensee had closed ,
the discrepant condition had 6ct been removed. These items all consisted of boric acid buildup on valve stems and bodies and all four of the concerned valves had been inadequately cleaned. When informed of these findings, the licensee was unable to provide an explanation of these apparent inadequate punchlist work activities; however, they speculated that the boric acid buildup had been cleaned and due to an active leak on the valve, boric acid had reformed on the valve. The licensee initiated SRs for these leak ;
.
In addition to these deficiencies, the' inspectors observed several other discrepant conditions that had not been identified during the sys c.? walkdow The cap to Valve CV-0592 was noted to have boric acid buildup, and appeared to be actively leaking on the floor under the valve. A fitting on the Instrument line upstream of CV-0030A was recorded on the punchlist as having boric acid buildup and had been successfully cleaned; however, a similar fitting upstream '
of CV-0031A, which was located approximately 6 inches from CV-0030A, had easily visible boric acid buildup yet had not been identified during the walkdown nor cleaned during CV-0030A's cleanin In Room 226, located in the mechanical auxiliary building, a Service Air Valve SA-0772 was not capped; the inspectors discovered the cap on a pipe hanger pedestal located in the center of the room. In Room 35, also in the mechanical auxiliary building, the ,
inspectors observed a significant leak on CV-0441 with large boric acid crystals being noted. In the positive displacement pump room, the inspectors discovered Temperature Element TI-9373 hanging loosely and unattached from ventilation ductin In the A train centrifugal charging pump room, only one ;
'
lighting fixture was operating and the room was dar Although these examples of material condition were not considered safety significant, they were indicative of a less than rigorous implementation of ,
station management's expectations for the system walkdown .
_ _ . . . _ _.__ _ _ _ _ _ ___
.
. ?
-12-l l
2.5 PM Deferrals The inspectors reviewed the status of the licensee's PM deferral rate. During ,
the period of January to March 1993, the licensee's PM deferral rate was .
excessive, with Unit 1 and Common PMs being deferred as high as 100 percent in l
March 1993. Since that time, the licensee had established a goal of less than three percent rate of deferra ,
The inspectors determined that the licensee had reached and maintained that PM deferral goal since April 1993, and typically defer less than one percent of i
, the PM i 2.6 Conclusions ,
The licensee had made notable progress in reducing the SR backlog and the ' l material condition of the station had improved significantly during the past 6 months. However, the inspectors considered that the achievement of the !
licensee's goal of less than 1000 Common and Unit 1 SRs and the subsequent i management of that backlog, given the planned shift of maintenance resources i to Unit 2, was a significant challenge to the license The 0WCG had been effective in reducing the administrative burden on control room operators. The inspectors viewed that the maintenance oversight provided i by the 0WCG was essential to the licensee's efforts to maintain and manage ,
their SR backlog. The Maintenance Rover Work Program was considered a good initiative, and that program's success was regarded as pivotal in the licensee's efforts to improve maintenance activity efficiency and reach and maintain the SR backlog goa Licensee activities to repair station automatic functions and main control 'l board deficiencies was viewed as a positive initiative. Although well behind t schedule, the maintenance procedure upgrade program should improve the quality of maintenance procedures.
'
The licensee's walkdowns conducted as a part of their system certification and l acceptance programs were generally effective in problem identification; however, the inspectors noted several examples of poor resolution of identified deficiencies and inconsistencies in identification of deficient . .
conditions. In addition, the system walkdown punchlists, though effective in improving overall system material condition, were adding to the maintenance l I
backlog. Although not intended to mask the actual SR backlog, the punchlists were challenging the licensee's efforts to reduce and maintain the backlo The PM deferral rate was less than one percent and had trended at that level
'
for the past 6 month l l
i r
'
?
!
,
- . - ~ r , p - y- - -
y m ,
. . _ . - .
s
.
-13-3 MAINTENANCE DEFERRALS (92720)
The inspectors reviewed various categories of the licensee's SR backlog, to determine if work was being deferred that would potentially reduce, or impair, the reliability of plant equipmen ,
3.1 OWCG Deferral Activities The inspectors reviewed all the current safety-related SR backlog items that t I
were deferred from the schedule for completion during the current Unit 1 outage. The categorization these deferred items was the responsibility of the ,
'
0WCG, with input from other licensee departments. Specifically, the inspectors reviewed on an item-by-item basis each SR associated with safety-related systems that was not scheduled for completion prior to the restirt of Unit 1. At the time of this inspection, the number of items in this deferral category was 8 r The inspectors ncted two SRs, HC-204298 and HC-309097, that were both associated with the main steam isolation valve cubicle ventilation system *
The problem described in HC-204298 consisted of a cubicle ventilation fan that did not automatically secure at the setpoint temperature of 68oF, and subsequently required operator action to manually secure the fan. HC-309097 '
described a related problem associated with a nuisance alarm that annunciated in the control room when the fan did not secure at the required setpoin ;
Neither of these SRs were scheduled for work during the current outage. The j inspectors questioned the 0WCG supervisor as to whether these problems ,
constif.uted operator work-arounds or distractions. The supervisor agreed that :
they were distractions to the control room operators and should be worked !
during the outage. Both SRs were subsequently rescheduled to be worked prior to Unit I restar '
In addition to these identified problems, the inspectors noted minor errors in the safety-related SR backlog items such as: 1) numerous coding errors where .
SRs were classified as corrective when they were actually preventive in nature, and vice-versa; 2) incorrect required plant modes indicated for when work could be accomplished; 3) incorrect plant identification numbers listed in the SRs; and 4) a significant number of SRs voided or waiting to be voided l to another SR or P The inspectors explored this last issue further. The inspectors' concern was'
that the SR backin<1 was being reduced by voiding active SRs to PMs, removing .
,
these items from the backlog, and the possibility that these PMs were not ;
scheduled or tracked with the same rigor that SRs receive. When a deficient ,
condition was identified and documented on an SR, the 0WCG discipline specialist would conduct a walkdown of the identified deficiency, in addition l to the 0WCG supervisor reviewing the SR (refer to Section 2.3.2.2 of this ,
report). A portion of the s Jpervisor's review consisted of determining if any equipment PMs, which were already proceduralized, were available that would address the problem identified in the SR. If a PM existed that addressed the !
deficiency, the SR was coded as waiting voidance, a reference to the specific
.
. . -
,
<
\
!
'
.
'
-14- l
!
l PM was documented in the SR, and the PM was called out. The SR waiting voidance was not removed from the backlog. Following completion of the PM, l the SR was voided from the backlog; however, the voidance did not remove the SR from the licensee's database, as equipment trending data was retained for l future reference and the voided SR was counted as a backlog reduction ,
'
accomplishment. Based on the inspectors' review of Procedure OPGP03-ZA-0090 and interviews conducted with the 0WCG supervisor, the inspectors concluded ;
that SRs in status " waiting voidance" were not actually voided until the work was complete I A further activity that the inspectors reviewed was whether the PMs called out to void SRs were effective in correcting the deficient condition. The inspectors randomly selected and reviewed the following PMs and the voided j SRs:
V0IDED SRs i
_P_M EM-1-CH-92001572 CH-315752 EM-1-DJ-87010547 DJ-209982 i FW-315459 :
MM-1-FW-86012507 MM-1-MS-92000335 SR-308935 Based on the review and independent field verification, in each of these four examples, the PM was effective in repairing the deficiency identified in the S .2 Non-System Certification and Acceptance Process Deferrals
'
A detailed review of the licensee's system certification and acceptance programs, including the process of deferring maintenance activities, was conducted by the resident inspector staff and documented in NRC Inspection Report 50-498/93-45; 50-499/93-4 ,
t During this inspection, the inspectors reviewed a selected sample of deferred *
SRs from systems not included in the licensee's system certification and acceptance program. The purpose of this review was to determine if ;
maintenance affecting the reliability of these systems was being -
inappropriately deferre The inspectors selected the following systems and reviewed all the open SRs that were deferred and not scheduled for work during the current outage:
- Containment Combustible Gas Control
'
- 125-volt DC Class 1E Power
- Standby Diesel Generator Lube Oil ;
!
- Electrical Containment Penetrations
- 120-volt AC Class 1E Power
)
i
!
$
i m%~ e ,w-,- - * e ~ - -
. . .- ,. . ..
..
$
.
-15-
>
i Based on their review, the inspectors concluded that no deferred SRs would significantly impact these system's reliabilit .3 Conclusions With the exception of two deferred SRs that constituted operator work-arounds ,
and several relatively minor coding errors, the licensee's deferral process was effectiv ,
.
SRs voided to PMs were being appropriately tracked to ensure that deficient i conditions were not being removed from the SR backlog prior to being correcte t Nonsystem certification and acceptance systems were being effectively monitored for deferral of maintenance activitie .
4 STATUS OF ITEMS RELATED TO RESTART ISSUES (92701) ;
!
The following items related to Restart Issues were statused concerning the manner that the licensee had resolved the issue within the scope of the SR Backlog Restart issue. They will remain open pending further NRC inspection effort to completely resolve the items during future Restart Issue and other inspection .1 (0 pen) IFI 498:499/9331-07: The team found that maintenance and testing weaknesses reduced the reliability of safety-related and balance-of-plant eauipment The inspectors determined that based on the SR backlog reduction and the improved material condition of the station's equipment that the portion of '
this IFI that refers to maintenance weaknesses was closed. The part that refers to testing weaknesses will be addressed in another Restart Issue inspectio !
4.2 (0 pen) IFI 498:499/9331-08: Ineffective corrective and weak preventive maintenance significantly contributed to poor eauipment performanc l
. Although the SR backlog has been reduced, little safety-related and no balance-of-plant equipment has been returned to service; therefore, there was ' ;
no basis to conclude that these component's reliability had been improve < (0 pen) IFI 498:499/9331-09: Ineffective corrective maintenance. caused by inadeauate root cause analysis. Door prioritization of work. and poor craft performance. adversely affected safety-related equipment performance This item remains open pending the return to service of a sufficient number o safety-related system and the demonstration of improved equipment performanc .. .
-.
_ _ _ ___ _ _ _ _ _ _ _ _ ._
. .
.
-16- (0 pen) IFI 498:499/9331-79: Work procedures occasionally contained ,
unneeded information and did not match the experience of the individuals using the procedure Procedures were sometimes ignored and often revised to correct errors This item (refer to Section 2.2) will remain open pending additional progress
in implementing the Maintenance Procedure Upgrade Progra .5 (0 pen) IFI 498:499/9331-37: The coal for bnit I and common power block '
SRs is below 1000 This item remains open pending further NRC inspection (refer to Section 2.1).
4.6 (0 pen) IFI 498:499/9331-38: The goal for Unit 2 power block SRs is ,
below 850 The Unit 2 SR backlog was not reviewed during this inspectio .7 (0 pen) IFI 498:499/9331-39: There will be no outstandina SRs that ;
adversely affect plant safety or reliability (Priority 1 and 2) l This item remains open pending further NRC inspection (refer to Section 2.1).
4.8 (0 pen) IFI 498:499/9331-47: All SRs involving automatic functions will be evaluated and necessary work performed to ensure that no significant impact on system operability or operator burden exists. An_y remaining l inoperable automatic functions will be analyzed in the accregate to j ensure safe and reliable plant operation will not be unacceptably i impacted This item (refer to Section 2.1.3) will remain open pending the completion of the licensee's initiative to repair all inoperable automatic functions prior to the restart of Unit .9 (0 pen) IFI 498:499/9331-49: Management will review the number of components on increased surveillance testing frequency to ensure that the burden on operations and maintenance relating to the testino of these components will not adversely affect the safe operation of the plant This item will remain open because the number of ASME Section XI components o'n increased surveillance frequency remains high and does not meet the licensee's established goa I l
i
. __ _
.
i
,
.
'b-17- l
-!
4.10 (0 pen) IFI 498:499/9331-62: Criteria for Maintenance Effectiveness and :
Material Condition
- No outstanding SRs that affect unit safety or reliability - No ~
Priority is or 2 .
This item remains open pending further NRC inspection (refer to Section 4.7). l
- Demonstrate ability to manage maintenance workload - Total open SRs '
meets goal (less than 1000 in Unit 1) and workoff rate trend remains positiv This item remains open pending further NRC inspection (refer to Section 4.5).
- Changes in SR generation rate are evaluated and understood to ensure threshold for deficiency identification was acceptable - (SR ceneration rate is consistent with plant condition).
This item remains open pending further NRC inspection (refer to Section 2.1). l
. Main Control Board deficiencies - Goal (less than 10) met and trend remains positiv This item remains'open pending further NRC inspection (refer to'
Section 2.1.3).
+ Inoperable automatic control functions - Aggregate does not adversely affect operations ability to perform quality rounds and handle normal work load. Positive trend continuing in resolving inoperable function This item remains open pending further NRC inspection (refer to Section 2.1.3).
4.11 (0 pen) Inspection Followup Item 498:499/9306-07: Power'0perating Relief Valve (PORV) Block Valve The calculated thrust required to close the PORV block valves under dynamic conditions was based on an assumed valve factor of 0.45. Dynamic testing of these valves was not practicable. Testing of an identical valve under dynamic conditions at the Comanche Peak Unit 2 facility indicated an apparent valve' '
factor of 0.67. The licensee was asked to review the Comanche Peak data for applicability to South Texas The licensee's review indicated that there were no significant differences between the Comanche Peak and South Texas block valves and that the Comanche Peak test data should therefore be used as the basis for the valve factor assumption. In order to incorporate the higher valve factor into the design of the block valves, the licensee took several actions. The valve and actuator internals were inspected the valve seats were reworked, sharp edges
- - _-. . .
~ . - . - - . .. . _ _ _ _ _ _ _ _ _ _ .
l .
!
.
-18-on the internal guiding surfaces were broken or chamfered, and stem packing was changed to an improved type. The maximum expected differential pressure was lowered to 2315 psid based on the PORV reseat pressure of 2315 psid and the fact that there would never be a operational need to close the block valve above this pressure. The probability that an operator would misposition a block valve is low because the block valves operate automatically and the operators are not attuned to having to operate them. Nevertheless, pending NRC review of the mispositioning issue for pressurized water reactors, the licensee's position is potentially in variance to the intent of Generic-Letter 89-10. Based on calculations of required thrust and torque, the licensee determined that a stem friction coefficient of 0.2 under dynamic conditions would be acceptable. However, since the block valves can only be !
tested under static conditions, the licensee set a performance standard of j attaining a stem friction coefficient of 0.15 under static conditions to establish a margin to account for load sensitive behavior and stem lubrication degradation. In addition, the licensee intends to perform manual handwheel tests to determine whether the load sensitive behavior assumption is reasonable. The licensee stated that the actions described above including-all testing and analyses of the block valves would be completed prior to entry into Mode 4 for each uni The inspectors concluded that the licensee's actions to improve the performance of the PORV block valves and the conservatisms used in the ,
calculation of valve capability were sufficient to support plant startup, _ !
pending successful static test results. The remaining open issue is whether the block valves need to be designed for the possibility of inadvertent operation at higher differential pressures. This item will remain open pending NRC resolution of the generic mispositioning issue for pressurized !
water reactors, expected in early 199 l 5 CLOSED ITEMS RELATED TO RESTART ISSUES (92701)
The inspectors determined that the licensee's actions to address the following i issues was adequate. These items were considered close .1 (Closed) IFI 498:499/9331-02: Operators were significantly affected by l dearaded plant eouipment. including eauipment work-arounds and the administrative burden associated with the high rate of removal and return i of ecuipment to service , l Based on the establishment of the 0WCG and that group's effectiveness in removing administrative burdens from the operators and the improvement noted '
in the station's material condition (refer. to Section 2.3.2.1), this item was close . - - -
. _ . . _
. _
'
-,
.
-19- i 5.2 (Closed) IFI 498:499/9331-03: The shift supervisors and their control room staff could not effectively maintain the proper focus and overview of plant operations because of their participation in administrative programs and resource-intensive surveillances The item was closed based on the actions taken by the licensee to close IFI 498;499/9331-02 (refer to Section 5.1). ; (Closed) IFI 498:499/9331-80: Management support to maintenance was ;
poor, reducing the effectiveness of the maintenance process and auality '
of the maintenance effort Licensee management's focus on maintenance has generally been good with effective oversight (refer to Section 6).
5.4 (Closed) IFI 498:499/9331-29: A new methodology will be developed to ,
properly characterize the existing maintenance backlog and newly generated SRs Based on the action taken by the licensee (refer to Section 2.3.2.2) this item was close ,
5.5 (Closed) IFI 498:499/9331-62: (fourth bullet) Criteria for Maintenance Effectiveness and Material Condition -l
,
- PM deferrals analyzed and corrective actions in progress - Goal (less than 20) met and trend remains positiv Based on the action taken by the licensee (refer to Section 2.5) this item was close ASSESSMENT OF MANAGEMENTS RECEPTIVENESS TO IDENTIFYING AND CORRECTING PLANT PROBLEMS (92720) l The inspectors determined that licensee management had responded in a i proactive manner to the-issue of the SR backlog. Although the actual size of the backlog had been reduced, the licensee's ability to maintain the backlog within manageable levels has yet to be fully determine !
)
- -.. - -. - _ _ - -
,
-
.
i
.-
l t
ATTACHMENT 1 f
1 PERSONS CONTACTED
- Licensee Personnel l
!
J. Blevins, Supervisor, Records Management and Administration i R. Caldwell, Assessor, Planning and Assessment T. Cloninger, Vice President Nuclear Engineering K. Coates, Manager, Unit 2 Maintenance
-
,
'
I W. Cottle, Group Vice President, Nuclear P. Creveling, Director, Project Controls ,
R. Ferguson, Contract Engineer, Nuclear Licensing :
J. Groth, Vice President, Nuclear Generation J. Gruber, Manager, Unit 1 Work Control
!
S. Head, Deputy, General Manager Nuclear Licensing J. Johnson, Supervisor, Quality' Assurance L. Martin, General Manager, Nuclear Assurance L. Myers, Plant Manager, Unit 1 K. Richards, Manager, Unit 2 Work Control i
'
P. Schimpf, Assessor, Planning and Assessment J. Sheppard, General Manager, Nuclear Licensing ,
'
D. Stonestreet, Manager, Outage S. Thomas, Manager, Design Engineering i
!
K. Taplett, Manager, Quality Performance L. Taylor, Senior Consultant, Maintenance Support !
R. Tennant, Director, Nuclear Purchasing and Material Management D. Tower, Supervisor, Quality Assurance C. Walker, Manager Public Information L. Walker, Licensing Engineer, Nuclear Licensing W. Waddell, Manager, Operations Support K. Wissman, Engineer, Material Technical Service Nuclear The personnel listed above attended the exit meeting conducted on December 10, 1993. In addition to the personnel listed above, the inspectors contacted other personnel during this inspection perio ;
2 EXIT MEETING
'
An exit meeting was conducted on December 10, 1993. During this meeting, the inspectors reviewed the scope and findings of this report. The licensee did ,
not identify as proprietary any intormation provided to, or reviewed by, the inspector ,
. . - - - . -. _
- -
. . . .. -_