ML17261A929
| ML17261A929 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/29/1990 |
| From: | Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| NUDOCS 9002060118 | |
| Download: ML17261A929 (14) | |
Text
Docket No. 50-244 JAN 2 8 3990 Rochester Gas and Electric Corporation ATTN:
Mr. Robert C. Mecredy General Manager Nuclear Production 49 East Avenue Rochester, New York 14649 Gentlemen:
Subject:
Maintenance Program Team Inspection This letter is to inform you that the NRC intends to perform a team inspection of your maintenance program at the R.E.
Ginna Nuclear Power Plant, Ontario, New York, on April 9, 1990 through April 20,
- 1990, and to request your assistance in accomplishing this task.
The inspection will focus on the performance of maintenance and whether components, systems and structures of your plant are adequately maintained and properly repaired so that they are available 'to perform their intended safety function..
In order for us to properly prepare for the inspection and maximize the onsite time spent in observation of maintenance in progress, we request that you furnish the reference material identified in Enclosure 1 to this letter.
To assist you in the gathering of the requested reference material, we have enclosed a Maintenance Inspection Tree (Enclosure
- 2) which is used, by the
- team, as guidance during the inspection.
The team leader will be contacting a
member of your staff shortly regarding the information that will be needed prior to the start of the inspection and to arrange a suitable date for a meeting to explain the inspection and assessment methodology.
A copy of the NRC Temporary Instruction 2515/97 "Maintenance Inspection;"
Revision 1 is enclosed for your information and to aid in the preparation for the inspection (Enclosure 3).
Thank you for your cooperation in this matter.
If you have any questions regarding this matter, please contact Walter Baunack at (215) 337-5175 or Robert Gallo at (215) 337-5291.
Sincerely, Agg<i:7!gZggc~lr,.
Robert M. Gallo, Chief Operations Branch Division of Reactor Safety 0001.0.0 OFFICIAL RECORD COPY BAUNACK/GINNAMTI/1/10/90-01/25/90
Rochester Gas and Electric Corp.
Enclosures:
1.. Request for Material 2.
Maintenance Inspection Tree 3.
- NRC Temporary Instruction 2515/97 Maintenance Inspection cc w/encl:
Harry H. Voigt, Esquire Central Records (4 copies)
M. Baunack, DRS N. Blumberg, DRS
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York, SLO Designee bcc w/encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
A. Gody, NRR (w/o encl)
J.
- Chung, NRR (w/o encl)
J.
- Dyer, NRR (w/o encl)
DRP Section Chief A. Johnson, PM, NRR J.
- Johnson, DRP E.
DRS: RI DRS: RI Baunack/ajk u
rg
~I")
01/Zij/90 01 i/90 D
Ga o
01/490 0002.0.0 OFFICIAL RECORD COPY BAUNACK/GINNAMTI/1/10/90-01/25/90
ENCLOSURE I To aid us in the preparation for the maintenance inspection, please provide us with certain documents, procedures, administrative controls, and information which are needed to prepare for the inspection.
We request that you provide your pertinent documents covering each of the elements on the Maintenance Inspection Tree (see Enclosure
- 2) to include your management and administrative controls, procedures, instructions and guides.
Experience has shown that providing the requested information in accordance with the elements on the inspection tree makes the preparation for the inspec-tion less difficult for both yourself and the team.
If you do not have a
document for any specific item within an element, it is not necessary to
~ generate it to comply with this request.
The blocks on this tree identified as 1.0, 2.0, etc.
need not have any information provided by you. It is recognized that some documents may be applicable to a number of elements.
For these, it is only necessary to provide the document for one element and only list it for the other elements for which it also applies.
Also, to aid in the planning of the onsite portion of the inspection, please provide us with the appropriate contact for each element.
In addition to the information provided in accordance with the elements on the inspection tree, to fully prepare for the inspection, we also request that you include, for our review, the following information.
Any of the below listed information provided in accordance
'with the tree elements need.only be listed and not separately provided.
Please provide three sets of the requested documents.
A member of our staff wi 11 contact a member of your staff regarding the best method of transmitting the documents to us.
Additional Re vested Information Description of methods by which maintenance performance is measured.
Are performance indicators used?
What are they?
Who is informed of the reports that are used to assess maintenance performance.
Description of process for communications with vendors for technical services and latest technical information on equipment and systems installed at the
- plant, and interfaces with equipment and NSSS vendors for training, modifi-
- cations, and equipment replacement.
Documents which describe the preventive maintenance and predictive maintenance programs.
Which equipment is included?
How is maintenance frequency determined?
What is done with results of these maintenance actions?
The number of craft personnel for electrical, mechanical, and I&C maintenance organizations.
Please include foremen and the foreman to craft ratio.
The average years of experience for each individual and the turnover rate.
Description of shift work and work assignments.
How do'icensee supervisors decide on which craft or contractor is to perform what type of work?
Identify significant equipment failures which occurred during the last two years, include those identified during the last refueling.
Describe the maintenance and testing of diesel generators and class lE electrical equipment.
Provide the following status concerning Maintenance Work Orders (MWOs).
Current total listing and status of MWOs, number in planning, number in final sign-off, number on hold for lack of parts, number on hold for engineering assistance, number available to be worked on.
Projected number of corrective MWOs to be outstanding at 'start-up by priority.
Rate of completion of corrective MWOs in terms of number completed per month and manhours expended (by craft) per month for the past 12 months.
k Current number of preventive maintenance work orders overdue.
Rate of completion of preventive MWOs for the past 12 months.
Estimated manhours required to complete current preventive maintenance MWOs.
Number MWOs requiring rework over the past six months.
Provide five corrective maintenance procedures for work that is scheduled for the outage (e.g.,
- MOVs, PRVs, Solenoid Operated Valves, Safety/Relief
- Valves, ECS Pumps, Batteries, Switchgear, etc.)
Provide five preventive maintenance procedures that are scheduled prior to your next scheduled outage.
Provide your overall maintenance schedule for the outage.
I ggpg ER ER Ri8 RW HR HR ER ggg ERR HS IH5 ERR EW ggQ pg$JJ
nclosure 3
~C
<p,R R(g>lWp
+
0
~ 9i I
UNITED STATES NUCLEAR REGULATORY COMMISSION WASklNGTON, O. C. 20%5 NRC INSPECTION iVIANUAL TEIIPORARY INSTRUCTIO~ 2515/97, REVISION 1'QEB HAIHTENAKCE INSPECTION 2515/97-01 PURPOSE This temporary instruction (TI) provides guidance for conducting a perfor-mance-based inspection of an established and implemented maintenance process at all operating nuclear power stations.
2515/97-02 OBJECTI VES The primary obiective of this TI is to determine whether all components,
- systems, and structures of nuclear power plants are adequately maintaired so that they can be relied upon to perform their intended functions.
R Additionally, thi s TI should determine whether the maintenance process provides for the prompt repair of plant components,
- systems, and structures, as appropriate'- to their prescribed functions.
2515/97-03 BACKGROUNO NRC has examined their nuclear power plant maintenance progiams and has found a wide variation in their effectiveness.
Inadequate maintenance has been a
significant contributor to plant and system reliability problems
- and, thus, is a safety concern.
Analysis of 'operational events has shown that nuclear power plant components are rot being maintained at a level of reliability R
commensurate with thei r importance to safety.
This TI was developed tc inspect ard assess the effectiveness of maintenance at selected nuclear power plant sites.
A Ilaintenance Inspection Tree (tree) will be used as guidance during these inspections to collate and present inspection findings.
The tree is i~tended to provide a systematic approach to the performance of the inspections and to ensure a level of consistency.
R 2515/97-04 CONDUCT I HG TEAt! IhSPECT IOHS The maintenance team inspections will be announced when the tean:
leader prepares for the pre-inspection visit. (Section 04.01) to the site.
The full-scope inspection cycle vill generally be of a
6-week duration, with the team leader possibly taking an additional 2
weeks to initially coordinate the inspect~on, gather information, and issue the final inspection report.
Issue Date:
09/22/I.'9
~
The. 6 weeks of team effort shou generally consist of 1 week of eparation, I week of in-nffice inspection, 2 weeks of onsite inspection, and 2 weeks of documentation.
The sequence of the inspection effort will be determined by the regional off>ce.
For example, the 2 weeks of onsite inspection may be consecutive or separated hy 1 week of in-office inspection.
Generally, the inspection team wi'il be composed of the following six members:
one team leader (region) two reactor/project engineers (region) one radiation specialist (region)
Two englnceig (hg)
The team composition and/or the extent of effort for individual members may he adjusted by the region.
For example, the extent of involvement of the radiation specialist may be less than 6 full weeks, as determined by the regional office.
In addition, the regions may include involvement of the resident inspector (RI) to the extent that is normally covered by IP-62703 monthly examinations.
The RI should be provided training in the use of the logic tree by the appropriate team leader for this purpose.
The project manager (PH) will be generally involved with each inspection to the following extent:
be available to the team leader to facilitate contacts with the licensee attend 1 to 2 days of the team preparation attend final pre-exit team meeting attend exit meetings The team will determine wnat failures of significant equipment (probabilistic risk assessment (PRA)-identified, safety-related, or balance of plant (BOP) that affects safety-related and special interest items) have occurred and will inspect the licensee's trending and maintenance activities to schedule,
- repair, and prevent further failure of that equipment.
Other selective examinations of equipment failures attributed to maintenance will be examined to determine the adequacy of licensee corrective actions and root-cause determinations of the failures.
The inspection should be performed following review of the elements of the Naintenance Inspection Tree (tree) and the additional inspection guidance provided in the Yiaintenance Inspection Guid-,
ance Volumes I
and II (separately distributed).
This guidance should be used as an aid in determining adequacy and implementation of maintenance activities and to evaluate them.
The tree is also used as a tool to provide a
level of uniformity in inspection structure and in the preliminary recording of the inspection results.
It is important to stress that the tree does not drive the inspection, but it does represent guidance in the areas of inspection to be considered in planning the scope of the inspection, with inspection results recorded on the tree tn the extent completed.
The tree consists of three major sections:
('.)
Overall Plant Performance, (2) t'management Support of Maintenance, and (3) Vaintenance Implementation.
The inspection requirements for tiaintenance Implementation, which focus on the plant
- systems, components, test and surveillance
- data, and related activities, will receive the major portion (at least 80 percent.
including direct observations of maintenance heino performed) of the inspection effort.
Issue Date:
Q9/72/Q9 n4 2516i9",
It should be recognized ~
inspection resul ts from t
t1aintenance'mplementation area wi11 alsW5+provide input tn the Yiaragement
.support area.
It is expected that portions of the management Support of Maintenance sections',
of,. the
- tree, especiaTly ttie Yanagement Commitment and Management Organi'zation
- sections, could be conducted by a
single team menber in a
relatively short time.
The amount of inspection effort devoted to the individual subsections of the tree will be - determined by the regional
- office, taking into account recent inspection
- findings, time and staf.i limitations, and future inspec-tions planned to cover specific areas.
The inspection is tu determine the ev-.i:c;.iveness of the total integrated maintenance process of the power reactor licensees.
Therefore, the team inspection may be directed into areas for which explicit regulatory require-ments may not exist.
- Thus, the inspection is oriented toward analyzing the performance o.
maintenance activities rather than toward the identifi-cation of violations.
A specific example of an area not subiect to'xplicit requirements is the licensee's participation with the Institute of Nuclear Power Operations
( INPO).
Review of licensee resolution of INPO activities shall be conducted in accordance with established policy and, thus, observa-tions in this
- aree, when warranted, should be treated as indicators of strengths or weaknesses.
Although the inspection may result in the identification of inadequacies that are not covered by explicit regulatory requirements, there is no intent to "ratchet" licensees.
Individual findings that licensees are not following published NRC guides and industry guidelines do not necessarily indicate that a
program or area is inadequate.
The goal of the inspection effort is to emphasize the use of plant experience,
- test, reliability and surveillance
- data, component failures, PRA irsights (available to the licensee or provided to the team by the Risk Applications Branch),
and items of interest in evaluating the licensee's maintenance process in terms of capabilities and performance, and to identify major strengths and weaknesses as they are related to safety significance.
04.01 Team Leader Preparation.
A meeting should be held with the licensee to describe the scope of the inspection and to obtain preliminary review materials, such as the licensee's procedures for planninq, conducting and assessing maintenance, as well as organizational
- charts, work schedules, equipment lists, component failure and trending
- data, completed work orders, and related quality control
((}C) inspection procedures.
The material obtained by the team leader from the licensee should be distributed to the team members for their review.
Following completion of the in-office review of the licensee's maintenance'rocess, the team leader will discuss the results of these reviews with the team members and factor them into the plan for the onsite inspection.
64.02 Inspection Preparation.
In preparation for site inspections, the inspection team shou d review the elements of the Haintenance Inspection Tree to determine which areas may have received recent inspections, which areas may not be applicable, and which areas will be reviewed at the plant site.
The three major parts of maintenance (i.e.,
overall plant performance, management support of maintenance, and maintenance implementation) should be inspected to the degree requi red to provide a valid conclusion. regarding the effectiveness o1 the licensee's maintenance program.
?5}5/97 Issue Date:
09/22/89
During the preparation
- phas, the team should select several components and/or systems for detailed inspection either through consideration of available PPA
- insights, licensing trending
- data, component failures in safety-related or BOP systems that affect safety, or selected equipment of heightened interest to the Commission, such as check valves, motor-operated
- valves, solenoid-operated valves.
and air systems.
The PRA insights may be used to select components or activities whose potential failures are predicted to contribute most to the risk at that plant.
At least one high-risk system should be included to verify that all performance-related mair tenance has been accomplished, including preventive maintenance.
Equip-ment failures provide a vehicle for review of various aspects of maintenance, including root-cause andlysis~gnd trencin, equipment history, corrective
- actions, and past maintenanc<
preventive or ccrrective).
Inspection of i
failed equipment repairs or(
hark packages will provide the opportunity to examine the adequacy of the. >(teraction of all licensee functions supporting maintenance, including engineerinq analyses ano trending.
Review of performance indicator
- reports, previous inspection
- findings, 1 icersee event reports (LERs),
maintenance radiation exposure
- history, and other direct measures may identify potential weak areas at that plant f'r which more detailed inspection may be required.
Figure I
(Inspection Flowchart) depicts the initiators that may he selected to enter the tree.
R R
During the preparation
- phase, program strengths and weaknesses in certain areas may be recorded on the l1aintenance Inspection Tree (working tree).
If there are sufficient data to provide an evaluation rating during the prepara-
- tion, the elements should be rated in accordance with the maintenance Inspection Guidance.
However, selected items and, in particular, identified weaknesses should be verified during the onsite inspection, even if an evaluation rating is assigned during the preparation.
04.03 Onsite Inspection.
An entrance meeting shall be held with the licen-see tc Cetai the scope and schedule of the inspection, introduce the team members.
and establish the licensee's contacts for the inspection.
1he team should obtain from the licensee the status of ongoing work applicable to the inspection or that may affect the performance of the inspection or the inspection schedule.
Schedules and plans for the exit meetings and the interim meetings between the team leader and licensee management should also be establishea ouring the entrance meeting.
Team members shall perform a detailed walkdown inspection of the plant on the first or second day on site to observe the overall plant and equipment material condition.
This walkdown inspection, in which the team should observe the condition of numerous
- valves, pumps,
- motors, etc.,
should
- include, but not be limited to the following:
Condition of components Significance of tagged equipment Housekeeping and environment Adequacy of 'labeling Comparisons with drawings and/or procedures Status nf annunciators This walkdown inspection may provide indications of areas requiring further examination during the inspection.
~
Issue Date:
09/22/Pg 25i5/g7
The onsite inspection she focus on the direct observa on o
work in progress.
including the following ef licensee work with equipment in progress (e.g.,
- tagouts, procedures, wc rk
- packages, engineering
- support, materials, communications,
- testing, approvals, quality control holdpoints.
etc.),
significance of the maintenance
- backlog, rework, licensee assessment of the performance of maintenance, work control processes.
control of inter-
- aces, post-maintenance
- testing, plant material condition, ard maintenance facilities.
Qn the basis nf the collected
- data, the team should determine the apparent cause of any problems noted; that is, if the cause is related tn the adeouacy of procedures, work
- packaaes, quali ication of personnel, managemient, engineering, etc.
This analysis should provide entry into specific elements of the tree, which then becomes a tool to explore the suspected causes and to assess effectiveness of the implementation of applicable elements.
All areas listed need not. be used in forming conclusions.for each element.
Furthermore, other areas of inspection selected by the team may be used for entry to tree elements.
04.0c
~Ana'I sis.
Using the inspection findinas and results noted on the Maintenance Inspection
- Tree, the team should determine whether each of the areas inspected has been adequately implemented by the licensee and whether or not there is enough information to assign a rating.
The Maintenance Inspection Guidance and Criteria previously provided, also assists use of the Maintenance Inspection Tree.
The team will assion"a rating to thc applicable elements identified cn the work sheets.
The team should assign an overall evaluation rating to each of the elements inspected.
When this analysis has been completed, an overall rating can be determined in accordance with the Maintenance Inspection Guidance and Criteria.
04.05 Exit Meetin Before the final days of inspection,'ssues and findings s ou d
be reduced to definitive writing and then used to highlight the presentation version of the Miaintenance Inspection Tree (the Presentation Tree}
and to complete. the rating roll-up.
The exit meeting should include a
brief discussion of the preliminary inspection findings using the Presenta-tion Tree to depict inspection results in a
summary fashion;
- however, the licensee should be irformed that the findings are preliminary unti 1 they are reviewed by regional management and the inspection report is issued.
04.06 Report Preparation.
Because of the broad extent of the inspection, documentation nf inspection activities should begin early in the process to minimize the time required to complete the final report.
The final report should document the assumptions
- used, the elements inspected, the elements that were not applicablc, licensee strengths and weaknesses, and overall conclusions consistent with IMC-0610.
The report should address elements of the tree to at least the depth of the tier with eight areas (e.g..
Direct
- Measures, Management Conmitment and Involvement, etc.).
04.07 Follow Up.
Any unresolved findings identified during the inspection will be appropriate<y tracked arC resolved by the regioral office.
251519> Issue Date:
09/22/09
~
2515/97-05 Il<SPECTI Oi4 RE(}UIREHEhTS The inspectior. shall include selective examinations of the aspects of main-tenance listed in Sections 05.0i through C5.03; including each of the areas and related elements of.licensee activities identified under the sections.
To the 'extent possible, selective examinations should be based on observation of maintenance and equipment work activities in progress, review of licensee implementation of maintenance procedures and controls, results of'eview of selected documents (such as work packages, equipment test results, and engi-neering evaluations),
and interviews with personnel).
05.01 Overall Plant Performance Related to Maintenance a".
Direct Measures.
The team shall corduct appropriate examinations of plant operability, equipment availability, and plant material condition that can be directly related to the effective implementa-tion of a maintenance process.
I Before conducting the inspection of plant performance, the inspector should review available plant. information on (1) availability, (2) operabi 1 ity, and (3) reliability.
Information on these items can be obtained from the plant's.
operating history..
Other sources for obtaining the informa tion are SALP
- reports, Per orma nce Indicator Da ta, AEOD-Scram
- Studies, ESF Actuation
- Studies, Safety System Unavailability
- Studies, Technical Specification Violations, Monthly Operating Peport
- Data, and Capacity Factors from NUREG-0020.
Data collection should be directed to those measures related to safety significant aspects of the maintenance process.
In addition, the inspector should conduct a detailed walkdown inspection of the overall plant material condition to assess the effectiveness of the licensee's maintenance process to the extent that it is reflected in plant housekeeping and in the external condition of equipment.
The scope of the inspection should include examination of direct measures by using information gleaned from plant and equipment for the following:
Historical data Material condition 05.02 Mana ement Support of Maintenance a.
Mana ement Commitment and Involvement.
The examination of management ef ectiveness concerning maintenance should be directed tu deter-mining The extent of corporate and plant management awareness and support of the maintenance and resolution of maintenance problems and should include examination of:
b ~
The application of irdustry initiatives.
Extent of management direct participation in maintenance and in corrective actions (management vigor and example).
Vana ement Orqanization and Administration.
The inspection of management organization and administration controls should be directed to determining how the organizat.ion supports maintenance activities, what maintenance activity plan has been established, how the maintenance activity plan has been implemer ted, corrected, and controlled, and the control o
resources.
The inspection should include examination of:
t Issue Date:
09/22/89 2515/97
Program coverage for maintenance Policy, ooals, and objectives for maintenance Allocation of resources Definition of maintenance requirements Performance measurement Document Control System for maintenance Maintenance decision process c.
Technical Support.
The areas that are to be selectively examined for follows:
Internal and/or corporate comiunication channels Engineering control Licensee acknowledgement of risk significance Ouality control Incorporation cf radiological controls into maintenance process Safety Review Committees Reoulatory documents Trending Examples of the applicable departments or organizations subiect to this inspection are:
Engineeririg (nuclear, instrumentation and control
( ISC),
mechanical, electrical, licensing,
- systems, etc.)
equality Assurance (OA) equality Control (gC)
Health Physics (HP)
Safety Fire Protection Opera tiorzation s
ou e
directed to how the organization supports maintenance activities, how the maintenance activi ties are controlled, implemented, and corrected, how personnel are controlled, how the organization establishes documentation, the effectiveness nf'515/97 Issue Date:
09/22/89
a the coordination and edback lines o'f corrmunication between plant management.
ard craft personnel, and the effectiveness of interfaces with other departments, especia>ly nperations.
The irispectinn should include selective examination of:
Control of plant maintenance activities Control of contracted maintenance Deficiency identification, control, and corrective action system Maintenance trending Suppnrt interfaces c.
Maintenance Facilities, E uipment, and Materials Control.
The fol-lowing are to be selectively examined for the area of facilities, equipment, and material
- controls, as well as for thei~
support of the maihtenance process:
Maintenance facilities ar.d equipment Material controls Maintenance tnnl and equipment control Control and calibratior. of measurement and test equipment d.
Personnel Control.
The following areas of personnel control are to be se ectively
- examined, including consideration of
- staffing, trairring, and qualification:
Staffing control Personnel training Test and qualification process Assessment of the current personnel control status 2515/97-06 REPORTING REQUIREMENTS The appropriate regional office will document the tindings and the actiors taken in an inspection report
- and, in addition to the normal distribution, will forward one copy to the Director, Division of Licensee Performance and Quality Evaluation, Office of, NRR, and one copy to the Director, Division nf Reactor
- Safety, in each of the other regional offices.
A copy of the R.
Maintenance Inspection Tree colored to reflect the inspection results
<or P.-
each inspection conducted should be ser.t to the Chief of PQEB at mail stop R
10-A-19.
R 2515/97-07 COMPLETION SCHEDDLE Inspections should be scheduled so that they are completed prior to April, P.
1991.
2515/97-08 EXPIRATION This temporary instruction shall rema in in effect until April
)991 or R
Until the inspectiors have been completed.
issue Date:
09/22/89
.2515/97
2515/97-09 NRR CONTACT C
Any questions regarding this temporary instruction should be addressed to
'i A. T. Gody (301-492-1117).
2515/97-10 STATISTICAL ORTA REPORTING Record the'ctual time spent to perform this inspection against inspectior.
procedure number "5597 for the 766 system and 2515/097 for RITS.
2515/97-11 ORIGINATING ORGANIZATION INFORMATIC'N 11.01 Or anization Responsibilities.
The Performance and Ouality Evaluation Branch of NRR wi provide support and overall guidance for these inspec-tions.
11.02 Estimated Resources.
Each inspection is plarned for 6
weeks for 6 persons with 2 of the 6.weeks being direct onsite inspection (12 s'taff weeks) and 1
week in-office inspection, with expected additional effort by the team leader (a total of 38 staff weeks).
This total includes prepara-tion, inspection and report writing.
11.03 Parallel Inspection Procedures The inspection procedures that this TI may satisfy totally or in part are listed below.
Where credit is taken, the inspection report should note the inspection procedure number per INC-0610.
The region should make final determinations based on the scope= arid documentation of the inspectior.
37701 37702 37828 CIP 38701 30702 41400 56700 61700 61 725 62700 62702 62?03 CIP 62704 62705 72701 83000 series 92700 CIP 92701 2515/97 Issue Late:
09/2c./89